STATE OF WASHINGTON

DEPARTMENT OF ECOLOGY PO Box 47600 • Olympia, WA 98504-7600 • 360-407-6000

711 for Washington Relay Service • Persons with a speech disability can call 877-833-6341

April 28, 2016

Tami D. Smith Nippon Paper Industries (NIP) USA 1902 Marine Drive PO Box 271 Port Angeles, WA 98362

Re: March 16, 2016 Class II Wastewater Inspection

Dear Ms. Smith:

Enclosed is a report of the Class II wastewater inspection conducted at Nippon Paper Industries USA on March 16, 2016. The results of the inspection indicate that Nippon Paper Industries was in compliance with the NPDES permit on the day of the inspection.

If you have any questions concerning this report, please contact me at (360) 407-6954 or ro bert.carruthers@ecy. wa. gov.

Sincerely,

e/eNC ~ Robert Carruthers, P.E. Industrial Section Waste 2 Resources Program

Enclosure

United States Environmental Protection Agency Form Approved

SEPA Washington , D C 20460 OMB No. 2040-0057

Water Compliance Inspection Report Approval Expires 10-31-95

Section A: National Data System Coding (i.e ., PCS)

Transaction Code NPDES yr/mo/day Inspection Type Inspector Fae Type

11_1 21§1 31Wl~IQIQIQlil~lil§l 11 12111§1Ql~11§1 11 181§1 191§1 201i1 Remarks

21IuNANN0 u N c ED c LASS2_LLLLLLLLLLLLLLLLLLLLLLLLLLLLLLLLLl_LLLLLLLLLLLl66 Inspection Work Days Facility Self-Monitoring Evaluation Rating Bl QA ---- - - --------------Reserved- ------- --- - ---- -----

s1 l_l_l_ls9 101§1 11ltll n lQI 73 1_1_174 1sl_LLLLLl_lao

Section B: Facility Data

Name and Location of Facility Inspected (For industrial users discharging to POTw, Entry Time/Date Permit Effective Date also include POTW name and NPDES permit number) 9:30 a.m., 03/16/16 November 1, 2013

NIPPON PAPER INDUSTRIES USA CO., LTD. Exit Time/Date Permit Expiration Date

P.O. BOX 271, PORT ANGELES, WA 98362 11 :30 p.m. , 03/16/16 October 30, 2018

Name(s) of On-Site Representative(s)fTitle(s)/Phone and Fax Number(s) Other Facility Data

PAUL PERLWITZ 360-565-7045 TAMI SMITH 360-565-7059 Name, Address of Responsible OfficialfTitle/Phone and Fax Number.

STEVEN R JOHNSON, VP Mill and Power Manager, 360 565-7034

Contacted

D Yes [gJ No

Section C: Areas Evaluated During Inspection (Check only those areas evaluated)

0Permit [g]Flow Measurement Doperations & Maintenance Dcsotsso (Sewer Overflow)

0Records/Reports Oself-Monitoring Program Osludge Handling/Disposal 0Pollution Prevention

[g]Facility Site Review Ocompliance Schedules D Pretreatment 0Multimedia

[gJ EffluenUReceiving Waters 0Laboratory [glstorm Water Dother:

Section D: Summary of Findings/Comments (Attach additional sheets of narrative and checklists as necessary)

The Nippon wastewater treatment system consists of primary clarification followed by an aeration basin and then secondary clarification prior to discharge. See the attached wastewater treatment report copy for a snapshot of system conditions on the day of the inspection. In the recent past I have observed occasional accumulation of small shreds of floating plastic and spheres of styrofoam on the surface of the primary clarifier and some carry over into the secondary clarifier. Nothing unusual was observed during this inspection. The secondary clarifier auto sampler appeared to be functioning properly. The tubing into the sampling compositer was clean . Some buildup of plant growth was present on the secondary clarifier weir. The mill has completed a walk around platform at the secondary clarifier which will allow weir cleaning

Name(s) and Signature(s) of lnspector(s) Agency/Office/Phone and Fax Numbers Date

1)9.t?e~ Carruthe.£_,s Ecology, Industrial Section, (360)-407-6954 4/28/2016 "

f~_ y f/l - ~ ~~

1

Sign;~~~~~OA Reviewer I --- 7 l

~genr/Office/Phone and Fax Numbe~s

t:uJ Otµf - 3 (:;i Q - '-f 01 - b q 4-~ Date t-}- j~/I~ EPA Form 3510-3 (Rev. 9-94) Previous editions are obsolete. OQ

Form Approved OMB No. 158-R0073

Sections F thru L: Complete on all inspections, as app~opriate . N/A = Not Applicable I PERMIT NO. WA 000292-5

SECTION F - Facility and Permit Background

ADDRESS OF PERMITTEE IF DIFFERENT FROM FACILITY DATE OF LAST PREVIOUS INVESTIGATION BY EPNSTATE (Including City, County and ZIP code) 06/21/2015 for Class II 1/26/2016 for Class I

FINDINGS In Compliance

SECTION G - Records and Reports

RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT. ~YES ONO ON/A (Further explanation attached J DETAILS:

(a) ADEQUATE RECORDS MAINTAINED OF:

(i) SAMPLING DATE, TIME, EXACT LOCATION ~YES ONO ON/A

(ii) ANALYSES DATES, TIMES ~YES ONO ON/A

(iii) INDIVIDUAL PERFORMING ANALYSIS ~YES ONO ON/A

(iv) ANALYTICAL METHODSfTECHNIQUES USED ~YES ONO ON/A

(v) ANALYTICAL RESULTS (e.g., consistent with self-monitoring report data) ~YES ONO ON/A

(b) MONITORING RECORDS (e.g., flow, pH, 0.0., etc.) MAINTAINED FOR A MINIMUM OF THREE YEARS ~YES ONO ON/A INCLUDING ALL ORIGINAL STRIP CHART RECORDINGS (e.g., continuous monitoring instrumentation, calibration and maintenance records) .

(c) LAB EQUIPMENT CALIBRATION AND MAINTENANCE RECORDS KEPT. ~YES ONO ON/A

(d) FACILITY OPERATING RECORDS KEPT INCLUDING OPERATING LOGS FOR EACH TREATMENT ~YES ONO ON/A UNIT.

(e) QUALITY ASSURANCE RECORDS KEPT. ~YES ONO ON/A

(f) RECORDS MAINTAINED OF MAJOR CONTRIBUTING INDUSTRIES (and their compliance status) DYES ONO ~N/A USING PUBLICLY OWNED TREATMENT WORKS.

SECTION H - Permit Verification

INSPECTION OBSERVATIONS VERIFY THE PERMIT. ~YES ONO D N/A (Further explanation attached J DETAILS:

(a) CORRECT NAME AND MAILING ADDRESS OF PERMITTEE. ~YES ONO ON/A

(b) FACILITY IS AS DESCRIBED IN PERMIT. ~YES ONO ON/A

(c) PRINCIPAL PRODUCT(S) AND PRODUCTION RATES CONFORM WITH THOSE SET FORTH IN ~YES ONO ON/A PERMIT APPLICATION.

(d) TREATMENT PROCESSES ARE AS DESCRIBED IN PERMIT APPLICATION. ~YES ONO ON/A

(e) NOTIFICATION GIVEN TO EPNSTATE OF NEW, DIFFERENT OR INCREASED DISCHARGES. ~YES ONO ON/A

(f) ACCURATE RECORDS OF RAW WATER VOLUME MAINTAINED. ~YES ONO ON/A

(g) NUMBER AND LOCATION OF DISCHARGE POINTS ARE AS DESCRIBED IN PERMIT. ~YES ONO ON/A

(h) CORRECT NAME AND LOCATION OF RECEIVING WATERS. ~YES ONO ON/A

(i) ALL DISCHARGES ARE PERMITTED. ~YES ONO ON/A

SECTION I - Operation and Maintenance

TREATMENT FACILITY PROPERLY OPERATED AND MAINTAINED. ~YES ONO ON/A (Further explanation attached J DETAILS:

(a) STANDBY POWER OR OTHER EQUIVALENT PROVISIONS PROVIDED. ~YES ONO ON/A

(b) ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE. ~YES ONO ON/A

(c) REPORTS ON ALTERNATIVES SOURCE OF POWER SENT TO EPA/STATE AS REQUIRED BY DYES ONO ~N/A PERMIT.

(d) SLUDGES AND SOLIDS ADEQUATELY DISPOSED. ~YES ONO ON/A

(e) ALL TREATMENT UNITS IN SERVICE. ~YES ONO ON/A

(f) CONSUL TING ENGINEER RETAINED OR AVAILABLE FOR CONSULTATION ON OPERATION AND ~YES ONO ON/A MAINTENANCE PROBLEMS.

(g) QUALIFIED OPERATING STAFF PROVIDED. ~YES ONO ON/A

(h) ESTABLISHED PROCEDURES AVAILABLE FOR TRAINING NEW OPERATORS. ~YES ONO ON/A

(i) FILES MAINTAINED ON SPARE PARTS INVENTORY, MAJOR EQUIPMENT SPECIFICATIONS, AND ~YES ONO ON/A PARTS AND EQUIPMENT SUPPLIERS.

U) INSTRUCTIONS FILES KEPT FOR OPERATION AND MAINTENANCE OF EACH ITEM OF MAJOR ~YES ONO ON/A EQUIPMENT.

(k) OPERATION AND MAINTENANCE MANUAL MAINTAINED. ~YES ONO ON/A

(I) SPCC PLAN AVAILABLE. ~YES ONO ON/A

(m) REGULATORY AGENCY NOTIFIED OF BY PASSING. (Dates ) DYES ONO ~N/A

(n) ANY BY-PASSING SINCE LAST INSPECTION. DYES ~NO ON/A

(o) ANY HYDRAULIC AND/OR ORGANIC OVERLOADS EXPERIENCED. DYES ~NO ON/A

EPA FORM 3560-3 (9-77) PAGE 2 OF 4

Form Approved OMB No. 158-R0073

I PERMIT NO. WA 000292-5

SECTION J - Compliance Schedules

PERMITTEE IS MEETING COMPLIANCE SCHEDULE. DYES ONO [8J N/A (Further explanation attached )

CHECK APPROPRIATE PHASE(S}: 0(a) THE PERMITTEE HAS OBTAINED THE NECESSARY APPROVALS FROM THE APPROPRIATE AUTHORITIES TO BEGIN

CONSTRUCTION. O(b) PROPER ARRANGEMENT HAS BEEN MADE FOR FINANCING (mortgage commitments, grants, etc.). D (c) CONTRACTS FOR ENGINEERING SERVICES HAVE BEEN EXECUTED. 0(d) DESIGN PLANS AND SPECIFICATIONS HAVE BEEN COMPLETED. 0(e) CONSTRUCTION HAS COMMENCED. D (f) CONSTRUCTION AND/OR EQUIPMENT ACQUISITION IS ON SCHEDULE. D (g) CONSTRUCTION HAS BEEN COMPLETED. 0(h) START-UP HAS COMMENCED. D (i) THE PERMITTEE HAS REQUESTED AN EXTENSION OF TIME.

SECTION K - Self-Monitoring Program

Part 1 - Flow measurement (Further explanation attached )

PERMITTEE FLOW MEASUREMENT MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT. [8JYES ONO ON/A DETAILS:

(a) PRIMARY MEASURING DEVICE PROPERLY INSTALLED. [8JYES ONO ON/A

TYPE OF DEVICE: 0WEIR 0PARSHALL FLUME 0MAGMETER 0VENTURI METER OOTHER: (Specify)

(b) CALIBRATION FREQUENCY ADEQUATE. (Date of/ast calibration) [8JYES ONO ON/A

(c) PRIMARY FLOW MEASURING DEVICE PROPERLY OPERATED AND MAINTAINED. [8JYES ONO ON/A

(d) SECONDARY INSTRUMENTS (totalizers, recorders, etc.) PROPERLY OPERATED AND MAINTAINED. [8JYES ONO ON/A

(e) FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGES OF FLOW [8JYES ONO ON/A RATES.

Part 2 - Sampling (Further explanation attached )

PERMITTEE SAMPLING MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT. [8JYES ONO ON/A DETAILS:

(a) LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES. [8JYES ONO ON/A

(b) PARAMETERS AND SAMPLING FREQUENCY AGREE WITH PERMIT. [8JYES ONO ON/A

(c) PERMITTEE IS USING METHOD OF SAMPLE COLLECTION REQUIRED BY PERMIT. [8JYES ONO ON/A

IF NO, 0GRAB 0MANUAL COMPOSITE 0AUTOMATIC COMPOSITE FREQUENCY

(d) SAMPLE COLLECTION PROCEDURES ARE ADEQUATE [8JYES ONO ON/A

(i) SAMPLES REFRIGERATED DURING COMPOSITING [8JYES ONO ON/A

(ii) PROPER PRESERVATION TECHNIQUES USED [8JYES ONO ON/A

(iii) FLOW PROPORTIONED SAMPLES OBTAINED WHERE REQUIRED BY PERMIT [8JYES ONO ON/A

(iv) SAMPLE HOLDING TIMES PRIOR TO ANALYSES IN CONFORMANCE WITH 40 CFR 136.3 [8JYES ONO ON/A

(e) MONITORING AND ANALYSES BEING PERFORMED MORE FREQUENTLY THAN REQUIRED BY [8JYES ONO ON/A PERMIT.

(f) IF (e) IF YES, RESULTS ARE REPORTED IN PERMITTEE'S SELF-MONITORING REPORT. DYES ONO [8JN/A

Part 3 - Laboratory (Further explanation attached )

PERMITTEE LABORATORY PROCEDURES MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT. [8JYES ONO ON/A DETAILS:

(a) EPA APPROVED ANALYTICAL TESTING PROCEDURES USED. (40 CFR 136.6) [8JYES ONO ON/A

(b) IF ALTERNATE ANALYTICAL PROCEDURES ARE USED, PROPER APPROVAL HAS BEEN DYES ONO [8JN/A

OBTAINED.

(c) PARAMETERS OTHER THAN THOSE REQUIRED BY THE PERMIT ARE ANALYZED. [8JYES . ONO ON/A

(d) SATISFACTORY CALIBRATION AND MAINTENANCE OF INSTRUMENTS AND EQUIPMENT. [8JYES ONO ON/A

(e) QUALITY CONTROL PROCEDURES USED. [8JYES ONO ON/A

(f) DUPLICATE SAMPLES ARE ANALYZED. 100 % OF TIME [8JYES ONO ON/A

(g) SPIKED SAMPLES ARE USED. %0FTIME DYES [8JNO ON/A

(h) COMMERCIAL LABORATORY USED. [8JYES ONO ON/A

(i) COMMERCIAL LABORATORY STATE CERTIFIED. [8JYES ONO ON/A

LAB NAME Columbia Anal~tical, Kelso, WA CH2MHill, Corvallis, OR

LAB ADDRESS

EPA FORM 3560-3 (9-77) PAGE 3 OF 4

PERMIT NO. WA 000292-5

SECTION L - Effluent/Receiving Water Observations (Further explanation attached J

OUTFALL NO. OIL SHEEN GREASE TURBIDITY VISIBLE FOAM VISIBLE COLOR FLOAT SOL

001 None None None None

002 None None None None

(Sections Mand N: Complete as appropriate for sampling inspections) SECTION M - Sampling Inspection Procedures and Observations (Further explanation attached

~ GRAB SAMPLES OBTAINED ~ COMPOSITE OBTAINED ~ FLOW PROPORTIONED SAMPLE ~ AUTOMATIC SAMPLER USED ~ SAMPLE SPLIT WITH PERMITTEE ~ CHAIN OF CUSTODY EMPLOYED ~ SAMPLE OBTAINED FROM FACILITY SAMPLING DEVICE

COMPOSITING FREQUENCY Flow (pulse)-Based at 9 MGD PRESERVATION Temperature at 4° c Flow rate, auto-sampler for 20 minute intervals SAMPLE REFRIGERATED DURING COMPOSITING: ~YES ONO

SAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE Yes

SECTION N - Analytical Results (Attach report if necessary)

See attached report

Grab pH 7.1 5.1 <pH<9.0

Composite TSS 562 lbs/day (9 mg/I) note 1. 1,487 · Grab TSS 493 lbs/day (8 mg/I) note 2. 1,487

Composite BOD 499 lbs/day (8 mg/I) note 1. 673

Grab BOD 432 lbs/day (7 mg/I) note 2. 673

Composite Turbidity 15 NTU

NA

Form Approved OMB No. 158-R0073

OTHER

Note 1. From composite sample of secondary effluent before noncontact cooling water. Mass based on average secondary effluent flow of 7.48 mgd on March 15, 2016. Note 2. Based on grab sample of secondary effluent before noncontact cooling water. Mass based on average secondary effluent flow of 7.39 mgd March 16, 2016.

Metals as TR from composite sample.

Silver U ug/I, Arsenic 0.72 ug/I, Beryllium U ug/I, Cadmium .79 ug/I, Chromium 3.55 ug/I, Copper 1.75 ug/I, Mercury U ug/I, Nickel 4.22 ug/I, Lead .15 ug/I, Selenium U ug/I, Thallium U ug/I, Zinc 41.3 ug/I, Antimony U ug/I.

EPA FORM 3560-3 (9-77) PAGE 4 OF 4

3/16/2016 9:46:58 AM

TO SCREW PRESSES •

PRIMARY CLARIFIER TORQUE 22%

1.2 TPH 0.1 PPM DISSOLVED 02

OIL 2.7%

AUTO 2.6 CONS

187 GPM - -!4-- 11

PRI SLUDGE

MAIN PUMP STATION

6.8 pH

2 Pumps Running

OXYGEN PUMP

79F

AIR SUPPLY 90 PSI AIRCOMPRESSOR#1 RUNNING

6.2 pH

SPLITTER BOX

21.2%

AUTO

SECONDARY CLARIFIER 3.6 BED DEPTH

I . _Ju

RECYCLE SLUDGE

AUTO 25GPM

WASTE SLUDGE

15 TURB.

F

8.2 MGD

7.1 pH

EFFLUENT • !>

CLARIFIER UPS

TANK FARM SUMP

7 % BASEMENT SUMP

200 GPO AUTO

30 GPO

42% 12%

AQUEOUS AMMONIA PHOSPHORIC ACID

I