To: Raj Kapur,
Oregon Department of Environmental Quality
From: Robert
Anderson, National Marine Fisheries Service (NOAA Fisheries)
Date : May 6, 2003
Subject: Proposed
NPDES permit renewal for Fort James Operating Company’s Wauna Mill
Raj: Here are my comments regarding the proposed
NPDES permit.
(1) Port
velocities. The information provided in
the NPDES fact sheet does not provide specific port velocities for outfalls 001
and 003, rather the NPDES fact sheet refers to model outputs (dilution values).
Please provide calculations on
real-time port velocities (minimum, average, and maximum velocities). The National Marine Fisheries Service (NOAA
Fisheries) recommends that maximum port velocities not exceed 4-8 feet per
second. Port velocities that exceed
this velocity range would likely create attraction flows for juvenile Pacific
salmon and steelhead and induce movement into the mixing zone (MZ) and the zone
of initial dilution (ZID) potentially causing lethal or sublethal effects
(e.g., thermal shock).
(2) Effluent
daily maximum temperatures. NOAA
Fisheries is concerned that juvenile Pacific salmon and steelhead may be swept
into the ZID by the current, especially if port velocities exceed the 4-8 feet
per second range inducing attraction.
Juvenile fish entering the ZID in the MZ, particularly within 1 meter of
the point of discharge, may be subject to sublethal and potentially lethal
thermal shock effects. NOAA Fisheries
recommends Fort James consider applying for a section 10 incidental take permit
for its discharges to the Columbia River because of the potential for lethal
thermal shock effects to Endangered Species Act-listed Pacific salmon and
steelhead.
(3) Please
provide clarification on the discharge of 2,3,7,8-TCDD at 0.44 mg/day
(quarterly max) and 0.31 mg/day (annual average). In the final TMDL for Dioxin discharges to the Columbia River,
the WLA for Fort James is 0.21 mg/day.
It appears that the NPDES permit is allocating a WLA inconsistent with
the TMDL. Please clarify.
(4) Please
provide clarification on whether the WLA for 2,3,7,8-TCDD applies to the ZID or
the MZ.
(5) NOAA
Fisheries recommends that ODEQ change the permit limits for pH to reflect the
water quality-based pH range (6.5-8.5).
(6) The
MAO, section 4, permits the permittee to violate permit effluent limitations
for TSS, aluminum, chlorine, and zinc.
How does exceeding NPDES permit limitations for pollutants comply with
the Clean Water Act? NOAA Fisheries
recommends that the permit be written and issued to ensure that effluent
limitations are in full compliance at all times.
(7) The
public notice indicates that the Fort James facility has consistently complied
with the NPDES permit limitations. In
addition to the MAO clause permitting violation of effluent limitations, the
supplemental information provided by Oregon Department of Environmental Quality
(ODEQ) to NOAA Fisheries included a notice of noncompliance dated April 2,
1998. There appears to be discrepancies
in the information provided. Please
clarify.
(8) Please
provide clarification regarding supplemental information provided by ODEQ to
NOAA Fisheries on modeled discharges causing near-field instability and
unstable re-circulation. Please provide
clarification on how near-field instability and unstable re-circulation would
affect the ZID and MZ hydraulics. How
would the permittee comply with acute (CMC) and chronic criteria (CCC) for
water quality standards if these effects are present?
(9) NOAA
Fisheries recommends ODEQ condition the NPDES permit to comport with the
Environmental Protection Agency’s Region 10 Guidance for Pacific Northwest
state and tribal temperature water quality standards which include measures for
minimizing effects to ESA-listed Pacific salmon and steelhead for limitations
for NPDES permits. The guidance can be
accessed at:
<http://yosemite.epa.gov/r10/water.nsf/1887fc8b0c8f2aee8825648f00528583/ce95a3704aeb5715882568c400784499?OpenDocument>
Raj: If you have any questions, please feel free
to call or e-mail me.
Robert
503-231-2226