Development Document
                          for

Proposed Effluent Limitations Guidelines and Standards
                        for the

  Pulp, Paper and Paperboard Point Source Category
             Engineering and Analysis Division
             Office of Science and Technology
                    Office of Water
           U.S. Environmental Protection Agency
                 Washington, DC 20460

                     October 1993

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                              TABLE OF CONTENTS
 1.0
2.0
                                                                 Page

 CONCLUSIONS	      M
 1.1    Introduction 	             1-1
 1.2    Subcategorization  	' ] ' *   j.j
 1.3    Scope of Proposed Rules	'.'.'.'.'.   1-1
 1.4    Best Practicable Control Technology Currently
        Available (BPT) 	   ^
 1.5    Best Conventional Pollutant Control Technology
        (BCT)	6J	   x_2
 1.6    Best Available Technology Economically Achievable
        (BAT)  	   x_2
 1.7    New Source Performance Standards (NSPS) 	   1-2
 1.8    Pretreatment Standards for  Existing Sources (PSES)  	   1-2
 1.9    Pretreatment Standards for  New Sources (PSNS)	 .   1-2
 1.10   Best Management Practices (BMP)	'.'.'.'.'.'.'.'.   1-3

 BACKGROUND  . ,	          2-l
 2.1 ,    Clean Water Act Requirements	  2-1
       2.1.1  Best Practicable Control Technology Currently
             Available (BPT) ~ Section 304(b)(l) of the
             CWA	  2-1
       2.1.2  Best Conventional Pollutant Control
             Technology (BCT)  -  Section 304(b)(4) of the
             CWA	  2-1
       2.1.3  Best Available Technology Economically
             Achievable (BAT) ~  Section 304(b)(2) of the
             CWA	  2.2
       2.1.4  New Source Performance Standards (NSPS) -
             Section 306 of the CWA	  2-2
       2.1.5  Pretreatment Standards for Existing Sources
             (PSES) - Section 307(b) of the CWA	  2-2
       2.1.6  Pretreatment Standards for New Sources
             (PSNS) ~ Section 307(b) of the CWA	  2-3
       2.1.7  Best Management Practices (BMP)	  2-3
2.2    Overview of the Industry	  2-3
       2.2.1  Raw Materials  	       2-3
       2.2.2  Pulping Processes	     2-4
       2.2.3  Pulp Bleaching	         2-5
       2.2.4  Paper Making	  2-6
2.3    Prior Regulations	     2-6

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                                                                  9 7
2.4   Summary of Environmental Studies	  L~'
      2.4.1   Swedish Studies  	  ^'
      2.4.?   National Dioxin Study  	  L~'
      2.4.3   Five-Mill Study	  L~'
      2.4.4   104-Mill Study  	•	  L'\
      2.4.5   National Study of Chemical Residues in Fish	  ^-»
      2.4.6   Air Emission Findings	  ^
      2.4.7   Dioxin Reassessment  ,	  ^~*
2.5   Litigation History (Since the 1982 Promulgation)	  2-y
2.6   Pollution Prevention Act	   "
2.7   Integrated Regulatory Development  	^™
      2.7.1   Technical Approach  	™
      2.7.2  Results	™
2.8   References  	•	

SUMMARY OF DATA COLLECTION METHOD^  	  3-1
3.1    Introduction  	: '  ";	
       3.2.1  Evaluation of Five-Mill and 104-Mill Study
             Data	  \~l
       3.2.2  Short-Term  Studies	  *~
       3.2.3  Long-Term  Study  	  ;f 4
 3.3    National Census Questionnaire	  3-°
 3 4    Data Collection From Non-U.S. Mills  	  J--J
 3.5    Data Collected for NESHAP	3-10
 3.6    Supplementary Data Collection	;™
       3.6.1  Public Meetings	3-10
       3.6.2  Mill Site Visits	3-li
       3.6.3  Literature	•  • • 3~n
       3.6.4  Information from Other EPA Offices and
             Agencies	3-11
       3.6.5  Voluntary Submission of Data	3-12
 3.7   References	3-12

 DESCRIPTION OF THE INDUSTRY	  4-1
 4.1    Introduction	   '
 4.2    Manufacturing Processes	  J"1
        4.2.1  Overview of Manufacturing Processes	  4-1
        4.2.2  Fiber Furnish and Fiber Furnish Preparation
              and Handling	  4-2
        4.2.3  Pulping Processes	  4"4
                                         11

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       4.2.4   Chemical Recovery Processes	  4.7
       4.2.5   Pulp Processing  	  4.9
       4.2.6   Bleaching	4_10
       4.2.7   Stock Preparation	4.11
       4.2.8   Pulp, Paper, and Paperboard Making  	4-12
 4.3 :   Manufacturing Processes Profile  	4-14
       4.3.1   General Overview of the Industry	4.14
       4.3.2   Fiber Furnish and Fiber Furnish Preparation
              and Handling	4.15
       4.3.3   Pulping Processes	447
       4.3.4   Chemical Recovery Processes	4.19
       4.3.5   Pulp Processing  .	4_19
       4.3.6   Bleaching	4_2Q
       4.3.7   Pulp, Paper, and Paperboard Making  	4-24
 4.4    Trends in the Industry	4.25
       4.4.1   Trends  in Production and Products	4-25
       4.4.2   Trends  in New Mill Construction 	4-26
       4.4.3   Trends  in Fiber Furnish Use	] ',[ 4-26
       4.4.4   Trends  in Pulping	4_27
       4.4.5   Trends  in Bleaching 	4.27
 4.5    References  	        4.27

 SUBCATEGORIZATTON  	  5_!
 5.1    Introduction 	    5.^
 5.2    Description of Current Industry Subcategorization and
       Rationale for Changing the Current Subcategorization	  5-1
 5.3    Methodology for Revising Industry Subcategorization	  5-2
       5.3.1  Methodology - Conventional Pollutants	  5-3
       5.3.2  Methodology - Priority and Nonconventional
             Pollutants	5_lg
       5.3.3  Factors  Considered	      5_2i
5.4    Proposed Industry Subcategorization  . . .	5.26
       5.4.1  Subpart A - Dissolving Kraft Subcategory	5-27
       5.4.2  Subpart B - Bleached Papergrade Kraft and
             Soda Subcategory	5.27
       5.4.3  Subpart C - Unbleached Kraft Subcategory	5-27
       5.4.4  Subpart D - Dissolving Sulfite Subcategory	'.'. 5-27
       5.4.5  Subpart E - Papergrade Sulfite Subcategory  	5-28
       5.4.6  Subpart  F - Semi-Chemical Subcategory 	5-28
       5.4.7  Subpart  G - Mechanical Pulp Subcategory	] 5-28
                                        111

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      5.4.8  Subpart H - Non-Wood Chemical Pulp
            Subcategory  	^-28
      5.4.9  Subpart I - Secondary Fiber Deink Subcategory	>^»
      5.4.10 Subpart J - Secondary Fiber Non-Deink
            Subcategory	5"2y
      5.4.11 Subpart K - Fine and Lightweight Papers from
            Purchased Pulp Subcategory	5'29
      5.4.12 Subpart L - Tissue, Filter, Non-Woven, and
            Paperboard from Purchased Pulp Subcategory	5-29
5.5    Production Normalizing Parameters .	5-30
      5.5.1  Conventional Pollutants  	J-3U
      5.5.2  COD and Color 	-	^-3U
      5.5.3  Volatile and Chlorinated Pollutants	3-JU
5.6    References  	5"31

WATER USE AND WASTEWATER CHARACTERISTICS  	  6-1
6.1    Water Use and Sources of Wastewater 	  6-1
      6.1.1  Wood Preparation  	  6-2
      6.1.2  Pulping	•	  ™
      6.1.3   Chemical Recovery	  °"^
      6.1.4   Bleaching	  °~°
      6.1.5   Pulp Handling and Papermaking	  °-/
6.2   Water Reuse and Recycle	  °-°
      6.2.1   Wood Preparation  	  °-8
       6.2.2  Pulping	  *£*
       6.2.3   Chemical Recovery	  °~^
       6.2.4  Bleaching	  °~9
       6.2.5  Pulp Handling and Papermaking	6-1U
       6.2.6  Complete Wastewater Recycle  	6-10
 6.3    Wastewater Characterization - Conventional Pollutants	6-13
       6.3.1  Background and Definitions   	6-13
             6.3.1.1       BOD5  	6-14
             6.3.1.2       TSS	6'14
       6.3.2  Sources of Information	6-14
       6.3.3  Current Discharge Loadings  	6-15
       6.3.4  Estimate of Raw  Waste Loads  	6-16
 6.4   Wastewater Characterization - Priority and
       Nonconventional Pollutants	6-18
       6.4.1  Background and Definitions	6-18
       6.4.2  Sources of Information	6-22
                                         IV

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        6.4.3  Mill Water Supply  	6_23
        6.4.4  Brown Stock Washing Wastewaters	 6-24
        6.4.5  Bleach Plant Wastewaters	 6-25
        6.4.6  Paper Machine White Waters	.'!.'.' 6-31
        6.4.7  Treated Wastewater Effluents	 6-31
        6.4.8  Wastewater Treatment Sludges	'   6-35
        6.4.9  Non-Chemical and Non-Wood Pulping and
              Bleaching Mills	   6-36
 6.5    References	                   	g_30

 SELECTION OF POLLUTANT PARAMETERS	    7.1
 7.1    Review of Previous Regulations	  7-2
        7.1.1   Conventional Pollutants	        7_2
        7.1.2   Nonconventional Pollutants	    7.3
       7.1.3   Priority Pollutants	  	  7_3
 7.2   Selection Criteria	  7_4
       7.2.1   Conventional Pollutants  	...'...   7-4
       7.2.2  Nonconventional and Priority Pollutants 	         7.4
 7.3    Pollutants Not Regulated	  7.5
       7.3.1  Pollutants Not Detected	    7-6
       7.3.2  Pollutants Detected But Only At One Facility . . .  . . . . .  7-6
       7.3.3  Pollutants Detected But Below Concentrations
             of Concern	                 7_7
       7.3.4  Pollutants Controlled by Control of Another	'
             Analyte  	                7_7
       7.3.5  Pollutants Remaining Under Consideration for
             Regulation	        7_o
7.4    Subcategories Not Regulated	  j.%
       7.4.1  Non-Chemical Pulp Mills and Chemical Non-	
             Wood Pulp Mills that Bleach with Chlorine
             and/or Hypochlorite	             7,9
7.5    Pollutants Selected for Regulation	 . .  . ', . . . .   7.11
       7.5.1  Conventional Pollutants   ....                 	711
       7.5.2  AOX,  COD, and Color	'.'.'.'.'.'.'.'.'.'.'.'.'. '. 7-11
       7.5.3  Priority and Nonconventional Pollutants .	• • • • • ^^
7.6    References ....                                  	n «,-
                        	/-lo

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POLLUTION PREVENTION AND WASTEWATER TREATMENT
TECHNOLOGIES	; • • • '	  ^
8.1   Introduction  	,'".'"'' j	
8.2   Pollution Prevention Controls Used in Pulping and
      Delignification Processes	   "
      8.2.1  Chip Quality Control  	  °~~
      8.2.2  Defoamers and Pitch Dispersants  	  8-J
      8.2.3  Extended Cooking  	  °~*
      8.2.4  Effective Brown Stock Washing	 °-°
      8.2.5  Closed Screen Room Operation  	 °-°
      8.2.6  Oxygen Delignification	 **
      8.2.7  Steam Stripping 	;	5"1U
       8.2.8  Pulping Liquor Management, Spill Prevention,
             and Control	°~"
       8.2.9  Maximizing Recovery Boiler Capacity	o-u,
 8.3    Pollution Prevention Controls Used in the Bleach
       Plant	o 1 f.
       8.3.1  Countercurrent Washing	°'f°
       8.3.2  Ozone Bleaching  	°'f°
       8.3.3  Split Addition of Chlorine		»-|»
       8.3.4  Improved Mixing and Process Control	8-18
       8.3.5  Chlorine Dioxide Substitution	°-19
       8.3.6  Enhanced Extraction	•	°-f?
       8.3.7  Elimination of Hypochlorite  	8'z:)
       8.3.8  High-Temperature/High-Alkalinity
             Hypochlorite Bleaching	°-fo
       8.3.9  Enzyme Bleaching  	°'fjj
       8.3.10 Peroxide  Bleaching	8"/0
       8.3.11 TotaUy Chlorine-Free Bleaching of Papergrade
              Kraft Pulps	8'27
       8.3.12 Totally Chlorine-Free Bleaching of Dissolving
              Kraft Pulps	8"29
        8.3.13 Totally Chlorine-Free Bleaching of Dissolving
              Sulfite Pulps	8"29
        8 3 14 TotaUy Chlorine-Free Bleaching of Papergrade
              Sulfite Pulps	°^
  8.4    Flow Reduction Technologies  	°"jf
        8.4.1  Countercurrent Brown Stock Pulp Washing	8-32
        8.4.2  Screen Room Closure	8-32
        8.4.3  Recycling of Evaporator Condensates	o-J/
                                          VI

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       8.4.4  Bleach Plant Counter-current and Jump-Stage
             Pulp Washing	8-32
       8.4.5  Flotation Clarification (Deinking)	 8-33
       8.4.6  Savealls	3.33
       8.4.7  Gravity Strainers With High-Pressure, Self-
             cleaning Showers  	8-34
       8.4.8  Vacuum Pump Seal Water Cascade System	8-34
       8.4.9  Vacuum Pump Seal Water Cooling Tower
             System	8-34
       8.4.10 Adequate Wastewater Storage  	8-35
8.5    End-of-Pipe Wastewater Treatment Technologies  	8-35
       8.5.1  Primary Treatment:  Screening, Solids Removal,
             Equalization, and Neutralization	8-36
       8.5.2  Activated Sludge Systems'	8-40
       8.5.3  Aerated and Non-aerated Stabilization Basins	8-44
       8.5.4  Sludge Handling Operations	8-46
       8.5.5  Chemical Addition	8-49
       8.5.6  Other Treatment Technologies	8-50
       8.5.7  Color Reduction Technologies  	8-51
       8.5.8  Ultrafiltration of Bleach Plant Filtrates	8-52
8.6    References  	8-54

DEVELOPMENT OF CONTROL AND TREATMENT OPTIONS .  9-1
9.1    Introduction  	                                9.4
9.2    BPT	'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.  9-2
       9.2.1  Approach to BPT Option Development	  9-2
       9.2.2  Identification of Mills Representing Secondary
             Wastewater Treatment Performance in Each
             Subcategory  	  9.5
       9.2.3  Performance Levels  	9-10
       9.2.4  Development of BPT  Option 2 for the
             Dissolving Sulfite Subcategory	9-12
       9.2.5  Description of Technology Bases	            9-16
9.3    BCT	'  9_2i
       9.3.1   BCT Options Assuming "Baseline" is BPT
             Option 2	9_23
       9.3.2  BCT Options Under Alternative Analysis:
             Assuming "Baseline" is Current Industry
             Performance	9_24
                                       vn

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9.4   BAT	• •	9-25
      9.4.1  Approach to Option Development  	y-*'
      9.4.2  Bleached Papergrade Kraft and Soda
            Subcategory 	•	^"^
      9.4.3  Dissolving Kraft Subcategory	9-47
      9.4'.4  Unbleached Kraft Subcategory  	9-52
      9.4.5  Dissolving Sulfite Subcategory	9-53
      9.4.6  Papergrade Sulfite Subcategory	9-56
      9.4.7  Semi-Chemical Subcategory 	9-60
9.5   NSPS	•	9-60
      9.5.1  Introduction	*™
      9.5.2 Dissolving Kraft Subcategory	9-63
      9.5.3  Bleached Papergrade Kraft and Soda
            Subcategory 	•	9-64
      9.5.4 Unbleached Kraft Subcategory 	9-67
      9.5.5 Dissolving Sulfite Subcategory	9-68
      9.5.6 Papergrade Sulfite Subcategory	9-69
      9.5.7  Semi-Chemical Subcategory  	9-70
      9.5.8  Mechanical Pulp Subcategory
             Non-Wood Chemical Pulp Subcategory
             Secondary Fiber - Deink Subcategory
             Fine and Lightweight Papers from Purchased Pulp
             Subcategory
             Tissue, Filter, Non-Woven, and Paperboard from
             Purchased Pulp Subcategory  . . .'	9-71
       9.5.9  Secondary Fiber Non-Deink Subcategory	9-71
 9.6    PSES	9-74
       9.6.1  Pass-Through Analysis	*-'^
       9.6.2  PSES Options	9'75
 9.7    PSNS  	,	9-76
 9.8    References  	y~''

 POLLUTANT REDUCTION ESTIMATES	10-1
 10.1  Introduction	' • •
 10.2  Conventional Pollutants	
       10.2.1  Estimation of Baseline Conventional Pollutant
              Loadings
       10.2.2  Estimation of BPT Target Production
              Normalized Conventional Pollutant Mass
              Loadings
                                        Vtll

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       10.2.3 Conventional Pollutant Reductions for Direct
             Discharging Mills  	10-4
       10.2.4 Conventional Pollutant Reductions Associated
             With BCT  	10_9
       10.2.5 Conventional Pollutant Reductions for Indirect
             Discharging Mills  	10-11
 10.3   Priority and Nonconventional Pollutants  	10-12
       10.3.1 Estimation of Baseline Loadings	1.0-14
       10.3.2 Pollutant Mass Loadings After Implementation
             of the Options  	10-17
       10.3.3 Pollutant Reductions	       10-18
 10.4   Chemical Oxygen Demand  	10-19
       10.4.1 Estimation of Baseline Loadings	10-20
       10.4.2 COD Loadings After Implementation of COD
             Control Option  	10-22
       10.4.3 Pollutant Reductions	10-23
 10.5   References 	        '10-24

 COSTS OF TECHNOLOGY BASES FOR REGULATIONS  	11-1
 11.1   Costs of Pollution Preventing Process Changes  	H-i
       11.1.1 Methodology for  Estimating Costs of Pollution
             Preventing Process Changes 	H_2
       11.1.2 Conventions Used in the Cost  Model  	. . . 11-8
       11.1.3 Description of Cost Model 	11-13
       11.1.4 Cost Model Validation	 n-17
       11.1.5 Benefits of Replacing Equipment  	11-17
       11.1.6 Estimated Process Change Costs	           \\.\g
 11.2   Costs for COD Control	 11-20
       11.2.1 Dissolving Kraft and Bleached  Papergrade
             Kraft and Soda Subcategories	11-21
       11.2.2 Unbleached Kraft and Papergrade Sulfite
             Subcategories	       11-22
       11.2.3  Semi-Chemical Subcategory  	11-23
       11.2.4  Summary of Costs for COD Control	 H-23
11.3   Steam Stripping Costs  ...                                 11 23
11.4   BMP Costs	'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'.'. '. ' .' .' 11-24
      11.4.1 General Approach  	    11-25
      11.4.2 Bleached Papergrade Kraft and Soda
            Subcategory  	     11-26
      11.4.3 Unbleached Kraft Subcategory	 11-26
                                      IX

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      11.4.4 Dissolving Kraft, Dissolving Sulfite, Papergrade
            Sulfite, Semi-Chemical, and Non-Wood
            Chemical Pulp Subcategories  	11-27
11.5   Flow Reduction Costs	•	n"28
      11.5.1 General Approach Used to Develop Flow
            Reduction Costs	•	II"2?
      11.5.2 Flow Reduction  	•	JJ-31
      11.5.3 Cost Estimation  	-
      11.5.4 Pollutant Reduction
      11.5.5 Cost Results
11.6   End-of-Pipe Treatment Costs  	•	u'4i
      11.6.1 Approach to Estimating End-of-Pipe Treatment
            Costs  	11-42
      11.6.2 Development of Design'and Cost Models	11-46
      11.6.3 Sources of Operating and Maintenance Costs  	11-51
      11.6.4 Sources of Capital Costs	JJ-51
      11.6.5 Application of Design and Cost Models  	11-55
      11.6.6 Cost Results	n~61
      11 6.7 Validation of. End-of-Pipe Treatment System
            Cost Model	II-62
 11.7  Summary of Costs by Regulation	Jl-jg
      11.7.1 BPT	J™
      11.7.2 BCT	n~°5
      11.7.3 BAT	11-66
      11.7.4 PSES  	I™
      11.7.5 BMP  	11-°*
 11.8  References  	n"°y

 INTEGRATED RULEMAKING AND NON-WATER QUALITY
 ENVIRONMENTAL IMPACTS	12-1
 12.1   Integrated Rulemaking and Database	12-1
 12.2   Energy Impacts	•	Jf"3
 12.3   Air Pollution	^
 12.4   Solid Waste  Generation and Management	i^-o
 125   Odor Control	•	JJ^
 12.6   Other Impacts	*£'
 12.7   References  	lz"y

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 ANALYTICAL METHODS  	13_j
 13.1   Chlorinated Dioxins and Furans  	13_1
 13.2   Chlorinated Phenolic Compounds	13-3
 13.3   Volatile Organic Compounds (VOCs) 	'.'.] 13.3
 13.4   Adsorbable Organic Halides (AOX)  	'.'.'.'.'.'.'.'. 13-4
 13.5   Chemical Oxygen Demand (COD)  . .	'.'.'.'.'. 13-5
 13.6   Color  	           23_5
 13.7   Biochemical Oxygen Demand (BOD5)	         13.6
 13.8   Total Suspended Solids (TSS)	 13-6
 13.9   Other Analytes	       J3_g
       13.9.1 Resin and Fatty Acids	             13_6
       13.9.2 Metals 	'.'.'.'.'.'.'.'.'/.'.'.'. 13-7
       13.9.3 Semi-volatile Organic Compounds	13.7
       13.9.4 Pesticides and Herbicides	13.7

 BEST PRACTICABLE CONTROL TECHNOLOGY
 CURRENTLY AVAILABLE AND BEST
 CONVENTIONAL POLLUTANT CONTROL
 TECHNOLOGY	  u_1
 14.1  Introduction 	          j4_j
 14.2  Regulated Pollutants	  ' ^	14^
 14.3  Identification of BPT	   14-1
      14.3.1 BPT Performance Level and Limitations	14-1
      14.3.2 Description of Technology Basis  . .                   14.2
 14.4  BCT	.';;.';;.';;;;;
 14.5  Implementation	
      14.5.1 NPDES Production Rate (Production	
            Normalizing Parameter)  	14.4
      14.5.2 Point of Application	[] 14.5
      14.5.3 Application of BPT to Mills in More Than One
            Subcategory  	
      14.5.4 Application of BPT to Mills With
            Noncontinuous Discharges  	14-10

BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
15.1   Introduction  	            ^_j
15.2   Regulated Pollutants	'.'.'.'.'.'.'.'"' 15-1
15.3   Identification of BAT	      15-2
      15.3.1 Subpart B - Bleached Papergrade Kraft and
           Soda Subcategory	        15_2
                                     XI

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      15.3.2 Subpart A - Dissolving Kraft Subcategory 	15-4
      15.3.3 Subpart C - Unbleached Kraft Subcategory	15-7
      15.3.4 Subpart D - Dissolving Sulfite Subcategory  	15-7
      15.3.5 Subpart E - Papergrade Sulfite Subcategory  	15-9
      15.3.6 Subpart F - Semi-Chemical Subcategory 	15-10
15.4   Implementation'	
      15.4.1 NPDES Production Rate (Production
            Normalizing Parameter) 	J5-11
      15.4.2 Point of Application	: •  • l5^
      15.4.3 NPDES Monitoring Requirements  	15-w
      15.4.4 Application of BAT  	15-13

NEW SOURCE PERFORMANCE STANDARDS  	16-1
16.1   Introduction 	I6~l
16.2  Selection of NSPS Options	^
      16.2.1 Subpart A - Dissolving Kraft Subcategory  	lo-*-
      16.2.2 Subpart B - Bleached Papergrade Kraft and
            Soda Subcategory	•	l°-4
      16.2.3 Subpart C - Unbleached Kraft Subcategory	16-6
      16.2.4 Subpart D - Dissolving Sulfite Subcategory 	16-6
      16.2.5 Subpart E - Papergrade Sulfite Subcategory  	16-6
      16.2.6 Subpart F - Semi-Chemical Subcategory 	16-7
      16.2.7 Subpart G - Mechanical Pulp Subcategory
             Subpart H - Non-Wood Chemical Pulp Subcategory
             Subpart I - Secondary Fiber - Deink Subcategory
             Subpart K - Fine and Lightweight Papers from
             Purchased Pulp Subcategory
             Subpart L - Tissue, Filter, Non-Woven, and
             Paperboard from Purchased Pulp Subcategory	16-7
       16.2.8 Subpart J - Secondary Fiber Non-Deink
             Subcategory  	16~8

 PRETREATMENT STANDARDS FOR EXISTING
 SOURCES 	\L\
 17.1  Introduction  	}'"]
 17.2  Selection of PSES Options  	f '^
       17.2.1 Subpart A - Dissolving Kraft Subcategory  	1 /-4
       17.2.2 Subpart B - Bleached Papergrade Kraft and
             Soda Subcategory
       17.2.3 Subpart C - Unbleached Kraft Subcategory
                                        Xll

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                         TABLE OF CONTENTS (Continued)
 18.0

 19.0
20.0

21.0

22.0
                                                                Page

        17.2.4 Subpart D - Dissolving Sulfite Subcategory	17-5
        17.2.5 Subpart E - Papergrade Sulfite Subcategory  	17.5
        17.2.6 Subpart F - Semi-Chemical Subcategory	    17-6
        17.2.7 Subpart G - Mechanical Pulp Subcategory
              Subpart H - Non-Wood Chemical Pulp Subcategory
              Subpart I - Secondary Fiber - Deink Subcategory
              Subpart J - Secondary Fiber - Non-Deink Subcategory
              Subpart K - Fine and Lightweight Papers from
              Purchased Pulp Subcategory
              Subpart L - Tissue, Filter, Non-Woven, and
              Paperboard from Purchased Pulp Subcategory	17-6

 PRETREATMENT STANDARDS FOR NEW SOURCES	18-1

 BEST MANAGEMENT PRACTICES	   19_!
 19.1   Introduction 	   	j^_^
 19.2   Legal Authority	'.'.'.'.'.	19.2
 19.3   Toxicity of Pulping Liquors	19-2
 19.4   Sources of Pulping Liquor Losses  	   	19.3
       19.4.1 Kraft and  Soda Mills   	.  . . .'	19.3
       19.4.2 Sulfite and Semi-Chemical Mills	.... . '.'.'.'. '. [ .' .' .' 19.4
 19.5   Current Industry Practice - Pulping Liquor Spill
       Prevention and Control	                    19 5
       19.5.1 Kraft and Soda Mills   	   	19"c
       19.5.2 Sulfite Mills	•.	'.'.'.'.'.'.'.'.'.'.'.'.'. 19-6
 19.6   Regulatory Approach and Proposed Regulatory
       Provisions	                  jo_7
 19.7   Estimated  Costs and Effluent  Reduction Benefits ".'.'. '. '. '. . . .  19-10
       19.7.1 Estimated  Costs 	   	19-10
       19.7.2 Estimated Effluent Reduction Benefits  .........     19-H
 19.8  References 	           	19-12

ACKNOWLEDGEMENT AND DISCLAIMER 	20-1

GLOSSARY	                  21_j

ABBREVIATIONS AND CONVERSIONS	22.!
22.1  Abbreviations	           	22-1
22.2  Units of Measure   	   	22-7
22.3  Unit Conversions   	               22-8
                                      xni

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          TABLE OF CONTENTS (Continued)
Appendix A -


Appendix B -


Appendk C -
                                                              Page
Listing of Revised Subcategories in Which Each
Mill Reported Production in 1989	A-l

Analytes Included in the Long- and Short-Term
Studies
                                             B-l
Ranges of Concentrations and Mass Loadings
for Priority and Nonconventional Pollutants  	C-l
                            xiv

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                                 LIST OF FIGURES
 4-1

 4-2

 4-3

 4-4

 4-5

 4-6

 4-7

 4-8


 4-9

 5-1



 5-2



 5-3



 5-4

 5-5



5-6



5-7
                                                                  Page

 Process Flow Diagram for a Bleached Chemical Pulp Mill	4-29

 Fourdrinier Paper Machine	4.39

 Typical Bleach Plant,	     4_31


 Geographic Profile of All Mills  	4.32


 Geographic Profile of Mills That Manufacture Chemical Pulp  	4-33

 Geographic Profile of Mills That Bleach Chemical Pulp	4.34

 Geographic Profile of Mills That Process Secondary Fiber	4-35

 Geographic Profile of Mills That Deink Secondary Fiber	4-36

 Comparison of Number of Mills by Mill Type  	4.37

 Bleached Papergrade Kraft and Soda Subcategory
 Cumulative Distribution Function  	     5.32

 Unbleached Kraft and Semi-Chemical Subcategory
 Cumulative Distribution Function  	         5.33
Mechanical Pulping Subcategory Cumulative Distribution
Function	
                                                                 5-34
Secondary Fiber Deink Cumulative Distribution Function  	5-35
Secondary Fiber Non-Deink Cumulative Distribution
Function	
                                                                 5-36
Fine and Lightweight Papers from Purchased Pulp
Subcategory Cumulative Distribution Function	5.37

Tissue, Filter, Non-Woven, and Paperboard from Purchased
Pulp Subcategory Cumulative Distribution Function	5.33
                                       xv

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                          LIST OF FIGURES (Continued!)
                                                                             Page
6-1



6-2



6-3



6-4



6-5


8-1


8-2

8-3


 8-4

 8-5

 8-6

 8-7

 8-8

 8-9
Diagram of Process Operations for Secondary Fiber Mills
That Make Paperboard from Wastepaper and Discharge
Wastewater	
Diagram of Process Operations for Secondary Fiber Mills
That Make Paperboard from Wastepaper and Completely
Recycle Wastewater 	
Diagram of Process Operations for Secondary Fiber Mills
That Make Builders' Paper and Roofers' Felt and Discharge
Wastewater	

Diagram of Process Operations for Secondary Fiber Mills
That Make Builders' Paper and Roofers' Felt and Completely
Recycle Wastewater  	

Total PCB Effluent Concentrations at a Secondary Fiber
Deink Mill (1985 to March 1993)	
6-41
6-42
6-43
6-44
 U.S. and Worldwide Increase in Kraft Pulp Produced by
 Extended Cooking, 1983-1992  	
 6-45
 8-60
 Extended Cooking Continuous Digester System (EMCC®)	8-61

 U.S. and Worldwide Increase in Pulp Produced by Oxygen
 Delignification, 1970-1992	8"62

 Typical Medium-Consistency Oxygen Delignification System	8-63

 Typical High-Consistency Oxygen Delignification System  	8-64

 Continuous Steam Stripper System	8"65

 Schematics of Flotation Clarifiers for Deinking 	8-66

 Schematic of a Disc Saveall	•	8'67

 Schematic of a Gravity Strainer	8-68
                                         xvi

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                         LIST OF FIGURES (Continued)
9-1


11-1
                                                               Page

Production Normalized Flow vs. Concentration for Bleached
Papergrade Kraft and Soda Mills	  9.80

Decision Tree for Basin Design and Cost Model  	11.72
                                    xvn

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                                LIST OF TABLES
1-1


1-2


1-3

4-1

4-2

4-3

4-4

4-5

4-6

4-7

4-8

 4-9


 4-10


 5-1


 5-2


 6-1
                                                                Page

Comparison of the Proposed Subcategorization Scheme With
the Existing Subcategorization Scheme	   "

Application of Proposed Rules to Pulp, Paper, and
Paperboard Subcategories 	

Summary of Technology Basis for BAT Effluent Limitations  	  1-7

Comparison of Kraft and Sulfite Pulping Processes  .:	4-38

                                                                 4-39
Bleaching Symbols	

Geographic Profile of Pulp, Paper, and Paperboard Mills	4-40

Total Fiber Furnish Received On Site by Process Type  	4-43

Types of Fiber Furnishes Used by Pulping Process	4-44

Number of Mills by Specific Secondary Fiber Furnish  	4-45

 Wood Preparation and Handling	4" 7

 Number of Mills by Pulping Process  	•	4-48

 Bleaching Chemicals Used As Reported in the  1990                  ^ ^
 Questionnaire	

 U.S. Pulp, Paper, and  Paperboard Production in 1989, by
 Product	
                                                 i
 Final Effluent BOD5 Loadings and Concentrations for
 Selected .Direct Discharge Mills	5'3y

 Proposed Subcategorization with the Current
 Subcategorization 	j'

 Mill Discharge Status	;	6"46
                                         xvm

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                           LIST OF TABLES (Continued)
 6-2



 6-3


 6-4



 6-5



 6-6


 6-7

 6-8  .



 6-9


 6-10


 7-1



7-2


7-3
                                                                 Page

 Approximate Percentage of Total Industry Water Use and
 Wastewater Discharge by Process Area, as Reported in the
 1990 Questionnaire   	5.47

 Average Production Normalized Flow Discharged to
 Treatment by Process Area and Subcategory 	6-48

 Comparison  of Zero, Direct, and Indirect Discharge Mills
 That Manufacture Only Paperboard From Wastepaper, As
 Reported in  the 1990 Questionnaire  	6-50

 Comparison  of Zero, Direct, and Indirect Discharge Mills
 That Manufacture Only Builders' Paper and Roofing Felt, As
 Reported in  the 1990 Questionnaire  	,. . . 5.52

 Estimated Subcategory-specific Production Normalized BOD5
 and TSS Discharge Loads  	5.54

 Priority Pollutant List  	5.55

 Chlorinated Pollutant Concentrations in Effluents from Non-
 Chemical Pulp Mills and Chemical Non-Wood Pulp Mills
 That Bleach With Hypochlorite or Chlorine	6-56

 Secondary Fiber Deink Mill CDDs and CDFs In Wastewater
 Treatment Plant Influent and Effluent	6-59

 Secondary Fiber Deink Mill CDDs and CDFs in Wastewater
 Treatment Plant Sludge	     6-60'

 Pollutants for Which Effluent Limitations Guidelines Were
 Previously Proposed (P) or Promulgated (X) by Current
 Subcategory	           y_2Q

 Analysis Summary for Specific Pollutants in Treated Effluents
 From Chemical Pulp Mills That Bleach	7_23

Priority and Nonconventional Pollutants Not Detected in
Treated Effluents Frorri Chemical Pulp Mills That Bleach 	7-24
                                       xix

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                          LIST OF TABLES (Continued)
7-4


7-5



7-6
7-7


7-8

8-1

8-2

8-3

8-4


8-5


8-6


8-7


8-8


 8-9
                                                               Page

Priority and Nonconventional Pollutants Detected in Treated
Effluents From Only One Chemical Pulp Mill That Bleaches .	7-39
Priority and Nonconventional Pollutants Detected in Treated
Effluents At More Than One Chemical Pulp Mill That
Bleaches	•	

Number of Data Points and Final Effluent Concentrations for
Analytes Detected at Non-Chemical Pulp Mills and Chemical
Non-Wood Pulp Mills That Bleach With Chlorine and/or
Hypochlorite	•	
7-41
                                                                             7-44
Summary of Pollutant Parameters Proposed for Effluent
Limitations Guidelines by Proposed Revised Subcategory	7-45

Jurisdictions Regulating AOX as a Wastewater Pollutant	7-46

Full-Scale Installations of Ozone Bleaching Systems	8-69

Information for Several TCF Papergrade Sulfite Mills  	8-70

Properties of Several TCF Papergrade Sulfite Pulps	8-71
 Summary of Primary and Biological Wastewater Treatment
 Systems In Place at Pulp and Paper Mills	
8-72
 Summary of Wastewater Treatment In Place at Direct-
 Discharging Mills, by Subcategory	8-73
 Summary of Primary Wastewater Treatment In Place at Pulp
 and Paper Mills	
 Types of Activated Sludge Processes In Place at Pulp and
 Paper Mills	• • •
 8-75
 8-76
 Summary of Sludge Handling/Dewatering Operations In
 Place at Pulp and Paper Mills	8-77

 Sludge Disposal Methods Used by Pulp and Paper Mills  	8-78
                                        xx

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                           LIST OF TABLES (Continued)
 9-1

 9-2

 9-3

 9-4

 9-5


 9-6

 9-7


 9-8


 9-9


 9-10


 9-11


 9-12


 9-13


9-14


9-15
                                                                Page

 BPT Candidate Mills By Subcategory . . .	9_8i

 Summary of Mills in the Semi-chemical Subcategory  	9-87

 Summary of Mills in the Papergrade Sulfite Subcategory  	9-88

 Summary of Mills in the Mechanical Pulp Subcategory	9-89

 Summary of Mills in the Non-Wood Chemical Pulp
 Subcategory	   9_9Q

 BPT Performance Levels	  9.91

 Production Normalized Flows Required to Meet BPT BOD5
 Performance Levels	       9_92

 Pulp and Paper Industry Secondary Wastewater Treatment
 System Performance and Design and Operating Parameters	9-93

 Activated Sludge Treatment System Performance and Design
 and Operating Parameters	• 9.102

 Aerated  Stabilization Basins Performance and' Design and
 Operating Parameters	'......	  9-103

 Performance of BAT Options For the Bleached Papergrade
 Kraft and Soda Subcategory	     9-104
Pollutants Discharged In Final Effluent from Dissolving Kraft
Mills . .	
                                                               9-106
Performance of BAT Options For the Dissolving Kraft
Subcategory	         9-108

Performance of BAT Options For Dissolving Sulfite
Subcategory	9-11Q

Performance of BAT Options For Papergrade Sulfite
Subcategory	        .
                                      xxi

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LIST OF TABLES (Continued)

9-16

9-17

9-18

9-19

9-20

9-21
10-1

10-2

10-3
10-4

10-5
10-6

10-7

10-8
10-9

Performance of NSPS Options For the Dissolving Kraft
Subcategory 	
Performance of NSPS Options For the Bleached Papergrade
Kraft and Soda Subcategory 	
Performance of NSPS Options For Dissolving Sulfite
Subcategory 	
Performance of NSPS Options For Papergrade Sulfite
Subcategory 	
Performance of NSPS Option for Five Non-BAT
Sub'categories 	 	
Comparison of BAT, PSES Option 1, and PSES Option 2 	
Baseline Conventional Pollutant Loadings for Direct
Discharging Mills 	 	
Total Conventional Pollutant Reductions Resulting From
BPT Options 1 and 2 	 	
Conventional Pollutant Reductions Associated With BAT 	
Conventional Pollutant Reductions Associated With
NESHAP 	
Conventional Pollutant Reductions Associated With BMP 	
Conventional Pollutant Reductions Associated With the BPT
Technology Bases 	
Conventional Pollutant Reductions Associated With BCT
Option A.2 	 ' 	
Conventional Pollutant Reductions Associated With PSES ....
Priority and Nonconventional Pollutants for Which Pollutant
Rfirinrtinns Were Calculated 	
Page
Q-1 14


-116
Q-1 1R


-120
91 OO
-IZZ
i
9-123

10-25

10-26
10-27

10-28
10-29

10-30

10-31
10-32
	 10-33
             XXll

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                           LIST OF TABLES (Continued)
 10-10


 10-11


 10-12


 10-13


 10-14


 10-15


 10-16

 10-17


 10-18

 10-19


 11-1

 11-2

 11-3

 11-4


11-5
                                                                 Page

 Technology Subgroups for the Bleached Papergrade Kraft
 and Soda Subcategory ...........................          10-34

 Baseline Loadings for Priority and Nonconventional
 Pollutants in Final Effluents  .............................. 10-36

 Pollutant Reduction of BAT Options For the Dissolving Kraft
 Subcategory ........................................... ( 10_3?

 Pollutant Reduction of BAT Options For the Pleached
 Papergrade Kraft and Soda Subcategory  , .............. .       io-38

 Pollutant Reduction of BAT Options For Dissolving Sulfite
 Subcategory ........................................... 10_39

 Pollutant Reduction of BAT Options For Papergrade Sulfite
 Subcategory .............................  ............. 10_4Q

 Pollutant Reductions for PSES  ........................      IQ-41

 Summary of Available COD Data - Chemical Pulping
 Subcategories   ..........................                   10-42

 Baseline COD Discharge Load  ..........................   10_43

 Reduction in Annual Discharge of COD After
 Implementation of BAT and PSES Regulations  ................ 10.44

 Operating Costs ...................                          11-73

 Summary of Constants for Capital Cost Scaling Equation ......... 11.74

 Summary of BAT/PSES Process Change Costs  ................ 11.75

 Summary of Equipment Costed for BAT/PSES Process
 Changes  Dissolving Kraft Subcategory (3 Mills)  ................ 11.75
Summary of Equipment Costed for BAT/PSES Process
Changes Bleached Papergrade Kraft and Soda Subcateeory
(86 Mills)  ................................. & _ ........  11_7?
                                      xxm

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                         LIST OF TABLES (Continued)


                                                                          Page

11-6         Summary .of Equipment Costed for BAT/PSES Process
            Changes Dissolving Sulfite Subcategory (5 Mills) 	' H-/9

11-7         Summary of Equipment Costed for BAT/PSES Process
            Changes Papergrade Sulfite Subcategory (11 Mills)  	H-80

11-8         Summary of Costs for COD Control	n'81

11-9         Costs for Upgrades to Implement BMP at Kraft, Sulfite,
            Semi-Chemical, and N.on-Wood Mills	H-82

11-10       Lowest TSS and BOD5 Concentrations Achievable by
            Secondary Treatment, By Subcategory	H"83

11-11       Percentage of Final Effluent Flow Discharged From Three
            Process Areas, By Subcategory	H-84

11-12       Percentages of Process Area Wastewater Discharge
            Reductions Achieved by Each Flow Reduction Technology
            and Combination of Technologies  	H-85

11-13       Percent Reduction in Final Effluent Flow Achieved By Flow
            Reduction Technologies, By Subcategory	H'86

11-14       Summary of Flow Reduction Costs and Technologies Costed	11-88

11-15       CAPDET Modules Used as Basis for Basin Upgrades in the
            Basin Design and Cost Model	H'89

11-16       Unit O&M Costs for End-of-Pipe Treatment Technologies	11-90

11-17       Unit Capital Costs for End-of-Pipe Treatment Technologies	11-91

 11-18        Scenarios for the Application of Land Cost Components to
             Individual Mills	11'93

 11-19        BOD5 Load Reduction to Wastewater Treatment Due to
             Implementation of BAT at Bleached Papergrade Kraft and
             Soda Mills	•	n'94
                                       XXIV

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                            LIST OF TABLES (Continued)
  11-20


  11-21

  11-22


  11-23


  11-24


  11-25


 11-26


 11-27


 11-28



 11-29

 11-30

 11-31


 11-32

11-33

12-1
                                                                 Page

  BOD5 Load Reductions to Wastewater Treatment Due to
  Steam Stripping of Condensates	     n_95
  Summary of BPT Costs
                                                                11-96
  Wastewater Treatment Upgrades Costed for Mills to Meet
  Target BOD5 and TSS Loads for BPT/BCT Options 1 and 2	11.97

  Aerators, Comparison of Industry-Reported Costs and EPA
  Model Costs 	
 Aerated Stabilization Basins, Comparison of Industry-
 Reported Costs and EPA Model Costs	
 Polishing Ponds, Comparison of Industry-Reported Costs and
 EPA Model Costs	
.  11-98


.  11-99


11-100
 Activated Sludge Aeration Basins, Comparison of Industry-
 Reported Costs and EPA Model Costs	          11-101

 Activated Sludge Secondary Clarifiers, Comparison of
 Industry-Reported Costs and EPA Model Costs	11-102

 End-of-Pipe Treatment Model Validation Summary,
 Comparison of Industry-Reported Costs  and Adjusted EPA
 Model Costs	
                                                              11-103
 Best Practicable Control Technology (BPT) Costs  	n_i04

 Best Conventional Pollutant Control Technology (BCT) Costs  ....  11-105

 Best Available Technology Economically Achievable (BAT)
 Costs	                              v    '
                                                              11-106
Pretreatment Standards for Existing Sources (PSES) Costs	11-107

Best Management Practices (BMP) Costs	n_108

Pollutants Included in the Final Integrated Database	12-11
                                      XXV

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                          LIST OF TABLES (Continued)
                                                                            Page
12-2        Description of Regulatory Alternatives Included in the Final         ^^
            Integrated Database  .......................... ..........

13-1        Regulatory Status of Analytical Methods To Be Used to
            Determine Compliance With the Proposed Rule . . . . ............  iJ-°

14-1        Proposed BPT Effluent Limitations Guidelines - Continuous         ^^
            Dischargers .....' ......................................

14-2        Proposed BPT Effluent Limitations Guidelines - Non-              ^^
            Continuous Dischargers ..................................

14.3        Characterization of Mffls Currently Achieving BPT
            Performance (Based on Long-Term Average  BOD5 Load) ........  14-1 /

 15-1         Pollutants Regulated'by BAT Effluent Limitations Guidelines
             Under the Proposed Rule  ................................

 15-2         Proposed BAT Effluent Limitations Guidelines for Subpart B
             Papergrade Kraft and Soda Subcategory  .....................  L^

 15 3         Proposed Alternative BAT Effluent Limitations Guidelines
             for Subpart B Papergrade Kraft and Soda Subcategory
             Applicable to Totally Chlorine-Free Bleaching Processes  .........  l*-*>

 154        Proposed BAT Effluent Limitations Guidelines for Subpart A
             Dissolving Kraft Subcategory  .................. ............

 15 5         Proposed Alternative BAT Effluent Limitations Guidelines
              for Subpart A Dissolving Kraft Subcategory  Applicable to
              Totally Chlorine-Free Bleaching Processes ....... . ............  i:>-ze

  15-6         Proposed BAT Effluent Limitations Guidelines for Subpart C
              Unbleached Kraft Subcategory ................. ............

  15-7         Proposed BAT Effluent Limitations Guidelines for Subpart D
            '  Dissolving Sulfite Subcategory ....... - .................
                                         XXVI

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                            LIST OF TABLES (Continued)
 15-8



 15-9


 15-10


 15-11

 16-1


 16-2



 16-3


 16-4



 16-5


 16-6


 16-7



16-8
                                                                  Page

 Proposed Alternative BAT Effluent Limitations Guidelines
 for Subpart D Dissolving Sulfite Subcategory Applicable to
 Totally Chlorine-Free Bleaching Processes .................... 15.31

 Proposed BAT Effluent Limitations Guidelines for Subpart E
 Papergrade Sulfite Subcategory ... ......................... 15-32

 Proposed BAT Effluent Limitations Guidelines for Subpart F
 Semi-Chemical Subcategory ........................         15-32

 BAT Monitoring Requirements ..........................    15-33

 Proposed New Source Performance Standards for Subpart A
 Dissolving Kraft Subcategory ............................     16_9

 Proposed Alternative New Source Performance Standards for
 Subpart A Dissolving Kraft Subcategory Applicable to Totally
 Chlorine-Free Bleaching Processes .......................... 16-lQ

 Proposed New Source Performance Standards for  Subpart B
 Bleached Papergrade Kraft and Soda Subcategory .............. ig-H
 Proposed Alternative New Source Performance Standards for
 Subpart B Bleached Papergrade Kraft and Soda Subcategory
 Applicable to Totally Chlorine-Free Bleaching Processes .........  16-12

 Proposed New Source Performance Standards for Subpart C
 Unbleached Kraft Subcategory ...........................    16.13

 Proposed New Source Performance Standards for Subpart D
 Dissolving Sulfite Subcategory .. ..........................    16-14

 Proposed Alternative New Source Performance Standards for
 Subpart D Dissolving  Sulfite Subcategory Applicable to
 Totally Chlorine-Free Bleaching Processes  .................... ig-15
Proposed New Source Performance Standards for Subpart E
Papergrade Sulfite Subcategory  ...........................   16.16
                                      xxvn

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                          LIST OF TABLES (Continued)
16-9


16-10
 16-11
 17-1


 17-2
 17-3


 17-4


 17-5


 19-1


 22-1
Proposed New Source Performance Standards for Subpart F
Semi-Chemical Subcategory	
Page


16-16
                                                                            16-17
Proposed New Source Performance Standards for
Subpart G - Mechanical Pulp Subcategory, Subpart H - Non-
Wood Chemical Pulp Subcategory, Subpart I - Secondary
Fiber - Deink Subcategory, Subpart J - Secondary Fiber -
Non-Deink Subcategory, Subpart K - Fine and Lightweight
Papers from Purchased Pulp, Subpart L - Tissue, Filter, Non-
Woven, and Paperboard from Purchased Pulp Continuous
Dischargers	

Proposed New Source Performance Standards for
Subpart G - Mechanical Pulp Subcategory, Subpart H - Non-
Wood Chemical Pulp Subcategory, Subpart I - Secondary
Fiber - Deink Subcategory, Subpart J - Secondary Fiber -
Non-Deink Subcategory, Subpart K - Fine and Lightweight
Papers from Purchased Pulp, Subpart L - Tissue, Filter, Non-
Woven, and Paperboard from Purchased Pulp Non-
 Continuous Dischargers	

 Proposed Pretreatment Standards for Existing Sources for
 Subpart B Papergrade Kraft and Soda Subcategory  	17-7

 Proposed Alternative Pretreatment Standards for Existing
 Sources for Subpart B Papergrade Kraft and Soda
 Subcategory Applicable to Totally Chlorine-Free Bleaching
 Processes	

 Proposed Pretreatment Standards for Existing Sources for
 Subpart C Unbleached Kraft Subcategory	17'9

 Proposed Pretreatment Standards for Existing Sources for
 Subpart E Papergrade Sulfite Subcategory	l'~w

 Proposed Pretreatment Standards for Existing Sources for
 Subpart F Semi-Chemical Subcategory	17'1U

 Quantified Effluent Reduction Benefits From Kraft Mill
 Black Liquor Spill Prevention and Control	iy-14

                                                                 22 9
 Units  of Measurement	
                                       XXVlll

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                                                                       1.0 Conclusions
  1.0    CONCLUSIONS

  1.1    Introduction

  The proposed regulations for the pulp, paper, and paperboard industry include effluent
  limitations guidelines and standards for the control of wastewater pollutants and national
  emission standards for hazardous air pollutants.  This document presents the information
  and  rationale supporting the  proposed effluent  limitations guidelines  and standards
  lechnical information supporting the air emissions regulations is detailed in "Pulp Paper
  and Paperboard Industry - Background Information for Proposed Air Emission Standards
  (October 1993V'EPA-453-R93-050a,orthe Background InforLtionDoZenUBI^ Tfat

                        *™10® bases and °ther key aspects of                     '
       Subcategorization

 EPA is proposing to replace the Subcategorization scheme under the existing effluent
 limitations guidelines for this industry (in 40 CFR Parts 430 and 431) with a revised
 Subcategorization scheme. Table 1-1 summarizes the new proposed subcategories and the
 corresponding subcategories under the existing regulations.

 1.3    Scope of Proposed Rules

 These proposed rules apply to mills within the U.S. Department of Commerce, Bureau of
 the Census Standard Industrial Classifications (SIC) 2611 (pulp mills), 2621 (paper mills
 except building paper mills), 2631 (paperboard mills), and 2661 (building paper anXu™ng
 board mills).  Some components of these proposed rules apply to only some of the foregoing
 mills. The components of these proposed rules applicable to each subcategory of the Pulp
 Paper, and Paperboard Point Source Category are shown on Table 1-2.

 1>4   Best Practicable Control Technology Currently Available (RPT)
                            BPT effluent Batons guidelines for biochemical oxygen
    ™   v              SUX6nded S°lids (TSS> for a11 Categories of the pulp, piper
and paperboard industry.   These proposed revisions  are based  on the appKcation of
                    treatment ^ WPriate water use and reuse.  In most caseMhe
                                     by the performance °f the avera^e of
                                       1-1

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                                                                    1.0 Conclusions
1.5    Rest Conventional Pollutant Control Tpphnnloftv (BCT)

FPA is nroDOsine to revise the BCT effluent limitations guidelines for BODS and TSS for
^fubcSrs^the pulp, paper, and paperboard industry  In -g^ **
BCT effluent limitations guidelines are equal to the proposed BPT effluent limit

j 6   Rest Available Technology Econoi"*'"'11Y Achievable (BAT)


3«M!£^S^^^


proposed effluent Umitations guidelines for each subcategory.

In addition to the effluent limitations guidelines based on the technologies in Table 1-3 for
SubpartsTB, and D, EPA is proposing alternative effluent limitations guidelines applicable
to mills that utilize totally chlorine-free processes in these subcategones.

 1.7    New Source Performance Standards (NSPS)

 FPA is oroDOSine revised NSPS for priority and nonconventional pollutants for seven
 StSSTL^p, paper, and paperboard industry. In five of these subca egones,
 EpltproposSg ^NSPSequivPalent to the proposed BAT effluent ^tatlo^ld^ef' £
 onf  ubcategory  (Bleached Papergrade  Kraft), EPA is proposing NSPS  based on
 preaching Controls in addition to those that form the technology basis ^r proposed BAT.
 £ one subcategory where  EPA is not proposing BAT limitations (Secondary Fiber Non-
 Deink), EPA is proposing  NSPS based on zero discharge of wastewater.

 EPA is proposing to revise  the NSPS controlling discharges of BOD5 and TSS for all
                f level equal to the discharge characteristics of the best performing mill.
  1.8    Pretreatment Standards for Existing Sources (PSES)

  EPA is proposing to revise PSES for the same priority and nonconventional pollutants to
  be I controlled by the  proposed BAT  Umitations based  on the same  technologies, as
  summarized in Table 1-3.

  1.9    Pretreatment Standards for New Sources (PSNS)

  EPA is proposing to revise PSNS for  the same priority and nonconventional pollutants
  controlled by the proposed NSPS based on the same technologies.
                                         1-2

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                                                                     1.0  Conclusions
1.10  Best Management Practices (BMP)

EPA is proposing BMP for pulping liquor spill prevention and control for the following
subparts: A (Dissolving Kraft), B (Bleached Papergrade Kraft and Soda), C (Unbleached
Kraft), D (Dissolving Sulfite), E (Papergrade  Suffite), F (Semi-Chemical), and H (Non-
Wood Chemical Pulp).   EPA is proposing to require that each mill in the subparts listed
above develop a BMP plan within 120 days of promulgation of this rule. This plan must be
submitted to EPA for approval and implemented within 24 months of promulgation.
                                      1-3

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                                Table  1-1

     Comparison of the Proposed  Subcategorization Scheme
            With the Existing Subcategorization Scheme
Proposed
 Subpart
    Proposed Subcategorization
            Scheme
  Current SitfeeategotizatSow Scheme
   (Witt Existing 48 OFK'Part 43Q
                 'Noted)
                                             Dissolving Kraft (F)
   B
Bleached Papergrade Kraft and Soda
Market Bleached Kraft (G),
BCT Bleached Kraft (H),
Fine Bleached Kraft (I),
Soda (P)
            Unbleached Kraft
                                 Unbleached Kraft (A)
                                 - Linerboard
                                 - Bag and Other Products
                                 Unbleached Kraft and Semi-Chemical
                                 (D, V)           ^	
    D
Dissolving Sulfite
Dissolving Sulfite (K)
- Nitration
- Viscose
- Cellophane
- Acetate
             Papergrade Sulfite
                                  Papergrade Sulfite (J,U)
                                  - Blow Pit Wash
                                  - Drum Wash
             Semi-Chemical
                                  Semi-Chemical (B)
                                  - Ammonia
                                  - Sodium
             Mechanical Pulp
                                  GW-Thermo-Mechanical (M),
                                  GW-Coarse, Molded, News (N)
                                  GW-Fine Papers (O)
                                  GW-Cheini-Mechanical (L)
    H
 Non-Wood Chemical Pulp
 Miscellaneous mills not covered by a
 specific subpart	
             Secondary Fiber Deink
                                  Deink Secondary Fiber (Q)
                                  - Fine Papers
                                  - Tissue Papers
                                  - Newsprint       	
                                      1-4

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                                  Table 1-1

                                 (Continued)
Proposed
Subpart
    Proposed Subcategorization
             Scheme
Current Subcategorization Scheme
 (W&th Exist Ing 40 CPR #art 430
        Subparts Noted)
             Secondary Fiber Non-Deink
                                   Tissue from Wastepaper (T)
                                   Paperboard from Wastepaper (F)
                                   - Corrugating Medium
                                   - Non-Corrugating Medium
                                   Wastepaper-Molded Products (W)
                                   Builders' Paper and Roofing Felt (40
                                   CFR Part 431 Subpart A)
   K
Fine and Lightweight
Papers from Purchased Pulp
                                               Non-Integrated Fine Papers (R)
                                               - Wood Fiber Furnish
                                               - Cotton Fiber Furnish
                                               Lightweight Papers (X)
                                               - Lightweight Papers
                                               - Lightweight Electrical Papers
            Tissue, Filter, Non-Woven, and
            Paperboard from Purchased Pulp
                                   Non-Integrated
                                   - Tissue Papers (S)
                                   - Filter and Non-Woven (Y)
                                   - Paperboard (Z)
                                     1-5

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                              Table 1-2

           Application of Proposed Rules to Pulp, Paper, and
                       Paperboard Subcategories
p=====3S==3===============
Effluent Guidelines
Subcategory
Dissolving Kraft
Bleached Papergrade Kraft
and Soda
L_ 	 	 	
Unbleached Kraft
	 	 	
| Dissolving Sulfite
1 Papergrade Sulfite
I) Semi-Chemical
Mechanical Pulp
Non-Wood Chemical
II Secondary Fiber 'Deink
I Secondary Fiber
1 Non-Deink
I 	 	 	
Fine and Lightweight
Papers from Purchased Pulp
Tissue, Filter, Non-Woven,
and Paperboard from
|| Purchased Pulp
=z=z==i 	 1 —
Effluent
Guidelines
Subpart
A
B
C
D
E
F
G
H
I
J
K
L

Clean
Air
Act
NESHAP
X
X
X
X
X
X





	 ._
Clean Water Act |
Priority &
Nonconv;
BAT, NSPS,
PSJES, and
PSNS
X
X
X
X
X
X



X(a)

—
C0nv:
BPT
BCT
NSPS
X
X
X
X
X
X
X
X
X
X
X
X
=^===
BMP
X
X
X
X
X
X

X



1 	 1
(a)NSPS only.
                                    1-6

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                       Table 1-3




Summary of Technology Basis for BAT Effluent Limitations
Proposed Subpart
A
B
C
D
E
F
Name of Subcategory
Dissolving Kraft
Bleached Papergrade Kraft
and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Technology Basis
Oxygen delignification with 70% chlorine
dioxide substitution for chlorine; COD
controls
Oxygen delignification or extended
delignification with 100% chlorine dioxide
substitution for chlorine;
COD controls
COD controls
Oxygen delignification with 100% chlorine
dioxide substitution for chlorine
Totally chlorine-free bleaching; COD
controls
COD controls
                         1-7

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                                                                        2.0 Background
 2.0    BACKGROUND

 2.1    Clean Water Act Requirements

 The objective of the Clean Water Act (CWA) is to "restore and maintain the chemical
 physical, and biological integrity of the Nation's waters" (CWA Section 101(a)). To assist
 in achieving this objective, EPA  issues effluent  limitations  guidelines, pretreatment
 standards,  and new source performance standards for industrial dischargers   These
 guidelines and standards are summarized below.

 2.1.1   Best Practicable Control Technology Currently Available (BPT) - Section 304(b)ri)
        of the CWA

 BPT effluent limitations guidelines apply to direct discharges of conventional poUutants from
 existing sources to waters of the United States.  BPT guidelines are based on the average
 ol the best existing performance by plants in a category or subcategory. In establishing BPT
 bPA considers the cost of achieving effluent reductions in relation to the effluent reduction
 benefits, the age of equipment and facilities, the processes used, process changes required
 engineering  aspects of the control technologies, non-water quality environmental impacts
 (including energy requirements), and other factors as  the EPA Administrator deems
 appropriate (CWA §304(b)(l)(B)).  Where existing performance is uniformly inadequate
 ufL  may be transferred from a different subcategory or category.

 Section 304(a)(4) designates the following as conventional pollutants: biochemical oxygen
 demanding pollutants (measured as BOD5), total suspended solids (TSS), fecal conform pH
 and any additional pollutants  defined by  the  Administrator  as conventional   'The

 197^(44 J FR4450?)nated ^ "** ***** ™ ^ additioml conventi°aal pollutant on July 30,


2'1'2       Conventional PoHutant Control Technology (BCT) - Section 304(b)(4) of the
The 1977 amendments to the CWA established BCT as an additional level of control for
discharges of conventional pollutants from existing industrial point sources. In addition to
other factors specified in Section 304(b)(4)(B), the CWA requires that BCT limitations be
established in light of a two-part "cost-reasonableness" test.  EPA issued a methodology for
the development of BCT limitations in July 1986 (51 FR 24974).                  •
                                       2-1

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                                                                     2.0 Background
2.1.3  BestAvailableTechnologyEconomicaUyAchievable(BAT)--Section304(b)(2)ofthe

      CWA

In general, BAT effluent limitations guidelines represent the best existing ecraomcaUy
achievable performance of plants in the industrial subcategory or category  The CWA
establishes BAT as a principal means of controlling the direct discharge of priority and
nonconventional polluLts to waters of the  United States.  The factors  considered rn
aTesSg  BAT include the age of equipment and facilities involved  the  process ^
potential process changes, and non-water quality environmental impacts, including energy
Sukernents.  The Agency retains considerable discretion in assigning the weight to be
accorded these factors" As with BPT, where existing P^o^ce^^^^
BAT may be transferred from a different subcategory or category. BAT may be based upon
process changes or internal controls, even when these technologies are not common industry
practice.

2.1.4  New Source Performance Standards (NSPS) -- Section 306 of the CWA

NSPS are based on the best available demonstrated technology.  New plants have  the
 opportunity  to  install the best and most efficient production processes and wastewater
 treatment technologies.  As a result, NSPS should represent the most strmgent contro
 attainable through the application of the best available control L techno ^ d^aBu^
 (ie conventional, nonconventional, and priority pollutants).  In establishing NSPS, EPA is
 directed to take too consideration the cost of achieving the effluent reduction and any non-
 water quality environmental impacts and energy requirements.

 2.1.5  Pretreatment Standards for Existing Sources (PSES) - Section 307(b) of the CWA

 PSES are designed to prevent the discharge of pollutants that pass through, interfere with,
 or are otherwise incompatible with the operation of publicly  owned treatment works
 (POTW)  The CWA authorizes EPA to establish pretreatment standards for pollutants that
 pass through POTWs or interfere with treatment processes or sludge ^P08^1.^^
 POTWs.  Pretreatment standards are technology-based and analogous to BAT ettluent
 limitations guidelines.
  The  General  Pretreatment  Regulations,  which  set      .
  implementation of categorical pretreatment standards, are found at 40 CFR Part 403. Those
  regulations contain a definition of pass-through that addresses localized rather than national
  instances of pass-through and establish pretreatment standards that apply to all nondomestic
  dischargers (see 52 FR 1586, January 14, 1987).
                                         2-2

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                                                                       2.0 Background
 2.1.6  Pretreatment Standards for New Sources (PSNS) -- Section 307(b) of the CWA

 Like PSES, PSNS are designed to prevent the discharges of pollutants that pass through,
 interfere with, or are otherwise incompatible with the operation of POTWs.  PSNS are to
 be issued at the same time as NSPS.  New indirect dischargers have the opportunity to
 incorporate into their plants the best available demonstrated technologies.  The Agency
 considers the same factors in promulgating PSNS as it considers in promulgating NSPS.

 2.1.7  Best Management Practices (BMP)

 Section 304(e) of the CWA gives  the Administrator the authority to publish regulations, in
 addition to the effluent limitations guidelines and standards listed above, to  control plant
 site runoff, spillage or leaks,  sludge  or waste disposal, and drainage from raw material
 storage  which  the  Administrator  determines may  contribute significant  amounts of
 pollutants.

 2.2    Overview of the Industry

 Presented below is a brief summary description of the pulp, paper, and paperboard industry.
 Based upon responses to EPA's  1990 National Census of Pulp, Paper, and Paperboard
 Manufacturing  Facilities,  the Agency estimates  that there are approximately  565
 manufacturing facilities located in 42 states. The major pulp production areas in the U.S.
 are the southeast, northwest, northeast, and northern central regions, due to availability of
 fiber furnish and processing facilities.

 The 565 manufacturing facilities that  EPA has considered for regulation comprise  either
 integrated pulp and paper mills, where pulp is manufactured on site from virgin wood fiber,
 secondary fiber, or non-wood fiber; or, non-integrated paper  mills  where only paper or
 paperboard products are manufactured from purchased pulp or pulp produced elsewhere.
 There are approximately 290 integrated pulp and paper mills and 275 non-integrated paper
 mills.

 2.2.1  Raw Materials

 There are  four major types of fiber  furnish used  for papermaking: (a) hardwood;  (b)
 softwood; (c) secondary fibers (recycled  fibers); and (d) non-wood fibers. Pulps produced
 from hardwood trees (oak, maple, birch, beech, and others) -contain relatively short fibers,
 which produce pulps of higher density. Pulps produced from softwood trees (pine, spruce,
 hemlock, and others) contain longer fibers, which produce pulps of greater strength.  Many
papers are made from blends of hardwood and softwood pulps to take advantage of
softwood pulp strength and hardwood pulp density.  About twice as much softwood pulp is
produced in the U.S. compared to hardwood pulp.

                                        2-3

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                                                                      2.0 Background
"Secondary fibers" is the term used to describe furnish obtained from the recycle of waste
papers and paperboard. Depending upon waste paper segregation and processing, secondary
fibers can be converted into most grades of finished paper. Examples of non-wood fibers
include cotton, sugar cane waste called bagasse, flax, and hemp.  Non-wood fibers are most
often used to produce low-volume, specialty grades of paper. Certain plastics and latexes
are also used for specialty papermaking.
                                                               i
2.2.2  Pulping Processes

In 1992 as reported by the American Forest and Paper Association (AFPA), the U.S. pulp
and paper industry produced 90.7 million  tons of pulp  by the following  processes:  (a)
chemical pulping (60.3 percent); (b) secondary fiber pulping (28.0 percent); (c) mechanica
pulping (7.2 percent);  and  (d)  semi-chemical  pulping (4.5  percent).   The principal
distinguishing characteristics and the major products associated with each pulping process
are briefly described below and are detailed in Section 4.0.
                                                               i
Chemical pulping processes are carried out using concentrated chemical solutions at high
temperature and under pressure.  The processes  are characterized by chemical pulps with
relatively low yield and pure fibers that impart particular properties that are important to
high-grade products.  Examples of chemical pulping processes are kraft, soda,  and sulrite.
Extensive chemical recovery cycles or by-products production are necessary for  economical
operation  of chemical pulp  mills.  Modifications of the kraft  and sulfite pulping  and
bleaching processes are  used to  produce "dissolving" grades of pulp for  manufacture ol
selected products where a high purity of alpha cellulose and the virtual absence of ligmn is
desired.

Secondary fiber pulping is carried out mechanically where waste paper and board products
are solubilized in water.  Impurities (e.g., staples, clips, plastics, adhesives) are  remold by
various cleaning steps, depending upon the grade  of wastepaper processed and the product s
 end use  If secondary fiber pulps will be used for the manufacture of printing grades ot
 paper the pulp must also be deinked by chemical and mechanical methods. The grades ot
 paper and paperboard produced from recycled papers or wastepapers are highly dependent
 upon the quality of the wastepaper.

 Mechanical pulping is conducted by mechanical energy, with little or no use of chemicals
 and moderate or no use of heat. The process has high yield and results  in short, impure
 fibers that exhibit good print quality. It is generally not feasible to produce highly bleached
 mechanical pulp.  Examples of mechanical pulps  are stone groundwood, refiner mechanical,
 and  chemi-thermo-mechanical pulps.

 Semi-chemical pulping is generaUy conducted with combinations of chemical and mechanical
 treatments; however, some mills use only chemical treatments.   The  processes  have

                                          2-4

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                                                                        2.0  Background
  intermediate yields and result in pulps with a wide range of properties depending upon the
  degree of mechanical and  chemical methods used.  A common semi-chemical pulping
  process is the neutral sulfite semi-chemical process used to produce corrugating medium

  2.2.3  Pulp Bleaching

  Pulps may either be used to produce unbleached final products from the pulping process
  or pulps may be chemically bleached to desired levels of brightness for the production of
  other products.  Bleached pulps are used for products where high purity is required and
  yellowing (or color reversion) is not desired (e.g., printing and writing papers, food contact
  papers, sanitary paper products).  Unbleached pulp is typically used to produce boxboard
  nnerboard, and grocery bags.                                                       '

  Bleaching is used to whiten pulp by chemically altering the coloring matter and to impart
  a higher brightness.  The selection of wood type for pulping, the pulping process used, end
  the desired qualities and end use of the paper product greatly affect the type and degree of
 pulp bleaching required.  There are  two basic methods to increase the brightness of pulps
 The first is to use selective bleaching agents that destroy some of the colored compounds'
 without significantly reacting with lignin, which binds wood fibers together. This method is .
 used to brighten pulps with high lignin content, such as groundwood and semi-chemical''
 pulps. High brightness values are difficult to achieve without delignification, and significant
 deligmfication of these pulps is not desirable due to the negative impact on yield ^ The
 second method of bleaching includes complete or near-complete removal  of the 'lignin
 remaining after chemical pulping, followed by further bleaching of the pulp to a desired

                                                                                 to
In recent years there has been a major trend in the industry toward reducing both the types
and amount of chlorine and chlorine-containing chemicals used for pulp bleaching. Most
of  these  changes have occurred as  a result  of product quality considerations  and
environmental concerns about the presence of dioxins and other chlorinated compounds in
pulp and paper products resulting from the bleaching of pulps with chlorine and chlorine-
containing compounds.  At many mills, chlorine dioxide is being used in the first stage of
bleaching m place of some or all of the chlorine;  use .of hypochlorite has diminished £
response to concerns about chloroform emissions; and significant efforts have been made
by many mill operators to improve delignification prior to bleaching to minimize bleach
chemical usage and the attendant formation of unwanted chlorinated by-products  At this
       '1 Production of market g^es of high brightness bleached softwood kraft
                .^y denumstrated without the use of any chlorine or chlorine derivatives
                                       2-5

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                                                                   2.0 Background
2.2.4  Paper Making
calendering, reeling, winding, and application of surface treatments.

2.3   Prior Regulations

EPA promulgated BPT, BAT, NSPS, and PSNS for the Builders' Paper and Roofing Felt
Su^eEOTy of the Builders' Paper and Board Mills Point Source Category on May 9, 1974 ,
                                                                         fr the
  ueEOTy o   e
  39 pf 16578 40 CFR Part 431). EPA promulgated BPT, BAT, NSPS, and PSNS for the
 Unbteached Kraft Sodium-Based Neutral Sulfite Semi-Chemical, Ammonia-Based Neutral
 ^le S-Chlmical, Unbleached Kraft Neutral-SulfiteSem>Chemica^ (C"**"™^
 and Paperboard from Wastepaper Subcategories of the Pulp, Paper and Paperboard Point
 Source Category on May 29, 1974 (39 FR 18742; 40 CFR Part 430).
 EPA promulgated BPT for the Dissolving Kraft, Market Bleached Kr aft 1 j^ (Board
 Coaxse, and Tissue) Bleached Kraft, Fine Bleached Kraft, Papergrade Sulfite (Blow IK
 WaTh)  Dissolving  Sulfite  Pulp,  Groundwood-Thermo-Mechanical  Groundwood-CMN
 Capers', Gro^dwgood-Fine Papers, Soda,  Deink, Non-Integrated^Fme Papers, Kg
 Integrated-Tissue Papers, Tissue from Wastepaper, and Papergrade Sulfite (Drum Wash)
 SubStegories of the Pulp, Paper, and Paperboard Point Source Category on January 6, 1977
 (42 FR 1398; 40 CFR Part 430).
 Several industry members challenged the regulations promulgated in May . [974
 1977  These challenges were heard in the District of Columbia Circuit Court of Appeals.
 The promulgatedregulations were upheld in their entirety with one exception. The Agency
 was ordSedto recorder the BPT BOD5 limitation for acetate grade pulp Production m
 tte Dissolving Sulfite Pulp Subcategory (Weyerhaeuser Company, et al. v. Costle, 590 F. 2nd
  1011  me  Circuit 1978))    In  response to this remand,  the Agency proposed BPT
 re^latfomfor acetate grade pulp production in the Dissolving Sulfite Pull > Subcategory on
  March 12, 1980 (45 FR 15952).  These proposed regulations were not promulgated.

  EPApublished proposed effluent limitations guidelines and standards for BAT, BCT, NSPS^
  PSES? and PSNS for 24 of the 25 subcategories of the pulp, paper, and paperboard indus ry
  on January  6, 1981 (46 FR  1430). These regulations were promulgated on November 18,
  1982 (47 FR 52006) with the exception of BCT, which was reserved.  On December 17,
  1986 EPA promulgated BCT effluent Umitations for 24 of the 25 subcategories of the pulp,
  paper a^d paperboard industry (51 FR 45232).  These regulations are currently in effect.
                                        2-6

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                                                                        2.0 Background
 2.4    Summary of Environmental Studies

 After the 1982 promulgation of effluent limitations guidelines and standards, research and
 studies in the United States and other countries showed that pulp and paper mills were
 discharging priority pollutants  that had  not been addressed in the earlier rulemaking
 Presented below is a summary of some of the major studies.

 2.4.1   Swedish Studies

 In the mid-1980s, the Swedish Environmental Protection Board's Environment Cellulose
 Project documented biological effects of pulp and paper mill wastes on several species of
 aquatic life in the Baltic Sea (1).

 2.4.2   National Dioxin Study

 In 1983,  EPA issued  a-Dioxin Strategy to establish a framework  for addressing dioxin
 contamination. As part of the Dioxin Strategy, the Agency conducted a broad National
 Dioxin Study of dioxin contamination in the environment and its associated risks (2)  An
 unexpected finding  of the National Dioxin Study was that the dioxin isomer  2378-
 tetrachlorodibenzo-p-dioxin(2,3,7,8-TCDD) was present in fish downstream from 57 percent
 of the pulp and paper mill sites sampled. To further investigate these results, EPA sampled
 wastewater treatment  sludge at pulp and paper mills in late 1985,  and dioxin was also
 detected in the sludges. The data revealed that, within the paper industry, bleached kraft
 pulp mills contained the highest levels of dioxin. This suggested that dioxin was probably
 being formed as a by-product during the bleaching of wood pulp with chlorine or chlorine
 derivatives.

 2.4.3   Five-Mill Study

 In early 1986, EPA made plans to obtain detailed sampling data from one bleached kraft
 pulp and paper mill  to determine the source of the dioxin.  Before  sampling took place
 industry representatives urged EPA to expand the study from one to five mills. The industw
 agreed to fund a portion of the project and to  supply detailed process information for each
 mill selected for study.  In June 1986, EPA and industry representatives entered into  an
 agreement for a cooperative screening study, often referred to as the Five-Mill Study Full-
 scale sampling started in June 1986 and ended in January 1987.  Two compounds 2378-
TCDD and 2,3,7,8-tetrachlorodibenzofuran (2,3,7,8-TCDF), were detected in the effluents
of four  of the five mills, the pulps of all five mills, and the wastewater treatment plant
sludges  of all five mills (3).                                                     F
                                        2-7

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                                                                     2.0 Background
2.4.4  104-Miil Study

After reviewing the results from the Five-Mill Study, EPA determined that informationrwas
needed from aU chlorine-bleaching facilities to assess if dioxin was being formed at all mills
       hSe containing compounds and to determine how dioxin ™^g««£
       industry  representatives expressed interest in  cooperating voluntarily  to  gather
aMtionafda^  ^agreement waldrafted in late 1987. After the Office of Management
and Budget (OMB) approved the cooperative data collection activities, the agreement was




 1976; Sore, the 104-Mill Study provided EPA with valuable data representative of pulp
 and paper mill operations operating in 1988 (4).

 2.4.5  National Study of Chemical Residues in Fish

 After  the Five-Mill Study, EPA initiated a study to  determine whether fish  tissue  was
 ^LZatedbypoUutaJs of concern, including dioxins and furans. Pulp and paper miUs
 usSg^lorine to  bleach pulp  appeared  to  be   the  dominant  source of  2,3,7,8-
 tetmchlorodibenzo-p-dioxin (2,3,7,8-TCDD) and 2,3,7,8-tetrachlorodibenzofu an (2 3 7£
 TCDF)   Statistical comparisons show that fish near pulp  and paper mills using chlorine
 bare  signmcantiy  highe? concentrations of 2,3,7,8-TCDD than all other  point source
 categories (5).

 2.4.6  Air Emission Findings

 EPA has long known that pulp and paper mills emit chlorine and chloroform to the air  In
     1980s  the Agency attempted to get chloroform  listed as a hazardous air pollutant
         due to £ cardnogenicity, under Section 112 of the  1977 Amendments to the Clean
         f CAA) After the 1990 Amendments to the CAA, the pulp and paper industry was
          a^atgory of major sources of hazardous air pollutants because  of the known
 p_ of chloriS, chloroform, and other HAPs in pulp miU emissions. ™™**£^
 emissions of HAPs from the pulp and paper industry are  estimated *° be  1WJ° "^
 tons per year. In addition, pulp mills are known to be a source of odor due to total reduced
 sulfur (TRS)!  TRS would be controlled as a result of a National Emission Standard for
 Hazardous Air Pollutants (NESHAP).

 2.4.7  Dioxin Reassessment

  In the spring of 1991, EPA undertook a reassessment of the risk of dioxin.  As part of this
  reassessment, EPA is examining the mechanisms by which dioxin apparently causes a variety

                                         2-8

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                                                                       2.0 Background
  of adverse  effects  in animals and humans,  including  cancer, reproductive effects
  developmental effects, and effects on the immune system" EPA's regulatory programs 2e
  proceeding uninterrupted during the preparation of the reassessment.  Findings of the
  reassessment are scheduled to be published in mid-to-late 1994.

  2-5    Litigation History fSince the 1982 Promulgation)

  On March 25,1985, the Environmental Defense Fund and the National Wildlife Federation
  filed suit against the Agency concerning the regulation of dioxins and furans ffinvironmer.^
  Defense Fund and National Wildlife Federation v. Thomas Civ.No. 85-0973 (D.D.C.)). In
                              entered mto a consent decree (the "Consent Decree") on
                The Consent Decree imposed a number of obligations on EPA  Amone
 fr™  1*2? iS* °bllgatiT t0 .f^P* a schedule to address discharges of dioxins and furanf
 from  104 bleaching pulp  mills.  As amended by order dated April 2, 1992  the  Consent
 Decree requires the Agency to propose regulations addressing discharges of dioxins and

 ft  obLa^oneSeTh r °n °r nf°re °Ct0ber 31' 1993' ™S pr°P°Sed rStamaktag satisfies
 this obligation  The Consent Decree requires EPA to use its best efforts to promulgate
 o?tit propofarSSm8 diSChargeS °f dioxms and tons from thes* nulls withinPlZoSte


                     8to° rTired EPA t0 C0nduct a multiPle Pathway risk assessment
                      PA/T^T' nd Pr°dUCtS made fr°m P^ Prod^ed at the ^
       t     i       EpA/Industry Cooperative Dioxin Study.   The results  of EPA's
 integrated risk assessment were published in 1990.

 2-6    Pollution Prevention Apt

 In the Pollution Prevention Act of 1990 (42 U.S.C. 13101 et sea  Public Law 101  sns

          Vf?' Copngress dedaredp°u^
          f   °5? °n ^^ Act declares that poUution should be prevented or reduced
        n        ; P°llutl°Vhat Cam0t be Prevented or red^ed should be recycled or
       ^an1^vironmentally s^ Banner wherever feasible; poUution that cannot be
                    8115                               environment should ^ chosen
                         consistent with this policy.  As described in this document
            oi the proposed rules focused on the pollution-preventing technologies that
            its 0±  the industry have already adopted.  Thus, critical components of the
tT,    i •  "     ' ?r certam effluent limitations guidelines and standards are process changes
that  eliminate the formation of certain  toxic chemicals.   Process changes were also
considered as the technology basis for the  air emission standards.
                                       2-9

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                                                                       2.0 'Background
27    Integrated Regulatory Development




multimedia nature of pollution control.
 2.7.1  Technical Approach

 2.7.1.1       Coordinated Information Collection









  the database reasonably reflects the current status of the industry.








  SlSSSS SSry requirements, and allows consideration oi : other factors such
  as coordinated compliance planning and multimedia pollutant reduction.
                                           2-10

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                                                                       2.0 Background
 2.7.1.2
Development of Effluent Limitations and Air Emissions Control Technology
Options
 After evaluating control technologies and their use in the industry, EPA selected potential
 BAT, PSES,  BPT, BCT, NSPS, PSNS,  and Maximum Achievable Control Technology
 (MACT) control technology options, as weU as BMP; this process is described in Section 9.0.
 Process change options were selected as the primary basis for proposed BAT and PSES
 limitations in all cases because they are the most effective and  economically achievable
 controls for priority and nonconventional pollutants. Combustion, wet scrubbing, and steam
 stripping were selected for the basis of the proposed MACT standards because they are the
 best system of air emission limitation considering the costs, non-air quality health and
 environmental impacts, and energy requirements. Proposed BPT limitations to reduce
 conventional  pollutant effluent loadings are based on wastewater flow  controls and
 improvements to wastewater treatment systems. The proposed BMP are based on pulping
 liquor spill prevention and control.

 2.7.1.3       Analyses of Multiple Integrated Air and Water Regulatory Alternatives

 A series of analyses were conducted to assess the impacts of various combinations of BAT
 PSES, BPT,  BCT, NSPS,  PSNS, and MACT control  options, as well as  BMP.  EPA
 developed regulatory alternatives based on pollution-preventing process changes alone, air
 emission controls alone, and combinations  of process changes and air emission controls.
 Each  regulatory alternative also  included a flow control  and wastewater treatment
 component comprising the BPT technology basis, and a BMP component based on pulping
 liquor spill prevention and control.  The projected effluent  loadings  and air emissions
 resulting from these integrated regulatory alternatives were compared to baseline pollutant
 releases.  Control costs and other environmental and economic impacts for each alternative
 above the baseline level of control were also estimated.  These analyses were used to
 determine the combined  effect of the process changes, air  controls, improvements to
 wastewater treatment, and best management practices.  The alternatives were designed to
 evaluate the most efficient application of control technologies and to minimize the cross-
 media transfer of pollutants between water and air.

 EPA evaluated whether pollution-preventing process changes, such as those selected as the
 control basis for BAT and PSES, reduce HAP emissions sufficiently to satisfy the CAA
 requirements.  Based  on available data,  the analyses showed that use of process  change
 technologies reduces emissions of some HAPs, but increases others. Specifically, process
 change technologies decrease emissions of chlorinated HAPs, including chloroform, chlorine,
 and hydrochloric acid.  This decrease in air emissions of chlorinated HAPs is believed to
be attributable to the  elimination of hypochlorite  as a bleaching agent and to increasing
levels of chlorine dioxide substitution in  the process changes  considered.  However, air
emissions of some nonchlorinated HAPs, including methanol, methyl ethyl ketone (MEK),

                                       2-11

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                                                                      2.0 Background
and formaldehyde, show modest increases as a result of those process changes.  These
patterns in air emissions were observed for the range of process change control options
evaluated as possible technology bases for BAT and PSES.  EPA concluded that process
changes alone do not adequately control HAP emissions to the air, and that air emission
control technologies in addition to the process changes are needed to achieve HAP emission
limitations required by the CAA

EPA also considered the effect of steam stripping process wastewater streams on water and
air pollutant releases, as it is recognized as a control device that reduces both conventional
effluent pollutant loadings and HAP emissions. The analyses showed that flow reduction
and wastewater treatment system improvements would be needed for some mills to reduce
BOD< and TSS  discharges to comply with proposed BPT limitations based  on the best
performing 50 percent of mills with advanced biological  treatment.   Steam stripping
contributes to any necessary BOD5 removal.

A third consideration was the effect of the air controls on effluent loadings of priority and
nonconventional pollutants. The analyses showed that air controls did not significantly affect
effluent loadings of priority pollutants. Combustion destroys most compounds emitted from
process vents, thus reducing the amount of pollutants that could enter surface waters due
to deposition. Chlorinated HAPs remaining after the process changes react with the caustic
in the scrubber, neutralizing the caustic effluent.  Non-chlorinated HAPs that absorb into
the caustic are biodegradable, and are not estimated to significantly increase the pollutant
load to the wastewater treatment system. Steam stripping systems remove compounds from
wastewater streams, and the removed compounds are destroyed in  a combustion device.

2.7.2  Results

The analyses of multiple integrated regulatory alternatives showed that there is no single
 control technology currently available that reduces pollutant discharges to the water and au-
 to the levels required by the respective statutes. The demonstrated control technologies that
 can serve as the bases for BAT, PSES, NSPS, PSNS, and BPT limitations pose no significant
 adverse impacts to, and have some benefits for, air quality. Similarly, the air control
 technologies that can serve as the basis for NESHAP pose no significant adverse impacts
 on  and  have some benefits  for,  water quality.  Therefore, combining the best control
 technology options for effluent limitations with the best control technology options for the
 air emission standards represents a reasonable  method for constructing the integrated
 regulatory alternative.

 EPA-selected control  options for the BAT, PSES, and BPT limitations and the NESHAP
 are based on evaluation of pollutant reductions, costs, cost effectiveness, and economic,
 environmental,  ancl energy impacts. Prior to selection of the proposed rules, an integrated
 regulatory alternative comprising the  sum of the proposed control options for the four

                                        2-12

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                                                                       2.0 Background
 standards  was constructed.   Impacts of the  combined  standards, including  pollutant
 reductions, costs, cost effectiveness, and economic, environmental, and energy impacts, were
 then assessed. This coordinated evaluation ensures that the proposed regulations fully
 satisfy  all  the relevant  statutory requirements  while  minimizing cross-media  pollutant
 transfer, encouraging the use of pollution-preventing process changes, and ensuring the
 greatest environmental benefit for the pollution control costs.

 2.8    References
 1.


 2.



 3.



 4.



5.
 Sodergren, A., B. E. Bengtsson, et. al. Summary of Results from the Swedish Project
 Environment Cellulose.  Water Science Tech., 20(1), 1988.

 U.S. EPA, Office of Water Regulations and Standards. The National Dioxin Study-
 Tiers 3, 5, 6, and 7.  EPA 440/4-87-003,  U.S. Environmental Protection Agency
 Washington, D.C., February 1987.

 U.S. EPA, Office of Water Regulations and Standards. U.S. EPA/Paper Industry
 Cooperative Dioxin  Screening Study.   EPA 440/1-88-025, U.S. Environmental
 Protection Agency, Washington, D.C., March 1988.

 U.S. EPA, Office of  Water Regulations and Standards. U.S. EPA/Paper Industry
 Cooperative  Dioxin  Study  "The  104-Mill  Study"  Summary  Report.    US
 Environmental Protection Agency, Washington, D.C., July 1990.

U.S. EPA, Office of Science and Technology. National Study of Chemical Residues
in Fish. EPA 823-R-92-008a, U.S. Environmental Protection Agency, Washington
D.C., September 1992.                                                       '
                                      2-13

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                                                   3.0 Summary of Data Collection Methods
 3.0    SUMMARY OF DATA COLLECTION METHODS

 3.1    Introduction

 The Agency collected information necessary for the development  of revised effluent
 limitations guidelines  and standards from many sources, including several Agency and
 industry sampling programs, an industry-wide census, questionnaire surveys submitted to
 mills in other countries, industry trade  associations,  public meetings, mill  site visits,
 conferences, literature reviews, and  other EPA offices.  This section  summarizes each
 information collection activity.

 3.2    Wastewater Sampling

 3.2.1  Evaluation of Five-Mill and 104-Mill Study Data

 In response to findings of 2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD) in native fish
 collected downstream from a number of bleached kraft pulp and paper  mills from Tier 7
 of the National Dioxin Study, EPA and the American Paper Institute  (now the American
 Forest and Paper Association, AFPA) undertook a joint screening study during 1985 and i
 1986 at five bleached kraft mills (1,2).  This study provided the first comprehensive results,
 released in  1987,  on formation and  discharge  of chlorinated  dibenzo-p-dioxins  and
 dibenzofurans (CDDs and CDFs) in pulp and paper mills (3,4).

 This early screening study of five bleached kraft mills (Five-Mill Study) confirmed that the
 pulp bleaching process was primarily responsible for forming CDDs and CDFs.  The
 partitioning of these compounds among the bleached pulp, wastewater treatment sludge, and
 final effluent was found to be highly variable among the five mills. The study also indicated
 that 2,3,7,8-TCDD  and  2,3,7,8-tetrachlorodibenzofuran (2,3,7,8-TCDF) were the most
 significant CDDs  and CDFs formed during the pulp  bleaching process.  The combination
 of 2,3,7,8-TCDD and 2,3,7,8-TCDF accounted for more than 90 percent of the 2,3,7,8-TCDD
 toxic equivalents for these samples using either the 1987 EPA toxicity  equivalency factors
 (TEF) or the I-TEFs/89 approaches (5).

 To provide EPA with more complete data on the release of these compounds by the U.S.
pulp and paper industry,  a second screening study was initiated in April 1988  to further
 characterize all 104 U.S.  mills then practicing chlorine bleaching of chemically produced
pulps (6,7,8,9).  The scope of the 104-Mill Study was developed by EPA and  the paper
industry, and the study was managed by industry with EPA overview.  The data from this
study provided an estimate of the release of 2,3,7,8-TCDD and 2,3,7,8-TCDF in three
environmental export vectors (bleached pulp, wastewater sludge, and final effluent) as of
mid- to late-1988.  The preliminary findings from the initial Five-Mill Study were confirmed
and supplemental  analyses clearly indicated that 2,3,7,8-TCDD and 2,3,7,8-TCDF were the

                                       3-1

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                                                  3.0  Summary of Data Collection Methods
principal CDDs and CDFs formed in pulp bleaching.  The results are summarized in the
following table (8):

Medium
Bleached Hardwood
Pulp
Bleached Softwood
Pulp
Final Effluent

Wastewater Sludge

-
Palp
Process
Kraft
Sulfite
Kraft
Sulfite
Kraft
Sulfite
Kraft
Sulfite

Unit
ppt
ppt
ppt
ppt
ppq
ppq
ppt
ppt

Median
4.0
4.4
7.6
3.5
35
12
39
4.7

Maximum
56
15
116
3.5
640
23
l',390
58
Z£ft$*
Median i
17
9.9
26
6.3
100
35
161
63

Maximum
661
323
2,620
449
8,400
840
17,100
584
       Short-Term Studies

 Thirteen short-term sampling episodes were conducted from 1988 through mid-1993 at mills
 that chemically pulp and bleach wood. Eleven of these episodes were conducted by the
 Agency  and two were conducted cooperatively with the respective mills.  The first three
 sampling episodes, performed in 1988, served as screening episodes, and allowed the Agency
 to narrow the list of pollutants to be examined during future episodes. During these first
 three  episodes, samples were analyzed for the following groups of analytes:  chlorinated
 dioxins  and  furans,  chlorinated  phenolics, volatile  organics,  semi-volatile  organics
 pesticides/herbicides, metals, conventional pollutants (biochemical oxygen demand (BOD5)
 and totalsuspended solids (TSS)), andnonconventional, bulk-parameter pollutants (chemical
 oxygen  demand (COD), adsorbable organic halides (AOX),  and  total organic halides
 (TOX)).  Subsequently, two short-term sampling episodes were conducted in 1989,  six in
 1990,  one in 1992, and one in 1993.  During these episodes, samples were analyzed for
 chlorinated dioxins and furans, chlorinated phenolics, volatile organics, BOD5, COD, TSS,
 and AOX.

 Mills were selected for participation in the short-term sampling program based on particular
 pulping or bleaching technologies, wastewater treatment, or particular fiber furnishes used
 or products produced. The following table summarizes the subcategory, fiber furnish pulped
 during  sampling, BAT technology option in place on the fiber lines sampled, type of
 treatment system, and discharge status for each short-term study mill.
                                         3-2

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                                                    3.0 Summary of Data Collection Methods
Mttt
1
2
3
4
5
5
6
8
9 .
10
11
12
13
Terms:
DK =
BPK =
UBK =
HW =
SW =
ACT =
ASB =
1
Subcategory
DK
BPK
BPK
BPK
BPK
BPK
BPK, UBK
BPK, UBK
BPK
BPK
BPK
BPK
Fiber
Furnish
HW
HW
SW&HW
SW&HW
SW
SW
SW
HW
HW
SW&HW
HW
SW
BAT Option
none
none
none
none
none
none
none
none
none
none
2 •
3
BPK SW 5
' ' '
Dissolving Kraft Subcategory
Bleached Papergrade Kraft and Soda Subcategory
Unbleached Kraft Subcategory
Hardwood
Softwood
Activated Sludge Treatment System
Aerated Stabilization Basin
=^^ 	
Wastewater
Treatment
ACT
ASB
ASB
ASB
ASB
ACT
ASB
primary
primary
primary
ACT
ASB
ACT
=^=^===^=
•— — ™- 1
Discharge
Status
Direct
Direct
Direct
Direct
Dkect
Direct
Direct
Indirect
Indirect
Indirect
Direct
Dkect
Direct
=^^=^=^=
At each mill sampled in 1988 through 1990, sampling points were selected to characterize
wastewater discharges from various process areas (pulping area sewers, bleach plant filtrates
and  paper machine white water),  mill  exports (final effluent,  pulp, and  sludge), the
performance of the wastewater treatment system (one or more influents and final effluent)
and mill process water and brown stock pulp. For the sampling episodes in 1992 and 1993
the sampling points were limited to bleach plant filtrates, bleached pulp, and wastewater
treatment system influent, effluent, and sludge samples.

The  Agency reviewed  the  analytical  data  from the short-term  studies to  ensure that
analytical method quality assurance/quality control (QA/QC) requirements were met. Each
analytical method specifies particular QA/QC requirements which, in general, include
                                       3-3

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                                                 3.0 Summary of Data Collection Methods I
certain time periods in which samples must be analyzed, specific recoveries that must be
obSeS internal analytical standards, and duplicate or corifirmatory «^ P^^
Datathat did not meet specific criteria were excluded from the database  For example the
       method for analysis of 2,3,7,8-TCDF specifies that when this analyte is detected in
           confLatory analysis must be performed. If 2,3,7,8-TCDF was detected in he
             "™«BJ*ory analysis was not performed, ^.«^<^f^S
value was removed from  the database.   During the years in which these studies were
conducted,  a  few  analytical  methods   and  QA/QC  requirements  were   changed
Sequently  the quality of analytical data from short-term studies that were used to
I^SSSS^ options were reviewed to ensure that the QA/QC criteria established
during the long-term study (described below) were met.

In addition to these QA/QC reviews, the  Agency performed an engineering review of the.
d^ta to evaluate sample results versus results for field blanks and background process water
samples  Idditionafdata were excluded from the database based upon ^ engineenng
review when it appeared likely that the presence of certain compounds m some samples,
particularly volatile organic compounds, was  due to contamination during  sampling,
P^™n, shipping, or analysis'^ Following both QA/QC reviews and the —ring
Review,  an  approbate total of 784  analytical determinations were excluded from the
 dSse (approximately  1.8 percent of the data). As a result of using ; established and
 documented sampling and analytical protocols and these extensive QA/QC reviews, the
 database contains only high-quality data that are representative of samples obtained.
 During development of the proposed regulation, many miUs
 operating changes in the bleach plant to reduce the formation of 2,3 7,8-TCDD and 2,3
 TCDF and other chlorinated pollutants. Because the bleaching technologies of interest to
 the Agency in 1988 as possible BAT options are different from those presented  in this
 proposal, many of the analytical data from short-term studies do not fully represent the BAT
 technology options in this proposal (as indicated in  the table above).

 32.3  Long-Term Study

 The scope of the Agency's long-term study was substantially expanded by a voluntary and
 cooperative effort between EPA  and the  industry.   The American Forest and  Paper
 Association and the National  Council  of the Paper Industry  for Air and  Stream
 Improvement, Inc.  (NCASI) cooperated  with  EPA in coordinating and conducting  he
 collection  and analysis of  data from  eight pulp and paper  mills.  The majority at  the
 wastewater and sludge analyses were contracted and paid for by the industry. Laboratories
 with demonstrated capability to perform the analytical methods were selected with the
 Agency's approval.
                                         3-4

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                                                    3.0 Summary of Data Collection Methods
 The Agency initially made suggestions to the industry regarding mills to include in the long-
 term study sampling program based on particular pulping or bleaching technologies,
 wastewater treatment, or particular fiber furnishes used or  products  produced.  The
 following table summarizes the subcategory, fiber furnish during sampling, BAT technology
 option in place on the lines sampled, type of treatment system, and discharge status for each
 mill selected by the industry to participate in the long-term study.
Mm
i
2
3
4
5
6
7
8
Subeategory
DK
BPK
BPK
BPK
BPK, UBK
BPK
BPK
DS
Fiber
FlDroish
SW&HW
HW
SW&HW
HW
SW
SW&HW
SW
SW
BAT Option
none
none
1
2
2
3
4
1
Wastewater
Treatment
ASB
ASB
ACT
ACT
ACT
ASB
ASB
ASB
Discharge
Status
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Direct
Terms:
DK = Dissolving Kraft Subcategory
BPK = Bleached Papergrade Kraft and Soda Subcategory
UBK = Unbleached Kraft Subcategory
DS = Dissolving Sulfite Subcategory
SW = Softwood
HW = Hardwood
ASB = Aerated Stabilization Basin
ACT = Activated Sludge Treatment System
At each mill, sampling points were selected to characterize the bleach plant effluent, mill
exports (final effluent, pulp, and sludge), and the performance of the wastewater treatment
system. Bleach plant effluents were characterized by collecting samples that represent the
total discharge from a bleach line, typically an acid filtrate (or acid sewer) and an alkaline
filtrate (or alkaline sewer) and other filtrates that may have been discharged separately.
Mill process water, the influent and effluent from wastewater treatment, bleached pulp, and
wastewater treatment sludge were  also sampled.   The following table summarizes the
constituents for which the samples were analyzed.
                                        3-5

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                                                 3.0 Summary of Data Collection Methods
Sampling Point
Process Water
Bleach Plant
Filtrates
Influent to
Treatment
Effluent from
Treatment
Bleached Pulp
Sludge
Volatile .
Organlcs
X
X
X
X

X
Dioxins &
Ftttaas
X
X
X
X
X
X
Chlorinated
Phenolics
X
X
X
X
X
X
___-__^_______.^_____«-^— -—-
AQX
X

X
X

X
B0P»
IBS, and
Color
X

X
X


Detailed sampling plans were prepared by the Agency and reviewed with mill^ personnel
prior to the first week of sampling (10). The mill-specific sampling plans included analytical
methods, sampling and shipping procedures, and contemporaneous process and wastewater
treatment operational data-gathering requirements. Prior to the start of the study, EPA and
its technical contractor conducted a workshop with mill personnel to familiarize them with
the details of the procedures required by the sampling plans. NCASI and EPA contractor
staff were on site during the first week of sampling at each mill.

Samples were collected during one 24-hour period each week for nine weeks during the
summer of  1991, and each week for nine weeks during the winter of 1991-1992.  Mill
personnel were responsible for collecting the samples, and accurately reporting wastewater
flow  bleached pulp production, and mill  operating  conditions.  The Agency audited
sampling performance in the eighth or ninth week of the summer program, and again during
the winter  program to assess whether mill  personnel were following the  site-specific
sampling plans.  Summer and winter program audit  reports were prepared for each mill.
Most of these reports contain confidential business  information (CBI) pertaining to mill
operations during the study. At  the conclusion of the long-term study, a non-confidential
audit report was prepared to summarize audit results from both the summer and winter
programs for all eight mills (11).  The audits uncovered very few significant deviations from
established sampling and sample handling protocols.

The Agency and NCASI jointly reviewed the quality  of the long-term study analytical data
to ensure that appropriate QA/QC criteria were met.  Data that did not meet appropriate
QA/QC criteria were excluded from the database.  Details of these  reviews are provided
 elsewhere (12,13,14,15).  During these reviews, a total of 3,109 analytical determinations
                                        3-6

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                                                           3.0  Summary of Data Collection Methods
  were excluded from the database (approximately 3.7 percent of the data). The distribution
  ol data that were excluded from the database are summarized in the following table:
        Antdyte Group
Medium
 Overall
Percentage
 of Date
 Excluded
 Aaalytes With Greater than the Overall
Percent Exclusions for the Anatyte Group
and jftsrcentage of Data Excluded for the
        Analyte «ntd Medium
    Dioxins/Furans
 Liquids
                                              1.3
   Dioxins/Furans
   Chlorinated Phenolics
 SoUds
 Liquids
                                                       Octadibenzo-p-dioxin
   Chlorinated Phenolics
 SoUds
                                             0.0
                                                       4-Chlorocatechol
                                                       2-Chlorosyringaldehyde
                                                       3,4-Dichlbrocatechol
                                                       3,6-Dichlorocatechol
                                                       4,5-Dichlorocatechol
                                                       4,6-Dichloroguaiacol
                                                       3,4,5-Trichlorocatechol
                                                       3,4,6-Trichlorocatechol
                                                       Tetrachlorocatechol
                                                          17
   Volatile Organics
Liquids
  2.7
   Volatile Organics
Solids
                                                       Diethyl Ether
                                                       Methylene Chloride
                                                       Trichlorofluoromethane
                                                       1,4-Dioxane
                                                       2-Propanone
  2.7       Diethyl Ether
            Methylene Chloride
            Trichloroethene
            Trichlorofluoromethane
            1,1,1-Trichloroethane
            1,4-Dioxane
            2-Butanone
            2-Propanone
  Adsorbable Organic
  Halides (AOX)
  Organic HaUdes (OX)
In addition to the QA/QC reviews, the Agency performed an engineering review of the
data  Like the engineering review of short-term study data, this review evaluated sample
results versus results for field blanks and background process water samples. However this
review also evaluated  whether any deviations  from established sampling  and sample
                                            3-7

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                                                 3.0 Summary of Data Collection Methods
coSd dS   blea?hplant shutdown (174 excluded); and data for volatile organic
 0ompHdsrgseveral san^s that were excluded for other reasons (6exchidd)
After the QA/QC reviews and  the  engineering  review, a total o4,945
^errnmations were excluded from the database (approximately 60 percent:of
As a result of using established and documented sampling and analytical protocols and these
e^tenslvf data reviews, the database contains only high-quality data that are representative
of samples obtained.

3.3   National Census Questionnaire

    important data-gathering activity was an industry-wide census which was conducted by
        a detailed questionnaire to all known U.S. pulp and paper faohties^ appronmately
           7^ The Agency collected questionnaire data under the authority of Section 308
 oh^r Act, Section 114 of the Clean Air Act, and Section3007 of the Resource
 Conservation and Recovery Act.







 schematics- waste tteatment system schematics; daily production information; daily, monthly
 avenge bimonthly maximum monitoring data for BOD5, TSS, and  flow for combined
 wStewate^treatment system influent and final effluent streams over a one-year^period and
 IvaillblTtoxics  monitoring data for  all media.   The  questionnaire requested detailed
 JS±*T£o£ each facility  for the calendar year  1989, although some economic,
 production, and  amdytical data were requested for 1985 through 1989.

 The Asency submitted the questionnaire to the Office of Management and Budget (OMB)
 S Maf 9 Tw  for approval under the Paperwork Reduction Act. The questionnaire was
 Proved by OMB  on August 10, 1990, and was mailed on October 4, 1990.  Responses
 SduebLkby January S, 1991. While facilities were completing the^q^sUormaure  ^e
 Asencv provided assistance to questionnaire respondents through a toll-free he p line. Two,
  aSnaU^ers were sent to each facility clarifying a few questions, and workshops were
  held in Atlanta,  Georgia and Vancouver, Washington to assist representatives in completing
  the questionnaire.

                                         3-8

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                                                     3.0 Summary of Data Collection Methods
  Questionnaires were submitted to approximately 600 mills.  The Agency received some
  incomplete responses and determined that some facilities were ineligible (i.e., they do not
  produce products representative of facilities in this point source category).  The Agency
  reviewed questionnaire responses for completeness and response consistency, often clarifying
  responses  with  null  personnel via  teleconferences and  written confirmation  of these
  conversations.  Responses to the  entire questionnaire  (except for certain supplemental
  information) for all bleaching chemical pulp mills were entered into an electronic database
  Selected responses for all remaining mills also were entered into the database. Remaining
  responses were utilized in hard copy as submitted.  The database contains information for
  565 mills.

  The information was key-entered using a data processing system in which responses to each
  questionnaire  were independently double-entered.   The  two key-entry files were then
  independently compared and any discrepancies in the key-entry were investigated and
 resolved by a third independent reviewer. Next, a random sample of the electronic data was
 compared to the original written questionnaire responses to further ensure the accuracy of
 the data entry.  Finally, the data were processed through a series of programs designed to
 detect any inconsistencies in skip patterns, general logic, arithmetic, and response ranges
 (e.g., product codes).  Any inconsistencies discovered were referred to the technical and
 economic reviewers and resolved through further review or contact with the facility  These
 databases were then placed on the EPA National Computer Center (NCC) mainframe on
 protected data tapes.

 The Agency supplemented the database by sending foUow-up letters to those  facilities
 particularly mills that chemically pulp and bleach wood, that indicated they would make
 process changes in' 1990 and 1991.  These facilities were asked to verify that the process
 changes had been made, to update the relevant pages of the original questionnaire, and to
 submit analytical data that reflected the operating change, if available.  As this updated
 information was received, it was entered into the questionnaire database.

 3-4    Data Collection From Non-U.S. Mills

 The Agency submitted a survey to mills in other countries requesting the same information
 as was requested in the questionnaire sent to U.S. mills. The purpose of this data collection
 activity was to obtain analytical and operating data for pulping and bleaching technologies
 in use at those mills.  In some countries, the  information was requested through the
 representative environmental protection authority rather than from individual mills It
 should be noted that these mills and agencies were under no legal obligation to provide the
 requested information to the Agency.

Information was requested for approximately 45 mills in 15 countries. The Agency received
responses for 27 mills, of which only a few responses included all of the information

                                        3-9

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                                                 3.0 Summary of Data Collection Methods
requested.  Of the mills for which data were submitted, most responses did not |
Iy£e of analytical data that was requested and  most responses  provided only limited
information about pulping and bleaching operations.
 3.5    T>ata Collected for NESHAP

 The EPA Office of Water (OW) and  the Office of Air and Radiation (OAR)  often
 Sagged  industry-related information  during  the development of  the mtegra ted
 Remaking.   Sampling plans, sampling data,  and questionnaire data were among ; the
 Sources fhat the offices shared. Information in the q™*"™" distributed by OW m
 1990  particularly air monitoring results,  were provided to  OAR.  In addition to this
 Questiormaire  OAR  and  NCASI  jointly  developed   another  survey questionnaire
 ?SSS^tSrfmatiaa for EPA's Development of Hazardous Air Pollutan ^Emission
 Standards for Pulp and Paper Manufacturing") for facilities potentia %°&«"*W£
 proposed air emission standards; this voluntary questionnaire was mm ^ m Febmary 199^
 Where simUar data were requested in both questionnaires (for differen t years)  OW and
 OAR combined the information into one database for the purpose of characterizing the
 mdSttyS W92. This, combined database was used by both OW and OAR or estimating.
 pVSSemovals and compliance costs for the air and water components of the integrated
 rulemakhig.

 3.6    Supplementary Data Collection

 In addition to the data collection activities  previously  described, the Agency collected
 supplementary information from public meetings, mill site visits, literature, conferences, and
 other EPA offices.

 3.6.1  Public Meetings

 The  Agency held five public meetings during 1992 and 1993  to brief the public  on  the
  development status of the proposed regulations and to solicit comments from the  pub he
 An infonnationpackage was either mailed to participants before the meetings or distributed
  at the meetings; each information package is now available in the record for the rulemakmg.
  The  dates and locations of these meetings were as follows:
                                         3-10

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                                                    3.0 Summary of Data Collection Methods
                     September 30, 1992, Washington, B.C.
                     December 16, 1992, Arlington, VA
                     February 24, 1993, Durham, NC
                     May 19,  1993, Herndon, VA
                     June 30, 1993, Durham, NC

 The Agency received comments on the development of the proposed regulations during
 these meetings.  These comments are described in summaries of each meeting which were
 prepared by the Agency and are available in the record for the rulemaking.  The Agency
 abo received written comments from several organizations. The Agency incorporated manv
 ot these comments into the proposed rulemaking.

 3.6.2  Mill Site Visits

 During development of the proposed regulations, the Agency conducted many mill site visits
 Site visits were  conducted to obtain information  on particular pulping, bleaching  or
 wastewater treatment operations and to evaluate a mill for possible inclusion in a sampling
 program. The information coUected during a site visit is an important supplement to the'
 questionnaire information provided by each mill.  Site visit reports are contained in the
 record for the rulemaking, but some reports are not publicly available because they contain
 confidential business information.

 3.6.3  Literature

 Industry journals such as Pulp and Paper and TAPPI Journal WCTP. reviewed regularly during
 development of the proposed regulations. Agency staff and contractors also attended manv
 conferences during this period, including TAPPI pulping, bleaching, and environmental
 conferences and other specialty conferences. For research on  specific topics, literature
 searches were conducted and relevant papers were obtained. All conference proceedings
 and literature articles used to support each proposed regulation were included in the record
 tor the rulemaking.

 3.6.4   Information from Other EPA Offices and Agencies

 OW often exchanged industry-related information with  other  EPA offices during  the
proposed regulations development. In addition to OAR, as discussed above, OW exchanged
information with  the Office of Pollution Prevention and Toxics (OPPT) regarding  the
disposition of sludges from mills thai chemically pulp and bleach wood. The questionnaire
asked about sludge handling practices, including analytical data for various  compounds
found in sludge.  OPPT reviewed the data and prepared a report summarizing its findings
(18). Selected information was also obtained from EPA regional offices.
                                       3-11

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                                                 3.0 Summary of Data Collection Methods
3.6.5  Voluntary Submission of Data









 summaries which provide updated profiles of 2,3,7,8-TCUU ana z,^/,o ^
 sludge, and pulp at the bleaching chemical pulp nulls.
3.7

1
 4.
 6


 7
       References
                                                              I
       II S  EPA, Office of Water Regulations and Standards.  The National Dioxin Study:
       Tiers W^d 7.   EPA-440/4-87-003,  U.S. Environmental Protection Agency,
       Washington, D.C., February 1987.

       U S  EPA, Office of Solid Waste and Emergency Response.  The National Dioxin
       Study? ReportTo Congress. EPA/530-SW-87-025, U.S. Environmental Protection
       Agency, Washington, D.C., August 1987.

       U S EPA, Office of  Water Regulations and Standards. U.S. EPA/Paper Industry
       S?op!fativ' HSoxL  Screening Study.   EPA440/1-8M25. U.S. Environmental
       Protection Agency, Washington, D.C., March 1988.

                                                                       in Bleached
        Amendola, G. A., et al. The Occurrence and Fate
        Kraft Pulp and Paper Mills. Chemosphere, 18(1-6): 1181-1188, 1989.

                   Risk Assessment Forum.  Interim Procedures  for Estimating Risks
                        E^0r:f to Mixtures of  Chlorinated Dibenzo-p-dioxins  and
                       (CDDs and CDFs).  EPA/625/3-89/016,  U.S.  Environmental
        Protection Agency, Washington, D.C., March 1989.

        U.S. EPA.  U.S. EPA/Paper Industry Cooperative Dioxin Study.  Washington, D.C.,
        April 26, p88 (104-Mill Study Agreement).

        U S EPA, Analysis and Evaluation Division. U.S. EPA/Paper Industry Cooperative
        Siox£ Study, "The 104  Mill Study," Statistical Findings and  Analyses.   U.S.
        Environmental Protection Agency, Washington, D.C., June 199U.
                                         3-12

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                                                  3.0 Summary of Data Collection Methods
 10.




 11.



 12.




 13.




 14.




 15.




 16.




 17.



18.
        U.S. EPA, Office of Water Regulations and Standards. U.S. EPA/Paper Industry
        Cooperative  Dioxin  Study,  "The 104  Mill Study" Summary Report.   US
        Environmental Protection Agency, Washington, D.C., July 1990.

        WMttemore R C, L.E. LaFluer, W.J. Gillespie, G.A. Amendola, and J. Helms. U.S
                                                  The 104 Mill Study. Chemosphere,
 Radian Corporation. Generic Sampling and Analysis Plan for U.S. Environmental
 Protection Agency and Paper Industry Cooperative Long-Term Variability Study
 Radian Corporation, Herndon, Virginia, July 31, 1991.


 Radian Corporation. Audit Report for the U.S. EPA/Pulp and Paper Industry Long-
 lerm Study. Radian Corporation, Herndon, Virginia, March 1993.

 Radian Corporation. Draft Quality Assurance Project Plan for the Pulp  Paper and

                    Samplmg Pr°Sram-  Radian Corporation, Herndon, Virginia,
 U-\EpA> SamPle C°ntro1 Centen SamPle Contro1 Center Data Review Guidelines
 for the Pulp and Paper Industry Study Final Draft. Viar and Company, Alexandria
 Virginia, June 1991.                                                        '


 U.S.  EPA,  Sample  Control  Center.   Compilation of  Data  Quality  Review
 Documentation for the Summer Phase of the Pulp and Paper Variability Study Viar
 and Company, Alexandria, Virginia, October 1992.

 U.S.  EPA,  Sample  Control  Center.   Compilation of  Data  Quality  Review
 Documentation for the Winter Phase of the Pulp and Paper Variability Study  Viar
 and Company, Alexandria, VA, October 1, 1992.


 Radian Corporation.  Summary of Preliminary Engineering Review of Long Term

 U S                    111 fr°m D°Ug SpCnge1'  Radian C0rp" t0 Ge°rge Heath'
U.S.  EPA.    U.S.  EPA  National  Census  of Pulp, Paper, and Paperboard
Manufacturing Facilities Questionnaire, 1990.
Am/, ****** .Gro*P> Inc.   Economic Analysis of Impacts of Integrated
Air/Water Regulations for the Pulp and Paper Industry on Disposal of Wastewater
Sludge, Draft Final Report, August 17, 1993.
                                      3-13

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                                                             4.0 Description of the Industry


  4.0    DESCRIPTION OF THE INDUSTRY

  4.1    Introduction

  The pulp, paper, and paperboard industry includes mills that manufacture market pulp
  paper, and/or paperboard from wood or non-wood pulp.  Wood and non-wood pulp may
  be manufactured on site, obtained from other mills by purchase or intra-company transfer
  or derived from pre- and/or post-consumer reclaimed fiber (secondary fiber). This section
  describes  the  manufacturing processes used  in the industry, including fiber furnish
  preparation and handling, pulping, chemical recovery, pulp processing, bleaching  stock
  preparation,  and pulp, paper, and paperboard making.   This  section also provides a
  statistical profile of the manufacturing processes used in the U.S.  industry in 1989 as
  reported in the  1990 questionnaire. The following information is profiled:  the types and
  amounts of fiber furnish used and related preparation and handling; types and amounts of
  pulp manufactured and pulping equipment used; bleaching processes used and application
  of these processes to different types of pulps; and the types and amounts of final products
  manufactured.  Also included in this section is a discussion of trends in the industry.

 4.2   Manufacturing Processes

 4.2.1  Overview of Manufacturing Processes

 The only  processes common to all mills are pulp stock  preparation and final  product
 manufacture   Figure 4-1 illustrates the primary processes used at a typical bleached
 chemical pulp mill, which include:

              Fiber furnish preparation and handling (log slashing, debarking, chipping and
              screening);                                                  ^  &'

       •     Pulping (chemical, semi-chemical, and/or mechanical);

       •     Chemical recovery;

             Pulp processing (deknotting, brown stock washing, screening, cleaning and
             thickening);                                                     &

       •      Bleaching; and

       •      Stock preparation (mixing, refining, and addition of wet additives).

If a mill manufactures market pulp, paper, or paperboard, the pulp from the bleach plant
will proceed to a paper machine, similar to that shown in  Figure 4-2.  Pulp, paper, and

                                        4-1

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                                                           4.0 Description of the Industry
      Fiber Furnish and Fiber Furnish Preparation and Handling












to pulping are described in Section 4.2.2.1.







secondary fiber prior to pulping are described in Section 4.Z.2.Z.




fibers and inorganics.






 facilities.

 In all cases  the type(s) of fiber furnish used depends primarily upon the mill location.  For
 exa^r mtegS  pulp  mills  (mills  that  manufacture final products  from  pulp
 mTutmrTd ?n site) « pulp' a furnish grown within a ^^
 mill, whereas secondary fiber mills are typically located near urban areas, sources
 consumer fiber.
                                          4-2

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                                                             4.0 Description of the Industry
  4.2.2.1
Wood Preparation and Handling
  Wood preparation entails converting wood into a form amenable to chemical or mechanical
  pulping. Mills that receive wood in the form of logs may operate log ponds and flumes to
  transport wood to the pulp mill.  Other mills receive logs via barge, log rafts, truck or
  raiicar.  Tree-length logs are generally cut  to manageable lengths using a slasher   Log
  WEJ ungj?ay be Performed to remove soil and debris to reduce wear on wood preparation
  and handling equipment.

  Virtually all mills that handle logs perform debarking, because bark is considered to be a
  contaminant in pulping operations. A variety of debarking processes may be used, including
  mechanical and hydraulic debarkers. Debarkers differ in their energy requirements wood
  loss, and ability to debark frozen logs and species with strong bark adhesion. In mechanical
  debarking, bark is removed either by logs rubbing against each other, or by cutting tools that
  cut and abrade bark. In hydraulic debarking, a high pressure water jet is used to blast bark
 from the logs. Hydraulic debarking is generally confined to large diameter logs and logs
 with fluted surfaces, which are not amenable to mechanical debarking.  Bark is typically

                          fUmaCeS WMCl1 may Pr°dUCe 6nergy dePendmS on the moisture
 Subsequent wood preparation operations performed depend upon .the pulping processes
 used at the mill.  Certain mechanical pulping processes, such as stone groundwood pulping
 are performed using roundwood (logs); however, the majority of pulping operation require
 wood chips. Debarked logs are generally chipped using blades mounted on a rotating disk
 Well designed and operated chippers produce chips of uniform size about 20 mm tone in
 the gram direction^ and about 4 mm thick (1). Some mills depend upon suppliers to provide
 wood chips of uniform size. Chips are typically received on site by truck, raiicar, or barge.

 After chipping, wood chips are passed over vibratory screens to remove oversized chips and
 fines Oversized  chips remain on the upper screen and are recycled to a rechipper. Fines
 tall through all the screens and are collected and usually burned with bark (1)  Chips are
 typically screened by length; however, some mills also screen chips by thickness to improve
 pulp uniformity and quality after digestion, and to reduce bleaching chemical requirements
 where bleaching  is used  (see  Section 8.2.1).  When chips are  screened for thickness
 oversized chips are sent to a reslicer.                                           w"«a*,

After screening,  chips are generally stored in large  outside piles and are moved to
subsequent operations via conveyors or augers.  Chip bins or silos may also be used to
facilitate metering and blending of chips (e.g., mixing hardwood and softwood chips) prior
                                        4-3

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                                                          4.0 Description of the Industry
             Secondary Fiber Preparation and Handling

Secondary fiber preparation and handling involves sorting and classifying the materials into
     Tades  Generally, these operations are performed by the collector or the waste
      dfaler rather than a the mill  At the mill, secondary fiber preparation and handling
          TS more than storage and a transfer and dewiring system for second^
fiber bales.  Bales are charged  directly  to  the continuous pulper where pulping and
contaminant removal are performed.

4.2.2.3       Non-Wood Fiber Preparation and Handling

After being harvested, non-wood plant fibers are stored before being chopped, screened imd
cleaned prior to pulping.  The handling methods are specific to each particular fiber  to
prevent fiber degradation and therefore produce the highest possible pulp yield.

4.2.3  Pulping Processes

Pulping processes convert raw materials into fibers that can be formed into a sheet. P^mg
may be performed chemically or mechanically using a variety of processes described below
The selection of a pulping method depends upon the  final product to be produced a^id the
raw material used Although secondary fibers, by definition, have previously undergone
pulping  they require additional processing to  make them amenable to forming into a sheet.
Accordingly, secondary fiber processing is also described in this section.
 4.2.3.1
Chemical Pulping
 Chemical pulping involves mixing the raw materials with cooking chemicals under controlled
 temperature Ld pressure conditions to yield a variety of pulps with unique properties.
 Chemical pulps are manufactured into products that have high-quality standards or require
 special properties.  Three types of chemical pulping are currently used in the U.S.:  1) krait
 pulping" 2) sulfite pulping,  and 3) soda pulping.  All three processes include cooking
 (digesting) wood chips or non-wood furnishes in aqueous chemical solutions at elevated
 temperatures andpressures to dissolve the lignin that binds cellulose fibers together.  The
 degree of lignin removal is measured by the Kappa number test.  A high Kappa number
 indicates a greater amount of lignin remaining with the pulp while a low Kappa number
 indicates less lignin remaining with the pulp (i.e., better lignin removal).  Cooking may be
 performed using batch or continuous operation.  The three types of chemical pulping differ
 primarily in the types of chemical solutions and chemical recovery processes used.

 The kraft process uses an alkaline solution of sodium sulfide (Na^) and sodium hydroxide
  (NaOH). Sodium sulfate (Na2SO4) and lime (CaO) are used to replenish the pulping liquor
  as part of the chemical and energy recovery operations associated with the process,   ine
                                          4-4

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                                                             4.0 Description of the Industry
  yield of the kraft process is about 50 percent. Kraft pulp is a dark brown color when it
  leaves the digester and is used in products where strength is a required characteristic (kraft
  is the Swedish and German word for strength).

  The sulfite process uses an acid solution of sulfurous acid (H2SO3) and bisulfite ion (HSCV)
  Die bisulfite may be an ionic salt of calcium, magnesium, sodium, or ammonium   Yield
  from the sulfite process is generally greater than that from the kraft process: however  the
  sulfite process produces a lighter colored and weaker strength pulp.

  Table 4-1 compares distinguishing characteristics of the kraft and sulfite pulp processes and
  kraft and sulfite pulps.

  The soda process, from which the  kraft process evolved, uses an alkaline solution of only
  sodium hydroxide (NaOH).  The  kraft process has virtually  replaced the soda process
  because of the economic benefits of chemical recovery and improved reaction kinetics and
  pulp properties for softwood pulping.

  Modified kraft and sulfite pulping processes are used to manufacture dissolving pulps used
  to produce products such as rayon,  cellophane, cellulose acetate, cellulose nitrate, and
  caxboxymethyl cellulose.  In the modified pulping processes used to manufacture dissolving
 grade pulps chemical solutions and operating conditions are controlled to dissolve not onlv
 ligmn, but also hemicellulose, to  produce a relatively pure and uniform chemical cellulose
 at the expense of greatly decreased yield.
 4.2.3.2
Semi-Chemical Pulping
 Semi-chemical pulping involves processing wood chips in a relatively mild chemical solution
 prior to mechanical refining for fiber separation. The chemical solution is usually a neutral
 sodium sulfite/sodium carbonate liquor which softens and, to a limited extent, dissolves the
 hgnin to promote fiber separation.  For  this  reason, semi-chemical pulp is often called
 neutra1 sulfite semi-chemical (NSSC) pulp.  Other semi-chemical proLses include u ng
 green hquor for pulping, the Permachem  process, and the two-stage vapor process.  The
 yield of semi-chemical pulping depends upon the  specific process used  (the degree of
 cooking), and ranges from 55 to 90 percent.  Semi-chemical pulp can be very stiff which
 makes it particularly useful as the center layer in corrugated container board

 4.2.3.3       Mechanical Pulping •

            pulping involves separating wood fibers by mechanical means.  Mechanical
™ h -•T'S88?       J  '1}  St°ne groundwood> 2) refiner mechanical, 3)  thermo-
mechamcal, 4) chemi-mechamcal, and 5) chemi-thermo-mechanical. Pulp yields are high
up to 95 percent; however, energy requirements are significant. The pulp manufactured is

                                        4-5

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                                                          4.0 Description of the Industry
a low grade used principally for newsprint and other products where
important factor.  To increase sheet strength, chemical pulp is ofter
pTfo^aper production.  Since lignin is not removed, mechanical pulping gener
in moderately colored pulps that discolor with exposure to hght.

Stone groundwood pulp is produced by forcing  logs against a stone grindstone.using
mechaSressure Hbers Ltd fiber fragments are torn from the wood and washed away
!SrSSr Refiner mechanical pulp is produced by passing wood chips between pair of
           -- steel plates called refiners where the fibers are mechanically separated
                ie frayed which results in better interfiber bonding, but are not chopped
             dy as in the stone grinding process. Consequently, refiner mechanic^.pulp is
             stone groundwood pulp, and more suitable for certain uses where strength is
 an important factor.

 Thermo-mechanical pulp is produced by preheating wood chips with steam prior to refining
 ^double d'sc^fine^s. The steam softens the chips, allowing separation of nearly intact
 fibers as opposed to chopped and frayed fibers produced by the stone groundwood and
 SeVlcS^
 sroundwood or refiner mechanical pulps; consequently, less chemical pulp is requiredto
 STadequate sheet strength. The softened chips also  require less energy for refining
 than chips that are not preheated.





  90 perceS  and the resulting  pulp is also stronger than refiner  mechanical pulp.  Chemi-
  meScalM>ing differs from semi-chemical pulping in that the chemicals ^ operating
  conditions of chemi-mechanical pulping are intended to soften rather than to digest ana
  dissolve lignin. Semi-chemical pulping is discussed in Section 4.2.3.2.

  Chemi-thermo-mechanical pulp is produced by pretreating wood chips with caustic soda
  solution at elevated temperate  and ambient pressure.  The chemicals and steam soften
  and sweUThe chips, allowing  separation of nearly  intact  fibers  with minimum energy
  Squiremente forMechanical refining.  The resulting pulp is stronger than other mechanical
  pulps and requires less chemical pulp added to achieve adequate sheet strength.

  4.2.3.4        Secondnry Fiber Processing

  Secondary fiber processing includes all operations performed to repulp secondary fiber and
  to rem^e  coSnants  Common contaminants include ink, adhesives and coa ings,
  polystyrene foam, dense plastic chips, plastic films (polyethyiene), wet strength resins, latex,

                                          4-6

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                                                            4.0 Description of the Industry
 pressure sensitives, waxes, asphalt, and vegetable and synthetic fibers (1).  The types of
 secondary fiber processing operations performed depend upon the grade of waste paper or
 paperboard processed and the desired final product.  For example, envelope trimmings or
 broke purchased from another mill may require simple repulping and minimal contaminant
 removal.   This high-grade  secondary  fiber is used in place of virgin market pulp to
 manufacture a variety of products. Recycled post-consumer newspaper, on the other hand,
 may  require extensive  contaminant removal,  including  deinMng, prior to  reuse in
 manufacturing newsprint.

 Common to all secondary fiber processing is a continuous pulper with a ragger and junker.
 The pulper  includes a rotor or impellers  to disperse  the  secondary  fiber.  Elevated
 temperatures may be used to facilitate defibering. The ragger, initially a wire, is rotated in
 the  stock and continuously withdrawn to remove  strings,  wires, and  rags.   Heavy
 contaminants are removed by centrifugal force to a junk removal system (the junker) located
 at one side of the pulper.  A flotation purge system may also be used to remove light
 contaminants that are not removed in the junker (1).  Chemicals commonly used to aid the
 repulping process include caustic soda, soda ash, and sodium silicate.

 Deinking is performed when ink is considered to be a contaminant. The deinking process
 uses surfactants and heat  to remove ink particles from fiber, disperse them in an aqueous
 medium, and prevent redeposition onto the fibers. Continuous solvent extraction processes
 have been used to recover fiber from paper and board treated or coated with plastics or
 waxes (2).  Surfactants, including detergents and dispersants, are typically added directly to
 the pulper.  The ink particles are then removed from the stock using washing and/or
 flotation.  Washing commonly consists of a series of stages using screens and thickeners.
 The finely dispersed ink particles and other fines are removed through the screens which
 retain the fiber stock, or are  removed with water in thickeners. In the flotation process, air
 bubbles are blended in the stock suspension.  Ink particles collect on the air bubbles and
 rise to the surface of the flotation cell where they are removed as  a layer of froth (1).

 4.2.4  Chemical Recovery Processes

 Recovery, reconstitution, and reuse of spent cooking liquor to produce fresh cooking liquor
 is  necessary for viable  economic operation of most chemical pulp mills.  This  section
 describes the liquor burning  and chemical recovery processes operated at kraft, sulfite, and
 semi-chemical pulp mills.

At kraft mills, weak black liquor recovered from pulp washing, screening, and knotting is
concentrated in multi-stage evaporators.  The concentrated weak black liquor is burned in
a recovery boiler to generate energy from combustion of organic constituents in the liquor,
leaving a molten smelt consisting of sodium sulfide (NajS) and sodium carbonate (NajCC^).
The smelt is dissolved in water to form green liquor.  The green liquor is causticized with

                                        4-7

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                                                           4.0 Description of the Industry
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.

Chemical recovery is also performed at sulfite mills that use magnesium salts.  Spent red
pulping liquor is concentrated in multi-stage evaporators, then burned in a recovery boiler
to generate energy, magnesium oxide (MgO)  ash, and sulfur dioxide (SO2)  gas.  The
magnesium  oxide ash is slaked to form magnesium hydroxide.  The sulfur dioxide gas is
stripped from the flue gas in a gas/liquid contactor to generate acid, which is reacted with
magnesium hydroxide from the slaking of magnesium oxide to regenerate the cooking liquor.

At sulfite mills that use sodium salts, weak liquor is concentrated in multi-stage evaporators.
The concentrated liquor is burned in a recovery boiler to generate energy from combustion
of organic constituents in the liquor, leaving  a molten smelt consisting of sodium sulfide
(NajS)  and  sodium carbonate  (Na^COs).   The smelt  is similar to that  generated from
burning kraft black liquor except'that the sulfidity of the smelt and the sulfur dioxide
content in the flue  gas are significantly greater. The smelt is dissolved in water to form
green liquor. The smelt chemicals are then regenerated into cooking liquor using either the
Sivola-Lurgi, TampeUa, Stora, Mead, or Rayonier processes (1).

At sulfite mills that use calcium salts, spent  pulping liquor is burned to recover energy;
however, chemical  recovery is  not possible because of the generation of  calcium sulfate
(CaSO4)'during liquor combustion.  At sulfite mills that use ammonium salts, energy and
sulfur  are recovered; however, pulping liquor cannot be recovered because ammonium
combustion generates elemental nitrogen  and water (1).

At semi-chemical mills that also manufacture chemical pulp, spent cooking liquor from semi--
chemical pulping is recovered in the kraft or sulfite chemical recovery system  (i.e., cross-
recovery).   At semi-chemical mills  that do not manufacture chemical pulp, fluidized bed
incineration is the most common method used for spent liquor disposal. Pulping liquor may
be recovered by adding solid products from  fluidized  bed incineration to a conventional
recovery furnace for reduction, similar to  the kraft recovery process (1).

At non-wood chemical pulp mills, spent pulping liquor may be evaporated and sold to nulls
with excess  recovery boiler capacity, evaporated and burned in an on-site combustion device,
 or simply discharged to wastewater  treatment.   Non-wood  spent liquor handling and
 recovery processes differ from traditional processes because  relatively small amounts of
 liquor are generated, and the liquor contains less organic constituents that could be burned
 for energy recovery (non-wood furnishes  generally contain less lignin and extractives than
 wood furnishes).
                                         4-8

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                                                             4.0 Description of the Industry
 4.2.5  Pulp Processing

 Pulp processing is performed after pulping and prior to bleaching (if performed) or stock
 preparation.  The primary pulp processing operations include defibering, deknotting, brown
 stock washing, pulp screening, and centrifugal cleaning. Defibering, if used, is performed
 immediately  after chemical and semi-chemical pulping to completely separate the fibers,
 typically using disk refiners. Deknotting removes knots and uncooked chips (rejects) prior
 to brown stock washing, although some mills wash the pulp prior to deknotting.  Rejects
 include material that does not pass through a 1-cm perforated plate.  The knots and rejects
 are either disposed of as waste or recycled for repulping. Large amounts of rejects indicate
 poor cooking uniformity or poor chip uniformity.

 Residual spent cooking liquor is washed from the pulp using brown stock washers. Efficient
 washing is  critical to maximize return of cooking liquor to  chemical recovery  and to
 minimize carryover of cooking liquor (known as brown stock washing loss) into the bleach
 plant, because excess cooking liquor increases consumption of bleaching chemicals.  A
 variety  of  brown  stock washing technologies are used;  however, the most common
 technology  is a series of two to  four rotary vacuum washers. In each washing stage, wash
 water is applied to displace  cooking liquor hi the pulp; countercurrent washing is generally
 used to reduce  fresh water requirements.  Other washing technologies include diffusion
 washers, rotary pressure washers, horizontal belt filters, wash presses, and dilution/extraction
 washers.

 Pulp screening  removes remaining oversized  particles.  The  pulp  is 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 other pulping operations and ultimately enters the
 chemical recovery system.

 Centrifugal  cleaning (also known as liquid cyclone, hydrocyclone, or centricleaning) is used
 to remove relatively dense  contaminants  such  as sand and dirt.  Fiber stock enters the
 cleaner tangentially and rotates within the cleaner.   Centrifugal force and fluid shear
generated from fluid rotation cause the more dense contaminants to concentrate  at the
bottom of the cleaner where  they are removed, while the cleaned pulp exits through the top
of the cleaner.  A series of centrifugal cleaners of various diameters are used to remove a
variety of contaminants of different densities (1).
                                        4-9

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                                                           4.0 Description of the Industry
42.6  Bleaching

In the November 16,  1990 follow-up  letter to  the  1990 questionnaire issued by EPA,
bleaching was defined as any process that chemically alters pulp to increase its brightness.
Bleachml may be performed to simply brighten pulp, to provide "touch-up" bleachmgto
colored internal broke and other sources, or to completely remove lignrn in a raditional
bleaching process, resulting  in bright, white pulp.  VirtuaUy any type of pulp ca*L be
b eached* including chemical, semi-chemical, and mechanical pulps, as well as secondary
fiber; however, only chemical pulps are  fully bleached.  Tie type(s) of fib« *F"
pulp ng processes used, as well as the desired qualities and end use of the final^product
greatly alfect the type and degree of pulp bleaching required  For example, sulfite pulps
and hardwood kraft pulps have a lower lignin content and are therefore more  easily
bleached to a high brightness than softwood kraft pulps.
 42.6.1
Chemical Pulps
 The vast majority of bleached chemical pulps are bleached in traditional bleach plants (see
 Fieure 4-3)  The bleach plant consists of multiple alternating stages of chemical bleaching
 and washing with water. The number of stages typically ranges from two to six, depending
 upon the brightness of the unbleached pulp, the desired final pulp brightness and bleach
 plant design and operation.  The purpose of the initial bleaching stages is to dissolve and
 remove as much ligMn as possible, while the purpose of latter bleaching stages is  c.decolor
 any remaining lignin. Typically, bleaching stages alternate acid and alkahne conditions.  The
 acid stages generally perform "bleaching" where chemical reasons with lignin occur.  The
 alkaline stages generally perform "extraction" where lignin reaction products are dissolved.
 The washing stages remove the active bleaching chemicals and dissolved reaction products.

 Critical to selection and application of bleaching chemicals  and the bleaching chemical
 sequence is the reactivity and selectivity of the chemical with lignin.  Pulp yield loss> due»to
 bleaching chemical reaction with cellulose and hemicellulose is typically 4 to 8 percent, bu
 may be as high as 12 or 18 percent for dissolving grade pulps where further bleaching is
 performed to purify the cellulose.

 The most common bleaching chemicals used are elemental chlorine, chlorine  dioxide,
 sodium hydroxide, sodium or calcium hypochlorite, hydrogen peroxide, and oxygen. Table
 4-2 lists chemicals used and their abbreviations. These chemical abbreviations are used to
 represent  the  bleaching sequence.   An example of a five-stage bleaching sequence is
 represented by C/DE0DED.  This sequence includes first-stage bleaching with elemental
 chlorine and chlorine dioxide, second-stage extraction with sodium hydroxide enhanced with
 oxygen, third-stage, bleaching with chlorine dioxide, fourth-stage extraction with  sodium
  hydroxide, and fifth-stage bleaching with chlorine dioxide.
                                          4-10

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                                                             4.0 Description of the Industry
 4.2.6.2       Semi-Chemical Pulps

 Semi-chemical  pulps  are  typically bleached with hydrogen peroxide in a bleach tower.
 Bleaching with one or two stages of peroxide does  not solubilize as much lignin  as is
 dissolved using a typical four- or five-stage bleaching process, but it increases the  pulp
 brightness and retains the higher pulp yield.

 4.2.6.3       Mechanical Pulps

 Mechanical pulps are bleached or brightened with peroxide and/or sodium hydrosulfite.
 Bleaching chemicals are applie'd using either in-line bleaching (i.e., bleaching performed
 without use of separate bleaching equipment)  or bleaching in bleach towers.  Mechanical
 pulp bleaching brightens pulp using selective bleaching agents that destroy at least a portion
 of the chromophoric, or colored compounds, without significantly reacting with or removing
 lignin.  Full bleaching of mechanical pulps is generally not practical because of the bleaching
 chemical cost and the negative impact on pulp yield.

 4.2.6.4       Secondary Fiber

 Deinked  secondary fiber is generally bleached with sodium or calcium hypochlorite or
 elemental chlorine in bleach towers.  Bleaching chemicals may also be added directly to the
 pulper. Mills that manufacture newsprint from deinked secondary fiber generally bleach
 with sodium hydrosulfite in bleach towers.

 Non-deinked secondary fiber is generally bleached to remove dye from the fiber furnish, as
 required.  Bleaching generally involves adding sodium or calcium hypochlorite directly to
 the pulper, although some mills may apply hypochlorite in bleach towers or to the pulp
 storage chest.

 4.2.6.5       Non-Chemical Non-Wood Pulps

 Mills that pulp cotton linters using non-chemical means generally bleach pulp by adding
 sodium or calcium 'hypochlorite directly to the pulper or brown stock washer.

 4.2.7  Stock Preparation

 Stock preparation processes include pulp mixing and dispersion, beating and refining,  and
 addition of wet additives. Minimal or no stock preparation is performed for market'pulp
production.

The first step in stock preparation is the dispersion of pulp in water (repulping). Purchased
pulp, broke, and/or pulp from high density storage is slurried.and defibered using fiberizers,

                                        4-11

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                                                           4.0 Description of the Industry
deflakers, or dispergers to completely disperse all of the fibers (1). Many mills blend pulp
from several sources to manufacture specific products. For example, fine papers may be
manufactured from a blend of hardwood and  softwood chemical pulp and  non-deink
secondary fiber produced on site and purchased  cotton linter pulp.

Prior to paper or paperboard making, the pulp must be further processed to obtain desired
qualities in the finished products, such as proper surface, opacity, strength, and feel. Fulp
stock is prepared for formation into paper by mechanical treatments, called beating and
refining. Generally, beating and refining make the finished product stronger, more uniform,
more dense, more opaque, and less porous.

Most paper manufactured is sized to resist penetration  of liquids, either internally as the
paper is being made on the machine, or externally after the paper sheet is formed.  Rosin,
rosin size, emulsified waxes, fortified sizes, bituminous emulsions, latex, and silicones are
examples of internal paper sizes  commonly used.   Paper sizing is usually applied with
various precipitants, including alum, sodium aluminate, and others, in specific proportions
to impart the desired degree of sizing.

Wet strength resins can be added for making papers that must retain considerable strength
when wet, such as paper towels.
                                                                 i
Fillers are added to most papers to improve texture, print quality, opacity, brightness, and
to affect certain physical properties, such as pore size for filterability, porosity, burning rate
(for cigarette paper), and formability.   Fillers  commonly include clays, silicas, talc, and
certain inorganic chemicals such as calcium sulfate, barium sulfate, zinc sulfide, and titanium
dioxide, which is also used as an optical brightener.

 Many papers are colored by  the addition of inorganic and organic synthetic dyes and
 pigments. For most products,  dyes and pigments are added before the paper is formed.

 4.2.8   Pulp, Paper, and Paperboard Making

 Paper and  paperboard making consist  of "wet end" operations, including sheet formation
 (using  either a Fourdrinier, twin wire, or cylinder machine process) and pressing, and dry
 end" operations, including drying, calendering, reeling, winding, and application of surface
 treatments  Paper and paperboard making differ  primarily in the thickness of the sheet
 formed  Wet end operations for pulp manufactured for use off site are similar to those for
 paper and paperboard making; however, little or no additives are used.  Dry end operations
 consist only of pulp drying and on-machine slitting and sheet cutting operations.

 Figure 4-2 is a schematic of the components of the Fourdrinier paper machine, the most
 commonly used system. The flowspreader distributes the fibers uniformly across the width

                                         4-12

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                                                             4.0 Description of the Industry
 of the headbox.  The headbox deposits the fiber slurry onto a thin moving wire mesh belt
 through which excess water drains. Suction from a series of hydrofoils, vacuum boxes, and
 vacuum rolls further dewaters the formed sheet as it moves from the headbox towards the
 press section.  In a twin wire system, the fiber  is deposited  into the gap between two
 converging wires. Excess water drains through the wire mesh as in the Fourdrinier process;
 however, additional dewatering via suction can be performed from both sides of the sheet.
 Excess water, containing valuable  entrained  fiber,  is captured  and recycled to  the
 flowspreader after a series of thickening and cleaning steps (1).

 From the wire, the formed sheet enters the press section where it passes through a series
 of presses to remove additional water and compact the fibers more closely together.  The
 sheet then enters the dryer section where remaining water is evaporated via steam-heated
 rollers and the fibers begin to bond together.  In the calender section, the sheet is pressed
 between heavy rolls to reduce paper thickness and provide a smooth surface.  Finally, the
 paper is wound onto a reel for intermediate storage. On- or off-machine rewinding is then
 performed to cut and wind the full-size reels into smaller, more manageable rolls. The rolls
 are then wrapped and are ready for distribution (1).

 Bleached kraft market pulp is currently defined as kraft pulp having a brightness between
 88 and 90 ISO.  Market pulp production uses the process described above, but the final
 dried pulp product is rolled  or slit and  cut  on-machine  to produce baled pulp sheets.
 Market pulp may also be dried using either of the air float or flash drying processes. In the,
 air float process,  the pressed pulp  sheet passes through a chamber where hot air dries the
 suspended sheet,  'in the flash drying process, the pressed pulp is "fluffed" and injected into
 a series of drying towers. Hot gases in the towers vaporize moisture in the pulp. The dried
 pulp is then compressed and formed into  bales (1).  If market pulp customers are located
 nearby, it may be more economical to transfer wet pulp (referred to as wet lap or slush
 pulp) rather  than dried pulp.

 Paper finishing, if used, includes  adding surface treatments, such as external sizing or
 coating, and super calendering. External surface sizing involves applying starch particles to
 fill the surface voids in the sheet.  The starch reduces the pore radius and thus the rate of
 liquid penetration into the paper.  Surface sizing is generally applied on-machine in a size
 press or in the calender stack. Coatings are applied to provide various surface qualities,
 such as improved gloss, slickness, color, printing detail, and brilliance. Lighter coatings are
 generally applied on-machine, while heavy coatings are generally performed off-machine.
 Super calendering, performed off-machine, consists of running the paper sheet through a
vertical stack of hard and soft rolls, providing a smooth, glazed appearance for high-quality
printing papers.
                                        4-13

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                                                           4.0  Description of the Industry
4.3   Manufacturing Processes Profile

This section provides a statistical profile of the manufacturing processes used in the pulp
and paper industry based upon U.S. industry responses to the "1990 National Census of
Pulp  Paper, and Paperboard Manufacturing Facilities" (the 1990 questionnaire)  Industry
characteristics have changed slightly since that time, as reflected in Sections 80 and 11.0
The following information is  profiled:   the types and  amounts of fiber furnish and
preparation and handling; types and amounts of pulp manufactured and pulping equipment
used- chemical recovery processes used; pulp processing performed, including brown stock
washing operations; bleaching  processes used and application of bleaching processes to
different types of pulps; and types and amounts of final products manufactured.

Responses to the  1990 questionnaire from 565 mills were evaluated.  This total includes
mills that were in operation in 1989, minus  a few that  have subsequently gone out olj
business, and also includes one mill that began operation after 1989, the year upon which
the  1990  questionnaire  is  based.   In  some  cases,  mills  did  not provide  complete
questionnaire responses, primarily because manufacturing operations  only began in 1989.
Therefore the number of responses  received and analyzed for different portions  of the
questionnaire varies. Selected questionnaire information for different types of mills were
entered into a questionnaire database.  The information presented in this section is based
upon interpretation of this database.

4.3.1  General Overview of the Industry

 Included in Table 4-3 and illustrated in Figure 4-4 is a geographic profile, by state  of the
 565 mills included hi EPA's analysis. As expected, the greatest density of mills  is located
 in regions of the country that either provide significant growth of trees or provide significant
 industry and human population for economic collection and recycling of secondary fiber.
 Also included in Table 4-3 and iUustrated in Figures 4-5 through 4-8 are geographic profiles,
 by state, of the following types  of mills:

        •     Figure 4-5: Mills that manufacture chemical pulp (bleached and unbleached);

        •     Figure 4-6:  Mills that bleach chemical pulp;

        •     Figure 4-7: Mills that process secondary fiber (with or without deinking); and

        •     Figure 4-8:  Mills that deink secondary fiber.

 Figure 4-9 compares the number of mills performing each of the processes shown in Figures
 4-5 through 4-8.
                                         4-14

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                                                            4.0 Description of the Industry
 The number of mills using each process is summarized below, and is also expressed as a
 percentage of the total number of mills included in EPA's analysis.
Type of Process
Chemical Pulping(a)
Bleaching of Chemical Pulp(a)
Processing of Secondary Fiber(b)
Deinking of Secondary Fiber
Number of Mills
Performing Process ;
154
110
378
43
Percent of Total
Number of Mills
27
19
67
8
 (a)Includes both wood and non-wood fiber.
 (b)Includes processes with and without deinking.

 4.3.2  Fiber Furnish and Fiber Furnish Preparation and Handling

 4.3.2.1       Fiber Furnish Use and Pulping Operations

 The table below presents the number of mills that reported using various fiber furnishes.
 Many mills use  multiple types of fiber furnishes as demonstrated by the number of mills
 reporting use of each type.
                  Furnish
No. of Mills Using Furnish
  Wood
       Logs
       Chips
       Purchased Pulp
       Waste Wood (Sawdust)
            144
            140
            249
            78
  Secondary Fiber
           386
  Other
                                                              57
Table 4-4 presents the distribution of fiber furnish by mill type.   This information was
reported in  Question 7 of the  1990 questionnaire ("What percentage of the total fiber
furnish as received on site in calendar year 1989 is represented by each raw material given
below?").
                                       4-15

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                                                           4.0  Description of the Industry
The table below presents the number of mills that reported using different types of non-
wood fiber furnish. Many mills that process secondary fiber also use one or more of the
fiber  types listed.  Twenty-two mills reported using synthetic and inorganic materials;
however, these types of fiber furnish are generally used in relatively small quantities  In
contrast, mills that reported using cotton linters and rags generally used relatively large
quantities of these furnishes.
                   Furnish Ttype  .
     Synthetic and Inorganic Materials
     (Fiberglass, Ceramic, Asbestos, Glass,
     Rayon, Aramid, Polyester, Polypropylene)
      Cotton Linters
      Rags
      Flax
      Tobacco
      Hemp
      Bagasse
No.
Reporting Use
                                                                 22
                                                                 16
 Table 4-5 presents the number of mills that reported using different types of fiber furnish
 to manufacture different types of .pulp.  Many mills manufacture multiple types of pulps.
 The  percentage,  indicated in the  table  represents  the percentage  of all  mills that
 manufacture each type of pulp that use a particular furnish; it is not a production- or mass-
 weighted percentage  of total pulp production.  For example, although one-third of the
 dissolving kraft mills  in the U.S. (i.e., one  of the  three mills) manufactures  pulp from
 hardwood only, this mill may not necessarily manufacture one-third of all dissolving kraft
 pulp. The following observations can be made from the information presented in the table:

        (1)    Where only softwood or hardwood are chemically pulped,  more mills pulp
              softwood than pulp hardwood, although most papergrade kraft mills pulp both
              hardwood and softwood;

        (2)    Soda pulping of softwood is not performed, although the soda process is still
              used for pulping hardwood and non-wood furnishes;

        (3)    Most semi-chemical mills pulp only hardwood; and
                                         4-16

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                                                            4.0 Description of the Industry
        (4)    The majority of mechanical pulp mills pulp only softwood, with the exception
              of stone groundwood mills where more mills pulp only hardwood.

 Table 4-6 lists the number of mills that reported processing different types of secondary
 fiber. Most mills that process secondary  fiber reported processing more than one type of
 secondary fiber.  The type of secondary fiber furnish processed by the largest number of
 mills is old corrugated  containers (OCC).  Other commonly processed secondary fiber
 furnishes are newsprint, mixed and super mixed paper, new corrugated cuttings, bleached
 kraft, and ledger grades.
 4.3.2.2
 Fiber Furnish Preparation and Handling
 Table 4-7 presents the percentage of mills manufacturing bleached chemical wood pulp that
 perform various types of wood preparation and handling operations  (106 mills).  Data
 concerning wood preparation and handling operations at other mills (93 unbleached kraft
 semi-chemical, and mechanical pulp mills) were not entered into the questionnaire database
 and are therefore not included in this summary.  As shown in this table, a significant
 number of mills continue to use wet wood preparation and handling operations, including
 log ponds, log flumes, log washing, wet debarking, and chip washing.

 4.3.3  Pulping Processes

 Table 4-8 lists the number of mills that perform different pulping processes.  Many mills
 perform multiple pulping processes at the same site. The two pulping processes performed
 by the greatest number  of mills are non-deink secondary fiber processing (pulping) and
 papergrade kraft (chemical pulping).
4.3.3.1
Chemical Pulping
All kraft and soda mills use sodium-based pulping chemicals.  As described in Section
4.2.3.1, sulfite mills use acid solutions of sulfurous acid and one of four bisulfite salts. As
shown in the table below, all four sulfite chemicals are used by U.S. mills that manufacture
papergrade sulfite wood pulp. One mill reported using both sodium-based and calcium-
based pulping chemicals for sulfite pulping.  Three of the five dissolving sulfite mills also
reported manufacturing papergrade sulfite pulp.  All non-wood sulfite pulp (tobacco and
hemp) is manufactured using the sodium-based sulfite process.
                                       4-17

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                                                          4.0 Description of the Industry
-=^s=
Pulping Process
Papergrade Wood
Sulfite
Papergrade Non-
wood Sulfite
Dissolving Sulfite
	 	 f .^ ^vAj-l&v a •. '*&*&*& sW ^ VLT. •*, vf <•
,- ^ , ;X^'N«miberk Mills _
Sodium-
Based
1
3
0
- «",,(£•'*&•
CaleiamrBas
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                                                             4.0 Description of the Industry
 4.3.3.4
Secondary Fiber Processing
 An industry profile of the types of secondary fiber processing performed is included in
 Section 4.3.2.1.

 4.3.4  Chemical Recovery Processes

 Recovery  boilers  are one of the  most  expensive pieces  of equipment  at  a mill
 Approximately one-third of the recovery boilers currently in operation were reported to be
 over  25 years old; approximately half of these were reported to be over 35 years old.
 Recovery boilers are frequently upgraded or modified throughout their operating life so the
 installation date may not be an accurate indication of the age and condition of the boiler.

 If a mill increases  its  pulp production, there is a proportional increase in the amount of
 organic solids that  are incinerated in the recovery boiler.  A mill may require additional
 recovery boiler burning capacity if it increases the organic load on the boiler above a certain
 level, and, therefore,  the mill's production level may be limited by the  current burning
 capacity of the recovery boiler. The cost of replacing a recovery boiler with one of greater
 capacity is economically unattractive for most mills; however,  methods are available to
 increase recovery boiler capacity through lower cost upgrades, as discussed in Section 8.2.8.
 The 1990 questionnaire asked mills to list their h'miting process in terms of pulp and paper
 production.  Of 94 chemical pulp mills that pulp and subsequently bleach  wood that
 responded to  Question 21  of the 1990 questionnaire  ("Indicate what unit process or
 processes is the current limiting process . . ."), 45 indicated that recovery boiler capacity is
 their limiting process.  Many of these mills could use one or more of the boiler upgrades
 discussed in Section 8.2.8 to increase recovery boiler capacity if they want to increase pulp
 and paper production.  Alternatively, integrated mills may increase overall pulp production
 by adding secondary fiber to their  operations.

 4.3.5  Pulp Processing

 Brown stock washing  is the only  pulp processing  operation for which information was
 collected in the 1990 questionnaire. On average, the number of brown stock washing stages
 operated at mills that manufacture bleached chemical wood pulp is between 3  and 4.
Although the number  of brown stock washing stages operated is not  a direct measure of
washing efficiency, lower amounts of pulping liquor are generally carried over to subsequent
operations at mills that operate more brown stock washing stages. The average brown stock
washing losses for papergrade and dissolving kraft mills are approximately 13.5 and 24.2 kg
Na2SO4/ADMT of pulp, respectively, as reported in the 1990 questionnaire.
                                        4-19

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                                                            4.0 Description of the Industry
4.3.6   Bleaching

As explained in Section 4.2.6, bleaching is any process that chemically alters pulp to increase
its brightness.  It should be noted that the number of mills that bleach mechanical pulp and
secondary fiber, particularly using in-line bleaching, is likely under-reported in the following
sections because the 1990 questionnaire was designed to gather information concerning
operations at traditional bleach plants, and because the Agency's definition of bleaching was
clarified in a follow-up letter to the questionnaire that may not have been received in time
for mills to revise their responses.

4.3.6.1       Chemical Pulp

       Traditional Bleaching

A  total  of 104 mills bleached chemical wood  pulp  in traditional bleach  plants as of
January 1,1993. The table below summarizes the types of chemical pulps bleached at these
mills.
                             MillT^pe
   Papergrade Kraft only
   Papergrade Sulfite only
   Dissolving and Papergrade Kraft
   Dissolving and Papergrade Sulfite
   Dissolving Sulfite only
   Papergrade Soda only
   Papergrade Kraft and Papergrade Sulfite
   Total
^ ^^ f \ \
\








Number of Mills
84
9
3
3
2
2
1
104
 These mills reported operation of approximately 176 physical bleach hues (i.e., unique
 bleaching equipment lines).  Most of these lines bleach only one type of fiber furnish:
 hardwood  softwood, or a blend of hardwood and softwood.  The remaining bleach lines
 (approximately 16 percent) switch between bleaching hardwood, softwood, or a blend; these;
 bleach lines are referred to as "swing lines."
                                          4-20

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                                                             4.0 Description of the Industry
 The table below summarizes the approximate percentage of physical bleach lines bleaching
 each type of fiber furnish.
Fiber Furnish
Hardwood only
Softwood only
Hardwood/softwood blend only
Multiple fiber furnishes
Percentage of Lines
33%
42%
9%
16%
 Typically, a mill that manufactures and bleaches both hardwood and softwood pulp will
 operate separate pulping, washing, and bleaching lines for hardwood and softwood. This
 allows the mill the flexibility to manufacture final products consisting of different blends of
 fiber furnish.

 Several mills operate physical bleach lines that swing by varying operating conditions rather
 than varying  fiber furnish.   These  bleach  lines are  referred to in this document  as
 "operational  swing lines."   The operating parameters for these swing lines, including
 chemical addition rates, number of bleaching stages, and process control parameters, such
 as temperature and product quality targets, may vary to produce specific products or product
 grades. Some mills use up to eight different modes of operation on a single fiber furnish
 on a single physical bleach line.  Approximately seven percent  of bleach lines are operated
 as operational swing lines.  Most of these lines are at dissolving pulp mills that produce a
 wide variety of pulp grades to meet their customers' needs.

 Four- and five-stage bleach lines are most common at kraft pulp mills, although three or six
 stages are frequently used. None of the bleach lines have more than six bleaching stages,
 and  one- or two-stage bleach sequences are seldom used.                              '

 Table  4-9 presents the approximate percentage of papergrade kraft and soda, dissolving
 kraft, and papergrade and dissolving sulfite mills that use each bleaching chemical in at least
 one  bleaching stage for at  least one  mode  of operation, as  reported in the  1990
 questionnaire.  The most commonly used bleaching chemicals were reported to be sodium
hydroxide, elemental chlorine, chlorine dioxide, hypochlorite, and oxygen.  Chlorine dioxide
and  oxygen use is much more prevalent at papergrade  kraft and soda mills than at sulfite
mills, while hypochlorite use is much more prevalent at papergrade and dissolving sulfite
and  dissolving kraft mills than at papergrade kraft and soda mills,
                                        4-21

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                                                           4.0 Description of the Industry
Oxygen is used in both oxygen delignification and oxygen-enhanced extraction.  Sections
8.2.5 and 8.3.6 discuss these technologies.

Chorine dioxide is often partially or completely substituted for elemental chlorine in the first
chlorination stage.  Chlorine dioxide may be added before, after, or simultaneously with
elemental chlorine; simultaneous addition is the most common.  The  degree of chlorine
dioxide substitution for elemental chlorine is calculated as a percentage using the following
formula:
  Percent Substitution  =
                                  2.63 (C102 in kg/ADMT)
2.63 (C102 in kg/ADMT) + (C12 in kg/ADMT)
                                                 (1)
where 2.63 equals the equivalent oxidizing power of chlorine compared to chlorine dioxide
(see Section 8.3.5).

Most mills reported using chlorine dioxide substitution of up to 10 percent to minimize
degradation of the cellulose and to achieve higher final brightness, better brightness stability,
and reduced effluent color (1).  As of 1989, approximately one-third of chemical wood pulp
was bleached at chlorine dioxide substitution rates of greater than 10 percent.  Section 8.3.5
discusses the environmental benefits of increased chlorine dkndde substitution for elemental
chlorine.

For papergrade pulps,  an important measure of bleached pulp quality is final pulp
brightness  Several methods are used  to measure pulp brightness;  however, the most
 common method in the  U.S. is GE brightness. ISO brightness is the measure most often
 reported in the technical literature and is commonly used in Scandinavia. A third measure,
 Elrepho, is used in Canada.  As a general rule,  these measures  are related as follows:
 92 GE = 92 5 Elrepho = 90 ISO. Extremely bright pulps have a GE brightness of 90 and
 greater  Low-brightness pulps have a GE brightness of 83 or less.  Unbleached chemical
 pulp has an approximate GE brightness of less than 30.  The table below presents estimates
 of the percentage of bleached chemjcal wood pulp by final GE brightness.
Final GE Brightness
>93
90-92
86-89
83-85
<83
Approximate ISO Brightness Equivalent
>91
88-90
84-87
Estimated Percent ol Putp by Weight
6% •
15%
41%
81-83 1 20%
<81 1 18%
                                            4-22

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                                                            4.0 Description of the Industry
       Non-Traditional Bleaching


 Two  mills bleach chemical  wood  pulp using non-traditional bleaching processes (i.e.,
 bleaching that is not performed in a traditional three- to six-stage bleach plant). One suffite
 mill performs some brown stock pulp brightening by adding sodium hydrosuffite to the paper
 machine.


       Non-Wood Bleaching


 Four chemical pulp mills, one suffite and three kraft, bleach pulp made from furnishes other
 than wood. Bleaching is performed using either traditional bleach plants or using a process
 similar to that used by mills that bleach non-chemical, non-wood pulp described in Section
 4.3.6.5.
4.3.6.2
Semi-Chemical Pulp
Only two mills reported bleaching semi-chemical pulp.  Both mills bleach semi-chemical
pulp by applying peroxide in a bleach tower. One of the mills also adds sodium hydrosulfite
to pulp storage.
4.3.6.3
Mechanical Pulp
Most mechanical pulp mills  bleach pulp in  a single bleach tower by applying sodium
hydrosulfite. A few bleach with peroxide instead of sodium hydrosuffite, or bleach with both
peroxide and sodium hydrosulfite.  Some  mills apply peroxide and/or sodium hydrosuffite
in-line, either in the refiner or the mix tank, without using dedicated bleaching equipment.

The number of mechanical pulp mills that bleach pulp is summarized in the table below,
by mechanical pulping process.
Mechanical Pulping Process
Stone Groundwood
Mechanical Refiner
Thermo-Mechanical
Chemi-Mechanical
Chemi-Thermo-Mechanical
Total Number of
Mills
24
7
27
4
2
Number and; Percent of Total That
Bleach
10 (42%)
1 (14%)
14 (52%)
2 (50%)
0(0%)
                                       4-23

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                                                           4.0 Description of the Industry
The highest percentage of bleaching is performed by thermo-mechanical pulp mills, although
chemi-mechanical and stone groundwood mills also bleach.  Significantly lower percentages
of  mechanical  refiner and  chemi-thermo-mechanical pulp  are bleached.   Overall,
approximately 40 percent  of mechanical pulp mills reported bleaching mechanical pulp;
however since there was confusion by industry concerning the Agency's definition of pulp
bleaching,  the use of bleaching by non-chemical wood pulp mills may have been under-
reported in the questionnaire.
4.3.6.4
Secondary Fibers
A total of 29 mills deink and subsequently bleach secondary fiber. These mills generally
perform bleaching in bleach towers using hypochlorite, although four mills also use chlorine.
Two mills add hypochlorite directly to the pulper rather than in a bleach tower. Sodmm
hydrosuffite is used to bleach deinked secondary fiber used to manufacture newsprint. This
bleaching is also generally performed in bleach towers.  Two mills that bleach groundwood
pulp with sodium hydrosulfite also bleach some deinked secondary fiber in this way.

A very small percentage of mills that process secondary fiber without deinking (nine mills)
reported subsequent bleaching of the secondary fiber. Most of these mills add hypochlorite
directly to the pulper.  Two mills add hypochlorite in a bleach tower or chest, and two mills
add sodium hydrosulfite and/or peroxide in a tower.
 4.3.6.5
Non-Chemical Non-Wood Pulp
 Eight mills that pulp cotton linters by non-chemical means reported bleaching with chlorine
 and/or hypochlorite.  These mills generally add hypochlorite directly to the pulper or brown
 stock washer; however, one mill appears to operate a more traditional bleach plant with
 consecutive, separate stages, including chlorine application. Two of the non-chemical cotton
 linter mills bleach only internal broke.

 4.3.7  Pulp, Paper, and Paperboard Making

 Total final production for the 565 mills included in the Agency's analysis is nearly 84 million
 metric tons per year.  The table below shows the distribution of the total final production:
"' •* v
"type
Pulp
Paper
Total Final Production (%>
(million OMMT/yr)
10.76 (12.9%)
36.01 (43.1%)
                                         4-24

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                                                             4.0 Description of the Industry
-. Type
Paperboard
Not Classified
TOTAL
Total Final Production (%)
(million OMMT/yr)
36.25 (43.4%)
0.59 (0.7%)
83.59 (100%)
 Table 4-10 provides the production distribution by product. The majority of market pulp
 is sold to other U.S. and foreign mills and subsequently used to manufacture paper and
 paperboard.   Therefore,  the  majority  of market pulp production is  also counted  in
 subsequent paper and paperboard production. Nearly 75 percent of market pulp is bleached
 kraft pulp, and approximately 13 percent of market pulp production is dissolving and special
 alpha grade pulp that is subsequently used to manufacture products other than paper and
 paperboard as discussed in Section 4.2.3.1.  Nearly 30 percent of paper production is
 uncoated free sheet used for printing,  writing, and related product. Nearly 50 percent  of
 paperboard production is unbleached kraft packaging and industrial converting paperboard
 used for corrugating medium, folding carbon board, and related products.

 4.4    Trends in the Industry

 In the 1970s, the pulp and paper industry focused on increasing energy efficiency to reduce
 its dependency on petroleum-derived fuels. During the 1980s, the paper industry automated,
 cutting production costs  and improving product quality and consistency at the same time!
 Entering  the 1990s, the  industry is under pressure to recycle more fiber and reduce the
 environmental impact of its effluent (3). The pulp and paper industry has also been affected
 by the economic recession and evolving information technologies. Capital spending during
 1989-1991 resulted in capacity expansions, which, combined with the recession, resulted in
 a decline in operating rates. Regulations to reduce dioxin formation and consumer demands
 for products made from recycled paper have led to non-chlorine bleaching alternatives and
 to the increased use of secondary fibers as furnish for paper and paperboard products. Also,
 as businesses and the public increasingly rely on electronic media for information transfer'
 slower growth in demand is predicted for printing/writing papers and for newsprint.  Trends
 relating to production and products, new mill construction, fiber furnish use, and pulping
 and bleaching technologies are  discussed below.

4.4.1  Trends in Production and Products

The U.S. paper industry began to feel the impact of the economic slowdown from the fourth
quarter of 1990 into 1992  (4).  Reduced advertising expenditures for magazines  and
                                       4-25

-------
                                                          4.0 Description of the Industry
newsoaoers has  resulted in lower demand for printing/ writing papers and newsprint




(5).

4.4.2   Trends in New Mill Construction

A summary of 18 mills that came on-line in the U.S. subsequent to 1988, and their products
^prSS below. This information was compiled from the 1990 questionnaire database
and published articles (6,7,8).
         Market Pulp
             Bleached softwood kraft
             Deinked secondary fiber
         Paper
              Tissue
              Newsprint
              Special Industrial
              Uncoated free-sheet
              Coated
              Bond, ledger, copy
         Paperboard
              Recycled containerboard
              Various paperboard
3
2
4
3
1
1
1
1
 2
 2
  "Some of the new mills produce multiple products and therefore are counted in more than
  one product.

  4.4.3  Trends in Fiber Furnish Use

  Recycled-content mandates, procurement provisions, and recycling goals; will ^e industry
  o improve  technology  to manufacture  products  containing  recycled material^   Old
  newspapers, old corrugated containers, mixed papers, and office papers are adding to
  supples of nigh-grade deinking papers and pulp substitutes. Deinking capacity is expandmg
  rapTdy   Forty-five deinking facilities  were started up in the U.S.  and Canada m  1991,
                                         4-26

-------
                                                            4.0 Description of the Industry
 adding more than three million short tons of recycled fiber capacity.  Most of the tissue
 produced from 1990 to 1993 used deinked wastepaper (9).  The use of secondary fibers as
 furnish has also increased the addition of biocides and wet and dry strength agents.

 Recovered paper usage as a share of total paper and paperboard production jumped to
 approximately 32  percent   in 1992  compared  to  23  percent  in the  mid-1980s  (5).
 Consumption of fiber from recovered paper is growing more than twice as fast as overall
 fiber consumption (10).

 4.4.4  Trends in Pulping

 In response to environmental concerns, pulp and paper mills have implemented advanced
 pulping technologies that provide greater delignification.  The reduced lignin load to the
 bleach plant reduces the need for bleaching chemicals.

 Some of  the pulping technologies that  increase  delignification  include  extended
 delignification during kraft pulping, solvent pulping, and pulping in the presence  of the
 catalyst anthraquinone.  Oxygen delignification is a post-pulping method used to lower the
 lignin content of pulp entering the bleach plant. Adding hydrogen peroxide to an oxygen
 delignification system further reduces the amount of lignin.  In 1992, more than 32 oxygen
 delignification systems started up worldwide, bringing the total number of systems operating
 worldwide to 155 (11).                                                             &

 4.4.5 Trends in Bleaching

 Environmental pressures have pushed mills to consider bleach plant modernization and to
 adopt novel bleaching technologies as alternatives to chlorine bleaching.  It  has  been
 estimated that completely chlorine-free pulps will account for up to 10 percent of the total
 chemical market pulp volume in the year 2000 (12). Bleaching process modifications by the
 industry  include chlorine dioxide substitution for elemental chlorine, enhanced caustic
 extraction with peroxide and  oxygen, hypochlorous acid in the Dl  stage, ozone bleaching,
 and  chlorine injection process modification.  These bleaching strategies have helped to
reduce the environmental impact of bleach plant effluent and are discussed in detail in
Section 8.0 of this document.

4.5   References
1.
Smook, G.A.   Handbook for Pulp and  Paper Technologists.  Joint  Textbook
Committee of the Paper Industry.  TAPPI, Technology Park, Atlanta, Georgia and
CPPA, Montreal, Quebec, Canada, 1982.
                                       4-27

-------
                                                          4.0 Description of the Industry
2     Hamilton,' F. and B. Leopold, eds. Pulp and Paper Manufacture (Third Edition).
      Volume 3 - Secondary Fibers and Non-Wood Pulping. Joint Textbook Committee
      of the  Paper Industry,  TAPPI,  Technology Park, Atlanta, Georgia and CPPA,
      Montreal, Quebec, Canada, 1987.
3.    Advanced Process Technologies Offer Paper Industry Ticket to the Future. Pulp &
      Paper, 66(9):44-45, September 1992.
4.    American Forest & Paper Association, Statistics of Paper, Paperboard & Woodpulp,
       1993.
5.     Mais, W., et. al. Economic Recovery, Overseas Sales Will Pace U.S. Paper Industry
       Growth. 'Pulp & Paper, 67(1)33-47, January 1993.
6.     Espe,  C.  Capital Spending Plans:  1992-94.  Pulp  & Paper, 67(l):75-82, January
       1993.'
7.     Espe,  C.  Capital Spending Plans:  1991-93. Pulp  & Paper, 66(l):89-96, January
       1992.
 8.     Espe,C. Capital Spending Plans: 1990-92. Pulp & Paper, 65(1): 101-108, January
       1991.
 9.     U.S. Paper Industry Will Benefit from Economic Revival This Year.  Pulp & Paper,
       66(1):59, January 1992.
 10    Storat, R.E.  The U.S. Pulp, Paper, and Paperboard Industry:  A Profile. TAPPI
       Journal, 76(3):53-57, March 1993.
 11    Johnson A.P. O2 Delignification Systems Flourish As Mills Push for Lower Kappa
       Levels. Pulp & Paper, 67(3):103-112, March 1993.
 12    Forbes,  D.R.   Mills  Prepare  for  Next Century  with  New Pulping, Bleaching
       Technologies.  Pulp & Paper.  66(9):79-90. September 1992.
                                         4-28

-------
   AU3AOO3U TVOIW3HO
4-29

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                                               I




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4-37

-------
                                         Table 4-1
              Comparison of Kraft and Sulfite Pulping Processes
       Characteristic
Cellulosic Raw Material
Principal Reaction in
Digester
Composition of Cooking
Liquor
                                        Kraft Process
Almost any kind of wood, soft or
hard
Hydrolysis of lignins to alcohols and
acids; mercaptans are formed
 Cooking Conditions
 Chemical Recovery
12.5% solution NaOH, NajS and
Na2CO3
 2-5 hours at 340-350°F and 100-135
 Pulp Characteristics
 Recovery of cooking chemicals, with
 energy recovery from burning
 organic matter dissolved in liquor.
 Chemical losses are replenished
 with salt cake
 Typical Final Papergrade
 Products
 Brown color; difficult to bleach;
 strong fibers; resistant to
 mechanical refining	
 Typical Final Dissolving
 Grade Products
 Strong brown bag and wrapping;
 multiwall bags; gumming paper;
 building paper; white papers from
 bleached kraft; paperboards for
 cartons, containers, and corrugated
 board; tissue
  Cellulose for processing into textile-
  and tire cord-grade rayon; acetate
  plastics
                                                                          Swlfite Process
Any kind of hardwood or
softwood free of certain hydroxy
phenolic compounds	
Sulfonation and solubilization of
lignin with bisulfite; hydrolytic
splitting of cellulose-lignin	
7% by weight SO2, of which 4.5%
is present as sulfurous acid, and
2.5% Ca, Na, NH3, or
Mg(HS03)2	
 6-12 hours at 257-320°F and 90-
 110 psi    	
 SO2 relief gas recovered; MgO
 recovered
 Dull white color; easily bleached;
 iftbers weaker than kraft fibers
 Fine paper; bread wrap; sanitary
 tissue
  Cellulose for processing into
  textile-grade rayon; plastic filler
  cellophane; cellulose acetate;
  cellulose nitrate; carboxymethyl
  cellulose; photographic film
                                               4-38

-------
    Table 4-2
Bleaching Symbols
Bleaching Chemical
Sulfuric Acid
Elemental Chlorine
Chlorine Dioxide
Sodium Hydroxide
Hypochlorite
Sodium Silicate
Monoethanol Amine (Monox-L)
Nitrogen Dioxide
Oxygen
Hydrogen Peroxide
Peracetic Acid
Sulfur Dioxide Gas
Chelating Agents
Urea
Water
Hydrosulfite and
Dithionite
Ozone
Chemical Formula
H2S04
Cla
C102
NaOH
HC10, NaOCl, Ca(OCl)2
NajSiOa
NHzOH^CHjOH
N02
02
H.O,
CH3CO2OH
SO2
DTPA, EDTA
NHjCON^
^0
NajSOj, NaHSOj
Na2S2O4, ZnS2O4
03
Symbol
A
C
D
E
H

M
N
O
P
PA
S
Q
U
W
HS
Z
      4-39

-------
 o>
           V) W Q.
                    i-l O i-l iH CO
                                 O O O i-l CO
                                             O O i-l O O
                                                         O O O CM O
                     O\ O CM CO
                                 i-H \0 CM
                                             O O <=> i-j CM
                                                         CM CM 00 \O CM
 OJ
 a
P*
            I _, a f~.
             *3 W hfi

          ill!
CM i-< •<* CO
               u
          O O O
                      O i-l O O O
                                   O CM "* OO
             I -s _
             •s s&
                                 O i-l O O\
                                             O i-l O O O
                                                          O CM Q 00
                     O\ CM CM OO
                                 i-l O CM
                                              O i-l O CM CM
                                                          CM U1 CO 00 CO

                                  0 -a £

                                  llllf
                                  U U Q E
                                    si a-a a
^
                                                l-H
                             ••I ^
                                     4-40

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ts
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U
"tS 6*4
5 |;l 1
1° IE
I'll
•** . i(-t
g| Je
js J i-i
l«g£
Is a -a
eilf
= f If
s a o ^
W
1
3
£
O CO tS VO O
00 CO OS 0 CO
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
O O O O CO
i-i o o o c<-
r-l O O i-H rt
«-l O O ^4 ft
«H O O CS •*
i-H 1-1
Montana
Nebraska
Nevada
New Hampshire
New Jersey
O CS T-I O CO
^$a°?$
O CO VO O TH
o co r- o cs
iH T— 1 vo O O
<0 T-l CO
ii|l
t§ 8 1 J
55 fc Z fc 0
C^ CS TH O O
VO OO CO O •*
O CO 10 O T}-
r- 1 C~ >O O VO
^O CN r-l O ON
*— 1 CO
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
O r-( O JO i-l
O O\ VO O >O
O CN 
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                       1

s >

'S
u
                        8
                      •2 S
                      -si
                       J
                      ft
                      OH &

                      •31
                       II
                       a a
                       11
                       T3 T3
                       o o
                       II
                       II
                      4-42

-------
                                         Table 4-4
              Total Fiber Furnish Received On Site by Process Type
Furnish T^pe
Logs
Chips
Purchased Pulp
Waste Wood
(Sawdust)
Secondary Fiber ,
Other (Non-wood,
Synthetics, Inorganics)
Average Percent of Total Fiber Furnish Used to Produce Final Prod«ct(a)
All Mills ,
14%
10%
24%
5%
44%
3%
Chemical
Pulp Mi«s(b)
43%
30%
8%
11%
3%
5%
Na»"
Chemical
Pulp mils($
3%
2%
30%
3%
59%
,3%
Semi-
Chemical
Pulp
MilfeKd)
27%
28%
3%
19%
22%
<1%
Beink
Secondary Pulp
MttlsCe)
2%
4%
15%
2%
76%
<1%
(a)Simple average of percent of total fiber furnish use reported by each applicable mill (from Question 7 1990
   questionnaire).                                                                         '
(b)Data from mills that manufacture any chemical pulp (wood or non-wood).
(c)Data from mills that do not manufacture any chemical pulp.
(d)Data from mills that manufacture any semi-chemical pulp.
(e)Data from mills that deink any secondary fiber.
                                           4-43

-------
        en
        V)
 O)

I
        O)
        (A
(A
O)
        OJ
        I
                                                              §
                                                                      1
                                                                      •a-
                                                                       •3
                                                      4-44

-------
                    Table 4-6
Number of Mills by Specific Secondary Fiber Furnish
API(a) Paper Recycling
Committee Code
1103
1105
1209
1226
1244
1311
1314
1421
1443
1446
1447
1 Code Description
Mixed paper
Super mixed paper
Boxcoated cuttings
Mill wrappers
Printed TMP
News, printed
News, imprinted
Groundwood computer printout
Publication blanks
Mixed groundwood shavings
Flyleaf shavings
Coated groundwood sections
Corrugated, old boxes
Corrugated, new cuttings
Used brown kraft bags
Mixed kraft cuttings
New colored kraft
Grocery bag waste
Kraft multi-wall bag waste
New brown kraft envelope cuttings
New colored envelope cuttings
Semi-bleached cuttings
Colored tabulating cards
Sorted colored ledger
Manifold colored ledger
Sorted white ledger
Manifold white ledger
Computer printout
Printed bleached kraft
Bleached kraft:
Coated soft white shavings
Hard white shavings
Hard white envelope cuttings
Manila tabulating cards
Unprinted bleached sulfate
Unprinted TMP
Number of Mills
Reporting Use
120
45
125
32
I
37
161
94
36
66
35
85
                      4-45

-------
                                      Table 4-6
                                     (Continued)
  API(a) Paper Recycling
     Committee Code
(a)API (American Paper Institute) now AFPA (American Forest and Paper Association).
                                           4-46

-------
                                     Table 4-7
                        Wood Preparation and Handling
   Wood Preparation and. Handling Operations
Number (%> of Bleached Chemical Wood Pulp
               Reporting Use
None Applicable
                                                             3(3%)
Log Ponds
                                                            4(4%)
Log Flumes
                                                            40 (38%)
Log Washing
               15 (14%)
Slashing
                                                            5(5%)
Wet Debarking
               12 (11%)
Dry Debarking
                                                           76 (72%)
Chipping
                                                           81 (77%)
Chip Washing
                                                            9(9%)
Chip Screening
                                                           94 (90%)
                                       4-47

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                                     Table 4-8
                      Number of Mills by Pulping Process
Pulp Process
Dissolving Kraft
Papcrgrade Kraft and Soda
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Stone Groundwood
Mechanical Refiner
Thermo-Mechanical
Chemi-Mechanical
Chemi-Thermo-Mechanical
Non-Deink Secondary Fiber
Deink Secondary Fiber
Number of M

13

1
r
/•

/

/•
3

                                                             3(1%)
                                                           133 (24%)
                                                             5 (1%)
                                                            17 (3%)
                                                            32 (6%)
                                                            24(4%)
                                                             7(1%)
                                                             27 (5%)
                                                             4 (1%)
                                                            342 (61%)
                                                             43 (8%)
Total Number of Reporting Mills: 565
(a)Note that the number of mills is not additive because many mills operate multiple fiber lines and processes.
                                          4-48

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                                       Table 4-9


                             Bleaching Chemicals Used
                      As Reported in the 1990 Questionnaire
Chemical
Elemental Chlorine
Chlorine Dioxide
Hypochlorite
Oxygen
Hydrogen Peroxide
Sodium Hydroxide
Sulfur Dioxide i
Sulfuric Acid
Water Soak
Hydrosulfite
Urea
Monox-L
Approximate Percentage of MiHs(a)
Papergrade Kraft and Soda
and Dissolving Kraft
99%
89%
69%
64%
43%
100%
10%
9%
5%
1%
1%
1%
Papergrade Sulfite and
Dissolving Sulfite
82%
41%
88%
29%
41%
88%
12%
12%
-..
__
..

(a)Includes data for mills that bleach chemical wood pulp in traditional bleach plants; not based on amount of
   pulp bleached by mills.


— Not used by any mills.
                                        4-49

-------
                                      Table 4-10
                                                                      i
    U.S. Pulp, Paper, and Paperboard Production in 1989, by Product
                     Description
Market Pulp:
 Special Alpha and Dissolving Woodpulp
 Bleached Kraft Pulp
 Unbleached Kraft Pulp
 Bleached Sulfite Pulp
 Groundwood Pulp
 Thenno-Mechanical Pulp
 Semi-Chemical Pulp
 Miscellaneous Pulp (Deink and Non-Deink Secondary
   Fiber Pulp, Cotton Pulps)	
                                                        Number of Mills
                                                                            Total Final
 Paper:
  Newsprint
  Uncoated Groundwood Papers
  Clay Coated Printing and Converted Paper
  Uncoated Free Sheet
  Bleached Bristols (Excluding Cotton Fiber Index and
   Bogus)
  Cotton Fiber Writing Paper and Thin Paper
  Unbleached Kraft Packaging and Industrial
   Converting Paper
  Special Industrial Paper, Except Specialty
   Packaging
  Tissue
  Wrapping Paper
  Shipping Sack and Other Bag and Sack Paper
  Waxing Stock
  Other Stocks (Asphalting, Creping, Coating and
    Laminating, Gummed, Twisting and Spinning)
  Specialty Packaging
  Glassine, Greaseproof, and Vegetable Parchment
10
55
6
10
2
3
1
11
21
22
51
109
11

26
26

65

74
 17
 13
 7
 10

 10
 7
                {million
              OMMT/yr)
1.40
7.90
0.33
0.49
 nd
0.21
 nd
0.37
4.98
1.90
8.28
10.26
0.71

0.52
2.67

 1.17

 4.70
 0.12
 0.40
 0.06
 0.06

 0.15
 0.06
                                            4-50

-------
                                       Table 4-10




                                      (Continued)
Description
Paperboard:
Unbleached Kraft Packaging and Industrial
Converting Paperboard
Semi-Chemical Paperboard, Including Corrugated
Medium and Other Uses
Recycled Paperboard
Wet Machine Board, Including Binder's and Shoe
Board
Construction Paper
Insulating Board
Linerboard
Folding Carton Type Board
Milk Carton Board
Heavyweight Cup and Round Nested Food Container
Plate, Dish, and Tray Stock
Bleached Paperboard for Miscellaneous Packaging
Other Solid Bleached Board (Paperboard for Moist,
Oily, and Liquid Foods)
Molded Pulp Products, Including Fruit/Vegetable
Packs and Egg Cartons
1
Number of Mills
That Manufacture

45

31

129
9

18
4
9
13
7
11
8
9
7

19
-•-•j — —
Total Final
JProductwm
(million
OMMT/yr)

17.58

5.38

7.5
0.07

007
\Jf\J f
003
\J*\JO
0^4
\JfJ*T
2.17
i no
j-.i/*'
034
0?0
UtiAJ
0.49
0.24

0.21

nd - Not disclosed to prevent compromising confidential business information.
                                         4-51

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-------
                                                                    5.0  Subcategorization
 5.0    SUBCATEGORIZATION

 5.1    Introduction

 In  developing the  proposed  regulation,  EPA  considered whether different  effluent
 limitations guidelines and standards were appropriate for different groups of mills  or
 subcategories within the industry. Factors considered by EPA for industry Subcategorization
 include the following (see Clean Water Act (CWA) Section 304(b)):

              Process technologies used and products manufactured;
              Raw materials;
              Wastewater characteristics,  discharge rates, and treatability;
              Water pollution control technologies;
              Geographical location;
              Mill age and size;
              Non-water quality environmental impacts;
              Engineering aspects of applying process change control technologies; and
              Costs and  economic impacts.

 The industry Subcategorization set out at 40 CFR Parts 430 and 431 was developed for the
 pulp, paper, and paperboard regulations promulgated during the period 1974 to 1982 (39
 FR 16578; 39 FR 18742; 42 FR 1398; and 47 FR 52006).  There are 26 subparts in the
 current regulations, with 15 further  divisions.  As part of the  proposed revision  of the
 effluent limitations guidelines and standards for  the pulp, paper, and paperboard industry,
 the Agency reviewed the current Subcategorization to determine if the  subcategories
 adequately represent present industry characteristics.  The Agency analyzed the most recent
 data from the pulp and paper industry and concluded that the 26 current subcategories are
 not necessary and that 12 revised subcategories are sufficient to  characterize the industry.

       Description of Current Industry Subcategorization and Rationale for Changing the
       Current Subcategorization
5.2
Manufacturing processes and untreated wastewater characteristics (i.e., pollutant loadings)
were the principal factors used to develop the current Subcategorization of the industry.
Data used to determine the current Subcategorization represented the state of the industry
during the mid- to late-1970s. At that time, the overall level  of wastewater treatment
provided by the industry was not consistent  among mills  with similar manufacturing
processes.   EPA concluded that untreated wastewater  pollutant loadings  provided a
reasonable basis to subcategorize the industry principally because the costs for mills with
similar untreated wastewater pollutant loadings to  achieve uniform effluent levels were
similar.
                                        5-1

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                                                                 5.0 Subcategorization
The current subcategorization is set out below:
      40 CFR Part 430

      • Subpart    A -
      • Subpart    B -
      • Subpart    D -
Sulfite  Semi-Chemical  (Cross
                       Unbleached Kraft;
                       Semi-Chemical;
                       Unbleached  Kraft-Neutral
                       Recovery);
                       Paperboard from Wastepaper;
                       Dissolving Kraft;
                       Market Bleached Kraft;
                       Board, Coarse, and Tissue (BCT) Bleached Kraft;
                       Fine Bleached Kraft;
                       Papergrade Sulfite (Blow Pit Wash);
                       Dissolving Sulfite Pulp;
                        Groundwood-Chemi-Mechanical;
                        Groundwood-Thermo-Mechanical;
                        Groundwood-Coarse, Molded, and News (CMN) Papers;
                        Groundwood-Fine Papers;
                        Soda;
                        Deink;
                        Non-Integrated-Fine Products;
                        Non-Integrated-Tissue Papers;
                        Tissue from Wastepaper;
                        Papergrade Sulfite (Drum Wash);
                        Unbleached Kraft and Semi-Chemical;
                        Wastepaper-Molded Products;
                        Non-Integrated-Lightweight Papers;
                        Non-Integrated-Filter and Nonwoven Papers;
                        Non-Integrated-Paperboard;

      40 CFR Part 431

      • Subpart   A -   Builders' Paper and Roofing Felt.

5.3    Methodology for Revising Industry Suhcategorization

EPA and state permit writers have gained much  experience implementing  the current
effluent limitations guidelines and standards for the pulp,  paper, and paperboard industry
since the regulations were first promulgated in 1974. Frequently, those permit writers have
found that a  single  mill will contain  processes  that fall within two,  three, or more
subcategories.   This  situation greatly complicates  the task of permit writing, requiring
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart'
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart
• Subpart
E-
F-
G-
H-
I-
J-
K-
L-
M-
N-
0-
P-
Q-
R-
S-
T-
U-
V-
w
X-
Y-
z-
                                         5-2

-------
                                                                  5.0 Subcategorization
considerable additional information gathering, time, and resources.  As a result, the Agency
analyzed the most recent data from the pulp, paper, and paperboard industry to determine
if the revised regulations might appropriately contain fewer subcategories.

Using the current Subcategorization as a starting point, EPA applied factors set out in
Section 304(b) of the CWA using data from the 1990 questionnaire to assess the current
Subcategorization.  Presented below is a review of the methodology used and the factors
considered by the Agency.

5.3.1  Methodology - Conventional Pollutants

The pulp, paper, and paperboard industry can be classified as follows by major production
processes.  This classification and  how the current subcategories  relate  to  it are  shown
below:

             Integrated Pulp and Paper Mills
                   Chemical Pulp Mills
                         Kraft and Soda Mills
                               Dissolving Kraft (Subpart F)
                               Bleached Papergrade Kraft (Subparts G, H, I)
                               Bleached Papergrade Soda (Subpart P)
                               Unbleached Kraft (Subparts A, D, V)

                         Sulfite Mills
                               Dissolving Sulfite (Subpart K)
                               Papergrade Sulfite (Subparts J and U)

                         Non-Wood Fiber Pulp Mills

                   Semi-Chemical Pulp Mills (Subparts B, D, V)

                   Mechanical Pulp Mills
                         Stone Groundwood (Subparts N and O)
                         Refiner
                         Thermo-Mechanical (Subpart M)
                         Chemi-Mechanical (Subpart L)
                         Chemi-Thermo-Mechanical

                  Secondary Fiber Mills
                         Deink Mills (Subpart Q)
                         Non-Deink Mills (Subparts E, T, W, and Part 431 Subpart A)

            Non-Integrated Paper  Mills (Subparts R, S, X, Y, Z)
            (producers of products from purchased pulp)
                                       5-3

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                                                                   5.0 Subcategorization
This classification of the industry reflects differences in raw materials used (e.g  wood,
secondary fiber, non-wood fiber, purchased pulp); manufacturing processes (e.g. chemical,
mechanical, and secondary fiber pulping; pulp bleaching; paper making); final products (e.g.,
unbleached pulp, bleached pulp, finished paper products); and, to a large extent untreated
and treated wastewater characteristics (e.g., biological oxygen  demand (BOD5) loadings
presence of toxic chlorinated compounds from pulp bleaching) and process water usage and.
discharge rates.

The classification of the industry by the major production processes described above directly
addresses  many  of the statutory factors  set  forth in  CWA  Section 304(b),  including
manufacturing processes and equipment, raw  materials, and products manufactured.  A
review of the 1990 questionnaire data demonstrated that size, age, and geographical location
were not significant factors to explain wastewater characteristics for this industry.  As  a
result the Agency used the production process classification as a starting point for reviewing
Subcategorization, with additional consideration of wastewater characteristics and wastewater
treatabUity.

All types of pulp, paper, and paperboard mills produce wastewaters that contain substantial
quantities of the conventional pollutants BOD5 and total  suspended solids (TSS).  Ihe
Agency determined that BOD5 is the most significant conventional pollutant generated and
discharged by the industry  (in terms of potential to degrade water quality) and that the
principal design objective for pulp, paper, and paperboard mill wastewater treatment systems
is efficient BOD5 removal.  The Agency examined the status of the industry with respect to
 treatment of BOD5 to determine if the current subcategories adequately represent present
 industry characteristics. The Agency determined that, based upon the present status of the
 industry  many of the current subcategories are  no longer necessary because  mills with
 similar production processes  have, at reasonable costs, achieved   similar  production
 normalized effluent quality, notwithstanding differences in untreated wastewater pollutant
 loadings  Accordingly, the Agency used effluent quality, in terms of production normalized
 BOD5 load, as  a  basis to  further subcategorize the industry beyond the  major process
 classifications set out above.

 EPA's approach to reviewing industry Subcategorization can be summarized as follows:

        1.      Determination of long-term average effluent characteristics for each mill;

        2.
        3.
Selection of individual mills to represent final effluent characteristics for each
current subcategory;

Determination of the  range and average  effluent characteristics for each
current subcategory;
                                          5-4

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                                                                     5.0 Subcategorization
        4.
       5.
Within the framework  of  the industry  production process classification,
evaluation of whether mills within  different  current  subcategories could
achieve the same or similar effluent quality in terms of production normalized
BOD5; and,

Combination of subcategories  from  the  1982  regulation within the major
process groups described above, where appropriate.  Subcategories were not
combined across major process groups.
 The first step in the Subcategorization analysis was to determine long-term average (LTA)
 effluent characteristics for each mill.  For this analysis, the Agency used data characterizing
 final  effluent BOD5 and TSS  loadings  supplied by mills  responding  to the  1990
 questionnaire.  Long-term average mass loadings (kg/day) for each mill were production
 normalized  by  dividing  by  the mill's average  daily final  off-machine  production
 (OMMT/day).  Section 9.2.3 presents more detail about these calculations.

 Long-term average mass loadings were not calculated for certain mills, as follows:

       •      Indirect and zero discharge mills;

       •      Non-continuous dischargers;

       •      Mills without wastewater treatment or mills with poor treatment performance
              due to lack of adequate primary or secondary treatment;

       •      Mills that did not operate for significant portions of 1989;

       •      Mills -that did not report final effluent BOD5 loadings;

       •      Mills that combined wastewater for treatment with another mill; and

       •      Mills that treated significant portions of wastewater from non-pulp and paper
             industry sources.

After the exclusions listed  above were made, effluent characteristics were determined for
290-mills.

The next step was to identify mills to represent the final effluent characteristics  of each
current subcategory.  Ideally, only mills with all of their final off-machine production in a
single  subcategory would  be used to represent the  final effluent  characteristics for that
subcategory.  After application of the selection parameters discussed above, the majority of
the subcategories  included few or no  mills  with  all of their production in a single

                                        5-5

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                                                                   5.0 Subcategorization
subcategory, reflecting the actual organization of the U.S. pulp and paper industry (a typical
mill has operations in more than one subcategory). To account for this situation, while at
the same time reflecting the characteristics of the principal subcategory at a mill, the Agency
considered mills with a large percentage of their final production in a single subcategory.
The Agency selected a final production cut-off of 85 percent within a single subcategory for
a mill to be considered representative of that subcategory.  Except as  noted below, mills
with less than 85 percent of their final production within a single subcategory were generally
considered to be  "multiple subcategory mills" and were  not selected to represent final
effluent characteristics for a subcategory.

After selecting mills to represent each current subcategory, the average final effluent EODS
loading of mills in each.current subcategory was calculated. Table 5-1 presents average final
effluent BOD5 concentrations and loadings for each current subcategory.  Loadings were
normalized to two different productions:  off-machine metric tons of final product (as
reported  in Table E of the 1990 questionnaire)  and metric tons  of  pulp produced (as
reported  in  Tables  B  and C  of the  1990 questionnaire).   The Agency found  it more
meaningful to normalize final effluent BOD5 loadings to off-machine tons (OMMT) of final
product, and, therefore, the loadings presented in the following discussion are OMMT ol
final production.  Where presentation of production normalized loadings may compromise
confidential business information, these data have not been disclosed.
 The Agency compared average and range of production normalized final effluent
 loadings of the mills selected to represent each current subcategory.  Subcategones with
 similar process technologies were compared.  Based upon these comparisons, the Agency
 determined  that several current subcategories  exhibited similar  treated  wastewater
 characteristics, and that these subcategories may be grouped or combined into revised
 subcategories.

 The results of EPA's review of industry subcategorization are detailed below.

 1.     Dissolving Kraft Subcategory

        This  subcategory was characterized by mills producing both  dissolving grade and
        papergrade pulp. Three kraft mills reported on-site manufacture of dissolving grade
        pulp  ranging from 31 to 61 percent of total production.  Each  of these mills also
        reported production of papergrade pulp, ranging from 39 to 69 percent of total
        production.  The manufacture of papergrade pulp at these mills closely resembles
        manufacture of dissolving grade pulp because the papergrade pulp produced at these
        mills contains a higher percentage of cellulose than typical papergrade pulp. For this
        reason, the Agency has included the production of papergrade kraft pulp at mills that
        produce dissolving kraft pulp in the Dissolving Kraft Subcategory.
                                          5-6

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                                                                   5.0 Subcategorization
       The Agency  calculated the average production normalized  final effluent BOD5
       loadings for these three mills, shown below:
Current
Subpart
F
' Current
Suheategory
Name
Dissolving Kraft
Number of
Mills
3
—
Production Normalized Final
Effluent BQDj Loadings
(kg BQB5/GMMT)
Average
5.39
Range
nd
Proposed
Subpart
A
nd - Not disclosed to prevent compromising confidential business information.

       Because this subcategory uses a unique process technology, the Agency proposes to
       maintain dissolving kraft as a separate subcategory, proposed Subpart A.

2.      Bleached Papergrade Kraft and Soda Subcategory

       This  subcategory  was  characterized by  mills with  production in four current
       subcategories: current Subpart G - Market Bleached Kraft; current Subpart H - BCT
       (Board, Coarse, Tissue) Bleached Kraft; current Subpart I - Fine Bleached  Kraft- •
       and/or current Subpart P - Soda Pulps. At these mills, the combined production in'
       the four current subcategories ranged from 57  to 100 percent of total production.
       The balance of production comprised up to 43 percent unbleached kraft or up to 32
      percent purchased pulp.

      The Agency  calculated the average production normalized  final effluent BOD5
      loadings for these four current subparts . These averages and the lowest and highest
      individual mill long-term average loadings are shown below:
Current
Subpart
G
H
Current
Subcategory
Name
Market Bleached
Kraft
BCT (Board,
Coarse, Tissue)
Bleached Kraft
.. .
Number of
Mills
6
3
=============
Production Normalized final
Effluent BQB5 Loadings
(kg BOD5/OMMT)
Average
2.06
2.45
Range
1.06 - 4.37
1.62 - 2.93
==============
Proposed
Subpart
B
B
                                       5-7

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                                                                   5.0 Subcategorization
               Fine Bleached
               Kraft
                                              Production Normalized Final
                                                Effluent BO»S Loadings
                                                  (kg BOP5/OMMT)
                                                  1.99
0.26 - 7.40
                                                                            B
nd - Not disclosed to prevent compromising confidential business information.

       Because these loadings are similar, and there is overlap  across the ranges  the
       Agency proposes to combine current Subparts G, H, I, and P into proposed Subpart
       B (see Figure 5-1).

3.     Unbleached Kraft Subcategory

       This subcategory was characterized  by mills  with  production in three  current
       subcategories: current Subpart A - Unbleached Kraft,'or current Subparts D and V -
       Unbleached Kraft  and  Semi-Chemical Pulps.   At these mills,  the combined
       production in the three current subcategories ranged from 66 to 100 percent of total
       production.  The balance of production comprised up to 3 percent non-demk
       secondary fiber pulp or up to 34 percent purchased pulp. Semi-chemical processes
       that use a cross-recovery system to process spent liquors with kraft pulping liquors,
       including the neutral sulfite semi-chemical process, are included in this subcategory.
       The Agency also  considered combining current Subpart B with current Subparts A,
       D, and  V into one proposed subpart.

       The Agency calculated  the average production  normalized  final  effluent BOD5
       loadings for the  following current  subparts.   These averages  and  the  lowest and
       highest individual mill long-term average loadings are shown below:
                                          5-8

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                                                                    5.0 Subcategorization
Current
Subpart
A
D,V
B
Current
Subcategory
Name
Unbleached Kraft
Unbleached Kraft
and Semi-
Chemical
Semi-Chemical
Number of
Mills
8
1
1
— 	 	
Production Normalized
Final Effluent BOJD5
Loadings
(kg BOB5/OMMT>
Average
1.63
0.29
9.41
Range
0.56 - 2.47
0.29
9.41
Proposed
Subpart
c
C i
F
       The average loading for current Subpart B - Semi-Chemical, is over five times the
       average loading for current Subpart A - Unbleached Kraft, and over 32 times the
       average loading for current  Subparts  D  and V -  Unbleached  Kraft and Semi-
       Chemical.  The Agency also  recognizes that the process technologies for current
       Subparts A, D, and V are similar in that chemical recovery systems  are  used to
       process  spent  liquors.   The  process technology for  current Subpart  B  - Semi-
       Chemical, does not include chemical recovery systems.   For these reasons,  the
       Agency proposes to maintain semi-chemical as a separate subcategory, proposed
       Subpart F.  The Agency further proposes to combine current Subparts A, D and V
       into proposed Subpart C (see Figure 5-2).

4.      Dissolving Sulfite Subcategory

       This subcategory was characterized by  mills  producing both dissolving grade and
       papergrade pulp. Five sulfite mills reported on-site manufacture of dissolving grade
       pulp ranging from 82 to 100 percent of total production. Three of these mills also
       reported production of papergrade pulp  ranging from 2 to  18  percent of total
       production. The manufacture of papergrade pulp at these mills closely resembles
       manufacture of dissolving grade pulp because the papergrade pulp produced at these
       mills contains a higher percentage of cellulose than typical papergrade pulp. For this
      reason, the Agency has  included the production of papergrade sulfite pulp at mills
      that produce dissolving sulfite pulp in the Dissolving Sulfite Subcategory.

      The current Subcategorization provides for four grade-segments within dissolving
      sultite: nitration, viscose, cellophane, and acetate grades. During the development
      ot the 1982 regulation, the Agency determined that the untreated wastewater BOD5
      loadings of these four grade segments were significantly different from each other
      as follows:                                                                   '
                                       5-9

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                                                                 5.0 Subcategorization
           Dissolving Sulfite Sequent
   Nitration
   Viscose
    Cellophane
   Acetate
Untreated Wastewater BOD5 Load
        (Ug/OMMT)	
                                                          137
                                                          156
                                                          182
                                                          266
     The Agency has production normalized final effluent data from the dissolving sulfite
     mills and classified these data by predominant grade produced. The Agency has not
     disclosed these data, however,  to  prevent compromising confidential  business
     information.  Wastewaters from the four dissolving sulfite grade segments exhibit
     similar treatability. That is, treating each type of ^^^^^J^^
     system will result in the same range of percent reduction in BODS (1).  Thus, given
     the same degree of treatment, final effluent loadings from viscose production should
     be lower than the effluent loadings from acetate production. The data do not reflect
     this expected trend.  In fact, the mills producing primarily acetate grade  achieved
     lower production normalized final effluent BOD5 loadings than the mills producing
     primarily viscose grade.

     The Agency concludes that the differences in the reported production normalized
      effluent loads  were not attributable  to  differences  in treatability, but  were
      attributable to differences in wastewater treatment systems.

      The Agency further concludes that production of these grade-segments  does not
      define unique process technologies, and therefore proposes to  eliminate these four
      grade-segments from the proposed subcategorization.  However,  this  subcategory,
      overall, uses a unique process technology; therefore, the Agency proposes to maintain
      dissolving sulfite as a separate subcategory, proposed Subpart D.

5.    Papergrade Sulfite Subeategory

      This  subcategory was  characterized  by mills with production in  two current
      subcategories:  current Subpart J - Papergrade Sulfite (Blow Pit Wash), or current
      Subpart U - Papergrade Sulfite (Drum Wash). At these mills, the production of
      papergrade sulfite ranged from 53 to 85 percent of total production.  The balance of
      production comprised up to 47 percent purchased pulp. The Agency  also considered
      combining current Subpart K with  current Subparts J and U into one proposed
      subpart.
                                        5-10

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                                                                     5.0 Subcategorization
        The  Agency  calculated the average production  normalized final  effluent BOD,
        oadings  for  the current subparts.   These  averages  and the lowest and highes
        individual mill long-term average loadings are shown below
     Current
     Subpart
   Current
  Subcategory
  Number of
    Mills
                                                         Proposed
                                                          Subpart
 nd - Not disclosed to prevent compromising confidential business information.
                                               Production Normalized Final
                                                Effluent BODS Loadings
                                                  (kg BOPS/QMMT>
       o        th   A     CfflUent ?°D5 10adingS are not similar' and the ^nges do not
       overlap,  the  Agency  rejected  this combination of subcategories.   Because  the
       Papergrade  Sulfite Subcategory uses  a unique  process  technology, the  Agency
       E  Furthfr TT '* papergrade flf*e as a seParate Subcategory, proposed Subpart
       E  Further, the Agency asserts that blow pit washing processes and drum washing
       processes do  not  constitute unique process technologies.  The Agency  therefor?
       proposes to combine current Subparts J and U into proposed Subpart E.

6.      Semi-Chemical Subcategory

       This  Subcategory was characterized  by  a  mill producing semi-chemical puto
       eqmvalent to 62 percent of total production. The mill product no unbleS toaft

                1      C                                   •
           rd
      comprised 38 percent purchased pulp.
         dinthfn                   Production normalized final effluent BOD5
      loading for the following current subpart as shown below:
   Current
   Subpart

      B
  Current
Subcategory
  Name
              Semi-Chemical
Number of
  Mills
                                    1
                                             Production Normalized Final
                                               Effluent BODS Loadings
                                                {kg BOD5/OMMT)
Average
                                                 9.41
                                           Range
                                                               9.41
Proposed
Subpart
                                       5-11

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                                                                5.0 Subcategorization

      Sibpart F includes mills having semi-chemical processes, including the       ^
      semi-chemical process, which do not use a cross-recovery system to process spent
      liquors.

7.     Mechanical Pulp Subcategory

      This  subcateeory was characterized by  mills with  production in  four  current
      SLSSSfSncot Subpart M - Groundwood-Thermo-Mechamcal Puho  current
      Subpart N -  Groundwood-Coarse, Molded,  News  Pulps;  current  Subpart  O  -
      Groundwood-Fine  Papers;  and/or  current  Subpart L  - Groundwood-Chemi-
      Mechamcal Pur^s.  At? these mills, the combined, production in ***™^
      subcategories ranged from 8 to 68 percent of total production.  The balance at
      p^odSn comprfsed up to 77 percent bleached kraft or up to 84 percent purchased

      pulp.

      In order to adequately represent the proposed subcategory, the Agency included the
      treated effluent BOD5 loadings from at least one mill in each current subpart. In this
       cS Tin order to include one'mill to represent ffo^ood-^^r^^^
       Agency included a mill with mechanical pulping production as low as 8 percent of
       total production.

       The  Agency  calculated the average production  normalized  final  effluent BODj
       loadings for these four current subparts. These averages and the lowest and highest
       individual mill long-term average loadings are shown below:
=========
Current
Subpart
M
N
O
======
Current
Subcategory
Name
GW-Thermo-
Mechanical
GW-CMN
(Coarse, Molded,
News) Papers
GW-Fine Papers
.
Number of
Mills
1
1
4
Production Normalized Final
Effluent BOD5 Loadings
(kg BODj/OMMT)
Average
0.35
0.56
1.04
Rangp
0.35
0.56
0.53 - 2.37
Proposed
Subpart
G
G
G
                                         5-12

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                                                                   5.0  Subcategorization
     Current
     Subpart
  Current
Subeategory
  Name
Number of
  Mills
                                              Production Normalized Final
                                                Effluent BODS Loadings
                                                  (kg BODS/OMMT>
Average
Range
Proposed
Subpart
                GW-Chemi-
                Mechanical
                               0.65
                                            0.65
                                           G
       Because these loadings are within a relatively narrow range, the Agency proposes to
       combine current Subparts M, N, O, and L into proposed Subpart G (see Figure 5-3).

8.     Non-Wood Chemical Pulp Subcategory

       This Subcategory was  characterized  by a mill producing non-wood chemical pulp
       equivalent to 30 percent of total production.  The balance of production comprised
       70 percent purchased pulp.  The production normalized BOD5 loading for this mill
       is not  disclosed  to  prevent  compromising confidential business  information
       Regardless of final effluent BOD5 load, the Agency finds  that the chemical pulping
       of virgin non-wood fiber constitutes a unique process technology and, therefore
       requires a new subpart, proposed subpart H.

9.      Secondary Fiber Deink Subcategory

       This subcategory was characterized by mills with production in two segments of the
       current  Deink Subcategory:  fine papers and tissue papers.   At these mills, the
       combined production in the two segments ranged from 33 to 100 percent of  total
      production.  The balance of production comprised up to 43 percent secondary fiber
      non-demk pulps or up to 57 percent purchased pulp.  At the time of this analysis  a
      mill that was representative of the third segment of the  current Deink Subcategorv
      newsprint, was not identified from the available data.

      The  Agency  calculated the  average  production  normalized final effluent BOD
      loadings for  two  of the three  segments of the current  Deink Secondary Fiber
      Subcategory.  These averages and the lowest and highest individual mill long-term
      average  loadings are shown below:
                                      5-13

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r
                                                                              5.0 Subcategorization
	 -I— ^=B
Current
Subpart
Q
Q
Q
	 ~
Current Segment
Name
SF Deink Fine
Papers
SF Deink Tissue
Papers.
SF Deink
Newsprint
=======
Number of
Mills
5
13
0
Production Normalized Final
Effluent ftODj Loadings
(kg BODS/OMMT)
Average
2.00
-.
3.12

Range
0.20 - 4.67
..
0.65 - 7.63
-
i
Proposed
Subpart
I
I
I
                    Because this subcategory uses a unique process technology, the
                    maintain secondary fiber deink as a separate subcategory proposed subpart I  The
                    Agency does not expect this process technology to produce significantly different
                    trS effluent loadings for the  newsprint  segment,  and therefore proposes  to
                    combine this segment into proposed Subpart  I (see Figure 5-4).

              10.    Secondary Fiber Non-Deink Subcategory

                    This subcategory was characterized by mills with production in four current secondary
                    fiber non-deL^^categories: current Subpart T - Tissue from Wastepaper; current
                    Subpart E  -  Paperboard from Wastepaper (Corrugating  and Non-Corrugating
                    Medium); current Subpart W - Wastepaper-Molded Products; and/or Builders  Paper
                    and Roofing-Felt (40 CFR Part 431, Subpart A) and by mills with production of non-
                    deink secondary fiber not currently covered by any subcategory. At these^rnills  he
                    combined production of non-deink secondary fiber ranged from 1 to 100 percent of
                    total production.  The balance  of production comprised up to 2 percent synthetic
                    fiber or up to 99 percent purchased pulp.

                    Seven nulls with very low production of non-deink secondary fiber were^includedi in
                    this analysis due to problems in interpreting questionnaire production information
                    At the time  of  the analysis,  these mills were  believed to have most of then-
                    production in the Non-Deink Secondary Fiber Subcategories.  Subsequent  to this
                     analysis revised or corrected production information was obtained from a number
                     of mills  Because the final effluent loadings from these mills were very similar to
                     mills with most of their production in the Non-Deink Secondary Fiber Subcategories
                     the Agency concludes that the use of these data did not significantly impact the
                     proposed subcategorization. (Note: these mills were not used to determine BPT
                     option performance. See Section 9.2.)
                                                                            I
                                                      5-14

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                                                             5.0 Subcategorization
  Treated effluent BOD5 loadings from a total of 48 mills were used to characterize
  the wastewater effluents from this process technology. At 35 of these 48 mills the
  combined production of the current non-deink secondary fiber ranged from 50 to 100
  percent  of total production.  At six  of the remaining mills, the majority  of the
  production was non-deink secondary fiber not currently covered by any subcategory
  The majority of the production at the remaining seven mills was production of paper
  or paperboard from purchased pulp.

  The Agency calculated the average production normalized final  effluent  BOD5
  loadings for the six current subparts and segments.  These averages and the lowest
  and highest individual mill long-term average loadings are shown below
======
Current
Subpart
T

E



E



W

-
A
(40 CFR Part
431)
==^=
	
Current
Subcategory
Name
Tissue from
Wastepaper
Paperboard from
Wastepaper -
Corrugating
Medium
Paperboard from
Wastepaper -Non-
Oorrugating
Medium
Wastepaper -
Molded Products
Other Non-Deink
Builders' Paper
and Roofing Felt

	
Number of
Mills
13

20



2



2

10
1
=====
,, ,
Production Normalized Final
Effluent B0DS Loadings
(kg BOD5/OMMT>
Average
2.27

0.56



0.53



0.87

2.78
0.65
=====
Range
0.05 - 4 68

0.05 - 1.46



0.27 - 0.79



0.39 - 1.35

0.49 - 7.52
0.65
=====
======
Proposed
Subpart
i

j



j



j

J
J
===== 	
Because these loadings are similar,  and there is overlap across  the ranges  the
A%nC^£>°?,OSeS t0 combine current Subparts T, E, and W (40 CFR Part 430) and
A (40 CFR Part 431) into proposed Subpart J (see Figure 5-5). The Agency asserts
that demk secondary fiber processes  and non-deink secondary fiber processes  are
distinct process technologies and, therefore, did not combine them into one subpart
                                 5-15

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                                                                  5.0 Subcategorization
11.    Fine and Lightweight Papers from Purchased Pulp Subcategory

      This  subcategory  was  characterized by  mills  with  production in two current
      subcategories:  current Subpart R - Non-Integrated Fine Papers from Wood and
      Cotton Fiber Furnishes, and/or current Subpart X - Non-Integrated Lightweight
      Papers  At these  mills, the combined production in the two subcategories ranged
      from 61 to 100 of  total production. The balance of production comprised up to 32
      percent synthetic fiber or up to 39 percent secondary fiber non-deink pulp.

      The Agency calculated the mean production normalized final effluent BOD5 loadings
      for these current subparts and segments. These averages and the lowest and highest
      individual mill long-term average loadings are shown below:
— — — -^
Current
Subpart
R
R
X
X
3======
Current
Subcategory Name
NI Fine Papers -
Wood Fiber
Furnish
NI Fine Papers -
Cotton Fiber
Furnish
NI Lightweight-
Lightweight Papers
NI Lightweight-
Electrical Papers
	 	
Number of
Mills
3
2
1
0
.,.,.-
Production Normalized Final
Effluent BC)D5 Loading!?
(kg BOtyOMMT)
Average
1.18
5.47 '
2.11
-
Range
0.64 - 1.46
0.96 - 9.98
2.11
-
Proposed
Subpart
K
K
K
K
 NI - Non-integrated.
        Because these loadings  are  similar, and there  is overlap across  the  ranges, the
        Agency proposes to combine current Subparts R and X  into proposed Subpart K
        (see Figure 5-6).  At the time of this analysis, a mill representative of the lightweight
        electrical papers segment of the current Lightweight Papers Subcategory was not
        identified  from the available  data.   The Agency does  not  expect this process
        technology to produce  significantly different  treated effluent loadings for the
        lightweight electrical papers segment, and,  therefore, proposes to combine this
        segment into proposed Subpart K.
                                         5-16

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 12.
                                                                    5.0 Subcategorization
 The Agency considered combining current non-integrated Subparts R and X with the
 other current non-integrated subparts:  S - Tissue Papers, Y - Filter and Non-Woven
 Papers, and Z  - Paperboard.   The Agency asserts that non-integrated  fine and
 lightweight processes compose a distinct process technology  and, therefore, did not
 combine them with the other non-integrated processes into one subpart.

 Tissue, Filter, Non-Woven, and  Paperboard from Purchased Pulp Subcategory

 This  subcategory was  characterized  by  mills  with production in  two  current
 subcategones:  current Subpart  S - Non-Integrated Tissue Papers; current Subpart
 Y -Non-Integrated Filter and Non-Woven Papers; and by mills with production of
 paper from purchased pulp not currently covered by any subcategory.  At these mills
 the combined production of paper from  purchased pulp ranged from 83 to 100
 percent of total production.  The balance of production comprised up to 17 percent
 synthetic fiber or fiber glass.

The Agency calculated the average production normalized final effluent BOD.
loadings for these current subparts. These averages and the lowest and highest
individual mill long-term.average loadings  are shown below:
Current
Subpart
S
Y
Z
-

Current
Subcategory
Name
NI Tissue Papers
NI Filter and
Non-Woven
Papers
NI Paperboard
Other NI Paper
=======
— ••
Number of
Mills
1
7
0
4
=====
===============
Production Normalized Final
Effluent BOD5 Loadings
(kg BCHVOMMT)
Average
0.22
2.26
-
1.72
=====
Range
0.22 .
0.61 - 6.74
_
0.33 - 3.09
=======
======
Proposed
Subpart
L
L
L
L
==^= 	
NI - Non-integrated.
      Because these loadings are similar, and there is overlap  across the ranges  the
      Agency proposes to combine current Subparts S, Y, and Z into proposed Subpart L
      (see Figure 5-7)  At the time of this analysis, a mill representative of the current
      Non-Integrated Paperboard Subcategory was not identified from the available data
      Ihe Agency does not expect this process technology to produce significantly different
                                       5-17

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                                                                 5.0 Subcategorization
      treated  effluent loadings for the Non-Integrated Paperboard Subcategory,  and,
      therefore, proposes to combine this subcategory into proposed Subpart L.

      The Agency considered combining current non-integrated Subparts S, Y and Z with
      the other ^Per'
and Paperboard Point Source Category. The Builders' Paper and Board Mills Point Source
Category consists  of only  one  subpart,  Subpart A,  in  Part  431  in  the  current
subcftegorization scheme.  The Agency is proposing to move this subpart and include it in
Subpart J of Part 430 hi the proposed subcategorization.

EPA has structured the proposed regulation in a building-block approach such that the
a^caSeNationalPoUutant Discharge Elirnmati^^
wfh production in more than one proposed subcategory mil be the  sum of the mass
loadings based upon production in each subcategory and the respective subcategory effluent
limitations guideline  Discharge allowances for process wastewater deriving from production
in other individual point source categories can be developed similarlyusing an approach
similar to the Combined  Wastes^ream Formula set forth in 40 CFR 403.61(e).  EPA
 determined  thatj this approach results  in achievable effluent  limitations and will be
 straightforward to implement through the NPDES permit program.

 5.3.2  Methodology - Priority and Nonconventional Pollutants

 The Agency also considered the generation and control of priority and nonconventional
 poUutants while developing the revised  subcategories.  Like  Best Practicable Control
 Technology Currently Available (BPT), which establishes limitations on the direct discharge
 of conventional pollutants, the  regulations  that  limit the  discharge of priority  and
 nonconventional pollutants are established for groups of facilities with shared characteristics.
 The Agency identified certain pollutants for which additional discharge limitations were
 required (see Section 7.0).  An important shared characteristic was that the facilities in the
                                         5-18

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                                                                    5.0  Subcategorization
 groups subject to priority and nonconventional pollutant discharge limitations discharge
 similar pollutants of concern.

 Because  of the nature of their production processes,  mills that produce chemical pulps
 generate higher amounts of chemical oxygen demand (COD) and conventional pollutants
 than do  other mills.  In addition, mills that produce  bleached chemical pulps generate
 environmentally significant amounts of certain volatile and chlorinated pollutants (including
 chlorinated dibenzo-p-dioxins (CDDs) and chlorinated dibenzofurans (CDFs)) of concern
 to the Agency.  On the basis of these different wastewater characteristics, the Agency
 identified the chemical pulp mills that do not bleach (unbleached kraft, semi-chemical and
 non-wood chemical pulp) and the bleached chemical pulp mills (bleached kraft, bleached
 soda, bleached sulfite, dissolving kraft, and dissolving sulfite) as two distinct groups of mills
 that may require effluent limitations guidelines and  standards for different  groups  of
 pollutants.   The  Agency's  evaluation of the  pollutants of concern  in each  of these
 subcategories is presented in Section 7.0.

 Control of  priority  and  nonconventional pollutants generated by pulping and bleaching
 processes results from using available manufacturing processes that eliminate or reduce the
 formation and discharge of these pollutants  of concern into process wastewaters.  A few
 examples of such pollution preventing processes are: reuse of screen room decker filtrates
 as make-up in brown stock washing; extended cooking of pulp; and substitution of peroxide
 and oxygen for chlorine and hypochlorite bleaching agents. These and many other pollution
 preventing processes are discussed in detail in Sections 8.0  and  9.0.   These  types  of
 processes directly affect the quality and grade of product that may be produced from a given
 fiber furnish.  Thus, in developing limitations for priority and nonconventional pollutants
 it was necessary to group mills that could feasibly produce the quantity, quality, and grade
 of product  they currently produce  using identified pollution preventing manufacturing
processes.                                                                         6

The Agency identified the following groups of mills for which similar pollution preventing
manufacturing processes are feasible:

             dissolving kraft;
             bleached papergrade kraft and soda;
             dissolving sulfite;
             bleached papergrade sulfite;
             unbleached kraft and semi-chemical, with  cross-recovery of pulping liquor;
             semi-chemical without  cross-recovery of pulping liquor; and
             non-wood chemical pulp mills.
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                                                                  5.0 Subcategorization
The Agency considered, but rejected, further division of the above-listed groups on the basis
of:

       •      hardwood and softwood fiber furnish;
       •      brightness of pulp produced;
       •      grade of dissolving pulp (e.g., viscose, cellophane, nitration, acetate); and
       •      grade of papergrade sulfite pulp (e.g., high absorbency, high strength).

These issues are discussed further below.

5.3.2.1       Subcategorization Based on Hardwood and Softwood Fiber Furnish

There are some differences in the pollutants generated in bleaching hardwood pulp and
softwood pulp.  In general, when bleached, softwood  (which contains more ligmn than
hardwood) generates wastewaters with higher poUutant loadings than hardwood. However,
the Agency concluded that there were  not sufficient data  upon which to base separate
limitations and standards for  hardwood and  softwood furnishes for  each of the process
technology options considered. To account for the somewhat higher pollutant loadings from
softwood mills, the Agency used pollutant loadings from  softwood mills in developing
effluent limitations guidelines for priority and nonconventional poUutants. Of the pollutants
of concern to the Agency, chlorinated phenolic compounds were detected more frequently
and at higher concentrations in softwood bleach plant  effluents than in hardwood bleach
plant  filtrates.  The  exception was the class  of  compounds called  syringols  (i.e., 2-
chlorosyringaldehyde, 2,6-dichlorosyringaldehyde, and trichlorosyringol) which were detected
in  the majority of hardwood bleach  plant filtrates, but not detected as often in softwood
bleach plant filtrates.  For trichlorosyringol, which  is typically detected in bleach plant
effluents from hardwood mills but not softwood mills, effluent limitations guidelines were
based upon effluent from a hardwood bleach line.

 5.3.2.2       Pulp Brightness

 Some pulp bleaching processes that do not use chlorine or chlorine-containing compounds
 and generate very low quantities of pollutants of concern to the Agency have not yet been
 used to  manufacture  full  brightness pulp.  The Agency considered further subcategorizing
 the Bleached Papergrade Kraft and Soda Subcategory, based upon pulp brightness. Instead,
 the Agency developed alternative limitations for mills that certify they bleach  without
 chlorine or chlorine-containing chemicals without regard to the brightness  of the products.
 5.3.2.3
Dissolving Pulp Grades
 Dissolving grade pulps (both kraft and sulfite) differ from papergrade pulps in that they
 contain much higher percentages of alpha ceUulose, lower percent hemicellulose, and are
                                         5-20

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                                                                     5.0  Subcategorization
  of a much higher chemical purity. Dissolving grade pulps are typically raw materials for
  chemical processes used to manufacture viscose, acetate, and other cellulose derivatives
  Thus, the characteristics of the pulp as used in the chemical process (e.g., viscose viscosity
  acetate solution color and haze) are critical determinants of pulp quality   The Agency
  considered all available information to determine if various pollution preventing processes
  beyond existing technology were feasible for the production of dissolving grade pulps.

  Certain technologies considered for the  control of pollutant generation in these processes
  were not selected by the Agency as the basis for effluent limitations guidelines because the
  technologies were  not demonstrated to produce pulp with  the properties needed for
  dissolving grade uses.  For example, the Agency recently received data indicating that
  acetate grade dissolving sulfite pulp produced with totally chlorine-free (TCP) processes has
  unacceptable acetate solution haze values. The proposed dissolving kraft effluent limitations
  guidelines  were not based upon 100  percent  chlorine  dioxide  substitution, because
 preliminary data indicate that these pulps cannot be produced without elemental chlorine
 bi addition, the Agency did not have sufficient data to characterize effluent quality from
  £ /r°ff technoloSies  for a11 ^des of dissolving pulp.   The  Agency will evaluate
 additional data received after proposal for the processes considered in this rulemaking (or
 modifications) and alternatives. The Agency may find it appropriate to establish separations
 and different limitations within the two dissolving pulp subcategories based upon grades of
 dissolving pulps produced.
 5.3.2.4
Papergrade Sulfite Pulp Grade
 The Agency has received preliminary information from some papergrade sulfite producers
 indicating that, for ammonium-based  sulfite manufacturing of tissue and  towel products
 strengtii requirements may not be achievable with TCP processes.  Also,  for some other
 specialty grade pulps (for example, photographic and plastic molding pulps), the comments
 state that to be suitable for use, the pulp must be not only high in brightness, but have
 purity, uniform resin absorption rates,  no electrical conductivity, no color reversion at high
 temperature, and high alpha cellulose  content.                                       ^

 The Agency received these data too late to evaluate their impact on the proposed revised
 subcategories  and the need  to further divide the  Papergrade Sulfite Subcategorv  The
 Agency will review these data, and any additional data submitted after proposal, prior to
promulgation of the regulation to determine what pollution preventing processes  beyond
 existing technology may be feasible for certain grades of papergrade sulfite products.

5.3.3  Factors Considered


              Pr°POSed revisions  to the cu"ent industry Subcategorization, the Agency
                                        5-21

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                                                                  5.0 Subcategorization
            Process technologies and products manufactured;
            Raw materials;
            Wastewater characteristics, discharge rates, and treatability;
            Water pollution control technologies;
            Geographical location;
            Mill age and size;
            Non-water quality environmental impacts;
            Engineering aspects of applying process change control technologies; and
            Costs and economic impact.

These factors were considered principally in terms of their impact on production normalized
final effluent BOD5 loadings, because secondary treatment systems in place at these mills
are designed to control BOD5.   An important distinction between this review and the
analyses conducted to support previous rulemakings is the use of treated effluent dataas
opposed to raw waste load data to evaluate the relative impacts  of these factors.  Ihe
Agency determined that production normalized final effluent BOD5 mass loadings were
appropriate to use for subcategorization as opposed to raw waste loadings for the tallowing
reasons:
                                                                 i
       1.    At the time of the development of the current subcategories, many facilities
             had minimal  or no wastewater treatment, whereas at. present, nearly all
             facilities in this category have complied with the regulations by installing
             treatment to  reduce raw waste loads of BOD5; and

       2.    Many facilities do not collect raw waste load data, whereas discharge (treated
             effluent) data are available.

The primary bases for subcategorization were found to be process technologies and products
manufactured, raw materials, and wastewater characteristics and treatability.

5.3.3.1      Process Technologies and Products Manufactured

 Selection of a specific process technology involves consideration of the desired end product;
 type of fiber furnish; use of mechanical or chemical pulping; chemicals used for pulping and
 bleaching; and the need  for product-specific additives (e.g., clays and  fillers)  in the
 papermaking process. These aspects of process technology, in combination with secondary
 biological treatment, contributed to characteristic treated effluent pollutant loadings for mills
 with similar processes.  For reasons  described in Section 5.3.1, the Agency used process
 technologies as a primary  basis for subcategorization.
                                         5-22

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                                                                    5.0  Subcategorization
  5.3.3.2
  Raw Materials
  Raw materials were considered as a factor for Subcategorization as they relate to the process
  technology used. The primary raw materials used in pulp and papermaking are- (1) fiber
  furnish, (2)  chemicals used for pulping and bleaching, and (3) papermaking additives.

  The fiber furnish used as raw material may be hardwood, softwood or non-wood virgin fiber
  wastepaper and other secondary fiber, or purchased pulp. The Agency previously considered
  Subcategorization on the  basis of wood  type  (i.e., hardwood and softwood species) (2)
  Significant relationships between wood type and raw waste loads of conventional pollutants
  could  not  be  determined  for  any  of the  wood pulping  subcategories;  therefore
  Subcategorization based upon wood type  could not be justified during the previous
  rulemaking.  Revising Subcategorization based upon wood  type was not considered  for
  conventional pollutants.  The relationships between wood type and generation of priority
  and nonconventional pollutants resulting  from pulp bleaching are discussed in 5.3.2.1.

  Wood and non-wood virgin fiber, wastepaper and other secondary fiber, and purchased pulp
  are classes  of fiber furnish.   Selection of one of these furnishes as  a raw material
 determines, in part, the type of process technology to be used.  For this reason, these factors
 were used as a basis for Subcategorization.

 Most chemical pulping in the United States is conducted with the kraft (sulfate) or sulfite
 processes.  Semi-chemical and  chemi-mechanical pulping systems  have  similar chemical
 bases Bleaching chemicals include chlorine and chlorine derivatives (calcium and sodium
 hypochlonte, chlorine dioxide); other oxidizing agents (ozone, oxygen, hydrogen peroxide)-
 and extractive agents  (sodium hydroxide).  Selection of chemicals used for pulping and
 bleaching further specifies the process technology and thus was used indirectly as a basis for
 Subcategorization. •                                                     J

 Papermaking additives include  fillers (titanium dioxide, clay, calcium carbonate)- sizing
 agents (alum rosin size); dry strength agents (catcosic starch, gums); wet strength agents
 (urea-formaldehyde,  polyamine  resins);  coloring and  tinting  agents;   retention aids-
 defoamers;  pitch control  agents;  drainage aids; and  formation  aids.   Selection  of
 papermaking  additives further specifies the  process technology required to achieve the''
 desired end product  and thus was used indirectly as a basis for Subcategorization
5.3.3.3
Wastewater Characteristics, Discharge Rates, and Treatability
Manufacturing process technologies  and  raw materials used  at  mills  determine the
production normalized amount of wastewater discharged and the identity and concentration
of pollutants in the untreated wastewater. Thus, wastewater characteristics, as represented
by production normalized final  effluent  BOD5 and TSS loadings, were included in the

                                       5-23

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                                                                   5.0 Subcategorization
analyses supporting Subcategorization.  The number of sources of BOD5 and TSS, and the
typical loads generated by these sources, determine a mill's total BOD5 and TSS load. For
example, a mill with wood handling, pulping, bleaching, and papermaking operations on site
will typically produce a wastewater that is characteristically different from that of a mill that
makes paper from purchased pulp. This characteristic difference is the result of the process
technologies and raw materials used at the mill. The Agency, therefore, did not combine
subcategories with different process technologies, even when these technologies produced
similar final products. Nor did the Agency combine subcategories with different process
technologies even when these technologies generated similar final effluent loadings.

Wastewater treatability was considered as a factor for Subcategorization. The production .
normalized final effluent BOD5 loading  was used as the primary indicator of wastewater
treatability in this evaluation.  The Agency recognized differences in wastewater treatability
among groups  of  mills  with similar process  technologies  by structuring the revised
Subcategorization in accordance  with the major industry classification  set out in Section
531   The  Agency combined  existing subcategories  that used similar  manufacturing
processes where differences in BOD5 treatability were determined to be insignificant.

5.3.3.4      Wastewater Pollution Control Technologies

The Agency considered  using wastewater pollution control technologies as a  factor for
Subcategorization.  As discussed  in 5.3.1 above, the Agency analyzed treated effluent data
from approximately 290  direct discharge pulp and paper mills.  The end-of-pipe control
 technologies in place at these mills  included aerated stabilization basins, activated sludge
 treatment systems,  biological trickling filters, aerated and non-aerated lagoons, and polishing
 ponds   No apparent relationship  between the various types  of end-of-pipe  treatment,
 technologies and-the production normalized final effluent BOD5 were found within the
 major process groups described  above.  Therefore,  end-of-pipe control technologies were
 not used as a basis for Subcategorization.

 5.33.5       Geographical Location

 The Agency previously considered Subcategorization on the basis of geographical location.
 Three aspects  related to geographical  location were considered:  1)  wood type, 2) wet
 woodyard operations, and 3) effect of climate on BOD5 removal efficiencies.   Based on
 these analyses, the Agency concluded that there were no significant differences in raw waste
 loads resulting from geographical location, nor were there significant differences in BOU5
 removal efficiency due to  climate (2).   Consequently, Subcategorization based  upon
 geographical location could not be justified. In that no significant relationships between
 geographical location and treated effluent loadings of conventional pollutants are expected
 due to the effects  of wastewater treatment, the Agency did riot reevaluate this factor.
                                          5-24

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                                                                    5.0  Subcategorization
  5.3.3.6
 Mill Age and Size
  The Agency previously considered Subcategorization on the bases of mill age and mill size
  The Agency concluded that differences related to age of mill were not discernible, and that
  the production normalized data demonstrated the apparent lack of correlation between size
  of mill and raw waste flow and BOD5 (2).

  As  the previous  work describes,  mill age is an indefinite parameter primarily due  to
  continual upgrading and modernization most mills have undertaken in order to remain
  competitive. The cornerstone age (the age of the original facility) was evaluated relative
  to raw waste load BOD5 without apparent relationship.  The Agency did not reevaluate this
  factor in terms of treated effluent load.

  The previous  work demonstrated the lack of apparent relationship between mill size
  measured as tons of production per day, and raw waste flow and BOD5.  The use of a
 production normalizing parameter minimizes the impact of mill size as a determining factor
 for  Subcategorization by allowing  treated effluent  data  to  be compared based on unit
 production (OMMT).

 Reviewing this previous work, the Agency considered, but did not use, mill age and mill size1
 as bases for Subcategorization.  However, the Agency recognizes that the costs to comply1
 with certain aspects of the proposed regulation will be higher for older mills than for1 newer
 mills.  These include the costs associated with upgrading pulping and bleaching operations
 to comply with the  proposed BAT effluent limitations guidelines and installing pulping
 liquor spill prevention and control systems.  In both case's, the Agency considered and
 developed additional retrofit costs associated with installations at older mills
 5.3.3.7
Non-Water Quality Environmental Impacts
The Agency considered using non-water quality environmental impacts from the pulp and
paper industry as factors for Subcategorization. Non-water quality environmental impacts
include possible impacts  on air quality, impacts associated with disposal of wastewater
treatment sludges, energy requirements, and consumptive water loss.

Aside from differences in non-water quality environmental impacts associated with the major
process divisions set out above, the Agency found no basis to subcategorize  the industry
according to non-water quality environmental impacts.
5.3.3.8
Engineering Aspects of Applying Process Change Control Technologies
As discussed in 5.3.2 (and discussed in further detail in Section 9.4), the Agency carefully
considered the feasibility of the use of various pollution preventing manufacturing processes
                                        5-25

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                                                                  5.0 Subcategorization
to produce quality and grades of products currently produced by U.S. pulp and paper mills.
The engineering aspects of applying various process change pollution control technologies
to individual mills was accounted for in estimating the costs of these technologies  (see
Section 11.0). Although the  estimated costs for implementing various technologies were
greater at certain mills, as configured, the various control technologies considered as the
basis for effluent limitations guidelines for each subcategory could be applied at all mills in
the subcategory, thus confirming the proposed subcategories.

5.3.3.9       Costs and Economic Impacts

Analysis of costs and resulting economic impacts did influence the options selected as the
basis of BAT effluent limitations. However, costs and economic impacts did not result in
further subcategory separations from  those  defined, to account  for  disproportionate
economic impacts.

5.4    Proposed Industry Snhcategorization

In summary, after reviewing the current Subcategorization, EPA made several revisions. The
proposed revised Subcategorization is as follows:

       40 CFR Part 430

        • Subpart    A -   Dissolving Kraft Subcategory;
        • Subpart    B -   Bleached Papergrade Kraft and Soda Subcategory;
        • Subpart    C -   Unbleached Kraft Subcategory;
        • Subpart    D -   Dissolving Sulfite Subcategory;
        • Subpart    E -   Papergrade Sulfite Subcategory;
        • Subpart    F -   Semi-Chemical Subcategory;
        • Subpart    G -   Mechanical Pulp Subcategory;
        • Subpart    H -   Non-Wood  Chemical Pulp Subcategory;
        • Subpart    I -    Secondary Fiber Deink Subcategory;
        • Subpart    J -   Secondary Fiber Non-Deink Subcategory;
        • Subpart    K -   Fine and Lightweight Papers from Purchased Pulp Subcategory;
        • Subpart    L -   Tissue, Filter,  Non-Woven, and Paperboard from Purchased
                          Pulp Subcategory.

 The subcategory descriptions that form the basis of the proposed regulation are presented
 in the following paragraphs.
                                         5-26

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                                                                     5.0 Subcategorization
 5.4.1   Subpart A - Dissolving Kraft Subcategory

 This Subcategory includes production of a highly bleached and purified kraft wood pulp
 using  an alkaline sodium  hydroxide  and  sodium sulfide  cooking  liquor  with acid
 prehydrolysis. This pulp is used primarily for the manufacture of rayon, viscose, acetate and
 other  products  requiring a high percentage of  alpha cellulose,  a low percentage of.
 hemicelluloses, and a virtual absence of lignin.  This subcategoiy includes production at
 facilities that manufacture dissolving grade kraft pulps and papergrade kraft pulps at the
 same site.

 5.4.2   Subpart B - Bleached Papergrade Kraft and Soda Subcategory

 This subcategoiy includes production of a bleached kraft wood pulp  using an alkaline
 sodium hydroxide and sodium sulfide cooking liquor. Principal products include papergrade
 kraft market pulp,  paperboard, coarse papers, tissue papers, uncoated free sheet, and fine
 papers, which include business, writing, and printing papers.

 This Subcategory also includes production of bleached soda wood pulp using an alkaline
 sodium hydroxide cooking liquor. Principal products are fine papers, which include printing
 writing, and  business papers, and market pulp.

 5.4.3  Subpart C - Unbleached Kraft Subcategory

 This Subcategory includes production of kraft wood pulp without bleaching using an alkaline
 sodium hydroxide and sodium sulfide cooking liquor. Principal products include unbleached
 kraft market pulp, bag papers, and liner board (the smooth facing in corrugated  boxes).

 This Subcategory also includes production of both unbleached kraft and semi-chemical wood
 pulps at  mills with cross-recovery  processes.  Principal products  are similar  to  those
 produced at stand-alone unbleached kraft mills and stand-alone semi-chemical mills.

 5.4.4  Subpart D - Dissolving Sulfite Subcategoiy

 This subcategoiy includes production of  a highly bleached and purified sulfite wood pulp
 using acidic cooking liquors of calcium, magnesium, ammonium, or sodium sulfites  Pulps
 produced by this process are used  primarily  for the manufacture of rayon, cellophane
 methyl cellulose,  ethyl cellulose, nitra-cellulose, cellulose acetate, and other products that
 require a high percentage of alpha  cellulose,  a low percentage of hemicelluloses  and a
virtual absence of lignin. This subcategoiy includes production at facilities that manufacture
dissolving grade sulfite pulps and papergrade sulfite pulps at the same site.
                                        5-27

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                                                                 5.0 Subcategorization
5.4.5  Subpart E - Papergrade Sulfite Subcategory

This subcategory includes production of sulfite wood pulp, with or without brightening or
bleaching, using  an acidic cooking liquor of calcium, magnesium, ammonium, or sodium
sulfites. Principal products include tissue papers, fine papers, newsprint, and market pulp.

5.4.6  Subpart F - Semi-Chemical Subcategoiy

This subcategory includes production of pulp from wood chips under pressure using a variety
of cooking liquors, including but not limited to neutral sulfite semi-chemical (NSSC), suttur
free (sodium carbonate), green liquor, and Permachem®.  The cooked chips are usually (but
not always)  mechanically refined. Pulp is produced with or without bleaching. Principal
products include corrugating medium, paper, and paperboard. Production of both semi-
chemical wood pulp and unbleached kraft wood pulp at the same site using a cross-recovery
system is included in the Unbleached Kraft Subcategory.

5.4.7  Subpart G - Mechanical Pulp Subcategory

This subcategory includes production of stone groundwood, refiner mechanical,  thermo-
mechanical,  chemi-mechanical, and chemi-thermo-mechanical pulps.  Stone groundwood
and refiner mechanical pulps are produced using mechanical  defibration by either stone
grinders or steel refiners. Thermo-mechanical pulp (TMP) is produced using steam followed
by mechanical defibration in refiners.  Chemi-mechanical pulp (CMP) is produced using a
chemical cooking liquor to partially  cook the wood.  The softened wood fibers are further
processed by mechanical defibration using refiners. Chemi-thermo-mechanical pulp (CTMP)
is produced using steam foUowed  by chemical cooking and mechanical defibration in
refiners. Principal products include market pulp, newsprint, coarse papers, tissue, molded
fiber products and fine papers, including business, writing, and printing papers.

 5.4.8  Subpart H - Non-Wood Chemical Pulp Subcategory

 This subcategory includes production of non-wood  pulps from chemical pulping processes
 such as kraft, sulfite, or soda. Fiber furnishes include textiles (rags), cotton linters, flax,
 hemp, bagasse, tobacco, and abaca.  Principal products include market pulp, cigarette plug
 wrap paper, and other specialty paper products.

 5.4.9   Subpart  I - Secondary Fiber Deink Subcategory

 This subcategory  includes production of deinked  pulps from  wastepapers or paperboard
 using a chemical  or solvent process to remove contaminants such as inks, coatings, and
 pigments.  Deinked pulp is usually brightened or bleached.  Principal products include
 printing, writing, and business papers, tissue papers, newsprint, and deinked market pulp.

                                        5-28

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                                                                   5.0 Subcategorization
 For purposes of proposed New Source Performance Standards (NSPS), EPA divided this
 subcategory mto two segments.  Segment A comprises mills  that produce paperboard
 builders  paper or roofing felt.  Segment B comprises mills that produce other products'
 ihe decision to segment this subcajegory was based upon EPA's finding that many mills
 making paperboard, builders' paper  or roofing felt  operate  with complete  recycle of
 wastewater.  EPA lacked reliable data to indicate that mills  producing other products
 commonly operated with complete recycle, or that complete recycle of wastewaters was a
 demonstrated technology for producers of these other products.

 According to responses to the 1990 questionnaire and  other information, EPA concluded
 that 21 mil s in this subcategory operate with complete recycle of process wastewater. Of
 mese 21 mills, 15 mills manufacture paperboard from wastepaper, and six mills manufacture
 builders paper and roofing felt.  Complete recycle is defined as a system where the sum of
 fresh water and water entering the system in raw materials is equal to the  sum of water
 included in any rejects streams from screening, including sludges.  There is no direct or
 indirect discharge of wastewater to surface waters, nor is there any land application, surface
 impoundment or other land disposal of wastewater effluents.

 5.4.10  Subpart J - Secondary Fiber Non-Deink Subcategory

 This subcategory includes production of pulps from wastepaper or paperboard without
 demking.  Pulp ^ produced with o'r without brightening. Principal products include tissue,
 paperboard,  molded products, and construction papers.  Construction papers may be
 produced from cellulosic fibers derived from wastepaper, wood flour and sawdust, wood
 cnips, and rags.

 5.4.11 Subpart K - Fine and Lightweight Papers from Purchased Pulp Subcategory

This subcategory includes production  of fine  and lightweight papers produced  from
purchased virgin pulps or secondary fiber. Principal  products include clay coated printing

                             free sheet' cotton fiber
5.4.12  Subpart L  - Tissue, Filter, Non-Woven, and Paperboard from Purchased Pulp
       S                                                                         F
      Subcategory
This subcategory includes production of paperboard, tissue papers, filter
pul™
                                      * ""' *
                                                                 papers, non-woven
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                                                                 5.0 Subcategorization
5.5   Production Normalizing Parameters

Three different production normalizing parameters (PNPs) were used in the analysis of raw
and Seated waste loads. These PNPs are briefly discussed below as they apply to  each
regulation.

5.5.1  Conventional Pollutants

The generation of the conventional  pollutants  BOD5 and TSS  is related  to  pulping
bleachmg and papermaking processes. To analyze the generation and discharge of these
SSI fce Agency used off-machine metric  tons (OMMT)  of production (including
adSs and coatings, at off-the-machine moisture for paper and paperboard and  at 10
percent moisture for market pulp). This production is defined as the 1989 annual OMMT.
Sy production is the annual production divided by the number of ^operating .days of  he
paper machine during the year.  In its analysis of  conventional pollutant discharges, the
Agency assumed each mill operated 350 days per year.

 5.S.2  COD  and Color

 Wastewater  COD and color result primarily from pulp mill wastewaters as well as bleach

                                         -\=
                  .
               of the pulp mill during the year. In its analysis of COD and color discharges,
 the Agency assumed each pulp mill operated 350 days per year.

 5.5.3   Volatile and Chlorinated Pollutants

 2,3,7,8-Tetracmorodibenzo-p^^
 TCDF), chlorinated phenolic compounds, chloroform, methylene chloride, acetone, methyl
 ethyl ketone (MEK),  and adsorbable organic halides (AOX) are generated in the bleach
 plant of mills that bleach chemically pulped wood with chlorine-containing compounds To
 Lalyze the discharge of these pollutants from the bleach plant and in the future effluent
 the Agency used the  annual ADMT of unbleached pulp entering  he bleach plant (at 10
 percent moisture). Daily production is the annual production divided by the number of
 operatmg^days of the bleach line during the year. In its analysis of volatile and chlorinated
 pollutant discharges, the Agency assumed each bleach line operated 350 days per year.
                                         5-30

-------
                                                                5.0 Subcategorization
5.6

1.


2.
References

Dolloff, D. Comments Delivered at the EPA Public Meeting on the Rulemaking for
the Pulp, Paper, and Paperboard Industries, May 19, 1993.

U.S. EPA, Office of Water.  Development Document for Effluent Limitations
Guidelines - Best Practicable Control Technology Currently Available for the
Bleached'Kraft, Groundwood, Sulfite, Soda, Deink, and Non-Integrated Paper Mills
Segment of the Pulp, Paper, and Paperboard Mills Point Source Category.  EPA
440/1-76-047-b, U.S. Environmental Protection Agency, Washington, D.C., December
1976.

U.S. EPA, Office of Water.  Development Document for Effluent Limitations
Guidelines and New Source Performance Standards for the Unbleached  Kraft and
Semi-Chemical Pulp Segment of the Pulp, Paper, and Paperboard Mills Point Source
Category.  EPA 440/1-74-025-a, U.S. Environmental Protection Agency, Washington
D.C., May 1974.                                                           '

U.S. EPA, Office of Water.   Development Document for Effluent Limitations
Guidelines, New Source Performance Standards and Pretreatment Standards for the
Pulp, Paper, and Paperboard and the Builders' Paper and Board MiUs Point Source
Categories. EPA-440/1-82-025, U.S. Environmental Protection Agency, Washington
D.C., October  1982.                                                   *   '
                                     5-31

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                                                6.0  Water Use and Wastewater Characteristics
  6.0    WATER USE AND WASTEWATER CHARACTERISTICS

  This  section  describes water  use and  wastewater recycle  practices,  and the  general
  characteristics of wastewater at mills that manufacture pulp, paper, and paperboard in the
  U.S.  As described in Section 4.3, EPA's database includes information on 565 mills based
  on responses to the 1990  questionnaire and follow-up letters.  All pulp and papermaking
  processes require the use of water.  The pulp and paper industry is the largest industrial
  process water user in the  U.S.  Water use in the industry has decreased approximately 30
  percent since  1975, reflecting significant effort by the industry to reduce consumption and
  increase wastewater reuse and recycle (1).

  6-1    Water Use and Sources of Wastewater

 This section describes water use and sources of wastewater at mills that manufacture pulp
 paper, and paperboard in the U.S. All pulp and papermaking processes require the use of
 water; however, water use, wastewater sources, and wastewater characteristics for any mill
 are dependent upon the combination of raw material used, processes  used, and products
 manufactured.                                                              F

 Approximately 16 million cubic  meters  (m3) (4.25 billion gallons)  of  wastewater  are
 discharged daily by pulp, paper, and paperboard manufacturers. Approximately 84 percent
 ?i 7nn V°3U,mn1S discharfd directlv> and I* percent is discharged indirectly. Approximately,
 11,400m ( < 0.1 percent) of this  volume is disposed of daily by on-site land application   Of'
 the 565 U.S. mills included in EPA's  analysis, 319 are direct dischargers, 203 are indirect
 dischargers,  and  6 discharge both directly and  indirectly.   Mill  discharge statms   by
 subcategory,  is listed in Table 6-1.                                               '

 Water use and sources of wastewater generation from each major process in the industry
 are summarized in Table 6-2 and are reviewed below.  Industry-wide paper and paperboard-
 making processes discharge the greatest volume of wastewater (37  percent of the total
 discharge)    Bleaching and  pulping  operations  also contribute major portions of the
 wastewater flow discharged by the industry (21 and 16 percent, respectively), although only
 approximately 38 percent of all mills have pulping operations and approximately 30 percent
 have bleaching operations.                                                    F

 Table  6-3 includes the average  production-normalized flow discharged to treatment bv
process area and subcategory. The following conclusions can be made from the information
presented in Table 6-3:

       (1)    Mills in the Non-Wood Chemical Pulp Subcategory discharge the largest
             amount of wastewater per metric ton.
                                        6-1

-------
                                       6.0  Water Use and Wastewater Characteristics
(5)
     (2)    Mills in the Semi-Chemical Pulp Subcategory discharge the smallest amount
            of wastewater per metric ton.

     (3)    Dissolving kraft and dissolving suffite mills discharge more wastewater per
            metric ton than their papergrade counterparts, largely  because of more
            wastewater discharged from bleaching.

     (4)    Both dissolving suffite  and papergrade sulfite mills discharge more wastewater
            per metric ton than their kraft counterparts. Dissolving sulfite mills discharge
            more wastewater than dissolving kraft, largely because  of more wastewater
            discharged from bleaching.   Papergrade  sulfite  mills discharge more
            wastewater than bleached papergrade kraft mills, largely because  of more
            wastewater discharged from pulping, bleaching, and papermakmg.

            Unbleached kraft mills discharge about half as much wastewater per metric,
            ton as bleached papergrade kraft mills, because bleaching wastewater is not'
            generated and because less wastewater is discharged from pulping operations,
            possibly due to reduced pulp screening and cleaning requirements.

      (6)   Secondary fiber deink mills discharge more than twice as much wastewater
            per metric ton as secondary fiber non-deink mills,  largely because of increased
            water use and wastewater discharge from secondary fiber processing.

      (7)   Mills that manufacture final products from purchased pulp discharge two to
            three  times more wastewater per metric ton  in the  paper and paperboard
            making process than  rnills in other subcategories. This is primarily because
            these mills have fewer operations  in which to  reuse excess white water than
            mills that pulp wood  or process secondary fiber  on site.

6.1.1  Wood Preparation

Pulp mills that use logs as raw material may use water for three purposes to prepare wood
for pulping: log conveyance, log washing, and wet debarking.  Log washing is required to
remove dirt and silt that will abrade debarking equipment.  Wet debarking typically is
accomplished  by wet drum barkers or hydraulic barkers.  Approximately 2 percent of the
wastewater  discharged by  the  industry is generated  from wood preparation processes.
Wastewater generation rates range from 0.5 to  19.2 m'/CMMX of final product as shown
below:
                                   6-2

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                       Subcategory
                                                6.0  Water Use and Wastewater Characteristics
                                           Average Wastewater
                                        Generation Rate from Wood
                                         Preparation (raVOMMT)
      Dissolving Kraft
      Bleached Papergrade Kraft and Soda
      Unbleached Kraft
      Dissolving Sulfite
      Papergrade Sulfite
      Semi-Chemical
      Mechanical Pulping
                                                      7.2
                                                      1.8
                                                      0.5
                                                     19.2
                                                      3.1
                                                      1.3
                                                      5.2
 Mills that manufacture dissolving grade products use more water in wood preparation than
 mills that manufacture papergrade products, largely due to hydraulic debarking.

 6.1.2  Pulping

 Water use and sources of wastewater for pulping  vary according to  the specific type of
 pulping process performed, as described below.
 6.1.2.1
Chemical Pulping
 In all types of chemical pulping, wood chips are cooked in a digester in an aqueous chemical
 solution, at elevated temperature and pressure.  After cooking,  the digester pressure is
 released and the pulp is washed to remove pulping chemicals and soluble wood components
 Washed pulp is screened and deckered (thickened) to storage consistency, typically 4 to 10
 percent. Water is used as a solvent for cooking chemicals, as the pulp cooking medium as
 pulp wash water, and as a diluent for screening, cleaning, and subsequent pulp processing
 Most chemical pulping processes collect, evaporate, and incinerate the concentrated pulping
 liquors  to recover pulping chemicals. Wastewater sources from chemical pulping include
 digester relief and blow condensates, wastewater from the screen room, cleaners  deckers
 and  spills from the digester area where  inadequate spill control and containment are
practiced.

Commonly practiced water conservation measures include reusing screen room, cleaner or
decker filtrates for pulp washing (i.e., "closed" processes).  These measures not only reduce
makeup water requirements but also reduce wastewater pollutant loads and improve energy
efficiency because more pulping chemicals and dissolved wood components are captured in
the chemical recovery system.
                                        6-3

-------
                                               6.0  Water Use and Wastewater Characteristics
Approximately 15 to 20 percent of the wastewater discharged by chemical pulping mills is
generated from the pulping processes. Wastewater generation rates range from 7.5 to 34.3 -
m3/OMMT of final product as shown below:
                      Subcategoiy
                                           Average Wastewater
                                          Generation Rate from
                                            Chemical Pulping
                                              (m3/OMMT)
     Dissolving Kraft
     Bleached Papergrade Kraft and Soda
     Unbleached Kraft
     Dissolving Sulfite
     Papergrade Sulfite
     Non-Wood Chemical
                                                     28.0
                                                     16.4
                                                      7.5
                                                     29.8
                                                     34.3
                                                     31.9
 6.1.2.2
Mechanical Pulping
 In the stone groundwood process, logs or billets are pressed against large rotating stone
 grinders to produce pulp. In the refiner mechanical pulp process (and its modifications),
 wood chips are forced between pairs  of rotating grooved  steel plates  called refiners
 Modifications of the refiner mechanical pulp process include presteaming of the chips with
 and without additional chemicals and cold soaking of the chips in caustic soda. All of these
 mechanical pulping processes use water as a coolant, as a carrier to sluice pulp from the
 body of the grinder, and as  a diluent for subsequent pulp screening and  cleaning steps.
 Refiner mechanical pulping also uses water to wash or otherwise pretreat the chips betore
 refining   Approximately 17 percent of  the wastewater discharged by mechanical pulping
 mills is generated from the pulping processes.  Pulping wastewater is generated at a typical
 rate of 10.3 m3/OMMT of final product.
 6.1.2.3
 Secondary Fiber Processing
  The first step in secondary fiber pulping (or repulping) is to solubilize the furnish (waste
  paper old newspapers, cardboard, etc.) in water.  Wood fibers are then separated from
  undesirable contaminants by physico-chemical means. When deinking is not necessary the
  contaminants are removed physically (sedimentation, flotation, and filtration).  Deinking
  requires adding surfactant chemicals such as detergents, dispersants, and foaming agents to
  facilitate the physical separation of ink particles from fiber. The wastewater that contains
  contaminants is further  treated to  remove  or concentrate the contaminants  and the
                                          6-4

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                                                6.0  Water Use and Wastewater Characteristics
 recovered process water is reused in the repulping process.  Excess water is discharged to
 wastewater treatment.

 Approximately 30 to  50 percent of the wastewater discharged by secondary fiber mills is
 generated from the secondary fiber processing. Wastewater generation rates are typically
 8.9 m /OMMT of final production for non-deink mills and 40.3 m3/OMMT for deink mills.

 6.1.3   Chemical Recovery

 Water use and sources of wastewater for chemical recovery vary according to the specific
 type of chemical recovery operations performed.

 At kraft mills, pulping liquors are washed from the brown stock pulp and  recycled to the
 chemical recovery system.  The pulp wash water is known as weak black liquor and typically
 contains 14 to 16  percent liquor solids. The weak black liquor is concentrated to typically
 more than 60 percent liquor solids in multi-stage evaporators.  The condensates from the
 evaporators comprise  the excess water resulting from liquor concentration.  At most mills,
 evaporator condensates are reused in other mill processes. Excess condensate is discharged
 to wastewater treatment.   Depending upon  where  the  condensates  are  drawn  off the
 evaporator set, they may be foul (containing high levels of TRS, methanol, and acetone) or
 relatively clean and suitable  for  reuse in several  hot  water applications  including pulp
 washings.  Foul condensates  may also be reused after steam  stripping  to remove TRS
 methanol, and acetone.

 During the recovery  of kraft pulping chemicals, water  is  also 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 is  reused in the
 recovery cycle to dissolve recovery furnace smelt and as a scrubbing medium in air emission
 control scrubbers.   Excess weak wash is discharged  to wastewater treatment.

 Although recovery of pulping chemicals is not practiced  at sulfite mills as  extensively as at
 kraft mills, sulfite pulp wash water (weak red liquor) is evaporated, generating an evaporator
 condensate wastewater. At most sulfite mills, evaporator condensate is reused in other mill
 processes with the excess condensate discharged to wastewater treatment. Concentrated red
 liquor is burned to recover heat, sulfur, or both sulfur and base. Magnesium sulfite mills
 use water to wash and slake the ash formed from burning  red liquor, and discharge the wash
 water to wastewater treatment.   Calcium-  and sodium-base weak liquors may also be
 processed to recover by-products such as lignin chemicals, yeast, and alcohol; because a
 recovery system is  not  used, recovery system wastewaters are not generated  (2).

Approximately 5 to 12 percent of the wastewater discharged by chemical pulping mills is
generated from chemical recovery.  Wastewater generation rates range from 2.5 m3/OMMT

                                        6-5

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                                              6.0  Water Use and Wastewater Characteristics
Of final production for semi-chemical mills to 18.1 m3/OMMT for dissolving sulfite mills as
shown below:
                      Subcategory
 Average Wastewater
Generation Rate from
 Chemical Recovery
    (mVOMMT)
     Dissolving Kraft
     Bleached Papergrade Kraft and Soda
     Unbleached Kraft
     Dissolving Sulfite
     Papergrade Sulfite
     Semi-chemical
     Non-wood Chemical
           12.4
            8.8
            4.2
           18.1
           10.4
            2.5
           12.8
 6.1.4  Bleaching
                                                                I
 Pulp bleaching is a multi-stage process that uses different chemicals and conditions in each
 stage with washing performed between stages. Washing removes bleaching chemicals and
 any dissolved wood components extracted during bleaching. Chlorine-containing compounds
 (chlorine chlorine dioxide, and hypochlorites) are the most widely used bleaching chemicals.
 Primary water use is for interstage pulp washing.  Secondary water uses include preparation
 of bleach chemical solutions and in air emission control scrubbers.   The high chloride
 content of bleaching wastewaters makes them incompatible with pulping chemical recovery
 processes so they are discharged to wastewater treatment.  For this reason, elimination ot
 chloride from bleaching will enable recovery of bleaching wastewater to be practiced.

 Approximately  30 to 50 percent of the wastewater discharged by bleaching chemical pulp
 mills is generated from the bleaching processes.  Wastewater generation rates range from
 13.7 m3/OMMT  of final  production  for the Non-Wood Chemical Subcategory to 113.4
 m3/OMMT for dissolving sulfite as  shown below:
                                          6-6

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                                                6.0  Water Use and Wastewater Characteristics
                      Subcategory
 Average Wastewater
Generation Rate from
      Bleaching
    (m3/OMMT)
      Dissolving Kraft
      Bleached Papergrade Kraft and Soda
      Dissolving Sulfite
      Papergrade Sulfite
      Non-Wood • Chemical
          68.7
          27.3
         113.4
          65.8
          13.7
 6.1.5  Pulp Handling and Papermaking

 In preparation for papermaking, pulp is suspended in water and mechanically conditioned
 in beaters or continuous  refiners.  Chemical additives are added either before or after
 beating ^d refining. Water is added to farther dilute the pulp and transport it to the paper
 machine.  Water that drains from the wet end of the paper machine is known as white
 water, and is largely captured and reused in stock preparation or on the  machine  after
 removal of entrained solids by savealls. White water may also be recycled to the woo'dyard

                       washers and bleach line washers- Excess white
Approximately 40 percent of the wastewater discharged by the industry is generated from
pulp  handling  and   papermaking  processes.    Wastewater  generation   rates  for
paper/paperboard making range from 8.5 m3/OMMT of final production for pulp produced

"^
                                       6-7

-------
                                             6.0  Water Use and Wastewater Characteristics
                    Subcategory

    Dissolving Kraft
    Bleached Papergrade Kraft and Soda
    Unbleached Kraft
    Dissolving Sulfite
    Papergrade Sulfite
    Semi-chemical
    Mechanical Pulping
    Non-Wood Chemical
    Secondary Fiber Deink
    Secondary Fiber Non-deink
    Fine and lightweight Paper from
      Purchased Pulp
    Tissue, Filter, Nonwoven, and
      Paperboard from Purchased Pulp
   Average Wastewater
Generation Rate from Pulp
Handling and Papermaking
       (m3/OMMT)

             11.9
             23.2
             17.5
               8.5
             53.7
             12.9
             30.9
             329.2
             30.0
             21.7
              64.2
              60.2
63,   Water Reuse and Recycle

This section describes water reuse and recycle at mills that manufacture pulp,'paper, and
paperboard in the U.S.  Water reuse and recycle are common practices ^ most pulp and
Lpermaking processes, primarily for recovery of fiber, heat, pulping chemicals, and other
chemkal additives that aW contained in wastewater.  The degree to which water reuse and
rSe is practiced at a mill is dependent upon the mill's raw materials processes and
products 
-------
                                                6.0  Water Use and Wastewater Characteristics
 6.2.2  Pulping

 Water reuse and recycle in pulping operations vary according to the specific type of pulping
 process performed. In mechanical pulping operations, water consumption is reduced by
 reusing diluent water from screening and cleaning in grinding or refining processes.  Water
 conservation measures commonly practiced in chemical pulping processes include reusing
 screen room, cleaner, or decker filtrates for pulp washing (i.e., "closed" processes). "Closing"
 the screen room not only reduces makeup water requirements but also reduces wastewater
 pollutant loads because pulp wash water  is captured and sent to the chemical recovery
 system.  Most chemical pulp mills also utilize countercurrent pulp washing, where water
 from later washing stages is reused as wash water in earlier washing stages.

 The extent of water reuse and recycle in secondary fiber processing varies greatly from mill
 to mill. Some mills do not reuse any water within secondary fiber processing, and virtually
 all water applied in secondary fiber washing is discharged to wastewater treatment.  Other
 mills operate completely closed systems in which water reused within the process and
 recycled white water satisfy most of the repulping and washing water requirements  for
 secondary  fiber processing.  Section 6.2.6 discusses in greater detail secondary fiber mills
 that operate with zero discharge of process wastewater.

 6.2.3   Chemical Recovery

 Multi-stage evaporators generate evaporator condensates of varied quality.  The most
 contaminated evaporator condensates from kraft mills are referred to as "foul" condensates
 and are generally unsuitable for most fresh hot water uses. Steam stripping foul condensates
 to remove volatile organic and reduced sulfur contaminants is usually a prerequisite to reuse
 the condensates in wood preparation and pulp washing.  Virtually all mills recycle clean
 evaporator condensates as makeup water to the final pulp washing stage.  Some mills also
 recycle clean evaporator condensates to screening and cleaning processes and to the decker.

 In the kraft chemical recovery process, weak wash from washing green liquor dregs and lime
 mud is reused in the recovery cycle to dissolve recovery furnace smelt.  Weak wash  is also
 often used  as a scrubbing medium in air pollution control devices.

 6.2.4   Bleaching

 Reusing wash water from later bleaching stages in earlier stages (countercurrent and jump
stage  washing)  is commonly practiced to reduce the water consumed in bleaching.  These1
flow reduction practices are described in Section 8.4.4. Reusing paper machine white water
as bleaching washwater is also frequently performed  to reduce  total  mill wastewater
discharge.
                                        6-9

-------
                                               6.0 Water Use and Wastewater Characteristics
Some foreign sulfite mills that operate totally chlorine-free bleach plants have significantly
reduced the amount of wastewater discharged from the bleaching area. This is achieved by
either recycling bleaching wastewaters to the chemical recovery system or by evaporating
and incinerating the bleaching wastewaters for heat recovery. These technologies are not
applicable  to  mills that bleach with chlorine or chlorine derivatives because the high
chloride  content of their bleaching wastewater is incompatible with pulping chemical
recovery processes.

6.2.5  Pulp Handling and Paper-making

All mills recycle rich white water from the wet end of the paper machine to recover and
recycle valuable fiber.  Most mills also capture limited amounts of lean white water for
reuse in other areas of the papermaking process (e.g., machine showers and vacuum pumps),
in stock preparation, and in bleaching; however, the extent to which white water is reused
varies significantly from mill to mill. Section 8.4 describes  specific papermaking process
areas to which white water can be recycled.

62.6   Complete Wastewater Recycle

Twenty-eight  mills surveyed  in the  1990  census  of  pulp,  paper,  and paperboard
manufacturing facilities reported that  they were  able  to  discharge  no wastewater  by
completely recycling their wastewater. Complete recycle is defined as a system in which the
sum of fresh water and water entering the system in raw materials is equal  to the sum of
water exiting the system via evaporation/vaporization, water in the final product, and water
included in any rejects streams from screening, or other dewatered sludges.   Of the 28
"complete  recycle" mills, 15 mills manufacture paperboard  from wastepaper and 6 mills
manufacture builders' paper and roofing felt. The remaining 7 mills manufacture a variety
of final products from either non-deinked secondary fiber (6 mills)  or semi-chemical pulp
manufactured on site (1 mill).

Due to limited data provided in responses to the 1990 questionnaire, the Agency was unable'
to determine whether "complete recycle" mills generate similar or significantly less or greater
amounts of  dewatered sludge than their  directly discharging counterparts.   However,
"complete recycle" of wastewater does not include mills that dispose of wastewater in dilute
sludge streams.

 Using information collected during EPA's  1990 census, the Agency compared total 1989
production, final products, fiber furnish, process  operations, and water use  between mills
 that discharge process wastewater directly or indirectly and mills with complete wastewater
 recycle. The  Agency also obtained additional information from 30 mills (11 that completely
 recycle  wastewater and 19  direct dischargers)  that  make  paperboard  from  corrugating
 medium (a specific type of wastepaper used  by  12 of the 15 complete  recycle mills that

                                         6-10

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                                                 6.0  Water Use and Wastewater Characteristics
  manufacture  paperboard  from wastepaper)  to  determine why some mills  continue to
  discharge wastewater while others do not. To simplify the analysis, the Agency evaluated
  data from mills that manufacture only paperboard from wastepaper, or builders' paper and
  rooting felt. The results of these analyses are discussed below.

  Tables 6-4 and 6-5 compare, by discharge status, mills that manufacture only paperboard
  from wastepaper, or builders' paper and roofing felt, respectively.  Although most of these
  mills discharge wastewater indirectly, 10 percent completely recycle wastewater
  6.2.6.1
 Production Rate and Final Products
 Because materials that some mills discharge with process wastewater may be incorporated
 into the product at complete recycle mills, the final product manufactured may determine
 whether complete recycle is feasible. As indicated by the responses from direct dischargers
 during telephone contacts,  quality demands for some products may preclude high levels of
 recycle.  Therefore, the Agency assessed the differences in production rates and products
 made at mills that  completely recycle, directly discharge, and indirectly discharge process
 wastewater. Tables 6-4 and 6-5 show that average mill final production is less at mills that
 completely recycle wastewater than at mills that directly or indirectly discharge wastewater
 however, the ranges of total final production overlap.

 Although  mills were not  requested in the 1990  questionnaire to  report  the specific
 paperboard products they manufactured, the 1992 Lockwood Post's Directory of the Pulp,
 Paper and Allied Trades lists chipboard, partition board,  and boxboard among the products'
 tor mills that manufacture paperboard from wastepaper, and asphalt paper and sheathing
 among the products for mills that manufacture builders'  paper and roofing felt, regardless
 of discharge status.  One direct discharger that manufactures builders' paper and roofing felt
 also  produces insulation board  and acoustical products.  Based on  these analyses the
 Agency  determined that there is no significant  difference in production rate and  final
 products between mills that completely recycle, indirectly discharge, and directly discharge
 6.2.6.2
Fiber Furnish
Because secondary fiber processing of certain fiber furnishes may require high quality water
the fiber furnish used at a mill may affect the feasibility of complete wastewater recycle'
Fiber  furnish for mills  that manufacture  paperboard from  wastepaper,  regardless of
discharge status, include old and  new corrugating medium, printed news, bleached  and
brown kxaft and mixed wastepaper. Fiber furnish for mills that manufacture builders' paper
and roofing felt  regardless of discharge status, include old corrugating medium and printed
news.  Direct discharge mills that manufacture builders' paper and roofing felt also  use
boxboard cutting and mixed wastepaper as fiber furnish. Based upon these analyses,  the

                                        6-11

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                                               6.0  Water Use and Wastewater Characteristics
Agency determined that there is no significant difference in fiber furnish between mills that
completely recycle, indirectly discharge, and directly discharge wastewater.

6.2.6.3       Process Operations and Water Use and Recycle/Reuse

The Agency analyzed water flow schematics submitted in response to the 1990 questionnaire
to determine why some mills continue to discharge wastewater while others do not. EPA
reviewed the water flow schematics to identify which processes generate wastewater and how
the wastewater is managed (e.g., recycled to other processes  or discharged to wastewater
treatment).

Figures 6-1 and 6-2 are generic process flow diagrams for mills that manufacture paperboard
from wastepaper.  Figure 6-1 is  a diagram for mills that discharge wastewater and Figure
6-2 is a diagram for mills that do not discharge wastewater.  Figures 6-3 and 6-4 are generic
process flow diagrams for mills that manufacture builders' paper and roofing felt.  Figure
6-3 is a diagram for mills that discharge wastewater and Figure 6-4 is  a diagram for mills,
that do not discharge wastewater. A comparison of the generic process flow  diagrams for
mills that discharge wastewater with those for mills that completely recycle wastewate(r does
not indicate significant differences in process units or operations. In general, the same types
of wastestreams are generated; however, the mills  that completely recycle wastewater treat
and reuse  the wastestreams  rather  than combine them  for wastewater treatment and
discharge.

For example, direct discharge mills  that manufacture paperboard from wastepaper may
screen and clarify wastewater from stock preparation, recycle part of the clarified wastewater
to stock preparation,  and discharge, the remaining wastewater to  wastewater treatment
Some direct discharge mills recycle effluent from wastewater treatment to the paperboard
process.  In contrast, a mill with complete recycle may recycle the  clarified wastewater to
 stock preparation and to the paper machine or to pulping (via water storage).

 Complete recycle mills perform additional process wastewater screening or cleaning steps
 on wastewater from each process area, particularly pulping and paper making. Complete
 recycle mills recycle all paper machine lean white water  through a white water chest and
 saveall to the paper machine. These mills also recycle wastewater to more process areas
 than mills that discharge wastewater, most  notably to utilities.
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                                                 6.0 Water Use and Wastewater Characteristics
  The average production normalized flows discharged directly and indirectly vary significantly
  as shown below:                                                                  J'
      Number of Mills
      Range of Discharge Flow
      (m3/OMMT)
      Average Discharge Flow
      (m3/OMMT)
                                          Paperboard from
                                            Wastepaper
                                         Direct
  24
0.4-127
  18
           Indirect
                                                      58
0.4-8,267
  148
                       Builders' Paper
                      and Roofing Felt
            Direct
              2
3-20
 11
                                                                        Indirect
                                                                           1-5
 While the reason for the difference in rate of water use by direct and indirect dischargers
 is  not  known,  the  Agency believes that the cost of wastewater  treatment for  direct
 dischargers is an incentive for water  conservation and  recycle.   Section 8.4  describes
 technologies used by mills to reduce wastewater discharge via increased water recycle and
 reuse.                                                                      J
 6-3    Wastewater Characterization - Conventional Pollutants

 6.3.1  Background and Definitions
 The Clean Water Act of 1977 defined four conventional pollutants or pollutant parameters-
 5-day biochemical oxygen demand (BOD5), total suspended solids (TSS), PH  and fecal
 conform.  The Agency  later defined  an additional  pollutant, oil  and grease  as  a
 conventional pollutant under procedures established in Section 304 of the Clean Water Act
 Effluent limitations were established in 1976 and 1982 for the control of BOD5  TSS and
 pH in discharges from the pulp, paper, and paperboard industry based on BPT  The Aeencv
 is proposing revisions to the BPT effluent limitations guidelines for BOD5 and TSS Fecal
 cohform and oil and grease have not been identified as pollutants of concern in the Pulp
 Paper  and Paperboard Point Source  Category.  Accordingly,  the  prior and  proposed
 regulations do not contain effluent limitations for fecal coliform or oil and grease.
™ltt             -    u    meth°dS Whlch are aPPlicable to each conventional
pollutant, Section 13.0 describes these methods. This section summarizes analytical data for
the conventional pollutants BOD5 and TSS that were reported by industry in the 1990
questionnaire.                                                         J
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                                              6.0  Water Use and Wastewater Characteristics
6.3.1.1
BOD,
BOD5  is a measure of the oxygen required by microorganisms to oxidize  the  organic
contaminants in a water sample under standard laboratory conditions.  EPA Method 405.1
describes the measurement of BOD5 at standard test conditions of 20°C over five days.
6.3.1.2
TSS
TSS consist of the non-filterable residue which are retained by a glass fiber filter and dried
to constant weight at 103-105°C.  EPA Method 160.2 is used to measure TSS.

6.3.2  Sources of Information

Calendar year 1989 data obtained from the 1990 questionnaire are presented in this section.
These data included:

             Average daily flow (m3/day);
             Average daily BOD5 concentration (mg/L);
             Average daily BOD5 mass loading (kg/day);
             Average daily TSS concentration  (mg/L); and
             Average daily TSS mass loading (kg/day).

The data were reported for each month of 1989 measured at one or more of the following
locations throughout the wastewater treatment system:

              Influent-to-primary;
              Primary effluent;
              Influent-to-secondary;
              Secondary effluent; and
              Final  effluent.

 Most facilities provided final effluent data; however, much less  influent-to-treatment and
 internal treatment system data were provided.

 The monthly average daily mass loadings and monthly average  daily flow were averaged
 over twelve months to obtain the long-term average daily mass loadings (kg/day) and the
 long-term average daily flow (m3/day). The long-term average daily mass loadings and daily
 flows were each production normalized by dividing by the total annual production expressed
 as off-machine metric tons per year (OMMT/yr)  and multiplying by 350 days per year, the
 typical number of mill production days per year, to determine the long-term average annual
 mass loadings.
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                                                 6.0  Water, Use and Wastewater Characteristics
  6.3.3   Current Discharge Loadings

  The long-term average annual final effluent mass loadings of BOD5 and TSS, calculated as
  described above, were used to estimate the  current total industry discharge loading  For
  direct  discharging mills,  this represents  the load to receiving streams   For  indirect
  discharging mills, this represents the load to POTWs.

  Four direct discharging mills and 68 indirect discharging mills did not report the  mass  of
  conventional pollutants they discharged.  Mass loads were estimated for these mills by
  transferring the reported production normalized load from a mill with similar products and
  processes. The transferred production normalized load (kg/OMMT) was multiplied by the
  production of  the  miU that did not report  loads  (OMMT/yr) to estimate the mass of
  pollutants discharged by the non-reporting mill (kg/yr).

  In 30 cases where more than one mill discharged to a shared wastewater treatment system
  the  total treatment system discharge load was apportioned by production to each  mill
  sharing the treatment system.  In eight cases where a mill shared wastewater treatment with
  a chemical plant or another facility not regulated by this rulemaking, the total discharge load
 was assigned to the mill when the pollutant loadings  from the non-category facility were not
 expected  to be significant.  When the  greatest contribution to pollutant  loadings  was
 e                 n°n'CategOry fa!cility' the total di^harge load was assigned  to the non-
 The estimated industry-wide 'discharge of conventional pollutants is shown below:
        Number of
        Mills
        BOD,
        TSS
        Total
                            Direct Discharge
                              (billion kg/yr)
322
0.18
                                  0.27
0.45
                    Discharge to POTWs
                     (indirect discharge)
                       (billion kg/yr)
                            202
                                                              0.91
                                                              1.37
                                                             2.28
The Agency tabulated  the  production normalized current discharge loadings  for mills
selected  to represent  the  performance  of secondary  wastewater  treatment  in each
subcategory, as described in  Section 9.2. The current conventional pollutant mass loadings
                                        6-15

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                                              6.0  Water Use and Wastewater Characteristics
of these 152 direct discharging mills were selected to represent wastewaters characteristic
Of production within each subcategory.   Table  6-6  summarizes  average production
normalized BOD5 and TSS discharge loadings by subcategory.

6.3.4  Estimate of Raw Waste Loads

The approach used to estimate the  current industry discharge loading, described in 6.3.3
could not be used to estimate industry-wide raw waste loads, because most mills do not
monitor (and thus did not report) the mass loading of their raw wastewater. Some mil s
Sported mass loadings into treatment, but because not all of the wastewate^ at the mill is
treated the total raw waste load is still unknown. For these reasons the Agency back-
Saed raw waste loads from reported final effluent discharge loads  andf average
treatment performance achieved by the industry. Industry average treatment performance
is summarized below:
            Wastewater Treatment System
      None
      Primary Only
      Primary Followed by Secondary Using
      Aerated Stabilization Basins
      Primary Followed by Secondary Using
      Activated Sludge          	
      Primary Followed By Secondary Using
      Both Aerated Stabilization Basins and
      Activated Sludge
                                                BOIX fteittoval
                                                       o
                                                      57.6
86.1
89.6
89.3
           TSS Removal
                 0
                93.2
89.4
92.2
94.7
 These performance levels were determined using the following methodology.  The Agency
 first determined which mills provided data for influent-to-primary treatment (i.e.,. which mills
 completed Table G of the 1990 questionnaire). The Agency then eliminated mills that did
 not treat all of their wastewater through all units of their treatment system by eliminating
 mills for which the average daily influent-to-treatment flow (i.e., the average of Row (2) of
 Table G of the 1990 questionnaire) differed from the average daily final effluent flow (i.e.,
 the average of Row (2) of Table K of the 1990 questionnaire) by more than 10 percent.
 Treatment performance achieved by the remaining 98 mills was calculated by comparing the
 BOD5 and TSS average loads reported for influent-to-primary (Rows (6) and (10) ot lable
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                                               6.0  Water Use and Wastewater Characteristics
 G) with those reported in final effluent (Rows (6) and (10) of Table K). The mills were
 then classified by treatment system as shown below.
Wastewater Treatment System
Primary Only
Primary Followed by Secondary Using Aerated
Stabilization Basins
Primary Followed by Secondary using Activated
Sludge
Primary Followed by Secondary using Aerated
Stabilization Basins and Activated Sludge
Number of Mills
13
38
37
10
The average treatment performance achieved by each group of mills was determined by
calculating the average  percent BOD5 and TSS removals achieved by the  mills in each
group.

After industry-average treatment performances were determined, they were applied to the
reported (or estimated)  discharge load for each  mill, based only on the type of treatment
used at each mill.  The raw waste loads estimated for each mill were summed to estimate
the industry-wide raw waste load of conventional pollutant as shown below:

Number of Mills
BOD5
TSS
Total
========!
Raw Waste Load
from Direct
Discharging Mills
(billion kg/yr)
322
1.38
3.09
4.47
,.
Raw Waste Load
from Indirect
Discharging Mills
(billion kg/yr)
202
1.09
2.11
3.20
i— - 	 in 	 -.
Industry Total
(billion kg/yr)
524
2.47
5.20
7.67
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                                               6.0  Water Use and Wastewater Characteristics
The calculation of the industry-average treatment performance did not take into account any
differences that may exist in the treatability of wastewaters from production processes in
different subcategories. Therefore, the Agency has not attempted to estimate raw waste
loads by subcategory.
6.4
Wastewater Characterization - Priority and Nonconveiatinnal Pollutants
6.4.1   Background and Definitions
                                                                 I
Section 301(b)(2) of the CWA gives the EPA Administrator the authority, and obligation
to develop effluent limitations guidelines for toxic pollutants identified in Section 307(a)(l)
(see Title 40, Code of Federal Regulations, Section 401.15). This list of toxic pollutants was
later expanded to include a total of 126 pollutants, commonly known as priority pollutants
(see Table 6-7 or 40 CFR Part 423, Appendix A).  The priority pollutants include specific
compounds in many  chemical categories:   2,3,7,8-tetrachlorodibenzo-p-dioxm  (2,3,7,8-
TCDD) selected chlorinated phenolic compounds, volatile organic compounds, semi-volatile
organic compounds, pesticides, herbicides, metals, and inorganics.  Additional compounds
not designated as priority pollutants but  that exhibit toxic effects to aquatic life and the
environment  are  considered nonconventional pollutants  in  this discussion;  Sections
301(b)(2)(F)  and 301(g) give the EPA  Administrator the authority  to  regulate these
compounds if warranted. For this proposed regulation, nonconventional pollutants are those
that are not priority pollutants and not conventional, and include most  of the chlorinated
phenolic compounds,  certain volatile organic compounds, 2,3,7,8-tetrachlorodibenzofuran
(237 8-TCDF), adsorbable organic halides  (AOX), chemical oxygen demand (COD), and
color.' This section describes  each chemical category of priority and nonconventional
pollutants.

The Agency has developed analytical methods applicable to each category of priority and
 nonconventional pollutants; these methods, and detection limits, are briefly described below
 and are described further in Section 13.0. The analytical methods can identify most of the
 priority pollutants and additional nonconventional pollutants within each chemical category.
 Appendix B identifies the compounds within each chemical category that can be analyzed
 by each method.

 This section summarizes analytical data and mass loadings for priority and nonconventional
 pollutants that have been coUected primarily through EPA sampling programs at U.S. pulp
 and paper mills.  Other data were collected from the 1990 questionnaire, questionnaire
 follow-up letters, and from mills in other countries. Sections 6.4.2 through 6.4.8 summarize.
 information from mills that chemically pulp and bleach wood. Section 6.4.9 summarizes,
 information from pulls that bleach semi-chemical pulps, mechanical pulps, secondary fibers,
 and other pulps (e.g., non-wood pulp) with chlorine and/or chlorine derivatives.
                                         6-18

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                                                 6.0  Water Use and Wastewater Characteristics
  6.4.1.1
Chlorinated Dioxins and Furans
  Chlorinated   dibenzo-p-dioxins  and  chlorinated  dibenzofurans  (CDDs  and  CDFs
  respectively) are closely related families of highly toxic and persistent organic chemicals
  which are formed as  unwanted  by-products in some commercially significant chemical
  reactions, during high-temperature decomposition and combustion of certain chlorinated
  organic chemicals, and through other reactions involving chlorine  and organic materials
  (3,4,5 6,7,8).   In the pulp and paper industry, CDDs and CDFs are formed during pulp
  bleaching where  chlorine and chlorine derivatives are used.   There  are  210 related
  CDD/CDF  chemical  compounds (congeners1) with varying  chemical,  physical  and
  toxicologic properties.                                                          '

  The congener that appears to be the most toxic and has generally raised the greatest public
  o??o 55S1? 1S 2'3'7'8-TCDD-  EPA has been conducting a scientific reassessment of
  2,3 7 8-TCDD for several years (9,10), including a review of exposure assessment procedures
  and health assessment issues. The results of that review may be available after proposal of
 this regulation. Notwithstanding the results of that review, 2,3,7,8-TCDD is a designated
 priority pollutant for which technology-based effluent limitations guidelines  and  standards
 are required by the CWA.

 CDDs and CDFs with chlorine substituted at the 2,3,7, and 8 positions are considered more
 biologically active  and  more toxic than CDDs and CDFs that are not chlorinated at the
 2 3,7, and  8 positions (11,12). EPA Method 1613, Revision A, can be used to analyze the
 17 tetra- through octa-substituted congeners that are chlorinated at the 2,3,7, and 8 positions
 (prior to, 1989, EPA Method 8020, Revision E was used). Method  1613 can also be used
 to  analyze for only 2,3,7,8-TCDD and 2,3,7,8-TCDF.

 For each method and analyte, EPA determines a method detection limit (MDL) which is
 the minimum concentration  of a substance that can be measured  and reported with 99
 percent confidence that the analyte concentration is greater than zero and is  determined
 rrom analysis  of a sample in a given matrk  containing the analyte (see 40 CFR  Part 163'
 Appendix B).  From an MDL, EPA determines a minimum level (ML) which is  the level
 at which the analytical system gives recognizable signals and an acceptable calibration point
 For Method 1613, these limits usually depend upon sample matrk interferences rather than
 instrument limitations. The ML established  for several CDD and CDF studies in the pulp
 and paper industry have been 10 pg/L (ppq) for 2,3,7,8-TCDD and 2,3,7,8-TCDF in liquid
 samples and 1 ng/kg (ppt) for 2,3,7,8-TCDD and 2,3,7,8-TCDF in solid matrices (pulp and
   'The term "congener" refers to a specific compound within the same chemical family (e.g., there are 75
congeners of cMormated dibenzo-p-dioxins (CDDs)). The term "homologue" refers to a group of structurally
      Cem    f1  r ^T6 ^ °f cWorinati0'1 ^ <*« are eight homologLof CDDs    "
             through octachlorinated).
                                        6-19

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                                              6.0 Water Use and Wastewater Characteristics
wastewater treatment sludge).  MLs for higher chlorinated 2;,3,7,8-substituted CDDs and
CDFs in liquid samples are 50 pg/L (ppq) for penta- through hepta-substituted congeners
and 100 pg/L for octa-substituted congeners. Depending upon sample matrix.interferences
and other factors, achievable limits are sometimes greater than the established minimum
levels.
6.4.1.2
Chlorinated Phenolic Compounds
All chlorinated phenolic compounds share the basic structural unit of the phenol molecule
and have varying chemical, physical, and toxicologic properties.  Thirty-three chlorinated
phenolic compounds were investigated, including chlorinated phenols chlorinated catechols,
chlorinated guaiacols, chlorinated syringols, and chlorinated benzaldehydes ^,vamllms
and syringaldehydes). Twenty-eight of these compounds are analyzed using EPA Me hod
1653 (including seven chlorinated phenolic compounds on the priority pollutant list that are
also semi-volatiles and can be analyzed using Method 1625C). In some short-term sampling
episodes, NCASI analytical methods (upon which Method 1653 was based) were used and
included five chlorinated phenolics that are not analyzed by Method  1653. The detection
limit of the method usually depends upon interferences rather than instrument limitations.
For this method, MLs have been determined to be 1.25,2.50, or 5.00 ug/L (ppb), depending
upon the specific compound.

 6.4.1.3      Volatile Organic Compounds

 Fifty-seven volatile organic compounds (VOCs) were investigated, including both chlorinated
 and non-chlorinated compounds. Certain VOCs (e.g., acetone and methyl ethyl ketone) are
 attributable to chemical pulping operations, while others (e.g., chloroform) are associated
 with bleach plant operations. VOCs are analyzed using EPA Method 1624, Revision C.
 The detection  limit of the  method usually depends upon  interferences  rather than
 instrument limitations.  For this method, MLs have been determined to be 10 or 50 wg/L
 (ppb), depending upon the specific compound.
                                                               I
 Methanol is a volatile organic compound, and it is the hazardous air pollutant emitted from
 pulping operations  in the largest mass (13).  Methanol cannot be analyzed using EPA
 Method 1624C, and so does not appear on the tables in this section or in Appendix Q
 However  analytical methods are available for methanol (such as EPA Method 8015) and
 methanol concentrations and mass loads  are available in the record for the proposed
 NESHAPs.
  6.4.1.4
 Adsorbable Organic Halides
  Adsorbable  organic  halides  (AOX),  a nonconventional  pollutant,  is  a measure of
  halogenated organic compounds that adsorb onto granular activated carbon.  AOX in water

                                         6-20

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                                               6.0  Water Use and Wastewater Characteristics
 and wastewater is measured by EPA Method 1650, Revision A. For pulp and paper mills
 bleaching with chlorine or chlorine-containing compounds, chlorine is the predominant
 halide present in bleach plant and wastewater treatment system samples. At these mills,
 virtually all of the AOX present can be attributed to bleach plant operations. The detection
 limit of the method is usually  dependent upon interferences  rather  than instrument
 limitations. For this method, the ML has been determined to be 20 ug/L (ppb).

 For solid samples (soils, sludges, and pulps), organic halides (OX) are measured using draft
 EPA Method 1648. Because this method is still in draft form, MDL and ML information
 is not yet available. (Results from this analysis are referred to as organic halides rather than
 adsorbable organic halides.)
 6.4.1.5
Chemical Oxygen Demand
Chemical oxygen demand (COD), a nonconventional pollutant, is a measure of the oxygen
equivalent of the organic matter in a sample that is susceptible to oxidation by a strong
chemical  oxidant The result is expressed as a concentration of oxygen consumed.  For
chemical pulp and paper mills, most of the raw waste COD is associated with losses from
pulping and bleaching operations. COD can be analyzed by EPA Methods 410.1 or 410.2.
Method 410.2 covers COD concentrations in the range of 5-50 mg/L (ppm) whereas Method
410.1 covers COD concentrations from 50-2,000  mg/L.  EPA Method 410.4 was used to
collect some of the data presented in this section. At this time, EPA has not developed a
minimum level for the COD methods.
6.4.1.6
Color
Color,  a nonconventional  pollutant,  interferes with  aquatic life  by  limiting light
transmittance.   Color is  influenced by  the  presence of metallic ions (e.g., iron and
manganese) and humic matter.  For kraft pulp and paper mills, most of the effluent color
is attributable to losses of pulping liquor  (black liquor) and bleach plant extraction stage
filtrates (14,15).  Color is measured by the procedure described in NCASI Technical Bulletin
No. 253.  Color results can be reported either in color units  or mg/L relative  to the
platinum standard.  The MDL for this method is 1 to 25 mg/L and depends upon the
instrument used. At this time, EPA has not developed a minimum level for color using this
method.
6.4.1.7
Other Compounds
In the data collection process, the Agency analyzed mill in-process wastewaters and final
effluents for pollutants in four other chemical categories, including resin and fatty acids,
metals,  semi-volatile  compounds, and pesticides/herbicides.   These  compounds  were
analyzed in samples from three (or fewer) short-term sampling episodes.

                                       6-21

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                                              6.0  Water Use and Wastewater Characteristics
Resin and fatty acids are analyzed by the method described in NCASI Technical Bulletin
No  501   MDLs are influenced  by the sample  matrix  and interferences.   With  no
interferences present, compound-specific MDLs ranging from 0.8 to 5.4 ug/L (ppb) can be
achieved for treated effluents. These compounds were analyzed in samples from one short-
term sampling episode but the results were not received in time to include in this document.

Metals are analyzed using EPA Method 1620. MDLs are influenced by sample matrix and
interferences.  With no interferences present, compound-specific MDLs ranging from 0.3 to,
75 ug/L (ppb) can be achieved.

Semi-volatile compounds are analyzed by EPA Method 1625, Revision C.  The detection
limit of the method usually depends upon interferences rather than instrument limitations.
For this method, compound-specific minimum levels have been determined to be 10, 2U, or
50 ug/L (ppb).

Pesticides  and herbicides (and polychlorinated biphenyls or PCBs) are  analyzed by EPA
Method 1618. The detection limit of the method usually depends upon interferences rather
than instrument  limitations.  With' no  interferences  present,  compound-specific  MDLs
ranging from 2 to 1,000 ng/L (ppt) can be achieved. Total PCBs are analyzed using EPA
Method 608.

Most compounds in  these four chemical  categories  were either  not  detected or were
detected at concentrations  deemed to be not treatable or below concentrations of concern
in  pulp and paper mill wastewaters (see Section  7.3).  For these reasons, and because
limited  data  are  available, data for compounds in these four  chemical  categories are
presented  in Appendix C but are not discussed in the remainder of this section.

 6.4.2   Sources of Information

 Four sources of  analytical data were  used to characterize discharges  of priority  and
 nonconventional compounds from pulp and paper mills following the Five-Mill and 104-Mill
 Studies (discussed in Section 3.2.1):  short-term study data, long-term study data, industry-
 supplied data, and data from mills in other countries.  Section 3.0 describes these sources.
 Preliminary data from sampling at a papergrade kraft mill in mid-1993 are included in the
 record for the proposed rulemaking but were not available to include in this section.

 Short-term sampling episodes were conducted at thirteen mills from 1988 through mid-1993.
 Long-term sampling was conducted at eight mills  in 1991 and 1992. Because three mills
 were sampled in both studies, a total of eighteen mills were sampled in the short- and long-
 term studies.  These mills included  15 in the  Bleached Papergrade Kraft and  Soda
 Subcategory, two in  the Dissolving Kraft Subcategory,  and one in the Dissolving Sulfite
                                         6-22

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                                                6.0  Water Use and Wastewater Characteristics
 Subcategory.  The dissolving sulfite mill also manufactures papergrade sulfite pulp.  One'
 additional sampling episode was conducted by EPA at a secondary fiber deink mill in 1989.

 6.4.3   Mill Water Supply

 A sampling point included  in all of the EPA sampling programs was mill  water  supply
 (process  water).   Process  water  samples were  collected to  establish  background
 concentrations of pollutants included in the study.  Appendix C presents  the range of
 pollutant concentrations found in process waters at mills sampled by EPA (Table C-l).  The
 pollutants found in process water samples (in three chemical categories) from 20 mills are
 shown below; only 2,3,7,8-TCDF,  6ctachlorodibenzo-p-dioxin, acetone, chloroform,  and
 methyl ethyl ketone were detected at more than two  mills:
    Chemical Category
      Compounds Detected in Process Water Samples
   CDDs and CDFs
2,3,7,8-tetrachlorodibenzo-p-dioxin,
1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin,
octachlorodibenzo-p-dioxin,
2,3,7,8 - tetr achlorodibenzofur an,
1,2,3,4,6,7,8-heptachlorodibenzofuran
  Chlorinated Phenolics
3,4,5-trichlorocatechol, pentachlorophenol
  Volatiles
acetone, bromodichloromethane, chloroform,
chloromethane, methylene chloride, methyl ethyl ketone,
trichlorofmoromethane, 2-hexanone
Of the pollutants studied, chloroform was detected  most often in mill process waters
Chloroform was detected in process waters  at  four of  eight long-term study mills  at
concentrations ranging from-10 to 52.8 ug/L. All four mills chlorinate their process water
before use, the other four mills do not.  Chloroform concentrations were typically greater
in  untreated  process  wastewaters from bleach plants  and untreated combined  mill
wastewaters than in process waters. Because chloroform concentrations in untreated process
wastewaters are much higher than in process waters, chloroform concentrations in untreated
process wastewaters have not been adjusted based upon  the detection of chloroform  in
process waters.

Bromodichloromethane and trichlorofluoromethane were both detected in mill process
waters and wastewaters.  However, because bromine and fluorine are not used in pulping
or bleaching processes and because other sources of these elements could not be identified
the Agency concluded that the detection of these compounds in pulp mill wastewaters was
                                       6-23

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                                              6.0  Water'Use and Wastewater Characteristics
due to something other than the sampled processes (e.g., as a result of contamination during
sample handling or analysis).

AOX COD and color were analyzed in process waters.  AOX concentrations ranged from
not detected (at a detection limit of 20 mg/L) to 32 mg/L. COD concentrates ranged
from not detected (at 15 mg/L) to  77 mg/L. Color was not detected at any mill (at 25
mg/L).

6.4.4 Brown Stock Washing Wastewaters

During short-term sampling episodes, the Agency sampled pulp and paper mill brown stock
washing wastewaters, and other process wastewaters  that did not  derive from bleach ng.
ApfendkC presents concentrations  of pollutants found in brown stock washing wastewaters
from papergrade kraft mills (Table C-2). Pollutant concentrations in these wastewaters from
mills in^categories other than  bleached papergrade kraft  are sirmjar, but are  not
™eenTed  here due to claims  by mill owners  that such  data  are confidential business
information Because such data were obtained from a limited number of mills, the data
cannot be  aggregated to preserve confidentiality, and thus  are not presented.

The compounds detected in brown  stock washing wastewaters at more than two bleached
 papergrade kraft mills are shown below:
     Chemical Category
   CDDs and CDFs
   Chlorinated Phenolics
   Volatiles1
                                 Compounds Detected in Brown Stock Washing
                             Wastewaters at More Than Two Bleached Papergrade
                                                 Kraft Mills
octachlorodibenzo-p-dioxin,
2,3,7,8-tetrachlorodibenzofuran
3,4,5-trichloroguaiacol
acetone, chloroform, methylene chloride,
methyl ethyl ketone
  Acetone and methyl ethyl ketone were detected most often.  Acetone concentrations ranged
  from not detected (at 50 ug/L) to 6,500 ug/L.  Methyl ethyl ketone concentrations ranged
  from not detected (at 50 ug/L) to 864 ug/L. Concentrations of these pollutants in bleach
  plant filtrates at softwood mills were similar but maximum concentrations in bleach plant
  filtrates (particularly acid filtrates) at hardwood mills were higher.
                                         6-24

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                                                6.0 Water Use and Wastewater Characteristics
 Hie range of AOX concentrations in brown stock washing wastewaters (up to 80 mg/L) is
 slightly  greater  than AOX  concentrations in  process  waters.   The range  of COD
 concentrations in brown stock washing wastewaters (up to 12,000 mg/L) is much higher than
 in process waters, bleach plant wastewaters, and paper machine white waters.   COD in
 brown stock washing wastewaters is the result of  removing wood extractives and lignin
 during washing.  Color was not measured in these wastewaters.

 6.4.5  Bleach Plant Wastewaters

 Bleaching operations at mills that chemically pulp and bleach wood were found to be the
 sources of chlorinated organic compounds found in wastewaters from these mills.  Both
 EPA's short- and long-term studies included sampling of bleach plant wastewaters.  At most
 mills that chemically pulp and bleach wood, acid and alkaline bleach stage wastewaters are
 discharged to separate sewers.  However, at  some  mills, bleach plant wastewaters are
 discharged to a combined se,wer containing both acid and alkaline wastewaters.

 Because  separate sewers  are more common, acid  and alkaline wastewater pollutant
 concentrations  are presented separately in this  section.  The data include results obtained
 from sewer samples (e.g., a point where several acid stage filtrates have been combined) and
 from individual stages (e.g., the first C/D stage if filtrates from subsequent C or D stages
 are not discharged, but recycled to the first stage).  To calculate the total pollutant mass
 load from bleach plants, separate mass loadings of acid and alkaline sewer discharges were
 summed.

 This  section  summarizes pollutant concentrations and mass loadings in bleach plants at
 bleached papergrade kraft mills. Data are presented separately for mills with hardwood and
 softwood fiber furnishes because some differences between mills are attributable to furnish.
 Bleach plant data for mills in subcategories other than bleached papergrade kraft are not
 presented here due to claims by mill owners that such  data are confidential  business
 information.  Because such data were obtained from  a limited number  of mills,  the data
 cannot be aggregated to preserve confidentiality, and  thus are not presented.
6.4.5.1
Specific Organic Pollutants
Appendix C presents the range of pollutant concentrations in acid and alkaline filtrates at
hardwood and softwood bleached papergrade kraft mills (Tables C-3, C-4, C-5, and C-6,
respectively), which are summarized below. .The following discussion primarily focuses on
the compounds that were detected most frequently in bleach plant  wastewaters and for
which effluent limitations guidelines and standards are being proposed.

2,3,7,8-TCDD and 2,3,7,8-TCDF were detected in the bleach plant effluent at six and seven
long-term study mills, respectively. These compounds were detected in acid filtrates at some

                                        6-25

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                                              6.0  Water Use and Wastewater Characteristics
mills, in alkaline filtrates at some mills, and in both filtrates at some mills.  The dioxin and
furan congeners detected in either acid or alkaline filtrates at more than two hardwood or
softwood mills, and their maximum observed concentrations, are shown below:
=====3S=====SS==S==3S=3====^====
CDDs and CDFs Detected In Either
Acid or Alkaline Filtrates at More Than
Two Hardwood or Softwood Bleached
Papergrade Kraft Mills
2,3,7,8-tetrachlorodibenzo-p-dioxin
1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin
octachlorodibenzo-p-dioxin
2,3,7,8-tetrachlorodibenzofuran
'— ' ' . —
Maximum Observed Concentration (pg/L)
Hardwood Lines
Acid
40
61
400
220
Alkaline
--
--
230,000
63
1
Softwood Lines
Acid
160
107
1,500
2,700
—
Alkaline
320
170
2,000
1,900
=====
- Compound was not detected at more than two mills of this type.

In addition to those shown above, nine other 2,3,7,8-substituted CDD and CDF congeners
were detected in bleach plant effluents at one or two hardwood or softwood mills.  (It
should be noted that, although 2,3,7,8-TCDD and 2,3,7,8-TCDF were analyzed in each
bleach plant sample in the short- and long-term studies, the other fifteen 2,3,7,8-substituted
CDD and CDF congeners were analyzed for at all but one short-term study mill and only
in selected samples from each long-term study mill.)  The CDD and CDF results obtained
are consistent with results in the Five-Mill and 104-Mill Studies. Those results showed that
2,3,7,8-TCDD and 2,3,7,8-TCDF are the predominant CDDs and CDFs found in pulp and
paper mill  matrices, particularly  when  considered in light of the Agency's  toxicity
equivalence approach (8,11,12).

The chlorinated phenolic compounds detected in acid or alkaline filtrates at more than two
hardwood or softwood mills, and the maximum observed concentrations, are shown below:
Chlorinated Phenolic Compounds
Detected In Either Acid or Alkaline
Filtrates at More Than Two
Hardwood or Softwood Bleached
Papergrade Kraft Mills
4-chlorophenol
4-chlorocatechol
Maximum Observed Concentration (wg/L)
Hardwood Lines
Acid
33
~
Alkaline
19
—
Softwood Lines
Acid
35
35
Alkaline
57
—
                                         6-26

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           6.0  Water Use and Wastewater Characteristics
Chlorinated Phenolic Compounds
Detected In Either Acid or Alkaline
Filtrates at More Than Two
Hardwood or Softwood Bleached
Papergrade Kraft Mills
4-chloroguaiacol
5-chlorovanillin
6-chlorovanillin
2-chlorosyringaldehyde
2,4-dichlorophenol
2,6-dichlorophenol
3,4-dichlorocatechol
3,6-dichlorocatechol
4,5-dichlorocatechol
3,4-dichloroguaiacol
4,5-dichloroguaiacol
4,6-dichloroguaiacol
5,6-dichlorovanillin
2,6-dichlorosyringaldehyde
2,4,5-trichlorophenol
2,4,6-trichlorophenol
3,4,5-trichlorocatechol
3,4,6-trichlorocatechol
3,4,5-trichloroguaiacol
3,4,6-trichloroguaiacol
4,5,6-trichloroguaiacol
trichlorosyringol
1 2,3,4,6-tetrachlorophenol
Maximum Observed Concentration («g/L)
Hardwood Lines
Acid
"
—
>50
>50
26
21
410
130
>267
—
82
—
34
21
—
50
170
—
12
,
7
16
2
Alkaline
14
350
2,260
1,430
23
--
~
17
171
49
637
64
550
560
29
95
150
~
65
13
300
120
11
Softwood Lines
Acid
72
29
797
50
55
—
320
95
820
—
298
15
30
—
__
750
818
12
34
—
31
13
27
Alkaline
150
595
7,500
—
250
__
19
>50
80
93
> 5,000
>50
509
__
__
210
49
__
>500
40
300
—
36
6-27

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                                               6.0  Water Use and Wastewater Characteristics
Chlorinated Phenolic Compounds
Detected In Either Acid or Alkaline
Filtrates at More Than Two
Hardwood or Softwood Bleached
Papergrade Kraft Mills
tetrachlorocatechol
tetrachloroguaiacol
pentachlorophenol
Maximum Observed Concentration (#g/L) ;
Hardwood Lines
Acid
57
--
—
Alkaline
67
42
~
Softwood Lines
Acid
131
10
375
Alkaline
29
470
12
-- Compound was not detected at more than two mills of this type.
>  The review of the analysis used to derive the reported concentration indicated that the result may have
   actually been higher.

Of 33 chlorinated phenolic compounds analyzed during these sampling programs, almost all
of them were detected at least once in both acid and alkaline filtrates at mills that pulp
hardwood and softwood. Some compounds were almost never detected ini either acidor
alkaline filtrates while other compounds were almost always detected in both filtrates  me
only compound not detected in any bleach plant filtrate sample was 3,4-dichlorophenol
(analyzed only in short-term studies). 6-Chlorovanillin was detected in almost every sample
in both acid  and alkaline filtrates and for both fiber  furnishes.   In general,  for both
furnishes  phenols and catechols were detected more often and at higher concentrations in
acid filtrates than in alkaline filtrates while guaiacols, syringols, and vanillins were detected
more often and  at higher concentrations in alkaline filtrates than in  acid filtrates.  One
apparent difference  between  furnishes  is  that  syringols  and benzaldehydes  (i.e., 2-
chlorosyringaldehyde, 2,6-dichlorosyringaldehyde, and trichlorosyringol) were detected in the
majority of hardwood alkaline filtrates, whereas these compounds were not detected as often
in softwood alkaline filtrates.

The volatile organic  compounds detected in acid  or alkaline filtrates at more  than two
hardwood or softwood mills, and  the maximum  observed concentrations, are shown as
follows:
                                          6-28

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                                                 6.0  Water Use and Wastewater Characteristics
Volatile Organic Compounds Detected
In Either Acid or Alkaline Filtrates at
More Than Two Hardwood or Softwood
Bleached Papergrade Kraft Mills
acetone
brornodichlorornethane
carbon disulfide
chloroform
chloromethane
methylene chloride
methyl ethyl ketone
trichloroethene ' .
Maximum Observed Concentration
(mg/L)
Hardwood Lines
Acid
29
—
0.27
57
30
2.1
6.6
~
Alkaline
6.2
0.13
--
30
—
8.2
4.5
—
Softwood Lines
Acid
6.7
—
0.12
6.9
>0.19
1.1
1.1
—
Alkaline
2.3
—
—
>3.3
—
1.1
0.43
0.019
 - Compound was not detected at more than two mills of this type.
 > The review of the analysis used to derive the reported concentration indicated that the result may have
   actually been higher.

 The four volatile organic compounds detected most often in acid and alkaline filtrates at
 both hardwood and softwood  mills were  acetone, chloroform,  methylene chloride,  and
 methyl ethyl ketone. The Agency concluded that the detection of brornodichlorornethane
 in bleach plant  alkaline filtrates was due to contamination during sample  handling or
 analysis because bromine is not used in pulping or bleaching processes and other sources
 of bromine could not be identified.
6.4.5.2
AOX, COD, and Color
Nonconventional pollutants were notanalyzed in bleach plant filtrates in the long-term study
but AOX and COD were analyzed in bleach plant filtrates in some short-term sampling
episodes. AOX concentrations at hardwood mills range from 7 to 128 mg/L in acid filtrates
and from 3  to 73 mg/L in alkaline filtrates.  AOX concentrations at softwood mills range
from  10 to 200 mg/L in acid filtrates and from 13 to 160 mg/L in alkaline filtrates.  COD
concentrations were similar at mills with either furnish, and in  both  acid and alkaline
filtrates.  COD concentrations range from not detected (at 15 mg/L) to 3,200 mg/L.
                                         6-29

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                                                6.0  Water Use and Wastewater Characteristics
6.4.5.3
Pollutant Mass Loadings
Appendix  C presents  the range  of production normalized loadings for priority  and
nonconventional pollutants in bleach plant effluents at hardwood and softwood bleached
papergrade kraft mills (Tables C-7 and C-8, respectively).  For pollutants for which bleach
plant limitations are being proposed, the range of production normalized mass loadings for
hardwood and softwood bleach lines are shown below. Most minimum values shown below
(except for chloroform and MEK for softwood mills) were calculated using the detection
limit for the pollutant.
======
Pollutant
2,3,7,8-TCDD
2,3,7,8-TCDF
All tri- through
pcnta-substituted
chlorinated
phenolic
compounds
acetone
chloroform
methylene
chloride
methyl ethyl
ketone
=^==

Units
«g/
ADMT
"g/
ADMT
mg/
ADMT
g/
ADMT
g/
ADMT
g/
ADMT
g/
ADMT
Range of Bleach Plant Loadings
Hardwood Lines
Minimum
0.056
0.059
2.4
0.69
>2.0
0.12
0.61
Maximum
3.6
8.9
9,350
305
405
34
165
No. of
Mills
Now-
Detect
2 of 10
lof 10
0 of 10
1 of 9
Oof 10
6 of 9
2 of 9
Softwood Lines
Minimum
0.11
0.11
14.1
0.71
0.31
0.093
0.77
Maximum
3.2
53
12,400
86
>106
83
39

No. of
Mills
Non-
Detect
4 of
10
lof 9
2 of
10
lof
10
Oof
10
5 of
10
Oof
10
 > The review of the analysis used to calculate this loading indicated that the result may have actually been
 higher.
                                          6-30

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                                                6.0 Water Use and Wastewater Characteristics
  6.4.6  Paper Machine White Waters

  During short-term sampling episodes, the Agency sampled paper machine white waters
  Appendix C presents the range of pollutant concentrations found in paper machine white
  waters from papergrade kraft mills (Table C-9). Pollutant concentrations in white waters
  from nulls in subcategories other than bleached papergrade kraft were similar, but are not
  presented here due to claims  by mill owners that such data are confidential business
  information. Because such data were obtained from a limited number of mills  the  data
  cannot be aggregated to preserve confidentiality, and thus are not presented.

  The compounds detected  in paper machine  white  waters at  more than two bleached
  papergrade  kraft mills are shown below:
     Chemical Category

   CDDs and CDFs
   Chlorinated Phenolics
                                                "      —
 Compounds Detected in Paper Machine White Waters at
     More Than Two Bleached Papergrade Kraft Mills

l>2,3,4,6,7,8-heptachlorodibenzo-p-dioxin,
octachlorodibenzo-p-dioxin
6-chlorovanillin, 3,4,5-trichloroguaiacol, pentachlorophenol
   Volatiles
acetone, chloroform
 Chlorinated organic compounds contained in paper machine white waters are believed to
 be generated in the bleach plant.  The compounds are carried with the bleached pulp to the
 paper machines where-the compounds are transferred to the white water.

 The range of AOX concentrations in paper machine white waters  is slightly greater than
 £,  ? T.nn31^;?? I!1 Pr°CeSS WaterS (UP t0 72 mg/L>'  CQD Concentrations were higher
 (up to 4,500 mg/L) than in process waters and bleach plant wastewaters but were not as
 high as in brown stock washing wastewaters. Color was  not measured in white waters.

 6.4.7   Treated  Wastewater Effluents

 Final effluent pollutant concentrations are presented in this section for mills that chemically
wht      f^     •  ^ data Presented are from the short- and long-term studies except
where noted otherwise  Appendix C presents the range of pollutant concentrations reported
ftntr /?HT^  ^f^ With hardwood (to mills) and softwood (ten mills)
furnishes Tables C-10 and C-ll, respectively). Appendix C presents the range of pollutant
concentrations for two dissolving kraft mills that both use hardwood and softwood (the data
are combined) and a dissolving sulfite mill with softwood furnish (Tables C-12 and C-13
                                       6-31

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                                              6.0  Water Use and Wastewater Characteristics
             All data are from direct-discharge mills with secondary effluent treatment
                       detected less frequently in final effluents than m bleach. plant
effluents.

6.4.7.1       Specific Organic Pollutants

2,3,7,8-TCDD was detected in the final effluent at three pa pe rgrade kraft  milk and a
dissolving kraft mill.  The highest  concentration measured for 2,3,7,8-TCDD in  these
saS^s w^a^pergrade krlft mill (at 74 ug/L); ^'%7^*%%£^
this detection to be representative of -typical mill operations.  2,3,7,8-TCDF was detectea in
 he find effluent at nine mills, including six papergrade kraft mills, both dissolving kraft
rk and the dissolving sulfite mill  The .highest detected <™^^>7£™
in these effluents was  320 pg/L.  Besides 2,3,7,8-TCDD and  4V,» ' ~»?>  L       8_
CDD/CDF congeners were detected in final effluents at more than one mill. V^W>8
                   --
 Twentv-eieht chlorinated phenolic compounds were detected in final effluents at these mills




 fr0rparticular mills. The chlorinated phenolic compounds  detected m treated effluents,
 and their maximum observed concentrations, are shown below.
,

Chlorinated Phenolic Compounds
Detected In Treated Effluents
4-chlorophenol
4-chlorocatechol
4-chloroguaiacol
5-chlorovanillin
6-chlorovanillin
2-chlorosyringaldehyde
2,4-dichlorophenol
2,6-dichlorophenol
3,4-dichlorocatechol
Maximum Observed Concentration (Mg/L)
Bleached Papergrade Kraft
Hardwood
—
>1.9
0.90
1
9.0*
5.8*
0.90
—
1.1
Softwood
0.20
>2.2
• 28*
-
>26*
--
9.0*
>0.85
~
Dissolving
Kraft
Both
4.1
--
	 - -
-
-
7.5*
-
~
Dissolving
Sulfite
Softwood
2.9
>13
-
3.0
-
-
-
-
~
                                          6-32

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                                                   6.0  Water Use and Wastewater Characteristics
1 	 .
Chlorinated Phenolic Compounds
Detected In Treated Effluents
3,5-dichIorocatechol
4,5-dichlorocatechol
3,4-dichloroguaiacol
4,5-dichIoroguaiacol
4,6-dichloroguaiacol
5,6-dichlorovanillinj
2,6-dichlorosyringaldehyde
2,4,5-trichlorophenol
2,4,6-trichlorophenol
3,4,5-trichlorocatechol
3,4,6-trichlorocatechol
3,4,5-trichloroguaiacol
3,4,6-trichlorophenol
4,5,6-trichloroguaiacol
trichlorosyringol
2,3,4,6-tetrachlorophenol
tetrachlorocatechol
tetrachloroguaiacol
	 	 	 • 	 - 	
pentachlorophenol
Maximum Observed Concentration (wg/L)
Bleached Papergrade Kraft
Hardwood
7.1
11*
--
~
6.8*
~
9.7*
4.3
16
27
-
1.7
1.5
7.6*
3.0*
2.6
17
—
19
Softwood
—
39*
4.8*
9.5*
—
15
11*
~
>18*
18*
~
33*
—
5.4*
8.2*
—
17*
—
0.20
Di$$olving
Kraft
Both
	
6.9*
__
0.10
	
_,_
2.8
__,
14*
12*
12
>1.6
0.10
0.50
3.7
0.20
9.6
1.5
--
Dissolving
Sulfite
Softwood
..
	
..
	
	
..
..
..
8.7*
..
__.
	
	
..

	


-
- Compound was not detected at mills of this type.
* Compound was detected in more than three samples at mills of this type.
>  The review of the analysis used to derive the reported concentration indicated that the result mav have
actually been higher.

Eight volatile organic compounds were  detected  in final effluent samples and five were
detected  at more than  one mill.  Acetone, chloroform,  and methylene chloride were
detected  at more than one hardwood  bleached papergrade kraft mill.  Acetone, carbon
disulfide, chloroform, methylene chloride, and methyl  ethyl ketone were detected at more
                                          6-33

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                                               6.0  Water Use and Wastewater Characteristics
than one softwood papergrade kraft mill.  Acetone and chloroform were the only volati e
organic compounds detected at both dissolving kraft mills.  At the dissolving sulfite mill,
four volatile organic compounds were detected but  only acetone and chloroform were
detected in two or more samples.

6.4.7.2       AOX, COD, and Color

The range of final effluent concentrations at short- and  long-term study mills for AOX
COD and color are shown in Appendix C (Tables C-10 through C-13), and are summarized
below  AOX and COD were analyzed at some short-term  study mills; AOX and color were
analyzed at all long-term study mills. The range of concentrations for each nonconventional
pollutant is greatest for softwood bleached papergrade kraft mills (where the most data are
available).
S3353=3SS323S=33=
Pollutant
AOX
COD

_==_____=_^^
Rangfe Of Final Effluent Concentrations (fflg/L)
Bleached Papergrade Kraft
Hardwood
Min
>3
160
300
Max
18
740
1,210
Softwood
Min
>0.1
272
115
Max
180
810
1,950
Dissolving Kraft
Both Furnishes
Min
3
380
965
•. , Max •
14
690
1,870
"'.', i, ,i 11,11, 	 . ^ .... '.
Dissolving Sulfite
Softwood
Min
>2.2
Max
>9.3
Not Analyzed
250
850
 > The review of the analysis used to derive the reported concentration indicated that the result may have actually been higher.
 6.4.7.3
Pollutant Mass Loadings
 Appendix C presents pollutant loadings for each priority and nonconventional pollutant
 analyzed in final effluents at hardwood and softwood papergrade kraft mills, two dissolving
 kraft mills, and a dissolving sulfite mill (Tables C-14 through C-17).  The range of loadings
 for pollutants for which limitations are being proposed are summarized below. Each loading
 was based on an individual analytical measurement on one day at one mill.  The maximum
 loading observed in each of four datasets is shown with the minimum loading from among
 the four datasets. Minimum values for 2,3,7,8-TCDD, 2,3,7,8-TCDF, and the chlorinated
 phenolics, and maximums for 2,3,7,8-TCDD for bleached papergrade kraft (hardwood) and
 dissolving sulfite, were calculated using detection limits.
                                          6-34

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                                                6.0  Water Use and Wastewater Characteristics
Pollutant
2,3,7,8-TCDD
2,3,7,8-TCDF
All tri- through penta-
substituted chlorinated
phenolic compounds
AOX
COD
color
Unite
Kg/ADMT
«g/ADMT
mg/ADMT
kg/ADMT
kg/ADMT
kg/ADMT

Overall
Minimum
0.17
0.28
6.2
> 0.0062
11
7
===^=
=^===^=::=^======:^^==^=================^==:^=
Range of Final Effluent Loadings
Bleached Papergrade Kraft
Hardwood
Maximum
1.5
0.97
2,800
1.5
77
129
:^==
Softwood
Maximum
12
6.6
4,050
16
62
416
Dissolving
Kraft
Both

3.2
42
2,390
22
93
268
Dissolving
Sulfite
Softwood

2.8
12
1,680
>1.8
Not Analyzed
192
 > The review of the analysis used to derive the reported concentration indicated that the result may have actually been higher.

 In comparison to the data presented above for U.S. mills, eight papergrade and dissolving
 sulfite mills  in other countries that use totally chlorine-free (TCP) bleaching processes
 reported effluent AOX loadings of 0.1 kg/ADMT or less, and three of these mills do not
 have secondary treatment systems. The AOX measurements on which the non-U S mill
 loadings are  based may not have been obtained using the EPA method but are presented
 for comparison.

 COD loadings at TCP mills in other countries with secondary treatment range from 15 to
 75 kg/ADMT. Again, COD measurements from these mills may not have been obtained
 using the EPA method but are presented for comparison.

 6.4.8  Wastewater Treatment Sludges

 During most sampling episodes, the Agency  sampled  wastewater treatment  sludges.
 Appendix C presents the range of pollutant concentrations found in wastewater treatment
 sludges from papergrade kraft mills (Table C-18). The data include all types of sludges-
primary, secondary, or combined sludges from mills that pulp hardwood, softwood  or both ;
Pollutant  concentrations  in  sludges  from mills in  subcategories  other  than bleached
papergrade kraft were similar, but are not presented here due to claims by mill owners that
such data are confidential business information.  Because such data were obtained from a
limited number of mills, the data cannot be aggregated to pre'serve confidentiality  and thus
are not presented.
                                        6-35

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                                                6.0  Water Use and Wastewater Characteristics
The compounds detected in wastewater treatment sludges at more than two bleached
papergrade kraft mills are shown below:
    Chemical Category
  CDDs and CDFs
  Chlorinated Phenolics
                                Compounds Detected in Wastewater Treatment Sludges
                                 at More Than Two Bleached Papergrade Kraft Mitts
         2,3,7,8-tetrachlorodibenzo-p-dioxin,                         _
         1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxm, octachlorodibenzo-p-dioxin,
         2,3,7,8-tetrachlorodibenzofuran,
         2,3,4,7,8-pentachlorodibenzofuran,
         1,2,3,4,6,7,8-heptachlorodibenzofuran
         4-chlorophenol, 6-chlorovanillin, 4,5-dichloroguaiacol,
         3,4,5-trichloroguaiacol
                        acetone, carbon disulfide, chloroform, ethylbenzene, methylene chloride,
                        tlL^HJi-lv. ^"ClA l^VA* vfcALjv****-*-™-; —	  i    *            -
                        methyl ethyl ketone, o + p xylene, toluene, 2-propenal (acrolem)
 The compounds detected most often in wastewater treatment sludges are the same as those
 detected in wastewaters from both pulping and bleaching areas of the mill.

 6.4.9   Non-Chemical and Non-Wood Pulping and Bleaching Mills
 6.4.9.1
1990 Questionnaire Data
 As described in Section 4.3.6, 41  mills bleach semi-chemical pulps, mechanical pulps,
 secondary fibers, and  other  pulps  (e.g., non-wood pulp) with chlorine and/or chlorine
 derivatives. Sodium and calcium hypochlorite are the principal bleaching agents used. This
 section summarizes final effluent pollutant concentrations available for these mills.  Most,
 of the data were provided to the Agency by the mills with the 1990 questionnaire and
 represent the time period 1985 to 1989.  Twelve of the 41 mills submitted final effluent data
 for one or more of the following compounds:  2,3,7,8-TCDD, 2,3,7,8-TCDF, chloroform, and
 chlorinated phenolic compounds. Table 6-8 summarizes effluent concentrations for these
 mills, and identifies the mill  process(es), and discharge status.  Data are not available for
 all types of bleaching performed by  the 41 mills. 2,3,7,8-TCDD was detected in the effluent
 fronVone secondary fiber deink mill. 2,3,7,8-TCDF was detected in the effluent from four
 secondary fiber  mills  (two deink and two non-deink).  Chloroform was detected at all ot
 these mills.

  6.4.9.2       EPA Sampling of a Secondary Fiber Deink Mill

  The Agency conducted a short-term sampling episode at a secondary fiber deink mill with
  bleaching operations in June 1989.  The mill has extensive internal water reuse and recycle
                                           6-36

-------
                                               6.0  Water Use and Wastewater Characteristics
 systems and is equipped with an activated sludge biological treatment system for end-of-pipe
 treatment.  The purpose of the sampling program was to characterize concentrations and
 loadings of CDDs and CDFs in untreated and treated wastewaters and in wastewater
 treatment sludge; PCBs in treated wastewaters; and, other chlorinated phenolic and volatile
 compounds in treated wastewaters.  The mill uses more grades of waste paper stock than
 do many secondary fiber mills and bleaches a portion  of the secondary fiber pulp with
 hypochlorites.  Hence, EPA expects the sampling results are representative of secondary
 fiber deink mills with a higher potential to discharge toxic pollutants because of the variety
 of waste paper grades used.

 Table 6-9 presents concentrations of CDDs and CDFs found in wastewaters.  These results
 show that tetra-, penta-, hexa-, hepta-, and octa-2,3,7,8-substituted CDD and CDF congeners
 were present in untreated wastewaters at variable concentrations during the three-day
 sampling program but only OCDD was found in the treated effluent.  Reported analytical
 detection limits were 1.2 to 8.8 pg/L (ppq). Table 6-10 presents the wastewater treatment
 sludge results.  Seven CDDs and CDFs were detected on one or more days in the sludge.

 Based upon the type and degree of pulp bleaching conducted at the mill and CDD and CDF
 analyses for unbleached and bleached pulps, the Agency determined the principal source of
 CDDs and CDFs found  in the untreated wastewaters to be the bleached waste paper stock
 used as part of the fiber furnish at  the mill.  The Agency anticipates that, as a result of]
 industry efforts to  reduce  the mass of CDDs and CDFs  in bleached pulp, the amount of
 CDDs and CDFs in waste papers will also decrease, but at a slower rate as waste paper
 stocks are recycled over time.

 Additional data, reported by the parent company of the sampled mill, show that as of 1988
 and  1989, PCBs were present in several  grades of waste papers, generally in the range of
 100 to more than 300 ug/kg (ppb). When PCBs were eliminated from the manufacture of
 carbonless copy paper in the early 1970s, PCB concentrations in mixed waste  papers
 decreased significantly, but have  apparently leveled off to the range cited  above.  The
 company also reported findings of PCBs in virgin bleached wood pulps from four  mills
 ranging from 70 to 120 ug/kg (ppb). These results suggest that secondary fiber, and possibly
 virgin bleached wood fiber, remain sources of PCBs at  secondary  fiber  mills.  PCBs can
 reach the wastewaters through secondary fiber repulping and deinking operations.

 Figure 6-5 presents a summary of treated effluent PCB  data reported by the mill for the
period January 1985 through March 1993. Data from 1985 through 1989  were reported in
response to the 1990 questionnaire.  Data for 1990 through March  1993 were provided by
the state agency that issued the mill's NPDES permit. These data show that, except for a
few isolated  cases,  total  PCBs (analyzed  by EPA Method 608) have not  been detected in
the mill effluent since late  1989. The reported analytical detection  level  is 0.1 ug/L.  The
                                       6-37

-------
                                                6.0  Water Use and Wastewater Characteristics
mill successfully instituted an improved chemically assisted clarification system in 1989 as
part of an effort to reduce PCB effluent concentrations and mass loadings.
                                                                  i
Monitoring results for other priority and nonconventional pollutants indicate that mostof
these  compounds were not  detected  in  the treated  effluent  from  the mill.    The
concentrations of pollutants that were detected are summarized below:
    Chemical Category
           Compound
                                                           Minimum
                                                                          Maximum
  Volatiles
chloroform
                                                             < 10
                                                      15
                       p-dioxane
                                                              < 10
                                                                              29
  Chlorinated Phenolics
2,4,6-trichlorophenol
                                                             < 0.5
                                                      30
                       2,6-dichlorophenol
                                                             < 0.25
                                                      1.8
                        pentachlorophenol
                                                              1.2
                                                                              2.4
                        4,6-dichloroguaiacol
                                                              7.0
                                                                              10
                        3,4,5-trichloroguaiacol
                                                              < o.i
                        4,5,6-trichloroguaiacol
                                                             < 0.25
                                                       0.6
                        chlorosyringaldehyde
                                                              < 0.5
                                                       3.4
 < indicates that the compound was not detected; the detection limit is shown.
 The Agency believes that the  presence of chloroform is attributable to hypochlorite
 bleaching conducted at the mill, and that the chlorinated phenolic pollutants are introduced
 with the waste paper stock used as the fiber supply.

 6.5    References

 1      Miner R. and J. Unwin.  Progress in Reducing Water Use and Wastewater Loads
        in the U.S. Paper Industry. TAPPI Journal, 74(8):127-131, August 1991.

 2.     Ingruder, O.V., M.J. Kocurek, and A. Wong,  eds.  Pulp and Paper Manufacture
        (Third  Edition):   Volume 4-Sulfite  Science  and Technology.  Joint  Textbook
        Committee of the Paper Industry, TAPPI, Technology Park, Atlanta, Georgia and
        CPPA, Montreal, Quebec, Canada, 1985.
                                           6-38

-------
                                               6.0  Water Use and Wastewater Characteristics
 4.
 5.
 6.
 7.
8.
9.
10.
11.
12.
       Esposito, M,P., T.O. Tiernan, and RE. Dryden. Dioxins.  Office of Research and
       Ohio mO nt EPA-600/2-80-197' U'S- EnvironmentalProtection Agency, Cincinnati,
 U.S. EPA, Office of Water Regulations and Standards.  The National Dioxin Study-
 Tiers 3,5,6,  and 7.  EPA-440/4-87-003, U.S. Environmental Protection Agency'
 Washington, D.C.,  February 1987.                                           y>

 U.S  EPA, Office of Solid Waste and Emergency Response. The National Dioxin
 Study - Report To  Congress. EPA/530-SW-87-025, U.S. Environmental Protection
 Agency, Washington, D.C., August 1987.

 U.S.  EPA, Office of Water Regulations and Standards.  U.S. EPA/Paper Industry
 Cooperative Dioxin  Screening  Study.   EPA-440/1-88-025,  U.S.  Environmental
 Protection Agency, Washington,  D.C., March 1988.
            " G' Soderstrom' C RaPPe> L.E. Hagerstdet, and E. Burstrom.  PCDD
 and  PCDF Emissions  from  Scrap Metal  Melting Processes at a  Steel  Mill
 Chembsphere, 19(1-6):705-710, 1989.

 Amendola, G.A., et al. The Occurrence and Fate of PCDDs and PCDFs in Bleached
 Kratt Pulp and Paper Mills.  Chemosphere, 18(1-6):1181-1188, 1989.

 Public Meeting on EPA's Scientific Reassessment of Dioxin. U.S. Environmental
 Protection Agency.  56 FR 50903, October 1991.
           °^ice <£ Health and Exposure Assessment.  Health Assessment for
 ,,,8-Tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD) and Related Compounds. Draft
Chapters 1 through 8.  U.S. Environmental Protection Agency/Washington, D.C.,
Bellin J.S. and D.G  Barnes.  Interim Procedures for Estimating Risks Associated
With Exposures to Mixtures of Chlorinated Dibenzo-p-dioxins and -Dibenzofurans
                 }"        625/3-87/012, U.S. Environmental  Protection Agency!
Bellin  J.S. and D.G. Barnes.  Interim Procedures for Estimating Risks Associated
Wrth Exposures to Mixtures of Chlorinated Dibenzo-p-dioxins and -Dibenzofurans
M? ?1989       }'  EPA 625/3-89/016'  U'S- Environmental Protection Agency
                                      6-39

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                                             6.0 Water Use and Wastewater Characteristics
13    US  EPA, Office of Air Quality Planning and Standards.   Pulp, Paper  and,
  '    Paperboard Industry - Background Information for Proposed Air Emission^ Standards •
      (Manufacturing Processes at Kraft, Sulfite, Soda, and Semi-Chemical Mills), EPA
      453/R93-050a, U.S. Environmental Protection Agency, Research Inangle.rarK,
      North Carolina, October 1993.

14.    Springer, A.M. Industrial Environmental Control - Pulp and Paper Industry. John
      Wiley and Sons, New York, New York,  1986. p. 182.

15    Panchapakesan,  B.   Process  Modifications,  End-of-Pipe Technologies  Reduce
      Effluent Color. Pulp & Paper, 65(8):82-84, August 1991.

16    US EPA, Office  of Water Regulations and Standards.  Development  Document for
  '   Effluent  Limitations  Guidelines,  New  Source  Performance  Staiutards  and
      Pretreatment Standards for the Pulp, Paper, and Paperboard aiid the Builders Paper
      and Board Mills Point Source Categories.  EPA-440/1-82-025, U.S. Environmental
      Protection Agency, Washington, D.C., October 1982.
                                        6-40

-------
                                                                 LEGEND
                     FURNISH
 FRESH
 INTAKE
 WATER
                                                          	  WATER  FLOW
                                                          	PULP FLOW
                                    CLARIFIED
                               WASTEWATER RECYCLE

                              RECOVERED
                                FIBER
                 PULP SCREENS/
                    CLEANERS
                                   WASTEWATER
                       V
                                   RECOVERED
                                   FIBER AND
                                   REJECTS TO
                                PULPING  OR WASTE
                 PAPER MACHINE
              RICH
           WHITEWATER
                             LEAN
                          WHITEWATER
WASTEWATER
   TO   •*
 TREATMENT

                  BOARD PRESS/
                     DRYER
                               TO

                               DISCHARGE
    RECOVERED
     FIBER TO
STOCK PREPARATION
                                                           SLUDGE
                                                         TO DISPOSAL
                    PRODUCT
SOURCE: 1990 QUESTIONNAIRE AND BEST PROFESSIONAL JUDGEMENT.
       FIGURE 6-1.
                   DIAGRAM OF  PROCESS OPERATIONS  FOR SECONDARY
                   FIBER  MILLS  THAT MAKE PAPERBOARD FROM WASTEPAPER
                   AND DISCHARGE WASTEWATER
                                      6-41

-------
 FRESH
MAKE-UP
 WATER
                                                                LEGEND

                                                          	 WATER  FLOW
                                                          	t- PULP FLOW
                                  WASTEWATER
                            CLARIFIED
                           WASTEWATER
                           TO PULPING,
                         STOCK CHESTS,
                         PAPER  MACHINE,
                          AND UTILITIES
                                   RECOVERED
                                     FIBER


                                    WASTEWATER
                                    RECOVERED
                                    FIBER AND
                                    REJECTS  TO
                                 PULPING  OR  WASTE
                             RECYCLE WATER
                               TO  PULPING,
                             PAPER MACHINE,
                                   UTILITIES
                                 LEAN
                              WHITEWATER
WASTEWATER
  (IF ANY)-^
TO SCREENS,
 CLEANERS
                   BOARD PRESS/
                       DRYER
 RECOVERED
  FIBER TO
 PULPING OR
STOCK CHEST
                      PRODUCT
 SOURCE:  1990 QUESTIONNAIRE AND BEST PROFESSIONAL JUDGEMENT.
        FIGURE  6-2   DIAGRAM  OF PROCESS  OPERATIONS FOR SECONDARY
                      FIBER MILLS THAT  MAKE PAPERBOARD FROM, WASTEPAPER
                      AND COMPLETELY RECYCLE WASTEWATER
                                    6-42

-------
                      FURNISH
  FRESH
  INTAKE
  WATER
                                               LEGEND

                                           	 WATER FLOW
                                           	PULP FLOW
                      STOCK
                    PREPARATION
                                       CLARIFIED  WASTEWATER
PAPER MACHINE
               RICH
            WHITEWATER
                                                        TO
                                                    DISCHARGE
          TO
       DISCHARGE
                                                       RECOVERED
                                                        FIBER TO
                                                   STOCK  PREPARATION
                     PRODUCT
SOURCE: 1990 QUESTIONNAIRE AND BEST PROFESSIONAL JUDGEMENT.
         FIGURE 6-3.
     DIAGRAM OF  PROCESS  OPERATIONS  FOR SECONDARY
     FIBER  MILLS  THAT MAKE  BUILDERS'  PAPER  AND
     ROOFERS' FELT AND DISCHARGE WASTEWATER
                                      6-43

-------
                   FURNISH
                                            LEGEND

                                             WATER FLOW
                                      	PULP FLOW
 FRESH
MAKE-UP-
 WATER
                     i
                    STOCK
                 PREPARATION
                             CLARIFIED AND/OR TREATED WASTEWATER
PAPER MACHINE
              RICH
           WHITEWATER
              LEAN
           WHITEWATER
                    PRODUCT
                                   RECOVERED
                                   FIBER TO
                               STOCK PREPARATION
                                                                 NOT  PRESENT
                                                                 FOR  100% Q
                                                                     MILL

SOURCE; 1990 QUESTIONNAIRE AND BEST PROFESSIONAL JUDGEMENT.
        FIGURE 6-4.
     DIAGRAM OF  PROCESS  OPERATIONS FOR  SECONDARY
     FIBER  MILLS  THAT MAKE  BUILDERS' PAPER AND
     ROOFERS'  FELT AND COMPLETELY RECYCLE WASTEWATER
                                     6-44

-------
             Figure 6-5.  Total PCB Effluent Concentrations
          at a Secondary Fiber Deink Mill (1985 to March 1993)
 (50
8
OH
o
H
 3.2
 3.0
 2.8
 2.6
 2.4
 2.2
 2.0
 1.8
 1.6
 1.4
 1.2
 1.0
0.8
0.6
0.4
                                Reported Detection Level - 0.1 jitg/1
          198S   I 1987
              1988   1988
                                1990
                                                1992
                                                        1993
                                  6-45

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                                         Table 6-1
                                 Mill Discharge Status
(a)MUls are counted in every subcategory in which they have production.
(b)Includes three mills that discharge wastewater directly and dispose of wastewater by on-site land application.
(c)For industry total, mills in multiple subcategories are  counted only once.
                                               6-46

-------
                                   Table 6-2
        Approximate Percentage of Total Industry Water Use and
                  Wastewater Discharge by Process Area,
                   as Reported in the 1990 Questionnaire
        Process Area
 Wood Preparation
Percentage of Total Water Use
                                        3%
Percentage of Total Wastewater
  Discharged to Treatment
 Pulping
 Chemical Recovery
Bleaching
Pulp Drying

Power Operation
                                        15%
            8%
                                        13%
            1%

            8%
                                                                  16%
                                       9%

                                      21%
             1%
                                                                   6%
Secondary Fiber Processing

Pulp Handling
Paper/Paperboard Making
Broke Processing and Storage

TOTAL
            5%
                                       4%
                                       4%

                                      37%
                                    6-47

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                                                6-49

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                                                       Table 6-7
                                            Priority Pollutant List
   1  acenaphthene
   2  acrolein
   3  acrylonitrile
   4  benzene
   5  benzidine
   6  carbon tetrachloride (tetrachloromethane)
   7  chlorobenzene
   8  1,2,4-trichlorobenzene
   9  hexachlorobenzene
  10  1,2-dichloroethane
  11  1,1,1-trichloroethane
  12  hexachloroethane
  13  1,1-dichloroethane
  14  1,1,2-trichloroethane
  15  1,1,2,2-tetrachloroethane
  16  chloroethane
  17  bis(chloromethyl) ether (has been removed)
  18  bis(2-chloroethyl) ether
  19  2-chloroethyl vinyl ether (mixed)
  20  2-chloronaphthalene
  21  2,4,6-trichlorophenol
  22 parachlorometa cresol (4-chloro-3-methylphenol)
  23  chloroform (trichloromethane)
  24 2-chlorophenol
  25 1,2-dichlorobenzene
  26 1,3-dichlorobenzene
  27 1,4-dichlorobenzene
  28  3,3'-dichlorobenzidine
  29  1,1-dichloroethylene
  30  1,2-trans-dichloroethylene
  31  2,4-dichlorophenol
  32  1,2-dichloropropane
  33  1,3-dichloropropyIene
  34  2,4-dimethylphenol
  35  2,4-dinitrotoluene
  36  2,6-dinitrotoluene
 37  1,2-diphenylhydrazine
 38  ethylbenzene
 39  fluoranthene
 40 4-chlorophenyl phenyl ether
 41 4-bromophenyl phenyl ether
 42 bis(2-chloroisopropyl) ether
 43 bis(2-chloroethoxy) methane
 44 methylene chloride (dichloromethane)
 45 methyl chloride (chloromethane)
 46 methyl bromide (bromomethane)
 47 bromoform (tribromomethane)
 48 dichlorobromomethane
 49 trichlorofluoromethane (has been removed)
 50 dichlorodifluoromethane  (has been removed)
 51 chlorodibromomethane
 52 hexachlorobutadiene
 53 hexachlorocyclopentadiene
 54 isophorone
 55  naphthalene
 56  nitrobenzene
 57  2-nitrophenoI
 58  4-nitrophenol
 59  2,4-dinitrophenol
 60 4,6-dinitro-o-cresoI (2-methyl-4,6-dinitrophenol)  •
 61  N-nitrosodimethylamine
 62  N-nitrosodiphenylamine
63 N-nitrosodi-n-propylamine
64 pentachlorophenol
65 phenol
   66  bis(2-ethylhexyl) phthalate
   67  butyl benzyl phthalate
   68  di-n-butyl phthalate
   69  di-n-octyl phthalate
   70  diethyl phthalate
   71  dimethyl phthalate
   72  benzo(a)anthracene (1,2-benzanthracene)
   73  benzo(a)pyrene (3,4-benzopyrene)
   74  3,4-benzo fluoranthene (benzo(b)fluoranthene)
   75  benzo(k)fluoranthene (11,12-benzofluoranthene)
   76  chrysene
   77  acenaphthylene
   78  anthracene
   79  benzo(ghi)perylene (1,12-benzoperylene)
   80  fluorene
   81  phenanthrene
   82  dibenzo(a,h)anthracene (1,2,5,6-dibenzanthracene)
   83  indeno(l,2,3-cd)pyrene (2,3-o-phenylenepyrene)
   84 pyrene
   85 tetrachloroethylene
   86 toluene
   87 trichloroethylene
   88 vinyl chloride (chloroethylene)
   89 aldrin
   90 dieldrin
   91  chlordane (technical mixture & metabolites)
   92  4,4'-DDT (p,p'-DDT)
   93  4,4'-DDB (p,p'-DDX)
   94  4,4'-DDD (p,p'-TDE)
   95  alpha-endosulfan
   96 beta-endosulfan
  97  endosulfan sulfate
  98 endrin
  99 endrin aldehyde
 100  heptachlor
 101  heptachlor epoxide
 102  alpha-BHC
 103  beta-BHC
 104 gamma-BHC (lindane)
 105 delta-BHC
 106 PCB-1242 (Arochlor 1242)
 107 PCB-1254 (Arochlor 1254)
 108 PCB-1221 (Arochlor 1221)
 109 PCB-1232 (Arochlor 1232)
 110 PCB-1248 (Arochlor 1248)
 111 PCB-1260 (Arochlor 1260)
 112 PCB-1016 (Arochlor 1016)
 113 toxaphene
 114 antimony (total)
 115  arsenic (total)
 116  asbestos (fibrous)
 117  beryllium (total)
 118  cadmium (total)
 119  chromium (total)
 120  copper (total)
 121  cyanide (total)
 122  lead (total)
 123  mercury (total)
 124  nickel (total)
 125  selenium (total)
 126  silver (total)
127  thallium (total)
128 zinc (total)
129 2,3,7,8-tetrachlorodibenzo-p-dioxin
                                                         6-55

-------
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                                          6-58

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-------
                            Table 6-10

                    Secondary Fiber Deink Mill
      CDDs and CDFs in Wastewater Treatment Plant Sludge
z=s£=zss=3S=s3£==sz=s£===================
CDDs and CDFs
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
OCDD
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8 PeCDF
1,2,3,4,7,8 HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,23,4,7,8,9-HpCDF
OCDF
U, 	 ====^====================
Wastewater Sludge
86/05/89
ND
ND
ND
ND
ND
160
2,200
89
ND
7
ND
ND
ND
ND
41
ND
190
=====
06/06/89
22
ND
ND
ND
ND
370
4,400
120
ND
ND
ND
ND
ND
64
ND
310
==================
06/07/89
ND
ND
ND
ND
ND
280
3,800
110
ND
ND
ND
ND
ND
ND
ND
270
==================
ND - Not detected at 0.1 - 0.8.ng/kg.
                                6-60

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                                                       7.0 Selection of Pollutant Parameters
7.0    SELECTION OF POLLUTANT PARAMETERS

The Agency conducted a study of the pulp, paper, and paperboard industry to establish
effluent  limitations  guidelines  and  standards  reflecting  the  best  practicable  control
technology currently available (BPT), best conventional pollutant control technology (BCT)
best available technology economically achievable (BAT), new source performance standards
(NSPS),  and pretreatment standards for new and for existing sources (PSNS and PSES).
The study included a review of existing regulations, a review of available literature, and an
evaluation of existing data, data obtained from an industry-wide questionnaire, data from
foreign mills, as well as data obtained from short- and long-term sampling at 19 separate
facilities.  The Agency identified the following 24 pollutants or pollutant parameters as
present in pulp, paper, and paperboard wastewaters and determined they should be subject
to limitation under BPT, BCT, and BAT effluent limitations guidelines, NSPS, PSNS and
PSES, as appropriate:                                                          '
      Conventional Pollutants:
      Nonconventional Pollutants:
      Priority Pollutants:
 biochemical oxygen demand (BOD5)
 total suspended solids (TSS)
 pH

 adsorbable organic halides (AOX)
 chemical oxygen demand (COD)
 color
 acetone
 methyl ethyl ketone (MEK)
 tetrachlorocatechol
 tetrachlorguaiacol
 trichlorosyringol
 2,4,5-trichlorophenol
 3,4,5-trichlorocatechol
 3,4,5-trichloroguaiacol
 3,4,6-trichlorocatechol
 3,4,6-trichloroguaiacol
 4,5,6-trichlorguaiacol
 2,3,4,6-tetrachlorophenol
 2,3,7,8-tetrachlorodibenzofuran(2,3,7,8-TCDF)

 chloroform
methylene chloride
pentachlorophenol (PCP)
2,4,6-trichlorophenol
2,3,7,8-tetrachlorodibenzo-p-dioxin
      (2,3,7,8-TCDD)
                                       7-1

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                                                     7.0  Selection of Pollutant Parameters
Conventional pollutants are those defined in Section 304(a)(4) of the CWA, namely TSS,
BOD5  oil and grease, fecal conform, and pH.  Analytical measures of TSS, BOD5, and oil
and grease are not chemical-specific determinations but aggregate measures of suspended
particulates, oxygen-demanding substances, and freon-extractable  substances in water,
respectively.  Specific compounds contributing to these measures may or may not exhibit
toxic effects and may or may not be among the 126 priority pollutants defined by the CWA.
The priority pollutants are specifically designated elements or compounds that exhibit toxic
effects in aquatic systems and, if determined  to be present at significant levels,  must be
regulated by categorical  technology-based effluent limitations guidelines and standards
pursuant to Section 301(b)(2)(A) of the CWA.  Nonconventional pollutants are all other
pollutants that are neither- the five listed conventional pollutants nor the designated 126
priority pollutants. Nonconventional pollutants may be aggregate measures such as COD
or AOX or specific elements or compounds such as chlorine (C12), ammonia-N (NH3-N), and
237 8-TCDF  Nonconventional  pollutants can be nontoxic  (e.g., iron at low levels) or
highly toxic (e.g., 2,3,7,8-TCDF).  The Agency has the authority and discretion to limit
nonconventional pollutants in categorical effluent limitations guidelines and standards as
appropriate based upon the presence of these pollutants and  findings  that the removal or
treatment of the pollutants is technically and economically  achievable.

7.1    Review of Previous Regulations

Conventional,  nonconventional,  and  priority  pollutants  are  currently  limited  under
promulgated  effluent  limitations guidelines and new source performance  standards
applicable to  wastewater discharges from the Pulp, Paper, and Paperboard and Builders
Paper and Board Mills  Point  Source Categories (1,2,3,4).   Table 7-1 summarizes the
pollutants that have been regulated or have been addressed in previous Agency rulemakings
for each of the current subcategories of the industry.

7.1.1  Conventional Pollutants

Regulations limiting the discharge of BOD5, TSS, and pH have been promulgated for all 25
 of the current subcategories of the pulp, paper, and paperboard industry with one exception:
 the BOD5 effluent limitation guideline for the acetate grade segment of the Dissolving
 Sulfite Pulp Subcategory (Subpart K) which was remanded by the court to the Agency (5).
 The Agency reproposed this limitation on September 6, 1985; however, as of this writing,
 this limitation has not been promulgated (6).  The conventional pollutants BOD5, TSS, and
 pH are subject to regulation as specified in Section 304(b)(l)(A) of the CWA based upon
 the "best practicable control technology currently available" (BPT); Sections 301(b)(2)(E)
 and 304(a)(4) of the CWA through identification of the "best conventional pollutant control
 technology" (BCT); and, Section 306 of the CWA based on the "best available demonstrated
 technology" (BAT).
                                         7-2

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                                                      7.0 Selection of Pollutant Parameters
  7.1.2  Nonconventional Pollutants

  Two nonconventional pollutants were controlled under prior regulations: settleable solids
  and color. In 1974, when the Agency was developing BPT regulations for the industry
  settleable solids were limited for the Builders' Paper and Roofing Felt Subcategory of the
  Builders' Paper and Board Mills Point Source Category, now the Secondary Fiber Non-
  ?ei^e    ategOIT (SubPart J) (7)- Settleable solids can be measured during the analysis
  tor TSS, a conventional pollutant. In 1982, when the Agency was developing BCT and BAT
  ieg!J cSS^ f(V ~C induStry' EPA concluded that (a) settleable solids would be controlled
  by JNbPb tor  TSS and by limitations, when established, that reflect BCT- and (b) BAT
  limitations for control of settleable solids were unnecessary and redundant (8). '

  In  1974, BAT effluent limitations guidelines were established  for control of color in
  SSSSP8 ?°m "?* in the Unbleached Kraft, Sodium-Based Neutral Sniffle Semi-Chemical
  (NSSC),  Ammonia-Based  NSCC,  and Unbleached  Kraft/NSSC  (Cross  Recovery)
  Subcategories (9). EPA also proposed BAT effluent limitations guidelines for color for the
 Dissolving Kraft, Market Bleached Kraft, BCT (Paperboard, Coarse, and Tissue) Bleached
 Kraft Fine Bleached Kraft, and Soda Subcategories.  However, BAT effluent limitations
 guidelines were not promulgated for these Subcategories. In 1982, when the Agency was
 developing BCT and BAT limitations for the industry, EPA made the determination that
 the  discharge of color in pulp, paper, and paperboard effluent was not of uniform national
 concern and therefore withdrew all color limitations (1).

 7.1.3  Priority Pollutants

 In 1977, BPT limitations for zinc were established for the Groundwood-Chemi-Mechanical
 Groundwood-Thermo-Mechanical,  Groundwood-CMN Papers, and Groundwood-Fine
 f a?f^ i   Categ°neS (10)' ^ 1982' BAT effluent ^tations for zinc were established equal
 to BPT limitations for the Groundwood-Thermo-Mechanical, Groundwood-CMN Papers
 and  Groundwood-Fine Papers Subcategories where zinc hydrosulfite was being used as a
 bleaching chemical (1).  In addition to zinc, BAT effluent limitations for the control of
 trichlorophenol (TCP) and pentachlorophenol (PCP) were established for 24 Subcategories
 in November 1982 (1) BAT effluent limitations were not established for the GroundwooJ
                                    subcateg<*y was excluded from regulation under
                                  Resources  Defen^ Council  (NRDC)  settlement
Effluent Hmitations guidelines for polychlorinated biphenyls (PCBs) for the fine and tissue
paper products sectors of the Deink Subcategory were proposed in November 1982 (13)
In comments to the proposed regulations, industry representatives explained that the PCB
content of wa^tepaper had dropped steadily after they were  no longer  used in the
manufacture of carbonless copy paper. Effluent data obtained subsequent to the proposed
                                      7-3

-------
                                                      7.0 Selection of Pollutant Parameters
regulation indicated that discharge concentrations were in fact decreasing and, as a result,
the regulations were not promulgated.

7.2   Selection Criteria

Tte Agents detenninatto^
from fhe pulp, paper, and paperboard industry involved a review of existing regulations and
an evSuation of existing data, data obtained from the 1990 questionnaire, data obtained
from  foreign mills, as well as data obtained from completion of an extensive sampling
pro-am. The Agency's effort with regard to this proposed regulation focused on two ; major
Redevelopment of BAT effluent limitations guidelines for the chemical pulp nnlls that
bleach wood; and, revision of BPT/BCT effluent limitations guidelines for  the entire
industry.

7.2.1   Conventional Pollutants

The Agency has designated the following pollutants as conventional:  BOD5, TSS, pH, oil
and grease" and fecal coliform (14,15). Of these, the Agency determined, as part of previous
rulemaking efforts, that those of significance for the pulp, paper, and paperboard industry
are BOD5 TSS, and pH (16,17).  During the review conducted for this proposal, the Agency
did not obtain any new information or data that caused it to alter its previous determination.

7.2.2  Nonconventional and Priority Pollutants

 As noted above, nonconventional pollutants are  those that have not been designated as
 conventional or priority pollutants. For the purposes of this section priority and non-
 conventional pollutants are addressed together.  Priority pollutants are those pollutants that
 ^1^ designated as such pursuant to Section 307(a)(l) of the CWA (14,18,19). Section
 301fb)(2)(F) of the CWA gives the EPA Administrator the authority to regulate additional
 compounds if warranted.  The additional compounds are the nonconventional pollutants^
 To develop the proposed regulation, the Agency studied the following nonconventional and
 priority pollutants:  AOX, COD,  and color; chlorinated dibenzo-p-dioxms (CDDs) and
 chlorinated dibenzofurans (CDFs); volatile organics; chlorinated phenohcs;  pesticides/
 herbicides; other semi-volatile organics; and metals.

 When developing the current BAT effluent limitations guidelines during the late 1970s and
 early 1980s, the Agency used a defined set of 126 toxic pollutants which became known as;
 "priority pollutants "  Table 6-7 lists the priority pollutants  F^]^^^P^^
 126 priority pollutants have been highlighted with an astensk (* I in Tables 7-3, 7-4 7_-5, and
 7-6 in this section. In addition to  the 126 priority pollutants, the NRDC Consent Decree
 set out a defined set of criteria for the selection of pollutant parameters to be regulated
 (12).
                                          7-4

-------
                                                        7.0 Selection of Pollutant Parameters
 While the Agency is no longer bound by the conditions of the NRDC Consent Decree, the
 Agency used a screening protocol similar to that of the NRDC Consent Decree for selecting
 pollutants  and pollutant parameters  for  this proposed  regulation.  A pollutant was
 eliminated from further consideration  for regulation if any of the following criteria were
 met:

       •      The pollutant was not detected in the effluent with the use of analytical
              methods promulgated pursuant to Section 304(h) of the CWA or with other
              state-of-the-art methods;

       •      The pollutant was detected in the effluent from only one mill or in a small
              number of samples and the pollutant's presence could not be confirmed;

       •      The pollutant was  detected  but below the concentration that  could be
              achieved with treatment;

       •      The pollutant was detected but below a concentration of concern;

       •      The pollutant could be controlled by the control of other pollutants; and

       •     No analytical method is available for the pollutant.

 The above protocol is focused on pollutants detected in final effluents with emphasis on the,'
 ability to detect and control pollutants with end-of-pipe treatments. With the current
 emphasis on pollution prevention, the Agency also considered as selection criteria the, ability
 to minimize generation of pollutants through process changes and the bioaccumulation
 potential of pollutants present at trace levels.

 7.3    Pollutants Not Regulated

 A total of 443 specific pollutants were the subject of extensive study for the proposed
 regulation (see Section 6.4). These 443 pollutants included 124 of the  126 priority poUutants
 and 319 nonconventional pollutants.  Asbestos and cyanide were the two priority poUutants
 not included because they are not expected to be present at concentrations of concern in
pulp and paper  mill effluents.  EPA conducted short- and long-term studies as weU as
reviewed available data, which led  to  the exclusion of  many of these pollutants  from
regulations,  based upon the factors outlined  in  Section  7.2.2.  Table  7-2 presents a
breakdown of the number of pollutants detected at more than one mill, the number detected
at only one mill, the  number not detected, and the total number in each pollutant class
                                        7-5

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                                                      7.0  Selection of Pollutant Parameters
7.3.1  Pollutants Not Detected

Of the 443 priority and nonconventional pollutants which were analyzed as part of the short-
and long-term studies at chemical pulp mills that bleach, 363 were not detected in the final
effluent with the use of analytical methods promulgated pursuant to Section 304 (h) ol the
CWA or with  other state-of-the-art methods.  Table 7-3 lists these  pollutants, the number
of mills sampled, and the respective analytical detection levels.  Because these pollutants
were not detected, they have been eliminated by the Agency as pollutants of concern for
purposes of this proposed regulation.

7.3.2  Pollutants Detected But Only At One Facility

Of the 443 priority and nonconventional pollutants which were analyzed as part of the short-
and long-term studies at chemical pulp mills that bleach, 31 were detected at only one mill.
Table 7-4 lists these pollutants.  Most of the 31 pollutants detected at only one mill werj
detected at levels so low they are not considered treatable in large effluent flows with
available end-of-pipe treatment technologies. Because these pollutants were detected at
only one facility, they have been eliminated by the Agency as pollutants of concern for
purposes of this proposed regulation.

Eleven pesticide/herbicide pollutants were found at only one mill. Six of seven (alpha-BHC,
captan, dieldrin, gamrna-BHC, isodrin, and PCNB) reported as being detected at one mill,
were detected at concentrations less than or equal to the detection limits reported for these
compounds in other samples from the same mill. In addition, because EPA has banned all
uses of alpha-BHC, dieldrin and isodrin (aldrin) from the United States, it is unlikely that
 these pesticides would be detected-in the future.   There is no evidence to suggest these
pesticide compounds are generated as a result of pulp and paper mill operations.

 Data obtained for trichlorofluoromethane were dropped from consideration in the long-term
 study because it was  a suspected laboratory contaminant.   Similarly, bis(2-ethylliexyl)
 phthalate was eliminated from consideration in the original BAT  screening study because
 it, too, was a suspected laboratory  contaminant (8).  For purposes of pollutant selection,
 these pollutants are considered as not-detected.

 The only pollutant detected at only one mill with a concentration of concern is naphthalene,
 which was detected at a concentration of 1,800 /*g/L.  A review of the data collected during
 the  development of the BAT effluent limitations guidelines promulgated in 1982 reveals
 that for chemical pulp mills that  bleach, the naphthalene concentration in 12 effluent
 samples ranged from 7 to 88 Mg/L.  Based upon these data, the Agency believes the single
 high analysis for naphthalene collected as part of the short-term study for this regulation is
 not representative.
                                          7-6

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                                                       7.0 Selection of Pollutant Parameters
 7.3.3  Pollutants Detected But Below Concentrations of Concern

 Of the 443 pollutants analyzed in samples from mills in the chemical pulping subcategories
 that bleach, 49 were detected at  more  than  one mill  (see Table 7-5).  Many of these
 pollutants have been eliminated by the Agency as pollutants of concern because they were
 detected below a concentration of concern.  Those pollutants eliminated are listed in Table
 7-5 with a check mark (/) in the far right column. Among the pollutants eliminated are the
 mono- and dichlorophenols, o-cresol, barium,  and vanadium, which were detected below
 concentrations of concern based on estimates of concentrations known to cause acute and,
 chronic toxicity (20,21).  Calcium, silicon, and zinc were eh'minated because these pollutants
 were detected at higher concentrations in mill water supplies than in treated effluents.
 Boron, iron,  and  strontium  were ehminated because they were detected at similar
 concentrations in mill water supplies as in treated effluents. Phosphorus and titanium were
 eliminated because these pollutants were detected at concentrations below those considered
 treatable (22). Other pollutants (aluminum, magnesium, manganese, potassium, sodium, and
 sulfur) were eliminated because  they were detected at concentrations not  considered
 treatable with end-of-pipe treatment technologies suitable for large effluent flows.

 7.3.4  Pollutants Controlled by Control of Another Analyte

 Three CDDs  (2,3,7,8-TCDD,  1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin  (HpCDD)  and
 octachlorodibenzo-p-dioxin (OCDD)), and one CDF (2,3,7,8-TCDF), were detected in the
 treated effluents from more than one mill. These compounds are generated in the bleaching
 of chemical pulps with chlorine and chlorme-containing compounds. 2,3,7,8-TCDD is the
 most toxic CDD and 2,3,7,8-TCDF is one of the  most toxic CDFs. 1,2,3,4,6,7,8-HpCDD and
 OCDD are among the least toxic CDDs.   The international 2,3,7,8-TCDD  toxicity
 equivalency factors  (TEFs) for those congeners are as foUows (23,24):
                 Congener
  2,3,7,8-TCDD
1.0
  2,3,7,8-TCDF
0.1
  1,2,3,4,6,7,8-HpCDD
0.01
  OCDD
                                                               0.001
2,3,7,8-TCDD is considered to be 10 times more toxic than 2,3,7,8-TCDF, 100 times more
toxic than 1,2,3,4,6,7,8-HpCDD, and 1,000 times more toxic than OCDD.
                                       7-7

-------
                                                     7.0  Selection of Pollutant Parameters
The Agency is proposing to regulate 2,3,7,8-TCDD and 2,3,7,8-TCDF and, in so doing will
effectively minimize generation of the most toxic CDDs and CDFs (see  Section 7.5.3.1),
Data obtained as part of the Five-Mill and 104-Mill Studies showed that 2,3,7,8-TCDD and
237 8-TCDF were the principal CDD and CDF congeners found at most mills at the time,
in terms of absolute level, and most notably, in terms of 2,3,7,8-TCDD toxic equivalents
(25,26,27).  Available data indicate that 2,3,7,8-TCDD and 2,3,7,8-TCDF account for more
than 90  percent of equivalent 2,3,7,8-TCDD toxicity for pulp  and paper mill samples.
Accordingly, by limiting 2,3,7,8-TCDD and 2,3,7,8-TCDF, the Agency will effectively control
the toxicity associated with all CDDs and CDFs found in pulp and paper mill effluents.

7.3.5   Pollutants Remaining Under Consideration for Regulation

The following pollutants were detected  in treated effluents from more than one mill at
concentrations that may be of concern:
---.. .
Pollutant
Biphenyl
Carbon Disulfide
Dimethyl Sulfone
Mercury
	
Mills Sampled
3
17
3
3
j *
Mills Fomitd
2
8
3
2
Maximum
Concentration
572.0 /*g/L
176.9 A*g/L
148.0 /*g/L
' 74.0/ig/L
 Carbon disulfide was detected in acid filtrates and treated effluents but not in alkaline
 filtrates.  Biphenyl and mercury were detected in treated effluents from two of three mills
 sampled,  and dimethyl sulfone was found at each of the three mills sampled.  Because of
 potential problems with effluent toxicity and bioaccumulation in the aquatic environment,
 the Agency, while not proposing effluent limitations guidelines and standards at this time,
 has not decided  to exclude  these pollutants from  regulation.   The  Agency will seek
 supplemental data prior  to • promulgation  of the regulation and make a determination
 whether,  or to what extent, to regulate these pollutants.

 7.4    Subcatesories Not Regulated

 As previously stated, the main focus of revising the BAT effluent limitations guidelines for
 the pulp, paper, and paperboard industry was chemical pulp mills that bleach. Two related
 issues were investigated in gathering and analyzing  information and data related  to the
 industry.  The first dealt with potential generation of chlorinated organics at non-chemical
                                         7-8

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                                                       7.0 Selection of Pollutant Parameters
 pulp mills and chemical non-wood pulp mills that bleach with chlorine and/or hypochlorite.
 The second issue investigated was the discharge of PCBs from secondary fiber mills.

 7.4.1  Non-Chemical Pulp Mills and Chemical Non-Wood Pulp Mills  that Bleach with
       Chlorine and/or Hypochlorite

 7.4.1.1        CDDs/CDFs, Chlorinated Phenolics, and Chloroform
       t

 The Agency identified 41 mills that bleach semi-chemical pulps, mechanical pulps, secondary
 fiber pulps, or non-wood pulps with chlorine and/or hypochlorite.  These include:
Subcategory
Non-Wood Chemical Pulp
Non-Wood Chemical Pulp
Non-Wood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-
Deink
'type of MM
Non-Chemical Pulp,
Cotton Linters
Papergrade Sulfite, Hemp
Kraft, Flax, or Cotton
Linters
Secondary Fiber - Deink,
Fine Papers, or Tissue
Secondary Fiber - Non-
Deink, Tissue, Paper, or
Paper from Paperboard
Total
Momfeer
8
1
3
23
6
41
Table 7-6 summarizes the chloroform, chlorinated phenolic compound, and CDD and CDF
data for final effluents from these mills. The data were reported by the mills in response
to the 1990 questionnaire.  Additional data were obtained at one secondary fiber deink mill
sampled by EPA as described in Section 6.4.9.2. These data indicate that some of the same
pollutants are found at non-chemical pulp mills with chlorine and hypochlorite bleaching
operations as are found at chemical pulp mills with chlorine-based bleaching.  The rate of
occurrence is less than at chemical pulp mills and the concentrations of pollutants found are,
for the most part, lower than found at chemical pulp mills.  This is attributable to the
relatively mild bleaching operations performed at most of these mills (lower bleach plant
chemical application rates  to achieve lower pulp brightness targets).
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                                                      7.0 Selection of Pollutant Parameters
The results of the short-term study conducted at one secondary fiber mill show that the
more toxic 2,3,7,8-substituted tetra-, penta-, and hexa-CDDs and CDFs were not found in
the treated effluent  at  low analytical detection  levels,  and that the  relatively mild
hypochlorite bleaching performed did not result in generation of CDDs and CDFs (see
Section 6.4.9.2).  The Agency does not believe that similar secondary  fiber mills are
significant sources of CDDs and CDFs. The relatively high 2,3,7,8-TCDD and 2,3,7,8-TCDF
results presented in Table 7-6 are from a secondary fiber mill with chlorine pulp bleaching.

The levels of chloroform, selected  chlorinated phenolic compounds, 2,3,7,8-TCDD, and
2,3,7,8-TCDF shown in Table  7-6 are significant in the  context of the proposed effluent
limitations guidelines  and standards for the chemical pulp mills.  These poUutants may be
controlled by substituting peroxide, hydrosulfite, or other non-chlorine-containing chemicals
for chlorine  and hypochlorite.  The Agency, while not  proposing effluent  limitations
guidelines and standards at this tune, has not decided to  exclude these subcategories from
regulation. The Agency  is considering whether to establish effluent limitations  guidelines
and standards for CDDs  and CDFs, chlorinated phenolic compounds, and volatile organic
compounds for non-chemical pulp nulls and non-wood chemical pulp mills that bleach with
chlorine and chlorine-containing compounds as part of its Section 304(m) planning process.
 7.4.1.2
PCBs Discharged in Secondary Fiber Mill Effluents
 The Agency has PCB effluent data for seven secondary fiber deink mills and one secondary
 fiber non-deink mill obtained over the period 1985 -1990. These data were obtained from
 1990 questionnaire  responses,  and,  in one case, were supplemented with more recent
 NPDES monitoring data obtained from  a state agency.  These data show PCB effluent
 concentrations ranging from less than 0.1 /tg/L to more than 60 jttg/L.  Most of the higher
 values were  recorded during the early part of that period.  More recent data for one
 secondary fiber deink mill that has implemented specific controls show that PCB effluent
 concentrations have been consistently not detected at less than 0.1 j*g/L (see Figure 6-5).
 Aside from possible changes in fiber supply or addition of costly end-of-pipe wastewater
 treatment technologies  such  as adsorption on granular  activated carbon  or various
 membrane technologies, the Agency does not believe there are other feasible means to
 reduce effluent concentrations of total PCBs at  secondary fiber mills below concentrations
 attained at this mill.

 Because the available PCB effluent data for other secondary fiber mills indicate a wide
 range of PCB discharges above treatable concentrations, the Agency is considering whether
 to establish PCB effluent limitations guidelines and standards for secondary fiber mills as
 part of its Section 304(m) planning process.
                                        7-10

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                                                       7.0 Selection of Pollutant Parameters
 7.5    Pollutants Selected for Regulation

 7.5.1  Conventional Pollutants

 Based upon a review of available data, the Agency is proposing to revise the current BOD5
 and TSS effluent limitations guidelines for all  subcategories of the pulp,  paper  and
 paperboard industry. Table 7-7 summarizes all pollutants proposed for limitation by revised
 subcategory.

 7.5.2  AOX, COD, and Color

 7.5.2.1       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. For pulp, paper  and
paperboard wastewaters, essentially all of the halogenated organic substances measured as
AOX are chlorinated compounds which result from the bleaching of pulps with elemental
chlorine and chlorinated compounds such as chlorine dioxide and hypochlorite.

The  Agency is proposing effluent  limitations  guidelines and standards for AOX for the
following reasons:
      (1)
      (2)
      (3)
 AOX is an approximate measure of the total amount of chlorinated matter
 generated  from bleaching  pulp with  chlorine  and  chlorine-containing
 compounds. As such, it is an aggregate measure of the pollution potential of
 chlorinated compounds generated in pulp bleaching, similar in some respects
 to BOD5, which is an aggregate measure of the oxygen-demanding potential
 of wastewaters.  Some  of the  organic material  comprising  AOX is not
 measured or may be only partially measured with the BOD5 test.

 The estimated total discharge of AOX from chemical pulp mills that bleach
 is about 51,100 kkg/yr, and is estimated to be reduced by about 45,100 kkg/yr
 after implementation of the proposed rule.

 Relatively few specific chlorinated compounds contributing to AOX have been
 isolated (28).  Both low- and high-molecular weight chlorinated compounds
 are measured by the AOX test.  High-molecular weight chlorinated material
 comprising AOX is persistent in the aquatic environment and a portion of the
 high-molecular weight material is bioaccumulative and toxic (29 30)  Specific
 tests to measure  the fraction of AOX that may be bioaccumulative (eg
 EOX-extractable  organic halogens;  EPOX-extractable  persistent organic
halogens) have not been standardized and there is no substantial database for

                           7-11

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                                                     7.0 Selection of Pollutant Parameters
            these fractional measures of AOX upon which to establish effluent limitations
            guidelines and'standards;

      (4)    Statistically valid relationships among AOX and specific chlorinated organic
            compounds have not been established.  It is unlikely that correlations for a
            macro constituent such as AOX, which is measured at the mg/L level, with
            micro constituents such as chlorinated phenolics measured at the pg/L level
            and CEJDs/CDFs measured at the pg/L level, can be made.  However, further
            data gathering and more refined statistical analysis may establish relationships
            among AOX and  certain chlorinated  pollutants  or groups  of pollutants.
            Accordingly, although controls for chlorinated phenolics and CDDs and CDFs
            will result in reduction in formation of AOX, controls for specific chlorinated
            compounds cannot ensure control of all compounds contributing to AOX;

      (5)    The AOX test is relatively inexpensive, can be performed in a short amount
            of time, and is reliable. For these reasons, AOX has been adopted by several
            jurisdictions around the world for the measurement and control of bleached
            chemical pulp wastewater  (see Table 7-8).

      (6)    Because the AOX test is relatively inexpensive and can be performed in a
            short amount of time, it is  suitable for use in NPDES permits as a daily
            measure of mill performance, much like the BOD5 and COD tests, as opposed
            to the more expensive monitoring for 2,3,7,8-TCDD and 2,3,7,8-TCDF and
            chlorinated phenolics (proposed to be conducted monthly).

Under the CWA, the Agency has the authority and the obligation to develop technology-
based effluent limitations and standards for nonconventional pollutants where appropriate.
For  the reasons set out above, EPA is proposing effluent  limitations guidelines and
standards for AOX.
7.5.2.2
COD
COD effluent limitations guidelines and standards are based upon process technologies
(closed screen rooms, effective brown stock washing, and implementation of BMP Plans for
pulping liquor management, spill prevention, and control) that will control losses and
discharges of pulping liquors and associated wood extractives, which recently have been
postulated as the source of toxicity to aquatic systems (31).  Effluent limitations for COD
are being proposed for the chemical pulping subcategories, both bleached and unbleached,
including the Dissolving Kraft Subcategory (Subpart A), Bleached  Papergrade Kraft and
Soda Subcategory (Subpart B), Unbleached Kraft Subcategory (Subpart C), Papergrade
Suffite Subcategory (Subpart E), and Semi-Chemical Subcategory (Subpart F). The Agency-
also intends to propose COD effluent limitations for the Dissolving Sulfite Subcategory

                                        7-12

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                                                       7.0  Selection of Pollutant Parameters
 (Subpart D); however, there are insufficient data available to propose limitations for this
 subcategory at this time.
 7.5.2.3
Color
 Color in treated effluents from both unbleached and bleached chemical pulp mills is an
 easily recognized characteristic of chemical pulp mill wastewaters.  Pulp and paper mill
 effluent color has become a major concern in several areas. When promulgating the current
 effluent guidelines and standards regulation, EPA decided not to regulate color because the
 end-of-pipe treatment technologies evaluated as the basis for proposed effluent limitations
 guidelines and  standards  were considered too costly and color  was not,  at the time,
 determined to be an issue  of uniform national concern.  The technologies evaluated
 included chemically assisted clarification (CAC) of whole mill effluents, effluent filtration,
 and selective treatments for bleach plant caustic extraction stage filtrates.

 The process changes  used as a basis for the proposed effluent limitations guidelines and
 standards will result in significant reduction of effluent color from:

       (1)   More extensive  delignification of  chemical wood pulps  through use of
             extended cooking and oxygen delignification;

       (2)    Effective brown stock pulp washing;

       (3)    Addition of oxygen and peroxide to bleach plant caustic extraction stages; and

       (4)    Effective pulping  liquor management, spill prevention, and control.

Accordingly, because color is  a useful measure of the performance of these pollution
prevention process technologies, the Agency is proposing to regulate color.

Effluent limitations guidelines and standards for  color are being proposed for the Bleached
Papergrade Kraft and Soda Subcategory (Subpart B).  The Agency also intends to propose
color effluent  limitations guidelines and standards for the Dissolving Kraft  Subcategory'
(Subpart A), the 'Dissolving Sulfite Subcategory (Subpart D), and the Papergrade Sulfite
Subcategory (Subpart E); however, there are insufficient data available to propose effluent
limitations guidelines and standards for these subcategories at this time.
                                       7-13

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                                                     7.0 Selection of Pollutant Parameters
7.5.3  Priority and Nonconventional Pollutants
7.5.3.1
CDDs and CDFs
The dioxin molecular framework consists of two benzene rings connected by two oxygen
bridges. There are eight positions where substitution of hydrogen atoms by other atoms or
by organic or inorganic radicals can occur. The furan molecule has a similar structure, but
has one oxygen bridge  rather than two.  2,3,7,8-TCDD is one of 75 CDD congeners with
various chlorine substituents.  There are 135 chlorinated dibenzofurans, all of which have
the same basic chemical structure and many of which have qualitatively similar toxicities
(32).

2,3,7,8-TCDD is the most completely studied of the CDDs and CDFs. Exceptionally low
doses  of 2,3,7,8-TCDD  elicit a wide range of toxic responses in animals,  including
carcinogenicity, teratogenicity, fetotoxicity, reproductive dysfunction, and immunotoxicity
(33).

Pulp, paper, and paperboard mills that chemically pulp and bleach wood with chlorine and
chlorine-containing compounds generate significant discharges  of toxic pollutants from the
pulping and  bleaching processes.  Such toxic pollutants include chlorinated dioxins and
furans, particularly 2,3,7,8-TCDD and 2,3,7,8-TCDF, and other CDD and CDF compounds.
None of the  bleaching chemical pulp mills in the 104-Mffl Study were found to be free of
2378-TCDD  and  2,3,7,8-TCDF  (24).  Data gathered by  the  Agency indicate  that
approximately 410  grams of 2,3,7,8-TCDD and  2,3,7,8-TCDF combined are discharged,
annually (as  of 1992) to surface waters by the mills using those bleaching operations.
                                                                            i
Because of the toxicity of the CDDs and CDFs and the ability to reduce formation of these
compounds through process changes, effluent limitations guidelines and standards for 2,3,7,8-
TCDD and 2,3,7,8-TCDF are included in the proposed regulations in the Dissolving Kraft
Subcategory  (Subpart A), Bleached Papergrade Kraft and Soda Subcategory (Subpart B),
Dissolving Sulfite Subcategory (Subpart D), and Papergrade Sulfite Subcategory (Subpart E).

 7.5.3.2       Volatile  Organic Compounds

 Among the 57 volatile  organic compounds for which wastewater samples were analyzed, the
 four  detected most often were acetone, chloroform, methylene chloride, and methyl ethyl
 ketone (MEK). These four compounds were detected in bleach plant effluent samples at
 most long-term study mills.   Under the CWA,  chloroform and methylene chloride are
 priority pollutants, and MEK and acetone are nonconventional pollutants. Chloroform,
 methylene chloride, and MEK also are listed as hazardous air pollutants (HAPs).  Data
 gathered by the Agency indicate that a total  of approximately 1,530 kkg/yr of these four
 volatile organic compounds were discharged in wastewaters in  1992.  These compounds are

                                        7-14

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                                                       7.0 Selection of Pollutant Parameters
  also emitted to the atmosphere.  The proposed regulations will reduce both wastewater
  discharges and atmospheric emissions of these compounds.  For these reasons, these four
  compounds are proposed for regulation in the Dissolving Kraft Subcategory (Subpart A)
  Bleached  Papergrade Kraft  and  Soda Subcategory (Subpart B),  Dissolving  Sulfite
  Subcategory (Subpart D), and Papergrade Sulfite Subcategory (Subpart E).

  7.5.3.3       Chlorinated Phenolic Compounds

  Chlorinatedphenolic compounds include selected chlorinated phenols, chlorinated guaiacols
  chlorinated catechpls, and  chlorinated vanillins.  Chlorinated phenolic compounds  are
  lormed in the  bleaching process at chemical pulp  mills that bleach with chlorine and
  chlorine-containing compounds. Chlorinated phenolic compounds have varying degrees of
  toxicity.  The generation of  these  compounds can also  be minimized  through process
  changes.                                                                   v
                 28 cUormated Phenolic compounds for which samples were analyzed (by.
 Method 1653) were found in bleach plant and final effluents from chemical pulp mills that'
 bleach.  Of the detected chlorinated phenolic compounds, 12 of the higher substituted tri-
 tetra-, and penta-chlonnated compounds are associated with the presence of 2,3,7 8-TCDD
 and 2,3,7,8-TCDF, and also have human health or aquatic life effects. Data gathered bv the
 Agency indicate that 282 kkg/yr of higher substituted chlorinated phenolic compounds are
 discharged in final effluent by bleaching chemical pulp mills.  The 12 compounds proposed
 for regulation are as follows:                                                  F^U
       trichlorosyringol
       2,4,5-trichlorophenol
       2,4,6-trichlorophenol
       3,4,5-trichlorocatechol
       3,4,5-trichloroguaiacol
       3,4,6-trichlorocatechol
3,4,6-trichloroguaiacol
4,5,6-trichloroguaiacol
te'trachlorocatechol
tetrachloroguaiacol
2,3,4,6-tetrachlorophenol
pentachlorophenol.
Because bleaching conditions which favor formation of tri-, tetra-, and penta- chlorinated
phenols also favor formation of 2,3,7,8-TCDD and 2,3,7,8-TCDF, limiting these compounds
™V???££uT P10^688 toward Deducing formation and discharge of 2,3,7,8-TCDD and
^,/,8-J.CDF  below currently  measurable concentrations.   These 12  compounds are
proposed  for  regulation in the Dissolving Kraft Subcategory  (Subpart A),  Bleached
SSSf f™   fPand S°f j^^ 
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                                                    7.0 Selection of Pollutant Parameters



7.6   References

1.     Federal Register, 47 FR 52019, 40 CFR 430 and 431, November 18, 1982.

2.     Federal Register, 48 FR 13176, 40 CFR 430 and 431, March 30, 1983.

3.     Federal Register, 48 FR 31405, 40 CFR 430 and 431, July 8, 1983.

4.     Federal Register, 51 FR 45241, 40 CFR 430 and 431, December 17, 1986.

5.     Weyerhaeuser Company, et al. v. Costle, 590 F. 2nd 1011; D.C.  Circuit 1987.'

6.    Federal Register, 50 FR 36444, 40 CFR 430, September 6, 1985.

7.    Federal Register, 39 FR 16578, 40 CFR 431, May 9, 1974.

8     US. EPA, Office of Water Regulations and Standards. Development Document for
      Effluent  Limitations  Guidelines,  New  Source  Performance   Standards  and
      Pretreatment Standards for the Pulp, Paper, and Paperboard and the Builders' Paper
      and Board Mills Point Source Categories.  EPA 440/1-82-025, U.S. Environmental
      Protection Agency, Washington, D.C., October 1982.

9.    Federal Register, 39 FR 18742, 40 CFR 430, May 29. 1974.

 10.    Federal Register, 42 FR 1398, 40 CFR 430, January 6, 1977.

 11.    Natural Resources Defense Council, Inc., et al. v. Train, United States District Court
       for the District of Columbia, (8 ERC 2120), June 8, 1976.

 12    Natural Resources Defense Council, Inc., et al. v. Costle, United States District Court
       for the District of Columbia, (12 ERC 1833), March 9, 1979.

 13.    Federal Register, 47 FR 52066, 40 CFR 430, November 18, 1982.

 14.    Federal Register, 44 FR 44503, 40 CFR 401, July 30, 1979.

 15.    Federal Register, 44 FR 52685, 40 CFR 401, September 10, 1979.

 16.    U.S. EPA, Office of Water.   Development  Document for Effluent Limitations
       Guidelines and New Source Performance Standards for the Unbleached Kraft and
       Semi-Chemical Pulp Segment of the Pulp, Paper, and Paperboard Mills Point Source
                                        7-16

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                                                      7.0 Selection of Pollutant Parameters
 17.
 18.

 19.

 20.




 21.




 22.
23.
24.
25.
26.
 Category. EPA440/l-74-025-a, U.S. Environmental Protection Agency, Washington
 D.C., May .1974.                                                       &

 U.S. EPA, Office  of  Water.  Development Document for Effluent Limitations
 Guidelines and New Source Performance Standards for  the  Bleached 'Kraft,
 Groundwood, Sulfite, Soda, Deink, and Non-Integrated Paper Mills Segment of the
 Pulp, Paper, and Paperboard  Point Source Category.  EPA 440/1-76-047-b, U.S.
 Environmental Protection Agency, Washington, D.C., December 1976.

 Federal Register, 46 FR 2266, 40 CFR 401, January  8, 1981.

 Federal Register, 46 FR 10724, 40 CFR 401, February 4, 1981.

 U.S. EPA. Categorization Assessment Report for Pulp and Paper Analytes Detected
 During Short-Term Sampling 1988-1990.  U.S. Environmental Protection Agency
 Washington, D.C., April 28, 1992.

 Versar Inc. Human Health and Aquatic Life Toxicity Data and References for Pulp,
 Paper,  and Paperboard Industry  Proposed Effluent  Guidelines  Environmental
 Assessment. Springfield, Virginia, October 14, 1993.

 U.S. EPA, Office of Water.  Development Document for  Effluent Limitations
 Guidelines and Standards  for the Nonferrous Metals Manufacturing Point Source
 Category,  Vol.  1.  EPA 440/1-89-010.1, U.S. Environmental Protection Agency
 Washington, D.C., May 1989.

 Bellin, J.S., and D.G. Barnes.  Interim Procedures for Estimating Risks Associated
 With Exposures  to Mixtures of Chlorinated Dibenzo-p-dioxins and -Dibenzofurans
 (CDDs and CDFs).  EPA 625/3-87/012,  U.S. Environmental Protection Agency
 March 1987.                                                             y>

 Bellin, J.S., and D.G. Barnes.  Interim  Procedures for Estimating Risks Associated
 With Exposures  to Mixtures of Chlorinated Dibenzo-p-dioxins and -Dibenzofurans
 (CDDs and CDFs).  EPA 625/3-89/016,  U.S. Environmental Protection Agency
 March 1989.                                                             y'

 U.S. EPA, Office of Water Regulations and Standards. U.S. EPA/Paper Industry
 Cooperative Dioxin  Screening Study.  EPA-440/1-88-025, U.S. Environmental
 Protection Agency, Washington, D.C., March 1988.

Amendola, G.A., et al. The Occurrence and Fate of PCDDs and PCDFs in Bleached
Kraft Pulp and Paper Mills. Chemosphere, 18(1-6):1181-1188. 1989.
                                      7-17

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                                                    7.0 Selection of Pollutant Parameters
27    US  EPA, Office of Water Regulations and Standards. U.S. EPA/Paper Industry
      Cooperative  Dioxin Study  "The  104  Mill  Study"  Summary  Report.   U.S.
      Environmental Protection Agency, Washington, D.C., July 1990.

28    Kringstad,  K.P.  and K.  Lindstrom.    Spent Liquors  From Pulp  Bleaching.
      Environmental Science & Technology,  18(8):236A-248A, 1984.
                                                                i
29    Paasivirta, J. The Nature,  Properties and Fate of Organochlorine Chemicals in the
      Environment. In: Proceedings of the Sixth Colloquium on Pulp  and Paper Mill
      Effluents:  Environmental Modelling of Organochlorine Chemicals.  University ot
      Toronto, Canada, December 10-11, 1991.

30    Higashi, R.M, et al. A Polar High Molecular Mass Constituent of Bleached Kraft
      Mill Effluent Is Toxic to Marine Organisms. Environmental Science & Technology,
      26(12):2413-2420, 1992. .

31    Carey JH   P V. Hodson, K.R. Munkittrick, and M.R. Servos.  Recent Canadian
      Studies on the Physiological Effects of Pulp Mill Effluent  on Fish.  Environment
       Canada, Fisheries and Oceans, 1992.

 32.    U.S. EPA.  National Dioxin Study.   EPA/530-SW-87-025, U.S.  Environmental
       Protection Agency, Washington, D.C.,  August 1987.

 33    US EPA, Office of Water Regulations and Standards. The National Dioxin Study:
       Tiers 3, 5,  6, and 7. . EPA 440/4-87-003,  U.S. Environmental Protection Agency,
       Washington, D.C., February 1987.

 34.    Commonwealth of Australia.  Pulp and Paper Industry Package, Canberra, Australia,
       December  1989.

 35.    Personal Communication from Dan Bodien, U.S. EPA September 1, 1993.

 36    Ontario Ministry of the Environment  Draft Development Document for the Pulp
       and Paper Sector - Effluent Limits Regulation. Toronto, Ontario, Canada, February
       1993.

 37    Folke J  H Edde, and K.J. Lehtinen. The Scientific Foundation of Adsorbable
       Organic Halogens (AOX) As A Regulatory Parameter for Control of Organochlorine
       Compounds.  In:   Proceedings  of 1991  TAPPI Environmental  Conference,  San
       Antonio, Texas, April 7-10, 1991.

 38.   Austria Pulp & Paper Regulation. April  1991.

                                        7-18

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                                                      7.0 Selection of Pollutant Parameters
39.




40.



41.
Dillner, B. and W. Peter.  Application of MC Ozone Delignification for Bleaching
Chemical Pulp. Presented at the SPCI 92/AT/CELCA Conference, Bologna Italy
May 20, 1992.                                •                         '    "

Ontario Ministry of the Environment.  Best Available Technology for the Ontario
Pulp and Paper Industry.  Toronto, Ontario, Canada, February 1992.

Sjoblom K. Pulp Mill Emissions and Environmental Regulations. In: Proceedings
of 1990 TAPPI Pulping Conference, Toronto, Ontario, Canada, October 14-17,1990.
                                     7-19

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11
^ ,a
go,

>-
_o
"o
U







* »*s

^ S3

OT
.5

1


§^
«





1




1










1




•




X





X




1









1


X

X


X




^
1-4
3
173
°r
•i
u
4_l
Jl
&) C
u u
•4— « p"
•s i
i C
a a
0 0
Z 2



1




I




X





X




1









1


X

X


X

13
H
«
1
n
(L,
-c
I
•i-J
CS
&
a
4-J
e
i
c
o
2
  £>
  •a
  8
  I
 ii
 U
   "

7-22

-------
                    Table 7-2
Analysis Summary for Specific Pollutants in Treated
  Effluents From Chemical Pulp Mills That Bleach
Pollutant Group
CDDs/CDFs
Volatile Organics
Chlorinated Phenolics
Metals
Pesticides/Herbicides
Semi- Volatile Organics
Total
Nuitobet
Detected At
Mom Than
One Mill
4
5
20
17
0
3
49
==^===
Numfeer
Detected At
Only One
Mil
2
5
8
3
11
2
31
Nniiiber Not
Detected
11
47
5
49
78
173
363
Total
17
57
33
69
89
178
443
""
                     7-23

-------
                       Table 7-3
                                               I
Priority and Nonconventional Pollutants Not Detected in
Treated Effluents From Chemical Pulp Mills That Bleach
                                No. of
                                Mills
                                Non-
                                Detect
: uujL»a/^jL/i.'o 	 _________
1,2,3,7,8-pentachlorodibenzo-p-dioxin
_J±LJ 	 E 	
1 2 3,4,7,8-hexachlorodibenzo-p-dioxm
1 1 2,3 6 7,8-hexachlorodibenzo-p-dioxin
1 1,2,3,7,8,9-hexachlorodibenzo-p-dioxin
1,2,3,7,8-pentachlorodibenzofuran
2,3,4,7,8-pentachlorodibenzofuran
1 1 2,3 4,7,8-hexachIorodibenzofuran
1 — »-»»'» 	 . 	 	 	
1 2,3,6,7,8-hexachlorodibenzofuran
1 2,3,7,8,9-hexachlorodibenzofuran
2 3 4,6,7,8-hexachIof-odibenzofuran
1 1 2,3 4 6,7,8-heptachlorodibenzofuran
16
16
16
16
16
16
16'
16
16
16
16
16
16
16
16
16
16
16
16
16
16
16
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1 Volatile Organics
acrylonitrile*
I benzene*
I bromodichloromethane*
|| bromomethane
1 chloroacetonitrile
chlorobenzene*
| chloroethane* 	 	
chloromethane*
cis-l,3-dichloropropene*
crotonaldehyde
dibromochloromethane*
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
333.0
385.0
455.0
62.0
357.0
294.0
417.0
455.0
455.0
417.0
417.0

500.0
100.0
100.0
500.0
100.0
100.0
500.0 '
500.0
100.0
500.0
100.0
pg/L 1
Pg/L
Pg/L
Pg/L
Pg/L
Pg/L
Pg/L
Pg/L
Pg/L
Pg/L
Pg/L

Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Atg/L
                           7-24

-------
 Table 7-3




(Continued)
PolLutant(a)
dibromomethane
diethyl ether
ethyl cyanide
ethyl methacrylate
ethylbenzene*
iodomethane
isobutyl alcohol
m-xylene
methyl methacrylate
o + p xylene
tetrachloroethene*
tetrachloromethane*
trans-l,2-dichloroethene*
trans- 1,3-dichlor opr opene *
trans- l,4-dichloro-2-butene
tribromomethane*
trichloroethene*
vinyl acetate
vinyl chloride*
1,1-dichloroethane*
1, 1, 1-trichloroethane*
1,1,1,2-tetrachloroethane
1,1,2-trichloroethane*
1,1,2,2-tetrachloroethane*
1,2-dibromoethane
No. of
Mills
Sampled
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
16
17
17
No, of
Mills
Non«
Detect
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
17
16
17
17
Symh»I(b)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Maximum
100.0
500.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
500.0
100.0
100.0
500.0
100.0
100.0
100.0
100.0
100.0
100.0
100.0
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L I
Mg/L
Mg/L
Mg/L
/ig/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
   7-25

-------
 Table 7-3




(Continued)
1 Pollutant(a)
| 1,2-dichloroethane*
| 1,2-dichloropropane*
| 1,2,3-trichloropropane
| 1,3-butadiene, 2-chloro
1 1,3-dichloropropane
1 1,4-dioxane
1 2-chloroethyl vinyl ether*
1 2-hexanone
|] 2-propen-l-ol
1 3-chloropropene
| 4-methyl-2-pentanone
No. of
Mills
Sampled
17
17
17
17
17
17
17
17
17
17
17
No. of
Mills
Noli-
Detect
17
17
17
17
17
17
17
17
17
17
17
Symbol(b)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1 Chlorinated Phenolics
| 5-chloroguaiacol .
I] 3,4-dichlorophenol
| 3,5-dichlorophenol
1 3,6-dichlorocatechol
| 2,3,6-trichlorophenol
4
8
8
10
8
4
8
8
10
8
ND
ND
ND
ND
ND
|| Mctals(c)
| antimony*
1 arsenic*
| beryllium*
| bismuth
1 cadmium*
1 cerium
1 cobalt
3
3
3
3
3
3
3
3
3
3
3
3
3
3
ND
ND
ND
ND
ND
ND
ND
Maximum
100.0
100.0
100.0
100.0
100.0
200.0
100.0
500.0
100.0
100.0
500.0

5.0
5.0
5.0
5.0
5.0

6.0
20.0
2.0

5.0

25.0
Units
Mg/L |
Mg/L
^g/L
Mg/L
Mg/L
Mg/L
Mg/L
/^g/L
Mg/L
Mg/L
Mg/L

Mg/L
Mg/L
/*g/L
Mg/L
Mg/L

Mg/L
Mg/L
Mg/L
Mg/L
fig/L
Mg/L
Mg/L 1
     7-26

-------
 Table 7-3




(Continued)
I
Pollutant(a)
copper*
dysprosium
erbium
europium
gadolinium
gallium
germanium
gold
hafnium
holminum
indium
iodine
iridium
lanthanum
lead*
lutetium
neodymium
nickel*
niobium
osmium
palladium
platinum
praseodymium
rhenium
rhodium
No. of
Mills
Sampled
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
No. of
Mills
Non«
Detect
3
3 .
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Symbol(h)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Maximum
15.0













50.0


22.0







1
Unite
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
   7-27

-------
 Table 7-3




(Continued)
. . . 	
Pollutant(a)
ruthenium
samarium
I scandium 	
[| selenium 	
I silver*
1 tantalum
| tellurium
II terbium
1 thallium* 	
|| thorium
|| thulium 	
1 tin
| tungsten
1 uranium 	
1 ytterbium
yttrium
zirconium
No. of
Mills
Sampled
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Nd. Of
Mills
Noft-
Detect
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Syinbol(b)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Pesticides/Herbicides
|j alpha-chlordane*
| azinphos-ethyl
|| azinphos-methyl
1 beta-BHC*
| carbophenothion
| chlorbenzilate
| chlorfenvinphos
3
3
3
3
3
3
3
3
3
3
3
3
3
3
ND
ND
ND
ND
ND
ND
ND
Maximum



30.0
6.0



65.4


30.0



5.0


2.5
1.0
3.0
0.4
5.0
4.0
2.5
Units
Mg/L
Mg/L
jug/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
A
-------
 Table 7-3




(Continued)
Polliitant(a)
chlorpyrifos
coumaphos
crotoxyphos
Idelta-BHC*
demeton
diallate
diazinon
dichlofention
dichlone
dichlorvos
dicrotophos
dimethoate
dioxathion
disulfoton
endosulfan I (alpha-endosulfan)*
endosulfan II (beta-endosulfan)*
endosulfan sulfate*
endrin*
endrin aldehyde*
endrin ketone
epn (santox)
ethion
ethoprop
famphur
fensulfothion
No. of
Mills
Sampled
3
3
3
3
3
3
3
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
2
3
3
No. of
Mills
Non«
Detect
3
3
3
3
3
3
3
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
2
3
3
Symbol(b)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Maximum
0.5
1.0
3.0
0.3
1.0
2.0
0.5
0.5
2.5
0.5
2.0
0.5
1.0
0.5
0.5
0.3
0.5
0.3
0.5
0.5
0.5
0.5
0.5
2.5
3.0
Unite
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
   7-29

-------
                                       Table 7-3

                                     (Continued)
                                        No. of
                                        Mills
                                       Sampled
heptacHor epoxid
hcxamethylphosphoramide
methoxvchlor
methyl parathion
methvl trithion
mevinphos (phosdrin)
 monocrotopho
 nalcd (dibrom)
 nitrofcn (TOK)
 p,p'-TDE (4,4'-DDD)*
 p,p'-DDX (4,4'-DDE)*
 p.p'-DDT (4,4'-DDT)*
 parathion-methyl
 PCB 1016 CArochlor 1016)
 PCB 1221 (Arochlor 1221)
 PCB 1232 CArochlor 1232)
 PCB 1242 CArochlor 1242)
                                            7-30

-------
 Table 7-3




(Continued)
Pollutant(a)
PCB 1248 (Arochlor 1248)*
PCB 1254 (Arochlor 1254)*
PCB 1260 (Arochlor 1260)*
phorate
phosmet
phosphamidon
ronnel
sulfotep
sulprofos
TEPP
terbufos
tetrachlorvinphos
|| tokuthion
toxaphene*
trichloronate
trichlorphate
trichorphon
tricresylphosphate
trifluralin
trimethylphosphate
2,4,5-T
No. of
Mills
Sampled
1
1
1
3
3
3
2
3
2
1
3
3
2
1
1
1
3
1
3
1
3
=====
No, of
Mills
Non.
Detect
1
1
1
3
3
3
2
3
2
1
3
3
2
1
1
1
. 3
1
3
1
3
=========
Symbol(b)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Semi-volatiles
acenaphthene*
acenaphthylene*
acetophenone
3
3
3
3
3
3
ND
ND
ND
=====
Maximum
2.0
2.0
2.0
0.5
1.0
3.0
0.5
0.3
0.5
0.1
0.5
.2.5
0.5
10.0
0.5
0.5
1.0
0.4
0.5
0.4
13.0

10.0
10.0
10.0
~~|
Unite
yzg/L
A*g/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L.
fig/L
Mg/L
Mg/L
Mg/L
Mg/L
/«g/L
Mg/L
Mg/L
/*g/L
Mg/L
Mg/L
Mg/L

Mg/L
Mg/L
/Pg/L
  7-31

-------
 Table 7-3




(Continued)
Pollutant(a)
alpha-naphthylamine
alpha-picoline
aloha-terpineol
aniline
anthracene*
aramite
1 b-naphthylamine
1 bcnzanthrone
bcnzencthiol
j benzidine*
1 bcnzo{"a)anthracene*
1 benzo(a)pyrene*
benzo(b)fluoranthene*
benzo(ghi)perylene*
benzo(k)fluoranthene*
!bcnzoic acid
benzyl alcohol
bis(2-chloroisopropyl) ether*
bis(chloromethyl)etlier(nr)
bis(2-chloroethoxy)methane*
bis(2-chloroethyl)ether*
butyl benzyl phthalate*
carbazole
chrysene*
di-n-butyl amine
No. of
Mills
Sampled
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
No, of
Mills
Nott-
Detect
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Symbol(h)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Maximum
10.0
50.0
10.0
10.0
10.0
50.0
50.0
50.0
10.0
50.0
10.0
10.0
10.0
20.0
10.0
50.0
10.0
10.0
10.0
10.0
10.0
10.0
20.0
10.0
10.0
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
     7-32

-------
 Table 7-3




(Continued)
Pollutant(a)
di-n-butyl phthalate*
di-n-octyl phthalate*
dibenzo(a,h)anthracene*
dibenzofuran
dibenzothiophene
dichlorodifluoromethane (NR)
diethyl phthalate*
dimethyl phthalate*
diphenyl ether
diphenylamine
diphenyldisulfide
ethanol
ethyl methanesulfonate
ethylenethiourea
ethynylestradiol 3-methyl ether
fluoranthene*
fluorene*
hexachloro-l,3-butadiene*
hexachlorobenzene*
hexachlorocyclopentadiene*
hexachloroethane*
hexachloropropene
hexanoic acid
indeno(l,2,3-CD)pyrene*
isophorone*
No. of
Mills
Samplec
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Na,of
Mills
Non-
Detect
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Symbol (b)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
' ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Maximum
10.0
10.0
20.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
20.0
10.0
20.0
20.0
20.0
10.0
10.0
10.0
10.0
10.0
10.0
20.0
10.0
20.0
10.0
Units
fjLg/L
Mg/L
//g/L
Mg/L
Mg/L
Mg/L
Mg/L
/ig/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
ug/L
Mg/L
Mg/L
A^g/L
/zg/L
/"g/L
/ig/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
   7-33

-------
 Table 7-3




(Continued)
"" . -™ ' • ~ "~~
>
Pollutant(a)
isopropanol
Iisopropyl ether
isosafrole
longifolene
malachite green
methapyrilene
methyl methanesulfonate
1 n-butanol 	
I n-decane (N-C10)
n-docosane (N-C22)
I n-dodecane (N-C12)
1 n-eicosane (N-C20)
I n-hexacosane (N-C26)
| n-hexadecane (N-C16)
n-nitrosodi-n-butylamine '
| n-nitrosodi-n-propylamine*
1 n-nitrosodiethylamhie
1 n-nitrosodimethylamine*
| n-nitrosodiphenylamine*
| n-nitrosomethylethylamine
| n-nitrosomethylphenylamine
|j n-nitrosomorpholine
| n-nitrosopiperidine
|| n-octacosane (N-C28)
| n-octadecane (N-C18)
=====
No. of
Mills
Sampled
3
3
3
3
3
3
3
3
3
. 3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
=====
No, of
Mills
Non«
Detect
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
SymboL(b>
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Maximum
10.0
10.0
10.0
50.0
10.0
10.0
20.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
10.0
20.0
10.0
50.0
20.0
10.0
99.0
10.0
10.0
10.0
10.0
Units
jug/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
/*g/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
/*g/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L 1
     7-34

-------
  p-cymeme
 pentachlorobenzene
 pentachloroethane
 pentamethylbenzene
——•—-^^—^—_^—.—
 perylene

 phenacetin

 phenanthrene*

 phenol*

 phenothiazine

 pronamide

 pyrene*

 pyridine

 safrole

 squalene

 styrene
                                           Table 7-3

                                         (Continued)
                                                      No, of
                                                      Milfs
                                                      Non-
                                                      Detect
  n-tetradecane (N-C14)
  n,n-dunethylform amide
,
jbenzene
.

&






3
3
3
3
3
3
3
3
3
3
„
3
3
3
3
3
3
3
3
3
3

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

10.0
20.0
20.0
20.0
10.0
10.0
10.0
10.0
10.0
50.0

                                            7-35

-------
 Table 7-3




(Continued)
. - . • 	
Pollutant(a)
t-butanol
1 thianaphthene
thioacetamide
1 thioxanthone
triohenylene ,
1 trioroDYleneglycol methyl ether
1 1-methylfluorene
1 1-mcthylphenanthrene
	
1-ohenytlnaphthalene
— i 	
l,2-dibromo-3-chloropropane
1.2-dichlorobenzene*
| 1,2-diphenylhydrazine*
11 1.2,3-trichlorobenzene
I 1,2,3-trimethoxybenzene
11 l.Z3.4-diepoxybutane
I 1,2,4-trichlorobenzene*
II 1,2,4,5-tetrachlorobenzene
1 1.3-benzenediol (resorcinol)
1.3-dichloro-2-propanol
	
|] 1,3-dichIorobenzene*
II 1.3-dinitrobenzene
II 1,3,5-trithiane
11 1,4-dichlorobenzene*
1 1,4-naphthoquinone
1 1,5-naphthalenediamine
No. of
MiU$
Sampled
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
No. Of
Miiis
NoJi-
Detect
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Symbol (b)
: ND
ND
ND
ND
ND
ND
ND •
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Maximum
10.0
. "
10.0
20.0
20.0
10.0
99.0
10.0
10.0'
10.0
20.0
10.0
20.0
t' 10.0
	
10.0
20.0
10.0
10.0
50.0
10.0
10.0
20.0
50.0
10.0
99.0
99.0
Units
. Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Aig/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
A*g/L
Mg/L
      7-36

-------
 Table 7-3




(Continued)
Pollutant(a)
2-(methylthio)benzothiazol
2-bromochlorobenzene
2-butanol
2-chloronaphthaIene*
2-chlorophenol*
2-isopropylnaphthalene
2-methyl-4, 6-dinitrophenol*
2-methylbenzothioazole
2-methylnaphthalene
2-nitroaniline
2-nitrophenol*
2-phenylnaphthalene
2,3-benzofluorene
2,3-dichloroaniline
2,3-dichloronitrobenzene
2,4-diaminotoluene
2,4-dimethylphenol*
2,4-dinitrophenol*
2,4-dinitrotoluene*
2,4,5-trimethylaniline
2,6-di-tert-butyl-p-benzoqinone
2,6-dichloro-4-nitroaniline
2,6-dinitrotoluene*
3-bromochlorobenzene
3-chloronitrobenzene
No. of
Mills
Sampled
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
No. of
Mills
Non«
Detect
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Symbol(b>
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Maximum
10.0
10.0
10.0
10.0
10.0
10.0
20.0
10.0
10.0
10.0
20.0
10.0
10.0
10.0
50.0
99.0
10.0
50.0
10.0
20.0
99.0
99.0
10.0
10.0
50.0
Units
Mg/L 1
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
/*g/L
Mg/L
Mg/L
Mg/L
A«g/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
   7-37

-------
                                          Table 7-3

                                        (Continued)
Pollutant(a)
3-mcthylcholanthrene
3-nitroaniline
3,3'-dichlorobenzidine*
3,3'-dimethoxybenzidine
3,5-dibromo-4-hydroxybenzonitr
3,6-dimethylphenanthrene
4-aminobiphenyl
4-bromophenyl phenyl ether*
4-chloro-2-nitroaniline
4-chloro-3-methyl phenol*
4- chlor oaniline
4-chlorophenyl phenyl ether*
4-nitroaniline
4-nitrobiphenyl
4-nitrophenol*
4,4'-methylenebis(2-chloroani)
4,5-methylenephenanthrene
5-chloro-o-toluidine
5-nitro-o-toluidine
7,12-dimethylbenz(a)anthracene
No. of
Mills
Sampled
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
No. Of
Mills
Non«
Detect
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
Symbol(b)
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Maximum
10.0
20.0
50.0
50.0
50.0
10.0
10.0
10.0
20.0
10.0
10.0
10.0
50.0
10.0
50.0
20.0
10.0
10.0
10.0
10.0
Units
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L.
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
(a)Priority pollutants are indicated by an asterisk (*).
(b)Symbol of ND indicates that all results are non-detected; the maximum value is a detection limit.
(c)Dctection limits are not available for metals analyzed semiquantitatively.
                                               7-38

-------
                             Table 7-4
Priority and Nonconventional Pollutants Detected in Treated Effluents
         From Only One Chemical Pulp Mill That Bleaches
PoIIutant
No, of
Mills
Sampled
No, of
Mills
Non-
Betect
Symbol(b)
Maximum
CDDs/CDFs
1,2,3,4,7,8,9-heptachlorodibenzofuran
octachlorodibenzofuran
16
15
15
14


2000.0
190.0
Volatile Organics
toluene*
trichlorofluoromethane
1,1-dichloroethene*
2-propenal (acrolein)*
2-methyl-2-propenenitrile
17
9
17
17
17
16
8
16
16
16





12.1
32.8
15.0
51.9
67.3
Chlorinated Phenolics
5-chlorovanillin
2,6-dichlorophenol
3,4-dichlorocatechol
3,5-dichlorocatechol
5,6-dichlorovanillin
2,4,5-trichlorophenol
3,4,6-trichlorocatechol
tetrachloroguaiacol
9
17
13
2
16
17
9
14
8
16
12
1
15
16
8
13

>






3'.0
0.9
1.1
7.1
15.0
4.3
12.1
1.5
Metals
chromium*
lithium
molybdenum
3
3
3
2
2
2



12.0
200.0
12.0
Units

Pg/L
Pg/L

Mg/L
Mg/L
Mg/L
Mg/L
/
-------
                                         Table 7-4

                                        (Continued)
PoIIutant(a)
=====
No. of
Mills
Sampled
No. of
Mills
Non»
Detect
Symbol (fo)
Pesticides/Herbicides
alclrin*
alpha-BHC*
captafol
captan
dieldrin
gamma-BHC (lindane)*
gamma-chlordane*
isodrin
PCNB
2,4-D
2,4,5-TP (silvex)
3
3
3
3
3
3
2
3
3
2
3
2
2
2
2
2
2
1
2
2
1
2











Semi-volatiles
bis(2-ethylhexyl)phthalate*
naphthalene*
3
3
2
2


Maximum

0.2
0.1
2.1
0.3
0:2
0.2
0.3
0.3
0.1
2.2
2.2

29.0
1791.0
I
Units

Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L

Mg/L
Mg/L
(a)Priority pollutants are indicated by an asterisk (*).                                         .
(b)A > symbol indicates that the review of the analysis used to derive the reported maximum value indicated
 that the result may have actually been higher.
                                              7-40

-------
                            Table 7-5
Priority and Nonconventional Pollutants Detected in Treated Effluents
        At More Than One Chemical Pulp Mill That Bleaches
PoHutant(a)
No. of
Mills
Sampled
No, of
Mills
Non-
Detect
Symbol(b)
Maximum
Units
Pollutant
s Below
Level of
Concern
or Below
Treatable
Levels
CDDs/CDFs
octachlorodibenzo-p-dioxin
2,3,7,8-tetrachlorodibenzofuran
1,2,3,4,6,7,8-
heptachlorodibenzo-p-dioxin
2,3,7,8-tetrachlorodibenzo-p-
dioxin*
14
17
16
17
2
8
11
13




5995.0
320.0
100.0
74.0
Pg/L
Pg/L
Pg/L
Pg/L




Volatile Organics
carbon disulfide
chloroform
(trichlorometfaane) *
methylene chloride*
2-butanone (MEK)
2-propanone (acetone)
17
17
17
17
17
9
5
11
13
5




>
176.9
533.0
4493.3
232.0
1000.0
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Chlorinated Phenolics
4-chlorophenol
4-chlorocatechol
4-chloroguaiacol
6-chlorovanillin
2-chlorosyringaldehyde
2,4-dichlorophenol*
4,5-dichlorocatechol
3,4-dichloroguaiacol
4,5-dichloroguaiacol
13
9
13
16
13 '
14
16
9
17
10
5
10
6
11
8
7
7
12

>

>




>
4.1
13.2
28.0
26.0
5.8
9.0
39.0
4.8
8.1
Mg/L
/*g/L
Mg/L
Mg/L
Mg/L
Mg/L
J«g/L
Mg/L
Mg/L





'
^
/
S
S
S
s
s
s
s
                              7-41

-------
 Table 7-5




(Continued)
Pollutant(a)
4,6-dichIoroguaiacol
2,6-dichlorosyringaldehyde
2,4,6-trichlorophenol*
3,4,5-trichlorocatechol
3,4,5-trichloroguaiacol
3,4,6-trichIoroguaiacol
4,5,6-trichloroguaiacol
trichlorosyringol
2,3,4,6-tctrachlorophenol
tetrachlorocatechol
pentachlorophenol*
No. of
Mills
Sampled
16
13
17
16
17
13
17
17
17
17
16
No. of
Mills
Non-
Detect
14
8
7
10
10
11
10
11
14
11
13
Sj**nbol(b)


>

>




>

Maximum
6.8
11.0
18.0
26.8
1.6
1.5
7.6
8.2
2.6
2.5
18.7
Metals - • • . •.-••'. ••:;; '•••' • \ :?;••'• .::..:''- • • .
aluminum
barium
boron
calcium
iron
magnesium
manganese
mercury*
phosphorus
potassium
silicon
sodium
3
3
3
3
3
3
3
3
3
3
3
3
0
1
1
0
0
0
0
1
1
0
0
0












2480.0
380.0
1310.0
87600.0
1550.0
12600.0
2660.0
74.0
2400.0
3700.0
11900.0
765000.0
Units
Mg/L
MgA
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L

Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Mg/L
Pollutant
s Below
Level/of
Concern
or BelOW
Treatable
Levels
/
^










/
/
/
/
/
^
/

S
S
S
S
     7-42

-------
                                           Table 7-5

                                          (Continued)





Pollutant(a)
strontium
sulfur
titanium
vanadium
zinc*
=====

•

No, of
Mills
Sampled
3
3
3
3
3



No. of
Mills
Non-
Defect
0
0
0
1
0





Symbol(b)





—




Maximum
300.0
164000.0
45.0
155.0
116.0
Semi-volatiles
biphenyl
dimethyl sulfone
o-cresol
3
3 •
3
1
0
1


•
572.0
148.0
18.0





Units
Mg/L
Mg/L
Mg/L
Mg/L
/zg/L

Mg/L
Mg/L
Mg/L
Pollutant
s Below
Level of
Concern
or Below
Treatable
Levels
S
s
S
S
S
•


S
(a)Priority pollutants are indicated by an asterisk (*).
(b) Where a > symbol was used, the review of the analysis used to derive the reported maximum value indicated
  that the result may have actually been higher.
                                             7-43

-------
                                 Table 7-6

      Number of Data Points and Final Effluent Concentrations for
            Analytes Detected at Non-Chemical Pulp Mills and
               Chemical Non-Wood Pulp Mills That Bleach
                    With Chlorine and/or Hypochlorite
— ^--i=g8i^^5==s==S====!
Analyte(a)
Chloroform*
======
No. of Mills
With Data
10
1
Total No. of
Data Points
64

2-chlorophenol*
2,4-dichlorophenol*
trichlorophenol
2,4,6-trichlorophenol*
4-chloro-3-methylphenol*
5
• 5
3
5
3
36
29
4
29
27
—
Total No.
of Detects
57

2
1
1
3
1

2,3,7,8-tetrachlorodibenzo-p-
dioxin*
2,3,7,8-tetrachlorodibenzofuran
12
7
=====
28
14
3
8
=
Concentration
Range(b)
<1.0 - 36,480 ppb

<1.0-370ppb
< 1.0 - 20 ppb
<0.3 - 35 ppb
<1.0 -32 ppb
<5.0 - 18 ppb

<1.5 - 65 ppq
<2.0 - 490 ppq
1
(a)Priority pollutants are indicated by an asterisk (*).
(b)A < symbol indicates that the analyte was not detected above the reported concentration.
                                     7-44

-------
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2,4,5-trichloropheno
4,5,6- trichloroguaiac
































C/3
1
03
LH

^
CQ
                                               7-45

-------
                      Table 7-8



Jurisdictions Regulating AOX as a Wastewater Pollutant
1 Jurisdiction
I AUSTRALIA:
| CANADA:
Alberta:
British
Columbia:
1 Ontario(c):
Quebec:
1 EUROPE:
Austria:
Belgium:
I Finland:
AOX Regulation
Australia issued guidelines in 1989 for new bleached eucalypt kraft
pulp mills discharging to marine waters. These guidelines stipulate the
following limitations on the discharge of AOX:
Maximum 24 hour ave. (based on rated production capacity: 2.5
kg/ADMT(a)
Maximum 1 year moving ave. (based on actual production): 1.0
kg/ADMT
No federal regulations for AOX; however, several provinces have
regulated AOX as follows:
IjEas no AOX regulations; however, all existing and new bleached kraft
mills have AOX limitations in their licenses. These limitations range
from 0.29 kg/ADMT (annual average) for a new facility (Alpac) to 1.5
kg/ADMT (monthly average) for existing facilities.
1.5 kg/ADMT (monthly average) by 31 December 1995 and 0.0
kg/ADMT by 31 December 2002 or 0.0 kg/ADMT by 31 December
2000(b).
1.50 kg/ADMT (monthly average) by 31 December 1995
1.93 kg/ADMT (daily maximum) by 31 December 1995
0.80 kg/ADMT (monthly average) by 31 December 1999
1.03 kg/ADMT (daily maximum) by 31 December 1999
Goal of 0.00 kg/ADMT by 31 December 2002
1.5 kg/ADMT (monthly average) for hardwood by 31 December 1993
2.5 kg/ADMT (monthly average) for softwood by 31 December 1993
1.0 kg/ADMT (monthly average) for hardwood by 30 September 1995
2.0 kg/ADMT (monthly average) for softwood by 30 September 1995
0.8 kg/ADMT (monthly average) by 31 December 2000
1.5 kg/ADMT for kraft mills
0.5 kg/ADMT for sulfite mills
0.75 kg/ADMT for magnetite mills
One area of Austria, the Salzkammergut, required the attainment of
0.0 kg/ADMT by the year 1992.
1.5 kg/ADMT for kraft mills
2.0 kg/ADMT (maximum annual average) for softwood kraft by 1995
1.0 kg/ADMT (maximum annual average) for hardwood kraft by 1995
1.4 kg/ADMT (maximum annual average) for mixed hardwood and
softwood kraft by 1995
Reference
34
36
35
36
36
36,37
38
39
41
36,37,40
                          7-46

-------
                                           Table 7-8

                                         (Continued)
Jurisdiction
Germany:
Norway:
i
Sweden:
AOX Regulation
1.0 kg/ADMT for sulfite mills
2.0 kg/ADMT for kraft mills
1.0 kg/ADMT for sulfite mills
1.0 kg/ADMT (annual average) by 1995 for softwood
0.5 kg/ADMT (annual average) by 2000 for softwood
0.5 kg/ADMT (annual average) by 1995 for hardwood
0.3 kg/ADMT (annual average) by 2000 for hardwood
Reference
37,40
36,37,40
36,37,40,41
(a)A!I tons in this table are bleached metric tons.  However, each jurisdiction does not necessarily define this
   measurement the same way.
(b)This alternative allows the discharger an exemption from meeting the 31 December 1995
   requirements provided a plan is submitted to the director on or before 30 June 1992 for
   completely eliminating AOX discharges by 31 Decenber 2000.
(c)Draft regulations.
                                             7-47

-------

-------
                                 8.0 Pollution Prevention and Wastewater Treatment Technologies
 8.0   POLLUTION   PREVENTION   AND   WASTEWATER   TREATMENT
       TECHNOLOGIES

 This section describes technologies that are in use at pulp, paper, and paperboard mills to
 prevent  the formation  of wastewater  pollutants or 'reduce the discharge of wastewater
 pollutants.  Various combinations of these technologies were considered as the basis for the
 proposed effluent limitations guidelines and standards for the industry.

 8.1    Introduction

 There are two major approaches that may be used  to improve effluent quality at pulp
 paper, and paperboard mills: (a) in-process technology changes and controls to prevent or
 reduce the formation of wastewater pollutants of concern, and (b)  end-of-pipe wastewater
 treatment technologies to remove pollutants from process wastewaters prior to discharge.

 The Agency has defined pollution prevention as source reduction and other practices that
 reduce or eliminate the formation of pollutants. Source reduction includes any practice that
 reduces the amount of any hazardous substance or pollutant entering any waste stream or
 otherwise released into the environment, or any practice that reduces the hazards to public
 health and the environment associated with the release of such pollutants.  Such practices
 may include equipment or technology modifications,  process or procedure modifications
 reformulation or redesign of products, substitution of raw materials, and improvements iii
 housekeeping, maintenance, training, and inventory control. Other pollution prevention
 practices include increased efficiency in the use of raw materials, energy, water and other
 resources.

 The Agency has developed  a model pollution prevention plan for the  pulp  and paper
industry, as part of the Agency's effort to encourage pollution prevention programs in U S
industries.  The model plan is discussed in a series of reports:

      •      Pollution Prevention Opportunity Assessment  and Implementation Plan for
             Simpson Tacoma Kraft Company, Tacoma, Washington. EPA 910/9-92-027.
             U.S. Environmental Protection Agency Region 10, August 1992.

             Model Pollution Prevention Plan for the Kraft Segment of the Pulp and Paper
            Industry. EPA 910/9-92-030. U.S. Environmental Protection Agency Region
             10, September 1992.                                           y •  &

            Pollution Prevention for  the Kraft Pulp and'Paper Industry, Bibliography
            EPA  910/9-92-031.   U.S. Environmental Protection Agency Region  10
            September 1992.                                                      '
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                                8.0 Pollution Prevention and Wastewater Treatment Technologies
Pollution preventing process changes  may be implemented in the pulping, bleaching,
chemical recovery, and papermaking areas of a null (shown on Figure 4-1). Many of the
in-process controls that prevent or reduce wastewater pollution also result in improved
product quality and/or fiber yield, as weU as reduced operating costs through more efficient
use of process materials and prevention and control of leaks and spills. Sections 8.2 through
8.4 describe  applicable pollution prevention  controls and technologies for the industry.
These sections also provide information on the performance of each technology and the
number of mills using each technology as of January 1, 1993.

Additional information on pollution prevention technologies for the pulp and paper industry
is available in these EPA documents:

       •     Summary of  Technologies  for  the  Control  and Reduction of Chlorinated
             Organics from the Bleached Chemical Pulping Subcategories of the Pulp and
             Paper  Industry.   U.S. Environmental Protection  Agency,  Office  of Water
             Regulations and Standards, April 27, 1990.

       •     Pollution Prevention Technologies for the Bleached Kraft Segment of the U.S.
             Pulp  and Paper Industry.   EPA/600/R-93/110.   U.S.  Environmental
             Protection Agency, Office of Pollution Prevention and Toxics, August 1993.

 End-of-pipe wastewater treatment  includes physical, chemical, and biological processes that
 remove pollutants from mill effluent prior to discharge to a receiving stream  or publicly
 owned treatment works (POTW).  Section 8.5 describes end-of-pipe wastewater treatment
 technologies applicable to the industry and provides information on the performance of each
 technology and the number of mills using each technology.
S3,   Pollution Prevention Controls Used in
                                                   and DeMgnification Processes
 This section describes  applicable technologies  for  reducing and preventing pollutant
 discharges from the pulping area of a chemical pulp mill. Pulping area processes include
 chipping, cooking, pulp washing, and screening. Pollution prevention technologies applicable
 to pulping  area  processes include  chip  quality control, use  of  dioxin  precursor-free
 defoamers and pitch dispersants, extended cooking, effective brown stock washing, closing
 the screen room, oxygen delignification, steam stripping of condensates, and pulping liquor
 spiU prevention and control.   This section discusses these technologies, as well as their
 impact on the recovery boiler.

 8.2.1  Chip Quality Control

 In preparation for chemical pulping, wood is  reduced to  chips  approximately 2  to 5
 millimeters thick and 10 to 30 millimeters long. Some mills use chips obtained from an off-

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                                   8.0 Pollution Prevention and Wastewater Treatment Technologies



  site source such as a sawmill, although most mills perform at least some chipping on site
  Several chipper designs are in use today, but the most common is the flywheel-type disc
  chipper  in which logs are fed to one side of the disc at a pre-determined angle through a
  vertical directing chute.                                                          6

  After chipping, the chips are passed over a set of vibratory screens to separate chips of
  acceptable length and width from fines and oversized pieces. Oversized chips are rechipped
  and tines are usually burned in an on-site hog fuel boiler.                              '

  Good quality chipping and screening equipment provides a uniform supply of chips to the
  digester, leading to more uniform cooking and reduced digester chemical consumption  The
  uniform pulp produced results in less variation in bleach plant feed and better control of
  the bleaching process, reducing overbleaching  of the pulp to remove shives and colored
  fiber   This improves the  effluent quality  from  the bleaching area,  because when
  overbleaching is avoided, lower levels of chlorinated organics are formed. A more uniform
 pulp also reduces the amount of rejects from screening following brown stock washing.

 Mills can improve the quality of chips going to the digester in several ways.  Mills that
 receive chips from an off-site source can develop a quality control program for suppliers to
 ensure that uniform, high-quality chips are received. Mills that chip on site can closely
 monitor the operation of the chipper to maintain optimum settings in order to produce chips
 of consistent  size.                                                                 F

 Mills can also provide uniform chip dimensions with chip thickness screens.  Chip thickness
 screens are rotating disc screens  that separate overly thick chips, which are then sliced to
 the desired thickness for pulping.   Chip thickness screening  also  removes  knots  and
 compression  wood,  in which  dioxin precursors  are reported  to be  concentrated  (1)
 Providing  chips of uniform thickness, free  of  knots and compression  wood, results in
 improved pulping, reduced screen rejects, and improved bleaching, and may reduce the load
 on the mill s wastewater treatment system.  When knots and compression wood are removed

 ETIJ*! °T  g'  Jitre tyPcalfy bumed in the mill's P°wer boiler- If these components
 are instead removed from the pulp by screening after cooking, they may  be sent to the

 S^^eSdn"^^^ millS'in ^ U'S' tyPiCally USC °hiP       eSS SCreeninS
 woodyard or pulp mill upgrade.

 8.2.2  Defoamers and Pitch Dispersants

 Defoamers are added to pulp to decrease foaming from air entrained with the pulp during
brown stock washing.  Pitch dispersants are added to pulp to prevent wood resins and fatty
acids from depositing on the paper at the paper machine.  Both of these chemical additives
are introduced into the pulp flow prior to brown stock washing and are carried with the pulp
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                                8.0 Pollution Prevention and Wastewater Treatment Technologies
into the bleach plant. Defoamers and pitch dispersants have been shown to contain the
Started  dibenzo-p-dioxin (CDD)  and  chlorinated dibenzofuran (CDF precursors
dibenzo-p-dioxin (DBD) and dibenzofuran  (DBF) (2,3).  In^ the first (f™^*^
bleaching, the DBD and DBF are chlorinated to form 2,3,7,8-TCDD  and 2,3,7,8-TCDF.

Defoamers can be oil-based or water-based.  Oil-based defoamers are a blend of 90 percent
oil and 10 percent additives.  Defoamers made from re-refined oil  are particularly high in
DBF concentration (4).  DBD and DBF can essentially be eliminated from defoamer oils
(i.e.,  to  a  level of less than 1 ppb of both) by  using  two-stage severe hydrotreatmg
technology (4). Alternatively, completely oil-free defoamers that do not contain CDD and
CDF precursors may be used (5). Switching to non-contaminated defoamers can reduce the
content of 2 3,7,8-TCDF in bleached pulp and in mill effluent by  at least 90 percent (6)
The Agency believes that the U.S. pulp industry has generally converted to the  use of
precursor-free additives.

8.2.3  Extended Cooking

At chemical pulping  mills, wood chips or a non-wood fiber furnish are cooked in * chemical
solution in a digester at elevated temperature and pressure to dissolve the lignm that holds
the  cellulose fibers  together.  Chemical pulping occurs in either a batch or continuous
digester system.

The most common continuous digester is the vertical downflow type.  The wood  chips are
preheated in a steaming vessel before entering the digester, which removes air and volatile
wood constituents.  The chips are mixed with the cooking liquor and are fedinto the top
 of the digester so that they move downward by gravity through the tower  The  hydraulic
 pressure in the tower is  kept at approximately 1,140 kPa.  After  the chips have.been
 impregnated with liquor, the temperature is raised to approximately 105 to 130 C at a
 residence time of one to one and a half hours, until the pulping reaction is complete.  The
 reaction is stopped in the lower region of the tower, where diffusion washing of the pu p is
 carried out, normally using a countercurrent flow of the'filtrate from the first brown stock
 washer. The pulp is blown from the bottom of the digester  at about  1,380 kPa to a tank  at
 atmospheric pressure.

 For batch cooking, a mill normally uses  several  vessels.  Mills in the U.S. with batch
 digesters have reported using anywhere from 3 to 24 vessels.  Wood  chips and cooking
 liq°uor are added simultaneously to the top of the digester, after which the digester is sealed
 and raised to a target operating pressure of approximately 700 to 900 kPa and temperature
 of approximately 170°C.  After impregnation for approximately one hour, and cooking tor
 one to two hours, the pulp is blown into an atmospheric tank,  from which it is pumped  to
 the brown stock washing system. Usually a mill staggers the digester cycles to maintain a
 continuous flow of pulp through its washing and pulping sections.

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                                 8.0  Pollution Prevention and Wastewater Treatment Technologies
 The  continuous process produces  pulp at a  consistent rate  and  with  lower energy
 requirements; however,  a batch pulping system enables a mill to pulp several  different
 grades at once, by using different digesters for different pulping conditions or fiber furnishes.
 Since the continuous process was commercialized in the 1950s, the amount of chemical pulp
 produced by continuous digesters has increased. Most new installations are now continuous
 systems.

 Chemical pulp mills that bleach must remove enough residual lignin from the pulp prior to
 bleaching to achieve their required final pulp brightness.  The Kappa number (a measure
 of a pulp's lignin content) of the  pulp  entering the bleach plant dictates  the amount of
 bleaching chemicals needed. Since decreasing bleaching chemical use lowers both the cost
 for bleaching chemicals and the environmental impact of the effluent from the bleach plant,
 it is generally desirable for mills that bleach to lower the prebleaching Kappa number as
 much as possible, without affecting pulp strength.

 Through work done by the Swedish'Forest Products Research Institute (STFI) in the late
 1970s (7), the concept of "extended cooking" for papergrade kraft pulps was developed and
 commercialized  in 'the late  1980s.  Extended cooking enables a mill to lower the Kappa
 number of the pulp entering the bleach plant further than is possible with a traditional kraft
 pulping digester, while increasing pulp strength and maintaining or increasing pulp yield.
 During extended cooking, the pulp is mixed with the cooking liquor for a longer time than
 in traditional cooking, under modified temperature and alkalinity conditions. The process
 can be performed using either a batch or continuous pulping system.  Eighteen of the 87
 mills in the Bleached Papergrade Kraft and Soda Subcategory used extended cooking as of
 January 1,1993.  Currently, extended cooking is not typically used for papergrade kraft pulps
 that will not be bleached, because achieving a low Kappa number out of the digester is not
 as important as it is for pulps that  will be bleached.

 Approximately 11 million metric tons per year of kraft pulp is produced worldwide using
 extended cooking (8).  This  represents about 20 percent of world bleached kraft capacity.
 Figure 8-1  shows the increase in the amount of kraft pulp produced by extended cooking
 from 1983 through 1992.  Capacities shown are as reported by mills  and vendors, and have
 been normalized to air dry metric tons per day.  Extended cooking for dissolving kraft and
 sulfite pulps has  not been demonstrated on an industrial scale.
               i
The types of continuous extended cooking processes most  commonly used in the U.S. are
the Modified Continuous Cooking  (MCC®) developed by Kamyr Inc. and Kamyr  AB and
Extended Modified Continuous Cooking (EMCC®) processes developed by Kamyr Inc.
Figure 8-2 shows a typical EMCC® installation.  These processes are similar, in that fresh
cooking liquor, comprising sodium hydroxide and sodium sulfide, is added at several points
in the digester, instead of at just one point as with traditional continuous cooking. More
lignin is dissolved with these  processes than is dissolved in the traditional digester,  because

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                                8.0  Pollution Prevention and Wastewater Treatment Technologies
the active chemical concentration is kept more uniform throughout the cook. At the same
time, less damage is done to the wood fiber cellulose, because a high initial cooking liquor
concentration is avoided.  The resulting pulp is stronger and has a lower Kappa number
than traditional pulps, while the pulp yield is maintained.

Extended cooking hi batch digesters yields  similar results.  Two systems are available
commercially: the Rapid Displacement Heating (RDH®) System,  sold by Beloit Inc., and
the Super Batch® System, sold by Sunds Defibrator, Inc. These processes maintain a more
uniform cooking liquor concentration throughout the cook than traditional batch cooking.
The wood chips are initially impregnated with warm black liquor under pressure to remove
air in the chips.  The warm black liquor is then displaced with hot black liquor and white
liquor to begin the cook.  After cooking, the spent cooking liquor is displaced with wash
liquor from the first brown stock washer. The spent cooking liquor becomes the warm black
liquor used for impregnation during another cook.  The batch extended cooking process
requires several large holding tanks to store liquor between the various stages of the cooking
process,  and  many older mills do not have the  space to install a batch  extended cooking
system. Most of the extended cooking installations in the world are continuous rather than
batch.

The unbleached Kappa number  of softwood kraft pulps typically ranges from 30 to 32 for
traditional cooking.  Extended cooking by either the continuous  or batch processes can
achieve softwood pulp unbleached Kappa numbers ranging from 12 to 18.  For hardwood
kraft pulps, the unbleached Kappa number of approximately 20 for traditional cooking can
be reduced to 8 to 10 using extended cooking (9).

8.2.4  Effective Brown Stock Washing

In a chemical pulping mill, after the pulp leaves the digester it is cleaned through a series
of knotters, screens,  and countercurrent washers to remove impurities and uncooked fiber
and to recover as much spent cooking liquor as possible.  Section 4.2.5 describes these
processes.

In brown stock washing, spent  pulping chemicals,  along with  any dissolved  wood
components, are separated from the pulp and sent to the recovery boiler for incineration.
Effective brown stock washing minimizes the amount of pulping liquor carried over to the
bleach plant with the pulp. This improves the mill's effluent quality, because residual black
liquor carried over to the bleach  plant includes  unchlorinated toxic substances, some of
which appear to resist degradation in  biological treatment plants (10).  If chlorine-based
bleaching chemicals  are used, the organic compounds that are carried over with the pulp to
the bleach plant also react with  the bleaching chemicals and, therefore, increase the mill's
effluent load of chlorinated organics.
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                                  8.0  Pollution Prevention and Wastewater Treatment Technologies
 Effective brown stock washing also reduces the amount of bleaching chemicals required to
 bleach the pulp to a given brightness, because well-washed pulp carries less organic material,
 which competes with the pulp fiber for reaction with the bleaching  chemicals.  Finally,
 effective  brown  stock washing  is  essential for satisfactory  operation of an oxygen
 delignification system.

 Mills try to minimize the amount of water used for brown stock washing, because all water
 added at this stage is .typically evaporated in the black liquor recovery cycle.  Although using
 more water increases the removal of pulping liquor and dissolved organic material from the
 pulp, the maximum amount of water that can be used depends on the capacity of the black
 liquor evaporators and the additional energy requirements necessary to evaporate more
 black liquor.

 Brown stock washing effectiveness at kraft mills is conventionally expressed as saltcake
 (NajSOJ loss per mass of pulp, and is considered to be effective if the washing loss is less
 than 10 kg NajSCymetric ton of pulp.  This is approximately equivalent to 99 percent
 recovery of spent pulping chemicals. The average washing loss for the Bleached Papergrade
 Kraft and Soda Subcategory was 13.5 kg NajSCVmetric ton in 1989,  and the average
 washing loss for  the Dissolving Kraft Subcategory was 24.2 kg  Na2SO4/metric ton, as
 reported in the 1990 questionnaire. This is much lower than washing losses were ten vears
 ago.                                                           *               J

 The  traditional method of pulp washing using a rotary vacuum drum washer  has been
 supplemented or  replaced in many mills with other, high-efficiency  washers,  including
 pressure diffusion washers, belt washers, and presses of various types.  All are capable of
 providing well-washed pulp.

 Pressure diffusion washers  are enclosed and operate at elevated pressure and temperature
 resulting in good washing efficiency. The pulp enters a pressure diffusion washer at the top
 and moves downward as a fiber mat between the stationary central body of the washer and
 the moving perforated cylindrical screen surrounding it.  The wash water flows  from  the
 center of the washer through the pulp mat and outer screen, and is extracted continuously
 from the system.  The pulp continues through the vessel and is removed at the bottom
 Pressure diffusion washers require relatively less floor space than other types of washers and
 are therefore often selected  for upgrading  a  mill's washing system where there is little
 available space.

 In a belt washer, the pulp flows onto an endless moving horizontal filter cloth and  is drawn
 ott at the opposite end.  Wash water  is applied to the top  of the pulp mat and  is drawn
 through the pulp by vacuum boxes located beneath the cloth.  Each wash water  addition
point is considered to be one "stage" of washing, and the wash water moves countercurrently
rrom the final stage through to the first stage on the belt.  A belt washer can provide up to

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                                 8.0 Pollution Prevention and Wastewater Treatment Technologies
seven stages of washing.  The system can be enclosed to roinimize air emissions.  Belt
washers are not currently used to incrementally increase brown stock washing capacity, but
are efficient systems for replacing an entire washing line.

A wash press consists of a cylindrical washer and a press roll. Pulp that is washed in a wash
press leaves the  system at a higher consistency than  with other washing systems.  The
geometric configuration of the cylindrical washer causes the pulp to be dewatered during
washing, because the pulp is forced into a smaller space and ultimately passes through a nip
between the washing cylinder and the press roll. Instead of leaving the washer at the usual
consistency of between 10  and 15 percent solids, the pulp mat leaves at a consistency of
between 30 and  40 percent.   This  type of washer is beneficial when high consistency is
required downstream of the brown stock washing area.

8.2.5  Closed Screen Room Operation

After brown stock washing, pulp is usually screened to remove oversized particles.  The pulp
is first diluted with fresh water, then screened using gravity or pressure screens,  and then
thickened in a decker to an appropriate consistency for the next process operation.  In an
open screen room, the filtrate from the decker goes to the sewer. This sewered stream
carries residual organics and cooking liquor solids from the pulping operation.  Closing the
screen  room eliminates the overflow of decker filtrate to the sewer.   This operation
optimizes the water balance around the washing and screening operations, because all of the
decker filtrate is reused as dilution water for the screening operation, or as brown stock
wash water.  Residual organics and  cooking liquor  are  thus returned to  the  chemical
recovery cycle.  The closed screen room concept has  been discussed in the literature for
many years, and, based on information provided in the 1990 questionnaire, 47 mills in the
United States use closed screen rooms:
                 Subcategory
No. of Mills
   Dissolving Kraft
   Bleached Papergrade Kraft and Soda
   Unbleached Kraft
   Dissolving Sulfite
   Papergrade Sulfite	
       1
      23
      20
       1
       2
 The ability to operate the screen room as a closed process depends  on a systematic
 optimization of the pulping, washing, screening, and liquor recovery cycles, and the type of
 washing and screening equipment available.  Effective brown stock washing should be used
 to minimize the amount of cooking liquor solids carried to the screening operation.  In
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                                  8.0  Pollution Prevention and Wastewater Treatment Technologies
 addition, many mills are replacing gravity flow screens with pressure screens to prevent air
 entrainment and resultant foaming problems (11).

 8.2.6  Oxygen Delignification

 Oxygen delignification uses oxygen gas to remove lignin from pulp after brown stock washing
 and prior to bleaching.  Using oxygen delignification between the kraft or sulfite pulping
 processes and the  bleach plant results in lower  bleaching  chemical demands  than a
 traditional  bleaching  sequence, because  the  unbleached Kappa number  drops  by
 approximately 50 percent and the subsequent bleaching chemical requirements drop relative
 to this (9). In addition, bleaching to a particular brightness can often be accomplished using
 fewer bleaching stages than a traditional bleach line if oxygen delignification is used prior
 to bleaching.  Decreased bleaching chemical use reduces pollutant levels in the mill's bleach
 plant effluent. Although the operation of an oxygen delignification system in itself does not
 decrease the  effluent flow from the bleach plant,  it can lessen  water use if older,  less
 efficient bleaching towers are bypassed.

 As of January 1,1993, sixteen mills in the Bleached Papergrade Kraft and Soda Subcategory
 reported using oxygen delignification.  The amount of  bleached papergrade kraft pulp
 produced by these mills using oxygen delignification represented approximately 40 percent
 of the total U.S. production.  One mill in each of the Papergrade and  Dissolving Sulfite
 Subcategpries reported using oxygen delignification.  Figure  8-3 illustrates the rate of
 increase in the use of oxygen delignification systems in the U.S. and worldwide.  Oxygen
 delignification has been adopted much more extensively in foreign mills than in those in the
 U.S., while U.S. mills have adopted extended cooking more rapidly than foreign mills.

 Figures 8-4 and 8-5 show medium- and high-consistency oxygen delignification systems,
 respectively, both of which are in use today.  In both cases, it is important to start with well-
 washed pulp,  and to add magnesium salt (MgSO4) to protect the cellulose fibers from
 degradation.   After  oxygen delignification, it is also necessary to wash the pulp well to
 remove organic material so that the subsequent bleaching stages can operate effectively.

 High-consistency oxygen delignification is accomplished at a consistency of approximately
 25 to 30 percent, which is attained using a press prior to the oxygen delignification tower.
 The pulp is then fed to a pressurized reactor into which oxygen  and sodium hydroxide  (or
 oxidized white liquor) are added.  The pulp is fluffed using baffles inside the tower to
 achieve a more consistent reaction, and gaseous reaction products are purged from the
vessel to avoid a fire hazard. Pulp degradation has been  a problem with high-consistency
systems, even though magnesium salt is added for pulp stabilization.

Medium-consistency oxygen delignification takes place at a consistency of between 10 and
20 percent, which is  attained using a brown stock decker, avoiding the need for the  more

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                                8.0  Pollution Prevention and Wastewater Treatment Technologies
expensive press frat is required for a high-consistency oxygen delignification system.  Prior
to entering the reaction tower, the pulp is mixed with oxygen and sodium hydroxide (or
oxidized  white  liquor).  Since fewer gaseous compounds are formed, the risk of fire is
eliminated with the medium-consistency system. There is less potential for pulp degradation
than in a high-consistency system, but slightly less delignification occurs than with a high-
consistency reaction due to a lower reaction rate.

The filtrate from the post-oxygen delignification washers is sent  to the recovery boiler,
marginally  increasing the load on the boiler, but concurrently increasing the amount of
recovered chemicals and  energy.  Recycling  the  filtrate from the oxygen delignification
washers,  rather than sending it to wastewater  treatment, reduces the bleach plant effluent
load of biochemical oxygen demand (BOD5) by 30 to 50 percent, chemical oxygen demand
(COD) by  40 percent, color by approximately 60 percent, and  chlorinated organics by
approximately 35 to 50 percent (9,1). Currently, all kraft and sodium-based sulfite mills with
oxygen delignification recycle the associated filtrate.

8.2.7  Steam Stripping

Wastewater streams in the pulping and chemical recovery areas of a chemical pulp mill
contain organic and  sulfur compounds that may be emitted to the air or conveyed to the
wastewater treatment system.  Condensate streams from evaporators, digester blow tanks,
and turpentine recovery  systems  at  kraft mills  contain the highest loadings  of these
compounds, with evaporator condensate representing the major volume  of pulping area
condensate flow. Steam strippers are used to control air emissions of organic and sulfur
compounds from pulping area condensate streams, and at the same time reduce the organic
load of the stripped wastewater on the wastewater treatment system.

Steam stripping is a fractional distillation process that involves the direct contact of steam
with wastewater. Figure 8-6 presents a schematic of a continuous steam stripper system.
Wastewater is pumped into the top of the stripping column, and steam is injected near the
bottom of the column. The column is typically equipped with perforated  trays or packing
to increase contact between the vapor and the liquid. Heat from  the steam vaporizes the
volatile compounds in the wastewater, which are carried out the top of the column with the
steam.  This  overhead  vapor stream is typically incinerated on site  (12).   Stripped
wastewater leaving the steam stripper passes through a heat exchanger to preheat the
unstripped wastewater  entering  the  steam  stripper.  The stripped wastewater is then
discharged to the wastewater treatment system or reused in the mill for fresh hot water
applications. The removal efficiency of volatile compounds is determined by the steam-to-
feed ratio hi the column.  The steam stripper may be  a stand-alone piece of equipment, or,
at some mills,  it may be integrated into the evaporator set.
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                                  8.0 Pollution Prevention and Wastewater Treatment Technologies
 A properly  designed  steam stripper can reduce the BOD5 load to  a mill's wastewater
 treatment system by removing organic compounds, primarily methanol, from the pulping
 area condensate streams.  Mills that currently use steam stripping to reduce the load of
 organic constituents discharged to wastewater treatment report using  steam-to-feed ratios
 ranging from 145 to 215 kg/m3. A steam-to-feed ratio of 180 kg/m3 achieves approximately
 90 percent removal of methanol. Total reduced sulfur (TRS) compounds can be removed
 at lower steam rates.

 8.2.8  Pulping Liquor Management, Spill Prevention, and Control

 Mills that perform chemical or semi-chemical pulping of wood or other fibers  generate
 pulping liquors that are generally either recovered in a chemical recovery system or treated
 in a wastewater treatment system.  These mills  may lose pulping liquor through spills
 equipment leaks, and intentional diversions from the pulping and chemical recovery areas
 of the mm. Spills and intentional diversions of pulping liquor are a principal cause of upsets
 in biological wastewater treatment systems, which are used at most chemical and semi-
 chemical pulp mills. Pulping liquor losses increase the need for pulping liquor make-up
 chemicals, decrease energy generated from pulping liquor solids combustion,  increase
 hazardous air pollutant emissions, and may result in biological treatment upsets.

 Unintentional pulping  liquor losses at pulp  mills are most commonly caused by process
 upsets, equipment breakdowns, and tank overfillings.  Maintenance and construction in a
 mill s pulping and chemical recovery areas may cause intentional diversions of pulping liquor
 to the wastewater  treatment system. Pulping liquor may also be lost  during normal mill
 operations, such as planned shutdowns and start-ups and pulp grade changes.

 Management programs, combined with engineered controls and monitoring systems can
 prevent or control pulping liquor losses. These efforts should be both proactive to prevent
 pulpmg liquor losses and reactive to control spills  after they have occurred.

Practices to prevent or control pulping liquor losses at chemical pulp mills include the
following:

      •      Management of process operations to minimize variability.

      •      Preventative maintenance programs for equipment in pulping liquor service.1

      •      Automated  spill detection,  such as  conductivity sensors in sewers ,'in the
             pulping and chemical recovery areas.

      •      Frequent  operator surveillance of pulping  and chemical recovery  areas to
             quickly detect and repair leaks.

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                                8.0 Pollution Prevention and Wastewater Treatment Technologies
      •      Secondary containment and high-level alarms on weak  and strong pulping
             liquor tanks.

      •      Spill collection systems for  the pulping and chemical recovery  areas with
             sufficient capacity to store collected spills and planned liquor diversions. The
             collected liquor may then be recovered in the chemical recovery system or
             slowly released to the wastewater treatment system (e.g., weak pulping liquor
             that would not adversely impact the treatment system).

Mills with effective pulping liquor  spill prevention and control programs have instituted  a
combination  of these practices to substantially eliminate black liquor  losses.  It has been
reported that the practical maximum reduction in BOD5 raw wastewater loading that  can
be attained from spill prevention  is 5 kg/metric  ton (13).  Based upon site visits by  the
Agency  it appears  that sulfite mills are less likely than kraft or  soda mills to have
engineered controls for collecting spills and leaks of pulping liquors at the immediate
process areas.

Details of the practices listed above, and the associated estimated costs and  effluent
reduction benefits for nulls that chemically pulp wood or other fibers are in the document
entitled  "Technical Support Document for Proposed Best Management Practices Programs,
Pulping Liquor Management,  Spill Prevention and Control," located in the Record for the
Rulemaking.

8.2.9  Maximizing Recovery Boiler Capacity

At kraft mills, spent cooking liquor (black liquor) from the digester and from brown stock
washing is sent to the chemical recoveiy area, where it is concentrated in multiple-effect
evaporators  and then burned as  part of the  chemical recovery process.  Section 4.2.4'
describes this process in detail. The organic fraction of the concentrated black liquor solids
generates heat as it is burned, and the inorganic  material produces a molten smelt .that is
dissolved to  regenerate the cooking chemicals.

When a mill improves its brown stock washing or installs oxygen delignification or extended
cooking, it is common practice to  recycle the resulting filtrates to the  recovery boiler,  thus
increasing the amount of organics to the recovery boiler.  The heating value  of these
additional organics is an important factor in determining whether a mill needs to increase
the  burning capacity of its recovery boiler when it  makes these process  changes. Thirty-nine
mills in the Bleached Papergrade Kraft and Soda Subcategory and one  mill in the Dissolving
 Kraft Subcategory indicated in the 1990 questionnaire that their pulp production capacity
was limited  by the burning capacity of their recovery boilers.
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                                  8.0 Pollution Prevention and Wastewater Treatment Technologies
 The increase in the heating load on the recovery boiler (referred to in this section as an
 increase in boiler capacity) depends not only upon the amount of organics coming from the
 process, but also  upon their heating value.  The heating value of the  organics  differs
 depending upon the wood furnish (hardwood or softwood) and the process from which the
 organics are obtained.  For example, the solids recycled from an oxygen delignification
 process have been oxidized and therefore have  a lower heating value than those recycled
 from a brown stock washer or digester. Also, more organics are recovered from softwood
 pulp than from hardwood pulp. The increase of approximately  3 to 4 percent in organics
 that is expected from upgrading a mill's  brown stock washing system and adding oxygen
 delignification and extended cooking generally requires an increase of about 2 to 4 percent
 in recovery  boiler capacity (14).

 In U.S. mills, the  increase in recovery boiler capacity that results from improving  brown
 stock washing alone is  minimal (generally less  than 1 percent) because, as indicated in
 Section  8.2.3,  U.S.. mills,  on  average,  have fairly  good brown  stock  washing.   This
 contribution to the  recovery  boiler is  negligible  when the  accuracy  of boiler flow
 measurements  is taken into account.  However, the impact of extended delignification
 processes such as extended cooking and oxygen delignification is significant in determining
 increases in recovery boiler capacity.

 A mill can  compensate for an increase in solids loading to the  recovery boiler in several
 ways (15).   One solution is  to incrementally increase the capacity of the existing recovery,
 boiler by expanding the boiler bed. Other options include making adjustments or modest
 equipment upgrades to the existing boiler, modifying the air system,  or replacing the, boiler
 with a larger unit.  However, because the capital cost of a new recovery boiler ranges from
 50' to 100 million dollars, it is more economical to increase the capacity of the existing
 boiler.

 Alternatives to increasing  the burning capacity of the recovery boiler are to reduce the load
 on the boiler by using anthraquinone in the digester; installing high black liquor solids firing;
 decreasing pulp production; removing the  soap fraction of the black  liquor; or transporting
 black liquor to another mill for incineration.   Methods for increasing  recovery  boiler
 capacity  and decreasing the load on' the recovery boiler are discussed below.
8.2.9.1
Recovery Boiler Expansion
To incrementally increase the boiler's capacity for burning black liquor, the boiler bed can
be physically expanded through rebuilds and equipment upgrades to combust a higher load
of solids.  In some cases, relatively minor adjustments or modest equipment upgrades to
such items as liquor feed pumps will increase boiler capacity.
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                                 8.0 Pollution Prevention and Wastewater Treatment Technologies
8.2.9.2
Air System Modifications
Modifications to the boiler's air system can increase recovery boiler capacity. The objective
of these modifications is to attain as complete combustion as possible in the lower part of
the boiler, to reduce carryover of unburned particles into the upper boiler, where plugging
is most likely to occur.

Most recent air system upgrades use high-pressure air.  This air is fed through small ports,
creating higher than normal turbulence in the lower furnace. The increased heat transfer
to the lower water walls lowers temperatures in the upper area of the boiler, reducing
particulate carryover.
82.9.3
Anthraquinone
When wood chips are pulped in the digester, some loss of cellulose and hemicellulose along,
with the lignin occurs. Adding anthraquinone to the pulping liquor in the digester has been
shown to reduce the loss of these carbohydrates during pulping by stabilizing the molecules
from "peeling" reactions.  Peeling  is the detachment of sugar groups from the end 'of the
carbohydrate chain. As a result of  anthraquinone's stabilization of cellulose, pulp yield
increases: less wood is pulped to achieve the same pulp yield.  For a given production, the
amount of black liquor organics sent from the digester to the recovery boiler is thereby
reduced.  Anthraquinone  has also  been shown to accelerate the pulping process and does
not affect pulp properties such as  strength and viscosity.

The reacted anthraquinone is removed along with the spent cooking liquor, and is burned
in the recovery boiler.  Anthraquinone has not been shown to remain with the pulp after
bleaching.

Pulp yield increases of 1 percent with boiler load reductions of about 4 percent are typical
when a mill adds anthraquinone. Anthraquinone use can also allow the pulping process to
occur at a slightly lower temperature, resulting in energy savings; also, pulping chemical
requirements  are reduced.   Five mills  in the Bleached Papergrade Kraft and Soda
Subcategory reported using anthraquinone in their pulping operation.
8.2.9.4
High-Consistency Black Liquor Solids Firing
Traditional recovery boilers burn black liquor at a consistency of between 60 and 70 percent.
Firing of high-consistency (80 percent) black liquor solids has been shown to increase boiler
capacity (16).

Burning higher consistency black liquor reduces the gas flow through the boiler, which
reduces the tendency of the boiler to plug.   A higher temperature  will result in the

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                                   8.0 Pollution Prevention and Wastewater Treatment Technologies
  combustion zone, which will reduce the emissions of total reduced sulfur and improve the
  reduction  efficiency.of  the  recovery boiler.   Carryover of unburned particles will also
  decrease as the gas flow is lowered. Although these characteristics indicate that the boiler's
  capability to burn increased quantities of black liquor solids will improve, some trials have
  shown that the success of this method may be  boiler-specific.
 8.2.9.5
Other
 In addition to the technologies discussed above, several other measures can be implemented
 to increase  recovery boiler capacity.  These include lowering pulp production, removing
 black liquor soap, and transporting spent liquor to another mill for incineration.

 The most uncomplicated way to reduce recovery boiler load is by lowering pulp production
 rate.  However, this approach is economically unattractive to most mills.

 If the soap fraction of the spent cooking liquor (consisting largely of resin and fatty acids
 irom the wood that become ionized in the pulping liquor) is separated from the black liquor
 and sold, burned  outside the recovery boiler, or converted to tall oil, the heating value of
 the black liquor can drop by 4  to 8 percent.  A lower heating value from the black liquor
 solids results in less heat produced per mass unit of solids in the boiler.  Less recovery
 boiler capacity is  therefore required to burn the same mass of black liquor organics.

 Kraft mills can sometimes transport their black liquor to other  mills for incineration  instead
 of burning it on  site.   The green liquor produced would normally be returned to the
 originating mill.   This practice is generally impractical  for mills that  are not within
 approximately 300 kilometers of a mill with excess recovery boiler capacity.

 8-3    Pollution Prevention Controls Used in the Bleach Plant

 This  section describes  applicable technologies for reducing and preventing  poUutant
 discharges from bleach plants at chemical pulp mills. For most facilities, the Agency defines
 the bleach plant as including the  stage where bleaching agents (e.g., chlorine, chlorine
 dioxide, ozone, sodium or calcium hypochlorite, peroxide) are first applied, each subsequent
 extraction stage, and each subsequent stage where bleaching agents are applied to the pulp
 A limited number of mills produce specialty grades of pulp using hydrolysis or extraction
 stages pnor to the first application of bleaching agents. For those mills, EPA considers the
 bleach plant to include those pulp pretreatment stages. Although oxygen delignification
 systems are integrated with pulping and chemical recovery systems,  the convention in the
mdustry is to include oxygen delignification when specifying bleach sequences (e g  O D/C
7*.  '.'.     ASency1S using that convention in this document,  although it considers oxygen
delignification to be part of pulping rather than bleaching.  Section 4.2.6.1  presents an
overview of bleach plant operation.

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                                8.0 Pollution Prevention and Wastewater Treatment Technologies
8.3.1  Counter-current Washing

In a typical bleach plant, each stage of bleaching is followed by washing in vacuum or
diffusion washers to remove residual chemicals and dissolved reaction products from the
pulp  Prior to 1960,  it was standard practice to use fresh water to wash pulp between
bleaching stages. This required a large amount of fresh water (approximately 300 m /metric
ton of pulp) and energy to heat  that water, and resulted in large bleach plant effluent
discharges. In the 1960s, mills began to reuse bleach plant effluents for washing. Currently
almost all mills use some form of countercurrent washing between bleaching stages, which
conserves bleaching chemicals and heat, and reduces effluent discharge.

Various degrees of countercurrent washing can be performed. In jump-stage countercurrent
washing  the most common form of countercurrent washing, wash water is recycled from the
final acid bleaching stage back through all the other acid bleaching stage washers skipping
the alkaline stage washers.  Similarly, the wash water from the final alkaline bleaching stage
is recycled back through the alkaline stage washers. Two bleach plant effluents result: one
from the first acid bleaching stage and one from the first alkaline bleaching stage.  Water
usage for a jump-stage  countercurrent system is approximately 30 to 40 m /metric ton ot
pulp.

In a fully countercurrent washing system, fresh water is added to the final bleaching stage
washer and circulated back through each  preceding washer to the  first bleaching stage
washer.  Effluent from the first bleaching  stage washer is  discharged to  the sewer.  The
amount  of water used in this system is approximately 25 m3/rnetric ton of pulp.  Mixing the
effluents from the acid and alkaline washing stages may produce foaming and precipitation
of chlorolignin compounds, but  this can be controlled by installing washers with large
enough  capacity such that they are not overloaded, sizing the seal tank  large enough to
allow foam to break down, and installing better showers to remove scale  from the washer
wires Modern countercurrent washing systems are normally constructed of materials able
 to withstand thd more corrosive environment created by the concentration  of  chlorine
 compounds in the washers.

 Some mills use  minimal wash  water recirculation in the  bleach plant, primarily by
 recirculating water from the areas where the pulp is thickened rather than washed. This
 reduces bleach plant flow by approximately 60 percent compared to the  completely open
 system.

 8.3.2 Ozone Bleaching

 Ozone  is a powerful oxidizer, which has  been studied for  over 20 years as a potential
 replacement for chlorine and  chlorine  dioxide in the  first  stage of pulp bleaching.
 Historically,  two major drawbacks have inhibited the  adoption of industrial-scale ozone
                                                                 i

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                                   8.0 Pollution Prevention and Wastewater Treatment Technologies
 bleaching: high cost and poor selectivity (i.e., a high degree of carbohydrate degradation
 and therefore  viscosity  drop) (17).   Recent  technological developments,  such as the
 introduction of medium-consistency ozone bleaching and improvements in ozone efficiency
 and selectivity, have removed these disadvantages to using ozone (17,18), and  ozone
 bleaching technology continues to evolve. The first full-scale ozone bleaching systems in a
 sulfite mill and a kraft mill were started up in 1991 and 1992, respectively.  Table 8-1 lists
 current and planned ozone installations.

 Ozone is generated either from oxygen or air, though it is normally produced using oxygen.
 The oxygen (O2) passes through a series of tubes and a high voltage is applied, causing the
 oxygen molecules to dissociate. The dissociated molecules recombine to form ozone (O3),
 which is relatively unstable.  Since ozone can easily decompose back to oxygen, ozone must
 be generated on site for immediate use in the bleach plant.

 Ozone bleaching has been researched at low, medium, and high consistencies.  There are
 no full-scale low-consistency systems at this time. Most currently operating full-scale systems
 process the pulp at medium consistency (10 to  15 percent).  Medium-consistency systems
 have lower capital costs than do high-consistency  systems (18).

 Oxygen delignification with effective post-oxygen  washing is necessary prior to ozone
 bleaching to lower the lignin content of the pulp and therefore reduce the ozone charge
 required.  There ,are currently no defined "target" Kappa numbers documented for the pulp
 entering the ozone stage; for ozone bleaching, target Kappa numbers tend to be site-specific.
 Ozone oxidizes the carbohydrates in pulp as well as the lignin, so the ozone charge must be
 optimized to achieve the maximum pulp delignification while minimizing the effects on pulp
 viscosity. Mills currently operating ozone bleaching systems use between 5 and 12 kg ozone
 per metric ton of pulp, although actual application rates and operating conditions for this
 technology are  usually confidential.  A  high-consistency system allows  a higher ozone
 application rate than a medium-consistency system.

 The processes and  equipment used for ozone  bleaching and oxygen delignification are
 similar.  Prior to being fed to the ozone  bleaching  tower, the pulp is treated with either
 acetic or  sulfuric acid to lower the pH.  As with oxygen delignification, the pulp may be
 fluffed in the reactor to facilitate a more uniform reaction. Ozone is delivered to the
 reactor with an oxygen carrier gas.  This carrier gas can be recovered after ozone bleaching,
 cleaned, and recycled to the ozone  generator, or used elsewhere in the mill (e.g., in an
 oxygen delignification system or an oxygen-enhanced extraction stage).

The reaction of the pulp with the ozone normally takes a few minutes, as opposed to a few
hours with other bleaching agents.  The ozone bleaching reactor is therefore much smaller
than other reaction vessels in traditional bleach plants.
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                                 8.0 Pollution Prevention and Wastewater Treatment Technologies
Process effluents from ozone bleaching can be  recycled to the recovery boiler, which
decreases the  volume of bleach plant  effluent and  the amount  of non-chlorinated
compounds discharged from the bleach plant. Because chlorine and chlorine derivatives are
not used  for first stage bleaching, chlorinated organic compounds (e.g., CDDs/CDFs,
chlorinated phenolics) are not formed. The increase in the load of solids on the recovery
boiler from  recycling  the  ozone  stage  filtrate  is lower than  that  from  an oxygen
delignification stage. The increase in solids for the ozone and subsequent extraction stages
cause an additional heating load on the recovery boiler of approximately 1 percent (19).

8.3.3   Split Addition of Chlorine

Split addition of chlorine involves separating the single chlorine charge to the first bleaching
stage into multiple smaller charges that are added sequentially, producing a more constant
chlorine charge in the first bleaching stage. High shear mixing is necessary for  optimum
contact between, the chlorine and the pulp and to avoid localized high concentrations of
chlorine, and sodium hydroxide is used to raise the pH to a higher than normal level.  This
pH level must be carefully controlled (20).

Split  addition of chlorine has been shown to reduce, but not eliminate, the formation of
chlorinated phenolics and chlorinated dioxins and furans in the bleach plant, while retaining
pulp  quality.  This technology does not have a measurable effect on a mill's effluent
discharge of unchlorinated organics (21). An additional benefit of split addition is that the
capital expenditure is  small compared to other technologies  for reducing bleach plant
discharges of chlorinated organics.

As of January 1,  1993, 11  of the 87 mills in  the Bleached Papergrade  Kraft and  Soda
Subcategory reported using this technology on one or all of their bleach lines. Split addition
has not been demonstrated at dissolving grade or sulfite mills.

8.3.4  Improved Mixing and Process Control

To realize the full benefits of technologies such as split addition of chlorine, high chlorine
 dioxide substitution, oxygen-enhanced extraction, and oxygen delignification on the bleach
plant effluent, the pulp and bleaching agents must be well-mixed and the chemical addition
 rate  controlled as  precisely  as possible.  Normally, when technologies such as  these are
 installed, mixing and process control are also upgraded.

 High shear mixers, introduced in the late 1970s, dramatically increased the contact of the
 pulp with gases such as oxygen, making the oxygen-enhanced extraction stage a practical,
 effective bleaching technology (22).  High shear mixing has similarly become a vital part of
 a medium-consistency oxygen delignification system. To ensure uniform application of the
 chemicals in a high chlorine dioxide substitution stage, the pulp must be well-mixed with the

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                                   8.0 Pollution Prevention and Wastewater Treatment Technologies
  chlorine dioxide gas.  Finally, as noted in Section 8.3.3, the use of high shear mixers is
  essential with split addition of chlorine to  avoid high localized concentrations of chlorine.

  8.3.5  Chlorine Dioxide Substitution

  Substituting chlorine dioxide for some or all of the molecular chlorine in the first bleaching
  stage has become common practice in the  industry, because C1O2 substitution reduces the
  formation of chlorinated organics in the  bleach plant effluent and lowers bleach plant
  chemical consumption (23).                                                     K

  The amount of chlorine dioxide used is expressed as percent substitution. The percentage
  of chlonne dioxide substitution is defined as the percentage of the total chlorine bleaching
 power of the first bleaching stage that is provided by chlorine dioxide, and is calculated by
 the following formula:                                                              J
      Percent Substitution =
2.63 (C1O2 in kg/metric ton)
                             2.63 (C102 in kg/metric ton)  + (C12 in kg/metric ton)
 (1)
 where 2.63 equals the oxidizing power of chlorine dioxide compared to chlorine.

 Chlorine dioxide is a stronger oxidizing agent than chlorine. Consequently, less chemical
 below                ^ dlOXide 1S Substituted for chlorine. An example of this is shown
                         
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                                 8.0 Pollution Prevention and Wastewater Treatment Technologies
      2.63 (C102 in kg/metric ton) + (C12 in kg/metric ton) = 65 kg/metric ton
(3)
Solving for the mass flow rates of chlorine and chlorine dioxide results in application rate
of 32.5 kg/metric ton chlorine and 12.4 kg/metric ton chlorine dioxide.  Thus, the total
amount of chemical added at 50 percent substitution is 44.9 kg/metric ton^ instead of he
65 kg/metric  ton that is added without chlorine dioxide substitution. This reduces  the
amount of chlorine available to form chlorinated organics.

Chloroform formation is  substantially reduced  when  a  mill raises  chlorine  dioxide
substitution to between 50 and 100 percent (24). Discharges of under 10 g/metnc ton pulp
can be expected with 100 percent chlorine dioxide substitution  including the chloroform
emitted at all atmospheric vents. Chloroform levels also depend on he order of chlorine
STd chlorine dioxide addition in the first bleaching stage.  Adding chlorine dioxide before
chlorine generates 2 to 5 times more chloroform than does adding them simultaneously (24).
Chlorine  dioxide substitution also results in improved pulp quality because it minimizes
cellulose  degradation.   Chlorine dioxide substitution does not affect the  discharge of
unchlorinated compounds.

Chlorine  dioxide must be generated on site because it is unstable and cannot be transported
in a  pure form by truck or rail. As of January I,  1993,  most of the mills that bleach
chemically pulped wood pulps generated chlorine dioxide on site, and more than 60 percent
of those mills used chlorine dioxide substitution in the first bleaching stage, as shown below.



Subcategory
Dissolving Kraft
Bleached Papergrade Kraft and
Soda
Dissolving Sulfite
Papergrade Sulfite
======
Total
Number of
Mills
3
87

5
10
==========
Number With
OOj Generation
On Site
3
79

3
5
========
Number With CIOZ
Substitution in
First Bleacbing
Stage
3
60

3
4
  In generating chlorine dioxide, there is also some byproduct generation.  Sodium sulfate
  (Nis04) and chlorine are generated in different amounts,  depending on the  chlorine
  dioxide generator, as shown below (25):
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                                  8.0 Pollution Prevention and Wastewater Treatment Technologies
Chlorine Dioxide Generator
Solvay
Mathieson
R2
R3
R8
CJj (kkg/kkg CIO*)
0
0
0.66
0.66
0
Sf%S04 (kkg/kkg CLOz)
3.5
3.5
7
2.4
1.4
 It is important to control the ratio of chlorine applied in the first bleaching stage to lignin
 content of the pulp  entering the first bleaching stage, as well as the amount of C1O2
 substitution, to most effectively reduce the formation of chlorinated compounds (23).  The
 ratio of molecular  chlorine applied in the first bleaching  stage (expressed as percent on
 pulp) to Kappa number of the pulp entering the first bleaching stage is referred to in this
 document as the gaseous chlorine multiple (GCM):
                      GCM =
  C12 (kg/100 kg brown stock)
Pre-chlorination Kappa number
(4)
 The ratio of total chlorine (from molecular chlorine  and chlorine dioxide) in the first
 bleaching stage (expressed as percent on pulp) to Kappa number of the pulp entering the
 first bleaching stage is referred to in this document as the active chlorine multiple (ACM):


     ACM =  tcl2 (kg/100 kg brown stock) + 2.63 C1O2 (kg/100 kg brown stock)] (5)
                               Pre-chlorination Kappa number


 It has been shown that mills that control chemical dosage to maintain a GCM of 0 15 or less
 can be expected to have no detectable 2,3,7,8-TCDD or  2,3,7,8-TCDF in their bleach plant
 effluent (26).  This is primarily applicable to mills with low  (30 percent or less) CIO
 substitution.

 The ACM is a more appropriate guideline for chemical dosage for mills with  greater than
 30 percent C1O2 substitution. A Canadian study evaluated formation of 2,3,7,8-TCDD and
 A'™8/TCCDF in the final effluent from bleached kraft mills relative to C1O2 substitution and
ACM (27). The study developed an equation for the relationship between C1O2 substitution
and ACM, using three assumptions:
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                               8.0  Pollution Prevention and Wastewater Treatment Technologies
      1)    When chlorine is used alone, lignin very quickly consumes chlorine at an
            ACM of 0.16;

      2)    When chlorine and C1O2 are both used in the first bleaching stage, chlorine
            reacts with lignin three times faster than does C1O2; and

      3)    There is a possibility of measurable concentrations of TCDDs and TCDFs
            forming only if residual molecular chlorine remains after the reaction with
            lignin.  (The detection limits in the study were 10 ppq for 2,3,7,8-TCDD and,
            30 ppq  for 2,3,7,8-TCDF.)
               i
These assumptions had been previously supported by laboratory work (28,29).

The equation developed is shown below:
      0.16
              ACM (100 - % C1O2 substitution)    ACM (% QO2 substitution)
                            100
3(100)
This equation simplifies to:
                        ACM <
                                            24
                                 150  -  % C1O2 substitution
                  (7)
 Dividing through by the right side of the equation gives:
                                    ACM
                        24/(150 - % C1O2 substitution)
                                                       <;  1
                  (8)
 The left side of this equation is referred to in this document as the ACM Ratio.  It can be
 used to calculate the  amount  of C1O2 substitution required for a mill to achieve  non-
 detectable final effluent concentrations of 2,3,7,8-TCDD and 2,3,7,8-TCDF, as indicated by
 an ACM Ratio of less than or equal to 1.0.  The relationship is shown on the following
 graph:
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                                  8.0 Pollution Prevention and Wastewater Treatment Technologies
                            20       40       60
                                  % CIO2 Substitution
80
100
8.3.6  Enhanced Extraction

In the alkaline extraction stages of the bleach plant,  lignin reaction products from the
preceding acid stages are dissolved, or extracted, by applying sodium hydroxide (caustic)
solutions to the pulp. These dissolved products are then washed from the pulp.  The first
caustic extraction stage of the bleach plant can be enhanced with oxygen, hydrogen peroxide,
or both (shown as E0, Ep, and E^, respectively) to replace equivalent quantities of chlorine-
based bleaching chemicals in other bleaching stages (30).  Enhanced extraction is a low
capital cost measure that improves effluent quality by reducing  chlorine consumption,
therefore reducing the amount of chlorinated organics in the bleach plant effluent. Mills
implementing enhanced extraction typically reduce  molecular chlorine use in the first
bleaching stage,.while keeping the  chlorine dioxide addition rate constant (resulting in a
higher level of chlorine dioxide substitution).

Oxygen-enhanced extraction became commercially feasible in the  early 1980s due to the
development and introduction of high-shear mixers for pulp stock.  A high-shear mixer is
required to ensure'good mixing of the gaseous oxygen with the pulp.  The extraction must
be carried out in either an upflow extraction tower or a downflow tower preceded by a small
upflow pre-retention tube  to maintain the pressure  required to keep the oxygen gas in
solution until it has reacted with the pulp. Adding oxygen to the extraction stage improves
delignification by approximately 25 percent (31), while allowing the mill to use less chlorine
or chlorine dioxide in the overall bleaching sequence. Adding between 4 and 6 kg of oxygen
per metric ton of pulp saves approximately 2 kg of active chlorine per kg of oxygen (22).
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                                 8.0 Pollution Prevention and.Wastewater Treatment Technologies
Oxygen-enhanced extraction normally reduces overall bleaching chemical  costs,  thus
justifying, in many cases, the capital cost of the additional mixing power and piping required.
This is evidenced by many mills in the U.S. converting their bleaching sequences to E0
operation during the 1980s.

Hydrogen peroxide is usually added at the inlet to the oxygen mixer when E^ is used, or at
the inlet to the stock pump for Ep alone. Adding hydrogen peroxide in the first extraction
stage improves deligmfication and reduces chlorine-based chemical requirements either in
the first chlorination stage or further along in  the bleaching sequence.  Applying  1 kg of
peroxide per metric ton of pulp results in an active chlorine savings of approximately 2 to
3 kg (25). If hydrogen peroxide-enhanced extraction is used following 100 percent chlorine
dioxide substitution, a higher final brightness can be achieved (22).

Mills that use hydrogen peroxide-enhanced extraction are able to reduce the amount of
either molecular chlorine or chlorine dioxide in  other bleaching stages.   The  cost .of
hydrogen peroxide is currently much higher than the cost of molecular chlorine and slightly
lower than the  cost of chlorine dioxide (see Section 11.0).  Therefore, a mill operating
hydrogen peroxide enhancement increases its operating costs if it reduces molecular chlorine
use, but decreases operating costs if it reduces chlorine dioxide use.

Adding oxygen to an extraction stage is more capital intensive than adding peroxide because,
as described above, a high shear mixer and other equipment must be used for the bleaching
stage to operate effectively. Therefore, the simplest way for a mill to enhance its extraction
stage  is with  hydrogen peroxide.  Hydrogen peroxide  is also effective in enhancing  the
second extraction stage, unlike  oxygen.

A significant number of U.S. bleached pulp mills have implemented enhanced extraction.
As of January  1, 1993, mills  in all four  BAT subcategories were using some form of
enhanced extraction, as  shown below:
Subcategoiy
Dissolving Kraft
Bleached Papergrade
Kraft and Soda
Dissolving Sulfite
Papergrade Sulfite
Total Number of Mills
3
87
5
10
Numbe* With Enhanced
Extraction (E^ Ep, or Eop)
1
65
2
4
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                                  8.0  Pollution Prevention and Wastewater Treatment Technologies
 8.3.7  Elimination of Hypochlorite

 Sodium hypochlorite and calcium hypochlorite are effective bleaching agents that attack
 lignin.  Suffite pulps are more easily bleached with hypochlorite than kraft pulps because
 the lignin  is more easily solubilized (32).   Hypochlorite can  also  degrade cellulose,
 decreasing pulp viscosity.  To limit cellulose degradation, hypochlorite is usually applied in
 an intermediate bleaching stage for kraft pulps.  Hypochlorite is also used to control pulp
 viscosity in dissolving pulps, as discussed in Section 8.3.8.

 Chloroform is generated when pulp is  bleached with hypochlorite (33).  Mills that use
 sodium or calcium hypochlorite in one or more bleaching stages generate approximately ten
 times as much chloroform as  mills using a CEDED bleaching sequence (34). Controlling
 chloroform releases generally entails eliminating hypochlorite as a bleaching agent.  The
 bleaching power of hypochlorite can be replaced by chlorine, chlorine dioxide, peroxide,
 and/or oxygen.  However, replacing hypochlorite with chlorine is counterproductive if the
 purpose is to reduce chloroform generation, because bleaching with molecular chlorine also
 generates chloroform.

 For some mills, particularly those with short bleaching sequences (e.g., CEH), eliminating
 hypochlorite requires replacing the hypochlorite bleaching tower with a new chlorine dioxide
 tower, washer, and auxiliaries made of materials resistant to the more corrosive environment
 of chlorine dioxide bleaching. Some nulls may be able to modify the bleaching chemical
 additions to other stages (i.e.,  adding oxygen and/or peroxide to the first extraction stage)
 and abandon the hypochlorite stage, rather than replacing it. This may apply to mills with
 a CEHDED-rype of bleaching sequence and mills using hypochlorite  only in extraction
 stages.

Replacing  hypochlorite  reduces  direct  operating costs, because  hypochlorite is more
expensive than chlorine dioxide, oxygen, and peroxide and has a lower chlorine equivalence
factor  (see  Section 11.1.2.6).  The  number of  nulls using  a  hypochlorite  stage or
hypochlorite-reinforced extraction as of January 1, 1993 is shown below:
Subcategory
Dissolving Kraft
Bleached Papergrade
Kraft and Soda
Dissolving Sulfite
Papergrade Sulfite
Total Number of Mills
3
87
5
10
=========================
Mills Using Hypochlorite
3
36
5
9
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                                8.0 Pollution Prevention and Wastewater Treatment Technologies
83.8  ffigh-Temperature/High-Alkalinity Hypochlorite Bleaching

Some mills, particularly dissolving kraft and suffite mills, may have difficulty eliminating
hypochlorite from their bleaching sequences because of hypochlorite's ability to control the
pulp viscosity required for dissolving pulp final products. An alternative for these mills to
reduce chloroform generation in the bleach plant is to use high-temperature/high-alkalmity
hypochlorite bleaching (35). This involves increasing the temperature in the  hypochlonte
stage from approximately 60°C to between approximately 70°C and 80°C and increasing the
pH from approximately 10 to between approximately 12 and 13. This procedure appears
to destroy chloroform in the H stage after it is generated, but before it is emitted to air or
discharged to water (36). This process has been tested in several full-scale mill applications
with no adverse effects on pulp viscosity or brightness.

8.3.9  Enzyme Bleaching

Enzymes  are  organic compounds that act as catalysts in reactions.  Xylanase enzymes
improve the bleachability of wood pulps by partially hydrolyzing the xylan, the primary
bonding agent between the cellulose and the lignin, although the exact mechanism by which
they aid in bleaching is not known (37). The lignin is therefore more easily removed in
subsequent bleaching stages. Xylanase may be added to the pulp after brown stock washing
or after oxygen delignification to reduce or eliminate the need for bleaching with chlorine
compounds. The optimum conditions for the xylanase reaction are temperatures between
40 and 55 °C,  pH between 4 and 6, and detention time between 0.5 and 3 hours (37).  The
xylanase is  applied at less than 1 kg/metric ton of pulp.

Several mills  worldwide have conducted full-scale trials with xylanase on kraft pulps with
resulting increases in brightness and viscosity and no loss of pulp strength (37).   More
experimental  work has been done using enzymes to bleach kraft pulps than to bleach sulfite
pulps.

83.10  Peroxide Bleaching

Though hydrogen peroxide is primarily used to reinforce caustic extraction stages, hydrogen
peroxide can replace chlorine compounds in bleaching chemical pulps.  The  brightness
 achievable using peroxide can be increased by lowering the lignin content of the pulp as
 much as possible prior to bleaching (e.g., by using oxygen delignification).

 While bleaching stages that use chlorine compounds inherently remove metal ions from the
 pulp, these ions will react with peroxide to form hydroxyl radicals that can degrade cellulose.
 Therefore, the metal ions must be removed from solution by using chelating agents, followed
 by effective pulp washing prior to applying peroxide (38). When a peroxide stage follows

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                                  8.0 Pollution Prevention and Wastewater Treatment Technologies
 a chlorine compound bleaching stage, separate addition of a chelating agent is not required.
 One method of peroxide bleaching using chelating agents is the Lignox® process developed
 by Eka Nobel (39).

 The peroxide charge, required for a full peroxide stage is approximately 2.5 percent on pulp.
 To fully utilize the peroxide charge and achieve high brightness requires a temperature of
 between 70 and 90°C and retention time between 2 and 4 hours, but these conditions may
 decrease pulp viscosity (38).

 Peroxide bleaching has been demonstrated in full-scale applications at both kraft and sulfite
 mills outside  the U.S.  As of January 1,  1993, no U.S. kraft mills bleached pulp with
 peroxide alone, but peroxide bleaching was in use  at one mill in the Papergrade Sulfite
 Subcategory and two mills in the Dissolving Sulfite Subcategory.

 The capital cost of implementing peroxide bleaching is minimal, assuming use of existing
 bleaching towers.  Because the unit cost for hydrogen peroxide is higher than for chlorine,
 operating  costs for peroxide bleaching may be higher depending  upon the amount of
 peroxide used. The cost of the large amount of peroxide that is necessary to bleach a pulp
 to full brightness has limited the use of peroxide bleaching.

 8.3.11 Totally Chlorine-Free Bleaching of Papergrade Kraft Pulps

 The production of totally chlorine-free (TCP) bleached kraft pulp is  accomplished using a
 combination of ozone, oxygen, enzymes, and/or peroxide in place of chlorine  or chlorine
 derivatives.  In the last several years, numerous TCP bleaching processes  have been
 developed, and at present, more than 15 mills worldwide produce TCP papergrade kraft
 pulps. However, most kraft TCP bleaching lines are not dedicated to TCP production due
 to lack of market demand. Most TCP kraft pulps are lower brightness pulps than market
 kraft grades (75-80 ISO vs 88-90 ISO).

 EPA found that only one mill, located in Sweden, routinely produces commercial quantities
 of high brightness (88-90  ISO) TCP hardwood papergrade kraft pulp.  This  mill began
 production of this high brightness pulp in September 1992 using a bleaching sequence that
 includes ozone, and, in January 1993,  began mill trials to produce TCP softwood kraft pulp
 using ozone.

 Two mills in Finland produce commercial quantities of pulp using a TCP bleaching process
 for both hardwood and softwood, and  a third mill has been running TCP trials (40,41). The
 first  two mills  use extended cooking  and oxygen delignification followed by enzyme and
peroxide bleaching to produce pulp with a brightness of over 80 ISO for softwood and
approximately  85 ISO for hardwood.   One  of  these  mills  plans to  convert all of  its
production  to  TCP in 1994 after  installing an  ozone bleaching  system to help lower

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                                8.0 Pollution Prevention and Wastewater Treatment Technologies
bleaching costs.  The second mill plans to install ozone blea,ching after the first mill is
bleaching its full production with ozone.

A U.S. kraft mill began producing lower brightness pulp using a TCP bleaching process in
September 1992. The mill currently bleaches eight percent of its pulp with the TCP process
and will gradually increase this to 100 percent over the next three years.  This mill pulps and
bleaches softwood (70/30 mix of Douglas Fir and redwood) to 80 Elrepho brightness. The
current bleaching sequence, following oxygen delignification, is QE^PPS (42). Q represents
an acidic chelant stage, followed by  an enhanced extraction stage  (E^), two  alkaline
peroxide stages (PP), and a sodium bisulfite stage (S).

The mill referenced above  reports significant  environmental benefits from the  TCP
bleaching sequence compared to the normal (DC/DEEDED sequence.  For example,  color
has decreased from 1,200 to less than 300 color units, and has been as low as 50 color units
when bleach plant effluents are recycled to the recovery system. None of the seventeen
2,3,7,8-substituted CDD and CDF congeners have been detected in the TCP bleach  plant
effluent, and  adsorbable organic halide (AOX), when detected, has been less  than 0.1
kg/ADMT. It is expected that when bleach plant effluents are recycled, BOD5 discharge
loadings will be significantly reduced.  Decreases in both effluent flow and heat losses are
also predicted. There is currently a discharge of approximately 1 mg/L of manganese in the
total mill effluent resulting from the discharge of the chelation (Q) stage filtrate.

In September 1992, a U.S. kraft mill began producing lower brightness kraft pulp  using
ozone bleaching.  This mill pulps  and bleaches softwood  to  approximately  82-83 ISO;
however, the  bleaching sequence at this mill (OZED) includes a final chlorine dioxide
brightening stage and thus  is not a TCP process. The following description of this mill is
based upon a recent publication (43).

This mill reports significant environmental benefits from the OZED bleaching sequence
compared to  sequences CEDED and OD/CED  for both hardwood and softwood  for
parameters such as  color, BOD5, COD, chloroform, and total organic halides. Although
chlorine dioxide is used in the final bleaching stage, 2,3,7,8-TCDD has not been detected
in D-stage filtrate or bleached pulp. Another advantage of this sequence is the  potential
to recycle filtrates from the oxygen, ozone, and extraction stages to the recovery system.
Compared to bleaching sequences of CEDED and OD/CED, the OZED sequence achieves
equivalent pulp properties,  except for viscosity, for both hardwood and softwood. Since pulp
viscosity and strength have  a different correlation for oxygen/ozone bleached pulps than for
chlorine compound bleached pulps, the mill reports the decrease in viscosity has not been
a problem.

Additional environmental benefits and further recycling of filtrates could be achieved if the
 final chlorine dioxide stage would be converted to use a non-chlorine containing compound.

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                                 8.0 Pollution Prevention and Wastewater Treatment Technologies
 The mill has studied combinations of oxygen and ozone with peroxide and believes that an
 acceptable softwood  TCP pulp can be made.  The mill does not currently use a TCP
 bleaching sequence because it would substantially increase operating costs over those of the
 OZED sequence.

 Although TCP bleaching has  been  demonstrated for both softwood and hardwood
 papergrade kraft pulps with lower brightness, the Agency  has  determined that TCP
 bleaching processes have not been adequately demonstrated for producing high brightness
 softwood papergrade  kraft pulp at this writing.  Softwood papergrade kraft pulp comprises
 a large percentage of U.S. bleached kraft pulp production.

 8.3.12 Totally Chlorine-Free Bleaching of Dissolving Kraft Pulps

 At present, none of the three U.S. dissolving kraft mills use a TCP process to bleach their
 pulp and the Agency  is not aware of any non-U.S. mill that produces dissolving kraft pulp
 using a TCP process.  Although laboratory investigations of alternative bleaching sequences
 for dissolving kraft pulps may be under way, at this time the Agency has determined that
 TCP processes are not demonstrated for or  transferable to this subcategory.

 8.3.13 Totally Chlorine-Free Bleaching of Dissolving Sulfite Pulps

 At present, there are no mills in the  U.S. that use a TCP process to bleach dissolving sulfite
 pulps.  The Agency has received information from one dissolving sulfite mill located in
 Austria that  uses a TCP bleaching process to produce viscose fiber-grade pulps using
 peroxide-enhanced oxygen delignification followed by a medium-consistency ozone stage and
 a peroxide stage. The mill uses magnesium-based sulfite cooking liquor to pulp hardwood
 (beech) to a Kappa number of 6 to 8 prior to  bleaching. The bleach plant filtrates from this
facility are incinerated in a dedicated incinerator,  because sodium in the filtrates is not
 compatible with magnesium in the pulping liquor, which is recovered.

Bleached pulp properties at this mill were reported as follows (44,45):
Pulp Property
Brightness
Cleanliness
alpha-Cellulose
Kappa
Ash
Quantify
90-92 ISO
<45 specks/m2
90.5 - 91%
<0.7
<0.06%
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                                8.0 Pollution Prevention and Wastewater Treatment Technologies
The biological wastewater treatment system at this mill reduces COD by 93 percent, and an
average AOX of 0.04 kg/metric ton is reported for the final effluent. Across the treatment
system,  BOD5 is reduced by 99 percent to approximately 0.5 kg/metric ton, and TSS is
reduced by 91 percent to approximately 1 kg/metric ton.

Although the Agency  has determined that TCP bleaching is  a viable technology for
dissolving suffite pulps, the process has not been demonstrated for all grades produced in
the U.S., particularly high purity acetate grade pulps.

8.3.14 Totally Chlorine-Free Bleaching of Papergrade Suffite Pulps

At present, there are no mills in the U.S. that use a TCP process to bleach papergrade
sulfite pulps. There are at least 10 papergrade suffite mills worldwide located in Austria,
Canada, France, Germany,  Norway, Sweden, and Switzerland  that use TCP bleaching
processes. The Agency has information on these 10 mills and believes other papergrade
sulfite mills may be using TCP processes.

The bleaching sequences at most of the TCP papergrade suffite mills are based upon oxygen
delignification, followed by one or more  peroxide bleaching stages.  Many of these mills
describe their oxygen delignification stage as an enhanced extraction stage (Eop); however,
in form and function it is the same as oxygen delignification (i.e., a pressurized tower is used
to introduce oxygen to lower the pulp lignin content). Further delignification, or bleaching,
is performed with one or more peroxide stages.  The peroxide  stages  are operated at
consistencies ranging from 12 to 30 percent; peroxide charges  vary  between 30 and 40
kg/ADMT. To prevent side reactions of metal ions in the peroxide stages, some mills use
acid washes or add,chelating agents before, between, or in the peroxide stages. Some mills
also add sodium silicate or nitrilamine to peroxide  stages  to further brighten the pulp.

The furnish  used by papergrade suffite  mills using TCP bleaching include a variety of
hardwoods (predominately birch and beech) and softwoods (mostly spruce). These TCP
sulfite mills also make a variety • of products including market pulp, tissue, and printing and
writing grades.  Bleached pulp properties vary by product. Most mills report brightnesses
 near 85 ISO; the range reported is 70 to 90 ISO.  Table 8-2 compares pulping liquor base,
 furnish, Kappa number, products, bleaching sequence, and product brightness for the TCP
 papergrade suffite mills.

 Information about other product qualities was provided by three mills. Two of these mills
 provided data  for comparison befpre and after the conversion to the TCP process.  Most
 significant product qualities at these three mills were either not changed by conversion to
 the TCP process or were  accommodated by the mills  and their customers.  Because
 products, significant product qualities, and testing methods vary from mill to mill, each mill's

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                                   8.0 Pollution Prevention and Wastewater Treatment Technologies
 experience with the conversion was different. Table 8-3 summarizes the comparative data
 provided by each mill.

 The 10 papergrade sulfite mills that use TCP bleaching include mills that use calcium,
 sodium, and magnesium base pulping liquors. One sodium base null has started to recycle
 all bleach plant filtrates back to the recovery system (i.e., to close the bleach plant).  Two
 magnesium base mills are attempting to close the bleach plant by using magnesium oxide
 instead of sodium hydroxide as the extraction stage base.  So far, both of these nulls have
 been unable to completely close their bleach plants, because some sodium hydroxide is still
 used.

 Limited final effluent data were provided by these 10 mills and are presented below:
Mill
l(a)
2(a)
3
4
5
6
7
8
9(a)
10
AOX
(kg/metric ton)
0.5
0.02 to 0.06
0.0(b)
No data
<0.01
<0.1
0.0(b)
No data
0.0(b)
0.0(b)
»ODS
(Jig/metric ton)
0.8
76
8.7(c) ,
No data
13(c)
0.8
35
No data
16
No data
COD
(kg/metric ton)
55
248
44
80
75
28
125
No data
55
50
Type of Wastewater Treatment
Primary and Secondary
Primary
Primary and Secondary
Primary
Primary and Secondary
Primary and Secondary
Primary
Primary and Secondary
Primary and Secondary
Primary
(a)Mill only bleached a portion of its pulp with a TCP process.
(b)Mill reported an AOX value of approximately zero but did not provide actual test results
(c)Test used was for BOD7.

Note that some of the effluent data reported above were developed using different analytical
methods, and are therefore not necessarily directly comparable with U.S. standard analytical
results.
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                                8.0  Pollution Prevention and Wastewater Treatment Technologies
The Agency has determined that TCP bleaching is demonstrated for the full range of grades
of papergrade sulfite pulps produced in the U.S., including both hardwood and softwood
furnishes and similar brightness ranges.

8.4   Flow Reduction Technologies

This section describes applicable technologies for i-educing wastewater discharges from pulp,
paper  and paperboard mills.  Applicable flow reduction technologies serve either of the
following purposes:' (a) treat wastewater to a quality sufficient for recycle/reuse m the same
or other processes  (e.g., savealls) or (b) reduce fresh water use by using more recycled
wastewater (e.g., self-cleaning machine showers). Many flow reduction technologies provide
additional benefits, including decreased pollutant load to wastewater treatment, improved
fiber and chemical recovery, reduced energy requirements,  fresh water treatment cost
savings, and wastewater treatment cost savings.

8.4.1  Countercurrent Brown Stock Pulp Washing

Most chemical pulp mills use countercurrent brown stock pulp washing, where water from
later washing stages is reused as wash water in earlier washing stages. Because most brown
stock washing wastewater enters the  pulping liquor recovery system, this flow reduction
technology has minimal impact on final effluent flow reduction, but does reduce the amount
of fresh water required for brown stock washing.

8.4.2  Screen Room Closure

Section 8.2.5 discusses screen room closure.  In an open system, screen room wash water is
routed to wastewater treatment. In a closed system, screen room wash water is typically
reused in brown stock washing.  Complete  closure of the screen room area can reduce by
 10 to 15 percent the total water consumed at an integrated mill.

 8.43  Recycling of Evaporator  Condensates

 Mills  can significantly reduce  final  effluent flow by stripping  and  reusing evaporator
 condensates in brown stock washing, screening, cleaning,  and thickening rather than
 discharging these wastewater streams to wastewater treatment. Most mills currently recycle
 clean evaporator condensates. With increased emphasis on condensate stripping, additional
 hot water will be available for reuse and recycle (see Section 8.2.7).

 8.4.4   Bleach Plant Countercurrent and Jump-Stage Pulp Washing

 Wastewater discharged from the bleach plant can be significantly reduced by reusing wash
 water from later bleaching stages in earlier stages via countercurrent washing or jump-stage

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                                   8.0 Pollution Prevention and Wastewater Treatment Technologies
  washing.  These technologies are described in Section 8.3.1.  Most chemical pulp mills that
  bleach pulp perform countercurrent or jump-stage bleached pulp washing.

  8.4.5  Flotation Clarification (Deinking)

  Deinking of secondary fiber is accomplished by a "washing" process that removes inks clay
  plastics, and organic material.  In this washing process, fiber is diluted to approximately 1
  percent consistency and is screened or pressed to retain usable fiber.  Dilution to such low
  consistency requires large amounts of water and results in large filtrate flows to wastewater
  treatment from the screens and presses. If the filtrate is clarified, however, it can be reused
  as dilution water in the washing process. Clarification is the preferred filtrate  treatment
  technology, because wash water,  with its  heat  and  chemicals,  is recovered  while
  contaminants are removed from the filtrate.  Flotation clarifiers have  several advantages
  over other types of clarifiers because their small volume minimizes retention time  space
 requirements, and installation costs, and they are more  effective than gravity settlers  at
 separating fine ink particles.  The sludge generated by the clarifier has a relatively high
 solids content and is easily handled by a belt or screw press.  Because the flotation clarifier
 effectively removes all types of suspended solids (fibers and contaminants), it is commonly
 preceded  by a process water filter that recovers reusable fiber (46).  Figure 8-7 includes
 illustrations of two types of flotation clarifiers.

 8.4.6   Savealls

 Savealls are the primary technology used to remove reusable fibers  and fillers from paper
 machine white water.  Many different types of savealls are used in the industry,  including
 drum filters, flotation devices, and disc filters.  Disc savealls  are generally preferred over
 other types because they possess a larger filtration area for a given floor space an ability
 to separate filtrates of different qualities, and an ability to handle large volumes and surge
 loads (47). Disc savealls consist of a series of discs mounted on a center shaft, as illustrated
 in Figure 8-8  White water flows through the filtering medium in each disk sector and
 though the shaft core. Filtrates of varying quality are generated  as the disks rotate (32)
 The initial cloudy" filtrate can be reused in stock preparation processes prior to the
 headbox.  The subsequent "clear* filtrate can be reused in low-pressure, high-volume paper
 machine showers (e.g., headbox showers, wire showers, knockoff showers, grooved roll
 showers, and roll and fabric cleaning showers) which generally do not require very hieh
 quality  water.  "Clear" filtrate may  also  be used in other pulp mill  and  bleach plant
 operations  A separate saveall should be instaUed for each paper/pulp machine, especially
 if the machines are producing different products, to avoid mixing different qualities of white-
water and to prevent upsets on one machine affecting the  performance of another
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                                8.0 Pollution Prevention and Wastewater Treatment Technologies
the
 an
8.4.7  Gravity Strainers With High-Pressure, Self-cleaning Showers

Gravity strainers remove fine, long, and medium fiber from the "clear" filtrate
saveall, so that the filtrate can be reused in paper machine showers. Figure _8-
Sustration of a gravity strainer. Gravity strainers also guard against upsets in the saveaU
load that make "clear" filtrate too dirty for reuse  in the machine showers  <«)•»«£
pressure, self-cleaning showers are commonly installed in combination L with gravity strainers
Sd other filtration devices as an added safeguard against plugging of shower  nozzles (49)
Self-cleaning shower nozzles are automatically cleaned by periodically  applying a brush or
eSa water pressure to the nozzles.  These showers can be installed  to replace machine
showers (e.g. headbox showers, wire showers, knockoff showers, grooved roll  showers and
roU and fabric cleaning showers) and require much less water than  low-pressure, high-
volume showers.  The automatic nozzle cleaning prevents plugging and makes them more
amenable to using clarified white  water.

8.4.8  Vacuum Pump Seal Water Cascade System

Cascading seal water from high- to low-pressure vacuum pumps in the press section of the
paper machine reduces fresh water requirements to this ; area jty ' approximately 5Q i percent
 (50)  The low-pressure vacuum pumps can tolerate a slightly higher seal water temperature
kan the high-pressure pumps; however, the seal water entering the ^pressure pumps
must be  cool enough that it can be used in the low-pressure pumps. Warm seal water
 decreases pump efficiency, requires larger pumps to maintain the same vacuum, and causes
 Lrmal degradation of the vacuum pump system. This technology is usually  ess expensive
 tta^fhe cooling tower technology discussed in Section 8.4.9, but its applicability is limited
 to northern mills whose fresh water temperatures are sufficiently low (51).

 8.4.9  Vacuum Pump Seal Water Cooling Tower System

 Fresh water requirements for vacuum pump seal water in the press  section of the paper
 machine can be reduced beyond that achieved in cascade systems byinstalhng  a cooling
 tower to recirculate and cool all vacuum pump seal water  (51)  The accumulation of
 chemicals and solids that cause corrosion will necessitate occasional bleeding of seal water
 to wastewater treatment.  Some fresh water make-up is required to compensate for bleeding
 and evaporative losses, but the amount of make-up required is very smaU compared to the
 amount of fresh water saved because of recirculation and cooling. This technology, although
 generally more  expensive than seal water cascade systems, is particularly  applicable for
 fouthern mills whose  fresh water temperatures may be too high to operate seal water
 cascade systems.
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  8.4.10 Adequate Wastewater Storage

  Adequate wastewater storage (e.g., storage tanks and pits) is critical to achieve optimum
  wastewater recycle and reuse during minor and most major process upsets and surges. For
  example, during a process shutdown, mills that lack adequate wastewater storage are forced
  to discharge recyclable wastewater to wastewater treatment.  When the process restarts,
  fresh water is  required to satisfy water demands because adequate recycled wastewater is
  not available.

  Mills that operate closed or nearly closed wastewater systems often require some form of
  disinfection to control build-up of biological contaminants. Disinfection systems range from
 adding biocides to wastewater storage tanks, to wastewater treatment with chlorine dioxide
 or peroxide or installation of in-process secondary treatment.

 8-5   End-of-Pine Wastewater Treatment Technologies

 Conventional end-of-pipe wastewater treatment at pulp and paper mills typically comprise
 primary treatment followed by various secondary biological treatment. The application of
 these treatments is nearly universal across most segments of the industry.

 Primary treatment includes physical and chemical processes that achieve solids removal,
 equalization, neutralization,  and  color reduction.  Primary treatment is generally used in
 combination with secondary biological treatment. The most common types of secondary
 biological treatment at pulp and paper mills are activated sludge, aerated and non-aerated
 stabilization  basins.  In  these systems, bacteria convert  soluble organic material that
 contribute to BOD5 into settleable biological solids in the presence of oxygen; these solids
 are then removed by sedimentation (52).  Mills that  have mixed treatment have both
 activated sludge and basin systems.

 This section describes the physical, chemical, and biological treatment technologies used to
 treat  pulp and paper mill wastewater and the pertinent design and operating parameters of
 these technologies.  Table 8-4 shows the  number of mills, grouped  by discharge  status
 (direct, indirect, and non-discharging), that have each type of wastewater treatment.   In
 general, more direct-discharging mills have biological treatment and more indirect and non-
 discharging mills have primary treatment  only.  Basin systems  are more common than
 activated sludge systems at mills with biological treatment.

Table 8-5 summarizes the number of direct-discharging mills in each subcategory that have
each type of wastewater treatment.  For the purpose of this table, mills were grouped into
the subcategory that represented the largest percentage of their total annual production
Of direct-discharging mills, chemical pulping  and secondary fiber mills have secondary
biological treatment more  frequently than non-integrated mills.  At chemical pulping  mills,

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                                8.0 Pollution Prevention and Wastewater Treatment Technologies
Darticularly kraft mills, basins are twice as common as activated sludge systems Secondary
fiber deink mills use activated sludge more often, whereas non-deink mills use basins more
frequently. Most non-integrated mills have primary treatment only; at non-integrated mills
that also have secondary biological treatment, basins are used equally as often as activated
sludge. There are nine direct-discharging mills that have no treatment or less than complete
secondary treatment because of unique site-specific factors.

8.5.1   Primary Treatment:  Screening, Solids Removal, Equalization, and Neutralization

The technologies  discussed in this section are  generally, but not always, used prior to
biological treatment.  Some of these technologies may also constitute the major method ot
wastewater treatment at mills that do not need additional biological treatment in order to
meet current regulatory requirements.

Table 8-6  summarizes the number  and types  of solids removal,  equalization,  and
neutralization technologies currently used at pulp and paper mills.
 8.5.1.1
Coarse Solids Removal
       Screening

 Numerous types "of screens are used in the pulp and paper industry.  Such screens are
 generally grouped into two types: bar (coarse) and fine screens.  Bar screens are most often
 the first unit operation in the treatment sequence as coarse solids must be removed from
 wastewater streams to protect downstream treatment equipment, such as pumps and valves,
 from plugging. Mechanically cleaned bar screens are the most common coarse screen used;
 approximately 40 percent of nulls with wastewater treatment use this type. Bar screens have
 at least 1.5 cm spacings through which the wastewater passes, retaining solids such as wood
 chips, leaves, plastics, and rags.

 A few mills use fine screens and microstrainers with spacings smaller than 1.5 cm; however,
 fine screens, microstrainers, and pressure filters are more easily  clogged by wastes (52).
 Fine screens are often as expensive as comparable clarification units but more difficult to
 maintain (13).

        Grit  Removal

 Grit removal  protects  downstream  equipment from  abrasion  and  damaging  deposit
 formation.   Therefore, grit  chambers are usually  located  after  screens  and before
 sedimentation clarifiers. Grit chambers remove mostly sand and other inorganic particles
 greater than 0.2 mm (52). Approximately 10 percent of mills with wastewater treatment
 operations perform grit removal.

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8.5.1.2
Sedimentation
Suspended solids from pulp and paper wastewater are removed primarily by sedimentation
(settling).  Sedimentation is desirable prior to biological treatment because it reduces the
load  on the  treatment system and prevents equipment wear  (52).  Most mills with
wastewater treatment systems use some type of sedimentation process.  Because activated
sludge systems are particularly sensitive to load fluctuations, more than 90 percent of mills
with activated sludge treatment have sedimentation equipment.  Sedimentation units are
also the major treatment operation at two-thirds of the mills that do not have biological
treatment systems.  Sedimentation equipment can include mechanical clarifiers and settling
ponds.  Chemically assisted flocculation is also used to improve sedimentation.

The sedimentation device used most in the pulp and  paper industry is  the mechanical
clarifier. This device is used approximately three times as often as all other sedimentation
devices at mills with biological treatment, but only equally as often as other sedimentation
devices at mills with no biological treatment.  Suspended solids are removed  by two types
of settling in the clarifier, discrete and floe.  Zone type settling might also occur in the lower
regions of the clarifier.

A rotating sludge scraper mounted on the floor of the clarifier rakes the sludge into a center
sump, where a sludge pump removes it to sludge handling facilities.  To facilitate sludge
removal, the bottom of the clarifier slopes towards the center at a 1:12 ratio (13). The table
below describes primary clarifier designs typically used at pulp and paper mills.
                           Typical Primary Clarifier Design
  Construction Material
  Construction Geometry
  Depth
  Detention Time
  Overflow Rate
                              Concrete(a)
                              Circular(a)
                              3-4.5 m(a)
                              2-10 hours(a)
                              2.5-15 m3/d/m2(b)
(a)Based on mill responses to the 1990 questionnaire.
(b)Based on values obtained from literature (13).

Mills with no subsequent biological treatment reported slightly longer detention times than
mills with biological treatment.

Mechanical clarifiers  can remove as  much as  80-90 percent  of suspended solids
(approximately 95-100 percent of settleable solids), producing a clarified effluent containing
35-60 mg/L suspended solids (13).   Mechanical clarifiers also remove some of the
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                                 8.0  Pollution Prevention and Wastewater Treatment Technologies
biodegradable portion of settleable solids present in pulp and paper wastewater.  The
amount of BOD5 removed  depends on the production operations at the mill.  At non-
integrated mills producing tissue and board, most BOD5 is associated with the suspended
solids and, therefore, BOD5 removal efficiencies at these mills may be as high as 90 percent.
The more soluble BOD5 generated at integrated mills results in less BOD5 removed, ranging
from 20-60 percent (13).

The clarified effluent produced by mechanical elarifiers either undergoes further biological
treatment or is discharged as the mill's final effluent. Because mechanical elarifiers produce
a more constant  solids loading, they are more often installed in front of  activated sludge
treatment.  The clarifier also generates a concentrated sludge stream that is easily handled
by conventional  sludge handling  equipment and can be disposed of by incineration or
landfilUng.  Section 8.5.4 discusses sludge handling operations in more detail.

Mechanical elarifiers may also be located after biological treatment systems, particularly
activated sludge  systems, where they remove additional  solids  generated by biological
treatment.   Section 8.5.2 discusses the design and types of these elarifiers used in the pulp
and paper industry.

Settling ponds, a less sophisticated and less expensive alternative to mechanical elarifiers,
also remove suspended solids  by  sedimentation. Settling ponds are usually unlined and
earthen, and have longer detention times than elarifiers, ranging from 0.5 to several days.
Settling ponds produce a less  constant solids loading than mechanical elarifiers, but will
usually provide  sufficient solids removal prior to aerated  stabilization basins and  other
lagoon types of biological treatment.
8.5.1.3
Flocculation
Despite the good settling properties of the suspended solids present in pulp and paper mill
wastewater, a mill may need to improve the settling properties of the particles in wastewater
with flocculation.  At pulp and paper mills, flocculation typically occurs in the mechanical
elarifiers; a few mills reported that they operate separate clari-flocculators. In either case,
flocculation  involves chemical addition and  gentle mechanical  or air mixing of  the
wastewater to increase the floe-type sedimentation that occurs  in the clarifier.   The
chemicals and mixing agglomerate particles to form heavier, settleable particles (usually
termed a "chemi-floc") that will settle faster. Less than 15 percent of mills with biological
treatment use flocculation before biological treatment, while one-half of all  mills without
biological treatment use flocculation.  Section 8.5.4 discusses flocculation in more detail.
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                                  8.0 Pollution Prevention and Wastewater Treatment Technologies
 8.5.1.4
 Flotation Clarification
 In flotation clarification units, a fine gas, usually air, is introduced into the wastewater where
 it adheres to particles. The buoyancy of the air causes the particles to rise to the surface
 of the water where they are collected by a skimming mechanism. A common modification
 of this process is dissolved air flotation (DAF), in which air under pressure is injected into
 the  wastewater.  As the pressure is released  in the flotation tank,  fine bubbles of
 supersaturated air form and attach to particles, carrying them  to the surface (52).  The
 advantage of flotation clarification over traditional sedimentation is that lighter particles that
 require very long detention times to settle are removed more quickly.  DAF units are more
 efficient than conventional flotation clarifiers, because more air is introduced into the
 wastewater, thereby removing more solids.  Less than 5 percent of all mills with wastewater
 treatment operations use flotation  clarification.  Responses to the 1990 questionnaire
 indicate that, of the ten DAF units reportedly operated as primary treatment at pulp and
 paper mills, eight are operated by mills with no biological treatment.  In fact, at mills with
 no biological treatment, approximately 30 percent use flotation clarifiers (most of these are
 DAF units) making them the second most common solids removal devices after mechanical
 clarifiers. The TSS concentrations in the final effluents at these mills range from 8.6 to 113,
 mg/L; the average concentration is 37.4  mg/L.
8.5.1.5
Equalization
Wastewater flow and load variations can affect the performance of subsequent treatment
operations, especially biological treatment.  Flow equalization and mixing dampens shock
loads, dilutes potentially inhibiting substances, and improves chemical feed control which
results in more efficient operation of downstream treatment (52).  According to mill
responses to the 1990 questionnaire, equalization is normally performed after sedimentation
and before biological treatment.  Detention times in equalization tanks and basins vary
greatly in the industry and are very dependent on the flow rate and variability at each mill
(52). Approximately 10 percent of all  mills with wastewater treatment have equalization.
More mills with activated sludge treatment have equalization than do mills with other types
of treatment.
8.5.1.6
Neutralization (pH Adjustment)
Another method for improving the performance of wastewater treatment  systems is
neutralization, or pH adjustment. Biological treatment relies on bacteria to degrade organic
substances dissolved in wastewater.  These bacteria function optimally in neutral  pH
environments of 6.5 to 7.5. Pulp and paper mill wastewater pH typically ranges from 5 to
9, and may therefore require some buffering to achieve optimal conditions, particularly in
activated sludge systems (13). At mills with no biological treatment, neutralization adjusts
the pH to levels acceptable for discharge to receiving streams.  According to mill responses

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                                 8.0 Pollution Prevention and Wastewater Treatment Technologies
to the 1990 questionnaire, one-third of mills with wastewater treatment use neutralization;
mills with activated sludge are more likely to use neutralization than other mills.

8.5.2  Activated Sludge Systems

In an activated sludge system, bacteria digest dissolved organic wastes in an aeration basin,
generating biological solids that are removed in a sedimentation clarifier. The solids are
removed from the bottom of the clarifier as sludge,  a fraction of which is recycled back to
the aeration basin to maintain the high level of mixed liquor suspended solids (MLSS)
Activated sludge treatment is a high-rate biological process where there is a relatively high
concentration of MLSS and mixed liquor volatile suspended solids (MLVSS) in the aeration;
basin; mills  report most MLSS levels in the range of 1,000-6,000 mg/L and MLVSS levels
in the range of 1,000-4,000 mg/L.  The main advantage of an activated sludge system over
other biological treatment processes in use in the industry is that it can treat up to 45 kg of
BODj/28 m3 of aerated volume, thus requiring relatively little space (13).  A disadvantage
of an activated sludge system is that maintenance of optimum'performance and final effluent
quality requires a consistently higher level  of attention to day-to-day operation  than
aerated/non-aerated basin treatment systems. The  presence of properly designed physical
components alone is not sufficient to achieve optimum performance. Therefore, O&M costs
for activated sludge systems  are typically higher than for aerated/non-aerated basin
treatment systems.

The four most common activated  sludge processes used by pulp  and paper mills are
conventional (plug-flow), extended aeration,  high-rate aeration, and pure-oxygen aeration
(UNOX®).   Mills with activated sludge processes that are not included in one  of these four
groups operate other modifications, such as  complete-mix, oxidation ditch, step aeration,
contact stabilization, and reaeration.   Approximately a third of all mills with biological
wastewater treatment and a quarter of all mills with any type of wastewater treatment have
activated sludge  treatment.   If  mills that  have  mixed treatment  are included,  these
percentages increase to about 40 percent and 35 percent, respectively. Table 8-7 shows the
number of  mills with activated sludge  and mixed systems that use each type of activated
 sludge process.

 The  activated sludge process used by each mill  was determined  from the  description
 provided by the mill in response to the 1990 questionnaire.  If the process  could not be
 identified from the description, a detention tune criteria was applied. Some mills were not
 included in Table 8-7 because they did not provide  process descriptions or detention times.
 Some mills also use more than one type of activated sludge process. Therefore, the total
 number of mills indicated in Table 8-7 does not correspond to the total number of mills with
 activated sludge and naked treatment mentioned previously..
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Almost one-third of mills with activated sludge or mixed treatment use the conventional
process. In a conventional activated sludge system, wastewater from the primary clarifier
and recycled activated sludge both enter the aeration tank at a single location. Mechanical
or diffused-air aerators supply the required oxygen and uniform mixing throughout the tank.
Microorganisms, in the presence of oxygen, oxidize dissolved organic matter (52). Food-to-i
microorganism (F/M) ratios, detention times, and MLSS levels for the conventional process
and other activated  sludge  processes  common to the  pulp and paper  industry are
summarized in the table below.
Activated! Sludge
Pr0ee$$
Conventional
Extended Aeration
High Rate Aeration
Pure Oxygen Aeration
Typical Detention
Times(a) (hr$)
4-8
>18
2-4
2-4
F/Sf Rafio${a)
0.2-0.4
0.05-0.15
0.4-1.5
0.25-1.0
MLSS Levei$ Relative
to Conventional
Process(a)
-
Lower
Higher
Higher
(a) Values for each parameter were obtained from literature (52).

Values for these parameters reported by the industry in response to the 1990 questionnaire
compare well to values cited in literature and are given below:
Activated Sludge Design Parameter
F/M Ratio
Detention Tune
MLSS Concentrations
Range of Values Reported by Mills
0.06-1.6
1-130 hours
1-6,000 mg/L
Almost as many mills with activated sludge or mixed treatment have extended aeration as
have conventional activated sludge. Extended aeration differs from conventional activated
sludge only in that it uses a lower organic loading and a longer detention time.  F/M ratios
in these systems are normally lower, and detention times are normally longer for the
conventional process (52).

Approximately 20 percent of the mills with activated sludge treatment operate a high-rate
modification. High-rate activated sludge combines high MLSS concentrations with high flow
rates.  The result is higher F/M ratios and relatively short hydraulic  detention times.
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Adequate mixing in the high-rate aeration tank is critical in order to maintain F/M ratios
(52).

Pure oxygen, or UNOX®, activated sludge systems use high-purity  oxygen instead of air.
UNOX® detention times are typically even shorter than those for high-rate activated sludge
systems. Oxygen is diffused into covered aeration tanks and recirculated; pH is adjusted and
recirculated oxygen is occasionally purged to avoid carbon dioxide accumulating at  toxic
levels in the effluent.  Approximately four times as much oxygen can be added in this
process than in conventional activated sludge systems.  As with high-rate aeration, the  F/M
ratios for this system are generally higher, and detention times are shorter. The advantage
of a UNOX® system is that it is less sensitive to shock loads than other types of activated
sludge systems (52). About 10 percent of all mills with activated sludge use this process; no
mills with mixed treatment use this process.

Most of the aeration tanks constructed at pulp and paper mills are concrete; a few are  lined
or earthen.  Mechanical or diffused aerators create the aerobic  environment in the  tank.
These aerators supply approximately  1 kg of oxygen/kg of BOD5 removed.  The aerators
supply oxygen to the bacteria while maintaining the mixing level required to achieve high
MLSS concentrations.  The table below shows the approximate  number of  mills that use
each type of aerator in their activated sludge aeration tanks based on responses to the 1990
questionnaire.
*£ype of Aerator
Mechanical Surface
Diffused Air.
Mechanical Submerged Turbine
Total(a)
Howler of Mills
31
28
8
67
 (a)The total number does not equal the number of mills that have activated sludge treatment as some mills did
   not report the type of aerator used.

 In order for biological systems to operate efficiently, the bacteria require sufficient amounts
 of nutrients, particularly nitrogen and phosphorus. Supplemental nitrogen and phosphorus
 are added at over 90 percent of all mills operating activated sludge systems.  The average
 dosage required is a ratio of 100:5:1 of BOD5:nitrogen:phosphorus (13).

 Because activated sludge systems do not handle shock loads efficiently, the installation of
 flow equalization, neutralization, and sedimentation units prior to the activated sludge unit
 is necessary.
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 As mentioned previously, sedimentation clarifiers are necessary to remove the biological
 solids generated in the aeration tanks.  All of the mills with activated sludge systems use
 mechanical clarifiers for solids removal following treatment. The typical design features of
 activated sludge clarifiers are similar to those for primary clarifiers (discussed in Section
 8.5.1.2) and are shown in the following table.
Topical Activated Sludge Clarifies Design
Construction Material
Construction Geometry
Depth
Detention Time
Overflow Rate
Concrete
Circular
3-4.5 m
3-10 hours
5-30 m3/day/m2
(average = 17.3)
 The average surface overflow rate in these clarifiers is slightly lower than the value of 24.4
 m /day/m2 reported in literature (13).  Chemicals are added to enhance flocculation in
 more than 15 percent of the activated sludge clarifiers. Section 8.5.4 describes the chemicals
 used for flocculation.

 Activated sludge systems are used by mills with a wide range of wastewater flows: 115 to
 182,000  m3/day.  Responses to  the 1990 questionnaire indicate that  activated sludge
 treatment  is used by nulls in every production subcategory.  Activated sludge systems
 achieve  BOD5 removal of 80 to greater than 90 percent (52).   The  BOD5 and  total
 suspended  solids (TSS) concentrations  achieved at  mills with  activated  sludge are
 summarized below:
                                        Range
                            Average
  BOD5 Concentration (mg/L)
3.40-200
                              33.7
  TSS Concentration (mg/L)
6.90-300
                              56.6
Approximately 13 percent of all mills with activated sludge achieve BOD5 concentrations
lower than 10 mg/L; approximately 7 percent achieve TSS concentrations lower than 10
mg/L.
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8.5.3  Aerated and Non-aerated Stabilization Basins

Aerated and non-aerated basins are characterized by longer detention times, lower F/M
ratios, and lower MLSS concentrations than are typical for activated sludge systems. The
concentration  of suspended solids in stabilization basins at pulp and paper mills is  low
enough that subsequent mechanical clarification is unnecessary.

Slightly more  than half of all basins operated at pulp and paper mills are aerated basins.
Mechanical surface aerators are used in three times as many basins  as all other types of
aerators combined, including diffused-air and mechanical submerged  turbine aerators.

Aerated basins  may be  configured in two ways.  In one configuration, all  the aeration
equipment is located near the wastewater Met to the basin, providing maximum oxygento
the bacteria  that degrade the  dissolved organic matter,  reducing  BOD5  levels.   The
remaining portion of the basin is not aerated, providing a quiescent area for the biological
solids generated in the aerated  portion to settle. The range of detention times in these
types of basins is approximately 1 to 18 days.

In the second configuration, the entire basin is aerated. The amount of aeration supplied
may be based on oxygen or oxygen and mixing requirements. In complete-mix conditions,
the contact between bacteria and the wastes they degrade is maximized.  However, the
aeration  capacity required to  maintain a complete mix provides more  oxygen than is
required  for BOD5 removal.  These types of aerated  basins are often followed by non-
aerated basins  that remove  the solids kept in suspension by mixing. If the  amount  of
aeration supplied is based on oxygen requirements (not mixing), there will be some settling
of biological solids in the basin. However, because there is no quiescent zone to allow for
 complete sedimentation, the detention times in these basins are slightly shorter than for the
first configuration, ranging from 1 to 12 days.

 Non-aerated basins, or "polishing ponds," primarily serve to settle any biological solids that
 may have been generated in previous treatment operations. The basin may,  depending  on
 its size, also serve as a holding area, or "holding pond," from which the flow of final effluent
 into  a receiving stream can be controlled.   Because fluctuations in flow  and load are
 dampened in large holding ponds,  they function as  equalization units as well.  In general,
 most BOD5 removal that occurs in holding ponds is associated with the settling of suspended
 solids. However, active bacteria from previous treatment units may be carried over into
 ponds, where they continue to digest organics, removing some BOD5.  Because there are no
 aerators  to supply additional oxygen below the surface, there are zones of anaerobic
 digestion.  As a result, non-aerated basins are sometimes referred to as facultative basins
 because  biological processes occur with and without the presence of oxygen.  In order to
 sufficiently remove suspended solids, the detention times in non-aerated basins are from 1
 to 27 days, longer than  those required in aerated basins.

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 Most basins, of any type, are earthen, while more than 20 percent are lined, usually with
 compacted clay.  Basins are constructed based on the topography of the available land, so
 there is no preferred geometry.  Basin depths are between 10 and 25 feet and may depend
 on the type of aeration, if any, used. At approximately 20 percent of all basins used in the
 industry, nutrients  are  added to facilitate biological processes,  but  typically in smaller
 dosages than are added to activated sludge units (13).

 Like activated sludge units, basins are used by mills with a wide range of flows:  190 to over
 380,000 m3/day. The BOD5 and TSS concentrations achieved at mills with basins are given
 below:

BOD5 Concentration (mg/L)
TSS Concentration (mg/L)
Range
3.00-536
2.00-400
Average
60.89
67.5
Approximately 7 percent of these mills achieve BOD5 concentrations lower than 10 mg/L.
In general, the BOD5 levels achieved at mills with basins are higher than those achieved by
activated sludge. However, the TSS concentrations achieved by basins and activated sludge
are more comparable; about 5 percent of these mills achieve TSS concentrations lower than
10 mg/L.  The  average TSS concentration reported by mills is comparable to literature
stating that solids concentrations in basins are typically less than 200 mg/L (13).

More than 25 pulp and paper mills operating wastewater treatment combine both activated
sludge and basin technologies. In most mixed treatment systems, activated sludge units
precede basins; however, other combinations do exist (one mill has parallel activated sludge
and basin systems).  Flows at these mills range from  1,900 to 290,000 m3/day. The BOD5
and TSS concentrations achieved at mills that have mixed treatment are shown below:
	 	 f 	
BOD5 Concentration (mg/L)
TSS Concentration (mg/L)
Range
3.20-100
2.30-150
Average
31.99
94.33
The BOD5 levels achieved by mixed treatment are slightly better than those achieved by
basins or activated sludge systems  alone.  A higher portion of these mills, 22 percent,
achieve BOD5 concentrations lower than 10 mg/L. TSS concentrations achieved by mixed
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                                 8.0 Pollution Prevention and Wastewater Treatment Technologies
systems are generally lower than those achieved by basins or activated sludge systems alone;
however, only one of these mills achieves a TSS concentration lower than 10 mg/L.

8.5.4   Sludge Handling Operations

Sludge handling and disposal operations may account for more than one-half of the costs
of operating a wastewater treatment system.  Wastewater treatment systems at pulp and
paper mills generate two types of solid waste, or sludge, that require further handling and
disposal: biological and primary. Biological sludge is generated by mills that use clarifiers
after biological treatment to remove  biological solids. Primary sludge is generated by mills
using clarifiers prior to biological  treatment or  at mills  with no biological treatment.
Primary sludge is usually generated in greater quantities than biological sludge (13).

The dewaterability. of sludge varies  greatly and depends on the type of pulp and paper
produced at the mill.  Dewaterability is important because it  determines  the amount of
waste  to be handled by other sludge operations; the more dewaterable the sludge, the
smaller the volume of waste to be handled and the lower the operating and disposal costs.
Primary sludges are easier to dewater than biological sludge because of their higher fiber
and lower ash content (13).

More  than 90 percent of mills that  treat biological sludge have activated sludge systems.
Only a few basin mills  have clarifiers that follow then:  basin systems; consequently,
approximately 90 percent of basin mills that have sludge handling  facilities treat primary
sludge rather than biological sludge.  Mills that operate trickling filters, flotation clarifiers,
and DAF units also generate  sludges that require dewatering  and disposal. According to
responses to the 1990 questionnaire, the solids content of primary sludge ranges from 1 to
6 percent and the solids content  of the various biological  sludges, regardless of type,.is
lower, ranging from 0.3 to 2.2 percent.

Table 8-8 summarizes the number  of mills that have sludge  handling  operations.  The
specific types of sludge handling operations commonly used in the industry are described in
detail below.

The sequence of sludge operations  typically begins with a preliminary operation such as
sludge grinding, blending, or storage. Sludge is ground primarily to eliminate large material
that could clog downstream equipment. Particularly difficult-to-dewater biological sludge
may be blended with primary sludge to improve its dewaterability if neither type of sludge
is used individually as a by-product or in another application.  Mills may store sludge to
dampen fluctuations in sludge generation, providing a constant feed to subsequent sludge
operations.  Sludge is stored  in tanks,  basins, or ponds and lagoons.  Blending may also!
occur in storage areas as well (52,13). Fewer than 10 percent of mills with sludge handling
operations blend or grind sludge and approximately 15 percent store sludge.

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 Preliminary sludge  operations are often followed by a preconditioning step.  The most
 common preconditioning operations are sludge thickening and chemical conditioning.

 Sludge is thickened primarily by gravity and flotation clarifiers.  About one-fourth of all
 mills that have sludge handling facilities perform sludge thickening. The increased solids
 content of sludge due to thickening allows more efficient operation of dewatering equipment
 that usually requires higher feed concentrations than found in unthickened sludge. The
 gravity and flotation clarifiers used for sludge thickening are similar in function and design
 to sedimentation clarifiers and DAF units described in Section 8.5.1 (13).   Flotation
 thickeners achieve a higher solids content than gravity thickeners because they can generally
 accept a higher solids loading rate (52).  The solids content of primary and biological
 sludges after flotation thickening are approximately 4 and up to 10 percent, respectively (13).

 Chemical conditioning of sludge is  also  performed prior to dewatering  to improve the
 dewaterability of  the sludge. Conditioners  facilitate the coagulation and  flocculation of
 sludge particles, releasing absorbed water;  this results in a  15 to 30 percent increase in
 sludge solids content (52). The chemicals most commonly used for conditioning by pulp and
 paper mills are ferric chloride, lime, and polymer. These chemicals may be used singly or
 in conjunction. The more difficult-to-dewater sludges require larger dosages of conditioner;
 biological sludge typically requires a larger dose of conditioner than primary sludge and is
 therefore more costly to treat (13).  Like sludge thickening, slightly more than one-fourth
 of mills with sludge operations condition sludge before dewatering; about 15 percent of
 these mills have both thickening and conditioning operations.

 Preconditioning of sludge is followed by dewatering, the major sludge operation. The most
 common dewatering equipment used in the pulp and paper industry includes belt filter
 presses, screw presses, vacuum filters, coil filters, and V-presses. Because pulp and paper
 sludge  is amenable  to  mechanical dewatering, the  types  of equipment listed above
 accomplish dewatering by physical means such  as squeezing and vacuum withdrawal (52).

 The most popular dewatering device is the belt filter press.  Preconditioned (thickened or
 chemically conditioned) sludge is fed to a gravity drainage section where much of the free
water is removed by gravity.  The sludge is then fed to a low-pressure section where it is
squeezed between two porous  cloth belts.  Some presses also have a  subsequent high-
pressure section where the sludge passes through a series of rollers.  The  squeezing and
shearing forces in the low- and high-pressure sections release more absorbed water from the
sludge. The dewatered sludge cake is scraped from the belts by blades. Belt filter presses
are relatively inexpensive to operate as they are energy-efficient and require little operator
attention (52).  Their one major drawback is that the belt cloth has a short  useful life and
often requires replacement.  The sludge cake solids content is 20 to 50 percent for primary
sludge and 10 to 20  percent for biological sludge (13).  Almost one-half of all mills with
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                                 8.0 Pollution Prevention and Wastewater Treatment Technologies
sludge handling faculties operate belt filter presses; one-fourth of the belt filter presses
operated at mills are preceded by a thickening or conditioning step.

Screw presses are starting to  replace belt filter presses as the dewatering technology  of
choice in the pulp and paper industry.  Screw presses achieve a sludge cake solids content
of 50 to 55 percent without preconditioning (13). Chemical conditioning is not necessary
prior to dewatering by screw presses because it has little impact upon the  sludge cake
consistency; fewer than 10 percent of mills that have screw presses perform  chemical
conditioning. About one-fifth  of mills with sludge handling operations have screw presses.

Another dewatering device common to the pulp and paper industry is the vacuum filter
Vacuum filter  systems consist of a horizontal cylinder partially submerged in a tank ot
sludge A layer of porous filter media of fabric or tightly wound coils covers the outer
surface of the cylinder. Fabric is used almost three times more frequently than coils.  The
cylinder rotates at a rate  of  approximately 1 to 2 rpm.  As the cylinder surface passes
through the sludge tank, a layer of sludge adheres to the cylinder.  A vacuum is then applied
to the interior  of the cylinder along a portion of the circumference just beyond the sludge
tank, withdrawing water from the sludge layer. The dewatered sludge cake layer then passes
by a blade that scrapes the sludge cake off the fabric (52).  The solids content of sludge
cake from vacuum filters ranges from 20 to 30 percent.  Vacuum filters are as preva ent as
screw presses at pulp and paper mills. About 20 percent of all vacuum filters are followed
by a V-press which increases  the solids to 35 to 40 percent (13).

V-presses, or mechanical presses, are used by mills primarily to further dewater vacuum
filter sludge cake. They can  dewater sludge cakes already containing 30 percent solids to
produce  cakes with  up to 45 percent solids content; cakes of this consistency can be
 incinerated (13).  Fewer than 5 percent of mills that handle sludge have V-presses and only
 two mills operate a V-press independent of a vacuum filter.

 Between 10 and  15 percent of nulls with sludge operations use some type of sludge pond
 or lagoon  Sludge lagoons serve a variety of purposes, such as equalization, stabilization,
 and storage.  Lagoons are not often used as the primary method of  dewatering. They are
 usually sites of sludge accumulation prior to dewatering where equalization and stabilization
 can occur or they are storage sites for dewatered sludge prior to disposal.

 Other sludge handling operations that are used in the pulp and paper industry, but by only
 a few mills, include aerobic digestion, anaerobic digestion, centrifuges, drying beds, dryers,
 and plate-and-frame filter presses.

 The pulp and paper industry disposes of dewatered sludge by several methods, including
 landfilling, surface impoundment, incineration, and land application.  Table 8-9 presents the
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                                  8.0 Pollution Prevention and Wastewater Treatment Technologies
 number of mills using various disposal methods for each type of sludge (primary, biological,
 and combined).

 Landfilling is by far the most prevalent method of sludge disposal used by more than one-
 half of all mills that dispose of sludge.  Because primary sludge is generated in greater
 amounts than biological sludge,  more primary sludge is landfilled than biological  or
 combined sludge. Landfills may be company-owned, municipal,  or commercial; however,
 more than three times as many mills use company-owned landfills than either municipal or
 commercial landfills. Approximately 20 percent of mills that dispose of sludge send their
 sludge to surface impoundments.

 Incineration is the next most common method of sludge disposal at pulp and paper mills.
 Sludge is generally incinerated in one of three places: a specialized sludge incinerator, the
 bark boiler, or a power boiler that also burns fossil fuels (13). Combined sludge is more
 often incinerated than either primary or biological sludge.  About 15 percent of mills that
 dispose of sludge do so by incineration.

 Land application of sludge is another method of sludge disposal.  Pulp and paper sludge is
 classified as a soil  amendment rather than a fertilizer because  it does not  meet the
 elemental requirements for fertilizers; it is a particularly good amendment for sandy soils.
 However, restrictions and guidelines governing the land spreading of solid wastes may limit
 its  use  (13).   Between 10 and 15 percent of mills disposing  of sludge perform land
 application. Primary, biological, and combined sludges are applied to land equally as often.

 Other methods of sludge disposal used by pulp and paper mills include composting, sale of
 sludge as by-products, and recycling sludge back to mill processes. Each  of these methods
 is used by less than  10 percent of mills  requiring sludge disposal.

 8.5.5  Chemical Addition

 In the pulp and paper industry, the primary purpose for most chemical addition is to assist
 sedimentation clarification by enhancing flocculation in the clarifier. More than 25 percent
 of all mills with wastewater treatment use some type of chemically assisted clarification,
 whether  it precedes or follows biological treatment or is the only major  method  of
 treatment.  Certain chemicals,  called  coagulants,  destabilize the colloidal material in
wastewater by reducing the electrostatic repulsive forces between colloids or, more typically,
by  forming positively  charged  hydrous  oxides  that  absorb  to the colloidal surface.
Destabilized particles more easily coalesce to form heavier, more settleable particles called
floes.  Flocculation is the actual transport of destabilized particles to  make contact with
other particles in order to form floes.  The floes containing the original material to be
removed are  therefore settled out more efficiently (53).
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The coagulants most commonly used in the pulp and paper industry, in order of decreasing
usage, are:

      •      Polymer (polyelectrolytes);

      •      Aluminum sulfate, or alum (Al^SO^g);

      •      Calcium hydroxide, or lime (Ca(OH)2)

      •      Ferric sulfate and ferrous sulfate, or iron salts (Fe2(SO4)3 and Fe(SO4)); and

      •      Others (ferric chloride, calcium chloride).

Because there are so many varieties of polymer that may accomplish efficient flocculation,
it is used in mills twice as frequently as all other coagulants combined.  The selection and
dosage of a coagulant depends on the ease of floe formation and generated solids handling.

8.5.6 Other Treatment Technologies

This section describes biological treatment technologies currently used by less than three
percent of pulp and paper mills.  These technologies are used less frequently than activated
sludge and basin systems because they are generally more expensive and less efficient.

Two types of aerobic attached-growth biological treatment systems are used in the industry:
trickling filters and rotating biological  contactors.

In a trickling filter system, wastewater trickles through a bed of permeable media to which
microorganisms are attached. The microorganisms degrade the dissolved organic matter
into biological solids.   The treated wastewater passes through a sedimentation  clarifier
where biological solids  are removed (52).  Four mills reported that they operate trickling
filter systems in conjunction with mechanical clarifiers for sedimentation.  None of  the four
mills chemically or mechanically pulp wood; two mills are secondary fiber non-deink mills
and two manufacture their products from purchased pulp. The average effluent flow rate
and BODj and TSS concentrations achieved at these mills are approximately 21,200 m /day,
29.2 mg/L, and 38.4 mg/L, respectively.  One of the non-deink mills achieves BOD5 and
TSS  concentrations as low as 8.50, mg/L and 6.0 mg/L.  However, trickling filter systems
generally have very low BOD5 removal efficiencies for pulp and paper wastes, approximately
50 percent. Even the development of plastic media could not sufficiently solve this problem.
Therefore, trickling filters will probably not ever be a preferred biological treatment
 alternative (13).
                                         8-50

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                                  8.0 Pollution Prevention and Wastewater Treatment Technologies
  A  rotating biological contactor  (RBC) is a series of closely packed circular disks of
  polystyrene or polyvinyl chloride that are partially submerged in wastewater and slowly'
  rotated  As biological growth attaches to the surface of the RBC, a layer of slime forms
  Ihe disks  rotate between contacting the dissolved organic matter in the wastewater and
  adsorbing oxygen from the atmosphere.  The shearing forces of rotation remove the excess
  biological solids, which remain in suspension.  The solids are removed in a sedimentation
  clarifier (52).   RBCs can achieve BOD5 and TSS concentrations of 20 mg/L each (13)
  which is sufficient treatment at most pulp and paper mills.  However, this system is more
  expensive than the other types of biological treatment common in the industry   Only one
  mill, which produces fine and lightweight papers from purchased pulp, operates an RBC as
  its major method of wastewater treatment. This mill achieves BOD5 and TSS concentrations
  ot 20.6 and 23.6 mg/L, respectively.

  Filtration processes used to treat pulp and paper wastewater typically are granular-medium
  Miration rather than membrane  filtration.   Filtration usually follows  clarification,  and
  removes additional suspended solids from wastewater. As wastewater passes through a bed
  of granular medium or media, such  as  sand,  anthracite, coal, garnet, ilmenite,  and
  diatomaceous earth, solids are removed via straining and sedimentation.  Media, grain size
 filter type  and bed depth can be varied to achieve the desired results (52,54)   At  two
 secondary fiber deink mills, continuous sand filters are the last polishing step  in  the
 treatment sequence.  One mill operates an activated sludge system and achieves effluent
     t*n< i -r   concfntrations of 6.7 and 6.9  mg/L, respectively; the second mill has an
 aerated stabilization basin and achieves effluent BOD5 and TSS concentrations of 20.3 and
 16.0 mg/L,  respectively.   Filtration technologies are generally very expensive to  operate
 especially at rmUs where effluent flows can be  as high as 190,000 m'/day. Both mills have
 relatively low effluent flows (less than 11,000 m3/day) which helps miinmize their operating


 Other minor treatment technologies used by a few mills include anaerobic digestion, land
 filtration, comminution, oil skimming, and lamella separators.

 8.5.7  Color Reduction Technologies
    h                  P^P?r ^ wastewaters ^ primarily the result of chemical pulping
and bleaching processes.  Color has potentially harmful effects on plant and aquatic life as
weU as downstream _ wastewater treatment operations.  The biological treatment systems
g±ly T d, by. ™ES adueve  ^ P°or color «™oval efficiencies,  at best, 30 percent
Because  biological  treatment  cannot  achieve  acceptable  color  removal,  several
physicochemical processes have been developed. These color removal technologies include^
                                       8-51

-------
                               8.0 Pollution Prevention and Wastewater Treatment Technologies
     •     Lime Precipitation or Coagulation;

     •     Enzyme Pretreatment;

     •     Magnesium and Lime;

     •     A1»m Coagulation and Precipitation;

     •     Ozone Oxidation;

     •     Resin Separation;

     •      Ion Exchange;

      •      Aluminum Oxide;

      •      Wood Adsorption;

      •      Activated Carbon Adsorption;

      •     Membrane Separation; and
                                                               j
      •     MYCOR Processing.

All of the technologies listed above, with the exception of activated carbon adsorption
reduce color  by 90 percent or more (activated carbon achieves removals of 70 to  85
nercent)  BOD5 and COD are also reduced by each technology. However, BODs and COD
removal is less expensive using biological treatment. Color removal technologies are not
widely used primarily due to their relatively high operating costs (13).

End-of-pipe treatment technologies are not the only methods available to reduce color.  In-
plant process changes, such as oxygen  delignification, can  also  reduce  color  in mill
wastewater   Replacing conventional chlorine bleaching with oxygen,  chlorine dioxide
hypochlorite, peroxide, or ozone bleaching would also reduce color loads. Environmental
pressures to  reduce the use of chlorine bleaching make oxygen  and ozone bleaching
particularly promising (13).

8.5.8 Ultrafiltration of Bleach Plant Filtrates

Membrane filtration processes, such as ultrafiltration (UF), were initially applied to pulp
and paper mill effluents for color removal. However, these systems were not implemented
because of high operating costs due to membrane replacement, energy requirements, and

                                        8-52

-------
                                 8.0  Pollution Prevention and Wastewater Treatment Technologies
 large capital investments. TWO events within the past 15 years made UF a viable treatment
 option for removal of high molecular weight chlorinated compounds that are not removed
 by conventional biological treatment. One was an increasing pressure on the industry to
 eliminate toxic organics, such as dioxin, from mill effluents; the second was the development
 of more chemically and thermally resistant membranes, such as polysulphone and cellulose
 acetate, that operated well in conditions similar to those found in alkaline stage filtrates.
 Early studies of UF indicated that there was high rejection of chlorinated lignins and resin
 acids and low rejection of low molecular weight chlorinated organic compounds (55).
 Because isomers  of dioxin and furan may attach to the high molecular weight chlorinated
 lignins, a  high rejection of dioxin  and furan compounds  by the membrane was  also
 anticipated (56).  Tests showed that polysulphone was particularly well-suited for application
 to alkaline stage effluents because it performed well over a range of pH and temperatures
 and at high pressure (55,56).

 The Agency's Office of Research and Development (ORD) conducted a bench-scale dioxin
 treatability study in 1991 to assess the performance of UF in treating raw alkaline stage
 filtrates.  The  first part  of the study focused on membrane selection and testing.  Two
 membrane materials, polysulphone and vinyl copolymer, were evaluated for their ability to
 remove chlorinated organic compounds.  In general, the polysulphone membrane achieved
 greater removal of chlorinated constituents than the vinyl copolymer. The test results also
 indicated that optimal performance was  achieved at a pH of  10 to 11.  Lower pH did not
 impact removal efficiencies, but did lower the flux rate across the  membrane. Subsequent
 clean water testing of the membrane indicated that flux rates increased with higher pressure
 (prior to fouling)  and temperature (56).

 The second part of the ORD study measured the removal efficiencies of various compounds
 in raw alkaline stage filtrates achieved by a UF system (using a polysulphone membrane).
 The tests were performed using a grab sample of alkaline stage filtrate from a bleached
 kraft pulp mill. Test results indicated that 2,3,7,8-TCDD and 2,3,7,8-TCDF were reduced
 to concentrations  lower than the method detection limit;  chlorinated phenolic compounds
 were essentially not removed; and TOC1, AOX, and COD were removed by 19, 25, and 40
 percent,  respectively.   During the  tests,  the removal  efficiencies  decreased  as  the
 concentration of the feed increased. Clean water testing of the membrane revealed that flux
 rates before and after the performance tests were the same.  This suggests that the alkaline
 stage  filtrate  had  a  negligible  short-term  impact, due  to fouling,  upon  membrane
performance (56).

The application of UF to bleach plant effluents focused on alkaline stage filtrates because
these had many high molecular weight compounds that are easily removed, had manageable
flows, and did not require pH and temperature adjustments (55).
                                       8-53

-------
                                8.0 Pollution Prevention and Wastewater Treatment Technologies
In a UF installation,  the  permeate from the UF unit is further treated by biological
treatment, and the concentrate is incinerated. However, incineration could pose a problem
because of the  chlorinated organics contained in the concentrate.   Commercial  UF
installations have achieved removals of 60 to 70 percent TOC1, 90 to 95 percent color, 80 to
85 percent AOX, and 70 to 80 percent COD in E-stage effluents. The cost of a UF system
applied to the alkaline stage filtrate is estimated at about $4 per ton of pulp. The successful
application of UF treatment to bleach plant effluents can ultimately reduce the amount ot
dioxin discharged in final effluents (55).

8.6    References

1      McCubbin, N., H. Edde, E. Barnes,  J. Folke,  E. Bergman, and D.  Owen.  Best
       Available Technology for the Ontario Pulp and Paper Industry.  ISBN 0-7729-9261-4.
       Ontario Ministry of the  Environment, Canada, February 1992.

2      Allen, L.H., R.M. Berry, B.L. Fleming, C.E. Luthe, and R.H. Voss. Evidence That
       Oil-Based Additives are Potential Indirect Source of the TCDD and TCDF Produced
       in Kraft Bleach Plants.  In: Proceedings for the Eight International Symposium on
       Chlorinated Dioxins and Related Compounds, Umea, Sweden, August 21-26, 1988.

3      Voss, R.H., C.E. Luthe, B.L. Fleming, R.M. Berry, and L.H. Allen. Some New
       Insights into the Origins of Dioxins Formed During Chemical Pulp Bleaching.  In:
       Proceedings for the 1988 CPPA Environment Conference, Vancouver, BC Canada,
       October 25-26, 1988.

4     Cully, T.G. and S.C. Cohen. Lowering DBF and DBD Levels in Defoamer Oil. In:
       Proceedings  of the TAPPI 1990 Pulping Conference, Toronto, Ontario, Canada,
       October  14-17, 1990. pp. 981-983.

 5     Twomey  L F New Oil-Free Brownstock Washer Defoamer Can Help Mills Reduce
       Dioxin Related Problems.  In: Proceedings of the TAPPI 1990 Pulping Conference,
       Toronto, Ontario, Canada, October 14-17, 1990. pp. 984-987.

 6.    Rempel,  W., D.C. Pype, and M.D. Ouchi.  Mill Trials of Substantial Substitution of
       Chloride Dioxide for Chlorine-Part ffl:  Medium Consistency. Unpublished.'

 7.    Hartler,  N.  Svensk Paperstidning 81(15):483, 1978.

 8     Macleod, M.  Extended  Delignification in  Kraft Mills Science, Technology, and
       Installations  Worldwide.   Presented  at the  1992  Conference  on Emerging
       Technologies in Non-Chlorine Bleaching, Hilton Head, South Carolina, March 2-5,
       1992.

                                        8-54

-------
                                 8.0 Pollution Prevention and Wastewater Treatment Technologies
 9.
 10.
 11.
 12.
 13.


 14.

 15.


 16.


 17.



18.


19.
 U.S. EPA, Office of Pollution Prevention and Toxics.   Pollution  Prevention
 Technologies for the Bleached Kraft Segment of the U.S. Pulp and Paper Industry.
 EPA/600/R-93/100, U.S.  Environmental Protection Agency,  Washington,  D.C
 August 1993.                                                               '

 European Environmental Research Group  (MFG) and O. Duoplan.   Chlorine
 Dioxide  in Pulp Bleaching --  Technical Aspects and  Environmental  Effects,
 Literature Study.  CEFIC, Sodium Chorate Sector  Group, Brussels, Belgium
 February 1993.                                                             '

 Grace, T.M., B. Leopold, E.W. Malcolm, and MJ. Kocurek, eds.  Pulp and Paper
 Manufacture: Volume 5 - Alkaline Pulping. Joint Textbook Committee of the Paper
 Industry, TAPPI, Technology Park, Atlanta, Georgia and CPPA, Montreal, Quebec
 Canada, 1989.

 U.S. EPA, Office  of Air  Quality  Planning and Standards.   Pulp,  Paper,  and
 Paperboard Industry - Background Information for Proposed Air Emission Standards
 (Manufacturing Processes at Kraft, Sulfite, Soda, and Semi-Chemical Mills), EPA
 453/R93-050a,  U.S. Environmental Protection Agency, Research Triangle Park,
 North Carolina, October 1993.

 Springer,  A.M.  Industrial Environmental Control-Pulp and Paper Industry, John
 Wiley & Sons, Inc., New York, New York, 1986.

 Personal communication  with Neil McCubbin, October 6, 1993.

 McCubbin, N. Technology Available to Compensate for Recovery Boiler Overloads.
 CPPA Environmental Conference, Thunder Bay, Ontario, October 26-28, 1993.

 Hyoty, P.A. and S.T. Ojala?  High  Solids Black Liquor Combustion.  TAPPI Journal
 January 1988.  pp. 108-111.

 Colodette, J.L., U.P. Singh, A.K. Ghosh, and R.P. Singh.  Ozone Bleaching Research
 Focuses on Reducing High  Cost,  Poor Selectivity. Pulp and Paper, 67(6): 139-147,
 June 1993.

 Henricson, K. New Generation Kraft Pulping and Bleaching Technology Paoeri ia
 Puu, 74(4), 1992.                                                      F   J

 Shackford, L.D.   Commercial Implementation of Ozone Bleaching Technology.
Presented at  the  1992 Conference on Emerging Technologies in Non-Chlorine
Bleaching, Hilton Head, South Carolina, March 2-5,  1992.
                                      8-55

-------
                                8.0 Pollution Prevention and Wastewater Treatment Technologies
20.
21.
22.
23.
24.
 25.
 26.
 27.
 28.
 29.
Hise, R.G., R. Streisel, and A.B. Bills. The Effect of Brown Stock Washing, Split
Addition of Chlorine and pH Control on the C-Stage Formation of AOX and
Chlorophenols  During  Bleaching.    In:    Proceedings.  of  the  TAPPI  1992
Environmental Conference, Richmond, Virginia, April 12-15. pp. 1135-1142.

Burns, O.B., H.L. Hintz, and S.H. Tabor. Split Addition Technology from Concept
to Reality.  Presentation by Westvaco.

Fredstrom, C., K. Idner, and C. Hastings. Current State-of-the-Art of E0, Ep and Epo
Technologies. Presented at the 1992 Conference on Emerging Technologies in Non-
Chlorine Bleaching, Hilton Head, South Carolina, March 2-5, 1992.

U.S. EPA,  Office of Water Regulations and Standards.  Summary of Technologies
for the Control and Reduction of Chlorinated Organics from the Bleached Chemical
Pulping  Subcategories of the  Pulp  and  Paper Industry.  U.S.  Environmental
Protection  Agency, Washington, D.C., April 27, 1990.

Results of'Field Measurements of Chloroform  Formation and Release From Pulp
Bleaching.  Technical Bulletin No. 558. National Council of the Paper Industry for
Air and Stream Improvement, Inc., December 1988.  p. 2.

Fredette, M.C. New C1O2 Generation Capacity. In: Proceedings of the TAPPI 1990
Bleach Plant Operations Short Course, Hilton Head, South Carolina, June 17-22,
1990.  pp.  159-168.

Axegard, P.  "Environmentally Friendly" Processes of the Future.  In:  Proceedings
of the 1989 TAPPI Bleach Plant Operations Seminar, Charleston, South Carolina,
March 5-10, 1989.

Luthe, C.E., P.E.  Wrist, and R.M. Berry.   An Evaluation of the Effectiveness  of
Dioxins Control Strategies on Organochlorine Effluent Discharges from the Canadian
Bleached Chemical Pulp Industry.  Pulp & Paper Canada, 93(9):40-49, 1992.

Kringstad, K.P., L. Johansson, M. Kolar, and F. de Sousa.  The Influence of Chlorine
Ratio and Oxygen Bleaching on the Formation of  PCDF's and PCDD's in Pulp
Bleaching.  TAPPI Journal, June 1989.
 Berry,  R.M., B.I. Fleming,  R.H. Voss, C.E. Luthe, and P.E. Wrist.
 Preventing the Formation of Dioxins During Chemical Pulp Bleaching.
 Paper Canada, 90(8):48, 1989.'
Toward
Pulp &
                                        8-56

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                                 8.0 Pollution Prevention and Wastewater Treatment Technologies
 30.



 31.


 32.



 33.



 34.



 35.



 36.



 37.



 38.



 39.



40.
 Hastings, C. and K. Idner.  Current State-of-the-Art of Eo, Ep and Eop Technologies.
 Presented at the  1992 Conference on Emerging Technologies hi Non-Chlorine
 Bleaching, Hilton  Head, South Carolina, March 2-5, 1992.

 O'Reardon, D. Review of Current Technology Vital to Bleach Plant Modernization
 Study.  Pulp & Paper, 66(4): 124-129, April 1992.

 Smook,  G.A.   Handbook  for Pulp  & Paper Technologists.   Joint Textbook
 Committee of the  Paper Industry, TAPPI, Technology Park, Atlanta, Georgia and
 CPPA, Montreal, Quebec, Canada, 1982.

 Crawford, R.J., M.N. Stryker, S.W. Jett, W.L. Carpenter,  R.P. Fisher, and A.K. Jain.
 Laboratory Studies of Chloroform Formation in Pulp Bleaching.  TAPPI Journal
 November 1987. pp. 123-128.

 Crawford, R.J., V.J. Dallons, A.K. Jain, and S.W. Jett.  Chloroform,Generation at
 Bleach Plants with High Chlorine Dioxide Substitution  or Oxygen  Delignification
 TAPPI Journal, 74(4): 159-163, April 1991.

 An Investigation of the Effect of Increased Hypochlorite Stage Temperature and pH
 on Chloroform Generation at a Bleach Plant.  Special Report No. 90-08. National
 Council of the Paper Industry for Air and Stream Improvement, Inc., August 1990.

 Status of NCASI Laboratory Investigations  of  Factors  Affecting  Chloroform
 Generation from Pulp Bleaching, as of September 1988.  Report.  National Council
 of the Paper  Industry for Air and Stream Improvement,  Inc., September 1988.

 Farrell, R.L.  Status of Enzyme Bleaching R&D and Mill Work. Presented at the
 1992  Conference on Emerging Technologies  in Non-Chlorine Bleaching, Hilton
 Head, South  Carolina, March 2-5, 1992.

 Anderson, R.  Peroxide Delignification and  Bleaching.  Presented at the 1992
 Conference on Emerging Technologies in Non-Chlorine Bleaching, Hilton  Head
 South Carolina, March 2-5, 1992.

 Basta, J., L. Andersson, W. Hermansson. Lignox and Complementary Combinations.
 Presented at the 1992  Conference  on Emerging  Technologies in Non-Chlorine
 Bleaching, Hilton Head, South Carolina, March 2-5, 1992.

Kukkonen, K. and I. Relama. Experiences and Conclusions with TCP Bleaching at
Metsa-Botnia. Presented at the 1993 Non-Chlorine Bleaching Conference, Hilton
Head, South Carolina, March 14-18,  1993.
                                       8-57

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                                8.0 Pollution Prevention and Wastewater Treatment Technologies
41.   Korhonen, H. and S. Hiljanen. EnoceU's New Pulp Mill Started Up. Paper! jaPuu,
      March 1993.

42.   Young, J. Louisiana-Pacific's Samoa Mill Establishes TCP Pulp Production. Pulp &
      Paper, 67(8):61-63, August 1993.

43.   Nutt, W.E., B.F. Griggs, S.W. Eachus, and M.A. Pikulin.  Developing an Ozone
      Bleaching Process. TAPPI Journal, 76(3):115-123, Ma,rch 1993.
                                                              j
44.   Young, J. Lenzing Mill Bringing Second Ozone Bleaching Line Onstream. Pulp &
      Paper, 66(9):93-95, September 1992.

45.   Lenzing  Aktiengesellschaft. Letter to Dan Bodien, U.S. Environmental Protection
      Agency,  May 10, 1993.

46.   Guss, D.B. arid D. Brown. Clarification and Recycling of Deinking Process Water,
      In: Proceedings of the TAPPI 1991 Environmental Conference, San Antonio, Texas,
      April 7-10, 1991.  pp. 179-183.

47.   Panchapakesan, B.   Closure of Mill White Water Systems Reduces Water Use,
      Conserves Energy. Pulp & Paper, 66(3):57-60, March 1992.

48.   Sullivan, T. Pope & Talbot Water Reuse Program Boosts Production, Cuts Steam
      Use. Pulp & Paper, 65(4):73-75, April 1991.

49.   Albany Engineered Systems.

50.   Wyvill, C,, J. Adams, and G. Valentine.  Mills Often Overlook Significant Water
      Recycling Opportunities. Pulp & Paper, April 1986.

51.   Nash-Clark and Vicario.

52.    Metcalf  & Eddy, Inc., revised by Tchobanoglous,  G. and F.L. Burton.  Wastewater
       Engineering-Treatment, Disposal, and Reuse, Third Edition, B.J. Clark and J.M.
       Morris,  eds.  McGraw Hill, Inc., New York, New York, 1991.

53.    U.S. EPA, Office of Water. Preliminary Data Summary for the Industrial Laundries
       Industry. U.S. Environmental Protection Agency, Washington, D.C., September 1989.

54.    U.S. EPA, Office of Water Regulations and Standards. Development Document for
       Effluent Limitations  Guidelines  New  Source  Performance  Standards  and
       Pretreatment Standards for the Pulp, Paper, and Paperboard and the Builders' Paper

                                       8-58

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                                 8.0 Pollution Prevention and Wastewater Treatment Technologies
55.


56.
and Board Mills Point Source Categories.  EPA-440/1-82-025, U.S. Environmental
Protection Agency, Washington, D.C., 1982.

Radian Corporation.   Literature  Search  for Pulp and Paper Dioxin Removal
Treatability.  EPA Contract No. 68-CO-0032, September 1991.

Radian Corporation.  Bench-Scale Dioxin Treatability Study for Pulp  and Paper
Wastewaters - Draft Report. Radian Corporation, Heradon, Virginia, July 1991.
                                       8-59

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                                         c "lter cycle: (A) Mctor
                            «,,£ILoutwart; (B) vacuum «"•
                            filtrate collectod; (C) clear filtrate obtained; (D)
                            vacuum off; (E) atmospheric port opens; (F) knock-
                            off shower peels mat; (G) wire washing starts; (H)
                            atmospheric  port closes; (I) thickened pulp dis-
                            charged.
                                        Figure 8-8


                              Schematic of a Disc  Saveall
Courtesy of G.A. Smook
Handbook for Pulp & Paper Technologists
Copyright 1982
                                            8-67

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                                       I
                                        
                                               
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                    Table 8-1
Full-Scale Installations of Ozone Bleaching Systems
Company
SCA, Ostrands
Fabriker
Sodra Skogsagarna
Sodra Skogsagarna
Stora Cell
MoDo
Metsa-Botnia
Wisaforest
(Kymmene)
Metsa Sellu
Union Camp Corp.
Lenzing AG
Lenzing AG
Ixwatfon
Timra
Monsteras
Morrum
Skogshall
Husum
Kaskinen
Pietersaari
Rauma
Franklin
Lenzing
Lenzing
Country
Sweden
Sweden
Sweden
Sweden
Sweden
Finland
Finland
Finland
U.S.
Austria
Austria
Start-up
1993
1992
1993/4
1993
1993
1993
1993
1995
1992
1991
1993
A»MT/d
300+
1,000
-600
100
1,000
1,450
1,000
1,000
900
100
400
Notes
Kraft
HW/SW
Kraft
Kraft
Kraft
SW Kraft
SW Kraft
HW Kraft
SW Kraft
SW Kraft
Diss. Sulfite
Diss. Sulfite
                       8-69

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                     Table 8-2
Information for Several TCF Papergrade Sulfite Mills
Mill
1
2
3
4
5
6
7
8
9
10
Pulping
Liquor Base
Ca
Na
Na
Mg
Mg
Mg
Mg
Mg
Mg
Mg
Furnish
SW/HW
SW/HW
SW
SW
SW
SW
SW
SW/HW
SW/HW
SW/HW
Kappa No.
10 - 40 SW
10-20HW
16
8-10
15
10-12
15
16-18
22
18 SW
15 HW
25
Products
Market pulp
Tissue
Market pulp: fluff
and tissue
Market pulp
Market pulp,
printing and
writing papers
Tissue
Printing, writing,
and coated papers
Market pulp:
printing, writing,
and tissue papers
Market pulp:
printing, writing,
and tissue papers
Printing and
writing papers
Bleaching
Sequence
EopP
P
E^P
QPsi
PPQ
PoPoPP
EopAp,,
OAQE0fAEf-
Eps
Eop
E^ and E^P
Brightness
(ISO)
70-90
84-85
85-90
85
85+
82-83
86-88
85-86
85
85
                        8-70

-------
                                     Table 8-3
              Properties of Several TCP Papergrade Sulfite Pulps
Mill Number
(from Table
8-2)
4(a)









6




7






•1

Parameter
Brightness
Kappa number
Drainability
Tensile index
Burst index
Tear index
Density
PH
Cleanliness
Extractives
Brightness
Breaking length
Bursting strength
Dirt count
Teargrowth work
Brightness
Breaking length
Dirt count
DCM pitch
Folding number
Tear strength
Tensile stretch


Units
(ISO)

SR
Nm/g
kPam2/g
mNm2/g
kg/dm2

mm2/dm2
%DKM
(ISO)
m
KPa
specks/m2
Nm/m
(ISO)
m
kg-'
%

mN
%


Old Sequence
76.0
23.0
23.2
95.2
6.0
6.7
821
9.7
3.1
0.70
89-90
7.0
353
570
1,030
89-90
6.85
< 1,900
<0.50
350
<455
<2.66


TCF Sequence
83.5
14.8
23.3
92.2
6.2
7.0
808
9.9
1.3
0.34
82-83
6.7
356
1,250
1,070
85-97
6.60
< 1,900
<0.30
350
<530
<2.72


Ret
5









6




7






(a)The comparison for this mill is from an old bleach line to a new line; both bleaching sequences were TCF.
                                       8-71

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                                        8-72

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                                                    8-75

-------
                                       Table 8-7

                  Types of Activated Sludge Processes In Place
                               at Pulp and Paper Mills
Proc*ss{»>
Conventional (5-18 hrs)
Extended Aeration,
(>18hrs)
High Rate Aeration
(<5 hrs)
Pure Oxygen Aeration
Other
Total(c)
Number of Activated
Sludge Mills
31
25
10
9
8
83
Number of JVBMJd
misi$
7
8
6
0
0
21
Total
38
33
16
9
8
104
(a)The process used by each mill was determined from descriptions provided by mills in response to the pulp
   and paper questionnaire. If no description was provided, detention time was used to identify the process.

(b)Mixed mills have both activated sludge and basin treatment.

(c)Some mills were not counted because they did not provide process descriptions or detention times and some
mills may use more than one process.
                                            8-76

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                                    Table 8-8

             Summary of Sludge Handling/Dewatering Operations
                       In Place at Pulp and Paper Mills
Sludge Operation
Number of Mills
Sludge Conditioning and Handling
Blending
Storage
Thickening ,
Chemical Conditioning
21
43
68
73
Sludge Dewatering
Belt Filter Press
Screw Press
Vacuum Filter (Fabric Media)
Vacuum Filter (Coil Media)
V-Press
Sludge Lagoon
Other
Total Number of Mills With Sludge Operations(a)
122
53
40
15
11
35
29
262
(a)The sum of the number of mills having each operation does not necessarily equal the total number of mills
  because most mills have more than one type of operation.
                                      8-77

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                                      Table 8-9
           Sludge Disposal Methods Used by Pulp and Paper Mills

Disposal Method
Landfill (Company-owned)
Landfill (Municipal)
Landfill (Commercial)
Surface Impoundment
Incineration
Land Application
Saleable By-product
Recycle to Process
Composting
lumber of Mills(a) '*"'*" '' ''
Primary
Sludge
63
15
23
28
8
10
4
11
2
Biological
Sludge
16
2
3
8
2
9
1
5
1
Combined
Sludge
48
13
8
9
24
9
1
3
2
TotaKW
132
37
37
56
43
38
10
21
12
(a)Includes only those mills that use each method to dispose of 50% or greater of each type of sludge.




(b)Includes all mills that use each method to dispose of any portion of any or an unknown type of sludge.
                                          8-78

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                                           9.0 Development of Control and Treatment Options
 9.0    DEVELOPMENT OF CONTROL AND TREATMENT OPTIONS

 9.1    Introduction

 This section describes the combinations of pulping and bleaching technologies, in-process
 water  conservation practices, and  end-of-pipe wastewater  treatment  that  the  Agency
 configured as technology options for consideration as bases for the following proposed
 regulations:

       BPT (Best practicable control technology currently available);
       BCT (Best conventional pollutant control technology);
       BAT (Best available technology economically achievable);
       NSPS (New source performance standards);
       PSES (Pfetreatment standards for existing sources); and
       PSNS (Pretreatment standards for new sources).

 These regulations establish quantitative limits on the discharge of pollutants from industrial
 point sources. The applicability of the various regulations the Agency is proposing for the
 Pulp, Paper, and Paperboard Point Source Category is summarized below:
_,
BPT
BCT
BAT
NSPS
PSES
PSNS
Direct
Discharge
X
X
X
X


Indirect
Discharge




X
X
Existing
Source
X
X
X

X

New
Source



X

X
Conventional
PollofcWfc*
X
X

X


Priority and
Noneonventional
Pollutants


X
X
X
X
All of these regulations are based upon the performance of specific technologies but do not
require the use of any specific technology. The regulations applicable to direct dischargers
are effluent limitations guidelines which are applied to individual facilities through National
Pollutant Discharge Elimination System (NPDES) permits issued by EPA or authorized
states under Section 402 of the Clean Water Act (CWA).  The regulations applicable to
indirect dischargers are standards, and are administered by local permitting authorities (i.e.,
the government entity controlling the Publicly Owned Treatment Works (POTW) to which
                                       9-1

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                                          9.0 Development of Control and Treatment Options
the industrial wastewater is discharged). The pretreatment standards are designed to control
pollutants that pass through or interfere with POTWs.

After the Agency developed technology options for each of the regulations that apply to
existing sources (BPT, BCT, BAT, and PSES), the Agency analyzed the impacts oft some of
the options for each regulation in combination with the technology bases developed for air
emissions standards.  The combinations  of air pollution  and  water pollution control
technologies were designed to evaluate the combination that would provide the most
pollution control at  the least cost.  To  analyze the  combinations of pollution control
technologies, the Agency used the mass of pollutants controlled (i.e., the mass of pollutants
no longer discharged or emitted) and the costs of the control technologies. These data were
used  to  evaluate the total environmental and economic impacts of the water and air
regulations.  Estimation of the mass of pollutants controlled by the proposed  water
regulations and costs of the proposed water regulations are discussed in Sections 10.0 and
11.0, respectively. How these estimates were combined with similar estimates of the effects
of the air regulations is discussed in Section 12.0 and in more detail in the Background
Information Document (BED) (1). Analysis of the environmental and economic impacts is
described in the economic impact analysis  and  the regulatory impact assessment (2,3).

92    BPT

Best practicable control technology currently available (BPT) effluent limitations guidelines
establish quantitative limits on the direct discharge of conventional pollutants from existing
industrial point sources. BPT effluent limitations guidelines axe based upon the average of
the best  existing performance, generally in terms of treated effluent discharged by facilities
of various sizes, ages, and unit processes within an industry or subcategory.

BPT effluent limitations guidelines are based upon the performance of specific technologies,
but do not require the use of any specific technology.  BPT effluent limitations guidelines
are applied to individual facilities through NPDES permits issued by  EPA or authorized
states under Section 402 of the CWA.   The  facility  then  chooses its own approach to
complying with its permit limitations.

In developing BPT, the Agency considers the total cost of application of the technology in
relation to the effluent reduction benefits to be achieved from the technologies; the size and
age   of  equipment  and facilities;  the   processes  employed;   and  non-water  quality
environmental impacts,  including energy requirements.

9.2.1  Approach to BPT Option Development

To develop the BPT effluent limitations guidelines  promulgated from 1974 to 1982, the
Agency first developed  equations that relate the final effluent biological oxygen demand

                                        9-2

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                                           9.0 Development of Control and Treatment Options
 (BOD5) and total suspended solids (TSS) concentrations to the raw waste BOD5 and TSS
 concentrations entering a biological treatment system. Next, long-term average BPT effluent
 concentrations were developed by applying these removal equations to raw waste loads
 characteristic of each subcategory. Finally, long-term average BOD5 and TSS production
 normalized final effluent mass loads were calculated by multiplying calculated final effluent
 concentrations by the effluent flow rates characteristic of each subcategory. This process
 can be summarized as follows:
       1.
       2.
       3.
Identification of the best practicable control technology and its performance
in terms of reduction in wastewater concentrations;

Calculation  of long-term average effluent  concentrations achievable by
applying the identified control technology;

Calculation of long-term average mass loads by multiplying the BPT effluent
concentrations by a "characteristic" production normalized effluent flow rate.
This approach reflected the state of the industry during the mid-to-late 1970s, when many
mills did not have biological wastewater treatment systems. For these proposed regulations,
the Agency used a different approach to develop BPT effluent limitations guidelines, an
approach reflecting the state of the industry in the late 1980s and early 1990s, when more
than 80 percent of the direct discharging mills had biological  (secondary) wastewater
treatment.

Secondary  treatment  involves a biological process to remove organic matter through
biochemical oxidation.  In the  pulp and paper industry, activated sludge systems  and
aerated/non-aerated basin systems are the most commonly used biological process.   As
needed, secondary treatment is preceded by pretreatment (e.g., equalization, neutralization,
cooling) and primary treatment for the  removal  of suspended solids.

Tertiary treatment is advanced treatment,  beyond  secondary,  to  remove particular
contaminants.  Common tertiary treatment operations are the removal of phosphorus by
alum precipitation and removal of toxic refractory organic compounds by activated carbon
adsorption.  Tertiary treatment is not common in the pulp and paper industry.

The Agency decided that secondary wastewater treatment represented the state of the
industry, from which BPT effluent limitations guidelines would be developed, because more
than 80 percent of direct discharging mills use secondary treatment while only 2 percent use
tertiary treatment. Common elements of secondary wastewater treatment, as practiced in
the pulp and paper industry, include (but are not limited to):
                                       9-3

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                                          9.0 Development of Control and Treatment Options
      •     Equalization;

      •     Precooling;

      •     Primary sedimentation;

      •     Nutrient addition;

      •     Aeration;

      •     Addition of flocculants to secondary clarifiers to improve settling;

      •     Multi-basin systems, some of which act as polishing ponds; and

      •     Mixed  or hybrid treatment systems  (activated sludge  and basin systems
            operated in series or parallel).

Some of the basin treatment systems in use in the industry cover large areas.  Many mills
are able to operate their treatment systems to meet stringent, water quality based discharge
limitations.  Other treatment systems were enlarged in an add-on manner, as the capacity
of the mill increased over time. The Agency considers all of these scenarios as typical of
industry wastewater treatment practice, and included all of them in characterizing pulp and
paper industry secondary wastewater treatment performance.

The proposed revised BPT effluent limitations guidelines were developed in seven steps:

       1.    Identification of mills representing the performance of secondary wastewater
            treatment in each subcategory;

       2.     Analysis of the performance (in terms of production normalized final effluent
             BOD5 load) of the representative mills to determine "the average of the best
             existing performance;"

       3.     Identification of combinations  of in-process flow reduction and end-of-pipe
             wastewater treatment used by the industry to achieve these performance
             levels;

       4.     Estimation of the cost of applying these identified technologies  at mills^that
             do not currently achieve "the average of the best existing performance;"

       5.     Estimation of the benefits of applying the identified technologies, in terms of
             the reduction in the mass of conventional pollutants discharged;

                                        9-4

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                                            9.0 Development of Control and Treatment Options
       6.     Comparison of the estimated costs and benefits; and

       7.     Review of non-water quality environmental impacts.

The remainder of Section 9.2 describes Items 1, 2, and 3 above: the identification of mills
representing secondary treatment performance, the determination of "the average of the best
existing  performance"  (i.e., BPT  Option  performance  levels),  and  identification  of
technologies used by the industry to achieve the BPT option performance levels.  A different
approach used  to develop Option  2 performance levels for the  Dissolving  Sulfite
Subcategory, and the reasons the Agency used this  approach, are also discussed in this
section.  The assessment of the options, in terms of pollutant reductions achieved, is
presented in Section 10.0. Section 11.0 presents estimated costs, while Section 12.0 presents
the non-water quality environmental impacts of the option selected to form the basis of the
proposed regulation.  The comparison of costs and benefits for BPT is presented in the
Record for the Rulemaking.

9.2.2  Identification of Mills Representing Secondary Wastewater Treatment Performance
       in Each Subcategory

BPT Imitations were based  upon production normalized BOD5 and TSS mass loadings in
final effluents from mills representative  of the  performance of secondary wastewater
treatment in each subcategory.  This group of mills is listed in Table 9-1. Identification of
these representative mills is  described below.

In selecting the mills to represent secondary wastewater treatment performance in each
subcategory,  the  Agency began with  the  list  of mills  that responded to the 1990
questionnaire and deleted mills from the list that were not considered representative  of
standard industry secondary treatment system design, operation, and performance for a
specific subcategory. Deleted mills included:

       •      Ineligible mills (27 mills);

       •      Closed mills (12 mills);

       •      Indirect or mixed discharge mills (212 mills);

       •      Mills not discharging wastewater (37 mills);

       •      Mills that provided less than 12 months of effluent data (27 mills);

       •      Mills known to be the subject of EPA enforcement actions due to wastewater
            discharge practices (2 mills);

                                        9-5

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                                           9.0 Development of Control and Treatment Options
      •      Mills that do not operate secondary treatment (31 mills);

      •      Mills with tertiary treatment (2 mills);

      •      Mills with unique operations not representative of a specific subcategory (10
             mills); and

      •      "Multiple" subcategory mills (85 mills).

Some mills received a 1990 questionnaire but were determined to be "ineligible" and were
not required to complete and return the questionnaire because:  (1) mill operations were
not within the scope of the Pulp, Paper, and Paperboard Point Source Category (e.g., mill
products are derived from only synthetic materials such as glass or fiberglass) or (2) the mill
was not in operation in 1989 (e.g., mills under construction).

Closed mills included mills that received a 1990 questionnaire but were not required to
complete and return the questionnaire because they closed operations subsequent to 1989
and employees were no longer available to provide required information.

Mills that discharge wastewater indirectly or have a "mixed" discharge status (i.e., mills that
discharge wastewater both directly and indirectly and mills that discharge wastewater directly
and also dispose of wastewater via land irrigation and other methods) were not included in
developing BPT effluent limitations guidelines. These nulls were excluded because they
generally are not representative of treatment performance achieved by mills that discharge
wastewater  directly (i.e., nearly all indirectly  discharging mills  lack on-site secondary
treatment).

Mills not discharging wastewater include mills that:  (1) dispose of all wastewater on site
(e.g., operate  surface  impoundments  or land  application)  or (2) completely  recycle
wastewater. Complete recycle of wastewater is discussed in Section 6.2.6. These mills were
not included in  developing BPT  limitations  because they  do  not represent  the BPT
technology basis of secondary treatment. Section 9.2.3 describes the BPT technology basis
in detail. Although the Agency did not consider it a basis for BPT, complete recycle of
wastewater  is the technology basis of NSPS for one segment of the Secondary Fiber Non-
Deink Subcategory, as discussed in Section 9.5.

Mills that provided less than 12 months of effluent data included those mills that did  not
monitor their final effluent, mills that did not operate for  significant portions of 1989, and
mills that discharge wastewater intermittently. These mills were not included in developing
BPT limitations  because their  data were unavailable, unrepresentative, or difficult to
interpret. As noted above,  an adequate number of mills that monitored final effluent and
                                         9-6

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                                           9.0  Development of Control and Treatment Options
discharged wastewater continuously in 1989 were available within each subcategory for
development of the proposed BPT effluent limitations guidelines.

Mills known to be the subject of EPA enforcement actions resulting from their wastewater
discharge practices were  not  considered representative of standard industry secondary,
wastewater treatment system design, operation, and performance.

Similarly, mills that do not operate secondary treatment or that operate tertiary treatment
were not identified as representative of secondary treatment performance.

Mills with unique operations not representative of a specific subcategory include mills that
share wastewater treatment with  another facility not included in the scope  of this
rulemaking, such as chemical  or sugar plants, that contribute significant flow and BOD5
and/or TSS pollutant loadings. Also included in this group are mills that did not report
other necessary information such as. 1989 final production.

Ideally,  only mills with all of  their final off-machine production in a single  subcategory
would be used to represent the performance of secondary wastewater treatment for that
subcategory. After application of the selection parameters discussed above, the majority of
the  subcategories included few or no mills  with all  of their  production  in a single
subcategory, reflecting the actual organization of the U.S. pulp and paper industry (a typical
mill has operations in more than one subcategory).  To account for this situation, while at
the same time reflecting the characteristics of the principal subcategory at a mill, the Agency
chose to use mills with a large percentage of their final production in a single  subcategory
to represent the subcategory.   Based upon a review of direct discharging mills with
secondary treatment, the  percentage of final production in each subcategory,  and 'the
anticipated proportional BOD5 load contributed by each subcategory, the Agency selected
a final productions cut-off of  85  percent within a single subcategory for a mill to be
considered representative of that subcategory.  Except as noted below, mills with less than
85 percent of their final production within a single subcategory were generally considered
to be "multiple subcategory mills" and were not selected to represent secondary treatment
performance for a subcategory. This final production cut-off was also applied to groups of
mills that combine treatment of their wastewater. The percent of final production in each
subcategory for the group of mills was calculated using a production-weighted average of
each individual mill's percentages of final production in each subcategory.

Because most mills in the Papergrade Sulfite, Semi-Chemical, Mechanical Pulp, and Non-
Wood Chemical Pulp Subcategories do not have more than 85 percent of their production
in one subcategory, the Agency selected  different  criteria for these subcategories, as
described below.
                                        9-7

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                                          9.0 Development of Control and Treatment Options.
93,2.1
Papergrade Sulfite Subcategory
In responses to the 1990 questionnaire, 12 mills reported production in the Papergrade
Sulfite Subcategory in  1989.  Of these 12 mills,  two were not selected to represent the
performance of secondary treatment in the Papergrade Sulfite Subcategory because one
discharges wastewater both directly and indirectly, and one operates tertiary wastewater
treatment.  Information concerning the remaining 10 mills is summarized in Table 9-2. As
shown in the table, production in the Papergrade Sulfite Subcategory comprises an average
of 56 percent of final production at these mills and ranged from 37 percent to 96 percent
of final production. For most mills in this Subcategory, the remaining final production was
in the Purchased Pulp Subcategories as well as a combination of several other subcategories.

Two mills (observations 9 and 10 on Table 9-2) were eliminated from further consideration
because they are not considered to be representative of the Papergrade Sulfite Subcategory.
One mill manufactures bleached papergrade kraft pulp, a pulping process that contributes
significant pollutant load to wastewater treatment.  The second mill shares its wastewater
treatment system with another mill that manufactures bleached papergrade kraft pulp.,

After deleting the two mills discussed above, as shown in Table 9-2, the percentage of final
production in the Papergrade Sulfite Subcategory is distributed within a range of 37 percent
to 96 percent with the majority of the remaining final production in the purchased pulp
subcategories.  The Agency found relatively poor correlation between percent of final
production in the Papergrade Sulfite Subcategory and the-production normalized BOD5 load
in final effluent (correlation coefficient 0.58).  Because this Subcategory is characterized by
mills with significant quantities of final production in the Papergrade Sulfite Subcategory
and the two purchased pulp subcategories, the Agency selected mills with production in
these three subcategories to represent the performance of secondary  treatment in the
Papergrade Sulfite Subcategory.   The Agency determined  that these mills adequately
represent the Papergrade Sulfite Subcategory because the majority of the pollutant loading
to wastewater treatment is generated by the papergrade sulfite pulping operations.
93,3.3,
Semi-Chemical Subcategory
In responses to the 1990 questionnaire, 21 mills reported production in the Semi-Chemical
Subcategory in 1989. Of these 21 mills, four were not selected to represent the performance
of  secondary treatment in the Semi-Chemical Subcategory because one  discharges
wastewater indirectly and three discharge wastewater directly without secondary treatment.
Information concerning the remaining 17 mills is summarized in Table 9-3. As shown in the
table, production in the Semi-Chemical Subcategory comprised an average of 55 percent of
final production at these mills and ranged from 10 percent to 78 percent of final production.
The remaining final production was  in the Secondary Fiber Non-Deink Subcategory, the
purchased pulp subcategories,  and/or the Bleached Papergrade Kraft Subcategory.

                                        9-8

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                                           9.0 Development of Control and Treatment Options
 Two mills (observations 16 and 17 on Table 9-3) were eliminated from further consideration
 because they are not considered to be representative of the Semi-Chemical Subcategory.
 These mills manufacture bleached papergrade kraft pulp with cross-recovery systems and
 they are not representative of stand-alone semi-chemical mills.

 After deleting the two mills discussed above, the percentage of final production in the Semi-
 Chemical Subcategory is distributed within a range of 26 percent to 78 percent with the
 remaining final production in the Secondary Fiber Non-deink and/or the purchased pulp
 subcategories. The Agency found little correlation between percent of final production in
 the Semi-Chemical Subcategory and the production normalized BOD5 load in final effluent
 (correlation coefficient 0.14). .Because  this Subcategory  is characterized  by  mills  with
 significant quantities of final  production in the Semi-Chemical and Secondary Fiber Non-
 Deink and/or the two purchased pulp subcategories,  the Agency selected  mills  with
 production in these four subcategories to represent the performance of secondary treatment
 in the Semi-Chemical Subcategory. The Agency determined that these mills adequately
 represent the Semi-Chemical Subcategory  because most of the pollutant  loading  to
 wastewater treatment is generated  by the semi-chemical pulping operations at these mills.
9.2.2.3
Mechanical Pulp Subcategory
In responses to the 1990 questionnaire, 57 mills reported production in the Mechanical Pulp
Subcategory in 1989. Of these 57 mills, 24 were not selected to represent the performance
of secondary  treatment  in the Mechanical  Pulp Subcategory because  nine discharge
wastewater indirectly, seven do not discharge any process wastewater, five provided less than
12 months of final effluent  monitoring data, and  three  have unique  operations not
representative of the Mechanical Pulp Subcategory. Paper products containing mechanical
pulp are typically manufactured from a mixture of mechanical pulp and bleached chemical
pulps.   The source  of bleached chemical pulp  may be virgin bleached chemical pulp
manufactured  on site, purchased bleached chemical pulp, or deink or non-deink secondary
fiber originally manufactured from bleached chemical pulp. To represent the performance
of secondary treatment in the Mechanical Pulp Subcategory, the Agency selected mills that
had a significant proportion of final production in the Mechanical Pulp Subcategory (i.e.,
greater than or equal to 50 percent), with the remainder of final production in subcategories
representing production  processes  that contribute   a relatively low  pollutant load to
wastewater  treatment  (e.g.,  the  Secondary Fiber  Non-Deink  and purchased  pulp
subcategories). Accordingly, 16 mills with final production in chemical pulping subcategories
or the Secondary Fiber Deink Subcategory were not considered representative of the
Mechanical Pulp Subcategory.  Similarly, four mills that combine their wastewater for
treatment with wastewater  from another mill with final production in chemical pulping
subcategories were also deleted from consideration. Finally, four mills  were deleted from
consideration because less than 50 percent of their final production was in the Mechanical
Pulp Subcategory. An exception was made to this 50 percent production cut-off to include

                                        9-9

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                                          9.0. Development of Control and Treatment Options
a mill that manufactures chemi-thermo-mechanical pulp to ensure that data from this
segment of the Mechanical Pulp Subcategory were included in developing BPT performance
levels.

After deleting the mills discussed above, as shown in Table 9-4, the percentage of final
production in the Mechanical Pulp Subcategory is distributed between <50 and 87 with the
majority of the remaining final production in the Secondary Fiber Non-Deink  and the two
purchased pulp subcategories.  In spite of a limited correlation between composition of final
production and  the production normalized BOD5  load in final  effluent  (correlation
coefficient of 0.70), the Agency determined that these mills adequately represent the
Mechanical  Subcategory because the majority  of the  pollutant loading to wastewater
treatment is generated by the mechanical pulping operations.
9.2.2.4
Non-Wood Chemical Pulp Subcategory
In responses to the 1990 questionnaire, 12 mills reported production in the Non-Wood
Chemical Pulp Subcategory in 1989. Of these 12 mills, 6 were not selected to represent the
performance of secondary treatment in the Non-Wood Chemical Pulp Subcategory because
five discharge wastewater indirectly  and one discharges wastewater  directly without
secondary treatment.  The remaining six mills operate four wastewater treatment systems
(three mills combine their wastewater for treatment). Information concerning these four
treatment systems is summarized in Table 9-5. As shown in the table, production in the
Non-Wood  Chemical Pulp  Subcategory comprises  an average of 41  percent of  final
production at these mills and ranges from 3 percent to 100 percent of final production. The
majority of the remaining final production is in the two purchased pulp subcategories. The
Agency found relatively poor correlation between composition of final production and the
production normalized BOD5 load in final effluent (correlation coefficient -0.56).  Mills
selected to represent the performance of secondary treatment in the Non-Wood Chemical
Subcategory had  a significant proportion of final production in the Non-Wood Chemical
Subcategory (i.e., greater than or equal  to  30 percent), with the remainder of final
production in the two purchased pulp subcategories.  The Agency determined that these
mills adequately represent the Non-Wood Chemical Pulp Subcategory because the majority
of the pollutant loading to wastewater treatment is generated  by the non-wood  chemical
pulping operations.

9.2.3  Performance Levels

As discussed, the Agency based BPT upon the average of the best existing performance, in
terms of treated effluent discharged by facilities in a Subcategory. The Agency used final
effluent long-term average production normalized BOD5 mass loadings to  characterize
existing performance. This measure of performance was selected because BOD5 control is
the primary objective of secondary treatment. Mills responding to the 1990 questionnaire

                                        9-10

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                                           9.0  Development of Control and Treatment Options
 supplied final effluent data in two formats. They completed a table listing daily TSS and
 BOD5 loadings (in Ib^day), averaged over each calendar month in 1989. They also provided
 daily measurements of flow and BOD5 and TSS concentrations.  For each subcategory, the
 daily data  reported  by half of the mills  selected  to  represent secondary treatment
 performance were entered into a database for analysis.  The mills whose daily data were
 analyzed represent the best performers in each subcategory.  Using these data, daily mass
 loadings (in kg/day) were calculated using the following equation:
                                     ML = kFC
(1)
where:

       ML   =    Daily mass loading, kg/day

       k     =    conversion factor

       F     =    Daily flow, MOD

       C     =    Daily pollutant concentration, mg/L.

The daily mass loadings were then averaged  to  determine  the long-term average mass
loading (in kg/day). The long-term average mass loadings were production normalized by
dividing by the mill's 1989 final off-machine production (in OMMT/year) and multiplying
by 350 production days per year, the typical number of operating days per year at a mill.

For mills for which only the monthly average flows, mass loadings, and concentrations were
entered into a database, the monthly average mass loadings (in Ibs/day) were averaged to
calculate the long-term average mass loadings.  The long-term average mass loadings were
then production normalized as described above.

To determine the average of the best existing performances of mills in each subcategory, the
Agency first ranked the mills representing secondary  treatment  performance in each
subcategory by ascending long-term average production normalized BOD5 mass loading in
final effluent.  This ranking is shown in Table 9-1.

The Agency made two divisions of the ranked mills. The first division excluded the mills
discharging the highest BOD5 loads in each subcategory, leaving 90 percent of the mills
representative of each subcategory to define "the best existing performance."  The second
division, at  the  50th percentile, was established  to:  (1) include enough mills in each
subcategory so that the range of products and processes  encompassed by the subcategory
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                                          9.0 Development of Control and Treatment Options
were included; (2) include both activated sludge and aerated/non-aerated basin treatment
systems; and (3) use a standard percentile cutoff for all subcategories.

After two division levels defining "best existing performance" were determined, the Agency
calculated performance levels representing the average of the long-term average production
normalized BOD5 mass loadings of each group of mills. The average performance of the
best 90 percent of the mills in each subcategory was Option 1.  The average performance
of the  best 50 percent of the mills in each subcategory was Option 2.  TSS performance
levels  for BPT Options  1  and 2 were calculated  by averaging the long-term average
production normalized TSS mass loadings of the best 90 percent and best 50 percent of the
mills representative of each subcategory, respectively, as determined by  the long-term
average production normalized BOD5  mass loadings. The Agency determined that a
separate performance level analysis for TSS  was not appropriate because secondary
treatment systems are designed for optimal BOD5 removal and may  not be optimized for
TSS removal. These performance levels are summarized in Table 9-6. The best performing
mills whose long-term average production normalized mass loadings were used to calculate
BPT Options 1 and 2  performance levels are indicated in Table 9-1.

9.2 A   Development off BPT Option 2 for the Dissolving Sulfilte Subcategoiy

BPT Option  1 BODS and TSS  performance levels were developed based upon the
performance of the single best performing dissolving sulfite mill, in terms of long-term
average production normalized BOD5 mass load.  Table  9-6 includes these performance
levels.

A different approach was  used to  develop a second option  for the Dissolving Sulfite
Subcategory for the following reasons:  (1) existing production normalized effluent loadings
for BOD5 and TSS in this subcategory are significantly greater than the loadings for other
subcategories (e.g., the loadings associated with the Dissolving Sulfite  Pulp Subcategory are
four times greater than the loadings for the Dissolving Kraft Subcategory, which utilizes
similar processes that produce high BOD5 raw waste loads); and (2) the performance level
of the single best dissolving sulfite mill, described above, would result in proposed BPT
effluent limitations less stringent than the current BPT limitations. Therefore, for Dissolving
Sulfite Option 2, the Agency developed an alternative methodology to determine the BOD5
and TSS performance levels. The Option 2 performance level was calculated in three steps:
(1) calculation of current average BOD5 and TSS production normalized raw waste loads
for the subcategory as reported by mills in their  1990 questionnaire;  (2) calculation  of
adjusted BOD5 and  TSS raw waste loads  based  upon load reductions associated with
implementation of BAT, National Emission  Standards for Hazardous Air Pollutants
(NESHAP),  Best  Management Practices (BMP),  and other  applicable flow  reduction
technologies; and (3) further load reduction based upon treatment performance from a well-.
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                                           9.0 Development of Control and Treatment Options
 designed and operated primary and secondary biological treatment system. These steps are
 described in further detail below.

 9.2.4.1       Calculation of Current Average Raw Waste Loads

 None of the dissolving sulfite mills provided raw waste characterization data in their 1990
 questionnaire.  Four of the five mills provided characterization data for partially treated
 wastewater streams. For these mills, raw waste BOD5 and TSS loads were back-calculated
 based upon assumed primary treatment performance or by accounting for situations where
 mills had multiple  treatment system inputs. Primary treatment performance data were
 available for only one mill; however, these data (10 percent TSS removal and 15 percent
 BOD5 removal) are not representative  of a well-designed or operated primary treatment
 system.  Therefore,  average primary treatment performance (86 percent TSS removal and
 18 percent BOD5 removal) of the Papergrade  Sulfite Subcategory was used to calculate
 dissolving sulfite raw waste loads.  For the fifth mill, data were insufficient to calculate or
 otherwise estimate raw waste loads. For the subcategory, estimated current BOD5 raw waste
 loads averaged 144 kg/OMMT and ranged from  114 kg/OMMT to  200 kg/OMMT.
 Estimated current TSS raw  waste loads averaged 92.5 kg/OMMT and ranged from 29
 kg/OMMT to 228 kg/OMMT.  .
9.2.4.2
Application of Load Reductions
The following load reductions were applied to the estimated current average subcategory
raw waste loads:
Source
BMP
NESHAP
BAT/COD
Control
Parameter
BOD5
BOD5, TSS
BOD5
TSS
Load Reduction
(kg/OMMT)
5
0
21.6
13.9
Comments
All mills were assumed to have
not implemented BMP. BMP do
not result in significant TSS load
reductions.
Condensate stripping of dissolving
sulfite mill condensates does not
result in significant BOD5 or TSS
load reductions.
BAT/COD control technologies
are estimated to reduce BOD5
and TSS raw waste loads by 15
percent.
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                                          9.0 Development of Control and Treatment Options
    Source
Parameter
Load Reduction
  (kg/OMMIT)
 BAT/Process
    Changes
BOD5, TSS
       0
See discussion below.
  Other Flow
   Reduction
  Technologies
BOD<, TSS
       0
Flow reduction in the pulping
area is part of BAT/COD control
technologies. Flow reduction in
the pulp drying area is applicable
to only one mill; therefore, flow
reduction in this area was not
applied to the subcategory. See
discussion below concerning flow
reduction in the bleaching area.
Wastewater discharge from all
other areas is minimal.
BAT Option 1 for the Dissolving Sulfite Subcategory consists of oxygen delignification with
complete substitution of chlorine dioxide for chlorine in the first bleaching stage. Although
reduction of the lignin content of the pulp bleached and elimination of chlorine in bleaching
will greatly reduce generation of chlorinated compounds, significant reductions in BOD5 and
TSS load will not occur because the revised bleaching process will continue to remove wood
components and their associated BOD5 and TSS load.  Depending on the sulfite base used,
some mills may recover or evaporate/incinerate post-oxygen delignification wastewaters
which would significantly reduce conventional pollutant load  to wastewater  treatment;
however, the BAT option does not include these technologies as part of the technology
basis. Therefore, the load reduction associated with BAT process changes for the purpose
of calculating the BPT performance level was considered to be zero.

The Agency also considered potential flow  reduction technologies applicable to the
bleaching area, such as countercurrent washing, to reduce the amount of wastewater
discharged from bleaching. Currently, approximately  50 percent of wastewater discharged
by dissolving sulfite mills is generated by the bleaching process. These technologies were
rejected because  of the product quality requirements of dissolving pulp and because of
limited available  data on the impact of conversion to totally chlorine-free bleaching on
wastewater discharge rates.

The remaining load reductions shown hi the above table  are the same as those used in the
end-of-pipe wastewater treatment upgrade and flow reduction cost models as discussed in
Sections 11.6.5.2 and 11.5.4, respectively.
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                                          9.0 Development of Control and Treatment Options
9.2.4.3
Application of Wastewater Treatment
The Agency assumed that a well-designed and operated primary and secondary treatment
system can achieve 90 percent BOD5 removal and 88 percent TSS removal. These removal
rates are demonstrated by mills in the Dissolving Sulfite Subcategory. The Agency believes
that these treatment performance levels may be improved after implementation of BAT,
NESHAP, and BMP and their associated flow reductions;  however, this has not been
demonstrated by the industry.
9.2.4.4
Calculation of Dissolving Sulfite Option 2 Performance Levels
The long-term average production normalized BOD5 and TSS mass loadings in raw waste,
after load reductions, were calculated as follows:
PNL = RWLC - (PR
              BMp
                               PR
                                              BAT/COD
                                                       PRBA
                                                           T/Tcp
POTHER)   <2>
where:
      PNL
      RWLC
      PR
         •BAT/COD
      PR
         •BAT/TCF
      PR
         OTHER
            Long-term average production normalized raw  waste mass
            loading, kg/OMMT

            Current  average production  normalized raw waste  load,
            kg/OMMT

            Pollutant reduction associated with BMP, kg/OMMT

            Pollutant reduction associated with NESHAP, kg/OMMT

            Pollutant reduction associated with BAT/COD, kg/OMMT

            Pollutant reduction associated with BAT/TCF, kg/OMMT

            Pollutant  reduction  associated  with  other  technologies,
            kg/OMMT.
Substituting values discussed above, the adjusted raw waste loads are:

      BOD5 PNLRaw      =     144 - (5 + 0 + 21.6 + 0 + 0) = 117.4 kg/OMMT

      TSS PNLRaw        =     92.5 - (0 + 0 + 13.9 + 0 + 0) = 78.6 kg/OMMT.

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                                          9.0 Development of Control and Treatment Options
The BOD5 and TSS  performance levels as represented by final effluent loads after
wastewater treatment were calculated as follows:
                                 = PNLRaw (100% - %R)
                                                    (3)
where:
      %R
Long-term average production normalized final effluent mass
loading, kg/OMMT

Long-term  average production  normalized  raw waste, mass
loading, kg/OMMT

Percent removal  of conventional  pollutants  in  wastewater
treatment.
Substituting values discussed above, the BOD5 and TSS performance levels are:

      BOD5 PNLpE =     117.4 (1QO% - 90%) = 11.74 kg/OMMT

      TSS PNLpE   =     78.6  (100% - 88%) = 9.4 kg/OMMT.

These values are listed in Table 9-6, as Dissolving Sulfite Option 2.

9.2.5  Description of Technology Bases

The BPT Option 1 and Option 2 performance levels described in Sections 9.2.3 and 9.2.4,
above, are mass-based, production normalized loads (i.e., they are expressed as kg of BOD5
(or TSS) per off-machine metric ton of production). These mass-based performance levels
derive from effluent concentrations and production normalized effluent flow:
                                PNL = C x
                                            PNF
                                                    (4)
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                                           9.0 Development of Control and Treatment Options
 where:
       PNL   =     production normalized load, kg/OMMT

       C     =     concentration, mg/L
       PNF   =
production normalized flow, m3/metric ton.
 Figure 9-1 presents final  effluent BOD5  concentrations plotted against  production
 normalized flows for the 33 nulls  selected  to represent the performance of secondary
 wastewater treatment for the Bleached Papergrade Kraft and Soda Subcategory. Each mill
 is represented by a number, with 1 representing the mill with the lowest BOD5 load and 33
 representing the mill with the highest BOD5 load. Also shown on the plot are lines for
 Option 1 and Option 2 for this subcategory. The equations for these lines (from Equation 2,
 solved for C) are, respectively:
                                 .  (1.000) 2.66.
                                       PNF
                                                           (5)
                                      (1,000) 1.57
                                         PNF
where:
       2.66   =

       1.57   =
Option 1 performance level, kg/OMMT

Option 2 performance level, kg/OMMT.
As shown in the graph, mills numbered 1  through 8 currently achieve lower production
normalized mass loadings than the Option 2 performance level, while mills numbered 9 and
above do not.

As shown on Figure 9-1, there are an infinite number of mill modes of operation, in terms
of production normalized flow and final effluent concentration, that may be used to achieve
Option  2 performance.  For example,  a bleached kraft mill achieving a production
normalized flow of 50 m3/OMMT and treating its wastewater to a concentration of 31.4
mg/L or less will  achieve Option 2 performance, as will a bleached kraft mill using 150
m /OMMT and treating its wastewater to 10.5 mg/L or less.
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                                          9.0 Development of Control and Treatment Options
The remainder of this section discusses the two components, production normalized flow
and effluent conventional pollutant concentration, of the BPT option performance levels.

9.2.5.1       Production Normalized Flow and Water Conservation Practices

Secondary wastewater treatment cannot achieve complete removal of BOD5 or TSS. There
is a lowest concentration that secondary treatment has been demonstrated to achieve to
date.  For the Bleached Papergrade Kraft and Soda Subcategory, the Agency determined
lowest secondary treatment system effluent BOD5 concentration currently demonstrated was
6 5 mg/L>  based on the three mills reporting the  lowest effluent BOD5 concentration.
Substituting 6.5 mg/L in Equation 4, above, and solving for PNF gives 242 m /OMMT,
meaning that 242 m3/OMMT is the maximum production normalized wastewater flow a
bleached papergrade kraft mill can discharge and achieve the Option 2 performance level
for BOD5.

Table 9-7 presents the calculated maximum production normalized flow for each option, by
subcategory, based upon the BPT performance levels listed in Table 9-6 and  the minimum
demonstrated concentration for each subcategory (listed in Table 11-10).  For comparison,
Table 9-7 also lists the maximum production normalized flow discharged by any of the mills
selected to represent the performance  of  each subcategory  that achieve  Option 1 or
Option 2 performance levels.   (Many data are not  presented to prevent  disclosure of
confidential business information). As shown on Table 9-7, mills that currently achieve BPT
option performance levels discharge less than the maximum discharge flow,  as a result of
good water conservation practices. Practices that are considered part of the technology basis
for BPT are:

       1.     Increased reuse and recycle of pulp and paper machine white water through
             the use of paper machine gravity strainers with high-pressure, low-volume,
             self-cleaning showers, or disc savealls;

       2.    Paper machine vacuum pump seal water recycle;

       3.     Screen room closure; and

       4.     Reuse of deinldng washwater after flotation clarification.

 These  technologies and the flow reduction that they can accomplish  are discussed in
 Sections 8.4 and 11.5.
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                                            9.0 Development of Control and Treatment Options
 92.52       Final Effluent Concentrations and Secondary Wastewater Treatment

 Low final effluent BOD5 and TSS concentrations are necessary for mills to achieve the BPT
 option performance levels.  To achieve these low concentrations while maintaining low
 discharge flows requires secondary wastewater treatment. Two types of secondary treatment
 are commonly used in the pulp and paper industry:  activated sludge and aerated/ non-
 aerated basin systems. In its 1990 census of the industry, the Agency requested a schematic
 diagram of each mill's treatment system and design and operating information  including:
                                                                            j>
       •      The hydraulic residence time (detention time) of each unit;

       •      The surface area of ponds and clarifiers;

       •      Horsepower of aeration in each tank or basin; and

       •      For activated  sludge systems, the MLSS, F:M  ratio,  and biological solids
              retention time.

 The Agency also requested data describing the flow and BOD5 and TSS concentrations and
 loadings into and out of the treatrnent system.

 Table  9-8 tabulates data supplied in response to these requests, for the mills selected to
 represent secondary wastewater treatment performance in each subcategory.  Data for
 certain mills is  not reported on Table  9-8.  If there were fewer than three  mills in a
 subcategory, or fewer than three mills in a subcategory with one treatment type, data for
 these mills was not disclosed to prevent compromising confidential business information.
 AU mills supplied data describing the flow and BOD5 and TSS concentrations and loadings
 discharged from their treatment system.  But, as indicated by Table 9-8, the data supplied
 by many mills  describing the influent to the treatment system were inadequate to calculate
 the percent removal of influent BOD? and TSS.  The inadequacy in the data resulted from
 the fact that many nulls do not monitor influents, many treatment systems have multiple
 entry points (and so a single removal efficiency cannot be calculated), and many respondents
 did not supply influent information for unspecified reasons. Where data were sufficient to
 calculate treatment system performance,  Table 9-9 for activated sludge systems and Table
 9-10 for aerated stabilization basins  list critical treatment system design and  operating
parameters.
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                                          9.0 Development of Control and Treatment Options
The best removals achieved by activated sludge treatment systems are summarized below:
                              BOB$ Removal Percent
                    TSS Removal Petcent
  Chemical Pulp Mills
93 to 98
                                                                92 to 97
  Mechanical Pulp Mills
92 to 97
                                                                97 to 99
  Nonpulping Mills
71 to 93
                                                                95 to 98
Aerated/non-aerated basin treatment system performance is similar:
                               BODS Removal Percent
                     TSS Removal Percent
  Chemical Pulp Mills
91 to 96
                                                                92 to 98
  Nonpulping Mills
84 to 89
                                                                85 to 97
 As discussed in Section 8.5, activated sludge treatment system performance improves as:

       •     Detention time increases;

       •     F:M ratio decreases (within a range sustaining an active biomass); and

       •     Secondary clarifier overflow rates decrease.

 Aerated/non-aerated basin treatment system performance improves as:

       •     Detention time increases;

       •     BOD5 loading decreases; and

       •     Aeration intensity increases.

 However, there is no simple relationship between any one design parameter and excellent
 BOD5 and TSS removal.  For example, the worst performing chemical pulp mill activated
 sludge treatment system (80 percent BOD5 removal) had an F:M ratio of 0.74, more than
 twice as high as any other system.  The aeration intensity was also  quite high (954 HP/
 1,000 m3), but evidently the oxygen transfer was not high enough  to sustain an adequate
 microbial population to achieve a high BOD5 removal.
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                                            9.0 Development of Control and Treatment Options
 The generalizations listed above cannot always explain treatment system performance. For
 example, the detention times of the best performing mechanical pulp mill activated sludge
 treatment systems  ranged from 3.6 to 5.4 hours, while the worst performing  system
 (achieving 53  percent BOD5 removal)  had a 19-hour detention time.   This treatment
 system's poor performance may be explained by a very low F:M ratio, 0.08, perhaps too low
 to sustain an active biomass. Moreover, as noted in Section 8.5, the operation of treatment
 systems is also important to achieving optimum effluent quality. This is particularly true of
 activated sludge systems which require careful day-to-day attention to numerous important
 operating parameters.

 Due to the complex relationship between treatment system critical design and operating
 parameters, there is no simple definition of treatment system upgrade. Feasible activated
 sludge treatment system upgrades include:

        •     Increase in aeration basin capacity (resulting in longer hydraulic retention
             times and lower F:M ratios);

        •     Increase in clarifier capacity (resulting in lower overflow rates); and

       •     Addition of flocculant to improve sludge settling.

 Feasible aerated stabilization basin treatment system upgrades include:

       •     Increasing the aeration  in  existing ponds (resulting in improved  oxygen
             transfer);

       •     Increasing the volume of aerated ponds or adding new  ponds (resulting in
             increased hydraulic detention time);

       •     Supplementing the nutrients available in mill wastewater; and

       •     Adding settling capacity for the removal of suspended solids.

The combination of upgrades applicable to a mill depends upon the characteristics of its
wastewater and upon the treatment it currently uses.

9.3    BCT

Best conventional'pollutant control  technology  (BCT) effluent limitations  guidelines
establish quantitative limits  on the direct discharge of conventional pollutants from existing
industrial point sources. In contrast to BPT guidelines that are derived as the average of
the best existing performance by a group of like facilities, BCT guidelines are developed by

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                                          9.0 Development of Control and Treatment Options
identifying candidate technologies and evaluating their  cost-reasonableness.  Effluent
limitations guidelines based upon BCT may not  be less stringent than  BPT effluent
limitations guidelines. As such, BPT effluent limitations guidelines are a "floor" belowwhich
BCT effluent limitations guidelines cannot be established.  EPA has developed a BCT cost
test methodology to assist the Agency in determining whether it is "cost-reasonable" for
industry to control conventional pollutants at a level more stringent than would be required
by BPT effluent limitations (4).

BCT effluent limitations guidelines are developed in five steps:

       (1)    Identification of existing technologies which control conventional pollutants
             beyond the level achieved by BPT effluent limitations;

       (2)    Analysis of the technologies to determine  their performance, in terms of
             pollutant reduction;

       (3)   Estimation of the cost of the technologies;

       (4)   Execution  of the BCT  cost test, using the estimated costs  and pollutant
             reductions; and

       (5)   For any options that pass the cost tests, review of non-water  environmental
             quality impacts.

 In performing the BCT cost test, a BPT baseline must be developed to serve as the starting
 point against which more stringent technologies are analyzed. The baseline includes both
 baseline pollutant discharges and control costs. Because EPA was revising BPT limitations
 at the same time the BCT limitations were revised, an  additional level of analysis was
 necessary to determine an appropriate BPT baseline.  EPA considered  three possible
 baselines:

       (1)   Proposed revised BPT effluent limitations guidelines, equivalent to BPT
             Option 2 (discussed in Section  9.2), and the cost of this level  of control
              (discussed in Section 11.0);

        (2)    The current long-term average discharge of conventional pollutants and the
              cost of this level  of control (based on data from the 1990 questionnaire); or

        (3)    The 'current BPT effluent limitations guidelines and the hypothetical cost of
              this level of control.
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                                           9.0  Development of Control and Treatment Options
 The Agency rejected the third approach, because there was no reasonable estimate of the
 cost of this level of control. Further, many segments of the industry attain better control
 of conventional pollutants than is required by the  existing  BPT effluent limitations
 guidelines.  Instead, the Agency conducted the BCT analysis using Baseline 1 (above). The
 Agency also conducted an alternative analysis using Baseline 2.

 The remainder of this section describes the BCT options developed for the two analytical
 approaches. The assessment of the options, in terms of pollutant reductions achieved, is
 presented in Section 10.0. Section 11.0 presents the estimated costs of implementing each
 option  while Section 12.0 presents the non-water quality environmental impacts of the
 option  selected to form the technology basis of each regulation.  The two-part BCT cost-
 reasonableness test is described in a separate  report "BCT Cost Test for the Proposed
 Effluent Limitations for the Pulp, Paper, and Paperboard Industry," which may be found in
 the Record for the Rulemaking.

 9.3.1   BCT Options Assuming "Baseline" is BPT Option 2

 The Agency identified two candidate technologies to evaluate against baseline conventional
 pollutant control costs and removals equivalent to BPT Option 2. As discussed above, BCT
 may not be less  stringent than BPT.

 9.3.1.1       Option A.1 - The Performance Level Represented by the Best-Performing Mill
             in Each Subcategory

 Using information supplied in response to the 1990 questionnaire, the Agency identified the
 best performing mill in each subcategory.  As discussed in Section 9.2, performance was
 defined by the production normalized load of BOD5 discharged and the performance of a
 subcategory was defined, in general, by the group of mills with 85 percent or more of then-
 production in that subcategory.  Using information reported in the 1990 questionnaire, the
 Agency could identify the end-of-pipe wastewater treatment used by each best-performing
 mill.  As discussed in Section 9.2, the low discharge loads achieved by the best-performing
 mills  often result from  excellent  water  conservation practices  (i.e.,  low production
 normalized  water use). However, information  supplied with the questionnaire was not
 sufficiently detailed  to  enable the  Agency to  estimate the cost of retrofitting  existing
 facilities with the water conservation technologies used by the best-performing mills. As a
 result, Option A.1 could not be evaluated using  the cost-reasonableness  tests.
9.3.1.2
Option A.2 - Multimedia Filtration
This option consists of the addition of multimedia filters,  designed for the rempval of
suspended solids, to the flow reduction and end-of-pipe treatment train required for each
mill to meet BPT Option 2 performance levels.  The Agency assumed the multimedia filter

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                                          9.0 Development of Control and Treatment Options
(or filters, for large flows) would treat the entire volume of wastewater discharged by the
mill.  Performance was defined as 60 percent reduction in the TSS load (that is, a 60
percent reduction from the BPT Option 2 level), to a minimum TSS  concentration of 3
mg/L (5). The mass of BOD5 removed by the fflter(s) was assumed to be half the mass of
TSS removed, the  same assumption about the relationship between BODS and TSS used
during the estimation of the cost of BPT Options 1 and 2 (see Section 11.6).

The Agency estimated the pollutant removals and costs of Option A.2 (see Sections 10.2.4
and 11.7.2) and the estimates were used to test its cost-reasonableness.

933,   BCT Options Under Alternative Analysis: Assuming "Baseline" is Current Industry
       Performance

The Agency developed two BCT options to evaluate against baseline conventional pollutant
control costs and removals represented by the current performance of the industry.

932.1       Option B.I - The Performance Level Representing the Average of the Best 90
             Percent of Mills in Each Subcategory (BPT Option 1)

This option is equivalent to BPT Option 1, discussed in Section 9.2. The pollutant removals
and costs estimated for BPT Option 1 were used to test the cost-reasonableness of this
option against the  current industry performance baseline.

9.3.2.2       Option B.2 - The Performance Level Representing the Average of the Best 50
             Percent of Mills in Each Subcategory (BPT Option 2)

This option is equivalent to BPT Option 2, discussed in Section 9.2. The pollutant removals
and costs estimated for BPT Option 2 were used to test the cost-reasonableness of this
option against the current industry performance baseline.
 9.3.2.3
Other Options Considered
 The Agency considered evaluating the options developed for evaluation against the baseline
 represented by BPT Option 2 against the baseline represented by the current performance
 of the industry. These two options are: (1) the performance level represented by the best-
 performing mill, and (2) BPT Option 2 plus multimedia filtration. As discussed in 9.3.1.1,
 above, the "best-performing mill" option was not analyzed because the Agency was not able
 to sufficiently define the technology basis of this option to estimate its cost.

 The multimedia filtration option differs  slightly from Option A.2 identified to evaluate
 against the BPT Option 2 baseline hi 9.3.1.2, above, in that the starting point is the current
 mill performance, rather than BPT Option 2 performance.  The removal is the  sum of the

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                                           9.0 Development of Control and Treatment Options
 removals for BIT Option 2 and BCT Option A.2, described in 9.3.1.2, but the cost is not
 a simple sum. This is because, for some mills, the current TSS effluent concentrations are
 low enough that filters could be feasibly applied without the treatment system upgrades
 costed for BPT Option 2.  The Agency had inadequate tune and resources to fully evaluate
 the  costs of the  multimedia  filtration option assuming baseline is current  industry
 performance and, as a result, this option was not evaluated using the cost-reasonableness
 test.

 The Agency also considered an alternative using a different baseline (revised BPT effluent
 limitations guidelines equivalent to BPT Option 1) and one BCT option equivalent to BPT
 Option 2. The analysis of this alternative can be found in the Record for the Rulemaking.

 9.4    BAT

 Best available technology economically achievable (BAT) effluent limitations guidelines
 establish quantitative limits on the  direct  discharge  of priority  and nonconventional
 pollutants to navigable waters  of the United  States.  These limits are based upon the
 performance of specific  technologies,  but they do  not require the use of any specific
 technology.  BAT effluent limitations guidelines are applied to individual facilities through
 NPDES permits issued by EPA or authorized states under Section 402 of the CWA. The
 facility then chooses its own approach to complying with its permit limitations.

 The technology selected by the Agency to define the BAT performance may include end-of-
 pipe treatment, process changes, and internal controls, even when these technologies are not
 common industry practice. BAT performance is established for groups of facilities with
 shared characteristics.  Where  a  group of facilities demonstrates uniformly inadequate
 performance in the  control of  pollutants of concern, BAT  may be transferred  from a
 different subcategory or industrial category.

 A primary consideration in selecting BAT is  the effluent pollutant reduction capability of
 the available technologies.  Implementation of the best available technology must  be
 economically achievable  by the industry, so  the cost of applying the technology is also
 considered.  Other factors considered in establishing BAT include:

      •      The processes used;
      •      Potential process changes;
      •      Age and size of equipment and facilities; and
      •      Non-water quality environmental  impacts, including energy requirements.

As discussed in Section 7.0, the Agency identified 18 priority and nonconventional pollutant
 compounds  generated by mills in the United States  that  chemically pulp wood and
subsequently bleach the wood pulp with chlorine and/or chlorine-containing compounds.

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                                          9.0 Development of Control and Treatment Options
The Agency determined that control of the discharge of these pollutants was required and
assessed the technologies available to control their discharge.  This assessment focused on
available process technologies that reduce or eliminate the formation of the pollutants of
concern to the  Agency, and so avoid the potential for cross-media impacts  (such  as
accumulation of chlorinated dibenzo-p-dioxins  (CDDs) and  chlorinated dibenzofurans
(CDFs) in sludges  and the emission of chloroform to air) in end-of-pipe  wastewater
treatment.  Section 8.0 provides an overview of the technologies assessed by the Agency.

As  the Agency assessed these process technologies, it also reviewed the status of their
implementation  on an industrial  scale.  Because it is the performance of the selected
technology that becomes the basis for effluent limitations guidelines, it was important for
the Agency to identify technologies for which  performance data (in terms  of mass  of
pollutants discharged from the process and from the mill) were available. Because the
pulping and bleaching technologies the Agency considered for BAT are inter-related, they
are implemented in a limited number of combinations.  As the Agency assessed various
process technologies,  it also  reviewed the typical combinations  in which they were
implemented on,an industrial scale.

As  a result of this engineering assessment, the Agency  developed  a  number of process
technology combinations capable of reducing the discharge of priority and nonconventional
pollutants of concern and configured these combinations into BAT options. Because the
BAT options focused on source reduction (pollution prevention) through  changes  to
production processes, they were developed separately for each process/product subcategory
in the category.

The BAT options considered for each subcategory were numbered to  indicate the degree
of pollutant control  achieved by each option, with Option 1 being the  lowest degree of
control and each increasing number providing increased  control.  This ranking of options
was based upon the  improvements to pollutant  control that would be seen if the process
changes were implemented while all other pulp manufacturing variables were held constant,
(i.e., if the process changes were implemented at  a single mill in a controlled series of tests).
The Agency did not have such data available to evaluate the performance of the BAT
options. Instead, as described in Section 3.0, hi  cooperation with the industry, the Agency
collected data from separate mills that had implemented the BAT option technologies  on
a full scale.  Each  mill produced somewhat different  products, such as market pulp,
uncoated free sheet, fluff pulp, and paperboard for the mills representing the Bleached
Papergrade Kraft and Soda Subcategory.   Each  mill used somewhat different  pulp
manufacturing variables such as fiber furnish, pulp consistency, brown stock Kappa number,
and bleaching chemical application rates. Each mill controlled these variables to a different
extent,  through  instrumentation,  automation, and operator diligence.  As a result, the
performance data do not always reflect increased pollutant control, for every pollutant, with
each increasing option. For example, for the Bleached Papergrade Kraft and Soda

                                        9-26

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                                            9.0 Development of Control and Treatment Options
 Subcategory, final effluent adsorbable organic halides (AOX) and 2,3,7,8-tetrachlorodibenzo-
 p-dioxin (2,3,7,8-TCDD) discharges follow the progression below:
Option
1
2
3 '
4
5
Final Effluent AOX
(fcg/ADMT)
1.39
1.62
0.46
0.14
0.26
Bleach Plant 2,3,7,8-
TCDD (ng/ADMT)
519(a)
161(a)
131(a)
ND
ND
 (a)Average mass discharge calculated using half the detection limit for one or more concentrations reported at
   less than the detection limit.

 The Agency concluded that the deviations from the expected trends result from sources of
 variability in its sampling program, including manufacturing variables, wastewater treatment,
 sampling, and laboratory analysis. The Agency further concluded that the data it used to
 characterize the  BAT  options reflect  full-scale  implementation  of the  options  at
 commercially viable mills, producing products typical of the industry, and reflecting the
 variability of the industry as represented by the data sets available in a timely manner for
 inclusion in the proposed regulations. The Agency has requested additional data to refine
 the performance of these options.

 9.4.1 Approach to Option Development
                             i
 9.4.1.1       Process Changes and End-Of-Pipe Treatment

 Two major approaches may be used to control the discharge of chlorinated pollutants, AOX,
 and other nonconventional pollutants from mills that bleach chemical pulp:

      (1)    In-process technology changes to prevent or reduce pollutant formation; and

      (2)    End-of-pipe wastewater treatment technologies to  remove pollutants from
             process wastewaters prior to discharge.

The Agency determined that the most environmentally beneficial approach is to combine
process  technology changes which reduce or eliminate the  formation of the pollutants of
concern with best available end-of-pipe treatment.  It is not feasible to rely on end-of-pipe
                                        9-27

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                                          9.0  Development of Control and Treatment Options
controls alone, because they do not prevent pollution and do not ensure that non-water
quality environmental  impacts (such as emission of chloroform, and contamination of
wastewater treatment sludge with CDDs) will be minimized.  Process technology changes
cannot be relied upon alone, however, because end-of-pipe treatment provides additional
cost-effective control of the discharge of conventional pollutants and many nonconventional
pollutants, including certain chlorinated phenolics, AOX, and COD.

Even after the implementation of pulping and  bleaching process changes to reduce the
formation of chlorinated pollutants, low levels of these pollutants may be  discharged from
mills, and thus require end-of-pipe treatment. Sources of chlorinated pollutants not directly
related to the bleaching process may include:

       •      Paper machine white water generated when paper is made from chlorine-
             bleached pulp;

       *      Floor washings from bleach plants where chlorine and chlorine-containing
             compounds are used;

       •      Wastewaters from  areas used to prepare chlorine-containing  bleaching
             compounds; and

       •      Wastewaters from wet scrubbers used to control emissions from bleaching
             towers and  bleach  plant vents on bleach lines where chlorine-containing
             compounds are used.

In addition, effective end-of-pipe treatment (particularly suspended solids removal) can help
control the discharge  of sludges that  have  accumulated in aerated stabilization basins,
polishing ponds, and appurtenant sludge management devices.  These sludges can contain
CDDs, CDFs, and other chlorinated organic pollutants.

Because revised BPT effluent limitations guidelines were developed at the same time as the
BAT options, the end-otpipe treatment that would be required to comply with the revised
BPT guidelines was presumed to be in place as  the  BAT  options were  developed.
Therefore, the BAT options include only process changes.

9.4.1.2       Strategies for Preventing the Formation of Chlorinated Pollutants

CDDs, CDFs, and other chlorinated pollutants result from the interaction of chlorine (and
to  a lesser extent,  other  chlorine-containing bleaching chemicals) and lignin during  the
bleaching of pulp.  After eliminating the direct  introduction of CDD and CDF precursors
(in defoamers and pitch dispersants) into the bleaching process, three major strategies have
evolved  to reduce the formation of chlorinated  pollutants during bleaching:

                                        9-28

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                                           9.0 Development of Control and Treatment Options
       (1)    Elimination of localized high concentrations of chlorine and/or lignin (by
             improving pulp quality, improving mixing, eliminating overbleaching, and split
             addition of the chlorine charge);

       (2)    Reduction in the lignin entering the bleaching process (by improved brown
             stock washing, and extended delignification with oxygen or modified cooking
             processes); and

       (3)    Reduction in the amount of chlorine used to bleach pulp (by substituting
             other bleaching agents such as chlorine  dioxide, hydrogen peroxide, oxygen,
             or ozone, for chlorine).

These strategies have been incorporated into the BAT options for each subcategory for
which the  Agency is proposing limitations for  2,3,7,8-TCDD, 2,3,7,8-TCDF, and  other
chlorinated compounds.

9.4.1.3       Production Rate and Product Qualify Considerations

As outlined  at the  beginning  of this section, BAT  (best available control  technology
economically achievable) effluent limitations guidelines are developed in four steps:

       (1)    Identification of existing technologies for the control of wastewater
             pollutants;
                          i
       (2)    Analysis of the technologies to determine the best performance, in terms of
             pollution reduction;

       (3)    Estimation  of the  cost of  the   technologies to determine  economic
             achievabiliry; and

       (4)    Review of non-water quality environmental impacts.

The underlying assumption under which  the  Agency carried out the development and
analysis of BAT options was that BAT process changes would not result in:

       •      Changes in raw materials (i.e., fiber furnish);

       •      Changes in the amount of final product produced by each mill; or

       •      Significant changes  in the properties (e.g., quality and grade) of the final
             product produced by each mill.
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                                           9.0 Development of Control and Treatment Options
For example, if a mill currently produces 1,200 ADMT/day of 90 ISO brightness pulp from
softwood, only technologies demonstrated to achieve 90 ISO brightness for softwood pulp
were considered "available technologies." Further, in estimating the pollutant reduction and
cost of implementing each option the mill was assumed to  continue to  produce 1,200
ADMT/day of 90 ISO pulp.

As reviewed in Sections 8.2 and 8.3, most of the technologies that reduce the generation of
chlorinated  pollutants involve  either  changes in  the pulp  entering the bleach plant
(particularly changes that result in reduction of the lignin content of the pulp entering the
first stage of bleaching, as measured by the brown stock Kappa number),  changes in the
bleaching chemicals used, or both. Pulp is bleached to increase its brightness.  Bleaching
also affects pulp properties by removing or modifying lignin and its degradation products,
and by removing resins, metal ions, noncellulosic carbohydrate components, and flecks of
various kinds. Pulp is bleached not just to make it whiter, but also to reduce the effects of
aging on color, strength, and brightness (6). In order to implement changes in pulping and
changes in bleaching chemicals, but still maintain consistent pulp properties, all BAT process
change options include two assumptions:

       (1)    The total bleaching power (expressed as chlorine equivalent) of all bleach line
             stages after the first chlorine stage is constant; and

       (2)    The active chlorine multiple (ACM) of the first (chlorine) stage is constant.

As explained in Section 11.1.2.6, each bleaching agent used by the industry has a bleaching
power related to the oxidation potential of chlorine.  The practical relative bleaching power
of chlorine dioxide, for example is 2.63, meaning that 1 kg chlorine dioxide can replace 2.63
kg of chlorine.  The practical relative bleaching power of ozone is 4.4, meaning  1 kg ozone
can replace 4.4 kg of chlorine.

The chlorine equivalence factors are used to implement the assumption that the total bleach
line bleaching power is constant after a process change. For example, the BAT  options for
the  Bleached  Papergrade  Kraft and  Soda Subcategory include  the  elimination of
hypochlorite and the replacement of its bleaching power with additional chlorine dioxide in
subsequent bleaching stages.

A slightly different approach is used in assessing bleaching chemical changes for the first
chlorine bleaching stage, because the chemical application rate of this stage  is  dependent
on the lignin content of the incoming pulp (measured as Kappa number). Because certain
technology options include changes in both the chemicals currently  applied in the first
bleaching stage and in the incoming brown stock  Kappa  number, it is the ratio of the
equivalent chlorine to Kappa number that is held constant. This ratio is called the active
chlorine multiple (ACM)  and is defined as:

                                        9-30

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                                          9.0 Development of Control and Treatment Options
where:
       TEC

       Kappa

       C12


       CIO,
                         ACM =
 TEC
Kappa
                                                2.63C1O
                                               Kappa
                                                    (7)
tptal equivalent chlorine in percent on pulp

pre-chlorination brown stock Kappa number

chlorine charge in percent on pulp (kg C12/100 kg brown stock
pulp)

chlorine dioxide charge, in percent on pulp (kg C1O2/100 kg
brown stock pulp).
For ozone, the total equivalent chlorine is given by:
                                  TEC = 4.4 CX
                                                    (8)
where:

      O3     =     ozone charge in percent on pulp (kg O3/100 kg brown stock pulp).

An example of the application of this approach is summarized below:
-
Base Case
64% substitution
lower Kappa + 64% substitution
lower Kappa + 100% substitution
lower Kappa + ozone
Kappa
30
30
18
18
15
•&<
7.5
2.73
1.63
0
0
CIO*
0
1.81
1.09
1.71
0.85 kg
ozone/100 kg
pulp
IfJC
7.5
7.5
4.5
4.5
3.75
ACM
0.25
0.25
0.25
0.25
0.25
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                                          9.0  Development of Control and Treatment Options
In the base case, chlorine is applied at a rate of 7.5 percent on pulp to an incoming pulp
with Kappa number 30, resulting in an ACM of 0.25.  When 64 percent of the bleaching
power of chlorine is replaced with chlorine dioxide, the chlorine charge is reduced to 2.73
percent on pulp.  Maintaining the ACM at 0.25 and the 64 percent substitution rate, but
reducing the incoming Kappa number to  18, further reduces the chlorine charge (to 1.63
percent on pulp). Finally, the bleaching power of chlorine may be completely replaced by
chlorine dioxide or ozone at a rate of 1.71 or 0.85 percent on pulp, respectively.

In actual practice, a mill has considerable flexibility in modifying bleach sequences.  For
example, enhancing the first extraction stage with oxygen and peroxide would enable the use
of a lower ACM. For simplicity of presentation, however, this flexibility is not included in
the following explanation of the BAT options.

The remainder of this section describes the BAT options developed for each subcategory.
The assessment of the options, in terms of pollutant reductions achieved, is presented in
Section 10.0.  Section 11.0 presents the estimated cost of implementing each option. Section
12.0 presents the non-water quality environmental impacts of the option selected to form
the technology basis of each regulation. These non-water quality environmental impacts are
energy use, air pollution, odor, and quantity and quality of wastewater treatment sludge
generated.

9A3,  Bleached Papergrade Kraft and Soda Subcategory

The proposed BAT effluent limitations guidelines for 2,3,7,8-TCDD and other priority and
nonconventional pollutants apply  to  four  subcategories with a total of 95 mills.  The
Bleached Papergrade Kraft and Soda Subcategory,  with 77 mills and approximately  90
percent of the total U.S. bleached chemical pulp production, is the largest of the four
subcategories. More research and development of toxics-reducing processes have been done
on the bleached papergrade kraft process than on the other processes. For these reasons,
 Section 8.0 describes many pollution prevention process changes and end-of-pipe treatment
 technologies that can be used to control the discharge of priority  and nonconventional
 pollutants from bleached  papergrade kraft and  soda mills.   While  many  of these
 technologies may be currently hi use or may be used by mills when complying with the
 proposed BAT regulations, the Agency did not have  sufficient performance data to fully
 analyze  all of them as BAT options.  The Agency developed five  BAT options for the
 Bleached Papergrade Kraft and Soda Subcategory for which it had performance data and'
 considered developing a totally chlorine-free  (TCP) bleaching  option.  The  elements
 common to these five options are described below, followed by a description of each of the

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                                           9.0 Development of Control and Treatment Options
five options the Agency completely analyzed. A discussion of TCP bleaching of papergrade
kraft pulp completes this section.

9.4.2.1       Common Elements of Bleached Papergrade Kraft and Soda Options

The BAT  options for the Bleached Papergrade Kraft and Soda Subcategory have six
common elements.

1.     Adequate Wood Chip Size Control.  Until recently, mills have controlled only two
of the three chips dimensions (length and width) using vibratory screens. As described in
Section 8.2.1, however, uniform chip thickness promotes more uniform liquor penetration,
resulting in a high-quality pulp. Lower quality pulps contain excessive shives that may be
removed by screening resulting in yield loss or overbleaching, which may result in formation
of chlorinated pollutants.  Chip thickness can be controlled by:

       •     Close control of chipping equipment tolerances, or

       •     The use of chip thickness screens.

As discussed in  Section 11.1, implementing chip size control is assumed to  pay for itself
through improved yield (fewer rejects), higher quality pulp  that requires less intense
bleaching (lower chemical costs), and more consistent pulp mill and bleach plant operation
(lower overall operating costs).

2.     Elimination of defoamers and pitch dispersants containing dioxin precursors. Two
groups  of  additives used  in  the  production of bleached  pulp,  defoamers  and pitch
dispersants, have been shown to contain the CDD and CDF precursors dibenzo-p-dioxin
(DBD) and dibenzofuran (DBF) (7,8).

Replacing  contaminated additives with precursor-free additives requires no significant
process modifications or equipment changes.  Thus,  the conversion to clean  additives
containing less than 1 ppb of both DBF and DBD thus does not have a significant impact
on the cost of the production of bleached pulp or on the quality of product.  The Agency
believes that the U.S. pulp industry has generally converted to the use  of precursor-free
additives.

3.     Effective  brown stock washing.  Washing that achieves a soda loss of less than or
equal to 10 kg Na^SCv  per ADMT of pulp (i.e., 99 percent recovery of pulping  chemicals
from the pulp) maximizes the return of cooking liquor to chemical recovery for recovery of
the cooking chemicals and energy value  of the dissolved wood components.  Because the
organic material carried over into the bleach plant with the pulp exerts a chlorine demand,
minimizing the carry over of cooking liquor to bleaching reduces the amount of bleaching

                                       9-33

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                                           9.0 Development of Control and Treatment Options
chemicals  required and,  consequently,  the  likelihood  of  charging  excess  chlorine.
Muiirnizing the carry over of cooking liquor also  reduces the load  of  organic material
(measured as COD) discharged in bleach plant filtrates.  For this reason, improved brown
stock washing is part of the technology basis for COD control, described in Section 9.4.2.7
below, as well as the technology basis for the control of chlorinated pollutants.

As discussed in Section 11.1.3.6, effective brown stock washing results in greater loads of
pulping liquor solids and dissolved wood components to the recovery  boiler.  On average,
this increased load represents less than 1 percent increase in the total heating value input
to the recovery boiler which can be accommodated at virtually all mills.

4.     Elimination of hvpochlorite.  As discussed in Section 8.3.7, controlling chloroform
releases generally requires eliminating hypochlorite as a bleaching agent. Each of the five
BAT options for the Bleached Papergrade  Kraft and Soda Subcategory includes replacing
hypochlorite with equivalent bleaching power for  mills that  currently use hypochlorite.
These replacements are in the form of additions  of peroxide and oxygen  to the  first
extraction stage. Also, if additional bleaching power replacement is  required, additional
chlorine dioxide is applied in subsequent  brightening stages.  The approach selected to
compensate for the elimination of hypochlorite depends on the mill's current bleaching
sequence.  Typical "before" and "after" bleach sequences are listed below.
Before Hypochlorite
Substitution
C/DEHD,ED2
C/DEHD
sequences with 2H and ID
stage
CEH
' 'Ate* *™ '
£ i : -. i
•n't ••' ^
C/D EopD1ED2, with increased C1O2 in Dj '
C/D EopDjDj for Options 1 and 2 or
OC/D E^D for Options 3, 4, and 5
Eop with 2D stages
CE^D
As discussed in Section 9.4.1.3 above, options that eliminate hypochlorite also maintain the
total bleaching power (in chlorine equivalent) of all bleach line stages after the first chlorine
stage.

5.     Oxygen and peroxide enhanced extraction. As discussed in 8.3.6, enhancing the first
extraction stage with oxygen and  peroxide increases pulp brightness and allows use of a
lower ACM (less chlorine and/or chlorine dioxide) in the first bleaching stage. Each of the
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                                            9.0  Development of Control and Treatment Options
 five BAT options for the Bleached Papergrade Kraft and Soda Subcategory includes oxygen
 and  peroxide enhanced extraction.   As  described  above,  for mills that currently use
 hypochlorite, these enhancements replace the bleaching power of hypochlorite when it is
 eliminated.  For mills that currently do not use hypochlorite, the  enhancements replace
 some of the bleaching power of chlorine and/or chlorine dioxide in the first bleaching stage.

 6;    High shear mixing for split addition of chlorine in Option 1, for addition of chlorine
 dioxide in Options 2, 3, 4, and 5, and for addition of oxygen in reinforced extraction in all
 options.  High shear  mixers impose large rotational speeds across narrow gaps through
 which the pulp suspension flows, thus ensuring floe disruption and good contact between
 added chemicals and  the individual pulp fiber.   This contact  is  essential  in  ensuring
 adequate bleaching in the first chlorine stage and efficient use of oxygen in reinforced
 extraction.

 9.4.2.2        Option 1 - Split Addition of Chlorine

 For this option, the total equivalent chlorine (chlorine and/or chlorine dioxide)  added to
 the first bleaching  stage is split into two parts and added at discrete intervals, instead of
 adding the entire chlorine charge at one point. In order to be1 effective, the pulp must be
 very well mixed with the chlorine, and the pH of the stage must be controlled using sodium
 hydroxide (9). The option includes additional high  shear mixing, as well as additional
 process controls.  The increased mixing ensures optimum contact between pulp and chlorine
 in the first bleaching stage and that the chlorine  charge is well dispersed: The process
 controls allow the mill to accurately maintain the pH in the first bleaching stage at a higher
 than normal level.

 Based upon data  reported by ffise (9) and confirmed by contact with several mill operators
 through EPA's capital  cost request letter of mid-1992,  the total chlorine charge to the first
 stage should  be increased slightly (by approximately 10 percent) when it is applied in two
 parts, to ensure that the bleaching effect of the first stage remains the same.

 9.4.2.3       Option 2 - Substitution of Chlorine Dioxide for Chlorine

This option includes the replacement of some of the molecular chlorine used  in the first
bleaching stage with chlorine  dioxide, known as chlorine dioxide substitution.  As described
in Section 8.3.5, percent chlorine dioxide substitution is defined  as the percent of the total
equivalent chlorine bleaching power in the first bleaching stage contributed by the chlorine
dioxide:
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                                           9.0 Development of Control and Treatment Options
                           % S  =
                                      2.63 CIO,
                                   C12 + 2.63 C1O2
                         x 100
                                                                                (9)
where:

       % S   =  '   chlorine dioxide substitution, percent

       C1O2  =     chlorine dioxide charge, kg C1O2/100 kg pulp

       C12    =     chlorine charge, kg C12/100 kg pulp.

As discussed in  Section 8.3.5, Luthe, et. al (10) developed a relationship between the
amount of chlorine dioxide substitution needed to rninirnize the formation of chlorinated
pollutants and the ACM (active chlorine multiple) used in the first bleaching stage. They
developed an equation which defines a limiting ACM which, for a given percent substitution,
cannot be exceeded and still ensure that final effluent will maintain concentrations of
2,3,7,8-TCDD and 2,3,7,8-TCDF less than 10 ng/L and 30 ng/L, respectively. This equation
(derived in Section 8.3.5) is:
                                              24
                                           150 - %S
                                                     (10)
 where:
       ACML

       %S
limiting active chlorine multiple

Percent chlorine dioxide substitution.
 The Agency analyzed the relationship of the ACM and percent substitution at the U.S. mills
 that  used  high chlorine dioxide  substitution  (without  extended  cooking  or  oxygen
 deh'gnification) and achieved non-detectable final effluent concentrations of 2,3,7,8-TCDD
 and 2,3,7,8-TCDF.  For this analysis, the Agency looked at the ratio of the mill's actual
 ACM, to the limiting ACM  defined in Equation 4:
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                                            9.0 Development of Control and Treatment Options
                              ACM.
ACMA
                              ACML    [24/(150 -
                                                                               (11)
 For data presented in the Canadian study, the ACM ratio was 1; for the U.S. mills, however,
 the ACM ratio averaged 0.9.  This relationship can be represented  as:
                          n n    ACMA
                          0.9 =       A
   ACM.
                                           [24/(150  -
                                   (12)
Solving for %S:
                                %S =  150 -
                                             ACM.
                                  (13)
The ACM ratio less than 1 indicates that the ACM used by U.S. mills was lower than that
theoretically required for the percent substitution they used.  In terms of a fixed ACM, the
U.S. mills used a somewhat higher percent substitution than would be theoretically required
to achieve concentrations of 2,3,7,8-TCDD and 2,3,7,8-TCDF below analytical detection
limits. The Agency used Equation 11 to define the percent substitution technology basis of
Option 2, because it represented practice of the mills for which the Agency had data.

Using Equation 11, a low ACM will require a low percent substitution, and high ACM will
require high substitution.   In fact, for ACMs  greater than 0.432,  the calculated percent
substitution will always be greater than 100 percent. For this case, Option 2 is complete
substitution of chlorine  dioxide for chlorine in the first bleaching  stage.   ACMs for U.S.
bleached papergrade kraft and soda mills were typically between 0.24  and 0.27, resulting in
calculated chlorine dioxide substitutions of 60 to 70 percent and gaseous chlorine multiples
of less than  0.065.
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                                          9.0 Development of Control and Treatment Options
The calculation of percent substitution is illustrated in Example 1:


Example 1
      base case:    Kappaj
                   ACM


             calculated TEC,
From Equation 13, calculate %S
           30
           0.25
           (KappatXACM)
           (30)(ACM) = 7.5 kg C12/100 kg pulp
                        (assuming 0% substitution)
                                                                            (13)
                                         . (0.9X24)

                                             0.25
                                   = 63.6%
 From Equation 9 and the definition of TEC, calculate charges of C1O2 and C12:
                                     2.63 CIO,
                            %S = 	-— x 100
                                  C12 + 2.63 C102
                           %S  = 2.63 C12

                           lOO     TEC,
                                                   (9)
0.636 =
                                  2.63 CIO,
                                  - __
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                                            9.0 .Development of Control and Treatment Options
       C1O2  =     3.53 kg/100 kg pulp

       C12    =     1.23 kg/100 kg pulp
                    (compared to 7.5 kg C12/100 kg without substitution)

 9.4.2.4        Option 3 - Oxygen Delignification or Extended Cooking with Substitution of
              Chlorine Dioxide for Chlorine

 This option includes the reduction of the lignin content (as measured by Kappa number) of
 the pulp entering the first bleaching stage, along with the substitution of chlorine dioxide
 for chlorine in the first bleaching stage.  Lignin reduction may be accomplished with either
 oxygen delignification or extended cooking (batch or continuous) to achieve the following
 target Kappa numbers:
.
softwood pulp
hardwood pulp
Traditional Cooking
Brown Stock Kappa
Number
30
20
Enhanced Delignification
Brown Stock Kappa Number
18
12
Theoretically, the performance of pulping and bleaching processes, hi terms of pollutant
reduction, is essentially the same whether oxygen delignification or extended cooking is used
to reduce the brown stock Kappa number (11).  In analyzing this option, the Agency
assumed that a mill would install whichever of the two technologies would be least
expensive:   extended cooking for mills with a continuous digester that could be easily
retrofitted, and medium consistency oxygen delignification for all other mills (see "Pulp and
Paper Process Change Cost Model Documentation" in the Record for the Rulemaking for
more cost details).

Oxygen deh'gnification, described in Section 8.2.5, uses oxygen gas to remove lignin from
brown stock  pulp after washing in an alkaline environment.  The process includes the
addition of magnesium sulfate (to control delignification), addition of oxidized white liquor
or sodium hydroxide to control pH, and two stages of washing after the oxygen reactor to
completely remove dissolved lignin. Extended cooking, described in Section 8.2.2, may be
conducted in either continuous or batch mode.  Pulp is mixed with the cooking liquor under
modified time, temperature, and alkalinity conditions that dissolve  more  lignin than
traditional continuous or batch cooking without significant fiber  degradation because the
active chemical concentration is kept more uniform throughout the cook.
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                                          9.0 Development of Control and Treatment Options
As discussed in Section 9.4.1.3, options that include pulping and bleaching process changes
also maintain the ACM in the first chlorine bleaching stage. Because ACM is defined as
the ratio of the total equivalent chlorine to the prechlorination brown stock Kappa number,
when oxygen delignification 'or extended cooking are applied prior to bleaching the total
equivalent chlorine required for a constant ACM is reduced. As discussed in Section 9.4.2.3,
the required percent chlorine dioxide substitution depends on the ACM and so is  not
changed by the reduction in prechlorination Kappa number.  However, a lower total mass
dose  of pulping  chemicals is required.  The  relationship  of ACM,  TEC and  percent
substitution is illustrated in Example 2:
Examle 2
       base case:   Kappat
                   ACM
30
0.25
             calculated

after enhanced delignification

                   Kappaj
                   ACM

             calculated TEQ



From Equation 13, calculate %S:
7.5 kg equivalent C12/100 kg pulp
18
0.25

(Kappaa)(ACM)
(18)(0.25)
4.5 kg equivalent C12/100 kg pulp.
                               «8 . 150  -
                                             ACM
                                       (13)
                                   - 150 -
                                              0.25
                                   = 63.6%
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                                           9.0 Development of Control and Treatment Options
 From Equation 9 and the definition of TEC, calculate charges of C1O2 and C12
„„
%S =
                                      2.63 CIO,
                                       + 2.63 C10
                                                   x 100
(9)
                                   2.63 CIO,
                            %S =1 * 10°
where:
                           . _    2.63  CIO.
                           0.636 =  	I
                                      4.5
       C1O2  =     1.09 kg/100 kg pulp

       C12    =     1.63 kg/100 kg pulp
                    (compared to 7.5 kg C12/100 kg without substitution or enhanced
                    delignification).

9.4.2.5       Option 4 -  Oxygen Delignification or Extended  Cooking With Complete
             Substitution of Chlorine Dioxide for Chlorine

This option includes the same reduction in pulp lignin content as specified for Option 3.
However, the direct use of elemental chlorine is eliminated and the current active chlorine
multiple is maintained using chlorine dioxide only. Example 3 continues with the previous
example:

Example 3
      base case:   Kappat
                   ACM
from Example 2:
                   ACM
                   TEQ
          30
          0.25

          18
          0.25
          4.5 kg equivalent C12/100 kg pulp.
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                                          9.0 Development of Control and Treatment Options
For Option 4, %S =  100
from the definition of TEC, calculate the charge of C1O2
                   TEQ
                   4.5
                   C102
                   C12
                               2.63 C102
                               2.63 C102
                               1.71 kg/100 kg pulp
                               0 kg/100 kg pulp
                               (compared to 1.63 kg C12 in Option 3).
9.4.2.6
      Option 5 - Oxygen Delignification and Extended Cooking With Complete
      Substitution of Chlorine Dioxide for Chlorine
This option includes further reduction of the lignin content of the pulp entering the first
stage of bleaching along with the complete elimination of elemental chlorine.  The lignin
reduction is accomplished by using extended cooking (batch or continuous) followed by
oxygen delignification to achieve the following target Kappa numbers:

softwood pulp
hardwood pulp
Traditional Cooking
Brown Stock Kappa
Number
30
20
Extended Cooking Followed
by Oxygen Delignification
Kappa Number
15
10
 As with Option 4, the direct use of elemental chlorine is eliminated and the current active
 chlorine multiple is applied using chlorine dioxide only.  Example 4 continues with the
 previous examples:
 Example 4
base case:    Kappat
             ACM
                                      30
                                      0.25
 after oxygen deh'gnification and extended cooking:
                    ACM
                    TEQ
                                15
                                0.25
                                (KappaaXACM)
                                (15)(0.25)
                                3.75 kg equivalent chlorine/100 kg pulp.
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                                          9.0  Development of Control and Treatment Options
For Option 5, %S = 100
from the definition of TEC, calculate the charge of C1O2
                   TEQ =     2.63 C1O2
                   3.75  =     2.63 C1O2
                   C1O2  =     1.43 kg/100 kg pulp
                                (compared to 1.71 kg C1O2/100 kg pulp in Option 4).

9.4.2.7       Performance of BAT Options for the Bleached Papergrade Kraft and Soda
             Subcategory

Table 9-11 summarizes  the performance of each of the five options discussed above, in
terms of production normalized mass of pollutant discharged from the bleach plant for all
pollutants of concern to  the Agency other than AOX and color. For AOX and color, the
performance of each option is characterized by the final effluent discharge.  The data used
to characterize each option were collected by the Agency during the long-term and short-
term studies described in Section 3.0.

In many cases, some or all of the pollutants of concern were not detected in the analyzed
samples. In these cases  (as discussed in Section 6.4), one-half the reported detection limit
was used to estimate the pollutant mass loading of the sampled waste stream.  In Table
9-11, long-term average loads are footnoted "a" if some of the averaged values were below
the method detection limits; they are marked "ND" if all of the averaged values were below
the method detection limit. For example, the performance of Option 3, in terms of 2,3,7,8-
TCDD discharged from  the bleach plant, is 13 la ng/ADMT, indicating that one or more
sample  measurements were  reported less than the sample-specific detection limit, but
2,3,7,8-TCDD was detected at least once in a bleach plant effluent from an Option 3 mill.
In contrast, the performance of Option 4, in terms  of 2,3,7,8-TCDD discharged from the
bleach plant, is 99.4 ND ng/ADMT.  The "ND" indicates  that 2,3,7,8-TCDD was never
detected in any bleach plant effluent from an Option 4 mill.  The average loading, 99.4
ng/ADMT, was calculated using one-half the detection limit for each sample analyzed.

The  data presented in  Table  9-11  do not distinguish between softwood  or hardwood
furnishes, because the Agency determined that subcategorization based upon furnish was not
appropriate.  Pollutant loadings from softwood mills are somewhat higher than pollutant
loadings from hardwood mills.  For this reason, where possible, the  Agency used the
pollutant loadings from  softwood mills to characterize the BAT options.  Option 1 was
characterized by a mill that pulps and bleached both softwood and hardwood.  All other
options were characterized using  loadings from softwood mills.

Trichlorosyringol is an exception to the trend described above. Trichlorosyringol is typically
detected in  bleach plant effluents from mills  that pulp hardwood.  It is  detected less
frequently, if at all, at mills that pulp softwood using comparable technologies.  Because of

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                                          9.0  Development of Control and Treatment Options
this, the BAT option performance for trichlorosyringol in bleach plant effluent is based upon
the one  hardwood bleach line for which the Agency had data.  Note that  because
trichlorosyringol was  not detected  in the final effluent of any of the mills  used to
characterize the BAT options, regardless of furnish pulped, the final effluent performance
levels for trichlorosyringol were not specifically related to the furnish pulped.

The methodology used to calculate long-term average loads is further discussed in Section
10.0, and in the Statistical Support Document (12).
9.4.2.8
Totally Chlorine-Free Bleaching of Papergrade Kraft Pulp
Worldwide, more than 15 mills produce totally chlorine-free (TCP) Icraft pulp.  But, as
discussed  in  Section  8.3.11,  only  within the  last year has the routine production of
commercial quantities of high brightness (88 to 90 ISO) TCP kraft pulp been implemented.
One mill, located in Sweden, began production of high brightness hardwood pulp bleached
with ozone (and no chlorinated compounds) in September 1992, and began mill trials of
high brightness softwood pulp bleached with ozone (and no chlorinated compounds) in
January 1993. At least two other Scandinavian mills also plan to produce high brightness
TCP softwood kraft pulp within a year (13,14).

The Swedish mill routinely monitors its final effluent for TOC1, chlorate, COD, TSS, BOD7,
color, total nitrogen, total phosphorus, and pH.  In 1990, as part of a special study, they
analyzed one sample of the influent and one sample of the effluent from their wastewater
treatment system for hundreds of pollutants, including those of interest to the Agency. At
the time of that study, the mill was using oxygen delignification  followed by 30 perc'ent
chlorine dioxide substitution to bleach softwood pulp.   These data are included in the
confidential record1 supporting this rulemaking.

The Agency requested but has not obtained data from the Swedish mill that characterize
the effluents  from their ozone bleaching processes. At, this writing, the Agency does not
believe the feasibility of commercial-scale production of TCP softwood kraft pulp has been
fully demonstrated. Because softwood has a higher lignin content than hardwood, it is more
difficult to bleach to high brightness. The Agency did not assume that a technology feasible
for bleaching hardwood was feasible for softwood.   Instead,  the Agency  developed
alternative limitations for mills that  certify they .bleach without chlorine or  chlorine
containing compounds. These alternative limitations apply to mills making products of any
brightness and are discussed further in Section  15.0 of this document.
9.4.2.9
Other Options Considered
                               i
The Agency also developed two other options for this subcategory but could not fully
analyze them due to lack of performance data. One of these options was similar to Option
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                                           9.0 Development of Control and Treatment Options
 2 but included 100 percent chlorine dioxide substitution instead of approximately 70 percent
 substitution.  The other option was similar to Option 5 but included 70 percent chlorine
 dioxide substitution instead of 100 percent substitution,

 One mill produces bleached papergrade kraft pulp without discharging wastewater, directly
 or indirectly, to waters of the United States.  This mill is located in a semi-arid region of
 the U.S. and discharges untreated wastewater to a large surface impoundment.  Because of
 the potential for cross-media impacts (i.e., contamination of soil and groundwater) from the
 practice of impounding wastewater, the Agency did not consider zero discharge of process
 wastewater as best available technology.

 9.4.2.10      Control of COD

 The Agency  developed two BAT options for the control of COD discharges from the
 Bleached Papergrade Kraft and Soda Subcategory. Option A included:

       •     Effective brown stock washing;
                 I
       •     Pulping liquor spill prevention and control; and

       •     End-of-pipe wastewater  treatment  at a level of performance equivalent to
             BPT Option 2.

 Option B included all of the elements of Option A, with the addition of:

       •      Closing the brown stock pulp screen room.

 The performance of each of the two options, in  terms of production normalized mass of
 COD discharge in final effluent, is:

       Option A:    30.0 kg COD/ADMT

       Option B;    21.3 kg COD/ADMT.

The data used to characterize each option were collected by the Agency during the short-
term  studies  described in Section 3.0,  or were submitted  by  mills with their  1990
questionnaire.

With the exception of closing the brown stock pulp screen room, each of the elements of
the two COD control options is also  an element of the technology basis for another
regulation that the Agency is proposing. Effective brown stock washing, described in Section
8.2.3, is an element of all of the BAT options for the control of AOX and toxic pollutants

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                                          9.0 Development of Control and Treatment Options
(see Section 9.4.2.1).  Pulping liquor spill prevention and control, summarized in Section 19
of this document and described  in  detail in  the BMP Technical Support  Document,
comprises BMPs. End-of-pipe wastewater treatment at the level of performance achieved
by the average of the best 50 percent bleached papergrade kraft and soda mills is BPT
Option 2. Because all of the above mentioned  elements were presumed to be in place as
the COD control options were developed, the Agency determined that Option A was not
a distinct option. Therefore only Option B, which adds screen room closure to the above
listed technologies was analyzed as a  separate BAT option.

Screen room closure, described in detail  in Section 8.2.4,  refers to the  elimination of
discharges  of wastewater  from  knotting and screening  operations.   It is  generally
accomplished through reusing screen decker filtrates as pulp dilution ahead of the screens,
or as wash liquor in a preceding stage  of washing. Closing  the screen room can require
significant modification to screening operations.

Oxygen delignification is not  part of the technology basis for COD control, because the
Agency had data for a mill without oxygen delignification that demonstrated performance
(in terms of production normalized mass discharge of COD) as good or better than similar
mills  with oxygen delignification.   However, oxygen delignification will have a positive
impact on reducing COD discharges  (15).  Further, the Agency did not have information
about the cost of screen room closures implemented without simultaneous implementation
of oxygen delignification and so could not analyze the costs of closing screen rooms alone.
For this  reason, the COD control option was only analyzed hi  combination with BAT
Options 3, 4, and 5 described above.  The Agency has solicited data reflecting the cost and
performance of all COD control technologies.
9.4.2.11
Control of Color
The brown color typical of kraft mill effluents is attributable  to the presence of high
molecular weight lignin based compounds (16).  Because these compounds are typically
resistant to biodegradation, color is not significantly reduced by biological treatment (15).
These high molecular weight compounds have also been shown to exhibit toxicity to aquatic
organisms (17). At nulls with good black liquor control, the bleach plant may contribute 80
percent of the total color discharged (16). Oxygen delignification, part of the technology
bases for Options 3, 4, and 5, can reduce the discharge of bleach plant color due  to the
recycle of the organic matter extracted from the pulp to the recovery boiler.  High chlorine
dioxide substitution, both on conventional pulp or oxygen delignified pulp, also reduces the
color discharged from the bleach plant. Laboratory studies have  shown that oxygen
deh'gnification or 100 percent chlorine dioxide substitution can each reduce bleach plant
effluent color by 70 to 75 percent. When used together, the bleach plant effluent color was
reduced  almost 90 percent (15).  Mill performance data confirm that 100 percent chlorine
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                                          9.0 Development of Control and Treatment Options
dioxide substitution1 can reduce color discharges 50 to 80 percent (compared to 0 percent
substitution) (18).

Two end-of-pipe treatment technologies, chemically assisted coagulation and membrane
ultrafiltration, are currently in use on mill scale to reduce effluent color (16). The Agency
did not have sufficient performance data to fully analyze these technologies.

The Agency did not develop separate BAT options for the control of effluent color, but
analyzed the performance of the options  developed for the control of 2,3,7,8-TCDD and
other priority and nonconventional pollutants. The performance of BAT Option 3 could not
be fully characterized, however, due  to lack of data characterizing the impact of process
changes alone on final effluent color.  Table 9-11 summarizes the performance of the other
four options, in terms  of estimated average final effluent color discharge. The Agency has
solicited data reflecting the performance of all BAT options in controlling color.

9.4.3   Dissolving Kraft Subcategory

The Agency found the proces.s technologies and end-of-pipe treatment currently used by the
three mills in the Dissolving Kraft Subcategory were uniformly inadequate for the control
of 2,3,7,8-TCDD,  2,3,7,8-TCDF,  chloroform,  and other  priority  and nonconventional
pollutants. For this reason, the three BAT options for the Dissolving Kraft Subcategory
were developed from  technologies used to produce bleached papergrade kraft pulp. The
Agency determined that the  performance of the technologies, in terms of production
normalized mass of pollutants generated, could also be transferred  from the Bleached
Papergrade Kraft Subcategory to the  Dissolving Kraft Subcategory.

These determinations, and the options considered for the Dissolving Kraft Subcategory, are
described below.

9.4.3.1        Transfer of Options from the  Bleached Papergrade Kraft  and Soda
             Subcategory

The Agency studied the existing pollution control technologies used by each of the three
mills in the Dissolving Kraft Subcategory  and conducted  sampling programs at two of the
three mills.  The three mills use similar bleaching and end-of-pipe wastewater treatment
processes. Table 9-12 presents a summary of the pollutants  discharged by the two sampled
dissolving kraft mills.  Both mills discharged chloroform in final effluents as compared to
non-detect levels achieved by papergrade kraft mills that do not use hypochlorite. 2,3,7,8-
TCDD and 2,3,7,8-TCDF were frequently detected in the final effluent of one mill resulting
in estimated production normalized discharge loadings more than twenty times greater than
the discharge loadings for papergrade kraft Options 3 and 4.  From these results, the Agency
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                                           9.0 Development of Control and Treatment Options
determined that none of the dissolving kraft mills use technologies that adequately control
the discharge of chlorinated pollutants.

The Agency developed three options for the Dissolving Kraft Subcategory from technologies
used to produce  bleached papergrade kraft pulp.  These technologies  include oxygen
delignification, substitution of chlorine dioxide for chlorine in the first bleaching stage, and
elimination of hypochlorite.

Dissolving grade  pulps differ from papergrade pulps in that they contain much higher
percent alpha cellulose, lower percent hemicellulose, and are of a much higher  chemical
purity. Dissolving grade pulps are typically raw materials for chemical processes used to
manufacture viscose, acetate, and other cellulose derivatives.  Thus, the characteristics of
the pulp as used in the chemical process (e.g., viscose viscosity, acetate solution color and
haze) are critical  determinants of pulp  quality. For these reasons, the Agency considered
all  available  information  to determine if the components of the BAT options for  the
Bleached Papergrade Kraft and  Soda Subcategory were feasible for the production of
dissolving grade pulps. At present, there are no mills in the U.S. that use these process
technologies to produce  dissolving kraft  pulp.  However, there is a mill in Brazil that
produces dissolving kraft pulp from pre-hydrolyzed eucalyptus (a hardwood) using oxygen
delignification, 80 percent substitution of chlorine dioxide for chlorine, and up to 3 kg/t
hypochlorite to control viscosity (19).  Although this mill continues to use hypochlorite, it
uses a much lower charge than the U.S. dissolving kraft mills. The Agency also recently has
been provided with conflicting confidential laboratory studies from U.S. mills. One study
indicates that it maybe technically feasible to produce high-grade dissolving kraft pulps from
softwood using oxygen delignification and high chlorine dioxide substitution, while a second
study concludes that oxygen delignification and high chlorine dioxide substitution is  not
technically  feasible.   Many  of the assertions made by individual companies have been
supported with only limited mill trial and wastewater analytical data. Moreover, essentially
no  wastewater, air emissions, sludge, and product quality data have been received for
process technology alternatives  beyond existing technology.   The Agency solicits that
supporting  data; without it, the  commenters' assertions cannot be fully evaluated.  The
Agency is reviewing these  data and will review data from additional studies now underway
as they are provided to the Agency during the comment period for the proposed rule. The
process changes the Agency considered in detail are discussed below.
9.43.2
Common Elements of Dissolving Kraft Options
The BAT options for the Dissolving Kraft Subcategory share the same six common elements
as the Bleached Papergrade Kraft and Soda Subcategory options:
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                                     9.0 Development of Control and Treatment Options



(1)   Adequate wood chip size control;

(2)   Elimination of defoamers and pitch dispersants containing dioxin precursors;

(3)   Brown stock washing to a saltcake loss of 10 kg NasSC^ per ADMT or less;

(4)


(5)

(6)
             Replacing hypochlorite with additional chlorine dioxide bleaching power in
             brightening stages;

             Oxygen and peroxide enhanced extraction; and

             High shear mixing for the addition of chlorine dioxide in the first bleaching
             stage and for addition of oxygen in reinforced extraction.
Each of the options evaluated for the proposed BAT effluent guidelines includes complete
elimination of hypochlorite to minimize the formation of chloroform in the bleach plant.
However, the Agency has  recently received data that mills may not be able to produce
certain high-grade dissolving kraft pulps without the use of hypochlorite to control intrinsic
viscosity.  (Intrinsic viscosity is a measure of the degree of polymerization, proportional to
percent alpha cellulose in the pulp.) The Agency is currently evaluating this information.
9.4.3.3
      Option 1 - Substitution of Chlorine Dioxide for Chlorine
This option is identical to BAT Option 2 for the Bleached Papergrade Kraft and Soda
Subcategory, and  includes replacing some of  the  molecular chlorine  used in the first
bleaching stage  with chlorine dioxide.   As discussed in Section 9.4.2.3,  the amount  of
chlorine dioxide substitution needed to minimize the formation of chlorinated pollutants
depends on the active chlorine multiple^ (ACM) in the first bleaching stage.  For Option 1,
ACMs used by dissolving kraft mills"fesuited in calculated chlorine dioxide substitutions
typically ranging from 50 to 70 percent.                      .

9.4.3.4       Option 2 - Oxygen Delignification With Substitution of Chlorine Dioxide for
             Chlorine

This option, like BAT Option 3 for the Bleached Papergrade Kraft and Soda Subcategory,
includes the reduction of the lignin content of the pulp  entering the first bleaching stage
along with the substitution of chlorine dioxide for chlorine in the  first stage of bleaching.
The target Kappa numbers were identical to  the  target Kappa numbers for Bleached
Papergrade Kraft and Soda Option 3. The option differs from the bleached papergrade
kraft option in that the lignin reduction is accomplished only by using oxygen delignification
(not extended cooking).
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                                          9.0  Development of Control and Treatment Options
9.43.5       Option 3 - Oxygen Delignification With Complete Substitution of Chlorine
             Dioxide for Chlorine

This option includes the same reduction in pulp lignin content as specified in Option 2.  It
is similar to BAT Option 4 for the Bleached Papergrade Kraft and Soda Subcategory except,
as with Dissolving Kraft Option 2, the lignin reduction is accomplished only by using oxygen
delignification.

After this option was developed and analyzed, the Agency received data demonstrating that
100 percent substitution of chlorine dioxide for chlorine may result in unacceptable changes
in pulp viscosity.

9.4.3.6       Performance of BAT Options for the Dissolving Kraft Subcategory

Table 9-13 summarizes the performance of each of the three options discussed above, in
terms of production normalized mass of pollutant discharged from the bleach plant for all
pollutants of concern to  the Agency for all pollutants other than AOX.  For AOX, the
performance of each option is characterized by the final effluent discharge. The data used
to characterize each option were obtained from bleached papergrade kraft mills, and are
identical to data used to characterize Options 2,3, and 4, for the Bleached Papergrade Kraft
and Soda  Subcategory.   Because of the  similarity in processes comprising bleached
papergrade kraft and dissolving kraft BAT options, the  Agency determined  that the
performance of the BAT options was transferable to the Dissolving Kraft Subcategory. Note
that for analyzed pollutants not detected in a sample, one-half the reported detection limit
was used to estimate the pollutant mass loading of the sampled waste stream.
9.4.3.7
Other Options Considered
As discussed in Section 8.3.12, totally chlorine-free bleaching of dissolving grade kraft pulp
has not been demonstrated on a commercial, pilot, or laboratory scale. For this reason, the
Agency  determined that  TCP technologies  could  not be  practically applied in this
Subcategory at this time.  Further, because the processes and chemicals used to produce
dissolving sulfite pulp  are  not the same as the processes and chemicals used to produce
dissolving kraft pulp, the Agency determined that the transfer of the technology bases and
performance of the dissolving sulfite BAT options to the Dissolving Kraft Subcategory was
not appropriate.

As discussed in Section 9.4.3.2 above, the Agency has received some data indicating that
dissolving kraft pulps cannot be produced without the use of hypochlorite to control intrinsic
viscosity. The Agency began to develop an alternative technology option for the control of
chloroform formation, based on high-temperature, high-pH hypochlorite bleaching discussed
in Section 8.3.8.  However, because data characterizing the performance of this technology

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                                           9.0 Development of Control and Treatment Options
 (in terms of production normalized mass discharge of chloroform and other pollutants in
 bleach plant effluents) were not available at the  time the proposal was developed, this
 option was  not fully analyzed.  As additional laboratory trial data are submitted to the
 Agency during the comment period for the proposed rule, the feasibility and performance
 of high-temperature, high-pH hypochlorite bleaching will be further evaluated.
9.4.3.8
Control of COD
The Agency developed one BAT option for the control  of COD discharges from the
Dissolving Kraft Subcategory. This option included:

       •     Effective brown stock washing;

       •     Pulping liquor spill prevention and control;

       •     Closing the brown stock pulp screen room; and

       •     End-of-pipe wastewater treatment at  a level  of performance equivalent to
             BPT Option 2.

The performance of this option, in terms of production normalized mass of COD discharge
in final effluent, is 70.3 kg COD/ADMT. The data used to characterize this option were
collected by the Agency during a short-term study, as described in Section 3.0.

With.the exception of closing the brown stock pulp  screen room, each of the elements of
the COD  control option is also an element of the technology basis for another regulation
that the Agency is proposing. Effective brown stock washing, described in Section 8.2.3, is
an element  of all of the BAT options for  the control of  AOX and other priority and
nonconventional pollutants.  Pulping liquor spill prevention and control, described in detail
in the BMP  Document, comprise BMP.  End-of-pipe wastewater treatment at the level of
performance achieved by the average of the best 50 percent dissolving kraft mills is BPT
Option 2.

Screen room closure, described in detail in Section  8.2.4, refers to  the elimination of
discharges of wastewater  from the knotting and screening operations.  It is  generally
accomplished through reusing screen decker filtrates as pulp dilution ahead of the screens,
or as wash liquor on a preceding stage of washing.  Closing the screen room can require
signification modification to screening operations.

Oxygen delignification is not part of the technology basis for COD control, because the
Agency had  data for a mill without oxygen delignification that demonstrated performance
(in terms of production normalized mass discharge of COD) as good or better than similar

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                                          9.0 Development of Control and Treatment Options
mills with oxygen delignification.  However, oxygen delignification will have a positive
impact on reducing COD discharges (14). Further, the Agency did not have information
about the cost of screen room closures implemented without simultaneous implementation
of oxygen delignification and so could not analyze the costs of closing screen rooms alone.
For this  reason, the COD  control option was only analyzed in combination with BAT
Options 2 and 3, described above.

9.4.4  Unbleached Kraft Subcategory
9.4.4.1
Control of COD
The Agency developed one BAT option for the control of COD discharges from the
Unbleached Kraft Subcategory.  This option includes:

       •     Effective brown stock washing;

       •     Pulping liquor spill prevention and control;

       •     Closing the brown stock pulp screen room; and

       •     End-of-pipe wastewater treatment at a level of performance equivalent to
            BPT Option 2.

The performance of this option, in terms of production normalized mass of COD discharge
in final effluent, is 20.8 kg COD/ADMT. The data used to characterize this option were
submitted by unbleached kraft mills in response to the 1990 questionnaire.

Two of the elements of the COD control option are also elements of the technology basis
for another regulation that the Agency is proposing.  Pulping liquor spill prevention and
control, described in detail in the BMP Document, comprise BMP. End-of-pipe wastewater
treatment at the level of performance achieved by the average of the best 50 percent
unbleached kraft mills is BPT Option 2.

Effective brown stock washing, described in detail in Section 8.2.3, is washing that achieves
a 99 percent recovery of pulping chemicals from the pulp (washing loss of less than 10 kg
Na2SO4 per ADMT of pulp).  Washing efficiency can be improved by replacing existing
washers with new equipment, or adding additional stages of washing.

Screen room closure,  described in detail in Section 8.2.4, refers to  the elimination of
discharges of wastewater from the screening operation. It is generally accomplished through
reusing screen decker filtrates as pulp dilution ahead of the screens, or as wash liquor on
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                                           9.0 Development of Control and Treatment Options
a preceding stage of washing. Closing the screen room can require significant modification
to screening operations.

9.4.5  Dissolving Sulfite Subcategory

The Agency developed two BAT options for the Dissolving Sulfite Subcategory.  These
options are described below.

9.4.5.1       Option  1 - Oxygen Delignification With Complete Substitution of Chlorine
             Dioxide for Chlorine (Retaining Hypochlorite)

This option is  similar to BAT Option 4 for the Bleached Papergrade Kraft and Soda
Subcategory in that it includes the reduction of the lignin content of the pulp entering the
first bleaching stage along with 100 percent substitution of chlorine dioxide for chlorine in
the first stage of bleaching.  The option differs from the bleached papergrade kraft option
in terms of the method of lignin reduction, which is accomplished only by using oxygen
deh'gnification  (not  extended cooking).   The  target Kappa  number  after oxygen
delignification is 5 for all mills.

Of the  six elements common to the bleached papergrade kraft options,  as described in
Section 9.4.2.1, three are shared by Dissolving Sulfite Subcategory Option 1:

       (1)    Adequate wood chip size control;

       (2)    Elimination of defoamers and pitch dispersants containing dioxin precursors;
             and

       (3)    High shear mixing for the addition of chlorine dioxide in the first bleaching
             stage.

Improvements in brown stock washing were not considered to be part of the in-plant process
changes assessed for BAT, because the relationship between the performance of oxygen
delignification and the performance of brown stock washing is not as well documented for
sulfite pulping as it is  for kraft pulping.

Unlike BAT Option 4  for the Bleached Papergrade Kraft and Soda Subcategory, Dissolving
Sulfite Option  1 retains  the use of hypochlorite  for bleaching because the option was
designed to reflect technologies in use at a dissolving sulfite miH for which the Agency has
performance data. The Agency has no performance data representing the use of oxygen
delignification and 100 percent chlorine dioxide to bleach dissolving sulfite pulp without the
use of hypochlorite.
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9.4.5.2
                                          9.0 Development of Control and Treatment Options.
Option 2 - Totally Chlorine-Free Bleaching:  Oxygen Delignification, Ozone,
and Peroxide Bleaching
No U.S. mills use totally chlorine-free (TCP) bleaching to produce dissolving sulfite pulp.
This option is based on the TCP bleaching processes used by a European dissolving sulfite
mill, and does not include the use of hypochlorite.  The technology bases for this option are:

      (1)   Adequate wood chip size control;

      (2)   EUmination of defoamers and pitch  dispersants containing dioxin precursors;

      (3)   Oxygen delignification to reduce the lignin content of pulp entering the first
            stage of bleaching to a target Kappa number of 5; and

      (4)   Ozone and peroxide bleaching.

9.4.53      Performance and Demonstration Status of BAT Options for the Dissolving
            Sulfite Subcategory

Table 9-14 summarizes the performance of each  of the options discussed above, in terms
of production normalized mass of pollutant discharged from the bleach plant for  all
pollutants of concern to the Agency other than AOX and color.  For AOX and  color, the
performance of each option is characterized by the final effluent discharge. The  data used
to characterize Option 1 were collected by the Agency during the long-term and short-term
studies described in Section 3.0. Npte that for analyzed pollutants not detected in a sample,
one-half the reported detection limit was used to estimate the pollutant mass loading of the
sampled waste stream.

The data used to characterize Option 2 are limited to production  normalized loadings of
AOX in mill final effluent. The Agency has data from one European dissolving sulfite mill
indicating that AOX loading of 0.04 kg AOX/ADMT are achievable. However, the Agency
has  characterized the performance  of this option as 0.1 kg AOX/ADMT, because on a
subcategory-wide basis it does not believe the performance at dissolving sulfite mills will
exceed the performance at papergrade sulfite mills.  The Agency requested but was unable
to obtain performance data, in terms of production normalized  mass discharges of all
pollutants of concern, from the European mill. However, because chlorine and chlorine-
containing compounds are not used at this mill, and because the AOX loadings are very low,
the  Agency believes that concentrations of individual  chlorinated  compounds are not
detectable.  At this time, the Agency has no data  to characterize the discharges of acetone
and methyl ethyl ketone from the European mill and  thus has  no way to predict the
performance of Option 2 with regard to these pollutants.
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                                           9.0  Development of Control and Treatment Options
As discussed in Section 8.3.13, totally chlorine-free bleaching of dissolving grade sulfite pulp
has been demonstrated at only one mill. That mill produces viscose grade pulp used for the
production of staple fibers (i.e., textile grade viscose).  A comparison of the properties of
this TCF-bleached viscose grade pulp and traditionally bleached acetate grade sulfite pulps
is presented below.
Dissolving Sulfite Pulps
Grade
Furnish
Bleach
Critical Pulp Properties
% Alpha Cellulose (R10)
% Hemicellulose (S,8)
% Extractives(a)
% Ash ,
ISO Brightness
Intrinsic Viscosity (dL/g)
Cleanliness (parts/m2)
Viscose Staple
European Beech
0D, E«pZF

90.5 - 91
MR
NR
<0.6
90-92
NR
<45
Acetate (20)
Western Hemlock
Traditional

95.3
2.9
0.04
0.09
94
9.0
NR
Acetate Plastic <2«)
Southern Pine
Traditional

97.0
1.6
0.03
0.01
94
8.8
NR
(a)Extractives soluble in ethyl ether.
NR - Not reported.
As listed above, the TCF-bleached viscose grade pulp had a lower alpha cellulose content
(i.e., lower purity) and lower brightness than required for acetate grade pulps. Contacts at
the mill producing TCP viscose grade pulp reported to EPA that their ozone-based TCP
bleaching technology can be used to produce other grades without the degradation of pulp
quality (21).  At this time, the Agency has not received data confirming this report.

The Agency has recently received preliminary data from one company indicating that, to
date, they had been unsuccessful in producing high purity TCP pulps or pulps made by the
selected option in laboratory trials. These data are in the Record for the Rulemaking. The
Agency encourages further efforts (laboratory and mill trials) at adapting TCP bleaching
technologies  to the production of acetate-grade pulps. Many of the assertions made by
individual  companies have  been supported with only limited mill trial and wastewater
analytical data.  Moreover,  essentially no wastewater, air emissions, sludge, and product
quality  data have  been received for process  technology alternatives beyond existing
technology. The Agency solicits that supporting data; without it, the commenters' assertions
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                                           9.0 Development of Control and Treatment Options
cannot be folly evaluated.  EPA does, however, consider TCP bleaching to be an available
technology for many products made within this subcategory at this time. As additional data
are submitted to the Agency during the comment period for the proposed rule, the Agency
will evaluate the need for developing separate options and  limitations  within this
subcategory based upon pulp grade.
9.4.5.4
Other Options Considered
The Agency developed one additional option for this subcategory but could not folly analyze
it  due to lack of performance  data.  This  option  consisted of nunimal (20  percent)
substitution of chlorine dioxide for chlorine in the first bleaching stage.  Similar changes in
bleaching processes for kraft pulps have resulted in minimal reductions in pollutants beyond
existing practices.  For this  reason, the Agency did not pursue this option.
9.4.5.5
Control of COD
The Agency  developed one BAT option for the control of COD discharges from the
Dissolving Sulfite Subcategory.  This option included:

       •      Effective brown stock washing;

       •      Pulping liquor spill prevention and control;

       •      Closing the brown stock pulp screen room; and

       •      End-of-pipe wastewater treatment at a level of performance equivalent to
             BPT Option 2.

Because  the  Agency did not have data at the  time of proposal  to characterize the
performance  of this option, it was not folly analyzed.  However, the Agency has solicited
data and will consider developing COD limitations when appropriate data are available.

9.4.6   Papergrade Sulfite Subcategory

The Agency developed two BAT options for the Papergrade Sulfite Subcategory. These
options are described below.

9.4.6.1       Option 1 - Oxygen Delignffication With Complete Substitution of Chlorine
             Dioxide for Chlorine  (Eliminating Hypochlorite)

This option is similar  to BAT Option 4 for the  Bleached Papergrade Kraft and  Soda
Subcategory in that it includes the reduction of the lignin content of the pulp entering the

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                                           9.0 Development of Control and Treatment Options
first bleaching stage along with 100 percent substitution of chlorine dioxide for chlorine in
the first stage of bleaching. The option differs from the bleached papergrade kraft option
in terms of the method of lignin reduction, which is accomplished only by using oxygen
delignification  (not extended cooking).   The target  Kappa  number  after  oxygen
delignification is 18 for softwood and 11 for hardwood.

Of the six elements common to the bleached papergrade kraft options, as described in
Section 9.4.2.1, four are shared by Papergrade Sulflte Subcategory Option 1:

      (1)    Adequate wood chip size control;

      (2)    Elimination of defoamers and pitch dispersants containing dioxin precursors;

      (3)    High shear mixing for the addition of chlorine  dioxide in the first bleaching
             stage; and

      (4)    Elimination of hypochlorite (by replacement with chlorine dioxide, only).

Improvements in brown stock washing were not considered to be part of the in-plant process
changes assessed for BAT, because the relationship between the performance of oxygen
delignification and the  performance of brown stock washing is not as well documented for
sulfite pulping as it is for kraft pulping. Also, oxygen and peroxide reinforced extraction
were not included in this option because the Agency did not have data to characterize the
performance of this process change.

9.4.6.2       Option 2 - Totally  Chlorine-Free Bleaching:  Oxygen Delignification and
             Peroxide  Bleaching

The technology bases for this option are:

      (1)    Adequate wood chip size control;

      (2)    Elimination of defoamers and pitch dispersants  containing dioxin precursors;

      (3)    Oxygen delignification to reduce the lignin content of pulp entering the first
             stage of bleaching to Kappa number 18 (for softwood) or 11 (for hardwood);

      (4)    Elimination of hypochlorite; and

      (5)    Peroxide  bleaching.
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                                          9.0 Development of Control and Treatment Options
9.4.63
Performance of BAT Options for the Papergrade Sulfite Subcategory
Table 9-15 summarizes the performance of each of the options discussed above, in terms
of production normalized mass  of pollutant discharged  from the bleach plant  for all
pollutants of concern to the Agency other than AOX and color. For AOX and color, the
performance of each option is characterized by the final effluent discharge. The data used
to characterize Option 1 were collected by the Agency during the long-term and short-term
studies described in Section 3.0. Note that for analyzed pollutants not detected in a sample,
one-half the reported detection limit was used to estimate the pollutant mass loading of the
sampled waste stream.

The data used to characterize Option 2 are presented in  Section 8.3.14.  These data are
limited to production normalized loadings of AOX, BOD, and COD in final effluent. Some
of the pollutants  were analyzed using test  methods that are not necessarily directly
comparable with U.S. standard analytical results.  The Agency requested but was not able
to obtain performance  data, in terms  of production normalized mass  discharges of all
pollutants of concern from these mills.

One mill, which bleached less than 100 percent of its pulp by TCP processes, reported a
final effluent AOX load of 0.5 kg/metric ton.  All other mills reported final effluent AOX
loads of 0.1 kg/metric ton or less (four mills reported AOX loadings of approximately zero,
but did not provide actual test results). The Agency determined that a final effluent loading
of 0.1 kg/ADMT was characteristic of  the performance of TCP bleaching of papergrade
sulfite pulp.

The Agency believes that concentrations of individual chlorinated compounds are not
detectable in effluents from TCP papergrade sulfite bleaching processes, because chlorine
and chlorine-containing compounds are  not used. Also, the Agency has no data at this time
to characterize the discharges of acetone and methyl ethyl ketone and cannot predict the
performance of Option 2 with regard to these pollutants.

During the development of these proposed rules, the Agency received comments and some
trial data  from individual mills  concerning the  feasibility of TCP processes  and the
papergrade products that can and cannot be made by these processes. Commenters asserted
that certain processes (e.g., ammonium-based) yielding specific products and specifications,
and certain specialty papers and pulps (e.g., photographic papers and plastic molding pulps)
have not yet been made by the TCP processes without changes in pulp properties that are
not acceptable to  mill  customers.  Many of the assertions made by individual companies
have been supported with only limited mill trial and wastewater analytical data. Moreover,
essentially no wastewater, air emissions,  sludge, and product quality data have been received
for process technology alternatives beyond existing technology. The Agency solicits that
supporting data; without it, the commenters'  assertions cannot be fully evaluated.

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                                           9.0 Development of Control and Treatment Options
9.4.6.4
Other Options Considered
The Agency developed one other option for this subcategory but could not fully analyze it
due to lack of performance data. This option consisted of reducing the charge of chlorine
(C12) in the first bleaching stage and implementing oxygen and peroxide-enhanced extraction.
Similar changes in bleaching processes for kraft pulps have resulted in minimal reductions
in pollutants beyond existing practices.  For this reason, the Agency did not pursue this
option.
9.4.6.5
Control of COD
The Agency developed one BAT option for  the  control of COD discharges from the
Papergrade Sulfite Subcategory.  This option included:

       •      Effective brown stock washing;

       •      Pulping liquor spill prevention and control;

       •      Closing the brown stock pulp screen room; and

       •      End-of-pipe wastewater treatment at a level of performance equivalent to
             BPT Option 2.

The performance of this option, in terms of production normalized mass of COD discharge
in final effluent, is 63.7 kg COD/ADMT.  The data used to characterize this option were
provided by a U.S.  papergrade  sulfite  mill as a follow-up to an engineering  site visit
conducted by the Agency.

Two of the elements of the COD control option are also elements of the technology basis
for another regulation  that the Agency is proposing.  Pulping liquor spill prevention and
control, described in detail in the BMP Document, comprises BMP. End-of-pipe wastewater
treatment at the level of performance  achieved by the average of the best 50 percent
papergrade sulfite mills is BPT Option 2.

Effective brown stock washing, described in detail in Section 8.2.3, is washing that achieves
a 99 percent recovery of pulping chemicals from  the pulp.  Washing efficiency can be
improved by replacing existing washers with new equipment, or adding additional stages of
washing.

Screen room closure, described  in detail in Section 8.2.4, refers to  the elimination of
discharges of wastewater from the screening operation. It is generally accomplished through
reusing screen decker filtrates as pulp dilution  ahead of the screens, or as wash liquor on

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                                          9.0 Development of Control and Treatment Options
a preceding stage of washing.  Closing the screen room can require significant modification
to screening operations.

9.4.7  Semi-Chemical Subcategory
9.4.7.1
Control of COD
The Agency developed one BAT option for the control of COD discharges from the Semi-
Chemical Subcategory. This option included:

       •      Effective brown stock washing;

       •      Pulping liquor spill prevention and control; and

       •      End-of-pipe wastewater treatment at a level of performance equivalent to
             BPT Option 2.

Screening is usually not practiced at semi-chemical mills; therefore, closed screen room
operation was not included as part of the technology basis  for COD control. Data that
characterize the performance of this option are not available.   However,  the  Agency
transferred performance data from the Unbleached Kraft Subcategory as the basis for the!
proposed effluent limitations. The pulping processes in the Unbleached Kraft Subcategory
are similar to those used in the  Semi-Chemical Subcategory, and therefore the  Agency
concluded that the data transfer is appropriate.

Two of the elements of the COD control option are also elements of the technology basis
for another regulation that the Agency is proposing. Pulping liquor spill prevention and
control, described in detail in the BMP Document, comprises BMP. End-of-pipe wastewater
treatment at the level of performance achieved by the average of the best 50 percent semi-
chemical mills is BPT Option 2.

Effective brown stock washing, described in detail in Section 8.2.3, is washing that achieves
a 99 percent recovery of pulping chemicals from the pulp.  Washing  efficiency can be
improved by replacing existing washers with new equipment, or adding additional stages of
washing.

9.5    NSPS

9.5.1   Introduction

New Source Performance Standards (NSPS) are effluent limitations guidelines that establish
quantitative limits on the direct discharge of conventional, priority, and nonconventional

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                                           9.0 Development of Control and Treatment Options
pollutants from new industrial point sources.  Definitions of new sources, specific for the
Pulp, Paper, and Paperboard Point Source Category are presented in Section 16.0.  NSPS
limits, like BPT, BCT, and BAT limits,  are based upon the performance of specific
technologies, but do  not require  the  use of any specific technology.   NSPS effluent
limitations guidelines are applied to individual facilities through NPDES permits issued by
EPA or authorized states under Section 402 of the CWA  The facility then chooses its own
approach to complying with  its permit limitations.

This section describes  the development of the NSPS options and presents the Agency's
determinations as to  the demonstration status of each option.  The general  approach
followed by the Agency for developing NSPS options for subcategories with proposed BAT
effluent limitations guidelines (Subparts A, B, C, D, E, and F) was, where appropriate, to
evaluate the best demonstrated processes for  control of priority and nonconventional
pollutants at the process level, and, best demonstrated end-of-pipe treatment for control of!
conventional pollutants and additional control of certain priority and nonconventional
pollutants.  For subcategories where BAT effluent limitations guidelines are not' being
proposed, the Agency evaluation  was  directed at the best demonstrated  conventional
pollutant control technology, which, with the exception of on0 segment of the Secondary
Fiber Non-Deink Sub'category, comprises flow minimization and primary treatment followed
by effective secondary biological treatment. For manufacture of paperboard and builders'
paper and roofing felt from non-deink secondary fiber, the Agency determined that the best
demonstrated  conventional  pollutant control  technology  was  complete  recycle of all
wastewater.

The Agency determined that the best demonstrated processes are those that result in the
minimum generation  of pollutants of concern (i.e.,  the  priority  and nonconventional
pollutants proposed for regulation at BAT) that can be used to produce the full range of
products currently produced by existing facilities.  The Agency does not intend to select
NSPS that would prevent manufacture of certain products. The Agency determined that the
best demonstrated conventional pollutant control technologies are those that result in the
rninimum discharges of conventional pollutants  as generally represented  by  the best
performance by an existing mill in each subcategory.
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                                                9.0 Development of Control and Treatment Options
Pollutants proposed for regulation at NSPS are summarized, by subcategory, below:
Subcategory
Dissolving Kraft '
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical Pulp
Non-Wood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-Deink
A. Paperboard, builders' paper and
roofing felt
B. Other products from non-deinked
secondary pulp
Fine and Lightweight Paper from
Purchased Pulp
Tissue, Filter, Non-Woven and Paperboard
from Purchased Pulp
Chlorinated
and Volatile
Compounds, at
the Bleach
Pbattft)
X
X(b)

X
(e)





X(f)



AOX
X
(c)
t
X
X





X(f)



"* J " i
COB
X
(d)
X
(d)
X
X




X(f)



BODsand
JSS
X
X
X
X
X
X
X
X
X

X(f)
X
X
X
 (a)2,3,7,8-TCDD, 2^,7,8-TCDF, chloroform, MEK, acetone, methylene chloride, and 12 chlorinated phenolic
   compounds.
 (b)The Agency is not proposing NSPS limitations for chloroform, MEK, or 4,5,6-trichloroguaiacol for this
 subcategory at this time.
 (c)The Agency is not proposing NSPS limitations for AOX for this subcategory at this time.
 (d)The Agency is not proposing NSPS limitations for COD for this subcategory at this time.
 (e)No specific limitations:  certification that no chlorine-containing compounds are used to bleach.
 (QBased upon no discharge of wastewater.

 Note that the Agency is not proposing NSPS for color in any subcategory at this time.
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                                           9.0 Development of Control and Treatment Options



9.5.2  Dissolving Kraft Subcategory

The process change components of the NSPS options considered by the Agency for the
Dissolving Kraft Subcategory are the same as those considered for BAT, and include the
process change components for COD control. These options are fully described in Section
9.4.3.  In addition, the NSPS options add components for conventional pollutant control,
based upon the  single best performing mill in the Subcategory. The NSPS options are
summarized below:

      Elements Common to Each NSPS Option

      •      Wood chip size and thickness control;

      •      Use of dioxin precursor-free  defoamers and pitch dispersants;

      •      Effective brown stock washing;

      •      Closed pulp screening operations;

      •      Pulping  liquor spill prevention and control;

      •      Use of chlorine dioxide instead of hypochlorites in brightening stages;

      •      Oxygen- and peroxide-enhanced extraction in the bleach plant;

      •      High shear mixing for addition of bleaching chemicals in the first bleaching
             stage and for addition of oxygen in reinforced extraction;

      •      Flow minimization (process water reuse and recycle); and

      •      Best demonstrated end-of-pipe secondary wastewater  treatment.

      Option 1  -   Substitution of Chlorine Dioxide for Chlorine

      Option 2  -   Oxygen  Delignification with Substitution of  Chlorine Dioxide for
                   Chlorine

      Option 3  -   Oxygen Delignification with Complete Substitution of Chlorine Dioxide
                   for Chlorine (no direct use of elemental chlorine)

The Agency determined that process technologies and end-of-pipe wastewater technologies
used by existing U.S. dissolving  kraft mills are uniformly inadequate for purposes of

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                                          9.0 Development of Control and Treatment Options
developing BAT options.   Consequently, the Agency transferred  certain BAT process
technology options from the 'Bleached Papergrade Kraft and Soda Subcategory to the
Dissolving  Kraft Subcategory.  The Agency is  using  the  process technology options
developed for the proposed BAT effluent limitations guidelines for this subcategory as NSPS
process technology options  as well.  The performance of each NSPS option, in terms of
production normalized mass of pollutant discharged in bleach plant effluents, is based upon.
performance of the pulping and bleaching technologies.  The performance of each NSPS
option, in terms of production normalized mass of pollutant discharged in final effluent, is
based upon performance of the pulping and bleaching process technologies and performance
of the best demonstrated end-of-pipe wastewater treatment technologies.

The combination of pulping and bleaching technologies  that form the bases of the NSPS
options are not currently used by any U.S. producer of dissolving  kraft pulps; however,
similar  technologies, including oxygen delignification and 80 percent chlorine dioxide
substitution are used at a Brazilian dissolving kraft mill.  The Agency determined that this
technology is applicable to U.S. mills.

Table 9-16 lists the performance of each NSPS option, in terms of production normalized
mass load  of pollutant discharged from the  bleach  plant for chlorinated and volatile
compounds of concern  to the Agency.  For  AOX, color, COD, and the  conventional
pollutants,  each option is characterized by the  final effluent discharge.

9.53  Bleached.Papergrade Kraft and Soda Subcategory

The process change components of the NSPS options considered by the Agency for the
Bleached Papergrade Kraft and Soda Subcategory are the same as BAT Options 4 and 5.
These options are fully described in Sections 9.4.2.5 and 9.4.2.6.  The NSPS options also
include the process change components for COD control, described in Section 9.4.2.10. In
addition, the NSPS options add components for conventional pollutant control, based upon
the single best performing mill in the subcategory.  For the Bleached Papergrade Kraft and
Soda Subcategory, the Agency also considered options based on ozone bleaching with
chlorine dioxide brightening and a TCP option, but could not fully analyze these options due
to lack of performance data at this time.

There are 10 common elements for all considered NSPS options, listed below:

      Elements Common to Each NSPS Option

      •     Wood chip size and thickness control;

      •     Use of dioxin precursor-free defoamers and pitch dispersants;
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                                          9.0 Development of Control and Treatment Options



             Effective brown stock washing;

             Closed pulp screening operations;

             Pulping liquor spill prevention and control;

             Oxygen- and peroxide-enhanced extraction in the bleach plant;

             Use of chlorine dioxide instead of hypochlorite in brightening stages;

             High shear mixing for addition of bleaching chemicals in the first bleaching
             stage and for addition of oxygen in reinforced extraction;

             Flow minimization (process water  reuse and recycle); and

             Best demonstrated end-of-pipe secondary wastewater treatment.
      Option 1 -   Oxygen  Delignification  or  Extended  Cooking  with  Complete
                   Substitution of Chlorine Dioxide for Chlorine (no  direct use of
                   elemental chlorine).  Same  as BAT Option 4.

      Option 2 -   Oxygen  Delignification  and  Extended  Cooking with  Complete
                   Substitution of Chlorine Dioxide for Chlorine (no  direct use of
                   elemental chlorine).  Same  as BAT Option 5.

Option 1 is equivalent to BAT Option 4; Option 2 is equivalent to BAT Option 5, and is
typical of new greenfield market kraft pulp mills constructed in the United States during the
past few years. The process technologies are suitable for manufacture of high brightness (88
to 90 GE, 86 to 88 ISO) market grades of hardwood and softwood pulps,  and represent the
best demonstrated process technologies for production of market pulp.  The end-of-pipe
performance  levels for  conventional pollutants are based upon the best demonstrated
performance of the mills in this subcategory.

Table 9-17 presents the performance data available to characterize the two NSPS options.
Performance  is characterized in terms of production normalized mass  load of pollutant
discharged from the bleach plant for chlorinated and volatile compounds of concern to the
Agency.   For AOX, color, COD, and the conventional  pollutants, each option  is
characterized by the final effluent discharge.
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                                          9.0 Development of Control and Treatment Options



Based on current understanding of the formation of pollutants during pulping and bleaching,
the mass discharges for Option 2 should be lower than the mass discharges for Option 1.
This is not the case for the following pollutants:

       •      Chloroform;

       •      Methyl ethyl ketone;

     •  •      4,5,6-Trichloroguaiacol; and

       •      AOX.

The Agency believes that these results are attributable to site-specific characteristics of the
mills whose performance data were used to characterize each option.
9.53.1
Other Options Considered
The Agency developed two other NSPS options for this subcategory but could not fully
analyze them at this time due to lack of performance data.  These options include the
common elements for Options 1 and 2, described above, with these additional elements:

       Option 3 -   Oxygen  Delignification  and  Extended  Cooking  with Complete
                   Substitution of  Ozone for Chlorine  (Chlorine  Dioxide used in
                   brightening stages); and

       Option 4 -   Oxygen Deh'gnification and Totally Chlorine-Free Pulp Bleaching.

Option 3 is similar in many respects to the ozone bleaching system installed at a southern
U.S. mill in September 1992.  The process technology for this option  includes  oxygen
delignification of conventionally delignified pulps followed by a ZEOPD bleach sequence.
The process technology is capable of producing 82 to 84 GE (80 to 82  ISO) brightness
softwood pulp. To date, manufacture of commercial quantities of high brightness (88 ISO)
market grades of softwood pulp using ozone bleaching has not been demonstrated in the
United States or abroad.

Option 4 comprises oxygen deh'gnification of conventionally delignified pulps followed by
a totally chlorine-free QEOPPPS bleach sequence. This technology is similar to that installed
at a west coast mill, also in September 1992. The technology is capable of producing 75 to
80 ISO brightness softwood pulp.  To date, Option 4 has not been demonstrated to be
feasible for the production of full brightness pulps. The Agency has requested data for this
option.
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                                           9.0 Development of Control and Treatment Options
The Agency did not consider either Option 3 or 4 fully demonstrated at this time, because
it does not have data to fully characterize the options. However, the Agency and the mill
which uses Option 3 technology recently completed a cooperative sampling program, and
some data from this sampling program are available in the Record for the Rulemaking.
Additional, thorough engineering and statistical analysis of these data and any preliminary
limitations developed from  them, will  be  made available at a later date for review and
comment.  The Agency has requested additional data for this option.

The Agency  developed alternative limitations for  mills that certify they bleach without
chlorine or chlorine-containing compounds. These limitations would be applicable to a mill
using Option 4 technology and are further discussed in Section 16.0.

9.5.4 Unbleached Kraft Subcategory

For the Unbleached Kraft Subcategory, the Agency is proposing to regulate COD,  BOD5,
and TSS at NSPS.  One NSPS option was developed based upon the following process and
wastewater treatment technologies:

      •     Effective brown stock washing;

      •     Closed pulp screening operations;

      •     Pulping liquor spill prevention and control;

      •     Flow minimization (process water reuse and recycle); and,

      •     Best demonstrated end-of-pipe secondary wastewater treatment.

These technologies have been widely  demonstrated across chemical  pulp  mills in this
industry and are readily incorporated in new mills in this Subcategory.  The Agency was not
able to identify other technologies for controlling COD, and therefore concluded that this
combination of technologies  represents  the best available demonstrated technology for the
control of COD.

The Agency determined that all of the pulping, flow minimization, and wastewater treatment
technologies used as the basis for the NSPS option are demonstrated for purposes of the
CWA. The performance of  this NSPS option, in terms of production normalized mass of
pollutant discharged in final  effluent, is listed below:
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                                          9.0  Development of Control and Treatment Options
COD
BOD5
TSS
20.8 kg/ADMT
0.24 kg/OMMT
0.69 kg/OMMT
9.5.5  Dissolving Sulfite Subcategory

The process change components of the NSPS options considered by the Agency for the
Dissolving Sulfite Subcategory are the same as those considered for BAT. These options
are fully described in Section 9.4.5, in addition, the NSPS options  add components for
conventional pollutant control.

      Elements Common to Each NSPS Option

      •      Wood chip size and thickness control;

      •      Use of dioxin precursor-free  defoamers and pitch dispersants;

      •      Closed pulp  screening operations;

      •      Effective brown stock washing;

      •      Pulping liquor spill prevention and control;

      •      Oxygen delignification;

      •      High shear mixing for addition of bleaching chemicals in the first stage of
             bleaching;

      •      Flow minimization (process water reuse and recycle); and

      •      Best demonstrated end-of-pipe secondary wastewater treatment.

      Option 1 -  Complete Substitution of Chlorine Dioxide for Chlorine (no direct use
                   of elemental chlorine  but use of hypochlorite).

      Option 2 -  TCP Bleaching with Ozone and Peroxide.
                                        9-68

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                                           9.0 Development of Control and Treatment Options



Option 1 is similar to the dissolving sulfite bleaching technology used by a U.S. dissolving
sulfite/papergrade sulfite  mill.  Option 2 is similar to the dissolving sulfite bleaching
technology used by an Austrian dissolving sulfite mill.

The Agency determined that all of the pulping, flow minimization, and wastewater treatment
technologies used as the basis for the NSPS options are demonstrated for purposes of the
CWA.  The Agency determined that the bleaching technologies  for NSPS Option 1 are
demonstrated for purposes of the  CWA,  The Austrian dissolving sulfite mill does not
produce the highest purity grades of dissolving sulfite pulp produced at some U.S. mills, and
thus this technology  (and NSPS Option 2) has not been fully demonstrated as yet for all
grades of dissolving sulfite pulp produced in the U.S. EPA does, however, consider TCP
bleaching to be an available and demonstrated technology for many products within this
subcategory at this time.  The Agency will consider prior to promulgation whether this
subcategory should be further divided, based on product specifications or otherwise, for
purposes of establishing NSPS. Table 9-18 lists the performance of the two NSPS options,
in terms of production normalized mass load of pollutant discharged from the bleach plant
for chlorinated and volatile compounds of concern to the Agency. For AOX, color, and the
conventional pollutants, the options are characterized by the final effluent discharge.

9.5.6  Papergrade Sulfite Subcategory

The process change  components of the NSPS  options  considered by the Agency for the
Papergrade Sulfite Subcategory are the same as those considered for BAT. These options
are fully described in Section 9.4.6. In addition, the NSPS options add components for
conventional pollutant control.  There are eight common elements for the two NSPS options
listed below:

      Elements Common  to Each  NSPS Option

      •      Wood chip size and thickness control;

      •      Use of dioxin precursor-free defoamers and pitch dispersants;

      •      Closed  pulp screening operations;

      •      Effective brown stock washing;

      •      Pulping liquor spill prevention and control;

      •      Oxygen delignification;

      •      Flow minimization (process water reuse and recycle); and

                                       9-69

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                                          9.0 Development of Control and Treatment Options
      •     Best demonstrated end-of-pipe secondary wastewater treatment with extended
            residence time secondary clarification.

      Option 1 -   Complete Substitution of Chlorine Dioxide for Chlorine (no direct use
                   of elemental chlorine or hypochlorite).  Chlorine dioxide is added
                   using high shear mixing.

      Option 2 -   TCP Bleaching with Peroxide.

Option 1 is similar to the papergrade sulfite bleaching technology used by the same west
coast dissolving suffite/papergrade sulfite mill noted above. There are no U.S. papergrade
sulfite mills with bleaching operations similar to Option 2.  This technology is, however,
being used at a number of European papergrade sulfite producers (see Section 8.3.14). The
extended  residence  time  secondary  clarification performance is demonstrated  at  a
papergrade sulfite mill located in the midwest.

The Agency determined  that all  of the pulping,  bleaching, flow minimization,  and
wastewater treatment technologies used as  the basis for the NSPS options are demonstrated
for purposes of the CWA.  Table 9-19 lists the performance of the two NSPS options, in
terms of production normalized mass load of pollutant discharged from the bleach plant for
chlorinated and volatile compounds of concern to the Agency.  For AOX, color, COD, and
the conventional pollutants, the options are characterized by the final effluent discharge.

9.5.7 Semi-Chemical Subcategory

For the Semi-Chemical Subcategory, the Agency is proposing to regulate COD, BOD5, and
TSS at  NSPS.  One NSPS option was developed based upon the  following process and
wastewater treatment technologies, which, are the same technologies used as the basis of
the proposed BAT effluent limitations guidelines, with the addition of components for
conventional pollutant control:

      •     Effective brown stock washing;

      •     Pulping h'quor spill prevention and control;

      •     Flow minimization (process  water reuse and recycle); and,

      •     Best demonstrated end-of-pipe secondary wastewater treatment.

The Agency determined that all of the pulping, flow minimization, and wastewater treatment
technologies used as the basis for the NSPS option are demonstrated for purposes of the
CWA. As discussed in Section 9.4.7, however, the Agency did not have data to characterize

                                       9-70

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                                          9.0 Development of Control and Treatment Options
the BAT technology basis for COD control  for the  Semi-Chemical Subcategory and
determined  that the performance of the  Unbleached  Kraft Subcategory COD control
technologies could be transferred to the Semi-Chemical Subcategory.  The performance of
this NSPS option, in terms of production normalized mass of pollutants discharged in final
effluent, is listed below:
COD
BOD5
TSS
20.8 kg/ADMT
0.41 kg/OMMT
0.55 kg/OMMT
9.5.8  Mechanical Pulp Subcategory
      Non-Wood Chemical Pulp Subcategory
      Secondary Fiber - Deink Subcategory
      Fine and Lightweight Papers from Purchased Pulp Subcategory
      Tissue, Filter, Non-Woven, and Paperboard from Purchased Pulp Subcategory

For each of the above-listed subcategories,  the Agency is proposing to regulate  the
conventional pollutants BOD5, and TSS at NSPS. The Agency is not proposing NSPS for
priority and nonconventional pollutants for these subcategories, pending further study (see
Section  7.4).  One NSPS option  was developed for each Subcategory based upon  the
following process and wastewater treatment technologies:

      •      Flow minimization (process water reuse and recycle); and

      •      Best demonstrated end-of-pipe biological wastewater treatment.

The single mill in each Subcategory with the best demonstrated performance was used to
characterize long-term average performance levels associated with these technologies. The
Agency determined that the flow minimization and wastewater treatment technologies used
as the basis for the NSPS option are demonstrated for purposes of the CWA.  Table 9-20
presents  the long-term  average   NSPS performance levels  for  each  of  these five
subcategories.

9.5.9  Secondary Fiber Non-Deink Subcategory

The Agency is proposing NSPS for conventional pollutants for the Secondary Fiber Non-
Deink Subcategory.  The Agency is also proposing NSPS for priority and nonconventional
pollutants for a portion of this Subcategory.
                                       9-71

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                                          9.0 Development of Control and Treatment Options
For purposes of these proposed NSPS, EPA divided this subcategory into two segments.
Segment A comprises those mills that produce paperboard, builders' paper, or roofing felt.
Segment B comprises those mills that produce other products. The decision to segment this
subcategory was based upon EPA's finding that many mills making paperboard, builders'
paper, or roofing felt operate with complete recycle of wastev/ater.  EPA lacked reliable
data to indicate that mills producing other products  commonly operated with complete
recycle, or that complete recycle of wastewaters  was a  demonstrated technology for
producers of these other products.

Based upon responses to the 1990 questionnaire and other information, EPA concluded that
21 mills in this subcategory operate with complete recycle of process wastewater. Of these
21 mills, 15 mills manufacture paperboard from wastepaper,  and six mills manufacture
builders' paper and roofing felt.  Complete recycle is defined as; a system where the sum of
fresh  water and  water entering the system in raw materials is  equal to the sum of water
exiting the system via evaporation/vaporization, water in the final  product, and water
included in any rejects streams from screening, including sludges.  There is no direct or
indirect discharge of wastewater .to surface waters, nor is there any land application, surface
impoundment or other land disposal of wastewater effluents.
9.5.9.1
Paperboard, Builders' Paper, and Roofing Felt Segment
This segment includes production of paperboard, builders' paper, and roofing felt from
wastepaper that has not undergone deinking processes. The Agency developed and analyzed
two regulatory  options for NSPS for this segment of the Secondary Fiber Non-Deink
Subcategory as follows:

      Option 1 -   Flow Minimization with Best Demonstrated End-of-Pipe Secondary
                   Wastewater Treatment.

      Option 2 -   Complete Recycle of Wastewater.

Option 1 is similar to the NSPS options the Agency considered for other subcategories. The
performance of this option is based on the single mill in the segment which achieves the
lowest production normalized mass discharge of BOD5.

Option 2, complete recycle of wastewater, is based upon practices used by 21 mills in this
segment. These practices include:

      •      Screening of wastewater from stock preparation,  and reuse and recycle to
             paper machine;

      •      Use of savealls and screens to remove fiber from white water;
                                       9-72

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                                          9.0 Development of Control and Treatment Options
      •      Clarification of combined mill wastewaters and recycle to pulping and paper
             machine; and

      •      High-capacity storage for recycled wastewater.

Option 1 controls the discharge of conventional pollutants. Option 2 controls the discharge
of all pollutants (conventional* priority, and nonconventional).  The performance of
Option 1, in terms of production normalized mass of pollutants discharged in final effluent,
is listed below:
BOD5
TSS •
0.05 kg/OMMT
0.17 kg/OMMT
9.5.9.2
Producers of Other Products from Non-Deink Secondary Fiber Segment
This segment includes production of secondary fiber products that have not undergone
deinking processes, except for production of paperboard, builders' paper, and roofing felt
from wastepaper that has not undergone deinking processes.  These products include tissue
and molded products.

The Agency found no reliable evidence that zero discharge is achieved on a consistent basis
at mills in this segment of the Secondary Fiber Non-Deink Subcategory. One NSPS option
for the control  of -conventional pollutants was developed.  The technology basis for this
option is:

       •      Flow minimization (process water reuse and recycle);  and

       •      Best demonstrated end-of-pipe secondary wastewater treatment.

The Agency determined that all of the pulping, flow minimization, and wastewater treatment
technologies used as the basis for the NSPS options are demonstrated for purposes of the
CWA. The performance of the identified option, in terms of production normalized mass
of pollutants discharged in final effluent, is listed below:
BOD5
TSS
0.19 kg/OMMT
0.46 kg/OMMT
                                       9-73

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                                           9.0 Development of Control and Treatment Options
9.6    PSES

Pretreatment Standards for Existing Sources (PSES) establish quantitative limits on the
indirect discharge of priority and nonconventional pollutants to waters of the United States;
that is, PSES limits industrial discharges to Publicly Owned Treatment Works (POTWs).
PSES are designed to prevent the discharge of pollutants which pass through, interfere with,
or  are otherwise  incompatible  with  the operation of POTWs.   The CWA requires
pretreatment for pollutants that pass through POTWs in amounts that would exceed direct
discharge effluent limitations or limit POTW sludge management alternatives, including the
beneficial use of sludges on agricultural lands. Pretreatment standards are to be technology-
based and analogous to BAT for removal of priority and nonconventional pollutants. Like
BAT, PSES do not require the use of any specific technology. Reference is made to the
general pretreatment regulations (40 CFR Part 403), which served as the framework for the
proposed pretreatment standards for the pulp, paper, and paperboard industry.

The Agency's general approach for  developing  PSES options for subcategories with
proposed BAT effluent limitations guidelines that have indirect discharging mills (Bleached
Papergrade Kraft and Soda, Unbleached Kraft, Papergrade Sulfite and Semi-Chemical) was
to use the BAT options as PSES options for  control of priority  and  nonconventional
pollutants at the process level, and,  equivalent BPT Option 2 technologies for additional
control of certain nonconventional pollutants at the point of discharge from the indirect
discharger  to the receiving POTW.  For  subcategories where  BAT effluent h'mitations
guidelines are not being proposed for priority and nonconventional pollutants, and for the
Dissolving Kraft and Dissolving Sulfite Subcategories, which have no indirect dischargers,
the Agency is proposing to reserve PSES.

9.6.1   Pass-Through Analysis

To determine whether pollutants indirectly discharged by mills in this industry pass through
POTWs, EPA reviewed sampling data for direct dischargers, performance  data for POTWs,
and technical literature.  Based  on  preliminary review of circumstances at some of  the
POTWs receiving pulp and paper mill effluent, and EPA's best professional judgment, EPA
concludes  that  biological  treatment systems  at these POTWs,  while  designed  to
accommodate pulp and paper wastewaters, are not designed to the same standards as those
installed and operated at direct discharging mills.  Activated sludge systems and aerated
stabilization basin systems, as, designed and operated at direct discharging mills, typically
include substantially longer detention times and other features that, in combination, achieve
greater removals of BOD5 and TSS than are achieved at POTWs receiving effluent from
these mills.  This is evidenced by the fact that the BPT and BCT effluent limitations EPA
is proposing for certain subcategories are substantially more stringent than the secondary
treatment effluent limitations applied to most POTWs (30 mg/L each of BOD5 and TSS).
Therefore, the Agency concludes that BOD5 and TSS pass-through these POTWs. However,
EPA is not proposing pretreatment standards for BOD5 and  TSS.
                                       9-74

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                                           9.0 Development of Control and Treatment Options
In addition, the Agency concluded that other pollutants, including AOX, COD, and color,
also pass through POTWs. In part, this is because nonconventional pollutants typically are
less biodegradable  than  the conventional  pollutants  (BOD5 and  TSS).   For  example,
biological treatment systems at direct discharging pulp and paper mills (for which EPA has
data)  remove approximately 40 percent of the influent AOX, which is representative of
chlorinated organic  compounds (specific chlorinated organic compounds generally are less
biodegradable than  nonchlorinated biodegradable organic matter measured as BOD5).

As noted in Section 9.4.2.11, the brown color typical of kraft mill effluents is attributable
to the presence of high molecular weight lignin based compounds that are typically resistant
to biodegradation (14,15). The Agency does not have detailed analytical data from POTWs
for these and other pollutants of concern in this industry to serve as the basis for a detailed,
quantitative pass-through analysis. However, in view of the lower removal of conventional
pollutants achieved  at POTWs in comparison to the removals being proposed for direct
dischargers in this industry, the Agency concludes that certain chlorinated phenolics, AOX,
COD, and  color also pass through these POTWs.

9.6.2  PSES Options

The Agency considered three  options for PSES. Two of these options would set bleach
plant and final effluent limitations equivalent to the BAT limitations for direct dischargers.
The options differ in the  point of application of the limitations.  Option 1 would set final
effluent limitations at the mill  discharge to the POTW. Option 2 would transfer the final
effluent limitations to the POTW discharge. Option 3 would set no national standards, but
would allow pretreatment authorities to determine local limitations for the mills  and
POTWs. Table 9-21 summarizes these  alternatives and notes the pollutants regulated at
each point. Each option  is discussed in more detail below.
9.6.2.1
Option 1 - Final Effluent Limitations at Mill Discharge
Option 1 would set effluent limitations on the same pollutants controlled with BAT limits
for direct dischargers, at the point of discharge from the indirect discharging mill to the
industrial POTW  (for AOX, COD, and for the Bleached Papergrade Kraft  and Soda
Subcategory, color) as well as at certain internal bleach plant wastewater streams (for 18
chlorinated and volatile compounds). These limitations were developed based on the same
technologies as BPT Option 2 and COD control technologies for all subcategories for which
the Agency is proposing PSES.  The PSES limitations were also based on BAT Option 4 for
the Bleached  Papergrade  Kraft and  Soda Subcategory, and BAT  Option  2 for  the
Papergrade  Sulfite Subcategory.  PSES at these points would prevent pass through of
pollutants, help control sludge contamination, and reduce air emissions.  This option is
based upon  complete secondary treatment of mill wastewater prior to its discharge to the
POTW.
                                       9-75

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9.63,3,
                                          9.0 Development of Control and Treatment Options
Option 2 - Final Effluent Limitations at the POTW Discharge
Option 2 may  provide a more cost-effective way of obtaining the effluent reductions
obtained under Option 1.

Under Option 2, EPA would establish PSES limits identical to those established under
Option 1. However,'EPA would also provide that, in the event the POTW receiving a mill's
discharge voluntarily accepted certain limits in a legally enforceable NPDES permit, that
mill would no longer be subject to those PSES limits that apply at the mill's discharge to the
POTW's sewer.  (The bleach plant limits would still apply.) The additional limits in the
POTW's permit would cover all pollutants for which  the mill would otherwise have had
PSES limits at the point of discharge to the sewer, and would in each case need  to be at
least as stringent as the BAT limits applicable to direct dischargers in the subcategory.  In
calculating the POTW's limits, the percentage of the POTW's flow from domestic sources
and from industrial sources  other than pulp, paper, and paperboard mills would also be
considered.
9.63,3
Option 3 - No National PSES
The Agency also considered a third option under which EPA would not promulgate PSES
limits for these mills.   Under this option,  pretreatment authorities  would use  best
professional judgment to develop local limits for the mills and end-of-pipe limits for the
industrial POTWs. The Agency is concerned that this would impose difficult or unrealistic
administrative burdens on POTWs.  This option also may not achieve the same levels of
discharge by the industrial POTWs as for direct dischargers.

9.7   PSNS

Pretreatment Standards for New Sources (PSNS) establish quantitative limits on the indirect
discharge of priority and nonconventional pollutants to waters of the United States.  Section
307(c) of the CWA requires EPA to promulgate PSNS at the same time it promulgates
NSPS.   New indirect discharging  mills, like new direct discharging  mills,  have  the
opportunity to incorporate the best available demonstrated technologies, including process
changes, in-plant controls, and end-of-pipe treatment technologies.

As discussed in Section 9.6, above, EPA determined that a broad range of pollutants
discharged by pulp and paper mills (including CDDs, CDFs, AOX, BOD5, and TSS)  pass
through POTWs.  The same technologies discussed previously for BAT, NSPS, and PSES
are available as the basis for PSNS.
                                       9-76

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                                            9.0  Development of Control and Treatment Options
The Agency considered options equivalent to the options considered for NSPS, discussed
in Section 9.5, for the following subcategories:

             Dissolving Kraft;
             Bleached Papergrade Kraft and Soda;  .
             Unbleached Kraft;
             Dissolving Sulfite;
             Papergrade Sulfite; and
             Semi-Chemical.'

Although the options considered for PSNS are identical to NSPS, the pollutants controlled
differ slightly: PSNS does not control conventionals.  The pollutants for which the Agency
is proposing PSNS are listed below, by subcategory and control point:
Siibcategory
Dissolving Kraft
Bleached Papergrade
Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Bleach Plant Effluent
18(a)
15(b)
None
18(a)
None(c)
None
Mia Discharge to POTW
AOX, COD
None(b)
COD
AOX
AOX, COD
COD
(a)2,3,7,8-TCDD, 2,3,7,8-TCDF, 4 volatiles and 12 chlorinated phenolic compounds.
(b)Insufficient data to propose PSNS for chloroform, MEK, 4,5,6-trichloroguaiacol, AOX, or COD.
(c)No specific limitations: certification that no chlorine-containing compounds are used to bleach.

9.8    References

1.     U.S. EPA, Office  of  Air  Quality Planning  and  Standards.   Pulp,  Paper,  and
       Paperboard Industry - Background Information for Proposed Air Emission Standards
       (Manufacturing Processes at Kraft, Sulfite, Soda, and Semi-Chemical  Mills), EPA
       453/R93-050a, U.S. Environmental Protection Agency, Research Triangle Park,
       North Carolina, October 1993.

2.     Economic  Impact  and  Regulatory  Flexibility  Analysis of  Proposed  Effluent
       Guidelines and NESHAP for the Pulp, Paper, and Paperboard Industry, EPA 821-
       R93-021.
                                        9-77

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                                          9.0 Development of Control and Treatment Options
3.    Regulatory Impact Assessment of Proposed Effluent Guidelines and NESHAP for
      the Pulp, Paper, and Paperboard Industry, EPA 821-R93-020.

4.    Federal Register, 51 FR 24974, July 9, 1986.

5.    Harris, R.W., M.J. Cullinane, and P.T. Sun, eds. Process Design and Cost Estimating
      Algorithms for the Computer Assisted Procedure for Design and Evaluation of
      Wastewater Treatment Systems  (CAPDET).   United  States  Army Engineer
      Waterways Experiment Station, Vicksburg, Mississippi, 1982. (Prepared for the U.S.
      Environmental Protection Agency).

6.    Singh, R.P., ed. The Bleaching of Pulp. TAPPI Press, Atlanta, Georgia, 1979. p. 15.

7.    Allen, L.H, R.M. Berry, B.L. Fleming, C.E. Luthe, and R.H. Voss. Evidence That
      Oil-Based Additives are Potential Indirect Source of the TCDD and TCDF Produced
      in Kraft Bleach Plants. Eighth International Symposium on Chlorinated Dioxins and
      Related Compounds, Umea, Sweden, August 21-26, 1988.

8.    Voss, R.H., C.E. Luthe, B.L. Fleming,  R.M.  Berry, and L.H. Allen.  Some New
      Insights into the Origins of Dioxins Formed During Chemical Pulp Bleaching.  In:
      Proceedings for the 1988 CPPA Environment Conference, Vancouver,  BC Canada,
      October 25-26, 1988.

9.    Hise, R.G., R. Streisel, and A.B. Bills.  The Effect of Brownstock Washing, Split
      Addition of Chlorine and pH Control on the C-Stage Formation of AOX and
      Chlorophenols During  Bleaching.    In:    Proceedings  of  the  TAPPI  1992
      Environmental Conference, Richmond, Virginia, April 12-15. pp. 1135-1142.

10.    Luthe, C.E., P.E.  Wrist, and R.M. Berry. An Evaluation of the Effectiveness of
      Dioxins Control Strategies on Organochlorine Effluent Discharges from the Canadian
      Bleached Chemical Pulp Industry.  Pulp & Paper Canada, 93:9, 1992.

11.    Personal communication with Stromberg, Bertyl Kamyr.

12.    U.S. EPA, Office of Water.  Statistical Support Document for Proposed Effluent
      Limitations Guidelines and Standards for the Pulp, Paper, and Paperboard Point
      Source Category.  November 1993.

13.    Korhonne, H. and S. Hiljanen. Enocell's New Pulp Mill Started Up. PPI, May, 1993.

14.    Kukkonen, K. and I. Reilama. Experiences and Conclusions with TCF Bleaching at
      Metsa-Botnia. Presented at the 1993  Non-Chlorine Bleaching Conference,  Hilton
      Head, South Carolina, March 15-18, 1993.
                                      9-78

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                                          9.0 Development of Control and Treatment Options
15.    Graves, J.W., T.W. Joyce and H. Jameel. Effects of Chlorine Dioxide Substitution,
      Oxygen Delignification and Biological Treatment on Bleach Plant Effluent, TAPPI
      Journal, 76:7, July 1993.

16.    NLK Consultants,  Inc.  Colour  Reduction Technology on Kraft Mill Effluents.
      Prepared for Alberta Environment, Edmonton, Alberta, September 1992.

17.    Higashi, R.M., et al.  A Polar High Molecular Mass Constituent of Bleached Kraft
      Mill Effluent Is Toxic to  Marine Organisms.  Environmental Science & Technology,
      26(12):2413-2420, 1992.

18.    Effects of Chlorine Dioxide Substitution on Bleach Plant Effluent BOD and Color.
      Technical Bulletin No. 630.   National Council of the Paper Industry for Air and
      Steam Improvement, Inc.,  March 1992.

19.    Personal communication with Celso Foelkel, New York, September 13, 1993.

20.    Ingruber,  O.V., M.J. Kocurek, and A. Wong.  Pulp and Paper Manufacture (Third
      Edition):  Volume 4 - Sulfite Science and Technology. Hink, J.L., R.L. Casebier, J.K.
      Hamilton, eds. Joint Textbook Committee of the Paper Industry, TAPPI, Technology
      Park, Atlanta, Georgia and CPPA, Montreal, Quebec, Canada, 1985.

21.    Personal Communication with Walter Peter, Lenzing, Austria, October 28-29, 1993.
                                       9-79

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                                            I
                                            "a

                                            f
                                            E
1/Sra '

                 9-80

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             Table 9-1
BPT Candidate Mills By Subcategory



Observation
Number
BPT
Option
1
Mitt?
(Y/N)
BPT
Option
2
Mill?
<*/**>
Current
&OJ>3
Effluent
Ixoad
(kg/OMMT)

Current TSS
Load
Effluent

-------
 Table 9-1




(Continued)



Observation
Number
BPT
Option
1
Mill?
07N)
BF3T
Option
• 2
MM?
(Y/N)
Current
BODs
Effluent
Load
(kg/OMMT)

Current tSS
Load
Effluent
(bg/0MMT)


Wastewater
treatment
**&*



"
Comments
Bleached Paper-grade Kraft and Soda Subcategory (Continued)
29
30
31
32
33
Y









• 5.53
5.55
5.69
5.70 .
6.68
6.88
4.56
9.64
8.62
9.79
B
B
S
B
B





Unbleached Kraft Subcategory
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y


Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
i









0.24
0.56
1.18
1.31
1.52
1.59
1.63
1.70
1.79
1.83
1.86
1.89
1.98
1.99
2.27
2.28
2.34
2.46
2.62
2.80
0.68
0.72
2.99
2.49
2.66
3.92
6.06
3.20
2.69
2.85
3.55
3.22
1.96
3.57
2.67
2.12
5.04 '
1.44
2.36
4.44 .
B
B
B
B
B
B
S
S
B
B
B
B
B
B
B
B
S
B
B
B










Combined WWTP (2
mills)








Dissolving Sulfite Subcategory
1
2
3
Y


(a)
(a)
(a)


nd


nd
S
S
B



       9-82

-------
 Table 9-1




(Continued)



Observation
Number
BPT
Option
1
Mitt?

-------
 Table 9-1




(Continued)



Observation
Number
BPT
Option
1
M«l?
(Y/N)
BPT
Option
2
Mill?
(Y/N)
Current
BOJ>5
Effloent
Load
(kg/OMMT)

Current TSS
Load
Effluent
(kg/QMMT)
-

Wastexvater
Treatment
T^I»e
f ."i.



Comments
Non-Wood Chemical Pulp Subcategory
1
2
3
Y
Y
Y


nd

nd

nd

Combined WWTP (5
mills)
Secondary Fiber Deink Subcategory
1
2
3
4
5
6
7
8
9
10
11
12
13
14
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y


Y
Y
Y
Y
Y
Y
Y







0.89
0.94
1.03
1.05
1.11
2.15
2.65
2.76
3.27
3.72
4.05
4.67
6.44
7.63
0.92
0.86
1.67
1.40
2.22
1.73
1.72
10.70
0.42
3.78
6.09
5.81
6.27
4.66
S
B
S
S
S
S
S
S
B
S
B
S
S
S














       9-84

-------
 Table 9-1




(Continued)



Observation
Number
BPT
Option
1
Mill?
(Y/N)
BPT
Option
2
Mill?

-------
                                          Table 9-1

                                         (Continued)



Observation
Number
BPT
Option
1
Mitt?
(V/N)
BPT
Option
2
Mill?
: (V/N)
Current
BOJ>S
Effluent
Load
(fcg/OMMT)
ii*vi *- "•
Current IBS
Load
Effluent
(kg/OMMT)


Wastewater
Treatment
lE^jrpe

,

^
Comments
Tissue, Filter, Non-Woven and Paperboard from Purchased Pulp Subcategory
1
2
3
4
5
6
7
8
9
10
Y
Y
Y
Y
Y
Y
Y
Y
Y

Y
Y
Y
Y
Y





0.25
0.27
0.46
0.69
1.60
1.74
1.77
1.79
3.09
6.74
0.18
0.41
0.17
2.43
3.32
0.22
2.87
1.45
4.42
2.44




ND















(a)Best performing mill methodology was not used for developing limitations for BPT Option 2 for the Dissolving Sulfite
   Subcategory.
 B - Mills that operate secondary wastewater treatment in basins.
 S - Mills that operate secondary wastewater treatment in activated sludge systems or a combination of activated
    sludge systems and basins.
nd - Not disclosed to prevent compromising confidential business information.
                                                  9-86

-------
                                   Table 9-2
            Summary of Mills in the Semi-chemical Subcategory
Observation
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
Current BOD5
Effluent Load
(kg/OMMT) ;
0.37
0.41
0.85
1.18
1.24
1.31
1.43
1.74
1.76
1.98
2.28
2.30
2.40
2.62
9.41
nd
nd
Percentage of Final
Production in the.
Semi-Chemical
Subcategory
m
76
26
37
72
49
76
52
78
41
78
65
69
65
60
62
10
18
Representative of
Secondary
Treatment in the
Semi-Chemical
Subcategory?
(¥/N)
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
N
N
nd - Not disclosed to prevent compromising confidential business information.
                                       9-87

-------
                                   Table 9-3
          Summary of Mills in the Papergrade Sulfite Subcategory
Observation
Number
1
2
3
4
5
6
7
8
9
10
Current BOD5
Effluent Load
(kg/OMMD
2.69
3.37
3.92
4.42
4.80
7.09
8.48
13.70
nd
nd
Percentage of Final
Production in the
Papergrade Sulfife
Subcategory
(%>
48
43
42
37
49
85
86
96
33
37
Representative of
Secondary
Treatment in the
Papergrade Sulfite
Subcategory?
(Y/N)
Y
Y
Y
Y
Y
Y
Y
Y
N
N
nd » Not disclosed to prevent compromising confidential business information.

-------
                     Table 9-4
Summary of Mills in the Mechanical Pulp Subcategory
Observation
Nmmher
1
2
3
4
5
6
7
8
9
Carres* BOD^
Effluent Load
(kg/OMMT)
0.16
0.30
0.53
0.54
0.65
1.11
1.93
2.71
3.60
Percentage of Final
Production in the
Mechanical
Subcategory
(%)
61
55
56
62
<50
54
83
86
87
Representative of
Secondary
treatment in the
Mechanical Palp
Subcategory?
(1f/N>
Y
Y
Y
Y
Y
Y
Y
Y
Y
                       9-89

-------
                                  Table 9-5
      Summary of Mills in the Non-Wood Chemical Pulp Subcategory





Observation
Number
1
2
3
4




Current BOB5
Effluent Load
(kg/OMMT)
nd
nd
nd
nd


Percentage of Final •
Production in the No'm-
Wood Chemical
Subcategory
(%>
100
30
30
3
Representative of
Secondary
Treatment in the
Non-Wood
Chemical Pulp
Subcategory?

-------
       Table 9-6
BPT Performance Levels
Subcategory
Dissolving Kraft
Bleached Papergrade Kraft
and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical Pulp
Non-Wood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-deink
Fine and Lightweight
Papers from Purchased Pulp
Tissue, Filter, Non-woven,
and Paperboard from
Purchased Pulp
Number of Mills
Representing
Secondary
Wastewater
Treatment
Performance in
Subeategory
3
33
20
3
8
15
9
3
1 14
28
i 8
10
BWT Option 1
Performance Level
flig/OMMT) :
BOJDj
3.66
2.66
1.69
16.67
4.97
1.48
,0.99
1.67
2.36
0.65
2.30 .
1.30
TSS ;
4.62
4.47
2.74
39.72
5.46
2.28
2.18
2.40
3.11
0.70
1.45
1.72
BPT Option 2
Performance Level
(kg/OMMT)
BOJ>5
3.51
1.57
1.32
11.74
3.60
0.97
0.38
1.59
1.40
0.36
1.59
0.63
TSS
4.85
2.72
2.57
9.44
4.74
1.96
1.35.
2.03
1.50
0.53
1.23
1.29
         9-91

-------
                                       Table 9-7

                 Production Normalized Flows Required to Meet
                          BPT BOD5 Performance Levels
Subcategory
Dissolving Kraft
Bleached Papergrade Kraft and
Soda
Unbleached Kraft
i
Dissolving Sulfite
Papergrade Sulfite
i
Semi-Chemical
Mechanical Pulp
Non-Wood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-Deink
i
Fine and Light Weight from
Purchased Pulp
Tissue, Filter, Nonwoven and
Paperboard from Purchased Pulp
- Option 1
Maximum
FIow(a)
(raVOMMl}
166
409
158 .
233
1 126
81
2,106
145
311
407
152
325
Option 2
Maximum
F!ow
-------
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                                             9-101

-------
                                    Table 9-9

            Activated Sludge Treatment System Performance and
                       Design and Operating Parameters
Observation
Number
%BOD5
Removal
Detention
Time
(hrs)
FtM
Ratio
MLSS
(mg/JL>
Aeration
Intensify
(hp/1,00
Om3)
%TSS
Removal
Secondary
Clarifier
Overflow
Rate
(myday/m2)
Chemical Pulp MillsCb")
l(a)
2
3
4
5
6
7
8
98
97
96
93
93
91
89
80
16
3.3
8.7
84
60
7.7
11
4.6
0.37(a)
0.4
0.3
0.19
0.08
0.45
0.20
0.74
NR
3,000
NR
800
1,800
NR
3,100
4,600
178(a)
108
109
5.6
NR
39
75
954
85
97
93
87
84
95
92
83
7.6(a)
22
8.7
15
NR
11
21
20
Non-Pulpers(c)
1
2
3
4
5
93
ib
71
61
MR
19
30
130
'34
9.3
• 0.3
0.06
NR
NR
NR
5,000
2,000
NR
NR
NR
NR
NR
NR
, 108
NR
98
95
97
87
97
22
8.0
15
NR
83
Mechanical Pulp
1
2
3
4
5
98
97
	 1" 	
93
92
53
5.4
3.6
NR'
5.0
19
0.22
0.3
NR
NR
0.08
NR
4,200
NR
3,000
2,900
37
20
NR
NR
46
99
99
98
97
89
14
21
20
20
12
(a)Reprcsents the average of two parallel treatment systems.
(b)Includes four bleached papergrade kraft and soda, two unbleached kraft, and two papergrade sulfite mills.
(concludes two secondary fiber deink and three purchased pulp mills.
NR - Not reported.
                                        9-102

-------
                                     Table 9-10

                 Aerated Stabilization Basins Performance and
                        Design and Operating Parameters
Observation
Number
* BOJ>5
Removal
%m
Removal
Detention
Time
Pays)
BOD, Loading
(ikg/day/acre)
: Aeration
Intensity
(hp/l,000m3)
Chemical Pulping Mills (a)
1
2
3
4
5
6
7
8
9
10
11
12
96
95
94
92
91
89
88
87
77
65
MR
MR
96
98
91
93
95
, 91
86
92
88
-13
95
88
14
NR
, ' 43
35
NR
62
14 .
22
8
NR
6.2
4.7
NR
370
360
NR
1,200
55
482
300
460
NR
370
NR
350
70
NR
184
6.51
28
8.7
83
NR
NR
3.5
4.2
Non-Pulpers(b)
1
2
3
4
5
6
.89
86
84
79
71
5.3
86
85
86
MR
97
63
NR
7.5
8.2
6.5
3.3
5.0
NR
NR
200
260
375
NR
NR
NR
27
NR
NR
NR
(a)Includes 3 bleached papergrade kraft and soda, 3 unbleached kraft, 1 papergrade sulfite, and 5 semi-chemical
   mills.
(b)Includes 1 secondary fiber non-deink, 2 fine and lightweight paper from purchased pulp, and 3 tissue, filter,
   non-woven and paperboard from purchased pulp mills.
NR - Not reported.
                                         9-103

-------
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                                                     9-108

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                                                       9-112

-------
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                                             9-114

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                                                 9-116

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                                              9-122

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                              9-123

-------

-------
                                                      10.0 Pollutant Reduction Estimates
10.0  POLLUTANT REDUCTION ESTIMATES

10.1  Introduction

This section describes the Agency's estimates of the reduction in the mass of pollutants that
would be discharged from pulp and paper mills after the implementation of each technology
option considered for the proposed regulations.  For each mill and pollutant, a baseline
mass loading was compared to the mass that would be discharged after implementation of
the various technology options; the difference between these two loadings is the pollutant
reduction.  Pollutant reduction estimates are discussed separately below for conventional
pollutants,  priority  and nonconventional pollutants (except chemical oxygen demand
(COD)), and COD.

In all of the estimates, the loadings are production normalized. A production normalized
load is the product of a pollutant concentration and a wastewater flow rate divided by one
of three production normalizing parameters (PNPs):

      1)    The PNP  for Best Practicable Control Technology (BPT)/Best Conventional
            Pollutant  Control Technology (BCT) for BOD5 and  TSS  is the off-the-
            machine production rate (including additives and coatings, at off-the-machine
            moisture for paper and paperboard  and at 10 percent moisture for market
            pulp).

      2)    The PNP for Best Available Control Technology Economically Achievable
            (BAT)/Pretreatment Standards for Existing Sources (PSES) for priority and
            nonconventional pollutants (except COD and color) is the production rate (at
            10 percent moisture) of unbleached pulp that is bleached.

      3)    The PNP for  BAT/PSES for  COD and color is the unbleached  pulp
            production rate (at 10 percent moisture).

10.2  Conventionai Pollutants

This section presents the Agency's estimates of conventional pollutant reductions achieved
by  implementation of  BAT, Best  Management Practices  (BMP),  National  Emission
Standards  for  Hazardous Air Pollutants  (NESHAP), BPT, BCT, and  PSES.   The
methodology used to calculate these reductions is  described in the following subsections.

10.2.1 Estimation of Baseline Conventional Pollutant Loadings

Baseline biological oxygen demand (BOD5) and total suspended solids (TSS) loadings for
direct discharging mills were calculated using final off-machine production and final effluent

                                       10-1

-------
                                                       10.0 Pollutant Reduction Estimates
characterization data for 1989, as reported by mills in the 1990 questionnaire. As discussed
in Section 6.3, mUls reported monthly average daily mass loadings (Ib/day) for BOD5 and
TSS in final effluent. The monthly average daily mass loadings were averaged over twelve
months to obtain the long-term average daily mass loadings (Ib/day).  These long-term
average loadings were converted to kilograms and production normalized by dividing by the
reported annual final production expressed in off-machine metric tons per year (OMMT/yr)
and multiplying by 350 days per year, the typical number of mill production days per year.
The baseline load of each mill in a subcategory was summed to calculate the subcategory
load.  If the mill production was in more than one subcategory, the load was attributed to
each subcategory on a production-weighted basis.  Baseline BOD5 and TSS loadings are
summarized by subcategory in Table 10-1.

10.2.2  Estimation  of BPT Target Production Normalized Conventional Pollutant Mass
       Loadings

BPT target BOD5 and TSS production normalized mass loadings are the long-term average
final effluent mass loadings (in kg/OMMT) that  a mill is  estimated to achieve after
compliance with proposed BPT limitations.  For each direct discharging mill for each BPT
option, the BPT target BOD5 and TSS production normalized final effluent pollutant mass
loadings were calculated using a production-weighted average "of the BPT performance levels
listed in Section 9.2 for each subcategory in which the mill had production. This calculation
is illustrated in the following example.

Example Mill 1 has final production in three subcategories as shown below:
Subcategory
J. Secondary Fiber Non-Deink
K. Fine and Lightweight Paper From Purchased Pulp
L. Tissue, Filter, Non-Woven and Paperboard From Purchased Pulp
Percent of Final P«*di«!ti0tt
21
11
68
                                       10-2

-------
                                                      10.0 Pollutant Reduction Estimates
From Table 9-6, the BPT Options, 1 and 2 performance levels for these three subcategories
are:
Subcategory
J. Secondary Fiber
Non-Deink
K. Fine and Lightweight
Paper From Purchased
Pulp
L. Tissue, Filter, Non-Woven
and Paperboard From
Purchased Pulp
BFT Option 1
BOD Load
(kg/OMMR
0.65
2.30
1.30
TSSLoad
flkg/OMMT)
0.70
1.45
1.72
»FT Option 2
BOD Load
(fcg/OMMT*
0.35
1.59
0.65
TSSLoad
{kg/OMMT)
0.52
1.26
1.30
The BPT target BOD5 and TSS target production normalized final effluent pollutant mass
loadings for BPT Options 1 and 2 were calculated for this mill as shown below:
                             PNLT = V (%Fi)(PNL.)
                                 T   ti  100  ^    *'
(1)
where:
      PNLj.  =     Mill target production normalized final effluent pollutant mass loading,
                   kg/OMMT

      n      =     Number of subcategories

      %P}   =     Percent of final production in subcategory i

      PNL-,  =     BPT performance level for subcategory i, kg/OMMT.
                                      10-3

-------
                                                        10.0 Pollutant Reduction Estimates
 Substituting data specific to this mill:

 BPT Option 1

                   (0.21)(0.65) + (0.11)(2.30) + (0.68)(1.30) = 1.27 kg/OMMT

                   (0.21)(0.70) + (0.11)(1.45)+(0.68)(1.72) = 1.48 kg/OMMT
BOD PNLj.  =

TSS PNLr    =

BPT Option 2

BOD PNLr  =

TSS PNLr    =
                   (0.21)(0.35) + (0.11)(1.59) + (0.68)(0.65) = 0.69 kg/OMMT

                   (0.21)(0.52) + (0.11)(1.26) + (0.68)(1.30) = 1.13 kg/OMMT
 10.2.3 Conventional Pollutant Reductions for Direct Discharging Mills

 Pollutant reductions in final effluent were calculated for each mill using the mill's baseline
 BOD5 and TSS production normalized mass loadings and BPT Option 1 or 2 target BOD5
 and TSS production normalized mass loadings calculated as  described above using the
 following equation:
                                 = (PNL,ASE -
                                                                              (2)
where:

      PRT         =    Mill total conventional pollutant reduction, kg/yr

                   =    Mill baseline production normalized pollutant mass loading,
                         kg/OMMT

                   =    Mill target production normalized pollutant mass loading to
                         achieve BPT Option 1 or 2, kg/OMMT

      P           =    Mill annual final off-machine production, OMMT/yr.

The Agency compared the baseline loadings to the target loadings. K the baseline BOD5
and TSS loadings were less than the target BOD5 and TSS loadings, respectively, for BPT
Options 1 and/or 2, then the Agency assumed the mill currently meets  Options 1 and/or
2 and pollutant reductions for Options 1 and/or 2 were assumed to be zero. If the baseline
BODj and/or TSS loadings were greater than the target BOD5 and/or TSS loadings for
                                       10-4

-------
                                                       10.0 Pollutant Reduction Estimates
either Options  1 and/or 2, respectively, then conventional pollutant reductions are the
difference between the baseline and target mass loadings. Conventional pollutant reductions
for BPT Options 1 and 2 are summarized, by subcategory, in Table 10-2.

Implementation of the technology bases for the proposed BAT (pulping and bleaching
process changes), NESHAP (steam stripping of pulping condensates), and BMP (pulping
liquor management, spill prevention, and control) will significantly reduce BOD5 loads in
raw wastewater, resulting in a proportionate reduction in final effluent BOD5 load.  The
BOD5 reductions summarized in Table 10-2 represent the sum of reductions associated with
BAT, NESHAP, BMP,  and BPT as shown in the following equation:
                     PRT = PRBAT + PRNESHAP + PR
    ,  Tm
'BMP      BPT
                                                     (3)
where:
      PRT
      PR
         •BAT
      PR
         •NESHAP
      PR
         BMP
      PR
         •BPT
Mill total BOD5 reduction calculated using Equation (2), kg/yr

Mill BOD5 reduction associated with BAT, kg/yr

Mill BOD5 reduction associated with NESHAP, kg/yr

Mill BOD5 reduction associated with BMP, kg/yr

Mill BOD5 reduction associated with BPT, kg/yr.
BOD5 reductions associated with each regulation and the methodology used to estimate
these reductions are described in the following sections.

BAT, NESHAP, and BMP reductions in final effluent BOD5 loads were related to raw
wastewater loads based upon the mill's wastewater treatment performance (i.e., percent
removal of BOD5 in wastewater treatment) as illustrated in the following equation:
                                             RawA 1QQ'
                                                                              (4)
                                       10-5

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                                                       10.0  Pollutant Reduction Estimates
where:
       PR
         BAT.FE
      PR
         •BAT, R«w
             Mill BOD5 reduction in final effluent associated with BAT,
             kg/yr

             Mill BOD5 reduction in raw wastewater associated with BAT,
       %R
             Mill percent removal of BOD5 in wastewater treatment.
By using this relationship, the Agency is implicitly assuming that wastewater treatment
efficiency, in terms df percent BOD5 removal, does not change after implementation of
BAT, NESHAP, and BMP. The Agency believes this is a conservative assumption because,
in most cases, reducing influent loadings, variability, and flow to a  biological treatment
system will result in improved performance in terms of BOD5 removal. This is particularly
true for pollutant reductions associated with  BMP, which  are not easily  degraded
biologically.

To estimate loading reductions associated with BPT Options  1 and 2, the Agency first
calculated BOD5 and TSS loading reductions associated with implementation of BAT,
NESHAP, and BMP, in that order. If the loading reductions from implementation of these
regulations were not sufficient to attain the BPT Option  1 and 2  performance levels,
additional loading reduction  associated with BPT end-of-pipe treatment and/or BPT in-
process flow reduction technologies was calculated.  For purposes of estimating category-
wide loading reductions, the Agency did not consider loading reductions  beyond those
necessary to  attain the BPT Option 1 or  2 performance levels,  even if implementation of
BAT, NESHAP, and/or BMP would reduce discharges'below the  BPT Option 1 or 2
performance levels.  The Agency believes that this conservative  approach results  in
underestimation of loading reductions.  The Agency also believes that this conservative
approach ensures that mills will consistently achieve effluent loadings more  stringent than
the proposed limitations.  The Agency will consider, prior to promulgation, whether the
methodology for developing the effluent limitations should reflect these pollution prevention
reductions in raw waste loads.
10.2.3.1
Conventional Pollutant Reductions Associated with BAT
Reductions in final effluent BOD5 associated with BAT are summarized, by subcategory, for
BPT Options 1 and 2 in Table 10-3. These pollutant reductions were estimated as discussed
below. Pollutant reductions associated with BAT for BPT Option 2 are greater than for
BPT Option 1 because, as  discussed above, the  Agency did not consider conventional
pollutant reduction  estimates  for BAT at an individual mill that exceeded the removal
necessary to attain the BPT option.

                                       10-6

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                                                       10.0 Pollutant Reduction Estimates
      BAT Process Change Options

Reductions in BOD5 in raw wastewater  associated with BAT process  changes were
calculated as  described in Section 11.6.5.2.  TSS reductions associated with BAT process
changes were determined to be negligible. For mills in the Bleached Papergrade Kraft arid
Soda Subcategory, BOD5 load reductions in raw wastewater resulting from BAT process
changes were calculated based upon BAT Option 2 and range from zero to 13 kg/OMMT
of final bleached  papergrade  kraft  and  soda production  depending  upon  process
technologies in place, as summarized in Table  11-19.  BAT Option 2 was used as the basis
for conventional pollutant reduction estimates because it was not practical to try to calculate
pollutant reductions and corresponding wastewater treatment upgrades required to comply
with BPT based  upon each BAT option.  This underestimates conventional pollutant
reductions associated with BAT because  BAT  Option 4 was selected.

For mills in the Dissolving Kraft Subcategory, BOD5 load reductions in raw wastewater were
also  dependent on process  technologies  hi place, but the  resulting load reductions were
assumed equal to half'the value estimated for similar bleached papergrade kraft and soda
mills. The Agency assumed that dissolving kraft mills generally have more effective brown
stock washing and screening, in terms of resulting black h'quor loss to the bleach plant, than
papergrade kraft mills due  to higher product  purity requirements.  Thus, the impact on.
BOD5 loads due to implementing BAT process change options would be less.

For  mills in  the Papergrade Sulfite and Dissolving Sulfite Subcategories, BOD5 load
reductions in raw wastewater associated with BAT process changes options were not applied
because (1) improved brown stock washing and extended cooking were not included in the
process   change   technology  basis  for  BAT,  and (2)  wastewater  generated  from
implementation of the BAT technology basis was assumed to  be routed to wastewater
treatment rather than to chemical or heat recovery because of chemical incompatibility (e.g.,
incompatibility of sodium-based  bleaching chemicals  with magnesium-based  pulping
chemicals).

      BAT Limitations for COD

Although implementation of screen room closure, a component of the technology basis for
BAT limitations  for COD, results in significant conventional pollutant reductions in raw
wastewater, the Agency did not account for these reductions for any Subcategory except the
Dissolving Sulfite Subcategory for BPT Option 2. For the Dissolving Sulfite Subcategory
for BPT Option 2, the Agency assumed that  screen room closure results in  15 percent
reduction of  BOD5 and  TSS in raw wastewater.  The Agency intends  to account for
conventional  pollutant reductions associated with  BAT limitations for COD for  all
applicable subcategories for both BPT Options 1 and 2 in the final rule.
                                       10-7

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                                                       10.0 Pollutant Reduction Estimates
10.2.3.2      Conventional Pollutant Reductions Associated with NESHAP

Pollutant reductions associated with pulp mill condensate stripping, a technology basis for
the proposed NESHAP, are summarized, by subcategory, for BPT Options 1 and 2 hi Table
10-4.  These pollutant reductions were estimated as discussed below.  Pollutant reductions
associated with condensate stripping for BPT Option 2 are greater than for BPT Option 1
because, as discussed previously, the Agency  did not consider conventional  pollutant
reduction estimates for BAT at an individual mill that exceeded the removal necessary to
attain the BPT option.

Reductions in BOD5 hi raw wastewater associated with condensate stripping were calculated
as described hi Section 11.6.5.2. TSS reductions  associated with condensate stripping were
assumed to be negligible.  For mills with final production hi any subcategory to which the
proposed NESHAP applies, BOD5 load reductions hi raw wastewater range from zero to 8
kg/OMMT of final production hi those subcategories depending upon the fate of pulping
condensates (e.g., steam stripped, totally or partially reused,  or discharged to wastewater
treatment) at each mill in 1989  as summarized in Table 11-20.

For sulfite mills, the Agency overestimated the BOD5 pollutant reductions associated with
condensate stripping  because less of the  BOD5 hi condensates at sulfite mills  can be
removed by conventional steam stripping than BOD5 in condensates at kraft mills.  Pollutant
reduction estimates associated with the proposed NESHAP for dissolving sulfite mills for
BPT Option 2 were revised to take this into account. For these mills, the BOD5 pollutant
reduction associated with NESHAP condensate stripping was assumed to be zero.  The
result is that the Agency's cost and pollutant reduction estimates for both Papergrade Sulfite
BPT options and Dissolving  Sulfite  Option 1 are underestimated by approximately 15
percent and 4 percent, respectively, because BOD5 reduction resulting from condensate
stripping was overestimated. However, then: underestimation does not affect the selected
BPT option (Option 2).
10.2.3.3
Conventional Pollutant Reductions Associated with BMP
Pollutant reductions associated with BMP are summarized, by subcategory, for BPT Options
1 and 2 hi Table 10-5.  These pollutant reductions were  estimated as discussed below.
Pollutant reductions associated with BMP for BPT Option 2 are greater than for BPT
Option  1  because,  as discussed previously, the Agency did not consider conventional
pollutant reduction estimates for BMP at an individual mill that exceeded the removal
necessary to attain the BPT option.

Reductions hi BOD5 in raw wastewater associated with BMP were calculated as described
hi Section 11.6.5.2.  TSS reductions associated with BMP were assumed to be negligible.
For mills  with final production ha any subcategory to which BMP applies,  BOD5 load

                                       10-8

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                                                      10.0 Pollutant Reduction Estimates
reductions in raw wastewater range from zero to 5 kg/OMMT of final production in those
subcategories depending upon  each mill's status in implementing BMP  (i.e.,  major,
moderate, or no BMP upgrades required) in 1989. These reductions are summarized in
Section 11.6.5.2.

10.2.3.4     Conventional Pollutant Reductions Associated with the BPT Technology Bases

The Agency estimated that implementation of the technology bases for the proposed BAT,
NESHAP, and BMP will result in significant reductions in BOD5 final effluent loads, but
reductions in TSS were not estimated. BPT BOD5 reductions shown in Table 10-6 are the
component of the total BOD5 reduction that a mill is estiinated to achieve after compliance
with proposed BPT limitations that  is not already achieved by implementation of BAT,
NESHAP, or BMP, as illustrated in the following equation:
            PR
               BPT
- PNLT)(P)  -  (PRBAT
PRBMp)
                                                    (5)
where:
      PNLj.
      PR
         •BAT
      PR
         •NESHAP
      PR
         BMP
Mill BOD5 reduction associated with BPT, kg/yr

Mill baseline production normalized pollutant  mass loading,
kg/OMMT

Mill target production normalized pollutant mass loading to
achieve BPT Option 1 or 2, kg/OMMT

Mill annual final off-machine production, OMMT/yr

Mill BOD5 reduction associated with BAT, kg/yr

Mill BOD5 reduction associated with NESHAP,  kg/yr

Mill BOD5 reduction associated with BMP, kg/yr.
10.2.4 Conventional Pollutant Reductions Associated With BCT

As discussed in Section 9.3, the Agency developed four BCT options. Two of these options
(BCT Options B.I and B.2) were identical to BPT Options 1 and 2, resulting in identical
pollutant reductions (i.e., the pollutant reduction  each mill is estimated to achieve after
compliance with BCT not already achieved by implementation of BAT, NESHAP or BMP).

                                      10-9

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                                                      10.0 Pollutant Reduction Estimates
The Agency did not fully analyze the third BCT option (BCT Option A.1; see Section
9.3.1.1) and no pollutant reductions resulting from this option were estimated. Pollutant
reductions resulting from the fourth BCT option compared to a baseline equivalent to BPT
Option 2 (BCT Option A.2), multi-media filtration, are discussed below.

Table 10-7 summarizes, by subcategory, the incremental BOD5 and TSS reductions resulting
from BCT  Option A.2.  This  option represents tertiary wastewater treatment applied in
addition to other technologies costed to  achieve BPT Option 2, such as in-plant flow
reduction  technologies and  end-of-pipe primary and secondary wastewater treatment
upgrades.  Therefore, load reductions associated with BCT Option A.2 represent only the
portion of load reductions estimated from installation of multimedia filtration and does not
include load reductions estimated for BPT Option 2.

To calculate load reductions associated with BCT Option A.2, the Agency first determined,
for each direct discharging mill, loadings achieved after compliance with BPT Option 2. For
mills whose 1989 conventional pollutant loadings are less than the mill's BPT Option 2
target loadings, the 1989 pollutant loadings were used. For mills whose 1989 conventional
pollutant loadings are greater than the  mill's BPT Option 2 target loadings, the mill's BPT
Option 2 target loadings were used.

Treatment performance for multi-media filters was determined to be 60 percent removal of
TSS (1).  BOD5 removal was assumed equal to 50 percent of the TSS removal (2). These
calculations are illustrated below:
                         TSS PRBCT = (TSS PNLBASE)(0.6)
                                                    (6)
where:
      TSS

      TSS
Mill TSS reduction resulting from BCT, kg/yr

Mill TSS production normalized mass loading, kg/yr (either
1989 loading or BPT Option 2 loading, as discussed above).
                          BOD PRBCT = (TSS PRBCT)(0.5)
                                                    (7)
where:
      BOD PR
               •BCT
Mill BODS reduction resulting from BCT, kg/yr.
                                      10-10

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                                                       10.0 Pollutant Reduction Estimates
Use of multimedia filters was not considered to be a viable technology option for mills with
baseline TSS concentrations of 10 mg/L or less.

10.2.5  Conventional Pollutant Reductions for Indirect Discharging Mills

Table  10-8 summarizes, by subcategory, conventional pollutant reductions resulting from
PSES Options 1 and 2.  PSES Option 1 includes in-plant flow minimization and end-of-pipe
wastewater treatment equivalent to BPT Option 2 on the mill discharge to POTWs. This
is equivalent to upgrading the on-site treatment system of indirect discharging mills to a
performance level equivalent to BPT Option 2. PSES Option 2 includes upgrade of POTWs
to the level of BPT Option 2.  PSES Option 2 limitations  only  apply to the flow and
pollutant loadings discharged to the POTW from an applicable mill. The Agency believes
that these two options will result in reductions in the discharge of conventional pollutants
generated by indirectly discharging mills, even though conventional pollutants are not
limited at PSES.  Further, assuming that, under PSES  Option 1, the mills no longer
discharge to the POTW, the reductions resulting from the two options will be equal.

The baseline for this analysis was the mass of conventional pollutants currently discharged
by POTWs derived from mills to which the proposed PSES will apply.  To calculate this
baseline, each POTW was assumed to currently discharge treated wastewater, including pulp
and paper mill-derived wastewater, at BOD5 and TSS concentrations of 30 mg/L each. The
baseline mass of pollutants discharged is thus:
                                        CONCroTW
                                                     (8)
where:
      PMBASE

      k
      CONG
            POTW
Baseline mass of pollutants discharged, kg/yr

Conversion factors

30 mg/L

Mill 1989 final effluent flow (discharged to the POTW), m3/day.
                                       10-11

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                                                       10.0 Pollutant Reduction Estimates
The mass of pollutants discharged after implementation of PSES is given by:
                                      » E
                                                     (9)
where:
      PMPSES


      PNL;
Mass of pollutants discharged after PSES, kg/yr

BPT Option 2 performance level for subcategory i, kg/OMMT

Production in subcategory i, OMMT/yr.
Pollutant reductions resulting from PSES are thus the difference between the baseline mass
discharge and the mass discharge at PSES:
                                                    IBS
                                                                              (10)
where:

      PRpsEs       =     Mill poUutant reductions associated with PSES, kg/yr

                   =     Baseline mass of pollutants discharged, kg/yr

                   =     Mass of pollutants discharged after PSES, kg/yr.

10.3  Priority and Nonconventional Pollutants

This section describes pollutant reduction estimates for priority and nonconventional
pollutants (except COD). The pollutants for which final effluent discharge estimates were
calculated are listed in Table 10-9 and include 2,3,7,8-TCDD, 2,3,7,8-TCDF, four volatile
organic compounds, 20 chlorinated phenolic compounds,  and AOX  The Agency also
calculated pollutant reduction estimates for 2,3,7,8-TCDD,  2,3,7,8-TCDF, and the four
volatile compounds at the bleach plant effluent.

Pollutant reductions were calculated for each pollutant, wastewater stream, and mill as the
difference between a production normalized baseline load and the estimated discharge load
                                       10-12

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                                                        10.0 Pollutant Reduction Estimates
resulting from each BAT option.   Separate discussions of baseline and the discharges
associated with each BAT option follow this section.

The pollutants for which reductions were calculated were not always detected in bleach
plant  effluents and final effluents at all mills.  To  account for these pollutants in the
reduction estimates on a mass basis, production normalized loadings were calculated using
one-half of reported detection limits for non-detect analytical results. The Agency considers
this to be a reasonable approach because 1) these pollutants are known to be formed during
the chemical pulping and bleaching of wood, and 2) these pollutants are often detectable
in bleach plant effluents and wastewater treatment sludges when they are not detected in
treated  effluents.  Therefore, these pollutants are likely present in most samples but are
below detectable concentrations  in some.

Because reported detection limits vary, an additional step was used for data collected by the
Agency  (short- and long-term study data) to reset high detection limits that might skew the
estimates. Detection limits  greater than twice the mode of detection limits reported for'
each pollutant in all water samples in each database (see database discussion below) were
reset  to twice the mode.   This calculation methodology  is described in detail in the
Statistical Support Document.

The pollutant reduction calculations used data from four databases: 104-Mill Study, short-
term  study,  long-term study, and industry  self-monitoring  data.  In the three  sampling
programs conducted by  the Agency, bleach plant effluent and final effluent samples were
collected as  composites  over a 24-hour or multi-day period.  The average flow rate of the
wastewater stream and the brown stock pulp flow rate from the sampled bleach line(s) for
the composite period were used to calculate production normalized loads for each mill. The
self-monitoring data submitted by industry resulted from a wide range of analyses varying
from one pollutant in one stream at some mills to many pollutants in many streams at other
mills.  Some of the  industry-collected samples were grab samples and others were composite
samples. Furthermore,  sample-specific wastewater flow rates and brown stock pulp flow
rates were not provided for  any of these samples.  To calculate mass loadings from these
data, average annual flow rates for each mill (bleach plant effluent, final effluent, and brown
stock  pulp)  were obtained from responses to the 1990 questionnaire and  questionnaire
follow-up letters. Production normalized mass loadings using self-monitoring analytical data
were calculated using the following types of flow data:

      •    The average annual (1989) bleach plant flow rate reported by each mill in its
            questionnaire was used. For mills that responded to Question 46 (flows for
            combined  or separate acid  and alkaline bleach plant sewers), these flow rates
            were  used.  For mills that responded to Question 47  (total wastewater
            discharged from the bleaching area), half of this flow was attributed to the
            acid  sewer and half to the  alkaline sewer. This determination is based upon

                                       10-13

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                                                        10.0 Pollutant Reduction Estimates
             flow data where acid filtrate and  alkaline filtrate flows were  separately
             reported.

       •     The average annual final effluent flow rate reported by each mill for each of
             the years  1989,  1990,  and  1991 was  used.   Each mill reported  1989
             information in the  questionnaire and mills that indicated they  had made
             process changes in  1990 and 1991 provided flow rate data for those years.
             Final effluent chemical  concentration data obtained during 1989  were used
             with the  1989 annual  average flow rate,  while  final effluent chemical
             concentration data from 1990 or 1991 were used with the average annual flow
             rate for each of those years, if available.  When chemical concentration data
             were available for  a year in which an  average annual flow rate was not
             available, the flow rate from the previous year was  used.

       •     A single average annual brown stock pulp flow rate reported by each mill was
             used. For most mills, the flow rate used was the 1989 rate obtained from the
             1990 questionnaire.  However, many mills submitted more recent brown stock
             pulp flow rates.  The most recent data available from each mill were used.

103.1  Estimation of Baseline Loadings

Baseline loadings were estimated for selected priority and noiiconventional pollutants in the
bleach plant effluent and final effluent for each mill. The information needed to estimate
baseline pollutant mass  loadings was not available for  all mills for a particular  date;
however, much information was available about each mill from mid-1988 through 1992. The
Agency used the most recent information about each mill from the four databases (104-Mill
Study,  short-term study, long-term study, and industry self-monitoring data) to estimate
baseline loadings  for each pollutant at each mill as of January 1, 1993, the same date used
to establish the baseline technology in place at each  mill for the purpose of  estimating
compliance costs.

For mills that made recent process changes, only analytical data obtained after the most
recent process change were used to determine baseline pollutant mass loadings for those
mills. For this discussion, the relevant process changes are those that relate to the various
technology options described in Section 9.0.  For example, increasing  chlorine dioxide
substitution to 100 percent is relevant, but adding a new lime kiln is not.
          _
The following example explains how chemical concentration data were used in calculating
baseline loadings.  A hypothetical mill reported that it  increased its  chlorine dioxide
substitution on June 15, 1991 to 100 percent and that the process change stabilized on July
1, 1991.  Because the Agency was  not aware of any subsequent process changes related to
the technology options, it  was assumed that the  mill used  the same  chlorine dioxide

                                       10-14

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                                                        10.0 Pollutant Reduction Estimates
substitution from  July  1,  1991  through January  1,  1993.   Therefore, any chemical
concentration data submitted by this mill during this period were used to represent baseline
for this mill  and any data submitted prior to July 1,  1991 were disregarded.  If a null
reported making no process changes (related  to the various technology options)  since it
submitted its response to the 1990 questionnaire (1989 information), the time period was
assumed to extend from January 1,  1989 through January 1, 1993.

Very limited use was made of 104-Mill Study data. For most mills,  these data  are not
representative of the amount of 2,3,7,8-TCDD and 2,3,7,8-TCDF discharged as of January 1,
1993.  When a mill did not report making any process changes subsequent to the 104-Mill
Study and did not submit more recent data, the 104-Mill Study data were used.  Except for
104-Mill Study data, no other chemical concentration data obtained prior to January 1,1989
were used to estimate baseline loadings.

Sufficient chemical analytical and flow data were not available to calculate baseline loadings
for all pollutants at all mills. The following approach was used to estimate baseline loadings
at mills where data were not available.  Each mill in the four wood chemical pulping and
bleaching subcategories was classified into a group (referred to as a technology group) based
upon the pulping and bleaching processes used by the mill. The technology groups into
which the mills were divided are described below:
Technology
Group
A
B
C
D
E
F
G
Technology Group Description
Mills that do not use chlorine dioxide for bleaching.
Mills that use low (less than 30 percent) chlorine dioxide
substitution and do not use split addition, oxygen delignification, or
extended cooking.
Mills that use split addition of chlorine and chlorine dioxide in the
first bleaching stage.
Mills that use chlorine dioxide substitution and a chlorine multiple
less than or equal to 0.15 (approximately 70 percent).
Mills that use chlorine dioxide substitution and oxygen
delignification.
Mills that use extended cooking.
Mills that use chlorine dioxide substitution, oxygen deh'gnification,
and extended cooking.
                                        10-15

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                                                        10.0 Pollutant Reduction Estimates
For the Bleached Papergrade Kraft and Soda Subcategory, the groups described above were
further divided into subgroups. Table  10-10 shows the subgroups and the criteria used to
classify each of the bleached papergrade kraft and soda mills. The criteria for the various
subgroups included the gaseous chlorine multiple or percent chlorine  dioxide substitution
in the first stage of bleaching,  whether hypochlorite was used in the bleach sequence, and
whether the mill met the technology basis of the associated BAT option for its subcategory
and technology group.

Besides the pulping and bleaching technologies,  fiber furnish was also considered when
estimating baseline pollutant loadings for each mill.  Each mill was classified as to whether
it pulps hardwood or softwood. Mills that pulp both hardwood and softwood were classified
as softwood,  because mass loadings of most pollutants are greater  for mills that pulp
softwood than for  those that pulp hardwood. However, for mills that provided analytical
data during production Of both hardwood  and softwood,  these data were averaged to
determine baseline loadings for these mills.  Therefore, the Agency does not believe that
baseline loadings  have been overestimated for the mills that pulp both  hardwood and
softwood.

Each bleach line at each mill was classified by its technology group (or  subgroup) and fiber
furnish. In general, the technology groups of different bleach lines at a particular mill were
the same.  Because of this, and because the self-monitoring data were usually not specified
by bleach line, it was necessary to assign each mill a  single classification.  For mills with
multiple bleach lines and/or mills that use different bleach sequences on a particular line,
the one group/subgroup classification judged to best model the mill's pollutant discharge
was assigned to the mill. This classification corresponded to the technology group assigned
to the bleach line with the lower level of bleaching technology. For example, if the bleach
lines at a mill with two lines were  classified as technology groups A and  B, the mill's
classification would be A.   Therefore, for mills with multiple bleach lines  or modes of
operation, one bleach plant production normalized loading was calculated for each pollutant,
not separate loadings  for each bleach line.

Data were transferred to mills for which baseline loading data were not available in any of
the four databases for a particular pollutant.  These data were estimated by calculating an
average loading from data that were available in each database from other mills in the same
subcategory, in the same technology group or subgroup, and with the same fiber furnish.
Data transfers were accomph'shed by using production normalized loadings (kg/ADMT).
An average loading was calculated for each mill from data in each database.  Loadings for
all mills in a  particular  group were then averaged to  arrive  at a single production
normalized loading for the group.  This value was then transferred to mills in the group for
which baseline data were not available.
                                       10-16

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                                                       10.0  Pollutant Reduction Estimates
For example, if no data were available for chloroform from a bleached papergrade kraft
(BPK) mill in  technology  subgroup  Al  that  pulps  softwood, the data  that  would
preferentially be transferred to that mill would be the average chloroform loading from all
other BPK mills (from all data sources) in subgroup Al that pulp softwood.  If no other
chloroform data were available from  any  other BPK mill  in subgroup Al that pulps
softwood, the data transferred to this mill would preferentially be the average chloroform
loading for all BPK mills in technology group A that pulp softwood.

For some pollutants (particularly chlorinated phenolic compounds), this methodology could
not be implemented because there were not enough data available for certain pollutants in
bleach plant and final effluents. When this situation arose, loadings data were transferred,
based upon best professional judgment, from mills  with the most similar operations for
which data were available.

For example, data were not available for chloroform (at the bleach plant or final effluent)
for BPK mills in technology subgroup A2 that pulp hardwood. Furthermore, because all of
the BPK group A mills pulping hardwood are in subgroup  A2 (meaning no data were
available from subgroup Al), a group A chloroform average could not be calculated.
Therefore,  the production normalized mass loadings for chloroform that were transferred
to the BPK, subgroup A2, hardwood mills came from the average of the chloroform  data
available for BPK, group B, hardwood mills, based upon best professional judgment.

The baseline pollutant loadings for priority and nonconventional pollutants in final effluents
by subcategory are summarized in Table 10-11.

10.3.2  Pollutant Mass Loadings After Implementation of the Options

Data characterizing  each technology option  were used to estimate average production
normalized mass loadings for the pollutants listed in Table  10-9 for bleach plant and  final
effluents.  The. calculation of these average pollutant mass loadings is briefly described
below, and is described in more detail in a separate document (3). The calculation of these
average pollutant mass loadings is similar to the calculation of long-term  averages as
described in the Statistical Support Document.

The loadings representing the performance of the technology options were calculated from
data from the short-term study, the long-term study, and from non-U.S.  mills.  For most
options, data were available from one mill. Where data were available from more than one
mill, a combined loading was calculated by weighting the loadings from each mill  by the
number of analytical measurements available  from each mill.

The loadings representing the long-term performance of each technology option were
determined by fitting a  modified delta-lognormal  distribution to  the daily production

                                       10-17

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                                                        10.0 Pollutant Reduction Estimates
normalized loads from the mills representing each option. The mean of the distribution was
used in the pollutant reduction calculations. The modified delta-lognormal distribution and
the reasons for its selection are described in the Statistical Support Document. Bleach plant
loadings  (for  some pollutants)  and  final effluent loadings were calculated for  each
technology option.

For technology options where a pollutant was seldom or never detected, the calculated final
effluent loadings were often greater than the calculated bleach plant loadings.  The Agency
assumed that the higher calculated final effluent loadings resulted from greater flow volumes
of the final effluent as compared to  bleach plant flow volumes.  This assumption was
supported by comparing the loadings; in most cases, calculated final effluent loadings were
larger than calculated bleach plant effluent loadings when the pollutants were not detected
at either location. At pulp mills, chlorinated compounds are generally introduced only in
the bleach plant, and it is reasonable to assume that only in the bleach plant are chlorinated
by-products (pollutants) generated. Therefore, theoretically, the loadings of chlorinated
compounds  in the final effluent  cannot exceed those in the  bleach plant effluent.
Consequently, where the calculated final effluent loading was greater than the bleach plant
loading for a specific chlorinated compound, the bleach plant loading was used as the final
effluent loading.

The  performance of  the dissolving and papergrade  sulfite totally chlorine-free (TCP)
bleaching options were not determined as described above because the Agency did not have
sufficient performance data.  Instead,  the Agency assumed the discharge loads of specific
chlorinated organic pollutants were zero. A final effluent AOX loading of 0.1 kg/ADMT,
based on reported data, was used.  Also, because the Agency has no data to  characterize
the performance of the TCP options hi  controlling  acetone  and methyl ethyl  ketone,
reductions of these pollutants were not estimated.  However, data that  may be received
prior to promulgation will be considered in developing bleach plant and final  effluent
loadings and any appropriate limitations for these pollutants.

10.3.3 Pollutant Reductions

Pollutant reductions were calculated by comparing the baseline pollutant mass loadings for
each mill with the estimated average pollutant mass loadings of each technology option. If
the baseline loading for a mill was greater than the estimated average loading for an option,
the pollutant reduction achieved for that mill and option was the difference between the
baseline loading and  the estimated average loading (kg/ADMT)  for the option.  If the
baseline loading for a mill is already lower than the estimated average loading for the
option, no pollutant reduction was achieved for that mill and option (the pollutant reduction
was zero).
                                       10-18

-------
                                                        10.0 Pollutant Reduction Estimates
The pollutant reductions (in kg/ADMT) were then multiplied by the annual production
(ADMT/yr) for each mill to  convert the pollutant reduction to kg/yr.  The pollutant
reductions  in  kg/yr  calculated for each mill for a particular option, were summed to
estimate the total pollutant reduction resulting from the option.

Tables 10-12 through 10-15  summarize the pollutant reductions in final effluent for each
BAT option for each subcategory, respectively, for direct discharging mills.  Table 10-16
summarizes the pollutant reductions in effluent discharged from POTWs to the environment
for indirect discharging mills (PSES).

As can be seen in Tables 10-12 through 10-16, the estimated reductions for most pollutants
increase with the more advanced technology  options.  For example, in the Bleached
Papergrade Kraft and Soda Subcategory (see Table 10-13), the estimated pollutant reduction
for AOX increases from 10,800 to 29,900 kkg/yr from Option 1  to Option 5.  For some
pollutants, such as 2,3,7,8-TCDD, the pollutant reduction estimates for several options are
similar because implementing these options is expected to reduce current discharges of this
pollutant to non-detect levels.  In Table 10-13, for example, all of the options show nearly
the same pollutant reduction  for 2,3,7,8-TCDD.  2,3,7,8-TCDD was not detected in the
effluent  at any of the mills but was detected in the bleach plant effluent at the mills
representing Options 1, 2, and 3.

The bleach plant effluent pollutant reductions estimated for the Bleached Papergrade Kraft
and Soda Subcategory (for  Option 4) are 517 g/yr for 2,3,7,8-TCDD and 2,3,7,8-TCDF,
2,160 kkg/yr for volatile organics (acetone, chloroform, methylene chloride, and methyl ethyl
ketone), and 43,800 kkg/yr for AOX. These reductions are greater than the reductions
shown in Table 10-13 for these pollutants in final effluents.  This indicates that the process
modifications reduce pollutant loadings  to  wastewaters, as well as in sludge  and air
emissions.  This same trend is observed for mills in other subcategories where sufficient data
are available.  The Agency believes that  these bleach plant effluent pollutant reductions
(that exceed final effluent  reductions) are pollution prevention benefits attributable  to
process  changes, which are important multimedia source reduction components of the
proposed integrated rules.  Prior to promulgation of these rules, the  Agency will consider
how these pollution  prevention benefits can be factored into the analysis of final options.

10.4   Chemical Oxygen Demand

Reductions in chemical oxygen demand (COD) discharge loads were estimated for each mill
in the chemical pulping subcategories for which COD limitations  were proposed:

       •      Dissolving Kraft,
       •      Bleached Papergrade Kraft and Soda,
       •      Unbleached Kraft,
                                        10-19

-------
                                                         10.0  Pollutant Reduction Estimates
       •     Papergrade Sulfite, and
       •     Semi-Chemical.

The load reduction at each mill was calculated as  the difference between the baseline
discharge load and the estimated discharge load associated with the COD control option.
Calculation of baseline and discharges associated with the COD control option are discussed
below.  These mill-by-mill load reductions were summed across all mills to provide total
subcategory load reductions.

10.4.1  Estimation of Baseline Loadings

Production normalized COD data were available for 19 mills in the five subcategories where
COD limitations were proposed. Data were available from either the short-term study, or
were provided by the mill in their response to the 1990 questionnaire. COD discharge loads
at these facilities are presented in Table 10-17.  For these facilities, baseline COD discharge
loads (kkg/yr) were calculated by multiplying the mill's production normalized discharge
load (kg/ADMT) by the mill's 1989 brown stock pulp production rate (ADMT/yr) obtained
from the 1990 questionnaire.

Because current COD discharge load data were not  available for the remaining facilities,
the production normalized COD discharge loads for these facilities were estimated based
on BOD5 loads,  using a relationship between COD and BOD3.  For many types of wastes,
it is possible to correlate COD with BOD5 (4).  While COD and BOD5 are correlated in
treated pulp and paper industry wastewaters, there is variation in the relationship of COD
to BOD5, based on mill-specific factors.  These factors include type of pulping process
(subcategory designation) and level of pulping liquor loss control.

Within each subcategory, the level of pulping liquor  loss control was classified depending
on whether the  mill operated a closed brown stock  pulp screen room, and whether best
management practices for pulping liquor spill control were implemented, using the following
matrix:
Screen Room
Status
Closed
Closed
Closed
BMP Implementation
Status '
Good
Fair
Poor
Pulping Liquor Loss
Control Status
Good
Good
Fair
                                       10-20

-------
                                                        10.0 Pollutant Reduction Estimates
Screen, Room
Status
Open
Open
Open
BMP Implementation
Status
Good
Fan-
Poor
Pulping Liquor Loss
Control Status
Fair
Poor
Poor
Based on available data, average COD/BOD5 ratios were established as shown below:
Subcategory
Bleached Papergrade Kraft and Soda


Dissolving Kraft
Unbleached Kraft

Papergrade Sulfite

Level of Pulping
Liquor Loss Control
Good
Fair
Poor
Good
Good
Fair
Good
Poor
COB/BOD* Ratio
15.9
18.7
20.2
16.5
13.7
18.0
17
27
These data suggest that as pulping liquor loss control improves, the ratio of COD to BOD5
decreases. This relationship is not surprising, because pulping liquors exert a high chemical
oxygen demand and can also  be difficult to biodegrade.

These COD/BOD5 ratios were used to estimate baseline COD discharge loads at mills
where COD data were not available, based on available BOD5  data, and the status of
pulping liquor loss control:
                                       10-21

-------
                                                       10.0 Pollutant Reduction Estimates
COD
                             BASE
                                             (COD/BOD5)
(11)
where:
      CODBASE

      BODBASE
 Mill baseline COD discharge load,, kg/yr

 Mill baseline BOD5 discharge load, kg/yr  (as described in
 Section 10.2.1)
      COD/BOD5 =     COD/BOD5 ratio.

For example, a bleached papergrade kraft and soda mill has a closed screen room and is
judged to have good implementation of best management practices. Therefore, this mill has
good pulping liquor loss control and is estimated to have a COD/BOD5 ratio of 15.9. The
BODj discharge load at this  mill, based  on data reported in the 1990  questionnaire, is
2,020,000 kg BOD5/yr.  The COD discharge load is calculated as:

      (2,020,000 kg BOD5/yr) (15.9 COD/BOD5) = 32,100,000 kg COD/yr

The baseline COD discharge loads for indirect discharging mills were calculated as above,
using the BOD5 load currently discharged by the POTW to the  receiving body of water,
calculated as described in Section 10.2.5.

The baseline COD discharge loads  are summarized for each subcategory in Table 10-18.

10.4.2 COD Loadings After Implementation of COD Control Option

The performance levels for the COD control option hi each subcategory, as described in
Section 9.4, are listed below:
      Dissolving Kraft
      Bleached Papergrade Kraft and Soda
      Unbleached Kraft
      Papergrade Sulfite
      Semi-Chemical
                          70.3 kg/ADMT
                          21.3 kg/ADMT
                          20.8 kg/ADMT
                          63.7 kg/ADMT
                          20.8 kg/ADMT
The estimated discharge load after implementation of the COD control option at each mill
was calculated by using a production-weighted average of the COD performance levels listed
above for each subcategory in which the mill had production.  This calculation is identical
to that described in Section 10.2.2, and is illustrated by the following example.

                                      10-22

-------
                                                       10.0 Pollutant Reduction Estimates
Example Mill 2 has 500,000 ADMT/yr chemical pulp production in two subcategories as
shown below:
Subcategory
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Percent of Final
Production
23.3
76.7
COB Performance i
Level (fcg/ADMf)
21.3
20.8
Using Equation (1):
                                      "   % P.
                             PNL, = V"  	-  (PNL);
                               ^   tf   100  V     ''
and substituting data specific to this mill:

      COD PNLj. = (0.233) (21.3)  + (0.767) (20.8) = 20.9 kg/ADMT

To calculate the annual discharge of COD after implementation of the COD control option,
the above calculated target production normalized load is  multiplied by the total annual
brown stock pulp production:


             (20.9 —kg  )  (500,000 ADMT)  = 10,450,000 kg COD/yr
             v     ADMT'  v          yr   '               *      /y


10.4.3 Pollutant Reductions

For each mill, the pollutant load reduction was calculated  as the difference between the
baseline discharge and the COD control option discharge.  If the baseline discharge was
lower than the control option discharge, the load reduction was estimated to be zero.  If all
of the chemical pulp production at a mill was in one subcategory, the load reduction was
attributed to that subcategory.  If the production was in more than one subcategory, the load
reduction was attributed to each subcategory to which the COD control option applies on
a production-weighted basis. The estimated  COD load reduction for each subcategory is
shown on Table  10-19.
                                       10-23

-------
                                                       10.0  Pollutant Reduction Estimates
10.5  References

1.     Harris, R.W., M.J. Cullinane, and P.T. Sun, eds. Process Design and Cost Estimating
      Algorithms for the Computer Assisted Procedure for Design and  Evaluation of
      Wastewater Treatment Systems  (CAPDET).   United  States Army  Engineer
      Waterways Experiment Station, Vicksburg, Mississippi, 1982. (Prepared for the U.S.
      Environmental Protection Agency).

2.     Personal communication with J. Floyd Byrd, October 27, 1992.

3.     Radian Corporation. Methodology for Determining BAT Pollutant Loadings For the
      Revision of Pulp and Paper Effluent Limitation Guidelines.  Radian Corporation,
      Herndon, Virginia, June 2,  1993.

4.     Metcalf and  Eddy, Inc.  Wastewater Engineering,  Treatment, Disposal, Reuse,
      Second Edition.  McGraw-Hill, Inc., New York, New York, 1979. pp. 96.
                                       10-24

-------
                                      Table 10-1
                    Baseline Conventional Pollutant Loadings
                            for Direct Discharging Mills
Subcategory(a)
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical
Nonwood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-Deink
Fine and Lightweight Papers from
Purchased Pulp
Tissue, Filter, Non- Woven, and
Paperboard from Purchased Pulp
Industry Total
BODS
(kkg/yr)
6,910
73,400
31,200
22,400
8,860
3,970
8,560
276
4,450
8,980
7,830
5,570
182,000
TSS
(kfcgM)
9,870
110,000
48,200
30,600
12,100
6,080
14,400
282
6,240
12,200
10,200
5,450
266,000
(a)Baseline pollutant loads for mills with operations in more than one subcategory have been apportioned based
  upon annual production (OMMT) in the subcategories to which each regulation applies.
                                         10-25

-------
                                    Table 10-2
          Total Conventional Pollutant Reductions Resulting From
                              BPT Options 1 and 2
Subcategory(a)
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical
Nonwood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-Deink
Fine and Lightweight Papers from
Purchased Pulp
Tissue, Filter, Non-Woven, and
Paperboard from Purchased Pulp
Industry Total
BPT Option 1 Reductions

-------
                                       Table 10-3
            Conventional Pollutant Reductions Associated With BAT
SubcategoryCa)
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical
Nonwood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-Deink
Fine and Lightweight Papers from
Purchased Pulp
Tissue, Filter, Non- Woven, and
Paperboard from Purchased Pulp
Industry Total
BAT/B0I>5 Reductions at
BPT Option 1

-------
                                       Table 10-4
         Conventional Pollutant Reductions Associated With NESHAP
Subcategoiy(a)
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical
Nonwood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-Deink
Fine and Lightweight Papers from
Purchased Pulp
Tissue, Filter, Non- Woven, and
Paperboard from Purchased Pulp
Industry Total
Condensate Stripping/BOO,
Reductions at BPT Option 1
, 
-------
                                       Table  10-5
           Conventional Pollutant Reductions Associated With BMP
SubcategoryCa)
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical
Nonwood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-Deink
Fine and Lightweight Papers from
Purchased Pulp
Tissue, Filter, Non- Woven, and
Paperboard from Purchased Pulp
Industry Total
BMP/B00«r Reductions at
BPT Option 1
(kkg/yr)
407
1,510
519
368
433
0
NA
22
NA
NA
NA
NA
3,260 .
BMJP/BODij Reductions at
BPT Option -2
Oskg/j*)
407
1,900 •
1,480
840
436
0
NA
24
NA
NA
NA
NA
5,090
(a)Reductions for mills with final production in more than one subcategory to which BMP applies have been
   apportioned based upon annual production (OMMT) in the subcategories to which BMP applies.

NA -   Conventional pollutant reductions associated with BMP are not applicable to this subcategory and BPT
       Option.
                                           10-29

-------
                                    Table 10-6
           Conventional Pollutant Reductions Associated With the
                             BPT Technology Bases
Subcategory(a)
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical
Nonwood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-Deink
Fine and Lightweight Papers from
Purchased Pulp
Tissue, Filter, Non- Woven, and
Paperboard from Purchased Pulp
Industry Total
BPT Option 1 Reductions

-------
                                     Table 10-7

     Conventional Pollutant Reductions Associated With BCT Option A.2
Subcategory(a)
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical
Nonwood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-Deink
Fine and Lightweight Papers from
Purchased Pulp
Tissue, Filter, Non-Woven, and
Paperboard from Purchased Pulp
Industry Total
BCT Reductions, Option A3 j

-------
                                       Table 10-8
         Conventional Pollutant Reductions Associated With PSES(a)
Subcategory(b)
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical
Nonwood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-Deink
Fine and Lightweight Papers from
Purchased Pulp
Tissue, Filter, Non-Woven, and
Paperboard from Purchased Pulp
Industry Total
PSES Reductions "" '
(kkg/yr)
BOD..
' ' ' .,' A
0
3,130
123
0
14
50
NA
NA
NA
NA
NA
NA
3,320
, "iJrJSS
0
1,190
0
0
0
0
NA
NA
NA
NA
NA
NA
1,190
(a)Pollutant reductions resulting from PSES Options 1 and 2 are equal.

(b)Reductions for mills with final production in more than one subcategory to which PSES applies have been
   apportioned based upon annual production (OMMT) in the subcategories to which PSES applies.

NA -   Conventional pollutant reductions associated with PSES are not applicable to this subcategory.
                                           10-32

-------
                                  Table 10-9

            Priority and Nonconventional Pollutants for Which
                   Pollutant Reductions Were Calculated
                   Priority and Nonconventional Pollutants
Chloroform
Methylene Chloride
2-Propanone (Acetone)
2-Butanone (Methyl Ethyl Ketone)
4-Chlorophenol
4-Chlorocatechol
6-Chlorovanillin
2,4-Dichlorophenol
2,6-Dichlorophenol
4,5-Dichloirocatechol
5,6-Dichlorovanillin
2,6-Dichlorosyringaldehyde
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
3,4,5-Trichlorocatechol
3,4,6-Trichlorocatechol
3,4,5-Trichloroguaiacol
3,4,6-Trichloroguaiacol
4,5,6-Trichloroguaiacol
Trichlorosyringol
2,3,4,6-Tetrachlorophenol
Tetrachlorocatechol
Tetrachloroguaiacol
Pentachlorophenol
Adsorbable Organic Halides
2,3,7,8-Tetrachlorodibenzo-p-dioxin
2,3,7,8-Tetrachlorodibenzoruran
                                     10-33

-------
                 Table 10-10
         Technology Subgroups for the
Bleached Papergrade Kraft and Soda Subcategory
Group
A
B
C
D
E
Subgroup
A(a)
Al
A2
B(b)
Bl
B2
B3
B4
B5
B6
C(a)
Cl
C2/C3
C4
D(a)
Dl
D2
D3
E(a)
El
E2
E3
Option













1


2(b)



3(b)
3/4
™ ----"--' ; Description
Mills that do not use chlorine dioxide for bleaching (and do not use oxygen
delignification or extended cooking).
Mills with bleach sequences of CEH or CEHH.
Mills with other bleach sequences.
Mills that use some chlorine dioxide and do not use split addition, oxygen
delignification, or extended cooking.
Mills that use hypochlorite that have gaseous chlorine multiples >0.22.
Mills that do not use hypochlorite that have gaseous chlorine multiples >0.22.
Mills that use hypochlorite that have gaseous chlorine multiples from 0.17 to
0.22.
Mills that do not use hypochlorite that have gaseous chlorine multiples from
0.17 to 0.22.
Mills that use hypochlorite that have gaseous chlorine multiples <0.17.
Mills that do not use hypochlorite that have gaseous chlorine multiples <0.17.
Mills that use split addition of chlorine in the first stage of bleaching.
Mills that use hypochlorite.
Mills that use more than 30% chlorine dioxide substitution.
Mills that represent Option 1.
Mills with high chlorine dioxide substitution (>50%).
Mills with high chlorine dioxide substitution that use hypochlorite.
Mills with high chlorine dioxide substitution that do not use hypochlorite.
Mills that have 100% chlorine dioxide substitution that do not use
hypochlorite.
Mills that use chlorine dioxide substitution and oxygen delignification.
Mills with less than 50% chlorine dioxide substitution.
Mills with greater than 50% chlorine dioxide substitution.
Mills that represent Option 3 or 4.
                     10-34

-------
                                            Table 10-10

                                            (Continued)
Gicoup
F
G
Subgroup
F
Fl
F2
F3
F4
G
Optieia
3/4




5(b)
Description
Mills that use extended cooking that represent Option 3 or 4.
Mills that have chlorine dioxide substitution and use hypochlorite.
Mills that have no chlorine dioxide substitution and use hypochlorite.
Mills that have gaseous chlorine multiples <0.20.
Mills that have gaseous chlorine multiples >0.20.
Mills that use both extended cooking and oxygen delignification that have
chlorine dioxide substitution and do not use hypochlorite.
(a)The technologies described for this group also apply to each of the subgroups (i.e., mills in subgroups Al and A2 have
   the technology described for mills in group A).

(b)Some mills in this subgroup meet the technology basis of the option indicated.
                                                10-35

-------
                                       Table 10-11

                Baseline Loadings for Priority and Nonconventional
                             Pollutants in Final Effluents
Pollutant
2,3,7,8-TCDD
2A7.8-TCDF
Chloroform
Methylene Chloride
MEK
Acetone
Total Chlorinated
Phenolics(b)
AOX
Units
g/yr
g/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
Dissolving
Kraft
2.0
25
5.9
1.5
2.6
7.1
5.8
2,290
Bleached
Papergrade
Kraft and
Soda
57
266
919
26
141
126
1,490
36,700
Dissoiying
Sulfite
1.0
2.7
71
0.4
5.8
26
6.8
2,180
Papergrade
Sulfite
0.91
7.3
18
2.1
6.8
23
19
5,350
Indirect
Discharge
Mills(a)
9.6
40
125
1.5
7.8
14
27
4,550
(a)Basclinc loading discharged from POTWs to the environment.

(b)Sum of baseline loadings for the 20 chlorinated phenolic compounds listed in Table 10-9.
                                           10-36

-------
                                          Table 10-12

    Pollutant Reduction of BAT Options For the Dissolving Kraft  Subcategory
Pollutant
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform
Methylene Chloride
MEK
Acetone
Total Chlorinated Phenolics(a)
AOX
Pollutant Redaction in Final Effluent
Units
g/F
g/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
Option 1
1.8
24
0.0
1.2
0.94
0.0
2.6
230
Option 2 i
1.8
25
5.4
1.3
1.8
4.0
3.5
1,670
Option 3
1.9
25
5.6
1.2
1.3
0.0
4.8
2,100
(a)Sum of pollutant reductions for the 20 chlorinated phenolic compounds listed in Table 10-9.

Option 1 is based on high chlorine dioxide substitution.
Option 2 is based on oxygen delignification and high chlorine dioxide substitution (approximately 70%).
Option 3 is based on oxygen delignification and 100% chlorine dioxide substitution.
                                               10-37

-------
                                           Table 10-13

    Pollutant Reduction of BAT Options For the Bleached Papergrade Kraft and
                                       Soda Subcategory
Pollutant
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform ,
Methylene Chloride
MEK
Acetone
Total Chlorinated Phenolics(a)
AOX
PoUutant Reduction in Final Effluent ' '" '
Units
g/F
g/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
Option t
48
253
867
20
95
21
1,410
10,800
Options
53
262
790
22
110
11
1,390
8,550
Option 3
53
263
910
24
125
68
1,440
25,400
Option 4
54
263
913
21
115
15
1,470
32,900
Option 5
54
263
913
25
113 •
36
! 1,460
29,900
(a)Sum of pollutant reductions for the 20 chlorinated phenolic compounds listed in Table 10-9.

Option 1 is based on split addition of chlorine and chlorine dioxide.
Option 2 is based on high chlorine dioxide substitution (approximately 70%).
Option 3 is based on oxygen delignification and high chlorine dioxide substitution, (approximately 70%).
Option 4 is based on oxygen delignification and 100% chlorine dioxide substitution.
Option 5 is based on extended cooking, oxygen delignification, and 100% chlorine dioxide substitution.
                                               10-38

-------
                                          Table 10-14

      Pollutant Reduction of BAT Options For Dissolving Sulfite Subcategory
Pollutant
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform
Methylene Chloride
MEK
Acetone
Total Chlorinated Phenolics(a)
AOX
Pollutant Redaction in Final Effluent
Units ;
g/y
g/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
Option 1
0.37
2.0
54
0.0
0.0
0.0
2.4
1,010
Option 2
0.99
2.7
71
0.45
N/A
N/A
6.8
2,080
 N/A - Data not available.

(a)Sum of pollutant reductions for the 20 chlorinated phenolic compounds listed in Table 10-9.

Option 1 is based on oxygen delignification and chlorine dioxide substitution (hypochlorite is not eliminated).
Option 2 is based on totally chlorine-free bleaching.
                                              10-39

-------
                                         Table 10-15

     Pollutant Reduction of BAT Options For Papergrade Sulfite Subcategory
Pollutant
2,3,7,8-TCDD
2^,7,8-TCDF
Chloroform
Methylene Chloride
MEK
Acetone
Total Chlorinated Phenolics(a)
AOX
Pollutant Reductions in Final Effluent
Units
g/F
g/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
, Option 1
0.54
6.7
9.4
1.1
1.1
0.0
15
4,460
Option 2
0.91
7.3
18
2.1
N/A
N/A
19
5,250
 N/A - Data not available.

(a)Sum of pollutant reductions for the 20 chlorinated phenolic compounds listed in Table 10-9.

Option 1 is based on oxygen delignification, chlorine dioxide substitution, and elimination of hypochlorite.
Option 2 is based on totally chlorine-free bleaching.
                                              10-40

-------
                                          Table 10-16
                               Pollutant Reductions for PSES
	 Pollutant
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform
Methylene Chloride
MEK
Acetone
Total Chlorinated Phenolics(c)
AOX
Pollutant Reduction in Final ESluent(a)
Units
g/yr
g/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
kkg/yr
Selected Option(b)
.9.4
40
124
1.0
5.3
1.8
26
4,250
(a)Effluent discharged from POTWs to the environment.

(b)The selected option has the same technology basis as BAT Option 4 for the Bleached Papergrade Kraft and Soda
  Subcategory and BAT Option 2 for the Papergrade Sulfite Subcategory.

(c)Sum of pollutant reductions for the 20 chlorinated phenolic compounds listed in Table 10-9.
                                              10-41

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                           Table 10-17

               Summary of Available COD Data
                 Chemical Pulping Subcategories
Observation
1
2
3 ,
4
5
6
7
8
9 .
10
11
12
13
14
15
16
17
18
19
'Vi&ij
s\?
Subcategory
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Bleached Papergrade Kraft and Soda
Bleached Papergrade Kraft and Soda
Bleached Papergrade Kraft and Soda
Bleached Papergrade Kraft and Soda
Bleached Papergrade Kraft and Soda
Bleached Papergrade Kraft and Soda
Bleached Papergrade Kraft and Soda
Bleached Papergrade Kraft and Soda
Bleached Papergrade Kraft and Soda
Bleached Papergrade Kraft and Soda
Bleached Papergrade Kraft and Soda
Bleached Papergrade Kraft and Soda
Papergrade Sulfite
Papergrade Sulfite
Unbleached Kraft
Unbleached Kraft
Unbleached Kraft
Final
Effluent
€OUHx>ad
(kg/ADMT)
703
14.4
23.5
23.8
25.1
26.8
32.4
35.6
41.6
59.6
60.9
69.5
72.8
253
63.7
200
17.4
19.9
21.6
Final
Effluent
BOJ>« Load

4.26
1.25
1.08
1.45
1.61
1.92
3.78
1.63
1.31
2.16
4.92
5.69
6.15
N/A
3.81
7.42
2.34
.1.58
1.72
N/A - BODj data that reliably correspond to COD data are not available.
                               10-42

-------
                                           Table 10-18
                                Baseline COD Discharge Load
•" f f
•••• m'sS- '• %O ^ !
r% Ssii^ategoty^a) :
V. % ; •. ,
Dissolving Kraft
Bleached Papergrade
Kraft and Soda
Unbleached Kraft
Papergrade Sulfite
Dissolving Sulfite
Semi-Chemical
Total
Bireg$ £&&ii&ng$i$
'" ;/$&%/wy -~
nd
1,590,000
705,000
270,000
nd
107,000
3,010,000
" ladireet l>iseliiargers{lj) i
i -' <"t^>^ - ;
0
121,000
43,900
4,080
0
2,000
171,000
(a)Baseline pollutant loads for mills with operations in more than one subcategory have been
   apportioned based on annual production (OMMT) in the subcategories to which each
   regulation applies.

(b)Estimated COD load discharged by POTWs to receiving waters.

nd - Not disclosed to prevent compromising confidential business information.
                                                10-43

-------
                                        Table 10-19

           Reduction in Annual Discharge of COD After Implementation
                             of BAT and PSES Regulations
•"••''• :
s ^ •.••
•>' \
$ubeateg0*y(a) Tj
Dissolving Kraft
Bleached Papergrade
Kraft and Soda
Unbleached Kraft
Papergrade Sulfite
Dissolving Sulfite
Semi-Chemical
Total
Direct PissKhaj^rsi
«/"v  ' -, , :
0
82,300
20,800
1,860
0
1,180
106,000
(a)Reductions for mills with final production in more than one subcategory have been
  apportioned based on annual production (OMMT) in the subcategories to which each
  regulation applies.

(b)Estimated reduction hi treated effluent discharged by POTWs to receiving waters.

NC - Not calculated.
                                           10-44

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                                              11.0 Costs of Technology Bases for Regulations
11.0  COSTS OF TECHNOLOGY BASES FOR REGULATIONS

Effluent limitations guidelines and standards establish quantitative limits on the discharge
of pollutants to waters of the United States. The limits are based upon the performance of
specific technologies,  but  do not require the  use of  any specific technology.  Effluent
limitations guidelines  are applied to individual  facilities through National Pollutant
Discharge Elimination System (NPDES) permits issued by EPA or authorized states under
Section 402 of the Clean Water Act. Each facility then chooses its own approach to comply
with its permit limitations.

The technologies considered as the bases for Best Available Technology Economically
Achievable (BAT), Pretreatment Standards for Existing Sources (PSES), Best  Practicable
Control Technology (BPT), and Best Management Practices (BMP)  were described in
Section 8.0.  Section 9.0 described the combination of these technologies into  options for
pulping and bleaching process  changes,  end-of-pipe wastewater treatment, and internal
controls. Section 11.0 describes the methodology used to calculate the costs to the industry
of implementing each of the technology options.

From an  overall mill perspective, there is  considerable overlap among the  technology
options for each of the regulations. For example, the final effluent limitations for toxic and
conventional pollutants regulated under BAT depend not only upon the pulping and
bleaching process changes that comprise the BAT options, but also upon effective end'-of-
pipe biological treatment,  which is the basis of the BPT options. Thus, the costing effort
for  each regulation for a mill assumed that the technologies included in the other effluent
guidelines regulations applicable to that mill were in place.

Section 11.1 describes the calculation of costs of pulping and bleaching process  changes for
BAT and PSES. Section 11.2 describes the calculation of costs for BAT chemical oxygen
demand (COD) control technologies. Section 11.3 discusses the costs of steam  stripping of
pulping area condensates,  a technology that was included in the technology options for the
National Emissions Standards  for Hazardous Air Pollutants (NESHAP).  BOD5 load
reductions associated with steam stripping pulping area condensates were considered when
BPT costs were developed. Section 11.4 discusses the calculation of costs for BMP.  Section
11.5 describes the  calculation of costs for flow reduction, which was also part  of the BPT
options.  Section 11.6  describes BPT end-of-pipe treatment costing.

11.1   Costs of Pollution Preventing Process Changes

As  described in Section 9.4, various in-plant  pollution prevention measures have been
selected by the Agency as the basis for BAT for the different types of bleached chemical
pulp mills in the U.S.  These technologies also represent the basis for bleach plant effluent
standards under PSES and part of the basis for  the pulp and paper NESHAP. Section 11.1
describes  the method  used to  estimate  the capital and  annual operating costs  of
                                        11-1

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                                              11.0 Costs of Technology Bases for Regulations
implementing pulping and bleaching area process changes for the mills in the following
subcategories: Dissolving Kraft, Bleached Papergrade Kraft and Soda, Dissolving Sulfite,
and Papergrade Sulfite.  The estimated costs for these mills to implement each technology
option are also summarized.

It is important to note that implementation of the technologies that comprise the process
change options is not required to comply with BAT or PSES. The technologies were used
as the basis for the development of numerical limitations and standards for bleach plant and
end-of-pipe  discharges, and the cost of implementing the technologies at each mill was
calculated to provide an estimate of the compliance cost for the  industry to meet the
numerical limitations or standards. However, the technologies are not required under BAT
or PSES.

11.1.1  Methodology for Estimating Costs of Pollution Preventing Process Changes

Estimating the costs of pollution preventing process changes involved selecting a costing
approach, developing a  cost model, and compiling the operating, design, and cost data
necessary to execute the cost model. Each of these steps is described in the sections below.
11.1.1.1
Costing Approach and Sources of Information
The Agency selected a mill-by-mill costing approach rather than a model-mill approach to
estimate the cost of the BAT and PSES process change options. The mill-by-mill approach
was selected to account for the wide variation hi pulping area and bleach plant design and
operation across the industry.  Detailed information on pulping area and bleach plant
operation was available to the Agency from the mill responses to the 1990 questionnaire and
follow-up correspondence.  Additional information was obtained from telephone contact
with mills,  mill site visits, and publications by the pulp and paper industry.  Using this
information, the Agency was able to obtain a reasonably accurate picture of the equipment
and technologies in place at each mill as of January 1,  1993.

The technology in place at each mill as of January 1,1993 was compared to the BAT/PSES
process change options to determine whether existing  equipment should be upgraded or
additional equipment should be added to achieve option level performance. Because mill
performance data  for all pollutants of concern to the Agency at appropriate discharge
locations were not available, the Agency could not directly compare actual mill performance
with the BAT or PSES option performance levels.  The Agency believes this approach tends
to overestimate costs, because option level performance nray be  achievable without using
all of the components of the technology option. Thus, costs were estimated to implement
process change technologies for some mills  even though they may already achieve bleach
plant and end-of-pipe discharge loads equal to or less than the proposed BAT and PSES
limitations.
                                       11-2

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                                              11.0  Costs of Technology Bases for Regulations
11.1.1.2
Source of Cost Model
The Ministry of the Environment in Ontario, Canada developed a spreadsheet cost model
to calculate costs for technology options identified as "Best Available Technology" as part
of the development of the Pulp and Paper Sector Effluent Limits regulation for the Province
(1). This model estimates costs for both in-plant pollution prevention measures and end-of-
pipe wastewater treatment. Based upon a detailed review of this model, EPA determined
that, with some modification and updating, the model was appropriate to use as a costing
tool for the proposed BAT and PSES regulations.

The cost model runs on Quattro-Pro® software.  It consists of a main spreadsheet for each
subcategory containing the equations  and assumptions that determine the equipment,
chemicals, energy, and labor required for each technology option. The main spreadsheet
is linked with three external spreadsheets containing appropriate constants, factors, and cost
equations to estimate capital and operating costs for each technology option.  Site-specific
pulping and bleaching data for each mill  are entered into the main spreadsheet, and
appropriate equations are applied to the mill for each technology option evaluated. A copy
of the main spreadsheet and each external spreadsheet can be found in the Record for the
Rulemaking. Mill-specific data, however, are not included in the spreadsheets found in the
Public Record.

The capital and annual operating costs calculated using the cost model are incremental, and
reflect the costs a mill would incur in implementing any new technologies beyond the mill's
current operating budget.  For example, if a mill upgrades or enlarges a system, its repair
and maintenance budget would be expected to increase proportionally (a conservative
assumption). If a mill replaces an existing system with a new one, it is assumed that the
current repair and maintenance budget would suffice, and the incremental operating and
maintenance cost would be zero.  In the second case, the estimate is also conservative,
because the new equipment would likely require  less maintenance than did the older
equipment  that was replaced.
11.1.1.3
Sources of Operating and Maintenance Costs
Operating and maintenance (O&M) costs consist of the annual costs incurred by a mill for
raw materials, chemicals, energy, and operating and maintenance labor.  O&M costs may
increase  or  decrease with new technology installation.   A negative annual  O&M cost
indicates that the cost of operating a new technology costs less than operating an older
technology, usually because of savings in chemical and energy use.

Costs for chemicals, energy, raw materials, and labor for the technologies included in the
BAT/PSES process change options were required to estimate the incremental operating
costs.  Although costs were available from various engineering and trade journals, the
Agency solicited more representative data through a survey of 21 mills in six regions of the
                                        11-3

-------
                                               11.0  Costs of Technology Bases for Regulations
U.S.:  Alaska, Midwest, Northeast, Northwest, Southeast, and West Coast. Eighteen of the
21 mills responded to the survey.  One mill not included 'in the survey voluntarily provided
cost data.

The operating costs reported by each mill were summarized by item, and the units were
standardized to metric. For each item, the Agency examined the ranges of operating costs
by region to assess whether use of a single nation-wide average cost or different regional
costs was more appropriate.

In general, the responses to the survey indicated that costs for each item were site-specific,
as opposed to region-specific.  Based upon this finding, nation-wide averages were used to
estimate mill operating costs. Table 11-1 summarizes the operating costs derived from these
mill responses.  The derivation of each cost is described in a memorandum entitled  "Pulp
and Paper Operating Costs"  dated September 1,  1993,  found in the Record for the
Rulemaking.
11.1.1.4
Sources of Capital Costs
Capital costs consist of direct costs for equipment installation and labor and indirect costs
for engineering, project management, and overhead. Capital cost curves for the technologies
included in the BAT/PSES process change options were developed primarily using cost
information supplipd by selected pulp mills and major vendors of pulping and bleaching
technologies. Chemical pulping and bleaching mills that had installed the technologies of
interest were identified from responses to the 1990 questionnaire.  Twenty-eight mills,
selected  to represent a range 'of capacities  and geographic locations, were  surveyed for
capital cost information for one or more recently installed technologies. Responses were
received from 25 of the 28 mills. Major vendors were also requested to provide capital cost
information for equipment with various capacities. In addition, capital cost information was
obtained from other pulp and paper projects in the U.S.  and Canada and from literature
sources.  The mills and vendors were requested to provide as detailed a breakdown as
possible for the following capital costs:

      Direct Installed Costs

      Mechanical Equipment
      Piping and Instrumentation
      Foundations, Buildings, and Structural Components
      Electrical Components
      Site-specific Costs (site clearance, demolition, major utility runs,  etc.)
                                        11-4

-------
                                                11.0 Costs of Technology Bases for Regulations
       Actual Indirect Costs

       Engineering
       Other (contingencies, misc.)

       Other Costs

       License Fees
       Land

The capital cost information received from mills and vendors was adjusted to fourth-quarter
1991  dollars by multiplying by a cost adjustment factor, based on the average of the
Chemical Engineering Equipment and Composite indices. The adjustment factors are shown
below.
1 Cost Adjustment Factors
Year
1986
1987
1988
1989
1990
1991
Cost Factor
1.16
1.13
1.06
1.02
1.01
1.00
The capital costs were also adjusted  to standardize the scope of the projects.  In their
responses, most mills included capital costs that were incurred due to site-specific problems
(often space-availability problems).  Because these costs are typical of retrofit projects in
mills, they were retained in the adjusted capital cost information to better reflect realistic
mill conditions. However, costs for equipment beyond what was necessary to  install the
technology of interest were not included.  In addition, the capacities associated with the
capital costs were converted to standard units. In certain cases, the reported capital costs
were adjusted to reflect the different labor  rates, material prices, and different climates
across the U.S.

The adjusted costs and capacities for each technology of interest were then plotted, and a
curve was fitted to the data.  From the fitted  curve, an equation calculating the capital cost
of each technology was developed. This cost equation was used to scale the capital costs
for each mill's capacity and is of the form:
                                         11-5

-------
                                               11.0' Costs of Technology Bases for Regulations
                                 C = C0(Cap/Cap0)"                            (D
where:
             =    Calculated capital cost of the system in dollars

       Qj    =    Base cost for a similar system of capacity Cap0

       Cap   =    Capacity of the system for which the capital cost is being calculated

       Cap0  =    Capacity corresponding to the base cost C0

       n     =    Index which reflects the  economy  of scale for adjusting equipment
                   costs for various  capacities. The value most often used was 0.6, but
                   this value was adjusted to better fit the pattern of cost data for some
                   unit operations.

This type of equation is widely used to calculate preliminary capital cost estimates  and to
scale known capital costs, as discussed in many engineering texts (2,3).

Table 11-2 presents the constants for the above equation developed from the cost curve for
each technology.  A detailed description of the derivation of capital cost curves is provided
in a report entitled Development of Capital Cost Curves for Best Available Technology
Options for  Chemical Pulp Mills That Bleach Wood,  found in the Record for  the
Rulemaking.
11.1.1.5
Effluent Monitoring Costs
Mills subject to BAT and PSES will be required to perform monitoring of bleach plant
effluent and final effluent streams as described in Section 15.4.  The cost  to develop a
bleach plant effluent flow monitoring station was included in the process change capital
costs and is discussed in a memorandum entitled "Bleach Plant Flow Monitoring Station
Costs," found in the Record for the Rulemakmg. The annual cost to a mill for chemical
analysis of the monitored effluents is discussed in this section.
                                        11-6

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                                               11.0  Costs of Technology Bases for Regulations
Monitoring costs were based oh the following effluent streams, analytes, and frequencies:
i
Pollutant
2,3,7,8-TCDD and TCDF
Chloroform
Acetone
Methyl ethyl ketone
Methylene chloride
Chlorinated Phenolics
AOX
COD
Color
Monitoring Frequency
Bleach Plant
Effluent
1 per month
1 per week(a)
1 per week(a)
1 per week(a)
1 per week(a)
1 per month
0
0
0
Final Effluent
1 per month
0
0
0
0
1 per month
1 per day
1 per day
1 per day
(a)Bleach plant acid and alkaline filtrates are to be sampled and analyzed separately for
   volatile organics.

Note that while costs were included for monitoring 2,3,7,8-TCDD, 2,3,7,8-TCDF, and
chlorinated phenolics in the final effluent, effluent limitations guidelines are not proposed
for these  constituents in final effluent.  The Agency has determined that more direct and
adequate control of 2,3,7,8-TCDD, 2,3,7,8-TCDF, and chlorinated phenolics is provided by
effluent h'mitations guidelines applicable to  bleach plant effluents.   The  final .effluent
monitoring costs presented in this section therefore overestimate by 30 percent the actual
final effluent monitoring costs expected to be incurred.

Estimated costs for these analyses as of February 1993 were obtained from EPA's Sample
Control Center (SCC).  These costs were  discounted by an assumed factor of 25 percent to
account for  the following:  (1) the price difference between SCC laboratories and the
commercial laboratories that would be contracted by some of the industry to perform these
analyses;  (2) the increase in volume of these analyses that will be performed as a result of
this regulation which would result in a decrease in costs; and (3) the use by some mills of
in-house laboratories rather than commercial laboratories. The discounted analytical prices
are shown below, along with the calculation of the total analytical  costs for bleach plant
effluent and final effluent monitoring.
                                         11-7

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                                               11.0  Costs of Technology Bases for Regulations
Bleach plant Effluent
Analysis
2,3,7,8-TCDD/TCDF (including
secondary column confirmation)
Volatile organics
Chlorinated phenolics
Analytical
Method
1613A
1624C
1653
Cost per
Sample
$1563
$335
$613
Fluency
per Year
12
52x2
12
Cost per
Year
$18,756
$34,840
$7,356
TOTAL $60,952
The total shown above ($60,952) is the estimated annual analytical cost per bleach line for
BAT/PSES bleach plant monitoring.
Final Effluent
Analysis
2,3,7,8-TCDD/TCDF (including
secondary column confirmation)
Chlorinated phenolics
AOX
COD
Color(a)
Analytical
Method
1613A
1653
1650
410.1 and 410.2
NCASI Tech.
Bulletin #253
Cost per
Sample
$1563
$613
$ 124
$ 36
$ 11
Frequency
per Year
12
12
365
365
365
Cost pejf
Year
$18,756
$ 7,356
$45,260
$13,140
$ 4,015
' TOTAL $88,527
(a)Limitations for color proposed for only the Bleached Papergrade Kraft and Soda Subcategory.

The total shown above ($88,527) is the estimated annual analytical cost per mill for final
effluent BAT/PSES monitoring.

11.1.2 Conventions Used in the Cost Model

The cost model was developed based upon several assumptions regarding mill 'operating
conditions. The most basic assumption is that a mill will continue to produce  the same
grades and quantities of pulp after implementing BAT and PSES process changes; therefore,
there was no speculation as to future market trends.  The number of production days per
year at each  mill is assumed  to be 350 days;  this number was used in calculating annual
costs.  Also,  each mill  is assumed to have  effective biological wastewater treatment
                                        11-8

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                                               11.0 Costs of Technology Bases for Regulations
equivalent to BPT Option 2. Other assumptions and conventions used in the cost model are
described below.
11.1.2.1
Units of Measure
All calculations in the cost model are performed in metric units.  Pulp flows are measured
in metric tons (1,000 kg = 2,204.6 Ibs).  Chemical charges are expressed as kg/metric ton
(1 kg/metric ton = 2 Ib/U.S. ton).   Calculations are based upon air dry (10% moisture)
metric tons  of either unbleached or bleached pulp;  the production basis used is stated in
each section of the model.

Pulp production was reported in the 1990 questionnaire  as unbleached tons entering the
bleach plant, and most of the data in the questionnaire database are related to unbleached
tons of pulp production.  The unbleached pulp production was converted to bleached pulp
production for use in the cost model by applying pulp shrinkage through the bleach plant
(see Section 11.1.2.5).  The production was also converted  to  air dry metric tons, and
chemical application rate data used in the  cost model were normalized to kg/bleached
ADMT.
11.1.2.2
Reference Date
Data reflecting  the  current (as of January 1, 1993) operation of a mill's pulping and
bleaching processes were entered into the cost model spreadsheet, to represent the mill's
"base case."  If  the Agency was aware  that a mill had actually begun to install process
equipment by January 1, 1993, that equipment was assumed to be in place and to represent
the "base  case" for  the  purposes of estimating compliance costs.  Projects that were
announced as being under study or in the engineering, purchasing, or other initial phases
were  not considered to be  "committed,"  and the related  process  equipment was not
considered to be in place.
11.1.2.3
Costing of Bleach Plant Swing Lines
Many mills bleach more than one grade of pulp on the same bleach line. A line producing
more than one grade is referred to as a swing line.  Where a bleach line swings between two
very different grades (i.e., using a different furnish or different chemical application rates),
the capital costs for both grades were calculated. The more expensive of the two estimated
capital costs was selected to represent the cost of the process change option for the line.
The operating costs were calculated as the production-weighted sum of the operating costs
for each grade. Most bleach plant swing lines in the U.S. alternate between hardwood and
softwood furnish.  Where a bleach line swings between two similar grades, best professional
judgment was used to select the grade that would result in a higher, and therefore more
conservative, cost estimate.
                                        11-9

-------
                                              11.0 Costs of Technology Bases for Regulations
In some cases, a swing line produces more than two different pulp grades.  In these cases,
best professional judgment was used to select a combination of grades that would result in
the best estimate of the maximum cost incurred for the line.
11.1.2.4
Effluent Flow Reduction
Implementing many of the BAT and PSES process change technologies results in lower
effluent flows. However, no credit for flow reduction was included in the cost model.
11.1.2.5
Shrinkage
As pulp is bleached, organic material in the pulp combines with bleaching chemicals and
is washed out of the pulp, leaving more pure cellulose.  Thus, there is a decrease in the
amount of pulp leaving the bleach plant compared to entering the bleach plant.  This
difference is known as bleaching yield loss or shrinkage.  Shrinkage is calculated as:
 (Unbleached metric tons/day - Bleached metric tons/day)
               (Unbleached metric tons/day)
                                                                              (2)
The cost model uses shrinkage for each bleach line to calculate the amount of chemical
required for each bleaching stage, and the shrinkage is therefore important in estimating the
costs for changing a mill's bleach plant operation.

The 1990 questionnaire asked mills to estimate the shrinkage for each bleach line. Most
mills reported data.  For mills that did not report shrinkage, a value was estimated.  The
percent shrinkage was applied to the unbleached pulp flow entering the first bleaching stage,
or entering oxygen delignification for mills that have oxygen delignification, to calculate the
bleached pulp flow leaving the bleach plant.  Estimates of shrinkage, based upon the bleach
sequence and the  delignificalion processes preceding the bleach plant are shown as follows:
                                       11-10

-------
                                                 11.0 Costs of Technology Bases for Regulations
' " "%' ' „ '
"• •£•"• ffff ''"'
- ifSP" V.^> •**>•• wvw
•* s v. sw, •,-,•,•, _, :
Traditional chlorine-based bleaching
sequence
Oxygen delignification + chlorine-based
bleaching (overall shrinkage)
Extended cooking + chlorine-based
bleaching (bleach plant shrinkage)
Extended cooking + oxygen delignification
+ chlorine-based bleaching (shrinkage
across OD and bleach plant)
i
L Ftt! MgM»ess pulp
ssss
Hardwood
4%
4%
2%
2%
;.«•>•.•, „
8%
8%
4%
4%
: B$ttll~
bleaeh(a)
6%
6%
—

(a)A six-percent shrinkage factor was used for either hardwood or softwood pulp that is not
bleached to full market brightness (semi-bleached).

These estimates are consistent with values used by paper industry engineers for design and
analysis.
11.1.2.6
Bleaching Chemical Consumption
The cost model calculates changes in bleaching chemical consumption  associated .with
implementation of the following technologies:

       •     Oxygen delignification;

       •     Extended cooking;

       •     Elimination of hypochlorite;

       •     Split addition of the first chlorine charge;

       •     Increased chlorine dioxide substitution; and

       •     Enhanced extraction.

Changes in bleaching chemical consumption associated with improved brown stock washing
were considered negligible.
                                         11-11

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                                              11.0 Costs of Technology Bases for Regulations
Changes in bleaching chemical consumption were calculated relative to a mill's base case
chemical consumption.  It was assumed  that the chemical charges (i.e.,  the  amount of
chemical added to each bleaching stage) reported by a mill were appropriate to the mill's
equipment,  furnish,  and  product.   The cost  model calculated  changes  in chemical
consumption while maintaining the equivalent bleaching power of each stage, as described
below.

Each bleaching agent used by the industry has a bleaching power related to the oxidation
potential of chlorine, the  traditional bleaching agent.  The table below summarizes the
relative bleaching power of each bleaching compound, expressed as a chlorine equivalence
factor (4).
Bleaching Ag«»t -/'- s _i
Chlorine
Chlorine dioxide
Hypochlorite
Oxygen hi E^
Hydrogen peroxide
Ozone
Chlorine E^nivaleiws^Faefar^
1
2.63
1
2
2
4.4
The concept of "equivalent chlorine" is widely used in the pulp and paper industry, and is
used in cost model calculations to determine appropriate changes in chemical consumption
that still maintain a mill's base case bleaching power.  Because an increasing number of
mills are eliminating the use of chlorine, the term "oxidizing equivalent" (OE) is a more
appropriate term to express the bleaching power of a particular bleaching agent.

The factors shown in the table above are valid only within the limitations of the process
equipment and practical bleaching chemistry. For example, if 70 kg of chlorine/metric ton
is used to lower the Kappa number of pulp to 5, it cannot simply be replaced by 35 kg of
oxygen/metric ton, because such intense treatment with  oxygen would destroy the pulp
strength  and  make  the pulp unusable for  its   normal purposes.   The  cost  model
mathematically accounts for these limitations and bleach plant chemical charges are adjusted
accordingly.
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                                               11.0 Costs of Technology Bases for Regulations
 11.1.3 Description of Cost Model

 11.1.3.1      Model Overview and Base Case

 The BAT/PSES .process change cost model consists of a  main spreadsheet for each
 subcategory  and three  supporting  files  containing costs  and  costing factors  for  all
 subcategories.  The main  cost model spreadsheet for each subcategory is comprised of
 several subsections.  The first is a section of base case information drawn from the 1990
 questionnaire and subsequent follow-up correspondence.' Sections follow for estimating the
 costs for each process change option for the subcategory. The final section summarizes the
 costs for each option and the major equipment included in the costs.

 As described in Section  11.1.2.2, the process change cost model is based on incremental
 costs relative to  a mill's operation as of January 1, 1993, referred to as the base case.
 Information on the base case operations at each mill was obtained from the questionnaire,
 follow-up letters and telephone contacts, and site visits. The following table presents a list
 of the base case information that was entered into the cost model for each'mill.

               Process Change Cost Model Base Case Mill Information
Mill location
Fiber furnish
Unbleached pulp flow to bleach plant
Fraction of production on line (for multiple lines or swing lines)
Bleaching sequence
Brown stock washer loss
Digester exit Kappa number
Pre-chlorination Kappa number
Bleach plant'shrinkage
Chemical dosages for oxygen delignification and each bleaching stage
Products
Type and number of digesters
Brown stock washer types
Number and capacity of recovery boilers
Type and capacity of C1O2 generators
Production bottleneck (from 1990 questionnaire)

In order to maximize the efficiency of the cost model spreadsheet, all capital and operating
costs, as well as factors and constants used in the model, were stored in supporting files.
When  information  in the supporting files is  modified,  the mill-specific spreadsheets
automatically recalculate costs using the updated information.  The three supporting files
are:
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                                              11.0 Costs of Technology Bases for Regulations
      •      CAP.WQ1 - A list of the constants that apply to capital costs.

      •      CONST.WQ1 - A  list of the constants that apply to operating costs and
             conditions.  These include unit costs for chemicals, process parameters such
             as  the  target  Kappa  number  for  various  process modifications,  and
             assumptions such as the number of mill operating days assumed  when
             converting costs expressed in dollars per ton to annual costs.

      •      FACTORS.WQ1 - A list of the regional labor costs and climate factors that
             apply to all capital  cost estimates.

The costs for each process change option are  estimated in separate sections of the cost
model.  The technologies that comprise the process change options and the methodology
used in the cost model to estimate costs are described in detail in a document entitled Pulp
and Paper Process Change Cost Model Documentation,  found in the Record  for the
RulemaWng.  A brief discussion of each of the technologies and the subcategories to which
they are applicable is provided below.
11.1.3.2
Extended Cooking
Extended cooking was  costed  for  mills in the Bleached  Papergrade Kraft and Soda
Subcategory. Costs were calculated for extended modified continuous cooking (EMCC®).
The costs were estimated for either a new digester or a retrofit, depending on the type of
digester already in use at a mill.
11.1.3.3
Oxygen Delignification
Oxygen delignification was costed for mills in the Bleached Papergrade Kraft and Soda,
Dissolving Kraft, Papergrade Sulfite, and Dissolving Sulfite Subcategories.  Costs were
calculated for a medium-consistency system, including the necessary white liquor oxidizing
equipment and two-stage post-oxygen washing. It was assumed that the oxygen generating
plant would be leased from a vendor.
11.1.3.4
Ozone Bleaching
An ozone bleaching stage was costed for mills in the Dissolving Sulfite Subcategory.  Costs
were calculated for a two-stage medium-consistency system. It was assumed that the ozone
generating plant would be leased from a vendor.
11.1.3.5
Effective Brown Stock Washing
Effective brown stock washing was costed for mills in the Bleached Papergrade Kraft and
Soda and Dissolving Kraft Subcategories. Costs were calculated for a washing line upgrade
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                                               11.0 Costs of Technology Bases for Regulations
(an additional stage of washing) if a mill's washing loss was between 10 and 25 kg of
Na2SO4/metric ton of pulp. Costs were calculated for a new washing line if a mill's washing
loss was greater than 25 kg NajSO^metric ton of pulp.
11.1.3.6
Recovery System Upgrades
When a mill improves brown stock washing or installs  oxygen delignification and/or
extended cooking, there is an increase in the amount of organics recycled to the recovery
boiler, as discussed in Section 8.2. These organics result in an increased heating load on the
recovery boiler.  Costs for increased recovery boiler heating loads were calculated for mills
in the Bleached Papergrade Kraft and Soda and Dissolving Kraft Subcategories.

Increases in recovery boiler heating load of less than 1 percent are negligible with respect
to the accuracy of boiler flow measurements.  Therefore, no costs  were calculated for
increases of 1 percent or less. The increase in organics from improved brown stock washing
fell within this range, so no recovery boiler capacity increases due to improved brown stock
washing were calculated.

The heating value of the organics recovered after oxygen delignification or extended cooking
was used to determine the additional load on the recovery boiler from oxygen delignification
or extended cooking. If the additional load was greater than 1 percent, a cost for increased
recovery boiler capacity was calculated.  The increase in recovery boiler heating load from
both oxygen delignification and extended cooking (BAT Option 5) was estimated to be the
same as for either technology alone, because the estimated target Kappa number for the
combined technologies is only three points lower than for either  technology alone (a
conservative estimate).

Methods for increasing recovery boiler capacity were discussed in Section 8.2.6.  These
methods include:

       1.     Expanding the boiler bed;

      2.     Air system modifications;

      3.     High solids firing;

      4.     Adding anthraquinone to the digester; and

      5.     Building a  new boiler either as a replacement with larger capacity or as
             additional capacity.

The Agency  did not include new recovery boilers in the cost model because  the modest
increases in organics calculated did not suggest that mills required new boilers and because
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                                               11.0  Costs of Technology Bases for Regulations
recovery boiler upgrades are more economical than new boilers. Anthraquinone was not
included in the cost estimates because the Agency was not aware of any U.S. mills using
anthraquinone  in full-scale  operations.  Costs for the remaining three recovery boiler
upgrades listed above are within a similar range.  Costs for air system modifications and
high solids firing were available from mills hi -North America and were used hi estimating
the costs for increasing recovery boiler capacities (5). Upgrades of these types are common
hi the industry and  can result in savings hi operating and maintenance costs by increasing
steam generation and decreasing maintenance shutdowns.

The costs for the three  upgrades were within the same  range for  a given capacity, as
described hi Development of Cost Curves  for  Best  Available Technology Options for
Chemical Pulp Mills That  Bleach Wood,  found hi the  Record for the Rulemaking.
Therefore, a- single  cost curve was developed from the reported costs as an allowance for
a recovery boiler upgrade; it was assumed that each mill would make a site-specific selection
as to the type of upgrade implemented.

Costs for recovery boiler upgrades were required for 55 mills in the Bleached Papergrade
Kraft and Soda Subcategory for Options 3 and 4.  An additional 13 mills in the subcategory
that did  not require upgrades for Option 3 and 4 because they already had either oxygen
delignification or extended cooking required upgrades for Option 5. The highest estimated
percent increase hi  recovery boiler heating load for any individual mill was 2.1 percent.
11.1.3.7
Split Addition of Chlorine
Split addition of chlorine was costed for mills hi the Bleached Papergrade Kraft and Soda
Subcategory. Costs were calculated for splitting the chlorine charge to the first bleaching
stage into two  separate charges, including high shear mixing and process control and a
10-percent increase hi chlorine charge.
11.1.3.8
High Chlorine Dioxide Substitution
High chlorine dioxide substitution was costed for mills hi the Bleached Papergrade Kraft
and Soda, Dissolving Kraft, Papergrade Sulfite, and Dissolving Sulfite Subcategories. The
amount of substitution required was calculated based on a target Active Chlorine Multiple
(ACM) Ratio of 0.9 and a target gaseous chlorine multiple (GCM) of 0.065, as described
hi Section 9.4.1.
11.1.3.9
Peroxide Bleaching
Peroxide bleaching was costed for mills in the Papergrade Sulfite and Dissolving Sulfite
Subcategories.   Costs  were calculated for converting an existing bleaching tower to a
peroxide tower and for peroxide supply and storage.
                                       11-16

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                                               11.0 Costs of Technology Bases for Regulations
11.1.3.10     Enhanced Caustic Extraction Stage

Peroxide- and oxygen-enhanced extraction were costed for mills in the Bleached Papergrade
Kraft and Soda and Dissolving Kraft Subcategories. Oxygen-enhanced extraction was costed
for mills in the Papergrade Sulfite Subcategory.  Costs were calculated for chemical supply,
peroxide unloading and storage facilities (if the mill did not already have such facilities),
peroxide piping and controls, and a high shear mixer and retention tube for the oxygen.

11.1.3.11     Elimination of Hypochlorite

Hypochlorite elimination was costed for mills in the Bleached Papergrade Kraft and Soda
and Dissolving Kraft Subcategories.  Costs were calculated to  replace hypochlorite with
chlorine dioxide.  The method of compensating for the hypochlorite bleaching  power
depended on the miU's bleaching sequence.
11.1.3.12
Chlorine Dioxide Generation
Increasing chlorine dioxide use through increased substitution or elimination of hypochlorite
required increased chlorine dioxide generating capacity for some mills in all Subcategories.
Costs were calculated for a generator upgrade for mills that had an R3 or Single Vessel
Process (SVP)-type generator. Costs for new generators were calculated for the remaining
mills.

11.1.4  Cost Model Validation

In order to validate the cost model used by the Agency to develop mill by mill costs for this
regulation, EPA compared costs  developed with its cost model to recent, cost estimates
reported by Simons/AF-IPK, major design consultants retained  by the pulp and paper
industry (6). This comparison showed that the capital and operating and maintenance costs
used by the EPA cost model are within the  range of costs used to calculate estimates
reported by Simons/AF-IPK in their four case studies. On the basis of this comparison, and
the fact that the Agency's model costs for process changes are based in large measure upon
actual  industry installed cost for  process changes, the Agency concludes that its costs
estimates are reasonable for the purposes intended.
                i
11.1.5  Benefits of Replacing Equipment

The costs calculated for BAT and PSES process changes are  used by the Agency as an
estimate of the costs that will be  incurred by the industry to achieve the BAT and PSES
pollutant reduction benefits discussed in Section 10.0. Additional benefits of implementing
the process change technologies are reductions in energy demand, chemical costs, and labor;
credit for these, reductions is included in the cost model.
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                                              11.0 Costs of Technology Bases for Regulations
Another benefit of the process change technologies is the replacement of old and outdated
equipment with new, modern equipment. In estimating process change costs, the Agency
assumed older  chlorine dioxide generators that do not use the R3 or SVP processes are
replaced in order to increase C1O2 generating capacity and increase C1O2 substitution.

Recent developments in chlorine dioxide generating technology mean that many mills will
upgrade their generators in  order to produce C1O2 with less residual  chlorine and fewer
problem by-products.  These mills  will also likely add C1O2 generating capacity when
installing a new generator. The BAT/PSES capital costs attributable to replacing generators
that do not use the R3 or SVP process are shown below.
,'::.';' Cost Option ''.. ' ,- \
Oipifcal C«* (tfilil&Mi $)
Bleached Papergrade Kraft and Soda Subcategory
1
2
3
4
5
37.4
199
164
241
210
Dissolving Kraft Subcategory
1
2
3
19.4
31.1
22.3
Papergrade Sulfite Subcategory
1
2
59.6
NA
                                       11-18

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                                              11.0 Costs of Technology Bases for Regulations
€0&jpptfoai - - i
L ,,iQ*$Me&sM»$H&l*$l .. :
Dissolving Sulfite Subcategory
1
2
15.8
NA
NA - Not applicable.

All of these estimated costs were attributed to the cost of implementing the process change
option even though many mills would upgrade their chlorine dioxide generators regardless
of effluent limitations guidelines.

There are also intangible benefits of replacing and upgrading equipment.  New equipment
is usually more reliable than old equipment, requiring less maintenance and repair.  New
equipment may improve product marketability, particularly as it relates  to elemental or
totally chlorine-free bleaching processes.

When estimating the costs for the new and upgraded equipment that forms the basis of the
BAT/PSES process  change options, the Agency assumed each mill would  maintain its
production capacity as of January 1,  1993.  However,  it is likely that many mills would
increase  capacity when making  major modifications to pulping and bleaching processes
without a significantly higher cost because of the economies of scale associated with such
projects.

11.1.6  Estimated Process Change Costs

Table 11-3 presents summaries of total capital and annual operating and maintenance costs
calculated for each of the BAT/PSES process change options for mills with production in
the Dissolving Kraft,  Bleached Papergrade Kraft  and Soda,  Dissolving  Sulfite, and
Papergrade Sulfite Subcategories. Tables 11-4 through 11-7 summarize by subcategory the
equipment costed for each BAT/PSES process change option and the numbers and cos,t of
each type of equipment.  The equipment costs shown on Tables 11-4 through  11-7 do not
add up to the  total  capital costs because the cost for installing a bleach plant effluent
monitoring station is not shown on the tables.  The costs shown in Tables 11-3 through 11-7
represent both the direct and indirect discharging mills in the four subcategories listed
above. Costs for COD control are not included; they are presented in Section 11.2.
                                       11-19

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                                              11.0  Costs of Technology Bases for Regulations
11.2  Costs for COD Control
                                                                i
This section presents the background data and methodology used to estimate the costs of
the technology bases  for  COD control.  COD controls  are part of the proposed BAT
effluent limitations guidelines and standards for the following subcategories:

      Subpart     Subcategory

      A.          Dissolving Kraft;

      B.          Bleached Papergrade Kraft and Soda;

      C.          Unbleached Kraft;

      E.          Papergrade Sulfite; and

      F.          Semi-Chemical.

Effective COD control should focus on capturing spent pulping liquors and returning them
to a chemical or heat recovery process. EPA evaluated a set of these recovery techniques,
including effective brown stock washing, closed screen room operation, and pulping liquor
spill prevention and control. These techniques are applicable to subcategories where spent
pulping liquor is collected, evaporated, and burned to recover reusable chemicals and/or
heat:  dissolving kraft, bleached papergrade kraft  and  soda., unbleached kraft, dissolving
sulfite, papergrade sulfite, and semi-chemical. In  addition to the above techniques, that
portion of COD which is biodegradable can be treated by end-of-pipe secondary biological
treatment.

The technology elements listed above were combined to form BAT for COD control in each
applicable subcategory:
So^^oiey - - '-\
Dissolving Kraft,
Bleached Papergrade Kraft and Soda,
Unbleached Kraft,
Dissolving Sulfite; and
Papergrade Sulfite
Semi-chemical
Technology Ba$i$0fC0»C^jtttwi<>jiitiwi _ss
• Effective brown stock washing,
• Closed screen room operation,
• Pulping liquor spill prevention and control, and
• End-of-pipe secondary biological treatment.
• Effective brown stock washing,
• Pulping liquor spill prevention and control, and
• End-of-pipe secondary biological treatment.
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                                               11.0  Costs of Technology Bases for Regulations
Note that closed screen room operation is not included in the BAT basis for semi-chemical
mills, because screening is usually not practiced at these mills.  Section 9.4 further discusses
the development of COD control options.

The Agency developed a technology option for the control of COD in the Dissolving Sulfite
Subcategory that contains the same elements listed above (effective brown stock washing,
closed screen operation, pulping  liquor spill prevention  and control, and  end-of-pipe
biological treatment).  However, the Agency did not have sufficient data to  analyze the
performance of this option and so has not proposed effluent limitations for COD for the
Dissolving  Sulfite Subcategory, nor has the Agency estimated the cost of COD  control
technology for this Subcategory.

Cost estimates for most of the technology elements for COD control are included within
estimates developed for other aspects of the regulation.  Pulping liquor spill prevention and
control is a component of BMP.  Section 11.4 discusses BMP costs. Section 11.6 discusses
cost estimates for end-of-pipe secondary biological treatment.  Costs for the remaining
components of the COD  control options, effective brown stock washing and closed screen
room operation, are discussed by Subcategory below.

11.2.1  Dissolving Kraft and Bleached Papergrade Kraft and Soda Subcategories

The cost of upgrading brown stock washing where necessary at dissolving kraft and bleached
papergrade kraft and soda  mills  is included in the estimated cost of pulping area process
changes, as discussed in Section 11.1. Therefore, for these subcategories, the only remaining
component of COD control costs not otherwise  accounted  for is the cost of screen room
closure.

The closure status of screen rooms at mills for which COD data are available  was
determined from site visits  and telephone contact with  the mills. Using information from
these mills, a production normalized pulping area discharge flow rate of 6.3 m3/ADMT
(1,500 gallons/ADT) brown stock pulp was established as indicative of screen room closure.
Those mills reporting pulping area discharge flows of 6.3 m3/ADMT or less were assumed
to have closed screen rooms, whereas those with flows  over 6.3 m3/ADMT were assumed
to have open screen rooms and incur costs  for screen room closure.

Costs for closed screen room operation are partially incorporated in the costs of pulping
area process changes for options that include oxygen delignification (BAT Options 3,4, and
5), because some of the mill costs attributed to oxygen  delignification were for closing the
screen room. An assessment of whether screen room closure was included in the project
cost could be  made for  nine  of 12 projects  that formed  the  basis  for  the  oxygen
delignification cost curve.  Of the  nine projects,  seven  did  not include closing the screen
room and two included closing the screen room. The capital cost for one of the two projects
fell on the oxygen delignification cost curve,  and the cost for the other was $2,100,000 above
                                       11-21

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                                              11.0 Costs of Technology Bases for Regulations
the curve (494,000 ADMT/yr production basis).  Based upon these data, a capital cost
estimate for screen room closure (in conjunction with oxygen delignification), of $2,100,000
for a 494,000 ADMT/yr mill was used. Individual costs for bleached kraft mills that do not
currently have closed screen rooms were assigned using this cost, scaled to production. The
Agency did not base the estimated  cost of closing screen rooms on mills without oxygen
delignification because it did not have data available to do so.  The technology basis for
BAT Options 3 and 4 includes enhanced delignification through oxygen delignification or
extended cooking. Upgrading to extended cooking includes some of the same improvements
to pulp washing as oxygen delignification. Therefore, the cost estimates for screen room
closure assume the installation of technology equivalent to BAT Options 3, 4, or 5, but are
not additive to BAT Options  1 and 2.

Operating and maintenance costs for closed screen room operation are assumed to be zpro,
because the new equipment replaces existing equipment and is assumed to require the same
or less operating  and maintenance  expenses.  Savings from reduced water consumption,
steam requirements, fiber recovery, and wastewater treatment are also realized; these have
not been quantified.

11.2.2  Unbleached Kraft and Papergrade Sulfite Subcategories

Cost estimates for improved brown stock washing and closed screen room operation at mills
in the unbleached kraft and papergrade sulfite subcategories were based upon the cost of
fiber line improvements made at an unbleached kraft mill in the southeastern United States.
These  improvements (installation of fibrilizers, hot stock screens and reject refiners, new
deckers, and a decker filtrate return line to the digester) cost $4,300,000, normalized to
fourth  quarter 1991 dollars (349,000 ADMT/yr production basis). The Agency recognizes
that certain components of this system, such as the fibrilizers, are specific to the high-yield
pulping operations used at unbleached kraft mills, and the metallurgy requirements at sulfite
mills are different than at kraft mills. However, on a subcategory-wide basis, the scale and
cost of the modifications required  are assumed  to represent the type of pulping area
improvements necessary for improved brown stock  washing and  closed  screen  room
operation at papergrade sulfite mills.

As was the case for bleached kraft mills,  a production normalized pulping area discharge
flow rate of 6.3 m3/ADMT brown stock pulp was established as indicative of screen room
closure. Mills with pulping area flows above this level were assigned a screen room closure
cost based on the $4,300,000 estimate above, scaled to the mill-specific production. Similar
to the bleached kraft subcategories, operating and maintenance costs for closed screen room
operation are assumed to be zero.
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                                              11.0 Costs of Technology Bases for Regulations
11.2.3 Semi-Chemical Subcategory

Screening is usually not practiced at semi-chemical pulp mills (7). This is reflected in the
1990 questionnaire responses, as semi-chemical mills reported significantly lower production
normalized discharge flows from the pulping area than kraft mills. Therefore, closed screen
room operation is  not included as part of the technology basis for COD control at semi-
chemical mills.
             i
The BMP and end-of-pipe cost components of COD control at semi-chemical mills are
presented in Section 11.4 and  11.6, respectively.  There are no proposed BAT effluent
limitations guidelines for toxic pollutants discharged from the Semi-Chemical Subcategory;
therefore, the cost of  improved brown stock washing is the  cost of the COD control
technology basis at semi-chemical mills.

Specific data on brown stock washing efficiency at semi-chemical mills were not available
in the questionnaire database.   However, based upon low raw wastewater  BOD5 loadings
(<3.6 kg/metric ton),  four  of  19  semi-chemical  mills were assumed to  currently have
adequate brown stock washing in place.  The range of raw wastewater BOD5 loadings for
these mills was 0.8  to 3.6 kg/metric ton compared to a Subcategory median of 12 kg/metric
ton. Each of the other semi-chemical mills was assumed to need to install an additional
brown stock washer to improve  brown stock washing efficiency.  The capital cost curve for
an additional brown stock washer from the process  change cost model was used to estimate
capital costs (see Section 11.1.3). The base cost for this upgrade is $4,450,000  at a base
capacity  of  296,000 ADMT/year.   Costs were scaled  to  production.   Operating  and
maintenance materials and labor were estimated at 4 percent of the capital  cost, consistent
with the  process change cost model. These costs were offset by a savings of  $0.15 per
ADMT brown stock pulp to account for the heat value of the additional recovered organics
that result from improved washing.

11.2.4 Summary of Costs for COD Control

Table 11-8 presents the capital  and operating and maintenance costs for COD control in
each subcategory.  The table presents the total number of mills in the Subcategory, the
technology included in the cost estimate, the estimated number  of mills in the subcategory
without the technology  in place that will incur costs,  and the total subcategory cost.

11.3  Steam Stripping Costs

Steam stripping of  digester blow tank condensates, turpentine underflow condensates, and
evaporator condensates is included as part of the Maximum Achievable Control Technology
(MACT) Standards of the NESHAP. The NESHAP is applicable to mills in the Dissolving
Kraft, Bleached Papergrade Kraft and Soda, Unbleached Kraft, Semi-Chemical, Dissolving
Sulfite, and  Papergrade Sulfite  Subcategories.  The  NESHAP  and the Pulp,  Paper,  and
                                       11-23

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                                             11.0 Costs of Technology Bases for Regulations
Paperboard Industry Effluent Limitation Guidelines and Standards comprise the integrated
proposed rulemaMng, which includes an integrated analysis of the cost and impacts of both
rules.

Steam stripping of condensates reduces the BOD5 load discharged to wastewater treatment,
as well as emissions of total reduced sulfur and  hazardous air pollutants.  Therefore, a
BOD5 load reduction associated with steam stripping was accounted for when the costs of
BPT treatment system upgrades were estimated.  These load reductions are discussed in
Section  11.6.5.2.  The cost of steam stripping condensates was included as part of  the
analysis of the proposed NESHAP, and  the cost estimating methodology is detailed in  the
Background Information Document (BID) and the Record for the proposed NESHAP. A
summary of the costing methodology is provided below.

The steam stripper system design basis was derived from data that indicate that a steam-to-
feed ratio of 0.180 kg steam/L wastewater (1.5 Ib/gal) is representative of pulp mill stripper
operation and achieves a 90-percent removal efficiency for methanol.  The column was
assumed to be a sieve tray column with  eight theoretical trays.  These data were obtained
from  a  questionnaire sent to the industry  in 1991 as  part of the proposed  NESHAP
development.

Condensate steam strippers can be integrated directly into evaporator sets, or designed as
Stand-alone units.  Based on responses  to the NESHAP questionnaire, approximately 67
percent of existing systems are integrated into evaporator sets, and 33 percent stand alone.
An integrated system uses steam from the evaporator  set for operation;  therefore,  the
amount of fresh steam needed is much less than for a stand-alone system.  Average costs
are prorated  to reflect these percentages.  Specific equipment and example costs  are
presented in the NESHAP BID.

11.4  BMP Costs

This section describes the estimation of costs to implement Best Management  Practices
(BMP).  The Agency  estimated costs for all mills in the  following  subcategories to
implement BMP:

      Subpart     Subcategorv

      A.           Dissolving Kraft;

      B.           Bleached Papergrade Kraft and Soda;

      C.           Unbleached Kraft;

      D.          Dissolving Sulfite;
                                       11-24

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                                               11.0  Costs of Technology Bases for Regulations
       Subpart      Subcategory

       E.           Papergrade Sulfite;

       F.           Semi-Chemical; and

       G.           Non-Wood Chemical Pulp.

11.4.1  General Approach

The general approach in BMP costing was to group the mills based upon the amount of
upgrade they would require to implement BMP. To simplify the cost estimation process,
the Agency used three groups:  mills that require no upgrades, mills that require moderate
upgrades, and mills that require major upgrades.  Initially, 23 mills that the Agency had
recently visited were assigned to one of the three groups based on operations in place at
each site.  The 23 mills are in the following subcategories:
•"? " ,„ ,
"•• ^«bcai«g
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                                              11.0 Costs of Technology Bases for Regulations
industry-wide and subcategory basis.  Actual costs for individual mills may be  above or
below the costs the Agency estimated by this approach.

11.4.2 Bleached Papergrade Kraft and Soda Subcategory

Many of the 14 bleached papergrade kraft mills listed in the table above had recently
constructed or rebuilt production facilities. Consequently, as a group, these 14 mills are
likely to  have better-than-average  spill  prevention  and control  systems.   From  this
assessment, the Agency estimated that, in the subcategory as a whole, approximately one-
third  of the mills have BMP technologies equivalent to the proposed BMP and require no
upgrades; one-third require moderate upgrades; and one-third require major upgrades.
Mills  were assigned to one of the three groups according to the pulping and bleaching
technologies irl place. In making these assignments, the Agency assumed that mills that had
upgraded their pulping and bleaching processes were most likely  to  have implemented
pulping liquor  BMP,  based on observations during  site  visits.  Mills  in the  Bleached
Papergrade Kraft and Soda Subcategory were assigned to BMP upgrade groups, as follows:

      No BMP upgrade required: Mills that have oxygen delignification and/or extended
      cooking and mills that have alow gaseous chlorine multiple (<_0.2) and high chlorine
      dioxide substitution (>40 percent).

      Moderate BMP upgradk required: Mills that have split addition of chlorine and mills
      that  have a high gaseous chlorine multiple  (>0.2) and  low  chlorine dioxide
      substitution.

      Major BMP upgrade required:  Mills that have not modernized their pulping and
      bleaching processes (do not  use oxygen delignification or extended cooking or
      chlorine dioxide substitution; use hypochlorite).

The average capital and operating and maintenance (O&M) costs assigned to each level of
upgrade are shown in Table 11-9. A net savings in O&M costs for kraft mills requiring
moderate or minor upgrades results from increased  recovery of pulping  chemicals and
energy.

11.4.3 Unbleached Kraft Subcategory

For the Unbleached Kraft Subcategory, the Agency assumed the same distribution of mills
in  the  three BMP upgrade groups as in the Bleached Papergrade  Kraft  and  Soda
Subcategory. One-third of the unbleached kraft mills require no upgrades, one-third require
moderate upgrades, and one-third require major upgrades. Mills were assigned to one of
the three groups based on the reduction in five-day biochemical oxygen demand (BOD5)
effluent load  (kg  BOD5/ADMT)  required to  meet BPT performance levels  (BPT
performance levels are defined in Section 9.2). Mills requiring the greatest reduction in
BOD5 discharge were assumed to have done little to implement BMP and to require major
                                        11-26

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                                               11.0 Costs of Technology Bases for Regulations
BMP upgrades. Mills requiring little reduction in BOD5 discharge were assumed to have
a strong BMP program in place and to require no farther upgrades.

Table 11-9 lists the average capital and O&M costs assigned to each level of upgrade.  As
with bleached papergrade kraft mills, a net savings in O&M costs results from an increased
recovery of pulping chemicals and energy.

11.4.4 Dissolving Kraft, Dissolving Sulfite, Papergrade Sulfite, Semi-Chemical, and Non-
       Wood Chemical Pulp Subcategories

The Agency  conducted site' visits to at least one mill in each subcategory to which BMP
apply, with the exception of a stand-alone semi-chemical mill. Based on the information
gained on these site visits and general knowledge  of the industry, the Agency classified mills
in the remaining subcategories into BMP upgrade groups as follows:
       Dissolving Kraft

       Dissolving Sulfite
- Major BMP upgrade required;

- Major BMP upgrade required;
       Papergrade Sulfite        - Major BMP upgrade required;

       Semi-Chemical           - Moderate BMP upgrade required; and

       Non-Wood Chemical Pulp - Moderate BMP upgrade required.

Table  11-9 presents the average capital and O&M costs assigned to each subcategory.
Dissolving kraft mills were assumed to have costs similar to bleached papergrade kraft and
unbleached kraft mills, and are also  assumed to  realize  a net savings  in O&M from
increased recovery of pulping chemicals.

Sulfite, semi-chemical, and  non-wood  chemical pulp mills were assumed to have .lower
average capital investment costs than kraft mills, because kraft mills are typically larger and
more complex. The average savings in pulping chemical and energy costs realized at sulfite
and non-wood chemical pulp mills is typically less than at kraft mills. For this reason, O&M
cost  savings were assumed to balance any additional O&M costs resulting from spill
prevention and control, and net O&M  costs for these subcategories are zero.

Semi-chemical pulp mills  were assumed to incur  a net O&M cost due to BMP, because
some mills do not recover base  pulping chemicals  from spent pulping liquor.   Savings
resulting from lower waste loads in wastewater treatment  were accounted for during
estimation of end-of-pipe treatment costs (see Section 11.6.5).

The  total capital cost to  the industry  to implement BMP is 86 million dollars with an
associated O&M savings of 22 million dollars per year.
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                                             11.0 Costs of Technology Bases for Regulations
11.5  Flow Reduction Costs

This section presents the technical data and methodology used to develop cost estimates for
the flow reduction technologies that are part cif the BPT and PSES options described in
Section 9.

BPT Option 1 and Option 2 performance levels are normalized to production (i.e., kg of
TSS or BOD5/off-machine metric ton (OMMT) of final production).  These mass-based
levels are derived from effluent concentrations (resulting from end-of-pipe treatment) and
effluent flow (resulting from in-process water conservation practices).  The relationship
between effluent concentrations and flow is illustrated below:
       5
      a
                        BPT/BCT Performance Level
                               (kg/metric ton)
                  Production Normalized Flow (L/metric ton)
The equation of the line plotted above is:
                                    C =
PNL
PNF
(3)
where:
       C     =     Concentration, kg/L

       PNL  =     BPT/BCT Performance Level, kg/OMMT (a constant)

       PNF  =     Production normalized flow, L/OMMT.
                                       11-28

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                                               11.0  Costs of Technology Bases for Regulations
 As shown in the graph, there are an infinite number of mill modes of operation, in terms
 of final effluent flow and concentration, that achieve  a fixed BPT/Best Conventional
 Pollutant Control Technology (BCT) performance level.  For example, at a very low flow,
 a high concentration can achieve a fixed performance level (in the equation above, as PNF
 decreases, C increases).  Conversely, at a high flow, a very low concentration is required.

 Secondary biological treatment cannot achieve complete removal of BOD5 and TSS. There
 is a lowest concentration that secondary treatment can achieve due to its physical and
 biological limitations.  Mills  that treat wastewater to low concentrations, but have poor
 water conservation practices evidenced by high production normalized flows, cannot achieve
 the production normalized mass loads achieved by the best performing mills.  These mills
 will require 'in-process flow reduction to meet BPT.

 The amount of flow reduction a  mill requires to achieve the BPT performance levels
 depends on the lowest concentration that secondary treatment can achieve.  In lieu of
 performing treatability studies to determine  the  lowest concentration that secondary
 treatment can currently achieve  for pulp  and paper wastewaters, the Agency  instead
 analyzed secondary treatment system effluent concentrations currently demonstrated by the
 industry.  Specifically, the Agency  analyzed data from the mills whose  data were  used to
 develop the BPT performance levels. For each subcategory, the Agency determined the
 lowest currently demonstrated concentrations using the average of the lowest two or three
 BOD5 concentrations achieved by mills representing that subcategory and the average of the
 corresponding total suspended solids (TSS) concentrations achieved by those mills. Table
 11-10 lists the lowest currently demonstrated concentrations for each subcategory. These
 concentrations  may not  be the absolute minimum that  can be achieved by biological
 treatment; they are based upon data from the best performing mills at this time.  The
 exception to this is the Dissolving Sulfite Subcategory in which the Agency has determined
 that existing performance is uniformly inadequate, and has developed an alternative basis
 for BPT Option 2.  See  Section 9.2.4.  Based  upon these lowest currently demonstrated
 concentrations, EPA  estimated that 20 of the total 290 mills evaluated require flow
 reduction, in addition to upgraded  secondary treatment, to meet BPT Option 1. To meet
 BPT Option 2,59 mills were estimated to require flow reduction. This section describes the
 methodology and data used to estimate the costs of implementing flow reduction at these
 mills.

 11.5.1 General Approach Used to  Develop Flow Reduction Costs

 In developing flow reduction costs, the Agency focused on technologies that reduce flow
from the paper machines and pulp dryers, because these technologies are applicable to all
mills regardless of subcategory. Because most mills that require flow reduction discharge
much more wastewater than  an average mill within the  same subcategory, the Agency
assumed that mills requiring flow reduction operate open paper machines and pulp dryers
and pulping areas.  Applicable flow reduction technologies include those that provide
treatment of Whitewater to allow its reuse in stock preparation and in the pulp machine or
                                      11-29

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                                              11.0 Costs of Technology Bases for Regulations
paper machine as well as technologies that enable the mill to use less fresh water. The
Agency developed cost estimates for the following technologies:

       •      Gravity strainers with high-pressure, self-cleaning showers;

       •      Disc savealls;

       •      Vacuum pump seal water cascade systems; and

       •      Vacuum pump seal water cooling tower systems.

Costs were also estimated for flotation clarifiers for secondary fiber processing at deink mills
and screen room closure at chemical pulping mills.  Section 8.5 describes these technologies.
While  estimating the amount of flow reduction required, credit was taken for flow reduction
achieved as a beneficial result of technologies used as  the basis for other aspects of the
proposed regulation, such as condensate stripping for NESHAP and spill control for BMP.

The Agency's generalized flow reduction methodology, described in greater detail in Section
11.5.2, was to determine, for each mill, the final effluent flow reduction required to meet
mass-based BPT performance levels after secondary treatment. Then, for each mill, the
final effluent flow  reduction that would be achieved  by applying each flow reduction
technology was determined. For a specific mill, the final effluent flow reduction achieved
by each applicable technology depends upon the flow reduction achieved in the process area
where the technology is applied, the amount of wastewater discharged from the process
area, and  the mill's subcategory.   The  only  mill-specific information used in selecting
appropriate flow reduction technologies was the percentage flow reduction required and the
percentage of final production by subcategory.  Mill location was also considered for one
technology, vacuum pump seal water cooling tower systems, because it is not considered
applicable for southern mills. In some cases, more than  one technology alternative was
appropriate and the least expensive alternative was selected.,

Capital costs, including equipment, installation, freight, and piping, were calculated for each
flow reduction technology selected. Section 11.5.3 details the methodology used to calculate
capital costs.  Operating  and  maintenance  costs for  flow reduction technologies were
assumed to be zero, as discussed in Section 11.5.3.

While estimating flow reduction costs, the Agency estimated BOD5 and TSS load reductions
achieved by applying the flow reduction technologies, as weE as load reductions associated
with BAT process  changes, BMP, and  MACT.  Section 11.5.4 discusses load reductions
achieved by flow reduction technologies. Load reductions for BAT process changes, BMP,
and MACT were calculated using the same equations as the secondary treatment upgrade
 cost estimation spreadsheets discussed hi Section 11.6.
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                                              11.0 Costs of Technology Bases for Regulations
11.5.2 Flow Reduction

Section 11.5.2.1 describes the Agency's approach for calculating flow reduction required for
each mill to achieve mass-based BPT performance levels after secondary treatment and for
selecting appropriate flow reduction technologies to achieve the required flow reduction.
Section 11.5.2.2 provides an example of how the methodology described in Section 11.5.2.1
was applied to a specific mill.
11.5.2.1
Flow Reduction Methodology
For each mill, the percent reduction in final effluent flow required for the mill to meet
mass-based BPT performance levels after secondary treatment was determined as follows:

      (1)    The lowest BOD5 and TSS concentrations achievable by secondary treatment
             were determined  for each  subcategory  based on  the BOD5  and  TSS
             concentrations  currently demonstrated by mills whose data were used to
             develop the proposed BPT limitations. Table 11-10 lists these concentrations.

      (2)    The lowest BOD5 and TSS  concentrations  achievable by each  mill were
             calculated using a production-weighted average of the lowest BOD5 and TSS
             concentrations  achievable  by each subcategory  in which  the  mill  had
             production.

      (3)    The final effluent flow required for each mill to meet BPT was calculated
             once for BOD5 and once for TSS, as follows:
                                  PNFR =
                                           PNL
                                                                 (4)
            where:

                   PNFR =     Required production normalized flow, L/OMMT

                   PNL  =     Mill-specific BPT/BCT Performance Level, kg/OMMT

                   CL    =     Mill-specific lowest achievable concentration, mg/L.

            The lower of the two calculated flows was considered the  required final
            effluent flow. Calculation of the BPT long-term average load  is described in
            Section 10.2.2.
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                                              11.0 Costs of Technology Bases for Regulations
      (4)    The percent reduction in final effluent flow required for the mill to meet BPT
             performance levels after secondary treatment was calculated as follows:
                                       PNFr - PNF_
                                           PNF
                                               (5)
             where:
                   % FR =     % Flow Reduction
                   PNFC  =

                   PNFR  =
Current production normalized flow, L/OMMT

Required production normalized flow, L/OMMT
             The percent reduction in final effluent flow required for specific mills ranged
             from 1 to 86 percent.

Table 11-11 lists the percentage of final effluent flow dischaxged from the screen room,
deinking, and $tock preparation/papermaking areas for mills in each subcategory. Most of
these values  were determined from information  provided in Table F, Water Use  and
Wastestream Characteristics, of the 1990 questionnaire by mills whose data were used to
develop the BPT limitations; however, where data from the questionnaire were inadequate,
values were determined from the literature (9).

Table 11-12 lists the percent reduction in process  area wastewater discharge achieved by
applying each flow reduction technology and combinations of technologies. These values
were  determined  from vendors  and literature sources  (10,11,12) and  by using best
professional judgment. By multiplying the values  listed in Table 11-11 by those listed in
Table 11-12, the1 percent reduction in final effluent flow that could be achieved by applying
each  flow  reduction  technology  and combination of technologies was determined by
subcategory.  Table 11-13 lists these values. The data in Table 11-13, combined with the
percentage of each mill's final production in each subcategory, is the basis for selecting the
appropriate flow reduction technology(ies) to achieve the percent reduction in wastewater
flow required for  each mill.   EPA  did not consider water recycle/reuse opportunities
between processes located at the same mill, but that are in different subcategories.  This
may be possible at many  mills.

Flow reduction is also a beneficial result of technologies used as the basis for other aspects
of the proposed regulation: condensate stripping for NESHAP and spill control for BMP.
The following are flow reductions estimated by the Agency for these technologies:
                                       11-32

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                                               11.0 Costs of Technology Bases for Regulations
,,t, •••*?}'
%W$&&fa$t*i$&t$
Strip and Reuse All Condensates
Strip and Reuse Some Condensates
Strip and Reuse No Condensates
Pulping fclqutw Spill Frey«ntioB and Control {BMP)
Major Upgrade
Moderate Upgrade
No Upgrade (
flowJRfidirction^aiVOMMTCa)
'v f" $, "
7
2.5
0
" % " moor JtedBeti0n> mVOMMTta>
8
4
0
(a)Flow reduction in m3/OMMT of final production in the subcategories to which these regulations apply.

These flow reduction values were obtained from literature sources (13,14).

As discussed in Section 10.2.3.1, for mills in the Bleached Papergrade Kraft and Soda and
Dissolving Kraft Subcategories,  BAT Options 2 and 1, respectively, were selected as the
basis  for BPT costing and pollutant reduction estimates.  The technology basis associated
with these BAT options, 70% chlorine dioxide 'substitution for chlorine, was estimated to
result in negligible flow reduction benefits.  Therefore, no flow reduction benefits  were
applied for BAT process changes.  The technology basis for the  selected BAT options for
these subcategories, BAT  Option 4  and 2,  respectively, includes oxygen delignification
and/or extended cooking and is estimated to result in significant flow reduction benefits.
The Agency will consider prior to promulgation whether these flow reduction benefits will
be included in the flow reduction methodology.

For the Papergrade Sulfite and Dissolving Sulfite Subcategories,  BAT process change flow
reduction benefits were  assumed  to be  zero  because  wastewater  generated  from
implementation of the BAT  technology  basis as assumed to be routed to  wastewater
treatment rather than to chemical or heat recovery because of chemical incompatibility (e.g.,
incompatibility of sodium base bleaching chemicals with magnesium base pulping chemicals).
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                                               11.0 Costs of Technology Bases for Regulations
11.5.2.2
             Example Application of Flow Reduction Methodology
The Agency's flow reduction methodology is illustrated by the following example. Example
Mill 1 from Section 10.2.2. has final production in three sub categories, as shown below:
t $a$K9tteg&$ - , ;''
Secondary Fiber Non-deink
Fine and Lightweight Paper From
Purchased Pulp
Tissue, Filter, Non-woven and
Paperboard From Purchased Pulp
: s ' f ttytff
1' ftwmnitf )tttt*l %wte»&m ,
21
11
68
The lowest currently demonstrated BOD5 and TSS concentrations achievable by this mill
using secondary treatment were calculated using a production-weighted average of the
lowest currently demonstrated BOD5 and TSS concentrations achievable by each subcategory
using secondary treatment listed in Table 11-10. These calculations are shown belo'w:
                                           (PiXCn)
                                                                               (6)
where:
      CL

      n
             =     Mill-specific lowest currently demonstrated concentration, mg/L

             =     Number of subcategories in which the mill has production

             =     % of total mill production in subcategory i

             =     Lowest currently demonstrated concentration, subcategory i (from
                   Table 11-10), mg/L

Substituting data specific to this  mill results in the following:

      TSS CL      =     (0.21)(6.5) + (0.11)(12.9) + (0.68)(4.9) = 6.1 mg/L

      BOD5 CL    =     (0.21)(5.8) + (0.11)(15.1) + (0.68)(4.0) = 5.6 mg/L
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                                            11.0 Costs of Technology Bases for Regulations
This mill's effluent flow  required to meet mass-based BPT performance levels after
secondary treatment (BPT Long-Term Average Load) was calculated once for BOD5 and
once for TSS for each BPT option. These calculations are shown below:
                                 PNF
                                                                   (7)
      where:

            PNFR  =    Required production normalized flow, L/OMMT

            PNL   =    Mill-specific BPT/BCT performance level (calculated in Section
                        10.2.2), kg/OMMT

            CL     =    Mill-specific lowest achievable concentration, mg/L.

Substituting data specific to this mill gives:

BPT Option 1
             '      =  1.47 kg/OMMT   1,000,000 mg =        L/OMMT
                        6.1 mg/L           kg                 '
                    __ 1.26 kg/OMMT    1,000,000 mg =               MT
            5     R      5.6 mg/L            kg                 '
BPT Potion 2
TSS pNp  =  1.13 kg/OMMT
        R       6.1 mg/L
                                        1,000,000 mg =       Q L/OMMT
                                            kg
        BOD5 PNFR = 0.69 kg/OMMT x 1,000,000 mg =       Q L/OMMT
            5     R      5.6 mg/L            kg
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                                             11.0 Costs of Technology Bases for Regulations
The lower of the TSS or BOD5 flows is considered the required final effluent flow for each
BPT option. Therefore, the required final effluent flows for this mill are:

      Option 1 - 225,000 L/OMMT

      Option 2 - 123,000 L/OMMT

This mill currently discharges 212,000 L/OMMT, less than the  Option 1 flow; therefore,
flow reduction is  not required to meet mass-based performance'levels after secondary
treatment for Option 1.

This mill's percent reduction in final effluent flow required to meet BPT Option 2 after
secondary treatment was calculated as shown below:
                                      PNFC - PNF,
                                          PNR.
(8)
      where:

             % FR =     % flow reduction

             PNFC  =     Current production normalized flow, L/OMMT

             PNFR  =     Required production normalized flow, L/OMMT

Substituting data specific to this mill gives:

BPT Option 2


                        = 212,000 L/OMMT - 123,000  L/OMMT
                                    212,000  L/OMMT
The required percent flow reduction calculated above was adjusted by  applying flow
reduction achieved from NESHAP and BMP technologies, if applicable. Because NESHAP
and BMP do not apply to this mill, the estimated flow reduction required  remains at 42
percent.

This mill makes paper, so papermaking flow reduction technologies are applicable to this
mill.  The percent flow reduction achieved by any flow reduction technology(ies) is
calculated using a production-weighted average of the percent flow reduction values listed
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                                               11.0  Costs of Technology Bases for Regulations
in Table 11-13. For the example mill, the percent reduction in final effluent flow achieved
by application of a vacuum pump seal water cascade system is calculated as follows:
                                     = E
                                               (9)
      where:
             n
             Pi
                FRcsi
Data for this mill are:
% total mill flow reduction achieved by using a vacuum
pump seal water cascade system

Number of  subcategories in  which  the mill  has
production

Proportion of total mill production in subcategory i

% reduction in final effluent flow achieved by cascade
system, subcategory i (from Table 11-13)
• * ~ . ******
Secondary Fiber Non-Deink
Fine and Lightweight Paper from Purchased Pulp
Tissue, Filter, Non-woven and Paperboard from
Purchased Pulp
F, „
0.21
0.11
0.68

- » **«
12
14
14

Substituting these data into the above equation gives:
  % FRCS = (0.21)(12)+(0.11)(14)+(0.68)(14) = 14%
This calculation process can then be repeated for each flow reduction technology
appropriate for this mill.  The flow reduction achieved by all appropriate flow reduction
technologies for the example mill is shown below:
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                                               11.0 Costs of Technology Bases for Regulations
Mlsole^
Gravity Strainers with High-Pressure
Showers (Strainers)
Disc Saveall (Saveall)
Strainers plus Saveall
Vacuum Pump Seal Water Cascade System
(Cascade System)
Vacuum Pump Seal Water Cooling Tower
System (Cooling Tower)
Strainers plus Saveall plus Cascade System
Strainers plus Saveall plus Cooling Tower
Strainers plus Cascade System
Strainers plus Cooling Tower
Pifew jppLfbefw*ifta
•• ** ff. S
42
41
62
14
24
75
86
55
67
As  shown in  the  table  above,  six flow reduction technology alternatives provide flow
reduction equal to or greater than the 42 percent estimated as necessary to achieve BPT
Option 2. The technology selected for the example mill, gravity strainers with high-pressure
showers, was the lowest cost alternative.

11.53  Cost Estimation

Capital costs, including equipment, installation, freight, and piping, were calculated for each
type of flow reduction technology selected for installation.  All capital cost's were adjusted
by a factor of 1.3 (identical to factors used to calculate the end-of-pipe treatment upgrade
cost estimates discussed  in  Section 11.6) to account for  contingencies,  overhead,  and
engineering.

Operating and maintenance costs were not estimated but assumed to be zero. For most of'
the flow technologies considered, the Agency believes that costs associated with operation
and maintenance of new equipment will be offset by savings in recovered fiber, purchase of
process water or treatment of raw water, and energy savings associated with reusing heated
process water.
                                        11-38

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                                              11.0 Costs of Technology Bases for Regulations
Equipment costs were not estimated for mills requiring less than 5 percent flow reduction.
Instead, a $100,000 capital cost for these mills was estimated, which includes engineering
and minor water conservation projects that typically would be completed in-house.

Capital costs for each flow reduction technology were estimated as described below.
11.5.3.1
Gravity Strainers With High-Pressure, Self-Cleaning Showers
One gravity strainer, with a set capital cost of $125,000 (not including the 1.3 adjustment
factor described above), was installed for each pulp/paper machine.  The gravity strainer
capital cost was provided by a vendor (15).

The number and type of high-pressure, self-cleaning showers costed to replace current
machine showers depends upon the type and number of pulp/paper machines operated (fine
papers, market pulp, paperboard, newsprint, or tissue). Forming section showers and press
section showers are estimated to cost $12,900 and $10,600 each, respectively. The number
of forming section showers and press section showers required varies by the type of product,
as follows:
, " Product *fy|»e j
Fine Paper
Paperboard
Market Pulp
Newsprint
Tissue
derating Section "
1
1
1
2
2 .
.Press Section ;
3
3
3
4
1 '
The number, type, and capital cost of showers required for each type of machine were also
provided by a vendor (15).
11.5.3.2
Disc Savealls
Capital costs for disc savealls were based upon cost curves developed for a range of machine
sizes for each type of pulp machine and pulp dryer (fine papers, newsprint, tissue, market
pulp, and paperboard).  These cost curves are included in a document entitled "Detailed
Description of the Flow Reduction and End-of-Pipe Treatment Design and Cost Models,"
in the  Record  for the  Rulemaking.  The cost  of one saveall of appropriate size was
estimated for dach type of machine operated. These costs were provided by a vendor (16).
                                       11-39

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                                              11.0 Costs 
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                                              11.0 Costs of Technology Bases for Regulations
reduction achieved by the technology.  For example, if the final effluent flow reduction for
a technology alternative is 40 percent, the calculated TSS reduction is 30 percent (75 percent
of 40 percent). This assumption is based on information from the literature (14); specific
documentation for this assumption is included in a document entitled, "Detailed Description
of the Flow Reduction and End-of-Pipe Treatment Design and Cost Models," in the Record
for the Rulemaking.  The Agency assumed corresponding BOD5  reductions equal to 25
percent of the TSS reduction, based on best professional judgment.

TSS reductions resulting from installing flotation clarifiers at deink mills were based on
values provided by a vendor (10).  Reductions vary with flow rate in the deinking process
area with an approximate range of TSS reduction from 225 to 1,800 kg/day. The Agency
developed a TSS reduction curve to estimate the reduction. This reduction curve is included
in the Record for the Rulemaking. Again, BOD5 reductions were assumed equal to 25
percent of the TSS load reduction.

TSS reductions resulting from screen room closure are 15 percent and 19 percent of total
TSS load to wastewater treatment for bleaching and non-bleaching mills, respectively.  BOD5
reductions resulting from screen room closure were  estimated to be 15 percent and 25
percent of total BOD5 load to wastewater treatment for bleaching and non-bleaching mills,
respectively. These values were determined using best professional judgment, based on an
assumed 95 percent reduction of estimated TSS and BOD5 loads from the screen room and
the percent reduction in final effluent flow achieved by screen room closure.

11.5.5 Cost Results

Table 11-14 summarizes total costs for flow reduction, and the  number of mills for which
each  flow reduction technology was costed, for BPT Options 1 and 2.  Twenty-six mills,
require flow reduction at Option 1 and 59 mills require flow reduction at Option 2.

11.6  End-of-Pipe Treatment Costs
             1

This section presents the technical data and methodology used to develop cost estimates for
the end-of-pipe  treatment technologies  that are part of the  BPT options  described in
Section 9.2. These options are based on the performance of the  best mills, in terms of
production normalized  load of  BOD5  discharged.   These  best  mills achieve  their
performance using many different combinations of water conservation and wastewater
treatment.   For  each mill to which BPT applies, the Agency estimated the cost of a
combination of technologies  that will achieve BPT performance, in order to estimate the
economic impact  of  the proposed regulations.   The  costed technologies are  not  a
prescription for compliance.  Each mill will choose its own approach to complying with its
permit limitations.
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                                              11.0 Costs of Technology Bases for Regulations
This section also describes the estimation of the increased amounts of solid waste that would
be generated as a result of the end-of-pipe treatment system upgrades and the associated
handling and disposal costs.

11.6.1 Approach to Estimating End-of-Pipe Treatment Costs

The Agency estimated the cost for each mill to achieve target BOD5 and TSS production
normalized loads for BPT Options 1 and 2 using in-process flow reduction (described in
Section 11.5) and/or end-of-pipe treatment.  Section 10.2 details the calculation of target
BOD5  and TSS loads for each mill based  on the long-term average loads  for each
subcategory.

In general, the following steps were used to estimate the cost of end-of-pipe treatment:

      •     Mills that required wastewater treatment upgrades to meet target BOD5 and
             TSS loads for BPT Options 1 and 2 were identified;

      •     Wastewater treatment upgrades that would enable each  mill  to meet  the
             target loads were selected;

      •     The capital and operating and maintenance (O&M) costs  to implement  the
             selected upgrade for each mill 'were estimated; and

      •     The energy consumption and solid waste generation due to the  treatment
             system upgrades for each mill were estimated.

Wastewater treatment system upgrades that would .enable each mill to meet target BOD5
and TSS loads for BPT Options 1 and 2 were selected.  Because the most common end-of-
pipe treatment currently in place at pulp and paper mills is biological treatment, including
basins (aerated and non-aerated) and activated sludge treatment systems, these technologies
became the basis for the wastewater treatment upgrades designed and costed.  The specific
upgrades are outlined in Sections  11.6.2.

Primary treatment is an integral part of biological treatment. More than 75 percent of all
mills with biological treatment have primary treatment; mechanical clarifiers are the most
common type of primary treatment in place at these mills. Mechanical clarifiers reduce
solids loads to subsequent biological treatment systems, improving their operating efficiency.
In activated sludge  systems, primary  clarification is particularly  necessary because'it also
reduces the volume of aeration tank and secondary; clarification required. The Agency did
not have sufficient data to determine, on a mill-specific basis, whether the primary treatment
in place is adequate.  To  simplify the cost estimation process, primary treatment upgrades
were not included for mills that currently have primary treatment.  A complete treatment
system,  including primary  clarifiers,  was included in  the estimated  costs for  mills that
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                                              11.0  Costs of Technology Bases for Regulations
 currently have no wastewater treatment.  Clarifiers were included as part of all greenfield
 treatment systems, both basin systems and activated sludge systems.

 11.6.1.1      General Assumptions for Estimating End-of-Pipe Treatment Costs

 To estimate end-of-pipe treatment costs, the Agency made the following assumptions about
 each mill:

       •     The wastewater treatment  operations at each mill are the same  as those
             existing in 1989, based on the information reported by each mill in the 1990
             questionnaire;

       •     Each mill will continue to make the same mix of products at the same rate
             that it did in 1989, independent of wastewater treatment system upgrades
             implemented to achieve target loads;

       •     The wastewater treatment system at each mill will operate 365 days per year;

       •     The number of production days per year at each mill is 350 days; this number
             was used to  convert production normalized loads to concentrations;

       •     The primary wastewater treatment operations at each mill are adequate to
             precede end-of-pipe biological treatment; and

       •     Each mill will continue to generate the same final effluent flow regardless of
             upgrades  made  to the wastewater  treatment system except when flow
             reduction was required  to achieve target concentrations.

Some mills could not achieve target BOD5 or TSS loads for BPT Options 1 and 2 with end-
of-pipe treatment alone because their target BOD5 and TSS concentrations were lower than
the lowest  currently demonstrated concentrations.  Therefore,  these mills  required flow
reduction to increase their target concentrations. Section 11.5 describes the calculation of
target and lowest currently demonstrated concentrations and the flow reduction technologies
costed for these mills. The technologies that reduce flow also reduce BOD5 and TSS loads.
Flow reduction, if required, was applied to a mill first; the revised final effluent flow rates,
BOD5 load, and TSS load achieved with flow reduction were entered into models to design
and cost end-of-pipe wastewater treatment upgrades that would enable the mill to achieve
target loads.  The above assumptions  were then applicable to the revised flows and loads.
For some mills, target BOD5 and TSS loads were met with flow reduction, and end-of-pipe
treatment costs were not estimated.
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                                              11.0 Costs of Technology Bases for Regulations
11.6.1.2      Design and Cost Model Selection

The Agency selected a combination of models to design and cost basin and activated sludge
wastewater treatment upgrades.  Because the critical operating parameters for basin and
activated sludge systems are different, separate models were necessary to design and cost
upgrades for each type of treatment Each mill was placed into one of two groups according
to the type of biological wastewater treatment it has in place. If a null has activated sludge
treatment, it was grouped as .such; all  other mills,  including mills  with  no wastewater
treatment or only primary treatment, were initially grouped as basin mills.  Section 11.6.6
discusses the number  of  mills  for which basin  and activated sludge treatment system
upgrades were costed.

       Basin Design and Cost Model
                      i
The model used to  design and cost basin upgrades was the Computer Assisted Procedure
for Design and Evaluation of Wastewater Treatment Systems (CAPDET).  The  general
purpose of CAPDET  is to estimate planning level  costs for the preliminary  design of
wastewater. treatment systems. CAPDET uses a "screening" methodology to estimate costs,
which  involves designing several alternative treatment systems that meet specified  effluent
criteria and then ranking each alternative that'meets the criteria in order of least annual
cost (17).

CAPDET is primarily a costing tool. The planning level costs estimated by CAPDET have
an accuracy of _±15  percent  for capital costs and ±20  percent for  operation and
maintenance costs; these costs are based on a knowledge of basic treatment operations and
the use of cost curves (17).

CAPDET combines parametric and unit costing methods to estimate the direct construction
costs for the treatment system.

Parametric costing is used to estimate the more site-specific types of construction costs, such
as labor and electrical and mechanical components.  Costs of these components are
estimated as a function of-one distinguishing operating or design parameter of the treatment
system such  as flow or surface area.  The quantity cost curves for several construction
components were developed by EPA from a statistical analysis of national average data for
facilities similar  in size and scope and are contained  in the EPA publication  entitled
"Construction Costs for Municipal Wastewater Treatment Plants" (FRD11) (17).

Unit costing is used to estimate costs for unit processes.  CAPDETs unit costing method
allows the user to  input unit  prices for major cost items  of  a unit process, including
equipment, installation, and structural materials.   Associated minor costs are usually
calculated as a percentage of the costs of major  items (17).
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                                              11.0 Costs of Technology Bases for Regulations
 CAPDET does  not perform mathematical optimization of treatment design and is not
 considered a process simulation design model; instead, CAPDET uses generally accepted
 design equations and simplifying assumptions to develop preliminary designs of wastewater
 treatment unit(processes (17). This simplified approach is particularly appropriate for basin
 designs because  it focuses on independent basin units whose primary design considerations
 are aeration and volume.

 CAPDET was selected to design and cost basin upgrades for several reasons, including:

       •     CAPDET requires relatively few input parameters to estimate planning level
             costs. The inputs for  each mill required by CAPDET were available from
             responses to  the 1990 questionnaire or could be estimated from  industry
             averages.
              i
       •     CAPDET has unit process modules to  design and  estimate costs for large
             flows, 378,540 m3 (100 million gallons/day),  and therefore is applicable to
             most pulp and paper mills.

       •     CAPDET allows input of current unit prices for equipment and other related
             construction costs.

       •     CAPDET is  a costing  tool and  does not  attempt  to rigorously design
             wastewater  treatment processes.   This approach  is appropriate  for the
             estimation of costs for end-of-pipe treatment upgrades.

 The specific CAPDET design and cost modules used to cost basin upgrades were modules
 for aerobic aerated lagoon, aerated facultative lagoon,  and facultative lagoon  (17).
 Section 11.6.2 discusses in further  detail the application of these modules to the costing of
 basin upgrades for pulp and paper mills.

 An additional computer program was used as a supplement to  the design model for basin
 upgrades. The program optimizes  the detention time requirements for a two-lagoon system
 comprising an aerated lagoon followed by an aerated facultative lagoon.  The program
 calculates, by an iterative  algorithm, the minimum detention time required in both lagoons
 to achieve  the desired BOD5 removal.  Minimal detention times require  lower lagoon
volumes and thus lower land and construction costs. Section 11.6.3 explains the use of this
program with the CAPDET modules mentioned previously.

Another model used for basin upgrade costing was a mathematical model developed by
NCASI for polishing ponds described in "Development and Application of a Mathematical
Model for  Predicting BOD and  TSS Removal  in Polishing  Ponds Following Aerated
Stabilization Basins" (NCASI Technical Bulletin No. 550). This model is a diagnostic model
(rather than a costing model) that simulates the particular system in which a polishing pond
follows an aerated stabilization basin (ASB) to identify parameters that most impact system
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                                              11.0 Costs of Technology Bases for Regulations
performance. This model was used primarily to compare and verify the design assumptions
and algorithms used in the model to estimate costs for water treatment upgrades described
in Section 11.6.2.

      Activated Sludge Design and Cost Models

CAPDET was used to estimate the costs of activated sludge treatment system upgrades.
The design portion of CAPDET was not used, however, because activated sludge systems
are more  intensively  engineered than basin systems  and therefore require  a more
sophisticated design model than CAPDET.  Activated sludge systems are complex systems
comprising two interdependent unit processes: aeration tanks and mechanical clarifiers.
Therefore, an analysis of the interdependent operating conditions was necessary to evaluate
the impact of various upgrades on system performance.

To design activated sludge treatment system upgrades, the Agency used a spreadsheet model
that simulates the existing treatment system at a facility based on available operating and
design information. Where actual operating and design information were not available, the
Agency used values for these parameters based on best professional judgment.  Once the
existing system  was simulated, a treatment  upgrade was designed that  improved the
performance of  the existing system to enable  the facility to meet target BOD5 and  TSS
concentrations.  Section 11.6.2 describes the particular  upgrades that were designed and
costed for activated sludge systems.

11.6.2 Development of Design and Cost Models

This section describes the specific wastewater treatment upgrades that were costed and how
the models described in Section 11.6.1.2 were modified  to estimate costs of upgrades
necessary for pulp and paper mills to achieve BPT Option. 1  and Option 2 performance
levels.
             Basin Design and Cost Model

Eight basin treatment upgrades were considered for each mill:

       •     Additional aeration in existing basins;

       •     Additional aeration in existing basins and new aerated facultative lagoon (in
             addition to existing basins);

       •     Single aerated facultative lagoon (in addition to existing basins);

       •     Two lagoons (in addition to existing basins): aerobic aerated lagoon followed
             by aerated facultative lagoon;
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                                               11.0  Costs of Technology Bases for Regulations
       •     Polishing pond (in addition to existing basins);

       •     Polishing pond (in addition to existing basins) and additional aeration in
             existing basins;

       •     Polymer addition in existing basins; and

       •     Primary clarification (installed as part of a greenfield treatment system at
             mills that have no wastewater treatment in place).

Figure 11-1 shows the logical sequence in which basin upgrades were designed, costed, and
selected.  The applicability of each upgrade to a mill depended upon the required BOD5
and TSS removals and the treatment in place. Not all upgrades were applicable to each
mill, but sometimes several different upgrades could enable a mill to achieve target loads.
For mills that currently have no wastewater treatment, primary clarification was designed
and costed in combination with a lagoon or polishing pond upgrade to comprise a greenfield
treatment  system.  In some cases,  however,  target loads were achieved with  primary
clarification as a stand-alone upgrade. When more than one possible upgrade was designed
and costed for a mill, the model selected the upgrade with the lowest total annualized cost.
The total annualized cost calculation is described in Section 11.6.5.3.

Selected CAPDET modules were used to design  and cost all the upgrades except polymer
addition and primary clarification. Not all of CAPDETs specific equations and assumptions
reflect actual conditions at pulp and  paper  mills, although  the basic design equations still
apply.   Accordingly,  the  equations  and algorithms  suitable for costing upgrades were
extracted from the documentation for each  CAPDET module and built into a spreadsheet
model.   In most cases,  significant  portions  of each module  remained  intact  in the
spreadsheet model.  Extracting module equations into a spreadsheet had several advantages
because it allowed for the following:

       •     Modification of equations to better suit the designs of basin upgrades for pulp
             and paper mills;

       •     Selection of only those equations required for estimating costs;

       •     Input  of additional data not normally entered in the original version of
             CAPDET; and

       •     Assigning fixed values to design and operating variables appropriate for pulp
             and paper mill wastewater.

The CAPDET modules on which the design and cost equations for the basin upgrades are
based are listed in Table 11-15. The  document entitled "Detailed Description of the Flow
Reduction and End-of-Pipe Treatment Design and Cost Models" found in the Record for
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                                              11.0 Costs of Technology Bases for Regulations
the Rulemaking provides a detailed description of the modifications made to the CAPDET
modules, design and operating parameters,  and other assumptions used for  each basin
upgrade.

The polymer addition upgrade was developed based on best professional judgment. Polymer
addition was designed and costed for mills that require no BOD5 removal, but do require
TSS removal less than 5 mg/L or 20 percent of the current TSS load to meet target loads.
Polymer is added to the existing basin treatment system at a rate of 5 mg/L based on the
final effluent flow rate.  This upgrade is also discussed in the "Detailed Description of the
Flow Reduction and End-of-Pipe Treatment Design and Cost Models."

Primary clarifiers were designed using an algorithm  to calculate  the clarifier diameter
required to obtain a weir overflow rate (in m3/day/m2) typical of primary clarifiers used in
the pulp and paper industry. The design algorithm is  also described more completely in the
"Detailed Description of the End-of-Pipe Treatment Design and Cost Models." The number
and size of primary clarifiers were then entered into the activated sludge cost model
(described in Section 11.6.2) to estimate costs for this upgrade.
11.6.2.2
Activated Sludge Design Model
Activated sludge systems typically consist of one or more aeration basins or tanks followed
by sedimentation clarifiers.   Activated sludge systems reduce BOD5 by microorganism
digestion at a much greater rate than aerated basin systems.  The faster digestion rate
produces more biological solids in the aeration tank that require settling in a mechanical
clarifier. A portion of the settled solids in the clarifier are removed as waste sludge, with
the remaining sludge returned to the aeration tank to maintain a stable, active population
of microorganisms.

Upgrades for activated sludge systems are  difficult to define because performance often
relies on the complex interdependence of the aeration tank and clarifier, the manner in
which the system is operated, and not necessarily on the equipment type or capacity. Simple
expansions or additions are  not easily implemented, as minor changes  can impact
performance. Therefore, a more detailed analysis than was required for basins was required
to design an appropriate and realistic upgrade of the activated sludge system at each mill.

The activated sludge design model  allowed the user to identify aspects of the activated
sludge system that were inadequate to meet target BOD5 and TSS loads. The user analyzed
the activated  sludge treatment system in  place at each  mill and designed  alternative
upgrades by the following steps:

      •     Summarizing design and operating data;

      •     Mathematically simulating the current treatment at each mill using summary
             data; and
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                                               11.0 Costs of Technology Bases for Regulations
       •     Modeling alternative designs to achieve target BOD5 and TSS loads for BPT
             Options 1 and 2.

Upgrades were selected based on an alternative design that achieved target loads.  The
major design and operating parameters, calculations, and assumptions used in the design
model to perform each step of this analysis are described in "Detailed Description of the
Flow Reduction and End-of-Pipe Treatment Design and Cost Models."

Increased BOD5 and TSS removals in activated sludge systems cause related changes in
waste activated sludge generation. The model calculated new clarifier loadings and recycle
ratios to determine the additional quantity of waste activated sludge requiring handling and
disposal. Section 11.6.2.3 describes the separate program developed to estimate costs for
additional sludge handling and disposal.

Potential upgrades to existing activated sludge treatment to achieve target BOD5 and TSS
loads are summarized below:

       •     Additional aeration tank volume;

       •     Additional aeration;

       •     Additional secondary clarification (after activated sludge aeration tanks);

       •     Polymer addition;

       •     Operational modifications; and

       •     Primary clarification (installed with a greenfield system at mills that have no
             wastewater treatment in place).

Additional aeration tank volume, aeration, and secondary clarification were selected based
on the design analysis of the existing activated sludge treatment described above. Polymer
addition was selected, based upon best professional judgment, to achieve incremental TSS
removals required to meet target loads. Depending on the requirements for each mill to
meet target  loads, each of these upgrades except operational modifications may have been
selected individually or in combination. Operational modifications were selected when the
existing activated sludge system had sufficient capacity  to achieve the required BOD5 and
TSS removals but was not effectively operated. As with basin costing, primary  clarification
was costed as part of a greenfield activated sludge system for mills that  have no wastewater
treatment in place.  In some cases, target loads were achieved with primary  clarification
only, and primary clarification was therefore designed and costed as a stand-alone upgrade.
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                                              11.0 Costs of Technology Bases for Regulations
11.6.2.4      Sludge Handling, Dewatering, and Disposal

The wastewater treatment system upgrades that are the technology basis of the proposed
BPT effluent limitations guidelines generate increased amounts of wastewater treatment
sludges.  The Agency estimated the cost for the industry to handle and dispose of this
increased amount of sludge. Unlike the approaches used to estimate the cost of upgrades
to the wastewater treatment systems (described in 11.6.2.1 and 11.6.2.2), specific sludge
management technology  upgrades were not designed.  Thus,  costs for specific sludge
handling equipment and operating practices were not estimated.  Instead,  the Agency
estimated the increased mass of sludge resulting from the treatment system upgrades, as well
as site-specific sludge management and  disposal  costs  ($/metric ton of sludge), and
calculated the incremental sludge management cost.

Wastewater treatment sludges are generated by primary settling basins and clarifiers, by
aerated and unaerated basins,  and by activated sludge treatment systems.

The Agency assumed that mills will incur no additional costs to manage and dispose of the
increased amounts of sludge that result from upgrades to aerated and  unaerated basins.
Current practices typically involve dredging basins every three to five years and disposing
of the dredged solids. Some  mills reported that they have never dredged their basins.
Accordingly, the Agency believes that current mill practices are sufficient to handle the
increased sludge load at essentially no additional cost, or, if there are incremental  costs,
these costs would be minimal and not possible to estimate with  any reasonable degree of
accuracy.

Incremental sludge management and disposal costs were estimated for increased amounts
of sludge resulting from upgraded activated sludge  treatment  systems.  The  increased
amount  of  activated sludge generated was estimated by first using the design model
described in Section 11.6.2.2 to simulate the performance of the  existing treatment system
and to estimate the sludge generation rate of this modeled system.  Then, an appropriate
treatment system upgrade was designed to enable the treatment system to achieve the target
loads and the sludge generation rate of the upgraded  system was estimated. The increase
in sludge generation resulting from achieving the BPT Option 1  and 2 performance  levels
were  defined as the difference between the two modeled sludge  generation rates.  The
activated sludge design model was also used to estimate the  sludge generation rate in
primary clarifiers for greenfield treatment  systems (basin or activated sludge).

Once the increased amount of activated and/or primary sludge was estimated for each mill,
a. separate program that calculates mill-specific unit costs was used to estimate capital and
annual O&M costs for sludge handling and disposal; these costs were then entered into the
activated sludge cost model to be included in 'the total capital and O&M compliance costs
for each mill. This program is described in more detail in "Detailed Description of the Flow
Reduction and *End-of-Pipe Treatment Design and  Cost Models."
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                                              11.0 Costs of Technology Bases for Regulations
11.6.2.3
Activated Sludge Cost Model
This section describes the algorithms used to estimate costs for implementing the upgrades
to activated sludge treatment discussed in the previous section. The costing algorithms for
additional aeration volume and additional clarification (both primary and secondary) were
based on the CAPDET module for high-rate activated sludge and secondary clarification,
respectively.

The costs for additional aeration and polymer addition were estimated by the algorithms
used in the basin design and cost model described  in Section  11.6.2.1.  Operational
modifications were estimated to have zero capital and O&M costs as they require minimal
or no additional equipment,  labor-hours, chemicals, or energy.

"Detailed Description of the  Flow Reduction and End-of-Pipe Treatment Design and Cost
Models" further describes the  modifications made to the CAPDET modules, design and
operating parameters, and other assumptions used for each activated sludge upgrade.

11.6.3 Sources of Operating and Maintenance Costs

Components of operating and  maintenance costs for basin and activated sludge upgrades
include the following:

      •      Chemicals

      •      Energy

      •      Labor

Table 11-16 summarizes unit costs used to estimate operating and maintenance (O&M)
costs for upgrades to basin  and activated  sludge treatment.  The  source of each cost is
presented in a memorandum entitled "Pulp and Paper Operating Costs"  dated September
1, 1993, found in the Record for the Rulemaking.  All of the unit costs discussed in this
section were scaled to fourth  quarter 1991 dollars using the Chemical Engineering composite
index. The fourth quarter index for 1991 is 361.1.

Sludge handling and disposal costs were mill-specific based on data submitted in response
to the 1990 questionnaire.  These costs were also scaled to fourth quarter 1991 dollars using
the Chemical Engineering Composite Index.

11.6.4 Sources of Capital Costs

This section describes the components of direct capital costs for basin and activated sludge
wastewater treatment system upgrades, the sources from which these costs were obtained,
and the actual costs used in the cost models described in Section 11.6.2.
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                                              11.0 Costs of Technology Bases for Regulations
11.6.4.1
Direct Capital Costs
Components of direct capital costs for basin and activated sludge upgrades include the
following:

      •     Equipment (purchase and installation);

      •     Construction materials and excavation;

      •     Land; and

      •     Other minor cost items.

The cost basis for  each of these components was obtained from one of four sources:
1) equipment  vendor quotes;  2) environmental  engineering consultants, 3)  cost data
collected by EPA for the development of costs for the pesticides manufacturing regulation
promulgated in August  1993 (these costs were reported in  1986 dollars),  and 4) mill
responses to the 1990 questionnaire. All costs obtained were scaled to fourth quarter 1991
dollars using the Chemical Engineering composite index.  The fourth quarter index for 1991
is 361.1.

Table 11-17 summarizes some of the unit costs for each component listed above and the
upgrades to which they  apply.  Each cost component is briefly discussed below. A more
detailed discussion of each component is contained in "Detailed Description of the Flow
Reduction and End-of-Pipe Treatment Design and Cost Models."

      Equipment Costs

Equipment costs included the purchase and installation cost of each piece of equipment.
Equipment costs were obtained for two major types of equipment: high-speed, mechanical
surface  aerators  and circular mechanical  clarifier mechanisms and  accessories.  The
equipment costs of 20-, 40-, 60-, and 75-horsepower surface aerators were obtained from a
vendor of pulp and paper wastewater treatment equipment. The delivered installed cost of
each aerator was estimated as approximately 10 percent of the purchase cost (18). The
aerator unit costs listed  in Table 11-17 include purchase and installation costs.

The purchase cost of mechanical clarifiers was estimated using a cost curve developed from
vendor price quotes obtained for a range of clarifier diameters; therefore, a unit  cost is not
provided in Table 11-17. Equipment installation costs for clarifiers were estimated using
CAPDET calculations that included installation labor and crane rental. Unit costs for labor
and crane rental are given in Table 11-17. The installation labor rate is the same as that
for the maintenance technician described in Section 11.6.3. The unit cost of crane rental
was scaled from the unit cost used for the pesticides manufacturing regulation.
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                                              11.0 Costs of Technology Bases for Regulations
The equipment cost for a feeder box for polymer addition was estimated based upon best
professional judgment.

      Construction Materials and Excavation

Table 11-17 lists unit costs for construction materials and excavation. Construction materials
include reinforced concrete wall, reinforced concrete slab,  clay liner, grout, and handrail.
Unit costs for concrete wall and slab, handrail, and excavation were scaled from cost data
collected for the pesticides manufacturing regulation.  Unit costs were obtained from an
engineering consulting firm for  compacted clay (19)  and from a wastewater treatment
equipment vendor for grout (20).

      Land

Costs for  aerated  lagoons and polishing ponds included purchasing additional land and
piping and pumping the wastewater, if necessary, to the new lagoon or pond. The amount
of land required for each lagoon or pond  accounts for the calculated surface  area of the
lagoon or pond, embankments, pump stations, fences, and maintenance roads and buildings.
The Agency did not include  land  costs in the total costs for activated  sludge upgrades
because these upgrades are compact, requiring minimal space and can be accommodated
by any available company-owned land.

Land  costs consisted of four components:

      •      The purchase cost of the nearest available  land;

      •      The purchase cost of right-of-way to the  nearest available land;

      •      The cost of pump stations; and

      •      The cost of pipeline.

The purchase cost of land for each mill was obtained from that mill's response  to the 1990
questionnaire.  The purchase cost of right-of-way  was  estimated as  10 percent of the
purchase cost of land.  The costs  of pipelines and pump stations were based on cost curves
developed by the  Agency.

Three scenarios existed for the application of each 'component of land  costs based on the
information obtained from the questionnaire for each mill.  Table 11-18 summarizes these
scenarios and components of land costs that were  calculated for each.

The purchase costs of land and right-of-way were added to the total direct capital cost after
the factors  for minor cost items, regional  labor (Section  11.6.4.2)  and indirect costs
(Section 11.6.4.3)  have been applied to the  other direct capital costs. "Detailed Description
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                                               11.0  Costs of Technology Bases for Regulations
of the Flow Reduction and End-of-Pipe Treatment Design and Cost Models" describes the
calculation of land cost components.

      Other Minor Cost Items

According to CAPDET documentation, approximately 90 percent of the total direct'capital
costs for lagoons, ponds and activated sludge aeration tanks and 85 percent of the total
direct capital costs for mechanical clarifiers are accounted for by the algorithms in each
module.  To account for other minor cost items, CAPDET applied a correction factor of
1.11 to the total direct capital costs, for lagoons, ponds, and activated sludge aeration tanks
and a factor of 1.18 to the total direct capital costs for mechanical clarifiers.  In the basin
cost model, the correction factor was applied to the total  direct capital costs including the
pipeline and pump station components of land costs.
11.6.4.2
Site-specific Cost Factors
A site-specific cost factor was applied to the direct capital costs, excluding the purchase cost
of land and right-of-way, for each mill. The cost factor was applied to reflect the differences
in construction and installation labor rates for various regions of the country. Cost factors
were assigned according to  the  state in which the1 mill is located. The cost factor was
applied to direct capital costs for all basin and activated sludge treatment upgrades except
additional aeration and polymer addition for basins and activated sludge because they do
not require any construction. The source of these site-specific cost factors is Development
of Cost Curves for Best Available Technology Options for Chemical Pulp Mills that Bleach
Wood found in the Record for the Rulemaking:
11.6.4.3
Indirect Capital Costs
Indirect capital costs included overhead and profit, engineering, and contingency. Each
component of indirect costs was calculated as a percentage of the total direct capital costs
excluding the purchase cost of land or right-of-way  and including the  adjustments for
regional labor and minor cost items described above. Based on values reported in literature
including  the development documents for other rulemakings, total indirect costs range
typically from 15 to 50 percent of the total direct costs.

The following table summarizes the allowances made for indirect cost components and the
percentage of the total direct costs used to calculate each component. Each component is
briefly described below.  '
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                                               11.0 Costs of Technology Bases for Regulations
fff
_"„"•_ Infitreet Cast Cemponent " •
ff ^ '•
Overhead and Profit
Engineering
Contingency
I
Allowance M % of Bireet Capital ; ;
" - * Carts - *" ' :
•"••>, ;
10%
10%
10%
Overhead and profit covers the contractors' fixed expenses and profit margin; this was
estimated as 10 percent of the total direct costs.

Engineering costs account for the design, specifications, and inspections required to take a
project from concept to operation. Engineering services may include site surveys, soil and
groundwater investigations, and laboratory or pilot plant work.  Engineering costs were
estimated as 10 percent of the total direct capital costs.

Contingency is an allowance for errors and omissions inherent in the costs and also for
unforeseen difficulties that prolong project completion. Contingency was also estimated as
10 percent of the total direct capital costs.

Indirect costs were not included in the estimates for the additional aeration or polymer
addition upgrades for basins and activated sludge because they are simple, low-cost upgrades
that do not require large time investments or intensive engineering or construction by
contractors.

11.6.5 Application of Design and Cost Models

This section discusses how the design and cost models were used to estimate the costs for
each direct discharging pulp and paper mill to meet target BPT BOD5 and TSS loads using
secondary treatment.  The data inputs to each model and  how each piece of data was used
in the model are described.  In addition, the methodology used to account for BOD5 and
TSS load reductions achieved by implementing other regulations (BAT, NESHAP, and
BMP) is presented.
11.6.5.1
Inputs to Design and Cost Models
The input data for each mill required by the basin design and cost model, the activated
sludge design model, and the activated sludge cost model are discussed1  in  "Detailed
Description of the Flow Reduction and End-of-Pipe Treatment Design and Cost Models."
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                                             11.0 Costs of Technology Bases for Regulations
All input data were obtained from mill responses to the 1990 questionnaire.  Where data
were missing for a mill, reasonable estimates were made based on industry averages, best
professional judgment, or data transferred from a similar mill.
11.6.5.2
Load Reductions Prior to Wastewater Treatment
The implementation of BAT, NESHAP, and BMP will reduce wastewater flow and BOD5
loads to wastewater treatment.  The flow reductions have not been accounted for in the
application of the end-of-pipe treatment design and cost models. (As discussed in 11.6.1,
only flow reduction necessary to achieve BPT performance levels without exceeding lowest
achievable BOD5 and TSS concentrations was accounted for in estimating the cost of end-of-
pipe treatment)) Therefore, the resulting costs have been somewhat overestimated.  BOD5
load reductions, however, are accounted for prior to the application of wastewater treatment
upgrades for basins and activated sludge treatment systems.

BAT, NESHAP, and BMP result in BOD5 load reduction in untreated wastewater.  The new
BOD5 load in the mill effluent after the  load  reductions were applied (and  before any
treatment system upgrade was designed) was obtained by calculating the product of percent
removal across  the entire treatment system and the reduced untreated wastewater BOD5
load.

If a portion of a mill's production was in a subcategory to which a particular load reduction
did not apply, then the load reduction was prorated based on the percentage of production
to which the load reduction did apply.

An example calculation of how load reductions  were applied is given below:
                                    BOD5i - BODSe
                                         BOD5i
                             BOD5i(LR) = BOD5i - RPr
                                                                (10)


                                                                (11)
              BOD
                   5e(LR)
                                         - RT)BODSi(LR)
(12)
                                       11-56

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                                              11.0 Costs of Technology Bases for Regulations
where:
      BOD5i


      BOD5e


      BOD5i(LR)
      BOD5e(LR)
      BAT
Percent  removal  of BOD5  across  wastewater  treatment
system, %

Current  BOD5   load  influent  to  wastewater  treatment,
kg/OMMT

Current BOD5 load in final effluent from wastewater treatment,
kg/OMMT

BOD5 load influent to wastewater treatment after application
of load reduction, kg/OMMT

BOD5  load reduction  in influent  to wastewater treatment,
kg/OMMT

Percent of mill's production to which load reduction applies, %

BOD5 load in final effluent from wastewater treatment after
application of load reduction, kg/OMMT.
BOD5 load reductions resulting from process changes that form the technology basis for
BAT were applied to mills that have production in either the bleached papergrade kraft and
soda or the dissolving kraft subcategories.  The amount of BOD5 load reduction achieved
was based on the implementation of BAT Option 2.  However, many mills upgraded their
pulping and bleaching processes between 1989, the basis year for available BOD5 data, and
January 1, 1993, the baseline date for BAT  costing for technology in-place at each mill.
BOD5 load reductions associated with these pulping and bleaching upgrades were also taken
into  account. The BOD5 load reduction estimated to be achieved by implementing BAT
technologies are summarized in the table below.
.,., .--»**.**-•.;
Improved Brown Stock Washing Only
Extended Cooking .or Oxygen Delignification
Improved Brown Stock Washing (21)
Total
BOl>s Ix»a
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                                               11.0  Costs of Technology Bases for Regulations
     Extended Cooking and Oxygen Delignification
     Improved Brown Stock Washing (21)
     Total
9
4
13
To assign BOD5 load reductions to mills, each mill was placed in one of the following four
groups according to its pulping and bleaching technologies in place:

       •      Mills that do not have either extended cooking or oxygen delignification;

       •      Mills that have oxygen delignification;

       •     ' Mills that have extended cooking; and

       •      Mills that have both extended cooking and oxygen delignification.

Table 11-19 summarizes the BOD5 load reduction assigned to each group for mills in the
Bleached Papergrade Kraft and Soda  Subcategory.

For mills that have extended cooking  and/or oxygen delignification based on information
from the 1990 questionnaire, it was assumed that the  effluent BOD5 load already reflects
any reductions resulting from the technologies; therefore, a zero load reduction was assigned
to these mills. The exceptions to this rule were mills that have extended cooking, for which
a  BOD5 load reduction will result from improved  brown stock washing  (the Agency
determined that mills that have installed extended cooking do not necessarily have improved
brown stock washing whereas mills that  have  oxygen delignification typically do).   Mills
believed to have  installed extended  cooking and/or oxygen delignification  based  on
information obtained since the questionnaire was completed received BOD5 load reductions
resulting from those technologies (see table above).

Mills that  do not have either extended cooking or  oxygen delignification  require only
improved brown stock washing to match the technology basis for BAT Option 2.  These
mills received the same BOD5 load reduction regardless of whether their group assignment
was based on 1990 questionnaire responses or information obtained since the questionnaire
was completed.

Dissolving  kraft mills were assigned load reductions equal to one-half of those shown in
Table 11-19 because the Agency determined that dissolving kraft mills generally have morb
effective brown stock washing and screening, in terms of resulting black liquor loss to the
                                        11-58

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                                              11.0  Costs of Technology Bases for Regulations
bleach plant, than papergrade kraft mills due to higher product purity requirements.  Thus,
the impact on BOD5 loads due to implementing BAT process change options would be less.

BOD5 load reductions due to implementation of BAT process changes were not applied to
papergrade and dissolving sulfite mills.   Improved brown stock washing and extended
cooking were not included in the technology basis for BAT for sulfite mills and therefore
a BOD5 load reduction was not applicable due to these technologies.  Although oxygen
delignification was included as part of the technology basis for BAT for sulfite mills, the
Agency determined that the wastewater generated by  oxygen  delignification is sent to
wastewater treatment and not to a recovery system as it is in a kraft mill. Therefore, oxygen
delignification would not reduce the load of BOD5 entering the treatment systems at sulfite
mills. A BOD5 load reduction was applied to dissolving sulfite mills due to technologies that
form the basis of BAT limitations for COD; the application of pollution reductions due to
BAT is discussed in Section 10.2.3.1.

      NESHAP

The BODS load to wastewater treatment is reduced when condensate wastestreams  are
steam stripped to remove methanol and other volatile organic compounds. Section 8.4.2 and
the BID for the proposed NESHAP discuss in  detail the application of steam stripping to
pulp and paper mill wastestreams.

Load reductions due to steam stripping were applied to mills in the following subcategories:
dissolving kraft; bleached papergrade kraft and soda; unbleached kraft; dissolving sulfite;
papergrade sulfite; and semi-chemical. For the purpose of assigning BOD5 load reductions
to mills, the Agency used the following methodology.  If a  mill currently steam  strips
condensates, the raw waste load was assumed to reflect this,  and no load reduction was
assigned.  If the mill does not have steam stripping in-place, a load reduction was assigned
based on the criteria presented in Table 11-20.

Table 11-20 separates mills used for BPT costing into four groups, based on the extent that
they reuse condensates. If a mill discharges all its condensates to wastewater treatment, a
maximum raw waste load reduction of 8 kg BOD5/OMMT was applied.  This reduction is
based on a typical pulp  mill condensate raw waste load at kraft mills of 9 kg BOD5/OMMT
(22) and a 90-percent methanol (and BOD5) removal by steam  stripping. For mills that
discharge  only a portion of their pulp mill condensates to wastewater treatment, one half
of the above load reduction was applied, or 4 kg/OMMT. No load reduction was applied
for mills that do not discharge condensates to wastewater treatment.

The percent of condensates discharged and/or  reused was assessed based on responses to
a voluntary mill survey conducted through the National Council  of the Paper Industry for
Air and Stream Improvement  (NCASI) as part of the NESHAP development. In  some
cases, insufficient information was  provided  to determine whether  condensates  were
                                       11-59

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                                              11.0 Costs of Technology Bases for Regulations
discharged or reused and best professional judgement was used  to  assign BOD load
reductions.
The implementation of BMP for pulping liquor spiU prevention and control will also reduce
the BOD5 load to wastewater treatment. Mills were placed into groups based on their status
in implementing BMP as described in Section 11.4. The table below lists the BOD5 load
reductions for mills in each group resulting from implementation of BMP.
\ ™?S^\ *L-*s ^'X- -^-^ -" \ ,
Mills that require no upgrades
Mills that require moderate upgrades
Mills that require major upgrades

0
2.5
5
11.6.53
Basin Costing
Designs and costs for basin upgrades were developed using the basin design and cost model
described in Section 11.6.2.1.  However, because more than one possible upgrade was
designed and costed for many mills, a criterion for selecting among the upgrades was
required.  The criterion used to select a basin upgrade was the lowest total annualized cost
(TAG). For the purpose of identifying a least cost upgrade, TAG was calculated at a seven
percent interest rate over  15 years, as given by the equations below:
                                  GAG = 0.6 OM
                                                                              (13)
                      TAG = CAP x fl (1+I)") + OM + GAG
                                                                 (14)
where:
       GAG =    General and administrative costs, $/yr

       CAP  =    Total capital costs of upgrade (direct, indirect and land costs)
                                       11-60

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                                               11.0 Costs of Technology Bases for Regulations



       OM   =     Total O&M costs of upgrade

       1=7 percent interest rate

       n     =     15 years.

The equation simplifies to the following expression that is used in the basin design and cost
model:
                           TAG = (0.1498)CAP + (1.6)OM
                                                                  (15)
11.6.5.4
Activated Sludge Costing
Activated sludge costing was completed in three parts:

       •     The activated sludge design spreadsheet model described in Section 11.6.2.2
             was used to design  and select the appropriate upgrade(s) to the existing
             treatment system to enable the mill to meet target BODS and TSS loads. A
             summary sheet was generated describing the upgraded system.

       •     The incremental activated sludge generated at each mill, given on the design
             summary sheet, was  entered into the  sludge  handling and  disposal cost
             program described in Section 11.6.2.3. Once data were generated for all mills.,
             the cost program was run to estimate mill-specific capital and O&M costs for
             each mill.

       •     Output from the design summary sheet and the sludge handling and disposal
             cost program were entered into the activated sludge cost model described in
             Section 11.6.2.4, and total  capital and O&M costs  of the recommeijHed
             upgrade(s) to treatment at each mill were estimated.

11.6.6  Cost Results

BPT applies to all direct discharging pulp and paper mills, a total of 325 mills. Mills whose
long-term average BOD5 and/or TSS effluent loads exceed the target loads for either BPT
Options 1  oil 2  required  costs for end-of-pipe treatment  (and possibly flow reduction)
upgrades.  However, for several mills that do not meet target loads for either option, no
treatment system upgrade costs were estimated because insufficient data for costing were
available.  Costs for these mills were transferred from a similar mill. Several mills share
wastewater treatment systems.  For these cases, the total costs for the  treatment system
upgrade were apportioned to each mill sharing treatment based on its contribution to the
                                       11-61

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                                               11.0 Costs of Technology Bases for Regulations
total wastewater flow to the treatment system. The total number of mills that required costs
and the types of costs they received for each option are summarized in Table 11-21.

The total number, capital cost, and O&M cost of each type of upgrade costed for mills to
achieve target loads is shown hi Table 11-22 for BPT Options 1  and 2.  The total cost to
industry, by subcategory, to achieve BPT Options 1 and 2 performance  levels are discussed
in Section 11.7; total industry costs include those shown in Table  11-22 for mills costed for
wastewater treatment upgrades and for mills whose costs were transferred from a similar
mill.

The  incremental amount of sludge generated by mills to achieve target loads was 59,700
metric tons per year for Option 1 and 63,100 metric tons per year for Option 2. The capital
and O&M costs associated with handling and disposing the additional sludge are shown in
Table  11-22 for Options 1 and 2.

11.6.7  Validation of End-of-Pipe Treatment System Cost Model

As described above, the major end-of-pipe treatment system upgrades  considered by EPA
for estimating industry-wide compliance costs  with proposed  BPT  and  BCT effluent
limitations guidelines include:

       •     Additional aeration in existing basins;

       •     Additional aeration in existing basins and new aerated facultative lagoon (in
             addition to existing basins);

       •     Single aerated facultative lagoon (in addition to existing basins);

       •     Two lagoons (in addition to existing basins): aerobic aerated lagoon followed
             by aerated facultative lagoon;
            i
       •     Polishing pond (hi addition to existing basins);

       •     Polishing pond (in addition to existing basins) and additional aeration in
             existing basins;

       •     Polymer addition in  existing basins; and

       •     Primary clarification (installed as part of a greenfield treatment system at
             mills that have no wastewater treatment in place).

EPA compared the capital costs estimated using its model for major end-of-pipe treatment
system upgrades with industry installed costs for similar treatment systems or treatment
system components.  The purpose of the comparison was to determine  if the end-of-pipe
                                        11-62

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                                              11.0 Costs of Technology Bases for Regulations
treatment upgrade costs estimated using the model were similar to industry costs on an
aggregate basis.  Based upon these comparisons, EPA found that the costs estimated using
the model were  higher than industry reported costs by about 11 percent on an aggregate
basis for more than 200 treatment system upgrades.  The costs estimated using the Agency's
model were consistently higher than industry-reported costs for aerated basin and polishing
pond upgrades,  and consistently lower than industry-reported costs for activated sludge
system clarifier upgrades.

EPA reviewed industry investment cost data supplied in response to the 1990 questionnaire
for a number of mills that reported investment costs for treatment system upgrades that
were similar to those listed above. Where industry costs could be reasonably broken out
for similar treatment systems or treatment system components, EPA converted those costs
to fourth quarter 1991 dollars using the Chemical  Engineering  composite cost index, and
prepared cost estimates for similarly sized treatment systems or treatment system upgrades
using its end-of-pipe treatment system cost  model.  The results of those comparisons are
presented in Tables 11-23 through 11-27.

Each table presents mill observation numbers (corresponding to data from a specific mill),
the flow, size, or  number associated with the treatment system upgrade, the investment cost
reported by the mill, and, the corresponding cost estimated using the Agency's model. For
each type of treatment system upgrade,  the Agency compared the sum of the industry
reported costs and the sum of the costs  estimated by its model.  Ratios of the sums of
industry-reported costs to the sums of the costs estimated using the Agency's model were
computed to illustrate the potential magnitude of the differences.  Following is a summary
of the model-derived costs and the industry-reported installed  costs by treatment system
upgrade:
5
,s Treatment , -
__U#g*atte,
Aerators
Aerated Basins
Polishing Ponds
Activated Sludge
Aeration Tanks
Clarifiers
•.*•*•_. *?", /
Isf amber
•Co&j&rM''
3
16
9
8
14
lad«sfetft;ttgfs*
<»aii*m$> s
1.87
34.6
8.37
14.5
12.7
» Motel
' " Cests(a)
., jisBIi0a$)
1.54
71.9
16.8
18.3
6.5
Ratio ,
,, Sto4»stty/®^4
•• , <
1.22
0.48
0.50
0.79
1.97
(a)Fourth quarter 1991 dollars.
                                       11-63

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                                              11.0 Costs of Technology Bases for Regulations
This summary shows that costs estimated using the Agency's model are likely to be higher
than industry-reported costs for aerated stabilization basins, polishing ponds and activated
sludge aeration basins; and, lower than industry-reported costs for the addition of aerators
to aeration basins and  installation of secondary clarifiers for  activated sludge systems.
Accordingly, the mill-by-mill costs for mills with aerated basin and polishing pond upgrades
may be overstated.   For those mills with activated  sludge system upgrades,  the costs
estimated using the Agency model may  be understated depending  upon the extent that
additional secondary clarification capacity was part of the upgrade.

EPA believes  its model-derived cost estimates are higher than reported industry installed
costs for aerated basins  and polishing ponds for the following reasons:  1) EPA developed
cost estimates for each basin or pond on the basis that complete  excavation of the basin or
pond would be required.  In actual practice, many lagoons and ponds are constructed to
take advantage of natural terrain, thus minimizing excavation costs; and, 2) EPA included
for each basin or pond a compacted clay liner two feet thick.  It  is not likely that all of the
basins and ponds used for these comparisons were so constructed. The costs for activated
sludge system secondary clarifiers estimated using the Agency's model included costs for the
clarifier tank,  sweep mechanism, grout, weirs, baffles,  and piping.

EPA verified  the accuracy of these  costing algorithms with two wastewater treatment
experts:   an  engineering  consultant and an equipment supplier.   Based upon these
verifications, EPA believe the model-based cost estimates to be accurate. EPA believes that
industry installed costs for activated sludge system secondary clarifiers may include costs for
other components such as waste sludge  pumps or other equipment not included in the
model-based cost estimate, although  these items were not specified  in the information
provided in the 1990 questionnaire response.  EPA plans additional investigation as to the
differences between its  model-based cost estimates for activated sludge system secondary
clarifiers and reported industry installed costs.  The differences ma'y also be attributable to
the time period over which costs were escalated. ,

As shown in Table 11-28, the Agency made an additional comparison in order to determine
whether costs  estimated using its cost model approximate reported industry installed costs
for the aggregate mix of treatment system upgrades necessary to comply with the proposed
BPT effluent limitations guidelines. This comparison  assessed whether the model-derived
costs were reasonable on an industry-wide  basis. For  this comparison, aggregate  costs
estimated using the Agency's model for  each of the major end-of-pipe  treatment system
upgrades were adjusted using the Industry Cost/EPA Model-Derived Cost ratios shown in
Tables 11-23 through 11-27 to approximate industry costs for the mix of treatment system
upgrades considered by EPA.

Table 11-28 shows that for over  200  treatment system upgrades, the  model-derived cost
estimates,  including costs for land, total nearly $231  million.  The adjusted industry
investment costs total nearly $205 million, or about 11  percent less. These results show the
costs estimated using the Agency's model  are reasonable on an aggregate basis for purposes
                                        11-64

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                                               11.0  Costs of Technology Bases for Regulations
of estimating economic  impacts for  the  proposed regulation.  EPA plans  to  conduct
additional cost validation studies for the final regulation and make adjustments as necessary
to refine the model-derived cost estimates.

11.7   Summary of Costs by Regulation

This section summarizes .the estimated costs by subcategory for BPT, BCT, BAT, PSES, and
BMP.  Costs are presented  for all options that were'considered as the technology bases for
the proposed effluent limitations guidelines and standards.  The options are described in
Section 9.0.  The costs presented were used to estimate the economic impact of each option
on the industry; however, installation of the specific technologies costed is not required for
compliance with the effluent limitations guidelines and standards.  Owners and operators
of the mills  subject to the regulation may select any process modifications,  wastewater
treatment technologies, or operating practices to comply with the effluent limitations
guidelines and standards  applicable to their facility.

In many cases, components of the technology basis for one effluent limitation guideline or
standard also form part of the technology basis for another effluent limitation guideline or
standard.  Costs were allocated to avoid double counting in such cases. For example, the
BAT end-of-pipe limits are based upon process changes and effective end-of-pipe biological
treatment. Only the process change costs were allocated to BAT.  Biological treatment costs
were accounted for under BPT.

The sections below briefly summarize capital and annual operating and maintenance (O&M)
costs for each proposed effluent limitation  guideline and standard and the technology basis
of the costs.

11.7.1 BPT

Table 11-29 presents the Agency's estimate of costs for end-of-pipe treatment and flow
reduction that would be incurred by direct discharging mills to comply with BPT Option 1
and 2.  The development of target BOD5  and TSS loadings based  upon the amount of a
mill's production in each  subcategory is described  in Section 10.2. The estimation of flow
reduction required for certain mills to meet these loadings is described in Section 11.5. The
end-of-pipe treatment system costing methodology, including BOD5 load reductions applied
due to BAT, NESHAP, and BMP is described in Section 11.6.

11.7.2 BCT

As discussed in Section 9.3,  the Agency developed four BCT options. Two of these options
(BCT Options B.I and B.2) were identical to  BPT Options  1 and 2, resulting in identical
pollutant reductions (that is, the pollutant reduction each mill is estimated to achieve after
compliance with BCT not already achieved by implementation of BAT, NESHAP or BMP)
and  identical costs.  The  Agency did  not  fully analyze the third BCT option  (BCT
                                       11-65

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                                             11.0  Costs of Technology Bases for Regulations
Option A.1, see Section 9.3.1.1) and no pollutant reductions or costs resulting from this
option were estimated.

The fourth BCT option (BCT Option A.2) was compared to a baseline equivalent to BPT
Option 2. BCT Option A.2 represents tertiary wastewater treatment in the form of multi-
media filtration applied in addition to other technologies costed to achieve BPT Option 2,
such  as  in-plant  flow reduction technologies  and end-of-pipe primary and secondary
wastewater treatment upgrades. Therefore, pollutant load reductions and costs associated
with BCT Option A.2 represent only the portion of load reductions and costs associated with
installation of multi-media filtration and not include load reductions or costs estimated for
BPT Option 2. Table 11-30 presents the costs for BCT Option A.2.  The methodology used
to estimate the costs is described below.

Costs for multimedia filters and associated pumps were estimated using database versions
of the CAPDET modules for filtration and intermediate pumping.  Pumps were included
because there is typically a minor head loss through the filter.  CAPDET is described in
Section 11.6.1.

Capital costs for filters and pumps included the same cost components, estimated for end-of-
pipe treatment described in Section 11.6.4, except land costs. The equipment costs for filters
and pumps were  estimated using the  base unit costs for standard sizes and the scaling
algorithm used in CAPDET.  Land costs were not included for filters and pumps because
they are relatively small items that can be accommodated by any available company-owned
land.  Operating and maintenance costs included costs for an additional operator, energy,
and maintenance. The unit costs for an operator and energy are given in Table 11-16.  The
major design and operating parameters, calculations, and assumptions used to design and
cost multi-media filters with pumps are further described in "Detailed Description of the
Flow Reduction and End-of-Pipe Treatment.  Design and  Cost  Models," found in  the
Record for the Rulemaking.

11.7.3 BAT

Table 11-31 presents BAT  costs, the Agency's  estimate of costs for process changes and
COD control that would be incurred by direct discharging mills in the industry to comply
with the various BAT options.  The development of process change costs is described in
Section 11.1, and the development of COD control costs is described in Section  11.2

11.7.4 PSES

Table 11-32 presents PSES  costs, the Agency's estimate of costs for process changes, COD
control, and end-of-pipe wastewater treatment that would be incurred by indirect discharging
mills  in the industry to comply with the two PSES options. Option 1 includes the process
change costs described in Section 11.1 and the COD control costs described in Section 11.2,
plus the estimated wastewater treatment costs for each mill to meet the BPT Option 2 target
                                       11-66

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                                              11.0 Costs of Technology Bases for Regulations
BOD5 and TSS values for the subcategory. The process, change costs shown are for the
proposed BAT option for each subcategory. The wastewater treatment costs include end-of-
pipe biological treatment and flow reduction  as  appropriate for each mill and  were
developed using the approaches described in Sections 11.5 and 11.6 for direct discharging
mills. Only one of these mills currently has any biological treatment on-site.

PSES Option 2 includes  the same process change and COD control costs as Option 1, plus
the estimated cost for the POTWs to which these mills discharge to upgrade their treatment
to be able to achieve the proposed BPT Option 2 limits for the mill's subcategory.  The
Agency did not have information on the  BOD5 and TSS loads  currently discharged by the
POTWs, and had limited information on the treatment used at each POTW. Therefore, the
following assumptions were made in order to cost POTW upgrades:

      •      Each POTW currently has  biological treatment in place.
                                                 i
      •      Each POTW is currently achieving discharge concentrations of 30 mg/1 BOD5
             and 30 mg/1 TSS, the minimum federal standards for secondary biological
             treatment.

The baseline BOD5 and TSS discharge loads for each POTW were calculated using the flow
and production values for the associated mill in  the equation:
                             PMBASE = k CONC?OTW Fm
                                                    (16)
where:
      PM,
         •BASE
      v_,(JJN(_,pOTW   —
Baseline mass of pollutant discharged, kg/year;

Conversion factor;

30 mg/L; and

Mill 1989 final effluent flow (discharged to the POTW), MOD.
The target BOD5 and TSS discharge loads for each POTW were calculated using the flow
and production values and the BPT Option 2 target BOD5 and TSS concentrations for the
associated mill in the equation:
                                       11-67

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                                              11.0 Costs of Technology Bases for Regulations
                                                                             (17)
where:
      PNL,
                         Mass of pollutant discharged after PSES, kg/yr;

                         BPT Option 2 performance level for subcategory i, kg/OMMT;
                         and

                         Production in subcategory i, OMMT/yr.
Pollutant reductions resulting from PSES are the difference between the baseline mass
discharge and the mass discharge at PSES:
                                    = PMBase - PMPS]
                                                   IBS
                                                                             (18)
where:
      PR
                   =     Mill pollutant reduction associated with PSES, kg/year;

                   =     Baseline mass of pollutant discharged, kg/yr; and

                   =     Mass of pollutants discharged after PSES, kg/yr.

The total pollutant reduction required for the POTW was calculated as the sum of the
BOD5 and TSS removals required.

The capital  and annual operating and maintenance costs for the POTW to upgrade its
treatment to  achieve  the  pollutant  removal required were estimated using average
conventional pollutant removal costs for direct discharging  mills.   Average  costs per
kilogram of  BOD5 and TSS removed were calculated for each subcategory using the BPT
Option 2 costs.  Average unit costs  were calculated separately for aerated stabilization
basins and activated sludge systems.

The appropriate unit costs were then applied to each POTW, depending on whether it had
an aerated stabilization basin treatment system or an activated sludge system. If the type
of treatment used at the POTW was unknown, the basin costs and activated sludge costs for
the appropriate subcategory were averaged. The unit costs for the Bleached Papergrade
Kraft and Soda Subcategory were used for POTWs receiving wastewater from mills with
                                       11-68

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                                              11.0 Costs of Technology Bases for Regulations
production in that subcategory. Unit costs applied to the other POTWs were the unit costs
for the subcategory representing the largest percentage of production from the mill
associated with each POTW.

Capital and O&M costs for each POTW were calculated using the equation:
                              CostpOTW = (UC)(TPR)
                                                    (19)
where:
      uq
      TPR
Capital or O&M cost for the POTW upgrade, $ or $/yr;

Average  unit cost of pollutant removal for the appropriate
subcategory and type of treatment system (basin or activated
sludge), $/kg; and

Total POTW pollutant reduction associated with PSES (BOD5
plus TSS), kg/yr.
These costs are an estimate of the costs that would be incurred by each POTW that receives
chemical pulp mill wastewater to comply with PSES, should the POTW accept conventional
pollutant limitations under the PSES Option 2 scenario.

11.7.5 BMP

Table 11-33 presents BMP costs, the Agency's  estimate  of  costs for pulping liquor
management, spill prevention, and control for mills that perform chemical pulping of wood
or non-wood fibers.  BMP applies to all mills, both direct and indirect dischargers.  The
development of BMP costs is described in Section 11.4.

11.8  References

1.     McCubbin, N., E. Barnes, E. Bergman, H. Edde, J.  Folke, and D. Owen.  Best
      Available Technology for the Ontario Pulp and Paper Industry. Ontario Ministry of
      the Environment, Toronto, Canada, 1991.

2.     Perry, R.H., D.W. Green and J.O. Maloney. Perry's Chemical Engineers' Handbook.
      McGraw Hill, Inc., New York, New York, 1984.

3.     Peters,  M.S., and K.D. Timmerhaus, Plant Design and  Economics for Chemical
      Engineers.  McGraw-Hill, Inc., New York, New York, 1980.
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                                             11.0 Costs of Technology Bases for Regulations
4.     Kocurek, MJ. "Alkaline Pulping." TAPPI press, Atlanta, Georgia, 1989.  (One of
      a series of textbooks on the pulp and paper industry published jointly by TAPPI and
      CPPA).

5.     McCubbin, N. Review of Technology for Overcoming Capacity Limitations in Kraft
      Pulp Industry Recovery Boilers. Industry, Science, and Technology Canada, Ottawa,
      Canada, July 1990.

6.     Simons, H.A. and AF-Industries Processkonsult AB.   Towards Kraft  Mill 2000.
      (Multi-client report published by Simons Eastern, Atlanta, Georgia), 1991.

7.     Worster, H.E. Pulp and Paper Manufacture,  Vol. 4, Chapter VI, Semichemical
      Pulping for Corrugating Grades,  The Joint Textbook Committee of the Paper
      Industry, 1985.

8.     U.S. EPA, Office of Water.  Technical  Support Document for  Proposed Best
      Management Practices Programs: Pulping Liquor Management, Spill Prevention, and
      Control.  U.S. Environmental Protection Agency, Washington, B.C., November 1993.

9.     Panchapakesan,  B.  Closure of  Mill  Whitewater Systems Reduces Water Use,
      Conserves Energy. Pulp and Paper.  March 1992.

10.   Krofta Engineering Corp.

11.   Nash-Clark & Vicario.

12.   Wyvill, C, J. Adams, and  G. Valentine.  Mills Often Overlook Significant Water
      Recycling Opportunities.  Pulp and Paper, April 1986.

13.   Blackwell, B.R., W.B. McKay, F.E. Murray, and W.K. Oldham. Review of Kraft Foul
      Condensates: Sources, Quantities, Chemical Composition, and Environmental Effects.
      Tappi Journal, Vol. 62, No. 10, October 1979.

14.   Springer, A.M. Industrial Environmental Control - Pulp and Paper Industry. John
      Wiley & Sons, Inc., 1986.

15.   Albany Engineering Systems.

16.   Celleco Hedemora, Inc.  .

17.   Harris, R.'W., MJ. Cullinane, and P.T. Sun, eds. Process Design and Cost Estimating
      Algorithms for the Computer Assisted Procedure for Design and Evaluation  of
      Wastewater  Treatment Systems  (CAPDET).   United States  Army Engineer
                                      11-70

-------
                                             11.0 Costs of Technology Bases for Regulations
      Waterways Experiment Station, Vicksburg, Mississippi, 1982. (Prepared for the U.S.
      Environmental Protection Agency).

18.    Aqua-Aerobic Systems, Inc., 1992.

19.    Personal communication, B. Elmore, SEC Donahue Consultants and S. Brezniak,
      Radian Corporation, Record for the Rulemaking, August 18, 1993.

20.    Personal  communication,  J.  Riddle,  Envirex,  Inc.  and  S.  Brezniak,  Radian
      Corporation, Record for the Rulemaking, May 17, 1993.

21.    Personal communication, N.  McCubbin, N.  McCubbin Consultants, Inc.  and S.
      Brezniak, Radian Corporation, Record for the Rulemaking, 1992.

22.    Amendola, G.  Possible BODS Load Reductions from Condensate  Stripping and
      Black Liquor Spill Prevention and Control.  Memorandum to R. Sieber, Radian
      Corporation, Record for the Rulemaking, September 19, 1992.
                                      11-71

-------
                   ES
                MILL HAVE
              WASTEWATER
               TREATMENT

DO NOT
COST
AERATION
UPGRADE



4 'N
^i

                KEY:

 BODLR    = BOD load after pro BPT load
             reductions (If applicable)
 BODTGT   » BOD target load
 TSS       « current TSS load
 TSSTGT   s TSS target load
 BODAER   = BOD Wad after application
             of aeration upgrade
 BODPOND  = BOD load after application of
             polishing pond upgrade
 BODPPAR  3 BOD load after polishing pond
             and aeration upgrade
                                                                         APPLY POLISHING POND
                                                                        AND AERATION UPGRADE
                                                                       YES
                                                                        DO NOT COST POLISHING
                                                                      POND AND AERATION UPGRADE
COST ALL APPLICABLE
    UPGRADES '
COMPARE TOTAL ANNUAL COSTS
  OF APPLICABLE UPGRADES.
      SELECT LEAST
    EXPENSIVE UPGRADE.
PLPPPRDRW-MOQJXJ-11£8/93
                                          Figure 11-1

                  Decision Tree for Basin Design  and Cost Model
                                              11-72

-------
   Table 11-1
Operating Costs
Parameter
Cost
Units
Chemicals
Molecular Chlorine
Chlorine Dioxide
NaOH (ECU)
NaOH (non-ECU)
Oxygen — by truck
Oxygen — on site
Hydrogen Peroxide
Hypochlorite
Sulfuric Acid
0.12
1.10
0.42
0.47
0.08
0.06
1.05
Calculated
individually for
each mill
0.07
$/kg
$/kg
$/kg ,
$/kg
$/kg
$/kg
$/kg

' $Ag
Energy and Wood
Electricity
Steam
Softwood Logs
Hardwood Logs
0.04
4.02
84.20
49.38
$/kWh
$/t steam
$/ODt wood
$/ODt wood
Labor
Operator
Supervisor
Technician
Process Engineer
Additional Supervision & Technical Support
24.66
68,784
22.44
80,000
0.5% of capital
cost
$/hr
$/yr
$/hr
$/yr

     11-73

-------
                                  Table 11-2
          Summary of Constants for Capital Cost Scaling Equation
Technology
Brown Stock Washing Upgrade
New Brown Stock Washing Line
Monitor Bleach Plant Filtrates
Split Addition of Chlorine
New D-stage Tower and Washer
Peroxide Unloading and Storage
Piping to Add Peroxide to Extraction Stage
Install Oxidativc Extraction (Eo)
Oxygen Delignification
Simple Retrofit Extended Cooking
Add Second Vessel to Digester for Extended
Cooking
New Continuous Extended Cooking Digester
Improved C102 Mixing and Control
Greenfield Chlorine Dioxide Plant
New Chlorine Dioxide Generator only
Conversion of R3/SVP C102 Generator to
mcthanol reduction process
Recovery Boiler Upgrade
Ozone Tower (medium consistency)
Base Cost
(C,)
$4,450,000
$14,300,000
$117,000
$4,000,000
$13,500,000
$100,000
$25,000
$900,000
. $16,000,000
$2,000,000
$20,300,000
$47,000,000
$1,000,000
$19,000,000
$15,000,000
$2,200,000
$4,800,000
$4,000,000
Base Capacity
(Cap0i)(a)
845
540
700
700
750
1
1
825
1050
1000
965
900
500
30 tpd C102
30 tpd C102
11 tpd C102
190 tpd black
Liquor organics
500
Cost Index
(n)
'0.6
'0.6
0.05
0.3
0.6
0
0
0.3
0.5
0.6
0.7
0.5
0.6
0.8
0.8
0.2
0.6
0.25
(a)Units are air dry unbleached metric tons of pulp per day, unless otherwise stated.
                                      11-74

-------
                               Table 11-3
              Summary of BAT/PSES Process Change Costs


"•
Subcategory
A. Dissolving Kraft

i
B. Bleached Papergrade Kraft and Soda




D. Dissolving Sulfite

E. Papergrade Sulfite




Option
1
2
3
1
2
3
4
'5
1
2
1
2

Capital
Cost
(million $)
61.3
130
135
710
1,150
1,930
2,070
4,680
106
83.1
252
88.3
Annual
O&M Cost
(million
$/K)
-8.78
-8.65
-4.86
47.7
-9.63
-58.9
23.3'
25.9
-12.6
56.0
13.4
17.8
All costs in fourth quarter 1991 dollars.
                                  11-75

-------
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                                         11-77

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                                                           11-81

-------
                               Table 11-9

         Costs for Upgrades to Implement BMP at Kraft, Sulfite,
                  Semi-Chemical, and Non-Wood Mills
Group
Capital Cost ($)
Annual 0&M Cost
($/year)
Kraft Mills (Dissolving, Unbleached, and Bleached Papergrade)
Mills that require no upgrades
Mills that require moderate upgrades
Mills that require major upgrades
0
750,000
1,500,000
0
(250,000)(a)
(500,000)(a)
Sulfite Mills (Dissolving and Papergrade)
Mills that require major upgrades
750,000
0
Semi-chemical Mills
Mills that require moderate upgrades
250,000
50,000
Non-wood Mills
Mills that require moderate upgrades
250,000
'0
(a) A savings in annual O&M costs for kraft mills is realized.
                                   11-82

-------
                                Table 11-10

                   Lowest TSS and BOD5 Concentrations
            Achievable by Secondary Treatment, By Subcategory
1
Subcategory
Dissolving Kraft
Bleached Papergrade
Kraft and Soda
Unbleached Kraft
Semi-chemical
Dissolving Sulfite
Papergrade Sulfite
Mechanical
Non-wood Chemical
Secondary Fiber Deink
Secondary Fiber Non-
deink
Fine and Lightweight
Papers from Purchased
Pulp
Tissue, Filter, Non-woven,
and Paperboard from
Purchased Pulp
t
-------
                                  Table 11-11

             Percentage of Final Effluent Flow Discharged From
                     Three Process Areas, By Subcaltegory
Subcategory
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Semi-chemical
Dissolving Sulfite
Papergrade Sulfite
Mechanical
Non-wood Chemical
Secondary Fiber Deink
Secondary Fiber Non-
deink
Fine and Lightweight Papers from
Purchased Pulp
Tissue, Filter, Non-woven, and
Paperboard from Purchased Pulp
Process £rea
Screen Room
21(a)
21(a)
21(a)
MR
18(a)
27(a)
21(a)
21(b)
NA
NA
NA
NA
Delinking
NA
NA
NA
1 NA
NA
NA
NA
NA
48(a)
NA
NA
NA
Stock
Preparation/
Papermaking
25(b)
25(b)
45(b) '
69(a)
25(b)
25(b)
71(a)
25(b)
53(a)
80(a)
91(a)
94(a)
NA - Not Applicable.
NR - Not Required.

Sources:      (a)1990 Questionnaire.
            (b)Reference (9).
                                      11-84

-------
                               Table 11-12

      Percentages iof Process Area Wastewater Discharge Reductions
            Achieved by Each Flow Reduction Technology and
                       Combination of Technologies
Flow Reduction Technology
Gravity Strainers with High Pressure Showers
(Strainers)
Disc Saveall (Saveall)
Strainers plus Saveall
Vacuum Pump Seal Water Cascade System
(Cascade System)
Vacuum Pump Seal Water Cooling Tower
System (Cooling Tower)
Strainers plus Saveall plus Cascade System
Strainers plus Saveall plus Cooling Tower
Strainers plus Cascade System
Strainers plus Cooling Tower
Screen Room Closure
Flotation Clarifier
Process Area
Papermaking
Papermaking
Papermaking
Papermaking
Papermaking
Papermaking
Papermaking
Papermaking
Papermaking
Pulping
Deinking
Percentage
46
45
68
15
27
83
95
61
73
95
95
Reference
BPJ
BPJ
BPJ
(12)
(11)
BPJ and (12)
BPJ and (12)
BPJ and (12)
BPJ and (12)
BPJ
(10)
BPJ - Best Professional Judgment.
                                  11-85

-------
 53   ~
                     a
   o
Gravity Strainers with High-Pr
Showers (Strainers)
a
                            co,
                             1
                            CO
                            •1
Saveall
plu
Str
                                     00
                                     s
Pump Seal Water Cascade
Cascade System)
Va
Syst
                                            a
                                            a

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                                           11-86

-------
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-------
                      Table 11-14
Summary of Flow Reduction Costs and Technologies Costed
Parameter
Number of Mills Requiring Flow Reduction
Total Flow Reduction Capital Costs (million $)
Total Flow Reduction Operating and Maintenance Costs
(million $/yr)
Number of Mills Costed for Each Flow Reduction Technology:
Gravity Strainers with High-Pressure Showers
Disc Saveall
Vacuum Pump Seal Water Cascade System
Vacuum Pump Seal Water Cooling Tower System
Screen Room Closure
Flotation Clarifier
Engineering and Minor Projects In-house
BPT Option 1
26
33.2
0

17
6
5
9
5
0
2
BPT Option 2
59
81.9
0

41
15
7
13
9
7
6
                         11-88

-------
                  Table 11-15
CAPDET Modules Used as Basis for Basin Upgrades
       in the Basin Design and Cost Model
---s B&g&k IJpgr&i&
s "•"• *" *• ^5, WA %
Additional Aeration
Additional Aeration + New Aerated
Facultative Lagoon
Single Aerated Facultative Lagoon
Two Lagoons
Polishing Pond
Polishing Pond + Additional Aeration
Primary Clarification
cfciwf maatewn ,
% SSS-. %
Aerated Facultative Lagoon
Aerated Facultative Lagoon (both)
Aerated Facultative Lagoon
Aerobic Aerated Lagoon + Aerated
Facultative Lagoon
Facultative Lagoon
Facultative Lagoon + Aerated
Facultative Lagoon
Secondary Clarification (cost model
only)
                     11-89

-------
                     Table 11-16
Unit O&M Costs for End-of-Pipe Treatment Technologies
'XssVVjf ^' •*--•
**&*& s ^r^^-1%.^^-. i
Ammonia
Phosphoric Acid
Electricity
Operator
Technician
,< Bait Cos*
" ,•«•>•>»' ,„, ; * 	
0.24 $/kg
0.29 $/kg
in Alaska 0.64 $/kg
0.04 $/kwhr
24.66 $/hr
22.44 $/hr
                          11-90

-------
                      Table 11-17
Unit Capital Costs for End-of-Pipe Treatment Technologies
Item
High-Speed,
Mechanical Surface
Aerators:
20 hp
40 hp
60 hp
75 hp
Polymer Feeder Box
Reinforced Concrete:
Wall
Slab
Excavation
Compacted Clay Liner
Handrail
Grout
Crane Rental
Unit Cost
$11,900
$17,400
$24,900
$26,000
$2,000
$707.53/m3
$155.74/m3
$6.21/m3
$2.43m2
$152.34/m
$261.58/m3
$127.12/hr
Basin Upgrades to Which item
Applies
• Additional aeration
• Additional aeration
and facultative lagoon
• Facultative lagoon
• Two lagoons
(75 hp only)
• Primary clarification
• Polymer addition
• Additional aeration
and facultative lagoon
• Facultative lagoon
• Two lagoons
• Polishing pond
• Polishing pond and
additional aeration
• Primary clarification
• Additional aeration
and facultative lagoon
• Facultative lagoon
• Two lagoons
• Polishing pond
• Polishing pond and
additional aeration
• Primary clarification
• Additional aeration
and facultative lagoon
• Facultative lagoon
• Two lagoons
• Polishing pond
• Polishing pond and
additional aeration
None
• Primary clarification
• Primary clarification
Activated Sludge Upgrades to
Whiefe ten Applies
• Additional aeration
• Additional aeration
tank volume
• Polymer addition
• Additional aeration
tank volume
• Additional
clarification
• Primary clarification
• Additional aeration
tank volume
• Additional
clarification
• Primary clarification
None
• Additional aeration
tank volume
• Primary clarification
• Additional
clarification
• Additional
clarification
• Primary clarification 	
                         11-91

-------
Table 11-17




(Continued)
Item
Maintenance
(Technician Labor
Rate)
Unit Cost
$22.44/hr
Basin Upgrades to Which Item
Applies
• Primary clarification
Activated Sludge Upgrades to
Which Item Applies
• Additional
clarification
• Primary clarification
    11-92

-------
                                  Table 11-18

                  Scenarios for the Application of Land Cost
                       Components to Individual Mills
Scenario
Mill has sufficient company-owned land
to meet land requirements.
Mill has insufficient company-owned land
to meet land requirements but the
nearest available land is contiguous.
Mill has insufficient company-owned land
to meet land requirements and the
nearest available land is not contiguous.
Land Cost Components Calculated
No costs
Purchase cost of land(a)
Purchase cost of land(b)
Purchase cost of right-of-way(b)
Cost of pipeline(c)
Cost of pump stations(c)
(a)This cost is only for the additional amount of land needed to meet the requirements.
(b)Purchase cost of land and right-of-way were based on mill-specific responses to the
1990 questionnaire.
(c)Costs of pipeline and pump stations were estimated from cost curves developed from
cost estimates for several wastewater flow rates over several distances.
                                     11-93

-------
                               Table 11-19

              BOD5 Load Reduction to Wastewater Treatment
          Due to Implementation of BAT at Bleached Papergrade
                          Kraft and Soda Mills (a)







BAT Group
Mills that do not have either extended cooking or
oxygen dclignification
Mills that have oxygen delignification
Milk that have extended delignification
Mills that have both oxygen and extended
delignification
Bt>05 Load
Reduction to
Wastewater
Treatment for Mill
Placed in Group
Based on 1989 or
Earlier Pats

(kg/QMMT)
5

10
10
13

(a)BOD5 load reductions for dissolving kraft are half of those shown in this table.
                                    11-94

-------
                 Table 11-20

BOD5 Load Reductions to Wastewater Treatment
    Due to Steam Stripping of Condensates
i
Steam Stripping Status Group
Mills with steam stripping in place.
Mills assumed to achieve no BOD5 load reduction
by adding a steam stripper. Condensates currently
are reused and not discharged to wastewater
treatment.
Mills assumed to achieve a moderate BOD5 load
reduction by adding a steam stripper. Condensates
currently are partially reused and partially
discharged to wastewater treatment.
Mills that can achieve the maximum BOD5 load
reduction by adding a steam stripper. Condensates
currently are discharged to wastewater treatment.
Number of Mills
in Status Group
16
14
46
26
BOD5 Load Reduction to
Wastewater Treatment
{kg/OMMT)
0
0
4
8
                    11-95

-------
                                    Table 11-21
                             Summary of BPT Costs
Type of Costs
Basin Only
Activated Sludge Only
Flow Reduction Only
Basin and Flow Reduction
Activated Sludge and Flow
Reduction
Transferred
Number of MHHs^a) ' ' '" f"
Option 1
111
55
4
12
11
3
Option 2
120
59
9
25
24
4
(a) Mills that share wastewater treatment systems are counted as one mill in this table.
                                        11-96

-------



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11-97

-------
                               Table 11-23

                                Aerators
      Comparison of Industry-Reported Costs and EPA Model Costs
Observation
Number
1
2
3
TOTAL
Flow
(mVday)
42,400
23,100 '
37,900

Number of
Aerators
(75 HP)
10
12
19

Ratio: Industry Cost/Model Cost
Industry-
Reported
Cost(a)
(million $)
0.711
0.556
0.598
1.87
EPA Mode!
Cost(a)
(million $)
0.412
0.525
0.598
1.53
1.22
(a)Fourth quarter 1991 dollars.
                                  11-98

-------
                               Table 11-24

                       Aerated Stabilization Basins
      Comparison of Industry-Reported Costs and  EPA Model Costs
Observation
Number
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
TOTAL
Flow
(nryaay)
3,440
1,320
4,540
18,900
32,900
29,900
73,400
23,100
36,700
42,400
29,900
184,000
104,000
120,000
138,000
73,100

Lagoon
Volume
(m3)
36,000
37,900
53,000
56,800
90,800
208,000
280,000
307,000
344,000
492,000
636,000
825,000
863,000
984,000
1,220,000
1,220,000

Ratio: Industry Cost/Model Cost
Industry-Reported
Gost(a) :
(million $)
1.68
2.10
1.39
0.940
5.40
0.980
0.183
1.05
3.27
1.59
3.01
2.52
2.41
1.00
5.33
1.75
34.6
EPA Model
Cest(a)
(million $)
2.76
0.236
0.598
0.940
0.972
1.42
3.50
1.18
1.73
1.78
3.32
16.4
8.99
8.17
9.47
10.4
71.9
0.48
(a)Fourth quarter 1991 dollars.
                                  11-99

-------
                              Table 11-25

                            Polishing Ponds
      Comparison of Industry-Reported Costs and EPA Model Costs
Observation
Number
1
2
3
4
5
6
7
8
9
TOTAL
Flow
(nrYday)
757
1,320
7,500
184,000
18,900
20,800
184,000
42,400
73,400

Pond
Volume
(m3)
2,270
3,790
18,200
92,000
189,000
621,000
1,010,000
1,840,000
2,290,000

Ratio: Industry Cost/Model Cost
Industry-
Reported
Cost(a)
(million $)
0.0140
0.579
0.282
0.137
0.970
1.10
0.813
0.206
4.27
8.37
EPA Model
Cost(a)
(million $)
0.0160
0.0280
0.133
0.816
0.644
0.887
3.69
2.54
8.06
16.8
0.50
(a)Fourth quarter 1991 dollars.
                                 11-100

-------
                               Table 11-26

                     Activated Sludge Aeration Basins
       Comparison of Industry-Reported Costs and EPA Model Costs
Observation
Number
1
2
3
4
5
6
7
8
TOTAL
flow
(m'/day)
2,270
5,680
35,600
22,000
15,100
15,500
65,500
61,300

Basin
Volume
«
2,650
3,030
7,950
8,330
15,100
53,000
72,300
215,000

Ratio: Industry Cost/Model Cost
Industry-
Reported
Cost(a)
(million $)
0.492
0.225
2.24
2.52
1.81
0.679
2.18
4.37
14.5
EPA Model
Cost(a)
(million $)
0.403
0.423
0.518
2.13
1.13
1.06
2.41
10.2
18.3
0.79
(a)Fourth quarter 1991 dollars.
                                 11-101

-------
                              Table 11-27

                  Activated Sludge Secondary Clarifiers
      Comparison of Industry-Reported Costs and EPA Model Costs
Observation
Number
1
2
3
4
5
6
7
8
9 :
10
11
12
13
14
TOTAL
Oarifier
Diameter
(m>
15.2
21.3
22.6
23.2
24.1
24.7
26.5
27.4
29.3
36.6
39.6
39.6
45.7
51.8

Industry-Reported
Cost(a)
(million $)
0.295
0.441
1.08
0.786
0.844
0.350
0.172
0.449
0.895
0.265
2.05 :
0.450
3.02
1.64
12.7
Ratio: Industry Cost/Model Cost
EPA Model
Cost(a)
(million $)
0.215
0.302
0.341
0.0285
0.330
0.368
0.374
0.388
0.432 ,
0.563
0.608
0.641
0.713
0.904
6.46
1.97
(a)Fourth quarter 1991 dollars.
                                 11-102

-------
                        O   ,
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                                                  o

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ed Ba
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Polishing Ponds
                                                           00
Activated Sludge
Aeration Tanks
Activated Sludge
Clarifiers
                                                                                  CM
                                     i
"3
                                                                                  SJ
Addition
Polyme
TOT
                                                                                        I
                                                    11-103

-------
                                    Table 11-29
               Best Practicable Control Technology (BPT) Costs
Subcategory(a)
Dissolving Kraft
Bleached Papergrade Kraft and
Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical Pulp
Nonwood Chemical Pulp
Secondary Fiber Non-deink
Secondary Fiber Deink
Fine and Lightweight Papers
from Purchased Pulp
Tissue, Filter, Non-woven, and
Paperboard from Purchased Pulp
Industry Total
Option 1
(Performance level representing
the average at the best $0
percent of mills in each
subcategory)
Capital Costs
(million $)
3.1
63
26
14
14
5.1
8.5
2.9
9.3
17
18
18
202
Annual O&M
(million $/yr)
0.08
7.4
4.2
0.6
0.6
0.5
1.0
0.04
0.9
2.1
2.0
2.0
23
Option 2
(Performance level representing
the average of the best 50
percent of mills in each
subcategory)
Capital Costs
(million $)
3.2
120
35
19
19
5.9
20
3.5
26
27
24
32
337
Annual O&M
(million $/yr)
0.08
10
3.7
0.7
0.7
0.6
1.8
0.04
1.4
2.5
2.1
2.8
29
(a) Costs for mills with operations in more than one subcategory have been apportioned based upon annual
  production.
                                       11-104

-------
                                   Table 11-30
        Best Conventional Pollutant Control Technology (BCT)  Costs
Sulbcategory(a)
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-chemical
Mechanical Pulp
Non-wood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-deink
Fine and Lightweight Papers from Purchased
Pulp
Tissue, Filter, Non-woven, and Paperboard
from Purchased Pulp
Industry Total
Multimedia Filtration With Pump
Capital
(million $)
22
271
117
33
21
14
45
1.9
22
57
54
44
703
Annual O&M
(million $/yr)
1.3
15
6.8
1.5
1.1
0.9
2.7
0.1
1.4
3.8
3.1
2.8
41
(a) Costs for mills with operations in more than one subcategory have been apportioned
  based upon annual production.
                                      11-105

-------
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                                            11-106

-------







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i-- -
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888
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8^8
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OD or Extended Cooking & 100% substitution
on-site wastewater treatment system for BOD5 i
OD or Extended Cooking & 100% substitution
POTW upgrade for BOD5 and TSS control.

CS V)

* £
COD control + on-site wastewater treatment sy
and TSS control.
COD control + POTW upgrade for BOD5 and
v> cs
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11-107

-------
                                       Table 11-33
                     Best Management Practices  (BMP)  Costs
Subcategory(a)
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Nonwood Chemical Pulp
Industry Total
1 jp Vs 1 f
Pulping Liquor Spill Prevention and Control
Capital
(million D,
4.5
37
2,7
3.8
6.3
4.8
3.0
86
Annual O&M
(million $/yr)
-1.5(b)
-10.0(b)
-9.0(b)
0
0
0.9
0
-22.0(b)
(a) Costs for mills with operations in more than one subcategory have been apportioned based upon annual
  production in each subcategory to which BMP apply.
(b) Negative operating costs represent net cost savings resulting from recovery of pulping liquor chemicals
  and energy.
                                           11-108

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                          12.0 Integrated Rulemaking and Non-Water Quality Environmental Impacts
 12.0   INTEGRATED RULEMAKING AND NON-WATER QUALITY ENVIRONMENTAL
       IMPACTS

 In 1990, EPA established the Pulp and Paper Regulatory Cluster comprising representatives
 from every EPA office. One role of the Pulp and Paper Regulatory Cluster is to identify
 optimal approaches to solving environmental problems associated with the pulp and paper
 industry through regulatory coordination.  As a result of the cluster's efforts, the effluent
 limitations guidelines are being jointly proposed with the NESHAP for the pulp and paper
 industry. Regulation of land application of pulp and paper mill sludge was also considered
 in the Agency's  coordinated regulatory strategy.

 Sections 304(b)  and 306  of the Clean Water Act require EPA to consider the non-water
 quality  environmental impacts (including air pollution, solid waste generation, and energy
 requirements) of effluent limitations guidelines.  The consideration of these impacts was
 integral to the coordinated regulatory strategy.  EPA conducted coordinated information
 collection,  performed analyses of multiple air and water  regulatory alternatives, and
 evaluated the impacts of  those  alternatives.   A summary of the development of the
 integrated  rulemaking and database, and the non-water quality  environmental impacts
 derived from integrated analyses,  is provided below.

 12.1  Integrated Rulemaking and Database

 The  first step  in  developing  the integrated  rulemaking was to collect  mill-specific
 information from all facilities subject to both the air and water standards. As described in
 Section 3.0, EPA used information from a number of sources, including its wastewater
 sampling program,  air emissions testing program,  1990 census questionnaire, and the
 voluntary API/NCASI 1992 questionnaire, to develop the integrated regulations.  The
 information collected includes the process and control technologies in use, current control
 levels, and pollutant release information. This information was compiled in a mill-specific
 database for use in developing both the air and water regulations.  Then estimated costs,
 pollutant reductions, and other environmental impacts for each air and water regulatory
 alternative were developed and various combinations of these alternatives were analyzed.
 The resultant database is known as the integrated database and the approach for developing
 and analyzing the results is known  as the integrated database system. This system calculates
 national baseline air emissions and wastewater discharges, national pollutant reductions and
 costs  of various  combinations of  effluent limitations guidelines and air emission control
 options, and other1 national environmental impacts.

The pollutants included in the final integrated database are listed in Table 12-1. This table
also identifies which pollutants were evaluated by the  Office of Water. Except for COD and
color, all pollutants for which effluent limitations  guidelines  are being proposed were
included in the  final integrated database.  Some additional pollutants which were not

                                       12-1

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                        12.0 Integrated Rulemaking and Non-Water Quality Environmental Impacts
regulated were also included.  COD and color were not included because data from which
baseline discharges could be • estimated were not available for all mills included in the
database.

The process changes that are part of the technology bases for the proposed air and water
regulations will reduce discharges of a large number of compounds, particularly chlorinated
compounds.  In preliminary analyses of the  integrated database, EPA included a larger
number of compounds but chose to limit the number of compounds included in the final
integrated  database for several reasons  including the  relatively small amounts of these
pollutants released by the industry and controlled by the options, and the tune involved in
processing and analyzing the additional data.

The control technologies considered as the bases for BAT, PSES, BPT, BCT, NSPS, and
PSNS are described in Section 9.0. The control technologies considered as the bases for
BMP and NESHAP are described in separate documents. The control options for BAT and
PSES involve pulping and bleaching process changes and secondary wastewater treatment.
The control options for BPT and BCT include improvements to water conservation practices
and secondary wastewater treatment systems. The proposed BMP require prevention and
control of pulping liquor spills. The three major air pollution controls that are the basis for
NESHAP are steam strippers, combustion, and wet scrubbing. Steam strippers are used to
remove HAPs from pulping area condensates. Combustion devices  are used to destroy the
HAPs removed by steam strippers. Combustion devices include stand-alone devices such
as thermal incinerators  or existing devices such as lime kilns, power boilers, and recovery
furnaces.  Wet scrubbers, and process changes, are used to reduce HAP emissions in the
bleaching area.

EPA developed regulatory alternatives based on pulping and bleaching process changes
alone, air  emission control options  alone, and combinations of process changes  and air
emission controls.  Each regulatory alternative also included secondary wastewater treatment
and spill prevention and control components. The alternatives were designed to evaluate
the most efficient  application of control technologies to minimize the cross-media transfer
of  pollutants between air and  water.  Table 12-2 summarizes 12 integrated regulatory
alternatives developed and evaluated by EPA. These integrated regulatory alternatives were
selected by EPA for its  final analysis  of the integrated rulernaking from integrated options
that had undergone preliminary analyses. As an example, in preliminary analyses integrated
options consisting of pulping and bleaching process change options  without air control
options were evaluated. However, as described below, process change options alone were
not sufficient to satisfy CAA requirements and for the final analysis these options were not
considered.

EPA evaluated whether the pulping and bleaching process changes that form the basis of
BAT and PSES reduce HAP emissions sufficiently to satisfy CAA requirements.  Based on

                                        12-2

-------
                         12.0 Integrated Rulemaking and Non-Water Quality Environmental Impacts
available data, the analyses showed that the use of these process technologies decrease
emissions of some HAPs, but increase others.  Specifically, process change technologies
decrease emissions of chlorinated HAPs, including chloroform, chlorine, and hydrochloric
acid.  This decrease in air emissions of chlorinated HAPs is believed to be attributable to
the elimination of hypochlorite as a bleaching agent and to increasing levels of chlorine
dioxide substitution in the process changes considered. However, air emissions of some non-
chlorinated HAPs, including methanol, methyl ethyl ketone, and formaldehyde, show modest
increases  as  a result of those process  changes.  These patterns in air  emissions were
observed for the range of process change control options evaluated as possible technology
bases for BAT and PSES.  EPA concluded that process technology changes alone do not
adequately control HAP emissions to the air, and that air control technologies in addition
to the process changes are needed to achieve HAP emission limitations required by the
CAA.

EPA also considered the effect of steam stripping certain pulping condensate wastewaters
on water and air pollutant releases, because steam stripping reduces both conventional
effluent pollutant  loadings and HAP  emissions.  As described in Section 10.2, a BOD5
pollutant load reduction was calculated for facilities that do not already steam strip pulping
condensates. This load reduction was applied prior to calculating other load reductions (for
flow reduction or wastewater treatment system improvements) for estimating compliance
costs and load reductions associated with BPT and BCT.

EPA also considered the effect of the air pollution controls on effluent loadings of priority
and nonconventional pollutants.  The analyses showed that the major air pollution controls
that form the basis for NESHAP (steam stripping, combustion, and wet scrubbing) did not
significantly affect effluent loadings of these pollutants.  Steam stripping systems remove
compounds from pulping area condensates, and the removed compounds are destroyed in
a combustion device.  Combustion also destroys  most compounds emitted from process
vents,  thus reducing the amount of pollutants that could enter surface waters due to
deposition.  Steam stripping also  reduces the volume of wastewater discharged to the
wastewater treatment system.  Chlorinated HAPs, that remain in bleaching area wastewaters
after process changes are implemented, react with caustic in the wet scrubber, neutralizing
the caustic effluent. Non-chlorinated HAPs that absorb into the caustic are bio-degradable,
and are  not estimated to significantly increase  the  pollutant load to the wastewater
treatment system.  Wet scrubbing operations are also not expected to significantly increase
the volume of wastewater discharges to the wastewater treatment system.

The analyses of multiple integrated regulatory alternatives showed that there is no single
control or process  change technology currently available that reduces pollutant discharges
to the air and water to levels required by the respective statutes. The demonstrated control
technologies that can serve as bases for BAT, PSES, NSPS, PSNS, BPT, and BCT, pose no
significant adverse impacts to and have some benefits for air quality.  Similarly, the air

                                        12-3

-------
                         12.0 Integrated Rulemaking and Non-Water Quality Environmental Impacts
control technologies that can serve as the basis for NESHAP pose no significant adverse
impacts on and have some benefits for water quality. Therefore, combining the best control
technology options for effluent limitations with the best control technology options for air
emission standards represents a reasonable method for constructing the integrated regulatory
alternative. EPA selected control options for the proposed integrated rulemaking based on
evaluation of pollutant reductions, costs, cost effectiveness, and economic, environmental,
and energy impacts.  The non-water quality environmental impacts associated with the
selected options are. summarized in the following sections.

12.2   Energy Impacts

According to the Department of Energy, the pulp and paper industry was the fourth largest
industrial user of energy in 1990,  accounting for 9.9 percent (2.4 quadrillion BTUs) of total
U.S. industrial energy consumption  (1).  Much of the energy used by the industry is
produced on site in power and recovery boilers. In 1990, the sources of energy used by the
industry included pulping liquor fuel (40.2 percent), fossil fuels  (37.1 percent), bark and
wood fuel (15.5 percent), and purchased electricity (7.2 percent).  The fossil fuels used
include natural gas, fuel oil,  and coal.

Compliance with the proposed regulations is anticipated to increase the industry's energy
usage by less than one percent (17.6 trillion BTUs/yr).  Among the reasons for this increase
are the  energy requirements  for process  equipment upgrades  for  compliance with
BAT/PSES, wastewater treatment system upgrades for compliance with BPT/BCT, and new
control devices or equipment upgrades for compliance with NESHAP. However, the energy
value  of  recovered cooking liquor  solids resulting from compliance  with BMP  and
BAT/PSES is anticipated to offset some of the increase in industry-wide energy usage.  The
following table summarizes the estimated change in the use of energy associated with the
proposed integrated rule.
Regulation
BAT/PSES
BPT/BCT
BMP
NESHAP
Source of Energy Use
Pulping and bleaching process
modification^.
Recovery of cooking liquor solids.
Wastewater treatment system upgrades.
Recovery of cooking liquor solids.
Equipment upgrades, increased steam
generation and auxiliary fuels.
Total
Energy Use Change '.
(TrilHoa BTUs/yr)
4.1
-7.8
1.0
-0.3
20.6
17.6
                                       12-4

-------
                         12.0 Integrated Rulemaking and Non-Water Quality Environmental Impacts
Additional energy requirements for process equipment upgrades for BAT/PSES result from
expansion of chlorine dioxide generator capacity and additional pumps for application of
oxygen,  ozone,  and/or  hydrogen peroxide in  the bleach plant.   Additional energy
requirements for process equipment for compliance with BPT/BCT result from increased
aeration in the treatment system.  Additional energy requirements for new control devices
or equipment upgrades for NESHAP result from: 1) the electricity needed to power fans
and blowers to transport vent streams, 2) natural gas needed to generate additional steam
for steam stripping of pulping area condensates, and 3) natural gas as an auxiliary fuel for
combustion devices.

BMP and BAT/PSES will result in increased recovery of cooking liquor solids which have
an energy value.  The Agency estimated the energy value of cooking liquor no longer spilled
and/or sewered  as a  result of BMP.  The  technology basis of the proposed BAT/PSES
includes the  addition of oxygen  delignification  and/or  extended cooking,  screen room
closure, and effective brown stock washing. The Agency also estimated the energy value of
this recovered cooking liquor.  As summarized above, the energy obtained from increased
recovery of cooking liquors offsets the increased energy demand of the additional process
equipment.

The Agency concludes that the effluent reduction benefits from the proposed regulation
exceed any potential adverse impacts from the minor increase in energy consumption that
is projected.

12.3   Air Pollution

As described in Section 12.1, the development of the integrated rulemaking analyzed air and
water regulatory alternatives simultaneously. Some air pollution benefits are summarized
below for the proposed integrated alternative.

Compliance with the  proposed integrated  rule will reduce hazardous air pollutants by
120,000 kkg/yr, volatile organic compounds by 715,000 kkg/yr,  and  total reduced sulfur
compounds by 295,000 kkg/yr.  These  reductions result from steam stripping of pulping
condensates, combustion of pulping vent streams (except deckers and screens), scrubbing
of all bleaching vent streams, and implementation of the BAT/PSES process changes.

Compliance with the proposed integrated rule is anticipated to increase the quantity of
criteria pollutants (CO, NOxj SO2, and particulate matter) emitted.  Carbon monoxide
emissions are expected to increase by 300 kkg/yr, nitrogen oxide emissions by 1,300 kkg/yr,
sulfur dioxide emissions by 168,000 kkg/yr, and particulate matter emissions by 100 kkg/yr.
These increases   are due to combustion of emissions from controlled  vents  and  the
combustion of fuels used to generate steam for stripping pulping wastewaters.  The increase

                                       12-5

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                         12.0 Integrated Rulemaking and Non-Water Quality Environmental Impacts
in sulfur dioxide emissions is higher than the other  criteria pollutants because of the
formation of sulfur dioxide from combustion of TRS in pulping vent streams.

The air impacts from improved end-of-pipe biological treatment under BPT are considered
negligible in view of the significant reduction in HAPs and VOCs in pulping and bleaching
wastewater that result from steam stripping of pulping condensates and implementation of
the BAT/PSES process changes.

The Agency concludes that the air emission and effluent reduction benefits of hazardous air
pollutants and priority, nonconventional,  and  conventional pollutants  far outweigh the
potential negative impacts of increased emissions of criteria air pollutants.

12.4   Solid Waste Generation and Management

Compliance with BPT/BCT is anticipated to increase the mass of wastewater treatment
sludge generated by 52 million kg/yr, mostly because of increased solids removal at facilities
with activated sludge wastewater treatment systems.  This represents less than a 1 percent
increase over current sludge generation rates.

Compliance with BAT/PSES is anticipated to improve the quality of wastewater treatment
sludge by reducing mass loadings of pollutants exported in sludge. Although mass loadings
of all chlorinated pollutants are anticipated to  decrease, the Agency specifically estimated
reductions for 2,3,7,8-TCDD  and  2,3,7,8-TCDF.

To estimate the effect of the integrated regulatory alternative on sludge quality in terms of
2,3,7,8-TCDD  and  2,3,7,8-TCDF concentrations and mass  loadings,  the Agency first
estimated baseline concentrations and loadings for all mills in the Bleached Papergrade
Kraft and Soda, Dissolving Kraft,  Papergrade Sulfite, and Dissolving Sulfite Subcategories.
Baseline concentrations and mass loadings were compared to estimates of concentrations
and mass loadings of 2,3,7,8-TCDD and 2,3,7,8-TCDF in sludge following implementation
of BAT/PSES, with the difference representing the pollution reduction.  The methodology
used was similar to that described in Section 10.3 for estimation of pollutant reductions in
effluent and is described further elsewhere (2).

The proposed regulatory alternative is estimated to reduce the overall mass loading of
2,3,7,8-TCDD and 2,3,7,8-TCDF  in sludge by  115 grams per year (98.9 percent) and 626
grams per year (98.8  percent), respectively.  For comparison, the proposed regulatory
alternative is  estimated to reduce the overall  mass loading of 2,3,7,8-TCDD and 2,3,7,8-
TCDF in treated effluents by 65 grams per year (92.9 percent) and 337 grams per year (98.9
percent), respectively.  These reductions of 2,3,7,8-TCDD and 2,3,7,8-TCDF mass loadings
in sludge should allow greater use of land application of sludge and will enable mills to
achieve cost savings  in sludge management.

                                        12-6

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                         12.0 Integrated Rulemaking and Non-Water Quality Environmental Impacts
Because the proposed regulation is based upon process changes that reduce formation of
2,3,7,8-TCDD, 2,3,7,8-TCDF, and other chlorinated phenolics (including AOX), there will
be less transfer of these compounds to sludge during wastewater treatment. Accordingly,
the Agency concludes that there will be no adverse non-water quality environmental impacts
regarding sludge management.

12.5  Odor Control

Noxious odors can be emitted from pulp and paper mills. At kraft mills, odors are primarily
caused by four reduced-sulfur compounds: hydrogen sulfide, methyl mercaptan, dimethyl
sulfide, and dimethyl disulfide.  These compounds are referred to collectively as total
reduced sulfur or TRS. TRS gases are mainly emitted from digester blow and relief gases,
evaporator vents, and recovery furnace flue gases (3).  These compounds have low odor
thresholds, meaning their odor can be detected at low concentrations. Sulfur oxides emitted
from recovery and power boilers can also contribute to odors from both  kraft  and sulfite
mills but are much less noticeable than TRS emissions, because the odor threshold for sulfur
dioxide is  about 1,000 times higher than for the TRS gases.

Odors will be reduced by various technologies that will be applied at mills for compliance
with the integrated rule.  For example, steam stripping of pulping  condensates to control
emissions of hazardous air pollutants will also reduce odors. Collecting and redirecting vent
gases from various areas of the mill to combustion devices will reduce odors. In addition,
implementation of the BMP regulation will result in less exposure of pulping liquors to the
atmosphere, which in turn will  result in incidental  reductions in odors. The Agency
estimates that TRS emissions will decrease by 295,000 kkg/yr, as a result of the integrated
rulemaking (4).

Because the integrated rule will result in capture of TRS and other compounds contributing
to odors, the Agency concludes there will be no adverse non-water quality environmental
impacts associated with odors.

12.6   Other Impacts

Other non-water quality environmental impacts include a  reduction in the volumes of
process water used and wastewater discharged, a reduction of pollutants found in bleached
pulps, and changes in quantities of chemicals used at bleaching mills.

Compliance with the proposed rulemaking is expected to result in an industry-wide reduction
in the volumes of process water  used and  wastewater discharged.  Compliance with
BAT/PSES is expected  to result in the closure  of screen rooms and installation or
modification of pulping and bleaching processes that use less water.  Compliance with BPT,
BCT, BMP, and NESHAP is also expected to reduce the volume  of water used as mills

                                        12-7

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                         12.0 Integrated Rulemaking and Non-Water Quality Environmental Impacts
implement additional water conservation practices. In this discussion, changes in the volume
of process water used are assumed to similarly affect the volume of wastewater discharged
although at many mills  these volumes may not be the same due to factors  such as
evaporation.

The industry-wide reduction in water use as a result of process changes that are part of the
technology bases of BAT and  PSES  is estimated to be  1.2 million  m3/yr.  This was
determined by estimating the reduction of water use as a result of process changes at a
model mill and multiplying this by the total number of mills.  A mill-by-mill estimate was
not developed because water conservation practices vary from mill-to-mill and such mill-
specific information is not available. To date, the industry has already made a significant
effort to reduce consumption and increase water reuse and recycle. Since 1975, water use
by the industry has decreased approximately 30 percent (5).

Some treatment and control technologies consume water (consumptive water loss) which
contributes to water scarcity in arid and semi-arid regions.  The technology bases of  this
rulemaking may lead to increased  loss of water to  evaporation  as a result of routing
additional wastewater streams to the recovery system. The Agency has not quantified the
consumptive water loss associated with this rulemaking  but does not believe that it is of
concern because, as discussed above, most mills are reducing water use and because most
mills are located in the pacific northwest or east of the Mississippi River where water
scarcity is generally not a problem.

Compliance with BAT/PSES is anticipated to improve the quality of bleached pulp by
reducing mass loadings of all chlorinated pollutants exported in this medium.

Compliance with BAT/PSES will also affect the quantity of bleaching chemicals used in the
industry.   Quantities of  hypochlorite, chlorine, and  sodium hydroxide (ECU, which is
purchased with chlorine) are expected to decrease while quantities of chlorine  dioxide,
oxygen, hydrogen peroxide,  sodium hydroxide (non-ECU), and ozone are expected to
increase.  Estimated industry-wide changes in the use of these chemicals are summarized
below. The estimates were prepared from individual cost model data for each bleach line
at each mill (see Section 11.1).
                                       12-8

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                         12.0 Integrated Rulemaking and Non-Water Quality Environmental Impacts
Chemical
Chlorine
Chlorine Dioxide
Hydrogen Peroxide
Hypochlorite
Oxygen
Ozone
Sodium Hydroxide (ECU)
Sodium Hydroxide (non-ECU)
Increase or
Decrease
Decrease
Increase
Increase
Decrease
Increase
Increase
Decrease
Increase
Estimated Change
in Use
(Wsg/yr)
1,990,000
497,000
219,000
420,000
320,000
4,200
2,390,000
573,000
The Agency  concludes that the air  emission and effluent reduction benefits from the
proposed regulations outweigh any negative impacts associated with changes hi production
and usage of pulping and bleaching chemicals.

12.7  References
1.
2.
3.
Swink, D. U.S. Department of Energy. Overview of DOE's Pulp and Paper Industry
Program.  Presentation to the American Paper Institute, August 14, 1992.

Eastern Research Group,  Inc.   Economic  Analysis of  Impacts of Integrated
Air/Water Regulations for the Pulp and Paper Industry on Disposal of Wastewater
Sludge, Draft Final Report, August 17,  1993.

Smook,  G.A.   Handbook  for Pulp  and Paper  Technologists.  Joint Textbook
Committee of the Paper Industry, TAPPI, Technology Park, Atlanta, Georgia and
CPPA, Montreal, Quebec, Canada, 1982. pg. 366.
                                       12-9

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                  12.0 Integrated Rulemaking and Non-Water Quality Environmental Impacts
U.S. EPA, Office of .Air  Quality Planning  and Standards.   Pulp,  Paper,  and
Paperboard Industry - Background Information for Proposed Air Emission Standards
(Manufacturing Processes at Kraft, Sulfite, Soda, and Semi-Chemical Mills), EPA
453/R93-050a, U.S. Environmental Protection Agency, Research Triangle Park,
North Carolina, October 1993.

Miner, R. and J. Unwin. Progress in Reducing Water Use and Wastewater Loads
in the U.S. Paper Industry.  TAPPI Journal, 74(8): 127-131, August 1991.
                                 12-10

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                                 Table 12-1
           Pollutants Included in the Final Integrated Database
               Pollutant
Pollutant Data Contributed by Office of
               Water
Acetaldehyde
Acetophenone
Acrolein
Adsorbable organic halides (AOX)
BOD5
2-Butanone (MEK)
Carbon disuMde
Carbon tetrachloride
Chlorine
4-Chlorocatechol
Chloroform
4-Chlorophenol
6-ChlorovanilMn
1,4-Dichlorobenzene
4,5-Dichlorocatechol
2,4-Dichlorophenol
2,6-Dichlorophenol
2,6-Dichlorosyringaldehyde
5,6-Dichlorovanillin
Formaldehyde
HAP
Hexane
Hydrochloric acid
Methanol
Methyl chloroform (1,1,1-trichloroethane)
Methylene chloride
Pentachlorophenol
Propionaldehyde
2-Propanone (acetone)
2,3,7,8-Tetrachlorodibenzo-p-dioxin
2,3,7,8-Tetrachlorodibenzofuran
Tetrachlorocatechol
Tetrachloroguaiacol
                 X
                 X
                 X
                 X
                 X
                 X
                 X

                 X
                 X
                 X
                 X
                 X
                 X
                 X

                 X
                 X
                 X
                 X
                 X
                                     12-11

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                                  Table 12-1

                                 (Continued)
               Pollutant
                                          Pollutant l>a*a Cartb^tejTfey Ace of
Toluene
Total reduced sulfur
2,3,4,6-Tetrachlorophenol
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
Trichlorosyringol
TSS
VOC
X
X
X
X
X
X
X
X
X
X
                                      12-12

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                                                                13.0 Analytical Methods
 13.0   ANALYTICAL METHODS

 Section 304(h) of the Clean Water Act directs EPA to promulgate guidelines establishing
 test procedures (analytical methods) for the analysis of pollutants. These methods are used j
 to determine the presence and concentrations of pollutants in wastewater, and are used for
 filing applications 'and for compliance monitoring under the National Pollutant Discharge
 Elimination System (NPDES) at 40 CFR Parts 122.41(j)(4) and 122.21(g)(7), and for the
 pretreatment program at 40 CFR Part 403.7(d).

 EPA has promulgated analytical methods for monitoring discharges to surface waters at 40
 CFR Part 136, and has promulgated methods for analytes specific to a given industrial
 category and for other purposes at Parts 400 - 480 of the CFR.  In  this proposed rule,
 methods not promulgated at  40  CFR Part  136 will be proposed at 40 CFR'Part 430 to
 support regulation of discharges from the Pulp,  Paper,  and Paperboard  Point Source
 Category.  The list of regulated analytes in Table 13-1 includes  the methods  that pulp,
 paper, and paperboard manufacturers will be allowed to use for compliance monitoring.
 Table  13-1 lists methods  already promulgated by EPA at 40 CFR Part 136  as well as
 analytical methods not contained in 40 CFR Part 136.  At a later date, EPA may choose to
 promulgate all of the methods contained in Table 13-1 as allowable methods under 40 CFR
 Part 136.  The methods are summarized in this section and are included in the  record for
 the rule. Also included in the record are modifications resulting from testing of the methods
 on  pulp and  paper  industry wastewaters and summaries  of comments received from
 interested parties concerning the methods, and responses to those comments.

 13.1   Chlorinated Dioxins and Furans

 EPA Method 1613,  Revision A (1613A), is  to  be used  to  analyze pulp and paper
 wastewaters for the 17 tetra- through  octa- substituted dibenzo-p-dioxin and dibenzofuran
 isomers and congeners that are chlorinated at the 2, 3, 7, and 8 positions.  Included in this
 list of 17 are the  2,3,7,8-TCDD and 2,3,7,8-TCDF isomers to be regulated under the
 proposed rule. Prior to.  1989, EPA SW-846 Method 8290 (40  CFR Parts 260 - 270, by
 reference) was used  in several studies and NCASI Technical Bulletin 551  was used for
 analysis of 2,3,7,8-TCDD  and  2,3,7,8-TCDF.

 Method 1613A uses isotope dilution and high resolution gas chromatography combined with
 high resolution mass spectrometry  (HRGC/HRMS) for separation and detection of the
 individual 2,3,7,8-substituted  tetra- through octa- isomers  and congeners.  Separate
procedures are available for measurement of these analytes in water and solid matrices;
however, the method is being proposed in this rule for  use in treated and  untreated
wastewater samples only.
                                       13-1

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                                                              13.0 Analytical Methods
In the procedure for water, a one-liter sample is passed through a 0.45 micron glass fiber
filter. The filter is extracted with toluene in a Soxhlet/Dean-Stark (SDS) apparatus.  The
aqueous filtrate is extracted with methylene chloride in a separatory funnel. Extracts from
the SDS  and separatory funnel extractions are combined and concentrated.  To remove
interferences, the combined, concentrated extract is  subjected to  cleanup using various
combinations of  acid and  base washes,  acidic  and basic silica  gel, gel permeation
chromatography (GPC),  high performance liquid chromatography (HPLC), and  activated
carbon. The extract is then concentrated to 20 /xL and a 1 - 2 /xL aliquot is injected into the
HRGC/HRMS.  Labeled compounds  serve to correct the variability of the analytical
technique.

For each method and analyte, EPA determines a method detection limit (MDL) which is
the minimum concentration of a substance that  can  be measured and reported with 99
percent confidence that the  analyte concentration is greater than zero and is determined
from analysis of a sample in a given matrix containing the analyte (see 40 CFR  Part 163,
Appendix B). From an MDL, EPA determines a minimum level (ML) which is the level
at which the analytical system gives recognizable signals and an acceptable calibration point.
For Method 1613, these limits usually depend upon sample matrix interferences rather than
instrument limitations.  With no interferences present, method detection limits (MDL) of
4.4 and  3.6  ppq can be achieved for 2,3,7,8-TCDD  and 2,3,7,8-TCDF, respectively.
Minimum levels determined for Method 1613 are 10 ppq for 2,3,7,8-TCDD and 2,3,7,8-
TCDF, 50 ppq for the penta-through hepta-substituted CDD and CDF congeners, and 100
ppq for the oeta-substituted congeners.

Method 1613A is based on the method that was used in EPA's  National Dioxin  Study, on
EPA SW-846 Method 8290, and on methods from industry, academia, and commercial
analytical laboratories.  Some effluent limitations guidelines contained  in this rule for
2,3,7,8-TCDD and 2,3,7,8-TCDF were developed using Methods 1613A and 8290.   For
2,3,7,8-TCDD and 2,3,7,8-TCDF, the results obtained using both methods are equivalent.

Method 1613A was proposed at 40 CFR Part 136 (56 FR 5090, February 7, 1991) but has
not been promulgated for use in wastewater programs as of this date.  Method 1613A is
currently required for use in  drinking  water programs  (40 CFR Parts 141 - 142; 57 FR
31776, July 17,  1992). The only CDD/CDF method that has been promulgated for use in
wastewater programs is Method 613, promulgated at 40  CFR Part 136 (49 FR 43234,
October 26,1984). This method is specific for 2,3,7,8-TCDD only and has an MDL of 2,000
ppq, which  is more  than 400 times larger than the MDL of  4.4 ppq in Method 1613.
Therefore, Method 613 is  incapable  of detecting any of the CDDs or  CDFs at the
concentrations present in pulp and paper wastewaters and is not allowed for monitoring
under  the proposed rule.
                                       13-2

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                                                                 13.0 Analytical Methods
  13.2   Chlorinated Phenolic Compounds

  Chlorinated phenolic  compounds (chlorophenolics) are  a group  of toxic  pollutants
  characterized by a benzene ring with one hydroxyl group (phenols) and at least one chlorine
  atom (chloropheriols).  Ring substituents may be a second hydroxyl group at the ortho
  position (catechols), a methoxy group at the ortho position (guaiacols), a methoxy group at
  the ortho position and an aldehyde group at the para position (vanillins), and methoxy
  groups  at both ortho positions and a hydroxyl or aldehyde group at the para position
  (syrmgols and syringaldehydes).  Each of these compound classes are identified in the
 proposed rule as part of the general class  known as chlorinated phenolic compounds.

 The chlorophenolics to be regulated under  the proposed rule are to be measured using EPA
 Method 1653. Method 1653 measures compounds in water and wastewater amenable to in-
 smi acetylation,  extraction, and determination by high  resolution gas  chromatography
 (HRGC) combined with low resolution  mass spectrometry (LRMS).   In this method
 chlorophenolics are derivatized in situ to form acetic acid phenolates that are extracted with
 hexane, concentrated, and injected into the HRGC/LRMS where separation and detection
 occur.  Detected chlorophenolics are quantified by isotope dilution if a labeled analog is
 available.  Where labeled analogs are not available, detected compounds are quantified by
 an internal standard technique.

 The detection limit of the method is usually  dependent  upon interferences rather than
 instrument limitations, With no interferences present, MDLs of 0.09 -1.39 /tg/L (ppb) have
 been determined for chlorophenolics in water.  Based on  these MDLs and on calibration
 of the GC/MS instrument, minimum levels have been determined to be 1.25, 2.50 or 5 00
 jwg/L, depending upon the specific compound.                                 '

 Method 1653 is based on NCASI Method CP-86.01 and draft APHA Method 6240  In early
 data-gathering studies for the proposed rule, NCASI Methods CP-85.01 and CP-86 01 were
 used. Some effluent limitations guidelines  contained in this rule were developed using the
 NCASI methods.  The extensive quality assurance and quality control program that these
 data were subjected to ensured that an equivalent degree  of confidence was obtained for
 analytical results from each method.

 *3.3  Volatile Organic Compounds (VOCs)

 VOCs are to be determined in wastewater  using EPA Method 1624.  Method 1624 is the
 only method promulgated at 40 CFR Part 136 that can determine all four of the pollutants
 to be regulated under the proposed pulp and paper rule. The method uses isotope dilution
 and  gas chromatography/mass spectrometry (GC/MS)  to  separate and  quantify the
regulated analytes. VOCs are purged from  a water sample onto a trap by a stream of inert
gas.  Subsequent heating of the trap introduces the concentrated VOCs into  the GC/MS.

                                      13-3

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                                                              13.0 Analytical Methods
The detection limit of the method is usually dependent upon interferences rather than
instrumental limitations. With no interferences present, minimum levels of 10 or 50 j*g/L
can be achieved, depending upon the specific compound.

13.4  Adsorbable Organic Halides TAOX)

AOX is a measure of halogenated organic compounds that adsorb onto granular activated
carbon  AOX in water and wastewater is to be measured by EPA Method 1650, Revision
A  This method is a microcoulometric technique that determines organically bound halides
(chlorine, bromine, and iodine) dissolved or suspended in a water sample. The results are
reported as organic chlorine even though other halides may be present.

The concentration of organic halides is determined by adsorption onto granular activated
carbon removal of inorganic halides by washing, and combustion of the organic halides
(along with the carbon) to form hydrogen halides.  The amount of hydrogen halides
produced is determined by titration with silver ions in the  microcoulometer.

The detection limit of Method 1650 is usually dependent  upon interferences rather than
instrumental limitations. With no interferences present,  an MDL of 6.6 pg/L (ppb) can be
achieved.  Based on this MDL and  on calibration of the microcoulometer, the minimum
level in Method 1650 has been determined to be 20 /*g/L.

Method 1650 is based on the following methods for determination of organic halides in
water-  EPA SW-846 Method 9020; Deutsche Industrie  Norm (DIN) Method 38409, Part
 14- International Organization for Standardization (ISO/DIS) Method 9562; Scandinavian
 Pulp Paper, and Board Testing Committee Method SCAN-W 9:89; APHA Method 5520;
 and the Canadian Standard Method for the Determination of Adsorbable Organic Halides
 (AOX) in Waters and  Wastewaters. In early data gathering studies,  the ISO 9562  and
 SCAN-W 9:89 methods were used.

 For solid  samples (soils, sludges, and pulps), organic  halides (OX) were measured by
 neutron activation analysis using draft EPA Method 1648. In this method, samples are
 sonicated  in acid to solubilize organic  halides which are then adsorbed  onto activated
 carbon. The adsorbed sample is sealed and exposed to  neutrons to produce radioisotppes
 of chlorine that are measured with  a gamma-ray detector. Because this method is still in
 draft form, MDL and ML information is not yet available.

 In addition to Method  1650 for AOX and Method 1648 for OX, other analytical methods
 (and terms) have been used to quantify halogenated organic matter. For example EPA
 SW-846 Methods 9020 and 9022 quantify total organic halides (TOX) and Method 9021
 quantifies purgeable organic halides (POX) in water and wastewater.  TOX is a measure
 of the dissolved or suspended  halogenated organic matter that adsorbs  onto  granular

                                         13-4

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                                                                13.0 Analytical Methods
activated carbon. Therefore, AOX results should be equal to or greater than TOX results.
Because of this distinction, dissolved organic halides (DOX) is now the preferred term for
the original TOX procedure. The difference between Methods 9020 and 9022 is that 9022,
which  utilizes neutron activation techniques,  can be used to determine  each halogen
separately.  POX is a measure of the volatile fraction of organic halogens.  Extractable
organic halides (BOX) is another measure of organic halogen concentrations.  BOX is
measured by extraction of the hydrophobic fraction of chlorinated organic matter using an
organic, lipophilic solvent.  Methods for measuring  BOX have been reported in the
literature  but have not been standardized.  The Agency has not developed a method for
BOX.

13.5   Chemical Oxygen Demand (COD)

COD is a measure of the oxygen equivalent of the  organic matter in a sample that is
susceptible to oxidation by a strong chemical oxidant.  For samples from a specific source,
COD can  be related empirically to biochemical oxygen demand (BOD5). Several methods
for COD are incorporated by reference into 40 CFR Part 136, notably EPA Methods 410.1
through 410.4.  Methods 410.1 and 410.2  are the only EPA COD  methods that will be
allowed for monitoring under the pulp and paper rule.  In these methods, the organic and
oxidizable inorganic substances in an aqueous  sample are  oxidized by  a  solution of
potassium dichromate in sulfuric  acid.   The excess dichromate is titrated  with standard
ferrous ammonium sulfate using orthophenanthroline ferrous complex (ferroin) as an
indicator.  Method 410.2 covers COD concentrations in the range  of 5 - 50 mg/L whereas
Method 410.1  covers  COD concentrations from 50 -  2,000 mg/L.   Other methods
incorporated by reference into 40 CFR  Part 136 that  use oxidation with  potassium
dichromate in sulfuric acid and subsequent titration of the excess dichromate (e.g., APHA ,
Method 5520B) are also allowed.  At this time, EPA has not developed a minimum level'
for the COD methods.

A few studies of wastewaters in the pulp and paper industry where COD was analyzed were
conducted with Method 410.4.  In this method, COD is determined colorimetrically after
digestion of the organic matter in a sample using hot chromic acid solution.  However, the
highly  colored nature of some pulp and paper samples interferes  with the colorimetric
determination of COD.   Therefore, Method 410.4  and  other colorimetric methods
incorporated by reference  into  40 CFR Part 136 will not be allowed for monitoring under
the proposed pulp and paper rule.  Similarly, Method 410.3 is  intended for high levels of
COD in saline waters and will  not be allowed.

13.6   Color

Color in water and wastewater may result from the presence of metallic ions (e.g., iron  and
manganese)  and humic matter. Color in pulp and paper mill effluents is attributable to

                                       13-5

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                                                               13.0 Analytical Methods
losses of pulping liquor (black liquor) and bleach plant extraction stage filtrates. Color is
measured by the procedure described in NCASI Technical Bulletin No. 253 that was
specifically designed to measure color in pulping  and bleaching effluents.  Samples are
adjusted to pH 7.6, and the turbidity of the solution is reduced by filtration.  Color is then
determined at 465 nm by spectrophotometric comparison of a wastewater sample with  a
standard solution of chloroplatinate ions.  Color results are reported in either color units
or mg/L relative to the platinum standard. The MDL for this method is approximately 1
mg/L (ppm).  At this time, EPA has not developed a minimum level for color using this
method.

EPA has added QC tests and specifications as an addendum to NCASI Technical Bulletin
No. 253 to provide  the  level  of QC required in  other  EPA wastewater  methods.
Specifications  for calibration linearity, calibration verification,  and initial and ongoing
precision and recovery are some of the QC elements now included in the method.

13.7  Biochemical  Oxygen Demand (BODg)

BODS is a measure of the relative oxygen requirements of wastewaters, effluents, and
polluted waters. Method 405.1 for determination of BOD5 is incorporated by reference into '
40 CFR Part 136.  The BOD5 test specified in this method is an empirical bioassay-type
procedure which measures dissolved oxygen consumed by mierobial life while assimilating
and oxidizing  the organic matter  present.   The  standard  test conditions include dark
incubation at 20°C for a five-day period.

13.8  Total Suspended Solids (TSS)

TSS are to be measured using EPA Method 160.2 or other methods for TSS which are
incorporated by reference into 40 CFR Part  136.  In this method, a well-mixed sample  is
filtered  through a pre-weighed glass fiber filter. The filter is dried to constant weight at 103-
105 °C.  The weight of material on the filter divided by the sample volume is the amount
of TSS.

13.9  Other Analvtes

During  several screening episodes, EPA analyzed wastewater samples for pollutants in four
other chemical categories: resin and  fatty  acids,  metals, semi-volatile compounds,  and
pesticides/herbicides.

13.9.1 Resin and Fatty Acids

Resin and fatty acids were analyzed by the method described in NCASI Technical Bulletin
No. 501.  This method uses GC/MS or GC combined with a flame ionization detector

                                       13-6

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                                                                13.0 Analytical Methods
 (GC/FID).  Wastewater samples are extracted with an organic solvent.  The extract is
 concentrated and the resin and fatty acids are converted to the ethyl ester derivatives.
 GC/MS analysis does not require any further cleanup. GC/FID analysis requires cleanup
 with a silica gel column.  The resin and fatty acid esters are quantified by an external
 standard  calibration  technique.   MDLs  are  influenced  by  the  sample  matrix and
 interferences.  With no interferences present, compound-specific MDLs ranging from 0.8 to
 5.4 /*g/L (ppb) can be achieved for treated effluents.

 13.9.2  Metals

 Metals were analyzed using EPA Method 1620. This method is a consolidation of the EPA
 200 series methods  for the quantitative determination of 27 trace elements by inductively
 coupled plasma (ICP) and graphite furnace atomic absorption (GFAA), and determination
 of mercury by cold vapor atomic absorption (CVAA). The method also provides a semi-
 quantitative ICP screen for 42 additional elements.  The ICP technique measures atomic
 emissions by optical spectroscopy.  GFAA measures the atomic absorption of a vaporized
 sample, and CVAA measures the atomic  absorption of mercury vapor.   MDLs are
 influenced by  the  sample  matrix and interferences.  With no interferences present,
 compound-specific MDLs ranging from 0.3 to 75 jwg/L (ppb)  can be achieved.

 13.9.3  Semi-volatile Organic Compounds

 Semi-volatile organic compounds were analyzed by EPA Method 1625, Revision C. In this
 method,  samples  are prepared by liquid-liquid extraction with  methylene chloride in a
 separatory funnel or continuous liquid-liquid extractor.  Separate acid  and base/neutral
 extracts are concentrated to 1.0 mL, and a 1 /iL aliquot is injected into an HRGC/LRMS.
 The detection limit of the  method is usually dependent upon interferences  rather than
 instrument limitations. With no interferences present, minimum levels of 10,20, or 50 ng/L
 (ppb) can be achieved, depending upon the specific compound.

 13.9.4 Pesticides and Herbicides

Pesticides and herbicides were analyzed by EPA Method 1618. Method 1618 is  a wide-bore
 capillary column GC method for determination of organo-halide and organo-phosphorus
pesticides, phenoxy-acid herbicides, and other compounds  amenable to  extraction and
analysis by GC with organo-halide and  organo-phosphorus detectors. The detection limit
of the method is usually dependent upon interferences rather than instrument limitations.
With no interferences present, compound-specific MDLs ranging from 2 -1,000 ng/L (ppt)
can be achieved. '
                                       13-7

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                     Table 13-1

Regulatory Status of Analytical Methods To Be Used To
    Determine Compliance With the Proposed Rule
Regulated Pollutant
2,3,7,8-TCDD
2,3,7,8-TCDF
Volatile Qreanics
Chloroform
Acetone
Methyl Ethyl Ketone
Methylene Chloride
AOX
Chlorinated Phenolics
2,3,4,6-Tetrachlorophenol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
3,4,5-Trichlorocatechol
3,4,5-Trichloroguaiacol
3,4,6-Trichlorocatechol
3,4,6-Trichloroguaiacol
4,5,6-Trichloroguaiacol
Tetrachlorocatechol
Tetrachloroguaiacol
Trichlorosyringol
Pentachlorophenol
COD
Effluent Water Color
BOD,
TSS
Chemical
Abstract
Service No,
1746-01-6
51207-31-9
67-66-3
67-64-1
78-93-3
75-09-2
—
58-90-2
95-95-4
88-06-2
56961-20-7
57057-83-7
32139-72-3
60712-44-9
2668-24-8
1198-55-6
2539-17-5
2539-26-6
87-86-5
~
—
~
~
Method
1613
1624
1650
1653
410.1
410.2
NCASI
253
405.1
160.2
Technique
HRGC/HRMS
LRGC/LRMS
Titrimetric
HRGC/LRMS
Titrimetric
Spectrometric
Potentiometric
Gravimetric
Regulatory
Status
Proposed, 1991
56 FR 5090
Promulgated 40
CFR Part 136
This Proposal
This Proposal
Promulgated 40
CFR Part 136
This Proposal
Promulgated 40
CFR Part 136
Promulgated 40
CFR Part 136
                         13-8

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14.0
                           14.0 Best Practicable Control Technology Current Available and
                                       Best Conventional Pollutant Control Technology

BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE AND
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
14.1   Introduction

Best  Practicable Control Technology Currently Available (BPT) effluent  limitations
guidelines are generally based upon the average of the best existing performance, in terms
of treated effluent discharged by facilities in a category or subcategory.  BPT focuses on
end-of-pipe treatment technology and such process changes and internal controls that are
common industry practice. In establishing BPT, the Agency considers the cost of achieving
effluent reductions in  relation to  the effluent reduction  benefits, the size and age of
equipment and facilities, the processes used, process changes required, engineering aspects
of the control technologies, non-water quality environmental impacts (including energy
requirements), and other factors the Administrator deems appropriate (Section 304(b)(l)(B)
of the Clean Water Act (CWA)). Where existing performance is uniformly inadequate, BPT
may be transferred from a different subcategory or category.

The 1977  amendments to the CWA established BCT for discharges  of conventional
pollutants, including biological oxygen demand (BODS), total suspended solids (TSS), and
pH, from existing industrial point sources. BCT is not an additional limitation but replaces
BAT for the  control of conventional  pollutants.  In addition to other factors specified in
Section 304(b)(4)(B), the CWA requires that BCT limitations be  established in light  of a
two-part "cost-reasonableness" test.  EPA issued a methodology for the development of BCT
limitations  in July 1986 (51 FR 24974).

14.2   Regulated Pollutants

The current BPT regulations, promulgated between 1974 and 1982, established limitations
for BOD5, TSS, and pH for 26 separate  subcategories.  The current BCT regulations are
identical  to the  current BPT regulations.  The Agency is proposing to consolidate the
current 26  subcategories to 12 subcategories, and to revise the limitations for BOD5  and
TSS.

14.3   Identification of BPT

14.3.1  BPT Performance Level and Limitations

As described in Section 9.2, the Agency developed and analyzed two options for BPT.  For
all subcategories other  than Dissolving Sulfite, the two options are:

       (1)    The performance level  representing the average of the best  90  percent of
             mills in each subcategory; and
                                       14-1

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                                  14.0 Best Practicable Control Technology Current Available and
                                              Best Conventional Pollutant Control Technology

      (2)    The performance level representing the average of the best 50 percent of
             mills in each subcategory.

For the Dissolving Sulfite Subcategory, the Agency also analyzed two options:

      (1)    The performance level representing the best mill in the subcategory; and

      (2)    Reduction in raw waste load through in-plant process changes that are the
             technology  bases  for National Emission  Standards for Hazardous  Air
             Pollutants (NESHAP),  Best Available Control Technology  Economically
             Achievable (BAT), and Best Management Practices (BMP); and end-of-pipe
             primary and secondary (biological) treatment.

Analyses of the impacts of these options in terms of reduction in pollutant discharges to the
environment, costs to industry, and non-water quality environmental impacts are described
in Sections 10, 11, and 12, respectively.  After comparing the estimated costs to effluent
reduction benefits of each option, the Agency concluded that Option 2, for all subcategories,
was reasonable and justified.

BPT effluent limitations were developed as described in the Statistical Support Document.
Table 14-1 presents the BPT effluent limitations that the Agency is proposing for continuous
dischargers. Table 14-2 presents the BPT effluent limitations that the Agency is proposing
for non-continuous dischargers.

14.3.2  Description of Technology Basis

The BPT performance levels are calculated from measured effluent pollutant concentrations,
effluent flow rate, and mill production, as follows:
                                 PNL = C x
                    PNF
                    1,000
(1)
where:
       PNL

       C

       PNF
production normalized load, kg/metric ton

concentration, mg/L

production normalized flow, m3/metric ton
                                        14-2

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                                   14.0 Best Practicable Control Technology Current Available and
                                               Best Conventional Pollutant Control Technology

 Thus, the performance level, expressed as production normalized mass load,  is equally
 dependent on the effluent concentrations achieved by end-of-pipe treatment and production
 normalized flow resulting from in-process water conservation practices.

 As discussed in Section 9.2.5, there are many ways in-process flow reduction technologies
 and end-of-pipe wastewater treatment can be combined to achieve BPT performance levels.
 Mills that treat wastewater to low concentrations but have poor water conservation practices
 evidenced by  high production normalized flows cannot  achieve  the low production
 normalized mass loads achieved by the best performing mills.  These mills will require in-
 process flow reduction to meet BPT.

 Appropriate flow  reduction  technologies  vary by  the process  operations used in a
 subcategory. Flow reduction considered as part of the technology basis for BPT includes
 one or more of the following:

       1.     Increased reuse and recycle of pulp and paper machine white water through
             the use of paper machine gravity strainers with high-pressure, self-cleaning
             showers or disk savealls;

       2.     Paper machine vacuum pump seal water recycle;

       3.     Screen room closure; and/or

       4.     Reuse of deinking washwater after flotation clarification.

 The two secondary treatment technologies commonly used in the pulp and paper industry
 are aerated stabilization basin (ASB) systems and  activated sludge systems.  The Agency
 identified feasible upgrades  for each  treatment type.  ASB  treatment systems can be
 upgraded by increasing the amount of aeration in existing ponds, by increasing the volume
 of aerated ponds or by adding new ponds (resulting in increased hydraulic detection time),
 by supplementing the nutrients available  in the mill wastewater, and/or by  providing
 additional settling capacity for the removal of suspended solids.

 Activated sludge systems can be upgraded by increasing the capacity of aeration basins
 (resulting in longer hydraulic detention times and lower BOD5-to-microorganism ratios), by
 increasing the size of clarification equipment, and/or by adding flocculant to improve sludge
 settling.

The combination of upgrades applicable to a mill will be dependent upon the characteristics
 of its wastewater and upon the treatment it currently uses.

Table  14-3  presents production normalized flow, effluent concentrations,  and critical
wastewater treatment system design parameters for mills that achieve BPT performance

                                       14-3

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                                 14.0 Best Practicable Control Technology Current Available and
                                             Best Conventional Pollutant Control Technology

levels.  The data are presented for those subcategories where such a disclosure does not
compromise confidential business information.

14.4  BCT

As described in Section 9.3, the Agency developed two options for BCT:

      (1)   The performance level  of the best-performing mill  in  each subcategory
            (Option A.1); and

      (2)   Multimedia  filtration following  flow  reduction, primary  treatment,  and
            secondary treatment (Option A.2).

The Agency was not able to fully analyze Option A.1.  The analyses of the impact of Option
A.2 in terms of reduction in pollutant discharges to the environment and costs to industry
are described in Sections 10.0 and 11.0, respectively. Option A.2 failed to pass the BCT cost
test in 11 subcategories.  Consequently, the Agency is proposing to  set BCT equal to the
proposed BPT in these 11 subcategories. The Agency found that multimedia filtration (BCT
Option A.2) passed the BCT cost test in the Mechanical Pulp Subcategory. As a result, the
Agency is proposing multimedia filtration as  the BCT technology in this subcategory.
However, EPA does not have  sufficient data at this time to propose limits for BOD5 and
TSS discharges based on this technology.  BCT effluent limitations, for all subcategories
other than Mechanical Pulp, are identical to  the BPT effluent limitations presented in
Tables 14-1 and 14-2.

14.5   Implementation

BPT effluent guidelines are applied to individual mills through National Pollutant Discharge
Elimination System (NPDES) permits issued by EPA or authorized states under Section 402
of the CWA.  Using annual average production information  supplied by the mill and the
BPT effluent  guidelines, the permitting authority  will establish  numerical  discharge
limitations for the mill and specify monitoring  and reporting  requirements.

14.5.1 NPDES Production Rate (Production Normalizing Parameter)

For the proposed BPT effluent limitations guidelines, production is defined as the annual
off-machine production (including off-machine coating where applicable) divided by the
number of operating days during  that year.  Paper and paperboard production shall be
measured at the off-machine moisture content whereas market pulp shall be measured in
air dry tons (10 percent moisture). Production shall be determined for each mill based upon
the highest annual production in the past five years divided by the number of operating days
 that year. The mill's production in each subcategory is used with the subcategory production
 normalized mass effluent limitations guidelines to calculate null-specific NPDES permit limitations.

                                        14-4

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                                  14.0 Best Practicable Control Technology Current Available and
                                              Best Conventional Pollutant Control Technology
14.5.2  Point of Application
BPT effluent limitation guidelines are applicable to the final effluent discharged to waters
of the United States.

14.5.3 Application of BPT to Mills in More Than One Subcategory

The Agency has structured the proposed  BPT  effluent guidelines in a building-block
approach.   This means  that the applicable NPDES permit limitations for mills with
production in more than one subcategory will be the sum of the mass loadings based upon
production  in  each subcategory and  the  respective  subcategory effluent  limitations
guidelines. Examples of this approach are provided below.
14.5.3.1
Example 1:  Integrated Bleached Kraft Mill
An integrated bleached kraft mill produced 315,000 OMMT (kkg) of uncoated free sheet
in 1993.  1993 was the highest production year for the past five years.  In 1993, the paper
machine operated 350 days.  Virgin softwood, pulped and bleached on site, constitutes 85
percent, by weight, of this production. The remaining 15 percent is derived from purchased
pulp.

The production at this mill falls into two subcategories: Subpart B - Bleached Papergrade
Kraft and Soda and Subpart K - Fine and Lightweight Papers from Purchased Pulp. The
production in each subcategory may be calculated as follows:

The NPDES production rate for the purpose of calculating BOD5 and TSS limitations is:
                            NPDES = PROD/OPDAYS
                                                                  (2)
where:
      NPDES


      PROD


      OPDAYS
            NPDES production rate for the purpose of calculating BOD5
            and TSS permit limitations, kkg/day

            highest annual off-machine production in the past five calendar
            years, kkg/yr

            number of paper machine operating days in the calendar year
            used for PROD, days.
                                       14-5

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                                  14.0 Best Practicable Control Technology Current Available and
                                              Best Conventional Pollutant Control Technology

Using Equation 2:

      315,000 kkg/year / 350 days/year = 900 kkg/day

      900 kkg/day x 0.85 = 765 kkg/day Subcategory B production

      900 kkg/day x 0.15 = 135 kkg/day Subcategory K production

The BPT effluent limitations guidelines for these two subcategories (Table 14-1) are:
Subpart
B
K
Maximum for 1 Day
(kg/kkg)
BOB5
4.26
5.87
TSS „?•
8.75
4.87
Monthly Average (kg/kkg)
Bb»s
2.19
2.29
TSS
3.89
1.62
Permit limitations are calculated as follows.

Maximum BOD5 for 1 Day:

      4.26 kg/kkg x 765 kkg/day = 3,259
      5.87 kg/kkg x 135 kkg/day =   792
                                   4,051 kg BOD5/day

Maximum TSS for 1 Day:

      8.75 kg/kkg x 765 kkg/day = 6,694
      4.87 kg/kkg x 135 kkg/day =   657
                                   7,351 kg TSS/day

Monthly Average BOD5:

      2.19 kg/kkg x 765 kkg/day = 1,675
      2.29 kg/kkg x 135 kkg/day =   309
                                    1,984 kg BOD5/day
                                        14-6

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                                   14.0 Best Practicable Control Technology Current Available and
                                               Best Conventional Pollutant Control Technology
 Monthly Average TSS:
       3.89 kg/kkg x 765 kkg/day = 2,976
       1.62 kg/kkg x 135 kkg/day =  219
                                    3,195 kg TSS/day

 14.5.3.2      Example!:  Newsprint Mill

 A mill produced  426,000  OMMT (kkg) of newsprint in 1992.  1992  was the highest
 production year for  the past five years.  In 1992, the paper machine operated 355 days.
 Virgin wood, mechanically pulped on site, constitutes 55 percent, by weight, of this
 production. Secondary fiber, deinked on site, constitutes 25 percent of the production. The
 remaining 20 percent is derived from purchased virgin pulp.

 The production at this mill falls into three subcategories:

       •      Subpart G, Mechanical Pulp;

       •      Subpart I, Secondary Fiber Deink; and

       •      Subpart L, Tissue, Filter, Non-Woven and Paperboard from Purchased Pulp.

The production in each subcategory may be calculated as follows:

Using Equation 2 from Example 1:

      426,000 kkg/year / 355 days/year = 1,200  kkg/day

       1,200 kkg/day x 0.55  =  660 kkg/day Subpart G
       1,200 kkg/day x 0.25  =  300 kkg/day Subpart I
       1,200 kkg/day x 0.20  =  240 kkg/day Subpart L.
                                       14-7

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                                 14.Q Best Practicable Control Technology Current Available and
                                             Best Conventional Pollutant Control Technology
The BPT effluent limitations guidelines for these subcategories (Table 14-1) are:
Subpart
G
I ,
L
Maximum for 1 Day
(kg/kkg)
BODS
1.39
5.29
2.96
TSS
5.59
6.12
5.32
^ ^ ^ *"
f f' '"•'f tj
Mont% Averag^ (kg/kkg)
BO»5
0.568
2.16
0.974
TSS
2.02
2.29
1.73
Permit limitations are calculated as follows:

Maximum BOD5 for 1 Day:
       1.39 kg/kkg x 660 kkg/day
       5.29 kg/kkg x 300 kkg/day
       2.96 kg/kkg x 240 kkg/day
 Maximum TSS for 1 Day:

       5.59 kg/kkg x 660 kkg/day
       6.12 kg/kkg x 300 kkg/day
       5.32 kg/kkg x 240 kkg/day
 Monthly Average BOD5:

       0.568 kg/kkg x 660 kkg/day
       2.16 kg/kkg x 300 kkg/day
       0.974 kg/kkg x 240 kkg/day
 Monthly Average TSS:

       2.02 kg/kkg x 660 kkg/day
       2.29 kg/kkg x 300 kkg/day
       1.73 kg/kkg x 240 kkg/day
 917
1,587
 710
 3,214 kg BOD5/day
3,689
1,836
1.277
 6,802 kg TSS/day
   375
   648
   234
                                   1,257 kg BOD5/day
 1,333
  687
  415
 2,435 kg TSS/day
                                        14-8

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                                   14.0  Best Practicable Control Technology Current Available and
                                                Best Conventional Pollutant Control Technology

 14.5.3.3      Example 3: Linerboard Mill

 An integrated kraft mill produced 379,500 OMMT (kkg) in 1993 of two-ply linerboard (high
 yield  unbleached  kraft with a thin,  bleached kraft  top layer).  1993 was the highest
 production year in the past five years. Virgin softwood, pulped on site, is used to produce
 the linerboard. The linerboard mill operated 345 days in 1993.  By weight, 67 percent of
 the finished product is derived from unbleached pulp, while 33 percent, by weight, is derived
 from bleached pulp.

 The production at this mill falls into two subcategories:

       •      Subpart B - Bleached Papergrade Kraft and Soda;  and

       •      Subpart C - Unbleached Kraft.

 The production in each subcategory may be calculated as follows:

 Using Equation 2 from Example 1:

       379,500 kkg/year / 345 days/year  = 1,100 kkg/day

       1,100 kkg/day x 0.67 = 737 kkg/day Subpart B
       1,100 kkg/day x 0.33 = 363 kkg/day Subpart C

 The BPT effluent imitations guidelines for these two subcategories (Table 14-1)  are:
Subpart
B
C
Maximum for 1 Day
Ckg/fckg)
BO»S
4.26
4.19
TSS
8.75
8.14
Monthly Average (kg/kfcg)
BOI>5
2.19
1.90
TJSS
3.89
3.45
Permit limitations are calculated as follows.

Maximum BOD5 for 1 Day:

      4.26 kg/kkg x 737 kkg/day = 3,140
      4.19 kg/kkg x 363 kkg/day = 1.521
                                   4,661 kg BOD5/day
                                        14-9

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                                 14.0  Best Practicable Control Technology Current Available and
                                              Best Conventional Pollutant Control Technology
Maximum TSS for 1 Day:
      8.75 kg/kkg x 737 kkg/day = 6,449
      8.14 kg/kkg x 363 kkg/day = 2,955
                                   9,404 kg TSS/day

Monthly Average, BOD5:

      2.19 kg/kkg x 737 kkg/day = 1,614
      1.90 kg/kkg x 363 kkg/day =   690
                                   2,304 kg BOD5/day

Monthly Average TSS:

      3.89 kg/kkg x 737 kkg/day = 2,867
      3.45 kg/kkg x 363 kkg/day = 1.252
                                   4,119 kg TSS/day

14.5.4 Application of BPT to Mills With Noncontinuous Discharges

Example:    Integrated Bleached Kraft Mill

An integrated bleached kraft mill produced  315,000 OMMT (kkg) of uncoated free sheet
in 1993.  1993 was the highest production year for the past five years. In 1993, the paper
machine operated 350 days.  Virgin softwood, pulped and bleached on site, constitutes 85
percent, by weight, of this production.  The remaining 15 percent is derived from purchased
pulp.  The mill stores wastewater in a holding pond and does not discharge wastewater
during  August,  September,  and  October, because  of receiving  stream conditions.
Wastewater is discharged over the remaining nine months of the year.

The production at this mill falls into two subcategories:

       •     Subpart B - Bleached Papergrade Kraft and Soda;  and

       •     Subpart K  -  Fine and Lightweight  Papers from Purchased Pulp.   The
             production in each subcategory may be calculated as follows:

       315,000 kkg/yr x 0.85 = 267,750 kkg/yr Subpart B
       315,000 kkg/yr x 0.15 = 47,250 kkg/yr Subpart K
                                        14-10

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                                   14.0 Best Practicable Control Technology Current Available and
                                                Best Conventional Pollutant Control Technology

 The BPT effluent  limitations guidelines  for  non-continuous  dischargers for these two
 subcategories (Table 14-2) are:
Subpart
B
K
Annual Average (kg/kkg)
BODS
1.57
1.59
TSS
2.72
1.23
 Permit limitations are calculated as follows.
 Annual Average BOD5:

       267,750 kkg/yr x 1.57 kg/kkg
       47,250 kkg/yr x  1.59 kg/kkg =
Annual Average TSS:

       267,750 kkg/yr x 2.72 =
       47,250 kkg/yr x 1.23 =
420,368
 75.128
495,496 kg BOD5/yr
728,280
 58.118
786,398 kg TSS/yr
It is  recommended that non-continuous  discharging  mills with  annual average  mass
limitations track their mass discharged throughout the year by a cumulative total ("running
balance") of the mass  of each pollutant  discharged.  By  closely monitoring the  mass
discharged during each day of the discharge period and updating the total annual discharge
to date, mills with potential compliance problems will be aware of the situation with
adequate time to take .remedial action.  Remedial action might include wastewater flow
reduction and improvement to treatment system performance.

Annual average effluent limitations must be applied to non-continuous dischargers.  Daily
maximum and monthly average limitations may be applied also, and can be calculated by
using the effluent limitations guidelines  for  continuous  dischargers, and  adjusting the
production appropriately.  Production is adjusted using the equation:
                                       14-11

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                                 14.0 Best Practicable Control Technology Current Available and
                                              Best Conventional Pollutant Control Technology
                             PRDDADJ = NPDES
                                                                             (3)
where:
      PROD
            'ADJ
       NPDES


       T,
                         Adjusted production rate for the purpose of calculating daily
                         and monthly permit limitations for noncontinuous dischargers,
                         kkg/day

                         NPDES production calculated using Equation 2 in Section
                         14.5.3.1, kkg/day

                         Length of time over which wastewater discharged is produced

      Xj           =     Length of tune over which wastewater is discharged.

In this example, wastewater from twelve months of production is discharged over a nine-
month period. The NPDES production is the same as calculated in Example 1 in Section
14.5.3.1:

       765 kkg/day Subpart B
       135 kkg/day Subpart K

Therefore, the adjusted productions, using Equation 3, are:

       Subpart B:  765 kkg/day x (12 months/9 months)  = 1,020 kkg/day
       Subpart K:  135 kkg/day x (12 months/9 months)  = 180 kkg/day

The daily maximum and monthly average BPT effluent limitations guidelines for these two
subcategories (Table 14-1) are:
Subpart .
B
K
Maximum for 1 Day
(kg/fckg)
BO»S
4.26
5.87
TSS
8.75
4.87
Monthly Average (feg/kkg)
BOB*
2.19
2.29
TSS
3.89
1.62
                                        14-12

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                                  14.0 Best Practicable Control Technology Current Available and
                                               Best Conventional Pollutant Control Technology

 Daily maximum and monthly average permit limitations are calculated as follows.

 Maximum BOD5 for 1 Day:

       4.26 kg/kkg x 1,020 kkg/day =   4,345
       5.87 kg/kkg x 180 kkg/day =     1.057
 Maximum TSS for 1 Day:
                                       5,402 kg BOD5/day
       8.75 kg/kkg x 1,020 kkg/day =    8,925
       4.87 kg/kkg x 180 kkg/day =      877
                                       9,802 kg TSS/day
Monthly Average BOD5:
       2.19 kg/kkg x 1,020 kkg/day =    2,234
       2.29 kg/kkg x 180 kkg/day =      412
Monthly Average TSS:

       3.89 kg/kkg x 1,020 kkg/day =
       1.62 kg/kkg x 180 kkg/day =
                                       2,646 kg BOD5/day
3,968
 292
4,260 kg TSS/day
These mass limitations can be converted to a concentration basis, by dividing by the actual
average discharge flow during discharge periods:
                                            LM
                                            _
                                         (4)
where:
                   concentration-based effluent limitation, mg/L

                   unit conversion factor
                                       14-13

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                                  14.0 Best Practicable Control Technology Current Available and
                                               Best Conventional Pollutant Control Technology

      LM    =     mass-based effluent limitation, kg/day

      F     =     actual average process wastewater discharge flow during discharge
                   period, m3/day.

The example mill  discharged an average  of  100,000  m3/clay  (26.4 MOD) of process
wastewater during the nine months in  1993 in which discharge occurred.  The monthly
average BOD5 concentration limit is calculated using Equation 4:
              1,000,000 mg/kg    2,646 kg BODs/day  =
1,000 L/m
                                   100,000 m3/day

Note that since the flow term is in the denominator, the higher the mill's discharge flow, the
lower the equivalent concentration limit becomes.  Therefore, it is in the mill's best interest
to practice water conservation and flow reduction and thereby lower process water discharge
flow rates.
                                         14-14

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                                         15.0  Best Available Technology Economically Achievable
 15.0  BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE

 15.1  Introduction

 Best Available Technology Economically Achievable (BAT) effluent limitations guidelines
 represent the best existing economically achievable performance of plants in the industrial
 subcategory or category.  The Clean Water Act (CWA) establishes  BAT as the principal
 national means of controlling the direct discharge of priority pollutants and nonconventional
 pollutants  to navigable waters of the United States.  The factors considered in assessing
 BAT include the age of equipment and facilities involved, the process used, process changes,
 and non-water quality environmental impacts, including energy requirements.  The Agency
 retains considerable discretion in assigning the weight to be accorded these factors. As with
 BPT, where existing performance is uniformly inadequate, BAT may be transferred from a
 different subcategory or category. BAT may include process changes or  internal controls,
 even when these technologies are not common industry practice.

 15.2   Regulated Pollutants

 The Agency is proposing to consolidate the current 26 subcategories into  12 subcategories.
 BAT effluent limitations guidelines regulating the discharge of priority and nonconventional
 pollutants  are proposed for six of these subcategories:

             Dissolving Kraft;
             Bleached Papergrade Kraft and Soda;
             Unbleached Kraft:
             Dissolving Sulfite;
             Papergrade Sulfite; and
             Semi-Chemical.

 The pollutants regulated at BAT are listed in Table 15-1, by subcategory. Pollutants  are
 shown for  two monitoring points on Table 15-1:  bleach plant effluent and final effluent.
 These  monitoring points are discussed further in Section 15.4.2.

 Volatile  organics, chlorinated phenolics, adsorbable organic halides (AOX),  and 2,3,7,8-
 tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD) and 2,3,7,8-tetrachlorodibenzofuran (2,3,7,8-
 TCDF) will be regulated in the Dissolving Kraft,  Bleached Papergrade  Kraft and Soda,
 Dissolving  Sulfite, and Papergrade Sulfite Subcategories. Chemical oxygen demand (COD)
will  be limited in each of the six subcategories listed  above; however,  data to support
limitations  in the Dissolving Sulfite Subcategory  are currently not  available and COD
effluent  limitations guidelines have  not been proposed for that subcategory.   Color
limitations  are being proposed in the Bleached Papergrade  Kraft and Soda Subcategory.
The Agency has solicited  additional performance data  for  certain  pollutants  and

                                        15-1

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                                       15.0 Best Available Technology Economically Achievable
technologies, as detailed in the preamble.  The Agency will consider developing limitations
for these pollutants at a later date.

The  current BAT regulations,  promulgated in  1982,  established effluent limitations
guidelines for zinc in Subparts L, M, N, and O which have been combined into the proposed
Subpart G - Mechanical Pulping Subcategory.  Effluent limitations guidelines were also
promulgated for trichlorophenol and pentachlorophenol in 24 of 26 subcategories.  The
Agency intends to withdraw the current regulations at 40 CFR Parts 430 and 431 when this
proposed regulation is promulgated'. Consequently, none of the current effluent limitations
guidelines and standards will be effective after that time.

15.3   Identification of BAT

The selected BAT option and resulting BAT limitations for each subcategory is  presented
in this section. Derivation of the numerical BAT effluent limitations guidelines is described
in the Statistical Support Document.

The owners or operators of facilities subject to  BAT are not required to use the specific
process technologies and wastewater treatment technologies selected by EPA to establish
the BAT, but may choose to use any combination of process technologies and wastewater
treatment to comply with National Pollutant Discharge Elimination System (NPDES) permit
effluent limitations derived from BAT effluent limitations guidelines.

15.3.1 Subpart B - Bleached Papergrade Kraft and Soda Subcategory

The Agency developed five BAT options for the Bleached Papergrade Kraft and Soda
Subcategory.   The Agency considered developing a sixth, totally chlorine-free (TCP)
bleaching option but does not consider TCP bleaching to be an available technology option
for the Bleached Papergrade Kraft and Soda Subcategory at this time.

The five technology options all include these elements:

       •     Adequate  wood chip size control,  achieved by close  control of chipping
             equipment tolerances or use of chip-thickness screens;

       •     Elimination of defoamers and pitch dispersants containing dioxin precursors;

       •     Effective brown stock washing that achieves  a washing loss of 10
             per metric ton or less;
                                        15-2

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                                         15.0  Best Available Technology Economically Achievable
       •      Elimination of hypochlorite, replacing it with oxygen and peroxide enhanced
              extraction and additional  chlorine dioxide bleaching power in brightening
              stages;

       •      Oxygen and peroxide enhanced extraction; and

       •      High shear mixing for the split addition of chlorine in Option 1, for addition
              of chlorine dioxide, and for addition of oxygen in reinforced extraction.

 In addition to these elements,  the  five  technology options considered for the Bleached
 Papergrade Kraft and Soda BAT are:

 •      Option 1 - Split Addition of Chlorine. For this option, the total equivalent chlorine
 added to the first stage of bleaching is applied in two steps.

 •      Option 2 - Substitution of Chlorine Dioxide for Chlorine. Chlorine is replaced with
 chlorine dioxide  to reduce the active chlorine multiple ratio to 0.90 or less (see Section
 9.4.2.3).

 •      Option 3 - Oxygen Delignification OR Extended Delignification With Substitution
 of Chlorine Dioxide for Chlorine.

 •      Option 4  - Oxygen Delignification OR Extended Delignification  With Complete
 Substitution of Chlorine Dioxide for Chlorine.

 •      Option 5 - Oxygen Delignification AND Extended Delignification With Complete
 Substitution of Chlorine Dioxide for Chlorine.

 The Agency selected Option 4 as the technology  basis for the proposed BAT effluent
 limitations guidelines for the Bleached Papergrade Kraft and Soda Subcategory.  In making
 this decision, EPA  considered  factors  including the  effluent reduction attainable,' the
 economic achievability of each option, the  age of equipment and facilities involved, the
 process used, the engineering aspects of various types of control techniques, process changes,
 the cost  of achieving effluent reductions, and non-water quality environmental impacts
 (including energy requirements). EPA selected Option 4 as the  technology basis for the
 Bleached Papergrade Kraft and Soda Subcategory, principally because no other option that
 was both technically feasible and  economically achievable resulted in greater effluent
 reductions.

The technology basis for the proposed  COD  effluent limitations  guidelines consists  of
 effective  brown stock washing, closed brown stock pulp screen room, application of pulping
liquor  spill prevention  and control (Best  Management Practices  (BMP)),  and  Best

                                        15-3

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                                        15.0 Best Available Technology Economically Achievable
Practicable Control Technology (BPT) level secondary treatment performance. The Agency
concluded that this combination of technologies represents the best available technology for
the control of COD.

The Agency considered the age, size, processes, other engineering factors, and non-water
quality environmental impacts pertinent to mills in this subcategory.  No basis could be
found for identifying different COD effluent limitations guidelines within this subcategory
based upon age, size, processes, or other engineering factors.  EPA believes  that the
combination of technologies upon  which COD effluent limitations  are  based would not
result in any significant non-water quality environmental impacts. In addition, the Agency
concluded that the COD effluent limitations are technically and economically achievable
based upon the control technologies identified above.

Alternative BAT effluent limitations guidelines are applicable to mills in this subcategory
that use TCP bleaching processes.  These alternative  guidelines provide mills with an
incentive to eliminate or nearly eliminate the generation and discharge of chlorinated
organic pollutants by using totally chlorine-free processes.  These mills would initially be
required to certify to the permitting authority that their processes are totally chlorine-free.
Except  for AOX, there are no alternative  effluent limitations guidelines for chlorinated
organic  pollutants (i.e., 2,3,7,8-TCDD, 2,3,7,8-TCDF,  chloroform,  methylene  chloride,
chlorinated phenolic compounds) at the bleach plant or  end-of-pipe.  Mills  using TCP
processes would  have effluent limitations for AOX,  and would have initial  monitoring
requirements for specific chlorinated organic pollutants (i.e., 2,3,7,8-TCDD, 2,3,7,8-TCDF,
chloroform,  methylene  chloride,  chlorinated  phenolic  compounds)  which could be
terminated if all  analytical results hi a specified series of sampling events are non-detect.

Table 15-2 presents the BAT effluent limitations guidelines that the Agency is proposing for
the Bleached Papergrade Kraft and Soda Subcategory.  Table 15-3 presents alternative BAT
effluent limitations guidelines that are  applicable to mills  that certify that their bleaching
process is totally chlorine-free.

 15.3.2 Subpart A - Dissolving Kraft Subcategory

The Agency studied the existing manufacturing processes and pollution control technologies
used by the  three mills in the Dissolving Kraft Subcategory and conducted  sampling
programs at two  of the three mills.  Each of these mills has relatively high application rates
 of hypochlorite in the respective bleaching sequences.

The Agency found existing process technologies to be uniformly inadequate to control the
 generation  of   2,3,7,8-TCDD,  2,3,7,8-TCDF,   chloroform,;  and   other priority  and
 nonconventional pollutants generated during the bleaching of dissolving grade pulp. Data
 available indicate that each mill discharges chloroform indicating high  loadings  from the

                                         15-4

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                                         15.0  Best Available Technology Economically Achievable
 bleach plants.  2,3,7,8-TCDD and 2,3,7,8-TCDF were detected in mill effluents at high
 frequency compared to most bleached papergrade kraft mills.

 For these reasons, the Agency considered three regulatory options transferred from the
 Bleached Papergrade Kraft and Soda Subcategory. Each of these options include reduction
 in the amount of chlorine and chlorine-containing compounds applied to the pulp. The
 Agency also  considered a TCP option for this  subcategory.   However, the  Agency
 determined that  TCP technologies  could  not be  practically  applied  at this time for
 production of dissolving kraft pulps.

 The three options considered for the Dissolving  Kraft  Subcategory include  all of the
 common elements of the bleached papergrade kraft options (adequate chip size control,
 elimination of defoamers and pitch dispersants containing dioxin precursors, effective brown
 stock washing, elimination of hypochlorite, oxygen and peroxide enhanced extraction, and
 high  shear  mixing for the addition of chlorine dioxide,  and oxygen), as well as the
 technologies described below:

 •      Option 1 - Substitution of Chlorine  Dioxide for  Chlorine, at the addition rates
 described for bleached papergrade kraft (approximately 70 percent substitution).

 •      Option  2 - Oxygen Delignification With Substitution of Chlorine Dioxide for
 Chlorine.  This option differs from the bleached papergrade kraft option.  It does not
 include extended delignification because the Agency has received information indicating that
 extended delignification cannot  be  applied  in  the  Dissolving Kraft Subcategory.  The
 chlorine dioxide substitution rate is defined as  for bleached papergrade kraft Option 2,
 approximately 70 percent.

 •      Option 3 - Oxygen Delignification With Complete Substitution of Chlorine Dioxide
 for Chlorine. As in Option 2,  this option does not include  extended delignification. While
 the  Agency  developed and  fully  evaluated  this  option, it  recently  received  data
 demonstrating that complete substitution of chlorine dioxide for chlorine is not technically
 feasible in the Dissolving Kraft Subcategory at this time.

 The Agency determined that the performance of dissolving kraft Options 1 and 2 would be
 equivalent to bleached papergrade kraft Options 2 and 3,  respectively.  This conclusion is
 based upon the similarities of components of the process technologies.

The Agency selected Option 2 as the proposed technology basis for BAT effluent limitations
guidelines for the Dissolving Kraft Subcategory.  In making this decision, EPA considered
the following factors:  the effluent reduction attainable, the economic achievabih'ty of each
option, the age of equipment and facilities involved, the process used, the engineering aspect
of various types of control techniques, process changes,  the cost of achieving effluent

                                        15-5

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                                        15.0  Best Available Technology Economically Achievable
reductions, and non-water quality environmental impacts (including energy requirements).
EPA selected  Option 2  as the proposed technology basis for the  Dissolving  Kraft
Subcategory, principally because no other option that was technically and economically
feasible achieved greater effluent reductions.

The technology basis for the proposed COD effluent limitations guidelines for the Dissolving
Kraft Subcategory consists of effective brown stock washing, closed brown stock pulp screen
room, application of pulping liquor spill prevention and  control (BMP), and BPT level
secondary  treatment  performance.   The  Agency  concluded that this combination  of
technologies represents the best available technology for the control of COD.

The Agency considered the age, size, processes, other engineering factors, and non-water
quality environmental impacts pertinent to mills in developing the COD effluent limitations
guidelines  for this Subcategory.   No basis could be found for identifying different COD
effluent  Limitations  within this  Subcategory  based on  age, size,  processes, or  other
engineering factors.  EPA believes that the combination  of technologies upon which the
proposed COD effluent limitations guidelines are based will not result in any significant
non-water  quality environmental impacts.  In addition,  the Agency concluded that the
proposed COD effluent limitations guidelines would be economically achievable based upon
the control technologies identified above.

Alternative BAT effluent limitations guidelines are applicable to mills in this Subcategory
that use TCP bleaching processes. These mills would initially be required to certify to the
permitting authority that their processes are totally chlorine-free. Except for AOX, there
are  no  alternative effluent  limitations guidelines for chlorinated organic pollutants (i.e.,
23,7,8-TCDD,  2,3,7,8-TCDF,   chloroform,  methylene   chloride,  chlorinated  phenolic
compounds) at the bleach plant or end-of-pipe. Mills using TCP processes would have
effluent limitations for AOX, and would have initial monitoring requirements for specific
chlorinated organic pollutants  (i.e., 2,3,7,8-TCDD, 2,3,7,8-TCDF, chloroform, methylene
chloride, chlorinated phenolic compounds) which could be terminated if all analytical results
in a specified series of sampling events are non-detect.

Table 15-4 presents the BAT effluent limitations guidelines that the Agency is proposing for
the Dissolving Kraft Subcategory. Table 15-5 presents alternative BAT effluent limitations
guidelines that are applicable  to mills that certify that their  bleaching process is  totally
 chlorine-free.

 The Agency  recently received information from the  industry  that suggests that use of
 hypochlorite for producing certain grades of dissolving kraft pulp is necessary. The Agency
 will evaluate that information  and make appropriate changes to the technology basis and
 the final effluent limitations guidelines, to the extent it finds such changes are warranted.
                                         15-6

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                                         15.0 Best Available Technology Economically Achievable
 15.3.3 Subpart C - Unbleached Kraft Subcategory

 COD effluent limitations guidelines are proposed for the Unbleached Kraft Subcategory.
 These  COD effluent  limitations  guidelines were developed based  upon  engineering
 evaluation of the best available methods to control COD discharges.

 The  technology basis for the proposed COD  effluent limitations guidelines comprises
 effective brown stock washing, closed brown stock pulp screen room operation, application
 of pulping liquor spill prevention and control (BMP),  and BPT level secondary treatment
 performance. The Agency was not able to identify other technologies for controlling COD,
 and therefore concluded that this combination of technologies represents the best available
 technology for the control of COD.

 The Agency considered the age, size, processes, other engineering factors, and non-water
 quality environmental impacts pertinent to mills in this Subcategory.  No basis could be
 found for identifying different COD effluent limitations guidelines within  this Subcategory
 based on age, size, processes, or other engineering factors. EPA has no data to suggest that
 the combination of technologies upon which COD effluent limitations guidelines are based
 significantly increase  non-water quality environmental impacts.  In addition, the Agency
 concluded that the COD effluent guidelines limitations would be economically achievable
 based on the control technologies identified above.

 Table 15-6 presents the BAT effluent limitations guidelines that the Agency is proposing for
 the Unbleached Kraft Subcategory.

 15.3.4 Subpart D - Dissolving Sulfite Subcategory

 The Agency developed three  regulatory options to reduce  priority and nonconventional
pollutants generated during bleaching of dissolving sulfite wood pulps. One of these options
 (20 percent chlorine dioxide substitution for elemental  chlorine) was rejected from further
 consideration for reasons including  lack  of adequate performance data and minimal
improvement in control of pollutants beyond existing practices.

The two regulatory options considered for the Dissolving Sulfite  Subcategory include the
following common elements and are described more fully below:

      •      Adequate wood chip size control, achieved by  close control of chipping
             equipment tolerances' or use of chip-thickness screens.

      •      Elimination of defoamers and pitch dispersants containing dioxin precursors.
                                        15-7

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                                       15.0 Best Available Technology Economically Achievable
•     Option 1 - Oxveen Delignification With Complete Substitution of Chlorine Dioxide
for Chlorine.  This option comprises oxygen delignification followed by bleaching with
complete substitution of chlorine dioxide for chlorine.  High shear mixing is used for the
addition of chlorine dioxide.  This option does not preclude use  of hypochlorite in the
bleach sequence.

•     Option 2  - Totally Chlorine-Free Bleaching.  This'option is  based upon TCP
bleaching processes in use at one foreign mill. The bleach sequence is based upon oxygen
delignification and use of ozone and/or peroxide in subsequent bleaching stages.

The Agency  selected Option  1 as the  technology basis  for the proposed  BAT  effluent
limitations guidelines for the Dissolving Sulfite Subcategory. Option 1  is both technically
and economically feasible. Although Option 2 would achieve the maximum reduction in the
discharge of pollutants to the environment, the Agency found that, based on available data,
this technology has not been demonstrated for the highest purity dissolving sulfite grades
and thus would not be suitable as the basis for BAT effluent limitations guidelines for all
grades produced in the U.S.  However, the Agency is still considering alternative limitations
based upon TCP process technology for certain grades of dissolving sulfite pulps.

In making the decision to select Option 1, EPA considered factors  including:  the effluent
reduction attainable, the economic achievability of each option, the age of equipment and
facilities involved, the process used, the engineering aspects of various types of control
techniques, process changes, the cost of achieving effluent reduction, and non-water quality
environmental impacts (including energy requirements).

Alternative BAT effluent limitations guidelines are applicable to mills in this subcategory
that use TCP bleaching processes. These mills would initially be required to certify to the
permitting authority that their processes are totally chlorine-free. Except for AOX, there
are no alternative effluent limitations guidelines for chlorinated organic pollutants (i.e.,
2,3,7,8-TCDD,  2,3,7,8-TCDF,  chloroform,  methylene  chloride,  chlorinated  phenolic
compounds)  at the bleach plant or end-of-pipe.  Mills using TCP processes would have
effluent limitations for AOX,  and would have initial monitoring requirements for specific
chlorinated organic pollutants (i.e., 2,3,7,8-TCDD, 2,3,7,8-TCDF,  chloroform, methylene
chloride, chlorinated phenolic  compounds) which could be terminated if all analytical results
in a specific  series of sampling events are non-detect.

Table 15-7 presents  the BAT effluent limitations  that the Agency is proposing for the
Dissolving Sulfite Subcategory. The Agency considered proposing BAT effluent limitations
guidelines for COD based on effective brown stock washing, closed brown stock pulp screen
room operation, pulping liquor spill prevention and control, and BPT level treatment. The
Agency was not able to fully analyze this option because it does not have performance data
for this option  at  this time.   Table 15-8 presents alternative BAT effluent limitation^

                                         15-8

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                                         15.0 Best Available Technology Economically Achievable
 guidelines that are applicable to mills that certify that their bleaching process is totally
 chlorine-free.

 15.3.5  Subpart E - Papergrade Sulfite Subcategory

 The Agency considered three options to reduce generation and discharge of priority and
 nonconventional pollutants during bleaching of papergrade sulfite wood pulps. One of these
 options (based upon oxygen and peroxide  enhanced extraction) was rejected for reasons
 including insufficient performance data to fully  characterize  the option  and minimal
 improvement in control of pollutants beyond existing practices. Two options were analyzed
 in detail.

 The two regulatory options include the following common elements and are described more
 fully below:

       •     Adequate wood chip size  control, achieved by close control of chipping
             equipment tolerances  or use of chip-thickness screens;

       •     Elimination of defoamers and pitch dispersants containing dioxin precursors;
             and

       •     Elimination of hypochlorite in the bleaching sequence.

 *      Option  1 - Oxygen Delignification With Complete Substitution of Chlorine Dioxide
 for Chlorine.  High  shear mixing is used for chlorine dioxide addition.

 *      Option  2 -  Totally Chlorine-Free Bleaching.   This option is  based upon TCP
 bleaching processes  used by mills in other countries. Although bleach sequences at these
 mills vary, all are based upon oxygen delignification or an extraction stage using oxygen
 and/or peroxide, followed by one or more peroxide bleaching stages.

 The Agency selected Option  2 as the technology basis for the proposed BAT effluent
 limitations guidelines for the Papergrade Sulfite Subcategory.  Option 2 is both technically
 and  economically feasible  and will  achieve the maximum reduction in the  discharge of
 pollutants because no chlorine or chlorine-containing bleaching  chemicals are used, and
 therefore, chlorinated pollutants are not formed.

In making the decision to select Option 2, EPA considered factors including:  the effluent
reduction attainable, the economic achievability of each option, the  age of equipment and
facilities involved, the process used, the engineering aspects of  various types of control
techniques, process changes, the cost of achieving effluent reduction, and non-water quality
environmental impacts (including energy requirements).

                                        15-9

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                                       15.0 Best Available Technology Economically Achievable
The technology  basis for the proposed COD effluent limitations  guidelines comprises
effective brown stock washing, closed brown stock pulp screen room operation, application
of pulping liquor spill prevention and control (BMP), and BPT level secondary treatment
performance. The Agency concluded that this combination of technologies represents the
best available technology for the control of COD.

The Agency considered the age,.size, processes, other engineering factors, and non-water
quality environmental impacts pertinent to mills in this subcategory.  No basis could be
found for identifying different COD effluent limitations within this subcategory based upon
age size processes, or other engineering factors. EPA believes that the combination of
technologies  upon which COD  effluent limitations  are based would not result in any
significant non-water quality environmental impacts. In addition, the Agency concluded that
the COD effluent limitations are technically and economically achievable based upon the
control technologies identified above.

Table  15-9 presents the BAT effluent limitations that the Agency is proposing for the
Papergrade Sulfite Subcategory. In addition to the effluent limitations guidelines presented
on Table 15-9, the owner or operator of  the facility must certify, in the NPDES permit
application, that chlorine or chlorine-containing compounds are not used for pulp bleaching.
In addition, the owner or operator of the facility must provide, as part of the NPDES permit
application, monitoring results for three composite bleach plant wastewater samples tor
CDDs/CDFs and  chlorinated phenolics, and  three grab  samples for chloroform  and
methylene chloride. Such samples shall be obtained at approximately weekly intervals.

 15.3.6 Subpart F - Semi-Chemical Subcategory

 COD effluent limitations are proposed for the Semi-Chemical Subcategory.  These COD
 limitations were developed based upon engineering evaluation of the best available methods
 to control COD discharges. COD data are not available for technologies that control losses
 of pulping liquors and wood extractives (e.g., BMP, etc.) in this subcategory.  However, the
 Agency is transferring data from the Unbleached Kraft Subcategory as the basis for the
 proposed effluent limitations guidelines.  The pulping processes in the Unbleached Kraft
 Subcategory are similar to those used in the Semi-Chemical Subcategory, and therefore the
 Agency has concluded that data transfer is appropriate.

 The technology basis for the proposed COD  effluent  limitations guidelines consists of
 effective brown stock washing, application of pulping liquor spill prevention and control
 (BMP) and BPT level secondary treatment performance.  Screening is usually not practiced
 at semi-chemical pulp mills.  Therefore, closed screen room operation is not included as
 part of the  technology basis for the COD control at serni-chemical mills.  The Agency
 concluded that this combination of technologies represents the best available technology for
 the control of COD.

                                        15-10

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                                        15.0 Best Available Technology Economically Achievable
 The Agency considered the age, size, processes, other engineering factors, and non-water
 quality environmental impacts pertinent to mills in this subcategory.  No basis could be
 found for identifying different COD effluent limitations within this subcategory based on
 age, size, processes, or other engineering factors.  EPA has no  data to suggest that the
 combination of technologies upon which COD effluent limitations are based significantly
 increase non-water quality environmental impacts. In addition, the Agency concluded that
 the  COD  effluent limitations would be  economically achievable based on the control
 technologies identified above.

 Table 15-10 presents the BAT effluent limitations that the Agency is proposing for the Semi-
 Chemical Subcategory.

 The Agency does not have adequate information and data at this time to determine that
 BAT to control priority and other nonconventional pollutants from existing semi-chemical
 mills is warranted. However, the Agency may consider the need for effluent limitations and
 standards for other pollutants after further review  as  part of its CWA Section 304(m)
 planning process.

 15.4   Implementation

 BAT effluent limitations guidelines are applied to individual mills through NPDES permits
 issued  by EPA or authorized  states under Section 402  of  the CWA.  Using annual
 production information supplied by the mill as required in the regulation and the BAT
 effluent limitations guidelines, the permitting authority will establish numerical discharge
 limitations for the mill and specify monitoring and reporting requirements.

 15.4.1  NPDES Production Rate (Production Normalizing Parameter)

 For all the proposed effluent limitations guidelines except COD and color, the daily NPDES
 production rate is the annual unbleached pulp production that enters the bleach plant (at
 10 percent moisture) divided by the number of operating days of the bleach plant.  The
 proposed regulation specifies that the annual production rate shall be the maximum annual
 (calendar year) production rate for the previous five  years.

 The  bleach plant begins with the stage where bleaching agents  (e.g., chlorine, chlorine
 dioxide, ozone,  sodium or calcium hypochlorite,  peroxide) are first applied.  A limited
number of mills produce specialty grades of pulp using hydrolysis or extraction stages prior
 to the first application of bleaching agents. For those mills, EPA considers the bleach plant
to include those pulp pretreatment stages.  Oxygen delignification systems, operated prior •
to the application ,of bleaching agents, are not considered part of the bleach plant.
                                       15-11

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                                       15.0 Best Available Technology Economically Achievable
Wastewater COD and color loadings result primarily from pulp mill wastewaters and bleach
plant extraction stages. Therefore, for COD and color effluent limitations guidelines applied
at the end-of-pipe, the NPDES production rate is the annual unbleached pulp production
(at 10 percent moisture) divided by the number of operating days of the pulp mill during
the year.

Daily production shall be determined for each mill based upon the maximum annual
production rate during he previous five years divided by the number of operating days that
year. The mill's production in each subcategory is used with the subcategory production
normalized mass  effluent limitations guidelines to calculate mill-specific monthly average
and daily maximum NPDES permit bleach plant and effluent limitations.

15.4.2  Point of Application

15.4.2.1      BAT Limitations for Bleach Plant Effluent

BAT limitations for 2,3,7,8-TCDD, 2,3,7,8-TCDF, volatile organics,  and  chlorinated
phenolics will be applied at the effluent from the bleach plant. Control at this point is
necessary because, with the chemical analytical methods currently available, discharges of
2,3,7,8-TCDD, 2,3,7,8-TCDF, and most chlorinated phenolic compounds of concern from the
bleach plant will be near or below analytical method detection limits for mills using the
technologies that form the basis for the proposed BAT effluent limitations guidelines. If the
effluent limitations were not applied at the effluent from the bleach plant, compliance could
be achieved in some instances through dilution of bleach plant wastewaters with the large
wastewater flows frqm the rest of the mill. 2,3,7,8-TCDD and 2,3,7,8-TCDF, present but in
concentrations below detection limits, would then either be discharged to receiving streams
 (where these pollutants bioaccumulate), or to the sludge generated by the mill's secondary
wastewater treatment system. EPA believes that these in-plant limitations are critical in
 order to measure the performance of the process changes proposed as the basis for BAT
 limits in the regulation. These process changes, in turn, are critical to multimedia pollution
 prevention in the pulp, paper, and paperboard industry.
                  i
 Chloroform and  other volatile compounds are also controlled by BAT effluent limitations
 guidelines at the bleach plant  effluent. These pollutants cannot be controlled at the end-of-
 pipe because  of the considerable  potential for these  compounds  to volatilize to  the
 atmosphere during the transport, storage,  and treatment of bleach plant effluents and
 dilution with other process wastewaters not containing these pollutants.

 The BAT effluent limitations guidelines are applied to the total discharge of bleach plant
 filtrate from each physical bleach line operated at the mill.  They are not applied to bleach
 plant and chlorine dioxide plant air emission control scrubber blowdowns, floor washings,
 and other miscellaneous flows (e.g., pump seal water) not included in the filtrate streams.

                                        15-12

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                                        15.0 Best Available Technology Economically Achievable
At most mills that chemically pulp and bleach wood, acid and alkaline bleach stage filtrates
are  discharged to separate sewers; however, at some mills, bleach plant filtrates are
discharged to a  combined sewer  containing both acid and alkaline wastewaters.   For
nonvolatile  compounds  (2,3,7,8-TCDD,  2,3,7,8-TCDF,  and  the  chlorinated phenolic
compounds), compliance with the  BAT limitations  may be demonstrated by collecting
separate samples of the acid and alkaline discharges and preparing a flow-proportioned
composite of these samples in the field, resulting in one sample of bleach plant effluent for
analysis.  For volatile compounds, however, separate samples and analyses of all bleach
plant filtrates discharged separately are required. This is to prevent the loss of compounds
through volatilization as the samples are collected, measured, and composited or through
chemical reaction when the acid and alkaline samples are combined. If separate acid and
alkaline sampling locations do not exist, compliance samples must be collected from the
point closest to the bleach plant that is physically accessible.

Demonstrating compliance with BAT effluent limitations at bleach plant effluent requires
knowledge of the  flow rates of filtrates discharged from the bleach plant. These filtrates are
generally  discharged as seal tank overflows from the first acid stage and the  first caustic
stage, but discharges from subsequent stages are possible.   Filtrate discharge flow rates
should be metered; the cost of installing metering  systems has been accounted for in the
Economic Impact Analysis and is discussed in a memorandum entitled  "Bleach Plant Flow
Monitoring Station Costs," in the Record for the Rulemaking.
15.4.2.2
BAT Limitations for Final Effluent
BAT effluent limitations guidelines for AOX, COD, and color are applicable to the final
effluent discharged to navigable waters of the  United States. This compliance point is
identical to the point used to  demonstrate compliance with BPT  effluent limitations
guidelines.

15.4.3  NPDES Monitoring Requirements

Proposed minimum required monitoring frequencies, and specified analytical methods, are
provided in Table 15-11. The proposed minimum monitoring requirements are set out in
the proposed regulation.

15.4.4  Application of BAT

The Agency has structured the proposed BAT effluent limitations guidelines in a building-
block approach.  .This means that the applicable NPDES permit limitations for mills with
production in more than one subcategory will be the sum of the mass loadings based upon
production in each  subcategory  and  the  respective  subcategory effluent limitations
guidelines. Examples of this approach are provided below.

                                       15-13

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                                      15.0 Best Available Technology Economically Achievable
15.4.4.1     Example 1:  Integrated Bleached Kraft Mill

An integrated bleached kraft mill produced 315,000 OMMT (kkg) of uncoated free sheet
in 1993.  Brown stock pulp production was 283,500 ADMT (kkg) in 1993. 1993 was the
highest production year for the past five years. All brown stock pulp produced on site is
bleached. In 1993, the pulp mill operated 350 days and the bleach plant operated 345 days.
Bleached pulp is combined with pulp produced off site to form the final product.

The  production  at this mill falls into two subcategories:   Subcategory B -  Bleached
Papergrade Kraft and Soda and  Subcategory K - Fine and Lightweight  Papers from
Purchased Pulp.  BAT limitations are applicable to Subcategory B.  Example calculations
of BAT limitations for 2,3,7,8-TCDF and COD are shown below.

The  NPDES production rate for the purpose of calculating COD and color limitations is:
                          NPDES., = PRODyOPDAYSj
                                                    (1)
where:
      NPDESt


      PROD,


      OPDAYSj
NPDES production rate for the purpose of calculating BAT
COD and color permit limitations

Highest annual brown stock pulp production in the past five
calendar years

Number of pulp mill operating days in the calendar year used
for PRODj.
Using Equation 1:

      283,500 kkg/yr / 350 days/yr = 810 kkg/day

The NPDES production for all other BAT permit limitations is:


                           NPDES2  = PROD2/OPDAYS2
                                                    (2)
                                      15-14

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                                       15.0  Best Available Technology Economically Achievable
where:
      NPDES2


      PROD2


      OPDAYS2
NPDES production rate for the purpose of calculating all BAT
permit limitations, except COD and color

Highest annual brown stock pulp production entering the bleach
plant in the past five calendar years

Number of bleach plant operating days in the calendar year
used for PROD2.
Using Equation 2:

      283,500 kkg/yr / 345 days/yr = 822 kkg/day

The BAT effluent limitations guidelines for these constituents (from Table 15-2) are:
Pollutant
2,3,7,8-TCDF
COD
Bleach Plant Effluent
Maximum for
One Day
359 ng/kkg
NA
Monthly ;
Average i
NA
NA
Final Effluent
Maximum fox-
One Day
NA
35.7 kg/kkg
Monthly
Average
NA
25.4 kg/kkg
NA - Not applicable.
ND - Non-detect value - a measurement reported below the minimum level that can be
      reliably measured by the analytical method for the pollutant. Analytical methods and
      minimum levels that apply are shown in Table 15-11.

NPDES permit limitations are calculated as follows:

Bleach Plant Effluent, Maximum for One Day:

2,3,7,8-TCDF:       359 ng/kkg x 822 kkg/day = 295,098 ng/day = 0.295 mg/day
                                      15-15

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                                      15.0 Best Available Technology Economically Achievable
Final Effluent

COD:              Maximum for One Day:

                   35.7 kg/kkg x 810 kkg/day = 28,917 kg/day

                                            = 28.9 kkg/day

                   Monthly Average:

                   25.4 kg/kkg x 810 kkg/day = 20,574 kg/day

                                            = 20.6 kkg/day

15.4.4.2      Example 2: Integrated Bleached Kraft Mill, Non-Continuous Discharger

Example 2 is for the same mill described in Example 1, except in this case the mill does not
discharge process'wastewater during August, September, and October, because of receiving
stream conditions.  Wastewater is  stored in a holding pond  and  discharged over the
remaining nine months of the year.

Bleach plant limitations for this mill are the same as for the continuous discharging mill in
Example 1.  Example calculations of BAT permit limitations for AOX and COD in final
effluent are shown below. The BAT effluent limitations guidelines for these constituents
(from Table 15-2) are:
•
AOX
COD
Annual Average (kg/kkg)
0.143
21.3
Brown stock pulp production was 283,500 kkg in 1993, the highest production year for the
past five years. NPDES permit limitations are calculated as follows:

      AOX: 283,500 kkg/yr x 0.143 kg/kkg = 40,540 kg AOX/yr
      COD: 283,500 kkg/yr x 21.3 kg/kkg = 6,038,550 kg COD/yr

It is recommended that noncontinuous discharging  mills with  annual  average mass
limitations track their mass discharged throughout the year by a cumulative total ("running
balance") of the mass of each pollutant discharged.   By  closely monitoring the mass

                                       15-16

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                                       15.0 Best Available Technology Economically Achievable
discharged during each day of the discharge period and updating the total annual discharge
to date, mills with potential compliance problems will be aware of the situation with
adequate time to take remedial action.  Remedial action might include wastewater flow
reduction, process modification, and improvement to treatment system performance.

Annual average effluent limitations must be applied to noncontiguous dischargers.  Daily
maximum and monthly average limitations may be applied also, and can be calculated by
using the  effluent limitations  guidelines  for  continuous  dischargers, and  adjusting the
production appropriately. Production is adjusted using the equation:
                             PRODADJ = NPDES   '
                                                                             (3)
where:
      PROD
            ADJ
      NPDES
                   =     Adjusted production rate for the purpose of calculating daily
                         and monthly permit limitations for noncontinuous dischargers,
                         kkg/day

                   =     NPDES production calculated using Equation 1 or 2 in Section
                         15.4.4.1, kkg/day

      T!           =     Length of time over which wastewater discharged is produced

      T2           =     Length of time over which wastewater is discharged.

In this example, wastewater from twelve months of production is discharged over a nine-
month period.  The NPDES productions are the same as calculated in Example 1 in Section
15.4.4.1:

      NPDES production for AOX limitations:  822 kkg/day
      NPDES production for COD limitations:  810 kkg/day

These productions are adjusted using Equation 3:

      822 kkg/day x (12 months / 9 months)  = 1,096 kkg/day
      810 kkg/day x (12 months / 9 months)  = 1,080 kkg/day
                                      15-17

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                                      15.0 Best Available Technology Economically Achievable
The daily maximum and monthly average BAT effluent limitations guidelines for AOX and
COD are:

AOX
COD
Maximum for Any One
Day (fcg/kkg)
0.267
35.7
Monthly Average (kg/fckg)
0.156
25.4
Daily maximum and monthly average permit limitations are calculated as follows.

Maximum AOX for any one day:

      0.267 kg/kkg x 1,096 kkg/day = 293 kg AOX/day

Monthly average AOX:

      0.156 kg/kkg x 1,096 kkg/day = 171 kg AOX/day

Maximum COD for any one day:

      35.7 kg/kkg x 1,080 kkg/day = 38,556 kg COD/day

Monthly Average COD:

      25.4 kg/kkg x 1,080 kkg/day = 27,432 kg COD/day

These mass limitations can be converted to a concentration basis, by dividing by the actual
average discharge flow during discharge periods:
                                   L  = k
                                   L    *
(4)
                                      15-18

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where:
      LM

      F
                                       15.0 Best Available Technology Economically Achievable
    concentration-based effluent limitation, mg/L

    unit conversion factor

    mass-based effluent limitation, kg/day

    actual average process wastewater discharge flow during discharge
    period, m3/day.
The example  mill  discharged an average of 100,000 m3/day (26.4  MGD) of process
wastewater during the nine months in 1993 in which discharge occurred.  The monthly
average AOX concentration limit is calculated using equation 4:
1,000,000 mg/kg    171 kg AOX/day =
  1,000 L/m
                                   100,000 m3/day
                                                   = m    /L
Concentration-based limitations for other parameters can be calculated similarly. Note that
since the flow term is in the denominator, the higher the mill's discharge flow, the lower the
equivalent concentration limitation becomes.  Therefore, it is in the mill's best interest to
practice water conservation and flow reduction, or dilution water segregation, and thereby
lower process water discharge flow rates.

15.4.4.3     ,Example3:  Linerboard Mill

An integrated kraft mill produced 379,500 OMMT (kkg) in 1993 of two-ply linerboard (high
yield unbleached kraft with a thin, bleached kraft top layer).   1993  was the highest
production year in the past five years.  Virgin softwood, pulped on site, is used to produce
the linerboard. By weight, 67 percent of the finished product is derived  from unbleached
pulp, while  33 percent, by weight, is  derived from bleached pulp.   Brown stock pulp
production was 395,025 ADMT in 1993.  Of this total, 125,235 tons were bleached and
269,790 were left unbleached. The pulp mill operated 345 days in 1993 and the bleach plant
operated 355 days.

Example calculations of BAT limitations for 2,3,7,8-TCDF and COD are shown below. The
BAT effluent limitations guidelines for these constituents (from Tables 15-2 and 15-6) are:
                                       15-19

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                                      15.0 Best Available Technology Economically Achievable
Subcategory
B - Bleached Papergrade
Kraft and Soda
C - Unbleached Kraft
Pollutant
2,3,7,8-TCDF
COD
2,3,7,8-TCDF
COD
Bleach Plant Effluent
Maximum for
One Day
359 ng/kkg
NA
NA
NA
Monthly
Average
NA
NA
NA
NA
Final Effluent ,
Maximum for
One Day
NA
35.7 kg/kkg
NA
40.2 kg/kkg
Monthly
Average
NA
25.4
kg/kkg
NA
24.6
kg/kkg
NA - Not applicable.
ND - Non-detect value.

The Subcategory B (Bleached Papergrade Kraft and Soda) NPDES production for COD is
calculated using Equation 1 from Example 1:

      125,235 kkg/yr / 345 days/yr = 363 kkg/day

The Subcategory B NPDES production for 2,3,7,8-TCDF is calculated using Equation 2 from
Example 1:

      125,235 kkg/yr / 355 days/yr = 353 kkg/day

The Subcategory C (Unbleached Kraft) NPDES production for COD is calculated using
Equation 1:

      269,790 kkg/yr / 345 days/yr = 782 kkg/day

NPDES permit limitations are calculated as follows:

Bleach Plant Effluent, Maximum for One Day:

2,3,7,8-TCDF:       359 ng/kkg x 353 kkg/day  =      126,727 ng 2,3,7,8-TCDF/day
                                                  0.127 mg 2,3,7,8-TCDF/day
                                      15-20

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                                        15.0  Best Available Technology Economically Achievable
Final Effluent:
COD:
      Maximum for One Day:

      35.7 kg/kkg x 363 kkg/day
      40.2 kg/kkg x 782 kkg/day
15.4.4.4
                                                   12,959
                                                   31.436

                                                   44,395 kg COD/day

                                                   44.4 kkg COD/day



                                                    9,220
                                                   19.237

                                                   28,457 kg COD/day

                                                   28.5 kkg COD/day
Example 4:  Alternative Effluent Limitations Guidelines Applicable to TCF
Bleaching Processes
      Monthly Average:

      25.4 kg/kkg x 363 kkg/day
      24.6 kg/kkg x 782 kkg/day
Example 4 is for the same mill described in Example 3, except that in this case the mill
bleaches with a totally chlorine-free process.  This mill could choose  to  comply with
alternative limitations applicable to wastewaters from TCF bleaching processes.  Once the
mill certifies to the permitting authority that the bleaching process is totally chlorine-free,
and demonstrates  through the specified number of sampling events that specific organic
pollutants (i.e., 2,3,7,8-TCDD, 2,3,7,8-TCDF, chloroform, methylene chloride, chlorinated
phenolic compounds) are not present, the alternative effluent limitations guidelines can
apply.  These alternative effluent limitations guidelines include limitations for AOX, COD,
and color only.  An example calculation of BAT limitations for AOX is shown below.
Unlike the previous example, there are no effluent limitations for 2,3,7,8-TCDF (or any
other specific chlorinated compound) under the alternative effluent limitations guidelines.
COD effluent limitations are the same as in Example 3.

Alternative BAT Limitations:

Bleach Plant Effluent:     Not applicable
                                       15-21

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                                       15.0 Best Available Technology Economically Achievable
Final Effluent:
1
1 AOX
Maximum for One Day
0.1 kg/kkg
Monthly Average ;
Not applicable
NPDES permit limitations are calculated as follows:



      Maximum, for One Day:



      0.1 kg/kkg x 353 kkg/day  =     35.3 kg AOX/day
                                       15-22

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        4)

        1
        IM
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I
!
       i
        S3
        4>
       H


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        3



       &
       ea
                   pa
                           X
                          fc

                               X
                               X
X
                                   X
X
                                       X
                                           X

                                               X
           X
                                                   X

                    X

                                                    15-23

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•s
 53
 B

1
 o
U
                   X
X
                          X
X
                              X
                                 X
              X
              X
                                        X
                                        X
                                           X
                    X
                                   15-24

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                                            Table 15-2

           Proposed BAT Effluent Limitations Guidelines for Subpart B
                         Papergrade Kraft and Soda Subcategory
Pollutant or Pollutant
Property
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform
Acetone
Methyl ethyl ketone
Methylene chloride
trichlorosyringol
3,4,5-trichJorocatechol
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
AOX
COD
Color
*
Continuous Dischargers
Bleach Plant Effluent
Maximum for
Any One Day
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                                      Table 15-3

  Proposed Alternative BAT Effluent Limitations Guidelines for Subpart B
                     Papergrade Kraft and  Soda Subcategory
            Applicable to Totally Chlorine-Free Bleaching Processes
Pollutant or Pollutant Property
AOX
COD
Color
jSnal Effluent
, VAkviS-h ,
•* ^ V
Continuous Dischargers
Maximum for Any
One Day (a)
0.1 kg/kkg
35.7kg/kkg
120 kg/kkg
Mtimiviy ' "" ;
Average(a)
NA
25.4 kg:/kkg
76.3 kg/kkg
Ken-Continuous
Dischargers
Annual
Average(a)
NA
21.3 kg/kkg
71.2 kg/kkg
(«)Ef fluent limitations guidelines are expressed in terms of mass of pollutant per kkg. For COD and color limitations, kkg refers to mass
 of unbleached pulp at 10 percent moisture; for all other limitations, kkg refers to mass of unbleached pulp that enters the bleach plant
 at 10 percent moisture.
NA - Not applicable.
                                          15-26

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                                             Table 15-4

          Proposed BAT Effluent  Limitations Guidelines for Subpart A
                                Dissolving Kraft Subcategory
Pollutant or Pollutant
Property
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform
Acetone
Methyl ethyl ketone
Methylene chloride
trichlorosyringol
3,4,5-trichlorocatechol
3,4,6-trichlorocatechol
3,4,5-trichloroguaiacol
3,4,6-trichloroguaiacoI
4,5,6-trichloroguaiacol
2,4,5-trichlorophenol
2,4,6-trichlorophenol
tetrachlorocatechol
tetrachloroguaiacol
2,3,4,6-tetrachlorophenol
pentachlorophenol
AOX
COD
Continuous Dischargers
Bleach Plant Effluent
Maximum for Any
O«e Dayfajj
300 ng/kkg
415 ng/kkg
10.1 g/kkg
35.1 g/kkg
1.89 g/kkg
ND
218 mg/kkg
5,690 mg/kkg
180 mg/kkg
2,230 mg/kkg
97.7 mg/kkg
400 mg/kkg
ND
2,180 mg/kkg
554 mg/kkg
134 mg/kkg
223 mg/kkg
ND
NA
NA
Monthly
Av«rag«(a)
NA
NA
7.06 g/kkg
17.2 g/kkg
1.04 g/kkg
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Final Effluent
Maximum for
Any One Day(a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.67 kg/kkg
118 kg/kkg
Monthly
A.verage{a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.650 kg/kkg
84.1 kg/kkg
Non»
Continuous
Dischargers
Final
Effluent
Annual
ArerageCa)
'NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0 .553 kg/kkg
70.3 kg/kkg
(a)Effluent limitations guidelines are expressed in terms of mass of pollutant per kkg. For COD limitations, kkg refers to mass of
  unbleached pulp at 10 percent moisture; for all other limitations, kkg refers to mass of unbleached pulp that enters the bleach plant
  at 10 percent moisture.
NA - Not applicable.
ND - Non-detect value.  A measurement reported below the minimum level that can be reliably measured by the analytical method for
    the pollutant. Analytical methods and minimum levels that apply are shown in Table 15-11.
                                                 15-27

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                                       Table 15-5

  Proposed Alternative BAT Effluent Limitations Guidelines for Subpart A
                            Dissolving Kraft Subcategory
            Applicable to Totally Chlorine-Free Bleaching Processes
Pollutant or Pollutant Property
AOX
COD
- Final Efflutnt
Continuous Dischargers
Maximum for Any
OnsJtey(a)
0.1 kg/kkg
118 kg/kkg
Monthly
Average(a)
NA
84.1 kg/kkg
Noa-ContiBttous
Dischargers
Annual
Average(a)
NA
70.3 kg/kkg
(a)Efflucnt limitations guidelines are expressed in terms of mass of pollutant per kkg. For COD limitations, kkg refers to mass of
  unbleached pulp at 10 percent moisture; for AOX limitations, kkg refers to mass of unbleached pulp that enters the bleach plant
  at 10 percent moisture.
NA - Not applicable.
                                           15-28

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                                    Table 15-6
        Proposed BAT Effluent Limitations Guidelines for Subpart C
                         Unbleached Kraft Subcategory
Pollutant Property
COD
Final Effluent
Continuous Dischargers
Maximum for Any
One Day(a)
40.2 kg/kkg
Monthly
Average^)
24.6 kg/kkg
Nott"
Continuous
Dischargers
Annual
Average(a)
20.8 kg/kkg
(a)Effluent limitations guidelines are expressed in terms of mass of pollutant per kkg. For COD limitations,
  kkg refers to mass of unbleached pulp at 10 percent moisture.
                                       15-29

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                                          Table 15-7

         Proposed BAT Effluent Limitations Guidelines for Subpart D
                              Dissolving Sulfite Subcategory


Pollutant or Pollutant
Property
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform
Acetone
Methyl ethyl ketone
Methylene chloride
trichlorosyringol
3,4,5-trienIorocatechol
3,4,6-trichlorocatechol
3,4,5-trichloroguaiacol
3,4,6-trichloroguaiacol
4,5,6-trichloroguaiacol
2,4,5-trichlorophenol
2,4,6-trichIorophenol
tetrachlorocatechol
tctrachloroguaiacol
2,3,4,6-tetrachlorophcnoI
pentachlorophenol
AOX
"' •?,*>'
* i l-K. S< JJ ' j
Continuous Dischargers
Bleach Plant Effluent
Maximum for Any
One I>ay(a)
ND
1,870 ng/kkg
232g/kkg
1,620 g/kkg
505 g/kkg
15.8 g/kkg
218 mg/kkg
ND
ND
ND
ND
ND
ND
1,500 mg/kkg
ND
881 mg/kkg
ND
ND
NA
Monthly
Averagefa)
NA
NA
74.4 g/kkg
688 g/kkg
167 g/kkg
4.77 g/kkg
NA
NA
NA
NA
. NA
NA
NA
NA
NA
NA
NA
NA
NA
Final Effluent
Maximum for Any
One»ay(a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
3.13 kg/kkg
Monthly
Av«jrage(«l
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.39 kg/kkg
Won*
Continuous
Dischargers i
Final
Effluent
Aujdiudl
AywsgeOa)
NA
NA ,
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.22 kg/kkg
(«)Efftuent limitations guidelines are expressed in terms of mass of pollutant per kkg. kkg refers to mass of unbleached pulp that enters
  the bleach plant at 10 percent moisture.
NA-Not Applicable.
ND - Non-detect value - a measurement reported below the minimum level that can be reliably measured by the analytical method for
     the pollutant. Analytical methods and minimum levels that apply are shown in Table 15-11.
                                               15-30

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                                     Table 15-8

  Proposed Alternative BAT Effluent Limitations Guidelines for Subpart D
                          Dissolving Sulfite Subcategory
            Applicable to Totally Chlorine-Free Bleaching Processes
Pollutant or Pollutant Property
AOX
fluid Effluent
Continuous Dischargers
Maximum for Any
One Day (a)
0.1 kg/kkg
Monthly
Average(aj
NA
Non-Continuous
Dischargers
Apmial
Average(a)
NA
(a)Effluent limitations guidelines are expressed in terms of mass of pollutant per kkg. For AOX limitations, kkg refers to mass of
 unbleached pulp that enters the bleach plant at 10 percent moisture.
NA - Not applicable.
                                         15-31

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                                   Table 15-9
        Proposed BAT Effluent Limitations Guidelines for Subpart E
                        Papergrade Sulfite Subcategory
Pollutant or Pollutant
Property
AOX
COD
Final Effluent
Continuous Dischargers
Maximum for Any
One Day{a)
0.1 kg/kkg
144 kg/kkg
Monthly
Average{a)
NA
71.2 kg/kkg
Non-
Continuous
Dischargers
Annual
Average(a)
NA
63.7 kg/kkg
                                   Table 15-10

        Proposed BAT Effluent Limitations Guidelines for Subpart F
                          Semi-Chemical Subcategory
Pollutant Property
COD
Final Effluent
Continuous Dischargers
Maximum for Any
One Day(a)
40.2 kg/kkg
Monthly
Average(a)
24.6 kg/kkg
Non-
Continuous
Dischargers
Annual
Average(a)
20.8 kg/kkg
(a)E£fluent limitations guidelines are expressed in terms of mass of pollutant per kkg. For COD limitations,
  kkg refers to mass of unbleached pulp at 10 percent moisture; for AOX limitations, kkg refers to mass of
  unbleached pulp that enters the bleach plant at 10 percent moisture.
NA - Not applicable.
                                       15-32

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                                               15-33

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                                                    15-34

-------
                                                   16.0 New Source Performance Standards
16.0  NEW SOURCE PERFORMANCE STANDARDS

16.1  Introduction

The basis for New Source Performance Standards (NSPS) under Section 306 of the Clean
Water Act (CWA) is the best available demonstrated technology.   Industry has  the
opportunity to  design and install the best  and most efficient pulping,  bleaching, and
papermaking processes  and wastewater treatment facilities at  new mills.  Accordingly,
Congress directed EPA  to consider the best demonstrated  alternative processes, process
changes, in-plant control measures, and end-of pipe wastewater treatment technologies that
reduce pollution to the maximum extent feasible.  In response to that directive, and as with
the development  of options for the proposed Best Available Technology Economically
Achievable (BAT) effluent limitations  guidelines, EPA considered effluent reductions
attainable by the  most advanced and demonstrated process  and treatment technologies at
pulp,  paper, and paperboard mills.  The Agency is proposing revised NSPS for all of the
revised subcategories set out in Section 5.
The National Pollutant Discharge Elimination System (NPDES) permit regulations define
the term "new source" at 40 CFR §§122.2 and 122.29. According to these regulations, to be
a "new source," a source must:

      (1)    Be constructed at a site at which no other source is located;

      (2)    Totally replace the process or production equipment that causes the discharge
             of pollutants at an existing source; or,

      (3)    Be a process substantially independent of an existing source at the same site,
             considering the extent of integration with the existing source and the extent
             to which the new facility is engaged in the same general type of activity as the
             existing source.

The application of these definitions has, at times, led to disagreements between NPDES
permitting authorities and those seeking permits and subsequent delays in the.permitting
process.  In order to  provide permit writers and the industry with more specific rules to
follow in determining new source status in the pulp, paper, and paperboard industry, the
Agency is proposing supplemental definitions of the  term "new source". Examples of new
sources located at existing pulp, paper, and paperboard mills are as follows:
                                        16-1

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                                                    16.0  New Source Performance Standards


      A.    At existing chemical pulp mills with bleaching operations (Subparts A, B, D,
             and E):  The construction, within any five-year period, of

             1.     a new pulping digester or pulping digester that completely replaces an
                    existing digester, in  combination with
             2.     a new bleaching facility or bleaching facility that completely replaces
                    an existing bleaching facility.

      B.    At existing chemical pulp mills without bleaching operations (Subparts C, F,
             and H):

             1.     ne,w pulping digester(s), or
             2.     new  pulping digester(s)  that totally  replaces  an existing pulping
                    digester(s).

      C.    At existing mechanical, secondary fiber and non-integrated mills (Subparts G,
             I, J, K, L):

             1.     a new paper or paperboard machine; or,
             2.     a new paper or paperboard machine that  totally replaces an existing
                    paper or paperboard machine.

The following are not examples of "new sources" within the pulp, paper, and paperboard
industry:

      •      Upgrades of existing pulping operations;

      •      Upgrading or replacement of pulp screening and washing operations;

      •      Installation  of  oxygen delignification  systems or other post-digester,  pre-
             bleaching delignification systems; and

      •      Bleach plant modifications  including changes in method or  amounts of
             chemical applications, new chemical applications, installation of new bleaching
             towers to facilitate  replacement of sodium  or  calcium  hypochlorite, and
             installation of new pulp washing systems.

As  described in Section 9.5, the general approach followed by the Agency for developing
New Source Performance Standards (NSPS) options for subcategories with proposed BAT
effluent limitations guidelines (Subparts  A, B, C, D, E, and F)  was, where  appropriate, to
evaluate the best demonstrated processes for  control  of  priority  and nonconventional
pollutants at the process level; and best demonstrated end-of-pipe treatment for  control of
conventional pollutants and  additional  control of certain  priority  and nonconventional

                                         16-2

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                                                   16.0 New Source Performance Standards
pollutants.  For subcategories where BAT effluent limitations guidelines  are not being
proposed, the Agency evaluation  was directed  at the best demonstrated conventional
pollutant control technology.

The Agency determined that the best demonstrated processes are those that result in the
minimuni generation of pollutants of concern  in this industry (i.e., the priority and
nonconventional pollutants proposed for regulation at BAT) that can be used to produce
the full range of products currently produced by existing facilities  in the subcategory.  The
Agency does not intend to select NSPS that would prevent manufacture of certain products.
The Agency determined  that the best  demonstrated conventional pollutant  control
technologies are those that result in the minimum discharges of conventional pollutants as
generally represented by the performance of the best existing mill in each subcategory.

Pollutants proposed for regulation at NSPS are the same as the priority and nonconventional
pollutants proposed for regulation at BAT, and the conventional pollutants biological oxygen
demand (BOD5) and total suspended solids (TSS).  For Subparts A, B, and D, the Agency
is  also proposing alternative NSPS applicable at the end-of-pipe effluent for adsorbable
organic halides (AOX) based upon totally chlorine-free (TCF) bleaching technologies.
These alternative standards would apply to  new sources constructed and operated in a TCF
bleaching mode.  There would be no NSPS applicable to bleach  plant effluents for these
mills.

The proposed NSPS set out in tables at the end of this section are based upon the long-term
average performance values for the selected NSPS options and monthly average and daily
maximum variability factors set out in the Statistical Support Document. Reference is made
to the Statistical Support Document for derivation of the variability factors.  The long-term
average performance values for each option are presented in Section 9.5.

In developing and selecting NSPS options and the proposed NSPS, the Agency considered
factors: the demonstration status of the process and wastewater treatment technologies, the
cost of achieving the effluent reductions,  non-water  quality environmental impacts, and
energy requirements.

The owners or  operators of facilities subject to NSPS  are not required to use the specific
process technologies and wastewater treatment technologies selected by EPA to establish
the NSPS, but may  choose to use any combination of process technologies and wastewater
treatment to comply with NPDES permit effluent limitations derived from  the NSPS.

This section presents the Agency's selection of NSPS options and the proposed new source
performance standards for each subcategory.
                                        16-3

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                                                    16.0  New Source Performance Standards
16.2  Selection of NSPS Options

Reference is made to Section 9.5 for a summary of the NSPS options considered, long-term
average performance, and their demonstration status. Because many of the NSPS options
for subcategories where BAT effluent limitations guidelines are being proposed are based
upon the BAT options, reference is also made to Sections 9.4 and 15.

Pursuant to the statutory requirements of Section 306 of the CWA, the Agency has selected
the following options as the basis for the proposed new source performance standards for
each subcategory.

16.2.1 Subpart A - Dissolving Kraft Subcategory

The Agency selected NSPS Option 2 as the basis of the proposed NSPS for the Dissolving
Kraft Subcategory on the basis of transfer of technology from the  Papergrade Kraft
Subcategory. The major pulping, bleaching, and wastewater treatment components included
in this option are:  wood chip  size and thickness control;  use  of dioxin precursor-free
defoamers  and pitch  dispersants; effective brown stock washing; closed pulp  screening
operations; pulping liquor spill prevention and  control; oxygen delignification;  partial
(approximately 70 percent) substitution of chlorine dioxide  for chlorine; oxygen- and
peroxide-enhanced extraction in the bleach plant; use of chlorine  dioxide instead of
hypochlorite in bleach plant brightening stages; high shear mixing for addition of bleaching
chemicals in the first bleaching stage and for addition of oxygen in enhanced extraction; flow
minimization  (process  water  reuse and  recycle); and  best  demonstrated  end-of-pipe
secondary biological wastewater treatment.

The Agency believes  that the transfer of pulp bleaching technology from the  Bleached
Papergrade Kraft and Soda Subcategory is an appropriate basis for NSPS for dissolving kraft
mills. Those technologies are well demonstrated at several mills. The proposed NSPS for
the Dissolving Kraft  Subcategory are presented  in Table 16-1.   Table  16-2 presents
alternative NSPS that would apply to dissolving kraft mills that may use totally chlorine-free
(TCP) bleaching operations in the future.

Just prior to proposal of this regulation, the industry provided EPA with information to
support their contention that some  usage  of hypochlorite is necessary to produce certain
high purity dissolving kraft grades of pulp.  The Agency will evaluate that information and
make a determination whether, or to what extent, to modify NSPS options for the Dissolving
Kraft Subcategory.

16.2.2 Subpart B - Bleached Papergrade Kraft and Soda Subcategory

The Agency selected NSPS Option 2 as the basis for the proposed NSPS for the Bleached
Papergrade Kraft and Soda Subcategory. This option is  the  isame as BAT Option 5. The

                                        16-4

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                                                    16.0 New Source Performance Standards
major pulping, bleaching, and wastewater treatment components of this option are: wood
chip size and thickness control; use of dioxin precursor-free defoamers and pitch dispersants;
extended delignification; effective brown stock washing; closed pulp screening operations;
pulping liquor spill prevention and control; oxygen delignification; use of chlorine dioxide
instead of elemental chlorine for bleaching (100 percent substitution); oxygen- and peroxide-
enhanced extraction in the bleach plant; use of chlorine dioxide instead of hypochlorites in
brightening  stages; high shear mixing for addition of bleaching  chemicals in the  first
bleaching stage and for addition of oxygen in enhanced extraction; flow minimization; and
best demonstrated end-of-pipe secondary biological wastewater  treatment.

These  technologies have been installed at many existing kraft  mills and at two recently
constructed greenfield bleached kraft mills and thus are fully demonstrated for purposes of
the CWA. The Agency also determined that these technologies  can be used at new source
soda mills to achieve the proposed NSPS.

The Agency considered  whether  to select  Option  1 (extended  cooking  or oxygen
delignification with complete substitution of chlorine dioxide for  elemental chlorine) as the
basis for NSPS. EPA rejected this option because it does not provide, based upon available
data and best professional judgment, the most stringent pollutant reductions.

The Agency considered whether to select Option 3 (ozone bleaching) and Option 4 (TCP
bleaching) as the basis for the proposed NSPS, but decided that because these technologies
are currently not suitable for manufacture of softwood market grades of pulp, they could not
be  selected  as  NSPS at this time for the entire Bleached Papergrade Kraft and-Soda
Subcategory. At this writing, the Agency does not have sufficient data to fully characterize
process wastewaters and wastewater effluents for the Option 3 and 4 technologies.

The Agency also considered whether to propose NSPS using the Option 2 technologies for
market pulp grades, and alternate NSPS using the Option 3 and 4 technologies for pulps
produced within selected brightness ranges. That approach would require further division
of the Bleached Papergrade Kraft and Soda Subcategory into segments based upon product
specifications. The Agency did not select that alternative at this time because it does not
have sufficient data to  fully characterize the Option 3 and 4 technologies. The Agency is
seeking additional data to more fully characterize process wastewaters for Option 3 and 4
technologies. These NSPS alternatives will be reconsidered prior to promulgation.

The proposed NSPS for the Bleached Papergrade Kraft and Soda Subcategory are presented
in Table 16-3. Alternative NSPS that would apply to papergrade kraft and soda mills using
TCP bleaching operations are presented in Table 16-4.
                                        16-5

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                                                    16.0 Mew Source Performance Standards
16.2.3  Subpart C - Unbleached Kraft Subcategory

The proposed NSPS are based upon the single option developed by the Agency for the
Unbleached Kraft Subcategory.  The principal technologies that form the basis  of the
proposed NSPS include:  effective brown stock washing; closed screen room operations;
pulping liquor spill prevention and  control; flow minimization; and best demonstrated
secondary biological treatment. These technologies are fully demonstrated at existing kraft
pulp mills. The proposed NSPS for the Unbleached Kraft Subcategory are presented in
Table 16-5.

16.2.4  Subpart D - Dissolving Sulfite Subcategory

The Agency selected NSPS Option  1 as the basis for the proposed NSPS. The major
pulping, bleaching and wastewater treatment components of the selected option are: wood
chip size and thickness control; use of dioxin precursor-free defoamers and pitch dispersants; i
effective brown s.tock washing; closed pulp screening operations;  pulping liquor  spill
prevention and control; oxygen delignification; use of chlorine dioxide instead of chlorine
in the  first bleaching stage (100 percent substitution); use of hypochlorite in subsequent
bleaching stages; high shear mixing for the addition of chlorine dioxide in the first bleaching
stage;  flow minimization;  and  best  demonstrated end-of-pipe  secondary  biological
wastewater treatment.

These  technologies are fully demonstrated and used for production of the full range of
dissolving sulfite pulps manufactured  in the  United States.   The  Agency  considered
proposing NSPS on  the  basis of  Option 2  (TCP bleaching),  but currently available
information and data indicate this technology is not suitable for manufacture of the full
range of dissolving pulps produced in the United States at this time. EPA is still considering
TCP bleaching  for certain products in this  subcategory.  The proposed  NSPS  for the
Dissolving Sulfite Subcategory are presented in Table 16-6. Table 16-7 presents alternative
NSPS that would apply to  dissolving sulfite mills that may use TCP bleaching operations in
the future.

16.2.5  Subpart E - Papergrade Sulfite Subcategory

The Agency selected NSPS Optipn 2 as the basis of the proposed NSPS for the Papergrade
Sulfite Subcategory.  The  major pulping, bleaching and wastewater treatment components
of this option are:  wood chip size  and thickness control; use of dioxin  precursor-free
defoamers and pitch dispersants; closed pulp screening operations;  effective brown stock
washing; pulping liquor spill prevention and control; oxygen delignification; totally chlorine-
free bleaching; flo,w minimization; and effective end-of-pipe secondary biological wastewater
treatment with extended residence tune secondary clarification.
                                        16-6

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                                                   16.0 New Source Performance Standards
The pulping technologies are fully demonstrated at chemical pulp mills located in the
United States.  Totally chlorine-free bleaching of sulfite pulps is fully demonstrated at a
number of papergrade sulfite mills located in Europe. The Agency has concluded that the
full range of papergrade sulfite grades manufactured in the United States can be produced
using TCP bleaching processes. The wastewater treatment technologies, including extended
residence time secondary clarification, are fully demonstrated at  a U.S. mill.
                     i
The proposed NSPS are presented in Table 16-8.  In addition to the  effluent limitations
guidelines presented on Table 16-8, the owner or operator of the facility must certify, in the
NPDES permit application, that chlorine or chlorine-containing compounds are not used for
pulp bleaching. In addition, the owner or operator of the facility must provide, as part of
the NPDES  permit application,  monitoring results for  three  composite bleach plant
wastewater samples for CDDs/CDFs and chlorinated phenolics, and three grab samples for
chloroform and methylene chloride.  Such samples shall be obtained at approximately
weekly intervals.  Because the proposed NSPS are based upon TCP bleaching technology,
there are no proposed alternative NSPS.

16.2.6 Subpart F  - Semi-Chemical  Subcategory

The proposed NSPS for the Semi-Chemical Subcategory are based upon the single NSPS
option developed by the Agency. The major process and wastewater treatment technologies
that comprise this option are: effective brown stock washing; pulping liquor spill prevention
and control; flow minimization; and best demonstrated end-of-pipe secondary biological
wastewater treatment.  These technologies  are fully demonstrated in  the industry in the
United States and can be used to achieve the proposed NSPS presented in Table 16-9.

16.2.7 Subpart G - Mechanical Pulp Subcategory
      Subpart H - Non-Wood Chemical Pulp Subcategory
      Subpart I - Secondary Fiber - Deink Subcategory
      Subpart K - Fine and Lightweight Papers from Purchased Pulp Subcategory
      Subpart L - Tissue, Filter, Non-Woven,  and Paperboard from Purchased Pulp
      Subcategory

The Agency selected the single NSPS  option  developed for each  of the above-listed
subcategories as the basis for the respective proposed NSPS. The proposed NSPS are for
BOD5 and TSS.  The technologies considered as the basis of the NSPS include flow
minimization and best demonstrated secondary biological treatment. These technologies are
fully demonstrated in each subcategory because the bases for the respective proposed NSPS
are demonstrated performance of the best performing mill in  each  subcategory.  The
proposed NSPS for continuous dischargers are presented in Table 16-10, the standards for
non-continuous dischargers are presented in Table 16-11.
                                       16-7

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                                                  16.0 New Source Performance Standards
162.8 Subpart J - Secondaiy Fiber Non-Deink Subcategory

As noted in Section 9.5, the Agency divided the Secondary Fiber Non-Deink Subcategory
into the following segments:

      Segment 1
             Paperboard, Builders' Paper and Roofing Felt Segment

      Segment 2
             Producers of Other Products from Non-Deink Secondary Fiber Segment

The Agency is proposing "zero discharge of process waste-waters" as the NSPS for Segment 1.
The  major components of this  option include in-mill water reuse and recycle; primary
treatment; and complete reuse of the primary treatment effluent. As noted in Section 9.5.9,
this technology is-fully demonstrated at 21 mills located in the United States that produce
paperboard from secondary fiber and builders' paper and roofing felt.  For Segment 2, the
Agency is  proposing NSPS  on the basis of the single option developed.  The  major
technologies  include flow  minimization and best demonstrated secondary biological
treatment.  The proposed NSPS.are presented in Table 16-10,
                                       16-8

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                                              Table 16-1

           Proposed New Source Performance Standards for Subpart A
                                 Dissolving Kraft Subcategory
t
Pollutant or Pollutant
Property
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform
Acetone
Methyl ethyl ketone
Methylene chloride
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-tetraehlorophenol
pentachlorophenol
BODj
TSS
AOX
COD
Continuous Dischargers
Bleach Plant Effluent
Maximum for
Any One
Bay£a) '
300 ng/kkg
415 ng/kkg
10.1 g/kkg
35.1 g/kkg
1.89 g/kkg
ND
218 mg/kkg
5,690 mg/kkg
180 mg/kkg
2,230 mg/kkg
97.7 mg/kkg
400 mg/kkg
ND
2,180 mg/kkg
554 mg/kkg
134 mg/kkg
223 mg/kkg
ND
NA
NA
NA
NA
Monthly
Averag$(a)
NA
NA
7.06 g/kkg
17.2 g/kkg
1.04 g/kkg
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Final Effluent
Maximum for
Any One
Day(a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
8.21 kg/kkg
17.0 kg/kkg
1.67 kg/kkg
118 kg/kkg
Monthly
Average(a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
4.90 kg/kkg
6.84 kg/kkg
0.650 kg/kkg
84.1 kg/kkg
Non-
Contmuous
Dischargers
Final Effluent
Annual
Average(a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
3.51 kg/kkg
4.85 kg/kkg
0.553 kg/kkg
70.3 kg/kkg
(a)Standards are expressed in terms of mass of pollutant per kkg.  For BOD3 and TSS standards, kkg refers to off-the-machine mass of
  final product at off-the-machine moisture for paper and paperboard and 10 percent moisture for market pulp; for COD standards,
  kkg refers to mass of unbleached pulp at 10 percent moisture; for all other standards, kkg refers to mass of unbleached pulp that enters
  the bleach plant at 10 percent moisture.
NA - Not applicable.
ND - Non-detect value. A measurement reported below the minimum level that can be reliably measured by the analytical method for
    the pollutant. Analytical methods and minimum levels that apply are shown in Table 15-11.
                                                  16-9

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                                        Table 16-2

  Proposed  Alternative New Source Performance Standards for Subpart A
                             Dissolving Kraft Subcategory
            Applicable to Totally Chlorine-Free Bleaching Processes
Pollutant or Pollutant Property
BOD,
TSS
AOX
COD
Final Effluent
Continuous Dischargers
Maximum for Any
One Day(a)
8.21 kg/kkg
17.0 kg/kkg
0.1 kg/kkg
118 kg/kkg
Monthly
Average(a)
4.90 kg/kkg
6.84 kg/kkg
NA-
84.1 kg/kkg
Non-Continuous
Dischargers
Annual
Average(a)
3.51 kg/kkg
4.85 kg/kkg
NA
70.3 kg/kkg
(a)S!4mdards are expressed in terms of mass of pollutant per kkg. For BOD3 and TSS standards, kkg refers to off-the-machine mass of
  final product at off-the-machine moisture for paper and paperboard and 10 percent moisture for market pulp; for COD standards,
  kkg refers to mass of unbleached pulp at 10 percent moisture; for AOX standards, kkg refers to mass of unbleached pulp that enters
  the bleach plant at 10 percent moisture.
NA - Not applicable.
                                             16-10

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                                           Table 16-3

          Proposed New Source Performance Standards for Subpart  B
                 Bleached Papergrade  Kraft  and  Soda Subcategory
Pollutant or Pollutant
Property
2,3,7,8-TCDD
2,3,7,8-TCDF
Acetone
Methylene chloride
trichlorosyringol
3,4,5-trichlorocatechol
3,4,6-trichlorocatechol
3,4,5-trichloroguaiacoI
3,4,6-trichloroguaiacol
2,4,5-trichlorophenol
2,4,6-trichlorophenol
tetrachlorocatechol
tetrachloroguaiacol
2,3,4,6-tetrachlorophenol
pentachlorophenol
BODj
TSS
Continuous Dischargers
Bleach Plaat Effluent
Maximum for Any
One Day (a)
ND
329 ng/kkg
12.0 g/kkg
ND
218 mg/kkg
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
NA
Monthly
Average(a)
NA
NA
6.09 g/kkg
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Final Effluent
Maximum for
Any One Day{a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.726 kg/kkg
0.988 kg/kkg
Monthly
Average(a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.365 kg/kkg
0.383 kg/kkg
Non-
Conthiuoiis
Dischargers
Final Effluent
Annual
Average(a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.262 kg/kkg
0.241 kg/kkg
(a)Standards are expressed in terms of mass of pollutant per kkg.  For BOD3 and TSS standards, kkg refers to off-the-machine mass of
  final product at off-the-machine moisture for paper and paperboard and 10 percent moisture for market pulp; for all other standards,
  kkg refers to mass of unbleached pulp that enters the bleach plant at 10 percent moisture.
NA - Not applicable.
ND - Non-detect value. A measurement reported below the minimum level that can be reliably measured by the analytical method for
    the pollutant. Analytical methods and minimum levels that apply are shown in Table 15-11.
                                               16-11

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                                       Table 16-4

   Proposed Alternative New Source Performance Standards for Subpart B
               Bleached Papergrade Kraft and Soda Subcategory
            Applicable to Totally Chlorine-Free Bleaching Processes
Pollutant or Pollutant Property
BOD,
TSS
AOX
Final Effluent
Continuous Dischargers
Maximum for Any
Qae Day(a)
0.726 kg/kkg
0.988 kg/kkg
0.1 kg/kkg
Monthly
Averagefal
0.365 kg/kkg
0.383 kg/kkg
NA
Non-Continuous
Dischargers
Annual
Average(a)
0.262 kg/kkg
0.241 kg/kkg
NA
(a)Standards arc expressed in terms of mass of pollutant per kkg. For BOD3 and TSS standards, kkg refers to off-the-machine mass of
  final product at off-the-machine moisture for paper and paperboard and 10 percent moisture for market pulp; for AOX standards,
  kkg refers to mass of unbleached pulp that enters the bleach plant at 10 percent moisture.
NA - Not applicable.
                                          16-12

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                                     Table  16-5

         Proposed New Source Performance Standards for Subpart C
                          Unbleached Kraft Subcategory
Pollutant Property
BOD5
TSS
COD
Final Effluent
Continuous Dischargers
Maximum for Any
One Day
0.236 kg/kkg
0.685 kg/kkg
20.8 kg/kkg
(a)Standards are expressed in terms of mass of pollutant per kkg. For BOD5 and TSS standards, kkg refers to
  off-the-machine mass of final product at off-the-machine moisture for paper and paperboard and 10 percent
  moisture for market pulp; for COD standards, kkg refers to mass of unbleached pulp at 10 percent moisture.
                                        16-13

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                                            Table 16-6

          Proposed New Source Performance Standards for Subpart D
                               Dissolving Sulfite Subcategory
Pollutant or Pollutant
Property
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform
Acetone
Methyl ethyl ketonc
Methylene chloride
triehlorosyringol
3,4,5-trichlorocatechol
3,4,6-trichlorocatechol
3,4,5-trichloroguaiacol
3,4,6-trichloroguaiacol
4,5,6-trichloroguaiacol
2,4,5-triehlorophenol
2,4,6-trichlorophcnoI
tctrachlorocatcchol
tctrachloroguaiacol
2,3,4,6-tetrachIorophenol
pcntachlorophcnol
BODj
TSS
AOX
Continuous Dischargers
Bleach Plant Effluent
Maximum for Any
OneDayCa)
ND
1,870 ng/kkg
232 g/kkg
1,620 g/kkg
505 g/kkg
15.8 g/kkg
218mg/kkg
ND
ND
ND
ND
ND
ND
1,500 mg/kkg
ND
881 mg/kkg
ND
ND
NA
NA
NA
Monthly
AveMge(a)
NA
NA
74.4 g/kkg
688 g/kkg
167 g/kkg
4.77 g/kkg
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Final Effluent
Maximum for Any
One Bay(a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA.'
NA.
NA
NA
NA
NA
NA
NA
25.6 kg/kkg
23.3 kg/kkg
3.13 kg/kkg
Monthly
Awage(a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
14.1 kg/kkg
11.8 kg/kkg
1.39 kg/kkg
N0n*
Continuous
Dischargers
Final
Effluent
Monthly
Average(a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
' NA
11.7 kg/kkg
9.44 kg/kkg
1.22 kg/kkg
(a).Standards are expressed in terms of mass of pollutant per kkg. For BOD3 and TSS standards, kkg refers to off-the-machine mass of
  final product at off-the-machine moisture for paper and paperboard and 10 percent moisture for market pulp; for all other standards,
  kkg refers to mass of unbleached pulp that enters the bleach plant at 10 percent moisture.
NA - Not applicable.
 ND - Non-detcct value. A measurement reported below the minimum level that can be reliably measured by the analytical method for
     the pollutant. Analytical methods and minimum levels that apply are shown in Table 15-11.
                                                 16-14

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                                        Table 16-7

  Proposed Alternative New Source Performance Standards  for Subpart  D
                            Dissolving Sulfite Subcategory
            Applicable to Totally Chlorine-Free Bleaching Processes
J
Pollutant or Pollutant Property
BOD3
TSS
AOX
final Effluent
Continuous Dischargers
Maximum for Any
One Day (a)
25.6 kg/kkg
23.3 kg/kkg
0.1 kg/kkg
Monthly
Average(a)
14.1 kg/kkg
11.8 kg/kkg
NA
Non-Continuous
Dischargers
Monthly
Average(a)
11.7 kg/kkg
9.44 kg/kkg
NA
(a)Standards are expressed in terms of mass of pollutant per kkg. For BOD3 and TSS standards, kkg refers to off-the-machine mass of
  final product at off-the-machine moisture for paper and paperboard and 10 percent moisture for market pulp; for AOX standards, kkg
  refers to mass of unbleached pulp that enters the bleach plant at 10 percent moisture.
NA - Not applicable.
                                           16-15

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                                    Table 16-8
        Proposed New Source Performance Standards for Subpart E
                        Papergrade Sulfite Subcategory
t
Pollutant or Pollutant
Property
BOD5
TSS
AOX
COD
Final Effluent
Continuous Dischargers
Maximum for Any
One Day(a)
4.90 kg/kkg
7.81 kg/kkg
0.1 kg/kkg
144 kg/kkg
Monthly
AverageCa)
2.57 kg/kkg
3.22 kg/kkg
NA
71.2 kg/kkg
Non-Continuous
Dischargers
Annual
Average(a)
1.98 kg/kkg
2.42 kg/kkg
NA
63.7 kg/kkg
                                    Table 16-9

         Proposed New Source Performance Standards for Subpart F
                           Semi-Chemical Subcategory
Pollutant Properly
BODj
TSS
COD
Final Effluent
Continuous Dischargers
Maximum for Any
One Day(a)
' 1.06 kg/kkg
2.14 kg/kkg
40.2 kg/kkg
Monthly
Average(a)
0.509 kg/kkg
0.826 kg/kkg
24.6 kg/kkg
Non-Continuous
Dischargers
Annual
Average(a)
0.409 kg/kkg
0.548 kg/kkg
20.8 kg/kkg
(a)Standards are expressed in terms of mass of pollutant per kkg. For BOD5 and TSS standards, kkg refers to
  off-the-machine mass of final product at off-the-machine moisture for paper and paperboard and 10 percent
  moisture for market pulp; for COD standards, kkg refers to mass of unbleached pulp at 10 percent moisture;
  for AOX standards, kkg refers to mass of unbleached pulp that enters the bleach plant at 10 percent moisture.

NA - Not applicable.
                                        16-16

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                                Table 16-10

             Proposed New Source Performance Standards for
                 Subpart G - Mechanical Pulp Subcategory
            Subpart H - Non-Wood Chemical Pulp Subcategory
              Subpart  I - Secondary Fiber - Deink Subcategory
           Subpart J - Secondary Fiber - Non-Deink Subcategory
      Subpart K - Fine and Lightweight Papers from Purchased Pulp
          Subpart L - Tissue, Filter, Non-Woven, and Paperboard
                            from Purchased Pulp
                          Continuous Dischargers
Subcategory
Mechanical Pulp
Non-Wood Chemical Pulp
Secondary Fiber - Deink
Secondary Fiber - Non-Deink
Paperboard, Builders'
Paper and Roofing Felt
Segment
Producers of Other
Products from Non-
Deink Secondary Fiber
Segment
Fine and Lightweight Papers
from Purchased Pulp
Tissue, Filter, Non- Woven,
and Paperboard from
Purchased Pulp
Final Effluent
BODS
Maximum for
Any One
Day(a)
0.480 kg/kkg
3.71 kg/kkg
3.35 kg/kkg
0(b)
1.42 kg/kkg
2.37 kg/kkg
0.982 kg/kkg
Monthly
Average(a)
0.208 kg/kkg
1.97 kg/kkg
1.21 kg/kkg
0(b)
0.568 kg/kkg
0.922 kg/kkg
0.363 kg/kkg
TSS
Maximum for
Any One
Day(a)
1.62 kg/kkg
5.44 kg/kkg
4.58 kg/kkg
0(b)
2.02 kg/kkg
2.16 kg/kkg
0.563 kg/kkg
Monthly
Average(a)
0.598 kg/kkg
2.52 kg/kkg
1.38 kg/kkg
0(b)
0.719 kg/kkg
0.921 kg/kkg
0.221 kg/kkg
(a)Standards are expressed in terms of mass of pollutant per kkg. For BOD5 and TSS standards, kkg refers to
  off-the-machine mass of final product at off-the-machine moisture for paper and paperboard and 10 percent
  moisture for market pulp.

(b)No new source within this segment of this subpart shall discharge wastewater to any waters of the United
  States.
                                    16-17

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                                Table 16-11

             Proposed New Source Performance Standards for
                 Subpart G - Mechanical Pulp Subcategory
            Subpart H - Non-Wood Chemical Pulp Subcategory
             Subpart I - Secondary Fiber - Deink Subcategory
           Subpart J - Secondary Fiber - Non-Deink Subcategory
      Subpart K - Fine and Lightweight Papers from Purchased Pulp
          Subpart L -  Tissue, Filter, Non-Woven, arid Paperboard
                           from Purchased Pulp
                        Non-Continuous  Dischargers
Subcategory
Mechanical Pulp
Non-Wood Chemical Pulp
Secondary Fiber - Deink
Secondary Fiber - Non-Deink
Paperboard, Builders'
Paper and Roofing Felt
Segment
Producers of Other
Products from Non-
Deink Secondary Fiber
Segment
Fine and Lightweight Papers
from Purchased Pulp
Tissue, Filter, Non-Woven,
and Paperboard from
Purchased Pulp
Final Effluent
BODj
Annual
Average(a)
0.155 kg/kkg
1.59 kg/kkg
0.888 kg/kkg
0(b)
0.386 kg/kkg
0.641 kg/kkg
0.248 kg/kkg
TSS
Annual
Average(a)
0.455 kg/kkg
2.03 kg/kkg
0.920 kg/kkg
0(b)
0.485 kg/kkg
0.724 kg/kkg
0.175 kg/kkg
(a)Standards are expressed in terms of mass of pollutant per kkg. For BOD5 and TSS standards,, kkg refers to
  off-the-machine mass of final product at off-the-machine moisture for paper and paperboard and 10 percent
  moisture for market pulp.

(b)No new source within this segment of this subpart shall discharge wastewater to any waters of the United
  States.
                                    16-18

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                                            17.0 Pretreatment Standards for Existing Sources
17.0  PRETREATMENT STANDARDS FOR EXISTING SOURCES

17.1  Introduction

Section 307(b) of the Clean Water Act (CWA) requires EPA to promulgate pretreatment
standards  for existing sources (PSES), which must be achieved within three years of
promulgation. PSES are designed to prevent the discharge of pollutants which pass through,
interfere with, or are otherwise incompatible with the operation of publicly owned treatment
works (POTWs). The CWA requires pretreatment for pollutants that pass through POTWs
in amounts that would exceed direct discharge effluent limitations or limit POTW sludge
management alternatives, including the beneficial use of sludges  on agricultural lands.
Pretreatment standards are to be technology-based and analogous to the best available
technology economically achievable (BAT) for removal of priority and nonconventional
pollutants.  Reference is made to the general pretreatment regulations (40 CFR Part 403),
which served as the framework for the proposed pretreatment  standards for the pulp, paper,
and paperboard industry.

Pretreatment standards for existing sources  apply to all existing mills in the Bleached
Papergrade  Kraft and Soda, Unbleached Kraft, Papergrade Sulfite,  and Semi-Chemical
Subcategories that discharge process wastewater to POTWs. There are a total of 13 indirect
discharging mills and associated POTWs in these four subcategories, as follows:  nine mills
in the Bleached Papergrade Kraft and Soda Subcategory; one  mill in the Papergrade Sulfite
Subcategory; two mills  in the Unbleached Kraft Subcategory;  and  one mill in the Semi-
Chemical Subcategory.  The Agency is individually identifying the 13 associated POTWs to
facilitate comment on  these proposed PSES.  The 13 POTWs are Gulf Coast  Waste
Disposal Authority, Pasadena, Texas; Muskegon County Wastewater Management System,
Muskegon, Michigan; Upper Potomac River Commission, Westernport,  Maryland; City of
St. Helens, St. Helens, Oregon; Jackson County Port Authority, Pascagoula, Mississippi;
Western Lake Superior Sanitary District, Duluth, Minnesota; Bay County Waste Treatment
Plant No.  1, Panama  City, Florida;  Erie City Wastewater  Treatment Facility, Erie,
Pennsylvania; City of Port St. Joe Wastewater  Treatment  Plant, Port St. Joe, Florida;
Peshtigo Joint Wastewater Treatment Facility, Peshtigo, Wisconsin; Hopewell Regional
Wastewater Treatment Facility, Hopewell,  Virginia;  Macon-Bibb County  Water and
Sewerage Authority, Macon Georgia; and Water Pollution Control Plant, Plattsburgh, New
York.

To determine whether pollutants indirectly discharged by mills in this industry pass through
POTWs, EPA reviewed sampling data for direct dischargers, performance data for POTWs,
and technical literature.  Based  on preliminary  review of circumstances at some of the
POTWs receiving pulp and paper mill effluent, and EPA's best professional judgment, EPA
concludes  that  biological  treatment systems  at  these POTWs,  while designed to
accommodate pulp and paper wastewaters, are not designed to the same  standards as those

                                       17-1

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                                             17.0 Pretreatnient Standards for Existing Sources
installed and operated at direct discharging mills.  Activated sludge systems and aerated
stabilization basin systems, as designed and operated at direct  discharging mills, typically
include substantially longer detention times and other features that in combination achieve
greater removals of biological oxygen demand (BOD5) and total suspended solids (TSS) than
are achieved at POTWs receiving effluent from these mills. This is evidenced by the fact
that the Best  Practicable  Control Technology  Currently Available  (BPT)  and  Best
Conventional Pollutant Control Technology (BCT) effluent limitations EPA is proposing for
certain subcategories are substantially more stringent than the secondary treatment effluent
limitations  applied to most POTWs (30 mg/L each of BOD5 and TSS).  Therefore, the
Agency concludes that BOD5 and TSS pass through these POTWs.  The Agency is not
proposing PSES standards for conventional pollutants, but has solicited comment on whether
these pollutants should be controlled.

In addition, the Agency concluded that other pollutants, including adsorbable organic halides
(AOX), chemical oxygen demand (COD), and (for the Bleached Papergrade Kraft and Soda
Subcategory only) color, also pass through POTWs.  In part, this is because these pollutants
typically  are  less biodegradable than the  conventional pollutant parameters (BOD5 and
TSS).  For  example, biological treatment systems at direct discharging pulp  and paper mills
(for which  EPA has data) remove approximately 40 percent of the influent AOX, which is
representative of  chlorinated organic compounds.   The literature indicates that the
biodegradability of certain  chlorinated organic compounds varies in comparison to AOX,
but generally these compounds are less biodegradable  than nonchlorinated biodegradable
organic matter measured as BOD5.  The Agency does not have detailed analytical data from
POTWs for these and other poUutants of concern in this industry to serve  as the basis for
a detailed,  quantitative pass-through analysis.  However, in view of the lower removal of
conventional poUutants achieved at POTWs in comparison to the removals being proposed
for direct dischargers in this industry, the Agency concludes that AOX, COD, and color (for
the Bleached Papergrade Kraft  and Soda Subcategory) also pass through these  POTWs.

Because  EPA believes that dioxins and furans,  and certain  other pollutants, cannot
practicably or feasibly be controlled with limits at the point of discharge to the POTW, EPA
is proposing PSES limits for those poUutants at the end of the bleach plant. The Agency's
sampling data show that dioxins and furans can only  be effectively removed by process
changes.  Dioxins  and furans are known to become associated with suspended solids in
process wastewaters. Internal stream pretreatment technologies (e.g., ultrafiltration) and
end-of-pipe treatment technologies (e.g., chemical precipitation and clarification, filtration)
are not capable of removing sufficient quantities of total suspended solids (TSS) to achieve
the same bleach plant or end-of-pipe dioxin and furan concentrations (i.e., below detection
limits) as achieved through process changes. Therefore, without process changes and bleach
plant limits, dioxins and furans would pass through POTWs. Moreover, removal of dioxins
and furans  from wastewaters using only end-of-pipe treatment would substantially increase,,
rather than decrease, the dioxin and furan concentrations in wastewater treatment system

                                        17-2

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                                              17.0 Pretreatment Standards for Existing Sources
sludges, thereby further limiting POTWs sludge disposal alternatives.  Similarly, volatile
organic compounds, such  as  chloroform (which is a hazardous  air pollutant), will be
liberated  from process wastewaters to the  atmosphere in collection, conveyance, and
aeration systems, and  thus are best removed in bleach plants through process changes.
These circumstances lead to pass-through and unacceptable non-water quality environmental
impacts on sludges and air emissions.  Moreover, certain of the volatile organics  are
hazardous air pollutants subject to  control under  the Clean  Air Act in this integrated
rulemaking. Because it is neither practical nor feasible to set limits for some pollutants at
the point  of discharge to the POTW sewer, EPA is proposing to set PSES limits for those
pollutants inside the mill, at the bleach plant, in a similar fashion as proposed in revising
BAT limits for the direct discharging mills.

For the Bleached Papergrade  Kraft  and Soda Subcategory, the Agency is also proposing
alternative PSES applicable at  the mill discharge to the POTW for AOX based upon totally
chlorine free (TCP) bleaching technologies.  These alternative PSES would apply to existing
sources that may operate in a  TCP bleaching mode.  There would be no PSES applicable
to bleach  plant effluents for these mills.

The proposed PSES presented in tables at the end of this section are based upon the long-
term average performance values for the selected PSES options and monthly average and
daily maximum variability factors set out in the Statistical Support Document.  Reference
is made to the Statistical Support Document for derivation of the variability factors. The
long-term average performance values  for each option are presented in Section 9.4.

In developing  and selecting PSES options and the proposed PSES, the Agency considered
the following factors:

      •      The manufacturing processes used  in the pulp,  paper, and paperboard
             industry;

      •      The age and size of the equipment and facilities involved;

      •     The location of the manufacturing facilities;

      •     Process changes;

      •     The engineering aspects of the application of pretreatment technology and its
            relationship to the POTW;
                                        17-3

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                                             17.0 Pretreatment Standards for Existing Sources
      •      The cost of application of technology in relation to the effluent reduction and
             other benefits achieved from such application; and
                                                               i
      •      Non-water quality environmental impacts (including energy requirements).

The owners or operators of facilities  subject to PSES are not required to use the specific
process technologies and wastewater  treatment technologies selected by EPA to establish
the PSES, but may choose to use any combination of process technologies and wastewater
treatment to comply with pretreatment standards derived from the PSES.

This section presents the Agency's selection of PSES options and the proposed pretreatment
standards for existing sources for each subcategory.

113,  Selection of PSES Options

Reference is made to Section 9.6 for a summary of the PSES options considered. Because
the PSES options being proposed are based upon the BAT options, reference is  also made
to Sections 9.4 and 15.

Pursuant  to the statutory requirements  of Section 307(b) of the  CWA, the Agency  has
selected the following  options as the basis for the proposed pretreatment  standards for
existing sources:

17.2.1 Subpart A - Dissolving Kraft Subcategory

PSES are reserved.

17.2.2 Subpart B - Bleached Papergrade Kraft and Soda Subcategory

The selected PSES option for the Papergrade Kraft and Soda Subcategory is the same as
BAT Option 4. The major pulping, bleaching and wastewater treatment components of this
option are  wood  chip size  and thickness control; elimination of defoamers  and pitch
dispersants that contain dioxin precursors; extended delignification or oxygen delignification;
effective  brown stock washing; closed pulp screening operations; pulping liquor spill
prevention and control; use of chlorine dioxide instead of elemental chlorine for bleaching
(100 percent substitution); oxygen- and peroxide-enhanced extraction in the bleach plant;
use of chlorine dioxide instead of hypochlorite in brightening stages; high shear mixing; flow
reduction; and effective end-of-pipe secondary biological wastewater treatment.

The Agency selected this option as the basis for the proposed PSES for many of the same
reasons BAT Option 4 was selected (see Section 9.4.2 and Section 15), and because  this
option results in the maximum economically achievable effluent reduction benefits, and thus

                                        17-4

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                                              17.0  Pretreatment Standards for Existing Sources
will  result in maximum protection  of POTWs from interference and pass-through of
pollutants. These technologies are suitable for manufacture of all grades of papergrade
kraft and soda pulp.

The proposed PSES for the Bleached Papergrade Kraft and Soda Subcategory are presented
in Table 17-1. Alternative PSES that would apply to papergrade kraft and soda mills that
use TCP bleaching operations are presented in Table 17-2,

17.2.3  Subpart C - Unbleached Kraft Subcategory

The proposed PSES are based upon the single technology option developed by the Agency
for the Unbleached Kraft Subcategory.  The principal technologies that form the basis of
the proposed PSES include effective brown stock washing; closed pulp screening operations;
pulping liquor spill prevention  and control; flow  reduction; and  effective secondary
biological treatment. These technologies are fully demonstrated at existing kraft pulp mills.
The proposed PSES for the Unbleached Kraft Subcategory are presented in Table  17-3.

17.2.4  Subpart D - Dissolving Sulfite Subcategory

PSES are reserved.

17.2.5  Subpart E - Papergrade Sulfite  Subcategory

The selected PSES option for the Papergrade Sulfite Subcategory is  the same as BAT
Option 2.  The major pulping, bleaching and wastewater treatment components of this
option are adequate wood chip size and thickness control; elimination of defoamers and
pitch dispersants that contain dioxin precursors; closed pulp screening operations; effective
brown stock washing; pulping liquor spill prevention and control;  oxygen delignification;
totally chlorine-free bleaching; flow reduction; and effective end-of-pipe secondary biological.
wastewater treatment.

The pulping  technologies are fully demonstrated  at chemical pulp mills located  in the
United States.   Totally  chlorine-free bleaching  of papergrade  sulfite  pulps is fully
demonstrated at a number of papergrade sulfite mills located in Europe. The Agency has
concluded that the full range of papergrade sulfite grades manufactured in the United States
can be produced using TCP bleaching processes.  The wastewater treatment technologies
are fully demonstrated at a U.S. mill.

The proposed PSES are presented in Table 17-4. In addition to the pretreatment standards
presented on Table  17-4, the owner or operator  of the  facility must  certify, in the
pretreatment baseline monitoring report, that chlorine or chlorine-containing compounds
are not used  for pulp bleaching.  In addition, the  owner or operator of the facility must

                                        17-5

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                                            17.0 Pretreatment Standards for Existing Sources
provide, as part of the pretreatment baseline monitoring report, monitoring results for three
composite bleach plant wastewater samples for CDDs/CDFs and chlorinated phenolics, and
three grab samples for chloroform and methylene chloride. Such samples shall be obtained
at approximately weekly intervals.   Because the proposed PSES are based upon TCP
bleaching technology, there are no proposed alternative PSES.

17.2.6 Subpart F - Semi-Chemical Subcategoiy

The proposed PSES for  the Semi-Chemical Subcategory are  based upon  the  single,
technology option developed by the Agency.  The major process and wastewater treatment
technologies that comprise this option are effective brown stock washing; pulping liquor spill
prevention and control; flow reduction; and  effective end-of-pipe secondary biological
wastewater treatment.  These technologies are fully demonstrated in the industry in the
United States and can be used to achieve the proposed PSES  presented in Table 17-5.

17.2.7 Subpart G - Mechanical Pulp Subcategory
      Subpart H - Non-Wood Chemical Pulp Subcategory
      Subpart I - Secondary Fiber - Deink Subcategoiy
      Subpart J -  Secondary Fiber - Non-Deink Subcategoiy
      Subpart K - Fine and Lightweight Papers from Purchased Pulp Subcategory
      Subpart L - Tissue, Filter, Non-Woven,  and Paperboard from Purchased Pulp
      Subcategory

The Agency does not have adequate information and  data at  this time to determine that
PSES to control priority and nonconventional pollutants from existing mills in the above
subcategories is warranted.  However, the  Agency may consider the need for effluent
limitations and standards after further review as part of its CWA Section 304(m) planning
process. Accordingly, the Agency is proposing to reserve PSES for these subcategories. The
need for PSES will be considered at a future date.

EPA solicits comments on whether the Agency should develop PSES limits for conventional
pollutants in subcategories other than the four  in which the  Agency is proposing PSES
limits.   The conventional  pollutant limitations for direct dischargers proposed in all
subcategories of the pulp and paper industry are  more stringent than EPA's secondary
treatment requirements for POTWs. Therefore, the conventional pollutants discharged from
pulp and paper mills would pass through POTWs. The Agency has identified 19 mills and
associated POTWs  in the following subcategories: Mechanical Pulp; Deink Secondary
Fibers; Non-Deink Secondary Fibers; Fine and Lightweight Papers  from Purchased Pulp;
and Tissue, Filter, Non-Woven, and Paperboard  from Purchased Pulp.
                                       17-6

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                                           Table 17-1

    Proposed Pretreatment Standards  for Existing Sources for  Subpart B
                       Papergrade Kraft and Soda Subcategory
Pollutant or Pollutant
Property
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform
Acetone
Methyl ethyl ketone
Methylene chloride
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
AOX
COD
Color
Continuous Dischargers
Bleach Plant Effluent
Maximum for
Any One Day(a)
ND
359 ng/kkg
5.06 g/kkg
43.0 g/kkg
3.81 g/kkg
1.33 g/kkg
218 mg/kkg
ND
ND
ND
ND
ND
ND
78.6 mg/kkg
ND
ND
ND ,
ND
NA
NA
NA
Monthly
Average(a)
NA
NA
2.01 g/kkg
21.9 g/kkg
1.75 g/kkg
0.518 g/kkg
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Discharge to the POTW
Maximum for
Any One Day(a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.267 kg/kkg
35.7 kg/kkg
120 kg/kkg
Monthly
Average(a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.156 kg/kkg
25.4 kg/kkg
76.3 kg/kkg
Non-Continuous
Dischargers
Discharge to the
POTW
Annual
Average(a)
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
' NA
NA
NA
NA
0.143 kg/kkg
21.3 kg/kkg
71.2 kg/kkg
(a)Standards are expressed in terms of mass of pollutant per kkg.  For COD and color standards, kkg refers to mass of unbleached pulp
  at 10 percent moisture; for all other standards, kkg refers to mass of unbleached pulp that enters the bleach plant at 10 percent moisture.
NA - Not applicable.
ND - Non-detect value. A measurement reported below the minimum level that can be reliably measured by the analytical method for
     the pollutant. Analytical methods and minimum levels that apply are shown in Table 15-11.
                                               17-7

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                                      Table 17-2

      Proposed Alternative Pretreatment Standards for Existing Sources
                                    for Subpart B
                    Papergrade Kraft and Soda Subcategory
            Applicable to Totally Chlorine-Free Bleaching Processes
Pollutant or Pollutant Property
AOX
COD
Color
Discharge to the POTW
Continuous Dischargers
Maximum for Any
One Diy(a)
0.1 kg/kkg
35.7 kg/kkg
120 kg/kkg
Monthly
A"verage(a)
NA.
25.4 kg/kkg
76.3 kg/kkg
Non-Continuous
Dischargers
Annual
Average(a)
NA
21.3 kg/kkg
71.2 kg/kkg
(a)Stand»rds are expressed in terms of mass of pollutant per kkg. For COD and color standards, kkg refers to mass of unbleached pulp
 at 10 percent moisture;, for AOX standards, kkg refers to mass of unbleached pulp that enters the bleach plant at 10 percent moisture.
NA • Not applicable.
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                                   Table 17-3

   Proposed Pretreatment Standards  for Existing Sources for Subpart C
                        Unbleached Kraft Subcategory
Pollutant Property
COD
Discharge to the POTW
Continuous Dischargers
Maximum for Any
One Day{a)
40.2 kg/kkg
Monthly
Average(a)
24.6 kg/kkg
Nan-Continuous
Dischargers
Annual
Average(a)
20.8 kg/kkg
(a)Standards are expressed in terms of mass of pollutant per kkg. For COD standards, kkg refers to mass of
  unbleached pulp at 10 percent moisture.
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                                   Table 17-4
   Proposed Pretreatment Standards for Existing Sources for Subpart E
                        Papergrade Sulfite Subcategory
Pollutant or Pollutant
Property
AOX
COD
Discharge to the PQTW
Continuous Dischargers
Maximum for Any
One Day(a)
0.1 kg/kkg
144 kg/kkg
Monthly
Averag,e(a)
NA
71.2 kg/kkg
Non-Continuous
Dischargers
Annual
Average{a)
NA
63.7 kg/kkg
                                   Table 17-5

    Proposed Pretreatment Standards  for Existing Sources for Subpart F
                          Semi-Chemical Subcategory
Pollutant Property
COD
Discharge to the POTW
Continuous Dischargers
Maximum for Any
One Day(a)
40.2 kg/kkg
Monthly
Average(a)
24.6 kg/kkg
Non-Continuous
Dischargers
Annual
Average(a)
20.8 kg/kkg
(a)Standards are expreSvSed in terms of mass of pollutant per kkg. For COD standards, kkg refers to mass of
  unbleached pulp at 10 percent moisture; for AOX standards, kkg refers ito mass of unbleached pulp that enters
  the bleach plant at 10 percent moisture.
NA - Not applicable.
                                      17-10

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                                               18.0 Pretreatment Standards for New Sources
18.0  PRETREATMENT STANDARDS FOR NEW SOURCES

The basis for Pretreatment Standards for New Sources (PSNS) under Sections 306 and
307(c)  of the Clean Water Act (CWA) is the best available demonstrated technology.
Industry  has the opportunity  to design and  install the best and most efficient pulping,
bleaching, and papermaking processes and wastewater treatment facilities  at new mills.
Accordingly, Congress directed EPA to consider the best demonstrated alternative processes,
process  changes, in-plant  control measures,  and  end-of  pipe wastewater treatment
technologies that reduce pollution to the maximum  extent feasible.  In response to that
directive, and as with the development of options for the proposed Best  Available
Technology Economically Achievable (BAT) effluent limitations guidelines and New Source
Performance Standards (NSPS), EPA considered effluent reductions attainable by the most
advanced and demonstrated process  technologies at pulp, paper, and paperboard mills
located in the United States and foreign countries, and the best demonstrated wastewater
treatment for the pulp, paper  and paperboard mills located in the United States.

Section 307(c) of the CWA requires  EPA to promulgate PSNS simultaneously with the
promulgation of NSPS.  PSNS are designed to prevent  the discharge of pollutants which pass
through,  interfere with, or are  otherwise incompatible with the operation of publicly owned
treatment works (POTWs).  The CWA requires pretreatment for pollutants that pass
through POTWs  in amounts that would exceed direct  discharge effluent limitations or limit
POTW sludge  management  alternatives,  including the beneficial use of sludges on
agricultural lands. Pretreatment standards for new sources (see Section 16.0 for a discussion
of the definition  of new source) are to be technology-based and analogous to the NSPS for
removal  of priority and nonconventional pollutants.  Reference is  made to the general
pretreatment regulations (40 CFR Part 403),  which  served as the framework for  the
proposed pretreatment standards for the pulp, paper, and paperboard industry.

The Agency determined that certain priority and nonconventional pollutants and process
materials that can be present in untreated wastewaters from chemical and semi-chemical
pulp and paper mills can pass through POTWs, may limit POTW sludge disposal alternatives
and can interfere with biological treatment in POTWs  (see Section 17.0). Therefore, the
Agency is proposing PSNS for the six revised chemical and semi-chemical subcategories set
out in Section 5:
             Dissolving Kraft;
             Bleached Papergrade Kraft and Soda;
             Unbleached Kraft;
             Dissolving Sulfite;
             Papergrade Sulfite; and
             Semi-Chemical.
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                                               18.0 Pretreatment Standards for New Sources
Pollutants proposed for regulation at PSNS  are the same as those proposed for NSPS,
except PSNS does not control conventional pollutants. PSNS apply to both the bleach plant
effluent and mill discharge to the POTW.   Reference is made to the preamble to the
proposed regulation (Section IX.E.5.) and Section 17 for a review of the Agency's proposed
approach to regulating pulp, paper, and paperboard indirect discharges both at the bleach
plant effluent and at the discharge from the mill to the POTW.

The selected PSNS options are the same as the selected NSPS options for the Dissolving
Kraft,  Bleached  Papergrade Kraft  and  Soda, Unbleached  Kraft, Dissolving Sulfite,
Papergrade Sulfite, and Semi-Chemical  Subcategories.

In developing and selecting PSNS  options and the proposed PSNS, the Agency considered
factors:  the demonstration status of the process and wastewater treatment technologies, the
cost of achieving the effluent reductions, non-water quality environmental impacts, and
energy requirements.

The owners or operators of facilities subject to PSNS are not required to use the specific
process technologies and wastewater treatment technologies selected by EPA to establish
the PSNS, but may choose to use any combination of process technologies and wastewater
treatment to comply with permit limitations derived from the PSNS.

The Agency is proposing to reserve PSNS for the following subcategories: Mechanical Pulp;
Non-Wood Chemical Pulp; Secondary Fiber - Deink; Secondary Fiber - Non-Deink; Fine
and  Lightweight  Papers from  Purchased Pulp;  and Tissue,  Filter,  Non-Woven and
Paperboard from Purchased Pulp.
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                                                         19.0 Best Management Practices
19.0  BEST MANAGEMENT PRACTICES
19.1  Introduction

In addition to  pollutant-specific effluent  limitations guidelines  and standards, EPA is
proposing Best Management Practices (BMP) pursuant to Section 304(e) of the Clean Water
Act (CWA) for pulping liquor management, spill prevention and control.  BMP would be
applicable to chemical pulp mills, namely the following subcategories:

             Dissolving Kraft;
             Bleached Papergrade Kraft and Soda;
             Unbleached Kraft;
             Dissolving Sulfite;
             Papergrade Sulfite;
             SemiTChemical; and
             Non-Wood Chemical Pulp.

The principal focus of BMP is prevention and control of losses of pulping liquors from spills,
equipment leaks, and intentional liquor diversions from the pulping and chemical recovery
processes.

EPA has emphasized control of pulping liquor losses from  chemical pulp mills for the
following reasons:

      (1)    Losses of pulping liquor contribute significant portions  of the  untreated
             wastewater loadings  and discharge loadings of  color, oxygen demanding
             substances, and non-chlorinated toxic compounds from chemical pulp mills.
             EPA is not proposing to regulate these non-chlorinated toxic compounds with
             compound-specific effluent limitations and standards as part of Best Available
             Technology Economically Achievable  (BAT), New Source Performance
             Standards  (NSPS), Pretreatment Standards for Existing Sources (PSES) or
             Pretreatment Standards for New Sources (PSNS);

      (2)    Pulping liquor spills and intentional liquor diversions are a principal cause of
             upsets and loss of efficiency of biological wastewater treatment systems that
             are nearly universally used for treatment of chemical pulp mill wastewaters;

      (3)    Prevention and control of pulping liquor  losses  is a form of pollution
             prevention that will result  in less demand for pulping liquor make-up
             chemicals; improved process and energy efficiency through recovery of fiber
             and liquor solids; more effective and less costly wastewater treatment system
             operations; and reduced formation  of wastewater treatment sludges; and,

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                                                         19.0 Best Management Practices
      (4)    Control of pulping liquor losses will result in reduced atmospheric emissions
             of Total Reduced Sulfur (TRS) from kraft mills and volatile hazardous air
             pollutants (HAPs) from all chemical pulp mills.

EPA has prepared a separate technical support document for the proposed BMP that may
be found in the Record for the Rulemaking (1).  That document sets out EPA's findings
with respect to pulping liquor loss control from pulping and chemical recovery operations
and presents proposed  BMP for chemical pulp mills.  This section presents a summary of
parts of the BMP Technical Support Document and an overview of the proposed regulation.

19.2  Legal Authority

EPA's legal authority for establishing BMP as part of the effluent limitations guidelines and
standards for industrial categories is found at  Section 304(e) of the CWA.

The proposed BMP are directed at preventing and controlling spills, leaks, and intentional
diversions of pulping liquors associated with the various chemical pulping processes, for the
express purpose of minimizing the  discharge of conventional pollutants total suspended
solids  (TSS),  biological  oxygen demand (BOD5),  a priority pollutant (phenol), a
nonconventional pollutant chemical oxygen demand  (COD), and other non-chlorinated,
nonconventional toxic pollutants (e.g., resins and fatty acids) associated with the pulping
liquors.  Through improved wastewater treatment effectiveness, BMP should also result in
improved removals of priority and nonconventional pollutants from chemical pulp mills.

19.3  Toxicity of Pulping Liquors

The toxicity of wood pulping liquors has been well documented through  studies conducted
over many years (2,3,4,5).  The BMP Technical Support Document presents summaries of
several studies. The results show that in addition to hydrogen sulfide and methyl mercaptan,
crude sulfate soap and  sodium salts of fatty and resins acids, all components of kraft black
liquor are among the more toxic compounds to Daphnia and freshwater minnows. Minimum
lethal concentrations in the low ppm levels were found for these compounds. Toxic impacts
in the aquatic environment of compounds associated with kraft pulping liquors have also
been reported (6,7).

In recent studies of in-mill toxicity at a northern Ontario (Canada) bleached kraft mill, the
pulp mill sewer was found to contribute 55 percent of the  effluent toxic loading, while the
combined condensate and (bleach plant) acid sewer contributed 25 percent and 20 percent,
respectively (8). Of the eight recommendations to reduce effluent toxicity, the first two, and
five in all, were Directed at reducing the amount of black liquor lost from the processes.
Improved black liquor  spill control was cited as the highest priority project.
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                                                           19.0  Best Management Practices
Other recent studies conducted by the National Water Research Institute, Canada Centre
for Inland Waters suggest wastewater discharges from kraft mills that do not bleach and
modernized bleached kraft mills produce sub-lethal toxic effects in fish populations in
receiving streams (9).  In one study of a kraft mill with modern bleaching processes (e.g.,
chlorine dioxide substitution, oxygen delignification), secondary treatment, and low AOX
discharges (less than 1.5 kg AOX/ADMT pulp), physiological changes were evident in white
sucker (Catostomus commersonf) collected downstream of the mill discharge (10).  This
study, and others, suggest that fish responses are attributable to the discharge of biologically
active compounds derived from black liquor.

Sulfite pulping liquors also exhibit toxicity to aquatic organisms, with ammonium-based
liquors the most toxic and sodium-based liquors the least toxic (11).

19.4  Sources of Pulping Liquor Losses

19.4.1 Kraft and Soda Mills

Losses of black liquor from kraft and soda pulping and chemical recovery processes arise
from routine process operations including maintenance practices, planned start-ups and
shutdowns, grade changes, other intentional liquor diversions, and losses from screen rooms,
brown stock washers, and deckers.  Unintentional losses result from nonroutine occurrences
such as fiber and liquor spills, equipment leaks, tank overfillings, and process upsets. These
types of losses contribute  a significant portion of the total  untreated BOD5 wastewater
loading at both unbleached and bleached kraft mills, as summarized below.

Intermittent Uncontrolled
Losses
Decker Filtrate
— — — — — ^^^^— — i 	
Sewered Contaminated
Condensates
Bleach Plant Effluent
Total
Unbleached Kraft
33 - 50%
33%
17 - 34%
0
100%
Bleached Kraft
25 - 38%
25%
12 - 25%
25%
100%
Source:  (12).

For purposes of the proposed BMP regulation, liquor losses from brown stock washing (i.e.,
residual liquor  remaining in  the brown stock  pulp after washing)  are  not  considered.
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                                                          19.0 Best Management Practices
 Minimization of brown stock washing losses is an important aspect of process optimization
 and a pollution prevention technique, particularly at bleached kraft mills where increased
 formation of chlorinated organics and higher sewer loadings of COD, adsorbable organic
 halides (AOX), and BOD5 have been attributed to poor brown stock washing. Such losses
 are not considered part of black liquor management, spill prevention and control. Improved
 brown stock washing is included as an integral part of each model BAT, NSPS, PSES, and
 PSNS process technology train considered by EPA.

 Based upon on-site evaluations conducted at several kraft mills and one soda mill, the
 following were identified as significant sources of black liquor losses from routine process
 operations:

       1.     Decker losses at older mills with open screen rooms;

       2.     Losses from knotters and screens at mills with open screen rooms and without
             fiber and liquor recovery systems for those sources;

       3.     Sewered evaporator boil-out solutions;

       4.     Leaks from seals on brown stock washers;

       5.     Leaks from seals onrpumps and valves in black liquor service; and,
               i
       6.     Intentional liquor diversions during shutdowns, start-ups, grade changes, and
             during equipment maintenance.

 Process upsets, equipment breakdowns, tank overfillings,  and construction activities were
 identified as the most common sources of nonroutine,  unintentional black liquor  and
 causticizing  area sewer losses.   EPA expects that sources of pulping liquor losses at non-
wood chemical pulp mills are similar to those at kraft and soda mills because the pulping
processes are similar.

 Mills with more  effective pulping  liquor spill  prevention and  control programs  have
instituted specific engineered controls, preventative  maintenance programs, management
practices, and  monitoring systems to substantially eliminate black liquor losses from these
sources.

 19.4.2 Sulfite and Semi-Chemical Mills

Although sulfite and semi-chemical mills have pulping systems based upon different process
chemistry and different or limited chemical recovery facilities, pulping liquor losses from
normal  process operations and unintentional losses arise from many of the same types of

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                                                           19.0 Best Management Practices
sources as at kraft and soda mills.  Based upon site evaluations conducted at three sulfite
mills and a detailed review of spill prevention and control practices at a fourth sulfite mill,
EPA determined that sulfite mills are less likely than kraft or soda mills to have engineered
controls for collecting spills and leaks of pulping liquors at the immediate process areas.

19.5   Current Industry Practice - Pulping Liquor Spill Prevention and Control

19.5.1  Kraft and Soda Mills

Pulping liquor spill prevention and control practices were evaluated at several kraft mills,
four sulfite mills and one soda mill to assess current industry practice. Mills were selected
for evaluation based upon age, size, discharge status (direct  and indirect), and pulping
practice (kraft; soda; ammonium base, magnesium base, and calcium base sulfite). The age
of kraft and soda mills ranges from mills where wood pulping operations commenced at the
turn of the century to relatively new greenfield mills constructed in the mid- to late-1980s.
The age of sulfite mills ranged from about 70 to 90 years as characterized by first year of
pulp production.

Based upon findings from the mill visits and information provided by several mill operators,
EPA classified industry efforts at kraft pulping liquor spill prevention and control as either
proactive or reactive. The proactive programs are characterized by the following:

       •     Management of process operations to minimize variability to the maximum
             extent possible;

       •     Extensive preventative maintenance programs for equipment in pulping liqu or
             service;

       •     Automated spill detection and recovery systems in the pulping and recovery
             areas for collection and recovery of pulping liquor and fiber.  These systems
             are maintained and operated by pulping and recovery personnel;

       •     Secondary containment and high-level alarms on weak and strong pulping
             liquor tanks;
                      >
       •     Frequent  operator surveillance of equipment and tanks in pulping liquor
             service. Minor repairs are made immediately;

       •     Sufficient capacity (95,000 cubic meters to > 400,000 cubic meters; 250,000
             gallons  to  >  1,000,000 gallons) for storage of collected spills  and planned
             liquor diversions.  Most storage capacity is provided in covered tanks;
                                        19-5

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                                                          19.0 Best Management Practices
       •      Systems to recover fiber and liquor from knotting and screening operations;
             and,

       •      Secondary monitoring and diversion systems for major mill sewers  serving
             pulping, recovery, and recausticizing areas.

In the reactive programs, spill response is emphasized more heavily than spill prevention.
At  these mills, _ wastewater  treatment plant operators most often have  conductivity
monitoring systems to detect problems in major sewers and at the influent to the treatment
plant.   Typically, it is  then: responsibility to notify  pulping  and  chemical recovery
superintendents of detected problems. In these instances, the pulping and chemical recovery
areas generally do not have primary responsibility for spill detection and response.

Many  of the proactive  pulping  liquor management programs, engineered controls  and
monitoring systems observed at kraft and soda mills are consistent with those recommended
by the National Council of the Paper Industry for Air and Stream Improvement,  Inc.
(NCASI) in 1974  (13).   NCASI recommended approaches for spill containment for all
aspects of pulp and paper mill operations, sewer monitoring, and management programs.

Several mill operators reported that the key to successfully managing and preventing bladk
liquor losses is sufficient liquor storage capacity and  the  flexibility to  manage liquor
inventories and spills through transfers among liquor storage tanks. No operator reported
having excess liquor storage capacity.

19.5.2  Sulfite Mills

At the sulfite mills surveyed, pulping liquor spill prevention and control include many of the
same items as noted above for kraft and soda mills; however, none of the sulfite mills visited
had automated spill detection and recovery systems at the pulping and recovery areas. One
surveyed mill had a fiber and liquor recovery system at the brown stock washers.  Most did
not have full secondary containment for weak and strong pulping liquor tanks. High-level
alarms on liquor tanks appeared to be standard practice. All mills  were equipped with pH
and/or conductivity meters and alarms at strategic locations for identification of spills or
upsets. Some mills had diversion tanks or ponds for large pulping liquor diversions or spills.
Protection of the wastewater treatment facilities was a principal objective at these mills.
One mill not visited reported an extensive proactive pulping liquor spill prevention and
control program comprising all of the elements described above for kraft mills (12).  The
following techniques can be used to substantially minimize pulping liquor losses from most
sulfite mills (12,14):

       •      Management of process operations to minimize variability to the maximum
             extent possible;

                                        19-6

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                                                          19.0 Best Management Practices
      •      Extensive preventative maintenance programs for equipment in pulping liquor
             service;

      •      Automated spill detection and recovery systems in the pulping and recovery
             areas for collection and recovery of pulping liquor and fiber.  These systems
             are maintained and operated by pulping and recovery personnel;

      •      Secondary containment and high-level  alarms on pulping liquor and stock
             tanks;

      •      Flow recorders and continuous monitors and samplers on major process area
             sewers;

      •      Overflow from heavy to weak liquor tanks;

      •      Sufficient capacity (95,000 cubic meters to > 400,000 cubic meters; 250,000
             gallons to >  1,000,000 gallons) for storage of collected spills and planned
             liquor diversions.  Storage capacity should be provided in covered tanks; and

      •      Ability to return heavy liquor and compatible boil-out solutions to the weak
             liquor tanks instead of to the  sewer.

19.6  Regulatory Approach and Proposed Regulatory Provisions

EPA's approach for controlling losses of pulping liquor is to require, by regulation, that the
owner or operator of each  chemical and semi-chemical pulp mill develop and implement
Best Management Practices Plans (BMP Plans) for prevention and control of pulping liquor
losses, other than those losses associated with normal brown stock pulp washing. In many
respects, the proposed BMP Plans are similar  to  Spill Prevention Countermeasure and
Control (SPCC) Plans for oil spill prevention and control (40 CFR 112).  The principal
objective is to prevent losses and spills of pulping liquors from equipment items in pulping
liquor service; the secondary objectives are to contain, collect, and recover or otherwise
control those spills that do occur and  to minimize emissions of TRS and hazardous air
pollutants.  A goal for pulp  mill operators should be to ensure there are no visible leaks or
spills of pulping liquors.

The major elements of the  BMP Plan are as follows:

             •     Engineering Analyses,
             •     Engineered Controls and Containment,
             •    • Work Practices,
             •     Preventative Maintenance,
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                                                          19.0 Best Management Practices
             •     Dedicated Monitoring and Alarm Systems,
             •     Surveillance and Repair Programs, and
             •     Employee Awareness and Training.

EPA is proposing that the BMP Plans contain the following key elements:

      1.     A  detailed  engineering review of  the pulping  and  chemical recovery
             operations, including, but not limited to, process equipment, storage tanks,
             pipelines and pumping systems, loading and unloading facilities, and other
             appurtenant pulping and recovery equipment in pulping liquor service.  The
             purpose of the engineering review is to determine the magnitude and routing
             of potential leaks, spills, and intentional pulping liquor diversions during the
             following periods of operation:

                          Process start-ups and shutdowns,
                          Maintenance,
                          Grade changes,
                          Storm events,
                          Power failures, and
                          Normal operations.

             A detailed engineering review of existing pulping liquor containment facilities
             for  the  purpose of  determining whether there is adequate  capacity for
             collection and  storage  of anticipated  intentional  liquor  diversions with
             sufficient contingency for collection and containment of spills,  based upon
             good engineering practice. Secondary containment equivalent to the  volume
             of the largest tank plus sufficient freeboard for  precipitation should be
             provided for bulk storage tanks.

             The  engineering review must  also  consider:   (1) the need  for  process
             wastewater diversion facilities  to protect end-of-pipe wastewater treatment
             facilities from adverse effects of pulping liquor spills and diversions; (2) the
             potential for contamination of storm water from the immediate process areas
             (digesters, evaporators,  recovery boilers, recausticizing); (3) the  extent to
             which segregation  and  collection  of contaminated storm  water  from the
             process areas is  appropriate; and,  (4) the potential to reduce atmospheric.
             emissions of total reduced sulfur compounds and hazardous air pollutants.

             Development and  implementation of preventative  maintenance  practices,
             standard operating  procedures,  work practices, engineered controls,  and
             monitoring systems to prevent  liquor losses and to divert pulping liquors to
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                                                   19.0 Best Management Practices
      containment facilities such that the diverted or spilled liquors may be returned
      to the process or metered to the wastewater treatment system;

4.    A program of regular visual inspections (at least once per operating shift) of
      equipment in pulping  liquor service and a program  for repair of leaking
      equipment items.  The repair program must encompass immediate repairs
      when possible, and tagging for repair during the next maintenance outage
      those  leaking  equipment  items  that cannot  be  repaired  during  normal
      operations.  The owner or operator of the mill must also establish conditions
      under which  production will  be curtailed or halted to  repair  leaking
      equipment items or prevent liquor losses.  The repair program should include
      tracking repairs over  time to  identify that equipment where  upgrade or
      replacement may be warranted based upon frequency and severity of leaks or
      failures. The owner or operator shall maintain logs showing the date pulping
      liquor leaks were detected, the type of pulping liquor (e.g., weak black liquor,
      intermediate black liquor, strong black liquor), an estimate of the magnitude
      of the leak, the date of first attempt at repair, and the date of final repair.
      The logs shall be maintained at  the  mill for review by the Regional
      Administrator or his designee during normal working hours.

5.    A program of initial and refresher training  of operators, maintenance
      personnel,  and  other technical and  supervisory  personnel   who  have
      responsibility for operating, maintaining, or supervising the operation and
      maintenance of equipment and  systems in pulping  liquor service.   The
      refresher training must be conducted  annually.   The  training must be
      documented and records of training shall be maintained for review by the
      Regional Administrator or his designee during normal working hours.

6.    A program of "boards of review" to evaluate each spill and intentional liquor
      diversions not contained at the immediate process area. The boards of review
      should be conducted as soon as practicable after the  event, and should be
      attended  by  the involved  operators,  maintenance  personnel,   process
      engineering personnel,  and  representatives  of  mill  management  and
      environmental control staff. A brief report shall be prepared for each board
      of review.  The report  shall describe the circumstances leading the incident,
      corrective  actions taken,  and recommended  changes to  equipment or
      operating and maintenance practices to prevent recurrence.  A summary of
      the boards of review reports should be made  part of the annual refresher
      training.

7.    A program to review any planned modifications to the pulping and chemical
      recovery facilities and any construction activities in the pulping and chemical

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                                                          19.0 Best Management Practices
             recovery areas before these activities commence. The purpose of the reviews
             js to ensure that pulping liquor spill prevention and control is considered as
             part of the planned modifications, and that construction and supervisory
             personnel are aware of and take into account possible liquor diversions and
             the potential for causing liquor spills during construction.

      8.     An implementation schedule not to exceed thirty months from the  effective
             date  of  the  final regulations  for  construction  of any pulping  liquor
             containment or diversion facilities necessary to fully implement the BMP plan.
             A schedule not to  exceed eighteen months from the effective date of the final
             regulations for installation or upgrade of continuous, automatic monitoring
             systems, including, but not limited to, high-level monitors and  alarms on
             existing  storage tanks, process  area conductivity (or pH) monitoring and
             alarms, and process area sewer, process wastewater, and wastewater treatment
             plant conductivity (or pH) monitoring  and alarms.  Notwithstanding any
             construction activities, the owner or operator shall  begin  implementing all
             other aspects  of the BMP Plan not later than four months from the effective
             date of the final regulations.

      9.     The BMP Plan shall be reviewed and certified by a  Registered Professional
             Engineer  familiar with the  facility and the requirements of the  BMP.
             regulation. The Registered Professional Engineer shall attest that the BMP
             Plan has been prepared in accordance with the requirements of the regulation
             and good engineering practices.

      10.    The BMP Plan shall  be reviewed and updated as necessary at least every
             three years, or whenever  there are significant changes  to the pulping and
             chemical recovery facilities.

19.7  Estimated Costs and Effluent Reduction Benefits

19.7.1 Estimated Costs

The approach used by the Agency to estimate the cost for the affected subcategories of the
pulp, paper, and paperboard industry to  implement BMP is  described in Section 11.4. The
estimated capital costs and operating and maintenance costs or savings, by subcategory, are
summarized in Section 11.7.  These cost estimates were based upon cost data the Agency
obtained from two older bleached kraft pulp and paper mills where effective pulping liquor
spill prevention and control systems were recently installed.  Both mills had little or no black
liquor spill prevention and control prior to  completing the recent upgrades (see BMP
Technical Support Document for the reported costs).
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                                                          19.0 Best Management Practices
19.7.2  Estimated Effluent Reduction Benefits

The following effluent reduction benefits were realized at a southern U.S. kraft mill that has
recently installed pulping liquor spill prevention and control systems:

       •      Elimination of intermittent acute toxicity in the POTW effluent to C.daphnia
             and Pimephales promelas.  Eh'mination of intermittent chronic toxicity  to
             Pimephalespromelas and reduction of consistent chronic toxicity to C.daphnia;
             and,

       •      Reduced effluent flow and reduced discharges of TSS, COD, and BOD5.

Operators of a Canadian kraft mill that has also recently installed pulping liquor spill
prevention and control systems reported the effluent reduction benefits in Table 19-1, prior
to installation of  an aerated stabilization basin in 1989 (15).

Based upon these results, EPA believes that improved management of pulping liquors and
effective spill prevention and control can result in the following effluent reduction benefits:

       •      Reduced raw waste  loadings and reduced toxicity of raw waste loadings prior
             to biological treatment;

       •      Reduced toxicity in  biologically treated pulp mill effluents;

       •      Reduced effluent .discharges of flow and conventional and nonconventional
             pollutants, namely TSS, BOD5, and COD;
                     i
       •      Reduced potential  for  catastrophic spills of pulping  liquors directly  to
             waterways;

       •      Reduced potential for upsets  to wastewater treatment facilities from in-mill
             spills, and attendant increased discharges of unchlorinated  and chlorinated
             toxic compounds, effluent toxicity, and conventional  and nonconventional
             pollutants (TSS, BOD5, and COD).

Non-water quality environmental  impacts include:

       •      Reduced atmospheric emissions of volatile HAPs including methanol and
             methyl ethyl ketone, among others;
                                       19-11

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                                                         19.0  Best Management Practices
      •      For kraft mills,  reduced atmospheric  emissions  of odor-causing  TRS
             compounds comprising hydrogen sulfide, metlryl mercaptan, dimethyl sulfide,
             and dimethyl disulfide, among others;

      •      Energy recovery from combustion of black liquor solids that would otherwise
             be lost to the sewer.  Increased energy will be required if very dilute weak
             liquors are processed;'and,

      •      Improved process efficiency and operating cost savings including recovery of
             lost fiber, reduced need for make-up chemicals, and more efficient utilization
             of operating and supervisory personnel.

The estimated reductions in BOD5 loading that would result from the proposed BMP are
presented in Section 10.2 (see Section 11.6.5.2 for a discussion of how these estimated BOD5
reductions were accounted for in estimating the cost of the two BPT options).

19.8  References
1.     U.S.EPA. Technical Support Document for Proposed Best Management Practices
      Program: Pulping Liquor.  Management, Spill Prevention, and Control, November
      1993.

2,     The Toxicity of Kraft Pulping Wastes to Typical Fish Food Organisms.  Technical
      Bulletin  No. 10.   National Council of the  Paper Industry  for Air  and Stream
      Improvement, Inc., May 1947.

3.     A Study of the Toxic Components of the Waters of Five  Typical  Kraft Mills.
      Technical Bulletin No. 16 - Aquatic Biology. National Council of the Paper Industry
      for Air and Stream Improvement, Inc., April 1948.

4.     The Effects of Kraft Mill Waste liquors and Some of Their Components on Certain
      Salmonid Fishes  of the Pacific Northwest.  Technical Bulletin No. 51 - Aquatic
      Biology.  National Council of the Paper Industry for .Air and Stream Improvement,
      Inc., May 1952.

5.     McKee, I.E., and H.W. Wolf. Water Quality Criteria, Second Edition, Publicatiqn
      3-A.  The Resources Agency of California, State Water Resources Control Board.
      Sacramento, California, February  1963 (Reprint December 1971).
                                       19-12

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                                                        19.0 Best Management Practices
6.     Kleyhans, C.J., G.W. Schulz. J.S. Engelbrecht, and F.J. Rousseau. The Impact of a
      Paper Mill Effluent Spill on the Fish Populations of the Elands and Crocodile Rivers
      (Incomati System, Transvaal).  ISSN 0378-4738=Water SA, 18(2), April 1992.

7.     Fox, M.E. Dehydroabietic Acid Accumulation by Rainbow Trout (Salmo gairdneri)
      Exposed to Kraft Mill Effluent.  Journal of Great Lakes Research, 3 155-161,  1977.

8.     Scroggins, R.P.. In-Plant Toxicity Balances for a Bleached Kraft Pulp Mill.  Pulp &
      Paper Canada, 87(9): T344-348, September 1986.

9.     Personal Communication with John Carey, Rivers Research Branch,  National Water
      Research Institute, Canada Centre for Inland Waters, Burlington, Ontario, Canada,
      May 19, 1992.

10.   Servos,  M.,  et. al.   Impact of a Modern Bleached Kraft Mill on White Sucker
      Populations in the Spanish River, Ontario. April 22, 1991. Unpublished.

11.   Ingruber, ,O.V.,  M.J.  Kocurek, and A. Wong, eds.  Pulp  and Paper Manufacture
      (Third  Edition):   Volume 4  - Sulfite Science and Technology.   Joint Textbook
      Committee of the Paper Industry, TAPPI, Technology Park, Atlanta,  Georgia, and
      CPPA,  Montreal, Quebec, Canada, 1985.

12.   Springer, A.M. Industrial Environmental Control - Pulp and Paper Industry.  John
      Wiley and Sons, Inc., New York, New York,  1986.

13.   Spill Prevention and Control Aspects of Paper Industry Wastewater Management
      Programs. Technical Bulletin No. 276. National Council of the Paper Industry for
      Air and Stream  Improvement, Inc., August 1974.

14.   Personal Communication  with J. Floyd Byrd, Lawrenceburg,  Indiana, August 31,
       1992.

15.   Sikes, J.E.G. and S. Almost.  Black Liquor Spill Control at Terrace Bay. Pulp and
      Paper Canada, 87(12):T496-500, December 1986.
                                       19-13

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                                       Table 19-1

             Quantified Effluent Reduction Benefits from Kraft Mill
                    Black Liquor Spill Prevention and Control
Effluent
Characteristic
Flow, m3/ADMT(
BODi, kg/ADMT
TSS, kg/ADMT
Dissolved Solids, kg/ADMT
Sodium, kg Na-jSO^ADMT
Toxic Contribution, TU m3/ADMT
March
1992,
135
40
8.6
200
146
1,060
July
1985
106
29
5.3
145
108
335
Percent
Reduction
21%
27%
38%
27%
26%
68%
Source: (15).

Note:   TU - Toxic Units calculated as the reciprocal of the LC^ using static bioassays multiplied by 100. Toxic
       Units were converted to Toxic Contribution in m3/ADMT by multiplying the Toxic Units by the flow
       of the effluent and dividing by mill production. Bioassays were conducted using juvenile rainbow trout
       (Salmo gairdneri).
                                          19-14

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                                                     20.0 Acknowledgement and Disclaimer
20.0  ACKNOWLEDGEMENT AND DISCLAIMER

This report has 'been reviewed and  approved for publication by the  Engineering and
Analysis Division, Office of Science and Technology.  This report was prepared with the
support of Radian Corporation (Contract No. 68-CO-0032) under the direction and review
of the Office of Science and Technology. Neither the United States Government nor any
of its employees,  contractors, subcontractors, or their employees  make any  warrant,
expressed or implied, or assumes any legal liability or responsibility for any third party's use
of or the results of such use of any information, apparatus, product, or process discussed in
this report, or represents that its use by such party would not infringe on privately owned
rights.
                                        20-1

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                                                                         21.0 Glossary
21.0
GLOSSARY
104-Mill Study - Study of 104  chemical pulp mills with chlorine bleaching operations
conducted during 1988 and 1989 for the purpose of determining levels of 2,3,7,8-TCDD and
2,3,7,8-TCDF in bleached pulps, treated wastewater effluents and wastewater treatment
sludges.  The  study was conducted by the paper industry under direction by NCASI in
accordance with EPA-approved  protocols.  Also known as the U.S. EPA/Paper Industry
Cooperative Dioxin Study.

1990 Census - The 1990 National Census of Pulp, Paper, and Paperboard Manufacturing
Facilities.  A  questionnaire submitted by EPA to  all facilities  in the pulp, paper, and
paperboard industry in October  1990 to gather technical and financial information.  (Also
referred to in this document as the 1990  questionnaire).

Abaca - Plant (Musa textiles), related to the banana, used as a non-wood fiber furnish. Also
known as Manila hemp.

Acid filtrate - Process wastewater from the acid bleach plant stages,  (e.g., chlorine, chlorine
dioxide, or hypochlorite stages).

Active chlorine multiple (ACM)  - The ratio of total chlorine (from molecular chlorine and
chlorine dioxide) in the first  bleaching  stage (expressed as  percent of pulp) to Kappa
number of the pulp entering the first bleaching stage.
                  i
Administrator - The Administrator of the U.S. Environmental Protection Agency.

Agency - The U.S. Environmental Protection Agency.

Air dry pulp - Pulp with a moisture content of 10 percent by weight.

Alkaline extraction - The second stage in a pulp bleaching sequence where the first stage
is chlorination (in which chlorine and/or chlorine dioxide are added and allowed tcx react
with the pulp  slurry).  The resulting chlorinated fiber residuals and  other alkali-soluble
constituents are then dissolved in the  second or "alkaline" extraction stage; also, caustic
extraction stage, or "E"-stage.

Alkaline filtrate - Process wastewater from the pulp washing operations following alkaline
bleach plant stages. See also caustic filtrate.

Annual average - The mean concentration, mass loading or production normalized mass
loading of a pollutant over a period of 365 consecutive days (or such other period of time
determined  by the  permitting authority to be sufficiently' long to encompass expected

                                        21-1

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                                                                        21.0  Glossary
variability of the concentration, mass loading or production-normalized mass loading at the
relevant point of measurement).

Average monthly discharge limitation - The highest allowable average of "daily discharges"
over a calendar month, calculated as the sum of all "daily discharges" measured during the
calendar month  divided by the number of "daily discharges" measured during the month.

Backwashing - The operation of cleaning a rapid sand or mechanical filter by reversing the
flow of water or liquid that is being filtered.

Bagasse - Sugarcane residual from the manufacturing of sugar consisting  of crushed stalk
from which paper pulp can be made.

Batch digester - A pressurized cooking vessel in which predetermined, specific amounts of
wood and cooking liquor are heated so that the dissolving of the wood into pulp  is
completed and the pulp is removed before the cycle repeats, as opposed to a continuous
digester.

Batch system -  A pulp and paper manufacturing unit process  consisting of a series of
operating units which process pre-determined specific amounts of materials and carry the
process to completion before starting another cycle.

Black liquor - Spent pulping liquor from the digester prior to its incineration in the recovery
furnace of a sulfat'e (kraft) recovery process.  It contains dissolved organic wood substances
and residual active alkali compounds from the pulping process.

Bleach plant - All process equipment beginning with the first application of bleaching agents
(e.g., chlorine, chlorine dioxide, ozone, sodium or calcium hypochlorite,  peroxide), each
subsequent extraction stage, and each subsequent stage where bleaching agents are applied
to the pulp. A limited number of mills produce specialty grades of pulp  using hydrolysis or
extraction stages prior to the first application of bleaching agents. The bleach plant includes
those pulp pretreatment stages. Oxygen delignification prior to the application of bleaching
agents is not part of the bleach plant.

Bleach plant effluent - The total discharge of process wastewaters from the bleach plant
from each physical bleach line operated at the mill, comprising separate acid and alkaline
filtrates or the combination thereof.

Bleach sequence -  Sequence in which chemicals are used to bleach pulp.

Bleach tower - Usually tall, cylindrical retention vessel where pulp, mixed with the bleaching
agent, is retained the required time for the bleaching action to be completed in a continuous

                                        21-2

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                                                                        21.0 Glossary
system of pulp bleaching. An upflow-type is used when bleaching low consistency pulp, and
a downflow-type is used when bleaching medium and higher consistency pulp. Also referred
to as a bleaching tower.

Bleach washer - A filter (washer) located after a bleach tower in the bleaching sequence of
pulp where the pulp is washed free of the residual bleaching agent and the products of the
bleaching action.

Bleached pulp - Pulp that has been purified or whitened by chemical treatment to alter or
remove coloring matter and has taken on a higher brightness characteristic.

Bleaching - The process of further delignifying and whitening pulp by chemically treating
it to alter the coloring matter and to impart a higher brightness.

Bleaching agent - A variety of chemicals used in the bleaching of pulp such as chlorine (C12),
sodium hypochlorite (NaOCl), calcium hypochlorite (Ca(OCl)2), chlorine dioxide  (C1O2),'
peroxide (H2O2), • oxygen (O2),  ozone (O3), and others.   Also referred to as bleaching
chemical.

Bleaching stage - One  of the unit process operations in which  a bleaching chemical or
combination of chemicals is added in the sequence of a continuous system of bleaching pulp.

Boiler - Any enclosed combustion  device that extracts useful energy in the form of steam
and is not an incinerator.

Brightening - Chemical modification'of colored elements in high-yield pulps to render them
colorless without removing them. Also, the final chlorine dioxide (D) stages of a traditional
high-brightness kraft bleaching sequence (CEHDED).

Brightness - As commonly used in the paper industry, the reflectivity of a sheet of pulp,
paper, or paperboard for specified light measured under standardized conditions, relative
to a magnesium oxide standard.

Broke - Partly or  completely manufactured paper that does not leave the machine room as
salable paper or paperboard; also, paper damaged in finishing operations such as rewinding
rolls,  cutting and trimming.

Brown stock - Pulp, usually kraft sulfite  or groundwood, not yet bleached or treated other
than in the pulping process.
                                        21-3

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                                                                        21.0 Glossary
Caustic extraction - A stage in the pulp bleaching sequence (E) that normally follows the
chlorination stages to remove alkali-soluble, chlorinated lignins. (See alkaline extraction and
extraction stage)

Caustic filtrate - Process wastewater from the caustic bleach plant stages.  See also alkaline
filtrate.

Causticizing - Converting green liquor to white liquor by the use of slaked lime [Ca(OH)2]
which reacts with the sodium carbonate (NajCC^) in the green liquor to form active sodiunv
hydroxide (NaOH). Also called recausticizing.

Cellulose - The chief substance in the cell walls of plants used in pulp manufacturing. It is
the fibrous substance that remains after the nonfibrous portions, such as lignin and some
carbohydrates, are removed during the cooking and bleaching operations of a pulp mill.

Chemical pulp  - The mass of fibers resulting from the reduction of wood or other fibrous
raw material into its  component  parts during the cooking phases with various chemical
liquors, in such processes as sulfate, sulfite, soda, NSSC, etc.
                      '           i
Chemical recovery - The recovery of chemicals from spent pulping liquor after it is used to
cook wood in the digester.

Chipper - A piece of equipment in the woodyard/pulp mill area used to slice whole logs
into chips.  It consists of an enclosed,  rapidly revolving disk fitted with  surface-mounted
knives against which the logs are dropped in an  endwise direction in such a manner that
they are reduced to chips, diagonally to the grain.

Chlorination -  (1) The mixing and reacting of chlorine water or gas with pulp in the
bleaching operation.  (2) The application of chlorine to  mill water supply and sewage for
disinfection or oxidation of undesirable compounds.

Chlorination stage - The step in a multi-stage bleaching process ("C" stage) where chlorine
water  or gas is mixed,  allowed to react,  and then washed as  an initial operation in a
complete pulp bleaching system.
                i
Chlorinator - A device for adding a chlorine-containing gas  or liquor to mill wastewater.
Sometimes the  term is also used to refer to the chlorine mixer in the bleach plant.
Chlorine - A greenish-yellow, poisonous, gaseous chemical element
pulp and water purification in a pulp and paper mill.
                                                                   used in bleaching
                                        21-4

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                                                                         21.0 Glossary
Chlorine consumption - Actual amount of chlorine consumed to bleach pulp, expressed as
kilograms of chlorine used per air dry metric ton of pulp bleached, or a percentage on the1
same basis.  It may also be expressed on a bone dry basis.

Chlorine dioxide generation - Chemical reduction of sodium chlorate under controlled
conditions to generate chlorine dioxide.   Chlorine (C12)  is a. by-product of this reaction.
Several different processes are used to generate chlorine dioxide.  The chlorine content of
the chlorine dioxide varies with the process used.

Chlorine dioxide  stage - The step or steps in a multi-stage bleaching process ("D" stages)
where chlorine dioxide solution is mixed with pulp, allowed to react, and then washed as one
of the operations making up a complete pulp bleaching system. See brightening.

Chlorine evaporator - A specially constructed, thermostatically controlled vessel using hot
water or steam to vaporize liquid chlorine transferred from tank cars to a pulp mill bleach
plant. This vaporized product is a gas used in the chlorination stage of a bleaching  process,
as well as to make up hypochlorite bleaching liquor.   Also called  chlorine vaporizer.

Chlorine mixer - A mixing device used in the bleach plant to mix chlorine water or  gas with
unbleached  pulp.

Chlorine requirement - The amount of elemental chlorine (C12) required to achieve a
specified final brightness level of pulp in the bleaching process. It is supplied in the form
of elemental chlorine and/or bleaching agents such as hypochlorite, chlorine dioxide, etc.

Clarifier - A treatment unit designed to remove suspended materials  from wastewater,
typically by  sedimentation.

Closed vent system  - A system that is not open to  the atmosphere and is composed of
piping, ductwork, connections, and, if necessary, flow-inducing devices that transport gas or
vapor from  an emission point to a control device.

Combustion device - An individual unit of equipment, including but not  limited to,  an
incinerator,  lime kiln, recovery furnace, or boiler, used for the thermal oxidation of organic
hazardous air pollutant vapors.

Complete recycle - A system where the sum of fresh water and water entering the system
in raw  material  is  equal to  the  sum  of water exiting the system via evaporation  or
vaporization, water in the final product, and water  included in any reject streams from
screening, including sludges.  There  is  no direct or  indirect discharge of  wastewater to
surface waters, nor is there any  land application, surface  impoundment,  or other  land
disposal of wastewater effluents.

                                        21-5

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                                                                        21.0 Glossary
Condensate - Any material that has condensed from a gaseous phase into a liquid phase.

Consistency - Mass or weight percent of bone dry fiber in a stock. Smook (1) provides the
following guide to qualitative consistency descriptions:
             low consistency     1'- oyo
             medium consistency 8-16%
             high consistency    16 - 40%

Continuous digester - A wood-cooking vessel in which chips are reduced to 'their fiber
components using suitable chemicals under controlled temperature and pressure in  a
continuous operation.

Continuous discharge - Discharge that occurs without interruption throughout the operating
hours of the facility.

Controlled-release discharge - A discharge that occurs at a rate that is intentionally varied
to accommodate fluctuations in receiving stream assimilative capacity or for other reasons.

Conventional pollutants - The pollutants identified in sec. 304(a)(4) of the CWA and the
regulations thereunder (biochemical oxygen demand (BOD5), total suspended solids (TSS),
oil and grease, fecal coliform, and pH).

Converting mill - A facility that purchases paper for converting into marketplace products
(e.g., boxes, paper plates, etc.).

Cooking liquor - Chemical solution  added  to digesters to  reduce chips  into their fiber
components by dissolving the cementing material, usually lignin, thereby forming pulp.

Cotton linters - The shorter length cotton fibers used to make a high quality dissolving pulp
used in the manufacture of cellulose derivatives.

Countercurrent washing - (1)  Method of washing pulp  by running the  wash water
countercurrent to the flow of pulp through the process. Examples include countercurrent
intra-stage washing in a multi-stage bleaching process (to minimize effluent) and  the
countercurrent flow of wash water to pulp flow on vacuum-type brown stock washers (to
mininiize water use and maximize black liquor recovery). (2) The washing of pulp within
a Kamyr continuous digester (before blowing) in which the wash water flows countercurrent
to the pulp flow in the process.

Daily discharge - The discharge of a pollutant measured during any calendar day or any 24-
hour period that reasonably  represents a calendar  day.  For pollutants with limitations
                                       21-6

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                                                                         21.0 Glossary
expressed as mass, the daily discharge is calculated as the total mass of the pollutant
discharged over  the  day.   For pollutants with limitations expressed  in  other units of
measurement, the daily discharge is calculated as the average measurement of the pollutant
over the day.

Decker - A piece of equipment used to thicken or reduce the water content of the pulp
slurry after the pulp washer system.

Deinking - The processing of printed and other used, reclaimed waste paper by mechanical
disintegration, chemical treatment, washing, and bleaching in order to remove ink and other
undesirable materials so that it can be reused as a source of papermaking fiber.

Delignification - The process of degrading  and dissolving away lignin and/or hemicellulose.

Dewater - (1) The tendency of solids in a slurry to aggregate and cause the draining of water
from standing or flowing sludge or pulp slurry in a pipeline, sometimes to the point where
the remaining solids become thick enough to make removal difficult, or to obstruct free flow
through the line  or a restriction such as a valve.  (2) The process by which some of the
water is removed from the pulp stock, increasing the consistency.

Digester - A pressure vessel used to chemically treat chips and other cellulosic  fibrous
materials such as straw, bagasse, rags, etc., under elevated temperature and pressure in
order to separate fibers from each other.

Digester system - Each continuous digester  or each set of batch digesters used for the
chemical  treatment of wood, including associated  flash  tank(s),  blow  tank(s), chip
steamer(s), condenser(s), and pre-hydrolysis unit(s).

Direct discharger - A facility that discharges or may discharge treated or untreated process
wastewaters, non-contact cooling waters, or non-process wastewaters (including stormwater
runoff) into waters of the United States.

Dry end operation - The process on the paper machine in which paper sheet moisture is
removed by evaporation.

Effluent - Wastewater discharges.

Effluent limitation  - Any restriction, including schedules of compliance, established by a
State or the Administrator on quantities,  rates, and concentrations  of chemical, physical,
biological, and other constituents which are discharged from point sources into navigable
waters, the waters of the contiguous zone, or  the ocean.
                                        21-7

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                                                                        21.0 Glossary
Emission - Passage of air pollutants into the atmosphere via a gas stream or other means.

Emission  point - Any location within a source from which air pollutants are emitted,
including an individual process vent, opening within a wastewater collection and treatment
system, or an open piece of process equipment.

Enhanced delignification - See extended delignification.

EOF (End-of-pipe) effluent - Final mill effluent discharged to waters of the United States
or to a. POTW. .

EOF  (End-of-pipe) treatment - Treatment facilities or  systems used  to  treat process
wastewaters, non-process wastewaters and/or stormwaters after the wastewaters have left
the process area of the facility and prior to discharge. End-of-pipe treatment generally does
not include facilities or systems where products or by-products are separated from process
wastewaters and returned to the process or directed to air emission control devices  (e.g.,
pulping liquor spill prevention and control systems, foul condensate stripping systems, paper
machine save-alls).

Extended  cooking - Modifications to traditional pulping processes to produce pulp of lower
Kappa number while increasing pulp strength and  maintaining or increasing pulp yield.
Extended cooking modifications are available for both batch and continuous kraft pulping
processes.  By maintaining a more uniform active chemical concentration during the cook,
more lignin is dissolved with less damage to the wood fiber cellulose than in traditional kraft
pulping.

Extended delignification - A process that enables a mill to lower the Kappa number of the
pulp entering the bleach plant further than is possible with traditional pulping technology.
Extended delignification can be in the form of extended  cooking or oxygen delignification.

Extraction stage - That stage hi a multi-stage pulp bleaching operation ("E" stage), usually
following  the  chlorination stage, hi which sodium hydroxide (NaOH) is used to remove
water insoluble chlorinated lignin and other colored  components  not removed in an
intermediate washing operation.  Also referred to as  the caustic stage or alkaline extraction
stage.

Extractives -  Woody plant components which are  not part  of the cell wall structural
elements and can be removed with neutral solvents such  as ether, alcohol, and water.  Also
referred to as extraneous  components of wood.

Fiber furnish  - Raw materials used to manufacture  market pulp, paper,  or paperboard.
                                        21-8

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                                                                        21.0  Glossary
Fine papers - High-quality writing, printing, and cover-type papers having excellent pen and
ink writing surface characteristics.

Fines - Very small fibers and fiber fragments that readily pass through a filter wire cloth.

Finishing - Processing of paper after the papermaking operations are completed, including
super calendaring, slitting, rewinding, trimming, sorting, counting, and packaging prior to
shipment from the paper mill.

First stage - A reference to the first stage of a multi-stage pulp bleaching operation, which
traditionally has been a chlorination stage (C stage). Recent technological developments
have introduced other chemicals  for use in the first stage, including chlorine dioxide and
ozone.

Five-Mill Study - U.S. EPA/Paper Industry Cooperative Dioxin Screening Study conducted
during 1985 and 1986 at five  bleached kraft pulp and paper  mills for the  purpose of
determining the process sources of CDDs and CDFs. The study results were published in
1988 (U.S. EPA Paper Industry Dioxin/Cooperative Screening Study, EPA-440/1-88-025,
March 1988).

Flow indicator - A device that indicates whether gas flow is present in a closed vent system.

Fluff pulp - Bleached pulp further processed into fluff by dry fiberization and made into
disposable diapers, feminine care products, hospital wads, and various types of tissue and
towels.

Free chlorine - Elemental chlorine in the pulp bleaching process which is in solution and
not compounded with lignin elements in chlorinated pulp slurries.

Green Liquor - A solution made by dissolving the sodium and sulfur-containing smelt from
the kraft recovery process prior to causticizing.

Groundwood - Pulp and paper made up of mechanically separated fibers produced by the
grinding  of pulpwood.

Hardwood - Pulpwood from broad-leaved dicotyledonous deciduous trees, such as birch,
aspen,  oak, etc.

Hemicellulose - The alkali-soluble, noncellulosic polysaccharide portion of the wood cell
wall.
                                        21-9

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                                                                        21.0 Glossary
Hemp - Annual plant (Cannabis sativa) used as a non-wood fiber furnish. The blast fibers
are separated from the stalks in the same manner as for flsix.

High-temperature  bleaching - Operating the bleaching stages (hypochlorite or chlorine
dioxide) of a multi-stage pulp bleaching system at temperatures higher than considered
conventional.

High-temperature  chlorination - Operating the first bleaching stage (chlorination)  of a
multi-stage pulp bleaching process at higher temperatures (usually 110°F to  120 °F)  than
considered conventional (less than 80°F).

Hypochlorite - Reducing-type of  bleaching  chemical, usually in the  form of  calcium
hypochlorite (Ca(OCl)2) or sodium hypochlorite (NaOCl), used extensively in the bleaching
of chemical pulps.

Hypochlorite stage - The step or steps ("H" stages) in a multi-stage bleaching process in
which hypochlorite bleaching chemicals (usually calcium or sodium hypochlorite) are mixed
with pulp  and allowed to react.

Incinerator - An enclosed combustion device that is used for destroying organic compounds.
Auxiliary  fuel may be used to heat waste gas to  combustion temperatures.  Any energy
recovery section present is not physically formed into one manufactured or assembled unit
with the combustion section; rather,  the  energy recovery section is a separate  section
following  the combustion section and the two are joined by ducts or connections  carrying
flue gas.

Indirect discharger - A facility that discharges or may discharge wastewaters into a publicly
owned treatment works or a treatment works not  owned by the discharging facility.

Industrial POTW - Any POTW receiving more than 50 percent of its influent flow  or more
than 50 percent of  its  BOD5 or TSS wastewater load from a  facility subject to these
regulations.

Integrated mill - A mill that produces pulp and may use none, some, or all of that pulp
(often in combination with purchased pulp) to produce paper or paperboard  products.

Integrated regulatory alternative - A set of control options comprising the technology bases,
for effluent limitations guidelines and national emission standards.

K number - One  of two laboratory test values used for indirectly indicating the lignin
content, relative hardness, and bleachability of pulps.  This value is more frequently used
for pulps  having lignin contents below 6 percent, and tends  to be pulp-specific.  It is

                                       21-10

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                                                                       21.0 Glossary
determined by  the  number of milliliters of tenth normal  permanganate  solution (0.1
KMnO4) which  is absorbed by 1 gram of oven dry pulp under specified conditions. Also
known as permanganate number.

Kappa number  - One of two laboratory test values used for indirectly indicating the lignin
content, relative hardness, or bleachabih'ty of higher lignin content pulps. This value is more
frequently used for pulps with yields of 70 percent or more, and tends to be pulp-specific.
It is determined by the number of milliliters of tenth normal permanganate solution (0.1
KMnO4) which  is absorbed by 1 gram of oven dry pulp under specified conditions, and is
then corrected to 50 percent consumption of permanganate.

Knotter - A device that removes knots or pieces of uncooked wood from pulp after the
digester system  and prior to the pulp washer system. Equipment used to remove oversized
particles from pulp following the pulp washer is considered screens.

Kraft process -  See Sulfate process.

Kraft cooking liquor (Kraft pulping liquor)  - A chemical mixture  consisting of sodium
hydroxide (NaOH) and sodium sulfide (NajS). It is used to cook wood chips and convert
them into wood pulp.  Sometimes called sulfate cooking liquor.

Kraft digester - A pulpwood cooking vessel in which sulfate cooking liquor, consisting of
sodium hydroxide (NaOH) and sodium  sulfide  (Na2S)  active chemicals, is used as the
cooking medium. ;

Kraft pulp - Wood pulp produced by the sulfate  chemical process. Also  known as sulfate
pulp.

Kraft recovery cycle - The series of unit processes in a sulfate pulp mill in which the spent
cooking liquor  is separated  from  the pulp  by washing, concentrated  by evaporation,'
supplemented to make up for spent sodium, and burned to recovery other chemicals. These
recovered chemicals are converted to fresh cooking liquor by reacting them with lime in a
causticizing operation.

Lignin - A brown-colored organic substance which acts  as an interfiber bond in woody
materials. It is chemically separated from cellulose during the chemical cooking process to
form pulp, and  is removed along with other organic materials in the spent cooking liquor
during subsequent washing and bleaching stages.

Lime (CaO) - A pulp  mill chemical obtained by burning limestone (CaCO3) and used to
prepare and regenerate cooking and bleaching liquors. It is used in recausticizing sulfate
                                      21-11

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                                                                        21.0 Glossary
and soda cooking liquors, and to make up milk of lime [Ca(OH)2] for the sulfite cooking
process.

Lime kiln  - An enclosed combustion device used  to calcine lime mud, which consists
primarily of calcium carbonate, into calcium oxide, which is known as quicklime and is used
again with  green liquor to form white liquor.

Market pulp - Bleached or unbleached pulp in the form of bales or sheets for transfer or
sale off site.

Maximum  daily discharge limitation - The highest allowable daily discharge of a pollutant
measured during a calendar day or any 24-hour period that reasonably represents a calendar
day.

Mechanical pulp - Pulp produced by reducing  pulpwood logs and chips into their fiber
components by the use of mechanical energy (at CMP or CTMP mills, also with  the use of
chemicals or heat), via grinding stones or refiners.

Method detection limit - The minimum concentration of a substance that can be  measured
and reported with 99 percent confidence that the analyite concentration is greater than zero
and is determined from analysis of a sample in a given matrix containing the analyte (see
40 CFR Part 136, Appendix B).

Metric ton - One thousand (103) kilograms (abbreviated as kkg), or one megagram.  A
metric ton  is equal to 2,204.5 pounds.

Minimum level - The level at which an analytical system gives  recognizable signals and an
acceptable  calibration point.

Multiple effect evaporator system - A series of evaporators, operated at different pressures
such that the vapor  from one evaporator body becomes the steam supply for the next
evaporator, as well as the associated condenser(s) and hotwell(s) used to concentrate  the
spent cooking liquid  that is separated  from the pulp.

New Source - Any building, structure, f acility, or  installation from which there is or may be
a discharge of pollutants, the construction of which commences after the promulgation of
the standards being proposed today for the pulp, paper, and paperboard industry under sec.
306 of the CWA:  See CWA §306.

Non-continuous or intermittent discharge - Discharge of wastewaters stored for periods of
at least 24 hours and released on a batch basis.
                                       21-12

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                                                                        21.0 Glossary
Nonconventional pollutants - Pollutants that are neither conventional pollutants nor priority
pollutants (see 40 CFR Section 401.15 and Part 423, Appendix A).

Non-detect value - A concentration-based measurement reported below the minimum level
that can reliably be measured by the analytical method for the pollutant.

Non-integrated mill - A mill that produces paper or paperboard from purchased pulp and
not from pulp produced on site.

Non-water quality environmental  impact -  An environmental impact  of  a control or
treatment technology, other than to surface waters.

Off-machine  metric tons  (OMMT)  - Mass  of final product, including coatings where
applicable, at the off-machine moisture content. For market pulp, the off-machine moisture
content is  defined to be  10 percent moisture.  OMMT is the  production normalizing
parameter for end-of-pipe limitations for BOD5 and TSS.

Oven dry (OD) -  Moisture-free conditions of pulp and paper and other materials used in the
pulp and paper industry.  It is usually determined by drying a known sample to a constant
weight in a completely dry atmosphere  at a temperature  of  100°C to  105°C (212°F to
221 °F). Also called bone dry (BD).

Outfall - The mouth of conduit drains and other conduits from which a mill effluent
discharges into receiving waters.

Oxygen delignification - An extended delignification process used after pulping and brown
stock washing and prior to bleaching. In this process, which can be used on both kraft and
sulfite  pulps,  oxygen gas  is used in an alkaline environment to delignify pulp.  Because
oxygen delignification typically precedes the application of chlorine,  oxygen delignification
wastewaters can  be rerouted to  the pulping liquor recovery cycle.

Paper machine - The primary machine in a paper mill on which slurries containing fibers
and other constituents are formed into a sheet by the drainage of water, pressing, drying,
winding into rolls, and sometimes coating.

Permanganate number - See K  number.

Peroxide - A  short name for hydrogen peroxide  (H2O2) or sodium peroxide (NajOj).

Peroxide bleaching stage -  A  hydrogen peroxide bleaching  step  or steps  ("P" stages)
sometimes used in the later part of the multi-stage chemical-bleaching sequence as one of
                                       21-13

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                                                                        21.0 Glossary
the operations making up the complete pulp-bleaching system.  Sodium peroxide is also
occasionally used.

Point source category - An industrial source of water pollutants.

Pollutant (to water) - Dredged spoil, solid waste, incinerator residue, filter backwash,
sewage, garbage,'sewage sludge, munitions, chemical wastes, biological materials, certain
radioactive materials, heat, wrecked or discarded equipment, rock,  sand, cellar dirt, and
industrial, municipal, and agricultural waste discharged into water.

Pretreatment standard  - A regulation addressing industrial wastewater  effluent quality
required for discharge to a POTW.

Priority pollutants - The toxic pollutants listed in 40 CFR part 423,  Appendix A.

Process changes - Alterations in process operating conditions, equipment,  or chemical use
that reduce the formation of chemical compounds that  are pollutants and/or pollutant
precursors.

Process unit -  A piece  of equipment, such as  a pulp washer,  decker, or filtrate tank,
associated with either the pulping process or the bleaching process.

Process wastewater - When used in connection with CWA obligations, any water which,
during manufacturing or processing, comes into  direct contact with or results from the
production or use of any raw material, intermediate product, finished product, byproduct,
or waste product.  Process wastewater includes boiler blowdown; wastewaters from water
treatment and other utility operations; blowdowns from  high  rate (e.g., greater than 98
percent) recycled non-contact cooling water systems to the extent they are mixed and co-
treated with other process wastewaters; and, stormwaters from the immediate process areas
to the extent they are mixed and co-treated with other process wastewaters. Contaminated
groundwaters from on-site or off-site groundwater remediation  projects are not process
wastewaters. The discharge of such groundwaters are regulated separately, or in addition
to, process wastewaters.

Process wastewater collection system - A  piece of  equipment, structure, or  transport
mechanism used in conveying or storing a process wastewater stream. Examples of process
wastewater collection system equipment include individual drain systems, wastewater tanks,
surface impoundments, or containers.

Process water -  Water used to dilute,  wash, or carry  raw materials, pulp, and any other
materials used in the manufacturing process.
                                       21-14

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                                                                        21.0 Glossary
Product - Completed material ready for sale or intra-company off-site transfer.

Production rate - For application to NPDES permits and pretreatment standards, defined
as the daily  process-specific production rate  used to apply to the effluent limitations
guidelines and standards in the proposed 40 CFR Part 430. Production shall be determined
based upon the  highest annual  production in the five  years divided by the number of
operating days that year.  See the  General Provisions at 40  CFR §430.01 for production
normalizing parameters applied to the limitations and standards (included in the definition
of "product").

Pulp - A fibrous material  produced by mechanically or chemically reducing woody plants
into their component parts from which pulp, paper, and paperboard sheets are formed after
proper slushing and treatment, or used for dissolving purposes (dissolving pulp or chemical
cellulose) to make rayon, plastics, and other synthetic products.

Pulp bleaching - The process of further delignifying and whitening pulp by chemically
treating it to  alter the coloring matter and to impart a higher brightness.

Pulp cooking - The process of reacting fiber-containing materials with suitable chemicals,
usually under high temperature and pressure, in order to reduce them into their component
parts with the fiber portion separated in the  form of pulp.   More commonly known as
chemical pulping.

Pulp machine - Equipment used to remove moisture from pulp slurry to prepare the pulp
for shipment. The pulp machine  is  similar to a paper machine and consists of a formulating
section, pressing section, drying section, winders, and cutters. Sometimes referred to as a
pulp dryer.

Pulp mill - A plant in which pulp is mechanically or chemically produced from fibrous
materials such as woody  plants, together with other  associated processes such as pulp
washing and bleaching. Chemical preparation and cooking chemical recovery operations are
also conducted there.

Pulping - Conversion of raw materials into fibers that  can be formed into a sheet.

Pulp washer - A piece of pulp mill equipment designed to separate soluble, undesirable
components in a pulp slurry from the acceptable fibers, usually by some type  of  screening
method combined with diffusion and displacement with  wash liquors, utilizing vacuum or
the natural force of gravity.

Pulping component - For the NESHAP, all process equipment, beginning with the digester
system, up to and including  the last piece of pulp conditioning equipment  prior to  the

                                       21-15

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                                                                        21.0 Glossary
bleaching component, including treatment with ozone, oxygen, or peroxide before the first
application of chlorine or chlorine-containing compounds.

Purchased pulp - Pulp purchased from an off-site facility or obtained from an intra-company
transfer from another site.

Recovery boiler - An enclosed combustion device where concentrated spent pulping liquor
is burned to recover sodium and sulfur, produce steam, and recover the heating value of
dissolved wood components in the liquor.  Sometimes referred to as a recovery furnace.

Recovery plant - The area, building, or buildings where all of the process units considered
to be included hi the chemical recovery cycle of a pulp mill are located.

Red liquor - Sulfite pulping liquor.

Screen - A device that removes oversized particles from the pulp slurry after the pulp
washer system  and prior to the papermaking  equipment.  Equipment used to remove
oversized particles prior to the pulp washer system is considered knotters.

Screen room - The area hi a pulp mill where unwanted particles called rejects or tailing are
separated from the accepted fibers with  the use of equipment  such as knotters, rifflers,
refiners, separators, thickeners, and flat or rotary screens. Closed screen room operation,
or screen room closure, refers to the elimination of wastewater discharge from knotting and
screening operations. It is generally accomplished through reusing the wastewater (screen
decker filtrates) as pulp dilution water  ahead of the  screens, or as wash liquor on a
preceding stage of washing.

Seal tank - A receiving tank located beneath vacuum-type washers and filters. Wash water
drops into  it through a pipe and forms a seal to create a vacuum in the sheet-forming
cylinder portion of the unit.  Sometimes referred to as a seal pit.

Secondary  flber -  Furnish  consisting of  recovered  material.  For the purposes of this
preamble, secondary fiber  does not include broke but does include recycled paper or
paperboard known commonly as "post-consumer" recycled material.  The  term secondary
fiber is used both for the raw material (wastepaper, old corrugated containers, etc.) and the
pulp produced from the wastepaper and board.

Semi-bleached kraft (SBK) - Pulp made by the sulfate process which has not been bleached
to the extent that normally fully bleached pulp has.

Semi-bleached pulp  -  Pulp  which has been only lightly bleached to what is ordinarily
considered  a very low brightness range.

                                       21-16

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                                                                        21.0 Glossary
Semi-chemical pulp - Pulp made by cooking fibrous materials under pressure in a variety
of cooking liquors, including neutral sulfite/sodium carbonate (NSSC), sulfur free (sodium
carbonate), green liquor, and Permachem®. The cooked chips are usually mechanically
refined.

Skives - Small bundles of fibers that have not been separated completely in the pulping
operations.

Showers - Water jets or sprays used throughout pulp and paper mills to wash wire mesh
screens, wires, wet felts, and pulp pads on paper machines,  cylindrical-type washers, pulp
screens, pulp drainers, etc.

Slaking/causticizing - A two-stage chemical process in the causticizing plant of an alkaline
pulp mill in which the sodium carbonate (NajCOg) in the green liquor is converted to
sodium hydroxide (NaOH) to produce white liquor. The first stage is slaking, which consists
of the addition of lime (CaO) to green liquor where it reacts  with water to form calcium
hydroxide [Ca(OH)2].  The second stage is causticizing, in which the calcium  hydroxide
reacts with the sodium carbonate to form sodium hydroxide. '

Soda process - A chemical pulping process that consists of the reduction of chips to their
individual fiber components by use of cooking liquor made up of caustic soda (NaOH)
solution, the recovery and preparation of this liquor, or the treatment of pulp and  paper
produced from it.

Sodium hydroxide (NaOH) - A strong alkali-type chemical used in making up cooking liquor
in alkaline pulp mills. It is commonly referred to in the mill as caustic or caustic soda.

Sodium hypochlorite (NaOCl) - A chemical used as one of  the bleaching agents in multi-
stage pulp mill bleach plants. It is also used as the only bleaching agent at deink secondary
fiber mills and during the production of non-wood pulp by non-chemical means.

Softwood - Pulpwood obtained from evergreen, cone-bearing species of trees, such as pine,
spruce, hemlock, etc., which are characterized by having needles.

Source Category - A category of major or area sources of hazardous air pollutants.

Source Reduction - The reduction or elimination of waste generation at the source, usually
within a process.  Any practice that 1) reduces the amount of any hazardous substance,
pollutant,  or contaminant  entering any waste  stream  or  otherwise released into  the
environment (including fugitive emissions) prior to recycling, treatment, or disposal; and 2)
reduces the hazards to public health and the environment associated with the release of such
substances, pollutants, or contaminants.

                                       21-17

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                                                                        21.0 Glossary
Spent liquor - Used cooking liquor in a chemical pulp mill which is separated from the pulp
after the cooking process.  Spent liquor from kraft pulping is called black liquor. Spent
liquor from suMte pulping is called red liquor.

Stock preparation - The area of a paper mill where pulp is received from an on- or off-site
pulp mill, prepared for storage in slurry form, mechanically treated in beaters and refiners,
mixed with other pulps,  additives, dyes, and  chemicals, and then cleaned and  generally
processed prior to sheet formation on the paper machine.

Stripper system - A column, and associated feed tanks, decanters, reboilers, preheaters,
condensers or heat exchangers, used to strip compounds from process wastewater, using an-
or steam. Steam strippers are generally used to control the release of volatile compounds
to the air from process wastewaters that contain high concentrations of such compounds.
For  example, black liquor evaporator condensates containing high concentrations  of
methanol are steam-stripped to control the emission of methanol to the air.

Subpart S - National Emission Standards for Hazardous Air Pollutants from the Pulp and
Paper Production Source  Category under Title 40, Chapter I, Part 63 of the Code of Federal
Regulations.

Sulfate  process - An alkaline pulp manufacturing process in which the active chemicals of
the liquor used in cooking (digesting) wood chips to their component parts in a pressurized
vessel (digester) are sodium sulfide (Na2S) and sodium hydroxide (NaOH) with sodium
sulfate  (NaaSC^) and lime (CaO) being used to replenish these chemicals in recovery
operations.  Also referred to as the kraft process.

Sulfate pulp - Fibrous material used in pulp, paper, and paperboard manufacture, produced
by chemically reducing wood chips into their component parts by cooking in a vessel under
pressure using an alkaline cooking liquor. This liquor consists of sodium sulfide (NajS) and
sodium  hydroxide (NaOH). Also referred to as kraft pulp.

Sulfite process - An acid pulp manufacturing process in which chips are reduced to their
component parts by cooking (digesting) in a pressurized vessel using a liquor of calcium,
sodium, magnesium or ammonia salts  of sulfurous acid.

Toxic pollutants -  The pollutants designated by EPA as toxic in 40 CFR § 401.15.  Also
known as priority pollutants.

Unbleached pulp - Pulp that has not been treated in a bleaching process.

Variability factor - The daily variability factor is the ratio of the  estimated 99th percentile
of the distribution of daily values divided by the expected value, or mean, of the distribution

                                      21-18

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                                                                        21.0 Glossary
of the daily data.  The monthly variability factor is the estimated 95th percentile of the
monthly averages of the data divided by the expected value of the monthly averages.

Washer - Pulp mill equipment designed to separate soluble, undesirable components in a
pulp slurry from the acceptable fibers.  It usually consists of some type of screening method
combined with diffusion and displacement with wash liquid, utilizing vacuum, or the natural
force of gravity.

Waters of the United States - As defined in 40 CFR §122.2.  This definition includes  all
waters that are currently used, may be used in the future, or were used in the past, in
interstate or foreign commerce (including all waters subject to the ebb and flow of the tide)
and adjacent wetlands.

Wet end operation - The process on the paper machine in which the sheet is formed from
the stock furnish and most of the water is removed before the sheet enters the dryer section.

White liquor - A solution of kraft pulping liquor chemicals.  White liquor can be made  by
re-causticizing green liquor, produced  in the kraft recovery cycle, with slaked lime.

White water - Waters formed when stock or other fiber-bearing suspensions are dewatered.

Wood preparation - Those operations to prepare  wood for pulping, including  removal of
bark from logs, converting them into chips, and chip screening.

Zero discharge  (ZD) - No discharge of wastewater to waters of the United States or to a
POTW.

Reference

Smook, G.A.  Handbook  of  Pulp and Paper Terminology:   A Guide to Industrial and
Technological Usage.  Angus  Wilde  Publications, Vancouver, B.C.   1990.
                                      21-19

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                                                      22.0 Abbreviations and Conversions
22.0  ABBREVIATIONS AND CONVERSIONS

22.1  Abbreviations
2,3,7,8-TCDD

2,3,7,8-TCDF

A

ACM

ACT

AFPA


APHA

AQ

AOX


API

ASB

BAT

BCT

BCTMP

BID



BMP

BOD5
 2,3,7,8-tetrachlorodibenzo-p-dioxin

 2,3,7,8-tetrachlorodibenzofuran

 bleach sequence symbol for treatment with acid

 active chlorine multiple

 activated sludge wastewater treatment

 American Forest and Paper Association (formerly the American
 Paper Institute and the National Forest Products Association)

 American Public Health Association

 anthraquinone

 Adsorbable organic halides. A bulk parameter which measures the
 total chlorinated organic matter in wastewater.

 American Paper Institute (Now AFPA)

 aerated stabilization basin

 Best Available Technology Economically Achievable

 Best Conventional Pollutant Control Technology

. bleached chemi-thermo-mechanical pulp

 Background Information Document:  Pulp, Paper, and Paperboard
 Industry-Background Information for Proposed Air Emission
 Standards (October, 1993)  .

 Best Management Practices

 Five day biochemical oxygen demand
                                      22-1

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                                                     22.0  Abbreviations and Conversions
BPJ

BPK

BPT

C

CAA

CAPDET


CBI

CDDs
CFR

CMN

CMP

COD

CP

CTMP

CVAA

CWA

D

DAP

DBD

DBF
best professional judgment

bleached papergrade kraft and soda mills

Best Practicable Control Technology

bleach sequence symbol for chlorine stage

Clean Air Act

computer assisted procedure for design and evaluation of
wastewater treatment systems

confidential business information

chlorinated dibenzo-p-dioxins

chlorinated dibenzofurans

Code  of Federal Regulations

corrugated, molded and newsprint

chemi-mechanical pulp

chemical oxygen demand

chlorinated phenolic compound

chemi-thermo-mechanical pulp

cold vapor atomic absorption

Clean Water Act

bleach sequence symbol for chlorine dioxide stage

dissolved air flotation

dibenzo-p-dioxin

dibenzofuran
                                      22-2

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                                                       22.0 Abbreviations and Conversions
DK

DOX

E

BAD

ECF

ECU

EMCC*


BOX

EPA

ESAB

FID

F/M


FR

GC

GCM

GFAA

GPC

H

HAP

HPLC
 dissolving kraft mills

 dissolved organic halides

 bleach sequence symbol for extraction stage

 Engineering and Analysis Division

 elemental chlorine-free

 electrochemical unit

 extended modified continuous cooking, a registered trademark of
 Kamyr, Inc.

 extractable organic halides

 U.S. Environmental Protection Agency

 Economic and Statistical Analysis Branch

 flame ionization detector

 food to microorganism ration (concentration BOD5 4- concentration
 of mixed liquor volatile suspended solids)

 Federal Register

 gas chromatography

 gaseous chlorine multiple

 graphite furnace atomic  absorption

 gel permeation chromatography

 bleach sequence symbol for hypochlorite stage

Hazardous Air Pollutant

high pressure liquid chromatography
                                       22-3

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                                                     22.0 Abbreviations and Conversions
HRGC



HRMS



HW



ICP



IU



LRGC



LRMS



ISO



LTA



LTS



MACT



MCC*



MDL



MEK



ML



MLSS



MLVSS



MS



N



NA



N/A
high resolution gas chromatography




high resolution mass spectrometry




hardwood



inductively coupled plasma



industrial user (synonym for "indirect discharger")



low resolution gas chromatography




low resolution mass spectrometry



Internatiorial Organization for Standardization




long-term average



long-term study



Maximum Achievable Control Technology



modified continuous cooking, a registered trademark of Kamyr, Inc.




method detection limit



methyl ethyl ketone (2-butanone)




minimum level



mixed liquor suspended solids



mixed liquor volatile suspended solids



mass  spectrometry



bleach sequence symbol indicating the absence of a washing stage




not applicable




not available
                                       22-4

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                                                      22.0 Abbreviations and Conversions
NCASI


ND

ND


NESHAP

NPDES

NR

N/R

NRDC

NSPS

NSSC

o

O&M

OAR

OMB

OPPT

OW

OX

P

PCB

PCP
National Council of the Paper Industry for Air and Stream
Improvement, Inc.

not detected

not disclosed to prevent compromising confidential business
information

National Emission Standards for Hazardous Air Pollutants

National Pollutant Discharge Elimination System

npt reported

not required

Natural Resources Defense Council

New Source Performance Standards

Neutral Sulfite Semi-Chemical

bleach sequence symbol for oxygen stage

operating and maintenance

Office of Air and Radiation

Office of Management and Budget

Office of Pollution Prevention and Toxics

Office of Water

organic halides

bleach sequence symbol for peroxide stage

polychlorinated biphenyl

pentachlorophenol
                                      22-5

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                                                      22.0 Abbreviations and Conversions
pH


PNF

PNP

POTW'

POX

PSES

PSNS

Q

QA

QC

RBC

RDH*

S

SCC

SDS

SIC

SID

STFI

STS

SVP

SW
negative logarithm of the effective hydrogen-ion concentration hi
moles per liter, a measure of acidity

production normalized flow

production normalizing parameter

publicly owned treatment works

purgeable organic halides

Pretreatment Standards for Existing Sources

Pretreatment Standards for New Sources

bleach sequence symbol for acid chelarit stage

quality assurance

quality control

rotating biological contactor

rapid-displacement heating, a registered trademark of Beloit Corp.

bleach sequence symbol for sodium bisulfite

Sample Control Center

Soxhlet/Dean-Stark apparatus

Standard Industrial Classification

survey identification number

Swedish Forest Products Research Institute

short-term study

single vessel process used in chlorine dioxide generation

softwood
                                       22-6

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                                                      22.0 Abbreviations and Conversions
TAG




TCP




TCP



TEF




TOC1



TOX




TRS




TSS



UBK




UP



VOC



W



X
Z




22.2  Units of Measure




ADMT            air dry metric ton
total annualized cost




totally chlorine-free




trichlorophenol



toxicity equivalency factor




total organic chlorine




total organic halides




total reduced sulfur




total suspended solids




unbleached kraft mills



ultrafiltration



volatile organic compound



bleach sequence symbol for washing stage



bleach sequence symbol for enzyme stage



bleach sequence symbol for ozone stage
ADT



BTU




fg



g



kg
air dry (short) ton



British Thermal Unit



femtogram



gram




kilogram
                                       22-7

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                                                       22.0 Abbreviations and Conversions
kkg

kPa

L

m3

mg


MOD

ng

OMMT

OMT
1000 kilograms = 1 metric ton = 1 megagram

kilopascal

liter

cubic meter

milligram


million gallons per day

nanogram

off-machine metric ton

off-machine (short) ton
pg                 picogram

ppb               part per billion

ppm               part per million

ppq               part per quadrillion

ppt                part per trillion

fig                 microgram

223   Unit Conversions

       Table 22-1 presents mass and concentration unit conversions used throughout this
document.
                                       22-8

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                                        Table 22-1
                                 Units of Measurement
Mass Units
Unit
Metric ton
Kilogram
Gram
Milligram
Microgram
Nanogram
Picogram
Femtogram
Unit Abbreviation
kkg
kg
g
mg
Mg
Qg
Pg
fg
Equivalent Mass in Grams
1,000,000
1,000
1
0.001
0.000001
0.000000001
0.000000000001
0.000000000000001
Concentration Units
Unit Abbreviation
ppm (10-*)
ppb (10-9)
ppt (10-12)
ppq (io-ls)
Liquids
mg/L
Mg/L
ng/L
Pg/L
Solids
mg/kg = /ig/g
Mg/kg = ng/g
ng/kg = pg/g
pg/kg = fg/g
Notes:  (1)    For liquids, conversions from metric concentration unit to ppm, ppb, ppt, and ppq are
              approximate.
       (2)    1.0 kg = 2.2046 Ibs.

Source: American Petroleum Institute
       Publication No. 4506, March 1990
                                            22-9

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          Appendix A

Listing of Revised Subcategories
 in Which Each Mill Reported
      Production in 1989
             A-l

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              Appendix A
Listing of Revised Subcategories in Which
 Each Mill Reported Production in 1989

Facility Name
AHLSTROM FILTRATION INC
AHLSTROM FILTRATION INC
AHLS1 KUM PlLTKATlON INC
ALABAMA. PINE PULP
ALABAMA RIVER PULP CO
ALASKA PULP CORP
ALPHA CELLULOSE CORP
AMERICAN FIERir CO.
AMERICAN PAPER PRODUCTS CO
APPLBlON PAPERS INC
Ai^LKlUJN rAWKS INC
APPLKIUN PAPERS INC
ASHUELOT PAPER CO
ATLAS PAPER MILLS
ATLAS ROOFING CORP
AUGUSTA NEWSPRINT co
AUSTELL BOX BOARD CORP.
BJ FIBRES
BADGER PAPER MILLS INC
3 ADGER/GLOBE MILL
BALDWINVILLE PRODUCTS INC
BANNER flHKfiBOARD CO
JEAR ISLAND PAPER CO
BECKKH PAPER CO
BELOIT BOX BOARD CO
JEVERIDGE PAPER CO INC
BIG M PAPERBOARD
BLANDIN PAPER CO
5OISE CASCADE CORP
BOISE CASCADE CORP
BOISE CASCADE CORP
BOISE CASCADE CORP
BOISE CASCADE CORP
BOISE CASCADE CORP
BOISE CASCADE CORP
BOISE CASCADE CORF
BOWATER SOUTHERN PAPER CO
BOWAltK £>OtJ ThLERN PAPER CO
BRANDYWINE PAPERBOARD MILLS INC
BRUNSWICK PULP & PAPER CO/GEORGIA PACIFIC
BURROWS PAPER CORP - LYONSDALE DIV
BURROWS PAPER CORP.
BURROWS PAPER CORP.
BURROWS PAPER CORP.
C & A WALLCOVERINGS INC
CALIFORNIA PAPERBOARD CORP.
IAMDEN PAPERBOARD
CAROLINA PAPER BOARD CORP
CAROTELL PAPER BOARD CORP
CASCADE DIAMOND INC
:ASCADES INDUSTRIES INC
CASCADES NIAGARA FALLS INC
CELLU TISSUE CORP
:ELLULO co INC
UtluJl tA. UUKf.
CELOlttX CORP.
;ELOTEXCORP.
JELOTEXCORP.
CELOTEXCORP.
SRTAINTEED CORP
3JRTAINTEEDCORP
CHAMPION BVliiKNAliONAL
CHAMPION INTERNATIONAL
:HAMPION INTERNATIONAL
CHAMPION INTERNATIONAL
CHAMPION INTERNATIONAL

CSly
CHATTANOOGA
MADISONVILLE
MOUNT HOLLY SPRINGS
PERDUE HILL
PURDUE HILL
SIIXA
LUMBERTON
BATTLE CREEK
EDEN
COMBINED LOCKS
ROARING SPRING
WEST CARROLLTON
HINSDALE
fflALEAH
MERIDIAN
AUGUSTA
AUSTELL
SANTA ANA
PESHllGO
NEENAH
ERVING
WELLSBURG
ASHLAND
HAMILTON
BELOIT
INDIANAPOLIS
PALMYRA
GRAND RAPIDS
DERIDDER
INTERNATIONAL FALLS
JACKSON
RUMFORD
ST HELENS
STEILACOOM
VANCOUVER
WALLULA
CALHOUN
CATAWBA
DOWNINGTOWN
BRUNSWICK
LYONS FALLS
LITTLE FALLS
UTTLE FALLS
PICKENS
PLATTSBURGH
STOCKTON
:AMDEN
CHARLOTTE
TAYLORS
[•HORNDKE
IOCKINGHAM
4IAGARA FALLS
EAST HARTFORD
TOESNO
CAMDEN
GOLDSBORO
rfARRERO
QUINCY
SAN ANTONIO
tOLAN
SHAKOPEE
JUCKSPORT
:ANTON
:ANTONMENT
XJURTLAND
>EFERIET

Slate
TN
KY
PA
AL
AL
AK
NC
MI
PA
WI
PA
OH
NH
FL
MS
GA
GA
CA
WI
WI
MA
WV
VA
OH
WI
IN
MI
MN
LA
MN
AL
ME
OR
WA
WA
WA
TN
SC
PA
3A
NY
NY
NY
VIS
NY
ZA
JC
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                 A-2

-------
Appendix A




(Continued)
Facility Nimc
CHAMPION INTERNATIONAL
CHAMPION INTERNATIONAL
CHAMPION INTERNATIONAL
CHAMPION INTERNATIONAL
CHAMPION INTERNATIONAL
CHASE PACKAGING CORP '
CHATTANOOGA PAPERBOARD CORP.
CHENEY PULP * PAPER CO
CHESAPEAKE CORP.
CHESAPEAKE PAPERBOARD CO
CHICAGO PAPERBOARD CORP.
ONONNATI PAPERBOARD CORP.
3JBANBRS HANGER CO
CLIMAX MFG. CO.
COLUMBIA CORP
COLUMBIA CORP
CONNELLY CONTAINERS
CONSOLIDATED PACKAGING CORP.
CONSOLIDATED PAPERS INC - BIRON DIVISION
CONSOLIDATED PAPERS INC -KRAFT DIVISION
CONSOLIDATED PAPERS INC - STEVENS POINT DIV
CONSGUDATED PAPERS INC- WISCONSIN RAPIDS DIV
CONSOLIDATED PAPERS INC- WISCONSIN RIVER DIV.
CONTAINER CORP. OF AMERICA
CONTAINER CORP. OF AMERICA
CONTAINER CORP. OF AMERICA
CONTAINER CORP. OF AMERICA
CONTAINER CORP. OF AMERICA
CONTAINER CORP. OF AMERICA
CONTAINER CORP. OF AMERICA
CONTA&ffiR CORP. OF AMERICA
CONTAINER CORP. OF AMERICA
CONVERTERS PAPERBOARD CO.
CORNWALL PAPER MILLS
CORRUGATED SERVICES
COTTRELL PAPER CO INC
COY PAPER CO
CFMINC
CPMINC
CRANE & CO INC - BAYSTATE/MILL D
CRANB&CO KC-BYRON WESTONCO
CRANE & CO INC - PIONEERMILL C
CRANE*COINC.WAHCONAHI/MILLA
CRANB*CO mC-WAHCONAHD/MILLB
CROCKERTECHNICAL PAPERS INC
CRYSTALTISSUECO
OAISHOWA AMERICA co. LTD.
OAVBYCO
DAVEYCO
DAVEYCO
DEERFIELD SPECIALTY PAPERS INC fSIMPKEMS END)
DETROIT RIVER PAPER CO
DOMTARGYPSUM
DOMTAR GYPSUM
DOMTARGYPSUM
DUPONTSPECIALTY IMAGING MEDIA INC
BB EDDY PAPER INC
EASTERN FINE PAPER INC
EASTMAN KODAK CO/MILL A
EASTMAN KODAK CO/MILL B
EHV-WEIDMANN INDUSTIRES INC
aOUITABLEBAG CO INC
ERVINO PAPER MILLS
ESLEECK MANUFACTURING CO INC
FAIRFIELDPAPERCO.
4»EDERALFAPER BOARD CO.
FEDERAL PAPER BOARD CO.
City
HOUSTON
LUFKIN
NORWAY
ROANOKE RAPIDS
SARTELL
CHAGRIN FALLS
CHATTANOOGA
FRANKLIN
WEST POINT
BALTIMORE
CHICAGO
CINCINNATI
MASSILLON
CARTHAGE
CHATHAM
NORTH WALLOOMSAC
PHILADELPHIA
FORT MADISON
WISCONSIN RAPIDS
WISCONSIN RAPIDS
STEVENS POINT
WISCONSIN RAPIDS
STEVENS POINT
BREWTON
CARTHAGE
CIRCLEVILLE
FERNANDINA BEACH
PHILADELPHIA
SANTA CLARA
TACOMA
VERNON
WABASH
ROCKFORD
CORNWALL
FORNEY
ROCK CITY FALLS
CLAREMONT
CLAREMONT
ERYEGATE
DALTON
DALTON
DALTON
DALTON
DALTON
FITCHBURG
MIDDLETOWN
PORT ANGELES
AURORA
DOWNINGTOWN
JERSEY CITY
AUGUSTA
DETROIT
LOCKPORT
SANLEANDRO
VERNON
COLUMBUS
PORT HURON
BREWER
ROCHESTER
ROCHESTER
STJOHNSBURY
ORANGE
ERVING
TURNERS FALLS
BALTIMORE
AUGUSTA
RIEGELWOOD
State
TX
TX
MI
NC
MN
OH
TN
OH
VA
MD
EL
OH
OH
NY
NY
NY
PA
IA
WI
WI
WI
WI
WI
AL
IN
OH
FL
PA
CA
WA
CA
IN
MI
NY
TX
NY
NH
NH
VT
MA
MA
MA
MA
MA
MA
OH
WA
IL
PA
NJ
GA
MI
NY
CA
CA
OH
MI
ME
NY
NY
VT
TX
MA
MA
OH
GA
NC

A



































































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    A-3

-------
Appendix A




(Continued)
Facility Name

FTOERWEB NORTH AMERICAN INC
MBKB fUKM UUKlf
FILTER MATERIALS - DIVISION OF A. GUSMER
FINCHPRUYN&COINC
FLAMBEAU PAPER
FLETCHER PAPER CO
FLOWER CITY TISSUE MILLS. CO
FONTANA PAPER MILLS INC
FORT HOWARD CORP
FORT HOWARD CORP
FORT HOWARD CORP
FORT ORANGE PAPER CO. INC
FOX RIVER PAPER CO. INC
FRANKLIN BOXBOARD CO.
FRASER PAPER LIMITED
FRENCH PAPER CO
FSC PAPER CO
G E ROBERTSuN & CO
G. S. ROOFING PRODUCTS
GAP BUILDING MATERIALS CORP
GARDEN STATE PAPER CO.
GAYLORD CONTAINER CORP.
GAYLORD CONTAINER CORP.
GEO A WHITING PAPER CO
GEORGIA BONDED FIBERS INC.
GEORGIA PACIFIC CORP - NEKOOS A PAPERS INC
GEORGIA PACIFIC CORP - NEKOOSA PAPERS INC
GEORGIA-PACIFIC CORP
GEORGIA-PACIFIC CORP
UUUKUlA-rAClFlC COKT
GEORGIA-PACIFIC CORP
GEORGIA-PACIFIC CORP
GEORGIA-PACIFIC CORP
GEORGIA-PACIFIC CORP
GEORGIA-PACIFIC CORP
GEORGIA-PACIFIC CORP
GEORGIA-PACIFIC CORP
GEORGIA-PACIFIC CORP
GEORGIA-PACIFIC CORP
.HiUiMJIA-l'ACil'lC CUKT
GEORGIA-PACIFIC CORP
GEORGIA-PACIFIC CORP
OILMAN PAPER COJSt. MARY'S KRAFT DIV.
GLOBE BUILDING MATERIALS INC
GREATNORTHERNPAPERCO
3REAT NORTHERN PAPER CO
3REAT SOUTHERN PAPER CO
GREEN BAY PACKAGING INC
UKUttN BAY PACKACiINCj 1IXU/AKKANSAS KKAJPT JLM V.
GREIF BOARD CORP
GULF STATES PAPER CORP
HALIFAX PAPERBOARD CO INC
HALLTOWN PAPERBOARD CO
HAMMERMILL PAPERS BUSINESS
HAMMERMILL PAPERS BUSINESS
HAMMERMILL PAPERS BUSINESS
HAMMERMILL PAPERS GROUP/RIVERDALE PLANT
HAVERHILL PAPERBOARD CORP.
HENNEPIN PAPER CO
HENRY MOLDED PRODUCTS INC
HOJLUNGSWORTH & VOSE CO.
HOLLINGSWORTH & VOSE CO.
TOLLINGSWORTH & VOSE CO.
HOLLINGSWORTH & VOSE CO.
HULJJWUS WUKTtt & VOSJti CU.
HOMASOTECO
City
VERSAILLES
MILFORD
COLUMBIA Ull Y
WAUPACA
GLENS FALLS
PARK FALLS
ALPENA
ROCHESTER
FONTANA
GREEN BAY
MUSKOGEE
RINCON
CASTLETON-ON-HUDSON
APPLETON
FRANKLIN
MADAWASKA
NILES
ALSO?
HINSDALE
SHREVEPORT
MOBILE
GARFIELD
BOGALUSA
PINE BLUFF
MENASHA
BUENA VISTA
NEKOOSA
PORT EDWARDS
ARDMORE
BELUNGHAM
(JKUSSttlT
DELAIR
FRANKLIN
GARY
KALAMAZOO
MONTICELLO
PALATKA
PLATTSBURGH
PRYOR
TAYLORVILLE
TOLEDO
WOODLAND
ZACHARY
ST. MARY'S
CORNELL
EAST MILLINOCKET
MEilNOCKET
CEDAR SPRINGS
GREEN BAY
MORRILTON
MASSILLON
DEMOPOLIS
ROANOKE RAPIDS
HALLTOWN
ERIE
LOCK HAVEN
OSWEGO
SELMA
HAVERHILL
LITTLE FALLS
LEBANON
EASTWALPOLE
EASTON
GREENWICH
HAWKINSVILLE
WESTGROTON
WTRENTON
State
CT
NJ
IN
WI
NY
WI
MI
NY
CA
WI
OK
GA
NY
WI
OH
ME
MI
IL
NH
LA
AL
NJ
LA
AR
WI
VA
WI
WI
OK
WA
AR
NJ
OH
IN
MI
MS
FL
NY
OK
IL
OR
ME
LA
GA
WI
ME
ME
GA
WI
AR
OH
AL
NC
WV
PA
PA
NY
AL
MA
MN
PA
MA
NY
MY
GA
MA
NJ
Subpart
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    A-4

-------
Appendix A




(Continued)
Facility Name
HOWARD PAPER MILLS INC
HOWARD PAPER MILLS INC
INLAND CONTABffiR CORP.
INLAND CONTAINER CORP.
INLAND CONTAINER CORP.
INLAND CONTAINER CORP.
INLAND EMPIREPAPER CO
INLAND ROME INC
INLAND-ORANGE INC
NTERNATIONAL PAPER CO
INTERNATIONAL PAPER CO
INTERNATIONAL PAPER CO
INTERNATIONAL PAPER CO
INTERNATIONALPAPERCO
INTERNATJONALPAPERCO
iNTBRNATKJNALPAPERCO
INTERNATIONAL PAPER CO
INTERNATIONAL PAPER CO
INTERNATiGNALPAPERCO
INTERNATIONAL PAPER CO
INTERNATIONAL PAPER CO
&JTERNAT1ONALPAPERCO
INTERNATIONAL PAPER CO
INTERNATIONAL PAPER CO/WHITE PAPERS ORP
iNTEHSTATE CONTAINER CORP-INTERCORR DIVISION
INTERSTATE PAPER CORP
nr RAYONIER INC
m- RAYONIER INC
rrr RAYONIER INC
HT RAYONIER INC.- DIVISION GRAYS HARBOR
[VEX CORP.
rVEXCORP.
JACKSON PAPER MFC CO
JAMES RIVER CORP
TAMES RTVER CORP
JAMES RIVER CORP
JAMES RIVER CORP
JAMES RIVER CORP
JAMES RIVER CORP
TAMES RIVER CORP
IAMBS RIVER CORP
JAMES RIVER CORP
JAMES RIVER CORP
JAMES RIVER CORP
JAMES RIVER CORP
JAMES RIVER CORP
JAMES RIVER CORP
JAMES RIVER CORP
JAMES RIVER CORP - CURTIS PAPER DIV
JAMES RIVER CORP - DUNN PAPER DIV
FAMES RIVER CORP -PEPPERELL DIV
FAMES RIVER CORP-FTTCHBURG
[AMES RIVER CORP/BERLIN MILL
JAMES RIVER CORPORATION-PORT HURON MILL
FAMES RIVER EL INC
(AMES RIVER-OTIS
FAMES RIVER-ROCHESTER INC
JAMES RIVER/MDLFORD MILL '
FAMES RIVER/WARREN GLEN MILL
FEFFERSON SMURFTT- INDUSTRIAL PKG DIV
FEFFERSONSMURFrrCORP.
FEFFERSON SMURtir U3RP.
rEFFERSONSMURFlTCORP.
FEFFERSON SMURFTT CORP.
FEFFERSONSMURFrrCORP.
IEFFBRSON SMURFTT PAPERBOARD MILL DIV
KERWIN PAPER CO
City
DAYTON
URBANA
NEWJOHNSONVILLE
NEWARK
NEWPORT
ONTARIO
SPOKANE
ROME
ORANGE
CAMDEN
CORINTH
GARDINER
GKORGKIUWN
JAY
MANSFIELD
MOBILE
MOSS POINT
NATCHEZ
PINE BLUFF
PINEVILLE
REDWOOD
TEXARKANA
TICONDEROGA
BASTROP
READING
RICEBORO
FERNANDINA BEACH
JESUP
PORT ANGELES
HOQUIAM
JOLIET
PEORJA
SYLVA
ADAMS
ASHLAND
CAMAS
CARTHAGE
CLATSKANIE
GOUVERNEUR
GROVETON
HALSEY
KALAMAZOO
OLD TOWN
PARCHMENT
PENNINGTON
RICHMOND
SOUTH GLENS FALLS
WEST LINN
NEWARK
WIGGINS
PEPPERELL
FTTCHBURG
BERLIN
PORT HURON
STFRANCISVILLE
LTVERMORE
ROCHESTER
MILFORD
WARREN GLEN
MONROE
ALTON
CEDARTOWN
JACKSONVILLE
LAFAYETTE
LOCKLAND
MUJLIlJiUjWN
APPLETON
State
OH
OH
TN
CA
IN
CA
WA
GA
TX
AR
NY
OR
sc
ME
LA
AL
MS
MS
AR
LA
MS
TX
NY
LA
PA
GA
FL
GA
WA
WA
IL
IL
NC
MA
WI
WA
NY
OR
NY
NH
OR
MI
ME
MI
AL
VA
NY
OR
DE
MS
MA
MA
NH
MI
LA
ME
MI
NJ
NJ
MI
IL
GA
FL
IN
OH
OH
WI
Subpjiit*
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   A-5

-------
Appendix A




(Continued)
Facility Name
KH1XJHIKAN PULP CO
KJi YhiJ> VIBKU CO
KEYES PURE CO
KUYESJOBKiiCU
KEYES FIBRE CO
KEYES PUtKE CO
tunetfian VAVUK. MILLS iwu
KIMBERLY-CLARK CORP
KIMBERLY-CLARK CORP
KIMBERLY-CLARK CORP
KIMBERLY-CLARK CORP
KIMBERLY-CLARK CORP
KIMBERLY-CLARK CORP
•CIMBERLY-CLARK CORP
KIMBERLY-CLARK CORP
KIMBERLY-CLARK CORP
KIMBERLY-CLARK CORP
KNOWLTON SPECIALTY PAPERS INC
LAKE SUPERIOR PAPER INDUS IKIES
-AKEV1EW MILL
LATEX MILL
LAUREL HILL, VAUUX. cO
LEAF RIVER FOREST PRODUCTS INC
LEATHERS ACK INDUSTRIES
LEATHERBACK INDUSTRIES
JiWISMILL
LINCOLN PULP & PAPER CO INC
LONGVIEW FIBRE CO
LOS ANGELES PAPER BOX AND BOARD MILLS
LGUISlANA-rAClPlC CUKT
LOWE PAPER CO/SIMKINS
AJNIJAY-THAUAKU KUOf IJNtr CO
LYDALLINC
LYDALLINC
LYDALLINC
LYDALLINC
LYDALL MANNING
LYONS FALLS PULP & PAPER INC
M H DIELECTRICS INC
M. JJ. VALENTINE PAeKK CO INC.
MACMUXAN BLOEDEL CORP./PULP * PAPER DIV.
MACON KRAFT INC
MADISON PAPER INDUSTRIES
MANCHESTER BOARD AND PAPER CO., INC
MANISTIQUE PAPERS INC
MANVIIXE FOREST PRODUCTS CORP
MARCAL PAPER MILLS INC
MARTISCO PAPER CO INC
MCINTYRE PAPER CO INC
MEAD COATED BOARD INC
ffiAD CORP - CHILLICOTHE MILL
MEAD CORP - LAUREL MILL
MEAD CORP - WILLOW MILL
MEAD CORP GILBERT PAPER DIVISION
MEAD CORP.
MEAD CORP.
MEAD CORP.
MENASHACORP
MENOMINEE PAPER CO INC
MERRIMAC PAPER CO INC '
MIAMI PAPER
MICHIGAN PAPERBOARD
NDDDLETON PACKAGING INC
MIDDLETOWN PAPERBOARD CO.
MIDTEC PAPER CORP

MOBILE PAPERBOARD CORP.
City
KETCHKAN
ALBERTVILLE
HAMMOND
SACRAMENTO
WATERVILLE
WENATCHEE
BROWNSTOWN
ANCRAM
BEECH ISLAND
COOS A PINES
FULLERTON
T.RR
MEMPHIS
MUNISING
NEENAH
NBWMILFOKD
SPOTSWOOD
WATERTOWN
JJULUTii
NEENAH
BEAVER FALLS
CORDOVA
NEW AUGUSTA
ALBUQERQUE
HOLL1STER
BEAVER FALLS
LINCOLN
LONGVIEW
LOS ANGELES
SAMOA
mLJGEPlKLjJ
SOUTH GATE
COVINGTON
HOOSICK FALLS
MANCHESTER
ROCHESTER
TROY
LYONS FALLS
MOUNT HOLLY SPRINGS
[jOCKPORT
MONTGOMERY
MACON
MADISON
RICHMOND
MANISTIQUE
VEST MONROE
3LMWOODPARK
MARCELLUS
?AYETTEVILLE
PHENKCITY
anmcoTHE
SOUTH LEE
SOUTHLEE
iffiNASHA
2SCANABA
UNGSPORT
STEVENSON
JISEGO
dENOMINEE
.AWRENCE
WESTCARROLLTON
JA1TLE CREEK
:rnr OF INDUSTRY
(ODDLETOWN
HMBERLY
GARWOOD
MOBILE
State
AK
AL
IN
CA
ME
WA
IN
NY
SC
AL
CA
MA
TN
MI
WI
CT
NJ
NY
MN
WI
NY
NC
MS
MM
CA
NY
ME
WA
£A
CA
SJ
^V
TN
MY
^T
>IH
«JY
«Y
?A
^A
AL
3A
HE
VA
rfi
JV
tr
«Y

-------
Appendix A




(Continued)
F«c2itvNime
VK>HAWK PAPER MILLS INC
MOHAWK PAPER MILLS INC
^tUDNOCK PAPER MILLS INC
'dONROB PAPER CO.
'yfOSINEE PAPER CORP
lAtlCKPAPERBOARDCORP.
NATIONAL GYPSUM CO.
NATIONAL OYPSUM CO.
NATK3NALOYPSUMCO.
NBENAHPAPER
NEKOOSA PACKAOINO INC
NEKOOSA PACKAGING INC
NEKOOSA PACKAGING INC
NEKOOSA PAPERS INC
NBWARKATLANTICPAPERBOARD
fteWARKBOXBOARDCO
NEWARK PAPERBOARD CORP
NEWARK SIERRA PAPERBOARD CORP.
NEWMAN AND COMPANY INC
NEWSPR1NTSOUTH INC
NEWTON FALLS PAPER MILL INC
NIAGARA OP WISCONSIN PAPER CORP
NKXDLET PAPER CO.
NORFOLK PAPER CO
StORTH ENDPAPER CO
NVPCO
NVF CORPORATION
OHIO PULP MILLS INC
DRCIIIDS PAPER PRODUC1S CO.
f. H, GLATFELTER CO
P. H. GLATFELTER CO
P. H. GLATFELTER CO/ECUSTA CORP. DIV.
?ABCO PAPER
PACKAGING CO OF CALIFORNIA
PACKAGING CORP. OF AMERICA
PACKAGING CORP. OF AMERICA
PACKAGING CORP. OF AMERICA
PACKAG&
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    A-7

-------
Appendix A




(Continued)
Facility Name
PROCTER & GAMBLE PAPER PRODUCTS CO
PROCTOR & GAMBLE
PROCTOR & GAMBLE CELLULOSE
PROCTOR & GAMBLE CELLULOSE/FLINT RIVER PLANT
PUTNEY PAPER CO INC
QUAKER OATS CO
3UIN-TCORP-NH
3UIN-TCORP-PA
RAND WHITNEY PAPERBOARD CORP.
READING PAPERBOARD CORP
RED HOOK PAPER CO
REPROCELL
REPUBLIC PAPERBOARD CO.
REPUBLIC PAPERBOARD CO.
RHINELANDER PAPER CORP INC
RISING PAPERDIV. OF FOX RIVER PAPER
ROBEL TISSUE MILLS INC
ROCK-TENNCO.
ROCK-TENNCO.
ROCK-TENNCO.
ROCK-TENNCO.
ROCK-TENNCO.
lOCK-TENNCO.
ROCK-TENN CORP.
ROGERS CORP. •
ID WARREN CO
!D WARREN CO
CHOELLER TECHNICAL PAPERS INC
COTT PAPER CO
COTTPAPERCO
iCUTi' PAPER CO
COTTPAPERCO
COTT PAPER CO
COTTPAPERCO
COTTPAPERCO
COTTPAPERCO
EALEDAIR
iEALEDAIR
IEALED AIR CORPORATION
EAMAN PAPER CO OF MASSACHUSETTS INC
IHRYOCK BROTHERS
IIERRATISSUEINC
IIMKINS INDUSTRIES INC.
IIMKINS INDUSTRIES INC.
ilMPLEX PRODUCTS GROUP
UMPUCrrYPATTERNCOINC
IIMPSON PAPER CO
IIMPSON PAPER CO
IIMPSON PAPER CO
IMPSON PAPER CO
IIMPSON PAPER CO
IIMPSON PAPER CO
IMPSON PAPER CO
ilMPSON PASADENA PAPER CO
IMPSON TACOMA KRAFT CO
1MURFTT NEWSPRINT . '
MURFIT NEWSPRINT CORP
VIURFrr NEWSPRINT CORP

ONOCO PRODUCTS OO
ONOCO PRODUCTS CO
ONOCO PRODUCTS CO
Chy
OXNARD
GREEN BAY
PERRY
OGLETHORPE
PUTNEY
PEKIN
TILTON
ERIE
MONTVILLE
READING
RED HOOK
SUN VALLEY
DENVER
HUTCHINSON
RHINELANDER
HOUSATONIC
PRYOR
CHATTANOOGA
CINCINNATI
DALLAS
DELAWARE WATER GAP
LYNCHBURG
DTSEGO
EATON
MANCHESTER
MUSKEGON
WESTBROOK
PULASKI
CHESTER
SVERETT
T EDWARD
MARINETTE
MOBILE
3CONTO FALLS
SKOWHEGAN
OTNSLOW
riODENA
'A1TERSON
JXTON
5ALDWINVILLE
X3WNINGTOWN
•OMONA
SATONSVILLE
•JEW HAVEN
XJNSTATINE
4ILES
ANDERSON
SUREKA
HLMAN
HQUON
•OMONA
UPON
1CKSBURG
ASADENA
•ACOMA
OMONA
IEWBURG
)REGONCnT

JTY OF INDUSTRY
OWNINGTOWN
[ARTSVDLLE
State
CA
WI
FL
GA
VT
DL
NH
PA
CT
PA
NY
CA
CO
KS
WI
MA
DK
TN
DH
TX
?A
VA
va
N
T
M
ME
«Y
?A
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VI
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   A-8

-------
Appendix A




(Continued)
MilyN«me 	 	 	
8ONOCO PRODUCTS CO 	
9ONOOO PRODUCTS CO 	
CONOCO PRODUCTS CO 	 	
SONOCO PRODUCTS CO 	 	 	
SONOCO PRODUCIS CO 	 	 	
9513CCb PRODUCIS CO 	
SONOCO PRODUCIS CO 	 	
SONOCO PRODUCTS CO - BOLTON PLANT 	
5ORO PAPER CO 	 	 	
SOUTHEASTPAPERMPGCO 	 . 	 .
SOUTHWORTHCO 	 	 	
SgAULDINO COMPOSITES CO 	
MOALTYPAPER BOARD 	 	
SPECIALTY PAPER MILLS INC 	 ,
SPECIALTY PAFERBOARD INC. 	
stJOS FOREST PRODUCIS CO 	 	 	
rTATLER TISSUE CO 	 	 	 	 	
STEVENS AND THOMPSONPAPER CO INC 	
yrtMteCOOTAlNERCORP 	 	
TONE CONTAINER CORP 	 . 	
STONE CONTAINER CORP 	 	 	
grONBCONTASreRCORP 	 , 	
STONE CONTAINER CORP 	 	 	
STONE CONTAINER CORP 	 	 	
TONE CONTAINER CORP
TONE CONTAINER CORP 	 	 	
TONE CONTAINER CORP 	 	 	
rfONBCOKrAlNBR CORP/SAVANNAH R1VBRDIV 	
TONE CONTAINER CORPgEMINOLE KRAFT CORP 	
TONE CONTAINER CORP/SNOWPLAKEMILLDIV 	
STRATHMORBPAPERCO.
STRATHMORBPAPERCO. 	 	
STRATHMORBPAPERCO. 	 _
SWBBTWATER PAPER BOARD CO. 	 	 	
rAOSONS PAPERS INC 	
TALLMAN CONDUirCO 	
rAMKO ASPHALT PRODUCTS INC 	
FAMKO ASPHALT PRODUCTS OF KANSAS INC 	
rAMKOASPHALTPRODUCTSOFTENNESSEBINC 	
ffiMPLE-INLAND FOREST PROD. INC 	
TENNESSEE RIVER PULP APAPER 	
TEXQNUSA 	 	 	
THE DEXTER CORP 	 ; 	
rHEWESTONPAPER AND MANUFACTURING CO 	
nflLMANYPULPAPAPERCO. 	 .
US PACKAGING INC 	
OS, PAPER Mms CORP 	
UNION CAMP CORP.
ONION CAMP CORP.
UNION CAMP CORP. 	 _ 	
UNION CAMP CORP. 	 	 . 	
LS GYPSUM CORPORATION
US OYPSUM CORPORATION 	
US OYPSUM CORPORATION 	 	 	
\JS GYPSUM CORPORATION 	
US OYPSUM CORPORATION 	 	
US OYPSUM CORPORATION 	
US PAPER MILLS INC 	 	
USO INDUSTRIES PAPERBOARD CO. 	
VIRGIMA FIBRE CORP 	
WRORACBACO 	
WALDORF CORPORATION t 	 	 	
WALDORF CORPORATION 	
WARD PAPER CO/INTERNATIONAL PAPER 	 	
WAUSAU PAPER MILLS co 	 	
SiS 	 _
HOLYOKE
LANCASTER
MUNROEFALLS
NEWPORT
RICHMOND
ROCKTON
SUMMER
ATLANTA
MIDDLETOWN
DUBLIN
WEST SPRINGFIELD
TONAWANDA
BRATTLEBORO
SANTAFE SPRINGS
SHELDON SPRINGS
PORT ST JOE
AUGUSTA
MIDDLE FALLS
CHOSCHOCTON
FLORENCE
HODGE
HOPEWELL
MKSOULA
ONTONAGON
UNCASVILLE
YORK
PORTWENTWORTH
JACKSONVIT.T.E
SNOWFLAKE
RUSSELL
rURNERS FALLS
WESTFIELD
AUSTELL "
MECHANICVILLE
LOUISIANA
JOPLIN
PHEJJPSBURG
KNOXVILLE
SILSBEE
COUNCE
RUSSELL
WINDSOR LOCKS
TERRE HAUTE
KAUKAUNA
MAXTON
MENASHA
EASTOVER
FRANKLIN
PRATTVILLE
SAVANNAH
CLARK
GALENA PARK
GYPSUM
JACKSONVILLE
NO KANSAS CITY
OAKFIELD
DEPERE
SOUTH GATE
AMHERST
OWENSBORO
BATTLE CREEK
STPAUL
MERRILL
BROKAW
tate
MA
OH
OH
TN
VA
WAT
GA
OH
GA
MA
NY
VT
VT
FL
ME
NY
OH
SC
fA
MT
MI
[CT~
PA
GA
FL
VIA
MA
MA
GA
NY
MO
MO
KS
TN
TX
TN
MA
IN
WI
NC
WI
SC
VA
AL
GA
NJ
TX
OH
FL
MO
NY
wT—
CA
VA
KY
MN
WI
WI
MA


x"
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x
x
x
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x
x
     A-9

-------
                                                             Appendix A

                                                             (Continued)
FacUity Name
WESTFffiLD RIVER PAPER CO INC
wtssrvMuu UJKF
WESTVACOCORP
WESlVAUU 
-------

-------
                    Appendix B




Analytes Included in the Long- and Short-Term Studies

-------

-------
Appendix B consists of two tables that list the analytes that were included in the long- and
short-term studies.  Table B-l h'sts the analytes that are included in methods proposed to
be  used to determine compliance  with proposed  effluent limitations guidelines  and
standards.  Most analytes on Table  B-l were included in the long-term study, although
effluent limitations guidelines have not been proposed for all of them. Table B-2 lists the
analytes included in methods not proposed for determination of compliance.  None of the
analytes listed are proposed for regulation, although most  analytes on Table B-2 were
included in short-term study screening episodes.
                                       B-l

-------
                                  Table B-l

           Analyses Included in Analytical Methods to be Used to
               Determine Compliance With the Proposed Rule
CAS K«ber

3268879
39001020
37871004
38998753
34465468
55684941
36088229
30402154
41903575
55722275
35822469
67562394
39227286
70648269
55673897
57653857
57117449
40321764
57117416
19408743
72918219
60851345
57117314
1746016
51207319

OOKBQn MIM9 ffft ff '

OCTACHLORODIBENZO-P-DIOXIN
OCTACHLORODIBENZOFURAN
TOTAL HEPTACHLORODIBENZO-P-DIOXINS
TOTAL HEPTACHLORODIBENZOFURANS
TOTAL HEXACHLORODIBENZO-P-DIOXINS
TOTAL HEXACHLORODIBENZOFURANS
TOTAL PENTACHLORODIBENZO-P-DIOXINS
TOTAL PENTACHLORODIBENZOFURANS
TOTAL TETRACHLORODIBENZO-P-DIOXINS
TOTAL TETRACHLORODIBENZOFURANS
1,2,3,4,6,7, 8-HEPTACHLORODIBENZO-P-DIOXINS
1,2,3,4,6,7, 8-HEPTACHLORODIBENZOFURAN
1,2,3,4,7, 8-HEXACHLORODIBENZO-P-DIOXIN
1,2,3,4,7, 8-HEXACHLORODIBENZOFURAN
1,2,3,4,7,8, 9-HEPTACHLORODIBENZOFURAN
1,2,3,6,7, 8-HEXACHLORODIBENZO-P-DIOXIN
1,2,3,6,7, 8-HEXACHLORODIBENZOFURAN
1,2,3,7, 8-PENTACHLORODIBENZO-P-DIOXIN
1,2,3,7, 8-PENTACHLORODIBENZOFURAN
1,2,3,7,8, 9-HEXACHLORODIBENZO-P-DIOXIN
1,2,3,7,8, 9-HEXACHLORODIBENZOFURAN
2,3,4,6,7, 8-HEXACHLORODIBENZOFURAN
2,3,4,7, 8-PENTACHLORODIBENZOFURAN
2,3,7, 8-TETRACHLORODIBENZO-P-DIOXIN
2,3,7, 8-TETRACHLORODIBENZOFURAN
tectacigue

HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
'HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
HRGC/HRMS
Method

1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
1613
Miniww
2S&

100
100








50
50
50
50
50
50
50
50
50
50
50
50
50
10
10
• Mb
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10 .
10








5
5
5
5
5
5
5
5
5
5
5
5
5
1
1
25 DIOXIN/FURAN ANALYTES
BRGC - High resolution gas chromatography.
HEMS - High resolution mass speotrometry.
                                      B-2

-------
                                         Table B-l

                                       (Continued)
'
&I& HixnbiKC!
,
Connmn Mama
Chlorinated Phenolics:
106489
87650
120832
88062
95954
58902
87865
16766306
16766317
77102944
2460493
60712449
57057837
2668248
2539175
2138229
3938167
3978674
3428248
32139723
56961207
1198556
19463480
18268763
18268694
76341690
76330068
2539266
4-CHLOROPHENOL
2, 6-DICHLOROPHENOL
2 , 4-DICHLOROFHENOL
2,4, 6-TRICHLOROPHENOL
2,4, 5-TRICHLOROPHENOL
2,3,4, 6-TETRACHLOROPHENOL
FENTACHLOROFHEHOL
4-CHLOROGUAIACOL
4,6, -DICHLOROGUAIACOL
3 , 4-DICHLOROGUAIACOL
4 , 5-DICHLOROGUAIACOL
3,4, 6-TRICHLOROGUAIACOL
3,4, 5-TRICHLOROGUAIACOL
4,5, 6-TRICHLOROGUAIACOL
TETRACHLOROGUAIACOL
4-CHLOROCATECHOL
3 , 6-DICHLOROCATECHOL
3 , 4-DICHLOROCATECHOL
4 , 5-DICHLOROCATECHOL
3,4, 6-TRICHLOROCATECHOL
3,4, 5-TRICHLOROCATECHOL
TETRACHLOROCATECHOL
5-CHLOROVANILLIN
6-CHLOROVANILLIN
5 , 6-DICHLOROVAHILLIN
2-CHLOROSYRINGALDEHYDE
2 , 6-DICHLOROSYRINGALDEHYDE
TRICHLOROSYRINGOL
^
technique

Method

HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
HRGC/LRMS
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
28 CHLORINATED PHENOLIC ANALYTES
TuWOl
<«;/*.>

1.25
2.5
2.5
2.5
2.5
2.5
5.0
1.25
2.5
2.5
2.5
2.5 .
2.5
2.5
5.0
1.25
2.5
2.5
2.5
5.0
5.0
5.0
2.5
2.5
5.0
2.5
5.0
2.5

HRGC — High resolution gas chromatography.
LRMS = Low resolution mass spectrometry.
                                            B-3

-------
                                          Table B-l

                                         (Continued)
CAS Bumbor
Common, Hame
TeqjBiiqpie
*tet*od
MininaMtt Level
<«5/U
Volatile Organics:
107131
71432
7527*
74839
75150
107142
108907
75003
67663
74873
10061015
4170303
124481
74953
60297
107120
97632
100414
74884
78831
108383
80626
75092
1-952
127184
56235
108883
156605
10061026
110576
75252
79016
75694
108054
75014
75343
75354
71556
630206
79005
79345
106934
107062
78875
96184
126998
142289
123911
78933
110758
591786
67641
107186
107028
ACRYLOHITRILE
BENZENE
BROMODICHLOROMETHANE
BROMOMETHANE
CARBON BISULFIDE
CHLOROACETONITRILE
CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
CHLOROMETHANE
CIS-1, 3-DICHLOROPROPENE
CROTONALDEHYDE
DIBROMOCHLOROMETHANE
DIBROMOMETHANE
DIEIHYL ETHER
ETHYL' CYANIDE
ETHYL METHACRYLATE
ETHYLBENZENE
IODOMETHANE
ISOBUTYL ALCOHOL
M-XYLENE
METHYL METHACRYLATE
METHYLENE CHLORIDE
0+P XYLENE
TETRACHLOROETHENE
TETRACHLOROMETHANE (CARBON TETRACHLORIDE)
TOLUENE
TRANS- 1 , 2-DICHLOROETHENE
TRANS- 1, 3-DICHLOROPROPENE
TRANS-1, 4-DICHLORO-2-BUTENE
TRIBROMOMETHANE (BROMOFORM)
TRICHLOROETHENE
TRICHLOROFLUOROMETHANE
VINYL ACETATE
VINYL CHLORIDE
1, 1-DICHLOROETHANE
1 , 1-DICHLOROETHENE
1,1, 1-TRICHLOROETHANE
1,1,1, 2-TETRACHLOROETHANE
1 , 1 , 2-TRICHLOROETHANE
1,1, 2, 2-TETRACHLOROETHANE '
1 , 2-DIBROMOETHANE
1 , 2-DICHLOROETHANE
1 , 2-DICHLOROPROPANE
1,2.3-TRICHLOROFROPANE
1,3-BUTADIENE, 2-CHLORO (CHLOROFRENE)
1, 3-DICHLOROFROFANE
1,4-DIOXANE
2-BUTANONE (METHYL ETHYL KETONE)
2-CHLOROETHYLVINYL ETHER
2-HEXANONE
2-PROPANONE (ACETONE)
2-FROPEN-l-OL (ALLYL ALCOHOL)
2-FROPENAL (ACROLEIN)
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
GCMS
1624
1624
1624
1624
VSRCH
VSRCH
1624
1624
1624
1624
VSRCH
VSRCH
1624
VSRCH
1624
VSRCH
VSRCH
1624
VSRCH
' VSRCH
VSRCH
VSRCH
1624
VSRCH
1624
1624
1624
1624
1624
VSRCH
1624
1624
VSRCH
VSRCH
1624
1624
1624
1624
VSRCH
1624
1624
VSRCH
1624
1624
VSRCH
VSRCH
VSRCH
1624
1624
1624
VSRCH
1624
VSRCH
1624
50
10
10
50
ft
ft
10
50
10
50
ft
•ft
10
ft
50
ft
ft
10
ft
ft
ft
ft
10
ft
10
10
10
, 10
10
ft
10
10
ft
ft
10
10-
10
10
ft
10
10
ft
10
10
ft
ft
ft
50
50
10
ft
50
ft
50
*Mlnimuro levels for compounds analyzed by reverse search have not been calculated.
VRSCH ~ Volatiles reverse search.
GCMS " Gas chromatography mass spectrometry.
                                               B-4

-------
                                           Table B-l

                                          (Continued)
CAS. Sumber
Common: Same
Volatile Organics (Continued):
126987
107051
108101
2-PROPEBEHITRILE, 2-METHYL- (METHACRYLONITRILE )
3-CHLOROPROPENE
4-METHYL-2-PENTANONE
fecfanigue
Method

GCMS
GCMS
GCMS
VSRCH
VSRCH
VSRCH
H2xtll&Uttt
liA««I,
tosft.)

*
*
*
57 VOLATILE ORGANIC ANALYTES
*Minimum levels for compoimds analyzed by reverse search have not been calculated.
VRSCH = Volatiles reverse search.
GCMS - Gas chromatography mass spectrometry.
                                               B-5

-------
 Table B-l



(Continued)
:: • W«*M*
,« '' <&»»»* ****
f
-------
                             Table B-2

Analytes Included in Analytical Methods Used in the
Short-Term  Studies But Not Proposed for Regulation
    CAS Somber
                     Ccranom Same
  Semi-volatile Organics:
  83329
  208968
  98862
  98555
  62533
  137177 .
  120127
  140578
  82053
  108985
  92875
  56553
  50328
  205992
  191242
  207089
  65850
  1689845
  100516
  91598
  92524
  92933
  111911
  111444
  108601
  117817
  85687
  86748
  218019
  77,00176
  7700176
  84742
  117840
  621647
  53703
  132649
  132650
  84662
  131113
  67710
  101848
  122394
  882337
  76017
  62500
  96457
  206440
  86737
  118741
  87683
  77474
  67721
ACENAPHTHENE
ACENAPHTHYLENE
ACETOPHENONE
ALPHA-TERPINEOL
ANILINE
.ANILINE, 2,4,5-TRIMETHYL-
ANTHRACENE
ARAMITE
BENZANTHRONE
BENZENEIHIOL
BENZIDINE
BENZO(A)ANTHRACENE
BENZO(A)PYRENE
BENZO(B)FLUORANIHENE
BENZO(GHI)PERYLENE
BENZO(K)FLUORANTHENE
BENZOIC ACID
BENZONITRILE,  3,5-DIBROMO-4-HYDROXY-
BENZYL ALCOHOL
BETA-NAPHTHYLAMINE
BIPHENYL
BIPHENYL, 4-NITRO
BIS(2-CHLOROETHOXY)METHANE
BISC2-CHLQROETHYL) ETHER
BISC2-CHLOROISOPROPYL) ETHER
BISC2-ETHYLHEXYL) PHIHALATE
BUTYL BENZYL PHTHALATE
CARBAZOLE
CHRYSENE
CIODRIN
CROTOXYPHOS
DY-N-BUTYL PHTHALATE
.DY-N-OCTYL PHTHALATE
DY-N-PROPYLNITROSAMINE
DIBENZO(A,H)ANTHRACENE
DIBENZOFURAN
DIBENZOTHIOPHENE
DIETHYL PHTHALATE
DIMETHYL PHTHALATE
DIMETHYL SULFONE
DIPHENYL ETHER
DIPHENYLAMINE
DIPHENYLDISULFIDE
ETHANE, PENTACHLORO-
ETHYL METHANESULFONATE
ETHYLENETHIOUREA
FLUORANTHENE
FLUORENE
HEXACHLOROBENZENE
HEXACHLOROBUTADIENE
HEXAPHLOROCYCLOPENTADIENE
HEXACHLOROETHANE
                                 B-7

-------
 Table B-2




(Continued)
CAS Btttbfet
' .• n*m*'tii Batta '
-, -V %VI •.v^ V. vTW^ •, •.
S«ai-fft>latilo Organics (Continued):
1888717
142621
193395
78591
120581
475207
569642
72333
91805
66273
124185
629970
112043
112958
630013
544763
924163
55185
62759
86306
10595956
614006
59892
100754
630024
593453
646311
629594
638686
68122
91203
98953
90040
95487
95534
95794
106478
106445
99876
60117
100016
608935
87865
700129
198550
62442
85018
108952
534521
92842
23950585
129000
HEXACHLOROPROPENE
HEXANOIC ACID
INDENOC1, 2, 3-CD)PYRENE
ISOPHORONE
ISOSAFROLE
LONGIFOLENE
MALACHITE GREW
MESTRAHOL
METHAFXRILENE
METHYL METHANESULFONATE
N-DECANE
N-DOCOSANE
H-DODECAHE
N-EICOSABE
N-HEXACOSAHE
N-HEXADECAHE
N-NITROSODI-N-BUTYLAMINE
N-NITSOSODIETHYLAMIBE
N-NITROSODIMETHYLAMmE
H-HITROSODIPHENYLAMINE
N-NITROSOMETHYLETHYLAMINE
N-NITROSOMEIHYLPHENYLAMINE
H-NITROSOMQREHOLINE
N-NITROSOPIPERIDIHE
N-OCTACOSANE
•H-OCTADECANE
N-TETRACOSANE
H-TETRADECAHE
H-TRIACONTANE
H.H-DIMETHYLFORMAMIDE
NAPHTHALENE
NITROBENZENE
0-AHISIDINE
0-CRESOL
0-TOLUIDIHE
0-TOLUIDINE, 5-CHLORO-
P-CHLOROAHILIHE
P-CRESOL
P-CYMEHE
P-DIMETHYLAMINOAZOBENZENE
P-NITROANILISE
PENTACHLOROBENZENE
PENTACHLOROPHEHOL
PENTAMETHYLBENZENE
PERYLEHE
PHEKACETIN
PHEHANTHRENE
PHENOL
PHENOL, 2-METHYL-4,6-DINITRO-
PHENOTHIAZINE
PRONAMIDE
PYRENE
    B-8

-------
                             Table B-2

                           (Continued)
   CAS
                                             H&tao
Semi-volatile Organics (Continued):
110861
108462
94597
7683649
100425
95158
62555
492228
95807
217594
20324338
6914804
108372
121733
1730376
832699
134327
605027
96128
95501
122667
87616
634366
120821
95943
1464535
96231
541731
291214
106467
100254
130154
2243621
615225
91587
95578
2027170
120752
91576
88744
88755
612942
109068
243174
608275
3209221
58902
933755
120832
105679
PYRIDINE
RESORCINOL
SAFROLE
SQUALENE
STYRENE
THIANAPHTHENE
THIOACETAMIDE
THIOXANTHE-9-ONE
TOLUENE, 2,4-DIAMINO-
TRIPHEljrYLENE
TRIFROPYLENEGLYCOL METHYL ETHER
l-BROMO-2-CHLOROBENZENE
l-BROMO-3-CHLOROBENZENE
l-CHLORO-3-NITROBENZENE
1-METHYLFLUORENE
1-METHYLPHENANTHRENE
1-NAPHTHYLAMINE
1-PHENYLHAPHTHALENE
1,2-DIBROMO-3-CHLOROFROPAHE
1,2-DICHLOROBENZENE
1,2-DIPHENYLHYDRAZIHE
1,2,3-TRICHLOROBENZENE
1,2,3-TRIMETHOXYBENZENE
1,2,4-TRICHLOROBENZENE
1,2,4,5-TETRACHLOROBENZENE
1,2,3,4-DIEPOXYBUTAHE
1,3-DICHLDRO-2-PROPANOL
1,3-DICHLOROBENZENE
1,3,5-TRITHlANE
1,4-DICHLOROBENZENE
1,4-DINITROBENZENE
1,4-NAPHTHOQUIHONE
1,5-HAPHTHALENEDIAMINE
2-(METHYLTHIO)BENZOTHIAZOLE
2-CBLORONAPHTHALENE
2-CHLOROPHENOL
2-ISOPROPYLNAPHTALENE
2-METHYLBEHZOTHIOAZOLE
2-METHYLNAPHTHALENE
2-HITROANILINE
2-NITROPHENOL
2-PHENYLHAPHTALEHE
2-PICOLINE
2,3-BENZOFLUORENE
2,3-DICHLOROANILINE
2,3-DICHLORONITROBENZENE
2,3,4,6-TETRACHLOROPHENOL
2,3,6-TRICHLOROPHENOL
2,4-DICHLOROPHENOL
2,4-DIMETHYLPHENOL
                                 B-9

-------
 Table B-2




(Continued)
	 ^tttf^
'• ! + fn-atr-iti kmttt
S«U.-volmtil« Organic! (Continued):
51285
121142
95954
88062
719222
99309
87650
606202
56495
99092
91941
119904
1576676
92671
101553
89634
59507
7005723
100027
101144
203546
99558
57976
2 , 4-DINITROPHENOL
2 , 4-DINITROTOLUENE
2,4, 5-TRICHL0ROPHEHOL
2,4, 6-TRICHLQROEHEHOL
2, 6-DI-TER-BUTYL-P-BENZOQUINONE
2, 6-DICHLORO-4-NIXRDANILINE
2, 6-DICHLOROEHENOL
2 , 6-DINITROTOLUENE
3-MEIHYLCHOLANTHRENE
3-NITROANILINE
3,3' -DICHLOROBENZIDINE
3,3' -DIMETHOJnBEHZIDIHE
3 , 6-DIMETHYLFHEHANTHRENE
4-AMIHOBIPHENYL
4-BROMOPHESYL BHENYL ETHER
4-CHLORO-2-SITROANILIHE
4-CHLORO-3-METHYLPHENOL
4-CHLOROPHENYLEHENYL ETHER
4-NITROEHENOL
4 , 4 ' -METHYLEHEBIS ( 2-CHLOROANILINE )
4,5-METHYLENE PHENANTHRENE
5-HITRO-O-TOLUIDINE
7 , 12-DnffiTHYLBENZ(A)AlITHRACENE
177 SEMI-VOLATILE AHALYTES
    B-10

-------
                            Table B-2

                           (Continued)
Pesticides/Herbicides/PCBs:
94757
309002
319846
2642719
86500
319857
2425061
133062
786196
57749
510156
470906
2921882
56724
7700176
319868
8065483
2303164
333415
62737
141662
60571
60515
78342
298044
1031078
959988
33213659
72208
7421934
53494705
563122
52857
115902
55389
76448
1024573
463736
21609905
58899
121733
72435,
298000
7786347
2385855
6923224
300765
1836755
56382
Acetic Acid (2,4-Dichlorophenoxy)
Aldrin
Alpha-BHC
Azinphos Ethyl
Azinphos Methyl
Beta-EEC
Captafol
Captan
Carbophenothion (Trithion)
Chlordane
Chlorobenzilate
Chlorofenvinphos
Chlorpyrifos
Coumaphos
Crotoxyphos
Delta-BHC
Demeton
Diallate
Diazinon
Dichlorvos
Dicrotophos (Bidrin)
Dieldrin
Dimethoate
Dioxathion
Disulfoton
Endosulfan Sulfate
Endosulfan-I
Endosulfan-II
Endrin
Endrin Aldehyde
Endrin Ketone
Ethion
Famphur
Fensulfothion
Fenthion
Heptachlor
Heptachlor Epoxide
Isodrin
Leptophos
Lindane (Gamma-BBC)
Malathion
Methoxychlor
Methyl Farathion
Mevinphos (Phosdrin)
Mirex
Honoorotophos
Haled (Dibrom)
Nitrofen (Tok)
Parathion
                                B-ll

-------
 Table B-2




(Continued)
CfiSmtabt*
CttMhofc Hap* fr ,r ""'"'"'"
Festic.tdes/Harbicides/ECBs (Continued) :
12674112
11104282
11141165
53469219
12672296
11097691
11096825
82688
298022
732116
13171216
78308
512561
680319
2104645
13071799
961115
3689245
107493
8001352
52686
1582098
117806
88857
93765
93721
72548
72559
50293 ,
PCB-1016
PCB-1221
PCB-1232
PCB-1242
PCB-1248
PCB-1254
PCB-1260
Pentachloronitrobenzene
Fhorato
Fhosmot
Fhosphamidon
Phosphoric Acid, Tri-o-tolyl Ester
Phosphoric Acid, Trimathyl Ester
Phosphoric Triamide, Hexaraethyl-
Santox (Epn)
Torbufos
Tetrachlorvinphos
letraethyldithiopyrophosphate
Tetraethylpyrophosphate
Toxaphene
Trichlorofon
Trifluralin (Treflan)
1,4-Haphthoquinone, 2,3-Dichloro-
2-Sec-Butyl-4 , 6-Dinitrophenol
2,4,5-Iricblorophenoxyacetic Acid
2,4, 5-Tr ichlorophenoxypropionio Acid
4,4'-DDD
4,4'-DDE
4,4'-DDT
78 Pesticide/Herbicide/PCB Analytes
    B-12

-------
                                       Table B-2



                                      (Continued)
CAS Vtrtba?
Metals:
7429905
7440360
7440382
7440393
7440417
7440699
7440428
7440439
7440702
7440451
7440473
7440484
7440508
7429916
7440520
7440531
7440542
7440553
7440564
7440575
7440586
7440600
7440746
7553562
7439885
7439896
7439910
•7439921
7439932
7439943
7439954
7439965
7439976
7439987
7440008
7440020
7440031
7440042
7440053
7723140
7440064
7440097
7440100
7440155
7440166
7440188
7440199
7440202
7782492
7440213
7440224
7440235
7440246
7704349
C™,B*»

ALUMINUM*
ANTIMONY*
ARSENIC*
BARIUM*
BERYLLIUM*
BISMUTH
BORON*
CADMIUM*
CALCIUM*
CERIUM
CHROMIUM*
COBALT*
COPPER*
DYSPROSIUM
ERBIUM
EUROPIUM
GADOLINIUM
GALLIUM
GERMANIUM
GOLD
HAFNIUM
HOLMIUM
INDIUM
IODINE
IRIDIUM
IRON*
LANTHANUM
LEAD*
LITHIUM
LUTETIUM
MAGNESIUM*
MANGANESE*
MERCURY*
MOLYBDENUM*
NEODYMIUM
NICKEL*
NIOBIUM
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
IHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SELENIUM*
SILICON
SILVER*
SODIUM*
STRONTIUM
SULFUR
* Metal to be quantitatively analyzed for all samples.
                                         B-13

-------
                                      Table B-2




                                     (Continued)

*w**te

1 ,\-:;; ^ :*wi£i&* .^^\lLi..t
Metals (Continued):
7440257
13494809
7440279
744&280
7440291
7440304
7440315
7440326
7440337
7440611
7440622
7440644
7440655
7440666
7440677
TANTALUM
TELLURIUM
TERBIUM
THALLIUM*
THORIUM
THULIUM
TIN*
TITANIUM*'
TUNGSTEN
URANIUM
VANADIUM
YTTERBIUM
YTTRIUM*
ZINC*
ZIRCONIUM
69 METAL ANALYTES
* H»t«l tex b« quantitively analyzed for all samples.
                                          B-14

-------
 Table B-2




(Continued)
CAS Tfoa&e*
Comma Hame
Resin Acids:
127275
5835267
1945535
514103
PIMARIC ACID
SANDRACOPIMARIC ACID
ISOPIMARIC ACID
PALUSTRIC ACID
ABIETIC ACID
DEHYDROABIETIC ACID
NEOABIETIC ACID
14-CHLORODEHYDROABIETIC ACID
12-CHLORODEHYDROABIETIC ACID
DICHLORODEHYDROABIETIC ACID
Fatty Acids:
112801
463401
OLEIC ACID
LINOLEIC ACID
Chlorinated Phenolics:
95772
51355
5-CHLOROGUAIACOL
3 , 4-DICHLOROPHENOL
3 , 5-DICHLOROPHENOL
3 , 5-DICHLOROCATECHOL
2,3, 6-TRICHLQROPHENOL
   B-15

-------

-------
                 Appendix C

Ranges of Concentrations and Mass Loadings for
    Priority and Nonconventional Pollutants

-------

-------
Appendix C consists of 18 tables that list either chemical concentrations or mass loadings
of each analyte for which data are available from the long- and short-term studies. Each
table is referenced and briefly summarized in Section 6.4 of this document. Each table has
a main heading of either "Concentrations" or "Loadings" and a subheading that identifies the
sample point category (e.g., Table C-l where Sample Point Category = Process Water).
Some of the subheadings also include abbreviations for subcategory and furnish.  The
abbreviations used are as follows:

       BPK  Bleached Papergrade Kraft Mills
       DK   Dissolving Kraft MiUs
       DS    Dissolving Sulfite Mills
       HW   Hardwood Mills (or lines)
       SW   Softwood Mills  (or lines)

Each table summarizes the following for each analyte:

       •      Number of mills for which a result was obtained;

       •      Number of mills for which the analyte was not detected;

       •      Number of data points available;

       •      Number of data points for which the analyte was not detected;

       •      Units associated with each set of results;

       •      A symbol associated with the minimum value;

       •      The minimum value;

       •      A symbol associated with the maximum value; and

       •      The maximum value.

The symbols indicate in the minimum or maximum value was not detected (symbol = ND),
or whether the review of the  analytical result indicated that the result may have actually
been higher (symbol = >). To determine the minimum and maximum values, the absolute
value of the detected results and the results with > symbols were used (e.g., the maximum
result in the database for an analyte may be shown as ,100 but another value in the database
for this analyte may be > 99).  Data that were excluded from the database because they did
not meet acceptable QA/QC criteria or based upon the engineering review are not included
in the counts on these tables.

-------

-------
                                                            TABLE C-1

                                        LONG-TERM STUDY AND SHORT-TERM STUDY  CONCENTRATIONS
 CHEMICAL  NAME

 2,3.7,8-TETRACHLORODIBENZO-P-DIOXIN
 1,2,3,7,8-PENTACHLORODIBENZO-P-DIOXIN
 1,2,3,4,7.8-HEXACHLORODIBENZO-P-DIOXIN
 1,2,3,6,7,8-HEXACHLORODIBENZO-P-DIOXIN
 1,2,3,7,8,9-HEXACHLORODIBENZO-P-DIOXIN
 1,2,3.4,6,7.8-HEPTACHLORODIBENZO-P-DIOXI
 OCTACHLORODIBENZO-P-DIOXIN
 2,3,7,8-TETRACHLORODIBENZOFURAN
 1,2,3.7,8-PENTACHLOROOIBENZOFURAN
 2,3,4,7;8-PENTACHLORODIBENZOFURAN
 1,2,3,4,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,6,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,7,8,9-HEXACHLORODIBENZOFURAN
 2,3,4,6,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,4,6,7,8-HEPTACHLORODIBENZOFURAN
 1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN
 OCTACHLORODIBENZOFURAN
 4-CHLOROPHENOL
 4-CHLOROCATECHOL
 4-CHLOROGUAIACOL
 S-CHLOROGUAIACOL
 5-CHLOROVANILLIN
 6-CHLOROVANILLIN
 2-CHLOROSYRINGALDEHYDE
 2,4-DICHLOROPHENOL
 2,6-DICHLOROPHENOL
 3,4-DICHLOROPHENOL
 3,5-DICHLOROPHENOL
 3,4-DICHLOROCATECHOL
 3,5-DICHLOROCATECHOL
 3,6-DICHLOROCATECHOL
 4,5-DICHLOROCATECHOL
 3,4-DICHLOROGUAIACOL
 4,5-DICHLOROGUAIACOL
 4,6-DICHLOROGUAIACOL
 5,6-DICHLOROVANILLIN
 2,6-DICHLOROSYRINGALDEHYDE
 2,3,6-TRICHLOROPHENOL
 2,4,5-TRICHLOROPHENOL
 2,4,6-TRICHLOROPHENOL
3,4,5-TRICHLOROCATECHOL
3,4,6-TRICHLOROCATECHOL
3,4,5-TRICHLOROGUAIACOL
3,4,6-TRICHLOROGUAIACOL
4,5,6-TRICHLOROGUAIACOL
TRICHLOROSYRINGOL
2,3,4,6-TETRACHLOROPHENOL
TETRACHLOROCATECHOL
TETRACHLOROGUAIACOL
PENTACHLOROPHENOL
ACRYLONITRILE
BENZENE
BROMODICHLOROMETHANE
BROMOMETHANE
--- SAMPLE POINT CATEGORY NAME=PROCESS WATER
           NO.  OF
 NO. OF     MILLS       NO.  OF
  MILLS  NON-DETECT  DATA POINTS
   20
   11
   11
   11
   11
   11
    8
   20
   11
   11
   11
   11
   11
   11
   11
   11
   10
   16
    9
   16
    7
    9
   18
   16
   17
   20
   11
   11
   16
    5
   10
   19
    9
   20
   19
   20
   16
   11
   20
   19
   19
    9
   20
   16
   20
   20
   20
   19
   17
   19
   20
   20
   20
   20
 18
 11
 11
 11
 11
  9
  4
 15
 11
 11
 11
 11
 11
 11
 10
 11
 10
 16
  9
 16
  7
  9
 18
 16
 17
 20
 11
 11
 16
  5
 10
 19
  9
 20
 19
 20
 16
 11
 20
 T9
 18
  9
 20
 16
20
20
20
 19
 17
 18
20
20
 18
20
 46
 20
 20
 20
 20
 20
 11
 46
 20
 20
 20
 20
 20
 20
 20
 20
 18
 44
 21
 44
 18
 26
 47
 44
 46
 51
 25
 25
 39
 13
 24
 44
 26
 51
 49
 51
 44
 25
 51
 48
 43
 21
 50
44
 51
 52
 51
43
46
49
 51
51
51
51
> WHICH •
10. OF
•DETECTS
44
20
20
20
20
17
7
41
20
20
20
20
20
20
19
20
18
44
21
44
18
26
47
44
46
51
25
25
39
13
24
44
26
51
49
51
44
25
51
48
42
21
50
44
51
52
51
43
46
48
51
51
47
51 .

UNITS
PG/L
PG/L
PG/L
PG/L
P6/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MINIMUM
4.00
3.00
3.00
3.00
5.00
20.00
49.00
5.00
3.00
3.00
3.00
3.00
5.00
5.00
3.00
5.00
11.00
0.25
0.84
0.25
0.50
1.70
0.50
0.50
0.10
0.25
0.25
0.25
1.70
0.50
1.70
1.00
1.70
0.50
0.25
0.50
1.25
0.10
0.25
0.50
0.25
3.40
0.10
0.50
0.25
0.25
0.25
0.25
0.10
0.10
10.00
5.00
5.00
10.00
MAXIMUM
SYMBOL

ND
ND
ND
ND



ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

"ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND

MAXIMUM
13.00
310.00
310.00
310.00
310.00
35.00
310.00
22.00
310.00
310.00
310.00
310.00
310.00
310.00
13.00
310.00
620.00
2.50
2.50
2.50
0.50
5.00
5.00
5.00
5.00
5.00
5.00
5.00
5.00
0.50
5.00
5.00
5.00
5.00
5.00
10.00
10.00
5.00
5.00
5.00
1.57
10.00
5.00
5.00
5.00
5.00
5.00
6.00
6.00
5.80
100.00!
20.00'
15.00
100.00

-------
                    TABLE C-1




LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
.- 	 	 	 	 - 	 SAMPLE POINT CATEGORY NAME=PROCESS WATtK 	 	
(continued)
NO. OF

CHEMICAL HARE
CARBON D1SULFIDE
CHLOROACETOHITRRE
CHLOROBEHZEHE
CHtOROETHANE
CHLOROFORM
CHLOROKETHANE
CIS-1.3-OICHLOROPROPENE
CROTOKALDEHYDE
DIBROHOCHLOROMETHANE
D1BROHOHETHANE
DIETHYL ETHER
ETHYL CYANIDE
ETHYL HETHACRYLATE
ETHYLBENZEHE
ICOOKETHANE
ISOBUTYL ALCOHOL
H-XYLENE
METHYL HETHACRYLATE
HETHYLEHE CHLORIDE
0+P XYLENE
TETRACHLOROETHEHE
TETRACHLOROHETHANE
TOLUENE
TRANS- 1 , 2-D I CHLOROETHENE
TRANS-1 ,3-DICM.OROPROPEHE
TRANS-1,4-DICHLORO-2-BUTENE
TR1BROHOMETHANE
TR1CM.OROETHENE
TRICHLOROFLUOROMETHANE
VIHYL ACETATE
VINYL CHLORIDE
1,1-DICHLOROETHANE
1,1-DlCHLOROETHENE
1,1,1-TR I CHLOROETHANE
1,1,1, 2-TETRACHLOROETHANE
1 , 1 , 2-TRI CHLOROETHANE
1,1,2,2-TETRACHLOROETHANE
1,2-DIBROMOETHANE
1, 2-DI CHLOROETHANE
1,2-DICHLOROPROPANE
1,2,3-TRICHLOROPROPANE
1,3-tUTADIEHE, 2-CHLORO
1,3-DICHLOROPROPANE
1,4-DIOXAHE
2-BUTAKOKE (HEK)
2-CHtOROETHYLVINYL ETHER
2-HEXAHOME
2-PROPAXONE (ACETONE)
2-PROPEN-1-OL
2-PROPEMAL (ACROLEIN)
"Z-PROPEHEHITRILE, 2-HETHYL-
3-CHLOROPROPENE
4-HETHYL-2-PENTANONE
NO. OF
MILLS
19
19
20
20
20
20
19
19
20
19
20
19
19
20
19
19
19
19
19
19
20
20
20
20
20
19
20
20
10
19
20
20
20
20
19
19
20
19
20
20
19
19
19
19
19
20
19
19
19
20
19
19
19
MILLS
NON-DETECT
19
19
20
20
12
19
19
19
20
19
20
19
19
20
19
19
19
19
18
19
20
20
20
20
20
19
20
20
8
19
20
20
20
20
19
19
20 '
19
20
20
19
19
19,
19
17
20
18
15
19
20
19
19
19
NO. OF
DATA POINTS
50
50
51
51
51
51
50
50
51
50
51
50
50
51
50
50
50
50
47
50
50
51
51
51
51
50
51
51
18
50
51
50
51
51
50
49
51
50
51
51
50
50
50 '
48
49
51
50
48
50
51
50
50
50
NO. OF
NON-DETECTS
50
50
51
51
37
50
50
50
51
50
51
50
50
51
50
50
50
50
46
50
50
51
51
51
51
50
51
51
16
50
51
50
51
51
50
49
51
50
51
51
50
50
50
48
47
51
49
43
50
51
50
50
50

UNITS
UG/L
UG/I.
UG/L
UG/L
UG/L
UG/I.
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
'UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
'UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MINIMUM
10.00
10.00
5.00
10.00
10.00
10.00
10.00
50.00
5.00
10.00
10.00
10.00
10.00
5.00
10.00
10.00
10.00
10.00
5.00
10.00
5.00
5.00
5.00
5.00
5.00
50.00
5.00
5.00
10.00
50.00
10.00
5.00
5.00
5.00'
10.00
5.00
5.00
10.00
5.00
5.00
10.00
10.00
10. od
10.00
20.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
50.00
MAXIMUM
SYMBOL
ND
ND
ND
ND


ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
'ND

ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND


ND
ND
ND
ND
ND

MAXIMUM
20.00
20.00
20.00
100.00
105.00
91.03
20.00
100.00
20.00
20.00
100.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
10.57
20.00
20.00
20.00
20.00
20.00
20.00
100.00
20.00
80.00
31.00
100.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
50.00
123.14
20.00
70.11
1029.88
20.00
100.00
20.00
20.00
100.00
•IM

-------
                    TABLE C-1
LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
	 snnrLC ruim LHICLUKI NAnc=KKULCss WAICK — ---- — - — 	 	 	 	 	 — 	 	 --
(continued)


CHEMICAL NAME
ADSORBABLE ORGANIC HALIDES (AOX)
COD
COLOR
ACENAPHTHENE
ACENAPHTHYLENE
ACETOPHENONE
ALPHA-NAPHTHYLAMINE
ALPHA-PICOLINE
ALPHA-TERPINEOL
ANILINE
ANTHRACENE
ARAMITE
B-NAPHTHYLAMINE
BENZANTHRONE
BENZENETHIOL
BENZIDINE
BENZO(A)ANTHRACENE
BENZO(A)PYRENE
BENZO(B)FLUORANTHENE
BENZO(GHI)PERYLENE
BENZO(K)FLUORANTHENE
BENZOIC ACID
BENZYL ALCOHOL
BIPHENYL
BIS (2-CHLOROISOPROPYL) ETHER
BIS(CHLOROMETHYL)ETHERCNR)
BIS(2-CHLOROETHOXY)METHANE
BIS(2-CHLOROETHYL)ETHER
BIS(2-ETHYLHEXYL)PHTHALATE
BUTYL BENZYL PHTHALATE
CARBAZOLE
CHRYSENE
DI-N-BUTYL AMINE
DI-N-BUTYL PHTHALATE
DI-N-OCTYL PHTHALATE
DIBENZOCA, H) ANTHRACENE
DIBENZOFURAN
DIBENZOTHIOPHENE
DICHLORODIFLUOROHETHANE (NR)
DIETHYL PHTHALATE
DIMETHYL PHTHALATE
DIMETHYL SULFONE
DIPHENYL ETHER
DIPHENYLAMINE
DIPHENYLDISULFIDE
ETHANOL
ETHYL METHANESULFONATE
ETHYLENETHIOUREA
ETHYNYLESTRADIOL 3-METHYL ETHER
FLUORANTHENE
FLUORENE
HEXACHLORO-1 ,3-BUTADIENE
HEXACHLOROBENZENE

.NO. OF
MILLS
15
12
9
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
NO. OF
MILLS
NON-DETECT
1
6
9
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
2
3
3
3
3
2
3
3 '
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3

NO. OF
DATA POINTS
36
26
23
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5

NO. OF
NON -DETECTS
2
19
23
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
4
5
5
5
5
4
5
5
4
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5


UNITS
MG/L
MG/L
MG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
0.01
0.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
10.00
20.00
10.00
50,00
10.00
10.00
10.00
10.00'
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00

MAXIMUM
SYMBOL


ND
ND
ND
ND
ND
ND
ND
(ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND

ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
32.20
77.00
25.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
10.00
20.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
15.81
10.00
20.00
10.00
10.00'
10.21
10.00
20.00
21.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00

-------
                    TABLE C-1
LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
... 	 . 	 SAMPLE POINT CATEGORY NAME=PROCESS WATER -- 	 	 	 	
(continued)'


CHEMICAL NAME
HEXACHLOROCYCLOPENTAD I ENE
HEXACHIOROETHANE
HEXACHLOROPROPENE
HEXAHOIC ACID
1NOENO(1,2,3-CD>PYRENE
ISOPHORONE
ISOPROPAHOL
ISOPROPYL ETHER
ISOSAFROLE
LONGIFOLENE
MALACHITE GREEN
HETHAPYRILENE
H€THYL HETHANESULFONATE
H-BOTANOL
H-DECANE (N-C10)
H-DOCOSANE (H-C22)
N-DOOECANE (H-C12)
H-EICOSAHE (H-C20)
H-HEXACOSANE (N-C26)
H-HEXADECAHE (N-C16)
N-H1TR0SC01-N-BUTYLAHINE
H-HITROSODI-H-PROPYLAHINE
N-HITROSODIETHYLAHINE
H-NITROSCOIHETHYIAMINE
N-NITROSODIPHENYLAHINE
N-HITROSOHETHYLETHYLAHINE
N-HITROSOHETHYLPHENYLAHINE
H-HITROSOMORPHOUNE
H-HITROSOPIPERIDIHE
N-OCTACOSANE (H-C28)
H-OCTADECANE (N-C18)
N-PROPANOL
H-TETRACOSANE (M-C24)
H-TETRADECANE (H-C14)
H-TRIACOMTANE (N-C30)
«,H-t>lHeTHYLFORMAHIDE
NAPHTHALENE
NITROBENZENE
O-AHISIDIHE
0-CRESOL
0-TOLUIDINE
P-CRESOL
P-CYHEHE
P-D1HETHYLAHIHOAZ03EMZENE
PEHTACHLOROBEHZENE
PENTACHtOROeTHAHE
PEHTAHETHYLBENZENE
PERYLENE
PHEHACETIN
PHEMANTHRENE
PHENOL
PHENOTH1AZINE
PRON AMIDE

NO. OF
MILLS
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
NO. OF
MILLS
N OH -DETECT
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
2
3
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3

NO. OF
DATA POINTS
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5-
5
S
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5

NO. OF
NON-DETECTS
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
3
5
4
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
NO
NO
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
10.00
10.00
20.00
10.00
20.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
10.00
10.00
20.00
10.00
20.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
21.00
10.00
21.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00
' 10.00
10.00
10.00
10.00
50.00
10.00

-------
                    TABLE C-1





LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS


CHEMICAL NAME
PYRENE
PYRIDINE
SAFROLE
SQUALENE
STYRENE
T-BUTANOL
THIANAPHTHENE
THIOACET AMIDE
THIOXANTHONE
TRIPHENYLENE
TRIPROPYLENEGLYCOL METHYL ETHER
1-METHYLFLUORENE
1-METHYLPHENANTHRENE
1-PHENYLNAPHTHALENE
1 ,2-DIBROMO-3-CHLOROPROPANE
1,2-DICHLOROBENZENE
1,2-DIPHENYLHYDRAZINE
1 ,2,3-TRICHLOROBENZENE
1 ,2,3-TRIMETHOXYBENZENE
1,2,3,4-DIEPOXYBUTANE
1 ,2,4-TRICHLOROBENZENE
1 ,2. 4,5-TETRACHLOROBENZENE
1,3-BENZENEDIOL (RESORCINOL)
1 .3-DICHLORO-2-PROPANOL
1,3-DICHLOROBEHZENE
1,3-DINITROBENZENE
1,3,5-TRITHIANE
1,4-DICHLOROBENZENE
1,4-NAPHTHOQUINONE
1,5-HAPHTHALENEDIAMINE
2-BENZOTHIAZOL
2-BROMOCHLOROBENZENE
2-BUTANOL
2-CHLORONAPHTHALENE
2-CHLOROPHENOL
2- ISOPROPYLHAPHTHALENE
2-METHYL-4 , 6-D I N I TROPHENOL
2-METHYLBEHZOTHIOAZOLE
2-METHYLNAPHTHALENE
2-NITROANILINE
2-NITROPHENOL
2-PHENYLNAPHTHALENE
2,3-BENZOFLUORENE
2,3-DICHLOROANILINE
2,3-DICHLORONITROBENZEHE
2,4-DIAMINOTOLUENE
2,4-D I CHLOROPHENOL
2,4-DIMETHYLPHENOL
2,4-DINITROPHENOL
2,4-DINITROTOLUENE
2,4,5-TRIMETHYLANILINE
2,6-DI-TERT-BUTYL-P-BENZOQINONE
2.6-DICHLORO-4-NITROANILINE

NO. OF
MILLS
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
--- SAMPLE PO.
NO. OF
MILLS
NON-DETECT
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3 '
3
3'
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
INT CATEGORY NAME=PROCESS WATER! 	
(continued)
NO. OF
DATA POINTS
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
•5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
NO. OF
NON-DETECTS
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5

UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MINIMUM
10.00
10.00
10.00
99.00
10.00
10.00
10.00
20.00
20.00
10.00
99.00
10.00
10.00
10.00
20.00
10.00
20.00
10.00
10.00
20.00
10.00
10.00
50.00
10.00
10.00
20.00
50.00
10.00
99.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
99.00
10.00
10.00
50.00
10.00
20.00
99.00
99.00
MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MAXIMUM
10.00
10.00
10.00
99.00
10.00
10.00
10.00
20.00
20.00
10.00
99.00
10.00.
10.00
10.00
20.00
10.00
20.00
10.00
10.00
20.00
10.00 '
10.00
50.00
10.00
10.00
20.00
50.00
10.00
99.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
99.00
10.00
10.00
50.00
10.00
20.00
99.00
99.00

-------
                    TABLE C-1




LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
	 SAMPLE POINT CATEGORY NAHE=PROCESS WATER 	
(continued)


CHEMICAL NAME
2,6-DIMITROTOtUENE
3-BROMOCHLOROBENZENE
3-CHLOROMITROBENZENE
3-HETMYLCHOLANTHRENE
3-WITROAHILIHE
3,3'-DICHLOR08ENZIDINE
3,3'-DIHETHCXYBEMZIDIHE
S.S-DIBROHO^-HYDROXYBENZONITR
3,6-DIHETHYLPHENANTHREHE
4-AHIKOBIPHENYl
4-IROHOPHEHYL PHENYL ETHER
4-CHLORO-2-HnROAMlLINE
4-CHIORO-3-HETHYLPHENOL
4-CHLOROAMIUNE
4-CHU3ROPHEHYL PHEMYL ETHER
4-H1TROAHILINE
4-HITROBIPHEHYL
4-H1TROPHENOL
«,4«-«6THYtEMEBIS(2-CHLOROANI )
4,5-HgTHYtEHEPHEHANTHRENE
5-CHIORO-0-TOLUIDINE
5-HITRO-O-TOLUIDINE
7,12-DIHeTHYLBENZ(A)ANTHRACENE
ALDRIM
AtPHA-BHC
AlPHA-CHLORDANE
AZ1NPHOS-ETHYL
AZINPHOS-HETHYL
BETA-BKC
CAPTAFOt
CAPTAM
CARBOPHEHOTHION
CHIORBEHZILATE
CHtORFEHVINPHOS
CHLORPYRIPHOS
COUHAPHOS
CROTOXYPHQS
DEUA-tHC
DEHETOU
DIALLATE
DIAZINOH
DICHLOFEHTHION
DICHLOWE
DICHLORVOS
DICROTOPHOS
DIELDRIH
DIHETHOATE
D10XATHIOH
OlSUtFOTOH
EHOOSUtFAM I
EHOOSULFAH II
EHDOSULFAH SULFATE
EKORIH

HO. OF
MILLS
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
2
3
3
3
3
3
3
3-
3.
3
3
3
NO. OF
HILLS
NON-DETECT
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
2
3
3
3
3
3
2
3
3
3
3
3

NO. OF
DATA POINTS
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
S
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
1 5
5
5
5
5
5
5
5
5
3
5
5
5
5
5
5
5
5
5
5
5

NO. OF
NON -DETECTS
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
3
5
5
5
5
5
4
5
5
5
5
5


UNITS
UG/L
LIG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
10.00
10.00
50.00
10.00
20.00
50.00
50.00
50.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
10.00
50.00
20.00
10.00
10.00
10.00
10.00
0.10
0.10
0.20
0.20
0.20
0.10
2.00
0.60
2.00
0.20
0.32
0.10
0.20
0.20
0.20
0.20
1.00
0.10
0.50
2.00
0.10
1.44 •
0.10
0.50
0.80
0.10
0.50
0.10
0.40
0.10

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND.
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND


MAXIMUM
10.00
10.00
50.00
10.00
20.00
50.00
50.00
50.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
10.00
50.00
20.00
10.00
10.00
10.00
10.00
0.20
0.20
2.50
1.00
3.00
0.40
5.00
1.00
5.00
4.00
2.50
0.50
1.00
3.00
0.25
1.00
2.00
0.50
0.50
2.50
0.50
2.00
0.30
0.50
1.00
0.50
0.50
0.30
0.50
0.30

-------
                    TABLE C-1
LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
	 SAMPLE POINT CATEGORY NAME=PROCESS WATER 	 - 	
(continued)


CHEMICAL NAME
ENDRIN ALDEHYDE
ENDRIN KETONE
EPN (SANTOX)
ETHION
ETHOPROP
FAMPHUR
FENSULFOTHION
FENTHION
GAHMA-BHC (LINDANE)
GAMMA-CHLORDANE
HEPTACHLOR
HEPTACHLOR EPOXIDE
HEXAMETHYLPHOSPHORAM IDE
ISODRIN
KEPONE
LEPTOPHOS
MALATHION
MERPHOS
METHOXYCHLOR
METHYL PARATHION
METHYL TRITHION
HEVINPHOS (PHOSDRIN)
MIREX
MONOCROTOPHOS
NALED (DIBROM)
NITROFEN (TDK)
P,P'-DDD
P,P'-DDE
P,P'-DDT
PARATHION
PCB 1016
PCB 1221
PCB 1232
PCB 1242
PCB 1248
PCB 1254
PCB 1260
PCNB
PHORATE
PHOSMET
PHOSPHAMIDON
RONNEL
SULFOTEP
SULPROFOS
TEPP
TERBUFOS
TETRACHLORVINPHOS
TOKUTHION
TOXAPHENE
TRICHLORONATE
TRICHLORPHATE
TRICKORPHON
TRICRESYLPHOSPHATE

NO. OF
MILLS
3
3
3
3
2
3
3
3
3
2
3
3
1
3
2
3
3
2
3
3
2
3
3
1
3
1
3
3
3
3
1
1
1
1
1
1
1
3
3
3
3
2
3
2
1
3
3
2
1
1
1
3
1
NO. OF
MILLS
NON-DETECT
3
3
3
3
2
3
• 3
3
3
2
3
3
1
3
2
3
3
2 .
3
3
2
3
3
1
3
1
3
3
3
3
1
1
1
1
1
1
1
3
3
3
3
2
3
2
1
3
3
2
1
1
1
3
1

NO. OF
DATA POINTS
5
5
5
5
3
5
5
5
5
3
5
5
2
5
3
5
5
3
5
5
3
5
5
2
5
2
5
5
5
5
2
2
2
2
2
2
2
5
5
5 •
5
3
5
3
2
5
5
3
2
2
1
5
2

NO. OF
NON-DETECTS
5
5
5
5
3
5
5
5
5
3
5
5
2
5
3
5
5
3
5
5
3
5
5
2
5
2
5
5
5
5
2
2
2
2
2
2
2
5
5
5
5
3
5
3
2
5
5
3
2
2
1
5
2


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
0.25
0.50
0.10
0.10
0.50
0.32
1.00
0.10
0.20
0.20
0.20
0.20
2.50
0.30
2.00
0.10
0.10
0.50
0.50
0.10
0.50
0.10
0.50
1.00
0.32
0.20
0.50
0.50
0.20
0.20
2.00
2.00
2.00
2.00
2.00
2.00
2.00
0.20
0.10
0.20
1.44
0.50
0.10
0.50
0.10
0.10
0.56
0.50
10.00
0.50
0.50
1.00
0.40

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND '
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
0.50
0.50
0.50
0.50
0.50
2.50
3.00
0.50
0.25
0.20
0.20
0.20
2.50
0.50
2.00
0.50
0.50
0.50
1.00
0.50
0.50
0.50
0.50
1.00
1.00
0.20
0.50
0.50
0.40
0.50
2.00
2.00
2.00
2.00
2.00
2.00
2.00
0.20
0.50
1.00
3.00
0.50
0.30
0.50
0.10
0.50
2.50
0.50
10.00
0.50
0.50
1.00
0.40

-------
                    TABLE  C-1

LONG-TERH STUDY AND  SHORT-TERM  STUDY CONCENTRATIONS
(continued)


CHEMICAL HAKE
TRIFIURALIH
TR1H6THYLPHOSPHATE
2,4-D
2,4,5-T
2,4,5-TP (S1LVEX)
ALUHIKUH
ANTIMONY
ARSCHIC
BARIUM
BERYLLIUM
BISHUTH
BORON
CADMIUM
CALCIUM
CERIUM
CHROMIUM
COBALT
COPPER
DYSPROSIUM
ERBIUM
EUROPIUM
GADOLINIUM
GALLIUM
CERHAHIUM
COLD
HAFNIUM
HOLHIHUN
INDIUM
IODINE
IRIDIUK
IRON
LANTHANUM
LEAD
LITHIUM
lUTETIUH
MAGNESIUM
MANGANESE
MERCURY
MOLYBDENUM
KEOOYMIUH
NICKEL
NI08IUH
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCAKOIUH

NO. OF
HILLS
3
1
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
NO. OF
MILLS
NOM-DETECT
3
1
3
3
3
1
3
3
3
3
3
2
3
1
3
3
3
2
3
3
3
3
3
3
3
3
3
3
3
3
1
3
3
3
3
3
1
1
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3

NO. OF
DATA POINTS
5
2
4
5
5
5
5
5
5
5
15
5
5
5
15
5
5
5
15
15
15
15
15
15
15
15
15
15
15
15
5
15
5
15
15
5
5
5
5
15
5
15
15
15
15
15
15
15
15
15
15
15
15

NO. OF
NON-DETECTS
5
2
4
5
5
3
5
5
5
5
15
4
5
3
15
5
5
4
15
15
15
15
15
15
15
15
15
15
15
15
1
15
5
15
15
5
2
2
5
15
5
15
15
15
15
15
15
15
15
15
15
15
15
                                      UNITS

                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                      UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
                                       UG/L
MINIMUM
SYMBOL
NO
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
HD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
HD
ND
ND
ND
ND

MINIMUM
0.50
0.40
0.05
0.04
0.03
90.00
6.00
2.00
4.00
2.00

10.00
5.00
805.00

10.00
25.00
8.00












15.00

50.00


264.00
5.00
0.40
10.00

22.00












MAXIMUM
SYMBOL
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND

ND

ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND


ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND '
ND
ND

MAXIMUM
0.50
0.40
67.00
13.00
13.00
300.00
6.00
20.00
60.00
2.00

1050.00
5.00
12300.00

10.00
25.00
173.00












1340.00

50.00


2110.00
105.00
2.40
10.00

22.00













-------
                    TABLE C-1
LONG-TERH STUDY AND SHORT-TERH STUDY CONCENTRATIONS




CHEMICAL NAME
SELENIUM
SILICON
SILVER
SODIUM
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIN
TITANIUM
TUNGSTEN
URANIUM
VANADIUM
YTTERBIUM
YTTRIUM
ZINC
.ZIRCONIUM



NO. OF
MILLS
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3


NO. OF
MILLS
NON -DETECT
3
0
3
0
2
0
3
3
3
3
3
3
3
3
3
3
3
3
3
1
3
- SAMPLE POINT


NO. OF
DATA POINTS
5
5
5
5
13
5
15
15
15
5
15
15
5
5
15
15
5
15
5
5
15
CATEGORY NAME'
(continued)

NO. OF
NON-DETECTS
5
0
5
2
12
0
15
15
15
5
15
15
5
5
15
15
5
15
5
3
15
                                    UNITS

                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                    UG/L
                                   UG/L
MINIMUM
SYMBOL
ND

ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MINIMUM
3.00
2400.00
6.00
1940.00

2700.00



2.00


30.00
5.00


13.00

5.00
13.00

MAXIMUM
SYMBOL
ND

ND



ND
ND
ND
ND
ND
ND
ND
ND
ND
.HO
NO
ND
ND

ND

MAXIMUM
30.00
17100.00
.6.00
99400.00
200.00
8500.00



26.00


30.00
5.00


13.00

5.00
192.00


-------
                                                           TABLE C-2

                                       LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
                                                                                                                               10
CHEMICAL NAME

2,3,7,8-TETRACW.ORODIBEHZO-P-DIOXIN
1,2,3,7,8-PEHTACHLOROOIBENZO-P-DIOXIN
1,2,3,4,7,8-HEXACHLOROOIBENZO-P-DIOXIN
1,2,3,6,7,S-HEXACHLOROOIBENZO-P-DIOXIN
1,2,3,7,8,9-H£XACHLORODIBENZO-P-DIOXIN
1,2,3,4,6,7,8-HEPTACHLORCOIBENZO-P-DIOXI
OCTACHLOROOIBENZO-P-DIOXIN
2,3,7,8-TETRACHLORODIBENZOFURAN
1,2,3,7,8-PEHTACHLOROOIBENZOFURAM
2,3,4,7,8-PEHTACHLOROOIBENZOFURAN
1,2,3,4,7,8-HeXACHlOROOlBEMZOFURAN
1,2,3,6,7,8-BEXACHLORCOIBENZOFURAN
1,2,3,'7,8,9-HeXACHLOROOIBENZOFURAN
2,3,4,6,7,8-HEXACHlOROOIBENZOFURAN
1,2,3,4,6,7,8-HEPTACHLORCOIBENZOFURAN
1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN
OCTACHLOROOIBEHZOFURAH
4-CHLOROPHEHOt
4-CHLOROGUAIACOl
5-CHLOSOOUAIACOL
6-CHLOfiCVAHILLIH
2-CHLOR03YRINGALDEHYDE
2,4-DICHLOROPHENOL
2,6-DICHLOROPHENOL
3,4-DlCHCOROPHENOt.
3,5-Dlcm.OROPHENOt
3,4"DICHLj3ROCATECHOL
3,5-DICHLOROCATECHOL
3.6-D1CHLOROCATECHOL
4,5-DICHtOROCATECHOt
4.5-DlCHtOROGUAIACOL
4,6-DICHtOROGUAIACOL
5,6-DICHLOROVANILLIN
2,6-DICHLOROSYRINGALDEHYDE
2,3,6-TRICHtOROPHEHOL
2,4,5-TRICW.OROPHEHOL
2,4,6-TRICHtOROPHEHOL
3,4,5-TRlCHLOROCATECHOt
3,4,5-TRICHLOROCUAIACOL
3,4,6-TRICHLOROGUAIACOC
4,5,6-TRICHLOROGUAIACOt
TRICHLOROSYRIHGOL
2,3,4,6-TETRACHLOROPHENOL
TEIRACHLOROCATECHOL
TETRACHLOROGUAIACOL
PEMTACHlOROPHeNOL
ACSYLOMITRILE
BEHZEHE
BROHCOICHLOROHETHANE
8ROHOHETHANE
CARSOH  DISULFIDE
CHIOROACETOHITRILE
CW.OR08EHZEHE
CHIOROETHANE
:ATEGORY
NO. OF
MILLS
8
8
8
8
8
8
4
8
8
8
8
8
8
8
8
8
7
5
5
5
6
5
6
8
8
8
5
4
1
8
8
7
8
5
8
8
7
7
8
5
8
8
8
8
6
8
8
8
8
8
8
8
8
8
NAME=BROWN
NO. OF
MILLS
NON-DETECT
7
8
8
8
8
6
1
5
8
8
8
8
8
8
7
8
5
3
4
5
5
5
4
8
7
7
5
3
1
7
8
6
7
5
7
7
6
6
5
4
6
8
8
8
5
8
8
7
7
8
7
8
8
8
STOCK WASHING
NO. OF
DATA POINTS
13
13
13
13
13
11
7
13
13
13
13
13
13
13
12
13
12
18
18
17
17
17
21
22
22
22
18
15
^
22
23
20
23
17
22
23
20
20
23
18
23
23
23
22
21
23
23
23
23
23
23
23
23
23
UASTEUATEK S
NO. OF
NON-DETECTS
12
13
13
13
13
7
1
9
13
13
13
13
13
13
11
13
10
12
15
17
16
17
16
22
21
21
18
13
3
21
23
19
21
17
21
20
17
18
17
17
18
23
23
22
18
23
23
21
20
23
22
23
23
23
UBCATEG

UNITS
P6/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
ORY=BPK •
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
3.00
2.00
7.00
8.00
5.00
18.00
110.00
5.00
2.00
5.00
3.00
2.00
3.00
3.00
4.00
5.00
9.00
0.25
0.25
0.50
0.50
0.50
0.10
0.25
0.25
0.25
2.50
0.50
5.00
1.00
0.50
0.25
0.50
1.25
0.10
0.25
0.50
0.30
0.10
0.50
0.25
0.25
0.25
0.25
0.10
0.10
50.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00

MAXIMUM
SYMBOL

ND
ND
ND
ND



ND
ND
ND
ND
ND
ND

ND
'


ND

ND

ND


ND

ND

ND


ND







ND
ND
ND

ND
ND


ND

ND
ND
ND


MAXIMUM
76.00
385.00
294.00
263.00
69.00
210.00
2100.00
210.00
455.00
455.00
294.00
294.00
294.00
278.00
53.00
333.00
260.00
17.00
91.00
5.00
31.00
5.00
30.00
5.00
1.70
2.00
25.00
12.20
5.00
14.00
5.00
1.70
57.00
13.00
2.00
4.00
16.00
19.00
250.00
14.00
49.00
5.00
5.00
5.00
45.00
5.00
500.00
13.00
11.00
500.00
52.00
100.00
100.00
500.00

-------
                                                         TABLE  C-2

                                     LONG-TERM STUDY AND  SHORT-TERM STUDY CONCENTRATIONS
rr
 CHEMICAL NAME

 CHLOROFORM
 CHLOROMETHANE
 CIS-1,3-DICHLOROPROPENE
 CROTONALDEHYDE
 DIBROMOCHLOROMETHANE
 DIBROMOMETHANE
 DIETHYL ETHER
 ETHYL CYANIDE
 ETHYL METHACRYLATE
 ETHYLBENZENE
 IOOOMETHANE
 ISOBUTYL ALCOHOL
 M-XYLENE
 METHYL METHACRYLATE
 METHyLENE CHLORIDE
 0+P XYLENE
 TETRACHLOROETHENE
 TETRACHLOROMETHANE
 TOLUENE
 TRANS-1,2-DICHLOROETHENE
 TRANS-1,3-DICHLOROPROPENE
 TRANS-1,4-DICHLORO-Z-BUTENE
 TRIBROMOMETHANE
 TRICHLOROETHENE
 TRICHLOROFLUOROMETHANE
 VINYL ACETATE
 VINYL CHLORIDE
 1,1-DICHLOROETHANE
 1,1-DICHLOROETHENE
 1,1,1-TRICHLOROETHANE
 1,1,1,2-TETRACHLOROETHANE
 1,1,2-TRICHLOROETHANE
 1,1,2,2-TETRACHLOROETHANE
 1,2-DIBROMOETHANE
 1,2-DICHLOROETHANE
 1,2-DICHLOROPROPANE
 1,2,3-TRICHLOROPROPANE
 1,3-BUTADIENE, 2-CHLORO
 1,3-DICHLOROPROPANE
 1,4-DIOXANE
 2-BUTANONE (MEK)
 2-CHLOROETHYLVINYL  ETHER
 2-HEXANONE
 2-PROPANONE (ACETONE)
 2-PROPEN-1-OL
 2-PROPENAL (ACROLEIN)
 2-PROPENENITRILE, 2-METHYL-
3-CHLOROPROPENE
4-METHYL-2-PENTANONE
ADSORBABLE ORGANIC  HALIDES  (AOX)
COD
ACENAPHTHENE
ACENAPHTHYLENE
. n i i*r\ 1 1.

NO. OF
MILLS
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
6
8
8
8
8
8
8
8
8
7
8
8
7
8
8
8
8
8
5
8
2
2
.uwrv i nMi'it— on
NO. OF
MILLS
NON-DETECT
3
8
8
8
8
8
8
8
8
8
8
8
7
8
5
8
8
8
8
8
8
8
8
8
7
8
8
8
8
8
8
6
8
8
8
8
8
8
8
8
2
8
8
0
8
8
8
8
8
.0
2
2
2
.uwn o i UI.N. WMO
(continued)

NO. OF
DATA POINTS
23
23
23
23
23
23
23
23
23
23
23
23
23
23
22
23
23
23
23
23
23
23
23
23
19
23
23
23
23
23
23
21
23
23
23
23
23
23
23
23
22
23
23
22
23
23
23
23
23
18
23
2
2
ninu wnaiewH

NO. OF
NON-DETECTS
9
23
23
23
23
23
23
23
23
23
23
23
22
23
14
23
23
23
23
23
23
23
23
23
18
23
23
23
23
23
23
21
23
23
23
23
23
23
23
23
8
23
23
8
23
23
23
23
23
0
2
2
2
ICK SUOL


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L '
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
MG/L
MG/L
UG/L
UG/L
HICljUKT-H

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
:PK 	


MINIMUM
10.00
50.00
10.00
50.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
50.00
50.00
10.00
50.00
10.00
10.00
50.00
0.20
15.00
10.00
10.00


MAXIMUM
SYMBOL

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND
ND
ND

ND t
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND
ND
ND
ND


ND
ND



MAXIMUM
1383.00
500.00
100.00
500.00
100.00
100.00
500.00
100.00
100.00
100.00
100.00
100.00
12.00
100.00
9152.00
100.00
100.00
100.00
100.00
100.00
100.00
500.00
100.00
iod.oo
107.00
500.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
864.00
100.00
500.00
6514.00
100.00
500.00
100.00
100.00
500.00
80.00
12000.00
10.00
10.00

-------
                                                           TABLE C-2

                                       LONG-TERM STUDY AND  SHORT-TERM  STUDY CONCENTRATIONS
                                                                                                                              12
CHEMICAL HAKE

ACETOPHEHONE
ALPKA-HAPHTHYLAHINE
AlPKA-PlCOtlNE
ALPRA-TERPINEOL
AHILIHE
AHTHRACENE
ARAH1TE
8-KAPHTHYLAH1NE
8ENZAHTHRONE
BEHZENETHIOL
BEN2IDIKE
BEMZO(A>AHTKRAGENE
BEHZO
8IS(Z-CHLOROETHOXY)HETHANE
BIS(2-CHLOROETHYL)ETHER
B1S(2-ETHYLHEXYL)PHTHALATE
BUTYL BENZYL PHTHALATE
CARBAZOLE
CKSYSEME
DI-H-BUTYL AHINE
Dl-N-BUTYL PHTHALATE
DI-H-OCTYL PHTHALATE
DIBEHZOCA,H)ANTHRACENE
DIBENZOFURAH
D1BENZOTHIOPHENE
DICHLORCOJFLUOROHETHANE (NR)
DIETHYL PHTHALATE
DIMETHYL PHTHALATE
DIHETHYL SULFOME
DIPHEHYL ETHER
DIPHEHYLAWME
DIPHENYLDISUtFIDE
ETHAHOL
ETHYL HETHANESULFOHATE
ETHYLEHETHIOUREA
ETHYHYLESTRADIOL 3-HETHYL ETHER
FLU08AHTHENE
FLUORENE
HEXACHLORO-1,3-BUTADIENE
HEXACH10ROBEHZEHE
HEXACHLOROCYCLOPENTADIENE
HEXACHtOROETHAHE
HEXACHLOROPROPENE
HEXAHOIC ACID
 IKOEHO<1,2,3-CD)PYRENE
• POINT CATEGORY NAME=

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
HILLS
NON-DETECT
2
2
2
0
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
1
2
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
=BROWN STOCK WASHING WASTEWATER SUBCATEGORY=BPK. 	 - 	
(continued)

NO. OF
DATA POINTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
NON-DETECTS
2
2
2
0
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
1
2
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
10.00
10.00
50.00
112.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
10.00
20.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00

MAXIMUM
SYMBOL
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NP
ND
ND
ND

ND
ND

ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
10.00
10.00
50.00
454.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
1
10.00
10.00
20.00
10.00
50.00
10.00
53.00
10.00
10.00
30.00
10.00
28.00
10.00
20.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00

-------
                                                          TABLE C-2
                                                                                                                              13
                                      LONG-TERM STUDY AMD SHORT-TERM STUDY CONCENTRATIONS
 CHEMICAL NAME

 ISOPHORONE
 ISOPROPANOL
 ISOPROPYL ETHER
 ISOSAFROLE
 LONGIFOLEME
 MALACHITE GREEN
 METHAPYRILENE
 METHYL METHANESULFONATE
 N-BUTANOL
 N-DECANE (N-C10)
 N-DOCOSANE (N-C22)
 N-DODECANE (N-C12)
 N-EICOSANE (N-C20)
 N-HEXACOSANE (N-C26)
 N-HEXADECANE (N-C16)
 N-NITROSCOI-N-BUTYLAMINE
 N-NITROSODI-N-PROPYLAMINE
 N-NITROSODIETHYLAMINE
 N-NITROSODIMETHYLAMINE
 N-NITROSODIPHENYLAMINE
 N-NITROSOMETHYLETHYLAMINE
 N-HITROSOMETHYLPHENYLAMINE
 N-NITROSOMORPHOLINE
 N-NITROSOPIPERIDINE
 N-OCTACOSANE (N-C28)
 N-OCTADECANE (N-C18)
 N-PROPANOL
 N-TETRACOSANE  (N-C24)
 N-TETRADECANE  (N-C14)
 N-TRIACONTANE  (N-C30)
 N,N-DIMETHYLFORMAMIDE
 NAPHTHALENE
 NITROBENZENE
 0-ANISIDINE
 0-CRESOL
 0-TOLUIDINE
 P-CRESOL
 P-CYMENE
 P-DIMETHYLAMINOAZOBENZENE
 PENTACHLOROBENZENE
 PENTACHLOROETHANE
 PENTAMETHYLBENZENE
 PERYLENE
 PHENACETIN
 PHENANTHRENE
 PHENOL
PHENOTHIAZINE
PRONAMIDE
PYRENE
PYRIDINE
SAFROLE
SQUALENE
STYRENE
(continued)

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON -DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
0
2
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
1
2

NO. OF
DATA POINTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
NON-DETECTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
0
2
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
1
2


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
27.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
99.00
10.00

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND'
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND

ND


MAXIMUM
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
31.00
10.00
10.00
10.00
20.00
20.00
20.00
33.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
150.00
•10.00

-------
                                                           TABLE C-2

                                       LONG-TERM STUDY AND  SHORT-TERM STUDY CONCENTRATIONS
                                                                                                                              14
CHEMICAL HAHE

T-BUTAHOt
THIANAPHTHENE
THIQACETAH1DE
THIQXANTHONE
TR1PHEHYLENE
TRIPROPYLENEGLYCOL METHYL ETHER
1-KeTHYLFLUORENE
1-HETHYLPHEHAMTHRENE
1-PHEHYLHAPHTHALENE
1.2-D1BROMO-3-CHLOROPROPANE
1,2-DICHLOROBEH2ENE
1,2-DlPHEHYLHYDRAZIHE
1,2,3-TRICHIOROBENZENE
1,2,3-TRlHETHOXYBENZENE
1,2,3,4-DIEPOXYBUTANE
1,2,4-TRICHLOROeENZENE
1,2,4,5-TETRACHLOROBENZENE
1,3-BE«ZENEDICt (RESORCINOL)
1.3-DICHLORO-2-PROPANOL
1,3-DICHLOROBENZENE
1,3-DIHITROBENZENE
1,3,5-TRITHIANE
1,4-DlCHLOROeENZENE
1,4-HAPHTHOQUINONE
1,5-MAPHTHALENEOIAHINE
2-(HETHYUTHlO)BENZOTHIAZOL
2-SROHOCHtOROBENZENE
2-BUTAHOL
2-CHLORONAPHTKALENE
2-CW.OROPHENOt
2- ISOPROPYLNAPHTHALENE
2-HETHYL-4.6-DINITROPHENOL
2-KETHYLBEHZOTHIOAZOLE
2-HETHYLHAPHTHALENE
2-HITROANILINE
2-HITROPHENOC
2-PKEHYLHAPHTHALENE
2,3-BEHZOFLUORENE
2,3-DICHLOROAMILlNE
2,3-DICHLOROWITROBENZENE
2,4-DIAHIHOTOLUENE
2,4-DlCHlOROPHENOl.
2,4-DlHETHYLPHENOt
2,4-DlHITROPHENOl.
2,4-DlHlTROTCtUENE
2,4,5-TRlHETHYLANlLINE
 2,6-DI-TERT-Blim-P-BENZOQINONE
 2,6-DlCHLORO-4-NITROANILINE
 2,6-DIHITROTOUOE
 3-BROMOCHLOR06ENZENE
 3-CHLOROMITROeENZENE
 3-HCTMYLCHOtAMTHRENE
 3-H1TROAMILINE
[ POINT CATEGORY NAME=BROWN STOCK WASHING WASTEWATER SUBCATEGOKY=Bl'K. 	
(continued)

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON-DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
,2
~2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
DATA POINTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
NON-DETECTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
10.00
10.00
20.00
20.00
10.00
99.00
10.00
10.00
10.00
20.00
10.00
20.00
10.00
10.00
20.00
10.00
10.00
50.00
10.00
10.00
20.00
50.00
10.00
99.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
99.00
10.00
10.00
50.00
10.00
20.00
99.00
99.00
10.00
10.00
50.00
10.00
20.00

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
10.00
10.00
20.00
20.00
10.00
99.00
10.00
10.00
10.00
20.00
10.00
20.00
10.00
10.00
20.00
10.00
10.00
50.00
10.00
10.00
20.00
50.00
10.00
99.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
99.00
10.00
10.00
50.00
10.00
20.00
99.00
99.00
10.00
10.00
50.00
10.00
20.00

-------
                                      /                      TABLE C-2
                                     /   LONG-TERM  STUDY AND SHORT-TERM STUDY CONCENTRATIONS
15
                              SAMPL!
  CHEMICAL NAME

  3,3'-DICHLOROBENZIDINE
  3,3'-DIMETHOXYBENZIDINE
  3.5-DIBROMO-4-HYDROXYBENZONITR
  3,6-DIMETHYLPHENANTHRENE,'
  4-AMINOBIPHENYL
  4-BROMOPHENYL PHENYL ETHER
  4-CHLORO-2-NITROANILINE
  4-CHLORO-3-METHYLPHENOL
  4-CHLOROANILINE
 4-CHLOROPHENYL PHENYL 'ETHER
 4-NITROANILINE
 4-NITROBIPHENYL
 4-NITROPHENOL
 4,4'-METHYLENEBIS(2-CHLOROANI)
 4,5-METHYLENEPHENANTHRENE
 5-CHLORO-O-TOLUIDINE
 5-NITRO-O-TOLUIDINE
 7,12-DIMETHYLBENZ(A)ANTHRACENE
 ALUMINUM
 ANTIMONY
 ARSENIC
 BARIUM
 BERYLLIUM
 BISMUTH
 BORON
 CADMIUM
 CALCIUM
 CERIUM
 CHROMIUM
 COBALT
 COPPER
 DYSPROSIUM
 ERBIUM
 EUROPIUM
 GADOLINIUM '
 GALLIUM  /
 GERMANIUM
 GOLD
 HAFNIUM
 HOLMINUM
 INDIUM
 IODINE
 IRIDIUH
 IRON
 LANTHANUM
 LEAD
 LITHIUM
 LUTETIUM
MAGNESIUM
MANGANESE
MERCURY
MOLYBDENUM
NEODYMIUM
(continued)

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2'
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF'
MILLS
NON -DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
'o
2
2
1
2
2
0
2
1
2
1
2
1
2
2
2
2
2
2
2
2
2
2
2
2
0
2
2
2
2
1
0
1
1
2
/
NO. OF
DATA POINTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
6
2
2
2
6
2
2
2
6
6
6
6
6
6
6
6
6
6
6
6
2
6
2
6
6
2
2
2
2
6

NO. OF
NON-DETECTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
0
2
2
1
2
6
0
2
1
6
1
2
1
6
6
6
6
6
6
6
6
6
6
6
6
0
6
2
6
6
1
0
1
1
6


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
IIG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
NO
ND /
ND
ND
ND
ND
ND
,' ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
- ND

ND
ND
ND
ND
ND

ND
ND
ND


MINIMUM
50.00
50.00
50.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
10.00
50.00
20.00
10.00
10.00
10.00
10.00
356.00
6.00
2.00
19.00
2.00

151.00
5.00
2670.00

10.00
25.00
16.00












383.00

50.00


1040.00
29.00
2.00
10.00


MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND

ND

ND

ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND




NO


MAXIMUM
50.00
50.00
50.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
10.00
50.00
20.00
10.00
10.00
10.00
10.00
6250.00
6.00
20.00
232.00
2.00

199.00
5.00
289000.00

22.00
25.00
50.00












5040.00

50.00


10100.00
1540.00
4.20
54.00


-------
                               TABLE C-2

           LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS

SAMPLE POINT CATEGORY NAME=BROWN STOCK WASHING WASTEUATER SUBCATEGORY=BPK
                                                                                                   16


CHEMICAL NAME
NICKEL
HIOSIUH
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SELENIUM
SILICON
SILVER
SODIUM
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIM
T1TAHIUH
TUMGSTEH
UBAHIUH
VANADIUM
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
oAnruc ruiNi
NO. OF
MILLS
NON-DETECT
2
2
2
2
1
2
0
2
2
2
2
2
2
2
0
2
0
1
0
2
2
2
2
2
2
2
1
2
2
0
2
2
0
2
Uftl CUWIM nrwtL.— L»
NO. OF
DATA POINTS
2
6
6
6
4
6
•2
6
6
6
6
6
6
2
2
2
2
4
2
6
6
6
2
6
6
2
2
6
6
2
6
2
2
6
(continued:
NO. OF
NON-DETECTS
2
6
6
6
3
6
0
6
6
6
6
6
6
2
0
2
0
3
0
6
6
6
2
6
6
2
1
6
6
0
6
2
0
6
                                             UNITS

                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
MINIMUM
SYMBOL

  ND
  ND
  ND
  ND
  ND
  ND

  ND
  ND
  ND
  ND
  ND
  ND
  ND

  KID

  ND

  ND
  MD
  HD
  MD
  HD
  (ID
  ND
  »D
  »D
  IID

  HD
  ND

  ND
SORY=BPK 	
MINIMUM
22.00





9700.00






3.00
5900.00
6.00
1130000.00

111000.00



20.00


30.00
5.00


64.00

5.00
93.00
MAXIMUM
SYMBOL
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

ND



ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND


MAXIMUM
22.00



1300.00

11100.00






30.00
7800.00
6.00
1440000.00
200.00
1010000.00



20.00


30.00
94.00


131.00

5.00
159.00
ND

-------
                                                             TABLE C-3

                                        LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
17
 CHEMICAL NAME

 2,3,7,8-TETRACHLORODIBENZO-P-D10XIN
 1,2,3,7,8-PENTACHLORODIBENZO-P-DIOXIN
 1,2,3,4,7,8-HEXACHLORODIBENZO-P-DIOXIN
 1,2,3,6,7.8-HEXACHLORODIBENZO-P-DIOXIN
 1,2.3,7,8,9-HEXACHLOROD1BENZO-P-DIOXIN
 1,2,3,4,6,7,8-HEPTACHLORODIBENZO-P-DIOXI
 OCTACHLORODIBENZO-P-DIOXIN
 2,3,7,8-TETRACHLORODIBENZOFURAN
 1,2,3,7,8-PENTACHLORODIBENZOFURAN
 2,3,4,7,8-PENTACHLORODIBENZOFURAN
 1,2,3,4,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,6,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,7,8,9-HEXACHLOROOIBENZOFURAN
 2,3,4,6,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,4,6,7,8-HEPTACHLORODIBENZOFURAN
 1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN
 OCTACHLORODIBENZOFURAN
 4-CHLOROPHENOL
 4-CHLOROCATECHOL
 4-CHLOROGUAIACOL
 5-CHLOROGUAIACOL
 5-CHLOROVANILL1N
 6-CHLOROVAMILLIN
 2-CHLOROSYRINGALDEHYDE
 2,4-DICHLOROPHENOL
 2,6-DICHLOROPHENOL
 3,4-DICHLOROPHENOL
 3,5-DICHLOROPHENOL
 3,4-DICHLOROCATECHOL
 3,5-DICHLOROCATECHOL
 3,6-DICHLOROCATECHOL
 4,5-DICHLOROCATECHOL
 3,4-DICHLOROGUAIACOL
 4,5-DICHLOROGUAIACOL
 4,6-DICHLOROGUAIACOL
 5,6-DICHLOROVANILLIN
 2,6-DICHLOROSYRINGALDEHYOE
 2,3,6-TRICHLOROPHENOL
 2,4,5-TRICHLOROPHENOL
 2,4,6-TRICHLOROPHENOL
 3,4,5-TRICHLOROCATECHOL
 3,4,6-TRICHLOROCATECHOL
3,4,5-TRICHLOROGUAIACOL
 3,4,6-TRICHLOROGUAIACOL
 4,5,6-TRICHLOROGUAIACOL
 TRICHLOROSYRINGOL
 2,3,4,6-TETRACHLOROPHENOL
 TETRACHLOROCATECHOL
TETRACHLOROGUAIACOL
PENTACHLOROPHENOL
ACRYLONITRILE
BENZENE
BROMODICHLOROMETHANE
BROMOMETHANE
.« I CUUK 1
NO. OF
MILLS
10
10
10
10
10
10
5
10
10
10
10
10
10
10
10
10
9
7
3
7
4
3
9
7
8
10
7
7
7
4
4
10
3
10
9
10
7
7
10
10
10
3
10
7
10
10
10
10
8
10
10
10
10
10
NHP1C— MU1U a
NO. OF
MILLS
NON -DETECT
7
9
10
9
10
5
2
5
10
10
10
10
10
10
10
10
8
1
1
6
3
1
1
2
2
5
7
6
3
2
0
3
3
3
7
6
3
5
9
2
4
1
6
7
7
2
7
1
8
9
10
9
8
10
IHUC I-1LIKHIC
NO. OF
DATA POINTS
81
19
19
19
19
19
8
81
19
19
19
19
19
19
19
19
17
84
60
79
12
72
86
80
90
93
21
21
74
12
69
86
68
91
79
89
81
21
91
91
81
61
88
80
89
89
87
81
90
93
93
92
92
93
5UBl.HltbUKT:
NO. OF
NON-DETECTS
78
18
19
18
19
13
5
69
19
19
19
19
19
19
19
19
16
46
32
73
11
69
12
47
65
85
21
19
38
6
41
40
68
22
76
84
67
17
88
28
36
43
83
80
85
49
83
58
90
91
93
91
71
93
-Off. I-UK

UNITS
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
'PG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
N15H=HW -
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
2.00
3.00
3.00
3.00
5.00
10.00
94.00
2.00
3.00
3.00
3.00
3.00
3.00
3.00
2.00
2.00
5.00
0.30
1.20
0.30
0.50
2.50
0.50
0.50
0.10
1.60
0.30
0.30
2.50
5.00
2.50
1.00
2.50
0.50
0.30
0.50
1.30
1.00
0.30
0.50
0.30
2.60
0.10
0.50
0.30
2.50
0.30
0.30
0.10
0.10
50.00
10.00
10.00
50.00

MAXIMUM
SYMBOL


ND

ND



ND
ND
ND
ND
ND
ND
ND
ND






>
>


ND




>
ND










ND




ND

ND


ND


MAXIMUM
40.00
10.00
54.30
3.00
54.30
61.00
400.00
220.00
54.30
54.30
54.30
54.30
54.30
54.30
54.30
54.30
140.00
33.00
350.00
4.80
9.00
15.00
50.00
50.00
26.00
21.00
5.00
21.00
410.00
98.00
130.40
266.70
5.00
82.00
23.20
34.00
20.84
5.20
41.00
50.00
170.00
21.00
12.19
10.00
6.73
16.00
2.22
57.00
10.00
5.96
500.00
3156.60
332.90
500.00

-------
                    TABLE C-3





LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
                                                                                         18
	 SAMPLE POINT CATEGORY NAME=ACID STAGE FILTRATE SUBCATEGORT=BPK FURNISH=HW 	
(continued)
NO. OF

CHEMICAL NAME
CARBON DISULFIDE
CHLOROACETONITR1LE
CHLOR06EHZENE
CHLOROETHANE
CHLOROFORM
CHLOROHETHANE
CIS-1 ,3-DICHLOROPROPENE
CKOTONALDEHYDE
DliROHOCHLOROHETHANE
D1BROHOM6THANE
DIETHYL ETHER
ETHYL CYAHIDE
ETHYL K6THACRYLATE
ETHYLBEHZENE
ICOOHETHAKE
ISOBUTYL ALCOHOL
H-XYLENE
METHYL HETHACRYLATE
HETHYLENE CHLORIDE
0+P XYLENE
TETRACHLOROETHENE
TETRACHLOROHETHANE
TOLUENE
TRANS-1 ,2-01 CHLOROETHENE
TRANS-1,3-DICHLOROPROPENE
TRANS-1, 4-DICHLORO-2-BUTENE
TRIBROMOMETHAME
TRICHlOROETHEHE
TR I CHLOROFLUOROHETHANE
VINYL ACETATE
VINYL CHLORIDE
1,1-DICHLOROETHANE
1,1-DICHLOROETHENE
1 ,1 , 1-TRICHLOROETHANE
1,1,1 ,2-TETRACHLOROETHANE
1,1,2-TRICHLOROETHANE
1,1,2,2-TETRACHLOROETHANE
1,2-DIBROMQETHANE
1,2-DlCHLOROETHANE
1,2-DICHLOROPROPANE
1,2,3-TRICHLOROPROPANE
1,3-BUTADIENE, 2-CHLORO
1,3-DICHLOROPROPANE
1,4-DIOXANE
2-BUTANQNE (MEK)
2-CHLOROeTHYLVINYL ETHER
2-HEXANONE
2-PROPANOHE (ACETONE)
2-PROPEN-1-OL
2-FROPEHAL (ACROLEIN)
2-PROPEHEHITRILE, 2-METHYL-
3-CHLOROPROPEHE
4-METHYL-2-PENTANONE
NO. OF
MILLS
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
9
10
10
10
10
10
10
10
10
10
7
10
10
10
10
10
10
9
10
10
10
10
10 '
10
10
10
9
10
10
9
10
10
10
10
10
MILLS
NON-DETECT
' 5
10
10
10
0
6
10
9
10
.1°
9
10
10
9
9
9
9
10
6
9
9
8
9
10
10
10
10
10
6
9
9
10
10
9
10
9
10
10
9
9
10
10
10
10
5
9
10
2
10
10
9
10
10
NO. OF
DATA POINTS
93
93
93
93
93
92
93
93
93
93
88
93
93
93
93
93
93
93
77
93
91
93
93
93
93
93
93
90
19
93
93
92
93
90
93
92
93
93
93
93
93
93
93
88
89
93
93
85
93
92
93
93
93
NO. OF
NON-DETECTS
64
93
93
93
0
87
93
92
93
93
86
93
93
92
92
92
92
93
65
92
89
90
92
93
93
93
93
90
16
91
92
92
93
88
93
92
93
93
92
92
93
93
93
88
78
92
93
19
93
92
92
93
93

UNITS
UI3/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
LIG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
MINIMUM
SYMBOL
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MINIMUM
10.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
50.00
50.00
10.00
50.00
10.00
10.00
50.00
§••
MAXIMUM
SYMBOL

ND
ND
ND


ND

ND
ND

ND
ND




ND





ND
ND
ND
ND
ND



ND
ND

ND
ND
ND
ND


ND
ND
ND
ND


ND

ND
ND

ND
ND
mim

MAXIMUM
266.09
100.00
100.00
500.00
56756.00
29857.00
100.00
129.46
100.00
100.00
1646.98
100.00
100.00
76.00
11.69
462.87
202.00
100.00
2062.91
84.00
16.00
3693.55
16.80
100.00
100.00
500.00
100.00
100.00
144.00
4230.00
22.49
100.00
100.00
283.00
100.00
100,. 00
100.00
100.00
41.70
11.00
100.00
100.00
100.00
100.00
6639.00
91.49
500.00
29316.70
100.00
500.00
723.03
100.00
500.00
•^H

-------
                                                            TABLE C-3

                                        LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
19
 CHEMICAL NAME

 ADSORBABLE ORGANIC  HALIDES  (AOX)
 COO
 ACENAPHTHENE
 ACENAPHTHYLEHE
 ACETOPHENONE
 ALPHA-NAPHTHYLAMINE
 ALPHA-PICOLINE
 ALPHA-TERPINEOL
 ANILINE
 ANTHRACENE
 ARAMITE
 B-NAPHTHYLAMINE
 BENZANTHRONE
 BENZENETHIOL
 BENZIDINE
 BENZO(A)ANTHRACENE
 BENZO(A)'PYRENE
 BENZO(B > FLUORANTHENE
 BENZO(GHI)PERYLENE
 BENZO(K)FLUORANTHENE
 BENZOIC ACID
 BENZYL ALCOHOL
 BIPHENYL
 BIS <2-CHLOROISOPROPYL) ETHER
 BIS(CHLOROMETHYL)ETHERCNR)
 BISC2-CHLOROETHOXY)METHANE
 BISC2-CHLOROETHYL5ETHER
 BISC2-ETHYLHEXYDPHTHALATE
 BUTYL BENZYL PHTHALATE
 CARBAZOLE
 CHRYSENE
 DI-N-BUTYL AMINE
 DI-N-BUTYL PHTHALATE
DI-N-OCTYL PHTHALATE
DIBENZOCA,H)ANTHRACENE
DIBENZOFURAN
DIBENZOTHIOPHENE
DICHLORODIFLUOROMETHANE CNR)
DIETHYL PHTHALATE
DIMETHYL PHTHALATE
DIMETHYL SULFONE
DIPHENYL ETHER
DIPHENYLAMINE
DIPHENYLDISULFIDE
ETHANOL
ETHYL METHANESULFONATE
ETHYLENETHIOUREA
ETHYNYLESTRADIOL 3-METHYL ETHER
 FLUORANTHENE
 FLUORENE
HEXACHLORO-1,3-BUTADIENE
HEXACHLOROBENZENE
HEXACHLOROCYCLOPENTADIENE
rwini wi

NO. OF
MILLS
6
7
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1 1 CUUK i nnnc— •
NO. OF
MILLS
NON-DETECT
0
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
AUil/ 0IMUC TiU
(continued:

NO. OF
DATA POINTS
34
21
3
3
3
3
3
3
3
3
3,
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
IKMIC 3UDIMICU
>

NO. OF
NON-DETECTS
0
1
3
3
3 '
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
2
3
3
3
3
3
2
3
3
3
3
3
3
3
3
3
3
3
3
1
3
3
3
3
3
3
3
3
3
3
3
3
UKI— orN I


UNITS
MG/L
MG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
ruKNian=nh

MINIMUM
SYMBOL
>
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND /
ND/
ND
ND
ND
ND
ND
ND
ND
ND/
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND



MINIMUM
7.10
15.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
/10.00
' 20.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00 '
10.00
20.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00


MAXIMUM
SYMBOL


ND -
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

/ND /
ND /
ND/
/ND
/ ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND



MAXIMUM
128.00
2300.00
10.00
10.00
.10.00
10.00
50.00
10.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
10.00
20.00
10.00
50.00
68.00
/ 10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
100.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00

-------
                                                        TABLE C-3

                                    LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
                                                                                                                          20
CHEMICAL NAME

HEXACHLOROETHAHE
BEXACHtOROPROPENE
HEXAHOIC ACID
IHDEHOa,2,3-CD)PYRENE
1SOPHOROHE
ISOPRO>AHOL
ISOPROPYL ETHER
1SOSAFROLE
IOMGIFOLENE
MALACHITE GREEH
H6THAPYRILEHE
H6THYL HETHANESULFONATE
H-BUTAWX.
N-DECANE (M-C10)
H-DOCOSANE (H-C22)
H-D00ECANE (H-C12)
N-EICOSANE (N-C20)
H-HEXACOSANE (H-C26)
N-HEXADECAHE (M-C16)
N-HITROSODI-H-BUTYLAMINE
N-MITROSOOI-N-PROPYLAHINE
H-HITROSODIETHYLAMIHE
H-MITROSOOIHETHYLAHIKE
H-HraOSOOIPHENYLAMINE
N-H1TROSOHETHYLETHYLAHINE
H-NITROSOHETHYLPHENYLAHINE
H-HITROSOMORPHOLINE
H-N1TROSOPIPERIDINE
M-OCTACOSAKE (H-C28)
H-OCTADECANE (H-C18)
H-PROPAKOt
M-TETRACOSAME CH-C24)
H-TETRADECAHE (N-C14)
H-TR1ACOHTAHE CH-C30)
K,H-DIHETHYLFORHAMIDE
HAPHTHALEHE
NITROBENZENE
0-AHISIDIfiE
0-CRESOL
0-TOLU1DINE
P-CRESOt
P-CYHENE
P-D1METHYLAHIHOAZOBENZENE
PEHTACHLOR08EMZENE
PENTACHIOROETHANE
PEMTAMETHYLBEHZEHE
PERYLEME
PHEHAC6TIH
PHEHANTHREHE
PHENOL
PHEKOTHIAZINE
PROHAHIDE
PYREHE
'LE POINT CATEGORY NAME=ACID STAGE FILTRATE SUBCATEGORr=BPK FUKNI5H=HW 	 - 	
(continued)

NO. OF
HILLS
2
2
2
2
2
2
,2
~2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON-DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
DATA POINTS
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3

NO. OF
NON-DETECTS
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
10.00
20.00
10.00
20.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
10.00
20.00
10.00
20.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10'. 00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00

-------
                                                            TABLE C-3

                                        LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
21
 CHEMICAL NAME

 PYRIDINE
 SAFROLE
 SQUALENE
 STYRENE
 T-BUTANOL
 THIANAPHTHENE
 THIOACETAMIDE
 THIOXANTHONE
 TRIPHENYLENE
 TRIPROPYLENEGLYCOL METHYL  ETHER
 1-METHYLFLUORENE
 1-METHYLPHENAMTHRENE
 1-PHENYLNAPHTHALENE
 1, 2-DIBROMO-3-CHLOROPROPANE
 1,2-DICHLOROBENZENE
 1,2-01PHENYLHYDRAZ1NE
 1,2,3-TRICHLOROBENZENE
 1,2,3-TRIMETHOXYBENZENE
 1,2,3,4-DIEPOXYBUTANE
 1,2,4-TRICHLOROBENZENE
 1,2,4,5-TETRACHLOROBENZENE
 1,3-BENZENEDIOL (RESORCINOL)
 1.3-DJCHLORO-2-PROPANOL
 1,3-DICHLOROBENZENE
 1,3-DINITROBENZENE
 1,3,5-TRITHIANE
 1,4-DICHLOROBENZENE
 1,4-NAPHTHOQUINONE
 1,5-NAPHTHALEHEDIAMINE
 2-(METHYLTHIO)BENZOTHIAZOL
 2-BROHOCHLOROBENZENE
 2-BUTANOL
 2-CHLORONAPHTHALENE
 2-CHLOROPHENOL
 2-ISOPROPYLNAPHTHALENE
 2-METHYL-4.6-DINITROPHENOL
 2-METHYLBENZOTHIOAZOLE
 2-METHYLNAPHTHALENE
 2-NITROANILINE
 2-NITROPHENOL
 2-PHENYLNAPHTHALENE
 2,3-BENZOFLUORENE
 2,3-DICHLOROANILINE
 2,3-DICHLORONITROBENZENE
2,4-DIAMINOTOLUENE
2,4-DICHLOROPHENOL
2,4-DIMETHYLPHENOL
2,4-DINITROPHENOL
2,4-OINITROTOLUENE
2,4,5-TRIHETHYLANlLINE
2.6-DI-TERT-BUTYL-P-BENZOQ1NONE
2,6-DICHLORO-4-NITROANILINE
2,6-DINITROTOLUENE
(continued)

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2'
2
2
NO. OF
MILLS
NON -DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
DATA POINTS
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3

NO. OF
NON-DETECTS
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3


UNITS
'UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
10.00
10.00
99.00
10.00
10.00
10.00
20.00
20.00
10.00
99.00
10.00
10.00
10.00
20.00
10.00
20.00
10.00
10.00
20.00
10.00
10.00
50.00
10.00
10.00
20.00
50.00
10.00
99.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
99.00
10.00
10.00
50.00
10.00
20.00
99.00
99.00
10.00

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
fcD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM \
10.00
10.00
99.00
10.00
10.00
10.00
20.00
20.00
10.00
99.00
10.00
10.00
10.00
20.00
10.00
20.00
10.00
10.00
20.00
10.00
10.00
50.00
10.00
10.00
20.00
50.00
10.00
99.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
99.00
10.00
10.00
50.00
10.00
20.00
99.00
99.00
10.00

-------
                                                         TABLE C-3
                                                                                                                             22
                                     LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
CHEMICAL NAME
                          SAMPLE POINT CATEGORY NAME=ACID STAGE FILTRATE SUBCATEGORY=BPK FURNISH=HW
                                                         (continued)

                                           NO. OF
                                 NO. OF     MILLS       NO. OF       NO. OF           MINIMUM
                                  MILLS  NON-DETECT  DATA POINTS  NON-DETECTS  UNITS  SYMBOL
3-BROHOCHLOR06ENZENE                2         2
3-CHLORONITROBENZENE                2         2
3-HETHYLCHOtANTHRENE                2         2
3-HITROANILINE                      2         2
3,3'-DICHLOROeENZIDINE             2         2
3,3'-DIHETHOXYBEHZIDINE            2         2
3.5-D1BROHO-4-HYDROXYBENZONITR     2         2
3,6-DIBETHYLPHEHANTHRENE           2         2
4-AMINOeiPHENYL                     2         2
4-BROHOPHEHYL PHENYL  ETHER         2         2
4-CHI.ORO-2-NITROANIL1NE            2         2
4-CHIORO-3-HETHYLPHENOL            2         2
4-CHLOROAH1LINE                     2         2
4-CHIOROPKENYL PKENYL ETHER        2         2
4-MITROANILINE                      2         2
4-NlTROeiPHENYL                     2         2
4-NnROPHENOt                       2         2
4,4'-HETHYLENEBIS(2-CHLOROANI)     2         2
4f5-M6THYLENEPHEHANTHRENE          2         2
5-CHtORO-O-TOtUIDINE                2         2
S-MITRO-0-TOLUIDINE                 2         2
7,12-OIHETHYLBENZ(A>ANTHRACENE     2         2
ALUMINUM                            2         0
ANTINOMY                            2         2
ARSENIC                             2         2
BARIUM                              2         0
BERYLLIUM                           2         2
BISMUTH                             2         2
BORON                               2         1
CADMIUM                             2         2
CALCIUM                             2         0
CERIUM                              2         2
CHROMIUM                            2        • 2
COBALT                              2         2
COPPER                              2         1
DYSPROSIUM                          2         2
ERBIUM                              2         2
EUROPIUM                            2         2
GADOLINIUM                          2         2
GALLIUM                             2         2
GERMANIUM                          *2         2
GOLD                                2         2
HAFNIUM                             2         2
HOLHINUH                            2         2
INOIUH                              2         2
IODINE                              2         0
IRIDIUH                             2         2
IROM                                2         0
LAHTHANW                           2         2
LEAD                                2         2
LITHIUM                             2         2
LUTETIUH                            2         2
MAGNESIUM                           2         0
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
9
3
3
3
9
3
3
3
9
9
9
9
9
9
9
9
9
9
3
9
3
9
3
9
9
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
0
3
3
0
3
9
1
3
0
9
3
3
1
9
9
9
9
9
9
9
9
9
9
0
9
0
9
3
9
9
0
UG/IL
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/L
UG/L
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/IL
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/i
UG/L
UG/L
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
iti=nw - — •-
MINIMUM

10.00
50.00
10.00
20.00
50.00
50.00
50.00
10.00
10.00
10.00
20.00'
10.00
10.00
10.00
50.00
10.00
50.00
20.00
10.00
10.00
10.00
10.00
851.00
6.00
2.00
1120.00
2.00

30.00
5.00
110000.00

10.00
25.00
15.00










3100.00

261.00

50.00


MAXIMUM
SYMBOL

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND

ND

ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND

MAXIMUM
, J
10.00
50.00
10.00
20.00
50.00
50.00
50.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
10.00
50.00
20.00
10.00
10.00
10.00
10.00
2510.00
6.00
2.00
2190.00
2.00

1390.00
5.00
205000.00

10.00
25.00
36.00










6500.00

487.00

50.00


        11900.00
21200.00

-------
                    TABLE C-3
LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS


CHEMICAL NAME
MANGANESE
MERCURY
MOLYBDENUM
NEODYMIUM
NICKEL
NIOBIUM
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SELENIUM
SILICON
SILVER
SODIUM
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIN
TITANIUM
TUNGSTEN
URANIUM
VANADIUM
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
SWIKLC KU1NI C
NO. OF
MILLS
NON-DETECT
0
0
2
2
2
2
2
2
0
2
0
2
2'
2
2
2
2
2
0
2
CT
0
0
2
2
2
2
2
2
2
1
2
2
1
2
1
0
2
AltbUKT NAMt=AL
NO. OF
DATA POINTS
3
3
3
9
3
9
9
9
3-
9
3
9
9
9
9
9
9
3
3
3
3
3
3
9
9
9
3
9
9
3
3
9
9
3
9
3
3
9
ilU STAGE FILTR/
(continued)
NO. OF
NON -DETECTS
0
1
3
9
3
9
9
9
0
9
0
9
9
9
9
9
9
3
0
3
0
0
0
9
9
9
3
9
9
3
1
9
9
2
9
2
0
9
lit SUBC,

UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
                                            MINIMUM
                                            SYMBOL
                                              ND
                                              ND
                                              ND
                                              ND
                                              ND
                                              ND
                                              ND

                                              ND

                                              ND
                                              ND
                                              ND
                                              ND
                                              ND
                                              ND
                                              ND

                                              ND
                                             ND
                                             ND
                                             ND
                                             ND
                                             ND
                                             ND
                                             ND
                                             ND
                                             ND
                                             ND
                                             ND
                                             ND
                                             ND

                                             ND

MINIMUM
2210.00
2.00
10.00

22.00



4500.00

2300.00






3.00
10100.00
6.00
260000.00
900.00
50800.00



20.00


30.00
5.00


13.00

5.00
150.00
MAXIMUM
SYMBOL


ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

ND



ND
ND
ND
ND
ND
ND
ND

ND
ND

ND



MAXIMUM
4690.00
5.80
10.00

22.00



7700.00

3400.00






3.00
15500.00
6.00
392000.00
1700.00
305000.00



26.00


30.00
15.00


102.00

6.00
275.00
                                                                      ND

-------
                                                       TABLE C-4
                                                                                                                          24
                                   LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
CHEMICAL HAKE

2,3,7,8-TETRACHLORODIBENZO-P-DIOX'IN
1,2.3,7,8-PENTACHLORODIBENZO-P-DlOXIN
1,2,3,4,7,8-HEXACHLORODIBENZO-P-DIOXIN
1,2,3,6,7,8-HEXACHLORODIBENZO-P-DIOXIN
1,2,3,7,8,9-HEXACHLORODIBENZO-P-DIOXIN
1,2,3,4,6,7,8-HEPTACHLOROOIBENZO-P-DIOXI
OCTACHLORCOIBENZO-P-DIOXIN
2,3,7, 8-TETRACHLORODIBENZOFURAN
1,2,3,7,8-PENTACHLORODIBENZOFURAN
2,3,4,7,8-PENTACHLOROOIBENZOFURAN
1,3,3,4,7,8-HEXACHIORODIBENZOFURAN
1,2,3,6,7,8-HEXACHLORODIBENZOFURAN
1,2,3,7,8,9-HEXACHLORODIBENZOFURAN .
2,3,4,6,7,8-HEXACHLOROOIBENZOFURAN
1,2,3,4,6,7,8-HEPTACHLOSODIBENZOFURAN
1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN
OCTACHtORCOIBENZOFURAN
4-CHLOROPHENOL
4-CW.OROCATECHOt
4-CHLOROCUAIACOt
5-CHIOROGUAIACOL
5-CHLOROVANILLIN
6-CHLOROVAHILLIN
2- CWtOROSYRINGALDEHYOE
2,4-DICHLOROPHENOL
2,6-DICHLOROPHENOL
3,4-DICHLOROPHENOL
3,5-OICHLOROPHENOC
3,4-DtCHLOROCATECHOL
3,5-DlCHLOROCATECHOL
3,6"DICHIOROCATECKOL
4,5-OICHLOROCATECHOi
3,4-DICHLOROGUAIACOL
4,5-DICHLOROG'JAIACCL
4,6-DICHLOROGUAlACCL
5,6-DICHLOROVAMILLIH
2,6-DICHLOROSYRINGALDEHYDE
2,3,6-tRICHLOROPHENOt
2,4,5-TRICHLOROPHENOL
2,4,6-TRICHLOROPHENQL
3,4,5-TRICHLOROCATECHOL
3,4,6-TRlCHLOROCATECHOL
3,4,5-TRICHLOROGUAIACOL
3,4,6-TRICHLOROGUAIACOL
4,5,6-TR1CHLOROGUAIACOL
TRICHLOROSYRIHGOL
2,3,4,6-TETRACHLOROPHENOL
TETRACHL080CATECHOL
TETRACHtOROGUAIACOL
PENTACHtOROPHENOL
ACRYLONITRILE
BENZENE
BROHODICHLOROHETHANE
BftOMOHETHANE
)RY NAME=ALKALINE STAGE FILTRATE SUBCATEGORY=BPK FUKNISH=MH 	
NO. OF
NO. OF MILLS NO. OF NO. OF MINIMUM MAXIMUM
MILLS.
10
10
10
10
10
10
7
10
10
10
10
10
'10
10
10
10
9
7
3
7
4
3
9
7
8
10
7
7
7
4
4
10
3
10
9
9
7
7
10
10
10
3
10
7
10
10
10
10
8
10
9
10
10
10
NON-DETECT DATA POINTS NON-DETECTS UNITS SYMBOL
8
10
10
10
10
9
2
5
' 10
10
10
10
10
9
9
10
7
3
1
3
3
0
3
3
0
9
7
5
5
3
0
6
0
4
4
4
0
6
7
3
7
2
3
3
1
0
6
6
3
9
9
10
7
10
62
16
16
16
16
15
9
62
16
16
16
16
16
16
16
16
15
66
45
62
12
53
68
66
68
72
18
18
59
12
52
66
51
72
67
70
66
18
70
72
63
46
70
63
68
71
68
64
68
72
71
71
72
72
60
16
16
16
16
13
3
47
16
16
16
16
16
15
15
16
13
33
43
32
10
6
11
9
31
70
18
14
56
11
46
60
23
13
21
15
6
15
64
11
60
41
33
38
22
9
58
60
60
71
71
71
54
72
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
NO
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
MINIMUM SYMBOL
3.00
3.00
5.00
5.00
4.00
5.00
100.00
3.00
3.00
3.00
5.00
3.00
7.00
5.00
3.00
4.00
7.00
0.30
1.20
0.30
0.50
2.50
0.50
0.50
0.10
0.30
0.30
0.30
2.40
0.50
2.40
1.00
2.50
0.50
0.30
0.50
1.30
0.10
0.30
0.50
0.30
4.80
0.10
0.50
0.30
0.30
0.30
0.30
0.10
0.10
50.00
10.00
10.00
50.00

ND
ND
ND
ND



ND
ND
ND
ND
ND


ND










ND














>








ND
ND

ND
MAXIMUM
15.00
53.00
53.00
53.00
70.00
8800.00
230000.00
63.00
100.00
100.00
53.00
53.00
53.00
23.00
200.00
53.00
1900.00
19.00
42.47
14.00
13.50
350.00
2261.00
1428.00
23.00
8.60
5.00
23.00
36.28
1.70
17.47
171.08
48.70
637.00
64.00
550.00
560.00
0.20
29.00
94.78
149.91
23.81
64.84
13.00
300.00
120.00
11.00
67.39
42.00
1.70
50.00
10.00
132.00
50.00

-------
                                                        TABLE C-4

                                    LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
25
 CHEMICAL NAME

 CARBON DISULFIDE
 CHLOROACETONITRILE
 CHLOROBENZENE
 CHLOROETHANE
 CHLOROFORM
 CHLOROHETHANE
 CIS-1.3-DICHLOROPROPENE
 CROTONALDEHYDE
 DIBROMOCHLOROMETHANE
 DIBROMOMETHANE
 DIETHYL ETHER
 ETHYL  CYANIDE
 ETHYL  METHACRYLATE
 ETHYLBENZENE
 IODOMETHANE
 ISOBUTYL ALCOHOL
 M-XYLENE
 METHYL METHACRYLATE
 METHYLENE  CHLORIDE
 0+P XYLENE
 TETRACHLOROETHENE
 TETRACHLOROMETHANE
 TOLUENE
 TRANS-1,2-DICHLOROETHENE
 TRANS-1,3-DICHLOROPROPENE
 TRANS-1.4-DICHLORO-2-BUTENE
 TRIBROMOMETHANE
 TRICHLOROETHENE
 TRICHLOROFLUOROMETHANE
 VINYL ACETATE
 VINYL  CHLORIDE
 1,1-DICHLOROETHANE
 1,1-DICHLOROETHENE
 1,1.1-TRICHLOROETHANE
 1,1,1,2-TETRACHLOROETHANE
 1,1,2-TRICHLOROETHANE
 1,1,2,2-TETRACHLOROETHANE
 1.2-DIBROMOETHANE
 1,2-DICHLOROETHANE
 1,2-DICHLOROPROPANE
 1,2,3-TRICHLOROPROPANE
 1,3-BUTADIENE, 2-CHLORO
 1,3-DICHLOROPROPANE
 1,4-DIOXANE
2-BUTANONE (MEK)
2-CHLOROETHYLVINYL ETHER
2-HEXANONE
2-PROPANONE (ACETONE)
2-PROPEN-1-OL
2-PROPENAL (ACROLEIN)
2-PROPENENITRILE, 2-METHYL-
3-CHLOROPROPENE
4-METHYL-2-PENTANONE
\*n i buu

NO. OF
MILLS
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
7
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
9
10
10
10
10
10
10
10
10
TV i rannc—Munt/i
NO. Ot
MILLS
NON-DETECT
10
10
10
10
0
9
10
10
10
10
10
8
10
10
10
9
10
10
7
10
9
9
10
10
10
10
9
10
6
9
10
10
10
9
10
10
10
10
9
10
10
10
10
9
3
10
10
2
10
10
9
10
10
.line OIMUC ri
(continued)

NO. OF
DATA POINTS
72
72
72
72
71
71
72
72
72
72
68
72
72
72
72
72
72
72
63
72
71
72
72
72
72
72
72
70
17
72
72
71
72
70
72
72
72
72
72
72
72
72
72
66
71
72
72
66
72
72
72
72
72
L.1KM1C OUDUMI

NO. OF
NON-DETECTS
72
72
72
72
1
70
72
72
72
72
68
70
72
72
72
71
72
72
54
72
70
71
72
72
72
72
71
70
14
71
72
71
72
68
72
72
72
72
71
72
72
72
72
65
56
72
72
13
72
72
71
72
72
! CUUK I -D


UNITS
UG/L
UG/L
U6/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
rK ruKNia

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND



MINIMUM
10.00
10.00
10.00
50.00
10.00
50.00
10.00
50.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
50.00
50.00
10.00
50.00
10.00
10.00
50.00


MAXIMUM
SYMBOL
ND
ND
ND
ND


ND
ND
ND
ND
ND

ND
ND
ND

ND
ND

ND


ND
ND
ND
ND

ND


ND
ND
ND

ND
ND
ND
ND

ND
ND
ND
ND


ND
ND

ND
ND

ND
ND



MAXIMUM
10.00
10.00
10.00
50.00
29811.00
234.33
10.00
50.00
10.00
10.00
50.00
13369.00
'10.00
10.00
10.00
440.00
10.00
10.00
8234.50
10.00
13.49
1086.00
10.00
10.00
10.00
50.00
962.00
10.00
1897.00
3515.00
10.00 -
10.00
10.00
172.00
10.00
10.00
20.00
10.00
16.30
10.00
10.00
10.00
10.00
5649.00
4548.00
10.00
50.00
6187.00
10.00
100.00
798.00
1Q.OO
50.00

-------
                                                            TABLE C-4

                                       LONG-TERM STUDY AND  SHORT-TERM STUDY CONCENTRATIONS
                                                                                                                                26
CHEMICAL MAKE

ADSORBABLE ORGANIC HALIDES (AOX)
COD
ACEKAPHTHENE
ACENAPHTHYLEBE
ACETOPHEHONE
ALPHA-MAPHTHYLAHIHE
ALPHA-P1COUHE
ALPHA-TERPINEOC
AHILIHE
ANTHRACENE
ARAH1TE
B-KAPHTHYLAH1HE
8EMZAHTHRONE
BENZEHETHIOt
BEHZIDIHE
SEHZO(A)AHTHRACENE
8EHZO(A)PYRENE
BEMZO(B)FLUORANTHENE
BE«ZO(GHI)P£RYLENE
8£NZO{>C>FLUORANTHENE
BEMZOIC ACID
BENZYL ALCOHOL
BIPHEHYL
BIS C2-CHLOROISOPROPYL) ETHER
BmCHLOROMETHYDETHERCNR)
BISCZ-CHLOROETHOXYWETHANE
BIS(2-CHLOROETHYL)ETHER
BIS<2-ETHYLHEXYL)PHTHALATE
BUTYL BENZYL PHTHAUTE
CARBAZOtE
CHRYSEHE
DI-H-BUTYL AMINE
OI-H-BUTYL PHTHALATE
Dt-H-OCTYL PHTHALATE
01BEHZOCA,H)ANTHRACENE
D1BENZOFORAH
DIBENZOTHIOPKENE
DICHLOROOIFLUOROHETHANE (NR)
OIETHYL PHTHALATE
OIHETHYL PHTHALATE
DIMETHYL SULFONE
DIPHEHYL ETHER
D1PHEHYLAHIKE
01PHEHYLDISULFIDE
ETHAHOL
ETHYL HETKANESULFOWATE
ETHYLENETHIOUREA
ETHYNYLESTRADIOL 3-HETHYL ETHER
FLUORANTHENS
FLUOREME
HEXACHLORO-1,3-BUTADIENE
HEXACKLOR06EHZENE
BEXACHLOROCYCLOPENTAOIENE
IIHT CATEGORY NAME=ALKALINE STAGE FILTRATE SUBCATEGORY-BPK FURNISM=HW 	
(continued)

NO. OF
HILLS
6
7
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON-DETECT
0
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
DATA POINTS
31
18
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3'
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3

NO. OF
NON -DETECTS
0
1
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
2
3
3
3
3
1
3
3
3
3
3
3
3
3
3
3
3
3


UNITS
KG/I
MG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
>
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
2.59
15.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
10.00
20.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00

MAXIMUM
SYMBOL


ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
• ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
73.00
2200.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
10.00
20.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
20.00
20.00
10.00
10.00
10.00
10.00
51.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00

-------
                                                        TABLE C-4
                                                                                                                            27
                                     LONG-TERM  STUDY AND SHORT-TERM STUDY CONCENTRATIONS
CHEMICAL NAME

HEXACHLOROETHANE
HEXACHLOROPROPENE
HEXANOIC ACID
INDENO(1,2.3-CD)PYRENE
ISOPHORONE
ISOPROPANOL
ISOPROPYL ETHER
ISOSAFROLE
LONGIFOLENE
MALACHITE GREEN
METHAPYRILENE
METHYL METHANESULFOMATE
N-BUTANOL
N-DEC'ANE CN-dO)
N-DOCOSANE (N-C22)
N-DODECANE (N-C12)
N-EICOSANE (N-C20)
N-HEXACOSANE (N-C26)
N-HEXADECANE (N-C16)
N-NITROSODI-N-BUTYLAMINE
N-NITROSODI-N-PROPYLAMINE
N-NITROSODIETHYLAMINE
N-NITROSODIMETHYLAMINE
N-NITROSODIPHENYLAMINE
N-NITROSOMETHYLETHYLAMINE
N-NITROSOMETHYLPHENYLAMINE
N-NITROSOMORPHOLINE
N-NITROSOPIPERIDINE
N-OCTACOSANE (N-C28)
N-OCTADECANE (N-C18)
N-PROPANOL
N-TETRACOSANE (N-C24)
N-TETRADECANE (N-C14)
N-TRIACONTANE (N-C30)
N,N-DIMETHYLFORMAMIDE
NAPHTHALENE
NITROBENZENE
O-ANISIOINE
0-CRESOL
0-TOLUIDINE
P-CRESOL
P-CYMENE
P-DIMETHYLAMINOAZOBENZENE
PENTACHLOROBENZENE
PENTACHLOROETHANE
PENTAMETHYLBENZENE
PERYLENE
PHENACETIN
PHENANTHRENE
PHENOL
PHENOTHIAZINE
PRONAHIDE
PYRENE
(continued)

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
,2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2 '
2
2
NO. OF
MILLS
NON-DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
DATA POINTS
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3 .
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3

NO. OF
NON -DETECTS
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
10.00
20.00
10.00
20.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND'
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
10.00
20.00
10.00
20.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00 .
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00

-------
                                                           TABLE C-4

                                       LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
                                                                                                                               28
CHEMICAL HAKE

PYR1DIHE
SAFROtE ,
SOMIEHE
STYREKE
T-BUTANOt
TKIAHAPHTKENE
THIOACETAHIDE
THIOXANTHOHE
TRIPHENYLEHE
TRIPROPYtENEGtYCOL HETHYL ETHER
1-H£THYLFLUORENE
1-HETHYLPHENAHTHRENE
1-PHENYLNAPHTHALENE
1,2-DIBROHO-3-CHLOROPROPANE
1,2-DICHLOROBEHZENE
1,2-DIPHEHYLHYDRAZIHE
1,2,3-TRlCHLOROBENZEHE
1,2,3-TR1H£THOXYBENZENE
1,2,3,4-DIEPOXYBUTANE
1,2,4-TRlCHLOROBENZENE
1,2,4,5-TETRACHLOROBENZENE
1,3-BENZENEDlOt (RESORCINOL)
1.3-DICHLORO-2-PROPANOL
1,3-DlCHLOROeENZENE
1.3-DIHITR08ENZENE
1,3,5-TRITHIAHE
1,4-DICHLOROeENZENE
1,4-MAPHTHOQUJNOHE
1,5-HAPHTHALENEDIAMINE
2-
-------
                                                           TABLE C-4
                                                                                                                               29
                                        LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
CHEMICAL NAME
                           SAMPLE POINT  CATEGORY NAME=ALKALINE STAGE FILTRATE SUBCATEGORY=BPK FURNISH=
                                                           (continued)

                                             NO. OF
                                 NO. OF     MILLS        NO. OF        NO. OF             MINIMUM
                                  MILLS  NON-DETECT   DATA POINTS   NON-DETECTS   UNITS   SYMBOL
3-BROMOCHLOROBENZENE                2
3-CHLORONITROBENZENE                2
3-METHYLCHOLANTHRENE                2
3-NITROANILINE                      2
3,3'-DICHLOROBENZIDINE              2
3,3'-DIMETHOXYBENZIDINE             2
3.5-DIBROMO-4-HYDROXYBENZONITR      2
3,6-DIMETHYLPHENANTHRENE            2
4-AMINOBIPHENYL                     2
4-BROMOPHENYL PHENYL ETHER          2
4-CHLORO-2-NITROANILINE             2
4-CHLORO-3-METHYLPHENOL             2
4-CHLOROANILINE                     .2
4-CHLOROPHENYL PHENYL ETHER         2
4-NITROANILINE                      2
4-NITROBIPHENYL                     2
4-NITROPHENOL                       2
4,4'-METHYLENEBIS(2-CHLOROANI)      2
4,5-METHYLENEPHENANTKRENE           2
5-CHLORO-O-TOLUIDINE                2
5-NITRO-O-TOLUIDINE                 2
7,12-DIMETHYLBENZ(A)ANTHRACENE      2
ALUMINUM                            2
ANTIMONY                            2
ARSENIC                             2
BARIUM                              2'
BERYLLIUM                           2
BISMUTH                             2
BORON                               2
CADMIUM                             2
CALCIUM                             2
CERIUM                              2
CHROMIUM                            2
COBALT                              2
COPPER                              2
DYSPROSIUM                          2
ERBIUM                              2
EUROPIUM                            2
GADOLINIUM                          2
GALLIUM                             2
GERMANIUM                           2
GOLD                                2
HAFNIUM                             2
HOLMIHUM                            2
INDIUM                              2
IODINE                              2
IRIDIUM                             2
IRON                                2
LANTHANUM                           2
LEAD                                2
LITHIUM                             2
LUTETIUM                            2
MAGNESIUM                           2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 0
 2
 2
 0
 2
 2
 1
 2
 0
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
•2
 2
 2
 1
 2
 0
 2
 2
 2
 2
 1
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
9
3
3
3
9
3
3
3
9
9
9
9
9
9
9
9
9
9
7
9
3
9
3
9
9
3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 3
 0
 3
 3
 0
 3
 9
 1
 3
 0
 9
 3
 3
 3
.9
 9
 9
 9
 9
 9
 9
 9
 9
 9
 6
 9
 0
 9
 3
 9
 9
 2
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
=nw ---- —
MINIMUM
10.00
50.00
10.00
20.00
50.00
50.00
50.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
10.00
50.00
20.00
10.00
10.00
10.00
10.00
406.00
6.00
2.00
205.00
2.00

10.00
5.00
17300.00

10.00
25.00
13.00












168.00

50.00


MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND

ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND

MAXIMUM
10.00
50.00
10.00
20.00
50.00
50.00
50.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
10.00
50.00
20.00
10.00
10.00
10.00
10.00
1950.00
60.00
2.00
407.00
2.0,0

1220.00
5.00
35200.00

10.00
25.00
24.00










2300.00

373.00

50.00


                                                                                                     2090.00
                                                                                                                          6880.00

-------
                    TABLE C-4
                                                                                       30
LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS



CHEMICAL HAMS
MANGANESE
MERCURY
MOLYBDENUM
NCOOYHIUH
NICKEL
NIOBIUM
OSHIUH
PALLADIUM
PHOSPHORUS
PL ATI HUH
POTASSIUM
PRASEODYMIUM
RHEHIUH
RHODIUM
RUTHENIUM
SAKARIUH
SCANDIUM
SELENIUM
SILICON
SILVER
SOOIUH
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIN
TITANIUM
TUNGSTEN
URAHIUH
VANADIUM
YTTERBIUM
YTTRIUM
21 HC
ZIRCONIUM


NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
nrLC fuiHi UHI
NO. OF
MILLS
NON-DETECT
0'
0
1
2
2
2
2
2
0
2
0
2
2
2
2
2
2
2
0
2
0
0
0
2
2
2
2
2
2
2
1
2
2
1
2
2
0
2
CUUKI HHT1C-MI.ISJ%

NO. OF
DATA POINTS
3
3
3
9
3
9
9
9
3
9
5
9
9
9
9
9
9
3
3
3
3
3
3
9
9
9
3
9
9
3
3
9
9
3
9
3
3
9
l. i nc o I nuc r i 1
(continued)

NO. OF
NON-DETECTS
0
0
1
9
3
9
9
9
0
9
3
9
9
9
9
9
9
3
0
3
0
0
0
9
9
9
3
9
9
3
1
9
9
2
9
3
0
9
                                   UNITS

                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                            MINIMUM
                                            SYMBOL
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
UKN15H=MW -
MINIMUM
477.00
4.40
10.00

22.00



1200.00








3.00
7600.00
6.00
836000.00
200.00
32800.00



20.00


30.00
5.00


13.00

5.00
36.00
MAXIMUM
SYMBOL



ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

ND



ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND


MAXIMUM
746.00
21.00
15.00

22.00



2900.00

1200.00






30.00
26500.00
6.00
928000.00
300.00
38500.00



20.00


30.00
20.00


60.00

5.00
79.00
                        ND

-------
                                                            TABLE C-5
                                                                                                                               31
                                        LONG-TERM  STUDY AND  SHORT-TERM STUDY CONCENTRATIONS
CHEMICAL NAME
SAMPLE POINT CATEGORY NAME=ACID STAGE FILTRATE SUBCATEGORY=BPK FURNISH=SU

                        NO., OF
              NO. OF     KILLS       NO. OF       NO.  OF           MINIMUM
               MILLS  NON-DETECT  DATA POINTS  NON-DETECTS  UNITS  SYMBOL
2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN  •        11         4
1,2,3,7,8-PENTACHLORODIBENZO-P-DIOXIN        10         8
1,2,3,4,7.8-HEXACHLORODIBENZO-P-DIOXIN       10         9
1,2,3,6,7,8-HEXACHLORODIBENZO-P-DIOXIN       10         9
1,2,3,7,8,9-HEXACHLOROOIBENZO-P-DIOXIN       10         10
1,2.3,4,6,7,8-HEPTACHLORODIBENZO-P-DIOXI     10         6
OCTACHLORODIBENZO-P-DIOXIN                   8         5
2,3.7,8-TETRACHLORODIBENZOFURAN              10         2
1,2,3,7,8-PENTACHLORODIBENZOFURAN            10         9
2,3,4,7,8-PENTACHLORODIBENZOFURAN            10         9
1,2,3,4,7,8-HEXACHLORODlBENZOFURAN           10         10
1,2,3,6,7,8-HEXACHLORODIBENZOFURAN           10         10
1,2,3,7,8,9-HEXACHLORODIBENZOFURAN           10         10
2,3,4,6,7,8-HEXACHLOROOIBENZOFURAN           10         10
1,2,3,4,6,7,8-HEPTACHLORODIBENZOFURAN        10         10
1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN        10         10
OCTACHLORODIBENZOFURAN                       9         9
4-CHLOROPHENOL                               8         2
4-CHLOROCATECHOL                             5         1
4-CHLOROGUAIACOL                             8         4
5-CHLOROGUAIACOL                             3         2
5-CHLOROVANILLIN                             5         1
6-CHLOROVANILLIN                             10         1
2-CHLOROSYRINGALDEHYDE                       8'         5
2,4-DICHLOROPHENOL                           9         2
2,6-DICHLOROPHENOL                           11         9
3,4-DICHLOROPHENOL                           6         6
3,5-DICHLOROPHENOL                           6         5
3,4-DICHLOROCATECHOL                         8         4
3,5-DICHLOROCATECHOL                         2         0
3,6-DICHLOROCATECHOL                         6         3
4,5-DICHLOROCATECHOL                         11         2
3,4-DICHLOROGUAIACOL                         5         3
4,5-DICHLOROGUAIACOL                         11         4
4,6-DICHLOROGUAIACOL                         10         7
5,6-DICHLOROVANILLIN                         10         7
2,6-DICHLOROSYRINGALDEHYDE                   8         6
2,3,6-TRICHLOROPHENOL                        6         5
2,4,5-TRICHLOROPHENOL                        11         9
2,4,6-TRICHLOROPHENOL                        11         3
3,4,5-TRICHLOROCATECHOL                      11         5
3,4,6-TRICHLOROCATECHOL                      5         2
3,4,5-TRICHLOROGUAIACOL                      11         4
3,4,6-TRICHLOROGUAIACOL                      8         7
4,5,6-TRICHLOROGUAIACOL                      11         6
TRICHLOROSYRINGOL                            11         8
2,3,4,6-TETRACHLOROPHENOL                    11         8
TETRACHLOROCATECHOL                          11         2
TETRACHLOROGUAIACOL                          9         6
PENTACHLOROPHENOL                            11         8
ACRYLONITRILE                                11         11
BENZENE                                      11         11
BROMODICHLOROMETHANE                         11         10
BROMOMETHANE                                 11         11
                                       87
                                       21
                                       21
                                       21
                                       21
                                       21
                                       11
                                       85
                                       21
                                       21
                                       21
                                       21
                                       21
                                       21
                                       21
                                       21
                                       19
                                       81
                                       63
                                       80
                                        8
                                       73
                                       85
                                       77
                                       87
                                       94
                                       19
                                       19
                                       75
                                        6
                                       73
                                       93
                                       68
                                       91
                                       83
                                       85
                                       78
                                       18
                                       92
                                       90
                                       85
                                       63
                                       86
                                       77
                                       90
                                       90
                                       91
                                       85
                                       90
                                       94
                                       94
                                       95
                                       95
                                       95
74
19
20
20
21
15
 8
69
19
20
21
21
21
21
21
21
19
22
13
62
 6
44
10
67
26
91
19
18
27
 1
59
26
45
30
80
60
75
17
90
29
31
57
47
73
58
78
85
35
85
89
94
95
89
95
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
 ND
 NO
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
'ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND

MINIMUM
1.00
3.00
2.00
2.00
1.00
11.00
37.00
1.00
1.00
1.00
1.00
1.00
2.00
1.00
2.00
2.00
6.00
1.25
1.25
1.20
5.00
2.50
2.50
2.50
2.50
1.60
1.60
1.60
2.50
5.00
2.50
2.50
2.50
0.44
2.50
0.47
5.00
1.00
1.00
1.00
1.00
5.00
1.00
2.43
1.22
0.25
0.61
1.60
1.00
1.00
10.00
5.00
5.00
5.00
MAXIMUM
SYMBOL




ND





ND
ND
ND
ND
ND
ND
ND









ND























ND
ND

ND

MAXIMUM
160.00
180.00
60.00
70.00
110.00
106.50
1500.00
2700.00
180.00
61.50
714.00
714.00
714.00
714.00
833.00
833.00
140.00
35.40
34.70
72.00
7.10
29.21
797.40
50.30
55.43
22.70
5.00
3.00
320.00
101.00
95.00
820.00
11.00
297.60
15.30
30.00
8.80
1.00
5.39
750.00
818.00
12.00
33.62
4.60
30.64
13.00
27.29
.131.30
10.00
374.90
500.00
100.00
51.00
500.00

-------
                    TABLE C-5
                                                                                        32
LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
	 SAMPLE POINT CATEGORY NAME=ACID STAGE FILTRATE SUBCATEGOKY=BPK
(continued)
NO. OF

CHEMICAL HAH£
CARBON DISULFIDE
CHIOROACETONITRILE
CHLOR06EHZEHE
CrtLOROETHANE
CHLOROFORM
CHIORCMITHAHE
CIS-1.3-DICHLOROPROPENE
CROTOKALDEHYDE
D1BROHOCHLOROHETHANE
01BROHOHETHANE
DIETHYL ETHER
ETHYL CYANIDE
ETHYL HETHACRYLATE
EtHYLBSNZENE
1000HGTHANE
1S06UTYL ALCOHOL
H-XYLENE
HETHYL HETHACRYLATE
HETHYLENE CHLORIDE
0+P XYLENE
TETRACHLOROETHENE
TETRACHLOROHETHANE
TOLUEUE
TRAHS-1.2-DICHLOROETHENE
TRA«S-1,3-OICHLOROPROPENE
TRANS-1 .4-DICHLORO-2-BUTENE
TRIB«ONOM€THANE
TR1CHLOROETHENE
TRICHLOROFLUOROHETHANE
VINYL ACETATE
VINYL CHLORIDE
1,1-DICHiOROETHANE
1,1-DICHLOROETHENE
1,1,1-TRICHLOROETHAHE
1 , t . 1 . 2-TETRACHLOROETHANE
1,1,2-TRICHLOROETHANE
1,1,2,2-TETRACHLOROETHANE
1,2-DIBROKOETHAHE
1,2-DICHLOROETHANE
1,2-DICHlOROPROPANE
1 ,2,3-TRICHLOROPROPANE
1,3-tUTADIENE, 2-CHLORO
1 ,3-DICHLOROPROPANE
1,4-OIOXAHE
2-BUTAKONE (HEK)
2-CHLOROETHYLVINYL ETHER
2-HEXAHONE
2-PROPANOHE (ACETONE)
2-PROPEN-1-OL
2-PROPEUAL (ACROLEIH)
2-PROPENENITRILE, 2-HETHYL-
3-CHLOROPROPENE
4-HETHYL-2-PENTANONE
HO. OF
HILLS
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
8
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
10
11
11
11
11
11
11
11
11
MILLS
NON-DETECT
5
11
11
11
0
8
11
11
11
11
11
11
•11
11
11
11
11
11
8
11
11
10
11
10
11
11
11
11
6
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
4
11
11
1
10
11
11
11
11
NO. OF
DATA POINTS
94
95
95
95
94
94
95
95
95
95
93
95
95
95
95
95
95
95
76
95
94
94
95
95
95
95
95
94
22
95
95
95
'95
94
95
93
94
95
95
95
95
95
95
88
90
95
95
83
95
93
95
95
95
NO. OF
NON-DETECTS
77
95
95
95
2
88
95
95
95
95
93
95
95
95
95
95
95
95
71
95
94
93
95
94
95
95
95
94
18
95
95
95
95
94
95
93
94
95
95
95
95
95
95
88
58
95
95
13
94
93
95
95
95

UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
;UKN1SH=SW
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
10.00

5.00
5.00
20.00
5.00


5.00

5.00


5.00




5.00

5.00
5.00
5.00
5.00
5.00

5.00
5.00
10.00

5.00
5.00
5.00
5.00

5.00
5.00

5.00
5.00



10.00
50.00
5.00

50.00

20.00




MAXIMUM
SYMBOL

ND
ND
ND

>
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND


ND
ND
ND
ND
i^H


MAXIMUM
123.51
100.00
100.00
500.00
6927.00
185.70
100.00
500.00
100.00
100.00
500.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
1098.00
100.00
100.00
228.45
100.00
18.46
100.00
500.00
100.00
100.00
32.80
500.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
200.00
1062.00
100.00
500.00
6694.00
1254.42
500.00
100.00
100.00
500.00
^^

-------
                                                            TABLE C-5
                                        LONG-TERM STUDY AND SHORT-TERM  STUDY  CONCENTRATIONS
                             SAMPLE
 CHEMICAL NAME

 ADSORBABLE ORGANIC  HALIDES (AOX)
 COD
 ACENAPHTHENE
 ACENAPHTHYLENE
 ACETOPHENONE
 ALPHA-NAPHTHYLAMINE
 ALPHA-PICOLIHE
 ALPHA-TERPINEOL
 ANILINE
 ANTHRACENE
 ARAMITE
 B-NAPHTHYLAM1NE
 BENZANTHRONE
 BENZENETHIOL
 BENZIDINE
 BENZO(A)ANTHRACENE
 BENZO(A)PYRENE
 BENZO(B)FLUORANTHENE
 BENZO(GHI)PERYLENE
 BENZOMETHANE
 BISC2-CHLOROETHYDETHER
 BIS<2-ETHYLHEXYL)PHTHALATE
 BUTYL BENZYL PHTHALATE
 CARBAZOLE
 CHRYSENE
 DI-N-BUTYL AMINE
 DI-N-BUTYL PHTHALATE
 DI-N-OCTYL PHTHALATE
 DIBENZO(A.H)ANTHRACENE
 DIBENZOFURAN
DIBENZOTHIOPHENE
 DICHLORODIFLUOROMETHANE (NR)
 DIETHYL PHTHALATE
DIMETHYL PHTHALATE
DIMETHYL SULFOME
DIPHENYL ETHER
DIPHENYLAMINE
DIPHENYLDISULFIDE
 ETHANOL
 ETHYL METHANESULFONATE
 ETHYLENETHIOUREA
 ETHYNYLESTRADIOL 3-METHYL ETHER
 FLUORANTHENE
 FLUORENE
 HEXACHLORO-1,3-BUTADIENE
 HEXACHLOROBENZENE
 HEXACHLOROCYCLOPENTADIENE
ruiNi u

NO. OF
MILLS
4
7
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2 '
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
* 1 CbUKT N«l"ie=/
NO. OF
MILLS
NON -DETECT
0
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
0
2
2
2
2
2
2
2
2
2
2
2
2
\UJU SlAlit 1-tL
( continued:

NO. OF
DATA POINTS
24
23
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
IKAIt SUBUAIbGI
>

NO. OF
NON-DETECTS
0
5
5
5
5
5
5
5
5
5
5
5
5
4
5
5
5
5
5
5
5
3
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
2
5
5
5
5
5
5
5
5
5
5
5
5
0KT=BHK 1


UNITS
MG/L
MG/L
U6/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
US/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
-UKN1SH=SW

MINIMUM
SYMBOL

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND



MINIMUM
10.00
15.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
10.00
20.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00


MAXIMUM
SYMBOL


ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND



MAXIMUM
200.00
1400.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
50.00
50.00
16.00
50.00
10.00
10.00
10.00
20.00
10.00
50.00
39.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
972.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00

-------
                               TABLE C-5
           LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
SAMPLE POINT CATEGORY NAME=ACID STAGE FILTRATE SUBCATEGORY=BPK FURNISH=
                               (continued)


CHEMICAL MAKE
BEXACHLOROETHANE
HEXACHLOROPROPENE
HEXANOIC ACID
IHO£NQ(1,Z,3-CD)PYRENE
ISOPKORONE
ISOPROPAHQt
ISOPROPYL ETHER
1SOSAFROIE
LONGIFCH.ENE
MALACHITE GREEN
HETHAPYRILENE
METHYL HETHAMESULFOHATE
H-BOTAHW.
H-DECAHE (N-C10)
H-DOCOSAME (H-C22)
H-DOCECAKE (N-C12)
H-EICOSANE (H-C20)
H-HEXACOSANE (N-C26)
H-REXAOECANE (N-C16)
H-NITROSOOI -N-BUTYLAHINE
H-HITROSODI -N-PROPYLAMINE
H-HITROSOD1ETHYLAMINE
H-HITROSODIKETHYLAHINE
H-NITROSOOIPHENYLAHINE
H-MI7ROSOHETHYLETHYLAMINE
H-NITROSOHETHYLPHENYLAHINE
H-NITROSOHORPKOLINE
H-NITROSOP1PERIDINE
H-OCTACOSAHE (N-C28)
H-OCTADECANE (N-C18)
H-PROPAHOi
H-TETRACOSANE CN-C24)
H-TETRAOECAKE (N-C14)
H-TRIACOHTANE (N-C30)
H.H-DIHETHYLFORHAHIDE
HAPHTHALEKE
HITROB.ENZENE
0-AHISIDINE
0-CRESOL
0-TOLUIDINE
P-CRESOL
P-CYHEHE
P-DIH£THYLAMINOAZOBEHZENE
PENTACHLOR08ENZENE
PENTACHLOROETHANE
PENTAMETHYLBENZENE
PERYLEHE
PKEHACETIH
PHEHAHTHREHE
PHEHOL
PREHOTHIAZINE
FROM AH IDE
PYRENE

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2'
2
2
2
2
2
2
2
2
2
2
2
2 '
2
NO. OF
MILLS
NGN-DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
2
0
2
2
2
2
2
2
2
2
2
2
2
2
1
2

NO. OF
DATA POINTS
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5

NO. OF
. NON-DETECTS
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
4
5
5
5
5
5
3
5
5
5
5
5
5
5
5
5
5
5
5
4
5


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L'
UG/L
•H
, ruKNiar
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
i=aw -------
MINIMUM
10.00
20.00
10.00
20.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND •
ND
ND

ND

MAXIMUM
10.00
20.00
10.00
20.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
55.00
10.00
10.00
10.00
10.00
10.00
306.00
10.00
10.00
10.00
20.00
20.00
20.00
10,00
10.00
10.00
10.00
10.00
50.00
21.00
10.00

-------
                                TABLE C-5

           LONG-TERM  STUDY AND  SHORT-TERM STUDY CONCENTRATIONS

SAMPLE POINT CATEGORY NAME=ACID STAGE FILTRATE SUBCATEGORY=BPK
                                
-------
                                                           TABLE C-5
                                                                                                                              36
                                       LONG-TERM STUDY AND SHORT-TERM STUDY  CONCENTRATIONS

                            SAMPLE POINT CATEGORY NAME=ACID STAGE FILTRATE SUBCATEGORY=BPK  FURNISH=SU
                                                           (continued)
CHEMICAL NAME

2,6-DIHlTROTOLUENE
3-BROHOCHLOR08ENZENE
3-CHLOROHITROBEHZEHE
3-HETHYLCHOUNTHRENE
3-HITRCAHILIHE
3,3«-DlCHLOROB£HZIDIHE
3,3(-DIH£THOXY8EHZIDIHE
3,5-DlBROKO-4-HYDROXYBENZONITR
3,6-DIHETHYLPHENANTHRENE
4-AHIHOBIPBEHYL
4-BROHOPHEHYL PHEHYL ETHER
4-CHLORO-2-HITROANILINE
4-CHLO&0-3-HETHYLPHEHOL
4-CHLOROAMIL1K6
4-CHLOROPHENYL PHEHYL ETHER
4-H1TROAHIL1NE
4-HITROSIPHEHYL
4-MmoPHeHOt
4,4«-HeTHYLEN£BIS<2-CHLOROANI)
4,5-HeTHYLEHEPHENANTHRENE
5-CHLORO-O-TOtUIDIHE
5-NITRO-O-TOLUIDINE
7,12-DIH£WLBENZCA)ANTHRAC£NE
ALUMINUM
ANTINOMY
ARSENIC
BARIUM
BERYLLIUM
BISMUTH
BOSOM
CADMIUM
CALCIUM
CERIUM
CHROMIUM
COBALT
COPPER
DYSPROSIUM
ERBIUM
EUROPIUM
GADOUHIUM
GALLIUM
GERHAHIUH
COLD
KAFHIUH
HOLHIKUH
1M01UH
IODINE
1R1DIUH
IRON
LANTHANUM
LEAD
LITHIUM
LUTETIUH

NO. OF
HILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
'2
2
2
2
2
2
2
2. '
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON-DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
0
2
2
• o
2
2
1
1
0
2
1
2
1
2
2
2
2
2 •
2
2
2
2
2
0
2
0
2
2
2
2

NO. OF
DATA POINTS
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
S
5
5
5
5
5
15
5
5
5
15
5
5
5
15
15
15
15
15
15
15
15
15
15
9
15
5
15
5
15
15

NO. OF
NON-DETECTS
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
0
5
5
1
5
15
4
4
0
15
4
5
4
15
15
15
15
15
15
15
15
15
15
6
15
0
15
5
15
15


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
                                                                                                               MAXIMUM
                                                                                                     MINIMUM   SYMBOL
  10.00
  10.00
  50.00
  10.00
  20.00
  50.00
  50.00
  50.00
  10.00
  10.00
  10.00
  20.00
  10.00
  10.00
  10.00
  50.00
  10.00
  50.00
  20.00
  10.00
  10.00
  10.00
  10.00
 293.00
   6.00
   2.00
  53.00
   2.00

  10.00
   5.00
6390.00

  10.00
  25.00
   8.00
 175.00

  50.00
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND'
ND

ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
  MAXIMUM

    10.00
    10.00
    50.00
    10.00
    20.00
    50.00
    50.00
    50.00
    10.00
    10.00
    10.00
    20.00
    10.00
    10.00
    10.00
    50.00
    10.00
    50.00
    20.00
    10.00
    10.00
    10.00
    10.00
  2300.00
     6.00
  <  20.00
  1040.00
     2.00

   111.00
     5.00
125000.00

    10.00
    25.00
    50.00
  2950.00

  1000.00

    50.00

-------
                    TABLE C-5
                                                                                        37
LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS



CHEMICAL NAME
MAGNESIUM
MANGANESE
MERCURY
MOLYBDENUM
NEOOYMIUH
NICKEL
NIOBIUM
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SELENIUM
SILICON
SILVER
SODIUM
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIN
TITANIUM
TUNGSTEN
URANIUM
VANADIUM
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM


NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
, 2
SAMKLt KU1NI t
NO. OF
MILLS
NON -DETECT
0
0
0
2
2
2
2
'2
2
0
2
0
2
2
2
2
2
2
2
0
2
0
0
0
2
2
2
2
2
2
2
0
2
2
0
2
2
0
2
AlbliOKT NAMt=AU

NO. OF
DATA POINTS
5
5
5
5
15
5
15
15
15
7
15
7
15
15
15
15
15
15
5
5
5
5
7
5
15
15
15
5
15
15
5
5
15
15
5
15
5
5
15
ID STAGE F1LTI
(continued)

NO. OF
NON-OETECTS
1
0
0
5
15
5
15
15
15
3
15
3
15
15
15
15
15
15
5
0
5
0
3
0
15
15
15
5
15
15
5
3
15
15
3
15
5
0
15
                                   UNITS

                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
MINIMUM
SYMBOL

  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND

  ND

  ND

  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND

  ND

MINIMUM
4760.00
436.00
2.40
10.00

22.00












3.00
5000.00
6.00
365000.00

43600.00



2.00


30.00
5.00


13.00

5.00
56.00
MAXIMUM
SYMBOL



ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

ND



ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND


MAXIMUM
52900.00
6570.00
28.00
10.00

22.00



5100.00

3000.00






3.00
18800.00
6.00
627000.00
600.00
57200.00



47.00


30.00
17.00


94.00

5.00
603.00
                                                                     ND

-------
                                                           TABLE  C-6
                                                                                                                              38
                                       LONG-TERM STUDY AMD  SHORT-TERM STUDY CONCENTRATIONS
CHEMICAL HAKE

2,3,7,8-TETRACHLOROOIBENZO-P-DIOXIN
1,2,3,7,8-PENTACm.ORODIBENZO-P-DIOXIN
1,2,3,4,7,8-HEXACHLORODIBENZO-P-DIOXIN
1,2,3,6,7,8-HEXACHLOROOIBENZO-P-DIOXIN
1,2,3,7,8,9-HEXACHLORODIBENZO-P-DIOXIN
1,2,3.4,6,7,8-H£PTACHLORODlBENZQ-P-DIOXI
OCTACHLORODIBEHZO-P-DIOXIN
2,3,7,8-TETRACHLOROOlBENZOFURAN
1,2,3,7,8-PEHTACHLORODIBENZOFURAN
2,3,4,7,8-PEHTACHLOROOIBENZOFURAN
1,2,3,4,7,8-HEXACHLORODIBENZOFURAN
1,2,3,6,7,8-HEXACHLORODIBEHZOFURAN
1,2,3,7,8,9-HEXACHLORODIBENZOFURAN
2,3,4,6,7,8-HEXACHLORODIBENZOFURAH
1,2,3,4,6,7,8-BEPTACKLOROOlBENZOFURAN
1,2,3,4,7,8,9-HEPTACHLOROOIBENZOFURAN
OCTACHLOROOIBEHZOFURAN
4-CHlOROPHENOL
4-CHiOROCATECHOC
4-CHLoaOGUAIACOt
5-CHIOROGUA1ACOL
5-CHLOROVAHILLIM
6-CHLOROVAHILL1N
2- CHtOROSYRIHGALDEHYDE
2,4-DlCHLOROPHENOL
2,6-DlCHLOfiOPHENOL
3,4-DlCHlOROPHENOL
3.5-DlCHLOROPHENOL
3,4-DlCHLOROCATECHOL
3,5-DlCHLOROCATECHOL
3,6-DlCHLOROCATECHOL
4,5-DICHLOROCATECHOL
3.A-D1CHLOROGUAIACCL
4,5-DlCHLOROGUAIACOt
4,6-DICHLOROGUAlACOL
5,6-DlCHLOROVAHILLIN
2,6-DlCHLOROSYRINGALDEHYDE
2,3,6-TRICHLOROPHENOL
2,4,5-TRlCHLOROPHEHOL
2,4,6-TR1CHLOfiOPHEHOL
3,4,5-TRICHLOROCATECHOL
3,4,6-TRICHlOROCATECHOL
3,4,5-TRlCHlOROGUAlACOL
3,4,6-TRICHLOROCUAlACOt
4,5,6-TRICHtOROGUAIACOL
TRICHtOROSYRIHGOt
2,3,4,6-TETRACHLOROPHENOt
TETRACHLOROCATECHOL
TETRACHIOROGUAIACOL
PEHTACHLOROPHENOL
ACRYLOHITRILE
BEHZENE
8ROHOD1CHLOROKETHANE
BftOHOHETHAHE
EGORY NAME=ALKALINE

NO. OF
MILLS
11
10
10
10
10
10
8
11
10
10
10
10
10
10
10
10
9
8
5
8
3
5
10
8
9
11
6
6
8
2
6
11
5
11
10
9
8
6
11
11
11
5
11
8
11
11
11
11
9
11
11
11
11
11
NO. OF
MILLS
NON-DETECT
5
10
10
10
9
7
3
2
9
9
10
10
10
10
10
10
7,
o'
4
2
2
0
2
7
2
11
6
6
5
2
3
7
2
2
5
3
7
4
10
4
5
3
3
3
1
9
8
5
3
8
11
11
11
11
STAGE FILTRATE SUBCATEGORY=BPK FUKNISH=SW 	

NO. OF
DATA POINTS
82
18
18
17
18
16
9
83
18
18
18
18
18
18
17
17
17
81
66
77
7
72
86
76
83
88
13
13
74
5
73
86
72
87
79
80
76
13
86
85
78
67
87
76
81
83
85
79
83
89
88
89
89
89

NO. OF
NON-DETECTS
66
18
18
17
17
13
4
57
17
17
18
18
18
18
17
17
15
14
64
12
4
19
6
62
25
88
13
13
64
5
66
41
21
17
52
23
61
10
83
25
58
63
27
45
26
67
66
68
45
75
88
89
89
89


UNITS
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
8.00
2.00
6.00
8.00
4.00
10.00
100.00
10.00
4.00
3.00
4.00
3.00
4.00
3.00
2.00
2.00
11.00
1.25
1.20
1.25
5.00
2.50,
2.50
2.40
1.00
1.60
1.60
1.60
1.20
5.00
2.50
2.50
2.50
2.50
2.50
5.00
4.90
1.00
1.00
1.00
1.00
4.90
1.00
2.40
2.50
1.60
1.00
1.60
1.00
1.00
10.00
5.00
5.00
5.00

MAXIMUM
SYMBOL

ND
ND
ND






ND
ND
ND
ND
ND
ND









ND
ND
ND

ND
>


>
>







>







ND
ND
ND
ND


MAXIMUM
320.00
227.00
100.00
100.00
100.00
170.00
2000.00
1900.00
64.00
30.50
100.00
227.00
227.00
238.00
357.00
278.00
6500.00
57.43
1.80
150.00
29.00
594.80
7505.00
43.00
250.00
5.00
5.00
5.00
19.00
5.00
50.00
80.40
92.99
5000.00
50.00
509.00
160.00
3.00
7.00
210.00
49.00
7.70
500.00
40.00
300.00
38.00
35.60
29.00
470.00
12.10
100.00
20.00
20.00
100.00

-------
                                                             TABLE C-6
                                                                                                                                  39
                                         LONG-TERM STUDY AND SHORT-TERM STUDY  CONCENTRATIONS
 CHEMICAL NAME

 CARBON DISULFIDE
 CHLOROACETONITRILE
 CHLOROBENZENE
 CHLOROETHANE
 CHLOROFORM
 CHLOROMETHANE
 CIS-1.3-DICHLOROPROPENE
 CROTONALDEHYDE
 DIBROMOCHLOROMETHANE
 DIBROMOMETHANE
 DIETHYL ETHER
 ETHYL CYANIDE
 ETHYL METHACRYLATE
 ETHYLBENZENE
 IODOMETHANE
 ISOBUTYL ALCOHOL
 M-XYLENE
 METHYL METHACRYLATE
 METHYLENE CHLORIDE
 0+P XYLENE
 TETRACHLOROETHENE
 TETRACHLOROMETHANE
 TOLUENE
 TRANS-1,2-DICHLOROETHENE
 TRANS-1,3-D ICHLOROPROPENE
 TRANS-1.4-DICHLORO-2-BUTENE
 TRIBROMOMETHANE
 TRICHLOROETHENE
 TRICHLOROFLUOROMETHANE
 VINYL  ACETATE
 VINYL  CHLORIDE
 1,1-DICHLOROETHANE
 1,1-DICHLOROETHENE
 1,1,1-TRICHLOROETHANE
 1,1,1,2-TETRACHLOROETHANE
 1,1,2-TRICHLOROETHANE
 1,1,2,2-TETRACHLOROETHANE
 1,2-DIBROMOETHANE
 1,2-DICHLOROETHANE
 1,2-DICHLOROPROPANE
 1,2,3-TRICHLOROPROPANE
 1,3-BUTADIENE, 2-CHLORO
 1,3-DICHLOROPROPANE
 1,4-DIOXANE
 2-BUTANONE  (MEK)
 2-CHLOROETHYLVINYL ETHER
 2-HEXANONE
 2-PROPANONE (ACETONE)
 2-PROPEN-1-OL
 2-PROPENAL (ACROLEIN)
 2-PROPENENITRILE. 2-METHYL-
3-CHLOROPROPENE
4-METHYL-2-PENTANONE


NO. OF
MILLS
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
10
11
11
11
11
11
11
11
11.
11
6
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
10
11
11
11
11
11
11
11
11

NO. OF
MILLS
NON-DETECT
9
11
11
11
0
10
11
11
11
11
11
11
11
11
11
10
11
11
6'
11
11
11
10
11
11
11
11
8
5
9
11
11
10
11
11
11
11
11
10
11
11
11
11
11
2
11
11
2
10
11
10
11
11
(continued;
,
NO. OF
DATA POINTS
87
89
89
89
89
88
89
89
89
89
86
89
89
89
89
89
89
89
69
89
88
89
89
89
89
89
89
88
15
89
89
89
89
88
89
88
88
89
89
89
89
89
89
81
86
89
89
81
89
89
89
89
89
L k. i t\n i b a\jo\*n 1
)

NO. OF
NON-DETECTS
85
89
89
89
2
87
89
89
89
89
86
89
89
89
89
88
89
89
59
89
88
89
88
89
89
89
89
83
12
87
89
89
88
88
89
88
88
89
88
89
89
89
89
81
54
89
89
r
88
89
88
89
89
cuwiv i — Dri


UNITS •
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
v runnion-;

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND



MINIMUM
10.00

5.00
5.00
10.00
5.00


5.00
'
5.00


5.00




5.00

5.00
5.00
5.00
5.00
5.00

5.00
5.00
10.00

5.00
5.00
5.00
5.00

5.00
5.00

5.00
5.00



10.00
50.00
5.00

50.00

20.00





MAXIMUM
SYMBOL

ND
ND
ND
>

ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND
ND

ND
ND
ND
ND



ND
ND

ND
ND
ND
ND
ND

ND
ND
ND
ND
ND

ND
ND


ND

ND
ND



MAXIMUM
47.55
20.00
20.00
100.00
3276.03
166.22
20.00
100.00
20.00
20.00
100.00
20.00
20.00
20.00
20.00
45.37
20.00
20.00
1095.00
20.00
20.00
20.00
117.67
20.00
20.00
100.00
20.00
19.02
33.40
3938.16
20.00
20.00
1122.00
20.00
20.00
20.00
20.00
20.00
1788.00
20.00
20.00
20.00
20.00
200.00
433.00
20.00
100.00
2334.90
243.95
100.00
175.78
20.00
100.00

-------
                                                           TABLE  C-6

                                       LONG-TERM STUDY AND SHORT-TERM  STUDY CONCENTRATIONS

                          SAMPLE POINT CATEGORY NAME=ALKALINE STAGE FILTRATE SUBCATEGCIRY=BPIC FURNISH=SW
                                                           (continued)
                                                                                                                              40
CHEMICAL NAME
                           CAOX)
AOSORBA8LE ORGANIC KALIDES
COD
ACEHAPHTHENE
ACEKAPHTHYLENE
ACETOPHENONE
ALPKA-HAPHTHYLAMINE
ALPHA-PICOLIHE
ALPKA-TERPIHEOL
ANILINE
ANTHRACENE
ARAHITE
B-KAPHTHYLAHINE
IEHZAHTHRONS
BEHZEHETHIOL
BENZIDIHE
BEHZOCA>ANTKRAC£NE
B£NZO(A>PYREN£
BENZOWFLUORAHTHENE
BENZOCGHDPERYLEHE
BENZOOOFLUORAHTHENE
BEHZOIC ACID
BENZYL ALCOHOL
BIPHENYL
BIS (2-CHLOROISOPROPYL) ETHER
EISETH£R
-------
                                                         TABLE C-6
                                                                                                                              41
                                     LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
 CHEMICAL NAME

 HEXACHLOROETHANE
 HEXACHLOROPROPENE
 HEXAN01C ACID
 INDENO<1,2,3-CD)PYRENE
 ISOPHORONE
 ISOPROPANOL
 ISOPROPYL ETHER
 ISOSAFROLE
 LONGIFOLENE
 MALACHITE GREEN
 METHAPYRILENE
 METHYL METHAMESULFONATE
 N-BUTANOL
 N-DECANE (N-C10)
 N-DOCOSANE (N-C22)
 N-DODECANE CN-C12)
 N-EICOSANE CN-C20)
 N-HEXACOSANE  (N-C26)
 N-HEXADECANE  (N-C16)
 N-NITROSODI-N-BUTYLAMINE
 N-NITROSODI-N-PROPYLAMINE
 N-NITROSODIETHYLAMINE
 N-NITROSODIMETHYLAMINE
 N-NITROSODIPHENYLAMINE
 N-NITROSOMETHYLETHYLAMINE
 N-NITROSOMETHYLPHENYLAMINE
 N-NITROSOMORPHOLINE
 N-NITROSOPIPERIDINE
 N-OCTACOSANE  
-------
                                                           TABLE  C-6

                                       LONG-TERM STUDY AND SHORT-TERM  STUDY CONCENTRATIONS

                          SAMPLE POINT CATEGORY NAME=AUCALINE STAGE FILTRATE SUBCATEGORY=BPK FURNISH=SU
                                                           (continued)
                                                                                                                              42
CHEMICAL HAKE

PYRIDINE
SAFROLE
SOUALEHE
STYREHE
T-BUTA«0L
TH1AKAPHTHENE
THIOACETAHIDE
THIOXAMTHONE
7RIPHEHYLENE
TRIPROPYLENEGLYCOL METHYL ETHER
1-KETHYLFtUORENE
1-HETHYLPHEHAMTHREHE
1-PHEMYLMAPHTHALENE
1.2-DIBROHO-3-CHLOROPROPAKE
1,2-DICHLOROSEHZEHE
1,2-D1PHEHYLHYDRAZINE
1,2,3-TRICHLOROBENZENE
1,2,3-TRIHETHOXYBEHZENE
1,2,3,4-DlEPCXYBUTANE
1,2,4-TRICHIOROBENZENE
1,2,4,5-TETRACHLOROBEMZENE
1,3-BEMZEHEOIOt (RESORCIHOL)
1.3-DICHLORO-2-PROPANOL
1,3-DICHLOROBENZENE
1,3-DlHITROeEUZENE
1,3,5-TRlTHIANE
1,4-D1CHLOROBEHZENE
1,4-HAPHTHOQUINONE
1,5-HAPHTHALENED1AMIHE
2-
-------
                                                             TABLE C-6
                                                                                                                                 43
                                        LONG-TERM STUDY AND  SHORT-TERM STUDY CONCENTRATIONS
 CHEMICAL NAME

 3-BROMOCHLOROBENZENE
 3-CHLORONITROBENZENE
 3-METHYLCHOLANTHRENE
 3-NITROANILINE
 3,3'-DICHLOROBENZIDINE
 3,3'-DIMETHOXYBENZIDINE
 3,5-DIBROMO-4-HYDROXYBENZONITR
 3,6-DIMETHYLPHENANTHRENE
 4-AMINOBIPHENYL
 4-BROMOPHENYL PHENYL ETHER
 4-CHLORO-2-NITROANIL1NE
 4-CHLORO-3-METHYLPHENOL
 4-CHLOROANILINE
 4-CHLOROPHENYL PHENYL ETHER
 4-NITROANILINE
 4-NITROBIPHENYL
 4-NITROPHENOL
 4,4'-METHYLENEBIS(2-CHLOROANI)
 4,5-METHYLENEPHENANTHRENE
 5-CHLORO-O-TOLUIDINE
 5-NITRO-O-TOLUIDINE
 7,12-DIMETHYLBENZ(A)ANTHRACENE
 ALUMINUM
 ANTIMONY
 ARSENIC
 BARIUM
 BERYLLIUM
 BISMUTH
 BORON
 CADMIUM
 CALCIUM
 CERIUM
 CHROMIUM
 COBALT
 COPPER
 DYSPROSIUM
 ERBIUM
 EUROPIUM
 GADOLINIUM
 GALLIUM
 GERMANIUM
 GOLD
 HAFNIUM   .
 HOLMINUM
 INDIUM
 IODINE
 IRIDIUM
 IRON
 LANTHANUM
 LEAD
 LITHIUM
 LUTETIUM
MAGNESIUM
(continued)

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON-DETECT
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
0
2
2
1
2
2
2
2
0
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
0
2
2
2
2
1

NO. OF
DATA POINTS
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
9
3
3
3
9
3
3
3
9
9
9
9
9
9
9
9
9
9
9
9
3
9
3
9
9
3

NO. OF
NON-DETECTS
3
3
3
3
3
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
3
1
3
3
2
3
9
3
3
0
9
3
3
3
9
9
9
9
9
9
9
9
9
9
9
9
0
9
3
9
9
2


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND


MINIMUM
10.00
50.00
10.00
20.00
50.00
50.00
50.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
10.00
50.00
20.00
10.00
10.00
10.00
10.00
171.00
6.00
2.00
67.00
2.00

10.00
5.00
9360.00

10.00
25.00
8.00












145.00

50.00


2650.00

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND.
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND



MAXIMUM
10.00
50.00
10.00
20.00
50.00
51.00
50.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
10.00
50.00
20.00
10.00
10.00
10.00
10.00
1010.00
60.00
20.00
268.50
2.00

56.00
5.00
30600.00

10.00
25.00
14.00












661 .50

50.00


9985.00

-------
                                 TABLE C-6

             LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS

SAMPLE POINT CATEGORY NAHE=ALKALINE STAGE FILTRATE SUBCATEGORY=BPK  RJRNISH=SU
                                                                                                     44


CHEMICAL NAME
MANGANESE
MERCURY
MOLYBDENUM
NEOOYHIUH
NICKEL
HIOBIUH
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASS1UH
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SELENIUM
SILICON
SILVER
SODIUM
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIM
TITANIUM
TUNGSTEN
URANIUM
VANADIUM
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM

NO. OF
MILLS
2
2
2
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
Z
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Mine ruiwi wt
NO. OF
MILLS
NON-DETECT
0
0
2
2
2
2
2
2
0
2
0
2
2
2
2
2
2
2
0
2
0
0
0
2
'2
2
2
2
2
2
1
2
2
1
2
2
0
2
1 CUUTV i nm'ib.~nuiv
NO. OF
DATA POINTS
3
3
3
9
3
9
9
9
5
9
5
9
9
9
9
9
9
3
3
3
3
5
3
9
9
9.
3
9
9
3
3
9
9
3
9
3
3
9
ni_*r«h. »* • *-»»*ta. • .
(continued:
NO. OF
NOM-DETECTS
0
0
3
9
3
9
9
9
3
9
3
9
9
9
9
9
9
3
0
3
0
3
0
9
9
9
3
9
9
3
2
9
9
2
9
3
0
9
                                               UNITS
                                                        MINIMUM
                                                        SYMBOL
MINIMUM
           MAXIMUM
           SYMBOL
MAXIMUM
0
0
3
9
3
9
9
9
3
9
3
9
9
9
9
9
9
3
0
3
0
3
0
9
9
9
3
9
9
3
2
9
9
2
9
3
0
9
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L


ND
ND
NO
ND
ND
MD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND

ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
312.00
24.00
10.00

22.00












3.00
9000.00
6.00
1400000.00

48100.00



20.00


30.00
5.00


13.00

5.00
34.00



ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

ND



ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND

ND
2495.00
30.50
10.00

22.00



2200.00

2800.00






3.00
15150.00
6.00
1815000.00
200.00
roipo.oo



72.00


30.00
5.50


53.50

5.00
304.00


-------
                                                         TABLE C-7
                                                                                                                             45
 CHEMICAL NAME
             .  LONG-TERM STUDY AND SHORT-TERM  STUDY  LOADINGS

SAMPLE POINT CATEGORY NAME=BLEACH PLANT  EFFLUENT SUBCATEGORY=BPK FURNISH=HW

                          NO.  OF
                 NO.  OF    MILLS     NO. OF
                  MILLS NON-DETECT DATA  POINTS NON-DETECTS
 2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN        10        2          68
 1,2,3,7,8-PENTACHLORODIBENZO-P-DIOXIN      10        9          22
 1,2,3,4,7,8-HEXACHLORODIBENZO-P-DIOXIN     10        9          22
 1,2,3,6,7,8-HEXACHLORODIBENZO-P-DIOXIN     10        9          22
 1,2,3,7,8,9-HEXACHLORODIBENZO-P-DIOXIN     10       10          22
 1,2.3,4,6,7,8-HEPTACHLORODIBENZO-P-DIOXI    10        5          21
 OCTACHLORODIBENZO-P-DIOXIN                  70          10
 2,3,7,8-TETRACHLORODIBENZOFURAN            10        1          68
 1,2,3,7,8-PENTACHLORODIBENZOFURAN          10       10          22
 2,3,4,7,8-PENTACHLORODIBENZOFURAN          10       10          22
 1,2,3,4,7,8-HEXACHLORODIBENZOFURAN         10       10          22
 1,2,3,6,7,8-HEXACHLORODIBENZOFURAN         10       10          22
 1,2,3,7,8,9-HEXACHLORODIBENZOFURAN         10       10          22
 2,3,4,6,7,8-HEXACHLORODIBENZOFURAN         10        9          22
 1,2,3,4,6,7,8-HEPTACHLORODIBENZOFURAN      10        9          22
 1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN      10       10          22
 OCTACHLORODIBENZOFURAN                       96          20
 4-CHLOROPHENOL                               70          75
 4-CHLOROCATECHOL                             3        1           43
 4-CHLOROGUAIACOL                             72          70
 5-CHLOROGUAIACOL                             42          21
 5-CHLOROVANILLIN                             30          53
 6-CHLOROVANILLIN                             9        1           78
 2-CHLOROSYRINGALDEHYDE                       7        1           72
 2,4-DICHLOROPHENOL                           80         80
 2,6-DICHLOROPHENOL                          10       .5          86
 3,4-DICHLOROPHENOL                           77         32
 3,5-DICHLOROPHENOL                      '75          32
 3,4-DICHLOROCATECHOL                         73          66
 3,5-DICHLOROCATECHOL                         4        1          21
 3,6-DICHLOROCATECHOL                         40          53
 4,5-DICHLOROCATECHOL                        10       2          80
 3,4-DICHLOROGUAIACOL                         30          51
 4,5-DICHLOROGUAIACOL                        10        2          85
 4,6-DICHLOROGUAIACOL                        93          75
 5,6-DICHLOROVANILLIN                        94          80
 2,6-DICHLOROSYRINGALDEHYDE                   70          72
 2,3,6-TRICHLOROPHENOL                       7       5          32
 2,4,5-TRICHLOROPHENOL                       10        6          83
 2,4,6-TRICHLOROPHENOL                       10  '      1          84
 3,4,5-TRICHLOROCATECHOL                     10        4          75
 3,4,6-TRICHLOROCATECHOL                     3        1          46
 3,4,5-TRICHLOROGUAIACOL                     10        2          81
3,4,6-TRICHLOROGUAIACOL                     72          72
4,5,6-TRICHLOROGUAIACOL                    10        0          80
 TRICHLOROSYRINGOL                          10        0          82
 2,3.4,6-TETRACHLOROPHENOL                  10        5          82
TETRACHLOROCATECHOL                        10        1          77
TETRACHLOROGUAIACOL                         82          80
PENTACHLOROPHENOL                          10        8          86
ACRYLONITRILE                              10       10          85
BENZENE                                    10        9          85
BROMODICHLOROMETHANE                       10        6          85
BROMOMETHANE                               10       10          86
JD\*n i cu
10. OF
MINIMUM
•DETECTS UNITS
60
20
21
20
22
12
1
40
22
22
22
22
22
21
21
22
17
17
16
39
15
6
17
15
33
75
32
24
30
11
25
26
23
20
30
24
8
25
70
9
27
29
37
44
26
17
68
41
66
82
85
84
49
86
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
' KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
MINIMUM
5.63E-11
7.82E-11
7.45E-11
7.82E-11
1.06E-10
9.08E-10
1.86E-09
5.90E-11
5.63E-11
6.31E-11
7.45E-11
6.31E-11
9.17E-11
7.45E-11
5.90E-11
7.00E-11
1.42E-10
7.12E-06
2.61E-05
7.12E-06
1.19E-05
5.56E-05
1.19E-05
1.81E-05
3.63E-06
1.09E-05
7.12E-06
7.12E-06
5.19E-05
1.81E-05
5.22E-05
2.37E-05
2.90E-05
1.19E-05
7.12E-06
1.19E-05
3.08E-05
3.81E-06
7.12E-06
1.19E-05
7.12E-06
6.48E-05
2.38E-06
1.19E-05
7.12E-06
1.14E-05
7.64E-06
7.12E-06
2.37E-06
2.37E-06
5.80E-04
1.16E-04
1.16E-04
5.80E-04
MAXIMUM
SYMBOL MAXIMUM
3.56E-09
1.52E-09
5.91E-10
6.53E-10
ND 2.89E-09
1.31E-07
3.40E-06
8.93E-09
ND 2.89E-09
ND 2.89E-09
ND 2.89E-09
ND 2.89E-09
ND 2.89E-09
3.66E-10
3.78E-09
ND 2.89E-09
2.98E-08
1 .48E-03
2.67E-03
1.36E-04
1.01E-03
1.92E-03
1.27E-02
8.06E-03
3.01E-03
5.53E-04
ND 1.93E-04
1.20E-03
3.54E-03
3.42E-03
1.51E-03
3.14E-03
3.26E-04
3.75E-03
6.10E-04
3.67E-03
3.29E-03
1.19E-04
8.07E-04
7.05E-03
6.87E-03
2.49E-04
9.35E-03
1.32E-03
3.64E-03
1 .37E-03
6.24E-04
5.76E-03
1.46E-03
3.52E-03
ND 7.67E-03
1 -85E-02
2.38E-03
ND 7.67E-03

-------
                                                         TABLE C-7

                                        LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
                                                                                                                            46
CHEMICAL HAKE
CARBON DISULFIDE
CHLOROACETOHITRILE
CHLOROBENZENE
CHtOROETKAHE
CHLOROFORM
CHtOROHETHAHE
C1S-1.3-DICHLOROPROPENE
CROTONALOEHYDE
DIBROMOCHLOROMETHANE
D1BRCMOHETHAHE
DIETHYt ETHER
ETHYL CYANIDE
ETHYL HETHACRYUTE
ETHYLBENZENE
1000HETHAHE
ISOBUTYL ALCOHOL
H-XYLENE
METHYL HETHACRYLATE
H6THYLEHE CHLORIDE
0+P XYLEHE
TETRACHLOROETHENE
TETRACHLOROHETHANE
TOLUENE
TRAMS-1.E-DICHLOROETHENE
TRANS-1.3-DICHLOROPROPENE
TRANS-1,4-DICHLORO-2-BUTENE
TRIBROKOHETHANE
TRICWLOROETHENE
tR1CHLOROFLUOROMETHANE
V1HYL ACETATE
V1HYL CHLORIDE
1,1-DICHLOROETHANE
1,1-DICHLOROETHENE
1,1,1-TRICHLOROETHANE
1,1,1,2-TETRACHLOROETHAHE
1,1,2-TRICHLOROETHAME
1,1,2,2-TETRACHLOROETHANE
1,2-DIBROMOETHANE
1,2-DICHLOROETHAME
1,2-DICHLOROPROPANE
1,2,3-TRlCHLOROPROPAHE
1,3-BOTAOIENE,  2-CHLORO
1,3-DICHLOROPROPANE
1,4-DIOXANE
2-BUTANONE (HEK)
2-CHLOROETHYLVIHYL ETHER
2-KEXAHONE
2-PROPANOWE (ACETONE)
2-PROPEM-1-OL
2-P80PEHAL CACROLEIN)
 2-PROPENEHITRILE, 2-HETHYL-
3-CHIOROPROPENE
 4-K£THYL-2-PEHTANO«E
INT CATEGORY NAME=BLEACH PLANT EFFLUENT SUBCATEGORY=BPK FURNISH=HW 	
(continued)
NO. OF
NO. OF MILLS NO. OF NO. OF MINIMUM MAXIMUM
MILLS NOM-DETECT DATA POINTS NON-DETECTS UIUITS SYMBOL MINIMUM SYMBOL
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
9
10
10
10
10
10
10
10
10
10
7
10
10
10
10
10
10
9
10
10
10
10
10
10
10
10
9
10
10
9
10
10
10
10
10
5
10
10
10
0
6
10
9
10
10
9
9
10
9
9
9
9
10
6
9
8
7
9
10
10
10
9
10
5-
9
9
9
10
8
10
9
10
10
9
9
10
• 10
10
9
2
9
10
1
10
10
9
10
10
86
86
86
86
85
85
86
86
86
86
82
86
86
86
86
86
86
86
70
86
84
86
86
86
86
86
86
84
28
86
86
85
86
84
86
84
86
86
86
86
86
86
86
78
82
86
86
74
86
85
86
86
86
62
86
86
86
0
81
86
85
86
86
80
85
86
85
85
85
85
86
57
85
82
80
85
86
86
86
85
84
20
85
85
84
86
77
86
84
86
86
85
85
86
86
86
77
57
85
86
7
86
85
85
86
86
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
ND
ND
ND
ND
>
ND
HD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
I1D
HD
ND
ND
ND
ND
ND
ND
ND
ND
1.16E-04
1.16E-04
1.16E-04
5.80E-04
1.95E-03
5.80E-04
1.16E-04
6.11E-04
1.16E-04
1.16E-04
5.80E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1 .16E-04
5.80E-04
1.16E-04
1.16E-04
1 .39E-04
5.80E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.16E-04
1.22E-04
6.11E-04
1.16E-04
5.80E-04
6.94E-04
1.16E-04
5.80E-04
1.16E-04
1.16E-04
5.80E-04

ND
ND
ND
•

ND

ND
ND


ND




NO





ND
ND
ND

ND




ND

ND
ND
ND
ND


ND
ND
ND



ND

ND
ND

ND
ND
MAXIMUM
1.93E-03
1.53E-03
1.53E-03
7.67E-03
4.05E-01
5.76E-01
.53E-03
.17E-03
.53E-03
.53E-03
.76E-02
.12E-03
.53E-03
1.53E-03
2.37E-04
3.25E-03
3.96E-03
1.53E-03
3.44E-02
1.68E-03
3.16E-04
6.25E-02
3.20E-04
1 .53E-03
1.53E-03
7.67E-03
6.24E-03
1.53E-03
6.37E-02
3.56E-02
3.39E-04
6.22E-03
1.53E-03
6.99E-02
1 .53E-03
1.53E-03
1.53E-03
1.53E-03
7.38E-04
2.75E-04
1.53E-03
1 .53E-03
1.53E-03
3.57E-02
1.65E-01
8.37E-04
7.67E-03
3.05E-01
1.53E-03
7.67E-03
4.93E-03
1.53E-03
7.67E-03

-------
                                                         TABLE C-7
                                                                                                                             47
                                         LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
 CHEMICAL  NAME

 ADSORBABLE ORGANIC  HALIDES  (AOX)
 COD
 ACENAPHTHENE
 ACENAPHTHYLENE
 ACETOPHENONE
 ALPHA-NAPHTHYLAMINE
 ALPHA-P1COLINE
 ALPHA-TERPINEOL
 ANILINE
 ANTHRACENE
 ARAMITE
 B-NAPHTHYLAMINE
 BENZANTHRONE
 BENZENETHIOL
 BENZIDINE
 BENZOCA)ANTHRACENE
 BENZO(A)PYRENE
 BENZOCB)FLUORANTHENE
 BENZOCGHDPERYLENE
 BENZO(K)FLUORANTHENE
 BENZOIC ACID
 BENZYL ALCOHOL
 BIPHENYL
 BIS (2-CHLOROISOPROPYL) ETHER'
 BISCCHLOROMETHYDETHERCNR)
 BIS(2-CHLOROETHOXY)METHANE
 BISC2-CHLOROETHYUETHER
 BIS<2-ETHYLHEXYL)PHTHALATE
 BUTYL BENZYL PHTHALATE
 CARBAZOLE
 CHRYSENE
DI-N-BUTYL AMINE
DI-N-BUTYL PHTHALATE
DI-N-OCTYL PHTHALATE
DIBENZOCA,HJANTHRACENE
DIBENZOFURAN
DIBENZOTHIOPHENE
DICHLORODIFLUOROMETHANE (NR>
DIETHYL PHTHALATE
DIMETHYL PHTHALATE
DIMETHYL SULFONE
DIPHENYL ETHER
DIPHENYLAMINE
DIPHENYLDISULFIDE
ETHANOL
ETHYL METHANESULFONATE
ETHYLENETHIOUREA
ETHYNYLESTRADIOL 3-METHYL ETHER
FLUORANTHENE
FLUORENE
HEXACHLORO-1,3-BUTADIENE
HEXACHLOROBENZENE
HEXACHLOROCYCLOPENTADIENE
(continued)

NO. OF
MILLS
6
7
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON-DETECT
0
1
2
2
1
2
2
2
2
2
2
.2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
2
1
2
2
2
2
2
2
2
1
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
DATA POINTS
43
32
5
5
5
5
5
5
. 5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5

NO. OF
NON-DETECTS
0
3
5
5
4
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
3
5
5
5
5
5
3
5
5
5
5
5
5
5
3
5
5
5
5
2
5
5
5
5
5
5
5
5
5
5
5
5


UNITS
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT

MINIMUM
SYMBOL
>
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
•ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
6.33E-02
3.60E-01
1 .39E-04
1 .39E-04
1 .39E-04
1.39E-04
6.94E-04
1 .39E-04
1.39E-04
1.39E-04
6.94E-04
6.94E-04
6.94E-04
1 .39E-04
6.94E-04
1 .39E-04
1 .39E-04
1 .39E-04
2.78E-04
1 .39E-04
6.94E-04
1 .39E-04
1 .39E-04
1 .39E-04
1 .39E-04
1 .39E-04
1 .39E-04
1 .39E-04
1 .39E-04
2.78E-04
1.39E-04
1 .39E-04
1 .39E-04
1 .39E-04
2.78E-04
1 .39E-04
1 .39E-04
1 .39E-04
1 .39E-04
1 .39E-04
2.40E-04
1.39E-04
1 .39E-04
2.78E-04
1.39E-04
2.78E-04
2.78E-04
2.78E-04
1.39E-04
1 .39E-04
1 .39E-04
1 .39E-04
1 .39E-04

MAXIMUM
SYMBOL


ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
5.69E+00
1.12E+02
5.66E-04
5.66E-04
2.98E-04
5.66E-04
2.83E-03
5.66E-04
5.66E-04
5.66E-04
2.83E-03
2.83E-03
2.83E-03
5.66E-04
2.83E-03
5.66E-04
5.66E-04
5.66E-04
1.13E-03
5.66E-04
2.83E-03
1.15E-03
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
6.89E-04
5.66E-04
1.13E-03
5.66E-04
5.66E-04
5.66E-04
5.66E-04
1.13E-03
1.97E-03
5.66E-04
5.66E-04
5.66E-04
5.66E-04
2.91E-03
5.66E-04
5.66E-04
1.13E-03
5.66E-04
1.13E-03
1.13E-03
1.13E-03
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04

-------
                                                          TABLE  C-7

                                         LONG-TERM STUDY AND SHORT-TERM  STUDY  LOADIHGS

                          SAMPLE POINT CATEGORY NAME=BLEACH PLANT  EFFLUENT  SUBCATEGORY=BPK FURHISH=HW
                                                          (continued)
                                                                                                                              48
CHEMICAL HAKE

HEXACHLOROETHANE
HCXACHLOROPROPEKE
RgXAHOlC ACID
1«0£KO<1,2,3-CO)PYRENE
ISOPHQftONE
ISOPROPANOt
ISOPROPYL ETHER
ISOSAfROLE
LOHS1FOLENE
MALACHITE GREEN
HETHAPYRILENE
METHYL HETHANESULFONATE
H-BUIAHOL
H-DECANE (M-C10)
H-DOCOSAHE (H-C22)
H-DOOECAHE (H-C12)
H-EICOSAHE (H-C20)
H-HSCACOSANE (M-C26)
N-HEXADECANE (N-C16)
H-H1TROSODI-H-BUTYLAMINE
M-HITROSODI-H-PROPYLAHINE
N-NITROSCOIETHYUHINE
H-NITROSODIHeTHYLAHINE
H-MITROSOOIPHENYLAHINE
H-HITROSOHETHYLETHYLAMINE
H-HITROSOHETHYLPHEHYLAHINE
N-HITROSOMORPHOUNE
H-HITROSOPIPERIDINE
H-OCTACOSANE (H-C28)
M-OCTADECANE (N-C18)
H-PROPAHOL
H-TETRACOSANE (N-C24)
H-TETRADECANE (N-C14)
H-TR1ACONTANE (N-C30)
M,H-DIHETHYLFORHAMIDE
NAPHTHALENE
NITROBENZENE
0-AHISIDINE
0-CRESOt
0-TOiUIDINE
P-CRESOt
P-CYHEHE
P-DIRETHYLAHINOAZOSENZENE
PENTACHLOR06ENZENE
PENTACHLOROETHANE
PENTAHETHYLBENZENE
PERYLEKE
PHEHACETIH
PKENAHTHREHE
PHENOL
PKEKOTHtAZINE
PROKAHIDE
PYREME

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
'2
2
a
2
' 2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON-DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2 '
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
DATA POINTS
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
. 5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5

NO. OF
NON-DETECTS
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
5
:ATEGUKY=B
UNITS
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/AIDMT
KG/A0MT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/AflMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
PK FURNIS
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
H=MW 	
MINIMUM
1.39E-04
2.78E-04
1.39E-04
2.78E-04
1 .39E-04
1.39E-04
1 .39E-04
1 .39E-04
6.94E-04
1 .39E-04
1.39E-04
2.78E-04
1.39E-04
1 .39E-04
1.39E-04
1 .39E-04
1 .39E-04
1 .39E-04
1.39E-04
1.39E-04
2.78E-04
1 .39E-04
6.94E-04
2.78E-04
1.39E-04
1.37E-03
1.39E-04
1 .39E-04
1.39E-04
1.39E-04
1.39E-04
1.39E-04
1 .39E-04
1 .39E-04
1 .39E-04
1 .39E-04
1 .39E-04
1.39E-04
1 .39E-04
1.39E-04
1 .39E-04
1.39E-04
2.78E-04
2.78E-04
2.78E-04
1 .39E-04
1.39E-04
1.39E-04
1.39E-04
1 .39E-04
6.94E-04
1 .39E-04
1 .39E-04
MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MAXIMUM
5.66E-04
1.13E-03
5.66E-04
1.13E-03
5.66E-041
5.66E-04
5.66E-04
5.66E-04
2.83E-03
5.66E-04
5.66E-04
1.13E-03
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
1.13E-03
5.66E-04
2.83E-03
1.13E-03
5.66E-04
5.60E-03
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
1.13E-03
1.13E-03
1.13E-03
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
2.83E-03
5.66E-04
5.66E-04

-------
 CHEMICAL NAME
                                TABLE C-7

               LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS

SAMPLE POINT CATEGORY NAME=BLEACH PLANT EFFLUENT SUBCATEGORY=BPK FURNISH=HW
                                (continued)

                   NO. OF
         NO. OF     MILLS       NO.  OF      NO. OF
          MILLS  NON-DETECT   DATA POINTS  NON-DETECTS
                                                                                                                            49
 PYRIDINE                            2         2
 SAFROLE                             2         2
 SQUALENE                            2         2
 STYRENE                             2         2
 T-BUTANOL                           2         2
 THIANAPHTHENE                       2         2
 THIOACETAMIDE                       2         2
 THIOXANTHONE                        2         1
 TRIPHENYLENE                        2         2
 TRIPROPYLENEGLYCOL METHYL ETHER     2         2
 1-METHYLFLUORENE                    2         2
 1-METHYLPHENANTHRENE                2         2
 1-PHENYLNAPHTHALENE                 2         2
 1.2-DIBROMO-3-CHLOROPROPANE          2         2
 1,2-DICHLOROBENZENE                 2         2
 1,2-DIPHENYLHYDRAZINE                2         2
 1,2,3-TRICHLOROBENZENE               2         2
 1,2,3-TRIMETHOXYBENZENE              2         2
 1,2,3,4-DIEPOXYBUTANE                2         2
 1,2,4-TRICHLOROBENZENE               2         2
 1,2,4,5-TETRACHLOROBENZENE          2         2
 1,3-BENZENEDIOL  (RESORCINOL)         2         2
 1.3-DICHLORO-2-PROPANOL              2         2
 1,3-DICHLOROBENZENE                 2         2
 1,3-DINITROBENZENE                   2         2
 1,3,5-TRITHIANE                      2         2
 1.4-DICHLOROBENZENE                 2         2
 1,4-NAPHTHOQUINONE                   2         2
 1,5-NAPHTHALENEDIAMINE               2         2
 2-(METHYLTHIO)BENZOTHIAZOL           2         2
 2-BROMOCHLOROBENZENE                 2         2
 2-BUTANOL                            2         2
 2-CHLORONAPHTHALENE                  2         2
 2-CHLOROPHENOL                       2         2
 2-ISOPROPYLNAPHTHALENE               2          2
 2-METHYL-4.6-DINITROPHENOL           2         2
 2-METHYLBENZOTHIOAZOLE              2         2
 2-METHYLNAPHTHALENE                  2         2
 2-NITROANILINE                      2         2
 2-NITROPHENOL                       2         2
 2-PHENYLNAPHTHALENE                 2         2
 2,3-BENZOFLUORENE                   2         2
 2,3-DICHLOROANILINE                 2         2
2,3-DICHLORONITROBENZENE            2         2
2,4-DIAMINOTOLUENE                  2         2
2,4-DICHLOROPHENOL                  2         0
2,4-DIMETHYLPHENOL                  2         2
2,4-DINITROPHENOL                   2         2
2,4-DINITROTOLUENE                  2         2
2,4,5-TRIMETHYLANILINE              2         2
2,6-DI-TERT-BUTYL-P-BENZOQINONE     2         2
2.6-DICHLORO-4-NITROANILINE         2         2
2,6-6lNITROTOLUENE                  2         2
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                  5
                                 5
                                  5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
                                 5
 5
 5
 5
 5
 5
 5
 5
 4
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
 5
3
 5
 5
 5
 5
 5
5
5
UCUUKI— or
UNITS
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
N ruKNia
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
n=nw 	 	
MINIMUM
1.39E-04
1.39E-04
1.37E-03
1.39E-04
1 .39E-04
1.39E-04
2.78E-04
2.78E-04
1 .39E-04
1.37E-03
1.39E-04
1 .39E-04
1 .39E-04
2.78E-04
1 .39E-04
2.78E-04
1 .39E-04
1.39E-04
2.78E-04
1 .39E-04
1.39E-04
6.94E-04
1 .39E-04
1.39E-04
2.78E-04
6.94E-04
1.39E-04
1 .37E-03
1.37E-03
1.39E-04
1 .39E-04
1.39E-04
1.39E-04
1.39E-04
1 .39E-04
2.78E-04
1.39E-04
1 .39E-04
1.39E-04
2.78E-04
1 .39E-04
1 .39E-04
1.39E-04
6.94E-04
1.37E-03
1 .39E-04
1.39E-04
6.94E-04
1 .39E-04
2.78E-04
1 .37E-03
1 .37E-03
1.39E-04
MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
I
MAXIMUM
5.66E-04
5.66E-04
5.60E-03
5.66E-04
5.66E-04
5.66E-04
1.13E-03
5.73E-03
5.66E-04
5.60E-03
5.66E-04
5.66E-04
5.66E-04
1.13E-03
5.66E-04
1.13E-03
5.66E-04
5.66E-04
1.13E-03
5.66E-04
5.66E-04
2.83E-03
5.66E-04
5.66E-04
1.13E-03
2.83E-03
5.66E-04
5.60E-03
5.60E-03
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
5.66E-04
1.13E-03
5.66E-04
5.66E-04
5.66E-04
1.13E-03
5.66E-04
5.66E-04
5.66E-04
2.83E-03
5.60E-03
1 .36E-03
5.66E-04
2.83E-03
5.66E-04
1.13E-03
5.60E-03
5.60E-03
5.66E-04

-------
CHEMICAL HAHE
                                                        TABLE C-7

                                       LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS

                        SAMPLE POINT CATEGORY NAME=BLEACH PLANT EFFLUENT SUBCATEGORY=BPK FURNISH=HU
                                                  '      (continued)
                                          NO. OF
                                HO. OF     MILLS       NO. OF       NO. OF             MINIMUM            MAXIMUM
                                 MILLS  NON-DETECT  DATA POINTS  NON-DETECTS   UNITS   SYMBOL   MINIMUM   SYMBOL   MAXIMUM
                                                                                                                            50
3-BRCHOCHLOROBENZENE
3-CHLOROHITR06ENZENE
3-HETHYLCHOUNTHRENE
3-HITROAHILINE
3,3«-DICHLOR08EHZIDINE
3,3'-DIM6THOXYBENZIDINE
3,5-DIBROHO-4-HYDROXYBEHZONITR
3,6-DIHETHYLPHENANTHRENE
4-AMINOBIPHENYL
4-BROMOPHENYL PHENYL ETHER
4-CHLORO-2-HITROANILINE
4-CHLORO-3-HETHYLPHEHOL
4-CHLOROAHILINE
4-CHLOROPHENYL PHENYL ETHER
4-HITRQAHILINE
4-NITROBIPHENYL
4-M1TROPBENOL
4,4•-KETHYLENEBISCa-CHLOROANI)
4,5-H£THYLEMEPHEHAHTHRENE
5-CHLORO-O-TOtUIDINE
5-M1TRO-0-TOLUIDINE
7.12-D1H£THYLBENZ
-------
                 TABLE C-7
                                                                                      51
LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS



CHEMICAL NAME
MANGANESE
MERCURY
MOLYBDENUM
NEODYMIUM
NICKEL
NIOBIUM
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SELENIUM
SILICON
SILVER
SODIUM
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIN
TITANIUM
TUNGSTEN
URANIUM
VANADIUM
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM


NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Hnruc rut HI UH
NO. OF
MILLS
NON -DETECT
0
0
1
2
2
2
2
2
0
2
0
2
2
2
2
2
2
2
0
2
0
0
0
2
2
2
2
2
2
2
1
2
2
0
2
1
0
2
ICUUKI H«me=Di_e

NO. OF
DATA POINTS
5
5
5
15
5
15
15
15
5
15
6
15
15
15
15
15
15
5
5
5
5
4
5
15
15
15
5
15
15
5
5
15
15
5
15
5
5
15
m»n ruANi crri
(continued)

NO. OF
NON-DETECTS
0
0
3
15
5
15
15
15
0
15
3
15
15
15
15
15
15
5
0
5
0
0
0
15
15
15
5
15
15
5
2
15
15
2
15
4
0
15
                         EFFLUENT SUBCATEGORY=BPK FURNISH
                                 UNITS

                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                           MINIMUM
                                           SYMBOL
 ND
 ND
 ND
 ND
 ND
 ND

 ND
 ND
'ND
 ND
 ND
 ND
 ND
 ND
 ND

 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND

 ND
uan=nH 	
MINIMUM
3.63E-02
4.53E-05
2.40E-04

3.05E-04



7.18E-02








7.19E-05
2.14E-01
8.33E-05
8.69E+00
1.34E-02
6.15E-01



1.13E-04


4.16E-04
1.20E-04


2.69E-04

1 .20E-04
2.34E-03
MAXIMUM
SYMBOL



ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

ND



ND
ND
ND
ND
ND
ND
ND

ND
ND

ND



MAXIMUM
9.70E-02
8.49E-04
4.39E-04

1 .24E-03



1 .78E-01

1.13E-01






3.73E-04
7.89E-01
3.39E-04
3.67E+01
2.86E-02
6.25E+00



7.83E-04


1.70E-03
1.16E-03


3.65E-03

7.60E-05
1 .06E-02
                                                                    ND

-------
                                                        TABLE C-8
                                                                                                                            52
                                       LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
CHEMICAL NAME

2,3,7,8-TETRACHLOROOIBENZO-P-DIOXIN
1,2,3,7,8-PENTACHLOROOIBENZO-P-DIOXIN
1,2,3,4,7,8-HEXACHLOR001BENZO-P-DIOXIN
1,2,3,6,7,8-H£XACHLOROOIBENZO-P-DIOXIN
1,2,3,7,8,9-H£XACHLOROD1BENZO-P-DIOXIN
1,2,3,4,6,7,8-HEPTACHLORODIBENZO-P-DIOXI
OCTACHLOR001BENZO-P-DIOXIN
2,3,7,8-TETRACKLOROOIBENZOFURAM
1,2,3,7,8-PEHTACHLOROOIBENZOFURAN
2,3,4,7,8-PENTACHLORODIBENZOFURAN
1,2,3,4,7,8-HEXACHLOROOIBENZOFURAN
1,2,3,6,7,8-HEXACHLORODIBENZOFURAN
1,2,3,7,8,9-HEXACHLOROOIBENZOFURAM
2,3,4,6,7,8-HEXACHLOROOIBENZOFURAH
1,2,3,4,6,7,8-HEPTACHLOROOIBENZOFURAN
1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN
OCTACHIORCOIBEHZOFURAM
4-CHLOROPBEHOt
4-CHLOfiOCATECHOL
4"CHia?OGUAIACOt
5-CHLOROCUAIACOL
5-CHLORCVAHILLIH
6-CHLOROVAHILLIN
2-CHLOROSYRINGALDEHYDE
2,4-DlCHLOROPHENOL
2,6-DICHLOfiOPHENOL
3,4-DICHLOROPHENOL
3,5-DICHLOROPHENOt
3,4-DICHLOROCATECHOt
3,5-DICBLOROCATECHOL
3,6-DICHLOROCATECHOL
4,5-DICHLOROCATECHOl
3,4-DICHLOROGUAIACOL
4,5-DlCHLOROGUAIACOL
4,6-DICHLOROGUAIACOL
5,6-DlCHLOROVANILLIN
2,6-DICHLOROSYRINGALDEHYDE
2,3,6-TRICHLOROPHENOL
2,4,5-TRICHLOROPHEMOL
2,4,6-TRICHLOROPHENOL
3,4,5-TRICHiOROCATECHOt
3,4,6-TRICHLOROCATECHCH.
3,4,5-TRICHLOROGUAIACOC
3,4,6-TRICHLOROCUAIACOL
4,5,6-TRlCHLOROGUAIACOt
TRICHLOROSYRINGOL
2,3,4,6-TETRACHLOROPHENQL
TeiRACHlOROCATECHOL
TETRACHLOROGUAIACOL
PEHTACHtOROPHENOL
ACRYLOHITRILE
BENZENE
BROHOOICHIOROMETHAME
BROHOHETHAHE
[GORY NAHE=BLEACH PLANT EFFLUEN
NO. OF
NO. OF MILLS NO. OF
T SUBCATtl
NO. OF
3U*I=BPK FUKN1SH=SW 	
MINIMUM MAXIMUM
MILLS NON-DETECT DATA POINTS NON-DETECTS UNITS SYMBOL
10
9
9
9
9
9
7
9
9
9
9
9
9
9
9
9
8
8
5
8
3
5
9
8
9
10
5
5
8
2
6
10
5
10
9
9
8
5
10
10
10
5
10
8
10
10
10
10
9
10
10
10
10
10
4
7
8
8
7
6
1
1
8
8
9
9
9
9
8
9
6
0
1
• 2
2
0
1
5
2
8
5
4
4
0
3
3
2
1
4
3
5
3
9
3
4
2
3
4
2
9
7
2
3
6
10
10
9
10
80
16
16
15
16
14
8
79
16
16
16
16
16
16
15
15
15
80
60
76
7
70
80
75
83
86
11
11
72
5
70
84
67
83
74
76
76
11
84
82
72
63
77
75
79
81
82
77
83
86
87
87
87
87
62
14
15
14
14
11
2
54
14
15
16
16
16
16
14
15
13
11
12
12
5
17
4
54
23
83
11
10
26
1
53
24
21
15
49
23
58
8
82
24
22
56
25
46
28
66
65
29
46
69
87
87
81
87
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
• KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
MINIMUM SYMBOL
1.08E-10
7.87E-10
1.94E-10
1.94E-10
2.37E-10
2.05E-10
2.01E-09
1.08E-10
1.34E-10
1.34E-10
1.24E-10 ND
1.24E-10 ND
1.94E-10 ND
1.66E-10 ND
1.87E-10
2.47E-10 ND
3.96E-10
1 .92E-05
1 .53E-05
1.89E-05
9.12E-05
3.78E-05
9.12E-05 >
3.04E-05
3.04E-05
2.26E-05
2.26E-05 ND
2.26E-05
3.04E-05
9.51E-05
3.04E-05
3.04E-05
3.04E-05
3.04E-05 >
3.04E-05
6.10E-05
6.10E-05
1.41E-05
1.41E-05
1.41E-05
1.41E-05
6.10E-05
1 .90E-05 >
3.04E-05
3.04E-05
2.08E-05
3.04E-05
6.10E-05
3.62E-05
1 .82E-05
1 .86E-04 ND
9.30E-05 ND
9.30E-05
1 .29E-04 ND
MAXIMUM
3.19E-09
8.39E-10
8.39E-10
2.94E-10
2.42E-09
6.29E-09
3.81E-08
5.34E-08
3.77E-09
1.51E-09
1.09E-08
1.22E-08
1.22E-08
1.23E-08
8.39E-10
1 .44E-08
6.79E-08
8.71E-04
5.80E-04
1.83E-03
1.55E-04
4.47E-03
5.69E-02
7.61E-04
2.92E-03
2.11E-04
2.14E-04
1.81E-04
5.96,E-03
9.96E-04
1.79E-03
1.23E-02
9.22E-04
5.70E-02
4.80E-04
4.08E-03
1.50E-03
3.15E-05
3.26E-04
1.24E-02
7.75E-03
2.88E-04
4.75E-03
3.90E-04
2.78E-03
6.01E-04
4.32E-04
1.20E-03
4.28E-03
3.98E-03
8.95E-03
1.79E-03
8.63E-04
8.95E-03

-------
CHEMICAL NAME
                                TABLE C-8

               LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS

SAMPLE POINT CATEGORY NAME=BLEACH PLANT EFFLUENT SUBCATEGORY=BPK FURNISH=SW
                                (continued)

                   NO. OF
         NO. OF     MILLS       NO. OF       NO. OF             MINIMUM
          MILLS  NON-DETECT  DATA POINTS  NON-DETECTS   UNITS   SYMBOL
                                                                                                                             53
CARBON DISULFIDE
CHLOROACETONITRILE
CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
CHLOROMETHANE
C1S-1.3-D1CHLOROPROPENE
CROTONALDEHYDE
DIBROMOCHLOROMETHANE
DIBROMOMETHANE
DIETHYL ETHER
ETHYL CYANIDE
ETHYL METHACRYLATE
ETHYLBENZENE
IODOMETHANE
ISOBUTYL ALCOHOL
M-XYLENE
METHYL METHACRYLATE
METHYLENE CHLORIDE
0+P XYLENE
TETRACHLOROETHENE
TETRACHLOROMETHANE
TOLUENE
TRANS-1,2-DICHLOROETHENE
TRANS-1,3-D ICHLOROPROPENE
TRANS-1,4-DICHLORO-2-BUTENE
TRIBROMOMETHANE
TRICHLOROETHENE
TRICHLOROFLUOROMETHANE
VINYL ACETATE
VINYL CHLORIDE
1,1-DICHLOROETHANE
1,1-DICHLOROETHENE
1,1,1-TRICHLOROETHANE
1,1,1.2-TETRACHLOROETHANE
1,1,2-TRICHLOROETHANE
1,1,2,2-TETRACHLOROETHANE
1,2-DIBROMOETHANE
1,2-DICHLOROETHANE
1,2-DICHLOROPROPANE
1.2,3-TRICHLOROPROPANE
1,3-BUTADIENE, 2-CHLORO
1,3-DICHLOROPROPANE
1,4-DIOXANE
2-BUTANONE 
>
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND'



ND
ND
ND



ND
ND

ND
ND
ND
ND
ND

ND
ND
ND
ND


ND
ND




ND
ND

MAXIMUM
1.73E-03
1 .79E-03
1.79E-03
8.95E-03
1.06E-01.
5.44E-03
1.79E-03
8.95E-03
1.79E-03
1 .79E-03
8.95E-03
1 .79E-03
1.79E-03
1.79E-03
1.79E-03
6.32E-04
1.79E-03
1.79E-03
8.27E-02
1 -79E-03
1.79E-03
2.40E-03
7.60E-04
3.77E-04
1.79E-03
8.95E-03
1 .79E-03
2.51E-04
6.20E-04
3.68E-02
1.79E-03
1.79E-03
7.56E-03
.79E-03
.79E-03
.79E-03
.79E-03
.79E-03
.21E-02
-79E-03
.79E-03
-79E-03 •
1.79E-03
2.16E-04
3.89E-02
1.79E-03
8.95E-03
8.62E-02
2.20E-02
1.08E-03
1.78E-03
1.79E-03
8.95E-03

-------
CHEMICAL NAME
                                                        TABLE C-8

                                        LONG-TERH  STUDY AND SHORT-TERM STUDY LOADINGS

                         SAMPLE POINT CATEGORY NAHE=BLEACH PLANT EFFLUENT SUBCATEGORY=BPK  FURNISH=SU
                                                        (continued)
                                            NO.  OF
                                  NO. OF     MILLS       NO. OF       NO. OF             MINIMUM            MAXIMUM
                                   MILLS  NOH-DETECT  DATA POINTS  NON-DETECTS   UNITS   SYMBOL   MINIMUM   SYMBOL   MAXIMUM
                                                                                                                            54
ADSORBA8LE ORGANIC HALIDES (AOX)
COD
ACEHAPHTHENE
ACEHAPHTHYLENE
ACETOPHENONE
AtPHA-NAPHTHYLAHINE
ALPHA-PICOUNE
ALPRA-TERPIHEOL
AH1L1KE
ANTHRACENE
ARAHITE
B-MAPHTHYLAHINE
8ENZAHTHRONE
BEHZEMETHIOL
BEHZIDINE
BEHZOCA)ANTHRACENE
BEHZO(A)PYRENE
BENZO(B)FLUORANTHENE
8ENZO{GHI)P£RYLENE
BEHZOdOFLUORANTHENE
BENZOIC ACID
BENZYL ALCOHOL
BIPHEMYL
BIS (Z-CHLOROISOPROPYL) ETHER
BISCCHLOROKETHYDETHERCNR)
S!S(2-CHLOROETHOXY)METHANE
BIS(2-CHLOROETHYL)ETHER
flS(2-ETHYLHEXYL)PHTHALATE
BUTYL BENZYL PHTHALATE
CARBAZOtE
CHRYSENE
Dl-H-BUTYL AHINE
DI-H-BUTYL PHTHALATE
OI-H-OCm PHTHALATE
01BENZOCA,H>ANTHRACENE
D1BENZOFORAH
DIBEHZOTHIOPHEHE
DICHLORODIFLUOROHETHANE (NR)
DIETHYL PHTHALATE
D1HETHYL PHTHALATE
DIHETHYL SULFONE
DIPHENYL ETHER
OIPKEUYLAHINE
D1PHEHYL0ISULFIDE
ETHANOL
ETHYL HETHANESULFONATE
ETHYLENETHIOUREA
ETHYHYLESTRADlOt 3-METHYL ETHER
FLUORAMTHEKE
FLUORENE
HEXACHLORO-1,3-BUTADIENE
HEXACHLOROBEMZENE
HEXACHLOROCYCtOPENTADIENE
4
6
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1





1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1-
1
0
1
1
1
1
0
1
1
1
1
1
1
1
1
1
1
1
1
12
16
1
1
1
1
.1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1
1
0
1
1
1
1
0
1
1
1
1
1
1
1
1
1
1
1
1
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT •
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
HD
HD

ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
6.40E-01
2.12E-01
1.41E-04
1.41E-04
1.41E-04
1.41E-04
7.07E-04
1.41E-04
1.41E-04
1.41E-04
7.07E-04
7.07E-04
7.07E-04
2.05E-04
7.07E-04
1.41E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
7.07E-04
1.41E-04
1 .41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.66E-03
1.41E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
2.83E-04
4.36E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.17E-02
1 .41E-04
1.41E-04
2.83E-04
1.41E-04
2.83E-04
2.83E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1 .41E-04


ND
ND
ND
ND
ND
ND
ND
NDi
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
2.64E+00
8.33E+01
1.41E-04
1.41E-04
1.41E-04
1.41E-04
7.07E-04
1.41E-04
1.41E-04
1.41E-04
7.07E-04
7.07E-04
7.07E-04
2.05E-04
7.07E-04
1.41E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
7.07E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.66E-03
1.41E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
2.83E-04
4.36E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.17E-02
1.41E-04
1.41E-04
2.83E-04
1.41E-04
2.83E-04
2.83E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04

-------
                                                            TABLE C-8
                                                                                                                                55
                                          LONG-TERM  STUDY  AND  SHORT-TERM STUDY LOADINGS

                           SAMPLE POINT CATEGORY  NAHE=BLEACH PLANT EFFLUENT SUBCATEGORY=BPK FURNISH=SW
                                                            (continued)
 CHEMICAL NAME

 HEXACHLOROETHANE
 HEXACHLOROPROPENE
 HEXANOIC ACID
 INDENO(1,2,3-CD)PYRENE
 ISOPHORONE
 ISOPROPANOL
 ISOPROPYL ETHER
 ISOSAFROLE
 LONGIFOLENE
 MALACHITE GREEN
 METHAPYRILENE
 METHYL METHANESULFONATE
 N-BUTANOL
 N-DECANE  (N-C10)
 N-DOCOSANE (N-C22)
 N-DODECANE (N-C12)
 N-EICOSANE (N-C20)
 N-HEXACOSANE  (N-C26)
 N-HEXADECANE  (N-C16)
 N-NITROSODI-N-BUTYLAMINE
 N-NITROSODI-N-PROPYLAMINE
 N-NITROSODIETHYLAMINE
 N-NITROSODIHETHYLAMINE
 N-NITROSODIPHENYLAMINE
 N-NITROSOMETHYLETHYLAMINE
 N-NITROSOMETHYLPHENYLAMINE
 N-NITROSOMORPHOLINE
 N-NITROSOPIPERIDINE
 N-OCTACOSANE  (N-C28)
 N-OCTADECANE  (N-C18)
 N-PROPANOL
 N-TETRACOSANE CN-C24)
 N-TETRADECANE (N-C14)
 N-TRIACONTANE (N-C30)
 N.N-DIMETHYLFORMAMIDE
 NAPHTHALENE
 NITROBENZENE
 0-ANISIDINE
 0-CRESOL
 0-TOLUIDINE
 P-CRESOL
 P-CYMENE
 P-DIMETHYLAMINOAZOBENZENE
 PENTACHLOROBENZENE
 PENTACHLOROETHANE
 PENTAMETHYLBENZENE
PERYLENE
PHENACETIN
PHENANTHRENE
PHENOL
 PHENOTHIAZINE
PRONAMIDE
PYRENE

NO. OF
KILLS

1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
T
1
1
1
1
1
1
1
1
1
1
1
NO. OF
MILLS
NON-DETECT

1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1,
o'
0
1
0
1
1
1
1
1
1
1
1
0
1
0
1

NO. OF
DATA POINTS

1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1

NO. OF
NON-DETECTS

1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
0
0
i
0
1
1
1
1
1
1
1
1
0
1
0
1 '


UNITS

KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT .
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
, KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT

MINIMUM
SYMBOL

NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND


ND

ND
ND
ND
ND
ND
ND
ND
ND

ND

ND


MINIMUM

1.41E-04
2.83E-04
1.41E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
7.07E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
7.07E-04
2.83E-04
1.41E-04
1.40E-03
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
6.68E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.59E-04
3.88E-03
1.41E-04
1.45E-04
1.41E-04
2.83E-04
2.83E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1 .47E-04
7.07E-04
2.58E-04
1.41E-04

MAXIMUM
SYMBOL
I
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND


ND

ND
ND
ND
ND
ND
ND
ND
ND

ND

ND


MAXIMUM

1.41E-04
2.83E-04
1.41E-04
2.83E-04
1.41E-04
1.41E-04
1 .41E-04
1.41E-04
7.07E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
7.07E-04
2.83E-04
1.41E-04
1.40E-03
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
6.68E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.59E-04
3.88E-03
1.41E-04
1.45E-04
1.41E-04
2.83E-04
2.83E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
1.47E-04
7.07E-04
2.58E-04
1.41E-04

-------
                                                        TABLE C-8

                                       LONG-TERM STUDY AND  SHORT-TERM STUDY LOADIHGS

                        SAMPLE POINT CATEGORY NAME=BLEACH PLANT EFFLUENT SUBCATEGORY=BPK  FURNISH=SW
                                                        (continued)
                                                                                                                           56
CHEMICAL HAKE

PYRIDINE
SAFROLE
SQUALEHE
STYRENE
T-BUTAKOL
TttlAHAPHTHENE
THIOACETAHIDE
THIOXAHTHONE
TRIPHEHYLENE
TRIPROPYLENEGL.YCOL METHYL ETHER
1-HETHYLFLUORENE
1-HETHYLPHEHANTHRENE
1-PHEHYLHAPHTHALENE
1.2-D1BROHO-3-CHLOROPROPANE
1,2-D1CHLOROB£NZENE
1,2-01PHEHYLHYDRAZINE
1,2,3-TRICHLOROBENZENE
1,2,3-TRIHETHOXYBENZENE
1,2,3,4-DIEPOXYBUTANE
1,2,4-TRlCHLOROBENZENE
1,2,4,5-TETRACHLOROBENZENE
1,3-BEHZENEDIOL (RESORCINOO
1,3-DICHLORO-2-PROPANOt
1,3-DlCHtOROBENZENE
1,3-D1HITROBEHZENE
1,3,5-TRITHIANE
1,4-DlCHLOROBENZENE
1,4-NAPHTHOQUINONE
1,5-HAPHTHALENEDIAMINE
2-(HETHYLTHIO)BENZOTHIAZOL
2-BROHOCHLOROBENZEHE
2-807ANOL
2-CHLOROHAPHTHALENE
2-CHtOROPHENOL
2-1SOPROPYLMAPHTHALEHE
2-HeTHYL-4,6-DINITROPHENOL
2-WETHYLBENZOTHIOAZOLE
2-HETHYLNAPHTHALENE
2-HITROAHILINE
2-HJTROPHENOL
2-PHEHYLHAPHTHALENE
2,3-BEHZOFLUORENE
2,3-DICHLOROANILINE
2,3-DICHLOROHITR08ENZENE
2,4-OIAHIHOTOiUENE
2,4-DICHLOROPHENOL
2,4-DIHETHYLPHEKOL
2,4-DlHITROPHENOt
2,4-DIMITROTOLUENE
2,4,5-TRIHETHYlANILINE
2.6-D1-TERT-BUTYL-P-BENZOQINONE
2,6-DICHtORO-4-NITROANILINE
2,6-DINITROTOtUENE
                                           NO. OF
                                 NO. OF     MILLS       NO.  OF        NO. OF
                                  HILLS  NON-DETECT  DATA POINTS   NON-DETECTS
        MINIMUM            MAXIMUM
UNITS   SYMBOL   MINIMUM   SYMBOL   MAXIMUM
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1





1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1
1
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KCi/ADMT
KG/ADMT
KG/ADMT
KCi/ADMT
KG/ADMT
KG/ADMT
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
1.41E-04
1.41E-04
1.40E-03
1.41E-04
1.41E-04
1.41E-04
2.83E-04
2.83E-04
1.41E-04
1.40E-03
1.41E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
2.83E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
1.41E-04
7.07E-04
1.41E-04
1.41E-04
2.83E-04
7.07E-04
1.41E-04
1 .40E-03
1.40E-03
1.41E-04
1.26E-03
1.41E-04
1.41E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
7.07E-04
1.40E-03
1.63E-04
1.41E-04
7.07E-04
1.41E-04
2.83E-04
1.40E-03
1 .40E-03
1 .41E-04
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
.ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
1.41E-04
1.41E-04
1.40E-03
1.41E-04
1.41E-04
1.41E-04
2.83E-04
2.83E-04
1.41E-04
1.40E-03
1.41E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
2.83E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
1.41E-04
7.07E-04
1.41E-04
1.41E-04
2.83E-04
7.07E-04
1.41E-04
1.40E-03
1.40E-03
T.41E-04
1.26E-03
1.41E-04
1.41E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
2.83E-04
•U41E-04
1.41E-04
1.41E-04
7.07E-04
1.40E-03
1.63E-04
1.41E-04
7.07E-04
1.41E-04
2.83E-04
1.40E-03
1 .40E-03
1.41E-04

-------
                                                           TABLE C-8

                                         LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
57
  CHEMICAL NAME

  3-BROMOCHLOROBENZENE
  3-CHLORONITROBENZENE
  3-METHYLCHOLANTHRENE
  3-NITROANILINE
  3,3'-DICHLOROBENZIDINE
  3,3'-DIMETHOXYBENZIDINE
  3.5-DIBROMO-4-HYDROXYBENZONITR
  3,6-DIMETHYLPHENANTHRENE
  4-AMINOBIPHENYL
  4-BROMOPHENYL PHENYL ETHER
  4-CHLORO-2-NITROANILINE
  4-CHLORO-3-METHYLPHENOL
  4-CHLOROANILINE
  4-CHLOROPHENYL PHENYL ETHER
  4-NITROANILINE
  4-NITROBIPHENYL
  4-NITROPHENOL
  4,4'-METHYLENEBIS<2-CHLOROANb
 4,5-METHYLENEPHENANTHRENE
 5-CHLORO-O-TOLUIDINE
 5-NITRO-O-TOLUIDINE
 7,12-DIMETHYLBENZ(A)ANTHRACENE
 ALUMINUM
 ANTIMONY
 ARSENIC
 BARIUM
 BERYLLIUM
 BISMUTH
 BORON
 CADMIUM
 CALCIUM
 CERIUM
 CHROMIUM
 COBALT
 COPPER
 DYSPROSIUM
 ERBIUM
 EUROPIUM
 GADOLINIUM
 GALLIUM
 GERMANIUM
 GOLD
 HAFNIUM
 HOLMINUM
 INDIUM
 IODINE
 IRIDIUM
 IRON
LANTHANUM
LEAD
LITHIUM
LUTETIUM
MAGNESIUM
(continued)

NO. OF
MILLS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
NO. OF
MILLS
NON-DETECT
1
1
1
1
1
0
1 '
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
' 0
1
1
0
1
1
1
0
0
1
1
1













0
1
1
1
1
0

NO. OF
DATA POINTS
1








1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
3
1
1
1
3
1
1
1
3
3
' 3
3
3
3
3
3
3
3
3
3
1
3
1
3
3
1

NO. OF
NON-DETECTS
1
1
1
1
1
0
1
1
1
1
1
1
1
1
1
' 1
1
1
1
1
1
1
0
1
1
0
1
3
1
0 '
0
3
1
1
1
3
3
3
3
3
3
3
3
3
3
3
3
0
3
1
3
3
0


UNITS
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT

MINIMUM
SYMBOL
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND
ND


ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND



MINIMUM
1.41E-04
7.07E-04
1.41E-04
2.83E-04
7.07E-04
7.10E-04
7.07E-04
1.41E-04
1.41E-04
1.41E-04
2.83E-04
1.41E-04
1.41E-04
1 .41E-04
7.07E-04
1.41E-04
7.07E-04
2.83E-04
1 .41E-04
1.41E-04
1.41E-04
1.41E-04
2.80E-02
8.48E-05
2.83E-04
7.53E-03
2.83E-05

3.04E-04
7.07E-05
1.11E+00

1.41E-04
3.53E-04
3.04E-04












1.29E-02

7.07E-04


2.97E-01

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND
ND


ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND



MAXIMUM
1.41E-04
7.07E-04
1.41E-04
2.83E-04
7.07E-04
7.10E-04
7.07E-04
1.41E-04
1 .41E-04
1.41E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
7.07E-04
1.41E-04
7.07E-04
2.83E-04
1.41E-04
1.41E-04
1.41E-04
1.41E-04
2.80E-02
8.48E-05
2.83E-04
7.53E-03
2.83E-05

3.04E-04
7.07E-05
1.11E+00

1.41E-04
3.53E-04
3.04E-04












1.29E-02

7.07E-04


2.97E-01

-------
                                TABLE C-8

               LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS

SAMPLE POINT CATEGORY NAME=BLEACH PLANT EFFLUENT SUBCATEGORY=BPK FURNISH=SW
                                                                                                    58



CHEMICAL HAHE
MANGANESE
MERCURY
MOLYBDENUM
NEOOYHIUH
NICKEL
HIOB1UH
OSMIUM
PALLADIUM
PHOSPHORUS
PUT I HUH
POTASSIUM
PRASEODYMIUM
RBEHIUH
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SELENIUM
SILICON
SILVER
SODIUM
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIM
TITANIUM
TUNGSTEN
URANIUM
VANADIUM
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM


HO. OF
MILLS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
nnruc rwini wi
NO. OF
MILLS
NON-DETECT
0
0
1
1
1
1
P
1
0
1
0
1
1
1
1
1
1
1
0
1
0
0
0
1
1
1
1
1
1
1
0
1
1 .
0
1
1
0
1


NO. OF
DATA POINTS
1
1
1
3
1
3
3
3
1
3
, 1
3
3
3
3
3
3
1
1
1
1
1
1
3
3
3
1
3
3
1
i
3
3
1
3
1
1
3
(continued)

NO. OF
NON-DETECTS
0
0
1
3
1
. 3
3
3
0
3
0
3
3
3
3
3
3
1
0
1
0
0
0
3
3
3
1
3
3
1
0
3
3
0
3
1
0
3

UNITS
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMt
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
MINIMUM
SYMBOL


ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

ND



ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND

ND
                                                                     MINIMUM

                                                                     7.85E-02
                                                                     4.05E-04
                                                                     1.41E-04

                                                                     3.11E-04
                                                                     5.76E-02

                                                                     2.67E-02
                                                                     4.24E-05
                                                                     2.53E-01
                                                                     8.48E-05
                                                                     1.26E+01
                                                                     6.01E-03
                                                                     8.06E-01
                                                                      7.53E-04
                                                                      4.24E-04
                                                                      7.24E-05
                                                                      1.19E-03

                                                                      7.07E-05
                                                                      7.47E-03
                                                                                 MAXIMUM
                                                                                 SYMBOL
ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND

 ND
 ND

 ND
 ND

 ND
 MAXIMUM

 7.85E-02
 4.05E-04
 1.41E-04

'3.11E-04
 5.76E-02

 2.67E-02
 4.24E-05
 2.53E-01
 8.48E-05
 1.26E+01
 6.01E-03
 8.06E-01
                                                                                             7!53E-04
  4.24E-04
  7.24E-05
  1.19E-03

  7.07E-05
  7.47E-03

-------
                                                             TABLE C-9
                                         LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
59
 CHEMICAL NAME

 2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN
 1,2,3,7,8-PENTACHLORODIBENZO-P-DIOXIN
 1,2,3,4,7,8-HEXACHLORODIBENZO-P-DIOXIN
 1,2,3,6,7,8-HEXACHLORODIBENZO-P-DIOXIN
 1,2,3,7,8,9-HEXACHLORODIBENZO-P-DIOXIN
 1.2,3,4.6,7,8-HEPTACHLORODIBENZO-P-DIOXI
 OCTACHLOROD1BENZO-P-DIOXIN
 2,3,7,8-TETRACHLOROD IBENZOFURAN
 1,2,3,7,8-PENTACHLORODIBENZOFURAN
 2,3,4,7,8-PENTACHLORODIBENZOFURAN
 1,2,3,4,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,6,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,7,8,9-HEXACHLORODIBENZOFURAN
 2,3,4,6,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,4,6,7,8-HEPTACHLORODIBENZOFURAN
 1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN
 OCTACHLORODIBENZOFURAN
 4-CHLOROPHEHOL
 4-CHLOROGUAIACOL
 5-CHLOROGUAIACOL
 6-CHLOROVANILLIN
 2-CHLOROSYRINGALDEHYDE
 2,4-DICHLOROPHENOL
 2,6-DICHLOROPHENOL
 3,4-DICHLOROPHENOL
 3,5-DICHLOROPHENOL
 3,4-DICHLOROCATECHOL
 3,5-DICHLOROCATECHOL
 3,6-DICHLOROCATECHOL
 4,5-DICHLOROCATECHOL
 4,5-DICHLOROGUA!ACOL
 4,6-DICHLOROGUAIACOL
 5,6-DICHLOROVANILLIN
 2,6-DICHLOROSYRINGALDEHYDE
 2,3,6-TRICHLOROPHENOL
 2,4,5-TRICHLOROPHENOL
 2,4,6-TRICHLOROPHENOL
 3.4,5-TRICHLOROCATECHOL
 3,4,5-TRICHLOROGUAIACOL
 3,4,6-TRICHLOROGUAIACOL
 4,5,6-TRICHLOROGUAIACOL
 TRICHLOROSYRINGOL
 2,3,4,6-TETRACHLOROPHENOL
 TETRACHLOROCA7ECHOL
 TETRACHLOROGUAIACOL
 PENTACHLOROPHENOL
 ACRYLONITRILE
 BENZENE
 BROMODICHLOROMETHANE
 BROMOMETHANE
 CARBON DISULF1DE
CHLOROACETONITRILE
CHLOROBENZENE
CHLOROETHANE
V 1 \ff\ 1 l_ U
NO. OF
MILLS
8
8
8
8
8
7
4
8
8
8
8
8
8
8
8
8
7
5
5
5
7
5
6
8
8
8
5
4
1
8
8
7
7
5'
8
8
7
7
8
5
8
8
8
8
6
8
8
8
8
8
8
8
8
8
vr\ i nrufif—rr\r
NO. OF
'MILLS
NON-DETECT
7
8
8
7
7
2
0
6
7
7
6
8
8
7
8
8
5
4
4
4
4
4
5
7
8
8
4
3
1
8
6
6
5
5
8
7
6
6
4
5
7
8
8
8
4
4
8
8
7
8
7
8
8
8
&i\ rmvtninc wn
NO. OF
DATA POINTS
10
10
10
10
10
9
4
10
10
10
10
10
10
10
9
10
9
15
15
13
17
13
18
18
18
18
15
12
3
18
20
17
19
13
18
20
17
17
20
15
20
20
20
18
18
20
20
20
20
20
20
20
20
20
1 I C Hn 1 Cl\ OUI
NO. OF
NON-DETECTS
8
10
10
9
9
4
0
6
8
9
8
10
10
9
9
10
7
14
14
12
12
12
16
17
18
18
14
11
3
18
18
15
16
13
18
17
15
16
13
15
19
20
20
18
16
15
20
20
18
20
19
20
20
20
9l»M 1 CUUK

UNITS
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
3.00
3.00
3.00
3.00
3.00
48.00
120.00
5.00
3.00
3.00
3.00
3.00
3.00
8.00
3.00
3.00
15.00
0.25
0.25
0.50
0.50
0.50
0.10
0.25
0.25
0.25
2.50
0.50
5iOO
1.00
0.50
0.25
0.50
1.25
0.10
0.25
0.36
0.30
0.10
0.50
0.25
0.25
0.25
0.25
0.10
0.10
50.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00

MAXIMUM
SYMBOL

ND
ND








ND
ND

ND
ND








ND
ND


ND
ND



ND
ND




ND

ND
ND
ND


ND
ND

ND

ND
ND
ND


MAXIMUM
31.00
69.00
69.00
51.00
25.00
2800.00
920.00
410.00
92.00
27.00
31.00
69.00
69.00
4.00
238.00
227.00
560.00
0.32
0.45
1.40
11.37
1.00
1.80
0.35
5.00
5.00
0.90
0.80
5.00
5.00
13.14
8.35
1.70
1.30
5.00
1.40
10.00
0.60
3.17
0.50
1.05
5.00
5.00
5.00
0.90
12.44
500.00
100.00
21.50
500.00
10.00
100.00
100.00
500.00

-------
                                                           TABLE C-9

                                       LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
                                                                                                                             60
 CHEMICAL NAME

 CHLOROFORM
 CHLORONETHANE
 C1S-1.3-DICHLOROPROPENE
 CROTOWALDEHYDE
 DIBRONOCHLOROHETHANE
 DIBROMOMETHANE
 OIETHYL ETHER
 ETHYL CYAMIDE
 ETHYL HETHACRYLATE
 ETHYLBEHZENE
 ICOCHETHAUE
 IS06UTYL ALCOHOL
 H-XYLEHE
 METHYL HETHACRYLATE
 M6THYLENE CHLORIDE
 (HP XYLEHE
 TETRACHLOROETHEME
 TETRACHLOROH6THANE
 TOtUEHE
 TRANS-1,2-DICHLOROETHENE
 TRANS-1,3-DICHLOROPROPENE
 TRANS-1,4-DICHLORO-2-BUTENE
 TR1BROHOHETHANE
 TRICHLOROETHENE
 TRICHLOROFLUOROHETHAHE
 VIHYL ACETATE
 VINYL CHLORIDE
 1,1-DlCHLOROETHANE
 1,1-DICHLOROETHENE
 1,1,1-TRICHLOROeTHANE
 1,1,1,2-TETRACHLOROETHANE
 1,1,2-TRICHLOROETKANE
 1,1,2,2-TETRACHLOROETHANE
 1,2-DIBROMOETHANE
 1,2-DICHLOROETHANE
 1,2-DICHLOROPROPANE
 1,2,3-TRICHLOROPROPANE
 1,3-BUTADIEHE, 2-CHLORO
 1,3-DICHLOROPROPANE
 1,4-DIOXANE
 2-BUTAKOHE (HEK)
 2-CHLOROETHYLVINYL ETHER
' 2-HGXANOME
 2-PROPANOHE  (ACETONE)
 2-PROPEH-1-OL
 2-PROPEMAL (ACROtEIN)
 2-PROPEHEHITR1LE, 2-HETHYL-
 3-CHLOROPROPENE
 4-HETHYL-2-PEHTANOHE
 ADSORBABLE ORGANIC  HALIDES (AOX)
 COD
 ACENAPHTHENE
 ACEHAPHTHYLENE
>LE POINT CATEGORY NAME=PAPER MACHINE WHITE WATER SUBCATEGORY=BPK 	
(continued)
NO. OF
HO. OF
MILLS
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
5
8
1
1
MILLS
NON-DETECT
5
8
8
8
8
8
8
8
8
6
8
8
7
8
7
7
8
8
7
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
8
7
8
8
5
8
8
8
8
8
0
2
1
1
NO. OF
DATA POINTS
20
20
20
20
20
20
20
20
20
20
20
20
20
20
18
20
20
19
20
20
20
20
20
20
19
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
20
17
20
20
20
20
20
15
20
1
1
NO. OF
NON-DETECTS
12
20
20
20
20
20
20
20
20
17
20
20
18
20
17
19
20
19
19
20
20
20
20
20
19
20
20
20
20
20
20
, 20
20
20
20
20
20
20
20
20
17
20
20
9
20
20
20
20
20
0
2
1
1

UNITS
IJG/L
UG/L
UG/L
UG/L
IJG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
MG/L
MG/L
UG/L
UG/L
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND

MINIMUM
10.00
50.00
10.00
50.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
50.00
50.00
10.00
50.00
10.00
10.00
50.00
0.83
15.00
10.00
10.00
MAXIMUM
SYMBOL

ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND


ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND
ND
ND
ND


ND
ND

MAXIMUM
159.00
500.00
100.00
500.00
100.00
100.00
500.00
100.00
100.00
39.00
100.00
100.00
20.00
100.00
544.00
14.00
100.00
10.00
12.00
100.00
100.00
500.00
100.00
100.00
100.00
500.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
1358.00
100.00
500.00
2301 .00
100.00
500.00
100.00
• 100.00
500.00
71.60
4500.00
10.00
10.00

-------
                                                            TABLE C-9
                                                                                                                                 61
 CHEMICAL NAME

 ACETOPHENONE
 ALPHA-NAPHTHYLAMINE
 ALPHA-PICOLIHE
 ALPHA-TERPINEOL
 ANILINE
 ANTHRACENE
 ARAMITE
 B-NAPHTHYLAMINE
 BENZANTHRONE
 BEHZENETHIOL
 BENZIDINE
 BENZO(A)ANTHRACENE
 BENZO(A)PYRENE
 BENZOCB)FLUORANTHENE
 BEMZO(GHI)PERYLENE
 BENZO(K)FLUORANTHENE
 BENZOIC ACID
 BENZYL  ALCOHOL
 BIPHENYL
 BIS C2-CHLOROISOPROPYL) ETHER
 BISCCHLOROMETHYL)ETHER(NR)
 8IS(2-CHLOROETHOXYJMETHANE
 BISC2-CHLOROETHYDETHER
 BIS(2-ETHYLHEXYL)PHTHALATE
 BUTYL BENZYL PHTHALATE
 CARBAZOLE
 CHRYSENE
 OI-N-BUTYL AMINE
 DI-N-BUTYL PHTHALATE
 DI-N-OCTYL PHTHALATE
 DIBENZOCA,H)ANTHRACENE
 DIBENZOFURAN
 DIBENZOTHIOPHENE
 DICHLORODIFLUOROMETHANE (NR)
 DIETHYL PHTHALATE
 DIMETHYL PHTHALATE
 DIMETHYL SULFONE
 DIPHENYL ETHER
 DIPHENYLAMINE
DIPHENYLDISULFIDE
 ETHANOL
ETHYL METHANESULFONATE
ETHYLENETHIOUREA
ETHYNYLESTRADIOL 3-METHYL ETHER
 FLUORANTHENE
 FLUORENE
HEXACHLORO-1,3-BUTADIENE
HEXACHLOROBENZENE
HEXACHLOROCYCLOPENTADIENE
HEXACHLOROETHANE
HEXACHLOROPROPENE
HEXANOIC ACID
 INDENOO ,2,3-CD)PYRENE
        LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS

SAMPLE POINT CATEGORY NAME=PAPER MACHINE WHITE WATER SUBCATEGORY=BPK
                            (continued)
              NO. OF
   NO. OF      MILLS        NO. OF         NO.  OF             MINIMUM
    MILLS   NON-DETECT   DATA POINTS    NON-DETECTS   UNITS   SYMBOL
                                                                        MINIMUM
MAXIMUM
SYMBOL    MAXIMUM
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
2
1
1
1
1
1
1






1
1
1
1
1;
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
0
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
2
1
1
1 '
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
0
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
2
1
1
1
1
1
1






UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
10.00
10.00
50.00
10.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
10.00
20.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
27.00
10.00
20.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
10.00
10.00
50.00
10.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
10.00
20.00
10.00
50.00
10.00
10.00
10.00
10:00
10.00
10.00
27.00
10.00
20.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
20.00

-------
CHEHICAl HAHE

ISOPHORONE
ISOPROPAHOt
ISOPROPYL ETHER
tSOSAFROLE
LOHGIFOLENE
MALACHITE GREEN
HETKAPYIULENE
HETHYL H€THA«ESULFONATE
H-BUTAHOL
H-DECAHE (N-C10)
H-DOCOSANE (H-C22)
H-DODECANE (H-C12)
N-EICOSANE CN-C20)
H-HEXACOSANE (N-C26)
H-HEXADECANE CM-C16)
H-HlTROSOOt-H-BUTYLAHINE
M-HITROSODI-N-PROPYLAMINE
H-HITROSODIETHYLAHINE
N-HITROSODIHETHYLAHINE
H-M1TROSOD1PHENYLAMINE
N-HITROSOHETHYLETHYLAHINE
H-HITROSOMETHYLPHENYLAMINE
B-HITROSOHORPHOUNE
H-HITROSOPIPERID1NE
M-OCTACOSANE CN-C28)
H-OCTAOECANE 
H-PROPANOL
H-TETRACOSANE 
U-TETRADECANE CN-CU)
H-TRIACOHTANE (H-C30)
H,H-DIHeTHYLFORMAMIDE
NAPHTHALENE
NITROBENZENE
0-ANISIDINE
0-CP.ESOL
0-TOiUlDlNE
P-CRESOt
P-CYHENE
P-D1HETHYLAHIKOAZ06EHZEHE
PfHTACHlOROBENZENE
PEMTACHtOROETHANE
PENTAMETHYLBEJiZENE
PERYLEHE
PHEHACETIN
PHEHAHTHRENE
PHENOL
PHEHOTHIAZIME
PRONAHIDE
PYRENE
PYR1DIHE
SAFROtE
SOUALENE
STYRENE
                                                        TABLE C-9

                                    LONG-TERM STUDY AND SHORT-TERM STUDY  CONCENTRATIONS

                            SAMPLE POINT CATEGORY NAME=PAPER MACHINE WHITE WATER SUBCATEGORY=BPK
                                                        (continued)
                                                                                                                           62

NO. OF
HILLS
1
2
2
1
1
1
1
1
2
1
1
1
1
1
1
1
1







1
-1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
,1
1
1
1
1
1
1
1
1
NO. OF
KILLS
NON-DETECT
1
2
2
1
1
1
V
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
0
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1

NO. OF
DATA POINTS
1
2
2
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1

NO. OF
NON -DETECTS
1
2
2





2
1
1
1
1






1
1
1
1
1
1
1
2
0
1
1
1
1
1
1
1
1
1
1
1
1
1
1
•1
1
1
1
1
1
1
1
1
1
1


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UGi/L
UGi/L
UGi/L
UGi/L
UGi/L
UGi/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UCi/L
U6/L
UG/L
UG/L
UG/L
UCi/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
' UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
17.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
99.00
10.00

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND .
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
MAXIMUM

 10.00
 10.00
 10.00
 10.00
 50.00
 10.00
 10.00
 20.00
 10.00
 10.00
 10.00
 10.00
 10.00
 10.00
 10.00
 10.00
 20.00
 10.00
 50.00
 20.00
 10.00
 99.00
 10.00
 10.00
 10.00
 10.00
 10.00
 17.00
 10.00
 10.00
 10.00
 10.00
 10.00
 10.00
 10.00
 10.00
 10.00
 10.00
 20.00
 20.00
 20.00
 10.00
 10.00
 10.00
 10.00
 10.00
 50.00
 10.00
 10.00
 10.00
 10.00
 99.00
  10.00

-------
                                                            TABLE C-9
                                                                                                                                63
                                        LONG-TERM  STUDY AND  SHORT-TERM STUDY CONCENTRATIONS
                                SAMPLE  POINT  CATEGORY NAME=PAPER MACHINE  WHITE WATER SUBCATEGORY=BPK
                                                            (continued)
 CHEMICAL  NAME

 T-BUTANOL
 THIANAPHTHENE
 THIOACETAMIDE
 THIOXANTHONE
 TRIPHENYLENE
 TRIPROPYLENEGLYCOL METHYL ETHER
 1-METHYLFLUORENE
 1-METHYLPHENANTHRENE
 1-PHENYLNAPHTHALENE
 1.2-DIBROMO-3-CHLOROPROPANE
 1,2-DICHLOROBENZENE
 1,2-DIPHENYLHYDRAZINE
 1,2,3-TRICHLOROBENZENE
 1,2,3-TRIMETHOXYBENZENE
 1,2,3,4-DIEPOXYBUTANE
 1,2,4-TRICHLOROBENZENE
 1,2,4,5-TETRACHLOROBENZENE
 1,3-BENZENEDIOL (RESORCIMOL)
 1,3-DICHLORO-2-PROPANOL
 1,3-DICHLOROBENZENE
 1,3-DINITROBENZENE
 1,3.5-TRITHIANE
 1,4-DICHLOROBENZENE
 1,4-NAPHTHOQUINONE
 1,5-NAPHTHALENEDIAMINE
 2- CMETHYLTHIO)BENZOTHIAZOL
 2-BROMOCHLOROBENZENE
 2-BUTANOL
 2-CHLORONAPHTHALENE
 2-CHLOROPHENOL
 2-ISOPROPYLNAPHTHALENE
 2-METHYL-4.6-DINITROPHENOL
 2-METHYLBENZOTHIOAZOLE
 2-METHYLNAPHTHALENE
 2-NITROANILINE
 2-NITROPHENOL
 2-PHENYLNAPHTHALENE
 2,3-BENZOFLUORENE
 2,3-DICHLOROANILINE
 2,3-DICHLORONITROBENZENE
 2,4-DIAMINOTOLUENE
 2,4-DICHLOROPHENOL
 2,4-DIMETHYLPHENOL
 2,4-DINITROPHENOL
 2,4-DINITROTOLUENE
 2,4.5-TRIMETHYLANILINE
 2,6-OI-TERT-BUTYL-P-BENZOQINONE
2,6-DICHLORO-4-NITROANILINE
2,6-DINITROTOLUENE
3-BROMOCHLOROBENZENE
3-CHLORONITROBENZENE
3-METHYLCHOLANTHRENE
3-NITROANILINE

NO. OF
MILLS
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
|1
1
1
1
1
1
NO. OF
MILLS
NON -DETECT
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
. 1
1
1
1
1
1







1
1

NO. OF
DATA POINTS
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1

NO. OF
NON-DETECTS
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
i
1
1
1
1
1
1


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L '
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
MINIMUM

 10.00
 10.00
 20.00
 20.00
 10.00
 99.00
 10.00
 10.00
 10.00
 20.00
 10.00
 20.00
 10.00
 10.00
 20.00
 10.00
 10.00
 50.00
 10.00
 10.00
 20.00
 50.00
 10.00
 99.00
 99.00
 10.00
 10.00
 10.00
 10.00
 10.00
 10.00
 20.00
 10.00
 10.00
 10.00
 20.00
 10.00
 10.00
 10.00
 50.00
 99.00
 10.00
 10.00
 50.00
 10.00
 20.00 '
 99.00
 99.00
 10.00
 10.00
 50.00
 10.00
 20.00
MAXIMUM
SYMBOL    MAXIMUM
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
 10.00
 10.00
 20.00
 20.00
 10.00
 99.00
 10.00
 10.00
 10.00
 20.00
 10.00
 20.00
 10.00
 10.00
 20.00
 10.00
 10.00
 50.00
 10.00
 10.00
 20.00
 50.00
 10.00
 99.00
 99.00
 10.00
,10.00
 10.00
 10.00
 10.00
 10.00
 20.00
 10.00
 10.00
 10.00
 20.00
 10.00
 10.00
 10.00
 50.00
 99.00
 10.00
 10.00
 50.00
 10.00
 20.00
 99.00
 99.00
 10.00
 10.00
 50.00
 10.00'
 20.00

-------
                                                            TABLE C-9

                                       LONG-TERM STUDY AND  SHORT-TERH  STUDY  CONCENTRATIONS
                                                                                                                               64
CHEMICAL MAKE

3,3'-DICHLOROBENZIDINE
3,3'-DIHETHOXYBENZIDINE
3,5-DIBROHO-4-HYDROXYBENZONITR
3,6-DlKETHYLPHEKANTHRENE
4-AHIHOBIPHEHYL
4-BfiOHOPHEHYL PHENYL ETHER
4-CHIORO-2-HITROAN1LINE
4-CHLORO-3-HETHYLPHENOL
4-CHLOROAHlLIHE
4-CHLOROPHEHYL PHENYL ETHER
4-UITROANILIHE
4-HITROBJPHEHYL
4-HlTROPHENOL
4,4'-K£THYLENEBIS(2-CHLOROANI)
4,5-HETHYLEHEPHENANTHRENE
5-CHLORO-O-TOtUIDINE
5-HITRO-0-TOLUID1HE
7,12-DIHETHYLBENZCA)ANTHRACENE
ALUHIHUH
AHTIHOHY
ARSENIC
BARIUM
BERYLLIUM
BISMUTH
BORON
CADMIUM
CALCIUM
CERIUM
CHROMIUM
COBALT
COPPER
DYSPROSIUM
ERBIUM
EUROPIUM
GADOUKIUH
GALLIUM
GERHAHIUH
GOLD
HAFNIUM
HOLNIKUH
INDIUM
IODINE
1RIDIUH
IRON
LAHTHAHUH
LEAD
LITHIUM
LUTETIUH
MAGNESIUM
HAXGANESE
KCRCURY
MOLYBDENUM
HECOYHIUM
iHPLE POINT CATEGORY NAHE=PAPER MACHINE UHITE WATER SUBCATEGORY=BPK 	 - 	
(continued)

HO. OF
KILLS
1
1
1
1
1
1
1
1
1
1
1
1
• 1
1
1
1
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
I
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
HILLS
NON-DETECT
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
2
2
2
2
2
1
2
0
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
0
2
2
2
2
1
0
0
2
2

NO. OF
DATA POINTS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
2
2
2
2
6
2
2
2
6
2
2
2
6
6
6
6
6
6
6
6
6
6
6
6
2
6
2
6
6
2
2
2
2
6

NO. OF
NON-DETECTS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
2
2
2
1 2
6
1
2
0
6
2
2
1
6
6
6
6
6.
6'
6
6
6
6
6
6
0
6
2
6
6
1
0
0
2
6


UMITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L .
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
NO
ND
NO
ND
ND
ND
ND
IID
HD
ND
HD
ND
ND
ND
ND
HD
ND
ND

ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND


ND
ND


MINIMUM
50.00
50.00
50.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
10.00
50.00
20.00
10.00
10.00
10.00
10.00
512.00
6.00
2.00
89.00
2.00

10.00
5.00
8080.00

10.00
25.00
16.00












724.00

50.00


1520.00
82.00
2.30
10.00


MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND

ND

ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND



ND
ND


MAXIMUM
50.00
50.00
50.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
10.00
50.00
20.00
10.00
10.00
10.00
10.00
8050.00
. 6.00
2.00
128.00
2.00

1010.00
5.00
17300.00

10.00
25.00
69.00












913.00

50.00'


5390.00
1330.00
5.50
10.00


-------
                    TABLE C-9
                                                                                        65
LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS



CHEMICAL NAME
NICKEL
NIOBIUM
OSMIUM
PALLADIUM
PHOSPHORUS
PLATI'NUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SELENIUM
SILICON
SILVER
SODIUM
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIN
TITANIUM
TUNGSTEN
URANIUM
VANADIUM
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM


NO. OF
MILLS
2
2
Z
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
-- SAmrLt KUIN
NO. OF
MILLS
NON-DETECT
2
2
2
2
1
2
'1
2
2
2
2
2
2
2
10
2
0
1
0
2
2
2
2
2
2
1
1
2)
2
2
2
2
0
2
II LAItUUKT NAME

NO. OF
DATA POINTS
2
6
6
6
4
6
4
6
6
6
6
6
6
2
2
2
2
4
2
6
6
6
2
6
6
2
2
6
6
2
6
2
2
6
=PAPSK MACHINE
(continued)

NO. OF
NON-DETECTS
2
6
6
6
3
6
3
6
6
6
6
6
6
2
0
2
0
3
0
6
6
6
2
6
6
1
1
6
6
2
6
2
0
6
                                   UNITS

                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                  UG/L
                                  UG/L
MINIMUM
SYMBOL

  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND

  ND

  ND

  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND

  ND

MINIMUM
22.00












3.00
6700.00
6.00
150000.00

34700.00



20.00


30.00
5.00


13.00

5.00
50.00
MAXIMUM
SYMBOL
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

ND



ND
ND
ND
ND
ND
ND


ND
ND
ND
ND
ND


MAXIMUM
22.00



1200.00

8500.00






30.00
9100.00
6.00
698000.00
100.00
37300.00



20.00


34.00
137.00


13.00

5.00
1 187.00
                                                                     ND

-------
                    TABLE C-10




LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
                                                                                        66
	 	 SAMPLE POINT CATEGORY NAME=FINAL EFFLUENT SUBCATEGORY=BPK FURNISH=HW —
NO. OF
NO. OF MILLS NO. OF NO. OF MINIMUM
CHEMICAL HAHE HILLS NON-DETECT DATA POINTS NON-DETECTS UNITS SYMBOL

2,3,7,8- TETRACHLORODIBENZO-P-DIOXIN
1,2,3,7,8-PEHTACHLORODIBEHZO-P-DIOXIN
1,2,3,4,7,S-HEXACHLOROOIBENZO-P-DIOXIN
1,2,3,6,7,8-HEXACHLOROOIBENZO-P-DIOXIN
1, 2,3,7,8, 9-HEXACHLOfiODIBENZO-P-DIOXIN
1,2,3,4,6,7,8-HEPTACHLORODIBENZO-P-DIOXI
OCTACHIORODIBENZO-P-DIOXIH
2,3,7,8- TETRACHLORODIBENZOFURAN
1,2,3,7,8-PEHTACHLORODIBENZOFURAN
2,3,4,7,8-PENTACHLORODIBENZOFURAN
1, 2,3,4, 7,8-HEXACHLOROOIBENZOFURAN
1,2,3,6,7,8-HEXACHLOROOlBENZOFURAN
1,2,3,7,8,9-HEXACHLORODIBEMZOFURAN
2,3,4,6,7,8-HEXACHLORODIBEHZOFURAN
1, 2,3,4, 6,7,8-HEPTACHLORODIBENZOFURAN
1,2,3,4,7,8,9-HEPTACHLQRODIBENZOFURAN
OCTACHLOROO 1 BENZOFURAN
4-CHLOROPHENOL
4-CHLOROCATECHOL
4-CHtOROCUAIACOL
5-CHtOROGUAlACQL
5-CHLOfiOVAHILLIH
6-CHLOROVAHILLIN
2-CHtOROSYRIHGALDEHYDE
2,4-DICHLOROPHEHOL
2,6-DICHLOROPHENOL
3,4-DICHLOROPHENOL
3,5-DICHLOROPHENOL
3,4-DtCHLOROCATECHOL
3,5-DICHLOROCATECHOL
3,6-DICHLOROCATECHOL
4,5-DICHLOROCATECHOL
3,4-DICHLOROCUAIACOL
4,5-DICHLOROGUAIACOL
4,6-DlCHLOROGUAIACOL
5,6-DlCHLOROVANILLIN
2,6-DICHLOROSYRINGALDEHYDE
2.3,6-TRlCKLOROPHENOL
2,4,5-TRICHLOROPHENOL
2,4,6-TRICHLOROPHENOL
3,4,5-TRICHLOROCATECHOL
3,4,6-tfUCHLOROCATECHQt
3,4,5-TRICHLOROGUAIACOL
3,4,6-TRICHLOROGUAIACOL
4,5,6-TRlCHLOROGUAIACOL
TRICHLOROSYRINGOL
2,3,4,6-TETRACHLOROPHEHOL
T6TRACHLOROCATECHOL
TE1RACHLOROGUAIACQL
PEHTACHLOROPHENOL
ACmOHITRILE
BENZENE
BROHOOICHLOROHETHANE
BROHOKETKANE

4
4
4
4
4
4
3
4
4
4
4
4
4
4
4
4
4
3
2
3
1
2
4
3
3
4
2
2
3
1
2
4
2
4
4
4
3
2
4
4
4
2
4
3
4
4
4
4
3
4
4
4
4
4-

4
4
4
4
4
3
1
3
4
4
4
4
4
4
4
4
4
3
1
2
1
2
0
1
?
4
2
2
2
0
2
1
2
4
2
4
1
2
3
2
2
2
3
2
2
1
2
2
3
2
4
4
4
4

40
9
9
9
9
9
6
40
9
9
9
9
9
9
9
9
9
39
32
38
3
36
39
37
39
40
4
4
34
3
31
35
36
40
36
39
38
4
40
40
35
31
40
38
38
39
40
34
39
40
40
40
40
40

40
9
9
9
9
8
3
39
9
9
9
9
9
9
9
9
9
39
30
36
3
36
22
30
«
4
4
33
0
31
30
36
40
31
39
34
4
37
37
32
31
39
36
32
32
37
31
39
38
40
40
40
40

PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND'
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
MINIMUM

8.00
5.00
13.00
13.00
15.00
50.00
100.00
9.30
5.00
5.00
8.00
8.00
15.00
10.00
8.00
13.00
25.00
0.30
1.20
0.30
0.50
2.50
2.50
0.50
2.50
0.30
0.30
0.30
2.50
1.65
2.50
1.00
2.50
0.50
2.50
0.50
5.00
0.10
1.00
0.50
0.30
5.00
0.10
0.50
0.30
0.39
0.30
0.30
0.10
0.10
50.00
10.00
10.00
50.00
MAXIMUM
SYMBOL

ND
ND
ND
ND
ND



ND
ND
ND
ND
ND
IND
ND
ND
ND
ND
>

ND
ND


ND
ND
ND


ND

ND
ND

ND

ND



ND






ND

ND
ND
ND
ND
MAXIMUM
i
13.00
62.00
62.00
62.00
62.00
60.00
270.00
14.00
62.00
62.00
'62.00
62.00
62.00
62.00
62.00
62.00
120.00
2.50
1.90
0.90
0.50
5.00
9.00
5.80
0.90
5.00
1.60
1.60
1.10
7.10
5.00
10.50
5.00
5.00
6.80
10.00
9.65 '
1.00
4.30
15.98
26.81
10.00
1.73
1.50
7.55
3.00
2.60
16.99
10.00
18.70
100.00
20.00
20.00
100.00
I

-------
                                                            TABLE C-10
                                                                                                                                 67
                                        LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
 CHEMICAL NAME

 CARBON D1SULFIDE
 CHLOROACETONITRILE
 CHLOROBENZENE
 CHLOROETHANE
 CHLOROFORM
 CHLOROMETHANE
 CIS-1.3-DICHLOROPROPENE
 CROTONALDEHYDE
 DIBROMOCHLOROMETHANE
 DIBROMOMETHANE
 DIETHYL ETHER
 ETHYL CYANIDE
 ETHYL METHACRYLATE
 ETHYLBENZENE '
 IODOMETHANE
 ISOBUTYL ALCOHOL
 M-XYLENE
 METHYL HETHACRYLATE
 METHYLENE CHLORIDE
 0+P XYLENE
 TETRACHLOROETHENE
 TETRACHLOROMETHANE
 TOLUENE
 TRANS-1,2-DICHLOROETHENE
 TRANS-1,3-DICHLOROPROPENE
 TRANS-1.4-DICHLORO-2-BUTENE
 TRIBROMOMETHANE
 TRICHLOROETHENE
 TRICHLOROFLUOROMETHANE
 VINYL ACETATE
 VINYL CHLORIDE
 1,1-0ICHLOROETHANE
 1,1-DICHLOROETHENE
 1,1,1-TRICHLOROETHANE
 1,1,1,2-TETRACHLOROETHANE
 1,1,2-TRICHLOROETHANE
 1,1,2,2-TETRACHLOROETHANE
 1,2-DIBROMOETHANE
 1,2-DICHLOROETHANE
 1,2-DICHLOROPROPANE
 1,2,3-TRICHLOROPROPANE
 1,3-BUTADIENE, 2-CHLORO
 1,3-DICHLOROPROPANE
 1,4-DIOXANE
 2-BUTANONE (MEK)
 2-CHLOROETHYLVINYL ETHER
2-HEXANONE
2-PROPANONE (ACETONE)
 2-PROPEN-1-OL
 2-PROPENAL (ACROLEIN)
2-PROPENENITRILE, 2-METHYL-
3-CHLOROPROPENE
4-HETHYL-2-PENTANONE
•LC ruin

NO. OF
MILLS
4
4
4
4
,4
4
4
4
4
4
4
4
4
4 •
4
4
4
4
4
4
4
4
4
4
4
4
4
4
2
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
1 WUCUUKT NAI
NO. OF
MILLS
NON-DETECT
3
4
4
4
0
4
4
4
4
4
4
4
4
4
4
4
4
4
2
4
4
4
4
4
4
4
4
4
2
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
3
4
4
2
4
4
3
4
4
It-l-lNAL tl-l-LUt
(continued;

NO. OF
DATA POINTS
40
40
40
40
39
40
40
40
40
40
38
40
40
40
40
40
40
40
34
40
40
40
40
40
40
40
40
40
4
40
40
40
39
39
40
40
40
40
40
40
40
40
40
38
40
40
40
38
40
39
40
40
40
:NI SUUUAIbliUK
>

NO. OF
NON-DETECTS
39
40
40
40
1
40
40
40
40
40
38
40
40
40 '
40
40
40
40
32
40
40
40
40
40
40
40
40
40
4
40
40
40
39
39
40
40
40
40
40
40
40
40
40
38
38
40
40
27
40
39
39
40
40
T=BPK , FUI


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
.UG/L
'UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

-------
                    TABLE C-10
                                                                                        68
LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
	 	 	 	 	 	 SAI



CHEMICAL NAME
AOSOR8ASLE ORGANIC MAUDES (AOX)
COO
COLOR
ACEHAPHTHEHE
ACEHAPHTHYLEHE
ACETOPHENOME
ALPHA-HAPHTHYLAHINE
ALPHA-PICOLINE
ALPHA-TERPINEOt
ANILINE
ANTHRACENE
AKAHITE
I-HAPHTHYLAHIHE
BEHZAHTHRONE
SEMZEHETHIOC
BEHZ1DINE
8EHZO(A>AHTHRACENE
BEHZO(A)PYRE»E
8£NZO(B)FLUORAHTHENE
BEHZO(GHI)PERYLENE
S£HZO{K>FLUORANTHENE
BEHZOIC ACID
BENZYL ALCOHOL
8IPHEHYL
BIS (2-CHLOROISOP80PYL) ETHER
SISCCHLOROHETHYDETHERCNR)
BIS(2-CHLORO£THOXY)HETHANE
BIS(2-CHLOROETHYL)ETHER
BISC2-ETHYLHEXYDPHTHALATE
BUTYL BENZYL PHTHALATE
CARBAZOIE
CHRYSEHE
DI-H-BUTYL AHINE
DI-M-BUTYL PHTHALATE
DI-H-OCTYL PHTHALATE
DI BEHZOC A, H) ANTHRACENE
D1BEHZOFURAH
D1BEHZOTHIOPHEHE
DICHLOROOIFLUOROHETHANE 


ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
•^•H




MINIMUM
3.33
160.00
300.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
10.00
20.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
31.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
^^m



MAXIMUM
SYMBOL



ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
•^•1




MAXIM
18.
740.
1210.
10.
10.
10.
10.
50.
10.
10.
10.
50.
50.
50.
10.
50.
10.
10.
10.
20.
10.
50.
10.
10.
10.
10.
10.
10.
10.
10.
20.
10.
10.
10.
10.
20.
10.
10.
10.
10.
10.
31.
10.
10.
20.
10.
20.
20.
20.
10.
10
10
10
M




UM
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
Oo
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
00
•

-------
                    TABLE C-10
                                                                                        69
LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
	 SAMPLE POINT CATEGORY NANE=FINAL EFFLUENT SUBCATEGORY=BPK
(continued)


CHEMICAL NAME
HEXACHLOROCYCLOPENTAD I ENE
HEXACHLOROETHANE
HEXACHLOROPROPENE
HEXANOIC ACID
INDENOC 1 , 2, 3-CD)PYRENE
1SOPHORONE
ISOPROPANOL
ISOPROPYL ETHER
ISOSAFROLE
LONGIFOLENE
MALACHITE GREEN
METHAPYRILENE
METHYL METHANESULFONATE
N-BUTANOL
N-DECANE (N-C10)
N-DOCOSANE (N-C22)
N-DODECANE (N-C12)
N-EICOSANE (N-C20)
N-HEXACOSANE (N-C26)
N-HEXADECANE (N-C16)
N-NITROSODI-N-BUTYLAMINE
N-NITROSODI-N-PROPYLAMINE
N-NITROSODIETHYLAMINE
N-NITROSODIMETHYLAMINE
N-NITROSODIPHENYLAMINE
N-NITROSOMETHYLETHYLAMINE
N-N I TROSOMETHYLPHENYLAMI NE
N-NITROSOHORPHOLINE
N-NITROSOPIPERIDINE
N-OCTACOSANE (N-C28)
N-OCTADECANE (N-C18)
N-PROPANOL
N-TETRACOSANE (N-C24)
N-TETRADECANE CN-CH)
N-TRIACONTANE (N-C30)
N.N-DIMETHYLFORMAMIDE
NAPHTHALENE
NITROBENZENE
0-ANISIDINE
0-CRESOL
0-TOLUIDINE
P-CRESOL
P-CYMENE
P-DIMETHYLAMINOAZOBENZENE
PENTACHLOROBENZENE
PENTACHLOROETHANE
PENTAHETHYLBENZENE
PERYLENE
PHENACETIN
PHENANTHRENE
PHENOL
PHENOTHIAZINE
PRONAM1DE

NO. OF
MILLS






1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
NO. OF
MILLS
NON -DETECT
1
1
1
1
1
1







1
1
1
1
1
1
1
1
1
1
1 .
1
1
1
1
1
1
1
1
1
1
1
1
1
, 1
1
1
1
1
1
1







1
1

NO. OF
DATA POINTS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1

NO. OF
NON-DETECTS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1


UNITS
UG/L
UG/L
UG/L
. UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
FURNISH=HU 	

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
10.00
10.00
20.00
10.00
20.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NP
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
10.00
10.00
20.00
10.00
20.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00 .
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00

-------
                                                           TABLE C-10

                                       LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS

                               SAMPLE POINT CATEGORY HAME=FINAL EFFLUENT SUBCATEGORY=BPK FURNISH=HU
                                                           (continued)
                                                                                                                               70
CHEMICAL HAKE

PYREHE
PYRIDINE
SAFROtE
SOMLEHE
STYREME
T-BOTAMOt
TH1AHAPHTHENE
TH10ACETAHIBE
TH10XAHTHONE
TRlPHENYLEHi
TRIPROPYLEMEGLYCOL METHYL ETHER
1-KETHYLFLUOREHE
1-HETHYLPHEKAHTHRENE
1-PHE«Yt«APHTHALENE
1 ,2-DlBROMO-3-CHLOROPROPANE
1,2-DICHtOROBEHZENE
1,2-DlPBEHYLHYDRAZINE
1,2,3-TRlCHtOROBEMZEHE
1,2,3-TRIHETKOXYBEHZENE
1,2,3,4-DIEPOXYBOTANE
1,2,4-TRICHLOROBEHZENE
1,2,4,5-TETRACHLOROeENZENE
1,3-BEHZEHEDIOt CRESORCINOL)
1,3-DICHLORO-2-PROPANOL
1,3-DlCHLOROBEHZENE
1,3-DINITROBEMZENE
1,3,5-TRITHIAHE
1,4-DICHLORCflEMZENE
1,4-HAPHTHOQUIHONE
1,5-HAPHTHALEHEDIAHINE
2-(KETHYLTHIO)BEMZOTHIAZOL
2-BROHOCHLOROBENZENE
2-BUTAKOC
2-CW.OROHAPHTHALENE
2-CHLOROPHEHOL
2-1SOPROPYLNAP8THALENE
2-HeTHYL-4,6-DINITROPHENOL
2-K6THYLBEMZOTHIOAZOLE
2-HETHYLKAPHTHALEHE
2-HITROAWLIHE
2-HmOPBEHOL
2-PHEHYLHAPHTHALENE
2,3-BENZORUORENE
 2,3-DICHLOROAHRINE
 2,3-DICHLORO«ITROBENZEKE
 2,4-DIAHlNOTOLUENE
 2,4-DICHLOROPHEKOL
 2,4-DIHETHYLPHENOL
 2,4-DINITROPHENOt.
 2,4-OIHITROTOtUENE
 2,4,5-TRIBETHYLANILIHE
 2,6-DI-TERT-BUTYL-P-BENZOQINONE
 2,6-OICHiORO-4-HITROANILIHE

NO. OF
MILLS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1






1
1
1
1
1
1
1
1
1
1
1
1
HO. OF
MILLS
NOH-DETECT
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
V
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
.1
1
1
1

NO. OF
DATA POINTS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
' 1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1

NO. OF
NON-DETECTS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1


UHITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
•ND
ND
ND
HD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
HD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
HD
ND
ND
ND
ND
ND


MINIMUM
10.00
10.00
10.00
99.00
10.00
10.00
10.00
20.00
20.00
10.00
99.00
10.00
10.00
10.00
20.00
10.00
20.00
10.00
10.00
20.00
10.00
10.00
50.00
10.00
10.00
20.00
50.00
10.00
99.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
99.00
10.00
10.00
50.00
10.00
20.00
99.00
99.00

MAXIMUM
SYMBOL
HD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
HD
ND
ND
HD
HD
HD
HD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
HD
HD
HD
HD


MAXIMUM
10.00
10.00
10.00
99.00
10.00
10.00
10.00
20.00
20.00
10.00
99.00
10.00
10.00
10.00
20.00
10.00'
20.00
10.00
10.00
20.00
10.00
10.00
50.00
10.00
10.00
20.00
50.00
10.00
99.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
' 99.00
10.00
10.00
50.00
10.00
20.00
99.00
99.00

-------
                                                           TABLE C-10
                                                                                                                                71
                                        LONG-TERM  STUDY AND SHORT-TERM STUDY CONCENTRATIONS

                               SAMPLE POINT CATEGORY  NAHE=FINAL EFFLUENT SUBCATEGORY=BPK FURNISH=HW
                                                           (continued)
 CHEMICAL NAME

 2,6-DINITROTOLUENE
 3-BROMOCHLOROBENZENE
 3-CHLORONITROBENZENE
 3-METHYLCHOLANTHRENE
 3-NITROANILINE
 3,3'-DICHLOROBENZIDINE
 3,3'-DIHETHOXYBENZIDINE
 3,5 -DIBROMO-4- HYDROX YBENZONI T'R
 3,6-DIMETHYLPHENANTHRENE
 4-AMINOBIPHENYL
 4-BROHOPHENYL PHENYL ETHER
 4-CHLORO-2-NITROANILINE
 4-CHLORO-3-METHYLPHENOL
 4-CHLOROANILINE
 4-CHLOROPHENYL PHENYL ETHER
 4-NITROANILINE
 4-NITROBIPHENYL
 4-NITROPHENOL
 4,4'-HETHYLENEBIS(2-CHLOROANO
 4,5-METHYLENEPHENANTHRENE
 5-CHLORO-O-TOLUIDINE
 5-NITRO-O-TOLUIDINE
 7,12-DIMETHYLBENZ
-------
                             TABLE C-10

        LONG-TERM STUDY AND  SHORT-TERM STUDY CONCENTRATIONS

SAMPLE POINT CATEGORY  NAME=FINAL EFFLUENT SUBCATEGORY=BPK FURNISH=HW
                             (continued)
                                                                                                 72


CHEMICAL HAKE
EHCR1H ALDEHYDE
EHCR1H KETOKE
EPH (SAHTOX)
ETHIOH
ETHOPROP
FAHPHUR
FEHSULFOTHIOH
FEHTHIOH
CAMKA-BHC (LIKOANE)
GAHHA-CHLORDANE
HEPTACHLOR
HEPTACHLOR EPOXIDE
1SOORIH
KSPOWE
LEPTOPHOS
HALATHIOW
H£RPHOS
HETH0XYCM.OR
HfiTHYL PARATH10N
H6THYt TRJTHIOH
HEVINPHOS (PHOSORIN)
HI REX
HALED (DIBROH)
P.P'-DOO
P,P'-DOE
P.P'-DOT
PARATHIOH
PCHS
PHORATE
PHOSHET
PHOSPHAHIDOH
ROHHEL
SULFOTEP
SULPROFOS
TERBUFOS
TETRACHLORVINPHOS
tOKUTHIOM
TRICHLOROHATE
T81CHORPHON
TRIFLURALIH
2,4-D
2,4,5-T
2,4,5-TP (SILVEX)
ALUHIHUH
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
BISMUTH
SORON
CA0HIUH
CALCIUM
CEfUUH

NO. OF
MILLS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
NO. OF
HILLS
NON -DETECT
1
1
1
1
1
1
1
1
1
0
i
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
0
1
1
0
1
0
1

NO. OF
DATA POINTS
1
1





1
1
1
1
1
1
1
1
1
1
1
'1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
3
1
1
1
3

NO. OF
NON-DETECTS
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
0
1
3
0
1
0
3
                                                UNITS

                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                UG/L
                                                 UG/L
                                                 UG/L
                                                 UG/L
                                                 UG/L
                                                 UG/L
                                                 UG/L
                                                 UG/L
                                                 UG/L
                                                 UG/L
MINIMUM
SYMBOL

  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND

  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
   ND
   ND
   ND
   ND
   ND
   ND
   ND
   ND

   ND
   ND

   ND
   ND

   ND

   ND

MINIMUM
0.50
0.50
0.50
0.50
0.50
2.50
3.00
0.50
0.20
0.30
0.20
0.20
0.30
2.00
0.50
0.50
0.50
1.00
0.50
0.50
0.50
0.50
1.00
0.50
0.50
0.40
0.50
0.20
0.50
1.00
3.00
0.50
0.30
0.50
0.50
2.50
0.50
0.50
1.00
0.50
67.00
13.00
13.00
2480.00
6.00
2.00
380.00
2.00

1310.00
5.00
49500.00
MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
.ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND

ND

        MAXIMUM

            0.50
            0.50
            0.50
            0.50
            0.5,0
            2.50
            3.00
            0.50
            0.20
            0.30
            0.20
            0.20
            0.30
            2.00
            0.50
            0.50
            0.50
            1.00
            0.50
            0.50
            0.50
            0.50
            1.00
            0.50
            0.50
            0.40
            0.50
            0.20
            0.50
            1.00
            3.00
            0.50
            0.30
            0.50
            0.50
            2.50
            0.50
            0.50
            1.00
            0.50
            67.00
            13.00
            13.00
          2480.00
            6.00
            2.00
           380.00
            2.00

          1310.00
             5.00
         49500.00
ND

-------
                    TABLE C-10
                                                                                       73
LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS




CHEMICAL NAME
CHROMIUM
COBALT
COPPER
DYSPROSIUM
ERBIUM
EUROPIUM
GADOLINIUM
GALLIUM
GERMANIUM
GOLD
HAFNIUM
HOLM I HUM
INDIUM
IODINE
IRIDIUM
IRON
LANTHANUM
LEAD
LITHIUM
LUTETIUM
MAGNESIUM
MANGANESE
MERCURY
MOLYBDENUM
NEODYMIUM
NICKEL
NIOBIUM
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SELENIUM
SILICON
SILVER
SODIUM
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIN
TITANIUM
TUNGSTEN



NO. OF
MILLS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
-- SAMPLE POIN

NO. OF
MILLS
NON-DETECT
0
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
0
1
0
0
1
1
1
1
1
1
1
0
1
0
1
1
1
1
1
'l
1
0
1
0
0
0
1
1
1
1
1
1
1
0
1
IT CATEGORY NAME


NO. OF
DATA POINTS
1
1
,1
3
3
3
3
3
3
3
3
3
3
3 ,
3
1
3
1
1
3
1
1
1
1
3
1
3
3
3
1
3
1
3
3
3
3
3
3
1
1
1
1
1
1
3
3
3
1
3
3
1
1
3
=FINAL EFFLUEI
(continued)

NO. OF
NON-DETECTS
0
1
1
3
3
3
3
3
3
3
3
3
3
3
3
0
3
1
0
3
0
0
1
1
3
1
3
3
3
0
3
0
3
3
3
3
3
3
1
0
1
0
0
0
3
3
3
1
3
3
1
0
3
                                  UNITS

                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  •UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L,
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
                                  UG/L
MINIMUM
SYMBOL
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND

  ND
  ND

  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND

  ND

  ND
  ND
  ND
  ND
  ND
  ND
  ND

  ND
 ND
 ND
 ND
 ND
 ND
 ND
 ND

 ND

MINIMUM
12.00
25.00
15.00











497.00

50.00
200.00

5250.00
949.00
20.00
10.00

22.00



2400.00

3700.00






30.00
11900.00
6.00
562000.00
300.00
95400.00



65.40


30.00
15.00
MAXIMUM
SYMBOL

NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
un
ND
ND
ND

ND
ND

ND


ND
ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

ND



ND
ND
ND
ND
ND
ND
ND


MAXIMUM
12.00
25.00
15.00











497.00

50.00
200.00

5250.00
949.00
20.00
10.00

22.00



2400.00

3700.00






30.00
11900.00
6.00
562000.00
' 300.00
95400.00



65.40


30.00
15.00
                                                                    ND

-------
                                                      TABLE C-10

                                  LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS

                          SAMPLE POINT CATEGORY NAME=FINAL EFFLUENT SUBCATEGORY==BPK FURNISH=HW
                                                      (continued)
                                                                                                                         74
CHEMICAL NAME

  URANIUM
  VANADIUM
  YTTERBIUM
  YTTRIUH
  ZINC
  ZIRCOHIUH
NO. OF
 MILLS

   1
   1
   1
   1
   1
   1
  NO. OF
   MILLS
NON-DETECT

     1
     0
     1
     1
     0
   •  1
   NO. OF
DATA POINTS

     3
     1
     3
     1
     1
     3
   NO. OF
NON-DETECTS

     3
     0
     3
     1
     0
     3
UNITS

UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
MINIMUM
SYMBOL

  ND

  ND
  ND

  ND
                                                                                           MINIMUM
155.00

  5.00
 93.00
MAXIMUM
SYMBOL

  ND

  ND
  ND

  ND
                                                                                                                 MAXIMUM
155.00

  5.00
 93.00

-------
                                                           TABLE C-11

                                       LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
75
CHEMICAL NAME

2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN
1,2,3,7,8-PENTACHLORODIBENZO-P-DIOXIN
1,2,3,4,7,8-HEXACHLORODIBENZO-P-DIOXIN
1,2,3,6,7,8-HEXACHLORODIBENZO-P-DIOXIN
1,2,3,7,8.9-HEXACHLORODIBENZO-P-DIOXIN
1,2,3.4,6,7,8-HEPTACHLORODIBENZprP-DIOXI
OCTACHLOROOIBEHZO-P-DIOXIN   '
2,3,7,8-TETRACHLORODIBENZOFURAN
1,2,3,7,8-PENTACHLORODIBENZOFURAN
2,3,4,7,8-PENTACHLOROOIBENZOFURAN
1,2,3,4,7,8-HEXACHLORODIBENZOFURAN
1,2,3,6,7,8-HEXACHLORODIBENZOFURAN
1,2,3,7,8,9-HEXACHLORODIBENZOFURAN
2,3,4,6,7,8-HEXACHLORODIBENZOFURAN
1,2,3,4,6,7,8-HEPTACHLORODIBENZOFURAN
1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN
OCTACHLORODIBENZOFURAN
4-CHLOROPHENOL
4-CHLOROCATECHOL
4-CHLOROGUAIACOL
5-CHLOROGUAIACOL
5-CHLOROVANILLIN
6-CHLOROVANILLIN
2-CHLOROSYRINGALDEHYDE
2,4-DICHLOROPHENOL
2,6-DICHLOROPHENOL
3,4-DlCHLOROPHENOL
3,5-DICHLOROPHENOL
3,4-DICHLOROCATECHOL
3,5-DICHLOROCATECHOL
3,6-DICHLOROCATECHOL
4,5-DICHLOROCATECHOL
3,4-DICHLOROGUAIACOL
4,5-DICHLOROGUAIACOL
4,6-DICHLOROGUAIACOL
5,6-DICHLOROVANILLIN
2,6-DICHLOROSYRINGALDEHYDE
2,3,6-TRICHLOROPHENOL
2,4,5-TRICHLOROPHENOL
2,4,6-TRICHLOROPHENOL
3,4,5-TRICHLOROCATECHOL
3,4,6-TRICHLOROCATECHOL
3,4,5-TRICHLOROGUAIACOL
3,4,6-TRICHLOROGUAIACOL
4,5,6-TRICHLOROGUAIACOL,
TRICHLOROSYRINGOL
2,3,4,6-TETRACHLOROPHENOL
TETRACHLOROCATECHOL
TETRACHLOROGUAIACOL
PENTACHLOROPHENOL
ACRYLONITRILE
BENZENE
BROMOOICHLOROMETHANE
BROMOMETHANE
II LAICb
NO. OF
MILLS
10
9
9
9
9
9
8
10
9
9
9
9
9
9
9
9
8
7
5
7
2
5
9
7
8
10
5
5'
7
1
6
10
5
10
9
9
7
5
10
10
9
5
10
7
10
10
10
10
8
10
10
10
10
10
UK I NAPlt-l-lN
NO. OF
MILLS
NON-DETECT
7
9
9
9
9
6
1
5
9
9
9
9
9
9
9
9
7
6
3
5
2
5
3
7
4
9
5
5
7
1
6
5
3
6
9
8
5
5
10
5
6
5
5
7
6
8
10
8
8
9
10
10
10
10
AL tft-LUtNl 5
NO. OF
DATA POINTS
86
20
20
20 '
20
20
14
85
20
20
20
20
20
20
20
20
17
81
68
81
4
75
82
77
84
86
9
9
74
3
71
82
75
86
79
83
80
9
86
86
77
68
85
81
85
86
86
75
84
86
85
85
85
85
UttUUt:liUKT=tih
NO. OF
NON -DETECTS
81
20
20
20
20
17
4
74
20
20
20
20
20
20
20
20
16
80
66
77
4
75
63
77
64
83
9
9
74
3
71
41
59
72
79
80
71
, 9
86
55
59
68
46
81
66
74
86
71
84
85
85
85
85
85
•f. I-UKNJ

UNITS
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
SH=bW 	
MINIMUM
SYMBOL
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
2.00
3.00
3.00
3.00
3.00
5.00
100.00
3.00
1.00
3.00
3.00
3.00
5.00
3.00
1.00
1.00
20.00
0.25
1.20
0.25
0.50
1.30
1.00
0.50
0.10
0.50
0.25
0.25
2.50
1.00
2.50
1.00
2.50
0.50
0.25
1.00
2.50
0.10
0.25
0.94
0.50
5.00
0.10
0.50
1.03
0.25
0.25
0.25
0.10
0.10
25.00
5.00
5.00
5.00

MAXIMUM
SYMBOL

ND
ND
ND
ND



ND
ND
ND
ND
ND
ND
ND
ND


>

ND
ND
> .
ND ,
I
>
ND
ND
ND
ND
ND



ND


ND
ND
>•

ND

ND


ND

ND

ND
ND
ND
ND


MAXIMUM
74.00
278.00
357.00
385.00
60.00
58.00
5995.00
91.00
278.00
278.00
385.00
455.00
385.00
385.00
417.00
455.00
190.00
0.20
2.21
28.00
5.00
5.00
26.00
5.00
9.00
0.85
5.00
5.00
25.00
5.00
5.00
39.00
4.80
9.49
5.00
15.00
11.00
5.00
5.00
17.97
18.00
10.00
33.00
5.00
5.40
8.20
5.00
17.00
10.00
0.20
100.00
20.00
20.00
100.00

-------
                                                           TABLE C-11

                                       LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
                                                                                                                               76
CHEHICAL NAME

CARBON DISULFIDE
CHIOROACETOHITRILE
CHIOR08EHZENE
CHIOROETHANE
CHLOROFORM
CHLORCHETHAHE
C1S-1,3-DICHLOROPROPENE
CROTOHALDEHYDE
DIBROMOCHLOROHETHANE
DIBROHCKETHAHE
DIETHYL ETHER
ETHYL CYANIDE
ETHYL H6THACRYLATE
ETHYLBEHZENE
IOOOHETHANE
ISOBUTYL ALCOHOL
H-XYIENE
HCTHYL HETHACRYLATE
HETHYLENE CHLORIDE
0+P XYLEHE
TETRACHLOROETHENE
TETRACHLOROHETHANE
TOLUENE
TRANS-1,2-DICHLOROETHEHE
TRANS-1,3-DICHLOROPROPEHE
TRANS-1,4-D1CHLORO-2-BUTENE
TRISROMQHETHANE
TRICHLOROETHEHE
TRICHLOROFLUOROMETHANE
VINYL ACETATE
V1MYL CHLORIDE
1,1-DICHtOROETHANE
1,1-DlCHLOROETHENE
1,1,1-TRICHLOROETHANE
1,1,1,2-TETRACHLOROETHANE
1,1,2-TRICHLOROETHANE
1,1,2,2-TETRACHLOROETHANE
1,2-DIBROHOETHANE
1,2-DICHLOROETHANE
1,2-DlCHLOROPROPANE
1,2,3-TRlCHLOROPROPANE
1,3-80TADIENE, 2-CHLORO
1,3-DICHLOROPROPANE
1,«-D10XAN£
2-SUTAKOHE (H£K)
2-CHtOROETHYLVIHYL ETHER
2-HEXAMOHE
2-PROPAHOHE  (ACETONE)
2-PROPEM-1-OL
2-PROPEHAL (ACROLEIN)
2-PROPENEHITRILE, 2-METHYL-
3-CHLOROPROPEHE
4-H6THYL-2-PENTANONE
'LE POINT CATEGORY NAME=FINAL EFFLUENT SUBCATEGORY=BPK FURNISH=SW 	
(continued)
NO. OF
NO. OF
MILLS
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
6
10
10
10
10
10
10
9
10
10
10
10
10
10
10
10
10
10
10
9
10
10
10
10
10
MILLS
NON-DETECT
5
10
10
10
5
10
10
10
10
10
10
10
10
10
10
10
10
10
7
10
10
10
10
10
10
10
10
10
5
10
10
10
9
10
10
9
10
10
10
10
10
10
10
10
8
10
10
3
10
9
10
10
10
NO. OF
DATA POINTS
85
85
85
85
84
84
85
85
85
85
82
85
85
85
85
85
85
85
68
85
84
85
85
85
85
85
85
84
14
85
85
85
85
84
85
84
84
85
85
85
85
85
85
78
82
85
85
77
85
83
85
85
85
NO. OF
NON-DETECTS
68 ,
85
85
85
49
84
85
. 85
85
85
82
85
85
85
85
85
85 '
85
63
85
84
85
85
85
85
85
85
84
11
85
85
85
84
84
85
84
84
85
85
85
85
85
85
78
80
85
85
44
85
82
85
85
85

UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MINIMUM
10.00

5.00
5.00
5.00
5.00


5.00

5.00


5.00




5.00

5.00
5.00
5.00
5.00
5.00

5.00
5.00
10.00

5.00
5.00
5.00
5.00

5.00
5.00

5.00
5.00



10.00
10.00
5.00

50.00

25.00



MAXIMUM
SYMBOL

ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND

ND
ND
ND

MAXIMUM
56.83
20.00
20.00
100.00
345.92
100.00
20.00
100.00
20.00
20.00
100.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
480.40
20.00
20.00
20.00
20.00
20.00
20.00
100.00
20.00
80.00
32.80
100.00
20.00
20.00
15.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
200.00
232.00
20.00
100.00
2326.66
20.00
51.86
20.00
20.00
100.00

-------
                                                             TABLE C-11
                                                                                                                                 77
                                         LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
 CHEMICAL NAME

 ADSORBABLE ORGANIC HALIDES (AOX)
 COD
 COLOR
 ACENAPHTHENE
 ACENAPHTHYLENE
 ACETOPHENONE
 ALPHA-NAPHTHYLAMINE
 ALPHA-PICOLINE
 ALPHA-TERP1NEOL
 ANILINE
 ANTHRACENE
 ARAHITE
 B-NAPHTHYLAMINE
 BENZANTHRONE
 BENZENETHIOL
 BENZIDINE
 BENZO(A)ANTHRACENE
 BENZO(A)PYRENE
 BENZO(B)FLUORANTHENE
 BENZO(GHI)PERYLENE
 BENZO

NO. OF
NON -DETECTS
0
0
0
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
0
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
0
2
2
2
2
2
2
2
2
2
2
2
1 1 — orK rui


UNITS
MG/L
MG/L
MG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
XNjan=aw -

MINIMUM
SYMBOL
>


ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND



MINIMUM
0.12
272.00
115.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
10.00
20.00
10.00
50.00
10.00
56.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
49.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00


MAXIMUM
SYMBOL



ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND



MAXIMUM
180.00
810.00
1945.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
50.00
50.00
10.00
50.00
10.00
10.00
10.00
20.00
10.00
50.00
10.00
572.00
10.00
10.00
10.00
10.00
29.00
10.00
20.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
148.00
10.00
10.00
20.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00

-------
                    TABLE C-11




LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
                                                                                        78
	 SAMPLE POINT CATEGORY
NO. OF

CHEMICAL HAKE
HEXACHLOROCYCLOPENTADIENE
HEXACHtOROETHANE
HEXACHLOROPROPENE
HEXAHOIC ACID
INO£NOC1,2,3-CD)PYRENE
ISOPHORONE
ISOPROPAHOL
1SOPROPYL ETHER
ISOSAFROLE
LOHG1FOLENE
MALACHITE GREEK
HETHAPYRILEHE
HGTHYL HETHANESULFONATE
H-BUTAKOt
H-DECANE (M-C10)
H-DOCOSANE (N-C22)
M-DODECANE (H-C12)
H-E1COSANE (H-C20)
H-HEXACOSANE (N-C26)
H-HEXADECAHE (N-C16)
H-H1TROSODI-H-BUTYLAHINE
H-NITRQSODI-N-PROPYLAHINE
H-NITROSOOIETHYLAMINE
H-HITROSODIHETHYLAMINE
H-NITROSOD1PHENYLAMINE
H-HITROSOHETHYLETHYLAMINE
H-HITROSOHETHYLPHENYLAMINE
N-NITROSOHORPHOUNE
H-HITROSOPIPERIDINE
H-OCTACOSANE (N-C28)
H-OCTAOECANE (N-C18)
M-PROPAMOL
H-TETRACOSAHE (N-C24)
M-TETRADECANE (H-C14)
H-TRIACONTAHE (H-C30)
M.H-D1METHYLFORMAHIDE
HAPHTKALEHE
NITROBENZENE
0-AHISIDINE
0-CRESOL
0-TGtUIDIHE
P-CRESOL
P-CYKENE
p-DIBETHYLAHINOAZOBENZENE
PEHTACHLOROBENZENE
PEHTACHLOR06THANE
PEHTAMETHYLBEN2ENE
PERYLENE
PHEHACETIM
PHEHANTHRENE
nucuni
rncfivu
PHENOTHIAZINE
PROHAH1DE
NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
MILLS
NON-DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
0
2
2
2
2
2
2
2
2
2
2
2
2
2
NAME=FINAL EFFLUENT SUBCATEGORY=BPK
(continued)
NO. OF
DATA POINTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
NON -DETECTS,
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
0
2
2
2
2
2
2
2
2
2
2
2
2
2

UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
' UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
FURNISH=SU 	
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MINIMUM
10.00
10.00
20.00
10.00
20.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
12.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MAXIMUM
10.00
10.00
20.00
10.00
20.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
20.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
50.00
20.00
10.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
1791.00
10.00
10.00
18.00
10.00
10.00
10.00
20.00
20.00
20.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00

-------
                                                            TABLE C-11
                                                                                                                                 79
                                        LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
 CHEMICAL NAME

 PYRENE
 PYRIDINE
 SAFROLE
 SQUALENE
 STYRENE
 T-BUTANOL
 THIANAPHTHENE
 THIOACETAHIDE
 THIOXANTHONE
 TRIPHENYLENE
 TRIPROPYLENEGLYCOL METHYL ETHER
 1-HETHYLFLUORENE
 1-HETHYLPHENANTHRENE
 1-PHENYLNAPHTHALENE
 1.2-DIBROMO-3-CHLOROPROPANE
 1,2-DICHLOROBENZENE
 1,2-DIPHENYLHYDRAZINE
 1,2,3-TRICHLOROBENZENE
 1,2,3-TRIMETHOXYBENZENE
 1,2,3,4-DIEPOXYBUTANE
 1,2,4-TRICHLOROBENZENE
 1,2,4,5-TETRACHLOROBENZENE
 1,3-BENZENEDIOL (RESORCINOL)
 1,3-D!CHLORO-2-PROPANOL
 1,3-DICHLOROBENZENE
 1,3-DINITROBENZENE
 1,3,5-TRITHIANE
 1,4-DICHLOROBENZENE
 1,4-NAPHTHOQUINONE
 1,5-NAPHTHALENEDIAMINE
2-(METHYLTHIO)BENZOTHIAZOL
2-BROMOCHLOROBENZENE
2-BUTANOL
2-CHLORONAPHTHALENE
2-CHLOROPHENOL
2-ISOPROPYLNAPHTHALENE
2-METHYL-4.6-DINITROPHENOL
2-HETHYLBENZOTHIOAZOLE
2-METHYLNAPHTHALENE
2-NITROANILINE
2-NITROPHENOL
2-PHENYLNAPHTHALENE
2,3-BENZOFLUORENE
2,3-DICHLOROANILINE
2,3-DICHLORONITROBENZENE
2,4-DIAMINOTOLUENE
2.4-DICHLOROPHENOL
2,4-DIMETHYLPHENOL
2,4-DINITROPHENOL
2,4-DINITROTOLUENE
2,4,5-TRIMETHYLANILINE
2.6-DI-TERT-BUTYL-P-BENZOQINONE
2.6-DICHLORO-4-NITROANILINE
(continued)

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON-DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
DATA POINTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
NON-DETECTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
10.00
10.00
10.00
99.00
10.00
10.00
10.00
20.00
20.00
10.00
99.00
10.00
10.00
10.00
20.00
10.00
20.00
10.00
10.00
20.00
10.00
10.00
50.00
10.00
10.00
20.00
50.00
10.00
99.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00
50.00
99.00
10.00
10.00
50.00
10.00
20.00
99.00
99.00

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND •
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
10.00
10.00
10.00
99.00
10.00
10.00
10.00
20.00
20.00
10.00
99.00
10.00
10.00
10.00
20.00
10.00
20.00
10.00
10.00
20.00
10.00
10.00
50.00
10.00
10.00
20.00
50.00
10.00
99.00
99.00
10.00
10.00
10.00
10.00
10.00
10.00
20.00
10.00
10.00
10.00 '
20.00
10.00
10.00
10.00
50.00 -
99.00
10.00
10.00
50.00
10.00
20.00
99.00
99.00

-------
                                                         TABLE C-11

                                      LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
                                                                                                                             80
CHEMICAL NAME

2,6-DIHmOTOLUENE
3-BROHOCHLOftOBENZENE
3-CHLOROMITROSENZENE
3-H6THYLCHOIANTHRENE
3-HITROAMILIHE
3,3'-DICHLOR0BENZlDINE
3,3'-OIKETHOXYBEHZIDINE
3.5-DIBROMO-4-HYDROXYBENZON1TR
3,6-DlKETHYLPHENANTKRENE
4-AHIKOBIPHEHYL
4-BfiOHOPHENYL PHENYL ETHER
4-CHLORO-2-HITROANILINE
4-CHLORO-3-HETHYLPHENOL
4-CHLOROAHILINE
4-CHLOROPHEHYL PHENYL ETHER
4-MITRQANU.lttE
4-MITROBIPHEHYL
4-HITROPHENOL
4,4'-«eTHYLEMEBIS(2-CHLOROANI>
4,5-HGTHYLENEPHENANTHRENE
5-CHtORO-O-TOLUIDINE
5-HITRO-0-TOLUID1NE
7,12"DIHETHYLBENZ
-------
                     TABLE  C-11
                                                                                         81
LONG-TERM STUDY AND SHORT-TERM  STUDY CONCENTRATIONS


CHEMICAL NAME
ENDRIN ALDEHYDE
ENDRIN KETONE
EPN (SAHTOX)
ETHION
ETHOPROP
FAHPHUR
FENSULFOTHIOH
FENTHION
GAMMA- BHC (LINDANE)
GAMMA- CHLORDANE
HEPTACHLOR
HEPTACHLOR EPOXIDE
HEXAMETH YLPHOSPHORAM I DE
ISODRIN
KEPONE
LEPTOPHOS
MALATHION
HERPHOS
METHOXYCHLOR
METHYL PARATHION
METHYL TRITHION
MEVINPHOS (PHOSDRIN)
MI REX
MONOCROTOPHOS
HALED CDIBROM)
NITROFEN 
-------
                            TABLE  C-11

        LONG-TERH STUDY AND  SHORT-TERM  STUDY CONCENTRATIONS

SAMPLE POINT CATEGORY NAHE=FINAL EFFLUENT SUBCATEGORY=BPK FURNISH=SW
                                                                                               82



CHEMICAL HAKE
TR1HETHYLPHOSPHATE
2,4-D
2,4,5-T
2,4,5-TP (SILVEX)
ALUMINUM
ANTIMONY
ARSENIC
1AR1UH
BERYLLIUM
IISMUTH
BORON
CADMIUM
CALCIUM
CERIUM
CHROMIUM
COBALT
COPPER
DYSPROSIUM
ERBIUM
EUROPIUM
GAOOUN1UH
GALLIUM
GERMANIUM
COLO
KAFHIUM
HOLHINUH
INDIUM
IODINE
1RIDIUM
1ROH
LANTHANUM
LEAD
LITHIUM
LUTETIUH
MAGNESIUM
MANGANESE
MERCURY
MOLYBDENUM
KEODYHIUM
NICKEL
HIOSIUH
OSMIUM
PALLADIUM
PHOSPHORUS
PUT I HUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCAKDIUH
SELENIUM


NO. OF
MILLS
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
OAnrLC ruini
NO. OF
HILLS
NON-DETECT
1
0
2
1
0
2
2
1
2
2
1
2
0
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
6
2
2
2
2
0
0
0
1
2
2
2
2
2
1
2
0
2
2
2
2
2
>2
2


NO. OF
DATA POINTS
1
1
2
2
2
2
2
2
2
6
2
2
2
6
2
2
2
6
6
6
6
6
6
6
6
6
6
6
6
2
6
2
6
6
2
2
2
2
6
2
6
6
6
4
6
2
6
6
6
6
6
6
2
(continued)

NO. OF
NON-DETECTS
1
0
2
1
0
2
2
1
2
6
1
2
0
6
2
2
2
6
6
6
6
6
6
6
6
6
6
6
6
0
6
2
6
6
0
0
0
1
6
2
6
6
6
3
6
0
6
6
6
6
6
6
2
                                            UNITS

                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                            UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                             UG/L
                                              UG/L
                                              UG/L
                                              UG/L
                                              UG/L
                                              UG/L
                                             .UG/L
                                              UG/L
                                              UG/L
                                              UG/L
MINIMUM
SYMBOL

  ND

  ND
  ND

  ND
  ND
  ND
  ND
  ND
  ND
  ND

  ND
  ND
 . ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND

  ND
  ND
  ND
  ND
   ND
   ND
   ND
   ND
   ND
   ND
   ND
   ND

   ND
   ND
   ND
   ND
   ND
   ND
   ND
:SW 	
MINIMUM
0.40
2.22
0.04
13.00
1830.00
6.00
13.90
158.00
2.00

49.00
5.00
34600.00

10.00
25.00
10.00












1210.00

50.00


7050.00
605.00
60.00
10.00

22.00





3100.00






3.00
MAXIMUM
SYMBOL
ND

ND


ND
ND

ND
ND

ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND'
ND




ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

MAXIMUM
0.40
2.22
13.00
2.22
2400.00
6.00
20.00
311.00
2.00

138.00
5.00
87600.00

10.00
25.00
14.00












'1550.00

50.00


12600.00
2660.00
74.00
12.00

22.00



2300.00

3200.00






4.00

-------
                    TABLE C-11
                                                                                        83
LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS



CHEMICAL NAME
SILICON
SILVER
SODIUM
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIN
TITANIUM
TUNGSTEN
URANIUM
VANADIUM
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM


NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
-- annruc ruiw
NO. OF
MILLS
NON-DETECT
0
2
0
0
0
2
2
2
2
2
2
2
0
2
2
1
2
2
0
2
1 V.HICUUKT NHMC

NO. OF
DATA POINTS
2
2
2
2
2
6
6
6
2
6
6
2
2
6
6
2
6
2
2
6
= 1-1 HAL CI-I-LUCI
(continued)

NO. OF
NON-DETECTS
0
2
0
0
0
6
6
6
2
6
6
2
0
6
6
1
6
2
0
6
                                   UNITS

                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                   UG/L
                                            MINIMUM
                                            SYMBOL
NO
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND

ND
  MINIMUM

  6000.00
     6.00
468000.00
   100.00
 91400.00
    20.00
    30.00
    26.00
    24.00

     5.00
    67.00
                      MAXIMUM
                      SYMBOL
                        ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND

ND
           MAXIMUM

           8500.00
              6.00
         765000.00
            300.00
         164000.00
                            33.00
 30.00
 45.00
 60.00

  5.00
116.00

-------
                                                           TABLE  C-12

                                       LONG-TERM. STUDY AND SHORT-TERM STUDY CONCENTRATIONS
                                                                                                                              84
CHEMICAL NAME

2,3,7,8-TETRACHLOROOIBENZO-P-OIOXIN
1,2,3,7,8-P£HTACHLOROOIBENZO-P-DIOXIN
1,H,3,4,7,8-HEXACHLOROOIBENZO-P-DIOXIN
1,2,3,6,7,8-HEXACHLORCOIBEHZO-P-DIOXIN
1,2,3,7,8,9-HEXACHLOaCOlBEHZO-P-DIOXIN
1,2,3,4,6, 7,8-HEPTACHLORODIBENZO-P-DIOXl
OCTACHU»COIBEHZO-P-DIOXIN
2,3,7,8-TETRACHLOROOlBENZOFURAN
1,2,3,7,8-PENTACHLORCOIBENZOFURAN
2,3,4,7,8-PEHTACHLORCOIBENZOFURAN
1,2,3,4,7,8-HEXACHLORCOIBEHZOFURAN
1,2,3,6,7,8-HEXACHLORODlBEHZOFURAN
1,2,3,7,8,9-HEXACHLOROOIBEHZOFURAM
2,3,4.6,7,8-HEXACHLORODIBEMZOFURAN
1,2,3,4,6,7,8-HEPTACHLOROOIBENZOFURAN
1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN
OCTACHLOROOIlENZOFURAN
4-CHLOROfHEKOL
4-CHLOROCATECHOt
4-CHLOROCUMACOt
5-CHiOROGUAIACOL
5-CHUOfiOVAHILLIH
6-CHLOROVANILLIN
2-CKlOROSYRINGALDEHYDE
2,4-DICHlOROPHENOL
2,6-0ICHLOROPHENOL
3,4-DICHLOROPHENOt.
3,5-DlCHLOROPHENOL
3,4-DICHLOROCATECHOL
3,6-DlCHLOROCATECHOL
4,5-DICHLOROCATECHOL
3,4-DICHlOROCUAIACOL
4,5-DlCHLOROGUAIACOL
4,6-DICKLOROGUAIACOL
5,6-DlCHLOfiOVAHILLIN
2,6-DlCKLOROSYRIHGALDEHYDE
2,3,6-TRlCHLO«OPHENOL
2,4,5-TRICHLOROPHENOL
2,4,6-TRICHLOfiOPHENOl
3,4,5-TRlCHlOROCATECHOL
3,4,6-TRlCHLOROCATECHOL
3,4,5-TftlCHLOROGUAlACOL
3,4,6-TRICHLOROGUAIACOL
4,5,6-TRICHLOROGUAIACOL
TRICHtOROSYRINGOL
2,3,4,6-TETRACHLOROPHENOL
TETRACHLOROCATECHOt
TETRACHtOROGUAIACOl
PEHTACHLOROPHEKOl
ACRYLOH1TRILE
BENZENE
BROHOOICHtOROHETHAME
IROHOHETHAHE
CARBON D1SULFICE
E POINT
NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
1
1
2
2
2
2.
1
1
2
1
1
1
2
2
2
2
1
2
2
2
1
2
2
2
2
2
2
2
1
2
2
2
2
2
CATEGORY NA
NO. OF
MILLS
NON-DETECT
1
2
2
2
2
2
0
0
2
2
2
2
2
2
2
1
2
1
1
2
1
.1
2
2
1
2
1
1
2
1
0
1
1
2
2
1
1
2
0
1
0
1
1



0


2
2
2
2
1
ME=FINAL EFFL
NO. OF
DATA POINTS
20
5
5
5
5
5
3
19
5
5
5
5
5
5
3
5
5
20
15
20
3
18
21
20
19
21
3
3
17
16
17
18
20
20
20
21
2
20
21
18
16
20
20
19
21
20
18
20
18
21
21
21
21
21
UENT SUBCAItU
NO. OF
NON-DETECTS
17
5
5
5
5
5
1
9
5
5
5
5
5
5
3
4
5
18
15
20
3
18
21
20
9
21
'3 .
3
17
16
11
18
19
20
20
19
2
20
0
9
15
,18
19
17
18
19
15
18
18
21
21
21
21
20
OKT=PK

UNITS
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
>
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
10.00
10.00
26.00
26.00
25.00
26.00
100.00
10.00
10.00
10.00
26.00
26.00
26.00
26.00
26.00
26.00
50.00
0.25
1.20
0.25
0.50
2.50
0.50
0.50
0.10
0.25
0.25
0.25
2.50
2.50
2.50
2.50
0.50
0.25
0.50
1.25
0.10
0.25
0.70
0.25
5.00
2.50
0.50
2.50
2.50
0.25
5.00
5.00
5.00
50.00
10.00
10.00
50.00
10.00

MAXIMUM
SYMBOL

ND
ND
ND
ND
ND


ND
ND
ND
ND
ND
ND
ND

ND

ND ,
ND
ND
ND
ND
, ND

ND
ND
ND
ND
ND

ND

ND
ND

ND
ND



>






ND
ND
ND
ND
ND



MAXIMUM
21.00
333.00
385.00
455.00
52.00
500.00
210.00
320.00
357.00
294.00
417.00
455.00
455.00
417.00
52.00
2000.00
100.00
4.10
2.50
2.50
0.50
4.17
5.00
5.00
7.50
4.17
0.25
0.25
5.00
5.00
6.90
5.00
0.10
5.00
10.00
2.80
0.10
5.00
14.00
11.90
12.10
1.60
0.10
0.50
3.70
0.20
9.60
1.50
5.80
500.00
100.00
100.00
500.00
176.90

-------
                    TABLE C-12




LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
85



CHEMICAL NAME
CHLOROACETONITRILE
CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
CHLOROMETHANE
CIS-1.3-DICHLOROPROPENE
CROTONALDEHYDE
D 1 BROMOCHLOROMETHANE
DIBROMOMETHANE
DIETHYL ETHER
ETHYL CYANIDE
ETHYL METHACRYLATE
ETHYLBENZENE
IODOMETHANE
ISOBUTYL ALCOHOL
M-XYLENE
METHYL METHACRYLATE
METHYLENE CHLORIDE
0+P XYLENE
TETRACHLOROETHENE
TETRACHLOROMETHANE
TOLUENE
TRANS-1 ,2-DICHLOROETHENE
TRANS- 1 ,3-DICHLOROPROPENE
TRANS-1 ,4-DICHLORO-2-BUTENE
TRIBROMOMETHANE
TRICHLOROETHENE
TR I CHLOROFLUOROMETHANE
VINYL ACETATE
VINYL CHLORIDE
1,1-D I CHLOROETHANE
1,1-DICHLOROETHENE
1,1,1-TR I CHLOROETHANE
1,1,1. 2-TETRACHLOROETHANE
1,1,2-TRICHLOROETHANE
1, 1 ,2, 2-TETRACHLOROETHANE
1,2-DIBROMOETHANE
1,2-D I CHLOROETHANE
1 ,2-DICHLOROPROPANE
1 ,2,3-TRICHLOROPROPANE
1,3-BUTADIENE, 2-CHLORO
1,3-DICHLOROPROPANE
1,4-DIOXANE
2-BUTANONE (MEK)
2-CHLOROETHYLVINYL ETHER
2-HEXANONE
2-PROPANONE (ACETONE)
2-PROPEN-1-OL
2-PROPENAL (ACROLEIN)
2-PROPENENITRILE, 2-METHYL-
3-CHLOROPROPENE
4-METHYL-2-PENTANONE
ADSORBABLE ORGANIC HALIDES (AOX)
	 SAMKLI

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
= ruiNi uAibm
NO. OF
MILLS
NON-DETECT
2
2
2
0
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
2
' 2
2
1
2
2
0
2
2
2
2
2
0
JKT NAME-FINAL
(continued;

NO. OF
DATA POINTS
21
21
21
21
21
21
21
21
21
20
21
21
21
21
21
21
21
19
21
20
21
21
21
21
21
21
21
3
21
21
21
21
21
21
21
21
21
21
21
21
21
21
18
21
21
21
19
21
21
21
21
21
15
EFFLUENT SUBC
>

NO. OF
NON-DETECTS
21
21
21
7
21
21
21
21
21
20
21
21
21
21
21
21
21 .
15
21
20
21
21
21
21
21
21
21
3
21
21
21
21,
21
21
21
21
21
21
21
21
21
21
18
20
21 '
21
8
21
21
21
21
21
0
ATEGORY=I


UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
MG/L
3K 	

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND,
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND




MINIMUM
10.00
10.00
50.00
10.00
50.00
10.00
50.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
50.00
50.00
10.00
50.00
10.00
10.00
50.00
4.26
•

MAXIMUM
SYMBOL
ND
ND
ND

ND
ND
ND
ND
ND
ND'
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND
ND
ND
ND




MAXIMUM
100.00
100.00
500.00
57.00
500.00
100.00
500.00
100.00
100.00
500.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
4493.27
100.00
100.00
100.00
100.00
100.00
100.00
500.00
100.00
100.00
100.00
500.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
100.00
116.69
100.00
500.00
892.56
100.00
500.00
100.00
100.00
500.00
13.60

-------
                                                           TABLE C-12

                                       LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS

                                     SAMPLE POINT CATEGORY NAME=FINAL EFFLUENT SUBCATEGORY=OK
                                                           (continued)
CHEMICAL KANE

COO
COLOR
 3
18
HG/L
MG/L
380.00
965.00
                                                                                                                               86
                                              NO. OF
                                   110. OF      HILLS         NO. OF        NO. OF             MINIMUM             MAXIMUM
                                    MILLS   NON-DETECT   DATA  POINTS   NON-DETECTS   UNITS   SYMBOL    MINIMUM   SYMBOL    MAXIMUM
 690.00
1865.00

-------
                                                            TABLE C-13

                                        LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
87
 CHEMICAL NAME

 2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN
 1,2,3.7.8-PENTACHLORODIBENZO-P-DIOXIN
 1,2.3.4,7,8-H£XACHLORODIBENZO-P-DIOXIN
 1,2,3,6,7,8-HEXACHLORODIBENZO-P-DIOXIN
 1,2,3,7,8,9-HEXACHLORODIBENZO-P-DIOXIN
 1,2,3,4,6,7,8-HEPTACHLORODIBENZO-P-DIOXI
 OCTACHLORODIBENZO-P-DIOXIN
 2,3,7,8-TETRACHLORODIBENZOFURAN
 1,2,3,7,8-PENTACHLORODIBENZOFURAN
 2,3,4,7,8-PENTACHLORODIBENZOFURAN
 1,2,3,4,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,6,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,7,8,9-HEXACHLORODIBENZOFURAN
 2,3,4,6,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,4,6,7,8-HEPTACHLORODIBENZOFURAN
 1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN
 OCTACHLOROOIBENZOFURAN
 4-CHLOROPHENOL
 4-CHLOROCATECHOL
 4-CHLOROGUAIACOL
 5-CHLOROVANILLIN
 6-CHLOROVANILLIN
 2-CHLOROSYRINGALDEHYDE
 2,4-DICHLOROPHENOL
 2,6-DICHLOROPHENOL
 3,4-DICHLOROCATECHOL
 3,6-DICHLOROCATECHOL
 4,5-DICHLOROCATECHOL
 3,4-DICHLOROGUAIACOL
 4,5-DICHLOROGUAIACOL
 4,6-DICHLOROGUAIACOL
 5,6-DICHLOROVANILLIN
 2,6-DICHLOROSYRINGALDEHYDE
 2,4,5-TRICHLOROPHENOL
 2,4,6-TRICHLOROPHENOL
 3,4,5-TRICHLOROCATECHOL
 3,4,6-TRICHLOROCATECHOL
 3,4,5-TRICHLOROGUAIACOL
 3,4,6-TRICHLOROGUAIACOL
 4,5,6-TRICHLOROGUAIACOL
 TRICHLOROSYRINGOL
 2,3,4,6-TETRACHLOROPHENOL
 TETRACHLOROCATECHOL
 TETRACHLOROGUAIACOL
 PENTACHLOROPHENOL
ACRYLONITRILE
 BENZENE
BROMODICHLOROMETHANE
BROMOMETHANE
CARBON DISULFIDE
CHLOROACETONITRILE
CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
•i* r w* n •
NO. OF
MILLS
1
1
1
1
1
1
1
1
1
1







1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1





1
1
1
1
1
1
1
1
1
1





1
wn i i^uwn. i n/i
NO. OF
MILLS
NON -DETECT
1
1
1
1
1
0
0
0
1
1
1
1 .
1
1
1
1
1
0
0
1
0
1
1
1
1
1
1
1
1
1
1
1
1
1
0











1
1
1
0
1
1
1
0
ii*ic— r A rim. c r r i_
NO. OF
DATA POINTS
18
2
2
2
2
2
2
18
2
2
2
2
2
2
2
2
2
18
18
17
18
18
17
18
18
16
16
16
18
18
16
18
18
18
18
16
16
18
18
17
18
18
15
18
18
18
18
18
18
18
18
18
18
18
uun t ouDwtlci
NO. OF
NON-DETECTS
18
2
2
2
2
1
1
4
2
2
2
2
2
2'
2
2
2
15
16
17
17
18
17
18
18
16
16
16
18
18
16
18
18
18
14
16
16
18
18
17
18
18
15
18
18
18
18
18
18
17
18
18
18
0
aUKI^Ud

UNITS
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
PG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L

MINIMUM
SYMBOL
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
. ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND



MINIMUM
10.00
50.00
50.00
50.00
50.00
50.00
100.00
10.00
50.00
50.00
50.00
50.00
50.00
50.00
50.00
50.00
100.00
1.20
1.20
1.20
2.50
2.50
2.50
2.50
2.50
2.50
2.50
2.50
2.50
2.50
2.50
5.00
5.00
2.50
2.50
5.00
5.00
2.50
2.50
2.50
2.50
2.50
5.00
5.00
5.00
50.00
10.00
10.00
50.00
10.00
10.00
10.00
50.00
30.03

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND



ND
ND
' ND
ND
ND
ND
ND
ND
ND

>
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND



MAXIMUM
11.00
53.00
53.00
53.00
53.00
100.00
800.00
55.00
53.00
53.00
53.00
53.00
53.00
53.00
53.00
53.00
110.00
2.90
13.20
1.40
3.04
2.84
2.84
2.80
2.80
2.80
2.80
2.80
2.84
2.84
2.80
5.68
5.68
2.84
8.70
5.60
5.60
2.84
2.84
2.80
2.84
2.84
5.60
5.60
5.60
100.00
20.00
20.00
100.00
12.89
20.00
20.00
100.00
532.96

-------
                    TABLE C-13





LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
                                                                                        88
	 SAMPLE POINT CATEGORY NAHE=FINAL EFFLUENT SUBCATEGORY=DS 	
(continued)
NO. OF

CHEMICAL NAME
CHLOROHETHANE
C1S-1 ,3-DICHLOROPROPENE
CROTOHALDEHYDE
DIBROBOCHtOROHETHANE
DI8ROMOHETHANE
01 ETHYL ETHER
ETHYL CYANIDE
ETHYL KETHACRYLATE
ETHYIBENZENE
1000HETHAKE
JSOeUTYL ALCOHOL
H-XYLEHE
KETHYL HETKACRYLATE
HETHYLENE CHLORIDE
0+P XYLENE
TETRACHIOROETHEHE
TETRACHtOROHETHANE
TOLUENE
TRAHS-1 ,2-DI CHLOROETHENE
TRANS-1,3-DICHLOROPROPENE
TRAHS-1.4-DICHLORO-2-BUTENE
TRIBROMOMETHANE
TRICHLOROETHENE
VIHYL ACETATE
VINYL CHLORIDE
1,1-DICHLOROETHANE
1,1-D1CHLOKO£THENE
1 , 1 , 1 -TR ICHLOROETHANE
1,1,1,2-TETRACHLOROETHANE
1,1,2-TRICHLOROETHANE
1 , 1 ,2,2-TETRACHLOROETHANE
1,2-D1BROHOETHANE
,2-DICHLOROETHANE
,2-01CHLOROPROPANE
,2,3-TRlCHLOfiOPROPANE
,3-SUTADlENE, 2-CHLORO
,3-DICHLOROPROPANE
,4-DIOXANE
2-8UTANONE (HEK)
2-CHLOROETHYLVINYL ETHER
2-HEXAJiONE
2-PROPANONE (ACETONE)
2-PROPEH-1-OC
2-PROPENAL (ACROLEIN)
2-PROPEHEHITRILE, 2-HETHYL-
3-CHLOROPROPENE
4-HCTHYL-2-PEMTAHONE
AOSORBABLE ORGANIC HALIDES (AOX)
COLOR
NO. OF
I MILLS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1





1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
HILLS
NON-DETECT
1
1
1
1
1
1
1
1
1
1
1
1
1
1
. 1
1
1
0
1
1
1
1
1
1
1 ,
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
0
0
NO. OF
DATA POINTS
18
18
18
18
18
18
18
18
18
18
18
18
18
15
18
18
18
18
18
18
18
18
18
18
18
18
18
18
18
17
18
18
18
18
18
18
18
15
18
18
18
18
18
17
18
18
18
17
18
'NO. OF
NON-DETECTS
18
18
18
18
18
18.
18
18
18
18
18
18
18
15
18
18
18
16
18
18
18
18
18
18
18
18
18
18
18
17
18
18
18
18
18
18
18
15
18
18
18
9
18
17
18
18
18
0
0

UNITS
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
UG/L
MG/L
MG/L
MINIMUM
SYMBOL
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
HD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
>


MINIMUM
50.00
10.00
50.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
10.00
50.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
50.00
10.00
50.00
50.00
10.00
50.00
10.00
10.00
50.00
2.16
250.00
MAXIMUM
SYMBOL
ND
ND
ND
ND .
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
>
ND
ND
ND
ND
ND
>


MAXIMUM
100.00
20.00
100.00
20.00
20.00
100.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
12.15
20.00
20.00
100.00
20.00
20.00
100.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
20.00
100.00
20.00
100.00
1000.00
20.00
100.00
20.00
20.00
100.00
9.27
850.00

-------
                                                         TABLE  C-14

                                        LONG-TERM STUDY AND SHORT-TERM STUDY  LOADINGS
89
 CHEMICAL NAME

 2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN
 1,2,3,7,8-PENTACHLORODIBENZO-P-DIOXIN
 1,2,3,4,7,8-HEXACHLORODIBENZO-P-DIOXIN
 1,2,3,6,7,8-HEXACHLORODIBENZO-P-DIOXIN
 1,2,3,7,8,9-HEXACHLORODIBENZO-P-DIOXIN
 1,2,3,4,6,7,8-HEPTACHLORODIBENZO-P-DIOXI
 OCTACHLORODIBENZO-P-DIOXIN
 2,3,7,8-TETRACHLORODIBENZOFURAN
 1,2,3,7,8-PENTACHLORODIBENZOFURAN
 2,3,4,7,8-PENTACHLORODIBENZOFURAN
 1,2,3,4,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,6,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,7,8,9-HEXACHLOROOIBENZOFURAN
 2,3,4,6,7,8-HEXACHLORODIBENZOFURAN
 1,2,3,4,6,7,8-HEPTACHLORODIBENZOFURAN
 1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN
 OCTACHLOROOI BENZOFURAN
 4-CHLOROPHENOL
 4-CHLOROCATECHOL
 4-CHLOROGUAIACOL
 5-CHLOROGUAIACOL
 5-CHLOROVANILL1N
 6-CHLOROVANILLIN
 2-CHLOROSYRINGALDEHYDE
 2,4-DICHLOROPHENOL
 2,6-DICHLOROPHENOL
 3,4-DICHLOROPHENOL
 3,5-DICHLOROPHENOL
 3,4-DICHLOROCATECHOL
 3,5-DICHLOROCATECHOL
 3,6-DICHLOROCATECHOL
 4,5-DICHLOROCATECHOL
 3,4-OICHLOROGUAIACOL
 4,5-DICHLOROGUAIACOL
 4,6-DICHLOROGUAIACOL
 5,6-DICHLOROVANILLIN
 2,6-DICHLOROSYRINGALDEHYDE
 2,3,6-TRICHLOROPHENOL
 2,4,5-TRICHLOROPHENOL
 2,4,6-TRICHLOROPHENOL
 3,4,5-TRICHLOROCATECHOL
 3,4,6-TRICHLOROCATECHOL
 3,4,5-TRICHLOROGUAIACOL
 3,4,6-TRICHLOROGUAIACOL
 4,5,6-TRICHLOROGUAIACOL
 TRICHLOROSYRINGOL
 2,3,4,6-TETRACHLOROPHENOL
 TETRACHLOROCATECHOL
TETRACHLOROGUAIACOL
PENTACHLOROPHENOL
ACRYLONITRILE
BENZENE
BROMODICHLOROMETHANE
BROHOMETHANE
NO. OF
i ivrtrik— r A ni
NO. OF
MILLS
MILLS NON-DETECT
4
4
4
4
4
4
3
4
4
4
4
4
4
4
4
4
4
3
2
3
1
2
4
3
3
4
2
2
3
1
2
4
2
4
4
4
3
2
4
4
4
2
4
3
4
4
4
4
3
4
4
4
4
4
4
4
4
4
4
3
1
3
4
4
4
4
4
4
4
4
4
3
1
2
1
2
0
1
2
4
2
2
2
0
2
1
2
4
2
4
1
2
3
2
2
2
3
2
2
1
2
2
3
2
4
4
4
4
rn, b-rruucn i .
NO. OF
DATA POINTS
40
9
9
9
9
9
6
40
9
9
9
9
9
9
9
9
9
39
32
38
3
36
39
37
39
40
4
4
34
3
31
35
36
40
36
39
38
4
40
40
35
31
40
38
38
39
40
34
39
40
40
40
40
40
ouDun i CUUK i — or K ruitN j
NO. OF
NON-DETECTS UNITS
40
9
9
9
9
8
3
39
9
9
9
9
9
9
9
9
9
39
30
36
3
36
22
30
36
40
4
4
33
0
31
30
36
40
31
39
34
4
37
37
32
31
39
36
32
32
37
31
39
38
40
40
40
40
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
,an=nw -----------
MINIMUM
SYMBOL MINIMUM
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
6.07E-10
5.22E-10
1 .36E-09
1.36E-09
1.57E-09
3.04E-09
6.83E-09
6.07E-10
5.22E-10
5.22E-10
8.35E-10
8.35E-10
1.57E-09
1.04E-09
8.35E-10
1 .36E-09
2.61E-09
2.09E-05
8.05E-05
2.09E-05
3.48E-05
1.55E-04
1.55E-04
3.48E-05
1.55E-04
2.09E-05
2.09E-05
2.09E-05
1.55E-04
1.15E-04
1.55E-04
6.98E-05
1.55E-04
3.48E-05
1.55E-04
3.48E-05
3.11E-04
6.95E-06
1.04E-04
3.48E-05
2.09E-05
3.11E-04
6.95E-06
3.67E-05
2.09E-05
4.07E-05
2.09E-05
2.20E-05
6.95E-06
6.95E-06
3.04E-03
6.07E-04
6.07E-04
3.04E-03
MAXIMUM
SYMBOL MAXIMUM
ND
' ND
ND
ND
ND



ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
>

ND
ND



ND
ND
ND


ND

ND
ND

ND

ND



ND






ND

ND
ND
ND
ND •
1.45E-09
5.88E-09
5.88E-09
5.88E-09
5.88E-09
4.19E-09
1 .89E-08
9.74E-10
5.88E-09
5.88E-09
5.88E-09
5.88E-09
5.88E-09
5.88E-09
5.88E-09
5.88E-09
1.16E-08
2.75E-04
1 .36E-04
6.61E-05
3.67E-05
5.51E-04
1.03E-03
4.26E-04
6.61E-05
5.51E-04
1.67E-04
1.67E-04
7.65E-05
5.22E-04
5.51E-04
8.27E-04
6.11E-04
6.11E-04
5.00E-04
1.22E-03
1.11E-03
1 .04E-04
3.16E-04
1.67E-03
2.80E-03
1.10E-03
1.81E-04
1.04E-04
4.86E-04
2.90E-04
1.91E-04
1.77E-03
1.10E-03
1.95E-03
1.17E-02
2.35E-03
2.35E-03
1.17E-02

-------
CHEMICAL NAME

CARBON D1SULFIDE
CHiOROACETONITRILE
CBLOROBEHZENE
CHLOROETHAHE
CHLOROFORM
CHLOROMETHAHE
C1S-1.3-DICHLOROPROPENE
CROICtfALCEHYOE
DIBRCHOCHLOROHETHANE
D1BRCHOMETHANE
DIETHYL ETHER
ETHYL CYANIDE
ETHYL KETHACRYLATE
ETHYLBENZENE
1COOHETHANE
ISOSUTYL ALCOHOL
H-XYLENE
METHYL METHACRYLATE
HETHYLENE CHLORIDE
0+P XYLENE
TETRACHLOROETHENE
TETRACHLOROHETHANE
TOLUENE
TRAHS-1,2-DICHLOROeTHENE
TRANS-1,3-DICHLOROPROPENE
TRANS-1.4-DICHLORO-2-BUTENE
TRIBROHOHETHANE
TRlCHtOROETHENE
TRICHLOROFLUOROMETHANE
VIMYt ACETATE
VINYL CHLORIDE
 1,1-DlCHLOROETHANE
 1,1-DICHLOROETHENE
 1,1,1-TRICHLOROETHANE
 1,1,1,2-TETRACHLOROETHANE
 1,1,2-TRICHLOROETHANE
 1,1,2,2-TETRACHLOROETHANE
 1,2-DlBROMOETHANE
 1,2-DICHLOROETHANE
 1,2-DICHLOROPROPANE
 1,2,3-TRlCHLOROPROPAHE
 1,3-BUTADIENE, 2-CHLORO
 1,3-DICHLOROPROPANE
 1,4-D10XAHE
 2-BOTAHOME (HEK)
 2-CHiOROETHYLVINYL ETHER
 2-HEXANONE
 2-PROPANOHE  (ACETONE)
 2-PROPEH-1-OL
 2-PROPENAL (ACROLEIN)
 2-PROPEHEHITRILE, 2-HETHYL-
 3-CHLOROPROPENE
 4-HETHYL-2-PEHTANQNE
                                                         TABLE C-14

                                        LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS

                                 LE POINT CATEGORY NAME=FINAL EFFLUEN
                                                         (continued)

                                            HO. OF
                                  NO. OF     HILLS       NO. OF
                                   MILLS  NON-DETECT  DATA POINTS  NON-DETECTS
                                                                                                                            90
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
4
2
4
4
4
4
4
4
 4
 4
 4
 4
 4
 4
 4
 4
 4
 4
 4
 4
 4
 4
 4
 4
 4
 4
3
4
4
4
0
4
4
4
4
4
4
4
4
4
4
4
4
4
2
4
4
4
4
4
4
4
4
4
2
4
4.
4
4
 4
 4
 4
 4
 4
 4
 4
 4
 4
 4
 4
 3
 4
 4
 2
 4
 4
 3
 4
 4
40
40
40
40
39
40
40
40
40
40
38
40
40
40
40
40
40
40
34
40
40
40
40
40
40
40
40
40
  4
40
40
40
39
39
 40
 40
 40
 40
 40
 40
 40
 40
 40
 38
 40
 40
 40
 38
 40
 39
 40
 40
 40
UBCATEGORY=BPK FURNISH=HW 	
1. OF
lETECTS
39
40
40
40
1
40
40
40
40
40
38
40
40
40
40
40
40
40
32
40
40
40
40
40
40
40
40
40
4
40
40
40
39
39
40
40
40
40
40
40
40
40
40
38
38
40
40
27
40
39
39
40
40

UNITS
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KS/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
HD
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
HD
ND
ND
ND

MINIMUM
6.07E-04
6.07E-04
6.07E-04
3.04E-03
2.35E-03
3.04E-03
6.07E-04
3.04E-03
6.07E-04
6.07E-04
3.04E-03
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.21E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
3.04E-03
6.07E-04
6.07E-04
6.95E-04
3.04E-03
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
6.07E-04
3.04E-03
6.07E-04
3.04E-03
3.11E-03
6.07E-04
3.04E-03
6.07E-04
6.07E-04
3.04E-03
MAXIMUM
SYMBOL

ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND

ND
ND

MAXIMUM
4.85E-03
2.3SE-03
2.35E-03
1.17E-02
2.23E-02
1.17E-02
2.35E-03
1.17E-02
2.35E-03
2.35E-03
1.17E-02
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
1 .36E-02
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
1.17E-02
2.35E-03
2.35E-03
1.04E-03
1.17E-02
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
2.35E-03
1.95E-03
8.39E-03
2.35E-03
1.17E-02
3.06E-02
! 2.35E-03
1.17E-02
6.74E-03
2.35E-03
1.17E-02

-------
 CHEMICAL NAME
                                                          TABLE C-14

                                         LOHG-TERH STUDY AND SHORT-TERM STUDY LOADINGS

                              SAMPLE POINT CATEGORY NAME=FINAL EFFLUENT SUBCATEGORY=BPK FURNISH=HW --
                                                          (continued)
          NO. OF1
NO. OF     MILLS       NO. OF.      NO. OF             MINIMUM            MAXIMUM
 MILLS  NON-DETECT  DATA POINTS  NON-DETECTS   UNITS   SYMBOL   MINIMUM   SYMBOL   MAXIMUM
                                                                                            91
 ADSORBABLE ORGANIC HALIDES (AOX)
 COD
 COLOR
 ACENAPHTHENE
 ACENAPHTHYLENE
 ACETOPHENONE
 ALPHA-NAPHTHYLAMINE
 ALPHA-PICOLINE
 ALPHA-TERPINEOL
 ANILINE
 ANTHRACENE
 ARAMITE
 B-NAPHTHYLAMINE
 BENZANTHRONE
 BENZENETHIOL
 8ENZIDINE
 BENZO(A)ANTHRACENE
 BENZO(A)PYRENE
 BENZO(B)FLUORANTHENE
 BENZO(GHI)PERYLENE
 BENZO(K>FLUORANTHENE
 BENZOIC ACID
 BENZYL ALCOHOL
 BIPHENYL
 BIS (2-CHLOROISOPROPYL) ETHER
 BIS(CHLOROMETHYL)ETHER(NR)
 BIS(2-CHLOROETHOXY)METHANE
 BIS(2-CHLOROETHYL)ETHER
 BIS(2-ETHYLHEXYL)PHTHALATE
 BUTYL BENZYL PHTHALATE
 CARBAZOLE
 CHRYSENE
Dl-N-BUTYL AMINE
DI-N-BUTYL PHTHALATE
DI-N-OCTYL PHTHALATE
DIBENZOCA,H)ANTHRACENE
DIBENZOFURAN
DIBENZOTHIOPHENE
DICHLORODIFLUOROMETHANE (NR)
DIETHYL PHTHALATE
DIMETHYL PHTHALATE
DIMETHYL SULFONE
DIPHENYL ETHER
DIPHENYLAMINE
DIPHENYLDISULFIDE
ETHANOL
ETHYL METHANESULFONATE
ETHYLENETHIOUREA
ETHYNYLESTRADIOL 3-METHYL ETHER
FLUORANTHENE
FLUORENE
HEXACHLORO-1,3-BUTADIENE
HEXACHLOROBENZENE
3
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1






1
1
1
1





1
0
0
0
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1
1
1
1
1
1
37
4
27
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
0
0
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
0
1
1
1
1
1
1





KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
>


ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
2.11E-01
1.11E+01
1 .91E+01
1.04E-03
1.04E-03
1 .04E-03
1.04E-03
5.22E-03
1 .04E-03
1.04E-03
1.04E-03
5.22E-03
5.22E-03
5.22E-03
1.04E-03
5.22E-03
1.04E-03
1 .04E-03
1.04E-03
2.09E-03
1.04E-03
5.22E-03
1.04E-03
1.04E-03
1 .04E-03
1.04E-03
1.04E-03
1.04E-03
1 -04E-03
1.04E-03
2.09E-03
1.04E-03
1.04E-03
1.04E-03
1 .04E-03
2.09E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
3.24E-03
1 .04E-03
1.04E-03
2.09E-03
1.04E-03
2.09E-03
2.09E-03
2.09E-03
1 .04E-03
1.04E-03
1.04E-03
1 .04E-03



ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1.48E+00
7.73E+01
1 .29E+02
1.04E-03
1 .04E-03
1.04E-03
1.04E-03
5.22E-03
1.04E-03
1 .04E-03
1.04E-03
5.22E-03
5.22E-03
5.22E-03
1.04E-03
5.22E-03
1.04E-03
1.04E-03
1.04E-03
2.09E-03
1.04E-03
5.22E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1 .04E-03
1.04E-03
1.04E-03
1.04E-03
2.09E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
2.09E-03
1 .04E-03
1.04E-03
1.04E-03
' 1.04E-03
1.04E-03
3.24E-03
1.04E-03
1 .04E-03
2.09E-03
1.04E-03
2.09E-03
2.09E-03
2.09E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03

-------
                                                          TABLE C-14
                                                                                                                              92
                                         LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
                                                   I

                              SAMPLE POINT CATEGORY NAHE=FINAL EFFLUEMT SUBCATEGORY=BPK FURNISH=HW
                                                           (continued)
CHEHICAL HAHE

WEXACHLOROCYCLOPENTADIENE
HCXACHLOROETHANE
HSXACHLOROPROPEHE
HCXAN01C ACID
1KOEHO(1,2,3-CD)PYRENE
1SOPHOROHE
ISOPROPANOL
1SOPROPYL ETHER
ISOSAFROU
LOHGIFOIEHE
MALACHITE GREEK
K6TKAPYRILENE
K£THYL HETHANESULFOMATE
M-BUTAHOL
H-DECAME (M-C10)
N-DOCOSANE (H-C22)
N-DODECANE (H-C12)
H-EICOSAHE CN-C20)
H-HEXACOSANE (N-C26)
N-BEXADECANE CM-C16)
H-HITROSOOI-H-BUTYLAHIHE
N-HmOSODI-H-PROPYLAHINE
N-NITROSODIETHYLAHINE
H-HITROSOD1HETHYLAMINE
N-NITROSODIPHENYLAHINE
H-HITROSOHETHYLETHYLAMINE
H-MITROSOHETHYLPHENYLAHIHE
H-MITROSOHORPHOLINE
H-HITROSOPIPERIDINE
N-OCTACOSANE (N-C28)
H-OCTADECANE 
H-PROPAHOL
H-TETRACOSANE (H-C34)
N-TETRADECAHE (N-C14)
H-TRIACOMTAHE (N-C30)
H,N-D1HETHYLFORMAHIDE   ,
NAPHTHALENE
NITROBENZENE
0-AM1SID1ME
0-CRESOL
0-TOLUIDIKE
P-CRESOL
P-CYHENE
P-DIHETHYLAHINOAZOBEHZENE
PEHTACHLOROBEHZEHE
PEHTACHLOROETHANE
PEHTAKETHYLBENZENE
PERYLEHE
PKEKACETIH
PHEHAHTHREHE
PHCKd
PHEKOTHIAZIME
PROHAMIDE

NO. OF
MILLS
1
1
1
1









1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
r
1
1
1
1
1
i
NO. OF
MILLS
NON-DETECT
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
•1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
                                                      NO. OF        NO. OF
                                                   DATA POINTS   NON-DETECTS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
 1
 1
 1
 1
 1
 1
 1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1  '
1
.1
1
1
1
1
1
1
1
1
 1
 1
 1
 1
 1
 1
 1
 1
 1
 1
 1
 1
 1
 1

UNITS
KG/ADHT
KG/ADHT
KG/ADHT
KG/ADHT
KG/ADHT
KG/ADHT
KG/ADHT
KG/ADHT
KG/ADHT
KG/ADMT
KG/ADHT
KG/ADHT
KG/ADMT
KG/ADHT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADiMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/A0MT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
MINIMUM
SYMBOL
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MINIMUM
1 .04E-03
1.04E-03
2.09E-03
1.04E-03
2.09E-03
1 .04E-03
1.04E-03
1.04E-03
1.04E-03
5.22E-03
1.04E-03
1 .04E-03
2.09E-03
1.04E-03
1 .04E-03
1 .04E-03
1.04E-03
1.04E-03
1 .04E-03
1.04E-03
1.04E-03
2.09E-03
1 .04E-03
5.22E-03
2.09E-03
1.04E-03
1 .03E-02
1.04E-03
1.04E-03
1 .04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1 .04E-03
1.04E-03
1.04E-03
1 .04E-03
1.04E-03
1 .04E-03
1.04E-03
1.04E-03
1.04E-03
2.09E-03
2.09E-03
2.09E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
5.22E-03
1 .04E-03
MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND •
ND
ND
ND
ND .
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MAXIMUM
1.04E-03
1.04E-03
2.09E-03
1.04E-03
2.09E-03
1.04E-03
1.04E-03
1 .04E-03
1.04E-03
5.22E-03
1.04E-03
1.04E-03
2.09E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
2.09E-03
1.04E-03
5.22E-03
2.09E-03
1.04E-03
1.03E-02
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
2.09E-03
2.09E-03
2.09E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1 .04E-03
5.22E-03
1.04E-03

-------
 CHEMICAL  NAME
                                                        TABLE C-14

                                        LONG-TERM  STUDY AND SHORT-TERM STUDY LOADINGS

                             SAMPLE  POINT  CATEGORY NAHE=FINAL EFFLUENT SUBCATEGORY=BPK FURNISH=HU
                                                        (continued)
          NO. OF
NO. OF     MILLS       NO.  OF       NO. OF             MINIMUM            MAXIMUM
 MILLS  NON-DETECT  DATA POINTS  NON-DETECTS   UNITS   SYMBOL   MINIMUM   SYMBOL   MAXIMUM
                                                                                           93
PYRENE
PYR1DINE
SAFROLE
SQUALENE
STYRENE
T-BUTANOL
THIANAPHTHENE
THIOACETAHIDE
THIOXANTHONE
TRIPHENYLENE
TRIPROPYLENEGLYCOL METHYL ETHER
1-METHYLFLUORENE
1-HETHYLPHENANTHRENE
1-PHENYLNAPHTHALENE
1.2-DIBROMO-3-CHLOROPROPANE
1,2-DICHLOROBENZENE
1,2-DIPHENYLHYDRAZINE
1,2,3-TRICHLOROBENZENE
1,2,3-TRIMETHOXYBENZENE
1,2,3,4-DIEPOXYBUTANE
1,2,4-TRICHLOROBENZENE
1,2,4,5-TETRACHLOROBENZENE
1,3-BENZENEDIOL (RESORCINOL)
1,3-DlCHLORO-2-PROPANOL
1,3-DICHLOROBENZENE
1,3-DINITROBENZENE
1,3,5-TRITHIANE
1,4-DICHLOROBENZENE
1,4-NAPHTHOQUINONE
1,5-NAPHTHALENEDIAMINE
2-(METHYLTHIO)BENZOTHIAZOL
2-BROMOCHLOROBENZENE
2-BUTANOL
2-CHLORONAPHTHALENE
2-CHLOROPHENOL
2-ISOPROPYLNAPHTHALENE
2-METHYL-4.6-DINITROPHENOL
2-METHYLBENZOTHIOAZOLE
2-METHYLNAPHTHALENE
2-NITROANILINE
2-NITROPHENOL
2-PHENYLNAPHTHALENE
2,3-BENZOFLUORENE
2,3-DICHLOROANILINE
2,3-DICHLORONITROBENZENE
2,4-DIAMINOTOLUENE
2,4-DICHLOROPHENOL
2,4-DIMETHYLPHENOL
2,4-DINITROPHENOL
2.4-DINITROTOLUENE
2,4,5-TRIMETHYLANILINE
2,6-DI-TERT-BUTYL-P-BENZOQINONE
2.6-DICHLORO-4-NITROANILINE
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1











1
1
1




1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1





1
1
1
1
1
1
1
1
1
1
1
1






1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1





1
1
1
1
1
1
1
1
1








1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1






KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND '
ND
ND
ND
ND
ND
ND
ND
1.04E-03
1.04E-03
1.04E-03
1.03E-02
1.04E-03
1.04E-03
1.04E-03
2.09E-03
2.09E-03
1.04E-03
1.03E-02
1.04E-03
1.04E-03
1.04E-03
2.09E-03
1.04E-03
2.09E-03
1.04E-03
1 .04E-03
2.09E-03
1.04E-03
1.04E-03
5.22E-03
1.04E-03
1.04E-03
2.09E-03
5.22E-03
1 .04E-03
1.03E-02
1 .03E-02
1 .04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
2.09E-03
1.04E-03
1.04E-03
1.04E-03
2.09E-03
1.04E-03
1.04E-03
1 .04E-03
5.22E-03
1 .03E-02
1.04E-03
1.04E-03
5.22E-03
1.04E-03
2.09E-03
1.03E-02
1.03E-02
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND .
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1.04E-03
1.04E-03
1 .04E-03
1.03E-02
1.04E-03
1.04E-03
1.04E-03
2.09E-03
2.09E-03
1.04E-03
1.03E-02
1.04E-03
1.04E-03
1.04E-03
2.09E-03
1.04E-03
2.09E-03
1.04E-03
1.04E-03
2.09E-03
1.04E-03
1.04E-03
5.22E-03
1 .04E-03
1.04E-03
2.09E-03
5.22E-03
1.04E-03
1.03E-02
1.03E-02
1.04E-03
1 .04E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
2.09E-03
1.04E-03
1.04E-03
1.04E-03
2.09E-03
1.04E-03
1.04E-03
1.04E-03
5.22E-03
1.03E-02
1.04E-03
1.04E-03
5.22E-03
1.04E-03
2.09E-03
1.03E-02
1.03E-02

-------
                                                        TABLE C-14

                                       LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS

                            SAMPLE POINT CATEGORY NAME=FINAL EFFLUENT SUBCATEGORY=BPK FURNISH=HU
                                                        (continued)
                                                                                                                            94
CHEMICAL HAKE

2,6-DIHITROTOLUGNE
3-BROHOCHLOROBENZENE
3-CHLOROWTROBENZENE
S-HETHYLCHOUNTHRENE
3-NITROANILINE
3,3'-DlCHLOROBENZIDINE
3,3'-DIK£THOXYBENZIDINE
3,5-DI8ROHO-4-HYDROXYBENZONITR
3,6-DIHETHYLPHEHANTHRENE
4-AMlHOeiPHENYL
4-BROHOPHENYL PHENYL ETHER
4-CHLORO-2-MITROANILINE
4-CHLORO-3-HETHYLPHENOL
4-CHLOROAHILIHE
4-CHLOROPHENYU PHEHYL ETHER
4-HITROANILINE
4-HITROSIPHENYL
4-HnROPHEMOL
4,4«-H£TBYLEHEBIS(2-CHLOROANI>
4,5-H£THYLEN£PHENANTHRENE
5-CHLORO-O-TOLUIDINE
5-HITRO-O-TOLUIDINE
7,12-D!HETHYLBENZ(A)ANTHRACENE
AIDRIN
ALPHA-BHC
ALPHA-CHLORDANE
AZINPHOS-ETHYL
AZINPHQS-HETHYL
IETA-BHC
CAPTAFOC
CAPTAN
CARBOPHENOTHIOH
CHLOfiBEHZILATE
CHIORFEHVIHPHOS
CHLORPYR1PHOS
COUKAPHOS
CROTOXYPHOS
BELTA-BHC
DEKETOH
DIALLATE
DIAZIKOM
DICKLCFEHTHION
DICHLOWE
DICHLORVOS
DICROTOPHOS
DJELDRIH
DIHETKOATE
DIOXATHIOM
OISULFOTOH
ENOOSUIFAH I
EHOOSL'LFAH II
EHCOSULFAH SULFATE
EHCRIH
                                          NO. OF
                                HO. OF     HILLS       NO. OF       NO. OF
                                 MILLS  NON-DETECT  DATA POINTS  NON-DETECTS

UNITS
KG/ADMT
KG/ADHT
KG//IDMT
KG//IDMT
KG/;iDMT
KG//IDMT
KG//IDMT
KG//IDHT
KG//IDMT
KG//IDHT
KG/ADMT
KG/WMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
MINIMUM
SYMBOL
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MINIMUM
1.04E-03
1.04E-03
5.22E-03
1.04E-03
2.09E-03
5.22E-03
5.22E-03
5.22E-03
1.04E-03
1.04E-03
1.04E-03
2.09E-03
1.04E-03
1.04E-03
1.04E-03
5.22E-03
1.04E-03
5.22E-03
2.09E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MAXIMUM
1.04E-03
1.04E-03
5.22E-03
1.04E-03
2.09E-03
5.22E-03
5.22E-03
5.22E-03
1.04E-03
1.04E-03
1 .04E-03
2.09E-03
' 1.04E-03
1.04E-03
1.04E-03
5.22E-03
1.04E-03
S.22E-03
2.09E-03
1.04E-03
1.04E-03
1.04E-03
1.04E-03
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
Q.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00
O.OOE+00

-------
                 TABLE C-14
                                                                                      95
LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
	 a/WirLC KU1NI LAICbUKT NflnE=MNftL tffLUtNl SUBLA 1 tUUKT=bKK. |-UKN1SH=HW 	
(continued)


CHEMICAL NAME
ENDRIN ALDEHYDE
ENDRIN KETONE
EPN 
ETHION
ETHOPROP
FAMPHUR
FENSULFOTHION
FENTHION
GAMMA-BHC (LINDANE)
GAMMA- CHLORDANE
HEPTACHLOR
HEPTACHLOR EPOXIDE
ISODRIN
KEPONE
LEPTOPHOS
MALATHION
MERPHOS
METHOXYCHLOR
METHYL PARATH10N
METHYL TRITHION
MEVINPHOS (PHOSDRIN)
MI REX
NALED (DIBROM)
P,P'-DDD
P.P'-DDE
P,P'-DDT
PARATHION
PCNB
PHORATE
PHOSMET
PHOSPHAMIDON
RONNEL
SULFOTEP
SULPROFOS
TERBUFOS
TETRACHLORVINPHOS
TOKUTHION
TRICHLORONATE
TRICHORPHON
TR I PLURAL IN
2,4-D
2,4,5-T
2,4,5-TP 
-------
                 TABLE C-14




LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
                                                                                    96



CHEMICAL NAME
CHROHIUH
COBALT
COPPER
DYSPROSIUM
ERBIUM
EUROPIUM
GADOLINIUM
GALLIUM
GERMANIUM
GOLD
HAFNIUM
KOLMINUH
INDIUM
IODINE
IRIDIUM
IRON
LANTHANUM
LEAD
LITHIUM
LUTETIUM
MAGNESIUM
MANGANESE
MERCURY
HOLYIOEHUH
NECOYHIUH
NICKEL
HIOBIUH
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SELENIUM
SILICON
SILVER
SODIUM
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIN
TITANIUM
TUNGSTEN


NO. OF
MILLS
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1









NO. OF
MILLS
NQN-DETECT
0
1
1
1
1
1
1
1
1
1
1
1'
1
1
1
0
1
1
0
1
0
0
1
1
1
1
1
1
1
0
1
0
1
1
1
1
1
1
1
0
I
0
0
0
1
1
1
1
1
1
1
0
1
I unicuuivi nnne

NO. OF
DATA POINTS
1
1
1
3
3
3
3
3
3
3
3
3
3
3
3
1
3
1
1
3
1
1
1
1
3
1
3
3
3
1
3
1
3
3
3
3
3
3
1 .
1
1
1
1
1
3
3
3
1
3
3
1
1
3
(continued)

'NO. OF
NON-DETECTS
0
1
1
3
3
3
3
3
3
3
3
3
3
3
3
0
3
1
0
3
0
0
1
1
3
1
3
3
3
0
3
0
3
3
3
3
3
3
1
0
1
0
0
0
3
3
3
1
3
3
1
0
3

UNITS
KG/AOHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
MINIMUM
SYMBOL

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND


ND
ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND •
ND
ND
ND

ND



ND
ND
ND
ND
ND
ND
ND

ND
I=MW 	 	
MINIMUM
1.25E-03
2.61E-03
1.57E-03












5.19E-02


5.22E-03
2.09E-02

5.48E-01
9.91E-02
2.09E-03
1.04E-03

2.30E-03



2.51E-01

3.86E-01






3.13E-03
1.24E+00
6.27E-04
5.87E+01
3.13E-02
9.96E+00



6.83E-03


3.13E-03
1.57E-03
MAXIMUM
SYMBOL

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


ND
ND

ND


ND
ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

ND



ND
ND
ND
ND
ND
ND
ND


MAXIMUM
1.25E-03
2.61E-03
1.57E-03












5.19E-02
1

5.22E-03
2.09E-02

5.48E-01
9.91E-02
2.09E-03
1.04E-03

2.30E-03



2.51E-01

3.86E-01






3.13E-03
1.24E+00
6.27E-04
5.87E+01
3.13E-02
9.96E+00



6.83E-03


3.13E-03
1.57E-03
                                                                    ND

-------
                 TABLE C-14

LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
                                           97



CHEMICAL NAME
URANIUM
VANADIUM
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM
	 SAMKLI: ruin
NO. OF
NO. OF MILLS
MILLS NON-DETECT
1 1
1 0
1 1
1 1
1 0
1 1
1 LAItlaUKT NAMt

NO. OF
DATA POINTS
3
1
3
1
1
3
=I-INAL EFFLUEI
(continued)

NO. OF
NON-DETECTS
3
0
3
1
0
3
                                 UNITS

                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
MINIMUM
SYMBOL

  ND

  ND
  ND

  ND
MINIMUM
1.62E-02

5.22E-04
9.71E-03
MAXIMUM
SYMBOL

  ND

  ND
  ND

  ND
                       MAXIMUM
1.62E-02

5.22E-04
9.71E-03

-------
                                                        TABLE C-15
                                                                                                                            98
                                       LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
CHEMICAL NAME

2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN
1,2,3,7,8-P£NTACHLOROOIBENZO-P-DIOXIN
1,2,3,4,7,8-HEXACHLORODIBENZO-P-DIOXIN
1,2,3,6,7,8-HEXACHLORODIBEMZO-P-DIOXIN
1,2,3,7,8,9-HEXACHLOROOIBEHZO-P-DIOXIN
1.2,3,4.6,7,8-HEPTACHLOROOIBENZO-P-DIOXI
OCTACHLORODIBEHZO-P-DIOXIN
2,3,7,8-TETRACHLORODIBENZOFURAN
1,2,3,7,8-PENTACHLOROOIBENZOFURAN
2,3,4,7,8-PENTACHLOROOIBENZOFURAN
1,2,3 ,4 ,7,8-HEXACHLOROOIBENZOFURAN
1,2,3,6,7,8-HEXACHLORODIBENZOFURAN
1,2,3,7,8,9-HEXACHLORODIBENZOFURAN
2,3,4,6,7,8-HEXACHLORODIBENZOFURAN
1,2,3,4,6,7,8-HEPTACHLOSOOIBENZOFURAN
1,2.3,4,7,8,9-HEPTACHLORODlBENZOFURAN
OCTACHLOROOIBENZOFURAN
4-CHLOROPHEHOL
4-CKtOROCATECHOt
4-CHlOROGUAIACOL
5-CKLOfiOa'AIACOL
5-CHtOROVAHILLIN
6-CHLOfiOVAHILLIH
2-CM.OROSYRINGALDEHYDE
2,4-DICHLOROPHENOL
2,6-DICHLOROPHENOL
3,4-DICHLOROPHENOL
3,5-DICHLOROPHENOt
3,4-DICHLOROCATECHOL
3,5-DICHLOROCATECHOL
3,6-DICHLOROCATECHOL
4,5-DICHLOROCATECHOL
3,4-DICHLOROCUAIACOL
4,5-DlCHLOROGUAIACOL
4,6-DICHLOROCUAIACOL
5,6-DlCHLOROVAHlLLlN
2,6-DlCHLOROSYRINGALDEHYDE
2,3,6-TRICHLOROPHENOL
2,4,5-TRICHLOROPKENOL
2,4,6-TRICHLOROPHEHOL
3,4,5-TRICHLOROCATECHOL
3,4,6-TRICHLOROCATECHOL
3,4,5-TRICHLOROGUAIACOL
3,4,6-TRICHLOROGUAIACOL
4,5,6-TRICHLOROGUAIACOL
TRICHLOROSYRINGOL
2,3,4,6-TETRACHLOROPHENOL
TETRACHLOROCATECHOL
TETRACHLOROGUAIACCL
PfiHTACHLOROPHENOL
ACRYLOHITRILE
8EHZEKE
BRCNOD1CHLOROMETHANE
BROHOHETHANE
CATEGORY
NO. OF
NAME-FINAL EFFLUENT SUBCATEGORY=BPK FURNISH=SW 	
NO. OF
MILLS NO. OF NO. OF MINIMUM MAXIMUM
HILLS NON-DETECT DATA POINTS NON-DETECTS UNITS SYMBOL
10
9
9
9
9
9
8
10
9
9
9
9
9
9
9
9
8
7
5
7
2
5
9
7
8
10
5
5
7
1
6
10
5
10
9
9
7
5
10
10
9
5
10
7
10
10
10
10
8
10
10
10
10
10
7
9
9
9
9
6
1
5
9
9
9
9
9
9
9
9
7
6
3
5
2
5
3
7
4
9
5
5
7
1
6
5
3
6
9
8
5
5
10
5
6
5
5
7
6
8
10
8
8
9
10
10
10
10
86
20
20
20
20
20
14
85
20
20
20
20
20
20
20
20
17
81
68
81
4
75
82
77
84
86
9
9
74
3
71
82
75
86
79
83
80
9
86
86
77
68
85
81
85
86
86
75
84
86
85
85
85
85
81
20
20
20
20
17
4
74
20
20
20
20
20
20
20
20
16
80
66
77
4
75
63
77
64
83
9
9
74
3
71
41
59
72
79
80
71
9
86
55
59
68
46
81
66
74
86
71
84
85
85
85
85
85
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT '
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
MINIMUM SYMBOL
1.70E-10
3.30E-10
3.51E-10
3.51E-10
3.51E-10
4.96E-10
7.39E-09
2.78E-10
8.49E-11
3.30E-10
2.64E-10
2.64E-10
4.96E-10
3.51E-10
8.49E-11
8.49E-11
6.61E-10
1.56E-05
3.16E-05
1.56E-05
3.11E-05
6.32E-05
6.32E-05
3.11E-05
6.23E-06
4.38E-05
1.56E-05
1.56E-05
6.32E-05
8.76E-05
6.32E-05
6.23E-05
6.32E-05
3.63E-05
1.56E-05
8.76E-05
1.26E-04
6.23E-06
1.56E-05
3.11E-05
4.38E-05
1 .26E-04
6.23E-06
3.11E-05
5.29E-05
1.81E-05
1.56E-05
1.56E-05
6.23E-06
6.23E-06
1.26E-03
2.53E-04
2.53E-04
3.85E-04

ND
ND
ND
ND



ND
ND
ND
ND
ND
ND
ND
ND


>

ND
ND
>
ND

>
ND
ND
ND
ND
ND


>
ND

>
ND
ND


ND

ND


ND

ND

ND
ND
ND
ND
MAXIMUM
1.23E-08
2.39E-08
3.06E-08
3.30E-08
1.28E-08
1.34E-08
1.98E-07
6.60E-09
2.39E-08
2.39E-08
3.30E-08
3.90E-08
3.30E-08
3.30E-08
3.58E-08
3.90E-08
1 .38E-08
1.72E-05
9.32E-04
2.51E-03
4.49E-04
1.58E-03
2.23E-03
1 .59E-03
8.08E-04
7.29E-05
5.85E-04
5.85E-04
2.24E-03
4.49E-04
1.59E-03
1.20E-02
2.18E-03
5.71E-04
1.59E-03
1.29E-03
8.06E-04
5.85E-04
1.55E-03
1.38E-03
1.40E-03
3.17E-03
4.05E-03
1.55E-03
2.27E-03
5.62E-04
1.55E-03
1 .53E-03
4.22E-03
1.81E-05
3.13E-02
6.26E-03
6.26E-03
3.13E-02

-------
                                                          TABLE  C-15

                                         LONG-TERM STUDY AND  SHORT-TERM STUDY  LOADINGS
99
CHEMICAL NAME

CARBON DISULFIDE
CHLOROACETONITRILE
CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
CHLOROMETHANE
CIS-1,3-DICHLOROPROPENE
CROTONALDEHYDE
DIBROHOCHLOROMETHANE
DIBROMOMETHANE
DIETHYL ETHER
ETHYL CYANIDE
ETHYL METHACRYLATE
ETHYLBENZENE
IODOMETHANE
ISOBUTYL ALCOHOL
M-XYLENE
METHYL METHACRYLATE
METHYLENE CHLORIDE
0+P XYLENE
TETRACHLOROETHENE
TETRACHLOROMETHANE
TOLUENE
TRANS-1,2-DICHLOROETHENE
TRANS-1,3-DICHLOROPROPENE
TRANS-1.4-DICHLORO-2-BUTENE
TRIBROMOMETHANE
TRICHLOROETHENE
TRICHLOROFLUOROHETHANE
VINYL ACETATE
VINYL CHLORIDE
1,1-DICHLOROETHANE
1,1-DICHLOROETHENE
1,1,1-TRICHLOROETHANE
1,1,1,2-TETRACHLOROETHANE
1.1,2-TRICHLOROETHANE
1,1,2,2-TETRACHLOROETHANE
1,2-DIBROMOETHANE
1,2-DICHLOROETHANE
1,2-DICHLOROPROPANE
1,2,3-TRICHLOROPROPANE
1,3-BUTADIENE, 2-CHLORO
1,3-DICHLOROPROPANE
1,4-DIOXANE
2-BUTANONE (MEK)
2-CHLOROETHYLVINYL ETHER
2-HEXANONE
2-PROPANONE (ACETONE)
2-PROPEN-1-OL
2-PROPENAL (ACROLEIN)
2-PROPENENITRILE, 2-METHYL-
3-CHLOROPROPENE
4-METHYL-2-PENTANONE
(continued)

NO. OF
MILLS
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
10
6
10
10
10
10
10
10
9
10
10
10
10
10
10
10
10
10
10
10
9
10
10
10
10
10
NO. OF
MILLS
NON -DETECT
5
10
10
10
5
10
10
10
10
10
10
10
10
10
10
10
10
10
7
10
10
10
10
10
10
10
10
10
5
10
10
10
9
10
10
9
10
10
10
10
10
10
10
10
8
10
10
3
10
9
10
10
10

NO. OF
DATA POINTS
85
85
85
85
84
84
85
85
85
85
82
85
85
85
85
85
85
85
68
85
84
85
85
85
85
85
85
84
14
85
85
85
85
84
85
84
84
85
85
85
85
85
85
78
82
85
85
77
85
83
85
85
85

NO. OF
NON-DETECTS
68
85
85
85
49
84
85
85
85
85
82
85
85
85
85
85
85
85
63
85
84
85
85
85
85
85
85
84
11
85
85
85
84
84
85
84
84
85
85
85
85
85
85
78
80
85
85
44
85
82
85
85
85


UNITS
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
2.53E-04

2.53E-04
3.85E-04
2.53E-04
3.85E-04


2.53E-04

3.72E-04


2.53E-04




2.53E-04

2.53E-04
2.53E-04
2.53E-04
2.53E-04
2.53E-04

2.53E-04
2.53E-04
3.30E-04

2.53E-04
2.53E-04
2.53E-04
2.53E-04

2.53E-04
2.53E-04

Z.53E-04
2.53E-04



2.53E-04
7.25E-04
2.53E-04

1.65E-03

1.26E-03




MAXIMUM
SYMBOL

ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND'
ND

ND

ND
ND
ND


MAXIMUM
9.35E-03
6.26E-03
6.26E-03
3.13E-02
8.06E-02
3.13E-02
6.26E-03
3.13E-02
6.26E-03
6.26E-03
3.13E-02
6.26E-03
6.26E-03
6.26E-03
6.26E-03
6.26E-03
6.26E-03
6.26E-03
3.35E-02
6.26E-03
6.26E-03
6.26E-03
6.26E-03
6.26E-03
6.26E-03
3.13E-02
6.26E-03
6.26E-03
3.94E-03
3.13E-02
6.26E-03
6.26E-03
3.40E-03
6.26E-03
6.26E-03
6.26E-03
6.26E-03
6.26E-03
6.26E-03
6.26E-03
6.26E-03
6.26E-03
6.26E-03
2.42E-02
2.72E-02
6.26E-03
3.13E-02
7.37E-01
6.26E-03
1.65E-02
6.26E-03
6.26E-03
3.13E-02

-------
                                                         TABLE  C-15
                                                                                                                           100
CHEMICAL NAME
                                        LONG-TERM STUDY AND  SHORT-TERM  STUDY  LOADINGS

                             SAMPLE POINT CATEGORY NAME=FINAL EFFLUENT  SUBCATEGORY=8PK  FURNISH=SW
                                                         (continued)

                                            NO.  OF
                                  NO. OF     MILLS       NO. OF       NO. OF
                                   MILLS  NON-DETECT  DATA POINTS   NON-DETECTS
ADSORBABLE ORGANIC HALIDES CAOX)     7         0
COO                                  60
COLOR                                5         0
ACEHAPHTREHE                         2         2
ACENAPHTKYLENE                       2         2
ACETOPHEHOHE                         2         2
ALPHA-HAPHTHYLAHINE                  2         2
ALPHA-PICOUHE                       2         2
ALPHA-7ERP1NEOC                      2         2
ANILINE                              2         2
ANTHRACENE                           2         2
ARAMITE                              2         2
B-HAPHTHYLAHINE                      2         2
SEHZANTHROME                         2         2
EENZENETHIOL                         2         2
BENZ1D1NE                            2         2
B6NZOFLUORANTHENE                 2         2
BENZOIC ACID                         2         2
BENZYL ALCOHOL                       2         2
8IPHENYL                             2         0
BIS (2-CHLOROISOPROPYL) ETHER        2         2
B1S


ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
< 	
MINIMUM
6.16E-03
2.05E+01
6.82E+00
3.30E-04
3.30E-04
3.30E-04
3.30E-04
1.65E-03
3.30E-04
3.30E-04
3.30E-04
1.65E-03
1.65E-03
1.65E-03
3.30E-04
1.65E-03
3.30E-04
3.30E-04
3.30E-04
6.61E-04
3.30E-04
1.65E-03
3.30E-04
1 .85E-03
3.30E-04
3.30E-04
3.30E-04
3.30E-04
8.49E-04
3.30E-04
6.61E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
6.61E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
4.16E-03
3.30E-04
3.30E-04
6.61E-04
3.30E-04
6.61E-04
6.61E-04
6.61E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
MAXIMUM
SYMBOL



ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

MAXIMUM
1 .63E+01
6.22E+01
4.16E+02
8.49E-04
8.49E-04
8.49E-04
8.49E-04
4.24E-03
8.49E-04
8.49E-04
8.49E-04
4.24E-03
4.24E-03
4.24E-03
8.49E-04
4.24E-03
8.49E-04
8.49E-04
8.49E-04
1.70E-03
8.49E-04
4.24E-03
8.49E-04
4.86E-02
8.49E-04
8.49E-04
8.49E-04
8.49E-04
9.58E-04
8.49E-04
1.70E-03
8.49E-04
8.49E-04
8.49E-04
8.49E-04
1.70E-03
8.49E-04
8.49E.-04
8.49E-04
8.49E-04
8.49E-04
4.89E-03
8.49E-04
8.49E-04
1.70E-03
8.49E-04
1.70E-03
1.70E-03
1 .70E-03
8.49E-04
8.49E-04
8;49E-04
8.49E-04

-------
                 TABLE C-15
                                                                                    101
LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
(continued)


CHEMICAL NAME
HEXACHLOROCYCLOPENTAD I ENE
HEXACHLOROETHANE
HEXACHLOROPROPENE
HEXANOIC ACID
INDENO<1.2.3-CD)PYRENE
ISOPHORONE
ISOPROPANOL
ISOPROPYL ETHER
ISOSAFROLE
LONGIFOLENE
MALACHITE GREEN
METHAPYRILENE
METHYL METHANESULFONATE
N-BUTANQL
N-DECANE (N-C10)
N-DOCOSANE (N-C22)
N-DODECANE (N-C12)
N-EICOSANE CN-C20)
N-HEXACOSANE (N-C26)
N-HEXADECANE (N-C16)
N-NITROSODI-N-BUTYLAMINE
N-NITROSODI-N-PROPYLAMINE
N-NITROSODIETHYLAMINE
N-NITROSOOIMETHYLAMINE
N-NITROSODIPHENYLAMINE
N-NITROSOMETHYLETHYLAMINE
N-NITROSOMETHYLPHENYLAMINE
N-NITROSOMORPHOLINE
N-NITROSOPIPERIDINE
N-OCTACOSANE (N-C28)
N-OCTADECANE 
N-TR1ACONTANE (N-C30)
N,N-DIMETHYLFORMAMIDE
NAPHTHALENE
NITROBENZENE
0-ANISIDINE
0-CRESOL
0-TOLUIDINE
P-CRESOL
P-CYMENE
P-DIMETHYLAMINOAZOBENZENE
PENTACHLOROBENZENE
PENTACHLOROETHANE
PENTAMETHYLBENZENE
PERYLENE
PHENACETIN
PHENANTHRENE
PHENOL
PHENOTHIAZINE
PRONAMIDE

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON-DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
0
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
DATA POINTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
•2
2
2
2
2
2

NO. OF
NON-DETECTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
0
2
2
2
2
2
2
2
2
2
2
2
2
2


UNITS
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
3.30E-04
3.30E-04
6.61E-04
3.30E-04
6.61E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
1.65E-03
3.30E-04
3.30E-04
6.61E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
6.61E-04
3.30E-04
1.65E-03
6.61E-04
3.30E-04
3.27E-03
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-Q4
3.30E-04
5.95E-04
3.30E-04
3.30E-04
3.30E-04
6.61E-04
6.61E-04
6.61E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
1.65E-03
3.30E-04

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
8.49E-04
8.49E-04
1.70E-03
8.49E-04
1.70E-03
8.49E-04
8.49E-04
8.49E-04
8.49E-04
4.24E-03
8.49E-04
8.49E-04
1.70E-03
8.49E-04
8.49E-04
8.49E-04
8.49E-04
8.49E-04
8.49E-04
8.49E-04
8.49E-04
1.70E-03
8.49E-04
4.24E-03
1.70E-03
8.49E-04
8.40E-03
8.49E-04
8.49E-04
8.49E-04
8.49E-04
8.49E-04
8.49E-04
8.49E-04
8.49E-04
8.49E-04
1.52E-01
8.49E-04
8.49E-04
1.02E-03
8.49E-04
8.49E-04
' 8.49E-04
1.70E-03
1.70E-03
1.70E-03
8.49E-04
8.49E-04
8.49E-04
8.49E-04
8.49E-04
4.24E-03
8.49E-04

-------
CHEMICAL NAME
                                                       TABLE C-15

                                       LONG-TERM STUDY AHO SHORT-TERM STUDY LOADINGS

                            SAMPLE POINT CATEGORY NAME=FINAL EFFLUENT SUBCATEGORY=BPK FURNISH=SU
                                                       (continued)
                                           NO.  OF
                                 KO. OF     MILLS      HO. OF       NO. OF             MINIMUM            MAXIMUM
                                  MILLS  NON-DETECT  DATA POINTS  NON-DETECTS   UNITS   SYMBOL   MINIMUM   SYMBOL   MAXIMUM
                                                                                                                          102
PYRENE
PYR1DINE
SAFROLE
SQOALENE
STYREHE
T-BUTANOL
THIAHAPHTHENE
THIOACETAWDE
THIOXANTHONE
TRIPH6NYLENE
TfUPROPYLENEGLYCOL METHYL ETHER
1-H6THYLFLUORENE
1"K6THYLPHEHANTHRENE
1-PHENYLHAPHTHALENE
1,2-DIBROHO-3-CHLOROPROPANE
1,2-DICHLOROSEHZENE
1,2-DIPHEHYLHYDRAZINE
1,2,3-TRICHLOROBEHZENE
1,2,3-TRlKETHOXYBENZENE
1,2,3,4-DlEPOXYBUTANE
1,2,4-TRICHLOR06ENZENE
1,2,4,5-TETRACHLOROBENZENE
1,3-BEHZEMEDIOL CRESORCINOL)
1,3-DICHLORO-2-PROPAHOL
1,3-DICHLOROBENZENE
1,3-DIHITROBENZENE
1,3,5-TRITHIANE
1,4-DICHLOROBENZENE
1,4-HAPHTHOQUIHOWE
1,5-HAPHTHALENEDIAHINE
2-
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
-2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
. 2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
. 2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2-
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ABMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/AOMT
KG/AOMT
KG/AOMT
KG/ABMT
KG/ADMT
KG/ABMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/AOMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
3.30E-04
3.30E-04
3.30E-04
3.27E-03
3.30E-04
3.30E-04
3.30E-04
6.61E-04
6.61E-04
3.30E-04
3.27E-03
3.30E-04
3.30E-04
3.30E-04
6.61E-04
3.30E-04
6.61E-04
3.30E-04
3.30E-04
6.61E-04
3.30E-04
3.30E-04
1 .65E-03
3.30E-04
3.30E-04
6.61E-04
1.6SE-03
3.30E-04
3.27E-03
3.27E-03
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
6.61E-04
3.30E-04
3.30E-04
3.30E-04
6.61E-04
3.30E-04
3.30E-04
3.30E-04
1 .65E-03
3.27E-03
3.30E-04
3.30E-04
1.65E-03
3.30E-04
6.61E-04
3.27E-03
3.27E-03
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND '
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
8.49E-04
8.49E-04
8.49E-04
8.40E-03
8.49E-04
8.49E-04
8.49E-04
1.70E-03
1.70E-03
8.49E-04
8.40E-03
8.49E-04
8.49E-04
8.49E-04
1.70E-03
8.49E-04
1.70E-03
8.49E-04
8.49E-04
1.70E-03
8.49E-04
8.49E-04
4.24E-03
8.49E-04
8.49E-04
1.70E-03
4.24E-03
8.49E-04
8.40E-g03
8.40E-03
8.49E-04
8.49E-04
8.49E-04
8.49E-04
8.49E-04
8.49E-04
1.70E-03
8.49E-04
8.49E-04
8.49E-04
1.70E-03
8.49E-04
8.49E-04
8.49E-04
4.24E-03
8.40E-03
8.49E-04
8.49E-04
4.24E-03
8.49E-04
1.70E-03
8.40E-03
8.40E-03

-------
 CHEMICAL NAME
                             TABLE  C-15

           LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS

SAMPLE POINT CATEGORY NAME=FINAL EFFLUENT SUBCATEGORY=BPK
                           .  (continued)

              NO. OF
    NO. OF     MILLS       NO. OF       NO. OF
     MILLS  NON-DETECT  DATA POINTS  NON-DETECTS
                                                                                                                             103
 2.6|-DIN1TROTOLUENE                 2         2
 3-BROMOCHLOROBENZENE               2         2
 3-CHLORONITROBENZENE               2         2
 3-METHYLCHOLANTHRENE               2         2
 3-NITROANILINE                     2         2
 3,3>-DICHLOROBENZIDINE             2         2
 3,3'-DIMETHOXYBENZIDINE            2         2
 3.5-DIBROMO-4-HYDROXYBENZONITR     2         2
 3,6-DIMETHYLPHENANTHRENE           2         2
 4-AMINOBIPHENYL                    2         2
 4-BROMOPHENYL PHENYL ETHER         2         2
 4-CHLORO-2-NITROANILINE            2         2
 4-CHLORO-3-METHYLPHENOL            2         2
 4-CHLOROANILINE                    2         2
 4-CHLOROPHENYL PHENYL ETHER        2         2
 4-NITROANILINE                     2         2
 4-NITROBIPHENYL                    2         2
 4-NITROPHENOL                      2         2
 4,4'-METHYLENEBIS(2-CHLOROANI)     2         2
 4,5-METHYLENEPHENANTHRENE          2         2
 5-CHLORO-O-TOLUIDINE               2         2
 5-NITRO-O-TOLUIDINE                 2         2
 7,12-DIMETHYLBENZ(A)ANTHRACENE     2         2
 ALDRIN                              2         1
 ALPHA-BHC                           2         1
 ALPHA-CHLORDANE                     2         2
 AZINPHOS-ETHYL                      2         2
 AZINPHOS-METHYL                     2         2
 BETA-BHC                            2         2
 CAPTAFOL                            2         1
 CAPTAN                              2         1
 CARBOPHENOTHION                     2         2
 CHLORBENZILATE                      2         2
 CHLORFENVINPHOS                     2         2
 CHLORPYRIPHOS                       2         2
 COUMAPHOS                           2         2
 CROTOXYPHOS                         2         2
 DELTA-BHC                           2         2
 DEMETON                             fe         2
 DIALLATE                            2          2
 DIAZINON                            2          2
 DICHLOFENTHION                      1          1
 DICHLONE                            2          2
DICHLORVOS                          2          2
DICROTOPHOS ,                        2          2
DIELDRIN                            2          1
DIMETHOATE                          2          2
DIOXATHION                          2          2.
DISULFOTON                          2          2
ENDOSULFAN I                        2          2
ENDOSULFAN II                        22
ENDOSULFAN SULFATE                  2          2
ENDRIN                              2          2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             1
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
                             2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 1
 1
 2
 2
 2
 2
 1
 1
 2
 2
 2
 2
 2
 2
 2
 2
 2
 2
 1
 2
 2
 2
 1
 2
 2
 2
2
2
2
2
.uun i — DrK
UNITS
KG/ADMT
KG/AOMT
KG/ADHT
KG/AOMT
KG/ADMT
KG/AOMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
'KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
ruKNjon-
MINIMUH
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
1
MINIMUM
3.30E-04
3.30E-04
1.65E-03
3.30E-04
6.61E-04
1.65E-03
1 .65E-03
1.65E-03
3.30E-04
3.30E-04
3.30E-04
6.61E-04
3.30E-04
3.30E-04
3.30E-04
1.65E-03
3.30E-04
1.65E-03
6.61E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-04
3.30E-06
3.30E-06
1.70E-05
6.61E-06
6.61E-06
3.30E-06
1 .65E-04
3.30E-05
1 .65E-04
6.61E-06
1 .06E-05
3.30E-06
6.61E-06
6.61E-06
8.33E-06
6.61E-06
3.30E-05
3.30E-06
4.24E-05
8.26E-05
3.30E-06
4.76E-05
3.30E-06
1.65E-05
2.64E-05
3.30E-06
1.65E-05
3.30E-06
1.65E-05
3.30E-06
MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


ND
ND
ND '
ND


ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
I
MAXIMUM
8.49E-04
8.49E-04
4.24E-03
8.49E-04
1.70E-03
4.24E-03
4.24E-03
4.24E-03
8.49E-04
8.49E-04
8.49E-04
1.70E-03
8.49E-04
8.49E-04
8.49E-04
4.24E-03
8.49E-04
4.24E-03
1.70E-03
8.49E-04
8.49E-04
8.49E-04
8.49E-04
1.70E-05
8.49EJ'06
8.26E-05
8.49E-05
2.55E-04
3.40E-05
1.78E-04
2.55E-05
1 .70E-04
3.40E-04
2.12E-04
4.24E-05
8.49E-05
2.55E-04
1.70E-05
8.49E-05
1.70E-04
4.24E-05
4.24E-05
1.70E-04
4.24E-05
1 .70E-04
1.70E-05
4.24E-05
8.49E-05
4.24E-05
4.24E-05
2.55E-05
3.40E-05
2.S5E-05

-------
                 TABLE C-15




LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
                                                                                     104
	 SAMPLE POINT CATEGORY NAME=FINAL EFFLUENT SUBCATEGORY=BPK FURNISH
(continued)
NO. OF

CHEMICAL HAKE
ENORIH ALDEHYDE
EMOR1H KETONE
EPH (SANTOX)
ETHIOH
ETHOPROP
FAHPHUR
FEHSULFOTH10H
FEHTHION
GAHHA-BHC (LINDANE)
GAHHA-CHLORDANE
HEPTACHLOR
HEPTACHLOR EPOXIDE
H6XAMETHYLPHOSPHORAHIDE
1SCCRIM

LEPTOPHOS
HALATH10N
HfRPHOS
HETHOXYCHtOR
METHYL PARATHION
METHYL TRITHIOH
H6VWPHOS (PHOSDRIN)
HIRFX
nine A
HOHOCROTOPHOS
HAtED (DIBROH)
HITROFEN (TOO
P,P'-DDO
P,P'-D0E
P,P'-DOT
PARATHIOH
PCS 1016
PCS 1221
PCS 1232
PCS 1242
PCS 1248
PCS 1254
PCS 1260

PHORATE
PHOSKET
PHOSPHAHIDOH
SUtFOTEP
SUtPROFOS
TERBUFOS
TETRACHLORVINPHOS
TOKUTHIOH
TOXAPHENE
TRICHLOfiPHATE
TRICHORPHOM
TRICRESYLPHOSPHATE
TRIFLURALIH
NO. OF
MILLS
2
2
2
2
1
2
2
2
2
1
2
2
1
2
1
2
2
1
2
2
1
2
2
1
2
1
2
2
2
2
1
1
1
1
1
1
1
2
2
2
2
1
2
1
1
2
2
1
1
1
2
1
2
MILLS
NON-DETECT
2
2
2
2
1
2
2
2
1
1
2
2
1
1
1
2
2
1
2
2
1
2
2
1
2
1
2
2
2
2
1
1
1
1
1
1
1
1
2
2
2
1
2
1
1
2
2
1
1
1
2
1
2
NO. OF
DATA POINTS
2
2
2
2
1
2
2
2
2
1
2
2
1
2
1
2
2
1
2
2
1
2
2
1
2
1
2
2
2
2
1
1
1
1
1
1
1
2
2
2
2
1
2
1
1
2
2
1
1
1
2
1
2
NO. OF
NON-DETECTS
2
2
2
2
1
2
2
2
1
1
2
2
1
1
1
2
2
1
2
2
1
2
2
1
2
1
2
2
2
2
1
1
1
1
1
1
1
1
2
2
2
1
2
1
1
2
2
1
1
1
2
1
2

UNITS
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
' KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
MINIMUM
SYMBOL
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
(ID
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
=sw 	

MINIMUM
8.33E-06
1.65E-05
3.30E-06
3.30E-06
4.24E-05
1.06E-05
3.30E-05
3.30E-06
8.33E-06
1 .70E-05
6.61E-06
6.61E-06
8.26E-05
1.65E-05
1.70E-04
3.30E-06
3.30E-06
4.24E-05
1.65E-05
3.30E-06
4.24E-05
3.30E-06
1.65E-05
3.30E-05
1.06E-05
6.61E-06
1.65E-05
1.65E-05
6.61E-06
6.61E-06
6.61E-05
6.61E-05
6.61E-05
6.61E-05
6.61E-05
6.61E-05
6.61E-05
6.61E-06
3.30E-06
6.61E-06
4.76E-05
4.24E-05
3.30E-06
4.24E-05
3.30E-06
3.30E-06
1.84E-05
4.24E-05
3.30E-04
4.24E-05
3.30E-05
1.32E-05
1.65E-05

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
4.24E-05
4.24E-05
4.24E-05
4.24E-05
4.24E-05
2.12E-04
2.55E-04
4.24E-05
1.70E-05
1.70E-05
1.70E-05
1.70E-05
8.26E-05
2.55E-05
1.70E-04
4.24E-05
4.24E-05
4.24E-05
8.49E-05
4.24E-05
4.24E-05
4.24E-05
4.24E-05
3.30E-05
8.49E-05
6.61E-06
4.24E-05
4.24E-05
3.40E-05
4.24E-05
6.61E-05
6.61E-05
6.61E-05
6.61E-05
6.61E-05
6.61E-05
6.61E-05
8.49E-06
4.24E-05
8.49E-05
2.55E-04
4.24E-05
2.55E-05
4.24E-05
3.30E-06
4.24E-05
2.12E-04
4.24E-05
3.30E-04
4.24E-05
8.49E-05
1.32E-05
4.24E-05

-------
                 TABLE C-15
                                                                                    105
LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS



CHEMICAL NAME
TRIMETHYLPHOSPHATE
2,4-D
2.4,5-T
2,4,5-TP (SILVEX)
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
BISMUTH
BORON
CADMIUM
CALCIUM
CERIUM
CHROMIUM
COBALT
COPPER
DYSPROSIUM
ERBIUM
EUROPIUM
GADOLINIUM
GALLIUM
GERMANIUM
GOLD
HAFNIUM
HOLMINUM
INDIUM
IODINE
1RIDIUH
IRON
LANTHANUM
LEAD
LITHIUM
LUTETIUM
MAGNESIUM
MANGANESE
MERCURY
MOLYBDENUM
NEODYMIUM
NICKEL
NIOBIUM
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SELENIUM


NO. OF
MILLS
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
. 2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
SAHKLe KUINI
NO. OF
MILLS
NON -DETECT
1
0
2
1
0
2
2
1
2
2
1
2
0
2
2
2
2
2
|2
2
2
2
2
2
2
2
2
2
2
0
2
2
2
2
0
0
0
1
2
2
2
2
2
1
2
0
2
2
2
2
2
2
2
CAIbliUKT NAHE=F

NO. OF
DATA POINTS
1
1
2
2
2
2
2
2
2
6
2
2
2
6
2
2
2
6
6
6
6
6
6
6
6
6
6
6
6
2
6
2
6
6
2
2
2
2
6
2
6
6
6
4
6
2
6
6
6
6
6
6
2
INAL EFFLUENT
(continued)

NO. OF
NON-DETECTS
1
0
2
1
0
2
2
1
2
6
1
2
0
6
2
2
2
6
6
6
6
6
6
6
6
6
6
6
6
0
6
2
6
6
0
0
0
1
6
2
6
6
6
3
6
0
6
6
6
6
6
6
2
Dl*MICUUKV =
UNITS
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
or*. ruKHia
MINIMUM
SYMBOL
NO

ND
ND

ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND



ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND

MINIMUM
1 .32E-05
7.34E-05
1.16E-06
1.10E-03
6.05E-02
1.98E-04
6.61E-04
1.34E-02
6.61E-05

1.62E-03
1.65E-04
2.89E+00

3.30E-04
8.26E-04
4.63E-04












5.12E-02

1.65E-03


4.16E-01
5.14E-02
1.98E-03
3.30E-04

7.27E-04





1 .06E-01






9.91E-05
MAXIMUM
SYMBOL
ND

ND


ND
ND

ND
ND

ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND




ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

MAXIMUM
1.32E-05
7.34E-05
1.10E-03
7.34E-05
2.04E-01
5.09E-04
1.18E-03
1.03E-02
1.70E-04

1.17E-02
4.24E-04
2.94E+00

8,49E-04
2.12E-03
8.49E-04












1.03E-01

4.24E-03


5.99E-01
8.79E-02
6.28E-03
1.02E-03

1.87E-03



7.60E-02

2.63E-01






3.40E-04

-------
                 TABLE C-15
                                                                                    106
LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS



CHEH1CAL NAME
SILICON
SILVER
SOOIUH
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIM
TITANIUM
TUNGSTEN
URANIUM
VANADIUM
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM


NO. OF
HILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO1. OF
MILLS
NON-DETECT
0
2
0
0
0
2
2
2
*
2
2
2
0
2
2
1
2
2
0
2
I w* I cuwn i nrwifc

NO. OF
DATA POINTS
2
2
2
2
2
6
6
6
2
6
6
2
2
6
6
2
6
2
2
6
(continued)

NO. OF
NON-DETECTS
0
2
0
0
0
6
6
6
2
6
6
2
0
6
6
1
6
2
0
6
                                 UNITS

                                KG/ADHT
                                KG/ADHT
                                KG/ADMT
                                KG/ADHT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADHT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                KG/ADMT
                                           MINIMUM
                                           SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND

ND
MINIMUM

2.81E-01
1.98E-04
2.53E+01
8.49E-03
5.42E+00
1.09E-03
9.91E-04
8.59E-04
2.04E-03

1.65E-04
3.83E-03
                     MAXIMUM
                     SYMBOL
                       ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND
ND

ND
         MAXIMUM

         5.09E-01
         5.09E-04
         3.97E+01
         9.91E-03
         7.76E+00
                        1.70E-03
2.b5E-03
3.82E-03
1.98E-03

4.24E-04
5.69E-03

-------
                                                        TABLE  C-16
                                                                                                                            107
CHEMICAL NAME
                                       LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
                                  SAMPLE POINT CATEGORY NAME=FINAL  EFFLUENT SUBCATEGORY=DK

                                                  NO. OF
                                         NO. OF    MILLS      NO. OF
                                          MILLS NON-DETECT DATA  POINTS NON-DETECTS
2.3,7,8-TETRACHLORODIBENZO-P-DIOXIN         2        1           20
1,2.3,7,8-PENTACHLORODIBENZO-P-DIOXIN       22            5
1,2.3,4,7,8-HEXACHLORODIBENZO-P-DIOXIN      22            5
1,2,3,6,7,8-HEXACHLORODIBENZO-P-DIOXIN      22            5
1,2.3,7,8,9-HEXACHLORODIBENZO-P-DIOXIN      22            5
1,2,3,4,6,7,8-HEPTACHLORODIBENZO-P-DIOXI    22            5
OCTACHLORODIBENZO-P-DIOXIN                  20            3
2.3,7,8-TETRACHLORODIBENZOFURAN             20           19
1,2,3.7,8-PENTACHLORODIBENZOFURAN           22            5
2.3,4.7,8-PENTACHLORODIBENZOFURAN           22            5
1,2,3,4.7,8-HEXACHLORODIBENZOFURAN          22            5
1,2,3,6,7,8-HEXACHLORODIBENZOFURAN          22            5
1,2,3,7,8,9-HEXACHLORODIBENZOFURAN          22            5
2,3,4.6,7,8-HEXACHLORODIBENZOFURAN          22            5
1,2,3,4,6,7,8-HEPTACHLORODIBENZOFURAN       22            3
1,2,3,4,7,8,9-HEPTACHLORODIBENZOFURAN       .2        1            5
OCTACHLORODI8ENZOFURAN                      22            5
4-CHLOROPHENOL                              2        1           20
4-CHLOROCATECHOL                            1        1           15
4-CHLOROGUAIACOL                            22           20
5-CHLOROGUAIACOL                            11            3
5-CHLOROVANILLIN                            1        1           18
6-CHLOROVANILLIN                            22           21
2-CHLOROSYRINGALDEHYDE                      22           20
2,4-DlCHLOROPHENOL                          2        1           19
2,6-DICHLOROPHENOL                          22           21
3,4-DICHLOROPHENOL                          1        1            3
3,5-DICHLOROPHENOL                          1        1            3
3,4-DICHLOROCATECHOL                        2        2           17
3,6-DICHLOROCATECHOL                        1        1           16
4,5-DICHLOROCATECHOL                        1        0           17
3,4-DICHLOROGUAlACOL                        1        1           18
4,5-DICHLOROGUAIACOL                        2        1           20
4,6-DICHLOROGUAIACOL                        22           20
5,6-DICHLOROVANILLIN                        22           20
2,6-DICHLOROSYRINGALDEHYDE                  2        1           21
2,3,6-TRICHLOROPHENOL                       1        1            2
2,4,5-TRICHLOROPHENOL                       22           20
2,4,6-TRICHLOROPHENOL                       2        0           21
3,4,5-TRICHLOROCATECHOL                     2        1           18
3,4,6-TRICHLOROCATECHOL                     1        0           16
3,4,5-TRICHLOROGUAIACOL                     2        1           20
3,4,6-TRICHLOROGUAIACOL                     21           20
4,5,6-TRICHLOROGUAIACOL                     2        1           19
TRICHLOROSYRINGOL                           21           21
2,3,4,6-TETRACHLOROPHENOL                   2        1           20
TETRACHLOROCATECHOL                         20           18
TETRACHLOROGUAIACOL                         2        1           20
PENTACHLOROPHENOL                           1        1           18
ACRYLONITRILE                               22           21
BENZENE                                     22           21
BROMODICHLOROMETHANE                        2        2           21
BROMOMETHANE                                22           21
CARBON DISULFIDE                            2        1           21
SUBU
D. OF
)ETEC1
17
5
5
5
5
5
1
9
5
5
5
5
5
5
3
4
5
18
15
20
3
18
21
20
9
21
3
3
17
16
11
18
19
20
20
19
2
20
0
9
15
18
19
17
18
19
15
18
18
21
21
21
21
20
\ICUUK I =Ulk
rs UNITS
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADNT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
MINIMI*
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
>
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
I
MINIMUM
1.30E-09
1.30E-09
3.37E-09
3.37E-09
3.37E-09
3.37E-09
1.54E-08
1.48E-09
1 .30E-09
1.30E-09
3.37E-09
3.37E-09
3.37E-09
3.37E-09
3.37E-09
3.37E-09
6.62E-09
3.24E-05
1.85E-04
3.24E-05
6.49E-05
3.40E-04
6.49E-05
6.49E-05
1.30E-05
3.24E-05
3.24E-05
3.24E-05
3.64E-04
3.64E-04
3.71E-04
3.40E-04
7.28E-05
3.24E-05
6.49E-05
1 .69E-04
1.30E-05
3.24E-05
9.48E-05
3.38E-05
7.28E-04
3.40E-04
7.28E-05
3.64E-04
3.40E-04
3.64E-05
7.28E-04
6.80E-04
6.55E-04
6.49E-03
1.30E-03
1.30E-03
6.49E-03
1 .30E-03
MAXIMUM
SYMBOL

ND
ND
ND
ND
ND


ND
ND
ND
ND
ND
ND
ND

ND

ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND

ND

ND
ND

ND
ND



>






ND
ND
ND
ND
ND

1
MAXIMUM
3.20E-09
4.85E-08
5.61E-08
6.62E-08
8.03E-09
7.28E-08
2.73E-08
4.15E-08
5.20E-08
4.28E-08
6.07E-08
6.62E-08
6.62E-08
6.07E-08
8.03E-09
2.71E-07
1 .54E-08
5.37E-04
3.69E-04
3.28E-04
7.28E-05
5.46E-04
7.37E-04
7.37E-04
1.13E-03
5.46E-04
3.64E-05
3.64E-05
7.37E-04
7.37E-04
9.04E-04
7.37E-04
1.30E-05
7.37E-'04
1.47E-03
3.79E-04
1.46E-05
7.37E-04
2.39E-03
1.56E-03
1.97E-03
2.17E-04
1 .30E-05
6.49E-05
5.01E-04
2.60E-05
1.26E-03
1.95E-04
9.43E-04
6.77E-02
1.35E-02
1 .35E-02
6.77E-02
2.37E-02

-------
                                                         TABLE C-16
                                                                                                                            108
CHEMICAL NAME

CHLOROACETONITRILE
CHLOROBENZENE
CHLOROETHANE
CHLOROFORM
CHLOROHETHANE
CIS-1.3-DICHLOROPROPENE
CROTOHALDEHYDE
DIBROHOC HLOROHETHAKE
DI8ROMOHETHAHE
DIETHYL ETHER
ETHYL CYANIDE
ETHYL METHACRYLATE
ETHYLBENZENE
10DOHETHANE
ISOSUTYL ALCOHOL
M-XYLENE
H6THYL HETHACRYLATE
H6THYLEHE CHLORIDE
0+P XYLEME
TETRACHLOROETHENE
TETRACHLOROMETHANE
TOLUENE
TRANS-1,2-DICHLOROETHENE
TRANS-1,3-DICHLOROPROPEN£
TRANS-1,*-DICHLQRO-2-BUTENE
TRIBSOHOHETHANE
TRICHLOROETHENE
TRICHLOROFLUOROHETHANE
VINYL ACETATE
VINYL CHLORIDE
1,1-D1CHLOROETHANE
1,1-DICHLOROETHENE
1,1,1-TRICHLOROETHANE
1,1,1,2-TETRACHLOROETHANE
1,1,2-TRICHLOROETHANE
1,1,2,2-TETRACHLOROETHANE
1,2-DIBROMOETHANE
1,2-DICHLOROETHANE
1,2-DICHLOROPROPANE
1,2,3-TRICHLOROPROPANE
1,3-BUTAOIENE, 2-CHLORO
1,3-DICHLOROPROPANE
1,4-D10XANE
2-BOTANOME 
2-CHLOROETHYLVINYL ETHER
2-HEXANOWE
2-PROPAMONE (ACETONE)
2-PROPEN-1-OL
2-PROPENAL (ACROLEIN)
2-PROPENEMITRILE, 2-HETHYL-
3-CHLOROPROPENE
4-KETHYL-2-PENTANONE
AOSORBABLE ORGANIC HALIDES 
-------
                                                         TABLE C-16

                                        LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
                                                                                          109
                                   SAMPLE POINT CATEGORY HAME=FINAL  EFFLUENT SUBCATEGORY=DK
                                                         (continued)
CHEMICAL NAME
          NO. OF
NO. OF     MILLS       NO. OF       NO.  OF,             MINIMUM            MAXIMUM
 MILLS  NON-DETECT  DATA POINTS  NON-DETECTS   UNITS   SYMBOL   MINIMUM   SYMBOL   MAXIMUM
COD
COLOR
                          3
                         18
KG/ADMT
KG/ADMT
5.53E+01
1.62E+02
9.34E+01
2.68E+02

-------
                                                        TABLE C-17

                                       LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
                                                                                                                          110
CHEHICAL NAME

2,3,7,8-TETRACHLORODIBENZO-P-DIOXIN
1,2,3.7,8-PEHTACHLORODIBENZO-P-DIOXIN
1,2,3,4,7,8-HEXACHLOROOIBENZO-P-DIOXIN
1,2,3,6,7,8-HEXACHLORODIBENZO-P-DIOXIN
1,2,3,7,8,9-HEXACHLORODIBENZO-P-DIOXIN
1,2.3,4,6,7.8-HEPTACHLORODIBENZO-P-DIOXI
OCTACHLORODIBENZO-P-DIOXIN
2,3,7,8-TETRACHLORODtBENZOFURAN
1,2,3,7,8-PENTACHLORODIBENZOFURAN
2,3,4,7,8-PENTACHLOROOIBENZOFURAN
1,2,3,4,7,8-HEXACKLORODIBENZOFURAN
1,2,3,6,7,8-HEXACHLOROOIBENZOFURAN
1,2,3,7,8,9-HEXACHLORODIBENZOFURAN
2,3,4,6,7,8-HEXACKLOROOIBENZOFURAN
1,2,3,4,6,7,8-HEPTACHLOROOIBENZOFURAN
1,2,3,4,7,8.9-HEPTACHLORODIBENZOFURAH
OCTACHLORODIBENZOFURAN
4-CHLOROPHENOt.
4-CHLOROCATECHOL
4-CHLOROGUAIACOL
5-CHIOROVANILL1N
6-CHlOROVAHILLlN
2-CHLOROSYRIHGALDEHYDE
2,4-DICHLOROPHENOL
2,6-DICHLOROPHENOL
3,4-DICHLOROCATECHOL
3,6-DICHLOROCATECHOL
4,5-DICHLOROCATECHOL
3,4-DICHLOROGUAIACOL
4,5-DlCHLOROGUAIACOL
4,6-DICHLOROGUAIACOL
5,6-DICHLOROVANILLIN
2,6-D1CHIOROSYRINGALDEHYDE
2,4,5-TRICHLOROPHENOL
2,4,6-TRICHLOROPHENOL
3,4,5-TRICHLOROCATECHOL
3,4,6-TRICHLOROCATECHOL
3,4,5-TRICHLOROGUAIACOL
3,4,6-TRICHLOROGUAIACOL
4,5,6-TRICHLOROGUAIACOL
TRICHLOROSYR1NGQL
2,3,4,6-TETRACHLOROPHENOL
TETRACHLOROCATECHOL
TETRACHLOROGUAIACOL
PEHTACHLOROPHENOL
ACRYLOHITRILE
BENZENE
BROHOOICHLOROMETHANE
BROHOHETHANE
CARBON DISULFIDE
CHLORCACETONITRILE
CHIOR08ENZEME
CHLOROETHABE
CHLOROFORM
POll
NO.
JI UAItUUKY NAM
NO. OF
OF MILLS
b=MNAL tl-t-L
NO. OF
JtNl SUBUf
NO.. OF
UI:liUKY"U5 	
MINIMUM
MILLS NON-DETECT DATA POINTS NON-DETECTS UNITS SYMBOL
•
•
t
t








































.









1
1
1
1
1
0
0
0
1
1
1
1
1
1
1
1
1
0
0
1
0
1
1
1
1
1
1
1
I 1
1
1
1
1
I
I 0
1 1
1 1
1 1
1
1
1
1
1
1 1
1 1
1 1
1 1
1 1
1 1
1 0
1 1
1 1
1 1
1 0
18
2
2
2
2
2
2
18
2
2
2
2
2
2
2
2
2
18
18
17
18
18
17
18
18
16
16
16
18
18
16
18
18
18
18
16
16
18
18
17
18
18
15
18
18
18
18
1,8
18
18
18
18
18
18
18
2
2
2
2
1
1
4
2
2
2
2
2
2
2
2
2
15
16
17
17
18
17
18
18
16
16
16
18
18
16
18
18
18
14
16
16
18
18
17
18
18
15
18
18
18
18
18
18
17
18
18
18
0
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADNT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
i
MAXIMUM
MINIMUM SYMBOL
8.
1.
99E-10
17E-08
1.17E-08
1.
1.
1.
2.
2.
.
.
.
17E-08
17E-08
17E-08
35E-08
01E-09
17E-08
17E-08
.17E-08
.17E-08
,
' .
1.
1.
2.
1.
2.
1.
2.
2.
2.
2.
2.
4.
4.
4.
2.
2.
4.
4.
4.
2.
4.
9.
9.
2.
2.
2.
17E-08
17E-08
17E-08
17E-08
35E-08
02E-04
38E-04
02E-04
04E-04
32E-04
32E-04
04E-04
04E-04
77E-04
77E-04
77E-04
32E-04
32E-04
77E-04
64E-04
64E-04
32E-04
77E-04
54E-04
54E-04
32E-04
32E-04
04E-04
2.32E-04
2.32E-04
9.54E-04
4.09E-04
4.09E-04
4.09E-03
8.17E-04
8.17E-04
4.09E-03
ND
ND
ND
ND
ND



ND
ND
ND
ND
ND
ND
ND
ND
ND

>
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
8.17E-04
8.17E-04
8.17E-04
4.09E-03
ND
ND
ND
2.45E-03
MAXIMUM
2.76E-09
1 .33E-08
1.33E-08
1.33E-08
1 .33E-08
2.51E-08
2.01E-07
1.22E-08
1.33E-08
1.33E-08
1.33E-08
1 .33E-08
1 .33E-08
1.33E-08
1.33E-08
1 .33E-08
2.76E-08
5.42E-04
1.08E-03
3.22E-04
7.37E-04
6.45E-04
6.45E-04
6.45E-04
6.45E-04
6.45E-04
6.45E-04
6.45E-04
6.45E-04
6.45E-04
6.45E-04
.29E-03
.29E-03
6.45E-04
.68E-03
.29E-03
.29E-03
6.45E-04
6.45E-04
6.4SE-04
6.45E-04
6.45E-04
1.29E-03
1.29E-03
1.29E-03
2.18E-02
4.36E-03
4.36E-03
2.18E-02
2.87E-03
4.36E-03
4.36E-03
2.18E-02
1.09E-01

-------
                 TABLE C-17
                                                                                     111
LONG-TERM STUDY AND SHORT-TERM STUDY LOADINGS
	 	 . 	 	 	 SAMPLE POINT CATEGORY NAMt=HNAL t
(continued)
NO. OF
NO. OF MILLS NO. OF
1-l-LUtNI SU

NO. OF
CHEMICAL NAME MILLS NON-DETECT DATA POINTS NON-DETECTS
CHLOROMETHANE
CIS-1 ,3-DICHLOROPROPENE
CROTONALDEHYDE
DIBROMOCHLOROMETHANE
DIBROMOMETHANE
DI ETHYL ETHER
ETHYL CYANIDE
ETHYL METHACRYLATE
ETHYLBEN2ENE
IODOMETHANE
ISOBUTYL ALCOHOL
M-XYLENE
METHYL METHACRYLATE
METHYLENE CHLORIDE
0+P XYLENE
TETRACHLOROETHENE
TETRACHLOROMETHANE
1 18
















TOLUENE 1
TRANS-1,2-DICHLOROETHENE 1
TRANS-1.3-DICHLOROPROPENE 1
TRANS-1.4-DICHLORO-2-BUTENE 1
TRIBROMOMETHANE 1
18
18
18
18
18
18
18
18
18
18
18
18
15
18
18
18
) 18
18
18
18
18
TRICHLOROETHENE 1 1 18
VINYL ACETATE 1 1 18
VINYL CHLORIDE 1 1 18
,1-DICHLOROETHANE 1 1 18
,1-DICHLOROETHENE 1 1 18
,1,1-TRICHLOROETHANE 1 1 18
,1,1,2-TETRACHLOROETHANE 11 18
,1,2-TRICHLOROETHANE 1 1 17
,1,2.2-TETRACHLOROETHANE 1 1 18
,2-DIBROMOETHANE 1 1 18
1,2-DICHLOROETHANE 1 1 18
1,2-DICHLOROPROPANE 1 1 18
1,2,3-TRICHLOROPROPANE 1 1 18
1,3- BUTADIENE. 2-CHLORO 1 1 18
1,3-DICHLOROPROPANE 11 18
1,4-DIOXANE 1 1 15
2-BUTANONE (NEK) 1 1 18
2-CHLOROETHYLVINYL ETHER 11 18
2-HEXANONE 1 1 18
2-PROPANONE (ACETONE) 1 0 18
2-PROPEN-1-OL 1 18
2-PROPENAL (ACROLEIN) 1 17
2-PROPENENITRILE, 2-METHYL- 1 18
3-CHLOROPROPENE 1 18
4-METHYL-2-PENTANONE 1 18
ADSORBABLE ORGANIC HALIDES (AOX) 1 0 17
COLOR 1 0 18
18
18
18
18
18
18
18
18
18
18
18
18
18
15
18
18
18
16
18
18
18
18
18
18
18
18
18
18
18
17
18
18
18
18
18
18
18
15
18
18
18
9
18
17
18
18
18
0
0
BUAIttiUKT


UNITS
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADMT
KG/ADHT
=us 	

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
>




MINIMUM
4.09E-03
8.17E-04
4.09E-03
8.17E-04
8.17E-04
4.09E-03
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
1.87E-03
8.17E-04
8.17E-04
4.09E-03
8.17E-04
8.17E-04
4.09E-03
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
8.17E-04
4.09E-03
8.17E-04
4.09E-03
9.36E-03
8.17E-04
4.09E-03
8.17E-04
8.17E-04
4.09E-03
2.50E-01
4.13E+01


MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND'
ND
ND
ND
ND
>




MAXIMUM
2.18E-02
4.36E-03
2.18E-02
4.36E-03
4.36E-03
2.18E-02
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
2.32E-03
4.36E-03
4.36E-03
2.18E-02
4.36E-03
4.36E-03
2.18E-02
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
4.36E-03
5.09E-03
2.51E-02
4.36E-03
2.18E-02
1.10E-01
4.36E-03
2.58E-02
4.36E-03
4.36E-03
2.18E-02
1 .79E+00
1.92E+02

-------
                                                            TABLE C-18
                                                                                                                              112
                                        LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS

                               SAMPLE  POINT
CHEMICAL MAKE

2,3,7,8-TETRACHLORCOIBENZO-P-DIOXIN
1,2,3,7,8-PENTACHLOROOIBENZO-P-DIOXIN
1,2,3,4,7,8-HEXACHLORODlBENZO-P-DIOXIN
1,2,3,6,7,8-HEXACHLORODIBEHZO-P-DIOXIN
1,2,3,7,8,9-HEXACHLORCOIBENZO-P-DIOXIN
1,2,3,4,6,7,8-HEPTACHLORODIBENZO-P-DIOXI
OCTACHLORODIBEHZO-P-DIOXIN
2,3,7,8-TETRACHLORCOIBENZOFURAH
1,2,3,7,8-PENTACHLOROOIBENZOFURAN
2,3,4,7,8-PENTACHLOROOIBENZOFURAN
1,2,3,4,7,8-HEXACHLORODIBENZOFURAN
1,2,3,6,7,8-HEXACHLOROOIBENZOFURAN
1,2,3,7,8,9-HEXACHLORODIBENZOFURAN
2,3,4,6,7,8-HEXACHLOROOIBENZOFURAN
1,2,3,4,6,7,8-HEPTACHLOROOIBENZOFURAH
1,2,3,4,7,8,9-HEPTACHLOROOIBENZOFURAN
OCTACHiOROD1BEHZOFURAN
4-CHLOROPHEHOL
4-CHlOROCATECHOt
4-CHLOROGUAIACOL
5-CHLOROVAHILLIH
6-CHLOROVANILLIM
2-CHtOROSYRIHGALDEHYDE
2,4-DICHLOROPHEHOL
2,6-OlCHLOROPHENOL
3,4-DlCHLOROCATECHOL
3,6-01CHLOROCATECKOL
4,5-DICHLOROCATECHOL
3,4-OICHLOROGUAIACOL
4,5-DICHlOROGUAIACOL
4,6-DICHLOROGUAIACOL
5,6-DICHLOROVANILLIN
2,6-DICHLOROSYRINGALDEHYDE
2,4,5-TRlCHLOROPHENOL
2,4,6-TRICHLOROPHENOL
3,4,5-TRICHLOROCATECHOL
3,4,6-TRlCHLOROCATECHOL
3,4,5-TRlCHLOROGUAIACOl
3,4,6-TRlCHLOROGUAIACOl
4,5,6-TRICHLOROGUAIACOL
TRICHLOROSYRIMGOL
2,3,4,6-TETRACHLOROPHEHOL
TETRACHLOROCATECHOL
TETRACHLOROGUAIACOL
PENTACHLOROPHEHOt
ACRYLOHITR1LE
BEH2EHE
SROHOOICHLOROHETHANE
BROHOHETHANE
CARBON DISULFIDE
CHLOfiCACETOMITRILE
CHLOROBENZENE
CHLOR0ETHANE
CHLOROFORM
uueiiu
NO. OF
MILLS
14
13
13
13
13
13
11

13
13
13
13
13
13
13
13
13
12
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
7
12
12
12
12
12
11
12
12
12
«T NKnC=WM:>l
NO. OF
MILLS
NON-DETECT
5
13
12
12
12
2
0

2
11
10
12
13
13
12
10
13
11
3
6
6
6
2
5
6
7
5
5
5
5
2 •
6
7
5
7
5
5
7
4
6
5
5
7
7
6
7
12
11
12
12
1
11
12
12
3
CWA 1 CK 1 KCH 1 n
NO. OF
DATA POINTS
79
22
22
22
22
22
17

78
22
22
22
22
22
22
22
22
21
73
73
73
73
73
73
73
73
73
73
7?
73
73
73
73
73
73
73
73
73
73
73
73
73
73
73
73
73
45
45
45
45
44
44
45
45
43
CNI &L.UUUC !>U
NO. OF
NON-OETECTS
59
22
21
20
20
8
0

15
19
19
21
22
22
21
18
22
20
59
71
60
72
31
70
63
73
69
69
57
60
33
72
73
71
73
59
59
73
53
72
60
63
73
73
70
73
45
44
45
45
23
44
45
45
11
IBWtlCbU

UNITS
NG/KG
NG/KG
NG/KG
NG/KG
NG/KG
NG/KG
NG/KG

NG/KG
NG/KG
NG/KG
NG/KG
NG/KG
NG/KG
NG/KG
NG/KG
NG/KG
NG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND


ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
0.76
1.00
2.00
1.30
1.80
5.00
21.00

0.57
1.08
1.09
1.85
1.10
2.70
1.70
2.09
2.88
5.78
84.00
84.00
84.00
169.00
169.00
169.00
169.00
169.00
169.00
169.00
169.00
169.00
169.00
169.00
338.00
338.00
169.00
169.00
338.00
338.00
169.00
169.00
169.00
169.00
169.00
338.00
90.00
338.00
25.00
5.00
5.00
5.00
21.00
10.00
5.00
5.00
5.00

MAXIMUM
SYMBOL

ND










ND
ND


ND








ND






ND

ND


ND




ND
ND

ND
ND

ND
N'D

ND
ND
ND



MAXIMUM
67.00
22.00
7.00
18.00
14.00
160.00
1900.00
n i' <
160.00
27.00
11.00
1.80
25.00
25.00
6.00
35.00
25.00
150.00
443.00
450.00
466.00
290.55
4394.10
. 939.70
1610.00
460.00
4202.50
730.00
18000.00
1020.00
10400.00
653.10
2400.00
811.40
460.00
2980.00
3101.50
2400.00
7900.00
380.00
1580.00
1855.10
460.00
2400.00
1200.00
2400.00
312.50
600.11
62.50
312.50
925.00
62.50
62.50
312.50
24552.00

-------
                                                        TABLE C-18
                                                                                                                           173
CHEMICAL NAME
                                    LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS

                           SAMPLE POINT CATEGORY NAME=UASTEWATER TREATMENT SLUDGE SUBCATEGORY=BPK
                                                        (continued)
                                            NO. OF
                                  NO. OF     MILLS       NO. OF       NO. OF           MINIMUM
                                   MILLS  NON-DETECT  DATA POINTS  NON-DETECTS  UNITS  SYMBOL
CHLOROMETHANE    .                   12        12
CIS-1.3-DICHLOROPROPENE             11        11
CROTONALDEHYDE                      11        11
DIBROMOCHLOROMETHANE                12        12
DIBROMOMETHANE                      11        11
DIETHYL ETHER                       12        12
ETHYL CYANIDE                       11         9
ETHYL METHACRYLATE                  11        11
ETHYLBENZENE                        12         8
IODOMETHANE                         11        11
ISOBUTYL ALCOHOL                    11        10
M-XYLENE                            11         9
METHYL METHACRYLATE                 11        11
METHYLENE CHLORIDE                  12         4
0+P XYLENE                          11         7
TETRACHLOROETHENE                   12        12
TETRACHLOROMETHANE                  12        10
TOLUENE                             12         5
TRANS-1,2-DICHLOROETHENE            12        12
TRANS-1,3-DICHLOROPROPENE           12        12
TRANS-1.4-DICHLORO-2-BUTENE*        11        11
TRIBROMOMETHANE                     12        12
TRICHLOROETHENE                     12        11
TRICHLOROFLUOROMETHANE               5         4
VINYL ACETATE                       11        10
VINYL CHLORIDE                      12        12
1,1-DICHLOROETHANE                  12        10
1,1-DICHLOROETHENE                  12        12
1,1,1-TRICHLOROETHANE               12        12
1,1,1,2-TETRACHLOROETHANE           11        11
1,1,2-TRICHLOROETHANE               11        10
1,1,2,2-TETRACHLOROETHANE           12        11
1,2-DIBROMOETHANE                   11        11
1,2-DICHLOROETHANE                  12        12
1.2-DICHLOROPROPANE                 12        12
1,2,3-TRICHLOROPROPANE              11        11
1,3-BUTADIENE, 2-CHLORO             11        11
1,3-DICHLOROPROPANE                 11        11
1,4-DIOXANE                         12        10
2-BUTANONE (MEK)                    12         3
2-CHLOROETHYLVINYL ETHER            12        12
2-HEXANONE                          12        10
2-PROPANONE (ACETONE)               12         2
2-PROPEN-1-OL                       11        11
2-PROPENAL (ACROLEIN)               12         9
2-PROPENENITRILE, 2-METHYL-         11        11
3-CHLOROPROPENE                     11        11
4-METHYL-2-PENTANONE                12        10
ADSORBABLE ORGANIC HALIDES  (AOX)     1         0
ACENAPHTHENE                         2         2
ACENAPHTHYLENE                       2         2
ACETOPHENONE                         2         2
ALPHA-NAPHTHYLAMINE                  2         2
45
44
44
45
44
44
44
44
45
44
44
44
44
34
44
45
45
45
45
45
44
45
45
 9
44
45
45
45
45
44
43
45
44
45
45
44
44
44
43
43
45
45
44
44
44
44
44
45
 1
 2
 2
 2
 2
45
44
44
45
44
44
42
44
38
44
43
40
44
16
39
45
42
34
45
45
44
45
44
 8
43
45
43
45
45
44
42
44
44
45
45
44
44
44
41
18
45
41
 9
44
41
44
44
43
 0
 2
 2
 2
 2
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
MG/KG
UG/KG
UG/KG
UG/KG
UG/KG
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND

IINIKUM
5.00
10.00
51.00
5.00
10.00
5.00
14.71
10.00
5.00
10.00
10.00
10.00
10.00
10.00
10.00
5.00
5.00
10.00
5.00
5.00
51.00
5.00
5.00
10.00
51.00
5.00
5.00
5.00
5.00
10.00
5.00
5.00
10.00
5.00
5.00
10.00
10.00
10.00
10.00
51.00
5.00
51.00
51.00
10.00
25.00
10.00
10.00
51.00
263.50
333.00
333.00
333.00
333.00
MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND

ND

ND


ND


ND

•
ND
ND
ND
ND



ND

ND
ND
ND


ND
ND
ND
ND
ND
ND


ND


ND

ND
ND


ND
ND
ND
ND

MAXIMUM
312.50
62.50
312.50
62.50
62.50
312.50
275.00
62.50
521.04
62.50
2114.00
12430.81
62.50
2991.00
5274.38
62.50
3563.44
597.16
62.50
62.50
312.50
62.50
640.00
46.87
586.00
62.50
328.11
62.50
62.50
62.50
810.48
2931.24
62.50
62.50
62.50
62.50
62.50
62.50
13063.00
484215.62
62.50
4342.35
775412.50
62.50
13992.00
62.50
62.50
408.41
263.50
333.00
333.00
333.00
333.00

-------
                                                            TABLE C-18
                                                                                                                                114
                                       LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
CHEMICAL KANE

ALPHA-PI COUNE
ALPHA-TERPINEOL
AH I LI HE
ANTHRACENE
ARAMITE
B-HAPHTHYLAH1HE
BEHZAHTHRONE
BEHZENETHIOL
8EHZ1DIHE
BEHZOFLUORAHTHENE
8EHZOFLUORAHTHENE
iEMZOIC ACID
8EHZYL ALCOHOL
8IPHEHYL
BIS (2-Cm.OROlSOPROPYL) ETHER
gIS(CHLOROHETHYL)ETHER(NR)
ttS(2-CHLOROETHOXY)METHANE
1IS(2-CHLOROETHYL)ETHER
8IS<2-ETHYLHEXYL)PHTHALATE
BUTYL BENZYL PHTHALATE
CARBAZOLE
CHRYSENE
DI-H-BUTYL AMINE
Dl-M-BUTYL PHTHALATE
DI-H-OCTYL PHTHALATE
DI8ENZO(A,H)AHTHRACENE
D18EHZOFURAH
DIBEMZOTHIOPHEHE
D1CM.ORODIFLUOROHETHANE (NR)
DIETHYL PHTHALATE
DIMETHYL PHTHALATE
DIKETHYL SULFOHE
DIPKEHYL ETHER
OIPHENYLAMINE
D1PHENYLOISULFIDE
ETKANOL
ETHYL HETHANESULFONATE
ETHYLENETHIOUREA
ETBYHYLESTRADIOL 3-HETHYL ETHER
FLUORAHTBEHE
FLUORENE
HEXACHLORO-1,3-BUTADIENE
BEXACHtOROBEHZEME
HEXACHtOROCYCLOPENTADIEHE
HEXACHLOROETHANE
HEXACHLOROPROPEHE
HEXAXOIC ACID
IN0ENO(1,2,3-CD)PYRENE
1SOPHORONE
1SOPROPANOL
'LE POINT CATEGORY NA(

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
HILLS
NON-DETECT
2
0
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
0
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1E=WASTEHATER TREATMENT SLUDGE SUHCAIkUOKT=bPK. 	
(continued)

NO. OF
DATA POINTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
NON -DETECTS
2
0
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
0
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2


UNITS
LIG/KG
UG/KG
LIG/KG
LIG/KG
LIG/KG
LIG/KG
LIG/KG
LIG/KG
UG/KG
LIG/KG
UG/KG
LIG/KG
LIG/KG
LIG/KG
LIG/KG
LIG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG

MINIMUM
SYMBOL
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
1667.00
51.00
333.00
333.00
1667.00
1667.00
1667.00
333.00
1667.00
333.00
333.00
333.00
667.00
333.00
1667.00
333.00
333.00
333.00
10.00
333.00
333.00
333.00
333.00
667.00
333.00
333.00
1824.43
333.00
667.00
333.00
333.00
10.00
333.00
333.00
333.00
333.00
333.00
667.00
10.00
667.00
667.00
667.00
333.00
333.00
333.00
333.00
333.00
333.00
667.00
333.00
667.00
333.00
10.00

MAXIMUM
SYMBOL
ND


ND
ND
ND,
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND

ND.
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
1667.00
3878.00
3596.00
333.00
1667.00
1667.00
1667.00
333.00
1667.00
333.00
333.00
333.00
667.00
333.00
1667.00
333.00
333.00
333.00
10.00
333.00
333.00
60560.00
333.00
667.00
333.00
333.00
34743.00
333.00
667.00
7521.00
333.00
10.00
333.00
333.00
333.00
333.00
333.00
667.00
10.00
667.00
667.00
667.00
333.00
333.00
333.00
333.00
333.00
333100
667.00
333.00
667100
333.00
10.00

-------
                    TABLE C-18




LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
                                                                                        115
	 SAMPLE POINT CATEGORY NAI>lb=WAS I bWA 1 tK IKtAIMtNl SLUUUt SUbUAl tljUKT=BKR. 	 	 	
(continued)


CHEMICAL NAME
ISOPROPYL ETHER
ISOSAFROLE
LONGIFOLENE
MALACHITE GREEN
METHAPYRILENE
METHYL METHANESULFONATE
N-BUTANOL
N-DECANE (N-C10)
N-DOCOSANE (N-C22)
N-DODECANE (N-C12)
N-EICOSANE (N-C20)
N-HEXACOSANE (N-C26)
N-HEXADECANE (N-C16)
N-NITROSODI-N-BUTYLAMINE
N-NITROSODI-N-PROPYLAMINE
N-NITROSODIETHYLAMINE
N -N I TROSODIMETH YLAM I HE
N-NITROSODIPHENYLAMINE
N-NI TROSOMETHYLETHYLAMI NE
N-NITROSOMETHYLPHENYLAMINE
N-NITROSOMORPHOLINE
N-NITROSOPIPERIDINE
N-OCTACOSANE (N-C28)
N-OCTADECANE (N-C18)
N-PROPANOL
N-TETRACOSANE (N-C24)
N-TETRADECANE (N-C14)
N-TRIACONTANE (N-C30)
N.N-DIMETHYLFORMAMIDE
NAPHTHALENE
NITROBENZENE
0-ANISIDINE
0-CRESOL
0-TOLUIDINE
P-CRESOL
P-CYMENE
P-DIMETHYLAMINOAZOBENZENE
PENTACHLOROBENZENE
PENTACHLOROETHANE
PENTACHLOROPHENOL
PENTAMETHYLBENZENE
PERYLENE
PHENACETIN
PHENANTHRENE
PHENOL
PHENOTHIAZINE
PRONAMIDE
PYRENE
PYRIDINE
SAFROLE
SQUALENE
STYRENE
T-BUTANOL

NQ. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON-DETECT
2
2
'2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
1
2
1
2
2
2
2
2
2
2
1
2
2
2
2
1
2
2
2
2
2
2
2
2
2
0
2
2

NO. OF
DATA POINTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
NON -DETECTS
2
2
2
2
2
2
2
2
2
2'
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
1
2
1
2
2
2
2
2
2
2
1
2
2
2
2
1
2
2
2
2
2
2
2
2
2
0
2
2


UNITS
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND


MINIMUM
10.00
333.00
1667.00
333.00
333.00
667.00
10.00
333.00
333.00
333.00
333.00
333.00
333.00
333.00
667.00
333.00
1667.00
667.00
333.00
3300.00
333.00
333.00
333.00
333.00
10.00
333.00
333.00
333.00
333.00
333.00
333.00
333.00
333.00
333.00
333.00
333.00
667.00
667.00
667.00
1667.00
333.00
333.00
333.00
333.00
333.00
1667,00
333.00
333.00
333.00
333.00
1378.00
333.00
10.00

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND

ND

ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND


MAXIMUM
10.00
333.00
1667.00
333.00
333.00
667.00
10.00
333.00
333.00
333.00
333.00
333.00
333.00
333.00
667.00
333.00
1667.00
667.00
333.00
3300.00
333.00
333.00
381.00
333.00
10.00
631.00
333.00
814.00
333.00
333.00
333.00
333.00
333.00
333.00
333.00
88940.00
667.00
667.00
667.00
1667.00
6537.00
333.00
333.00
333.00
333.00
1667.00
333.00
333.00
333.00
333.00
6984.00
333.00
10.00

-------
                                                            TABLE C-18
116
                                        LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
 CHEMICAL NAME

 THIANAPHTHENE
 THIOACETAHIDE
 THIOXAHTHONE
 TRIPHEHYLENE
 TRIPROPYtENEGLYCtX. METHYL ETHER
 1-HETHYLFLUORENE
 1-HETHYLPHEHAHTHRENE
 1-PHENYLHAPHTHAIENE
 1,2-01BRCMO-3-CHLOROPROPANE
 1,2-DICHLOROBEHZEHE
 1,H-DIPHEHYLHYDRAZINE
 1,2,3-TRICHLOROBENZENE
 1,2,3-TRIHETHOXYBENZENE
 1,2,3,4-DIEPOXYBUTANE
 1,2,4-TRICHLOROBENZEHE
 1,2,4,5-TETRACHLOROBENZENE
 1,3-BENZENEDIOL (RESORCINOL)
 1,3-DICHLORO-2-PROPAHOL
 1,3-DICHLOROSEHZENE
 1,3-DINITROBEHZENE
 1,3,5-TRlTHIANE
 1,4-D1CHLOR08£HZENE
 1,4-HAPHTHOQUlNONE
 1,5-HAPHTHALENEDIAHINE
 2*(HETHYLTHIO)BENZOTHtAZOL
 2-BROMOCHIOROBENZEHE
 2-SUTANOt
 2-CHlOROHAPHTHALENE
 2-CHlOROPHEHOL
 2-1SOPROPYLHAPHTHALENE
 2-H£THYL-4,6-DIHITROPHENOL
2-KETHYLBEMZOTHIOAZOLE
2-HETHYLHAPHTHALENE
2-HITROANILINE
2-H1TROPHENOL
2-PHENYLMAPHTHALENE
2,3-BENZOFLUORENE
2,3-DlCHLOROANlLINE
2,3-DICHLOROHlTROBEHZENE
2,3,4,6-TETRACHLOROPHEMOL
2,3,6-TRlCHLOROPHEHOL
2,4-DIAHIHOTOLUENE
2,4-DICHLOROPHEHOL
2,4-DIHETHYLPHENOL
2,4-DIHWOPHiNOt
2,4-DlHITROTOLUENE
2,4,5-TRICHLOROPHEKOL
2,4,5-TRlH6THYUNILINE
2,4,6-TRICHLOROPHENOL
2,6-Dl-TERT-BUm-P-BENZOQINONE
2,6-DICHLORO-4-NITROANILINE
2,6-DlCHLOROPHENOL
2,6-DIHITROTOtUENE
•ue ruim imeuuKT Nnne=WAaiewmcK iKCHincni OLUUUC ;iuoi,HicuuKi=DrK 	 	 	 	 .
(continued)

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
Z
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON-DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
DATA POINTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2

NO. OF
NON-DETECTS
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2


UNITS
UG/KG
UGi/KG
UG/KG
UGi/KG
UG/KG
UGi/KG
UGi/KG
UGi/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MINIMUM
333.00
667.00
667.00
333.00
3300.00
333.00
333.00
333.00
667.00
333.00
667.00
333.00
333.00
667.00
333.00
333.00
1667.00
333.00
333.00
667.00
1667.00
333.00
3300.00
3300.00
333.00
333.00
10.00
333.00
333.00
333.00
667.00
333.00
333.00
333.00
667.00
333.00
333.00
333.00
1667.00
667.00
333.00
3300.00
333.00
333.00
1667.00
333.00
333.00
667.00
333.00
3300.00
3300.00
333.00
333.00

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND .
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
333.00
667.00
667.00
333.00
3300.00
333.00
333.00
333.00
667.00
333.00
667.00
333.00
333.00
445.00
333.00
333.00
1667.00
333.00
333.00
667.00
1667.00
333! 00
3300.00
3300.00
333.00
333.00
10.00
333.00
333.00
333.00
667.00
333.00
333.00
333.00
667.00
333.00
333.00
333.00
1667.00
667.00
333.00
3300.00
333.00
333.00
1667.00
333.00
333.00
667.00
333.00
3300.00
3300.00
333.00
333.00

-------
                                                          TABLE C-18
                                                                                                                             117
                                      LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
CHEMICAL NAME

3-BROMOCHLOROBENZENE
3-CHLORONITR08ENZENE
3-METHYLCHOLANTHRENE
3-NITROANILINE
3,3'-D!CHLOROBENZIDINE
3,3'-DIMETHOXYBENZIDINE
3.5-DIBROMO-4-HYDROXYBENZONITR
3,6-DIMETHYLPHENANTHRENE
4-AMINOBIPHENYL
4-BROMOPHENYL PHENYL ETHER
4-CHLORO-2-NITROANILINE
4-CHLORO-3-METHYLPHENOL
4-CHLOROANILINE
4-CHLOROPHENYL PHENYL ETHER
4-NITROANILINE
4-NITROBIPHENYL
4-NITROPHENOL
4,4'-METHYLENEBIS(2-CHLOROANI)
4,5-METHYLENEPHENANTHRENE
5-CHLORO-O-TOLUIDINE
5-NITRO-O-TOLUIDINE
7,12-DIMETHYLBENZ(A)ANTHRACENE
ORGANIC HALIDES (OX)
ALDRIN
ALPHA-BHC
ALPHA-CHLORDANE
AZINPHOS-ETHYL
AZINPHOS-METHYL
BETA-BHC
CAPTAFOL
CAPTAN
CARBOPHENOTHION
CHLORBENZILATE
CHLORFENVINPHOS
CHLORPYRIPHOS
COUMAPHOS
CROTOXYPHOS
DELTA-BHC
DEMETON
DIALLATE
DIAZINON
DICHLOFENTHION
DICHLONE
DICHLORVOS
DICROTOPHOS
DIELDRIN
DIMETHOATE
DIOXATHION
DISULFOTON
ENDOSULFAN I
ENDOSULFAN II
ENDOSULFAN SULFATE
ENDRIN
'Lt KU1NI LAItUUKI NRnt=Wft5ltWAICK IKEAIHCNI SLUUbC SUBLRI CUUKI^BCR 	
(continued)

NO. OF
MILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
6
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON-DETECT
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
0
2
0
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2

NO. OF
DATA POINTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
39
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2

NO. OF
NON-DETECTS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
2
0
2
2
2
1
2
2
2
2
2
2
2
2
2
2
2
2
1
2
2
2
. 2
2
2
2
2
2
2
2


UNITS
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
MG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG

MINIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
. ND
ND
ND


MINIMUM
333.00
1667.00
333.00
667.00
1667.00
1667.00
1667.00
333.00
333.00
333.00
667.00
333.00
333.00
333.00
1667.00
333.00
1667.00
667.00
333.00
333.00
333.00
333.00
19.40
0.10
0.20
0.20
0.20
0.20
0.10
2.00
0.60
2.00
0.20
0.32
0.10
0.20
0.20
0.20
0.20
1.00
0.10
15.00
2.00
0.10
1.44
0.10
0.50
0.80
0.10
0.50
0.10
0.40
0.10

MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND

ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND


MAXIMUM
333.00
1667.00
333.00
667.00
1667.00
1667.00
1667.00
333.00
333.00
333.00
667.00
333.00
333.00
333.00
1667.00
333.00
1667.00
667.00
333.00
333.00
333.00
333.00
1103.00
0.20
0.36
2.50
30.00
90.00
0.30
5.00
1.00
5.00
4.00
75.00
15.00
30.00
90.00
0.25
30.00
2.00
15.00
15.00
2.50
15.00
60.00
0.30
15.00
30.00
15.00
0.50
0.30
0.50
0.30

-------
                    TABLE C-18




LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
                                                                                       118
---------------------------- SAMPLE POINI CAICUUKT N«nt=WA5 1 tW« 1 CK IKCHIMCNI &LUUUC 9UBIH 1 BUUK I -DCK 	 	 --
(continued)


CHEMICAL NAME
EHDRIH ALDEHYDE
EN0RIH KETONE
EPH CSANTOX)
ETHIOH
ETHOPROP
FAHPHUR
FEMSULFOTHION
FEHTHION
CAHHA-BHC (LIHDANE)
GAHHA-CHtOftDAHE
HEPTACHLOR
HEPTACHLOfi EPOXIDE
HEXAHETHYLPHOSPHORAMIDE
ISOORIN
KEPONE
LEPTOPHOS
HALATHION
HERPHOS
HETHOXYCHLOR
HEIHYL PARATHIOH
HETHYL TRITHIOH
HEV1NPHOS (PHOSORIN)
HIREX
HO«OCROTOPHOS
HALED (DIBROH)
M1TROFEH (TOK)
P,P'-DDD
P,P'-D0E
P,P<-DOT
PARATHION
PCS 1016
PCS 1221
PCS 1232
PCS 1242
PCS 1248
PCS 12S4
PCS 1260
PCH8
PHORATE
PHOSMCT
PHOSPHAHIDON
ROWEL
SUIFOTEP
SUtPROFOS
TEPP
TERBUFOS
TETRACHLORVIHPHOS
TOKUTHION
TOXAPHENE
TRICHLOROHATE
TRICHOftPHON
TRICRESYLPHOSPHATE
TR1FLURAL1N


NO. OF
HILLS
2
2
2
2
1
2
2
2
2
1
2
2
1
2
1
2
2
1
2
2
1
2
2
1
2
1
2
2
2
2
1
1
1
1
1
1
1
2
2
2
2
1
2
1
1
2
2
1
1
1
2
1
2

NO. OF
MILLS
NON-DETECT
2
2
2
2
1
2
2
2
2
1
2
2
1
2
1
2 '
2
1
2
2
1
2
2
1
2
1
2
2
2
2






1
2
2
2
2
1
2
1
1
2
2
1
1
1
2
1
2


NO. OF
DATA POINTS
2
2
2
2
1
2
2
2
2
1
2
2
1
2
1
2
2
1
2
2
1
2
2
1
2
1
2
2
2
2
1
1
1
1
1
1
1
2
2
2
2
1
2
1
1
2
2
1
1
1
2
1
2


NO. OF
NON-DETECTS
2
2
2
2
1
2
2
2
2
1
2
2
1
2
1
2
2
1
2
2
1
2
2
1
2
1
2
2
2
2
1
1
1
1
1
1
1
2
2
2
2
1
2
1
1
2
2
1
1
1
2
1
2



UNITS
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/ICG
UG/KG
UG/ICG
UG/KG
UG/KG
UG/ICG
UG/ICG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG
UG/KG


MINIMUM
SYMBOL
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND



MINIMUM
0.25
0.50
0.10
0.10
15.00
0.32
1.00
0.10
0.20
0.20
0.20
0.20
2.50
0.30
2.00
0.10
0.10
15.00
0.50
0.10
15.00
0.10
0.50
1.00
0.32
0.20
0.50
0.50
0.20
0.20
2.00
2.00
2.00
2.00
2.00
2.00
2.00
0.20
0.10
0.20
1.44
15.00
0.10
15.00
0.10
0.10
0.56
15.00
10.00
15.00
1.00
0.40
0.50


MAXIMUM
SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

'

MAXIMUM
0.50
0.50
15.00
15.00
15.00
75.00
90.00
15.00
0.25
0.20
0.20
0.20
2.50
0.50
2.00
15.00
15.00
15.00
i.oo
15.00
15.00
15.00
0.50
1.00
30.00
0.20
0.50
0.50
0.40
15.00
2.00
2.00
2.00
2.00
2.00
2.00
2.00
0.20
15.00
30.00
90.00
15.00
9.00
15.00
0.10
15.00
75.00
15.00
10.00
15.00
30.00
0.40
0.50
li:'

-------
                    TABLE C-18
                                                                                       119
LONG-TERM STUDY AND SHORT-TERM STUDY CONCENTRATIONS
	 SHnKLt CU1NI LAItUUKT NAPlt=WAbltWAItK IKbAIMI
(continued)


CHEMICAL NAME
TRIMETHYLPHOSPHATE
2.4-D
2,4.5-T
2,4,5-TP (SILVEX)
ALUMINUM
ANTIMONY
ARSENIC
BARIUM
BERYLLIUM
BISMUTH
BORON
CADMIUM
CALCIUM
CERIUM
CHROMIUM
COBALT
COPPER
DYSPROSIUM
ERBIUM
EUROPIUM
GADOLINIUM
GALLIUM
GERMANIUM
GOLD
HAFNIUM
HOLMINUM
INDIUM
IODINE
IRIDIUM
IRON
LANTHANUM
LEAD
LITHIUM
LUTETIUM
MAGNESIUM
MANGANESE
MERCURY
MOLYBDENUM
NEODYMIUM
NICKEL
NIOBIUM
OSMIUM
PALLADIUM
PHOSPHORUS
PLATINUM
POTASSIUM
PRASEODYMIUM
RHENIUM
RHODIUM
RUTHENIUM
SAMARIUM
SCANDIUM
SELENIUM

NO. OF
MILLS
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
NO. OF
MILLS
NON -DETECT
1
2
2
2
0
2
2
0
2
2
1
1
0
2
0
1
0
2
2
2
2
2
2
2
2
2
2
2
2
0
2
2
2
2
0
0
2
2
2
1
2
2
2
1
2
2
2
2
2
2
2
2
2

NO. OF
DATA POINTS
1
2
2
2
2
2
2
2
2
6
2
2
2
6
2
2
2
6
6
6
6
6
6
6
6
6
6
6
6
2
6
2
6
6
2
2
2
2
6
2
6
6
6
4
6
6
6
6
6
6
6
6
2

NO. OF
NON-DETECTS
1
2
2
2
0
2
2
0
2
6
1
1
0
6
0
1
0
6
6
6
6
6
6
6
6
6
6
6
6
0
6
2
6
6
0
0
2
2
6
1
6
6
6
3
6
6
6
6
6
6
6
6
2
                                       UNITS

                                       UG/KG
                                       UG/KG
                                       UG/KG
                                       UG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       HG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
                                       MG/KG
MINIMUM
SYMBOL

  ND
  ND
  ND
  ND
  ND

  ND
  ND
  ND
  ND

  ND

  NO

  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND

  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
  ND
»rs. ------
MINIMUM
0.40
0.05
0.04
0.03
3.64
0.00
0.00
0.47
0.00

5.00
3.00
263.00

0.12
12.00
0.07












2.63

0.01


7.25
1.14
0.00
0.00

11.00












0.00
MAXIMUM
SYMBOL
NO
NO
ND
ND

ND
ND

ND
ND



ND



ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND


ND
ND
ND

ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND

MAXIMUM
0.40
1800.00
400.00
400.00
5850.00
3.00
1.70
262.00
1.00

0.01
0.00
95200.00

14.00
0.01
36.00












7640.00

25.00


2680.00
1020.00
0.50
5.00

0.08



1.10








1.50

-------
                    TABLE C-18

LONG-TERM STUDY AND  SHORT-TERM STUDY CONCENTRATIONS
                                                                                      120



CHEMICAL NAME
SILICON
SILVER
SODIUM
STRONTIUM
SULFUR
TANTALUM
TELLURIUM
TERBIUM
THALLIUM
THORIUM
THULIUM
TIM
TITANIUM
TUNGSTEN
URANIUM
VAKADIUM
YTTERBIUM
YTTRIUM
ZINC
ZIRCONIUM


(10. OF
HILLS
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
dAnri.c rujm u
MO. OF
MILLS
NON-DETECT
0
1
0
0
0
2
2
2
2
2
2
2
0
2
2
1
2
0
0
2
n I cuwn i nnris— w/»

NO. OF
DATA POINTS
2
2
2
2
2
6
6
6
2
6
6
2
2
6
6
2
6
2
2
6
d 1 bltn i ur\ i r\wn
(continued)

NO. OF
NON -DETECTS
0
1
0
0
0
6
6
6
2
6
6
2
0
6
6
1
6
0
0
6
                                    UNITS

                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                    MG/KG
                                             MINIMUM
                                             SYMBOL
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
r=BFK 	
MINIMUM
3.80
3.00
4.30
0.80
14.80



0.00


0.00
0.11


18.00

0.01
0.16
MAXIMUM
SYMBOL





ND
NO
ND
ND
ND
ND
ND

ND
ND

ND



MAXIMUM
611.00
0.00
4250.00
224.00
2500.00



9.90


15.00
301.00


0.02

3.00
184.00
                      ND

-------