Fact Sheet Cascades Tissue Group Wisconsin Inc. 1200 Forest - PDF by JoeyVagana


									                                                Fact Sheet
                                  Cascades Tissue Group Wisconsin Inc.
                                 1200 Forest Street, Eau Claire, Wisconsin
                                    WPDES Permit No. WI-0003077-8
                                               June 2, 2009

General Description:

The Cascades Tissue manufacturing plant in Eau Claire has an annual average production of 167 tons per
day (TPD) of tissue base sheet from deinked recycled paper. Pre-consumer and post-consumer wastepaper
bundles are hydrated into a slurry, and then centrifuges, screens and dissolved air flotation units are used to
separate contaminants and recover useable paper fibers. Following paper fiber recovery, a two stage
whitening process can be used (if needed) to oxidize ink particles and brighten the paper fibers. The initial
whitening stage (hydrogen peroxide and/or hypochlorite) is normally followed by a reduction step (sodium
bisulfite and hydrosulfate) to eliminate dyes, neutralize any hypochlorite, and finish the pulp recovery
process. Cascades Tissue produces tissue, napkins and paper towels from the recycled paper fibers on two
paper machines.

The pulp recovery and papermaking wastewaters are treated by gravity settling in a primary clarifier,
aerobic degradation in a 2 million gallon lined, biological treatment lagoon with surface aerators, and final
settling in the secondary clarifiers. Inks and coatings captured in the dissolved air flotation units make up
50% of the organic load to the wastewater treatment plant. The papermaking wastewaters and filtrate from
the sludge belt presses are the other two main loads to the wastewater treatment plant. About 10,000
gallons per day of boiler blowdown and leachate from the closed paper sludge landfill are minor additional
loads to the treatment plant. The final treated wastewater is routed back to the factory basement where it
can be discharged through the Dells Dam (outfall 001) to the Chippewa River or routed back into the
papermaking process for reuse. No water from the river intake is used primarily for non-contact cooling in
the plant; river water used for cooling is rerouted back into the deinking or paper making process. A
diagram of the wastewater treatment process is included as attachment 1. The sanitary wastewater from the
factory bathrooms is not discharged to the river and is sent to the Eau Claire Municipal Wastewater
Treatment Plant.

The Cascades Tissue deinking and paper making activities result in an average treated wastewater
discharge of 1.9 million gallons per day (MGD) to the Chippewa River. This is a 20% reduction in
wastewater discharge to the river over the last 5 years even though the paper production has remained
stable. Multiple projects have been implemented to reduce water use or recycle wastewater at this
Cascades Tissue plant. However, the reduced wastewater volumes have created some challenges in
operating some of the wastewater treatment units due to the flow rates being lower than the treatment plant
design rate. At times, the primary clarifier flow-through volumes have needed to be increased by the
addition of clean water to the primary influent. Cascades Tissue has a consistent and very effective
wastewater treatment process; the Biochemical Oxygen Demand and Total Suspended Solids discharge
levels are normally 10%-20% of the limits for discharge to the Chippewa River.

Rationale of Specific Permit Requirements

Categorical Treatment Based Limits. The process wastewater effluent limits for BOD5, TSS, and pH
are proposed to be unchanged from the current permit. Those limits are based on national (U.S. EPA)
wastewater treatment standards for the category of "deinked wastepaper for tissue products" times the
historical tissue production level of 146 tons per day. See attachment 1 for the calculation basis for the
categorical limits. The facility's paper production is currently at 167 tons per day. Since the facility has
shown substantial compliance with the existing BOD and TSS limits, Wisconsin's anti-degradation
standards require that the categorical limits from the current permit be retained until an increase is
"needed" and justified under the anti-degradation requirements of NR 207. The Cascades Tissue fiber
recovery/deink process has a production rating of 250 tons/day, however it is currently operated at a lower
level (167 ton/day average) to meet the capacity of the paper machines.
Reissuance Fact Sheet                  Cascades Tissue Wisconsin                                Page 2

 Over the last two years, the BOD discharge was usually 5 to 10% of the monthly average limit and normal
daily maximum discharge amounts are 10 to 20% of the limit. However, there was a daily discharge at
75% of the daily maximum limit during a plant upset in the summer of 2006. Total Suspended Solids
(TSS) discharges were usually 5 to 10% of the monthly average limit. During the 2006 plant upset, the
highest daily TSS discharge exceeded the daily maximum limit twice. The discharge returned to
compliance the next day at 5% of the permit limit. The pH discharge range was 6.8 to 8.6 std units, with
the discharge almost always between 7 and 7.9 std units.

NR 105/106 Pollutants. The treated wastewater was tested (to the parts per billion level or less) for the
priority pollutants required by the EPA NPDES permit reissuance application and additional substances
required in the Wisconsin reapplication process. Those test results were evaluated to identify pollutants
needing limits to protect aquatic life, wildlife and human health. The July 1, 2008 water quality effluent
limit evaluation for the Cascades Tissue Wisconsin facility at Eau Claire is attached. This evaluation
identified ammonia nitrogen and total recoverable mercury as the only parameters with concerns regarding
site specific water quality limitations under NR 105 and 106 of the Wisconsin Administrative Code.
Monitoring for Total Residual Chlorine is not proposed for this permit because the reported sample results
indicate that treatment plant effluent total residual chlorine level is below the generally accepted detection
level for the Hach DPD method that was used on-site by plant personnel. Cascades Tissue occasionally
adds hypochlorite to control filamentous bacteria in the return sludge feed to the activated sludge lagoon.

Bioassy Testing. No significant acute toxicity to daphnia or fathead minnows has been reported for
treated wastewater from this facility. Annual acute tests during the permit term are proposed to continue to
monitor for acute toxicity. Cascades Tissue has been granted approval to use an alternate control/dilution
water for the fathead minnow whole effluent test. The Department has received the results of a State Lab
of Hygiene study to investigate the cause of negative survival and growth of the fathead minnow in various
river water samples across the state. The study found that a reduced number of minnows in each sample
was effective in minimizing the pathogen effect that was observed.

Mercury. A water quality based effluent limitation for mercury is recommended for inclusion in the
reissued permit based on NR 106, Wis. Adm. Code. Cascades Tissue data collected during the previous
permit term indicates the treated wastewater discharge levels through outfall 001 (up to 12 ng/L) are
slightly greater than the mercury in the intake water from the Chippewa River (up to 9 ng/L). The July 1,
2008 water quality evaluation calculated a daily maximum water quality-based effluent limitation
(WQBEL) of 9 ng/L for Cascades Tissue in Eau Claire based on the Department’s P99 estimate of the
background concentration of mercury in the Chippewa River water taken to supply the paper mill. The
permittee has requested a variance from this mercury WQBEL. In support of this request, on June 30th,
2008, the permittee submitted an application for an alternative mercury effluent limitation, as allowed
under s. NR 106.145(8), Wis. Adm. Code. The application concludes that mercury source reduction
activities are highly preferable to unproven mercury treatment/removal options and that compliance with
the 9 ng/L WQBEL at this time using wastewater treatment technology would cause substantial and
widespread adverse social and economic impacts. The permittee makes a commitment in the application to
continued implementation of a mercury pollutant minimization program . The Department and the
permittee have agreed to propose an alternative daily maximum mercury limitation of 12 ng/L for the
wastewater discharge from outfall 001, continued monthly wastewater monitoring for mercury, and
specific permit requirements for implementation of a mercury pollutant minimization program. The
Department proposes to grant the alternative mercury effluent limitation, which represents a variance to the
water quality standard used to derive the WQBEL, as provided for under s. NR 106.145(6), Wis. Adm.
Code. The designated use of the receiving water will not change as a result of the variance. For additional
information.on this water quality variance, see the attached alternative mercury effluent limit evaluation
and environmental impact evaluation.

Phosphorus. The proposed permit contains a 1.0 mg/L average effluent limitation for total phosphorus
that was established in the previous permit. The monthly discharge of phosphorus through outfall 001
Reissuance Fact Sheet                     Cascades Tissue Wisconsin                                   Page 3

exceeds the 60 pounds per month threshold specified in ch NR 217, Wis. Adm. Code. Phosphorus is
added to the wastewater to supply this essential nutrient for microorganism growth in the activated sludge
treatment system. Data from the treatment system indicates that the permittee can meet this phosphorus
limit over the next permit term. Chapter NR 217 specifies that compliance with the phosphorus limitation
be determined by comparing the limitation to a rolling 12-month average of the phosphorus discharge

Raw Wastewater Overflows. In the past, this facility has had problems with raw wastewater overflows to
the Chippewa River from the main mill wastewater collection sump ("the water hole") or leaks from the
pipeline from the collection sump to up to the treatment system. A multi-level pumping system has been
installed in the 9000 gallon mill sump to reduce the frequency and duration of the raw wastewater
discharges. The lead/lag primary wastewater pumps can transport up to 8000 gallons per minute to the
head end of the treatment plant. A third booster pump rated at 75 hp. will start if needed to increase the
pumping rate to the treatment plant. If the water level in the wet well rises further, 50 and 75 hp. surge
pumps kick in to pump the excess water to a pair of 34,000 gallon storage tanks. Various backup level
controls were also installed in the mill sump to prevent a control error from causing an overflow. A non-
electrical pneumatic control system can keep the pumping system operational even when an electrical
surge has disabled the primary computer operated control system. In the last 5 years, the facility had 6
instances of overflows from the mill sump area. The overflows were caused by: a faulty lift pump starter, a
lift pump wiring short, an unexpected overflow during startup of a dissolved air flotation treatment unit, a
break in the river water intake pipe, and a storm water surge into the mill basement.

Even with the high volume pumping system in place, large storm water surges can cause overflows of the
mill sump. Storm water can enter the main mill sump when high intensity storms, such as a 1 inch rain in
60 minutes, causes runoff to exceed the 15 cfs flow capacity of the storm sewer serving the 5 acre plant
site. As storm water backs up, the water can eventually enter the mill basement through an elevator shaft.
As the mill basement floods, the water fills the mill sump where attempts are made to pump the water to
the wastewater treatment plant or the surge tanks. If the pumps cannot clear the basement, the water will
overflow the mill sump. Storm water flooded the basement and caused an overflow one time (June 2005)
under the existing permit. Even though additional storm sewer capacity is needed, site limitations have
made it difficult to remedy. Curbs and gutters have been installed along Forest Street to divert off-site
storm water away from the paper mill storm sewers.

When the mill raw wastewater sump overflows, the water can enter the adjoining treated wastewater
discharge channel to the river (outfall 001). Due to this arrangement, any raw wastewater or storm water
overflowing the mill sump is mixed with the treated wastewater in the open effluent channel. The mill
sump overflow/treated effluent mixture can be sampled by the regular outfall 001 flow proportional
sampler. The parshall flume located beneath the sampler measures combined flows in the effluent channel
prior to outfall 001. These samples can be used to show that any discharge through outfall 001 would
comply with permit limits. Since raw wastewater overflows could contain deink pollutants, paper fibers,
and other process contaminants (that are usually removed or degraded in the treatment process), the permit
requires reporting under sample point 101 of the estimated pounds/day amounts of raw wastewater BOD,
TSS and phosphorus discharged to the river. These estimates can be made from grab samples or data from
the treatment system influent sampler.

The permit requires a written report of each overflow event that describes the cause, reports the duration
and volume of overflow, specifies the volume or rate of treated effluent also discharged through outfall 001
during the overflow event, estimates the pounds of BOD, TSS and phosphorus discharged from the
overflowed wastewater, and provides an estimate the pH of the overflowed wastewater. Of the 6 reported
overflows under the last permit, three events had less than 250 lbs of BOD discharged, two events had less
than 950 lbs of BOD discharged, and one event had a discharge of 3,800 lbs of BOD. The permit also
requires an overflow reduction plan be prepared and implemented should there be more than 4 overflows
in any 12 month period. Since there were 5 overflows between September 2004 and June 2005 an
Reissuance Fact Sheet                      Cascades Tissue Wisconsin                                    Page 4

overflow reduction plan was prepared and implemented. Based on the approved overflow reduction plan,
Cascades Tissue installed automatic valves on the effluent recycle and the river intake pipes that will close
when needed to reduce mill sump lift station levels to prevent overflows.

Sludge Landspreading. Sludges from the primary and secondary clarifier are consolidated, dewatered
with belt presses and thinly spread on DNR approved sites or transported to sanitary landfills (for daily
cover). The pulp-cleaning dissolved air flotation sludge is sent to the activated sludge treatment system
since it is difficult to dewater directly. The facility generates approximately 150 tons per day of
wastewater treatment plant sludge. The sludge main components are un-usable paper fibers, wastewater
treatment system organisms, and removed paper coatings such as clay or calcium carbonate.

This facility has been landspreading treatment plant sludge since 1987 for the benefit of the soil. There was a
significant change in the sludge character in 1996 when a new wastepaper deink system was installed at the
mill. The modern deink process is run at a cooler temperature and a more neutral pH than the old deink process
resulting in much less chemical use. The sludge character has also has varied due to recycled paper coating
changes (higher amounts of calcium carbonates and less clay). These, and other factors, resulted in poor crop
yields at some sludge spreading sites in 1996. The company suspended sludge landspreading at that time to
conduct research and crop test plots to determine the cause and find a remedy for the reduced crop yields.
Based on the test plot research results, sludge landspreading began again in 2000 at a typical application rate of
50 wet tons/acre and 75 lbs/acre of supplemental nitrogen fertilizer. During the rest period following sludge
application, the soil organisms have time to biologically decompose organic solids in the sludge, and paper
fibers in the sludge increase the water holding capacity of the soil. The Cascades Tissue sludge contains
relatively low nutrient levels and low metals levels. The sludge has a distinct gray color and a substantial
texture that does not dissolve readily. Field observations have indicated that the sludge is very stable on the
soil; the sludge absorbed water and did not runoff the field during an observed spring snow melt event. The
sludge is beneficial to the soil as a conditioner and liming agent on sandy or lighter soils. The sludge is usually
spread over the sites within 24 hours, except that during wet site conditions, the sludge may be stockpiled prior
to spreading for up to 72 hours. The sludge must be incorporated into the soil within 7 days of spreading,
except when frozen ground delays incorporation until the spring. Winter spreading sites are limited to less than
6% slope.

The sludge spreading program at Cascades Tissue is primarily restricted to meet the 0.5 part per trillion (ppt) or
5 pg/g maximum total dioxin equivalents level in the soil/sludge mixture. This maximum level was established
for agricultural land in the May 4, 1994 memo to DNR from Jay Goldring, of the Wisconsin Bureau of Health
(available by request). When the sludge cannot be incorporated into the soil (for silvicultural and frozen soils),
the sludge spreading system is managed to meet the 0.53 mg total dioxin toxicity equivalents/acre limit to
protect wildlife. That limit is the same as in the previous permit. Cascades Tissue sludge currently exhibits
2,3,7,8 TCDD in a range from 0.5 – 1.3 pg/g and the 2,3,7,8 TCDF in a range from 3.3 – 10.5 pg/g. The
2,3,7,8 TCDF makes up 0.1 of the dioxin toxic equivalency factor. Cascades Tissue has collected soil samples
from landspreading sites that have received one or more paper sludge applications. The soil sample results
show total dioxin equivalent levels for these two main congeners found in paper mill sludge at less than 0.12
ng/kg for the landspreading sites, except for one site at 0.273 ng/kg (WeissFF) and one site at 0.863 (McCann).
 The permit proposes quarterly monitoring of the sludge for the 17 dioxin/furan congeners to obtain additional
data on whether the 15 lower toxicity congeners could affect the total dioxin equivalence concentration in the
spreading site soils. Also, the permit proposes continued soil sampling of sludge application sites.

The permit conditions for sludge landspreading have been consolidated by including references to sections of
Chapter NR 214.18 - Wisconsin's sludge landspreading administrative code. The permit limits the maximum
cumulative metals loading per site to the amounts listed in NR 214.18 (4), Table 4. The monitoring frequency
for some parameters was decreased from quarterly to annually or semi-annually based on sample results
generated under the current permit. Based on results from the previous permit, the priority pollutant scan
requirement for the sludge was decreased from annually to twice during the permit term in the calendar years
2011 and 2013.
Reissuance Fact Sheet                      Cascades Tissue Wisconsin                                  Page 5

   The permit is proposed to expire on June 30, 2014. Questions regarding this permit can be directed to the
   writer by calling (608) 267-7643. Kathy Gillespie and Chuck Stanke of Cascades Tissue and Steve Thon of the
   DNR Eau Claire office assisted with this permit reissuance project.

   Respectfully submitted,

   Jeffrey W. Brauer, Environmental Eng.
   Bureau of Watershed Management

   cc: Lower Chippewa River Basin-Steve Thon
       Cascades Tissue – Kathy Gillespie

                                                  Attachment I
                                          Categorical Effluent Limitations

The production based categorical limits for this facility were established prior to 1988 when the facility was owned
by Pope and Talbot, Inc. The best practicable technology (BPT) limitations for the “Production of paper from
wastepaper by deink subcategory” has the following effluent limitations in accordance with Ch. NR 284.12, Wis.
Adm. Code:

36.2 pounds BOD/ton, daily maximum; 18.8 pounds lbs BOD/ton monthly average;
48.1 pounds TSS/ton, daily maximum; 25.9 pounds lbs TSS/ton monthly average;
pH range 5.0 to 9.0 Std. Units

For a production basis of 146.2 paper tons/day, the resulting limitations are:

5,292 pounds BOD/day, daily maximum; 2,749 pounds lbs BOD/day monthly average;
7,032 pounds TSS/day, daily maximum; 3,787 pounds lbs TSS/day monthly average;

                                                 Attachment II
                                  Wastewater Production and Treatment Diagrams

                                                Attachment III
                                  Water Quality Evaluation Memo – July 1, 2008
Reissuance Fact Sheet                       Cascades Tissue Wisconsin                                     Page 6

                                                 Attachment IV
                                     Alternative Effluent Limitation for Mercury

   Introduction: Pursuant to NR 105 & 106, Wis. Adm. Code, a water quality-based daily maximum
   effluent limit of 9 ng/L (based on the mercury amounts in the Chippewa River intake water) is applicable
   to the treated process wastewater discharge via outfall 001 from the Cascades Tissue Eau Claire paper mill.
   As part of its application for permit reissuance, however, Cascades Tissue requested an alternative effluent
   limit. As discussed below, the Department proposes to grant an alternative effluent limit of 12 ng/L daily
   maximum. Such an alternative effluent limit represents a variance from water quality standards as
   authorized by s. 283.15, Wis. Stats.

   Derivation of an Alternative Effluent Limit for Mercury: Pursuant to s. NR 106.145 (5)(a), an
   alternative effluent limit for the outfall 001mercury level shall equal the upper 99th percentile of
   representative daily discharge concentrations of total recoverable mercury as calculated pursuant to s. NR
   106.05 (4) (a). The Department’s July 1, 2008 water quality-based effluent limitations memo provides
   such a value as the one-day P99 of 12.1 ng/L.

   Granting of an Alternative Effluent Limit for Mercury: Pursuant to s, NR 106.145 (6), the
   Department proposes to grant Cascades Tissue an alternative effluent limit of 12 ng/L (the P99 value
   rounded to two significant figures) expressed as a daily maximum limit. The Department has reviewed the
   mill’s application for an alternative effluent limit, including an update to the mill’s mercury pollutant
   minimization program (PMP), and concludes that information supplied supports the establishment of an
   alternative effluent limit. The Department further concludes that requiring the Cascades Tissue mill to
   meet the water quality standard for mercury would result in substantial and widespread adverse social and
   economic impacts, which is consistent with the findings of s. NR 106.145 (1). The Department considers
   treating a large volume of effluent to meet a daily maximum water quality limit of 9 ng/L to be technically
   and economically infeasible. Cascades Tissue has directed efforts towards mercury minimization and
   reduced use of paper process chemicals that may contain trace amounts of mercury since 2001. There has
   been a 50% reduction in sulfuric acid use by the facility and a comparable reduction in discharge of the
   trace mercury amounts frequently found in industrial grade sulfuric acid. Also, the caustic supply was
   converted to membrane grade (the lowest mercury trace contaminant grade available) and the use of caustic
   in the mill has been reduced by 45%. The proposed permit mercury compliance schedule requires the
   facility to identify other potentially significant sources of mercury to the facility, such as leachate from the
   paper sludge landfill and the raw wastepaper supply, and to continue to evaluate additional feasible
   mercury pollutant minimization opportunities.

   Cascades Tissue and the Department have reached agreement on an alternative effluent limit of 12 ng/L
   expressed as a daily maximum and the continuation of the mill’s mercury pollutant minimization program
   plan (PMP) as proposed in the public noticed permit. The proposed PMP meets the requirements of s. NR
   106.145 (7) and the proposed permit requires the mill to report each year on the progress of the PMP. The
   proposed permit requires monthly mercury monitoring of the mill’s treated process wastewater discharge
   subject to the data quality requirements of ss. NR 106.146 (9) and (10).

   Water Quality Antidegradation: The Department concludes that Wisconsin’s water quality
   antidegradation requirements, ch. NR 207, Wis. Adm. Code, are not applicable to the proposed alternative
   effluent limit for mercury. Antidegradation requirements are not applicable to this initial imposition of an
   effluent limit and the Cascades Tissue mill will not be allowed to increase the loading of mercury to the
   Chippewa River.
Reissuance Fact Sheet                        Cascades Tissue Wisconsin                                      Page 7

Environmental Effects of Granting an Alternative Effluent Limit for Mercury: The Department
concludes that implementing the proposed alternative effluent limit for mercury will not result in increased
risk to human health or the environment. The proposed alternative effluent limit is equivalent to the
Cascades Tissue current discharge of mercury, which is only slightly greater than the mercury amounts
currently found in the Chippewa River at Eau Claire. The discharge of mercury by the mill in its treated
effluent (Sampling Point 001) has a P99 value of 12 ng/L compared to a P99 value of 9 ng/L for the intake
water withdrawn by the mill from the Chippewa River. (Effluent and intake mercury data can be found in
the July 1, 2008 water quality-based effluent limitations recommendation memo, which is an attachment to
this fact sheet.) Most of the mercury discharged from outfall 001 is due to mercury in the river water taken
into the facility and discharged with the process wastewater. Cascades Tissue has committed to mercury
pollutant minimization activities to achieve further reduction in the mercury discharge to the Chippewa
River. These PMP activities will include continued evaluation of ways to minimize the wastewater
contribution from trace mercury levels in the process chemicals, the mercury contribution from landfill
leachate, and investigation into the mercury contribution from the wastepaper recycled by the facility.

Approval of the proposed mercury variance limitation for the Cascades Tissue Eau Claire treated
wastewater discharge should result in no reduction in the existing use of the Chippewa River at Eau Claire
and should not have a significant impact to bald eagles or other listed species that occur within the State of
Wisconsin. The proposed permit places a daily maximum limitation on the existing discharge of mercury
from Cascades Tissue and requires pollution prevention efforts during the permit term. The goal of
mercury pollutant minimization program is to reduce the mercury discharge levels down to river water
intake levels or less if possible. No significant impact to the fisheries, other aquatic life, and wildlife in the
immediate area of the discharge from Outfall 001 is expected for the duration of this water quality variance
(5 years).

The Department concludes that Cascades Tissue has met the requirements of s. NR 106.145, Wisconsin
Administrative Code and s. 283.15, Wisconsin Statutes. The Department further concludes that requiring
the Cascades Tissue mill to meet the 9 ng/L water quality standard for mercury at this time would result in
substantial and widespread adverse social and economic impacts. The Department therefore proposes
to grant the variance for mercury.

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