States
Enforcement and
ERA310-B-99-001
..Compliance Assurance
May 1999
TrttBL/Zwwwepa.gov/oeca
ilo Mill Compliance
CWA, RCRA and
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-------
EPA/310-B-99-001
Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
United States Environmental Protection Agency
Office of Enforcement and Compliance Assurance
Office of Compliance
Manufacturing, Energy and Transportation Division
May 1999
-------
ACKNOWLEDGEMENTS
This document has been prepared under the direction of Mr. Seth Heminway, in
EPA's Office of Compliance, with reviews by EPA Headquarters and Regional Office
representatives, by State agencies, and by the American Forest and Paper Association.
These reviews provided valuable comments, many of which have been incorporated into
this final document. This document was prepared by Eastern Research Group, Inc. and its
subcontractor, Perrin Quarles Associates, Inc., under EPA Contract No. 68-C5-0013.
-------
DISCLAIMER
The statements in this document are intended solely as guidance. The document is
not intended, nor can it be relied on, to create any rights enforceable by any party in
litigation with the United States. EPA and State and local officials may decide to follow
the guidance in this document, or to act at variance with the guidance. The guidance may
be revised without public notice to reflect changes in EPA's policy.
Mention of trade names, commercial products, or organizations in this document or
associated references does not imply endorsement by the U.S. Government or a
recommendation for use.
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
Table of Contents
Page
LIST OF ACRONYMS xi
INTRODUCTION xvii
SECTION 1: OVERVIEW 1-1
1.1 Regulatory Programs Covered 1-1
1.2 Multi-media Components 1-1
1.3 Process-based Approach 1-2
1.4 Pollution Prevention Issues 1-2
1.5 Scope Limitations 1-2
1.6 Sector Information Resources 1-3
SECTION 2: ASSESSMENT OBJECTIVES AND TYPES 2-1
2.1 Objectives 2-1
2.2 Available Techniques 2-1
2.3 Air Inspections 2-3
2.4 Water Inspections 2-6
2.5 Hazardous Waste Inspections 2-7
2.6 Multi-media Inspections 2-9
2.7 Summary 2-10
SECTION 3: GENERAL INSPECTION STEPS 3-1
3.1 Planning the Inspection 3-1
3.2 Conducting the Inspection 3-4
3.3 Inspection Follow-up 3-8
SECTION 4: ASSESSMENT MODULE FOR KRAFT PULPING OPERATIONS .. 4-1
4.1 Introduction 4-1
4.2 Overview of Process and Discharges 4-1
4.2.1 Description of the Process 4-1
4.2.2 Air Pollutant Emissions 4-5
4.2.3 Water Pollutant Discharges 4-6
4.2.4 Solid/Hazardous Waste Releases 4-7
4.2.5 EPCRA Chemicals and Reportable Releases 4-7
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page i
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
Table of Contents (cont.)
Page
4.3 LVHC Gas Collection System 4-8
4.3.1 LVHC Emission Points 4-8
4.3.2 LVHC Air Regulations 4-10
4.3.2.1 TRS Requirements 4-10
4.3.2.2 Cluster Rules Requirements 4-13
4.3.3 LVHC Air Inspection Techniques 4-18
4.3.3.1 Pre-inspection Steps 4-18
4.3.3.2 On-site Inspection Steps 4-19
4.3.4 LVHC EPCRA Issues 4-25
4.4 HVLC Gas Collection System 4-27
4.4.1 HVLC Emission Points 4-27
4.4.2 HVLC Air Regulations 4-29
4.4.2.1 TRS Requirements 4-29
4.4.2.2 Cluster Rules Requirements 4-30
4.4.3 HVLC Air Inspection Techniques 4-33
4.4.4 HVLC EPCRA Issues 4-34
4.5 Condensates 4-34
4.5.1 Condensate Discharge Points 4-34
4.5.2 Condensate Air Regulations 4-35
4.5.3 Condensate Air Inspection Techniques 4-39
4.5.3.1 Pre-inspection Steps 4-40
4.5.3.2 On-site Inspection Steps 4-41
4.5.4 Condensate RCRA and EPCRA Issues 4-45
— eBA This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page ii
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
Table of Contents (cont.)
Page
4.6 Spent Pulping Liquor, Turpentine, and Soap Management 4-46
4.6.1 Potential Spent Pulping Liquor, Turpentine, and Soap
Management Discharge Points 4-46
4.6.2 Spent Pulping Liquor, Turpentine, and Soap
Management — CWA Requirements 4-48
4.6.3 Spent Pulping Liquor, Turpentine, and Soap
Management — CWA Inspection Techniques 4-49
4.6.3.1 Pre-inspection Steps 4-49
4.6.3.2 On-site Inspection Steps 4-51
4.6.3.3 Root Cause Assessments 4-54
4.6.4 Spent Pulping Liquor, Turpentine and Soap
Management - RCRA Issues 4-55
4.6.5 Spent Pulping Liquor, Turpentine and Soap
Management - EPCRA Issues 4-56
SECTION 5: ASSESSMENT MODULE FOR CHEMICAL RECOVERY
OPERATIONS 5-1
5.1 Introduction 5-1
5.2 Overview of Process and Discharges 5-1
5.2.1 Description of the Process 5-1
5.2.2 Air Pollutant Emissions 5-3
5.2.3 Water Pollutant Discharges 5-4
5.2.4 Solid/Hazardous Waste Discharges 5-4
5.2.5 EPCRA Chemicals and Reportable Releases 5-5
5.3 Recovery Furnaces, Smelt Dissolving Tanks and Lime Kilns 5-6
5.3.1 Air Emission Points 5-6
5.3.2 Applicable Air Regulations 5-7
5.3.2.1 Non-HAP Requirements 5-7
5.3.2.2 Proposed MACT Rule Requirements 5-11
5.3.2.3 Asbestos NESHAP Requirements 5-12
— eBA This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page iii
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
Table of Contents (cont.)
Page
5.3.3 Air Inspection Techniques 5-12
5.3.3.1 Pre-inspection Steps 5-12
5.3.3.2 On-site Inspection Steps 5-14
5.3.4 EPCRA Issues 5-23
5.4 Other Miscellaneous Equipment Systems 5-24
5.4.1 Emission/Discharge Points 5-25
5.4.2 Applicable Air Regulations and Inspection Techniques 5-25
5.4.3 Applicable Water Regulations and Inspection Techniques 5-26
5.4.4 Applicable RCRA/EPCRA Regulatory Issues and Inspection
Techniques 5-27
SECTION 6: ASSESSMENT MODULE FOR BLEACHING PROCESS
OPERATIONS 6-1
6.1 Introduction 6-1
6.2 Overview of Process and Discharges 6-1
6.2.1 Description of the Process 6-1
6.2.2 Air Pollutant Emissions 6-5
6.2.3 Water Pollutant Discharges 6-6
6.2.4 Solid/Hazardous Waste Discharges 6-7
6.2.5 EPCRA Chemicals and Reportable Releases 6-7
6.3 Air Regulations and Inspection Techniques 6-7
6.3.1 Emission Points 6-7
6.3.2 Applicable Regulations 6-8
6.3.2.1 State HAP Standards 6-8
6.3.2.2 Cluster Rules Standards 6-9
6.3.3 Air Inspection Techniques 6-14
6.3.3.1 Pre-inspection Steps 6-14
6.3.3.2 On-site Inspection Steps 6-15
— eBA This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page iv
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
Table of Contents (cont.)
Page
6.4 Water Regulations and Inspection Techniques 6-17
6.4.1 Discharge Points 6-17
6.4.2 Applicable Regulations 6-19
6.4.3 CWA Inspection Techniques 6-19
6.4.3.1 Record Reviews 6-20
6.4.3.2 Physical Inspection of the Bleach Plant
(Facility Site Review) 6-22
6.4.3.3 Flow Monitoring Evaluations 6-23
6.4.3 A Sampling Evaluations 6-23
6.4.3.5 Laboratory/QA Evaluations 6-25
6.5 EPCRA Issues and Inspection Considerations 6-25
SECTION 7: ASSESSMENT MODULE FOR THE WASTEWATER TREATMENT
PLANT 7-1
7.1 Introduction 7-1
7.2 Overview of Process and Discharges 7-1
7.2.1 Description of the Process 7-1
7.2.2 Air Pollutant Emissions 7-4
7.2.3 Water Pollutant Discharges 7-5
7.2.4 Solid/Hazardous Waste Discharges 7-7
7.2.5 EPCRA Chemicals and Reportable Releases 7-8
7.3 CWA Regulatory Requirements 7-8
7.3.1 Pollutants Regulated 7-11
7.3.2 Subcategorization 7-11
7.3.3 Compliance Monitoring Requirements and Locations 7-12
7.3.4 Production Definitions 7-12
7.3.5 Storm Water Permitting 7-14
7.4 CWA Inspection Techniques 7-17
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page v
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
Table of Contents (cont.)
Page
7.4.1 Record Reviews 7-18
7.4.2 Physical Inspection of Wastewater Treatment Plants
(Mill Site Review) 7-20
7.4.3 Flow Monitoring Evaluations 7-21
7.4.4 Sampling Evaluations 7-22
7.4.5 Laboratory/QA Evaluations 7-23
7.4.6 Special Considerations for Kraft Pulp Mill Wastewater
Treatment Plants 7-24
7.4.7 Storm Water Inspection Considerations 7-26
7.5 RCRA Issues 7-26
7.6 EPCRA Issues and Inspection Considerations 7-27
SECTIONS: ASSESSMENT MODULE FOR POWER BOILER OPERATIONS ..8-1
8.1 Introduction 8-1
8.2 Overview of Process and Discharges 8-1
8.2.1 Description of the Process 8-1
8.2.2 Air Pollutant Emissions 8-1
8.2.3 Water Pollutant Discharges 8-2
8.2.4 Solid/Hazardous Waste Discharges 8-2
8.2.5 EPCRA Chemicals and Reportable Releases 8-3
8.3 Air Issues and Inspection Techniques 8-3
8.3.1 Air Regulations 8-3
8.3.2 Inspection Techniques 8-10
8.3.2.1 Pre-inspection Steps 8-10
8.3.2.2 On-site Inspection Steps 8-12
8.4 Water Issues and Inspection Considerations 8-21
8.5 RCRA Issues and Inspection Considerations 8-26
8.6 EPCRA Issues and Inspection Considerations 8-27
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page vi
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
Table of Contents (cont.)
Page
SECTION 9: ASSESSMENT MODULE FOR WOOD YARD, PAPERMAKING,
AND OTHER OPERATIONS 9-1
9.1 Introduction 9-1
9.2 Overview of Processes and Discharges 9-1
9.2.1 Description of the Process 9-1
9.2.2 Air Pollutant Emissions 9-4
9.2.3 Water Pollutant Discharges 9-5
9.2.4 Solid/Hazardous Waste Discharges 9-6
9.2.5 EPCRA Chemicals and Reportable Releases 9-6
9.3 Air Issues and Inspection Considerations 9-7
9.4 CWA Requirements and Inspection Considerations 9-9
9.4.1 NPDES Permit Review and Physical Inspection of
the Woodyard 9-9
9.4.2 Storm Water Requirements 9-10
9.4.3 Storm Water Inspection Considerations 9-13
9.5 RCRA Issues and Inspection Considerations 9-14
9.6 EPCRA Issues and Inspection Considerations 9-15
APPENDIX A: CLEAN AIR ACT REGULATORY SUMMARY A-l
APPENDIX B: CLEAN WATER ACT REGULATORY SUMMARY B-l
APPENDIX C: RCRA REGULATORY AND ASSESSMENT PROCEDURES
OVERVIEW C-l
APPENDIX D: EPCRA REGULATORY AND ASSESSMENT PROCEDURES
OVERVIEW D-l
APPENDIX E: EXAMPLE ASSESSMENT FORMS E-l
— eBA This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page vii
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
List of Figures
Page
Figure 1-1: Information Resources Map 1-3
Figure 1-2: Website Addresses for State Agency/Regulatory Information 1-6
Figure 2-1: Air Compliance Inspection Types 2-3
Figure 2-2: Baseline Inspection Concepts 2-5
Figure 2-3: NPDES Inspection Types 2-6
Figure 2-4: RCRA Inspection Types 2-8
Figure 3-1: Pre-Assessment Coordination 3-2
Figure 3-2: Pre-Assessment Records Review 3-3
Figure 3-3: Inspection Plan 3-4
Figure 3-4: Opening Conference Topics 3-5
Figure 3-5: Compliance Assistance Activities 3-6
Figure 3-6: Documentation of Findings 3-7
Figure 4-1: Flow Diagram of Typical Kraft Pulping Systems 4-2
Figure 4-2: Typical Air Emissions from the Pulping Processes at a 1000 Ton
Per Day Kraft Mill 4-6
Figure 4-3: Flow Diagram of LVHC System 4-9
Figure 4-4: LVHC Emissions: TRS Federal and State Emission Limits 4-11
Figure 4-5: NSPS TRS Monitoring, Reporting and Recordkeeping
Requirements for LVHC Units 4-12
Figure 4-6: MACT Control Options for LVHC System (40 CFR 63.443) 4-14
Figure 4-7: LVHC MACT Monitoring and Recordkeeping Requirements 4-15
Figure 4-8: MACT Closed-vent System Requirements (40 CFR 63.450) 4-16
Figure 4-9: Enclosures and Closed-vent System MACT Monitoring and
Recordkeeping Requirements 4-16
Figure 4-10: Common Causes of Downtime in Lime Kilns and Power Boilers 4-17
Figure 4-11: Potential Upsets and Malfunctions in the Digester Relief
and Turpentine Recovery System 4-23
Figure 4-12: Potential Upsets and Malfunctions in the Blow Tank
and Accumulator 4-24
Figure 4-13: Potential Upsets and Malfunctions in Multiple Effect Evaporators ... 4-24
Figure 4-14: Potential Upsets and Malfunctions in the Closed-Vent Gas
Collection System 4-25
Figure 4-15: Flow Diagram of HVLC System 4-28
Figure 4-16: HVLC Emission Points: Federal and State TRS Emission Limits .... 4-29
Figure 4-17: HVLC Emission Points that are Subject to the MACT Standard 4-31
Figure 5-1: Flow Diagram of Kraft Chemical Recovery Area 5-2
Figure 5-2: Typical Air Emissions from the Chemical Recovery Processes
at a 1000 Ton Per Day Kraft Mill 5-4
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page viii
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
List of Figures (cont.)
Page
Figure 5-3: Federal and State Emission Limits for Recovery Furnaces,
Smelt Dissolving Tanks, and Lime Kilns 5-9
Figure 5-4: NSPS Monitoring, Reporting and Recordkeeping Requirements
for Recovery Furnaces, Smelt Dissolving Tanks and Lime Kilns 5-11
Figure 5-5: Asbestos Demolition and Renovation (D&R) Requirements
(40 CFR Part 61, Subpart M) 5-13
Figure 5-6: BLO Malfunctions and Associated Effects 5-16
Figure 5-7: ESP Level 2 Follow-up Inspection Points and Techniques 5-18
Figure 5-8: Indicators and Possible Causes of Suboptimal Scrubber
Performance 5-20
Figure 5-9: Recovery Furnace O&M Practices Affecting Uncontrolled
Emissions 5-21
Figure 5-10: Primary Lime Kiln O&M Practices Affecting Uncontrolled Emissions . 5-22
Figure 6-1: Diagram of Example Bleaching System 6-2
Figure 6-2: Bleaching Stage Abbreviations and Bleaching Sequences 6-5
Figure 6-3: Typical Air Emissions from the Bleaching System at a 1000 Ton
Per Day Kraft Mill 6-6
Figure 6-4: Summary of Maine Bleach Plant Regulations 6-8
Figure 6-5: Control Options for Bleaching System Emission Limits 6-9
Figure 6-6: MACT Monitoring, Reporting, and Recordkeeping Requirements
for Bleaching Systems Chlorinated HAP Emission Limit 6-12
Figure 6-7: Enclosures and Closed-vent System MACT Monitoring and
Recordkeeping Requirements 6-13
Figure 6-8: MACT Monitoring, Reporting, and Recordkeeping Requirements
for Bleaching Systems Chloroform Emission Limit 6-13
Figure 6-9: MACT Monitoring, Reporting, and Recordkeeping
Requirements for Mills in the Voluntary Advanced Technology
Incentives Program 6-14
Figure 6-10: Bleach Plant Sewer Stream Configurations 6-18
Figure 6-11: Pollutant Monitoring Frequencies for Bleach Plants 6-20
Figure 6-12: Conditions that May Lead to Problems in Compliance with Bleach
Plan Effluent Limitations 6-22
Figure 6-13: Recommended Bleach Plant Effluent Sampling Evaluation
Collection Procedures 6-24
Figure 6-14: Test Method for Each Pollutant Limited in Bleach Plant Effluent .... 6-25
Figure 7-1: Diagram of Wastewater Treatment Plant Major Equipment Systems . . . 7-2
Figure 7-2: Wastewater Regulations for Existing Kraft Pulp Mills 7-10
Figure 7-3: Monitoring Requirements 7-13
Figure 7-4: General Storm Water BMPs for Treatment Works 7-15
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page ix
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
List of Figures (cont.)
Page
Figure 7-5: Potential Sources of Pollution and General Storm Water BMPs
for Landfills 7-16
Figure 7-6: Stormwater Monitoring Requirements for Landfill/Land
Application Sites 7-17
Figure 7-7: Sampling Procedures for BOD5, TSS, pH and AOX 7-23
Figure 7-8: Analytical Methods 7-24
Figure 7-9: Summary of Permit Specifications for Non-Continuous Dischargers .. 7-25
Figure 8-1: Particulate Matter, Sulfur Dioxide and Nitrogen Oxides Requirements
for Fossil Fuel Fired Steam Generators (NSPS Subpart D) 8-4
Figure 8-2: Particulate Matter Requirements for Industrial-Commercial-
Institutional Steam Generating Units (NSPS Subpart Db) 8-4
Figure 8-3: Sulfur Dioxide Requirements for Industrial-Commercial-Institutional
Steam Generating Units (NSPS Subpart Db) 8-5
Figure 8-4: Nitrogen Oxides Requirements for Industrial-Commercial-Institutional
Steam Generating Units (NSPS Subpart Db) 8-6
Figure 8-5: Particulate Matter Requirements for Small Industrial-Commercial -
Institutional Steam Generating Units (NSPS Subpart DC) 8-7
Figure 8-6: Sulfur Dioxide Requirements for Small Industrial-Commercial-
Institutional Steam Generating Units (NSPS Subpart DC) 8-8
Figure 8-7: Sulfur Dioxide and Nitrogen Oxides Requirements for Gas-fired
Turbines (NSPS Subpart GG) 8-9
Figure 8-8: Asbestos Demolition and Renovation (D&R) Requirements
(NESHAP 40 CFR Part 61, Subpart M) 8-10
Figure 8-9: Fabric Filters: External Level 2 Inspection Parameters 8-15
Figure 8-10: Fabric Filters: Follow-up Level 2 Inspection Parameters 8-16
Figure 8-11: Power Boiler O&M: Key Level 2 Inspection Parameters 8-18
Figure 8-12: Measures and Controls for Inclusion in Steam Electric Power
Generating Facility SWPP Plan 8-23
Figure 9-1: Suggested BMPs for Paper and Allied Product Manufacturing
Facilities 9-11
Figure 9-2: Potential Sources of Pollution and General Storm Water BMPs
for Landfills 9-12
Figure 9-3: Monitoring Requirements for Paperboard Mills and Landfill/
Land Application Sites 9-13
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page x
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
List of Acronyms
Acronym
ACM
ADI
AIRS
AOX
ASTM
BACT
BAT
BCT
BLO
BPT
BMP
BOD5
CAA
CAM
CBI
CCA
CDI
CEI
CEMS
CERCLA
Term
Asbestos Containing Material
Applicability Determination Index
Aerometric Information Retrieval System
Adsorbable Organic Halides
American Society for Testing and Material
Best Available Control Technology
Best Available Technology Economically Achievable
Best Conventional Pollutant Control Technology
Black Liquor Oxidation
Best Practicable Control Technology Currently
Available
Best Management Practice
Biochemical Oxygen Demand
Clean Air Act
Compliance Assurance Monitoring
Confidential Business Information
Clean Condensate Alternative
Case Development Inspection
Compliance Evaluation Inspection
Continuous Emission Monitoring System
Comprehensive Environmental Response,
Compensation, and Liability Act
Regulatory Program
(Context)
CAA (hazardous material)
CAA (EPA database)
CAA (EPA database)
NPDES (pollutant)
N/A (test method source)
CAA (technology -based emission
limit)
NPDES (technology -based effluent
standard for toxic and non-
conventional pollutants)
NPDES (technology -based effluent
standard for conventional
pollutants)
N/A (TRS emissions control
method)
NPDES (technology -based effluent
standard for all pollutants)
N/A (regulatory work practice)
NPDES (pollutant)
CAA
CAA
N/A
CAA (pollution prevention-based-
regulatory -alternative)
RCRA (inspection type)
NPDES/RCRA (inspection type)
CAA
CERCLA
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page xi
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
List of Acronyms (cont.)
Acronym
CESQG
CFR
CME
CMS
COD
CSI
CWA
DCE
DCS
DI
DMR
DOT
D&R
ECF
EER
EPA
EPCRA
ERNS
ESP
FIP
FR
HAP
Term
Conditionally Exempt Small Quantity Generator
Code of Federal Regulations
Comprehensive Groundwater Monitoring Evaluation
Continuous Monitoring System
Chemical Oxygen Demand
Compliance Sampling Inspection
Clean Water Act
Direct Contact Evaporator
Distributed Control Systems
Diagnostic Inspection
Discharge Monitoring Report
Department of Transportation
Demolition and Renovation
Elemental Chlorine-free
Excess Emission Report
Environmental Protection Agency
Emergency Planning and Community Right-to-Know
Act
Emergency Response Notification System
Electrostatic Precipitator
Federal Implementation Plan
Federal Register
Hazardous Air Pollutant
Regulatory Program
(Context)
RCRA (category of hazardous
waste generating facility)
N/A
RCRA (inspection type)
CAA (Part 63 NEHSAP
monitoring system)
NPDES (pollutant)
NPDES/RCRA (inspection type)
CWA
N/A (kraft mill recovery furnace
type)
N/A (automated data handling
system)
NPDES (inspection type)
NPDES
N/A
CAA (asbestos-related term)
N/A (pulp bleaching term)
CAA
N/A
EPCRA
EPCRA (database of reported
spills)
N/A (particulate matter control
device)
CAA (plan for attaining NAAQS)
N/A
CAA
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page xii
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
List of Acronyms (cont.)
Acronym
HSWA
HVLC
IDEA
LAER
LDR
LEPC
LQG
LSI
LVHC
MACT
MEE
MLVSS
MRR
MSDS
MSGP
NAAQS
NCG
NDCE
NEIC
NESHAP
Term
Hazardous and Solid Waste Amendments
High Volume, Low Concentration
Integrated Data for Enforcement Analysis System
Lowest Achievable Emission Rate
Land Disposal Restrictions
Local Emergency Planning Committee
Large Quantity Generator
Legal Support Inspection
Low Volume, High Concentration
Maximum Available Control Technology
Multiple Effect Evaporator
Mixed Liquor Volatile Suspended Solids
Monitoring, Reporting, and Recordkeeping
Material Safety Data Sheet
Multi-sector General Permit
National Ambient Air Quality Standards
Noncondensible Gas Stream
Non-direct Contact Evaporator
National Enforcement Investigations Center
National Emission Standards for Hazardous Air
Pollutants
Regulatory Program
(Context)
RCRA
CAA (TRS emissions category)
N/A (EPA multimedia compliance
database)
CAA (technology -based emission
standard)
RCRA (hazardous waste
pretransportation requirements)
EPCRA
RCRA (category of hazardous
waste generating facility)
NPDES (inspection type)
CAA (TRS emissions category)
CAA (technology -based hazardous
air pollutants emission standard)
N/A (kraft mill recovery furnace
component)
CAA (biological treatment system
parameter)
N/A
EPCRA
NPDES (industrial storm water
permit type)
CAA (health-based standards for
criteria pollutants)
N/A
N/A (kraft mill recovery furnace
type)
N/A
CAA
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page xiii
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
List of Acronyms (cont.)
Acronym
NOX
NPDES
NRC
NSPS
NSR
OAQPS
OC
OOP
O&M
ORP
PAI
PCI
PCS
PERM
PM
POTW
PHA
PSD
PSES
PSNS
Term
Nitrogen Oxide
National Pollution Discharge Elimination System
National Response Center
New Source Performance Standards
New Source Review
Office of Air Quality Planning and Standards
Office of Compliance
Oven Dried Pulp
Operation and Maintenance
Oxidation Reduction Potential
Performance Audit Inspection
Pretreatment Compliance Inspection
Permit Compliance System
Program for Effective Residuals Management
Particulate Matter
Publicly Owned Treatment Works
Process Hazard Analysis
Prevention of Significant Deterioration
Performance Standards for Existing Sources
Pretreatment Standards for Existing Sources
Performance Standards for New Sources
Pretreatment Standards for New Sources
Regulatory Program
(Context)
CAA (pollutant)
NPDES (permitting program)
CERCLA (hazardous substance
release reporting center)
CAA and NPDES (technology-
based standards)
CAA (regulatory program)
N/A
N/A
N/A
N/A
CAA (bleach plant scrubber
monitoring parameter)
NPDES (inspection type)
NPDES (inspection type)
NPDES (EPA database)
NPDES (permit-specific
requirement)
CAA (pollutant)
NPDES
CAA (RMP element)
CAA (type of NSR permitting
program)
CAA (emission limits)
NPDES (technology-based
pretreatment standards))
NPDES (emission limits)
NPDES (technology-based
pretreatment standards)
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page xiv
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
List of Acronyms (cont.)
Acronym
QA/QC
RACM
RACT
RCRA
RCRIS
RI
RMP
RQ
SARA
SERC
SIP
SFIP
SFR
SPCC
SQG
SSM
SWPP
TADP
TCDD
TCDF
TCP
Term
Quality Assurance/Quality Control
Reportable Asbestos Containing Material
Reasonably Available Control Technology
Resource Conservation and Recovery Act
Resource Conservation and Recovery Information
System
Reconnaissance Inspection
Risk Management Plan
Reportable Quantity
Superfund Amendments Reauthorization Act
State Emergency Response Commission
State Implementation Plan
Sector Facility Indexing Project
Steam-to-Feed Ratio
Spill Prevention Control and Countermeasure
Small Quantity Generator
Startup, Shutdown or Malfunction
Storm Water Pollution Prevention
Tons of Air Dried Pulp
2,3,7, 8-tetrachlorodibenzo-p-dioxin
2,3,7, 8-tetrachlorodibenzo-p-fur an
Totally Chlorine Free
Regulatory Program
(Context)
N/A
CAA (hazardous material)
CAA (technology -based emission
limits)
RCRA
RCRA (EPA database)
NPDES (inspection type)
CAA (regulatory program)
CERCLA/EPCRA (reporting
threshold for hazardous/extremely
hazardous chemical releases)
EPCRA
EPCRA
CAA (plan for attaining NAAQS)
N/A
CAA (steam stripper monitoring
parameter)
NPDES (oil discharge
prevention/control plan)
RCRA (category of hazardous
waste generating facility)
N/A
NPDES (plan for control of storm
water discharges)
N/A (unit of measurement)
NPDES (pollutant)
NPDES (pollutant)
N/A (pulp bleaching method)
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Kraft Pulp Mill Compliance Assessment Guide
(CAA, CWA, RCRA and EPCRA)
List of Acronyms (cont.)
Acronym
TCLP
TMDL
TOC
T-R
TRI
TRS
TSD/TSDF
TSI
TSP
TSS
UST
VATIP
VEO
VOC
WBL
W.C.
WQBEL
Term
Toxicity Characteristics Leaching Procedure
Total Maximum Daily Load
Total Organic Carbon
Transformer-rectifier
Toxic Release Inventory
Total Reduced Sulfur
Treatment, Storage or Disposal/Treatment, Storage or
Disposal Facility
Toxics Sampling Inspection
Total Suspended Particulates
Total Suspended Solids
Underground Storage Tank
Voluntary Advanced Incentives Program
Visible Emission Observation
Volatile Organic Compound
Weak Black Liquor
Water in Column
Water Quality -based Effluent Limits
Regulatory Program
(Context)
RCRA (method for determining
hazardous waste characteristic)
NPDES (method of quantifying
allowable pollutant loadings)
NPDES (pollutant)
CAA (electrostatic precipitator
component)
EPCRA
CAA (pollutant)
RCRA (hazardous waste facility
type)
NPDES (inspection type)
CAA (pollutant)
NPDES (pollutant)
RCRA
CWA (Cluster Rules pollution
prevention program)
CAA (opacity inspection
technique)
CAA/NPDES (pollutant)
N/A (pulping process chemical)
N/A (unit of measurement for air
pressure)
NPDES
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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INTRODUCTION
The Office of Compliance (OC) of the U.S. Environmental Protection Agency
(EPA) was created in 1994 as a multi-media office organized around various industry
sectors. Among other responsibilities, OC is charged with assisting State, local and federal
agency personnel carry out their compliance oversight functions, as well as with providing
compliance assistance to the regulated industry. To help accomplish its mission, OC
developed a series of 18 profiles on various industry sectors (as defined by two digit
Standard Industrial Classification (SIC) codes). Each profile (or sector notebook) provides
an overview of the types of production processes within a sector, the associated
environmental discharges, and the types of compliance requirements that apply generally to
facilities within each sector. The EPA published the Profile of the Pulp and Paper
Industry in September 1995.
Building upon this initial effort, this manual has been developed to assist both
agency and plant personnel in conducting compliance assessments of kraft pulp mill
facilities. The Office of Compliance has selected this type of facility for several reasons.
First, the pulp and paper industry sector ranks as one of the most heavily inspected industry
sectors by State and EPA inspectors. Second, within the pulp and paper sector, the kraft
process represents the single largest portion of the pulp production in the U.S.
(approximately 80%). Third, the pulp and paper sector has recently become subject to new
requirements under a combined air and water pollution regulation commonly referred to as
the "Cluster Rules." The Cluster Rules were promulgated at 63 FR 18504, April 15, 1998.
Since then, EPA has released clarifications and technical amendments (see 63 FR 42238,
August 7, 1998; 63 FR 49455, September 16, 1998; 63 FR 71385, December 28, 1998;
and 64 FR 17555, April 12, 1999). If the Agency releases any further amendments to the
Cluster Rules, EPA will post information on the amendments on the EPA website (see
page 1-4 of this manual for specific website addresses for Cluster Rules information).
Although this document includes summaries of various regulatory provisions and
requirements, it does not change existing regulations and should not be interpreted to affect
in any manner the responsibilities of affected regulated sources to comply with applicable
statutes and regulations. It is intended only to outline regulatory requirements that apply
to kraft pulp mills and suggest various techniques of assessing compliance with those
requirements. It is not a substitute for regulations published by EPA in the Code of
Federal Regulations (CFR), any regulations promulgated by State and local governments,
or any specific permit requirements.
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SECTION 1: OVERVIEW
1.1 Regulatory Programs Covered
This manual assists agency and industry personnel in conducting assessments of
compliance at kraft pulp mills with environmental requirements developed under the
following federal statutes: the Clean Air Act (CAA), Clean Water Act (CWA), and
Resource Conservation and Recovery Act (RCRA). The manual also briefly covers
reporting and notification requirements under the Emergency Planning and Community
Right-to-Know Act (EPCRA) and section 103 of the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) (a parallel reporting section to
EPCRA section 304). Although individual State requirements are not evaluated or
outlined in detail, the manual does present general information on the types of State
requirements that may apply under regulations or in specific permits.
1.2 Multi-media Components
As noted above, the manual addresses multiple pollutant media. Because many
agency inspection programs are not organized in a multi-media fashion, the manual is
formatted to allow for multi-media or single media inspections. Consistent with existing
EPA guidance, the manual suggests specific opportunities for conducting multi-media
screening efforts as part of a single media inspection. In particular, the manual highlights
various opportunities for screening inspections involving hazardous waste concerns under
RCRA, and reporting and notification requirements under EPCRA/CERCLA. The Profile
of the Pulp and Paper Industry indicates that 10 percent or less of agency inspections of
pulp mills are RCRA-oriented inspections. For most other major industries, the level of
RCRA inspections ranges from 35-60 percent of total inspections.1 This relatively low
level of inspections in part reflects that most kraft pulp mills are subject to RCRA only as
generators of hazardous waste because they do not operate RCRA-regulated treatment,
storage or disposal (TSD) facilities. In fact, some large kraft mills may qualify as small
quantity generators of hazardous waste. Because of this status, there is an increased value
in conducting screening inspections by other media inspectors. Similarly,
EPCRA/CERCLA requirements present a multi-media opportunity where the resources to
conduct a media-specific inspection by an agency are limited.
Based on generally applicable multi-media screening checklists developed by EPA,2
this manual develops some specific multi-media assessment techniques appropriate for
RCRA and EPCRA/CERCLA assessments at kraft pulp mills. However, this manual is not
intended to establish a presumption or requirement that State and local agency inspectors
must conduct multi-media screening inspections.
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Section 1 Overview
1.3 Process-based Approach
This manual focuses on the individual processes at a kraft mill. For each process,
the manual describes the:
! Basic production cycle,
! Emissions effluents and other discharges that are generated,
! Regulations that limit and require monitoring of those various discharges, and
! Procedures for how to evaluate the process and controls in order to evaluate
compliance with those regulations.
The manual breaks the typical kraft mill down into the following processes:
(1) pulping operations; (2) chemical recovery; (3) bleach plant operations; (4) wastewater
treatment operations; (5) power facilities; and (6) woodyard, papermaking, and other
general mill operations. Special operations that may occur at kraft pulp mills, such as
hazardous waste cleanup efforts, are not covered by this manual. Also, because most kraft
mills are direct water dischargers, the discussion of water discharge issues in this manual
focuses on mills with direct discharge National Pollution Discharge Elimination System
(NPDES) permits rather than mills that are indirect dischargers to a publicly owned
treatment works (POTW). However, indirect discharger requirements are discussed where
appropriate.
1.4 Pollution Prevention Issues
There are circumstances in which the likelihood that a process may cause
compliance problems will decrease based on various process and design characteristics.
For instance, total reduced sulfur (TRS) emissions from a recovery boiler may be more of a
concern where a source relies on a direct contact evaporator process as opposed to a non-
direct contact evaporator process. In attempting to prioritize limited agency inspection
resources, an agency inspector may want to consider these types of process issues in
defining the scope and depth of inspections of various processes at a plant. The EPA
notes, however, that this manual is not intended to serve as a guide to conducting pollution
prevention opportunity assessments or as a resource on pollution prevention measures in
the pulp and paper sector. The EPA has developed such materials in the past specifically
for the pulp and paper sector (see the Sector Information Resources section below for
relevant materials). Pollution prevention measures are discussed in this manual as relevant
to conducting inspections under the various media.
1.5 Scope Limitations
This manual does not focus on features of certain procedures and issues associated
with conducting compliance inspections. First, safety considerations and precautions are of
paramount importance in conducting assessments of any facility, including kraft pulp mills.
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Overview
Section 1
The basic inspection manuals for the air, water and waste programs (see the References for
Section 2) cover these concerns in detail, and those or similar materials should be reviewed
by anyone that may be considering conducting an on-site compliance assessment. Other
general features of agency inspections are not covered in detail in this manual but are
covered in the general media-specific manuals. These include topics such as: obtaining the
right to enter onto a facility or obtaining a warrant if entry is refused; and specific
documentation procedures for supporting enforcement proceedings. Although these issues
are important concerns for an agency inspector, they are addressed at length in basic
inspection technique guidance materials. An agency inspector should consult those other
sources for a discussion of these topics.
1.6 Sector Information Resources
This manual is one element in a broad spectrum of materials that are available
related to environmental compliance and compliance assessment at kraft pulp mills. The
following Figure 1-1 illustrates some of the information currently available, as well as other
information resources the agency plans to develop in connection with the Cluster Rules.
Following Figure 1-1, the manual provides a summary of each resource and how to obtain
the resource or more information on the resource.
General Information
Figure 1-1
Information Resources Map
Profile of the Pulp and Paper Industry
Cluster Rules Supporting Documents
Spent Pulping Liquor BMP Support Document
Handbook for Pulp and Paper Technologists
Regulatory Information
Cluster Rules Enabling Documents
EPA Internet Homepage
State Regulatory Websites
Applicability Determination Index
Inspection Manuals
Baseline Inspection Techniques
ESP O&M Manual
Air Compliance Inspection Manual
1983 Kraft Pulp Mill Inspection Guide
NPDES Compliance Inspection Manual
Revised RCRA Inspection Manual
Program Audit Protocols
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Section 1
Overview
Figure 1-1 (cont.)
Information Resources Map
Compliance/Emissions
Data
! SFIP
! AIRS
! RCRIS
! Envirofacts
! IDEA
! PCS
! TRI Data
! ERNS
Pollution Prevention
Pollution Prevention Technologies for Bleached Kraft
Mills (1993)
Model Pollution Prevention Plan for Kraft Pulp
Mills (1992)
Simpson Tacoma Pollution Prevention Plan (1992)
Industry Websites
! Profile of the Pulp and Paper Industry. The EPA Office of Compliance
developed this document (EPA/310-R-95-015) in 1995 as part of EPA's sector
notebook project. This notebook provides a sector-based profile of air, water, and
land pollution regulations for the pulp and paper industry. The notebook reflects
EPA's desire to move toward comprehensive sector-based compliance programs for
all industrial sectors. The notebook includes a detailed discussion of pulp and
paper industrial processes, chemical profiles, and pollution prevention
opportunities; a summary of applicable federal statutes and regulations, compliance
history and initiatives; and resource lists. See http://www.epa.gov/oeca/sector.
\ Cluster Rules Supporting Documents. In support of the proposed and final
cluster rules, EPA developed technical support documents for both the water and
air issues involved in the rulemaking. These documents present the information and
rationale supporting the maximum available control technology (MACT) standards
and the effluent limitations guidelines and standards for the cluster rules. The
documents provide background information on industrial processes and regulatory
requirements; summarize data collection methods; provide a detailed overview of
air emission and wastewater characteristics, and the selection of pollutant
parameters; and discuss pollution prevention and control standards and
technologies, including cost estimates. See http://www.epa.gov/ost/pulppaperfor
water documents, and http://www.epa.gov/ttn/oarpg and
www.epa.gov/ttn/uatw/pulp/pulppg.htmlfor air documents. The preamble and
rules themselves are available electronically from the Government Printing Office
website, http://www.gpo.gov/su docs/aces/aces 140.html.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Overview Section 1
! Spent Pulping Liquor BMP Support Document. This 1997 document
(Technical Support Document for Best Management Practices for Spent Pulping
Liquor Management, Spill Prevention and Control (EP A-821 -R-97-011,10/97))
was prepared during the development of the final Cluster Rules and provides the
technical background for BMP programs applicable to spent pulping liquor
management, spill prevention, and control at pulp and paper facilities. The
document includes chapters discussing wood pulping processes and chemical
recovery systems; the composition, toxicity, and source of spent pulping liquor;
current industry pollution control practices; and BMP implementation, with
estimated costs and effluent reduction benefits. See
http://www.epa.gov/ost/rulesMfinal.
\ Handbook for Pulp & Paper Technologists (2d ed. 1992). This handbook,
written by pulp and paper expert G. A. Smook, provides technical information
relevant to pulp and paper processes, and includes information on the economic and
environmental benefits of various pollution minimization efforts. See
http://www.tappi.org for information on obtaining a copy of this handbook.
\ Cluster Rules Enabling Documents. The EPA is in the process of developing a
variety of documents to assist in the implementation of the Cluster Rules, including
the Pulp and Paper NESHAP: A Plain English Description (EPA-456/R-98-008,
11/98). Other documents being prepared include an NPDES permit writers guide
and a question and answer document on the NESHAP. These documents are
expected to be available through the EPA Internet Homepage
(http://www.epa.gov)., at the locations noted previously for the Cluster Rules
Supporting Documents.
! EPA Internet Homepage. The EPA Homepage (http://www.epa.gov) provides a
wealth of information relevant to environmental compliance issues and provides
links to other important website locations, such as the online version of the daily
Federal Register and the Enviro$en$e website (http://es.epa.gov), which includes
materials developed by EPA's Office of Enforcement and Compliance Assurance.
! State Regulatory Websites. Many States have made their regulations and other
relevant materials available on the Internet. Even if the regulations are not
available, the Internet websites generally provide appropriate contact information to
obtain regulatory updates. Figure 1-2 lists the website addresses for the relevant
States that either have kraft pulp mills or have promulgated specific kraft pulp mill
regulations. For links to various State regulatory resources on-line, see
http://www.paintcenter.org, a website resource developed by the National Center
for Manufacturing Sciences that was made possible by funding from EPA.
This manual is intended solely for guidance and May 1999
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Section 1
Overview
Figure 1-2
Website Addresses for State Agency/Regulatory Information
State/Local Agency
Alabama
California Districts (air and
water)
Florida
Georgia
Idaho
Kentucky
Maine
Maryland
Michigan
Mississippi
Montana
New Hampshire
North Carolina
Ohio
Oregon
Pennsylvania
South Carolina
Tennessee
Texas
Virginia
Washington
Wisconsin
Website Address
(http:// prefix unless noted)
www. adem. state, al.us
www. arb.ca. gov/homepage.htm,
www.swrcb.ca.gov
www.dep.state.fl.us
www. ganet. org/dnr
www2. state. id.us/adm/adminrules/index.
htm
www. state . ky . us/agencies/nrepc/dep/dep2 .
htm
www. state.me.us/dep
www.mde.state.md.us
www.deq.state.mi.us
www.deq.state.ms.us
www.deq.state.mt.us
www. state. nh.us/des
www.ehnr.state.nc.us/ehnr
www . ep a. ohio . gov
www.deq.state.or.us
www.dep.state.pa.us
www. state. sc.us/dhec/division2. htm
www. state. tn.us/environment
www.tnrcc.state.tx.us
www.deq.state.va.us
www.wa.gov/ecology
www.dnr.state.wi.us
Rules Available?
(as of 4/99)
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
No
Partial
Yes
Yes
Yes
No
No
Partial
Yes
Yes
Yes
Yes
! Applicability Determination Index (ADI). This database contains EPA
determinations related to the applicability of most federal air regulatory programs,
including NSPS and MACT determinations relevant to the kraft pulp mill sector.
See http :/Avww.epa.gov/oeca for electronic access and further details.
\ Baseline Inspection Techniques. This student manual (1996, 2d ed.) was
designed to be used as instructional material in EPA's Air Pollution Training
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Overview Section 1
Institute (APTI) Course 445, Baseline Inspection Techniques. The manual covers
use of baseline techniques in lieu of direct measurement to evaluate the
performance of air pollution control systems controlling various emission sources.
The manual contains chapters that provide recommended inspection procedures for
each of the major types of air pollution control devices and processes. See
http://www.epa.gov/airprogm/oar/oaqps/eog/obtain.htmlforfurther details on
obtaining APTI course materials.
\ ESP O&M Manual. This EPA manual (Operation and Maintenance Manual for
Electrostatic Precipitators (EPA/625/1-85/017)) summarizes available information
on ESP theory and design, discusses performance monitoring and the evaluation of
control system performance, summarizes methods and procedures for inspection of
ESP systems, presents guidelines for general O&M practices and procedures, and
outlines a model O&M plan. The manual is designed as an educational tool for
plant engineers, O&M personnel, and agency inspectors. Appendix B of the
manual addresses ESP applications for kraft recovery furnaces. Contact NTIS (1-
800-553-NTIS) to order a hardcopy version of this report.
\ Air Compliance Inspection Manual. This manual (EPA-340/1 -85-020) was
published by EPA's Office of Air Quality Planning and Standards in 1985 to support
inspectors in conducting field inspections necessary to promote stationary source
compliance with air quality standards. The manual provides standard inspection
procedures, with an emphasis on the evaluation of particulate emission sources, and
also provides a discussion of applicable regulations and inspector responsibilities
and liabilities. Contact NTIS ( 1-800-553-NTIS) to order a hardcopy version of this
report.
\ 1983 Kraft Pulp Mill Inspection Guide. This guide, published in 1983 by EPA's
Division of Stationary Source Enforcement (refer to Work Assignment No. 65,
Contract No. 68-01-6310), provides technical information and data to support
State and local inspectors in the evaluation of both new and existing kraft pulp
mills. The guide is divided into three substantive sections. Those sections outline
pre-inspection activities and necessary safety precautions; provide a detailed
discussion of six major processes or systems within kraft pulp mills (woodhandling,
pulping, chemical recovery, causticizing, power boilers, and other sources), noting
applicable inspection procedures; and provide compliance determination guidance.
Contact NTIS (1-800-553-NTIS) to order a copy of this report.
\ NPDES Compliance Inspection Manual. This 1994 EPA manual (EPA-300-B-
94-014) was developed to support wastewater inspection personnel in conducting
NPDES field inspections, and to provide standardized inspection procedures. The
manual encourages a consolidated inspection approach, and is organized in two
parts. The first part addresses basic inspection components, including technical
information on documentation, recordkeeping and reporting, sampling, and
This manual is intended solely for guidance and May 1999
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Section 1 Overview
laboratory procedures. The second part provides information on specific types of
inspections, concluding with a discussion of multi-media concerns. Contact NTIS
( 1-800-553-NTIS) to order a copy of this report.
\ Revised RCRA Inspection Manual. This 1993 manual (Order No. EPA
530R94007) was developed by the RCRA Enforcement Division for use by agency
inspectors. The manual describes the scope of inspector authorities and
responsibilities, provides a detailed overview of the elements of RCRA compliance
inspections (including checklists), establishes standard inspection procedures, and
presents essential regulatory information. The EPA has also developed additional
RCRA inspection training materials that can be accessed electronically. Contact
NTIS (l-800-553-NTIS)for a copy of the manual, and see
http://www.epa.gov/oeca/polguidfor other RCRA inspection materials.
\ Program Audit Protocols. The Office of Enforcement and Compliance Assurance
has developed audit protocols for some of the primary EPA regulatory programs,
including CERCLA, RCRA-Generators, and EPCRA. Protocols for the CAA and
CWA are scheduled for completion in December 1999. See
http://www.epa.gov/oeca/ccsmd/profile. html for further details.
\ Sector Facility Indexing Project (SFIP). The SFIP is a pilot data integration
effort initiated by EPA's Office of Enforcement and Compliance Assurance that
synthesizes environmental records from several compliance-related data sources
into a system that allows facility-level and sector analysis. The SFIP is currently a
pilot project covering five industry sectors, including the pulp mill sector. The
SFIP provides the public with better access to compliance-related information and
allows for sector-based analyses. See http://www.epa.gov/oecaforfurther details.
\ AIRS. The Aerometric Information Retrieval System (AIRS) is EPA's primary
national database for air quality, emissions, compliance, and enforcement
information. The AIRS Facility Subsystem (AFS) contains the emissions and
compliance data on regulated air pollution sources. Public access is available by
obtaining a mainframe account on EPA's National Computer Center. See
http://www. epa.gov/airsforfurther details.
\ RCRIS. The Resource Conservation and Recovery Information System (RCRIS)
contains information that identifies and locates entities that handle hazardous waste,
as well as providing compliance-related information. See
http://www. epa.gov/epaoswer/hazwaste/dataforfurther details.
\ Envirofacts. The Envirofacts Warehouse provides access to several EPA
databases (that would otherwise require a mainframe account to access), and also
provides tools for users to easily access the information in these databases. In
addition to Program data, Envirofacts includes spatial and demographic databases
This manual is intended solely for guidance and May 1999
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Overview Section 1
to enable geo-demographic analyses. See
http://www.epa.gov/enviro/html/ef overview.html for further details.
\ IDEA. The Integrated Data for Enforcement Analysis System (IDEA) is an
interactive data retrieval and integration system developed by EPA's Office of
Enforcement and Compliance Assurance. Users can retrieve data for performing
multimedia analyses of regulated facilities, produce compliance histories of
individual facilities, identify a group of facilities that meet user-defined criteria, and
produce aggregated data on selected industries. Public access is available by
obtaining a mainframe account on EPA's National Computer Center. See
http://www. epa.gov/oeca/ideaforfurther details.
\ PCS. The Permit Compliance System (PCS) is a national information system that
automates entry, updating, and retrieval of NPDES data, and tracks permit
issuance, permit limits, and monitoring data for NPDES facilities. Public access is
available by obtaining a mainframe account on EPA's National Computer Center.
See http://www.epa.gov/oeca/datasysforfurther details.
\ TRI Data. The Toxics Release Inventory (TRI) provides the public with
information on toxic chemicals being used, manufactured, transported, or released
into the environment. See http://www.epa.gov/opptintr/tri for access to numerous
TRI topics, including: "What is TRI," "Accessing and Using TRI Data," "Tri
Forms and Reporting Requirements," "TRI chemicals," "TRI Program
Development," "TRI National and International Programs," "TRI Contacts," and
"What's New with TRI." See http://www.epa.gov/opptintr/tri/ttpubacc.htm to
learn more about TRI information found on CD-ROM, the Right-to-Know Network
(RTKNET), Envirofacts, TOXNET (user fee), and TRI User Support (TRI-US).
\ ERNS. Through The Emergency Response Notification System, EPA maintains a
database of reported spills of oil and other materials. See
http://www. epa.gov/docs/ernsacctforfurther details.
\ Pollution Prevention Technologies for the Bleached Kraft Segment of the U.S.
Pulp and Paper Industry (1993). This report, published in 1993 by EPA's Office
of Pollution Prevention and Toxics (EPA/600/R-93/110), provides a detailed
description of pollution prevention techniques for kraft pulp and paper facilities.
Contact NTIS ( 1-800-553-NTIS) to order a hardcopy version of this report.
\ Model Pollution Prevention Plan for the Kraft Segment of the Pulp and Paper
Industry (1992). This document, a product of EPA's Industrial Pollution
Prevention Project (EPA 910/9-92-030), provides a model pollution prevention
plan for the kraft segment of the pulp and paper industry as a whole. The model
plan was developed after implementation of a specific plan for the Simpson Tacoma
Kraft Mill. Contact NTIS (1-800-5 5 3-NTIS) to order a hardcopy version of this
report.
This manual is intended solely for guidance and May 1999
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Section 1 Overview
! Simpson Tacoma Pollution Prevention Plan (1992). This report {Pollution
Prevention Opportunity Assessment and Implementation Plan for Simpson Tacoma
Kraft Company, Tacoma, Washington (EPA 910/9-92-027)) reflects a specific
pollution prevention opportunity assessment and voluntary implementation plan for
a single kraft pulp mill that was used as a model for developing other plans.
Contact NTIS ( 1-800-553-NTIS) to order a hardcopy version of this report.
\ Other Pulp & Paper Websites. The Technical Association of the Pulp and Paper
Industry maintains a website on the Internet (http://www.tappi.org) that provides
references to available pollution prevention materials as well as links to other
related websites, such as the sites maintained by the National Council of the Paper
Industry for Air and Stream Improvement (http://www.ncasi.org) and the American
Forest and Paper Association (http://www.afandpa.org).
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Overview Section 1
References:
1. Profile of the Pulp and Paper Industry (EPA/310-R-95-015), EPA Office of
Compliance Sector Notebook Project, U.S. Environmental Protection Agency,
September 1995.
2. Memorandum, S.A. Herman, Office of Enforcement, Assistant Administrator, to
Regional Administrators and Headquarters Compliance Program Directors, May 1993,
attaching Multimedia Screening Inspection Program Guidance and National Checklist
(5/12/93). Reproduced as Appendix T in NPDES Compliance Inspection Manual
(EPA300-B-94-014).
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Section 1 Overview
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SECTION 2: ASSESSMENT OBJECTIVES AND TYPES
2.1 Objectives
The appropriate tasks to perform in conducting a compliance assessment will
depend on the goal(s) of the assessment. The three primary goals that may apply which are
discussed in this manual are:
! Permit verification. Determine that the permit appropriately reflects current
process operations and includes all necessary components. Check to ensure that
the permit reflects all applicable regulatory requirements. Evaluate whether the mill
has applied for all necessary permits or permit revisions associated with source
modifications.
! Compliance assessment. Conduct general assessment of compliance with
applicable requirements. May include direct compliance assessments (sampling or
testing for emission limitations and verification of proper implementation of work
practice/operating requirements) or indirect compliance assessments (control
device/process operation and maintenance, observation of general housekeeping
practices, laboratory QA/QC checks, etc.).
! Root cause evaluations. Perform follow-up investigation after a problem is
identified to determine cause (such as follow-up to wastewater treatment plant
upset or to increased emissions levels reported from a CEMS).
Other objectives of an inspection may apply, but are generally considered beyond
the scope of this manual. These include:
! Observing compliance tests or certification tests for self-monitoring equipment.
! Conducting assessments in support of/response to specific enforcement actions.
! Gathering data to support development of new/revised regulations or permit
renewals.
2.2 Available Techniques
There are four basic methods of conducting an inspection: visual (or odor)
observation, record reviews, interviews with facility personnel, and sampling/testing
activities.
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Assessment Objectives and Types Section 2
! Visual and odor observations. Visual (and odor) observations serve two
important functions. In many situations, visual observations can serve as a direct
determination of compliance. For instance, compliance with work practice
requirements under RCRA or the air program can be determined in many cases
based on visual observations alone. The second use of visual or odor observations
is as an indirect screening tool. By observing general plant conditions, detecting
odor problems, or observing specific conditions of key discharge points and
controls, an inspector can identify indications of potential problems at the facility.
Generally, this type of assessment should be linked with other techniques, such as
record reviews, to provide a more complete assessment of compliance. Photo or
video documentation should be used when appropriate or necessary.
! Record reviews. Review of records is an important element of most inspections.
Appropriate file records, including permits, monitoring reports and previous
inspection reports, should all be evaluated prior to conducting the inspection. On-
site records should be reviewed during the inspection to assess current operations
and to verify that recordkeeping obligations are met. For both the RCRA and
NPDES programs, records, including monitoring reports, often allow for direct
compliance determinations without further analysis. For the air program,
continuous monitoring data has been more limited, and visual observations,
especially for particulate matter emissions, have played an increased role in
compliance assessments. As the air program moves toward the NPDES model with
expanded monitoring and compliance certification in Title V operating permits,
record reviews will continue to increase in importance.
! Interviews. An initial step in
the assessment process might
involve in-depth interviews
with facility staff in the target
process areas. Interviews
should cover what discharges
NOTE! Distributed control systems
(DCS) in pulp mill operations provide an
excellent opportunity to merge effective
plant interviews with record reviews. In
the control rooms for various processes, a
and waste streams are DCS can provide real-time and trend data
analyses during an inspection. Interviews
with plant operators can enhance the use
of the DCS to obtain relevant information
and to analyze the information provided
by the DCS.
associated with the process
and how these discharges and
waste streams are managed
to stay within compliance.
To the extent process
conditions are important to
maintaining compliance,
interviews should elicit detailed information about expected normal operating
conditions and how potential process upset conditions are monitored, prevented
and, if necessary, corrected. For an agency inspection, the opening conference is an
appropriate time to discuss what types of interviews are expected during the
inspection.
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! Sampling/testing. In all three main program areas, actual sampling or testing in
the conduct of a typical compliance assessment is limited. However, sampling or
testing methods usually serve as the benchmark for determining compliance and,
where necessary, should be performed where an accurate assessment is difficult to
perform and a significant risk of noncompliance or other problem exists.
Each of the three basic media programs — air, water and hazardous waste - has
developed general, media-specific inspection procedures that incorporate all of these
techniques to some degree. In each case, the media programs use standardized
nomenclature for various types and degrees of inspections. In addition, multi-media
inspection guidance developed by EPA has established additional standard elements of
different types of multi-media inspections. The following sections provide a brief overview
of these various existing inspection types and identify several common elements and some
unique characteristics.
2.3 Air Inspections
The EPA's 1985 Compliance Inspection Manual1 identifies four categories of air
compliance inspections (Levels 1 through 4). As summarized in Figure 2-1, these
categories represent increasing levels of effort associated with conducting a compliance
assessment for air pollution regulations.
Figure 2-1
Air Compliance Inspection Types
Inspection Level
Scope
Level 1
Visible emission observations (VEOs) without plant entry
Upwind/downwind odor assessment
General observation of operations to check for consistency with permit
Use as a screening tool for future inspections, and possibly for direct enforcement
of opacity requirements
Potential response to citizen complaints
Level 2
"Walkthrough" of the facility
Limited review of data from on-site monitoring equipment
Internal checks of air pollution control equipment (if not in service) — visually
from access hatches
Used to identify potential problems warranting follow-up investigation
Useful for verifying accuracy/completeness of emission points identified in a
permit
Level 3
Same as Level 2, plus detailed review of available monitoring data for
processes/equipment with expected problems
Use of portable instrumentation to check emission levels/operating conditions
Comparison of observed data with specified baseline conditions
Usually narrow in scope and targeted to specific units
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Figure 2-1 (cont.)
Air Compliance Inspection Types
Inspection Level
Scope
Level 4
Used to establish baseline conditions
For large units, done in conjunction with performance tests
For small units that are not generally tested, done during periods of documented
proper operation
Also includes development of process/control device flowcharts to aid future
inspections
In addition, an important feature of EPA's air inspection guidance is the concept of
baseline inspection techniques.1>2 For many air pollution requirements, a direct compliance
comparison during an inspection is impractical. The regulations are often expressed in
Ib/hr or Ib/ton of product, and portable or permanent monitoring equipment generally will
not read out directly in these regulatory formats. Instead, shifts from baseline conditions
are used to reveal potential compliance concerns. Baseline inspections are based on the
principle that control device performance can be evaluated by comparing present operating
conditions with specific baseline data. Baseline data are usually generated during a
performance test that establishes the ability of the control equipment to achieve compliance
with the emission limit. Baseline inspections rely on indications of control device
performance as an indirect means of assessing compliance.
Generally, each control device should be approached with the assumption that its
operating characteristics and performance levels are unique, given the myriad of site-
specific process and control variables that can influence the performance of a particular
piece of control technology when applied to a specific emissions source. In addition,
evaluations of control performance generally should consider multiple variables because
usually no one variable has a dominating effect on overall performance. Therefore, this
technique relies on the assessment of shifts in performance of more than one parameter to
document the possibility of reduced control performance. In addition, other signs of
potential reduced control performance, such as corrosion, solids discharge rate, and fan
conditions, can be used to support initial indications of reduced control performance.1'2
Figure 2-2 identifies several key principles for conducting baseline inspection techniques.
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Section 2
Assessment Objectives and Types
Figure 2-2
Baseline Inspection Concepts2
Principle
Rationale
Evaluate changes over time on an
individual unit basis
! Numerous site-specific factors vary from unit to unit and
impact performance
Evaluate sets of data as opposed to relying
on single measurements
! Reduces chance that baseline shifts represent
measurements, not emission, problems
! Increases strength of indication that indirect measures of
compliance represent actual increases in emissions
Scope should include component failure
information and general observations, not
just operating data
! Increases in component failure rates or obvious
housekeeping problems are important to assess cause of
potential compliance problems
The inspector must organize the data and
observations effectively and evaluate the
basic information while on site
! The inspection should include basic inspection points that
definitely are to be covered and follow-up inspection
points that are to be covered only if evaluation of basic
information indicates a potential problem
Inspectors should be flexible and exercise
professional judgement during the
assessment
The baseline concept is designed as a screening test in
which more in-depth follow-up is reserved for points at
which initial evaluations indicate problems
Rigid checklists may be incompatible with site conditions,
including health and safety concerns
Obviously, a key element of the baseline inspection technique is to have adequate
monitoring of process and control performance indicators. The 1985 Air Compliance
Inspection Manual notes that existing monitoring may be inadequate or insufficiently
reliable to perform this function properly. The manual suggests the use of portable
analyzers as an additional diagnostic tool to supplement in-place monitors. For most
modern pulp mill facilities, the use of DCS provides an effective tool to evaluate process
and control performance. To the extent an agency inspector intends to seek access to DCS
data, this issue should be discussed at the opening conference to address any confidential
business information (CBI) concerns. In addition, the Agency has promulgated the
compliance assurance monitoring (CAM) rule at 40 CFR Part 64. The basic concept of the
CAM rule is analogous to the baseline inspection technique and, as facilities implement the
rule, CAM data will increase the availability and reliability of control device performance
monitoring data. In addition, CAM data will have to be reported. These reports can be
evaluated prior to the actual on-site assessment activities to prioritize which control
equipment within the plant to evaluate during the on-site portion of the assessment. Note
that for many mills, CAM data may not be available until the first renewal of a Title V
permit, given the implementation schedule in the CAM rule.
In addition to the four basic compliance inspection types, compliance assessment
activities under the air program also include specific procedures for conducting compliance
tests and for conducting audits of continuous emission monitoring systems (CEMS).
This manual is intended solely for guidance and
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Section 2
These types of compliance assessment tools are not discussed at length in this manual. For
further information, see the 1985 Air Compliance Inspection Manual, as well as other EPA
guidance related to CEM audits.
2.4 Water Inspections
Under the CWA NPDES program, EPA has developed the NPDES Compliance
Inspection Manual^ As with the manual for the air program, the water manual
differentiates between varying degrees of inspections, as shown in Figure 2-3. These
various inspection types include a varying mix of records reviews, on-site sampling
activities, monitoring audits, and visual (and odor) observations. Unlike the air inspection
program, the baseline concept is not a critical component of the water inspection process.
Historically, NPDES
compliance inspection procedures
have focused generally on
wastewater treatment facility
operations and discharge
characteristics. Often, the
wastewater from all processes at a
pulp mill will be combined, treated at
a single on-site treatment facility, and
then discharged from an outfall. The water inspector then can focus the inspection on the
wastewater treatment plant operations and evaluate other areas only if problems are
discovered and the upstream production processes need to be evaluated to identify the
source of the problem. The Cluster Rules add requirements for the bleach plant effluent
that will require a water inspector to evaluate bleach plant operations (see Section 6). The
Cluster Rules also add best management practices (BMPs) for spent pulping liquor, soap
and turpentine that will require the inspector to evaluate operations in the pulping and
chemical recovery areas (see Section 4.6 for a discussion of these requirements). Another
reason to assess the upstream production processes would be to evaluate compliance with
general requirements such as storm water or spill prevention plans (see Sections 8 and 9
for relevant discussions).
Figure 2-3
NPDES Inspection Types
NOTE! The Cluster Rules will require
water inspectors to focus on bleach plant,
pulping, and chemical recovery
operations in addition to traditional focus
on wastewater treatment plant
operations.
Type
Compliance Evaluation
Inspection (CEI)
Scope
! Nonsampling inspection designed to verify compliance
! Records reviews, visual observations, and evaluation of treatment facilities,
laboratories, effluents and receiving waters
! Consider data from both biological and chemical self -monitoring
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Assessment Objectives and Types
Figure 2-3 (cont.)
NPDES Inspection Types
Type
Compliance Sampling
Inspection (CSI)
Performance Audit
Inspection (PAY)
Compliance
Biomonitoring Inspection
Toxics Sampling
Inspection (TSI)
Diagnostic Inspection
(DI)
Reconnaissance
Inspection (RI)
Pretreatment Compliance
Inspection (PCI)
Legal Support Inspection
(LSI)
Scope
! Same elements as CEI
! Obtain representative samples (chemical and bacteriological analyses)
! Verify accuracy of self -monitoring
! Determine compliance with permit limits
! Can be used to determine effluent characteristics and support permit
development
! Used to evaluate self -monitoring program
! Uses CEI records check to verify compliance
! Includes actual observations of permittee's monitoring program from
sampling through reporting
! May require permittee to analyze performance samples to assess laboratory's
accuracy
! Same as a CSI, except focus on toxicity bioassay sampling and chronic
toxicity testing
! Assess biological effect of effluent on test organisms
! Same as a CSI, except focus on toxic effluent parameters (other than heavy
metals, phenols, and cyanide generally analyzed during a CSI)
! Troubleshooting inspection to assist POTWs that are not able to achieve
permit compliance
! Used to obtain preliminary overview
! Quick visual inspection as a screening tool to identify potential problems
! Evaluation of municipal authority's pretreatment program
! Record reviews of industrial user activities (monitoring, inspections, and
enforcement)
! May be supplemented with inspection of industrial users
! Resource intensive inspection
! Designed to support specific enforcement action
2.5 Hazardous Waste Inspections
Under RCRA, EPA has developed the RCRA Inspection Manual* There are many
types of RCRA inspections, as shown in Figure 2-4. However, the compliance evaluation
inspection (CEI) is the primary mechanism for assessing RCRA compliance by hazardous
waste generators, transporters, and TSD facilities. The types of RCRA inspections differ
based upon the purpose, facility status, and probable use of inspection results.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Section 2
Figure 2-4
RCRA Inspection Types
Type of Inspection
Compliance Evaluation
Inspection (CEI)
Case Development
Inspection (GDI)
Comprehensive Ground-
Water Monitoring
Evaluation (CME)
Compliance Sampling
Inspection (CSI)
Operation and
Maintenance Inspection
(O&M)
Laboratory Audit
State Oversight
Inspection
Description
! Routine inspection of hazardous waste generators, transporters, and TSDFs
! Encompasses file review prior to the site visit, on-site examination of
generation, treatment, storage or disposal areas, and a review of records
! May include inspections of facilities with delisted waste (not typical to pulp
mills)
! If corrective action involved, this includes assessment of compliance with
consent and permit orders
! Conducted when RCRA violations are suspected or revealed during a CEI
! Specific purpose is to gather data in support of an enforcement action
! Conducted to ensure that groundwater monitoring systems are designed and
functioning properly at RCRA land disposal facilities (not typical to pulp
mills)
! Includes activities, plus sampling and analysis of groundwater monitoring
system and hydrogeological conditions
! Focus is on collecting samples for laboratory analysis
! May be conducted in conjunction with a CEI or any other type of inspection,
except a GDI
! Conducted at closed land disposal facilities (not typical to pulp mills) to
determine the adequacy of the operation and maintenance of groundwater
monitoring systems
! Usually conducted at facilities that have already received a thorough
evaluation of the groundwater monitoring system under a CME inspection
! Inspection of laboratories performing sample analyses
! Ensures that laboratories are using proper sample handling and analysis
protocols
! Conducted by U.S. EPA personnel to determine the effectiveness of State
hazardous waste management programs and to determine facility
compliance
Pulp and paper facilities generally will be subject to RCRA requirements as a
generator of hazardous waste, not as a TSD facility. Particular mills may have on-site
remediation or other corrective action activities subject to RCRA requirements, but those
activities are outside the scope of this manual. To the extent underground storage tanks
(USTs) are present, UST requirements under RCRA will apply. Consistent with the RCRA
Inspection Manual, waste sampling generally will not be part of a standard agency
inspection of a hazardous waste generator or for UST assessment purposes. Industry self-
assessments may be more likely to include waste sampling activities to verify the status of
various waste streams. The two primary inspection tools covered in this manual for RCRA
purposes are record reviews (e.g.. reviewing waste manifests or personnel training records)
and visual inspection of waste storage areas.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Section 2 Assessment Objectives and Types
2.6 Multi-media Inspections
The EPA's National Enforcement Investigations Center (NEIC) published a
Multimedia Investigation Manual in March 1992.5 Although the manual is no longer
considered a reference for current agency procedures and standards, much of the
information in the manual is still applicable.
The NEIC manual specifies four categories of inspections, with increasing
complexity and multimedia aspects:
! Category A: Program-specific compliance inspections that are conducted to
determine compliance status for program-specific regulations.
! Category B: Program-specific compliance inspections in which the inspector(s)
screens for and reports on obvious, key indicators of possible non-compliance in
other environmental program areas.
! Category C: Several concurrent and coordinated program-specific compliance
investigations conducted by a team of investigators from two or more program
offices. The team conducts a detailed compliance evaluation for each target
program area.
! Category D: Resource-intensive, comprehensive facility evaluations that address
compliance in targeted program-specific regulations and attempt to identify
environmental problems that might otherwise be overlooked. Identify waste
streams by process and trace to final disposition. Requires a team of inspectors
who have been thoroughly cross-trained in different program areas.
The NEIC manual identifies several benefits to conducting Category C or D multi-
media inspection. These benefits include:
More comprehensive and reliable compliance assessment
Higher probability of uncovering/preventing problems before they occur or before
they create an environmental/public health risk
! Improved ability to respond to non-program specific complaints or issues and to
understand cross-media problems
! Improved enforcement
This kraft pulp mill compliance assessment manual is designed to support any
assessment from Category A through Category D. This manual does not, however, focus
on Category D inspections. Instead, the manual is organized generally by program type
within each process area of the kraft pulp mill. This organization is consistent with
preparing for a Category A, B or C assessment. In addition, because of the relatively
limited nature of RCRA waste and EPCRA issues at most kraft pulp mills, the manual
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Assessment Objectives and Types Section 2
focuses on specific ideas for screening analyses (Category B) to assess compliance with
RCRA and EPCRA issues.
2.7 Summary
Inspections under the three media programs will have several elements in common.
First, both pre-inspection and on-site inspection activities in all three programs should
include a review of facility records, including the permit (not applicable to hazardous
waste), required monitoring data submissions, incident reports such as malfunction/upset
reports, and previous inspection/enforcement records. In addition, records required to be
maintained on site but not submitted to an agency (such as waste manifests, equipment
maintenance records, monitor quality assurance activities, etc.) can be reviewed during the
on-site inspection for all three media programs.
Visual and odor observations of facility operations will be a critical component of
an inspection for any of the media. Visual and odor observations can be used to provide a
quick indication of obvious potential problems or poor housekeeping practices. Based on
the observations, the inspector can prioritize which elements of the process deserve more
detailed attention within the time available. In addition, visual observations can be used as
a direct determination of compliance in many contexts. For instance, under the air
program, visible emission observations (VEOs) using Method 9 in Appendix A of 40 CFR
Part 60 is a method for determining compliance with opacity regulations. Compliance with
some work practice standards can also be assessed visually. For water, visual observation
can be used to assess compliance with certain effluent limitations, such as prohibitions
against excessive sheen. Under RCRA, numerous requirements can be assessed visually
because many of the standards are specific work practice standards. Examples include
appropriate labeling practices and aisle space between containers.
At this point, the appropriate assessment techniques for the various media will
begin to diverge. For waste inspections, no further assessment generally will be conducted
unless particular circumstances require sampling of specific wastes. For water, the next
level of assessment is likely to involve actual sampling activities aimed at developing a
direct determination of compliance with effluent limits and as a check on the source's
compliance monitoring program. For air, the next step toward a more in-depth analysis
involves evaluating baseline parameters to detect potential decreases in control
performance without having to conduct actual direct compliance determinations using
specified compliance test methods. Because of the diffuse nature of air pollutant emission
points, the compliance assessment for air also is likely to cover more separate process units
than an assessment related to water effluents.
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Section 2 Assessment Objectives and Types
References:
1. Air Compliance Inspection Manual (EPA-340/1-85-020), U.S. Environmental
Protection Agency, September 1985.
2. Richards, J., Baseline Inspection Techniques, Student Manual, Air Pollution Training
Institute Course 445, 2nd edition, 1996.
3. NPDES Compliance Inspection Manual (EP A-3 00-B -94-014), U. S. Environmental
Protection Agency, September 1994.
4. RevisedRCRA Inspection Manual (OSWER Directive 9938.02b), U.S. Environmental
Protection Agency, October 1993.
5. Multi-media Investigation Manual (EPA-330/9-89-003-R), U. S. Environmental
Protection Agency, Rev. March 1992.
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SECTION 3: GENERAL INSPECTION STEPS
The basic steps to conducting a successful compliance inspection are generally
similar across the various media. Each assessment requires (1) upfront planning,
(2) accurate recording and documentation of findings, and (3) effective follow-up action to
problems discovered during the inspection.
3.1 Planning the Inspection
Without successful planning before the inspection, compliance assessment is
unlikely to provide complete and accurate results. In addition, agency inspectors usually
will have only a relatively brief time to conduct on-site assessments for individual facilities.
Proper preparation is therefore essential to maximize the benefits of conducting the
assessment. Recommended steps include:
Define objectives. In order to plan the appropriate scope of an assessment, the
inspector first must define the objectives. Often, the basic objective of an assessment will
be to evaluate general compliance with regulatory requirements. In some cases, however,
more specific objectives may play a role, including:
! Verifying accuracy/completeness of a permit
! Responding to citizen complaints
! Identifying the root cause of a discovered problem and/or evaluating effectiveness
of corrective actions taken
! Developing information to support/respond to enforcement action
! Observing required sampling/testing
! Auditing of compliance monitoring systems
This manual will focus primarily on basic compliance assessments (including response to
citizen complaints), permit verifications, and root cause assessments.
Identify assessment team/critical participants. Assembling the appropriate team
of individuals that will be involved in the assessment will be critical to its overall success.
It is important to identify not only the direct participants but also the critical process
operators and other staff that may be needed to answer questions and assist with immediate
follow-up issues. For instance, if a review of continuous emission monitoring system
(CEMS) data is planned as a component of the assessment, coordinating in advance to
make sure that the key CEMS operators are available for questions on monitor
maintenance/downtime activities will be important.
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General Inspection Steps Section 3
At this stage, the agency inspector should also coordinate with other offices and the
facility to the extent appropriate. For agency inspections, a key issue to resolve at the
outset is whether the inspection will be an announced or unannounced inspection. Often,
an agency will want to conduct an unannounced inspection to obtain as realistic a view as
possible of source operating practices. If the inspection will be announced, the agency
inspector should coordinate with plant personnel to ensure that the appropriate staff are
available, that the schedule does not conflict with planned activities at the facility that could
interfere with the inspection, and that the inspector satisfies any special safety requirements
established by the facility. Examples of coordination activities include:
Figure 3-1
Pre-Assessment Coordination
Potential Coordination Activities
Scheduling joint inspections with other agencies/offices
Scheduling inspections to avoid conflicts with planned activities of other agencies/offices or the facility
Conferring with other agencies/offices on their information needs if multi-media screening planned
Obtaining relevant information on the facility and its compliance status
Discussing permit-related issues with the appropriate permit writer
Identifying all necessary safely and inspection equipment
Develop background information. Before conducting the on-site assessment, the
inspector should review existing information that describes the plant, processes, and
previous compliance assessments. At a minimum, existing permits, applicable regulations,
recent monitoring reports, and the most recent inspection report should all be evaluated for
matters within the scope of the assessment. If recent enforcement actions have occurred at
a facility, the relevant enforcement documents, especially any compliance plans or
corrective action obligations, should be reviewed so that compliance is assessed with those
obligations that may apply above and beyond the basic permit requirements. Agency air or
water inspectors that may be considering multi-media screening efforts for waste or toxic
release reporting issues may want to review available information from agency databases.
It is important to note that self-monitoring and self-certification data are
increasingly required and available under federal regulations. This availability increases the
need to review available data thoroughly and to integrate that information into deciding
which facilities and processes within a facility to evaluate. The following Figure 3-2
provides a list of various records and information sources that should be reviewed prior to
conducting the assessment.
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Section 3
General Inspection Steps
Figure 3-2
Pre-Assessment Records Review
Information Needs
Information Sources
Basic Facility Information
! Plant name, location, ID#s
! Contact information (name, title, phone/fax#)
! Flow diagrams/general schematics of
production processes, and associated
control/waste handling equipment
! Production rate data
! Safety equipment requirements
! Prior inspection reports
! Permit files
! Contact with facility
Regulatory Information
! Permits required
! Standards applicable
! Required reports
! Regulations
! Permits
Compliance Status/History
Enforcement files
Prior inspection reports
Computer databases (IDEA, AIRS, PCS, RCRIS)
Emissions Data
MSDS Sheets
TRI reports
DMRs
TRS, opacity, other CEMS
Material balance calculations
Engineering calculations used to prepare TRI reports
Control Method Data
! Description/design data for control
equipment
! Upsets/malfunctions
Permit files
Prior inspection reports
Baseline test results
Malfunction/upset/bypass reports
Reported control device parameter data
Prepare inspection plan/strategy. To assure that the objectives of the assessment
are achieved, the inspector should develop a specific plan for conducting the on-site
assessment. The plan should include the objectives, a list of specific tasks to be performed,
the procedures to use to complete the tasks, a list of required resources, and the schedule.
The plan should include priorities, and should address shifts in tasks and schedule that may
be necessary if initial screening evaluations indicate the need for detailed follow-up. For
instance, if a screening check of certain operating parameters documents a shift from
baseline expected conditions that could lead to emission increases, following up on that
information may take precedence over assessing another process. Figure 3-3 lists key
elements of an inspection plan.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Section 3
Figure 3-3
Inspection Plan
Issues to Cover
Objectives
Scope
Tasks
Procedures
Resources
Schedule
Potential Components
! General compliance assessment
! Root cause evaluation
! Permit preparation/verification
! Full facility
! Targeted processes
! Visual observation
! Record reviews
! Sampling/measurements
! Interviews with plant operators
! Identification of which records to look at and timeframe
! Link issues raised in records reviewed prior to inspection to items to be
investigated on site
! Checklists to use
! Measurement procedures, including chain-of-custody considerations
! Identify what follow-up procedures may be needed
! Identify necessary equipment
! Identify what background information needed during assessment (e.g..
baseline data for comparison purposes)
! Allocation of time per task, with potential adjustments if follow-up
procedures needed for particular tasks
Equipment/resource preparation. The final key aspect of planning the
assessment is to identity what equipment and resources to bring to the assessment. Safety
equipment is of paramount concern. In addition, inspection equipment, including sampling
or measurement equipment, should be identified. Finally, it is important to bring
information collected during the background review phase that may need to be verified or
compared against during the inspection.
3.2 Conducting the Inspection
Once these initial preparation activities are completed, the actual assessment can be
conducted. The remainder of this document focuses primarily on this phase of the
assessment process, although the manual also identifies, where applicable, critical
monitoring and similar information that should be evaluated prior to or after the on-site
phase to supplement on-site findings. The following discussion highlights key procedural
steps for conducting the on-site phase of the assessment.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Opening conference/meeting. For agency inspections, the opening conference
serves an important function, especially in the case of an unannounced inspection. At this
point, the agency staff should identify the purpose of the inspection, the legal authority, and
the procedures to be followed. The conference also presents the opportunity to provide
general compliance assistance and answer relevant questions. Effective communication at
this stage will facilitate the subsequent stages of the inspection. A list of appropriate topics
to cover in the opening conference includes:
Figure 3-4
Opening Conference Topics
Topic
Outline Objectives
Discuss Agenda/Schedule
Verify Facility Information
! Basic data (correct names,
etc.)
! Production data
! Emission sources
Provide List of Records to be
Reviewed
Arrange for Accompaniment
Photographs/Videos
Schedule Closing Conference
Duplicate Sampling/
Measurement
Confidentiality
Compliance Assistance
Purpose
! Inform facility of purpose and scope
! Avoid misunderstandings
! Streamline subsequent activities
! Identify possible conflicts
! Allow for scheduling meetings with facility personnel
! Update existing facility information
! Identify possible changes that create new compliance issues
! Streamline subsequent activities
! Provide source opportunity to collect information during initial
phase of on-site assessment
! Identify confidential business information (CBI)
! Identify safely constraints
! Identify CBI
! Explain operations/answer questions
! Arrange for discussions/questions with plant operational staff
! Notify plant personnel of intent to take photographs or videos to
document observed conditions
! Provide opportunity for follow-up questions
! Confirm confidentiality claims
! Advise facility of right to obtain duplicate samples or to conduct
simultaneous measurements
! Advise facility of right to request that documents be handled as
CBI
! Respond to inquiries about new/proposed regulations
The opening conference provides an excellent opportunity, along with the closing
conference, for an agency inspector to provide compliance assistance to facility
representatives. For instance, the inspector can provide information about new or
proposed regulations that could affect the facility. The agency inspector, however, should
not attempt to provide interpretations of the finer points of regulatory requirements,
provide unwritten policy interpretations or provide detailed design information on a
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 3-5
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General Inspection Steps
Section 3
facility's particular problem. The EPA has recently prepared a report1 on this issue that
identifies three tiers of compliance assistance activities, shown in Figure 3-5. Generally,
Tier I represents appropriate activities for inspection personnel, while Tier III represents
generally inappropriate activities. Tier II activities should be approached cautiously and
may be more appropriate for separate agency personnel or as part of a separate site visit.
Figure 3-5
Compliance Assistance Activities
Tier I (Appropriate
Assistance): Sharing
Standardized Information
and References
Tier II (Potentially
Appropriate Assistance):
More Technically Complex
and Site-Specific
Tier III (Generally
Inappropriate Assistance):
Most Technically Complex
and Site-Specific
! Providing physical copies of
requirements
! Conveying an understanding
of requirements
! Providing information
including prepared guidance,
manuals, and technology
transfer documents
! Providing information on what
assistance can be gained from
EPA, State, and local
programs
! Providing information on what
assistance can be gained from
trade and other (i.e. public)
organizations
! Sharing information on
control practices and
equipment used within a
specific sector to comply with
environmental regulations
! Providing published technical
information and/or advice for
simple solutions that do not
require a significant amount of
resources or liability to the
source/facility or regulatory
agency
! Providing prepared literature
on pollution prevention
techniques and opportunities
! Providing suggestions on
simple techniques and
concepts to reduce or
eliminate pollution (e.g..
housekeeping tips)
! Sharing information on
compliance status
! Providing review of
compliance status
! Sharing information and
insight into their particular
problem and what might be
evaluated to remedy the
problem
! Providing technical assistance
on recognized industry or
sector-based practices and
concepts to reduce or
eliminate pollution (e.g..
chemical substitution,
equipment changes)
! Providing information on
specific commercial
consultant services
! Providing interpretations of
the finer points of regulatory
requirements
! Providing detailed design
information on a
source/facility's particular
problem
! Providing unwritten policy
interpretations on regulatory
requirements
! Providing detailed facility-
specific engineering design
and materials management
information that advances
pollution prevention
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Section 3
General Inspection Steps
Recording assessment findings. Complete and accurate recordation of findings is
critical to the success of any compliance assessment activity. From an agency inspector's
viewpoint, maintaining complete and accurate information is essential as the information
may be used subsequently in an enforcement, permitting or similar context. Even if
potential enforcement concerns are not present, full documentation will be important so
that subsequent assessments build upon prior activities. Examples of documentation that
may be produced during the assessment include:
Figure 3-6
Documentation of Findings
Document Type
Purpose and Contents
Field Notebook/Notes
! Most critical component
! Include all observations made, list/reference all procedures used,
note unusual conditions, reference all documents/photographs
reviewed, copied or produced
Forms and Checklists
! Concise uniform method of collecting information
! May serve as template for entering data into tracking system (e.g..
use of standard NPDES Inspection Form for entering data into
PCS)
Sampling/Measurement
Documentation
! Chain of custody procedures must be followed and documented to
use samples/measurements as evidence
Drawings and Maps
I
Useful for cross-referencing in notes, checklists, etc.
Records Reviewed
Copies may be necessary to document potential problems
discovered or to verify compliance status
Copies should be numbered and initialed, with appropriate
referencing in field notes, to allow for substantiating authenticity at
later date
Photographs
Provide objective record of observed conditions
Because of proprietary/confidentiality concerns, the use of
photographs to document findings should be discussed with facility
personnel
Duplicates should be offered to facility personnel
Log photographs/video segments in field notebook. After film is
developed, mark all photographs to allow for proper identification
at a later date. Make sure you can identify from each photo or
inspection report the film type, lens type, shutter speed, lighting,
time of day, weather conditions, date and location, and description
of subject
The issue of confidential business information (CBI) is likely to arise during an
inspection. The facility is responsible for making a claim of confidentiality. However, a
claim of confidentiality is not grounds to refuse access to the information by an agency
inspector - rather, it safeguards the release of the CBI by the inspector to the public at
large. The EPA has developed specific regulatory procedures for handling claims of
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 3-7
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General Inspection Steps Section 3
confidentiality (see 40 CFR part 2). The inspector must assure that the facility is given the
opportunity to make the claim and that the inspector clearly acknowledges any information
received by the inspector which the facility claims is protected as CBI.
In addition, the inspector must follow all prescribed chain of custody procedures
for any samples collected during an inspection. See the discussion of this topic in the
media-specific inspection manuals for the air, water and hazardous waste programs.
Closing conference. The closing conference allows the assessment team and
facility staff to wrap up remaining issues following the data collection stage. The main
components of the closing conference include:
! Review findings. Allows for filling in gaps, clarifying ambiguous findings, and
resolving technical disagreements over what was found
! Answer questions. Provides a chance for factual questions. Legal conclusions,
opinions about compliance status, and enforcement consequences should be
avoided, except for circumstances where the inspector exercises field citation
authority
! Confidentiality claims. A final opportunity to claim CBI protection for
information collected during the inspection
3.3 Inspection Follow-up
The appropriate follow-up to an inspection clearly will vary depending on: (1) who
is conducting the inspection and (2) what is found during the inspection. However, two
fundamental aspects will be appropriate in nearly all circumstances:
! Develop a concise, clear report of what was found
! Communicate effectively what was found so that, if necessary, further action may
be taken
The critical elements of a successful report, for either an agency or industry
inspection, are to address the following issues:
! Why the inspection was performed
! What was covered
! What was found
! What issues should be followed up on and when
! What are the priorities for any further assessments
For an agency inspection report, the findings may eventually be used as part of an
enforcement action. Therefore, it is essential that inspection reports are well-written and
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 3-8
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Section 3 General Inspection Steps
document all key facts. Appropriate references to documentary support collected during
the inspection must be included. If CBI is included in the report, the material should be
referenced in a manner that preserves confidentiality (for instance, refer to a document
control number assigned by the agency and provide a general description of the
information). If the confidential information is referred to directly, then the entire report
must be treated as confidential. The inspector should refer to the media-specific inspection
manuals for further discussion of these CBI concerns, as well as further suggestions on the
style and format of an inspection report.
For a self-assessment inspection, the report should address many of the same
factual items as would be included in an agency inspector's report. However, a self-
assessment may be more likely to identify the root cause of any problems discovered and
what specific corrective actions will be taken to address the problems. The ability of
facility personnel to provide an explanation of the cause of any problem and the corrective
actions taken may help avert enforcement action by the regulatory agency. The facility
should document all corrective actions taken. The facility also should consider prompt
disclosure of any problems discovered and the actions taken to correct the problems. The
EPA has established a policy that substantially reduces or eliminates civil penalties for
violations that are addressed in this manner. (See 60 FR 66706, December 22, 1995)
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 3-9
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General Inspection Steps Section 3
References:
1. Role of the EPA Inspector in Providing Compliance Assistance., Final Report, U.S.
Environmental Protection Agency, July 1, 1997.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 3-10
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SECTION 4: ASSESSMENT MODULE FOR KRAFT
PULPING OPERATIONS
4.1 Introduction
In the past, the pulping process
area was less likely to be a priority area
for many compliance evaluations.
However, as a result of the Cluster
Rules, the pulping process area is
subject to significant new regulatory
requirements for both air emissions and
water discharges. Therefore, this area
will be a critical process for compliance
evaluation as the Cluster Rules are
implemented.
CONTENTS
4.1 Introduction
4.2 Overview of Process and Discharges
4.3 LVHC Gas Collection System
4.4 HVLC Gas Collection System
4.5 Condensates
4.6 Spent Pulping Liquor, Turpentine
and Soap Management
To address these compliance assessment issues, this section provides a thorough
overview of the applicable processes, regulatory requirements, and inspection procedures.
After a short description of the pulping process as a whole, this section breaks down the
pulping processes into four main activities of regulatory concern: low volume, high
concentration (LVHC) gas collection; high volume, low concentration (HVLC) gas
collection; condensates; and spent pulping liquor, turpentine and soap management. In
addition, Appendix E contains an example assessment form specifically designed to address
the issues raised in this process area.
4.2 Overview of Process and Discharges
4.2.1 Description of the Process
The pulping process converts raw materials (e.g.. wood, plants) into fibers that can
be formed into paper or paperboard. There are three main functions performed by the
pulping department: producing pulp (digestion), pulp processing to remove impurities
from the pulp and recover spent cooking chemicals, and weak black liquor processing to
concentrate spent liquor for chemical recovery. Figure 4-1 depicts a typical sequence of
the major equipment systems in the pulping process. The function of each of these systems
is described below.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-1
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Figure 4-1
Flow Diagram of Typical Kraft Pulping Systems
=
VI
•a
Wood
Screens
and Cleaners
Pulp
to Bleaching
(If applicable)
o
=
o
a
a
5'
ro
O
a
o
=
Kraft Pulping
Process
Condensates
Strong Black Liquor
to Recovery
Stripped Condensate
Equipment enclosed by the dashed line are part of the HVLC system. The remaining equipment are components of the LVHC system.
C/5
n
n
P^-
o°
=
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Section 4 Assessment Module: Kraft Pulping Operations
The digesting process. Kraft pulping entails cooking, or digesting wood chips at
elevated temperature and pressure with an alkaline pulping liquor that contains sodium
sulfide (Na2S) and sodium hydroxide (NaOH). Cooking may be performed in either batch
digester systems or continuous digester systems. For mills that use softwood feedstock,
the digester system generally will also include a turpentine recovery system. The
turpentine is recovered from digester relief vent gases.
Pulp processing steps. The raw pulp is cleaned of impurities prior to bleaching (if
performed) or papermaking. The primary cleaning operations include deknotting, brown
stock washing, and pulp screening and cleaning.
Deknotting removes knots and other portions of uncooked wood from the pulp
slurry. The knots and uncooked wood are either burned for energy recovery,
disposed of as waste, or recycled for repulping.
Brown stock washers recover spent cooking liquor (weak black liquor) for re-use in
the pulping process. Weak black liquor consists of dissolved wood compounds and
cooking chemicals. Efficient washing is critical to maximize return of spent
cooking liquor to chemical recovery and to minimize carryover of spent cooking
liquor (known as brown stock washing loss) into the bleach plant. Excess spent
cooking liquor carried over in the pulp increases consumption of bleaching
chemicals and can lead to high pollutant loads in wastewater treatment. A variety
of brown stock washing technologies are used; the most common technology is a
series of two to four rotary vacuum washers. In each washer, wash water is
applied to displace spent cooking liquor in the pulp; countercurrent washing is
generally used to reduce fresh water requirements. Other common washer types
are diffusion washers, rotary pressure washers, horizontal belt filters, wash presses,
and dilution/extraction washers.
Pulp screening removes the remaining oversized particles from washed pulp. The
pulp is diluted to low percent solids and passed through a perforated screen and
rejects are removed from the screen continuously. Methods for removing rejects
are shaking and vibration, hydraulic sweeping action, back-flushing, or pulsing the
flow through the openings with various moving foils, paddles, and bumps.1 Mills
may operate open, partially closed, or closed screen rooms. In open screen rooms,
wastewater from the screening process is discharged to wastewater treatment. In
closed screen rooms, wastewater is reused in brown stock washing or other pulping
operations and ultimately enters the chemical recovery system. Typically, a decker
is used to thicken the pulp for storage after screening.
Pulp cleaning in centrifugal cleaners is used to remove high specific gravity
contaminants such as dirt and sand from the screened pulp. Centrifugal cleaners,
also known as liquid cyclone, hydro cyclone, or centricleaners, consist of a conical
or cylindrical-conical pressure vessel with a tangential inlet at the largest diameter
of the cone. Centrifugal force and fluid sheer generated from fluid rotation cause
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 4-3
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Assessment Module: Kraft Pulping Operations Section 4
the more dense contaminants to concentrate at the narrow end of the cone where
they are removed. Cleaners are typically employed in a cascade of three or more
units, with the rejects stream directed to subsequent cleaners to concentrate the dirt
in the reject stream and return good fiber to the process.
Weak black liquor processing. Weak black liquor collected from the pulp
washers will usually go into a weak black liquor (WBL) storage tank. The WBL is sent to
the multiple effect evaporator (MEE) to evaporate water and concentrate the WBL in
order to increase solids content. Typically, weak black liquor from the brown stock
washers contains 13 to 17% solids.2 The WBL is then concentrated to 60 to 80% solids,
which is required for efficient combustion in the recovery boiler. A MEE will include four
to seven effects, or bodies, arranged in series.4 At pulp mills using pine wood, a tall oil
recovery system is generally incorporated into the evaporator system to recover tall oil or
"soap" from the black liquor.
Condensate stripping. The pulping process system may also include a condensate
stripper system to remove organics and total reduced sulfur (TRS) compounds from
various pulping process condensates. These condensates are wastewater streams produced
from condensed gases from digester systems, turpentine recovery systems, and evaporator
systems. Generally, the streams that are stripped are the turpentine decanter underflow,
blow steam condensates, and evaporator condensates. The stripped condensates may then
be used as hot process water and the off gases are typically combusted.
Gas collection systems. Vent gas collection systems, or non-condensible gas
(NCG) systems, are used to collect gases from the various pulping processes and transport
them to an appropriate incineration device for air pollution control purposes. For safety
purposes, the NCGs are segregated into two categories5: low volume, high concentration
(LVHC) and high volume, low concentration (HVLC). A number of mills will use a
dedicated incinerator to control these emissions, but most often the facility will use process
combustion sources such as the lime kiln, power boilers or recovery boiler. Historically,
most LVHC gases have been controlled, while a smaller portion of the HVLC gases have
been controlled.3
Oxygen delignification. Some mills may also have an oxygen delignification stage
either in the pulping area or as a prebleaching stage. At present, oxygen delignification is
used at only a relatively small number of mills, but is expected to become more widely used
over time. High efficiency oxygen delignification minimizes the amount of bleaching
chemicals needed to achieve adequate pulp brightness. There are currently two types of
oxygen delignification systems available: high consistency and medium consistency.4
Medium consistency systems are more popular due to safer operation and lower capital
costs. Design and placement of these systems vary from mill to mill. Two-stage oxygen
delignification systems are becoming more widely used in the United States.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 4-4
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Section 4 Assessment Module: Kraft Pulping Operations
4.2.2 Air Pollutant Emissions
As discussed above, air I *jnrn?, ™A*—r•• *u- c 1-
. . ,, . . NOTE! MACT summaries in this Section
emissions from the above process . , , A,«.,na T.. , „ , ,
,, r-,, • , 4 are based on 4/15/98 Final Rule and
equipment systems generally tall into . . . ,,. , ,
, , , • , subsequent regulatory notices published
two categories, low volume high ^ ^ ^ ^^ ^
concentration (LVHC) noncondensible ., • • • • • •••
,^-rr^^ 11-1 1 possible updates to this section that will
gas (NCG) streams, and high volume n ^ , ^ , ^
f ' . n-nrt r^\^j^^ reflect any subsequent regulatory notices.
low concentration (HVLC) NCG |^^^^j^^^^--^^^^^j^^^^^
streams. Critical characteristics of
these emissions are:
! The primary air pollutants of interest are TRS and organic HAPs, primarily
methanol. Typical emission rates for various equipment systems are shown
in Figure 4-2.
! TRS emissions may be subject to NSPS and/or State standards, and HAP
emissions are subject to MACT requirements under the Cluster Rules.
! LVHC emissions in the past have generally been subject to greater control
than HVLC emissions, and HVLC emission points are generally more likely
to be unenclosed than LVHC points.
! For safety reasons, the LVHC and HVLC gas streams also generally use
different gas collection systems and are often sent to separate combustion
units for control.
Because of their different regulatory treatment, Sections 4.3 and 4.4 treat these two
gas streams separately.
In addition, Section 4.5 contains a separate discussion of HAP air emission
concerns for pulping condensates. The Cluster Rules include requirements to control air
emissions from the liquid pulping process condensates in addition to LVHC system-based
requirements for condensate stripper system overhead gases. Section 4.5 addresses these
new regulatory provisions.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 4-5
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Assessment Module: Kraft Pulping Operations
Section 4
Figure 4-2
Typical Air Emissions from the Pulping Processes at a 1000 Ton Per Day Kraft Milla
Pulping System Components
(TypeofNCG)
Digester and Evaporator (L VHC)
Knotterc (HVLC)
Screend (HVLC)
Brown Stock Washer (HVLC)6
Decker (HVLC)
Oxygen Delignification (HVLC)
Pulp Storage (HVLC)
Weak Black Liquor Storage
(HVLC)
Steam Stripper Overhead Gases
Miscellaneous Sources
Typical Emissions (Tons/yr)
Methanol
0.5
2.6
1.4
210.0
12.1
210.0
7.0
12.1
0.4
Total HAP
2.3
2.9
1.5
249.0
21.7
244.5
18.0
12.9
0.4
Not Available
TRS
5.1
Not Available
Not Available
73.5
Not Available
Not Available
Not Available
Not Available
1.9
87.5
a Based on average AP-42 Emission Factors (TRS), Air Pollution Engineering Manual9 (steam stripper
gases TRS value) and 1997 EPA Chemical Pulping Emission Factor Development Document13
(Methanol and Total HAP), with 350 operating days/year.
" Assumes controlled system (99% control efficiency). Digester system includes an assumed turpentine
condenser. All other points assume no control device is used.
c Assumes pressure/open type configuration.
d Assumes closed screens.
e Assumes open rotary vacuum drum washer, using average of data from system with high and low HAP
concentration in recycled water.
* AP-42 identifies miscellaneous sources as "knotter vents, brownstock seal tanks, etc." Thus, includes
TRS emissions from smaller equipment systems in pulping area, likely including many of the individual
systems the table identifies as "Not Available" for TRS data.
4.2.3 Water Pollutant Discharges
Most of the equipment systems in the pulping process area have some associated
wastewater either in the form of foul condensates, black liquor spills or other discharges.
With proper management practices — with the exception of condensates and a reject purge
from screening and cleaning - planned discharges from the pulping area can be eliminated.
The high HAP/TRS concentration (or foul) condensates generally are steam
stripped prior to being sewered to wastewater treatment. The applicable effluent
limitations and other requirements apply at the wastewater treatment plant - after these
pulping condensates are combined with other process wastewaters. Thus, no CWA
effluent limitations guidelines or standards will apply specifically to these condensates.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-6
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Section 4 Assessment Module: Kraft Pulping Operations
However, best management practices (BMPs) promulgated as part of the Cluster Rules do
apply. These BMPs require certain practices for control of leaks, spills and intentional
diversions of spent black liquor, turpentine and soap, and are discussed in more detail in
Section 4.6.
4.2.4 Solid/Hazardous Waste Releases
The pulping process generally does not generate significant RCRA-related
hazardous waste streams. However, handling of spent black liquor can create RCRA-
related concerns. Black liquor is not a listed RCRA waste and is excluded from regulation
as a solid waste under 40 CFR 261.4(a)(6) if the black liquor is reclaimed in a recovery
furnace and reused in the pulping process. Therefore, potential liquor spills that are not
reused in the process — such as leaks from surface impoundments used to store black
liquor prior to recovery - may be an issue for RCRA compliance assessment if the spilled
liquor exhibits one of the four hazardous waste characteristics (toxicity, corrosiveness,
reactivity, or ignitability). The RCRA regulatory and inspection procedures are discussed
in Section 4.6, which covers spent liquor management.
To the extent other hazardous waste is generated in the pulping area, those issues
are addressed in Appendix C through the general discussion of RCRA regulatory and
inspection procedures for generators of hazardous waste.
4.2.5 EPCRA Chemicals and Reportable Releases
Facilities will have to provide information on chemicals used in the pulping process
area to meet EPCRA's emergency preparedness requirements. Appendix D contains a
process-based list of the types of hazardous chemicals that typically could be included in an
EPCRA inventory for a kraft pulp mill.
On-site air, water and land releases, including land disposals, of toxic chemicals
associated with pulping processes, as well as off-site waste transfers of these toxic
chemicals, may have to be accounted for in TRI Form R reports. These Form R reporting
requirements apply to each of Sections 4.3 through 4.6 and are discussed briefly in each
section.
In addition, EPCRA/CERCLA emergency release reporting could apply to off-site
releases that are not federally permitted. These releases potentially could include abnormal
air emissions or spills of black liquor or turpentine released off-site. These reporting issues
also are discussed briefly in Sections 4.3 through 4.6.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 4-7
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Assessment Module: Kraft Pulping Operations
Section 4
4.3 LVHC Gas Collection System
As discussed above, LVHC gas
collection is a critical element of
controlling air emissions from the
pulping process area. These air
emissions are subject to significant
CAA and State regulation, including
new Cluster Rules requirements, and
may also raise EPCRA reporting
obligations as well. This section
describes the:
! Emission points involved,
including the nature and
amounts of their emissions
! Air regulations that apply and
air compliance inspection
procedures
! EPCRA reporting obligations
and EPCRA inspection procedures
4.3.1 LVHC Emission Points
Key Features for LVHC Gas Collection
! TRS (NSPS and State) and HAP
(Cluster Rules) requirements may
apply
! Thermal incineration nearly exclusive
control option used
! Combustion units in other areas of the
mill often used to control emissions
! Cluster Rules add recordkeeping for
collection system inspections and
uncontrolled venting
! EPCRA obligations include TRI Form
R and the potential for emergency
reporting for abnormal air releases
The primary LVHC emission points are the digester system (including associated
flash and blow tanks, chip steamer(s), and condensers), turpentine recovery system,
multiple effect evaporators (including associated hotwells and condensers), and condensate
steam stripping system. These points are identified in Figure 4-3. The primary emissions
of concern are total reduced sulfur (TRS) compounds and organic HAPs, primarily
methanol.
These points generally are addressed consistently under the applicable regulations
(NSPS and State regulations for TRS, and Cluster Rules MACT requirement for HAPs).
However, the NSPS (and comparable State regulations) do not apply to emission points
associated with the turpentine recovery system except the condenser prior to the turpentine
decanter. In contrast, the Cluster Rules apply to all emission points associated with the
turpentine recovery system (other than turpentine storage tanks following the decanting
process). As a result, emissions associated with the turpentine decanter are covered only
under the Cluster Rules, not the NSPS.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-8
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Figure 4-3
Flow Diagram of LVHC System
C/5
re
n
p^-
o°
=
4-
Wood
White Liquor
OQ
ft
in
ft
A
Part of HVLC System
Washer System
Pulp
Kraft Pulping
Condensates
Condensate
Stripping
System
^ Stripped
^ Condensate
Weak
Black
Liquor
a
Strong Black Liquor
to Recovery Boiler
^
Multiple Effect Evaporator
=
VI
O
re
n
p*
o'
=
o
a
a
5'
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O
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re
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Assessment Module: Kraft Pulping Operations Section 4
4.3.2 LVHC Air Regulations
4.3.2.1 TRS Requirements
Basic emission limits. Prior to the Cluster Rules, TRS was the only compound
generally regulated from these LVHC points. The New Source Performance Standards
(NSPS) for kraft mills (40 CFR part 60, subpart BB) apply to new or modified (post
9/24/76) pulping process equipment systems with LVHC emission points. Although the
NSPS do not require any particular control technology, incineration is used almost
exclusively to meet the NSPS limits. Some mills will use stand-alone incinerators, but most
mills will take advantage of process combustion sources to incinerate LVHC gases. A lime
kiln is the predominant combustion source used for this purpose, although a significant
number of mills use on-site power boilers, and a few mills use a recovery boiler.3
In addition, many States have developed similar regulations for existing sources not
covered by the NSPS. Under section 11 l(d) of the Clean Air Act, EPA develops emission
guidelines for existing sources with respect to non-criteria air pollutants that are subject to
regulation under an applicable NSPS — such as TRS emissions from kraft pulp mills.
Several States have adopted these guidelines, which establish a 5 parts per million by
volume (ppmv) limit for digesters, multiple effect evaporators, and condensate strippers.
In addition, several States have adopted State-only TRS requirements for various LVHC
emission points at kraft pulp mills. The following Figure 4-4 summarizes the various NSPS
and State regulations.
General exceptions and r^™, ^ , , f^ni
1
-------
Section 4
Assessment Module: Kraft Pulping Operations
Figure 4-4
LVHC Emissions: TRS Federal and State Emission Limits*
Equipment System
Digester System (includes
blow/flash tanks, chip steamers
and condensers) and Multiple
Effect Evaporators
Condensate Stripper
TRS Emission Limits
5 ppmv (dry basis, corrected to a
standard O2 %) (averaging periods
vary)
0.6 Ib/TODP
0.2 Ib/TADP
0.5 Ib/TADP
Incineration in lime kiln or recovery
furnace subject to NSPS TRS limits
Incineration at 1200° F for 0.5 sec.
5 ppmv (dry basis, corrected to a
standard O9) (averaging periods
vary)
0.2 Ib/TADP
0.5 Ib/TADP
Incineration in lime kiln or recovery
furnace subject to NSPS TRS limits
Incineration at 1200° F for 0.5 sec.
Applicable Regulation
NSPS1, AL, CA (BAAQMD,
SHAAQMD), FL, GA, ME, MS,
NH, NC, OH, PA, SC, TN, TX,
VA
MD2
CA (MENAQMD, NCUAQMD,
NSOAPCD), ID3, NM4
CA (BUTAPCD, COLAPCD,
FRAQMD)
NSPS
NSPS5, CA (MENAQMD,
NCUAQMD, NSOAPCD), FL,
ID, KY6, MD, MT, OR (0.3 sec.),
WA, WI
NSPS, CA (BAAQMD (15 ppm),
SHAAQMD), FL, ME, MS, NC,
OH, SC, TX, VA
CA (MENAQMD, NCUAQMD,
NSOAPCD), ID3, MS, NM4
CA (BUTAPCD, COLAPCD,
FRAQMD)
NSPS
NSPS5, CA (MENAQMD,
NCUAQMD, NSOAPCD), FL,
OR (0.3 sec.), WA
State regulations updated through August 1997. See Figure 1-2 in Section 1 for information available
for updating State information.
Limit not applicable for digesters if uncontrolled TRS rate is less than 0.01 Ib/ton ADP from new,
modified or reconstructed digester. See other exceptions discussed below.
Limit for combined emissions from digesters, recovery boilers, evaporators, and smelt tanks.
Limit for combined emissions from brown stock washers, black liquor oxidation vents and condensate
stripper.
Limit for combined operations at a mill.
Allowed only if gases subject to NSPS combined with other waste gases.
Minimum 98% efficiency. Includes evaporator hot wells.
Back-up control requirements. Various States may require the use of a back-up
control system or place limits on the duration of uncontrolled venting. These types of
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-11
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Assessment Module: Kraft Pulping Operations
Section 4
requirements may be imposed through regulation, permit or enforcement-related action.
For example, Maine, Georgia and Oregon require that a back-up device or incineration unit
be available in the event adequate incineration in the primary device cannot be
accomplished due to breakdown, failure, servicing, overload, etc. Maine and Oregon also
limit the time frame for venting to the atmosphere during the switch from the primary
incineration device to the secondary incineration device (40 minutes for Maine and as soon
as possible but no more than 60 minutes for Oregon). Although the NSPS do not have
explicit requirements for back-up controls, the only excused excess emission periods under
NSPS would be allowable startup, shutdown or malfunction periods.
Monitoring, reporting and recordkeeping (MRR). The NSPS also establish
MRR requirements to assure compliance with the emission limits, and many States impose
similar requirements. The NSPS require use of Reference Method 16 for all performance
tests. In addition, a TRS continuous emission monitoring system (CEMS) may be required
to provide ongoing compliance data. If a CEMS is required, it is generally required only
downstream of the control device. In many cases, the control device for the TRS
emissions from the pulping area will be the lime kiln or power boilers, which are located
outside the pulping area.
Figure 4-5
NSPS TRS Monitoring, Reporting and
Recordkeeping Requirements for LVHC Units
Applicable
Limit
! If ppmv-
based limit
applies,
then...
! If
incinerator
temp.
standard
applies,
then...
Monitoring
! CEMS to monitor
and record TRS with
span of SOppmv,
together with a
CEMS to monitor
and record O2 by
volume on a dry
basis with a span of
20%. CEMS
located downstream
of control devices.
! Incinerator
temperature
monitoring applies
instead of TRS
CEMS. Accuracy
specification is
within ±1% of
temperature being
monitored.
Reporting
! Semiannual reporting of all
12-hour average TRS
concentrations > 5 ppmv by
volume, unless gases
combusted in an NSPS-
affected lime kiln or
recovery furnace (in which
case NSPS TRS limit for
those emission sources
applies).
! Semiannual reporting of all
5 -minute periods when
temperature < 1200°F
Recordkeeping
! Record all data and
calculate 1-hour
averages. Calculate
and record 12-hour
arithmetic mean
average TRS
concentrations
(corrected to 10% O2)
for the two consecutive
periods of each
operating day, based on
12 contiguous 1-hour
averages.
! Record all combustion
temperature monitoring
data, if applicable.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-12
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Section 4 Assessment Module: Kraft Pulping Operations
4.3.2.2 Cluster Rules Requirements
Basic emission limits. With I Tvi/^Tr. AI*U u*\ Z
. . . ., . „. _ . NOTE! Although control options are
the promulgation of the Cluster Rules, . ., , ...
. .c ° , ,, , r- similar, temperature and residence time
a significant new layer of regulation for _ . , , . . . *fnn°r
, °TrrT_ .,, , for stand alone incinerators are 1600 F
the LVHC gases will apply, even ,«-- , *• T.** ^rr ,
, i i 7 • 1 1 . and 0.75 seconds for MACT, as compared
though the basic control methods , .«nnol7 . nc ^ e ^cnc
. . , to 1200 F and 0.5 seconds for NSPS
remain the same (i.e. incineration in a L^^^^^^^^^^^^-.^^^^^^^^^^^^—
stand-alone thermal incinerator or in a
lime kiln, power boiler or recovery
boiler). Like the NSPS, the MACT requires that a kraft pulp mill control LVHC emission
points. However, the MACT standards apply to HAP emissions instead of TRS emissions.
Other key features of the basic MACT emission limits are:
Compliance options. The Cluster Rules provide four compliance options for
LVHC gases at kraft pulp mills:
98 percent reduction by weight (measured as total HAP or methanol),
Introduce gases with primary fuel or into flame zone of a boiler, lime kiln, or
recovery furnace,
! Route to a thermal oxidizer such that gases are subjected to 1600°F for 0.75
seconds, or
! Route to a thermal oxidizer such that the control device outlet concentration does
not exceed 20 ppmv (corrected to 10 percent O2, measured as total HAP or
methanol).
These alternatives, and the associated monitoring, reporting, and recordkeeping
requirements, are summarized in Figures 4-6 and 4-7, respectively.
Enclosures and closed-vent system. Regardless of the compliance option selected
for a particular facility, all LVHC equipment systems need to be enclosed and routed
through a closed-vent system to a control device. The basic requirements for these systems
and associated monitoring, reporting, and recordkeeping requirements are summarized in
Figures 4-8 and 4-9, respectively.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 4-13
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Assessment Module: Kraft Pulping Operations
Section 4
Figure 4-6
MACT Control Options for LVHC System (40 CFR 63.443)
LVHC system
(includes digester systems, turpentine recovery systems, evaporator systems, steam stripper systems,
and any other equipment serving the same function as any of these processes)
Route gases to a closed-
vent collection system
(see Figure 4-8)
98% reduction
by weight
(measured as
total HAP or
methanol)
Route to a thermal oxidizer
at one of the following
conditions:
Minimum
temperature of
1600° F and
0.75 seconds
residence time
Introduce vent stream with
primary fuel or into flame
zone of a boiler, lime kiln, or
recovery furnace
20 ppmv outlet
concentration
(corrected to 10%
O2, measured as
total HAP or
methanol)
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-14
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Section 4
Assessment Module: Kraft Pulping Operations
Figure 4-7
LVHC MACT Monitoring and Recordkeeping Requirements
Control Option
Lime kiln,
Recovery furnace,
Boiler
98% reduction by
weight standard
(controls other than
Thermal Oxidizer)
Thermal oxidizer
used to meet the 20
ppmv outlet HAP
concentration
standard
Thermal Oxidizer
used to meet the
98% reduction by
weight or a specific
design standard
(1600 °F and 0.75
seconds residence
time)
Monitoring
None required
Continuously record
operating parameters
from initial or
subsequent
performance test
Continuously measure
total HAP
concentration or
temperature
Continuously measure
fire box temperature
Reporting
N/A
Standard Part 63 reporting (i.e.,
semiannual EER and CMS performance
report, except if excess emissions occur,
then quarterly reports required)
Same standard Part 63 reporting as above
(for total HAP CMS performance and
exceedances)
! Same standard Part 63 reporting as
above (for temp, monitor performance
and exceedances)
! If meeting design standard, exceedance
value set at 1600°F, with site-specific
averaging time; if meeting 98%
reduction standard, exceedance value
and averaging time are both site-
specific (see § 63.453(n))
Recordkeeping
N/A
Standard Part 63
recordkeeping for
monitored
operating
parameters (i.e.,
both monitor
performance data
and measured data
averages)
Same standard Part
63 reqmts. as above
(for total HAP
CMS)
Same standard Part
63 reqmts. as above
(for temp. CMS)
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-15
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Assessment Module: Kraft Pulping Operations
Section 4
Figure 4-8
MACT Closed-vent System Requirements (40 CFR 63.450)
Closed-vent systems must meet all
of these requirements
Enclosures, openings, and hoods
Maintain negative pressure
and
if closed during initial
performance test, must be closed
during operation, except for
sampling, inspection,
maintenance, or repairs
Components operated at
positive pressure
Operate with no detectable
leaks (500 ppmv VOC above
background)
Bypass lines around control
devices
Seal and secure (e.g., car-seal)
or
If computer controlled, monitor
for presence of gas stream flow
at least once every 15 minutes
Figure 4-9
Enclosures and Closed-vent System MACT Monitoring and
Recordkeeping Requirements
Control Option
Enclosures and
Closed-vent System
Requirements apply
to all control
options
(See Figure 4-7)
Monitoring
! Every 30 days: Visual
inspection of all bypass
line valves or closure
mechanisms
! Initially and Annually.
Demonstrate no
detectable leaks at
positive pressure
components.
Demonstrate negative
pressure at enclosure
openings
Reporting
! None required for 30-day
visual inspections
! Initial and annual leak
checks/negative pressure
demonstrations are subject
to general Part 63
performance test reporting
requirements
Recordkeeping
! Prepare and maintain a
site specific inspection
plan
! Visual check records must
be kept because relevant
to documenting
compliance
(§63.10(b)(2)(vn))
! Performance test records
must be maintained
(§63.10(b)(2)(viii))
General exceptions. For the LVHC emission limits, the Cluster Rules also
establish an allowable percent of operating time (1%) during which HAP emission levels in
excess of the established limit shall not be considered to be a violation of the standard.
Periods of excess emissions could include uncontrolled venting to the atmosphere or a
monitored fire box temperature lower than the temperature established during the initial
performance test (or <1600° if the source is complying with the incinerator design
standard). The 1% allowance is in addition to excused periods under the startup,
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-16
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Section 4
Assessment Module: Kraft Pulping Operations
shutdown or malfunction provisions, and is calculated by dividing the time of excess
emissions by the total process operating time in a semiannual reporting period. Examples
of combustion unit downtime are listed in Figure 4-10. Note that these excess emissions
must be evaluated in light of overlapping State TRS requirements, such as the Maine and
Oregon examples discussed in Section 4.3.2.1, as well as the NSPS which excludes only
allowable startup, shutdown and malfunction periods. Even though 1% of excess HAP
emissions may be exempt under the MACT requirements, these periods of excess emissions
must still comply with NSPS TRS requirements, and any applicable State requirements.
Figure 4-10
Common Causes of Downtime in Lime Kilns and Power Boilers
Combustion Unit
Lime Kiln
Power Boiler
Cause of Downtime
Flame-out
Calcium oxide ring formation in kiln
Grate plugging in lime product
removal system
Mud mat formation problems with
vacuum drum filter; loss of lime mud
feed
Fuel feeder plugging
Rapid decline in steam demand (e.g..
paper break on the paper machine)
that results in fuel input reduction
Typical Duration of Downtime
5 to 30 minutes
(with backup combustor)
Less than 15 minutes
(with backup combustor)
Less than 15 minutes
(with backup combustor)
20 minutes to 2 hours
1 5 to 60 minutes
1 5 to 60 minutes
Back-up control requirements. There are no explicit back-up control MACT
requirements for the LVHC emission limits. However, the only excused excess emission
periods would be those periods that are specifically designated in the startup, shutdown, or
malfunction plan developed under § 63.6(e)(3), or those that are less than the allowable
excess periods.
Monitoring, reporting, and recordkeeping (MRR). The MACT establishes
MRR requirements to assure continuous compliance with the emission limits. All LVHC
systems must meet the MRR requirements for enclosures and closed-vent systems (Figure
4-9) and the appropriate MRR for the control option selected (Figure 4-7). The MACT
generally relies on parameter monitoring, although a total HAP continuous monitoring
system (CMS) is required if the mill elects to meet an outlet concentration HAP limit.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-17
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Assessment Module: Kraft Pulping Operations Section 4
4.3.3 LVHC Air Inspection Techniques
NOTE! Inspection steps for HVLC and
LVHC gas collection systems are similar,
and this section should be read as
generally applicable to both systems.
Because of the significant air
emission sources outside of the pulping
area (including the lime kiln, recovery
boiler and power boilers), the pulping
equipment systems in the past often
have not been a high priority for
committing on-site inspection resources. However, the Cluster Rules requirements can be
expected to make the LVHC gas collection systems and other pulping department emission
sources a higher priority. For initial compliance, the appropriate steps to follow for coming
into compliance with the Cluster Rules are outlined extensively in the OAQPS Cluster
Rules Implementation Guideline, including a discussion of applicability and timing issues,
as well as initial compliance checklists. This document, therefore, focuses on on-site
inspections that will be conducted after initial compliance has been demonstrated and the
appropriate permit conditions have been included to address the Cluster Rules.
4.3.3.1 Pre-inspection Steps
As discussed in Chapter 3, there are a number of steps that should be taken
routinely prior to conducting an actual on-site inspection, including file (especially permit)
reviews. As part of conducting the file review and planning the on-site inspection, the
inspector should consider at least the following items:
Process diagrams. Obtain a simplified diagram of the LVHC vent gas collection
system(s) and note what control(s) are employed. This type of diagram may be available in
the Part 70 operating permits file if submitted with the application.
Use of controls located in other process areas. If the facility combusts the
LVHC gases in a lime kiln, power boilers or recovery boiler, the inspection of the pulping
area will be abbreviated. However, the inspector will have to check on the continuous use
of these combustion process units for TRS/HAP combustion control (or that other
permitted backup controls were used during combustion unit downtime periods) when
conducting the inspection of the chemical recovery and power boiler areas of the mill. Any
downtime will have to be checked against required use of backup controls (if applicable)
and/or permitted levels of uncontrolled venting.
Evaluation of periodic monitoring reports. If a dedicated incinerator is used for
TRS and/or HAP control, incinerator temperature data will likely be recorded and
submitted in a semiannual (or quarterly) excess emission report (EER) of excursions from
required minimum temperature requirements. Review reports submitted since the last
inspection in order to prioritize the need for follow-up while on-site. If TRS CEMS or
total HAP CMS data are available instead of temperature data for the incinerator, evaluate
the CEMS data in the same manner.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 4-18
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Section 4 Assessment Module: Kraft Pulping Operations
The inspector should confirm that any periods of excess emissions, including
bypass/uncontrolled venting, indicated in the reports are within regulatory limits. If not,
the inspector may need to evaluate on-site records that document the reasons for the
excess emissions and/or uncontrolled venting. Under the Cluster Rules, records must be
kept of all bypass periods. The review will be necessary to evaluate claims of allowable
excursions, such as those from startup, shutdown or malfunction periods. For MACT
requirements under the Cluster Rules, these types of claims must be evaluated in
connection with the facility's startup, shutdown and malfunction plan required under 40
CFR63.8.
Evaluation of episodic malfunction reports. The inspector should review
malfunction/upset reports since the last inspection, if available. If the reports identify
corrective actions to be taken by the source, note the need to verify during the on-site
inspection that the corrective steps were actually taken and that they resolved the problem.
Also, the inspector can compare claims of malfunction periods on EERs with the
duration and timing of malfunction periods indicated on malfunction reports. If a
malfunction report is required for all or some specified subset(s) of malfunctions, note any
discrepancies between the malfunction reports submitted and the claimed excess emissions
in an EER. Significant discrepancies signify either errors in EER or malfunction reporting
that should be addressed with the facility either as part of the inspection or by agency
compliance staff responsible for processing periodic and episodic reports.
4.3.3.2 On-site Inspection Steps
The appropriate on-site inspection steps must be tailored to the objectives of the
inspection and the priority given to the pulping area in a particular inspection. The possible
steps for a routine Level 2 inspection include:
Permit verification. One objective of a standard Level 2 air inspection will be to
verify that the permit includes all the appropriate equipment. As noted above, the OAQPS
Cluster Rules Implementation Guideline contains a detailed discussion of the applicability
of the Cluster Rules requirements. Prior to the inspection, the permit should be reviewed
to determine what conditions apply to the pulping process. Depending on the nature of the
specific permit conditions, the inspector should evaluate a number of potential issues to
verify that pulping operations remain consistent with permit requirements, including:
! Are all emissions units properly identified in the permit?
! Have any modifications (including production increases) occurred that could trigger
NSPS or NSR? Note that minor modifications in the pulping area may
debottleneck downstream processes (such as recovery boiler operations). Evaluate
whether the debottlenecking creates potential for a significant emissions increase in
other areas of the mill that could trigger PSD/major NSR review. One resource for
documenting process modifications that have occurred in the pulping (and chemical
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 4-19
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Assessment Module: Kraft Pulping Operations Section 4
recovery area) will be the Best Management Practices (BMP) Plan required under
the Clean Water Act — see Section 4.6.2 and 4.6.3 for further discussion of those
requirements.
I
Are TRS/HAP control methods properly identified?
! Compare the basic process/design information with conditions in the permit to
verify the accuracy of the information in the permit and to support subsequent
assessment activities.
! Are permit terms and conditions properly linked to the emissions unit?
Evaluation of limits on uncontrolled releases. Regardless of the control option
selected, one key issue is to determine that the source is satisfying the limits on
uncontrolled venting of LVHC gases. Because uncontrolled venting will cause even higher
emissions than reduced control efficiency, assuring that such episodes are kept to a
minimum should be a focal point of the inspection in the pulping area. Uncontrolled
venting can occur because either the combustion source/control device for the gases is not
operating or because of process upsets that occur within the pulping area. In either case,
conduct a review of available records to evaluate that uncontrolled venting meets specific
regulatory limits and is also consistent with good air pollution control practices.
Under the Cluster Rules, the M/-^^, ^ ., f „ <_ .f
r. .ri .„ , .^ j NOTE! Consider follow-up assessment if
facility will have monitor records „ , . .
. ,. . . ,,,, . . uncontrolled venting or combustion
indicating the presence of flow through x , , f! • , ,
,. ° iU A ij • temperature below the excursion level
any line that bypasses a control device , .,„, f
,,. , . , , r- exceed 1% of operating time.
vent (this does not include safety j^^^^^^^^i^^^^^^^^^^^^^^
pressure relief valves). For modern
mills, these records likely will be
accessible through the facility's distributed control system (DCS) or similar automated data
handling system. This information can be used to calculate the total duration of
uncontrolled venting to document compliance with restrictions on those events. Although
generated for MACT compliance purposes, this information can be used for TRS
compliance evaluations as well.
The total duration of uncontrolled venting should be calculated for a period
consistent with the reporting period for the facility (quarterly or semiannually) and
compared against total operating time for that same period. If the total duration exceeds
1% of the total operating time, further evaluation of the causes of the uncontrolled venting
is warranted. Under the Cluster Rules, only uncontrolled venting events caused by
allowable startup, shutdown or malfunction (SSM) periods are excluded from calculating
compliance with the 1% limit. For TRS control, the NSPS do not include an excess
emission allowance (except for recovery furnaces) and State TRS provisions for any
excused excess emissions will vary.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 4-20
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Section 4
Assessment Module: Kraft Pulping Operations
If, based on the initial records review, a follow-up investigation appears warranted,
the likely root cause concerns will be shutdown of the control device/combustion unit used
for control or pulping area process upsets. Where the source relies on a process
combustion unit such as the lime kiln for controlling LVHC emissions, excessive downtime
of the combustion unit may lead to compliance problems unless the facility has a permitted
backup control option. If control device availability is not the cause, then process upsets,
such as the following, should be considered:6
! Liquor carryover that causes pluggage in the digester relief line. The pressure
build-up in the digester could lead to emergency bypass relief.
! Simultaneous digester blows could cause condenser and LVHC gas collection
system overload, leading to emergency bypass venting.
The inspector should seek clarification from the facility on the cause of excessive
uncontrolled venting and seek appropriate corrective action to address the problem. If
uncontrolled venting persists above the 1% Cluster Rules limit as a result of claimed SSM
conditions, the inspector should carefully review the facility's SSM plan required by the
MACT general provisions (see § 63.6(e)(3)) to assure that the plan is adequate to minimize
emissions consistent with good air pollution control practices. For this type of evaluation,
consider conducting a comparison of similar mills to determine what additional efforts may
be appropriate.
Evaluation of proper operation of control equipment. A Level 2 inspection will
focus on assuring that the control equipment is being properly operated and maintained so
that the facility continues to achieve compliance with the applicable emission limits. The
proper steps for this phase of the inspection will depend on the control measures used for
TRS and HAP control, which will generally include enclosures of emissions points and
conveyance of the LVHC gases in a closed-vent system that are then incinerated in process
combustion units or a dedicated thermal incinerator.
Enclosures and closed-vent
system. As part of the Cluster Rules,
facilities will have to enclose LVHC
emission points and convey the gases
through a closed-vent system. The
Cluster Rules require the facility to
develop a self-inspection plan,
including a series of periodic checks, to
assure that this system continues to
operate properly. Review the records
of these activities to assure that the
required checks are occurring and that
the source has taken any corrective
action steps necessary to remain in
Checks of Enclosures/Closed-vent
Systems for Suspected Problems with
Facility Self-Inspections
Visual inspections (ductwork, piping,
valves, etc.)
Leak checks using Method 21 analyzer
(positive pressure components)
Pressure checks using portable
pressure gauge, etc. (negative pressure
enclosure/hood openings)
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-21
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Assessment Module: Kraft Pulping Operations Section 4
compliance. If a problem is detected or suspected, the inspector may want to consider
conducting the types of checks that the facility is supposed to undertake as part of its self-
inspection program.
Process combustion sources. Where the controls used are the lime kiln, power
boilers or recovery furnace, the Level 2 inspection within the pulping area is generally
inapplicable. See Sections 5 (recovery process) and 8 (power boilers) of this manual for
available inspection procedures applicable to these process combustion units. Generally,
these combustion units are more than adequately sized and designed for control of TRS or
HAP emissions from LVHC gases and thus any increased emission problems likely stem
from combustion problems within the combustion unit itself.
Stand-alone incinerator. For a
stand-alone thermal incinerator, the
evaluation will focus first on the
reported monitoring data for monitors
required by rule, which may include
temperature monitors or a TRS CEMS.
Basic Thermal Incinerator Assessment
Steps
Check monitor for operating condition,
including most recent calibration
The Cluster Rules also provide for use recor s
of a total HAP continuous monitoring
system, if such a system becomes
available in the future. During the on-
• I •
site inspection, the inspector should: ase me
1 As needed, use portable equipment to
Evaluate required monitoring data
(temp., TRS, or HAP); check against
required limits and for shifts from
evaluate temperature and THC outlet
concentration against baseline
! Evaluate the operating
condition of the monitor. For a
CEMS or CMS, the daily
calibration and periodic QA/QC
checks provide a good check. For temperature monitors, there likely will be no
QA/QC records or only limited information. Interviews with plant personnel may
indicate what procedures the mill uses to verify proper operation of the temperature
monitor.
! Evaluate required monitoring data against permitted levels. Collect and evaluate
current data for the period of the inspection. In addition, if they are readily
available, review summaries of recent data such as the past 24 hours or week. The
inspector may want to inquire about the ability to analyze data trends using the
facility's DCS, especially if there are reasons to believe that the controls may not be
functioning effectively.
! Conduct baseline checks of critical parameter data. For thermal incinerators, an
evaluation of both temperature and outlet total hydrocarbon (THC) concentration
data is recommended as part of a Level 2 inspection.10'11 If these parameters are
not covered by required monitoring, a portable gauge or analyzer may be necessary.
A comparison of temperature data to prior baseline data allows for an evaluation of
whether temperatures are moving in an acceptable range. A comparison of THC
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 4-22
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Section 4
Assessment Module: Kraft Pulping Operations
outlet concentration at the time of the inspection with previously collected data will
allow a baseline comparison to determine if there are increasing organic emissions,
even though the temperature data do not indicate a problem. In this case, the THC
concentrations would be analyzed to indicate potential control problems, not as a
direct surrogate for the regulated HAPs that make up part of the total THC
emissions from the equipment systems.
! Conduct follow-up assessments of incinerator performance as needed. If the
baseline conditions have shifted significantly, then a follow-up assessment of the
internal elements of the incinerator may be appropriate. However, the follow-up
procedures generally require internal inspections, and thus are generally performed
only by mill personnel when the control system is off-line. Internal checks should
focus on finding any unusual conditions, such as leakage through the primary heat
exchanger, leakage of air into the combustion chamber, or impingement of burner
flame on the refractory.10
Follow-up assessment for suspected process problems. If the inspection of the
closed vent system and control device fails to reveal problems but an emission problem is
still suspected, an evaluation of process conditions that could lead to increased emissions
may be necessary. Although this type of process-oriented follow-up inspection in the
pulping area would be unusual given the nature of the operations and the control methods
used, Figures 4-11 through 4-14 outline several examples of process upset conditions that
could lead to compliance problems by increasing uncontrolled emission rates.
Figure 4-11
Potential Upsets and Malfunctions in the Digester Relief
and Turpentine Recovery System6
Upset/Malfunction
Liquor carryover
Low water flow rate to turpentine
condenser
Effect
Digester relief line pluggage
Turpentine condenser pluggage or
fouling
Increased condenser water
temperature
Result
Pressure build-up in digester which
may lead to following events: (1)
emergency bypass relief to
atmosphere; (2) premature digester
blow (may result in overload of blow
tank or accumulator)
Reduced condenser heat transfer
yielding increased TRS and organics
uncontrolled emissions
Increased uncontrolled TRS and
organics emissions due to larger
portion of gas left un-condensed
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-23
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Assessment Module: Kraft Pulping Operations
Section 4
Figure 4-11 (cont.)
Potential Upsets and Malfunctions in the Digester Relief
and Turpentine Recovery System
Upset/Malfunction
Failure to close blow valve after
blow
Effect
Fouling of blow line
Result
Pressure build-up during blowing,
increasing digester blow volume and
uncontrolled TRS, organics
emissions
Figure 4-12
Potential Upsets and Malfunctions in the Blow Tank and Accumulator6
Malfunction
Fiber or liquor carryover and fouling
of condensers
Low water flow rate to condensers or
hot water accumulator
Effect
Reduced heat transfer and loss of
condensate
Increased condenser water
temperature
Result
Increased uncontrolled TRS and
organics emissions due to larger
blow gas volume
Increased uncontrolled TRS and
organics emissions due to larger
portion of gas left un-condensed
Figure 4-13
Potential Upsets and Malfunctions in Multiple Effect Evaporators6
Malfunction
Fouling, scaling, and deposits in
evaporator effects
Air leaks in evaporator body
Low condenser water flow rate
High inlet condenser water temperature
Reduced scrubber water flow rate
Increased scrubber gas volume
Effect
Reduced evaporator efficiency
Larger NCG volume
Increased condenser outlet water
temperature
Increased condenser outlet water
temperature
Reduced liquor-to-gas ratio, lower
adsorption rate
Reduced liquor-to-gas ratio, lower
adsorption rate
Result
Results affect recovery boiler
emissions [See Section 5]
Increased uncontrolled TRS and
organics emissions due to increased
condenser load
Increased uncontrolled TRS and
organics emissions due to larger
portion of gas left un-condensed
Increased uncontrolled TRS and
organics emissions due to larger
portion of gas left un-condensed
Increased uncontrolled TRS and
organics emissions due to decreased
removal efficiency
Increased uncontrolled TRS and
organics emissions due to decreased
removal efficiency
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-24
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Section 4
Assessment Module: Kraft Pulping Operations
Figure 4-13 (cont.)
Potential Upsets and Malfunctions in Multiple Effect Evaporators
Malfunction
Scrubber packing flow channeling
Liquor foaming
Entrainment of soap in liquor
Effect
Reduced liquor-to-gas contact,
reduced adsorption
Liquor carryover and reduced
evaporator efficiency, lower black
liquor solids
Foaming, liquor carryover, and
reduced evaporator efficiency,
fouling of evaporators, lower black
liquor solids
Result
Increased uncontrolled TRS and
organics emissions due to decreased
removal efficiency
Results affect recovery boiler
emissions [See Section 5]
Results affect recovery boiler
emissions [See Section 5]
Figure 4-14
Potential Upsets and Malfunctions in the Closed-Vent Gas Collection System6
Malfunction
Excessive flow variations
Operation between lower and
upper explosive limits
Low gas flow velocity
Entrained moisture
Effect
Poor performance of collection
system
Operation below flame propagation
velocity
Flame blowout, reduced flame
temperature, corrosion of gas moving
equipment
Result
Fugitive TRS and organics emissions,
increased emissions due to
incomplete combustion
Potential for explosion
Potential for explosion and/or fire
Increased uncontrolled TRS and
organics emissions as a result of
incomplete combustion and potential
for explosion
4.3.4 LVHC EPCRA Issues
General concerns. The basic
regulatory requirements for EPCRA
are not process-specific but rather
apply on a facility-wide basis.
Appendix D to this manual provides an
overview of these regulatory
requirements.
NOTE! See Appendix D for overview of
EPCRA regulations and basic assessment
procedures.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-25
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Assessment Module: Kraft Pulping Operations Section 4
For the LVHC air emission points in the pulping area, the key EPCRA issues will
be to quantify releases of applicable toxic chemicals in the annual Toxic Release Inventory
(TRI) report (known as the "Form R" report), and to comply with emergency reporting
requirements. The emergency reporting requirements apply under both EPCRA and
CERCLA. The releases subject to these emergency reporting requirements are releases
that are not federally permitted and that exceed certain reportable quantities. For certain
releases that are "continuous" and "stable in quantity and rate," the mill may be able to use
special reporting options so that a notice is not required after each such release. See the
discussion of continuous releases in Appendix D for further detail on the differences
between standard emergency reporting and reporting of continuous releases.
Air releases from LVHC (or HVLC) points could be subject to EPCRA and
CERCLA emergency reporting requirements. Methanol has a reportable quantity threshold
of 5,000 pounds per 24-hour period, while the TRS compounds hydrogen sulfide and
methyl mercaptan each have a reportable quantity threshold of 100 pounds per 24-hour
period.
The determination of what constitutes a "federally permitted release" can be
complex. However, it is important to note that if the mill as a matter of normal operations
emits an applicable pollutant in amounts that exceed the reportable quantity and there is no
emission limit established for the pollutant, then the emergency reporting provisions likely
apply. For instance, a mill should file appropriate emergency reports if no TRS emission
limit currently applies to the LVHC (or HVLC) emission points, and the mill normally
emits more than 100 pounds of hydrogen sulfide or methyl mercaptan in a 24-hour period
from the unregulated emission points at the mill. In this circumstance, the reduced
continuous release reporting options likely are available, as discussed in Appendix D.
Inspection considerations. The EPCRA compliance assessment generally will
focus initially on a records review. The inspector should review the following materials:
! Emergency preparedness information. These obligations are not process-specific,
and thus the basic assessment considerations are covered for all facility operations
in Appendix D to this manual.
! TRI Form R. Check to ensure that the form is on file and that the source has
adequately considered releases associated with the LVHC emission points. Also,
ask to see the estimation technique being used. If the estimation technique involves
an assumed reduction efficiency for control methods, make sure that the assumed
efficiency is consistent with the overall efficiency that the mill is achieving. The
overall assumed efficiency should account for any excess emission releases
(including uncontrolled venting) in a manner consistent with the actual percent of
operating time such releases occur. Uncontrolled emission episodes or periods of
reduced control efficiency — even if allowed under Clean Air Act regulations — can
have a significant impact on the estimate of total releases. This is especially
important for LVHC and other pulping process emission points because there are
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does not alter any statutory or regulatory requirements. Page 4-26
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Section 4
Assessment Module: Kraft Pulping Operations
often built-in allowances for anticipated uncontrolled venting for at least some
percentage of operating time.
! Emergency notifications. Request documentation that the mill has filed all required
notices.
If an agency air inspector plans to screen for EPCRA compliance during an air
inspection, the inspector should confirm the necessary information with the facility contact
during the opening conference or just in advance of the closing conference. For an
announced inspection, the inspector should ask the source to have ready EPCRA-related
documentation so that this screening check can be performed without interrupting the main
focus of the inspection. A screening checklist is included as part of the example inspection
form in Appendix E.
In addition to a screening-type records review inspection, an EPCRA inspector may
want to conduct further assessments to identify potential compliance concerns with
emergency notification requirements. As one technique, the inspector first can check
malfunction reports and citizen complaints since the previous inspection. The inspector
then should cross-check those incidents with notification records identified in EPA's ERNS
database, records on file with State and local emergency officials, or records requested
from the mill. If this type of investigation identifies episodes of abnormal emissions in
which no notification was provided, further investigation may be required to determine if
reportable quantity thresholds were exceeded.
4.4 HVLC Gas Collection System
4.4.1 HVLC Emission Points
The primary HVLC emission
points are the washing, knotter, screen
and decker systems, weak liquor
storage tanks, and, where applicable,
oxygen delignification systems. These
points are identified in Figure 4-15.
Because rotary vacuum washers are the
most common, Figure 4-15 depicts the
use of this washer type. The rotary
vacuum washers are hooded and not
fully enclosed. Other types, such as a
diffusion washer or horizontal belt
washer are enclosed or have limited
exposure to the ambient air. These
more enclosed washer types will tend
Key Features for HVLC Gas Collection
! Similar to LVHC except air emission
points historically less regulated
! Cluster Rules add significant new
requirements but generally rely on
same thermal incineration control
options as LVHC gas collection
! Clean Condensate Alternative primary
difference for air emission compliance
assessments
! EPCRA obligations similar to LVHC
gas collection
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-27
-------
Figure 4-15
Flow Diagram of HVLC System
=
VI
•a
Wood
Blow
Tank
Blow
Heat
Accumulator
HVLC System Components
Washer
<^ci' £
^ B.^
ft E-~i (JQ
BOO
o'
Pulp Washing System
Knotter System and
Screening System
Decker
Pulp
o
=
o
a
a
5'
ro
O
a
o
=
Weak
Black
Liquor
Storage
Tank
MEE
Strong Black Liquor
to Recovery Boiler
o
=
Equipment enclosed by the dashed line are part of the HVLC system. The remaining equipment are components of the LVHC system.
-------
Section 4
Assessment Module: Kraft Pulping Operations
to have lower flow rates with higher pollutant concentrations. As with the LVHC emission
points, the primary emissions of concern are TRS and methanol, although the HVLC points
in most cases have lower emission rates than the LVHC emission points.
4.4.2 HVLC Air Regulations
4.4.2.1 TRS Requirements
NOTE! To the extent the NSPS apply,
the same monitoring, reporting and
recordkeeping requirements that apply to
LVHC emission points also apply to the
HVLC emission points.
The TRS requirements for
HVLC points are similar to the
requirements for LVHC points where
the regulations apply. However, many
of the HVLC points are not subject to
TRS regulations. Figure 4-16
summarizes the basic requirements ^^^^^^^^^^^^~^^^^^^^^^^^^~
applicable to the HVLC points. As
noted in Figure 4-16, new and modified (post - 9/24/76) brown stock washers (including
associated knotters, filtrate tanks and vacuum pumps) are regulated by the NSPS.
Figure 4-16
HVLC Emission Points: Federal and State TRS Emission Limits
Equipment System
Brown Stock Washers (NSPS
definition includes knotters,
filtrate tanks, and vacuum
pumps)
TRS Emission Limits
5 ppm (dry basis)
0. 156 Ib/ton, 24 hour average
0.2 Ib/TADP
0.5 Ib/TADP
Incineration in lime kiln or recovery
furnace subject to NSPS TRS limits
Incineration at 1200° F for 0.5
seconds
Applicable Regulation
NSPS1, CA(BAAQMD(15
ppm), SHAAQMD), ME
OR2
CA (MENAQMD, NCUAQMD,
NSOAPCD), ID3, NM4
CA (BUTAPCD, COLAPCD,
FRAQMD)
NSPS
NSPS5, CA (MENAQMD,
NCUAQMD, NSOAPCD)
1 Limit not applicable if Administrator determines, on a case-by-case basis, incineration is
technologically/economically unfeasible.
2 Limit for combined emissions from brown stock washers and black liquor oxidation vents.
3 Limit for combined emissions from brown stock washers, black liquor oxidation vents and condensate
stripper.
4 Limit for combined operations at a mill.
5 Allowed only if gases subject to NSPS combined with other waste gases.
The NSPS contain an exception for washers if the mill can document that
controlling the emissions is technically or economically infeasible. As an example, an
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 4-29
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Assessment Module: Kraft Pulping Operations Section 4
exception was granted by EPA Region IV in 1997 where the lowest estimated control cost
was over $14,000/ton of TRS (See ADI Control Number 9700087). The practical effect
of this exemption should be minimal in the future, however, because the Cluster Rules (as
discussed below) require control of these washers without a similar exception. Because the
control options are similar for the TRS and HAP compounds, it appears unlikely that —
once compliance with the Cluster Rules HVLC limits is required - a facility will be able to
document economic or technical infeasibility when the cost and technical burdens of
installing and operating the controls are already being incurred to satisfy the Cluster Rules.
Finally, EPA's TRS emission guidelines under section 11 l(d) of the Clean Air Act
do not cover brown stock washers or other HVLC points. Consequently, only a few State
or local jurisdictions have TRS requirements for HVLC points. Moreover, screens,
deckers, weak black liquor storage tanks, and oxygen delignification points are not covered
by the NSPS or generally by these State rules.
4.4.2.2 Cluster Rules Requirements
Basic emission limits. Although the TRS requirements for HVLC emission points
apply only to brown stock washer systems, the Cluster Rules HAP requirements apply to
additional HVLC emission points. Which points are subject to HAP limits and when
compliance is required will depend on whether the units involved are new or existing
sources. Once applicability and compliance dates are determined, the HVLC sources
generally are subject to the same basic control options as the LVHC sources. These
elements of the HVLC requirements are summarized as follows:
Applicability and compliance
dates. The HVLC system is the only
part of the mill that has more stringent
MACT control requirements for new
HVLC System Compliance Dates
Existing sources: April 15, 2006
., ,, • .• T • New sources: June 15,1998 or date of
sources than tor existing sources. In , . , . ,
,,. , , « „. startup, whichever is later
this context, a new source is an r'
HVLC system at a pulping system or
additional pulping line that is
constructed or reconstructed after December 17, 1993. The MACT control requirements
for new sources apply to additional emission points (see Figure 4-17) and require
compliance by an earlier date (see accompanying text box). The compliance options,
however, are the same for new and existing sources.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 4-30
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Section 4 Assessment Module: Kraft Pulping Operations
Figure 4-17
HVLC Emission Points that are Subject to the MACT Standard
Existing Sources
! Pulp washing system
! Oxygen delignification system
! Decker systems that use any process water other than fresh water or papermachine Whitewater; or any
process water with a concentration of HAPs greater than 400 ppm
! Knotter systems with HAP emissions > 0.05 kg/Mg oven dry pulp (ODP)
! Screen systems with HAP emissions > 0.1 kg/Mg ODP
! Knotter and screen systems with combined HAP emissions > 0.15 kg/Mg ODP
New Sources
Existing sources plus all...
! Decker systems
! Screen systems
! Knotter systems
! Weak liquor storage tank vents
Compliance options. Although the applicability issues are different for HVLC and
LVHC sources, the basic compliance options for HVLC sources are the same as those for
LVHC sources:
98 percent reduction by weight M^r™, „ • -rnTT ^ i-
f , ITT AT, NOTE! Basic HVLC compliance options
(measured as total HAP or xl T,7TT^ ,.
, ., are the same as LVHC compliance
T , • i • options, except for Clean Condensate
Introduce gases with primary . ,x ' v x.
,, . . ° c Alternative option.
fuel or into flame zone or a
boiler, lime kiln, or recovery
furnace,
! Route to a thermal oxidizer such that gases are subjected to 1600°F for 0.75
second, or
! Route to a thermal oxidizer such that the control device outlet concentration does
not exceed 20 ppmv (corrected to 10 percent O2, measured as total HAP or
methanol)
If the gases are subjected to 1600°F for 0.75 second in a thermal oxidizer, then
MACT and NSPS requirements are satisfied simultaneously. For all other MACT
compliance options, mills must demonstrate meeting NSPS in addition to the MACT
requirements.
Enclosures and closed-vent system. As with LVHC systems, all HVLC equipment
systems must be enclosed and routed through a closed-vent system to a control device.
Due to concerns about explosion hazards, the HVLC gases are not mixed with LVHC vent
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Assessment Module: Kraft Pulping Operations Section 4
gases, although the two vent stream gases could be sent to the same control device (i.e.,
power boiler). The basic MACT requirements for closed-vent systems are summarized
earlier in this section in Figure 4-8. Note that equipment systems that are included in the
clean condensate alternative are exempt from the enclosure and closed-vent system
requirements.
General exceptions. The MACT standards also establish an allowable percent of
operating time during which HVLC HAP emission levels in excess of the established limit
shall not be considered to be a violation of the standard. However, for HVLC gases,
periods of excess emissions may not exceed 4% of operating time, compared to 1% for
LVHC emissions. Also note that when HVLC and LVHC gases are controlled by the same
control device, periods of excess emissions may not exceed 4% of operating time. All
other provisions about excess HVLC emissions are the same as those for LVHC emissions
(see the General Exceptions discussion in Section 4.3.2.2).
Back-up control requirements. As with the LVHC emission limits, there are no
explicit back-up control MACT requirements for the HVLC emission limits. Refer to the
back-up control requirements discussion in Section 4.3.2.2 for additional information.
Monitoring, reporting, and recordkeeping (MRR). These requirements are the
same as those for the LVHC system. All HVLC systems must meet the MRR requirements
for enclosures and closed-vent systems (Table 4-9) and the appropriate MRR for the
control option selected (Table 4-7), unless the equipment is included in the clean
condensate alternative.
Alternative compliance XT™™ ™ ^ * i* *• •
. _,, , , NOTE! Clean condensate alternative is
approach: The clean condensate ., ,, , ,. TT.7T „ , T ,7TT^
!T x. ,„ „ ., „. . available only for HVLC - not LVHC -
alternative (CCA). The clean
, ^ ,_. ' ,._ „__ emission points.
condensate alternative (40 CFR I
63.447) provides a pollution prevention
alternative to control requirements
discussed in the Basic emission limits section above. In general, the CCA allows facilities
to meet HVLC system total HAP reduction requirements by reducing the HAP levels of
condensates used as process feed water in the pulping, bleaching, causticizing, and
papermaking systems. The CCA has the following key features:
! Any technology can be used to achieve HAP emission reductions. However, the
facility must demonstrate that the HAP emission reductions using the CCA are
equal to or greater than those emission reductions that would be achieved through
compliance with the kraft pulping HVLC system standards (98% by weight of total
HAP).
! The CCA may be used either for complete or partial fulfillment of the kraft pulping
HVLC system standards. This option may be chosen for individual vents or a subset
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 4-32
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Section 4 Assessment Module: Kraft Pulping Operations
of HVLC vents, and the remaining HVLC vents can comply with the basic pulping
vent control requirements described above.
! LVHC emission points are not eligible for participation in the CCA.
! The control strategy using the CCA will vary between mills, depending on mill
configuration and emission points selected. Thus, the monitoring and reporting
requirements for the CCA are also mill-specific, and must meet the approval of the
Administrator.
4.4.3 HVLC Air Inspection Techniques
To the extent that the HVLC I M^™. v .. ^~- 1- *~f
, , ,, . NOTE! Follow the inspection steps for
points are regulated, most of the T^TT,- n ^ j v *• * * *
°f ^ , LVHC gas collection under Section 4.3.3.
requirements tor these points are .. . . _ ,TC1T,
... . TTrrT/^ • T,, r- Also use this section for NSR concerns
similar to the LVHC points. Therefore, ,-f., ^^A .. ,f TT^T ^
^ and if the CCA option is used for HVLC
compliance under the Cluster Rules.
for most aspects of the inspection of
the HVLC points, the inspection
procedures should be the same as for
the LVHC points (see Section 4.3.3).
In addition, the inspector should consider the following issues:
NSR concerns. The increased control of the HVLC points (and the condensates
discussed in Section 4.5) to reduce HAP emissions could increase SO2 and NOX emissions
from the combustion sources used to control the HVLC gases. These increases could be
significant enough to trigger NSR permit requirements. The EPA has indicated that
generally these increases should not be subject to major NSR review under EPA's pollution
control project guidance, although State minor NSR programs would still apply (see 63 FR
18531-32 for further discussion of this issue). However, it is within the State agency's
discretion to require major NSR if the State agency believes that the net effect of the
controls is not "environmentally beneficial." For instance, the State agency must consider
whether the increases in SO2 or NOX will cause or contribute to a NAAQS violation or a
violation of a PSD increment, or would adversely affect visibility or other air quality related
values in a Class I area.
The facility should check with the State agency as to the NSR permit implications
of new controls used to comply with MACT requirements for HVLC emissions. As part of
the inspector's permit verification for the HVLC points, the inspector should confirm
whether NSR permitting is applicable as a result of controls installed for MACT
compliance, and if so whether it has been conducted.
CCA options. If a facility elects to implement the clean condensate alternative to
satisfy the MACT requirements, then there may be additional procedures necessary to
assess compliance with this option. The CCA option will be implemented on a mill-specific
basis, including the appropriate monitoring, reporting and recordkeeping procedures.
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Assessment Module: Kraft Pulping Operations Section 4
Therefore, the inspection procedures to determine compliance will also be highly mill-
specific. If this option is selected, careful pre-inspection planning will be essential in order
to conduct an accurate assessment. The basic assessment steps should involve:
! Careful pre-inspection review of the particular elements of the mill's pollution
prevention procedures that comprise its CCA implementation strategy, as well as
the MRR procedures required to document compliance with the CCA.
! Interviews with mill operators to evaluate awareness of the pollution prevention
procedures required and the extent to which the mill's standard operating
procedures have incorporated these requirements.
! On-site review of process and/or control records that document compliance with
the mill-specific requirements for CCA implementation.
4.4.4 HVLC EPCRA Issues
For EPCRA, the same issues generally will be present for HVLC points as were
present for LVHC points. See Appendix D for a general discussion of the EPCRA
regulatory requirements and basic EPCRA inspection considerations. Also see Section
4.3.4 for a discussion of EPCRA issues for LVHC points.
4.5 Condensates
4.5.1 Condensate Discharge Points
Condensates in the pulping area
contain organic and sulfur compounds
that may be emitted to the air. Pulping
process Condensates are considered to
Key Features for Pulping Condensates
! Regulatory concerns limited primarily
, TTAT1 . . ,. ,,, , to air compliance issues
be any HAP-contaming liquid that . f .
. ,, . 7. . . ! MACT HAP requirements apply, not
results from the contact of water with xrcuc/c* * TDCI- v
NSPS/State TRS limits
Biological treatment option may
involve evaluating controls in
wastewater treatment process area
organic compounds in the pulping
process (in other words, condensed
steam from pulping process vent
gases). Condensates from the digester,
evaporator, and turpentine recovery
systems contain the highest loadings of
these compounds, with evaporator condensate representing the major volume of pulping
area condensate flow. The LVHC and HVLC gas collection systems are also sources of
pulping condensates.
The pulping process condensates are collected and routed to a control device
and/or conveyed to the wastewater treatment system. Steam stripping is a common control
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 4-34
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Section 4 Assessment Module: Kraft Pulping Operations
technology for condensates. Steam stripping is a fractional distillation process that
involves the direct contact of steam with wastewater. Heat from the steam vaporizes the
volatile compounds in the wastewater. The overhead vapor stream is typically incinerated
on-site. Mills may condense or rectify the stripper overhead gases and then burn the
condensed material in an on-site combustion device. As discussed in Section 4.5.4, this
combustion is not subject to RCRA combustion requirements. The steam stripper may be
a stand-alone piece of equipment, or, at some mills, it may be integrated into the
evaporator system. Steam strippers are currently being used by some mills to control
portions of these condensates for odor reduction.
The primary emissions of concern are TRS and methanol. Condensate emission
points will be any area where the condensates are exposed to the atmosphere, including
open sewers and the wastewater treatment system.
4.5.2 Condensate Air Regulations
Cluster Rules Condensate Requirements
! Cluster Rules require control of certain
condensates
! Closed collection system required
! Multiple control options available
! Steam stripping or biological treatment
control options most likely
! Condensate segregation option reduces
condensate compliance costs
Prior to the Cluster Rules,
NSPS and State regulations focused
only on limiting TRS emissions from
steam stripper vent gases. The Cluster
Rules, however, require control of both
the steam stripper vent gases (as part of
the LVHC requirements discussed in
Section 4.3) and the pulping process
condensates.
Basic emission limits. The
Cluster Rules require the control of
certain condensates from each digester
system, turpentine recovery system, LVHC and HVLC gas collection system, and the
evaporator system condensates from weak liquor feed stage vapors and vacuum systems.
These streams must be captured in a closed collection system and controlled by one of the
following options:
! Recycling. Recycle the pulping process condensate to an equipment system
specified in standards for the pulping system at kraft, soda, and semi-chemical
processes that is meeting the closed-vent system and control device requirements of
the pulping vent MACT standards
! WWTP biological treatment. Discharge the pulping process condensate below the
liquid surface of the biological treatment system located at the mill's wastewater
treatment plant achieving at least 92 percent total HAP destruction
! Percent reduction. Treat the pulping process condensates (generally by steam
stripping) to reduce or destroy the total HAP's by at least 92 percent by weight
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Assessment Module: Kraft Pulping Operations Section 4
! Mass removal. At mills that do not perform bleaching, treat the pulping process
condensates to remove 3.3 kilograms or more of total HAP per megagram
(6.6 pounds per ton) of ODP, or at mills that perform bleaching, treat the pulping
process condensates to remove 5.1 kilograms or more of total HAP per megagram
(10.2 pounds per ton) of ODP
! Outlet concentration. At mills that do not perform bleaching, achieve a total HAP
concentration of 210 parts per million or less by weight (ppmw) at the outlet of the
control device, or at mills that perform bleaching, achieve a total HAP
concentration of 330 ppmw at the outlet of the control device. This emission limit
is not available to biological treatment systems because of dilution of regulated
condensates with other mill wastewaters
The pulping process _,. , _, „ ,. „ , _
, A A u j ^ Closed Collection System Requirements
condensates must be conveyed to
whichever control device the mill . _ x . x ,, ...
. . , , .. . ^ ! System consists of hardpipmg; covers,
chooses in a closed collection system , , . . ,
.... , , , water seals, or other emissions control
that is designed and operated to meet . ' xl , , ,
^ , , , , , equipment; or venting through closed-
the individual dram system f , . ,
.~ ,. cc ^0 nrr. vent system to control device (or
requirements specified in §§ 63.960, ,• ^ f ±, ,^
^c^^^ *<5 n*o j ^-5 rJv f u ^ combination of methods)
63.961, 63.962, and 63.964 of subpart . ,_ ,,,„»,,. ,.
__„. __ ... . ! Monthly (30 day) visual inspections
RR. Subpart RR essentially requires 1T , , \\. ' e ,
,, ,,, r- u i i ' Leak detection tests for condensate
that the means or conveyance be leak- ,
c A. . . r-TTAT^r- storage tanks
free. Air emissions of HAP from vents L^^^^^^^^^^^^^^^^^^^^^^^^^_
on any condensate treatment systems
(except biological treatment systems
located at the mill's wastewater treatment plant) and closed collection systems that are used
to comply with the standards must be handled in a closed-vent system and routed to a
control device meeting the Cluster Rules LVHC/HVLC standards (e.g.. combustion).
These are the same closed-vent/control system requirements that apply to LVHC and
HVLC gas collection systems (see Section 4.3.2).
General exceptions. For control devices (other than open biological treatment
systems that are part of the mill's wastewater treatment plant) used to achieve the percent
reduction, mass removal, or outlet concentration treatment options, the Cluster Rules
provide a 10 percent excess emissions allowance. For example, the allowance accounts for
stripper tray damage or plugging, efficiency losses in the stripper due to contamination of
condensate with fiber or black liquor, steam supply downtime, and combustion control
device downtime. The 10 percent allowance includes excused periods of excess emissions
associated with the startup, shutdown, and malfunction scenarios described in the facilities
startup, shutdown, and malfunction plan. Note that although there are no explicit back-up
control requirements as part of the Cluster Rules, back-up controls may be necessary for
mills that are concerned that this excess emission allowance is inconsistent with expected
control device operating experience.
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Section 4 Assessment Module: Kraft Pulping Operations
Note that EPA has clarified in technical corrections to the Cluster Rules how this
exception applies to control systems other than a steam stripper (see 63 FR 49455,
September 16, 1998). As originally written, this exception applied only to steam strippers
complying with the percent reduction option. The technical corrections modified this
language so that the exception applies to any control device — except the biological
treatment system at the mill's wastewater treatment plant — used to meet the percent
reduction, mass removal or outlet concentration emission limit options. For a stand-alone,
enclosed biological treatment system, the 10 percent excess emission allowance would
apply. Note, however, that such systems would have to develop site-specific parameter
monitoring and would not be subject to the same percent reduction testing and parameter
monitoring as systems that are part of the mill's wastewater treatment plant.
Condensate segregation options. The Cluster Rules also contain condensate
segregation options that can save costs by minimizing the condensate volume that must be
treated. Under the condensate segregation options, the facility has the option of
minimizing the condensate volume sent to treatment from the digester system, turpentine
recovery system, and weak liquor feed stage vapors and vacuum system condensates in the
evaporator system. The concept focuses on the fact that pulping systems may have more
than one condensate stream and these streams will vary in concentration of HAP. By
segregating condensate streams containing the greatest amount of HAP and treating only
these streams, an equivalent emission reduction can be achieved at a lower energy cost
(e.g.. less steam is required for a lower volume of condensates). The Cluster Rules contain
two options for determining if sufficient segregation of the condensate streams has been
achieved to qualify for the volume minimization allowance:
! Treat the total volume of LVHC and HVLC collection system condensates, plus at
least 65 percent of the total HAP mass from all condensates from the digester
system, turpentine recovery system, and weak liquor feed stage vapors and vacuum
systems in the evaporator system; or
! Treat any subset of the regulated streams that contain a minimum total HAP mass
(3.6 kg/Mg ODP for unbleached mills and 5.5 kg/Mg ODP for bleaching mills)
If sufficient segregation is not achieved, then the entire volume of condensate from
the digester system, turpentine recovery system, and weak liquor feed stage vapors and
vacuum systems in the evaporator system must be treated.
Monitoring, reporting, and recordkeeping. The monitoring requirements for the
condensate emission limits depend on the control option selected. The reporting and
recordkeeping requirements require semiannual reports (quarterly if excursions occur) and
specify that all records of monitoring parameters must be maintained. The Cluster Rules
also require specific records to be maintained of closed-vent system and closed collection
system inspections and results of negative pressure and leak detection tests.
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Assessment Module: Kraft Pulping Operations Section 4
The following basic monitoring requirements apply to each control option (no
monitoring of the recycling option is required):
Steam strippers generally will use parameter monitoring to determine continuous
compliance, based on site-specific parameter excursion values, although a methanol
continuous monitoring system (CMS) can be used as an option for monitoring the outlet
concentration. The following parameters must be monitored and recorded:
! Process wastewater feed rate
! Steam feed rate
! Process wastewater column feed temperature
Wastewater treatment plant biological treatment systems require an annual
performance test in the first calendar quarter to demonstrate, on a total-HAP basis, that the
system achieves at least 92 percent reduction efficiency. For each subsequent quarter, the
owner or operator must conduct percent reduction tests, on a methanol-only basis, to
determine compliance. In addition, there are several parameters that must be monitored on
a daily basis including:
! Outlet soluble BOD5
! Mixed liquor volatile suspended solids (MLVSS)
! Horsepower of aerator units
! Inlet liquid flow
! Liquid temperature
For the outlet soluble BOD5, MLVSS, and aerator horsepower parameters, an excursion
from an established parameter value triggers the need to conduct an additional percent
reduction performance test to determine compliance and requires the mill to correct the
problem as soon as practical. The inlet liquid flow and liquid temperature values are
necessary only to perform the percent reduction test, and are not used to trigger additional
tests or for other purposes.
Biological treatment systems that are not part of the mill's wastewater treatment
plant would have to submit a plan for monitoring appropriate control system parameters.
For each parameter, the mill would have to develop appropriate excursion levels. The
parameters would be used to determine continuous compliance and the excursions (subject
to the 10 percent allowance discussed above) could be used to document violations of the
standard.
Closed collection systems are subject to visual inspection and leak detection
requirements. For the gas vents, the self-monitoring (i.e. inspection) requirements are the
same as for the LVHC closed-vent and control system requirements (see Section 4.3.2).
For the closed collection system used to convey the liquid condensates, the monitoring
requirements under Subpart RR apply. The Cluster Rules also impose a monthly visual
inspection requirement.
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Section 4 Assessment Module: Kraft Pulping Operations
Condensate segregation requires site-specific monitoring to determine that the mill
continues to achieve sufficient segregation to qualify for the segregation alternative. The
appropriate parameters will be selected on a mill-specific basis. The mill will have to
establish excursion values for the monitored parameters.
4.5.3 Condensate Air Inspection Techniques
For pulping condensates, the Cluster Rules add a new activity of regulatory concern
that is not addressed by typical TRS requirements. The TRS requirements address
emissions for a Condensate steam stripper, but do not impose requirements as to which
condensates at the mill must be controlled by a stripper or equivalent control. For this
reason, this area is likely to be a focal point for potential compliance concerns during the
early years of the Cluster Rules' implementation. As described in Section 4.5.2, there are
four main steps necessary to achieve compliance with the Cluster Rules' condensate
requirements, each of which may involve different assessment techniques:
! Define the applicable condensates that must be handled and treated in accordance
with § 63.446. As described above, the mill owner or operator has the option of
segregating condensates so that not all pulping condensates must comply with the
condensate emission standards. If this option is selected, the owner or operator
must not only demonstrate initial compliance with the segregation applicability
requirements but also must develop a monitoring plan to document that the
segregation option continues to satisfy the applicability criteria. As part of the
monitoring plan, the owner or operator will have to develop appropriate parameter
excursion levels. If excursions occur, the excursions are direct evidence of
violations and will be reported quarterly as excess emissions. Assessments will
involve pre-inspection reviews of monitoring reports and then on-site checks of
current data and proper monitor operation.
! Convey the condensates in a closed collection system. The condensate closed
collection system includes elements for transfer of the liquid condensates and
closed-vent system and control device elements for transferring air emissions from
the liquid condensates. The assessment procedures for the closed-vent system and
control device requirements will be the same as the procedures required for the
LVHC gas closed-vent system and control device requirements. In addition, the
inspector will have to assess compliance with the requirements applicable to the
liquid closed collection system — requirements for tanks and individual drain
systems.
! Treat the condensates using one of the compliance options. If the recycling option
is selected, then no monitoring data will be available, and the inspection will consist
of verifying that the condensates are in fact recycled to the process equipment. A
check of process diagrams and visual observations are the likely techniques. If a
steam stripper is used to treat the condensates, then the inspector should evaluate
the required monitoring data to determine compliance. If the biological treatment
system (wastewater treatment plant) option is used, the inspector will have to
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Assessment Module: Kraft Pulping Operations Section 4
evaluate both required parameter and performance test data to determine
compliance. If a stand-alone biological treatment system is used, the inspector
should evaluate the site-specific parameter monitoring data to determine
compliance.
! Convey the treated HAP compounds in the same manner as the LVHC collection
system. Unless a mill uses the biological treatment system in the wastewater
treatment plant, the gaseous (volatilized) HAP emissions from the treatment of the
liquid condensates must be conveyed to a control device in the same manner as
LVHC gases. Generally, no separate assessment of this requirement will be
necessary; because most mills will rely on steam stripping, this requirement is
already incorporated into the LVHC requirement (§ 63.443) that the stripper
overhead gases be conveyed and treated as part of the LVHC system.
For initial compliance, the appropriate steps to follow for coming into compliance
with the Cluster Rules are outlined extensively in the document Pulp and Paper NESHAP:
A Plain Engish Description (EPA-456/R-98-008), including a discussion of applicability,
timing and other initial compliance issues. This document, therefore, focuses on on-site
assessments that will be conducted after initial compliance has been demonstrated and the
appropriate permit conditions have been included to address the Cluster Rules.
4.5.3.1 Pre-inspection Steps
As discussed in Chapter 3, there are a number of steps that should be taken
routinely prior to conducting an actual on-site inspection, including file reviews. As part of
the file review, the inspector should consider at least the following items:
Process diagrams. Obtain a simplified diagram of the condensate handling
system(s) and note what control(s) are employed. This type of diagram may be available in
the Part 70 operating permits file if submitted with the application. A drawing or
schematic of the closed-vent system and control device - and individual drain systems -
used to handle condensates should also be available as part of a mill's self-inspection plan
for these systems (see § 63.454(b), as well as § 63.965(a)(l) for individual drain systems).
Use of controls located in other process areas. If the facility relies on biological
treatment, then the control system may be located in the wastewater treatment plant area.
Also, if the facility combusts the vent gases from a steam stripper (or other treatment
device) in a lime kiln, power boiler or recovery boiler, the inspector must verify the
continuous use of these combustion process units for HAP control when conducting the
inspection of the chemical recovery and power boiler areas of the mill. Any downtime will
have to be checked against permitted levels of uncontrolled venting.
Evaluation of periodic monitoring reports. The mill will have to record and
report monitoring data for control devices (e.g.. steam strippers or biological treatment
systems) used to treat condensates. If the biological treatment system located in the
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Section 4 Assessment Module: Kraft Pulping Operations
wastewater treatment plant is used, the report will include quarterly performance test data
as well. If the mill elects to use the condensate segregation options, the reports will also
include the results of condensate segregation applicability monitoring. For each parameter
that must be reported, semiannual reporting is required so long as no exceedances occur.
Once an exceedance occurs, quarterly excess emission reports (EERs) are required until
such time as EPA approves a return to semiannual reporting. The inspector should review
reports submitted since the last inspection in order to prioritize the need for follow-up
while on-site.
The inspector should confirm that any periods of excess emissions indicated in the
reports are within regulatory limits. If not, the inspector may need to evaluate on-site
records that document the reasons for the excess emissions and/or uncontrolled venting.
The review will be necessary to evaluate claims of allowable excursions. For control
devices other than biological treatment systems at the mill's wastewater treatment plant, the
Cluster Rules allow for excess emissions for up to 10 percent of operating time (including
startup, shutdown and malfunction periods) within a semiannual reporting period without
the exceedances constituting a violation. For other monitored parameters with excursion
levels, allowable excursions may occur as a result of startup, shutdown or malfunction
periods. The inspector should evaluate these types of claims in connection with the
facility's startup, shutdown and malfunction plan required under 40 CFR 63.8.
Evaluation of episodic malfunction reports. The inspector should review
malfunction/upset reports since the last inspection, if available. If the reports identify
corrective actions to be taken by the source, note the need to verify during the on-site
inspection that the corrective steps were actually taken and that they resolved the problem.
The facility should have records of these corrective actions consistent with the Part 63
SSM Plan.
Also, in evaluating claims of malfunction periods noted on excess emission reports,
the inspector should compare the duration and timing of those periods to whether the
facility submitted a malfunction report. If a malfunction report is required for all or some
specified subset(s) of malfunctions, note any discrepancies between the malfunction reports
submitted and claims in an EER of "malfunction" as a cause of excess emissions.
Significant discrepancies signify either errors in EER or malfunction reporting that should
be addressed with the facility either as part of the inspection or by agency compliance staff
responsible for processing periodic and episodic reports.
4.5.3.2 On-site Inspection Steps
The appropriate on-site inspection steps must be tailored to the objectives of the
inspection and the priority given to the condensate requirements in a particular inspection.
The possible steps for a routine Level 2 inspection include:
Permit verification. One objective of a standard Level 2 air inspection will be to
verify that the permit includes all the appropriate standards for the applicable condensate
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Assessment Module: Kraft Pulping Operations
Section 4
equipment systems. Prior to the inspection, review the permit to determine what
conditions apply to the pulping condensates. Depending on the nature of the specific
permit conditions, the inspector may then evaluate a number of potential issues to verify
that the mill's operations remain consistent with permit requirements, including:
! Are all sources of condensates
properly identified in the
permit? (Note: This step is
critical if the mill has elected to
use the condensate segregation
options.)
\ Have any modifications
occurred that could trigger
NSR or that could affect the
condensate segregation
applicability requirements for
the facility? Have the additional
controls associated with HVLC
and condensate points triggered
NSR based on increases from
the combustion control units?
NOTE! Additional controls on HVLC
and condensate points as a result of the
Cluster Rules may increase SO2 and NOX
emissions and trigger NSR:
! EPA believes that the pollution control
project exemption from major NSR
generally should apply
! State minor NSR will still apply and
major NSR may apply if the State
determines it necessary or for sources
located near Class I areas
! See 63 FR 18531-32 for further detail
! Are the HAP control methods identified?
! Compare the basic process/design information with conditions in the permit to
verify the accuracy of the information in the permit and to support subsequent
assessment activities.
Evaluation of closed collection system. Prior to evaluating the control methods
used to treat the condensates, the inspector should determine that the source is satisfying
the requirements to maintain a closed collection system. Because the results of inspections
and other monitoring of the collection system are recorded but not reported, an on-site
records review inspection is necessary to evaluate that the system meets the regulatory
requirements.
As part of the Cluster Rules, facilities will have to enclose and convey pulping liquid
condensates through a closed collection system. Emissions from the liquid condensates must
be handled by a closed-vent system and sent to a control device meeting the requirements for
the LVHC and HVLC gas collection systems. The Cluster Rules require the facility to develop
a self-inspection plan, including a series of periodic checks, to assure that this system continues
to operate properly. The inspector should review the records of these activities to assure that
the required checks are occurring and that the source has taken any corrective action steps
necessary to remain in compliance.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Section 4
Assessment Module: Kraft Pulping Operations
Checks of Closed Collection/Closed-vent
Systems for Suspected Problems with
Facility Self-Inspections
! Visual inspections (ductwork, piping,
valves, water seals, closure devices,
junction boxes, unburied sewer lines,
etc.)
! Leak checks using Method 21 analyzer
(positive pressure components and
tanks)
! Pressure checks using portable
pressure gauge, etc. (negative pressure
enclosure/hood openings of closed-vent
systems)
In addition to the same basic
closed-vent system and control device
requirements applicable to LVHC/
HVLC gas collection, the condensate
requirements also include provisions
for individual drain systems and tanks:
For individual drain systems, a
self-inspection plan is required and the
source should have records of these
inspections. The Cluster Rules require
visual inspections every 30 days. The
key elements of the plan are visual
inspections of:
! Water seals used to control air
emissions — check liquid levels
! Closure devices on drains,
junction boxes and unburied portions of sewer lines — check to ensure device is in
place and has no defects (gaps, cracks, holes, broken/damaged seals, missing caps,
etc.)
If defects are identified, the mill must take corrective action and maintain records of the
action taken. Provided appropriate corrective action is taken, the facility will remain in
compliance — the existence of an observed defect by itself is not a violation. The inspector
should evaluate the records and interview site personnel to verify that appropriate
corrective action was taken. The inspector should pay special attention to claims of a need
for delay in repair. Under the Cluster Rules, such delays are allowed if the repair requires
emptying or removing the drain from service and there is no alternative capacity for the
wastewater handled by the affected drain.
For tanks., the Cluster Rules require the mill to conduct leak checks (using
Reference Method 21) initially and annually thereafter. If a leak is detected, the mill must
follow specified corrective action procedures and complete corrective action generally
within 15 days. The inspector should determine whether the source has records to
document compliance with these requirements. In addition, use of a portable leak check
analyzer may be appropriate where problems are suspected with particular tanks.
After a review of the applicable records and interviews with mill personnel, if the
inspector detects or suspects a compliance problem, the inspector should consider
conducting the types of checks that the facility is supposed to undertake as part of its self-
inspection program to the extent feasible within time and safety constraints.
Evaluation of proper operation of control equipment. A Level 2 inspection
next should focus on assuring that the control equipment is being properly operated and
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May 1999
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Assessment Module: Kraft Pulping Operations Section 4
maintained so that the facility continues to achieve compliance with the applicable emission
limits. The proper steps for this phase of the inspection will depend on the control
measures used for the condensates, which will generally include either recycling to the
process, steam stripping, or biological treatment systems.
Recycling. If the facility complies by recycling the condensates to the process
equipment, no recordkeeping or monitoring requirements will apply. The inspector should
verify through a review of process diagrams and a visual walk-through that the required
recycling equipment is in place. In addition, a DCS may provide real time and historical
data that documents recycled flow of condensates to the process.
Steam Stripping. This control
method is by far the most likely option
and is expected to be used in nearly all
mills. The main design characteristics of
steam strippers that have an effect on
removal efficiency are the steam-to-feed
ratio (SFR) and the number of trays (or from baseline
Check monitors for operating
overall packing height). Generally, as
either of these increases, removal
efficiency will tend to increase. QA/QC records
The Cluster Rules generally
Basic Steam Stripper Inspection Steps
Evaluate required monitoring data
(SFR, temp., or methanol CMS); check
against required limits and for shifts
condition, including most recent
SFR values generally should be at least
1.5 Ib/gal.
require monitoring of both the steam
and feed rates. The mill is required to
establish parameter excursion levels for purposes of reporting excess emissions. Although
not explicitly stated in the rule, the Agency expects these excursion levels to be expressed
as an SFR because the appropriate level for each of these two parameters is dependent on
the level of the other parameter. Background data collected in support of the Cluster
Rules indicate that a SFR of at least 1.5 Ib/gal should be maintained to achieve the 92%
reduction required by the rule. The Cluster Rules also require monitoring of the process
wastewater column feed temperature. A minimum temperature excursion level will be
established during the performance test.
In addition, if the mill elects to meet the Cluster Rules' condensate treatment
standard expressed in a ppmw format, the owner can install a methanol CMS at the outlet
of the steam stripper to measure the outlet concentration instead of measuring the control
device parameters. If this option is selected, the inspector should check recent QA/QC
results to assure proper operation of the monitor, and then analyze real-time and trend
data, to the extent available, through a DCS or other available records.
The number of trays (or overall height of packing) is fixed by the design of the
applicable stripper being used. However, removal of trays for maintenance and repair can
occur, and is one of the reasons for the 10 percent excess emission allowance in the Cluster
Rules. If excess emissions as detected by the SFR monitoring are high, then an inspector
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Section 4 Assessment Module: Kraft Pulping Operations
may follow up to examine tray maintenance and repair records to determine whether the
mill's O&M procedures for the steam stripper are adequate to minimize emissions.
Use of WWTP Biological -*mr™, ^ • .• ,, ,
„ VJ . ,. ,- NOTE! This section addresses only
Treatment System. As discussed in .•,•,. . . . .•- .
„ . . , . ., . . . . biological treatment systems that are
Section 4.5.2, for this control option ,.,.., . . . . . , .
, „, '. . , .,, located in the wastewater treatment plant
the Cluster Rules require the mill _,, ,. . . . , , , f
. area. Other biological treatment systems
owner or operator to conduct percent .-..-. • «-
, • r. are subject to site-specific parameter
reduction performance tests on a ., J.
... T .... . monitoring.
quarterly basis. In addition, the owner I
or operator also must monitor five
separate parameters on a daily basis
(outlet soluble BOD5; mixed liquor volatile suspended solids; horsepower of aerator units;
inlet liquid flow; and liquid temperature). For each parameter the mill must establish
parameter excursion levels. For the outlet soluble BOD5, mixed liquor volatile suspended
solids, and aerator horsepower parameters, an excursion triggers the need to conduct a
percent reduction performance test (in addition to the scheduled quarterly tests) to
determine compliance and requires the mill to correct the problem as soon as practical.
The inlet liquid flow and liquid temperature parameters are necessary to conduct the
percent reduction test, and are not used for actually triggering the test or other purposes.
To inspect the biological treatment system, the inspector should determine:
! Did each quarterly performance test document that the treatment system met the
required percent reduction efficiency?
! Were any performance tests triggered by excursions required during the period
reviewed?
! If so, were the tests conducted when and as required?
! If so, what were the results?
! Were the corrective action steps taken in response to the excursion successful in
addressing the underlying problem? Examples of potential problems that could
result in excursions and failure of the biological treatment system include black
liquor spills and aerator malfunctions.
4.5.4 Condensate RCRA and EPCRA Issues
The mill may want to
concentrate the methanol stripped from
the condensates as supplemental fuel
for power boilers to recover the
methanol's heating value. There is
some possibility that the concentrated
methanol condensate would exhibit the
hazardous waste ignitability
characteristic which potentially could make the use of the methanol condensate in the
power boilers subject to RCRA boiler and industrial furnace (BIF) requirements. To
— eBA This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 4-45
NOTE! The Cluster Rules revised RCRA
rules to allow on-site burning of
condensates derived from steam stripper
overhead gases.
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Assessment Module: Kraft Pulping Operations Section 4
encourage recovery of these methanol condensates, EPA — as part of the Cluster Rules —
added an exclusion from the RCRA definition of a "solid waste" for condensates derived
from overhead gases from steam strippers used to comply with the condensate control
requirements. This exclusion is limited to on-site combustion. (See 63 FR 18533 for
further detail.)
The EPCRA concerns for the condensates generally remain the same as for the
LVHC and HVLC gas collection systems. See Section 4.3.4.
4.6 Spent Pulping Liquor, Turpentine, and Soap Management
Spent pulping liquor M/-^^, T- c ± c t^m * ™/™ •
t- t- t- o n NOTE! Enforcement of CWA BMPs is
management is an integral component . . , , , .
r- • , almost entirely through inspection
of optimal wastewater treatment , , , ~ •„ •••
.. . ... because each kraft mill will use site-
operation as well as economic mill .-. , , • , T.TUT.
. „. „. _ . . specific methods to implement BMPs..
operation. The Cluster Rules require ji^^^^^^^^^^^^^^^^^^^^^^
kraft mills that bleach pulp to
implement measures to prevent or
otherwise contain spent pulping liquor, turpentine, and soap. In addition, the management
of these materials may trigger RCRA handling requirements or EPCRA/CERCLA
reporting requirements. This section describes the:
! Common spent pulping liquor, turpentine, and soap discharge points
! Best Management Practices (BMPs) to control spent pulping liquor,
turpentine, and soap and BMP compliance procedures
! BMP inspection steps
! RCRA regulatory requirements, EPCRA/CERCLA reporting obligations,
and the associated inspection procedures
4.6.1 Potential Spent Pulping Liquor, Turpentine, and Soap Management
Discharge Points
Mills that perform chemical pulping of wood or other fibers generate spent pulping
liquors that are generally either recovered in a chemical recovery system or treated in a
wastewater treatment system. Spent pulping liquor at kraft mills is comprised of black
liquor that is used, generated, stored, or processed at any point in the pulping and chemical
recovery process. Black liquor is generated during the cooking process in the digester and
contains dissolved organic wood materials and residual alkali cooking chemicals. After
separation from the pulp, spent liquor is routed to the chemical recovery cycle. Weak
black liquor that is more dilute in nature is separated during pulp washing operations.
Some of the weak black liquor is reused in the pulping process, and the rest is sent to the
chemical recovery process. The black liquor is evaporated to a high concentration and
then burned in a recovery boiler to recover the energy associated with the dissolved
organic wood materials and to regenerate cooking chemicals used to pulp the wood.
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Section 4 Assessment Module: Kraft Pulping Operations
Some kraft mills, particularly those that used softwood as raw material, isolate soap
and turpentine from the spent pulping liquor. Fatty and resin acids found in the wood
material become saponified during the kraft pulping process. During black liquor
evaporation, the soap becomes insoluble and rises to the surface of the liquor. The soap is
removed from one effect of the evaporator to a skimming tank where it is removed. The
skimmed liquor is then returned to the next evaporator effect.
Turpentine partitions to the foul condensates when digester relief vent gases are
condensed. Typically, the turpentine is recovered by decanting the condensates and
skimming the top layer containing the insoluble turpentine. The turpentine is then sent to a
storage tank for off-site sale, while the condensates are routed with other pulping area
condensates to the wastewater treatment plant (with or without steam stripping, depending
on the mill).
NOTE! NSPS Subpart Kb volatile
organic liquid tank standards may apply
to turpentine and black/green liquor
storage tanks, but likely impose only
minimal recordkeeping requirements.
Note that the turpentine and
black liquor storage tanks (as well as
green liquor storage tanks in the
chemical recovery area) store materials
with volatile organic liquid (VOL)
content. Subpart Kb of the NSPS
covers new or modified (after 7/23/84)
VOL storage tanks with a design
capacity of at least 40 cubic meters (approximately 10,000 gallons). Subpart Kb imposes
minimal recordkeeping requirements on all applicable tanks and then imposes, based on
tank capacity and the true vapor pressure of the stored materials, additional recordkeeping
requirements and/or design/control standards. Process vessels meeting the definition in 40
CFR 280.12 of a "flow through process vessel" are exempt from subpart Kb
requirements.12 For turpentine tanks, Subpart Kb generally will impose only minimal
recordkeeping (document the tank's capacity) because of the tanks' relatively small size
(usually 10,000-20,000 gallons) and the low true vapor pressure of the material stored
(estimated to be <1 kPa). The black and green liquor would be affected similarly.
Without careful management,
kraft mills can lose pulping liquor
through spills, equipment leaks, and
NOTE! BMPs require mills to return
spilled or diverted materials to the process
intentional diversions from the pulping to maximum extent the mill determines
practicable or to discharge the materials
at a rate that does not disrupt the
receiving treatment system.
and chemical recovery areas of the
mills. In the absence of adequate
collection and recovery (or controlled
rate of release to the wastewater ^^^^^^^^^^^^^^^^^^^^^^^^^^
treatment plant), intentional diversions
can have the same adverse impacts as a spill of similar size. Figure 4-1 depicts the critical
systems within the pulping area that involve managing spent liquor and that have the
potential for liquor releases. Spent pulping liquor may be accidentally or intentionally
released from any of these systems.
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Assessment Module: Kraft Pulping Operations Section 4
Spent pulping liquor losses increase the need for pulping liquor make-up chemicals
and decrease energy generated from pulping liquor solids combustion. Liquor losses and
spills not only adversely affect economic operation of the pulping process but may also
adversely affect wastewater treatment system operations and lead to increased effluent
discharges of conventional and toxic pollutants.
Significant sources of black liquor losses from normal process operations include:
! Leaks from seals on brown stock washers
! Leaks from seals on pumps and valves in black liquor service
! Intentional liquor diversions during shutdowns, startups, grade changes, and
equipment maintenance
! Sewered evaporator boil-out solutions
! Decker losses at older mills with open screen rooms
! Losses from knotters and screens at mills without fiber and liquor recovery systems
for those sources
Unintentional pulping liquor losses at pulp mills are most commonly caused by
process upsets, equipment breakdowns (i.e., malfunctioning valves, flanges, and pumps;
pipelines corrosion; and lack of preventative maintenance), and tank overfilling.
Maintenance and construction in a mill's pulping and chemical recovery areas may cause
intentional diversions of pulping liquor to the wastewater treatment system. Research into
spill incidents reported through EPA's Emergency Response Notification System shows
the following causes of pulping liquor spills7:
! Mechanical failure (45%)
! Human error (20%)
! Tank overfilling (16%)
! Intentional diversions (4%)
! Weather (1%)
! Power Failure (1%)
! Unknown (13%)
4.6.2 Spent Pulping Liquor, Turpentine, and Soap Management ~ CWA
Requirements
With the promulgation of the Cluster Rules, 40 CFR 430.03 requires papergrade
kraft mills that bleach pulp to implement BMPs to prevent leaks and spills of black liquor,
soap, and turpentine. (Note that these requirements also apply to soda mills as well.) The
primary objective of BMPs is to proactively prevent losses; a secondary objective is to
reactively collect, contain, recover, or control spills and losses that do occur. The BMP
requirements are designed to provide kraft mills the flexibility to implement general mill-
specific management controls, combined with various engineering controls and monitoring
systems to achieve these objectives. The BMPs include the following elements:
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Section 4 Assessment Module: Kraft Pulping Operations
! Return of diverted or spilled liquor, turpentine and soap to the process to the
maximum extent practicable as determined by the mill
! Establishment of preventive maintenance programs for equipment in spent pulping
liquor, turpentine and soap service
! Continuous, automated monitoring systems (i.e., alarms, conductivity monitors, or
pH meters) on storage tanks, in process areas, in process sewers, in process
wastewater, and in the wastewater treatment plant to detect leaks, spills, and
intentional diversions
! Annual training for personnel involved with operating, maintaining, or supervising
operation of equipment in spent pulping liquor, turpentine, or soap service
! Preparation of reports evaluating spill events not contained in the immediate
process area
! Establishment of a program to review any planned facility modifications and
construction activities in the pulping and chemical recovery facilities
! Installation of secondary containment for spent pulping liquor bulk storage tanks or
an annual tank integrity testing program coupled with diversion structures
! Installation of secondary containment for turpentine bulk storage tanks
! Installation of curbing or diking systems for turpentine and soap processing areas
! Wastewater treatment influent monitoring to track BMP performance and
effectiveness and to detect trends in spent liquor losses (EPA has recommended in
the Technical Support Document8 that mills monitor for COD, but 40 CFR
430.03(h)(2)(i) of the Cluster Rules provides that other parameters related to spent
pulping liquor loss also may be used)
In addition, kraft mill operators and owners must develop a BMP Plan which
specifies the procedures and practices each mill will employ to meet BMP requirements.
Details of the practices listed above are in the Technical Support Document for Best
Management Practices for Spent Pulping Liquor, Spill Prevention, and Control*
4.6.3 Spent Pulping Liquor, Turpentine, and Soap Management ~ CWA
Inspection Techniques
As a result of the new BMP requirements, water inspectors will have to evaluate
operations in the pulping area, in addition to the bleach plant and wastewater treatment
plant. Consequently, inspectors should carefully review all available materials prior to the
on-site inspection to become familiar with the pulping and chemical recovery areas.
4.6.3.1 Pre-inspection Steps
As discussed in Chapter 3, there are a number of steps that should be taken prior to
conducting an actual on-site inspection, including file reviews. As part of the file review,
the inspector should consider the following items:
Permit review. For direct discharges, BMP requirements are implemented through
the NPDES permit. For indirect discharges, BMPs are pretreatment standards and, thus,
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Assessment Module: Kraft Pulping Operations Section 4
apply directly to the indirect discharger. Inspectors should review permits to determine the
required schedule for implementing BMPs.
Evaluation of the BMP Plan. Each kraft facility that chemically bleaches pulp
must complete its BMP Plan by April 15, 1999 (or the date its NPDES permit containing
BMP requirements is issued, whichever is later). In addition to detailing the measures a
mill will implement to comply with the BMPs discussed in Section 4.6.2, the BMP Plan
must be based on a detailed engineering review of the pulping and chemical recovery
systems. If the permitting authority instructed the facility to submit the BMP Plan (which
is not required by the Cluster Rules) the inspector should review the document prior to the
mill inspection. If the permitting authority did not instruct the facility to submit the BMP
Plan, the inspector should contact the facility to ensure these materials are made available
upon arrival. The Cluster Rules specifically require the kraft facility to maintain a complete
copy of the current BMP plan on its premises and to make it available to EPA and the
State agency upon request. See 40 CFR 430.03(g).
Evaluation of periodic monitoring reports. As part of the Cluster Rules, mills
must conduct daily monitoring of the influent to wastewater treatment systems, expressly
for the purpose of tracking the performance of the BMP program. Alternative monitoring
points may be selected to isolate possible sources of spent pulping liquor, soap, or
turpentine from other sources of organic wastewaters. Although the monitoring program
may, from time to time, detect large releases of spent pulping liquor, that is not the specific
purpose of this monitoring. The monitoring is intended to systematically measure progress
in reducing losses of spent pulping liquor, soap, and turpentine through effective use of
BMPs and to assure that the BMP program continues to be effective over time.
Mills must measure BMP effectiveness by establishing action levels. Each facility
must establish its own action levels and identify them in the BMP Plan. Mills have the
flexibility to choose the statistical methodology they will use to establish these action
levels. The action levels must consist of a lower action level, which if exceeded, will
trigger investigative requirements, and an upper action level, which if exceeded, will trigger
corrective action requirements. It is important to note that exceedance of an action level
does not constitute a violation; however, failure to take action called for in the BMP Plan
when an action level is exceeded for the time period specified in the BMP Plan does
constitute a violation.
The results of the monitoring program must be submitted to permitting authorities
at least once a year. Inspectors should review the monitoring reports to determine whether
the mills experienced excessive pollutant discharge from uncontrolled or intentional
discharge of spent liquor, soap, or turpentine that may have required the mill to perform
corrective actions. In the review, inspectors should:
! Compare monitoring results with the BMP Plan to determine whether actions levels
were exceeded
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Section 4 Assessment Module: Kraft Pulping Operations
! Note general trends of the monitoring results, especially those that demonstrate
poor performance, for discussion with mill personnel during the on-site visit
Inspectors should note that any exceedances of the action levels that resulted from
a spill or intentional diversion should be documented in the spill records described below
(see Section 4.6.3.2).
Process diagrams. If the BMP Plan is not available prior to the inspection or does
not include a process diagram, the inspector should obtain a process diagram of the
pulping, washing, and turpentine and soap processing systems and note what spill
prevention and control devices are employed.
4.6.3.2 On-site Inspection Steps
BMPs require mills to closely document spent pulping liquor, soap, and turpentine
management. As a result, appropriate on-site inspection steps should include a review of
the reporting and recordkeeping. In addition, inspectors should verify that appropriate
influent monitoring measures are implemented, that appropriate actions were taken if
action levels were exceeded, and that preventive maintenance measures are performed.
Evaluation of the BMP Plan. As mentioned above, inspectors should review the
BMP Plan to become familiar with the procedures the mill determined necessary to comply
with the BMP requirements. Inspectors should review the BMP Plan and inspect the
pulping area to:
! Ensure the BMP plan contains all required elements
! Evaluate whether the monitoring parameter selected by the mill is appropriate
! Determine whether the mill has achieved the objectives outlined in the plan, as well
as whether it has achieved compliance with the rule's BMP requirements
Ensure mills update the plan, as elements of the program are implemented
Determine whether mill updates action levels when required, as elements of the
program are implemented. Final action levels that reflect operation of the fully
implemented program must be established by January 15, 2002 (or the date an
NPDES permit containing BMP requirements is issued, whichever is later)
Evaluation of training records. Training is an essential element of a proactive
approach to prevent spent pulping liquor, soap, and turpentine losses by reinforcing
operator awareness, preventive maintenance, and daily management. Mills are required to
maintain initial and refresher training records for all personnel involved with operating,
maintaining, or supervising operation of equipment in spent pulping liquor, turpentine, or
soap service. These records must be maintained for three years from the date they were
created. Inspectors should review these records to determine whether mills are achieving
the training goals outlined in the BMP Plan.
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Assessment Module: Kraft Pulping Operations Section 4
Evaluation of repair records. Mills are required to track the repairs of equipment
in spent pulping liquor, soap, and turpentine service. These records must be maintained for
three years from the date they were created. Inspectors should review these records to
ensure mills have implemented the control measures outlined in the BMP Plan as well as to
determine whether mills have implemented changes to equipment as a result of an
unintentional spent pulping liquor spill to prevent reoccurrence.
Evaluation of spill records. Mills must prepare brief reports that evaluate each
spill or intentional diversion that is not contained in the immediate process area. Inspectors
should review these reports to confirm that they describe the equipment involved, the
circumstances leading to the incident, the effectiveness of the corrective actions taken to
contain or recover the spill or intentional diversion, and plans to develop changes to
equipment and operating and maintenance practices as necessary to prevent reoccurrence.
The status of planned changes should be reviewed with mill staff.
Visual inspection. Referring to the BMP Plan, inspectors should perform a visual
inspection of a mill's pulping process area to determine whether the monitoring systems
and containment structures specified in the plan have been implemented. Mills have until
April 17, 2000 for monitoring systems and April 16, 2001 for containment structures (or
the date a NPDES permit containing the BMP requirement is issued, whichever is later) to
implement the following:
! Continuous automated alarm systems (i.e., alarms, conductivity monitors, or pH
meters) on storage tanks, in process areas, in process sewers, in process
wastewater, and in wastewater treatment plant. Inspectors should determine
whether the alarm signals (audio or visual) on the tanks are in the locations
specified in the BMP plan and provide sufficient notice to allow operator response.
Likewise, inspectors should visually inspect the process areas, process sewers, and
wastewater treatment plant to ensure conductivity monitors or pH meters are
placed in the appropriate locations and provide sufficient signal for operator
response.
! Secondary containment structures are required for turpentine bulk storage tanks
and are one option for spent pulping liquor bulk storage tanks. Mills will detail the
measures they will use to meet BMPs in the BMP Plan and inspectors must
determine whether these structures and management systems are in place by the
required date.
! Curbing or diking systems are required for turpentine and soap processing areas.
Again, mills will detail the measures in the BMP Plan and inspectors must
determine whether these structures are in place.
Evaluation of tank integrity testing. Mills may opt to implement tank integrity
testing, rather than install secondary containment structures, for spent pulping liquor bulk
storage tanks. If this option is used, inspectors should review the procedures used to
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Section 4 Assessment Module: Kraft Pulping Operations
perform tank integrity tests and the results of such tests. Note that some permits may
specify minimum integrity testing requirements. Inspectors should determine whether the
mill achieves the minimum requirements by reviewing the available testing records.
Evaluation of pulping and chemical recovery equipment construction or
modification program. Whether to meet the Cluster Rules requirements or to modernize
mill operations, mills will install new equipment or controls in the pulping and chemical
recovery areas. BMPs require a program to evaluate construction and modification
activities. This required program is intended to ensure that the prevention of spills and
leaks is considered while mills implement changes in the pulping and chemical recovery
areas. Inspectors should review documentation of this program.
Evaluation of activities related to influent monitoring program. As mentioned
above, mills must conduct daily monitoring of the influent to wastewater treatment systems
(or at an alternative location) to track the performance of the BMP program. Remember,
influent monitoring is intended to systematically measure progress in reducing losses of
spent pulping liquor, soap, and turpentine through effective use of BMPs and to assure that
the BMP program continues to be effective over time. While on-site, the inspector should:
! Interview mill staff to discuss ^m^^, T x ,,.-.• •,•
, r- . i i NOTE! Inspectors should interview mill
any exceedances or action levels „,. , , ,
, 11-1 staff and review records to determine
or trends noted during the pre- . xl ... , , x
,, , whether mills responded to any
inspection or periodic , „ . . .
. . T™,rr. exceedances of the action levels.
monitoring reports. BMPs _ , „,, ,. . . ,
.,, f , ^ Exceedance of the action levels does not
require mills to conduct . . . . . „ ..
... . . constitute a violation; however, failure to
investigations when lower x , , ' x .' x.
, , , , , take action does constitute a violation.
action levels are exceeded and L^^^^^^^^^^^^^_
to complete corrective actions
when upper action levels are
exceeded. Inspectors should determine whether mills responded to any
exceedances of the action levels because failure to take action called for in the BMP
Plan when an action level is exceeded constitutes a violation. If the action levels
are exceeded, inspectors should also discuss pollution prevention measures that
may be implemented to reduce treatment system loadings.
! Review the sampling procedures for the parameter the mill selected for monitoring
to ensure they are appropriate and consistent with any permit requirements (e.g..
conductivity would be inappropriate for monitoring soap and turpentine).
! Determine whether an appropriate sampling point is monitored to measure the
effectiveness of BMPs. Some mills will select locations further upstream from the
final influent stream to the wastewater treatment plant to better isolate problem
areas (i.e., pulp mill, chemical recovery operations, and bleach plant).
! Collect a sample, if appropriate, to verify the accuracy of the sampling program.
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Assessment Module: Kraft Pulping Operations Section 4
4.6.3.3 Root Cause Assessments
Where the initial inspection identifies potential problems with the source's BMP
implementation, more detailed review of the BMP procedures for the facility may be
appropriate. The Agency has recently examined two instances of NPDES permit violations
that were caused by spills and accidental releases of materials from the pulping area of kraft
pulp mills. These specific cases, along with information from an industry association
survey of spill prevention and control practices and information gained from EPA site visits
formed the basis for and approach to the BMP requirements included in the final Cluster
Rules. As a general proposition, it is clear that instituting the physical measures included in
the final Cluster Rules, along with a proactive, management-supported program of training,
maintenance and operator awareness, will prevent many accidental releases and capture
and return to the process many other spills and intentional diversions. Further
improvement is also found in a careful analysis of the root causes of those spills and
releases that occur in spite of the proactive BMPs that may be in place.
In conducting the root cause analysis performed in the wake of one of the cases
noted above, it was found that a process valve had failed to actuate in response to the
control room signal, and that the control circuit did not include a feedback signal providing
valve position status to the operators. As a result, the operator's initial action to remedy
an upset condition was not effective and a large quantity of foul condensate and spent
pulping liquor was sewered. The spike of organic material and black liquor solids was
sufficient to render the waste water treatment plant ineffective, even though the wastewater
treatment plant (WWTP) operators recognized the change in influent color and took
"defensive measures." The resulting releases from the WWTP resulted in a substantial fish
kill and the permitting authority ordered a mill shutdown.
The root cause analysis required as part of the Consent Order issued as a result of
the NPDES permit violation not only uncovered the specific cause noted above, but also
was generalized into a series of design and operating changes in the pulping and evaporator
areas. In the months that followed, the mill measured a 57% reduction in BOD levels
contained in WWTP influent. It is clear that the review of the incident not only determined
the cause of the specific event, but also led to a general improvement in the efforts to
reduce accidental losses of spent pulping liquor.
By requesting and reviewing information on the mill's follow-up root cause
investigation of incidents, the inspector should be able to construct a list of questions that
will determine if: (1) the cause was sufficiently well defined to put in place equipment
and/or procedures to prevent a recurrence of the same event in the future; (2) the "lessons
learned" were sufficiently "generalized" to allow them to be applied elsewhere in the mill to
prevent similar occurrences in the future; and (3) the information was communicated via
training and written procedures to all personnel that would benefit from the new
information.
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Section 4 Assessment Module: Kraft Pulping Operations
4.6.4 Spent Pulping Liquor, Turpentine and Soap Management ~ RCRA
Issues
Subtitle C of RCRA regulates "solid waste" that is "hazardous." Under RCRA,
"solid waste" is defined generally as "any garbage, refuse, sludge . . . and other discarded
material, including solid, liquid, semisolid, or contained gaseous material resulting from
industrial . . . operations[.]" (42 USC 6903(27)). EPA has determined, however, that spent
pulping liquors being reclaimed are not "discarded" and hence not "solid wastes," due to
their integral involvement in the kraft process. See 40 CFR 261.4(a)(6) and 50 FR 641-42
(Jan. 4, 1985).
In addition, there is a general exclusion for wastewaters discharged pursuant to an
NPDES permit (which excludes the actual discharge from regulation under RCRA,
although all units upstream of this discharge are not automatically excluded). RCRA also
exempts wastewater treatment tanks from regulation. See 40 CFR 264. l(g)(6). Thus, if
spent pulping liquor that is to be discharged to wastewater treatment is managed in
impoundments rather than wastewater treatment tanks, the impoundment would require
full regulation under RCRA if the spent liquor exhibits one of the four RCRA hazardous
waste characteristics.
Another RCRA issue would be spills that are not recycled into the process or
discharged with wastewater pursuant to an NPDES permit. One possible source for this
type of RCRA-regulated discharge would be leaks from surface impoundments if the spent
liquor exhibits one of the four RCRA hazardous waste characteristics. Spills to the ground
could also be an issue.
If a mill uses surface impoundments to contain spent pulping liquors, leaks from
these impoundments could trigger RCRA generator requirements, or RCRA corrective
action may be necessary to address the problem. As part of an air or water inspection, a
screening tool would be to determine whether impoundments are used. An appropriate
follow-up would be to investigate what types of liners or monitors are used to
prevent/detect leaks.
Another potential concern are general spills or leaks that affect the ground in the
pulping area. A screening technique for an air or water inspector would be to identify any
obvious evidence of potential spill areas. Typical indications of potential problems are:
discoloration, puddling, dead vegetation, or evidence of liquid channeling on the ground
area around piping, tanks, and similar areas.
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Assessment Module: Kraft Pulping Operations Section 4
4.6.5 Spent Pulping Liquor, Turpentine and Soap Management ~ EPCRA
Issues
As with other pulping area operations, the mill may have to take into account
discharges associated with management of spent pulping liquor and other residuals in
preparing TRI Form R reports. The inspector should verify that the reports include
estimates for these activities.
The handling of these materials can also raise potential emergency reporting
obligations. For instance, air releases that are not federally permitted and that exceed
certain reportable quantities require EPCRA/CERCLA emergency reporting. Also, as
noted above, EPA's ERNS database documents numerous emergency notifications related
to spills or intentional diversions of spent pulping liquor that result in abnormal discharges
to receiving waters.8
One method for an air or water inspector to screen compliance with these reporting
requirements is to note whether any upsets have been recorded by the mill. A list of
recorded upsets can be forwarded to the EPCRA inspector for further evaluation. For the
EPCRA inspector, these types of upset records provided by other media inspectors, as well
as citizen complaints or other tips, can be used to follow up and determine whether sources
have provided appropriate reports of incidents covered by EPCRA/CERCLA emergency
notification requirements.
The basic inspection procedures contained in Appendix D provide further detail on
procedures and decision steps for conducting a follow-up EPCRA emergency reporting
inspection, and the example assessment form in Appendix E contains an example checklist
for screening compliance with these requirements.
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Section 4 Assessment Module: Kraft Pulping Operations
References:
1. Mimms, A., Kocurek, M., Pyatte, J. and Wright, E., eds., Kraft Pulping. Atlanta, GA:
TAPPI PRESS. 1993
2. Smook, G.A., Handbook for Pulp and Paper Technologists. Bellingham, WA: Angus
Wilde Publications. 1992
3. Pulp, Paper, and Paperboard Industry - Background Information for Proposed A ir
Emission Standards for Manufacturing Processes at Kraft, Sulfite, Soda, and Semi-
chemical Mills. Publication No. EPA-453/R-93-050a. US EPA 1993.
4. Biermann, C. J., Essentials of Pulping and Papermaking. San Diego, CA: Academic
Press, Inc. 1993.
5. Burgess,!., The Basics of Foul Condensate Stripping. 1995 Kraft Recovery Short
Course. Atlanta, GA: TAPPI PRESS. 1995.
6. Kraft Pulp Mill Inspection Guide, prepared for U.S. EPA under Contract No. 68-01-
6310, Work Assignment No. 65, Pedco Environmental, Inc., Cincinnati, Ohio, January
1983.
7. U.S. EPA Emergency Response Notification System (ERNS): Data reported for the
period January 1988 to March 1993. U.S. Environmental Protection Agency,
Washington, D.C., 1993.
8. Technical Support Document for Best Management Practices for Spent Pulping
Liquor Management, Spill Prevention, and Control, EPA-821-R-97-011, U.S.
Environmental Protection Agency. Washington, D.C., October 1997.
9. Buonicore, A.J and Davis, W.T., eds., Air Pollution Engineering Manual, Air and
Waste Management Association, 1992.
10. Richards, J., Baseline Inspection Techniques, Student Manual, Air Pollution Training
Institute Course 445, 2nd Edition, 1996.
11. Ohio EPA's Operation and Maintenance (O&M) Guidelines for Air Pollution Control
Equipment, prepared for Ohio Environmental Protection Agency, under Contract No.
0810252, Environmental Quality Management, Inc., February 1993.
12. Rasnic, J., U.S. EPA, to Kaufman, R., AF&PA, interpretive letter dated October 29,
1998, regarding applicability of NSPS Subpart Kb to pulp and paper facilities.
13. U.S. Environmental Protection Agency, Chemical Pulping Emission Factor
Development Document (Revised Draft), July 8, 1997.
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Assessment Module: Kraft Pulping Operations Section 4
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SECTION 5: ASSESSMENT MODULE FOR CHEMICAL
RECOVERY OPERATIONS
5.1 Introduction
The chemical recovery area
contains large air emission sources that
are a significant regulatory concern.
The recovery process also involves
many other equipment systems that will
involve less significant air emission
concerns, as well as water and solid
waste issues. After a brief overview of
the process area, this section of the
manual focuses first on the main
equipment systems of regulatory
concern (recovery furnaces, smelt dissolving tanks, and lime kilns) and then addresses the
other miscellaneous equipment systems. In addition, Appendix E contains an example
assessment form specifically designed to address the issues raised in this process area.
CONTENTS
5.1 Introduction
5.2 Overview of Process and Discharges
5.3 Recovery Furnaces, Smelt Dissolving
Tanks and Lime Kilns
5.4 Other Miscellaneous Equipment
Systems
5.2 Overview of Process and Discharges
5.2.1 Description of the Process
Recovery, reconstitution, and reuse of spent cooking liquor to produce fresh
cooking liquor is necessary for viable economic operation of most chemical pulp mills.
Figure 5-1 provides a simplified schematic diagram of the kraft chemical recovery process.
At kraft mills, concentrated black liquor from the multi-stage evaporators is burned in a
recovery furnace to generate energy from combustion of organic constituents in the liquor,
leaving a molten smelt consisting of sodium sulfide (Na2S) and sodium carbonate
(Na2CO3). The smelt is then dissolved in water to form green liquor. The green liquor is
causticized with lime, precipitating calcium carbonate and leaving an aqueous solution of
sodium hydroxide and sodium sulfide (fresh white liquor), which is reused in the digesters.
The calcium carbonate is converted to quick lime via calcination in a lime kiln for reuse in
the recausticizing cycle.1
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 5-1
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Figure 5-1
Flow Diagram of Kraft Chemical Recovery Area
Strong Black Liquor
from Multiple Effect Recovery ^ Smelt ^ Green Liquor Slaker
Evaporators * Furnace * Dissolving P Clanfieror *
Tank Filter
V ^
r
Weak Wash ^ Dregs Causticizers
Storage Tank Washer 1
^ ^ Dregs to
or Sewer .
1 ,imp '
Mud White
Lime Kiln ^ Lime Mud ^ Lime Mud ^ _, .
^ Filter ^ Washer ^ _,
Lime Fl1
ij k Mud
Filtrate
Lime Storage
and Handling
I
Key 1
^ . . , White
^ Liquid stream to Di
^ Solid or slurry stream
r
liquor
ler or
ter
^
Grits to
Landfill
?
Liquor
gester
n
cr
n
n'
r>
o
n
VI
VI
n
VI
VI
5
n
£
VJ
C/5
n
n
o'
=
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Section 5 Chemical Recovery Assessments
5.2.2 Air Pollutant Emissions
The recovery furnace and lime kiln are the most significant, regulated sources of air
pollution in this area and have the following emission characteristics:
! Particulate matter/HAP emissions. Both recovery furnaces and lime kilns employ
particulate control devices. The particulates will also contain HAP compounds
(metals). The recovery furnace will also have some gaseous HAP emissions.
Under proposed MACT standards, the mill would use the existing particulate
matter control equipment and general operating practices to achieve compliance.
! TRS emissions. Good combustion practice is used to control TRS emissions,
although older recovery furnaces that use a direct contact evaporator (DCE) design
may also use a black liquor oxidation (BLO) system to reduce TRS emissions.
Newer recovery furnaces use a non-direct contact evaporator (NDCE) design that
results in lower TRS emissions than the DCE design. As described in Section 4,
the lime kiln often will be used as the control device for TRS emissions from
various pulping operations.
! SO2, NOX and CO emissions. Although these emissions are not subject to specific
federal regulations, state regulations may apply, as well as NSR or operating permit
requirements. Add-on control equipment is not generally used for these pollutants.
Other units in the chemical recovery area also are sources of air emissions, with
particulate matter emissions the primary concern. The smelt dissolving tank is a source of
particulate matter, is often subject to specific regulation, and generally will use some form
of low energy wet scrubber. Other units that may be covered by requirements, such as
generic opacity regulations or site-specific limits, would include the slaker, lime mud
washing system, and various storage and handling units.
Figure 5-2 indicates the typical air emissions from the various equipment systems in
the recovery process. The regulatory and inspection issues for the recovery furnace, smelt
dissolving tank and lime kiln are discussed in Section 5.3. The other miscellaneous air
emission sources are discussed in Section 5.4.
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Chemical Recovery Assessments
Section 5
Figure 5-2
Typical Air Emissions from the Chemical
Recovery Processes at a 1000 Ton Per Day Kraft Mill
Pulping System Components
Recovery Boiler (NDCE)
Smelt Dissolving Tank
Lime Kiln 4
Other Causticizing Area Sources 5
Typical Emissions (tons/yr) 1
Methanol
23
23
14
56
SO2
534
35
52.5
NOX
315
Not
Available
210
TRS
17.5
3.53
143
PM2
350
175
87.5
Not Available
1 Values are uncontrolled, except where otherwise indicated. Values are based on AP-42 factors (SO2, TRS, and PM),
1997 EPA Chemical Pulping Emission Factor Document13 (methanol), and Air Pollution Engineering Manual4 (NOX).
Values also assume 350 operating days per year.
2 Based on controlled emissions (ESP for recovery furnace, venturi scrubber for lime kilns, and mesh pad for smelt
dissolving tanks)
3 TRS values based on use of water low in sulfides in smelt dissolving tank and associated scrubber, and efficient mud
washing and optimal kiln operation.
4 Represents emissions from lime kiln with scrubber.
5 Sources include green and white liquor clarifiers, causticizer/slaker vent, and lime mud washer systems
5.2.3 Water Pollutant Discharges
In many mills, the later steps of black liquor processing may be located in or near
the chemical recovery area. These steps raise significant water discharge issues. However,
this manual addresses all black liquor processing in the pulping process discussion; see
Section 4.6.
For the remaining equipment systems, the chemical recovery process is a less
significant source of wastewater at most kraft pulp mills compared to the pulping and
bleaching processes. During the recovery of kraft pulping chemicals, water is used to wash
the solid precipitates formed in the recovery cycle. Washing recovers sodium- and sulfur-
containing compounds from green liquor dregs and lime mud. This weak wash water is
reused in the recovery cycle to dissolve the smelt and as a scrubbing medium for air
emission scrubbers. The excess weak wash is discharged to the wastewater treatment
plant.1 No specific regulatory concerns associated with the wastewater from the chemical
recovery process apply, and thus water-related issues for this area are discussed only
briefly in Section 5.4, which covers the miscellaneous equipment systems that involve
washing.
5.2.4 Solid/Hazardous Waste Discharges
Two primary solid waste discharges from the recovery area that must be handled
and disposed of are green liquor dregs and lime slaker grits. Green liquor dregs may be
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Section 5 Chemical Recovery Assessments
sewered and sent to the wastewater treatment plant or landfilled as solid waste. Lime
slaker grits generally are landfilled. There are opportunities for beneficial reuse of these
materials, such as using them as a cement additive. Although not generally a RCRA
hazardous waste concern, these wastes can exhibit the corrosivity hazardous waste
characteristic (which applies to wastes containing free liquids that have a pH < 2 or >
12.5). Generally, these materials are dewatered prior to disposal, and thus would not meet
the corrosivity characteristic under RCRA. However, if they do contain free liquids when
disposed of, some care must be taken to assure that the pH of these wastes is controlled to
be <12.5 so that the mill can handle the material as non-hazardous solid waste.2'3 Similar
concerns can arise for lime muds that are directed into surface impoundments or landfills
for disposal as a result of a process upset. In many circumstances, lime mud would be an
aqueous waste that could potentially qualify as a waste exhibiting the corrosivity
characteristic. Finally, it should also be noted that although the particulate matter removed
by the recovery furnace is another possible source of solid waste, mills generally will
recycle this material to the spent black liquor stream to recover any remaining cooking
chemicals and reduce solid waste handling.8 These RCRA issues are discussed in Section
5.4.
5.2.5 EPCRA Chemicals and Reportable Releases
Facilities will have to provide information on hazardous chemicals used in the
chemical recovery process to satisfy EPCRA's emergency preparedness provisions.
Appendix D contains a process-based list of chemicals that may be covered in an inventory
for a typical mill. In addition, the mill likely will have to file TRI Form R reports for on-
site air, water, and land releases of TRI toxic chemicals that originate from the recovery
process. Land releases include both on-site land disposals and off-site waste transfers that
contain TRI toxic chemicals. Finally, EPCRA/CERCLA emergency reporting could apply
to releases that are not federally permitted and that exceed a certain reportable quantity.
As noted above, although EPCRA concerns based on spent liquor spills may arise in or
near the chemical recovery area, all spent liquor concerns are addressed collectively in the
pulping area discussion (see Section 4.6). The remaining types of incidents are most likely
to be associated with the primary air emission sources. These EPCRA/CERCLA reporting
issues are discussed briefly in Section 5.3.
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Chemical Recovery Assessments
Section 5
5.3 Recovery Furnaces, Smelt Dissolving Tanks and Lime Kilns
These emissions units are
subject to significant CAA and State
regulation, including proposed MACT
requirements, and may raise
EPCRA/CERCLA reporting
obligations as well. This section
describes the:
! Emission points involved
! Air regulations that apply and
air compliance inspection
procedures
! EPCRA reporting obligations
and EPCRA inspection
procedures
5.3.1 Air Emission Points
Key Features of Primary Chemical
Recovery Equipment Systems
Significant PM air emissions with large
add-on control devices
Non-air emission issues generally are
minimal
Proposed MACT rule will expand
NSPS-type monitoring to existing non-
NSPS units
Effective use of computerized data
capabilities important for compliance
assessment
Recovery furnaces constitute a critical source of parti culate matter, TRS, SO2, NOX
and certain HAP emissions. The furnaces predominantly use electrostatic precipitators
(ESPs) for paniculate matter control. For TRS emissions, the key control method is
proper process operation, although black liquor oxidation (BLO) is used with older direct
contact evaporator (DCE) furnaces.4 Generally, specific controls are not applied for either
SO2 or NOX at this time. However, as States develop NOX reduction programs as part of
ozone attainment strategies, recovery furnaces may become increasingly subject to NOX
requirements.
Smelt dissolving tanks, although subject to federal and State regulations, are less
significant sources of parti culate matter and TRS than the recovery furnaces. For
particulate matter control, these tanks are generally equipped with low-energy scrubbers.
TRS emissions are generally controlled through proper process operation.4J
Lime kilns, like recovery furnaces, constitute a primary source of particulate matter
and NOX emissions in the chemical recovery process, as well as TRS emissions. For
particulate matter control, lime kilns are generally equipped with wet scrubbers (especially
venturi scrubbers), although ESPs may be used on new units. TRS emissions are
controlled through proper process operation.4 As with recovery furnaces, lime kiln NOX
emissions may become increasingly subject to ozone attainment NOX requirements.
This manual is intended solely for guidance and
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Section 5 Chemical Recovery Assessments
5.3.2 Applicable Air Regulations
5.3.2.1 Non-HAP Requirements
Basic emission limits. The federal New Source Performance Standards (NSPS)
for kraft pulp mills (40 CFR part 60, subpart BB) apply to recovery furnaces, smelt
dissolving tanks and lime kilns constructed or modified after September 24, 1976, for both
TRS and particulate matter emissions. Several States also regulate these sources for TRS
and PM, and some States also impose SO2 limits on these units. Also, for new or modified
emission units, a NSR permit may establish additional limits, including more stringent
requirements than NSPS.
Moreover, a recovery furnace that uses fossil fuel as a supplemental fuel source
may also be subject to standards for steam generating units, such as NSPS subparts D, Db,
DC, or state regulations applicable to combustion sources. Because recovery furnaces
generally use fossil fuels for only a small porion of their total fuel, these steam generating
unit standards may apply only in a limited fashion. The Agency has determined that
Subpart D applies to recovery furnaces only if fossil fuels account for > 10 percent of total
fuel usage. For Subpart Db, the SO2 percent reduction standards do not apply if fossil fuel
use is <30 percent. The Agency has prepared applicability determinations that further
discuss how these NSPS boiler requirements apply to recovery furnaces.12 (See also the
discussion in Section 8 about the various regulatory requirements that may apply to power
boilers at a kraft pulp mill.)
With the exception of these power boiler requirements, Figure 5-3 summarizes
which federal and state air regulations specifically apply to kraft mill recovery furnaces,
smelt dissolving tanks, and lime kilns. The following key features of these regulations
should also be noted:
! Recovery furnace TRS/SO2 standards. The NSPS regulations for TRS emissions
from recovery furnaces establish a general 5 ppm standard (corrected to 8 percent
O2), although there is a separate 25 ppm standard (same O2 correction factor) for
cross-recovery furnaces. Several of the states establish different TRS standards for
different types and ages of recovery furnaces. The standards are generally
expressed on a ppm basis, ranging from 3 ppm to 40 ppm, although some states use
a Ib/TADP format, ranging from 0.1 to 0.6 Ib/TADP. As noted below, several
states also have SO2 limits applicable to recovery furnaces. Nearly all of these
limits are on a ppm basis ranging from 200 to 2000 ppm.
! BLO requirements. It should be noted that vent gases from BLO systems are not
regulated under NSPS due to the prohibitive cost and declining use of BLO.4 A
few States and several California local districts, however, have established TRS
limits that apply to black liquor oxidation. These limits include both ppm limits (15
or 20 ppm) and Ib/TADP limits (0.2 or 0.5 Ib/TADP).
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Chemical Recovery Assessments Section 5
! Recovery furnace PM standards. For parti culate matter emissions from recovery
furnaces, the NSPS establishes a 0.044 gr/dscf standard (corrected to 8 percent O2)
as well as a 35 percent opacity standard. Most states regulate particulates on a
Ib/TADP basis, ranging from 2 to 4 Ib/TADP. One state, however, regulates
parti culates on the basis of lb/3000 Ib of black liquor solids, and others regulate
particulate matter emissions in a similar form to the NSPS. Several states also have
opacity limits (from 35-45 percent) that apply specifically to recovery furnaces;
while others will have general opacity standards that apply. One state, Michigan,
also has specific operating requirements for ESPs used to control particulate
emissions from recovery furnaces. Those types of O&M limits may apply as site-
specific permit limits in other states as well.
! Smelt dissolving tank TRS standards. For smelt dissolving tanks, the NSPS
establish a TRS limit of 0.033 Ib/ton of black liquor solids as H2S. Most states also
regulate TRS from this source on the basis of Ib/ton of black liquor solids, although
some establish limits on a Ib/TADP or ppm basis. Again, some states also establish
SO2 limits for smelt dissolving tanks in the same manner as for recovery furnaces.
! Smelt dissolving tank PM standards. For particulate matter emissions from smelt
dissolving tanks, the NSPS establish a limit of 0.2 Ib/ton of black liquor solids. Of
the states that establish particulate matter limits for this equipment, most use a
Ib/TADP format at varying levels.
! Lime kiln TRS standards. The NSPS establish an 8 ppm limit (corrected to 10
percent O2) for TRS. State TRS limits for existing lime kilns generally range from
20 to 40 ppm, although some jurisdictions use a Ib/TADP format ranging from 0.2
to 0.5 Ib/TADP. Some States also establish SO2 limits for lime kilns in the same
manner as for recovery furnaces.
! Lime kiln PM standards. The NSPS establish a limit of 0.067 or 0.13 gr/dscf
(corrected to 10 percent O2), depending on whether gaseous or liquid fuel,
respectively, is being used. Several States have also established specific PM
emission limits for lime kilns, although the format of the standards vary. Because
of the predominant use of wet scrubbers, the NSPS do not include an opacity
standard for lime kilns, and only a few States establish specific opacity limits for
this equipment. However, generic state opacity requirements may apply, as well as
specific permit conditions.
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Section 5
Chemical Recovery Assessments
Figure 5-3
Federal and State Emission Limits for Recovery Furnaces,
Smelt Dissolving Tanks, and Lime Kilns
Systems
Recovery
Furnaces
Smelt
Dissolving
Tanks
Lime Kilns
Regulations1
NSPS
TRS
Yes
Yes
Yes
PM
Yes
Yes
Yes
SO2
No
No
No
Opa-
city
Yes
No
No
State
TRS
AL, AZ, CA2,
FL, GA, ID, KY,
ME, MD, MS,
MT, NH, NM,
NC, OH, OR,
PA, SC, TN,
TX, VA, WA,
WI
AL, CA, FL,
GA, ME, MD,
MS, NH, NM,
NC, OH, OR,
PA, SC, TN,
TX, VA
AL, AZ, CA, FL,
GA, ID, ME,
MS, NH, NM,
NC, OH, OR,
PA, SC, TN,
TX, VA, WA
SO2
AK, ID, OR,
WA,WI
CA, MS, WA,
WI
CA, MS, WA,
WI
PM
AL, AK, FL,
ID, KY, MS,
NH, NM, OR,
TN, VA, WA,
WI
AL, CA, ID,
KY, NH, NM,
OR, TN, VA,
WA
AL, CA, ID,
KY, MS, NH,
NM, OR, TN,
VA, WA, WI
Opacity
FL, OR, TN,
VA,WA
OR,WA
OR, WA
1 Only regulations specific to kraft pulp mills are included. Other NSPS requirements (such as subpart Db)
or general State standards (such as generic opacity requirements) may also apply.
2 For purposes of this table, "CA" indicates that one or more air quality management districts in California
have specific applicable regulations.
Monitoring, reporting, and recordkeeping (MRR). The NSPS for kraft pulp
mills also establish MRR procedures for the recovery furnace, smelt dissolving tank, and
lime kiln emissions. TRS continuous emission monitoring systems (CEMS) are generally
required for recovery furnaces and lime kilns, but no TRS-related monitoring is required
for smelt dissolving tanks. An opacity CEMS is required after the ESP controls on the
recovery furnace, and control device parameter monitoring (pressure drop and scrubbing
liquid supply pressure) is required where a wet scrubber is used to control particulate
matter emissions from a smelt dissolving tank or lime kiln. Figure 5-4 summarizes these
NSPS MRR requirements, and the following additional issues should be noted:
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Chemical Recovery Assessments Section 5
! ESP monitoring on new lime kilns. Although ESPs are used on some new lime kiln
installations, the NSPS do not have any required monitoring for this control option
when used for lime kilns. Even with this regulatory gap, states can still require an
opacity CEMS or other monitoring as part of the new source review permitting
process for these new kilns.
! Recovery furnace excess emission allowance. The NSPS contain specific
exceptions for a limited duration of excess emissions of TRS or opacity from
recovery furnaces. For TRS emissions, excess emissions of one percent or less are
not considered indicative of a violation of 40 CFR 60.1 l(d) so long as the owner or
operator can document proper O&M for minimizing emissions. For opacity, the
exception is 6 percent or less. These periods exclude excess emissions caused by
excused start-up, shutdown or malfunction conditions. Although not explicit in the
NSPS, EPA has noted that these allowances must be taken into account in
determining whether a facility has violated the TRS and opacity limits (not just the
§ 60.1 l(d) general O&M duty).5 These excess emission allowances do not apply to
the smelt dissolving tanks or lime kilns.
! Scrubber parameter reporting. The NSPS do not require a mill to establish
parameter excursion levels or report parameter excursions. However, Part 70
operating permit requirements (including both Part 70 periodic monitoring and Part
64 compliance assurance monitoring, as applicable) likely will result in permit
conditions requiring the mill to both establish parameter excursion levels and submit
semiannual reports. Moreover, these excursion levels and reporting requirements
would be required explicitly under the proposed MACT rules.
! TRS data availability. In previous NSPS applicability determinations, EPA has
noted that a valid data hour requires both the TRS CEMS data and the O2 data
used to correct to a standard O2. Although excess emissions are calculated based
on 12-hour averages, EPA has indicated that no minimum number of valid hours is
necessary to calculate the 12-hour average.6
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Section 5
Chemical Recovery Assessments
Figure 5-4
NSPS Monitoring, Reporting and Recordkeeping Requirements for Recovery
Furnaces, Smelt Dissolving Tanks and Lime Kilns
Process/
Pollutant
Monitoring Requirements
Reporting and Recordkeeping
Requirements
Recovery
Furnaces/
TRS
Emissions
TRS CEMS requrred
Span generally set at 30 to 50 ppm
O2 CEMS required to correct to a
standard % O2
Located downstream of control devices
Temperature monitoring possible
alternative in some situations under NSPS
(and State) regulations
Note: Other parameter monitoring
possible in some State regulations on
case-by-case basis
Calculate and record on daily basis 12-hour
average TRS concentrations (corrected for
O2) for the two consecutive periods of each
operating day
Average equals the arithmetic mean of the
appropriate 12 contiguous 1 -hour average
TRS concentrations
Excess emissions not indicative of 40 CFR
60.1 l(d) violation if occur 1% or less of
operating time
Recovery
Furnaces/
PM Emissions
! Opacity CEMS required
Calculate and record each 6-minute average
Report as excess emissions any 6-minute
average that exceeds the applicable opacity
standard
Excess emissions not indicative of 40 CFR
60.1 l(d) violation if occur 6% or less of
operating time
Wet Scrubbers
(Smelt
Dissolving
Tanks & Lime
Kilns)/PM
Emissions
Continuous pressure drop and scrubbing
liquid supply pressure monitors (accuracy
specification: ±300 Pascals for pressure
drop and ±15% for supply pressure
monitors)
Note: Other parameter monitoring
possible in some State regulations on
case-by-case basis
! Record applicable measurements once per
shift
! No reporting applies
5.3.2.2 Proposed MACT Rule Requirements
At the same time that the
Cluster Rules were promulgated, EPA
proposed MACT requirements for
certain chemical recovery equipment
systems. (See 63 FR 18753, April 15,
1998.) Because EPA has not yet
finalized these standards, they are not
discussed further in this manual.
NOTE! These MACT standards are not
yet final. Check http://www.epa.gov/
ttn/uatw/pulp/pulppg.html for new
developments.
This manual is intended solely for guidance and
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Chemical Recovery Assessments Section 5
5.3.2.3 Asbestos NESHAP Requirements
In addition to the basic emission limits applicable to the recovery boiler and lime
kiln, a number of mills may have asbestos-containing material used to insulate steam pipes
or used for similar purposes in the chemical recovery area. Any demolition or renovation
activity that involves the asbestos-containing material may be subject to the requirements in
40 CFR Part 61, Subpart M. Generally, Subpart M requires prior notice of
demolition/renovation activity that will disturb a certain amount of asbestos and requires
compliance with a number of work practice and waste disposal requirements. Figure 5-5
briefly summarizes these requirements.
5.3.3 Air Inspection Techniques
5.3.3.1 Pre-inspection Steps
As discussed in Section 3, there are a number of steps that should be routinely
taken prior to conducting an actual on-site inspection, including file and permit reviews.
As part of this review and to plan the on-site inspection, the inspector should consider at
least the following items:
Process diagrams. Obtain a simplified diagram of the affected units and note what
control(s) are employed. This type of diagram may be available in the Part 70 operating
permits file if submitted with the application. At this stage, the inspector should also
attempt to understand how the control rooms for the operations are set up, what process
and control parameters can be evaluated from the control rooms, and what distributed
control system (DCS) data capabilities are on-site. A significant part of the on-site
inspection for these process units will occur in the control rooms, and an upfront
understanding of what data are available — both real-time data and historical data from a
DCS — can streamline the on-site investigation phase.
Evaluation of periodic monitoring reports. The NSPS for kraft pulp mills
require that CEMS data for TRS emissions and opacity be recorded and submitted in a
semiannual excess emission report (EER) for recovery furnaces. An EER is also required
for a lime kiln TRS CEMS. The NSPS do not require reporting of wet scrubber control
device parameters, but such reports may be required under a Part 70 permit or as a result
of the proposed MACT rules. The inspector should review any reports that have been
submitted since the last inspection in order to prioritize the need for follow-up while on-
site.
The inspector should confirm that any periods of excess emissions indicated in the
reports are within regulatory limits. If not, the inspector may need to evaluate on-site
records that document the reasons for the excess emissions. The review will be necessary
to evaluate claims of allowable excursions that may apply, including both regulatory
allowances for a certain percent of excess emissions, and excused startup, shutdown, or
malfunction periods.
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Section 5
Chemical Recovery Assessments
Figure 5-5
Asbestos Demolition and Renovation (D&R) Requirements
(40 CFR Part 61, Subpart M)
Regulatory Area
Requirements
Applicability
Covers regulated ACM (RACM) only: friable asbestos, certain "Category I"
nonfriable material with >1% asbestos that has become friable, or other
"Category II" nonfriable material with >1% asbestos that likely will be
crumbled/pulverized or be reduced to powder as a result of the D&R activity [see
40 CFR 61.141 for all definitions]
For pipes, the D&R activity must affect > 80 linear meters (260 linear feet)
For other facility components, the threshold is > 15 square meters (160 square
feet)
For planned renovations, consider all planned activities for the calendar year in
determining total amount of RACM that will be disturbed
A number of exceptions and alternatives also apply [see 40 CFR 61.145(a)]
Notice
Requirements
General rule is written notice > 10 working days prior to the removal activity
begins (i.e., any activity that could disturb the RACM), or at least 10 days before
end of the calendar year preceding the year in which applicable planned
renovation activity occurs
Follow-up notice required if the amount of asbestos affected changes by >20%,
or if start date of work changes
Exceptions apply for emergency D&R activities
Regulations prescribe elements that must be included in the notice and require
use of form included in Subpart M (or a similar form)
Work Practices
General rule is to remove RACM prior to any activity that could break up/disturb
the RACM or preclude access for subsequent removal
Wetting requirements apply in numerous stripping and other situations, although
use of ventilation system to a glove bag and leak tight wrapping with no visible
emissions is alternative for stripping procedures, and leak tight wrapping is
alternative to wetting after removal. Other wetting exceptions apply
Careful handling procedures to preclude disturbing the RACM apply
Other specific requirements apply
Waste Disposal
Additional work practice standards apply for handling RACM
Must deposit the RACM at a landfill that meets specific Subpart M requirements
A RCRA-type manifest system must be used by the facility, with follow-up
reporting required if the generating facility does not receive a receipt from the
disposal facility within 45 days
Other specific requirements apply
Evaluation of episodic malfunction reports. The inspector should review
malfunction reports submitted since the last inspection, if available. If the reports identify
corrective actions to be taken by the source, the inspector should note the need to verify
during the on-site inspection that the corrective steps were actually taken and that they
resolved the problem.
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Chemical Recovery Assessments Section 5
Also, if malfunction reports are required for all or some specified subset(s) of
malfunctions, the inspector should note any discrepancies between the malfunction reports
submitted and claimed "malfunction" periods in an EER. Significant discrepancies indicate
errors in EER or malfunction reporting that should be addressed with the facility either as
part of the inspection or by agency compliance staff responsible for processing periodic and
episodic reports.
5.3.3.2 On-site Inspection Steps
The recovery furnace and the lime kiln generally are a focal point for on-site
inspections of pulp mills. Except for visible emission observations and some potential
visual checks of the control equipment, the on-site inspection for these units will focus on
evaluating control room data. Modern mills are likely to have a single control room that
covers both recovery furnace and smelt dissolving tank operations. The room may have a
DCS with critical process-related data, as well as housing the CEMS/parameter data. The
lime kiln generally will have a separate control room, and may include other operations
such as the slaker, causticizer and receiving/conveying units.
The possible steps for a routine level 2 inspection include:
Permit verification. Verify that the permit properly identifies the recovery
furnace, smelt dissolving tank and lime kiln. The inspector should also assess whether any
modifications have been made, including changes in production that involve a physical or
operational change, that could trigger NSR. NSR applicability determinations are complex
and a full overview of this issue is beyond the scope of this manual. However, examples of
possible NSR concerns include:
! Increasing black liquor solids concentration fired in recovery furnaces or
incremental increases in mass of black liquor solids firing. These changes in
operation can result in increased recovery furnace NOX emissions and increased
emissions of other pollutants at other units by debottlenecking production.
! Underestimating SO2 emissions from new recovery boilers. Oil firing capacities
need to be considered carefully in the NSR permitting process.
Visible emissions observations. Check for visible emissions if weather conditions
permit. Optimally, formal visible emission observation (VEO) tests (i.e., Method 9 or state
equivalent) should persist for at least 30 minutes (one reading each 15 seconds, and then
averaged into 6-minute intervals). Plot the 6-minute averages to determine if any cyclic
patterns are present, and note the timing and duration of all significant opacity spikes. For
an ESP, conduct the VEO concurrently with a complete rapping cycle if possible. The
following additional considerations apply:9
! ESP emissions. Check for any condensing plume at the stack discharge. A
condensing plume is often indicated by a clear zone directly above the stack, is
typically bluish-white or yellow-white in color, and does not disperse like steam.
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Section 5 Chemical Recovery Assessments
Where visible emissions are high or a condensing plume is visible, the inspector
should conduct a level 2 follow-up inspection of the recovery furnace or lime kiln
ESP (as outlined in Figure 5-7).
! Wet scrubber emissions. Conduct a qualitative check of visible emissions for clear
indications of potential problems. A formal VEO likely will be difficult because of
the condensed water droplets in the plume exiting the wet scrubber. The inspector
must observe the plume at a point immediately downwind of the point where the
condensed water droplets evaporate. The residual plume at this point is often
bluish-white, brownish-white or gray; while, the portion of the plume dominated by
water droplets is often a bright white. It should be noted, however, that VEOs of
the residual plume are not always possible because plumes from various sources
may have merged, or high relative humidity will result in long distances before the
water droplet plume dissipates. Also, for the smelt dissolving tank in particular, the
location of the stack within the mill in relation to other mill facilities (such as the
recovery furnace) may make it difficult to observe the plume from an appropriate
viewing angle.
Evaluation of TRS CEMS data. Both the recovery furnace and lime kiln may
have a TRS CEMS installed. The CEMS data should be the focal point for TRS
compliance for these units. The inspector should confirm that the monitors are functioning
properly by reviewing the most recent QA/QC checks, such as daily calibration results. In
addition, if the periodic reports include excessive monitor downtime, the inspector should
follow-up to see if the monitor availability problems have been corrected. The inspector
can evaluate monitor data availability records since the last report period, although
interviews with mill personnel can also be effective to assess the causes of the problems
and the mill's approach to correcting the problem.
If the monitors are functioning properly, real-time data can be recorded to
document conditions at the time of the inspection. The inspector should also determine
what CEMS data trend analysis capability is available from the DCS or other PC-based
system. The historical data can then be reviewed to identify any trends in the emissions
profile of the units, or particular periods for which further review may be warranted.
If problems are detected, the follow-up inspection should focus on the recovery
furnace BLO (if used) or process operations designed to assure proper combustion of the
TRS components. These inspection elements are discussed in the following subsections.
Evaluation of proper operation of control equipment A critical interest of a
level 2 inspection will be to evaluate whether control equipment is being properly operated
and maintained. The appropriate steps for this phase of the inspection will depend on the
control equipment used for TRS (e.g., BLO systems) and particulate matter (e.g., ESPs or
wet scrubbers).
Black liquor oxidation systems. Malfunctions in the BLO system used with direct
contact evaporator recovery furnaces generally result in reduced oxidation efficiency,
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Chemical Recovery Assessments
Section 5
which produces elevated TRS concentration from the recovery furnace. These increased
concentrations will be indicated by a TRS CEMS, if required. Where a BLO is used on a
DCE furnace that is not equipped with a TRS CEMS, a basic inspection should include
documenting proper operation and maintenance of a kraft BLO system. Some key possible
BLO malfunctions and associated effects that result in increased outlet liquor sulfidity and
TRS emissions are summarized in Figure 5-6.
Figure 5-6
BLO Malfunctions and Associated Effects7
Malfunctions
Reduced air flow volume through
oxidation tank
Plugging of air sparge
Increased liquor flow
Liquor foaming
Increased inlet liquor sulfidity
Primary Effect Causing Increased TRS
Emissions
Reduced oxidation of sodium sulfide
Stratification of liquor air column and reduced
contact
Decreased liquor residence time and oxygen
adsorption
Foam carryover limits system liquor volume and
blowing rates
--
Basic ESP Assessment Steps
! Conduct VEO
! Check opacity CEMS data
! Evaluate T-R set electrical data
Electrostatic precipitators. In
addition to the VEO (discussed above),
the inspector should evaluate opacity
CEMS data and transformer-rectifier
(T-R) set electrical data as part of a
basic inspection for a unit controlled by
an ESP. These evaluations can involve
direct comparison of the data with
emission or operating limits contained in the mill's permit, but should also involve
comparisons with baseline conditions established in prior inspections, a recent performance
test, or through accepted engineering principles. See the general discussion of baseline
inspection techniques in Section 3.
The following recommendations and discussion summarizes material presented in
the Baseline Inspection Techniques: Student Manual9 and EPA's Operation and
Maintenance Manual for Electrostatic Precipitators*, and the inspector may want to
review those resources for further information (see Section 1 for information on obtaining
these materials).
! Opacity CEMS data. First, check the operating condition of the opacity monitor by
assuring that daily QA/QC checks are within acceptable limits. The inspector can
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Section 5 Chemical Recovery Assessments
review the most recent calibration data or request that the monitor be placed in the
calibration mode with respect to zero and span. Average opacity monitor readings
also can be compared with average Method 9 VEO values for identical periods. A
major deviation between the values may indicate possible monitor error.
If the monitor appears to be functioning properly, compare the opacity CEMS data
with the permitted opacity limit. Even if the CEMS data are below the permitted
opacity limit, the inspector also should conduct a baseline analysis by comparing the
average opacity data for selected days with respect to baseline values for the same
process operating load. This type of comparison can identify emission problems
before opacity exceedances occur and possibly before damage has occurred to
precipitator components. Check with mill personnel to determine which DCS
utilities may facilitate this type of analysis. Where average opacities are
significantly above baseline levels, the inspector should conduct a level 2 follow-up
inspection of the ESP (outlined in Figure 5-7).
! T-R set electrical data. Each of the T-R sets is connected to a control cabinet that
contains all of the electrical meters necessary to evaluate the operating conditions
inside an electrical field. The inspector should therefore determine at the outset how
the T-R sets and control cabinets are arranged. After having determined the layout
of the T-R sets, the inspector should record the electrical data for each chamber, as
indicated by the corresponding meters, starting with the set closest to the inlet and
moving toward the set closest to the outlet.
NOTE! The example assessment form in
Appendix E includes an example format
for collecting T-R set data.
The voltage, current, and spark
rate for each of the chambers
should be compared against
baseline data from the most
recent performance test. If the
data indicate that all or most of
the fields in a chamber have shifted in the same direction at about the same time, a
shift in the prevailing resistivity range has probably occurred. When only one field
is inconsistent with others in the same chamber, however, it is more likely the result
of mechanical or electrical problems inside that field. Note that, because of the
prevalent use of saltcake as a make-up in the chemical recovery process, high
resistivity problems are generally less of a concern for recovery furnace ESPs than
for other ESP applications.
Where the T-R set data indicate that impaired electrical conditions exist due either
to resistivity shifts or component failures in one or more fields, the inspector should
proceed with a more thorough inspection of the ESP. Suggested level 2 follow-up
inspection techniques that correspond to specific symptoms are summarized in
Figure 5-7.
The inspector also should verify that appropriate process adjustments were made
during periods when portions of the ESP were down for maintenance or repairs. ESP
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Chemical Recovery Assessments
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efficiency is related to gas flow, and recovery furnace/lime kiln ESP applications should be
designed to handle the maximum rated flow of the unit. If portions of the ESP are taken
off-line for maintenance or repairs, the operators may have to reduce gas flow to the ESP.
For the recovery furnace in particular, the inspector may want to evaluate black liquor
solids firing rate and opacity data for any periods since the last inspection when the ESP
was operated in this manner. Plant operator interviews can identify the appropriate periods
for evaluation. Depending on the DCS capabilities, the inspector can review the necessary
process parameter and opacity CEMS data for the relevant period through DCS historical
data or other available records. This type of review may be conducted during the
inspection, or the inspector may request that copies of the relevant data be made for
subsequent review after the on-site inspection.
Figure 5-7
ESP Level 2 Follow-up Inspection Points and Techniques9
Symptoms
Inspection
Points
Inspection Techniques
! Frequent opacity spikes
("puffing")
! Currents are low in isolated
areas
! Resistivity is particularly high
or low
Rapper Operation
Inspect rappers to determine if they are working
Compare rapper activation frequencies with opacity
spiking frequency indicated by opacity monitor
Note any need to adjust rapping frequencies and
intensities for resistivity conditions in each portion of
precipitator
! General indications of poor
ESP performance
Alignment
Records
Review collection plate/discharge electrode alignment
records
If resistivity is moderate-to-high, collection plate-to-
discharge electrode spacing should be approx. x ±
0.05 in., where x is the design spacing
If resistivity is low, spacing can be x ± 1.0 in.
! T-R set electrical data indicate
that chronic problems have
resulted in temporary loss
("tripping") of fields
Component
Failure Records
! Evaluate component failure records to identify
underlying causes
Increased inlet to outlet
temperature drop. Normal drop
generally ranges from 5-25
degrees C
Increased O2 from inlet to
outlet. Increases of >0.5% may
signal a problem
Air Infiltration
Listen for characteristic air rushing sound
Look for areas of corrosion around the unit
Compare inlet and outlet temperatures, checking for a
significant increase in baseline value for temperature
drop across the unit
Compare inlet and outlet O2 concentrations (if
available), checking for a significant increase in
concentration
! Consistently high amount and
duration of excess emission
periods
Start-up/Shut-
down Procedures
Review opacity monitor records to ascertain start-
up/shut-down frequency
Check to see if precipitator is energized in a
reasonable time after start-up of recovery furnace
(excessive time periods before energizing cause very
high particulate emissions)
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Section 5 Chemical Recovery Assessments
Wet scrubbers. Particulate emissions from lime kilns most often are controlled by
venturi scrubbers, while smelt dissolving tank vents are generally controlled by low-energy
scrubbing systems.7'12 A basic level 2 inspection of these wet scrubbers involves a
combination of visible emission observation of the stack plume, a check of control system
parameters, to the extent data are available, and visual check of the control device:7
! Conduct a VEO. Condensed water droplets likely will interfere with Method 9
VEOs of emissions from a wet scrubber. The inspector still should conduct a
qualitative observation to check for obvious emission problems.
! Obtain operating data from the available control system monitors. Typical
parameters that may be monitored include pressure drop across the scrubber and
scrubber liquid supply pressure (monitors required under NSPS and MACT), as
well as inlet and outlet gas temperature, and, in some cases, scrubber water
temperature.7'10 As part of this evaluation, the general operating condition of the
monitors should be considered. Under the NSPS and proposed MACT rules, the
inspector should assure that the facility can verify that the accuracy requirements
for pressure drop and liquid supply pressure monitors are satisfied. If these
requirements do not apply, the inspector should interview operating staff to
determine if any self-imposed QA/QC procedures are followed; if so, those results
may be checked. Without QA/QC data, only a qualitative judgment as to the
monitor condition can be made, and the final assessment report should note this
limitation.
To the extent possible, the monitoring data obtained during the inspection should
be compared not only with any parameter excursion values established by permit or
the proposed MACT rules, but also with values from the design, baseline, or
previous inspections to determine if there has been a significant change in
performance of the scrubber or in the number of control equipment malfunctions.
For low-energy scrubbing systems, performance can change significantly with only
a slight shift in pressure drop.7
! Check physical condition. The inspector should visually check the scrubber and
surrounding areas for any physical evidence of scrubber malfunction, such as the
droplet reentrainment indicators listed in Figure 5-8.7 This type of assessment is
particularly important if the other assessment techniques indicate a potential
problem.
If the basic assessment indicates potential compliance problems, the inspector
should conduct appropriate follow-up assessments. Figure 5-8 summarizes a few of the
more common indicators of suboptimal scrubber performance, as well as suggested follow-
up inspection points.
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Chemical Recovery Assessments
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Figure 5-8
Indicators and Possible Causes of Suboptimal Scrubber Performance9
Indicators of Suboptimal Performance
Potential O&M Causes
Droplet reentrainment. as evidenced by:
! Obvious fallout of solids-containing droplets
within 50 yards downwind of stack
! Discoloration of adjacent surfaces
! Mud lip around stack
! Heavy drainage from open ports on stack
! Ice buildup on structural steel and adjacent
surfaces near stack (during cold weather)
! Mist eliminator cleaning frequency (solids build-
up on mist eliminator can cause droplet
reentrainment)
Significant decrease (more than several inches) in
static pressure drop during peak gas flow periods
Erosion of adjustable throat mechanisms
Intentional changes in position of adjustable
throat mechanism
Decrease in gas flow rates
Severe decrease in recirculation liquid flow rate
Decrease in liquid flow rate such that liquid-to-gas
ratio is significantly below baseline level
Decrease in liquid supply header pressures at
scrubber inlet
Decrease in recirculation pump discharge
pressures
Pipe freezing or blockage
Centrifugal pump cavitation
Outlet gas temperature more than 5°Fto 10°F above
adiabatic saturation temperature (indicates poor gas-
liquid distribution)
! Higher-than-normal supply header pressures
! Apparent pipe or header freezing
! Malfunctioning adjustable throat linkages or
actuators
Evaluation of proper operation of process equipment. The inspector also
should check process parameters to assure that the process equipment is properly operated
and maintained. This type of process evaluation is especially important where potential
excess emissions are suspected. Of the three emissions unit types, this type of check is the
most critical for the recovery furnace.
Recovery furnaces. The
uncontrolled particulate matter and
TRS emission rates from a recovery
furnace depend on a number of
interrelated operating variables,
including:
NOTE! While reductions in TRS and
SO2 emissions may result from the
optimization of certain process variables,
operation of the recovery furnace under
these process conditions can also increase
uncontrolled particulate emissions.
Firing rate
Black liquor heat value
Black liquor concentration (solids content)
Total combustion air (primary and secondary air)
Char bed temperature
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Section 5
Chemical Recovery Assessments
Figure 5-9 summarizes some of the more common O&M practices related to these
variables that may result in an increase in uncontrolled emissions.
Figure 5-9
Recovery Furnace O&M Practices Affecting Uncontrolled Emissions
Operating
Parameter
Emission Concern
O&M/Assessment Technique
Firing Rate
Higher-than-design firing rate (flue gas
volume) leading to:
! increased uncontrolled PM
emission rate and concentration
! nature of particulates altered
! increased TRS emission rate
! decreased ESP efficiency
Establish baseline comparison of
boiler firing rate and (1) grain loading
air volume and (2) temperature at the
ESP. These monitor parameters would
be expected to increase with increased
firing rate
Black Liquor Heating
Value and Solids
Content
Increased black liquor heating
value/solids content leading to
increased PM emission rate, especially
for heating value increases
Difficult to control/evaluate due to
significant daily variations. Ensure
inlet grain loading remains within
allowable variation for specific ESP
Total Combustion Air
(excess air) (includes
primary and secondary
air)
Insufficient total combustion air
leading to "black out" (incomplete
combustion)
Check total amount of combustion air -
- the amount needed for complete
combustion is normally between 110
and 125 percent of theoretical air
Total combustion air greater than
125% of calculated theoretical
(stoichiometric) air leading to:
! increased PM emission rate
! increased flue gas volume to ESP
! increased SO3 formulation, causing
particulates to become sticky and to
build-up on ESP collection plates —
reduces ESP power input and
efficiency
Primary air exceeding 45% of total air
volume leading to:
! sharp increase in PM emission rate
! increased TRS emission rate
Graph (using DCS if possible) the
relationships between percent excess/
primary air and:
! particulate loading to ESP
! visible emissions observed from
ESP
! air volume to ESP
! flue gas temperature to ESP
Also, check electrical data — possible
indicators of buildup on ESP collection
plates include high secondary voltage
(> 50 kV) and low secondary current
(< 100 mA) in inlet fields
Char Bed Temperature
Increased char bed temperature
leading to:
! increased PM emission rate
! increased flue gas volume to ESP
Assure proper combustion air and
firing rate operation using techniques
outlined above
Smelt dissolving tanks. To control TRS emissions from smelt dissolving tanks, the
water used in the tanks and the associated scrubbers should contain minimal amounts of
reduced sulfur compounds. If an odor problem from the smelt dissolving tank is suspected,
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Chemical Recovery Assessments
Section 5
the inspector should obtain measurement data for the concentration of reduced sulfur
compounds contained in the inlet water and scrubbing liquid.
Lime kilns. If there is an indication of a problem with the TRS or particulate
emissions from the lime kiln, the inspector should check the kiln rotation rate and O2 levels
exiting the kiln. Operation outside of normal operating ranges could increase emissions.
In addition, if a permit limits the type and/or quantity of fuel for the kiln, fuel usage data
may be reviewed to verify that the permit levels are satisfied. Finally, as discussed in
Section 5.4, proper operation of lime mud washers is important for proper operation of the
kiln. To the extent emission problems in the kiln are occurring, an analysis of the lime mud
washers may be necessary to determine the cause of the problem. Figure 5-10 summarizes
these considerations.
Figure 5-10
Primary Lime Kiln O&M Practices Affecting Uncontrolled Emissions
Operating
Parameter
Kiln rotation rate
O2 level
Mud sodium content
Emission Concern
Increases above normal operating
ranges can increase emissions
Increases above normal operating O2
levels exiting the kiln can increase
emissions
Increased sodium in lime mud because
of mud washing problems can lead to
increased H2S emissions and fine
particulates
O&M/Assessment Technique
Compare rate to normal baseline rates
using process monitor
Compare O2 levels to normal baseline
levels using O2 process monitor, if
available
Check sodium content of lime mud
entering kiln. Generally, should be in
0.5-1% range; 2-2.5% indicates likely
problem
Asbestos NESHAP compliance evaluation. Finally, the on-site inspection
provides an opportunity to screen for compliance with asbestos demolition and renovation
(D&R) notice requirements. The inspector should interview mill personnel to determine
whether any maintenance, repair or similar construction activity conducted since the last
inspection involved insulated piping or similar locations likely to involve asbestos-
containing materials, and, if so, whether asbestos compliance issues were considered and
properly addressed. Obtain copies of any notice provided concerning the D&R activities.
If there was activity but no notice was filed, follow-up to determine whether asbestos-
containing materials were involved, and if so, whether the applicability provisions of
Subpart M were triggered - see the summary of Subpart M requirements in Figure 5-5.
Also, verify that the wastes containing the removed asbestos-containing material were
properly sent to a waste disposal site that meets the requirements of Subpart M. The mill
should have copies of all waste shipment records required under Subpart M.
For asbestos D&R inspections conducted in response to an asbestos D&R
notification, see the procedures outlined in applicable Agency guidance, such as Guidelines
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Section 5 Chemical Recovery Assessments
for Asbestos NESHAP Demolition and Renovation Inspection Procedures (EPA 340/1-90-
007, November 1990).
5.3.4 EPCRA Issues
General concerns The basic M^^. c ,. ^,
regulatory requirements for EPCRA *°™ See Appendix D for overview of
are not process-specific but rather EPCRA re§ulatlons and basic assessment
apply on a facility-wide basis. Thus the
basic requirements of EPCRA are
discussed in Appendix D.
For the major air emission points in the chemical recovery area, the key EPCRA
issues will be to quantify releases of toxic chemicals to the air, water, or land in the annual
Toxic Release Inventory (TRI) report (known as the "Form R" report), and to comply with
emergency reporting requirements. The emergency reporting requirements apply under
both EPCRA and CERCLA. The releases subject to these emergency reporting
requirements are releases that are not federally permitted and that exceed certain reportable
quantities. For certain releases that are "continuous" and "stable in quantity and rate," the
mill may be able to use special reporting options so that a notice is not required after each
such release. See the discussion of continuous releases in Appendix D for further detail on
the differences between standard emergency reporting and reporting of continuous
releases.
For this process area, the air emissions from the recovery boiler and lime kiln are
one potential source of releases that could be subject to EPCRA and CERCLA emergency
reporting. These emissions units likely will emit the following air pollutants (and may emit
others) that are listed chemicals subject to emergency reporting under CERCLA and/or
EPCRA (reportable quantity in lb/24-hour period is also provided):
! Sulfur dioxide (500 Ib) ! Nitrogen dioxide (10 Ib)
! Hydrogen sulfide (100 Ib) ! Methyl mercaptan (100 Ib)
! (See other potential chemical releases associated with kraft pulp mill air emission
sources listed in Appendix D)
The determination of what constitutes a "federally permitted release" can be
complex. However, it is important to note that if the mill as a matter of normal operations
emits an applicable pollutant in amounts that exceed the reportable quantity and there is no
emission limit established for the pollutant, then the emergency reporting provisions likely
apply. For instance, a mill should file appropriate emergency reports if no NOX emission
limit applies to the recovery boiler or lime kiln, and the unit normally emits more than 10
pounds of NO2 in a 24-hour period. In this circumstance, the reduced continuous release
reporting options likely are available, as discussed in Appendix D.
Inspection considerations. The EPCRA compliance assessment generally will
focus initially on a records review. The inspector should review the following materials:
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Chemical Recovery Assessments Section 5
! Emergency preparedness information. These obligations are not process-specific,
and thus the basic assessment considerations are covered for all facility operations
in Appendix D to this manual.
! TRI Form R. Check to ensure that the form is on file, and that the source has
adequately considered releases associated with the recovery furnace, smelt
dissolving tank and lime kiln. Also, ask to see the estimation technique being used.
If the estimation technique involves an assumed reduction efficiency for control
methods, make sure that the assumed efficiency is consistent with the overall
efficiency that the mill is achieving. The overall assumed efficiency should account
for any excess emission releases in a manner consistent with the actual percent of
operating time such releases occur. Uncontrolled emission episodes or periods of
reduced control efficiency can have a significant impact on the estimate of total
releases.
! Emergency notifications. Request documentation that the mill has filed all required
notices.
If an agency air inspector plans to screen for EPCRA compliance, the inspector
should confirm the necessary information with the facility contact during the opening
conference or just in advance of the closing conference. For an announced inspection, the
inspector should ask the source to have ready EPCRA-related documentation so that the
screening check can be performed without interrupting the main focus of the inspection. A
screening checklist is included as part of the example assessment form in Appendix E.
In addition to a screening-type records review inspection, an EPCRA inspector may
want to conduct further assessments to identify potential compliance concerns with
emergency notification requirements. As one technique, the inspector first can check
excess emission reports, malfunction reports, and citizen complaints since the previous
inspection. The inspector then should cross-check those incidents with notification records
identified in EPA's ERNS database, records on file with the state/local emergency
coordinator, or records requested from the mill. If this type of investigation identifies
episodes of abnormal emissions in which no notification was provided, the inspector should
consider a follow-up investigation to determine if reportable quantity thresholds were
exceeded.
5.4 Other Miscellaneous Equipment Systems
There are a number of handling, storage and other process equipment systems in
the chemical recovery area. These equipment systems generally involve some particulate
air emissions as well as the primary wastewater and solid waste discharges associated with
the recovery area. This section first provides a brief overview of the various equipment
systems involved, and then discusses, respectively, air, water, RCRA and EPCRA/
CERCLA regulatory issues and inspection procedures for these miscellaneous equipment
systems.
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Section 5 Chemical Recovery Assessments
5.4.1 Emission/Discharge Points
As noted on Figure 5-1 (the equipment system diagram in Section 5.2), there are a
number of small equipment systems within the chemical recovery process. The most
important of these systems for environmental compliance include:
! Green liquor preparation. The green liquor produced in the smelt dissolving tank
contains "dregs," or insoluble impurities. These dregs are removed in the green
liquor clarifier and then washed in a dregs washer. The wash water is pumped to
the mud washer, while the washed dregs are handled as a solid waste. The dregs
may be landfilled or included with wastewater sent to the wastewater treatment
plant.
! Slaker/causticizers. The clarified green liquor is pumped to storage for
introduction into the slaker. The green liquor and lime react to form sodium
hydroxide and calcium carbonate. Unreacted material ("slaker grit") is removed by
a mechanical rake and must be handled as a solid waste. The causticizers are used
to carry the reaction to equilibrium; reacted material is pumped to a clarifier to
separate the lime mud and the white liquor.
! Lime mud washers. Lime mud washers are used to reduce the sodium and sulfide
content of the lime mud before its use in the lime kiln. The waste wash water can
be used to dissolve smelt in the smelt dissolving tank and/or as a scrubbing medium
for air emission scrubbers. The mud washers also have their own air emission
controls. As noted above, process upsets resulting in poorly washed mud can have
adverse impacts on the lime kiln TRS emissions.
! Storage and handling equipment. Raw material storage and handling systems in
the chemical recovery process area are another potential source of air emissions.
These systems include the silos and conveyance systems for raw lime and the
conveyor used to handle hot lime from the lime kiln. Depending on the mill, these
systems may be open or enclosed and use different conveyance techniques. The
most common control device used for these systems are hooding and venting to a
fabric filter.
5.4.2 Applicable Air Regulations and Inspection Techniques
These miscellaneous source are generally not subject to significant regulation, and
neither NSPS or NESHAP regulations apply. However, at least one State (VA) does have
a specific regulation for slaker paniculate matter emissions and most states will have at
least generic opacity standards that will apply to these systems. Because these equipment
systems are a relatively low priority, a basic screening check is the most likely assessment
technique for an agency inspection. Basic process and (less likely) control device
parameter data may be available in the lime kiln control room. The following streamlined
procedures should be considered:10
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Chemical Recovery Assessments Section 5
! Slaker/Causticizers. The slaker and causticizers are often ducted together. Air
flows from these units generally have low volume and low concentrations. If there
are any controls, the controls often will consist of simple equipment such as a spray
nozzle. As a screening check, verify that the controls are operating, and then
conduct a visual opacity check if warranted.
Note that the green liquor storage tanks may be subject to volatile organic liquid
storage tank requirements under subpart Kb of the NSPS (for new/modified tanks
after 7/23/84). As discussed in Section 4.6.1 in the context of turpentine and black
liquor storage tanks, the only Subpart Kb requirement that is likely to apply is a
requirement to maintain records of the design capacity of the tanks.
! Mud washers. The mud washers will have their own controls. These systems are
small and vulnerable to upset conditions. General opacity requirements may apply
and can be checked. Because the systems are small, monitoring data will be lacking
but, if available, an inspector can check hood static pressure data (to make sure the
hoods are collecting the emissions) and pressure drop or liquid flow rate for
scrubbers. Process data on mud feed rate and sodium content of mud feed to the
kiln can also be checked to determine if the washers are operating properly. A
sodium content of 0.5 to 1% would be considered typical; a content of 2 to 2.5%
generally indicates a potential process problem.
! Storage and handling equipment. The storage silos, bucket elevators, and similar
equipment at many mills will have small fabric filter controls. The inspector should
conduct a brief visual screen for fugitive emissions. If a problem is suspected, a full
Method 9 test can be conducted. In addition, the inspector may ask to see any
pressure drop or flow data that the source maintains for these control devices. For
a source assessment, a useful tool would be to employ a fluorescent dye test as a
routine inspection technique. A small quantity of colored dye is injected in the inlet
duct of a negative pressure fabric filter, and then the area being tested is taken off-
line. A black light can then be used on the clean side of the bags to check for
leaks.3 This test can identify small bag problems and reduce bag failure rates.
5.4.3 Applicable Water Regulations and Inspection Techniques
NOTE! The Cluster Rules' CWA BMP
requirements for spent black liquor,
turpentine and soap are discussed entirely
in Section 4.6 even though some handling
likely will occur in the Chemical Recovery
area as well.
Air emissions from black liquor
processing are controlled by the MACT
standards discussed in Section 4,
Pulping Operations. Initial black
liquor processing steps, such as weak
black liquor storage and evaporation,
may be located in or near the pulping
area. Later steps, such as soap
skimming and turpentine recovery, may
be located in or near the chemical recovery area. Regardless of where these processes are
located, leaks, spills, and intentional diversions of black liquor, soap, and turpentine can
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Section 5 Chemical Recovery Assessments
interfere with the operation of biological wastewater treatment systems. For this reason,
the Cluster Rules establish Best Management Practices (BMPs) requirements to limit these
leaks, spills, and intentional diversions. See Section 4.6 for a discussion of these
requirements.
Other wastewaters associated with the chemical recovery area are generally reused
in the chemical recovery process or for air pollution control, and only limited flows are
discharged to the wastewater treatment plant. Thus, with the exception of the BMPs, the
Clean Water Act compliance assessment concerns related to wastewaters generated in the
chemical recovery area will be addressed at the wastewater treatment plant.
Note that discharges (including discharges of materials used in the manufacturing
process) are allowed only if specifically described in both the mill's NPDES permit
application and the permit itself. The inspector should verify that any mill sewering lime
mud slurries during process upsets and lime mud washer maintenance activities is
specifically permitted to do so. The sewering of these lime muds during upset or
maintenance periods may damage or plug sludge removal devices or mechanical clarifiers.
Sewering of lime mud may increase the inorganic load of wastewater treatment sludges to
such an extent that incineration is not feasible, and the mill may need to dispose of the
sludge on land, rather than recovering the energy value of the sludge organic content
through incineration. If, during upset or maintenance periods, the lime mud is directed into
surface impoundments or landfills for disposal, the lime mud may present a hazardous
wasted concern if it contains free liquids and has a pH > 12.5 (which most lime mud does).
To avoid increases in lime mud loadings to the treatment plant, a diversion basin that
allows subsequent use of the lime mud in the process can be used to avoid lime mud
losses.2
There may be some elements of the storm water control activities at the mill that
are affected by this area, and a storm water evaluation may need to consider how storm
water runoff from this area is handled. Outdoor storage and handling areas are a possible
source of concern that should be addressed in the management practices adopted by the
mill in conjunction with a stormwater permit. See Section 9, Assessment Module for
Woodyard, Papermaking and Other Operations, for a more detailed discussion of storm
water issues.
5.4.4 Applicable RCRA/EPCRA Regulatory Issues and Inspection
Techniques
Certain wastes can constitute hazardous wastes if they exhibit the corrosivity
characteristic. To qualify, the waste must contain free liquids (>20 percent by volume) and
have a pH < 2 or > 12.5. Some States may consider corrosive wastes to be hazardous
wastes solely on the basis of pH level, and not the presence of free liquids.
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Chemical Recovery Assessments Section 5
In the chemical recovery area, three primary sources of wastes potentially could
qualify as corrosive hazardous wastes unless the mill takes appropriate handling steps.
Slaker grits and green liquor dregs are two of the three primary solid waste concerns in this
area. Generally, lime slaker grits are washed in order to recover cooking and causticizing
chemicals. However, at least one plant has noted that this washing process is also
important to maintain a pH level <12.5 (i.e., below the pH level that is one element of the
RCRA corrosivity characteristic).5 Note also that, generally, these wastes are dewatered
prior to disposal and would be able to pass a paint filter test for free liquids. The third
concern is lime mud that may be sent to a surface impoundment or landfill for disposal.
Generally, the mud is used in the kiln. However, during process upsets, some mud may be
handled for disposal. The lime mud may fail a paint filter test and have a pH > 12.5. Thus,
disposal in this manner presents a possible noncomplying disposal practice.
These materials generally are landfilled on-site although there is some opportunity
for beneficial reuse of the materials as a cement additive.2 Solid waste landfill permits and
requirements are issued by State agencies within the general criteria and guidelines
included in 40 CFR Part 257. One concern is potential leachate from on-site solid waste
landfills. It should be noted that if the leachate is commingled with other process
wastewaters and sent to the wastewater treatment plant, the landfill leachate would
constitute "process wastewater" and be part of the wastewaters subject to the NPDES
permit for the facility (see 40 CFR 430.01 (m)). The inspector must identify the specific
State permit requirements before conducting the inspection. On-site landfill issues are
addressed in Section 9, Assessment Module for Woodyard, Papermaking and Other
Operations.
For EPCRA, the primary concern will be to ensure that the TRI Form R report
addresses all of the releases to the air, water and land from these equipment systems. In
addition, because some of these equipment systems do emit methanol and other air
pollutants (see Figure 5-2), and generally are not subject to any federal regulation or permit
condition limiting those emissions, emergency reporting requirements may also apply.
Note that, for EPCRA emergency reporting purposes, all releases that are not federally
permitted from all units at the mill would be combined to determine whether the air
emission releases exceed an applicable reportable quantity threshold. See further
discussion of emergency reporting requirements in Section 5.3.4 and Appendix D.
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Section 5 Chemical Recovery Assessments
References:
1. Proposed Technical Development Document for the Pulp, Paper and Paperboard
Category and Effluent Limitations Guidelines, Pretreatment Standards, and New
Source Performance Standards. U.S. Environmental Protection Agency, Washington,
D.C., October 1993.
2. Model Pollution Prevention Plan for the Kraft Segment of the Pulp and Paper
Industry, EPA 910/9-92-030. U.S. Environmental Protection Agency, 1992.
3. Pollution Prevention Opportunity Assessment and Implementation Plan, EPA 910/9-
92-027. U.S. Environmental Protect!on Agency, 1992.
4. Buonicore, AJ and Davis, W.T., eds., Air Pollution Engineering Manual, Air and
Waste Management Association, 1992.
5. Credible Evidence Rule Revisions: Response to Comments, U.S. Environmental
Protection Agency, February 1997.
6. U.S. Environmental Protection Agency, Applicability Determination Index (ADI):
Document Control #9600134.
7. Kraft Pulp Mill Inspection Guide. Prepared for U.S. Environmental Protection
Agency under Contract No. 68-01-6310, Work Assignment No. 65, Pedco
Environmental, Inc., Cincinnati, Ohio, January 1983.
8. Operation and Maintenance Manual for Electrostatic Precipitators, EPA/625/1-
85/017, U.S. Environmental Protection Agency, 1985.
9. Richards, J., Baseline Inspection Techniques, Student Manual, Air Pollution Training
Institute Course 445, 2nd Edition, 1996.
10. Telephone Communication, with J. Richards, Air Control Techniques, Inc., September
1997.
11. Richards, J., Control of'Paniculate Emissions, Student Manual, Air Pollution Training
Institute Course 413, 2nd Edition, 1995.
12. U.S. Environmental Protection Agency, Applicability Determination Index (ADI):
Document Control #s NB01 and NB03 (Subpart D) and NN04, NR117, and NR100
(Subpart Db).
13. U.S. Environmental Protection Agency, Chemical Pulping Emission Factor
Development Document (Revised Draft), July 8, 1997.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 5-29
-------
SECTION 6: ASSESSMENT MODULE FOR BLEACHING
PROCESS OPERATIONS
6.1 Introduction
This section provides the
necessary information for conducting a
compliance assessment of the bleaching
process at a kraft pulp mill. This
section first describes the bleaching
process. The section then outlines the
regulatory requirements and available
inspection procedures for pulp
bleaching activities. In addition,
Appendix E contains an example
assessment form that combines the
various elements discussed in this
section.
CONTENTS
6.1 Introduction
6.2 Overview of Process and Discharges
6.3 Air Regulations and Inspection
Techniques
6.4 Water Regulations and Inspection
Techniques
6.5 EPRCA Issues and Inspection
Considerations
6.2 Overview of Process and Discharges
6.2.1 Description of the Process
At some mills, the pulp produced by the kraft process is whitened and brightened in
a series of chemical bleaching operations that are together called a bleaching line. All the
bleaching lines at a mill, and all the equipment associated with those bleaching lines, are
defined in the Cluster Rules MACT standards as the bleaching system. Similarly, the
Cluster Rules wastewater regulations define the bleach plant as "all process equipment
used for bleaching ..." and limit the discharge of pollutants in the bleach plant effluent.
Figure 6-1 depicts the major equipment found in a typical five stage bleaching line. A brief
description of these equipment systems and their function follows.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-1
-------
Pulp from
Pulping
System
Pulp flow
Water/filtrate flow
Gas stream
Figure 6-1
Diagram of Example Bleaching System
Chlorinated bleaching stage vent gases (including associated seal tanks)
to scrubber
Wash;r
4
JkH
d)
0 fe
%e.
&
Fresh or White Water
Washi
£
a
CQ
t-
K
ia
J
Was
Seal
tank
1
Seal
tank
* Bleach plant filtrates sent to wastewater treatment.
Alkaline
»•
Sewer*
Fresh
Bleached
Pulp
Acid
Sewer*
<*!
VI
n
o
Q.
•s
03
fT
«
B£
5'
ro
o
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O
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-------
Section 6 Assessment Module for Bleaching Process Operations
The bleaching process. A bleaching line typically consists of a sequence of three
to six bleaching stages. The number of stages varies depending on the furnish (softwood
or hardwood) and on the brightness requirements of the pulp and the specific design of the
mill. A typical bleaching line has an alternating series of bleaching and extraction stages.
In a bleaching stage, the pulp is treated with chemical bleaching agents. In an extraction
stage, chemicals (usually sodium hydroxide) are added to neutralize the chemical reactions
and the acidity of the pulp prior to the next bleaching stage. An extraction stage is not
necessary in all cases.
NOTE! Bleaching line means a group of
stages arranged in series; pulp flows from
one stage to the next. Bleaching system
refers to all of the bleaching lines and all
of the process equipment associated with
those bleaching lines.
Each bleaching stage consists of
three steps: mixing of pulp and
bleaching chemical (and in some cases
steam), reaction of the chemical with the
pulp in a retention tower, and washing
the chemical out of the pulp. Thus, the
equipment considered part of a stage
includes chemical and steam mixers,
retention (bleaching or extraction)
towers, and the washers and their associated seal (filtrate) tanks and/or vacuum pumps.
For mills that use oxygen delignification (or "oxygen pre-bleaching"), the mills may
consider this equipment as the first bleaching stage. However, oxygen delignification is
defined by the MACT standards as a pulping area HVLC source and is discussed in Section
4.2.1. Oxygen delignification is also explicitly excluded from the effluent guidelines
definition of "bleach plant," given in 40 CFR 430.01.
Chemical and steam mixers. Bleaching chemicals must be thoroughly mixed with
the pulp to ensure pulp quality, to minimize chemical waste, and to minimize the generation
of bleaching contaminants such as chlorinated dioxins and furans. Mixing can be
accomplished with the use of enclosed rotary high-shear mixers or static in-the-pipe mixers.
Significant HAP emissions are not anticipated from mixers, because they are typically
enclosed.
Retention towers. The bleaching reactions occur primarily in a bleaching or
retention tower. To effectively manage the bleaching chemical reaction, it is necessary to
maintain a certain temperature, retention time, consistency, pressure, and pH for each
bleach stage. Conditions vary with the bleaching chemical used. Bleaching stages that use
chlorine and/or chlorine dioxide are performed at acid (low) pH, while extraction and
peroxide bleaching are performed at alkaline (high) pH.
There are two primary types of retention tower: the upflow tower and the
downflow tower. The choice of tower design depends on the particular conditions desired
for the bleach stage. As a general rule, however, chlorinated bleach stages use an upflow
tower design or a modification thereof.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 6-3
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Assessment Module for Bleaching Process Operations
Section 6
Washers. To minimize chemical usage and equipment corrosion, it is important to
remove as much bleaching chemical as possible from the pulp prior to entering the next
bleaching stage. Bleached pulp washing is performed in the same type of equipment used
to wash brown stock pulp, and typically consists of a rotary drum washer with an
associated seal tank. The washer consists of a hollow, mesh-covered cylinder through
which a vacuum is pulled. The vacuum is typically produced by a sealed drop leg on the
discharge line. In some cases, the vacuum may be created by vacuum pumps. Section
4.2.1 contains additional discussion of brown stock washers.
Seal tank. The seal tank holds washer filtrate and serves to keep the drop leg
(barometric leg) submerged, maintaining vacuum on the washer. Washer filtrate is
typically reused as wash water counter currently to the flow of the pulp. In other words,
fresh water is used in the final bleaching stages. Then filtrates from chlorinated bleaching
stages are reused in preceding chlorinated bleaching stages, and filtrates from non-
chlorinated stages are used on preceding non-chlorinated stages. Filtrates in the first two
seal tanks at the first chlorinated and non-chlorinated stages of a bleaching line are typically
sewered. Consequently, there is an "acid sewer" from the first chlorinated filtrate tank and
an "alkaline sewer" from the first non-chlorinated filtrate tank.
Vacuum pump. A vacuum
pump may be used to pull the vacuum
on a rotary vacuum washer. Vacuum
pumps are not expected to be widely in
use at bleaching systems since the
majority of the mills utilize the
barometric leg method of pulling a
vacuum on the washer.
NOTE! The Cluster Rules wastewater
regulations define bleach plant effluent as
the total discharge of process wastewaters
from the bleach plant bleaching system.
This would include separate acid and
alkaline filtrates or combined filtrates.
Bleaching chemicals. Many
oxidants are used as bleaching agents, but chlorinated chemicals are the most common.
Bleaching with chlorinated chemicals (chlorine gas, sodium hypochlorite, and chlorine
dioxide) is common because they are powerful and inexpensive. Use of these compounds
generates chlorinated HAP emissions from bleaching system vents and chlorinated
pollutants in bleach plant effluents. In addition to chlorinated chemicals, some oxygen
bleaching agents are commonly used, including oxygen, peroxide, and ozone. Oxygen and
peroxide are frequently mixed with the pulp just prior to an extraction stage.
Stages in a bleaching line typically are named after the bleaching chemical used or
the operation performed. For example, a bleaching stage using chlorine or chlorine dioxide
may be called a C-stage or D-stage, respectively. An extraction stage would be called an
E-stage. Figure 6-2 lists the chemicals and the bleaching stage abbreviations that are
commonly used by the industry. Figure 6-2 also lists some examples of bleach plant
sequences used by kraft mills.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-4
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Section 6
Assessment Module for Bleaching Process Operations
Figure 6-2
Bleaching Stage Abbreviations and Bleaching Sequences1
Bleaching Stage
C
D
E
H
P
Z
Bleaching Sequence
CEH
C/DE0DED
DEOPDED
ZE0D
Name
Chlorine
Chlorine Dioxide
Sodium Hydroxide (extraction)
Hypochlorite
Peroxide
Ozone
Formula
C12
C1O2
NaOH
NaOCl
H202
03
Comment
Classical sequence for production of semi-bleached pulp
Classical market kraft pulp sequence of the 1980s
Classical ECF (elemental chlorine-free) sequence for market kraft pulp,
sometimes preceded by oxygen delignification
First sequence using ozone for commercial production of kraft pulp in North
America (preceded by oxygen delignification)
6.2.2 Air Pollutant Emissions
Emissions of HAPs from the bleaching process equipment systems are strongly
influenced by the bleaching chemicals used. The primary pollutants generated from the
bleaching system are chlorine, chloroform, and other chlorinated HAPs. These pollutants
are generated in and emitted from stages that use chlorine or chlorinated bleaching
chemicals. Hypochlorite use results in the largest emissions of HAP, particularly
chloroform. Elimination of hypochlorite as a bleaching chemical significantly reduces
chloroform emissions. For bleaching lines that do not use hypochlorite, the degree of
substitution of chlorine dioxide for chlorine also affects chloroform and overall HAP
emissions. The use of oxygen delignification also may act to decrease chloroform
emissions. Although highly variable depending on the process used at a particular mill,
typical emission rates for chloroform and total HAPs are shown in Figure 6-3.
Uncontrolled chlorine emissions from the bleach plant can average approximately 0.70
Ib/ADTP, and chlorine dioxide emissions can average approximately 0.50 Ib/ADTP.
Scrubbers can achieve up to 99 percent reduction efficiency for these pollutants.2
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-5
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Assessment Module for Bleaching Process Operations
Section 6
Figure 6-3
Typical Air Emissions from the Bleaching System at a 1000 Ton Per Day Kraft Mill*
Pulping System
Components
Bleach Plant with
Hypochlorite
Bleach Plant with no
Hypochlorite and Chlorine
Dioxide Substitution <65%
Bleach Plant with no
Hypochlorite and Chlorine
Dioxide Substitution > 65%
Typical Emissions (Tons/yr)
Methanol
39
39
39
Total HAP
121
72
49
Chloroform
68
23
2
* Values are based on typical emission factors contained in the 1997 EPA Chemical Pulping Emission Factor Document,3
with an assumption that the mill operates 350 days/year.
6.2.3 Water Pollutant Discharges
Because chlorine-containing compounds are the predominant bleaching agents used
at kraft pulp mills, and because of the toxicity and persistence of chlorinated compounds,
EPA regulates the discharge of chlorinated pollutants generated during pulp bleaching.
Chlorinated pollutants regulated in the Cluster Rules, described in Section 7.2.3, include:
! AOX
! Chloroform
! 2,3,7,8-TCDD (Dioxin)
! 2,3,7,8-TCDF (Furan)
! 12 chlorinated phenolic compounds:
— Trichlrosyringol
— 3,4,5-Trichlorocatechol
— 3,4,6-Trichlorocatechol
— 3,4,5-Trichloroguaiacol
— 3,4,6-Trichloroguaiacol
— 4,5,6-Trichloroguaiacol
— 2,4,5-Trichlorophenol
— 2,4,6-Trichlorophenol
— Tetrachlorocatechol
— Tetrachloroguaiacol
— 2,3,4,6-Tetrachlorophenol
— Pentachlorophenol
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-6
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Section 6
Assessment Module for Bleaching Process Operations
6.2.4 Solid/Hazardous Waste Discharges
The solid waste discharges associated with the bleaching system are minimal. Most
of the discharges are liquid wastes that are part of the NPDES-regulated wastewater sent
to the treatment plant prior to discharge.
6.2.5 EPCRA Chemicals and Reportable Releases
Facilities will have to provide information on chemicals used in the bleach plant to
meet EPCRA's emergency preparedness requirements. Appendix D contains a process-
based list of the types of hazardous chemicals typically included in an EPCRA inventory for
a kraft pulp mill.
On-site air, water, and land releases, including land disposals, of toxic chemicals
from the bleach plant and off-site transfers of waste containing these toxic chemicals may
have to be accounted for in TRI Form R reports. For TRI purposes, the bleach plant
wastewaters will affect the quantity of releases for both water discharges and solid waste
discharges (i.e., the amount of certain TRI chemicals estimated to remain in wastewater
treatment plant sludges). For toxic chemicals in waste streams, the mill also must report in
Form R the waste treatment or disposal method employed and an estimate of treatment
efficiency.
In addition, EPCRA/CERCLA emergency release reporting could apply for off-site
releases that are not federally permitted and exceed certain reportable quantities. Releases
directly from the bleach plant most likely would involve air emissions chlorine or
chloroform that exceed the applicable reportable quantity (10 pounds per 24-hour period
for each of these chemicals) and are not federally permitted. Releases potentially could
occur as a result of spills resulting from material storage and handling activities.
6.3 Air Regulations and
Inspection Techniques
The air emissions from the
bleaching system are subject to the new
Cluster Rules requirements, as well as
any applicable State regulations. The
NSPS do not apply to bleaching
systems.
6.3.1 Emission Points
The primary emission points
from the bleaching process are the
bleaching towers, washers, and seal
Key Air Regulatory Considerations
Regulatory concerns are primarily
Cluster Rules-related ~ non-HAP
requirements do not apply
Control of emissions generally through
gas scrubbers
Voluntary Advanced Technology
Incentives Program can be used to
extend compliance deadline
Oxygen delignification system
considered part of pulping (HVLC)
system for MACT purposes — see
Section 4.4
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-7
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Assessment Module for Bleaching Process Operations
Section 6
tanks. If steam and chemical mixers are vented to the atmosphere, the mixers would also
emit HAPs. The emissions regulated by the MACT standard are chlorinated HAPs and
chloroform.
The emission points of concern are those from bleaching stages where chlorine or
other chlorinated compounds are applied. The washer systems remove the chlorinated
bleaching chemicals from the pulp slurry at the end of the stage and prior to the application
of the chemicals in the next bleaching stage. Therefore, there is not a significant carry over
of chlorinated HAPs and associated emissions to bleaching stages in which non-chlorinated
chemicals are used.
6.3.2 Applicable Regulations
Air emission regulations for criteria pollutants, such as NSPS Subpart BB, do not
cover the bleach plant equipment systems at kraft pulp mills. However, the Cluster Rules
MACT standards apply. In addition, state HAP requirements may also apply.
6.3.2.1 State HAP Standards
At least one state — Maine — has established specific emission limits for chlorine
and chlorine dioxide emissions from bleach plant operations (see Figure 6-4 for a summary
of the Maine requirements - Chapter 122 of the Maine Administrative Code). In addition,
some states may impose limits on these operations under other applicable authority. Based
on a review of sample permits from a few states, both Wisconsin and Georgia appear to
impose requirements on bleach plant operations. Wisconsin has established chlorine
emission limits for both new or modified sources, and existing sources under its state air
toxic regulations (See NR 445, Wis. Adm. Code). No monitoring requirements were
established in the sample permit reviewed. Similarly, Georgia appears to impose similar
requirements on the basis of a State air toxics program. In addition, the Georgia permit
reviewed also contained scrubber control device parameter monitoring requirements.
Figure 6-4
Summary of Maine Bleach Plant Regulations
Emission Limits
Monitoring Provisions
Testing Provisions
3.0 Ib/hr for Chlorine
3.0 Ib/hr for Chlorine
Dioxide
Limits apply to
combined bleach plant
operations
Total chlorine CEMS, but only after
determination that equipment is available
and reliable for determining compliance
Scrubber recycle flow, Oxidation
Reduction Potential (ORP), scrubber
pressure drop, pH meters, and potentially
other scrubber parameters
Recycle flow, ORP, scrubber pressure
drop, and pH must be recorded once per
shift
Annual testing required
Use NCASI methods
(Technical Bulletins #520
and #548, 4/87 and 6/88)
or other approved method
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-8
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Section 6
Assessment Module for Bleaching Process Operations
6.3.2.2 Cluster Rules Standards
NOTE! MACT summary based on
4/15/98 Final Rule and subsequent
regulatory notices published through
4/30/99. Check website for possible
updates to this section for any subsequent
regulatory notices.
Basic emission limits. At kraft
mills, the MACT requirements apply
only to bleaching lines that use
chlorinated compounds, and only to the
bleaching stages in which chlorinated
compounds are introduced. The
equipment covered is the bleaching
tower, washer, and seal tank. Steam
and chemical mixers are also covered if
they vent to the atmosphere as well as any vacuum pumps. Extraction stages are not
covered.
The rule has two emission limits, one for chloroform and one for chlorinated HAPs
(excluding chloroform). Figure 6-5 presents the control options for the bleaching system
emission limits. Each bleaching system must comply with both the chloroform and
chlorinated HAP limits (chlorinated HAPs may be measured as chlorine). The rule has two
limits because the technology used to control chlorinated HAPs will not control
chloroform.
Figure 6-5
Control Options for Bleaching System Emission Limits
Bleaching System
Emission Limit
Chloroform
Chlorinated HAP
Control Option
Comply with the revised effluent limitations guidelines and standards
Use no chlorine or hypochlorite in any bleaching stage
Reduce total chlorinated HAP mass in the vent stream by 99 percent or more
(measured as chlorine) using a control device
Reduce the total chlorinated HAP emission concentration (excluding
chloroform) to 1 0 ppmv or less exiting a treatment/control device
Reduce the total chlorinated HAP mass emission rate to 0.001 kg total HAP
(excluding chloroform) per Mg ODP
Chloroform emission limit. Process modifications are required to meet the
chloroform limit since chloroform is not removed in the bleach plant gas scrubber. A mill
can comply with the MACT requirements of eliminating chlorine and hypochlorite use or
meet the limits set forth in the NPDES effluent limitations guidelines. However, if the
compliance dates for the effluent limitations guidelines (which are based on the NPDES
permit renewal cycle for each facility) are different than those for the MACT standards, the
MACT compliance dates must still be met.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-9
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Assessment Module for Bleaching Process Operations Section 6
NOTE! The enclosures and closed-vent
system must meet the same requirements
as described in Section 4.3.2.2 for the
pulping process.
Chlorinated HAP emission
limit. As outlined in Figure 6-5, the
MACT standards provide three
optional emission limit formats (i.e., a
limit based on percent reduction,
pollutant concentration, or mass
emissions per product). However, for
each of these three options, the chlorinated HAP emission limit is based on the use of a gas
scrubber; and, although not explicitly required, nearly all mills are expected to use or
modify existing gas scrubbers to meet the emission limit. Some mills may be able to meet
the concentration or mass emission limits through process modifications (i.e., 100%
chlorine dioxide substitution). In addition to the ultimate control device, the Cluster Rules
require — for each bleaching stage in which chlorinated compounds are introduced — that
emission points be enclosed and vented to a closed-vent system which is routed to the
control device. The enclosures and closed-vent system requirements are the same as for
pulping process area emission points (see Section 4.3.2.2).
General exceptions and alternative standards. Under the Effluent Limitations
Guidelines (40 CFR Part 430.24), a mill may choose to enroll one or more of its bleach
lines in the Voluntary Advanced Technology Incentives Program. The program provides
extended compliance with the bleaching system requirements for kraft mills in exchange for
achieving greater HAP reductions than the regulatory baseline. Mills that elect to enter this
program receive a 3-year extension for complying with MACT bleaching standards (i.e.,
they must comply by April 15, 2004). As part of the extension, mills must submit a control
strategy report every two years under 40 CFR 63.455(b) until compliance is achieved. The
report must contain milestones and status reports for achieving compliance. In addition,
the mill must meet either one of the following two conditions:
! No increase in the application rates of chlorine and/or hypochlorite (in kg per Mg
ODP) in the bleaching system beyond current levels. The current application rate is
defined as the average daily rates used over the three months prior to June 15,
1998. The application rate limitation is provided to prevent a bleaching system
from "backsliding" (i.e., increasing emissions during the extended compliance
period). Or,
! By no later than April 16, 2001, comply with enforceable effluent limitation
guidelines for 2,3,7,8 TCDD and for AOX that are at least as stringent as the
baseline BAT levels set out in the Cluster Rules effluent guidelines (40 CFR
430.24(a)(l)).
Any bleaching line that is modified to not use chlorine or any chlorinated HAP is exempt
from all MACT requirements.
Back-up control requirements. There are no explicit back-up control MACT
requirements for the bleaching system emission limits and the rule provides no allowances
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 6-10
-------
Section 6 Assessment Module for Bleaching Process Operations
for excess emissions. Therefore, the only excused excess emission periods would be those
periods that are specifically designated in the startup, shutdown, or malfunction plan
approved under 40 CFR 63.6(e)(3).
Monitoring, reporting, and recordkeeping (MRR). The MACT establishes
MRR requirements to assure continuous compliance with the emission limits. In order to
meet the chlorinated HAP emission limit, the majority of the mills will use gas scrubbers.
The MACT requires that mills use a continuous monitoring system (CMS) to demonstrate
compliance. Figure 6-6 summarizes the MACT MRR requirements for each control
option. The specific parameter excursion levels used to determine ongoing compliance are
determined during the initial performance test. If a mill uses a control device other than a
gas scrubber, the mill must submit for approval proposed parameters to be monitored and
the applicable excursion level for each proposed parameter. The mill may submit proposed
revised excursion levels (or, if applicable, monitored parameters) on the basis of
subsequent performance testing results.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 6-11
-------
Assessment Module for Bleaching Process Operations
Section 6
Figure 6-6
MACT Monitoring, Reporting, and Recordkeeping Requirements
for Bleaching Systems Chlorinated HAP Emission Limit
Control Option
Gas scrubber used
to meet:
! 99%
chlorinated
HAP reduction,
or
! Mass emission
rate of 0.001 kg
chlorinate HAP
per Mg OOP
Gas scrubber used
to meet:
! 1 0 ppmv
chlorinated
HAP outlet
concentration
Compliance with
emission limits
with a control
device other than
gas scrubber
Process
modification to
meet mass or
concentration
emission limits
Continuous
Monitoring
! pH or oxidation-
reduction
potential of the
effluent
! Vent gas inlet
flow rate
! Scrubber liquid
influent rate
! Same scrubber
parameters as
above, or
! Chlorine outlet
concentration
Determine
appropriate
monitoring
parameters during
initial performance
test
Determine
appropriate
monitoring
parameters during
initial performance
test
Reporting
Standard Part 63 reporting
(i.e., quarterly EER and
CMS performance report,
except, if no excess
emissions, then semiannual
performance report with
statement that no excess
emissions occurred)
Standard Part 63 reporting
(i.e., quarterly EER and
CMS performance report,
except, if no excess
emissions, then semiannual
performance report with
statement that no excess
emissions occurred)
(Same as using a gas
scrubber to comply with the
emission limits)
(Same as using a gas
scrubber to comply with the
emission limits)
Recordkeeping
Standard Part 63
recordkeeping for
monitored operating
parameters (i.e., both
monitor performance data
and measured data
averages)
Standard Part 63
recordkeeping for
monitored operating
parameters (i.e., both
monitor performance data
and measured data
averages)
(Same as using a gas
scrubber to comply with the
emission limits)
(Same as using a gas
scrubber to comply with the
emission limits)
As noted above in this section, the mill must also meet the enclosures and
closed-vent system requirements for capturing and transporting the bleach vent gases to the
scrubber or other control device. These requirements include independent MRR
requirements, as summarized in Figure 6-7.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-12
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Section 6
Assessment Module for Bleaching Process Operations
Figure 6-7
Enclosures and Closed-vent System MACT Monitoring and
Recordkeeping Requirements
Control Option
Enclosures and
Closed-vent System
requirements apply
to all control
options
(See Figure 6-5)
Monitoring
! Every 30 days: Visual
inspection of all bypass
line valves or closure
mechanisms
! Initially and Annually.
Demonstrate no
detectable leaks at
positive pressure
components.
Demonstrate negative
pressure at enclosure
openings
Reporting
! None required for 30-day
visual inspections
! Initial and annual leak
checks/negative pressure
demonstrations are subject
to general Part 63
performance test reporting
requirements
Recordkeeping
! Prepare and maintain a site
specific inspection plan
! Visual check records must
be kept because relevant to
documenting compliance
(§63.10(b)(2)(vri))
! Performance test records
must be maintained
(§63.10(b)(2)(vni))
The MRR requirements (see Figure 6-8) for the chloroform emission limit are
limited because the mill will use process modifications rather than add-on control
technology to comply.
Figure 6-8
MACT Monitoring, Reporting, and Recordkeeping Requirements
for Bleaching Systems Chloroform Emission Limit
Control Option
Eliminate use of
hypochlorite or
chlorine
Comply with
effluent limitation
guidelines (by
MACT
compliance date)
Continuous
Monitoring
None
As required in
NPDES permit
(minimum weekly
monitoring of bleach
plant effluent)
Reporting
Initial (one-time) compliance report only
As required in NPDES permit
(minimum annual submission of
discharge monitoring report)
Recordkeeping
General Part 63
requirements for
initial compliance
reports
Standard NPDES
permit
recordkeeping (3
years for all
monitoring
records)
Finally, Figure 6-9 summarizes the MRR requirements for mills that receive the 3-
year compliance date extension. These requirements apply from June 1998 until the mill
demonstrates compliance with all applicable bleaching system emission limits.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-13
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Assessment Module for Bleaching Process Operations
Section 6
Figure 6-9
MACT Monitoring, Reporting, and Recordkeeping Requirements
for Mills in the Voluntary Advanced Technology Incentives Program
Control Option
Compliance date
extension for
Advanced
Technology
Incentives
systems (no
increase in
chlorine or
hypochlorite use)
Continuous
Monitoring
Chlorine and
hypochlorite
application rates in
kg/Mg OOP
Reporting
! Daily application rates of chlorine
and hypochlorite every 6 months; and
! Submit the initial control strategy
report and update the control strategy
report every 2 years
Recordkeeping
Daily application
rates of chlorine
and hypochlorite
6.3.3 Air Inspection Techniques
Because of the significant air emission sources outside of the bleach plant area
(including the lime kiln, recovery boiler and power boilers) and the lack of applicable
requirements, the bleaching systems in the past often have not been a high priority for
committing on-site inspection resources. However, the bleach plant air emissions will
require increased attention from inspectors to assure compliance with Cluster Rules
requirements. For initial compliance, the appropriate steps to follow for coming into
compliance with the Cluster Rules are outlined extensively in the document Pulp and
Paper NESHAP: A Plain English Description? including a discussion of applicability and
timing issues, as well as initial compliance checklists. This document, therefore, focuses on
on-site inspections that will be conducted after initial compliance has been demonstrated
and the appropriate permit conditions have been included to address the Cluster Rules.
6.3.3.1 Pre-inspection Steps
As discussed in Chapter 3, there are a number of steps that should be taken
routinely prior to conducting an actual on-site inspection, including file (especially permit)
reviews. As part of conducting the file review and planning the on-site inspection, the
inspector should consider at least the following items:
Process diagrams. Obtain a simplified diagram of the bleaching system(s) and
note what control(s) are employed. This type of diagram may be available in the Part 70
operating permits file if submitted with the application.
Evaluation of periodic monitoring reports. If a scrubber is used for HAP
control, scrubber parameter (or, in some cases, outlet chlorine concentration) data will be
recorded and submitted in a semiannual (or quarterly) excess emission report (EER) of
excursions from required parameter levels - these levels should be specified in the mill's
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-14
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Section 6 Assessment Module for Bleaching Process Operations
operating permit. The inspector should review any reports submitted since the last
inspection in order to prioritize the need for follow-up while on site. Note that under the
Cluster Rules, there is no allowance for excess emission periods, although the MACT
general provisions do allow for excess emissions that occur as a result of startup, shutdown
or malfunction. The inspector will have to review on-site records to evaluate any claims of
allowable excursions. This evaluation must also consider whether the claimed excursions
are consistent with the startup, shutdown and malfunction plan required under 40 CFR
63.8.
Evaluation of episodic malfunction reports. The inspector should review
malfunction/upset reports since the last inspection, if available. If the reports identify
corrective actions to be taken by the source, note the need to verify during the on-site
inspection that the corrective steps were actually taken and that they resolved the problem.
Also, the inspector can compare claims of malfunction periods on EERs with the
duration and timing of malfunction periods indicated on malfunction reports. If a
malfunction report is required for all or some specified subset(s) of malfunctions, note any
discrepancies between the malfunction reports submitted and the claimed excess emissions
in an EER. Significant discrepancies signify either errors in the EER or malfunction
reporting that should be addressed with the facility either as part of the inspection or by
agency compliance staff responsible for processing periodic and episodic reports.
6.3.3.2 On-site Inspection Steps
The appropriate on-site inspection steps must be tailored to the objectives of the
inspection and the priority given to the bleaching area in a particular inspection. The
possible steps for a routine Level 2 inspection include:
Permit verification. One objective of a standard Level 2 air inspection will be to
verify that the permit includes all the appropriate equipment. As noted above, the Plain
English Description document4 contains a detailed discussion of the applicability of the
Cluster Rules requirements. Prior to the inspection, review the permit to determine what
conditions apply to the bleaching process. Depending on the nature of the specific permit
conditions, the inspector then should evaluate a number of potential issues to verify that
bleaching operations remain consistent with permit requirements, including:
Are all emissions units properly identified in the permit?
Have any modifications (including production increases that required a physical or
operational change) occurred that could trigger NSR? Note that bleach plant
modifications, even if they do not constitute a major modification that triggers PSD
or major NSR review, could debottleneck production in other areas of the mill that
result in significant emission increases from other processes.
Are HAP control methods properly identified?
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 6-15
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Assessment Module for Bleaching Process Operations Section 6
! Compare the basic process/design information with conditions in the permit to
verify the accuracy of the information in the permit and to support subsequent
assessment activities.
Evaluation of proper operation of control equipment. A Level 2 inspection will
focus on assuring that the control equipment is being properly operated and maintained so
that the facility continues to achieve compliance with the applicable emission limits.
Although the proper steps for this phase of the inspection will depend on the control
measures used for HAP control, all mills will have to comply with the enclosures and
closed-vent system requirements and nearly all mills are expected to use gas scrubbers to
reduce emissions.
Enclosures and closed-vent
system. As part of the Cluster Rules,
facilities will have to enclose bleach
plant emission points and convey the
gases through a closed-vent system if
a control device is used. The Cluster , ,7. , . ,. ,, , , . .
, „ .,. , ! Visual inspections (ductwork, piping,
Rules require the facility to develop a , , ,
self-inspection plan, including a , T , ', j . ^, ., , -., ,
* . ;. I . & ! Leak checks using Method 21 analyzer
series of periodic checks, to assure , ... . ^
. . F . (positive pressure components)
that this system continues to operate , B , , . , ,,
, J , . , \ \ Pressure checks using portable
properly. The inspector should , , ..
^ . , ^ „ ... pressure gauge, etc. (negative pressure
review the records or these activities , ,, , ^
. , , , enclosure/hood openings)
to assure that the required checks are
Checks of Enclosures/Closed-vent
Systems for Suspected Problems with
Facility Self-Inspections
occurring and that the source has
taken any corrective action steps
necessary to remain in compliance. If a problem is detected or suspected, the inspector
may want to consider conducting the types of checks that the facility is supposed to
undertake as part of its self-inspection program.
Scrubber systems. Most mills will use scrubbers to control chlorinated HAP
emissions from bleaching systems. The Cluster Rules provide for a set of scrubber
parameters (or the use of an outlet chlorine CMS) that are used to determine direct
ongoing compliance with the applicable emission limits. The on-site inspection should
confirm that:
! The required monitors are in good working order. Interview plant personnel to
determine what type of routine maintenance and quality assurance is conducted as
part of the mill's monitoring program.
! The monitored readings at the time of the inspection are within permit limits. To
the extent that the monitoring data are handled and stored by a distributed control
system (DCS), the inspector can evaluate recent historical data and data trends for
direct compliance, as well as shifts in emissions that indicate a loss of control
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 6-16
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Section 6 Assessment Module for Bleaching Process Operations
efficiency that could lead to future compliance problems if corrective measures are
not taken.
If the initial review of scrubber performance data indicates potential problems, then
the inspector may want to consider conducting follow-up checks of the system. See the
discussion of scrubber follow-up assessment steps in Section 5.3.3.2.
6.4 Water Regulations and Inspection Techniques
Kraft mills that manufacture
bleached papergrade pulp are subject to
40 CFR Part 430 (Subpart B). EPA
did not promulgate revised regulations
for mills that manufacture dissolving
grade kraft pulp (Subpart A) in 1998,
but expects to do so in the future.
Also, note that the Subpart B
requirements apply to soda mills, of
which there are only a limited number
of U.S. facilities.
Key Water Considerations
Cluster Rules impose new requirements
applicable to bleach plant effluent
prior to entering WWTP
Voluntary incentives program applies
under Cluster Rules
Sampling needs to be performed at
bleach plant locations — important to
verify that sampling done under
representative conditions
The new Cluster Rules
regulations are based on technologies
that reduce pollutant generation during
bleaching. However, the regulations do not require use of specific technologies, but
instead limit the discharge of specific pollutants. This section focuses on:
! Wastewater discharge points
! Applicable regulations
! CWA inspection procedures
! Water-related EPCRA issues
6.4.1 Discharge Points
Some wash water from each bleaching stage is reused in a preceding bleaching
stage, while the rest is sewered. In general, kraft mills discharge wash water (collectively
known as bleach plant effluent) either in:
! Two sewer lines, one that contains acid wastewater from the chlorinated bleaching
stages and one that contains alkaline wastewater from the extraction stages, or
! One combined sewer line that contains wash water from all bleaching stages
Figure 6-10 shows the two configurations. Most mills have separate acid and alkaline
sewers, which convey bleach plant effluent to the wastewater treatment plant.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 6-17
-------
Figure 6-10
Bleach Plant Sewer Stream Configurations
Separate Acid and Alkaline Sewer Streams
Fresh or
White Water
Fresh or
Whitewater
Unbleached
Pulp
Do
Stage
Stag*
D,
Stage
E
Stage
Stage
Bleached
Pulp
VI
VI
5
n
o
a
Alkaline Sewer
Combined Acid and Alkaline Sewer Streams
Fresh or
White Water
Fresh or
Whitewater
fol
Unbleached
Pulp
Stage
Stage
Stage
E
Stage
Stage
Bleached
Pulp
n
BT
5'
ro
hd
o
o
re
O5
VI
O
a
re
o
=
VI
Combined Sewer
Monitoring Points
OO = Appropriate Bleach Plant Effluent Monitoring Locations.
C/5
n
n
P^-
o'
=
o\
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Section 6 Assessment Module for Bleaching Process Operations
6.4.2 Applicable Regulations
The Cluster Rules regulations require all bleached kraft mills, both direct and
indirect dischargers, to demonstrate compliance with limitations for 15 chlorinated
compounds at the bleach plant. In addition, indirect discharge mills must demonstrate
compliance with AOX limits at the bleach plant. See Section 7.3 for a more detailed
discussion of the effluent limitations guidelines and standards established for mills subject
to 40 CFR Part 430 (Subpart B).
Voluntary Advanced
Technology Incentives Program. In NOTE! The EPA established a voluntary
addition to the baseline wastewater incentives program to encourage bleached
kraft mills to achieve greater pollutant
reductions than baseline regulatory
requirements.
regulations, as part of the Cluster
Rules, EPA established the Voluntary
Advanced Technology Incentives
Program (VATIP) under 40 CFR Part
430 (Subpart B). This incentives
program is intended to encourage bleached papergrade kraft mills to voluntarily implement
pollution prevention controls beyond the baseline regulatory requirements. The program
contains three tiers that reflect increasingly more effective levels of environmental
protection. This increased environmental protection can be achieved with advanced
pollution prevention technologies, such as oxygen delignification, ozone bleaching, and
totally chlorine free (TCP) bleaching process operations. The incentives program includes
more stringent limitations on the discharge of AOX than do the baseline Cluster Rules
requirements. In addition, the incentives program imposes bleach plant flow reduction
requirements. Tier 1 also requires participating mills to limit the lignin content of the pulp
they bleach.
Mills that enter the program may do so on a line-by-line basis, so that the more
stringent limitations are only applicable to those lines enrolled. In return for voluntarily
accepting more stringent effluent limits, participating mills have additional time to achieve
compliance and are subject to reduced monitoring requirements. (For more details see
Technical Support Document for the Voluntary Advanced Technology Incentives
Program, October, 1997.)
6.4.3 CWA Inspection Techniques
Because the Cluster Rules require mills to demonstrate compliance by monitoring
bleach plant effluent, NPDES and pretreatment compliance assessments must focus on the
bleach plant as well as the wastewater treatment plant. This section discusses the steps
required to perform an inspection of the bleaching process and will:
! Assist inspectors in assessing kraft pulp mill compliance with NPDES permit limits
applied at the mill's bleach plant effluent; and
! Assist POTWs as they assess the compliance of kraft pulp mills with pretreatment
permits
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 6-19
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Assessment Module for Bleaching Process Operations
Section 6
6.4.3.1 Record Reviews
To demonstrate compliance with the bleach plant effluent permit limits, mills must
monitor their bleach plant effluent discharges and maintain records of the monitoring.
Discharge Monitoring Reports (DMRs) must be submitted to the mill's permitting
authority annually, or more frequently if required by permit.
Permit review. The inspector
should review permit requirements for
bleach plant effluent, noting the required
monitoring locations and frequency.
Although the mill must monitor at the
frequency specified in its permit, the
Cluster Rules specify minimum
monitoring frequencies for all pollutants
monitored at the bleach plant, as
indicated in Figure 6-11.
NOTE! The inspector should determine
if mill operations are consistent with the
permit. If an inconsistency is found, the
inspector should determine if the facility
is making an unauthorized discharge or if
a permit modification is required.
Figure 6-11
Pollutant Monitoring Frequencies for Bleach Plants
Pollutant
Chloroform
TCDD and TCDF
Chlorinated phenolic compounds
AOX (for indirect discharge mills)
Minimum Monitoring Frequency
Weekly
Monthly
Monthly
Daily
DMR review. The inspector should review DMRs (and any other available
monitoring data) to determine whether there has been a violation of permit limits and to
identify any excursions from typical performance which may not have been violations.
Events occurring at the mill at the time of the excursions should be reviewed with mill
operators.
Bleaching process operations.
Typically, kraft mills monitor and
record information about certain
parameters in order to control the
bleaching process. The operation and
control of pulping and bleaching
processes determines, to a large extent,
the quantity of chlorinated pollutants generated. The inspector should review bleach plant
records to determine if operations at the time that compliance samples were collected were
NOTE! The inspector should review
bleach plant operating records to
determine if compliance samples were
collected during normal operations.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-20
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Section 6 Assessment Module for Bleaching Process Operations
representative of the normal operation of the bleach plant, or if bleaching operations were
inappropriately manipulated in order to achieve compliance. In addition, the inspector
should identify any excursions from typical performance to understand how well controlled
bleach plant operations are. Records of the following parameters may provide such
information:
! Bleach plant discharge flow. Bleach plant limits for TCDD, TCDF, and the
chlorinated phenolic compounds are expressed as concentrations (31.9
picograms/liter for TCDF;
-------
Assessment Module for Bleaching Process Operations
Section 6
in temperature and pH may indicate a disruption in bleaching operations that may
have led to increased pollutant discharges.
! Production data. Chloroform permit limits are mass-based. The inspector should
compare bleach plant production records to the permit file to verify that an
appropriate production value was used as the basis of chloroform permit limits. (For
a more detailed discussion of mass-based permit limits, see Section 7.3.1.) If an
inconsistency is found, the inspector should refer the matter to the permit writer to
determine if the facility is making an unauthorized discharge or if a permit
modification is appropriate.
6.4.3.2 Physical Inspection of the Bleach Plant (Facility Site Review)
The bleach plant should be inspected following the general procedures described in
the NPDES Compliance Inspection Manual. The inspection should include interviews of
bleach plant personnel. By examining the bleach plant equipment and by interviewing mill
staff, the inspector may uncover bleach plant conditions which could lead to problems in
compliance with bleach plant effluent limitations (see Figure 6-12).
Figure 6-12
Conditions that May Lead to Problems in Compliance
with Bleach Plant Effluent Limitations
If...
Bleaching towers and extraction
stages show signs of corrosion
Bleach plant washers and savealls
leak
Sewer line(s) contain excessive
entrained air
Sampling procedures are not
documented
Monitoring points are incorrectly
placed
Bleach plant schematic is
inconsistent with bleach plant
layout
Then...
Inefficient bleaching operations may
persist, leading to excessive
pollutant discharge
Pollutant discharges may be
escaping detection
Monitoring results may be
inaccurate
Invalid laboratory results may
persist
Monitoring results do not reflect
accurate pollutant discharge
Incorrect monitoring locations may
be in use; wastewater flows used to
calculate mass discharges may be
inaccurate
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-22
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Section 6
Assessment Module for Bleaching Process Operations
6.4.3.3 Flow Monitoring Evaluations
Prior to the Cluster Rules, few mills regularly monitored bleach plant effluent flow
or pollutant loadings. The Cluster Rules' wastewater regulations require mills to collect
compliance samples for all chlorinated pollutants (except AOX from direct discharging
mills) from the point where the wastewater containing such pollutants leaves the bleach
plant. The appropriate location(s) should be specified in the permit. Because limits for
dioxins and chlorinated phenolic compounds are expressed as concentrations, EPA strongly
recommends that permit writers require mills to continuously measure bleach plant effluent
flow. Flow measurement will help verify that samples are representative of normal
operations. Inspectors must examine the monitoring locations and determine whether:
! Monitoring location(s) captures all bleach plant effluent streams; and
! Flow monitor(s) functions properly (i.e., is properly installed, calibrated, and
maintained)
Inspectors should refer to the NPDES Compliance Inspection Manual (EPA 300-B-94-
014) for more discussion of flow monitoring evaluations.
6.4.3.4 Sampling Evaluations
Demonstration of compliance
with limits for 2,3,7,8-TCDD, 2,3,7,8-
TCDF, chloroform and chlorinated
phenolic compounds at the bleach plant
effluent requires that mills use
appropriate sampling procedures.
NOTE! Each mill is required to follow
any specific sampling procedures
specified in its permit.
Collection methods. Appropriate sample collection procedures are determined by
the physical and chemical properties of the pollutants of concern.
2,3,7,8-TCDD; 2,3,7,8-TCDF; and the chlorinated phenolic compounds (and AOX
for indirect dischargers). Samples analyzed for these pollutants may be collected as grab
composite samples collected from both the acid sewer and the alkaline sewer. Typically,
the composite is collected every four hours, for 24 hours. Mills may collect samples by
using a continuous automated sampling device, if appropriate for the sampling location
specified in the permit. For these pollutants, the mills may demonstrate compliance by
preparing a flow proportioned composite of the acid and alkaline sewer samples, resulting
in one sample of bleach plant effluent for analysis. (If necessary to achieve the applicable
method's minimum level, EPA recommends that mills test the effluents separately for
reliable determination of chlorophenolic compounds, 2,3,7,8-TCDD and 2,3,7,8-TCDF.)
Chloroform. For chloroform,
however, separate samples and analyses
of all bleach plant filtrates discharged
NOTE! Samples to be analyzed for
chloroform require special handling
because of chloroform's volatility.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-23
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Assessment Module for Bleaching Process Operations
Section 6
separately are required to prevent the loss of chloroform through air stripping as the
samples are collected and measured, or through chemical reaction when the acid and
alkaline samples are combined. If separate acid and alkaline sewers do not exist,
compliance samples must be collected from the point closest to the bleach plant that is or
can be made physically accessible.
Samples to be analyzed for chloroform will typically be collected every four hours
for 24 hours. However, because chloroform is volatile, samples must never be collected
using a continuous automated sampling device (unless such a device has been
demonstrated to be suitable for sampling volatile compounds). In addition, the following
special sampling procedures apply:
! Samples should be cooled during collection because the bleach plant effluent
streams are hot
! Samples should not contain air bubbles
Figure 6-13 summarizes sampling procedures for each pollutant.
Figure 6-13
Recommended Bleach Plant Effluent Sampling Evaluation Collection Procedures
Pollutant Monitored
Chloroform
2,3,7,8-TCDD and
2,3,7,8-TCDF
Chlorinated phenolic
compounds
AOX (for indirect
dischargers)
Container
Glass vial
with Teflon
septum
Amber glass
bottle with
Teflon lid
liner
Amber glass
bottle with
Teflon lid
liner
Amber glass
bottle with
Teflon lid
liner
Preservative*
3 granules (10
mg) Na2S2O3 per
vial, 2 drops HC1
per vial, 4 °C
Na2S2O3, for
samples > pH
ll,addH2SO4to
pH 7-9, 4 °C
Na2S203, H2S04
to pH 2-3, 4 °C
Na2S2O3, HNO3
to pH 2-3, 4 °C
Minimum
Sample
Volume
12x40mL
each grab
2x1,000
mL
3 x 1,000
mL
500 mL
Collection
Method
! Grab (1 every 4
hours)
! 24-hour
composite
prepared by lab
! Grab (1 every 4
hours) or
continuous
automatic
composite
! 24-hour
composite
* Note: sodium thiosulfate (Na2S2O3) is required only if free chlorine is present in the wastewater
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 6-24
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Section 6
Assessment Module for Bleaching Process Operations
6.4.3.5 Laboratory/QA Evaluations
As discussed in Section 7.4.5, many kraft mills operate on-site laboratories to
analyze BOD5 and TSS. Unlike the test procedures for BOD5 and TSS, the test
procedures for chloroform, 2,3,7,8-TCDD, and 2,3,7,8-TCDF are complex and require
specialized laboratory equipment. As a result, many mills contract laboratories to perform
bleach plant effluent testing. Inspectors should examine sample handling procedures to
ensure QC procedures are followed. Each mill should have written QC procedures for mill
staff. Inspectors should review these procedures and determine whether they are followed.
Inspectors should review documentation to determine if contract laboratories use
the test methods specified in the NPDES permit. Figure 6-14 lists the test method that
must be used for each pollutant limited in bleach plant effluent.
Figure 6-14
Test Method for Each Pollutant Limited in Bleach Plant Effluent
Pollutant
Chloroform
12 Chlorinated Phenolic
Compounds
2,3,7,8-TCDD and 2,3,7,8-
TCDF
Method
601,624, 1624Band
standard methods 621 OB,
6230B
1653
1613
6.5 EPCRA Issues and Inspection Considerations
General concerns. The
basic regulatory requirements for
EPCRA are not process-specific but
rather apply on a facility-wide basis.
Thus the basic requirements of
EPCRA are discussed in Appendix
D.
NOTE! See Appendix D for overview of
EPCRA regulations and basic assessment
procedures.
For the bleach plant operations, key EPCRA issues will be to quantify releases of
applicable toxic chemicals in the annual Toxic Release Inventory (TRI) report (known as
the "Form R" report), and to comply with emergency reporting requirements. The
emergency reporting requirements apply under both EPCRA and CERCLA. The releases
subject to these emergency reporting requirements are releases that are not federally
permitted and that exceed certain reportable quantities. For certain releases that are
"continuous" and "stable in quantity and rate," the mill may be able to use special reporting
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Assessment Module for Bleaching Process Operations Section 6
options so that a notice is not required after each such release. See the discussion of
continuous releases in Appendix D for further detail on the differences between standard
emergency reporting and reporting of continuous releases.
For this process area, air emissions of chlorine or chloroform from bleach plant
emission points are one potential source of releases that could be subject to EPCRA and
CERCLA emergency reporting (the reportable quantity for each of these compounds is 10
pounds per 24-hour period). In addition, raw material spills could result in releases that are
not federally permitted and exceed applicable reportable quantities. See Appendix D for a
non-exclusive list of hazardous substances associated with kraft pulp mills and the
corresponding reportable quantity values for each substance.
The determination of what constitutes a "federally permitted release" can be
complex. However, it is important to note that if the mill as a matter of normal operations
emits an applicable pollutant in amounts that exceed the reportable quantity and there is no
emission limit established for the pollutant, then the emergency reporting provisions likely
apply. For instance, a mill should file appropriate emergency reports if no chloroform
emission limit applies to a bleaching system, and the bleaching system normally emits more
than 10 pounds of chloroform in a 24-hour period. In this circumstance, the reduced
continuous release reporting options likely are available, as discussed in Appendix D.
Inspection considerations. The EPCRA compliance assessment generally will
focus initially on a records review. The inspector should review the following materials:
! Emergency preparedness information. These obligations are not process-specific,
and thus the basic assessment considerations are covered for all facility operations
in Appendix D to this manual.
! TRI Form R. Check to ensure that the form is on file, and that the source has
adequately considered: (1) on-site air, water, and land releases, including land
disposals of toxic chemicals, associated with the bleach plant operations and (2)
transfers of waste containing those toxic chemicals. For wastewater discharge from
the bleach plant, verify that the mill accounted for the residual TRI compounds
found in wastewater treatment plant sludges that are associated with bleach plant
effluent. Also, ask to see the estimation technique being used for air and water
releases associated with bleach plant operations. If the estimation technique
involves an assumed reduction efficiency for control methods (either for air or
water control measures), make sure that the assumed efficiency is consistent with
the overall efficiency that the mill is achieving. The overall assumed efficiency
should account for any excess air or water releases in a manner consistent with the
actual percent of operating time air control device or wastewater treatment upsets
occur. Uncontrolled emission episodes or periods of reduced control efficiency can
have a significant impact on the estimate of total releases.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 6-26
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Section 6 Assessment Module for Bleaching Process Operations
! Emergency notifications. Request documentation that the mill has filed all required
notices.
If an air or water inspector plans to screen for EPCRA compliance, the inspector
should confirm the necessary information with the facility contact during the opening
conference or just in advance of the closing conference. For an announced inspection, the
inspector should ask the source to have ready EPCRA-related documentation so that this
screening check can be performed without interrupting the main focus of the inspection. A
screening checklist is included as part of the example assessment form in Appendix E.
In addition to a screening-type records review inspection, an EPCRA inspector may
want to conduct further assessments to identify potential compliance concerns with
emergency notification requirements. As one technique, the inspector first can check
material storage and handling spill records, and citizen complaints since the previous
inspection. The inspector should then cross-check those incidents with notification records
identified in EPA's ERNS database, records on file with state/local emergency officials, or
records requested from the mill. If this type of investigation identifies episodes of
abnormal discharges for which no notification was provided, the inspector should consider
a follow-up investigation to determine if reportable quantity thresholds were exceeded.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 6-27
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Assessment Module for Bleaching Process Operations Section 6
References:
1. Dence, C.W. and D.W. Reeve, Pulp Bleaching Principles and Practices. TAPPI
Press, 1996.
2. Buonicore, AJ and Davis, W.T., eds., Air Pollution Engineering Manual, Air and
Waste Management Association, 1992.
3. Chemical Pulping Emission Factor Development Document (Revised Draft), U.S.
Environmental Protection Agency, July 8, 1997.
4. U.S. Environmental Protection Agency, Pulp and Paper NESHAP: A Plain English
Description, EPA-456/R-98-008, November 1998.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 6-28
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SECTION 7: ASSESSMENT MODULE FOR THE
WASTEWATER TREATMENT PLANT
7.1 Introduction
This section provides the
information for conducting a
compliance assessment of the
wastewater treatment plant,
including a general description of
typical wastewater treatment plant
operations at kraft pulp mills. The
section also describes kraft mill
pollutants and outlines the regulatory
requirements for this area of kraft
pulp mills.
CONTENTS
7.1 Introduction
7.2 Overview of Process and Discharges
7.3 CWA Regulatory Requirements
7.4 CWA Inspection Techniques
7.5 RCRA Issues
7.6 EPCRA Issues and Inspection
Considerations
7.2 Overview of Process and Discharges
7.2.1 Description of the Process
Kraft pulp mills treat wastewater using primary (physical) and secondary
(biological) treatment to reduce pollutant discharges to receiving waters. Kraft mills
typically collect and treat the following wastewaters:
Water used in wood handling and barking
Digester, turpentine recovery, and evaporator condensates
Wastewater from brown stock screening
Bleach plant effluent
Paper machine white water
Spent pulping liquor spills from pulp processing areas
Figure 7-1 shows a typical sequence of the major equipment systems in the
wastewater treatment plant. The function of each of these systems is described below.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page 7-1
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Figure 7-1
Diagram of Wastewater Treatment Plant Major Equipment Systems
C/5
re
n
p^-
o°
=
Untreated (raw)
Wastewater
Primary
Mechanical
Clarifier
Aeration
Basin
Secondary
Clarifier
Return Activated Sludge
Primary Sludge
to Disposal
Sludge to Sludge
Thickener
Aerated
Stabilization
Basin
Settling
Pond
Receiving
Stream
3
as
VI
i
H
=
<-K
2
p*
^
O5
X - Point at which flow and pollutant content measured.
=
P4-
VI
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Wastewater Treatment Plant Assessments Section 7
Primary treatment. Mills use primary treatment to remove suspended solids from
wastewater, then treat the wastewater further in secondary treatment. Primary treatment
processes used by kraft mills typically involve screening followed by either sedimentation
or flotation.
Sedimentation. Kraft mills use mechanical clarifiers or, occasionally, settling ponds
that provide sufficient holding time to enable suspended solids to settle. After settling
occurs in the mechanical clarifier, the resulting sludge (which contains up to six percent
solids) is pumped from the clarifier to sludge handling facilities where it is dewatered prior
to disposal. Mechanical clarifiers can remove as much as eighty to ninety percent of
suspended solids.
Settling ponds, a less sophisticated alternative to mechanical clarifiers, also remove
suspended solids by sedimentation. Settling ponds may be clay-lined, synthetic-lined, or
unlined and earthen, and have longer retention times than clarifiers. Settling ponds
produce a less constant solids loadings than mechanical clarifiers, but still provide sufficient
solids removal prior to secondary treatment.
Flotation. Flotation is a solids removal process that introduces a gas, usually air,
into the wastewater stream. The gas adheres to the suspended solids, reducing their
density and causing them to rise to the surface of the water, where they are skimmed off.
The advantage of flotation clarification over sedimentation is that lighter particles that
require very long retention times to settle are removed more quickly.
A common modification of this process is dissolved air flotation (DAF), in which
air under pressure is injected into the wastewater. DAF units are more efficient than
conventional flotation clarifiers because more air is introduced into the wastewater, thereby
removing more solids.
Secondary treatment. Kraft mills employ secondary treatment to reduce
biochemical oxygen demand (BOD5) and toxicity in wastewaters. This process makes use
of microorganisms (mostly bacteria and fungi) under aerobic conditions to digest the
organic matter in the wastewater. The organic matter is removed as sludge and the treated
wastewater is discharged into receiving waters. Because pulp mill wastewater is deficient
in nitrogen and phosphorus relative to its high carbon load, these nutrients are usually
added to the process to enhance microbial activity. Kraft mills generally use one (or more)
of two basic types of secondary treatment processes described below.
Aerated and non-aerated stabilization basins. About seventy-five percent of U.S.
kraft mills use aerated stabilization basins. These basins are equipped with continuous
mechanical aerators or diffusers to introduce air into the wastewater. By aerating the
wastewater, an increased amount of oxygen is introduced into the wastewater stream. This
action significantly speeds up the biological activity compared to a non-aerated basin, so
that a retention time of five days may achieve ninety percent BOD5 removal. The
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Section 7 Wastewater Treatment Plant Assessments
continuous aeration also provides thorough mixing which allows mills to operate effective
aeration lagoons at depths up to twenty-five feet. These basins are typically lined with clay
or a combination of synthetics and clay.
Some kraft mills use basins without mechanical aerators. Known as stabilization
basins, this is the simplest form of aerobic treatment. This process uses shallow basins that
cover very large areas and relies on natural diffusion of air into the wastewater to create
aerobic conditions. At depths greater than four feet, anaerobic micro-organisms will
become active in the lowest levels; thus, stabilization basins are shallow. Typically, the
basin is earthen; however, some are lined with compacted clay. Wastewater retention time
may last up to thirty days to achieve up to ninety percent BOD5 removal.
Some kraft mills use both aerated and non-aerated basins. The stabilization basin,
which may precede or follow the aerated stabilization basin, serves as a "polishing" or
"holding" pond to remove additional organic wastes, including biological solids, or to
control final effluent discharge to receiving waters.
Activated sludge system. This system features a microbial floe held in suspension in
an aeration chamber. Soluble organic matter in the wastewater is metabolized by the
microbial floe which changes it into solids, thereby increasing the suspended solids load.
After aeration, treated wastewater is routed to a clarifier where the settled solids are
removed as sludge. A significant fraction of this sludge is recycled back to the aeration
chamber to maintain the high level of microbial floe (this is the "activated sludge"). The
sludge that is removed is dewatered and disposed. Retention time for this system can
range from less than six to over 12 hours.
7.2.2 Air Pollutant Emissions
The two main sources of air pollutants that may be emitted from the basic
wastewater treatment plant operations are the pulping condensates and the bleach plant
effluent. The pulping condensates may include total reduced sulfur (TRS) compounds as
well as volatile organic compounds (VOC), such as methanol. The primary pollutants of
concern for the bleach plant effluent are chloroform and methanol. Air emission concerns
for the pulping condensates and bleach plant effluent are covered in Sections 4 and 6,
respectively. The other sources of volatile compounds that could be released as air
emissions from basic wastewater treatment plant operations are relatively minor in
comparison to emissions from other mill operations and are generally not subject to specific
regulation.
In addition, if a mill operates a sludge incinerator, there will be emissions from the
incinerator. Inorganic gases (such as CO, NOX, SOX, and HCL) may be present, as well as
particulate matter (including ash and heavy metals) and organic gases. The only compound
subject to specific federal regulations for industrial wastewater sludge incinerators is
mercury (40 CFR Part 61, Subpart E). In most cases, compliance with the Subpart E
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Wastewater Treatment Plant Assessments Section 7
incinerator requirements involves only an initial test to document mercury levels, with a
follow up estimate of the impact on mercury emissions if operating conditions are changed.
For this reason, these emissions are not discussed further in this section.
7.2.3 Water Pollutant Discharges
As discussed above, kraft mills treat wastewater in order to minimize effluent
impacts on receiving waters. Generally, treated effluent is discharged from the wastewater
treatment system from one discharge point. The following pollutants of concern exist at all
kraft mills: BOD5, total suspended solids (TSS), color, and chemical oxygen demand
(COD). At kraft mills that bleach pulp with chlorine-containing compounds, additional
pollutants of concern are: chloroform; 2,3,7,8-TCDD; 2,3,7,8-TCDF; chlorinated phenolic
compounds; and adsorbable organic halides (AOX). Each of these pollutants is discussed
below.
BOD5 and TSS. High concentrations of organic matter found in kraft mill
wastewater result in large quantities of BOD5. Treatment of this BOD5 results in the
generation of large quantities of TSS. In general, kraft mills achieve ninety percent (or
greater) removal of these pollutants when primary and secondary treatment are well-
operated.
Color. Kraft pulp mill effluents contain highly colored lignin and lignin derivatives
that have been solubilized and removed from wood during pulping and subsequent
bleaching operations. For kraft mill wastewaters, color is determined by
spectrophotometric comparison of the sample with a 1 mg/L solution of platinum, in the
form of chloroplatinate ion. The color of kraft mill wastewaters is considered to be the
color of the water from which turbidity has been removed ("true" color). Further,
wastewater color is highly pH dependent, so the pH of color samples is adjusted to pH 7.6.
The EPA has not promulgated national regulations for color because the potential
for significant aesthetic or aquatic impacts from color discharges is driven by highly
site-specific conditions, such as the color of the receiving stream and the relative
contribution of the mill discharge to the stream flow. However, many individual NPDES
permits contain water quality-based effluent limitations on the discharge of color,
developed to address local conditions.
COD. COD is a measure of the quantity of chemically oxidizable material present
in wastewater. Sources of COD include the pulping area, chemical recovery area,
bleaching area, and papermaking area. A portion of COD is readily biodegradable while
the rest is resistant to biodegradation (i.e., "refractory"). Although the amount and sources
of refractory COD will vary from mill to mill, some portion of it is derived from black
liquor; thus, COD biodegradability indicates the degree to which black liquor is recovered
from brown stock pulp and kept out of wastewater through effective BMPs. Wastewater
COD loads also relate to discharges of toxic organic pollutants that are not readily
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Section 7 Wastewater Treatment Plant Assessments
biodegraded. Although EPA has not established COD effluent limitations guidelines at this
time, EPA is planning to do so in a future rulemaking.
Chloroform. Chloroform is an extremely volatile compound that is generated
during the bleaching of pulp with hypochlorite, chlorine, or chlorine dioxide. Hypochlorite
bleaching results in the greatest amount of chloroform generation, while chlorine dioxide
bleaching results in the least amount of chloroform generation. As chloroform is
generated, it partitions to air and to bleach plant effluent (with a small fraction remaining
with the pulp). Any chloroform found in bleach plant effluent that is not emitted to the air
prior to reaching the wastewater treatment plant may be volatilized or degraded during
secondary treatment or discharged in the effluent.
2,3,7,8-TCDD (dioxin) and 2,3,7,8-TCDF (furan). During the late 1980s,
bleaching with chlorine and hypochlorite were discovered to be sources of dioxin and
furan. Although use of chlorine dioxide (C1O2) bleaching minimizes the formation of
chlorinated pollutants, measurable quantities of 2,3,7,8-TCDF and possibly 2,3,7,8-TCDD
may still be formed. Dioxin and furan are not effectively degraded during wastewater
treatment; they partition to the sludge and may be discharged with TSS into receiving
waters untreated.
Chlorinated phenolic compounds. Chlorinated phenolic compounds include
phenols, guaiacols, catechols, and vanillins substituted with from one to five chlorine atoms
per molecule. Typically, bleaching processes that result in the formation of 2,3,7,8-TCDD
and 2,3,7,8-TCDF also generate the higher substituted tri-, tetra-, and penta-chlorinated
compounds. EPA has established effluent limitations guidelines and pretreatment standards
for the following twelve chlorinated phenolic compounds:
Trichlorosyringol
3,4,5-Trichlorocatechol
3,4,6-Trichlorocatechol
3,4,5-Trichloroguaiacol
3,4,6-Trichloroguaiacol
4,5,6-Trichloroguaiacol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Tetrachlorocatechol
Tetrachloroguaiacol
2,3,4,6-Tetrachlorophenol
Pentachlorophenol
Adsorbable organic halides (AOX). AOX is a measure of the total amount of
halogens (chlorine, bromine, and iodine) bound to dissolved or suspended organic matter in
a wastewater sample. In bleached kraft mill effluent, essentially all of the AOX is
comprised of chlorinated compounds formed during bleaching with chlorine and other
chlorinated bleaching agents. Inefficient application of chlorine-containing bleaching
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Wastewater Treatment Plant Assessments Section 7
chemicals can generate increased levels of AOX. Minimizing AOX will usually have the
effect of reducing the generation of chloroform, 2,3,7,8-TCDD, 2,3,7,8-TCDF, and
chlorinated phenolic compounds. Some AOX is biodegraded during secondary treatment.
In addition to retaining the existing effluent limitations guidelines and standards for
BOD5, TSS, and pH, the Cluster Rules establish new effluent limitation guidelines and
standards for bleached papergrade kraft mills for the other parameters described above,
with the exception of color and COD. The Cluster Rules regulations require bleached kraft
mills to meet limits on in-process streams and treated effluent, depending on the pollutant
(see Section 7.3.3). See the References for further sources of information on the
applicable discharges and control strategies.1'2'3'4
7.2.4 Solid/Hazardous Waste Discharges
Kraft pulp mills generate both primary sludge and secondary (biological) sludge.
The collected sludges may be thickened in gravity or flotation thickeners and/or chemically
conditioned prior to dewatering. Primary sludge is usually generated in greater quantities
than biological sludge. Although the sludges potentially can be used for alternative
beneficial uses, generally dewatered sludges are disposed of through land application,
landfilling, or combustion. Because of concerns about potential contamination with dioxin,
under paragraph l(l)(ii) of the Consent Decree in EDF v Browner Civ. No. 89-0598
(D.D.C), EPA was required to make a hazardous waste listing determination for sludges
from bleached kraft mill effluents unless the final effluent guidelines were based on the use
of at least one of certain specified technologies. These technologies enable the mill to use
less chlorine in bleaching pulp and thus to generate less dioxin contamination. After the
promulgation of the Cluster Rules, EPA determined that the final guideline was based on
the specified technologies, and thus EPA determined that it was not required to make a
hazardous waste listing determination for pulp mill sludges.5 If the sludges at a particular
mill exhibit a hazardous waste characteristic, the sludges would be hazardous wastes even
without an EPA listing determination.
Sludge handling processes. Some mills may perform sludge grinding, gravity, or
flotation thickening or chemical preconditioning to achieve up to ten percent sludge solids
content. Dewatering, the most common sludge handling process, is described below.
Belt filter press. Sludge is squeezed between two porous cloth belts. The
dewatered sludge cake is scraped from the belts by blades. This operation results in typical
sludge solids content of fifty percent for primary sludge and twenty percent for biological
sludge.
Vacuum filters. Vacuum filter systems consist of a horizontal cylinder partially
submerged in a tank of sludge. A layer of porous filter media fabric or tightly wound coils
covers the outer surface of the cylinder. As the cylinder surface passes through the sludge
tank, a layer of sludge adheres to the cylinder, and vacuum is applied. The dewatered
sludge cake is then scraped off the fabric and consists of up to thirty percent solids.
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Section 7 Wastewater Treatment Plant Assessments
Screw presses. Many kraft mills use screw presses that can achieve up to fifty-five
percent sludge solids when dewatering primary sludge. This operation does not require
preconditioning to achieve high sludge solids content.
Sludge disposal processes. Subsequent to sludge handling processes, kraft mills
dispose of sludge by land application, landfill, or combustion. Each disposal method is
discussed below.
Land application. Sludge from kraft mills is classified as a soil amendment because
it is too low in nutrients to be of any value as a fertilizer. Due to concerns regarding dioxin
and furan contaminated sludges, in 1994 EPA and AF&PA entered into an agreement
governing the land disposal of sludge.6 In this agreement, AF&PA agreed to compile
annual monitoring reports for those mills that land apply materials with a dioxin/furan
concentration equal to or greater than 10 ppt. Individual mills also entered in separate
agreements with EPA governing the land application of their sludges.
Landfill. This is the most common disposal method. Kraft mills may use on-site
landfills or off-site commercial landfills.
Combustion. Some mills will combust the sludge for heat recovery in a specialized
sludge incinerator, or a hogged or fossil fuel power boiler. Currently, this disposal method
is less common than landfilling.
7.2.5 EPCRA Chemicals and Reportable Releases
Facilities will have to provide information on chemicals used in the wastewater
treatment plant to meet EPCRA's emergency preparedness requirements. Appendix D
contains a process-based list of the types of hazardous chemicals that may be included in an
EPCRA inventory for a kraft pulp mill.
On-site air, water and land (i.e., sludge) releases, including land disposals, of toxic
chemicals from the wastewater treatment plant and off-site transfers of waste containing
these toxic chemicals may have to be accounted for in filing TRI Form R reports. In
addition, EPCRA/CERCLA emergency release reporting could apply for off-site releases
that are not federally permitted and that exceed a certain reportable quantity. These
releases most likely would involve water discharges resulting from wastewater treatment
plant upsets or could involve spills resulting from material storage and handling activities.
These EPCRA issues are discussed in Section 7.6.
7.3 CWA Regulatory Requirements
Section 402 of the Clean Water Act (CWA) mandated that EPA establish the
National Pollution Discharge Elimination System (NPDES) program to minimize the
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Wastewater Treatment Plant Assessments Section 7
discharge of pollutants to receiving waters. Within the NPDES program, industrial
facilities that discharge process wastewaters from any point source into waters of the
United States (i.e., direct dischargers) are required to obtain an NPDES permit. Permitting
authorities must develop NPDES permits using technology-based effluent limitations
guidelines established by EPA for the relevant industrial category. In cases where
technology-based effluent limitations guidelines are insufficient to achieve and maintain the
water quality standards of receiving waters, permitting authorities must impose water
quality-based effluent limits (WQBELs) in addition to, or in place of, technology-based
effluent limitations.
Technology-based effluent limitations. Technology-based effluent limitations
guidelines and standards are established to require a minimum level of treatment for
industrial point sources based on currently available in-plant process control and external
treatment technologies, while allowing the discharger to use any available control
technique to meet the limitations. The technology-based effluent limitations guidelines and
standards established in 40 CFR Part 430 are based on the demonstrated performance of
model process and treatment technologies that are within the economic means of the pulp
and paper industry.
Kraft mills are subject to one of three federal effluent limitation regulations in 40
CFR Part 430:
! Subpart B for bleached papergrade kraft and soda mills
! Subpart A for dissolving kraft mills
! Subpart C for unbleached kraft mills
Mills that use purchased pulp, as well as pulp that they make on site, in their final
product are also subject to effluent limitations regulations in:
! Subpart K for fine and lightweight papers
! Subpart L for tissue, filter, non-woven, and paperboard
For mills that discharge their wastewater directly to a receiving stream, these
subparts establish effluent limitations guidelines that are implemented through the NPDES
permit process. A mill is not required to comply with the guidelines until they are
incorporated into the mill's NPDES permit, which is effective for five years. For mills that
discharge their wastewater indirectly (i.e., to a POTW), the subparts establish pretreatment
standards, which are effective on the dates specified in the regulations.
In the Cluster Rules, EPA revised effluent limitation guidelines and pretreatment
standards for bleached papergrade kraft and soda mills, and revised the sub categorization
scheme of Part 430. The EPA intends to promulgate revised regulations for unbleached
kraft and dissolving kraft mills in future rulemakings.
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Section 7
Wastewater Treatment Plant Assessments
Water quality-based effluent limitations (WQBELs). All receiving waters have
ambient water quality standards which are established by the states or EPA in accordance
with federal regulations to maintain and protect designated uses of the receiving water
(e.g.. aquatic life-warm water habitat, public water supply, and primary contact recreation).
States can use the total maximum daily load (TMDL) process to quantify the allowable
pollutant loadings in receiving waters, based on the relationship between pollution sources
and in-stream water quality standards.
Some permitting authorities may find that the application of the technology-based
effluent limitations guidelines result in pollutant discharges that still cause exceedances of
the water quality standards in particular receiving waters. In such cases, permitting
authorities are required to develop more stringent WQBELs for the pollutant to ensure that
the water quality standards are met. For a description of how water quality standards are
developed and incorporated into permits, refer to Guidance for Water Quality-Based
Decisions: The TMDL Process (EPA 440/4-91-001) and Technical Support Document for
Water Quality-Based Toxics Control (EPA/505/2-90-001).
Summary of national regulatory requirements. This section describes the
applicable national regulatory requirements for bleached, unbleached, and dissolving kraft
mills, and points out where additional regulations may be added in the future. The
inspector, however, should note that permit requirements will be specifically tailored for
each discharging facility. Figure 7-2 summarizes the discussion of regulatory requirements
presented below.
Figure 7-2
Wastewater Regulations for Existing Kraft Pulp Mills
Type of
Kraft Mill
Bleached
Kraft Mills
Unbleached
Kraft Mills
Dissolving
Kraft Mills
Direct or
Indirect
Discharger
Direct Discharger
Indirect Discharger
Direct Discharger
Indirect Discharger
Direct Discharger
Indirect Discharger
BPT
/
/
/
Pre-Cluster
Rules BAT
/
/
/
Cluster
Rules
BAT
/
Pre-Cluster
Rules PSES
/
/
/
Cluster
Rules
PSES
/
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Wastewater Treatment Plant Assessments
Section 7
7.3.1 Pollutants Regulated
Prior to the Cluster Rules, direct discharge kraft mills were subject to:
! Best practicable control technology currently available (BPT) and best conventional
pollutant control technology (BCT) guidelines for the control of conventional
pollutants (BOD5, TSS, and pH)
! Best available technology economically achievable (BAT) guidelines for the control
of toxic and nonconventional pollutants (pentachlorophenol and trichlorophenol,
chemicals commonly used as biocides)
! New source performance standards (NSPS) for the same pollutants for new direct
dischargers
Indirect discharge kraft mills were subject to performance standards for existing
sources or new sources (PSES or PSNS, as applicable) for the control of
pentachlorophenol and trichlorophenol.
For kraft pulp mills, the Cluster
Rules add new requirements only for
bleached papergrade kraft mills. For
this subset of kraft mills, the Cluster
Rules adds effluent limitations
guidelines and standards for the
following BAT and PSES pollutants
(and NSPS/PSNS for new sources):
chloroform; 2,3,7,8-TCDD; 2,3,7,8-
TCDF; twelve chlorinated phenolic compounds; and AOX. All of the pre-Cluster Rules
effluent limitation guidelines and standards applicable to kraft pulp mills remain in effect,
although the Cluster Rules reorganized these limits into new subcategories.
7.3.2 Subcategorization
NOTE! For kraft pulp mills, the Cluster
Rules add toxic and nonconventional
pollutants to the list of regulated
pollutants only for bleached papergrade
kraft mills. All existing guidelines and
standards for kraft mills remain in effect.
NOTE! Cluster Rules collapsed four
previous bleached papergrade kraft mill
subparts into 40 CFR 430 Subpart B and
three previous unbleached kraft subparts
into 40 CFR Part 430 Subpart C.
The Cluster Rules reorganized
the Subcategorization scheme of Part
430 to simplify the categories.
Previously, mills were grouped by the
types of products manufactured. The
Cluster Rules reduced the number of
subcategories by grouping mills by
similar processes.
In the previous regulation, bleached kraft mills were divided into four subparts and
unbleached kraft mills were divided into three subparts. As a result, the remaining pre-
Cluster Rules limits (i.e., BPT for BOD5, TSS, and pH, and BAT and PSES for
pentachlorophenol and trichlorophenol) for the four previous bleached kraft mill subparts
now exist as four segments of 40 CFR Part 430 (Subpart B). Likewise, the remaining pre-
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does not alter any statutory or regulatory requirements.
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Section 7 Wastewater Treatment Plant Assessments
Cluster Rules limits for the three previous unbleached kraft subparts now exist as three
segments of 40 CFR Part 430 (Subpart C).
7.3.3 Compliance Monitoring Requirements and Locations
Before the Cluster Rules, all compliance monitoring for direct dischargers occurred
at a location in the plant downstream of treatment but prior to the point at which the final
effluent is discharged to the receiving waters. The revised BAT regulations require all
bleached kraft mills, both direct and indirect dischargers, to demonstrate compliance with
limitations for fifteen chlorinated compounds at the bleach plant (see Section 6). Bleach
plant effluent limits are necessary for 2,3,7,8-TCDD, 2,3,7,8-TCDF, and the twelve
chlorinated phenolic pollutants because pulp bleaching is the principal source of these
pollutants, and it would not be possible, in all instances, to properly assess compliance at
the final mill effluent due to dilution effects created by other wastewaters. Bleach plant
effluent limits for chloroform are also necessary because there is the potential for
volatilization and loss in mill sewer systems.
NOTE! Direct discharge bleached kraft
mills must assess compliance with AOX
limitations at the final effluent discharge.
Indirect discharge mills, however, must
assess compliance with AOX limitations
at the bleach plant.
Direct discharge bleached
kraft mills must assess compliance
with AOX limitations at the point at
which the final effluent is discharged
to receiving waters (unless the permit
provides otherwise). Indirect
discharge mills, however, must assess
compliance with AOX limitations at
the bleach plant, because POTWs
cannot achieve, through wastewater treatment alone, the degree of AOX removal achieved
by in-process technologies that form the basis of BAT.
For the remaining regulated pollutants, the compliance monitoring requirements
still apply at the point of final discharge. Note that, for the biocides pentachlorophenol and
trichlorophenol, most mills certify that they do not use these chemicals and thus need not
monitor effluent to demonstrate compliance. Figure 7-3 summarizes the discharge
monitoring requirements that apply.
7.3.4 Production Definitions
Limits for BOD5 and TSS, established before the Cluster Rules, are production
normalized - that is, they are expressed as pounds per 1,000 pound (or kg/kkg) of
product. Product is defined as "... the annual off-the-machine production (including off-
the-machine coating where applicable) divided by the number of operating days during that
year." This definition includes the weight contributed by coatings and additives (e.g.. clay,
dyes, strengthening agents, etc.) which may account for as much as twenty percent of a
final paper product's weight. If the mill produces market pulp, product is defined as
production of market pulp in air-dried metric tons (ADMT) with ten percent moisture
content.
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Wastewater Treatment Plant Assessments
Section 7
Figure 7-3
Monitoring Requirements
Pollutant
Chlorinated Phenolic Pollutants*
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform
AOX
Pentachlorophenol
Trichlorophenol
BOD5
TSS
pH
Monitoring Location, Bleached Papergrade Kraft Mills
Direct Discharge Facilities
Bleach plant effluent
Bleach plant effluent
Bleach plant effluent
Bleach plant effluent
Final effluent
Final effluent (or certify not used)
Final effluent (or certify not used)
Final effluent
Final effluent
Final effluent
Indirect Discharge Facilities
Bleach plant effluent
Bleach plant effluent
Bleach plant effluent
Bleach plant effluent
Bleach plant effluent
Final effluent (or certify not used)
Final effluent (or certify not used)
No national standards
No national standards
No national standards
* Chlorinated phenolic pollutants are: tetrachlorocatechol; tetrachloroguiacol; trichlorosyringol;
4,5,6-trichloroguaiacol; 3,4,6-trichlorocatechol; 3,4,5-trichlorocatechol; 3,4,5-trichloroguaiacol;
2,3,4,6-tetrachlorophenol; 3,4,6-trichloroguaiacol; pentachlorophenol; 2,4,6-trichlorophenol;
2,4,5-trichlorophenol.
NOTE! Product is defined as off-machine
tons (or air dry tons for market pulp) for
BOD5 and TSS limits, but as air-dried
tons of unbleached pulp entering the
bleach plant for AOX and chloroform
limits.
The Cluster Rules limits for
AOX and chloroform are also
production normalized (with the
exception noted below). However, for
the Cluster Rules limits, product is
defined as "... the annual unbleached
pulp production entering the first stage
of the bleach plant divided by the
number of operating days during that
year." The unbleached pulp must be measured in air-dried metric tons (with ten percent
moisture) of brown stock pulp entering the bleach plant at the stage in which chlorine-
containing compounds are first applied to the pulp. The other pollutant limits established
by the Cluster Rules (2,3,7,8-TCDD; 2,3,7,8-TCDF; and the 12 chlorinated phenolic
compounds; as well as AOX and chloroform limits for mills that certify to using totally
chlorine free bleaching) are expressed as pollutant concentrations (e.g.. micrograms per
liter and picograms per liter). Note that the limitations, expressed as less than the minimum
level (
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Section 7 Wastewater Treatment Plant Assessments
Typically, when effluent limitation guidelines are production normalized, permit
limits are expressed as pounds of pollutant per day. To calculate these limits, the permit
writer uses a daily production calculated from one year's data representative of operations
for the five years prior to permit issuance. In certain circumstances, however, production
for the past five years is not appropriate. For example, if a mill significantly expanded its
operations, production should be based on data representative of the period of increased
production. When effluent limitation guidelines are expressed as concentrations, permit
limits are typically expressed as concentrations as well.
7.3.5 Storm Water Permitting
The CWA requires an NPDES permit for storm water discharges associated with
industrial activity. As discussed in Appendix B, EPA or state agencies (as applicable)
typically issue "general" permits to authorize discharges from a group of similar facilities.
Storm water discharges from some mills, however, may be covered by site-specific
"individual" permits. Where EPA is the NPDES permitting authority, most mills will be
covered by EPA's multi-sector general permit (MSGP) requirements. State permit
requirements will vary but, in general, can be expected to include requirements comparable
to the MSGP requirements. The main elements of the permit are to maintain a storm water
pollution prevention (SWPP) plan and conduct certain limited monitoring (quarterly visual
examinations of grab samples and, in some cases, analytical tests for particular pollutants,
such as COD, TSS, and total recoverable iron).
Both the wastewater treatment plant operations and the sludge landfill/land
application sites at a kraft pulp mill are potential sources of contaminated storm water.
The EPA considers landfills and land application sites a separate sector within the MSGP.
The EPA has listed general best management practices (BMPs) for these operations. In
addition, treatment works for sewage are a separate sector for which EPA also has
developed appropriate BMPs. Although this MSGP sector is not specifically applicable
nor binding to industrial wastewater treatment facilities, many of these BMPs are relevant
to industrial facilities. Thus, the SWPP for kraft pulp mill wastewater treatment facilities
should have comparable BMPs to sewage treatment works and should cover the same
basic potential sources of contaminated storm water. Figures 7-4 and 7-5 outline the BMP
guidelines established by EPA for treatment works and landfills, respectively. For landfill
and land application sites, the monitoring requirements in Figure 7-6 apply in addition to
the basic quarterly visual monitoring requirements applicable to all sources covered by the
MSGP.
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Figure 7-4
General Storm Water BMPs for Treatment Works
Activity
BMPs
Preparation of Biological and Physical
Treatment Process
! Use drip pans under drums and equipment where feasible
! Store process chemical inside buildings
! Inspect the storage yard for filling drip pans and other problems regularly
! Train employees on procedures for storing and inspecting chemicals
Soil Amending and Grass Fertilizing
! Use the appropriate amount of fertilizer
! Do not overfertilize
! Train employee on proper fertilizing techniques
Liquid Storage in Above-Ground
Storage Containers
! Maintain good integrity of all storage containers
! Install safeguards (such as diking or berming) against accidental releases
at the storage area
! Inspect storage tanks to detect potential leaks and perform preventive
maintenance
! Inspect piping systems (pipes, pumps, flanges, couplings, hoses, and
valves) for failures or leaks
! Train employees on proper filling and transfer procedures
Pest Control
Minimize pesticide application — only apply pesticide if needed
Train employees on proper pesticide application
Sludge Drying Beds
Ensure drying bed is draining properly (e.g., check for clogging)
Avoid overfilling drying bed
Grade the land to divert flow around drying bed
Berm, dike, or curb drying bed areas
Cover drying beds
Sludge Storage Piles
Confine storage of sludge to a designated area as far from any receiving
water body as possible
Store sludge on an impervious surface (e.g., concrete pad)
Grade the land to divert flow around storage piles
Berm, dike, or curb sludge storage piles
Cover sludge storage piles
Sludge Transfer
Promptly remove any sludge spilled during transfer
Conduct transfer operations over an impervious surface
Avoid transferring sludge during rain events
Grade the land to divert flow around transfer areas
Berm, curb, or dike transfer areas
Avoid locating transfer operations near receiving water bodies
Incineration — Ash
Impoundments/Piles
Line ash impoundments with clay (or other type of impervious material)
Ensure ash impoundments will hold maximum volume of ash and a 10-
year, 24-hour rain event
Curb, berm, or dike ash storage areas
Avoid locating ash storage areas near receiving water bodies
Miscellaneous
Properly dispose of grit/scum and dispose of screens on a daily basis
Maximize vegetative cover to stabilize soil and reduce erosion
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Figure 7-5
Potential Sources of Pollution and General Storm Water BMPs for Landfills
Potential Pollutant Sources
BMPs
Erosion from:
! Exposed soil from excavating
cells/trenches
! Exposed stockpiles of cover materials
! Inactive cells with final cover but not yet
finally stabilized
! Daily or intermediate cover placed on cells
or trenches
! Erosion from haul roads (including vehicle
tracking of sediments)
Stabilize soils with temporary seeding, mulching, and geotextiles;
leave vegetative filter strips along streams
Implement structural controls such as dikes, swales, silt fences,
filter berms, sediment traps and ponds, outlet protection, pipe
slope drains, check dams, and terraces to convey runoff, to divert
storm water flows away from areas susceptible to erosion, and to
prevent sediments from entering water bodies
Frequently inspect all stabilization and structural erosion control
measures and perform all necessary maintenance and repairs
Stabilize haul roads and entrances to landfill with gravel or stone
Construct vegetated swales along road
Clean wheels and body of trucks or other equipment as necessary
to minimize sediment tracking (but contain any wash waters
[process wastewaters])
Frequently inspect all stabilization and structural erosion control
measures and perform all necessary maintenance and repairs
Application of fertilizers, pesticides, and
herbicides
Observe all applicable Federal, State, and local regulations when
using these products
Strictly follow recommended application rates and methods (i.e.,
do not apply in excess of vegetative requirements)
Have materials such as absorbent pads easily accessible to clean
up spills
Exposure of waste at open face
! Minimize the area of exposed open face as much as is practicable
! Divert flows around open face using structural measures such as
dikes, berms, swales, and pipe slope drains
! Frequently inspect erosion and sedimentation controls
Waste tracking onsite and haul roads, solids
transport on wheels and exterior of trucks or
other equipment (common with incinerator
ash)
! Clean wheels and exterior of trucks or other equipment as
necessary to minimize waste tracking (but contain any wash waters
[process wastewaters])
Uncontrolled leachate (commingling of
leachate with runoff or runon)
! Frequently inspect leachate collection system and landfill for
leachate leaks
General sources
! Maintain landfill cover and vegetation
! Maintain leachate collection system
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Section 7
Figure 7-6
Stormwater Monitoring Requirements for Landfill/Land Application Sites
Pollutant
Monitoring Requirements
Total Suspended
Solids (TSS)
In 2nd year of permit, conduct quarterly monitoring
Calculate average concentration for TSS — if > 100 mg/L, then conduct same quarterly
sampling in 4th year of permit
In 4th year of permit, conduct quarterly TSS monitoring if landfill/land application activities
or SWPP plan have been altered such that the storm water discharges will be adversely
affected
Total Recoverable
Iron
In 2nd year of permit coverage, conduct quarterly monitoring
Calculate average Total Recoverable Iron concentration — if > 1.0 mg/L, then conduct same
quarterly sampling in 4th year of permit
In 4th year of permit, conduct quarterly Total Recoverable Iron monitoring if landfill/land
application activities or SWPP plan have been altered such that the storm water discharges
will be adversely affected
7.4 CWA Inspection Techniques
The NPDES Compliance Inspection Manual (EPA 300-B-94-014) provides
inspectors with the information necessary to prepare for and perform thorough compliance
assessments of wastewater treatment plants at direct discharging kraft mills that must
comply with NPDES permits. See Section 2.4 of this manual for a description of the
various types of NPDES inspections addressed in the NPDES Compliance Inspection
Manual. Wastewater inspections of indirect discharging kraft mills may be undertaken as
part of an Approval Authority's evaluation of a POTW's pretreatment program. The
Approval Authority will either be the EPA Regional Office or the State with an approved
NPDES program. Guidance for Conducting a Pretreatment Inspection (EPA 300 R92-
009) details the procedures an Approval Authority should use to conduct a Pretreatment
Compliance Inspection, including procedures for reviewing Industrial User files and visits
to Industrial Users.
Note that a facility is not
required to comply with national
effluent limitations guidelines until
they are incorporated into the facility's
NPDES permit. Permit requirements
will be specifically tailored for each
discharging facility. The inspection
procedures discussed below refer to
the requirements of 40 CFR Part 430.
Compliance, however, must always be
evaluated against a mill's permit.
NOTE! Compliance must always be
evaluated against a mill's permit, because
national effluent limitations guidelines are
not binding until they are incorporated in
an NPDES permit. Also, mills are only
authorized to discharge wastewaters from
operations identified in their permit
application.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Section 7 Wastewater Treatment Plant Assessments
The purpose of this section is to provide further information specific to kraft mills
that will assist:
! Inspectors in assessing kraft pulp mill compliance with NPDES permit limits
applied at the mill's final effluent discharge to the receiving stream. This section
generally outlines procedures consistent with conducting a Compliance Evaluation
Inspection (CEI) or Compliance Sampling Inspection (CSI)
POTWs as they assess the compliance of kraft pulp mills with pretreatment permits
Approval Authorities when inspecting POTWs that receive wastewater from kraft
pulp mills
7.4.1 Record Reviews
The elements of a comprehensive record review undertaken as part of an NPDES
compliance inspection are presented in Sections 2A (Pre-Inspection Preparation) and 3 A
(Documentation, Recordkeeping, and Reporting Evaluation Procedures) of the NPDES
Compliance Inspection Manual. Pre-inspection preparation includes review of facility
background information, such as:
General mill information
Copies of all permits, regulations and restrictions placed on the mill discharge
(including the NPDES permit application, "fact sheet," and other information in the
NPDES permit file)
Receiving stream water quality standards
Mill compliance and enforcement history (including Discharge Monitoring Reports)
While on site, the inspector should review mill records to verify that the permit
description of mill operations is correct, current, and complete. In addition, the inspector
should:
Verify that the mill is meeting all recordkeeping and reporting requirements
Determine the mill status with any compliance schedules established as part of an
enforcement order
! For indirect dischargers, verify that the mill is meeting POTW pretreatment
requirements
Record review activities specific to kraft mills are described below.
As described in Section 4.6.2, Best Management Practices (BMPs) promulgated as
part of the Cluster Rules require bleached kraft mills to monitor the influent to the
wastewater treatment system for a measure of organic content such as COD or Total
Organic Carbon (TOC). Alternatively, the mill may use a measure related to spent pulping
liquor losses measured continuously, such as conductivity or color. The Discharge
Monitoring Reports (DMRs) and reports of BMP monitoring activities must be submitted
to the permitting authority annually, or more frequently if required by permit. Further, as
discussed in Section 4.5, mills deciding to comply with the MACT standards for pulping
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Wastewater Treatment Plant Assessments Section 7
process condensates by transporting the condensates to, and treating them in, the mill's
biological treatment system, have additional monitoring and recordkeeping requirements.
Prior to the inspection, the inspector should review the following to focus the on-
site phase of the inspection:
Permit review. Review permit(s) applicable to the effluent discharges, the permit
application and fact sheet. In addition, the inspector may want to review air emission
permits to determine if the mill chose to comply with MACT standards for pulp mill
condensates by using the mill biological treatment system. If so, a multi-media screening
inspection opportunity exists for the water inspector. The water inspector can review the
MACT requirements for monitoring the treatment system and all available monitoring
reports. See Section 4.5.3 for a discussion of inspection procedures for determining
compliance with the MACT standards for pulping condensates.
DMR review. The inspector should review DMRs submitted since the last
inspection to determine whether there has been a violation of permit limits and to identify
any excursions from typical performance that may not have been violations. If problems
are indicated, they should be discussed during the on-site inspection. Events occurring at
the mill and in the treatment plant at the time of the excursions should be reviewed with
mill operators to determine both the cause of the problem and the corrective action taken
by the mill.
Identify black liquor spills. Black liquor (spent pulping liquor) spills may upset
the operation of the wastewater treatment plant. Indications of such a spill may be initially
detected during DMR review, as described above. If the inspector identifies any
excursions from typical treatment system performance, during the on-site inspection the
inspector should:
! Review records of the influent flow and pollutant load (COD, TOC, conductivity,
or color) that the mill is required to maintain in accordance with the Cluster Rules'
BMP requirements. If BMP action levels were exceeded, did the mill undertake the
required corrective actions?
! Review operator logs to determine if spills were recorded
! Interview operators (detailed in Section 7.4.2)
! Verify that the mill prepared a report of all spills and intentional diversions not
contained at the immediate process area
Review spill record reports required by BMPs
Consider forwarding the information to an EPCRA inspector for follow-up on
emergency notification requirements
Determine if MACT standards were met. If a mill has chosen to comply with
MACT standards for pulp mill condensates by transporting the condensates to, and treating
them in, the mill biological treatment system, treatment system upsets may result in
exceedances of MACT standards. If the inspector identifies any excursions from typical
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Section 7 Wastewater Treatment Plant Assessments
treatment system performance, the inspector should assess compliance with the applicable
MACT standards or forward the concern to the air inspector for follow-up (see Section
4.5.3).
7.4.2 Physical Inspection of Wastewater Treatment Plants (Mill Site Review)
The elements of a comprehensive facility site review undertaken as part of an
NPDES compliance inspection are presented in Section 4 (Facility Site Review) of the
NPDES Compliance Inspection Manual. Site review includes a physical inspection of the
wastewater treatment plant, as well as an evaluation of operation and maintenance
procedures and practices. The inspector should visually examine:
! Wastewater treatment plant influent characteristics
! Process controls
! All components of the wastewater treatment plant, including supply of treatment
chemicals and sludge handling equipment
! Equipment condition
! Safety controls and equipment
! Effluent characteristics
! Flow measurement devices
The inspector should also interview treatment plant operators and maintenance
staff. Topics discussed should include:
! Policies and procedures
! Organization
! Staffing and training
! Planning and scheduling
! Record systems
! Spare parts and treatment chemical inventory controls
! Stand-by equipment
During these interviews, the inspector should determine if there have been any production
changes that were not anticipated when the permit was issued.
Facility site review issues specific to kraft mills are discussed below.
Interview wastewater treatment plant personnel. Inspectors should interview
wastewater treatment plant operators and staff to determine:
! How personnel in the pulping area report imminent upsets or discharges of highly
contaminated wastewater (i.e., shock loads) to wastewater treatment personnel
How wastewater treatment plant personnel respond to spills in the process area
If there have been mill upsets that affected wastewater treatment plant operations
(that may not have been identified during record review)
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Wastewater Treatment Plant Assessments Section 7
! How any spills or intentional diversions of process materials (pulp, black liquor,
soap, turpentine, lime mud, or other materials) were accommodated by wastewater
treatment
! Number and level of certified operators
Remember, even though permit limits have not been exceeded, the failure to document a
spill not contained in the immediate process area constitutes a violation of the spent liquor,
soap and turpentine BMP requirements discussed in Section 4.6. In addition, exceedances
of influent monitoring action levels established as part of the BMP Plan do not constitute
permit violations; however, failure to investigate and correct exceedances are violations.
Examine wastewater treatment plant equipment. In addition to evaluating the
final effluent monitoring equipment, inspectors should examine the equipment used to
monitor the influent to the wastewater treatment plant, as required by BMPs. For direct
dischargers, monitoring must be conducted at the point influent enters the wastewater
treatment system. For indirect dischargers, monitoring must be conducted at the point of
discharge to the POTW. Mills may select alternate monitoring locations in order to isolate
possible sources of black liquor, soap, or turpentine from other streams routed to
treatment, such as non-contact cooling water. Inspectors should review the mill's BMP
plan to identify these locations. Inspectors should examine the monitoring equipment to
ensure that it is operational and in the specified (and appropriate) location. Inspectors
should also determine how the equipment is calibrated and at what frequency.
7.4.3 Flow Monitoring Evaluations
The elements of flow monitoring evaluations undertaken as part of an NPDES
compliance inspection are presented in Section 4B (Physical Inspection of the Facility) and
Section 6 (Flow Measurement) of the NPDES Compliance Inspection Manual. Flow
monitoring evaluations include a review of the general conditions of those flow
measurement devices necessary for compliance with NPDES permit conditions, such as:
! Surcharging of influent lines, overflow weirs and other structures
! Flowthrough bypass channels
! Overflows at alternative discharge points
! Flow from unknown source or origin
NPDES permits require accurate determination of the quantity of wastewater discharged.
Thus, accuracy of the flow measurement must be determined by the inspector. The
inspector should verify that:
! Facility-installed flow devices are properly installed
! Corrosion and solids accumulation are not interfering with the operation of the flow
measurement device
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Section 7 Wastewater Treatment Plant Assessments
! The flow measurement system measures the entire wastewater discharge, is
installed at an appropriate site, and meets all permit requirements
! Flow measurement devices are properly calibrated at an appropriate frequency
! Calculations made using primary measurements are correct and accurate
The inspector also should review historical records for evidence of continuous flow
measurement, evaluate the mill's data handling and reporting (including quality control
procedures), and collect accurate flow data during the inspection to validate the mill's
monitoring data. There are no flow measurement issues unique to kraft pulp mill
wastewater treatment plants.
7.4.4 Sampling Evaluations
The elements of sampling evaluations undertaken as part of an NPDES compliance
inspection are presented in Section 5 (Sampling) of the NPDES Compliance Inspection
Manual. During a sampling evaluation the inspector should assess the mill's sampling
program to verify:
! That the program complies with the mill's permit and with 40 CFR Part 136
! Sample preservation and handling (including holding times prior to analysis)
conform to 40 CFR Part 136
! That the mill has reported accurate data in discharge monitoring reports
The inspector may also collect samples of mill effluent to verify compliance with daily
maximum effluent limitations. The NPDES Compliance Inspection Manual provides
extensive detail about proper sample collection techniques, sample identification methods,
sample preservation and holding time, transfer of custody and sample shipment, quality
control, and data handling and reporting. Sampling evaluation activities specific to kraft
mills are described below.
All kraft mills will have final effluent limits on the discharge of BOD5 and TSS, as
well as on pH. Bleached papergrade kraft mills will also have limits on the discharge of
AOX. Inspectors should verify that the mill follows the method-specified sampling
procedures, summarized in Figure 7-7 (see 40 CFR Part 136 for more detail). Note that
each mill is required to analyze for all pollutants specified in its permit and to follow any
permit-specified sampling procedures.
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does not alter any statutory or regulatory requirements. Page 7-22
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Wastewater Treatment Plant Assessments
Section 7
Figure 7-7
Sampling Procedures for BOD5, TSS, pH and AOX
Pollutant
BOD5
TSS
pH
AOX
Container
Plastic or glass
Plastic or glass
Plastic or glass
Amber glass bottle
with Teflon®-lined
lid
Preservation
Cool, 4°C
None
None, analyze
immediately
Na2S2O3 to remove
free chlorine, HNO3
topH2-3, Cool4°C
Maximum
Holding
Time
48hrs
7 days
Continuously
monitor or analyze
immediately
6 months*
* Sample must be analyzed no less than 3 days after collection.
7.4.5 Laboratory/QA Evaluations
The elements of laboratory and QA evaluations undertaken as part of an NPDES
compliance inspection are presented in Section 7 (Laboratory Procedures and Quality
Assurance) of the NPDES Compliance Inspection Manual. For laboratories operated by
the mill, the inspector should evaluate:
! Facilities and equipment
! Precision and accuracy
! Data handling and reporting
! Personnel qualifications and training
Laboratory performance is also evaluated by the DMR QA program, in which participating
laboratories analyze performance evaluation samples containing constituents normally
found in industrial and municipal wastewaters.
At kraft mills, on-site analyses for BOD5 and TSS are common due to the short
holding time allowed prior to analysis. In contrast, many mills will contract laboratories to
perform AOX analysis because of its long holding time and because it requires complex
procedures and equipment.
Whether the analyses are performed on site or at contract laboratories, all
pollutants must be analyzed using the analytical method specified in 40 CFR Part 136.
Note that the analytical methods for AOX, TCDD, TCDF, and chlorine phenolics were
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Wastewater Treatment Plant Assessments
recently promulgated and will appear in a future revision to 40 CFR Part 136. Figure 7-8
lists the analytical methods that must be used for each pollutant sampled at the wastewater
treatment plant. The methods for pollutants sampled at a bleach plant effluent location are
listed in Section 6 (Figure 6-14).
Figure 7-8
Analytical Methods
Pollutant
AOX
BOD5
TSS
pH
Method
1650
405.1
160.2
150.1
7.4.6 Special Considerations for Kraft Pulp Mill Wastewater Treatment
Plants
Inspectors should be aware of three potential special considerations for kraft mill
wastewater treatment plants:
! Non-continuous discharge of wastewater
! Co-treatment of municipal wastewater
! Foam restrictions of treated wastewater
Non-continuous dischargers. A mill is a non-continuous discharger if, for reasons
other than treatment plant upset control (e.g.. to protect receiving water quality), the mill is
prohibited by the NPDES authority from discharging pollutants during specific periods of
time or is required to release its discharge on a variable flow or pollutant loading rate basis.
However, one-day maximum limitations and thirty-day average limitations were developed
for continuous dischargers. Because non-continuous dischargers release higher flows than
continuous dischargers during their limited discharge periods, they will release greater daily
pollutant loads than continuous dischargers. These high daily pollutant loads, however,
may not reflect the pollutant control actually achieved by non-continuous dischargers on an
annual basis. To allow for such circumstances, EPA established annual average discharge
limitations for non-continuous dischargers.
Regulations promulgated prior to the Cluster Rules that are still in effect require
that the NPDES authority establish alternative maximum day and average of thirty
consecutive days effluent limitations for non-continuous dischargers, in addition to
applying the mass-based annual average limitations. These alternative daily and monthly
limitations must be concentrations that reflect the performance of BPT, BCT, or NSPS
wastewater treatment, as appropriate. See 40 CFR 430.01(k)(l).
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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In the new effluent limitations guidelines promulgated by EPA as part of the Cluster
Rules, EPA did not require the NPDES authority to include maximum one-day and thirty-
day average concentration limitations for non-continuous dischargers. Instead, EPA will
defer to the NPDES authority to establish maximum day and maximum thirty-day average
limitations that are necessary to protect receiving water quality.
Figure 7-9 shows a summary of permit specifications for bleached and unbleached
kraft mills. Inspectors should review mill permits to determine whether the limits specified
are accurate.
Figure 7-9
Summary of Permit Specifications for Non-Continuous Dischargers
Limitations Required for Non-continuous Dischargers
Applicable Limitations
Annual average
One-day maximum concentration,
reflective of BPT or NSPS
30-day average concentration,
reflective of BPT or NSPS
Bleached Papergrade Kraft
and Soda (Subpart B)
/
If determined by permitting authority
to be necessary to protect receiving
water quality
If determined by permitting authority
to be necessary to protect receiving
water quality
Unbleached Kraft (Subpart C)
/
/
/
Co-treatment of municipal wastewater. Some mills operate wastewater
treatment plants that receive and treat municipal waste. These mills operate wastewater
treatment plants with sufficient capacity to accommodate the municipal wastewater from
surrounding communities. Mills that treat municipal wastewater may chlorinate this stream
before it is mixed with pulp mill wastewater. These mills may be subject to standards and
monitoring requirements typical of sanitary wastewater treatment plants, especially those
for total and fecal coliform. Inspectors should review monitoring records to determine
whether these mills are in compliance with permit limits.
Foam restrictions. Treated wastewaters from some mills experience excessive
foaming. Although foam is not regulated nationally, some state or regional authorities may
require mills to control wastewater foam for aesthetic purposes. Inspectors should review
any permit requirements and verify whether mills meet the applicable requirements.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Section 7 Wastewater Treatment Plant Assessments
7.4.7 Storm Water Inspection Considerations
To evaluate compliance with storm water permit requirements, the inspector
should:
! Conduct a records review to assure that the SWPP plan is up-to-date and includes
all required elements, and to assure that the mill has performed all of the required
self-monitoring and self-inspection procedures
! Review required monitoring and inspection data — if the data indicate potential
problems with storm water contamination, determine what, if any, corrective
actions were taken by the mill in response to the data
! Observe control and prevention measures to evaluate whether good operation and
maintenance practices are being used
The inspector should review Section 9 for further discussion of these basic storm water
inspection steps. The inspector should also consider the following procedures to evaluate
compliance with potential storm water contamination problems specifically relevant to
wastewater treatment plant operations:
! Review the SWPP plan to document that runon/runoff from the wastewater
treatment plant area is addressed
! Evaluate the quarterly visual inspection records to determine if any concerns are
noted — if so, document that appropriate corrective actions were taken
! Determine what BMPs are used to eliminate/reduce discharges from wastewater
treatment plant areas
! Visually observe BMP implementation to check for excessive wear or damage to
containment mechanisms and for evidence of poor material handling (evidence of
spills, leaks, uncovered raw materials, etc.)
7.5 RCRA Issues
Kraft mills do not generate significant quantities of hazardous wastes. As part of a
consent decree, EPA considered making a determination of whether it was appropriate to
list bleached kraft mill wastewater treatment sludges as hazardous wastes because
wastewater treatment sludge generated at bleached papergrade kraft mills may contain
dioxin and furan if these pollutants contaminate wastewaters at these mills. Because the
Cluster Rules effluent limitations guidelines and standards are based on bleaching
technologies that substantially reduce the use of chlorine-containing compounds, EPA has
determined that the dioxin and furan content of wastewater treatment sludges will also be
substantially reduced, and no listing determination is required.5 If the sludges at a
particular mill exhibit a hazardous waste characteristic, the sludges would be hazardous
wastes even without an EPA listing determination.
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7.6 EPCRA Issues and Inspection Considerations
NOTE! See Appendix D for detailed
overview of EPCRA regulations and basic
assessment procedures.
General concerns. The
basic regulatory requirements for
EPCRA are not process-specific but
rather apply on a facility-wide basis.
Thus the basic requirements of
EPCRA are discussed in Appendix
D. For wastewater treatment plant operations, the key EPCRA issues will be to quantify
air, water and land releases in the annual Toxic Release Inventory (TRI) report (known as
the "Form R" report). In addition, wastewater treatment plant upsets could result in water
discharges that exceed applicable reportable quantities that would require emergency
notification under EPCRA and parallel provisions of CERCLA.
Inspection considerations. Generally, the EPCRA compliance assessment will
focus initially on a records review. The inspector should review the following materials:
! Emergency preparedness information. These obligations are not process-specific,
and thus the basic assessment considerations are covered for all facility operations
in Appendix D to this manual.
! TRI Form R. Check to ensure that the form is on file and that the mill has
adequately considered releases associated with the wastewater treatment plant
operations, including but not limited to, the water discharges and air releases of
volatile compounds such as methanol. Also, ask to see the estimation technique
being used. If the estimation technique involves an assumed reduction efficiency
for control methods, make sure that the assumed efficiency is consistent with the
overall efficiency that the mill is achieving. The overall assumed efficiency should
account for any excess releases that occur as a result of treatment upsets in a
manner consistent with the actual percent of operating time such releases occur.
Uncontrolled discharge episodes or periods of reduced control efficiency can have a
significant impact on the estimate of total releases.
! Emergency notifications. Request documentation that the mill has filed all required
notices.
If a water inspector plans to screen for EPCRA compliance, the inspector should
confirm the necessary information with the facility contact during the opening conference
or just in advance of the closing conference. For an announced inspection, the inspector
should ask the source to have ready EPCRA-related documentation so that this screening
check can be performed without interrupting the main focus of the inspection. A screening
checklist is included as part of the example assessment form in Appendix E.
In addition to a screening-type records review inspection, an EPCRA inspector may
want to conduct further assessments to identify potential compliance concerns with
emergency notification requirements. As one technique, the inspector first can check
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 7-27
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Section 7 Wastewater Treatment Plant Assessments
wastewater treatment plant upset reports and citizen complaints since the previous
inspection. The inspector then should cross-check those incidents with notification records
identified in EPA's ERNS database, records on file with state/local emergency officials, or
records requested from the mill. If this type of investigation identifies episodes of
abnormal discharges in which no notification was provided, the inspector should consider a
follow-up investigation to determine if reportable quantity thresholds were exceeded.
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Wastewater Treatment Plant Assessments Section 7
References:
1. Proposed Technical Development Document for the Pulp, Paper and Paperboard
Category and Effluent Limitations Guidelines, Pretreatment Standards, and New
Source Performance Standards. U.S. Environmental Protection Agency,
Washington, D.C., October 1993.
2. Supplemental Technical Development Document for Effluent Limitations
Guidelines and Standards for the Pulp, Paper, and Paperboard Category Subpart
B (Bleached Paper grade Kraft and Soda) andSubpart E (Papergrade Sulfite),
U.S. Environmental Protection Agency, Document Control Number 14487,
October 15, 1997.
3. Data Available for Limitations Development for Toxics and Nonconventional
Pollutants, U.S. Environmental Protection Agency, November 12, 1997.
4. Final Analysis of Data Available for Development of COD Limitations, Eastern
Research Group, prepared for U.S. Environmental Protection Agency, August, 25,
1997.
5. U.S. Environmental Protection Agency, Letter of December 12, 1997, to K. Florini
(Environmental Defense Fund) and D. Lenett re Pulp and Paper Mill Sludge under
EOF v. Browner. Civ. No. 89-0598 (D.D.C.)
6. Memorandum of Understanding between the American Forest & Paper Association
and the U.S. Environmental Protection Agency, Regarding the Implementation of
Land Application Agreements Among AF&PA Member Pulp and Paper Mills and
the U.S. Environmental Protection Agency (executed April 14, 1994).
This manual is intended solely for guidance and May 1999
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Section 7 Wastewater Treatment Plant Assessments
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SECTION 8: ASSESSMENT MODULE FOR POWER
BOILER OPERATIONS
8.1 Introduction
This section addresses the
power boilers commonly used at
kraft pulp mills. The regulations that
will apply are not unique to kraft
pulp mills and affect power boilers
used in various manufacturing
processes. Thus, this section
generally provides only an
abbreviated overview of this process
area, the regulatory requirements
that apply, and recommended
assessment procedures. Where
appropriate, specific issues relevant
to kraft mills are discussed. In addition, Appendix E contains an example assessment form
specifically designed to address the issues raised in this process area.
8.1
8.2
8.3
8.4
8.5
8.6
CONTENTS
Introduction
Overview of Process and Discharges
Air Issues and Inspection Techniques
Water Issues and Inspection
Considerations
RCRA Issues and Inspection
Considerations
EPCRA Issues and Inspection
Considerations
8.2 Overview of Process and Discharges
8.2.1 Description of the Process
Energy generation to meet electric and steam needs at kraft pulp mills is provided in
part by the recovery boiler; industry information indicates that approximately 40 percent of
on-site power needs typically will be met by recovery boiler operations. The remaining
generation needs are made up of power boilers burning various fuels. Increasingly, mills
are relying on waste wood, wood chips and bark (so-called "hogged fuel"), as well as other
materials such as tire-derived fuel, as fuel sources. For wood-fired boilers, a traveling-
grate type boiler, where hogged fuel is mass-fed onto a traveling grate, would be a typical
boiler type.1'2 However, coal, fuel oil and natural gas all remain significant fuel types for
on-site power boilers. For coal-fired boilers, either spreader stoker or pulverized coal
boilers may be used at some mills, and both types of boilers are addressed in this section.
8.2.2 Air Pollutant Emissions
The major emissions of regulatory concern from power boilers are particulate
matter, SO2 and NOX. The quantity of each pollutant produced is a function of the fuel
characteristics, the firing method, and the combustion characteristics for each boiler. In
general, kraft mill power boilers currently do not use add-on control equipment for the
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Power Boiler Assessments Section 8
control of SO2 or NOX. Most mills will limit the sulfur in the fuel they burn to meet state
sulfur-in-fuel limits, and more modern boilers may have some form of low NOX burner or
other combustion control design features that act to limit NOX emissions. Generally, only
coal- and hogged fuel/bark-fired boilers use particulate matter add-on control devices.
Multicyclones, scrubbers, ESPs, and fabric filters are the most commonly used devices for
the control of particulate emissions from coal-fired boilers. Particulate emissions from
hogged fue^ark-fired boilers are generally controlled by mechanical collectors, scrubbers
and, more recently, ESPs. Section 8.3 provides an overview of the regulations that apply
to these emissions and basic inspection techniques for power boiler air emissions.
8.2.3 Water Pollutant Discharges
In 1989, 5 to 15 percent of the flow discharged to the wastewater treatment plant
originated in power operations at kraft mills.4 This wastewater may include non-contact
cooling water, air pollution control blowdown (e.g.. scrubber blowdown), and boiler
blowdown. Boiler blowdown water may contain small amounts of materials such as:
! Soluble inorganic salts (chlorides, sulfates)
! Precipitated solids containing calcium and magnesium salts
! Corrosion products (both soluble and insoluble)
In addition, the wastewater may contain parts per million concentrations (mg/liter)
of conditioning chemicals, such as inorganic phosphates, sodium hydroxide, and
ethylenediamine tetraacetic acid (EDTA) (a chelating agent). Sodium sulfite or hydrazine
may be added to control corrosive gases, most commonly dissolved oxygen and carbon
dioxide. Ammonia, morpholine, or cyclohexane may be added to adjust pH. In addition,
various starches and other organic materials may be added to retard solids deposition.5
These water discharges from the power boilers are sent to the wastewater treatment plant
for treatment prior to discharge. See Section 7 for a discussion of regulatory and
inspection issues for the wastewater treatment plant.
In addition, storm water associated with power boiler operations and potential
releases of oil to receiving waters (if applicable based on the types of boilers used at a mill)
are two areas that are subject to regulation and may involve compliance issues at some
mills. Section 8.4 provides an overview of the CWA requirements that may apply for both
storm water and oil handling.
8.2.4 Solid/Hazardous Waste Discharges
Bottom and fly ash are the primary solid wastes generated by power boiler
operations. This material is usually landfilled, although ash in some situations may be
either reused as an additive for various products or spread over agricultural or forest lands.
Section 8.5 briefly discusses RCRA issues and inspection procedures for the power boiler
process area.
This manual is intended solely for guidance and May 1999
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Section 8
Power Boiler Assessments
8.2.5 EPCRA Chemicals and Reportable Releases
Facilities will have to provide information on chemicals used in the power boiler
area to meet EPCRA's emergency preparedness requirements. Appendix D contains a
process-based list of the types of hazardous chemicals that may be included in an EPCRA
inventory for a kraft pulp mill. On-site air, water and land releases, including land
disposals, of toxic chemicals from the power boiler area and off-site transfers of waste
containing these toxic chemicals may have to be accounted for in TRI Form R reports.
TRI toxic chemicals may be found in fly and bottom ash — especially for coal or oil-fired
boilers. In addition, EPCRA/CERCLA emergency release reporting could apply for off-
site releases that are not federally permitted and that exceed a certain reportable quantity
(RQ). A primary example of this type of release from power boiler operations would
involve air emissions of SO2 or NO2 that are not federally permitted releases and exceed
the applicable daily RQ (500 pounds for SO2 and 10 pounds for NO2). These EPCRA
issues are discussed in Section 8.6.
8.3 Air Issues and Inspection Techniques
8.3.1 Air Regulations
Basic emission limits. Fossil
fuel-fired combustion sources are
perhaps one of the most heavily
regulated source categories for air
pollution. For federal standards,
NSPS subparts D, Db and DC could
all potentially apply to power boilers
at a kraft pulp mill. In addition,
some plants potentially could use gas
fired turbines that could be subject to
NSPS subpart GG. Figures 8-1
through 8-7 summarize these NSPS
subparts.
Special NSPS Considerations for
Wood-fired Boilers
Subject to Subpart D only if also
combust fossil fuels — if so, subject to
PM, SO2 and NOX limits
Subject to Subpart Db and DC PM
limits
Under Subpart Db and DC, subtract
out wood fuel usage in determining
compliance with SO2 limits for fossil
fuels
Under Subpart Db, subject to NOX
limit only if also combust fossil fuels
State SIP regulations also
generally will include standards for at
least paniculate matter and SO2 from
pre-NSPS combustion sources. Although these limits may be expressed similarly to the
NSPS (such as grains per dry standard cubic foot (gr/dscf) or Ib/mmBtu for particulate
matter, or Ib/mmBtu for SO2), many States will express particulate matter limits in the form
of process weight regulations and SO2 limits as sulfur-in-fuel limits. Recent requirements
designed to limit NOX emissions as part of ozone attainment strategies may also apply to
the mill's power boilers. Because States have a number of regulations that may apply, this
summary does not address these regulations in any further detail.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Power Boiler Assessments
Section 8
Figure 8-1
Particulate Matter, Sulfur Dioxide and Nitrogen Oxides Requirements
for Fossil Fuel Fired Steam Generators (NSPS Subpart D)
Regulatory Area
Applicability
Emission
Standard/
Avg. Time*
Monitoring
System/
Procedure
Exceedance
Level
Reporting and
Recordkeeping
Requirements
Fossil fuel and fossil fuel/wood residue-fired steam generating units for which
construction or modification is commenced after August 17, 1 971 , and that have a heat
input capacity >73 MW (250 mmBtu/hr). Fossil fuel use must be > 10 percent.
! PM:
- 0.10 lb/mmBtu/3-hr. avg.
20% opacity, except for one 6-min. period per hr. of 27% opacity /6-min. avg.
! SO2: 0.80-1 .2 Ib/mmBtu depending on fuel fired/3-hr. avg.
! NOX: 0.20-0.80 Ib/mmBtu depending on fuel fired/3-hr. avg.
! Note: SO2 standard inapplicable to gaseous fossil fuel-fired units
! PM: Opacity CEMS, except not required if only gaseous fossil fuel burned
! SO2: CEMS, except not required if only gaseous fossil fuel burned or if no
control device used and SO2 monitored by fuel sampling and analysis
! NOX: CEMS, except if test shows emissions <70% of emission limit
! Opacity CEMS: Any 6-min. period of avg. opacity > opacity limit
! CEMS: Any 3-hr, period of avg. SO2 or NOX emissions > emission limit
! Quarterly excess emission reports (EERs); semiannual reporting if history of no
exceedances
! Other general NSPS reporting and recordkeeping requirements apply
Figure 8-2
Particulate Matter Requirements for Industrial-Commercial-
Institutional Steam Generating Units (NSPS Subpart Db)
Regulatory Area
Requirements
Applicability
Steam generating units for which construction, modification, or reconstruction is
commenced after June 19,1984, with a heat input capacity >29 MW (100
mmBtu/hr), except for certain new/modified oil-fired units prior to June 19, 1986,
and units meeting Subpart Da requirements:
Emission
Standard/
Avg. Time*
If use coal, oil, wood, or municipal-type solid waste (alone or in combination with
other fuels), PM less than 0.05 Ib/mmBtu to 0.20 Ib/mmBtu heat input, depending
on fuel type/6-hr. avg.
If use coal, oil, or wood (alone or in combination with any other fuels), 20%
opacity, except for one 6-min. period per hr. of 27% opacity/6-min. avg.
Monitoring
System/
Procedure
Exceedance
Level
! Opacity CEMS (if subject to opacity standard)
Any 6-min. period in which opacity > opacity standard
Reporting and
Recordkeeping
! Opacity EER's quarterly, with semiannual report if no exceedances
! Records of amounts of each fuel combusted, with recorded calculation of annual
capacity factors maintained on a quarterly basis
! Other general NSPS requirements apply
Averaging time based on minimum sampling time of performance test if not stated explicitly in standard.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Section 8
Power Boiler Assessments
Figure 8-3
Sulfur Dioxide Requirements for Industrial-Commercial-
Institutional Steam Generating Units (NSPS Subpart Db)
Regulatory Area
Requirements
Applicability
Steam generating units for which construction, modification, or reconstruction is
commenced after June 19, 1984, and that have a heat input capacity >29 MW (100
mmBtu/hr), except for:
- Certain coal and oil-fired affected units for which construction, modification, or
reconstruction is commenced on or before June 19, 1986
- Units also meeting the applicability requirements under Subpart J
- Units also meeting the applicability requirements under Subpart E
- Steam generating units meeting the applicability requirements under Subpart Da
Emission
Standard/
Avg. Time
! Various standards expressed in Ib of SO2/mmBtu heat input, depending on fuel
type/30-day rolling avg. with limited exception for certain units burning only very
low sulfur oil
! Various percent reduction requirements, depending on fuel type/30-day rolling
average
! Percent reduction not applicable to facilities:
- With annual capacity factor for coal and oil <30%
- In noncontinental areas
- Using a duct burner where >70% heat input from exhaust gases entering the
duct burner
- Burning very low sulfur oil
Monitoring
System/
Procedure
Exceedance
Level
Inlet/outlet SO2 CEMS with diluent (used as performance test method), subject to
following alternatives:
- For inlet CEMS, fuel sampling and analysis in "as fired" condition using
Reference Method (RM) 19
- For inlet or outlet CEMS, daily RM 6B testing
- If burning only very low sulfur oil, may use fuel supplier certification instead of
any CEMS
Any 30-day rolling avg. in which SO2 is > applicable standard(s)
Reporting and
Recordkeeping
Quarterly reports of emissions and monitor performance data, and capacity factors
for fuels used
If fuel pretreatment used, signed statement with quarterly report indicating removal
efficiency achieved and documenting proper procedures
If demonstrating compliance for units using only very low sulfur oil by obtaining
fuel supplier certifications, quarterly certification that only such fuel was used
Records of amounts of each fuel combusted, with recorded calculation of annual
capacity factors maintained on a quarterly basis
Other general NSPS requirements apply
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Power Boiler Assessments
Section 8
Figure 8-4
Nitrogen Oxides Requirements for Industrial-Commercial-
Institutional Steam Generating Units (NSPS Subpart Db)
Regulatory Area
Requirements
Applicability
Steam generating units for which construction, modification, or reconstruction is
commenced after June 19, 1984, and that have a heat input capacity >29 MW (100
mmBtu/hr), except for steam generating units subject to the applicability
requirements under Subpart Da
Emission
Standard/
Avg. Time
Various NO,, (expressed as NO2) emission limits expressed in Ib/mmBtu heat input,
depending on fuel type/30-day rolling avg.
24-hr, avg. (initial performance test), 3-hr. avg. (other performance tests) for units
with federally-enforceable low capacity factors and low nitrogen fuels
Exemption from NOX emission standard: Units with heat input capacity <73 MW
(250 mmBtu/hr) and federally-enforceable low capacity factors/low nitrogen fuels
Monitoring
System/
Procedure
Exceedance
Level
NO,, CEMS (used as performance test method), except not required for:
- Duct burners used in a combined cycle system (use RM 20)
- Low capacity factor/low nitrogen fuel facilities that are either subject to the 24-
hr./3-hr. emission standards or are exempt from the NOX emission standards (use
RM 7 or RM 7 alternates)
Facilities using low nitrogen fuels, but with capacity factors >10%, can use NOX
CEMS or EPA-approved predictive approach (used as performance test method for
initial and "upon request" 30-day tests only)
Any 30-day rolling avg. in which NO,, CEMS data (or calculated NO,, rate from
operating conditions) > applicable emission standard
Reporting and
Recordkeeping
For facilities subject to continuous NO,, monitoring requirements, quarterly reports
on emissions/monitor performance data; semiannual reporting if no exceedances in
limited circumstances
For facilities with federally-enforceable low capacity factors (<10%) and low
nitrogen fuels, quarterly reports on: annual capacity factor, average fuel nitrogen
content if residual oil fired, and, if applicable, performance test results, hours of
operation, and number of hours since last performance test
Plan for monitoring operating conditions, if applicable
Records of amounts of each fuel combusted, with recorded calculation of annual
capacity factors maintained on a quarterly basis
For residual-oil fired facilities that have federally-enforceable low capacity factors
(< 10%) and low nitrogen fuels, or that have heat input capacity <73 MW and use
low nitrogen fuel: records of nitrogen content of residual oil combusted, with
calculated quarterly average
For facilities with federally-enforceable low capacity factors (<10%) and low
nitrogen fuels, record for each operating day: calendar date, hours of operation,
and hourly steam load
Other general NSPS requirements apply
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Section 8
Power Boiler Assessments
Figure 8-5
Particulate Matter Requirements for Small Industrial-Commercial-
Institutional Steam Generating Units (NSPS Subpart DC)
Regulatory Area
Requirements
Applicability
Steam generating units for which construction, modification, or reconstruction is
commenced after June 9, 1989, and that has a maximum design heat input
capacity of >2.9 MW (10 mmBtu/hr) but <29 MW (100 mmBtu/hr)
Emission
Standard/
Avg. Time
PM less than various levels of Ib/mmBtu heat input for facilities with heat input
capacity >8.7 MW, and combusting coal or wood (either alone or in combination
with other fuels)/6-hr. avg.
20% opacity for facilities with heat input capacity >8.7 MW and combusting coal,
wood or oil, with allowance for one 6-min. period per hr. of up to 27% opacity 16-
min. avg.
Monitoring
System/
Procedure
Exceedance
Level
! Opacity CEMS if combust coal, wood or residual oil either alone or in combination
with other fuels
! Any 6-min. period in which opacity > opacity standard
Reporting and
Recordkeeping
! Quarterly EERs, except semiannual report if no excess emissions
! All performance test data
! Amounts of each fuel combusted during each day
! Other general NSPS requirements apply
* Averaging time based on minimum sampling time of performance test if not stated explicitly in standard.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Power Boiler Assessments
Section 8
Figure 8-6
Sulfur Dioxide Requirements for Small Industrial-Commercial-
Institutional Steam Generating Units (NSPS Subpart DC)
Regulatory Area
Requirements
Applicability
Steam generating units for which construction, modification, or reconstruction is
commenced after June 9, 1989, and that have a maximum design heat input capacity
>2.9 MW (10 mmBtu/hr) but <29 MW (100 mmBtu/hr)
Emission
Standard/
Avg. Time
General SO2 standard is both:
- Various levels of Ib/mmBtu heat input, depending on fuel type/3 0-day rolling
avg., unless supplier certification applicable
- Various levels of % reduction, depending on fuel type/30-day rolling avg., unless
supplier certification applicable
% reduction standards do not apply to certain facilities fired with coal (alone or in
combination with other fuels) that meet specified criteria
For oil-fired facilities, unless fuel supplier certification applies, standard is either:
- 0.50 lb/mmBtu/30-day rolling avg.
- 0.5 weight % sulfur in fuel/30-day rolling avg.
Monitoring
System/
Procedure
Exceedance
Level
Monitoring procedures used as compliance determination method in all cases
Inlet/outlet SO2/diluent CEMS, except outlet only if no % reduction applies
Daily as-fired fuel sampling and analysis (FSA) or Reference Method (RM) 6B are
alternatives to SO2 CEMS in specified situations
For FSA of oil, measurements on tank filling basis — not daily — allowed
Fuel supplier certifications of sulfur content alternative to CEMS for:
- Distillate oil-fired affected facilities
- Residual oil/coal-fired facilities with heat input capacities between 2.9 and 8.7
MW
Any 30-day rolling avg. in which data shows failure to achieve compliance
Reporting and
Recordkeeping
Quarterly reports of all emissions/monitor performance data, except semiannual
reporting if maintain a history of no exceedances
For fuel supplier certifications, quarterly report includes:
- Certification that records submitted account for all fuel combusted
- All certification records
All performance test data
Maintain records of amounts of each fuel combusted during each day, and fuel
supplier certification that include, for residual oil or coal, name of supplier,
sampling location, sampling method, and sulfur analysis results; for distillate oil,
certification includes only the name of the supplier and a statement that the oil
supplied meets distillate oil specifications
Other general NSPS requirements apply
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Section 8
Power Boiler Assessments
Figure 8-7
Sulfur Dioxide and Nitrogen Oxides Requirements for Gas-fired Turbines
(NSPS Subpart GG)
Regulatory Area
Requirements
Emissions
Unit(s)
Stationary gas turbine units for which construction, modification, or reconstruction
commenced after October 3, 1977, and that has a heat input at peak load > 10
mmBtu/hr, based on lower heating value of fuel fired
Emission
Standard/
Avg. Time
SO2: Either achieve a limit of < 0.015% by volume at 15% O2 (dry basis), or use
fuel with < 0.8% sulfur by weight
NO,,: Achieve a limit established by equations included in the standard, expressed
on a % by volume basis at 15% O2 (dry basis) [see § 60.332(a)-(l) for actual values
and exceptions]
Monitoring
System/
Procedure
Exceedance
Level
! SO2: Monitor sulfur content of fuel fired (used for direct compliance with % sulfur
standard)
! NO,,: Continuous monitoring of fuel consumption and ratio of water to fuel being
fired for units using water injection, and monitor nitrogen content of fuel being fired
! Daily period in which sulfur content of fuel fired >0.8%
! Any 1-hr period in which avg. water-to-fuel ratio data < baseline
! Any period in which nitrogen content > allowance used in baseline performance test
Reporting and
Recordkeeping
i
For NOX, semiannual EER (for parameter exceedances) that also include avg. water-
to-fuel ratio, avg. fuel consumption, ambient conditions, gas turbine load, and
nitrogen content of fuel during exceedance periods, plus graphs or figures developed
during performance test
Other general NSPS provisions apply
Asbestos NESHAP. In addition to the basic emission limits applicable to the
power boilers, a number of mills may have asbestos-containing material (ACM) used to
insulate steam pipes or used for similar purposes in the power boiler process area. Any
demolition or renovation activity that involves removing or disturbing asbestos-containing
material may be subject to the requirements in 40 CFR Part 61, Subpart M. Generally,
Subpart M requires prior notice of demolition/renovation activity that will disturb a certain
amount of asbestos and requires compliance with a number of work practice and waste
disposal requirements. Figure 8-8 provides a brief overview of these requirements.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Power Boiler Assessments
Section 8
Figure 8-8
Asbestos Demolition and Renovation (D&R) Requirements
(NESHAP 40 CFR Part 61, Subpart M)
Regulatory Area
Requirements
Applicability
Covers regulated ACM (RACM) only: friable asbestos, certain "Category I"
nonfriable material with >1% asbestos that has become friable, or other "Category
II" nonfriable material with >1% asbestos that likely will be crumbled/pulverized or
be reduced to powder as a result of the D&R activity [see 40 CFR 61.141 for all
definitions]
For pipes, the D&R activity must affect > 80 linear meters (260 linear feet)
For other facility components, the threshold is > 15 square meters (160 square feet)
For planned renovations, consider all planned activities for the calendar year in
determining total amount of RACM that will be disturbed
A number of exceptions and alternatives also apply [see 40 CFR 61.145(a)]
Notice
Requirements
General rule is written notice > 10 working days prior to the removal activity begins
(i.e., any activity that could disturb the RACM), or at least 10 days before end of the
calendar year preceding the year in which applicable planned renovation activity
occurs
Follow-up notice required if the amount of asbestos affected changes by >20%, or if
start date of work changes
Exceptions apply for emergency D&R activities
Regulations prescribe elements that must be included in the notice and require use
of form included in Subpart M (or a similar form)
Work Practices
General rule is to remove RACM prior to any activity that could break up/disturb
the RACM or preclude access for subsequent removal
Wetting requirements apply in numerous stripping and other situations, although
use of ventilation system to a glove bag and leak tight wrapping with no visible
emissions is alternative for stripping procedures, and leak tight wrapping is
alternative to wetting after removal. Other wetting exceptions apply
Careful handling procedures to preclude disturbing the RACM apply
Other specific requirements apply
Waste Disposal
Additional work practice standards apply for handling RACM
Must deposit the RACM at a landfill that meets specific Subpart M requirements
A RCRA-type manifest system must be used by the facility, with follow-up reporting
required if the generating facility does not receive a receipt from the disposal facility
within 45 days
Other specific requirements apply
8.3.2 Inspection Techniques
8.3.2.1 Pre-inspection Steps
As discussed in Section 3, there are a number of steps that should be routinely
taken prior to conducting an actual on-site inspection, including file review. As part of the
file review, the inspection should consider at least the following items:
Permit verification. One objective of a standard Level 2 air inspection will be to
verify that the operating permit includes all of the appropriate requirements. Prior to the
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Section 8 Power Boiler Assessments
inspection, the permit should be reviewed to determine what conditions apply to the
facility's power boilers. This permit review is particularly critical in the case of power
boilers because the federal and State regulatory requirements are so varied. In reviewing a
facility's permit, the inspector should consider the following questions:
What fuels are permitted to be burned in the power boiler(s)?
If special fuels/wastes may be burned, are they subject to any limits, constraints, or
reporting/recordkeeping requirements?
Are there any specific maintenance or testing requirements, such as annual testing
or semiannual boiler or control device maintenance?
Do NSPS requirements apply?
What types of modifications have occurred, and were NSR requirements met?
Has debottlenecking occurred in the main mill process areas, and thereby increased
utilization of the power boilers? If so, were potential NSR applicability issues
addressed?
NOTE! Check Title V permit materials
for process diagrams/layouts.
Process diagrams/layouts.
Obtain a simplified diagram of the
mill's power boilers and note what
control(s) are employed. This type
of diagram may be available in the
Part 70 operating permits file if submitted with the application. Use this information to:
! Determine where the power boiler(s) are located in order to perform a quick initial
evaluation of stack opacity upon arrival.
! Understand how the control room(s) for the boiler operations are set up, what
process and control parameters can be evaluated from the control rooms, and what
distributed control system (DCS) data capabilities are on-site. Especially for larger
boilers, a significant portion of the on-site inspection for the power boilers will
occur in the control room(s), and an up-front understanding of what data are
available, both real-time data and historical data from a DCS, can streamline the on-
site phase of the investigation.
Evaluation of periodic monitoring reports. Review any monitoring reports that
have been submitted since the last inspection in order to prioritize the need for follow-up
while on-site. As noted in Figures 8-1 through 8-7, the NSPS subparts for boilers and
turbines require excess emissions reports (EER) for continuous emission monitoring
system (CEMS) data in a number of instances. In addition, as mills obtain operating
permits under Part 70 programs, the permit conditions that implement Part 64 compliance
assurance monitoring (CAM) or Part 70 periodic monitoring will likely require parameter
monitoring for particulate matter control devices in those cases where the NSPS or
comparable State monitoring requirements do not apply. In those cases, the semiannual
Part 70 reports will include data on any parameter excursions that have occurred.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page 8-11
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Power Boiler Assessments Section 8
The inspector should confirm that any periods of excess emissions/parameter
excursions indicated in the reports are within regulatory limits. If not, the inspector may
need to evaluate on-site records that document the reasons for the excess emissions. The
review will be necessary to evaluate claims of allowable excursions, such as those from
startup, shutdown, or malfunction periods.
Evaluation of episodic malfunction reports. Review malfunction reports
submitted since the last inspection, if available. If the reports identify corrective actions to
be taken by the facility, the inspector should note the need to verify during the on-site
inspection that the corrective steps were actually taken and that they resolved the problem.
If a malfunction report is required for all or some specified subset(s) of
malfunctions, the inspector also should note any discrepancies between the periods covered
by the malfunction reports submitted and the claimed reasons for excess emissions included
an EER (if required). Significant discrepancies signify errors in monitoring or malfunction
reporting that should be addressed with the facility either as part of the inspection or by
agency compliance staff responsible for processing periodic and episodic reports.
8.3.2.2 On-site Inspection Steps
The on-site inspection for power boilers should include direct compliance
determinations where practicable (such as confirming compliance with sulfur-in-fuel limits
or conducting RM 9 visible emission observations for opacity standards). In other cases,
the inspector will have to conduct indirect compliance assessments (such as to evaluate
compliance with particulate matter limits). In these cases, the inspector should use indirect
compliance indicators to evaluate whether operating conditions for a particular
boiler/control equipment combination are consistent with baseline values. The baseline
values may be established during a performance test or other pertinent data (such as design
standards). If the boiler is operating outside normal ranges, follow-up activities may be
warranted. The following subsections summarize specific areas that should be checked
during the inspection.
NOTE! Visible emission checks are
unnecessary for gas-fired boilers.
Visible emissions. Begin
with a visible emission observation
(VEO) using Method 9 or
comparable State procedures. If
weather and site conditions permit,
the inspector should check for visible emissions before entering the facility. Generally, a 12
to 30 minute VEO can account for a full ESP rapper operating cycle and allow the
inspector to determine if any cyclic patterns are present. Where ESPs or fabric filters are
used and further evaluation is warranted, the inspector should observe the stack plume
over a continuous period to identify any "puffing" (i.e. spiking) problems. A VEO should
not be necessary for boilers firing only natural gas, although a smoking natural gas boiler is
typically indicative of combustion problems.1
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Evaluation of proper operation of control equipment. Because coal and wood-
fired power boilers typically use control equipment for the abatement of particulate
emissions, a routine Level 2 inspection should include an evaluation of control equipment
operation and maintenance in addition to a VEO. The appropriate steps for this phase of
the inspection will vary depending upon the type of control device(s) being used. Possible
parti culate matter abatement systems at kraft mill power boilers include multicyclones,
scrubbers, ESPs, and fabric filters.
Multicyclones. Inspections of multicyclones are relatively limited due to restricted
equipment access and the limited number of key operating parameters to be evaluated.
Detailed checks for proper operation require internal access to the multicyclone. This
requires scheduling a visit during boiler outage with full consideration of all safety
restrictions that apply. Routine checks that are available include:
! Pressure drop across the device
! Proper hopper discharge
! Gas flow rates near nominal design rates
The initial VEO, although appropriate for determining compliance with any
required opacity limits, usually does not provide useful information about multicyclone
performance because the controls do not normally collect the smaller light scattering
particles. Because multicyclones only collect the larger sized particles, little or no
observable shift in opacity may be noted when performance has decreased. Note that for
units with multicyclone controls only, opacity CEMS data likely will not be available.
Pressure drops (in the normal pressure drop range) across a multicyclone are useful
only if extreme values are present. Although very low or very high pressure drops tend to
indicate that something is wrong inside the multicyclone and that maintenance is required,
small shifts in pressure drop have little meaning in evaluating performance.
NOTE! See Section 5 for detailed
overview of scrubber and ESP inspection
techniques.
Scrubbers. Because the
venturi scrubbers applied to power
boilers are nearly identical to those
applied to lime kilns, a detailed
discussion of the appropriate data
and operating parameters to be
evaluated in a Level 2 inspection can be found in Section 5.3.3.2. It should be noted,
however, that there is a difference in the operating pH of these two scrubbers. Lime kiln
scrubbers operate under alkaline conditions; whereas power boilers operate under acidic
conditions. As a result of the acidic conditions, the power boiler scrubber may be more
susceptible to corrosion problems.1
Electrostatic precipitators (ESPs). ESPs applied to power boilers and those
applied to recovery boilers are also quite similar, both with respect to layout and key
parameters that should be evaluated. A detailed discussion of the appropriate data and
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Power Boiler Assessments Section 8
operating parameters (including opacity CEMS data) to be evaluated in a Level 2
inspection can therefore be found in Section 5.3.3.2. It is important to note, however, that
power boiler and recovery boiler ESPs are not identical. A critical distinction between the
two precipitators is the increased possibility of resistivity problems that exists with power
boilers:1'2
! Low resistivity concerns are generally not expected, except on stoker-fired boilers
and boilers firing high-sulfur coal. Possible indicators of low resistivity include: (1)
reduced primary and secondary voltages; (2) significantly increased primary and
secondary voltages, especially in the inlet fields; (3) decreased spark rates,
especially in the inlet fields; or (4) all or most fields at either the primary current or
secondary current limits. In addition, low resistivity may be indicated by a VEO
and/or review of opacity CEMS data that indicates rapper reentrainment problems.
Where low resistivity is suspected, the inspector should look for changes in
temperature or fuel quality that could be responsible for the change in resistivity.
! High resistivities can significantly impair performance if an ESP is not designed to
handle the high values. As the ash becomes more difficult to remove from the
collector plates, power levels decrease and sparking increases throughout the ESP.
In severe cases, virtually no normally expected increase in power or current levels
occurs from inlet to outlet. Possible causes of increased resistivity include a change
in coal sulfur content, a change in other ash constituents, or a change in
temperature.
Fabric filters. There are a
number of variables that can be used
to qualitatively check baghouse
operations for symptoms of
operating and/or design problems.
Each of these checks provides some
indication of the typical problems
operations. Note that as sources
develop compliance assurance
monitoring approaches to satisfy 40
CFR Part 64, a mill's Part 70 emissions
Basic Fabric Filter Assessments
that can occur with fabric filter Compressed air pressure (pulse jet
VEO
Opacity CEMS data (if applicable)
Static pressure drop
Inlet and outlet gas temperatures
systems only)
Walkaround inspection for air
infiltration, corrosion and fugitive
operating permit should contain
specific fabric filter parameters to be
monitored. Those parameters should be the most appropriate to indicate proper
performance for the particular fabric filter application.
The key external inspection parameters and their relevance in evaluating the
operation and maintenance of filters are summarized in Figure 8-9.1>2
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Figure 8-9
Fabric Filters: External Level 2 Inspection Parameters1'2
Inspection Parameters
Relevance in Evaluating Filter O&M
Opacity/Visible Emissions
Unless condensable plume is present, average opacity should be low;
opacity levels >5-10% warrant follow-up inspection
Opacity should increase slightly after cleaning cycle
Significant increase in opacity may indicate pinhole leak in given
module of row of bags
Length of time required to restore opacity to previous levels indicates
severity of problem
Pressure Drop
Reverse air and pulse jet systems generally should operate at overall
static pressure drops <6 in. W.C.
Except for large holes and tears, pressure drop is not as sensitive as
opacity for detecting bag holes and tears
Increase in pressure drop (1-2 in. W.C. from baseline) may indicate
cleaning system problems, increase in gas flow through filter, or
increase in dust layer resistance to gas flow
Gradual increase in pressure drop usually indicates bag blinding caused
by deeper penetration of particulate into fabric weave
Low pressure drop may indicate air infiltration problems
For reverse air systems, reverse direction static pressure drop should be
<0.0 during cleaning
Inlet/Outlet Gas Temperatures
Temperatures should be maintained within moderate range, slightly
below the maximum temperature rating for the type of bag in use
Short term excursions > 25°F above rated temperature for bags being
used can cause bag damage
Low temperatures below acid vapor dewpoint can cause acid attack to
bags
Cleaning System (should be
checked when time between
cleaning cycles is too long)
Pulse-jet systems should fire with resounding thud, with compressed air
pressures normally of 60 to 90 psig, although site-specific baseline
values important because of difference in designs. Compressed air
gauges generally will be located only on the compressed air manifold
Reverse-air systems should isolate each filter compartment
Reverse-air and dwell cycles should be sequenced to allow flexing and
release of dust cake under gentle conditions
Hopper Discharge, Air
Infiltration, Corrosion,
Fugitive Emissions
Check for plugged or damaged hoppers, which can allow ash to build
up in bags and bags to be shut off from gas flow
Listen for an air rushing sound to detect for severe air infiltration
problems on negative pressure units. For reverse air systems, listen
near hopper poke holes/access hatches, compartment side access
hatches, and ductwork expansion joints. For pulse jet systems, listen
near top access hatches, hopper solids discharge valves, ductwork
expansion joints, and welded side walls
Check for signs of corrosion on hopper wall, top access hatches, and
other portions of the baghouse. Corrosion can indicate low temperature
operation and possible chemical attack of the bags
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Section 8
If the basic inspection steps indicate potential problems, the inspector can follow-up
on several issues, as appropriate. Figure 8-10 identifies several possible follow-up
considerations.
Figure 8-10
Fabric Filters: Follow-up Level 2 Inspection Parameters2
Follow-up Procedure
Relevance in Evaluating Filter O&M
Opacity Monitor QA
If VEO and opacity GEMS data provide significantly different results,
check opacity CEMS QA data for possible monitor problems
Evaluate daily zero and span checks at monitor console
Confirm fault lamps do not indicate major malfunctions
Discuss with mill personnel if any other QA activities have been
conducted recently and check records to evaluate results
Inlet/Outlet Gas Temperatures
(Pulse jet systems)
Check inlet and outlet temperatures for temperature drop on hot gas
streams. Monitors generally located near baghouse inlet and fan inlet
Temperature drop from inlet to outlet should range from 5-25°F; higher
drops could indicate air infiltration problems
Increase in baseline temperature drop of 5-10°F (at similar process rate
to baseline conditions) also indicates air infiltration concerns
Compressed Air
Leaks/Inoperative Diaphragm
Valves
(Pulse jet systems)
If static pressure drop is significantly higher than baseline levels,
conduct walkaround check for compressed air pipe leaks and check for
inoperative diaphragm valves
For leaks, check threaded fittings leading to manifolds and leading from
the manifolds to the diaphragm valves
Severe leaks can be detected audibly; for smaller leaks, look for oil
deposition on the outside of the fittings
For inoperative valves, check valves to determine if frozen in the closed
position — Note: This concern is applicable only to cold weather
conditions for units that do not have compressed air dryers and that
have valves mounted below the air manifolds
Records Checks
For frequent bag failure problems, check bag failure records. Spatial
bag failure record charts may be used by mill personnel to spot
localized causes of bag failures. Timeline records may also be used to
indicate when increases in failure rates indicates potential need to rebag
entire compartment. Check any lab tests on fabric to evaluate potential
need to replace bags
Check internal inspection/tracer dust test records to evaluate quality of
the mill's efforts to track causes of bag failures/other operating
problems and to develop appropriate procedures to minimize control
problems
For many safety reasons, including OSHA confined space entry regulatory
restrictions, agency inspectors should not conduct internal baghouse inspections. In some
situations, an inspector may be able to arrange with plant personnel to open one or more
top access hatches to conduct a visual check of clean side conditions of a pulse jet
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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baghouse. The inspector must not break the plane of the hatch opening while conducting
this observation. Fresh dust deposits on the top surface of the tube sheet indicates likely
bag holes or leaks.2
In addition, as noted in Figure 8-10, the agency inspector can check records of
internal inspections conducted by mill personnel. Typical key points in an internal
inspection include the following:
! Proper installation and tensioning of bags
! Presence and patterns of deposits on "clean side" of fabric filter
! Location and integrity of baffle plate
! Apparent bag/hopper pluggage
! Moisture or oil problems blinding the bag
! Evidence of high temperatures in fabric filter
Finally, for units with chronic high levels of excess emissions, the inspector should
review the startup and shutdown procedures for the boiler with the mill operators.
Baghouses cannot operate during early stages of startup or late stages of shutdown
procedures because of the low temperatures. Verify that the operators are scheduling
startup and shutdown cycles consistent with good O&M practices for minimizing
emissions.2 One check would be to compare similar mills to determine whether the mill
with problems has significantly higher startup/shutdown periods than a typical mill.
Evaluation of proper
operation of process equipment.
During a Level 2 inspection, the
inspector should review pertinent
boiler operating data that directly
affects compliance with applicable
requirements. If sulfur-in-fuel limits
apply, the records of fuel sulfur
content should be checked. If
operating limits apply, such as limits
on the type of fuel that may be
burned or restrictions on hours or
levels of operation, the appropriate
records for those operating
conditions should be checked.
Key Process Parameter Checks
Fuel sulfur content (for sulfur-in-fuel
standards)
Basic operating data (fuel type and
operating hours/levels) to the extent
permit limits apply
Follow-up checks on fuel
characteristics, firing conditions, or ash
characteristics if compliance problems
suspected
Furthermore, a number of other boiler process parameters can affect emissions.
The appropriate parameters are highly boiler-specific. However, Figure 8-11 summarizes a
number of potential process operating conditions and data sources that may be appropriate
for this type of process evaluation. If potential compliance problems are suspected, the
inspector may want to evaluate some of these conditions as applicable. The values for
these parameters collected during the inspection should be used to determine if the boiler is
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Section 8
operating at normal production levels and also should be compared with historic baseline
data obtained during performance tests.1
Most critical boiler parameters are recorded through automated distributed control
systems (DCS) at modern mills (especially for larger boilers), or some other records at
older mills (such as log sheets, strip charts or chart recorders). The availability of DCS
data allows for quick access to data and potential trend analysis capability. If the data are
not available through a DCS, copies of the other records may be obtained after the
inspection to provide necessary documentation.
Figure 8-11
Power Boiler O&M: Key Level 2 Inspection Parameters2
Fuel Characteristics
Fuel Type(s)
! Generally specified in operating permit
! Various types of wood waste have significantly
different moisture contents and size distributions
which can affect ability to change loads rapidly
Ultimate Analysis (sulfur, nitrogen, chlorine, ash)
Ultimate analyses data are usually available in
laboratory data sheets kept on file
Check for regulatory requirements pertaining
directly to sulfur content
Higher than allowed sulfur content will cause
excessive SO2 emissions
Much lower than normal sulfur content may create
problems for ESPs
Nitrogen content roughly indicates potential for NOX
formation
Proximate Analysis (volatile matter, fixed carbon,
moisture, ash, heating value)
Heating value is directly related to amount of fuel
that must be burned to generate specific amount of
steam
Reduced heating values generally result in increased
ash, SO2, and other emissions
Fuel Sizing
Sizing is important variable in boilers where coal,
wood, or refuse-derived fuel is mechanically
distributed
Changes in fuel size distribution can adversely
affect adequacy of fuel/air distribution and increase
PM emissions
Free-swell Index
(Grate-based Boilers)
Determined using ASTM Procedure D 720-67,
although the test is not typically performed
For grate-based boilers, coals with high free-swell
indices are especially prone to combustion
problems
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Figure 8-11 (cont.)
Power Boiler O&M: Key Level 2 Inspection Parameters2
Firing Conditions
Load
Determine boiler load using steam generation rate
data and/or feed water flow rate data
High boiler loads in excess of permitted value likely
to cause a general increase in pollutant emissions
High boiler loads may generate substantially
increased NOX due to high combustion zone
temperatures (although any load/NOx relationship
will vary between boilers)
Below-design boiler loads generate insufficient heat
in the boiler, which allows for the emission of
partial oxidation products, CO, and carbonaceous
PM
O2 Concentrations (excess air rates)
Flue gas O2 concentration data should be obtained
from both economizer outlet unit and (if available)
O2 monitor that accompanies SO2 and/or NOX
CEMS
Emissions of CO, partial oxidation products, and
PM occur rapidly as O2 concentration decreases
from desired range
CO Concentrations
CO monitor rarely in place — portable monitor
likely necessary
Significant increases in hourly average and
instantaneous CO data indicate combustion
problems that can lead to changes in pollutant
characteristics, as well as increases in pollutant
generation
Air Infiltration
Best indicated by gradual increase in average O2
concentration at given boiler load
May also be indicated by audible leaks in lower
areas of boiler unit and/or boiler drafts close to or
exceeding 0.0 in W.C.
Air infiltration cools down gas stream thereby
inhibiting completion of oxidation reactions
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Section 8
Figure 8-11 (cont.)
Power Boiler O&M: Key Level 2 Inspection Parameters2
Firing Conditions (cont.)
Overfire and Underfire Air Flow Rates
(Stoker boilers)
Overfire air supply header and undergrate plenum
pressure data for inspection period are available
from control room static pressure monitors
Data are usually recorded once per shift in unit
operating logs
Shifts from baseline overfire and underfire
pressures combined with obvious increases in
emissions (CO and stack opacity) could indicate
non-ideal combustion conditions
Soot Blowing Practices
Soot blower activation frequency can be determined
by observing indicator lights in soot blower control
room or by using DCS data
Information about soot blowing cycle is helpful in
interpreting performance of air pollution control
system
Fuel/Air Distribution
Fuel air distribution can be evaluated qualitatively
by observing grate from protected, side-access
hatches
Large variations in side-to-side and front-to-back
fuel bed thickness may cause combustion problems,
thereby leading to increased pollutant emissions
Boiler Draft (static pressure in combustion
chamber)
Monitored by gauge located upstream of heat
exchange equipment
Static pressure below normal -0.05 to -0.25 range
suggests ambient infiltration into combustion zone
Positive (greater than atmospheric) static pressure
may indicate fugitive emissions from boiler —
emissions are usually visible
Ash Characteristics
Loss-on-ignition (LOT) and Appearance
! High LOI values are associated with above-normal
concentrations of carbonaceous matter in exhaust
gases
! Can reduce ESP efficiency or lead to baghouse/ESP
fires
Fugitive Emissions
! Fugitive emissions may indicate poor ash
handling/transportation practices
Asbestos NESHAP compliance evaluation Finally, the on-site inspection
provides an opportunity to screen for compliance with asbestos demolition and renovation
(D&R) notice requirements. The inspector should interview mill personnel to determine
whether any maintenance, repair or similar construction activity conducted since the last
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does not alter any statutory or regulatory requirements.
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Section 8 Power Boiler Assessments
inspection involved insulated piping or similar locations likely to involve asbestos-
containing materials, and, if so, whether asbestos compliance issues were considered and
properly addressed. Obtain copies of any notice provided concerning the D&R activities.
If there was activity but no notice was filed, follow-up to determine whether asbestos-
containing materials were involved, and, if so, whether the applicability provisions of
Subpart M were triggered (see the summary of Subpart M requirements in Figure 8-8).
Also, verify that the wastes containing the removed asbestos-containing material were
properly sent to a waste disposal site that meets the requirements of Subpart M. The mill
should have copies of all waste shipment records required under Subpart M.
For routine inspections conducted in response to an asbestos D&R notification, see
the procedures outlined in applicable Agency guidance, such as Guidelines for Asbestos
NESHAP Demolition and Renovation Inspection Procedures (EPA 340/1-90-007,
November 1990).
8.4 Water Issues and Inspection Considerations
General process wastewaters. As noted in Section 8.2.3, a significant percentage
of the overall flow to the wastewater treatment plant involves process wastewater from
power operations. However, the effluent limits and monitoring requirements under the
CWA do not involve specific requirements applicable to the power boiler wastewaters.
Instead, the inspector will evaluate compliance with any permit limits for pollutants that
originate in power operations at the wastewater treatment plant (see Section 7).
Oil-fired boilers. If the mill operates oil-fired boilers, additional requirements
under the Clean Water Act may apply specifically to power boiler operations. The basic
structure of these requirements is as follows:
! Part 110 of the CWA prohibits discharges of oil that violate applicable water quality
standards, cause a film or sheen upon (or a discoloration of) the surface of the
water or on the adjoining shoreline, or cause a sludge or emulsion to be deposited
beneath the surface of the water or on the adjoining shoreline. If a prohibited
discharge occurs, then the owner or operator must provide immediate notification
to the National Response Center.
! Part 112 requires a Spill Prevention Control and Countermeasure (SPCC) plan for
oil-storing/consuming facilities, except where underground storage is < 42,000
gallons and unburied storage is < 1320 gallons (with no single container > 660
gallons). In addition to developing the plan, Part 112 imposes obligations related
to response planning, plan updating, and employee training.
! Parts 116 and 117 designate hazardous substances and reportable quantities (RQs)
for those substances. Except for allowable discharges to a POTW or under an
NPDES permit, discharges of a designated substance in excess of the applicable RQ
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Power Boiler Assessments Section 8
must be reported to the federal government in accordance with applicable
Department of Transportation regulations.
For these requirements, the key assessment procedures are to:
! Assure that the mill has developed an SPCC plan, if required
! Inquire about past instances of spills, leaks, and similar events
! Identify how the facility reacted to the event and whether similar events appear to
recur
This type of assessment provides a useful screening opportunity for the air inspector, given
that the water inspector generally will evaluate NPDES compliance issues at the
wastewater treatment plant and not in the power boiler process area. The air inspector can
note generally whether spills have occurred, and then the water inspector can evaluate the
details of the spill, and the facility's response, in a follow-up discussion with facility staffer
on-site inspection if warranted. Appropriate details for a follow-up inspection include:
! The material and quantity spilled, and the RQ for the material
! The waters affected by the discharge
! The timing of notice in relation to the timing of the spill
! The facility's response, whether the response was consistent with the SPCC,
whether the SPCC was adequate to address the spill, and appropriate modifications
to the SPCC
! Identification of health and safety issues for the plant, the community and the
receiving waters
Storm water requirements and inspection procedures The CWA requires an
NPDES permit for storm water discharges associated with industrial activity. As discussed
in Appendix B, EPA or State agencies (as applicable) typically issue "general" permits to
authorize discharges from a group of similar facilities. Storm water discharges from some
mills may, however, be covered by site-specific "individual" permits. Where EPA is the
NPDES permitting authority, most mills will be covered by EPA's multi-sector general
permit (MSGP) requirements. State permit requirements will vary but, in general, can be
expected to include requirements comparable to the MSGP requirements. The main
elements of the permit are to maintain a storm water pollution prevention (SWPP) plan and
conduct certain limited monitoring (quarterly visual examinations of grab samples and, in
some cases, analytical tests for particular pollutants).
The MSGP requirements applicable to the paper and allied products sector do not
specifically address power boiler operations at pulp mills. However, the MSGP also
includes separate requirements for the steam electric power generating sector. Because the
various MSGP requirements for different sectors apply to all co-located activities at a
facility, these requirements will apply to power boilers that supply electricity to kraft mill
process operations. For the power generating sector, the MSGP includes specific SWPP
elements that are in addition to the requirements applicable to all general permits (see
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Figure 8-12). The MSGP also requires specific monitoring of total recoverable iron in the
second and possibly fourth year of permit coverage for the steam electric generating
facilities.
Figure 8-12
Measures and Controls for Inclusion in Steam Electric Power
Generating Facility SWPP Plan
Activity/Pollutant
Source
Measures and Controls
Fugitive Dust Emissions
Plan must describe measures to prevent or minimize fugitive dust emissions
from coal handling areas
Facility shall consider establishing procedures to minimize offsite tracking of
coal dust. To prevent offsite tracking, facility may consider:
— Specially designed tires; or
— Washing vehicles in designated areas before they leave the site and
controlling wash water
Delivery Vehicles
Plan must describe measures that prevent or minimize contamination of storm
water runoff from delivery vehicles arriving on site. At a minimum, facility
should consider the following:
! Develop procedures for the inspection of delivery vehicles arriving on site
and ensuring overall integrity of the body of the container
! Develop procedures to control leakage or spillage from vehicles or
containers and ensure that proper protective measures are available for
personnel and environment
Fuel Oil Unloading Areas
Plan must describe measures that prevent or minimize contamination of storm
water runoff from fuel oil unloading areas. At a minimum, facility must consider
using the following measures or an equivalent:
! Use containment curbs in unloading areas
! During deliveries, station personnel familiar with spill prevention and
response procedures must be present to ensure that any leaks or spills are
immediately contained and cleaned up
! Use spill and overflow protection (drip pans, drip diapers, and/or other
containment devices shall be placed beneath fuel oil connectors to contain
any spillage that may occur during deliveries or due to leaks at such
connectors)
Chemical
Loading/Unloading Area
Plan must describe measures that prevent or minimize the contamination of
storm water runoff from chemical loading/unloading areas. At a minimum,
facility must consider using the following measures or an equivalent:
! Use containment curbs at chemical loading/unloading areas
! During deliveries, station personnel familiar with spill prevention and
response procedures must be present to ensure that any leaks or spills are
immediately contained and cleaned up
! Where practicable, chemical loading/unloading areas should be covered, and
chemicals should be stored indoors
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Section 8
Figure 8-12 (cont.)
Measures and Controls for Inclusion in Steam Electric Power
Generating Facility SWPP Plan
Activity/Pollutant
Source
Measures and Controls
Miscellaneous
Loading/Unloading
Plan must describe measures that prevent or minimize contamination of storm
water runoff from loading and unloading areas. Facility may consider:
! Covering the loading area;
! Minimizing storm water runon to the loading area by grading, berming, or
curbing the area around the loading area to direct storm water away from the
area; or
! Locating the loading/unloading equipment and vehicles so that leaks can be
controlled in existing containment and flow diversion systems
Liquid Storage Tanks
Plan must describe measures that prevent or minimize contamination of storm
water runoff from above ground storage tanks. At a minimum, facility must
consider employing the following measures or an equivalent:
! Use protective guards around tanks
! Use containment curbs
! Use spill and overflow protection (drip pans, drip diapers, and/or other
containment devices shall be placed beneath chemical connectors to contain
any spillage that may occur during deliveries or due to leaks at such
connectors)
! Use dry cleanup methods
Large Bulk Fuel Storage
Tanks
Plan must describe measures that prevent or minimize contamination of storm
water runoff from liquid storage tanks. At a minimum, facility must consider
employing the following measures or an equivalent:
! Comply with applicable State and federal laws, including Spill Prevention
Control and Countermeasures (SPCC)
! Containment berms
Oil Bearing Equipment in
Switchyards
Plan must describe measures to reduce the potential for storm water
contamination from oil bearing equipment in switchyard areas. Facility may
consider:
! Level grades and gravel surfaces to retard flows and limit the spread of spills
! Collection of storm water runoff in perimeter ditches
Oil and Chemical Spills
Plan must describe measures for an oil or chemical spill, or reference the
appropriate section of their SPCC plan. At a minimum:
! The structural integrity of all above ground tanks, pipelines, pumps, or other
related equipment should be visually inspected on a weekly basis
! All repairs deemed necessary based on the findings of the inspections shall
be completed immediately to reduce the incidence of spills and leaks
occurring from such faulty equipment
Residue Hauling Vehicles
! All residue hauling vehicles shall be inspected for proper covering over the
load, adequate gate sealing, and overall integrity of the body container
! Vehicles without load covers or adequate gate sealing or with poor body or
container conditions must be repaired as soon as practicable
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Section 8
Power Boiler Assessments
Figure 8-12 (cont.)
Measures and Controls for Inclusion in Steam Electric Power
Generating Facility SWPP Plan
Activity/Pollutant
Source
Measures and Controls
Ash Loading Areas
Plant procedures shall be established to reduce and/or control the tracking of ash
or residue from ash loading areas including, where practicable, requirements to
clear the ash building floor and immediately adjacent roadways of spillage,
debris, and excess water before each loaded vehicle departs
Areas Adjacent to
Disposal Ponds or
Landfills
Plan must describe measures that prevent or minimize contamination of storm
water runoff from areas adjacent to disposal ponds or landfills. Facility must
develop procedures to:
! Reduce ash residue which may be tracked on to access roads traveled by
residue trucks or residue handling vehicles
! Reduce ash residue on exit roads leading into and out of residue handling
areas
Landfills, Scrapyards, and
General Refuse Sites
Plan must address landfills, scrapyards, and general refuse sites. Facility should
refer to applicable BMPs for Storm Water Discharges from Landfills and Land
Application Sites, and for Storm Water Discharges from Scrap and Waste
Material Processing and Recycling Facilities
Maintenance Activities
For vehicle maintenance activities performed on site, facility shall consider the
applicable BMPs for Storm Water Discharges from Vehicle Maintenance or
Equipment Cleaning Operations at Motor Freight Transportation Facilities,
Passenger Transportation Facilities, Petroleum Bulk Oil Stations and Terminals,
or the United States Postal Service
Material Storage Areas
Plan must describe measures that prevent or minimize contamination of storm
water from material storage areas. Facility may consider:
! Flat yard grades,
! Runoff collection in graded swales or ditches,
! Erosion protection measures at steep outfall sites,
! Covering lay down areas,
! Storing the materials indoors,
! Covering the material with a temporary covering made of polyethylene,
polyurethane, polypropylene, or hapalon, or
! Minimizing storm water runon by constructing an enclosure or building a
berm around the area
To evaluate compliance with basic storm water requirements, the inspector should:
Review applicable records to assure that the SWPP is up to date and includes all
required elements, and that the mill has performed all required self-monitoring and
self-inspection procedures
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Power Boiler Assessments Section 8
! Evaluate the results of monitoring and inspection data to determine whether those
records indicate potential compliance concerns — if the data indicate potential
problems, follow up with mill personnel to determine what corrective actions, if
any, were taken in response to the monitoring/inspection results
! Observe control and prevention measures to evaluate whether good operation and
maintenance practices are being used
! Verify that the mill does not have improper connections that permit non-storm
water to be discharged from storm water outfalls
In addition to these basic steps, the following procedures should be used to
evaluate compliance with storm water requirements that may be specifically applicable to
power boiler operations:
! If the mill has coal-fired boilers, carefully review measures to control coal pile
runon/runoff and to minimize fugitive dust emissions from coal piles
! For oil-fired boilers, check containment curbs and similar measures used at delivery
locations and for tank storage for adequate O&M. Observe deliveries if possible to
document that required procedures are used and appropriate staff are involved in
fuel handling — coordinate this evaluation with an evaluation of the mill's SPCC
plan
! Check inspection reports to evaluate the mill's compliance with the inspection
requirements and adequacy of response actions to problems detected
8.5 RCRA Issues and Inspection Considerations
The solid waste generated by
power boiler operation is generally
non-hazardous solid waste. The
bottom and fly ash from combustion
is either landfilled with other solid
wastes or may be sold or reused as
an additive. See Section 9 for a
discussion of solid waste landfill issues. To the extent a mill generates specific hazardous
wastes in ancillary power boiler operations, then those wastes must be handled as
hazardous wastes in accordance with standard RCRA procedures. See Appendix C for an
overview of the regulatory requirements that apply and appropriate inspection procedures
for these generator requirements.
NOTE! See Appendix C for overview of
RCRA requirements and inspection
techniques for hazardous waste generator
concerns.
In addition, the Cluster Rules provide a specific exemption from RCRA for certain
condensates recovered in the pulping area that contain methanol. This exemption allows
the mill to burn the condensates in the power boilers without having to comply with RCRA
requirements for boilers and industrial facilities. See Section 4.5 for further discussion.
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Section 8 Power Boiler Assessments
8.6 EPCRA Issues and Inspection Considerations
General concerns The basic M/-^^,
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Power Boiler Assessments Section 8
! TRIForm R. Check to ensure that the form is on file and that the source has
adequately considered releases associated with the power boilers and associated
equipment. Also, ask to see the estimation technique being used. If the estimation
technique involves an assumed reduction efficiency for control methods, make sure
that the assumed efficiency is consistent with the overall efficiency that the mill is
achieving. The overall assumed efficiency should account for any excess emission
releases in a manner consistent with the actual percent of operating time such
releases occur. Uncontrolled emission episodes or periods of reduced control
efficiency can have a significant impact on the estimate of total releases.
! Emergency notifications. Request documentation that the mill has filed all required
notices.
If an agency air inspector plans to screen for EPCRA compliance, the inspector
should confirm the necessary information with the facility contact during the opening
conference or just in advance of the closing conference. For an announced inspection, the
inspector should ask the source to have ready EPCRA-related documentation so that the
screening check can be performed without interrupting the main focus of the inspection. A
screening checklist is included as part of the example assessment form in Appendix E.
In addition to a screening-type records review inspection, an EPCRA inspector may
want to conduct further assessments to identify potential compliance concerns with
emergency notification requirements. As one technique, the inspector first can check
excess emission reports, malfunction reports, and citizen complaints since the previous
inspection. The inspector then should cross-check those incidents with notification records
identified in EPA's ERNS database, records on file with the State/local emergency
coordinator, or records requested from the mill. If this type of investigation identifies
episodes of abnormal emissions in which no notification was provided, the inspector should
consider a follow-up investigation to determine if reportable quantity thresholds were
exceeded.
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Section 8 Power Boiler Assessments
References:
1. Kraft Pulp Mill Inspection Guide. Prepared for U.S. EPA under Contract No. 68-01-
6310, Work Assignment No. 65, Pedco Environmental, Inc., Cincinnati, Ohio, January
1983.
2. Richards, J., Baseline Inspection Techniques, Student Manual, Air Pollution Training
Institute Course 445, 2nd Edition, 1996.
3. Ohio EPA's Operation and Maintenance (O&M) Guidelines for Air Pollution Control
Equipment., prepared for Ohio Environmental Protection Agency, under Contract No.
0810252, Environmental Quality Management, Inc., February 1993.
4. Proposed Technical Development Document for the Pulp, Paper and Paperboard
Category and Effluent Limitations Guidelines, Pretreatment Standards, and New
Source Performance Standards. U.S. Environmental Protection Agency, Washington,
D.C., October 1993.
5. Christman, R.C. et al., Activities, Effects and Impacts of the Coal Fuel Cycle for a
1,000 MWe Electric Power Generating Plant, Final report prepared for U.S. Nuclear
Regulatory Commission, February 1980.
6. H.A. Simons Ltd. et al., Water Use Reduction in the Pulp and Paper Industry 1994., a
Monograph sponsored by Fletcher Challenge Canada Limited and coordinated by Pulp
and Paper Research Institute of Canada, November 1994.
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SECTION 9: ASSESSMENT MODULE FOR WOOD YARD,
PAPERMAKING, AND OTHER OPERATIONS
9.1 Introduction
This section provides
information for conducting a
compliance assessment of the areas
within the mill that generally receive
little attention from agency
inspectors - including woodyard
operations, papermaking activities,
on-site landfills, and other general
mill operations. In addition,
Appendix E contains an example
assessment form specifically
designed to address the issues raised
in this process area.
CONTENTS
9.1 Introduction
9.2 Overview of Processes and
Discharges
9.3 Air Issues and Inspection
Considerations
9.4 CWA Requirements and Inspection
Considerations
9.5 RCRA Issues and Inspection
Considerations
9.6 EPCRA Issues and Inspection
Considerations
9.2 Overview of Processes and Discharges
9.2.1 Description of the Process
Woodyard operations. Wood preparation entails converting wood into a form
amenable to chemical pulping. Mils that receive wood in the form of logs typically cut
logs to manageable lengths and then conduct the following five operations:
conveying/washing logs via flume, debarking, chipping, knotting and screening, and
storage and transfer. A brief description of each is provided below.1'2
Log flumes. Prior to debarking, water-filled channels or flumes are used by a
number of mills to convey logs, as well as to provide washing. Flume water is typically
recycled; however, it must occasionally be purged. Solids are commonly dredged out and
landfilled or land applied.
Debarking. Because bark has very little useful fiber and contains dirt that reduces
the overall pulp quality, logs (roundwood) are usually debarked before being used for pulp
manufacturing. Prior to removal, the bark is softened by one of various techniques,
including: spraying the logs with water, soaking the logs in ponds, or steaming the logs in
special chambers. The bark is then removed either mechanically through abrasive action or
hydraulically using a high pressure water jet. Once removed from the logs, the bark is
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either flung from the machine or allowed to fall through openings along the base of the
machine onto a conveyor situated below. If the bark is to be used as boiler fuel, any
residual moisture is removed by presses.
Chipping. After the logs have been debarked, they must be reduced in size so that
cooking chemicals can easily penetrate the wood fiber to separate lignin and carbohydrates
from the cellulose. This is achieved by feeding the logs into chippers, which use powerful
high-speed rotating knives to reduce the wood to a uniform size.
Screening. After passing through the chipper, the wood contains fines, slivers, and
oversized chips. Wood chips are therefore passed over vibratory screens to remove
oversized chips and fines. Oversized chips remain on the upper screen and are recycled to
a chipper, sheer, or crusher. Fines drop into a collection hopper below the screens and are
usually used, along with bark, as boiler fuel.
Storage and transfer. After screening, chips are generally stored in large outside
piles or chip silos. The chips are typically moved to subsequent operations by conveyors or
augers.
Papermaking. Kraft pulp — wood fibers — that is dried, baled or rolled, and sold
as a finished product is known as market pulp. Some bleached kraft mills (including all
mills that make dissolving grade pulp) sell market pulp. Other bleached kraft mills send
pulp either as a slurry or partially dried (wet evaporated) to other mill sites. The remainder
of the bleached kraft mills, and virtually all mills that produce unbleached kraft pulp, use
the pulp on site to make paper and paperboard.
Paper is a felted sheet formed on a fine screen from a water suspension of fibers
and non-fibrous additives.1 Paperboard is distinguished from paper by thickness greater
than 0.3 mm. Materials mixed with the pulp before it is made into paper are called wet-end
additives. Materials applied to the formed paper are called coatings. Additives and
coatings can contribute up to 10 to 40 percent of the weight of the finished paper.
Commonly used additives and coatings are:
! Rosin and starch, sizing agents used to control penetration of liquids
! Clay, talc, and titanium dioxide, fillers that improve optical and surface properties
! Alum (aluminum sulfate) used to control pH and fix additives onto fibers
! Dyes, pigments, and brightening agents, used to color paper
! Polymer emulsions (latexes, acrylics, polyvinyl acetate) used for coatings
Although some mills manufacture market pulp only, most U.S. kraft mills produce
paper or paperboard as their final product. Market pulp is typically dried on a fourdrinier-
type machine or an air float dryer. Papermaking operations generally consist of the
following three discrete processes:
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Section 9 Assessment Module for Woodyard, Papermaking, and Other Operations
Pulp stock preparation. Pulp stock is processed to obtain desired qualities, such as
surface, opacity, strength, and feel, in the finished paper and paperboard products. Stock
preparation processes include pulp mixing and dispersion, beating and refining, and the
addition of wet-end additives. Softwood and hardwood pulp are frequently combined to
produce paper or paperboard of desired finished properties. Beating and refining make the
finished product stronger, more uniform, more dense, more opaque, and less porous.
Wet end operations. The Fourdrinier machine is the most commonly employed
paper machine for the manufacture of paper and paperboard. The first two operations
performed by this machine, sheet formation and pressing, are referred to as "wet end"
operations. Pulp fibers in the form of a fiber slurry are distributed evenly onto a thin
moving wire mesh belt ("the wire") through which excess water drains. Suction from a
series of hydrofoils, vacuum boxes, and vacuum rolls further extracts water from the
formed sheet. From the wire, the formed sheet passes through a series of presses designed
to remove additional water and compress the fibers. Excess water containing valuable
entrained fiber is captured and, after a series of thickening and cleaning steps, recycled.1
Dry end operations. The remaining operations performed by the Fourdrinier —
drying, calendering, reeling, winding, and application of surface treatments — are referred
to as "dry end" operations. The sheet leaves the presses and enters the dryer, where steam-
heated rollers evaporate any residual water, and fibers begin to adhere to one another. The
sheet is then pressed between heavy rolls in the calender that reduce the thickness of the
paper and create a smooth surface. If the paper is to be finished, surface treatments such
as external sizing or coating are added, and super calendering is performed. Finally, the
paper is wound onto a reel for intermediate storage. On- or off-machine rewinding is later
performed to cut and wind the full-size reels into smaller, more manageable rolls. At this
point, the rolls are wrapped and deemed ready for distribution.1
General mill services and operations. Kraft pulp mills will have other ancillary
operations not discussed in Sections 4 through 8. These processes include:
Solid waste landfills. In addition to landfilling wastewater treatment plant sludges
(see Section 7), kraft pulp mills may use on-site landfills for other mill wastes, including fly
and bottom ash from combustion sources, lime mud, and green liquor dregs. These
landfills will be subject to State-specific regulations developed under Subtitle D of RCRA.
The EPA guidelines for industrial landfills generally impose few requirements on States
other than certain general siting criteria. State solid waste programs will require mills to
obtain permits for each landfill and may impose a variety of conditions such as leachate
collection, operator training, self-inspection, ground water/surface water monitoring, and
similar requirements. Leachates, however, are typically routed to the wastewater treatment
system.
Industrial refrigeration. Kraft mills may operate customized industrial
refrigeration equipment for certain mill activities, especially related to bleach plant
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Assessment Module for Woodyard, Papermaking, and Other Operations Section 9
operations. Because of the use of chlorofluorocarbons in this type of equipment, there are
certain stratospheric ozone protection regulations that may apply.
Laboratories. Kraft mills operate laboratories to test the properties of their raw
materials, pulp, finished paper products and wastewater. Some of the wastes generated by
laboratories are hazardous wastes, which mills generally dispose of off-site, using a waste
disposal service. Laboratory wastewaters are treated in the mill wastewater treatment
plant.
Water supply treatment. Water sources for pulp and paper mills are categorized as
either surface water or ground water. Surface water sources from lakes, rivers and
reservoirs contain varying amounts of inorganic and organic contaminants. Groundwater
taken from springs and wells usually contain relatively high concentrations of dissolved
mineral matter. It is necessary to treat the raw water to reduce impurities to a level that
will not adversely affect equipment operation or product quality. Depending on specific
requirements, water treatment may employ a combination of sedimentation, filtering, and
coagulation. Supplemental processes include chlorination, aeration, de-aeration,
demineralization, and fine filtration. Water treatment may generate sludges that are
disposed in on-site landfills. In addition, as with on-site laboratories, water treatment may
involve chemical handling. However, water treatment operations generally are not a
significant compliance concern.
General maintenance/shop/fuelingfacilities. As with any large facility, pulp mills
will have a number of ancillary maintenance, shop and fueling operations that service the
needs of the facility. These operations will trigger waste handling requirements and may
raise storm water concerns as well.
9.2.2 Air Pollutant Emissions
Wood handling. Most of the air emissions from a woodyard, except those from
pneumatic conveying systems, are fugitive. Common sources of these fugitive emissions
include haul roads, debarkers, and chips that are received dry (shaving and saw dust). In
general, control measures consist of containment of sources and watering (or paving) haul
roads and other traveled areas. Water may also be used on the debarkers to reduce dust
and to wash the logs, as well as on shaving and saw dust to reduce fugitive emissions at
transfer points. Emissions from the pneumatic conveying cyclone are generally controlled
by the use of water sprays, which can reduce cyclone emissions by 95 percent.2
Papermaking. Air emissions from papermaking consist mainly of water with little
or no paniculate matter emitted by the dryers.4 Some particulate matter emissions may
occur as a result of raw material storage and handling activities, such as starch silos.
Emissions of volatile organic compounds, including hazardous air pollutants, may derive
from:
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Section 9 Assessment Module for Woodyard, Papermaking, and Other Operations
! Pulp stock
! Recycled Whitewater
! Additives
As part of the Cluster Rules development, EPA considered whether standards should be set
for papermaking activities. To make this determination, EPA evaluated several test results
from kraft pulp mills. The following pollutants were the primary HAPs identified in these
tests:
! Methanol
! Acetaldehyde
! MEK
! Tetrachloroethylene
! Propionaldehyde
These analyses documented that the additives contributed little to the total HAP
emissions.3 Because the additives tend to have high boiling points, very small quantities are
likely to volatilize and result in air emissions.4 Furthermore, EPA determined that the
control techniques for HAP emissions from paper machine vents are impractical based on
the cost per ton of pollutant removed.3
Other activities. Air emissions from other miscellaneous activities generally are
not regulated and do not raise significant concerns, although some air emission control
requirements for solvent parts washers may apply. In addition, general fugitive dust and
nuisance requirements likely apply. For the on-site landfills, odorous air emissions and
fugitive dust may raise concerns in some situations. Finally, stratospheric ozone protection
requirements may apply to certain industrial refrigeration units used at a mill (such as
chlorine dioxide chillers).
9.2.3 Water Pollutant Discharges
Wood handling. Wastewater sources in the wood handling area of a kraft mill
include:
! Wet barking
! Log washing or chip washing
! Log flumes or log ponds
In the 1970s, wet wood handling contributed up to 25 percent of the BOD5 load
discharged by mills that employed these practices. Wastewater regulations for
conventional pollutants include specific allowances for discharges from wet wood handling
operations only for mills that employ them. Over the past 20 years, use of wet woodyard
operations has declined. In EPA's 1990 survey of the industry, of the total wastewater
flow generated by kraft mills, only one to two percent originated in wood preparation
operations.5 Storm water discharges from wood yards also are subject to CWA regulation
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Assessment Module for Woodyard, Papermaking, and Other Operations Section 9
and are specifically addressed in EPA's multi-sector general permit (MSGP) developed for
kraft mills. Storm water issues are discussed in more detail in Section 9.4, as well as in
Appendix B.
Papermaking. Papermaking accounts for a significant portion (25 to 35 percent
by volume) of the wastewater discharges generated by kraft mills.5 Pollutants discharged
from the papermaking processes consist primarily of BOD5 and TSS. These pollutants are
treated in the mill's wastewater treatment plant prior to discharge. There are no specific
regulatory concerns associated with the wastewater from papermaking. To the limited
extent a mill uses outdoor material handling and storage areas for papermaking operations,
this process may also contribute to a mill's storm water discharge. Storm water issues are
discussed in more detail in Section 9.4, as well as in Appendix B.
Other activities. Under 40 CFR 430.01(m), leachate from unbleached kraft pulp
mill solid waste landfills is considered process wastewater where these leachate
wastewaters are commingled with other process wastewaters. Leachates typically
constitute a very small proportion of the total volume treated in the mill wastewater
treatment plant. In addition, a mill's landfill permit may include monitoring requirements to
evaluate potential contamination of ground or surface waters. Surface water runoff from
the landfill area also will be subject to storm water requirements. Other miscellaneous
industrial activities conducted onsite (miscellaneous shop, maintenance and storage
facilities) may also be subject to general storm water requirements and be covered by a
mill's storm water pollution prevention plan.
9.2.4 Solid/Hazardous Waste Discharges
Woodyard, papermaking and other miscellaneous operations identified in this
section typically will generate some solid wastes. Bark and other wood wastes constitute
the largest residual waste stream at most facilities.6 However, much of this wood waste
will be used as power boiler fuel; any remaining wastes that require disposal generally
would constitute non-hazardous solid waste. Papermaking operations also generate a
number of solid waste residuals, such as fibers, fillers and broke from the paper machine,
coating residue and broke from finishing operations, and cleaner and junker rejects from
wastepaper processing.7 In addition, some of the papermaking wastes may have to be
handled as hazardous wastes depending on the type of additives used. Used oil, certain
solvents, spent fluorescent light bulbs, and similar wastes may have to be handled as
hazardous wastes to the extent generated by the other miscellaneous activity areas at the
mill.
9.2.5 EPCRA Chemicals and Reportable Releases
Wood handling. The EPCRA issues for woodyard operations are relatively minor.
See Appendix D for a general discussion of EPCRA issues and inspection procedures, as
well as a list of chemicals that may be located in the woodyard that would be subject to
EPCRA inventory and other emergency preparedness requirements.
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Section 9 Assessment Module for Woodyard, Papermaking, and Other Operations
Papermaking. The papermaking process involves the manufacture, processing,
and use of a significant number of reportable hazardous chemicals. Kraft pulp mills
engaged in paper and paperboard production must provide information on hazardous
chemicals used in the papermaking process to State and local emergency agencies in order
to satisfy EPCRA's emergency preparedness provisions. Appendix D contains a process-
based list of chemicals that may be covered in an inventory for a typical mill. In addition to
the listed items, mills generally will have a number of additional specific chemicals that will
vary from mill to mill depending on the additives used by a particular mill. On-site air and
land releases, including land disposals, of toxic chemicals associated with the papermaking
process and off-site transfers of waste containing these toxic chemicals may also have to be
accounted for in TRI Form R reports; and EPCRA/CERCLA emergency reporting could
apply for off-site releases that are not federally permitted and that exceed a certain
reportable quantity. Section 9.6 and Appendix D discuss these issues.
Other activities. The emergency release requirements under EPCRA are not
expected to raise significant concerns with respect to the other activity areas addressed in
this Section 9, although miscellaneous material handling spills and other accidental releases
may trigger emergency notification requirements. In addition, the emergency preparedness
requirements do not raise specific process-based concerns, although the chemical inventory
and TRI reporting obligations may apply for various chemicals associated with these
miscellaneous mill activity areas.
9.3 Air Issues and Inspection Considerations
Wood handling. Although some permits may include specific work practice
standards for woodyard operations, generally the only applicable requirements are generic
opacity standards, general nuisance provisions, or general requirements for proper
operation and maintenance of a facility. Consistent with these types of requirements, the
inspector should:
! Conduct a visual evaluation of fugitive dust sources. If fugitive dust sources
appear high in comparison to other mills, interview plant personnel about the mill's
procedures for reducing fugitive emissions and note this information for subsequent
evaluation against other mills' procedures.
! Verify that the mill is conducting any control measures or work practices that are
required by permit or regulation. If water spray systems are used, verify the
location of spray nozzles and visually determine if the water spray pattern is
adequate. The water flow rate should be recorded along with the water supply
pressure for each system. Compare these data to design or other baseline values
for the water spray system.
In addition, the inspector should determine whether there have been any
modifications to the woodyard operations that could allow for increased production (and
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Assessment Module for Woodyard, Papermaking, and Other Operations Section 9
emissions) in other areas of the mill. If so, the increased emissions in the other process
areas that are associated with the ability to increase production may trigger new source
review (NSR) permit requirements. Document how the mill addressed NSR issues when
making the woodyard modifications.
Papermaking. As with the woodyard operations, there generally are no specific
air regulations that apply to the papermaking operations. There may be some small
controls in place, such as cyclones on fine paper finishing vents or filter systems on starch
silos. The inspector may conduct a visual screening check for visible emissions in this area.
In addition, as with woodyard operations, NSPS or NSR requirements for other
process areas may be triggered if papermaking improvements allow for increased
production (and emissions) in those other process areas. For instance, EPA has previously
noted these concerns in advising a State agency in the context of a planned papermaking
press replacement.8 The agency noted that the papermaking modification would increase
mill production capacity and would likely increase TRS and particulate matter emissions
from units outside the papermaking area that are the types of units affected under NSPS
Subpart BB (such as digesters and washer systems). These emission increases potentially
could trigger NSPS and/or NSR applicability. In this determination, the Agency noted a
key distinction in determining whether NSPS or NSR requirements are triggered:
! Because the NSPS do not apply to the papermaking operations, the NSPS would
be triggered only if the increase in production allowed by the press modification
required a capital expenditure on a unit of the type subject to the NSPS (e.g.. a
digester)
! For PSD, the entire mill is considered the affected source, so any "significant"
emission increase (as defined in the applicable NSR program) from the mill as a
whole would trigger NSR review
The inspector should determine what, if any improvements have been made or are
scheduled for the papermaking operations and then interview plant personnel to determine
how the mill addressed (or plans to address) NSPS and NSR concerns associated with the
modification(s).
Industrial refrigeration. Owners and operators of complex customized
refrigeration appliances used in various industries, including pulp and paper, are required to
follow service practices that maximize recovery and recycling during the service and
disposal of industrial process refrigeration equipment that contains chlorofluorocarbons
(CFCs). Where the same system is used as both industrial process refrigerant equipment
and comfort-cooling equipment, the appliance is considered industrial process refrigeration
equipment if at least 50 percent of its capacity is used in an industrial process refrigeration
application.
Persons servicing or disposing of this equipment must be properly certified, and
certified equipment and required service practices must be used. Also, because almost all
of these appliances normally contain more than 50 pounds of refrigerant, specific leak
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Section 9 Assessment Module for Woodyard, Papermaking, and Other Operations
repair requirements must be followed. The leak repair requirements are triggered when
refrigerant is found to be leaking at a rate that would exceed 35 percent of the total charge
in a 12-month period. The owner or operator must either repair such leaks within thirty
days from the date the leak was discovered, or develop a dated retrofit/retirement plan
within thirty days and complete actions under that plan within one year from the plan's
date. However, under certain circumstances, additional time may be available.
These requirements are contained in 40 CFR Part 82 Subpart F, the regulations
promulgated under section 608 of the Clean Air Act. The basic regulatory provisions
include:
! Specific servicing requirements at § 82.156, including the leak repair requirements
at §82.156(1)
! Technician certification requirements at § 82.161
! Recordkeeping and reporting requirements at § 82.166, including the leak repair
requirements at § 82.166(n) and (o)
In addition, there are a number of resources available from the Stratospheric
Protection Division's Hotline ((800) 296-1996) or the EPA Website
(www.epa.gov/docs/ozone). For the CFC program, EPA has developed various fact sheets,
a Compliance Guidance, Self-Audit Checklist, and Training Module For Industrial Process
Refrigeration Leak Repair Regulations Under Section 608, and an inspector's checklist.
Applicability determinations for questions about the coverage of these regulations can be
found at the ADI Website (see http://www.epa.gov/oeca).
Based on experience with the program to date, the inspector should focus on
whether persons operating industrial refrigeration have failed to:
! Employ properly certified technicians for refrigerant recovery
! Use certified equipment for refrigerant recovery
! Repair substantial leaks
! Retrofit or retire equipment properly
! Submit information regarding leak repair or retrofit/retirement requirements
The example assessment form in Appendix E includes a checklist of appropriate questions
that EPA has developed as part of its inspection guidance materials for the section 608
CFC program.
9.4 CWA Requirements and Inspection Considerations
9.4.1 NPDES Permit Review and Physical Inspection of the Woodyard
The inspector should review
the permit application and permit
limit calculations and determine if the
existing permit limits include
NOTE! Only mills employing wet
woodyard operations should have permit
allowances for such operations.
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allowances for discharges from wet wood handling operations. During the on-site
inspection, the inspector should examine the woodyard to determine if wet woodyard
operations are occurring. If an inconsistency is found, the inspector should consult with
the permit writer and determine if a permit modification is required.
9.4.2 Storm Water Requirements
The CWA requires an NPDES permit for storm water discharges associated with
industrial activity. As discussed in Appendix B, many permits are issued as "general"
permits to authorize discharges from a group of similar facilities, although site-specific
"individual" permits also may be used. The main permit elements are to develop and
comply with a storm water pollution prevention (SWPP) plan and conduct certain limited
monitoring (quarterly visual examinations of grab samples and, in some cases, analytical
tests for certain pollutants).
Wood handling is likely to contribute to storm water runoff and is a focal point for
storm water management at a mill. Wood handling activities such as log washing, bark
removal, and chipping/sawing generate large quantities of wood chips, sawdust, and other
debris. If exposed to storm water, these activities may contribute total suspended solids
(TSS) and biochemical oxygen demand (BOD5) to a mill's storm water discharge. On-site
landfills also may contribute pollutants to storm water discharges. Storm water discharges
from landfills frequently contain high TSS levels because of extensive land disturbance
activities.
The EPA has established a multi-sector general permit (MSGP) for jurisdictions in
which EPA is the NPDES permitting authority. State permit requirements vary but
generally will include requirements comparable to the MSGP requirements. Because the
MSGP is organized by various sectors, there is the possibility that a single mill will be
subject to different sector portions of the MSGP. One example of this type of co-located
MSGP coverage are the sectors for general kraft pulp mill operations (including woodyard,
papermaking and other miscellaneous mill operations) and for landfill (or land application)
operations. Figures 9-1 and 9-2 summarize the applicable best management practices
(BMPs) that EPA has identified for these operations.
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Section 9 Assessment Module for Woodyard, Papermaking, and Other Operations
Figure 9-1
Suggested BMPs for Paper and Allied Product Manufacturing Facilities
Activity
Suggested BMPs
Outdoor loading
and unloading
Confine loading/unloading activities to a designated response and control area
Avoid loading/unloading material in the rain
Cover loading/unloading area or conduct these activities indoors
Develop and implement spill plans
Use berms or dikes around area
Inspect containers for leaks or damage prior to loading
Use catch buckets, drop cloths, and other spill prevention measures where liquid
materials are loaded/unloaded
Provide paved areas to enable easy collection of spilled materials
Raw and/or waste
material storage
areas
Confine storage to a designated area
Store materials inside
Cover storage areas with a roof or tarp
Use dikes or berms for storage tanks and drum storage
Cover dumpsters used for waste paper and other materials
Store materials on concrete pads to allow for recycling and spills of leaks
Expedite recycling process for exposed scrap paper
Develop and implement spill plans
Provide good housekeeping (i.e., dust and debris collection) where cyclones are
utilized
Divert storm water around storage areas with ditches, swales, and/or berms
Log, lumber, and
other wood
product storage
areas
! Practice good housekeeping measures such as frequent removal of debris
! Line storage areas with crushed rock or gravel or porous pavement to promote
infiltration, minimize discharge, and provide sediment and erosion control
! Use ponds for collection, containment, and recycle for log spraying operations
Maintenance
activities
For vehicle maintenance activities performed on site, facility shall consider the
applicable BMPs for Storm Water Discharges from Vehicle Maintenance or
Equipment Cleaning Operations at Motor Freight Transportation Facilities, Passenger
Transportation Facilities, Petroleum Bulk Oil Stations and Terminals, or the United
States Postal Service
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Assessment Module for Woodyard, Papermaking, and Other Operations Section 9
Figure 9-2
Potential Sources of Pollution and General Storm Water BMPs for Landfills
Potential Pollutant Sources
BMPs
Erosion from:
! Exposed soil from
excavating cells/trenches
! Exposed stockpiles of cover
materials
! Inactive cells with final
cover but not yet finally
stabilized
! Daily or intermediate cover
placed on cells or trenches
! Erosion from haul roads
(including vehicle tracking
of sediments)
Stabilize soils with temporary seeding, mulching, and geotextiles;
leave vegetative filter strips along streams
Implement structural controls such as dikes, swales, silt fences, filter
berms, sediment traps and ponds, outlet protection, pipe slope drains,
check dams, and terraces to convey runoff, to divert storm water flows
away from areas susceptible to erosion, and to prevent sediments from
entering water bodies
Frequently inspect all stabilization and structural erosion control
measures and perform all necessary maintenance and repairs
Stabilize haul roads and entrances to landfill with gravel or stone
Construct vegetated swales along road
Clean wheels and body of trucks or other equipment as necessary to
minimize sediment tracking (but contain any wash waters [process
wastewaters])
Frequently inspect all stabilization and structural erosion control
measures and perform all necessary maintenance and repairs
Application of fertilizes,
pesticides, and herbicides
Observe all applicable Federal, State, and local regulations when
using these products
Strictly follow recommended application rates and methods (i.e., do
not apply in excess of vegetative requirements)
Have materials such as absorbent pads easily accessible to clean up
spills
Exposure of waste at open face
! Minimize the area of exposed open face as much as is practicable
! Divert flows around open face using structural measures such as
dikes, berms, swales, and pipe slope drains
! Frequently inspect erosion and sedimentation controls
Waste tracking onsite and haul
roads, solids transport on
wheels and exterior of trucks or
other equipment (common with
incinerator ash)
! Clean wheels and exterior of trucks or other equipment as necessary to
minimize waste tracking (but contain any wash waters [process
wastewaters])
Uncontrolled leachate
! Frequently inspect leachate collection system and landfill for leachate
leaks
General sources
! Maintain landfill cover and vegetation
! Maintain leachate collection system
In the MSGP, EPA has established specific discharge monitoring requirements for
paperboard mills, and landfills and land application sites (see Figure 9-3). These
requirements are in addition to the quarterly visual checks required for all MSGP-permitted
facilities.
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Section 9 Assessment Module for Woodyard, Papermaking, and Other Operations
Figure 9-3
Monitoring Requirements for Paperboard Mills and Landfill/
Land Application Sites
Facility/Pollutant
Monitoring Requirements
Landfills (and Land
Application Sites)/
Total Suspended
Solids (TSS)
In 2nd year of permit, conduct quarterly monitoring
Calculate average concentration for TSS — if > 100 mg/L, then conduct same quarterly
sampling in 4th year of permit
In 4th year of permit, also conduct quarterly TSS monitoring if landfill/land application
activities or SWPP plan have been altered such that the storm water discharges will be
adversely affected
Landfills (and Land
Application Sites)/
Total Recoverable
Iron
In 2nd year of permit coverage, conduct quarterly monitoring
Calculate average Total Recoverable Iron concentration — if > 1.0 mg/L, then conduct
same quarterly sampling in 4th year of permit
In 4th year of permit, also conduct quarterly Total Recoverable Iron monitoring if
landfill/land application activities or SWPP plan have been altered such that the storm
water discharges will be adversely affected
Paperboard
Mills/Chemical
Oxygen Demand
(COD)
In 2nd year of permit coverage, conduct quarterly monitoring
Calculate average COD — if > 120 mg/L, then conduct same quarterly sampling in 4th
year of permit
In 4th year of permit, also conduct quarterly COD monitoring if paperboard mill operations
or SWPP plan have been altered such that the storm water discharges will be adversely
affected
9.4.3 Storm Water Inspection Considerations
To evaluate compliance with basic storm water requirements, the inspector should:
! Review applicable records to assure that the SWPP is up to date and includes all
required elements, and that the mill has performed all required self-monitoring and
self-inspection procedures
! Evaluate the results of monitoring and inspection data to determine whether those
records indicate potential compliance concerns — if the data indicate potential
problems, follow up with mill personnel to determine what corrective actions, if
any, were taken in response to the monitoring/inspection results
! Observe control and prevention measures to evaluate whether good operation and
maintenance practices are being used
! Verify that the mill does not have improper connections that permit non-storm
water to be discharged from storm water outfalls
As a guide, the inspector should consider the example checklists included in EPA's
NPDES Compliance Inspection Manual (EPA 300-B-9-014). The lists identify
appropriate elements to cover in reviewing records and conducting visual observations of
control and prevention measures. The inspector should also consider the following in
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Assessment Module for Woodyard, Papermaking, and Other Operations Section 9
investigating the possibility of improper cross connections of storm water and process
wastewaters:5
Evaluate results of any testing of storm water outfalls for indicators of non-storm
water being discharged (such as results of pH testing)
Determine whether storm water outfalls continue to have discharges during periods
without rainfall
Observe the storm water outfalls for indications of possible non-storm water
discharges — is there discoloration, odor, residues, floatables, affected vegetation,
or structural damage such as peeling paint or corroded metal?
Interview plant personnel about floor drains, boiler blowdown waters, and non-
contact cooling waters - does the mill have documentation to show that these
sources are not connected to a storm water handling system?
Focus especially on older facilities/process units
9.5 RCRA Issues and Inspection Considerations
The woodyard operations,
papermaking, and other general mill
processes generate various
miscellaneous solid waste streams. regulations and basic assessment
Some of these wastes are hazardous, procedures
such as spent solvents from parts
NOTE! See Appendix C for detailed
overview of RCRA hazardous waste
degreasing. The inspector should
review the basic hazardous waste generator (and used oil) requirements and assessment
procedures outlined in Appendix C. A RCRA screening checklist is also included in
Appendix E.
In addition, non-hazardous solid waste discharges may be handled in on-site solid
waste landfills. Although the requirements for a landfill are highly State and source-
specific, the inspector should consider at least the following with respect to RCRA
compliance at these solid waste landfills:
! Verify that the mill properly excludes hazardous waste from the landfill -
document the waste streams that are landfilled on-site, and determine what methods
were used to characterize the waste and make the non-hazardous waste
determination
Check to make sure that only permissible wastes are received for disposal
Confirm that any required training, inspection and recordkeeping requirements are
up to date and meet State regulatory/permit requirements
Review any required monitoring data for evidence of potential contaminant leaks
from the landfill site. Sampling and contaminant limits may be outlined in the solid
waste permit
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Section 9 Assessment Module for Woodyard, Papermaking, and Other Operations
! Observe the landfill site to document any obvious problems with operation and
maintenance, and check for obvious signs of spills and improper unloading practices
! Leachate control and handling should be reviewed at unbleached kraft mills. If the
leachate is sent to the wastewater treatment plant or a stormwater outfall, consider
whether such handling is allowed under the mill's NPDES permit(s). Also identify
any requirements for leachate handling that are included in the solid waste permit
9.6 EPCRA Issues and Inspection Considerations
General concerns. The
basic regulatory requirements for
EPCRA are not process-specific but
rather apply on a facility-wide basis.
Thus the basic requirements of
EPCRA are discussed in Appendix
D. For the woodyard, papermaking, and other miscellaneous activities covered in this
Section 9, the key EPCRA issues will be to quantify releases of applicable listed toxic
chemicals in the Toxic Release Inventory (TRI) report (known as the "Form R" report). In
addition, spills of raw materials handled in these process areas, or air emissions from
papermaking operations, potentially could result in off-site releases that exceed applicable
reportable quantities that would require emergency notification under EPCRA and parallel
provisions of CERCLA.
NOTE! See Appendix D for overview of
EPCRA regulations and basic assessment
procedures.
Inspection considerations. The EPCRA compliance assessment generally will
focus initially on a records review. The inspector should review the following materials:
! Emergency preparedness information. These obligations are not process-specific,
and thus the basic assessment considerations are covered for all facility operations
in Appendix D to this manual.
! TRI Form R. Check to ensure that the form is on file and that the source has
adequately considered releases associated with these process areas. For
papermaking activities, EPA has prepared guidance to assist facilities with TRI
reporting.7 Also, ask to see the estimation technique being used. If the estimation
technique involves an assumed reduction efficiency for control methods, make sure
that the assumed efficiency is consistent with the overall efficiency that the mill is
achieving. The overall assumed efficiency should account for any excess
emission/discharge releases in a manner consistent with the actual percent of
operating time such releases occur. Uncontrolled emission/discharge episodes or
periods of reduced control efficiency can have a significant impact on the estimate
of total releases.
! Emergency notifications. Request documentation that the mill has filed all required
notices.
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Assessment Module for Woodyard, Papermaking, and Other Operations Section 9
If an air, water or RCRA inspector plans to screen for EPCRA compliance, the
inspector should confirm the necessary information with the facility contact during the
opening conference or just in advance of the closing conference. For an announced
inspection, the inspector should ask the source to have ready EPCRA-related
documentation so that this screening check can be performed without interrupting the main
focus of the inspection. A screening checklist is included as part of the example assessment
form in Appendix E.
In addition to a screening-type records review inspection, an EPCRA inspector may
want to conduct further assessments to identify potential compliance concerns with
emergency notification requirements. As one technique, the inspector first can check
general mill upset reports and citizen complaints since the previous inspection. The
inspector then should cross-check those incidents with notification records identified in
EPA's ERNS database, records on file with State/local emergency officials, or records
requested from the mill. If this type of investigation identifies episodes of abnormal
releases in which no notification was provided, the inspector should consider a follow-up
investigation to determine if reportable quantity thresholds were exceeded. For the process
areas covered by this section, significant accidental releases from raw material or waste
storage and handling would be the most likely areas of concern.
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Section 9 Assessment Module for Woodyard, Papermaking, and Other Operations
References:
1. Smook, G.A., Handbook for Pulp and Paper Technologists., Joint Textbook
Committee of the Paper Industry. TAPPI, 1982.
2. Kraft Pulp Mill Inspection Guide. Prepared for U. S. EPA under Contract No. 68-01 -
6310, Work Assignment No. 65, Pedco Environmental, Inc., Cincinnati, Ohio, January
1983.
3. Leatherwood, C. (Eastern Research Group, Inc.) to Lassiter, P. (U.S. EPA),
Memorandum re: Maximum Achievable Control Technology (MACT) Determination
for Papermaking Systems, September 10, 1997.
4. Buonicore, A.J and Davis, W.T., eds., Air Pollution Engineering Manual, Air and
Waste Management Association, 1992.
5. Proposed Technical Development Document for the Pulp, Paper and Paperboard
Category and Effluent Limitations Guidelines, Pretreatment Standards, and New
Source Performance Standards. U.S. Environmental Protection Agency, Washington,
D.C., October 1993.
6. Profile of the Pulp and Paper Industry (EPA/310-R-95-015), EPA Office of
Compliance Sector Notebook Project, U.S. Environmental Protection Agency,
September 1995.
7. Title III Section 313 Release Reporting Guidance — Estimating Chemical Releases
from Paper andPaperboadProduction, U.S. Environmental Protection Agency,
Office of Pesticides and Toxic Substances, EPA 560/4-88-004k, February 1988.
8. U.S. EPA Applicability Determination Index (ADI): Document Control #NR124.
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Chemical Recovery Assessments Section 5
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Overview
APPENDIX A: Clean Air
Act Regulatory Summary
Kraft pulp mills are subject to
a variety of different requirements
under the Clean Air Act (CAA), and state and local laws. These requirements are designed
to limit emissions of several different air pollutants. Most of those requirements will apply
separately to each specific point of emission, although some process-based or facility-based
limits may apply as well. For many of these emission limits, the regulations and permit-
specific requirements will establish associated monitoring, reporting and recordkeeping
(MRR) requirements to provide an assurance of ongoing compliance with the emission
limits. This appendix first outlines the basic elements of the air program and then
summarizes how the air program affects kraft pulp mills.
Outline of Regulatory Programs
National Ambient Air Quality Standards
The CAA is designed to protect
Primary NAAQS Impacts Related to
Kraft Pulp Mills:
Particulate Matter
Ozone (Emissions of VOC and NOX)
SO
2
the public health and welfare. The
centerpiece of the CAA are the national
ambient air quality standards (NAAQS)
that have been established for six
"criteria" pollutants: carbon monoxide,
lead, nitrogen dioxide, particulate
matter, ozone and sulfur dioxide.
Areas that meet the NAAQS are called
"attainment" areas: those that do not, are called "nonattainment" areas. Each State,
through a State implementation plan (SIP), is responsible for developing strategies to
achieve attainment within the State.
SIPs
A SIP will include all of the elements of a State's strategy to attain the NAAQS,
including emission limits, permitting requirements, mobile source restrictions and so on.
The EPA approves the SIP. If EPA finds that a SIP fails to adequately achieve attainment,
EPA can issue a "SIP Call" to the affected State(s) to correct the deficiency and can
impose direct federal requirements (a federal implementation plan or "FIP") if the SIP
remains inadequate. The basic federal requirements for a SIP are set forth in 40 CFR Part
51.
Not all emission limit requirements established by a State will be part of a SIP -
only those designed to attain the NAAQS. Thus, requirements designed to solve local
problems -such as general nuisance, odor, open burning and air toxic regulations - often
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Appendix A CAA Regulatory Summary
are not included within a SIP. This distinction is important for compliance assessment
purposes because the State requirements that are included in the SIP are federally-
enforceable while State-only requirements are enforced only by the State agencies
(including implementing local agencies if applicable).
A required element of each SIP will be a process for reviewing, prior to
construction, any new or modified source of air pollution to assure that the emissions from
that source will not interfere with the State's implementation strategy or cause an
exceedance of the NAAQS. These programs are generally referred to as "New Source
Review" (NSR). As explained below, special NSR requirements apply to certain "major"
sources.
Another common element of
a SIP are emission limitations and
standards. These limits will generally
be structured in three different ways:
Noncategorical limits
Source category-specific
Source-specific limits
Primary SIP Requirements
Related to Kraft Pulp Mills:
Visible emission regulations
Sulfur-in-fuel limits
PM/SO2 mass emission limits
hmits ' NOX RACT/NOX regional ozone
transport reduction strategies
Specific pulp mill standards
Noncategorical limits apply
to all sources of particular types of
pollutants, although States will often treat combustion units and process units separately.
For most States, the limits will at least cover paniculate matter and SO2 emissions.
Requirements for other pollutants often either apply more narrowly to specific types of
sources or are otherwise more limited in scope. For paniculate matter, the two most
common types of standards will be generic opacity standards (expressed as percent
opacity) and mass emission limits (expressed usually as allowable weight of total suspended
particulates (TSP) per million Btu of heat input or allowable TSP concentration per weight
or volume of stack gas emitted). For SO2, mass emission limits often will be expressed on
a Ib/hour or Ib/million Btu basis, and specific limits on the sulfur content of fuel for
combustion sources also will apply in most States.
Categorical limits are standards established for specific industries that will apply in
addition to the general, non-categorical emission limits. Many of the States with operating
kraft pulp mills have adopted these types of standards, especially for TRS emissions, but
also for particulate matter and SO2 in some States as well. However, as noted above,
control of odorous emissions, such as TRS, is generally not considered SIP-related. Thus,
State emission limits for TRS emissions from kraft pulp mills likely will not be considered
part of a State's SIP.
The third type of limit that may apply is a site-specific emission limit directly
adopted into a SIP. These limits generally are used where a source has a significant impact
on attainment, including situations where the source by itself can cause a particular area
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CAA Regulatory Summary Appendix A
within a State to be classified as nonattainment. Because these limits are site-specific, any
such limits that apply to kraft pulp mills are not addressed or summarized in this manual.
An additional SIP consideration is the control of ozone precursors for ozone
attainment purposes. Prior to the 1990 amendments to the Clean Air Act, ozone
attainment strategies focused on controlling emissions of volatile organic compounds
(VOC). The 1990 amendments generally required that States with ozone nonattainment
areas modify their control strategies to include nitrogen oxide (NOX) emission controls in
addition to VOC controls. Therefore, since the 1990 amendments, many States with ozone
nonattainment areas have developed NOX limits for existing sources, especially combustion
sources. These standards are generally based on "reasonably available control technology"
(RACT). Some areas of the country, most notably the Mid-Atlantic/Northeast region,
have developed emission trading programs as a least-cost compliance tool for achieving
NOX emission reductions beyond the RACT levels of control. To address regional NOX
transport, EPA is currently considering additional NOX reductions for a 22-State region in
the eastern U.S., including States that currently are in attainment with the ozone standards.
Because of the significant on-site power generation and other combustion sources at a pulp
mill, State NOX requirements may apply to pulp mills in those States that have ozone
nonattainment areas or that are affected by EPA's regional transport initiatives.
Finally, although technically not part of a SIP, under section lll(d) of the CAA,
States are required to submit regulations for existing sources of certain non-criteria
pollutants that are regulated under the New Source Performance Standards (NSPS). One
such pollutant, TRS, is emitted from kraft pulp mills. Many States with kraft pulp mills
have TRS regulations that have been approved under section 11 l(d). Other States have
adopted TRS regulations that are not considered section 11 l(d) regulations, but are
considered as State-only requirements. This distinction is important for compliance
assessment purposes because only the section 11 l(d) requirements will be federally
enforceable.
New/Modified Sources
Each State must have an NSR procedure in place as part of a SIP. In addition, for
new major sources (or modifications to a major source that result in a significant emission
increase), EPA requires more specific elements for an NSR program. These requirements
vary depending on whether the source is located in an attainment or nonattainment area for
the pollutant(s) that trigger NSR review.
! In attainment areas., major NSR involves a strategy to prevent significant
deterioration (PSD) of air quality. The PSD NSR program involves pre-
construction permitting in which the source must demonstrate that the project will
not cause a violation of the NAAQS or PSD increments (air quality concentrations
established to keep clean air clean). For projects located near designated "Class 1"
areas (e.g.. national parks), the source must also document that the project will not
interfere with certain air quality related values such as visibility. Finally, the PSD
permit must establish an emission limit that reflects the use of "best available
control technology" (BACT) at the new/modified source.
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Appendix A
CAA Regulatory Summary
Primary NSPS/NSR Requirements
Related to Kraft Pulp Mills:
NSPS Subpart BB standards for kraft
pulp mill process units
NSPS Subparts D, Db, DC standards
for power boilers
Minor and Major NSR permitting
requirements (primarily SO2, NOX and
PM)
Additional controls mandated by the
Cluster Rules could potentially increase
SO2 emissions and trigger major NSR
permitting for some mills
! In nonattainment areas, major NSR focuses on assuring that the source achieves
the lowest achievable emission rate (LAER) and obtains emission offsets so that the
nonattainment problem is not made worse by the addition of the new/modified
source.
In addition to these permit-
based requirements, EPA has
promulgated new source
performance standards (NSPS) for
many types of new/modified
industrial sources. The NSPS apply
to specific units at various source
categories (such as lime kilns and
recovery furnaces at kraft pulp mills,
fuel gas combustion devices at
petroleum refineries, etc.). The
standards are based on the best
available technology (BAT), taking
environmental, energy and economic
factors into account, that has been
commercially demonstrated. The
NSPS apply to all facilities
constructed/modified after the date the NSPS is proposed in the Federal Register. The
NSPS act as a floor in the context of NSR permitting (i.e., BACT, LAER or minor source
NSR requirements must be at least as stringent as an applicable NSPS). The EPA has
established NSPS requirements (summarized in Sections 4 and 5 of the manual) that are
applicable to several process units at kraft pulp mills that are constructed/modified on or
after September 24, 1976. In addition, the NSPS establish a number of requirements
applicable to steam and power generating facilities (summarized in Section 8 of the
manual).
Hazardous Air Pollutants
NESHAP/MACT standards. Under section 112 of the CAA, EPA is authorized
to regulate hazardous air pollutants. These requirements are separate from control
requirements designed to achieve attainment with the NAAQS. Prior to the 1990
amendments, EPA promulgated relatively few standards (called National Emission
Standards for Hazardous Air Pollutants or "NESHAP") for these pollutants. Prior to the
1990 amendments, the stringency of a NESHAP emission limit was based on health risk
considerations — not available technology. The 1990 amendments required EPA to
establish NESHAP generally on "maximum available control technology" (MACT), with a
subsequent review of the residual risk from a source category after implementation of the
MACT requirements.
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Appendix A
Under the pre-1990
NESHAP standards, EPA has not
promulgated any standards
specifically applicable to kraft pulp
mills. However, two standards —
Subpart M (asbestos) and Subpart
E (mercury) may apply. The
asbestos NESHAP will apply to any
demolition or renovation activity at
a mill that will disturb a significant
amount of asbestos-containing
material. The mercury NESHAP
applies to any sludge dryers or
incinerators used to treat industrial
wastewater treatment sludges.
Primary HAP/Other CAA Requirements
Related to Kraft Pulp Mills:
! The Cluster Rules MACT Standards
(Pulping and Bleaching)
! Proposed MACT Standards (Chemical
Recovery)
! Asbestos NESHAP (Demolition and
Renovation Activities)
! Mercury NESHAP (Sludge
Incinerators/Dryers)
! Section 112(r) Risk Management Plans
! Section lll(d) and State-only TRS
rules
Under the post-1990 MACT
standards, EPA has promulgated a number of standards, including requirements for pulp
mill pulping and bleaching operations as part of the Cluster Rules (see 63 FR 18503, April
15, 1998). At the same time, EPA proposed MACT requirements for pulp mill chemical
recovery operations (see 63 FR 18753).
In addition to federal hazardous air pollutant standards, some States have
developed their own air toxics regulations. Some of these may apply to kraft pulp mills,
including State rules applicable to bleaching operations (see Section 6).
Risk management plans.
Another requirement based on the
1990 Clean Air Act Amendments is
the requirement to develop and
maintain a Risk Management Plan
(RMP) under section 112(r) of the
Act. The EPA has promulgated regulatory criteria and procedures applicable to RMPs at
40 CFR Part 68. Under those regulations, kraft pulp facilities in SIC Code 2611 are
subject to the most stringent RMP requirements (so-called "Program 3" requirements).
The main elements of the RMP include:
NOTE! See http:7www.epa.gov/swercepp
for EPA guidance on section 112(r) RMP
compliance.
An executive summary
A registration form with basic facility, contact and other pertinent data
Offsite consequence analyses based on worst-case scenarios for all regulated toxic
and flammable substances
A five-year accident history
A prevention program. The program must include process safety information (for
each process, safety-related data pertaining to: the hazards of the regulated
substances used, the technology used, and the equipment used). The program must
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also include information on process hazard analyses (PHAs) conducted by the mill,
compliance audits, and other internal checking measures
! An emergency response program, including information on the emergency response
plan developed by the mill and emergency response training for employees
Because mills are subject to the Program 3 requirements, additional prevention program
requirements apply, including:
! Written operating procedures that provide clear instructions for operating all
processes safely
! Initial and refresher safety and health hazards training for all employees involved
with process operations
! Mechanical integrity requirements for critical process equipment (including written
operating procedures, training requirements, inspection and testing requirements,
and corrective action and quality assurance obligations)
! Procedures for addressing new safety and health issues as part of changes in
operations (including changes to process chemicals, equipment, technology or
procedures)
! Pre-startup review of safety and health issues
! Compliance audits for compliance with RMP requirements at least every 3 years
! Incident investigation procedures for any incidents that did involve or could have
involved a catastrophic release of a regulated substance
Compliance with the RMP requirements may be delegated by the State air
permitting agency to a separate State or local agency — most air agencies will likely
delegate implementation of the RMP program to State or local agencies directly involved
with emergency response issues. For all sources, the delegated agency must verify that the
required RMP has been registered and submitted, and that the source has submitted either a
compliance certification or a compliance schedule related to RMP requirements. Also, for
at least some of the sources, each delegated agency must use a procedure such as a
completeness check, source audit, record review or source inspection to ensure that
sources are in compliance. Where deficiencies in an RMP are found, the regulations allow
the agency to issue a preliminary determination of what changes are necessary, followed by
an opportunity for the source to respond and suggest alternative changes, and then a final
determination by the agency as to what changes are necessary.
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CAA Regulatory Summary
Appendix A
Title V Permitting
Prior to the 1990 amendments
to the CAA, there was no federal
requirement for a source to obtain
and maintain an air operating permit.
Title V of the 1990 amendments
established a requirement for an air
program operating permit similar to
the NPDES permit required under the
Clean Water Act. The concept of the
permit is to consolidate all applicable
requirements into a single document
and to clarify (and potentially
streamline) requirements that are
vague or overlapping. Because of
their size, all kraft pulp mills will have
to obtain Title V operating permits.
Primary Title V Requirements
Related to Kraft Pulp Mills:
! Consolidate applicable requirements in
a single permit
! Application will include emission and
control device information, as well as
general process information
! Periodic monitoring and compliance
assurance monitoring requirements
may impose new monitoring
requirements on various emissions
units, especially units subject to
particulate matter limits
One area of Title V permitting that is likely to affect kraft pulp mills is the periodic
and compliance assurance monitoring requirements that are being implemented through the
permitting process. These requirements may add monitoring requirements for many kraft
pulp mill units — especially for circumstances (e.g., smaller controlled units) where no
on-going monitoring may have been conducted in the past. For these units, a mill will
likely have to develop some form of control device parameter monitoring with established
parameter excursion levels established for reporting purposes.
Title VI Stratospheric Ozone Protection
Title VI of the Act establishes
certain restrictions on the
manufacture, use and disposal of
ozone-depleting substances, including
chlorofluorocarbons (CFCs). Among
other aspects of this program, section
608 of the Act establishes a
comprehensive program to limit
emissions of CFCs and other ozone-
depleting substances during the maintenance, service, repair, and disposal of air
conditioning and refrigeration equipment that contains these materials. EPA's implementing
regulations impose technician certification and technician work practice requirements. The
regulations also establish equipment and reclaimer certification programs, and disposal
restrictions. Finally, for owners of covered equipment, there are leak repair requirements
as well. This last requirement is the key element for kraft pulp mills that may operate
industrial process refrigeration units, such as chillers for chlorine dioxide plants.
Primary Title VI Requirements
Related to Kraft Pulp Mills:
! Leak repair obligations for industrial
process refrigeration units (e.g.,
chlorine dioxide plant chillers)
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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APPENDIX B: Clean
Water Act Regulatory
Summary
Overview
The Clean Water Act (CWA)
gives EPA the responsibility and
authority to regulate most forms of
water pollution in the United States and its Territories. Discharges of pollutants into the
nation's waters are regulated by several CWA programs, including the National Pollutant
Discharge Elimination System's (NPDES) permitting program for point-source discharges,
the storm water permitting program (a sub-category of NPDES) for all storm water
discharges from point sources, and a pretreatment program which establishes pretreatment
standards for discharges by industrial users into Publicly Owned Treatment Works
(POTWs). The EPA has developed specific requirements for kraft pulp manufacturing
operations as described below.
NPDES Permitting
The NPDES permitting program, outlined primarily in 40 CFR Part 122, establishes
permitting requirements for the discharge of pollutants from point sources into waters of
the United States. The scope of the NPDES program is quite broad, and as a practical
matter most point source discharges associated with the pulp and paper industry will be
subject to NPDES permitting requirements. The program is administered either by EPA or
the State in which a facility is located. EPA may authorize a State to administer the
NPDES permitting program upon a showing that the State's program is at least as strict as
the federal program, and that the State has adequate legal authority to implement and
enforce the NPDES program. The vast majority of States now have federally approved
NPDES permitting programs.
NPDES permits typically incorporate five components:
! Technology-based effluent limitations
! Water quality-based effluent limitations
! Monitoring and reporting requirements
! Standard conditions applicable to all permittees
! Special conditions developed on a site-specific basis by the permitting authority
Technology-based effluent limitations are defined by industry-specific guidelines
contained in the Code of Federal Regulations, and are designed to reflect actual production
(if mass-based) at a facility. The pulp and paper regulations [40 CFR 430] provide specific
definitions of production; see Section 7.3.4.
Types of pollutants limited by the technology-based standards include "toxic
pollutants" listed in 40 CFR 401.15, "conventional pollutants" (BOD5, TSS, pH, fecal
coliform, and oil and grease), and "nonconventional pollutants" (pollutants that are neither
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Appendix B
CWA Regulatory Summary
toxic nor conventional). Potential pollutants of concern for kraft pulp mills as reflected in
the effluent limitations guidelines and standards promulgated by EPA and in a sampling of
NPDES permits, are summarized in Figure B-l.
Figure B-l
Regulated Pollutant Parameters for Kraft Pulp Facilities
Effluent Guidelines/
Standards
BOD5
TSS
pH
Pentachlorphenol
Trichlorophenol
AOX
Chloroform
2, 3, 7, 8-TCDD
2, 3, 7, 8-TCDF
Chlorinated phenols (12
pollutants)
Other Potential Permit-
Specific Parameters
Total cadmium
Total mercury
Total silver
Total zinc
Total copper
Lead
Mercury
Temperature and thermal load
Dissolved oxygen
Total phosphorous
Ammonia
Aluminum
Color
COD
Guides to the technology-based standards and their application are contained in
Figures B-2 and B-3. See Sections 6 and 7 of this manual for a discussion of the relevant
effluent limitations guidelines and standards established for kraft pulp mills.
Water quality-based effluent limitations (WQBELs) apply in situations where
the technology-based standards are insufficient to protect water quality. All receiving
waters have ambient water quality standards which are established by the States or EPA in
accordance with federal regulations to maintain and protect designated uses of the
receiving water (e.g.. aquatic life-warm water habitat, public water supply, and primary
contact recreation). States can use the total maximum daily load (TMDL) process to
quantify the allowable pollutant loadings in receiving waters, based on the relationship
between pollution sources and in-stream water quality standards.
Some permitting authorities may find that the application of the technology-based
effluent limitations guidelines result in pollutant discharges that still cause exceedances of
the water quality standards in particular receiving waters. In such cases, permitting
authorities are required to develop more stringent WQBELs for the pollutant to ensure that
the water quality standards are met. For a description of how water quality standards are
developed and incorporated into permits, refer to Guidance for Water Quality-Based
Decisions: The TMDL Process (EPA 440/4-91-001) and Technical Support Document for
Water Quality-Based Toxics Control (EPA/505/2-90-001).
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Appendix B
Figure B-2
Technology-Based Regulations: A Guide to the Acronyms
BPT = "Best Practical Control Technology Currently Available," a baseline standard, applicable
in all circumstances to all pollutants.
BCT = "Best Conventional Pollutant Control Technology," potentially more stringent limitations
for conventional pollutants than BPT. Only applies if certain cost tests are met. Must be
"cost-reasonable." See 51 Fed. Reg. 24,974, 24,976 (July 9, 1986), for EPA's BCT
methodology.
BAT = "Best Available Technology Economically Achievable," a "best of the best" standard for
toxic and non-conventional pollutants.
NSPS = "New Source Performance Standards," a standard at least as stringent as BAT, applicable
to new sources, as defined in 40 CFR 122.2.
PSES = "Pretreatment Standards for Existing Sources," industry-by-industry pretreatment
standards, existing sources.
PSNS = "Pretreatment Standards for New Sources," industry-by-industry pretreatment standards,
new sources.
Figure B-3
A Guide to Technology-Based Limitations For Regulated Discharges
Discharger
existing sources
existing sources
new sources
existing sources
new sources
Type of Discharge
conventional pollutants
toxic and nonconventional
pollutants
all pollutants
all pollutants determined to
"pass-through" or interfere
with POTWs
all pollutants determined to
"pass-through" or interfere
with POTWs
Direct Receiver
surface waters
surface waters
surface waters
POTW
POTW
Required Standard
BPT or BCT
BAT
NSPS
PSES
PSNS
Regulatory Source: 40 CFR 125.3
Other NPDES permit conditions will also apply to reflect the general conditions
in 40 CFR 122.41. Those general conditions address matters such as:
! Monitoring and reporting
! The duty to mitigate adverse effects of discharges
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Appendix B CWA Regulatory Summary
! The permitting authority's right to conduct on-site inspections
! The permittee's duty of compliance (where applicable) with other environmental
protection laws
All permittees are also subject to the "bypass" and "upset" provisions of the
regulations. "Bypass," or the intentional diversion of waste streams from a treatment
facility, is prohibited, except where no feasible alternative exists and it is necessary to
preserve life or property. "Upset," or unintentional and temporary noncompliance with
technology-based permit effluent limits due to factors beyond the permittee's control, may
operate as an affirmative defense to permit violations in appropriate cases, as detailed in the
regulations.
With regard to monitoring and reporting, NPDES regulations impose self-
monitoring requirements on all permittees. Under the Cluster Rules, some monitoring is
required within the spent pulping liquor and bleach plant process areas; see Sections 4.6, 6
and 7 of this manual for further discussion. In addition to monitoring levels of pollutants
covered by the effluent limitations, paper and pulp facilities typically are required by permit
condition to conduct additional monitoring, such as flow monitoring, outfall observations,
and whole effluent toxicity (wet) testing. Other similar permit-specific requirements could
include, for example, developing a Dioxin Minimization Program (DMP), or a Program for
Effective Residuals Management (PERM).
Monitoring must be carried out using those methods specified in 40 CFR Part 136,
or as otherwise required by the permit and must be reported on a standardized Discharge
Monitoring Report (DMR) form. A mill must submit DMRs at intervals stated in the
permit, but in no case less than once per year. Permittees are subject to a host of other
reporting requirements as well, which generally cover any change or anticipated change in
the facility or nature or level of pollutant discharge, as more fully outlined in 40 CFR
122.41(1).
Pretreatment Programs
The general NPDES program described above is aimed at controlling the direct
discharge of pollutants into the nation's waters. To address the indirect discharge of
pollutants through POTWs, CWA section 307(b)(l) directs EPA to develop pretreatment
standards for pollutants that interfere with the operation of a POTW, or pass through the
POTW in quantities or concentrations that will violate the limitations contained in the
POTW's NPDES permit.
To carry out this mandate, EPA has developed pretreatment standards. The
standards consist of both general standards applicable to all industrial users of POTWs, and
industry-specific categorical standards (covering the pulp and paper industry, among
others), expressed as quantities or concentration limits of pollutants dischargeable to a
POTW. The categorical pretreatment standards applicable to paper and pulp facilities are
contained in 40 CFR Part 430, and are listed by industry subcategory and type of facility
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CWA Regulatory Summary Appendix B
(new or existing). New sources of pollutant discharges subject to pretreatment are
addressed by "Pretreatment Standards for New Sources (PSNS)," while discharges from
existing sources are addressed by "Pretreatment Standards for Existing Sources (PSES)."
Although the categorical standards in Part 430 cover kraft pulp mills, most kraft pulp mills
are direct dischargers subject to NPDES permit requirements and not the pretreatment
standards.
Pursuant to the pretreatment regulations, most (if not all) POTWs receiving effluent
from kraft mills are required to develop pretreatment plans and submit those plans to EPA
or the State (if the State has been authorized to administer its pretreatment programs) for
approval. If approval is granted, those POTWs are then required to develop local limits to
implement EPA's general and categorical standards. The pretreatment requirements
become part of the POTWs NPDES permit. Non-approved POTWs are only required to
develop local limits if a prohibited pass-through or interference event has occurred.
Because local limits will vary, this summary only highlights the national standards
developed by EPA.
Approved POTWs may in turn issue "individual control mechanisms" to each
industrial user of the POTW. Individual control mechanisms set out all effluent limitations
and standards, monitoring and reporting requirements, compliance schedules, and other
regulatory requirements. The POTW is the "Control Authority" for purposes of ensuring
industrial user compliance with applicable pretreatment standards.
EPA-promulgated general standards that prohibit all pass-through and interference,
and impose specific prohibitions against the following discharges of pollutants into
POTWs:
! Pollutants which create a fire or explosion hazard in the POTW including, but not
limited to, wastestreams with a closed cup flashpoint of less than 140 degrees
Fahrenheit or 60 degrees Centigrade using the test methods specified in 40 CFR
261.21
! Pollutants which will cause corrosive structural damage to the POTW, but in no
case discharges with pH lower than 5.0, unless the works is specifically designed to
accommodate such discharges
! Solid or viscous pollutants in amounts which will cause obstruction to the flow in
the POTW resulting in interference
! Any pollutant, including oxygen demanding pollutants (BOD, etc.) released in a
discharge at a flow rate and/or pollutant concentration which will cause interference
with the POTW
! Heat in amounts which will inhibit biological activity in the POTW resulting in
interference, but in no case heat in such quantities that the temperature at the
POTW treatment plant exceeds 40 degrees Centigrade (104 degrees Fahrenheit)
unless the Approval Authority, upon request of the POTW, approves alternate
temperature limits
! Petroleum oil, nonbiodegradable cutting oil, or products of mineral oil origin in
amounts that will cause interference or pass through
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Appendix B CWA Regulatory Summary
! Pollutants which result in the presence of toxic gases, vapors, or fumes within the
POTW in a quantity that may cause acute worker health and safety problems
! Any trucked or hauled pollutants, except at discharge points designated by the
POTW
The pretreatment regulations prohibit the use of dilution as a substitute for meeting
pretreatment requirements. At the same time, however, many industries generate regulated
wastewaters which are combined with unregulated wastewaters, or wastewaters subject to
a separate categorical standard, and this combination necessarily dilutes the discharge. To
address this reality, EPA has developed a "combined waste stream formula," contained in
40 CFR 403.6(e)(l), which must be applied to mixed effluent as a substitute for application
of the categorical standards. The formula may be used to establish alternative
concentration limits or alternative mass limits, but may not be applied if the alternative limit
generated is below the analytical detection limit for the regulated pollutant.
Within 180 days after the effective date of applicable categorical standards, facilities
subject to those standards must submit a certified baseline monitoring report to the Control
Authority (the POTW, if an approved pretreatment program is in place). Along with
general information about the facility and its operations, that report must include the results
of flow measurements and sampling and analysis of pollutants, and a compliance schedule
where additional pretreatment measures and/or O&M are required. Additionally, facilities
subject to pretreatment standards must submit regular compliance reports and notify the
Control Authority of any potential problems, changes in discharges, or violations.
Facilities must also notify the POTW, EPA, and State hazardous waste authorities in the
event that hazardous wastes are discharged to the POTW. Reporting requirements and
applicable time deadlines are summarized in Figure B-4. Monitoring records must be kept
for at least three years, and must be made available for inspection by regulatory authorities
upon request.
With EPA approval, the categorical standards applicable to industrial users of
POTWs, discussed above, may be modified by the award of "removal credits" reflecting the
pollutant removal levels consistently achieved by the POTW; by way of a "fundamentally
different factors variance" which takes into account facility-specific concerns not reflected
in the categorical standards; or by application of a "net/gross calculation" which adjusts the
standards to account for the presence of pollutants in the industrial user's intake water, but
only if the pollutant is listed in 40 CFR Subchapter N. EPA is considering changing this
provision to allow industrial users to obtain removal credits for other pollutants upon a
showing that there would be no adverse effect on the public health or the environment from
the concentration or quantity of the pollutant to be found in sludge if a removal credit is
granted.
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CWA Regulatory Summary
Appendix B
Figure B-4
Permittee Reporting Requirements
Type of Activity
Planned physical alterations or additions
to permitted facility which have potential
to significantly increase pollutant discharges or
significantly alter sludge use/disposal practices, or
which may subject facility to NSPS
Anticipated noncompliance
Transfer of permit
Compliance/noncompliance schedule reporting (per
permit)
Unanticipated bypass
Upset exceeding permit effluent
limitation
Violation of maximum daily discharge
limitations for pollutants identified in permit as
requiring 24-hour reporting
Monitoring reports (DMRs)
Other noncompliance not covered by monitoring
reports, compliance schedule reporting, or 24-hour
reporting requirements
Reporting Deadline
As soon as possible
In advance of event
In advance of event
Within 14 days after each schedule date
Within 24 hours of becoming aware of problem
Within 24 hours of exceedance
Within 24 hours of violation
As required by permit, but in no case less than once
per year, or as provided in 40 CFR Part 503 (for
sewage sludge)
Along with monitoring reports
Permitting for Storm Water
As the result of 1987 amendments to the CWA, including the enactment of CWA
section 402(p), the NPDES program now includes a separate section addressing storm
water discharges. As with the NPDES program generally, EPA has authorized many
States to issue permits for storm water.
Storm water permit application rules are published at 40 CFR 122.26. Because
EPA administers the NPDES permitting program in a few remaining jurisdictions
(including some States, U.S. territories, and Indian country), the Agency has published
general permits for storm water in the Federal Register. For purposes of coverage under
the program, "storm water" subject to regulation is defined as "storm water runoff, snow
melt runoff, and surface runoff and drainage." Storm water discharge "associated with
industrial activity" is defined as "the discharge from any conveyance which is used for
collecting and conveying storm water and which is directly related to manufacturing,
processing or raw materials storage areas at an industrial plant." To further clarify
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Appendix B CWA Regulatory Summary
industrial coverage, the regulations provide a list of eleven industrial categories subject to
storm water permitting requirements. That list defines covered industries by SIC codes
and/or narrative descriptions of activity, and includes all of SIC 26—paper and allied
products, except paperboard containers and products.
Pulp and paper facilities currently have two options for obtaining storm water
permit coverage in locations in which EPA acts as the permitting authority: the individual
(facility-specific) permit, or coverage under the "multi-sector general permit (MSGP),"
developed for the industry sector as a whole. The MSGP, published at 60 FR 50804
(September 29, 1995) and recently amended at 63 FR 52430 (September 30, 1998),
incorporates basic requirements applicable to all industry groups, including monitoring,
reporting, and pollution prevention plan requirements. Development of a storm water
pollution prevention (SWPP) plan, a central feature of storm water permitting, involves:
! Formation of a team of qualified plant personnel who will be responsible for plan
preparation and implementation
! Assessment and description of potential storm water pollution sources (including
drainage maps, inventory of exposed materials, 3 year history of significant spills
and leaks, certification of testing for non-storm water discharges, sampling data,
and a summary of potential pollution sources)
! Selection and implementation of appropriate pollution prevention measures, best
management practices (BMPs) and other controls (including good housekeeping,
preventive maintenance, spill prevention and response procedures, inspections,
employee training, internal recordkeeping/reporting procedures, sediment and
erosion control, and runoff management)
! Periodic comprehensive site compliance evaluation and subsequent SWPP plan
modification
The MSGP establishes special requirements (including general permit eligibility
restrictions) for storm water discharges that:
! Affect a property that is listed or is eligible for listing on the National Registry of
Historic Places
! Are subject to CWA New Source Performance Standards (NSPS)
! Mix with non-storm water
! Contain hazardous substances or oil in excess of reporting requirements established
under 40 CFR Parts 117 or 302 during any 24-hours period
Discharge into large and medium municipal separate storm sewer systems
Are subject to Toxic Release Inventory (TRI) reporting requirements in section 313
of the Emergency Planning and Community-Right-To-Know Act (EPCRA)
! Store salt
The MSGP requirements that are specific to paper and pulp facilities identify BMPs
for the pulp and paper sector, and establish special monitoring and reporting requirements
for chemical oxygen demand (COD) for paperboard mills. In addition, because different
types of storm water discharges are covered under the structure of the NPDES permitting
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CWA Regulatory Summary Appendix B
program for storm water, MSGP coverage is available for each of the types of covered
sectors that are co-located at a facility. Thus, MSGP requirements for landfills/land
application sites and steam electric generating facilities are potentially applicable to kraft
pulp mills. The MSGP also includes a separate sector for sewage treatment works.
Although not directly applicable to industrial wastewater treatment facilities, the BMPs
designed for sewage treatment are relevant for wastewater treatment operations at kraft
pulp mills. The recommended BMPs established by EPA are discussed in Sections 7
through 9 of this manual, as applicable to each process area.
The MSGP requirements generally provide that all facilities conduct visual
examinations of storm water quality at each outfall and, in some cases, by the grab sample
method collected within thirty minutes of the first storm water runoff discharge. This
visual examination must take place at least once per quarter, and should be conducted in a
well-lit area by a member of the pollution prevention team (preferably the same person
each time). Reports of this visual examination must be maintained on site with the facility's
pollution prevention plan. If samples cannot be collected over the entire course of the
quarter due to extreme weather, this fact must be documented. In addition to this basic
monitoring, the MSGP establishes additional analytical or chemical monitoring
requirements for certain activities in some sectors (such as paperboard mills within the
overall paper and allied products sector).
Limits on Oil Discharges
The CWA establishes specific requirements to limit discharges of oil to receiving
waters. These requirements may be applicable to certain kraft pulp mills that operate oil-
fired boilers. The basic structure of these requirements is as follows:
! Section 110 of the CWA prohibits discharges of oil that violate applicable water
quality standards, cause a film or sheen upon (or a discoloration of) the surface of
the water or the adjoining shoreline, or cause a sludge or emulsion to be deposited
beneath the surface of the water or on the adjoining shoreline. If a prohibited
discharge occurs, then the owner or operator must provide immediate notification
to the National Response Center.
! Section 112 requires a Spill Prevention Control and Countermeasure (SPCC) plan
for oil-storing/consuming facilities, except where underground storage is < 42,000
gallons and unburied storage is < 13,20 gallons (with no single container > 660
gallons). In addition to developing the plan, section 1 12 imposes reporting
requirements, a duty to provide plan updates, and training obligations.
! Sections 116 and 117 designate hazardous substances and reportable quantities
(RQs) for those substances. Except for allowable discharges to a POTW or under
an NPDES permit, discharges of a designated substance in excess of the applicable
RQ must be reported to the federal government in accordance with applicable
Department of Transportation regulations.
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Appendix B CWA Regulatory Summary
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APPENDIX C: RCRA
Regulatory and Assessment
Procedures Overview
Overview
Subtitle C of the Resource
Conservation and Recovery Act
(RCRA), 42 USC 6901 et seq..
establishes a comprehensive "cradle-to-grave" regulatory program for hazardous waste
management. The program is directed by EPA and implemented in part by authorized
States. Federal regulations relevant to the hazardous waste program, contained in 40 CFR
Parts 260-281, address hazardous waste management by generators, transporters, and the
treatment, storage, and disposal facilities (TSDFs) that ultimately receive hazardous
wastes. Generators who treat hazardous wastes on site may be subject to both generator
and TSDF regulations. Because kraft pulp facilities typically ship all hazardous wastes off
site for disposal, however, this overview focuses on generator requirements. Subtitle I of
RCRA governs underground storage tanks. Because various processes at a pulp mill may
have underground storage tanks covered by this part of RCRA, these requirements are also
addressed in this Appendix rather than in a process-specific chapter of the manual. Subtitle
D of RCRA establishes requirements for non-hazardous solid wastes. These requirements
are not discussed in this Appendix, but are discussed briefly in Section 9 of the manual in
the context of on-site solid waste landfills that may be used at a kraft pulp mill. Finally, on-
site remediation efforts or other corrective action subject to RCRA are not discussed,
although particular mills may be engaged in such activities. Figure C-l provides a quick
guide to the RCRA statutory and regulatory scheme.
In addition to providing a brief Tvi/^Tr. ^u- A ,1- -^ u • r
1 • mr^n A i- NOTE! This Appendix provides a brief
general overview of RCRA, this n^n» • , ,..,
° .. .. • . u .1 RCRA overview only ~ consult the
Appendix is designed to assist both
regulations for specific requirements that
apply. Also contact the RCRA Hotline —
1-800-424-9346 - for further information.
agency and plant personnel in
conducting RCRA compliance
assessments at kraft pulp mill facilities.
The primary assessment tools discussed
include record reviews, personnel
interviews, and visual inspection of the facility. RCRA requirements and compliance
assessment techniques are discussed separately from the process-specific sections of the
Manual (Sections 6 through 12), because RCRA issues at kraft pulp mills generally are not
highly process-specific. However, as in the main part of the manual, this Appendix does
not attempt to cover assessment issues related to topics such as enforcement, inspector
responsibilities and authority, and inspector health and safety concerns. Agency inspectors
seeking guidance on such issues may wish to consult EPA's RCRA Inspection Manual,1 or
similar resources. The References section at the end of this Appendix lists several
resources for obtaining additional information about RCRA issues.
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Appendix C
RCRA Summary
Figure C-l
RCRA Title II Statutory and Regulatory Structure
Subtitle C
Hazardous Waste
Management
40 CFR Part 261 Hazardous Waste Identification
40 CFR Part 262 Hazardous Waste Generators
40 CFR Part 263 Hazardous Waste Transportation
40 CFR Part 264-265 Treatment, Storage, Disposal
40 CFR Part 266 Specific Hazardous Wastes/Specific
Hazardous Waste Management Facilities (Subpart
H-Boilers/Industrial Furnaces)
40 CFR Part 268 Land Disposal Restrictions
40 CFR Part 270 RCRA Permit Program
40 CFR Part 279 Used Oil Management
Subtitle D
State or Regional Solid
Waste Plans
! 40 CFR Part 257 Solid Waste Disposal Criteria
! 40 CFR Part 258 Municipal Waste Landfills
Subtitle I
Regulation of
Underground Storage
Tanks
40 CFR Part 280 Underground Storage Tanks
The Hazardous Waste Determination
Subtitle C of RCRA regulates "solid waste" that is "hazardous." Thus, to be subject to
any hazardous waste regulations, one must first determine whether the material at issue is a
solid waste within the meaning of applicable statutes and regulations, and if so, whether
that waste is hazardous.
Under RCRA, "solid waste" is defined as "any garbage, refuse, sludge . . . and other
discarded material, including solid, liquid, semisolid, or contained gaseous material
resulting from industrial . . . operations[.]" (42 USC 6903(27)). Clearly, solid waste need
not be solid in the ordinary sense of the word to fall within this definition. The regulations
provide a more detailed definition of "solid waste" in 40 CFR 261.2, and provide a long list
of exclusions in § 261.4. Spent pulping liquor falls within an exclusion (§ 261.4(a)(6)).
Another exemption generally applicable for pulp facilities is that industrial wastewater
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RCRA Summary Appendix C
discharges from NPDES-regulated outfalls are not considered "solid wastes" and are thus
not regulated as hazardous wastes (§ 261.4(a)(2)).
The regulations also exclude from coverage certain recyclable materials which are
directly reused by excluding them from the definition of "solid waste" (§ 261.2(e)).
Excluded recyclable materials include those which are reused without reclamation:
! as ingredients in an industrial process,
! as substitutes for a commercial product, or
! as substitutes for a primary feedstock in the process from which they were
generated.
Some materials that must be reclaimed prior to reuse are also excluded, if, for example,
they are reclaimed and reused in the process through a closed-loop system
(§ 261.4(a)(8)), or, in the cases of reclaimed sludges and by-products, if they are hazardous
by characteristic only (§ 261.2(c), Table 1)). The regulations also exclude reclaimed
commercial chemical products (§ 261.2(c), Table 1) and wastewater treatment tanks.
If a waste is determined to be a non-excluded solid waste, a determination must
then be made as to whether that waste is hazardous. A waste may be deemed hazardous
either because it is specifically listed as a hazardous waste by the EPA, or because it
exhibits one of four hazardous characteristics, including ignitability, corrosivity, reactivity,
or toxicity (42 USC 6921 (a), (b)).
Listed Wastes
Forty CFR Part 261, SubpartD identifies several hundred "listed" wastes. The
regulations assign each listed waste a hazardous waste number (typically a letter followed
by three numbers). The letter preceding the hazardous waste number indicates the
category into which the listed waste falls (see Figure C-2). In addition to the waste
number, the regulatory waste lists also include a hazard code which identifies the basis for
the listing (e.g.. "I" for ignitability, "T" for toxicity, etc.). Note that EPA has considered
listing kraft pulp mill wastewater treatment plant sludges as a hazardous waste. However,
because of the Cluster Rules effluent limitations guidelines and standards, EPA has
determined that no such listing is required. See discussion in Section 7.5 of this manual.
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Appendix C RCRA Summary
Figure C-2
Listed Hazardous Wastes
"F" Wastes
"K" Wastes
"U" Wastes
"P" Wastes
Hazardous wastes from nonspecific sources (§ 26 1.31 (a))
Hazardous wastes from specific sources (§ 261.32)
Hazardous wastes from discarded commercial chemical products, off-specification species,
residues, and spill residues (§ 261.33(f))
Acutely hazardous wastes from discarded commercial chemical products, off-specification
container residues, and spill residues (§ 261.33(e))
container
species,
State hazardous waste lists should also be consulted (if applicable) before making a
final determination on the question of listing. Once listed, wastes remain listed until
delisted by EPA, either on the EPA's initiative or in response to a delisting petition filed by
a facility, in which the facility may illustrate that the listed waste is not truly toxic, due (for
example) to unique facility processes (see § 260.22).
Characteristic Wastes
If a waste is not on a hazardous waste list, it may nonetheless be subject to
regulation as a hazardous waste if it exhibits characteristics of ignitability, corrosivity,
reactivity, or toxicity, as determined either by testing or by knowledge. Once deemed
hazardous due to the presence of hazardous characteristics, a waste remains hazardous and
subject to regulation until such time as those characteristics are no longer present. Each
characteristic and its applicable test method(s) are identified and discussed in detail in 40
CFR Part 261, Subpart C. Figure C-3 summarizes the basic definitions, and indicates the
relevant waste code numbers that are used to identify characteristic hazardous wastes.
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RCRA Summary
Appendix C
Figure C-3
Characteristic Hazardous Waste
Ignitability (D001)
Corrosivity (D002)
Reactivity (D003)
Toxicity (D004-D043)
! Liquid: Not an aqueous solution containing <24% alcohol (by vol.) and has a flashpoint
below 140°F, determined by tests in ASTM Standards D-93-79, D-93- 80 or D-3278-78
(§261.21(a)(l))
! Non-liquids: Capable of causing vigorous and persistent fire hazard through friction,
absorption of moisture, or spontaneous chemical change (at std. temp, and pressure)
(§261.21(a)(2))
! Other: Ignitable compressed gas or oxidizer (as defined in 49 CFR 173.300 or 173.151,
respectively) (§ 261.21(a)(3) and (4))
Liquids with a pH equal to or below 2 or equal to or above 12.5, or which corrode steel at a
specified rate; uses tests in EPA Publication SW-846 (§ 261 .22(a)(l) & (2))
Among other things, reacts violently with water or other substances to create toxic gases
(§261.23(a))
A waste that leaches specified amounts of metal, pesticides, or organic chemicals using the
Toxicity Characteristic Leaching Procedure (TCLP) in EPA Publication SW-846 (§
26 1 .24(a)); or, for liquids, a waste that contains greater than the designated constituent
concentration levels
Special Rules for Certain Waste Types
The EPA has developed several rules to address combinations of hazardous and
non-hazardous solid wastes. The "mixture rule" provides that mixtures of listed
hazardous and non-hazardous solid wastes are regulated as "listed wastes," unless
expressly exempted by the regulations, and that mixtures of characteristic hazardous and
non-hazardous solid wastes are likewise subject to regulation, unless the mixture no longer
exhibits hazardous characteristics (§§ 261.3(a)(2)(iii)-(iv)). Similarly, the "derived-from
rule" provides that any solid waste generated by the treatment, storage, or disposal of a
hazardous waste is considered a hazardous waste as long as it exhibits hazardous
characteristics. There is an exception for "derived-from" wastes that are reclaimed and
reused, but the exemption excludes reclaimed materials which are burned for energy
recovery or used in a manner constituting disposal (§ 261.3(c)(2)(i)).
To address combinations of hazardous wastes and things other than solid wastes,
such as soil or groundwater contamination resulting from spills, EPA applies the
"contained in rule," which provides that a hazardous waste combined with an
environmental medium must be managed as a hazardous waste. Unlike the mixture rule,
the media contaminated by the hazardous waste can lose its status as hazardous waste once
it no longer contains the hazardous waste. The "contained in rule" was first articulated by
EPA in the Federal Register (53 FR 31138 (Aug. 17, 1988)), and has been upheld against
industry challenge by the courts (see, e.g.. Chemical Waste Management. Inc. v. EPA. 869
F.2d 1526, 1539 (D.C. Cir. 1989)).
This manual is intended solely for guidance and
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Appendix C RCRA Summary
Recycled materials not qualifying for an exclusion from regulation which
would otherwise be considered hazardous wastes may nonetheless be subject to
exemptions from some or all of the regulatory requirements, as detailed in 40 CFR 261.6.
That section lists certain recycled materials that are exempt from all hazardous waste
regulation. Other recycled materials listed in § 261.6 qualify for a partial exclusion from
regulation and are typically subject only to the special recycling standards set forth in 40
CFR Part 266, and to any applicable provisions of Part 124 and 270.
Finally, residues in empty containers have a qualified exemption from regulation
as hazardous waste (§ 261.7(b)). Empty containers, as well as the inner liners from empty
containers, are not regulated as hazardous wastes, provided that:
! All wastes have been removed using commonly employed practices, AND
! No more than 2.5 centimeters (one inch) of residue remains on the container
bottom or liner, OR
! No more than 3 percent by weight of the total capacity of the container remains
in the container or inner liner, if the container is less than or equal to 110
gallons in size, OR
! No more than 0.3 percent by weight remains in the container, if the container is
greater than 110 gallons in size.
Containers that held compressed gas are considered empty and thus exempted from
regulation when the pressure in the container approaches atmospheric pressure. A
container or inner liner that held an acute hazardous waste is empty and thus exempted
from regulation if it has been triple rinsed using solvent, or cleaned by an equivalent
method, or if the inner liner which prevented contact with commercial chemical products
has been removed.
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RCRA Summary Appendix C
Assessment Considerations for Waste Determinations:
> Prior to an assessment, the inspector must be familiar with the processes occurring at the facility.
> The generator must determine if a waste is hazardous and the inspector must substantiate the
determination. Knowledge of definitions and exceptions for hazardous waste is essential for both.
> When making a hazardous waste determination under §261.3, remember that listing takes precedence
over characteristics.
> The inspector should confirm that listed wastes are managed as hazardous waste, and verify that
generators have tested or apply their knowledge to wastes that are suspected of exhibiting hazardous
characteristics.
> The inspector should request documentation for wastes claimed to be exempt as "recycled" or
"reclaimed" wastes, and determine whether regulatory criteria applicable to these exemptions have been
met.
> With regard to the empty container exemption, has the waste been removed by commonly employed
practices (spilling, pouring, pumping, etc.)? If so, is there no more than 1 inch of residue remaining?
> If the residues in an empty container are subsequently exhumed and managed,
§ 261.7 exempts the resulting material from hazardous waste regulation, including the requirement to
determine if the solid waste exhibits a hazardous characteristic under Part 261, Subpart C.
Obligations of Generators
Those who generate hazardous waste, as defined above, are subject to a variety of
notification, accumulation and storage, labeling, tracking (by use of manifests), and
hazardous waste minimization requirements under 40 CFR Part 262. Generators who
provide on-site treatment, storage, and disposal are also subject to the TSDF permitting or
interim requirements of Parts 265 and 270. However, most paper and pulp facilities ship
their hazardous waste to an off-site TSDF and thus avoid the complex requirements of the
permitting and interim status regulations.
For purposes of regulation, EPA has identified three categories of generators,
defined according to the amount of hazardous waste generated or accumulated. Those
categories include large quantity generators (LQGs), small quantity generators (SQGs),
and conditionally exempt small quantity generators (CESQGs). Figure C-4 summarizes the
considerations used for this categorization. Because generator categories are based upon
quantities generated per month and total accumulation, a facility could conceivably change
categories over time (so-called "episodic generation"). Note that in determining the status
of a generator based on the quantity of hazardous waste generated, certain hazardous
wastes are excluded from the calculation (see § 261.5(c)). Generally, only those hazardous
wastes subject to substantive RCRA regulation under 40 CFR Parts 262 through 268 are
counted.
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Appendix C
RCRA Summary
Figure C-4
Hazardous Waste Generators
Large Quantity
Generators
In one calendar month:
! generate 2,200 pounds (1,000 kg) or more of hazardous waste, or
! generate 2,200 pounds (1,000 kg) or more of spill cleanup debris containing
hazardous waste, or
! generate more than 2.2 pounds (1 kg) of acutely hazardous waste, or
! generate more than 220 pounds (100 kg) of spill cleanup debris containing an
acutely hazardous waste, or
At any time:
! accumulate more than 2.2 pounds (1 kg) of acutely hazardous wastes on-site,
or
! accumulate more than 13,230 pounds (6,000 kg) of hazardous waste on-site
Small Quantity
Generators
In one calendar month:
! generate more than 220 pounds (100 kg) but less than 2,200 pounds (1,000
kg) of hazardous waste, or
! generate more than 220 pounds (100 kg) but less than 2,200 pounds (1,000
kg) of spill cleanup debris containing hazardous waste, or
At any time:
! accumulate more than 2.2 pounds (1 kg) of acutely hazardous waste on-site
Conditionally
Exempt Small
Quantity
Generators
In one calendar month:
! generate 220 pounds (100 kg) or less of hazardous waste, or
! generate 220 pounds (100 kg) or less of spill cleanup debris containing
hazardous waste, or
! generate 2.2 pounds (1kg) or less of acutely hazardous waste, or
At any time:
! accumulate up to 2.2 pounds (1 kg) of hazardous wastes on-site
Assessment Considerations for Generator Status:
> Confirm that generators that claim to be SQGs are not generating more than the limit for SQGs (Note
that 100-1,000 kg/mo is between 220 and 2,200 Ib/mo or about 25 - 300 gallons). This may be done by
reviewing manifests for quantities and doing a mass balance to convert to probable weight for waste on-
site.
> Calculate the maximum quantity of hazardous waste in tanks based upon storage volumes of tanks. This
may be determined based upon the quality of waste characteristics, the density of the waste and the
volume available for waste storage. The waste must not exceed 6,000 kg, unless the facility has interim
status, a permit or an emergency extension. If the maximum volume of tanks will exceed 6,000 kg, but
the actual waste quantity is less, this is not a current violation, but the assessment should note the
potential for a status change based on tank capacity.
This manual is intended solely for guidance and
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RCRA Summary Appendix C
Notification
Upon determining that a waste is a hazardous waste, a generator must notify EPA
before transporting, treating, storing, or disposing of that waste. Notifications are made
using EPA Form 8700-12 (45 FR 12746 (1988)). The notification form elicits the
generator's name and address, identifies a facility contact person, provides the EPA
hazardous waste number for the waste being managed (as indicated in the hazardous waste
regulations), and provides a brief description of the type of regulated activity being
conducted at the facility. Upon receiving this notification, EPA issues a generator ID
number which is used to track all wastes generated by the facility (40 CFR 262.12).
CESQGs are exempt from the notification and ID number requirements
(§ 261.5(b)), as are those who generate certain recycled materials specified in
§ 261.6(a)(3). All other generators must provide notification and obtain an ID number
before offering a waste for transport, or otherwise disposing of that waste.
Accumulation and Storage
As a general rule, generators who store hazardous waste on site must obtain a
RCRA permit or interim status under 40 CFR Parts 265 and/or 270, in addition to meeting
all generator requirements of 40 CFR Part 262. Recognizing that facilities cannot dispose
of waste the moment it is generated, however, EPA allows generators to store hazardous
wastes at the facility for up to 90 days (for LQGs) or 180 days (for SQGs accumulating no
more than 6000 kg) without being subject to permitting or interim status requirements if
the facility complies with the accumulation regulations of 40 CFR 262.34. The
accumulation period applicable to SQGs may be extended to 270 days, if the SQG must
transport the waste over a distance of 200 miles or more for treatment (§ 262.34(e)).
CESQGs are exempt from Part 262, so long as waste quantity limitations of the regulations
are met (§ 261.5(b),(e),(f),(g), and (j)).
The accumulation regulations mandate that all hazardous wastes must be stored in
containments buildings, containers, or tanks, or on drip pads, which comply with the
standards of 40 CFR Part 265 (40 CFR section 262.34(a)(l)), and must be managed in
accordance with any applicable air emission standards (see 40 CFR Part 265, Subparts AA,
BB and CC). Key requirements from Part 265 are detailed in Figure C-5.
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Appendix C RCRA Summary
Figure C-5
Storage Requirements for Temporary Accumulation
(40 CFR 262.34)
CONTAINERS: PART 265 SUBPART I
Generators must:
! Note the date that accumulation began and be clearly labeled with the words "Hazardous Waste"
! Construct containers of appropriate material and maintain them in good condition
! Keep containers closed at all times except when wastes are being removed or added
! Inspect containers weekly
! Take additional precautions to reduce the chance of explosion or fire if incompatible wastes are stored
! Note that air emission standards under Part 265, Subpart CC may apply
TANKS: PART 265, SUBPART J
(Note: These requirements do not apply to wastewater treatment tanks.)
Generators must:
! Assess existing tank system's integrity
! Design and install new tank systems or components according to regulatory specifications
! Provide secondary containment for tanks of a certain age, or for those storing specified hazardous wastes
! Comply with regulatory operating requirements, including spill, overfill, and overtopping prevention
controls and practices
Inspect the tank, spill control equipment, and monitoring data daily
Inspect any cathodic protection systems at least bimonthly
Immediately remove any leaking or unfit tanks from operation, take appropriate containment action, and
provide notice/reporting of any release to the environment
Refrain from storing ignitable, reactive, or incompatible wastes in tanks, unless regulatory treatment or
other special requirements are met
Comply with closure and post-closure requirements
Apply modified requirements for tank storage, reflected in 40 CFR 265.201 (for SQGs)
Note that air emission standards under Part 265, Subpart CC may apply
Note:
! These requirements do not apply to wastewater treatment tanks
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RCRA Summary Appendix C
Figure C-5 (cont.)
Storage Requirements for Temporary Accumulation
(40 CFR 262.34)
DRIP PADS: PART 265, SUBPART W
Generators must:
! Assess existing drip pad integrity
! Design, install, and operate new drip pads according to regulatory specifications
! Inspect liners and cover systems during construction or installation
! Have liners inspected and certified by independent qualified, registered professional engineer immediately
after construction or installation
Inspect drip pads weekly during operation, and after any storms
Comply with closure requirements of regulations
Maintain specific waste removal records
CONTAINMENT BUILDINGS: PART 265, SUBPART DD
Generators must:
Design building and operate according to regulatory standards
Establish procedures and regularly document the fact that the unit is emptied within the accumulation time
frame
Avoid the land disposal restrictions of Part 268 by ensuring that the unit:
! Is completely enclosed
! Is constructed out of use-appropriate materials
! Has a durable primary barrier
! Has a primary barrier that will prevent migration, a liquid collection system to protect the primary
barrier, and a secondary containment system (if unit used to manage liquids)
Has controls to prevent fugitive dust emissions, if applicable
Is designed and operated to ensure containment (design and operating standards are provided in the
regulations) (40 CFR 262.34 (a)(l)(iv))
Comply with closure and post-closure standards
Generators may accumulate as much as 55 gallons of hazardous waste or one quart
of acutely hazardous waste listed in § 261.33(e) in containers at or near the generation
point without triggering the 90-day (180-day for SQGs) accumulation regulations. This is
referred to as "satellite accumulation." The minimal requirements of § 262.34(c) must be
met for satellite accumulation, including proper marking of containers and compliance with
specified container management practices. Once these limits are exceeded, however, the
generator has only three days to comply with the 90-day (180-day for SQGs) rules
(§ 262.34(c)(2)).
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Appendix C
RCRA Summary
Assessment Considerations for Accumulation/Storage Practices:
> Inspect accumulation area to assure that all containers are marked with the accumulation start date and
the words "Hazardous Waste."
> Because tanks are reused, the generator is not required to mark the tank with the accumulation start
date. Therefore, review records and manifests to verify that tanks have been emptied within 90 days.
> Observe satellite accumulation areas (facilities may have multiple) and insure that there is no waste in
excess of 55 gallons, or in excess of one quart for acutely hazardous waste. If satellite containers are
full, check "full" date to assure containers are removed from satellite area w/i 3 day limit.
> Verify that satellite accumulation areas are at or near the point of waste generation and under the control
of a close-by operator.
> Verify that satellite accumulation containers are closed except when waste is being added or removed.
Pretransportation Requirements: Packaging and Marking the Waste
With the exception of CESQGs, all generators are subject to the pretransportation
requirements of §§ 262.30-262.33. Those regulations adopt by reference the Department
of Transportation (DOT) regulations governing packaging, labeling, and marking of
hazardous waste, and the placarding of the vehicle used to transport that waste. Figure C-
6 summarizes pretransportation requirements and identifies applicable EPA and DOT
regulations.
Figure C-6
Correlation with Applicable DOT Regulations
DOT Cite
49 CFR 173,
178, 179
49 CFR 172
49 CFR 172,
Subpart F
EPA Cite
40 CFR
262.30
40 CFR
262.31-
262.32
40 CFR
262.33
Requirements
Packaging must meet specific standards outlined in 49 CFR 173
(requirements for shipping and packaging), 178 (shipping container
specifications), and 179 (specifications for tank cars).
Containers must be marked and clearly labeled according to 49 CFR 172
(see Hazardous Waste Tables), with the statement:
"Hazardous Waste — Federal Law prohibits improper disposal. If found,
contact the nearest police or public safely authority or the U.S.
Environmental Protection Agency."
Placecards must be provided in accordance with DOT regulations for
hazardous materials.
The DOT provides technical assistance in complying with these pretransportation
requirements through its Hazardous Materials Information Center, (202) 366-4488.
This manual is intended solely for guidance and
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RCRA Summary Appendix C
Assessment Considerations for Packaging/Marking:
> If hazardous waste is ready for shipment, the inspector should:
- Check that containers are in good condition, and not damaged, corroded or leaking.
- Check each container for the appropriate DOT label, manifest number and generator's name and
address.
> If there is no waste ready for shipment, compliance with these requirements must be deduced by
questioning appropriate facility personnel. The inspector should request to see placards, if they are
required, and printed hazardous waste labels. If the facility has these items on hand, they are likely
being used.
Pretransportation Requirements: The LDR Determination
Prior to shipment, generators must determine whether the hazardous waste is
prohibited from land disposal. The regulations prohibit land disposal of virtually all
hazardous wastes, except where the treatment standards of 40 CFR Part 268 have been
met. Land disposal includes any placement of hazardous waste into a landfill, land
treatment unit, waste pile, injection well, salt dome or salt bed formation, underground
mine or cave, surface impoundment or placement in a concrete vault or bunker intended for
disposal purposes (§ 268.2(c)). Although the ultimate responsibility for treatment lies with
the person disposing the waste, generators must notify the designated TSDF of any
necessary treatment requirements under the LDRs in order to ensure that proper treatment
occurs.
As a first step to meeting generator LDR obligations, the generator must determine,
by knowledge or testing, whether the hazardous waste meets the treatment standards of
§§ 268.40, 268.45 or 268.49 (§ 268.7(a)(l)). After this determination is made, the
generator is subject to a multitude of notice, certification, and recordkeeping requirements.
The regulations, as recently amended to reduce paperwork (see 62 FR 25998, May 12,
1997, effective August 11, 1997), require notice of LDR status to each TSDF receiving
hazardous waste only with the initial shipment, unless the waste or the generating facility
change, in which case another notice reflecting the change must be provided. The notice
must include all of the relevant information reflected in the "Generator Paperwork
Requirements Table" of § 268.7 (reproduced below as Figure C-7).
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Appendix C
RCRA Summary
Figure C-7
Generator Paperwork Requirements Table
Required Information
1 . EPA Hazardous Waste and Manifest
numbers
2. Statement: this waste is not prohibited
from land disposal
3. The waste is subject to the LDRs.
Identify the constituents of concern for
F001-F005, andF039, and underlying
hazardous constituents (for wastes that
are not managed in a Clean Water Act
(CWA) or CWA-equivalent facility),
unless the waste will be treated and
monitored for all constituents. If all
constituents will be treated and
monitored, there is no need to put
them all on the LDR notice
4. The notice must include the applicable
wastewater/nonwastewater category
(see §§ 268.2(d) and (f)) and
subdivisions made within a waste code
based on waste-specific criteria (such
as D003 reactive cyanide)
5. Waste analysis data (when available) .
6. Date the waste is subject to the
prohibition
7. For hazardous debris, when treating
with the alternative treatment
technologies provided by § 268.45:
the contaminants subject to treatment,
as described in § 26 8. 4 5 (b); and an
indication that these contaminants are
being treated to comply with § 268.45
8. A certification is needed (see
applicable section for exact wording)
If waste does
not meet
treatment
standard
(40 CFR
268.7 (a)(2))
'
/
If waste
meets
treatment
standard at
point of
origination
(40 CFR
268.7 (a)(3))
'
/
'
If
exemptions
to LDR
treatment
standards
apply
(40 CFR
268.7 (a)(4))
'
'
/
'
If managing
a lab pack
and using
alternative
treatment
standards of
§268.42 (c)
(40 CFR
268.7 (a)(9))
'
'
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RCRA Summary Appendix C
As reflected in § 268.9(a)-(c), the generator must identify each applicable waste
code before determining what (if any) treatment is required. Where wastes are both listed
and characteristic, the treatment standard for the listed waste controls, provided that the
treatment standard addresses the hazardous constituents that cause the waste to exhibit a
hazardous characteristic. Otherwise, all applicable treatment standards must be met. The
treatment standards for all waste types are specified in Subpart D of Part 268. These
standards are expressed either as a specific concentration level (in mg/13) or as application
of a specific technology. Where characteristic waste is no longer hazardous, a one-time
notification and certification are placed in the generator's file and copies sent to the EPA
Regional Office or authorized State (§ 268.9(d)).
In addition to the preceding requirements, Part 268 contains surface impoundment
exemptions to the LDRs (Subpart B), and waste-specific prohibitions on land disposal that
are not generally applicable to kraft pulp mills. Note also that § 268.3(b) allows in certain
circumstances for dilution of characteristic wastes in a wastewater treatment unit that
discharges under a NPDES permit (or, to a POTW if subject to pretreatment standards), or
to a CWA-equivalent system. The wastes must be hazardous only because they exhibit a
hazardous waste characteristic. Finally, the regulations exempt the following wastes from
LDR requirements:
! Wastes generated by CESQGs,
! Wastes identified or listed as hazardous after November 8, 1984, for which no land
disposal prohibitions or treatment standards have been promulgated, and
! De minimis losses of characteristic wastes to waste waters (defined as losses from
normal material handling operations, minor leaks, etc.).
Assessment Considerations for LDR Requirements:
> Determine whether the generator produces wastes subject to the LDRs.
> Review how the generator determines the waste is restricted by reviewing documentation/data used to
support that determination.
> Check that LDR notifications are retained and have a corresponding manifest, and determine whether all
notification/certification requirements of § 268.7 were met.
> If a generator is treating a restricted waste in accumulation tanks or containers, review the waste
analysis plan.
Tracking and the Manifest System
The manifest system used to track hazardous waste from generation to final
disposal is a central feature of the RCRA regulatory scheme. Pursuant to 40 CFR Part
262, Subpart B, generators of hazardous waste must prepare a Uniform Hazardous Waste
Manifest (EPA Form 8700-22, reprinted in the Appendix to Part 262), or the equivalent
form developed by the consignment or generating State, for each hazardous waste
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Appendix C RCRA Summary
shipment. The manifest must identify the permitted TSDF designated to receive the waste,
and may identify an alternate TSDF in the event that an emergency prevents delivery to the
TSDF of choice.
At the time of hazardous waste transportation to an off-site TSDF, the generator
signs and dates the manifest, and obtains the signature of the initial transporter. The
manifest consists of sufficient carbon copies so that the generator, each transporter, and the
TSDF may each retain one copy, with one additional copy being returned to the generator
by the TSDF (§§ 262.22, 262.23). Generators must retain a copy of the manifest for at
least three years (§ 262.40(a)).
LQGs who do not receive a signed copy of the manifest from the TSDF within 35
days of shipment must contact the TSDF and/or transporter to determine the status of the
hazardous waste. If no manifest is received within 45 days of shipment, notwithstanding
the LQG's efforts to locate the manifest, the LQG must file an "Exception Report" with
EPA, which consists of a copy of the manifest and a cover letter explaining efforts taken to
locate the manifest. SQGs are subject to similar requirements, except that they need not
attempt to locate the manifest, and are only required to submit an Exception Report after
60 days have passed (§ 262.42(a), (b)).
The manifest requirements as outlined above apply to all LQGs, and to all SQGs,
unless the SQG reclaims waste under a contractual agreement meeting the requirements of
40 CFR section 262.20(e)(l) and maintains a copy of the reclamation agreement on file for
three years after termination or expiration of the agreement (§ 262.20(e)(2)). CESQGs are
exempt from manifest requirements (§ 261.5(b)).
Assessment Considerations for Manifests:
> Has the facility used the correct manifest (consignment State, generator State, or other)?
> Review generator's manifest files to determine whether manifests were completed correctly.
- Are the original manifests signed and dated by the generator and first transporter?
- Is the EPA ID number clearly marked for the generator, transporter and TSDF?
- Have all spaces been completed correctly, and all changes/cross-outs initialed?
- If the State requires hazardous waste codes to be included on the manifest, has the correct waste
code been entered?
> The TSDF should return the signed copy of a manifest to an LQG within 35 days, and to an SQG within
60 days, from the date upon which the waste was accepted by the initial transporter. A copy of the
returned and signed manifest must be retained for three years (the original may be discarded once the
signed manifest is returned).
> Obtain explanations for unusual gaps in the frequency of off-site shipment. Are subsequent shipments
larger? This could indicate an exceedance of the 90-day accumulation limit.
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RCRA Summary Appendix C
Recordkeeping and Reporting
Generators are required to prepare and retain copies of the following records for at
least three years: (1) manifests, (2) Exception Reports, (3) Biennial Reports detailing
shipments to TSDFs, and (4) laboratory test data generated by the initial hazardous waste
determination (if testing, rather than knowledge, was used) (40 CFR Part 262, Subpart D).
The three-year retention period is automatically extended where unresolved EPA
enforcement actions are pending, or as otherwise requested by EPA (§ 262.40(d)).
Exception Reports are discussed in the preceding section. Biennial Reports (EPA
Form 8700-13A) must be prepared by generators who ship hazardous waste to an off-site
TSDF within the United States, and filed with the EPA Regional Administrator by March 1
of each calendar year. Biennial Reports include the following information:
! EPA ID number, name, and address of generator
! Calendar year covered by report
! EPA ID number, name and address for each TSDF to which waste was shipped
! EPA ID number and name of any transporter used during the year
! Description, EPA hazardous waste number, DOT hazard class, and quantity of each
hazardous waste shipped to a TSDF
Description of waste minimization efforts
Description of changes in volume and toxicity actually achieved, as compared to
previous years
! Certification
SQGs are subject to slightly less stringent recordkeeping and reporting
requirements, inasmuch as the regulations exempt them from the Biennial and Exception
Report retention requirements of § 262.40(b), and impose simplified Exception Report
reporting requirements under § 262.42(b). However, both LQGs and SQGs may be
required to furnish additional reports concerning hazardous waste quantity and disposition
at the Administrator's discretion, as authorized by § 262.43. CESQGs are entirely exempt
from recordkeeping and reporting requirements (§ 261.5(b)).
Assessment Considerations for Recordkeeping/Reporting:
> Are all required reports and records being retained? If additional reports were required by the Regional
Administrator, verify that they are present.
> If the State has a shorter time frame for the manifest to be returned to the generator, verify that the
facility has been receiving the signed manifests within that timeframe.
> The inspector should review the on-site copy of the Biennial Report for completeness.
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Appendix C RCRA Summary
Waste Minimization Requirements
Generators are required to develop programs to minimize the quantity and toxicity
of their hazardous wastes (typically by source reduction or recycling), to report
minimization efforts on their Biennial Reports, and to certify on each manifest that they are
engaged in such efforts. EPA's interim final guidance on waste minimization, 58 FR 31114
(May 28, 1993), provides that a waste minimization plan should incorporate: (1) top
management support, (2) characterization of waste minimization and management costs,
(3) periodic waste minimization assessments, (4) appropriate cost allocation, (5)
encouragement of technology transfer, and (6) program implementation and evaluation.
Additional guidance and specific examples of successful waste minimization programs may
be found in The EPA Manual for Waste Minimization Opportunity Assessments (1988 ed.)
(EPA/600-2-88-025). Five basic types of waste minimization are:
! Source Separation (or segregation) - Keep hazardous waste streams separated
from nonhazardous waste streams through management practices to prevent
contamination of the nonhazardous waste. This is an inexpensive and effective
method for reducing the volume of hazardous waste to be handled, transported and
eventually disposed of.
! Recycling (also referred to as recover and reuse) - The process of removing a
substance from a waste returning it to productive use. Solvents, acids, and metals
are commonly recycled. Assure that the recycling is not "sham recycling."
! Raw Material Substitution - Replacing a raw material that generates large
amounts of hazardous waste with a material that generates less hazardous waste.
! Manufacturing Process Changes - Eliminate or alter a process so that it reduces
or eliminates the amount of hazardous waste produced.
! Product Substitution - Eliminating a product that contributes to contamination
and replacing it with a product that is innocuous.
Exporters of Hazardous Waste
Generators who export their hazardous wastes to foreign countries rather than
sending them to a domestic TSDF are subject to the requirements of 42 USC 6938 and 40
CFR Part 262, Subpart E. The regulations require exporters to provide EPA with notice at
each step of the export process and to comply with special manifesting, exception, and
annual reporting requirements. Under Subpart E, exports of hazardous waste are
prohibited, unless or until:
! Notice is given to EPA containing all of the information about the waste and its
expected course of travel listed in 40 CFR 262.53,
! The receiving country consents to the shipment,
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RCRA Summary Appendix C
! a copy of the EPA Acknowledgment of Consent (i.e., receiving country consent as
cabled by the U.S. Embassy in the receiving country) accompanies the shipment,
and
! the shipment conforms to the receiving country's consent.
Copies of all essential documents must be retained for at least three years, and the
retention period is automatically extended during any period of unresolved enforcement
actions or as requested (40 CFR 262.57).
Special export requirements may apply if the hazardous waste is being shipped to a
member country of the Organization for Economic Cooperation and Development
(OECD), as defined in 40 CFR 262.58(a)(l).
Assessment Considerations for Waste Exports:
> Review the exporter file. Verify that all information is complete and correct, the point of departure
from the US and the additional certification statement are areas commonly overlooked.
> Verify that the transporter has returned a signed copy of the manifest with the date and place of
departure within 45 days. If not, has an Exception Report been filed?
> If the exporter is using a broker, the inspector should question the nature of the arrangements made to
verify that all export requirements are being met.
> Insure that a copy of each notification of intent to export, EPA Acknowledgment of Consent,
confirmation of delivery, and annual report have been retained for at least 3 years.
Personnel Training and Contingency Planning
Large quantity generators are subject to the same requirements for personnel
training, preparedness and prevention, and contingency plan/emergency procedures as
TSDFs (see § 265.16, and Subparts C and D of Part 265). Training requirements
include classroom or on-the-job instruction, annual review of training received, and records
of all training provided. Preparedness and prevention requirements relate to general
facility operation and maintenance (O&M) practices, required equipment, access to alarms,
required aisle space to allow for responding to emergencies, and arrangements with local
and State emergency response agencies (police, fire, hospitals, emergency response teams)
to familiarize them with site conditions and/or types of wastes generated/handled on site.
Contingency plan requirements address the measures to be taken in response to any
unplanned sudden or non-sudden release of hazardous waste or hazardous waste
constituents. The regulations impose several specific components of an acceptable plan.
For small quantity generators, the same preparedness and prevention procedures in
Part 265, Subpart C apply, but the personnel training and contingency plan requirements in
Part 265 do not apply. Instead, § 262.34(d)(5) requires that the facility:
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Appendix C RCRA Summary
! Have at least one employee on-site or on-call that serves as an emergency
coordinator
! Properly notify the National Response Center (800-424-8802) immediately in the
event of a release that could threaten human health outside the facility or that has
reached surface waters
! Ensure that all employees are thoroughly familiar with proper waste handling
procedures relevant to their responsibility during both normal operations and
emergencies.
! Post next to the telephone the emergency coordinator's name and telephone
number, the location of fire extinguishers, spill control material, and fire alarm, and
the telephone number of the fire department (unless there is a direct alarm).
Standards for the Management of Used Oil
Used oil is one of a growing number of wastes classified as nonhazardous that have
been singled out for special regulation outside of the general nonhazardous waste program
of RCRA Subtitle D. Pursuant to the Used Oil Recycling Act of 1980, EPA adopted
regulations for used oil (40 CFR Part 279) which establish standards for generators,
transporters, and processors. Many States have established their own regulations for
handling used oil. Inspectors should become familiar with a State's used oil requirements
prior to inspection.
For purposes of federal regulation, used oil means any oil that has been refined
from crude oil, or any synthetic oil, that has been used and as a result of such use is
physically or chemically contaminated (§ 279.1). The EPA presumes that used oil is
recycled, unless a used oil handler disposes of it, or sends it for disposal. Except as
provided in § 279.11, the regulations in Part 279 apply to used oil whether or not it
exhibits any characteristic of hazardous waste identified in Subpart C of 40 CFR Part 261.
Used oil that exceeds any specification level is subject to Subpart C as an "off-specification
used oil." Mixtures of used oil and other substances may generate separate or additional
regulatory requirements. Figure C-8 lists different used oil mixtures and indicates how
they are regulated.
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Appendix C
Figure C-8
Used Oil and How it is Regulated
Used Oil
Mixtures of used oil and listed hazardous waste
Used oil containing more than 1 ,000 ppm total halogens
Mixtures of used oil and hazardous waste that exhibit a
characteristic other than ignitability
Mixtures of used oil and characteristic hazardous waste if
the mixture does not exhibit any hazardous waste
characteristic
Mixtures of used oils and characteristically ignitable
hazardous waste that is not listed in Subpart D of Part 261
Mixtures of used oil and CESQG hazardous waste
Mixtures of used oil with products
How Regulated
Regulated as a listed hazardous waste under Subpart D of Part 261
Regulated as hazardous waste under Subpart D of Part 261
(although may be rebutted)
Regulated as hazardous waste under Parts 260 through 266, 268,
270, and 124
Regulated as used oil under Part 279
Regulated as used oil under Part 279, if resultant mixture does not
exhibit the characteristic of ignitability
Regulated as used oil under Part 279
Regulated as used oil under Part 279. Unless the mixture is used
oil and diesel fuel for use in generator's vehicle. (Prior to mixture,
used oil is subject to Subpart C of Part 279)
Standards for Generators of Used Oil
A used oil generator is any person, by site, whose act or process produces used oil,
or whose act first causes used oil to become subject to regulation, except as provided in
§ 279.20(a)(l)-(4). The regulations address three generator activities: (1) used oil
storage, (2) on-site burning in space heaters, and (3) off-site shipments.
Used oil generators that store used oil in underground storage tanks (USTs) are
subject to regulation under 40 CFR Part 280 (see discussion below in this Appendix), and
are also subject to all applicable spill prevention, control, and countermeasure requirements
of 40 CFR Part 112. Other permissible storage units (tanks, containers, or units subject to
regulation under Parts 264 or 265, and any fill-pipes used for oil transfer) must be
maintained in good condition and labeled with the words "Used Oil." Upon detection of
any release to the environment not covered by the UST regulations, generators must stop
and contain the release, clean up and manage the released material, and if necessary, repair
or replace any leaking used oil storage containers or tanks prior to returning them to
service (§ 279.22).
Generators may burn used oil in on-site space heaters provided that the oil is
generated only by the owner/operator, the heater has a maximum capacity of not more than
0.5 million Btu per hour, and the heater combustion gases are vented to the ambient air
(§ 279.23).
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Appendix C RCRA Summary
When shipping used oil off-site, generators must ensure that their transporter has
obtained an EPA ID number, except for:
Generators who self-transport less than 55 gallons of their used oil at any time;
Generators who self-transport less than 55 gallons of their used oil from the
generator site to an aggregation point; or
Generators who arrange for used oil to be transported pursuant to a tolling
agreement under which the reclaimed oil is returned to the generator (§ 279.24).
Assessment Considerations for Used Oils:
> Determine how used oil is handled (disposed of or recycled).
> Determine if the used oil has been mixed with a listed waste or characteristically hazardous waste, if it
contains more than 1,000 ppm or exhibits the characteristic of ignitability.
> Review test results and/or analysis of used oils.
> Assess the condition of the used oil storage unit. It should be labeled "Used Oil", as should fill pipes
forUSTs.
> Determine whether any used oil releases have occurred. If so, how were they managed and cleaned-
up? (Review associated documentation.)
> Determine whether used oil is burned in a space heater. If so, do the space heater and the quantities
burned meet all the required conditions?
Regulation of Underground Storage Tanks
In 1984, Congress amended RCRA by enacting the Hazardous and Solid Waste
Amendments (HSWA). Subtitle I of the HSWA mandated the creation of a program for
the regulation of underground storage tanks (USTs) containing regulated substances other
than hazardous wastes. The EPA responded to this mandate by promulgating
comprehensive UST regulations, codified at 40 CFR Part 280. States may be authorized to
operate their own UST programs, so long as State UST regulations are at least as strict as
federal requirements.
A UST is defined as a tank that stores "regulated substances" and that has at least
10 percent of its volume below the surface of the ground, including piping connected to the
tank (§ 280.12). Regulated substances include hazardous chemical products regulated
under CERCLA (above de minimis concentrations) and any petroleum products that are
liquid at standard conditions. As noted above, regulated substances do not include
hazardous wastes covered by RCRA Subtitle C.
Other USTs excluded from regulation include:
! Heating oil tanks on the premises where the tank is located;
! Flow-through process tanks;
! Any wastewater treatment tank system regulated under the CWA;
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Appendix C
! Tanks with less than 110 gallons capacity;
! Spill and overflow containment systems that are expeditiously emptied after use;
! Stormwater and wastewater collection systems; and
! Tanks situated on or above the floor of underground areas such as basements,
shafts and tunnels.
The UST regulations establish conditions for design, construction, operation,
installation, and notification; release detection, response, investigation, confirmation,
reporting, and corrective action; out of service UST systems and closures; and financial
responsibility. Figure C-9 provides a general overview of the UST requirements in 40 CFR
Part 280.
Figure C-9
Underground Storage Tank Requirements (40 CFR Part 280)
Requirements
Description
Design, Construction,
Installation, and Notification
(Subpart B)
! New USTs (installed after December 1988) must meet performance
standards detailed in 40 CFR 280.20
! All existing UST systems (installed before December 1988) must be
upgraded to add spill, overfill, and corrosion protection, and to meet
other requirement detailed in 40 CFR 280.21, by December 1998, or
close and/or replace the existing UST (40 CFR 280.21)
! Notify State and/or local agencies upon the installation and use of new
UST systems (40 CFR 280.22)
General Operating
Requirements (Subpart C)
! Must ensure the prevention of releases through spill and overfill
control, proper corrosion protection, use of compatible materials, and
appropriate repairs to the UST system (40 CFR 280.30 - 280.33)
! Reporting requirements include notification, reports of all releases
(suspected and confirmed), corrective action, and permanent change
in service or closure (40 CFR 280.34(a))
! Recordkeeping requirements include documentation of corrosion
controls, UST system repairs, and release detection compliance (40
CFR 280.34(b))
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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RCRA Summary
Figure C-9 (cont.)
Underground Storage Tank Requirements (40 CFR Part 280)
Requirements
Description
Release Detection (Subpart D)
! Must provide a method or combination of methods to detect leaks and
releases from the UST system (40 CFR 280.40 - 280.41)
! Must comply with release detection requirements according to the
schedule set forth in 40 CFR 280.40(c)
! Owners or operators of petroleum USTs must comply with release
detection requirements under 40 CFR 280.41
! Owners or operators of hazardous substance USTs must comply with
release detection requirements under 40 CFR 280.42
! Must maintain records demonstrating compliance with release
detection requirements (40 CFR 280.45)
Release Reporting,
Investigation, and Confirmation
(Subpart E)
! Must report any suspected releases within 24 hours or another
reasonable time period specified by implementing agency (40 CFR
280.50)
! Must investigate and confirm any suspected releases (40 CFR
280.52)
! Must contain and cleanup any release, and report to implementing
agency (40 CFR 280.53)
Release Response and
Corrective Action for UST
Systems Containing Petroleum
or Hazardous Substances
(Subpart F)
In the event of a release
! Must notify implementing agency upon confirmation of a release and
take action to prevent additional release (40 CFR 280.60, 280.61)
! Must submit report to implementing agency that summarizes initial
abatement activities within 20 days (40 CFR 280.62)
! Must submit site characterization report (40 CFR 280.63)
! Must develop and implement a corrective action plan as directed by
implementing agency (40 CFR 280.66)
Out-of-Service UST Systems and
Closure (Subpart G)
For temporary closure, must maintain operating practices to ensure prevention
of releases (40 CFR 280.70)
Must notify implementing agency 30 days prior to permanent closure or
change in service (40 CFR 280.71)
Must maintain records to demonstrate compliance with closure requirements
in accordance with 280.34 (40 CFR 280.74)
Financial Responsibility (Subpart H)
Must demonstrate financial responsibility for taking corrective action and for
compensating third parties for bodily injury and property damage caused by
accidental releases (40 CFR 280.90 - 280.116)
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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RCRA Summary Appendix C
As indicated by Figure C-9, all existing USTs must add spill, overfill, and corrosion
protection, close the existing UST, or replace the existing UST with a new UST by
December 22, 1998 (§ 280.21). New USTs must have a suitable dielectric coating in
addition to cathodic protection, and must be installed in accordance with an established
code of practice and the manufacturer's instructions (§ 280.20(d)). Installation of new
USTs must also be certified (§ 280.20(e)). Any facility that brings a UST into use after
May 8, 1986 must submit the Notification Form prescribed in Appendix I of Part 280 (or a
comparable State form) within 30 days. This form must be submitted to the State or local
agency or department designated in Appendix II of Part 280 (§ 280.22).
Assessment Considerations for USTs:
> Interviews with facility personnel may cover the following:
Age, construction material, capacity of each tank on-site
Type of products stored in each tank
If tanks have been closed, determine whether there was contamination associated with the tank,
and when and how such contamination occurred.
Type of corrosion protection and frequency of inspections (corrosion protection required on
tanks by Dec. 22, 1998)
Type of overfill and spill protection
Inquire about release detection. Is monthly inventory control and/or annual tightness testing
used?
> Visual observations may be used to determine if any spills or overfills have occurred that have not
been remediated immediately. Look for USTs that may have gone unreported. Fill and/or vent pipes
are an indication of an UST.
> Document reviews should consist of Notifications for UST systems, reports of releases (suspected
releases), spills and overfills, initial site characterization and corrective action plans, notifications of
permanent closure, corrosion expert's analysis if corrosion protection is not used, documentation of
operation of corrosion protection equipment, recent compliance with leak detection requirements
(including daily inventory sheets with monthly reconciliation), and results of site investigations.
Evaluating Compliance
There are several types of RCRA inspections which differ based upon the purpose,
facility status, and probable use of the inspection results. The compliance evaluation
inspection (CEI) is the primary mechanism for assessing RCRA compliance, however, and
is the model for a RCRA assessment used in this Appendix. The various types of RCRA
inspections and basic forms for preparing for and conducting RCRA inspections are
included in EPA's RCRA Inspection Manual.1 In addition, a screening assessment may be
conducted by non-RCRA inspectors. See the sample screening checklist in Appendix E.
During the CEI, the inspector examines areas of the facility where hazardous waste
is generated and stored to determine compliance with the applicable storage, labeling and
handling requirements, and reviews all required records, including: manifests, Land
Disposal Restrictions (LDR) Forms, appropriate plans and reports, training and
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Appendix C
RCRA Summary
certification records, and other documentation. Record review provides insight into the
hazardous waste handling practices over the inspection period.
Under Section 3006 of RCRA, EPA may authorize a State to administer and
enforce a State hazardous waste program in lieu of the federal Subtitle C program. States
may include more stringent requirements than Federal regulations in their authorized
program. States typically receive authorization incrementally, consistent with the gradual
implementation of the federal RCRA program, due largely to the lag time between federal
promulgation of Subtitle C standards, and development and adoption of equivalent
standards by the States. There are also different levels of State authorization. States may
be granted primacy for the base RCRA program (the pre-HSWA RCRA requirements), for
land disposal requirements, and for the RCRA corrective action program. Where a facility
is subject to joint federal/State authority, inspections may be conducted by both EPA
and/or State inspectors. Inspectors who inspect areas not under their jurisdiction and
identify conditions of non-compliance should report those conditions to the agency with
jurisdiction for further action.
Assessment Preparation
Assessment preparation is discussed at length in Section 3 of this manual.
Adequate preparation will provide the inspector with background information necessary to
conduct an accurate assessment. Recommended preparation steps and step objectives
specific to RCRA assessments are included in Figure C-10.
Figure C-10
Assessment Preparation Summary
Recommended Steps
Objectives
Define Scope of Assessment
Define Assessment Objectives
>• To evaluate general compliance
>• To verify accuracy/completeness of permit
>• To respond to citizen complaints
>• To identify root cause of problem and/or evaluate effectiveness
of corrective actions
>• To develop information to support/respond to enforcement
action
>• To observe required sampling/testing
>• To audit compliance monitoring systems
Determine Assessment Type
>• Compliance Evaluation Inspection (CEI)
>• Case Development Inspection (GDI)
>• Comprehensive Groundwater Monitoring Evaluation (CME)
>• Compliance Sampling Inspection (CSI)
>• Operation and Maintenance Inspection (O&M)
>• Laboratory Audit
Identify needed preparation and appropriate inspection activities
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Appendix C
Figure C-10 (cont.)
Assessment Preparation Summary
Recommended Steps
Review Facility File
Coordinate/Schedule Inspection
Review Applicable Regulations
Develop Assessment Plan and
Appropriate Checklists)
Identify Necessary Equipment
Complete Pre-Assessment
Worksheet
Objectives
! Review facility file, including past inspection reports, appropriate
permits, correspondence, and enforcement file (such as
obligations under orders and consent decrees)
! Develop and maintain separate facility inspection file
! Identify interested offices or agencies
! Determine whether the inspection will be a joint effort
! Consult compliance officer/agency
>• Inquire about pending enforcement issues
! Identify and review applicable regulations, as determined through
file review
! Obtain and understand relevant amendments to RCRA standards
! Determine State/Federal jurisdiction of new regulations,
amendments
! Develop a plan on how to proceed during on-site assessment,
highlight:
>• Site-specific areas that need to be resolved, outstanding
violations or enforcement
>• Processes generating waste, waste accumulation areas
! Review existing checklists, determine their usefulness and modify
where necessary
! Identify /obtain necessary equipment based on the type of
assessment, e.g.. camera, fieldbook
! Complete pre-assessment worksheet
>• Highlight areas of concern and/or unresolved violations
>• Make appropriate changes to pre-assessment sheet
Worksheets are useful tools for organizing the pre-assessment information
gathering stage. Worksheets may also identify areas of concern and/or questions that
should be explored during the assessment. An example of a pre-assessment worksheet is
included as Figure C-l 1. Any unresolved issues should be noted on an interview sheet and
addressed accordingly.
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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RCRA Summary
Figure C-ll
Pre-Assessment Worksheet
Completed
Pre-Assessment Tasks
Information Source
Obtain and Review Facility Information
Schematics of Process/Production Rates/Wastes
Manifest History
Previous Inspection Reports
Correspondence
Annual/Biannual Reports
Notification Form
Appropriate Permits
Permit Status
Facility Contact Name, Title, Phone and Fax Number
Facility File
Facility File
Facility File
Facility File
Facility File
Facility File
Permit File
Permit Writer
Facility File
Previous Inspection Reports
Obtain and Review Enforcement Regulatory Information
NOVs, LOWs
Facility Responses
Consent Decrees/Orders
Compliance History
Enforcement Status (if ongoing)
Review Pertinent and New Regulations
Determine Jurisdiction
Identify and Contact Interested Offices and/or Agencies
Enforcement File
Enforcement File
Enforcement File
RCRIS
Enforcement File
Regulations (CFR Fed Reg)
Regulations (Fed Reg)
N/A
Develop a Plan on How to Proceed with Assessment
Site specific area to be observed
Process generating waste/waste accumulation area
Past/outstanding violations
Review Existing Checklists, Determine Usefulness — Modify
Where Necessary
Identify and Collect Necessary Inspection Equipment
Schedule Inspection
Past Inspection Reports
Past Inspection Reports
Facility File
Enforcement File
N/A
N/A
N/A
Conducting the Assessment
With the pre-assessment steps completed, the inspector is ready to schedule and
perform the assessment. By following the tasks listed on the pre-assessment worksheet,
including developing a site-specific assessment plan and checklists, the inspector should be
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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RCRA Summary
Appendix C
well prepared to conduct a thorough assessment. Key assessment steps and elements of
each step are included in Figure C-12.
Figure C-12
Key Assessment Steps and Elements
Key Steps
Elements
Opening Conference/Interview
Identify purpose of assessment
Discuss agenda and scheduling
Verify information on pre-assessment worksheet
Update existing facility information
> Rate of production changes, changes in number of employees
> Changes in manufacturing processes (raw material inputs,
process equipment, products, waste streams)
Discuss new waste minimization/pollution prevention measures
Discuss unresolved concerns/ongoing enforcement
Records Review
! Records needed for review:
> Map/facility drawings — prior to facility walk-through
> Manifests, LDR notification and certification
> Appropriate Records Plans — Contingency Plan, Waste
Analysis Plan, Waste Minimization Plan, Training Records,
Biennial Report, Annual Reports (if applicable)
> Exception reports
> List of wastes generated, their origins, rate of generation and
accumulation area (compare with pre-inspection worksheet)
> Facility notification forms
> Summary of names, titles, locations, and phone numbers of
persons involved in hazardous waste program
Visual Assessment
Follow raw material (wood) through process and identify waste
streams (solid and hazardous)
Inspect points of generation and satellite accumulation, <90 day
accumulation area
Evaluate waste handling techniques and procedures
Observe employees handling and management of hazardous
wastes
Check (randomly) solid waste containers for waste types
Evaluate container condition, labeling, marking etc.
Ask questions of facility personnel and the facility guide to
identify any inconsistencies in procedures or gaps in facility
training
Closing Conference
! Identify concerns/potential violations
! Discuss questions noted during record review and/or visual
inspection
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Appendix C RCRA Summary
By following the steps listed in Figure C-12, the inspector will be better able to identify:
Wastes that should have — but may not have been — considered hazardous
Procedures and management practices that may not be in compliance with the
current regulatory requirements
! Steps in the management process that may result in wastes being mishandled or
misidentified, and that present opportunities for spills and/or releases
! Unusual situations that may be encountered that vary from the facility's stated
normal operating procedures that may result in potential violation
When conducting an assessment, an agency inspector should ask questions of the
facility representative guiding them as well as other facility personnel, such as process
operators. By questioning different personnel, the inspector may identify inconsistencies in
explanations of procedures or operations that could indicate possible non-compliance. In
addition, speaking with additional personnel could identify gaps or inadequacies in the
facility's training program.
The inspector may want to use an appropriate checklist (see the model checklists
included at the end of this Appendix). The inspector should try to complete as much of the
checklist as possible during the opening conference and the record review and leave the
sections blank that require visual inspection to complete. If it is cumbersome to complete
the checklist during the visual inspection, the inspector is advised to carry a field notebook
to record observations, and refer to the checklist for general guidance. The checklist may
be completed at a later time. Sole reliance on a checklist may limit the scope and
thoroughness of an inspection. The inspector should be aware of, and investigate, all
relevant waste generation and management activities. The inspector should attempt to
understand how the facility operates, how and where wastes are generated, managed and
stored at the facility, and should rely on the record review (manifests, LDRs, etc.) to assure
that the waste is being handled appropriately after it is transported off-site.
If the facility is performing a self-assessment, the inspector may record observations
in a fieldbook and present the findings on a finding form. An example of a finding form is
included as Figure C-13. The "Finding Information" portion of the form may be completed
after the visual inspection or record review and the "Comment" section may be completed
during or after the closing conference. The finding form can be completed for both
negative and positive findings, as well as for management practices.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page C-30
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RCRA Summary
Appendix C
Figure C-13
Sample Finding Form
Date
Inspector
Type of Finding(+/-)
Bldg/Location (if applicable)
Section I - Finding Information
1. Condition
2. Regulatory Cite (Fed/State)
3. Finding ID Code
5. Finding Type
7. Rating
4. Problem Type
6. Repeat Finding (Y/N)
Section II - Comments
1. Cause(s)
2. Effect(s)
3. Suggested Solution(s)
4. Comments
Key
FINDING IDENTIFICATION CODES
3A Accumulation Points
3B TSD Facilities
3C Training
3D Waste Minimization
3E Others
PROBLEM TYPE CODES
A2
A3
A4
ADMINISTRATIVE
Al Records
Labels
Reports
Manifests
A5 Lack of a permit
A6 Inadequate/Missing Plan
A7 Public Notifications
A8 Operator Certification
A9 Fire Standard
A10 Program Planning
All Sampling
A12 Training
A13 Other
POTENTIAL DISCHARGE
PI Operational Practices
P2 Inadequate Facility
P3 Inadequate Equipment/Containers
P4 Other
DISCHARGE
Dl Excess Chemical Parameter
D2 Excess Physical Parameter
D3 Groundwater Contamination
D4 Spill/Leak
D5 Other
PROBLEM TYPE DESCRIPTIONS:
DISCHARGE — Spilling, leaking, pumping, pouring, emitting, emptying, or damping of a pollutant that is not covered by a permit or exceeds a permit limit.
POTENTIAL DISCHARGE — Physical conditions and operating practices, if left uncorrected, could cause a discharge.
ADMINISTRATIVE — Program management and oversight issues such as plans, permits, training, records, reports, etc.
FINDING TYPE:
REGULATORY — Involves federal, State, or local environmental requirements.
MANAGEMENT PRACTICE -- Environmental procedures/policies which are good practices but are not REGULATORY OR PROCEDURAL.
RATING:
SIGNIFICANT — Requires IMMEDIATE attention, poses a direct threat to human health/safety, can "shut you down."
MAJOR — Requires less than immediate attention, could affect human health/safety, would probably result in a NOV.
MINOR — Procedural, temporary, or occasional deficiencies of no immediate consequence.
MANAGEMENT PRACTICE — Used for positive findings and when the finding is of the management practice type
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
PageC-31
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Appendix C
RCRA Summary
Figure C-14 provides a list of basic equipment needed to perform a CEI, noting the
benefits of each. Photographs provide accurate documentation of observations, and can be
a significant and informative source for review prior to future inspections, informal
meetings, and in preparation of enforcement documentation.
Figure C-14
Necessary Inspection Equipment and Its Use
Necessary Equipment
Purposes/Limitations
Field Notebook
Accurate notes on
> Interviews/conversations with operators and
environmental staff
> Observations
> Inspection Activity
Photograph log
> Date, time
> Number of photo on roll
> Type of film, lens and camera
> Location on site (e.g. . view looking northeast at. . .)
Weather conditions
Record list of documents reviewed
Remember — take notes accurately and objectively
Checklists
Remember Pre-Inspection Worksheet
May be used as guidance tool
May be completed during inspection
Remember — do not rely solely on a checklist; it is only a
tool to organize your inspection and record inspection
observations
Photographs
! Provide "snap-shot" of facility conditions at time of
inspection — validates observations on checklist or in field
notebook
Schematics/Maps
If facility is large, excellent tool for orienting oneself
Provides graphic record, may mark map or schematic with:
> Waste generation areas
> Waste accumulations areas (satellite and <90 day)
> Spill or contamination parameters (size relative to site)
> Where photographs were taken (optional)
Inspector may verify areas inspected by schematic
Maintaining and recording accurate and detailed information during the inspection
is essential from an agency's viewpoint as the information may be used for enforcement
and permitting. In addition, full documentation will be beneficial to future assessments to
determine changes in processes and activities on-site.
After record review and visual inspection have been completed, the assessment
team and facility staff should meet for a closing conference. This will offer an opportunity
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page C-32
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RCRA Summary Appendix C
for the assessment team to resolve outstanding issues, answer questions, and review
findings with the facility staff. At the same time the conference offers the facility staff the
opportunity to respond to the inspector's concerns or questions, and provides a final
opportunity for the facility to claim confidential business information protection for
information collected during the inspection.
If the facility has performed a self-assessment, the appropriate facility staff should
gather and discuss the findings of the assessment team. This is an ideal opportunity for the
facility to involve the operators. The operators can offer insight into day-to-day concerns
and procedures that are contributing to any negative findings the assessment team may
have determined. In addition, this discussion provides a chance for management and staff
problem solving and for development of waste minimization initiatives. The finding form
(Figure C-13) is one way of recording the self-assessment findings, cause and effect of
noted problems, and suggested solutions, all of which can be included in the assessment
report.
Assessment Follow-up
The appropriate follow-up to the compliance inspection will vary depending on
who conducted the assessment and what findings were made, but in all cases, developing
an accurate, clear and concise report outlining the findings of the inspection is important.
The assessment report should include the reason for the assessment, the scope of the
assessment (what was covered), the findings of the assessment, a list of issues and concerns
to be followed-up on, and an indication of what additional assessments may be necessary.
If the assessment has been performed by an agency, the findings are be recorded in
the standard agency format, with all supporting documentation included. Since these
findings may be used as part of a future enforcement action — presentation and accuracy
are crucial.
If the inspection is a facility self-assessment, the report should address many of the
same factual items included in the agency report. In addition, the finding forms should be
included as an attachment. As such, the self assessment may identify the root cause of a
concern or issue, and recommend corrective actions to be taken to rectify these concerns
or issues.
Assessment Checklists
Figure C-15 provides a starting point for developing a specific RCRA generator
checklist appropriate for a particular facility. The form is based closely on a form used by
one State agency.2 Many States will use their own form, and will include State-specific
requirements in addition to federally-based requirements. For a mill in a particular State,
the applicable State agency's form (if available) is likely the best starting point as a model
for use in that State. In addition, for a screening assessment that may be conducted by
non-RCRA inspectors, see the sample screening checklist in Appendix E.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page C-33
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Appendix C
RCRA Summary
Figure C-15
Example RCRA Generator Checklist
I. BASIC DATA
Date of Inspection:
Inspector:
Weather Conditions:
Program:
General Facility Information
U.S. EPA ID No.:
Site Name:
Citv:
County:
Facility Contact:
Telephone No.:
Street:
State: Zio Code:
Title:
Type of Generator (circle appropriate type): SQG/CESQG/LQG
II. WASTE DATA
WASTE STREAM/EPA ID #
(Describe each waste stream including
Production Process)
1.
2.
3.
4.
5.
6.
7.
III. WALK-THROUGH
Generation
Rate
(Per Month)
Disposition
ASSESSMENT PROCEDURES
A. Pretransport, Containerization and Storage
1 . Storage does not exceed 90 days (LQG) or 1 80 days
(SQG)
2. Containers in good condition
3 . Waste compatible with container
n Yes n No
n Yes n No
n Yes n No
Comments
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page C-34
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RCRA Summary
Appendix C
Figure C-15 (cont.)
Example RCRA Generator Checklist
A. Pretransport, Containerization and Storage (cont.)
Comments
4. Containers closed in storage
5. Containers storing incompatible waste separated or
protected from each other by a dike, beam or wall
6. Date of accumulation marked on containers
7. Containers clearly marked "Hazardous Waste"
8. Facility inspected and maintained (weekly)
[Ask for, review self-inspection sheets]
9. Daily inspection of areas subject to spills, i.e., waste
handling areas
[Ask for, review self-inspection sheets]
10. Adequate aisle space available [36"]
11. All containers packaged, marked, and labeled
according to DOT requirements
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
B. Satellite Accumulation
Comments
1. Areas located at or near point where wastes initially
accumulate and are under operator's control
2. Containers clearly labeled "Hazardous Waste"
3. Containers kept closed
4. Containers in good condition
5. Waste compatible with container
6. Quantities accumulated not exceeding 55 gal. (1
quart acutely haz. waste)
7. Container marked identifying contents, beginning
date and "full" date
8. Satellite containers go to storage within 3 days of
"full" date
9. Ignitable/reactive wastes located at least 50 ft. from
property line
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page C-35
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Appendix C
RCRA Summary
Figure C-15 (cont.)
Example RCRA Generator Checklist
C. Preparedness and Prevention and Emergency Procedures
1 . Facility operated and maintained to minimize
possibility of an emergency
2. Adequate and proper spill control, decontamination
and safety equipment available (fire blankets,
respirators, SCBA, absorbents, etc.) and properly
tested and maintained
3 . Adequate water supply and fire control equipment
4. Device in the hazardous waste operation area
capable of summoning emergency assistance
5. Telephone or two-way radio on-site and capable of
summoning local fire or police departments
6. Communication and emergency equipment tested
and maintained
7. Emergency coordinator's name and phone number
posted near phone [SQG only]
8. Telephone number of fire department posted near
phone [SQG only]
9. Location of fire extinguisher and spill control
equipment posted near phone [SQG only]
10. Employees familiar with waste handling and
emergency procedures [SQG only]
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
Comments
IV. RECORD REVIEW ASSESSMENT PROCEDURES
D. Manifests
1 . Facility uses manifest system or [SQG only] wastes
reclaimed under contractual agreement
2. Records maintained for a 3 year period
3 . Manifest document ID and consecutive shipment
numbers
4. Generator's name, address and phone number
n Yes n No
n Yes n No
n Yes n No
n Yes n No
Comments
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page C-36
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RCRA Summary
Appendix C
Figure C-15 (cont.)
Example RCRA Generator Checklist
D. Manifests (cont.)
Comments
5. All transporters' names, phone numbers, license
plate #s, State & EPA ID#s
6. Designated facility name, address, phone, State &
EPA ID#
7. DOT shipping name, Hazard Class and waste ID#
8. Containers, quantity and specific gravity designated
9. Manifest signed and dated
10. Tests waste or uses knowledge of waste to determine
if the waste is restricted from land disposal
11. Appropriate LDNR notices, certifications sent under
Part 268
12. Manifests returned within 35 days
13. If "No" for question #12, contacted TSDF and/or
transporter [LQG only] and filed exception reports if
manifest not received within 45 days (60 days for
SQG)
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
E. Preparedness and Prevention [LQG only unless noted]
Comments
1. Arrangements with local emergency agencies [SQG
only]
2. Emergency coordinator(s) on premise or on call
[SQG only]
3. Personnel are trained to respond to emergencies
including the use of alarm systems, emergency
equipment and contingency plan
4. Employees do not work in unsupervised positions
until they have completed the training
5. Training reviewed annually
6. Program director trained in hazardous waste
management procedures
7. Personnel training plan on-site
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page C-37
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Appendix C
RCRA Summary
Figure C-15 (cont.)
Example RCRA Generator Checklist
E. Preparedness and Prevention [LQG only unless noted]
(cont.)
8. Gives job title, job description and name of
employee filling each position
9. Written description of introductory and continuing
training that will be given to each position
10. Documentation of training completed by personnel
1 1 . Records of current personnel maintained until
facility closure, former employee records maintained
for at least three years
n Yes n No
n Yes n No
n Yes n No
n Yes n No
F. Contingency Plan [LQG only]
1 . Contingency plan maintained on-site
2. Plan submitted to local emergency response
agencies
3 . Emergency coordinator on-site or on call
4. Plan describes actions personnel must take in
response to fires, explosions or other releases of
hazardous wastes
5. Describes arrangements with emergency response
agencies
6. Primary emergency coordinator designated
7. Lists names, addresses and phone numbers (home
and office) of emergency coordinators
8. Evacuation plan, if applicable, designates primary
and secondary routes and evacuation signal
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
n Yes n No
G Used Oil Storage
1 . Containers in good condition
2. Containers storing used oil are not leaking
3 . Containers/aboveground tanks are labeled or marked
clearly "Used Oil"
n Yes n No
n Yes n No
n Yes n No
Comments
Comments
Comments
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page C-38
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RCRA Summary
Appendix C
Figure C-15 (cont.)
Example RCRA Generator Checklist
G. Used Oil Storage (cont.)
4. Fill pipes used to transfer used oil into underground
storage tanks are labeled or marked clearly "Used
Oil"
5. Containers/tanks which are exposed to rainfall are
closed
6. Cleaned up any spills or leaks of used oil
n Yes n No
n Yes n No
n Yes n No
H. Off-Site Shipments to Approved Collection Centers
1 . Used oil is transported by transporters who have
obtained EPA Identification numbers
2. Transports used oil in a vehicle owned by the
generator or owned by an employee of the generator
3. Transports no more than 55 gallons of used oil at
any time
n Yes n No
n Yes n No
n Yes n No
Comments
Comments
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page C-39
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Appendix C RCRA Summary
References:
Cited References:
1. Revised RCRA Inspection Manual, OSWER Directive 9938.02b, U.S. Environmental
Protection Agency, 1993.
2. Inspection Record and Checklist (separate forms for both Large and Small Quantity
Generators), Missouri Department of Natural Resources, Form Nos. MO 780-1525
and MO 780-1802, September 1997.
Additional Available References:
3. Wagner, T.P., The Complete Guide to the Hazardous Waste Regulations, 2d. ed.,
1991.
4. Garrett, T.L. (ed.), The RCRA Practice Manual, American Bar Association, 1994.
5. Skillern, F.F., Environmental Protection Deskbook, Chapter 5, 2d. ed., 1995.
6. Wood Preserving Resource Conservation and Recovery Act Compliance Guide,
Chapter 3, U.S. Environmental Protection Agency (EPA-305-B-96-001), June 1996.
7. Process-Based Self-Assessment Tool for the Organic Chemical Industry, Appendix D,
U.S. Environmental Protection Agency (EPA-305-B-97-002), April 1997.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page C-40
-------
APPENDIX D: EPCRA
Regulatory and Assessment
Procedures Overview
Overview
The Emergency Planning and
Community Right-to-Know Act
(EPCRA), also known as the
Superfund Amendments Reauthorization Act (SARA) Title III, provides primarily for
dissemination of information on hazardous chemicals used by, released from, or otherwise
managed as waste by, a facility. There are four main functional areas under EPCRA, as
shown in Figure D-l below. All of the EPCRA requirements will likely apply to kraft pulp
mills based on the size, scope and nature of the facilities. The following sections briefly
summarize each area, and the final section highlights screening techniques for evaluating
EPCRA compliance.
Figure D-l
EPCRA Functional Areas
Emergency Planning
Emergency Notification
MSDS and Inventory
Information
Toxic Release
Reporting
Designate on-site facility emergency coordinator
Notify State/local emergency planning officials of
facility's status and name of on-site coordinator
Identify hazardous substances and reportable quantity
threshold for spills/leaks
Immediately notify if spill, leak or other release
exceeds reportable quantities. Notify National
Response Center and State/local emergency officials
Prepare or have available MSDS for all OSHA
hazardous chemicals used on site
Submit copies of MSDS for hazardous chemicals used
in excess of specified thresholds
Send copies to State/local emergency officials, along
with Tier I/Tier 2 inventory updates annually
Report annually quantities of listed toxic chemicals
entering each environmental medium, including land
disposals of toxic chemicals and off-site transfers of
waste containing toxic chemicals
Use standard form (Form R or Form A)
No specified calculation method applies, but fugitive
releases are included
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
PageD-l
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Appendix D EPCRA Overview
Emergency Planning
The emergency planning requirements apply if the facility has certain extremely
hazardous substances above threshold quantities specified in the regulations (40 CFR Part
355). The facility must notify the State emergency response agency and local emergency
planning commission (40 CFR 355.30). The facility must designate an emergency response
coordinator and provide the coordinator's name to the applicable emergency response
officials.
Emergency Notification
In the event of a spill, leak, or other release of a reportable quantity for a CERCLA
hazardous substance or an EPCRA extremely hazardous substance, the facility generally
must provide immediate notification to the State and local emergency agencies (40 CFR
355.40). If the release is of a CERCLA hazardous substance, the facility also must notify
the National Response Center (NRC) ((800) 424-8802), pursuant to CERCLA and 40 CFR
302.6. EPA logs notifications to the NRC into EPA's Emergency Response Notification
System (ERNS) database. The list of CERCLA hazardous substances is published at 40
CFR 302.4. The list of EPCRA extremely hazardous substances is published at 40 CFR
355 Appendix A. Figure D-2 lists several substances that are associated with kraft pulp
mill operations that are included in the lists of chemicals subject to EPCRA and/or
CERCLA emergency reporting. The figure also indicates the reportable quantity for each
chemical. Figure D-2 is a non-exclusive list - there likely are additional chemicals that
could be released from kraft pulp mill operations that could be subject to EPCRA or
CERCLA reporting. Also note that, for several of the compounds listed in Figure D-2, it
would be unlikely for mills to have releases that exceed the reportable quantity threshold.
Emergency reporting is not xTm™ ^ ^ n v* ,1 i
. , ° . ,, , NOTE! Federally permitted releases are
required for certain types of exempted x , J r
, A, . "1 ^ _>.• • exempt from emergency reporting
releases. Most important, reporting is . , „, , ,:_ TTI^T,fTT ,,.
. , ,, r- j ,, f requirements. Check the EPCRA Hotline
not required for federally permitted /* onn ^ ^ «v* ^ *• -ui j ^ j
, M , c , , J ;,,__„ . (1-800-424-9346) for possible updates and
releases as denned under CERCLA. ,.,... , .
„. -ill • i- clarifications on what constitutes a
These include releases in compliance „ , „ _ , ,
. . . . , . , federally permitted release.
with regulations and permits under I
various environmental statutes,
including the Clean Air Act, Clean
Water Act, and Resource Conservation and Recovery Act. See CERCLA section 101(10)
for the statutory definition.
In addition, for certain types of "continuous releases," special reporting procedures
apply. A continuous release is one that occurs without interruption or abatement, and is
stable in quantity or rate, or that is routine, anticipated, intermittent, and incidental to
normal operations. In these circumstances, special regulatory notice provisions established
under CERCLA apply. Those provisions include an initial telephone and written notice, an
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page D-2
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EPCRA Overview
Appendix D
update notice after one year, and then notices of changes in the source or composition of a
release, in the normal range of the release, or any statistically significant increase in the
release. In some circumstances, a facility can use the TRI Form R report (with certain
additional information) as the basis for reporting these types of releases under CERCLA
(but not for EPCRA). See 40 CFR 302.8 and 355.40 for further detail. Also see the EPA
report" Reporting Requirements for Continuous Releases of Hazardous Substances: A
Guide for Facilities on Compliance" (EPA 540-R-97-047).
Figure D-2
Non-Exclusive List of Chemicals Associated with Kraft Mill Operations
for CERCLA/EPCRA Emergency Reporting
Hazardous Substance
Sulfur dioxide
Nitrogen dioxide
1 ,4-Dichlorobenzene
2,4,5-Trichlorophenol
2-Butanone (MEK)
Acetaldehyde
Acetophenone
Acrolein
Arsenic*
Benzene
Cadmium*
Carbon tetrachloride
Chlorine
Chloroform
Chromium*
CERCLA
RQ (in Ibs)
-
10
100
10
5,000
1,000
5,000
1
1
10
10
10
10
10
5,000
EPCRA
RQ (in Ibs)
500
10
-
-
-
-
-
1
-
-
-
-
10
10
-
Hazardous Substance
Formaldehyde
Hexane
Hydrochloric acid
Hydrogen sulfide
Mercury
Methanol
Methyl chloroform
Methyl isobutyl ketone
Methyl mercaptan
Methylene chloride
Phenol
Propionaldehyde
Styrene
Toluene
Xylenes
CERCLA
RQ (in Ibs)
100
5,000
5,000
100
1
5,000
1,000
5,000
100
1,000
1,000
1,000
1,000
1,000
100
EPCRA
RQ (in Ibs)
100
-
-
100
-
-
-
-
100
-
1,000
-
-
-
-
* Not applicable if the diameter of the solid metal is > 0.004 inches (100 micrometers)
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
Page D-3
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Appendix D EPCRA Overview
Hazardous Chemical Reporting
For each hazardous chemical used at the facility and subject to the Material Safety
Data Sheet (MSDS) requirement under the Occupational and Safely Health Act, the owner
or operator must provide the MSDS to the state/local emergency agencies and the local
fire department. In addition, the facility must provide annually a current inventory of those
hazardous chemicals. At a minimum, this involves a "Tier 1" report that aggregates the
hazardous chemicals by hazard category. At an agency's request, the facility also must
submit a "Tier 2" report that identifies specific information on specific chemicals. A facility
need not submit MSDS, or Tier 1 or 2 information on a chemical if at any one time the
facility had less than 500 pounds of the chemical (if an extremely hazardous substance) or
10,000 pounds of the chemical (for all other hazardous chemicals) (40 CFR 370.20-
370.28). Many kraft pulp mills likely will be required to submit Tier 2 reports because the
mills are significant, large facilities. Based on a limited review of sample Tier 2 reports
submitted by four kraft pulp mills, Figure D-3 provides an example, non-exclusive list of
the types of materials that could be listed in a Tier 2 report for a kraft mill. The list is by
process area; note that for the papermaking process in particular, mills will have a variety
of additional chemicals listed in an actual report based on the types of additives and other
materials used at the particular mill. Also note that for the papermaking area in particular,
it appears from the example reports reviewed that mills may report the trade name of the
chemicals used and not the actual chemical substance.
Toxic Release Inventory (TRI) Reporting
Covered facilities that manufacture, process, or otherwise use listed toxic chemicals
above threshold quantities must file TRI reports annually, using "Form R" or "Form A" as
developed by EPA (40 CFR Part 372). TRI reports estimate all releases and other waste
management quantities, through all media (including air, water, and land disposals), of
listed toxic chemicals. Covered facilities also must report the quantity of toxic chemicals in
waste transferred offsite. Currently, the TRI list includes over 600 chemicals and chemical
categories.
The regulations (40 CFR Part 372) do not require that releases be calculated in any
particular manner for TRI reporting purposes, nor does EPCRA establish any monitoring
or testing requirements to support TRI reporting. Instead, a facility may rely on existing
information and estimates to prepare TRI reports. For the kraft pulp sector, recent audits
suggest that mills are using estimation models and techniques developed by the National
Council of the Paper Industry for Air and Stream Improvement, Inc. (NCASI) to develop
release information for TRI reporting.
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page D-4
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EPCRA Overview
Appendix D
Figure D-3
Example List of EPCRA Tier 2 Report Chemicals (by Process Area)
Process Area
Substances
Kraft Pulping
Anthraquinone
Antifreeze
Black/White Liquor
Gasoline
Hydrochloric Acid (HC1)
Hydrogen Sulfide (H2S)
Oil-Based Defoamer
Paraffinic/Napthalenic Solvent
Propane, Liquid
Sodium Hypochlorite
Sodium Hydrosulfide
Sodium Hydroxide (NaOH)
Sulfuric Acid (H2SO4)
Tall Oil
Tall Oil Sodium Salt
Turpentine
Chemical Recovery/
Causticizing
C1102
Caustic Soda
Green/White Liquor
Fuel Oil (Nos. 2, 4, or 6)
Hydrogen Sulfide (H2S)
Kerosene
Lime (CaO), Quicklime
Lime Mud (CaCO3), Lime Slurry
Muriatic Acid
Propane, Liquid
Recycled Oil
Salt Cake (Na2SO4)
Sodium Hydrosulfide
Sodium Hydroxide (NaOH)
Sulfuric Acid (H2SO4)
Sulfur, Liquid
Bleach Plant
Chlorine Dioxide
Methanol (CH3OH)
Paraffinic/Napthalenic Solvent
Sodium Chlorate
Sodium Chloride (NaCl)
Sodium Hydroxide (NaOH)
Sulfuric Acid (H2SO4)
Wastewater
Treatment Plant
Ammonia, Aqueous
Antifreeze
Chlorine (C12)
Ferric Sulfate
Lime Slurry
Paraffinic/Napthalenic Solvent
Phosphoric Acid
Sodium hydroxide (NaOH)
Sulfuric Acid (H2SO4)
Power Plant
Coal
Chlorine (C12)
Fuel Oil (Nos. 2, 4, or 6)
Flyash (coal)
Hydrogen (H2)
Hydrogen Sulfide (H2S)
Lubricating Oil
Morpholine
Oxygen (O2)
Paraffinic/Napthalenic Solvent
Propane, Liquid (C4H10)
Sulfuric Acid (H2SO4)
Woody ard and
Miscellaneous
Processes
Antifreeze
Diesel Fuel
Gasoline
Grease
Hydrogen Sulfide (H2S)
Kerosene
LPGas
Lubricating Oil
Methyl Acetylene Propadiene
Propane (liquid)
Salt Cake (Na2SO4)
Varsol
Papermaking
Alum
Chlorine (C12)
Custom Sperse (various)
Diesel Fuel
Dye (various)
Foamaster (various)
Muriatic Acid
Nalbrite (various)
Nalco (various)
Nopcote (various)
Rosin Size (various)
Sodium Hypochlorite
Starch
Sulfuric Acid (H2SO4)
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Appendix D EPCRA Overview
Key Assessment Strategies
Other than for emergency notification requirements, an EPCRA compliance
assessment generally involves a records review. For the facility, an assessment should
begin with establishing a complete inventory of all hazardous chemicals used on site and
verifying that the appropriate MSDS sheets, as well as current inventory estimates, are
available. Next, the assessment should ensure that basic notifications to State and local
emergency response agencies are current. Finally, the TRI "Form R" report should be
checked. If NCASI or similar estimation techniques are used, the assessment should
consider whether any extended process or control device upsets have occurred. If so, the
facility should evaluate whether the estimates, although they may be appropriate to use
generally, need to be adjusted to address the additional releases resulting from the upset
conditions.
An agency inspector can screen for compliance with these same EPCRA
requirements by confirming the information with the facility contact during the opening
conference or just in advance of the closing conference. For an announced inspection, the
inspector should ask the source to have EPCRA-related documentation ready so that this
screening check can be performed without interrupting the main focus of the inspection. A
screening checklist is included in Appendix E.
A mill or an agency inspector also must verify compliance with emergency
notification requirements. As an initial step, mill personnel should review internal training
programs and operating procedures to determine whether these elements are adequate to
ensure operator awareness and understanding of these requirements. Next, mill personnel
should review all plant upset and malfunction records, as well as accidental releases
associated with raw material handling, and then cross-check to see if an emergency
notification was made. If not, the mill should evaluate the severity of each incident to
confirm that the notification requirements were not triggered. In addition, mill personnel
should review whether routine releases are federally permitted and in compliance with
those permits. An agency air, water or waste inspector can screen for compliance with
these requirements by requesting that the source provide the relevant documentation for
review (see Appendix E for basic screening checklist questions).
For an agency EPCRA inspector, a more detailed approach, similar to the
appropriate approach for mill personnel, can be used to identify potential compliance
concerns with emergency notification requirements. The inspector can check general mill
upset reports and citizen complaints since the previous inspection, and then cross-check
those incidents with notification records identified in EPA's ERNS database, records on file
with State/local emergency officials, or records requested from the mill. For episodes of
releases in which no notification is provided, further investigation to determine if reportable
quantity thresholds were exceeded may be warranted. Figure D-4 provides an overview of
the steps and considerations involved in this type of assessment.
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EPCRA Overview
Appendix D
Figure D-4
Assessment Considerations for EPCRA/CERCLA Emergency Notifications
Upset records/citizen
complaint/other tip received
Check with State/local
officials to determine if
immediate notice received
Determine if CERCLA
notice given - Check ERNS
If no notice received,
contact/visit facility to determine
cause and likelihood of RQ
threshold being exceeded
STOP, if clearly
unlikely that RQ
threshold
exceeded
If exceeds RQ threshold,
DOCUMENT: Quantity
released and timing of
notification, if any
EVALUATE: Source
training/procedures for operator
awareness of emergency
reporting obligations
Was cause attributable to
non-standard operations?
"\^
If no, was release in
excess of allowable
limits?
If yes, evaluate opei
records and source ii
records to estim.
release quantit
rating
icident
ite
y
If no, STOP
STOP, if release
below RQ
threshold
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Appendix D EPCRA Overview
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APPENDIX E: Example
Assessment Forms
Overview
This Appendix provides a
series of example assessment forms
for the process areas described in
Sections 4 through 9 of this manual. The forms are designed primarily for the agency
inspector, as opposed to self-audit assessments. The forms generally cover the same issues
discussed in the "inspection considerations" portions of each of the relevant sections. In
addition, set out on the next two pages are screening checklists for EPCRA and RCRA
that are not process-specific. These screening checklists may be useful for the air or water
inspector if asked to screen for compliance with these other media statutes.
The forms are designed generally to evaluate whether a kraft pulp mill is in
compliance, although particular items for follow-up investigation are noted where
applicable. The forms are not geared toward evaluating applicability or other decisions
made during the permitting process. The forms do not include the basic forms already
available as part of the underlying media inspection guidance, if applicable (such as the
forms available in the NPDES Compliance Inspection Manual).
Finally, EPA notes that the forms are intended only as generalized examples. These
forms are not intended to replace mill-specific forms that may have been developed by
individual inspectors or offices nor to replace other general forms that a particular agency
or inspector may use. The forms also do not replace compliance checklists that may be
designed for a particular regulation. Instead, the forms provide a synopsis of much of the
detail found in Sections 4 through 9 of the manual, and can be used by inspectors to update
or refine existing inspection forms that they may use.
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Appendix E
Example Assessment Forms
Example RCRA Screening Form
(The following provides an example screening form for RCRA issues that are not process-
specific; additional process-specific RCRA issues are addressed in the process-based forms
where applicable)
RCRA Generator Screening Questions
Does the facility have an EPA ID No. for Hazardous
Waste Generation? If yes, provide ID #
How are waste determinations made?
What Generator status is claimed?
Are records available to document amount of
generation by month?
Are manifests available in organized file?
What are the primary wastes generated and what
process(es) generate the waste? (Provide Waste Type,
Process and EPA ID #)
Were any of the units that contain or handle wastes in
(circle all that apply):
Describe any units identified in the preceding
question.
Is there any evidence of current or past releases? If
so, please describe.
n Yes n No
ID#:
Sampling Knowledge Both
LQG SQG CESQG
n Yes n No
n Yes n No
Type (ID):
Type (ID):
Type (ID):
Type (ID):
Type (ID):
Type (ID):
(add more rows as necessary)
(a) poor condition (d) leaking
(b) unmarked (e) cracked
(c) opened (f) corroded
n Yes n No
Notes:
4>EFV\ This manual is intended solely for guidance and May 1999
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Example Assessment Forms
Appendix E
Example EPCRA Screening Form
(The following provides an example screening form for EPCRA issues that are not
process-specific; additional process-specific EPCRA issues are addressed in the process-
based forms where applicable)
General EPCRA Screening Questions
Have all hazardous chemicals been inventoried?
Are Tier I/Tier 2 inventories current?
Are appropriate MSDS data sheets available?
Has the facility designated an emergency response coordinator?
Has the facility given necessary notifications to State and local emergency
response agencies?
Are TRI Form R reports complete and current, including a Form R for all TRI
chemicals manufactured, processed or otherwise used over the applicable
threshold?
If applicable, do the Form R reports consider significant upsets/malfunctions
increasing releases beyond estimates from use of standard models/guidelines?
Does the facility have an established training program and written operating
procedures to ensure EPCRA compliance? [Note: not a regulatory
requirement; for screening purposes only]
Have any releases that are not federally permitted occurred at the facility during
the period of review?
If releases have occurred, does the source have documentation that the releases
were reported to State and local emergency agencies and to the National
Response Center (or that no notice was required) ?
D Yes D No
D Yes D No
D Yes D No
D Yes D No
D Yes D No
D Yes D No
D Yes D No
D Yes D No
D Yes D No
D Yes D No
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Appendix E Example Assessment Forms
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Example Assessment Forms
Appendix E
Pulping Process Area: Example Assessment Form
I. Air Emissions ~ Basic Unit Data (include row for each separate equipment system
for following categories of emissions units, as applicable)
Unit ID
Digester(s)
MEE(s)
Washer(s)
Knotter(s)
Screen(s)
Decker(s)
Oxygen
Delignification
Condensates
Other controlled
points
LVHC or
HVLC
Applicable
Regs.
Primary
Controls
Backup
Controls
II. Air Inspection
A. General: (1) Units properly identified in permit? Yes No N/A
(2) Operating rates w/i Permit Limits/Normal Op.? Yes No N/A
(3) Identify any inoperative units:
(4) Other general notes/concerns:
B. Uncontrolled Venting:
(1) Evaluate records (either through records required by Cluster Rules
or through mill's DCS, if available) to determine extent of
uncontrolled venting over last reporting period.
Is uncontrolled venting:
! Within permit allowable rates?
! < 1% of operating time?
Yes No
Yes No
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Appendix E Example Assessment Forms
(2) If uncontrolled venting exceeds 1% of operating time, consider follow up investigation
to determine cause(s) of problem and any corrective actions taken by source. Findings
include:
C. Enclosure/Closed-vent System:
(1) Monitoring/inspection plan available? Yes No
(2) Logs properly filled out? Yes No
(3) Identify any problems:
(4) Identify results of any portable leak checks/other inspections for these requirements
conducted while on-site:
D. Incinerator Evaluation (if applicable):
(1) Monitored Parameters (as applicable):
Parameters Actual Values Allowable/Baseline Values
! Temperature:
! TRSCEMS:
! HAP CMS:
— Are all monitors in proper working order, with
documentation of all required QA/QC? Yes No
— Identify problems:
(2) Identify any follow-up checks conducted:
E. Condensates Evaluation:
(1) If recycling compliance option used, identify any problems
noted through records review and/or visual observations:
(2) If condensates segregation option is used, do monitoring
records demonstrate that segregation requirements are met? Yes No
(3) Closed Collection/Closed-vent Systems:
! Monitoring/inspection plan available? Yes No
! Logs properly filled out? Yes No
! Identify any problems:
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Example Assessment Forms Appendix E
! Identify results of any portable leak checks/other inspections for these requirements
conducted while on-site:
(4) Steam Stripper (if applicable):
! SFR: (actual) (allowab^aseline)
! Methanol CMS: (actual) (allowable/baseline)
! Are all monitors in proper working order, with
documentation of all required QA/QC? Yes No
- Identify problems:
! Identify any follow-up checks conducted:
(5) WWTP Biological Treatment System (if applicable):
! Have all required percent reduction efficiency tests
been performed? Yes No
! Have all required tests demonstrated compliance?: Yes No
! Results of most recent test:
! Since last inspection, have any tests been triggered by
parameter value excursions? Yes No
! If so:
— Was test passed? Yes No
- Did mill take all appropriate corrective actions within
required timeframe? Yes No
! Are all monitors in proper working order, with
documentation of all required QA/QC? Yes No
- Identify problems:
Are discharge points below liquid surface? Yes No
Identify any follow-up checks conducted or
problems noted:
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Appendix E Example Assessment Forms
(6) Note: If biological treatment system other than WWTP system is used, evaluation will
be based on site-specific parameters; identify the parameters and complete the
following (add lines as necessary for each parameter):
! Parameter #1: (actual) (allowab^aseline)
! Parameter #2: (actual) (allowable/baseline)
! Are all monitors in proper working order, with documentation
of all required QA/QC? Yes No
- Identify problems:
! Identify any follow-up checks conducted:
III. Water Inspection ~ See BMP checklist on following pages
IV. RCRA
(1) Are surface impoundments used to manage spent black liquor? Yes No
! If yes, what liner material is used, if any?
(2) Are there indications of spills/leaks that affect the ground
(such as discoloration, puddling, dead vegetation, or
liquid channeling? Yes No
! If yes to either question, consider forwarding to RCRA inspector
for follow-up regarding leaks, and for a determination of whether
liquor from impoundments is sent to wastewater treatment instead
of being reused in process (which could affect treatment of material
as a RCRA solid waste)
(3) Are hazardous wastes generated in this area and/or are satellite
accumulation sites located in this area? Yes No
Not Checked
! If yes, consider completing RCRA screening checklist at
beginning of this Appendix
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Example Assessment Forms Appendix E
SPENT PULPING LIQUOR, TURPENTINE & SOAP BMP PLAN CHECKLIST
Evaluation of the BMP Plan
d Engineering review of pulping and chemical recovery systems included in Plan:
d Process equipment
d Storage tanks
d Pipelines and pumping systems
d Loading and unloading facilities
d Other equipment in spent pulping liquor, soap, and turpentine service (note below)
d Selection of monitoring parameter:
d Appropriate parameter selected
d Appropriate sampling location
d Required BMP Elements included in Plan:
d Return of diverted or spilled liquor to the process to the maximum extent practicable as
determined by the mill
d Establishment of preventive maintenance programs for equipment in spent pulping liquor
service
d Continuous, automated monitoring systems (i.e., alarms, conductivity monitors, or pH meters)
on storage tanks, in process areas, in process sewers, in process wastewater, and in
wastewater treatment plant to detect leaks, spills, and intentional diversions
d Annual training for personnel involved with operating, maintaining, or supervising operation
of equipment in spent pulping liquor, turpentine, or soap service
d Preparation of reports evaluating spill events not contained in the immediate process area
d Establishment of a program to review any planned facility modifications and construction
activities in the pulping and chemical recovery facilities
d Installation of secondary containment for spent pulping liquor bulk storage tanks or an annual
tank integrity testing program coupled with diversion structures
d Installation of secondary containment for turpentine bulk storage tanks
d Installation of curbing or diking systems for turpentine and soap processing areas
d Wastewater treatment influent monitoring to track BMP performance and effectiveness and to
detect trends in spent liquor losses (EPA has recommended that mills monitor for COD, but
other parameters may be used)
d Plan updated as elements of program are implemented
d Action levels updated
d Lower action level
d Upper action level
Notes/Concerns:
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Appendix E
Example Assessment Forms
SPENT PULPING LIQUOR, TURPENTINE & SOAP BMP PLAN CHECKLIST (cont.)
BMP Plan Implementation
A. Training
Yes No N/A
Yes No N/A
Yes No N/A
1 . Has the facility held annual training for personnel involved with operating,
maintaining, or supervising operation of equipment in spent pulping liquor,
turpentine, or soap service?
2. Is the facility achieving the training goals outlined in the BMP Plan?
3 . Are records of training activities maintained for three years?
B. Repair
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
1 . Has the facility recorded repairs of equipment in spent pulping liquor, soap
and turpentine service?
2. Has the facility implemented the control measures outlined in the BMP
Plan?
3 . Has the facility implemented changes to equipment to prevent reoccurrence
of unintentional spent pulping liquor spills?
4. Are records of repairs maintained for three years?
C. Spills
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
1 . Has the facility prepared reports on each spill or intentional diversion not
contained in the immediate process area?
2. Do the reports include:
equipment involved,
circumstances leading to the incident,
effectiveness of the corrective actions taken to contain or recover the spill
or intentional diversion,
plans to develop changes to equipment and operating and maintenance
practices as necessary to prevent reoccurrence?
3 . Has the inspector reviewed the status of planned changes with facility staff?
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Example Assessment Forms
Appendix E
SPENT PULPING LIQUOR, TURPENTINE & SOAP BMP PLAN CHECKLIST (cont.)
BMP Plan Implementation (cont.)
D. Monitoring Systems
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
1
2
3
4
5
6
Have storage tank alarms been installed?
Is the location of storage tank alarm signals (audio or visual) appropriate?
Do the storage tank alarm signals provide sufficient notice to allow
operator response?
Have conductivity monitors and/or pH meters been installed in the process
areas, process sewers and wastewater treatment plants?
Are the conductivity monitors and/or pH meters in appropriate locations?
Do the conductivity monitors and/or pH meters provide sufficient signal for
operator response?
E. Containment Structures and Tank Integrity Testing
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
1
2
3
4
5
6
7
Have curbing or diking systems for turpentine and soap processing areas
been installed according to the BMP Plan?
Have secondary containment structures for turpentine bulk storage tanks
been installed according to the BMP Plan?
Has the facility opted to install secondary containment structures for spent
pulping liquor bulk storage tanks?
Have secondary containment structures for spent pulping liquor bulk
storage tanks been installed according to the BMP Plan?
Has the facility opted to implement tank integrity testing for spent pulping
liquor bulk storage tanks?
Is the facility using diversion structures?
Has the inspector reviewed the procedures used to perform tank integrity
tests?
8. Are tank integrity tests conducted annually?
9
Has the inspector reviewed the results of tank integrity testing?
10. Does the permit specify minimum requirements for tank integrity testing
programs?
1
F.
Yes No N/A
1
1 . Do the records of the tank integrity testing program show that the facility
meets applicable permit requirements for such programs?
Pulping and Chemical Recovery Equipment
Do records show that construction and modification activities are evaluated
to consider prevention of spills and leaks during changes to pulping and
chemical recovery areas?
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Appendix E
Example Assessment Forms
SPENT PULPING LIQUOR, TURPENTINE & SOAP BMP PLAN CHECKLIST (cont.)
BMP Plan Implementation (cont.)
G. Influent Monitoring
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
Has inspector reviewed periodic monitoring reports?
Do the periodic monitoring reports reveal trends which should be
addressed? (Note below)
Has the inspector discussed trends in the monitoring data with facility
Were lower action levels exceeded?
staff?
Were investigations of such exceedances conducted according to the BMP
Plan?
Were upper action levels exceeded?
Were corrective actions implemented according to the BMP Plan?
Has the inspector discussed exceedances with facility staff?
Has the inspector discussed pollution prevention measures that may be
implemented in response to exceedances?
Has the facility selected an appropriate monitoring parameter?
Do the sampling procedures meet applicable permit requirements?
Are the sampling points in appropriate locations?
Has the inspector collected a sample to verify the accuracy of the sampling
program?
H. Notes/Concerns
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Example Assessment Forms Appendix E
V. EPCRA
Note: Includes only process-specific EPCRA screening for emergency reporting; see
general screening checklist at beginning of Appendix E.
(1) Does the facility have TRS limits for all affected emission
points - LVHC and HVLC? Yes No
(2) If yes, were there excess emission periods that were not in
compliance with permit? Yes No
! If yes, consider forwarding to EPCRA inspector for further
evaluation to determine if RQ threshold of 100 lb/24-hour period
was exceeded for H2S or methyl mercaptan
(3) If no, continuing release reporting may apply for unregulated points.
Has source filed required report or documented that reporting does
not apply? Yes No
(4) Prior to compliance dates for Cluster Rules, are all emission points
subject to HAP emission limits? Yes No
(5) If no, continuing release reporting may apply for unregulated points.
Has source filed required report or documented that reporting does
not apply? Yes No
(6) Were there HAP excess emissions not in compliance with permit
during reviewed time period? Yes No
! If yes, consider forwarding to EPCRA inspector for further
evaluation of whether emissions exceeded RQ thresholds for
various chemicals in HAP emissions
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Example Assessment Forms
Appendix E
Chemical Recovery Operations: Example Assessment Form
I. Air Inspection
A. General: (1) Units properly identified in permit? Yes No N/A
(2) Production Rate:
(3) w/i Permit Limits/Normal Op.? Yes No N/A
(4) Identify any inoperative units:
(5) Other general notes/concerns:
Emissions Units
[add rows as
appropriate]
TRS Limits
B. Recovery Boiler Operations
! Point ID:
MACT Limits
PM Limits
Other Limits
Control(s)
! Used for NCG control?: Yes No
Backup
! Type: DCE NDCE ! Subject to NSPS? Yes No
! Process Data: Black Liquor Feed Rate: Steaming Rate:
(1) Any periods of ESP compartment downtime since last inspection?
Yes No
! If so, was process adjusted to accommodate reduced ESP capacity? Yes No
(attach documentation if requested)
(2) CEMSData: TRS:
07: _
(Actual)
(Actual)
(Allowable)
(Allowable)
! Are all monitors in proper working order, with documentation
of all required QA/QC?
Yes No
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Appendix E
Example Assessment Forms
— Identify problems:
! Indicate if DCS used to obtain trend/recent data (attach any print-outs):
(3) VEO Results:
! Opacity levels (attach VEO form): Compliance?
! Increase (>5%) in baseline opacity?:
— If Yes, conduct follow-up
! Excessive spikes/puffing?:
— If Yes, check rapper operation
(4) Basic ESP Data (repeat chart for each ESP chamber):
Yes No
Yes No
Yes No
T-R
Set#
1
2
3
4
5
6
Primary Volts
Actual
Base
Primary Amps
Actual
Base
Secondary
KVolts
Actual
Base
Secondary
Milliamps
Actual
Base
Sparks/Minute
Actual
Base
(5) Follow-up ESP Data (if necessary):
! Apparent Rapper Operation:
! Component Failure Records Checks:
! Inlet/Outlet temperature drop:
! Audible Indications of Air Infiltration:
! Proper hopper discharge operations:
(Actual)
(Baseline)
Yes No
Yes No
— Identify problems:
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Example Assessment Forms Appendix E
C. Smelt Dissolving Tank: Point ID: Subject to NSPS? Yes No
(1) Scrubber Data
! Fan Vibration: Can you hear sounds of excessive vibration? Yes No
If so, stop inspection and inform site personnel of safety concern.
Parameters Actual Values Baseline Values
! Pressure Drop: in. H2O in. H2O
! Scrubber Liquid Supply Pressure:
! Pump Discharge Pressure:
! Pump Motor Current:
! Can you hear signs of pump cavitation? Yes No
! Adequate nozzle maintenance procedures/activities, if applicable? Yes No
! Physical indications of poor scrubber operation
(circle as applicable)?
— Shell/Ductwork Corrosion — Mud lip at stack discharge
-- Other (Identify):
(2) If suspect TRS problem, indicate sulfur content of inlet water/scrubbing liquid:
(3) Other checks (Identify):
D. Lime Kiln Operations: ! Point ID: ! NSPS? Yes No
(1) Process Data:
! Kiln Production Rate: ! Lime Mud Feed Rate:
! Fuel Firing Rate: ! Kiln Exit Temp:
! Kiln Rotation Rate:
(2) Used for NCG controls: HVLC LVHC Neither Backup Only
(3) VEO Check:
! Levels in compliance (attach form)? Yes No
! Presence of Rainout? Yes No
! If condensing plume does not permit RM 9,
indicate general visible conditions: High Average Low
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Appendix E Example Assessment Forms
(4) CEMSData:
! Opacity: (Actual) (Allowable)
! TRS: (Actual) (Allowable)
! O2: (Actual) (Allowable)
! Monitoring QA: OK Problems (Identify):
! Indicate if DCS used to obtain trend/recent data (attach any print-outs):
(5) Kiln Operating Data:
! Any kiln downtime since last inspection? Yes No
! If so, is there documentation of TRS backup controls
being used during those periods (if applicable): Yes No
! Were there periods of plant production increases since
last inspection? Yes No
! If so, consider checking opacity CEMS data and pressure
drop data (for scrubber-controlled kilns) to determine
if controls properly operated during such periods.
(6) Scrubber Data (Note, if ESP used, see above under
recovery boiler):
! Can you hear sounds of excessive fan vibration? Yes No
— If so, stop inspection and inform site personnel of safety concern.
Parameters Actual Values Baseline Values
! Pressure Drop: in. H2O in. H2O
! Scrubber Liquid Supply Pressure:
! Pump Discharge Pressure:
! Pump Motor Current:
! Can you hear signs of pump cavitation? Yes No
! Adequate nozzle maintenance procedures/activities, if applicable? Yes No
! Physical indications of poor scrubber operation
(circle as applicable)?
— Shell/Ductwork Corrosion — Mud lip at stack discharge
- Other (Identify):
(7) Identify any concerns for the lime kiln:
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Example Assessment Forms Appendix E
E. Lime Mud Washers: Mud Feed Rate: Sodium Content:
(1) Any checks on capture/control? Yes No
! Hood Static Pressure:
! Pressure Drop:
! Liquid Flow Rate:
(2) Results of VE checks: (attach VEO form, if applicable)
F. Other Process Equipment (Slakers and Storage/Handling Equipment)
(1) Controls operating? Yes No
(2) Any VE concerns? Yes No
(3) Identify any other concerns/checks conducted:
G. Asbestos D&R
(1) Indications of recent activities likely to disturb asbestos? Yes No
(2) If yes, does the source have appropriate D&R notice/records,
or documentation to support requirements applicable? Yes No
II. Other Inspection Items
A. Water
(1) Any lime mud slurries sewered during upsets/maintenance
periods? Yes No
! If yes, air inspector should forward to NPDES inspector
for follow-up
(2) Are there outdoor storage and handling areas? Yes No
! If so, are they addressed in the mill's SWPP Plan? Yes No
[Note: Use Pulping Process Area Example Assessment Form
for assessments of black liquor, soap, and turpentine management
involving applicable units that may be located in chemical
recovery area.]
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Appendix E Example Assessment Forms
B. RCRA
(1) Does mill have documentation that pH of liquid green liquor
dregs, slaker grits and lime mud sent to landfill is <12.5? Yes No
(2) Are dregs, grits and lime mud dewatered before disposal? Yes No
(3) Does the facility have paint filter test results to document that
these are dewatered, not aqueous, wastes? Yes No
(4) Are green liquor dregs, slaker grits and/or lime mud stored
in a surface impoundment? Yes No
! If yes, identify the liner material (if any):
(5) Does the mill collect, treat or manage elsewhere in the mill
any stormwater or groundwater from the unit in which the
dregs, grits or lime mud is stored (if so, identify location)? Yes No
! Location (if any):
(6) Are hazardous wastes generated in this area and/or are
satellite accumulation sites located in this area? Yes No
Not Checked
! If yes, consider completing RCRA screening checklist at
beginning of this Appendix
C. EPCRA
Note: Includes only process-specific EPCRA screening for emergency reporting; see
general screening checklist at beginning of Appendix E.
(1) Does the facility have SO2 and NOX limits for both the
recovery boiler and lime kiln? Yes No
(2) If yes, were there excess emission periods that were not in
compliance with permit? Yes No
! If yes, consider further evaluation to determine if RQ
threshold(s) exceeded
(3) If no, continuing release reporting may apply. Has source either
filed required report or documented that reporting does not apply? Yes No
(4) Were there TRS excess emissions not in compliance with permit
during reviewed time period? Yes No
! If yes, consider further evaluation of whether TRS compounds
exceed RQ of 100 lb/24-hours (for H2S or methyl mercaptan)
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Example Assessment Forms
Appendix E
Bleach Plant Operations: Example Assessment Form
I. Basic Unit Data
Bleach Line ID
C
H
Bleaching Sequence
= Chlorine D = Chlorine Dioxide E =
= Hypochlorite P = Peroxide Z =
Sodium Hydroxide
Ozone
(extraction)
II. Air Inspection
A. General
(1) Units properly identified in permit?
(2) Production Rate:
(3) w/i Permit Limits/Normal Op.?
(4) Identify any inoperative units:
(5) Other general notes/concerns:
B. Bleaching System Control Systems
(1) Bleaching System ID:
Scrubber Parameters:
! pH (or Oxidation Reduction Potential):
! Gas Inlet Flow Rate:
! Scrubber Liquid Flow Rate:
! Chlorine Outlet CEMS:
(2) Monitoring QA acceptable?
! Identify Problems:
Actual
Yes No
Yes No
Allowable
Yes No
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Appendix E Example Assessment Forms
(3) Enclosures/Closed Vent System
! Monitoring/inspection plan available? Yes No
! Logs properly filled out? Yes No
! Identify any problems:
! Identify results of any portable leak checks/other inspections for
these requirements conducted while on-site:
II. Water Inspection
A. DMR Follow-up
(1) Did the DMRs reviewed prior to the inspection indicate violations
or increasing pollutant levels for bleach plant wastewater? Yes No
(2) If yes, review causes with mill operators and identify potential
causes/corrective actions taken:
B. Compliance Sampling Procedures
(1) Indications of increased flow rate during sampling period? Yes No
(2) For mills that still use chlorine and/or hypochlorite, were samples
taken during periods when these materials were in use: Yes No
(3) Are kappa factors within normal ranges? Yes No
(4) Are temperature and pH readings across bleaching stages within
normal ranges? Yes No
C. Permit Accuracy
(1) Were permit mass-based limits (AOX and chloroform) based on
production levels consistent with normal operation levels? Yes No
! If no, refer issue to NPDES permit writer
D. Facility Inspection
(1) Do bleaching towers/extraction stages show signs of corrosion? Yes No
(2) Any leaking from bleach plant washers or savealls? Yes No
(3) Is there excessive entrained air in sewer lines? Yes No
(4) Is there adequate documentation of sampling procedures? Yes No
(5) Are monitoring locations proper? Yes No
(6) Is the bleach plant layout consistent with schematic used to locate
monitors and develop permit limits? Yes No
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Example Assessment Forms
Appendix E
E. Flow Monitoring
(1) Monitoring locations appropriate?
(2) Monitors functioning properly?
(3) Monitor calibration frequency:
Date of last test:
Yes
Yes
! Note: Also complete relevant portions of standard NPDES
Compliance Inspection Manual checklist.
F. Sampling Evaluation
(1) Appropriate collection methods used? Yes
(2) Sampling handling procedures meet 40 CFR 136 requirements? Yes
(3) Lab oratory/Q A: Part of overall WWTP assessment - see Section 7
No
No
No
No
IV. RCRA
(1) Has the facility analyzed chloroform levels discharged to the WWTP,
POTW, or other wastewater impoundment? Yes No
! If yes, indicate results:
(2) Are hazardous wastes generated in this area and/or are satellite
accumulation sites located in this area?
! If yes, consider completing RCRA screening checklist at
beginning of this Appendix
Yes No
Not Checked
V. EPCRA
(1) Does the facility have chorine and chloroform emission limits
(such as Part 63 MACT standards) for all emission points for these
pollutants at the bleach plant? Yes
(2) If yes, were there periods of excess emissions that were not in
compliance with permit?
! If yes, consider further evaluation to determine if RQ threshold
(10 lb/24-hour period for both substances) was exceeded.
! If no, continuing release reporting under EPCRA/EPCRA may
apply. Has source either filed required report or documented that
reporting does not apply? Yes No
No
Yes No
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Example Assessment Forms
Appendix E
Wastewater Treatment Plant Operations: Example Assessment Form
I. Water Inspection
(1) Complete and fill out NPDES Water Compliance Inspection Report (Form 3560-3)
(2) Consider elements in the appropriate checklists in the NPDES Compliance Inspection
Manual in developing findings for report, as applicable to scope of inspection
(3) Consider the following additional issues:
NPDES COMPLIANCE AND ASSESSMENT CHECKLIST
A. PERMIT VERIFICATION
Yes No N/A
Yes No N/A
Yes No N/A
1 . Permit includes appropriate limits for non-continuous discharger (if
applicable).
2. Does facility co-treat municipal wastewater? If yes, verify that appropriate
additional monitoring records and reports are complete and document
compliance (e.g. for total/fecal coliform).
3. Do foam restrictions apply? If yes, review applicable records to verify
compliance.
B. RECORDKEEPING AND REPORTING EVALUATION
Yes No N/A
Yes No N/A
Yes No N/A
Yes No N/A
1 . BMP monitoring records for black liquor, soap and turpentine management
(such as COD/TOC sampling or conductivity /color continuous monitoring)
are adequate.
2. If monitor records indicate BMP action levels exceeded, do records
document appropriate corrective action taken?
3. Do WWTP operator records indicate liquor, soap, turpentine spills that are
nor recorded under BMP records?
4. Did mill prepare report of all liquor, soap or turpentine spills/intentional
diversions not contained in immediate process area?
C. OPERATION AND MAINTENANCE EVALUATION
Yes No N/A
Yes No N/A
1 . Facility has procedures for notifying WWTP personnel of highly
contaminated wastewater from pulping/chemical recovery area.
2. Are all monitors required by the liquor, soap and turpentine BMPs in
proper operating condition? Also, indicate monitor calibration
frequency /unusual results (if any):
D. SAMPLING EVALUATION
Yes No N/A
1 . Mill followed method-specified sampling procedures (see permit and
Figures 7-7 and 7-8 in Section 7 of this manual).
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Appendix E Example Assessment Forms
(4) Storm water Issues:
! Does SWPP Plan document how WWTP runon/runoff
is addressed? Yes No
! Do quarterly visual inspection records indicate any concerns? Yes No
! If yes, do records document appropriate corrective action? Yes No
! Note any concerns or issues with implementation of
SWPP Plan BMPs:
II. Air
(1) If biological treatment system at WWTP used to treat condensates,
use procedures in Pulping Process Example Assessment Form for
evaluating compliance with Cluster Rules requirements.
(2) Water inspector: Is discharge of hardpiping of pulping condensates
occurring below liquid surface in WWTP? Yes No
! If no, forward to air inspector for follow up
III. RCRA
(1) Is chloroform discharged from the WWTP? Yes No
(2) If yes, what is the pH of the chloroform discharge?
(3) Are hazardous wastes generated in this area and/or are satellite
accumulation sites located in this area? Yes No
Not Checked
! If yes, consider completing RCRA screening checklist at
beginning of this Appendix
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Example Assessment Forms Appendix E
IV. EPCRA
(1) Check air emission estimates in the mill's Form R report for wastewater
treatment emission points. For chemicals subject to EPCRA/CERCLA
emergency reporting, do the emission estimates for normal operations
appear to exceed applicable RQ thresholds for the chemicals released
to the air (such as 10 lb/24-hour period for chlorine and chloroform)? Yes No
! If yes, continuing release reporting under EPCRA/CERCLA may
apply unless the mill has emission limits for these compounds from
these emission points. Has source either filed required report or
documented that reporting does not apply? Yes No
(2) Were there treatment plant upsets during the period reviewed or
other indications that discharges exceeded permit limits? Yes No
! If yes, does the plant have records of emergency reports under
EPCRA or CERCLA for periods in which the upsets/permit
exceedances occurred? Yes No
! If no, forward to EPCRA inspector for follow up
(3) Do BMP spill record reports indicate potential releases of
EPCRA/CERCLA hazardous substances? Yes No
! If yes, consider forwarding to EPCRA inspector for follow up
on emergency reporting compliance
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Example Assessment Forms
Appendix E
Power Boiler Operations: Example Assessment Form
I. Boiler Data
Unit ID
MMBTU/HR
Fuel(s)
Applicable
Regs.
Control(s)
II. Air Inspection
A. General: (1) Units properly identified in permit? Yes No N/A
(2) Operating rates w/i Permit Limits/Normal Op.? Yes No N/A
(3) Identify any inoperative units:
(4) Other general notes/concerns:
B. VEO Results (attach applicable VEO forms): Compliance? Yes No N/A
C. Boiler O&M Practices
(1) Fuel sulfur content:.
(actual)
(allowable)
(2) Fuel type within permit limits?
(3) Operating hours within any applicable limits?
(4) Identify any follow-up checks or concerns:
Yes No
Yes No
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Appendix E
Example Assessment Forms
D. CEMSData
Unit ID
SO2
! Identify any CEMS operation
NOx
Opacity
TRS
ial concerns:
E. Control System Data (complete for each applicable system used)
ESP Controls (if used)
(1) Electrical Parameter Data (repeat chart for each ESP chamber):
T-R
Set#
1
2
3
4
5
6
Primary Volts
Actual
Base
Primary Amps
Actual
Base
Secondary
KVolts
Actual
Base
Secondary
Milliamps
Actual
Base
Sparks/Minute
Actual
Base
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Example Assessment Forms Appendix E
(2) Follow up ESP Data:
! Apparent Rapper Operation:
! Component Failure Records Checks:
! Inlet/Outlet temperature drop: (Actual) (Baseline)
! Audible Indications of Air Infiltration: Yes No
! Proper hopper discharge operations: Yes No
- Identify problems:
Scrubber (if used)
(1) Can you hear sounds of excessive fan vibration? Yes No
! If yes, stop inspection and inform site personnel of safety concern.
(2) Parameters Actual Values Baseline Values
! Pressure Drop:
! Scrubber Liquid Supply Pressure:
! Pump Discharge Pressure:
! Pump Motor Current:
(3) Can you hear signs of pump cavitation? Yes No
(4) If nozzles used, does source have maintenance log? Yes No
! Does it appear that nozzle maintenance is being performed
consistent with source's standard procedures and that no unusual
increases in maintenance needs are occurring? Yes No
(5) Visible Compliance Indicators:
! Shell/Ductwork Corrosion? Yes No
- If so, consider liquor pH follow-up: discuss with source)
! Mud lip at stack discharge point? Yes No
If so, indication of reentrainment problems
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Appendix E Example Assessment Forms
Fabric Filter (if used): Pulse Jet Reverse Air
Shaker Other:
(1) Parameters Actual Values Baseline Values
! Pressure Drop:
! Inlet Temperature:
! Outlet Temperature:
! Compresses Air Pressure:
(2) Audible/visible checks of cleaning system: Identify any concerns:
(3) Visible/audible checks for air infiltration, corrosion, hopper discharge. Identify any
concerns:
(4) Identify any follow-up activities:
Multicyclones (if used):
(1) Pressure drop within normal range? Yes No
(2) Hopper discharge practices acceptable? Yes No
(3) Gas flow rates near nominal design rates? Yes No
(4) Identify any concerns:
F. Asbestos D&R
(1) Indications of recent activities likely to disturb asbestos? Yes No
(2) If yes, does the source have appropriate D&R notice/records, or
documentation to support requirements applicable? Yes No
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Example Assessment Forms Appendix E
III. Water Inspection
(1) Oil-fired Boilers
! Is SPCC plan required? Yes No
! If yes, is the SPCC plan available for inspect on? Yes No
! Has the facility recorded any recent spills, leaks, or similar events? Yes No
! If yes, forward to water inspector for follow up
! Observe containment curbs/other measures for tank storage;
are there any obvious problems (applicable to SPCC and
storm water compliance)? Yes No
! Identify any concerns/comments:
(2) Storm Water Issues
! Is the SWPP plan available for inspection? Yes No
! Does the SWPP plan include following BMPs for power
boiler operations, as applicable (circle all that apply)?
[See Section 9 for general SWPP plan checklist]
— Fugitive dust control, especially for coal handling
— Delivery/residue hauling vehicles
— Fuel oil/chemical unloading operations
— Storage tanks and facilities
— Ash loading
— Other spills and leaks
! Does the mill have records of any required monitoring? Yes No
! For coal-fired boilers, observe coal pile runon/runoff control
procedures and note any obvious problems or concerns:
IV. RCRA
(1) Does the facility burn any hazardous waste, used oil, or hazardous
waste liquids in the power boilers? Yes No
! If yes, identify material burned:
(2) Are hazardous wastes generated in this area and/or are satellite
accumulation sites located in this area? Yes No
Not Checked
! If yes, consider completing RCRA screening checklist at
beginning of this Appendix
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Appendix E Example Assessment Forms
V. EPCRA Inspection
Note: Includes only process-specific EPCRA screening for emergency
reporting; see general screening checklist at beginning of Appendix E.
(1) Does the facility have SO2 and NOX limits for each power boiler? Yes No
(2) If yes, were there excess emission periods that were not in
compliance with permit? Yes No
! If yes, consider further evaluation to determine if RQ
threshold(s) exceeded)
(3) If no, continuing release reporting may apply. Has source either
filed required report or documented that reporting does not apply? Yes No
(4) If used for NCG control, were there TRS excess emissions not in
compliance with permit during reviewed time period? Yes No
! If yes, consider further evaluation of whether TRS compounds
exceed RQ of 100 lb/24-hours (for H2S or methyl mercaptan)
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Example Assessment Forms Appendix E
Woodyard, Papermaking and Other Operations: Example Assessment Form
I. Air Inspection
(1) Woodyard Operations:
! Are there any fugitive dust problems observed? Yes No
! If permit requirements apply for fugitive dust control, are all
required control methods in operation? Yes No
! If water spray system used, is spray pattern appropriate? Yes No
! Water pressure (if applicable): (observed) (baseline)
! Water flow rate (if applicable): (observed) (baseline)
(2) Other Operations:
! Does the mill have industrial process refrigeration subject to
section 608 (stratospheric ozone protection) requirements? Yes No
! If yes, complete checklist on next page.
II. Water Inspection
(1) Does the mill use wet wood handling operations? Yes No
! If yes, does the permit include allowances for discharges from
these operations? Yes No
! If no, then evaluate further and forward to permit writer for follow up
(3) Identify any storm water permit concerns (use the SWPP Plan
Checklist on following pages as a tool to evaluate content and
implementation of plan):
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Appendix E
Example Assessment Forms
General Section 608 Screening Questions
(1) Does the facility have industrial process refrigeration units with CFC
and/or HCFC charges of 50 pounds or greater?
(2) Does the facility service, maintain, or repair this refrigeration equipment
with company employees? If no, go to question number 4.
(3) Do all service technicians have EPA approved technician certification?
NOTE: Approved 608 technician certifications contain the following
language, "[Name of person] has been certified as a [Type I, Type II,
Type III and/or Universal, as appropriate] technician as required by 40
CFR part 82, subpart F. "
(4) Does the facility keep all maintenance records on all 50+ pound units?
(5) Does that facility calculate the leak rate on all 50+ pound units? NOTE:
The leak rate that triggers mandatory repairs is 35% in a 12 month period.
(6) Are leaks above the allowable leak rate repaired within 30 days, or 120
days if an industrial process shut down is required?
(7) If leak repairs have been conducted, was an initial verification test
conducted before refrigerant was recharged into the system?
(8) If leak repairs have been conducted, was a follow-up verification test
conducted within 30 days of the successful initial verification test?
(9) If no repairs were conducted or repairs failed, was a retrofit or retirement
plan prepared and available for review?
(10) Does the company own refrigerant recovery equipment?
(11) Has the company submitted to EPA a recovery equipment certification
form? NOTE: Ask to see a file copy.
D Yes HI No
D Yes HH No
D Yes HI No
D Yes HI No
D Yes HH No
D Yes HH No
D Yes HI No
D Yes HH No
D Yes HI No
D Yes HH No
D Yes HI No
Copies:
! If any technicians are not EPA certified for 608, make a copy of at
least 1 record that shows the technician performing work involving
the refrigerant.
! If any no answer in questions 4, 6, 7, 8 and it is a reasonable amount,
make a copy of available maintenance records for each 50+ pound
unit receiving a no answer.
! Make a copy of any retrofit or retirement plan.
Notes:
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Example Assessment Forms Appendix E
SWPP PLAN - REVIEW OF PLAN ELEMENTS
1. Pollution Prevention Team
d Identify specific individuals
d Outline their responsibilities
2. Description of potential pollutant resources, including:
d Site map indicating:
d Drainage areas
d Drainage patterns/outfalls
d Structural and non-structural controls
d Surface waters
d Significant materials exposed to precipitation
d The location of leaks or spills that have occurred in the last 3 years
d Location of industrial activities exposed to precipitation including:
d Fueling stations
d Vehicle/equipment maintenance or cleaning areas
d Loading/unloading areas
d Waste treatment, storage, or disposal areas
d Liquid storage tanks
d Processing areas
d Storage areas
d A list of pollutants likely to be present in the discharges
d Description of significant materials handled, treated, stored, or disposed of such that exposure
to storm water occurred in the last 3 years
d Description of the method and location of storage or disposal
d Description of all material management practices
d Description and location of existing structural and non-structural controls
d List of significant spills and leaks that occurred in the 3 years prior to the effective date of the
permit
d Summary of existing storm water sampling data
d Description of areas with a high potential for significant soil erosion
d A narrative summarizing potential pollutant sources
A description of appropriate measure and controls, including:
d Good housekeeping procedures
d Preventive maintenance procedures
d Spill prevention and response procedures
d Inspection procedures
d Employee training program
d Recordkeeping and internal reporting procedures
d Non-storm water discharge certification or failure to certify non-storm water discharge
certification
d Identify authorized non-storm water discharges and appropriate controls
d Erosion and sediment controls for areas with a high erosion potential
d A narrative consideration of traditional storm water management practices
d Plan for implementation and maintenance of traditional measures found to be reasonable and
appropriate
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Appendix E Example Assessment Forms
SWPP PLAN - REVIEW OF PLAN ELEMENTS (cont.)
4. d Annual site compliance evaluation reports (prepared after the inspection is performed) including:
d A summary of the scope of the inspection
d Personnel making the inspection
d Major observations
d Actions taken to revise the Pollution Prevention Plan
d Certification of compliance or a list of incidents of non-compliance
5. d If discharging to a large or medium municipal separate storm sewer, compliance with applicable
requirements in the municipal storm water management program
6. d Consistency of the storm water pollution prevention plan with other plans
7. Additional requirements for facilities subject to Emergency Planning and Community Right to Know
Act (EPCRA) Section 313 requirements
d A description of the measures used in areas where Section 313 water priority chemicals are stored,
processed, or otherwise handled to:
-Minimize the potential contact or storm water run-on with the chemicals
-Prevent exposure of the chemicals to storm water and wind
d A discussion of the measures taken to minimize the discharge of Section 313 water priority
chemicals from the following areas:
d Liquid storage areas
d Non-liquid storage areas
d Truck and railcar loading areas
d Transfer, processing, or handling areas
d Other areas
d Preventive maintenance and housekeeping
d Facility security
d Training
d Professional Engineer (PE) certification every 3 years
8. d Assurance that any salt storage piles onsite are covered or enclosed
Notes/Comments on SWPP Plan Review:
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Example Assessment Forms
Appendix E
SWPP PLAN - REVIEW OF BMP IMPLEMENTATION
A. FUELING
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1.
2
o
J.
4.
5.
6.
7.
Has spill and overflow prevention equipment been installed?
Are vehicle fuel tanks often "topped off?
Have steps been taken to protect fueling areas from rain?
Is runon to the fueling area minimized?
Are oil/water separators or oil and grease traps installed in storm drains
in the fueling area?
Is the fueling area cleaned by hosing or washing?
Do you control petroleum spills?
8. Are employees aware of ways to reduce contamination of storm water
at fueling stations?
9.
Where does the water drain from the fueling area?
B. MAINTAINING VEHICLES AND EQUIPMENT
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
No
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
1.
2.
o
J.
4.
5.
6.
7.
Are parts cleaned at the facility?
Has the facility looked into using nontoxic or less toxic cleaners or
solvents?
Are work areas and spills washed or hosed down with water?
Are spills or materials washed or poured down the drain?
Are oil filters completely drained before recycling or disposal?
Are incoming vehicles and equipment checked for leaking oil and
fluids?
Are wrecked vehicles or damaged equipment stored onsite?
8. Does the facility recycle any of the automotive fluids or parts?
9.
10.
11.
Can the facility reduce the number of different solvents used?
Are wastes separated?
Does the facility use recycled products?
C. PAINTING VEHICLES AND EQUIPMENT
Yes
Yes
Yes
Yes
No
No
No
No
N/A
N/A
N/A
N/A
1.
2.
3.
4.
Is care taken to prevent paint wastes from contaminating storm water
runoff?
Are wastes from sanding contained?
Are parts inspected before painting?
Is the facility using painting equipment that creates little waste?
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
May 1999
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Appendix E
Example Assessment Forms
SWPP PLAN - REVIEW OF BMP IMPLEMENTATION (cont.)
C. PAINTING VEHICLES AND EQUIPMENT (cont.)
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
5. Are employees trained to use spray equipment correctly?
6. Does the facility recycle paint, paint thinner, or solvents?
7. Are wastes separated?
8. Can the facility reduce the number of solvents used?
9. Does the facility use recycled products?
D. WASHING VEHICLES AND EQUIPMENT
Yes
Yes
No
No
N/A
N/A
1 . Has the facility considered using phosphate -free biodegradable
detergents?
2. Are vehicles, equipment, or parts washed over the open ground?
E. LOADING AND UNLOADING MATERIALS
Yes
Yes
Yes
Yes
Yes
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
1 . Are tank trucks and material delivery vehicles located where spills or
leaks can be contained?
2. Is loading/unloading equipment checked regularly for leaks?
3 . Are loading/unloading docks or areas covered to prevent exposure to
rainfall?
4. Are loading/unloading areas designed to prevent storm water runon?
5. Is piping system routinely checked for leaks?
F. LIQUID STORAGE IN ABOVE-GROUND TANKS
Yes
Yes
Yes
Yes
Yes
G.
Yes
Yes
Yes
Yes
No
No
No
No
No
N/A
N/A
N/A
N/A
N/A
1 . Do storage tanks contain liquid hazardous materials, hazardous wastes,
or oil?
2. Are operators trained in correct operating procedures and safety
activities?
3 . Does the facility have safeguards against accidental discharge?
4. Are tank systems inspected, and is tank integrity tested regularly?
5. Are tanks bermed or surrounded by a secondary containment system?
INDUSTRIAL WASTE MANAGEMENT AND OUTSIDE MANUFACTURING
No
No
No
No
N/A
N/A
N/A
N/A
1 . Has the facility looked for ways to reduce waste at the facility?
2. Has the facility considered waste reduction BMPs?
3 . Are industrial waste management and outside manufacturing areas
checked often for spills and leaks?
4. Are industrial waste management areas or manufacturing activities
covered, enclosed, or bermed?
This manual is intended solely for guidance and
does not alter any statutory or regulatory requirements.
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Example Assessment Forms Appendix E
SWPP PLAN - REVIEW OF BMP IMPLEMENTATION (cont.)
G. INDUSTRIAL WASTE MANAGEMENT AND OUTSIDE MANUFACTURING (cont.)
Yes
Yes
Yes
Yes
H.
Yes
No
No
No
No
N/A
N/A
N/A
N/A
5. Are vehicles used to transport wastes to the land disposal or treatment
site equipped with anti-spill equipment?
6. Does the facility use loading systems that minimize spills and fugitive
losses such as dust or mists?
7. Are sediments or wastes prevented from being tracked off site?
8. Is storm water runoff minimized from the land disposal site?
OUTSIDE STORAGE OF RAW MATERIALS, BY-PRODUCTS, OR FINISHED
PRODUCTS
No
N/A
1 . Are materials protected from rainfall, runon, and runoff?
III. RCRA
(1) Solid Waste Landfills:
! Does the mill maintain records of all waste streams
landfilled on-site? Yes No
! For each waste stream, do the records document how the mill
characterized the waste and made a determination that the waste
is not hazardous? Yes No
! Were any free liquids observed in the landfill? Yes No
! Are all training, inspection and other recordkeeping requirements
specified by permit up-to-date and available for inspection? Yes No
! To the extent required, review available monitoring data.
Within specified permit limits? Yes No
— Identify evidence of any problems:
! Is leachate handling in accordance with solid waste permit? Yes No
! If leachate sent to WWTP or storm water outfall, does NPDES
permit allow for this practice? Yes No
! Identify any other concerns, such as obvious O&M problems,
signs of spills or improper unloading practices:
(2) Are hazardous wastes generated in this area and/or are satellite
accumulation sites located in this area? Yes No
Not Checked
! If yes, consider completing RCRA screening checklist at
beginning of this Appendix
This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page E-41
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Appendix E Example Assessment Forms
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This manual is intended solely for guidance and May 1999
does not alter any statutory or regulatory requirements. Page E-42
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