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NPDES Permit No. NH0000230Page 1 of 12
AUTHORIZATION TO DISCHARGE UNDER THENATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of the Federal Clean Water Act,as amended, (33 U. C. 1251 et seq ; the " CWA"
Monadnock Paper Mi ls, Inc.
is authorized to discharge from a facility located at
117 Antrim RoadBennington, New Hampshire 03442
to receiving water named
Contoocook River (Hydrologic Code; 01070003)
in accordance with effluent limitations, monitoring requirementsand other conditions set forth herein.
This permit shall become effective on the first day of the calendarmonth immediately following sixty days after signature.
This permit and the authorization to discharge expire at midnight,five (5) years from the last day of the month preceding theeffective date.
This permit supersedes the permit issued on October 23, 2000.
This permit consists of Part I, (12-pages), including effluentlimitations and monitoring requirements; Attachment A (9-pages),WET testing requirements; and Part II (25-pages), including General
Conditions and Definitions.
Signed this 10 day of July, 2007
/S/ SIGNATURE ON FILE
Stephen S. Perkins, DirectorOffice of Ecosystem ProtectionU. S. Environmental Protection AgencyNew England RegionBoston, Massachusetts
PAR
T
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Perm
it N
o. N
H00
0023
0Page 2 of
During the period beginning on the effective date and lasting through expiration
date, the Permittee is authorized to discharge treated wastewater (p
roce
ss w
ater
from paper manufacturing process) from Outfall Serial N
umer
001 into the
Contoocook River. Such discharges shall be limited and monitored by the Permittee
as specified below. Samples taken in compliance with the monitoring requirements
specified below shall be taken at Outfall 001 after the treatment system but
prior to discharge into the Contoocook River at a point that provides a
repr
esen
tativ
e an
alys
is o
f th
e ef
flue
nt.
Eff
luen
tD
isch
arge
Lim
itatio
nsM
oni toring Requirements
Cha
ract
eris
tic
Average Monthly
Maximum Daily
Measuremen t
Sam
ple
Freq
uenc
yT
ype
Flow
,M
GD
1. 0
1. 3
Con
tinuo
usR
ecor
der
BO
Ds,
lbs
/ day
400
lbs/
day
500 lbs/day
l/Wee
kG
rab
December 1 - March 31
BO
Ds,
lbs/
day
300
lbs/
day
400
lbs/
day
l/Wee
kG
rab
April 1 - November 30
TSS
lb/d
ay300 lbs/day
400 lbs/day
l/Wee
kG
rab
TSS
lb/d
ay31
5 lb
s/da
y420 lbs/day
l/Wee
kG
rab
Total Recoverable
2 /M
on
Gra
bA
lum
inum
,m
g/l
Ran
ge:
5 - 8.
(See PART I. D. 1 . a
. )
l/Day
Gra
b
(Note: See page 5 - 7 for explanation of superscripts.
Perm
it N
o. N
H00
0023
0Page 3 of
PAR
T
(Con
tinue
d)E
fflu
ent
Dis
char
ge L
imita
tions
Mon
i tor
ing
Req
uire
men
tC
hara
cter
istic
Whole Effluent
Toxici ty
Mea
sure
men
tSa
mpl
eFr
eque
ncy
Typ
e
LC
5 0
; in
perc
ent
;:100
%2/
Yea
r24
-Hou
rComposi te
NO
EC
;in percent
2/Y
ear
24-H
our
Rep
ort
Composi te
Am
onia
Ni t
roge
nas
Ni t
roge
nm
g/l
2/Y
ear
24-H
our
Rep
ort
Composi te
24-H
our
Har
dnes
sm
g/l
Rep
ort
2/Y
ear
Com
posi
te
. '-
Alu
min
um24
-Hou
rT
otal
Rec
over
able
mg/
lR
epor
t2/
Yea
rComposi te
Tot
alR
ecov
erab
leC
adm
ium
mg/
l2/
Yea
r24
-Hou
rR
epor
tC
ompo
site
Tot
alR
ecov
erab
leC
hrom
ium
mg/
l2/
Yea
r24
-Hou
rR
epor
tComposi te
Tot
alR
ecov
erab
leC
oppe
rm
g/l
2/Y
ear
24-H
our
Rep
ort
Composi te
Tot
alR
ecov
erab
leN
icke
llom
g/l
2/Y
ear
24-H
our
Rep
ort
Com
posi
te
Tot
alR
ecov
erab
leL
ead
mg/
l2/
Yea
r24
-Hou
rR
epor
tC
ompo
site
Tot
alR
ecov
erab
leZ
inc
mg/
l2/
Yea
r24
-Hou
rR
epor
tC
ompo
site
Tot
alPh
osph
orou
sm
g/l
2/Y
ear
24-H
our
Rep
ort
Com
posi
te
(Note: See page 5 - 7 for explanation of superscripts.
Perm
it N
o. N
H00
0023
0Page 4 of
EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date and lasting through expiration
date, the Permittee is authorized to discharge treated wastewater (solutions used
for well redevelopment) from Outfall Serial Number 002 into the Contoocook River.
Such discharges shall be limited and monitored by the Permittee as specified be
low
.Samples taken in compliance with the monitoring requirements specified below shall
be taken from the sedimentation/neutralization tank prior to discharging the
treated contents of that ta
nk.
Eff
luen
tD
isch
arge
Liff
i tat
ions
Mon
i tor
ing
Req
uire
men
tsC
hara
cter
istic
Max
imum
Mea
sure
men
tSa
mpl
eFr
eque
ncy
Typ
e
FloW
l1 ,
GPD
225,
600
Req
uire
dE
stim
ate
TSS
,m
g/l
Per Discharge
Gra
b
Ran
ge:
Per
Di s
char
geG
rab
Tot
alPh
osph
orou
s,m
g/l
Rep
ort
Per Discharge
Gra
b
Tot
alR
esid
ue01
1Per Discharge
12,
Gra
bC
hlor
ine
mg/
l
Turbidi ty,
NT
UR
epor
tPer Discharge
Gra
b
(Note: See page 5 - 7 for explanation of superscripts.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION I
ONE CONGRESS STREET BOSTON, MASSACHUSETTS 02114-2023
FACT SHEET
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT TO DISCHARGE TO WATERS OF THE UNITED STATES
NPDES PERMIT NO.: NH0000230
NAME AND ADDRESS OF APPLICANT: Monadnock Paper Mills, Inc. 117 Antrim Road Bennington, New Hampshire 03442
NAME AND ADDRESS OF FACILITY WHERE DISCHARGE OCCURS: Monadnock Paper Mills, Inc. 117 Antrim Road Bennington, New Hampshire 03442
RECEIVING WATER: Contoocook River
CLASSIFICATION: B
SIC CODE: 2621
Table of Contents
I. Proposed Action, Type of Facility and Discharge Location.. 2 II. Description of Discharge.................................. 4 III. Limitations and Conditions................................ 5 IV. Permit Basis and Explanation of Effluent Limitations
Derivation................................................ 5 A. General Statutory and Regulatory Background........... 5 B. Development of Water Quality-based Limits............. 7 C. Development of Water Quality Based Effluent Limitations
Specific to the Contoocook River...................... 9 D. Conventional Pollutants.............................. 10 E. Non-Conventional and Toxic Pollutants................ 12 F. Other Limits and Requirements........................ 16
Flow.......................................................... 16 G. Essential Fish Habitat and Endangered Species........ 20
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H. Outfall 002.......................................... 21 I. Additional Requirements and Conditions............... 23
V. Antidegradation.......................................... 25 VI. State Certification Requirements......................... 25 VII. Comment Period, Hearing Requests, and Procedures for Final
Decisions................................................ 26
ATTACHMENT A.................................................. 28
ATTACHMENT B.................................................. 30
ATTACHMENT C.................................................. 31
ATTACHMENT D.................................................. 33
ATTACHMENT E ................................................. 34
I. Proposed Action, Type of Facility and Discharge Location.
The above named applicant has applied to the U.S. Environmental Protection Agency (EPA) for reissuance of its NPDES permit to discharge treated effluent into the designated receiving water (Contoocook River). The applicant owns and operates the above named non-integrated paper mill; i.e., does not have an on-site wood pulp mill. The mill produces a variety of base and coated papers from purchased pulp. Products produced include wallpaper, abrasive paper backing, medical packaging, graphic arts paper and schoolbook covers
The location of the facility, Outfall 001 and the receiving water are shown in Attachment A. A schematic of the facility's water and wastewater flow is shown in Attachment B.
Paper is produced on two paper machines and, when necessary, the paper is coated on one paper coater machine. Water removed from the paper slurry that enters the paper making machines is recirculated for reuse. Any excess recirculated water is sent to the wastewater treatment plant. Liquid additives applied during the paper making process are either barreled for reuse, or, if contaminated, are directed to the wastewater treatment plant. Attachment B, extracted from a Monadnock Paper Mills May 4, 1998 drawing, depicts facility’s process and wastewater flows for a typical operating day. The wastewater flow averaging 0.684 millions gallons per day (MGD) is shown on Attachment B. Monadnock Paper Mills NPDES application and the most recent five years of flow data, however, presents average flows of 0.473 MGD and 0.489 MGD, respectively.
The wastewater treatment plant receives the following wastewater
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streams: excess process water from the paper making process, contaminated saturant from the paper making process and contaminated coatings from the paper coater process, cooling water/mechanical seal water, sand filter backwash water, boiler blowdown, and tank and machine wash water. Storm water from some roof drains is directed to the wetwell. These wastewater streams flow past two bar racks into a wet well. Sodium hydroxide may be added at the wet well to adjust the pH to neutral in the clarifier. The wastewater is then pumped from the wet well to a clarifier. During transfer of the wastewater from the wet well to the clarifier two polymers (a cationic coagulant and an anionic coagulant) are added to enhance the settling of suspended short paper fibers. The settled short paper fibers are then pumped to a dewatering press. The water from the press is returned to the wastewater treatment system via the wetwell, and the solids are recycled offsite. After treatment in the clarifier, the cleared wastewater sequentially flows through four lagoons, the first three being aerated, for secondary treatment. Phosphoric acid is used as a nutrient for bacteria in the treatment system only during the colder months (mid-September to March). After the leaving the lagoons the treated wastewater discharges to the Contoocook River through Outfall 001.
During this permit cycle NHDES began a Total Maximum Daily Load (TMDL) study of the Contoocook River. The section of the Contoocook River which Monadnock Paper Mills discharges into is encompassed by that study. In preparation of the TMDL study, low flow data for the Contoocook River was reassessed resulting in a revised 7Q10. (The 7Q10 represents the lowest average flow which occurs for seven consecutive days on an annual basis with a recurrence interval of once in ten years on average.) The 7Q10 is applied in calculating certain pollutant effluent limits. The 7Q10 low flow for the receiving water at this facility was recalculated to be 16.5 cubic feet per second (cfs). The previous 7Q10 was 19.2 cfs.
The mill=s process water is predominately obtained from Monadnock Paper Mills= ground water well. A small amount of water also is drawn from the Town of Bennington. Process water can also be taken from the Contoocook River. The intake on the Contoocook River is activated: 1) in July for a few days during the mill=s shutdown when the intake flow rate is reduced from an average flow of approximately 0.48 MGD to about 0.18 MGD; and, 2) in an emergency situation which precludes use of the well water. Emergency use of Contoocook River water is limited to less than a day. The River water=s quality is unsuitable in the production of the medical grade paper.
Each year Monadnock Paper Mills rehabilitates two groundwater wells. These wells supply the water used in the Mills’ paper making processes. The rehabilitation, also referred to as
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redevelopment, involves chemically treating the well with solutions containing acids and phosphorous, and biocides. In previous years, Monadnock Paper Mills was issued an EPA-New England NPDES permit waiver for the rehabilitation discharge. A NHDES Temporary Surface Water Discharge Permit regulated the redevelopments solutions’ discharge. In 2005, the EPA and NHDES issued a Remediation General Permit (RGP). The RGP was designed to regulate the most common surface water discharges found at contaminated groundwater remediation sites, contaminated construction dewatering and discharges that contain petroleum products, solvents and metals. The RGP was intended to be used at remediation sites.
The RGP eliminated the need for sites that were temporarily discharging water to apply for an EPA-New England NPDES permit exclusion and a NHDES Temporary Surface Water Discharge Permit. Since Monadnock’s well redevelopment is not at a contaminated or formerly contaminated site, however, Monadnock cannot apply for the RGP. Monadnock’s well development discharges now require an individual NPDES permit. A new outfall, Outfall 002, was established for Monadnock Paper Mills’ well rehabilitation treated wastewater discharge.
Monadnock Paper Mills, Inc. existing permit was issued on October 23, 2000, and expired on December 22, 2005. The expired permit (hereafter referred to as the "existing permit") has been administratively extended as the applicant filed a complete application for permit reissuance within the prescribed time period as per 40 Code of Federal Regulations (C.F.R.) ' 122.6. The existing permit authorizes discharge from Outfall 001.
II. Description of Discharge.
A quantitative description of those effluent parameters limited and monitored in the existing permit for the 62-month period January 2001 through February 2006 is presented in Attachment C. The data was compiled from monthly Discharge Monitoring Reports (DMR) submitted by the facility to the New Hampshire Department of Environmental Services, Water Division (NHDES-WD) and the EPA. The paper mill's wastewater treatment system average flow over this time period is 0.489 MGD, with a maximum daily flow of 0.84 MGD. The wastewater from the paper making process is discharged through Outfall 001 to the Contoocook River. The permittee submitted quantitative data with their reapplication submissions (FORMs 1 and 2C) along with the DMR data; all which are on file at the EPA Boston office. This effluent data is statistically compared to the permit’s effluent limits to ensure the permittee is effectively meeting the permit=s limits. The draft permit contains Outfall 001 limits for pH, Five Day Biochemical Oxygen Demand (BOD5), Total Suspended Solids (TSS), Total Recoverable Aluminum (TRA) and a requirement for a Whole Effluent Toxicity
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(WET) Test and monitoring for Total Phosphorous (TP).
Each year Monadnock Paper Mills rehabilitates two groundwater wells. These wells supply the water used in the Mills’ paper making processes. The rehabilitation includes three chemical treatments. The wastewater from this process is treated in a sedimentation/neutralization tank. The draft permit contains a new outfall, Outfall 002, with limits for pH and TSS; plus monitoring for TP, Total Recoverable Chlorine (TRC) and Turbidity.
III. Limitations and Conditions
Effluent limitations and monitoring requirements are found in PART I of the Draft Permit. The basis for each limit and condition is discussed in sections IV.D through IV.H of this Fact Sheet.
IV. Permit Basis and Explanation of Effluent Limitations Derivation
A. General Statutory and Regulatory Background
Congress enacted the Clean Water Act (ACWA@ or AAct@), "to restore and maintain the chemical, physical, and biological integrity of the Nation's waters." CWA ' 101(a). To achieve this objective, the CWA makes it unlawful for any person to discharge any pollutant into the waters of the United States from any point source, except as authorized by specified permitting sections of the Act, one of which is Section 402. See CWA '' 301(a), 402(a). Section 402 establishes one of the CWA's principal permitting programs, the National Pollutant Discharge Elimination System or NPDES. Under this section of the Act, EPA may "issue a permit for the discharge of any pollutant, or combination of pollutants" in accordance with certain conditions. See CWA ' 402(a). NPDES permits generally contain discharge limitations and establish related monitoring and reporting requirements. See CWA ' 402(a)(1),(2).
Section 301 of the CWA provides for two types of effluent limitations to be included in NPDES permits: "technology-based" limitations and "water quality-based" limitations. See CWA '' 301, 303, 304(b); 40 C.F.R. Parts 122, 125 and 131. Technology-based limitations, generally developed on an industry-by-industry basis, reflect a specified level of pollutant-reducing technology available and economically achievable for the type of facility being permitted. See CWA ' 301(b). EPA established minimum technology requirements for the pulp and paper industry in the form of effluent guidelines promulgated under 40 C.F.R. ' 430. These guidelines specify the maximum mass (lbs per day) of Biochemical Oxygen Demand (BOD) and
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Total Suspended Solids (TSS) which can be discharged per mass (tons per day) of product produced. The maximum amount of BOD and TSS allowed varies for the different types of pulp and paper products as well as manufacturing methods.
Water quality-based effluent limits, on the other hand, are designed to ensure that state water quality standards are met regardless of the decision made with respect to technology and economics in establishing technology-based limitations. In particular, Section 301(b)(1)(C) requires achievement of, "any more stringent limitation, including those necessary to meet water quality standards...established pursuant to any State law or regulation..." See 40 C.F.R. '' 122.4(d), 122.44(d)(1) (providing that a permit must contain effluent limits as necessary to protect state water quality standards, Aincluding State narrative criteria for water quality@) (emphasis added) and 122.44(d)(5) (providing in part that a permit incorporate any more stringent limits required by Section 301(b)(1)(C) of the CWA).
The CWA requires that states develop water quality standards for all water bodies within the state. CWA ' 303. These standards have three parts: (1) one or more "designated uses" for each water body or water body segment in the state; (2) water quality "criteria," consisting of numerical concentration levels and/or narrative statements specifying the amounts of various pollutants that may be present in each water body without impairing the designated uses of that water body; and (3) an antidegradation provision, focused on protecting high quality waters and protecting and maintaining water quality necessary to protect existing uses. CWA ' 303(c)(2)(A); 40 C.F.R. ' 131.12. The limits and conditions of the permit reflect the goal of the CWA and EPA to achieve and then to maintain water quality standards.
The applicable New Hampshire water quality standards can be found in Surface Water Quality Regulations, Chapter Env-Ws 1700 et seq. See generally, Title L, Water Management and Protection, Chapter 485-A, Water Pollution and Waste Disposal Section. Hereinafter, New Hampshire's Surface Water Quality Regulations are referred to as the NH Standards.
Receiving stream requirements are established according to numerical and narrative standards adopted under state law for each stream classification. When using chemical-specific numeric criteria from the state's water quality standards to develop permit limits, both the acute and chronic aquatic life criteria are used and expressed in terms of maximum allowable in stream pollutant concentrations. Acute aquatic life criteria are generally implemented through maximum daily limits and chronic aquatic life criteria are generally implemented through average monthly limits. Where a State has not established a numeric
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water quality criterion for a specific chemical pollutant that is present in the effluent in a concentration that causes or has a reasonable potential to cause a violation of narrative water quality standards, the permitting authority must establish effluent limits in one of three ways: based on a Acalculated numeric criterion for the pollutant which the permitting authority demonstrates will attain and maintain applicable narrative water quality criteria and fully protect the designated use@; on a Acase-by-case basis@ using CWA Section 304(a) recommended water quality criteria, supplemented as necessary by other relevant information; or, in certain circumstances, based on an Aindicator parameter.@ 40 C.F.R. ' 122.44(d)(1)(vi)(A-C).
All statutory deadlines for meeting various treatment technology-based effluent limitations established pursuant to the CWA have expired. When technology-based effluent limits are included in a permit, compliance with those limitations is from the date the issued permit becomes effective. See 40 C.F.R. ' 125.3(a)(1). Compliance schedules and deadlines not in accordance with the statutory provisions of the CWA cannot be authorized by an NPDES permit. The regulations governing EPA's NPDES permit program are generally found in 40 C.F.R. Parts 122, 124, 125 and 136.
B. Development of Water Quality-based Limits
The permit must limit any pollutant or pollutant parameter (conventional, non-conventional, toxic and whole effluent toxicity) that is or may be discharged at a level that causes or has "reasonable potential" to cause or contribute to an excursion above any water quality standard, including narrative water quality criteria. 40 C.F.R. ' 122.44(d)(1). An excursion occurs if the projected or actual in-stream concentration exceeds the applicable criterion.
Reasonable Potential
In determining reasonable potential, EPA considers: (1) existing controls on point and nonpoint sources of pollution; (2) pollutant concentration and variability in the effluent and receiving water as determined from permit application, monthly DMRs and State and Federal water quality reports; (3) sensitivity of the species to toxicity testing; (4) statistical approach outlined in Technical Support Document for Water Quality-based Toxics Controls, March 1991, EPA/505/2-90-001 in Section 3; and, where appropriate, (5) dilution of the effluent in the receiving water. In accordance with New Hampshire regulations (RSA 485-A:8,VI, Env-Ws 1705.02), available dilution for rivers and streams is based on a known or estimated value of the lowest average flow which occurs for seven (7) consecutive days with a recurrence interval of once in ten (10) years (7Q10) for aquatic life and human health criteria for non-carcinogens, or the long-
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term harmonic mean flow for human health (carcinogens only) in the receiving water at the point just upstream of the outfall. Furthermore, 10 percent (%) of the receiving water's assimilative capacity is held in reserve for future needs in accordance with New Hampshire's Surface Water Quality Regulations Env-Ws 1705.01.
Anti-Backsliding
Section 402(o) of the CWA generally provides that the effluent limitations of a renewed, reissued, or modified permit must be at least as stringent as the comparable effluent limitations in the previous permit. EPA has also promulgated anti-backsliding regulations, which are found at 40 C.F.R. ' 122.44(l). Unless applicable anti-backsliding requirements are met, the limits and conditions in the reissued permit must be at least as stringent as those in the previous permit.
State Certification
Section 401(a)(1) of the CWA requires all NPDES permit applicants to obtain a certification from the appropriate state agency stating that the permit will comply with all applicable federal effluent limitations and state water quality standards. See CWA ' 401(a)(1). The regulatory provisions pertaining to state certification provide that EPA may not issue a permit until a certification is granted or waived by the state in which the discharge originates. 40 C.F.R. ' 124.53(a). The regulations further provide that, "when certification is required....no final permit shall be issued...unless the final permit incorporates the requirements specified in the certification under ' 124.53(e)." 40 C.F.R. ' 124.55(a)(2). Section 124.53(e) in turn provides that the State certification shall include "any conditions more stringent than those in the draft permit which the State finds necessary@ to assure compliance with, among other things, state water quality standards, See 40 C.F.R. ' 124.53(e)(2), and shall also include, "[a] statement of the extent to which each condition of the draft permit can be made less stringent without violating the requirements of State law, including water quality standards," 40 C.F.R.' 124.53(e)(3).
However, when EPA reasonably believes that a state water quality standard requires a more stringent permit limitation than that reflected in a state certification, it has an independent duty under CWA ' 301(b)(1)(C) to include more stringent permit limitations. See 40 C.F.R. '' 122.44(d)(1) and (5). It should be noted that under CWA ' 401, EPA=s duty to defer to considerations of state law is intended to prevent EPA from relaxing any requirements, limitations or conditions imposed by state law. Therefore, A[a] State may not condition or deny a certification on the grounds that State law allows a less stringent permit condition.@ 40 C.F.R. ' 124.55(c). In such an instance, the
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regulation provides that, AThe Regional Administrator shall disregard any such certification conditions or denials as waivers of certification.@ Id. EPA regulations pertaining to permit limits based upon water quality standards and state requirements are contained in 40 C.F.R. ' 122.4(d) and 40 C.F.R. ' 122.44(d).
C. Development of Water Quality Based Effluent Limitations Specific to the Contoocook River
Section 303(d) of the CWA requires states to identify waters within their boundaries for which technology-based effluent limitations are insufficiently stringent to implement applicable water quality standards. States are required to prepare Total Maximum Daily Load (TMDL) analyses for receiving waters listed on the 303(d) list. A TMDL is a scientific analysis which identifies the amount of a pollutant from point, nonpoint and background sources that may be discharged to water quality-limited receiving water. Any pollutant loading above the TMDL will result in violation of the applicable water quality standards.
The State of New Hampshire=s 2004 303(d) list of impaired waters identifies surface waters which do not currently meet state water quality standards (NHDES 2004). Segments of the Contoocook River have been identified as violating water quality standards for percent Dissolved Oxygen (DO) saturation, aluminum, pH, and Escherichia coli. The impaired segment of the Contoocook River into which the Monadnock Paper Mills= discharge is labeled NHRIV700030108-15 on the State=s 2005 303d list. That segment is impaired because of low DO levels. The NHDES-WD has initiated, but not yet completed a TMDL for the reaches of the Contoocook River in the vicinity of Monadnock=s effluent discharge.
In the absence of a TMDL, EPA is required to use available information to establish water quality-based limits when issuing NPDES permits for discharges to impaired waters. See generally, 40 C.F.R. ' 122.44 (d). EPA has reviewed data collected, applicable narrative state water quality standards, federal water quality criteria guidance and other relevant information. At this time, EPA believes that the draft permit limits for BOD5 are sufficiently stringent to satisfy water-quality standards. This is discussed in greater detail below.
While the permit will be issued for the normal five year term, it can be reopened and modified during its term under certain circumstances. A permit may be modified or revoked and reissued in accordance with 40 C.F.R. ' 122.62(a) (Causes for modification) or (b) (Causes for modification or revocation and reissuance). One basis for reopening and modifying the permit during its term is the receipt of information that was not available at the time of permit issuance and that would have justified application of different permit conditions (ANew
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Information@). See 40 C.F.R. '122.62(a)(2). New Information may include, but is not limited to, an applicable final Total Maximum Daily Load (ATMDL@); other relevant water quality data or studies provided by any party; and the results of ESA Section 7 consultation with the U.S. Fish and Wildlife Service and/or National Marine Fisheries Service. In addition to constituting New Information, the outcome of the ESA Section 7 consultation may also satisfy the requirements of 40 C.F.R. '122.62(b)(1). A reopener provision reflecting the foregoing has been added to the permit.
Any modified permit resulting from the reopener must be consistent with applicable anti-backsliding provisions. See e.g., CWA '' 402(o)(1), 303(d)(4)(A)(i), 402(o)(2)(B) (and final paragraph) and 40 C.F.R. ' 122.44(l).
D. Conventional Pollutants
Biochemical Oxygen Demand (BOD5) and Total Suspended Solids (TSS)
In Section IV.A. of this Fact Sheet it was explained the EPA established minimum technology requirements for the pulp and paper industry in the form of effluent guidelines promulgated under 40 C.F.R. ' 430. These guidelines specify the maximum mass (lbs per day) of Five Day Biochemical Oxygen Demand (BOD5) and Total Suspended Solids (TSS) that can be discharged per mass (tons per day) of product produced.
However, none of the effluent guidelines found in 40 C.F.R. ' 430 can be directly applied to the Monadnock Paper Mills. There are no effluent guidelines for a nonintegrated paper mill producing coated specialty papers. In the absence of effluent guidelines (or if applicable effluent guidelines do not regulate a pollutant of concern), EPA is authorized to establish technology-based permit limits on a case-by-case basis using Best Professional Judgment (BPJ).
That first NPDES permit containing the BOD5 and TSS limits was issued on July 13, 1973. This permit contained “tiered” permit limits. The first tier limited BOD5 to 1100 pounds per day maximum and 750 pounds per day on an average monthly basis, while TSS was limited to 6000 pounds per day maximum and 4030 pounds per day on an average monthly basis. The second tier reduced the BOD5 permit limits to 350 pounds per day maximum and 235 pounds per day on an average monthly basis. TSS permit limits were reduced in the second tier to 470 pounds per day maximum and 315 pounds per day on an average monthly basis. Both the first tier and second tier permit limits were based on a production level of 78.1 tons of paper per day (t/d). However, the lower, second tier permit limits were based on the construction and operation of a wastewater treatment plant at the facility by June 30, 1975.
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Therefore, the second tier permit limits were technology-based limits developed using EPA’s BPJ authority.
In the late 1970's the New Hampshire Water Supply and Pollution Control Commission (NH WS&PCC), the predecessor of the NHDES-WD, evaluated the BPJ determination that set the BOD5 and TSS limits for the Monadnock Paper Mills. That evaluation by the NH WS&PCC was contained in Staff Report No. 98 titled, WATER QUALITY STUDY & LOAD ALLOCATION, Contoocook River, Bennington to West Henniker, which was issued in December 1978. The study stated that, A... Monadnock Paper Mills was in full compliance with all its NPDES effluent limits.@ Therefore, the technology-based permit BOD5 limit, effective June 30, 1975, was deemed to be sufficient to protect the water-quality of the Contoocook River, since it was lower than the 500 lbs/day “protective level” cited in the report.
Over the next several permit issuance cycles (1988, 1993, and 2000), both the BOD5 and TSS levels were adjusted based on varying production levels and the season (summer versus winter). At no time were the permitted BOD5 level allowed to exceed the water-quality based “protective level” of 500 pounds per day.
Accordingly, the existing average monthly and maximum daily limits for BOD5 and TSS are continued in the draft permit according to the antibacksliding requirements. See 40 C.F.R. '' 122.44(l)(1) and (2).
Tiered Permit Limits
Monadnock Paper Mills states in their NPDES reapplication that based on the slump in world pulp and paper sales that Monadnock Paper has cancelled several machine upgrades. The TSS limits in the existing permit are based on two paper production levels. The present TSS limits are based on the Monadnock Paper Mills current paper making machinery, which has an average production capacity of 105 tons/day (t/d). The higher TSS limits would be applied if Monadnock Paper Mills upgraded their paper making machinery, raising daily paper production above 105 t/d.
Although Monadnock Paper Mills did not install any machine upgrades during the term of the present permit, the tiered TSS have been maintained in the draft permit. Maintaining the tiered TSS limits would allow Monadnock Paper Mills to install machinery upgrades at a future date, without having to accomplish an antidegradation study.
pH
The pH limits in the draft permit remain unchanged from the existing permit, however, language has been added to the State Permit Conditions (PART I.D.1.a.) allowing for a change in pH
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limit(s) under certain conditions. A change would be considered if the applicant can demonstrate to the satisfaction of NHDES-WD that the in-stream pH standard will be protected when the discharge is outside the permitted range, then the applicant or NHDES-WD may request (in writing) that the permit limits be modified by EPA to incorporate the results of the demonstration.
Anticipating the situation where NHDES-WD grants a formal approval changing the pH limit(s) to outside the 6.5 to 8.0 Standard Units (S.U.) range, EPA has added a provision to this draft permit (See SPECIAL CONDITIONS section). That provision will allow EPA to modify the pH limit(s) using a certified letter approach. This change will be allowed as long as it can be demonstrated that the revised pH limit range does not alter the naturally occurring receiving water pH. Reference Part I.D.1.a. STATE PERMIT CONDITIONS in the draft permit.
E. Non-Conventional and Toxic Pollutants
Water-quality based limits for specific toxic pollutants such as chlorine, ammonia, etc. are determined from numeric chemical specific criteria derived from extensive scientific studies. The EPA has summarized and published specific toxic pollutants and their associated toxicity criteria in Quality Criteria for Water, 1986, EPA 440/5-86-001 as amended, commonly known as the federal "Gold Book". Each criteria consists of two values; an acute aquatic-life criteria to protect against short-term effects, such as death, and a chronic aquatic-life criteria to protect against long-term effects, such as poor reproduction or impaired growth. New Hampshire adopted these "Gold Book" criteria, with certain exceptions and included them as part of the States Water Quality Regulations promulgated on December 3, 1999. EPA uses these pollutant specific criteria along with available dilution in the receiving water to determine a specific pollutant's draft permit limit. Available dilution is discussed in the next subheading.
Available Dilution
As discussed in Section I, the NHDES during this permit cycle began a Total Maximum Daily Load (TMDL) study of the Contoocook River. The section of the Contoocook River which Monadnock Paper discharges into is encompassed by that study. In preparation of the TMDL study, low flow data for the Contoocook River was reassessed resulting in a revised 7Q10. The 7Q10 low flow for the receiving water at this facility was recalculated to be 16.5 cfs. The previous 7Q10 was 19.2 cfs.
The available dilution (also referred to as dilution factor) in the Contoocook River for the process wastewater discharge (Outfall 001) was calculated as 9.6 for the chronic dilution factor and 7.4 for the acute dilution factor. See Attachment D
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for calculation of the available dilution. The chronic available dilution is based on the facility’s permitted average monthly flow of 1.0 MGD (1.547 cfs), a 7Q10 low flow at Outfall 001 of 16.5 cfs, and a State of New Hampshire prescribed minimum 10% set aside for reserve. The acute available dilution is based on the facility’s permitted maximum daily flow of 1.3 MGD (2.01 cfs), a 7Q10 low flow at Outfall 001 of 16.5 cfs, and a State of New Hampshire prescribed minimum 10% set aside for reserve. See 40 C.F.R. ' 122.45(b)(2)(i). The State of New Hampshire has reserved ten percent assimilative capacity of surface water for future needs. See NH Env-Ws 1705.01.
Total Recoverable Aluminum (TRA)
The existing permit contains an average monthly Total Recoverable Aluminum (TRA) limitation at 0.97 mg/l. Based on a recalculated 7Q10, a revised TRA average monthly limit is required. The revised average monthly TRA limit is 0.83 mg/l. As mentioned, the recalculated 7Q10 is a result of the TMDL survey presently being conducted for the Contoocook River. See Attachment D for the dilution Factor calculation.
A maximum daily limit has also been added to the draft permit. A maximum daily limit is additionally referred to as an acute limit, and was calculated to be 5.5 mg/l. This limit is in accordance with 40 C.F.R. § 122.45(d)(1). This regulation requires that for continuous discharges there shall be both maximum daily and average monthly effluent limitations. Since Monadnock Paper Mills’ lagoon system continuously discharges to the Contoocook River, a TRA maximum daily limit has been added to the draft permit.
The EPA considered eliminating the TRA limit from the draft permit. Eliminating the TRA limit was considered because the mean of the average monthly concentration was notably lower than the TRA average monthly limit. The mean value for the average monthly TRA concentration in Monadnock Paper Mills= 62-month set of effluent data is 0.29 mg/l, with a standard deviation for that data set of is 0.18.
An evaluation was performed on the TRA data set to assess whether a reasonable potential existed for TRA concentration in the Monadnock Paper Mills= effluent to exceed the average monthly (chronic) limit. A statistical analysis was conducted on the TRA data set using the method presented in Technical Support Document for Water Quality-based Toxics Controls, March 1991, EPA/505/2-90-001, Section 3.3.2
The statistical approach has two parts. The first is a characterization of the highest measured effluent concentration based on the desired confidence level. The relationship that
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describes this is:
pn = (1 – confidence level) 1/n (Equation. 1)
where pn is the percentile represented by the highest concentration in the data and n is the number of samples.
The second part of the statistical approach is a relationship between the percentile described above and the selected upper bound of the lognormal effluent distribution. For example, if five samples were collected (which represents the 40th percentile), the coefficient of variation is 0.6, and the desired upper bound of the effluent distribution is the 99th percentile, then the two percentiles can be related using the coefficient of variation (CV):
( )( ) 2.4
5.0258.0exp5.0326.2exp
2
2
40
99 =−−−
=σσσσ
cc
(Equation. 2)
where σ2 = ln (CV2 + 1) and 2.326 and -0.258 are the normal distribution values for the 99th and 40th percentiles. The CV is the ratio of the standard deviation to the mean. The resulting value is then multiplied to the highest data value to estimate the maximum expected concentration, and this value is then compared to the water quality standard (which has been adjusted for dilution factor).
There are 62 data points for Monadnock Paper Mills. Using Equation 1:
pn = (1 – confidence level) 1/n
p62 = (1 – 0.99) 1/62
p62 = 0.9285
Next, to calculate a value for CV and σ2, the Monadnock data were used.
CV = standard deviation ÷ mean = 0.176 ÷ 0.292 = 0.60
Then σ2 = ln ((0.60)2 + 1) = 0.3075 and
σ = 0.5545
Next, using Equation 2 and look-up values for z.93 (equals 1.478) from the Cumulative Probability Function for the Standard Normal Distribution:
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( )( )( )
( )( )
60.16659.0exp136.1exp
)5545.0(5.0)5545.0(478.1exp)5545.0(5.05545.0326.2exp
c
c2
2
93
99 ==−−
=
Therefore, the maximum aluminum concentration in Monadnock’s data was multiplied by 1.60 and compared to the water quality standard. The highest data point for Aluminum was 0.8 mg/L, so the resulting value was 1.22 mg/L. The chronic water quality criterion for aluminum is 0.087 mg/L. Accounting for dilution of 9.58, the chronic water quality criteria for aluminum is 0.087 x 9.58, or 0.833. Since 1.22 is greater than 0.833, there is reasonable potential for aluminum to exceed the chronic water quality standard.
Total Phosphorous
Phosphorous promotes the growth of nuisance algae and rooted aquatic Plants. Elevated levels of phosphorous can cause excessive algae and/or plant growth resulting in reduced water clarity and poor aesthetic quality. Through respiration, and the decomposition of plant matter, excessive algae and plant growth can reduce in-stream oxygen concentrations to levels that could adversely impact aquatic life and produce strong odors. There are areas of the reach of the Contoocook River into which Monadnock Paper Mills discharges indicate sag, or decrease, in the River’s dissolved oxygen levels.
The NHDES has scheduled a TMDL study for the portion on the Contoocook River that flows through the towns of Bennington and Antrim, New Hampshire. Presently, NHDES has not announced when that TMDL will be completed. There is a possibility when that TMDL is issued that phosphorous limits will be imposed on the discharges to this section of the Contoocook River.
The wastewater stream of a paper manufacture is typically nutrient deficient. This means the bacteria, which are used to biologically treat the wastewater in the treatment systems lagoons, might not have sufficient nutrients to sustain their population. Monadnock Paper Mills, to enhance biological treatment, adds phosphoric acid to the aeration lagoons. The facility also periodically monitors the level of phosphorous in the lagoon system to ensure there is no excess loading of phosphorous. Currently there is insufficient information and data to determine that phosphorous contained in the Mills’ effluent causes or contributes to the Contoocook River’s impairment. EPA and NHDES-WD are not requiring a phosphorus limit for the Monadnock Paper Mills in the draft permit; however, the draft permit has added a bi-monthly monitoring of phosphorus levels in the facility’s effluent.
EPA and NHDES have added a monitoring requirement for Total Phosphorous in the draft permit. The reporting of Total
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Phosphorous will provide a historical record of the level of phosphorous discharged to the Contoocook River by Monadnock Paper Mills. In the future, the EPA will use this data to determine if phosphorous discharged in the facility’s effluent actually contribute to the impairment of the Contoocook River. Requiring this type of monitoring is allowed under 40 C.F.R. § 124.44(d)(1)(ii).
Biocides
The draft permit continues the requirement of prohibiting the use or discharge of pentachlorophenol or trichlorophenol that are contained in the present permit, thus complying antibacksliding provisions in 40 C.F.R. ' 122.44(l)(2).
F. Other Limits and Requirements
Flow
The requirement to report the existing average monthly and maximum daily flow limits are continued in the draft permit.
Special Low Flow Condition
The existing permit contained a requirement in Section B.1. that Monadnock Paper Mills maintain a minimum flow of 70 cfs, as measured immediately below the tailrace of the Paper Mill Dam or the inflow to the project, whichever is less. The “project” in this case refers collectively to the four Monadnock Paper Mills’ dams that are used to generate hydro-electrical power. The basis for the above minimum flow release requirement to the Contoocook River is the Federal Energy Regulatory Commission (FERC) License Project No. 6597 issued for the Monadnock Hydroelectric Project (Project) to Monadnock Paper Mills, Inc. on August 27, 1984 as corrected on November 23, 1984. By specifying, the immediate minimum Contoocook River flow measured at the Mills’ tailrace the FERC license prescribed the minimum flow requirements of the four upstream dams from Monadnock Paper Mills. Monadnock Paper Mills, by opening or closing gates at the Powder Mill Dam, matches outflow of the Powder Mill Dam tailrace with the inflow of that dam’s impoundment. The FERC license also contains a requirement in Article 26 that Monadnock Paper Mills maintain the “... discharge from each of the other three developments (Powder Mill, Monadnock, and Pierce) a continuous minimum flow of 13 cfs or inflow to the developments, whichever is less, ...” This minimum flow, over each dam, is to be maintained to protect the aquatic resources of the project area. The 13 cfs does not represent the minimum flow of the Contoocook River. See Attachment E.
The EPA and NHDES-WD have eliminated these minimum flow requirements from the draft permit because in the Monadnock Paper Mills case, flow regulation is the responsibility of FERC. FERC
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is responsible to direct what minimum flows the Mills shall maintain because Monadnock Paper Mills owns and operates these four dams on the Contoocook River in order to produce hydroelectric power for the facility.
The existing permit also contains another requirement in Section B.1. that Monadnock Paper Mills “ … shall maintain the opening in the waste gate at the High Gate (Paper Mill) Dam to maintain the 7Q10 flow of 19.2 cfs whenever possible or the inflow to this Project, whatever value is less.” Thus, the situation now exists that one regulatory agency, the EPA, is requiring Monadnock Paper Mills to maintain a minimum flow (19.2 cfs) which is higher than the minimum flow (13 cfs) that was required by another regulatory agency, FERC. Monadnock Paper Mills could be in violation of their NPDES permit by not maintaining a flow of 19.2 cfs through their dam complex, but not be in violation of their FERC license if the flow was maintained at 13 cfs. The EPA, therefore, has dropped the requirement for Monadnock Paper Mills to maintain a minimum flow equal to the Contoocook River’s 7Q10 flow. This eliminates the situation where two federal agencies permit requirements are in conflict.
The existing permit further contains a requirement that Monadnock Paper Mills cease discharge of wastewater to the Contoocook River when water removal by the Mills lowers the flow of the River below the river’s 7Q10. Although the likelihood is small that the Mills operations would lower the Contoocook River’s flow below the River’s 7Q10, the draft permit maintains the requirement for Monadnock Paper Mills to cease discharge of wastewater if the Mills’ operations cause the Contoocook River’s flow below the 7Q10. As previously explained, the 7Q10 low flow was recalculated as 16.5 cfs from 19.2 cfs by the NHDES for an ongoing TMDL study. The 7Q10, then, that triggers the cessation of wastewater flow has been changed to 16.4 cfs from 19.2 cfs.
Reopener Clause
A reopener clause was included in the draft permit. The permit can be modified if the need is demonstrated by any future analysis of the allowable loadings of the oxygen demanding pollutants and nutrients. This includes possible results of the on-going TMDL study.
Whole Effluent Toxicity
EPA's Technical Support Document for Water Quality-based Toxics Control, EPA/505/2-90-001, March 1991, recommends using an "integrated strategy" containing both pollutant (chemical) specific approaches and whole effluent (biological) toxicity approaches to control toxic pollutants in effluent discharges
from entering the nation's waterways. EPA-New England adopted
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this "integrated strategy" on July 1, 1991, for use in permit development and issuance. These approaches are designed to protect aquatic life and human health. Pollutant specific approaches such as those in the Gold Book and State regulations address individual chemicals, whereas, whole effluent toxicity (WET) approaches evaluate interactions between pollutants thus rendering an "overall" or "aggregate" toxicity assessment of the effluent. Furthermore, WET measures the "Additive" and/or "Antagonistic" effects of individual chemical pollutants which pollutant specific approaches do not, thus the need for both approaches. In addition, the presence of an unknown toxic pollutant can be discovered and addressed through this process.
Section 101(a)(3) of the CWA specifically prohibits the discharge of toxic pollutants in toxic amounts and New Hampshire law states that, "all waters shall be free from toxic substances or chemical constituents in concentrations or combination that injure or are inimical to plants, animals, humans, or aquatic life;...." (N.H. RSA 485-A:8, VI and the N.H. Code of Administrative Rules, PART Env-Ws 1703.21(a)). The federal NPDES regulations at 40 C.F.R. (122.44(d)(1)(v) require whole effluent toxicity limits in a permit when a discharge has a "reasonable potential" to cause or contribute to an excursion above the State's narrative criterion for toxicity.
Where EPA-New England believes toxicity testing and limits are appropriate and necessary as described in the previous paragraph, the type of toxicity testing (acute and/or chronic) and the effluent limitation (LC50 and/or C-NOEC) are established based on the available dilution. The LC50 is defined as the concentration of toxicant, or in this draft permit as percentage of effluent, that would be lethal to 50% of the test organisms during a specific time period. The C-NOEC (Chronic-No Observed Effect Concentration) is defined as the highest concentration effluent to which organisms are exposed in a life cycle or partial life cycle test, which causes no adverse effect on growth, survival or reproduction where the test results (growth, survival and/or reproduction) exhibit a linear dose-response relationship. In those instances where these test results do not exhibit a linear dose-response relationship, the permittee is required to report the lowest concentration where there is no observable effect.
The toxicity testing results are summarized in Attachment C for the period March 2001 to September 2005. There was one indication of chronic toxicity, a C-NOEC of 25 percent, for Pimephales promelas species in the September 2001 test results.
In accordance with the antibacksliding provisions in 40 C.F.R. ' 122.44(l)(2) this draft permit continues the WET testing requirement with two acute and chronic toxicity tests each year with two species and maintains the LC50 and C-NOEC limits. The
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draft permit contains an LC50 limit of 100% effluent concentration and a C-NOEC reporting requirement. The two tests are to be performed on a semi-annual basis using the species Daphnid (Ceriodaphnia dubia) and Fathead Minnow (Pimephales promelas). Further details on the dilution water for these two species are provided below.
The semiannual sampling for the WET test requirement shall be collected and tests completed during the calendar quarters ending March 31st and September 30th of each year. Results are to be submitted to EPA and the NHDES-WD by the 15th day of the month following the end of the quarter sampled; that is April 15th and October 15th, respectively.
If toxicity is found, though, monitoring frequency and testing requirements may be increased. The permit may also be modified, or alternatively, revoked and reissued to incorporate additional toxicity testing requirements or chemical specific limits. These actions will occur if the Regional Administrator determines the NH Standards are not adequately enforced and users of the waterways are not adequately protected during the remaining life of the permit. Results of these toxicity tests are considered "new information not available at permit development"; therefore, the permitting authority is allowed to use said information to modify an issued permit under authority in 40 C.F.R. ' 122.62(a)(2).
As a special condition of this draft permit (See applicable paragraph under SPECIAL CONDITIONS section), the frequency of testing may be reduced by a certified letter from EPA. This permit provision anticipates that the permittee may wish to request a reduction in WET testing. After completion of a minimum of four consecutive WET tests, all of which must be valid tests and must demonstrate compliance with the permitted limits for whole effluent toxicity, the permittee may submit a written request to the EPA seeking a review of the toxicity test results.
The EPA will review the test results and other pertinent information to make a determination. The frequency of toxicity testing may be reduced to as little as once per year. The permittee is required to continue testing at the frequency specified in the permit until the permit is either formally modified or until the permittee receives a certified letter from the EPA indicating a change in the permit conditions. This special condition does not negate the permittee's right to request a permit modification at any time prior to the permit expiration.
The permittee is required in the draft permit to use the receiving water as a control. If toxicity tests using the receiving water as the control are or would be invalid because the receiving water shows toxicity, the EPA allows the use of
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alternate dilution water. The draft permit requires three controls when alternate dilution water is used: 1) alternate dilution water (if culture water is not used as a diluent), 2) lab water control, and 3) site water control for future tests. The alternate dilution water will need to match the characteristics of the Contoocook River and it must be of a known quality with water-quality characteristic such as organic carbon, total suspended solids, pH, specific conductivity, alkalinity, and hardness similar to that of the Contoocook River. If the alternate dilution water is a lab water that does not require an adjustment to simulate the water chemistry of the receiving water, then two controls are required - the lab water and the site water. Prior to toxicity testing, it is recommended that the permittee screen the alternate dilution water for suitability.
This draft permit requires the reporting of selected parameters determined from the chemical analysis of the WET tests 100% effluent samples. Specifically, parameters for the constituents of ammonia nitrogen as nitrogen, hardness, and total recoverable cadmium, copper, chromium, lead, nickel, and zinc are to be reported on the appropriate Discharge Monitoring Reports for entry into the EPA's Integrated Compliance Information System (ICIS) Data Base. EPA New England does not consider reporting these requirements an unnecessary burden as the reporting of these constituents is required with the submission of each toxicity report (See Draft Permit, ATTACHMENT A, page A-8).
G. Essential Fish Habitat and Endangered Species.
Essential Fish Habitat
Under the 1996 Amendments (PL 104-267) to the Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C. ' 1801 et seq.(1998)), EPA is required to consult with NMFS if EPA=s action or proposed actions that it funds, permits, or undertakes, Amay adversely impact any essential fish habitat.@ See 16 U.S.C. ' 1855(b). The Amendments broadly define Aessential fish habitat@ (EFH) as: Awaters and substrate necessary to fish for spawning, breeding, feeding, or growth to maturity. See 16 U.S.C. ' 1802(10). Adversely impact means any impact which reduces the quality and/or quantity of essential fish habitat (EFH). See 50 C.F.R. ' 600.910(a). Adverse effects may include direct (e.g., contamination or physical disruption), indirect (e.g., loss of prey, reduction in species' fecundity), site-specific or habitat-wide impacts, including individual, cumulative, or synergistic consequences of actions. Id.
Essential fish habitat is only designated for fish species for which federal Fisheries Management Plans exist. See 16 U.S.C. ' 1855(b)(1)(A). EFH designations for New England were approved by the U.S. Department of Commerce on March 3, 1999.
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The Merrimack River and its tributaries, including the Contoocook River in the vicinity of Bennington, New Hampshire are designated essential fish habitat (EFH) for Atlantic salmon (Salmo salar). According to the New Hampshire Fish and Game Department (NHFGD), stocking of salmon fry in the Contoocook is limited to the reach between the towns of Hillsborough and Henniker. Bennington is approximately eight miles upstream from Hillsborough, and NHFGD currently has no plans to stock this stretch of the Contoocook.
Based on the permit limits and monitoring requirements identified in this fact sheet and permit that are designed to be protective of aquatic life, EPA has determined that a formal EFH consultation with National Marine Fisheries Service (NMFS) is not required because the proposed discharge is not likely to adversely affect Atlantic salmon EFH. If adverse effects to EFH do occur as a result of this permit action, or if new information becomes available that changes the basis for this determination, then NMFS will be notified and consultation will be promptly initiated.
Endangered Species
The Endangered Species Act (16 USC 1451 et seq) requires the EPA to ensure that any action authorized by the EPA is not likely to jeopardize the continue existence of any endangered or threaten species or adversely affect its critical habitat. Further, 40 CFR 122.49(c) requires the EPA to consult with the U.S. Fish and Wildlife Service (USFWS) and/or NMFS, as appropriate, to determine particular permit conditions when the regulations of the Endangered Species Act may apply.
Previous consultations with the USFWS have indicated there are no endangered species presently know to reside in the area of the Contoocook River where the Monadnock Paper Mills discharges.
H. Outfall 002
Each year Monadnock Paper Mills rehabilitates two groundwater wells. These wells supply the water used in the Mills’ paper making processes. The rehabilitation, also referred to as redevelopment, includes three chemical treatments. The first treatment is a chemical mixture of muriatic acid (HCL water mixture) and QC-21 (an acidic Layne Christensen priority solution). This mixture is used to break down well screen clogging mineral deposits. The mixture is injected into the well where the solution is allowed to mix with the well clogging mineral deposits for 6 to 12-hours. It is then mechanically surged and backwashed into and out of the well screen for 4-hours. Next, the solution is pumped into a sedimentation/neutralization tank where hydrated lime or light soda ash is added to neutralize any remaining acid. The treated
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solution is then released to the ground.
The second treatment, which is optional, injects sodium hexametaphosphate into the well. Sodium hexametaphosphate is a sequestering agent, which facilitates the removal of fine sands, silt and clay from the aquifer formation adjacent to the well screen. Additionally, chlorine is added to the treatment solution to inhibit biological growth in the well. The solution is pumped to the previously mentioned sedimentation/neutralization tank. Sodium hexametaphosphate does not require any special neutralization, however, any residual chlorine is neutralized with sodium metabisulfite. After treatment, the treated solution is released to the ground. The final treatment consists of injecting sodium or calcium hypochlorite into the well. The solution is allowed to react in the well for 6 to 12-hours. It is then mechanically surged and backwashed into and out of the well screen for 4-hours. The solution is then pumped into the sedimentation/neutralization tank where residual chlorine is neutralized with sodium metabisulfite. The solution is released to the ground.
Based on the volumes involved and the location of where the sedimentation/neutralization tank contents are emptied there is a potential for a portion of the treated wastewater to flow into the Contoocook River. In previous years, Monadnock Paper Mills, in order to discharge the treated solutions used for well redevelopment, was issued an EPA-New England NPDES permit exclusion for this discharger. A NHDES Temporary Surface Water Discharge Permit regulated the redevelopments solutions’ discharge. In 2005 the EPA and NHDES issued a Remediation General Permit (RGP)which eliminated the need for “exclusions” and/or temporary discharge permits for the most common surface water discharges found at contaminated groundwater remediation sites, contaminated construction dewatering and discharges that contain petroleum products, solvents and metals. The RGP was intended to be used at remediation sites.
Since Monadnock’s well redevelopment is not at a contaminated or formerly contaminated site, Monadnock cannot apply for the RGP. Monadnock’s well development discharges now require an individual NPDES permit, because the EPA New England Region no longer issues “exclusion” letters for ground water discharges.
Monadnock’s well redevelopment involves cleaning and de-scaling the well with acid solutions; injecting a biocide into the well; treating the solutions used to redevelop the well; and discharging the treated wastewater on the ground. Limits and monitoring requirements have been added to the draft permit to ensure these processes present no potential to pollute. The following limits and monitoring requirements for Outfall 002 are
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added to the draft permit:
• pH limit – To determine whether the acid solutions are neutralized sufficiently to meet State water quality standards for pH.
• Total Suspended Solids (TSS) – To determine whether material or deposits extracted from the well have been sufficiently precipitated out of the treated wastewater. The TSS limit of 50 mg/l is based on the RGP TSS limit for construction site dewatering. The RGP limits the concentration of suspended solids in the water being pumped from construction sites at 50 mg/l. EPA and NHDES consider well redevelopment analogous to dewatering at a construction site. The solutions injected into a well during the well redevelopment process entrain solids (scale removed from the well’s structure and silt). Accordingly, EPA and NHDES have adopted the 50 mg/l TSS limit for the treated solutions employed during well redevelopment at Monadnock Paper Mills.
• Total Phosphorous – Monitored to determine what concentration level of phosphorous is contained in the treated wastewater. Phosphorous is a component of some of the well cleaning solutions.
• Total Residual Chlorine - Monitored to determine that the dechlorination treatment is complete. Chlorine is a component of some of the well cleaning solutions and is injected into the well as a biocide.
• Turbidity – Monitored to determine the relative cloudiness of the wastewater discharge as compared to the Contoocook River.
Additionally, the draft permit will require the well redevelopment wastewater not be discharged during periods of wet weather or when the ground is frozen. The draft permit will also require Monadnock Paper Mills to prevent any erosion of the Contoocook River’s banks from the well redevelopment wastewater discharge. As a check that no erosion of the river bank has occurred, Monadnock Paper Mills will be required to photograph all possible point of discharge to the Contoocook River before and after any discharge from Outfall 002.
I. Additional Requirements and Conditions
The effluent monitoring requirements have been established to yield data representative of the discharge under the authority of
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Section 308(a) of the CWA in accordance with 40 C.F.R. '122.41(j), 122.44(i) and 122.48. The remaining conditions of the permit are based on the NPDES regulations 40 C.F.R. Parts 122 through 125 and consist primarily of management requirements common to all permits. A comparison of the existing permits and the draft permit sampling conditions is shown in the following table; with any changes highlighted:
Outfall 001 Effluent Monitoring Comparison
Parameter Sampling Frequency Sample Type Sampling
Frequency Sample Type
Flow Continuous Recorder Continuous Recorder
pH 1/Day Grab 1/Day Grab
BOD5 1/Week Grab 1/Week Grab
TSS 1/Week Grab 1/Week Grab
Total Recoverable 2/Month Grab 2/Month Grab
Total Phosphorous 2/Month Grab
WET 2/Year Grab 2/Year Grab
Outfall 002 Effluent Monitoring Comparison
Parameter Sampling Frequency Sample Type Sampling
Frequency Sample Type
Flow As Required Estimate
pH 1/Discharge Grab
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TSS 1/Discharge Grab
Turbidity 1/Discharge Grab
Total Phosphorous 1/Discharge Grab
Total Residue Chlorine 1/Discharge Grab
V. Antidegradation
This draft permit is being reissued with an allowable wasteload identical to the existing permit with the same parameter coverage and no change in location of the outfalls. EPA expects the State of New Hampshire, during the review of this draft permit as part of the State Certification process, to determine that there will be no lowering of water quality and no loss of existing water uses and that no additional antidegradation review is warranted.
VI. State Certification Requirements.
EPA may not issue a permit unless the State Water Pollution Control Agency with jurisdiction over the receiving water(s) either certifies that the effluent limitations and/or conditions contained in the permit are stringent enough to assure, among other things, that the discharge will not cause the receiving water to violate NH Standards or waives its right to certify as set forth in 40 C.F.R. § 124.53.
Upon public noticing of the draft permit, EPA is formally requesting that the State's certifying authority make a written determination concerning certification. The State will be deemed to have waived its right to certify unless certification is received within 60 days of receipt of this request.
The NHDES-WD is the certifying authority. EPA has discussed this draft permit with the Staff of the Wastewater Engineering Bureau and expects that the draft permit will be certified. Regulations governing state certification are set forth in 40 C.F.R. §§ 124.53 and 124.55.
The State's certification should include the specific conditions necessary to assure compliance with applicable provisions of the Clean Water Act Sections 208(e), 301, 302, 303, 306 and 307 and
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with appropriate requirements of State law. In addition, the State should provide a statement of the extent to which each condition of the draft permit can be made less stringent without violating the requirements of State law. Since the State's certification is provided prior to permit issuance, any failure by the State to provide this statement waives the State's right to certify or object to any less stringent condition. These less stringent conditions may be established by EPA during the permit issuance process based on information received following the public noticing. If the State believes that any conditions more stringent than those contained in the draft permit are necessary to meet the requirements of either the CWA or State law, the State should include such conditions and, in each case, cite the CWA or State law reference upon which that condition is based. Failure to provide such a citation waives the right to certify as to that condition. The only exception to this is the sludge conditions/requirements implementing Section 405(d) of the CWA are not subject to the Section 401 State Certification requirements. Reviews and appeals of limitations and conditions attributable to State certification shall be made through the applicable procedures of the State and may not be made through the applicable procedures of 40 C.F.R. Part 124.
It should be noted that under CWA § 401, EPA’s duty to defer to considerations of state law is intended to prevent EPA from relaxing any requirements, limitations or conditions imposed by state law. Therefore, “[a] State may not condition or deny a certification on the grounds that State law allows a less stringent permit condition.” 40 C.F.R. §124.55(c). In such an instance, the regulation provides that, “The Regional Administrator shall disregard any such certification conditions or denials as waivers of certification.” Id. EPA regulations pertaining to permit limits based upon water quality standards and state requirements are contained in 40 C.F.R. § 122.4 (d) and 40 C.F.R. § 122.44(d).
VII. Comment Period, Hearing Requests, and Procedures for Final Decisions.
All persons, including applicants, who believe any condition of the draft permit is inappropriate must raise all issues and submit all available arguments and all supporting material for their arguments in full by the close of the public comment period to:
Mr. John Paul King, Environmental Scientist U.S. Environmental Protection Agency
1 Congress Street Suite 1100 (Mailcode CPE)
Boston, Massachusetts 02114-2023
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Telephone: (617) 918-1295 FAX No.: (617) 918-1505
Any person, prior to such date, may submit a request in writing for a public hearing to consider the draft permit to EPA-New England and the State Agency. Such requests shall state the nature of the issues proposed to be raised in the hearing. A public hearing may be held after at least thirty (30) days public notice whenever the Director finds that response to this notice indicates significant public interest. In reaching a final decision on the draft permit, the Regional Administrator will respond to all significant comments and make these responses available to the public at EPA New England's Boston office.
Following the close of the comment period, and after a public hearing, if such hearing is held, the Director will issue a final permit decision and forward a copy of the final decision to the applicant and each person who has submitted written comments or requested notice.
Stephen S. Perkins, Director Date Office of Ecosystem Protection U.S. Environmental Protection Agency
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ATTACHMENT A
Location Monadnock Paper Mills and Outfall 001
Monadnock Paper Mills
Outfall 001
Area of Outfall 002 Potential
Discharge
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ATTACHMENT B
Monadnock Paper Mills Process Water and Wastewater Flow
Note: Typical operating day water flow (in MGD) with one grader change per paper machine. Diagram taken from drawing prepared in 1998 by Monadnock Paper Mills.
RIVER WATER
M SAND
FILTERS WELL
WATER BOILER
WET WELL
M
PAPER COATER
No. 1&2 PAPER
MACHINE
.022 1.080 .022
EVAPORATION
WASTEWATER TREATMENT
WATER SYSTEM
M
OUTFALL 001 CONTOOCOOK
RIVER
ROOF DRAIN STORMWATER
.720
.547
CITY WATER M
SANITARY
CITY TREATMENT
.360
COOL WATER SUMP
- Manhole
DEWATERING PRESS
OUTFALL 002 CONTOOCOOK
RIVER
Treatment Tank
.050
0.0
.684
.338
.252
.360
.108
.017
.015
.002
.036
.029
.079
.086
M
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ATTACHMENT C
TABLE I
EFFLUENT CHARACTERISTICS AT OUTFALL 001
The following effluent characteristics were derived from analysis of discharge monitoring data collected from Outfall 001 during the 61-month period, January 2001 through February 2006. This data was extracted from the monthly Discharge Monitoring Reports submitted by Monadnock Paper Mills. These effluent values characterize the process wastewaters discharged from this facility.
Effluent Characteristic Average of Average Monthly
Maximum of Maximum Daily1
Flow (MGD) 0.489 0.84, 0.81, 0.79
pH (Standard Units)
6.5 to 8.02
TSS, Winter (lbs/day) 148.9 651, 569, 291
TSS, Summer (lbs/day) 78.5 277, 250, 210
BOD5, Winter (lbs/day) 131.2 460, 406, 335
BOD5, Summer (lbs/day) 72.8 263, 250, 221
Aluminum (mg/l) 0.29 1.07, 1.01, 0.74
1. More than one number represents the second and third highest values, except for pH. 2. Numbers listed are minimum and maximum daily readings.
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ATTACHMENT C (con’t)
TABLE II
WHOLE EFFLUENT TOXICITY TESTING
Effluent Test Minimums of Maximum Test Result
LC501 (Per Cent Effluent)
Ceriodaphnia dubia 100 100 100
Pimephales promelas 100 100 100
C-NOEC2 (Per Cent Effluent)
Ceriodaphnia dubia
100 100 100
Pimephales promelas 25
100
100
1. This test involves preparing a series of effluent concentrations by diluting the effluent with control water. Groups of test organisms, i.e. Ceriodaphnia dubia and Pimephales promelas, are exposed to each effluent concentration and a control for a specific period. The mortality data for each concentration can be used to calculate (by regression) the medium lethal concentration or LC-50. LC-50 is defined as the concentration which kills half the test organisms. Samples with a high LC-50 value are less likely to impact an organism’s survival.
2. This test measures the sublethal effects by exposing test organisms to effluent samples during a sensitive period in their life cycle. Chronic minnow (Pimephales promelas) tests measure growth (weight) and survival during the seven-day test; chronic daphnid (Ceriodaphnia dubia) tests measure juvenile production and survival. Using Analysis of Variance techniques to evaluate data, it is possible to determine the highest concentration of effluent where no effect (C-NOEC) was observed.
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ATTACHMENT D
AVAILABLE DILUTION FACTOR
Equation used to calculate available dilution factor at Outfall 001.
Dilution Factor = 9.6
Where:
Q001 - Equivalent 7Q10 flow at Outfall 001, in CFS. Q001 = 16.5 CFS
QPDF -
Monadnock Paper Mill=s permitted process wastewater flow, in MGD.
QPDF = 1.0 MGD; Chronic Limit, based on monthly average flow
QPDF = 1.3 MGD; Acute Limit; based on daily maximum flow
1.547 - Conversion Factor; MGD to cfs
0.9 - 10% reserve of river's assimilative capacity.
WATER QUALITY CRITERIA BASED LIMIT
Equation used to calculate acute and chronic Total Recoverable Aluminum (TRA) limits.
TRA = Dilution Factor x Water Quality Criteria
Where:
Water Quality Criteria for TRA:
0.087 mg/l; Chronic Criterion to Protect Aquatic Life 0.75 mg/l; Acute Criteria to Protect Aquatic Life.
( ) 9.0547.1Q
QFactorDilution
001 ××
=
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FERC REQUIRMENT “… discharge .. a continious minimum flow of 70 cfs, as measured immediately below the tailrace of the Paper Mill Dam of inflow to the priject, whichever is less
Powder Mill Dam
Monadnock Dam
Pierce Dam
High Gate or Paper Mill Dam
Monadnock Paper Mills, Inc.
Contoocook River
In-Flow to Developments
In-Flow to Hydro-Electric Generator
Hydro-Electric Facility
Dam
Mills’ Hydro-Electric Generator
FERC REQUIRMENT “.. discharge from each of the other three developments (Powder Mill, Monadnock, and Pierce) a continious minimum flow of 13 cfs or inflow to the developments, whichever is less, …”
ATTACHMENT E
MONADNOCK PAPER MILLS
DAM PROJECT DIAGRAM
