. 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
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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
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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
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• 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
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• 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)
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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
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