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ASPECT CONSULTING <br />PROJECT NO. AS190583A-08  MAY 21, 2025 FINAL 7 <br /> <br />plant included two secondary clarifiers and secondary aeration basins, from which treated <br />mill wastewater was discharged to the East Waterway through two outfalls located <br />adjacent to the facility (Outfalls 003 and 008) and via the deep-water Outfall SW001 <br />shared with Weyerhaeuser and located southwest of Port of Everett’s Mill A Site, more <br />than a mile south of the Upland Area. <br />In 2004, K-C, with the City of Everett, constructed a deep-water outfall (Outfall 100) to <br />replace deep water Outfall SW001, which was plugged and demolished in the nearshore <br />area. Outfall 100 is located adjacent to decommissioned Outfall SW001 and became fully <br />operational in 2005. Under its National Pollutant Discharge Elimination System (NPDES) <br />permit WA-000062-1, K-C was authorized to discharge treated process wastewater, <br />stormwater, and noncontact cooling water to deep water Outfall 100. Outfall 100 also <br />discharges regional municipal wastewater from the Cities of Everett and Marysville. On <br />September 5, 2012, K-C sent Ecology’s Industrial Section a notice of their intent to <br />surrender their NPDES permit WA-000062-1. Ecology’s Industrial Section sent K-C <br />correspondence on September 19, 2012, that the NPDES permit was terminated. City of <br />Everett continues their permitted discharges to Outfall 100. K-C was also authorized under <br />the NPDES permit to discharge treated process wastewater, stormwater, and noncontact <br />cooling water from Outfalls 003 and 008 in emergencies and shutdowns. <br />Figure 2-3 depicts locations of historical underground pipelines and outfalls at the K-C <br />mill, based on an AutoCAD® file prepared by K-C in the 1990s-2000s from available <br />historical maps, and thus representing a historical composite. Numerous changes to <br />subsurface piping occurred at the former mill over its 80-year history, often with limited <br />documentation of older changes, and because the mill demolition contract specifications <br />required that all mill infrastructure in the upper 2 feet (and some at greater depths) be <br />removed during the 2012-2013 mill demolition. Some piping shown may have been <br />removed during mill operations, without documentation, and some piping was also <br />removed during the two interim actions (see Sections 4.1 and 4.3). Consequently, <br />Figure 2-3 displays piping that once existed, but it is not necessarily representative of <br />current conditions. <br />2.2.3.3 Pulp and Paper Mill Hazardous Waste Management <br />The pulp and paper mill was a large-quantity generator of hazardous waste (Resource <br />Conservation and Recovery Act [RCRA] ID number WAD009250820) from the early <br />1980s until its closure in 2012. The mill was never a hazardous waste Treatment, Storage, <br />and Disposal Facility (TSDF) under RCRA. The mill’s 90-day Hazardous Waste <br />Accumulation Unit (HWAU, also known as “haz waste cage”) was a secure storage unit in <br />which hazardous and nonhazardous waste materials generated at the mill were temporarily <br />stored prior to proper off-Site disposal. The HWAU is located on the southeast corner of <br />the former log pond and is shown on Figure 2-2 (co-located with item number 12 in the <br />legend). Prior to closure, K-C accumulated waste materials within the HWAU for periods <br />of less than 90 days and handled and disposed of the wastes in accordance with applicable <br />requirements of the Washington State Dangerous Waste Regulations (Chapter 173-303 <br />WAC). One of the final steps in mill demolition was to conduct clean closure of the <br />HWAU, as described in the RCRA Closure Report for the mill (Aspect, 2013b). This <br />report can be viewed on Ecology’s website using the link provided in Section 1.