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 concentration. 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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