Addendum to the Fact Sheet for State Waste Discharge Permit No. ST0005507

February 21, 2012

1. General Information

Facility: Twin City Foods, Inc. 501 West Fourth Street

Ellensburg, WA 98926 Contact: Grant Craig

Ellensburg Division Manager Twin City Foods, Inc. (509) 962-9806 Ext.225

2. Application and Compliance Review Twin City Foods Inc. (TCF) submitted an application to Ecology on January 1, 2011 for permit reissuance, and Ecology accepted it on February 7, 2011. Ecology reviewed inspections and assessed compliance of the facility’s discharge with the terms and conditions in the previous permit. Ecology has sufficiently reviewed the application, discharge monitoring reports, and other facility information in enough detail to ensure that: • TCF has complied with all of the terms, conditions, requirements and schedules of

compliance of the expired permit with the exception of a few minor pH and flow limit exceedances and one major spill to the City of Ellensburg wastewater collection system. Ecology issued an $80,000 penalty to the facility on May 5, 2009. The facility is in the process of constructing improved wastewater treatment facilities (described below).

• Ecology has up-to date information on the TCF waste treatment practices, the facility’s production levels; and the nature, content, volume, and frequency of its discharge.

• The discharge meets applicable effluent standards and limits, ground water quality standards, and other legally applicable requirements.

Since the issuance of the current permit, Ecology has not received any additional information, which indicates that environmental impacts from the discharge warrant a complete renewal of the permit. Therefore, Ecology chose to reauthorize this permit.

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3. Permit Reauthorization

When Ecology reauthorizes a discharge permit it essentially reissues the permit with the existing limits, terms and conditions. Alternatively, when Ecology renews a permit it re-evaluates the impact of the discharge on the ground water or publicly owned treatment plant, which may lead to changes in the limits, terms and conditions of the permit. The permit reauthorization process, along with the renewal of high priority permits, allows Ecology to reissue permits in a timely manner and minimize the number of active permits that have passed their expiration dates. Ecology assesses each permit that is expiring and due for reissuance and compares it with other permits due for reissuance when it plans its workload for the upcoming year. This fact sheet addendum accompanies the permit, which Ecology proposes to reauthorize for the discharge of wastewater to ground and to the POTW. The previous fact sheet explains the basis for the discharge limits and conditions of the reauthorized permit and remains as part of the administrative record.

4. Local Limits Evaluation

Appendix C contains the calculations for performance based limits for discharges to the Ellensburg POTW based on performance data from November 2009 through April 2011. Small discharges to the POTW occur during the winter season, when the sprayfield is not available, normally from November through April. TCF, under contract with the City, must pay a surcharge for wastewater above the strengths listed below. The performance based limits are those limits which Ecology believes constitute an enforceable violation due to inadequate treatment.

Local Limits Total BOD 750 mg/L TSS 250 Chlorine 0.05 mg/L Flow 100,000 gallons/Day pH Between 5.5 and 9.0 at all times

Appendix C also contains DMR data on sprayfield discharges from February 1, 2007 through September 1, 2011. The user contract is contained in Appendix C as well.

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5. Permit Limits and Conditions The reauthorized permit is virtually identical to the previous permit issued on December 22, 2006 with a few exceptions identified below. Ecology removed the completed report requirements that do not require additional or continued assessment. The proposed reauthorized permit includes: • The discharge limits and conditions in effect at the time of expiration of the previous

permit. • Changes to the submittal dates for reports from those in the previous permit. • Adjusted dates for the other necessary compliance and submittal requirements carried

over from the past permit including an adjusted compliance schedule for construction of the improvements to the wastewater treatment plant (see below).

• A new requirement, Appendix A, which identifies the required test methods, detection levels and quantitation levels for the monitoring required in the proposed permit. Ecology added this requirement to ensure that facilities use test methods with detection levels that will detect pollutants at levels necessary to evaluate ground water quality standards and compliance with local limits.

• Additional pretreatment requirements. The proposed permit requires TCF to complete construction of its wastewater aerated treatment lagoon by January 31, 2014. The previous permit required construction of the lagoon during the previous permit term. However, due to the complexity of land ownership among multiple federal, state and local landowners that process has taken longer than expected. Ecology issued an extension to complete the lagoon to the January 2014 date in a letter sent on September 30, 2011. Upon completion of the lagoon installation, Ecology may issue a new permit at that time or allow the reauthorized permit to remain in effect until the end of the permit cycle in 2017.

6. Public Process

Ecology public notices the availability of the draft reauthorized permit at least 30 days before it reissues the permit. Ecology invites you to review and comment on its decision to reauthorize the permit (see Appendix A-Public Involvement Information for more detail on the Public Notice procedures). After the public comment period has closed, Ecology will prepare a Response to Comments document and attach it to this fact sheet addendum. Ecology will respond to each comment and describe the resultant changes to the permit in this document. Ecology sends a copy of the Response to Comments to all parties that submitted comments.

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7. Permit Appeal Process

Appendix B describes the permit appeal process.

8. Recommendation for Permit Issuance

Ecology proposes to reissue this permit for 5 years.

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Appendix A--Public Involvement Information

Ecology proposes to reissue a permit to Twin City Foods - Ellensburg. The permit includes wastewater discharge limits and other conditions. This fact sheet describes the facility and Ecology’s reasons for requiring permit conditions. Ecology will place a Public Notice of Draft on February 27, 2012 in the Ellensburg Daily Record to inform the public and to invite comment on the proposed draft state waste discharge permit and fact sheet. The notice: • Tells where copies of the draft permit and fact sheet are available for public evaluation (a

local public library, the closest regional or field office, posted on our website). • Offers to provide the documents in an alternate format to accommodate special needs. • Asks people to tell us how well the proposed permit would protect the receiving water. • Invites people to suggest fairer conditions, limits, and requirements for the permit. • Invites comments on Ecology’s determination of compliance with antidegradation rules. • Urges people to submit their comments, in writing, before the end of the comment period. • Tells how to request a public hearing about the proposed NPDES permit. • Explains the next step(s) in the permitting process. NOTICE: ANNOUNCEMENT OF AVAILABILITY OF DRAFT

REAUTHORIZATION PERMIT PERMIT NO.: ST0005507 APPLICANT: TWIN CITY FOODS, INC. PO BOX 699 STANWOOD, WA 98292 FACILITY: ELLENSBURG FACILITY Twin City Foods, Inc. has applied for renewal of State Waste Discharge Permit No. ST0005507 for its Ellensburg facility in accordance with the provisions of Chapter 90.48 Revised Code of Washington (RCW), Chapter 173-216 Washington Administrative Code (WAC), and the Federal Water Pollution Control Act as amended. Following evaluation of the application and other available information, a draft permit has been developed which would allow the discharge of wastewater by applying it to land via spray irrigation at permitted rates on designated irrigation lands from its facility located at 501 West Fourth Street, Ellensburg, WA. All discharges to be in compliance with the Department of Ecology's Water Quality Standards for a permit to be issued. A tentative determination has been made to reauthorize this permit based on the effluent limitations and special permit conditions that will prevent and control pollution. A final determination will not be made until all timely comments received in response to this notice have been evaluated.

Addendum to the Fact Sheet For State Waste Discharge Permit No. ST0005507 Page 6 of 20 PUBLIC COMMENT AND INFORMATION The draft permit and fact sheet may be viewed at the Department of Ecology (Department) website: www.ecy.wa.gov/programs/wq/permits/wwdischargepermits.html. The application and other related documents are available at Ecology’s Central Regional Office for inspection and copying between the hours of 8:00 a.m. and 4:30 p.m., weekdays. To obtain a copy or to arrange to view copies at the Central Regional Office, please call Roger Johnson at 509/454-7658, e-mail roger.johnson@ecy.wa.gov , or write to the address below. Interested persons are invited to submit written comments regarding the proposed permit. All comments must be submitted by April 5, 2012 to be considered for the final determination. E-mail comments should be sent to cynthia.huwe@ecy.wa.gov . Comments should be sent to:

Cindy Huwe Department of Ecology Central Regional Office

15 West Yakima Avenue, Suite 200 Yakima, WA 98902

Any interested party may request a public hearing on the proposed permit within 30 days of the publication date of this notice. The request for a hearing shall state the interest of the party and the reasons why a hearing is necessary. The request should be sent to the above address. Ecology will hold a hearing if it determines that there is significant public interest. If a hearing is to be held, public notice will be published at least 30 days in advance of the hearing date. Any party responding to this notice with comments will be mailed a copy of a hearing public notice. If you require special accommodations or need this document in a format for the visually impaired, call Cindy Huwe at 509-457-7105. Persons with hearing loss can call 711 for Washington Relay Service. Persons with a speech disability can call 877-833-6341. Publication dates of this Notice are February 27, and March 5, 2012. Ecology has published a document entitled Frequently Asked Questions about Effective Public Commenting, which is available on our website at http://www.ecy.wa.gov/biblio/0307023.html. You may obtain further information from Ecology by telephone, 509.457.7105, or by writing to the address listed below.

Water Quality Permit Coordinator Department of Ecology Central Regional Office 15 West Yakima Avenue, Suite 200 Yakima, WA 98902

The primary author of this permit and fact sheet is Richard Marcley.

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Appendix B --Your Right to Appeal You have a right to appeal this permit to the Pollution Control Hearing Board (PCHB) within 30 days of the date of receipt of the final permit. The appeal process is governed by chapter 43.21B RCW and chapter 371-08 WAC. “Date of receipt” is defined in RCW 43.21B.001(2) (see glossary). To appeal you must do the following within 30 days of the date of receipt of this permit: • File your appeal and a copy of this permit with the PCHB (see addresses below). Filing

means actual receipt by the PCHB during regular business hours. • Serve a copy of your appeal and this permit on Ecology in paper form - by mail or in person.

(See addresses below.) E-mail is not accepted. You must also comply with other applicable requirements in chapter 43.21B RCW and chapter 371-08 WAC. ADDRESS AND LOCATION INFORMATION Street Addresses Mailing Addresses

Department of Ecology Attn: Appeals Processing Desk 300 Desmond Drive SE Lacey, WA 98503

Department of Ecology Attn: Appeals Processing Desk PO Box 47608 Olympia, WA 98504-7608

Pollution Control Hearings Board 1111 Israel RD SW STE 301 Tumwater, WA 98501

Pollution Control Hearings Board PO Box 40903 Olympia, WA 98504-0903

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Appendix C—Technical Calculations

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DISCHARGE MONITORING DATA 2/1/2007 - 9/1/2011

GroundParameter Ammonia BOD, Soluble BOD Chloride Chloride Conductivity Conductivity Units mg/L mg/L mg/L mg/L mg/L UMhos/Cm UMhos/CmStatistical Base MAX MAX MAX AVG MAX AVG MAX

Limits - / - - / - - / - - / - - / - - / - - / -2/1/2007 C C C C C C C3/1/2007 C C C C C C C4/1/2007 C C C C C C C5/1/2007 <.07 <5 <5 28.8 40.6 1400 14016/1/2007 12.3 2220 2500 382.38 724 1268.4 14227/1/2007 7.17 1520 22.5 42.15 54.2 1428.5 14448/1/2007 2.15 4940 114000 58.72 141 1582 17849/1/2007 1.23 2280 3690 46.18 85.9 1381.1 1706

10/1/2007 5.36 2980 4710 68.22 96.6 1482 169311/1/2007 C C C C C C C12/1/2007 C C C C C C C

1/1/2008 C C C C C C C2/1/2008 C C C C C C C3/1/2008 C C C C C C C4/1/2008 C C C C C C C5/1/2008 0.385 <5 1.95 20.33 26.9 1432.76 14516/1/2008 9.56 1980 2600 575 994 1136 14417/1/2008 9.93 18.9 4230 85 326 1286 14428/1/2008 4.11 6600 8700 34.9 54.1 1604 17969/1/2008 9.93 18.9 4230 78.9 126 1557 1837

10/1/2008 3.7 6680 8960 73 101 1428 150111/1/2008 2.53 1830 2400 63.8 84.8 640 150112/1/2008 C C C C C C C

1/1/2009 C C C C C C C2/1/2009 C C C C C C C3/1/2009 C C C C C C C4/1/2009 C C C C C C C5/1/2009 0.22 <5 <5.4 12.1 13.3 1430 14386/1/2009 13 3060 3480 279.78 1010 1414 14257/1/2009 2.6 1830 2190 46.02 108 1428 14398/1/2009 3.25 8280 11700 99.2 146 1484 15219/1/2009 2.83 13400 13400 81.74 142 1471 1481

10/1/2009 4.13 2250 2900 53.03 61.6 1472 148511/1/2009 C C C C C C C12/1/2009 C C C C C C C

1/1/2010 C C C C C C C2/1/2010 C C C C C C3/1/2010 C C C C C C C4/1/2010 0.07 <5 <5 24.8 24.8 1485 14855/1/2010 0.55 3.08 7.65 22.3 26.6 1452 14706/1/2010 2.29 413.44 482.44 252.04 1080 1449 14707/1/2010 0.57 43 70.9 34.78 58 1447 14628/1/2010 0.25 5.4 8.4 12.75 19.2 1456 14729/1/2010 12 5160 8400 225.66 899 1454 1481

10/1/2010 4.1 2160 3850 57.95 88.6 1456 14715/1/2011 0.08 25.2 30 45.9 73.4 1453 14756/1/2011 0.2 10.48 19.36 68.9 142 1458 14817/1/2011 8.85 1920 2460 162.4 580 1453 14818/1/2011 0.3 55 118 27.4 64 1469 14829/1/2011 3.51 4410 7410 137.5 184 1460 1485

Min 0.07 3.08 1.95 12.10 13.30 640.00 1401.00Max 13.00 13400.00 114000.00 575.00 1080.00 1604.00 1837.00Avg 4.24 2744.20 7591.83 103.28 244.37 1413.44 1513.65Median 2.83 3.83 4.83 5.83 6.83 7.83 8.8395th % 12.17 7800.00 12805.00 331.08 1002.00 1569.50 1790.00

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Addendum to the Fact Sheet For State Waste Discharge Permit No. ST0005507 Page 13 of 20 User Contract between Twin City Foods Inc. and the City of Ellensburg

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Appendix D--Response to Comments Ecology Comment: During the permit issuance process Twin City Foods –Ellensburg (TCF) and the City of Ellensburg negotiated a new user contract. Ecology Response: The new contract is presented at the end of the appendix. The requirement for TCF to submit a new contract to Ecology is removed from the permit. Ecology Comment: Permit Condition S1. C. Municipal Sewer System Discharges third paragraph reads “The performance based limits below are codified by contract between the City of Ellensburg and Twin City Foods that will expire in December 31, 2016. The elements of the new industrial user contract must conform to special condition S4.A.b10 of this permit.” Ecology Comment: The performance based limits are not codified by the user contract. The performance based limits are limits agreed upon by Ecology, the City of Ellensburg, and TCF. These limits reflect a discharge warranting action by Ecology to investigate the reason for non-typical performance at TCF. The industrial user contract limits but allows TCF to purchase addition capacity, if available. Additionally, the performance-based average monthly limit for TSS is below the industrial user contract. The calculated limit should be raised to reflect the industrial user contract limit of an average monthly limit of 250 TSS mg/L. The maximum daily limit should remain the same. Ecology Response: The permit has been changed to read “The performance-based limits are contained in the table below”. The average monthly TSS limit is adjusted up to an average monthly limit of 250 mg TSS/L. Ecology Comment: Please insert the following language in the S1.A, after paragraph 4 of the permit ST0005507, “The Permittee will submit engineering report, and plans and specifications to construct a lined

Addendum to the Fact Sheet For State Waste Discharge Permit No. ST0005507 Page 16 of 20 treatment and storage lagoon as referenced in Permit Section S7. The Permittee will construct the lagoon by February 1, 2014.” Thank you, Sanjay Barik Technical Unit Manager Water Quality Program Washington State Department of Ecology 15 W Yakima Avenue, Ste 200, Yakima, WA 98902 Phone: 509 454 4247 Fax: 509 575 2809 Ecology Response: The additional language suggested in the comment will be added to the permit.

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