. 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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