. United States Office of Water and February 1981 - ~ Environmental Protection Waste Management 5567 Agency Washington, D.C 20460 vvEPA Proposed Effluent Guidelines Rulemaking for Pulp, Paper, and Paperboard Builders' Paper and Board Mills Point Source Categories ------- ------- Background The Clean Water Act Under the Clean Water Act (the Federal Water Pollution Control Act Amend- ments of 1972, as amended by the Clean Water Act of 1977), the Environmental Protection Agency (EPA) is charged with the responsibility to restore and main- tain the chemical, physical, and biological integrity of the Nation's waters. Direct Dischargers The Act requires that all industries discharging wastes into navigable waters achieve by July 1, 1977, the "best practicable control technology currently available" (BPT). This control technology represents the average of the best exist- ing waste treatment performance within each industry category or subcategory. By July 1, 1984, the Act requires the application of effluent limitation technology based on the very best con- trol and treatment measures that have been developed or that are capable of being developed within the industry category or subcategory. These effluent limitations require: • Toxic and Nonconventional Pollutants—Application of the "best available technology economically achievable" (BAT) • Conventional Pollutants—Applica- tion of the "best conventional pollu- tant control technology" (BCT) New source performance standards (NSPS) are also established for the con- trol of toxic, conventional, and non- conventional pollutants discharged by new industrial direct dischargers. NSPS, which goes into effect at the commence- ment of operation, is described as the "best available demonstrated control technology, processes, operating methods, or other alternatives including, where practicable, a standard permitting no discharge of pollutants." Indirect Dischargers Indirect dischargers are industrial facilities that discharge pollutants to publicly owned treatment works (POTW). The Clean Water Act directs EPA to establish national pretreatment stand- ards for pollutants that are incompatible with municipal treatment plants. The Act requires: • Achievement, within 3 years of pro- mulgation, of pretreatment stand- ards for existing sources (PSES) • Achievement, upon commencement of operation, of pretreatment stand- ards for new sources (PSNS) Purpose of Proposed Regulations The primary purpose of these regula- tions is to provide effluent limitations guidelines for BAT and BCT and to establish NSPS, PSES, and PSNS under Sections 301, 304, 306, 307, and 501 of the Clean Water Act To promote these purposes, the regulations may also establish monitoring requirements under Section 308 of the Act and Best Manage- ment Practices (BMP) under Section 304(e) of the Act. While the requirements for direct dischargers are to be incorporated into National Pollutant Discharge Elimina- tion System (NPDES) permits issued under Section 402 of the Act by EPA and participating States, pretreatment stand- ards are enforceable directly by the agency against indirect dischargers. The proposed regulations do not re- quire the installation of any particular treatment technology. Rather, they re- quire achievement of effluent limitations representative of the proper operation of demonstrated technologies or equivalent technologies. Industry Coverage The Pulp, Paper, and Paperboard Industry (which includes the Pulp, Paper, and Paperboard and the Builders' Paper and Board Mills Point Source Categories) is included within the U.S. Department of Commerce, Bureau of the Census Standard Industrial Classifica- tions (SIC) 2611, 2621, 2631, and 2661. This industry, which produces wood pulp, nonwood pulp, paper, and paper- board, can be divided into three major segments: integrated, nonintegrated, and secondary fiber mills. Integrated mills manufacture pulp alone, or pulp and paper or paperboard on site Nonintegrated mills manufacture paper or paperboard but do not manufacture pulp on site. Secondary fiber mills use wastepaper as the primary raw material to produce paper or paperboard. • Products of this industry include pulp, newsprint, coated printing papers, unbleached and bleached linerboard, tissue papers, glassine and greaseproof papers, cotton fiber paper, special industrial papers, and bleached and un- bleached kraft papers. • This is a high-water-use industry. The major uses of water are similar industrywide, although the amount used varies. Wastewater discharges total 16 million cubic meters (4.2 billion gallons) per day, with 87 per- • cent from integrated mills. • Between 1969 and 1979, sales in- creased annually by 10.4 percent; after-tax return on sales averaged 5 percent, slightly higher than the average for all manufacturing industries. • Closures are expected to occur in all three segments of the industry, caused by declining demand for some products and concentration of the industry in the larger mills. The production capacity lost throuqh ------- these closures will be replaced either by transferring excess or idle capacity to existing mills or by ex- panding existing mills to allow for more production. Pollutants Pollutants discharged by the industry include: • Toxic Pollutants—Chloroform, zinc, trichlorophenol, and pentachlorophenol • Conventional Pollutants— BOD5, TSS, and pH • Nonconventional Pollutants— Ammonia, color, resin acids, and bleach plant derivatives ERA'S Development Program To implement the Clean Water Act, EPA conducted a complex development pro- gram. This program included: • Development of analytical methods for detecting and measuring toxic pollutants • Sampling of raw and treated wastewater and intake water of a representative sample of plants • Use of the analytical methods developed for detecting and measuring toxics, i.e., gas chromatography/mass spectrometry (GC/MS), atomic adsorption spec- trophotometry (AAS), and inductive- ly coupled argon plasma (ICAP) excitation with appropriate quality control/quality assurance (QC/QA) procedures Technical Data Gathering The technical analysis was based on: • Detailed questionnaires distributed to 678 operating mills, of which 632 responded • Contact with State regulatory agen- cies, EPA regional offices, and EPA and private research facilities to obtain available pertinent data and information on unpublished research activities • A literature survey to obtain infor- mation on the presence of toxic and nonconventional pollutants that may be discharged from mills and on the production process controls and effluent treatment technologies employed in the industry, including review of over 1 million articles and 3,500 environmental data files Methodology After gathering detailed technical data on all segments of the Pulp, Paper, and Paperboard Industry, EPA studied the data to determine whether differences among the segments of the industry re- quired separate effluent limitations and standards of performance. Next, EPA identified the wastewater constituents to be considered for effluent limitations guidelines and standards of performance and iden- tified in-plant and end-of-process treat- ment technologies that were being used, or that could be used, by the industry. EPA analyzed data on the performance of each technology, and its associated non-water-quality environmental impacts. The cost of each control and treat- ment technology was estimated from unit cost curves, and the economic im- pacts of these costs were evaluated. EPA derived unit process costs from model plant characteristics (production and flow) applied to each treatment pro- cess unit cost curve (i.e., activated sludge, chemically assisted clarifica- tion/sedimentation, granular activated carbon adsorption, mixed media filtra- tion). These unit process costs were combined to yield total cost at each treatment level. After confirming the accuracy of cost estimates by compar- ing EPA cost estimates with treatment system costs supplied by the industry, the Agency evaluated the economic im- pacts of these costs. EPA then identified the various treat- ment technology options for BAT, BCT, NSPS, PSES, and PSNS. Finally, EPA selected the preferred option by industry subcategory for each set of standards. Subcategories The existing subcategorization for the Pulp, Paper, and Paperboard Industry was reviewed to determine its adequacy in representing industrial practices. The regulations proposed in this rulemaking apply to the following subcategories: • Integrated Mills — Dissolving Kraft — Market Bleached Kraft — Board, Coarse, and Tissue Bleached Kraft — Fine Bleached Kraft —Soda — Unbleached Kraft —Semi-Chemical — Unbleached Kraft and Semi- Chemical — Dissolving Sulfite Pulp — Papergrade Sulfite (Blow Pit Wash) — Papergrade Sulfite (Drum Wash) —Ground wood—Thermo- Mechanical —Groundwood—Coarse, Molded, and News (CMN) Papers —Groundwood —Fine Papers • Nonintegrated Mills — Nonintegrated—Fine Papers — Nonintegrated—Tissue Papers — Nonintegrated—Lightweight Papers — Nonintegrated—Paperboard — Nonintegrated—Filter and Nonwoven Papers ------- • Secondary Fiber Mills — Deink — Tissue From Wastepaper — Paperboard From Wastepaper —Wastepaper-Molded Products — Builders' Paper and Roofing Felt The subcategories described above do not reflect the industry segments used to evaluate the economic impacts of the proposed regulations. At mills in certain subcategories, a variety of end products can be manufactured. Because of this, the economic impacts are presented for both mill and product types. Summary of Control Technologies Considered The following pollution control technologies were considered by EPA in developing standards for the Pulp, Paper, and Paperboard Industry Toxic Pollutant Controls • Option 1 — Proper application and operation of the technologies that formed the basis of BPT effluent limitations • Opt/on 2—Chemical substitution Conventional Pollutant Controls • Option 1 — BPT plus additional pro- duction process controls to reduce raw waste loads • Option 2—BPT plus chemically assisted clarification for those sub- categories where BPT was based on biological treatment or BPT plus biological treatment for sub- categories where BPT was based on primary treatment only • Option 3—Option 1 plus chemically assisted clarification for those sub- categories where BPT was based on biological treatment or Option 1 plus biological treatment for those subcategories where BPT was based on primary treatment only • Option 4—Upgrading of existing BPT to attain effluent levels characteristic of best performing mills • For NSPS, the application of pro- duction process controls to reduce wastewater discharge and raw waste loads plus end-of-pipe treatment (biological treatment or primary clarification) Nonconventional Pollutant Controls • Substitution of a different base chemical for ammonia • Application of biological treatment to allow conversion of ammonia to nitrate • Application of chemically assisted clarification where highly colored effluents are discharged The Proposed Regulations Proposed BAT • The Regulation —Option 1 (equal to BPT) for all subcategories where chlorine or zinc is used to bleach pulps — Option 2 (chemical substitution for slimicides and biocides) for all subcategories Technology—Screening, primary clarification, and biological treat- ment (Option 1) Rationale— No incremental cost would be associated with Option 1, and toxic chemicals would be substantially reduced; Option 2 would eliminate expensive end-of- pipe treatments and is already be- ing used at 80 percent of the mills Regulated Pollutants—Chloroform and zinc (Option 1) and penta- chlorophenol and trichlorophenol (Option 2) Proposed BCT • The Regulation —Option 4 (equal to best mill per- formance in each subcategory) for subcategories that pass the BCT cost-reasonableness test —Option 1 (BPT plus additional in- plant production process con- trols) for subcategories that fail the BCT cost-reasonableness test: nonintegrated—tissue, non- integrated—lightweight, nonintegrated—filter and non- woven — Same as BPT for the dissolving sulfite pulp, the builders' paper and roofing felt and noninte- grated paperboard subcategories • Technology —Option 41 Aerated stabilization basins with a spill prevention and control system, increased aera- tion and additional settling capacity, or an activated sludge system with spill prevention and control, equalization, increased aeration capacity, operation in the contact stabilization mode, and larger clarification and sludge-handling equipment; or ox- idation ponds with rapid sand filtration; or a primary treatment sytem with reduced clanfier overflow rates, addition of chemical coagulants, and in- creased sludge-handling capacity —Option 1: BPT plus segregation of noncontact cooling water, use of dry barking operations, collection of spills and leaks for reprocess- ing, increased efficiency of pulp washing, collection and reuse of paper machine spills, improve- ment in save-all operation, and effluent recycle/reuse ------- • Rationale—Option 4 yields signifi- cant removals of BOD5 and TSS at lower cost to the industry and has proved successful in full-scale operation throughout the entire range of process types; it also allows considerable flexibility to the industry in achieving BCT • Regulated Pollutants—BOD5, TSS, and pH • Results— Removal of 370.4 million pounds (167.9 million kilograms) of BOD5 and TSS per year Proposed NSPS • The Regulation —Option 1 (production process con- trols plus end-of-pipe treatment) for all subcategories —Option 2 (use of chemical substitutes for toxic pollutants) • Technology— Production process controls, end-of-pipe treatment, substitution of sodium hydrosulfite for zinc hydrosulfite, and use of slimicides and biocides that do not contain trichlorophenol and pen- tachlorophenol • Rationale—Options 1 and 2 will substantially reduce the identified toxic and conventional pollutants • Regulated Pollutants—Chloroform, BOD5, TSS, zinc, trichlorophenol, and pentachlorophenol Proposed PSES and PSNS • The Regulation—Chemical substitutes for toxic pollutants • Technology—Substitution of sodium hydrosulfite for zinc hydrosulfite and use of slimicides and biocides that do not contain trichlorophenol and pentachloro- phenol • Rationale—Will ensure minimal discharge of toxic pollutants that pass through POTW or limit POTW sludge management alternatives and will involve minimal cost • Regulated pollutants—Zinc, trichlorophenol, and pen- tachlorophenol • Results—Removal of 22,000 pounds of trichlorophenol, 8,000 pounds of pentachlorophenol, and 44,000 pounds of zinc per year Non-Water-Quality Aspects of Pollution Control Air Pollution • No additional air pollution problems are anticipated Solid Waste • Proposed BAT, BCT, and PSES will increase the industry's total generated solid waste by 1.3 percent Energy Requirements • Proposed BAT, BCT, and PSES will increase energy consumption by about 0.9 percent Best Management Practices Although EPA is not proposing them at this time, the Agency is considering development of BMP specific to the Pulp, Paper, and Paperboard Industry. These will be applicable to all industrial sites and will offer guidance to permit authorities in establishing the BMP re- quired by unique circumstances at a given plant. Economic Impact Analysis The economic analysis was based on: • Questionnaires distributed to 706 mills, of which 682 responded • A survey of government publica- tions, industry members, trade associations, and publicly available financial studies • Site visits to selected mills Impact Summary • Integrated Mills — Mills in this segment are ex- pected to make an initial invest- ment of $1.1 billion and to incur annual costs of $338 million per year at the projected 1982 in- dustry capacity to comply with the proposed regulations —One mill is expected to close as a result of the proposed regulations —One mill, which would otherwise close, is expected to remain open as a result of the proposed regulations (due to improved com- petitive standing) • Nonintegrated Mills — Mills in this segment are ex- pected to make an initial invest- ment of $29 million and to incur annual costs of $8 million per year at the projected 1982 in- dustry capacity to comply with the proposed regulations —One mill is expected to close as a result of the proposed regulations —One mill, which would otherwise close, is expected to remain open as a result of the proposed regulations (due to improved com- petitive standing) ------- Secondary Fiber Mills — Mills in this segment are ex- pected to make an initial invest- ment of $57 million and to incur annual costs of $21 million per year at the projected 1982 in- dustry capacity to comply with the proposed regulations —Five mills are expected to close as a result of the proposed regulations —Two mills, which would otherwise close, are expected to remain open as a result of the proposed regulations (due to improved com- petitive standing) Glossary AAS Atomic adsorption spectrophotometry BAT "Best available technology economically achievable," to be achieved by July 1,1984 BCT "Best conventional pollutant control technology," to be achieved by July 1, 1984 BMP Best management practices BOD5 Biochemical oxygen demand BPT "Best practicable control technology currently available," to be achieved by July 1, 1977 EPA U.S. Environmental Protection Agency GC/MS Gas chromatography/mass spectrometry ICAP Inductively coupled argon plasma NPDES National Pollutant Discharge Elimination System NSPS New source performance standards, to be achieved upon commencement of operation of a new plant POTW Publicly owned treatment works PSES Pretreatment standards for existing sources, to be achieved within 3 years of pro- mulgation of a regulation PSNS Pretreatment standards for new sources, to be achieved upon commencement of opera- tion of a new plant QC/QA Quality control/quality assurance SIC Standard Industrial Classifica- tion (Department of Commerce, Bureau of the Census) For futher information, contact: Technical information may be obtained from: Robert W. Dellinger Effluent Guidelines Division (WH-552) U.S. Environmental Protection Agency Washington, D.C. 20460 (202) 426-2554 Copies of technical documents may be obtained from: Distribution Officer Effluent Guidelines Division (WH-552) U.S. Environmental Protection Agency Washington, D.C. 20460 (202) 426-2724 The economic analysis may be obtained from: Robert C. Ellis Water Economics Branch (WH-586) U.S. Environmental Protection Agency Washington, D.C. 20460 (202)426-2617 TSS Total suspended solids ------- ------- United States Environmental Protection Agency Offic i.il Business Penalty fur PrivdU Use $300 Washington DC 20460 ~ o r Special Fourth-Class Pate BOOK j Postage and Fees Paid I EPA Permit No G 35 '"> f. "•,' f y sr ------- |