EPA 910/9-92-030
&EFK
             United States
             Environmental Protection
             Agency
              Region 10
              1200 Sixth Avenue
              Seattle WA 98101
Alaska
Idaho
Oregon
Washin
lington
             Management Division
              Program Planning & Evaluation
September 1992
Model Pollution Prevention
Plan for the Kraft Segment of
The Pulp and Paper Industry
REGION VI LIBRARY
U. S, ENVIRONMENTAL PROTE'
AGENCY
1445 ROSS AVENUE
DALLAS. TOS /520?

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                               SES°£NNViRONMENTALPROTtCT10N
                                AGENCY
                                1445 ROSS AVENUE
                                DALLAS, TEXAS  7520?
MODEL POLLUTION PREVENTION PLAN

                  FOR
       THE KRAFT SEGMENT OF
   THE PULP AND PAPER INDUSTRY
             September 1992
              Prepared for

           U.S. EPA Region 10
            1200 Sixth Avenue
         Seattle, Washington 98101
       EPA Contract No. 68-C8-0062
        Work Assignment No. 3-63
     SAIC Project No. 01-0832-03-1013
Science Applications International Corporation
     606 Columbia Street NW, Suite 300
        Olympia, Washington 98501
        Amendola Engineering, Inc.
             Lakewood, Ohio

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                            TABLE OF CONTENTS
1.0 PROJECT OVERVIEW	  1
      1.1 PURPOSE	  1
      1.2 ORGANIZATION OF THE REPORT	  1

2.0 INTRODUCTION TO POLLUTION PREVENTION	  3
      2.1 WHAT POLLUTION PREVENTION IS  	  3
      2.2 BENEFITS OF POLLUTION PREVENTION  	  5
      2.3 HOW POLLUTION PREVENTION IS ACCOMPLISHED 	  6
      2.4 POLLUTION PREVENTION FOR THE PULP AND PAPER INDUSTRY	  8

3.0 ORGANIZATIONAL AND MANAGEMENT FRAMEWORK	  9
      3.1 MANAGEMENT COMMITMENT 	  9
      3.2 POLLUTION PREVENTION TEAM	  9
            3.2.1  Pollution Prevention Awareness	  10
            3.2.2  Incentives and Barriers to Pollution Prevention 	  11
            3.2.3  Tracking	  12
      3.3 ENVIRONMENTAL FORWARD PLANNING PROCESS	  12
            3.3.1 Five Year Environmental Forward Plan  	  12
            3.3.2 Environmental Audits  	  14
      3.4 SOURCES OF ADDITIONAL INFORMATION 	  14

4.0 WOOD YARD OPERATIONS	  16
      4.1 OPTION NO. A-l:  RAW MATERIAL SELECTION	  17
      4.2 OPTION NO. A-2:  LOG FLUME RECYCLE	  18
      4.3 OPTION NO. A-3:  DRY DEBARKING	  19
      4.4 OPTION NO. A-4:  CHIP QUALITY CONTROLS	  20
      4.5 OPTION NO. A-5:  CHIP THICKNESS SCREENS  	  21
      4.6 OPTION NO. A-6:  STORM WATER CONTROL 	  22

5.0 PULPING AND CHEMICAL RECOVERY	  23
      5.1 OPTION NO. B-l: EXTENDED DELIGNIFICATION	  24
      5.2 OPTION NO. B-2: CLOSED SCREEN ROOM 	  26
      5.3 OPTION NO. B-3: LIQUOR SPILL PREVENTION AND CONTROL  	  27
      5.4  OPTION NO.  B-4:  IMPROVED BROWNSTOCK WASHING AND NEW
            BROWNSTOCK WASHING SYSTEMS	  28
      5.5 OPTION NO. B-5: USE OF DEFOAMERS AND PITCH DISPERSANTS	  29
      5.6 OPTION NO. B-6: STEAM STRIPPING OF FOUL CONDENSATES	  30
      5.7   OPTION  NO. B-7:   TRS CONTROLS  FOR HIGH  VOLUME. LOW
            CONCENTRATION  AND LOW  VOLUME. LOW  CONCENTRATION
            VENTS	  31
      5.8 OPTION NO. B-8:  CONVERSION OF RECOVERY BOILERS TO LOW ODOR
            DESIGN	  32
      5.9 OPTION NO. B-9: RECOVERY BOILER OPERATIONS FOR LOW ODOR
            EMISSIONS  	  33
      5.10 OPTION B-10: USE OF WEAK WASH FOR SCRUBBING FLUID IN AIR
            POLLUTION CONTROL SYSTEMS	  34
      5.11 OPTION NO. B-ll: LIME MUD DIVERSION BASIN  	  35
      5.12 OPTION NO. B-12: OXYGEN DELIGNIFICATION 	  36

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      5.13 OPTION NO. B-13: USE OF ANTHRAOUINONE IN PULPING PROCESS ...  37
      5.14 OPTION NO. B-14: BENEFICIAL REUSE OF LIME SLAKER GRITS AND
           GREEN LIQUOR DREGS.	  38
      5.15 OPTION NO. B-15: UTILIZATION OF POWER BOILER ASH.	  39

6.0 PULP BLEACHING	  40
      6.1 OPTION NO. C-l: CHEMICAL CONTROLS	  41
      6.2 OPTION NO. C-2: CHEMICAL MIXING	  42
      6.3 OPTION NO. C-3: SPLIT ADDITION OF CHLORINE	  45
      6.4 OPTION NO. C-4: CHLORINE DIOXIDE SUBSTITUTION	  46
      6.5 OPTION NO. C-5: ENHANCED EXTRACTION	  47
      6.6 OPTION NO. C-6: REPLACEMENT OF HYPOCHLORITES	  48
      6.7 OPTION NO. C-7: OZONE BLEACHING 	  49
      6.8 OPTION NO. C-8: COUNTER-CURRENT. JUMP STAGE WASHING	  50
      6.9 OPTION NO. C-9: BLEACH PLANT VENT CONTROLS 	  51

7.0 PULP DRYING AND PAPERMAKING	  52
      7.1  OPTION NO.  D-l:  FIBER  AND WHITE WATER  RECOVERY WITH
           SAVEALLS  	  53
      7.2 OPTION NO. D-2: REUSE OF VACUUM PUMP SEAL WATER  	  54
      7.3 OPTION NO. D-3: RECOVERY OF STEAM CONDENSATES	  55
      7.4 OPTION NO. D-4: CHEMICAL SUBSTITUTIONS	  56

8.0 WASTEWATER TREATMENT  	  57
      8.1 OPTION NO. E-l: IMPROVED SLUDGE DEWATERING	  58
      8.2 OPTION NO. E-2: SLUDGE UTILIZATION AS HOGGED FUEL	  59
      8.3 OPTION NO. E-3: ODOR CONTROL 	  60
      8.4 OPTION NO. E-4: REUSE OF TREATED EFFLUENT	  61

9.0 REFERENCES	  62
                                     11

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PROJECT OVERVIEW
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                                 1.0 PROJECT OVERVIEW
1.1  PURPOSE

In accordance with the Pollution Prevention Act of 1990, EPA is actively pursuing and encouraging
development of pollution prevention programs in U.S. industries.  The pulp  and paper industry
comprises one of the largest industries within Region 10, as well as the United States as a whole. The
pulp and paper industry was selected for this study because of its involvement in several major
environmental programs administered by EPA. This effort is viewed as an opportunity for Federal
and state governments to work in a partnership with industry to develop a plan that will benefit both
industry and the environment. This effort is being funded and conducted as a pilot project under
EPA's Industrial Pollution Prevention Project (IPS), one of EPA's "2% set-aside" pollution prevention
initiatives.

The purpose of this project is to provide EPA with a model pollution prevention plan for the pulp
and paper industry, focused specifically on the bleached kraft segment.  This plan is a compilation
of pollution prevention options that  could be implemented  at bleached  kraft mills to  achieve
reductions in waste generation or waste toxicity, and increase in-plant reuse and recycling of waste
materials. Several pollution prevention options are presented for each major process area within the
bleached kraft process. Not all of the options  described could be implemented  at any one mill, nor
would every option be advantageous at a given mill.  The application of a particular alternative must
be evaluated specifically for each mill. Feasibility, implementation costs, and engineering details will
vary widely from one facility to the next.

This model plan was developed after a thorough pollution prevention opportunity assessment and
implementation plan were developed for the Simpson Tacoma Kraft Mill in Tacoma, Washington.
The  results  of that effort are documented in the EPA publication entitled Pollution Prevention
Opportunity Assessment and Implementation Plan for  Simpson Tacoma Kraft Company, Tacoma,
Washington, August 1992 (EPA No. 910/9-92-027).
1.2 ORGANIZATION OF THE REPORT

The first three sections of this  report  provide general  background  information on pollution
prevention.   In the subsequent sections are presented numerous pollution prevention  options
applicable to various processes in kraft pulping,  bleaching, and paper making. Section 2.0 provides
an introduction to pollution prevention, describing how EPA defines pollution prevention and what
types of activities are included within that definition, what benefits pollution prevention provides,
and how pollution prevention is accomplished. Section 3.0 presents an organizational and management
framework for establishing a pollution prevention program, describing the importance of management


                                             1                     POLLUTION PREVENTION

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PROJECT OVERVIEW
commitment, the establishment of a pollution prevention team, and tracking the performance of
pollution prevention projects after implementation.

Section 4.0 addresses pollution prevention options for wood yard operations. Pollution prevention
alternatives applicable to pulping and chemical recovery operations are presented in Section 5.0. In
Section 6.0, pollution prevention options for pulp bleaching are covered. Alternatives in the pulp
drying and papermaking operations are provided in Section  7.0.  Section 8.0 addresses pollution
prevention activities  within  the area of wastewater  treatment.  The references used in the
development of this document are listed in Section 9.0.
                                                                   POLLUTION PREVENTION

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INTRODUCTION TO POLLUTION PREVENTION
                   2.0 INTRODUCTION TO POLLUTION PREVENTION
2.1  WHAT POLLUTION PREVENTION IS

The ultimate goal of pollution prevention is to reduce present and future threats to human health and
the environment. In EPA's Industrial Pollution Prevention Project (IPS), "pollution prevention" is
defined as "the use of processes, practices,  or products that reduce or eliminate the generation of
pollutants." This means that pollution prevention is to be thought of as the elimination of the sources
of pollution through one or more of the following:

                     • Product reformulation
                     • Process modification
                     • Improved housekeeping and management practices.
Where elimination of the source of pollution is not possible, some form of recycling, i.e., in-house,
closed-system measures which return (potential) pollutants for reuse within a production process, may
be pollution prevention.

Pollution prevention methods can be grouped into two main categories: source reduction and onsite
recycling. Source reduction is any activity that reduces or eliminates the generation of waste at the
source.  One example of source reduction is the use of oxygen delignification. This process results
in the removal of lignin prior to bleaching thus reducing the amount of bleaching chemical used and
the resultant chlorinated organic compounds formed. The lignin removed is returned to the recovery
cycle where the organics are burned for energy recovery and the inorganics recovered for reuse.
Another example is the substitution of chlorine dioxide for chlorine in pulp bleaching operations, and
control of the application of those chemicals.  This practice has resulted in significant reductions in
the amounts of chlorinated compounds, including dioxins, in the product and in process effluents.
Recycling includes the reuse or reclamation of used materials or by-products and returning them to
the process.  Within a pulp mill, for example, process chemicals contained in the  black liquor are
recovered and reused in the pulping process, and lignin solids  are burned for energy recovery.

There are many ways that source reduction can be implemented, including process changes, raw
material substitution, waste stream segregation, material handling improvements, and loss prevention
procedures. Furthermore, there are many ways that materials can be reused or reclaimed, either
within the manufacturing process or externally through commercial markets.   (The latter is not
considered pollution prevention.) Figure 1 depicts the categories of waste minimization techniques,
including off site recycling (Ref. A)*. EPA recommends the exploration of source reduction options
first, to minimize the generation of waste, and recycling options second, to maximize the reuse of
materials.
* See references at end of Section 3 (p. 14).                3                     POLLUTION PREVENTION

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INTRODUCTION TO POLLUTION PREVENTION
EPA makes a distinction between pollution control measures that are applied only after wastes are
generated and source reduction methods.  Offsite recycling, waste treatment, volume reduction
through concentration or compaction of wastes, dilution, and transferring contaminants from one
environmental medium to another are not considered pollution prevention methods by EPA.

In making this distinction, EPA is not discouraging the use of offsite recycling, such as the return of
used consumer paper as secondary fiber in pulp production.  The agency considers this an excellent
waste management activity but not pollution prevention. Collecting contaminants in one medium and
transferring them to another is likewise not, by itself, a pollution prevention measure. One example
of this is the collection of particulate emissions from combustion process exhaust, and subsequently
landfilling the filter cake.  Pollution prevention  is focused more directly on the reduction of
particulate generated or in reducing its toxicity.

Pollution prevention applies to all types of waste, both hazardous and non-hazardous, to discharges
to all environmental media:  air, surface water, soil, and ground water. Consideration of toxicity,
waste designation, and handling costs  is important  in the  evaluation  of  pollution prevention
alternatives as will be discussed later.
2.2 BENEFITS OF POLLUTION PREVENTION

The ultimate regional benefit of widespread implementation of pollution prevention will be the
maintenance of a safer, healthier environment in which to live. But there are also many benefits of
pollution prevention to each waste generator that chooses to implement waste reduction methods.
These may include:

       •      Reduced waste handling costs (including  storage, labor, pretreatment, packaging,
              transportation, and documentation)

       •      Reduced material procurement costs

       •      Reduced worker health and safety risk

       •      Reduced risk of civil and criminal liability

       •      Enhanced public image of the company

       •      Protection of local public health and the environment


The cost effectiveness of pollution prevention measures  applied within manufacturing processes,
equipment and vehicle maintenance shops, and other industrial activities has been demonstrated in
hundreds  of cases  over the past  several years.  A company with an aggressive, ongoing pollution
prevention program may acquire an important competitive advantage through the reduction of its
operating  costs. Moreover, liability risk can be significantly reduced through waste minimization and
* See references at end of Section 3 (p. 14).                5                     POLLUTION PREVENTION

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INTRODUCTION TO POLLUTION PREVENTION
material toxicity reduction measures.  Civil liability for the "cradle to grave" responsibility for
hazardous waste can be dramatically decreased when a company makes a commitment to waste
reduction strategies.  According to EPA, workers' compensation costs and risks are directly related
to the quantity of hazardous materials produced (Ref. B)*. Thus, minimization of hazardous materials
use and production will reduce worker health and safety risk and reduce workers' compensation
claims.

Finally, a pollution prevention program, coupled with public and employee education, can generate
goodwill in the community, enhance a facility's public image, and foster a higher level of concern for
the environment in individuals. In a company where management is committed to providing a safe
work environment and environmentally protective practices, employees are likely to feel more positive
about their employer.  Likewise, the community will  recognize and appreciate the efforts of a
company that improves its environmental performance by reducing wastes, reducing the toxicity of
materials, products,  and waste streams,  and in avoiding excessive or wasteful consumption of
materials and energy.  Thus, an effective pollution prevention program in concert with a program to
inform employees and the community can enhance a company's public image and improve consumer
marketing performance.
2.3 HOW POLLUTION PREVENTION IS ACCOMPLISHED

The implementation of pollution prevention in a given facility or portion of a facility requires first
an  assessment of  pollution prevention opportunities.   The assessment process is illustrated in
Figure 2 (Ref. A)*. In this assessment, what wastes are generated, how they are generated, and what
the waste streams consist of must be determined. Data on materials procurement costs, waste disposal
costs, and other waste management costs are gathered. Once this body of data is collected, waste
streams should be prioritized for further study, based on consideration of regulatory requirements,
waste management costs, waste quantity, hazardous characteristics of the waste, potential for pollution
prevention, and available budget. A detailed assessment of the highest priority waste streams can then
be  performed.   This analysis may involve further data gathering within the plant as well as the
identification of pollution prevention options. For each of the options identified, the feasibility of
implementation  must be evaluated for  its potential technical, environmental, and economic merit.
This includes engineering requirements, equipment and installation costs, operation and maintenance
costs, an estimate of waste reduction and other environmental benefits, timing, training requirements,
safety considerations, product quality,  availability, and many other considerations.  A cost-benefit
analysis for each option should  be performed.

The results of the pollution prevention assessment should be documented  in a report. The report
should include the considerations used  in evaluating feasibility of the options proposed and results
of the feasibility analysis. In addition,  the report  may include a discussion of possible performance
measures for evaluating the project after implementation, and a qualitative  evaluation of indirect or
intangible costs  and benefits associated with the identified alternatives.
 * See references at end of Section 3 (p. 14).                 6                    POLLUTION PREVENTION

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         The recognized need to minimize waste
            PLANNING AND ORGANIZATION
         Get management commitment
         Set overall assessment program goals
         Organize assessment program task force
 Assessment organization
and commitment to proceed
                ASSESSMENT PHASE
         Collect process and facility data
         Prioritize and select assessment targets
         Select people for assessment teams
         Review data and inspect site
         Generate options
         Screen and select options for further study
    Select new
assessment targets
  and reevaluate
 previous options
      Assessment report of
        selected options
            FEASIBILITY ANALYSIS PHASE
      •  Technical evaluation
      •  Economic evaluation
      •  Select options for implementation
   ReEvaluate
     Rnal report, including
     recommended options  y
                 IMPLEMENTATION
         Justify projects and obtain funding
         Installation (equipment)
         Implementation (procedure)
         Evaluate performance
         Publicize Results - internally and externally
Repeat the process
               Successfully implemented
              pollution prevention projects
                        Rgure 2

THE POLLUTION PREVENTION ASSESSMENT PROCEDURE

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INTRODUCTION TO POLLUTION PREVENTION
A selection of options to be  implemented  becomes the basis for the  next step, developing an
implementation plan.  The  plan needs to describe which pollution prevention projects will be
conducted, identify key  roles and responsibilities,  and establish a schedule for implementation.
Implementation will require procurement of funding, planning, design,  materials procurement,
construction  or installation, operator  training,  and possibly changes in company policies and
procedures.

After a project has been  implemented, an evaluation of its effectiveness should be conducted and
compared to the anticipated economic, environmental, and technical parameters evaluated during the
assessment  process. Modifications may be required  for projects where expectations have not been
met. More important, this post-audit information can enhance the evaluation and implementation
of subsequent pollution prevention projects.

Due to the dynamics of technological progress, regulatory development, our increasing knowledge of
particular compounds' effects on the environment and human health, and the demands of competitive
enterprise,  pollution prevention needs to be an ongoing activity at any facility. Implementation of
a one-time pollution prevention project will not ensure continuing advantages over time.  Thus, the
establishment of an ongoing pollution prevention program is the key to continued appreciation of the
benefits of waste reduction practices. Establishment of such a program is the subject of Section 3.0.
2.4 POLLUTION PREVENTION FOR THE PULP AND PAPER INDUSTRY

In this report, particular emphasis has been given to source reduction alternatives in the major process
areas of kraft pulping. A few options are presented that are not pollution prevention according to
the strict EPA definition, but that are worthwhile offsite recycling or waste management alternatives.
For each option represented, a description of the technology or method is provided with a general
range of costs,  a statement regarding its  applicability, the environmental benefits,  and useful
reference articles. The intent of this guide is to assist during the assessment process and provide a
starting point for the evaluation of alternatives that may be applicable within a particular pulp mill.
Further study involving an engineering analysis, refined cost estimates, and calculation of anticipated
environmental benefits will be necessary in most cases to determine whether a particular alternative
will  provide  the desired benefits at a particular facility.  Unique aspects of individual  pulp plants
must be considered for the  opportunities and hindrances they bring to source reduction/pollution
prevention for that facility.  Age of plant, layout, power costs, etc., all become factors  unique to a
particular plant and must be considered when reviewing options.
 * See references at end of Section 3 (p. 14).                 8                     POLLUTION PREVENTION

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ORGANIZATIONAL AND MANAGEMENT FRAMEWORK
              3.0 ORGANIZATIONAL AND MANAGEMENT FRAMEWORK
Experience in various industries over the last 10 years has shown that there are four keys to successful
implementation of a pollution prevention program. First is the commitment by management to make
pollution prevention a priority. Second is the involvement of personnel at many levels and from all
of the relevant components of the manufacturing process in an organization specifically created to
establish an ongoing pollution prevention effort. Third is the identification of incentives and barriers
to pollution prevention within the plant, company, and corporation. Fourth is the establishment of
an effective planning tool that can incorporate changes in environmental regulations, market climate,
and corporate reorganizations.
3.1  MANAGEMENT COMMITMENT

In a production-oriented corporate culture, if workers are expected to incorporate waste minimization
practices into their daily efforts, they need to know that pollution prevention is an important goal of
the company, beginning at the top.  Workers will recognize this commitment in decisions made by
management, in new projects selected for implementation, in corporate policies, and in company
newsletters and training.

A corporate policy statement regarding pollution prevention can be broad and simple, such as the one
adopted by E.I. DuPont in 1980 (Ref. C)*: "to minimize the generation of waste to the extent that is
technically and economically feasible." Or, the policy could be more specific, such as a commitment
to:

       Establish an ongoing pollution prevention program to reduce wastes and discharges
       to all environmental media; initiate a program of employee awareness activities; form
       a committee to address specific pollution prevention challenges,  perform regular
       assessments of waste generating  processes and practices, and track discharges and
       emissions; develop an incentive program to foster environmentally protective attitudes
       and innovation; and to consider pollution prevention benefits in every capital project
       proposed for funding.
3.2 POLLUTION PREVENTION TEAM

The primary objective of a pollution prevention team is to define or establish a successful system
within the corporate framework that works to achieve the cost effective minimization of waste, and
includes, representation and support from all the vital components of the manufacturing process. It


* See references at end of Section 3 (p. 14).                9                     POLLUTION PREVENTION

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ORGANIZATIONAL AND MANAGEMENT FRAMEWORK
is critical, therefore, that personnel who understand the plant's processes, and that personnel who
control or influence financial decisions are resident on the team. In addition, a pollution prevention
manager or team leader should be designated and the roles, responsibility, and authorities of this
position must be clearly defined.

The most important functions of a pollution prevention team are to enhance awareness of pollution
prevention and to identify what needs to be done. The team is the primary arena for sharing ideas
regarding pollution prevention opportunities, and is responsible for gathering and sharing information
both inside and  outside the  mill.  Internal communication will include both the identification of
potential projects and sharing knowledge of anticipated costs and benefits. Communications external
to the mill are important for enhancing the public image of the company as a good environmental
player, and for demonstrating to other companies that pollution prevention is a viable strategy and
may provide a competitive advantage.

Listed below are possible functions of a pollution prevention team:

       •   Enhance awareness of pollution prevention
                     - Employee training
                     - In-house  communications
                     - External communications

       •   Identify pollution prevention goals, targets, obstacles, and projects
                     - Define objectives
                     - Identify obstacles to pollution prevention
                     - Review objectives with management
                     - Establish plans
                     - Procure resources and support

       •   Tracking
                     - Conduct audits
                     - Establish accounting system
                     - Summarize progress
                     - Recognize achievements
3.2.1   Pollution Prevention Awareness

Just as environmental awareness has been significantly raised over the past 20 years, so too the
concepts and importance of pollution prevention can become widely known. If a pulp mill is to reap
the maximum benefits from establishing a pollution prevention program, sharing information with
all of the mill employees is a key factor. This can be accomplished in a number of ways. Pollution


* See references at end of Section 3 (p. 14).                10                    POLLUTION PREVENTION

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ORGANIZATIONAL AND MANAGEMENT FRAMEWORK
prevention can be included in new employee  orientation.  The corporate  policies on pollution
prevention can be included in the employee handbook.  Job training can  incorporate pollution
prevention methods such as good housekeeping and preventive maintenance.

Pollution prevention should be made part of job performance evaluations for individual employees.
Pollution prevention objectives could be communicated through this program, and personnel rewarded
for achievement  of pollution prevention milestones and development  of  innovative  pollution
prevention approaches.

The employee newsletter could be used to publicize pollution prevention concepts and to share success
stories.  Articles describing past projects and ongoing efforts to reduce waste within the mill could
be featured. The annual report could likewise highlight the pollution prevention success stories at the
facility.

3.2.2   Incentives and Barriers to Pollution Prevention

Identifying  incentives and  barriers to pollution  prevention is  one of the early  steps  in the
establishment of a pollution prevention program.  In some cases, this phase precedes the statement of
management commitment and the formation of a pollution prevention task force. Once such a team
has been established, specific barriers can be identified and subsequently addressed, and incentives
to pollution prevention can be used to illustrate the viability of proposed waste reduction alternatives.

In general, there are four basic incentives to pollution prevention:

       •   Potential to reduce the real costs and risks of generating and managing wastes
       •   Established corporate policies, procedures, and waste reduction goals
       •   Improvement in a company's environmental position and public image
       •   Compliance with legal  requirements

Barriers to pollution prevention  may be present within a company or inherent in the regulations.
Typical barriers include:

       •   Attitudes about managing wastes
       •   Lack of upper management support for pollution prevention
       •   Shortage of capital
       •   Competing priorities
       •   Lack of technical personnel
       •   Lack of information
       •   Incomplete appreciation for the need to minimize waste
       •   Resistance to change
       •   Inflexible regulations that hinder innovation
       •   Lack of coordination between local, state, and federal agencies


* See references at end of Section 3 (p. 14).                11                     POLLUTION PREVENTION

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ORGANIZATIONAL AND MANAGEMENT FRAMEWORK
The  program or series of activities  undertaken by a pollution prevention team  can be tailored
specifically to address the barriers identified by the team within the facility.

3.2.3   Tracking

In order to measure progress and to help ensure the ongoing success of the pollution prevention
program, an accounting  system should be  established  to  audit and  track  pollution prevention
accomplishments.  This system is analogous to  a post-audit performed on a capital project after
implementation to compare projected gains in productivity  or cost reductions with actual gains or
costs.  In this way,  the company can accumulate  experience for better estimating the pollution
prevention benefits of future proposed projects.

Tracking can be accomplished in a variety of ways.  Initially, pollution prevention gains may be
measured using  the  data collections systems already in place, for  example, the Toxics Release
Inventory (TRI) data required for SARA Title III compliance. As time goes on, a tracking system that
provides more project-specific detailed information may be useful. Companies including DuPont,
3M, and Dow Chemical have instituted sophisticated monitoring of in-plant flows and discharges in
order to track progress in waste reduction and to  pinpoint processes and areas where further
improvement is needed.
3.3 ENVIRONMENTAL FORWARD PLANNING PROCESS

Many corporations have successfully integrated environmental control operations into existing capital
appropriation and budgeting processes and operating plans.  Others have not. The former are most
often operating in an anticipatory mode; the latter usually react to changing events and often find
themselves  facing  compliance  problems and unanticipated  capital expenses.   A model for
environmental forward planning has been used successfully by several companies, enabling them to
anticipate the activities and expenditures associated with environmental compliance and pollution
prevention initiatives.  This approach is summarized below.

3.3.1  Five Year Environmental Forward Plan

On an annual basis, the facility prepares a five year environmental forward plan that addresses each
element of the mill's environmental program. Figure 3 is an example outline for the forward plan.
Environmental projects are listed in  terms of those necessary to achieve and maintain compliance
(usually non-discretionary), those discretionary projects that would improve compliance status or
minimize potential for environmental releases (risk reduction), and discretionary projects that would
result in waste reduction.  The plan should be prepared and updated annually such that the results can
be considered as part  of the  corporate and mill capital appropriations  process.  Those priority
discretionary projects that are not funded are carried forward year-to-year until funded or dropped
from consideration.
* See references at end of Section 3 (p. 14).                12                    POLLUTION PREVENTION

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ORGANIZATIONAL AND MANAGEMENT FRAMEWORK
   I.      Executive Summary


   II.     Certifications

          Certifications are provided by mill managers that company environmental policies, applicable
          laws and regulations, and any applicable industry trade association policies and operation
          practices have been adhered to . Also, a certification is made that all appropriation requests
          for capital expenses have had  the  appropriate environmental review, including pollution
          prevention and waste minimization. Any exceptions to the certifications are noted.


   III.    Programs and Issues

          Each environmental regulatory program is addressed and all significant issues are reviewed
          in  terms of impact  on ongoing  operations,  including human  and financial resource
          implicaTions.

          A.     SARA Title III Emissions Reduction Program
          B.     Air Programs
          C.     Water Programs
          D.     Spill Prevention and Control (Oil, chemicals, process solutions)
          E.     Solid Waste/Hazardous Waste Programs
          F.     Superfund
          G.     Groundwater Protection Program
          H.     PCB Elimination
          I.     Asbestos Remediation
          J.     Enforcement Issues (fines, penalties, lawsuits)
          K.     Future Laws and Regulations
          L.     Community Concerns and Issues
          M.     Resource Issues


   IV.    Financial Implications Summary

          A five year expense projection by project is made. Capital expenses are distinguished from
          mill expense items.  The costs for the multi-year projects are distributed to proposed year of
          expenditure.


   V.     Exhibits

          A.     Capital Expense and Appropriation Projection
          B.     SARA Title III Emissions Summary (five year summary by pollutant)
          C.     Waste Disposal Quantity and Cost Projections
          D.     Prior Year Expenditures - Projected vs. Actual
          E.     Offsite Waste Disposal Site Evaluation
          F.     Current Year Environmental Project Descriptions (summary project descriptions with
                cost, pollution prevention and waste minimization benefits)
                                           Figure 3

 SAMPLE OUTLINE FOR ENVIRONMENTAL AND POLLUTION PREVENTION PLANNING

 * See reference, at end of Section 3 (p. 14).                13                     POLLUTION PREVENTION

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ORGANIZATIONAL AND MANAGEMENT FRAMEWORK
3.3.2 Environmental Audits

On a regular basis, such as every year or two, an internal or external environmental audit should be
conducted to assess multi-media environmental compliance status and review progress with respect
to implementation of environmental forward plan items. A response to the audit findings should be
prepared by the mill within 30 days from receipt of the final audit report.  Audit action items
requiring significant capital spending or long term study are included in the next annual update of
the five year environmental forward plan.

This approach provides an appropriate vehicle for implementing pollution prevention projects. This
sort of deliberate planning process that allows pollution prevention initiatives to be considered with
other production goals and proposed mill expenditures will enhance a company's ability to reap the
benefits of pollution prevention implementation.
3.4 SOURCES OF ADDITIONAL INFORMATION

Listed below are the sources of information referenced in the preceding discussion of pollution
prevention and some additional helpful references.  These will provide a general foundation for the
application of pollution prevention concepts to any type of facility. Articles relating specifically to
pollution  prevention in kraft  pulp mills, categorized by  major process, can be found in the
Bibliography for Pollution Prevention in the Kraft  Pulp and Paper Industry, produced during this
project.

A.     U.S.  Environmental  Protection Agency,  July 1988.   Waste Minimization  Opportunity
       Assessment Manual, EPA/625/7-88/003. Hazardous Waste Engineering Research Laboratory,
       Cincinnati, OH.

B.     U.S. Environmental Protection Agency, May 1992. Facility Pollution Prevention Guide,
       EPA/600/R-92/088.  Office of Research and Development, Washington, D.C.

C.     Hollod, Gregory J. and William B. Beck.  Implementing Waste Minimization Programs in
       Industry, in Hazardous Waste Minimization, Harry Freeman, Ed.  McGraw-Hill, 1990.

D.     Higgins, Thomas E.  Hazardous Waste Minimization Handbook.  Lewis Publishers, Inc.,
       Chelsea, MI, 1989.

E.     Tavlarides, Lawrence L.  Process Modifications for Industrial Pollution Source Reduction.
       Lewis Publishers, Inc., Chelsea, MI, 1985.
                                            14                    POLLUTION PREVENTION

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ORGANIZATIONAL AND MANAGEMENT FRAMEWORK
F.     Committee to Evaluate Mass Balance Information for Facilities Handling Toxic Substances.
       Tracking Toxic Substances at Industrial Facilities. National Academy Press, Washington,
       B.C., 1990.

G.     General  Electric  Corporate  Environmental Programs.   Financial Analysis  of Waste
       Alternatives.

H.     U.S. Environmental Protection Agency, December 1991. Total Cost Assessment: Accelerating
       Industrial Pollution Prevention through Innovative Project Financial Analysis with Applications
       to the Pulp and Paper Industry.
                                            15
POLLUTION PREVENTION

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WOODYARD OPERATIONS
                       4.0 WOOD YARD OPERATIONS
                 Covering  material  selection, log handling,  chip
                 preparation, and storm water control.
   OPTION NO.
      TECHNOLOGY
       A-l
       A-2
       A-3
       A-4
       A-5
       A-6
Raw Material Selection	17
Log Flume Recycle	18
Dry Debarking	19
Chip Quality Controls  	20
Chip Thickness Screens  	21
Storm Water Control	22
                                     16
                         POLLUTION PREVENTION OPTIONS

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WOODYARD OPERATIONS
              4.1  OPTION NO. A-l: RAW MATERIAL SELECTION
Description:
Purchase of wood fiber (round wood, chips, sawdust) that has not
been treated with wood preservatives, particularly chlorophenols.
Costs:
Not applicable.
Applicability:
Broad application to all mills that pulp wood fiber and bleach with
chlorine or chlorine derivatives.
Benefits:
Eliminate source of CDDs/CDFs and CDD/CDF precursors from
fiber  supply.    Reduced  formation  of  higher  chlorinated
CDDs/CDFs in bleaching operations.  Improved product and
effluent quality.
References:
1,2
                                       17
                          POLLUTION PREVENTION OPTIONS

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WOODYARD OPERATIONS
                  4.2  OPTION NO. A-2;  LOG FLUME RECYCLE
Description:
Log flume water used to convey logs from log piles to debarkers
and chippers is  recycled with minimal blowdown to  wastewater
treatment facilities.  Collected bark and fiber is burned in hogged
fuel boilers to recover energy values. Currently installed at many
kraft mills. An  alternate practice is to use treated wastewaters as
make-up for the log flumes.
Costs:
Typical costs may range from $100,000 to $500,000 depending
upon site-specific retrofit considerations.
Applicability:
Broad application to mills with log flumes.
Benefits:
Water  conservation.  Reduced discharge loadings of TSS and
BOD5 of up to 750 Ibs/day for 3 MOD recycle system.
References:
                                         18
                            POLLUTION PREVENTION OPTIONS

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WOODYARD OPERATIONS
                    4.3 OPTION NO. A-3t DRY DEBARKING
Description:
Use  of dry drum debarkers  vs.  hydraulic debarkers.   Wet
debarkers result in significant hydraulic and BOD/TSS loadings
to wastewater treatment. Most wet debarkers have been replaced
with dry debarking systems at kraft and sulfite mills.
Costs:
High Range  >  $5,000,000
Applicability:
Broad application to kraft and sulfite mills  where roundwood
comprises fiber supply.
Benefits:
Water  conservation  (2,000 - 3,000  gallons per ton  of wood
barked). Reduced raw waste discharge loadings of TSS and BOD5
(1-10 Ibs. BOD5 and 6-55 Ibs. TSS per ton of product).  Reduced
handling (dewatering) of bark prior to burning  in hogged fuel
boilers.
References:
6, 7, 15
                                        19
                           POLLUTION PREVENTION OPTIONS

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WOODYARD OPERATIONS
               4.4  OPTION NO. A-4; CHIP QUALITY CONTROLS
Description:
Maintain and operate chippers  to  produce  chips  of uniform
dimensions, with emphasis on chip thickness control.  Continued
operation and maintenance of chippers to produce quality chips.
Costs:
Low   « $100,000 capital cost.
Applicability:
Broad application to chipping operations captive to kraft mills and
chipping performed by contract chippers remote from kraft mills.
Benefits:
Improved yield, reduction in rejects and shive content.  Allows for
more uniform pulping resulting in lower bleach plant chemical
consumption and attendant formation of AOX and other chlorinated
compounds.
References:
                                         20
                            POLLUTION PREVENTION OPTIONS

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WOODYARD OPERATIONS
                4.5  OPTION NO. A-5t CHIP THICKNESS SCREENS
Description:
Chip  screening device designed to produce chips of uniform
thickness.  Promotes uniform kraft liquor impregnation,  higher
pulping rates, and lower rejects.
Costs:
$2,000,000  to  $4,000,000  for  new  installations,  higher  for
retrofits.
Applicability:
Broad application to chipping operations captive to kraft mills.
Benefits:
Improved yield, reduction in rejects and shive content. Allows for
more uniform pulping resulting in lower bleach plant chemical
consumption and attendant formation of AOX and other chlorinated
compounds. The industry reports that benefits associated with chip
thickness screens are difficult to quantify because relatively small,
but important benefits accrue across many process operations.
References:
3, 4, 5, 7
                                         21
                            POLLUTION PREVENTION OPTIONS

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WOODYARD OPERATIONS
               4.6  OPTION NO. A-6; STORM WATER CONTROL
Description:
Curbing, diking, and drainage collection for storm water from chip
piles and  chip  processing areas.   Storage  and treatment of
stormwater in end-of-pipe wastewater treatment facilities.
Costs:
Variable and site-specific
Applicability:
Broad application to chipping operations captive to kraft and sulfite
mills.
Benefits:
Reduced discharge loadings of TSS and BOD5.  Eliminates need
for separate stormwater permit.
                                        22
                           POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
                  5.0 PULPING AND CHEMICAL RECOVERY
          Covering  pulping,  screening  and deknotting,  brownstock washing,
          recovery boilers, power boilers, causticizing, oxygen delignification, and
          spill prevention and control.
   OPTION NO.
          TECHNOLOGY
        B-l
        B-2
        B-3
        B-4

        B-5
        B-6
        B-7

        B-8
        B-9
       B-10

       B-ll
       B-12
       B-13
       B-14
       B-15
Extended Delignification	24
Closed Screen Room	26
Liquor Spill Prevention and Control	27
Improved Brownstock Washing and New Brownstock
Washing Systems 	28
Use of Defoamers and Pitch Dispersants	29
Steam Stripping of Foul Condensates  	30
TRS Controls for High Volume, Low Concentration
and Low Volume, Low Concentration Vents	31
Conversion of Recovery Boilers to Low Odor Design .  . 32
Recovery Boiler  Operations for Low Odor Emissions .  . 33
Use of Weak Wash for Scrubbing Fluid in Air
Pollution Control Systems	34
Lime Mud Diversion Basin 	35
Oxygen Delignification	36
Use of Anthraquinone in Pulping Process	37
Beneficial Reuse of Lime Slaker Grits and
Green Liquor Dregs	38

Utilization of Power Boiler Ash 	39
                                      23
                          POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
             5.1  OPTION NO. B-l;  EXTENDED DELIGNIFICATION
Description:
Modification of existing continuous digesters or installation of new
batch or continuous digesters to produce brownstock pulp of lower
Kappa  number.   Extended delignification is accomplished by
subjecting the fiber to modified time-temperature-alkaline cycles,
usually with the same total alkali charge.  This is accomplished by
modifying continuous digesters to allow for addition of cooking
liquor at multiple points (MCC - modified continuous cooking or
EMCC - extended modified continuous cooking), or by conducting
several  liquor exchanges  during the pulping cycle  for batch
digesters (RDH - rapid displacement heating).
Costs:
Depending   upon  site-specific   factors  including  age   and
configuration of existing continuous digesters, continuous digesters
may be  retrofitted  for  MCC or  EMCC for $1,000,000 to
$4,000,000.  The incremental cost of MCC or EMCC  for new
continuous  digesters is generally not significant.   The cost of
installing a  new RDH batch  digester  system  may range from
$30,000,000 to 50,000,000, depending upon capacity and site-
specific factors.
Applicability:
MCC, EMCC, or similar systems can be retrofitted to continuous
digesters equipped with separate steaming vessels.  RDH pulping
usually cannot be retrofitted economically to existing batch digester
systems due to the configuration of existing digesters (direct
steaming vs. liquor recirculation)  and the extensive tank  farm
necessary for liquor exchanges.
                                         24
                           POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
Benefits:
References:
Accomplishes greater degree of delignification (Kappa < 19-24
vs.  28 - 32  for pine) with recoverable pulping chemicals  as
opposed to delignification with disposable bleach plant chemicals.
Improves energy efficiency by increased recovery of liquor solids.
Reduces  bleach  plant  chemical consumption  and  attendant
formation of AOX and other chlorinated compounds, roughly in
proportion to Kappa number reduction.  Results in less rejects and
thus improves pulp yield.

8, 9, 10, 11, 12,  13, 14
                                        25
                           POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
                 5.2 OPTION NO. B-2; CLOSED SCREEN ROOM
Description:
Install new or modify existing brownstock pulp screening and
deknotting systems such that black liquor is recovered and recycled
to recovery system.
Costs:
For new closed screening systems, the investment costs may be
$10,000,000 to $15,000,000, depending upon capacity.  Costs for
retrofitting existing screen rooms are variable and site-specific.
Applicability:
Applicable to virtually all kraft and sulfite mills.
Benefits:
Improved  efficiency of the recovery circuit due to increased
retention of  liquor solids.   Reduced demand  for  make-up
chemicals.  Reduced raw wastewater loadings of BOD5 and other
organic  chemicals associated with kraft pulping.  This is due to
elimination of spills and overflows.
References:
15
                                         26
                           POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
      5.3  OPTION NO. B-3;  LIQUOR SPILL PREVENTION AND CONTROL
Description:
Preventive maintenance programs to ensure proper operation of
pumps,  tanks, pipelines,  and other equipment items in liquor
service.  Engineered systems to collect and recover leaks, spills,
and diversions  of weak  and strong liquor from pulping  and
chemical recovery areas.  Systems include tank level alarms, curbs
and dikes, and storage tanks.  Surveillance systems consisting of
a written plan including such items as a  combination of sewer
conductivity monitoring and frequent regular inspection of pulping
and chemical recovery areas to detect and repair leaks and spills.
Spill response and emergency action plans  to recover spills.
Costs:
All kraft and sulfite mills have some level of black or red liquor
spill prevention and control.  Site-specific costs to implement the
full program as described above are highly variable and may range
from $200,000 to $1,000,000.
Applicability:
Applicable to virtually all kraft and sulfite mills.
Benefits:
Improved efficiency of the recovery  circuit  due to increased
retention  of liquor solids.   Reduced  demand  for  make-up
chemicals. Reduced raw wastewater loadings of BOD5 and other
organic chemicals associated with pulping by up to 1/3.  Reduced
fugitive emissions of odor-causing TRS compounds from spills of
weak and strong black liquor and reduced emissions of volatile
compounds  from spills of weak black liquor at kraft  mills.
Reduction of SO2 emissions and acid leaks at sulfite mills.
 References:
 6, 15, 17, 25
                                         27
                            POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
    5.4  OPTION NO. B-4: IMPROVED BROWNSTOCK WASHING AND NEW
                      BROWNSTOCK WASHING SYSTEMS
Description:
Addition  of an  additional washing stage  or  stages to  existing
washing lines; installation of replacement washing systems.
Costs:
The addition of a diffusion washer as an additional washing stage
may  cost in the range  of $4,000,000.  Replacement washing
systems including pulp presses, belt washers, compaction baffle
washers, or  diffusion  washers  may  cost  $15,000,000  to
$20,000,000, depending upon capacity and retrofit considerations.
Applicability:
Generally applicable to bleached kraft mills with washing losses
greater than 15 kg Na2SO4 per metric ton of pulp.  Applicable to
sulfite mills as well to improve washing efficiency.
Benefits:
Improved  efficiency of the recovery  circuit due  to increased
retention of liquor solids.  Washing losses in the range of 5-10 kg
Na2SO4 per metric ton and  less are attainable with new washing
systems.  Reduced demand for make-up chemicals. Reduced raw
wastewater loadings of BOD5, AOX, and other chlorinated organic
chemicals associated with pulping and  bleaching. To the extent
washer  vents  are  low volume and  are  controlled,  reduced
emissions  of  odor-causing  TRS  compounds  and  volatile
compounds.
References:
9, 15, 18, 19, 20
                                        28
                           POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
     5.5 OPTION NO. B-5t  USE OF DEFOAMERS AND PITCH DISPERSANTS
Description:
Use of water-based or oil-based defoamers and pitch dispersants
free of CDD/CDF precursors.
Costs:
Costs are not significant  as  this  technology is a  chemical
substitution with limited or no equipment changes.  There may be
some increased  operating  costs  depending upon   costs  of
replacement chemicals.
Applicability:
Applicable to all unbleached and bleached kraft and sulfite mills.
Benefits:
In bleached kraft mills, reduced  formation of CDDs/CDFs and
other chlorinated  compounds  in the bleaching  process.   In
unbleached kraft mills, less deposition of potentially toxic materials
in product pulp and wastewater sludges and effluents.
References:
1, 2, 18, 21, 23, 24
                                         29
                           POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
      5.6 OPTION
                              )UL CONDI
Description:
Steam stripping of digester, evaporator and turpentine condensates
for removal of total reduced sulfur (TRS) and BOD5 (methanol,
acetone).  Steam-to-feed ratios  of 15  - 20% are necessary  to
achieve  efficient  BOD5 removal.    Stripper  overheads are
combusted in power boilers.  Stripper bottoms are reused for
brownstock washing.
Costs:
Depending upon capacity and retrofit considerations, investment
costs may range from $2,000,000 to $6,000,000.
Applicability:
Applicable to all unbleached and bleached kraft mills.
Benefits:
Reduced  atmospheric emissions  of TRS and volatile organic
compounds.  Reduced BOD5 raw wastewater loadings by up to
one-third at bleached kraft mills, higher at unbleached kraft mills.
Water conservation.  In bleached kraft mills, less formation of
CDDs/CDFs and compounds contributing to AOX.
References:
7, 25, 26, 27, 28, 29, 30, 31
                                        30
                           POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
       5.7 OPTION NO. B-7t  TRS CONTROLS FOR HIGH VOLUME. LOW
    CONCENTRATION AND LOW VOLUME. LOW CONCENTRATION VENTS
Description:
Collection and  combustion of vent streams from  brownstock
washers, foam tanks, black liquor filters, oxidation tanks and
storage tanks, and other TRS containing  streams that are not
usually collected in non-condensible gas (NCG) systems.
Costs:
Depending upon extent of vent collection, proximity to combustion
source and other site-specific factors, investment costs may range
from $500,000 to $2,000,000.
Applicability:
Applicable to all unbleached and bleached kraft mills.
Benefits:
Reduced atmospheric  emissions  of TRS  and volatile organic
compounds (VOCs).  Ten to twenty percent of total mill TRS
emissions are associated with these sources.
References:
7, 15, 25, 26
                                       31
                          POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
 5.8 OPTION NO. B-8;  CONVERSION OF RECOVERY BOILERS TO LOW ODOR
                                    DESIGN
Description:
Modification of old design recovery boiler to low odor design by
elimination of direct contact evaporator, modification of secondary
and tertiary combustion air systems,  installation  of a  new
economizer section.    Often completed  in  conjunction  with
moderate expansion  of  recovery boiler capacity.   Old  design
recovery boilers may account for 60% to 80% of total mill TRS
emissions.
Costs:
Highly variable and site-specific.  Depending upon initial boiler
capacity, expansion of capacity, and extent of rebuild, investment
costs may range from $20,000,000 to $40,000,000.
Applicability:
Applicable to all unbleached and bleached kraft  mills with old
design recovery boilers.  Many old design recovery boilers in the
United States have been converted to low odor design.
Benefits:
Reduced atmospheric emissions of TRS from recovery boiler by
more than 90%. Improved boiler efficiency.
References:
7, 15, 22, 25, 26
                                        32
                           POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
                 K). B-9; RECOVERY BOILER OPERATIONS
                                    EMISSIONS
Description:               Operation of recovery boilers within selected operating parameters
                          to minimize TRS emissions.  These parameters may include:

                             •  Operating within "critical" loading levels for liquor
                                solids

                             •  Maintaining secondary  and tertiary air at greater
                                than 35% of total combustion air supply

                             •  Maintaining excess oxygen between 2.0 and 2.5%

                             •  Maintaining liquor sulfidity as low as possible while
                                maintaining pulp quality

                             •  Maximizing  liquor solids within capability  of
                                available evaporator system

                             •  Minimizing the content of inerts in the liquor

                             •  Maximizing dispersion of the liquor spray by using
                                and maintaining appropriate liquor spray nozzles
Costs:
Variable and site-specific.   Many operating parameters can be
more closely controlled with little or no investment cost.
Applicability:


Benefits:
Applicable to unbleached and bleached kraft mills.


Reduced  atmospheric emissions of  TRS.    Improved  boiler
efficiency.
References:
7, 15, 25, 26
                                         33
                            POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
   5.10 OPTION B-10;  USE OF WEAK WASH FOR SCRUBBING FLUID IN AIR
                       POLLUTION CONTROL SYSTEMS
Description:
Weak wash from the causticizing circuit is used for operation of
air emission scrubbers on smelt dissolving tanks, bleach plant and
C1O2 plant vents, lime slakers, and lime kilns.  Scrubber water is
returned to the causticizing circuit.
Costs:
Variable and site-specific.
Applicability:
Applicable to unbleached and bleached kraft mills.
Benefits:
Water conservation.  Reduced atmospheric emissions. Additional
recovery of pulping chemicals. Reduced wastewater discharges.
References:
32
                                       34
                          POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
             5.11 OPTION NO. B-ll;  LIME MUD DIVERSION BASIN
Description:
Installation of a basin for diversion of lime mud slurries during
process upsets and lime mud clarifier maintenance. Lime mud that
would otherwise be lost to the mill sewerage system could  be
recovered.
Costs:
Investment costs should be in the range of a few hundred thousand
dollars.
Applicability:
Applicable to unbleached and bleached kraft mills.
Benefits:
Resource recovery.  Reduced wastewater loadings, wastewater
treatment costs, and reduced sludge disposal costs.
References:
                                         35
                           POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
              5.12  OPTION NO. B-12;  OXYGEN DELIGNIFTCATION
Description:
Pulp processing with oxygen in an alkaline environment subsequent
to conventional or extended pulping processes, but  prior to
bleaching with chlorine and/or chlorine derivatives.  For medium
consistency  systems   (10  -  12%),  40  -  45%  additional
delignification is attainable.  For high consistency systems (25 -
28%), additional delignification up to 50% is attainable.
Costs:
Applicability:
Retrofit costs are variable and site-specific.  Depending  upon
capacity and  site-specific considerations investment costs may
range  from  $10,000,000  -  $25,000,000.   Recovery  boiler
constraints may be a limiting factor for mills with no available
recovery boiler capacity.

Applicable to bleached kraft  mills with  a moderate amount of
available recovery boiler capacity.  Generally installed at new
bleached kraft mills and as part of major bleach plant rebuilds.
Prerequisite for ozone bleaching.
Benefits:
Energy conservation.  Pulping and bleach plant chemical savings.
Chlorine consumption reduced by up to 50%.  Reduced formation
of  color,   BODS,   and  chlorinated  compounds  including
CDDs/CDFs, chlorophenols, chloroform, and AOX. Reductions
in raw waste loadings as follows from conventional bleaching:
                         BOD5
                         COD
                         COLOR
                         AOX
                Conventional
                  Bleaching

                    28.0
                    100.0
                    300.0
                      7.9
   Oxygen
Delignification

   22.0 kg/ADMT
   70.0 kg/ADMT
   100.0 kg/ADMT
    4.7 kg/ADMT
References:
7, 12, 33, 34, 35, 36, 37, 38, 39, 40
                                        36
                           POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
   5.13 OPTION NO. B-13;  USE OF ANTHRAOUINONE IN PULPING PROCESS
Description:
Use of relatively low charges of anthraquinone in digester (» 0.5
kg/metric ton of pulp)  to  accelerate the pulping process and
increase pulp yield.  Used selectively to offset increased recovery
boiler loading caused by oxygen delignification.
Costs:
Investment costs are not significant.  Operating cost increases are
significant.
Applicability:
Applicable to bleached kraft mills with recovery boiler limitations
where increased pulp yield is desired.
Benefits:
Increased pulp yield.  Marginally reduced consumption of bleach
plant chemicals and attendant formation of chlorinated compounds.
Reduction in effluent color and BOD5.
References:
7, 41, 42
                                        37
                           POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
  5.14 OPTION NO. B-14; BENEFICIAL REUSE OF LIME SLAKFJR GRTTS AND
                           GREEN LIQUOR DREGS.
Description:
Collection and dewatering of lime slaker grits and green liquor
dregs  for  beneficial  offsite reuse as  additives  for  cement
manufacturing.   Grits and dregs are gravity dewatered onsite.
(Technically not pollution prevention.)
Costs:
Variable and site-specific.
Applicability:
Applicable to unbleached and bleached kraft mills.
Benefits:
Reduced volume of solid wastes requiring landfill disposal.
Reduced volume of wastewater treatment sludge requiring disposal
where green liquor dregs are washed to mill sewerage system.
References:
32
                                       38
                          POLLUTION PREVENTION OPTIONS

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PULPING AND CHEMICAL RECOVERY
        5.15 OPTION NO. B-15: UTILIZATION OF POWER BOILER ASH.
Description:
Beneficial reuse of power boiler ash as an additive for cement
manufacture  or as  a soil  conditioner  in combination with
wastewater  treatment  sludge.    (Technically  not  pollution
prevention.)
Costs:
Investment costs are low, but variable and site-specific.
Applicability:
Applicable to unbleached and bleached kraft mills.
Benefits:
Minimize solid waste disposal and associated costs.
References:
15
                                        39
                           POLLUTION PREVENTION OPTIONS

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PULP BLEACHING
                             6.0  PULP BLEACHING
Covering chemical controls and monitoring, improved chemical mixing, chlorine dioxide,
substitution, enhanced extraction, elimination of hypochlorite, water conservation, and control
of air emissions.
   OPTION NO.

        C-l
        C-2
        C-3
        C-4
        C-5
        C-6
        C-7
        C-8
        C-9
TECHNOLOGY
     Chemical Controls	41
     Chemical Mixing  	42
     Split Addition of Chlorine	45
     Chlorine Dioxide Substitution	46
     Enhanced Extraction  	47
     Replacement of Hypochlorites	48
     Ozone Bleaching	49
     Counter-current, Jump Stage Washing	50
     Bleach Plant Vent Controls   	51
                                       40
                               POLLUTION PREVENTION OPTIONS

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PULP BLEACHING
                 6.1 OPTION NO. C-l:  CHEMICAL CONTROLS
Description:
Use  of instrumentation  to  monitor and  control  application of
chlorine and/or chlorine dioxide in the first bleaching stage to
maintain chlorine multiple or Kappa factor within ranges where
formation of CDDs/CDFs and other chlorinated compounds are
minimized.
Costs:
Depending upon type of instrumentation and extent of control
systems, costs may range from $150,000 to $500,000.
Applicability:
Applicable to bleached kraft mills.
Benefits:
Minimize use of chlorine and chlorine derivatives and attendant
formation of CDDs/CDFs and other chlorinated compounds.
References:
16
                                        41
                           POLLUTION PREVENTION OPTIONS

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PULP BLEACHING
                   6.2  OPTION NO. C-2: CHEMICAL MIXING
Description:
Use of high shear mixers for bleach plant chemical additions to
ensure efficient  chemical application and to minimize localized
over-chlorination which fosters formation of unwanted chlorinated
compounds.
Costs:
Depending upon type and size of mixers, costs may range from
$200,000 to $500,000.
Applicability:
Applicable to bleached kraft mills.
Benefits:
Minimize use of chlorine and chlorine derivatives and attendant
formation of CDDs/CDFs and other chlorinated compounds (see
Figures 4 and 5).
References:
43
                                         42
                            POLLUTION PREVENTION OPTIONS

-------
PULP BLEACHING
           60

           50

           40

           30

           20



           10
        £•  5   -
.a
a.
•o
        8"  2
        o
        o
        Q.
        2
        .o
        6
           0.5
           0.2
           0.1
                      10
                      30       50       70


                          CIO2 in First Stage, %
                                 Figure 4

        THE EFFECT OF CHLORINE DIOXIDE SUBSTITUTION ON TOTAL AND
              TETRACHLORINATED PHENOLIC COMPOUND (Ref. 72)
                                    43
                                       POLLUTION PREVENTION OPTIONS

-------
PULP BLEACHING
         6-
         4-
     Q.
     O

     g
         a-
                      10
                                                       Softwood,
                                                       0 2' bleached lab

                                                    O Hardwood, lab
  20          30  •

Total Elementary C^, kgAon
40
                   100       75        50        25

                                CIO2 In First Stage, %
                                    Figure 5

   THE EFFECT OF CHLORINE DIOXIDE SUBSTITUTION ON THE FORMATION OF AOX
                                    (Ref. 72)
                                       44
                  POLLUTION PREVENTION OPTIONS

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PULP BLEACHING
             6.3 OPTION NO. C-3;  SPLIT ADDITION OF CHLORINE
Description:
Use of multiple additions of chlorine to ensure efficient chemical
application  and to  minimize localized over-chlorination  which
fosters formation of unwanted chlorinated compounds.
Costs:
Costs for multiple addition points including mixers and controls
may range from $3,000,000 to $5,000,000 per mill.
Applicability:
Applicable to bleached kraft mills.
Benefits:
Minimize use of chlorine and chlorine derivatives and attendant
formation of CDDs/CDFs and other chlorinated compounds.  Not
as effective as high rate chlorine dioxide substitution (> 70%) for
minimizing formation of chlorinated compounds.
References:
43
                                        45
                           POLLUTION PREVENTION OPTIONS

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PULP BLEACHING
           6.4 OPTION NO. C-4; CHLORINE DIOXIDE SUBSTITUTION
Description:
Use of chlorine dioxide  (ClOj) in place of some or all of the
elemental  chlorine in  the  first bleaching  stage.    C1O2  is
manufactured onsite and applied in solution ahead of the chlorine
charge at rates ranging from 5 % to 100% of the equivalent amount
of elemental chlorine.  Application of C1O2 and C12 is controlled
to maintain Kappa factors less than 0.15 to minimize formation  of
CDDs/CDFs.
Costs:
Depending  upon  capacity,  costs  for  new  chlorine  dioxide
generators  may  range  from  $10,000,000  to  more  than
$20,000,000.  Existing generators may be upgraded to produce
higher quality C1O2 (less than 2%
Applicability:
Applicable to bleached kraft mills.
Benefits:
Minimize use of chlorine and formation of CDDs/CDFs and other
chlorinated compounds including chlorophenols, chloroform and
compounds contributing to AOX.  Most effective at high rates of
substitution (> 70%) for minimizing formation of chlorinated
compounds.
References:
44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54
                                         46
                            POLLUTION PREVENTION OPTIONS

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PULP BLEACHING
                6.5 OPTION NO. C-5: ENHANCED EXTRACTION
Description:
Use of oxygen alone or in combination with hydrogen peroxide in
bleach plant  caustic  extraction  stages  to improve extraction
efficiency and delignification.  Enhanced extraction is practiced at
the majority of bleached kraft mills in the United States.
Costs:
Depending upon capacity, costs for installation of oxygen enhanced
extraction are moderate (less than $1,000,000).  Costs for addition
of hydrogen peroxide are minimal (less than $100,000).
Applicability:
Applicable to bleached kraft mills.
Benefits:
Minimize  use of chlorine  and chlorine derivatives for pulp
bleaching  and attendant formation  of CDDs/CDFs and  other
chlorinated compounds including chlorophenols, chloroform and
compounds contributing to AOX.   Reduced BOD5,  COD, and
effluent color.
References:
12, 35, 38, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64
                                        47
                           POLLUTION PREVENTION OPTIONS

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PULP BLEACHING
          6.6 OPTION NO. C-6: REPLACEMENT OF HYPOCHLORTTES
Description:
Costs:
Elimination of sodium or calcium hypochlorites in pulp bleaching
by replacement with chlorine dioxide.

Depending  upon  capacity,  costs  for  new chlorine  dioxide
generators  may  range  from  $10,000,000  to  more  than
$20,000,000.  Existing generators  may be upgraded to  produce
higher quality C1O2 (less than 2%
Applicability:
Applicable  to  market and  paper grade bleached kraft  mills.
Application may be limited for certain grades of dissolving kraft.
Application may also be limited at mills where  bleach plant
metallurgy is not compatible with chlorine dioxide.
Benefits:
Chloroform formation reduces at more than 95%. Most effective
when hypochlorite is replaced with high purity chlorine dioxide (<
2% Cy, and chlorine application in the first bleaching stage is
minimized through high rate chlorine dioxide substitution.
References:
44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54
                                         48
                            POLLUTION PREVENTION OPTIONS

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PULP BLEACHING
                   6.7 OPTION NO. C-7; OZONE BLEACHING
Description:
Costs:
Use of ozone as the primary bleaching agent in place of chlorine.
Oxygen delignified pulps would be bleached with ozone followed
by conventional extraction and final brightening stages.  The first
commercial scale ozone bleach line is scheduled for completion
during the last half of 1992.

Not available at this writing.  Investment costs are reported to be
higher than for a conventional bleach plant of similar capacity, but
bleaching costs are reported to be lower than for conventional or
high chlorine dioxide substitution bleaching.
Applicability:
Applicable to market and paper grade bleached kraft mills.
Benefits:
Eliminate  formation of CDDs/CDFs,  chlorinated phenols and
compounds contributing to  AOX in the first bleaching stage.
Minimize formation and discharge of AOX to the limited extent
produced in subsequent chlorine dioxide stages. Allows recovery
of ozone and extraction stage filtrates in the recovery circuit.
Substantially reduces wastewater discharge loadings of color and
BODS form bleach plant.
References:
5, 65, 66, 67, 68, 69, 70
                                         49
                            POLLUTION PREVENTION OPTIONS

-------
PULP BLEACHING
      6.8  OPTION NO. C-8t COUNTER-CURRENT. JUMP STAGE WASHING
Description:
Costs:
Reuse of acid stage  filtrates  (hypochlorite or chlorine  dioxide
stages) as  dilution and wash water on  first  bleaching  stage
(chlorine, chlorine/chlorine dioxide, chlorine dioxide/chlorine, or
chlorine dioxide stage), and on log sequence bleach lines, use of
filtrate from the second extraction stage on the first extraction
stage.

Highly variable and site-specific for retrofit installations. Included
in new installations.
Applicability:
Applicable to most bleached kraft mills.  Applications may be
limited at certain mills due to incompatible metallurgy.
Benefits:
Reduce bleach plant wastewater flow by 2,000 to 6,000 gal/ton at
conventional bleach plants.   Steam and energy savings.  Water
conservation.  Marginal reduction in  BOD5 loadings from the
bleach plant.
References:
6, 15
                                          50
                            POLLUTION PREVENTION OPTIONS

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PULP BLEACHING
           6.9 OPTION NO. C-9;  BLEACH PLANT VENT CONTROLS
Description:
Costs:
Caustic  scrubbers  for  control of  chlorine  and  chlorinated
compound emissions from bleach tower vents, washer vents, seal
tank vents, and chlorine dioxide plant vents.

Highly variable and site-specific for retrofit installations. Included
in new installations.
Applicability:
Applicable to bleached kraft mills.
Benefits:
Reduced  atmospheric emissions  of chlorine  and chlorinated
compounds.  See Use of Weak Wash for Scrubbing Fluid Use in
Air Pollution Control Systems, Option No. B-10.
References:
25,32
                                       51
                           POLLUTION PREVENTION OPTIONS

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PULP DRYING AND PAPERMAKING
                   7.0  PULP DRYING AND PAPERMAKING
         Covering  fiber recovery,  white water recovery and  reuse,  steam
         condensate recovery, and chemical substitutions
   OPTION NO.

       D-l
       D-2
       D-3
       D-4
      TECHNOLOGY
PAGE
Fiber and White Water Recovery With Savealls	53
Reuse of Vacuum Pump Seal Water	54
Recovery of Steam Condensates 	55
Chemical Substitutions	56
                                     52
                         POLLUTION PREVENTION OPTIONS

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PULP DRYING AND PAPERMAKING
7.1 OPTION NO. D-l: FIBER AND WHITE WATER RECOVERY WITH SAVEALLS
Description:
Costs:
Use of settling tank, drum, flotation or polydisc savealls to recover
and reclaim fiber and white water or brown water from pulp
dryers and paper machines. Fiber from savealls is returned to the
stock system and subsequently reclaimed as product.  Depending
upon quality (solids content), cleaned white water or brown water
is reused for stock dilution,  wire, headbox, grooved roll, trim
knockdown, wire knockoff and breast roll showers, consistency
regulation, and beaters.

Highly variable and site-specific for retrofit installations.  Included
in virtually all new installations.  Depending upon capacity and
retrofit considerations, costs  may range  from a few  hundred
thousand dollars to over $1,000,000.
Applicability:
Applicable to unbleached and bleached kraft mills.
Benefits:
Increase in yield.   More than 90% fiber recovery is possible
depending upon type of paper and type of saveall.  Water and
energy conservation.  Flow reductions from 200 to 10,000 gal/ton
are possible depending upon type of paper machine and level of
white water reuse.   Reduced wastewater effluent  loadings and
reduced wastewater treatment costs. Reduced solid waste disposal
costs.
References:
6, 7, 15
                                         53
                            POLLUTION PREVENTION OPTIONS

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PULP DRYING AND PAPERMAKJNG
        7.2  OPTION NO. D-2; REUSE OF VACUUM PUMP SEAL WATER
Description:
Costs:
Use  of cascade systems or recirculating  water systems for
operation of water ring vacuum pumps.

Highly variable and site-specific for retrofit installations. Included
in new installations.   Depending upon  capacity and  retrofit
considerations, costs may range from a few hundred thousand
dollars to over $1,000,000.
Applicability:
Applicable to unbleached and bleached kraft mills.
Benefits:
Water and energy conservation.  Reduced wastewater treatment
costs. Water savings in the range of 2,000 gal/ton of product are
possible.
References:
6, 7, 15
                                         54
                           POLLUTION PREVENTION OPTIONS

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PULP DRYING AND PAPERMAKING
         7.3 OPTION NO. D-3: RECOVERY OF STEAM CONDENSATES
Description:
Costs:
Collection and recovery of steam condensates from pulp dryers and
paper machines.

Highly variable and site-specific.
Applicability:
Applicable to unbleached and bleached kraft mills.
Benefits:
Reduced boiler feedwater treatment costs.   Energy and water
conservation.
References:
6,7
                                       55
                          POLLUTION PREVENTION OPTIONS

-------
PULP DRYING AND PAPERMAKING
                            52mfsr^^;sr^^*«r33?rcsr¥^
                            B!i&k-*l^;
-------
WASTEWATER TREATMENT
                      8.0  WASTEWATER TREATMENT
         Covering sludge dewatering, sludge utilization, odor control, and reuse
         of treated effluent.
   OPTION NO.

       E-l
       E-2
       E-3
       E-4
      TECHNOLOGY
PAGE
Improved Sludge Dewatering	58
Sludge Utilization as Hogged Fuel	59
Odor Control	60
Reuse of Treated Effluent	61
                                     57
                         POLLUTION PREVENTION OPTIONS

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WASTEWATER TREATMENT
           8.1 OPTION NO. E-l:  IMPROVED SLUDGE DEWATERING
Description:
Use  of twin wire presses, screw presses or other mechanical
dewatering  devices to maximize solids content  of dewatered
sludges to be disposed of in landfills or incinerated.  (Technically
not pollution prevention.)
Costs:
Depending upon capacity and retrofit considerations, investment
costs may range  from a few hundred thousand dollars to over
$1,000,000.
Applicability:
Applicable to unbleached and bleached kraft mills.
Benefits:
Reduced  landfill  disposal  of solid  wastes.   More  efficient
combustion of lower moisture sludges.
References:
15
                                        58
                           POLLUTION PREVENTION OPTIONS

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WASTEWATER TREATMENT
        8.2  OPTION NO. E-2;  SLUDGE UTILIZATION AS HOGGED FUEL
Description:
Dewatering and combustion of primary and secondary wastewater
treatment sludge in hogged fuel boilers. Dewatered sludges must
contain a minimum of 30%  solids, 6,000 BTU/lb and 66.5%
organic content to support self-sustaining combustion.
Costs:
Not Available
Applicability:
Applicable to unbleached and bleached kraft mills.
Benefits:
Energy recovery.  Reduced landfill disposal of solid wastes.
References:
15
                                       59
                           POLLUTION PREVENTION OPTIONS

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WASTEWATER TREATMENT
                     8.3  OPTION NO. E-3; ODOR CONTROL
Description:
There are  no effective means to control odors  emanating from
kraft mill sewer systems and wastewater treatment facilities. The
most effective means to control such odors are in-plant control
measures for steam stripping of foul condensates  and black liquor
spill prevention and control.
Costs:
See Chapter 5.0  - Condensate Stripping (Option No.  B-6) and
Black Liquor Spill Prevention and Control (Option No.  B-3).
Applicability:
Applicable to unbleached and bleached kraft mills.
Benefits:
Reduced  emissions of TRS and  volatile  organic compounds;
reduced odors. Raw wastewater BOD5 reductions by one-third to
more than one-half, depending upon type of mill.
References:
See Chapter 5.0 - Condensate Stripping (Option No.  B-6)  and
Black Liquor Spill Prevention and Control (Option No.  B-3).
                                        60
                           POLLUTION PREVENTION OPTIONS

-------
WASTEWATER TREATMENT
             8.4  OPTION NO. E-4: REUSE OF TREATED EFFLUENT
Description:
Treated wastewater effluent can be used for a number of non-
critical water applications including make-up to log flume recycle
systems, dust suppression on chip piles and roadways, and make-
up to fire protection ponds.  (Technically not pollution prevention.)
Costs:
Highly variable and site-specific.
Applicability:
Applicable to unbleached and bleached kraft mills.
Benefits:
Water conservation. Reduced effluent discharges (Approximately
300 Ibs/day BOD5 and TSS for each one million gallons per day
of effluent flow reduction).
References:
6, 15
                                        61
                           POLLUTION PREVENTION OPTIONS

-------
REFERENCES
                                9.0  REFERENCES
 1.    Berry, R.M. et.al.  Toward Preventing the Formation of Dioxins During Chemical Pulp
      Bleaching.  Pulp & Paper Canada, 90(8), 1989, pp. 48-58.

 2.    Voss, R.H.  et.al.  Some New Insights into the Origins of Dioxins Formed During
      Chemical Pulp Bleaching. Paper presented at the 1988 CPPA Environment Conference,
      Vancouver, B.C., October 25-26, 1988.

 3.    Personal communication with Georgia-Pacific Corporation, Leaf River Pulp Operations,
      New Augusta, Mississippi, March 17, 1992.

 4.    Personal communication with  Bowater  Southern Division, Calhoun,  Tennessee,
      March 25, 1992.

 5.    Personal communication with Union Camp  Corporation, Franklin, Virginia, April 8,
      1992.

 6.    Development Document for Effluent Limitations Guidelines and Standards for the Pulp,
      Paper and Paperboard. Effluent Guidelines Division, WH-552, Washington, D.C.  EPA
      440/1-82/025, October, 1982.

 7.    Smook, G. A. Handbook for Pulp & Paper Technologists: Joint Textbook Committee of
      the Paper Industry; TAPPI, Technology Park/Atlanta and Canadian Pulp  and Paper
      Association/Montreal; Seventh printing, 1989.

 8.    Ducey, MJ., Technical Editor.  Pulping Bleaching Concerns Focus on C1O2 Generation,
      Effluent. Pulp & Paper, June 1987, pp. 89-92.

 9.    Galloway,  L.R.  et.al.    Industry's  Effluent  Problems Spawn New  Engineering
      Technology, Design. Pulp & Paper, September  1989, pp. 91-97.
                                         62                   POLLUTION PREVENTION

-------
REFERENCES
10.   Andrews, E.K.  RDH Kraft Pulping to Extend Delignification, Decrease Effluent, and
      Improve Productivity and Pulp Properties.  TAPPI Journal, November 1989, pp. 55-61.

11.   Mera, F.E.; Chamberlin, J.L. Extended Delignification, An Alternative to Conventional
      Kraft Pulping. TAPPI Journal, January 1987, pp.  132-136.

12.   Axegard, P.   Chlorine Dioxide Substitution  Reduces  the Load of  TOC1.   TAPPI
      Proceedings,  1987 Pulping Conference, November 1987, pp. 105-110.

13.   Swift,  K.  RDH Pulping - Better Pulp Properties Through Improved Selectivity.
      Unpublished,  available from author or Beloit Corporation.

14.   Elliott, R.G.  and Whalley, C.A. AOX and Dioxin Emissions Reduction at Longview
      Fiber Company, Low Kappa number Pulping Trials.  1991 Pulp Bleaching Conference,
      Stockholm, Sweden, June 1991.

15.   Springer, A.M.  Industrial Environmental Control - Pulp and Paper Industry.  John
      Wiley & Sons, Inc., 1986.

16.   USEPA.  USEPA/Paper Industry Cooperative Dioxin Study (104 Mill Study) Summary
      Report. July, 1990.  Washington, D.C.

17.   National  Council of the Paper Industry for Air and Stream Improvement, Inc.  Spill
      Prevention  and Control Aspects of Paper Industry  Wastewater Management Programs.
      Stream Improvement, Technical Bulletin No. 276,  August, 1974.

18.   Hise, R.G.;  Hintz,  H.L.  Effects of Brownstock Washing on the Formation of
      Chlorinated Dioxins and Furans During Bleaching, The.  TAPPI journal, January 1990,
      pp. 185-190.

19.   Myers, M. et.al. Oxygen Delignification Systems: Synthesizing the Optimum Design.
      TAPPI Journal, April 1989, pp. 131-135.
                                        63                  POLLUTION PREVENTION

-------
REFERENCES
20.   Ducey,  M.J.  Technical Editor.   Efforts in Chemical Pulp Bleaching  Technology
      Emphasize Cutting Costs. Pulp & Paper, July 1986, pp. 47-50.

21.   Rempel, W.; Pryke,  D.C.; Ouchi, M.D.  Mill Trials of Substantial Substitution of
      Chlorine Dioxide for Chlorine - Part HI: Medium Consistency. Unpublished.

22.   Review of Technology for Overcoming Capacity Limitations in Kraft Pulp Industry
      Recovery Boilers; Industry,  Science and Technology  Canada; Ottawa,  Canada;  N.
      McCubbin Consultants, Inc.; July 1990.

23.   LaFluer, L., Brunck, R., McDonough, T., Ramage, K., Gillespie, W. and Malcome E.,
      1990:  Studies on the Mechanism of PCDD/PCDF Formation During the Bleaching of
      Pulp. Chemosphere 20:10-12, p. 1731-1738.

24.   Elliott,  R.G. and Walley, C.A.  AOX  and Dioxin Emissions Reduction at Longview
      Fiber Company, Low Kappa number Pulping Trials.  1991 Pulp Bleaching  Conference,
      Stockholm, Sweden, June 1991.

25.   Environmental Pollution Control, Pulp and Paper Industry, Part I - Air, U.S. EPA; EPA-
      625/7-76-001;  October 1976.

26.   Factors Affecting Emission of Odorous Reduced Sulfur Compounds from Miscellaneous
      Kraft Process Sources;  Atmospheric Quality Improvement Technical Bulletin No. 60;
      National Council of the Paper Industry for Air and Stream Improvement, Inc.; New
      York, New York; March 1972.

27.   Characterization  of  Various  Condensate  Streams  in the  Kraft Process;  Stream
      Improvement Technical Bulletin No. 310; National Council of the Paper Industry for Air
      and Stream Improvement, Inc.; New York, New York;  April 1978.

28.   Butryn,  G.L.  and Ayers, K.C.; Mead Experience in Steam Stripping Kraft Mill
      Condensates; TAPPI Journal; Vol. 58, No. 10; October 1975.
                                        64                  POLLUTION PREVENTION

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REFERENCES
29.   Carter, D.N. and Tench, L.; Condensate Stripping Systems for Kraft Mills; Pulp and
      Paper Magazine of Canada; Vol. 75, No. 8; August 1975.

30.   Stripping and Disposal of Contaminated Condensates; TAPPI Journal;  Vol. 57, No. 9;
      September 1974.

31.   Rowbottom, R. and Wheeler, G.; Stripping-Incineration System Cuts TRS Emissions at
      Cornwall; Pulp and Paper Canada; Vol. 76, No. 2; February 1975.

32.   Pollution Prevention  Opportunity Assessment and Implementation Plan for Simpson
      Tacoma Kraft Company, Tacoma, Washington.  Prepared for U.S. EPA  Region  10,
      Seattle, Washington  by Science Applications International  Corporation,  Olympia,
      Washington and Amendola Engineering, Inc., Lakewood, OH.  August,  1992.

33.   Tench, L., Harper, S.  Oxygen Bleaching Practices and Benefits - An Overview. TAPPI
      proceedings. 1987 International Oxygen Delignification Conference.

34.   Chang, H.M.  Oxygen Bleaching Shows  Potential for Reducing Costs and Effluent
      Problems.  Pulp and Paper.  March 1980.

35.   Liebergott, N., van Lierop, B. Oxidative Bleaching - A Review, Part I: Delignification.
      Pulp and Paper Canada.  September 1986.

36.   Schleinkofer, R.W.   Short Sequence Bleaching  with Oxygen:   Part H.  TAPPI
      Proceedings. 1982 Pulping Conference.

37.   Evans, J.C.W., Senior Editor.  Automated C102 Generation Improves Bleaching, Cuts
      Effluent.  Pulp & Paper, February 1983, pp. 69-71.

38.   Macleod, M.  Bleaching Technology Review:  Recent Developments, Future Trends.
      Pulp & Paper, October 1982, pp. 61-65.
                                         65                  POLLUTION PREVENTION

-------
REFERENCES
39.   Lindstrom, L.A.; Norden. S. Efficient Post Oxygen Washing - Crucial for Low Bleach
      Plant Emissions.  To be presented at APPITA 1990 Conference, New  Zealand, April
      1990.

40.   McDonough, TJ. Oxygen Bleaching Processes. TAPPI Journal, June 1986, pp. 46-52.

41.   Lightfoot, W.E. New Catalyst Improves Polysulfide Liquor Makeup, 02 Delignification.
      Pulp & Paper, January 1990, pp. 88-93.

42.   Renard, J.J. et.al.  New Opportunities for In-Plant Reduction of Pollutants Through
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43.   Hise, R.G.  Split Addition of Chlorine and pH  Control for Reducing Formation of
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44.   Pryke, B.C. Substituting Chlorine Dioxide for Chlorine. TAPPI Journal, October 1989,
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45.   Owen, D. et. al.  Survey of Chlorine Dioxide generation in the United States, A.  TAPPI
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46.   Axegard, P.  Substituting Chlorine Dioxide for Elemental Chlorine Makes the Bleach
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47.   Germgard, U.  Technical Consequences of New Knowledge on Prebleaching with a High
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48.   Axegard,  P.   Improvement  of  Bleach  Plant Effluent by  Cutting  Back on  C12.
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49.   Munro, F.C. et.al. Impact of High Chlorine Dioxide Substitution for Chlorine on the
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50.   de Sousa, F. et.al. Influence of Chlorine Ratio and Oxygen Bleaching on the Formation
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52.   Kringstad, K.P. et.al.   Influence  of  Chlorine Ratio and Oxygen Bleaching  on  the
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53.   Rempel, W.  et.al.   Mill Trials of Substantial Substitution  of Chlorine Dioxide for
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55.   Pryke, D.C.  Fraternity Gathers at  the chateau:  The 1985 International Pulp Bleaching
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56.   Renard, J.J.  et.al. New Opportunities for In-Plant Reduction of Pollutants Through
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57.   Kleppe, P.J.; Storebraten, S. Delignifying High-Yield Pulps with Oxygen and Alkali.
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58.   Helmling, O.  et.al.   Mill Experience  with Oxygen and Hydrogen Peroxide Bleaching
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59.    Liebergott, N.  et.al.  Modifying the Bleaching Process to Decrease AOX Formation.
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60.    Ducey, M.K.,  Technical Editor.  Sulfite Mills Move to Cut TOCI.   Pulp & Paper
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61.    Crawford, R.J. Laboratory Studies of Chloroform Formation in Pulp Bleaching.  TAPPI
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•62.    Ducey, J.J., Technical Editor.  Oxidative Extraction at Halsey Mill Cuts Hypochlorite
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63.    Lachenal, D.  Reinforcement of Oxygen-Alkali Extraction with Hydrogen Peroxide or
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64.    Anderson, J.R.,  Carmichael,  D.L.  Hydrogen Peroxide Technology for Chlorine
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65.    Lindholm, C.A. Some Effects of Treatment Consistency in Ozone Bleaching. Helsinki
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66.    Laxen, T., Henricson, H. and Ryyanen, H.  Medium Consistency Ozone Bleaching.
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67.    Lachenal, D. and Taverdet,  M.T.  Improvement in Ozone Bleaching of Kraft Pulps.
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68.    Jacobson, B., Lindblad, P-O and Nilvebrant, N-O.  Lignin Reactions Affect the Attack
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69.   Dillner, B. and Tibbling, P.  Use of Ozone at Medium Consistency for Fully Bleached
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70.   Hartler, N., Granlund, V. Sundin, J.  and Tubek-Lindblom, A.  Ozone Bleaching of
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71.   Krouskop, D.J. and Ayers, K.C.  The Story of Mead's Use of Bleached Kraft Sludge for
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72.   Axegard, P.   Improvement  of Bleach Plant  Effluent by  Cutting Back on  C12.
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