DEVELOPMENT DOCUMENT

                     for

       EFFLUENT LIMITATIONS GUIDELINES
       NEW SOURCE PERFORMANCE STANDARDS

                     and

            PRETREATMENT STANDARDS

                   for the

         PULP, PAPER, AND PAPERBOARD

                   and the

       BUILDERS' PAPER AND BOARD MILLS
           POINT SOURCE CATEGORIES
               Anne M. Gorsuch
                Administrator
               Jeffery D. Denit
    Director, Effluent Guidelines Division

             Robert W. Dellinger
            Senior Project Officer
                     and
Acting Chief, Wood Products and Fibers Branch
                Wendy D. Smith
               Project Officer
                 October 1982

         Effluent Guidelines Division
               Office of Water
     U.S. Environmental Protection Agency
           Washington, D.C.  20460

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                               ABSTRACT


This document presents the findings of a study of the pulp, paper, and
paperboard and the  builders'  paper  and  board  mills  point  source
categories.   The  purpose  of  this  study  was  to  develop effluent
limitations guidelines for existing  and  new  point  sources  and  to
establish  pretreatment  standards for existing and new dischargers to
publicly owned treatment works.  These regulations were promulgated in
October of 1982 under the authority of Sections 301,  304,  306,  307,
308,  and  501  of  the  Clean  Water Act (the Federal Water Pollution
Control Act Amendments of 1972, 33 USC 1251  et seq., as amended by the
Clean Water Act of 1977, P.L. 95-217 (the "Act")) and in  response  to
the Settlement Agreement in Natural Resources Defense Council, Inc. v.
Train, 8 ERC 2120 (D.D.C. 1976), modified, 12 ERC 1833 (D.D.C. 1979).

The  information  presented  in  this  document supports the following
promulgated regulations: best practicable control technology currently
available  (BPT), best  available  technology  economically  achievable
(BAT),  new  source  performance  standards  (NSPS),  and pretreatment
standards for new and existing sources (PSNS and PSES) for  the  pulp,
paper,  and  paperboard  and the builders' paper and board mills point
source categories.  In this report, information is presented  on  data
gathering efforts, subcategorization, water use, pollutant parameters,
control and treatment technologies, development of regulatory options,
cost  and  non-water  quality  considerations, and the methodology for
development of effluent limitations.
                                m

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                          TABLE OF CONTENTS


SECTION                                                               PAGE

I    CONCLUSIONS                                                        1

          SUBCATEGORIZATION                                             1
          BPT                                                           3
          BAT                                                           5
          NSPS                                                          5
          PSES and PSNS                                                12
          IMPACT OF THE REGULATIONS                                    12
             Existing Sources                                          12
             New Sources                                               17

II   INTRODUCTION                                                      19

          PURPOSE AND AUTHORITY                                        19
          STATUS OF THE EFFLUENT LIMITATIONS GUIDELINES                21
          SCOPE OF THIS RULEMAKING                                     23
          SUMMARY OF METHODOLOGY                                       24
             Introduction                                              24
             Existing Data Evaluation                                  26
             Data Request Program                                      29
             Screening Program                                         31
             Industry Profile and Review of Subcategorization          42
             Verification Program                                      44
             Long-Term Sampling Program                                56
             Discharge Monitoring Data Acquisition Program             60
             Supplemental Data Acquisition Program                     61
             PCB Data Acquisition Program                              63
             Data Obtained from Industry on proposed Regulations       63
             Analysis of Treatment Alternatives                        63
             Analysis of Cost and Energy Data                          66

III  DESCRIPTION OF THE INDUSTRY                                       67

          INTRODUCTION                                                 67
          RAW MATERIALS                                                67
          STANDARD MANUFACTURING PROCESSES                             67
             Raw Material Preparation                                  68
             Pulping                                                   68
             Use of Secondary Fibers                                   71
             Bleaching of Wood Pulps                                   72
             Papermaking                                               75
          INDUSTRY PROFILE                                             77
             Geographical Distribution                                 77
             Method of Wastewater Discharge                            77
             Production Profile                                        83

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SECTION                                                               PAGE

IV   SUBCATEGORIZATION                                                 89

          INTRODUCTION                                                 89
          INTEGRATED SEGMENT                                           90
          SECONDARY FIBERS SEGMENT                                     93
          NONINTEGRATED SEGMENT                                        95
          MISCELLANEOUS MILLS                                          97
          IMPACT OF TOXIC POLLUTANT DATA                               97
          SUMMARY                                                      97
             Dissolving Kraft                                          98
             Market Bleached Kraft                                     98
             BCT (Board, Coarse, and Tissue) Bleached Kraft            99
             Fine Bleached Kraft                                       99
             Soda                                                      99
             Unbleached Kraft                                          99
             Semi-Chemical                                             99
             Unbleached Kraft and Semi-Chemical                        99
             Dissolving Sulfite Pulp                                  100
             Papergrade Sulfite (Blow Pit Wash)                       100
             Papergrade Sulfite (Drum Wash)                           100
             Groundwood - Thermo-Mechanical                           100
             Groundwood-CMN (Coarse, Molded, News) Papers             100
             Groundwood-Fine Papers                                   101
             Groundwood-Chemi-Mechanical                              101
             Deink                                                    101
             Tissue From Wastepaper                                   101
             Paperboard from Wastepaper                               101
             Wastepaper-Molded Products                               102
             Builders' Paper and Roofing Felt                         102
             Nonintegrated-Fine Papers                                102
             Nonintegrated-Tissue Papers                              102
             Nonintegrated-Ligntweight Papers                         102
             Nonintegrated-Filter and Nonwoven Papers                 102
             Nonintegrated-Paperboard                                 102

V    WATER USE AND WASTE CHARACTERIZATION                             103

          WATER USE AND SOURCES OF WASTEWATER                         103
             Wood Preparation                                         103
             Pulping and Recovery                                     105
             Bleaching                                                109
             Papermaking                                              111
          WASTE CHARACTERIZATION STRATEGY                             112
             Conventional Pollutants                                  112
          TOXIC AND NONCONVENTIONAL POLLUTANTS                        183
             Screening Program                                        183
             Verification Program                                     193
             Long-Term Sampling Program                               193
             Summary                                                  235
             Supplemental Data on Nonconventional Pollutants          235

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SECTION                                                               PAGE

VI   SELECTION OF POLLUTANT PARAMETERS                                241

          WASTEWATER PARAMETERS OF SIGNIFICANCE                       241
          SELECTION OF WASTEWATER PARAMETERS OF SIGNIFICANCE          241
             Conventional Pollutants                                  241
             Toxic Pollutants                                         241
             Nonconventional Pollutants                               243
             Review of Previous Regulations                           244
             Identification of Other Compounds of Concern             246

VII  CONTROL AND TREATMENT TECHNOLOGY                                 275

          INTRODUCTION                                                275
          PRODUCTION PROCESS CONTROLS COMMONLY EMPLOYED BY THE
            PULP, PAPER, AND PAPERBOARD INDUSTRY                      275
             Woodyard/Woodroom                                        277
             Pulp Mill                                                281
             Brown Stock Washers and Screen Room                      287
             Bleaching Systems                                        290
             Evaporation and Recovery                                 293
             Liquor Preparation Area                                  303
             Papermill                                                303
             Steam Plant and Utility Areas                            319
             Recycle of Effluent                                      319
             Chemical Substitution                                    321
          OTHER PRODUCTION PROCESS CONTROLS                           323
             Bleach Systems and Recovery                              323
          END-OF-PIPE TREATMENT TECHNOLOGIES COMMONLY EMPLOYED
            BY THE PULP, PAPER, AND PAPERBOARD INDUSTRY               330
             Preliminary/Primary Treatment                            330
             Biological Treatment                                     331
             Chemically Assisted Clarification                        347
             Filtration                                               361
             Activated Carbon Adsorption                              363
             Foam Separation                                          377
             Microstraining                                           379
             Electrochemical Treatment                                379
             Ion Flotation                                            380
             Air/Catalytic/Chemical Oxidation                         381
             Steam Stripping                                          381
             Ultrafiltration                                          382
             Reverse Osmosis/Freeze Concentration                     383
             Amine Treatment                                          383
             Polymeric Resin Treatment                                384
                                       Vll

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SECTION                                                               PAGE

VIII DEVELOPMENT OF CONTROL AND TREATMENT OPTIONS                     387

          INTRODUCTION                                                387
          BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
            AVAILABLE (BPT)                                           387
             General                                                  387
             Development of Raw Waste Loads                           388
             Development of Final Effluent Characteristics            391
          BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY (BCT)        395
             General                                                  395
          NEW SOURCE PERFORMANCE STANDARDS-CONVENTIONAL
            POLLUTANTS                                                396
             General                                                  396
             Option 1                                                 397
             Attainment of NSPS Option 1                               432
             Option 2                                                 442
             Attainment of NSPS Option 2                               470
             Conventional Pollutant Variability Analysis              470
          TOXIC AND NONCONVENTIONAL POLLUTANT REMOVAL TECHNOLOGY
            ASSESSMENT                                                489
             Chlorophenolics                                          492
             Zinc                                                     504
             Chloroform                                               504
             Ammonia                                                  509
             Color                                                    512


IX   EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION OF
     THE BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
     AVAILABLE EFFLUENT LIMITATIONS GUIDELINES                        517

          GENERAL                                                     517
          REGULATED POLLUTANTS                                        517
          IDENTIFICATION OF THE BEST PRACTICABLE CONTROL
            TECHNOLOGY CURRENTLY AVAILABLE                            517
          BPT EFFLUENT LIMITATIONS                                    518
          RATIONALE FOR THE SELECTION OF THE TECHNOLOGY BASIS
            OF BPT                                                    518
          METHODOLOGY USED FOR DEVELOPMENT OF BPT EFFLUENT
            LIMITATIONS                                               520
          COST OF APPLICATION AND EFFLUENT REDUCTION BENEFITS         522
          NON-WATER QUALITY ENVIRONMENTAL IMPACTS                     522
             Energy                                                   524
             Solid Waste                                              524
             Air and Noise                                            524

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SECTION                                                               PAGE

X    EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION OF
     THE BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
     EFFLUENT LIMITATIONS GUIDELINES                                  525

          GENERAL                                                     525
          REGULATED POLLUTANTS                                        525
             Toxic Pollutants                                         525
          IDENTIFICATION OF THE BEST AVAILABLE TECHNOLOGY
            ECONOMICALLY ACHIEVABLE                                   526
          BAT EFFLUENT LIMITATIONS                                    526
          RATIONALE FOR THE SELECTION OF THE TECHNOLOGY BASIS
            OF BAT                                                    526
          METHODOLOGY USED FOR DEVELOPMENT OF BAT EFFLUENT
            LIMITATIONS                                               529
             Zinc                                                     529
             Trichlorophenol                                          529
             Pentachlorophenol                                        530
          COST OF APPLICATION AND EFFLUENT REDUCTION BENEFITS         530
             Fungicide and Slimicide Substitution                     530
             Zinc Removal                                             530
          NON-WATER QUALITY ENVIRONMENTAL IMPACTS                     530

XI   EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION OF
     BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY EFFLUENT
     LIMITATIONS GUIDELINES                                           533

          GENERAL                                                     533

XII  NEW SOURCE PERFORMANCE STANDARDS                                 535

          GENERAL                                                     535
          REGULATED POLLUTANTS                                        535
             Conventional Pollutants                                  535
             Toxic Pollutants                                         535
             Nonconventional Pollutants                               535
          IDENTIFICATION OF THE TECHNOLOGY BASIS OF NSPS              535
             Conventional Pollutant Control                           535
             Toxic Pollutant Control                                  535
          NEW SOURCE PERFORMANCE STANDARDS                            536
          RATIONALE FOR THE SELECTION OF THE TECHNOLOGY BASIS
            FOR NSPS                                                  536
             Conventional Pollutant Control Technology                536
             Toxic Pollutant Control Technology                       541
          METHODOLOGY USED FOR DEVELOPMENT OF NSPS                    542
             Conventional Pollutants                                  542
             Toxic Pollutants                                         542
          COST OF APPLICATION AND EFFLUENT REDUCTION BENEFITS         544
          NON-WATER QUALITY ENVIRONMENTAL IMPACTS                     544

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SECTION                                                               PAGE

XIII PRETREATMENT STANDARDS FOR EXISTING SOURCES                      545

          GENERAL                                                     545
          REGULATED POLLUTANTS                                        545
          IDENTIFICATION OF THE TECHNOLOGY BASIS OF PRETREATMENT
            STANDARDS FOR EXISTING SOURCES                            545
          PSES                                                        545
          RATIONALE FOR THE SELECTION OF THE TECHNOLOGY BASIS OF
            PSES                                                      548
          METHODOLOGY USED FOR DEVELOPMENT OF PSES                    548
             Zinc                                                     549
             Trichlorophenol                                          549
             PentachJorophenol                                        549
          COST OF APPLICATION AND EFFLUENT REDUCTION BENEFITS         550
             Fungicide and Slimicide Substitution                     550
             Zinc Hydrosulfite Substitution                           550
          NON-WATER QUALITY ENVIRONMENTAL IMPACTS                     550

XIV  PRETREATMENT STANDARDS FOR NEW SOURCES                           553

          GENERAL                                                     553
          REGULATED POLLUTANTS                                        553
          IDENTIFICATION OF THE TECHNOLOGY BASIS OF PRETREATMENT
            STANDARDS FOR NEW SOURCES                                 553
          PSNS                                                        553
          RATIONALE FOR THE SELECTION OF THE TECHNOLOGY BASIS
            OF PSNS                                                   553
          METHODOLOGY USED FOR DEVELOPMENT OF PSNS                    556
          COST OF APPLICATION                                         557
          NON-WATER QUALITY ENVIRONMENTAL IMPACTS                     557

XV   ACKNOWLEDGEMENTS                                                 559

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SECTION                                                               PAGE

APPENDICES

     APPENDIX A - COST, ENERGY, AND NON-WATER
       QUALITY ASPECTS                                                561

          METHODOLOGY FOR DEVELOPMENT OF COSTS                        561
             Introduction                                             561
             Model Mill Approach                                      561
             Mill and Site Specific Cost Factors                      564
             Cost Estimating Criteria for Control and Treatment
               Technologies                                           567
          COSTS FOR IMPLEMENTATION OF BPT                             570
          COSTS FOR IMPLEMENTATION OF BAT OPTIONS                     573
             Toxic Pollutant Control Options                          573
             Nonconventional Pollutant Control Options                576
          COSTS FOR IMPLEMENTATION OF PSES AND PSNS                   582
          COSTS FOR IMPLEMENTATION OF NSPS CONTROL AND TREATMENT
            OPTIONS                                                   583
             Conventional Pollutant Removal                           583
             Toxic Pollutant Removal                                  583
          ENERGY AND NON-WATER QUALITY IMPACTS                        594
             Energy Requirements                                      594
             Air Pollution                                            596
             Noise Potential                                          599
             Solid Waste Generation                                   599
             Implementation Requirements                              605

     APPENDIX B - GLOSSARY                                            607

     APPENDIX C - LEGEND OF ABBREVIATIONS                             625

     APPENDIX D - REFERENCES                                          635
                                 XI

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                            LIST OF TABLES
                              TITLE                                   PAGE
SECTION I
1-1       BPT Effluent Limitations                                      4
1-2       BAT Effluent Limitations                                      6
1-3       BAT Effluent Limitations—Noncontinuous Dischargers           7
1-4       New Source Performance Standards—Conventional Pollutants     8
1-5       New Source Performance Standards—Conventional
          Pollutants—Noncontinuous Dischargers                         9
1-6       New Source Performance Standards—Toxic Pollutants           10
1-7       New Source Performance Standards—Toxic Pollutants—
          Noncontinuous Dischargers                                    11
1-8       Pretreatment Standards for Existing Sources                  13
1-9       Pretreatment Standards for New Sources                       15
SECTION II
II-l      Status of Effluent Limitations Guidelines                    22
I1-2      Response to Data Request                                     32
I1-3      Toxic and Additional Nonconventional Pollutants Under
          Investigation in the Screening Program                       33
I1-4      Subcategory Groups Selected for Screening Program            37
I1-5      Summary of Treatment Type and Percent Differences—
          Contractor Screening for Mills Versus Raw Waste
          Load Basis of BPT                                            38
I1-6      Typical Screening Program Survey                             41
I1-7      Subcategoriration Scheme on Which BPT Was Based and
          the Revised Subcategoriration Scheme                         43
II-8      Verification Compounds—Pulp, Paper, and Paperboard
          Industry                                                     46
II-9      Verification Program Sampling Points                         51
11-10     Typical Verification Sampling Program Survey                 52
                                   xm

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                              TITLE                                   PAGE

11-11     Summary of Internal Standards                                55
11-12     Toxic and Nonconventional Pollutants Selected for
          Analysis During the Long-Term Sampling Program               57
11-13     Summary of Direct Discharging Mills Versus DMR Data
          Collected                                                    62
11-14     Production Process Controls and Effluent Treatment
          Technologies                                                 64
SECTION III
III-l     Bleaching Symbols                                            74
111-2     Summary of All Known Operating Pulp, Paper, and
          Paperboard Mills by EPA Region                               78
III-3     Summary of Method of Discharge and In-Place Technology—
          All Known Operating Mills                                    81
111-4     Estimated Pulp Production - 1977                             84
II1-5     Paper and Paperboard Products of Industry                    85
III-6     Production Statistics—Paper and Paperboard Products
          Industry                                                     86
SECTION V
V-l        Summary Raw Waste Load Data—Dissolving Kraft
          Subcategory                                                 11 3
V-2        Summary Raw Waste Load Data—Market Bleached Kraft
          Subcategory                                                 118
V-3        Summary Raw Waste Load Data—BCT Bleached Kraft
          Subcategory                                                 121
V-4        Summary Raw Waste Load Data—Alkaline-Fine                  125
V-5        Summary Raw Waste Load Data—Unbleached Kraft
          Subcategory                                                 130
V-6        Summary Raw Waste Load Data—Semi-Chemical Subcategory      133
V-7        Summary Raw Waste Load Data—Unbleached Kraft and
          Semi-Chemical Subcategory                                   137
                                   XIV

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                              TITLE                                   PAGE

V-8       Summary Raw Waste Load Data—Dissolving Sulfite Pulp
          Subcategory                                                 139
V-9       Summary Raw Waste Load Data—Papergrade Sulfite
          Subcategory                                                 140
V-10      Summary Raw Waste Load Data—Groundwood-Thermo-
          Mechanical Subcategory                                      149
V-11      Summary Raw Waste Load Data—Groundwood-CHN Papers
          Subcategory                                                 150
V-12      Summary Raw Waste Load Data—Groundwood-Fine Papers
          Subcategory                                                 153
V-13      Summary Raw Waste Load Data-Integrated Miscellaneous
          Mills                                                       157
V-14      Summary Raw Waste Load Data—Deink Subcategory              160
V-15      Summary Raw Waste Load Data—Tissue from Wastepaper
          Subcategory                                                 163
V-16      Summary Raw Waste Load Data—Paperboard from Wastepaper
          Subcategory                                                 164
V-17      Methods of Wastewater Disposal at Self-Contained
          Paperboard from Wastepaper Mills                            169
V-18      Summary Raw Waste Load Data—Wastepaper-Molded Products
          Subcategory                                                 170
V-19      Summary Raw Waste Load Data—Builders' Paper and
          Roofing Felt Subcategory                                    171
V-20      Methods of Wastewater Disposal at Self-Contained
          Builders' Paper and Roofing Felt Mills                      174
V-21      Summary Raw Waste Load Data—Secondary Fibers
          Miscellaneous Mills                                         175
v-22      Summary Raw Waste Load Data—Nonintegrated-Fine
          Papers Subcategory                                          176
V-23      Summary Raw Waste Load Data—Nonintegrated-Tissue
          Papers Subcategory                                          178
V-24      Summary Raw Waste Load Data—Nonintegrated-
          Lightweight Papers Subcategory                              180
                                      XV

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                              TITLE                                   PAGE

V-25      Summary Raw Waste Load Data—Nonintegrated-Filter
          and Nonwoven Papers Subcategory                             181
V-26      Summary Raw Waste Load Data—Nonintegrated-Paperboard
          Subcategory                                                 182
V-27      Summary Raw Waste Load Data—Nonintegrated
          Miscellaneous Mills                                         184
V-2B      Summary of Initial Screening Program Analysis Results       185
V-29      Summary of Screening Analysis Results at 17
          Verification Mills                                          190
V-30      Summary of EPA Regional StA Screening Program Results
          at 42 Mills                                                 191
V-31      Summary of Verification Program Analysis Results
          for Toxic Pollutants                                        194
V-32      Summary of Verification Program Analysis Results for
          Nonconventional Pollutants                                  218
V-33      Summary of Long-Term Sampling Program Analysis Results
          for Toxic Pollutants                                        231
V-34      Summary of Long-Term Sampling Program Analysis Results
          for Nonconventional Pollutants                              232
V-35      Toxic Pollutant Sampling Data Base                          236
V-36      Supplemental Color Data                                     237
V-37      Theoretical Raw Waste Ammonia Load                          238
V-38      Summary of Available Ammonia Data for All Mills Using
          Ammonia as the Chemical Pulping Base                        239
SECTION VI
VI-1      Summary of Parameters Proposed or Promulgated for
          Effluent Limitations Guidelines by Subcategory              245
VI-2      Criteria For Elimination of Toxic Pollutants Based
          on Screening Program Results and Toxic Pollutants
          Eliminated                                                  248
VI-3      Projected Treatability for Verification Program
          Toxic Pollutants                                            250
                                        XVI

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                              TITLE                                   PAGE


VI-4      Toxic Pollutants Eliminated from Assessment Based on
          Verification Program Results—Detected Below Treatability
          Level                                                       253

VI-5      Summary of Toxic Pollutants of Concern By Subcategory       255

VI-6      Summary of Data Assessment-Toxic Pollutants of
          Concern                                                     256

VI-7      Criteria for Elimination of Toxic Pollutants Based on
          Verification Program Results and Toxic Pollutants
          Eliminated                                                  260

VI-8      Exclusion of Toxic Pollutants of Potential Concern
          from Pretreatment Standards                                 263

VI-9      Summary of Influent Concentrations for Resin and Fatty
          Acids and Chlorinated Derivatives for All Verification
          Facilities                                                  265

VI-10     Summary of Effluent Concentrations for Resin and Fatty
          Acids and Chlorinated Derivatives for All Verification
          Facilities                                                  267

VI-11     Summary of Influent Concentrations for Resin and Fatty
          Acids and Chlorinated Derivatives for Verification
          Mills Meeting BPT Effluent Limitations                      269

VI-12     Summary of Effluent Concentrations for Resin and Fatty
          Acids and Chlorinated Derivatives for Verification
          Mills Meeting BPT Effluent Limitations                      270

VI-13     Removals of Resin and Fatty Acids and Chlorinated
          Derivatives                                                 272

SECTION VII

VII-1     Production Process Control Technologies Identified as
          the Best Practicable Control Technology Currently
          Available                                                   276

VIl-2     Production Process Control Technologies Identified as
          the Best Available Technology Economically Achievable       276

VI1-3     Production Process Control Technologies Available for
          Reduction of Effluent Volume and Pollutant Loadings         278

VII-4     Waste Load Reductions From Implementation of Hooker
          APS II and APS III Systems                                  329
                                     xvn

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                              TITLE                                   PAGE


VII-5     Calculated Toxic and Nonconventional Pollutant Removal
          Rates                                                       333

VI1-6     Typical Design Parameters for Activated Sludge Processes    337

VII-7     Oxygen Activated Sludge Treatability ~ Pilot Scale         341

VII-8     Pilot RBC Final Effluent Quality for Bleached Kraft
          Wastewater                                                  343

VII-9     Summary of Chemically Assisted Clarification Technology
          Performance Data                                            349

VII-10    Final Effluent Quality of a Chemically Assisted Clari-
          fication System Treating Bleached Kraft Wastewater          351

VII-11    Final Effluent Quality of a Chemically Assisted Clari-
          fication System Treating Wastewater from a Deink-
          Newsprint Mill                                              352

VII-12    Color and Organic Carbon Removal After Application of
          Massive Lime Treatment                                      355

VI1-13    Color Reductions Achieved After Application of
          Chemically Assisted Clarification With Ferric Sulfate,
          Alum, and Lime                                              358

VII-14    Comparison of Treatment Efficiencies On Kraft Effluents
          by the Application of Chemically Assisted Clarification
          Using Divalent Ions or Trivalent Ions                       359

VI1-15    Lime Treatment of Bleached Kraft Caustic Extract in the
          Presence of Metal Ion                                       360

VI1-16    Removal of BOD, COD, and Phosphate from Chemical
          Pulping Wastewaters at Selected Lime-Magnesia Levels        362

VII-17    TSS Reduction Capabilities and Related Factors for the
          Filtration Technology When No Chemicals Are Used            364

VII-18    TSS Reduction Capabilities and Related Factors for the
          Filtration Technology When Chemicals are Used               365

VII-19    Final Effluent Quality Following Three Layer Pressure
          Sand Filtration of the Effluent From an Aerated
          Stabilization Basin Treating Paperboard From
          Wastepaper Wastewater                                       366
                                       xv m

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                              TITLE
VII-20    Final Effluent Quality Following Deep Bed Sand
          Filtration of the Effluent From an Aerated
          Stabilization Basin and Secondary Clarifier
          Treating Paperboard From Wastepaper Wastewater

VII-21    Final Effluent Quality Following Rapid Gravity Sand
          Filtration of the Effluent From an Activated Sludge
          Plant Treating Paperboard from Wastepaper Wastewater

VII-22    Sand Filtration Results

VI1-23    Results of Pilot-Scale Granular Activated Carbon
          Treatment of Unbleached Kraft Mill Waste
          Powdered Activated Carbon Operating Data On a Chemical
          Plant Wastewater

          Full Scale "PACT" Process Results On  Chemical Plant
          Wastewater

          Results of Pilot-Scale Activated Carbon Treatment of
          Unbleached Kraft Mill Effluent
VII-24


VII-25


VII-26


SECTION VIII

VI11-1    Average Raw Waste Characteristics for the Nonintegrated
          Segment of the Pulp, Paper, and Paperboard Industry

VIII-2    BPT Long-Term Average Final Effluent Characteristics

VII1-3    Summary of NSPS Option 1 Raw Waste Loads

VII1-4    Discharge Monitoring Report Data—Dissolving Kraft
          Subcategory

VI11-5    Discharge Monitoring Report Data—Market Bleached Kraft
          Subcategory

VII1-6    Discharge Monitoring Report Data—BCT Bleached Kraft
          Subcategory

VIII-7    Discharge Monitoring Report Data—Alkaline-Fine

VI11-8    Discharge Monitoring Report Data—Unbleached Kraft
          Subcategory

VIII-9    Discharge Monitoring Report Data—Semi-Chemical
          Subcategory
367




368

369


373


375


376


378





389

394

398


400


401


403

404


406


409
                                    XIX

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                              TITLE                                   PAGE


VIII-10   Discharge Monitoring Report Data—Unbleached Kraft and
          Semi-Chemical Subcategory                                   410

VIII-11   Discharge Monitoring Report Data—Papergrade Sulfite
          Subcategory                                                 411

VIII-12   Discharge Monitoring Report Data—Dissolving Sulfite
          Pulp Subcategory                                            413

VIII-13   Discharge Monitoring Report Data—Groundwood-Thermo-
          Mechanical Subcategory                                      415

VIII-14   Discharge Monitoring Report Data—Groundwood-Fine
          Papers Subcategory                                          416

VIII-15   Discharge Monitoring Report Data—Groundwood-CMN
          Papers Subcategory                                          417

VII1-16   Discharge Monitoring Report Data—Deink Subcategory         418

VIII-17   Discharge Monitoring Report Data—Tissue from Waste-
          paper Subcategory                                           420

VII1-18   Discharge Monitoring Report Data—Paperboard from
          Wastepaper Subcategory                                      421

VIII-19   Discharge Monitoring Report Data—Wastepaper-Molded
          Products Subcategory                                        424

VI11-20   Discharge Monitoring Report Data—Builders' Paper
          and Roofing Felt Subcategory                                425

VIII-21   Discharge Monitoring Report Data—Nonintegrated-Fine
          Papers Subcategory                                          426

VIII-22   Discharge Monitoring Report Data—Nonintegrated-Tissue
          Papers Subcategory                                          427

VI11-23   Discharge Monitoring Report Data—Nonintegrated-
          Lightweight Papers Subcategory                              429

VIII-24   Discharge Monitoring Report Data—Nonintegrated-Filter
          and Nonwoven Papers Subcategory                             430

VIII-25   Discharge Monitoring Report Data—Nonintegrated-
          Paperboard Subcategory                                      431

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VI11-26   NSPS Option 1 Long-Term Average Discharge Characteristics   433

VIII-27   Number of Facilities That Attain BPT and NSPS Option 1
          Final Effluent Characteristics                              434

VIII-28   Percent Reductions Required to Attain NSPS Option 1  BODS
          Final Effluent Characteristics From NSPS Option 1 BOD5_ ~
          Raw Waste Loads                                             435

VII1-29   Percent BODS Reductions Attained at Some Mills Meeting
          BPT BODS. an
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                              TITLE
PAGE
VIII-40   Calculation of Final Effluent Levels for Subcategories
          For Which the NSPS Option 2 Raw Waste BOD5. Concentra-
          tion is Greater Than the NSPS Option 1  Raw Waste BOD5.
          Concentration                                       ~       468

VIII-4T  NSPS Option 2 Long-Term Average Discharge Characteristics   471

VIII-42   Number of Mills Attaining BPT and NSPS Option 2 Final
          Effluent Levels                                             472

VIII-43   Percent Reductions Required to Attain NSPS Option 2 BOD5_
          Final Effluent Characteristics From NSPS Option 2 BOD5_
          Raw Waste Loads                                             473

VIII-44   Distribution of Daily Values About the Estimate of the
          99th Percentile                                             476

VII1-45   Variability Factors for Determining Maximum Day
          Limitations                                                 477

VIII-46   Results of Goodness-of-Fit Tests for Successive 30-Day
          Averages                                                    480

VII1-47   Distribution of 30-Day Averages About the Estimate of
          the 99th Percentile                                         483

VIII-48   Variability Factors for Determining Maximum 30-Day
          Limitations                                                 484

VIII-49   Average Maximum 30-Day and Maximum Day Variability
          Factors for Subsets (1), (2), (3), (4), (5), (6), and
          (7)                                                         487

VIII-50   Summary of NSPS Variability Factors                         490

VIII-51   Summary of Uncorrected Trichlorophenol Results for
          Mills Where Verification and Long-Term Sampling Were
          Conducted and Where Chlorophenolic Biocides Were Not
          Used                                                        494

VIII-52   Summary of Uncorrected Trichlorophenol Results for
          Mills Where Verification and Long-Term Sampling Were
          Conducted and Where Chlorophenolic Biocides Were Used       495

VIII-53   Summary of Uncorrected Pentachlorophenol Results for
          Hills Where Verification and Long-Term Sampling Were
          Conducted and Where Chlorophenolic Biocides Were Not
          Used                                                        496
                                  xx n

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                              TITLE
PAGE
VI11-54   Summary of Uncorrected Pentachlorophenol Results for
          Mills Where Verification and Long-Term Sampling Were
          Conducted and Where Chlorophenolic Biocides Were Used

VI11-55   Summary of Corrected Trichlorophenol Results for Mills
          Where Chlorophenolic Biocides Were Not Used—NCASI Data

VIII-56   Summary of Corrected Trichlorophenol Results for Mills
          Where Chlorophenolic Biocides Were Used—NCASI Data

VI11-57   Summary of Corrected Pentachlorophenol Results for
          Mills Where Chlorophenolic Biocides Were Not Used
          —NCASI Data

VI11-58   Summary of Corrected Pentachlorophenol Results for
          Mills Where Chlorophenolic Biocides Were Used—NCASI
          Data

VIII-59   Summary of Pentachlorophenol (PCP) and Trichlorophenol
          (TCP) Discharge Characteristics for Direct Discharging
          Mills

VI11-60   Summary of Pentachlorophenol (PCP) and Trichlorophenol
          (TCP) Discharge Characteristics for Indirect Discharging
          Mills

VI11-61   Summary of Uncorrected Chloroform Biological Influent
          and Effluent Concentrations (ug/1) from the Verifi-
          cation and Long-Term Sampling Programs (Chlorine
          Bleaching Facilities Only)

VI11-62   Summary of Corrected Chloroform Effluent Data Submitted
          by the NCASI

VIII-63   Maximum Day Chloroform Variability Factors Computed
          Using Uncorrected Data

VI11-64   Predicted Range of Ammonia Raw Waste Load and Final
          Effluent Concentrations

VI11-65   Summary of Anticipated Color Levels After Minimum
          Lime/Alum Coagulation

SECTION IX
IX-1      BPT Effluent Limitations

IX-2      Variability Factors Used in the Development of BPT
          Effluent Limitations
497


499


500



502



503



505



506




507


510


511


513


514



519


523
                                      xxm

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                              TITLE                                   PAGE

SECTION X
X-l       BAT Effluent Limitations                                    527
SECTION XII
XII-1     New Source Performance Standards — Conventional
          Pollutants                                                  537
XI1-2     New Source Performance Standards — Conventional
          Pollutants — Noncontinuous Dischargers                     538
XII-3     New Source Performance Standards — Toxic Pollutants        539
SECTION XIII
XIII-1    Pretreatment Standards for Existing Sources                 546
SECTION XIV
XIV-1     Pretreatment Standards for New Sources                      554
APPENDIX A
A-l       Model Mill Sizes by Subcategory and Discharge Type          562
A-2       Regional Cost Adjustment Factors                            565
A-3       Cost Estimating Criteria                                    568
A-4       Design Criteria for BPT Activated Sludge Treatment —
          Wastepaper-Molded Products Subcategory                      571
A-5       Cost of Implementation of BPT Activated Sludge Treat-
          ment — Wastepaper-Molded Products Subcategory              572
A-6       Design Criteria for Chloroform Control at Nine Mills
          Where Chloroform Volatilization is Inhibited                574
A-7       Cost for Chloroform Control at Nine Mills Where
          Chloroform Volatilization is Inhibited                      575
A-8       Cost for Color Reduction for Direct Dischargers             577
A-9       Costs for Ammonia Removal for Direct Dischargers            581
                                     XXIV

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                              TITLE                                   PAGE


A-10      Costs for Substituting Sodium Hydrosulfite for Zinc
          Hydrosulfite                                                584

A-ll      Design Basis for Estimates of Costs of End-of-Pipe
          Treatment for Attainment of MSPS Options 1 and 2            585

A-12      Cost Summary for NSPS Option 1                               586

A-13      Gross Operation and Maintenance and Energy Costs and
          Savings for NSPS Option 2 Production Process Controls       588

A-14      Cost Summary for NSPS Option 2                              589

A-15      NSPS Option 2 Production Process Controls — Sample
          Cost Calculation                                            591

A-16      Design Parameters for NSPS Option 2 — Example
          Calculation                                                 592

A-17      Cost Summary for NSPS Option 2 Unit Process End-of-Pipe
          Treatment — Example Calculation                            593

A-18      Total Energy Usage at Existing Direct Discharging Mills     595

A-19      Additional Energy Usage at Existing Direct Discharging
          Mills with the Implementation of Color Removal
          Technology                                                  597

A-20      Energy Usage at New Source Direct Discharging Mills         598

A-21      Total Wastewater Solid Waste Generation at Existing
          Direct Discharging Mills                                    601

A-21      Wastewater Solid Waste Generation at New Source Direct
          Discharging Mills                                           602

A-23      Additional Wastewater Solid Waste Generation at Direct
          Discharging Mills with the Implementation of Color
          Removal Technology                                          604
                                  XXV

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                           LIST OF FIGURES

                              TITLE                                   PAGE

SECTION II
II-l      Location of Screening Program Mill Surveys                   40
II-2      Location of Verification Program Mill Surveys                49
SECTION III
III-l     Location of Operating Mills in the Industry                  80
SECTION V
V-l       General Flow Sheet—Pulping and Papermaking Process         104
V-2       Raw Waste Flow Versus Percent Dissolving Pulp—
          Dissolving Kraft Subcategory                                115
V-3       Raw Waste BOD5_ Versus Percent Dissolving Pulp—
          Dissolving Kraft Subcategory                                116
V-4       Raw Waste Data (Flow and BOD£) Versus Percent Softwood
          Used—Dissolving Kraft SubcaFegory                          117
V-5       Raw Waste Flow Versus Percent Softwood Used—Market
          Bleached Kraft Subcategory                                  119
V-6       Raw Waste BOD5 Versus Percent Softwood Used—Market
          Bleached Kraft Subcategory                                  120
V-7       Raw Waste Flow Versus Percent Softwood Used—BCT
          Bleached Kraft Subcategory                                  122
V-8       Raw Waste BOD5. Versus Percent Softwood Used—BCT
          Bleached KrafF Subcategory                                  123
V-9       Raw Waste Flow Versus Percent Softwood Used—Alkaline-
          Fine                                                        126
V-10      Raw Waste BOD5> Versus Percent Softwood Used—Alkaline-
          Fine                                                        127
V-ll      Raw Waste Flow Versus Percent On Site Pulp Production—
          Alkaline-Fine                                               128
V-l2      Raw Waste BODJi Versus Percent On Site Pulp Production—
          Alkaline-Fine                                               129
                                   XXVI 1

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                              TITLE                                   PAGE
V-13      Raw Waste Flow Versus Production—Unbleached Kraft
          Subcategory                                                 131
V-14      Raw Waste BOD5 Versus Production—Unbleached Kraft
          Subcategory                                                 132
V-15      Raw Waste Flow Versus Percent Wastepaper Used—
          Semi-Chemical Subcategory                                   135
V-16      Raw Waste BOD5_ Versus Percent Wastepaper Used—
          Semi-Chemical~Subcategory                                   136
V-17      Effect of Washing Process on Raw Waste BOD^—Paper-
          grade Sulfite Subcategory                 ~                 143
V-18      Effect of Washing Process on Raw Waste Flow—Paper-
          grade Sulfite Subcategory                                   144
V-19      Raw Waste Flow Versus Percent Sulfite Pulp On-Site          145
V-20      Effect of Cooking Process on Raw Waste BOD5.—Paper-
          grade Sulfite Subcategory                                   146
V-21      Effect of Condenser Type on Raw Waste Flow—Paper-
          grade Sulfite Subcategory                                   148
V-22      Raw Waste Flow Versus Percent Groundwood Pulp On
          Site—Groundwood-CMN Papers Subcategory                     151
V-23      Raw Waste BOD5_ Versus Percent Groundwood Pulp On
          Site—Groundwood-CMN Papers Subcategory                     152
V-24      Raw Waste Flow Versus Percent Groundwood Pulp On
          Site—Groundwood-Fine Papers Subcategory                    154
V-25      Raw Waste BOD5_ Versus Percent Groundwood Pulp On Site—
          Groundwood-Fine Papers Subcategory                          155
V-26      Raw Waste Flow Versus Percent Deink Pulp Produced—
          Oeink Subcategory                                           161
V-27      Raw Waste BOD5_ Versus Deink Pulp Produced—Deink
          Subcategory                                                 162
SECTION VII
VII-1     Convert Hydraulic Barking Systems to Dry System             279
VI1-2     Flume Replaced by Mechanical Conveyor                       280
                                  XXVTM

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                              TITLE                                   PAGE

VI1-3     Segregate Woodroom Non-Contact Cooling Water and
          Condensate                                                  282
VI1-4     Reuse of Digester Blow Condensate                           283
VII-5     Reduce Groundwood Thickener Filtrate Overflow               285
VII-6     Pulp Mill Spill Collection—Digester Area                   286
VI1-7     Addition of Third or Fourth Stage Pulp Washer               288
VII-8     Recycle Decker Filtrate                                     289
VI1-9     Cleaner Rejects to Landfill                                 291
VII-10    Jump Stage Washing in Bleach Plant                          292
VII-11    Full Countercurrent Washing in Bleach Plant                 294
VI1-12    Bleachery Jump Stage Washing and Caustic Extraction
          Filtrate Collection—Dissolving Sulfite Pulp                295
VII-13    Complete Reuse of Evaporator Condensate—Kraft and
          Soda Hills                                                  297
VII-14    Replace Barometric Condenser With Surface Condenser         298
VI1-15    Addition of an Evaporator Boilout Tank                      299
VII-16    Neutralization of Spent Sulfite Liquor                      301
VII-17    Spill Collection - Evaporator, Recovery, Causticizing
          and Liquor Storage Areas                                    302
VII-18    Green Liquor Dregs Filter                                   304
VII-19    Lime Mud Storage Pond                                       305
VII-20    Stock Spill Collection, Pulp Bleaching, and Papermachine
          Areas—Papergrade Sul£ite                                   307
VII-21    Stock Spill Collection System—Pulp Bleaching, and
          Dryer Areas—Bleached Kraft and Soda Mills                  308
VI1-22    Stock Spill Collection System—Paper Mill Area—
          Groundwood-CMN or Fine Papers                               309
VII-23    Spill Collection System Color Plant—Alkaline-
          Fine                                                        310
                                   XXIX

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                              TITLE                                   PAGE

VI1-24    Papermill Improvements—Unbleached Kraft                    312
VII-25    New Saveall on Pulp fc Paper Mill Effluents—Builders'
          Paper and Roofing Felt                                      313
VII-26    New Saveall on Papermill Effluents—Wastepaper-Molded
          Products                                                    314
VI1-27    White Water to Vacuum Pumps and Collection Tank for
          Pump Seal Water and Press Effluent                          315
VII-28    Increased White Water Storage Capacity                      317
VII-29    4-Stage Centricleaner System With Elutriation               320
VII-30    Improved Reuse of Clarifier Sludge                          322
VI1-31    Rapson-Reeve Process—Closed Cycle Bleached Kraft
          Pulpmill                                                    325
VII-32    Rapson-Reeve Closed Cycle Mill—Salt Recovery System        327
VII-33    Billerud-Uddeholm Non-Polluting Bleach Plant                386
SECTION VIII
VIII-1    Final Effluent TSS Versus Raw Wastewater BOD5.               392
VIII-2    Final Effluent TSS Versus Final Effluent BOD5 for the
          Groundwood-Fine Papers Subcategory                          469
VI11-3    Average Biological Effluent Chloroform Versus Average
          Biological Influent Chloroform                              508
APPENDIX A
A-l       Time Required to Construct Solids Contact Clarifier/
          Biological System                                           606
                                  XXX

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                              SECTION I

                             CONCLUSIONS

SUBCATEGORIZATION

For the purpose of establishing best  practicable  control  technology
currently   available   (BPT)  effluent  limitations,  best  available
technology economically achievable  (BAT)  effluent  limitations,  new
source   performance  standards  (NSPS),  pretreatment  standards  for
existing sources (PSES), and pretreatment standards  for  new  sources
(PSNS),  EPA  subcategorized  the  pulp, paper, and paperboard and the
builders' paper and board mills point  source  categories  into  three
segments as follows:

     Integrated Segment

          Dissolving Kraft
          Market Bleached Kraft
          BCT (Board, Coarse, and Tissue) Bleached Kraft
          Fine Bleached Kraft
          Soda
          Unbleached Kraft
               o    Linerboard
               o    Bag and Other Products
          Semi-Chemical
          Unbleached Kraft and Semi-Chemical
          Dissolving Sulfite Pulp
               o    Nitration
               o    Viscose
               o    Cellophane
               o    Acetate
          Papergrade Sulfite (Blow Pit Wash)
          Papergrade Sulfite (Drum Wash)
          Groundwood-Chemi-Mechanical
          Groundwood-Thermo-Mechanical
          Groundwood-CMN (Coarse, Molded, and News) Papers
          Groundwood-Fine Papers

     Secondary Fibers Segment

          Deink
               o    Fine Papers
               o    Tissue Papers
               o    Newsprint
          Paperboard from Wastepaper
               o    Corrugating Medium Furnish
               o    Noncorrugating Medium Furnish
          Tissue from Wastepaper
          Wastepaper-Molded Products
          Builders' Paper and Roofing Felt

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     Noninteqrated Segment

          Nonintegrated - Fine Papers
               o    Wood Fiber Furnish
               o    Cotton Fiber Furnish
          Nonintegrated - Tissue Papers
          Nonintegrated - Lightweight Papers
               o    Lightweight Papers
               o    Lightweight Electrical Papers
          Nonintegrated - Filter and Nonwoven Papers
          Nonintegrated - Paperboard

The  subcategorization  scheme from previous Agency rulemaking efforts
in 1974 and 1977  was  revised  based  on  current  information.   EPA
considered various factors including age, size of plant, raw material,
process  employed,  products,  and waste treatability in reviewing the
adequacy of the original subcategorization scheme.

EPA made the following revisions  to  the  original  subcategorization
scheme relating to the integrated segment of the industry: 1) A review
of  available  data  show that no significant differences in raw waste
loads  exist  at  mills  in  the  fine   bleached   kraft   and   soda
subcategories.   Therefore,  BAT effluent limitations, NSPS, PSES, and
PSNS are identical for both subcategories.  However,  because  of  the
familiarity  of permitting authorities and representatives of affected
mills with the original subcategorization scheme and the format of the
Code of Federal Regulations,  EPA decided that the fine bleached  kraft
subcategory  and  the  soda  subcategory  should  remain  as  separate
subcategories and that the BPT effluent  limitations  promulgated  for
those  subcategories  in  1977  should  not  be  revised.   2)  In the
unbleached kraft subcategory, EPA determined  that  higher  raw  waste
loads  occur  at  mills  where bag and other products are manufactured
than at mills where  only  linerboard  is  produced.   Therefore,  two
subgroups  were  established,  bag  and linerboard, with different BAT
effluent limitations, NSPS,  PSES,  and  PSNS.   3)  In  the  original
subcategorization  scheme, there were separate subcategories for mills
where the  sodium  and  ammonia-based  neutral  sulfite  semi-chemical
(NSSC)  pulping  processes are employed.  The Agency determined that a
single new subcategory, semi-chemical, best represents all  variations
of  the  semi-chemical  process.   4)  The  Agency  established  a new
subcategory, the unbleached kraft and semi-chemical subcategory, which
includes those mills originally included in the unbleached  kraft-NSSC
(cross  recovery)  subcategory  and  all  other  mills  where both the
unbleached kraft and any semi-chemical pulping processes are used.  5)
The Agency determined that a single factor, the percentage of  sulfite
pulp  produced  on-site,  is  a better indicator of differences in raw
waste loadings at papergrade sulfite mills than the  type  of  washing
system  or  condensers employed.  Therefore, BAT effluent limitations,
NSPS, PSES, and PSNS were  established  that  are  identical  for  the
papergrade  sulfite  (blow pit wash) and papergrade sulfite  (drum wash)
subcategories.  However, because  of  the  familiarity  of  permitting
authorities  and  representatives  of affected mills with the original
subcategorization scheme  and  the  format  of  the  Code  of  Federal

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Regulations,  EPA  decided that the papergrade sulfite (blow pit wash)
and papergrade sulfite (drum  wash)  subcategories  should  remain  as
separate   subcategories   and   that  the  BPT  effluent  limitations
promulgated for these subcategories in 1977 should not be revised.  6)
BAT, NSPS, PSES, and PSNS regulations were  not  established  for  the
groundwood-chemi-mechanical   subcategory,   one   of   the   original
subcategories for which BPT  effluent  limitations  were  established.
Insufficient data were available to determine the effect of the degree
of chemical usage in the pulping process on raw waste generation.  BAT
permits and NSPS for mills in this subcategory will be determined on a
case-by-case basis.

In the secondary fibers segment, three revisions were made:  1) in the
deink  subcategory,  differences in raw waste loads resulting from the
production  of  fine  papers,  tissue  papers,  and   newsprint   were
recognized,  and  different  BAT effluent limitations, NSPS, PSES, and
PSNS were developed for application at mills where these products  are
manufactured;  2)  a  new subcategory, wastepaper-molded products, was
established to reflect distinct  process  and  wastewater  differences
associated  with  the  manufacture of molded products from wastepaper;
and 3) the paperboard from wastepaper subcategory  was  segmented  and
different effluent limitations and standards were developed to account
for  higher  raw waste loads resulting from the processing of recycled
corrugating  medium.   (EPA  made  this  revision  after  proposal  in
response to public comments.)

In  the nonintegrated segment of the industry, three new subcategories
were established to represent the differences in  the  manufacture  of
specific   products.    The   new   subcategories  are  nonintegrated-
lightweight papers,  nonintegrated-filter  and  nonwoven  papers,  and
nonintegrated-paperboard.  Within the nonintegrated-lightweight papers
subcategory, a further allowance is made to account for the production
of  electrical  grades of paper.  Additionally, the nonintegrated-fine
papers subcategory was subdivided to  account  for  higher  raw  waste
loads  resulting  from  the  use of cotton fibers in the production of
fine papers.  (EPA made this revision after proposal  in  response  to
public comments.)

BPT

BPT   effluent   limitations   were   established  for  the  four  new
subcategories (wastepaper-molded  products,  nonintegrated-lightweight
papers,  nonintegrated-filter  and nonwoven papers, and nonintegrated-
paperboard) and for the two new subcategory subdivisions  (the  cotton
fiber subdivision of the nonintegrated-fine papers subcategory and the
corrugated   medium   furnish   subdivision  of  the  paperboard  from
wastepaper subcategory).   These limitations control three conventional
pollutants: biochemical oxygen demand (BOD£), total  suspended  solids
(TSS), and pH.  BPT effluent limitations are shown in Table 1-1.

Limitations  for  BOD15 and TSS are presented in kilograms of pollutant
per 1,000 kilograms of production (lb/1,000 Ibs).  Production shall be
defined  as   the   annual   off-the-machine   production   (including

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                                                  TABLE  1-1
               Subcategory
               Secondary Fiber* Segment

               Paperboard Fro* Vaatepaper
                 o Corrugating Nediuai Furnish
               Wastepaper-Molded Products

               Nonintegrated Segaent
BPT EFFLUENT LIMITATIONS
 CONTINUOUS DISCHARGERS
(kg/kkg or Its/1000 Ibs)

      Haximum 30-Day Average
           BODS      TSS
                                                                                Maxii
                                                                            BODS
                                                                                        Day
                                                                                       TSS
            2.8
            2.3
4.6
S.8
5.7
4.4
 9.2
10.8










Nonintegrated Fine Papers
o Cotton Fiber Furnish
Nonintegrated- Lightweight
o Lightweight
o Electrical
Nonintegrated-Filter and
Nonwoven Papers
Nonintegrated-Paperboard



9.1
Papers
13.2
20.9

16.3
3.6
BPT EFFLUENT
NONCONT1NUOUS
Annual Average

(ki/kkji or
lbs/1000 Ibs)
Subcategory BODS TSS
Secondary
Paperboard
Fibers Segstent
Froai Wastepaper
o Corrugating Medina Furnish 1.
Wastepaper-Holded Products 1.


6 2.1
3 3.2

13.1 17.4

10.6 24.1
16.7 38.0

13.0 29.6
2.8 6.5
LIMITATIONS
DISCHARGERS
MaxiBHJSi 30-Day Average
(.«/!)
BODS TSS


93 153
27 66

24.3

21.6
34.2

26.6
5.8


MaxiBua Day
(•8/D
BODS


189
51












TSS


306
122
Nonintegrated Segment

Nonintegrated Fine Papers
  o Cotton Fiber Furnish               5.1       7.2
Nonintegrated-Lightweight Papers
  o Lightweight                        7.4       6.0
  o Electrical                        11.6       9.5
Nonintegrated-Filter and
   Nonwoven Papers                     9.1       7.4
Nonintcgrated-Paperboard               2.0       1.6
                      52

                      65
                      65

                      65
                      65
          74

          52
          52

          52
          52
            99

           118
           118

           118
           118
            138

            106
            106

            106
            106

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off-the-machine  coating  where  applicable)  divided by the number of
operating days during that year.  Paper production shall  be  measured
at   the   off-the-machine  moisture  content.   Production  shall  be
determined for each mill  based  on  past  production  rates,  present
trends, or committed growth.

BPT  effluent limitations were based on the anticipated performance of
wastewater  treatment  technology  (either  primary  clarification  or
biological treatment) applied to raw waste loads characteristic of the
subcategory  or  on  transfer  of  technology performance from another
subcategory.

BAT

BAT limitations were established for the following toxic pollutants:

               pentachlorophenol (PCP),
               trichlorophenol (TCP), and
               zinc.

BAT effluent limitations are shown in Table 1-2 and 1-3.

Effluent  limitations  for  the  control  of   pentachlorophenol   and
trichlorophenol   were   established   for   all  subcategories.   The
technology basis of these limitations is the substitution  of  biocide
formulations that do not contain pentachlorophenol and trichlorophenol
for formulations containing these toxic pollutants.

BAT  effluent  limitations  for  zinc  were  established  equal to BPT
limitations  for  the  three  groundwood  subcategories   where   zinc
hydrosulfite  has been used as a bleaching chemical.  Limitations were
based on the precipitation of  zinc  using  lime,  although  the  most
likely technology employed to attain BAT is the substitution of sodium
hydrosulfite for zinc hydrosulfite.

Limitations  for  BODS and TSS are presented in kilograms of pollutant
per 1,000 kilograms of" production (lb/1,000 Ibs).  Production shall be
defined  as   the   annual   off-the-machine   production    (including
off-the-machine  coating  where  applicable)  divided by the number of
operating days during that year.  Paper production shall  be  measured
at  the  off-the-machine moisture content whereas market pulp shall be
measured in air-dry tons (10 percent moisture).  Production  shall  be
determined  for  each  mill  based  on  past production rates, present
trends, or committed growth.  For non-continuous dischargers,  maximum
day effluent concentrations shall apply.

NSPS

Pollutants  regulated  under  NSPS include the conventional pollutants
regulated under BPT (BOD5_, TSS,  and  pH)  and  the  toxic  pollutants
regulated  under  BAT  (pentachlorophenol, trichlorophenol, and zinc).
NSPS effluent limitations are presented in Tables 1-4, 1-5,  1-6,  and
1-7.

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                                 TABLE 1-2

                         BAT EFFLUENT LIMITATIONS
                         (kg/kkg or lbs/1000 Ibs)
                                                Maximum Day
Subcategory
                                          PCP1
          TCP*
                                                          Zinc
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
  o Linerboard
  o Bag
Semi-Chemical
Unbleached Kraft and Seai-Cheaical
Dissolving Sulfite Pulp
  o Nitration
  o Viscose
  o Cellophane
  o Acetate
Papergrade Sulfite4
Groundwood-Thermo-Mechanical
Groundvood-CMN Papers
Groundwood-Fine Papers

Secondary Fibers Segment
Deink
  o Fine Papers
  o Tissue Papers
  o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
  o Corrugating Medium Furnish
  o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
0.0025
0.0019
0.0016
0.0014
0.016
0.012
0.010
0.0088
0.00058  0.00053
0.00058  0.00053
0.0012   0.00043
0.00064  0.00059
0.0030
0.0030
0.0030
0.0033
   *
0.00097
0.0011
0.0010
0.019
0.019
0.019
0.021
   *
0.00088
0.00099
0.00092
0.0030   0.0069
0.0030   0.0069
0.0030   0.0010
0.0030   0.0011

0.00087  0.00030
0.00087  0.00030
0.0026   0.00088
0.0017   0.00060
 NA
 KA
 NA
 NA

 NA
 NA
 NA
 NA

 NA
 NA
 NA
 NA
  *
0.26
0.30
0.27
           NA
           NA
           NA
           HA

           NA
           NA
           NA
           NA
Noninteg rated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
tfonintegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard


0.0018
0.0051
0.0028

0.0059
0.0093

0.0072
0.0016


0.00064
0.0018
0.00096

0.0020
0.0032

0.0025
0 . 00054


NA
NA
NA

NA
NA

NA
NA
^Papergrade Sulfite Equations:

  PCP = 0.00058 exp(0.017x)
  TCP * 0.0036 exp(0.017x)
  Where x equals percent sulfite pulp produced on-site in the final product.

*PCP ^ Pentachlorophenol

2TCP = Trichlorophenol

3Includes Fine Bleached Kraft and Soda subcategories.

^Includes Papergrade Sulfite  (Blow Pit Wash) and Papergrade Sulfite
 (Drum Wash) subcategories.
NA = Not applicable.

-------
                                                        TABLE 1-3

                                                BAT EFFLUENT LIMITATIONS
                                                NONCONTINUOUS DISCHARGERS
                                                  (concentrations mg/I)
                                                                        Maximum Day
Subcategory
                                               PCP1
                         TCP2
                                                 Zinc
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
  o Lioerboard
  o Bag
Semi-Chemical
Unbleached Kraft and Semi-Chemical
Dissolving Sulfite Pulp
  o Nitration
  o Viscose
  o Cellophane
  o Acetate
Papergrade Sulfite4
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers

Secondary Fibers Segment
Deiok
  o Fine Papers
  o Tissue Papers
  o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
  o Corrugating Medium Furnish
  o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
(0.011X41.6)/Y
(0.011X35.4)/Y
(0.011X30.9)/Y

(0.011)(12.6)/Y
(0.011X12.6)/Y
(0.029X10.3)/Y
(0.011)(14.0)/Y

(0.011)(66.0)/Y
(0.011X66.0)/Y
(0.011X66.0)/Y
(0.011)(72.7)/Y
(0.011X23.8)/Y
(0.011)(21.9)/Y
(0.029)(24.4)/Y
(0.029)(24.4)/Y
(0.029)(24.4)/Y
(0.029X25.2)/Y

(0.029)(7.2)/Y
(0.029)(7.2)/Y
(0.029)(21.1)/Y
(0.029)(14.4)/Y
(0.068)(55.1)/Y
(0.068)(41.6)/Y
(0.068)(35.4)/Y
(0.068)(30.9)/Y

(0.010)(12.6)/Y
(0.010)(12.6)/Y
(0.010)(10.3)/Y
(0.010)(14.0)/Y

(0.068)(66.0)/Y
(0.068)(66.0)/Y
(0.068)(66.0)/Y
(0.068)(72.7)/Y
      *
(0.010)(21.1)/Y
(0.010)(23.8)/Y
(0.010X21.9)/Y
(0.068)(24.4)/Y
(0.068)(24.4)/Y
(0.010)(24.4)/Y
(0.010)(25.2)/Y

(0.010)(7.2)/Y
(0.010)(7.2)/Y
(0.010)(21.1)/Y
(0.010)(14.4)/Y
      NA
      NA
      NA
      NA

      NA
      NA
      NA
      NA

      NA
      NA
      NA
      NA
(3.0)(23.8)/Y
(3.0)(21.9)/Y
      NA
      MA
      NA
      NA

      NA
      NA
      NA
      NA
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Noointegrated-Tissue Papers
Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated- Paperboard


(0. 029X15. 2)/Y
(0. 029)(42. 3)/Y
(0. 029X22. 9)/Y

(0.029)(48.7)/Y
(0. 029X76. 9)/Y

(0.029)(59.9)/Y
(0.029)(12.9)/Y


(0.010)(15.2)/Y
(0.010)(42.3)/Y
(0.010)(22. 9)/Y

(0.010)(48.7)/Y
(0.010)(76.9)/Y

(0.010)(59.9)/Y
(0.010)(12.9)/Y


NA
NA
NA

NA
NA

NA
NA
Y * Mill wastewater discharged per ton of product.
NA 3 Not Applicable.

^Papergrade Sulfite Equations:

  PCP = ((0.011X12.67) exp(0.017x))/Y
  TCP = ((0.068X12.67) exp(0.017x))/Y
  Where x equals percent sulfite pulp produced on-site in the final product.

1PCP = Pentachlorophenol

ZTCP = Trichlorophenol

^Includes Fine Bleached Kraft and Soda subcategories.

^Includes Papergrade Sulfite  (Blow Pit Wash) and Papergrade Sulfite
 (Drum Wash) subcategories.

-------
                                   TABLE 1-4

                       NEW SOURCE PERFORMANCE STANDARDS
                            CONVENTIONAL POLLUTANTS
                           (kg/kkg or lbs/1000 Ibs)
Maximum
Subcategory
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
o Linerboard
o Bag
Semi-Chemical
Unbleached Kraft and Seal-Chemical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite*
Groundwood-Therao-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Papers
o Tissue Papers
o Newsprint
Tissue from Wastepaper
Paperboard From Wastepaper
o Corrugating Medium Furnish
o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonintegrated-Fine Papera
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard
pH-Within the range 5.0
30-Day
BODS

8.4
5.5
4.6
3.1

1.8
2.7
1.6
2.1

14.5
15.5
16.8
21.4
*
2.5
2.5
1.9


3.1
5.2
3.2
2.5

2.1
1.4
1.1
0.94


1.9
4.2
3.4

6.7
11.7

8.3
1.9
to 9.0
Average
TSS

14.3
9.5
7.6
4.8

3.0
4.8
3.0
3.8

21.3
21.3
21.3
21.5
*
4.6
3.8
3.0


4.6
6.8
6.3
5.3

2.3
1.8
2.3
1.4


2.3
4.9
2.6

5.2
9.2

6.6
1.5
at all tin*
Maximum Day
BODS

15.6
10.3
8.5
5.7

3.4
5.0
3.0
3.9

26.9
28.7
31.2
39.6
*
4.6
4.6
3.5


5.7
9.6
6.0
4.6

3.9
2.6
2.1
1.7


3.5
7.8
7.0

13.7
24.1

17.1
4.0
BS
TSS

27.3
18.2
14.6
9.1

5.8
9.1
5.8
7.3

40.8
40.8
40.8
41.1
*
8.7
7.3
5.8


8.7
13.1
12.0
10.2

4.4
3.5
4.4
2.7


4.4
9.5
6.0

12.0
21.1

15.0
3.5

*Papergrade Sulfite Equations:

  Maximum 30-day average:

      BODS * 2.36 exp(0.017x)
      TSS~ » 3.03 exp(0.017x)

  Maximum day:

      BOD5 « 4.38 exp(0.017x)
      TSS  = S.81 exp(0.017x)
      Where x equals percent sulfite pulp produced cm-site in the final product

'includes Fine Bleached Kraft and Soda subcategories.

^Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite
 (Drum Wash) subcategories.
                                     8

-------
                                                  TABLE I-5

                                      NEW SOURCE PERFORMANCE STANDARDS
                                           CONVENTIONAL POLLUTANTS
                                          NONCONTIGUOUS DISCHARGERS
Annual Average Maxisnisi 30-Day Average
(kg/kkg or lbi/1000 lb«) Ot/1)
Subcategory BODS TSS
Integrated Segpent
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
o Linerboard
o Bag
Seai-Chenical
Unbleached Kraft and Seai-Chenical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite'
Groundwood-Theftto-Mechanical
Groundwood-CMN Paper*
Groundwood-rine Papers
Secondary Fibera Segaent
Daink
o Fine Papers
o Tiaaue Papers
o Newsprint
Tissue Frosi Wsstepsper
Paperboard From Hastepaper
o Corrugating Mediua Furnish
o Noneorrugating Hediua Furnish
Wastepaper-Holded Products
Builders' Paper and Roofing Felt
Nonlntegrated Segnent
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrsted-Tiaaue Papers
?fonintegrated*Lightveight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Noaintegrated-Paperboard
pH-«ithin

4.4
2.9
2.4
1.6

0.96
1.4
0.84
1.1

7.6
8.1
8.8
11.2
*
1.3
1.3
1.0


1.6
2.7
1.7
1.3

1.1
0.73
0.60
0.49


0.98
2.2
2,3

4.5
7.9

5.6
1.3
the range

7.3
S.O
4.0
2.S

1.6
2.S
1.6
2.0

11.2
11.2
11.2
11.3
*
2.4
2.0
1.6


2.4
3.6
3.3
2.8

1.2
0.97
1.2
0.73


1.2
2.6
1.6

3.2
S.6

4.0
0.94
5.0 to 9,
BODS

40
36
34
29

47
S3
32
4J

39
63
68
78
62
44
34
31


46
62
49
36

161
105
48
83


48
33
43

42
42

42
42
.0 at all tinea
TSS

68
63
37
43

79
98
97
79

87
87
a?
79
80
80
54
46


69
84
92
79

171
137
92
122


36
38
33

33
33

33
33

Maxijsusi Day
(Bg/1)
BODS

74
68
63
S3

87
101
97
84

109
117
127
145
113
81
63
37


36
116
90
67

298
194
89
154


88
60
88

*?
87

87
87

TSS

129
120
109
85

131
188
186
151

166
166
166
131
133
153
104
88


131
162
177
151

328
263
176
234


107
72
76

76
76

76
76

*Papergrade Sulfite (See Equations in Table 1-4).

   BODS Long-Tern Average = Maximum 30-day average +1,91
   TSS Long-Tern Average » Haxiaun 30-day average * 1.90

^Includes Fine Bleached Kraft and Soda subcategories

'Includes Papergrade Sulfite (Blov Pit Wash) and Papergrade Sulfite (Drun Vaaa) subcategories.

-------
                                 TABLE 1-6

                     NEW SOUHCE PERFORMANCE STANDARDS
                             TOXIC POLLUTANTS
                         (kg/kkg or lbs/1000 lb«)
Subcategory
                                                Maxlama Day
                                          PCP»
          TCP2
                  Zinc
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
  o Linerboard
  o Bag
Semi-Chemical
Unbleached Kraft and Seni-Chenical
Dissolving Sulfite Pulp
  o Nitration
  o Viscose
  o Cellophane
  o Acetate
Papergrade Sulfite4
Groundwood-The mo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Paper*

Secondary Fibers Segment
Deink
  o Fine Papen
  o Tissue Papers
  o Newsprint
Tissue From Uastepaper
Paperboard Front Wastepaper
  o Corrugating Medium Furnish
  o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
0.0025
0.0019
0.0016
0.0014
0.00058
0. 00058
0.0012
0.00064
0.0030
0.0030
0.0030
0.0033
'*
0.00097
0.0011
0.0010
0.016
0.012
0.010
0.0088
0 . 00053
0.00053
0.00043
0.00059
0.019
0.019
0.019
0.021
*
0.00088
0.00099
0.00092
0.0030   0.0069
0.0030   0.0069
0.0030   0.0010
0.0030   0.0011

0.00087  0.00030
0.00087  0.00030
0.0026   0.00088
0.0017   0.00060
                    NA
                    NA
                    NA
                    NA

                    NA
                    NA
                    NA
                    NA

                    NA
                    NA
                    NA
                    NA
                     *
                    0.17
                    0.21
                    0.19
NA
NA
NA
NA

NA
NA
NA
NA
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Konintegrated-Lightweight. Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Non integra ted-Paperboard


0.0018
0.0051
0.0028

0.0059
0.0093

0.0072
0.0016


0.00064
0.0018
0.00096

0.0020
0.0032

0 . 0025
0 . 00054


NA
NA
NA

NA
NA

NA
NA
^Papergrade Sulfite Equations:

  PCP = 0.00058 exp(0.0l7x)
  TCP = 0.0036 exp(0.017x)
  Where x equals percent sulfite pulp produced on-site in the  final product.
     = Pentaehlorophenol

2TCP - Trichlorophenol

3Includes Fine Bleached Kraft and Soda subca tegones .

4Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade  Sulfite
  (Drum Wash) subcategories .

NA ~ Not applicable.
                                10

-------
                                             TABLE  1-7

                                 NEW SOURCE PERFORMANCE STANDARDS
                                         TOXIC POLLUTANTS
                                     NONCONTINUOUS  DISCHARGERS
                                        (concentrations rag/1)
                                                                        Maximum  Day
Subcategory
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
o Linerboard
o Bag
Serai-Chemical
Unbleached Kraft and Semi-Chemical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite4
Groundwood-The mo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
De ink
o Fine Papers
o Tissue Papers
o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
o Corrugating Medina Furnish
o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightweigbt Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard
PCP1

(0. 012X50. 7)/Y
(0. 013X36. 6)/Y
(0. 012X31. 7)/Y
(0. 014)(25. 1)/Y

(0. 015X9. 4)/Y
(0. 012)(11. 4)/Y
(0. 041X7. 3)/Y
(0.013)(11.5)/Y

(0. 012X59. 0)/Y
(0.012)(59.0)/Y
(0.012)(59.0)/Y
(0. 012X65. 7)/Y
*
(0.017)(13.8)/Y
(0.016)(16.8)/Y
(0. 016)(15. 4)/Y


(0. 045X15. 9)/Y
(0. 036X19. 5)/Y
(0.044)(16.2)/Y
(0.045)(16.3)/Y

(0. 065X3. 2)/Y
(0. 065X3. 2)/Y
(0. 107X5. 7)/Y
(0.155)(2.7)/Y


(0.047)(9.4)/Y
(0. 039X31. 1)/Y
(0. 035X19. 1)/Y

(0. 037X38. 2)/Y
(0. 033X66. 8)/Y

(0. 037X47. 5)/Y
(0. 033X11. 2)/Y
TCP2

(0. 074)(50. 7)/Y
(0. 077X36. 6)/Y
(0. 076)(31. 7)/Y
(0. 084)(25. 1)/Y

(0. 013X9. 4)/Y
(0. 011X11. 4)/Y
(0.014)(7.3)/Y
(0. 012X11. 5)/Y

(0. 076X59. 0)/Y
(0. 076X59. 0)/Y
(0. 076X59. 0)/Y
(0.075)(65.7)/Y
*
(0.015)(13.8)/Y
(0. 014X16. 8)/Y
(0.014)(15.4)/Y


(0.:04)(15.9)/Y
(0.085)(19.5)/Y
(0.015)(16.2)/Y
(0. 015X16. 3)/Y

(0.023)(3.2)/Y
(0. 023)(3. 2)/Y
(0.037)(5.7)/Y
(0.053)(2.7)/Y


(0. 016X9. 4)/Y
(0.014)(31.1)/Y
(0. 012X19. O/Y

(0. 013X38. 2)/Y
(0.012)(66.8)/Y

(0. 013X47. 5)/Y
(0.012)(11.2)/Y
Zinc

NA
NA
NA
NA

NA
NA
NA
NA

MA
NA
NA
NA

(3.0)(13.8)/Y
(3.0)(16.8)/Y
(3.0)(15.4)/Y


NA
NA
NA
NA

NA
NA
NA
NA


NA
NA
NA

NA
NA

NA
NA
Y = Mill wastewater discharged per ton of product.
NA = Not Applicable

^Papergrade Sulfite Equations:

  PCP = ((0.015X9.12) exp(0.017ic))/Y
  TCP a ((0.094X9.12) exp(0.017x))/Y
  Where x equals percent sulfite pulp produced on-site in the final product.

'PCP = Pentachlorophenol

ZTCP = Trichlorophenol

3Includes Fine Bleached (Craft and Soda subcategories.

4Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite
 (Drum Wash) subcategories.
                                                11

-------
The  basis  for  NSPS for conventional pollutants is commonly employed
production process control technology plus the application of  end-of-
pipe  treatment  of  the  type  that  formed the basis of BPT effluent
limitations (i.e., biological treatment or  primary  treatment).   The
technology  basis for control of toxic pollutants is identical to that
which forms the basis of BAT effluent limitations.

Standards are presented in kilograms of pollutant per 1,000  kilograms
of   production   (lb/1,000  Ibs).    The  production  basis  shall  be
determined in the same manner as described under BAT.

PSES and PSNS

PSES and PSNS are established for the following toxic pollutants:

               pentachlorophenol (PCP),
               trichlorophenol (TCP), and
               zinc.

PSES and PSNS are presented in Tables 1-8 and 1-9.

PSES  and  PSNS  were  based  on  chemical  substitution   to   reduce
substantially  the  discharge  of  PCP,  TCP,  and zinc.  Pretreatment
standards are needed because PCP, TCP, and  zinc  are  known  to  pass
through  publicly  owned  treatment works (POTWs).   Additionally, PSES
and PSNS will  minimize  disposal  'problems  associated  with  sludges
containing zinc.

Pretreatment  standards were established in terms of maximum allowable
discharge concentrations (mg/1).  They include a mathematical  formula
that accounts for flow differences to assure that the standards do not
discourage  the  implementation  of water conservation technologies at
indirect discharging mills.  Mass limitations (kg/kkg or lb/1000 Ib of
product) are also provided as guidance in cases where it is  necessary
to  impose  mass limitations for control of pollutants discharged from
contributing  pulp,  paper,  and  paperboard  mills  to  POTWs.    The
production  basis  shall be determined in the same manner as described
under BAT.

IMPACT OF THE REGULATIONS

Existing Sources

BPT.  Only the wastepaper-molded products subcategory is  expected  to
incur  BPT  compliance costs.  EPA anticipates that four mills  in this
subcategory will be required to spend a total  of  $6.01  million  for
capital  investment  and  a  total  of  $1.86  million  annually  (1978
dollars).  Upon compliance  with  BPT  effluent  limitations  for  the
wastepaper-molded    products,    nonintegrated-lightweight    papers,
nonintegrated-filter and nonwoven papers, and nonintegrated-paperboard
subcategories and for the cotton  fiber  furnish  subdivision  of  the
nonintegrated-fine papers subcategory, EPA estimates that conventional
pollutant  removals  from subcategory/subdivision raw waste discharges

-------
                                             TABLE 1-8

                            PRETREATMENT STANDARDS FOR EXISTING SOURCES
                                       (concentrations mg/I)
                                                                       Maximum Day
Subcategory
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
o Liner board
o Bag
Semi-Chemical
Unbleached Kraft and Semi-Chemical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite4
Groundwood-The mo-Mechanical
Groundvood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Papers
o Tissue Papers
o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
o Corrugating Medina Furnish
o Noncorrugatiog Medium Furnish
Wastepaper-Molded Product*
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightveight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard
PCP1

(0.011)(55.1)/Y
00.011)(41.6)/Y
00. 011)035. 4)/Y
(0.011)(30.9)/Y

(0.011)(12.6)/Y
(0.011)(12.6)/Y
(0.032)(10.3)/Y
00. 011)014. 0)/Y

(0.011)(66.0)/Y
(0.011)(66.0)/Y
(0.011)(66.0)/Y
(0.011)(72.7)/Y
*
(0.011)(21.1)/Y
(0.011)(23.8)/Y
(0.011)(21.9)/Y


00. 032)024. 4)/Y
00. 032)024. 4)/Y
00. 032)024. 4)/Y
(0.032)(25.2)/Y

(0.032)(7.2)/Y
(0.032)(7.2)/Y
(0.032)(21.1)/Y
00. 032)014. 4)/Y


(0.032)(15.2)/Y
00. 032)042. 3)/Y
(0.032)(22.9)/Y

00. 032)048. 7)/Y
(0.032)(76.9)/Y

(0.032)(59.9)/Y
(0. 032)012. 9)/7
TCP2

(0.082)(55.1)/Y
(0. 082)0*1. 6)/Y
00. 082)035. 4)/Y
(0.082)(30.9)/Y

(0.010)(12.6)/Y
(0.010)(12.6)/Y
(0. 010X10. 3)/Y
00. 010)014. 0)/Y

(0. 082)066- 0)/Y
(0.082)(66.0)/Y
(0.082)(66.0)/Y
(0.082)(72.7)/Y
*
(0.010)(21.1)/Y
00.010)(23.8)/Y
(0. 010)021. 9)/Y


00. 082)024. 4)/Y
(0. 082)024. 4)/Y
00. 010)024. 4)/Y
00. 010)025. 2)/Y

00. 010)07. 2)/Y
(0. 010)07. 2)/Y
00. 010)021. 1)/Y
00. 010)014. 4)/Y


(0. 010)015. 2)/Y
(0. 010)042. 3)/Y
00. 010)022. 9)/Y

00. 010)048. 7)/Y
00. 010)076. 9)/Y

00. 010)059. 9)/Y
(0. 010)012. 9)/Y
Zinc

NA
NA
NA
NA

NA
NA
NA
NA

NA
NA
NA
NA

03. 0)021. D/Y
03. 0)023. 8)/Y
03. 0)021. 9)/Y


NA
NA
NA
NA

NA
NA
NA
NA


NA
NA
NA

NA
NA

NA
MA
Y = Mill wastewater discharged per ton of product.
NA = Not Applicable

*Papergrade Sulfite Equations:

  PCP « 0(0.011)012.67) exp00.017x))/Y
  TCP = 000.082)012-67) exp00.017x))/Y
  Where x equals percent sulfite pulp produced on-site in the final product.

'PCP * Pentachlorophenol

'TCP = Trichlorophenol

3Includes Fine Bleached Kraft and Soda subcategories.

'Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite
 ODrun Wash) subcategories.

-------
                                  TABLE 1-8 (continued)

                                PSKS OPTIONAL MASS LIMITS
                                 (kg/kkg or lb/1000 lb«)
                                                                       Max lama Day
Subcategory
Integrated gegaent
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
AlkaliM-Fine8
Unbleached Kraft
o Liaerboard
o Bag
Seoi-Cheaical
Unbleached Kraft and Seal-Chemical
Dissolving Sulfite Pulp
o Nitration
o Viicoie
o Cellophane
o Acetate
Papergrade Sulfite4
Groundwood-The row -Mechanical
Oroundwood-CMN Paper*
Oroundwood-Fine Paper •
Secondary Fibers Segment
Deink
o Fine Papers
o Tiaiue Paper*
o Newsprint
Tissue Fro* Wastepaper
Paperboard Fro* Wastepaper
o Corrugating Medium Furnish
o Noncorrugating Medium Furnish
Waitepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonlntegrated-Flnc Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tlssue Papers
Nonintegrated-Lightwelght Papers
o Lightweight
o Electrical
Nonlntegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard
PCP1

0.0025
0.0019
0.0016
0.0014

O.OOOS8
0.00058
0.0014
0.00064

0.0030
0.0030
0.0030
0.0033
*
0.00097
0.0011
0.0010


0.0033
0.0033
0.0033
0.0034

0.00096
0.00096
0.0028
0.0019


0.0020
0.0056
0.0031

0.0065
0.010

0.0080
0.0017
TCP*

0.019
0.014
0.012
0.011

0.00053
0.00053
0.00043
0.00059

0.023
0.023
0.023
0.025
*
0.00088
0.00099
0.00092


0.0084
0.0084
0.0010
0.0011

0.00030
0.00030
0.00088
0.00060


0.00064
0.0018
0.00096

0.0020
0.0032

0.0025
0.00054
Zinc

NA
NA
NA
NA

NA
NA
NA
NA

NA
NA
NA
NA
NA
0.26
0.30
0.27


NA
NA
::A
NA

NA
NA
NA
NA


NA
NA
NA

NA
NA

NA
NA
T * Mill wastewater discharged per ton of product.
NA * Not Applicable

^Papergrade Sulfite Equations:

  PCP « 0.00058 exp(0.017x)
  TCP a 0.0043 exp(0.017x)
  Where x equals percent sulflte pulp produced on-slte in the final product.

ipCP = Pentacblorophenol

2TCP = Trichlorophenol

'includes Fine Bleached Kraft and Soda subcategories.

4Includes Papergrade Sulfite  (Blow Pit Wash) and Papergrade Sulfite
 (Drum Wash) subcategories.

-------
                                        TABLE  1-9

                         PRETREATMENT STANDARDS FOR  NEW  SOURCES
                                   (concentrations mg/1)
                                                                        Maximum Day
Subcategory
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
o Linerboard
o Bag
Serai-Chemical
Unbleached Kraft and Semi-Chemical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite4
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Papers
o Tissue Papers
o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
o Corrugating Medium Furnish
o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Ligtvtweight Papers
o Lightweight
o Electrical
Monintegrated-Filter
and Nonwoven Papers
Nonintegrated- Paperboard
PCP1

(0. 012X50. 7)/Y
(0. 013X36. 6)/Y
(0. 012X31. 7)/Y
(0. 014X25. 1)/Y

(0. 015X9. 4)/Y
(0. 012X11. 4)/Y
(0. 045X7. 3)/Y
(0.013)(11.5)/Y

(0.012)(59.0)/Y
(0. 012X59. 0)/Y
(0.012)(59.0)/Y
(0.012)(65.7)/Y
*
(0.017)(13.8)/Y
(0. 016X16. 8)/Y
(0.016)(15.4)/Y


(0. 049X15. 9)/Y
(0. 040X19. 5)/Y
(0. 048X16. 2)/Y
(0. 049X16. 3)/Y

(0.072)(3.2)/Y
(0.072)(3.2)/Y
(0. 118X5. 7)/Y
(0.171)(2.7)/Y


(0. 052X9. 4)/Y
(0.044)(31.1)/Y
(0.038)(19.1)/Y

(0.041)(38.2)/Y
(0.037)(66.8)/Y

(0. 040X47. 5)/Y
(0. 037X11. 2)/Y
TCP2

(0.089)(50.7)/Y
(0.093)(36.6)/Y
(0. 092X31. 7)/Y
(0.101)(25.1)/Y

(0.013)(9.4)/Y
(0.011)(11.4)/Y
(0.014)(7.3)/Y
(0. 012X11. 5)/Y

(0.092)(59.0)/Y
(0.092)(59.0)/Y
(0.092)(59.0)/Y
(0.091)(65.7)/Y
*
(0. 015X13. 8)/Y
(0.014)(16.8)/Y
(0-014)(15.4)/Y


(0.126)(15.9)/Y
(0. 103X19. 5)/Y
CO. 015X16. 2)/Y
(0.015)(16.3)/Y

(0.023)(3.2)/Y
(0.023)(3.2)/Y
(0. 037X5. 7)/Y
(0.053)(2.7)/Y


(0.016)(9.4)/Y
(0.014)(31.1)/Y
(0.012)(19.1)/Y

(0. 013X38. 2)/Y
(0.012)(66.8)/Y

(0.013)(47.5)/Y
C0.012)(11.2)/Y
Zinc

NA
NA
NA
NA

NA
NA
NA
NA

NA
NA
NA
NA

(3.0)(13.8)/Y
(3.0)(16.8)/Y
(3.0)(15.4)/Y


NA
NA
NA
NA

NA
NA
NA
NA


NA
NA
SA

NA
NA

NA
SA
Y = Mill wastewater discharged per ton of product.
N'A = Not Applicable

••'•'Papergrade Sulfite Equations:

  PCP = ((0.015X9.12) exp(0.017x))/Y
  TCP = ((0.114X9.12) exp(0.017x))/Y
  Where x equals percent sulfite pulp produced on-site  in  the  final product.

JPCP = Pentachlorophenol

^TCP = Trichlorophenol

""Includes Fine Bleached Kraft and Soda subcategories.

4Includes Papergrade Sulfite  (Blow Pit Wash) and Papergrjiie Sulfite
 (Drum Wdsh) subcalegones.

-------
                                  TABLE 1-9 (continued)

                                PSN8 OPTIONAL MASS LIMITS
                                 (kg/kkg or lb/1000 lb«)
                                                                               Day
Subcategory
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
o Linerboard
o Bag
Seai-Cheaical
Unbleached Kraft and Sen! -Chemical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite4
Groundwood-The mo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Papers
o Tissue Papers
o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
o Corrugating Media* Furniah
o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard
PCP1

0.0025
0.0019
0.0016
0.0014

0.00058
0.00058
0.0014
0.00064

0.0030
0.0030
0.0030
0.0033
*
0.00097
0.0011
0.0010


0.0033
0.0033
0.0033
0.0034

0.00096
0.00096
0.0028
0.0019


0 . 0020
0.0056
0.0031

0.0065
0.010

0.0080
0.0017
TCP*

0.019
0.014
0.012
0.011

0.00053
0.00053
0.00043
0.00059

0.023
0.023
0.023
0.025
*
0.00088
0.00099
0.00092


0.0084
0.0084
0.0010
0.0011

0.00030
0.00030
0.00088
0.00060


0.00064
0.0018
0.00096

0.0020
0.0032

0.0025
0.00054
Zinc

HA
HA
MA
HA

HA
HA
HA
HA

NA
HA
NA
NA
HA
0.17
0.21
0.19


NA
NA
NA
NA

NA
NA
HA
NA


NA
NA
NA

NA
NA

NA
NA
Y = Mill wastewater discharged per ton of product.
NA = Not Applicable

*Pdpergrade Sulfite Equations:

  PCP = 0.00058 exp(0.017x)
  TCP = 0.0043 exp(0.017x)
  Where x equals percent sulfite pulp produced on-site in the final product.

'PCP = Pentachlorophenol

2TCP = Trichlorophenol

3Includes Fine Bleached Kraft and Soda subcategories.

••includes Papergrade Sulfite  (Blow Pit Wash) and Papergrade Sulfite
 (Drum Wash) subcategories.
                                                16

-------
will be 3.7 million kg/yr  (8.1  million  Ibs/yr)  of  BOD5  and  14.2
million  kg/yr  (31.3 million Ibs/yr) of TSS.  EPA does not anticipate
any additional pollutant removals from the corrugating medium  furnish
subdivision  of  the  paperboard from wastepaper subcategory since the
amended BPT effluent limitations  are  less  stringent  than  the  BPT
effluent  limitations  established  in  1974 for the entire paperboard
from wastepaper subcategory.

EPA anticipates that compliance with BPT regulations will require  the
energy  equivalent  of  604 thousand liters  (3800 barrels) of residual
fuel oil per year which is 0.0017 percent of current  industry  usage.
The   Agency  estimates  that  BPT  regulations  will  result  in  the
generation of 100 kkg (110 tons) of wastewater solids  annually  which
is  equal  to  0.0042 percent of current solid waste generation in the
industry.   These  wastewater  solids  have  not  been  classified  as
hazardous under RCRA regulations.

BAT  and  PSES.   No incremental costs are expected as a result of BAT
and    PSES    regulations    controlling    pentachlorophenol     and
trichlorophenol.   A  survey  of  chemical manufacturers shows that no
measurable increase in production costs can be  expected  through  the
use  of  substitute  biocides  that  do  not  contain chlorophenolics.
Therefore, the only incremental costs that might be incurred at  these
mills  as  a  result of implementation of the BAT effluent limitations
and PSES are associated with monitoring for  PCP  and  TCP.   However,
since  monitoring  is  not  required  where  facilities  certify  that
substitute chemicals are  being  used  to  control  PCP  and  TCP  and
substitution  is the technology basis of BAT limitations and PSES, EPA
anticipates that monitoring will rarely be required.

Upon compliance with BAT effluent limitations and PSES, EPA  estimates
that  about  17,100 kg/yr (37,600 Ib/yr) of trichlorophenol and 11,640
kg/yr  (25,600  Ib/yr)  of  pentachlorophenol  will  be  removed  from
industry wastewater discharges.

EPA  estimates that attainment of BAT and PSES regulations controlling
zinc will result in annual compliance costs of $23,300 (1978  dollars)
at  one indirect discharging mill.  All other existing dischargers are
in compliance with the zinc regulations.  EPA estimates that the total
quantity of zinc removed at the one  indirect  discharging  groundwood
mill  where  zinc  hydrosulfite  is  used will be 20,000 kg/yr (44,000
Ib/yr).

EPA anticipates that attainment of BAT effluent limitations  and  PSES
will  result  in no increased energy use nor will it contribute to air
pollution, noise generation,  or solid waste generation.

New Sources

NSPS.  The Agency anticipates that compliance with NSPS will result in
incremental capital costs of $19.9 million and total annual  costs  of
$6.9  million  (1978 dollars) per year for the period between 1985 and
1990 based on the projected production growth rate.  These  costs  are
                                17

-------
expected to cause an average price increase of 1.18 percent.  Based on
this  price  increase,  EPA  estimates that the annual industry growth
rate will drop  marginally  from  3.0  to  2.9  percent.    Substantial
reductions  of  BODS^,  TSS,  and  zinc are ensured while discharges of
trichlorophenol  and  pentachlorophenol  resulting  from  the  use  of
biocides will be virtually eliminated.

EPA  projects  that attainment of NSPS will result in an insignificant
increase in solid waste generation and about a two percent increase in
energy use compared to attainment of BPT effluent limitations.

PSNS.  The technology basis for PSNS is identical  to  the  technology
basis  of  PSES;  therefore,  there  is  no incremental cost, economic
impact, or non-water  quality  environmental  impact  attributable  to
PSNS.
                                18

-------
                              SECTION II

                             INTRODUCTION
PURPOSE AND AUTHORITY

The Federal Water Pollution Control Act Amendments of 1972  (P.L.  92-
500;  the  Act)  established  a  comprehensive program to "restore and
maintain the chemical,  physical,  and  biological  integrity  of  the
Nation's  waters"  (see  section  101(a)).   By July 1,  1977,  existing
industrial dischargers were required to achieve "effluent  limitations
requiring  the  application of the best practicable control technology
currently available"  (BPT) (see section  301(b)(1)(A)).    By  July  1,
1983, these dischargers were required to achieve "effluent limitations
requiring   the   application   of   the   best  available  technology
economically achievable (BAT), which will result in reasonable further
progress toward the national goal  of  eliminating  the  discharge  of
pollutants"    (see   section  301(b)(2)(A)).   New  industrial  direct
dischargers were  required  to  comply  with  new  source  performance
standards (NSPS), established under authority of section 306,  based on
best  available demonstrated technology.  New and existing dischargers
to publicly owned treatment works (POTWs) were subject to pretreatment
standards under sections  307(b)  and  (c)  of  the  Act.   While  the
requirements   for  direct  dischargers  were  to  be incorporated into
National Pollutant Discharge Elimination System (NPDES)  permits issued
under section  402  of  the  Act,  pretreatment  standards  were  made
enforceable    directly   against   dischargers   to   POTWs  (indirect
dischargers).

Although section 402(a)(l) of the 1972 Act authorized the  setting  of
requirements   for  direct  dischargers  on a case-by-case basis in the
absence of regulations, Congress intended that,  for  the  most  part,
control  requirements would be based on regulations promulgated by the
Administrator  of  EPA.   Section  304(b)  of  the  Act  required  the
Administrator  to  promulgate  regulations  providing  guidelines  for
effluent limitations setting forth the degree  of  effluent  reduction
attainable through the application of BPT and BAT.  Moreover,  sections
304(c)  and  306  of  the Act required promulgation of regulations for
NSPS, and sections 304(f), 307(b), and 307(c) required promulgation of
regulations  for  pretreatment  standards.   In  addition   to   these
regulations  for designated industry categories,  section 307(a) of the
Act  required  the  Administrator  to  promulgate  effluent  standards
applicable  to  all dischargers of toxic pollutants.  Finally, section
501(a) of the  Act  authorized  the  Administrator  to  prescribe  any
additional  regulations  "necessary  to carry out his functions" under
the Act.

The Agency was unable to promulgate  many  of  these  toxic  pollutant
regulations  and guidelines within the time periods stated in the Act.
In  1976,  EPA  was  sued  by  several  environmental  groups  and,  in
settlement  of  this  lawsuit,  EPA  and  the  plaintiffs  executed  a
"Settlement  Agreement,"  which  was  approved  by  the  Court.   This


                                 19

-------
Agreement  required  EPA to develop a program and adhere to a schedule
for promulgating, for 21 major industries,  BAT  effluent  limitations
guidelines,   pretreatment   standards,  and  new  source  performance
standards for 65 toxic pollutants and classes of toxic pollutants (see
Natural Resources Defense Council, Inc. v. Train, 8 ERC  2120  (D.D.C.
1976), modified, 12 ERC 1833 (D.D.C.  1979)).(1)(2)

On  December  27,  1977, the President signed into law the Clean Water
Act of 1977 (P.L. 95-217).  Although this law makes several  important
changes  in  the  Federal  water  pollution  control program, its most
significant feature is its incorporation into the Act of many  of  the
basic elements of the Settlement Agreement program for toxic pollution
control.    Sections  301(b)(2)(A)  and  301(b)(2)(C)  of  the  Act now
require the achievement by  July  1,   1984,   of  effluent  limitations
requiring  application of BAT for "toxic" pollutants, including the 65
"priority"  pollutants  and  classes  of  pollutants  which   Congress
declared  "toxic"  under  section  307(a) of the Act.  Likewise, EPA's
programs  for  new  source  performance  standards  and   pretreatment
standards  are  now  aimed  principally  at  toxic pollutant controls.
Moreover, to strengthen the toxics control program, Congress  added  a
new  section  304(e)  to  the  Act,  authorizing  the Administrator to
prescribe what have been termed "best management practices (BMPs)"  to
prevent  the  release  of  toxic  pollutants  from  plant site runoff,
spillage or leaks, sludge or waste disposal,   and  drainage  from  raw
material  storage  associated with, or ancillary to, the manufacturing
or treatment process.

The 1977 Amendments added Section 301(b)(2)(E)  to the Act establishing
"best conventional pollutant control technology" [BCT] for  discharges
of  conventional  pollutants  from  existing industrial point sources.
Conventional  pollutants  are  those  defined  in  Section   304(a)(4)
[biological  oxygen demanding pollutants (i.e., BOD5_), total suspended
solids (TSS), fecal coliform, and pH], and any  additional  pollutants
defined  by the Administrator as "conventional"  [e.g., oil and grease;
see 44 FR 44501, July 30, 1979].

BCT is not an additional limitation but replaces BAT for  the  control
of conventional pollutants.  In addition to other factors specified in
section  304(b)(4)(B),  the  Act  requires  that  BCT  limitations  be
assessed in light of a two part "cost-reasonableness" test.   American
Paper  Institute v. EPA, 660 F.2d 954 (4th Cir.  1981).  The first test
compares the cost for private  industry  to  reduce  its  conventional
pollutants  with  the  costs to publicly owned treatment works (POTWs)
for  similar  levels  of  reduction  in  their  discharge   of   these
pollutants.   The  second  test  examines  the  cost-effectiveness  of
additional industrial  treatment  beyond  BPT.    EPA  must  find  that
limitations are  "reasonable" under both tests before establishing them
as BCT.  In no case may BCT be less stringent than BPT.

EPA  published   its  methodology  for carrying out the BCT analysis on
August 29, 1979  (44 FR 50732).  In the case mentioned above, the Court
of Appeals  ordered  EPA  to  correct  data  errors  underlying  EPA's
calculation  of  the  first  test,  and to apply the second cost test.
                                 20

-------
(EPA had argued that a second cost test was not required.)  The Agency
has recently developed a revised BCT methodology  (see  47  FR  49176,
October 29, 1982) .

For  non-"toxic", non-"conventional" pollutants, sections 301(b)(2)(A)
and (b)(2)(F) require achievement of BAT effluent  limitations  within
three  years  after their establishment, or July 1, 1984, whichever is
later, but not later than July 1, 1987.

STATUS OF THE EFFLUENT LIMITATIONS GUIDELINES

The effluent limitations guidelines program for the pulp,  paper,  and
paperboard  point  source  category  has  been  active since 1972.  In
proposing and then promulgating effluent limitations and standards for
the pulp, paper, and paperboard point source category, EPA conducted a
two phase study.  Phase I included certain portions  of  the  industry
where pulp bleaching is not employed.  Phase II included the remaining
portions  of  the  point  source  category.   Additionally, the Agency
promulgated effluent limitations and standards for the builders' paper
and board mills point source category.

The timing and status  of  the  effluent  limitations  guidelines  and
standards  that  have  been  issued  vary for the industry as shown in
Table II-l.   EPA  promulgated  BPT,  BAT,  NSPS,  and  PSNS  for  the
builders'  paper  and  roofing felt subcategory of the builders' paper
and board mills point source category on May 9, 1974  (39 FR 16578;  40
CFR  Part 431, Subpart A).(3) EPA promulgated BPT, BAT, NSPS, and PSNS
for the unbleached kraft, sodium-based neutral sulfite  semi-chemical,
ammonia-based  neutral sulfite semi-chemical, unbleached kraft-neutral
sulfite semi-chemical (cross recovery), and paperboard from wastepaper
subcategories of the pulp, paper, and paperboard point source category
on May 29, 1974  (39 FR 18742; 40 CFR Part 430, Subparts A-E).(4) These
five subcategories comprise Phase I.   EPA  promulgated  BPT  for  the
dissolving  kraft,  market bleached kraft, BCT (paperboard, coarse, and
tissue) bleached kraft, fine bleached kraft, papergrade sulfite  (blow
pit   wash),  dissolving  sulfite  pulp,  groundwood-chemi-mechanical,
groundwood-thermo-mechanical, groundwood-CMN  papers,  groundwood-fine
papers,  soda,  deink, nonintegrated-fine papers, nonintegrated-tissue
papers, tissue from wastepaper, and  papergrade  sulfite   (drum  wash)
subcategories of the pulp, paper, and paperboard point source category
on  January 6,   1977  (42  FR 1398; 40 CFR Part 430, Subparts F-U).(5)
These 16 subcategories comprise Phase II.

Several industry members challenged  the  regulations  promulgated  on
May 29, 1974, and January 6, 1977.  These challenges were heard in the
District  of  Columbia  Circuit of the United States Court of Appeals.
The promulgated regulations were upheld in  their  entirety  with  one
exception.   The  Agency  was  ordered  to  reconsider  the  BPT  BOD5_
limitation for acetate grade pulp production in the dissolving sulfite
pulp subcategory (Weyerhaeuser Company, et al. v. Costle, 590  F.  2nd
1011;  D.C.  Circuit1978).(6) In response to this remand, the Agency
proposed BPT regulations for acetate  grade  pulp  production  in  the
dissolving   sulfite   pulp  subcategory  on  March 12,  1980  (45  FR


                                21

-------
                                                                       TAltl.E  I I-I
                                                        TIMING AND STATUS OF  IIFKI.UENT LIH1TATIONS
Sul.cat t'gory/Rrgii lj>l|°»	
Dissolving Kliifl
M.irkol Bl<-dH_      C<
                                                                                          	Promulgated Regulation*
                                                                                                   "
                                                                                                   Convents
2/19/76  2/19/76
2/19/76  2/19/76
2/19/76  2/19/76
2/19/76  2/19/76  2/19/76
2/19/76  2/19/76  2/19/76
                  2/19/76
           .Sii/(He  (Blow Pit Wdsh)
           Sulfite  (Drua Wash)
DiBsolving Sulfile  Pulp
Drink
Noniiitpgrrftcd-Fiiie  Papers
Noli 1 nlTitrated -Tissue  Papers
Tissue fr'rugi W.istepaper
  BPCTCA                        2/19/76
  BATF.A & NSPS                  2/19/76
  PSF.S & PSNS
UnMrji-ar<1 from  Waslepaprr
  BPCTCA, n/MKA  & NSPS
  PSKS & PSNS
1/15/74  1/15/74
Bui Idem' PJ|«T  and  Roofing Kelt
  BPCTCA, BATI .  K  NSPS         1/14/74
  PSES & PSNS
         1/14/74
1/15/74
1/14/74
5/29/74   5/29/74
 5/9/74    5/9/74
                 5/29/74
                  5/9/74
                     BPCTCA. BATEA, &
                     NSPS settJeablr solid*
                     Halts were also
                     promulgated.

-------
15952).(7) EPA is currently assessing the costs and  economic  impacts
associated   with   attainment   of   the   proposed  BPT  limitation.
Promulgation of this rule will occur at a later date.

EPA published proposed effluent limitations guidelines for  BAT,  BCT,
NSPS,  PSES,  and  PSNS  for  the  pulp, paper, and paperboard and the
builders' paper and board mills point source categories in the Federal
Register on January 6,  1981  (46  FR  1430).   (8)  At  the  time  of
proposal,  the  subcategorization  scheme  was  modified to include 25
subcategories in the pulp, paper, and paperboard industry.

SCOPE OF THIS RULEMAKING

The Clean Water Act  of  1977  expanded  the  requirements  for  water
pollution  control  in  the  pulp, paper, and paperboard industry.  In
EPA's initial rulemaking (May 1974 and  January  1977),  emphasis  was
placed  on  the achievement of BPT, BAT, and NSPS based on the control
of familiar, primarily conventional pollutants, such as BOD, TSS,  and
pH.   In 1977, EPA also proposed PSES based on compliance with general
prohibitive waste provisions  (42 FR 6476; 40  CFR  Part  128).(9)  By
contrast,  in  this  round  of  rulemaking, EPA's efforts are directed
toward instituting  BCT  and  BAT  effluent  limitations,  new  source
performance standards, and pretreatment standards for existing and new
sources  that  will  result  in reasonable further progress toward the
national goal of eliminating the discharge of all pollutants.

In  general,  BCT  represents  the   best   control   technology   for
conventional  pollutants  that  is  reasonable  in  cost  and effluent
reduction benefits.  It replaces BAT for conventional pollutants.  BAT
represents, at a minimum,  the best economically achievable performance
in any industrial category or subcategory and,  as  a  result  of  the
Clean  Water Act of 1977,  emphasis has shifted to control of toxic and
nonconventional  pollutants.    New   source   performance   standards
represent  the  best  available demonstrated technology for control of
all pollutants.  Pretreatment standards for existing and  new  sources
represent  the best economically achievable performance for control of
pollutants  that  pass  through,  interfere  with,  or  are  otherwise
incompatible with the operation of POTWs.

As  a  result  of  the  Clean  Water  Act of 1977, all pollutants were
divided into three categories: (a) conventional pollutants, (b)  toxic
pollutants,  and  (c)  nonconventional  pollutants.   Included  in the
conventional pollutant category are 5-day  biochemical  oxygen  demand
(BOD^),  total  suspended  solids (TSS), pH, oil and grease, and fecal
coliform.  BOD^, TSS, and pH are controlled for all  subcategories  of
the  pulp,  paper,  and  paperboard industry by BPT and NSPS.  EPA has
recently proposed  a  revised  BCT  methodology  in  response  to  the
American  Paper  Institute v. EPA decision mentioned previously.  That
rulemaking included a reproposal of  BCT  limitations  for  the  pulp,
paper,  and  paperboard  industry.  This document does not address the
proposed BCT effluent limitations.
                                23

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The toxic pollutants consist of the 65 classes of pollutants listed in
the Settlement Agreement between EPA and the Natural Resources Defense
Council,  Inc.  (NRDC).(l) These pollutants are controlled by BAT, NSPS,
PSES,  and PSNS.   The list of 65 toxic pollutants and classes of  toxic
pollutants  potentially includes thousands of specific pollutants; the
expenditure of resources in government and private laboratories  would
be   overwhelming   if  analyses  were  attempted  for  all  of  these
pollutants.  Therefore, in order to make the task more manageable, EPA
selected 129 specific toxic pollutants for study  in  this  rulemaking
and  other  industry  rulemakings.(10)  The  criteria for selection of
these 129  pollutants  included  frequency  of  occurrence  in  water,
chemical  stability  and  structure,  amount of the chemical produced,
availability of  chemical standards for measurement, and other factors.
Since initiation of this rulemaking  effort,  three  toxic  pollutants
were    removed    from    the   list   of   129   toxic   pollutants:
dichlorodifluoromethane, trichlorofluoromethane, and  bis-chloromethyl
ether  (46  FR  2266,  January  8,   1981, and 46 FR 10723, February 4,
1981).

Nonconventional  pollutants are  those  not  included  in  one  of  the
previous  categories  of pollutants.  Discharge of these pollutants in
this category may be  industry-specific  and,  if  warranted,  may  be
regulated.   In  addition  to  industry-specific  compounds,  chemical
oxygen  demand  (COD),  ammonia,  and   color   were   nonconventional
pollutants  investigated  by  the  Agency  during  this  study.  These
pollutants are controlled by BAT and NSPS regulations, if appropriate.

SUMMARY OF METHODOLOGY

Introduction

EPA's  implementation  of  the  Act  required  a  complex  development
program,   described  in  this  section and subsequent sections of this
document.  Initially, because in  many  cases  no  public  or  private
agency  had  done  so, EPA and its laboratories and consultants had to
develop  analytical  methods  for  toxic   pollutant   detection   and
measurement,  which  are discussed below.  EPA then gathered technical
data about the industry, which are also summarized  in  this  section.
With these data, the Agency proceeded to develop final regulations.

First,   EPA  studied  the  pulp,  paper,  and  paperboard  industry to
determine  whether  differences  in  raw  materials,  final  products,
manufacturing  processes,  equipment,  age  and  size of manufacturing
facilities, water  use,  wastewater  constituents,  or  other  factors
required   the   development  of  separate  effluent  limitations  and
standards of performance for different segments (subcategories) of the
industry.  This study required the identification  of  raw  waste  and
treated  effluent  characteristics,  including:   a)  the  sources and
volume of water used, the manufacturing processes  employed,  and  the
sources  of  pollutants  and wastewaters within the plant,  and b) the
constituents of wastewaters, including  toxic  pollutants.   EPA  then
identified  the constituents of wastewaters which should be considered
for effluent limitations guidelines and standards of performance.
                                 24

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Next,  EPA  identified  several   distinct   control   and   treatment
technologies,  including  both  in-plant and end-of-pipe technologies,
which are in use or capable of being used to control  or  treat  pulp,
paper,  and  paperboard industry wastewaters.  The Agency compiled and
analyzed historical and newly generated data on the  effluent  quality
resulting  from  the application of these technologies.  The long-term
performance, operational limitations, and reliability of each  of  the
treatment and control technologies were also identified.  In addition,
EPA  considered  the  non-water quality environmental impacts of these
technologies,  including  impacts  on   air   quality,   solid   waste
generation, and energy requirements.

The  Agency  then  estimated  the  costs of each control and treatment
technology for the  various  industry  subcategories  from  unit  cost
curves  developed  by  standard engineering analysis as applied to the
specific pulp, paper, and paperboard wastewater characteristics.   EPA
derived   unit   process   costs   from  model  plant  characteristics
(production and flow) applied to  each  treatment  process  unit  cost
curve     (i.e.,     activated     sludge,     chemically     assisted
clarification/sedimentation,  granular  activated  carbon  adsorption,
mixed  media  filtration).   These unit process costs were combined to
yield total cost at each treatment level.  The  Agency  confirmed  the
reasonableness  of this methodology by comparing EPA cost estimates to
treatment system costs supplied by the industry.

Upon consideration of these factors, as more  fully  described  below,
EPA identified various control and treatment technologies as BPT, BAT,
NSPS,  PSES, and PSNS.  The final regulations, however, do not require
the installation of any particular technology.  Rather,  they  require
achievement  of  effluent  limitations  representative  of  the proper
application of  these  technologies  or  equivalent  technologies.   A
mill's  existing  controls  should  be  fully  evaluated, and existing
treatment systems fully optimized, before commitment  to  any  new  or
additional end-of-pipe treatment technology.

To  assemble  the necessary data to allow promulgation of BPT effluent
limitations, pretreatment standards, and NSPS for the pulp, paper, and
paperboard industry, twelve major tasks were completed, including:

1.    evaluation of existing data,

2.    development of a data request program to obtain new information,

3.    completion of a screening program,

4.    completion of an  industry  profile  and  a  review  of  industry
     subcategorization

5.    completion of a verification program,

6.    analysis of data from a long-term sampling program,
                                25

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7.   development of a program for collection and analysis of discharge
     monitoring data,

8.   analysis of information gathered  during  the  supplemental  data
     acquisition program,

9.   evaluation of PCB data,

10.  review of data obtained from industry comments  on  the  proposed
     regulation,

11.  determination and analysis of appropriate treatment  and  control
     alternatives, and

12.  development and analysis of cost and energy data.

EPA completed several of the above-mentioned tasks to allow the Agency
to respond fully to comments on  the  proposed  rules.   EPA  obtained
additional data on the presence and variability of toxic pollutants in
raw  wastes  and treated effluents by conducting a long-term (23 week)
sampling and analysis program at a deink and  a  fine  bleached  kraft
mill (Task 6).  The Agency used data for the deink mill to support the
PCB  effluent  limitations  and NSPS that EPA proposed concurrent with
the final regulations discussed in this document.  The  data  for  the
fine  bleached  kraft  mill  were  gathered to investigate further the
variability of biological treatment in removing  chloroform;  however,
as  described  herein, EPA decided to withdraw the proposed chloroform
limitations.

EPA  also  obtained  (1)  discharge  monitoring  reports  (DMRs)  from
Regional  and  State  permitting  authorities to update its records to
include the most recent available data (Task  7)  and  (2)  additional
conventional  pollutant data under the authority of section 308 of the
Act to broaden and update our existing data base  on  the  variability
associated with wastewater treatment systems (Task 8).  EPA used these
data,  as well as data on PCP and TCP that became available during the
PCB/chloroform sampling, to verify the accuracy of the  analyses  done
prior to proposal.

Industry, in some cases, provided comments on our proposed regulations
that  included effluent data on the discharge of toxic pollutants.  In
many cases, data were provided in a format  that  did  not  allow  for
proper  analysis  by  the  Agency.   In those instances, EPA requested
additional information in a format that  would  allow  the  Agency  to
include the data when developing the final regulations (Task 10).

Existing Data Evaluation

To  assess  existing data on pollutants and their control/reduction in
the pulp, paper, and paperboard industry, several  data  sources  were
investigated,   including  a)  the  EPA's  administrative  record,  b)
information acquired from  State  regulatory  agencies,  EPA  regional
offices, and research facilities, and c) the literature.
                                 26

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Administrative  Record.   EPA  reviewed the administrative records for
the previous effluent limitations  guidelines  studies  of  the  pulp,
paper,  and  paperboard  and the builders' paper and board mills point
source categories for information on:

o the use of chemical additives,

o the use or suspected presence of the 129 toxic pollutants,

o the use or suspected presence of other  (nonconventional) pollutants,

o available production process controls, and

o available effluent treatment techologies.

Regulatory Agencies  and  Research  Facilities.   During  the  initial
months  of  the  project,  EPA  determined  that  the State regulatory
agencies and the EPA regional offices had very  few  past  or  ongoing
projects that related to the toxic pollutants and the pulp, paper, and
paperboard  industry.   The  State  of Wisconsin and EPA, however, had
recently completed a study that deals with toxic pollutants  found  in
the  discharges  from  pulp, paper, and paperboard mills.(10)  Results
show  that  pulp,  paper,  and  paperboard  mill  effluents  contained
numerous organic compounds which are not on EPA's list of 129 specific
toxic pollutants.

In  addition, representatives of several research and other facilities
were contacted to obtain  all  available  information  on  ongoing  or
unpublished work.  Facilities contacted included:
University of Washington
College of Forest Resources
Seattle, Washington

Washington Department of
Fisheries Laboratory
Quilcene, Washington

Simpson Paper Company
Anderson, California

University of California Forest
Products Laboratory
Richmond, California

State University of New York
College of Environmental Science
and Forestry
Syracuse, New York
B.C. Research, Inc.
Vancouver, B.C.
Institute of Paper Chemistry
Appleton, Wisconsin
Forest Products Laboratory
Madison, Wisconsin

University of Toronto
Toronto, Canada

Pulp & Paper Research Institute
of Canda
Point Claire, Quebec

HSA Reactors Ltd.
Toronto, Canada
                    Lundberg Ahlen, Inc.
                    Richmond (Vancouver), Canada
                                 27

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The  Literature.  The Agency reviewed data available in the literature
to identify which of the  129  toxic  pollutants,   if  any,  might  be
present in the wastewaters discharged from pulp,  paper, and paperboard
mills.   This  review  also included a similar investigation of other,
nonconventional, pollutants.  Specifically, the materials,  chemicals,
and processes that might contribute to the discharge of both toxic and
nonconventional pollutants were identified.  Also,  data were sought on
technologies  available  to remove or control the 129 toxic pollutants
and nonconventional pollutants under investigation.   Several automated
document data bases were searched to identify relevant literature that
included:

o    The  Department  of  Commerce/National  Oceanic  and  Atmospheric
     Administration's  Environmental  Data Service (Environmental Data
     Index - ENDEX and the Oceanic Atmospheric Scientific  Information
     System - OASIS),

o    University microfilm's xerographic dissertation abstract  service
     (DATRIX II),

o    Environment Canada's Water Resources  Document  Reference  Center
     through Canada's Inland Waters Directorate (WATDOC), and

o    The Institute of Paper Chemistry's  Abstract  Service  (PAPERCHEM
     and Chemical Abstracts).

Through  these  services,  over  one million articles/papers and 3,500
environmental data files were identified.  Those that appeared  to  be
relevant were obtained and reviewed.

Also, several other summary documents were reviewed, including a) work
conducted  by  the  Pulp  and Paper Research Institute of Canada, b) a
report entitled, "Multi-Media Pollution Assessment in Pulp, Paper, and
Other Wood Products Industry," prepared for the U.S. EPA by  Battelle-
Columbus  Laboratories,  December 1976, (11), c)  the U.S. EPA's Office
of  Research  and  Development  Publication  Summary   (December  1976,
Cincinnati, Ohio), d) Environment Canada's Publication Summary of work
conducted  under  the  Canadian  Pollution Abatement Research Program,
March 1977 and March 1978, and e) "A position  paper  documenting  the
toxicity of pulp and paper mill discharges and recommending regulatory
guidelines and measurement procedures," prepared for the Canadian Pulp
&  Paper  Association  by  B.C.  Research,  Vancouver,  B.C.,  Canada,
December 1974.

Through these reviews, several compounds on the toxic pollutant  list,
as  well  as  certain  nonconventional pollutants known to be toxic to
aquatic organisms, were noted as being present in the  discharge  from
pulp,  paper, and paperboard mills.(12) As a result of this review, 14
additional compounds were added  to  the   list  of  pollutants  to  be
studied  including  xylene, 4 resin acids, 3 fatty acids, and 6 bleach
plant derivatives.
                                 28

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Data Request Program

To develop an up-to-date profile of the pulp,  paper,  and  paperboard
industry,  data  from previous effluent limitations guidelines studies
were  supplemented  by  undertaking  a  new  data   request   program.
Information  was collected on age and size of facilities, raw material
usage, production processes employed, wastewater characteristics,  and
methods of wastewater control and treatment.

Data Request Development.  The data request program was developed with
considerable  input  from  industry representatives.  It was initially
envisioned that a separate survey form would be developed for each  of
eight  basic  types  of  manufacturing  facilities:   kraft  and soda,
sulfite,  groundwood,  deink,  NSSC  and  CMP/TMP,   paperboard   from
wastepaper,  builders'  paper  mills,  and nonintegrated mills.  After
numerous discussions with industry  representatives,  it  was  decided
that  only  two survey forms would be developed for the basic types of
manufacturing facilities:(13)

               (1)  Multiple Pulping/Integrated Mills, including

                    Kraft and Soda Mills
                    Sulfite Mills
                    Groundwood Mills
                    Deink Mills
                    NSSC and CMP/TMP Mills
                    Paperboard from Wastepaper Mills
                    Builders' Paper Mills

               (2)  Nonintegrated Mills, including production of

                    Fine Papers
                    Coarse Papers
                    Paperboard
                    Tissue Papers and
                    Other Products

The data request program was developed through coordination  with  the
American   Paper  Institute  (API)  BAT  Task  Group.   This  industry
committee was formed to interact with  EPA  during  the  BATEA  review
project  and  included  representatives  from individual companies and
technical associations.  The committee participated in the review  and
development  of the survey forms and had considerable input into their
content.  EPA made revisions to the data request forms  in  accordance
with discussions at three API BAT Task Group meetings.

The  final  data  request  forms included two parts:  Part I requested
information required for selecting mills for the verification sampling
program;  Part  II  requested  information  needed  for   a   complete
assessment of the industry profile and subcategorization scheme.  When
EPA  representatives  sought input from the industry task group on the
proper number of mills  that  should  receive  a  data  request  form,
representatives  of both large and small mills recommended 100 percent
                                 29

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coverage of the industry.  Therefore,  under the authority  of  section
308  of  the  Act,  data  requests were sent to representatives of all
known operating pulp, paper, and paperboard mills during the last week
in September of 1977.  The responses to Parts I  and  II  were  to  be
completed and returned to the Agency in mid-November of 1977 and early
January of 1978, respectively.

Because  the  data  request forms were complex, representatives of the
National Council of the Paper Industry for Air and Stream Improvement,
Inc.  (NCASI) requested that  representatives  of  the  EPA  attend  a
meeting  on October 6, 1977, in Chicago, Illinois, to answer questions
from mill representatives about  the  forms.   As  a  result  of  this
meeting,   an   errata   sheet   was   prepared   and  distributed  to
representatives of mills who had received the data request forms.(14)

Throughout the response period industry representatives asked numerous
questions related to production information, raw material utilization,
process chemicals,  and  process  description.   Agency  personnel  or
representatives  continually  worked  with  industry  to  ensure  that
questions were correctly interpreted.

Representatives of the surveyed mills  could  request  that  EPA  hold
certain  information  confidential.   They  were  also allowed to send
copies of their completed forms to the NCASI and, where this was done,
EPA representatives were able to communicate with  representatives  of
NCASI regarding individual survey responses.

Data  Processing  System.  Since EPA expected to receive 700 responses
to the data request, the Agency developed a multi-phase procedure  for
receiving  and processing responses.  The first step in the processing
system was the development of mill codes to ensure  anonymity  and  to
facilitate  computer  analysis of data obtained.  Other steps included
data input, data verification, and data processing.

As responses to the data requests were received, they were  dated  and
logged into the data processing system.  Since nonstandard and lengthy
responses  were  anticipated,  the survey forms were manually reviewed
before input into the data processing  system.   This  review  ensured
consistency in the data input format and reasonableness of responses.

In  the  review  for  reasonableness,  numeric responses totally out of
line with expected values were either reconciled with other  responses
relating  to  a  specific mill request or the respondent was contacted
for clarification.  The same  procedure  was  followed  for  responses
which indicated a misunderstanding or misinterpretation of a question.
It  was  necessary  to  contact  representatives  of  approximately 35
percent of the mills from which data request forms  were  received  to
verify responses.

Responses  were stored as they appeared on the original survey form or
in coded form.  If a question requiring a numeric response (i.e., year
or quantity) was answered but included a written explanation,  a  code
was  inserted  in  the  data  base  that  indicated  the  presence  of
                                 30

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additional information.  A similar code was used to indicate an answer
that had been calculated by  the  reviewing  engineer  (these  answers
usually  consisted  of  conversions  to  standard  units).   Codes for
"unknown"  or  "not  available"  information  were  also  utilized  as
appropriate.    All  codes  and notes indicating additional information
were retrievable during the data analysis phase.

Data Verification and Editing Techniques.   Information  contained  in
the  data files was verified by comparing the printed output file copy
with the original data request responses.   Data  files  were  updated
according to the verified printouts.

Response  to  Data Request.  The response rate for both the integrated
and nonintegrated data request forms was good.  The  total  number  of
operating  mills  completing  forms  and  the  percentage of the total
operating mills that this represented are shown in Table II-2.

An additional summary was prepared showing  facilities  that  did  not
respond to the data request or were not sent a survey form.  A profile
of  these  mills  was  developed  with  respect to raw material usage,
manufacturing    processes,    products    manufactured,     wastewater
characteristics, and the type of effluent discharge.  This profile was
prepared   by   utilizing   readily   available   sources,   including
representatives of  the  facilities,  EPA  Regional  personnel,  State
permitting   officials,   existing  files,  literature,  and  industry
directories.   These  new  data  were  incorporated  into  the  overall
industry profile.

Screening Program

As  a result of the Settlement Agreement, the EPA was to determine the
presence or absence of 65 toxic pollutants or classes of pollutants in
industrial  effluent  discharges.   Prior  to  the  technical  studies
required,  EPA  expanded  the list of "priority pollutants" to include
129 specific toxic pollutants.(10) Based on the  information  gathered
in   the   literature   review,   EPA   identified  an  additional  14
nonconventional pollutants of concern specific to the pulp, paper, and
paperboard industry.

The screening program was established to  determine  the  presence  or
absence  of the 129 toxic and 14 additional nonconventional pollutants
listed in Table I1-3 in pulp, paper, and paperboard wastewaters.   The
analysis  procedures  used  during screening, outlined in Sampling and
Analysis Procedures for Screening of Industrial Effluents for Priority
Pollutants"  (EPA,  Cincinnati,  Ohio,  April,   1977)   and   Analysis
Procedures  for Screening of Pulp, Paper, and Paperboard Effluents for
Nonconventional Pollutants~TEPA. Washington,  D.C.,  December,  1980),
allow  for  calculation  of  the  approximate  quantity  of  toxic and
nonconventional pollutants present in wastewaters.  (15)(16)  Specific
criteria  were  developed  for  selecting sampling mills so that these
facilities would be representative of  the  entire  pulp,  paper,  and
paperboard industry.
                                 31

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                              TABLE II-2

                       RESPONSE TO DATA REQUEST
Number of operating mills sent surveys:                642
Number of operating mills returning surveys:           610
Percentage response:                                     95%

Method of Discharge - Responding Operating Mills

Direct Dischargers:                                    319
Indirect Dischargers:                                  221
Combined Indirect and Direct Dischargers:               18
Self-Contained:                                         52
                                  32

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                                                                                TABLE  II-3
                                        TOXIC AND ADDITIONAL NONCONVENTIONAL POLLUTANTS UNDER  INVESTIGATION IN THE SCREENING PROGRAM
CO
CO
                          1.    *acenaphthenp
                          2.    *acrolein
                          ).    *acrylonitrile
                          4.    *benzene
                          5.    *bpnzidine
                          6.    *carhon tetrachloride
                               (tptrachloromethane)

                          *CIILORIJ4ATED JENZENES (other than DICHLOROBEN7F.NES)
                          7.    chlorobenezene
                          8.    1 ,2,4-trichlorobrnzme
                          9.    hrxachlorobenzrne

                          ••''CHLORINATED ETHANES
                          10.
                          1 I.
                          12.
                          13.
                          14.
                          15.
                          16.
 , 2-d i chl o roe th vS|>pcific compounds and chpmical classes as  listpd  in  the  consent  decrpe.

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                                                                    TABLE M-3 (Continued)

                    *IIALOETHERS  (other than  those listed elsewhere)             *PHTHALATE ESTERS
OJ
40.  4-rhlorophenyl phenyl ether
41.  4-bromophenyl phenyl ether
42.  his(2-chtoroisopropyl) ether
43.  bis(2-chloroethoxy) methane

'HALOMKraANES (other than those listed elsewhere)

44.  methylene chloride (dichloromethane)
45.  methyl chloride (chloromethane)
46.  methyl bromide (bromomethane)
47.  bromoform (tribromomethane)
48.  di< hlorobromomethane
49.  trichlorofluoromrthane
50.  dichlorodifluororaethane
51.  chlorodibromomethane

52.  *hexachlorobutadiene
53.  *hexachlorocyclopentadiene
54.  *isophorone
55.  *naphthalene
56.  v'ni t robenzene

*NJTROPHENOLS

57.  2-nitrophenol
58.  4-nitrophetiol
59.  *2 ,4-dinitrophenol
60.  4,6-dinitro-o-cresol

•'NITROSAMINES

61.  N-nitrosodimethytnmine
62.  N-nitrosodiphenylamine
63.  N-nitrosodi-n-propylamine

64.  '''pentochlorophenol
65.  ^phenol
66.  bis(2-ethylhexyl) phthalate
67.  butyl benzyl phthalate
68.  di-n-butyl phthalatr
69.  di-n-octyl phthalate
70.  diethyl phthalate
71.  dimethyl phthalate

*POLYKUCLEAR AROMATIC HYDROCARBONS

72.  benzo|aJanthracene (1,2-benzanthracene)
73.  benzo(a)pyrene (3,4-ben7.opyrene)
74.  3,4-benzo fluoranthene
75.  benzo|klfluoranthene (11,12-benzo flnoranthene)
76.  chrysone
77.  acenaphthylene
78.  anthracene
79.  benzo[ghiJperylene ( 1,12-benzoperylene)
80.  fluorene
81.  phenanthrene
82.  dibenzo(a,h]anthracene (1,2,5,6-dibenzanthrarene)
83.  indenof1,2,3-cdlpyrene (2,3-o-phenylenepyrene)
84.  pyrene

85.  *tetrachloroethylene
86.  *toluene
87.  *trichloroethylene
88.  *vinyl chloride (chloroethylene)

PESTICIDES AND METABOLITES

89.  *alHrin
90.  *dieldrin
91.  *chlordane (technical mixture & metabolites)
                    ''•'Specific compounds and chemical classes as listed in the consent decree.

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                                                                       TABLE II-3 (Continued)
CO
cn
*DDT AND METABOLITES

92.  4,4'-DDT
93.  4,4'-DDE (p,p'-DDX)
94.  4,4'-DDD (p,p'-TDE)

*ENDOSULFAN AND METABOLITES

95.  o-endosulfan
96.  B-endosulfan
97.  endosulfan sulfate

*ENDRIN AND METABOLITES

98.  endrin
99.  endrin aldehyde

*HEPTACHLOR AND METABOLITES

100. heptachlor
101. heptachlor epoxide

*HEXACHLOROCYCLOHEXANE (all isomers)

102. o-BHC
103. B-BHC
104. y-BHC (lindane)
105. 6-BHC

*POLYCHLORINATED BIPHENYLS (PCB's)

106. PCB-1242 (Arochlor 1242)
107. PCB-1254 (Arochlor 1254)
108. PCB-1221 (Arochlor 1221)
109. PCB-1232 (Arochlor 1232)
110. PCB-1248 (Arochlor 1248)
111. PCB-1260 (Arochlor 1260)
112. PCB-1016 (Arochlor 1016)
                                                                                   113. *toxaphene
                                                                                   114. ^antimony (total)
                                                                                   115. *arsenic (total)
                                                                                   116. *asbestos (fibrous)
                                                                                   117. *berylliura (total)
                                                                                   118. *cadmium (total)
                                                                                   119. *chromiura (total)
                                                                                   120. *copper (total)
                                                                                   121. *cyanide (total)
                                                                                   122. *1ead (total)
                                                                                   123. *mercury (total)
                                                                                   124. *nickel (total)
                                                                                   125. *selenium (total)
                                                                                   126. *sllver (total)
                                                                                   127. ^thallium (total)
                                                                                   128. *zinc (total)
                                                                                   129. 2,3,7,8-tetrachlorodtbenzo-p-dioxin (TCUD)

                                                                                   ADDITIONAL NONCONVENT10NAL POLLUTANTS
130.       abietic acid
131.       dehydroabietic acid
132.       isopimaric acid
133.       priraaric acid
134.       oleic acid
135.       Ijnoleic acid
136.       linolenic acid
137.       9,10-cpoxystcaric acid
138.       9,10-dichlorostearic acid
139.       monochlorodehydroabietic aciH
140.       dichlorodehydroabietic aciH
141.       3,4,5-trichloroguaiacol
142.       tetrachloroRuaiacol
143.       xylenes
                       *Specific compounds and chemical classes as listed in the consent decree.

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Mill  Selection for Sampling.   A primary goal in mill selection was to
group mill types so that selected mills would be representative of the
entire pulp,  paper, and paperboard industry.   The  15  mill  groupings
developed are presented in Table 11-4.

EPA determined that one mill representative of each of these groupings
would  be  sampled during the screening program.  To ensure that mills
would be representative of current industry  practice,  the  following
four criteria were used to select mills:

     o    the mill should be a direct discharging mill to  obtain  the
          maximum  amount of data (both raw waste and treated effluent
          data),

     o    a biological treatment system should be employed at the mill
          if BPT limitations were based on  biological  treatment;  if
          BPT  limitations were based on primary treatment, the system
          could be a primary treatment system,

     o    the flow and BOD5_ raw wastewater characteristics of the mill
          should approximate the raw wastewater levels that formed the
          basis of BPT effluent  limitations  for  the  specific  mill
          grouping   (to  ensure  that  the  selected  mill  would  be
          representative of the industry grouping), and

     o    the manufacturing process should be  representative  of  the
          respective mill grouping.

Based  upon  these  criteria,   mills  were  selected  for 11 of the 15
industry groupings.  Table I1-5 presents a summary  of  the  treatment
systems  employed,  and  the  raw  waste  characteristics at screening
program mills.  Information is also presented on  raw  waste  loadings
used  in  the  development of BPT effluent limitations for the 11 mill
groupings.  Raw wastewater characteristics at  some  of  the  selected
mills  did  not  approximate  the  raw wastewater characteristics that
formed the basis of BPT effluent limitations as closely as other mills
in the grouping.  EPA  selected  these  mills  for  inclusion  in  the
screening  program  because they satisfied all four selection criteria
better than other mills.

Because of  insufficient  data,  representative  mills  could  not  be
selected for the following industry groupings:

               Nonintegrated-Coarse Papers,
               Nonintegrated-Specialty Papers (I),
               Nonintegrated-Specialty Papers (II), and
               Builders' Paper and Roofing Felt.

For  these  industry  groupings,  EPA  recognized that additional data
would become available as  a  result  of  the  data  request  program.
Therefore,  screening  program  visits  to  facilities  in  additional
industry groupings were delayed until these data could be obtained and
evaluated.
                                 36

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                                   TABLE II-4

                SUBCATEGORY GROUPS SELECTED FOR SCREENING PROGRAM
^Bleached Kraft 	 Fine Papers
^Bleached Kraft 	 BCT/Market Pulp/Dissolving
-'••Unbleached Kraft
^Unbleached Kraft/Neutral Sulfite Semi-Chemical (Cross Recovery)
*Neutral Sulfite Semi-Chemical
*Sulfite
*Groundwood 	 Fine Papers
*Deink
^Nonintegrated	Fine Papers
^Nonintegrated	Tissue Papers
 Nonintegrated	Coarse Papers
 Nonintegrated	Specialty Papers (I)
 Nonintegrated	Specialty Papers (II)
*Paperboard from Wastepaper
 Builders' Paper and Roofing Felt


'"Screened during initial contractor screening studies.
                                       37

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                                                      TABLE  II-5

                                   SUMMARY OF TREATMENT  TYPE AND  PERCENT  DIFFERENCES
                              CONTRACTOR SCREENING  FOR MILLS VERSUS  RAW WASTE  LOAD BASIS  OF BPT


                                                                                         Percent  from BPT RWL
    Subcategory	Treatment Type	Flow	BODS

    Fine Bleached Kraft                          ASB w/  Polishing Pond                    + 32%          + 11%
    Bleached Kraft - BCT/Market                  ASB w/  Polishing Pond                    +3%          + 16%
    Unbleached Kraft                             ASB                                     - 25%          - 21%
    Unbleached Kraft/Neutral Sulfite             ASB                                     -  5%          - 13%
       Semi-Chemical (Cross Recovery)
    Neutral Sulfite Semi-Chemical                ASB w/  Polishing Pond                       0%          + 40%
    Sulfite                                      ASB                                     + 14%          -  6%
    Groundwood                                   Activated Sludge                        +9%          - 11%
    Deink                                        Activated Sludge                        - 14%          - 29%
    Nonintegrated - Fine                         ASB                                     +9%          +4%
    Nonintegrated - Tissue                       Primary Treatment                       + 16%          + 32%
    Paperboard from Wastepaper                   Activated Sludge                           7%          - 14%
co

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After completion of the 11 sampling visits, funding for  this  project
was  depleted  due  to  delays  of  supplemental  appropriations  from
Congress.  Therefore, the screening  program  was  delayed  until  the
necessary funding could be allocated.

Supplemental  Screening Surveys.  In addition to the initial screening
program surveys, EPA Regional Surveillance and  Analysis  field  teams
surveyed  an  additional 47 mills to provide supplemental information.
The analytical procedures used in the analysis of samples  were  those
detailed   in  Sampling  and  Analysis  Procedures  for  Screening  of
Industrial Effluents for Priority Pollutants (EPA,  Cincinnati,  Ohio,
April,  1977).(15)  Therefore,  the  results  are  comparable to those
resulting from the 11 contractor screening surveys.

As explained later in this section, at a total  of  17  mills  sampled
during  the  verification  program,  processes were employed that were
characteristic of the four mill groupings not included in the  initial
contractor   screening  program.   These  mills  were  included  in  a
supplemental screening effort during the verification program.

Figure II-l shows the location of the 58 mills sampled as part of  the
screening program.

Sampling  Program.   Three  sample locations for each mill were chosen
for the sampling program:  a) the raw process  water  prior  to  water
treatment, b) the raw wastewater discharge t'o the wastewater treatment
system,  and  c)  the  final  effluent  from  the wastewater treatment
system(s).

The raw process water was selected to obtain background  concentration
levels  for  any toxic pollutants present in the water supply prior to
use at the mill.  The raw wastewater was sampled to  provide  data  on
the  toxic pollutants attributable to the industrial process that were
being discharged  to  the  wastewater  treatment  system.   The  final
effluent  was  sampled to determine the presence and quantity of toxic
pollutants remaining after wastewater treatment.

Prior to the sampling program,  a  "Screening  Program  Work  Booklet"
detailing  the  specific  procedures  of the program was prepared.(17)
These procedures were derived from and are  consistent  with  Sampling
and  Analysis  Procedures  for  Screening  of Industrial Effluents for
Priority Pollutants (EPA, Cincinnati, Ohio,  April,  1977).  (15)  The
screening  surveys  conducted  by  the  contractor  during the initial
screening program included collecting both composite and grab  samples
during  the  3-day  survey.   Composite  sampling  was conducted for a
period of 72  consecutive  hours  at  the  raw  wastewater  and  final
effluent  sampling  locations.  Grab samples were collected once daily
at these two locations.  A grab sample of the raw  process  water  was
also taken on the second day of the sampling survey.  Table I1-6 shows
the  work  items  included during a typical screening sampling program
survey.
                                 39

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         <   \
                                 .
                                    --
                          •

SCREENING PROGRAM SURVEYS
SUPPLEMENTAL AGENCY SURVEYS
                     FIGURE n - I
LOCATION OF SCREENING PROGRAM
                   MILL SURVEYS

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                                                            TABLE I1-6

                                               TYPICAL SCREENING PROGRAM SURVEY
Day I of the Survey
	Day 2 of the Survey
Day 3 of the Survey	Day 4 of the Survey	
1.   Meet with mill personnel
     and discuss Ltie program

2.   Select sample locations

3.   Set up automatic samplers

4.   Collect all grab samples
     required

5.   Take pll aud temperature
     readings at each sample
     location twice during
     24 hours

6.   Check automatic samplers
     periodically and keep
     composi I*" sample container
     iced
    1.   Check automatic
        samplers

    2.   Collect all grub
        samples required

    3.   Take pH and tempera-
        ture readings at each
        sample location twice
        during 24 hours

    4.   Check automatic samplers
        periodically and keep
        composite sample container
        iced
1.   Check automatic
     samplers

2.   Collect all grab
     .samples required

3.   Take pH and tempera-
     ture readings at each
     sample location twice
     during 24 hours

4.   Check automatic samplers
     periodically and keep
     composite sample container
     iced
1.    Distribute 72-hour com-
     posite between the re-
     quired composite samples

2.    Break down automatic
     samplers

3.    Final meeting with mill
     personnel to wrap up
     the survey

4.    Pack the samples and
     equipment for shipment

5.    Ship samples to the
     appropriate analytical
     laboratory

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To minimize biochemical  degradation  of  the  sample,   the  composite
sampler  jar was packed in ice during the 72-hr sampling period.  Grab
samples were collected and immediately packed in ice.    All  composite
samples  were  also  packed  in  ice immediately after the appropriate
containers were filled  at  the  end  of  the  72-hr  period  at  each
location.

Split  Sampling  Program.    At each mill sampled,  the screening survey
team also split samples, both grab  and  composite,   for  analysis  by
representatives  of the National Council of the Paper Industry for Air
and Stream Improvement, Inc.   (NCASI).   The  bottles  for  the  NCASI
samples were prepared and delivered to each mill by NCASI personnel in
Gainesville, Florida.  For these split samples, mill personnel assumed
responsibility  for  the bottles prior to and immediately after sample
collection.  At most of the mills sampled, a member of the mill  staff
was present during sample collection.

Sample  Analysis  Procedures.   The  screening  program  samples  were
analyzed in accordance with EPA  procedures.   The  organic  compounds
were  analyzed  by  gas chromatography/mass spectrometry (GC/MS). (15)
Resin acids, fatty acids,  and bleach plant derivatives  were  analyzed
in  accordance  with Analysis Procedures for Screening oJE Pu 1 p, Paper,
and  Paperboard  Effluents  for   Nonconventional   Pollutants   (EPA,
Washington,   D.C.,  December,  1980).(16)  These  procedures   involve
derivatization of the acid extract with a methylating agent  prior  to
analysis by GC/MS.

Metals were analyzed by  the following method(s):

o    beryllium,  cadmium,   chromium,  copper,  nickel,  lead,  silver,
     arsenic,  antimony, selenium, and thallium were first analyzed by
     flameless atomic adsorption (AA).  If the  metal  was  above  the
     dynamic range of the flameless AA, the metal was then analyzed by
     flame AA.

o    zinc was analyzed by flame AA.

o    mercury was analyzed by cold vapor flameless AA.

o    cyanide was analyzed in accordance with the total cyanide  method
     described in the  14th Edition of Standard Methods.  (18)

Industry Profile and Review of_ Subcategorization

Earlier  efforts  to  develop  a  profile  of  the  pulp,  paper,  and
paperboard  industry  resulted  in  establishing  the  original   (BPT)
subcategories  shown   in  Table  II-7.   During the screening program,
available data and newly obtained information resulting from the  data
request  program  were  reviewed  to  develop a revised profile of the
pulp, paper, and paperboard  industry.   This  review  recognized  such
factors  as  plant size, age, location, raw material usage, production
process  controls  employed,  products  manufactured,   and   effluent
treatment employed.
                                 42

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                                 TABLE 11-7

             SUBCATEGORIZATION SCHEME ON WHICH BPT WAS BASED AND
                    THE REVISED SUBCATEGORIZATION SCHEHI
BPT Subcategories
Pulp, Pager, and Paperboard

PhaseI

Unbleached Kraft
Neutral Sulfite Semi-Chemical - Ammonia
Neutral Sulfite Semi-Chemical - Sodium
Unbleached Kraft/Neutral Sulfite
  Semi-Chemical (Cross Recovery)
Paperboard From Wastepaper

Phase II

Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Fine Bleached Kraft
Papergrade Sulfite
 o Blow Pit Wash (plus allowances)
Papergrade Sulfite
 o Drum Wash (plus allowances)
Dissolving Sulfite Pulp
 o Nitration
 o Viscose
 o Cellophane
 o Acetate
             Chemi-Mechanical
             ThenBO-Mecbanical
             CMN Papers
             Fine Papers
                                             Revised Subcategories
                                             Integrated Segment

                                             Dissolving Kraft
                                             Market Bleached Kraft
                                             BCT Bleached Kraft
                                             Fine Bleached Kraft
                                             Soda
                                             Unbleached Kraft
                                               o Linerboard
                                               o Bag
                                             Semi-Chemical
                                             Unbleached Kraft and Serai-Chemical
                                             Dissolving Sulfite Pulp
                                               o Nitration
                                               o Viscose
                                               o Cellophane
                                               o Acetate
                                             Papergrade Sulfite (Blow Pit Wash)
                                             Papergrade Sulfite (Drum Wash)
                                            *Grouadwood - Cheni-Mechanical
                                             Groundwood - Thenno-Mechanical
                                             Groundwood - CMN Papers
                                             Groundwood - Fine Papers
Croundwood
Groundwood
Groundwood
Groundwood
Soda
Deink
Nonintegrated-Fine Papers
Nonintegrated-Tissue Papers
Tissue From Wastepaper
Secondary
                                                              Segment
Bui Idlers'  Paper and Bo_a rd _Mi lls
Phase I

Builders'  Paper and Roofing Felt
                                             Deink
                                               o Fine Papers
                                               o Tissue Papers
                                               o Newsprint
                                             Tissue From Wastepaper
                                             Paperboard From Wastepaper1
                                               o Corrugating Medium Furnish
                                               o Noncorrugating Medium Furnish
                                             Wastepaper-Molded Products
                                             Builders' Paper and Roofing Felt

                                             Monintegrated Segment

                                             Noniategrated - Fine Papers1
                                               o Wood Fiber Furnish
                                               o Cotton Fiber Furnish
                                             Nonintegrated - Tissue Papers
                                             Nonintegrated - Lightweight Papers
                                               o Lightweight
                                               o Electrical
                                             Nonintegrated-Filter and Nonwoven
                                               Papers
                                             Nonintegrated-Paperboard

                                             Mill Groupings

                                           **Integrated Miscellaneous, including:
                                               o Alkaline-Miscellaneous
                                               o Kenwood Pulping
                                           "•'^'Secondary Fiber Miscellaneous
                                           **Nonintegrated Miscellaneous

*  In subsequent Tables information on Groundwood-Chemi-Mechanical mills is
   included with information on Integrated Miscellaneous mills.
** Groupings of miscellaneous mills - not Subcategories.

1  These Subcategories were subdivided after the Verification Program in response
   to industry comments.

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As  part  of  this  updated  industry-wide  survey,  EPA  reviewed the
original subcategorizaton scheme using  the  more  comprehensive  data
obtained  during  the screening program, the data request program, and
related efforts.  As a result,   a  new  subcategorization  scheme  was
developed   and   is   also   shown   in  Table  I1-7.   This  revised
subcategorization better reflects the industry as it now operates with
respect to raw materials, processing sequences, and product mix.   EPA
used  the revised subcategorization scheme in designing and conducting
the  verification  program,  as  discussed  below.   A  more  detailed
explanation  of  the  rationale  and  process  of subcategorization is
presented in Section IV of this document.

Verification Program

The verification program was undertaken to verify the presence of  the
compounds found during the screening program and to obtain information
on  the  quantity  of  toxic and nonconventional pollutants present in
pulp, paper, and paperboard industry wastewaters.

Selection of. Significant Parameters.  As discussed  previously,  after
completion  of  the11  screening  sampling  visits, funding for this
project was depleted due to delays of supplemental appropriations from
Congress.  Monies allocated for  completion  of  the  technical  study
became  available  after a delay of seven months.  Keeping in mind the
court-imposed deadlines, the Agency determined that any further  delay
in initiation of the verification program was intolerable.  During the
period  of  delay,  a  methodology  was  developed  that  would  allow
initiation of the verification program immediately  upon  availability
of  funding  and  would  also provide for development of the same high
quality of data that would be obtained if the  screening  program  had
been completed.

Specific  toxic  pollutants  to  be  analyzed  during the verification
program were selected on the basis of the best  information  available
to  the Agency.  This necessitated a heavy reliance on analytical data
gathered during the abbreviated screening program.  All specific toxic
pollutants identified as present in discharges  from  the  11  sampled
mills would be analyzed during the verification program.  In addition,
EPA  decided  that  both  screening  and verification studies would be
conducted simultaneously at all  verification  mills  where  processes
were  employed that were representative of the four mill groupings not
previously a part of the screening program.

It was  decided  that  GC/MS  procedures  would  be  used  during  the
verification   program   because  this  would  allow  storage  of  all
verification data on computer tapes.  This would enable  a  review  of
the  data  tapes  upon  a  determination  that  other  specific  toxic
pollutants were present in pulp, paper, and paperboard effluents  that
were  not  identified at the 11 screening mills.  This storage of data
ensured that the verification program would yield  comparable  results
to  that  which  would  have  been obtained had screening results been
available from mills representative of all 15 mill groups.
                                 44

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EPA later determined that further analysis of the data tapes would  be
unnecessary  after  completion  of  a thorough review of data gathered
during (a) screening studies conducted by EPA Regional field teams and
(b) contractor verification sampling at those 17 mills where processes
were employed that were characteristic of the four mill groupings  not
a  part  of  the initial contractor screening program.  All additional
compounds  that  were  identified  and  were   not   analyzed   during
verification  sampling  were  present  in  amounts  too  small  to  be
effectively reduced by technologies known to the Administrator.

The compounds included in the verification program and the  basis  for
their inclusion are listed on Table II-8.

Selection  o.f  Mills for Verification Program.  Part I of the EPA Data
Request Survey Form, returned by representatives  of  644  mills,  was
used  in selecting mills for verification program surveys.(13)  One of
the first items addressed in selecting verification mills was industry
subcategorization.  A revised subcategorization scheme  was  developed
based on initial evaluations of the information submitted in Part I of
the  EPA  Survey  Form.   Candidate mills for the verification program
were listed for each of the revised  subcategories.   EPA  established
the  following  three  criteria  for selection of representative mills
during verification sampling:

o    the mill should be  a  direct  discharging  mill  to  obtain  the
     maximum amount of data (raw waste load and treated effluent data)
     at a minimum number of plants,

o    a biological treatment system should be employed at the  mill  if
     BPT  is based on biological treatment (if BPT is based on primary
     treatment, the system could be a primary treatment system), and

o    the final effluent flow and BOD£ should be equal to or less  than
     the  annual  average  levels  used  in  the  development  of  BPT
     regulations for a specific subcategory to ensure  that  the  mill
     selected   would  be  representative  of  the  subcategory  after
     compliance with BPT regulations.

The raw wastewater samples taken at  each  verification  mill  allowed
characterization of the levels of toxic and nonconventional pollutants
that  would be expected to be discharged at indirect discharging mills
to publicly owned treatment works (POTWs).  However, for some  of  the
subcategories,  an  insufficient  number of direct dischargers existed
that met all selection criteria and it  was  necessary  to  sample  at
indirect discharging mills.

All  known  operating  mills  where newsprint is produced from deinked
pulp were indirect discharging; therefore, only  indirect  discharging
mills   could   be   selected  as  verification  mills.   An  indirect
discharging  mill  where  molded  products   are   manufactured   from
wastepaper  was  included  in  the verification program as an adequate
number of direct dischargers could not be found that met the remaining
selection criteria.  A total  of  93  percent  of  the  mills  in  the
                               45

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                                  TABLE 11-8

                            VERIFICATION COMPOUNDS
                     PULP, PAPER, AND PAPERBOARD INDUSTRY
POLLUTANTS DETECTED IN SCREENING

Priority Pollutants

benzene
chlorobenzene
1,2-dichloroethane
1,1,1-trichloroethane
1,1-dichloroethane
1,1,2,2-tetrachloroethane
trichlorophenol*
chloroform
2,4-dichlorophenol
ethylbenzene
fluoranthene
methylene chloride
dichlorobromomethane
trichlorofluoromethane
chlorodibromomethane
isophorone
naphthalene
phenol
bis(2-ethylhexyl) phthalate
di-n-butyl phthalate
               di-n-octyl phthalate
               diethyl phthalate
               chrysene
               anthracene/phenanthrene
               tetrachloroethylene
               toluene
               trichloroethylene
               chromium
               zinc
               nickel
               copper
               lead
               PCB-1242 - wastepaper users
               PCB-1254 - wastepaper users
               PCB-1221 - wastepaper users
               PCB-1232 - wastepaper users
               PCB-1248 - wastepaper users
               PCB-1260 - wastepaper users
               PCB-1016 - wastepaper users
               cyanide  - wastepaper users
only
only
only
only
only
only
only
only
Sonconventional Pollutants

oleic acid
linoleic acid
linolenic acid
piraaric acid
isopimaric acid
denydroabietic acid
abietic acid

OTHER VERIFICATION POLLUTANTS
Priority Pollutants

bromoform
pentachlorophenol
carbon tetrachloride
2-chlorophenol
2,4-dinitrophenol
butyl benzyl phthalate
parachlorometa cresol
acenaphthylene

pyrene
mercury
               3,4,5-trichloroguaiacol
               tetrachloroguaiacol
               monochlorodehydroabietic acid
               dichlorodehydroabietic acid
               9,10-epoxystearic acid
               9,10-dichlorostearic acid
               xylenes
detected by industry in split screening samples
detected by industry in split screening samples
detected by industry in split screening samples
usage indicated on at least one 308 questionnaire
usage indicated on at least one 308 questionnaire
usage indicated on at least one 308 questionnaire
added because compound is a chlorinated phenolic
not detected but added to verification list due to an
inadvertent error
originally reported in screening results; upon finalizing
screening data (subsequent to development of verification
program), it was determined that this compound was not
present
previously used in slimicide formulations
Nonconventional Pollutants

rolor
ammonu
"Includes 2.4,5 and 2,4,5 - irichloropheno]

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builders'  paper  and  roofing  felt  subcategory were either indirect
discharging (63 percent) or self-contained  (30  percent).   The  only
direct  discharging  mill meeting the above criteria was sampled by an
EPA Regional Surveillance and Analysis  field  team  as  part  of  the
screening  program.   Therefore, three indirect discharging facilities
and one self-contained mill were included in the verification program.

For some subcategories, insufficient  direct  discharging  mills  with
biological  treatment  systems  existed  that  met the other selection
criteria.  Therefore, some  mills  were  sampled  where  only  primary
treatment  systems  were  employed.   This  was the case at one of the
three mills sampled in the tissue from wastepaper subcategory.  In the
paperboard from wastepaper subcategory, EPA  sampled  one  mill  where
only  primary  treatment  was  employed  because  extensive wastewater
recycle was practiced  that  enabled  attainment  of  BPT  limitations
without  the  use  of  biological  treatment.    This  is the case at a
significant number of mills in this subcategory.

In most of the nonintegrated subcategories, primary treatment  is  the
system  employed  at the majority of the mills.  Therefore, some mills
with only primary treatment were selected for sampling.   One  of  the
three mills selected in the nonintegrated-fine papers subcategory, one
of  the  two  selected in the nonintegrated-tissue papers subcategory,
one of  the  two  in  the  nonintegrated-filter  and  nonwoven  papers
subcategory,  and  all three of the nonintegrated mills that could not
be placed in a specific subcategory had only primary treatment.

In some of the subcategories, after reviewing the wastewater data, EPA
found that an insufficient number of mills  met  the  third  criteria.
Therefore,  mills  were  selected  where final effluent levels of flow
and/or BOD5. were in excess of the annual average levels upon which the
BPT limitations were based.

Those mills where the above criteria were  met,  with  the  exceptions
discussed  above,  were considered primary candidates for inclusion in
the verification program.  After completion of  this  evaluation,  EPA
evaluated   additional   specific  process  and  wastewater  selection
criteria.  Prior to final selection of mills to  be  included  in  the
verification program, the following were also considered:

1 .  raw wastewater and final effluent flow and BOD!> in relation to BPT
limitations,

2. average daily production rates and raw material usage,

3. the Kappa or permanganate number (if applicable to the  subcategory
that was analyzed),

4.  the  type  of  debarking  used,  wet  or dry (if applicable to the
subcategory analyzed),

5. the brown stock washer efficiency in terms of kilograms (pounds) of
soda loss (if applicable to the subcategory analyzed),
                               47

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6. bleach plant data  (if  applicable  to  the  subcategory  analyzed)
including:

     a. bleaching sequence,

     b. tonnage,

     c. shrinkage,

     d. brightness,

     e. fresh water usage,  and

     f. type of washing system employed.

7.  the  type  of  evaporator  condenser  used  (if  applicable to the
subcategory analyzed),

8. the number of papermachines used (if applicable to the  subcategory
analyzed),

9.  the  number  of papermachines for which savealls were utilized for
fiber recovery  (if applicable to the subcategory analyzed), and

10. the effluent treatment system used at the mill.

Based on this review, 59 mills were initially selected  for  inclusion
in  the  verification program.  The number of mills selected was based
on the total required to represent each of the revised subcategories.

Two of the 59 facilities selected for sampling were not sampled during
the verification program.  At one of the mills, union  employees  were
on  strike;  at  the  other mill, the aeration basin was being dredged
causing the discharge of much higher levels of  solids  than  normally
were  experienced.   No adequate replacement mills were available.  EPA
evaluated all of the verification program analysis results at the  end
of  the  sampling  effort  to  determine  if  additional  sampling  or
substitutions would be necessary and to assess the  coverage  obtained
during  the verification program.  As a result of this assessment, two
subcategories (dissolving kraft  and  dissolving  sulfite  pulp)  were
identified  for  additional  verification sampling because no mills in
these subcategories were included in the verification program.   Three
mills  were  selected  and  verification sampling was conducted at one
dissolving kraft and two dissolving sulfite pulp mills.  In total,  60
mills were sampled during the verification program.

The  location  of  mills that were sampled as part of the verification
program is shown on Figure I1-2.

Sampling Program.  The purpose of the verification program surveys was
to verify the presence and quantity of those toxic and nonconventional
pollutants detected during the screening  program.   The  verification
program  surveys were conducted to provide a more thorough examination


                                    48

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                            FIGURE IE-2
LOCATION OF VERIFICATION PROGRAM
                          MILL SURVEYS

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of the  possible  sources  of  toxic  and  nonconvehtional  pollutants
discharged,  the  quantity  discharged  to  the  end-of-pipe treatment
system, the levels in  the  final  mill  effluent,   and  the  relative
efficiency  of  the  treatment system for removing specific compounds.
Several different sampling procedures were examined for  accomplishing
these  goals.   Table I1-9 presents the general format for sampling in
particular subcategories and also presents the sample points  and  the
sample  duration  proposed for each.  EPA selected this format to meet
the verification program goals.

EPA representatives contacted representatives of the selected mills by
telephone; a confirmation letter  was  sent  verifying  the  scheduled
survey.   This  confirmation letter included submittal of two separate
forms used to obtain pertinent  mill  operating  information  for  the
survey  period  and  for  identification  of  management practices (as
defined in section 304(e) of the Clean Water Act of 1977) employed  at
the mills. (19)

A  "Verification  Program  Work  Booklet,"  similar  to the "Screening
Program Work Booklet,"  was  developed  prior  to  initiation  of  the
sampling   surveys.(20)    The  work  booklet  detailed  the  specific
procedures to be followed during the survey period.

The program included collecting composite and grab samples during  the
3-day  survey.   Composite  sampling  was normally performed for three
separate 24-hr periods at each sample location,  except  for  the  raw
process  water  source,  where  a  single  72-hr  composite sample was
collected.  In  addition,  certain  internal  sewers  were  monitored,
usually  for  one  24-hr  period.  Compositing usually started between
8:00 and 11:00 a.m. on the first day of the survey and ended 24  hours
later.   Table 11-10 shows the work items performed during each day of
a typical verification survey.

The composite samples were divided into  five  aliquots  including  a)
metals  and  color,  b)  extractable  organics,  c)  COD,  d) PCBs and
pesticides (where appropriate), and e)  ammonia  (where  appropriate).
Internal  sewers  were  not  sampled for COD.  Grab samples were taken
once per day at each of the sample locations including the raw process
water.  The grab samples were taken for analysis of volatile organics,
mercury, and cyanide (where appropriate).  Temperature and pH readings
were taken at least  three  times  per  day  at  each  of  the  sample
locations.

Split    Sampling   Program.    As   with   the   screening   program,
representatives of the National Council of the Paper Industry for  Air
and  Stream  Improvement,  Inc.  (NCASI) obtained split samples.  NCASI
personnel shipped the necessary sampling containers to the mills.  The
sampling team collected the samples for NCASI  and  returned  them  to
mill  personnel  for  shipment to the appropriate NCASI  laboratory for
analysis.  The NCASI split sampling effort did not include  collection
of all of the samples collected by the Agency at each mill.
                                50

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                                   TABLE II-9

                      VERIFICATION PROGRAM SAMPLING POINTS
Subcategory
Type of Samples and Sample Duration
Bleached Kraft/Sulfite Mills

1.   Raw Water
2.   Pulp Mill/Screening
3.   Bleach Plant
4.   Secondary Treatment Influent
5.   Final Effluent

Groundwood Mills

1.   Raw Water
2.   Pulp Mill/Screening
3.   Secondary Treatment Influent
4.   Final Effluent

Unbleached Kraft/Semi-Chemical Mills

1.   Raw Water
2.   Pulp Mill/Screening
3.   Secondary Treatment Influent
4.   Final Effluent

Secondary Fiber Mills

1.   Raw Water
2.   Stock Preparation
3.   Secondary Treatment Influent
4.   Final Effluent

Builders' Paper and Roofing Felt Mills

1.   Raw Water
2.   Secondary Treatment Influent
3.   Final Effluent
Grab samples (3 per day)
24-hr composite
24-hr composites
24-hr composites
24-hr composites
Grab samples (3 per day)
24-hr composite
24-hr composites
24-hr composites
Grab samples (3 per day)
24-hr composite
24-hr composites
24-hr composites
Grab samples (3 per day)
24-hr composites
24-hr composites
24-hr composites
Grab samples (3 per day)
24-hr composites
24-hr composites
Paperboard From Wastepaper & Nonintegrated Mills
1.    Raw Water
2.    Secondary Treatment Influent
3.    Final Effluent
Grab samples (3 per day)
24-hr composites
24-hr composites
                                     51

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                                                         TABLE  11-10

                                        TYPICAL VERIFICATION SAMPLING PROGRAM SURVEY
     Day 1  of the Survey
                              Day 2 of the Survey
                              Day 3 of the Survey
                              Day 4 of the Survey
tn
ro
1.  Meet with mill person-
   nel and discuss the
   program

2.  Select sample locations

3.  Discuss mill's manage-
   ment practices and tour
   mill to observe the
   items covered

4.  Set up the automatic
   samplers

5.  Collect all grab
   samples required

6.  Take pH and tempera'
   ture readings at each
   sample point twice
   during 24-hours

7.  Check automatic samplers
   periodically and keep
   composite sample con-
   tainer iced
1. Distribute 24-hour
   composite between the
   required composite
   samples

2. Rinse sample composite
   container and start
   automatic sampler for
   the next 24-hr period

3. Collect all grab samples
   required

4. Take pH and temperature
   readings at each sample
   location twice during
   24-hours

5. Check automatic samplers
   periodically and keep
   composite sample
   container iced
1. Distribute 24-hour
   composite between the
   required composite
   samples

2. Rinse sample composite
   container and start
   automatic sampler for
   the next 24-hr period

3. Collect all grab samples
   required

4. Take pH and temperature
   readings at each sample
   location twice during
   24-hours

5. Check automatic samplers
   periodically and keep
   composite sample
   container iced
1. Distribute 24-hour
   composite between the
   required composite
   samples

2. Break down automatic
   sampler at each loca-
   tion and pack equip-
   ment

3. Final meeting with
   mill personnel to
   wrap up the survey

4. Pack samples in ice
   and ship to the
   appropriate laboratory

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Generally, the NCASI samples were collected as follows:(21)

                                       Influent
                      Raw Water        to Treatment    Final Effluent
Parameter
Extractable Organics  Day 3 of Survey  Day 1 of Survey Day 2 of Survey
Nonconventional
 Pollutants
Metals
Mercury
Volatile Organics
Cyanide
                      Day 3 of Survey
                      Day 3 of Survey
                      Day 3 of Survey
                      Day 2 of Survey
                Day 1 of Survey
Day 2 of Survey Day 3 of Survey
                Day 3 of Survey
Day 2 of Survey Day 3 of Survey
                Day 2 of Survey
Analytical  Methods  for  Verification  Program Analysis.  The samples
from each verification mill were analyzed  for  18  volatile  organics
(VOA),  33  extractable  organics,  and  6  metals.   Included  in the
extractable organics were 13 resin and fatty acids  and  bleach  plant
derivatives,  nonconventional  pollutants specific to the pulp, paper,
and paperboard  industry.   In  addition,  samples  from  mills  where
wastepaper was used as a raw material source were analyzed for PCBs.

Copper,  chromium, lead, nickel, zinc, and mercury were analyzed using
the same  procedures  described  earlier  in  the  discussion  of  the
screening  program.  Cyanide was analyzed in accordance with the total
cyanide method described in the 14th Edition of Standard  Methods.(18)
Ammonia  was  analyzed by distillation and Nesslerization as described
in the same edition of Standard Methods.(18)  Color  was  analyzed  in
accordance  with  the procedures set forth in NCASI Technical Bulletin
Number  253.(22)   Chemical  oxygen  demand  (COD)  was  analyzed   in
accordance  with  the  procedures  presented  in  the  14th Edition of
Standard Methods.(18)

The procedures used to analyze samples collected  during  verification
sampling provided for additional quality control and quality assurance
over   those  procedures  used  during  the  screening  phase.   These
verification procedures are the same as Methods 624 and  625  proposed
under  authority  of sections 304(h) and 501(a) of the Act (see 40 CFR
Part 136; 44 PR 69464 (December 3, 1979)). (23) The Agency  chose  the
option  of  including additional quality control and quality assurance
procedures described in Procedures for Analysis of  Pulp,  Paper,  and
Paperboard  Effluents  for  Toxic and Nonconventional Pollutants (EPA,
Washington,  D.C.,  December,   1980).(24)Gaschromatography/mass
spectrometry  (GC/MS),  interfaced  with  a  computer  system, was the
primary analytical instrument for  volatile  and  extractable  organic
analysis.

The  computer  system  interfaced  with  the mass spectrometer allowed
acquisition of continuous mass scans throughout the chromatogram.  EPA
representatives obtained standards for each pollutant to be assayed in
the samples and  determined  the  mass  spectrum  for  each  of  these
standards daily throughout the analysis program.
                                53

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Duplicate  125-ml  samples  were  collected at each sampling point for
volatile organic analysis (VOA).  Volatile samples  were  checked  for
chlorine content in the field and preserved with sodium thiosulfate as
necessary.   Volatile  organic  analysis  utilized  the purge and trap
method, which is a modified gas sparging,  resin adsorption  technique,
followed by thermal desorption and analysis by packed column GC/MS.

The  sampling  team collected duplicate 1-liter samples of wastewaters
for analysis of extractable organic  compounds.   Extractable  organic
samples  were  preserved in the field with sodium hydroxide to a pH of
approximately 10 or higher.  For  extractable  organic  analysis,  the
sample  was  acidified to a pH of 2 or below, extracted with methylene
chloride, concentrated, and chromatographed on a GC/MS system equipped
with a support-coated open tubular (SCOT)  capillary column.

Extracts prepared for analysis  of  PCBs  were  analyzed  by  electron
capture  detection/gas chromatography (EC/GO.  Extracts in which PCBs
were detected at a level of greater than  1  ug/1  were  confirmed  by
GC/MS.

Quality  Control/Quality Assurance.  The verification program included
the implementation of  a  quality  control/quality  assurance  (QC/QA)
program  consisting of internal standards, field blanks, method blanks
and replicate analysis.  Deuterated internal standards  were  selected
to provide QC/QA data on primary groups of pollutants under evaluation
in  the  verification  program.  The deuterated compounds selected are
shown in Table 11-11.

These compounds were selected  because  of  their  similarity  to  the
compounds   under   investigation.    By  adding  deuterated  internal
standards to each sample analyzed by GC/MS, it was possible to  assess
system  performance  on  a per-sample basis.  Recovery of the internal
standards in the volatile organic analysis assured that the  apparatus
was  leakproof  and  that  the  analysis  was  valid.  For extractable
organic  analyses,  percent  recoveries  of  the  internal   standards
indicated  the complexity of the sample matrix and the validity of the
analysis.  In each case, low recovery of internal  standards  signaled
possible  instrument  malfunction  or operator error.  For analysis of
volatile organic compounds, the area of the 100 percent characteristic
ion for each internal standard had to agree within 25 percent with the
integrated peak area obtained from analysis of the composite  standard
or  the  GC/MS  sample run was repeated.  Extractable organic analysis
was repeated  if  internal  standard  recoveries  were  less  than  20
percent.

To  demonstrate  satisfactory  operation of the GC/MS system, the mass
spectrometers were tuned each day with perfluorotributylamine  (PFTBA)
to  optimize  operating  parameters  according  to  the manufacturer's
specifications.   Calibration  logs  were   maintained   to   document
instrument performance.  The entire GC/MS system was further evaluated
with   the  analysis  of  a  composite  standard  that  contained  all
pollutants of interest and the various deuterated internal  standards.
This standard was analyzed with each sample set or with each change in


                                54

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                                   TABLE 11-11

                          SUMMARY OF INTERNAL STANDARDS
     Volatiles*
          methylene chloride-d2
          1,2-dichloroethane-d4
          1,1,l-trichloroethane-d3
          benzene-d3
          toluene-d3
          p-xylene-dlj)
     Extractables
          phenol-d5-TMS
          naphthalene-d8
          diamyl phthalate
          stearic acid-d35-TMS
^Relative to benzene-d3
                                      55

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instrument  calibration/tune.    This  daily  analysis of the composite
standard  supplied  data  that  a)  verified  the  integrity  of   the
chromatographic  systems,  b)   produced acceptable low-resolution mass
spectrum  of  each  compound  assayed,   and   c)   verified   machine
sensitivity.

The field and method blanks were included in the analytical program to
indicate   possible   sample   contamination  and  confirm  analytical
methodologies.  Field blanks  were  spiked  with  deuterated  internal
standards.   Method  blanks  were  spiked with the deuterated internal
standards and standards for compounds under evaluation,  as  discussed
previously.   The  mass  spectrum for each of these standard compounds
was determined daily throughout  the  analysis  program.   The  blanks
provided  additional  quality  assurance, including:  a) data on clean
matrix  recoveries   and   b)    replicate   analysis   for   precision
determinat ions.

Long-Term Sampling Program

The  long-term  sampling  program  was  undertaken  to investigate the
variability and treatability  of  certain  toxic  and  nonconventional
pollutants  discharged  from  mills in the pulp, paper, and paperboard
industry.

Selection  of_  Significant  Parameters.   Through  an  evaluation   of
available  data(primarily verification data), EPA identified certain
pollutants to  be  of  potential  concern  in  the  pulp,  paper,  and
paperboard  industry.   These  included  chloroform,  trichlorophenol,
pentachlorophenol, and PCBs, which are  toxic  pollutants,  and  resin
acids,   fatty   acids,   and  bleach  plant  derivatives,  which  are
nonconventional  pollutants.   The  complete  list  of  the  pollutant
parameters selected for analysis during the long-term sampling program
is presented in Table 11-12.

Selection  of  Mills  for  the  Long-Term Sampling Program.  Candidate
mills for tHe long-term sampling program were listed for each  of  the
following  five  major  industry  sectors;  bleached kraft, unbleached
kraft/semi-chemical,  deink   with   bleaching,   wastepaper   without
bleaching,   and   bleached  sulfite.   The  following  criteria  were
established for selection of the mills:

     o    the mills  should  be  located  close  to  the  northeastern
          quarter of the U.S.  to minimize cost, and

     o    the final effluent flow and BOD!> for each mill chosen should
          be equal to or less than  the  annual  average  levels  that
          formed  the basis of BPT regulations to ensure that the mill
          selected would be  representative  of  the   industry  sector
          after compliance with BPT regulations.

Due  to budgetary concerns, only two mills could be chosen. Therefore,
the candidate mill list was reduced to include only mills representing
industry sectors that were best suited for this program.  A review  of
                                56

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                                  TABLE 11-12

                     TOXIC Am NONCONVENTIONAL POLLUTANTS
                       SELECTED FOR ANALYSIS DURING THE
                          LONG-TERM SAMPLING PROGRAM
Toxic Pollutants

Chlorinated Phenolics:
     2,4-dichlorophenol
     trichlorophenol*
     pentachlorophenol

Halonethane:
     chlorofonn

Polychlorinated Biphenyls (PCBs)2
     PCS-1016
     PCS-1221
     PCS-1232
     PCI-1242
     PCI-1248
     PCB-1254
     PCB-1260
Npnconventional Pollutants

Chlorinated Phenolics:
     4,5-dichloroguaiacol
     3,4,5-trichloroguaiacol
     4,5,6-trichloroguaiacol
     tetrachloroguaiacol

Unsaturated Fatty Acids:
     oleic acid
     linoleic acid
     linolenic acid

Unsaturated Fatty Acid Derivatives:
     9,10-epoxystearic acid
     9,10-dichlorostearic acid

Resin Acids:
     abietic acid
     dehydroabietic acid
     isopimaric acid
     levopimaric acid
     neoabietic acid
     palustric acid
     pimaric acid
     sandaracopimaric acid

Chlorinated Resin Acids:
     monochlorodehydroabietic acid
     dichlorodehydroabietic acid

Ethers:
     dimethyl sulfide
     dimethyl disulfide
Includes 2,4,5 and 2,4,6-trichlorophenol.

2Analyzed only at deink mill.
                                   57

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screening  and verification data showed that bleached kraft facilities
could have detectable levels of all the pollutants of concern  (except
PCBs)  in  their  wastewater.   A  further  review  showed  that PCBs,
chloroform, and the  chlorophenolics  could  be  found  in  wastewater
discharges from deinking mills where bleaching is employed.

As  a  result,  the  candidate  mill  list was reduced to include only
bleached kraft and deink mills.   EPA  selected  one  mill  from  each
sector  to  provide  full  coverage  of  the toxic and nonconventional
pollutants of concern.

Sampling Program.  The purpose of the long-term sampling  program  was
to  investigate the variability and treatability of certain pollutants
specific to the pulp, paper, and paperboard  industry.   The  sampling
effort  was primarily designed to collect long-term data on the levels
of the pollutants of interest in the  final  effluent  of  the  mill's
wastewater  treatment plant.  Raw wastewater samples were collected to
determine the levels of the pollutants being discharged to the end-of-
pipe treatment system and to evaluate the relative efficiency  of  the
treatment system for removing the specific compounds.

Representatives  of the selected mills were contacted by telephone and
a confirmation letter was sent explaining the program.  At the initial
meeting with mill personnel, discussions included the need  to  obtain
pertinent  mill operating information for the duration of the sampling
program.

Prior to beginning the sampling  effort,  EPA  developed  a  long-term
sampling work booklet for each mill sampled.(25)(26) Each work booklet
detailed the specific procedures to be followed at each mill.

For  the  fine  bleached kraft mill, sampling included collecting grab
and composite samples over a 72-hour period each week for twenty-three
weeks.   Weekly  composite  sampling  consisted  of  collecting  three
consecutive  24-hour  composites of the final effluent and one 72-hour
composite of the aeration  influent.   For  this  mill,  the  aeration
influent  was  the  first  point  at which all wastewater streams were
combined.

At the deink  tissue  mill,  sampling  included  collecting  grab  and
composite  samples  over  a  72-hour period each week for twenty-three
weeks.   Weekly  composite  sampling  consisted  of  collecting  three
consecutive  24-hour  composites  of the final effluent, and a 72-hour
composite of both the raw waste and primary clarifier  effluent.   The
primary  effluent  sample  point  was  added  to the program after EPA
learned that over fifty percent of the primary clarifier  effluent  is
recycled  back  to  the  mill.   By sampling the primary effluent, EPA
could evaluate the treatability of  the  chemically  assisted  primary
clarification system for the pollutants of  interest and could estimate
their levels entering secondary treatment.

At  both  mills,  grab  samples were taken  three times per day at each
sample point.  Collection of grab samples was necessary  for  analysis
                                58

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of   the  volatile  organic  compounds  of  interest.   Also,  pH  and
temperature were recorded each time a grab sample was taken.

Split Sampling  Program.   As  with  the  screening  and  verification
programs,  representatives  of  the  National  Council  of  the  Paper
Industry for Air and Stream Improvement, Inc. (NCASI)  obtained  split
samples.  NCASI personnel shipped the necessary sampling containers to
the . bleached kraft mill.  The sampling team collected the samples for
NCASI and  returned  them  to  mill  personnel  for  shipment  to  the
appropriate  NCASI  laboratory for analysis.  The NCASI split sampling
effort included only six  final  effluent  samples  collected  at  the
bleached kraft mill; none were collected at the deink mill.

Analytical  Methods  Used  During the Long-Term Sampling Program.  The
analytical  methods  used  to  analyze  wastewater  samples  from  the
bleached kraft mill and the deink mill are discussed below.

     Bleached  Kraft  Mill  -  The wastewater samples collected at the
bleached kraft  mill  were  analyzed  for  all  of  the  priority  and
nonconventional pollutants (except PCB's) listed in Table 11-12.

The  volatile  organic compounds were analyzed by U.S.EPA Method 1624,
"Volatile Organic Compounds by Purge and Trap Isotope Dilution GC/MS."
The concentrations of dimethyl sulfide  and  dimethyl  disulfide  were
determined  according  to  Method  624 because no labeled analogs were
available.

The semivolatile organic  compounds  were  analyzed  with  a  modified
version  of  U.S.EPA  Method  1625, "Semivolatile Organic Compounds By
Isotope Dilution GC/MS." Method 1625  was  modified  to  include  SE54
fused silica wall coated open tubular gas chromatography (HRGC) and N-
methyl-N-trimethylsilyl-trifluoroacetamide   (MSTEA)   derivatization.
The modification was necessary to allow  for  analysis  of  resin  and
fatty   acid   compounds   found  in  wood  pulping  discharges.   The
concentrations of those compounds for which no  isotopic  counterparts
were available were determined according to Method 625.

     Deink  Mill.   The wastewater samples collected at the deink mill
were routinely analyzed for the priority pollutants  only   (see  Table
11-12).

Chloroform concentrations were determined by U.S.EPA Method 1624.  The
chlorophenolics  were  analyzed  using  Method 1625 as was done at the
bleached kraft mill.
The  PCB  concentrations  were  determined  by  U.S.EPA  Method   617,
"Organochlorine  Pesticides  and  PCBs." It was necessary to determine
the presence of the PCBs  by  Method  617  since  Method  625  is  not
sensitive  enough  at  low  levels  for these compounds, the limits of
detection being about 30 ppb.  The PCBs were not analyzed  by  isotope
dilution  methods  since labeled standards were not available.  If any
PCBs were detected, they were confirmed by GC/MS  (though  quantitated
by GC/EC).
                                59

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To  investigate  the  levels  of the nonconventional pollutants at the
deink mill, fifteen final effluent samples were randomly selected  and
analyzed.   Volatile  and semivolatile nonconventional pollutants were
analyzed by using Methods 624 and 625, respectively, as for the bleach
kraft samples.

Quality Assurance/Quality Control.   The  long-term  sampling  program
included  the  implementation  of  separate  quality assurance/quality
control (QA/QC) procedures for each mill.  Analyses of chloroform  and
the chlorophenolics at both mills allowed similar QA/QC procedures for
these  compounds; however, analyses for the nonconventional pollutants
at the bleached kraft mill and PCBs at the  deink  mill  required  the
development of different QA/QC procedures.

For  the bleached mill, the QA/QC procedures used were primarily those
presented in the Federal Register (44 FR 69553, December 3, 1979)  for
analysis  of  organic  priority  pollutants.   (23)  The  QA/QC program
included routine QA/QC such as a preliminary,  clean  water  precision
and  accuracy  study,  and  the  use  of method and field blanks.  The
program  also  required  that  analytical  methods  be  validated  and
subsequent   analyses   be   within   the  validated  control  limits.
Additional quality assurance was included  for  the  analysis  of  the
nonconventional  pollutants for which no labeled analogs exist.  Three
levels of standard  additions  on  duplicates  of  ten  percent  final
effluent samples were required to provide recovery information.

Also,  a  mass  spectrometer linearity study was conducted three times
during the program.  The  study  determined  the  dynamic  performance
range  of  the entire analytical system for all compounds of interest,
surrogate standards, and internal standards.

For the deink mill, the use of labeled analogs for chloroform and  the
chlorophenolics   provided   recovery   information  for  these  toxic
pollutants.   Additional  precision  information   was   obtained   by
analyzing one final effluent sample in duplicate each week.

Since  no labeled analogs exist for PCBs, a separate QA/QC program was
developed.  During the odd numbered sampling weeks (1, 3, 5, 7,...23),
one  final  effluent  sample  was  analyzed  in  duplicate  to  obtain
precision  information.   During  the  even  numbered  weeks (2, 4, 6,
8,....22), one final effluent sample was analyzed first  unspiked,  to
establish background concentration of the analyte, and then spiked, to
provide recovery information.

Discharge Monitoring Data Acquisition Program

During  the  verification program, EPA obtained long-term conventional
pollutant data from each of  the  mills  surveyed.   These  data  were
obtained  to  analyze the effectiveness of in-place technology.  After
reviewing these data, EPA found that effluent  levels attained at  some
mills were well below BPT limits.  In addition, EPA was aware that the
data  request  program  had  preceded  the  start-up  of new treatment
facilities at many mills.  Based on this information, in  December  of
                                60

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1979,  EPA decided to obtain additional long-term data to evaluate the
performance of treatment systems relative to BPT limitations.

This effort involved contacting personnel at EPA Regional offices  and
States with permitting authority to obtain discharge monitoring report
(DMR)  data  to  supplement  the  conventional pollutant data received
during the  verification  program.   Discharge  monitoring  data  were
obtained  from  five  EPA Regional offices and from eleven States with
permitting authority.  The resulting DMR data base included 12  to  30
months  of DMR data for the period between July 1977 and December 1979
for approximately 250 direct discharging mills in the  industry.   The
data  were  used  to develop the effluent limitations proposed for the
conventional pollutants BOD5_ and TSS (see 46 FR 1430, January 6,1981).

To update and expand this data base, EPA conducted a supplemental  DMR
program  to  obtain additional data for direct, continuous discharging
mills for the period between July 1977  and  March  1981.   All  pulp,
paper,  and  paperboard  mills  were  identified  by  State,  and  EPA
developed a list of EPA  Regional  offices  and  State  agencies  with
permitting authority for these mills.

DMR  data  were  received  from the following EPA Regional offices and
States:

     EPA Region I, II, III, IV, VI, VIII, IX, and X. _

     Maine, New Hampshire, Connecticut, New York, Virginia,  Maryland,
     Delaware,   Tennessee,   Mississippi,   Alabama,  Georgia,  South
     Carolina, North  Carolina,  Ohio,  Indiana,  Illinois,  Michigan,
     Wisconsin,  Minnesota,  Kansas,  Iowa,  California  Region I, and
     California Region V (Redding Office).

The number of  direct  discharging  mills  for  which  DMR  data  were
collected   and  the  number  of  direct  discharging  mills  in  each
subcategory are presented in Table 11-13.

DMR  data  were  evaluated  to  identify  inconsistencies.   EPA  also
assessed  the  influence  of  treatment  system  startup  on  effluent
quality.  If effluent loads were found to  be  unusually  high  during
startup,   data   were   discarded   to   properly   reflect  effluent
characteristics subsequent to system startup.   When  EPA  found  that
long-term   effluent  levels  were  inconsistent  due  to  production,
process,  or  treatment  system  changes,  the   data   were   further
scrutinized  and  reanalyzed  or  deleted  from  the  data  base.  EPA
developed summaries of the DMR data for inclusion in the existing data
base.  The DMR data are discussed and summarized in  Section  VIII  of
this document.

Supplemental Data Acquisition Program

During  the  BATEA  review  program,  EPA collected 13 months of daily
production and wastewater data from 54 mills  to  determine  long-term
average,  maximum  day,  and  maximum 30-day average values.  EPA used
                                 61

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                                    TABLE 11-13

                        SUMHARV OF DIRECT DISCHARGING MILLS
                             VERSUS DMR DATA COLIiCTiD

                                                               Number of Hills
                                     Number of Direct        Included in Discharge
Subcategory	Discharging Mills  	Monitoring Data Base

Integrated Segment

Dissolving Kraft                             3                        3
Market Bleached Kraft                       12                       10
BCT Bleached Kraft                           9                        9
Alkaline-Fine                               16                       16
Unbleached Kraft
  o  Linerboard                             16                       16
  o  Bag                                    11                       11
Seal-Chemical                               18                       18
Unbleached Kraft and Seai-Chenical           9                        9
Dissolving Sulfite.Pulp                      6                        4
Papergrade Sulfite                          13                       13
Groundwood - Therms-Mechanical               3                        3
Groundwood - CMN Papers                      3                        3
Groundwood - Fine Papers                     7                        7
Integrated Miscellaneous                    75                       71

Secondary Fibers Segment

Deink
  o  Fine Paper*                             3                        3
  o  Tissue Papers                          11                       11
  o  Newsprint                               1                        1
Tissue From Wastepaper                      13                       13
Paperboard From Wastepaper                  45                       43
Wastepaper-Molded Products                   4                        4
Builders' Paper and Roofing Felt             5                        5
Secondary Fiber Miscellaneous                7                        7

Nonintegrated Segment

Nonintegrated - Fine Papers
  o  Wood Fiber Furnish                     16                       16
  o  Cotton Fiber Furnish                    5                        5
Nonintegrated - Tissue Papers               15                       15
Nonintegrated - lightweight Papers
  o  Lighweight Papers                      10                       10
  o  Electrical Paper*                       4                        4
Nonintegrated - Filter and Nonwoven Papers   5                        5
Nonintegrsted - Paperboard                   7                        7
Nonintegrated Miscellaneous                 26                       26

                            Total          378                      370


  The total represents all direct discharging mills knovn to have operated for a
  period of time during January 1978 and March 1981 and self-contained mills
  which submit DMRs.  The total incudes 35 Bills which share 14 joint treatment
  systems.  Each mill is listed separately on the table although only one set of
  data are reported for each joint treatment system.  The total also includes
  some mills which discharge a portion of their wastewater to POTWs.
  Includes Fine Bleached Kraft and Soda subcategories.
  Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash)
  subcategories.
                                        62

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these data  to  establish  maximum  day  and  maximum  30-day  average
variability  factors  in  developing proposed effluent limitations and
standards published on January 6, 1981 (46 FR 1430).

To broaden, update, and strengthen its  data  base,  EPA  conducted  a
supplemental  data  request  program.   EPA  selected  mills  for this
program  based  on  final  effluent   discharge   levels,   wastewater
monitoring  frequencies,  and type of treatment system employed.  Data
request forms were developed and submitted to representatives of  each
selected mill.  Daily operating data were gathered from 44 mills for a
period  of  approximately  three  years.    The  data  were analyzed to
determine maximum day and maximum 30-day average variability  factors.
One  mill was subsequently identified as a noncontinuous, intermittent
discharger and was dropped from the study.

PCB Data Acquisition Program

EPA conducted an extensive study to evaluate the presence  and  levels
of  PCBs  discharged  from  pulp,  paper,  and  paperboard mills where
recycled paper is  used  as  furnish.   EPA  Regional  offices.  State
agencies  with  permitting  authority, and environmental agencies were
contacted for information; those states which require  PCB  monitoring
were  identified.  Raw waste and final effluent data were obtained for
49 mills from data suplied by the States of New York,  Wisconsin,  and
Oklahoma  and  from  an  evaluation of discharge monitoring report and
verification sampling data.

Data Obtained From Industry on Proposed Regulations

The industry, through  its  comments  on  the  January  1981  proposed
regulations,  supplied  additional toxic and nonconventional pollutant
data.  Chloroform,  ammonia,  trichlorophenol,  and  pentachlorophenol
data  supplied  by  industry  representatives  in  their  comments are
summarized in Section V.

Analysis of Treatment Alternatives

As a result of  a  review  of  available  literature,  EPA  identified
numerous   production   process   controls   and   effluent  treatment
technologies that are applicable  for  control  of  the  discharge  of
conventional,  toxic, and nonconventional pollutants.  These processes
and systems include those currently in use in  the  pulp,  paper,  and
paperboard  industry  and  those demonstrated at a laboratory or pilot
scale  and/or  demonstration  level  within  an  industrial   category
including  the  pulp,  paper, and paperboard industry.  The production
process controls and effluent  treatment  technologies  evaluated  and
their area of application are presented in Table 11-14.  EPA evaluated
this  information,  along  with  the  data  developed through the data
request,  screening,  verification,  and  supplemental  data   request
programs,  to  determine  reduction/removal capabilities of applicable
control and treatment technologies.
                                    63

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                                   TABLE 11-14

          PRODUCTION PROCESS CONTROLS AND EFFLUENT TREATMENT TECHNOLOGIES
Production Process Controls

1.  Woodyard/Woodroom
a.   Close-up or dry woodyard and barking operation
b.   Segregate cooling water

2.  Pulp Mill
a.   Reuse blow condensates
b.   Reduce groundwood thickener overflow
c.   Spill collection

3.  Washers and Screen Room
a.   Add 3rd or 4th stage washer or press
b.   Recycle more decker filtrate
c.   Reduce cleaner rejects and direct to landfill

4.  Bleaching
a.   Countercurrent or jump stage washing
b.   Evaporate caustic extract filtrate

5.  Evaporation and Recovery Areas
a.   Recycle condensate
b.   Replace barometric condenser
c.   Boil out tank
d.   Neutralize spent sulfite liquor
e.   Segregate cooling water
f.   Spill collection

6.  Liquor Preparation Area
a.   Green liquor dregs filter
b.   Lime mud pond
c.   Spill collection
d.   Spare tank

7.  Paper-mill
a.   Spill collection
     1.   Paper machine and bleached pulp spill collection
     2.   Color plant
b.   Improve saveall
c.   High pressure showers for wire felt cleaning
d.   White water use for vacuum pump seal water
e.   Paper machine white water shower wire cleaning
f.   Additional white water storage upsets and pulper dilution
g.   Recycle press effluent
h.   Reuse of vacuum pump water
i.   Broke storage
j.   Wet lap machine
k.   Separate cooling water
1.   Cleaner rejects to landfill
m.   Addition of fourth stage cleaners
                                      64

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                                  TABLE II-14
                                  (continued)
8.  Steam Plant and Utility Areas
a.   Segregate cooling water
b.   Lagoon for boiler blowdown and backwash waters

9.  Recycle of Effluent
a.   Filtrate
b.   Sludge

10. Substitution of Chemicals
Other Technologies
a.   Oxygen bleaching process
b.   Rapson/Reeve process
c.   Sequential chlorination
d.   Displacement bleaching

Effluent Treatment Technologies
1.   Primary Clarification                   7.
2.   Biological Treatment
     a. Oxidation basins                     8.
     b. Aerated stabilization basin          9.
     c. Activated sludge                    10.
     d. Rotating biological contactor       11.
     e. Anaerobic contact filter            12.
     f. Ammonia removal by nitrification    13.
3.   Chemically Assisted Clarification      14.
4.   Foam Separation                        15.
5.   Activated Carbon Adsorption
6.   Steam Stripping
Reverse Osmosis/Freeze
  concentration
Filtration
Dissolved Air Flotation
Ultrafiltration
Polymeric Resin Adsorption
Amine Treatment
Electrochemical Treatment
Microstraining
Oxidation
                                     65

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EPA identified several technology options  for  consideration  as  the
basis  of  BPT  and  BAT  effluent  limitations,  NSPS, PSES, and PSNS.
These options include combinations of the  technologies  presented  on
Table 11-14.   EPA assessed the pollutant removal  capabilities of these
technology  options/  the  results  of  this analysis are presented in
Section VIII  of this document.

Analysis of_ Cost and Energy Data

Through the data assessment phase, mill surveys,   EPA  data  requests,
and  DMR data requests,  baseline data have been gathered for analysis.
Data obtained and evaluated include: a) age  of  mill,  b)  production
process  controls employed, c) effluent treatment technology employed,
d) cost for the technology employed (if available), e) site conditions
(i.e., ledge, poor soils), and f) land availability.  EPA  used  these
data   to   characterize   model  facilities  representative  of  each
subcategory of the pulp, paper, and paperboard and builders' paper and
board mills point source categories.

EPA developed appropriate model mill sizes  for  each  subcategory  to
properly  account  for  economies  of scale.  The Agency estimated the
costs of implementation of various control and treatment  options  for
these model mills.

In  developing  cost  data  for implementation of available production
process controls and end-of-pipe treatment, EPA estimated the costs of
construction  materials  in  terms  of  first  quarter  1978  dollars.
Equipment  and  material suppliers were contacted to aid in developing
these estimates.  Installation, labor,  and  miscellaneous  costs  for
such items as electrical, instrumentation, and contingencies have been
added  to  determine  a  total  construction  cost,  depending  on the
controlling parameters.   Cost data are presented in Appendix A of this
document.

EPA used its cost estimates to assess the economic impacts  (including
price  increases,  profitability,  industrial  growth, plant closures,
production changes, employment effects, consolidation trends,  balance
of trade effects, and community and other dislocation effects) of each
of  the  identified  control  and  treatment  options.  These economic
impacts are discussed in detail in a separate report: Economic  Impact
Analysis  of  Effluent  Limitations and Standards for the Pulp, Paper,
and Paperboard Industry (U.S. EPA, October 1982).  (27)

EPA estimated baseline energy consumption and solid  waste  generation
and  the incremental increase in energy and solid waste resulting from
implementation of various technology  options.   Information  gathered
through  the  data request program and subsequent  inputs from industry
representatives were  used  in  establishing  this  baseline.   Energy
consumption data are also presented in Appendix A of this document.
                                66

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                             SECTION III

                     DESCRIPTION OF THE INDUSTRY


INTRODUCTION

EPA identified a total of 674 operating facilities (as  of  April  12,
1982)  involved  in  the  manufacture  of  pulp,  paper and paperboard
products.  The mills vary in size, age, location, raw material  usage,
products  manufactured,  production  processes  employed, and effluent
treatment systems employed.  This highly diversified industry includes
the production of pulp, paper, and paperboard from  wood  and  nonwood
materials  such  as  jute,  hemp,  rags,  cotton 1 inters, bagasse, and
esparto.  The pulp, paper,  and  paperboard  industry  includes  three
major segments: integrated, secondary fibers, and nonintegrated mills.
Mills   where   pulp  alone  or  pulp  and  paper  or  paperboard  are
manufactured on-site are referred to as integrated mills.  Those mills
where  paper  or  paperboard  are  manufactured  but   pulp   is   not
manufactured  on-site  are  referred to as nonintegrated mills.  Mills
where wastepaper is used as the primary raw material to produce  paper
or paperboard are referred to as secondary fibers mills.

A  wide  variety  of  products including pulp, newsprint, printing and
writing papers,  unbleached  and  bleached  packaging  papers,  tissue
papers,  glassine,  greaseproof  papers,  vegetable parchment, special
industrial  papers,  and  bleached  and  unbleached   paperboard   are
manufactured  through  the  application of various process techniques.
The industry is sensitive to changing demands for paper and paperboard
products; operations are frequently expanded or modified at  mills  to
accommodate new product demands.

RAW MATERIALS

During the nineteenth century, wood began to supplant cotton and linen
rags,  straw, and other less plentiful fiber sources as a raw material
for the manufacture of paper products.  Today, wood is the most widely
used fiber source in the pulp,  paper,  and  paperboard  industry  and
accounts  for  over  98  percent  of  the virgin fiber sources used in
papermaking.

In recent years,  secondary  fiber  sources,  such  as  wastepaper  of
various  classifications, have gained increasing acceptance.  In 1976,
more than 22 percent of the fiber furnish in the U.S. was derived from
wastepaper.

STANDARD MANUFACTURING PROCESSES

The  production  of  pulp,  paper,  and  paperboard  involves  several
standard   manufacturing   processes   including   (a)   raw  material
preparation, (b) pulping,  (c) bleaching, and (d) papermaking.  Each of
these processes and their variations are described below.
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Raw Material Preparation

Depending on the form in which the raw materials arrive at  the  mill,
log  washing,  bark  removal,  and chipping may be employed to prepare
wood for pulping.  These processes can require large volumes of water,
but the use of dry bark removal techniques  or  the  recycle  of  wash
water  or  water  used in wet barking operations significantly reduces
water consumption.

Pulping

Pulping is the operation of reducing a cellulosic raw material into  a
form  suitable  for chemical conversion or for further processing into
paper or paperboard.  Pulping processes vary  from  simple  mechanical
action,  as  in  groundwood  pulping,  to  complex  chemical digesting
sequences  such  as  in  the  alkaline,  sulfite,   or   semi-chemical
processes.

Mechanical  Pulping.  Mechanical pulp is commonly known as groundwood.
There are two basic processes:  a) stone groundwood where pulp is made
by tearing fiber from the side of short logs (called billets) using  a
grindstone,  and  b)  refiner  groundwood  where  pulp  is produced by
passing wood chips through a disc refiner.

In the chemi-mechanical modification of the groundwood  process,  wood
is  softened with chemicals to reduce the power required for grinding.
In a relatively new process called  thermo-mechanical  pulping,  chips
are first softened with heat and then disc-refined under pressure.

Mechanical pulps are characterized by yields of over 90 percent of the
original  substrate.   The pulp produced is relatively inexpensive and
requires minimal use of forest resources because of these high yields.
Because mechanical pulping processes do not remove  the  natural  wood
binders   (lignin)  and  resins  inherent  in the wood, mechanical pulp
deteriorates quite rapidly.  The pulp is suitable for use  in  a  wide
variety  of  consumer products including newspapers, tissue, catalogs,
one-time publications, and throw-away molded items.  Natural oxidation
of the impure cellulose causes an observable yellowing  early  in  the
life  of  such papers.  Also, a physical weakening soon occurs.  Thus,
the use of groundwood pulp in the manufacture of higher quality grades
of paper requiring permanence is not generally permissable.

Chemical Pulping.  Chemical pulping involves  the  use  of  controlled
conditions  and  cooking  chemicals  to  yield a variety of pulps with
unique properties.  Chemical pulps are converted into  paper  products
that  have  relatively  higher  quality  standards  or require special
properties.  There are three basic types of chemical  pulping  now  in
common use: a) alkaline, b) sulfite, and c) semi-chemical.

     Alkaline  -  The first alkaline pulping process (developed in the
nineteenth century) was the soda process.  This was the forebearer  of
the  kraft process.  The kraft process produces a stronger pulp and is
currently the dominant pulping process worldwide.  At  present,  there
                                 6R

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is only one operating soda mill in the United States.  All other mills
have been converted to the kraft process.(28)

Early  in  the  twentieth  century, the kraft process became the major
competitor of the sulfite process for some grades of pulp.  Kraft pulp
now accounts for over 80 percent of the chemical pulp produced in this
country and the role of kraft continues to increase.  Although sulfite
is still preferred for some grades of products, sulfite production  is
declining.

Several  major process modifications and achievements have resulted in
the widespread application of the kraft process.   First,  because  of
their  increasing  cost,  chemicals  must  be  recovered  for economic
reasons.  In the 1930's, successful recovery techniques  were  applied
to  this  process;  these  techniques  have  vastly improved in recent
years.  Second, the process was found to be adaptable  to  nearly  all
wood  species.   Its  application  to  the  pulping  of southern pines
resulted in a rapid expansion of kraft pulping to  that  area  of  the
country.(28)  Third,  new  developments  in  bleaching  of kraft pulps
(primarily the use  of  chlorine  dioxide)  spurred  another  dramatic
growth  period  in  the  late  1940's  and  early 1950's.  Use of this
bleaching agent in simplified bleach sequences of four or five  stages
enables   production  of  high  brightness  kraft  pulps  that  retain
strength.

     Sulfite - Sulfite pulps are associated  with  the  production  of
many  types  of  paper,  including  tissue  and  writing  papers.   In
combination with other pulps, sulfite pulps  have  many  applications.
In  addition,  dissolving  pulps   (i.e.,  the highly purified chemical
cellulose  used  in  the  manufacture  of   rayon,   cellophane,   and
explosives)  were  produced  solely  by use of the sulfite process for
many years.

Initially, sulfite pulping involved the use of calcium (lime  slurries
sulfited with sulfur dioxide) as the sulfite liquor base because of an
ample  and  inexpensive  supply of limestone (calcium carbonate).  The
use of calcium as a sulfite base has declined in recent years  because
the  spent liquor from this base is difficult and expensive to recover
or burn.  If spent liquor is not  recovered  or  burned,  it  must  be
discharged as effluent, significantly increasing end-of-pipe treatment
costs.  Attempts to use more than about 10 percent of the spent liquor
in various by-products failed.  Also, calcium use has declined because
the  availability  of  softwoods, which are most suitable for calcium-
based pulping, is diminishing.(29)(30) As a result, at  most  calcium-
based  sulfite  mills, the process has been altered to include the use
of a soluble chemical base  (magnesium,  ammonia,  or  sodium).   This
permits the recovery or incineration of spent liquor.

In  recent  years, some sulfite mills have been converted to the kraft
pulping process and others have been shut-down rather than  incur  the
expense  of  installing recovery/incineration technology or converting
sulfite  processes  to  other  pulping  processes.(30)(31)  Based   on
industry survey responses, calcium-based cooking chemicals are used at

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six  papergrade  sulfite  mills.    A  magnesium  base is used at seven
facilities, an ammonia base at five mills, and a mixed base of  sodium
and calcium is used at one mill.

     Semi-Chemical  -  Early applications of the semi-chemical process
during the nineteenth century involved the cooking  of  chips  with  a
neutral or slightly alkaline sodium sulfite solution.  This process is
called  the  neutral sulfite semi-chemical (NSSC) pulping process.  In
the  1920's,  scientists  at  the  U.S.  Forest  Products   Laboratory
demonstrated  the  advantages of NSSC pulping, and the first NSSC mill
began operation in 1928 for production of corrugating medium.(28)

The NSSC process gained rapid acceptance because  of  its  ability  to
utilize  the  vast  quantities  of  inexpensive  hardwoods  previously
considered unsuitable  for  producing  quality  pulp.(32)   Also,  the
quality  of  stiffness  which hardwood NSSC pulps impart to corrugated
board and the large demand for this material  have  promoted  a  rapid
expansion  of  the process.(28) Both sodium and ammonia base chemicals
have been used in the NSSC process.

In the past, the small size of mills, the low organic content and heat
value of the spent liquor, and  the  low  cost  of  cooking  chemicals
provided  little  incentive  for  large  capital  investment  for NSSC
chemical  recovery  plants.(28)  Somewhat  lower  cost  fluidized  bed
recovery  systems  have  been  extensively  used  at NSSC mills.  With
ammonia-based  pulping,  only  sulfur  dioxide   recovery   (S02_)   is
practiced,  and  recovery  economics  are marginal.  With sodium-based
pulping, a by-product saltcake is obtained which cannot be recycled to
the semi-chemical process.  This material  can  be  sold  for  use  at
alkaline  pulp mills; however, sales have been very limited because of
the variable composition of the salt cake.

Recently, advances have been made  in  semi-chemical  pulping  process
technology  with  respect to liquor recovery systems.  Three no-sulfur
semi-chemical processes have been  developed:  a)  the  Owens-Illinois
process,  b)  the  soda  ash  process,  and  c)  the modified soda ash
process.  The present use of the  patented  Owens-Illinois  soda  ash-
caustic  pulping  process  permits ready recovery of sodium carbonate.
With  a  balanced  caustic  make-up  or  selective  recausticizing,  a
balanced  pulping  liquor  is  assured.   The  process uses a 15 to 50
percent caustic solution  (as Na20), with the  remainder  of  chemicals
consisting  of  soda ash.  Spent liquor is burned in a modified kraft-
type furnace or fluidized bed.  Traditionally, the difficulty has been
in reclaiming sodium sulfite from NSSC liquors containing both  sodium
carbonate and sodium sulfite.

In  the  soda  ash  process, soda ash  is used at 6 to 8 percent of the
oven dried weight of wood charged to the digester.   Spent  liquor  is
burned  in  a  fluidized  bed, and the soda ash  is recovered.  Caustic
make-up provides a balanced pH liquor  for reuse.   The  modified  soda
ash  process  uses  a  small amount of caustic along with the soda ash
(typically 7 to 8 percent NaOH as Na20).(33)
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There are valid reasons for conversion from the standard NSSC  pulping
process:

     1.  A  poor  market  for the saltcake (Na2S04_) by-product derived
     from fluidized bed recovery of NSSC liquors.

     2. High make-up chemical costs, as saltcake cannot be  reused  in
     the  NSSC  process  and  sodium  sulfite  is not produced in most
     recovery schemes.

     3. Sulfur emission problems can result  from  burning  the  waste
     liquors.

Extensive  use  of a kraft-type recovery furnace for chemical recovery
from both kraft and semi-chemical pulping systems  on  a  common  site
(unbleached  kraft/semi-chemical  cross  recovery) is often practiced.
Original practice was to apply all new cooking chemicals (i.e., Na2C03_
and/or Na2S03_) required for the semi-chemical pulping operation; often
a solution of sodium carbonate is  prepared  and  sulfited  with  S02^
Make-up  chemical  requirements  are  adjusted,  along with production
rates, to balance the total  liquor  lost  from  both  the  kraft  and
semi-chemical  pulping  systems.   The ratio of kraft to NSSC is about
4/1 depending upon the overall efficiency of chemical recovery.   Less
NSSC  pulp can be made if the necessary make-up chemicals are added to
the liquor at the recovery furnace (as Na2S04) as in the  conventional
kraft  system.   The  liquor recovered from the kraft recovery furnace
will be comprised primarily of Na2C03_ and Na2S, not Na2S03_ as  desired
for  production  of  NSSC  pulp.   This leads to the historic trend of
producing a balanced pulp ratio with make-up  in  the  form  of  fresh
chemicals added as NSSC liquor.

Recently, the trend is toward the use of kraft green liquor as part of
the semi-chemical cooking liquor.  This eliminates the reliance on 100
percent  new chemicals for the semi-chemical operation.  This requires
adequate evaporator and recovery furnace capacity to process the extra
green liquor required  for  the  semi-chemical  process.   The  latter
approach  can  free the operation of the mill from adherence to strict
production ratios.

Unfortunately, it appears that as  the  use  of  green  liquor  (Na2jS)
increases,  the  resulting pulp is reduced in brightness and strength.
Thus, while complete green liquor pulping has been practiced in a  few
cases, only partial substitution is the likely long-term practice.

Use of_ Secondary Fibers

Processing  of  some secondary fibers allows their use without intense
processing.  Other uses require  that  the  reclaimed  wastepapers  be
deinked, a more rigorous process technique, prior to use.

Non-Deink  Wastepaper  Applications.  Some wastepaper can be used with
little or no preparation, particularly if the wastepaper is  purchased
directly  from  other  mills  or converting operations where a similar
                               71

-------
product grade is manufactured.   Such material  is  usually  relatively
free  of  dirt  and  can sometimes be directly slushed or blended with
virgin pulps to provide a suitable furnish for the papermachine.   The
only cleaning and screening performed in such applications would occur
with  the  combined  stock in the papermachine1s own stock preparation
system.

At mills where low quality paper products  (i.e.,  industrial  tissue,
coarse consumer tissue, molded items, builders'  papers, and many types
of  paperboard)  are  made, extensive use is made of wastepaper as the
raw material furnish.  Such operations typically involve a  dispersion
process  using  warm  recycled  papermachine  white  water followed by
coarse screening to remove gross contamination  and  debris  that  may
have been received with the wastepaper.   More extensive fine screening
and centrifugal cleaners may then be used before the papermaking step.

Manufacture  of  higher  quality products, such as sanitary tissue and
printing  papers,  may  involve  the  use  of  small  percentages   of
wastepaper.  These products require clean, segregated wastepaper and a
more  extensive  preparation  system,  usually  including  a  deinking
system.

Deinking.  Deinking of wastepaper has been commercially applied  since
the  nineteenth  century.   However, large-scale operations that exist
today were developed much  more  recently.   Materials  that  must  be
removed  in  order  to  reclaim  a  useful  pulp include ink, fillers,
coatings, and other noncellulosic materials.  Deinked pulp is used  in
the  manufacture  of  fine  papers,  tissue,  toweling, liner for some
paperboards, molded products, and newsprint.

The use of detergents and solvents,  instead  of  harsh  alkalis,  has
permitted  effective  reuse  of  many previously uneconomical types of
wastepaper.  Similar advances, such as flotation deinking and recovery
of waste sludge with centrifuges, may yield  more  effective  deinking
processes with lower waste loads.

Presently,  however, the secondary fiber field is critically dependent
upon balancing available wastepaper  type  with  the  demands  of  the
product  to  be manufactured.  Upgrading of low quality wastepapers is
difficult and costly, with inherently high discharge of both BOD5^  and
TSS to ensure adequate deinked pulp quality.

Bleaching ojf Wood Pulps

After  pulping, the unbleached pulp  is brown or deeply colored because
of the presence of  lignins  and  resins  or  because  of  inefficient
washing of the spent cooking liquor from the pulp.  In order to  remove
these  color  bodies  from  the pulp and to produce a  light colored or
white product, it is necessary to bleach the pulp.

The degree of pulp bleaching for  paper  manufacture   is  measured  in
terms of units of brightness and  is determined optically using methods
established  by  the  Technical  Association  of  the  Pulp  and Paper
                                 72

-------
Industry (TAPPI).(34) Partially  bleached  pulps  (semi-bleached)  are
used in making newsprint, food containers, computer cards, and similar
papers.   Fully  bleached  pulp  is used for white paper products.  By
bleaching to different degrees, pulp of the desired brightness can  be
manufactured  up  to  a  level  of  92 on the brightness scale of 100.
These techniques are described in detail in a TAPPI monograph.(35)

Bleaching is frequently performed in several stages in which different
chemicals are applied.   The  symbols  commonly  used  to  describe  a
bleaching  sequence  are  shown and defined in Table III-l.  The table
can be used to interpret bleaching "shorthand", which is used in later
sections of this report.  For example,  a  common  sequence  in  kraft
bleaching,  CEDED, is interpreted as follows:

     C = chlorination and washing,
     E = alkaline extraction and washing,
     D = chlorine dioxide addition and washing,
     E = alkaline extraction and washing,  and
     D = chlorine dioxide addition and washing.

Almost  all sulfite pulps are bleached, but usually a shorter sequence
such as CEH is sufficient to obtain bright pulps because sulfite pulps
generally contain  lower  residual  lignin.   This  sequence  involves
chlorination,  alkaline extraction, and hypochlorite application, each
followed by washing.

Mechanical pulps (i.e., groundwood) contain  essentially  all  of  the
wood  substrate including lignin, volatile oils, resin acids, tannins,
and other chromophoric compounds.  The use of  conventional  bleaching
agents would require massive chemical dosages to enable brightening to
levels  commonly  attained  in the production of bleached fully cooked
kraft  or  sulfite  pulps.   Generally,  mechanical  pulps  are   less
resistant  to  aging because of the resin acids still present, and are
used in lower quality, short life paper products  such  as  newsprint,
telephone  directory,  catalogs,  or  disposable  products.  For these
products, a lower brightness is acceptable.  Groundwood may be used as
produced, at a brightness of about 58 to the mid 60's (GE Brightness),
or may be brightened slightly  by  the  use  of  sodium  hydrosulfite,
sodium   peroxide,   or   hydrogen   peroxide.   Generally,  a  single
application in one stage is used, but two stages  may  be  used  if  a
higher brightness is required.

Hydrosulfite  may  be used with conventional equipment.  Bleaching may
be accomplished  by  direct  addition  (without  air)  to  a  tank  or
pipeline.  Gains of 5 to 10 brightness points are possible; washing is
not   always  necessary.   Peroxides  may  be  used  to  give  similar
brightness gains or can be used in series  with  hydrosulfite  stages.
However,  higher consistencies and temperatures are required for cost-
effective  bleaching.   Buffering  agents,   chelating   agents,   and
dispersants are also used to improve bleaching efficiency.

Secondary  fibers  are  often  bleached  to  meet  the requirements of
specific grades.  Again, the choice of bleaching sequence  depends  on
                               73

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                                  TABLE III-l

                               BLEACHING SYMBOLS


Symbol	Bleach Chemical or Step Represented by Symbol	

  A                 Acid Treatment or Dechlorination
  C                 Chlorination
  D                 Chlorine Dioxide Addition
  E                 Alkaline Extraction
  H                 Hypochlorite Addition
  HS                Hydrosulfite Addition
  0                 Oxygen Addition
  P                 Peroxide Addition
  PA                Peracetic Acid Addition
  W                 Water Soak
  ( )               Simultaneous Addition of the Respective Agents
  /                 Successive Addition of the Respective Agents Without
                    Washing in Between

-------
whether  the  processed  stock  is  composed  of  only  fully bleached
chemical pulps or if appreciable groundwood is  also  contained.   For
the  latter,  a brightness touch-up with peroxide or hydrosulfites may
be required.

For deinked groundwood-free  stocks,  bleaching  can  be  employed  to
eliminate  the  color  of  the  dyes  used in coloring or printing the
sheet.  Bleach demand is minimal compared  to  that  in  a  pulp  mill
bleachery.   Usually a single hypochlorite stage may suffice, although
a CH or a CEH sequence may be used.

Papermakinq

Once pulps have been prepared from wood, deinked stock, or wastepaper,
further mixing, blending, and addition of non-cellulosic materials, if
appropriate, are necessary to prepare a suitable "furnish" for  making
most  paper  or board products.  Modern stock preparation systems have
preset instrumentation to control  blending,  addition  of  additives,
refining, mixing, and distribution of the furnish.

Two  or  more  types  of  pulp  are  often  blended to produce desired
characteristics.  Often, relatively long fiber softwood pulp  is  used
to  create  a  fiber network and to provide the necessary wet strength
required during the forming process.  Softwood pulps are used  in  the
production  of high strength, tear resistant paper products.  Softwood
pulps can be blended with shorter fiber hardwood pulps  by  mixing  in
large   agitated  tanks  or  in  continuous  stock  blending  systems.
Hardwood kraft pulp is not as strong as softwood pulp but  contributes
valuable  properties  to the product such as smoothness, opacity, good
printability, and porosity.

To develop the maximum strength possible in paper, the fibers must  be
"refined",   or   mechanically  worked  in  close  tolerance  machines
(refiners).  The fiber structures are  opened,  thus  presenting  more
bonding  surfaces  when the fibers are formed into sheets on the paper
machine and dried.

Many other materials may be used to provide the unique  properties  of
the  many  types  of  paper  used today.  If a printing paper is made,
fillers such as clay, calcium carbonate, talc, or titanium dioxide can
be added to improve smoothness, brightness,  and  opacity.   Increased
ink  or  water  resistance  may  be  derived by the addition of resin,
synthetic sizing, or starch, either during forming or  as  a  separate
application to the semi-dry sheet at the size press.

The  various  papermaking processes have basic similarities regardless
of the type of pulp used or the end-product manufactured.  A layer  of
fiber  is  deposited  from a dilute water suspension of pulp on a fine
screen, called the "wire."  The  wire  retains  the  fiber  layer  and
permits  water  to drain through.  (28) This layer is then removed from
the wire, pressed, and dried.  Two basic types  of  papermachines  and
variations thereof are commonly employed.  One is the cylinder machine
in  which  the  wire  is  on cylinders which rotate in the dilute pulp

-------
furnish.  The other is  the  Fourdrinier  in  which  the  dilute  pulp
furnish  is  deposited  upon  an  endless  wire  belt.  Generally, the
Fourdrinier is associated  with  the  manufacture  of  paper  and  the
cylinder machine with heavier paperboard grades.

Either  a  Fourdrinier or cylinder forming machine may be used to make
paperboard.  The primary operating difference between the two machines
is  the  flat  sheet-forming  surface  of  the  Fourdrinier  and   the
cylindrical-shaped  mold  of  the  cylinder  machine.  In the cylinder
operation, a revolving wire-mesh cylinder rotates in a vat  of  dilute
pulp  picking  up  fibers  and  depositing them on a moving felt.  The
pressing and drying operations are similar to that of the  Fourdrinier
machine.

In   the   Fourdrinier  operation,  dilute  pulp,  about  0.5  percent
consistency, flows from the headbox onto the endless wire screen where
the sheet is formed and through which the  water  drains.   A  suction
pick-up  roll transfers the sheet from the wire to two or more presses
which enhance density and smoothness and remove additional water.   It
leaves  the  "wet  end"  of  the  machine  at  about  35 to 40 percent
consistency and goes through  dryers,  heated  hollow  iron  or  steel
cylinders,  in  the "dry end." Because of its higher speed and greater
versatility, the Fourdrinier is in more common use than  the  cylinder
machine.

With  either  machine,  coatings  may  be applied in the dry end or on
separate coating machines.  After initial drying on the paper machine,
the sheet may be treated in a size press, and then  further  dried  on
the  machine.   Calender  stacks and breaker stacks may be employed to
provide a smoother finish, either after drying or while the  sheet  is
still partially wet.

If  smoothness  and high density are required, calendering is employed
on the machine just before the sheet is wound on a reel.   Control  of
moisture  in  the sheet and of the pressure and number of nips applied
dictates the degree of densification.

It  is  increasingly  common  to  impart   further    improvements   in
appearance,  printability,  water  resistance, or texture by "coating"
the dry paper sheet.  This may be  done  either  on-machine  or  on  a
separate  coater  (i.e.,  off-machine).   Coatings  may  be applied by
rolls, metering rods, air knives, or blades.  The coating commonly  is
a  high  density  water  slurry  of  pigments  and adhesives which are
blended, metered onto the fast moving sheet, and then dryed.   Binders
including various starches, latices, polyvinylacetate (PVA), and other
synthetics  are  now  used.   Other  types  of  coating operations may
involve the use of recoverable solvents for the application of release
agents, gummed surfaces, and other films.

Often with pigment type coatings, another  operation  is  required  to
obtain  the  desired  coated  sheet  smoothness and gloss.  Large high
speed devices similar to calenders are used; these   "super  calenders"
                                76

-------
have  alternating  steel  and  fabric-filled  rolls  that  impart  the
polishing effect.

INDUSTRY PROFILE

Information obtained from the data request program is the main  source
of  information  used  to  develop  a  profile of the pulp, paper, and
paperbpard industry.  In addition, several mills were  identified  for
which  responses  to  the data request survey were not received, which
were  not  operating  at  the  time  of  the  survey,  or  which  were
inadvertently  omitted  from  the program.  EPA developed a profile of
these mills by contacting representatives of the mills,  EPA  Regional
or State authorities, and/or using industry directories.  The industry
profile includes information on the geographical distribution of mills
by  subcategory,  the  method of wastewater discharge, and the type of
production techniques employed.   More  detailed  profile  information
will be presented in later sections of this report.

Geographical Distribution

Table  III-2  presents  the  geographical distribution of mills by EPA
Region for: a) facilities operating as of April 12,  1982,  for  which
responses  to the data request survey were received, and b) facilities
not responding to  or  not  operating  at  the  time  of  the  survey.
Information is presented based on the revised subcategorization scheme
that is discussed in greater detail in Section IV.

Figure  III-l  presents  information  on the total number of operating
facilities by State.  The totals shown are for the 610 operating mills
that responded to the data request program and for  the  64  operating
mills  that  were not included in the program.  A total of 22 mills of
those responding to the data request program are now closed.

Method of Wastewater Discharge

Table II1-3 presents information on the method of wastewater discharge
employed at the operating mills in the  pulp,  paper,  and  paperboard
industry.   At  fifty percent of the mills in the industry, wastewater
is treated on-site in treatment systems operated  by  mill  personnel.
Mills where all or a portion of the wastewater generated is discharged
to a POTW make up 39 percent of the industry.  Mills where 100 percent
of the wastewater generated is recycled or not discharged to navigable
waters (self-contained) make up 8 percent of the industry.  A total of
19  mills  (3  percent) were not categorized as to the method of their
discharge due to insufficient data.

Biological treatment systems are  currently  employed  extensively  at
direct  discharging  pulp,  paper, and paperboard mills to reduce BOD!>
and TSS loads.  Aerated stabilization is  the  most  common  treatment
process  employed.   At  a  relatively  large  number of plants in the
nonintegrated  and  secondary  fibers  subcategories,   only   primary
treatment   is   employed.    Primary   treatment  can  often  achieve
                                 77

-------
                                                                     TABLE  11 1-2

                                                  SUMMARY OK AM.  KNOWN OPERATING  PUI.P, PAI'KR,  AND
                                                          1'Al'ERHOARU HI1.I.S  BY  EPA KKGIUN


                                                                                                          Mi lib  Nol  RcspnmliitR To  Or  Not
                                                "Mills Krspon.J iiijj To Survey       _               _       0|>cr.it ing At Time 01  S»rvt-y
                                                          EPA  Region                                                KPA Region
SulK-dlfgury                   	I   If. JH.  IV.  V   VI   Vf|  VIif   IX   ~X  .Total_     \~  II   HI   IV    V .   VI. ~~VI f VI I f  I X  "x  Tolal

lnlegralf<[ Segment

Dissolving Kraft                    -    -    -     3   -    .   -     ...      3        -------      ---     0
Maikel  Bli'drbed Kialt               1--311-     -21      9        1--)---      -     -   -     t,
B(.T Bleached Kraft                  -    -    -     4   -    2   -     -     -   2      8        -----i-      ---     ]
Alkal iiif-Kine                       315253-     -1-20        -------      ---     0
Unb I rallied Krdft
  o   l.im-rboard                     ---II-    4-     -     -2     17        ...    _-    --      -     .   -     0
  o   B.IK                             ---523-     --111        -------      ...     o
SfUii-Clic-wica)                       1-25811     --119        -    -    -    -    |    -   -      ...     |
llnl.lfdi h.'.l Kralt auj
    Seaii-Chrmicdl                   --13-3-     --3     10        -    -    -    -    -    |   -      ---     t
Dissolving Siilfile Pul[i             ---]---     --5      ft        -------      ---     ()
PdlM-rgidilf Sulfite                  -11-9--     --3     14        -------      ---     0
liioun
-------
                                                             TABLE II 1-2 (c-ont.)


                                                                                                     Mills  Not  Responding To Or Not
                                              Mills  Kcb^ionding To Survey                              Or»eriiting At  Time Of Survey

Siibcdirgnry
No ni ntcgrated-Li ght weight Papers
o I. i ghtwei gtit Papers
o K Jert r ica 1 Papers
NOD intrgraleil-Filter and
Nun woven Papers
Noni integrated Miscellaneous
TOTAL
1

I

;j
3

3
16
101
^ V~A

II

4
-

3
I
1
8
68


ii i i v"

i
i

2 2
1 2
58 96

EPA Htgion
v "vi vn""v(ii "ix

3 -
- - - - -

3 - - - 1
31
l -
_9 r - - _-
160 41 9 2 38


X Totdl

11
4

14
1 9
if,
- _36
37 610


I " |l" III IV V"

- - - - -
1

11 It
11 11
1 2 I_ - _-
8 13 7 11 9

El'A Re;
VI V

-
-

-
_.- :
9 l

                                                                                                                                    X  Total
Includes Pdpergradc Sulfite  (Blow Fit Wash) and  Pdpcrgrade Sulfite (Drun Wash) subcategories.

-------
CC
o
                                                                           FIGURE HI-I
                                  LOCATION OF OPERATING MILLS IN THE INDUSTRY

-------
                     TABLE 111-3

SUMMARY OK METHOD OK DISCHARGE AND 1NPLACE TECHNOLOGY
              All Known Operating Hills

    Method of Uiictiargo    	  	         	  	     Treatment Scheme - Direct Discharger
                   "                                                  ~         ~
Sillu jit-gory
Iiil.e|jr.ilc.-.l Segmriil
DibM-lvjiiK Kr.iK
Hjrkcl Hit-ached Kraft
BCT Bleached Krai I
A 1 ka 1 inr- Kine
Unbleached Krjfl
o Lilierbuarcl
u Bag
Semi -Cheiuica 1
Unl> leached Kr.i 1 1 and
Semi -Clieiui ca 1
Dissolving Snlfitr Pulp
P.ipergrade Snltitc.
C r oiimluood -Thermo -
Mechanical
Crmmclwocicl-CNN Papers
G runiitlwoocl -Fi nti Papers
I iilt-ifi a ted Mi sc c.* 1 1 a neons
Secondary l-ibers Segment
u Fine
ci Ni.-wsprinl
o Tissur
liSMiif from Wa&tefianer
Prtj'crboa rd From Wastepapt'r
Wai»tepaper- Molded
Prodnc-ts
Riiilclerb1 Paper 
1 4

A
4
9
89

S
4
16
19
152

IS

60

22


J.J
/
Direi t

3
12
9
16

16
11
IS

9
6
11

3
2
7
62

3
1
11
10
40

4

4

7


13
2
Indirect No
Indirect Primary & Direct Contained Unknown Treatment

_ _
1 2
-
31 ...

I ...
- - -
2 ... l

1 - - 1
-
3 - -

1
2 - ...
2 - -
IS 1 731

11 ...
3 - -
3 - 11-
21 - 6 - 2
72 16 - 19 5 1

K - - 1 2 2

29 S 18 4

93 1-2 1


94 232
:i 2

Only ASB

1
1
3
2

1 3
3
1

-
1
2

1
-
-
4 14

_
-
3 1
2
1 8

1 1

1

2 1


6 3
1 1
ASB w/
Pond

1
3
4
4

3
3
8

5
-
-

-
-
-
14

1
-
-
3
13

-

2

-


1
-
ASB/w
Holding
La£oon

.
2
1
-

1
2
-

2
-
-

-
-
-
3

_
-
-
1
-

-

-

-


-
-
Activated
S 1 udge

1
3
-
5

1
2
3

1
2
3

1
1
6
19

2
-
6
-
7

-

-

2


1
-
Oxida-
tion
Pond Olhei

_
1
1
1 4

4 3
1
5

1
3
6

1
1
1
1 7

_
1
1
2
10

-

1

1


2
-

-------
                                                                                       TABLE  111-3 (coiit.)
       _   	 _  Method  o|_JHschajtge _    	
                 Indirect
                    w/      Indirect    Self-
                                                                                                                             __Treat-pent Schegie • Direct Discharger
                                                                                                                 No
                                           Niunber
                                             of                         v/      Indirect    Self-              External    Prinary
              Suhcategqry  _         __   .^fl*!^8 j9JJt?c_t   IP^i-f^SL  '>£l5ary	^^l?*f*r^ Coiitaincd  Unknown  Treatment    Onl
              Nuuiidegrateif-Tissue  Papera  25
              NouIntegra Led-Lightweight
                Papers
                o  Lightweight Papers       11
                o  Electrical Papers         5
              Nonintegrated-KiIler  and
                   Nunvoverl r*ape rs          14
              Nuiiililegrated-r'aperboa rd     16
              Niijiiiitfgratcd Hist'el Janeous  40
                   TOTAL
                                           674
                                                    12
  5
  6
 23

338
                                                              11
  7
 10
  9

202
                                                                                                                  1
 2

 3

41
                                                                                  ia
                                                                                             5

                                                                                            56
                                                                                                      19
                                                                                                                 14
               Includes Kine Bleached  Kr«*f t and Soda subcalegorieti.
               Include:, Papcrgrjde Sultite (Blow Pit Wash) 
-------
substantial BOD5^ reductions if a  large  percentage  of  the  BODj[  is
contained in settleable solids.

Production Profile

Pulp.   Many  types  of pulp are manufactured.  Some types, because of
fiber length and strength, are more suitable for production of certain
paper grades than others.  The desired pulp can be produced by varying
the type(s) of raw material used,  selecting  an  appropriate  pulping
process,  varying  the type of cooking chemicals used, and varying the
time of cook.  Through the use of improved processing techniques, most
paper and board are comprised of more than one type of pulp to achieve
desired properties.

Total  daily  pulp  production  is  listed  in  Table  III-4  by  pulp
type.(36)(37)

Paper  and  Paperboard  Products.   The  pulp,  paper,  and paperboard
industry manufactures a diversity of products.  The various grades  or
types  of products are delineated according to end use and/or furnish.
The basic differences in the various papers include durability,  basis
weight,   thickness,  flexibility,  brightness,  opacity,  smoothness,
printability,  strength,  and  color.   These  characteristics  are  a
function  of  raw material selection, pulping methods, and papermaking
techniques.

In addition to variations in stock preparation and  sheet  control  on
the  papermachine,  the  papermaking  operation  may enhance the basic
qualities of paper or  may  contribute  other  properties  (i.e.,  wet
strength,  greaseproofness,  printing  excellence)  through the use of
additives.  These additives include a variety of  substances  such  as
starch, clay, and resins used as fillers, sizing, and coatings.

Table   III-5   presents  a  general  list  of  the  various  products
manufactured by the industry.(38)  The grades listed are, for the most
part, self-explanatory.  Definitions according to industry  usage  may
be  found  in  the  publication,  Paper  and  Pulp  Mill  Catalog  and
Engineering Handbook, Paper Industry  Management  AssociationTPIMA),
1978.(37)  In  Table  III-6,  production  statistics are presented for
products  grouped   under   the   following   major   classifications:
newsprint, tissue, fine papers, coarse papers-packaging and industrial
converting, paperboard, and construction products.

Newsprint  includes  paper  made  largely  from  groundwood  pulp used
chiefly in the printing of newspapers.

Tissue is  set  apart  from  other  paper  grades  and  includes  many
different  types  of tissue and thin papers.  These range from typical
sanitary tissue products to industrial tissue which includes  packing,
wadding,  and  wrapping papers.  Also many special purpose grades with
unique process and product requirements such as glassine, greaseproof,
electrical, and cigarette papers are produced.
                                83

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                           TABLE III-4

                ESTIMATED PULP PRODUCTION - 19771
                                             Production
Pulp Type	(short tons x 1,000)

Dissolving and Special Alpha                    1,465
Sulfite-Bleached                                1,653
       -Unbleached                                389
Alkaline-Bleached                              14,929
       -Semi-Bleached                           1,523
       -Unbleached                             18,411
Groundwood                                      4,481
Semi-Chemical                                   3,876
Other Mechanical                                2,941
Screenings                                        110

Total                                          49,777
Market Pulp                                     4,881
Waste Paper Used                               14,015
 Sources used were Lockwood's Directory of the Paper and
 Allied Trades, Vance Publishing (1978), and Paper and
 Pulp Mill Catalog and Engineering Handbook, Paper Indus-
 try Management Association (1978).(36)(37)
2
 Includes insulation and hard-pressed wood fiberboard not
 evaluated within the scope of this study.

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                                   TABLE III-5
                   PAPER AND PAPERBOARD PRODUCTS CF INDUSTRY
A.  Paper
B.   Paperboard
I.   Printing, Writing and Related
    a.  Newsprint
    b.  Groundwood paper, ancoated
        1.  Publication and printing
        2.  Miscellaneous groandwood
    c.  Coated printing and converting
        1.  Coated, one side
        2.  Coated, two sides
    d.  Book paper, uncoated
        1.  Publication and printing
        2.  Body stock for coating
        3.  Other converting and mis-
            cellaneous book
    e.  Bleached bristols, excluding
        cotton fiber, index, and bogus
        1.  Tab, index tag and file
            folder
        2.  Other uncoated bristols
        3.  Coated bristols
    f.  Writing and related papers not
        elsewhere classified
        1.  Writing, cotton fiber
        2.  Writing, chemical woodpulp
        3.  Cover and text
        4.  Thin paper

II.  Packaging and Industrial Convert-
     ing
     a.  Unbleached kraft packaging
         and industrial converting
         1.  Wrapping
         2.  Shipping sack
         3.  Bag and sack, other than
             shipping sack
         4.  Other converting
               Glassine, greaseproof
               and vegetable parchment
     b.  Special industrial paper
I.   Solid Woodpulp Furnish
    a.   Unbleached kraft packaging
        and industrial converting
        I.  Unbleached linerboard
        2.  Corrugating medium
        3.  Folding carton type
        4.  Tube, can, and drum
        5.  Other unbleached packaging
            and industrial converting
            kraft
    b.   Bleached packaging and indus-
        trial converting (85% or more
        bleached fiber)
        1.  Folding carton type
        2.  Milk carton
        3.  Heavyweight cup stock
        4.  Plate, dish, and tray
        5.  Linerboard
        6.  Tube, can, and drum
        7.  Other, including solid
            groundwod pulp board
    c.   Semi-chemical paperboard

II.   Combination Furnish
     a.   Combination-shipping con-
         tainer board
         1.  Linerboard
III.
III. Tissue and Other Machine Creped
     a.  Sanitary paper
         1.  Toilet tissue
         2.  Facial tissue
         3.  Napkin
         4.  Toweling, excluding wiper
             stock
         5.  Other sanitary stock
     b.  Tissue, excluding sanitary and
         thin
         3.   Container chip and filler
             .  Combination-bending
             .  Combination-nonbending
             .  Gypsum linerboard
             .  Special packaging and
               industrial converting

     Construction Products
     a.   Wet machine board
     b.   Construction paper and board
            Construction paper
'Pos'-'s Pulp .ind Pap^r Directory, .Miller Fref-mnn Publications, San Francisco,
 California, 1979 Edition.(38)

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                              TABLE II1-6

                         PRODUCTION STATISTICS
                PAPER AND PAPERBOARD PRODUCTS INDUSTRY
                                                  Production
Product	(short tons x 1000)

Paper
     Newsprint                                       3,515
     Tissue                                          4,097
     Fine                                           13,929
     Coarse - Packaging and Industrial Converting    5,740

Paperboard                                          27,881
Construction Products                                5,567


 Source was Lockwood's Directory of the Paper and Allied Trades,
 Vance Publishing (1978).(36)
                                 Bfo

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Fine papers include printing, reproductive, and writing papers.

Packaging  and  industrial  converting  coarse  papers  include  kraft
packaging papers used for grocery and shopping bags, sacks and special
industrial papers.

Paperboard includes a wide range of types and weights of products made
on  both  cylinder  and Fourdrinier machines for packaging and special
purposes.  Paperboard is  made  from  various  pulps,  wastepaper,  or
combination  furnishes.   Board  products  include  such items as shoe
board, automotive board, and luggage board, as well as  common  liner,
corrugating,  box board, chip and filler, and gypsum board.

Construction products include various paper and board products.  Paper
products  include  sheathing  paper,  roofing  felts  (including  roll
roofing paper and shingles), and asbestos filled papers.

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                              SECTION IV

                          SUBCATEGORIZATION


INTRODUCTION

The purpose of subcategorization is to group together mills of similar
characteristics   so   that   effluent   limitations   and   standards
representative of each group can be developed.  This subcategorization
scheme  enables  permits  to  be  written  on a uniform basis.  In the
original (Phases I  and  II)  rulemaking,  EPA  recognized  two  major
industry  segments:  integrated and nonintegrated.  In recent efforts,
EPA has  also  recognized  the  secondary  fibers  segment  to  better
characterize  the  pulp, paper, and paperboard industry.  The original
subcategorization scheme established by the Agency follows:

Integrated                              Secondary Fibers

Unbleached Kraft                        Deink
NSSC - Ammonia                          Paperboard from Wastepaper
NSSC - Sodium                           Builders' Paper and Roofing Felt
Unbleached Kraft - NSSC                 Tissue from Wastepaper
     (Cross Recovery)
Dissolving Kraft
Market Bleached Kraft                   Nonintegrated
BCT Bleached Kraft
Fine Bleached Kraft                     Nonintegrated-Fine Papers
Soda                                    Nonintegrated-Tissue Papers
Papergrade Sulfite (Blow Pit)
Papergrade Sulfite (Drum Wash)
Dissolving Sulfite Pulp
Groundwood - Coarse,  Molded, News (CMN) Papers
Groundwood - Fine Papers
Groundwood - Thermo-Mechanical
Groundwood - Chemi-Mechanical

The factors considered in identifying these subcategories included raw
materials used, products manufactured, production processes  employed,
mill size,  mill age,  and treatment costs.

As  part  of  the  BAT  review  program, the Agency collected data for
operating mills in the pulp,  paper,  and  paperboard  industry.   EPA
reviewed  the  original  subcategorization  scheme to determine if the
subcategories adequately represent current  industry  characteristics.
This  review  led  to  the  identification  of  four new subcategories
representative of portions not recognized in the original pulp, paper,
and  paperboard  subcategorization  scheme.    EPA  also   made   other
revisions to several  subcategories of this industry.

Conventional   pollutant   data   were   reviewed   to  determine  the
relationship  of  raw  wastewater  characteristics  to  the  processes
employed  and  the  products manufactured at mills in the pulp, paper,

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and paperboard industry.   In addition,  EPA  gathered  toxic  pollutant
data  to  evaluate  the  validity  of  the subcategorization scheme in
accounting for toxic pollutant generation.

The results of these analyses are described below  for  earh  industry
segment.

INTEGRATED SEGMENT

The original subcategorization scheme included 16 subcategories within
the integrated segment.  EPA reviewed the raw waste characteristics of
mills in this segment to determine if these mills still conform to the
original  subcategory  definitions  or if differences exist because of
process or product variations.  Based on this review, the  Agency  has
concluded  that  the  original  subcategorization  scheme is generally
representative of the integrated segment.

Conventional pollutant and flow data support segmentation  to  account
for  the  different  pulping  processes:  alkaline   (kraft  and soda),
sulfite,   semi-chemical,   and   groundwood   (refiner   or    stone,
thermo-mechanical, and chemi-mechanical).  In addition, the production
of  dissolving  pulps,  both  alkaline  and  sulfite,  results  in the
generation of relatively large quantities of wastewater and wastewater
pollutants   and   should   continue   to   be   recognized   in   the
subcategorization   scheme.    Mills   where   pulp  is  bleached  are
characterized by  higher  waste  loadings  and  must  continue  to  be
recognized separately.

In  the original efforts, there were two subcategories for mills where
the  neutral  sulfite  semi-chemical  pulping  process   (sodium   and
ammonia-based)  is  used.   However,  the  original  subcategorization
scheme did not account for the full  range  of  semi-chemical  pulping
operations  that  now  exist  (see  Section III).  The neutral sulfite
process is only one type of semi-chemical  process,  and  its  use  is
decreasing.  Available data do not support the development of separate
subcategories  for  the  new  semi-chemical  processes.   In fact, the
Agency has determined that a  single  semi-chemical  subcategory  best
represents  all  variations  of  this  pulping  process.   This single
subcategory includes mills in  the  original  ammonia-based  NSSC  and
sodium-based  NSSC subcategories and also mills where other variations
of the semi-chemical process are used.

Similarly, EPA determined that a new subcategory, the unbleached kraft
and semi-chemical subcategory, should be established  to  include  all
mills   within   the   original   unbleached   kraft-neutral   sulfite
semi-chemical (cross recovery) subcategory and those mills where  both
the unbleached kraft and another type of semi-chemical pulping process
(i.e.,  green  liquor) are used on-site.  Available  data indicate that
there are no significant differences  in  wastewater  or  conventional
pollutant  generation at mills where the neutral sulfite semi-chemical
pulping process or any other semi-chemical process are used.

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The original subcategorization scheme included  the  unbleached  kraft
subcategory  which covered all mills where unbleached linerboard, bag,
and other unbleached products are produced  using  the  kraft  pulping
process.   EPA reviewed available data and determined that mills where
bag and other mixed products are manufactured have  higher  water  use
and  BODj[  raw  waste  loadings  than  mills  where only linerboard is
produced.  Therefore, two product sectors were established within  the
unbleached  kraft  subcategory  to account for these differences.  The
product sectors are  (a) linerboard and (b) bag and other products.

Based on current data, there is only one mill where the  soda  pulping
process is used.  At this mill, fine bleached papers are produced.  In
the  soda  process,  which  is similar to the kraft pulping process, a
highly alkaline sodium hydroxide cooking liquor is used as compared to
the sodium hydroxide and sodium sulfide cooking  liquor  used  in  the
kraft process.  The raw waste loadings and flow characteristics of the
soda  mill  are  similar  to those of mills in the fine bleached kraft
subcategory.  Accordingly, BAT effluent limitations, NSPS,  PSES,  and
PSNS  are  identical  for  both  the  soda  and  fine  bleached  kraft
subcategories.  However,  because  of  the  familiarity  of  permitting
authorities  and  representatives  of affected mills with the original
subcategorization scheme  and  the  format  of  the  Code  of_  Federal
Regulations,  EPA decided that the fine bleached kraft subcategory and
the soda subcategory should remain as separate subcategories and  that
the  BPT  effluent  limitations promulgated for these subcategories in
1977 should not be revised.  [For purposes of  data  presentation  and
development  of  BAT  effluent  limitations, NSPS, PSES, and PSNS, the
soda mill has been grouped with the fine bleached kraft mills to  form
a new mill grouping called "alkaline-fine."]

In  comments  on  the  January  1981  proposed regulation (46 FR 1430,
January 6, 1981), industry  representatives  suggested  that  the  BCT
bleached  kraft  and  fine  bleached  kraft  subcategories  should  be
redefined based on the ash or filler content  of  the  final  product.
They provided no data to support their argument but proposed that fine
bleached kraft mills where less than 12 percent filler are used should
be  redefined  as  BCT  bleached  kraft  mills and that all mills with
greater than 12 percent filler  should  continue  to  be  called  fine
bleached  kraft  mills.  In addition, the commenters proposed that the
redefined fine bleached kraft subcategory should have  less  stringent
limitations than those of the BCT bleached kraft subcategory.

Based on industry's comments, EPA evaluated all available data on fine
bleached  kraft  mills  with  less than 12 percent filler.  Regression
analyses  indicate  that  there  is   no   statistically   significant
relationship between percent filler and raw waste generation.
                               91

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In fact, as shown below, raw waste loads at fine paper mills with less
than  12  percent  filler  more  closely resemble fine rather than BCT
bleached kraft mill characteristics.
                                      Average Raw Waste Load
Mill Grouping

BCT Bleached Kraft
  Subcategory

Fine Bleached Kraft
  Subcategory

Fine Bleached Kraft
  Mills with Less Than
  12 Percent Filler
     Flow
147.4 kl/kkg
(35.4 kgal/ton)

128.7 kl/kkg
(30.9 kgal/ton)

109.9 kl/kkg
(26.4 kgal/ton)
    BODS

 38.4  kg/kkg
(76.7  Ib/ton)

 38.6  kg/kkg
(67.2  Ib/ton)

 31.3  kg/kkg
(62.5  Ib/ton)
      TSS

 66.5 kg/kkg
(133.0 Ib/ton)

 75.0 kg/kkg
(150.0 Ib/ton)

 35.3 kg/kkg
(70.5 Ib/ton)
Based  on  these  data,  EPA  made
subcategorization scheme or changes
         no   changes   to   the   original
         in subcategory definitions.
At  the time of the data request program,  there were three mills where
the groundwood-chemi-mechanical pulping process was used.   Because  of
the  limited  number  of  mills  where  this  process  is employed and
inherent differences in chemicals used at  these  mills  to  produce  a
variety  of final products,  insufficient data are available to develop
effluent limitations guidelines.  At  this  time,  EPA  is  unable  to
determine  the effects of chemical usage in the pulping process on raw
waste generation.  The groundwood-chemi-mechanical subcategory remains
as defined in the previous rulemaking; however,  national   regulations
are   reserved.   Permits  for  mills  in   this  subcategory  will  be
determined on a case-by-case basis.   It should be noted that all toxic
pollutants detected in discharges from mills in this subcategory  were
present  in  amounts  too small to be effectively reduced by available
technologies.

In  the  previous  rulemaking  efforts,   three   subcategories   were
established  to  characterize  the sulfite pulping process: dissolving
sulfite pulp, papergrade  sulfite  (blow  pit  wash),  and  papergrade
sulfite  (drum  wash).   Because process differences exist between the
manufacture  of  dissolving  sulfite  pulp  and  the  manufacture   of
papergrade sulfite pulp resulting in significantly different raw waste
characteristics, the dissolving sulfite pulp subcategory will continue
to  be  recognized  as  a separate subcategory with allowances for the
different types of pulps manufactured (nitration, viscose,  cellulose,
and acetate).

EPA's   review   of   available  data  indicate  that  no  significant
differences exist between mills in the two original papergrade sulfite
subcategories  due  to  the  types  of  washing  process  employed  or
condenser  used.   The Agency has determined that a single factor, the
percentage of sulfite pulp produced on-site, is a better indicator  of
differences in raw waste loadings at papergrade sulfite mills than the

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type  of  washing  system  or  condensers  employed.   Therefore,  BAT
effluent limitations,  NSPS, PSES,  and  PSNS  are  identical  for  the
papergrade  sulfite (blow pit wash) and papergrade sulfite (drum wash)
subcategories.  However,  because  of  the  familiarity  of  permitting
authorities  and  representatives  of affected mills with the original
subcategorization scheme  and  the  format  of  the  Code  of_  Federal
Regulations,  EPA  decided that the papergrade sulfite (blow pit wash)
and papergrade sulfite (drum  wash)  subcategories  should  remain  as
separate   subcategories   and   that  the  BPT  effluent  limitations
promulgated for these subcategories in 1977  should  not  be  revised.
[In  this rulemaking effort, data for mills in both papergrade sulfite
subcategories have  been  combined  in  the  development  of  effluent
limitations and standards.]

In   comments   received   on   the   proposed   regulation,  industry
representatives recommended that a distinction should be made  between
fine  and tissue production at papergrade sulfite mills.   EPA examined
raw waste load data  for  both  papergrade  sulfite  subcategories  to
determine  if  significant  differences exist due to the production of
fine and tissue papers.  The Agency  determined  that  no  significant
differences  in  raw  waste load flow, BODj[, or TSS exist between fine
and tissue mills.  Thus,  there is  no  justification  for  a  separate
tissue  and  fine paper delineation.  EPA found that the percentage of
sulfite pulp produced  on-site  is  a  much  more  significant  factor
affecting  raw  waste  load  than  the  type  of product manufactured.
Promulgated regulations recognize this factor through  the  use  of  a
flow  model that accounts for the effect of varying degrees of sulfite
pulping on raw waste generation (see Section V).

SECONDARY FIBERS SEGMENT

As noted previously, EPA has identified secondary  fiber  mills  as  a
separate  segment of the pulp, paper, and paperboard industry.  In the
original rulemaking effort, four subcategories  were  recognized  that
can  be  considered  to be a part of the secondary fibers segment: the
deink,  paperboard  from  wastepaper,  tissue  from  wastepaper,   and
builders' paper and roofing felt subcategories.

Mills  where molded products are manufactured from wastepaper were not
addressed in the  original  subcategorization  scheme.   Where  molded
products  are  produced,   the  wastepaper furnish is processed without
deinking.  Products include  molded  pulp  items  such  as  fruit  and
vegetable  packs,  throw-away  containers, and display items.  Because
waste characteristics for  molded  products  mills  are  not  properly
represented  by  any of the original secondary fibers subcategories, a
new subcategory, the wastepaper-molded products subcategory, has  been
established to include these mills.

Mills  where  paper  is  produced from wastepaper after deinking  were
included  in  the  original  subcategorization  scheme  in  the  deink
subcategory.   The principal products at these mills include printing,
writing, and business  papers,  tissue  papers,  and  newsprint.   EPA
reviewed  data  for this subcategory to study the relationship between

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the type of product manufactured and raw waste loadings.  As discussed
in Section V,  distinct  differences  exist  for  mills  where  tissue
papers,  fine  papers, or newsprint are produced.   As shown in Figures
V-26  and  V-27,  no  definitive  relationship  exists   between   the
percentage of deink pulp produced on-site and the associated raw waste
characteristics.   Therefore,   the  Agency  determined  that the deink
subcategory should remain as previously defined but  that  regulations
should  reflect  differences  in the production of tissue papers, fine
papers, and newsprint.

During the comment period following proposal, industry representatives
suggested that the paperboard from wastepaper  subcategory  should  be
modified  to account for differences in raw waste loads resulting from
the  processing  of  recycled  corrugating  medium  compared  to   the
processing of other types of recycled wastepaper.   Industry commenters
stated   that   paperboard   from   wastepaper  mills  where  recycled
corrugating medium is processed have experienced higher BODS^ raw waste
loads today than in 1976  (the  year  generally  represented  by  data
presented in Section V).  In 1976, the average BOD5_ raw waste load for
mills  where a 100 percent corrugating medium furnish is processed was
11.2 kg/kkg (22.4 Ib/ton).   However,  representatives  of  two  mills
where  a 100 percent corrugating medium furnish is processed submitted
data which reveal that the average BOD5_ raw waste load  has  increased
from  about  10  kg/kkg (20 Ib/ton) in 1976 to the present level of 23
kg/kkg (46 Ib/ton).  Additional supportive data were provided  on  the
quantity  of extractable BOD!> now present in waste corrugating medium.
EPA  has  recognized  this  increase  in  BODS^  raw  waste   load   by
establishing  two  subdivisions  of  the  paperboard  from  wastepaper
subcategory: (a) the corrugating medium furnish  subdivision  and  (b)
the noncurrugating medium furnish subdivision.

In  addition,  industry  commenters stated that mills where linerboard
products are produced from  wastepaper  experience  higher  raw  waste
loads   than   other  paperboard  from  wastepaper  mills  because  of
linerboard product  requirements.   EPA  compared  average  raw  waste
characteristics  of  all  mills  in  the  paperboard  from  wastepaper
subcategory  to  raw  waste  characteristics  of  mills  manufacturing
varying  percentages  of:  (a) linerboard products, (b) linerboard and
corrugating products, and (c)   linerboard,  corrugating,  and  folding
boxboard  products.   No  significant correlations were apparent.  EPA
also  performed  specific  statistical  analyses   to   determine   if
significant  relationships  exist between BOD5_ raw waste loads and the
following independent variables:  (a) type of raw  materials  used  as
furnish,  (b)  product  type,   (c) pulper yield, and (d) mill size (as
total production).  Again, no significant correlations were  apparent.
In  the paperboard from wastepaper subcategory, linerboard is commonly
produced from recycled corrugating medium.  It is  likely  that  these
commenters have experienced the same increases in BODS^ raw waste loads
due  to  the  processing  of  recycled corrugating medium as discussed
previously.   Therefore,  establishment  of  the  corrugating   medium
furnish  subdivision  accounts  for  this BOD5_ increase and no further
segmentation of the subcategory is warranted.

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NONINTEGRATED SEGMENT

In the original rulemaking effort, EPA established  two  subcategories
in  the  nonintegrated  segment  of  the  pulp,  paper, and paperboard
industry: nonintegrated-fine papers and  nonintegrated-tissue  papers.
At nonintegrated mills where other types of products are produced, BPT
permits  were  written  on  a  case-by-case basis.  In this study, EPA
reviewed data on process and  product  differences  in  an  effort  to
further  subcategorize  this  industry  segment.  Other major types of
products manufactured at mills in this segment  include lightweight and
thin papers, filter and nonwoven  papers,  paperboard,  and  specialty
items.   Because  the  basic  manufacturing  process is similar at all
nonintegrated mills, EPA investigated the effects of product  type  on
raw waste characteristics.

Based   on   a   review  of  the  raw  wastewater  characteristics  of
nonintegrated mills, EPA established three additional subcategories to
account   for   the   manufacture    of    various    products:    the
nonintegrated-lightweight  papers,  nonintegrated-filter  and nonwoven
papers,  and  nonintegrated-paperboard  subcategories.   Additionally,
within  the  nonintegrated-lightweight  papers subcategory, electrical
grade products are manufactured at  several  mills;  at  these  mills,
larger  quantities  of  wastewater  are discharged than at mills where
electrical grades are not produced.  Therefore,  effluent  limitations
and standards account for this higher wastewater discharge.

In  comments  on  the  January  1981  proposed  regulations,  industry
commenters suggested that the  nonintegrated-fine  papers  subcategory
should  be  further  segmented  to  account  for  the higher raw waste
loadings typical of mills where cotton fibers make up part of the  raw
material  furnish.   They  claimed that small mills where less than 91
kkg (100 tons) per day of product are manufactured  also  have  higher
raw  waste  loads  than  do larger mills.  Other commenters complained
that the proposal was unclear as to whether nonintegrated mills  where
fine  papers  are  produced from both wood pulp and cotton fibers were
included in the nonintegrated-fine papers subcategory.  Some requested
that EPA establish limitations for  these  cotton  fiber  mills  on  a
case-by-case basis and exclude them from the nonintegrated-fine papers
subcategory.

In   response   to   these   comments,   the   Agency  reexamined  the
subcategorization scheme for the nonintegrated segment  of  the  pulp,
paper,  and  paperboard  industry and evaluated all available data for
nonintegrated mills where fine papers are produced.

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As shown below, EPA found that mills where a significant  quantity  of
cotton  fibers  are contained in the product (equal to or greater than
four percent of the total product)   have  significantly  higher  water
usage  and  BOD5_  raw waste loads than other nonintegrated mills where
fine papers are produced.
     Furnish

     All mills where the
     total product contains
     less than 4% cotton
     fibers

     All mills where the
     total product contains
     4% or more cotton fibers
  Average Raw Waste Load
 Flow                BODS
 52.2 kl/kkg
(12.5 kgal/ton)
 124.4 kl/kkg
 (29.8 kgal/ton)
 10.9 kg/kkg
(21.8 Ib/ton)
 18.0
(35.9
kg/kkg
Ib/ton)
The Agency concluded that mills where a significant quantity of cotton
fibers are used in the raw material are substantially  different  from
other  mills  in  the nonintegrated-fine papers subcategory where only
wood pulp is processed.   Therefore, EPA established a separate  cotton
fibers  subdivision  of   the  nonintegrated-fine  papers  subcategory.
Because the Agency has sufficient data to establish  uniform  national
standards  and  limitations  for  this  subcategory  subdivision,  EPA
rejected the suggestion  to rely on case-by-case limitations.

The Agency investigated  industry's other contention that  small  mills
have  higher  raw  waste  characteristics  than the other mills in the
nonintegrated-fine papers subcategory.  EPA removed  the  eight  mills
where  cotton  fibers  constitute  a  significant portion of the total
product from the data base since they are now a  separate  subdivision
of  the  nonintegrated-fine  papers  subcategory.   (All of the cotton
fiber mills are small in that less than 91   kkg  (TOO  tons)  of  fine
papers  are produced per day.)   EPA separated the remaining mills into
the following groups:  (a) mills where more than 91 kkg (100 tons)  of
paper  are  produced per day and (b) mills where less than 91 kkg (100
tons) of paper are produced per day.  The raw  waste  loads  for  both
groups   are   substantially   the   same.     Therefore,   no  further
subcategorization based  on size is warranted.

Another group of nonintegrated mills where unique grades  of  products
are  manufactured  could  not  be  further divided into subcategories.
Permits  for  these  mills  will  continue  to  be  established  on  a
case-by-case basis.
                                96

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MISCELLANEOUS MILLS

The  subcategorization  scheme  does not account for all mills in each
industry segment because of the complex variety of  pulping  processes
employed,   ttie   different   products  manufactured,  or  because  no
subcategory exists within which  a  particular  mill  can  be  placed.
Mills  that  do not logically fit the revised subcategorization scheme
are  included  in  miscellaneous  mill  groupings  in   each   segment
(integrated-miscellaneous,    secondary    fibers-miscellaneous,   and
nonintegrated-miscellaneous).    Permits   for   all   mills   in   the
miscellaneous  groupings  will be established on a case-by-case basis.
For  many  mills,  permits  can  be  written  by  prorating   effluent
limitations and standards from the appropriate subcategories; however,
for  other  mills,  this  will  not be possible because operations are
employed that  are  not  characteristic  of  any  of  the  subcategory
delineations.

IMPACT OF TOXIC POLLUTANT DATA

As  discussed  in  Section  II  and in Section VI, EPA conducted toxic
pollutant sampling programs to determine the level of toxic pollutants
discharged from mills in each of the subcategories.  This program  was
designed  to  take  into account the revised subcategorization scheme.
EPA reviewed the  analytical  results  to  determine  if  the  revised
subcategorization   scheme   adequately   addresses   toxic  pollutant
discharges.  Available toxic pollutant data, summarized in Section VI,
support  the  revised  subcategorization   scheme.    Specific   toxic
pollutants  are  present  in  pulp,  paper, and paperboard wastewaters
because of the type of  bleaching  process  employed  (chloroform  and
zinc)   or   because   of   their   addition   as   process  chemicals
(trichlorophenol     and     pentachlorophenol).       The      revised
subcategorization  scheme  adequately  accounts  for  the  presence or
generation  of  toxic  pollutants  and  allows  for  establishment  of
effluent limitations and standards to ensure their control.

SUMMARY

In summary, after reviewing the original subcategorization scheme, EPA
made several revisions.   Four new subcategories were identified, while
more  subtle  revisions have been made for several other subcategories
(i.e.,   product  allowances,  adjustments for furnish used, allowances

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for   percentage
subcategorization

Integrated
                   of   pulp
                  scheme is as
                               produced
                               follows:
on-site).
The
revised
                         Pit Wash)
                         Wash)
                             and
                                             Secondary Fibers

                                             Deink
                                               o  Fine Papers
                                               o  Tissue Papers
                                               o  Newsprint
                                             Tissue from Wastepaper
                                             Paperboard from Wastepaper
                                               o  Corrugating Medium
                                                    Furnish
                                               o  Noncorrugating Medium
                                                    Furnish
                                             Wastepaper-Molded Products
                                             Builders' Paper and Roofing
                                               Felt

                                             Nonintegrated

                                             Nonintegrated-Fine Papers
                                               o  Wood Fiber Furnish
                                               o  Cotton Fiber Furnish
                                             Nonintegrated-Tissue Papers
                                             Nonintegrated-Lightweight
                                               Papers
                                               o  Lightweight Papers
                                               o  Lightweight Electrical
                                                    Papers
                                             Nonintegrated-Filter and
                                               Nonwoven Papers
                                             Nonintegrated-Paperboard

The  subcategories  that form the basis of the promulgated regulations
are defined as follows:

Dissolving Kraft

This subcategory includes  mills  where  a  highly  bleached  pulp  is
produced  using  a  "full  cook"  process  employing a highly alkaline
sodium hydroxide and sodium sulfide cooking liquor.  Included  in  the
manufacturing process is a "pre-cook" operation termed pre-hydrolysis.
The  principal  product  is  a highly bleached and purified dissolving
pulp used principally for the manufacture of rayon and other  products
requiring  the  virtual  absence  of  lignin  and  a  very  high alpha
cellulose content.

Market Bleached Kraft
Dissolving Kraft
Market Bleached Kraft
BCT (Board, Coarse, and
  Tissue) Bleached Kraft
Fine Bleached Kraft
Soda
Unbleached Kraft
  o  Linerboard
  o  Bag and Other Products
Semi-Chemical
Unbleached Kraft and Semi-Chemical
Dissolving Sulfite Pulp
  o  Nitration
  o  Viscose
  o  Cellophane
  o  Acetate
Papergrade Sulfite (Blow
Papergrade Sulfite (Drum
Groundwood-Thermo-Mechanical
Groundwood - Coarse,  Molded,
  News (C, M, N) Papers
Groundwood - Fine Papers
Groundwood-Chemi-Mechanical
This subcategory
u.sing  a  "full
                 includes mills where  a  bleached  pulp  is  produced
                 cook"  process  employing  a  highly  alkaline sodium

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hydroxide and sodium sulfide cooking liquor.  Papergrade  market  pulp
is produced at mills representative of this subcategory.

BCT (Board, Coarse, and Tissue) Bleached Kraft

This  subcategory includes the integrated production of bleached kraft
pulp and board, coarse, and tissue papers.   Bleached  kraft  pulp  is
produced  on-site  using  a  "full  cook"  process  employing a highly
alkaline sodium hydroxide and  sodium  sulfide  cooking  liquor.   The
principal  products  include paperboard (B), coarse papers (C), tissue
papers (T), and market pulp.

Fine Bleached Kraft

This subcategory includes the integrated production of bleached  kraft
pulp and fine papers.  Bleached kraft pulp is produced on-site using a
"full  cook"  process employing a highly alkaline sodium hydroxide and
sodium sulfide  cooking  liquor.    The  principal  products  are  fine
papers,  which  include  business,  writing,  and printing papers, and
market pulp.

Soda

This subcategory includes the integrated production of  bleached  soda
pulp  and  fine  papers.   The  bleached soda pulp is produced on-site
using a  "full  cook"  process  employing  a  highly  alkaline  sodium
hydroxide  cooking  liquor.   The  principal products are fine papers,
which include printing, writing,  and business papers, and market pulp.

Unbleached Kraft

This  subcategory  includes  mills  where  pulp  is  produced  without
bleaching  using  a  "full  cook"  process employing a highly alkaline
sodium hydroxide and sodium sulfide cooking liquor.  The pulp is  used
on-site  to produce linerboard, the smooth facing in corrugated boxes,
and bag papers.

Semi-Chemical

This subcategory includes mills where pulp is produced using a process
that involves the cooking of wood chips under pressure using a variety
of cooking liquors including neutral sulfite and combinations of  soda
ash  and  caustic  soda.   The cooked chips are usually refined before
being converted on-site into board or similar products.  The principal
products  include  corrugating  medium,  insulating  board,  partition
board, chip board, tube stock, and specialty boards.

Unbleached Kraft and Semi-Chemical

This  subcategory  includes  mills  where  pulp  is  produced  without
bleaching  using  two  pulping   processes:   unbleached   kraft   and
semi-chemical.   Spent  semi-chemical  cooking liquor is burned within
the kraft chemical recovery system.  The pulps  are  used  on-site  to

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produce  both linerboard and corrugating medium used in the production
of corrugated boxes and other products.

Dissolving Sulfite Pulp

This subcategory includes mills where a highly bleached  and  purified
pulp  is  produced  using  a  "full  cook"  process  employing  strong
solutions of sulfites of calcium, magnesium, ammonia, or sodium.   The
pulps  produced by this process are viscose, nitration, cellophane, or
acetate grades and are used principally for the manufacture  of  rayon
and other products that require the virtual absence of lignin,


Paperqrade Sulf ite (Blow Pit Wash)

This  subcategory  includes  integrated production of sulfite pulp and
paper.  The sulfite pulp is  produced  on-site  using  a  "full  cook"
process  employing  an  acidic  cooking liquor of sulfites of calcium,
magnesium, ammonia, or sodium.  Following the cooking operations,  the
spent  cooking  liquor  is  washed  from  the  pulp in blow pits.  The
principal products include tissue papers, newsprint, fine papers,  and
market pulp.


Paperqrade Sulfite (Drum Wash)

This  subcategory  includes  the integrated production of sulfite pulp
and paper.  The sulfite pulp is produced  on-site  employing  a  "full
cook"  process  using an acidic cooking liquor of sulfites of calcium,
magnesium, ammonia, or sodium.  Following the cooking operations,  the
spent  cooking  liquor  is  washed from the pulp on vacuum or pressure
drums.  Also included are mills using belt extraction systems for pulp
washing.  The principal products include tissue papers,  fine  papers,
newsprint, and market pulp.

Groundwood - Thermo-Mechanical

This   subcategory   includes   the  production  of  thermo-mechanical
groundwood pulp and paper.  The thermo-mechanical groundwood  pulp  is
produced  on-site  using  a  "brief  cook"  process  employing  steam,
followed by mechanical defibration in refiners, resulting in yields of
approximately 95% or  greater.   The  pulp  may  be  brightened  using
hydrosulfite  or peroxide bleaching chemicals.  The principal products
include market pulp, fine papers, newsprint, and tissue papers.
Groundwood-CMN (Coarse, Molded, News )  Papers

This subcategory includes the integrated production
and  paper.   The  groundwood  pulp  is  produced,
brightening,  utilizing only mechanical defibration
grinders or refiners.  The principal products  made
                                                    of groundwood pulp
                                                    with  or   without
                                                    using either stone
                                                     by  this  process
                                i oo

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include  coarse  papers  (C), molded fiber products (M), and newsprint
(N).

Groundwood-Fine Papers

This subcategory includes the integrated production of groundwood pulp
and  paper.   The  groundwood  pulp  is  produced,  with  or   without
brightening,  utilizing  only  mechanical  defibration by either stone
grinders or refiners.  The principal products made by this process are
fine papers which include business, writing, and printing papers.

Groundwood - Chemi-Mechanical

This   subcategory   includes    the    integrated    production    of
chemi-mechanical  groundwood  pulp  and  paper.   The chemi-mechanical
groundwood pulp  is  produced  using  a  chemical  cooking  liquor  to
partially  cook  the  wood;  the  softened  wood  fibers  are  further
processed by  mechanical  defibration  using  refiners,  resulting  in
yields of 90 percent or greater. -The pulp is produced with or without
brightening.   The  principal products include fine papers, newsprint,
and molded fiber products.

Deink

This subcategory includes the integrated production  of  deinked  pulp
and  paper  from  wastepapers  using  a chemical or solvent process to
remove contaminants such as ink and  coating  pigments.   The  deinked
pulp  is  usually  brightened or bleached.  Principal products include
printing, writing and business papers, tissue papers, and newsprint.


Tissue From Wastepaper

This  subcategory  includes  the  production  of  tissue  papers  from
wastepapers  without  deinking.   The  principal products made include
facial and toilet papers, paper diapers, and paper towels.


Paperboard from Wastepaper

This  subcategory  includes  mills  where  paperboard   products   are
manufactured  from  a  wide  variety of wastepapers such as corrugated
boxes, box board, and newspapers; no bleaching is done on-site.  Mills
where paperboard products are manufactured principally or  exclusively
from  virgin  fiber  are  not  included within this subcategory, which
includes only those mills where wastepaper comprises  the  predominant
portion  of the raw material fibers.  The principal products include a
wide variety of items used in commercial  packaging,  such  as  bottle
cartons.

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Wastepaper-Molded Products

This  subcategory  includes  mills  where molded products are produced
from wastepapers without deinking.  Products include molded items such
as fruit and vegetable packs and  similar  throw-away  containers  and
display items.

Builders'  Paper and Roofing Felt

This  subcategory  includes  mills  where  heavy,  papers  used  in the
construction industry are produced from cellulosic fibers derived from
wastepaper, wood flour and sawdust,  wood  chips,  and  rags.   Neither
bleaching nor chemical pulping processes are employed on-site.

Noninteqrated-Fine Papers

This  subcategory  includes  nonintegrated mills where fine papers are
produced from purchased pulp.  The principal products of this  process
are printing, writing, business, and technical papers.


Nonintegrated-Tissue Papers

This  subcategory includes nonintegrated mills where tissue papers are
produced from wood pulp or deinked pulp prepared at another site.  The
principal  products made at  these  mills  include  facial  and  toilet
papers, paper diapers, and paper towels.

Nonintegrated-Lightweight Papers

This  subcategory  includes  nonintegrated  mills where lightweight or
thin papers are produced from wood pulp or secondary  fibers  prepared
at  another site and from nonwood fibers and additives.  The principal
products made at these mills include uncoated  thin  papers,  such  as
carbonizing  papers  and  cigarette papers,  and some special grades of
tissue such as capacitor, pattern, and interleaf.

Nonintegrated-Filter and Nonwoven Papers

This subcategory includes nonintegrated mills where filter papers  and
nonwoven  items  are  produced  from a furnish of wood pulp, secondary
fibers, and nonwood fibers prepared at another  site.   The  principal
products  made  at  these  mills  include  filter and blotting papers,
nonwoven packaging and specialties,  and technical papers.

Noninteqrated-Paperboard

This subcategory includes  nonintegrated  mills  where  paperboard  is
produced  from wood pulp or secondary fibers prepared at another site.
The principal products made at these mills include linerboard, folding
boxboard,  milk cartons, food board,  chip board, pressboard, and  other
specialty  boards.   Mills  where electrical grades of board or matrix
board are produced are not included in this subcategory.
                                 I 0

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                              SECTION V

                 WATER USE AND WASTE CHARACTERIZATION


WATER USE AND SOURCES OF WASTEWATER

Water is used in the following major unit operations employed  in  the
manufacture of pulp, paper, and paperboard: wood preparation, pulping,
bleaching,  and papermaking.  It can be used as a medium of transport,
a cleaning agent, and a solvent or mixer.

Details of water use and sources of wastewater  generation  from  each
major  production area in the pulp, paper, and paperboard industry are
discussed below.  Figure V-l presents the  water  use  and  wastewater
sources from a typical integrated mill.

Wood Preparation

Wood  preparation  operations can be employed at mills where wood pulp
is manufactured on-site.  Water is utilized in  the  wood  preparation
process  in  three  basic  areas:  a)  log  transport, b) log and chip
washing/thawing, and c) barking operations.  Along  with  these  basic
uses,  water  can  also  be used to protect against fires (in chip and
wood storage) and for storage of logs (in rivers or ponds).

Water can be used to transport whole  logs  to  the  wood  preparation
area.   This  may  take  the form of river driving or flume transport.
The only wastewater generated  by  log  transport  operations  is  the
overflow from the transport flume.

In  the  log  and  chip  washing/thawing  operations, water is used in
sprays or showers to remove salt, dirt, and debris; these showers  can
be  activated  by  each log to minimize water use.  Hot ponds are also
used  in  cases  where  frozen  logs  need  thawing  prior   to   wood
preparation.

Bark  from whole logs is removed prior to chipping, and removal can be
accomplished by dry or wet methods.  In some cases, water is used as a
presoak to soften bonds between the wood and bark  prior  to  barking.
Wet  barking operations can utilize high volumes of water which can be
used  in  three  different  ways:  a)  in  high-pressure  water   jets
(hydraulic)  to  strip  away  bark  by  impingement,  b)  in  vats  to
facilitate cleaning, lubrication, and barking, and c)  in  showers  to
thaw frozen logs in the early stages of barking.

Wastewater  discharged  from  all  three  types  of wet barking can be
combined with flume overflow or log or chip wash water; coarse screens
can be used to remove large pieces of bark and wood slivers.   Barking
wastewater can then be passed through fine screens with the screenings
combined with the coarse screening materials.   The combined screenings
can  be  dewatered  in  a  press  and  burned  in a bark boiler.  This
eliminates a source of solid waste while generating power.


                               103

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                                   FIGURE  V-1
                         GENERAL FLOW SHEET
              PULPING  AND PAPERMAKING  PROCESS
RAW MATERIALS
FUNDAMENTAL  PROCESS
                                               9*8tOU3
 WASTES
   LI QUI?
                                                                                 SOLID
PULP LOOS
ACID SULFtTE LIQUOR
ALKALINE SULFATE LIQUOR   _
  (KM APT)            'IB*
NEUTRAL SULFITE LIQUOR ¥
WHITE WATER
FRESH WATER
•KHITC **TE* OK
REUSE MATCH
BLCACHM* ANO OTHER
NECESSARY CHEMICALS
 FRESH WATER OR WHITE
 WATER REUSE
 FILLERS
 DYI
 size
 ALUM
 STARCH
 FUEJH *ATt» OH
 WHITI WATtH RtUSf
 COATINi PI9MCNTS
 AHOAONCSIVES
                                                      LOSt
                                                             LO* FLUME

                                                             •AMKEM IEANIN*
                                                             COOLIN* WATER

                                                             WASH WATCH
                                                            BARK REFUSE
                                                            WOOD PARTICLES
                                                            ANO IL1VENS
                                                            SAWDUST
                          •B^SLOW-SYSTEM
                            EMISSION
                                           *.SMtLT  TANK
                                             EMISSION
                                             LIME KILN EMISSION
                                             RECOVERY FURNACE
                                             EMISSION
                                             EVAPORATION
                                             EMISSION
                          •••TO EVAPORATION
                            ANO RECOVERY
SULFITE  SPENT
LIQUOR
BLOW PIT COLLECTED
SPILLS
                                            CONOENSATE
                                            OREOS WASHING
                                            •UD WASHINS
                                            ACID PLANT
                                            WASTE
                                                                             RESIDUES
                                                             WASH WATERS
                                                                             FIBER
                                                             WEAK LIOUOR       KNOTS
                                                                             FISEft
                                                             WASTE WATERS     PISER
                                                             •LEACH  WASTES    FIBER
                                             MBAT AND WATER
                                             VAPOR
                                             CLEAN- UP
                                             WATER
                                                             WHITE WATER
                                             CLEAN - UP
                                             WASH WATER
                DIRT
                STOCK SPILLS
                                                             FIBER
                                                             FILLERS
                                                             BROKE
                 BROKE
                 COAT1NSS
                       FINISHED PAPER
                         PRODUCTS
                                           104

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Pulping and Recovery

In pulping operations, water is used as make-up, for dilution, and for
washing and cleaning.  It can also be used  to  facilitate  a  process
mechanism, such as fiberization.   With each different pulping process,
the  demand  and  sources  of  wastewater  discharge  vary.   They are
discussed separately below.

Mechanical  Pulping  (Groundwood).    The  two   basic   processes   in
groundwood  or mechanical pulping are the stone groundwood process and
the refiner  groundwood  process.   These  processes  have  also  been
modified  through  the  addition  of  steam and/or chemicals to reduce
power requirements for grinding.   These newer processes are  known  as
the thermo-mechanical process and the chemi-mechanical process.

In  stone  groundwood  pulping, billets are fed to grinders by hand or
automatically from a conveyor.   Water is used as both a coolant and  a
carrier  to  sluice  pulp from the body of the grinder.  More water is
added to dilute the pulp slurry,  which is passed  through  coarse  and
fine  screens and centricleaners to remove dirt and slivers.  The pulp
slurry is thickened on a decker and then discharged to a  stock  chest
for  mill  use,  to  be  bleached,   or  to  be  thickened  further for
transport.  Wastewater from the thickening processes can  be  recycled
back  to  a  white water chest to supplement process water flow to the
grinders.  Overflow from the white water chest and wastewater from the
centricleaners are usually discharged to the treatment system.

In refiner groundwood pulping,  wood chips are generally  washed  prior
to  two  stages  of  refining.    Disc type refiners are used which may
contain one fixed and one rotary disc (or two  rotary  discs)  between
which  wood  chips  pass  with  a stream of water.  After the pulp has
passed through the refiners, it is diluted with water,  screened,  and
cleaned in centricleaners.  After cleaning, the pulp is handled in the
same  manner  as stone groundwood.   Wastewater sources can include the
white  water  tank  overflow,  thickening  wastewater,   centricleaner
wastewater, and wood chip wash water.

In  chemi-mechanical  pulping,  logs or wood chips are soaked or cooked
in liquor containing different chemicals  such  as  sodium  carbonate,
sodium hydroxide, and sodium sulfite.  This can be done at atmospheric
pressure  or under forced pressure for shorter periods of time.  After
this treatment, the logs or chips are handled in a manner  similar  to
that  used in stone or refiner groundwood pulping.  Wastewater sources
are the same as those for stone or refiner groundwood pulping.

In thermo-mechanical pulping, wood chips are  pre-softened  with  heat
and  refined  under pressure.  After this treatment, chips are handled
in the same manner as stone or  refiner  groundwood  pulping  and  the
potential wastewater sources are identical.
                                105

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Chemical  Pulping.   Chemical  pulping  involves the use of controlled
conditions  and  cooking  chemicals  to  yield  a  variety  of  pulps.
Chemical  pulps  are converted into paper products that generally have
higher quality standards than products  made  from  mechanical  pulps.
The  three  basic  types  of  chemical  pulping  are alkaline (soda or
kraft), sulfite, and semi-chemical pulping.

Kraft pulping was originally developed from the soda process.  In  the
soda  process,  wood  chips  are cooked in a digester in a solution of
caustic soda.  When cooking is completed, the contents of the digester
are blown into a tank.   The pulp  is  washed  on  countercurrent  drum
washers  and  then diluted with water, screened, and deckered to stock
chest  consistency.   Wastewater  sources  include  spills  from   the
digester  area,  condensed  digester  vapors,  and wastewater from the
washing, screening, and deckering operations.

In the kraft pulping process, wood chips  are  cooked  in  a  solution
consisting  primarily  of a mixture of caustic soda and sodium sulfide
which is known as white liquor.  Both batch and  continuous  digesters
can  be  employed.   In  the manufacture of dissolving pulps, the wood
chips are sometimes steamed in the digester for a short  period  prior
to   the   addition   of   the  cooking  liquor.   This  is  known  as
pre-hydrolysis.  In this step, the chips are loaded into the  digester
which  is  then  partially or totally filled with water, and the whole
mass is heated.  As the temperature rises, wood  acids  are  released,
the  pH  drops,  and  the acidic conditions degrade and solubilize the
hemi-cellulose molecules in the wood.   After  about  two  hours,  the
acidic  sugar-rich  liquors  are  drained  and  the  kraft  liquor  is
introduced into the digester to start the cooking stage.

When cooking is completed, the chips are blown from the digester to  a
tank  where they separate into fibers.  Steam from the tank goes to an
accumulator for heating process water.  Drainings can be  returned  to
the  white  liquor  storage  tank to be used in succeeding cooks.  The
pulp is transferred, along with the spent  cooking  liquor  or   "black
liquor",  to  a  "brown stock" chest or tank, and from there to  vacuum
drum washers or continuous diffusers where spent liquor  is  separated
by  countercurrent  washing.   In order to optimize chemical recovery,
three or sometimes four stages of washing are used  to  allow  a  high
degree  of  liquor separation with a minimum amount of dilution.  This
reduces the heat requirements of evaporation in the chemical  recovery
operation.    Where   continuous   digesters  equipped  with  internal
diffusion washing are used, only one or two external washing steps may
be employed.

After washing, the pulp  is  diluted,  screened,  and  deckered  to  a
consistency suitable for bleaching.  Wastewater sources from the kraft
pulping  process  can  include spills from the digester area, digester
relief  and  blow  condensates,  wastewater  from  the  "brown   stock"
washers, and wastewater from the screen room and deckers.

Wastewater is also generated in the kraft  liquor recovery system.  The
liquor  recovered  from  the  washing  operation is called "weak black
                                106

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liquor." This weak black liquor is  concentrated  in  multiple  effect
evaporators  into  a  viscous  mass  called "strong black liquor." The
strong black liquor is further concentrated in  the  recovery  furnace
direct  contact  evaporator  or  in  a concentrator.  The strong black
liquor is burned and the  heat  is  recovered.   During  burning,  the
organic  sodium  compounds  are converted to soda ash and sulfates are
converted to sulfides.  The molten smelt  of  salts  is  dissolved  in
water  to  form  "green  liquor."  The  green  liquor is clarified and
causticized with lime to convert the soda ash to caustic soda.   After
causticizing, the combined sodium sulfide-caustic soda solution, known
as  "white  liquor,"  is  settled,  sometimes  filtered  through press
filters, and reused.  The lime mud (calcium carbonate) obtained  after
settling  the  white  liquor  is washed and dewatered on rotary vacuum
filters or centrifuges and burned in rotary or fluidized bed kilns  to
form  quick  lime.   This is hydrated with green liquor in slakers for
reintroduction into the  recovery  cycle.   The  wastewater  from  the
vacuum   filters  or  centrifuges  is  discharged  to  the  wastewater
treatment system.

The sulfite process is used to make two distinctly different types  of
pulp:  papergrade and dissolving grade.  The basic process is the same
for both,  although  there  are  significant  differences  in  cooking
temperatures,   strength   of   chemical  application,  and  bleaching
practices.  In the preparation of dissolving sulfite pulps, cooking is
continued until most of the lignin  and  part  of  the  cellulose  and
hemi-cellulose are dissolved.  In making papergrade pulps, essentially
only  the  lignin  is  dissolved;  final  net yield is several percent
higher than for dissolving pulps.

In the sulfite process, wood chips are cooked with  solutions  of  the
sulfites  of  calcium,  magnesium,  ammonia,  or  sodium.  The cooking
liquor is manufactured  at  the  mill  from  purchased  and  recovered
chemicals.   Sulfurous acid is prepared by absorbing sulfur dioxide in
water.  Sulfur dioxide is made at the mill by  burning  sulfur  or  is
purchased  in  liquid  form; both forms can be supplemented by sulphur
dioxide from the recovery system.  Process water is used to  cool  the
sulfur  dioxide  gas  produced.  Sulfurous acid is used in preparation
with calcium carbonate and calcium  oxide  or  aqua  ammonia  for  the
manufacture  of  cooking  liquor.   Neither  calcium  nor  ammonia  is
recovered.  Magnesium oxide and caustic soda are purchased as  make-up
base  chemicals  for  the  magnesium  and sodium base recovery systems
which recover about 90 percent of the base chemicals.

When ammonia, calcium, magnesium, or sodium base cooking is completed,
the pulp is  blown  into  a  blow  tank.   It  is  then  delivered  to
multi-stage   vacuum  (drum)  washers,  where  countercurrent  washing
separates the spent liquor from the pulp.  Blow pits rather than  blow
tanks  can  be  employed; in blow pits, pulp is washed by diffusion of
wash  water  through  the  pulp  mass.   Blow  pit  washing   can   be
supplemented   with   vacuum   (drum)   washing  to  increase  washing
efficiency.
                                107

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After washing,  the pulp is diluted,  screened,   centrifugally  cleaned,
and deckered to the desired stock chest consistency for bleaching.  In
the   manufacture  of  dissolving  sulfite  pulps,   an  extra  set  of
"side-hill" screens are used for thickening and to  separate  resinous
materials.   The  wastewater  sources from the sulfite process include
digester area spills, digester relief and blow condensates, and  water
losses  from  the  vacuum (drum) or blow pit washing and screening and
deckering operations.

Wastewater is also discharged from the recovery system.  The weak "red
liquor" washed from the pulp is evaporated to a  consistency  suitable
for  burning.   Some evaporator condensate is discharged to the sewer,
while the rest may be used for washing and stock dilution.

Historically, semi-chemical pulping has involved the cooking  of  wood
chips  in  a  solution  containing  sodium  sulfite.   As discussed in
Section III, the semi-chemical process  can  be  modified  to  include
non-sulfur  containing  solutions  of soda ash and caustic soda.  Wood
chips are cooked at high temperatures for a period of about 10  to  20
minutes   or   at  lower  temperatures  for  longer  periods  of  time
(generally, one to three hours).  After cooking,  the  softened  chips
are  sometimes  compressed  in one or more stages of screw pressing to
maximize the recovery of spent liquor.   The  cooked  chips  are  then
transferred  to  a disc mill for fiberization.  The chips then undergo
vacuum or pressure washing and screening and/or centrifugal  cleaning.
The  pulp  is  conveyed  to an agitated chest where it is diluted with
white water from the paper mill.  Wastewater sources include  digester
area  spills,  digester  relief and blow condensates, and water losses
from the screw press, washing, and screening operations.

Chemical recovery in the sodium-based  NSSC  process  is  considerably
more  difficult than in the kraft process.  The spent liquor is low in
solids with a relatively  high  proportion  of  inorganic  to  organic
constituents and does not burn easily.  At many mills, spent liquor is
evaporated   and   burned  without  recovery  of  the  chemical  base.
Evaporation is commonly accomplished in  multiple-effect  evaporators.
The  concentrated  liquor  is  burned  for  disposal  or recovery in a
fluidized  bed  reactor   or   a   specially-designed   furnace.    In
sodium-based  mills, the fluidized bed combustion units produce sodium
sulfate which is suitable for use in kraft mill  liquor  systems.   No
successful   system   has  been  developed  for  ammonia  recovery  at
ammonia-based NSSC mills; the spent liquor is  simply  incinerated  to
recover energy.

The  no-sulfur  semi-chemical processes allow for recovery of soda ash
after burning of spent liquor in  a  modified  kraft-type  furnace  or
fluidized  bed.   The  recovered chemical is recycled to the digester/
caustic make-up provides a balanced  pH  for  liquor  reuse.   In  any
semi-chemical recovery system, evaporator condensate may be sewered.
                                 108

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Secondary  Fiber Pulping.  Secondary fiber sources, such as wastepaper
of various classifications, can be used  to  make  several  grades  of
pulp.   Some  wastepaper  can  be  used with little or no preparation,
particularly if wastepaper is purchased directly from other  mills  or
converting  operations where a similiar product grade is manufactured.
However, some wastepaper is deinked  before  it  is  used  as  a  pulp
source.

In  the deinking process, wastepaper is cooked in an alkaline solution
to which dispersants, detergents, and solvents are added.  The process
is essentially a laundering operation in which the sizes, any  coating
binder, and the pigment vehicle in the ink are dissolved or dispersed;
the  ink pigment is released along with filler and coating agents such
as clay, calcium carbonate, and titanium dioxide.  Adhesives  such  as
starch  and  glue are also dissolved and dispersed.  The wastepaper is
then cooked in a pulper with cooking time determined by examination of
a sample from the pulper.  During this step, a trash boot and a ragger
may be used to remove such items as trash, rags, rope, and wire.   The
stock  is then usually screened, after which it is ready for cleaning.
This is accomplished by passing the stock through  centricleaners  and
fine screens.  Generally countercurrent washing is employed on washers
of  various types.   Flotation is employed at some mills for separating
the fiber from the undesirable materials; at others, various kinds  of
deckering  or thickening equipment are used.  Fiber leaves the washers
and is delivered to  a  stock  chest.   Wastewater  sources  in  deink
pulping  include  wastewater  from  the centrifugal cleaners, washers,
deckers, and thickeners and spills from the deinking process area.

In non-deinking operations, some wastepaper can be slushed or  blended
with  virgin  pulps  to provide suitable furnish for the papermachine.
The combined stock is generally cleaned  and  screened  in  the  stock
preparation  system  in  the papermachine area.  In other non-deinking
operations,  considerable  quantities  of  books,  envelope  cuttings,
flyleaf  shavings,  and similar unprinted scrap are repulped and washed
free of fillers, adhesives, and sizing material; any  ink  removal  is
incidental.   Wastewater  sources are similar to those in the deinking
process.

Bleaching

After pulping, the unbleached pulp can  be  brown  or  deeply  colored
because   of  the  presence  of  lignins  and  resins  or  because  of
inefficient washing of the spent cooking liquor  from  the  pulp.   In
order  to  remove  or  brighten  these  color  bodies and to produce a
lightly-colored or white product, it is necessary to bleach the pulp.

Bleaching of_ Mechanical (Groundwood) Pulp.  The most common  bleaching
agents  used  for  stone  and refiner groundwood are hydrosulfites and
peroxides; both can be  used  sequentially.   In  peroxide  bleaching,
hydrogen  or  sodium  peroxide is applied to the pulp in a mixing tank
along with caustic soda or other chemicals to raise the pH,  Steam  is
fed  to the mixing tank to heat the mixture to the proper temperature;
pulp is then fed to a peroxide bleaching tower.   After  bleaching  in
                               109

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the  tower,  the pulp is usually neutralized to prevent reversal of the
reaction.    Sometimes,   if  further   brightening   is   required,   a
hydrosulfite bleaching step follows peroxide bleaching.

Sodium  or  zinc  hydrosulfite  can  be  used  in  the  same manner as
peroxide.   Both acidic conditions and the presence of air in  solution
decrease  bleaching effectiveness.   Wastewater discharge is limited to
that resulting from the washing of  bleached mechanical pulp subsequent
to the peroxide or hydrosulfite bleaching step.

Bleaching of_ Chemical Pulp.  The chemicals most commonly employed  for
bleaching   of   chemical   pulps  are  chlorine,  calcium  or  sodium
hypochlorite,  and chlorine dioxide.   Alkaline  solutions  of  caustic
soda  are  used  for  extracting  chlorinated  reaction  products from
treated pulp.   Hydrogen peroxide,  sodium  peroxide,   or  peroxyacetic
acid can be used in the finishing stages of bleaching.  Sulfur dioxide
or  sodium sulfite can be used as neutralizing and anti-chlor reagents
and in some instances to  stabilize  pulp  brightness.   However,  the
chlorine   compounds   and  alkalis  are  the  most  commonly  applied
chemicals.

Chlorine and caustic soda are generally purchased in liquid form,  but
can  be  manufactured  at the mill  by electrolysis of sodium chloride.
Hypochlorites are generally manufactured on-site by treatment of  milk
of   lime   or  caustic  soda  with  chlorine.   Chlorine  dioxide  is
manufactured on-site because  of  its  instability.   Other  bleaching
chemicals  are  purchased in their  common form;  solutions are prepared
according to process needs.  These  are employed  in  relatively  small
quantities as compared to the major bleaching agents.

Bleaching is ordinarily performed in a number of stages.  This is done
to  preserve the strength of the pulp by avoiding excessively rigorous
chemical treatment and  to  control  consistency  and  temperature  in
accordance  with  the demands of the particular treatment application.
Each stage consists of a reaction tower in which the pulp is  retained
in  contact with a particular chemical agent for a specified period of
time.  It is then washed on vacuum washers or diffusers and discharged
to the next stage.

The chemical concentrations  employed  depend  upon  the  consistency,
temperature,  number  of  stages,  specific chemicals used, species of
wood from which the pulp was produced, degree to which it was  cooked,
and  quality  of  product desired.   Three stages are generally used in
semibleached kraft operations and for bleaching of sulfite  papergrade
pulps.   Since  kraft  pulps are dark in color, particularly when made
from softwoods,  high-brightness  kraft  pulps  usually  require  more
stages.   Normally  five  are used, although at some mills six or more
stages are used.  Three stages may be  used  for  low-brightness  soda
pulp and four stages for high brightness.

Wastewater  is  generated   in the preparation of both hypochlorite and
chlorine dioxide and is discharged from  the  bleach  plant  from  the
                                110

-------
first  stage  chlorine  tower  wash system and the first stage caustic
extraction wash tower.

Displacement bleaching is a new process which is  being  installed  at
some  U.S.   mills.   Bleaching chemicals are displaced through a high
consistency pulp mat rather than being conventionally mixed  into  the
pulp.   Very  rapid bleaching can be accomplished due to high reaction
rates.   Filtrate withdrawal at one stage  is  fortified  with  make-up
chemical  and  reused.   The  bleaching stages can be located within a
single displacement tower.  The  major  reactor  is  chlorine  dioxide
followed  by extraction with caustic soda.  Wastewater sources include
the wastewater from preparation of chlorine  dioxide  and  wash  water
introduced on the alkaline and acidic (C102_) stages.

Bleaching  of_  Deinked  Secondary  Fibers.   Deinked fibers consisting
primarily of bleached chemical pulp are bleached  in  one  stage  with
chlorine  or  calcium  or  sodium hypochlorite.  When pulps containing
considerable lignin are bleached after deinking, the  three-stage  CED
process   (chlorination,  caustic  extraction,  and  chlorine dioxide),
commonly applied to kraft and sulfite pulps,  is  employed.   In  this
process, chlorine is applied to a dilute slurry of the pulp at ambient
temperature.   The  pulp  is  then  thickened and treated with caustic
soda, washed, and treated with hypochlorite.  A variety  of  equipment
and  variations  of  this  process  are in use.  When pulps containing
mostly groundwood are bleached, bleaching  methods  similar  to  those
used  to  bleach  groundwood pulp are used; common bleaching chemicals
include peroxides and hydrosulfites.

Wastewater sources for bleaching of deinked pulps are similar to those
associated with the bleaching of other papergrade pulps.  In the  case
of  pulps  containing  large  amounts  of lignin, wastewater discharge
includes chlorination and caustic extraction wash water.  In the  case
of  secondary  fibers  containing  high  groundwood  or chemical pulp,
wastewater discharge includes wash water resulting from a single  wash
stage.

Papermaking

In  stock preparation, pulp, either purchased (nonintegrated mills) or
produced on-site (integrated or secondary fiber mills), is resuspended
in water.  The stock is mechanically treated in beaters or  continuous
refiners  to  "brush"  or  fray  the  individual  fibers to obtain the
necessary matting and bonding which produces the desired  strength  in
the  paper.   This  process  also  cuts  the  fibers  to  some degree.
Chemical  additives  may  be  added  either  before  or  after   stock
preparation.

Either  a  Fourdrinier or cylinder forming machine may be used to make
paper or paperboard.  The primary operational difference  between  the
two types is the flat sheet-forming surface of the Fourdrinier and the
cylindrical-shaped  mold of the cylinder machine.  The type of machine
used has little bearing on the raw waste load.  Because of its  higher
speed  and  greater versatility, the Fourdrinier is in more common use
                                111

-------
than the cylinder machine.   The cylinder machine is primarily used  to
produce thick, heavyweight board products.

Water is used for dilution and to transport pulp to the paper machine.
This  water,  called "white water" drains or is pressed from the paper
or paperboard on the "wet end" of the paper machine.  White  water  is
of relatively high quality and is normally reused on the paper machine
or  in other areas of the mill.  Wastewater sources in the papermaking
operation include water losses from the  stock  preparation  area  and
white  water  from the Fourdrinier or cylinder machine which overflows
the white water recycle tank.

WASTE CHARACTERIZATION STRATEGY

The  purpose  of  this  section  is  to  present  information  on  the
wastewater characteristics of mills in the subcategories identified in
Section  IV.   As  outlined previously, three categories of pollutants
were  under  investigation:   a)  conventional  pollutants,  b)  toxic
pollutants,  and c) nonconventional pollutants.  [When presenting data
in the tables that appear in this section,  wastewater data  in  metric
units are conversions of parallel data in English units.  However, BPT
raw waste characteristics are precisely those values published in this
and   previous   documents  supporting  development  of  BPT  effluent
limitations guidelines.]

Conventional Pollutants

The Clean Water Act defined four conventional pollutants or  pollutant
parameters:   BOD^,  TSS,  pH,  and  fecal  coliform.   An  additional
pollutant, oil and grease,   was  defined  by  EPA  as  a  conventional
pollutant  under  procedures  established  in section 304 of the Clean
Water Act.  As a result of past  efforts,  effluent  limitations  have
been  established  for  the control of BOD{>, TSS, and pH in discharges
from the pulp, paper, and paperboard industry.

Information on the raw waste characteristics of mills in each  of  the
subcategories of the pulp,  paper, and paperboard industry was gathered
as  part  of  the  data request program described in Section II and is
presented in this section.

Dissolving Kraft.  Table V-l  presents available  data  on  wastewater
discharge   and   raw   waste  loadings  of  BOD!>  and  TSS  at  mills
representative of the dissolving kraft subcategory.  At  these  mills,
blends  of  dissolving pulps and papergrade market pulps are produced.
Raw material usage ranges from 100 percent  hardwood  to   100  percent
softwood.   At one mill, a blend of 88 percent softwood and 12 percent
hardwood is used.  The proportion of dissolving pulp ranges from 49 to
72 percent with an overall average of 60 percent.  Bleaching sequences
and practices  vary  on  different  lines  at  the  individual  mills.
However,  at all three, jump-stage countercurrent washing  is generally
practiced.  Calculated bleached yield averages about  40  percent  for
the softwood and 46 percent for the hardwood pulps.
                                112

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                                                            TABLE V-l

                                                   SUMMARY RAW WASTE LOAD DATA
                                                  DISSOLVING KRAFT SUBCATEGORY
                                                                             Raw Waste  Load
Production Profile
Mill No. Raw M.iterial
03200 l(l>) 100'ii 1IW
03 2002(1)) 100/: SW
0:320030)) 88% SW
Avt> rugc
F 1 ow
Dissolving Pulp (%) kl/kkg
72
49
59
60
BPT K.iw W;isU? Load
136
218
239
198
230
.9
.2
. 1
.2
.0
(kg
(32
(52
(57
(47
(55
al/t)
.8)
.3)
.3)
.5)
-1)
BODS
kg/kkg (Ib/t)
109.5
39.4
59.8
69.6
66.5
(219.0)
(78.7)
(119.6)
(139. 1)
(133.0)
TSS
kg/kk£ (Ib/t)
120.4
132.0
81.6
111.3
113.0
(240.7)
(264.0)
(163.2)
(222.6)
(226.0)
SBPT(a)
F
BF
B

(.OF - Mill willi 
-------
In  order  to  evaluate  the effect of the fraction of dissolving pulp
produced on raw waste load,  raw waste flow and BODS^ have been  plotted
in  Figures  V-2  and  V-3  against  the percentage of dissolving pulp
produced relative to total product manufactured on-site.  Although  no
relationship appears to exist for flow, BODS^ increases with increasing
percent  of  dissolving  pulp  produced.   In  addition, the effect of
pulping softwood versus hardwood on raw waste load has been  evaluated
by plotting raw waste flow and BOD5^ against percent softwood in Figure
V-4.   It  has been suggested that raw waste loads would increase with
an increase in the percentage of  softwood  processed.   However,  the
highest  BODS^ raw waste load occurs at the mill where only hardwood is
pulped.  It must be noted that the highest  percentage  of  dissolving
pulp relative to total final product is produced at this mill.

Further  review  of  operating  variables at the three mills indicates
that washing efficiency has a greater effect on BODj^  raw  waste  load
than  either  the amount of dissolving pulp produced or the percentage
of softwood pulped.  The salt cake loss, as washable Na2^0, was  higher
at  the mill where the BOD5^ raw waste load was highest  (e.g., the mill
where only hardwood is pulped).  Based on the limited data  available,
it  was  impossible  to  determine a specific relationship between raw
waste flow and BODij relative to either the  percentage  of  dissolving
pulp produced or the percentage of softwood pulped.

Market   Bleached   Kraft.   Table  V-2  presents  available  data  on
wastewater  discharge  and  raw  waste   BOD5_   and   TSS   at   mills
representative of the market bleached kraft subcategory.  Raw material
use  ranges  from  100  percent  hardwood  to  100  percent  softwood.
Production ratios can and do shift and the capability generally exists
to pulp all softwood if desired.  To aid in  identifying  trends  with
respect  to  raw  waste load, the mills are listed sequentially  in the
order of increasing softwood pulping.  Figures  V-5  and  V-6  present
plots of the raw waste flow and EOD5_ versus the percentage of softwood
pulped.   A  trend is apparent with respect to raw waste load flow and
BODS^, with both generally increasing slightly  as  the  production  of
softwood  increases.  However, regression analysis of the relationship
of flow and BOD5^ versus  percent  softwood  was  inconclusive  and  no
definite relationship could be established.

BCT  (Paperboard,  Coarse,  and  Tissue)  Bleached  Kraft.   Table V-3
presents available data on wastewater discharge and BODS^ and  TSS  raw
waste  loads at the eight mills representative of the BCT (paperboard,
coarse, and tissue) bleached kraft  subcategory.   At   mills  in  this
subcategory,  bleached  kraft  pulps  are  produced  for  the  on-site
production of paperboard, market pulp, and tissue and coarse grades of
paper.  At most of the mills, both hardwood  and  softwood  pulps  are
produced;  however,  at  two,  only  softwood  pulp   is used  in  the
production of tissue and board products.  Figures V-7 and V-8  present
plots  of  raw  waste  flow and BOD5^ with respect to the percentage of
softwood pulp in the furnish.  Based on a statistical analysis of  the
data,  no  significant correlation could be established between  either
raw waste flow or BOD5_ and the percentage of softwood pulped.
                                114

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                                 FIGURE V-2
           RAW WASTE FLOW VERSUS PERCENT DISSOLVING PULP
                       DISSOLVING KRAFT SUBCATEGORY
240(57.eu
200(480)-
160(384)
IZO(28.I)-
 801 192)
 40 ( 961-
  0 (01
     1O
             20
                     30
                             40       50       60

                               PERCENT DISSOLVING PULP
                                                      70
                                                              8O

-------
                                      FIGURE V-3
                RAW WASTE BOOS VERSUS PERCENT DISSOLVING PULP
                          DISSOLVING KRAFT SUBCATEGORY
  120(2401
  IOOI200)-
  80(160)
I  60(1201-
u>l
* 4OI (80S-
  20 (40)-
   0 IOJ
       10
               20
                        30
                                 40       50       60

                                    PERCENT DISSOLVING PULP
                                                                     80
                                                                              90

-------
  I20(240)n
— 90(180)
  60 ( 1201-1
o'
O
09
* 30( 60)
                        FIGURE V-4

             RAW WASTE DATA (FLOW AND BODS)

             VERSUS PERCENT SOFTWOOD USED

              DISSOLVING KRAFT SUBCATEGORY
    0(0) 1
                20
                        40
                                 60
                                          80
                                                   100
  300 (72H
  200 (48)
  100 (241-
I
    0 (0)
                20       40       60


                      PERCENT SOFTWOOD USED
                                          80
                                                   100
                              117

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                                                                                TABLE V-2
                                                                       SUMMARY RAW WASTE LOAD DATA
                                                                    MARKET BLFACHED KRAFT SUBCATEGORY
00
Production Profile

Mill No.
030005
030009
030012
030042
030028

030031
030030
030018
030006
900074(b)
Average
BPT Raw
Average
Average
Average
Average
Average
Average
Average?

HWK(%)
100
100
89
64
27

26
21
11
0
0

Waste Load
of Mills with
of Mil Is >70%
of Mills >70%
of Hills >70%
of Mills >70%
of Mills >70%
of Mills >70%
Pulp
SWK(%)
_
-
11
36
73

74
79
89
100
100


SBPT flow
SWK
SWK and 
192.8
152.7
120.6
120.6
120.')
144.8
(kgal/t)
(17.6)
(32.4)
(36.7)
(18.8)
(37.0)

(79.8)
(40.6)
(44.3)
(43.1)
(32.3)
(38.3)
(41.6)
(30.8)
(46.2)
(36.6)
(28.9)
(28.9)
(28.9)
(34.7)
BODS
kg/kkg (lb/t)
17
-
35
37
35

44
44
39
41
23
35
38
32
37
34
26
26
26
29
.5
-
.7
.4
.5

.0
. 1
.2
.3
. 1
.3
.0
.2
.9
.2
.6
.6
.6
.3
(35.0)
( — )
(71.4)
(74.8)
(71.0)

(88.0)
(88.1)
(78.3)
(82.5)
(46.2)
(70.6)
(75.9)
(64.4)
(75.7)
(68.4)
(53.2)
(53.2)
(53.2)
(58.6)
TSS
kg/kkg
20.4
—
98.0
14.4
24.0

132.0
24.7
48.4
22.4
18.7
44.8
45.0
33.4
45.0
22.5
59.2
59.2
59.2
21.4

(lb/t)
(40.8)
(--)
(195.9)
(28.7)
(47.9)

(264.0)
(49.4)
(96.8)
(44.7)
(37.4)
(89.5)
(90.0)
(66.7)
(90.0)
(44.9)
(118.4)
(118.4)
(118.4)
(42.7)
               (a)Produc-t ion data  held  confidential.
               (b)Supplemcnl.il  data  (not  from 308).
               (c)F - Mill with  
-------
                         FIGURE V-5
      RAW WASTE FLOW VERSUS PERCENT SOFTWOOD USED
            MARKET BLEACHED KRAFT SUBCATEGORY
   400 {961-,
   150(84)-
   500(721-
~  250!«0)J
3  200(48!-
i
1
$  150S3SI4
<       '
c
   100(24).
   501 \
     0 (0)
                20       40        6O

                       PERCENT SOFTWOOD USED
                                           80
                                                    100
                                119

-------
                      FIGURE V-6
    RAW WASTE BOD5 VERSUS PERCENT SOFTWOOD USED
         MARKET BLEACHED KRAFT SUBCATEGORY
  8O(160).
  70(140)-
  60(1201-
  40! 801-
8
o
u
5
  30 ( 60S-
  20 ( 40) •
  10 ( 20H
   0 (0)4-
                       40        60

                     PERCENT SOFTWOOD USED
                              120

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                                                                    TABIK V-3
                                                          SUMMARY  RAW WASTE LOAD DATA
                                                        BCT BLEACHED  KkAFT SUBCATEGOKY
Production j'rofi^le
Puli) (t/d) "product (t/d)

Mill No .
030004
030010
030022
030024
030026(j)
030047
030032
030039(1>)
Average

IIW SW
436 535
335
352 943
512 368
1073
306 204
584 576
291 238


Board Tissue
548 343
231
907
714
884 59
583
895
487

Market &
Coarse
69
84
394(c)
106
210
--
348
107


Fl ow"

Total kl/kkg
960
315
1301
820
1153
583
1243
594

lipr Kaw Waste Load
Average of
Average oi
(a) Include
(l.)Waste 1
Mi 1 Is with
Mil Is with
s lumber mi
oad data re
SBPT flow
•?BI'T BODS
1 1 effluent in raw




waste figures.
rv influent: not inc
187.0
187.0
150.6
137.7
121.0
131.4
138. 1
_92.2
150.2
148.0
132.3
169.0
luded in


Kaw Waste Load
BOOS


(kgal/t) kg/kkg (Ib/t)
(44
(44
C16
(33
(29
(31
(33
(22
(36
(35
(31
(40
av
-------
                         FIGURE V-7
     RAW WASTE FLOW VERSUS PERCENT SOFTWOOD USED
             BCT BLEACHED KRAFT SUBCATEGORY
  220 (52.8H
  200(48.0)-
i 160(38.4)
ui 140(33.6)-
  120(28.8)
  100 (24.0!
   80 { 19.2)
                 20
                         40       60
                             SOFTWOCO USED
                                           80
                                                    !00
                               122

-------
                       FIGURE V-8


    RAW WASTE BODS VERSUS PERCENT SOFTWOOD USED


           BCT BLEACHED KRAFT SUBCATEGORY
  80(160),
  70 (140)-
  60 (120)-
2 50(IOOH
       i
       I
S'
o
o
  40 ( 301-
* 30 ( 601-
  20 ( 40)-
  10 ( 201-
    0 !0)
               20
                        40        60



                      PERCENT SOFTWOOD '.SED
                                          80
                                                  :oo
                           123

-------
Alkaline (Fine Bleached Kraft  and  Soda  Subcateqories).    Table  V-4
presents  available  data on wastewater discharge and BOD5_ and TSS raw
waste loads at 20 mills that are representative of  the  alkaline-fine
mill grouping.  Various grades of paper, both coated and uncoated, are
produced  from  combinations of hardwood and softwood kraft pulps and,
in some instances, on-site production of  groundwood  pulp.   Attempts
were  made  to determine if the amount of groundwood production or the
extent of high use of filler  and  coating  applications  affects  raw
waste characteristics.

Figures  V-9  and  V-10  present  plots of the raw waste flow and BOD5_
versus the percentage of softwood pulped relative to the total product
manufactured.   Those  mills  where  paper  is  produced  using   some
groundwood pulp produced on-site and those where large amounts of clay
are  used  as  a  filler  are also shown.  No relationship between raw
waste flow or BOD5_ and percentage of softwood pulp used  is  apparent.
Additionally,  no  relationship is apparent between groundwood or high
clay filler use and flow or BOD5_.

Figures V-ll and V-12 present plots of raw waste flow and BODS^  versus
the  percentage  of  pulp  manufactured  on-site relative to the total
product manufactured.  No significant statistical correlation could be
ascertained.  Two of the mills where some groundwood pulp is  produced
exhibit  high  BOD5_  raw  waste  load;  however, the other mills where
groundwood pulp is produced exhibit BOD5_ raw waste loads in  the  same
general range as for other alkaline-fine mills.

Unbleached  Kraft.   Table  V-5  presents available data on wastewater
discharge  and  raw  waste  loadings  of  BOD5_  and   TSS   at   mills
representative  of the unbleached kraft subcategory.  Figures V-13 and
V-14 are presented to illustrate the effect of  product  type  on  raw
waste loads.  Based on this analysis, the subcategory has been divided
into two separate groups: unbleached kraft (linerboard) and unbleached
kraft  (bag and other products).  As shown on Table V-5 and Figures V-
13 and V-14, significantly different wastewater discharge  exists  for
the two groups.  The bag and other product mills generally have higher
flow, BOD5^, and TSS raw waste loads.

Semi - Chemic a1.   Table  V-6 presents available raw wastewater data for
each of  the  19  mills  where  a  semi-chemical  pulping  process  is
employed.   Corrugating  medium is the primary product of these mills;
various  chemical  processes,  chemical  bases,  and  liquor  recovery
systems  are  utilized  at  mills  in  this  subcategory.   Previously,
sodium-based and ammonia-based neutral  sulfite  semi-chemical  (NSSC)
processes were identified.  Ammonia-based cooking liquors are now used
at  only one mill.  The raw waste loads for the ammonia-based mill are
not substantially different from the other semi-chemical  mills:  flow
and  TSS  raw waste loads are well below the subcategory average; BOD5_
is above the subcategory  average  but  is  not  the  highest  in  the
subcategory.

Many   process   innovations  are  being  applied  at  mills  in  this
subcategory including the use of no-sulfur pulping  and  green  liquor
                                124

-------
                                                                       TAIil.K V-4

                                                             SUMMARY RAW WASTE  l.OAL) DATA
                                                                    A1.KAUIIK-F1NK*
Product ion
Mi II N.I.
0 30001
0 JOOI3
0 UlOIMr )
030020 d )
0 1002 /(. )
030034 (< )
o too )/
030046
0 10049 I r )
0 tOO-') 1
0 (0052
0 100S7
031)0.')')
0 10060
1 10001
130002
Puli' ll/d)
nw sw"
101
146
124
--
292
341
449
408
449
1 13
237
181
(d)
(d)
5.35
(d)
35
129
123
174
199
109
476
232
224
218
31!
--
(.1)
(d)
--
(d)
Prof i lo
Purch (t/il)
Pulp Hroke(a) Ct
-------
                            FIGURE V-9
   RAW WASTE FLOW VERSUS PERCENT SOFTWOOD USED
                          ALKALINE-FINE '"
180(43.2)
160 (38.4).
140 (33.6).
120 (28.8).
100 (24.01-
80 ( 19.2)-
60 ( 14.4).
40
    (9.61-i
                    E
 LEGEND
Q GROUNDWOOD USED
5! HIGH CLAY FILLERS USED
A "5RCUNDWOOD AND HIGH CLAY FILLERS USED
20  (4.81-i-
        C          20         40         60

                          PERCENT SOFTWOOD USED

       '"'NCLUOF.S FINE BLEACHED KRAFT ino ICCi SUBCATEGORiF. S
                                                  30
                                                             100
                                    126

-------
                           FIGURE V-10
     RAW WASTE BOD5 VERSUS PERCENT SOFTWOOD USED
                           ALKALINE-FINE"1
ml
1
I

-------
                           FIGURE V-11
 RAW WASTE FLOW VERSUS PERCENT ON SITE PULP PRODUCTION
                          ALKALINE-FINE"1
208.3(50)-
166.7(40)-
125 0(301-
ro
oo
? 833(20)
*
1
a:
4 1 7 (10)
O (O )
1


.
• •




0 20 30 4O 50
                                                ID
                                            ts
                                         60

                           PERCENT ON SITE PULP
                                                        ®
                                                              ®
                                                   LEGEND

                                                   ® GROUNDWOOO USED
                                                   [•] HIGH CLAY FILLERS USED
                                                   A UTILIZE SOME GROUNDWOOO AND HIGH CLAY FILLERS
                                                   70
                                                             80
                                                                      90
                                                                                100
FINE BLEACHED KRAFT AND SODA SUBCATEGORIES

-------
70-
                            FIGURE V-12
RAW WASTE BODS VERSUS PERCENT ON SITE PULP PRODUCTION
                           ALKALINE-FINE"1              ®    ®«-«t
60(I20>-
50000K-
40 (sot-
3O (BO-
ZO (40)-
IO (20)-
     (I)
                                                     LEGEND
                                                     (§) GROuNOWOOO USED
                                                     ® HIGH CLAY fILLEHS
                                                     A GROUNDWOOD AND HIGH CLAY FILLERS USED
               20
                                    40
                                              50         60
                                            PERCENT ON SITE PULP
                                                                   70
                                                                             eo
                                                                                       90
       INCLUDES FINE BLEACHED KRAFT AND SODA SUBCATEGORIES

-------
                                                       TABLE V-5

                                              SUHNART RAW WASTE LOAD DATA
                                             UNBLEACHED KRAFT SUBCATEGORT
Production Profile
Furaish(t/d)
Hill Ho. Kraft WP
Lloarboard
010001 450 —
010002 923 "
010018 1,170 30
010019 1,127 39
010020 971 53
010023 323 39
010032 (a) (a)
010033 (a) (a)
010038 7SO 68
010040 1,193 83
010042 963
010043 1,539 10
010046 1,176
010047 1,299 —
010037 540
010063 (a) (a)
010064 664 31
Average
BPT Raw Waata Load
Average of Hills with
Average of Hills with
Bat and Other Producta
010003 243 12
010003 1,286
010006 1,685
010008 1,895
010028 400 10
010044 1,020
010053 748 Z
010060(c) 470
010062 231
010034 940
010035 (a) (a)
010048 (a) (a)
Average
BPT Raw Waate Load
Asauwd BPT Raw Waate
Average of Mills with
Average of Hills with
Parch
Broke Lincrbosrd

20
«
—
27
61
-•
(a)
(a)
5
--
--
-.
27
--
85
(a)
™


SBPT flow
SBPT BODS

m —
8
51
-.
..
82
12
25
10
48
(a)
(a)


Load
SBPT flow
S Aasuajed

450
934
1,081
1,144
965
563
(a)
(a)
789
1,220
963
1,549
1,102
1,194
620
(a)
666





— _
898
1,115
1,540
25
362
—
--
..
404
(a)
(a)




BPT BOD5
Product (t/d)
Bat

__
—
— -
--
«
-.
(a)
(a)
— •
-.
--
-.
«
—
--
(a)
--





283
332
478
434
279
712
726
443
234
453
(a)
(a)





Other Total

430
934
1,081
7 1,151
44 1,009
4 567
(a) (a)
(a) (a)
789
1,220
963
1,549
21 1,123
1,194
620
(a) (a)
666





283
1,230
1,594
1,974
95 399
1,074
726
443
234
68 925
(a)
(a)





Flow
kl/kkg

46.3
44.2
44.2
35.1
81.0
44.7
47.2
--
105.2
65.1
23.0
44.2
49.2
26.3
38.4
31.7
34.2
47.6
52.5
39.2
47.2

42.1
66.4
52.6
73.9
110.2
57.2
58.4
85.1
151.5
94.7
227.8
223.3
103.5
52.5
52.5
47.6
80.1
(ktal/t)

(11.1)
(10.6)
(10.6)
( 8.4)
(19.4)
(10.7)
(11.3)
(")
(23.2)
(15.6)
( 5.3)
(10.6)
(11.8)
( 6.3)
( 9.2)
( 7.6)
( 8.2)
(11.4)
(12.6)
(9.4)
(11.3)

(10.1)
(15.9)
(12.6)
(17.7)
(26.4)
(13.7)
(14.0)
(20.4)
(36.3)
(22.7)
(54.6)
(53.5)
(24.8)
(12.6)
(12.6)
(11.4)
(19.2)
Raw
Waate Load
BODS
kg/kkg

8.3
14.1
18.1
9.6
20.5
13.9
18.3
--
16.5
14.7
11.1
21.7
14.4
6.7
«
46.3
14.8
16.6
16.9
16.4
12.4

__
20.3
12.5
18.8
—
12.5
30.5
—
20.6
36.8
34.2
32.9
24.3
16.9
24.3
12.5
16.9
(Ib/t)

(16.5)
(28.2)
(36.1)
(19.1)
(41.0)
(27.8)
(36.5)
(")
(32.9)
(29.4)
(22.2)
(43.4)
(28.7)
(13.4)
(--)
(92.6)
(29.6)
(33.2)
(33.8)
(32.8)
(24.8)

(--)
(40.6)
(25.0)
(37.6)
( — )
(24.9)
(60.9)
( — )
(*1.1)
(73.5)
(68.4)
(65.7)
(48.6)
(33.8)
(48.6)
(25.0)
(33.8)
TSS
kx/kkg

26.9
24.7
14.1
4.8
27.6
9.8
17.4
--
13.9
11.4
5.7
13.9
20.1
10.8
—
9.9
24.3
15.8
21.9
15.2
15.4

__
20.5
—
45.7
13.3
17.8
23.2
—
8.6
24.3
56.3
73.2
31.4
21.9
21.9
—
23.2
(Ib/t)

(53.7)
(49.4)
(28.2)
(9.6)
(55.1)
(19.6)
(34.8)
( — )
(31.7)
(22.7)
(11.3)
(27.7)
(40.2)
(21.5)
( — )
(19.8)
(48.6)
(31.6)
(43.8)
(30.4)
(30.8)

(--)
(40.9)
( — )
(91.3)
(26.6)
(35.6)
(46.4)
( — )
(17.2)
(48.6)
(112.6)
(146.3)
(62.8)
(43.8)
(43.8)
(--)
(46. 3^
SBPT(b)

BF
BF
F
BF

BF
F

B
B
BF
F
BF
BF
F
r
BF





F
B
BF
B

B


B








(a)Production  data  held  confidential.
(b)F -  Mill  with SBPT  flow;  B  - Mill with S Asm
(c)Hill now  closed.
ed BPT BODS.
                                                          130

-------
                            FIGURE V-13
             RAW WASTE FLOW VERSUS PRODUCTION
               UNBLEACHED KRAFT SUBCATEGORY
  240 (57.6)
  2IO (50.4)
  ISO (43.2)
7 150(36.0)
M 120 (26.81-

3
   90 (21.61-
   60 ( 14.4).
  30 ( 7.2).
     0 (01-
LE8END
O UNBLEACHED KRAFT UNCRBOARD
Q UNBLEACHED KRAFT BAG AND OTHER PRODUCTS
                                3   O
                         °0
                  400
                            800       1200       1600
                               PRODUCTION - tom/doy
                                                         2000       2400
                               131

-------
                         F1GURE V-14
           RAW WASTE BODS VERSUS PRODUCTION
            UNBLEACHED KRAFT SUBCATEGORY
  40(80
  35 (TO)-
  JO (60!-
  20(401-
* ', 5(30t-
  10 !20)'
   5HOI-
                      046.$|
LEGEKD

0 UNBLEACHED KRAFT LINERBOARO
GJ UNBLfACHED KBAFT BAG AND OTHER PRODUCTS
                          O     O
               4QO
                        800      1200       1600
                           PRODUCTION- iom/00»
                                                    2000      2«CO
                                132

-------
                                           TABLE V-6

                                   SUMMARY RAW WASTE LOAD DATA
                                    SEMI-CHEMICAL SUBCATEGORY
Production Profile
Furnish (t/d)
Mill No. Semi-Chen WP Broke
Product
(t/d)

kl/kkg
Flow
(kgal/t)
Raw
Waste
Load
BODS
kg/kkg
(lb/
t)




TSS
kg/kkg
(lb/t)
SBPT(a)
I. Mills With Liquor Recovery and Less Than 1/3 WP
020002 248 90
020003(b) 582 61
020008 (b) 231 125
020009 (b) (c) (c)
020010 (c) (c)
020013 472 173
020014(d) 394 117
020017 (c) (c)
060004(b) 385 98
Average
BPT Raw Waste Load
Average of Mills with SBPT
Average of Mills with SBPT
20
--
—
(c)
(c)
--
—
(c)
9


flow
BOD5
II. Mills With Liquor Recovery and
020001 204 116
020004(e) 160 106
020006 190 99
020007 183 123
02001 l(f) 235 157
020012 (c) (c)
Average
BPT Raw Waste Load
Average of Mills with SBPT
Average of Mills with SBPT
III. Mills Without Liquor
020005 137 46
020015 118 50
Average
— —
—
--
--
--
(c)


flow
BOD5
Recovery
_ —
—

331
618
318
(c)
(c)
599
511
(c)
492




24.2
40.1
23.0
28.8
60.5
39.6
26.7
30.5
48.8
35.9
42.9
30.5
33.4
More Than 1/3
302
266
291
346
377
(.c)





183
169

19.2
25.0
16.3
10.4
34.2
26.4
18.8
42.9
18.8
17.9

47.2
20.4
33.8
(5.8)
(9.6)
(5.5)
(6.9)
(14.5)
(9.5)
(6.4)
(7.3)
(11.7)
(8.6)
(10.3)
(7.3)
(8.0)
WP
(4.6)
(6.0)
(3.9)
(2.5)
(8.2)
(6. a;
(4.5)
(10.3)
(4.5)
(4.3)

(11.3)
(4.9)
(8.1)
12.9
25.3
9.6
14.4
17.9
39.0
31.2
20.7
27.8
22.1
25.2
21.9
15.1

23.6
1.3
24.2
—
22.6
--
23.9
25.2
23.9
23.9

56.1
33.2
44.7
(25
(50
(19
(28
(35
(77
(62
(41
(55
(44
(50
(43
(30

(47
(2
(48
(
(45
	 ±
(47
(50
(47
(47

(112
(66
(89
.7)
-5)
.2)
.8)
.7)
-9)
.3)
.3)
.6)
.1)
.4)
.7)
.1)

.1)
-6)
.4)
— )
.2)

.8)
.4)
.8)
.8)

.1)
.4)
.3)
30.2
13.2
6.9
17.8
49.3
37.8
18.8
44.5
54.6
30.3
12.3
24.2
29.7

8.1
0.2
--
--
6.0
--
8.1
12.3
8.1
8.1

52.4
27.9
40.1
(60
(26
(13
(35
(98
(75
(37
(89
(109
(60
(24
(48
(59

(16
(0
(
(
(11
	 i,.
(16
(24
(16
(16

(104
(55
(80
.4)
-3)
.7)
.6)
.5)
.5)
.6)
.0)
.2)
.6)
.6)
.3)
.4)

.1)
.3)
— )
— )
.9)

.1)
.6)
.1)
-1)

.7)
.7)
.2)
BF
F
BF
BF
B
F
F
BF






BF

BF
F

T






F

IV. Non Representative Mills
020018(g) 217 450
020016(g) 200 221
Average
Average of All Mills
BPT Raw Waste Load
Average of Mills with SBPT
(Group I and II)
Average of Mills with SBPT
(Group I and II)
__
--



flow

BOD5

673
525







30.5
55.5
43.0
30.9
42.9
26.3

28.8

(7.3)
(13.3)
(10.3)
(7.4)
(10.3)
(6.3)

(6.9)

62.8
50.5
56.7
25.8
25.2
Z2.3

17.6

(125
(100
(113
(51
(50
(44

(35

.6)
.9)
.3)
.6)
.4)
.6)

.2)

61.5
42.2
51.9
30.1
12.3
22.2

26.1

(123
(84
(103
(60
(24
(44

(52

-0)
.3)
.7)
.2)
.6)
.3)

.2)

F








(a) F - Mill with SBPT flow;  B - Mill with SBPT BOD5.
(b) No-sulfur pulping.
(c) Production data held confidential.
(d) Ammonia-base.
(e) A reverse osmosis system  is used to treat internal process streams and allow for extensive
    recycle of these treated  streams.  Not included in averages.
(f) Mill 020011 has combined  effluent with other mills.   Not included in averages.
(g) Mill 020018 makes recycled paperboard and corrugating.   Mill  020016 makes tissue and
    fine papers.   These mills are not considered representative and are not included in averages.
                                                    133

-------
pulping   to  displace  the  conventional  NSSC  cook.   Insignificant
differences exist in  raw  waste  loadings  at  the  no-sulphur  mills
compared  to  mills  where  the conventional NSSC process is employed.
Similar results would be anticipated if data were available  on  green
liquor pulping.

Incomplete  on-site chemical recovery existed at two mills at the time
of data acquisition.  As expected,  these mills  exhibit  significantly
higher  BOD5^ raw waste loads than the other mills in this subcategory.
Two additional mills are not included in averages of data presented in
Table V-6 because they are not representative of general practices  of
the   semi-chemical  subcategory.   At  one,  a  variety  of  recycled
paperboard grades as well as corrugating media are  produced;  at  the
other,  tissue  and  fine  papers  are  made  as well as semi-chemical
corrugating media.

Data for another mill (020004) are not included in averages  presented
in  Table  V-6.  At this mill, a reverse osmosis system is utilized to
treat some process  wastewater  and  provide  for  extensive  internal
recycle,  thus  substantially reducing raw waste loads.  This reliance
on extensive  production  process  controls  is  not  typical  of  the
approach taken at most other mills in this subcategory.

Utilization of wastepaper in the furnish at mills in the semi-chemical
subcategory  ranges  from  about  10  percent  to  67 percent of total
production.  Therefore,  the effect of wastepaper usage  on  raw  waste
load  flow  and BOD5. has been evaluated to determine if the percentage
of wastepaper used affects raw waste load.

Figures V-15 and V-16 present plots of raw waste flow and BODI5  versus
the percentage of wastepaper used in the furnish relative to the total
product.  Flow tends to decrease with an increase in the percentage of
wastepaper used.  However, a significant statistical correlation could
not  be  determined.   No significant relationship exists between BOD5^
raw waste load and the percentage of wastepaper used.

Unbleached Kraft and Semi-Chemical.  The ten mills for which data  are
available   that  are  representative  of  the  unbleached  kraft  and
semi-chemical subcategory  are  some  of  the  largest  mills  in  the
industry  with  an  average  production  of approximately 1,360 metric
tons/day (1,500 tons/ day).  Table V-7 presents  available  raw  waste
load   data  for  this  subcategory.   At  all  of  these  facilities,
unbleached kraft pulps are produced along with high  yield  unbleached
semi-chemical  pulps.   These  products  are  commonly utilized in the
manufacture of linerboard and corrugating media.  At some mills, other
types of kraft paper including board, bag, and converting  papers  are
also  made  on-site.   Table  V-7  also  shows  the percentage of each
product made at each mill along  with  the  percentage  of  unbleached
kraft and semi-chemical pulp produced.  Kraft pulp production averages
about  five  times  as  much  as  semi-chemical pulp production.  This
reflects a typical balanced cross-recovery system  with  fresh  liquor
makeup  to the semi-chemical process to counterbalance chemical losses
from that operation and the kraft pulping operation.  The distribution
                               134

-------
                                          FIGURE V-15
                    RAW WASTE FLOW VERSUS PERCENT WASTEPAPER USED
                                SEMI-CHEMICAL SbBCATEGORY
  60(14.4)-,
  50(12.0)
  40 ( 961-
3 30( 7.2)
o
* 20{ 1.81
a:
   IOC Z.4|-
    O (0)
                —i—
                 10
                          20
                                             40
—I—
 50
          LEGEND
          O NO SULFUR PULPING
          A AMMONIA BASK
          0 NON-REPRESENTATIVE MILLS
          X NO LIQUOR RECOVERY
          * SODIUM BASE
—I—
 TO
                                                                                  80
—r
 90
                                         PERCENT WASTEPAPER USED

-------
OJ
CTl
                                                        FIGURE V-16

                                   RAW WASTE BODS VERSUS PERCENT WASTEPAPER USED

                                               SEMI-CHEMICAL SUBCATEGORY
                  60lJO)-i
                  50(25)-
30 (IS I •
                 Q
                 O
                 1C
                 <  20(101-
                     51
                                   *


                                   O
                    0 (0)..-

                       0
                                                            LtGl.Np


                                                           O NO GUI fUH I'M I'lNG

                                                           ^ AMMONIA UASt


                                                           EJ NOH RtPRt SENTATIVE Mil IS

                                                           X NO LlOUOH Rt(,OV£HV

                                                           » SO01UM HASt
                                IO
                                         20
                                        40        50

                                     PERCENT WAS1EPAPER USED
                                                                             80

-------
                                                                   TAliLK V-7

                                                          SUMMARY RAW WASTF. LOAD DATA
                                                UNBI.F.AaiF.D KRAFT AND SEMI-CHEMICAL SUBCATKGORY
F,irnish(%)(a)
Mill No. Semi-Chem
015001 (c)(20% bag  pructiiction
Avrrajji- for mills using varying  amounts  of  grivn
   liquor for pulpitij^

KI'T Haw Waste Loart

Avrr.iRr. of Mills with 
-------
of production as well as the range in the ratio  of  semi-chemical  to
kraft pulp are reasonably constant in this subcategory, except for one
mill  where about ten times as much kraft is produced as semi-chemical
pulp.

Six mills are known to be utilizing varying amounts  of  green  liquor
for pulping in the semi-chemical operation.  This is done to enable an
increase in semi-chemical pulp production relative to unbleached kraft
production  and/or  to  facilitate  the  recovery  of chemical cooking
liquor.  No trends are  apparent  with  respect  to  raw  waste  loads
relative  to  either  alterations  of  the semi-chemical process or to
variations in the products manufactured.

Because  the  production  of  bag  papers  in  the  unbleached   kraft
subcategory   has   a   significant  effect  on  raw  waste  load,  an
investigation was made of those  unbleached  kraft  and  semi-chemical
mills  where  higher percentages of bag papers are produced.  As shown
in Table V-7, the average raw waste loadings for the three mills where
greater than 20 percent of the final product is bag  paper  are  lower
than  the  overall  subcategory  averages.  In fact, the mill (015005)
where the highest percentage of bag paper is produced has  the  lowest
raw waste load flow and BOD5_ in the subcategory.

Dissolving  Sulfite  Pulp.   Table  V-8  presents  available  data  on
wastewater discharge and raw waste loadings of BOD5_ and TSS  at  mills
representative of the dissolving sulfite pulp subcategory.  At the six
mills   where   dissolving  grade  sulfite  pulps  are  produced,  the
capability exists for also producing papergrade pulps.   Predominantly
softwoods  are utilized with only small amounts of hardwood associated
with the production  of  dissolving  grades  of  sulfite  pulp.   Both
magnesium and ammonia-based pulping operations are employed.  In order
to  facilitate  the  production  of  the  high  purity pulps required,
extensive washing and evaporation systems are used  and  often  entail
two   evaporator  lines  operating  in  series.   Extensive  bleaching
operations, frequently with six or more stages, are used to purify the
cellulose.  Consequently, large amounts, of dissolved solids  (including
BOD5_) are discharged from the bleaching operations  as  well  as  with
spent  sulfite  pulping  liquors.   Extensive use is made of jumpstage
countercurrent washing systems to minimize wastewater  discharge.   At
two mills, a system is used which enables the evaporation of the total
effluent from the caustic extraction stage, which has the highest BOD5_
loading discharged from the bleaching operation.

BPT  effluent  limitations  are  based  on the grade of pulp produced,
including nitration, viscose, cellophane, and  acetate  grades.   Data
gathered  since the BPT program have been evaluated to verify the need
for effluent limitations by grade.   However,  insufficient  data  are
available  to  allow for presentation of raw waste  load data by grade.
Complete data are lacking for half the mills.

Papergrade Sulfite  (Papergrade Sulfite  (Blow Pit Wash) and   Papergrade
Sulfite   (Drum Wash) Subcategories).  Table V-9 presents available raw
waste  load data for 17 mills characteristic  of  these  subcategories.
                                138

-------
                                     TABLE V-8

                            SUMMARY RAW WASTE LOAD DATA
                        DISSOLVING SULFITE PULP SUBCATEGORY
                                              Raw Waste Load
Mill No.
Production
    (t/d)
                                Flow
                           BODS
                     TSS
    kl/kkg (kgal/t)
kg/kkg (Ib/t)    kg/kkg (Ib/t)
046001(a)      421

046002(b)      560

046003         620

046004(f)      (e)

046005         (e)

046006(a)      (e)

Average

BPT Raw Waste Loads are

   Nitration
   Viscose
   Cellophane
   Acetate
                  228.7  (54.8)       154.1  (308.2)

                  259.1  (62.1)(c)      --     (--)

                  265.0  (63.5)(c)(d) 114.5  (228.9)

                  190.7  (45-7)        97.2  (194.4)

                  358.5  (85.9)       276.0  (552.0)

                  182.8  (43.8)        99.2  (198.3)

                                      161.0  (321.9)
    258.7  (62.0)

dependent on processes used

    275.0  (66.0)       137
    275.0  (66.0)       156
    275.0  (66.0)       181
    303.4  (72.7)(g)    266
                  29.3  (58.6)

                         (")

                  11.2  (22.3)

                  39.6  (79.2)



                  53.6 (107.1)

                  31.3  (62.7)
.0  (321

 and are  as follows:

.0  (274.0)    92.5 (185.0)
.0  (312.0)    92.5 (185.0)
.5  (363.0)    92.5 (185.0)
.0  (531.9)(g)  92.5 (185.0)
(a) Data obtained from responses by mill representatives to a 1981
    questionnaire.
(b) Total raw waste BOD5 and TSS data are not available.
(c) Flow data obtained from telephone conversations with mill repre-
    sentatives in 1981.
(d) Flow data based on 1981 process flow and corresponding 647 ton/day
    production rate.
(e) Production data held confidential.
(f) Raw waste loads include wastewater from a dissolving sulfite pulp mill and
    a paper mill.  Therefore,data were not included in the averages.
(g) The flow and BOD5 are representative of the raw waste load associated with
    the production of acetate grade dissolving pulp at the time the remanded BPT
    BOD5_ limitation was promulgated in 1977.
                                        139

-------
                                                                1AIII.K  V-9
                                                       SUMMAKY KAW WASTE f.OAl) DATA
                                                     PAPKKCKAOE  SUmTK SUBCATECOKY
                Production Profn
                     1  Oil-site
                                                                                                   Haw Waste Load
Mill No.
040001 (h)
040002(d)

(l/'JL
(c)
547

040006(c)(f)ril


04000 7(e Kg) 135
040008 (.1)

040009 (d)

040010(10

040011 (.1)

0400 1 2 (d)

0400 l)(d)
0400 1 4 (d)

0400 1 5
04001o(d)
040017(d)

0400 1 8 (d)
04001 9(i )
040020(d)
964

566

244

284

270

289
146

155
437
412

359
(<•')
671
Sulfite Pulp Process
Produced Tyjue Wash Base_
82
101

8'J

100
78

41

32

39

72

56
59

100
61
42

34
52
57
Corrug
Market
Tissue
Ti ssue
Market
Market
Ti ssu
Marke
Writi g
Marki-
Glabs i\e
Package
Wri t ing
Thin
Writi ng
Print ing
Printing
Wri t ing
Laninat ing
Market
Wr i t ing
Prim ing
Market
Tissue
Tissue
Tissue
BP
BP

BP

«P
BP/DK

I)K

BP

BP

DK

l)l(
RP

BP/DR
I)N
RP

I)K
I1R
I)R
NH3.BS
Ca.Na
A, BS
NII3.A

NH3.A
NII3.A

Mj(0,BS

Ca.A

Cd,A

NH3,A

MgO , BS
Ca,A

Cd , BS
N1I3.BS
Ca,A

Ca,A
NH3.A
NH3.A
Condenser
U
Ba,S

S

None
Ba,S

S

S

Ba,S

Vr

S
S

S
S
S

S
Vr
Ba
Flow
kl/kkg (k£al/l) kg/kk£
135.
313.

346.

196.
186.

83.

290.

97.

225.

136.
170.

—
159.
116.

131.
58.
100.
2
0

8

1
5

9

0

6

3

5
.3


4
4

4
8
6
(32.
(75.

(83.

(47.
(44.

(20.

(69.

(23.

(54.

(32.
(40.

( —
(38.
(27.

(31.
(14.
(24.
/,)
0)

I)

0)
7)

1)

7)

4)

0)

7)
8)

)
2)
9)

5)
1)
1)
68
84

-

421
-

48

27

45

58

41
109

-
109
97

74
-
36
.7
. 1

-

.3
-

.9

.9

.0

.5

.4
.4

-
.3
. 1

.2
-
.3
BOD5
"(Tb/l) k_B/_k
(137
(168

(--

(842
(--

(97

(55

(89

(117

(82
(218

(-
(218
(194

(148
(-
(72
.3)
.2)

)

.5)
)

.7)

.8)

.9)

.0)

.8)
.7)

-)
.5)
.2)

.4)
-)
.5)
--
21 .

--

--
--

28.

51 .

25.

90.

31.
19.

--
140.
37.

65.
--
11 .
TKS
k& 11I1/.L

0






6

3

9

0

9
3


2
1

1

9
(--)
(42.0)

(--)

(--)
(--)

(57. 1)

(102.5)

(51.8)

(180.0)

(63.7)
(38.6)

(--)
(280,3)
(74. 1)

( 1 30 . 2 )
(--)
(23 .7 _)
Ave r.igi;
                         58(j)
BIT Kaw Wast.- Load
blow Pit Wash
  Ilisul I i te-Surfaie
  Bi .su 1 I i tc-Baronict r i c
  Acid Kill I i te-SurlaC.'
  Acid Stil I i li'-BariiineLric
Drum Wrjsh
  Bisult itc-Surlace
  R i su 11 11 f-BaroiiirLr i c
  Arid Sul liu-Surl.ice
  Ai-iil Kill I i le-Bdioim'li ic
                                                                                  156.5    (37.5)    68.9   (137.7)  50.0  (99.9)
186.0   (44.5)   116.0   (232.0)  90.0 (180.0)
221.0   (53.0)   116.0   (232.0)  90.0 (180.0)
186.0   (44.5)   121.0   (242.0)  90.0 (180.0)
221.0   (53.0)   121.0   (242.0)  90.0 (180.0)

186.0   (44.5)   134.0   (168.0)  90.0 (180.0)
221.0   (53.0)   134.0   (168.0)  90.0 (180.0)
186 0   (44.5)   103.5   (207.0)  90.0 (180.0)
221.0   (53.0)   103.5   (207.0)  90.0 (ISO 0)
                                                                                                                                        BF

                                                                                                                                         B

                                                                                                                                        BF

                                                                                                                                         B

                                                                                                                                        BF
                                                                                                                                        BF
                                                                                                                                         F
                                                                                                                                        KF

-------
                                                          T/V-LK V-9  (Continued)
Average of NI13 base  acid mills
Average of Nil:) li.ise  bisulfite mills
Average- of MgO base  bisulfite mills
Average of Ca base only and  acirl  only  mills
Average ol Ca base acid mills with drum wash
Average of Mills with  SRPT ROD5
170
159
1 10
128
131
lr>2
.7
.4
2
.9
.4
.7
(40
(38
(26.
(30.
(31.
(36
y)
.2)
4)
.9)
'.)
.6)
47
109
45
81
74
66
./.
.3
.2
.4
.2
. 1
(94
(218.
(90.
(162
(148
(1.12.
8)
r, )
.'»)
8)
4)
.^)
SI
140
30
36
6r>
36
.0
.2
.2
.9
. 1
.8
1 101
(280
( 6C
(71
( 1 30
(7:1
'»
.1)
4J
. /)
.2)
. 'i)
Mill is now closed.
(a)  F - mill with S  HPT  flow;  R  -  mill  with $BPT BOD5 .
(b)  Pulp w;is not hlcachpil  .it  this  mill  snd data a rp thrrrf»rr not  inrludnl  in  .nvprag
(c)  Production d.it.i  IIP Id confidential.
(d)  Raw wast«>  flows  from thpsr mills  wr>rr  used to ilevelop 'he- empirical  relation  bc.-twcrn raw wnste flow anil percent  .sulfitc
     pulp produced on-site  (see Figure V-19).
(e)  Pulp mill  operations werp  shut down shortly after data were gathered.   This mill did rtot employ a recnvi-ry system.   D.-iln
     a rr not  included in  the averages.
(f)  The pulp mill operations  werp  shut  down.   Operations a'  this mill are now  representative of the Nmti nt rx' .1 1 ed-T i ssii*- r.ip<
     subc.Tlogory .
(g)  Mill is  now closed.
(h)  This mill  produces glassinp  papprs.  Data are not included in  the averages as effluent is not considered typical  ol
     the subcatcgory.
(i)  Only a portion of  raw  waste  load  was reported.   Mill dita not  included  in  averages.
( j )  The average percent  sulfitc  pulp  produced on-site is b ised on  those  mills  used to develop the empiric1;*! relation  hclvc-rn
     flow anil percent sulfite  pulp  (sec  footnote d).

-------
At mills in these subcategories, a sulfite cooking process is employed
to  produce  pulps  from which writing, printing, business, and tissue
papers are made; pulps are produced using  calcium,  sodium,   ammonia,
and  magnesium  cooking  bases.   The  average  quantity of papergrade
sulfite pulp produced at these mills is 58 percent of  the  total  raw
material furnish.

Spent  liquor recovery systems employed in this subcategory range from
no recovery  to  the  use  of  spent  liquor  evaporation  systems  in
conjunction with modern kraft-type and fluidized bed recovery furnaces
and incinerators.  As shown in Table V-9, mills where recovery systems
are  not  employed  have  significantly higher flow and BOD5_ raw waste
loadings than mills where recovery is practiced.   Two  mills  without
recovery  systems  have  recently  been  closed  leaving only one mill
without an adequate recovery system.

BPT effluent limitations were established for two separate  papergrade
sulfite  subcategories:  drum wash and blow pit wash.  Allowances were
provided for acid sulfite cooking of sulfite pulp and for  mills  with
barometric  condensers.  Therefore, available raw waste load data have
been reviewed with respect to the type of washing  system,  condenser,
and cooking liquor used.

The trend in the industry has been to the use of drum washing systems.
Since  1976, drum washing (vacuum washing) systems have been installed
at two additional mills.  Figures V-17 and V-18 present information on
the effect of washing processes on raw waste load BODS^ and flow.   Raw
waste  flow and BOD5_ data from five papergrade sulfite mills have been
excluded from the plots shown in Figures V-17 and V-18.   Mill  040001
has  been eliminated because pulp is not bleached at this mill.  Mills
040007 and 040006 have been eliminated because  recovery  systems  are
not  employed at these mills.  Mill 040010 has been eliminated because
of its significantly higher  flow  relative  to  other  mills  in  the
subcategory.  It should be noted also that BOD5_ raw waste load at this
mill  is  the  lowest  in  the  subcategory.   Mill  040019  has  been
eliminated because only a portion of its raw waste load was  reported.
No  significant  difference  in  either the raw waste BOD5_ or flow for
mills using blow pit washing compared to drum washing was found.

As illustrated in Figures V-17 and V-18,  the  percentage  of  sulfite
pulp  production  relative  to total production was determined to be a
more significant factor than the  type  of  washing  system  employed.
Figure  V-19 presents an equation, developed using a least squares fit
method, that relates raw waste  flow  to  the  percentage  of  on-site
sulfite   pulp   production.    The  correlation  coefficient  squared
(rz=0.87) reflects the good statistical correlation of the regression.

Figure V-20 presents  a  plot  of  BOD5_  raw  waste  load  versus  the
percentage  of  sulfite  pulp  produced  relative to total production.
Information is presented on the type  of  chemical  base  and  cooking
process.  There is no apparent correlation between BOD5. raw waste load
and  the cooking process (acid or bisulfite) or cooking base (calcium,
sodium, ammonia, and magnesium) used.
                               142

-------
  120(240)
  lOO(ZOO)-
7 60(1601-
  60 ( 120)
  40( 80H
  
-------
                                          FIGURE V-18
                      EFFECT OF WASHING PROCESS ON RAW WASTE FLOW
                              PAPERGRADE SULFITE SUBCATEGORY
  350 (84H
  JOO (
- 250(601-
  .'OOI48J
  150(361-
  100(24)
   SO f 1
                                                             S)
                    O
LE6ENO
WASHING PROCESS
O DRUM WASHING
El BLOW PIT WASHING
       20
                 30
                         —,—
                          40
                                   50
                                            60        TO
                                        PERCENT SULFITE PULP ON SITE
                                                               80
                                                                        90
                                                                                  100

-------
                                             FIGURE V-19
                      RAW WASTE FLOW VS. PERCENT SULFITE PULP ON SITE
  3OO(72)
  250(60)
  200(48)
*
o
In  Ib0(36)
s
I
   tOO(24)
   50 (
         10
L_EGt_N0


• - ACTUAL MILL DATA
1 -. HAW WASTE FLOW
*= PERCENT SULFITE PULP ON SITE
                             » = I2,6?B001'«
                             R* = 08?
                             STD, EHBOB EST. = 6.28
._!	  .. L	
20         30
                                       40         50         60         7O
                                             PERCENT SULFITE PULP ON SITE
                                                                                 BO
                                                              a..
                                                              90
                                                                                                     100

-------
                                          FIGURE V-20
                      EFFECT OF COOKING PROCESS ON RAW WASTE BODS

                              PAPERGRADE SULFITE SUBCATEGORY	f
   I23(250h
   IOO (200)-
    73 (ISO)-
o
o
to

u   30(IOO>
    23
     0 (0)
           LEGEND

COOKING PROCESS   COOKING BASE
                                                              • ACID SULFITE


                                                              H BISULFITE
               C  CALCIUM


               No  SODIUM


              NHj AMMONIA


              M«0 MAGNESIUM
                                       • C
                                                                                              Be,No
                               • C
                                                                     ' NH3
                                    »C
                                                       NH3
        10
                  20
                                     40         SO        60




                                         PERCENT SULFITE PULP ON SITE
                                                                  70
                                                                           SO
                                                                                              100

-------
Figure V-21 presents information on the effect of  condenser  type  on
wastewater  discharge.    There  is no apparent correlation between raw
waste flow and the type of condenser used.

Groundwood-Thermo-Mechanical.   Data are available for two  mills  that
produce  only groundwood-TMP pulp on-site.  However, the number of TMP
installations  employed   at   complex   mills   in   the   integrated
miscellaneous  grouping  has increased in recent years.  All available
data   on   raw   waste   load    characteristics    resulting    from
groundwood-thermo-mechanical pulping operations are presented in Table
V-10.  Included in the table are data representative of TMP production
at  an  integrated  miscellaneous mill where groundwood and unbleached
sulfite pulp are produced to manufacture  newsprint  and  some  market
pulp.  The data for this mill reflect the BOD5_ contribution that would
be expected from the production of newsprint from TMP pulp.

EPA  reviewed  the  raw  waste  load information used to establish BPT
effluent limitations for the groundwood-thermo-mechanical subcategory.
The Agency found that the raw waste load was actually based on a  mill
where chemicals were added prior to refining.  As shown in Table V-10,
EPA revised the BPT BOD5_ raw waste load to reflect the average load at
mills  where  wood chips are pre-softened by heating, with no addition
of chemicals.

Groundwood-CMN Papers.   Available data  on  wastewater  discharge  and
BOD5_ and TSS raw waste loads are presented in Table V-l1 for six mills
where  groundwood  pulp  is  produced  on-site  using either stones or
refiners.  Average on-site pulp production  is  73  percent  based  on
total  mill production.  Major products include newsprint, molded, and
other coarse  and  specialty  groundwood  products.   Raw  waste  load
characteristics  are  relatively constant for all mills representative
of this subcategory with the exception of one  mill  (No.  052016)  as
presented  in Table V-ll.  Average raw waste loads for this subcategory
are  higher  than  those  used  in the development of BPT limitations.
Figures V-22 and V-23 present plots of raw waste flow and BOD5_  versus
the   percentage   of  groundwood  pulp  produced  relative  to  total
production.  No  correlation  is  evident  for  either  BOD5_  or  flow
relative to the percentage of groundwood pulp used.

Groundwood-Fine   Papers.    Data   are   available   on  eight  mills
representative of this subcategory.   Table  V-l2  presents  available
data  on   flow,  BOD5_,  and TSS raw waste loadings.  Printing grades of
paper, both coated and uncoated, are  produced  at  these  mills  from
groundwood  pulps produced on-site.  Groundwood pulp relative to total
production varies from 31 to 82.5 percent  and  averages  47  percent.
The remainder of the furnish may be filler or coating pigments as well
as purchased softwood and, to a lesser extent, hardwood pulps.

Raw  waste  flow  and  BOD5_ have been plotted versus the percentage of
groundwood pulp manufactured on-site  relative  to  total  production.
These  plots  are  presented  on  Figures  V-24 and V-25.  No apparent
correlation exists between  either  BOD5_  or  flow  to  percentage  of
groundwood pulp manufactured.
                                147

-------
  40O(96)-i
  330(84)-
  300(72)
~ 250(60)-
I  200(461-
*
o
   150(36)-
   100(24)-
   50 (121-
    0 (0)
        10
                                         FIGURE V-21
                     EFFECT OF CONDENSER TYPE ON RAW WASTE FLOW
                            PAPERGRADE SULFITE  SUBCATEGORY
LEGEND
TYPES OF CONDENSERS
•  SURFACE
(H  BAROMETRIC
A  VAPOR RECOMP
[•]  COMBINED SURFACE AND BAROMETIC
                  20
                                     4O        50        6O        70

                                         PERCENT SULFITE PULP ON SITE
                                                                           60
                                                                                     90
                                                                                              IOO

-------
                                                          TABT.F. V-10

                                                  SUMMARY RAW WASTE I.OAI) DATA
                                          GROUNDWOOD-TII^RHO-HF.CHANICAI. SUBCATF.GORY



f."
vO


fu[p (%)
Mill No. TUP Other GWD (L/d)
070001 90 0 155
070002(b) 88 12 497
O4000.)(c)
Ave rage
MPT Rnw W,.ste Load
Assumed DPT Haw Waste Load
Average of Mills with SBPT flow
Average of Mills with S Assumed BPT BODS
Product
Type kl/k
Coarse, Uncoaled 81.
Printing
Newsprint 33.
Newsprint
57.
88.
88.
57.
57.
Flow
kg (kgal/t)
4 (19.5)
4

6
0
0
6
6
(8.
_tl
(13.
(21.
(21.
(13.
(13.
0)
-)
8)
1)
1)
8)
8)
19.
16.
28.
21.
39.
21 .
17.
17.
BODS
Lkk_8_
.0
.2
.5
.2
.2
.2
.6
.6
(38.0)
(32.3)
.(V7._0)
(42.4)
(78.4)
(42.4)
(35.2)
(35.2)
TSS
41.3
43.4
.„"
42.3
39.9
39.9
42.3
42.3
	 (_lb/
(82.
(86.
.._(_-
(84.
(79.
(79.
(84.
(84.
t) 
-------
                                                              TABLK V-ll

                                                      SUMMARY RAW WASTE LOAD DATA
                                                   GROUNDWOOO-CMN PAPERS SUBCATECORy
                    Production Profile
                                                                                  Raw Waste  Load

til 11 No
0520 It.
0.'>40()4(1
Or>40(l(,(i
or>40IO(l
o-^oi-,

Average
lil'T HJW
GWD Kurnisli Product
...%_. . (t/d) 	 (t/_d)_. ._ 	 TyEe 	
78.7 74 94 Newsprint, Fine
79.2 369 465 Newsprint
i) 61.5 39 64 Molded
) 72.4 (c) (c) Molded
• ) 72.7 8 11 Molded
70. 5 693 983 Newsprint,
Special ties
72.5
Wjatc Load

	 _kj/
99
46.
94.
109.
121 .
118.

98.
99.
I
^k£
.7
.7
.3
.3
.9
.9

.5
.3
•'1 ow
	 (Mf
(23.
(11
(22.
(26.
(29.
(28.

(23.
(23.

.9)
.2) 20.0
.6) 27.0
.2) 19.1
2)
5) 21.4

6) 21.9
.8) 17.4
BODS
	 (Ib/t)
(40.0)
(53.9)
(38.2)
(")
(42.7)

(43.7)
(34.8)
TSS
	 ks/kkg 	 (J.
103.6 (207
56.4 (112
(
47.3 (94

69.1 (138
48.5 (97

b/t) JBP;
") F
.2) F
-7)
")
.5)

.1)
•0)
(d)   K-Mi11 with 
-------
  160(36.4)'
  140(33 6)
S I2QJ28.8)
*o
o
  IOOS24.OJ-
  80(19,2!-
  60(14.41-
  40 ( 9.6)
                                         FIGURE V-22
               RAW WASTE FLOW VERSUS PERCENT GROUNDWOOD PULP ON SITE
                          GROUNDWOOD-CMN PAPERS SUBCATEGORY
                55
                                           TO        T5
                                     PERCENT GROUNDWOOD PULP ON SITE
                                                                               9O

-------
                                                       FIGURE V-23
                              RAW WASTE BOD5 VERSUS PERCENT GROUNDWOOD PULP ON SITE
                                          GROUNDWOOD-CMN PAPERS SUBCATEGORY
\>
                    35(70)-i
                   30(601-
                  5 25I5O)-
                   2OMO)-
                    15(30)-
                    10(201-
                    51 IO)J
                       50
                                55
                                        60
                                                 65
                                                         7O        75
                                                   PERCENT GROUNDWOOD PULP ON SITE
                                                                          80
                                                                                   85
                                                                                           90
                                                                                                   95

-------
                                                               TAB1.K  V-12

                                                       SUMMARY RAW WASTE  LOAD DATA
                                                   C;ROUNI)WOOI>-KINK PAPERS  SUBCATECORY
Mill No.
052003
052 004
052005
052007
052008
052013
052014
054014
Avi? rage1
HPT Kaw
Average
Avt- rage
Production Profile
GW1) Pulp"" Product
. 	 (%) 	 	 (i/lL _...." Type
51 .
31.
39.
58.
41.
38.
34.
8_L
47.
Waste Load
0
0
1
0
8
5
0
5
0

of Mills with
of Mills with
535
481
755
224
787
(a)
285
76


*BPT flow
SBPT BOD5
Printing
Coated
Print ing
Printing
Coated
Coated
Coated
Printing
Specialties



Raw Was to Load
Flow
kl/l
88.
65
55
96
54
70
54
61
68
91
64
66
k8
1
i,
(16.
(21.
(15.
(16.
1)
8)
3)
2)
1)
8)
1)
11
4)
9)
4)
0)
12.2
28.6
27.8
--
10. 1
15.6
12.0
16.8
17.6
16.7
17.6
12.5
(24.
(57.
(55.
(-
(20.
(31.
(24.
(12.:
(35.
(33.
(35.
(24.
3)
2)
6)
-)
1)
2)
0)
6_)
1)
3)
1)
9)
61.0
79.2
56.7
--
56.0
41 .4
36.9
46.6
54.0
52.5
54.0
48.8
(II.
(122
( 1 58
(113
(
(112
(K2
(73
(y3
(107
( 105
(107
CJ7
A).
.0)
.<•)
.3)
--)
.0)
.7)
.7)
.2)
.9)
.0)
.9)
.6)

-------
Jl
                  IIO (26.4)
                  IOOI24.O)
                a 9OIZI.6)
                •—
                o
                  8OII9.2)
                §
                I fO( 16.8)
                
-------
                                     FIGURE V-25
            RAW WASTE BOD5 VERSUS PERCENT GROUNDWOOD PULP ON SITE
                      GROUNDWOOD-FINE PAPERS SUBCATEGORY
  30 (60)
  25 (SO)-
  20(401
  13(30)
* 10(20)
  5(10)
   0(0)
     20
              30
                      40
                               50        60       70
                             PERCENT GROUNDWOOD PULP ON SITE
                                                         80
                                                                 9O
                                                                          100

-------
Integrated   Miscellaneous   Mills.    Available  data  on  wastewater
discharge and BODJi and TSS raw waste loadings at all  remaining  mills
with  on-site  production  of pulp(s) are tabulated in Table V-13.  At
these mills,  multiple  pulping  operations  or  miscellaneous  pulping
processes not adequately described by specific subcategory definitions
are  employed.    Information  is also provided on the types of pulp(s)
produced and the various products manufactured on-site.

Deink.  Flow, BOD5_, and TSS raw waste load data are  available  on  20
mills  representative of this subcategory and are shown in Table V-14.
At these mills,  printing grades of paper,  tissue,  or  newsprint  are
produced.

Raw  waste  flow and BODI5 data were evaluated to determine if the type
of product manufactured or the percentage of deinked pulp relative  to
total  production  affects raw waste loadings.  In Figures V-26 and V-
27, data on flow and BOD5^ are plotted relative to  the  percentage  of
deink  pulp  produced on-site.  No apparent correlation exists between
flow and BOD5^ raw waste loads as  a  function  of  the  percentage  of
deinked pulp produced on-site.

However,  because of differences in flow and BOD5_ raw waste loads, EPA
concluded that the deink subcategory  should  be  divided  into  three
separate  groupings:  fine,  tissue,  and  newsprint.  Generally deink
mills where tissue is produced exhibit the highest flow, BOD5^ and TSS
raw waste loads, while mills where  newsprint  is  produced  have  the
lowest raw waste loads.  The average raw waste loads for each of these
product sectors is shown on Table V-14.

Tissue   from   Wastepaper .    Data   are   available   for  21  mills
representative of this subcategory.  Principal products  are  sanitary
and  industrial  tissue,  including industrial packaging, wadding, and
packaging and wrapping tissue.  At these mills,  mixed  wastepaper  is
generally  processed with little preparation, except for screening and
cleaning prior to paper production on the papermachine.
Table V-15 presents available data on wastewater  discharge  and      ^
and  TSS  raw  waste  loadings.  There are nine mills where industrial
grades and 12 where sanitary grades of tissue are made.  There are  no
significant  differences  in  raw  waste loadings for industrial grade
mills compared to sanitary tissue mills.

Paperboard  from  Wastepaper.   Data  are  available  for  146   mills
representative  of  this subcategory, which is the largest in terms of
number of mills in the pulp,  paper,  and  paperboard  industry.   Raw
waste  load data are presented in Table V-16.  Flow, BOD5_, and TSS raw
waste loadings are low compared to other industry subcategories.  Mill
sizes range from 0.5 to 871  kkg/day  (0.6 to 960  tons/day),  averaging
129   kkg/day   (142  tons/day).   Products  made  at  mills  in  this
subcategory include linerboard, corrugated  board,  chip  and  filler,
folding  boxboard,  set-up  box,  gypsum board, and other construction
boards, packaging materials, and automotive boards.   At  most  mills,
three or more types of products are produced on-site.


                                156

-------
          TABLE V-I3
  SWWARY RAW WASTE LOAD DATA
INTEGRATED MISCELLANEOUS MILLS



Production
Hill No. A
010010 4IK
0100! 1 3K
010012 209K
0)0013 I01K
010014 137K
010015 232K
010022 140K
010026 I35K
010027 (b)
010039
010050 615*
010056
010059
015010 638UK
030O03
0300O7
030008 20K
030011 251K
030014
0.10016
030017 (b)
030019 494
030021 69S
030025 1 68K
030029 (b)
030035
030036
030038 (c)
030040 185K
030041 164K
030043 (b)
030044 92K
030050
030053
030054 (b)
030055 (h)
030056
040003 721,
040004
040005
B
798U1C
156U
335UK
751UK
1,1931)
264U
—
505UIT
(b)
—
—
—
—
—
310U
633W
416UK
—
169K
—
(b)
--
—
—
(b)
—
—
—
I19KU
—
(b)


9671IK
(b)
(b)
413KU
—
--
--
C
903USK
8651!
336UK
—
—
68211
1,0070
—
(b)
61 7U
7 SOU
1,59008*
934US
2S9US
975US
528KU
406K
—
—
1,1371*
(b)
—
—
—
(b)
1 ,050K
—
1.4IOUK
—
—
(b)
670K
1,549X5
—
(b)
(b)
I68K 1
—
--
..





Profile (t/d FuroiibK*)
D
..
—
—
—
—
--
—
—
(b)
—
—
—
--
23K
878W
--
—
394K
527K
—
(b)
100KG
292E
439K
(b)
--
—
—
43IK
140K
(b)
854K
—
--
(b)
(b)
,019K
--
185).
--
B
_.
4S4
—
—
—
--
—
—
(b)
326
--
—
—
—
—
--
--
—
—
—
(b)
226
593
--
(b)
454
--
--
--
--
(b)
—
--
356
(b)
(b)
--
420 LOG
—
--
r
..
—
—
—
—
—
«
20RK
(b)
«
—
—
—
-„
—
.,
2*5
—
713
—
(b)
—
—
—
(b)
..
—
—
10IK
49K
(b)
—
--
..
(b)
(b)
--
--
_,
i?3r,P
G
112
—
9
—
—
—
—
33K
(b)
—
—
—
--
—
—
—
—
—
11K
—
(b)
--
—
—
(b)
--
—
.-
—
-_
(b)
—
—
__
(b)
(b)
--
--
..
--
Total
1,854
1,478
889
852
1,330
1,178
1,146
881
2.5)
( 188-6)
C2>' .3)
(35.4)

-------
TABI.K V-IJ  (Coul i f
1 1 ill No .
052006
052009
052010
052011
052017
054001
054002
054003
054005
054008
054009
05401 1
054012
05401.)
054016
054017
06000 1
060002
000003 (< )
080010
08001 1
080012
080013
,._. 080014
^ 080015
OK0016
080020
080023
080025
080035 (
-------
                                                        T\BI.E V-13 (Continued)
                                                                                             Raw Waste Loot!

Mill No.
150018
150020
150026
150029

A
85T
8N
1ST
(b)
Production Profile (t/d furni ;h) (a
B C D E F G
-.- -. „_, -- -_ _-
123N
-.
(b) (b) (b) (b) (b) lb)
)
Total
85
131
18
(b)
Flow
kl/kkg_ (kgal/t) _kg/kk{
122.7 (29.4) 3.8
577.6
74.7 (17.9)
	 	 	
BODS T
[ (Ib/t) kg/kkg
( 7 . ( > ) 11.8
(1)55.2) 441.0
67.6
— —
sr
(ii./t)
(2:1.5)
(RB2.0)
(135.2)
	
(a)  Product Designations

A.  Market Pulp
B.  Packaging and Converting Products
C.  Board and Construction Products
D.  Printing Writing and Related Papers
E.  Newsprint
F.  Sanitary Tissue
G.  Other - Includes specialty, thin, synthetic,
            non-wood (other than cotton writing),
            construction, and molded papers.
Furnish Designations
G.  Groundwood
K.  Kraft, bleached
U.  Kraft, unbleached
S.  Semi-Chemical
T.  Cotton
R.  Recycled Pulp (Wastepaper)
N.  Non-wood (Other than cotton, includes synthetics)
M.  Chemi-Mechanical
L.  Sulfite
P.  Greater than 50% purchased pulp
0.  Thermo-Mechanical
X.  Soda
Y.  Deinked
(b)  Production data held confidential.
(c)  Mill is closed.
(d)  Mill was an integrated miscellaneous mill at time of data collection, but has subsequently ceased pulping operations
     and is now classified as Nonintegrated-Fine Papers (I otton Fiber Furnish).

-------
                                                           TABLE V-14
                                                   SUHHAK7 RAW WASTE LOAD DATA
                                                        OEINX SUBCATEGORT
Production Profile
Furnish (t/d)
Hill Ho.
Deink Fine
140005

140007

140008

140017
140019
Average
(t/d) (a)

188

155

77

(d)
43

X0>) WP

SI —

57 55

62 9

61 (d)
60 —

Pureh (t/d)
Pulp Broke

166

54

10

(d)
8


19

41

29

(d)
18

Product
(t/d)

379

349

128

(d)
65

Type

Uactd Print
Writing
Ctd & Unctd
Printing
Unctd Print
Writing
Ctd Print
Unctd Print

BPT lUw Watte Load
Average of
Average of
Hill* with
Hill* vitb
san flow
SBPT JOD5








Flow
kl/kkg

100.1

53.8

114.8

126.0
44.7
88.1
102.0
66.4
88.1
(kgal/t)

(24.0)

(12.9)

(27.5)

(30.2)
(10.7)
(21.1)
(24.4)
(15.9)
(21.1)
Raw
Waste Load
BODS
kg/kkg

17.4

55.0

72.8

20.4
20.9
37.3
90.0
31.1
37.3
(Ib/t)

(34.8)

(110.0)

(145.5)

(40.7)
(*!.«)
(74.6)
(180.0)
(62.2)
(74.6)
TSS
kg/kkg

197.3

162.1

189.0

216.0
106.0
174.1
202.5
155.1
174.1
(Ib/t)

(394.6)

(324.1)

(377.9)

(432.0)
(211.9)
(348.1)
(405.0)
(310.2)
(348.1)
SBPT
(c>

BF

BF

B

B
BF




Dei ilk Tiaaue

140010
140029(e)
140030(f)
140011
140014
140015
140018(g)
140021
140022
140024
140025
140028
             (d)
              20
              60
             (d)
             (d)
             (d)
              36
             170
              56
             (d)
              92
             (d)
Average

BPT Raw Waate Load

Average of Hills with
Average of Mill, with

Deink Mevsprint(g)

140002 (h)
140003 (h)
I40013(h)

Average
 50  (d)
 73
 40   30
 96  (d)
 94  (d)
100  (d)
 97
 87
 48
100  (d)
 85
 99  (d)
                      SBPT flow
                      SBPT BOD5
(d)
  6
 30
(d)
(d)
(d)
 26
(d)
  4
(d)
(d)
(d)
(d)
(d)
  1
 20
  6
(d)
 11
(d)
(d)
 22
100
(d)
(d)
(d)
 36
150
 50
(d)
100
(d)
San Tissue
a«a Tissue
San Tiaiue
San Tissue
San Tissue
Tissue
Ind Wrap, Tissue
San Tiasue
San Tiasue
San Tiaaue
San Tiasue
San Tissue




118.1
--
75.1
90.6
90.6
139.8
25.5
205.7
166.9
203.2
62.6
156. 1
136.9
102.0
81.4
119.3
                                                        (19.5)
                                                        (28.6)
56
104
73
80
148
35
112
87
90
71
61
.7
.3
.2
.3
.3
.9
.6
.2
.0
. 1
.3
(113.4)
(208.5)
(146.3)
(160
(296
(71
(225
(174
(180
(142
(122
/
.5)
-5)
-8)
.1)
.3)
.0)
.2)
.6)
166
292
225
24?
320
161
375
251
202
226
192
.6
.1
.8
.3
.8
.6
.2
.0
.5
.5
. 1
(333
(584
(451
(494
(641
(323
(7jO
(501
(405
(453
(384
.2)
-2)
• 5)
.5)
.6)
•2)
^3)
• 9)
.0)
.0)
.2)
BF
F
BF
F
B
BF


                                                                        67.6     (16.2)     15.9    (31.7)    96.8  (193.5)
(a)  Wastepaper to deink proceas.
(b)  Percentage of deink pulp used calculated by subtracting waatepaper,  purchased  pulp,  and purchased broke from final
     daily production, assuming this is equal to the amount of  deink  pulp utilized,  then  dividing by the final daily pro-
     duction.
(c)  F - Hill with SBPT flow.
     B - Hill with SBPT BODS.
(d)  Production data held confidential.
(e)  Self-contained; not included in averages.
(f)  Operates with low deink use.  Not  included in averages.
(g)  Produces a coarse grade and recirculates approximately 50% of  its  treated  effluent.   Not included in averages.
(h)  Production and raw watte load data held confidential.
                                                           160

-------
  240(5/6)
  200 (480)
S 160(38.4)-
*
o
I
  120(28 81-
  80(19.21-
  40 (  961-
    0 (0||
       20
                                          FIGURE V-26
                 RAW WASTE FLOW VERSUS PERCENT DEINK PULP PRODUCED
                                     DEINK SUBCAfEGORY
  LfcGENO
PRODUCT TYPE

O DEINK - FINE
A OEINK - TISSUE
                                                                  A A
                                              O
                 30
                                    SO        6O        70
                                     PCHCCNT DEINK PULP USED
                                                                ao
                                                                          90
                                                                                   100

-------
                                           FIGURE V-27
                        RAW WASTE BODS VERSUS DEINK PULP PRODUCED
                                      DEINK SUBCATEGORY
  150(3001
   125 (2SO>-
  100 UOOl-
8
e
tol
I
*
   73(190).
   SO (I DOl-
   25 ( 5OI-
     0(OJ
  LEGEND
PRODUCT TYPE
G OEINK-FINE
A DEINK - TISSUE
                           40
                                              00
                                    SO        6O        7O
                                      PERCENT DEI NX PULP USED
                                                                • 0
                                                                          9O
                                                                                   100

-------
                                           TABLE V-15

                                   SUMMARY RAW WASTE LOAD DATA
                               TISSUE FROM WASTEPAPER SUBCATEGORY
Raw Waste Load
Production
Flow
Mill No. (t/d) kl/kkg
(kgal/t)
BOOS
kg/kkg
(lb/t)
TSS
kg/kkg
(lb/t)
SBPT(b)
I. Industrial Tissue
090002 19.5
085004 47.0
085006 (a)
090006(c) 10.5
100005 15.2
100011 11.2
100012(c) 7.0
100015 5.5
100001 (a)
Average w/o
Self-Contained Mills
II. Sanitary Tissue
090004 20.0
090010 (a)
100002 7.5
100003 83.0
100004 15.0
100007 (d) 20.0
100008 16.0
100013 20.0
100016 7.3
105007(c) 11.9
090014 40.7
100014(c)(d) 20.7
Average w/o
Self -Contained Mills
Overall Average w/o
Self-Contained Mills
BPT Raw Waste Load
Average of All Mills
with SBPT flow
Average of All Mills
with SBPT BOOS
72.6
141.9
138.1
29.2
62.2
35.5
84.7
99.7
59.7
76.8
51.7
(17.4)
(34.0)
(33.1)
(7.0)
(U.9)
(8.5)
(20.3)
(23.9)
(14.3)
(18.4)
(12.4)
22.4 (44.7)
37.6 (75.1)
14.2 (28.4)
106.4
103.3
46.7
38.0
(212.8)
(206.5)
(93.3)
(76.0)
F
BF

6.5 (13.0)
20.2 (40.3)
18.8 (37.6)
8.7 (17.3)
13.3
65.3
59.4
9.2
(26.5)
(130.5)
(118.7)
(18.4)
BF
F
F
BF


156.5
237.9
22.1
138.5
9.2
120.2
111.0
105.0
68.0
88.9
(37.5)
(57.0)
(5.3)
(33.2)
(2.2)
(28.8)
(26.6)
(25.2)
(16.3)
(21.3)
9.3 (18.6)
53.5 (107.0)
22.0 (44.0)
22.5
21.5
14.5
12.1
9.7
(44.9)
(42.9)
(29.0)
(24.1)
(19.3)
88.9
128.0
68.2
70.7
68.3
110.5
30.0
37.4
(177.8)
(255.9)
(136.3)
(141.4)
(136.5)
(221.0)
(59.9)
(74.7)
B


(a)  Production data held confidential.
(b)  F-Mill with SBPT flow; B-Mill with SBPT BOOS.
(c)  Extensive wastewater recycle performed; not included in averages.
(d)  Mill is now closed.
                                       163

-------
                                                                            TABI.K. V-16
CTi
             Mi 11
             No.
                        A     B     _C      I)

             NoMforrugal ing Medium  Fumi sh
                                SUMMARY RAW WASTK LOAD DATA
                          PAPERBOARD FROM WASTEPAPKR SUBCATK.GORY

production  Profile ^t/d)  (a)  	                                     R.iw Waste Load
                                      Percent
                                     Corrugated     	Flow    _            BOD5               TSS
             E     F    _G    Total    Furnish   kl/kkg     (kgal/l)    kg/kkg    (Ib/l)   kg/kkg    (ll'/tj   *BPT(I>)
085002
085009
110001 (c
110002
1 I0003(p
1 10004
110005
I 10006
1 1(1007
1 10008
110009
1 1001 1
110012
1 1 00 1 3
1 1 00 1 5
110016
110017
1 1 00 1 ft
110019
1 10020
110022
110023
110024
110026
110029
11(1031
110032
110033
110034
1 1 0035
1 10036
110037
1 10038
110039
110040
110041
1 10043
110044
110045
110046
) 300 250 240
45
) (c) (c) (c)
_
16
.
-
.
94
14
...
(410
-
_
-

_
_
138
223 90
_
2
-
_
9f> - -
.
_
_
-
-
(<) (c) (r)
(c) (r) (c)
8B - 16
130
108
100
_
170
-
(c)
-
130
127
170
58
-
35
208
C+D
-
-
-
18
9
Z3
-
-
-
-
-
74
-
-
150
61
89
92
(c)
(r)
-
30
-
175
-
-
-
(c) (<)
178
16
-
-
14
-
-
-
) -
-
-
-
25
23
-
-
-
-
133
150
-
-
165
27
-
57
-
(c) (c)
(<•) (c)
-
-
-
25
-
35
90
-
(r)
-
-
-
-
-
-
122
-
-
79
49
84
36
54
17
-
24
150
-
-
-
-
-
44
-
20
3
(c)
(c)
-
-
-
-
-
35
90
960
45
(r)
178
162
127
170
72
94
171
208
410
79
49
84
79
86
40
138
337
150
135
150
74
96
165
221
61
166
95
(c)
(r)
104
160
-
300
36
                                         56
                                          ft
                                         59
                                         31
                                         19
                                         10
                                         46
                                         24
                                         18
                                         45
                                          7
                                         40
                                         18
                                         22
                                          0
                                          0
                                          0
                                         49
                                         20
                                         17
                                         26
                                         56
                                         71
                                          0
                                         63
                                         44
                                         6)
                                         R2
                                         II
                                          5
                                          9
                                         28
                                         16
                                         IB
                                         Ift
                                         35
                                         46
                                         39
                                         3/.
                                         ft?
37.1
28.4
0.4
20.9
15.9
10.0
16.3
23.4
17.9
15.9
25.5
(8.9)
(6.8)
(0.1)
(5.0)
(3.8)
(2.4)
(3.0)
(5.6)
(4.3)
(3.8)
(6.1)
--nr I I -con ta
8.9
12.5
2.0
--
13.0
32. 1
Srt 1 f /"lift 1 -i
PI i - L<*n i «i
20 . 3
3.6
7.3
4.5
12.5
	 C.. 1 t _ /•'.,., 1 -»
i nrn 	
(17.7)
(25.0)
(3.9)
(--)
(25.9)
(64.6)
i f\ttr\
1 tl«'Cl - ~ 	
( 40 6 )
(7.1)
(14.6)
(9.0)
(25.0)
12.6
19.3
10.8
--
12.1
23.'.
6.4
8.2
11.1
103
35 . 9
(25.2)
(3R.5)
(21.5)
(--)
(24.2)
(47.2)
(12. R)
(16.3)
(22.2)
(20.6)
(71.7)
n
K
KB
K
K
r
F
KB
FB
rB
K
_ c~ i r f.,., t -,;„„.!
2.5
	
__
76 4
4.2
9.6
7. 1
18.8
83
40.9
31.3
25.0
35.9
18.8
30.0
37. 1
(0.6)
	
(--)
(18.3)
(1.0)
(2.3)
(1.7)
(4.5)
(2.0)
(9.R)
(7.5)
(6.0)
(8.6)
(4.5)
(7.2)
(8.9)

--Srlf-Cnnla
__
14.1
3.2
— Sc 1 f -Con t a
7.5

13.0
3.7
--Sp 1 f -Cont a
12.5
15.4
9.7
5.2
i nrd 	
/ •)
\ /
(2R.21
(6.3)
( 14.9)

(26.0)
(7.3)
i ncfi 	
(24.9)
(30.8)
(19.4)
(10.4)
1.0 (1.9)
	 Sri f-("ontrtiiif*«i) 	
1.0 (2.0)
--
(--)
	
-_
21 .R
2. )
R.8
--
10. 7
1 .3
13.9
27.2
7.9
4. 1
1 . 1
39 . 3
7. 1
	
(-")
C-.4.6)
(4.5)
(17.5)
(--)
(21.4)
(2.6)
(27.8)
(54.3)
(15.7)
(R.I)
(2.2)
(7R.5)
(14.2)
1



Ml
FR
K
F
KB


Kfl
B
KB
KH


-------
TABLE ^ -16  (Com i lined)
Hi 1 1
No. A
110047
110048
110050
110051
1 1 0052
I 1005.3
110055 (153
110056 10
110059 (r)
110060 (r)
110061 (r)
110062
110064
110065
110066
110067
110068
110069
110070
110071
110072
110074
110075
110076
110077
110078
1 10079
i i nnft i -
1 lUV/o J *
110082
1 1 OOA1 ( r )
I J V/wO»> V, *• )
110084
110085(d)(e)
i i nnQ A
I HJUoo -
110087
110088
110089
110090
110091
110092
110093
110094
110095 (r)
110096 (r)
Pro,
B C
100
-
32
40
-
-
A+B+C)
(<*) (<~)
(c:) (c)
(c) (r)
(r) (r)
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
An
ou
45
(r) (r-)

68
lie
~ 1 1 :>
-
-
54
24
-
49
-
(c) (c)
(«•) (c)
jurtion Profile (t/d) (a)
IV ' rent
Cor: ug.itrd
D
70
-
234
146
-
300
-
-
(c)
(r)
(r)
89
-
-
-
-
-
134
68
-
-
-
-
-
-
-
-
40
(.y
(102
Q e
0 J
442
43
35
3
36
200
91
-
(<:)
(r)
F.
100
-
-
-
-
-
-
55
(c)
(c)
(c)
3
-
-
120
-
-
-
-
-
-
-
-
-
-
- •
-
30
1 r)

D+T.)
-
-
-
20
30
-
-
-
(c)
(r)
F
-
-
-
-
95
-
-
-
(r)
(c)
(c)
-
-
76
-
-
-
-
-
-
-
-
-
-
-
-
-
(r)
105
-
-
-
-
-
-
-
-
99
(c-)
(r)
G
-
53
5
9
-
-
-
(r )
(c)
(c)
(r)
4
11
-
-
58
437
-
-
58
152
63
68
99
175
63
61


52
-
-
-
-
-
-
-
-
('•)
(r)
ToL.il_
270
53
271
195
95
300
153
65
(0
(c)
(c)
96
11
76
120
58
437
1.34
68
58
152
63
68
99
175
63
61
An
ou
115
105
222
442
43
35
77
90
200
140
99
(r)
(< )
Fin nisli
23
8
24
33
26
34
99
47
44
56
1
32
26
23
--
20
23
49
34
47
61
0
69
66
54
81
75
81
19
65
11
33
41
29
11
22
27
6
30
21
30
29
kl/kkg
20.0
--
30.5
45.5
25.5
12.9
14.6
21.7
1 L J
i ** . f.
42. 1
--
31.3
34.6
	
--
5.4
28.8
7.5
30.9
4.2
--
.34.6
--
8.3
4.2
--
2.5
11.. 3
79.7
28 0
15.9
15.0
27.5
27. 1
--
11.7
1.3.4
1 .3
29.6
--
12.5
--
Flow
Kaw W.isLe l.o.nl
BOD5
(kg,il/L) kg/kkg
(4
(-
(7
CO
(6
(3
(3
(5
(10
(-
(7
(8
	
(-
(1
(6
(1
(7
(1
(-
(8
(-
(2
(I
(-
(0
(2
(19
(ft
\ o
(3
(3
(6
(6
(-
(2
(3
(0
(7
(-
(3
(-
.8)
-)
.3)
.9)
.1)
.1)
.5)
.2)
A ^
• ** /
.i)
-)
.5)
.3)
	 Scl
-)
.3)
.9)
.8)
.4)
.0)
-)
.3)
-)
.0)
.0)
-)
.6)
.7)
.1)
71
• ' )
.8)
.6)
S_ 1
.6)
.5)
-)
.8)
.2)
.3)
.1)
-)
.0)
-)
6 . 5
--
10.0
10.7
9. 1
8. I
16.4
9.2
in n
i 
I 1 . /
26.2
--
8.6
8.2
TSK
(il'/l )
(4.1)
(...)
(71 ")
(26.?)
(10.0)
Ci.5l
(71.5)
(14.1)
( iM 8 )
(52. I)
(-- )
(17.7)
(16.4)

MU'T
I-'B

B
B
M)
f-'R
K
FR
f' M


B

f-Containrd 	
--
7.7
1.5
6.5
7.4
--
--
10.4
--
--
5. 1
--
--

5.2
K 9
3.2
10.2
ffni-il n
67.5
--
--
1 1.3
R.O
3.8
--
--
21.7
--
(--)
(15.3)
(3.0)
(12.9)
(14.8)
(--)
(--)
(20.8)
(--)
(--)
(10.2)
(--)
(--)
(--)
(10.4)
( 1 7 R\
\ 1 / . O )
(6.4)
(20.3)
: -. -, j
(135.0)
(--)
(--)
(22.6)
(15.9)
(7.5)
(--)
(--)
(43.3)
(--)
--
9.8
1 .5
--
16.5
--
--
26.6
--
--
2.5
--
--
6.9
3.5
10.8
4.6
15.8
16.9
--
--
7.5
8.9
2.2
2fl.O
--
•'. . 0

(--)
(19.6)
(3.0)
(--)
(T).O)
(--)
I--)
(53.7)
(--)
(--)
(4.9)
(-- )
(--)
(13.;)
(6.9)
(21 . 5 )
(9.1)
(31.5)
( il . 7 •
(--)
( -- )
(149)
(17. R)
(4.3)
f 55.'l 1
f--)
( 7 . ') )
(-- )

KB
in
FB
It
F'

R

1
FH


F
B
KB
IB
FR
1
I-'

1-
i-n
II!
1

r


-------
TABLE V-16 (Continued)
Production Profile (t/d) (a;
Hill
No.
110097
110098
1 10099
110100
1 10101
110102
110103
110)04
110105
110106
110107
110108
110110
110111
1101 12
110113
110114
110115
110116
110117
110118
110119
110120
110121
110123
110124
11012!)
110126
110127
110128
110129
110130
110133(c)
1 10134
110115
110118
110140
110141(x)
110142
110141
110144
1 l(M45(e)
1 101 46
11014.7(0
)


Rav Waste Load

Percent
Corrugated Flov BODS
A
1
40
(c)



(c)



27
(c)
fc)



20
61
B
282
(r)





6
74
(0
(r)



23
49
C
93
5
61
(c)





200
30
101
(c)
(c)
14


38
66
49
85
7
20
15
D
54
108
(c)

90

(r)

136
6

6
195
(c)
(c)
76
Crl



41
30
12
13
234
E
8
50
(c)

D+E)

(r)
(r)
3
96
24
(c)
(c)
(r)



42
115
F
198
(c)

192
(c)
(r)



(c)
(c)
(c)



11
220
16
G
112
(c)
70
(c)
(c)
(r)
27
70
54
12
69
(c)
(r)



5
122
123
Total
206
128
390
61
198
50
(c)
(c)
262
114
90
(c)
(c)
(c)
(c)
136
206
27
79
54
42
170
128
99
195
(O
(c)
90
(c)
(r)

38
(c)
118
220
104
211
208
62
234
43
64
115
Furnish
92
53
80
60
33
0
80
74
80
42
16
3
43
21
21
62
26
43
0
46
0
44
32
69
53
2
3
29
45
69
38
14
54
74
40
47
41
45
15
95
53
24
42
98
22
kl/kkg
15.9
13.8
8.8
12.9
9.6
1.3
12.1
9.6
17.1
8.8
15.9
6.7
5.4
14.6
28.0
10.8
7.1
18.4
45.5
1.3
23.4
52.2
6.7
14.2
18.8
10.0
20.0
9.2
7.1
10.8
(kgal/t) kg/kkg (Ib/t)
(3.8) 10.3 (20.5)
(3.3) -- (--)
(2.1) - (--)
(3.1) -- (--)
(2.3) 3. .5 (7.0)
(0.3) 1.6 (3.1)
(2.9) 27.8 (55.6)
	 Self-Contalued 	
(2.3) 11.2 (22.4)
(4.1) 3.6 (7.2)
(2.1) 3.4 (6.8)
(3.8) 5.1 (10.1)
(1.6) 2.5 (5.0)
	 Self-Contained 	
(1.3) 4.4 (8.7)
(3.5) -- (--)
(6.7) 6.1 (12.1)
(2.6) 7.5 (15.0)
(1.7) 1.2 (2.4)
(4.4) 11.0 (22.0)
(10.9) 12.8 (25.5)
(0.3) 1.0 (2.0)
(5.6) 0.8 (1.5)
(12.5) 12.5 (25.0)
(1.6) - (--)
(3.4) 1.9 (3.8)
(4.5) 8.9 (17.7)
(2.4) 4.9 (9.8)
(4.8) -- (--)
(2.2) 7.0 (13.9)
(1.7) i.l (2.2)
(2.6) 1.8 (3.5)
kg/kkj
2.1
1.4
3.7
O.I
16.3
13.3
4.2
5.0
34.0
0.1
3.4
2.8
1.5
1.5
9.4
32.6
1.5
0.5
19.5
0.3
18.1
4.9
	
0.7
2.2

TSS
db/t)
(4.2)
(2.8)
(7.3)
(0.2)
(32.5)
(26.5)
(8.4)
(10.0)
(68.0)
(0.2)
(6.7)
(5.5)
(3.0)
(2.9)
(18.8)
(65.2)
(3-0)
(0.9)
(39.0)
(0.6)
(36.1)
(9.7)
I'-}
(1.4)
(4.4)
SBPT(b)
FB
F
F
F
FB
FB
F
FB
FB
FB
FB
FB
FB
F
FB
FB
FB
FB
FR
FB
F
FB
FH
KB
F
FB
KB
FB

-------
                                  TABIK V-16 (Continued)
Production Profi 1 e (t/dj (a)
                                                                      Raw Waste Load
Mi 11
P-rcent
Corrugated Flow
No. A B C D E F G Total Furnish
110149 - 3
110150 75 35 -
110151 20 28
110152 - - (115 C+D+F.)
150019 ------
Average of <100 pen cut corrugated furnish
(w/o self-contained mills)
BPT Raw Waste Load
Average of <100 percent corrugated furnish
Average of <100 percent corrugated furnish
Corrugating Medium Furnish
110010 ------
110014 90
110025 45 408 -
110028 8.) -
110030 - 126 -
110049 (c) (c) (c) (c) (c) (c
110054 97
110057 (c) (c) (c) (c) (c) (c
110073 - 150 -
110139 23 87 - - - -
Average of 100 percent corrugated furnish
(w/o self-contained mills)
BPT Raw Waste Load
Average of 100 percent corrugated furnish
Average of 100 percent corrugated furnish
3 73
60 57
48 55
115 18
1 I 0
mills


mills ^BPT flow
mills SBPT BODS

10 10 100
90 100
453 100
83 100
126 100
) (c) (c) 100
97 100
) (c) (c) 100
150 100
110 100
mills


mills «BPT flow
mills ?BPT BOD5
Average of All Mills (w/o self-contained mills)
Average of All Mills SRPT flow
(a) A = Linerlioard
B = CoiTiig^l ing
C = Chip f. Filter Board
n - Folding Board
E = Set-up Board
F - Gypsum Wai 1 hoard
C = Other Board Products
(h) F-Mills t included in averages of mills rmp








BODS .



iloying corrugating lurnish
BODS
kl/kkg (kgal/t) kg/kkg (lb/t)
1.7
--
12.9
20.0

19.2
30.0
14.2
17.5

__
3.3
10.8
0.8
5.0
2.9
—
30.5
(0.4)
(--)
(3.1)
(^8J

(4.6)
(7.2)
(3.4)
(4.2)

(--)
(0.8)
(2.6)
(0.2)
(1.2)
(0.7)
(--)
(7.3)
—
—
4.3
"_

9.2
11.3
8.8
5.9

—
13.2
19.3
0.6
--
5.4
--
17.5
(")
(--)
(8.6)
LIT/..-

(18.4)
(22.5)
(17.5)
(11.7)

(--)
(26.4)
(38.6)
(1.2)
(--)
(10.7)
(--)
(35.0)
kg/kk;
—
--
6.4
— —

10.4
11.0
8.7
7.8

--
11.1
2.3
1.3
5.1
2.8
--
28.5
TSS
g (lb/t)
<::>
(--)
(12.8)
(-.- )

(20.8)
(21.9)
(17.4)
(15.5)

(--)
(22.2)
(4.6)
(2.6)
(10.2)
(5.6)
(--)
(57.0)

SBPT(b)
F

FB
F







FB
FB
FB
F
FR

B
	 Self-Contained 	
--

8.8
30.0
4.6
8.8
18.4
13.4











(--)

(2.1)
(7.2)
(1.1)
(2.1)
(4.4)
(3.2)











—

11.2
23.0
9.6
11.2
9.2
8.7











as corrugating data were not
(--)

(22.4)
(46.0)
(19.2)
(22.4)
(18.4)
(17.4)











provided by
--

8.5
11.0
4.5
8.5
10.2
8.3











mill
(--)

(17.0)
(21.9)
(9.0)
(17.0)
(20.3)
(16.6)











personnr 1 .




















(g) Mill se' 1 f -rout a i ned through spray irrigation of mill pfHiM-nt.

-------
Attempts  were  made to determine if product mix has any affect on raw
waste load characteristics.  Two types of multiple regression analyses
with one dependent variable were performed on the raw waste load  data
presented  in  Table  V-16.   No  significant correlation was found to
exist between raw waste levels and product type.

At 19 mills,  no discharge of wastewater is practiced/ these tend to be
smaller mills, less than 190 kkg/day (210 tons/day),  with  slow-speed
machines.   All  product  types  are  being produced at self-contained
mills.  Table V-17 presents a summary of the method used  in  handling
wastewater at each of the self-contained (zero discharge) mills.

Wastepaper-Molded  Products.   Table  V-18  presents available data on
wastewater discharge and BOD5_ and TSS raw waste loadings for 15  mills
representative  of  this  subcategory.   Various  molded  products are
produced at these mills  including  food  packs  (e.g.,  meat  display
trays,  egg cartons, and other containers of special design) and items
such as molded sewer pipe and flower pots.  These mills range in  size
from  2.5  kkg/day (2.8 tons/day) up to 169 kkg/day  (186 tons/day) and
have an average size of 44.2 kkg/day  (48.7  tons/day).   While  these
operations  utilize  primarily  a wastepaper furnish, some grades also
incorporate filler and sizing materials.  Molding  operations  do  not
utilize  Fourdrinier  or  cylinder  papermachines,  but employ forming
machines on which several vacuum pick-up  forming  dies  are  located.
The individual products are formed in one operation, pressed, and then
dried.

Builders'  Paper and Roofing Felt.  Table V-19 presents available data
on wastewater discharge and BOD5_ and TSS  raw  waste  loadings  at  57
mills  representative  of this subcategory.  At these mills, a variety
of construction  papers  are  produced,  including  roofing  felt  and
shingles  for  the  building  trade.   Both  saturated and unsaturated
papers are produced at mills  in  this  subcategory.   Generally,  the
asphalt saturation process utilizes a closed-cycle application system;
saturating operations are also done at off-site converting plants.

A  mixed wastepaper furnish is predominantly used.  Generally, this is
very low grade material, consisting of some corrugating  /and  a  great
deal  of  mixed  waste.   At 23 of these mills, some coarse defibrator
groundwood-type (TMP or other groundwood) pulps are produced  on-site.
This  pulp  is characterized by a yield of over 90 percent and  is very
coarse because there is little, if any, screening  subsequent   to  the
pulping step.  Even at mills where groundwood pulps  are produced, well
over half of the total furnish is wastepaper.

No  significant  difference  in the raw waste load characteristics are
apparent between groups  of  mills  where  saturated  and  unsaturated
papers  are produced.  The average BOD5_ raw waste loading  is higher at
mills where TMP pulp is produced than at mills where essentially  only
wastepaper  is  utilized in the furnish.  Where other groundwood pulps
are produced on-site, lower average raw wastewater characteristics are
exhibited than at mills where TMP/wastepaper or  only  wastepaper  are
used.  These differences may not be as significant as  indicated by the
                                168

-------
 Mill
Number
                                     TABLE V-17

                  METHODS OF WASTEWATER DISPOSAL AT SELF-CONTAINED
                          PAPERBOARD FROM WASTEPAPER MILLS
                         Method of Handling Wastewater
 Sludge
Disposal
085002    Settling basins and sand filters with total recycle.             Unknown

110007    Rotating screen, 2 clarifiers, partial reuse of clarified        Landfill
          wastewater, remainder to evaporation pond.

110015    Savealls and screening of wastewater with total recycle.         Unknown

110016    Savealls with total recycle.                                     Unknown

110018    Settling basin with total recycle.                               Unknown

110026    Savealls with total recycle.                                     Unknown

110033    Savealls with total recycle.                                     Unknown

110037    Screening, clarifier, and settling basin with total recycle.     Reused

110044    Savcall v.vtli partial recycle LO process, primary ciaritier       Reused
          treats remaining wastewater with more recycle, remaining
          wastewater (about 2%) treated by ASB with settling basin
          and evaporation.

110064    Saveall with total recycle.                                      Unknown

110073    Screen with total recycle.   Emergency holding pond and           Landfill
          recycle also available.

110081    Saveall with total recycle.  Emergency overflow to city          Unknown
          sewer.

110086    Screens, clarifier, settling basins, and clarifier with          Landfill
          total recycle.

110107    Clarifier with total recycle.                                    Landfill

110116    Unknown.                                                         Unknown

110135    Clarifier with total recycle.                                    Unknown

110141    Clarifier with partial recycle, remainder flows to spray         Reused
          irrigation system.

110142    Saveall with total recycle.  Can discharge to POTW when          Unknown
          required.

110146    Saveall with total recycle.                                      Unknown
                                         169

-------
                                                       TABLE V-18
                                               SUMMARY RAW WASTE  LOAD DATA
                                         WASTEPAPER-MOLDED PRODUCTS SUBCATEGORY
Production Profile

Mi 11 No.
!">0002(a)(c)
i. 5 00(14 (c)
150005 (a)
l')0<)06(c)

15000?
1 50(109 (a)

1500 10 (a)
15001 1

_ 150021
N
O 150022

150023

150024
150025
J 50028
150030
Average (w/o

Kurni sh
WP
WP
WP
liWD, Pulp
Substitute
WP
News, GWD
Substitute
News
News, Blank,
Purch GWD, K
News, GWD,
Teat Moss
Box Cuttings
C,WD Substitute
(»WD, BLK
9% WP
K, CM), 55% WP
News
K, GWD Substitute
News
self-contained mill)

- (t/!L .
20.0
2.8
5.5
43.7

(b)
(b)

60.0
(b)

16.6

61.8

186.0

93.4
26.5
Hfi
. u
3.0

Product
..._.!H* 	
Pipe, Conduit
Egg Cartons
Containers
Molded Products

Molded Products
Molded Products

Molded Products
Egg Cartons, Trays

Molded Products,
Peat Moss
Molded Products

(folded Products

Molded Products
Molded Products
Flower Pots
Molded Products

Average of Recycle Mills (w/o self-contained mill)
Average of Non-Hecycle Mills (w/o
self-contained mill)
Raw Waste Load
Flow
M/.
20
74
25
46

89
18

31
71

173

54

86

85
1 10
_^
68
23
88
kKa..
.4
.7
.0
,3

.7
.8

.3
.4

.2

.7

.8

.1
.2
-._
.4
.8
. 1
	 L5fi?
(4.
(17.
(6.
(11.

(21.
(4.

(7.
(17.

(41.

(13.

(20.

(20.
(26.
(_„
.L/JLL
9)
9)
0)
1)

5)
S)

5)
1)

5)

1)

8)

4)
4)
_)
(16.4)
(5.
(21.
7)
1)
.?Sik
4.6
--
2.4
10.4

15.9
--

9.4
10.5

5.2

7.6

8.6

5.1
0.2

7.3
5.5
7.9
BODS
kg .OJ>/.i)__
(9.2)
( — )
(4.7)
(20.7)

(31.7)
(--)

(18.8)
(20.9)

(10.4)

(15.2)

(17.2)

(10.2)
(0.4)

(14.5)
(10.9)
(15.8)
TSS
-.Jj/Ms
20. 1
--
8.4
18.9

23.7
0.5

15.0
23.4

11.2

16. »

10.9

12.8
0.9
" .
n.s
11.0
14.8
J]b£t>
(40.1)
(--)
(16.7)
(37.7)

(47.3)
(1.0)

(30.0)
(46.7)

(22.3)

(33.6)

(21.7)

(25.6)
(1.8)
( ."_ )
(27.0)
(22.0)
(29.6)
HI'T Raw Waste Load
                                                                 88. 1
7.9    (15.8)
14.8   (2<>.6)
(a)  Mill recycles significant amount o£ process waslewater.
(h)  Production data held confidential.
(c)  Mijl is closed.

-------
                                   TARi.r  v-iy

                           SUMMARY RAW  WASTE LOAD DATA
                  BUILDERS' TAPE:! AND ROOFING  FELT SUBCATKGORY
Production Profile
Product
Mill No. Furnish (t/d)
120001 WP,
120002 WP,

120003 WP,
120004 WP,
120005 WP,

120006 WP,
120007 WP,
120008 WP,

120009 WP,
120010 WP,
120011 WP,
120012 WP,
120013(f) WP,
120014 WP,
120015 WP,
120016 WP,
120017 WP,
120018 WP,
120019 WP,
120020 WP,
120021(c) WP,
120022(f) WP,
120023(f) WP,
120024 WP,
120025 WP,

120026 TUP
120027 WP,
120028 WP,
120029 WP,
120030 WP,

120031 TUP
120032(f) WP,
120033 WP,
120034 WP,
WF
WF, Rag

Chips
Rags, GWD
GWI)

GWD
GWD
WF

WF
WF
Chips
TMP
Chips
Baled Pulp
Chips
GWD
TMP
TMP
TMP
Chips, TMP
GWD
WF, Rag
Chips
TMP
WF. Rag

, Chips
GWD
TMP
TMP
WF, Rag

, Chips
TMP
TMP
WF, Rag
32
116

(d)
69
170

123
90
(d)

40
29
345
228
97
21
92
30
73
88
156
82
172
53
75
126
44

71
20 ,
193
39
28

167
77
60
30
Type
Construction Paper
Construction Paper
Roofing Felt
Construction Paper
Construction Paper
Asbestos Felt
Organic Felt
Construction Paper
Construction Paper
Construction Paper
Roofing Felt
Construction Paper
Construction Paper
Construction Paper
Construction Paper
Construction Paper
Construction Paper
Construction Paper
Roofing Felt
Roofing Felt
Roofing Felt
Roofing Felt
Roofing Felt
Roofing Felt
Construction Paper
Roofing Felt
Roofing Felt
Roofing Felt
Construction Paper
Construction Paper
Construction Paper
Roofing Felt
Roofing Felt
Roofing Felt
Construction Paper
Construction Paper
Construction Paper
Construction Paper
Construction Paper
	
»!?.(••)_..
s
u

s
u

s
s
s
s
s
s
u
u
u
u


u
1)
u
u
u
u
u
u
s
s
u

s
s
u
0
u
Subgroup
....._(.y.. _
w
w
T
G
G

G
W
W
W
T
T
T
W
T
T


T
T
T
W
T
T
W
G
T

w
T
T
T
W
	
kl7k
65.
3.
8.
4.
1.

	
26.
..
28.
7.
2.
13.
--
5.
7.


4.
	
48.
12.
19.
2.
9.
40.

5.
16.
43.
0.
	
__.

1
3
3
2
3

-_
3

8
5
9
8

0
1


2
--
4
5
2
1
6
9

8
7
4
8
--
Flow
._(*.
(15
(0
(2
(1
(0

	
(6

(6
(1
(0
(3

(1
(1


(1
	
(11
(3
(4
(0
(2
(9

(1
(4
(10
(0
	

E*?/.
.6)
.8)
.0)
.0)
.3)

	
.3)
_.
.9)
.8)
.7)
-3)
--
.2)
.7)


.0)
	
.6)
.0)
.6)
.5)
.3)
Raw Waste Load
BOD5
!_)__._ !?iB/kkg. .Oh/0..
(--)
(--)
(--)
5.5 (10.9)
4.2 (8.:))
•
	 Sel f -Con t. lined 	
(--)
(--)
2.1 (4.2)
12.8 (25. r>)
8.9 (17. R)
33.4 (66. R)
(-- )
11.2 (22.3)
(--)

C*» 1 ( f*t*nl •» i ntjl

	 Self -Contained 	
281.2 (562.4)
5.1 (10.1)
(--1
3.4 (6.R)
24.0 (48.0)
	 Self -Contained 	
.8) 22.1 (44.2)

.4)
.0)
.4)
.2)
	

2.2 (4.3)
6.2 (12.4)
25.7 (51.4)
(--)
	 Self-Contaitiril 	
.....

-
-
-
1.
2.


-
-
2.
5.
2.
10.
--
4.
--


7.
	
33.
8.
--
2.
71.
17.

6.
6.
40.
--
	
T
kk8
-
-
-
5
2

	
-
.
3
1
9
1

1



4
	
4
0

4
6
7

9
0
9

	
SS
. <»>.
(-
f-
(-
(2.
(4.

	
'-
(_
<4.
(Id.
(5.
(20.
( --
(R.
( --


(I'-.
	
(66.
( r>.
(--
(4.
(141.
(IS.

( 1 ).
(12.
(81.
( --


/'.).
-,
- 1
-)
9)
3)

-.
-'
.)
6)
1)
8)
2)
)
2}
)


7)
--
R)
9)
)
7)
2)
4)

R)
0)
R)
)
--

'RIT(_f)

F
F
m
Fn


K

Fl)
r'B
HI
F

KB
F


F'


FB
K
HI
F
K

HI
FR
F
F


-------
TABLK V-19 (Continued)


Mill No
Production Profile
Product
Raw Waste
Subgroup Flow
. Furnish (t/d) Type Finish(a) (b) kl/kkg
120035(f) WP, WF, Rag 71 Construction Paper S
Construction Felt
120036 WP, WF, Rag 54 Construction Paper S
Construction Felt
120037 WP, WF, Rag 49 Construction Paper U
Construction Felt
120038 WP, WF, Rag 51 Construction Paper S
Construction Felt
120041 (d) (d) Construction Paper S
120042 WP, WF, Rag 55 Construction Paper S
120043 WP, WF, Rag 43 Construction Paper 3
120044 WP, WF, Rag 21 Construction Paper S
120045 WP, WF, Rag 36 Construction Paper S
120046 WP, WF, Rag 72 Construction Paper S
120047 WP, WF, Rag 63 Construction Paper U
120049
120050

120052
120054
120056
120057
120058
120059
Average
Average
Average
Average
BPT Raw
Average
Average
(a) -S
(b) W
T
C
0
WP, WF 22 Construction Paper S
WP, WF, Rag 55 Construction Paper U
Pulp
WP, WF 39 Construction Paper U
WP, WF 60 Builders Board U
WP, WF 242 Builders Board S
TMP, WP 125 Construction Paper
TMP, WP, Rag 118 Construction Paper U
(w/o self-contained mills)
Subgroup W (w/o self-contained mills)
Subgroup T (w/o self-contained mills)
Subgroup G (w/o self-contained mills)
Waste Load
of Mills with ?BPT flow (w/o self-contained mills)
of Mills with SBPT BODS (w/o self-contained mills)
= Saturated; U = Unsaturated.
= Predominantly wastepaper furnish.
= Furnish includes TMP.
= Furnish includes other types of groundwood.
= Other furnish.
(c) Mill recycles significant amount of process wastewater. Not
W
W
W
W 5.4

tdj
W
W 4.6
W
W 0.4
W
W 4.6
W
W 10.0

W
0 7.9


T 13.8



8.3
14.6
13.4
2.9
60.0
11.3
9.2





included in averages.
Load
BODS
(kgal/t) kg/kkg (Ib/t)
(1

(1
(0
(1
.3)

-1)
.1)
.1)



TSS
kg/kkg (Ib/t) SBPT(e)

-Self-Contain



—
;

!
--) F

--) F
— ) F
— ) F

(2
-4)
5.0 (9.9)
7.6
(15
.2) FB

(
(1


(3



(2
(3
(3
(0
(14
(2
(2






— )
.9)


.3)



.0)
.5)
.2)
-7)
.4)
.7)
.2)







—
(
	 )
3.9 (7.7)
-Self-
14
Contain
.1
(28
-Self-Contain

5
7
15
4
17
11
6







.6
.7
.3
.8
.5
.2
.5







(11
(15
(30
(9
(35
(22
(13








-2)



.1)
-3)
.6)
.6)
.0)
.3)
.0)






—
6.5


15.3



6.3
19.3
11.2
1.8
35.0
12.1
5.4






(
(13


(30



(12
(38
(22
(3
(70
(24
(10






— )
.0) FB


.5) FB



.5)
.5)
.3)
.6)
.0)
-2)
.8)






(d) Production data held confidential.
(e) F
(f) Mi
- mill with SBPT flow; B - mill with < BPT BOD5.
11 is closed.





















-------
averages  shown  in  Table  V-19.   While there are many mills in this
subcategory, raw waste load data are available for a lower  percentage
of  mills  compared  to  other  subcategories.   Mills  in each of the
furnish groupings exhibit raw waste loadings significantly lower  than
those which formed the basis of BPT effluent limitations.

Final  product  quality  requirements  are  less stringent compared to
other paper or board products.  Therefore, the opportunity exists  for
recycling  wastewater  and reusing sludge in the process.   At 17 mills
in the subcategory, no wastewater is discharged.  At a total of  eight
of  these  mills, a furnish is used that is predominately TMP pulp, at
three a furnish is used that is predominately groundwood pulp, at four
a furnish is used that is  predominately  wastepaper,  and  at  two  a
combination  of  wood  flour,  wastepaper, and purchased pulp is used.
Table  V-20  presents  information  on  the  method  of  handling   of
wastewater at self-contained mills.
Miscellaneous
Fibers
Mills.
 waste
	  Secondary
discharge and BOD5^  and  TSS  raw
secondary  fibers  mills  are  presented
these mills, processes are employed that
subcategories   or   unique   processes
characterized by the current subcategorization
 Available data on wastewater
 loadings  at  all  remaining
in Table V-21.   Generally, at
are typical of  two  or  more
are  employed  that  are  not
      scheme.
Noninteqrated-Fine  Papers.   Data   are   available   on   36   mills
representative  of  the  nonintegrated-fine papers subcategory.  Table
V-22 presents available data on wastewater discharge and BOD5^ and  TSS
raw waste loadings.  Products include high-quality coated and uncoated
printing,  writing,  and  other  business papers, and specialty items.
The mills vary in size from 12 kkg/day (13 tons/day)  to  987  kkg/day
(1,088  tons/day).   The  number of machines in use varies widely from
mill to mill; operating units are generally small.

Attempts were made to relate factors such as  coated  versus  uncoated
production  and  the  production  of  cotton or specialty items to raw
waste load parameters.  As shown in Table V-22, the mills  where  fine
papers  are  produced  from  cotton  fibers  tend to have considerably
higher raw waste load characteristics  in  terms  of  flow  and  BOD5_.
Wastewater  discharge  and  BODS^  raw  waste  loadings  do  not appear
significantly different  at  mills  where  coated  paper  is  produced
compared  to  mills  where  uncoated paper is produced.  Another major
factor influencing raw  waste  characteristics  is  the  frequency  of
"waste  significant" grade changes at mills in this subcategory.  Data
are presented for overall subcategory averages  comparing  mills  with
different  frequencies  of  waste  significant grade changes: no grade
changes, less than one per day, and more than one per day.  A distinct
correlation is seen, with wastewater  discharge  and  BOD5.  raw  waste
loading generally increasing with the frequency of grade changes.

Noninteqrated-Tissue   Papers.    Available  data  on  raw  wastewater
characteristics for 26 mills representative of  this  subcategory  are
shown  in  Table  V-23.  Both industrial and sanitary grades of tissue
papers are made, primarily from purchased pulps.  Some wastepaper  and
                                173

-------
                                  TABLE V-20

                       METHODS  OF WASTEWATER DISPOSAL AT
                      SELF-CONTAINED BUILDERS'  PAPER AND
                             ROOFING FELT MILLS
Mill
Number
120006
120007
120017
120018
120020
120026
120027
120029
120034
120040(a)
120041
120048
120051
120055
120056
120058
120059
Method of Handling Wastewater
White water recycle, remainder to evaporation ponds.
Screening, lagoon, clarifier, and irrigation with some
recycle.
Total recycle.
Clarifier and recycle with overflow to city sewer in
cases of emergency.
Total recycle at time of 308 survey; now a
direct discharge.
Clarifier and recycle.
Primary and biological treatment and recycle.
Primary and biological treatment and recycle.
Total recycle.
Saveall, screening, settling pond, and recycle.
Saveall, screening, and recycle.
Saveall, screening, holding tank for process
spill recycle, and evaporation pond.
Neutralization, settling basin, and recycle.
Filtration and recycle.
Screening, clarifier, storage tank, and recycle.
Saveall, clarifier, saveall, and recycle.
Saveall and recycle.
Sludge
Disposal
Unknown
Lagoon
Unknown
Landfill
Unknown
Landfill
Unknown
Unknown
Unknown
Landfill
Landfill
Lagoon
Landfill
Unknown
Unknown
Unknown
Unknown
(a)   Mill  is closed.
                                     174

-------
                                                          TABLE V-21

                                                  SUMMARY RAW WASTE LOAD DATA
                                             SECONDARY  FIBERS MISCELLANEOUS MILLS
                              Production  Profile
Raw Waste Load
N
tn
Mill
No.
080002
110042(a)
Il0080(b)
110122
110109
110132

110136

120039

140004
140006
140009
140012
140016
140020
140023
140026
140027
150008
Flow
(t/d)
20
240
536
(c)
533
275

61

350

72
161
138
304
(c)
278
98
319
201
44
Product
Groundwood Specialties
Gypsum Board, Roofing Felt
San Tissue, Linerboard, Corrugating
Electrical Insulation and Fiberboard
Foldingboard, Wetlap Pulp
San Tissue, Linerboard, Corrugating
Chip & Filler Board, Tube Stock
GWD Specialty, Pressboard, Other
Board
Gypsum Wall Board, Construction
Pjper
Sanitary Tissue
Fine, Specialties
Sanitary Tissue
Uncoated Fine Paper
Market Deink
Uncoated Fine Paper
Unctd Fine & GWD, GWD Specialties
Coated, Uncoated Fine
Uncoated Fine
Cotton Fiber, Specialties
kl/kkg
_ ^
35.9
28.0
--
35.5
33.4


--
14.2

34.6
102.7
55.1
34.2
8.3
98.9
99.3
92.2
56 . 3
45.5
(kgal/t)
(")
(8.6)
(6.7)
( — )
(8.5)
(8.0)


(--)
(3.4)

(8.3)
(24.6)
(13.2)
(8.2)
(2.0)
(23.7)
(23.8)
(22.1)
(13.5)
(10.9)
BODS
kg/kkg
_ _
--
--
--
25.0
9.0


--
34.3

--
22.0
13.7
--
34.6
--
14.5
38.4
29.0
3.5
(lb/t
(")
(--)
(--)
(--)
(50.0)
(18.0)


(--)
(68.6)

(--)
(44.0)
(27.3)
(--)
(69.2)
(--)
(28.9)
(76.8)
(58.0)
(7.0)
                                                                                                               TSS
                                                                                                                   (lb/t)
                                                                                                        91 .2
                                                                                                        17.3
                   3.4
                  88.5
                  46.9
                  53.9
                  68.8
                  70.9
                  27.6
                  105.9
                  105 .0
                   7.6
                         (182.4)
                          (34.6)
                  15.7    (31.4)
                                                                                                                 (6.
                                                                                                               (176.
                                                                                                                (93.
                                                                                                               (107.
                                                                                                               (137.
                                                                                                               (141.
                                                                                                                (55,
                                                                                                               (211
7)
9)
8)
8)
6)
7)
1)
8)
                                                                                                               (210.0)
        (a)  Data  is  primary treatment  effluent.
        (b)  Data  is  representative  of  secondary  fibers  miscellaneous operation; since data collection, the mill has
            discontinued  tissue  production  and  is  now classified .is a paperboard from wastepapet mill.
        (c)  Production data held confidential.

-------
                                                           TABLE V-22

                                                   SUMMAI'Y RAW WASTE I-OAD DATA
                                              NONINTEGRA I ED-FINE PAPERS SUBCATFGORY
                        Production  Profile
 Mill
Number
          Percent
          Cotton
          Furnish
Wood Fihrr Furnish
                      (t/d)    Product
Gra1 grade  change/day

BPT Raw Waste Load

Average SBPT Flow -  no  grade changes
Average SRPT BOD5_  - no grade  changes
Average SBPT Flow -  <1  grade change/day
                                                                      Fow
   Raw Waistc Load

  	BOD5 	          TSS
kg/kkg (lb_/_t_on)	kg'/kkg  (Hi/ton)
7_9_.7

52.2
48.4
56.8
50. 1

63.0

38.0
21. 7
39.2
                                                                                                       18.1    (36.6)
(12.5)
(11.6)
(13.6)
(12.0)

(15.2)

 (9.1)
 (5.2)
 (9.4)
                                                                                     10.9    (21.8)
                                                                                      7.7    (J5.4)
                                                                                     11.4    (22.7)
                                                                                     12.9    (25.8)
                                                  35. /.
                                                  184
                                                  44 5
                                                  35.6
                         (70.7)
                         (36.R)
                         (89.0)
                         (71.1)
                                                                                      10.8
                                                                                      7. 7
                                                                                      9.6
                                                                                             (21.5)     .10. B    (61.6)
                                        (15.4)
                                        (15.4)
                                        (19.1)
                  17.0   (34.0)
                  17.0   (34.0)
                  29.7   (r>9.4)
*
•4
(.'
I |
1 '
1'
-

-
-
+
-f
+
-
0
I1
-
-
-
-
I.I
•f
t
I!
-
0
-
26.7
35 . 1
68.9
76.8
24.6
17.9
38.0
82.6
45.9
22.5
43.0
96.8
25.9
21 .7
44.7
86.0
110.6
33.0
61.3
11.7
50.5
48.4
73.9
53.0
54.2
71 .4
(6.4)
(8.4)
(16.5)
(18.4)
(5.9)
(4.3)
(9.1)
(19.8)
(II. 0)
(5.4)
(10.3)
(23.2)
(6.2)
(5.2)
(10.7)
(20.6)
(26.5)
(7.9)
(14.7)
(2.8)
(12.1)
(11.6)
(17.7)
(12.7)
(13.0)
(17.1)
9.0
--
6.9
5.9
SI r i

--
13.7
--
--
--
--
25.6
5.8
7. 7
10.5
16.9
14.9
10.8
13.8
3.3
11.1
--
--
3.8
--
--
(17.9)
(--)
(12.8)
(11.8)
~on t a i ned*
(--)
(27.3)
(--)
(--)
(--)
(--)
(51.2)
(11.5)
(15.4)
(20.9)
(33-8)
(29.8)
(21.6)
(27.6)
(6.5)
(22.1)
(--)
(--)
(7.6)
(--)
(--)
14.0
--
19.8
25.0
--
--
40. 7
44. 7
--
--
--
85.1'
10.?
17.0
43 . r)
115.2
47. R
41 .8
31 .5
4.'i
18.3
--
--
24.4
--
--
(27.9)
(--)
(39.6)
(50.0)
(--)
(--)
(81 .'))
(89.3)
(--)
(--)
(--)
(170.0)
(20.4)
(34.0)
(87.0)
(230.3)
(95.5)
(83.6)
(62.9)
(8.9)
(36.5)
(--)
(--)
(48. S)
(--
(--)
I-M
F

1!
,,
F
F

F
F
F

Hi
FH
FR


F
F
m
i
F

FH
1-


-------
                                                                             TABI K V-22 (Continued)
                                                Proilticlion  Profile
                                                                                                               Raw Waste  Load
Grailo
Change
Flow
BOD5
TSS
                                   Percent
                          Mill      Cotton                                               	       	         	
                         Number     Furnish	(t/d)    Product	      /Pnyla)__ _kl/kkg_ (kgal/ton)	kj/kjy5/(lb/ton)_ _kg/kkg  Ub/ton)  1  grade  change/day
                         Average  ?BPT B0115  -  >1  grade  change/day

                         Cotton  Fihrr Furnish
                                                                 39.6      (9.5)
                                                                 37.6      (9.0)
                                                                 51.7     (12.4)
 4.8    (9.6)
10.0   (20.0)
 7.1   (U.9)
17.)   (34.6)
16.1   (32.2)
19.5   (39.0)
N
N
080003
080004
080032
080042
08004.3
080044
080050
24.0
26.0
4.3
5.0
15.0
16.1
16.7
25
13
(c)
43
30
71
3.3
                                                      Cotton
                                                      Cotton
                                                      Unctd Rag
                                                      Unctd Cotton,Carbon
                                                      Unctd Print,Artist,Cotton
                                                      Unctd Print Cotton
                                                      Unctd Print Cotton
Average
Avcrge - > 1 grade change/Hay

BPT Raw Waste Load

Average of Mills SBPT Flow
and S nPT BOD5- >1 grade change/day
1
1

1


1




149
88
118
78
269
141
25
124
176
176
130
.4
.9
. 1
.9
.2
.9
.5
.4
.5
.5
.2
(35
(21
(28
(18
(64
(34
(6
(29
(42
(42
(31
.8)
.3)
• 3)
.9)
-5)
.0)
•11
.8)
.3)
.3)
.2)
6.0
17.9
12.1
19.5
40.7
15.9
13.7
18.0
22.9
22.9
14.0
(12
(35
(24
(39
(81
(31
(27
(35
(45
(45
(28
.0)
• 7)
-2)
.0)
•4)
.7)
.3)
•9)
-8)
.8)
.0)
7.0
65.0
29.4
44.8
86.5
49.7
15.2
42.5
55.2
55.2
39.6
(14
(130
(58
(89
(173
(99
Op
(85
(110
(110
(79
0)
0)
7)
6)
0)
4)
_!)
0)
4)
4)
.1)
KB
FB
KB
FB

FB
FB




                         (a)-=l;U= unknown.
                         (b)  F-MiJl  with  SBPT flow;  B-Mill  with «BPT BOD5.
                         (c)  Production data  held confidential.
                         (d)  Raw waste load BOD5 data after  primary treatment; B('Q5 data are not included  in averages.

-------
                                                                          TABLE  V-23
                                                                  SUMMARY  RAW WASTE LOAD DATA
                                                            NON1NTF.CRATED-T1SSUE  PAPERS SUBCATECOHY
OO
Production Profile
Furnish
Mill No. Purch CWI) DI WP
090001 23 -- -- 5
090005(e) (r) (c) (c) (c)
090007 (c) (c) (c) (c)
090008 (c) (c) (c) (c)
090009 (c) (c) (c) (c)
09001 l(e) 62 -- -- 12
090012 62
0900l:)(d) 34 1 -- 3
090016 (c) (c) (O (c)
090017 (c) (c) (c) (c)
0900I8(c) (c) (c) (c) (c)
090019 139 19 -- 48
090020 887 57 -- 5
090021 119 H -- 40
090022 154 7
090023 (c) (c) (c) (c)
090025 6
0'J0026 21 -- S 28
090027 140
090028(d)(e)(c) (c) (c) (c)
090029 41 -- -- 14
090030 (C-) (c) (c) (c)
090031 14 -- -- 4
090032 26 -- -- 4
090033 15 -- -- 1
Average
Average - ndustrial Tissue Only
Average - o grade changes
Averjge - 1 grade change/week
Average - 1 grade change/day
Average - 1 grade change/day
DPT KJW Waste Load
Ave ag.- of Hills ith SBPT flow -
Ave age of Mills ith SBPT BOD5 -
Ave age of Mills ilh SBPT flow -
Ave age of Mills ith SBPT BODS -
Av<- age of Mills ith SBPT flow -
Ave age of Mills ith SBPT BOU5 -
Ave .ige of Mills ith SBPT flow -
Av«- .igi- of Mills ith SBPT BODS -

(t/d)
20
(c)
(c)
(c)
(c)
70
59
37
U)
(c)
(c)
159
890
176
189
(c)
6
50
140
(c)
44
(c)
17
27
14







No grade
No gfade
<1 grade
<1 grade
<1 grade
<1 grade
>1 grade
>1 grade
Product
Type
Industrial Tissue
Sanitary Tissue
Sanitary Tissue
Sanitary Tissue
Sanitary Tissue
Sanitary Tissue
Sanitary Tissue
Sanitary Tissue
Sanitary Tissue
Sanitary Tissue
Sanitary Tissue
Sanitary Tissue
Sanitary Tissue
Mixed Product
Mixed Product
Mixed Product
Mixed Product
Sanitary Tis ue
Sanitary Tis ue
Sanitary Tis ue
Industrial T ssue
Sanitary Tis ue
Mixed Produc
Mixed Produc
Mixed Product







changes
changes
change/week
change/week
change/day
change/day
change/day
change/day
Grade
Chaoge/Dayd)
O
0
-
0
-
-
-1"
U
U
-/w
-
U
•fr
•fr
-
-/w
o

U
0
U
0
0
-/w
-
0















Flow
kl/kkg
104
23
78
96
89
78
35
63
56
56
80
103
79
170
66
30
286
74
17
143
94
32
98
177
29
85
99
57
55
122
125
96
39
41
40
--
78
78
79
—
.3
.0
.0
.8
.7
.9
.9
.8
.8
.3
.1
.5
.7
.7
.8
.9
.7
.7
.9
.6
.7
.5
.1
.8
.6
.5
.7
.2
.5
.7
.2
.0
.6
.3
.9

.9
.0
.7

(kgal/t)
(25.0)
(5.5)
(18.7)
(23.2)
(21-5)
(18.9)
(8.6)
(15.3)
(13.6)
(13.5)
(19.2)
(24.8)
(19.1)
(40.9)
(16.0)
(7.4)
(68.7)
(17.9)
(4.3)
(34.4)
(22.7)
(7.8)
(23.5)
(42.6)
(7.1)
(20.5)
(23.9)
(13.7)
(13.3)
(29.4)
(30.0)
(22.9)
(9.5)
(9.9)
(9.8)
( — )
(18.9)
(18.7)
(19.1)
(--)
Raw Wsste Load
BODS
kg/kkg
4.5
5.6
8.0
15.3
9.9
—
—
6.3
18.0
14.9
12.8
—
22.9
—
9.1
--
14.6
17.4
0.7
—
—
1.7
--
--
1.0
10.4
4.5
4.8
14.9
10.9
22.9
11.5
2.3
2.7
14.9
—
10.0
9.0
22.9
—
(lb/t)
(9.0)
(11.2)
(15.9)
(30.6)
(19.7)
( — )
( — )
(12.6)
(36.0)
(29.7)
(25.6)
( — )
(45.7)
( — )
(18.2)
(--)
(29.1)
(34.8)
(1.3)
( — )
(--)
(3.3)
( — )
( — )
(2.0)
(20.8)
(9.0)
(9.6)
(29.7)
(21.7)
(45.7)
(22.9)
(4.5)
(5.4)
(29.7)
(--)
(19.9)
(17.9)
(45.7)
(--)
TSS
kg/kkg
5.0
11.5
28. 5
47.1
25.7
—
—
40.0
53.2
48.3
43.9
—
54.5
31.2
26.9
15.8
14.6
53.8
4.1
--
—
6.6
—
—
5.8
28.0
5.0
13.4
32.0
27.9
42.8
34.7
7.0
6.6
32.0
—
31.3
27.0
54.5
~~
db/t)
(10.0)
(22.9)
(57.0)
(94.2)
(51.4)
( — )
( — )
(80.0)
(106.4)
(96.5)
(87.8)
( — )
(108.9)
(62.3)
(53.7)
(31.5)
(29.1)
(107.6)
(8.2)
( — )
( — )
(13.1)
( — )
( — )
(11.5)
(56.0)
(10.0)
(26.7)
(64.0)
(55.8)
(85.6)
(69.4)
(13.9)
(13.1)
(64.0)
( — )
(62.5)
(54.0)
(108.9)
(--)
SBPT(b)
B
FB
FB

FB
F
F
F
F
F
F

F

FB
F

F
FB

r
FB


FB















(a) - = <1; -/w = 
-------
purchased   deink   and   groundwood   pulps  are  also  used  in  the
manufacturing operations.

As with the nonintegrated-fine papers subcategory,  the  major  factor
influencing  raw  waste loadings is the frequency of waste significant
grade changes.  In general, wastewater discharge and  BOD5_  raw  waste
loadings  increase  with the frequency of grade changes.  Insufficient
data are available on the production of industrial  tissue  grades  to
determine  if there are significant differences in raw waste loads due
to differences in the type of products manufactured.

Noninteqrated-Liqhtweiqht Papers.  Available data  on  raw  wastewater
characteristics   for   17  mills  that  are  representative  of  this
subcategory are presented in Table V-24.  Lightweight,  thin,  tissue,
and  electrical papers are produced at mills in this subcategory.  EPA
attempted to group mills based on product type as illustrated in Table
V-24.  Differences between these groups are minor with one  exception.
At those mills where electrical papers are produced, larger quantities
of water are discharged than at mills where non-electrical lightweight
grades are produced.

As  with the nonintegrated-fine papers and nonintegrated-tissue papers
subcategories, the major factor influencing raw waste loadings is  the
frequency  of  waste  significant grade changes.  Wastewater discharge
and BOD5_ raw waste loadings generally increase with the  frequency  of
grade changes.

Nonintegrated-Filter  and  Nonwoven  Papers.   Available  data  on raw
wastewater  characteristics  for  14  mills  representative  of   this
subcategory  are  presented  in  Table V-25.  Average production is 15
kkg/day (16 tons/day).  At these mills, a wide variety of  filter  and
nonwoven  papers  are produced such as open-blotting type papers, hand
sheet testing blotters, oil and air  filter  papers  (often  saturated
with  resins),  vacuum cleaner bags, and a growing variety of nonwoven
type papers for personal, sanitary, and disposal uses.

As with the other subcategories in the nonintegrated  segment  of  the
pulp, paper, and paperboard industry, the major factor influencing raw
waste  loadings  is  the frequency of waste significant grade changes.
In general, wastewater discharge and BOD5_ raw waste loadings  increase
with the frequency of grade changes.

Nonintegrated-Paperboard.     Available   data   on   raw   wastewater
characteristics  for  11  mills  that  are  representative   of   this
subcategory  are presented in Table V-26.  Major products manufactured
at  mills  in   the   nonintegrated-paperboard   subcategory   include
electrical  board,  matrix  board  (used for typesetting), food board,
press board, and other board products.  As shown in Table V-26, larger
quantities of wastewater are  discharged  at  mills  where  electrical
grades  or matrix board are produced.  However, there is an inadequate
data base on which to characterize mills  where  electrical  board  .or
matrix board are made.
                                179

-------
Profile Profile
                 TABLE V-24

         SUMMARY SAW WASH LOAD DATA
SOKINTEG8ATED-LIGHTWEIGHT PAPERS SOTCATEG08Y

                                Raw Waste Load
Furnish (t/d) Product Grade
Flow
Mill No. Purch W Misc Broke (t/d) Change/Day (a) kl/kkg
Electrical Paper
105003(f) 11.2 — -- — 11.2
105015 (b) (b) (b) (b) (b) 0
105017 (b) (b) (b) (b) (b) 0
105018(c) (b) (b) (b) (b) (b) 0
105071 26.0 -- — — 26.3 U
Average
Miscellaneous Tissue and Carbonized
090015 47.4 25.6 -- -- 64.2 *
105057 33.0 5.1 — — 34.0 0
105058 34.0 4.9 — — 35.0
Average
Printing & Thin Paper
080039(f) (b) (b) (b) (b) (b) «•
105014 (b) (b) (b) (b) (b)
105020 203.0 4.0 2.0 -- 203.0
Average
Carbonized, Thin, Cigarette - Less Waitepaper
080024 20.6 — -- S. 3 32.5 0
080021(d) 30.3 — -- — 26,9 0
080022 102.4 11.3 — — 110.5
090003 12.0 1-6 -- 4,4{e)18.0
105013 15.1 -- 5.3 -- 20.4
105016 (b) (b) (b) (b) (b)
Average
Average of All Mills
Average of Electrical
Average w/o Electrical
Average of Kills - no grade change and flow
5 the Average w/o Electrical
Average of mills - no grade change and B005
£ the Average w/o Electrical
Average of mills - <1 grade change/day and flow
£ the Average w/o Electrical
Average of mills - <1 grade change per day and
BODS S to the Average w/o Electrical
Average of Electrical mills - flow S the
Average of Electrical
(a! -=!; V ~ unknown.
(b) Production data held confidential.
(c) Represents a combination of process sewer and a very
must use high flow on thermal sewer to meet thermal
(tlj After primary clarification; not included in average
(ej Estimated to balance.
(f) lill is now closed.

446.9
313.0
269.2
755.3
254.1
320.9
224,9
147.3
208.7
193.6
236.6
170.7
202.4
203.2
60. 3
10.8
128.9
135.2
517.5
210.7
237.0
320.9
203.2
103.9
147.3
159.4
181.9
278.3
high flow
Discharge 1
BODS
(kg«l/t) kg/kkg (Ib/t)

(107.1)
(75.0)
(64.5)
(181.0)
(60.9)
(76.9)
(53.9)
(35.3)
(50 .0)
(46.4)
(56.7)
(40.9)
(48^7)
(1-.3)
(2.6)
(30.9)
(32.4)
(124.0)
(50.5)
(56.8)
(76.9)
(48.7)
(24.9)
(35.3)
(38.2)
(43.6)
(66.8)

11.4
11.4
57.7
2.9
11.8
24.1
29.4
8.3
18.9
0.2
19.9
19.9
20.2
11.4
21.7
2.9
2.9
14.1
13.3
11.4
from a thermal sewer
iraits. Not included

(22.8)
(22.8)
(115,3)
(5.7)
(23.6)
(48.2)
(58.8)
(16,5)
(37.7)
(0,3)
(39.7)
/ \
,„ \"""f
(39.7)
(40. 3)
(22.8)
(43.3)
(5.7)
(5.7)
(28.1)
(26.6)
(22.8)
TSS
kg/kkg

19.1
19.1
149.9
5.2
25.7
60.3
127.1
15.6
71.4
0.1
57.0
57.0
57.1
19.1
63.4
5.2.
5.2
36.3
32.8
19.1
(Ib/t)

(38.1)
(38.1)
(299.8)
(10.3)
(51.4)
(120.5)
(254,2)
(31.1)
(142.7)
(0.2)
(114.0)
(114,0)
(114. 1)
(38.1)
(126.8)
(10.3)
(10.3)
(72.6)
(65.5)
(38.1)
Apparently, mill
in averages.
                                  1 80

-------
                                                     TABLE V-25
                                             SUMMAKV
                                                        ' kASTL LOAD DATA
                                                         NOKWOVF.N PAPERS SUBCATKGORY
Production Profile
Product
Mill No
1050C5
Grade
Raw Waste
Flow
(t/d) Type Change/Davfa) U/kkg (kg;
5.9
Saturated Filter &
328
.8
(78.
il/t;
.8)
Load

BODS
Kg/kkf

_
Ub/t)
(
--)



TSS
kg/kkg
24.3
ilb.'i;
(48
.6)
Nonvoven
105029
105030
105031
105033
4.1
(b)
0.7
(b)
Technics
Filter
Filter
Filter,
il £, Filter


Wall Cover
V
0
C
*
144
189
394
224
.0
.9
.3
.1
(34.
(45.
(94.
(53.
.5)
.5)
.5)
7)
18.
-
-
-
2
-
-
-
(36
(
(
(
.4)
— )
--)
--)
14.7
--
—
—
(29
I
(
(
.3)
--)
--)
--)
Miscellaneous
105034
105043
105044
105045
105051
105052
105053
105054
105055
Average
Average
Average
Average
(b)
(b)
(b)
(b)
(b)
(b)
(b)
(b)
(b)
Filter
Filter,
Filter.
Filter,
Filter,
Filter
Filter
Filter,
Filter,

Blotting, Photo
Blotting, Pkg
Pkg
Sat Tech


Photo, Wrap
Saturated
•f
4
C
f
-
0
0
u
»
of All Mills
of mills
of mills
of mills
- no grade
- <1 grade
- >1 grade
change
change/day
change/day



172
280
25
40
171
17
42
6
288
166
134
250
241
.3
.4
.9
. 1
.1
.9
. 6
*
.4
.1
.0
.0
.2
(4!
(67
(6
(9
(41
(4
(10
(1
(69.
(39.
(32
(59,
(57.
.3)
.2)
.2)
.6)
.0)
.3)
.2)
.6)
Jl
.8)
. D
.9)
.8)
-
25.
3.
-
5.
-
-
-
9.
12.
3.
5.
17.
-
0
8
-
0
-
-
-
0
2,
8
0
0
(
(49
(7
(
(9
(
(
(
(I?
(24
(7
(9
(33
--)
.9)
.5)
--)
.9'
— )
--;
--)
.9)
.3)
.5)
.9)
.9)
--
54. S
12 .R
—
19. i
—
—
--
36.3
27.4
12.8
21.9
46.5
(
(109
(25
(
OR
i
(
(
(76
(54
(25
(43
(93
--)
.5)
.5 i
— ;
.8';
-- i
--;
--)
.5)
.7)
.5)
.7)
.0)
Average of Mills - no grade change and flow
  & the Average of Mills with <1 grade change/day       69.3

Average of Mills - no grade changes and BOD5
  i the Average of All Mills               ~            25.9

Average of Mills - <1 grade change/day and
  BOD5 £ the Average of All Mills and flow
  S the Average of All Mills with <1 grade
  change/day                                           171.1

Average of Mills->l grade change/day and
  flow £ the Average of Mills with <1 grade change/day 198.2
Average of Milla >1 one grade change/day and
  BOD5 £ the Average of All Mills
(a)  -=<1;+=>1;U* Unknown.
(b)  Production data held confidential.
288.4
          116.6)


           (6.2)




          (41.0)


          (47.5)


          (69.1)
                      3.8
3.8
5.0
                      9.0
 (7.5)


 (7.5)




 (9.9)





(17.9)
12.8   (25.5)


12.8   (25.5)



19.4   (38.8)


         (--;


38.3   (76.5)
                                                       181

-------
                                                                     TABLE V-26
                                                             SUMMARY RAW WASTE LOAD DATA
                                                        NONINTEGRATED-PAPERBOARD SI1BCATEGORY
CO
rv>
Production Profile
Furnish(t/d)
Mill No.
085001
085007
085008
085010
105001
105002
105048
105049
105070
105071

1)0021
Purch
60.0
(h)
32.0
(h)
33 5
9.2
46.0
44.0
(b)
17.1

47.4
WP
12
(h)
22
(b)
--
(h )

--
(b)
--

36.6
(t/d)
84.0
(b)
50.0
(b)
38.2
8.4
fh)
62.0
51.0
(h)
15.0

76.0
Product
Grade

Type Change/nay (.1) kl/kkg
Packaging, Bag
Matrix Board
Pkg, Bag, Specialty
Matrix Board
F.iod Board, Gift
Hi Dens Electrical
Impregnated Fiber
Impregnated Fiber
Electrical Board
Saturated Paper for
Vul canizing
Press Board
+
U
I)
11
o
U
-
-
U
II

U
29.6
184.9
62.6
168.2
30.0
273.3
48 8
38.8
53.0
221.6
105.6

63.0
Flow
(kgal/t)
(7.1)
(44.3)
(15.0)
(40.3)
(7.2)
(65.5)
(9. .3)
(12.7)
(53.1)
(25.3)

(15.1)
Raw Waste Load
BODS
kg/kkg

--
10.0
7.0
8.2
--
--
--
87.5
11.0

--
(It'/t)
(-)
(--)
(20.0)
(1.3.9)
(16.4)


(--)
(175.0)
(26.0)

(-- )
TSS
kg/kkg

--
25.0
46.4
43.2
--
--
--
136.5
42.4

--
( Ib/t )
(--)
(--)
(50.0)
(92.7)
(86.4)


( --)
(272.9)
(84.7)

(-- )
Average
Average w/o Klectrical
Average w/o Electrical or Matrix

Average of Mill* - no grade change and flow
  $ the Average w/o Electrical or Matrix

Average of Mills - no grade change and BODS
  ^ the Average w/o Electrical or Matrix

Average of Mills - < 1 grade change/day and flow
  £ the Average w/o Electrical or Matrix

Average of Mills - <1 grade change/day and BOD5
   ^ the Average w/o Electrical or Matrix

Average of Mills - >1 grade change/day and flow
  < Aver.ige w/o Electrical or Matrix

Average of Mills - >I grade change/day and BOD5
   $ the Average w/o Electrical or Matrix
106
78
5.3
30
30
46
.8
.5
.8
.0
.0
.7
(25
(18
(12
(7
(7
(11
.6)
.9)
.2)
.2)
.2)
25.
9.
10.
8.
8.
2
6
4
2
2
(50.
(19.
(20
(16
06.
.3)
1)
.8)
4)
.0
58.
39.
36
41.
41.
7
3
9
2
'
(--)
(117.
(78.
(73.
(«,
(8ft.
(-
3)
5)
7)
4)
4)
.,
                                                                                      29.6
                                                                                                (7.1)
                (a)  - = <]; » = >1; U = Unknown.
                (b)  Production data held confidential.

-------
EPA  attempted to evaluate data on wastewater discharge and BOD5_ waste
loadings as a function  of  the  number  of  waste  significant  grade
changes per day.   The data base is very limited and no correlation was
apparent   between   frequency   of   grade   change   and  raw  waste
characteristics.

Miscellaneous Nonintegrated Mills.  Table V-27 presents available data
on wastewater discharge and BOD5_ and TSS raw waste  loadings  for  all
remaining    nonintegrated    mills.    At   these   mills,   products
representative of two or more subcategories  or  unique  products  not
defined by the current subcategorization scheme are manufactured.

TOXIC AND NONCONVENTIONAL POLLUTANTS

Screening Program

As part of the overall project investigations, a screening program was
undertaken  to  provide information on the presence or absence and the
relative levels of toxic and nonconventional pollutants discharged  at
mills  in  the  pulp, paper, and paperboard industry.  As explained in
Section II, screening was a three-phase effort.  The first  phase  was
the  initial  screening conducted by the contractor covering 11 of the
15 mill groupings established as representative of  the  pulp,  paper,
and paperboard industry.  The second phase included screening at 17 of
the verification program mills where processes were employed that were
characteristic  of the four mill groupings not included in the initial
screening program.  The third  phase  involved  47  screening  surveys
conducted by EPA Regional Surveillance and Analysis (S&A) field teams.
Collection  and  analysis  of  screening  samples  collected at the 17
verification mills and at the 47 mills sampled by Regional  S&A  field
teams  adhered  to  the  procedures specified in Sampling and Analysis
Procedures  for  Screening  of_  Industrial  Effluents   for   Priority
Pollutants (EPA,  Cincinnati, Ohio, April, 1977).(15)

Table  V-28  presents  a summary of the data collected during these 11
screening survey programs.  A summary of the analysis results for  the
second  phase  of the screening program conducted by the contractor at
the 17 verification mills is presented in  Table  V-29.   The  results
shown  in  Table  V-29  are  for  only  those  compounds that were not
detected in any wastewater samples  taken  at  the  11  mills  sampled
during initial screening surveys.

Table  V-30  presents  a  summary  of the  analysis results for the 42
regional surveys for which data  are  available.   At  31  of  the  47
facilities  surveyed  by  the Regional S&A teams, 3 individual 24-hour
composite samples were collected and analyzed  rather  than  a  single
72-hour   composite.   Analysis  results  for  the  screening  surveys
conducted by the Regional S&A teams  are  in  general  agreement  with
those conducted by the Agency contractor.
                                183

-------
                                                       TABLE V-27
                                               SUMMARY RAW WASTE LOAD DATA
                                            NONINTEGRATED MISCELLANEOUS MILLS
                       Production Profile
                                                                        Raw Waste Load
Production
.Mill No.
080006
080008
080026

080036

08SOOS
105004
105008
105010
105011

105012

105019

105022
105023
105024
105026

10S027
105028

105032
105035
105037
105038
105040
105041

105042
105050
105056

105059

105061
105062(b)
105065
105066
105067
105068
105069
105072
120053(b)
150003
150027
(t/d)
(•)
248
(•)

(a)

(«)
(a)
262
(a)
12

45

(a)

(•)
(a)
(•)
(a)

27
77

33
(a)
43
50
(a)
(a)

(a)
(«)
(a)

153

409
36
57
(a)
(a)
(a)
(»)
53
150
(a)
(a)
Product
Print, Photo
Print, Cotton, Pkg, Tissue
Print, Photo, Cotton,
Specialty Pkg
Print, Thin, Tiiaue, Release
Baie
Pkg, Conv
Spec Pkg, Glasaine
Print, Tech, Gasket, Sat
Spec Pkg, Sat
Spec Pkg, Glaaaine, Create
Prf
Spec Pkg, Glassine, Grease
Prf
Print, Write, Tape, Sat
Gasket
Unctd, Bristol, Pkg
Spec Pkg, Auto, Separated
Print, Pkg, Wet Str Glassine
Print, Poster, lad Conv Pkg,
Sat
Pkg
Print, Tech, Pkg, Sat,
Surgical
Gasket, Latex Sat
Asbestos, Gasket, Insul
Pkg, lad Conv
Pkg, Ind Conv
Pkg, Ind Conv, Sat, Bag
Briatol, Cable, Index,
Gasket
Copybase, Release, Specialty
Tape, Spec, Panels
Print, Thin, Pkg, Sat,
Tissue
Print, Ctd, Release,
Spec
Pkg, Print
Parchment
Print, Pkg, Cover, Masking
Tech, Asbestos, Pkg
Tech, Pkg, Lightweight
Print, Photo, Pkg, Sat
Writing, Tech, Cotton
Pkg, Ind Conv
Asbestos Gaskets
Asbestos, Electrical Board
Phenolic Board
Flow
kl/kkg
43.4
1.7
BOD
(kgal/t)
(10.4)
(0.4)est
kg/kkg
4.1
—
(Ib/t)
(8.1)
(--)
TSS
kg/kkg
34.7
1.0

(Ib/t)
(69.4)
(1.9)
	 	 	 . 	 Self -Contained 	

53.0

63.4
116.0
—
83.5
—

--

96.4

122.3
170.3
159.8
108.5

122.3
59.3

31.3
164.0
89.3
125.2
127.7
—

106.4
184.0
160.2

44.2

53.0
—
110.2
223.3
222.8
105.6
66.8
171.5
—
—
--

(12.7)

(15.2)
(27.8)
(" )
(20.0)
(--)

(--)

(23. Oest

(29.3)
(40.8)
(38.3)
(26.0)

(29.3)
(14.2)

(7.5)e.t
(39.3)
(21.4)
(30.0)
(30.6)
(--)

(25.5)
(44.1)
(38.4)

(10.6)

(12.7)
(--)
(26.4)
(53.5)
(53.4)
(25.3)
(16.0)
(41. I)
(--)
( — )
(--)

8.0

4.4
—
—
36.7
—

--

—

16.5
10.2
4.5
10.5

14.7
8.1

3.4
—
2.0
10.0
13.6
—

14.4
17.4
6.9

8.3

6.5
--
—
4.3
4.8
18.6
24.9
7.4
—
--
~~

(15.9)

(8.7)
(--)
(--)
(73.3)
(--)

(--)

(--)

(32.9)
(20.4)
(9.0)
(20.9)

(29.3)
(16. I)

(6.8)est
(--)
(4.0)
(20.0)
(27.1)
(--)

(28.7)
(34.8)
(13.8)

(16.5)

(12.9)
(— )
(--)
(8.6)
(9.5)
(37.2)
(49.8)
(14.8)
(--)
(--)
(--)

17.5

18.1
—
—
—
—

--

.-

29.2
15.7
25.5
17.0

40.3
24.1

25.8
30.2
3.0
—
61.7
—

50.6
41.1
13.8

34.0

48.8
--
—
156.5
149.0
86.8
42.4
26.2
—
—
~~

(35.0)

(36.2)
(--)
(--)
(--)
(")

(--)

(--)

(58.4)
(31.3)
(51.0)
(33.9)

(80.6)
(48.2)

(51.5)
(60.4)
(6.0)
(" )
(123.3)
(--)

(101. I)
(82.2)
(27.6)

(68.0)

(97.6)
(--)
(--)
(312. 
-------
                          TABLE V-28

SUMMARY  OF  INITIAL SCREKNING  PROGRAM ANALYSIS RESULTS
          TI.XII- I1.. I I n I,nit

          I .   at f'fl.iphl IlL'lit"
          2.   .11 >' roiuo I hattf )
          7.   flil.iriilx-nxtMif
          «.   1, 2 ,4-11 i ch I u rulifiixoiif
          ')    licXdClilorobenxtriH-
          JO.  J ,2-r.iflliyl ) cllit-r
          19.  2- -t h lor i» t hy I vinyl i-lher  (niixoil)
          20.  2-fliKiron.iplilli.i It'll.'
          21.  2 , i,ti-1 r ichlorufihi'iiu!
          22.  (I,J l\ll"ll ii- E'UIHt! t J ll't'Sul
          23.  i  Ii lt> rui arm  (t ri t Ii luromc than*')
          24.  2-rh I Mroi'lu'no 1
          2">.  I , 2-.lii -li I >ir illicit/.ft it-
          26 .  I , 3-IOO Ave Delft, lotl <10 10-100
12
12
12
462
12
12
10 1 1
12
12
1 1 1
; 2 3
12
] 1 1
12
1 1 1
12
12
12
12
1 .'.
1 1 1
1 ..'
2 1222
12
12
12
1 1
\.'.
12
Jjg/j) Final Kflluctit
Not"
>100 Ave Delected 
-------
TABLE V-28 iContinued)


Ti.x
10.
•\\ .
12.
t ', .

14 .
'15 .
id .
i?.
)«.
V).
40-
4 1 .
42.
4:s,
44.

4").
4t>.
47.
48.
4'J .
50.
51 .
5^.
vi.
54 .
55.
5ti.
57,
58.
iy .


It I'ol llll.llll
I , 2-1 r.nih-ili i lil or oflhy lene
_' ,4-ih i lili>ro|i|i>'»»\
1 J2--.li« lilt>ru|>r<>)».tr>*
1 , ,1-v! i t h 1 uroprupy Ivue
( I , i -if 1 1 h 1 <>rop r ojieiie )
2 , 4~"en/.eiif
i 1 noi-diil ii.-iie
4- rh 1 o e *jj'lu:iiy 1 plu'ityl ether
4--l'i iMiiophfiiy ) pln'iiyl ether
li i t.lJ-i-li IIMOI .sropyl ) ether
1» i s( 2 -t h J u roe i h<>xy ) methane
Mii-t hy idle ch loriije (djchloro-
Hielli.iiii')
iitflhy! ihluride (clilorometh^ne)
mt'fhyj brtimide (l»romometh*ne)
hruinolorin ( t ri hruroome thane)
.1 i ch 1 i/i ulirouioiru'lliane
t r i e hi ui fii 1 ut3ri>me thane
ilii lilonnli t liioiuiiiethaiie
I Illul ulliluotUOIHftitillte
ht>x. it'll i « I' ubii t^i! i one
hrx.u tihmn yi 1 upi-nt adiene
1 ^uplli> rune
il<100 Ave Detected <10 10-100 >100 Ave
12
11 1 1
12

12
12
12
12
12
65 19
10 2 1
12
12
12
12

4 2 54 I 1 6 4 81
12
12
12
111 1
11 1 23
12
111 1
12
12
11 1 5
1] 1 12
12
12
12
12
Final Effluent i
Not
Delected <10 10-100
11
9 2
11

11
11
11
11
11
9 2
10 1
11
11
11
11

I 2 4
11
11
11
li
10
11
1 1
11
11
1!
11
11
11
11
11
                                                                         >100   Ave
                                                                           4     55
                                                                            1    19

-------
                                                                                TABLE V-28 (Continued)
        Toxic  I'oljuljrit
05
N
60.
61.
62.
6'1.
64.
65.
66.
67.
6B .
69.
70.
71.
72.

73.
7**.
75).

76.
77.
7B .
Vi.

tttl .
8!.
82.

8:).

84.
85.
8B .
4,6-dini tro-o-t resol
N-ni L rus cull me thy I .imi in-
N-ni i rosodipheiiyldmine
N-iii t rosoiU-n-piopylaiBine
peiilachloropheiiol
phtfitol
l>is(2-ethylhexyl )  phthalate
butyl  benzyl plillialate
i;nzo
f ! iioraflthene
clirys»»'ii('
jceiiajihthy letie
aiithidcene
brunolglii Iperylone ( 1 , 12-benzo-
pery lene)
i I i*or*'ue
plienjriLhrt'fie
dibenzofa .hlaiithracene
( I ,2,5,6-di henzantlirdcene)
imletiol 1 ,2 , 3-cd Ipyrene
( 2 , 3-o-plieny 1 eut'py rene)
pyreiu-
loiri>clilorocthy lene
(OltltMlIf
Raw Water ((Jg/I)
Not
Detected <10 10-100 >100 Ave
11
11
11
11
11
092 6
713 5
11
4 33 1 16
10 1 1
10 1 1
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
10 1 1
Raw Wastewater (pg/1)
Not
Detected 100
12
12
12
12
12
0 264
2 163
U
J 135
12
/ 1 4
12
12
12
12
U
1 I 1
1 '
.; 2 2
I.'.
K:
12
i.1
12
i::
lo 2
1' 8 2
Final eifjuoiit (pg/1)
Not
Ave Oetpcted <1() 10-100 >100
11
11
11
11
11
624 0 r> 5 1
66 5 11
1 1
85 5 32 1
11
774
11
11
1 1
11
11
1 1 1
11
!> 10 1
li
11
11
1 1
11
1 I
1 10 1
44 t> 1

Ave





89
22

16

1







1






7
4

-------
                             TAIlI.li  V-2H (C..,itiniu-d)
       loxi i- I'ol tin jut

       H/.  tr ii liloroelhy Irne
       HK.  vinyj chloride (rhloroethyI.  4,4'-DUE  (p.p'-DDX)
       94.  4,4'-l)l)l)  (p.p'-TDE)
       95.  tt-endob'ulfan
       96.  (l-endobiil fan
       97.  endosu 1 t jn  suit.He.
^      98.  ondriu
(X      99.  endrin  aldehyde
a      lOO.Ileptjchlot
       101 . hept at:hi or  epox i de
       I02.U-UIIC
       lO.l.ii-Blir.
       104. y-HIIC (lindune)
       lOi  6-BIIC
       I06.l>i:ii-1242  (Aroihlur  1242)
       107.1'CB-1254  (Arochlor  1254)
       IOK.I'CU-1221  (Aroih or  1221)
       109.r-CU-12.-J2  (Aroch or  1232)
       I IO.I'CB-1248  (Aroch or  1248)
       II 1 .l'CB-1260  (Aroch or  1260)
       I 12.PCn-1016  (Aroch or  1016)
       m.Ti>xdi>lifin.-
       1 I 4.Antimony  (Total)
       1 15.Arsenic  (Total)
       1 l6.Asl100
11
11
11
11

11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
11
 0
 0
11
 0
            il
            n
            n
Not
Avc Del. rtcd <10 10-100
10 2
12
12
12
J2
12
12
12
12
12
12
12
12
12
12
12
12
12
12
12
1 1 1
12
12
12
12
12
12
1 0 10 2
:) o 11 i
12
1 0 12
NoL
>100 Avc Detected <10
1 11
1 1
11
1 1
11
1 1
1 1
1 1
11
11
1 I
11
11
11
11
1 1
11
1 1
11
1 1
1 10 1
1 1
11
1 1
11
1 1
11
7 0 10
5 0 10
1 1
1 0 11
10-100 MOO Ave




















1






1 4
1 3

1

-------
                                                                           TABLK V-28  (Continued)
CO
>0
Raw Water (M8/D
Toxic Pollutant
118. Cadmium (Total)
11 9. Chromium (Total)**
120. Copper (Total)**
121. Cyanide (Total)
122. Lead (Total)**
123. Mercury (Total)
124. Nickel (Total)**
125.Seleniun (Total)
126. Silver (Total)
127. Thallium (Total)
128. Zinc (Total)**
129. 2,3,7, 8-tetrarhlorodibenzo-p-
dioxin (TCDD)
130.Abietic Acid
131.Dehydroabietic Acid
132. Isopimaric Acid
133.Pinaric Acid
134.01eic Acid
135.Linoleic Acid
136.Linolenic Acid
137.9,10-Epoxystearic Acid
138.9,10-Dichlorostearic Acid
139.Monochlorodehydroabietic Acid
140.Dichlorodehydroabietic Acid
141.3,4,5-Trichloroguaiacol
142.Tetrachloroguaiacol
l43.Xylene
Not
Detected <10 10-100
0 11
065
0 1 10
0 11
065
0 11
065
0 11
0 10 1
0 11
0 9

*
11
11
11
11
11
11
11
11
11
11
11
11
11
11
Raw Wastewater (ug/1)
Not
MOO \ve Detected <10
1
8
27
10
10
1.2
13
2
5
2
2 55
















12
0
0
0
0
0
0
0
0
0
0

*
1
1
11
2
3
6
11
11
12
8
11
11
11
11

3

11
A
12
2
12
12
12







2
1



1




10-100

8
8

7

10



6


A
1

5
A
2

1

2
1
1
1

MOO

1
A
1
1





6


7
10
1
5
3
3
1


1



1
Final Kfflucnt (ug/1)
Not
Ave Uetrrted <10
2
42
81
26
36
1.5
35
3
2
2
555


365
700
9
87
99
192
18
5

41
5
1
1
4A
0
0
0
0
0
0
0
0
0
0
0

••'<•
7
.s
11
8
6
10
1 1
11
11
11
1 T
10
10
11
11
7

11
5
11
3
11
10
11




1

1
2






1
1

10-100

4
11

6

7

1

7


.3
3

2
3
1








MOO Avr
1
12
VI
10
16
1 .")
1 38
2
6
2
4 124


1 94
2 89

12
16
6





1
1

        *Not analyzed.
        **Cormistent discrepancies existed between split sample results for thi ; compound.

-------
                                            TABLE V-1'9

                  SUMMARY OK SCRF.KNINC ANALYSIS RESULTS AT  17  VERIFICATION MILLS


                                                                         Average
Compound                                                        	Ran^e	Concentration
 Ntimlu-r     Compound Name           .Sample Location  ND   _ £10     10-100    >100	(pg/1)
  3D

  62
Benzidine

Aery lonitri le

1 ,2-dichloroethylene
N-ni trosodipheny laniine
Raw Wastewater
Final Effluent
Raw Wastewater
Final Effluent
Raw Water
Raw Wastewater
15
11
16
11
16
16
1
1**
0
0
1
0
1
!**
1
2
0
1
0
0
0
0
0
0
1
1
1
3
0
1
. 1
.5
.A
.2
.2
.0
                ^Compounds listed are those detected -luring  screening  studies conducted at 17
                 verification mills that were not detected  in  any  wastewatur samples taken at
                 the 11 mills sampled during initial .screening surveys.
               *'"'KinaJ  effluent from clarifier at a s.'J f  contained mill.

-------
                                                                                TABLE  V-.10

                                               SUMMARY OF tl'A  KKfiJONAL S &  A SCREENING  PRI'ttiKAH RESULTS AT 42 MILLS
it' |H
II.   1, I , 1 -1 ri i hi o ro<; tli J tie
lr>.   I , ! ,2 , '- let rui li 1 OKH-th.tne
17.   bis (t b] i.rome.Uiy I )  rlher
18.   bibf '2-i -liluroflhyl ) ether

21.   ( b U. i at or in
2').   I , 1-di i Itlmoeihy Iciif
31 .   'i ,4-iii i hi oroplu'iiul
14.   2 , 4-J j met b;, ! pht:no I
.I).   2 ,<4-ilii»i I rut uliieiit:
Iti ,   2 , A ~ d 1 If i I ru Lo 1 iJelie
4.J,   1.1 .s ( 2-i him uf I boxy ) nn-th.iiu-
^4.   nu-iliylnu'  ttiluriJe
47.   I/1 oj«ol *>rii!
48 .   d 11 li i oiwbromoiilet b.itu;
''i9 .   t r M h Jui i^H no i owl h jjje
31.   ihloro.ljb i"*tinoiiu't IMDC
j J    fu'KdE'li 1 o ru<~y<' f open t .id i ffK'
V> ,   ri,»|>htlu, I cue
So    in t rude iixi-rir
SH .   4 - n i t I'otibt-no 1
02 ,   N- lit ( r f.s<.d i plu-ny I .nit i ne

t»r>.   pfit-iiol
(>t).   t>i.s(2-«-lliy Ibrxyl }  [ibtluil.ite
h7.   liulyl  beii.-.yl  (ibt li.. I ,ilc
«iii.   .1 i -n  lint y I  pin Ij-i l.i! c
71).   di.-ibyl  |.bth.,l,ilr
/I.   ili:uctliyl ptitbaljif
82 .   il i I>i-n £i> f a ,h j .inttir.it cue
ti'j.   li't i jcli I oi oe I by I cue
86.   U.lnrix-
rt7.   t ri< hlui iii'lhyti'iie
112.  rCli-1016 (Ar..Ki|.,i 1016)
 No.  of Hi I Is
fir re  pol tut «HI[
 wj.s  lit;t.erttrd

       10
        9
        0
        0
        1
       21
       3r>

       16

        0
        0
        I
       16
        1
        B

        2
        1
       10

        1
        2
       10
       34
       27
        9
       17
       12

        1
       li)
       23
        8
        1
                                                               KJW Waste
                                                            No
                                                           Wht!
                                                           was
Filial  Eftluent	

                 :b
                     Concent raL ioils
f Mills
pollutant No. i>f Hills
lerted at Concent ratj on where pollutant
than 10 pg/I Range (jjR/l) was detected
3
4
0
0
1
10
26
0
5
5
0
0
1
13
0
2
1
]
1
2
1
1
0
4
25
1 I
2
It
5
1
1
2
7
()
1
ND-
NO-


4,900-
ND-
ND-
ND-
ND-
ND-


ND-
NO-
<10
NI>-
ND-
ND-
<10-
ND-
ND-
00-
ND-
ND-
ND-
ND-
NO-
ND-
ND-
ND-
.18
Nl>-
ND-
ND-
<10-
30
70
NO
NI)
7,200
263
5,500
<10
2211
85
ND
NO
74
1 0 , 000

88
48
14
16
74
50
IK
<10
54
940
624
240
380
67
31

40
200
<10
12
10
7
1
1
--
It
24
4
9
4
1
1
0
15
1
1
1
2
--
4
1
1
1
6
13
28
7
19
7
1
0
b
15
5
0
No. of Mills
where pollutant was,
detected at greater
than 10_(jg/l
2
1
1
1
--
3
16
1
1
0
1
1
0
10
1
0
1
0
--
0
0
0
1
2
4
12
2
2
0
0
0
0
3
I
0
                                                                                                                                                      NO-
                                                                                                                                                      NO -
                                                                                                                                                      NO-
                                  80
                                  16
                                  24
                                  12
ND-
ND-
NO-
ND-
NIJ-
ND-
ND-

ND-
ND-
ND-
35-
Nl)-
14
1,200
86
41
•ilO
14
15
ND
3,600
13
<10
260
<10
                         NU-
                         ND-
                         NO-
                         17-
                         ND-
                         N»-
                         ND-
                         NO-
                         ND-
                         NO-
                         ND-

                         NO-
                         ND-
                                                                                                                                                               32
                                                                                                                                                               32
                                                                                                                                                               53
                                                                                                                                                             ,740
                                                                                                                                                               30
                                                                                                                                                               15
                                                                                                                                                               10
                                                                                                                                                          Nl)
                                                                                                                                                              <10
                                                                                                                                                              200
                                                                                                                                                               15
                                                                                                                                                          NI)

-------
                                                                  TABLE V-30  (Continued)
                                                Kaw  Waste       __           _      _      ___ 	  	Final Effluent


-.'"'
114.
I !').
117.
118
1 19.
120.
121 .
122.
124.
I2'i,
Ub
127,
I2B,

til! 1.1 Is ,
C'y.in i tic ,
T.it.il Phenolic*
. Ant imtmy
Ar:;en i r
IU> ry 1 i i nm
Cadi.ii lift)
('hruiti i HID
Coppii i nm
Si Iver
TlJa I 1 i inn
Z i m
Tat <* 1 Hit-no ( i cs
No. oi Mills,
wliere pollutant
was *ie tec led
!2
8
4"J
y
40
41
15
29
27
3
3
4
50
40
No. of Sample;*
detected at
10 to 99 (Jj|/l
14
9
49
12
58
75
25
28
36
5
6
10
45
16
No. of Samples
detected at
100 to 999 ^g/l
4
0
0
0
24
ia
t>
24
20
0
0
0
52
46
No. of Samples No.
at greater wliere
...Lh?JLj 5B/J 	 «a£
0
0
0
0
0
2
1
o
0
0
0
0
12
29
of Hills
pollutant
J?t£t!-?d_..
6
2
40
5
24
28
6
18
23
7
1
6
3V
32
No. oi" Samples
detected at
— L?_i?_2?_H8/L..
11
2
40
5
33
64
11
19
28
10
3
12
58
45
No. of Samples
detected at
	 IP-O.^L ???_««/ 1_.
0
0
0
0
17
3
0
13
13
0
0
0
25
21
No. of Sa
at g rea
than 1 a
0
0
0
0
0
1
0
0
0
0
0
0
4
2
The following pollutants were detected in at  least  one  raw waste and one final  effluent sample at a concentration of less than  10  M8/l:

6    c.irlioii  tci r jcliloride                               54.   isophorone
7    chloroU-iizcne                                       59.   2,4-dini trophenol
24.  J-clilor»phrnol                                      69.   di-n-octyl phthalate
2!i.  1,2-dicli lorohenzene                                81.   phenaulhrene/anthrjcene
38.  t*lliy Ihftizeiie                                        84.   pyrcne
1'.).  11 uorjntlienc

Tlu' ft. I lowing no! tulanls weie tit: tot ted in at  least  one  final effluent sample at a  concentration of less than  10 M8/l;

14.  I , 1 , 2 -11 i c 1' !«>rot'l htiue
20.  2-t li 1 oronaph I ha I ene
33 .  1 , *i-il i ch i tn oj»ropy J one

"fix fold,wing pollutants were detected in at  least  one  raw waste sample at a concentration of less than 10

10.  1,2-dicliloroeUiaue                                  42.   bis(2-chloroisopropyl) ether
II.  1 , 1 -di i htororlharie                                  45.   methyl cliloride
22.  pjr.ji'Mi>roirit.-t.i  cresol                              60.   4,6-dinitro-o-cresol

-------
Verification Program

As  described  previously,  the  contractor's initial screening survey
results, industry survey  responses,  and  available  literature  were
reviewed to develop a list of parameters to be studied in verification
sampling.    Table   II-8   presents   a  list  of  the  priority  and
nonconventional  pollutants  analyzed  as  part  of  the  verification
program.   During  verification  sampling  at 17 mills where processes
were employed that were characteristic of the four mill groupings  not
a  part of the initial contractor screening program, screening studies
were also conducted.  As  a  result  of  this  supplemental  screening
program,  three  additional  priority  pollutants  not included on the
verification compound list were identified.  However, as shown earlier
on Table V-29, the level and frequency of discharge of these compounds
did not warrant a review of the existing  GC/MS  data  tapes  for  the
remaining  43  verification  program  mills to further investigate the
presence of these three  compounds  in  pulp,  paper,  and  paperboard
industry discharges.

Verification samples were analyzed by GC/MS procedures that included a
quality  control/quality  assurance program developed specifically for
the analysis of pulp, paper, and paperboard  wastewater  samples.   As
discussed  in  Section  II, these procedures were developed to provide
higher quality analytical results than could  be  obtained  using  the
screening procedures.

In the verification program, data were obtained on 42 organic priority
pollutants,  6 metals, cyanide, 14 nonconventional organics (xylene, 4
resin acids, 3 fatty acids, and 6 bleach  plant  derivatives),  color,
ammonia, and COD.

Table  V-31  presents  a  summary of the verification program priority
pollutant analysis results by compound  and  subcategory.   The  table
shows the number of samples taken at mills in each subcategory and the
number  of  samples  in which the specific compound was detected.  The
ranges of concentrations and the  average  concentration  of  specific
compounds  at  those  mills  where  the compound was detected are also
shown.  Results for both raw waste and final effluent sampling  points
are presented.

Table  V-32  presents  a  summary  of  the results of analysis for the
additional nonconventional pollutants investigated during verification
sampling.  The same methodology and format utilized in Table V-31  has
been used to present summary information in Table V-32.

Long-Term Sampling Program

As  discussed in Section II, the Agency conducted a long-term sampling
program to obtain additional toxic and nonconventional pollutant data.
Tables V-33 and V-34 present summaries of  toxic  and  nonconventional
pollutant  data  obtained  during  sampling of a deink mill and a fine
bleached kraft mill.  Both tables present information on the number of
                               193

-------
                                                                TABLE V-31

                                             SUMMARY OF VERIFICATION PROGRAM ANALYSIS KESULTS
                                                           FOR TOXIC POLLUTANTS


                                     Total            Total  Number Of         *Concentrat ion           **Averjge
                               Number Of Samples    Detected Analyses         Kange (}lg/l)      Concentration (|Jg/l)       CompientB
Toxn Pol Iiitunt/Subcategory    Influent   Effluent   Influent  Effluent	Influent    ^iliy?"1	'.OQHSH? . £IfJH?Q^   Influent/Effluent
A. Brn/ene
Market Hlejrtted Kraft
bCT Bleaihcd Kratt
Unbleached Kraft
o BaK
Semi -CltfHi t:al
Unbleached Kraft
and Semi-Chemical
Dissolving SuJfite Pulp
Paper grade Sul f J Le
DP ink
o Fine Fa fieri.
o Tissue Papers

J'i sttue From Waste* pa per

rapt* rou«* fu r rore Was ttrpape r
Roofing fell

Nonintrgral.eil-r iue Papers

Nouintegrjt e
-------
                                                                       TAIJI.K V-.it (Continued)


                                                  Total           Total  NiiD.ber  Of         "Concentration          ^Avcrdg*;
                                            Niiiuhcr Of Saiapl rs    Detected  Analyses         Kangc  (pg/1 )      Concent rat i on (MK/ ' )       Comment s
            Toxic 1\>I LlJl_J".!VSuk^J:eJl0jy   _LniiHi'nL _J'f f i!1'!1.1.1-  Influent   Affluent    l!i£l*Ju"l _  _  EHJ_!'Vnf-  _  !!'* JueJ!V   ?_£' luenf:   Inl]j±£!!*/!>f I1 yenl

            4. Henzene  (continued)
               Noni ritffjrdted-l'apt'i boa rd
               Integrated Miscol Igneous
               NonintogrJted Miscrllam?ous


            6. Carbon 'futraehloride

            7 . Clilorobrn/.cne
               Deink
                o Tissue  Papers


            10. 1 ,2-niehioroetlidne
                Dei nk
                 o Tissue Pdpera

                NonIntegrated-Fine Papers

UD
cn
            11. 1 , I , 1-Trichloroet.hane
                Alkaliiie-Kine
                tlnbleuclied Krjft
                  and Seat i-Chemical
                pjperfciaiie Sul f i te
                Deink
                 o Fine  Papers
                PaperLourd Kron Wastepaper

                Bui 1 tiers '  Paper and
                  Roofing Felt

                Integrated Miscellaneous
                Nonintegrated Miscellaneous



             * Range  tor  those Mills where pollutant was detected in influent or effluent.
            ** Average  for those mills where  pollutant was detected in  influent or effluent.
6
12
3
No I
3
3
3
3
6
3
9
6
12
3
15
3
9
3
12
6
3
6
12
3
ifetecti-d
3
3
3
3
6
3
9
6
12
3
15
3
__
3
12
6
3
2
3
0

3
0
2
0
1
0
1
3
3
3
7
2
7
0
3
3
3
1
I
0

0
0
0
0
3
0
0
0
3
0
0
3
__
0
0
3
3
0-
6-
0

37-
0
0-
0
0-
0
0-
3-
130-2
6-
0-
0-
0-
0
3-
4-
7-
4
11


47

5

2

71
7
,000
53
4
5
20

187
9
22
0- 2
0- 2
0

0
0
0
0
1- 2
0
0
0
6- 8
0
0
2- 4
__
0
0
1- 5
4- 17
1
9
0

43
0
3
0
1
0
24
5
1,243
22
2
2
7
0
67
6
14
1

0

0
0
0
0
2
0
0
0
7
0
0
3
-.
0
0
2
10
Biological Treatment
Biological Treatment
Primary w/llolding Ponds

Partial Final Effluent
Biological Treatment
Partial Final Effluent
Biological Treatment
Biological Treatment
Hrinary Treatment
biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Primary Treatment
POTW
Primary Treatment
Biological Treatment
Primary Treatment
Primary w/Holding Pond

-------
                                                                     TABLE: V-JI (Continued)
1.0
en
Number Of Samples Detected
Toxic Pol Jutjiit/SuliciUegory Influent Effluent Influent
H. I.l-Oichlococthane
Papergrjdt1 Sul t i Le
2\ . 2,4,6-Ti it hlorophenol
Market Bleached Kratt
BCT Blejilied Kraft
A J ka 1 ine-f ine
Dissolving Sulfite Pu Ip
Papr.-rgr.idf Sul f J l«?
Drink
o Kim* Papers
o T is silt- Papers

I'JJM- rboa rd From Was Lepaper

Nun I nt eg rated Mi see 1 1 a lie o us

22 . Paracliloruurta Cresol
i'\ . Ch lorn form
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alka 1 inc-Kine
Unbleached Kraft
Semi -Chemical
Unblfrtrhed Kraft
and Seiui -Chemical
Dissolving Sulfite Pulp
Papergrade Sul f ite
Gruinidwood-Kine Papers

12
Not

6
y
9
4
12

3
3
3
15
3
12
6
3
Not

3
6
9
9

6

6
4
12
6

12

6
9
9
4
12

3
3
3
15
3
1 2
6
3
detected

3
6
•J
9

6

6
4
12
6

3

6
8
9
4
6

2
3
0
5
3
3
0


3
6
9
9

3

2
4
12
6
Anal yses
Effluent

0

6
1
7
4
6

1
3
0
2
3
3
0


3
6
8
9

0

0
4
12
6
Range
Int luent

5-

1-
0-
3-
7-
10-

0-
29-
0
0-
270-
0-
6-
0


360-
830-2
580-4
43-1

1-

0-
110-
62-8
17-

22

26
2\
23
15
370

16
65

5
420
18
30



900
,200
,000
,800

4

6
360
,600
240
(ug/1) Concentration  pollutant was detected in influent or effluent.

           ** Averjg*? for those mills  where pollutant was detected in influent or effluent.

-------
TABLE V-J1 (Continued)
'total Told 1 Number Of *Cuncent rat ion
Tux i «. I'o 1 1 u 1 
-------
co
                                                                        TABLE V-.'J1  (Continued)


                                                   Tola I            TdI a 1  Number Of          *Conccnt rat ion           *«Average
                                            Number 01  Samples    Delected Ana ly.M-s         Range  (H8/1)       Concent rat ion  (|ig/1)       Comments
                     »l lut jut/Suhr.it egory   Inl luent   Et fluent  jnl Ineiii  ti f l_ut*iil    !"* lu?'_lL_    ^^fl'jiL"?1   lufj".6"1	?f_LLll?Llk   1 nfluent/Effluent
.i 1 . 2 , K-;iched Kraft
" B.is
Sfini -riiemi ra 1
Ueink
u Newsprint
u Tissue 1'jperfc

'(issue From Waslepaper

Kuilders' I'.tpcr and
Koi.l IIIK Fell

Nmi i nl egr.it eil-Ti ssne Papers

Noniiitegiatrd-Fi Her
and Nonwoven Papers

N(»n integrated -Pa perboard
Integrated Mi si el laneous
Nniu in ex rat ed Hi seel luncous

V) . Kl iloranlliene
Dissolving Krafl
Dissolving Sulfile Pulp
• 1)

3
3
3

6
9

6
6

3
3
3
6
3

9
3
3
3

3
3
6
12
6
3

3
t.


3
3
''

6
9

6
6

--
3
3
6
3

--
3
3
3

3
3
6
12
6
.3

3
t.


1
3
0

1
0

3
2

2
3
0
3
1

3
0
3
0

1
0
3
1
2
0

1
1


1
2
0

0
1

0
2
Q

--
0
0
0
0

--
0
3
0

0
0
2
0
0
0

0
1


0-
1-
0

0-
0

1-
0-
0-

0-
27-
0
2-
0-

1-
0
54-39
0

0-
0
2-
0-
0-
0

0-
0-


5
5


82


2
2

4
45

74
5

11

,000


2

6
2
32


7
A


0- 3
0- 2
0

0
0- 3

0
0- 2

--
U
0
0
0

--
0
36- 300
0

0
0
0- 2
0
0
0

0
0- 1


2
4
0

27
0

2
1
j

2
33
0
27
2

5
0
13,081
0

1
0
3
1
13
0

2
1


1
1
0

0
1

0
1
Q

--
0
0
0
0

--
0
149
0

0
0
1
0
0
0

0
1


Biological Trealment
Partial Final Effluent
Biological Treatment

Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment

POTW
Partial Final Effluent
Biological Treatment
Biological Treatment
Primary Treatment

POTW
Primary Treatment
Primary Treatment
Biological Treatment

Biological Treatment
Primary Treatment
Biological Treatment
Biological Treatment
Primary Treatment
Primary w/Holding Pond

Biological Treatment
Biological Treatment
              "  KdiiK*-' tut those  mills where* pollutant  was  delected in influent or  effluent.
             x*  Average*  tor  Ihuse mills where polLutant  was detected in influent or  effluent.

-------
                                                         TABLE V-31 (Continued)
Total Total Number Of
Number Of Saapjes Detected Analyses
Influent
3
9
3
6
6
6
4
12
6
3
3
6
3
r 15
! 3
3
9
3
6
3
3
6
12
Effluent Influent Effluent
3
9
3
6
6
6
4
12
6
3

6
3
15
3
—
^_
3
6
3
3
6
12

7
3
4
4
3
3
10
1
3

3
3
6
2
0
4
0
1
2
,
1
4
0
6
0
5
6
1
1
12
0
3

0
2
3
1
—
__
0
2
3
2
0
4
^Concent ration
Rauge (MR/1)
**Average
Concentration (lig/1) Comaents
Influent Effluent
0-
0-
2-
0-
0-
0-
0-
0-2
0-
11-
0-
17-
1-
0-
0-
0
0-
0
0-
0-
0-
0-
0-
1
4
3
290
21
220
3
,500
13
14
3
410
11
4
2

6

1
17
2
3
10
0
0-
0
0-
'-
0-
0-
2-3,
0
1-

0
0-
0-
0-
--
__
0
0-
5-
0-
0
0-

4

6
14
80
2
100

3


4
4
1



1
8
2

12
Influent tf fluent Influent/Effluent
1
2
2
50
6
58
2
291
4
12
1
174
5
2
1
0
2
0
1
7
1
1
2
0
2
0
4
5
13
1
271
0
2
0
0
2
1
1
--
-.
0
1
7
1
0
2
Biological Treatment
Biological Treatment
Biological Treatnent
Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Partial Final Effluent
POTW
Biological Treatment
Primary Treatment
Biological Treatment
Biological Treatment
POTW
POTW
Primary Treatment
Biological Treatment
Primary Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Toxic Poilutant/Subcategury

44. Methylene Chloride
    Dissolving Kraft
    Market Bleached Kraft
    BCT Bleached Kraft
    Alkaline-Fine
    Unbleached Kraft
     o  l.inerboa rd
     o  Bag
    Semi-Chemical
    Unbleached Kraft
      and Sepi-Chemical
    Dissolving Sulfite Pulp
    Papergrade Sulfite
    Croundwood-Fine Papers
    He ink
     o Tisaue Papers

     o Newsprint
    Tissue From Wastepaper

    Faperhoard From Wastepaper

    Wastepaper-Molded Products

    BuiIders* Paper and
      Hoofing Felt

    Nonintcgrated-Fine Papers

    Menintegraled-Lightweight
      Papc rs
    NonIntegra Led-Paperboard
    integrated Miscellaneous
   Range lor those mills where pollutant was detected in influent or effluent.
   Average for those mills where pollutant was detected in influent or effluent.

-------
                                                          TABLE  V-31  (Continued)
                                     Total           Total  Number  Of          *Concent rat ion           **Average
                               Number Of Samples    Detected Analyses          Range (pg/1)       Concentration (pg/L)        Comments
T_°?ir f"' liUjiU/Snljcatcgory 	Influent  Effluent  _lnflneiil_ Effluent	 LsiiS*!!!     E£flu«Mil    Influent  Effluent   |nf i"?"1 /HfJ ly^ili












ro
o
o










47. Bromoform

48. Dj ch 1 orobromomethane
Dissolving Kraft
Alka 1 ine-Fine
('.ipergratle Sultite
Paperboard r'rooi Watttepaper

Knililert*' Paper and
Roufing Felt

49. Tri< lilorof 1 uoroaelhaue
Builders' Paper and
Routing Kelt


51. Di In oooclil oromethane
Builders' Caper and
Hoofing Felt

">4. Isopliurone
Unbleached Kraft
o l.incrhoard
55. Naphthalene
Scnti -Cheint ca 1
Oissolvinx SuJfite Pulp
Papergrudf Sul file

3

3
9
12
15
3

9
3


9
3



9
3


3

6
4
12
| C
J 3
3

3
9
12
IS
3

--
3


--
3



—
3


3

6
4
12
Q
1

1
3
3
0
1

1
0


1
0



1
0


3

2
3
3
Q
1

0
0
1
0
3

--
0


—
0



—
0


0

0
0
3
Q
0- 119

0- 4
13- 18
8- 40
0
0- 3

0- 14
0


0- 8
0



0- 5
0


8- 15

0- 5
3- 4
22- 230
Q
0- 62

0
0
0- 5
0
1- 2

--
0


--
0



--
0


0

0
0
7- 88
Q
40

1
15
26
0
1

5
0


3
0



2
0


11

3
4
102

21

0
0
2
0
1

--
0


--
0



--
0


0

0
0
36

Primary Treatment

Biological Treatment
biological Treatment
Primary Treatment

POTW
Primary Treatment


POTW
Primary Treatment



POTW
Primary Treatment


Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment
 * K.Jiige fur  those  mills  wh^rc pollutant watt delected  in  i nf Jucnt  or ef fluent.
 •'• Average  tor  those  mi/Is where pnl lulant was detected  in  inf lut-nt  or ef f 1 ncnt.

-------
no
o
                                                                      TABLE V-31 (Conlinued)





                                                Total            Total Number Of          "Concentration          *~"'Aver.iRe

                                          Number Of .Samples     Detected Analyses          Kange  (^lg/j)      Concentration  (MX/')        Comments

           Toxii  Pol Iut.int/Snbc£le(jory   l_n fluent  Kfflijenl   Influent   Effluent     Influent      Kff1'!!!'!1   I"! ' L'PP1 _J:f' ! '"''^   Influent/KH'luent
S5. Naphtha lene (continued)
Dei ilk
o Fi fit* lepers
o Ti ssuir Papers


Inlr grated Mi seel la neons
59. 2 , 4-di n i I ropheuol
64. IVntacli 1 oropheno ]
BCT Bleached Kraft
Al kj 1 i lie-Fin.1
Semi - Cht'm i ca 1
Unl.leached Kraft.
and Seini -Chemi ca 1
Papernrade Sulfite
Groundwood-Fine Papers
Deink
o Fine Papers
o Tissue Papers

Paperboard Front Wastepaper

Wastepapt' r -Molded Products

Builders' Paper and
Koofing Felt

Integrated Misccl lancoufl
Nanijltfgr.it ed Mi seel Ja/teous

65. Phenol
Dissolving Kraft
Market Bleached Kraft


:)
3
:i
^
3
12


9
9
6

6
12
6

3
3
3
15
3
3
3

9
3
1 2
6
3

3
6


3
3
3
6
3
12
Not detected

9
9
6

6
12
6

3
3
3
15
3
3
--

—
3
12
6
3

3
6


3
2
0
Q
3
1


3
3
1

1
6
3

3
3
0
5
3
1
0

6
0
4
0
2

3
6


0
0
0
Q
2
0


3
2
1

0
1
2

3
3
0
0
3
1
—

—
0
2
0
2

3
5


67-
0-
0
Q
16-
0-


5-
6-
0-

0-
1-
3-

9-
10-
0
0-
850-
0-
0

17-
0
0-
0
0-

8-
13-


190
78

A3
4


31
11
5

7
12
12

24
61

19
1,200
6


160

29
200

110
26


0
0
0
Q
0-
0


16-
0-
0-

0
0-
0-

4-
27-

0
1 ,100-1
0-
—

--
0
0-
0
0-

10-
0-





27



21
1
2


1
'2

20
38
0

,400
4




5
68

29
2


142
48
0
()
26
1


19
8
2

2
6
6

15
38
0
6
1,050
2
0

65
0
1 2
0
72

54
20


0
0
0
Q
18
0


19
1
1

0
1
1

12
34

0
1,200
1
—

--
0
0
27

18
1


Biological Treatment
Partial Final Effluf.it
Biological TredtmtMit
Primary Treatment
Biological Treatment


Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Partial Final Effluent
Biological Treatment
Biological Treatment
Primary Treatment
Biological Treatment
POTW

POTW
Primary Treatment
Primary Treatment
Primary w/llolding Pond

Biological Treatment
Biological Treatment
            * Range  for  those mills where polluianL wa&  detected  in influent or effluent.

           "•'•"** Average  tor  those mills where pollutant  was  delected in influent or effluent.

-------
                                                      TABLE V-31 (Continued)
Total
Number Of Samples
Toxic PoJ lutaiil/Siilu-ategory Influent Effluent
65. Phenol (continued)
BCT Bleached Kraft
Al ka 1 ine-Kine
Unbleached Kraft
o Linernuard
o Bag
Semi -Clienica 1
Unbleached Kraft
and Semi -Chemical
Dissolving Sulfite Pulp
Papergradc- Sulfite
Crouiidwood-t'ine Papers
Ueink
o Fine Papers
o Tiusue Papers

o Newsprint

Paperboard Fron Wastepapcr

Was tc-papc-r -Molded Products

builders' Paper and
Roofing Felt

Notii ntegratcd-Fine Papers

Noni ntegrated-Ti ssue Papers

Non integrated- Lightweight
Papers
Non intcgra ted-Ki Her
jnd Nonwoven Papers

Non integrated -Paperboard

9
9

3
6
6

6
4
12
6

3
3
3
3
3
3
15
3
3

3
9
3
6
3
3

3

3
3
6

9
9

3
6
6

6
4
12
6

3
3
3

3
3
15
—
3

3
--
3
6
3
3

3

3
3
6
Total Number Of ^Concentration **Average
Detected Analyses Range (pg/1) Concentration (pg/1) Comments
Influent Effluent Influent Effluent Influent Effluent Influent/Effluent

9
6

3
6
6

6
4
11
6

3
3
0

0
3
15
3
3

3
9
3
4
3
2

2

0
3
6

4
2

3
0
6

0
4
6
4

0
0
0

0
3
2
--
1

3
—
3
0
2
2

2

2
1
3

25-
4-

41-
50-
160-

30-
12-
0-
15-

8-
76-
0
0-
4—
~
0
430-
6-
4-
7-

1,100-1
51-
44-
0-
1-
0-

0-

0
8-
2-

92
14

110
140
400

100
19
640
51

41
150

4
1 Aft
1 **U
500
91
8
9

,400
280
150
25
11
2

4


150
10

0-
0-

3-
0
3-

0
1-
0-
0-

0
0
0

0_
~
0
310-
0-
—
0-

1,200-1
—
22-
0
0-
0-

0-

0-
0-
0-

17
2

4

24


10
250
5






520
13

3

,700

66

9
3

3

17
3
3

55
11

77
89
230

56
14
176
28

22
119
0
1
L. 1
H 1
0
457
41
6
8

1,233
134
94
6
5
1

2

0
64
6

5
1

3
0
14

0
5
41
2

0
0
0

0
427
1
—
1

1,433
—
38
0
4
2

2

10
1
2

Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Partial Final Effluent
Biological Treatment
POTV
Biological Treatment
Primary Treatment
Primary Treatment
Biological Treatment
POTV
Biological Treatment

Primary Treatment
POTV
Primary Treatment
Biological Treatment
Biological Treatment
Primary Treatment

Biological Treatment

Primary Treatment
Biological Treatment
Biological Treatment
Range for those aills where pollutant was detected in influent or effluent.
Average for those mills where pollutant was detected in influent or effluent.

-------
                                                                TABLE V-31  (Continued)
O
u
                                           Total
                                     Number Of Samples
       Toxi£ Hoi lnt ant ,/Siitu .ili'gory   lilt I iiunt  Effluent
  Total Number Of
 Detected Analyses
Influent  Effluent
    ^Concentration
     Range (|Jg/l)
Influent     Effluent
     **Average
Concentration (|Jg/l)
 Influent  Effluent
     Comments
Influent/Effluent
65. Phrnol ( font i itni'tf J
Integrated Nisid Uincous
Noninl egra t ed M i .sccl 1 aneons

66. Bis(2-elhylhexyJ ) Phthalate
Dissolving Kraft
Market Bleached Kraft
BCT Bleached KrjH
Alk.i 1 ine-Fine
Unbleaclied Kralt
u LiiiRi hoard
o Bag
Semi -Chemical
llnh leached Kraft
and Seuii -Chemi ral
Dissolving Sulfili! Pulp
Papergrjde Sulfil>-
Gruiifulwaod- t'i ne I'.ipers
Dei nk
o Fine Papers
o Tissue Papers

o Newsprint
Tissue From Wastepaper

Paperfooard Kruin Wastepaper

W.js t«*paper-Mo 1 ded Products

Riiiltlers' Paper and
Hooting Fell

Nun inLegr j led-Fi ne Papers


\2
3
6

3
6


12
3
6

3
6
9
9

3
6
6

6
4
12
6

3
3
3
--
3
6
3
15
--
3

--
3
3
6

9
2
4

3
6
e
7

3
2
5

5
4
9
A

2
3
2
3
3
5
3
13
3
3

9
0
3
3

7
2
A

1
A
6
6

1
1
6

5
A
5
6

1
0
1
--
1
3
1
10
--
1

--
0
3
4

0-
0-
0-

15-
6-
0-
0-

3-
0-
0-

0-
2-
0-
0-

0-
A-
0-
8-
3-
0-
17-
0-
11-
1-

5-
0
A10-2
0-

68
5
1A

180
21
35
190

130
7
46

16
22
200
18

10
26
20
20
5
19
3A
83
18
4

80

,500
13

0-
0-
0-

0-
7-
0-
0-

0-
0-
3-

0-
3-
0-
2-

0-
3-
0-
—
0-
0-
0-
0-1
—
0-

--
0
28-2
0-

15
3
8

A
9A
11
A9

9
A
29

1A
38
91
1A

4
5
2

1
8
20
,200

2



,494
25

15
3
6

72
1A
8
29

A9
A
21

10
9
29
7

4
13
8
13
4
10
23
14
14
3

35
0
1,193
3

4
1
3

1
32
3
16

3
1
15

10
14
21
7

3
4
1
—
1
3
7
87
--
1

--
0
869
6

Biological Treatment
Primary w/Holding Pond
Primary Treatment

Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Partial Final Effluent
Biological Treatment
POTW
Primary Treatment
Biological Treatment
Primary Treatment
Biological Treatment
POTW
Biological Treatment

POTW
Primary Treatment
Primary Treatment
Biological Treatment
         Kdiigo  for  Ihobf mills where pollutant was detected in influent or effluent.
         Aver.ige  lor Lhosu mills where pollutant was detected in influent or effluent.

-------
                                                           TABLE V-31 (Continued)
                                     To I a I
                               Niiml'er Of Samples
Toxic I'til lut .int/Siili( .jl rgory   l_ii fluent  E^fhienl
                                                      Total  Number Of
                                                     Delected  Analyses
    '•'•Concent rat ion           **AveraRi;
     Range (pg/1)       Concent ration (pg/1)       Comments
Influent _   Effluent    1 nf 1 nt-nt  Effluent    Inf 1 uent/EfI 1 uent
66. Uis(2-etliy Ihexyl ) Phthalale
Noui n I egrti li.'d-Ti ssue Papers

Nonintegrat ed-l.i xl'l-v-'e ight
Papers
Non i nl eg ra I ed- Ki 1 1 e r
and Non-Woven I'.ipers

Nou i u tegr j I ed-Papet hoa rd
Non i ut e&ra 1 ed Mist e i laueous

(>1. Hutyl Ben/yl Phtli.iljle
Unhleai hed KrJtt
o H,,g
Sem i -Chemi < a 1
Dissolving Siilfilr Pulp
DC ink
o Newsprint
Paper hoard Kiom W.islepaper

lill i Iclei s ' Paper and
Kuotiiig Kelt

Nou i n legra t ed-Ti s.sue Papers

08. IH-n-Biityl Phtlulute
Dissolving Kraft
Market Bleat-lied Kraft
Bi'T Bleached Kraft
A 1 ka 1 i ne- K i ne
llnhleaclied Kraft
o Li net hoard
o Bag
Semi -Cheini ea 1
(font inued)
3
3

3

.i
i
6
1 2

t)


b
0
4

)
:i
15

3
9
)
:i

3
6
y
y

3
6
6
3
3

3

3
3
6
12
3
6


6
6
4

--
3
15

3
--
3
3

3
6
9
9

3
6
6
3
3

3

1
3
6
9
3
6


2
1
0

3
3
4

0
3
3
0

2
6
5
2

3
1
6
3
2

3

2
3
3
9
3
6


0
0
1

--
3
0

0
--
1
0

1
5
1
1

3
0
0
8-
6-

4-

0-
14-
4-
0-
6-
3-


0-
0-
0

3-
17-
0-

0
5-
620-
0

0-
3-
0-
0-

1-
0-
1-
73
13

7

1
160
31
25
15
150


3'J
1


8
190
170


12
950


13
4
27
2

10
1
11
8-
0-

6-

0-
13-
0-
0-
1-
1-


0
0
0-

--
38-
0


--
0-
0

0-
0-
0-
0-

1-
0
0
38
13

7

4
61
7
220
26
11




2


81


0

15


3
19
23
2

2


30
8

5

1
85
11
g
11
34


23
1
0

5
80
51

0
9
797
0

7
4
9
1

7
1
4
23
7

7

2
31
2
25
15
6


0
0
1

--
63
0

0
--
5
0

1
8
4
1

1
0
0
Biological Treatment
Primary Treatment

Biological Treatment

Primary Treatment
Biological Treatment
Biological Treatment
Primary w/llolding Pond
Primary Treatment


Biological Treatment
Biological Treatment
Biological Treatment

POTW
Primary Treatment
Biological Treatment

Primary Treatment
POTW
Primary Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment
 ~- Range for  those  mills where pollutant was detected  in  influent  or effluent.
'•'•••• Average  for  those  mills where pollutant was detected  in  influent or effluent.

-------
                                                                      TABLE V-31 (Continued)
                                                                                         *€oQceetratiafl
                                                                                                                 **Average
IS3
O
in
Number Of Saaples Detected Analyses
Toxic PolIutBut/Subcatittory Influent Effluent Influent Effluent
68. Di-n-Butyl Phthslate (conti
Unbleached Kraft
and SeBi-Chestical
Dissolving Sulfite Pulp
Papergrade Sulfite
Groundwood-Fine Papers
He ink
o Fine Paper*
o Tissue Papers

o Newsprint
Tissue FroM Waatepaper


Builders' Paper and
Roofing Felt

Nonintegrated-Tissue Papers

Nonintegrated-I.ightweigbt
Papers
Noniotegrated-Filter
and Nonwoven Papers

Nonintegrated-Paperboard
Integrated Hiscelisneoua
69. Di-n-Octyl Phthalate
70. Diethyl Phthalate
Dissolving Kraft
Market Bleached Kraft
Unbleached Kraft
and Seaii-Chestical
Dissolving Sulfite Pulp
Papergrade Sulfite
* Rauge fur those mills where
oued)

6
4
12
6

3
3
3
3
3
£
3
15

3
1
3
3

3

3
3
6
12


6
4
12
6

3
3
3
—
3
6
15

3
—
3
3

3

3
3
6
12


4
2
1
4

3
1
0
1
0
1
2
11

0
5
1
0

1

0
0
3
4


0
1
0
4

2
2
0
—
0
0
0

0
—
0
0

1

1
0
1
2
Range (MS/1) Concentration (Ml/1) CosMents
Influent Effluent Influent Effluent Influent/Effluent


0-
0-
0-
0-

3-
0-
0
0-
0
0-
0*
0-

0
0-
0-
0

0-

0
0
110-
0-


12
2
3
8

9
10

2

17
85
21


25
3


3



230
7


0
0- 1
0
0- 11

0- 12
0- 12
0
—
0
0
30« 55
0

0
—
0
0

0- 5

0- 2
0
0- 61
0- 4


5
1
I
3

5
3
0
1
0
6
32
9

0
9
1
0

1

0
0
180
1


0
1
0
4

6
5
0
—
0
0
44
0

0
—
0
0

2

1
0
20
1


Biological Treataient
Biological TieatAent
Biological Treatment
Biological Treatment

Biological Treatment
Partial Final Effluent
Biological Treatment
POTW
Prisiary Treataent
Biological Treatsient
Biological Treatment

Pristary Treatment
POTW
Prinary Treatsient
Biological Treatsient

Biological Treatment

Priaiary Treatment
Biological Treatment
Biological Treatsient
Biological Treatatent
Not detected

3
6

6
4
12

3
6

6
4
12
pollutant was detected
** Average for those Bill* where pollutant

1
3

2
1
1
in
wab detected

0
0

0
0
1
influent or
in influent

0-
0-

0-
0-
0-
effluent

7
2

20
9
5


0
0

0
0
0- 14


2
1

13
9
2


0
0

0
0
5


Biologic* TreatsKnt
Biologica Treatment

Biolosica Treatsient
Biologica Treataient
Biologica Treatswnt

or effluent.

-------
                                                                       TABLE  V-31  (Cunlinueil)
                                                                                           *Concent ration
                                                                                                                   **Avrrage
fV)
o
cr>
Tox
70.











76.
77.
78.



81.
84.

85.










Number Of Samples Detected
ir Pol lut ant/Subcategory Influent Effluent Influent
Di ethyl Ph thai ate (continued)
Ueink
o Newspr int
Tissue From Wastepaper

Paperboard From Wastcpapcr

Bui Iders ' Paper and
Roo t i ng Felt
Nonintc-gr jted-Ti ssue Papers

Won i ntegrated-Paperboard
Integrated Miscellaneous
Chrysene
Areiuphthylenc
Anthracene
D J tisol vi ng Kra ft
BCT Bleached Kraft
Dissolving Sulfite Pulp
Phenantlircne
Py rene
Di Sbol v i MK Kraft
Tetrach Lorot thy lene
BCT Bleached Kraft
Alkaline-Fine
Unbleached Kraft
o Bag
Papergradc Sulfite
Cronndwood-Fine Papers
Dei nk
o Fine
Tissue From Wastepaper

3
3
6
3
15

9
3
3
6
12
Not
Not

3
9
It
Not

3

9
9

6
12
6

3
3
6
--
3
6
3
15


3
3
6
12
detected
detected

3
9
A
detected

3

9
9

6
12
6

3
3
6
1
0
2
i
6
Q
6
1
0
1
5



1
1
0


1

3
1

2
0
1

3
2
0
Anal yses
Effluent
2

0
0
3
3
Q

0
0
2
2



0
0
1


0

0
0

0
2
0

0
1
0
Range
Infl uent
0-
0-
0
0-
12-
38-
Q
0-
0-
0
0-
0-



0-
0-
0


0-

1-
0-

0-
0-
0-

22-
0-
0
10
4

55
210
690

180
35

12
6



5
3



6

5
3

2

2

180
220

lMg/1) Concentration (pg/1) Comments
Effluent Influent Kffluenl Int Inent /Effluent
0- 6

0
0
220- 320
0- 310
Q

0
0
0- 130
0- t,



0
0
0- 1


0

0
0

0
0- 6
0

0
0- 57
0

1
0
26
79
23A
Q
29
12
0
4
2



2
1
0


2

3
1

1
0
1

95
74
0
2

0
0
273
71
Q

0
0
58
1



0
0
1


0

0
0

0
3
0

0
19
0

POTV
Primary Treatment
Biological Treatment
Primary Treatment
Biological Treatment

POTW
Primary Treatment
biologi cal Treatment
Biologi ca 1 Treatment
Biological Treatment



Biological Treatment
Biological Treatment
Biologica 1 Treat ment


Biological Treatment

Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Primary Treatment
Biological Treatment
               •v Range for those mills where pollutant  was  de tec-ted  in  Influent  or  effluent.

              ** Average for those mills where pollutant was  detected  in  influent or  effluent.

-------
                                                         TABLE V-31  (Continued)
                                    Total
                              Number Of Samples
Tox i r _Pol I uian t/Sulu-a le£tiry   I n f J m-nl	Effluenl
  Tolal Number Of
 Delected Analyses
Influent  Effluent
    *Concenlralion
     Range (Mg/1)
InfJuonl     Effluent
     *~* Average
Concentration (pg/1)
 Influent  Effluenl
     Comments
Influent/Effluent
85. Telrachloroelhy lenc (continued)
Paperbojrd From W;istepaper

Builders' Paper and
Routing Kelt

Non i ntegr;i t ed-Ti ssue Papers

Noni nlegra led -Pa per board
86. Toluene
Dissolving Kraft
Market Bleac-lied Kraft
BCT Bleached Krji t
Al kal ine-Fine
Unbleached Kraft
o Linerboard
o Bag
Seini -Chemical
PO Unbleached Kraft
O arid Scin i -Chemical
Dissolving Sulfitc Pulp
Papergradc Snl file
Grouniiwood-r' i ne Pjpers
Dei uk
o Fine Papers
o Tissue Papers

o Newsp r i n t
Tissue From Wastepaper

Paperboard from Wjslepapcr

Builders' P.iper and
Roofing felt

15
3


-------
                                                                       TABLE V-31 (Continued)
ro
o
CO
              To x i c fo 1 1 u taut/Subcategory

              86. Toluene  (continued)
                  Nonintegrated-Fine Papers
                  Nonint egrated-Tissue Papers

                  Non Integra ted-Lightveight
                    Papers
                  Noui ntegra ted-Fi 1 ter
                    and Nonwoven Papers

                  Nonintegrated-Papeiboard
                  Integrated Miscellaneous
                  Nonintegrated Hiscel laneous
87.  Trichloroethylene
    BCT Blrarhcd Kraft
    Seni-Chemica1
    Unbleached Kraft
      and Semi -Chemical
    Papergrade Sulfite
    Dei nk
     o Fine Papers
     o Tissue Papers

    Paperboard From Wastepaper

    Builders' Paper and
      Roofing Felt

106. PCH-1242
     Deink
      o Fine Papers
                                                  Total
                                            Number Of Samples
                                            Influent  Effluent
                                                    Total  Number Of
                                                   Detected Analyses
                                                  Influent  Effluent
                                                                                          Concentration
**Average
6
3
3
3
3
3
3
6
12
6
3
6
6
6
12
3
3
3
15
3
9
3
6
3
3
3
3
3
3
6
12
6
3
6
6
6
U
3
3
3
15
3
	
3
Range (pg/1) Concentration (pg/1) Comments
Influent Effluent Influent Effluent Influent/Effluent
0
0
2-
0
0-
0-
0
0-
0-
2-
0-
1-
4-
0-
2-
130-
8-
0
0-
0
0-
0-


380

5
6

5
660
6
3
2
IS
3
33
8SO
13

5

38
2
1- 2
0
1- 15
0
0- 2
0
0
0- 1
0- ISO
0
0- 2
0
0
0
0
3- 11
0
0
0
0
—
0
0
0
130
0
2
2
0
2
99
4
1
2
9
1
IS
493
11
0
1
0
11
1
2
0
6
0
1
0
0
1
66
0
1
0
0
0
0
7
0
0
0
0
—
0
Biological Treatment
Prisury Treatment
Primary Treatment
Biological Treatawnt
Biological Treatment
Biological Treatment
Prisury Treatment
Biological Treatment
Biological Treatment
Primary Treatment
Prisury w/Nolding Pond
Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Partial Final Effluent
Biological Treatment
Biological Treatment
Prisury Treatment
POTW
Primary Trea talent
                                                                                        0-
                                                                                              9.9
                                                                                                                             0   Biological Treatment
               * Range for those nills where pollutant was detected in influent or effluent.
              ** Average for those mills where pollutant was detected in influent or effluent.

-------
                                                                      TABLE V-31  (Continued)
ro
O
107.  PCB-I254
     Unbleached Kraft
       and Seni-Chemical
     Deink
      o Tissue Papers

     Tissue From Vastepaper

     Paperboard from Vavtepaper  IS

     Bui liters' Paper and
       Roofing Felt

     Noniiitegrated-Fine Papers

     Nonintegrated-Filter
       and Nonwoven Papers

     Integrated Miscellaneous
     Nonintrgrated Miscellaneous  6
             108. PCB-U21

             109. PCB-1232

             110. PCB-1248
                  Paperboard From Wastepaper  15

                  Builders' Paper and
                    Roofing Felt
             111. PCS 1260
                  Deink
                    o Tissue Papers
             112. PCB 1016

             119. Chromium
                  Dissolving Kraft
                  Market Bleached Kraft
                  BCT Bleached Kraft
                  Alka1ine-Fine
Total Total Number Of
ber Of Samples Detected Analyses
luent Effluent Influent Effluent
6
3
3
6
3
IS
3
9
3
3
6
3
3
12
6
3
Not
Not
15
3
9
3
3
3
Not
3
6
9
9
6
3
3
6
3
IS
3
—
3
3
6
3
3
12
6
3
detected
detected
IS
3
--
3
3
3
detected
3
6
9
9
3
1
0
4
0
1
2
3
0
2
0
1
0
2
1
0


4
0
2
0
1
2

3
6
9
9
3
0
0
3
0
1
3
—
0
0
0
0
0
2
0
0


2
0
—
0
0
0

3
6
9
9
*Concent rat ion **Average
Range ((Jg/1) Concentration (|Jg/l) Comments
Influent Effluent Influent Effluent Influent/Effluent
0- <1
0- 4
0
0- <1
0
0- <1
0- <1
0- <1
0
0- <1
0
0- 28
0
0- <1
0- 7
0


0- 10
0
0- 7
0
0- 3
0- <1

5- 21
7- 20
4- 300
<2- 76
0- 2
0
0
0- <1
0
0- <1
41
—
0
0
0
0
0
0- <1
0
0


0- <1
0
—
0
0
0

<2- 19
9- 73
5- 240
2- 17
1
1
0
1
0
<1
<'

-------
                                                      TABLE V-31 (Continued)
Total
Number Of Samples
Toxic Pollulaiit/Subrat
-------
                                                         TABLE V-31 (Continued)
Total
Number Of Samples
Toxic Pollutant/Subcategory Influent Effluent
119. Chromium (continued)
Nonintegrated Miscel laneoua

<20. Copper
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine
Unbleached Kraft
o Linerboard
o Bag
Semi-Chemical
Unbleached Kraft
and Semi-Chemical
Dissolving Sulfite Pulp
Papergrade Sulfite
Groundwood-Fine Papera
Drink
o Fine Papers
o Tissue Papera

o Newsprint
Tissue From Wastepaper


Wastepaper-Molded Products

Builders' Paper and
Roofing Ke 1 t

Nouintegrated-Fine Papers



6
3

3
6
9
9

3
6
6

6
4
12
6

3
3
3
3
6
3
1 ^
1 3
3
3
3

9
3
6
3
3

6
3

3
6
9
9

3
6
6

6
4
12
6

3
3
3
—
6
3
1 ^
1 3
3
3
—

—
3
6
3
3
Total Number Of
Detected Analyses
Influent Effluent

6
3

3
6
9
9

3
6
6

6
4
12
6

3
3
3
3
6
3
1 ^
1 3
3
3
3

9
3
6
3
3

6
3

3
6
9
9

3
6
6

6
4
12
6

3
3
3
—
6
3
15
3
3
—

—
3
6
3
3
Concentration **Average
kange ((Jg/1) Concentration (Mg/1) Cossients
Influent Effluent Influent Effluent Influent/Effluent

<1-
5-

39-
24-
18-
9-

<2-
12-
44-

16-
8-
<2-
12-

42-
22-
8-
57-
24-
8-
2"
150-
3-
25-

30-
185-
<1-
6-
n_
65-

22
39

42
37
70
48

16
46
120

64
35
220
62

80
37
21
89
100
15
650
188
34
44

270
210
20
62
jf
A3
88

1-
<2-

<2-
4-
<2-
<1-

<2-
4-
5-

2-
6-
8-
5-

<2-
12-
<1
—
3-
<2-
<2-
143-
2-
—

—
87-
< 1-
16-
15-
13-

20
2

42
26
42
23

7
15
37

2B
28
100
24

11
40


110
18
42
162
5



97
81
26
•1-1
J J
17

11
18

40
31
46
22

9
24
79

38
17
71
28

61
29
13
76
55
13
46
yv
169
16
37

145
202
13
43
22
74

5
2

17
14
17
8

5
9
25

15
20
33
14

6
22
<1
—
47
8
15
152
4
—

—
93
18
19
25
14

Prlaury Treatwnt
Priaury v/Uolding Pond

Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment

Biological Treataent
Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Partial Final Effluent
Biological Treatment
POTW
Biological Treatment
Primary Treataent
Primary
Biological Treatment
POTW

POTW
Primary Treatment
Biological Treatment
Primary Treatment
Primary Treatment
 * Range for those nil la where pollutant was detected in influent or effluent.
** Average fur those nilla where pollutant was detected in influent or effluent.

-------
                                                                      TABLE V-31 (Continued)
rv>
I—"
rv>
Total
lumber Of
nf luent
3
3
3
6
12
is 6
3
3
6
3
3
3
3
6
3
15
3
3
3
9
3
3
3
3
Samples
Effluent
3
3
3
6
12
6
3
3
6
3
3
3
--
6
3
15
3
3
--
__
3
3
3
3
Total Nl
Detected
Influent
3
3
3
6
12
6
3
3
6
3
3
3
3
6
3
15
3
3
3
9
3
3
3
0
uber Of
Analyses
Effluent
2
3
3
6
12
6
3
3
6
3
3
3
—
6
3
15
3
3
—
—
3
3
3
0
*Concent rat ion

Range
Influent
10-
14-
6-
17-
2-
4-
60-
< 10
< 10-
32-
72-
<10
720-2
< 10
< 10
<10-
29-
< 10
< 10
90-1
25-
< 10
< 10-
0
54
28
120
300
68
59
100

25
162
110

,600


143
155


,200
170

13

(Mg/D
**Average
Concentration (pg/1)
Effluent
0-
9-
6-
< 1-
<1-
<1-
<2-
< 10
< JO-
40-
170-
<10
—
< 10
< 10
< 10-
< 10-
<10
—
—
25-
<10
<10
0
<10
10
13
10
31
12
31

15
95
200




34
25



190



Influent
37
19
61
78
33
29
81
<10
16
108
88
<10
1,560
< 10
< 10
27
74
<10
<10
368
108
<10
11
0
Effluent
4
10
9
4
13
8
\2
<10
11
72
185
<10
—
< 10
< 10
14
18
<10
--
__
117
<10
<10
0
Comments
Influent/Effluent
Biological Treatment
Primary Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Primary Treatment
Primary w/Holding Pond
Biological Treatment
Biological Treatment
Biological Treatment
Primary Treatment
Biological Treatment
POTW
Biological Treatment
Primary Treatment
Biological Treatment
Primary Treatment
Biological Treatment
POTW
POTW
Primary Treatment
Biological Treatment
Biological Treatment
Primary Treatment
             120. Copper (continued)
                  Nonintegrated-Lightweigtit
                    Papers
                  Nonintegrated-Fi1 let
                    and Nonwoven Papers

                  Nonintegrated-Paperboard
                  Integrated Miscellaneous
                  Nouintegrated Miscellaneous  6
121.  Cyanide
     Seni-Chemical
     Unblejctied  Kraft
       and Semi-Chenical
     Deink
      o Fine I'apprs
      o Tissue Papers

      o Newsprint
     Tissue From Wastepaper

     Paperhujrd  From Wastepaper  IS

     Wast (.'paper-Molded Products

     builders' Paper and
       Roofing Felt

     Nonintegrated-Lightweight
       Papers
     Nonintegrated-Fi Her
       and Nonwovcn Papers
              * Range  for those mills where  pollutant was detected in influent or effluent.
             ** Average for those mills where  pollutant was detected in influent or effluent.

-------
                                                                      TABLE V-31 (Continued)
ro
I—'
CO
Total
Number Of Samples
Toxic Pollutant/Subcatrgory Influent Effluent
121. Cyanide (continued)
Nonintegrated-Paperboard
fnti'grated Miscellaneous
Nun integrated Miscellaneous

1*2. l.ead
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
AJ ka 1 ine-r'ine
Unbleached Kraft
o Linerboard
o Bag
Seai -Chemical
Unbleached Kraft
and Semi-Chemical
Dissolving Sulfite Pulp
Piij>ergrade Sulfite
Groundwootl-Fine Papers
Deink
o Fine Papers
o Tissue Papers

o Newsprint
P P
Paperboard Froi* Wastepaper
Wastepaper-Molded Products

Builders' Paper and
Roofing Felt


6
9
3
6

3
6
9
9

3
6
6

6
12
6

3
3
3
3
£
3
15
3
3

9
3

6
9
3
6

3
6
9
V

3
6
6

6
12
6

3
3
3
-
3
15
3
—

—
3
Total Number Of
Detected Analyses
Influent Effluent

6
9
3
0

3
6
9
9

3
6
6

6
1,
**
12
6

3
3
3
3
3

3
3

9
3

6
9
3
0

3
6
9
9

3
6
6

6
12
6

3
3
3
—
3
15
3
—

--
3
*Concent rat ion ^Average
Range (pg/1) Concentration (|ig/D Comments
Influent Effluent Influent Effluent Influent /Effluent

<10-

-------
                                                                        TABU V-31  (Continued)
ro
t—•
JS»
Total
Number Of Samples
Toxic Pollutant/Subcategory Influent Effluent
122. Lead (continued)
Nonintegrated~f ine Papers

Nonintegrated-TisBue Papers

Nonintegrated-Lighlweight
Papers
Nonin leg rated -Filter
and Nontooveu Papers

Nonin tegrated-Paperboard
Integrated Miscellaneous
Nonintrgrated Miscellaneous

123. Heccury
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine
Unbleached Kraft
o Linerboard
o Bag
Seal -Chemical
Unbleached Kraft
and Semi -Chemical
Dissolving Sulfite Pulp
Papergrade Sulfite
GrounJwoed-Fine Papers
Uciiifc
o Fine Papers
P
o Newsprint
Tissue Fro* Wastepaper


6
3
3
3

3

3
3
6
12
6
3

3
6
9
9

3
6
6

6
4
12
6

3
3
3
3
6

6
3
3
3

3

3
3
6
12
6
3

3
6
9
9

3
6
6

6
4
12
6

3
3
3
--
3
6
Tutsi Number Of
Detected Analyse*
Influent Effluent

6
3
3
3

3

3
3
6
12
6
3

3
6
9
9

3
6
6

6
4
12
6

3
j
3
3
3
6

6
3
3
3

2

3
3
6
12
6
3

3
6
9
9

3
6
6

5
4
12
6

3
3
—
3
6
Concentration **Aver»ge
Range (MS/D Concent rat loo (|i*/D CaaaratB
Influent Effluent Influent Effluent Influent/Effluent

<1-
<1-
<1-
<2-

5-

<1-
1-
<2-9
<1-
<2-
<2-


-------
                                                                      TABLE V-31  (Continued)
PO
I—>
tn
Total Total Number Of
Number Of Samples Detected Analyses
Toxic Pol I ut nut /Subcatcgory Influent Effluent Influent Effluent
123. Mercury (continued)

WdStcpaper-Molded Produt Is

Hu i 1 ders ' Paper and
Roofing Felt

Noii Integra ted- Fine Papers


Nmi i ntegt a ted- Lightweight
Papers
Noiuntegrated-Filter
ami Nonwoven Paper &

Ni>ni ntcgralcd-Papcrboard
1 nL egrated Mi seel laiieous
NOIU n( egrated Miscellaneous

124. Nickel
l)i ssol ving Krai t
Market bleached Kraft
BCT Bl Pitched Kraft
Al kal i ue-Fine
Unbleached Kraft
o Li lit.' rboa rd
o Rag
Se-roi -Oieuica I
Unl-leached Kraft
and St'uti -Cheated!
IH& solving Sul f i te Pulp
Pa|>rrgr<*de Sul f J te
(trouiidwood-Fiiu* Papers
3
15
3
3

3
9
3
6
3
3

3

3
3
6
12
3
6

3
6
9
9

3
6
6

6
4
12
6
3
15
--
3

3
--
3
6
3
3

3

3
3
6
12
3
6

3
6
9
9

3
6
6

6
4
12
6
3
15
3
3

3
9
3
6
3
3

3

3
3
6
12
3
6

3
6
9
9

3
A
6

6
4
12
6

15
—
3

3
--
3
6
3
3

3

3
3
6
12
3
6

3
6
9
9

3
6
6

6
4
12
6
Concentration **Average
Range (pg/1) Concentration (M8/O Commeota
Influent Effluent Influent Effluent Influent/Effluent
<0. 5
<0.5-
<0.5
<0.5

<0.5
<0.5-
<0.5
<0.5-
tft S
vu . j
<0.5

<0.5

<0.5
<0.5
<0.5
<0.5-
<0.5
cO.5-

<2-
16-
<2-
<2-

<2-
<2-
<2-

<2-
8-
3-
<2-

1.0




1.0

0.8







0.6

1.5

8
59
120
33

9
12
22

29
45
48
8
<0. 5
<0.5-
--
<0.5

<0.5
—
<0.5
<0.5-

-------
                                                                        TABLE V-31 (Continued)


                                                   Total           Total Number Of         *Concentration          **Average
                                             Number Of Sample*    Detected Analyses         Range (pg/1)      Concentration (pg/1)        Comnenti
CTi
fox i r f'ol 1 utdnt /Subrj tegory Inf 1 uent
12V Nickel (couL imied)
Dei uk
o fine Papers
o Ti bsue Papers

o Nfw&pr i nt
TisijUf r'rooi Wastepaper

Pnperbo.i rtl from Wastepapor

W.is l epjper -Molded Products

Builder:,' Paper and
Koo f i UK felt

Noiiiiil».>j{r«jleil—iL in*? Pape rs
Non in leg rat ed-Ti ssue Papers

Non integrated- Lightweight
Papers
Won Integra ted- Fi 1 tcr
and Nonwoven Papers

Nun i n i eg rated -Pape rboj rd
Integrated Mi seel laueoti^
Won iiiLtixr<* t ft) Mi ace 1 1 aueous

128. Zinc
DJ ssol vi dg Kraft
rfdrkt/l Bleached Kraft
KCT Bleached Kraft
Al ka I i cic-Fi ne


3
3
3
3
3
6
3
15
3
3
•}
9
3
6
3
3

3

3
3
6
12
3
6

3
6
9
9
Effluent Influent


3
3
3
—
3
6
3
15
--
3
3

6
3
3

3

3
3
6
12
3
6

3
6
9
9


3
3
3
3
3
6
3
15
3
3
•j
9
6
3
3

3

3
3
6
12
3
6

3
6
9
9
Effluent


3
3
3
—
3
6
3
15
—
3
3

3
6
3
3

3

3
3
6
12
3
6

3
6
»
9
Influent


5-
4-
<1-
5-
5-
2-
42-
<2-
<2-
10-
84-
12-
S*)
Vjt
<1-
<2
<2-

<2

< 1

-------
                                                         TABLE  V-31  (Continued)
128.
Total Total Nuiiber Of ^Concentration **Average
Number Of Samples Detected Analyses Range ((Jg/1) Concentration ((JR/1) Comments
r Pollutant/Subcategory Influent Effluent Influent Effluent Influent Effluent Influent Effluent Influent/Effluent
Zinc (continued)
Unbleached Kraft
o Linerhoard
o Bag
Semi-Chemical
Unbleached Kraft
and Semi-Chemical
Dissolving Sulfite Pulp
Papergrade Sulfite
Grnundwood-Fine Papers
Oeink
o Fine Papers
P
o Newsprint
Tissue from Wastepaper

P P P
Wastepaper-Molded Products

Builders' Paper and
Roofing Felt

Noni utegrated-Fine Papers

Nonintegr Jted-Tiasue Papers

Nonintegr Jted-Lightweight
Papers
NOM Integra ted -Fi 1 ter
and Nonwoven Papers

Nouintegrated-Paperboard
Integrated Miscellaneous
Nonintegrated Miscellaneous



3
6
6

6
4
12
6

3
•j
3
3
3
6
IS
3
3

3
9
3
6
3
3

3

3
3
6
12
3
6


3
6
6

6
4
12
6

3
•i
j
3
—
3
6
IS
--
3

3
—
3
6
3
3

3

3
3
6
12
3
6


3
6
6

6
4
12
6

3
•j
3
3
3
6
•t
j
IS
3
3

3
9
3
6
3
3

3

3
3
6
12
3
6


3
6
6

6
4
12
6

3
•j
3
—
3
6
15
—
3

3
—
3
6
3
3

3

3
3
6
12
3
6


37-
41-
78-

24-
42-
5-
53-

97-
1 70-
30-
300-
52-
31-3
1 100-1
26-4
120-
262-

2,500-3
5-2
49-
6-


120
230
230

58
85
150
90

352
260
46
375
59
,560
600
,'720
330
465

,000
,100
91
185
52,000-54,000
46-

12-

11-
118-
72-2
12-
10-
40-3
160

22

15
193
,050
710
48
,840


27-
16-
31-

15-
37-
25-
9-

30-
51-
5-
—
22-
<5-
1 000- 1
40-
--
26-

1,900-2,
—
75-
<3-
60-
19-

0-

9-
40-
<5-
15-1,
1-
<2-l,


100
150
120

46
77
420
86

38
62
36

33
183
Qflfl
7UU
210

73

900

160
35
140
29

8

17
66
210
800
7
000


71
136
143

40
70
104
74

206
200
40
335
54
677
1 433
U206
200
392

2,800
999
71
55
53,300
92

16

13
159
710
259
25
802


67
81
69

25
60
118
45

33
71
19
—
27
88
1 500
113
—
52

2,400
—
118
18
88
23

4

12
56
72
443
3
217


Biological Treatawnt
Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Partial Final Effluent
Biological Treatment
POTW
Primary Treatment
Biological Treatment
Biological Treatment
POTV
Biological Treatment

Primary Treatment
POTW
Primary Treatment
Biological Treatment
Biological Treatment
Primary Treatment

Biological Treatment

Primary Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Primary w/Holding Pond
Primary Treatment
 * Range for those Bills where pollutant wae detected in influent or effluent.
'<* Average for those Bills where pollutant waa detected in influent or effluent.

-------
                                                                                            TABLE V-32
                                                                        SUMMARY OF VERIFrCATION PROGRAM ANALYSIS RESULTS
                                                                                 FOR  NONCONVENT10NAL POLLUTANTS
CD
Total Number
Toxic Pollutant/ of Samples
Subcategory Influrnt Effluent
130. Abietic Acid
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine
Unbleached Kraft
o Llnerboard
o Bag
Sewi-Chenica 1
Unbleached Kraft and
Semi -Chemical
DlssolvinR Sulfile Pulp
Croundwood-Fioe Papers
Dp ink
o Fine Papers
o Newsprint
P
Tissue From Wastepaper

Paperboard From Wastepaper

Wastep.iper-Molded Products

Builders' Paper and
Roofing Felt

3
6
9
9

3
6
6

6
4
1 7
I *
6

3
3
3
6
3
IS
3
3
3

9
3
3
6
9
9

3
6
6

6
k
1 7
1 £
6

3

3
6
3
15
3
3
—

—
3
Total Number of
Detected Analyses
Influent Effluent
3
6
7
6

3
6
3

6
4
g
6

3
3
•i
j
3
4
3
15
3
3
3

9
0
3
3
6
3

2
6
3

6
3
4

2

3
0
3
6
0
1
—

Concent rat ion
Range (pg/1)
Influrnt Effluent
8600-18000
6-
0-
190-

350-
390
2700
1100

1200
3700-12000
220-

650-
94-
0-
11-

700-
2300-
370-
330-
0-
120-
18-
120-
190-
540-

290

2000
5200
4QO
«4VU
600

990
4100
680
740
150
260
1900
710
250
680

loo-:
J500
0-1800
0-
0-

0-
30-
35-

520
11

21
250
43

5SO-1000
0-
g_
0-

0-
50-
40-
0
35-
0-
0
0-
—

940
340
26

31
1 40
90
--
140
96
--
21
—

930-14000 -- --
0
0
—
0
--
Average
Concentration
(MR/D
Influent Effluent
11800
178
1041
470

753
69R3
257

1392
1949
137
182

837
3467
557
513
54
203
651
407
210
6.13

7559
0
1467
767
119
3

10
165
39

710
383
76
7

12
97
72
0
64
19
0
7
--

--
0
                                                                                                                                               Comments
Bio] oft teal TrcHtmrrtl
Biologica 1 Trratmrnl.
Bi olofti ra 1 Trca Lmmt
Biolnftical Trratmmt

Blnlnftical Trfntmont
Biological TrcatmniL
Bi ologi ra1 Trfatmrnt

Biological Treatmrnt
Biologi ca t TrcatmpnL
Birr logical TiTritmpnl
Biologi caI Trent m^nt

Diologi ca1 Treat mrn(
POTW
Partial Final Kffhirnt
Biological Trcalm*'iil
Biological Treatment
Primary TreatrnfTit
Biological Treatment
Primary Treatment
Biologi ca1 Treatment
POTW

POTW
Primary Treatment

-------
TABLE V-32 (Continued)
Total Nunber
Toxic Pollutant/ of Samples
Subrategory Influent Effluent
130. Al.i-tic Acid (continued)
Nonintegrated-Fine Papers
Nonintegrated-Tissue Papers

Integrated Miscellaneous
Nonintegrated Miscellaneous

131. Dehydroahietic Acid
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine
Unbleached Kraft
o Linerboard
o Bag
Semi-Chemical
Unbleached Kraft and
Semi -Chemical
Dissolving .Sulfite Pulp
Papergrade Sulfite
Groundwood-Fine Papers
Deink
o Fine Papers
o Newsprint
P
Tissue From Vastepaper

Paper board From Wastepaper

Wastppaper-Molded Products


6
3
3
12
6
3

6
9
9

3
6
6

6
4
12
6

3
3
3
3
6
3
IS
3
3
3

6
3
3
12
6
3

6
9
9

3
6
6

6
4
12
6

3

3
6
3
15
3
3
--
Total Nunber of
Detected Analyses
Influent Effluent

5
3
0
8
3
0

6
9
6

3
6
6

6
4
12
6

3
3
3
6
3
15
3
3
3

2
Q
0
0
Q
6
1
0
2
6
9
6

3
6
4

6
4
9
6

3
3
3
4
3
12
3
3
—
Concentration
Range (|Jg/l)
Influent Effluent

0-
39-
0
Q_
0-
140-
0
3000-
10-
280-
140-

330-

660
75
i fton
I OUU
4100
240
--
5200
560
1400
430

640
950-27600
79-

230-
190-
2-
28-

1400-
2600-
2200-
1400-
150-
220-
130-
410-
340-
550-
230

1000
1870
1300
360

2900
4800
4700
2400
840
650
920
530
530
620

0- 18
0-. _
0
0
0__
0- 160
0- 24
0
0- 800
2-1000
48- 310
3- 7

6- 15
30- 200
0- 27

200- 330
6- 400
0- 950
10- 50

42- 62
130- 630
180- 300
0- 37
160- 300
0- 140
59- 120
2- 170
--
Averagr
Conrrntrat i on
(PR/I)
Influent Effluent

207
53
0
748
1029
177
0
3500
232
861
273

470
7142
168

607
1000
423
148

2267
3700
3267
1833
372
417
479
467
453
573

6
0
0
Q
61
8
0
520
431
123
5

11
85
14

235
171
246
26

49
343
253
20
250
55
96
61
--
Comments

Bi ol ofti ra 1


Trp.i tmr ill
Prim.iry Treatment
Biological
Biological
Primary Tr
Treatment
Treatment
ratmt-nl
Primary w/Hold J ng Pond

Biological
Biological
Biological

Biological
Biol ogicaj
Biological

Biologi ca 1
B Jolngi raj
Bi ol ogica 1
Bio 1 ogic.i I

Biological

Treatment
Treatment
Treatment

Treatment
Treatment
Treatment

Treatment
Treatment
Treatment
Treatment

Treatment
P01V
Partial Final Ff f 1 unit
Biol ogirfl
RioLogica
Primary T
Biol ogica
Primary T
Biolog jca
POTW
Treatment
Treatment
eat men t
Treatment
eatnent
Treatment


-------
                                                                                 TABLE V-32 (Continued)
                                                                                                                        Average
ro
ro
O
Total Kiaaber
Toxic Pollutant/ of Smmplem
Subcategory Influent Effluent
Total Nuajber of
Detected Analyaea
Inflaent Effluent
Concentration Concentration
Range (pg/1) (pg/1)
Influent Effluent Influent Effluent
Coaacenta
131. Dehydroabietic Acid (continued)
Builder*' Paper and
Roofing Felt

Nonintegrated-Fine Papera

Nonlntegrated-Tlsaue Papera

Nonlntegrated-Fllter
and Nonvoven Papera

Nonlntegrated-Paperboard
Integrated Miscellaneous

132. laoplaurlc Acid
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine
Unbleached Kraft
o Llncrboard
o Bag
Seni-Cheailcal
Unbleached Kraft and
Seaii-Chediral
Dissolving Sulflte Pulp
Papergrade Sulfite
Groundwood-Flne Papera
Deink
o Fine Papera
o Newsprint
o Tisaue Papers

9
3
6
3
3
3

3
3
6
12
g
3

3
6
9
9

3
6
6

6
4
12
6

3
3
3
3
—
3
6
3
3
3

3
3
6
12
3

3
6
9
9

3
6
6

6
4
12
6

3
—
3
3
9
3
6
3
3
0

2
0
6
10
£
3

3
3
8
6

3
6
6

6
4
6
4

3
3
3
3
--
3
6
3
3
0

0
0
4
9
4
3

3
3
7
3

2
3
3

6
3
7
5

3
—
3
3
670-
110-
58-
160-
190-
0

0-
0
110-
0-
2_
10-

660-
66-
0-
54-

78-
380-
23-

260-
15-
0-
0-

420-
240-
J10-
120-
6000
170
720
660
230
—

50
—
780
2000
400
^uv
16

1300
180
250
110

450
160O
48

850
1760
230
110

900
690
180
270
—
60-
17-
49-
85-
0

0
0
0-
0-
0-
160-

160-
230-
0-
0-

0-
0-
0-

140-
0-
0-
0-

1-
—
14-
1-
--
200
66
ISO
112
—

—
—
180
310
220
270

590
500
86
3

10
32
16

260
230
84
6

9
—
24
20
2199
143
433
483
213
0

33
0
413
585
14

887
115
107
74

283
770
34

547
774
62
29

587
510
150
193
—
117
45
93
98
0

0
0
64
96
67
Of
200

380
407
21
1

6
15
7

187
115
17
3

5
—
18
13
POTV
Primary Treatawnt
Biological Treatment
Prlauiry Treatawnt
Primary TreaUwnt
Biological Treatment

Biological Treatment
Priaury Treatawnt
Biological Treatawnt
Biological Treatawnt
Priawry TreataKnt
Priaury w/Holdlng Pond

Biological Treatment
Biological Treatawnt
Biological Treatawnt
Biological Treatawnt

Biological Treatawnt
Biological Treatawnt
Biological Treatawnt

Biological Treatment
Biological Treataient
Biological Treatawnt
Biological Treatment

Biological Treataient
POTV
Partial Final Effluent
Biological Treatawnt

-------
                                                                                   TABIX V-32  (Continued)
ro
ro
Total Number
Toxic Pollutant/ of Samples
Subcategory Influent Effluent
132. Isopimaric Acid (continued)

Paperboard From Wastepaper

Wastepaper-Molded Products

Builders' Paper and
Roofing Felt

Nonintegrated-Fine Paper*

Nonintegrated-Tissue Papers

Non Integra ted- Paperboard
Integrated Miscellaneous
Nonintegrated Miscel laneous

133. Pimaric Acid
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Finn
Unbleached Kraft
o Linerboard
o Bag
Semi -Chemical
Unhlcarhed Kraft and
Semi -Chemical
Dissolving Sulfite Pulp
Papergrade Sulfitc
Groundwood-Fine Papers
6
3
IS
3
3
3

9
3
6
3
3
3
6
12
6
3

3
6
9
9

3
6
6

6
4
12
6
£
3
IS
3
3
—

—
3
6
3
3
3
6
12
6
3

3
6
9
9

3
6
6

6
4
12
6
Total Nunher of
Detected Analyses
Influent Effluent
3
3
IS
3
3
3

9
0
6
0
3
0
6
8
3
0

3
3
7
6

3
6
4

6
3
2
3
o
0
4
1
0
—

—
0
0
0
1
0
0
6
2
0

3
3
6
0

1
6
2

6
3
1
1
Concentration
Range (pg/1)
Influent Effluent
21-
13-
12-
65-
41-
80-

160-
0
8-
0
23-
0
8-
0-
69-
0

970-
120-
0-
20-

38-
420-
0-

37-
180-
0-
31-
43
45
600
100
56
120

3000
—
140
—
46
—
190
1400
110
—

1900
200
350
93

51
2500
130

370
450
64
150
Q
0
0-
0-
0
—

—
0
0
0
0-
0
0
0-
0-
0

620-
320-
0-
0

0-
10-
0-

39-
20-
0-
0-

—
15
23
—
--

—
—
—
—
6
—
—
77
22
—

790
530
74
--

3
60
13

190
38
52
15
Average
Concentration
(MR/D
Influent Effluent
32
28
128
84
48
94

1164
0
39
0
37
0
62
374
84
0

1357
157
115
63

43
1168
36

152
277
25
76
Q
0
3
8
0
—

—
0
0
0
2
0
0
31
11
0

710
430
22
0

1
32
4

106
31
17
5
Contents

Primary Treatment
Biological Treatment
Primary Trearsient
Biological Treatment
POTW

POTW
Prfwary Treatjvent
Biological Treatment
Primary Treatment
Primary Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Primary Treatment
Primary w/Holding Pond

Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment

-------
                                                                                    TABLE  V-32  (Continued)
                                                                                                                            Average
IN)
IN)
FN)
Total Number
Toxic Pollutant/ of Samples
Suhcategory Influent Effluent
133. Pim.iric Acid (continued)
Deink
o Fine Papers
o New.sprint
o Tissue Pjpers

Tissue From Wastepaper

P.iperboard From Wastepaper

Wast epapcr-Mo Ided Products

Builders' Paper and
Roofing Felt

8 P
Nonintegrated-Tiiisue Papers

Nonintegrated-Paperhoard
Integrated Miscellaneous
Nonintegrated Mi seel Iflneous

134. Oleir Acid
Dissolving Kraft
Market Blenched Kraft
BCT Bleached Kraft
Al ka I ine-Fine
Unbleached Kraft
o Linerboard
o Ba8
Semi -Chemira 1
Unbleached Kraft and
Semi -Chemical


3
3
3
3
6
3
15
3
3
3

9
3
6
3
3
3
6
12
6
3

3
6
9
9

3
6
6

6


3
--
3
3
6
3
15
3
3
—

--
3
6
3
3
3
A
12
6
3

3
6
9
9

3
6
6

6
Total Number of
Detected Analyses
Influent Effluent


3
3
3
3
3
3
11
3
3
0

9
0
5
0
2
0
3
4
3
0

3
6
7
6

3
6
6

6


0
--
0
0
0
0
0
0
0
—

—
0
o
0
0
0
0
4
0
0

2
6
4
6

3
3
4

6
Concentration
Range (pg/1)
Influent Effluent


92-
220-
31-
36-
2-
19-
0-
35-
48-
0

130-
0
0-
0
0-
0
22-
0-
40-
0

3000-
250-
0-
16-

160-
1700-
21-

210-


160
310
52
160
18
78
210
48
64
—

1600
40

15
—
29
1300
65
--

4500
520
2900
970

500
6700
200

1200


0
—
0
0
0
0
0
0
0
--

—
0
o
0
0
0
0
0-
0
0

0-
22-
0-
15-

4-
0-
0-

130-


—
--
--
—
--
--
--
—
--
--

—
—
--
--
—
--
48
—
--

810
250
92
130

65
150
56

800
Concentration
(pg/D
Influent Effluent


127
257
39
80
12
43
78
41
57
0

576
0
19
0
10
0
25
184
54
0

3667
345
1084
276

337
3133
115

618


0
--
0
0
0
0
0
0
0
--

—
0
o
0
0
0
0
25
0
0

333
153
17
41

38
70
33

407
                                                                                                                                             Comments
Biological Treatment
I'OTW
Partial Final Kffluent
Biological Treatment
Biological Treatment
Primary Treatment
Biological Treatment
Primary Treatment
Biological Treatment
POTW

POTW
Primary Treatment
Biological Treatment
Primary Treatment
Primary Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Primary Treatment
Primary w/llolding Pond
                                                                                                                                             Biological Treatment
                                                                                                                                             Biological Treatment
                                                                                                                                             Biological Treatment
                                                                                                                                             Biological Treatment

                                                                                                                                             Biological Treatment
                                                                                                                                             Biological Treatment
                                                                                                                                             Biological Treatment

                                                                                                                                             Biological Treatment

-------
                                                                                   TABI.E V-32  (Continued)
to
Total Nuaber
Toxic Pollutant/ of Saaples
Subcategory Influent Effluent
134. Oleic Acid (continued)
Dissolving Sulfite Pulp
Papergrade Sulfite
Croundvood-Fine Papera
Defnk
o Fine Papers
o Newsprint
o Tissue Papers

Tissue Fro* Wastepaper

Paperboard Fro* Wastepaper

Wastopaper-Molded Products

Builders' Paper and
Roofing Felt

Nonintegrated-Ftne Papers

Nonintegrated-Tissue Papers

NonintPgrated-Paperboard
Integrated Miscellaneous
Nonintegrated Miscellaneous

135. Linoleic Arid
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine
Unbleached Kraft
o Linerboard
o Bag
Semi -Cheni cal

4
12
6

3
3
3
3
6
3
IS
3
3
3

9
3
6
3
3
3
6
12
6
3

3
6
9
9

3
6
6

4
12
6

3
--
3
3
6
3
15
3
3
--

--
3
6
3
3
3
6
12
6
3

3
6
9
9

3
6
6
Total Number of
Detected Analyses
Influent Effluent

It
12
6

3
3
3
3
6
3
15
3
3
3

9
0
3
0
3
3
3
11
3
0

3
6
6
3

3
6
3

4
9
4

3
—
3
3
5
1
10
0
3
—

--
0
0
0
2
2
0
5
2
0

1
6
0
3

0
0
3
Concentration
Range (pg/1)
lufluent Effluent

28-
14-
17-

500-
1300-
190-
310-
98-
81-
34-
180-
460-
340-

830-
0
55-
0
210-
4-
2SO-
0-
48-
0

2200-
220-
180-
170-

150-
610-
66-

1860
330
450

1200
1500
710
560
270
200
940
450
540
360

3500
--
80
--
290
29
270
1900
68
—

3900
2300
1300
470

270
1700
160

31-
0-
0-

30-
—
470-
220-
0-
0-
0-
0
5-
—

--
0
0
0
0-
0-
0
0-
0-
0

0-
26-
0
2-

0
0
13-

120
220
46

75
--
750
280
310
74
310
--
80
--

—
—
--
--
61
47
--
230
13
--

510
100
--
7

--
—
17
Average
Concentration
(ug/1)
Influent Kffluent

1157
129
174

967
1367
400
410
183
147
339
290
49.1
353

2237
0
65
0
260
13
260
450
55
0

2900
792
762
283

203
958
122

81
70
23

49
--
590
243
193
25
78
0
48
--

—
0
0
0
27
27
0
38
8
0

170
64
0
4

0
0
14
                                                                                                                                            Comments
Biological Treatment
Biological Treatment
Blologi CJtl Treatment

Biological Treatment
POTW
Partial Final Effluent
Biological Treatment
Biological Treatment
Primary Treatment
BiologicaI Treatment
Primary Treatment
Biological Treatment
POTW

POTW
Primary Treatment
Biologica1 Treatment
Primary Treatment
Pr imary Treatment
Bio Iogical Treatment
Bio logical Treatment
Biological Treatment
Primary Treatment
Primary w/HoIding Pond
                                                                                                                                            Biological Treatment
                                                                                                                                            Biological Treatment
                                                                                                                                            Rio]ogical Treatment
                                                                                                                                            Biological Treatment

                                                                                                                                            Biological Treatment
                                                                                                                                            BiologicaI Treatment
                                                                                                                                            Biologteal Treatment

-------
                                                                                    TABLE V-32 (Continued)
ro
ro
-fc.
Total Nwber
Toxic
Pollutant/
of
Saaples
Subcategory Influent Effluent
135.
























136.







Linoleir Arid (continued)
Unbleached Kraft and
Sesii-ChesUcal
Dissolving Sulfite Pulp
Papergrade Sulfite
Groundwood-Fine Papers
Deink
o Fine Papers
o Newsprint
o Tissue Papers

Paperhoard Fro* Wastepaper

Vastepaper Molded Products

Builders' Paper and
Roofing Felt

Nonintegrated-Fine Papers

Nonintegrated-Filter
and Nonwoven Papers
Integrated Miscellaneous
Nonlntegrated Miscellaneous

Linolenic Acid
Market Bleached Kraft
Alkaline-Fine
Unbleached Kraft
o Bag
Smi-Chenical
Papergr/ide Sulfite
Groundwood-Fine Papers


6
It
12
6

3
3
3
3
15
3
3
3

9
3
6
3

3
12
6
3

6
9

6
6
12
6


6
4
12
6

3
—
3
3
15
3
3
—

--
3
6
3

3
12
6
3

6
9

6
6
12
6
Total Nueber of
Detected
Influent


6
3
9
3

3
3
3
3
5
0
3
3

8
0
1
0

0
7
2
0

3
3

3
3
5
3
Analyses
Effluent


3
1
4
3

0
--
0
0
0
0
0
—

—
0
0
0

1
1
0
0

3
0

0
3
0
0
                                                                                               Concentration
                                                                                                Range  
-------
                                                                                   TABLE V-32  (Continued)
               Toxic Pollutant/
                 Subcatcgo ry_	
ro
ro
en
136.  Linolenic Acid (continued)
     Deink
      o Fine Papera
      o Newsprint
     Paperboard From Wastepaper

     Builders' Paper and
       Roofing Felt
137.  Epoxystearic Acid
     Dissolving Kraft
     Unbleached Kraft and
       Semi-Chemical
     Papergrade Sulfite
     Paperboard From Wastepaper
139.  Chlorpdehydroabietic Acid
     Dissolving Kraft
     Market Bleached Kraft
     BCT Bleached Kraft
     Alkaline-Fine
     Semi-Chemical
     Dissolving Sulfite Pulp
     Papergrade Sulfite
     Deink
      o Fine Papers
      o Tissue Papers

     Integrated Miscellaneous
 Total Number of
Detected Analyses
Influent  Effluent
                                                                               Concentrat ion
                                                                                Range  (pg/1)
                                                                              Influent      Effluent
                                                                                                           Average
                                                                                                         Concentration
                                                                                                             (MK/1)
                                                                                                      Influent   Effluent
                                                                                                                         212
                                                                                                                        <167
                                                                                                                          69
                                                                                                                          0

                                                                                                                         138
                                                                                                                          0
                                                                                                                         817
                                                                                                                                    99
                                                                                                                            Biological Treatment
                                                                                                                            POTW
                                                                                                                            Biologic.il Treatment
                                                                                                                            Primary Treatment

                                                                                                                            POTW
                                                                                                                            Primary Treatment
                                                                                                                                            Biological  Treatment
6
12
15
3
3
6
9
9
6
A
12
3
3
3
12
6
12
15
3
3
6
9
9
6
4
12
3
3
3
12
3
1
3
0
3
A
5
0
A
6
3
3
0
A
2
1
0
0
3
3
5
3
3
3
0
2
0
1
99-
0-
310-
0
1300-
0-
0-
2-
0
45-
8-
330-
18-
0
0-
380
120
490
~~
1600
120
190
9 /.n.
«i*»U
360
3AO
730
28
--
8A
0-
0-
0
0
330-
0-
0-
3-
0-
0-
0
0-
0
0-
190
20
--
— —
700
140
31
18
241
93
__
26
--
3
266
40
413
0
1433
5U
78
A A
0
161
123
467
24
0
33
113
7
0
0
473
A2
11
9
108
39
0
14
0
1
Biolog1c.il
Rio) ogi cal
Biologj cal
Treatment
Treatment
Treatment
Primary Treatment
Biological
Biologj ca 1
Biological
Bio log! cal
Biological
Biological
Biological
Treatment
Treatment
Treatment
Treatment
Tre.itmrnt
Treatment
Treatment
Partial Final Effluent
Biologica 1
Biological
Treatment
Treatment

-------
                                                                                      TABLK V-32 (Continued)
                                                                                                                             Average
ro
f\3
Total Rusher
Toxic Pollutant/ of Samples
Subcategory Influent Effluent
140.









141.







142.






143.





Total Nixber of
Detected Analyses
Influent Effluent
Concentration Concentration
Range (jlg/D (M«/D
Influent Effluent Influent Effluent
Cossaents

Dlchlorodehydroabietic Acid
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine
Sen! -Chemical
Dissolving Sulfite Pulp
Papergrade Sulfite
Deink
o Fine Papers
Integrated Miscellaneous
Trichloroguaiacol
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine
Dissolving Sulfite Pulp
Papergrade Sulfite
Deink
o Fine Papers
Tetrachlorogualacol
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine
Dissolving Sulfite Pulp
Deink
o Fine Papers
Xylenes
Alkaline-Fine
Unbleached Kraft
o Linerboard
o Bag
Semi-Chemical
6
9
9
6
4
12

3
12

6
9
9
4
12

3

6
9
9
4
12

3

9

3
6
6
6
9
9
6
4
12

3
12

6
9
9
4
12

3

6
9
9
4
12

3

9

3
6
6
3
2
2
0
1
3

2
1

3
1
4
1
3

2

6
6
9
1
]

3

2

3
3
2
3
1
0
2
0
1

0
0

0
0
1
0
2

3

0
1
5
1
0

3

0

0
0
3
30-
0-
0-
0
0-
0-

0-
0-

15-
0-
0-
6
2-

0-

4-
2-
4-
4
0-

4-

0-

22-
B-
0-
86
IS
32
—
280
5

12
5

21
1
9
—
6

28

23
17
17
2

16

8

44
10
4
11-
0-
0
0-
0
0-

0
0

0
0
0-
0
0-

10-

0
0-
0-
2
o

6-

0

0
0
1-
65
4
—
30
—
3

—
--

—
—
2
—
3

17

—
1
8
—

13

—

—
—
3
57
3
6
0
93
2

6
2

18
1
4
6
4

14

11
8
7
4
1

8

4

33
9
2
39
1
0
13
0
1

0
0

0
0
1
0
2

14

0
1
3
2
0

9

0

0
0
2
Biologica
Biologic*
Biologica
Biologica
Biologica
Biologica

Biological
Biological

Biological
Biological
Biological
Biological
Biological

Biological

Biological
Biological
Biological
Biological
Biological

Biological

Biological

Biological
Biological
Biological
Treatment
Treatment
Treatment
Treatment
Treatawnt
Treatatent

Treatment
Treatment

Treatment
Treatment
Treatment
Treatment
Treatment

Treatment

Treatawnt
Treatment
Treatment
Treatment
Treatment

Treatment

Treatment

Treatment
Treatment
Treatment

-------
                                                                                   TABLE V-32 (Continued)
ro
rv>
Total Number
Toxic Pollutant/ of Samples
Subcategory Influent Effluent
163. Xylenes (continued)
Unbleached Kraft and
Semi-Chemical
Papergrade Sulfite
Deink
o Fine Papers
o Newsprint
o Tissue Papers


Paperboard From Wastepaper

Builders' Paper and
Roofing Felt

P
Nonintegrated-I.ightveight
Papers
Integrated Hiscel laneous
Nonintegrated Miscellaneous

149. Color
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
AlkaJ ine-Fine
Unbleached Kraft
o Linerboard
o Bag
Semi-Chemical


6
12

3
3
3
3
D
3
15
3

9
3
3
3

3
D
12
6
3


6
12

3
—
3
3
6
3
15
3

—
3
3
3

3
D
12
6
3
Total Number of
Detected Analyses
Influent Effluent


3
3

1
3
2
0
3
1
S
1

9
2
3
0

2
3
7
3
0


0
0

0
—
0
0
]
0
0
0

--
2
3
0

0
3
1
3
0
Concentration
Range (|Jg/l)
Influent Effluent


19-
0-

0-
5-
0-
0
0-
0-
0-
0-

3-


27
4

20
110
9
140
31
6
3

63
0- 28
140-37000
0

0-
5.
0-
7-
0

8
14
160
10
--


0
0

0
— —
0
0
0- 1 3
0
0
0

—
0- 32
160- 1600
0

0
1 - 4
0- 4
6- 340
0
(Platinum Cobalt Units)
3
6
9
9

3
6
6
3
6
9
9

3
6
6
3
6
9
9

3
6
6
3
6
9
9

3
6
6
1086-
1420-
875-
630-

70-
340-
1820-
2220
1920
2030
1210

290
1900
8000
935-1326
1310-1920
1340-2040
430-1380

190- 240
350-2400
2350-6400
Average
Concentration
(M«/n
Influent Effluent Cements


22
1

7
46
5
0
28
10
3
1

18
14
13547
0

5
g
23
9
0
(Platinum
1475
1680
1233
850

173
1130
3915


0
0

0
0
0
0
2
0
0
0

—
16
800
0

0
3
1
147
0
Cobalt
1160
1597
1610
826

213
1208
3825


Biological Treatment
Biological Treatment

Biological Treatment
POTW
Biological Treatment
Partial Final Kffluent
Primary Treatment
Biological Treatment
Primary Treatment

POTW
Primary Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Primary Treatment
Primary w/Holding Pond
Units)
Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment

-------
                                                                                    TABIK V-.12 (Continued)
                                  Total  Number
'Ionic Pollutant/                   of Samples
  Subcategory _      	Infjuent_ EffJLuenlL
                                                                                                                            Average
                                                                    Total Ntiaiber  of              Concentration           Concentration
                                                                   Detected Analyses       (PUtinuw Cobalt Units)  (Platimni Cobalt Units)
                                                                   Influent  Effluent        Influent      Effluent   Influent   Effluent   Com»ent«
ro
r\3
CO
Col or (font i nupfJ)
Utthlearhr*) Kraft andl
Semi -thrmjc.il
Dissolving Sulfite Pulp
Piiprrgradc Su I f i t«?
Cronndwood-Fine Papers
DP ink
o Fine Papers
*i Newsprint
o Tissue Papers


Paprrboard Fro* Wastepaper
Was lepaper -Molded Products

Bui Iders ' Paper
and Pooling Felt

Noni ntegr s* ted-Fine Papers

Nan integrsted-TttiSue Papers

Non integrated -Light weight
Papers
and Nonwoven Paper*

Honintegrated-Paperboard

Non i ntCK rated H in eel I jineous


6
4
12
6

3
3
3
3
6
3
15
3
3

9
3
6
3
3
3

3
3
3
6
12

3


6
4
12
6

3
—
3
3
6
3
IS
3
3
—

—
3
6
3
3
3

3
3
3
6
12

3


6
4
12
6

3
3
3
3
3
15
3
3
3

9
3
6
3
3
3

3
3
3
6
12

3


6
4
12
6

3
—
3
3
3
15
3
—

—
3
6
3
3
3

2
3
3
5
12

3


200-
1070-
14-
<5-

48-
160-
210-
<5
5-
950-
82-
<5-

370-
7600-
<5
48-
<5

-------
TABLE V-32 (Continued)
Total Nunher
Toxic Pollutant/ of Samples
Subcalegory Influent Effluent
150. Ammonia
Dissolving Sulfite Pulp
Papergrade Sulfite
111. COD
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine
Unbleached Kraft
o Linerboard
o Bag
Semi -Chemical
Unbleached Kraft and
Semi-Chemical
Dissolving Sulfite Pulp
Papergrade Sulfite
Croundvood-Fine Papers
Deink
o Fine Papers
o Newsprint
o Tissue Papers

Tissue From Vastepaper

Faperboard Fro* Vastepaper

Wastrpaper-Holded Products

Builders' Paper
and Roofing Felt

Nonintegrated-Fine Papers


Total Number of
Detected Analyses
Influent Effluent
Concentration
Range
Influent Effluent
(isg/1)
4
12

2
6
9
9

3
6
6

6
4
12
6

3
3
3
3
6
3
14
3
3
3

8
3
6
3
3
4
12

3
6
9
9

3
6
6

6
4
12
6

3
—
3
3
5
3
15
3
3
—

—
3
6
3
3
3
2

2
6
9
9

3
6
6

6
4
12
6

3
3
3
3
6
3
14
3
3
3

8
3
6
3
3
3
3

3
6
9
9

3
6
6

6
4
12
6

3
—
3
3
5
3
15
3
3
—

—
3
6
3
3
6.2- 24.3
0- 260

1290- 1510
530- 920
300- 1270
400- 820

550- 670
590- 1840
1940- 2820

648- 1296
1744- 3170
780- 8700
450- 1020

700- 2850
1980- 4720
1700- 2400
370- 512
230- 500
160- 250
164- 6400
8440- 9060
262- 346
560- 880

2560- 5120
11800-19500
87- 220
254- 763
16~ 20
26- 666
3.45- 9.5
6.8- 48

330- 780
370- 440
290- 470
110- 310

220- 490
345-1000
1055-1930

80- 464
1040-2170
690-2370
77- 200

50- 260
--
360- 500
77- 87
170- 220
110- 156
5- 540
2980-8320
66- 101
—

—
16100-24300
73- 110
22- 26
85- 110
102- 142
Average
Concentration
Influent Effluent
CoMments
(mg/1)
12
105

1400
735
765
576

617
1113
2410

897
2251
4901
625

1600
3733
2063
435
363
190
1333
8833
291
693

3923
16667
168
437
18
399
7
21

497
407
397
244

310
663
1493

310
1404
1342
136

170
—
430
82
192
131
201
4797
82
—

—
19133
87
25
95
119
Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
Biological Treatment
Biological Treatment
Biological Treatment

Biological Treatment
POTW
Partial Final Effluent
Biological Treatment
Biological Treatment
Primary Treatment
Biological Treatment
Primary Treatment
Biological Treatment
POTW

POTW
Primary Treatment
Biological Treatment
Primary Treatment
Biological Treatment
Primary Treatment

-------
                                                                                  TABLE V-32  (Continued)
                                                                                                                         Average
Total Number
Toxic Pollutant/ of Samples
Subcategory Influent Effluent
151. COD (continued)
Non Integra ted-Lightveight
Papem
Nonintegrated-Filter
and Nonwoven Papers

Nonintpgrated-Paperboard
Integrated Miscel laneoun
Nonint.egratcd Miscel laneous



3

3
3
6
12
6
3


3

3
3
6
12
6
3
Total Number of
Detected Analyses
Influent Effluent


3

3
3
6
12
6
3


3

3
3
6
12
6
3
Concentration Concentration
Range (mg/1) (»g/D
Influent Effluent Influent Effluent


230-

77-
230-
<5-
uo-
125-
130-


475

136
250
370
2240
230
810


45-

13-
40-
12-
92-
28-
81-


90

57
56
97
590
80
98


313

104
240
203
848
184
493


69

28
49
46
255
48
89
Coanents


Biological Treatment

Prinary Treatment
Biological Treatment
Biological Treatment
Biological Treatment
Primary Treatment
Primary "/Holding Pond
no
CO
o

-------
                                                                                        TABLE V-33

                                                                   SUMMARY OF  LONG-TERM SAMPLING PROGRAM ANALYSIS  RESULTS
                                                                                    FOR TOXIC POLLUTAKTS
ro
CO
                                          Total Nuaber of Samples
     Total Number
of Detected Analyses	      Concentration Range(pg/1)
A^era^c Concent rat ion(pg/l)
              21.
              22.
              31.
              64.
Toxic
jtant/Subcategory
2 , 4,6-Trichlorophenol
Fine Bleached Kraft
Deink-Tiasue Papers
Chloroform
Fine Bleached Kraft
Deink-Tiasue Papers
2,4-Dichlorophenol
Fine Bleached Kraft
Deink-Tiasue Papers
Pentachlorophenol
Fine Bleached Kraft
PCB-1242
Deink-Tissue Papera
Raw
Waste*

0
23

0
23

0
23

0

23
Secondary
Influent*

23
19

23
19

23
19

23

19
Final
Effluent**

69
69

69
69

69
69

69
69

69
Raw
Waste

—
22

—
23

—
18



23
Seconday
Influent

13
IB

23
19

2
4

6
16

19
Final
Effluent

63
59

69
69

4
9

15
42

69
Raw
Waste

—
0-16

—
19-600

—
0-6

0-13

2.0-77
Second*/
Influent

0-5
0-15

227-772
60-800

0-1
0-2

0-11
0- 1 2

.0 0.6-9.6
final
Effluent

0-6
0-22

21-230
10-61

0-2
0-8

0-7
0-23

0.2-1.9
Raw
Waste

--
K.H

--
273

—
1.8

4 8

21.3
Secondly
Influent

1.8
8.4

404
262

0.1
0.4

1.2
3 8

3.8
Kinal
F.ff luei

2.7
3.7

58
:>2

0. 1
0.4

O.S
^ ^

0.8
               *72-hour composite samples
              **24-hour composite samples

-------
                                                                                            TABLE V-34
                                                                     SUMHARY  OF  LONC-TF.RH SAMPLING PROGRAM ANALYSIS RESULTS
                                                                                  FOR  NONCONVENTIONAL POLLUTANTS
                                                                                    Total  Number
ro
CO
ro

Toxic
Pol lutant/Subcategory
130. Abietic Acid
Fine Bleached Kraft
Deink-Tiasue Papers
131. Dehydroabietic Acid
Fine Blearhed Kraft
Deink-Tiasue Papers
132. Isnpinaric Acid
Fine Bleached Kraft
133. Pimaric Acid
Fine Bleached Kraft
Deink-Tissue Papers
1.34. Oleic Acid
Fine Bleached Kraft
Deink-Tissue Papers
135. Linoleic Acid
Fine Bleached Kraft
Deink-Tissue Papers
1.36. Linolenic Acid
Fine Blearhed Kraft
Deink-Tissue Papers
137. Epoxystraric Acid
Fine Bleached Kraft
138. DlchloroRtearic Acid
Fine Blearhed Kraft
139. Nonochlorodehydro-
abietic Acid
Fine Bleached Kraft
Deink-Tissue Papers
Total
Raw
Waste*

—
3

—
3



—
3

—
3

—
3

--
3






--
3
Number of
Secondary
Influent*

23
1

23
1

23

23
1

23
1

23
1

23
1

10

23


23
1
Sasiples
Final
Effluent**

69
11

69
11

69

69
11

69
11

69
11

69
11

30

69


69
11
of
Raw
Waste

—
3

—
3

3

—
2

—
1

—
3

—
1

3




--
1
Detected Anal
Seconday
yses
Final
Influent Effluent

23
1

23
1

23

21
0

19
0

23
I

3
0

10
o

20


19
0

59
0

55
7

61

25
2

44
1

55
0

2
1

18

44


25
0
Concentration Range (px/1)
Raw
Waste

--
55-156

--
180-405



--
0-13

—
0-322

—
120-286

--
0-90

1 1 -44




--
0-14
Seconday
Influent

200-12,000
34

12-1,800
275

140-4,900

0-530
0

0-6,700
0

390-12,000
49

0-480
0

85-490

0-640


0-217
0
Final
Effluent

0-8,000
0

0-1,300
0-16

0-3, "00

0-370
0-11

0-3,700
0-8

0-3,900
0

0-25
0-10

0-63

0-125


0-110
0
Average
Raw
Waste

--
110

--
291

36

--
4.3

--
107

--
187

--
30

26

A 3


--
4.7
Concentr
Seconday
Influent

1,890
34

259
275

775

70
0

1 , 1 30
0

2, 160
49

50
0

208
Q

175


66
0
                                                                                                                                                                   2''8
                                                                                                                                                                     U
                                                                                                                                                                    '17
                                                                                                                                                                     <•-,
                                                                                                                                                                   154
                                                                                                                                                                   0.5
                                                                                                                                                                    II
                                                                                                                                                                   1.4
119
0.7
                                                                                                                                                                   108
                                                                                                                                                                     0
                                                                                                                                                                   0.6
                                                                                                                                                                   0.9
                                                                                                                                                                   9. 7
                                                                                                                                                                   0.1
                                                                                                                                                                    19
                                                                                                                                                                    1.1
                 "v72-hour composite samp]en
                **24-hour composite samples

-------
                                                                     TABLE V-34 (Continued)
                           _Totaj Number of Sample s
     Total Number
of Detected Analyses
Concentration Range(pg/1)
Average Conmit ration(pg/l )

Toxic
Raw
Pollutant/Subcategory Waste*
140.



141.



142.


153.


154.
ro
oo
to
155.


156.


157.


158.


161.


162.


Dichlorodehydro-
abietic Acid
Fine Bleached Kraft
Deink-Tissue Papers
3,4,5-Trichloro-
guaiacol
Fine Bleached Kraft
Deink-Tissue Papers
Tetrachloroguaiacol
Fine Bleached Kraft
Deink-Tissue Papers
Palustric Acid
Fine Bleached Kraft
Deink-Tissue Papers
Levopi marie Acid
Fine Bleached Kraft
Deink-Tissue Papers
4,5,6-Trichloroguaicol
Fine Bleached Kraft
Deink-Tissue Papers
Keoabietic Acid
Fine Bleached Kraft
Deink-Tissue Papers
4,5-Dlchloroguaiacol
Fine Bleached Kraft
Deink-Tissue Papers
Sandaracopimaric Arid
Fine Bleached Kraft
Deink-Tissue Papers
2,4,5-Trichlorophenol
Fine Bleached Kraft
Deink-Tissue Papers
Dimethyl Sulfide
Fine Bleached Kraft
Deink-Tissue Papers


--
3


--
3

—
3

--
3

--
3

--
3

--
3

--
3

—
3

--
23

--
3
Secondary
Influent*


23
1


23
1

23
1

23
1

23
1

23
1

23
1

23
1

23
1

23
19

23
1
Final
Effluent**


69
11


69
11

69
11

69
11

69
11

69
11

69
11

69
11

69
11

69
69

69
11
Raw
Waste


--
0


--
0

—
0

--
3

--
1

--
0

--
0

—
0

—
1

—
1

--
0
Seconday
Influent


13
0


5
0

3
0

12
1

0
0

0
0

16
0

2
0

19
0

0
1

23
0
Final
Effluent


24
0


19
0

13
0

27
0

2
0

1
0

35
0

0
0

27
0

0
5

45
0
Raw Seconday
Waste Influent


0-41
0 0


0-4
0 0

0-2
0 0

0-1,800
20-59 17

0
0-37 0

0
0 0

0-5,200
0 0

0-1
0 0

0-690
0-44 0

0
0-11 0-10

448-3,740
0 0
Final
Effluent


0-33
0


0-7
0

0-6
0

0-1,100
0

0-66
0

0-2
0

0-3,000
0

0
0

0-570
0

0
0-8.4

0-230
0
Raw Secomlny
Waste Influent


9.6
0 0


0.6
0 0

0.2
0 0

170
39 17

0
12 0

0
0 0

818
0 0

0
0 0

125
15 0

0
0.5 0.5

1,370
0 0
Final
EffJuer


2.6
0


0.7
0

0.3
0

2r>
0

1 .5
0

0
0


0

0
0

17
0

0
0.3

r>5
0
 *72-hour composite samples
**24-hour composite samples

-------
                                                                                   TABLE  V-34 (Continue.!)
                       Toxic
              P°llutant^Subcategpry	

              163.  Dimethyl  Dinulfirte
                   Fine Bleached  Kraft
                   Deink-TiRsuo  Papers
              ^72-hour  coraponite  samples
             •^''ZA-hour  composite  sample*
  Total Nuaber of Sa«ple«	
 Raw    Secondary   Final
Waste*  Influent*  Effluent**
                   Total Number
          	of Detected Analyila
           Raw    Secondly    Final
          Waste   Influent   Effluent
            23
             1
69
11
21
 0
                     Concentration Range(Mg/11_
                     Raw    Seconiiay    Final
                    Waste   Influent   Effluent
38-1,800
   0
0-13
  0
                       Average Coocentratjon(pg/1)
                        Raw    Seconriay    final
                       Waste   Influent   Effluent
743
  0
0.6
  0
ro
OJ

-------
samples  taken,  the  number  of  samples  where  each  pollutant  was
detected, and the concentration ranges for each pollutant.

Summary

Table  V-35  lists  the  total number of facilities sampled during the
screening,   verification,   and   long-term   sampling   programs   by
subcategory.

Supplemental Data on Nonconventional Pollutants

Color.   Table  V-36  presents  additional  color data obtained during
earlier EPA investigations (under  Contract  No.  68-01-3287).   These
data  were  used to supplement color data obtained during verification
sampling.

Ammonia.  Limited data are available on raw waste  or  final  effluent
ammonia discharge levels at the eight mills where ammonia is used as a
cooking  chemical.   Theoretical  calculations of the range of ammonia
concentrations in raw wastewaters  were  developed  based  on  typical
rates  of  ammonia loss during pulping and pulp washing (losses due to
volatilization have not been considered in these calculations).  Table
V-37  presents  theoretical  raw  waste  loads  of  ammonia   in   the
subcategories  where  ammonia  is used as the base chemical in pulping
(semi-chemical, dissolving sulfite pulp, and both  papergrade  sulfite
subcategories).

Limited  data  are available on actual ammonia raw waste loads.  Table
V-38 presents available ammonia data for five of the eight mills where
ammonia is used for pulping.  These  data  are  generally  within  the
range  presented  in  Table  V-37  and tend to support the theoretical
calculations.
                                 235

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                                                                             TABU V-35

                                                                      TOXIC POLLUTANT SAMPLING
                                                                              DATA BASE
ro
oo


Subcategory or Hill Grouping
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine
Unbleached Kraft
o Llnerboard
o Bag
Seal-Cheaical
No. Mills
EPA Region
Screening
1
A
2
5

4
0
3
Unbleached Kraft and Se»i-Che»ical 2
Dlaaolvlng Sulfite Pulp
Papergrade Sulfite
Groundwood-Theno-Hechanl ca 1
Groundwood-CMN Papers
Groundwood-Flne Papers
Delnk
o Fine Papers
o Tissue Papers
o Newsprint
Tissue Fro* Wastepaper
Paperboard Frosi Wastepaper
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonlntegrated-Fine Papers
Nonintegrated-Tlssue Papers
Nonintegrated-Lightweight Papers
Nonintegrated-Filter and
Nomroven Papers
Nonlntegrated-Paperboard
Integrated Miscellaneous
Secondary Fibers-Miscellaneous
Nonintegrated Miscellaneous
Total
4
0
2
1
0

0
0
1
0
5
0
2
0
0
0

1
0
7
1
2
47
Sampled

Screening
0
0
1
0

1
0
1
1
0
1
0
0
1

0
1
0
0
0
0
0
1
1
0

0
0
1
1
0
11


Verification
1
2
3
3

1
2
2
2
2
4
0
0
2

1
2
1
3
6
2
4
3
2
1

2
2
4
0
3
60

Long-Ten
SaBpllnc,
0
0
0
1

0
0
0
0
0
0
0
0
0

0
1
0
0
0
0
0
0
0
0

0
0
0
0
0
2

Total
Mill Visits
2
6
6
9

6
2
6
5
6
5
2
1
3

1
4
2
3
11
2
6
4
3
1

3
2
12
2
5
1203
                                 Includes  Fine  Bleached Kraft and Soda subcatrgories.
                               2
                                 Includes  Papergrade Sulfite (Blow Pit Wash) and Papergrade  Sulfite  (Drum Wash)
                                 subcategories.

                                Some siills  saapled for screening and verification;  107 different  facilities  were
                                 sampled.

-------
                                                                             TABLE V-:)6

                                                                       SUPPLEMENTAL COLOR DATA
                    Subcatesory
                    Dissolving Kraft
                    Market Bleached Kraft
                    UCT Bleached Kraft
                    Alkaline-Kine
                                           Total NtiMber of Samples
                                              Influent   Effluent
  Concentration Range
(Platinum CobaU Units)
  Influent    El fluent
 Average Concentration
(Platinum Cobalt Units)
  Influent   Effluent
                                                                                                                               Comments
6
: 12
12
21
6
12
12
23
1310-1780
1010-2360
1040-3380
650-1480
1170-1710
1040-2360
1160-1830
480-1830
1545
1733
1625
953
1460
1830
1480
953
Biological
Bi olog ica 1
Biological
Biological
TreaLment
Trej tment
Treatment
Treatment
ro
OO
                     Jncludes Fine Bleached Kraft and Soda subcategories.

-------
ro
CO
oo
                                                    TABLE V-37


                                        THEORETICAL RAW  WASTE ANi/ONIA LOAD
                                                                        Assumed
Ammonia
Required(a)
Subca Legory (Ib/t)
Semi -Chemical 67

Dissolving Sulfite Pulp 125
Papergrade Sulfite 100
BPT RWL Flow
(kgal/t)
10. '5
10.3
66.0
66.0
44 . 5
44.5)
Recovery Raw Waste Load
Efficiency NH3-N
%
50
90
50
90
50
90
(Ib/t)
33.5
6.7
62.5
12.5
50.0
10.0
(mg/1)
390
80
114
23
135
27
                 Reported average ammonia  (as nitrogen)  required  per  ton of pulp produced.(28)

-------
                                                                              TABLE V-38
                                                                   SUMMARY OF AVAILABLE AMMONIA DATA
                                                                  KOR ALL MIIJ.S USING AMMONIA AS THE
                                                                         CHEMICAL PULPING BASE
ro
CO
vo
                                                 Raw Waste Averages (N1I3-N)

Mil 1

..._. "8/1

lb/d

Ib/t
Months of
Data

Data Source
Semi -Chemical
020014
Dissolving
046005
046006
Papergi ade
04000 Z (a)
040001 (a)
040008
040012
040016
040019(c)
040019
040020
337
Sulfite Pulp
•'(
20
Sulfite
*
&
*
50
*
157
*
*
10,100

*
3,490

*
*
*
7,540
*
2,680
ir
*
20.2

*
6.9

*
*
*-
27.2
*
4.0
*
*
12

*
1

*
ir
*
9
*
1
*
*
DMR


Verification




Supplemental

Verif icat ion


Industry Submitted Data
A
B(d)
C
E
K
£
*
*
*
*
*
•ir
*
ir
*
*
*
*
*
*
ir
ir
*
*
*





	j-jn.il Effluent Averages (NH3-N)   	
Months of
Blg/1
266
,
5
124
139
*
43
*
20.9
19
*
9.1
16.6
12.1
11.4
5.2
Ib/d Ih/t Data
7,990
*
788
3,130
4,860
*
6,170
•ff
1,590
1,406
*
1,790
993
1,260
1,520
716
16.0
*
1.6
31.3
*
*
21.4
*
2.4
1.7
*
*
*
*
*
*
12
*
1
14
12
•it
35
*
1
22
*
19
15
9
2
1
Data Source
DMR

Verif i cat ion
DMK
(b)








DMA, Supplemental

Veri f icat ion


DMR, Supplemental

Industry Submitted
Industry Submitted
Industry Submitted
Industry Submitted
Industry Submitted

Data
Data
Data
Data
Data
                  *  Data Not Available
                 (a) Mil] added ammonia to effluent for neutralization; Bill is now closed.
                 (L) Data from "Aerated Lagoon Treatoent of Sulfite Pulping Effluents," Report to U.S.
                     Environmental Protection Agency, Water Pollution Control Research Series Program
                     12040 ELW, December 1970. (39)
                 fr) R.iw waste averages are for the pulp mill only.
                 (d) Effluent data is based on discharge from biological treatment receiving pulp mill
                     waste only.  Concentration reported is that calculated for total mill discharge
                     assuming no ammonia is present in the balance of the mill wasteuater.

-------

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                              SECTION VI

                  SELECTION OF POLLUTANT PARAMETERS


WASTEWATER PARAMETERS OF SIGNIFICANCE

The Agency has conducted an exhaustive study of the pulp,  paper,  and
paperboard  industry  to establish effluent limitations reflecting the
best practicable control technology currently available (BPT) and  the
best  available  technology  economically achievable  (BAT), new source
performance standards (NSPS), and pretreatment standards for  new  and
for existing sources (PSNS and PSES).  After completion of a review of
existing  regulations,   a  review  of  available  literature,  and  an
evaluation of data obtained during sampling at  over  100  mills,  the
following  pollutant  parameters  have  been  identified as present in
pulp, paper, and paperboard  wastewaters  and  should  be  subject  to
limitation  under  BPT  and  BAT regulations, NSPS, PSNS, and PSES, as
appropriate:

     Conventional Pollutants:      BOD£, TSS, and pH.

     Toxic Pollutants:              Trichlorophenol -(TCP),
                                   pentachlorophenol  (PCP),
                                   and zinc.


SELECTION OF WASTEWATER PARAMETERS OF SIGNIFICANCE

The EPA's determination of pollutant  parameters  of  significance  in
wastewater  discharges  from  the pulp, paper, and paperboard industry
involved a review of existing regulations and an  evaluation  of  data
obtained after completion of an extensive sampling program.

All pollutants detected in pulp, paper, and paperboard wastewaters are
subject  to  limitation  except  if  excluded  for  one or more of the
following reasons:

Conventional Pollutants

1.   The pollutant is indirectly measured by measurement  for  another
     parameter.

2.   The pollutant is indirectly controlled when a selected  parameter
     is controlled.

3.   Insufficient data are available on which to base limitations.

Toxic Pollutants

Paragraph 8 of the Settlement Agreement in Natural  Resources  Defense
Council,  Inc.  v.  Train,  8 ERC 2120 (D.D.C. 1976), modified,  12 ERC
1833  (D.D.C.   1979)(1)(2),  provides  guidance  to  the   Agency   on

-------
exclusions  of specific toxic pollutants,  subcategories,  or categories
from regulations under the effluent limitations guideline?,  standards
of performance, and pretreatment standards:

          "8(a)   The  Administrator  may  exclude from
          regulation under the effluent limitations and
          guidelines, standards of performance,  and/or
          pretreatment  standards  contemplated by this
          Agreement a specific pollutant or  category or
          subcategory of point sources for any  of  the
          following  reasons,  based  upon  information
          available to him:

               (i)  For  a  specific  pollutant  or   a
          subcategory  or  category,  equally  or  more
          stringent protection is already  provided  by
          an   effluent,  new  source  performance,  or
          pretreatment  standard  or  by  an   effluent
          limitation and guideline promulgated pursuant
          to  Section(s)  301, 304, 306, 307(a),  307(b)
          or 307(c) of the Act;

               (ii) For a  specific  pollutant,  except
          for   pretreatment  standards,  the  specific
          pollutant  is   present   in   the   effluent
          discharge  solely as a result of its presence
          in intake waters taken from the same body  of
          water  into  which  it is discharged and, for
          pretreatment    standards,    the    specific
          pollutant is present in the effluent which is
          introduced  into  treatment works  (as defined
          in Section 212 of the Act) which are publicly
          owned solely as a result of its  presence  in
          the  point  source's  intake waters, provided
          however,  that  such  point  source  may   be
          subject to an appropriate effluent limitation
          for    such   pollutant   pursuant   to   the
          requirements of Section 307;

               (iii)  For  a  specific  pollutant,  the
          pollutant  is not detectable  (with the use of
          analytical  methods  approved   pursuant   to
          304(h)  of  the  Act,  or  in instances where
          approved methods do not exist, with  the  use
          of   analytical   methods   which   represent
          state-of-the-art capability)  in  the  direct
          discharges  or  in  the  effluents  which are
          introduced  into   publicly-owned   treatment
          works  from sources within the subcategory or
          category; or  is detectable  in  the  effluent
          from  only  a  small number of sources within
          the subcategory and the pollutant is uniquely
          related  to  only  those  sources;   or   the
                                242

-------
          pollutant  is  present  only in trace amounts
          and is neither causing nor  likely  to  cause
          toxic  effects;  or is present in amounts too
          small   to   be   effectively   reduced    by
          technologies  known  to the Administrator; or
          the pollutant will be effectively  controlled
          by  the  technologies  upon  which  are based
          other effluent  limitations  and  guidelines,
          standards  of  performance,  or  pretreatment
          standards; or

               (iv) For a category or subcategory,  the
          amount  and the toxicity of each pollutant in
          the discharge  does  not  justify  developing
          national  regulations  in accordance with the
          schedule contained in Paragraph 7(b).

          (b)  The  Administrator  may   exclude   from
          regulation  under  the pretreatment standards
          contemplated  by  this  Agreement  all  point
          sources  within  a  point  source category or
          point source subcategory:

               (i) if 95 percent or more of  all  point
          sources  in  the  point  source  category  or
          subcategory introduce  into  treatment  works
          (as  defined in Section 212 of the Act) which
          are publicly owned only pollutants which  are
          susceptible  to  treatment  by such treatment
          works and which do not interfere with, do not
          pass   through,   or   are   not    otherwise
          incompatible with such treatment works; or

               (ii)  if  the toxicity and amount of the
          incompatible  pollutants   (taken   together)
          introduced   by   such   point  sources  into
          treatment works (as defined in Section 212 of
          the Act)   that  are  publicly  owned  is  so
          insignificant  as not to justify developing a
          pretreatment regulation..."

Nonconventional Pollutants

1.   The pollutant is indirectly measured by measurement  for  another
     parameter.

2.   The pollutant is indirectly controlled when a selected  parameter
     is controlled.

3.   Insufficient data are available on which to base limitations.

4.   The pollutant is not  of ' uniform  national  concern  (i.e.,  the
     pollutant  is  present  at  only a small number of sources and is
                               243

-------
     uniquely related to those sources) and should be regulated  on  a
     case-by-case basis, as appropriate.

5.   The pollutant is present but cannot  be  effectively  reduced  by
     technologies known to the Administrator.

Review of Previous Regulations

Conventional,  toxic, and nonconventional pollutants have been limited
under promulgated  effluent  limitations  guidelines  and  new  source
performance  standards  applicable  to  wastewater discharges from the
pulp, paper, and paperboard and builders' paper and board mills  point
source  categories   (see  39  FR  16578, 39 FR 18742, and 42 FR 1398).
(3)(4)(5) Table VI-1  presents a summary of the  pollutants  that  have
been  regulated  or have been addressed in previous Agency rulemakings
for each of the subcategories of the industry.

Conventional Pollutants.  Regulations limiting the discharge of  BOD5_,
TSS,   and  pH  were  proposed  and/or  promulgated for the original 22
subcategories of the pulp, paper, and paperboard industry (see Section
IV).   These pollutants are  subject  to  regulation  as  specified  in
section 306 based on the best available demonstrated technology and in
sections  301(b)(2)(E)  and  304(a)(4)  through  identification of the
"best conventional pollutant control technology" (BCT).  As  discussed
in Sections II and XI, this document does not  address establishment of
BCT limitations.

Toxic  Pollutants.  The only toxic pollutant regulated in the past was
zinc (see 42 FR  1398).  (5)  This  pollutant   was  regulated  in  the
groundwood-thermo-mechanical,  groundwood-CMN   papers, and groundwood-
fine papers subcategories; at the time of promulgation of BPT effluent
limitations,  zinc  was  commonly  discharged   at   mills   in   these
subcategories  due  to  the  use  of  zinc hydrosulfite as a bleaching
chemical.

Responses obtained during a survey of the industry indicated that zinc
hydrosulfite was still used at one mill.  Since the  potential  exists
for   the  discharge  of  zinc  due  to  the  continued  use  of  zinc
hydrosulfite, EPA decided to continue to regulate  this  pollutant  in
those subcategories where zinc is currently regulated.

Nonconvent ional   Pollutants.   Two  nonconventional  pollutants  were
controlled under  prior  regulations:  settleable  solids  and  color.
Settleable  solids  were  limited  under regulations applicable to the
builders' paper and roofing felt subcategory of  the  builders'  paper
and  board  mills  point  source  category.   (3) Settleable solids are
measured  during  the  analysis  for   suspended   solids   (TSS),   a
conventional  pollutant.  Therefore, EPA concluded that (a) settleable
solids will be controlled by NSPS for TSS  and  by  limitations,  when
established,  that  reflect  the  best  conventional pollutant control
technology  (BCT)  and  (b)  that  BAT  limitations  for  control   of
settleable solids are unnecessary and redundant.

-------
                                                                                     TABLE VI-1
                                                                    SUMMAKY OF PARAMETERS PROPOSED OR  PROMULGATED
                                                                 FOR EFKLUENT LIMITATIONS GUIDELINES BY SIIBCATE<;ORY
ro
Subcatc-gory	

I nj. eg rated Segment

Dissolving Kraft
Market. Bleached Kraft
BCT Bleached Kraft
Alfcali lie-Fine *
Unbleached Kraft
Semi -f h(*ou cal
Unbleached Kraft and Seui-Che«ical
Dissolving Sulfite Pulp2
Fapergrade Sulfite3
Groundwood-Cheai-Mechanical
Groundwood-Theroio-Hechanical
Groiindwood-CMM Papers
Groumlwood-Fine Papers

Serondary Fibers Segaent

Deink
Tissue Fro« Wastepaper
Papcrboard Fron Wastepaper
Wastepaper-Molded Products4
Builders' Paper and Roofing Felt

Nonintegrated Seguent

Nonintegrated-Fine Papers
Noninlegrated-Ti&aue Papers
Noni ntcgrated-Lightweight Papers*
Noni nLegrjted-Filter and Nonwoven Papers'*
Noni itt t'grated-PapcrboH rd4
Conventional Pollutants
BODS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
rs<
TSS
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
>C
X
X
X
-
pH Seltleable Solids
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X X
X
X
-
Toxic Pollutant Nonconvent iona 1 Pollutant
Zinc

-
-
-
-
-
-
-
-
X
X
X
X

-
-
-

-
-
Color
*
A
*
*
X
X
X
-
-
-
-
-

.
-
-
-
.
-
-
                    X  Regulations were proposed and promulgated for this pollutant or  pollutant  parameter.
                    ~~  Regulations were proposed for this pollutant or pollutant parameter.

                    1 Includes Fine Bleached Kraft and Soda subcategories,
                    2 The RPT BOD5 effluent linitatiou for acetate grade production iu  the Dissolving Sulfite Pulp subcategory was
                      remunJed to EPA.
                    •* Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite  (Drua Wauh)  subcategories.
                    4 These dirt* new subcdtfgor ies for which the Agency is establishing  effluent limitations  and standards lor the
                      first t i me.

-------
BAT  limitations  were  established for control of color in discharges
from mills in  the  unbleached  kraft,   sodium-based  neutral  sulfite
semi-chemical  (NSSC),  ammonia-based  neutral  sulfite  semi-chemical
(NSSC), and unbleached kraft/NSSC (cross recovery) subcategories  (see
39  FR  18742).   (4)  EPA proposed BAT  color limits for the dissolving
kraft, market bleached kraft,  BCT  (paperboard,  coarse,  and  tissue)
bleached kraft,  fine bleached kraft,  and soda subcategories.  However,
as discussed in Section II,  BAT limitations were never promulgated for
these  subcategories.    Additional  subcategories where highly-colored
effluents are discharged include both papergrade sulfite subcategories
and the dissolving sulfite pulp subcategory.

As a result of further investigations by the Agency  since  the  prior
BAT  limitations were proposed and promulgated, EPA concluded that the
discharge of color in pulp,  paper, and  paperboard effluents is not  of
uniform  national  concern.    Therefore,  EPA proposed to withdraw all
color limitations and will control color on a  case-by-case  basis  as
dictated  by  water  quality  considerations.   While uniform national
color limitations will not be established,  the capabilities and  costs
of  various  end-of-pipe treatment techniques for the removal of color
are presented in Sections VII, VIII,  and Appendix A of  this  document
as a reference for use by permit writers.

Identification Of Other Compounds Of Concern
In  addition to the pollutants controlled by existing regulations, EPA
investigated  the  potential  for  discharge  of   other   toxic   and
nonconventional  pollutants  from  the  pulp,   paper,  and  paperboard
industry.   A total of 129 specific toxic pollutants and 14  additional
nonconventional  pollutants  were  the subject of extensive study (see
Section II).  EPA conducted screening and  verification  studies  that
led to the exclusion of many specific toxic pollutants from regulation
based  on  the  guidance  provided  in  Paragraph  8 of the Settlement
Agreement.

Screening Program.  As discussed in Section II, the screening  program
consisted  of three separate investigations: a) the initial contractor
screening program, b) contractor screening  studies  conducted  during
verification  sampling, and c) screening studies conducted by Regional
Surveillance and Analysis (S&A) field teams.

     Results  of_  Initial  Contractor  Screening  Program-Table   11-3
presents  the  list of toxic and additional nonconventional pollutants
analyzed as part of the screening  program.   Table  V-28  presents  a
summary  of the results of the contractor's initial screening studies.
As previously discussed in Section II,  EPA  determined  the  specific
toxic  pollutants  to  be investigated during the verification program
based on this abbreviated  initial  screening  program  and  on  other
available  data  including  information obtained in literature reviews
and during the industry  survey  program.   Specific  pollutants  were
eliminated  from investigation during the verification program only if
the pollutant was not detected in wastewater samples collected  during
the  initial contractor screening program, with the exception of seven
                               2*6

-------
metals: antimony, arsenic, beryllium, cadmium, selenium,  silver,  and
thallium.   Based  on  initial  screening results, EPA determined that
these seven metals were present in amounts too small to be effectively
reduced  by  the  application  of  available  control  and   treatment
technologies.

     Results   of.   Contractor   Screening  Studies  Conducted  During
Verification Sampling-Table V-29 presents  the  results  of  screening
studies conducted by the contractor during verification sampling at 17
mills  where  processes were employed that are representative of those
segments of the pulp, paper, and paperboard industry not  included  in
the contractor's initial screening investigations.

     Results of_ Regional S&A Screening Studies-Table V-30 presents the
results  of  screening  studies  conducted  by  EPA Regional S&A field
teams.

     Exclusion of_  Toxic  Pollutants  From  Regulation  Based  on  the
Results  of  the Screening Program-Table VI-2 presents a list of those
specific toxic pollutants that EPA excluded from regulation  based  on
screening program results and the reasons for those exclusions.

Verification Program.  Table I1-8 presents a list of all compounds for
which  EPA obtained chemical analyses during the verification program.
A summary of the analysis results is presented in Table V-31.

Toxic Pollutant Assessment.  EPA assessed the  analytical  results  of
those  toxic  pollutants  detected  in verification program samples to
identify those pollutants of potential concern and to determine  which
pollutants  should be subject to limitation through the implementation
of uniform national standards.

Anticipated treatability levels for the specific toxic pollutants were
developed by personnel in  the  Office  of  Quality  Review,  Effluent
Guidelines  Division.(40)  Projected  treatability  for  metals (zinc,
nickel, copper, lead, and chromium) and  cyanide  were  based  on  the
proposed  pretreatment  regulations  for  the  electroplating industry
point source category.(41) The basis for  comparing  the  results  for
mercury  was  proposed  pretreatment standards for the metal finishing
industry. (42) Table VI-3 presents projected treatability  levels  for
those  compounds  included  in the Agency's verification program.  EPA
compared verification analysis results with the treatabilities  listed
on  Table  VI-3  to determine if additional removal of these compounds
might be possible through  the  application  of  various  control  and
treatment  technologies known to be capable of removing specific toxic
compounds.

Based on this comparison, EPA  eliminated  19  toxic  pollutants  from
further  consideration  in  the  assessment of pollutants of potential
concern in discharges from the pulp, paper, and  paperboard  industry.
These  toxic  pollutants  were eliminated in accordance with Paragraph
8(a)(iii);  EPA  determined  that  these  pollutants  are  "present  in
                                  247

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                                     TABLE VI-2
                    CRITERIA FOR ELIMINATION OF TOXIC POLLUTANTS
                         BASED ON SCREENING PROGRAM RESULTS
                           AND TOXIC POLLUTANTS ELIMINATED
Paragraph 8 (a) (ill)
"For a apecific pollutant, the pollutant is not
 detectable	"
1.  acenaphthene                            88.
2.  acrolein                                89.
8.  1,2,4-trichlorobenzene                  90.
9.  bexachlorobenzene                       91.
12. hexachloroethane
16. chloroethane                            92.
19. 2-chloroethylvinyl ether (mixed)        93.
26. 1,3-dichlorobenzene                     94.
28. 3,3'-dichlorobenzidine                  95.
32. 1,2-dichloropropane                     96.
37. 1,2-diphenylhydrazine                   97.
40. t-chlorophenylphenyl ether              98.
41. 4-bromophenylphenyl ether               99.
46. methyl broaide (broBomethane)           100.
SO. dichlorodifluoroBcthane                 101.
52. hexachlorobutadiene                     102.
57. 2-nitrophenol                           103.
61. N-nitrofodiaethylaaine                  104.
63. N-nitrosodi-n-propylanine               105.
72. benzo[a]anthracene                      113.
    (1,2-benzanthracene)                    116.
73. benzo[a]pyrene (3,4-benzopyrene)        129.
74. 3,4-benzofluoranthene
75. beozo[k)fluoranthene
    (11,12-benzo fluoranthene)
79. benzo[ghiJperylene
    (1,12-benzoperylene)
80. fluorene
83. indeno[l,2,3-cdjpyrene
                     vinyl chloride (chloroethylene)
                     aldrin
                     dieldrin
                     chlordane (technical nixture and
                     •etabolitea)
                     4,4'-DDT
                     4,4'-DDE (p.p'-DDX)
                     4,4'-ODD (p,p'-TDE)
                     a-endoiulfan
                     B-endoiulfan
                     endoaulfan sulfate
                     endrin
                     endrin aldehyde
                     heptachlor
                     heptachlor epoxide
                     a-BHC
                     9-BHC
                     Y-BHC (lindane)
                     5-BHC
                     toxaphene
                     aabestoa (fibrous)
                     2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)
                                                248

-------
                              TABLE VI-2 (Continued)
Paragraph 8 (a) (iii)
"For a specific pollutant.....i» present la amounts
too small to be effectively reduced by technologies
known to the Administrator	"
3.    acrylonitrile                          53.
S.    benzidlne                              56.
14.   1,1,2-trichloroethane                  58.
17.   bis(chloronietbyl)ether                 60,
20.   2-cbloronaphthalene                    62.
25.   1,2-dichlorobenzene                    71.
27.   1,4-dichlorobenzene                    114.
30.   1,2-dicnloroethylene                   115.
33.   1,3-diehloropropylene                  117.
      (1,3-dichloropropeae)                  118.
34.   2,4-di«ethylphenol                     125.
35.   2,4-dinitrotoluene                     126.
36.   2,6-dinitrotoluene                     127.
42.   bis(2-chioroiSQpro]jyl3 ether
43,   bis(2~chl0roethoxy) methane
45.   methyl chloride (cblortwietkane)
                    hexacnlorocyclopentadiene
                    nitrobenzene
                    4-nitrophenol
                    4,6-dinitro-o-creaol
                    N-nitrosodiphenylaniine
                    dimethyl phthalate
                    antimony
                    arsenic
                    beryllium
                    cadmium
                    selenium
                    silver
                    thallium
Paragraph 8 (a) (iii)
"For a specific pollutant	is detectable in the
effluent from only a small nunber of sources	
and the pollutant is uniquely related to only those
sources	"
18.   bis (2-chloroethyl) ether
29.   1,1-dichloroethylene
82.   dibenzo(a,h]anthracene
      (1,2,5,6-dibenzanthracene)
                                            249

-------
                                    TABLE VI-3

         PROJECTED TREATABILITY FOR VERIFICATION PROGRAM TOXIC  POLLUTANTS


       Verification Compound                                              Source  for
Toxic Compounds (Priority Pollutants)    Comparison Level (ps/1)	Concentration Used
4.
6.
7.
10.
11.
13.
15.
21.
22.
23.
24.
31.
38.
39.
44.
47.
48.
49.
50.
51.
54.
55.
59.
64.
65.
66.
67.
68.
69.
70.
76.
77.
78.
81.
84.
85.
86.
87.
106.
107.
108.
benzene
carbon tetrachloride
chlorobenzene
1,2-dichloroe thane
1,1, 1-trichloroethane
1 , 1-dichloroe thane
1, 1,2,2-tetrachloroethane
2,4, 6-trichlorophenol
parachlorometa cresol
chloroform
2-chlorophenol
2,4-dichlorophenol
ethylbenzene
fluoranthene
oethylene chloride
broraoform
dichlorobronoroe thane
trichlorofluorome thane
dichlorodifluo rone thane
chlorodibromooe thane
iaophorone
naphthalene
2,4-dinitrophenol
pentachlorophenol
phenol
bis(2-ethylhexyl) phthalate
butyl benzyl phthalate
di-n-butyl phthalate
di-n-octyl phthalate
diethyl phthalate
chry»eue
acenaphthylene
anthracene
phenanthrene
pyrene
tetrachloroe thy lent
toluene
trichloroethylene
PCB 1242 (Arochlor 1242)
PCB 1254 (Arochlor 1254)
PCB 1221 (Arochlor 1221)
50
50
50
100
100
100
50
25
50
100
50
50
50
10
100
50
100
100
100
100
50
50
25
10
50
10
1 - 10
25
10
25
1
10
10
10
1
50
50
100
1
1
1
*
*
*
•ft
*
*
*
*

*
,v
*
it
*
*
*
*
*
*
*
*
*
*
*
*
-V
•Je
•:;
*
*
*
*
*
*
*
*
*
*
*.v
£
*
                                           250

-------
                                  TABLE VI-3 (continued)

       Verification Compound                                              Source for
Toxic Compounds (Priority Pollutants)   Comparison Level (|Jg/l)	Concentration Used


109.  PCB 1232 (Arochlor 1232)                      1                           *
110.  PCB 1248 (Arochlor 1248)                      1                           *
111.  PCB 1260 (Arochlor 1260)                      1                           *
112.  PCB 1016 (Arochlor 1016)                      1                           *
119.  chromium                                   2500                           **
120.  copper                                     1800                           **
121.  cyanide                                     230                           **
122.  lead                                        300                           **
123.  mercury                                     100                           ***
124.  nickel                                     1800                           **
128.  zinc                                       1800                           **
References

*Murray P. Strier, "Treatabilitv of Orgnnic Priority Pi] lut.ints - Part C - Thei- Estimated
(30 Day Average) Treated Effluent Concentration - A Molecular Engineering Approach,"
Table I, 1978.  (40)

**  Development Document for Existing Source Pretreatment Standards for the Electro-
    plating Point Source Category, EPA 440/1-79-003, August 1979.  (41)

*** Development Document for Proposed Effluent Limitations Guidelines and Standards for
    the Metal Finishing Point Source Category. EPA 440/l-82/091b, August 1982.  (42)
                                             251

-------
amounts  too  small to be effectively reduced by technologies known to
the Administrator." These toxic pollutants are listed in Table VI-4.

The following compounds were not detected in samples collected at  any
of 60 mills where verification surveys were conducted:

     1,1,2,2-tetrachloroethane
     2,4-dinitrophenol
     Chrysene
     Phenanthrene
     Parachlorometa cresol

EPA   included   chrysene   and   1,1,2,2-tetrachloroethane   in   the
verification program because they were detected during  the  screening
program  in  the  raw wastewater from one mill at a level of less than
one microgram per liter.  These compounds were not detected in  either
raw  wastewater  or final effluent samples from any of 60 mills during
verification sampling and analysis,  including four mills in  the  same
industrial subcategory as the one mill where they were detected during
the  initial screening program.  During screening studies conducted by
Regional S&A field teams, 1,1,2,2-tetrachloroethane  was  detected  in
the  final  effluent  of  one mill at a level lower than the projected
treatability level presented in Table VI-3.

EPA included 2,4-dinitrophenol on the list of  verification  compounds
because  its  use was reported at one mill for which a survey response
was received.  However, it was not detected in  samples  collected  at
any of the 60 mills where verification surveys were conducted.  During
screening   studies   conducted   by   Regional   S&A   field   teams,
2,4-dinitrophenol was detected in the final effluent of one mill at  a
level  lower  than the projected treatability level presented in Table
VI-3.

Phenanthrene was included in  the  verification  program  because  the
analysis  procedures  utilized  during  the  screening program did not
provide a basis for distinguishing between anthracene and phenanthrene
because they co-elute.   During  screening,  the  presence  of  either
anthracene  or  phenanthrene  or  both  was indicated.  Therefore, EPA
included both anthracene and phenanthrene on the list of compounds  to
be investigated during verification sampling.  The procedures utilized
during  the  verification  program  allowed  for  distinction  between
phenanthrene and anthracene.  Phenanthrene was not detected at any  of
the 60 verification mills.

EPA  added parachlorometa cresol to the list of verification compounds
because it is a chlorinated phenolic.  Based  on  literature  reviews,
EPA  determined that potential existed for the presence of chlorinated
phenolics  in  pulp,  paper,  and  paperboard   effluents.    However,
parachlorometa cresol was not detected in wastewater samples at any of
the 60 verification mills.

The   toxic   pollutants  bis(2-ethylhexyl)  phthalate  and  methylene
chloride were eliminated from further consideration because they  were
                               •252

-------
                                   TABLE VI-4

                   TOXIC POLLUTANTS ELIMINATED FROM ASSESSMENT
                      BASED ON VERIFICATION PROGRAM RESULTS
                        DETECTED BELOW TREATABILITY LEVEL
6.   carbon tetrachloride
     (tetrachloromethane)
7.   chlorobenzene
10.  1,2-dichloroethane
13.  1,1-dichloroethane
15.  1,1,2,2-tetrachloroethane1
22.  parachlorometa cresol2
39.  fluoranthene
44.  methylene chloride3
     (dichloromethane)
48.  dichlorobromomethane
49.  trichlorofluoromethane
51.  chlorodibromomethane
54.  isophorone
2,4-dinitrophenol1
bis(2-ethylhexyl) phthalate3
di-n-octyl phthalate
chrysene4
acenaphthylene
anthracene
phenanthrene 5
PCB-1221 (Arochlor 1221)
PCB-1232 (Arochlor 1232)
PCB-1016 (Arochlor 1016)
chromium (total)
copper (total)
mercury (total)
59.
66.
69.
76.
77.
78.
81.
108.
109.
112.
119.
120.
123.
124. nickel (total)
1 Not detected during verification sampling; detected in final effluent(s)
  during screening program below treatability level.

2 Not detected in raw waste or final effluent samples during screening or
  verification programs.

3 Laboratory contaminant.

4 Not detected during verification sampling; detected in raw waste stream(s)
  below treatability levels during screening program.

s Not detected during verification sampling; co-elutes with anthracene using
  screening procedures.
                                       253

-------
reported  to be laboratory contaminants.   Therefore,  verification data
on these compounds may not be valid.   The  toxic  pollutant  methylene
chloride  is  used  in  the  preparation  of  sample containers and in
extraction procedures used in the analysis  of  semi-volatile  organic
toxic and nonconventional pollutants.

Based  on  the  comparison  of  available  verification  data  to  the
treatability levels developed by the Office  of  Quality  Review,  EPA
identified   for   each   subcategory   those  toxic  pollutants  with
concentrations equal to or in excess of specified treatability  levels
in either the raw wastewater or treated effluent.  Table VI-5 presents
a  summary  of  the  toxic  pollutants  of  potential concern for each
subcategory based on this comparison.

Upon determining  the  toxic  pollutants  of  potential  concern,  EPA
evaluated  all  available  data.   The purpose of this analysis was to
determine those pollutants of potential concern that should be limited
through implementation of  uniform  national  standards.   Table  VI-6
presents  data  summaries  used  in  the  determination of which toxic
pollutants  occur  at  sufficient  levels  and  frequency  to  require
implementation  of  uniform  national  standards.  The summary includes
the range and average concentrations of the toxic pollutants found  in
raw wastewater and final effluent samples collected at all mills where
levels  exceeded  the  treatability  levels  presented  in Table VI-3.
Average concentrations were calculated  based  on  those  mills  in  a
subcategory   where   the   specific  pollutant  levels  exceeded  the
treatability level.  This method  allows  presentation  of  levels  of
pollutants  that would approximate the average concentrations expected
at  mills where the  pollutant  is  present  due  to  use  of  similar
processes or process chemicals.

As  a  result  of  this evaluation, EPA eliminated 20 toxic pollutants
from further consideration in the  assessment  of  the  necessity  for
development  of  uniform  national  guidelines.   Paragraph  8  of the
Settlement Agreement provides guidance for the  elimination  of  these
specific  toxic  pollutants.  Table VI-7 lists those criteria cited in
Paragraph 8 and the specific toxic pollutant(s) eliminated based  upon
the criteria.

Based on this analysis, the Agency proposed uniform national standards
for  the control of three additional specific toxic pollutants besides
zinc: chloroform, trichlorophenol and  pentachlorophenol  (see  46  FR
1430; January 6, 1981).

Subsequent  to  proposal, EPA reviewed its analysis of toxic pollutant
discharges  from  the  pulp,  paper,   and  paperboard  industry.   EPA
determined   that  uniform  national  standards  for  the  control  of
trichlorophenol   and   pentachlorophenol   should   be   promulgated.
Trichlorophenol  (TCP)  and  pentachlorophenol  (PCP) were consistently
detected in treated effluents in  excess  of  treatability  levels  at
those  mills where slimicide and biocide formulations containing these
compounds were used.  Additionally, P.CP and TCP  are  likely  to  pass
through  publicly owned treatment works (POTWs).  Technology (chemical

-------
                                                                                             TABLE VI-5

                                                                                     SUMMARY OF TOXIC POLLUTANTS

                                                                                      OF CONCERN BY SUBCATKGOKY
fO
Jl
Jl
SulndU.ii..iy A" 1
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Al ka 1 i ne-Fi ne '
llnlilrjc lied Kraft
a Linertioaril
o Bag
Seni -Cheulira 1
Unbleached Kraft and
Si-nu -Chemical
Dissolving Sulfjtc Pulp
I'apergrade Siilfitc2 X
(jf oim.lwoud-Fine Papers
Deink
o Fine Papers
o Tissue Papers
Paprrboard From Wastepaper
Builders' Paper and Roofing
Ke 1 1
Noli integrated Segilelit
Noniutegratcd-Kine Papers
Noniutegrated-Ti ssue Papers
Non j ll t eg ra t ed - L i gh t we i gh t
Nunintegrated-Fi 1 ter and
Noiiwoveu Papers

*Toxic Pollutants are as follows:
A. Benzene 31.
11. 1 , 1, 1-Trichloroethane 38.
21. Tr ich joropheriol 47.
2:i. Chloroform 55.
24. 2-Chlorophenol 64.
1 Includes tine BJeached Kraft and

.' 21. ?J_._2.A. _?i
X - -
X X - -
X - -
X - -
X - -
x x x x x
X - -
X - -

X
	
	

2 ,4-Dichloropheuol
Ethy Ibenzene
Bronof orm
Naphtha lene
Pentachlorophenol

38 __ 47 55 64
X
X
X X
X
X X

X - - -
X - X
X
X - - -
-

Toxic Pollutants-
65 67 68 70 84 B5 86 87 106 107 110 111 121
X---X----






X----XX--
X-----X--
XXXX

X--X-X---
xxxx 	 - x
XX-X--X-- - X - X
X-X--X 	




122 128


-




-
X
X
X X
X X
X

X X
65. Phenol 85. Tetrachloroethylene 110. PCB 1248
67. Butyl Benzyl Pbtbalate 86. Toluene 111. PCB 1260
68. Di-n-Butyl Phthalate 87. Tricbloroethylene 121. Cyanide
70. Dietbyl Phthalate 106. PCB 1242 122. Lead
84. Pyrene 107. PCB 1254 128. Zinc
                   liu I uilea  l",ipergra
-------
                                                                                    TABLE VI-6

                                                             SUMMARY OF DATA ASSESSMENT - TOXIC POLLUTANTS OF CONCERN
cn
o>
            Toxic Pollulant/Subc«te«.ory  	

              4.  Benzene
                 Papergrade Sulfite
11. 1,1,1-Trichloroethane
    Papergrade Sulfite
    Integrated Mittcel laneous

21. 2,4,6-Trichlorophenol
    Market Bleached Kraft
    Papergrade Sulfite
    Deink
      o  Tissue Papers
    Paperboard From Wastepaper
    Nonintegrated Miscellaneous

23. Chloroform
    Dissolving Kraft
    Market Bleached Kraft
    BCT Bleached Kraft
    Alkaline-Fine
    Dissolving Sulfite Pulp
    Papergrade Sulfite
    Groundwood-Fine Papers
    Deink
      o  Fine Papers
      o  Tissue Papers
    Integrated Miscellaneous

24. 2-Chlorophenol
    Papergrade Sulfite

31. 2,4-Dichlorophenol
    Papergrade Sulfite

38. Ethylbenzene
    Market Bleached Kraft
    Tissue Frosi Wastepaper
    Nonintegrated-Tissue Papen
                                                Influent  Effluent
                                       12
                                                    12
                                                    12
                                                 12
12
12
6
12
6
18
9
3
6
9
9
4
12
6
3
6
12
12
12
6
12
6
18
9
3
6
9
9
4
12
6
3
6
12
                                                              12
                                                              12
• of Sample* iu Excess Concentration
Treatability Levels Range lJg/1
if luent
3

3
1
1
3
3
3
1
3
6
9
8
4
11
3
3
3
3
Effluent
1

0
0
0
3
3
3
1
0
0
0
3
0
12
0
2
0
0
Influent
140-150

130-2,000
3-187
13-26
330-370
29-65
270-420
6-30
360-900
830-2,200
580-4,000
43-1,800
110-360
62-8,600
130-240
670-9,700
1,000-1,800
450-1,100
Effluent
7-96

6-8
0
5-6
170-270
39-43
420-450
6-28
40-86
6-20
0-11
2-110
1-42
120-1,200
16-36
95-240
48-61
2-14
Average
Concentrations Mft/1
Influent
147

1,243
67
20
350
48
360
18
647
1,405
1,550
1,148
268
2,677
170
4,190
1,367
833
Effluent Comments
Detected in tinal cfflu-
at low levels.
7
0
5
210
41
430
19
67
12
6
52
13
433
26
145
55
10
                                                                                                   0-120
                                                                                                   180-220
                                                                                                                  21-50
                                                                                                                  90-130
                                                                                                                                 65
                                                                                                                                203
                                                                                                                                             37
                                                                                                                                             106
                                                                                                                                                      (b)





6
9


6
9


1
1


0
0


0-82
2-74


0
0


27
27


0
0

Detected in two tiua 1
effluent samples at one
•ill where biological
employed.
            (a) Detected in final effluent samples at levels lower than the 30-day average treatability comparison value.

            (b) Detected in final effluent samples at levels higher than the 30-day average treatability comparison value only at aull(s) where BPT efiluent
                limitations are not attained.

-------
                                                                           TABLE  Vi-b  (Continue.!)
                                                           Nuuiher of Samples in Excess      Concentration
                               Nusibe£ _of_Sa«p_les_ A_na_lyzed	of  Treatability Levels   	  	Range pg/1	
                                    Influent  Effluent
in
 47.  Rromoforn
     Paurrbotird Frupi Wastepaper

 55.  Naphthalene
     Papergrade Sulfitc
     Dei nk
       o  Kinir Papers
       o  Tissue Papers
                                                 18
                                                 12
                                                           18
uent
1
2
3
2
2
I
2
1
2
2
5
6
3
2
I
5
2
5
6
3
6
1
3
2
9
12
2
1
1
Effluent
1
1
0
0
3
0
0
0
2
3
3
-
0
2
0
0
0
0
0
0
2
0
0
0
3
0
1
0
0
Influent
0-119
22-230
67-190
0-78
5-31
6-11
9-12
3-12
9-24
10-61
0-1,200
17-160
12-29
0-200
8-110
44-92
41-110
50-140
160-400
30-100
78-640
15-51
76-150
24-140
59-500
51-1400
44-150
8-150
10-68
Effluent
0-62
7-88
0
0
16-21
0-1
0
0-2
4-20
27-38
0-1,400
-
0-5
0-68
10-29
0-17
3-4
0
3-24
0
0-250
0-5
0
0-6
0-520
-
22-66
0-3
0
                                                                                                                                Average
                                                                                                                           Concent rat ions pg/1
                                                                                                                           TnfluenT   Effluent
                                                                                                                              40
                                                                                                                             102
                                                                                                                             142
                                                                                                                              48
                                                                                                                                          36
(b)


(b)
 64.  Pentachlorophcnoi
     BCT Bleached Kraft                  99                 23        5-31           16-21          19          19
     Alkaline-Fine                       99                 10        6-11           0-1             8           1
     Papcrgrade Sulfite                 12        12                 20        9-12           0              110
     Groundwood-Kine Papers              6         6                 1          0        3-12           0-2             6
     Do ink
       o  Kine Papers                    33                 22        9-24           4-20           15          12
       o  Tissue Papers                  66                 23        10-61          27-38          38          34
     Paperboard From Wustepaper         18        18                 53        0-1,200        0-1,400       356         400
     Builders'  Paper and Roofing Fell   12*        0                 6                   17-160          -             65
     Integrated Miscellaneous           12        12                 3          0        12-29          0-5            23           3
     Noiiinlegrate.l Miscellaneous         99                 22        0-200          0-68           72          27

 65.  Phenol
     Dissolving Kraft                    33                 10        8-110          10-29          54          18
     BCT Bleached Kraft                  99                 50        44-92          0-17           67           7
     Unbleached Kraft
       o  Unerboard                     33                 20        41-110         3-4            77           3
       o  Bag                            66                 50        50-140         0              89           0
     Seoii-Chemical                       66                 60        160-400        3-24          230          14
     Unbleached Kraft and
        Seni-Chemical                    66                 30        30-100         0              56           0
     Papergrade Sulfile                 12        12                 62        78-640         0-250         333          80
     Grojndwood-Kinc Papers              66                 10        15-51          0-5            34           2
     Deink
       o  Tissue Papers                  66                 30        76-150         0             119           0
     Tissue Froa Wastepaper              99                 20        24-140         0-6            77           2
     Paperboard From Wastepaper         18        18                 93        59-500         0-520         204          144
     Builders'  Paper and Roofing Felt   12         0                12          0        51-1400         -            409
     Nonintrgrated-Finc Papers           99                 21        44-150         22-66          94          38
     NoninLegrated-Ki1ter and Nonwoven
       Papers                            66                 10        8-150          0-3            64            1
     Integrated Miscellaneous           12        12                 10        10-68          0              31           0


(a) Detected in Final effluent samples at levels lower than the 30-day average treatabi1ily comparison value.

(b) Delected in final effluent sunples at levels higher than the 30-day average treatahility comparison value only at mill(s) where BPT  effluent
    limitations are not attained.
*1 mill was self-
contained and 3 dis-
charge to POTWs.

(b)

-------
                                                                              TABLE VI-6 (Continued)
                                                                       Nuaiber  ol  Samples  io Excess       Concent rat ion
                                           Nuaiber of Samples Analyzed	of Treatability Level 5     	  Range  pg/1	
Average
Jt
CD
Tuxi
67.








68.



70.





84.

85.



86.








c Pol lutant/Subcatcgory
Butyl Benzyl Phthalate
Unbleached Kraft
o Bag
Dissolving Sulfite Pulp
Deink
o Newsprint
Paperhoard From Wastepaper
Builders' Paper and Roofing
Nonintegraled-Tissue Papers
Ui-N-Butyl Phthalate
BCT Bleached Kraft
Paperhoard Fron Wastepaper
Noni ntegra ted-Paperboa rd
Uiethyl Phthalate
Tissue From Wastepaper
Paperboard Proa Wastepaper
Builders' Paper and Hoofing
Noniiitegrated-Tissue Papers
Nonintegrated-Paperboard
Pyrene
Dissolving Kraft
Tet rachloroethylene
Deink
o Fine Papers
Tissue from Wastepaper
Toluene
Alkal ine-Fine
Papergrade Sulfite
Groundwood-FJne Papers
Deink
o Fine Papers
Builders' Paper and Roofing
Nonintegrated-Tissue Papers
Integrated Miscellaneous
Influent


6
4

3
18
Felt 12
6

9
18
6

9
18
Felt 12
6
6

3


3
9

9
12
6

3
Felt 12
6
12
Effluent


6
4

0
18
0
6

9
18
6

9
18
0
6
6

3


3
9

9
12
6

3
0
6
12
Influent


2
0

3
7
3
3

1
1
3

1
7
3
1
0

1


2
1

1
2
1

1
2
1
3
Effluent


0
1

-
3
0
1

0
3
1

0
5
-
0
2

0


0
1

0
1
0

0
-
0
6
Inf 1 uent


0-39
0

3-8
0-190
5-12
620-950

0-27
0-85
110-230

0-55
12-690
0-180
0-35
0-12

0-6


22-180
0-220

1-180
10-70
1-63

11-150
0-620
2-380
0-660
Effluent


0
2

-
0-81
0
0-15

0-23
30-55
0-61

0
0-320
-
0
0-130

0


0
0-57

0
3-66
0

0
-
1-15
70-150
Influent


23
0

5
61
9
797

16
32
180

26
183
42
12
4

2


95
74

62
44
23

58
120
130
147
Effluent


0
2

-
21
0
5

8
44
20

0
138
-
0
58

0


0
19

0
29
0

0
-
6
99
Comment s
Detected in final
effluent samples at
very low levels.






Detected in fianl
effluent samples at
very low levels.

Detected at low levels
in final effluent
samples of only two
mills where BPT limits
are attained.

(a)

Only detected hi one
final effluent sample.



(b)







            (a)  Detected  in  final  effluent  samples at  level*  lower  than the 30-day average treatahllity  comparison value.

            (b)  Detected  in  final  effluent  samples at  levels  higher than  the  30-day  average treatability comparison value only  at •il](s)  where  BPT  effluent
                limitations  are  not  attained.

-------
                                                                                TABLE VI-6 (Continued)
                                            Nimber of Saaples Analyzed
rv;
tn
Toxic Pol lutant/Subcategory Influent Effluent
87.


106


107






110.


111.


121.



122





l'28.






(a)
(bl
Tri chloroethylene
Deink
o Fine Papers
. PCB-1242
Drink
o Fine Papers
. PCB-12S4
Unbleached Kraft and Sesu-
Cheaucal
DC ink
Nonintegra ted-Fi 1 ter and Nonwoven
Papers
Nodintfgrated Miscellaneous
PCB-1248
Paperboard Fro* Wastcpsper
Builders' Paper and Roofing Felt
. PCB 1260
Deink
o Tissue Papers
Cyanide
Deink
o Newsprint
Builders' Paper and Roofing Felt
. l,ca
-------
                                   TABLE VI-7

                 CRITERIA FOR ELIMINATION OF TOXIC POLLUTANTS
                     BASED ON VERIFICATION PROGRAM RESULTS
                        AND TOXIC POLLUTANTS ELIMINATED
Paragraph 8(a) (iii) "For a specific pollutant ....  is present in amounts
                     too small to be effectively reduced by technologies
                     known to the Administrator ..."
 4.  benzene
11.  1,1,1-trichloroethane
24.  2-chlorophenol
31.  2,4-dichlorophenol
47.  bromoform
55.  naphthalene
65.  phenol
67.  butyl benzyl phthalate
68.  di-n-butyl phthalate
                   70.  diethyl phthalate
                   84.  pyrene
                   86.  toluene
                   87.  trichloroethylene
                  121.  cyanide
                  122.  lead
Paragraph 8 (a) (iii)
"For a specific pollutant	  is detectable in the
effluent from only a small number of sources	and
the pollutant is uniquely related to only those sources.
38.  ethylbenzene
85.  tetrachloroethylene
107. PCS 1254
110. PCB 1248
111. PCB 1260
                                        260

-------
substitution) is available that will virtually eliminate the discharge
of PCP and TCP associated with the  use  of  chlorophenolic-containing
biocides  in the pulp, paper, and paperboard industry.  The Agency has
determined that removal of PCP at POTWs is on the  order  of  only  54
percent. (43) Limited data are available on the TCP removal capability
of  POTWs;  however,  available  data  on the capability of biological
treatment to remove TCP  indicates  that  reductions  approaching  100
percent do not occur (see Table V-31).

After reviewing all available information, EPA decided to withdraw the
chloroform  regulations  that were proposed for the nine subcategories
where chlorine or chlorine-containing compounds  are  used  to  bleach
pulp.  The technology basis of the proposed limitations was biological
treatment  capable  of  attaining  BPT effluent limitations.  Proposed
limits were based on the highest concentrations found after biological
treatment at mills in the nine subcategories where BPT limitations are
being achieved.   EPA's  review  of  all  available  chloroform  data,
including  data provided in comments on the proposed rules, identified
nine mills where closed biological  systems  (either  oxygen-activated
sludge  or  deep  tank  aeration  systems)  are  employed that inhibit
chloroform volatilization.  The Agency also determined that  the  nine
mills with closed systems are likely to exceed the proposed chloroform
limit  even  when  BPT  effluent limitations are attained.  The Agency
decided to withdraw the proposed BAT limitations for chloroform  since
(a) installation of biological treatment assures adequate treatment of
chloroform  for all but nine mills and (b) the proposed BAT chloroform
limitations cannot  be  achieved  at  the  nine  mills  without  major
modification  of  the  existing  closed  biological treatment systems.
Further, the incremental removal of chloroform  that  would  occur  at
these  nine  mills  is not justified in light of the non-water quality
impacts that would result from the application of  chloroform  removal
technology.    EPA  estimated  that compliance with proposed chloroform
limitations would increase  the  energy  used  to  operate  wastewater
treatment systems at these nine mills by over 70 percent.

The  Agency  also decided to withdraw the proposed NSPS for chloroform
because EPA anticipates that chloroform will be effectively controlled
at new sources through the application of  open  biological  treatment
systems;  closed biological treatment systems are now employed at only
about 4.7 percent of the existing direct discharging mills.

At proposal, EPA was aware that some wastepapers are contaminated with
PCBs which were once used in the manufacture of carbonless copy paper.
However, only  limited  data  were  available  on  the  discharge  and
treatability  of  PCBs  in  the  pulp, paper, and paperboard industry.
Thus,  PCB  effluent  limitations  were   not   proposed   for   those
subcategories  where  wastepaper  is  processed.   Instead, the Agency
sought comments and additional data  on  the  discharge  of  PCBs  and
explained  that EPA would evaluate all available data between proposal
and promulgation to determine whether BAT limitations for  control  of
PCBs are appropriate.
                                261

-------
After  proposal,  the Agency obtained all available information on the
discharge of PCBs in the pulp,   paper,  and  paperboard  industry  and
determined  that PCB-1242 is a pollutant of concern in discharges from
mills in the  deink  subcategory  where  fine  or  tissue  papers  are
produced.   Therefore,   concurrent  with  the  final  regulation,  EPA
proposed BAT effluent limitations and NSPS for control of PCB-1242  in
the  deink  subcategory.   The  proposed  regulation is the subject of
another document. (44)

Prior to promulgation,  based on the guidance provided in  Paragraph  8
of  the  Settlement  Agreement, EPA reexamined the toxic pollutants of
potential concern for this industry as  they  relate  to  pretreatment
standards.   Table  VI-8  lists  those  toxic  pollutants of potential
concern for which the Agency did not establish pretreatment  standards
and the reasons therefor.

Nonconventional   Pollutant  Assessment.   During  the  screening  and
verification  programs,   EPA  investigated  discharge  levels  of   14
additional nonconventional pollutants (xylene, four resin acids, three
fatty  acids,   and six  bleach plant derivatives) specific to the pulp,
paper, and paperboard industry and ammonia (used at eight mills  as  a
cooking  chemical).   Table V-32 presents a summary of the verification
program results for these  nonconventional  pollutants.   One  of  the
bleach plant derivatives, 9,10-dichlorostearic acid, was detected only
once  in  an-  internal  .process sewer sample at a market bleached kraft
facility.  Therefore, EPA eliminated  it  from  further  consideration
because  it  was  not  detected in final effluent samples at any of 60
mills.

Another nonconventional pollutant, xylene, was detected in significant
quantities in the final effluent at only one verification mill,  where
it  was  known  that  xylene  was used.  Therefore, EPA decided not to
establish uniform national regulations for control of  xylene  in  the
pulp,  paper,   and paperboard point source category; the pollutant (a)
was detectable at potentially significant levels in  the  effluent  of
only  one  source  within the category where the pollutant is uniquely
related to only that source or (b) was present in amounts too small to
be effectively reduced  by technologies known to the Administrator.  If
the permit issuing authority is aware that xylene is used at  a  mill,
EPA  recommends  that the permit writer undertake a closer examination
of the levels being  discharged  to  determine  if  xylene  should  be
limited in the NPDES permit.

EPA  assessed  data  on  the  remaining  four resin acids, three fatty
acids/  and  five  bleach  plant  derivatives.   Verification  program
results  for  raw  waste and final effluent discharges were summarized
for each compound by subcategory.  A similar summary was completed for
all of the verification mills where BPT effluent limitations for  BOD!5
and  TSS  were  attained.   Tables  VI-9, 10, 11, and 12 present these
summaries.

Data available to the  Agency  show  that  biological  treatment  (the
technology  basis  of  BPT in those subcategories where high levels of

-------
                                  TABLE VI-8

            EXCLUSION OF TOXIC POLLUTANTS OF POTENTIAL CONCERN FROM
                            PRETREATMENT STANDARDS
Toxic Pollutant
Reason for Exclusion
4.   benzene
Below treatability in raw waste
at all but one mill.
11.  1,1,1-trichloroethane
23.  chloroform
24.  2-chlorophenol
31.  2,4-dichlorophenol
38.  ethylbenzene
Below treatability in raw waste
at all but one mill.

Average POTW removal is 61 percent1
However, the only POTW sampled by
EPA that receives wastewater from
a mill where chlorine is used to
bleach pulp removed 97.8 percent
of the raw waste chloroform1.
Direct discharger removal averages
96.7 percent.  Pass through is
unlikely.

Below treatability in raw waste
at all but one mill.

Below treatability in raw waste
at all but one mill.

Below treatability in raw waste
at all but one mill.
47.  bromoform
55.  naphthalene
65.  phenol
67.  butyl benzyl phthalate
68.  di-n-butyl phthalate
Average raw waste discharge is
below treatability

Below treatability in raw waste
at all but two mills in two
different subcategories.

POTW removal is 83 percent1.
Direct discharger removal ranges
from 0 to 100 percent; average
removal is approximately 91
percent.  Pass through is
unlikely.
POTW removal is 99 percent1.
through is unlikely.
Pass
Below treatability in raw waste
at all but three mills in three
different subcategories.
                                     263

-------
                              TABLE VI-8 (cont.)
70.  diethyl phthalate
84.  pyrene
85.  tetrachloroethylene
86.  toluene
87.  trichloroethylene
106.  PCB-1242
107.  PCB-1254
110.  PCB-1248
111. PCB-1260
121.  cyanide
122. lead
POTW removal is 99 percent1.  Pass
through is unlikely.

Average raw waste discharge is
below treatability.

Below treatability in raw waste
at all but two mills in two
different subcategories.

POTW removal is 91 percent1.  Direct
discharger removal ranges from
39.1 to 100 percent.  Average
removal is approximately 90
percent.  Pass through is unlikely.

Below treatability in raw waste
at all but one mill.

POTW removal is comparable to
proposed BAT2.  Pass through is
unlikely.

Never used in the manufacture of
carbonless copy paper.   Found at
low levels only periodically.

Never used in the manufacture of
carbonless copy paper.   Found at
low levels only periodically.

Never used in the manufacture of
carbonless copy paper.   Found at
low levels only periodically.

POTW removal is 61 percent1.  Direct
discharger removal ranges from
31.2 to 91.6 percent; average
removal is approximately 70
percent.  Pass through is unlikely.

Below treatability in raw waste
at all but four mills in four
different subcategories.
1Based on information contained in Fate of Priority Pollutants in Publicly
 Owned Treatment Works, US Environmental Protection Agency,  September 1982.   (43)

2Based on a comparison of information contained in Fate of Priority Pollutants
 in Publicly Owned Treatment Works, US Environmental Protection Agency, September
 1982 (43) and information contained in the Development Document for Proposed
 Effluent Limitations Guidelines and Standards for Control of Polychlorinated
 Biphenyls in the Deink Subcategory of the Pulp,  Paper and Paperboard Point
 Source Category US Environmental Protection Agency, October 1982 (44).
                                     264

-------
                                                                         TABLE VI-9

                                                  SUMMARY OF INFLUENT CONCENTRATIONS* FOR RESIN AND FATTY ACIDS
                                                   AND CHLORINATED DERIVATIVES FOR ALL VERIFICATION FACILITIES
                                                                                                                            2-
Dehydro- Iso-













M
0
01






Integrated Segment
Dissolving Kraft
Market Bleached
Kraft1
BCT Bleached Kraft
Alkaline-Fine1'
Unbleached Kraft
o Li nerboard
o Bag
Semi-Chewica 1
Unbleached Kraft
jnd Sewi -Chemical
Dissolving Sulfite
Pulp
Papergrade Sulfite3
Croundwood-Fine
Papers
Hi seel tdneous
Treatment
Type

Biological

Biological
Biological
Biological

Biological
Biological
Biological

Biological

Biological
Biologic.) 1

Biological
Biologica 1
Abietic
130

11,800

13
1,043
470

753
6,983
257

1,392

1,949
137

182
1,029
jbieUc
131

3,500

26
861
273

470
7,142
168

607

1,000
423

148
585
pimaric
132

887

--
107
74

283
770
34

547

774
62

29
374
Piaaric
133

1,357

--
115
63

43
1,168
36

152

277
25

76
384
Oleic
134

3,667

383
1,084
276

337
3,133
115

618

1,157
129

174
450
Lino-
leic
135

2,900

1,320
762
283

203
958
122

441

510
63

337
290
Lino- Epoxy- Dichloro- Chlorodehy- Chlorodehy- Trichloro-
lenic atearic atearic droabietic droabietic (uaiacol
136 137 138 139 140 141

817 — 1,433

126 -- — 3
— 78 31
71 -- --44 64

—
1,543
98

266

161 93 6
58 40 -- 123 2 4

250
33 2
Tetrachloro-
guaiacol
142 Total

26,361

5 1,876
8 4,062
7 1,571

2,089
21,697
830

4,023

4 5,931
1 1,067

1,196
3,147
Sec on da ry Fi hers Segment











Drink
o Fine Papers
o Newsprint


Ti SSUP KroM
Was I epaper

Pape rboa rd From
WasLcpdper


Biological
POTW
Biologi ca L
Biological

Primary
Biological

Primary
Biological

837
3,467
e e 7
, 33 /
513

203
54

407
651

2,267
3,700
3 1 267
1,833

417
372

467
479

587
510
150
193

28
32

84
128

127
257
39
80

43
12

41
78

967
1,367
400
410

147
183

290
339

470
750
X f
33
178

—
—

—
63

212 -- -- 467 6 14
167

—

—
--

—
69 413

8 5,962
10,218
*
3,207

838
653

1,289
2,220
*Average concent rat ions pg/1.

1 Data ai one mill were not included due to upset conditions being reflected in the final effluent.

2 Includes Fine Bleached Kraft and Soda subcategories.

3 Includes Pdpcrgrade Sull'ite (Blow Pit Wash) and Tapergrade Sulfite (Drua Waah) subcategorieu.

-------
                                                                       TABLE VI-9  (Continued)

Type
Wastcpaper-MoJ Jed
Product.!* Biological
POTW
Bui Idcra ' Paper atid
Hoofing Kelt PUTW
Primary
Nnnintegrat ed Segment
Nonintegrated-Kine Primary
Papers Bio log i ca 1
Nonintegrated-
T issue Papers Biological
Pr iaary
Non i ul eg rated- Light -
\j weight Papers Biologi cal
& Noiii ntegrated-Filtcr
01 and Nonwoven
Papers Biological
Noniutegraled-
Pape rboa rd Bi o I og i ca 1
Nonintegrated
Mi srei laneous Primary w/
Holding
Pond
Primary

130

210
633

7,559
__

	
207

—
53

—


—

748

—


177
Dehydro-
131

453
573

2,199 1
143

483
433

—
213

--


33

413

14


174
Iso-
132

48
94

,164
--

..
39

—
37

—


—

62

—


84
Lino- Lino-
133 134 135 136

57 493 207
353 123

576 2,237 897 138
--

	
19 65 67

13
10 260

.-


--

25 260

—


54 55 33
Epoxy- Dlcbloro- Chlorodehy- Chlorodehy- Trichloro- Tetrachloro-
137 138 139 UO 141 142 Total

1,468
1,776

14,770
143

483
830

13
573

—


33

1,508

14


577
*Averjge conrtMit rat ions  pg/ 1 .

-------
                                                     TABLE VI-10

                              SUMMARY OK  EFFLUENT CONCENTRATIONS-' FOK RESIN AND FATTY  ACIDS
                               AND C11I.OK1NATEI) DERIVATIVES FOR ALL VERIFICATION FACILITIES


Integrated Segment
Dissolving Kraft
Market Bleached
Kraft1
BCT Blrathe.1 Kraft
Alkaline-Fine*
Unbleached Kraft
o Li nu rhoarJ
o Bag
Semi -Cheat ira 1
Unbleached Kraft am
Semi-Chemical
Dissolving Sulfite
Pulp
Papergrade SuLfite2
Groundwood-Fine
Pjpers
Integrated
Mi seel Janeous
Seconda r^ Fibers Scj
DC ink
o Fine Papers
o Newsprint
o Ti SBUe Papers


Tissue From
Wan Lcpaper

Paperhoard Froa
Waslepaper

Waslcpaper-Molded
Products

Type

Biological

Biological
Biological
Biological

Biological
Biological
Biological
1
Biological

Biological
Biological

Biologica 1

Biological
£aent

Biological
POTV
Partial Flow,
Biological
Biological

Primary
Biological

Primary
Biological

Biological

130

1,467

--
119
3

10
165
39

710

383
76

7

61


12
—
97

72

84
—

—
19

7
Uchydro-
131

520

4
123
5

11
85
14

235

171
246

26

96


49
—
343

253

250
20

96
55

6]
Iso-
132

380

—
21
1

6
15
7

187

115
17

3

31


5
—
18

13

--
—

8
3

—

133

710

--
22
—

1
32
4

106

31
17

5

25


—
—
—

—

--
—

—
—

--

134

333

69
17
41

38
70
33

407

81
70

23

38


49
—
590

243

25
193

—
78

48
Lino- Lino-
135 136

170

55 47
—
4

—
—
14 35

59

8
34

72

1


99
—
—

—

—
—

—
5

—
Epoxy- Dichloro- Chlorodehy- Chlorodehy- Trichloro- Tetrachloro-
137 138 139 140 141 142 Total

473 — — -- 4,053

175
11 1 — 1 315
13 58

66
367
9 13 — — 168

113 -- -- -- -- -- 1,817

108 -- — 2 899
7 -- 39 1 2 509

136

1 — -- -- 253


14 9 237
—
14 -- -- -- 1,062

581

359
213

104
160

116
POTW

-------
                                                                               TABLE VI-10  (Continued)

                                                            SUMMARY OF EFFLUENT CONCENTRATIONS*  FOR  RESIN AND  FATTY  ACIDS
                                                              AND  CHLORINATED DERIVATIVES FOR ALL VERIFICATION FACILITIES
ro
o*
CD
                                                                                                                             1-            2-
                                                       Dehydro-   I»o-                     Lino-  Lino-   Epoxy-  Dichloro-   Chlorodehy-   Chlorodehy-  Trichloro-  Telrachloro-
                                   TreaUMnl   Abietic  abietic piaaric  Pinaric  Oleic    leic   lenic   atearic   stearic    droabictic    droabietic   guaiacol     guaidrol
                                     Type	130     131      132	133	134	135    136      137	138	[3?_	UP	HI         142     Total
Builders' Paper and
   Roofing Felt     POTV
                    Primary

Nonintegrated Segment

Nonintegrated-Fine  Priswry
  Papers            Biological
Nonintegratcd-
  Tissue Papers     Primary
                    Biological
NonIntegraLed-Light-
  weight Papers     Biological
Nonintegraled-Filter
  and Nonwoven
  Papers
NonintegraLed-
   Paperboard
Nonintegrated
   Miscellaneous
                                                          117
                                                           93
                                                           45
                                                           98
                                                                                    27
                                                                                    27
Biological
Biological
Primary w/
Holding
Pond
Primary 8
--
64
200
67 11
--
—
—
--
                                                                                                                                                                           117
 93
 49
U7
 27
                                                                                                                                                                             3

                                                                                                                                                                            64

                                                                                                                                                                           200


                                                                                                                                                                            94
              ^Average  concentration

              1  Data  at one  mill  were not  included due to upset  conditions being  reflected  in  the  final  effluent.

              2  Includes Fine  Bleached KrafL and Soda subcategories.

              3  Includes Papergrade Sulfite  (Blow Pit Wash)  and  Papergrade Sulfite  (Drum Wash) subcategories.

-------
                                                                        TABLE VI-11

                                               SUMMAKY OF INFLUENT CONCENTRATIONS* FOR RESIN AND  FATTY  ACIDS
                                    AND CHLORINATED DERIVATIVES FOR VERIFICATION MILLS MEETING  BPT EFFLUENT LIMITATIONS

                                                                                                                1-            2-
                                         Dehydro-  Iso-                    Lino- Lino-   Epoxy- Oichloro-  Chlorodehy-   Chlorodehy- Trichloro- Tetrachioro-
                     Treatnent   Abietic abietic piraaric  Pinaric  Oleic   leic  lenic   stearic   stearic   droahietic   droabietic   guaiacol     guaijcol
                    	Type   	  130     131	132	133     134	J35	136	[37	138	U?._...	L*P	J*l	...I*?..   .]
integrated Segment
Market Bleached
Kraft' Biological
BCT Bleached Kraft Biological
Alkaline-Fine2 Biological
Unbleached Kraft
o I.inerbbard Biological
Seni-Chemical Biological
Unbleached Kraft and
Seni -Chemical Biological
Papergrade Siilfite3 Biological
Gruundwood-Fine
Papers Biological
Integrated Biological
Mi see 1 laneuus
Secondary Fibers Segioent
Ueiuk
o Fine Papers Biological
o Tissue Papers Biological
Tissue Frosi
Uaslepaper Primary
Biological
Paperboard From
Vastepaper Biological
Non i nte£ rated Segment
Nonintegraled-Fine Primary
Papers Biological
Nonintegrated-
Tiasue Papers Primary
Biological
Nonintegrated-Filter
and Nonwoven
Papers Biological
Non Integra ted-
Pdperbodrd Biological


13
350
470

753
—

1,633
—

305
2,700



837
513

203
54

426

--
207

53
—


—

1,477


26
547
273

470
153

750
18

245
1,400



2,267
1,833

417
372

357

483
433

213
—


33

667


--
51
74

283
29

590
--

55
1,020



587
193

28
32

173

—
39

37
—


--

117


--
58
63

43
11

243
--

76
747



127
80

43
12

150

--
19

10
—


—

25


383 1,320 126 -- -- 3
533 257 — — -- 116
276 283 71 -- -- 44

337 203
69

937 730
97

38 	
1,280 307 -- -- -- 54



967 470 212 -- -- 467
410 178

147
183

342 -- -- 413

-_
6i 67

260
13 	


—

260
                                                                                                                                                      5     1,876
                                                                                                                                                            1,912
                                                                                                                                                      7     1,571

                                                                                                                                                            2,089
                                                                                                                                                              262

                                                                                                                                                            4,88)
                                                                                                                                                              115

                                                                                                                                                              719
                                                                                                                                                            7,508
                                                                                                                                                            5,962
                                                                                                                                                            3,207
                                                                                                                                                              651

                                                                                                                                                            1,861
                                                                                                                                                              483
                                                                                                                                                              830
                                                                                                                                                              573
                                                                                                                                                               13
                                                                                                                                                               33

                                                                                                                                                            2,546
*Average concentrations pg/1

1 Data at one mill were not included due to upset conditions being reflected  iu  the  final  effluent.

2 includes Fine Bleached Kraft and Soda subcategories.

J Includes Paprrgrade SirJiite (Blow Pit Wash) and Papergrade Sulfite  (Drm Wash)  subcategories.

-------
                                                                         TABLE VI-12

                                                 SUMMARY OF EFFLUENT CONCENTRATIONS* FOK KESIN  AND FATTY ACIDS
                                      AND UILON1HATED DKKIVATJVES FOK VERIFICATION MJIJ.S MKKTING  BPT EFFLUENT LIMITATIONS

                                                                                                                 1-           2-
                                          Dehydro-  Iso~                    Lino- Lino-   Epoxy-  Dichlaio-   Clilorodehy-  Cith>ra
-------
resin acids, fatty acids, and bleach plant derivatives are  generated)
is very effective in reducing raw waste loadings of resin acids, fatty
acids, and bleach plant derivatives (see Table VI-13).  Almost no data
are  available  for  potential BAT treatment technologies such as foam
separation,  chemically  assisted  clarification,  ion  exchange,   or
activated  carbon.   In  addition,  analytical  methods  have not been
developed for measuring these  nonconventional  pollutants.   For  the
above   reasons,   EPA   cannot  establish  BAT  effluent  limitations
guidelines and NSPS for control  of  resin  acids,  fatty  acids,  and
bleach plant derivatives on a national basis.

Wastewaters  discharged  from mills in the pulp, paper, and paperboard
industry are generally nutrient deficient.  It is  normally  necessary
to  add nutrients, such as ammonia and phosphorus, to ensure efficient
operation of biological treatment systems.  However, there  are  eight
mills in three subcategories where ammonia-based cooking chemicals are
used in the pulping process.  The Agency did not propose establishment
of  ammonia limitations because there were very limited data available
on ammonia discharges from these eight mills.  EPA  sought  additional
data  and  requested  comments  on  the necessity for establishment of
uniform national standards for control of ammonia in the pulp,  paper,
and paperboard industry.

Some  commenters  stated  that  ammonia  should  not be regulated on a
uniform national basis because of the absence of wide-spread receiving
water quality problems from routine industrial discharges of  ammonia.
They  stated  that  ammonia  occurs  naturally  in the environment, is
readily metabolized to nitrite and nitrate, and,  therefore,  is  best
regulated  on a case-by-case basis.  Other commenters urged the Agency
to collect additional data on the  level  of  ammonia  discharges  and
applicable   treatment  technologies  to  determine  whether  effluent
limitations were necessary.

After reviewing the comments  and  all  available  ammonia  data,  EPA
decided  not  to  establish  ammonia  limitations.   In  reaching that
decision, the Agency confirmed that there  are  only  eight  mills  in
three  subcategories where ammonia-based cooking chemicals are used in
the pulping process.  Resulting ammonia raw waste concentrations range
from 20 to 340 mg/1.  After application of BPT, about 12 to 32 mg/1 of
ammonia remain, depending on the  subcategory  considered.   When  BPT
effluent limits are met, about 3.6 million kg (8.0 million pounds) per
year of ammonia are removed from industry raw wastes.

EPA identified two technologies capable of removing additional ammonia
from  pulp, paper, and paperboard industry wastewaters: (a) conversion
of existing biological treatment systems to operate in a nitrification
mode and (b) conversion to the use  of  a  new  chemical  base  (i.e.,
sodium  or  magnesium).  These technologies are discussed in detail in
Sections VII and VIII and Appendix A of this document.

The Agency  investigated  the  ammonia  removal  capability  of  these
technologies  and also estimated the economic impact that would result
from establishing ammonia limitations.   Uncertainties  exist  in  the
                               271

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                                                     TABLE  VI-13

                                          REMOVALS  OF RESIN AND FATTY  ACIDS
                                             AND  CHLORINATED DERIVATIVES
                                                             All  Verification Milli
  Verification Mills
Meeting BPT Liaitationi
Concentration (Mft/1)
Subcategory
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine
Unbleached Kraft
o Linerboard
o Bag
Seoi-Chenical
Unbleached Kraft and
S (Mi-Chemical
Sulfite Dissolving Pulp
Groundwood-Fine Papers
Integrated Miscellaneous
Secondary Fibers Segment
Deink
o Fine Papers
o Newsprint
o Tissue Papers


Tissue From Wastepaper

Paper-board From Wastepaper

Wastepaper-Molded Products

Builders' Paper and Roofing

Nonintegrated Segment
Nonintegrated-Fine Papers

Nonintegrated-Tissue Papers

Nonintegrated-Lightweight Pi
Nonintegrated-Filter and
Nonwoven Papers
Nonintegrated-Paperboard
Nonintegrated Miscellaneous

1 Data at one mill were not
Treatment Type

Biological
Biological
Biological
Biological

Biological
Biological
Biological

Biological
Biological
Biological
Biological


Biological
POTW
Partial Flow,
Biological
Biological
Prinary
Biological
Primary
Biological
Biological
POTW
Felt POTW
Primary

Primary
Biological
Primary
Biological
ipers Biological

Biological
Biological
Primary w/Holding Pond*
Primary
included due to upset conditions
Influent

26,361
1,876
4,062
1,571

2,089
21,697
830

4,023
5,931
i nfi7
L t UO /
1,196
3,147


5,962
10,218
4,492

3,207
838
653
1,289
2,220
1,468
1,776
14,770
143

483
830
573
13
—

33
1,508
14
577
Effluent

4,053
175
315
58

66
367
168

1,817
899
COQ
OUV
136
253


237
—
1,062

581
359
213
104
160
116
—
—
117

93
49
127
27
—

3
64
200
94
being reflected in
Percent Concentration (Mg/1)
Removal

85
91
92
96

97
98
80

55
85
«9
D*t
89
92


96
—
76

81
57
67
92
93
92
—
--
18

81
94
72
0
—

91
96
0
84
the final
Influent

__
1,876
1,912
1,571

2,089
—
262

4,883

719
7. SOS


5,962
—
—

3,207
838
653
—
1,861
—
—
—
—

483
830
573
13
—

33
2,546
—
•"
effluent.
Effluent

__
175
245
58

66
—
13

2,194

69
423


237
—
--

581
359
213
--
133
--
—
—
—

93
49
127
27
—

3
128
—
"

Percent
Removal

_„
91
87
96

97
«
95

55
inn
iUU
90
94


96
--
—

82
57
67
—
93
—
—
--
—

81
94
78
0
—

91
95
—
— —

2 Includes Fine Bleacbed Kraft and Soda subcategories .
3 Includes Papergrade Sulfite (Blow Pic Wash)  and  Papergrade  Sulfite  (Drum  Wash)  subcategories.

* Treatment system detention time is three days.
                                                       272

-------
modifications required to convert existing pulp, paper, and paperboard
biological treatment systems to operate in a nitrification mode (i.e.,
proper   detention  time,  sludge  age,  and  operating  temperature).
Therefore,  the  Agency   assumed   that   ammonia   limitations,   if
established,  would  be  attained  through  conversion, to a different
(non-ammonia) chemical base.

The Agency estimates that an additional 2.02 million kg (4.45  million
pounds)   per  year  of  ammonia  could  be  removed  from  wastewater
discharges  from  the  eight  mills  where  ammonia  -  based  cooking
chemicals are used.  Capital and total annual costs at the eight mills
would  be $120 million and $36.3 million, respectively (1978 dollars).
These costs would result in production cost increases ranging from 2.9
to 15.4 percent and might cause the  closure  of  four  of  the  eight
mills.

Because  of  these  projected  severe  economic  impacts,   the  Agency
determined  that  establishment  of  uniform  national  standards  for
control  of  ammonia  is  unwarranted.   If  required to protect water
quality, ammonia limitations are best established  on  a  case-by-case
basis.
                                273

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                             SECTION VII

                   CONTROL AND TREATMENT TECHNOLOGY


INTRODUCTION

This section describes the control and treatment technologies  in  use
and  available for application at pulp, paper, and paperboard mills to
reduce wastewater and/or wastewater pollutant  discharge.   There  are
two  major  technology  approaches  that may be employed: (a) in-plant
production process controls and  (b)  effluent  treatment  technology.
Production  process  controls  are  those  technologies implemented to
reduce the effluent volume and pollutant loading discharged  from  the
manufacturing  facility.   Effluent  treatment  technologies are those
end-of-pipe  treatment  systems  used  to  reduce  the  discharge   of
pollutants  contained in mill effluents.  In most instances, pollution
abatement programs developed for use at individual mills include  both
approaches.   In  some cases, production process controls and effluent
treatment technologies can yield  comparable  results.   For  example,
suspended solids removal equipment may be employed internally within a
mill  to  allow  for  reuse  of  clarified  water  in  the process and
recovered  solids  in  the  product;  at  another  mill,   end-of-pipe
technology  may  be  relied  on to a greater extent to produce similar
effluent characteristics.

PRODUCTION PROCESS CONTROLS COMMONLY EMPLOYED BY THE PULP,  PAPER,  AND
PAPERBOARD INDUSTRY

Many  alternative  approaches  have been taken within the pulp,  paper,
and paperboard industry in implementing  process  controls  to  reduce
effluent  volume  and  waste loads.  In earlier development documents,
technologies were identified that are  commonly  employed  within  the
industry  to control pulping, bleaching, washing, liquor recovery, and
papermaking processes.(45)(46)(47)(48) Tables VII-1 and 2 present  the
production  process control technologies on which BPT and BAT effluent
limitations were based.  Pollution abatement is not the  sole  driving
force  for  implementation  of  production  process controls.  In many
cases, the concern for consistent production of high quality  products
with  minimum  loss of substrate results in the development of process
controls that reduce raw waste loadings.  Production process  controls
have always been a part of integrated pulp and papermaking operations,
their  primary  function  being the control of product characteristics
and improvement of process economics.

As part of  the  data  request  program,  production  process  control
information  was  received for a total of 644 mills, 610 of which were
still in operation as of April 12, 1982.  Production process  controls
at  these mills are generally applied in eight specific mill areas and
also include provision for the recycle  of  effluent.   The  following
discussions relate to production process controls applicable to the:

o    woodyard/woodroom,
                               275

-------
                                  TABLE VII-1
                    PRODUCTION PROCESS CONTROL TECHNOLOGIES
                               IDENTIFIED AS THE
            BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
High Level Alarms on Tanks
Decker Filtrate for Sulfite Pit
  Dilution or Vacuum Washer
  Showers
Prehydrolysate Disposal by Burning
Evaporator Condensates for Brown Stock
  Washer Showers
Recook Screen Room Rejects
Use of CL02 Waste Acid for Tall Oil
  Manufacture or Add to Black Liquor
  for Recovery
Use of Green Liquor Dregs Filter
White Water Showers for Wire Cleaning
Broke Storage and Overflow Prevention
Install Saveall
Use of Mill Wastewater in Woodyard
Knot Collection Disposal or Reuse
Turpentine Collection
Soap Collection
Sulfite Red Liquor Evaporation and
  Disposal
Countercurrent Washing -- Deink
Close-up Screen Room with Reuse of
  Decker Filtrate
Jump State Countercurrent Wash in
  Bleach Plant with Reuse of
  Chlorination Filtrate
Reuse Kiln Scrubber Water
Evaporator Condensate Used as Causti-
  cizing Makeup
White Water Storage During Upsets and
  Reuse as Pulper Dilution Water
                                  TABLE VII-2

                    PRODUCTION PROCESS CONTROL TECHNOLOGIES
                               IDENTIFIED AS THE
               BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
Cooling Water Segregation and Reuse
Dry Barking
Evaporator Surface Condenser
Evaporator Boilout Tank
Caustic Area Spill Collection
Reuse Vacuum Pump Seal Water
Stock and Liquor Spill Collection
Lime Mud Pond
Filter and Reuse Press Effluent
Paper Mill Stock Spill Collection
High Pressure Showers for Wire
  and Felt Cleaning	
                                         276

-------
o    pulp mi 11,

o    washers/screen room,

o    bleachery,

o    evaporation and recovery area,

o    liquor preparation area,

o    papermill,

o    steam plant and utilities,

o    recycle of effluent, and

o    substitution of chemicals.

In order to comply with  BPT  effluent  limitations,  some  degree  of
production  process  control  was  implemented at most mills.  In this
section, some specific production process controls that are applicable
to each industry subcategory are described.  Additional controls  that
may  be  applicable  at  individual  mills, rather than all mills in a
subcategory, are also described.  Table VII-3 summarizes  the  control
items that have been identified and discussed.

Woodyard/Woodroom

Production  process controls that reduce raw waste loading in woodroom
area include:  a) conversion to mechanical or dry systems or  close-up
of wet operations and b) the segregation and reuse or direct discharge
of uncontaminated cooling waters.  These controls, their applicability
within  the various subcategories, and their general effectiveness are
described below.

Close-Up  or  Dry  Operation.   This  production  process  control  is
commonly  practiced  at  most mills; however, it has not been commonly
employed at mills in the dissolving sulfite pulp  and  groundwood-fine
papers  subcategories.   For  mills  in  the  dissolving  sulfite pulp
subcategory, discharge of wastewater from  hydraulic  barking  systems
can  be  eliminated  through  installation  of  a  collection tank and
cleaning system to enable recycle of water; pulp mill  wastewater  can
be  used  as  make-up  to the system.  At mills in the groundwood-fine
papers  subcategory,  conversion  to  dry  barking  and  the  use   of
mechanical  conveyors  is  possible.   In  colder  climates  it may be
necessary to use steam in  the  barking  drums.   These  controls  are
illustrated in Figures VII-1 and VII-2.

Application of these controls in the barking area of the woodroom will
result  in  reduced  water  use and a lower water content in the bark.
With drier bark, combustion (and heat reclamation) is possible without
further processing.
                                277

-------
                                  TABLE VII-3

                    PRODUCTION PROCESS CONTROL TECHNOLOGIES
                AVAILABLE FOR REDUCTION OF EFFLUENT VOLUME AND
                              POLLUTANT LOADINGS
Woodyard/Woodroora
     Closeup or dry operation
     Segregate cooling water

Pulp Mill
     Reuse blow condensates
     Reduce thickener overflow (groundwood)
     Spill collection

Brown Stock Washers and Screen Room
     Add third or fourth stage washer
     Recycle more decker filtrate
     Cleaner rejects to landfill

Bleaching Systems
     Countercurrent or jumpstage wash
     Evaporate caustic extraction stage filtrate

Evaporation and Recovery
     Recycle of condensates
     Replace barometric condenser with surface condenser
     Boilout tank
     Neutralize spent sulfite liquor
     Segregate cooling water
     Spill collection

Liquor Preparation Area
     Installation of green liquor dregs filter
     Lime mud pond

Papermill
     Spill collection
     Improvement of savealls
     Use of high pressure showers for wire and felt cleaning
     Whitewater use for vacuum pump sealing
     Papermachine Whitewater use on wire cleaning showers
     Whitewater storage for upsets and pulper dilution
     Recycle of press water
     Reuse of vacuum pump water
     Additional broke storage
     Installation of wet lap machines or other screening devices
     Segregate cooling water
     Cleaner rejects to landfill
     Fourth stage cleaners

Steam Plant and Utility Areas
     Segregate cooling water
     Lagoon for boiler blowdown and backwash waters

Recycle of Treated Effluent

Chemical Substitution

                                      278

-------
                                            •Aft*  COLLECTION  CONVKYOMt
tXJ
         LEGEND

         —.  exirriNfl

         -.— — —.-  NEW
                                 /•""X














^"-V







,






('net




II
II
II
II
• AftKIN* DRUMS

IMI mt mmn
                                                       . f
                          •O Li. CTIAW MAIN
                                                                                  FIGURE  "SJL- I
                                                                    CONVERT  HYDRAULIC BARKING
                                                                         SYSTEM TO DRY SYSTEM

-------
                                  O— — —
                                                    — —
                                 OUTLINE CLIVATION OP  CONVEYORS

                                                                                        WOODROOM
                                                                                        CONVEYOR
ro
Co
O
                                                                  n
                         TYPICAL  CONVEYOR  SECTION
LEGEND

	
EXISTING
NEW
                                                                                      FIGURE "SO.- 2

                                                                               FLUME REPLACED  BY

                                                                             MECHANICAL CONVEYOR

-------
Close-up of the woodroom by conversion to dry debarking or  a  closed-
cycle  hydraulic system typically results in flow reductions of 8.3 to
12.5 kl/kkg (2 to 3 kgal/t) and TSS reductions in the range of 5 to 10
kg/kkg (10 to 20 Ib/t).(28)(49)(50)  Factors affecting  the  level  of
reduction  are  the  source of water used in the woodroom, the type of
barking operation employed,  the  type  of  wood  processed,  seasonal
factors,  and the ultimate disposal technique.

Segregation   of_  Cooling  Water.   This  control  item  involves  the
collection of water used for motor, chip blower, and bearing  cooling.
This  non-contact  cooling  water can be returned to an existing water
collection tank.  At mills in some subcategories, this  control  could
also  include  the return of condensate from the heating system to the
steam plant through a separate line.  The technology is illustrated in
Figure VII-3.

Woodroom non-contact cooling water segregation has been  neglected  at
most  mills  in  the integrated subcategories.  It is designated as an
applicable production process control  technology  in  the  integrated
subcategories  where  woodrooms  are employed.  Its implementation can
result in a measurable flow reduction and significant energy  savings.
Segregation  of  cooling  water via a separate discharge can result in
effluent flow reduction in the range of 1.3 to 4.2 kl/kkg (0.3 to  1.0
kgal/t),   depending reduction ranges from about 1.3 to 4.2 kl/kkg (0.3
to 1.0 kgal/t), depending on the  subcategory.   Little  reduction  in
BODI>   or  TSS  raw  waste  loads  result  from  application  of  this
technology.

Pulp Mill

Production process controls that reduce raw waste loadings in the pulp
mill area include: a) reuse of digester relief and  blow  condensates,
b) reduction of groundwood thickener overflow, and c) spill collection
in  the  brown  stock,   digester,  and  liquor  storage  areas.  These
controls and their applicability are described below.

Reuse  Relief  and  Blow  Condensates.   Digester  relief   and   blow
condensates may be major contributors to the total BODS^ discharge from
a  mill.   Particularly with continuous digesters, the relatively small
flows are highly contaminated with foul  smelling  organic  mercaptans
and  other  organic  compounds.  Figure VI1-4 illustrates a system for
reusing blow condensates.  This control is  an  applicable  technology
for all of the kraft and soda subcategories.  Digester blow condensate
is  collected  in  a  tank and pumped to the area of greatest benefit.
The collection tank should be equipped with a  conductivity  alarm  to
alert  the operator of unusually strong condensate.   Areas where blow
condensates can be reused include: (a)  addition  at  the  salt   cake
dissolving tank and (b)  use at the lime kiln for mud washing.

If digester condensates,  including relief condensates,  are stripped or
further  treated  (i.e.,   reverse osmosis) to reduce BOD5_, they can be
reused in other process areas including  (a)  addition  at  the  first
                              281

-------
     STEAM
                                                            FRESH

                                                            WATER

WOOORO
1 '
1
oo I'LCN». ••!••*
ro \. t \
F I
•
•



DM HEATER CHIP 1 BLOWER BAKKINS 1 DRUM TRUNNIONS CHIP 1 SCREE
AND \ MOTOR 1 1 MOTOI
jU-'
h--*i (LCN|....i
1 1 VTX 1
t- H»l f"W**-
•• *
J
1
1
-•»«l»l
\f CONOENSATE TANK j f COOLIN8 WATER |
i * A TANK T
f SEWER T SEWER
STEAM PLANT
CONOENSATE
   TANK
WATER COLLECTION

TANk"AT* rTEAM^LANT
LE6ENP
EXISTINS
NEW
                                                                               3DI-3
                                                  SEGREGATE WOODROOM NON-CONTACT
                                                       COOLING WATER AND CONDENSATE

-------
                        DISESTER BLOW
ro
CO
co
COMPENSATE








1 V
t
4







X
»
»







T
i
i
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IOIOESTER
CONPENSATE
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1




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                                                                  "N
                                                                          CAUSTICIZINO AREA
                                     SKWCM
LEGEND
EXISTINS
NEW
                                                                                    FIGURE 3DE-4

                                                            REUSE OF DIGESTER BLOW CONOENSATE

-------
shower  of  the last stage brown stock washer or (b) addition directly
to the black liquor.

Wastewater BOD5_ reductions ranging from 0.9 to 3.0 kg/kkg (1 .8 to  6.0
Ib/t)  can  .be  achieved  by  incorporating  digester  relief and blow
condensates back into the  black  liquor  recovery  cycle.(51)(52)(53)
Wastewater  reduction  at alkaline (kraft and soda) pulp mills through
the reuse of increasingly dirtier condensates to replace  fresh  water
results  in higher concentrations of volatile organic sulfur compounds
in wash water and dilution water.  While a net reduction in  BOD5_  may
result,  the possibility of releasing these volatile compounds through
brown  stock  washer  vents,  screening  operations,  and  smelt  tank
dissolving operations is increased.

Until  recently,  emission regulations dealt only with the particulate
and TRS emissions from the recovery furnace itself.  With an increased
concern for reduction of overall emission levels, a higher  degree  of
scrubbing, collection, and combustion or disposal of volatile organics
may  have to be considered prior to implementation of condensate reuse
techniques.

Reduce Groundwood Thickener  Overflow.   At  a  typical  mill  in  the
groundwood-f ine   papers   subcategory,   excess   thickener  filtrate
overflows to the seVer at a rate of up to 16.7 kl/kkg (4.0 kgal/t)  of
pulp  produced.(54)  This  overflow represents a small source of fiber
loss and contributes 5.0 kg/kkg (10.0 Ib/t) of TSS at a typical  mill.
Modifications shown in Figure VII-5 can be implemented to close up the
white   water   system,   essentially  eliminating  thickener  filtrate
overflow to the sewer.  A small bleed would be maintained  to  control
the  build-up  of  pulp fines in the final accepted groundwood.  Water
make-up to the groundwood system would be  excess  papermachine  white
water.  A heat exchanger would be required during the warmer months of
the  year  to control heat build-up in the filtrate.  Fresh water used
as cooling water in the heat exchanger would subsequently be  returned
as  make-up  to the papermachine systems or discharged via the thermal
sewer to balance mill white water heat load.

Spill Collection.  Improved spill collection systems can  be  employed
in  the  digester,  liquor  storage,  and brown stock areas.   A system
designed to recover leaks, spills, dumps, and  weak  liquor  overflows
could  result in a recovery of approximately 1.5 to 3.5 kg/kkg (3.0 to
7.0 Ib/t) of BOD5_. (55) In the brown stock  area,  the  combination  of
stock  and  liquor  spills  would generally be combined with the brown
stock entering the first stage washer vat.  This control is designated
as an applicable technology in 10 subcategories.  A pulp  mill  liquor
spill system is illustrated in Figure VII-6.

A  separate  spill  collection  system can be employed using a sump in
conjunction with conductivity measurements to detect and  collect  any
leaks,  spills,  or  overflows  from the pulp mill digester and liquor
storage  tanks.   Any  liquor  recovered  could  be  diverted  to  its
appropriate  tank  or  to  a  spare  liquor  tank.  This technology is
considered applicable for the  dissolving,  market,  BCT  (paperboard,
                             284

-------
ro
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                        MKmmwHm
                        WTEft MAKtlN*
                      1 f.C. V

                            *
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                                WATER MAKE-UP
                           MINOCMI
                                                               THICKCNEH
                                                               TMICKCNIN
                                                               FILTRATE
                                                               CHEtT
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f—— ~
       1

       I

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                                            !  ^EEE]  \
                                              f~IL	Z-.  I
                                 FRESH WATER  J
                                                    -v,.
         MEAT

         EXCHANGER
  |_ MACHINE! _^

                          FIGURE  mi-5

                    REDUCE GROUNDWOOD

           THICKENER FILTRATE OVERFLOW

-------
         PULP HILL FLOOR DRAIN*

          LLLL
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LEGEND
i__<__ .•
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NEW
                                     ,...
                               j	
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                                  •CWCR
                                               LAVOON
                                                    FIGURE YE-6

                                           PULP MILL SPILL COLLECTION

                                                   DIGESTER AREA

-------
coarse,  and  tissue), and fine bleached kraft and soda subcategories;
modified systems could also be used in  the  three  sulfite  and  some
groundwood and deink subcategories.

Brown Stock Washers and Screen Room

Production  process  controls  that  reduce  raw waste loadings in the
washer and screen room areas include: a) addition of a third or fourth
stage washer or improved washing  efficiency  by  replacement  with  a
properly  sized  system,  b)  recycle  of more decker filtrate, and c)
discharge of cleaner rejects to landfill.

Addition  o_f  a  Third  o_£  Fourth  Stage  Washer.   This  control  is
applicable to mills in the kraft, soda, semi-chemical, both papergrade
sulfite,  and  deink  (newsprint  product  sector) subcategories.  The
control includes the addition of a fourth-stage washer  to  all  kraft
and  soda  washing lines and a third stage washer to all semi-chemical
and papergrade sulfite washing lines.  The addition of another  washer
stage  is  illustrated  in  Figure VII-7.  This control is primarily a
BOD5_ reduction measure as dissolved solids  losses  from  the  pulping
operation are reduced.

Improved  washing facilitates bleaching and results in lower bleaching
chemical costs.  In terms of raw waste load,  the  main  effect  is  a
reduction  in  BOD5_  ranging  from  about  2.5  kg/kkg  (5.0 Ib/t) for
dissolving kraft mills to as much as 4.0 kg/kkg.  (56)(57)(58)

Recycle of_ More Decker Filtrate.  This control item was considered  in
the  establishment  of  BPT  effluent  limitations.   It  is generally
applicable to the alkaline (kraft and  soda),  groundwood,  and  deink
subcategories.   Tightening up by using decker filtrate on brown stock
washer showers can substantially reduce decker  filtrate  overflow  to
the sewer, thus reducing effluent flow and BOD5_.  Efficient washing on
the  decker  is required to reduce liquor carry-over to bleaching.  At
many mills in the subcategories mentioned, a considerable quantity  of
decker  filtrate  is  reused  in the screen room as dilution water.  A
schematic of this control is shown in Figure VII-8.

Typically, reductions of about 4.2 kl/kkg (1.0 kgal/t) of flow and 0.5
to 1.0 kg/kkg (1.0 to 2.0  Ib/t)  of  BOD5_  can  be  realized  through
implementation of this production process control.(59)(60) Use of this
technology  requires  a detailed study at each mill; the efficiency of
the existing washing  and  screening  systems  should  be  taken  into
account  prior  to  further  modification.   This  production  process
control is now  being  practiced  to  a  limited  degree  and  can  be
considered as an applicable control technology at new source mills.

Cleaner  Rejects  to  Landfill.   Centricleaner rejects and continuous
screen rejects from the screen room are generally sewered directly and
processed in the wastewater treatment plant.  Most  of  these  rejects
are  removed  in  the  primary  clarifier  and  handled  in the solids
dewatering system; primary solids are often mixed with solids from the
"secondary clarifier.   Dry collection of  screen  and  cleaner  rejects
                               287

-------
                                         *»RO ITAM
                                          WASHER
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            * ILLUSTRATION ASSUMES EXISTENCE OF
              THREE STAGES OF WASHING
                            FIGURE  21-7

                  ADDITION OF  THIRD OR

             FOURTH  STAGE PULP WASHER

-------
                     •HIT! WATCH

                        TANK
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                   UAtT
                   •EOnLfTQCKWASHCM
             LEGEND
                                                                        MCOVtRt
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                                                                        eCKCM
                                                                      SEWER
                                                                                          FIGURE 1OE-8

                                                                             RECYCLE DECKER FILTRATE

-------
with  separate  discharge  to landfill,  as shown on Figure VII-9,  will
reduce TSS raw waste loads.

Typically 2.0 to 3.0 kg/kkg (4.0 to 6.0  Ib/t) of TSS would be  removed
from  the raw waste in most of the integrated subcategories.   However,
this may not affect final effluent characteristics, depending  on  the
existing  primary  clarifier  solids  loading.   If  the  clarifier is
overloaded,  TSS reduction can have an appreciable  effect  on  overall
treatment  plant  performance.   If the  existing clarifier can readily
accommodate this loading, it may be advantageous to continue  sewering
these  wastes.   The  accompanying  fibrous  material,  when mixed with
biological solids,  can aid in dewatering of the combined solids.  This
technology is considered applicable for   the  tissue  from  wastepaper
subcategory  for  the  purpose of purging dirt from the effluent;  this
allows for recycle of effluent and recycle of sludge to  the  furnish.
EPA  assumed  that adequate clarification is already provided at mills
in the remaining subcategories.

Bleaching Systems

The extent of bleaching varies widely  within  the  industry.   Single
stage  operations  are often used at groundwood and deink mills, while
three  bleaching  stages  (i.e.,  CEH)  are  common  at  sulfite   and
semi-bleached kraft mills.  Five or six  stages (i.e., CEDED)  are often
used  at  fully  bleached  kraft  mills.   In  multi-stage  bleaching,
effluents from the first two stages  are  commonly  sewered,   although
some  of  the  first stage chlorination  filtrate may be used to dilute
incoming washed brown stock.  Bleachery  effluent is a major source  of
process  wastewater  discharged  from  integrated  bleached  kraft and
sulfite mills.  The following technologies address further steps  that
may   be   implemented   to  reduce  effluent  flow  from  multi-stage
bleacheries.

Counter cur rent oj: Jump-Stage Washing.  This control is  applicable  at
all  kraft  and  soda  mills and at many sulfite mills.  In jump-stage
washing, the filtrate from the second chlorine dioxide washer is  used
on the showers of the first chlorine dioxide washer; the filtrate from
the  first  chlorine dioxide washer is then used on the showers of the
chlorine washer.  Filtrate from the second caustic washer is  used  on
the  first  caustic  washer.   Jump-stage washing, instead of straight
countercurrent washing, is necessary if  the first and  second  caustic
washers  are  constructed  of  materials  that  are  not  sufficiently
corrosion resistant (i.e.,  304  stainless  steel  or  rubber  covered
carbon  steel  rather  than  the more resistant 317 stainless steel or
titanium).  Water reduction to levels typical of  the  discharge  from
three  stage  bleacheries  may  be obtained.  Figure VII-10 presents a
schematic for jump-stage washing.

In newer mills where  all  bleach  plant  washers,  pumps,  pipelines,
repulpers,  and other equipment are constructed of 317 stainless steel
or equivalent, full countercurrent washing may be implemented.   Fresh
water  or  preferably pulp machine or papermachirne white water  is used
for the last stage washer showers and for dilution after high  density
                               290

-------
ACCEPTS
             THIRD OH
             FOURTH STASE
             PULP  MILL
             CLEAN!**
                                       8IDIHILL SCREEN
                                               DUMPSTER TO
                                               LANDFILL
                                                 TO REUSE
                                                 «..._..
                                                 OR SEWER
                REJECTS
                  SUMP
ACCEPTS
  TANK
                                                                      FIGURE  3ZE-9
                                                   CLEANER REJECTS TO LANDFILL

-------
                           • HITI  W«t«K
ro

-------
bleached pulp storage.  All washer filtrate is used on showers and for
dilution of pulp from the preceding stage.  Compared to a bleach plant
with  all  fresh  water showers, the conversion to full countercurrent
washing can reduce bleach plant effluent volume by up to  80  percent.
Figure  VII-11  presents a schematic for a full countercurrent washing
system.

Full countercurrent bleaching using chlorine dioxide necessitates  the
use  of  317 stainless steel or titanium materials of construction for
all washers, pumps, and pipelines in the system.  If  not  already  in
place,  such equipment is extremely expensive; by contrast, jump-stage
washing sequences can often  be  readily  implemented  using  existing
major  equipment  with  relatively  minor  alterations,  such  as  the
addition of pumps and pipelines to service additional showers.

Earlier studies proposed the use of  full  countercurrent  washing  or
jump-stage  washing  in  multi-stage  kraft  and soda pulp mill bleach
plants.  Jump-stage washing or modifications  of  such  a  system  are
utilized  at  many mills.  Bleach plant water use has declined sharply
as a result of these changes.  Flow reductions of 8.3 to  25.0  kl/kkg
(2.0 to 6.0 kgal/t) are possible through improved countercurrent reuse
of filtrates in the bleaching sequence at mills in the alkaline (kraft
and  soda)  and  sulfite  subcategories.   For  the simpler papergrade
sulfite bleach  plants,  savings  would  be  about  29.2  kl/kkg  (7.0
kgal/t). (53X61 X62)

Evaporate  Caustic  Extraction  Stage  Filtrate.   This  control is an
applicable control technology at mills in the dissolving sulfite  pulp
subcategory.   The  hot  caustic  extraction stage would have a three-
stage washing system similar to a  red  stock  washer  with  carefully
controlled  hot  showers.   The  effluent  from  this  stage  would be
evaporated and incinerated or disposed of separately from the rest  of
the  bleachery  effluent;  therefore, flow would be kept at a minimum.
Implementation of this control will greatly reduce the BOD5_  loadings,
from  41.4  to  104.4  kg/kkg (82.8 to 208.8 Ib/t), depending upon the
grade of dissolving sulfite pulp produced.(63) A flow diagram for  the
bleaching end of this system is shown in Figure VI1-12.

Evaporation and Recovery

Production  process  controls  that  reduce  raw waste loadings in the
evaporator and recovery areas include: a) recycle of  condensates,  b)
replacement  of  the barometric condenser with a surface condenser,  c)
addition of a  boil-out  tank,  d)  neutralization  of  spent  sulfite
liquor,  e)  segregation  of  cooling  water,  and  f)  various  spill
collection measures.  These controls are discussed below.

Recycle  o_f  Condensates.   Reuse  of   evaporator   condensates   was
identified   as  part  of  the  best  practicable  control  technology
currently available. (48) The analysis of survey  responses  indicates
that  considerable progress has been made in utilizing essentially all
condensates.   Only  in  the  BCT  (paperboard,  coarse,  and  tissue)
bleached  kraft  and  the  semi-chemical  subcategories does extensive
                               293

-------
FRESH
                                                             PAPER MACHINE
                                                             WHITE WATER
                                                                OR
                                                             FRESH WATER
WATER
   WASHER
[TJ
I FILTRAT
I TANK

SEWER
             71
FILTRATE   TOWER
              Lu
                 SEWER
V
SEWER
u
V
SEWER
ug
                  SEWER
.EGEND
        EXISTING
   . —.—• NEW
           FIGURE  3nr-n
     FULL COUNTERCURRENT
  WASHING IN BLEACH PLANT

-------
                                             RED HUlP WASHER
                   HOT WATER
vo
en
*'"'         J
Kl>-—•- — — — ——-tX-J
                                                                                EWER
                                                                              WASHER
                                                                              FILTRATE
LEGEND

— — — —..
EXISTING
                             WASHER
                            FILTHATE
                              TANK
 SIDE HILL_ __
'SCREENS
 ft  x_AN   »tweR
 I  \._s WASHER
~*   ~ FILTRATE
       TANK
                             TOWER               FIGURE 301-12
                                BLEACHERY JUMP STAGE WASHING
                             AND CAUSTIC EXTRACTION FILTRATE
                         COLLECTION-DISSOLVING SULFITE PULP

-------
increased recycle of  condensate  appear  feasible  when  compared  to
present modes of operation.   At BCT bleached kraft mills,  improved use
of  condensate  is projected to eliminate up to 7.5 kg/kkg (15.0 Ib/t)
of BOD5_ from the raw  waste.   At  semi-chemical  mills,  where  lower
levels  of substrate are dissolved, the reuse of condensate represents
a far lower BOD5_ saving, generally less than 0.25 kg/kkg (0.50  Ib/t).
A flow schematic for this system is shown in Figure VI1-13.

Replace  Barometric  Condenser.   At  most  mills  in  all  integrated
subcategories, except for dissolving  kraft,  surface  condensers  are
used.   Similarly,  in  the  dissolving  kraft subcategory, barometric
condensers can be replaced with surface condensers,  thus  assuring  a
clean,  warm  condenser  water  stream  that can be reused.  This also
results in a smaller concentrated stream of  condensate  that  may  be
reused  in  the causticizing area or in the brown stock washer area or
that can be steam stripped and reused for  other  purposes.   Existing
barometric  condenser seal tanks could be reused as the seal tanks for
new surface  condensers.   The  air  ejectors  would  be  retained  as
stand-by,   for use during system start-up.  A cooling water pump would
be provided to pump mill  process  water  through  the  condenser  and
return it to the process water main.

In  summer,  the  cooling  water  may be too hot to return entirely to
process.  Automatic temperature control could be implemented to divert
excess water to a non-contact water thermal sewer and return  only  an
acceptable  amount  to  the process water line.  A new condensate pump
could be provided to pump  to  the  required  discharge  point  or  to
washers where the condensate could be reused.  This production process
control  is  illustrated  in  Figure  VII-14.   Implementation of this
technology would result in less than a  0.5  kg/kkg  (1.0  Ib/t)  BOD5_
reduction   and   less   than   a   4.2   kl/kkg   (1.0  kgal/t)  flow
reduction.(53)(64) This technology is applicable at new mills.

Addition of_ a Boilout Tank.   This control is applicable  at  mills  in
the  dissolving  kraft and market bleached kraft subcategories.  Water
for the boilout would be pumped to the evaporators  from  the  boilout
tank,  which  would  be  full  at  the start of the process.  When the
concentration of the black  liquor  from  the  evaporators  starts  to
decrease,   the  flow  could be diverted to the weak black liquor tank.
When the concentration decreases further to a predetermined value, the
flow could be  diverted  to  the  boilout  tank.   Overflow  from  the
condensate  tank,  which occurs during boilout because of an increased
rate of evaporation, could also  be  diverted  to  the  boilout  tank.
After  the  boilout  is complete and weak black liquor is again fed to
the evaporator, weak black liquor flow would be initially diverted  to
the  weak  black liquor tank and eventually to the strong black liquor
tank.  This system is shown in Figure VII-15.

Neutralize Spent Sulfite Liquor.  in both the dissolving sulfite  pulp
and  both papergrade sulfite subcategories  (particularly at mills with
MgO  systems),  neutralization  of   spent   sulfite   liquor   before
evaporation  will  reduce  raw waste loadings of BOD5_.  Neutralization
gives a significant reduction in the carry-over of  organic  compounds
                               296

-------
                     CAUSTIC
                                       •iLcV
                                        V y
                     AREA
                                     CONDKN8ATC
                                        TANK
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                                                                   LAST STA9C
                                                                  BROWN STOCK
                                                                   WAtKER
LEGEND
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EXISTING
NEW
                                                                               FIGURE -ZE- 13

                                                  COMPLETE REUSE OF  EVAPORATOR CONDENSATE
                                                                         KRAFT AND SODA MILLS

-------
                                              TO EXISTING BAROMETRIC
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-------
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                                                      ADDITION OF AN EVAPORATOR B01LOUT TANK

-------
to the condensate.  Depending on the mode of operation, this reduction
can  range  from  1.0  to  1.5  kg/kkg  (2.0  to  3.0 Ib/t) of BOD5_ at
papergrade sulfite mills and up to 25.0 kg/kkg (50.0 Ib/t) of BOD5_  at
dissolving  sulfite mills.  Figure VII-16 shows the modifications.  At
sulfite mills where a MgO or a sodium base is not  used,  an  organi.cs
removal   system  could  be  used  to  enable  recycle  of  evaporator
condensate.  The reduction in BOD5_  load  is  of  the  same  order  of
magnitude  as  with  spent  sulfite  liquor  neutralization, but could
involve a greater capital cost.   Organics  removal  is  essential  to
prevent  build-up  in  the system when extensive condensate recycle is
practiced.  At most mills where this technology  is  applicable,  this
control  strategy has been implemented.  It is also applicable for use
at new mills.

Segregation of_ Cooling Water.  Segregation and reuse of cooling  water
in  the evaporator and recovery area of semi-chemical mills can result
in  substantial  flow  reductions.   Estimated  flow   reductions   of
approximately 1.7 kl/kkg (0.4 kgal/t) result.(53)(54) At some of these
mills, extensive reuse of cooling water is practiced; however, smaller
streams  are  typically  discharged  to the sewer.  Elimination of the
discharge of these sewered  streams  would  reduce  the  flow  to  the
treatment  facility.    The equipment requirements are similar to those
shown earlier in Figure VII-3 for application in the woodroom area.

Spill Collection.   Spill  collection  in  the  evaporator,  recovery,
causticizing, and liquor storage areas could be implemented to varying
degrees  at  mills in three kraft subcategories.  The spill collection
system  applicable  at  mills  in  each  subcategory  varies   widely,
depending  on  the  existing level of implementation.  This technology
involves the use of the following techniques, all of which  are  being
used at some mills in certain subcategories:

o spill collection in the evaporator and recovery boiler area,

o spill collection in the liquor storage area,

o spill collection in the causticizing area, and

o  addition  of a spare liquor tank to accept spills from any of these
three areas and a pump to return a spill to its point of origin.

All spill collection systems involve the use of a sump and a  pump  to
divert  the  spill  to  the spill tank.  If the tank were full, spills
could be diverted to a spill lagoon.  The spill  collection  sump  for
the  liquor  storage  area  could  be  equipped  with  a  conductivity
controller which allows surface run-off and low conductivity spills to
be diverted to the spill  lagoon,  while  allowing  high  conductivity
spills  to be sent to the spill tank for recovery.  A flow diagram for
a typical system is shown in Figure VII-17.(57)(65)(66)
                               300

-------
                  WASHERS
                                          AiSORPTION

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                                                  >•<«• '%«•
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                                                                                                   M     p.
                                                                                                    WASH
                                                  FRESH WATER
                                                    HEADER
         FIGURE H- 16
   NEUTRALIZATION OF
SPENT SULFITE  LIQUOR

-------








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-------
Liquor Preparation Area

Production process controls that reduce raw waste loads in the  liquor
preparation  area  include installation of a green liquor dregs filter
and lime mud pond, as described below.

Installation of. Green Liquor Dregs Filter.  At an alkaline  (kraft  or
soda)   pulp  mill  with  a modern recovery furnace, green liquor dregs
contribute approximately 5.0 kg/kkg (10.0 Ib/t) of TSS.(28)  Diversion
of this material from the primary  clarifier  can  have  a  beneficial
effect.  The dregs are usually pumped from a gravity-type dregs washer
or clarifier at very low consistencies with accompanying high strength
alkaline  liquor  entrainment.  This may have an appreciable effect on
pH at the clarifier.  In addition, the material tends to be of a  fine
colloidal nature and can be difficult to settle.

At many modern mills, belt-type filters have been installed to improve
washing  and  sodium recovery from the dregs.  This results in a drier
material that can readily be disposed of  at  a  landfill  site.   For
mills  having  only  a gravity type unit, a small vacuum filter can be
employed.  Condensate can be applied  for  washing  the  cake  on  the
filter with subsequent use of the filtrate in the dregs washer itself.
This creates a countercurrent system that is effective in the recovery
of  sodium  and  for dry dregs disposal.  Generally, such projects are
justified on the basis of alkali saving.  This decision depends on the
capability of the existing primary  clarifier  and  sludge  thickening
operations.   Figure  VII-18  presents  a  schematic  of  this control
technology.  Such devices are generally applicable at all mills in the
alkaline (kraft and soda) subcategories.  However, if adequate primary
clarification is  provided,  this  technology  may  result  in  little
improvement in overall treatment system performance.

Installation  of_  a  Lime Mud Pond.  At kraft pulp mills, the use of a
lime mud pond can reduce TSS discharges caused by  upsets,  start-ups,
and shutdowns in the white liquor clarification and mud washing area.

A  spill collection diversion system, incorporating a pond for liquors
containing high quantities of lime mud, allows for reuse of this  mud.
It also assures minimum upsets at the primary clarifier in the case of
a  dump of a unit containing high concentrations of lime.  Such a dump
could occur during a  period  of  outage  or  repair.   Figure  VII-19
presents  a  schematic  of this control technology.  Typical long-term
savings average 1.5 to 2.5 kg/kkg (3.0 to 5.0 Ib/t) of  TSS  in  kraft
pulp  mills.(58) However, this control technology may result in little
improvement in overall treatment system performance at facilities with
adequate primary clarification.  It may, however, be justified at many
mills on the basis of the resulting savings in lime cost.

Papermill

Production process controls that  reduce  raw  waste  loading  in  the
papermill  area include: a) papermachine, bleached pulp (furnish), and
color  plant   spill   collection,   b)   saveall   improvements,   c)
                                303

-------
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-------
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-------
high-pressure  showers  for wire and felt cleaning, d) white water use
for vacuum pump sealing, e) white water showers for wire cleaning,  f)
white  water  storage  for  upsets  and pulper dilution, g) recycle of
press effluent, h) reuse  of  vacuum  pump  water,  i)  provision  for
additional  broke  storage,  j)  installation  of wet lap machines, k)
segregation of cooling water, 1) collection  of  cleaner  rejects  for
landfill  disposal,  and  m) addition of fourth stage cleaners.  These
specific controls, their applicability to the  various  subcategories,
and  their  general  effectiveness  are  described individually in the
following paragraphs.

Spill Collection.  Papermachine and bleached  pulp  (furnish)  storage
area  spill  collection  is applicable at mills in all of the bleached
kraft and soda, sulfite, groundwood, and nonintegrated  subcategories.
The  extent  of  application  of  this  control varies by subcategory,
depending on factors such as the number of machines and the extent  to
which  spill  collection already exists at the various mills.  For the
bleached kraft, soda,  and  sulfite  subcategories,  spill  collection
systems  could  be  installed to handle overflows and equipment drains
along with spills from the bleached  stock  storage  area,  the  stock
preparation  areas, and the papermachine or pulp machine wet ends.  As
shown in Figures VII-20 through VII-22, these systems would  generally
require • installation  of  a new sump, a new stock tank, and a pump to
return the spills to a point where they could be blended back into the
process.  This control can result in substantial stock savings  and  a
reduction  in  TSS  load.   Savings  estimates  vary  widely,  but may
typically be 2.0 to 2.5 kg/kkg  (4.0 to 5.0 Ib/t) of TSS and 0.6 to 0.8
kg/kkg (1.2 to 1.6 Ib/t) of BOD!>.

Collection of color plant spills can be implemented at  mills  in  all
subcategories  where  fine  coated papers are manufactured.  One spill
collection system could be applied for each machine which has a coater
or size press.  With this system,  spills  and  wash  water  would  be
collected  in  a  sump  and stored for reuse.  The system provides for
control of spills in all the storage and mix tank areas of  the  color
plant  and  at the coater, tanks, and screens.  Implementation of  this
control would result in savings  of  expensive  coating  pigments  and
adhesives  as  well as a reduction in the TSS load.  A flow diagram is
shown in Figure VII-23.

Improvement o_f_ Savealls.  The use of savealls was  identified  as   part
of  the  best  practicable control technology currently available.  At
most mills, savealls have been  employed.   The  present  emphasis  on
savealls is to improve their performance.  Mills  in many subcategories
could  benefit  from  saveall improvements such as the installation of
new vacuum disc savealls or the  reworking  of  existing  savealls  by
adding  some  new equipment.  Savealls can be employed on all types of
machines producing all types of products including fine papers, board,
tissue papers, molded products, and newsprint.  Most of  the  savealls
being  installed  today  are of the vacuum disc filter type.  They are
flexible in handling various types of stock  and   shock  loadings  and
exhibit  high  separation  efficiencies.  As a control item, their use
results in flow and solids reductions.   Nearly   all  Stock  saved  is
                                306

-------
                   •LEACH PLANT
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                                                                 PAPERGRADE SULFITE

-------
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                                          PULP BLEACHING AND DRYER AREAS

                                           BLEACHED KRAFT AND SODA MILLS

-------
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-------
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-------
stored  or  reused  immediately.  The clear white water can be readily
reused within the mill, replacing  some  fresh  water  uses.   If  not
reused,   it  becomes  a  relatively  clear  overflow  to  the  sewer.
Significant flow reductions can be attained when an effective  saveall
is used in that extensive filtrate recycle becomes possible.

At  mills  with existing savealls, entire installations are not likely
to be required.  In these cases,  a  new  saveall  could  replace  the
existing saveall on the largest machine, making use of existing pumps,
tanks, and piping.  The existing saveall could be repiped for the next
smaller  machine,  and  so  on down the line, so that each machine may
have a larger, more effective saveall.  Figures VI1-24 through  VII-26
illustrate typical saveall installations.  The resulting overall white
water  balance determines the net savings, but flow reductions of from
about 0.8 to 41.7 kl/kkg (0.2 to 10.0 kgal/t) are  possible  depending
on the type of mill and level of white water reuse.(60)

Use  of_  High  Pressure  Showers  for  Wire  and  Felt Cleaning.  High
pressure showers to replace low pressure, high volume  showers  (i.e.,
those  used  for  felt  cleaning, return wire cleaning, and couch roll
cleaning) may save up to 90 percent of the water used in  conventional
shower  applications  and  may  be  more  effective.   It is generally
considered that felt cleaning showers are operated at  35.2  kg/sq  cm
(500  psi)  and  Fourdrinier  showers  at  21.1 kg/sq cm (300 psi).  A
typical installation is shown in Figure VII-24.  High pressure showers
are applicable at mills in the dissolving  kraft,  dissolving  sulfite
pulp,   deink,  nonintegrated-fine  papers,  nonintegrated-filter  and
nonwoven papers, and nonintegrated-lightweight  papers  subcategories.
Application     is,    however,    generally    universal    in    the
industry.(60)(67)(68)(69)(70)

White Water Use for Vacuum Pump Sealing.  Excess clarified white water
has been successfully used to  replace  fresh  water  on  mill  vacuum
pumps.  The vacuum pump seal water may then be recycled or discharged.
At  a  minimum, the equivalent quantity of fresh water use is directly
displaced.  Corrosion and abrasion may be deterrents to implementation
of this system, particularly at low pH  or  high  filler  levels.    As
shown  in  Figure VII-27, fresh water addition may be required and can
be  provided  to  maintain  temperatures  below  32°C  (90°F).    This
technology  can  be  applied at mills in all subcategories.  Resulting
reductions in waste loadings depend on the overall water balance,   but
flows  of  94.6  to  380  liters/minute  (25  to 100 gpm) per pump are
common.(67)(68)(69)(71)(72)

Papermachine White Water Use  on  Wire  Cleaning  Showers.   Clarified
white  water  from  the papermachine saveall, containing low levels of
additives and fillers,  can be used on wire  cleaning  showers.   White
water  can  be  used  on  Fourdrinier showers and knock-off showers as
shown earlier in Figures VII-24 through VII-26.  The system includes a
white water supply pump, supply piping, and showers.   A  fresh  water
backup  supply  header  is  provided with controls for introduction of
fresh water to the white water chest in the event of low volume in the
                                 311

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-------
                     SWEETENER STOCK
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                                                                                 PULPMILL SEWER
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                                                   TO MACHINE SHOWERS (WIRE)
                                                 TO COOLIN0 TOWER (VACUUM SEALS)
                                               TO MACHINE SHOWERS (KNOCKOFF)
                                                                                       FIGURE 3ZH-25
                                                    NEWSAVEALLON PULPS  PAPERMILL EFFLUENTS —
                                                                    BUILDERS'  PAPER 8 ROOFING FELT

-------
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                                                    EFFLUENT-WASTEPAPER-MOLDED PRODUCTS

-------
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                 FOR PUMP SEAL WATER AND  PRESS EFFLUENT

-------
chest.   The effect of implementation of this control varies widely  by
machine and type of mill.

White Water Storage for Upsets and Pulper Dilution.   As illustrated in
Figure  VII-28,  this system consists of an additional storage tank to
store excess white water that would overflow from the  existing  clear
white  water  tank.   Where possible, the tank could be adjacent to or
added onto the existing tank to eliminate pumping costs.

The white water from this tank can be used in  the  pulper  or  bleach
plant.    The  tank  would be sized to hold adequate white water needed
for pulp dilution after pulping, bleach plant washing,  or  continuous
washing  requirements.    A  fresh water header is provided to the tank
for makeup.

A separate system may be needed for each  machine,  depending  on  the
variability  of  furnish.    Each  machine  may have its own pulper and
require a completely separate white water system.   Increased  storage
facilities  can  provide  significant  flow  reductions;  BOD5_ and TSS
reductions may also result.(60)

Recycle of_  Press  Water.    Effluent  from  the  press  section  of  a
papermachine   contains   fibrous   fines  and  fillers  that  can  be
reintroduced into the white water system and  recovered.   Water  from
the  vacuum  presses,  as  well  as  pressure rolls, can be piped to a
collection tank (or wire pit) often  without  the  need  for  pumping.
From  the  tank,  the  water  can  be  pumped to the saveall system to
reclaim the fiber and fillers and to make the water available for  use
in  the  white water systems.  This would reduce solids and may reduce
flow to the wastewater treatment plant.  Generally,  a separate  system
would be required for each machine.

Felt  hairs, previously a deterrent in some systems, have been largely
eliminated with the advent of synthetic felts.   Thus,  provision  for
the  removal  of  felt  hairs has not been contemplated in the system,
although such provision may be required on top-of-the-line printing or
specialty grades, at least during periods of use of new felts.

Reuse o_f_ Vacuum Pump Water.  Recycle of vacuum  pump  water   (most  of
which  is  seal water)  and/or use of white water as seal water (Figure
VII-27) will nearly eliminate fresh water additions  for  these  uses.
Installation  of  the  system would require piping,  a collection tank,
and a pump to return the water to storage for reuse.   One  system  is
needed for each machine.

At  many mills, specific collection systems are not employed  for press
effluent and vacuum pump seal water.  By combining  the  two  systems,
cost reductions could be realized.  Up to 21.0 kl/kkg (5.0 kgal/t) may
be  saved.(49)  Typically,  flow reductions are estimated at  less than
8.3 kl/kkg (2.0 kgal/t).

Additional Broke Storage.  An additional broke storage chest  could  be
installed  at  most  mills  in  the  nonintegrated-lightweight  papers
                                316

-------
                                                          FRESH WATER MAKE-UP
                                                        THICKENER
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                                                                                 BOILER SLOWDOWN
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                         EXISTING WALL OR CONNECT
                         WITH LARGE DIAMETER PIPE
             LEGEND
                      EXISTING
             	NEW
                                                                                                FIGURE SH-28
                                                                     INCREASED WHITE WATER  STORAGE CAPACITY

-------
subcategory.  The system consists of a central  broke  storage  chest,
pumps,  and  piping.   This  enables excess broke to be brought to the
chest and returned to the proper machine once the upset is  over.   At
some  mills,  more  than one chest would be required, depending on the
number of machines and product mix.  Generally, the tank is  sized  to
hold  30  minutes  of  broke  from  the couch pit.  It would allow for
breaks or grade changes to occur with a minimum  of  overflow  to  the
sewers.    Up  to  10.0 kg/kkg (20.0 Ib/t) TSS might be saved at a mill
where grades are changed frequently.

Installation of_ Wet Lap Machines or_ Other Screening Devices.  Wet  lap
machines  or  other  screening  devices  can  be installed at mills in
several  subcategories as part of an  overall  stock  spill  collection
system.   The wet lap machine would be preceded by a screen for removal
of  rejects  and  dirt from spilled stock.  Rejects would be hauled to
landfill.  The accepts would be fed to the wet lap  machine,  allowing
recovered   stock  to  be  stored  in  a  convenient  form  for  later
reintroduction to the system or for use at another mill.

At some mills, devices such as sidehill or  inclined  screens  may  be
effective  at lower cost.  However, the wet lap machine is very useful
as a means of providing excess broke storage.

Segregation  o£  Cool ing  Water.   Improvements   in   cooling   water
segregation in the papermill could be employed resulting in reductions
in water usage.  Implementation of this control requires modifications
to  eliminate the discharge of pump seal, calender stack,  bearing, and
other cooling waters from the sewer.  These waters could be  collected
in  a sump and, depending on warm water requirements, either pumped to
the mill water system or discharged via a separate thermal sewer.   At
least  4.2 kl/kkg (1.0 kgal/t) would be expected to be reduced in most
nonintegrated mills.

Cleaner Rejects to Landfill .  Collection and screening of rejects from
sources such as pulp cleaners, papermill cleaners,  pressure  screens,
and  centrifugal screens will eliminate up to 40 percent of the solids
to the treatment plant from these sources. ( 52) ( 60)  The  system  would
consist  of  piping from the reject sources to a collection tank, pump
and piping to the screen  headbox,  a  sidehill  screen,  and  rejects
dumpster.   In  the  case of remote cleaner reject sources, an accepts
tank and pump and piping from the  accepts  tank  to  the  source  for
sluice  water would be required.  Savings of 1.5 to 5.0 kg/kkg (3.0 to
10.0 Ib/t) TSS are possible.  Figure VII-9  presented  earlier,  shows
this modification.

For   mills  where  ample  primary  clarifier  capacity  is  provided,
implementation of  this  technology  may  not  result  in  significant
improvement  in  overall  treatment  plant  performance.   These fiber
losses may  aid  in  the  dewatering  of  combined  primary/biological
sludges.
Addition  of_  Fourth Stage Cleaners.   The addition of a
stage can reduce the flow and solids being  discharged
                                                        fourth cleaner
                                                        from  a  three
                               318

-------
stage system by 80 to 90 percent.   The pulp stock savings alone can be
ample  justification  for  implementing such a system, shown in Figure
VII-29.   This control strategy may be an alternative to collection and
screening of rejects depending on relative mill operating  parameters.
Again,  if  ample  primary clarification is provided, this control may
not result in  significant  improvement  in  overall  treatment  plant
performance.

Steam Plant and Utility Areas

Production  process  controls that reduce raw waste loads in the steam
plant and utility areas include: a) segregation of cooling waters  and
b)  installation  of  lagoons for boiler blowdown and backwash waters.
These controls are discussed below.

Segregation of_ Cooling Water.  At mills in  many  subcategories,  this
control   technology  has been implemented; however, this technology is
not widely practiced at mills in several subcategories.  This  control
requires modifications to sewers and floor drains to segregate cooling
water  from  the  mill  process sewer and installation of a warm water
storage tank.  The sources of cooling water that are to be handled  by
this  system differ at mills in the various subcategories.  Generally,
they include miscellaneous streams such as pump  and  bearing  cooling
water,  air  compressor cooling water, and major water sources such as
turbine  and  condenser  cooling  waters.   This  control  is  a  flow
reduction measure, but will also result in energy savings.

Addition  of  Laqoon(s) for Boiler Blowdown and Backwash Waters.  This
control  could be effective at mills in many of the subcategories.   At
mills  in  several other subcategories, a separate discharge for these
sources has been provided or these waters are reused in  the  process.
The  boiler  blowdown water and the backwash waters can be pumped to a
new lagoon, from which they are discharged to receiving waters.   This
keeps  these sources segregated from the wastewater treatment facility
and provides sufficient settling time to effectively remove  suspended
solids.    pH adjustment may be required in some cases.  Implementation
of this control technology will reduce  the  flow  to  the  wastewater
treatment  facility.   While universally applicable, the technology is
widely practiced at mills in only a few subcategories. (53)

Recycle of_ Effluent

At mills in several secondary fibers and nonintegrated  subcategories,
fresh  water  usage  is reduced by recycling clarified effluent to the
mill for use as hose water and pump seal water.  At industrial  tissue
mills,  purchased  wastepaper  requirements  may  be ~ reduced  through
recycle of primary clarifier solids to the process.  The major benefit
of effluent recycle is flow reduction.  Recycle  of  clarifier  solids
can  yield  savings  in  the  cost  of  raw  materials and the cost of
handling and disposing of the primary waste solids.
                                319

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                                            CLEANERS
                  PROCESS
           CLEANER
             FEED
oo
rv>
O
            LEGEND
                     EXISTING
            «- — — ..  NEW
                                          FEED TANKS
                                                                                      FIGURE 3DE-29

                                                                           4-STAGE CENTRICLEANER

                                                                          SYSTEM WITH ELUTRIATION

-------
One system to recycle clarified effluent would consist  of  a  holding
tank,   piping  from  the clarifier to the holding tank, and a pump and
piping from the holding tank to existing headers.  The solids  recycle
system,  as  shown  in  Figure  VI1-30,   would  consist of a pump with
suction from the existing waste solids discharge line  and  piping  to
the pulpers.  This technology would be difficult to implement at mills
with  severe product quality constraints.  It is most likely that this
technology  would  be  implemented  at  mills  where  industrial   and
institutional  grades  of  tissue  paper are produced.  Solids recycle
occurs primarily at secondary fiber mills.(67)

At some secondary fiber mills,  effluent  is  now  recycled.   Saveall
improvements  could permit the use of more effluent on machine showers
and eliminate the use of fresh water on  the  machine.   Such  recycle
schemes  are  now commonly employed in the paperboard from wastepaper,
wastepaper-molded products,  and  builders'   paper  and  roofing  felt
subcategories.   Savealls  may  serve  as  a  means  of recycling both
effluent and reclaimed stock in these latter subcategories.  At  mills
in   the  nonintegrated-tissue  papers  and  nonintegrated-lightweight
papers subcategories, a settling basin can  be  installed  to  collect
discharges from floor drains for reuse of this water rather than fresh
water for hoses and seal water.  This system could also be employed at
mills in the deink and nonintegrated-fine papers subcategories.

Chemical Substitution

It  is often possible to use different process chemicals to accomplish
the same  goal.   For  example,  both  zinc  hydrosulfite  and  sodium
hydrosulfite  can be used to bleach mechanical (groundwood) pulps.  In
recent years, at most groundwood mills,  a substitution to the  use  of
sodium hydrosulfite rather than zinc hydrosulfite has been made.  This
was  prompted,  at least in part, by the establishment of BPT effluent
limitations controlling the discharge of zinc.  Rather than invest  in
costly  end-of-pipe  treatment, mill management determined that a less
costly  and  equally  effective  control  option  would  be   chemical
substitution.   This  substitution of chemicals resulted in attainment
of BPT effluent limitations.

Other opportunities exist to  minimize  the  discharge  of  toxic  and
nonconventional  pollutants  through  chemical  substitution  and  are
discussed below.

Toxic  Pollutants.   Slimicide  and  biocide  formulations  containing
pentachlorophenol are used at mills in the pulp,  paper, and paperboard
industry.   Initially, pentachlorophenol was used as a replacement for
heavy metal salts, particularly mercuric types.  Trichlorophenols  are
also  used  because  of  their  availability  as a by-product from the
manufacture  of  certain  herbicides.   Formulations  containing   the
following three types of materials are also currently being used:

     1.   Organo-bromides,
     2.   Organo-sulfur compounds, and
     3.   Carbamates.
                               321

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                             INSIDE  MILL
                                                                         OUTSIDE  MILL
oo
ro
no
                   BALES
LEGEND
	
	

EXISTING
NEW
                                   TO PROCESS
                                                                               PAPER  MILL SEWER
                                                                                         SEWER
                                                                                       FIGURE 3OI-30

                                                                                    IMPROVED REUSE

                                                                               OF CLARIFIER SLUDGE

-------
Substitution  to  the  use  of   alternate   slimicide   and   biocide
formulations  can lead to the virtual elimination of pentachlorophenol
and trichlorophenol from these sources.

Nonconventional Pollutants.  Ammonia is used as a cooking chemical  at
eight  mills  in  the semi-chemical, dissolving sulfite pulp, and both
papergrade sulfite subcategories.  One  method  for  reducing  ammonia
(NH3_)  discharges is the substitution of a different chemical, such as
sodium hydroxide, for ammonia in the cooking liquor.  The quantity  of
sodium   hydroxide   required,   based  on  chemical  composition  and
stoichiometry, is 150 kg per kkg (300 pounds per ton) of  pulp,  about
three  times  the  required  amount  of  NH3_.   The  equipment changes
necessary to receive and feed a 50 percent solution of  NaOH  are  not
likely to be significant.

After  conversion  to  the use of sodium-based chemicals, spent liquor
could be incinerated, and sulfur dioxide, sodium  sulfate,  carbonate,
or  sulfide could be recovered.   These compounds could be sold for use
at nearby kraft mills or for other industrial uses;  however,  markets
are not likely to be readily available.

Reducing,  smelting furnaces that produce a high-sulfidity, kraft-like
green liquor are now employed  at  sodium-based  sulfite  mills.   The
Agency  anticipates that it would be necessary to replace the existing
recovery boilers at ammonia-based mills if chemical substitution to  a
sodium  base  were employed.  Additionally, it is likely that, because
the heat value of sodium spent liquor  is  lower  than  ammonia  spent
liquor,  evaporator  modification  may  be required if excess capacity
does not now exist.

OTHER PRODUCTION PROCESS CONTROLS

In the  previous  discussion,  production  process  controls  commonly
employed  in  the  pulp,  paper,  and  paperboard  industry  have been
reviewed and summarized.  Other production process controls have  been
implemented   to  a  limited  extent;  these  controls  are  generally
applicable in the pulping, bleaching, and recovery areas of the  mill.
Several of these control items are discussed below.

Bleach Systems and Recovery

The  bleach  plant  is  commonly the largest contributor of wastewater
pollutants from kraft and soda mills where pulp is bleached.  For this
reason, much effort has been spent on investigating the possibility of
recycling bleach plant effluent to the liquor recovery  system,  where
organic  constituents  can  be  burned.   One  process  that  has been
investigated is the use of oxygen  bleaching.   The  oxygen  bleaching
concept   has   just  recently  begun  to  be  applied  in  commercial
use.(73)(74)  Other  processes  that  allow  return  of  bleach  plant
effluent  to  the  liquor  recovery cycle are the Rapson-Reeve closed-
cycle  process  and  the   Billerud   Uddeholm   nonpolluting   bleach
plant.(75)(76)(77)(78)
                               323

-------
Oxygen Bleaching.   Oxygen bleaching is currently used at only one mill
in  the  United  States,   the  Chesapeake Corporation in Virginia.(79)
Oxygen bleaching is used outside the U.S., at one mill in Canada,  one
in South Africa, one in France,  one in Japan, and three in Sweden.(80)

The  advantage  of  oxygen  bleaching  comes from the recycling of the
alkaline 02_ stage effluent to the black liquor  recovery  system.   In
order  to  recycle  the effluent, it is necessary to keep the chloride
content of the 02_ stage at a low  level.    For  this  reason,  the  02_
bleaching  sequences  being used generally have the 02_ stage preceding
any C12_ or C102_ stage.   The exception to this  is  at  the  Chesapeake
Corporation,   where  a  CDOD  sequence is used that does not allow for
recycle of the 02_ stage to the recovery system.

In work done by the NCASI, effluent characteristics from  conventional
and  oxygen  bleaching  sequences  were  compared.   The  conventional
sequences CEHDED and CEDED were compared in  the  lab  to  those  from
OCEDED  and  OCED  for  both hardwood and softwood alkaline pulps.  By
recycling all of the 02_ stage effluent, a BOD5_ reduction of 81 percent
and a color reduction of 89 percent over  the  conventional  sequences
were  achieved  for  softwood  pulps.   For hardwood, reductions of 81
percent of BOD5_ and 92 percent of color were achieved. (81 )

At the Cellulose d'Aquitaine mill in St.  Gaudens, France,  total  BOD5_
load and the total color load have reportedly been reduced by about 30
and  50  percent,   respectively.   An existing CEDED sequence has been
converted to an OCEDED sequence.(73)  The claimed operating  cost  for
the  new  oxygen bleach sequence is $2.10/ton  (1975) less than for the
old sequence.

The Enstra oxygen bleaching operation in South Africa has  achieved   a
cost  reduction  of  $5.00/ton  (1972)  with  an  ADDED sequence.  The
capital cost of adding an oxygen stage was reported to be $2.0 million
(1972) for a 270 kkg/day (300 tons/day) mill and $4.0  million   (1972)
for a 680 kkg/day (750 tons/day) mill.(74)

Oxygen  bleaching  technology  is  still  being  developed  and  is not
routinely used in alkaline pulp mills in the United States.

Rapson-Reeve  Closed-Cycle  Process.   The  Rapson-Reeve  closed-cycle
process  encompasses  some  standard  design  features  likely   to  be
employed at many kraft  pulp  mills  in  the  future.   (53)(76)   The
concepts  of  the  closed-cycle  mill, as proposed by ERCO-Envirotech,
Ltd. and illustrated in Figure VII-31, are included in the  system  at
Great Lakes Paper Co.,  Ltd., Thunder Bay, Ontario.

One  of  the  features  of  the  closed-cycle  process  is  the  use of
approximately 70 percent chlorine dioxide in the first stage.  It  has
been  claimed  that the use of chlorine dioxide will decrease effluent
BOD5_, color,  chemical  oxygen  demand  (COD),  dissolved  solids,  and
toxicity  even at a mill that is not completely closed.(82) The  bleach
sequence for the closed-cycle bleached  kraft  mill  is  DCEDED.   The
washing  design  is  straight countercurrent; excess E, stage filtrate
                                  324

-------
                                                                                                VENT
                 PUR6E

              (DRE88 a 0RIT)
               .PUR9E
CO
f\)
en
                TO ATMOSPHERE
                                                                                     H2O
                                                                            CONDCNSATE
                                                                                      HoO
                                                                                                 1
                                                             CONOEN8ATE


                                                             STRIPPING
                                                                   N«CL
  LIQUOR


PREPARATION
                                BLACK LIQUOR

                                EVAPORATOR
               c
                                                        PULPIN9
                                                        CHEMICALS

                                                        N«OH,NaaS
                                                     COOKIN6
                                                     WASHING
                                                                .WOOD
•LCACHIN9

 OeCOEO
                                                              UNBLCACH
                                                                 POLP
                                                                      ED
                                                                                       CLOj
H20
            FRESH
                                                                                     BLEACHED
                                                                                                      WATER
                                                       PULP
                                                                                           FIGURE  HI-31

                                                                                 RAPSON - REEVE PROCESS

                                                               CLOSED  CYCLE BLEACHED KRAFT PULP MILL

-------
can be pumped to the salt recovery process,  used  for  cooking  liquor
dilution,  or used on the brown stock washers.   The DC filtrate can be
used for brown stock washing,  screen room dilution,  or  sent  to  the
lime kiln scrubber.

Of  these  features,  the  only one that is unique to the closed-cycle
mill is the salt recovery process.  The salt recovery process (SRP) is
necessary in the closed-cycle mill  in  order  to  remove  the  sodium
chloride  that  would  otherwise  build  up  in  the  system.   In the
closed-cycle mill, the white liquor is evaporated and sodium  chloride
is  crystalized  and removed from the white liquor.  Recovered salt is
to be reused for the generation of C10i2; however, some must be  purged
from  the  cycle.   Figure  VII-32 is a schematic of the salt recovery
process.

ERCO-Envirotech  stated  that  use  of  the  design  features  of  the
closed-cycle mill result in (a) energy savings, (b) fiber savings, (c)
yield   increase,  (d)  decreased  water  consumption,  (e)  decreased
chemical  costs,  and  (f)  savings  in  effluent   treatment   costs.
According  to ERCO-Envirotech,  for a closed-cycle kraft mill producing
635 air dry kkg/day (700 air dry tons (ADT)  per day),  an  SRP  system
would  have  a capital cost of  $4.2 million (1977).  Implementation of
production process controls could run as high as $3.8 million  (1977),
making  the  total  cost  for  a closed-cycle mill about $8 million or
more.  The additional C102_ generating capacity and any major bleachery
modifications requiring more corrosion resistant materials will result
in yet higher costs.(77) Original estimates predicted that savings  of
$4  million  per year (1977) could be achieved when compared to a mill
having none of the features of  the closed-cycle mill.

Full-scale operating experience has been less favorable than the early
literature  had  projected.   Some  contaminated  effluent  is   being
discharged  and, while the salt recovery system has been operated, the
recovered salt has not been used on-site.(75)(76)  It  was  originally
thought  that  chemical  costs   would be lower for a closed-cycle mill
than for a conventional mill.   However, actual chemical costs at Great
Lakes Paper Co.,  Ltd.  have  been  higher  than  for  a  conventional
mill.(82)

On  implementation  of  the  closed-cycle  system,  corrosion problems
occurred  at  the  Thunder  Bay  facility.   A  combination  of   high
temperatures  (480°C  (900°F))   and  high  chloride levels resulted in
badly corroded tubes in the recovery boiler superheater.  The  damaged
equipment  was  replaced  with   equipment  made of Incaloy 880 and the
superheater has been operated at lower temperatures  (390°C  (730°F)).
This   has  permitted  operation  of  the  system  without  noticeable
pitting.(83) In addition, liquor pump failures and evaporator  scaling
were  the primary problems experienced in the initial operation of the
SRP.  Presently, liquor pump failures are no longer a problem and  new
evaporator  boil out procedures (using Et filtrate) have significantly
reduced scaling problems.  At the request of  representatives  of  the
government  of  the province of Ontario, mill personnel had planned on
constructing  a  biological  treatment  system.   However,  biological
                                 326

-------
CO
ro
                                                                                                      COIKIIITIUTU
                                                                                                          LMIUM  mat*
                                                                                                      TO
             HE-' HEAT EXCHANGED
             WL « WHITE LIQUOR
     FIGURE Ytt-32

    RAPSON-REEVE

CLOSED CYCLE  MILL

SALT RECOVERY SYSTEM

-------
treatment is not currently contemplated because the effluent from this
facility  combined with that from another mill at this site is able to
achieve  provincial  effluent  standards.   While  the  goal   of   an
effluent-free  mill  has not been realized, reductions in the BOD5_ raw
waste load of 50 to 75 percent of that of a  typical  market  bleached
kraft  mill  have  been  attained.   Even  higher reductions have been
achieved when the SRP has been operated within  the  specified  design
load.(83)

Sequential  Chlorination.   Another  method  of reducing the pollution
load from the bleach plant is with sequential Chlorination.

Sequential  Chlorination  is  based  on   initially   contacting   the
unbleached  pulp  with  C102_  equal  to  a  portion  of the equivalent
chlorine demand.  The reaction is rapid; the remainder of the chlorine
demand is satisfied with chlorine addition.   Strength  and  viscosity
improvements  have  been noted and total chemical application has been
reduced.(84)

MacMillian Bloedel Research views the use of  sequential  Chlorination
as  an  interim  solution  while  oxygen  bleaching  technology,  C102_
generation, and salt  recovery  systems  are  developed.   When  these
technologies  are  fully  developed, lower capital expenditures may be
realized.(85)

Hooker Chemical has investigated the use of  sequential  Chlorination;
their  work  has  dealt with modification of fully bleached sequences.
The first sequential Chlorination system studied  by  Hooker  Chemical
was the APS-I.  In this system, the standard CEHD or CEDED sequence is
modified   by  replacing  conventional  Chlorination  with  sequential
Chlorination  at  a  D:C   ratio   of   50:50   and   substituting   a
hypochlorination stage for the first extraction stage.  The system can
be  used  for  hardwood  or softwood pulps.  Substantial reductions in
effluent color and  toxicity  and  moderate  reductions  in  BOD5_  are
reported.(84)

Chemical  costs  for the APS-I system are reported to be equivalent or
slightly higher than for conventional  sequences.   Estimated  capital
costs range from $20,000 to $500,000 (1973) depending on the mill size
and   condition  of  the  existing  bleach  plant.   Pulp  quality  is
equivalent to that from conventional bleaching sequences.

The Hooker APS-II and APS-III systems  operate  differently  than  the
APS-I.   Chlorination is replaced by sequential Chlorination, at a D:C
ratio (75:25) and conventional caustic extraction is  employed.   This
minimizes  the  chloride  content  of  the  bleach  plant effluent and
permits recycling of the effluent into the kraft  recovery  system  to
allow  incineration  of  a  major  organic waste load.  The APS-II and
APS-III systems suggest a sequence of antipollution steps that may  be
implemented  one  at  a  time.   These  steps  and  the BOD5_ and color
reductions obtained through implementation of each step are  shown  in
Table  VI1-4.  This process is reported to involve the use of existing
or slightly modified bleach plant equipment  and  produces  pulp  with
                                 328

-------
                                                                           TABLE VI1-4

                                                          WASTE LOAD REDUCTIONS FROM IMPLEMENTATION OK
                                                                HOOKER APS II AMI) APS III SYSTEMS1
CO
ro
10
                    APSli

                    1
Effluent
' No. , Operation
rol standard
/
Countercurrent wash-jump
stage, split flow
Replace chlorination with
sequential chlorination -
75:25 J):C ratio
Rf cycle D/C et fluent to dilute
incoming brown stock
Dilute sequential chlorination

75

45
45
25
16
kl/kkg
.1-83.

.9-54.
.9-54.
.0-33.
.7-25.
(kgal/tj
4

2
2
4
0
(18 -

(11 -
(11 -
( 6 -
( 4 -
20)

13)
13)
8)
6)
W
12.

12.
11.
11
5,
&S
5

5
.0
.0
.0
BODS
_{lb/ton)
(25)

(25)
(22)
(22)
(10)
% BODS Color
Reduction kg/kkg
325

325
12 188
12 188
60 43.5
(Ib/tJ
(650)

(650)
(376)
(376)
( 87)
% Color
Reduction
-

-
42
42
87
                        stock with pjrt El and recycle
                        remainder to recovery via brown
                        stock washers and smelt dis-
                        solving system

                    5.  Use salt sepjration process to
                        purge NaCl and separate Na2S04
                        from pn-cipil ator catch

                    APS-I1I

                    6.  Treat D/C effluent in a resin
                        packed column and regenerate
                        resin with a portion of El
                        t-lll uent
16.7-25.0  ( 4 -  6)     5.0      (10)
16.7-25.0  (4-6)     4.5      ( 9)
                                               60
                                               64
43.5
                                                         11.5
(  87)
        ( 23)
                                                                             87
                    'Call, K.J. , ami F'.ll. Thompson, "The Ant i-Pol I nt ion Sequence - A  'lew Route
                     lo Ueduced Pollutants in Bleach Plant Effluent," TAPPJ, 56(11),  1973.(84)

-------
properties   equivalent   to  or  superior  to  that  of  conventional
processes.  Hooker also claims reduced chemical and  operating  costs.
The process allows for recovery of caustic,  sodium sulfate, and sodium
chloride that would normally be sewered.

Displacement  Bleaching.    There  are  presently only two mills in the
country where a displacement bleaching process is used.   The first was
at the Temple Eastex  mill  in  Evadale,   Texas,  where  operation  of
displacement  bleaching  began  in 1975.(86)  This was followed by the
start-up of a system at Weyerhaeuser Corporation  in  Plymouth,  North
Carolina,   in   1976.    Both  systems  are  Kamyr  designs,  with  a
conventional D/C first stage  tower  and  washer  preceding  an  EDEDW
displacement  tower.   The  caustic  is applied at the repulper of the
conventional washer.  The pulp is then pumped into the bottom  of  the
displacement   tower  (D,)  at  about  10  percent  consistency.   The
displacement tower has a retention time of  about  90  minutes.   Each
stage  in  the  tower is followed by a stage of diffusion washing with
the filtrate being  extracted  to  a  seal  tank  and  then  partially
reused.(87)  A  final  displacement  tower (D2) provides up to 4 hours
detention and washing using paper machine white water at the  Plymouth
mill.

There  are  four  filtrate  tanks  for the displacement towers.  These
tanks are of a stacked design with one set of tan-ks for  each  caustic
extraction stage and one set for each chlorine dioxide stage.  Caustic
extract  is  generally  reused on the conventional washer and is mixed
with the NaOH added at the repulper of the conventional  washer  prior
to  pumping  to  the  displacement tower.  Some chlorine dioxide stage
filtrate is also mixed with C102_ to be reused on the D, and D2 stages.
Overflows from the seal tanks are sewered.  Water use  for  a  D/CEDED
displacement  bleach sequence is typically 12.5 to 18.8 kl/kkg  (3.0 to
4.5 kgal/t) compared to  a  conventional  tower  washer  system  often
exceeding 50.0 kl/kkg (12.0 kgal/t).(86)

The  benefits  associated  with displacement bleaching are lower water
use and slightly lower initial capital costs.  Based on limited  data,
it  appears  that  chemical  usage  may  actually  be  higher than for
conventional bleaching systems.(86)

END-OF-PIPE TREATMENT TECHNOLOGIES  COMMONLY  EMPLOYED  BY  THE  PULP,
PAPER, AND PAPERBOARD INDUSTRY

Many  types  of  wastewater treatment systems are employed at mills in
the pulp, paper, and paperboard industry.  This section describes  the
treatment systems employed by the industry and presents information on
other applicable effluent treatment technologies.

Preliminary/Primary Treatment

Wastewater  must  often  be  screened  to  remove materials that could
seriously   damage   or   clog   downstream    treatment    equipment.
Automatically  cleaned  screens are commonly employed prior to primary
treatment and generally represent the preferred practice.
                                 330

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The initial process of removing organic and inorganic  solids  can  be
accomplished   by   sedimentation  (with  or  without  flocculants  or
coagulants), flotation, or filtration.  Primary treatment can  involve
mechanical clarifiers, flotation units, or sedimentation lagoons.

The  most  widely  applied  technology  for removing solids from pulp,
paper, and paperboard mill wastewaters is  the  mechanical  clarifier.
In   the   mechanical   clarifier,   solids   are  removed  by  simple
sedimentation.  Dissolved air flotation (DAF)  units  have  also  been
applied  to remove solids from paper mill'effluents.(88) DAF units are
somewhat limited in use because of  their  inability  to  handle  high
pollutant    concentrations    and   shock   loads.    Fine   screens,
microstrainers, and pressure filters are  not  commonly  used  in  the
industry  for  solids  removal.   Adequate fine screening systems cost
approximately the same as an equivalent clarifier.(89)

Because of the biodegradable nature of a  portion  of  the  settleable
solids  present  in  pulp,  paper,  and  paperboard  mill wastewaters,
clarification can result in some BOD5_ reduction.  Typical BOD5. removal
through primary  clarification  of  integrated  pulp  and  paper  mill
effluent  can  vary between 10 and 30 percent.  The exact BOD5. removal
depends  on  the  percentage  of  soluble  BOD5_  present  in "the  raw
wastewater.   Primary clarification can result in significantly higher
BOD5_ reductions at  nonintegrated  mills  than  at  integrated  mills.
Responses  to  the data request program indicate that approximately 50
percent  of  the  raw  wastewater  BOD5_   is   commonly   removed   at
nonintegrated mills through the application of primary clarification.

Easty observed that very little reduction of fatty acids, resin acids,
or    their    chlorinated    derivatives    occurs   during   primary
clarification.(90) This observation suggests that these compounds  are
not associated with the raw wastewater solids measured in the TSS test
procedure.   Polychlorinated  biphenyls  (PCBs)  have been observed to
undergo significant reductions through primary  treatment.(91)   At  a
deink  tissue  mill,  PCBs  were reduced from 25 to 2.2 micrograms per
liter (ug/1) through primary clarification,  while  TSS  were  reduced
from 2,020 to 72 milligrams per liter  (mg/l).(91)

Biological Treatment

Currently,  the  most common types of biological treatment used in the
pulp, paper, and paperboard industry include oxidation basins, aerated
stabilization  basins,  and  the  activated  sludge  process  or   its
modifications.   Other  biological systems that have been used include
rotating biological contactors and anaerobic contact filters.

A  principal  benefit  obtained  from  biological  treatment  is   the
reduction   of   oxygen   demand.   Significant  reductions  in  toxic
pollutants have also been observed through application  of  biological
treatment as illustrated by recent data gathering efforts (see Section
V).   Biological  treatment systems have been designed and operated to
achieve 80 to 95 percent and higher BOD5_ reductions  when  applied  to
pulp,  paper, and paperboard mill effluents.  Biological treatment can
                                  331

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also yield an effluent nontoxic to  fish  a  high  percentage  of  the
time.(92)

Due   to  the  fluctuation  of  influent  wastewater  characteristics,
specific  toxic  pollutant  removal  capabilities  are   not   readily
measureable  unless  long-term  field  sampling  is  employed.   In  a
laboratory study, Leach, Mueller,  and Walden determined  the  specific
biodegradabilities  of  six nonconventional pollutants in pulp, paper,
and paperboard mill wastewaters.(93)  The  relative  ease  with  which
these   six   compounds   were  degraded  was,  in  descending  order:
dehydroabietic     acid,     pimaric     acid,     tetrachloroguiacol,
monochlorodehydroabietic   acid,   dichlorodehydroabietic   acid,  and
trichloroguaiacol.  The researchers reported that  chlorinated  bleach
plant   derivatives  are  more  difficult  to  degrade  than  are  the
nonchlorinated wood derivatives.

A  recent  study  involved  investigation  of  influent  and  effluent
concentrations  of  toxic  and  nonconventional pollutants after full-
scale biological treatment.(90) Removal rates of these pollutants,  as
derived  from  the  published  design and treatment data, are shown in
Table VII-5.(90)  The relative  removal  rates  generally  agree  with
those obtained in laboratory studies.(90)(93)

BOD!>  and  toxic  pollutant  removals  from  bleached kraft wastewater
through  application  of  activated  sludge  treatment   and   aerated
stabilization  were investigated in an attempt to establish a relation
between  pollutant  concentration  and  toxicity.(92)    The   authors
concluded  that,  in general, a reduction in BOD5_ to about 45 mg/1 was
sufficient to achieve detoxification of  the  waste.   Also,  a  total
resin  and  fatty acid concentration of less than 1 mg/1 was necessary
to effect detoxification.  The correlation  between  total  resin  and
fatty  acid  content  and  toxicity  was  better  than the correlation
between BOD5_ and toxicity.

Oxidation Basins.  The first type of biological treatment systems used
in the pulp, paper, and paperboard  industry  were  oxidation  basins.
These  are  large natural or manmade basins of various depths; natural
aeration from the atmosphere  is  relied  on  as  the  primary  oxygen
source.    Additionally,   limited   oxygen   is   provided  by  algal
photosynthesis.  The amount of oxygen provided through  photosynthesis
is  dependent upon the basin configuration (depth) and its restriction
in light penetration.  Since oxidation through natural aeration  is  a
relatively   low-rate  process,  large  land  areas  are  required  to
effectively treat high strength wastes.  Because  of  availability  of
land  and  a  warm  climate  that enhances bioactivity, most oxidation
basins are found in southern states.   This  technology  can  be  more
effective  if  settleable solids are removed from the wastewater prior
to discharge  to  the  basins.   Solids  can,  in  certain  instances,
contribute significantly to the BOD£ waste loads.  In addition, excess
settleable  solids  tend  to  fill the basins, thus reducing detention
time.
                                332

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u
                                                         TABLE VII-5

                              CALCULATED TOXIC AND NONCONVENTIONAI. POLLUTANT REMOVAL RATES1(a)
Mill 9(b)
10-Day
ASB
Resin Acids
Abietic 0.85
Dehydroabietic 1.05
Isopimaric 0.30
Pimaric 0.10
Unsaturated Fatty Acids
Oleic
Linoleic
Linolenic
Other Acidics
Epoxysteric Acid
Dichlorosteric Acid
Chlorinated Resin Acids
Monochlorodehydroabietic
Dichlorodehydroabietic
Chlorinated Phenol ics
Tri chl oroguaiacol
Tetrachloroguaiacol
Chloroform
Mill ll(b)
6 -Day
ASB
0.86
2.65
0.37
0.14
0.7
2.6
0.4

0.10
0.05
0.03
0.02
2.2
Mill 12(c)
3.5-Hr
AS
0.3
0.6
0.26
0.3
0.35
0.30

0.006
0.019

2.1
Mill 13(b)
12-Day
ASB
1.5
1.85
1.25
0.3
0.55
0.15
10.4
0.03
0.10


Mill 14(b) Mill 15(b)
7-Day 15-Day
ASB ASB
1.0 0.45
1.1 0.72
3.0 0.12
0.1 0.15
0.67
0.47
0.03
0.12
0.01
0.03


        (a)  Removal rates shown as micrograms removed per milligrams/liter (mg/1) of biomass per day.
        (b)  Aerated stabilization basin (ASB) biomass assumed to l>e 200 mg/1.
        (c)  Activated sludge (AS) biomass reported to be 2,500 mg/1.
        NOTE:   Blank spaces indicate no data.
        *Source:  Easty,  Dwight B., L.G. Borchardt, and B.A.  Waber; , Institute of Paper Chemistry,
                 Removal of Wood Derived Toxics from Pulping and Jileaching Wastes, U.S. Environmental
                 Protection Agency, Cincinnati, OH,  EPA 600/2-78-031, 1978.(90)

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Typical design BOD5_ loads range from 56 to 67  kilograms  per  hectare
(kg/ha)  of  surface  area/day  (50 to 60 Ib/acre/day).(48)  Retention
times can vary from 20  to  60  days  or  more.(48)   This  method  of
treatment  has  two  principal  advantages:   a)  it  can be capable of
handling  (buffering)  accidental  discharges  of  strong   wastewater
without  significant  upset  and  b) it requires no mechanical devices
with inherent maintenance problems.  Oxidation basins have  been  used
to effectively treat pulp, paper, and paperboard industry wastewaters.
Generally,   suspended  solids  are  effectively  removed  in oxidation
basins.  However, high levels of suspended solids have been noted  due
to  algal  carryover.   Literature  presenting  data on the removal of
toxic and nonconventional pollutants through application of  oxidation
basin technology is limited.

Aerated  Stabilization Basins (ASBs).   The aerated stabilization basin
(ASB) evolved from the necessity of increasing performance of existing
oxidation  basins  due  to  increasing  effluent  flows  and/or   more
stringent  water  quality  standards.    Induced  aeration  provides  a
greater supply of oxygen, thus substantially  reducing  the  retention
time  required  to achieve treatment comparable to that attained in an
oxidation basin.  Nitrogen  and  phosphorus  (nutrients)  are  usually
added prior to the ASB if the wastewater is nutrient deficient.  These
additions  are  commonly  made  in  the form of ammonia and phosphoric
acid.  The  longer  the  retention  period  of  the  waste  undergoing
biological   oxidation,  the  lower  the  nutrient  requirement.   The
specific detention time used depends upon the characteristics  of  the
wastewaters  to  be  treated.   Retention  times  of 8 to 10 days, and
sometimes up to 15 days, have been used in order to obtain low  levels
of  BOD5_. (94)  The  specific  detention  time  used  depends  upon the
characteristics of the wastewaters to be treated.

Aeration is normally  accomplished  using  either  mechanical  surface
aerators  or  diffused air.  Oxygen transfer efficiencies under actual
operating conditions range from 0.61 to 1.52 kilograms (kg) of  oxygen
per  kilowatt-hour  (kwh),  or  about  (1.0  to  2.5  Ib of oxygen per
horsepower-hour) depending on the type of equipment used,  the  amount
of  aeration  power  per  unit  volume,  basin  configuration, and the
biological characteristics of the system.(95)(96)  It is necessary  to
maintain a dissolved oxygen (DO) level of 0.2 to 0.5 mg/1 in the basin
to sustain aerobic conditions.

BOD5_  and  suspended  solids  levels,   oxygen  uptake,  and  DO levels
throughout the basins are related to aerator location and  performance
and  basin configuration.  There have been extensive studies of eleven
existing aerated stabilization basins that have led to development  of
design criteria to aid in the design of future basins.(97)

Some  solids accumulate in the bottom of ASBs that can be removed with
periodic dredging.  Solids accumulation diminishes  as  the  detention
time  and degree of mixing within the basin increases.  At some mills,
a quiescent zone, settling basin, or  clarifier  is  used  to   improve
effluent clarity and to reduce suspended solids.
                                334

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The  toxicity  removal  efficiency of an ASB treating unbleached kraft
waste  was  evaluated  over  a  one-month  period  in  late  1976.(98)
Although  the  raw  wastewater  exhibited  an LC-50 of from one to two
percent by volume, all but one of the 26 treated effluent samples were
either nontoxic or exhibited greater than  50  percent  fish  survival
after 96 hours of exposure.  The one failure was attributed to a black
liquor  spill  at the mill.  Average reductions of 87 percent BOD5_, 90
percent toxicity, and 96 percent  total  resin  acids  were  achieved.
Dehydroabietic  acid was the only resin acid identified in the treated
effluent; pimaric, isopimaric and abietic acids tended to  concentrate
in the foam from the effluent.

Pilot-scale  ASB  treatment of bleached kraft wastewater was evaluated
over a five month period.(92)  Two basins, one with a five day and one
with a three day hydraulic  detention  time,  were  studied  with  and
without  surge  equalization.  The raw wastewater BOD5_ varied from 108
mg/1 to 509 mg/1 and was  consistently  toxic.   The  median  survival
times  (MST) of fish ranged from 7 to 1,440 minutes, while total resin
and fatty acid concentrations ranged from 2 to 9 mg/1. (92)  Mean  BOD5_
removals  with  surge  equalization  were  85 percent for the five day
basin and 77 percent for the three  day  basin.   Mean  effluent  BOD5_
levels with surge equalization were 40 mg/1 for the five day basin and
59  mg/1  for  the  three  day  basin.  Detoxification was attained 98
percent of the time by the five day basin with surge equalization  and
85 percent of the time by the three day basin with surge equalization.
Mean  reported  effluent  BOD5_  values  for the five day and three day
basins without equalization were 51 mg/1 and  67  mg/1,   respectively.
The detoxification rate without equalization dropped to 73 percent for
the  five  day  basin  and  70  percent  for the three day basin.  The
authors concluded that surge equalization  appeared  to  have  a  more
significant  effect  on  detoxification  than BOD5_ removal.  Since the
surge capacity  of  an  aerated  stabilization  basin  is  related  to
hydraulic  detention  time,  the  eight  to  ten  day basins which are
commonly employed in the pulp, paper, and paperboard industry  in  the
United  States  could  have  a  higher capacity for shock loading than
those used in this study.

Aerated stabilization basins provide a high degree of  BOD5_  reduction
and  also  can  remove or reduce the wastewater toxicity.  ASB capital
and operating costs may be lower than those for the  activated  sludge
process.   The treatment efficiency is not as dependent on ambient air
temperature as with oxidation basins; however, efficiency can be  more
dependent  on  ambient  air  temperature for ASBs than for higher rate
processes (i.e., activated sludge).(99)

Activated Sludge Process.  The activated sludge process is a high-rate
biological  wastewater  treatment  process.    The   biological   mass
(biomass)  grown  in  the  aeration  basins  is settled in a secondary
clarifier and varying amounts of this  biomass  are  returned  to  the
aeration   basins,   building  up  a  large  concentration  of  active
biological material.   It is common to maintain 2,000 to 5,000 mg/1  of
active  biological  solids  in  the  aeration  basin  section  of  the
activated sludge system compared to the  50  to  200  mg/1  common  to
                                 335

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aerated  stabilization basins.   Loadings in excess of 1.6 kilograms of
BOD5_ per cubic meter (100 Ibs of  BOD5_  per  1,000  ft3.)  of  aeration
capacity  per  day  are  sometimes used, allowing for relatively small
aeration basins.

The  characteristically  short  detention  times  tend  to  make   the
activated sludge process more susceptible to upset due to shock loads.
When  the  process  is  disrupted,  it  may  require  several days for
biological  activity  to  return  to  normal.     Particular   operator
attention is required to avoid such shock loadings at mills where this
process  is employed.  The necessity for strict operator attention can
be avoided through provision of sufficient  equalization  to  minimize
the effects of shock loadings.

Compared  with  aerated  stabilization  basins,  the  activated sludge
process  has  less  shock  load  tolerance,  greater  solids  handling
requirements, and higher costs.  However, the activated sludge process
requires  less  land  than  ASBs.    Thus, it may be preferred in cases
where sufficient land for ASB installation is  either  unavailable  or
too expensive.

The  activated  sludge  process is very flexible and can be adapted to
many waste treatment situations.  The  activated  sludge  process  has
many  modifications that can be selected as most appropriate.  Various
types of activated sludge processes that have been  applied  to  treat
pulp,  paper,  and paperboard wastewaters include:'a) conventional, b)
complete-mix, c) tapered  aeration,  d)  step  aeration,  e)  modified
aeration, f) contact stabilization, g) extended aeration, h) oxidation
ditch,  and  i)  pure  oxygen.    Another  process,  the Zurn-Attisholz
process consists of  a  two  stage  system.   Table  VI1-6  summarizes
standard  design  parameters  for  the  activated  sludge  process and
several of its modifications.(100)

In the conventional activated sludge process,  both influent wastewater
and recycled sludge enter the aeration basin at the head end  and  are
aerated for a period of about four to eight hours or more.  Mechanical
surface aerators similar to those used in aerated stabilization basins
are  used; the use of diffused air is becoming more common.  Normally,
the oxygen demand decreases as the  mixed  liquor  travels  the  basin
length.   The  mixed  liquor  is  settled  and the activated sludge is
generally returned at a rate of approximately 25 to 50 percent of  the
influent flow rate.

In  the complete-mix activated sludge process, influent wastewater and
recycled sludge enter the aeration basin at several points  along  the
length  of  the basin.  The mixed liquor is aerated at a constant rate
as it passes from the central channel to  effluent  channels  at  both
sides  of  the  basin.  The contents of the basin are completely mixed
and the oxygen demand remains uniform throughout.  The aeration period
is from three to five hours or  more,  and  the  activated  sludge  is
returned at a typical rate of 25 to 100 percent of influent flow rate.
                               336

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                                                       TABLE VJI-6

                                TYPICAL DESIGN PARAMETERS FOR ACTIVATED SLUDGE PROCESSES1
                                                                            Parameter
u>
CO
—I
          Process Modification
                                    Volumetric loading
                                   (Ib 8005/1,000 cu ft)
 MLSS (mg/1)
Detention Time
   V/Q (hr)	
          Conventional
          Complete mix
          Step aeration
          Modified aeration
          Contact stabilization

          Extended aeration
          Pure oxygen systems
                                          20-40
                                          50-120
                                          40-60
                                          75-150
                                          60-75

                                          10-25
                                         100-250
(a) Contact unit.
(b) Solids stabilization unit.
MLSS = Mixed Liquor Suspended Solids
V = Volume
Q = Flow
 1,500-3,000
 3,000-6,000
 2,000-3,500
   200-500
(1,000-3,000)(a)
(4,000-10,000)(b)
 3,000-6,000
 6,000-8,000
1
         4-8
         3-5
         3-5
        .5-3
        .5-1.0)(
        (3-6)(b)
        18-36
         1-3
           Source:  Metcalf and Eddy, Inc., Wastewater Engineering, McGraw-Hill Co., 1972 (100)

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The  tapered-aeration  process  is  a modification of the conventional
process with the primary difference being the amount of air  supplied.
At  the  head  of the basin,  where wastewater and returned sludge come
into contact, more oxygen is  required.   As the mixed liquor  traverses
the  aeration  basin,  the  oxygen  demand  decreases  so  aeration is
decreased.  Since the oxygen   supply  is  decreased  with  the  oxygen
demand, a lower overall oxygen requirement can be achieved.

The  step-aeration  process also is a modification of the conventional
activated sludge process.  In this  modification,  the  wastewater  is
introduced  at  several  points  in  a compartmentized basin while the
return activated sludge is introduced at the head of the basin.   Each
compartment  of  the  basin  is a separate step with the several steps
linked together in  series.   Aeration  can  be  of  the  diffused  or
mechanical  type and is constant as the mixed liquor moves through the
tank in a plug-flow fashion.   The  oxygen  demand  is  more  uniformly
spread over the length of the basin than in the conventional activated
sludge  process, resulting in better utilization of the oxygen supply.
The aeration period is typically between three and five hours and  the
activated  sludge is returned at a typical rate of 25 to 75 percent of
influent flow rate.

The contact-stabilization process takes advantage  of  the  absorptive
properties  of  activated sludge through operation in two stages.  The
first is the absorptive phase in which most of the  colloidal,  finely
suspended, and dissolved organics are absorbed in the activated sludge
in a contact basin.  The wastewater and return stabilized sludge enter
at the head of the contact basin, are aerated for a period of 30 to 60
minutes  or more, and settled in a conventional clarifier.  The second
stage is the oxidation phase,  in  which  the  absorbed  organics  are
metabolically  assimulated  providing  energy and producing new cells.
In this stage, the  settled  solids  from  the  absorptive  stage  are
aerated  for  a  period  of  from  three  to  six  hours  or more in a
stabilization basin.  A portion of the solids are wasted to maintain a
constant mixed liquor volatile suspended solids  (MLVSS)  concentration
in  the  stabilization  basin.  Contact stabilization has been applied
successfully at several facilities to treat kraft mill wastewaters.

The extended-aeration  process  is  a  complete-mix  activated  sludge
process  in  which  the  aeration  period is relatively long  (18 to 36
hours or more) and the organic loading  relatively  low.   Because  of
these   conditions,   the  process  is  very  stable  and  can  accept
intermittent loads with minimal or no upset.  The  solids  settled  in
the  clarifiers  are  recirculated  to  the  influent  of the aeration
basins.  Through this process, a mass of biological solids  are  built
up  in  the  aeration  basin.   This biomass assists in achieving high
treatment efficiencies through removal of dissolved organic matter  in
the wastewater by oxidation.   Excess secondary solids, if present, are
wasted  from the process.  Oxygen may be provided by either mechanical
or diffused aeration.  This  process  has  been  applied  successfully
throughout  the  pulp,  paper,  and  paperboard  industry.  In northern
climates, where temperature can impact  the  system  performance,  the
                               338

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extended-aeration  process  offers  the stability of an ASB system and
the high treatment efficiency of the activated sludge process.

The oxidation ditch activated sludge process is  an  extended-aeration
process in which aeration and circulation are provided by brush rotors
placed  across  a  race track-shaped basin.  The wastewater enters the
ditch at one end, is aerated, and  circulates  at  about  0.3  to  0.6
meters  per  second  (1  to 2 fps).  Operation can be intermittent, in
which case clarification takes place in the ditch, or  continuous,  in
which  case  a  separate clarifier and piping for recycling of settled
solids are provided.

The ability of activated sludge basins to detoxify bleached kraft mill
effluents was analyzed over a five month period.(92)  Two  pilot-scale
activated sludge systems (8-hr and 24-hr detention) were operated with
and  without  surge equalization.  Raw wastewater BOD5_ varied from 108
to 509 mg/1.  The raw wastewater was consistently toxic.  Reported raw
wastewater median survival times (MST) to fish ranged from 7 to   1,440
minutes.   Total  resin  and  fatty  acid  concentrations  in  the raw
wastewater ranged from 2 to 9 mg/1.

Mean BOD5_ removals for the 8-hr and  24-hr  activated  sludge  systems
with  a  12-hr  surge  equalization  basin  achieved  an average of 72
percent and 76 percent  BOD5_  removal,  respectively.   Effluent  BOD5_
concentrations  for  the  24-hr system ranged from 5 mg/1 to 263 mg/1,
with a mean of 59 mg/1.  The 24-hr system detoxified the  effluent  87
percent  of the time.  Final effluent BOD5_ concentrations for the 8-hr
system ranged from 14 to 270  mg/1  with  a  mean  of  70  mg/1.   The
effluent was detoxified 89 percent of the time.(92)

The 24-hr activated sludge system, when operated without equalization,
was  subjected  to  more  vigorous mixing plus the addition of 10 mg/1
alum.  Under these conditions, an average of 90 percent  BOD5_  removal
was  obtained and detoxification was achieved 100 percent of the  time.
The  8-hr  activated  sludge  system,  when  operated  without    surge
equalization,  was  also  subjected  to  more  vigorous mixing with no
addition of alum.  Under these conditions, an average  of  84  percent
BOD5_  removal  was obtained, although detoxification was attained only
55 percent of the time.(92)  The authors concluded  that  equalization
did   not   affect   BOD5_   removal   efficiency,   but  improved  the
detoxification efficiency by 15 to 30 percent.  Addition  of  alum  to
the  activated sludge system appeared to reduce toxicity.  The authors
speculated that the mechanism  of  toxicity  removal  was  a  chemical
reaction.(92)   Failures to detoxify were attributed in some instances
to hydraulic shocks, black  liquor  spills,  or  inadequate  treatment
system  operation,  although  in  many  instances  no  cause  could be
determined.(92)

The pure oxygen activated sludge process uses oxygen, rather than air,
to stimulate biological activity.  This scheme  allows  for  a  lesser
detention  time  and  a  lower aeration power requirement than for the
conventional activated sludge process; however,  additional  power  is
required  for  oxygen  generation  which may result in a net increased
                                339

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power requirement.   Waste  secondary  solids  volumes  that  must  be
dewatered  and  disposed  of  are  similar  to  those  produced by air
activated sludge systems.

Field test data by  Union  Carbide  Corp.  confirms  that  the  oxygen
activated  sludge  process is capable of achieving final effluent BOD5_
concentrations on  the  order  of  15  to  30  mg/1  when  applied  to
unbleached  kraft  wastes.(101)  Effluent  TSS after clarification was
generally in the range of 40 to 60 mg/1.(101) A summary of pilot-scale
information is presented in Table VII-7.

A sulfite-newsprint effluent was treated  using  an  oxygen  activated
sludge  pilot plant facility over an 11 month period.  BOD5_ reductions
during this time were  over  90  percent.(102)   Final  BOD5_  and  TSS
concentrations  ranged  from  23  to  42  mg/1  and  61  to  111 mg/1,
respectively.(102)  The effluent  from  the  oxygen  activated  sludge
system  was  found to be acutely toxic.(102)  Total resin acids before
and after oxygen activated  sludge  treatment  were  25  and  6  mg/1,
respectively.(102)   Ammonia  was  found  at levels on the order of 50
mg/1.  The treated effluent was air stripped to determine  if  ammonia
was  the  major  cause  of  the high toxicity.  Although air stripping
reduced the ammonia concentration to less than 1  mg/1  and  the  total
resin  acid  concentration  to  1 mg/1,  the effluent remained acutely
toxic.

Easty studied two examples of pure oxygen  activated  sludge  systems:
one  treating  integrated  bleached  kraft  wastewater  and  the other
treating   unbleached   kraft   pulp   mill   wastewater.(90)     Both
significantly  reduced  all  identified  pollutants.   The  pollutants
evaluated  included  resin  and   fatty   acids,    their   chlorinated
derivatives,  and chloroform.  The first system incorporated an oxygen
activated sludge basin with hydraulic detention of 190 minutes  and  a
sludge  recycle rate of 35 percent.  The pH was maintained between 6.2
and 7,5.  It was determined from Easty's data that 43 to 92 percent of
identified pollutants were removed, with the chlorinated  resin  acids
exhibiting  relatively  low  removal efficiencies.  This is consistent
with observed biodegradabilities of bleach plant derivatives.(103)

The second oxygen activated sludge system was operated at a  detention
time  of  3.7  hours  and  a  mixed  liquor  suspended  solids  (MLSS)
concentration of  2,500  mg/1.(90)   Bench-scale  alum/polyelectrolyte
coagulation  followed.   The  effluent  was adjusted to a pH of 5 with
alum; 1 mg/1  of  polyelectrolyte  was  added.   Essentially  complete
removal  of  all  identified  resin  and fatty acids was obtained.  It
should also be noted that initial concentrations in the raw waste were
relatively low.   Since no data were reported for the oxygen  activated
sludge  system without chemically assisted clarification, the relative
effects of each of the two processes on removal efficiencies could not
be determined.

The Zurn/Attisholz (Z/A)  process  is  a  two-stage  activated  sludge
system.   The  first stage operates at a DO of less than 1.0 mg/1; the
DO level in the second stage is maintained at 4 to 5  mg/1.   Nutrient
                              340

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                                          TABLE VII-7
                             OXYGEN ACTIVATED SLUDGE TREATABILITY
                                         PILOT SCALE1
Production Process
Alkaline-Unbleached
Alkaline-Unbleached
Alkaline-Unbleached
Retention
(Hr)
1
1
2
.3 -
.8 -
.0 -
2.2
3.0
2.9
BODS (mg/1)
Influent
277
214
265
- 464
- 214
- 300
Effluent
20
16
25
- 41
- 22
- 30
TSS
Influent
57 -
123 -
95 -
86
123
120
(mg/1)
Effluent
46
36
60
- 61
- 36
- 70
aSource:  Technical data supplied by Union Carbide Corp.(101)

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and  power  requirements for the two-stage system are similar to those
for the conventional activated sludge process.   A total Z/A  detention
time  of four hours may be required to achieve BODS^ and TSS reductions
comparable  to  activated  sludge  and  aerated  stabilization   basin
systems.

Seven  full-scale Zurn/Attisholz systems are currently in use at pulp,
paper, and paperboard mills in the United States.  These installations
treat wastewaters from the following types of manufacturing:

                    Deink(Fine or Tissue)     (5 mills)
                    Papergrade Sulfite        (1 mill)
                    Groundwood-Fine Papers    (1 mill)

At most of the mills where the Zurn/Attisholz process is  used,   final
effluent BOD5_ and TSS concentrations in the range of 20 to 25 mg/1 are
attained. (104)  At  one mill,  BOD5_ and TSS levels in the range of 5 to
10 mg/1 are attained. (104) At another mill, 96  percent  BOD5_  and  99
percent TSS reductions are attained using the Z/A process.(105)

A pilot study comparing a two-stage to a single-stage activated sludge
system  was  recently  performed.  The authors concluded that the two-
stage system achieved a higher toxicity reduction in treating bleached
kraft wastewater than did a single-stage system.(106)(107 )

Rotating Biological Contactor (RBC).  This system involves a series of
discs on a shaft supported above a basin containing  wastewater.   The
discs  are 40 to 45 percent submerged in the wastewater and are slowly
rotated; a biological slime  grows  on  the  disc  surfaces.   Closely
spaced  discs  with  a diameter of 3.7 meters (12 ft) mounted on a 7.6
meter (25 ft) shaft can result in 9,300 square meters (100,000 sq  ft)
of surface area.

Pilot-scale  evaluations  of  an  RBC  system  treating bleached kraft
wastewater with an average influent BOD5_  concentration  of  235  mg/1
have  resulted  in  substantial  BOD5_  reductions. (108)  The degree of
removal is related to the hydraulic loading rate,  as  seen  in  Table
VI1-8.   Secondary  waste solids production reportedly ranged from 0.3
to 0.5 kg of solids per kg of BOD5_ removed (0.3 to 0.5  Ib  of  solids
per Ib of BOD5_ removed) .(1 08 )

Two    pilot   plant   evaluations   reported   essentially   complete
detoxification of board mill,  integrated  kraft,  and  magnesium-based
sulfite  mill  effluents. (1 09)  Final effluent BOD5. of 59 mg/1 for the
kraft mill, 65 mg/1 for the board mill, and 338 mg/1 for  the  sulfite
mill  were  reported.  Raw wastewater BOD5_ levels for these mills were
290 mg/1,  285 mg/1, and 1,300 mg/1, respectively.  No  TSS  data  were
reported, (109)  This pilot plant work indicates good toxicity and BOD5_
reduction  capabilities.   However, to date, mill-scale systems in the
United States treating pulp mill wastewater have encountered operating
difficulties.
                                342

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                                   TABLE VII-8

                      PILOT RBC FINAL EFFLUENT QUALITY FOR
                           BLEACHED KRAFT WASTEWATER1
                               70% of Time                 90% of Time
   Hydraulic                  Final Effluent              Final Effluent
 Loading Rate                 BOD5 Less Than              BOD5 Less Than
  (gpd/sq ft)	(mg/1)	(mg/1)

       3                            70                           90

       2                            30                           45

       1                            22                           39


Note: Raw Effluent BOD5 = 235 mg/1.

1Source: Gillespie, W.J., D.W. Marshall, and A.M. Springer, A Pilot Scale
         Evaluation of Rotating Biological Surface Treatment of Pulp and
         Paper Wastes, NCASI, TAPPI Environmental Conference, April 17-19,
         1974.(108)
                                     343

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Anaerobic Contact Filter.  This process involves the use  of  a  basin
filled with crushed rock or other media.  Wastewater is passed through
the  media  at  a  temperature  of  32°  to  35°C (90° to 95° F) under
anaerobic conditions; detention times on the order of three  days  are
common.   Steam  stripping,  nutrient  addition,  neutralization,  and
dilution  of  waste  liquor  with  wash  water  may  be  required   as
pretreatment.
A  laboratory  study of this process showed that 80 to 88 percent     ^
removal from sulfite wastewaters have been  achieved. ( 1 1 0)  The  major
advantage  of  the  process  is  a  low solids production rate of 0.08
kilograms of solids per kilogram  of  BODS^  removed  (0.08  pounds  of
solids  per  pound  of  BODS^  removed).   This is because methane gas,
rather  than  biological  solids,  is  the  by-product  of   anaerobic
digestion.   The  author  concludes  that  the  cost for the anaerobic
process   was   approximately   the   same   as   that   for   aerated
stabilization. (110)

Impact  of_  Temperature  Variations.  All biological treatment systems
are affected by  temperature,  particularly  by  large  and/or  sudden
temperature  changes.  The effect of temperature variations on aerobic
biological systems has been demonstrated in both theory and  practice;
therefore,  temperature  is  of importance in the choice of design and
operation of treatment systems.  McKinney stated that all processes of
growth are dependent on chemical reactions  and  the  rates  of  these
reactions   are  influenced  by  environmental  conditions,  including
temperature. ( 1 1 1 )    The  discussion  below  presents  theoretical  and
operating  data on temperature variations and their effects.  Included
is an evaluation of the effect of temperature on biological  treatment
system performance as measured by BOD5. and TSS removals.

BOD5_  is  a measure of the dissolved oxygen used by microorganisms for
the  biochemical  oxidation  of  organic  matter  in   a   wastewater.
Biochemical  oxidation  occurs  in two stages:  a first stage in which
the carbonaceous (organic) matter is oxidized and a  second  stage  in
which  nitrification occurs.  The oxidation of the carbonaceous matter
results from the biological activity of bacteria and  other  organisms
in  the wastewater.  For a stated set of environmental conditions, the
growth rate of microorganisms  is  predictable  and  reproducible  and
related  to  the  amount  of  organic  matter present in a wastewater,
measured as BOD5^,  and the rate at which the organic matter is consumed
by the microorganisms present .( 1 1 2)

The heterogeneous population of bacteria found in  aerobic  biological
systems  treating  wastewaters  at  temperatures  resulting  from  the
production of pulp, paper, and  paperboard  includes  three  types  of
bacteria: psychrophilic, mesophilic, and thermophilic organisms.

Seasonal  wastewater temperature variations change the specific growth
rate of the heterogeneous population and,  to  a  lesser  extent,  the
relative   distribution  of  the  types  of  bacteria  comprising  the
population.  McKinney (111) depicted the rate of growth for mesophilic
organisms with the maximum rate occurring in the range of 35° to  40°C
                                344

-------
(95°  to  104°F).  Similar growth rate/temperature distributions exist
for both psychrophilic and thermophilic organisms,  with  the  optimal
growth  rate  occurring  in the range of 10° to 15°C (50° to 59°F) for
psychrophiles, and 60° to 65°C (140° to 149°F) for  thermophiles.(103)
However,   the   predominant  group  found  at  all  normal  operating
temperatures in aerobic systems are the mesophiles.(100)

A number of studies have been conducted to quantify various aspects of
microbial growth, temperature, and  BOD5_  reduction.   Degradation  of
organic  matter  in  pulp,  paper, and paperboard wastewaters has been
evaluated and found to proceed at rates similar  to  other  wastewater
sources.(100)(113)(114)(115)(116)(117)(118)

Soluble  BOD5_  reduction  by  microorganisms  approximates first-order
kinetics.(100) A temperature decrease of 10°C (18°F) from the  optimal
temperature  would  necessitate  an  increase in detention or reaction
time of approximately 35 percent to  attain  the  same  effluent  BOD5_
level  as  that  attained  at the optimal temperature.   Conversely, an
increase in temperature of 10°C (18°F) would theoretically shorten the
detention time by 25 percent to attain the same effluent BOD5_ level.

The above concept is of substantial practical importance in  treatment
system  design, since flexiblity in design allows treatment systems to
sustain efficient operation over a wide  range  of  conditions   (i.e.,
decreasing    microbial   (solids)   wastage   rates   will   increase
waste/microbe contact time  when  microbial  activity  is  reduced  in
colder  temperatures).   An  additional  study  relates  the  specific
effects of  changes  in  temperature  on  BOD5_  and  suspended  solids
reduction to performance for specific systems.(99)

Ammonia  Removal Through Nitrification.  One method of ammonia removal
is  through  single-stage  nitrification  in  a  biological  treatment
system.    Nitrification  is  the  process  where  specific  bacteria,
Nitrosomonas and Nitrobacter, oxidize ammonia to nitrite nitrogen  and
then to nitrate nitrogen.

Biological  treatment systems presently employed at mills in the pulp,
paper, and paperboard industry are generally designed and operated for
oxidation of organic material (i.e., BOD!3 reduction).   It is possible,
however, to design and operate these systems to  accomplish  BOD5_  and
ammonia  reduction  in  a  single  step  or  in  a  series  of  steps.
Nitrifying organisms exhibit a very slow growth rate in comparison  to
organic   assimilation   and   are  very  sensitive  to  environmental
conditions and growth inhibitors,  such as  toxic  organic  wastes  and
heavy  metals.   Growth  rates  and,  thus,  nitrification  rates  are
profoundly  influenced  by   such   environmental   factors   as   pH,
temperature,  and  dissolved  oxygen  (DO)  concentrations.  Since the
nitrifiers are autotrophic,  inorganic carbon sources (such  as  carbon
dioxide,  carbonates,  and  bicarbonate)  have  a  large  influence on
microbial growth rates.(119)

Aerobic nitrifiers require relatively large  quantities  of  molecular
oxygen  to  complete the oxidation of ammonia.  The theoretical oxygen
                                345

-------
requirements, based on the  biochemical  equations  of  nitrification,
were  determined  to be 4.57 kg of 02_ required/kg of ammonia nitrified
(4.57 Ib of 02_ required/lb of  ammonia  nitrified).   Generally,  this
oxygen  demand  may  be  satisfied  by  atmospheric  molecular  oxygen
furnished through conventional aeration  techniques.   However,  since
the  nitrifiers  are  autotrophic and obtain their carbon requirements
from such compounds as carbon dioxide  and  bicarbonates,  the  oxygen
contained  in  these  compounds  may also be available for metabolism.
Thus, depending on the alkalinity of the wastewater, the actual oxygen
which must be furnished by aeration equipment may be  lower  than  the
theoretical  4.57  ratio.   Discounting  the ammonia required for BOD5_
removal, the nitrifiers will also utilize a fraction of the  available
nitrogen for synthesis of cellular components.  This ammonia demand is
estimated   to  be  equivalent  to  0.7  to  0.9  oxygen  equivalents;
therefore, the theoretical oxygen ratio of 4.57 would  be  reduced  to
about 3.9 kg of 02/kg of ammonia nitrified (3.9 Ib of 02/lb of ammonia
nitrified).(120)

Since  the  nitrifiers  have  slower growth rates, a biological system
designed for nitrification requires a longer detention time and longer
sludge age.  Insufficient nitrification will result unless the  sludge
wastage  rate  is  lowered  to accommodate the nitrifier requirements.
Therefore, the wastage  rate  is  usually  controlled  to  maintain  a
sufficient  sludge  age  in  the  system  to accomplish nitrification.
Published data for municipal wastes indicate that a sludge age greater
than four days in the activated sludge  process  is  adequate  for  90
percent  nitrification  at  20°C  (68°F).(120)  Laboratory experiments
conducted on pulp and  paper  wastewaters  (weak  black  liquor)  with
influent  ammonia  and  BOD5_  concentrations  of 264 mg/1 and 511 mg/1
indicate that a sludge age of approximately 14 days  is  required  for
conversion of 90 percent of the ammonia to nitrate. (119)

In  the  absence of severe inhibitors, a single-stage activated sludge
system  can  be  properly  designed  to  achieve  BOD5_   removal   and
nitrification  in  a  single  aeration  basin.   Available  literature
indicates that 90 percent ammonia  removal  can  be  achieved  through
nitrification   provided   that   proper   operating   conditions  are
maintained.(100)(117)(121)(122)(123)(124)(125) In  low strength wastes,
ammonia  removal  to  levels  of  less  than  10 mg/1  is  achieveable
depending  on  the  variability of the influent ammonia concentration.
(120)

The  sensitivity  of  the  nitrification  process   to   environmental
conditions   is  well  documented  in  the literature previously cited.
Temperature, pH, and dissolved oxygen  levels  are  parameters  having
interrelated  effects  on the nitrification process.  This sensitivity
and the difficulty in maintaining optimum environmental conditions can
be overcome  through treatment system design and operation.  To  offset
the  decrease  in  the  nitrification  rate  that  can occur if optimum
conditions are not maintained, longer aeration  basin  detention  time
and  longer  sludge ages can be employed and maintained.  Additionally,
provisions can be made to (a) neutralize the effluent  to  maintain   a
                                346

-------
proper pH,  and (b) heat or cool the effluent and/or cover the aeration
basins to maintain proper temperature.

Chemically Assisted Clarification

Dissolved and colloidal particles in treated effluents are not readily
removed  by  simple settling.  Colloidal particles can be agglomerated
by the addition of chemical  coagulants.   Coagulants  in  common  use
include  lime,  alum,  ferric  chloride, ferric sulfate,  and magnesia.
Detailed   discussions   of   the   chemistry   of   coagulants    are
available.(126)

Rebhun et al.  suggest that the most efficient method of pulp and paper
mill  effluent  flocculation  is a solids-contact type clarifier.(127)
Ives suggests a theory for the operation of solids-contact  clarifiers
that  considers their integrated role as flocculators, fluidized beds,
and phase separators.(128)  Ives states that the  criterion  for  good
performance  is  the dimensionless product of velocity gradient, time,
and floe concentration.  He also  suggests  that  model  floe  blanket
studies  can  be meaningful for full-scale operation provided that  the
concentration of floe in the blanket and the  blanket  depth  are  the
same in both model and prototype.(128)

Ives  also  suggests  a  number  of  design considerations for solids-
contact clarifiers.  For  floe  particles  to  form  a  blanket  in  a
circular  tank,  the upflow velocity of the water must be equal to the
hindered settling velocity of floe suspension.  It is  important  that
the  floe removed from the blanket balance the rate of floe formation.
The  clarifier  should  be  symmetrical;  the  inlet  flow  should  be
uniformly  dispersed  and  the collection at the outlet should also be
uniform.  The clear water zone should have a minimum  depth  equal   to
half the spacing between collection troughs.

Upon  floe  formation,  settling  is accomplished in a quiescent zone.
The clarification  process  results  in  waste  solids  that  must  be
collected,   dewatered, and disposed.  The quantity, settleability,  and
dewaterablity of the waste solids  depend  largely  on  the  coagulant
employed.  In some cases the coagulant can be recovered from the waste
solids and reused.

Case   studies   of   full,   pilot,   and  laboratory-scale  chemical
clarification systems are discussed in the following sections.

Case  Studies-Full  Scale  Systems.   Several  full-scale,  chemically
assisted  clarification  systems  have  been  constructed in the pulp,
paper, and paperboard industry and in other  industrial  point  source
categories.   Data  on  the capability of full-scale systems to remove
conventional  and nonconventional pollutants are presented below.

     Conventional  Pollutants  -  Recent  experience  with  full-scale
alum-assisted   clarification   of   biologically-treated  kraft  mill
effluent suggests that final effluent levels of 15 mg/1 each  of  BOD£
and  TSS  can  be  achieved.   The desired alum dosage to attain these
                                  347

-------
levels can be expected to vary  depending  on  the  chemistry  of  the
wastewater to be treated.  The optimum chemical dosage is dependent on
PH.

Chemical  clarification  following activated sludge is currently being
employed at a groundwood (chemi-mechanical)  mill.   According  to  data
provided  by  mill  personnel,  alum is added at a dosage of about 150
mg/1 to bring the pH to an optimum level of  6.1.   Polyelectrolyte  is
also  added  at  a  rate  of  0.9 to 1.0 mg/1 to improve flocculation.
Neutralization using NaOH is practiced prior  to  final  discharge  to
bring    the    pH    within   acceptable   discharge   limits.     The
chemical/biological solids are recycled through the  activated  sludge
system  with  no  observed  adverse  effects  on biological organisms.
Average reported results for 12 months of sampling data  (as  supplied
by  mill  personnel)  show  a  raw  wastewater  to final effluent BODS^
reduction of 426 mg/1 to 12 mg/1 and TSS reduction of 186 mg/1  to  12
mg/1.

Treatment  system  performance  at the mill  was evaluated as part of a
study conducted for the EPA.(129)  Data obtained over 22 months  shows
average  final effluent BOD5_ and TSS concentrations of 13 and 11 mg/1,
respectively.  As part  of  this  study,  four  full-scale  chemically
assisted  clarification  systems  in  other  industries were evaluated.
Alum coagulation at a  canned  soup  and  juice  plant  reduced  final
effluent  BOD5_  concentrations  from 20 mg/1 to 11 mg/1 and TSS levels
from 65 mg/1 to 22 mg/1.  Twenty-five mg/1 of alum plus  0.5  mg/1  of
polyelectrolyte  were  added to the biologically-treated wastewater to
achieve these final effluent levels.  Treatment plant performance  was
evaluated   at   a  winery  where  biological  treatment  followed  by
chemically  assisted  clarification  was  installed.   Final  effluent
levels  of  39.6  mg/1 BOD!5 and 15.2 mg/1 TSS from a raw wastewater of
2,368 mg/1 BOD5_ and  4,069  mg/1  TSS  were   achieved.   The  influent
wastewater  concentrations  to  the  clarification  process  were  not
reported.  The chemical dosage was 10 to 15  mg/1 of  polymer.(129)   A
detailed  summary of the results of the study of full-scale systems is
presented in Table VII-9.U29)

In October of 1979, operation  of  a  full-scale  chemically  assisted
clarification  system  treating effluent from an aerated stabilization
basin at a Northeast  bleached  kraft  mill   began.   This  plant  was
designed  and  constructed  after  extensive  pilot-scale studies were
completed.   The  purpose  of  operating  the  pilot  plant   was   to
demonstrate  that  proposed  water  quality   limitations  could be met
through  the  use  of  chemically   assisted   clarification.    After
demonstrating  that  it  was  possible  to  meet  the proposed levels,
studies were conducted to  optimize  chemical  dosages.   The  testing
conducted  showed  that the alum dosage could be reduced significantly
by the  addition  of  acid  for  pH  control,  while  still  attaining
substantial  TSS removal.  In the pilot-scale study, it was shown that
total alkalinity, a measure of a system's buffering  capacity,  was  a
reliable   indication   of  wastewater  variations  and  treatability.
Through this study, it was shown that there  is a  direct  relationship
between  total alkalinity and alum demand.  High alkalinity (up to 500
                                 348

-------
                                                                                         TABLE  SOI -9


                                                             SUMMARY OF CHEMICALLY ASSISTED  CLARIFICATION
                                                                         TECHNOLOGY  PERFORMANCE  DATA
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mg/1)  caused  by  the discharge of black  liquor or lime mud  results   in
high   alum  demands.   Therefore, a substantial portion of alum dosage
can  be  used   as an  expensive  and  ineffective  means  of   reducing
alkalinity    (pH)   to  the  effective  pH  point  (5-6)  for  optimum
coagulation.   The use of acid to assist in pH  optimization  can  mean
.substantial   cost  savings  and  reduction  in  the  alum  dosage rate
required to effect coagulation.  In one instance, use of  concentrated
sulfuric acid  for  pH  reduction  reduced alum demand by 45  percent.
Acid   addition  was  also  effective  in  reducing  alum  dosage    for
wastewaters with a low alkalinity (approximately 175 mg/1).(130) Table
VII-10  summarizes  effluent  quality   of  the full-scale system since
startup;  this system has been operated  at an approximate  alum dosage
rate   of 350  mg/1 without acid addition.  Recent correspondence with  a
mill representative indicated that, with acid  addition,  this dosage
rate   could   be  reduced  to 150 mg/1.(131) However, this lower dosage
rate has not  been confirmed by long-term operation.

A  chemically  assisted clarification system treating effluent   from   an
aerated   stabliization  basin  at  a southeastern U.S. deink-newsprint
mill began operation in 1979.  Typical  alum dosage rates are 450 mg/1;
polymer  is also  added at a rate of 1 to 1.5 mg/1.  Caustic is  added to
maintain final effluent pH  within  permitted  levels.   Table VII-11
summarizes  available  effluent  data   for this facility subsequent to
treatment system start-up and stabilization.

Amberg,  e£ al.  (132) reported on a cellulose mill located on the shore
of Lake  Baikal in the USSR.  The mill produced  200,000  kkg   (220,000
tons)  of tire  cord  cellulose and 11,000 kkg (12,100 tons)  of kraft
pulp per year.   Average water usage was  1,000  kl/kkg   (240   kgal/t).
The  mill had  strong  and  weak  wastewater collection and treatment
systems.  The average BOD5_ for the  weak  wastewater  system   was   100
mg/1,  while  the strong wastewater BOD5_ was 400 mg/1.  Only 20 percent
of the total  wastewater flow was included  in  the  strong  wastewater
system.   Each  stream  received  preliminary  treatment consisting of
neutralization to pH 7.0, nutrient addition, and aerated equalization.
Effluent from equalization was discharged  to  separate  aeration   and
clarification  basins.   These  basins  provided  biological treatment
using  a conventional  activated  sludge  operation.   Aeration    was
followed by   secondary  clarification.  Suspended solids were settled
and  50 percent of the sludge was returned  to  the  aeration   process.
Waste  sludge was  discharged  to lagoons.  The separate streams were
combined after clarification and were treated for color and  suspended
solids  removal  in reactor clarifiers with 250 to 300 mg/1 of  alum  and
1  to 2 mg/1 of polyacrylamide flocculant,  a  nonionic  polymer.    The
clarifiers  had  an overflow rate of approximately 20.4 cu m per day/sq
m  (500 gpd/sq ft).

Chemical clarification overflow was discharged to  a  sand  filtration
system.   The  sand  beds  were  2.9  m  (9.6  ft) deep with the media
arranged in five layers.(133) The sand  size varied from  1.3  mm   (0.05
in)  at the top to 33 mm (1.3 in) at the bottom.  The filter was  loaded
at  0.11 cu   m per  minute/sq m  (2.7  gpm/sq ft).  Effluent from sand
filtration flowed to a settling basin and then to an  aeration basin;
                                350

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                     TABLE VII-10

    FINAL EFFLUENT QUALITY OF A CHEMICALLY ASSISTED
CLARIFICATION SYSTEM TREATING BLEACHED KRAFT WASTEWATER
Date
September 1979
October 1979
November 1979
December 1979
January 1980
February 1980
March 1980
April 1980
May 1980
June 1980
July 1980
August 1980
September 1980
October 1980
November 1980
December 1980
January 1981
February 1981
March 1981
BOD5
Average
for Month
11
8
9
21
8
7
13
9
11
25
5
10
13
11
20
33
17
17
29
(rag/1)
Maximum Day
21
12
18
83
16
14
46
16
22
49
9
21
25
28
44
93
—
43
53
TSS 1
Average
for Month
87
40
28
21
28
31
44
32
38
39
22
40
40
34
60
50
30
47
49
tog/l)
Maximum Day
254
92
47
56
36
68
113
96
80
65
50
84
72
75
107
139
43
82
93
                          351

-------
                  TABLE VII-11

FINAL EFFLUENT QUALITY OF A CHEMICALLY ASSISTED
   CLARIFICATION SYSTEM TREATING WASTEWATER
          FROM A DEINK-NEWSPRINT MILL
                 BOD5 (mg/1)                   TSS  (mg/1)
Date
January 1980
February 1980
March 1980
April 1980
May 1980
June 1980
July 1980
August 1980
September 1980
October 1980
November 1980
December 1980
January 1981
February 1981
March 1981
Average
for Month
39
28
25
17
20
30
22
21
16
14
15
23
50
38
25
Maximum Day
88
59
46
33
53
56
44
35
35
22
32
37
92
45
51
Average
for Month
18
18
16
19
20
28
13
18
21
15
15
23
32
21
14
Maximum Day
45
48
43
45
53
76
35
46
109
28
105
69
84
50
56
                       352

-------
both  basins  were  operated  in  series  and  provided  a  seven hour
detention time.

The effluent quality attained was as follows:

Parameter                  Raw Waste    Final Effluent

BOD5 (mg/1)                  300              2
Suspended Solids (mg/1)       60              5
pH                            -           6.8-7.0

Individual treatment units were not monitored for  specific  pollutant
parameters.

     Nonconventional   Pollutants.   The  development  of  coagulation
processes for color removal has been  traced  by  many  investigators.
Investigators  concluded  that  lime  precipitation  was a coagulation
process for color removal which afforded the possibility  of  chemical
recovery  utilizing  existing mill equipment.  Based on the results of
this early work, research continued  towards  development  of  a  lime
precipitation  process.  The overriding problem in this work continued
to be the difficulty of dewatering the lime-organic sludge.   Specific
studies  were  conducted for resolving the sludge problem with limited
success.(134)(135)

Continuing efforts to improve the dewatering of the lime sludge led to
consideration of using large dosages of lime for color reduction.   It
was believed that a large quantity of rapidly draining materials would
reduce  the effect of the organic matter on dewatering.  This thinking
led to the development and patenting of the "massive lime" process  by
the National Council for Air and Stream Improvement.  In this process,
the  mill's  total  process  lime  is slaked and reacted with a highly
colored effluent stream, usually the caustic extraction effluent.  The
lime sludge is then settled,  dewatered,  and  used  for  causticizing
green  liquor.   During the causticizing process, the color bodies are
dissolved in the white liquor and eventually burned  in  the  recovery
furnace.   Although  the massive lime process had been demonstrated as
an effective color removal system, the process was  not  taken  beyond
the pilot stage for several years.

The  first  installation of the massive lime color system was operated
at a mill in Springhill, Louisiana.  The 33.4 liter per sec (530  gpm)
demonstration  plant  was  used  to  treat  the  bleach  plant caustic
extraction and unbleached stock  decker  wastewaters.   These  streams
contributed 60 to 75 percent of total mill color.  In the process, the
lime slurry dosage was 20,000 mg/1.

The  demonstration  plant  at  Springhill  was  first tested using 100
percent bleach plant caustic extraction effluent.  Various amounts  of
unbleached  decker  effluent  were then added until TOO percent decker
effluent was treated.  Color removal ranged from 90 to 97 percent with
an average of 94 to 95 percent (136).  Organic carbon  removal  ranged
from  55  to  75  percent  and generally increased with higher colored
                                   353

-------
effluent.  The values  reported  are  shown  in  Table  VII-12.    BOD5_
removals  of  25  to  45 percent were reported with lower values found
during treatment of most highly-colored effluent.   The net  effect  of
the treatment process was estimated as a 72 percent reduction of total
mill color.

The  massive  lime  process,   as  developed,  required lime dosages of
approximately 20,000 mg/1.   Because of this, only a  relatively  small
effluent  stream  could  be treated with the quantity of lime used for
causticizing  green  liquor.    Additionally,  this  process   required
modifications  to  the recovery system.  These restrictions led to the
development  of  an  alternative  process  employing  "minimum   lime"
treatment.   Lime  dosages  of  1,000 to 2,000 mg/1 are common to this
process.(137)(138) A previous EPA document reported data on full-scale
minimum  lime treatment systems.(47) Two  systems  treating  unbleached
kraft  and  NSSC effluents are known to be operating.  Color levels of
1,200 to 2,000 color units are reported to be 80 to 90 percent removed
with lime dosages  of  1,000  to  1,500  mg/1.   A  full-scale  system
treating  the  first caustic extract of a bleached kraft mill has been
shut down.  When operating, lime dosages of 1,500 to 3,000  mg/1  were
used  to  remove  90 percent of a color load that ranged from 8,000 to
10,000 color units.(47)

Case Studies-Pilot and Laboratory Scale  Systems.   Several  laboratory
and  pilot-scale  studies  of  the  application of chemically assisted
clarification to treat pulp,  paper, and  paperboard  wastewaters  have
been  conducted.   Available data on the capability of this technology
to  remove  conventional  and  nonconventional  pollutants  based   on
laboratory and pilot-scale studies are presented below.

     Conventional  Pollutants  -  As part of a study of various solids
reduction techniques, Great Southern Paper Co. supported a pilot-scale
study  of  chemically  assisted  clarification.(139)   Great  Southern
operates  an integrated unbleached kraft mill.  Treatment consisted of
primary  clarification and aerated stabilization followed by a  holding
pond.    The average suspended solids in the discharge from the holding
pond were 65 mg/1 for the period January 1, 1973 to December 31, 1974.
In tests on this wastewater,  70 to 100 mg/1 of alum at  a  pH  of  4.5
provided optimum coagulation.  Three alum dosages were tested.  At the
optimum  dosages,  the removals after  24 hours of settling ranged from
83 to 86 percent.  Influent TSS of the  sample  tested  was  78  mg/1.
Effluent TSS concentrations ranged from 11 to  13 mg/1.

In a recent EPA-sponsored laboratory study, alum, ferric chloride, and
lime  in  combination  with  five  polymers  were evaluated in further
treatment of biological effluents from four pulp and paper mills.(140)
Of the three chemical coagulants, it was reported that  alum  provided
the  most  consistent  flocculation at minimum dosages, while lime was
the least  effective  of  the  three.   However,  the  study  provides
inconclusive results in determining the optimum chemical to be used or
the    optimum    chemical    dosage   for   removal   of   TSS   from
biologically-treated effluents.  These inconclusive findings  are  the
result of a number of factors, including  (a) the lack of determination
                                 354

-------
                                                          TABLE VII-12



                                            COLOR AND ORGANIC CARBON REMOVAL AFTER

                                            APPLICATION OF MASSIVE LIME TREATMENT1
GO
cr\
en
Composition of Treated Effluent
Bleach Plant Caus-
tic Extraction
Stage Effluent
(%)
100
67
60
50
33
20
0
0
Kraft
Decker
Effluent
(%)
0
33
40
50
67
80
100
100
Effluent Color
(APHA Color Units)
Before After
Treatment Treatment
21,546 1,265
14,325 745
12,125 594
10,043 451
6,612 331
4,660 298
l,640(a) 140(a)
900(b) 234(b)

Color
Removal
(%)
94.2
94.8
95.1
95.5
95.0
93.6
91.5(a)
74.0(b)
Organic
Carbon
(mg/D
Before
Treatment
1,446
1,016
905
798
569
450
270(a)
268(b)
After
Treatment
373
253
248
245
183
173
120(a)
126(b)

Organic Carbon
Removal
(%)
74.2
75.1
72.6
69.3
67.8
61.6
55.6(a)
53.0(b)
            (a) Very  little  paper mill white water reuse  for decker pulp washing  or  as make-up  water.


            (b) Practically  all water used  in decker system was white water  from  paper mill.


            'Oswalt,  J.L., and J.G. Land Jr., Color Removal from Kraft  Pulp  Mill  Effluents  by Massive  Lime

            Treatment,  EPA Project 12040  DYD,  1973.(136)

-------
of  an  optimum  pH  to  effect  removal  of  TSS,   (b)  the  lack  of
consideration of higher chemical dosages  when  performing  laboratory
tests even though data for some mills indicated that better removal of
TSS was possible with higher chemical dosage (a dosage of 240 mg/1 was
the  maximum  considered  for alum and ferric chloride, while 200 mg/1
was the maximum dosage used for lime), (c)  the  testing  of  effluent
from  one  mill  where  the  TSS concentration was 4 mg/1 prior to the
addition of chemicals, and (d) the elimination of data based simply on
a visual determination of proper flocculation characteristics.

Laboratory  data  on  alum  dosage  rates  for   chemically   assisted
clarification  were  submitted  to  the  Agency  in  comments  on  the
contractor's  draft  report.(141)  Data  submitted  for  bleached  and
unbleached  kraft  wastewaters  indicate  that significant removals of
suspended solids occur at alum dosages in the  range  of  TOO  to  350
mg/1,(142}(143)(144)  For wastewaters discharged in the manufacture of
dissolving sulfite pulp, effluent BODS^ and TSS data were submitted for
dosage rates of 250 mg/1; however, it was stated that dosages required
to achieve effluent TSS concentrations on the order of  15 mg/1  would
be  in  the  range  of 250 to 500 mg/1.(145) Subsequent to the comment
period, the NCASI assembled jar test data for  several  process  types
and  submitted  the data to the Agency.(146) Data for chemical pulping
subcategories indicate that alum  dosages  in  the  range  of  100  to
700 mg/1  will effect significant removals of TSS.   The average dosage
rate  for  all  chemical  pulping  wastewaters  was  282 mg/1.    Data
submitted  for  the  groundwood,  deink, and nonintegrated-fine papers
subcategories indicate that dosages in the range of 100  to  200  mg/1
will significantly reduce effluent TSS.

     To x i c   and   Nonconventional   Pollutants   -   As  part  of  an
EPA-sponsored study, biologically-treated effluent from a  kraft  mill
was   further   treated  using  alum  precipitation  technology  on  a
laboratory-scale.(90)   Existing  full-scale  treatment  at  the  mill
consisted  of a primary clarifier, an aerated stabilization basin, and
a polishing pond.  Twenty-four hour composite samples of the polishing
pond effluent were taken on three separate  days.   The  samples  were
adjusted  to a pH of 4.6 with alum; four drops of polymer per liter of
sample were added.  The results are summarized below:

                                 Polishing Pond          Alum-Treated
                                    Effluent               Effluent
                                   Range  (mg/l)   	Range (mg/1)

Total Resin and Fatty Acids        2.82  - 3.75        Undetected
Total Chlorinated Derivatives      0.43  - 0.45        Undetected - 0.04
Chloroform                         0.025 - 0.032       0.018 - 0.022
BOD5_                               43.0  -51.0        0-14.0

Other  researchers  have  investigated  modifications  of   chemically
assisted  clarification  technology  using  lime.   This  research has
concentrated primarily on color removal.  Investigations have included
the use of alternative coagulants in combination  with  lime.   Olthof
and  Eckenfelder reported on the use of ferric sulfate, lime, and alum
                                   356

-------
to  reduce  effluent  color  at  two  bleached  kraft  mills  and  one
unbleached  kraft  paperboard mill.(147)(148)   Their results, as shown
in Table VII-13, provide both an optimum pH  and  optimum  dosage  for
each  case.   All three coagulants were able to achieve a reduction in
color from 1,000 to 3,000 platinum-cobalt (Pt-Co) units to 125 to  300
Pt-Co  units.   Note  that  the dosage required for color reduction is
higher than that generally applied for BOD5_ and TSS reduction only.

Olthof and Eckenfelder concluded that ferric sulfate  used  for  color
removal  of  pulp,  paper,  and  paperboard mill wastewaters can be an
attractive alternative to lime treatment.   This conclusion  was  drawn
from  the  fact that the required optimum dosage of ferric sulfate was
25 to 33 percent that of the optimum lime dosage.   In  addition,  the
effluent  quality  which results from use of ferric sulfate was better
than that resulting from lime.  Lime treatment results in  a  high  pH
and a great deal of calcium in solution.   Common practice is to use an
additional  treatment  step, recarbonation,  which reduces the pH prior
to biological treatment and allows for recovery of calcium  as  CaC03.
The  use of ferric sulfate and alum prior to biological treatment does
not require recarbonation and may not require  neutralization.   Berov
studied the need for neutralization of kraft mill effluents which were
treated  with  alum  for  color removal.(149)  He concluded that if the
chemically treated  process  effluent  pH  did  not  fall  below  5.8,
neutralization was not needed prior to biological treatment.

Dugal,  et  al. performed laboratory studies on color reduction with a
combined ferric chloride and lime treatment  system.(150)  This  study
sought  to  establish  conditions  for  improving  the  lime treatment
systems  by  using  multivalent  ions  with   the   lime   for   color
precipitation.   Earlier  investigations  of  the  lime  precipitation
treatment system removal demonstrated 85  to  90  percent  removal  of
color;  it  was  determined  that  the  remaining  color bodies had an
apparent average molecular  weight  of  less  than  400.   Preliminary
studies  with  multivalent  ions  and  lime  showed almost total color
removal.

Tests were run in the laboratory on the decker  filtrate  and  caustic
extraction  discharge  from  International  Paper  Company's  mill  at
Springhill, Louisiana.  Various salts such as barium chloride,  ferric
chloride,  magnesium  hydroxide,  and  zinc  chloride were used in the
initial experiments.  Based on data from  these  initial  experiments,
ferric chloride was selected for further analysis.  In general, it was
determined  that  trivalent  ions  are  more  effective color-removing
agents than divalent ions.  Table VII-14 presents  a  summary  of  the
results.(150)

Twenty-four  experiments were run using ferric chloride and/or lime at
various concentrations.  Color removal up to 98.7 percent was attained
and it was concluded that a synergistic effect between lime and ferric
chloride  existed.   Table  VII-15  shows  the  results  of  these  24
experiments.(150)
                                  357

-------
                                                                      TABLE V7I-13

                                     COLOR REDUCTIONS ACHIEVED AFTER APPLICATION OF CHEMICALLY ASSISTED CLARIFICATION
                                                           WITH FERRIC SULFATE, ALUM, AND LIME1


OJ
oo


Ferric Sulfate Alum
Optimum Color Final Optimum Color
U^sage Reduction Color Value Optimum Dosage Reduction
Mill Type- (mg/J) (%) (Pt-Co. Units2) pH (mg/1) (%)
Bleach.-.) !iOO 92 250 3.5-4.5 400 92
KruM
Hlifache.l 275 91 125 3.5-4.5 250 93
Kratt
Unhl^a.liL-.! 250 95 150 4.5-5.5 250 91
Krj£t I'dpi- (-board
Line
Final Optimum Color Final
Color Value Optimum Dosage Reduction Color Value Optimum
(Pt-Co. Units2) pH (mg/1) (%) (PL-Co. Units2) pH
200 4-5 1,500 92 300 12. -12. 5
100 4-5 1,000 85 200 12. -12. 5

100 5-6 1,000 85 150 12. -12. 5
'Sources;  Olthof, M.G., "Color Removal From Textile and Pulp and Paper Wastewaters by Coagulation," Vanderbilt University, PhD Thesis, 1974.(147)
          Olthof, M.G.  and Eckenfelder, W.W.,  Jr.,  "Laboratory Study of Color Removal from Pulp and Paper Wascwaters by Coagulation," TAPPI,
          Vol.  S7, No.  8, August 1974.(148)

"I'l
-------
                                                      TABLE  VII-14

                      COMPARISON OF TREATMENT EFFICIENCIES ON KRAFT EFFLUENTS BY THE APPLICATION OF
                        CHEMICALLY ASSISTED CLARIFICATION USING DIVALENT  IONS OR TRIVALENT IONS1
Decker Filtrate
Salt
Concentration
(rag/1)
Mg(C








ZnCl








Bad










"°2
0
100
200
250
300
350
400
600
2
0
100
200
250
300
350
400
600
2
0
100
200
250
300
350
400
600
800
1000
Final
pH

7.2
7.4
7.5
7.8
8.0
8.0
8.1
8.0

7.2
6.9
6.5
6.5
6.4
6.3
6.2
6.0

7.2
7.3
7.2
7.1
7.0
6.9
6.7
6.4
6.2
5.7
Color
Removal

—
0
2.5
5.0
2.5
2.5
7.5
7.5

--
2.5
5.0
7.5
12.5
17.5(a)
22.5
45.4

..
5.0
16.7
21.7
23.3
26.7
28.3
41.2
42.5
61.2
Caustic Extract
Final
pH

8.2
8.4
8.7
8.9
9.0
9.0
9.1
9.2

8.1
6.9
6.7
6.7
6.7
6.7
6.7
6.7

7.1
6.9
6.5
6.5
6.6
6.8
6.9
7.0
7.1
7.1
Color
Removal
(t)

Decker
Salt
Concentration Final
(mg/1) pH
Alum (A12
Filtrate
Color
Removal
(X)
Caustic
Final
pH
Extract
Color
Removal
(SO,), 18H-0)
4 J 1
0 7.
0
6.8
11.4
11.4
11.4
12.0
22.8

—
0
3.9
3.9
13.6
13.4
22.9
44.0

..
0
0
0
1.3
4.1
1.1
23.7
35.9
45.2
100
200
250
7.
5.
4.
300 4.
350
400
600
FeCl3-pH
0
100
200
250
300
350
400
600
FeCl3-pH
0
100
200
250
300
350
400
600


4.
4.
4.
unadjusted
7.
5.
5.
4.
3.
3.
3.
3.
adjusted
7.
8.
8.
8.
8.
8.
8.
8.


2
3
1
7
6
5
5
5

2
8
0
I
8
7
4
1

2
2
7
3
5
9
9
a


-.
59.1
87.1
90.9
88.1
88.2
88.2
86.8

--
27.3
75.5
76.4
77.3
77.3
75.5
76.4

..
0
21.1
12.6
38.9
58.3
50.9
72.5


7.9
6.5
4.8
4.4
4.3
4.2
4.3
4.1

6.7
6.1
5.6
5.1
4.8
4.4
4.1
3.S

6.7
8.4
8.9
8.7
9.1
8.6
8.1
7.8


—
7.7
63.1
85.2
84.6
85.2
84.6
86.5

--
0
24.4
26.9
51.3
74. S
91.7
90.7

..
0.6
67.4
83.1
97.2
97.3
97.3
97.4


Ca(OH)2








(a)
0
100
200
250
300
350
400
600
Calculated
..
—
—
—
—
—
• •
—
Value.
—
—
—
—
—
—
—
—

8.6
10.3
11.3
11.6
11.7
11.8
11.9
12.1

—
20.0
22.5
22.5
25.0
32.5
62.5
72.5























































'Source:  Dugal, H.S.,  Church, J.O., Leekley, R.M., and Svanaon, J.W., "Color Removal in a Ferric Chloride-Lin
         Vol.  59,  No.  9,  September  1976.(150)
System," TAPPI ,
                                                         359

-------
                                    TABLE  VII-15

                 LIME  TREATMENT  OF  BLEACHED  KRAFT CAUSTIC EXTRACT  IN
                             THE PRESENCE  OF METAL  ION Ha)
Fed
(mg/I)
0
25
50
100
200
300
500
800
0
25
50
100
200
300
500
800
0
25
50
100
200
300
500
800
Lime
(mg/1)
1000
1000
1000
1000
1000
1000
1000
1000
2000
2000
2000
2000*
2000
2000
2000
2000
18,000
18,000
18,000
18,000
18,000
18,000
18,000
18,000
Sludge
Volume(b)
(ml)
6.2
8.2
8.2
8.5
13.3
14.4
22.0
30.1
6.2
7.0
7.3
9.7
14.1
19.1
33.5
62.0
8.9
8.7
9.0
9.4
11.2
12.2
14.3
16.8
Final
PH
11.58
11.50
11.42
11.42
11.49
11.50
11.40
11.32
11.79
11.70
11.70
11.70
11.70
11.71
11.78
11.73
11.98
11.99
11.98
12.00
12.01
12.01
12.01
12.00
Color
Removal
(%)
81.4
81.7
85.7
90.0
91.4
91.6
95.8
95.5
87.2
88.0
89.5
91.8
93.6
95.2
96.8
97.5
93.4
94.9
95.0
95.9
96.3
97.3
98.2
98.7
TOC
Removal
(%)
66.6
66.0
71.0
78.0
76.4
74.3
81.0
83.2
68.6
75.4
73.0
75.2
79.6
81.6
86.0
87.3
80.4
79.5
77.6
81.7
84.0
81.5
87.7
88.7
BOD
Removal
(%)
6.5
4.3
0.0
12.8
23.5
27.7
36.2
40.5
23.5
23.5
25.5
29.8
34.0
36.2
44.7
51.0
32.0
32.0
38.4
36.2
36.2
46.8
46.8
51.0
(a)Untreated  caustic  extract  had  a  pH  of  8.83,  a  color  of  4400  units,  a  TOC  of  220
   mg/liter,  and a  BOD  of 47  rag/liter.

(b)Total  volume of  kraft  bleach caustic extract after lime and  FeCl   addition was
   100 ml.  Sludge  volumes were measured  after  a  15-minute settling  time.


'Source:  Dugal, H.S., Church,  J.O.,  Leekley,  R.M.  and Swanson,  J.W.,  "Color
         Removal in a Ferric  Chloride-Lime  System,"  TAPPI, Vol.  59,  No.  9,
         September  1976.(150)
                                      360

-------
Another  flocculation  and  precipitation  process  is  in  full-scale
operation in Japan; it has also been investigated  through  laboratory
studies  in Sweden.  The process involves using iron salts and lime to
obtain  color  removals  in  the  range  of  85  to  95  percent.(151)
Chlorination  and  caustic  extraction  stage  effluents  are treated.
Metallic iron is first dissolved in the chlorination  stage  effluent.
Retention  times  of 1.5 to 2 hours and temperatures near 50°C (122°F)
are needed to dissolve a sufficient amount of the metallic iron.   The
resulting  solution is then combined with the caustic extract, and the
pH is adjusted within the range of 9 to 10  with  lime.   No  chemical
dosages  were  listed  for the lime required or the amount of metallic
iron consumed.

Vincent studied the decolorization of  biologically-treated  pulp  and
paper  mill  effluents  through  the  addition  of  lime  and  lime
magnesia.(152) Laboratory-scale studies were  conducted  on  effluents
from  three  kraft  mills,  one  sulfite mill, and one NSSC mill.   All
except one  of  the  kraft  mill  effluents  had  been  treated  in  a
biological  system  before  chemical treatment.  Separate testing with
lime and magnesia showed that, with  the  addition  of  1,000 mg/1  of
lime,  approximately  90  percent  of the color was removed.  Magnesia
alone proved to be ineffective  at  moderate  doses;  4,000 mg/1  were
required   to   obtain   approximately  50  percent  color  reduction.
Therefore, it was concluded that the use of magnesia alone  could  not
be justified.

The  use  of  magnesium  hydroxide in combination with lime was highly
effective.  The magnesium was added as a soluble  salt  prior  to  the
lime  slurry.   A  dosage  of  50 to 100 mg/1 of magnesia prior to the
addition of 500 mg/1 of lime  gave  the  same  color  removal  as  the
addition of 1,000 mg/1 of lime alone.  Additionally, sludge production
was  less  with  the lime - magnesia process.  Table VII-16 shows some
typical results of the lime - magnesia  process  for  removing  color,
BOD,   COD, and phosphate for the five mills.  Recovery techniques were
suggested, but none were investigated in connection with  this  study.
This  would   indicate that additional testing would have to be done to
prove the feasibility of this lime - magnesia recovery process  before
attempting  it  on  a  larger scale.  An evaluation concluded that the
system is costly, but the benefits might favor its use.

Filtration

This process refers to granular bed (rather than membrane) filtration.
The granular material may be sand, or coal, diatomaceous earth, and/or
garnet in combination with sand.  The various media, grain sizes,   and
bed  depths  may  be varied for optimal results.  It is common to vary
grain sizes,  with the larger sizes at the top of the  filter  bed,  to
improve   TSS   removal   and   to  extend  filter  run  time  between
backwashings.  The addition of a proper chemical flocculant  prior  to
filtration can further improve performance.

Filtration  technology  was evaluated as part of a study conducted for
the EPA.(129)  Results obtained during this study of nine pulp, paper,
                                361

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                                                               TABLE VII-16




                   REMOVAL OF BOD, COD, AND PHOSPHATE FROM CHEMICAL PULPING WASTEWATERS AT SELECTED LINE - MAGNESIA LEVELS1
Treatment



OJ
cn
rv>


Mill
A
11
C
D
E
(c-)BOD
(b)COD
Effluent (
Kraft (combined effluent,
80% bleached) biological
treatment
Kraft (high BOO stream,
unbleached) no biological
treatment
Kraft (combined effluent)
biological treatment
Sulfite (NH base, com 2
bined effluent) biological
treatment
NSSC (combined effluent) 6
biological treatment
determined after filtration
determined after filtration
CaO
»ji/l)
500
500
500
,000
,000
through
through
(a)Phosphate analysis (values in mg/1 of P)
MgO
(«*/!)
100
100
100
400
3,000
Before Treatment
Color
2
1
2
1
36
Reeve-Angel
Reeve-Angel
deter
•ined
,570
,070
,620
,790
,300
glass
glass
BOD(a) COD(b)
-
130
60
60
525
filter
filter
by modified
420
(560)
340
(560)
500
(720)
2,430
(1,300)
8,640
(4,960)
papers and
After Treatment Removal
Phosphute(c) Color BOD COD Phosphate Color BOD COD
1.05 137 16 100 F0.01 94.7 - 76
0.7 78 105 580 0.07 92.7 19
1,310
3.0 185 30 100 0.06 92.9 50 80
0.8 298 67 460 0.07 83.4 - 81
31.5 12,800 320 1,040 0.80 64.7 39 88
subsequent adjustment to pH 7°

Phosphat
99.0
90.0
98.0
91.3
97.5

papers. Bracketed values are for unfiltered effluents'
ascorbic acid method"
'Source: Vincent, D.L., Colour Removal Froo Biologically Treated Pulp and Paper
Mill Effluents, Distributed by CPAR Secretariat,

Canadian Forestry Service, Department of the Environment  Ottawa,  Ontario,  as  CPAR Report  210-1,  March 31,  1974.(152)

-------
and paperboard and other industrial facilities  where  filtration  was
used  are  shown  in Tables VII-17 and VII-18.  Also summarized in the
tables are the results  of  pertinent  published  results  from  other
filtration  studies.   Table  VII-17  summarizes  those  systems where
coagulants were not used  prior  to  filtration,  while  Table  VII-18
addresses those where coagulants were employed.

At those facilities where chemical coagulants were not utilized, final
effluent  levels  of  TSS  ranging  from  5.9 to 35 mg/1 were achieved
across" the filter; TSS reductions ranged from 45 to 79 percent.  Those
where coagulants were used prior to filtration achieved final effluent
TSS levels ranging from 5.0 to 27.5 mg/1 with removals  of  52  to  85
percent.    At  the  paperboard  mill  employing  single  medium  sand
filtration without chemical addition, an effluent TSS level of 7  mg/1
was attained.

Tables  VII-19,  VII-20,  and VII-21 summarize available effluent data
for  three  midwestern  mills  where  paperboard  is   produced   from
wastepaper.   At  these  mills,  biologically-treated effluent is sand
filtered  without  the  use  of  coagulants.   Table  VII-19  presents
effluent  data  after  treatment  in  an  aerated  stabilization basin
followed by a three-layer,  pressure  sand  filter.   The  system  was
designed  to  remove  50  percent  of  the  biological  solids but, in
practice, removes only  30  to  40  percent.   Table  VII-20  presents
effluent  data  after  treatment  in  an  aerated  stabilization basin
followed by secondary clarification  and  deep  bed  sand  filtration.
Table  VII-21  presents  effluent data after treatment in an activated
sludge system followed by a gravity rapid sand filtration system.

An EPA-sponsored laboratory study evaluated  the  efficiency  of  sand
filtration of four pulp and paper mill effluents.(140)  A flow rate of
0.20  cu  m  per  minute/sq m  (5 gpm/ft2_) was used and the results are
shown in Table VI1-22.  As  seen,  in  one  of  the  two  cases  where
coagulation was not employed prior to filtration, substantially better
results  were  obtained  than  when  coagulants  were  added.   It was
explained by the authors  that  natural  coagulation,  that  may  have
occurred during shipment of samples, could have affected the results.

Activated Carbon Adsorption

Currently,  there  are  two  basic approaches for the use of activated
carbon:   a)  use  in  a  tertiary  sequence  following  primary   and
biological  processes and b) use in a "physical-chemical" treatment in
which raw wastewater is treated in a primary clarifier with or without
chemical coagulants prior to carbon adsorption.

The tertiary approach involves the reduction of biodegradable organics
prior to discharge to the carbon system.   This  provides  for  longer
carbon life.  In a physical-chemical treatment mode, biodegradable and
refractory  organics  are  removed  solely  through  adsorption on the
activated carbon.  Activated  carbon  can  achieve  high  removals  of
dissolved  and  colloidal  pollutants  in  water and wastewater.  When
                                 363

-------
                          TABLE VII-17
TSS REDUCTION  CAPABILITIES AND  RELATED  FACTORS
           FOR  THE FILTRATION TECHNOLOGY
            WHEN NO CHEMICALS  ARE USED







A ,

*


c a., -.,-, i,,,..
>: . f i '•">! .t»Jr
.' |n(..n i...f,.
r iM.,-11.,1 fu.
• lut..i.. I*
ir.lct Foud.
•ro«ht»n. HI
i.™"i""»K>
dw.(jvlty LOUOLII
pilot n..,t







Oi i r>[ i..«rv

F «pf iboi: J j.r . ).,i »,

<:••»(•(
tuHll. •••1»
tc.l puU k (•>>• ic
food pri>c««*lii*

pulp Bill



BLSS - 1200 .«/!
Detention (1M - K>
AorftdC* Ho- - 4 I' ffci-
DO «ln - 1 0 •«'!

1000 cu l(. F/H - HD
KLSS - wr, un •!» -
[Wt*ntlo« tl«H - :; hr. f
A.rrtg* (low - 1 IV r«T.
Ac(l«*t*J Xidlgc: <««^lrt«
• U, P'H - 01 IL WX>/Ib
tUUSi. W.SS - l.WKJ ^/l
DO «ln *
1^ (*-b. «*.hirU»\ Mim>,r,
*vBr«gt fl™ - It 11 rtL.
k.rtv.tid »lud,* co^>trt*
• l«. 70. S It. K*>/]MX) fu (t
F/H - .•>, KU>S - ).ViO •«/]
DO *1n -
D*(*om.p UH - H htf f
i H.;O
A.*l.|* (low - J-G W.O
1UOC cu li. F/N *
M.SS -
DO •)• -
tet«BllOfl IIM ' *« hi. fr
0.1 M«
A**r«i* llo« - I-» N.O

Activated «l»d|* co^.l«l. Mil
F/H -
W3i -
DO •!« -
D*t«D(lori !!•• -
Jtv*tag* t)o« -

A«r«t*d )«•!»• - Ib MD/IOOO
<« fl - DO aJ» -
Totil Mr>tl»« u«Iy • <•>•
«..,^. Mo- -
Lrtt.r.tlo.. i

u| (1*1 1, <*•(• for




MI

«B

of 3 »othlr •Mr..*-
DOC! OOt iMlurf* Old
•*•>»•• lor )
08 ««/l

1% ••/!
«> •*/! tr«k M^IM

TSS Sit* -

•2.5 17.0


-1.^ - 76.)
•S.O - 8V.2

•I JS - ^10
 • MH
b«tH*D 1 fc ]0v



fllori -

11 ICD i
llll*r* -
I.* •>«/••< (l

•t 19.11 *;o t 9
(iliar. -
1 1 IP«/m It

•t J .0 HLD k 1

• ( 1.1) HCO 4 )
(llt*r. -
J.I1. f(*/.q (1
2 (fw/iq ft


l.k io 1.4 (»•;•«
(t

FlH.t MrdU: »u. "f
M4la. fVptt., U.S. . I.S. .

iu.1 !•*, O.t to 08 «
In d*ptb IlltiitlcM.

<•«•! - 24"; W: - MD
15 - Hli ••rrf - IT
UC - MO. KS - HD

1 ftcJU. i Hi. «
. »ad - 11" UC - U. rS • ND 1 »*J1»' »•«! «. Co* - 1*" Sp.C* .-!.& oc rs - HD tend - 9". UC i U - M> . C-rn.i • r. UC * U - U MD 1 »4t« - T at co*rM fMl, )- MdlM MM - i" ol CMlM UAd - •^ - !.«!, OC - 1.14 1) •*/!, •*•!**• of 12 •ot.thly 1.0 «t/l. .*„.»• Ol •> •unthly lv«I- Of 1 Bcnthlj »v*r- •t«» )fi«/» 1.4 »4/l M»oti •M*T»a» 11 ^/l *cr!.«nnl^""l.m Ml HI MO •cntion V>I •rportrd by »««-*r<-b^r* 771. Kuv. M. 197* tu F«b, U, H7i 701. au^an iv*r- **• VJ1

-------
                                                                                                                     TABLE  VII-18

                                                                                 TSS  REDUCTION  CAPABILITIES   AND  RELATED  FACTORS
                                                                                                FOR  THE  FILTRATION   TECHNOLOGY
                                                                                                      WHEN  CHEMICALS  ARE  USED

                                                                 11 U Wot/1000 [
OJ
o-)
CJ1
b.i*eilo« UM - I JO hi.
* 1.0 MLO
•„,»». (l» • 10 *U>
                                                                 *..r»,r fla. - 0. i M
                                                                                                               ISS flu - p.ic
                                                                                                                l.Ihi - «b.

                                                                                                                l.Ou - tvl
                                                                                                                J Vj • •).*

                                                                                                                                                       OC t IS -  HP.

                                                                                                                                                       w: « fc. -  i.o
                                                                                                                                                       li  1.1  - 10 tm
                                                                                                             10.1 •*/!
                                                                                                             t**I.|« ol  I
                                                                                                             •MiUr •<••!

-------
                            TABLE VII-19

                  FINAL EFFLUENT QUALITY FOLLOWING
THREE LAYER PRESSURE SAND FILTRATION OF THE EFFLUENT FROM AN AERATED
 STABILIZATION BASIN TREATING PAPERBOARD FROM WASTEPAPER WASTEWATER
                          BOD5 (mg/1)
TSS (mg/1)
Date
September 1978
October 1978
November 1978
December 1978
January 1979
February 1979
March 1979
April 1979
May 1979
June 1979
July 1979
August 1979
September 1979
r%_i_.* ... i r* ~ r*
Wt.btSL«C.A. A > * >
November 1979
December 1979
January 1980
February 1980
March 1980
April 1980
May 1980
June 1980
July 1980
August 1980
September 1980
October 1980
November 1980
December 1980
January 1981
February 1981
March 1981
Average
for Month
11
9
9
11
14
16
14
10
10
12
14
17
19
io
—
14
17
19
18
17
13
13
12
16
12
12
5
14
11
—
7
Maximum
Day
17
15
14
14
19
19
19
17
17
16
19
40
28
4..J
	
24
25
35
35
25
33
18
23
30
30
39
10
34
35
—
35
Average
for Month
12
12
8
7
11
13
12
14
11
11
14
17
21
4.U
21
22
23
18
20
18
12
17
19
23
12
17
7
16
12
--
11
Maximum
Day
20
16
12
16
18
20
24
20
20
16
20
30
24
•+U
22
32
34
49
36
46
40
44
44
46
40
50
24
50
48
--
40
                                366

-------
                            TABLE VII-20

  FINAL EFFLUENT QUALITY FOLLOWING DEEP BED SAND FILTRATION OF THE
EFFLUENT FROM AN AERATED STABILIZATION BASIN AND SECONDARY CLARIFIED
           TREATING PAPERBOARD FROM WASTEPAPER WASTEWATER
                          BODS (mg/1)
TSS (mg/1)
Date
December 1978
January 1979
February 1979
March 1979
April 1979
May 1979
June 1979
July 1979
August 1979
September 1979
October 1979
November 1979
December 1979
January 1^80
February 1980
March 1980
April 1980
May 1980
June 1980
July 1980
August 1980
September 1980
October 1980
November 1980
December 1980
January 1981
February 1981
March 1981
April 1981
Average
for Month
38
44
41
44
54
32
20
29
30
31
35
29
39
38
27
30
34
24
30
—
32
33
44
52
36
45
41
104
39
Maximum
Day
42
62
46
52
70
62
36
32
40
60
44
50
56
70
40
50
75
36
59
—
46
51
68
62
53
78
61
310
54
Average
for Month
49
54
44
55
51
53
27
37
30
33
40
46
59
45
44
48
52
31
28
--
22
38
48
66
64
56
67
55
57
Maximum
Day
60
100
65
66
89
88
42
44
37
46
54
60
75
70
65
70
85
44
61
--
33
50
70
78
92
75
95
80
99
                               367

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                            TABLE VII-21

FINAL EFFLUENT QUALITY FOLLOWING RAPID GRAVITY SAND FILTRATION OF THE
          EFFLUENT FROM AN ACTIVATED SLUDGE PLANT TREATING
                PAPERBOARD FROM WASTEPAPER WASTEVATER
                          BOD5 (mg/1)
TSS (mg/1)
Date
February 1979
March 1979
April 1979
May 1979
June 1979
July 1979
August 1979
Septeaber 1979
October 1979
November 1979
December 1979
January 1980
February 1980
March 1980
April 1980
May 1980
June 1980
July 1980
August 1980
September 1980
October 1980
November 1980
December 1980
January 1981
February 1981
March 1981
Average
for Month
13
8
12
6
6
18
13
8
36
29
12
5
6
6
7
6
8
2
3
6
4
6
5
7
11
10
Maximum
Day
34
15
22
8
9
31
34
20
110
86
17
12
11
22
20
20
16
3
10
16
8
9
21
16
49
37
Average
for Month
47
29
20
19
12
21
9
12
39
54
29
11
9
8
8
9
14
7
9
8
11
18
10
14
31
19
Maximum
Day
205
76
58
88
52
84
52
36
75
134
80
24
21
40
33
21
50
18
19
33
26
19
37
38
120
82
                                368

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                              TABLE VII-22

                        SAND FILTRATION RESULTS1
                                                TSS Removal (%)
Mill No.
1
2
3
5
Initial TSS (mg/1)
110
5.5
70
60
w/ chemicals
64

71

w/o chemicals
14
36
68
23
1Peterson,  R.R.  and Graham,  J.L.,  "Post Biological Solids Characteriza-
 tion and Removal from Pulp  Mill  Effluents," EPA-600/2-79-037, January
 1979.(140)
                                       369

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applied to a  well-treated  biological  effluent,   it  is  capable  of
reducing BOD5_ to less than 2.0 mg/l.(153)

The  primary  means  of removal is surface adsorption.  The key to the
carbon adsorption process is the extremely large surface area  of  the
carbon, typically 3.54 to 9.92 square meters per gram (sq m/g) (17,300
to 48,540 sq ft/lb).(154)

Activated  carbon will not remove certain  low molecular weight organic
substances,  particularly methanol, a  common  constituent  of  pulping
effluents.(155)  Additionally, carbon columns do a relatively poor job
of removing turbidity and associated organic matter.(156)  Some highly
polar organic molecules such as carbohydrates also will not be removed
through  the  application  of  activated  carbon  treatment.(156)(157)
However,  most  of  these  materials are biodegradable and, therefore,
should not be present in appreciable quantities in a well bio-oxidized
effluent.

Activated carbon may be  employed  in  several  forms  including:   a)
granular,   b)   powdered,  and  c)  fine.   The  ultimate  adsorption
capacities for each may be similar.(158)  The optimal carbon form  for
a  given  application  should be determined by laboratory and/or pilot
testing.  Each of the three forms of carbon listed above is  discussed
below.

Granular  Activated  Carbon.   Granular activated carbon has been used
for many years at municipalities and industrial facilities  to  purify
potable and process water.  In recent years, it has also been used for
removal of organics in wastewater.(159)

Granular  activated  carbon (GAC) treatment usually consists of one or
more trains of carbon columns or beds, including one or  more  columns
per train.  The flow scheme may be down through a column, up through a
packed  carbon bed, or up through an expanded carbon bed.  The optimum
column configuration, flow scheme, and carbon requirements can best be
determined through field testing.  Design aspects for various  systems
are readily available in the literature.{154)

It  can be economically advantageous in many granular activated carbon
applications to regenerate the exhausted  carbon.   Controlled  heating
in  a  multiple-hearth  furnace   is  currently  the best procedure for
removing adsorbed organics  from  activated  carbon.   Typically,  the
regeneration sequence is as follows:

o    Pump exhausted carbon in  a  water   slurry  to  the  regeneration
     system for dewatering.

o    After dewatering, feed the carbon to a furnace at 816°  to   927°C
      (1,500°  to   1,700°F)  where  the  adsorbed  organics  and   other
      impurities are oxidized and  volatized.

o    Quench the regenerated carbon in water.
                                  370

-------
o    Wash the carbon to  remove  fines;  hydraulically  transport  the
     regenerated carbon to storage.

o    Scrub the furnace off-gases and return  the  scrubber  water  for
     treatment.

The West Wastewater Treatment Plant at Fitchburg, Massachusetts treats
combined  papermill  and sanitary wastes at a 57,000 cu m/day (15 mgd)
chemical coagulation/carbon adsorption facility.(160) Approximately 90
percent of  the  flow  originates  from  three  papermills,  with  the
remaining  10  percent originating from municipal sanitary wastewater.
The industrial wastewater undergoes 5 minutes of rapid mixing  and  30
minutes  of flocculation prior to mixing with the chlorinated sanitary
wastewater.  The combined waste is then settled after  lime  and  alum
addition.   The  wastewater is then pumped to twelve downflow pressure
carbon filters.  Initial operation of the system has resulted in a  96
percent  suspended solids reduction and a 39 percent BOD5_ reduction in
the  pretreatment  system.   The  granular  activated  carbon  filters
initially  yielded total reductions of suspended solids and BOD5_ of 99
and 97 percent,  respectively.   Final  effluent  concentrations  were
reported  as  5.0  mg/1  BOD5_  and  7.0  mg/1  TSS.  No data have been
reported concerning toxicity"~or  toxic  pollutant  removal/  reduction
from the plant.

Since  the plant was started up in late 1975, it has been plagued with
a number of mechanical and operational problems.    As  a  result,  the
system  has  been unable to achieve the removal capabilities predicted
after initial  operation.   The  plant  was  designed  to  produce  an
effluent  quality of 8 mg/1 of BOD5_ and TSS on a monthly average.  The
pretreatment facility has  consistently  yielded  a  55  percent  BOD5_
reduction  and  95  percent  TSS  reduction.   The carbon filters have
provided 55 percent BOD5_ reduction and 70 percent TSS reduction of the
remaining pollutants after  pretreatment.   Overall,  the  system  was
anticipated  to  achieve  80 percent BOD5_ reduction and 98 percent TSS
reduction once the steady state conditions were met.(161)

Pilot testing by Beak  Consultants,  Ltd.,  with  laboratory  analysis
confirmed by B.C. Research, indicates that approximately 80 percent of
each  of  the  following  resin  and fatty acids were removed from raw
bleached kraft effluents by application of granular carbon adsorption:
pimaric, isopimaric, abietic,  dehydroabietic,  oleic,  linoleic,  and
linolenic.(162) Initial total resin acid and fatty acid concentrations
were  10.6 and 3.9 mg/1 as reported by Beak Consultants, Ltd. and 12.6
and 2.2 mg/1 as reported by B.C. Research.  Total resin acid and total
fatty acid concentrations  in  the  treated  effluent  were  1.49  and
2.4 mg/1  as reported by Beak Consultants, Ltd.  and 2.25 and 0.4 mg/1
as reported by B.C. Research.  A contact time of 7.5  minutes  with  a
carbon  exhaustion  rate of 0.6 to 0.7 kg per 1,000 liters (5.0 to 6.0
Ib per 1,000 gallons) was employed in the  study.   Detoxification  of
the  raw  woodroom  wastewater  was  successful.   However, the authors
report that the carbon system did not  detoxify  whole  mill  effluent
during  a simulated black liquor spill, even with a contact time of 30
minutes.
                                 371

-------
It is noteworthy that the carbon exhaustion rate for BOD5_ removal  was
20  times shorter than that for toxicity removal.   These results imply
that (a) carbon life  may  be  significantly  increased  if  competing
organics  are  removed  prior  to  carbon  adsorption  and  (b) carbon
adsorption capacity for resin and fatty acids is greater than that for
other biodegradable organics.

Several researchers have considered the reuse of wastewaters following
carbon adsorption treatment.   Kimura showed that the use of  activated
carbon  following biological  treatment and sand filtration was capable
of completely  detoxifying  kraft  board  mill  wastewater.   In  this
application,  the final effluent was recycled as process water.(163)

According  to Smith and Berger, pulp and papermill wastewater suitable
for reuse can be obtained using granular carbon without  a  biological
oxidation  step, particularly if the raw wastewater exhibits a BOD5_ of
200 to 300  mg/1.(164)  Color  due  to  refractory  organic  compounds
contained  in pulping effluents can also be reduced by such treatment.
Table VII-23  presents the pilot plant results obtained by the authors.

Condensate streams account for only about 2 to  10  percent  of  total
wastewater  flow,  but  contribute significantly higher proportions of
toxicity and  BOD5_ when discharged.  Tests by Hansen and Burgess showed
that 70 to 75 percent of the BOD5, COD, and TOC  in  kraft  evaporator
condensate  could  be removed using 0.46 kg of carbon per 1,000 liters
(3.8 Ib of carbon per 1,000 gallons)  of  wastewater.(157)   Treatment
with  granular  activated carbon reduced the effluent toxicity effects
on bay mussels by  a  factor  of  up  to  17.   The  toxicity  removal
efficiency  was  found  to be much more dependent on contact time than
were BOD5_ and COD removals.  For example, a contact time of 30 minutes
and a carbon  dosage of 40.1 g/1  (0.334  Ib/gal)  resulted  in  an  80
percent COD reduction to 186 mg/1 and an 85 percent larval survival in
a  10  percent condensate solution.  However, an extended contact time
of 19 hours under otherwise similar conditions resulted in an increase
to only 82 percent COD reduction, or 163 mg/1, while  larval  survival
in 10 percent solution increased to essentially 100 percent.

Weber  and  Morris  found  that  the  adsorption  capacity of granular
activated carbon increased with a decrease in pH.(165)  The effect  on
the  rate  of  adsorption  with  changes  in  temperature was not well
defined.

Powdered Activated Carbon.  A recent  variation  of  activated  carbon
technology  involves  the  addition  of  powdered  activated carbon to
biological treatment systems.  The adsorbant quality of carbon,  which
has  been  known  for  many  years,  aids  in  the  removal of organic
materials in the biological  treatment  process.(166)  This  treatment
technique   also   enhances   color   removal,  clarification,  system
stability, and BOD5_  and  COD  removal.(167)(168)    Results  of  pilot
testing  indicate  that this type of treatment, when used as a part of
the activated sludge process, is  a  viable  alternative  to  granular
carbon  systems.(169)(170)  Pilot  tests have also shown that powdered
                                 372

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                                     TABLE VII-23

                   RESULTS OF PILOT-SCALE GRANULAR ACTIVATED CARBON
                       TREATMENT OF UNBLEACHED KRAFT MILL WASTE1
Parameter
pH
Color (Pt-Co Units)
BODS (mg/1)
COD (mg/1)
Suspended Solids
(mg/1)
Total Solids (mg/1)
Note: Columns were
Desired Range
6.8-7.3
0-5
0-2
0-8
0-5

50-250
loaded at 3.6-4.0
Raw Waste
7.8
1,280
265
517
128

1,210
gpm/sq ft
After Lime
Treatment
11.9
28
82
320
115

1,285

After Carbon
Treatment
10.5
0
12
209
74

1,205

Remova 1
V •»
100
95.5
59.6
42.2

0.4

     ,  D.R. and Berger, H.F., "Wastewater Renovation," TAPPI, Vol. 51, No. 10,
October 1968.(164)
                                             373

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activated carbon can be used  successfully  with  rotating  biological
contactors.(171)

At  a  large  chemical manufacturing complex,  a full-scale, 151,000 cu
m/day (40 mgd),  powdered activated carbon system was started up during
the spring of 1977.(172)  This system  includes  carbon  regeneration.
The  waste sludge, which contains powdered carbon,  is removed from the
activated sludge system and is thickened in a  gravity thickener.   The
sludge  is  then dewatered in a filter press prior to being fed to the
regeneration furnace.  The regenerated carbon  is  washed  in  an  acid
solution to remove metals as well as other inorganic materials.  Fresh
carbon  is added as make-up to replace the carbon lost in the overflow
from the activated sludge process or from the  regeneration system.

The process was  originally  developed  because  biological  treatment
alone could not adequately remove the poorly biodegradable organics in
the  effluent.  Data were taken during operation of a laboratory-scale
powdered activated carbon unit using a carbon  dosage of 160 mg/1 and a
hydraulic retention of 6.1 hours.  Table VII-24 presents  the  results
of this investigation.(172)

It  is  noteworthy  that the estimated capital costs of using powdered
activated carbon rather than a conventional activated sludge system at
this chemical plant were within 10 percent of   each  other.  Operating
cost.of the powdered activated carbon system was estimated to be about
25 percent greater than for conventional activated sludge alone.(172)

The  powdered activated carbon system described above is a very comlex
treatment system that involves operations that may not be required  at
other  installations.   The  need  for  a  filter press system or acid
cleaning system as well as  a  carbon  regeneration  furnace  must  be
determined on a case-by-case basis.

In  a  follow-up  study  on  the  full-scale powdered activated carbon
activated sludge plant, the average results of three  months  of  data
are  reported  in Table VI1-25.  The carbon dosage was 182 mg/1, while
the hydraulic retention was 14.6 hours.(173)

Comparison of the laboratory and full-scale results in  Tables  VII-23
and VII-24 reflect an increase in BOD5_ and color removal for the full-
scale system over that of the laboratory-scale unit.

Fine  Activated  Carbon.   Timpe  and  Lang developed a fine activated
carbon system for which they filed a patent application.(158)  It is a
multi-stage,   countercurrent,  agitated  system  with   a   continuous
transfer  of  both carbon and liquid.  One of  the major aspects of the
fine activated carbon system is the use of an  intermediate-size carbon
in an attempt to combine the advantages of both powdered and  granular
carbon  while minimizing their limitations.  Equipment size and carbon
inventory are decreased due to the increased adsorption  rate  of  the
intermediate-size carbon.
                                  374

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                             TABLE VII-24

                       POWDERED ACTIVATED CARBON
            OPERATING DATA ON A CHEMICAL PLANT WASTEWATER1
Parameter
Soluble BOD5 (mg/1)
Color (APHA Units)
Raw Effluent
300
1,690
Final Effluent
23
310
Percent Removal
92.3
81.6
1Source:  Heath,  H.W.,  Jr.,  E.I.  duPont de Nemours and Company,  "Combined
         Powdered Activated Carbon-Biological (PACT)  Treatment  of 40
         MGD Industrial Waste,"  presented to Symposium on Industrial
         Waste Pollution Control,  American Chemical Society National
         Meeting, March 1977.(172)
                                      375

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                              TABLE VII-25

                    FULL SCALE "PACT" PROCESS RESULTS
                      ON CHEMICAL PLANT WASTEWATER1
Parameter             Raw Effluent    Final Effluent    Percent Reduction
Soluble BODS (rag/1)
Color (APHA Units)
504
1,416
15.2
311
95
78
1Robertaccio, F.L., "Combined Powdered Activated Carbon - Biological
 Treatment:  Theory and Results," Proceedings of the Open Forum on Manage-
 ment of Petroleum Refinery Wastewaters, June 1977.(173)
                                      376

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Timpe  and  Lang  report  that the fine activated carbon system showed
distinct advantages over the granular activated carbon  system.   They
ran  extensive  pilot  plant  tests for treating unbleached kraft mill
wastewater  with  granular  and  fine  activated   carbon.(158)   Four
different  treatment processes were investigated using a 110 liter per
minute (30 gpm) pilot plant: (a) clarification  followed  by  downflow
granular   activated   carbon   columns,   (b)   lime   treatment  and
clarification followed  by  granular  activated  carbon  columns,  (c)
biological  oxidation and clarification followed by granular activated
carbon columns, and (d) lime treatment and clarification  followed  by
fine   activated  carbon  effluent  treatment  (subject  of  a  patent
application.)

All treatment processes were  operated  in  an  attempt  to  obtain  a
treated effluent with less than 100 APHA color units and less than 100
mg/1  TOC  that  would  allow  for  reuse  of  the  wastewater  in the
manufacturing process.  The lime-carbon treatment achieved the desired
effluent criteria and was considered the most economical of the  three
processes utilizing carbon columns.  A relatively small lime dosage of
320  to 600 mg/1 CaO without carbonation prior to carbon treatment was
reported to be the optimum operating  condition  for  the  lime-carbon
process.    It was determined that the effluent should contain about 80
mg/1 Ca for successful optimization of treatment.  The required  fresh
carbon  dosage  was  0.3 kg of carbon per 1,000 liters treated (2.5 Ib
per 1,000 gallons treated).

Timpe and Lang reported lower rates of adsorption,  resulting in larger
projected capital and operating costs, for the  biological-carbon  and
primary   carbon   processes   in   treating   unbleached  kraft  mill
effluent.(158)  The lower rates of  adsorption  were  believed  to  be
caused by coagulation of colloidal color bodies on the carbon surface.
They  also  determined  that  the  use  of  sand  filters prior to the
activated carbon was not necessary.  The carbon columns operated  with
a  suspended  solids  concentration  of 200 mg/1 without problems when
backwashed every  day  or  two.   Filtration  or  coagulation  of  the
effluent from the fine activated carbon process was necessary in order
to  remove  the  color bodies that formed on the outer surfaces of the
activated carbon granules.

The authors  found  that  nonadsorptive  mechanisms  accounted  for  a
significant  amount  of  color  and  TOC removal in the clarification-
carbon process.  They felt that the  removals  were  not  due  to  any
biological degradation that might have occurred in the carbon columns.
The  color  colloids  were  subsequently  removed  as large settleable
solids during the backwashing process.(158)   Table  VII-26  tabulates
the pilot plant results obtained from Timpe and Lang's investigation.

Foam Separation

Foam  separation  techniques  have  been  evaluated to determine their
effectiveness in  treating  surface  active  substances  (i.e.,  resin
acids)  in pulp, paper, and paperboard mill wastewaters.  This process
involves physical removal of surface active  substances  through  foam
                               377

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CO
^J
CO
                                                                              TABLK VI[-26


                                                          RESULTS  OF  PILOT-SCALE ACTIVATED CARBON TREATMENT OF
                                                                     UNBLEACHED KJWFT MILL EFFLUENT1
Columns
Preceded By
Biological
Oxidation &
Description of Clarification
Carbon Process Inf. Eff. Removal
BOD (rag/l)
TOC (mg/l) 148 57 61%
Turbidity (JTU)
Color (Pt-Co Units) 740 212 71%
Hy driiil ic
Load (gpra/sq ft) 2.13
Carbon Granular
Contact Time (Hill) 140
Fresh Carbon
Dosage 8
(11) cjrbon/
1000 gal.)
pH
Columns Colunns Columns
Preceded By Preceded By Preceded By
Primary Primary Lime Treatment
Clarification Clarification & Clarification
Inf. Eff. Removal Inl. Eff. Removal Inf. Eff. Removal
26% Removal
220 83 62% 310 121 61% 177 100 44%
5-15
925 185 80% lloO 202 83% 252 76 70%
1.42 0.71 1.42
Granular Granular Granular
108
20.5 28 2.5
11.3
                                                                                                                               	FACET System	
                                                                                                                               Inf."  Eff.  "Removal
                                                                                                                                158
                                                                                                                                157
                                                                                                                                      101
                                                                                                                                              36%
                                                                                                                                       73(a)  54%
                                                                                                                                Intermediate
                                                                                                                                   J.y
                   'Source:  Timpe,  W.G.  and Lang,  E.W.,  "Activated Carbon Treatment  ol  Unbleached  Kraft  Effluent  for Reuse - Pilot Plant
                            Results,"  TAPPI Environmental  Conference, San Francisco,  Hay  1973.(158)
                   (a)  Kiltered

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generation.    In  this process,  fine air bubbles are introduced into a
basin or structure containing the effluent.    The  air  bubbles  cause
generation   of  foam  in  which  the  surface  active  compounds  are
concentrated.  Jet air dispersion  has  been  found  to  be  the  most
efficient  technique  for foam generation when compared to turbine and
helical generation systems.(174)

Several full-scale foam separation facilities have been built for  the
removal  of  detergents  from  municipal  wastes.(175)(176)   The  Los
Angeles County Sanitation District system operated a system treating a
flow of 45,000 cu m/day (12 mgd) at a seven minute  detention.   Water
reclamation  was  the  primary  purpose  of  the  unit, which operated
successfully  and  trouble-free  during  two   years   of   continuous
operation.(177}  This system, like other municipal systems, has ceased
operation  due  to  regulations  that require the use of biodegradable
detergents.

A bleached kraft whole mill effluent was analyzed for total resin acid
content before and after treatment in a  pilot-scale  foam  separation
unit.(177)  Two  mill  effluents  were treated in a two hour detention
time foam separation pilot unit.  The resin acid content in all  cases
was  reduced  by  between 46 and 66 percent.  The range of total resin
acid content in the influents and effluents was 2.6 to  5.1  mg/1  and
0.1 to 1.0 mg/1, respectively.  In all cases, the treated effluent was
rendered nontoxic to fish.

Pilot  studies  were performed using foam separation as a pretreatment
prior to the application of activated sludge and aerated stabilization
treatment of bleached kraft effluent.(178)   These  studies  indicated
that the detoxification efficiency of biological treatment can improve
from  50  to 85 percent of the time without foam separation to over 90
percent of the time with foam separation.(178)

Microstraining

At two nonintegrated papermills, full-scale coagulation/microstraining
facilities  are  used  for  treating   rag   pulp   and   fine   paper
effluents.(179)(180)   Coagulant usage includes the addition of 1 mg/1
of polymer plus the addition of alum or  caustic  for  pH  adjustment.
Typically,  suspended  solids  and  BOD5_  reductions to 10 mg/1 and 50
mg/1, respectively, are achieved.  When properly operating,  treatment
approaching  that  achievable  through  the  application of biological
treatment has been obtained.   It has been observed that upsets  caused
by  such practices as paper machine washup with high alkaline cleaners
affect the effectiveness of the technology.(179)

Electrochemical Treatment

Electrochemical treatment technology involves the  application  of  an
electrical  current  to  the effluent to convert chloride to chlorate,
hypochlorite, and chlorine.  The chlorine and hypochlorite can oxidize
organic compounds and be reduced again to chloride ions.  The  process
then  repeats  in  a  catalytic  fashion.   The  oxidation  of organic
                                379

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compounds reduces the BOD5_, color, and toxicity of  the  effluent.   A
significant advantage of the process is that no sludge is produced.

Oner  found  that  an  80  percent  reduction  of  color in whole mill
bleached kraft effluent and a 90 percent reduction of color in caustic
extract could  be  achieved  through  electrochemical  treatment.(181)
Similar  results were achieved when using a lead dioxide or a graphite
anode.  The lead dioxide anode required less energy.  No  toxicity  or
toxic pollutant data were reported.

In  a  variation  of the process, Barringer Research Ltd. investigated
the use of a carbon  fiber  electrochemical  reactor  to  treat  kraft
caustic  extracts.(182) The high surface to volume ratio of the carbon
greatly decreased the reactor volume requirements.  At an effluent  to
water  volume  ratio  of 60 percent (v/v), toxicity was reported to be
reduced from  10  percent  mortality  in  22  hours  to  zero  percent
mortality in 96 hours.  Color reduction of 90 percent and BOD5_ and COD
reductions  of 50 percent and 60 percent, respectively, were reported.
This process is in full-scale use in the mining industry, but no pilot
or mill-scale unit has been applied in the pulp, paper, and paperboard
industry.(183)  The primary drawback of the process is failure of  the
carbon cell to perform for extended periods.(183)

Another  variation  to  this  process involves the use of hydrogen gas
bubbles generated in the process to float solids  and  separate  scum.
Selivanov  found that an electrochemical unit with graphite anodes and
stainless steel  cathodes  could  cause  coagulation  in  kraft  white
water.(184)   Release of hydrogen bubbles in the process caused solids
removal by flotation.  Total suspended solids were reduced to 2  to  4
mg/1.   No toxicity data were reported.

Herer  and  Woodard  found  significant  color  and  TOC reductions in
bleachery  wastes  by  application  of  electrolytic  cells  using  an
aluminum  anode.(185)  Color  removals  from  chlorination and caustic
extraction effluents were 92 percent  and  99  percent,  respectively,
while  TOC  removals  were  69  percent  and 89 percent, respectively.
Specific concentrations, however, were not reported.

Ion Flotation

This process involves the addition of a  surfactant  ion  of  opposite
charge  to the ion to be removed.  The combining of these ions results
in a precipitate, the colligend.  The colligend is removed by  passage
of  air  bubbles  through  the  waste  and collection of the resulting
floating solids.

Many of the chromophoric (color producing) organics  in  pulp,  paper,
and  paperboard  mill  wastewaters are negatively charged, making this
process suitable for the removal of color.  Chan, et^ al.  investigated
the process on a laboratory scale.(186)  A variety of commercial grade
cationic  surfactants  were tested and Aliquat 221 produced by General
Mills was found to be very effective.  The  process  removed  over  95
                               380

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percent  of  the  color  from  bleached  kraft effluents.  No specific
removals of toxicity or toxic pollutants were reported.

Ai r/Catalyt i c/Chem i ca1 Oxidation

Complete oxidation of organics found in pulp,  paper,  and  paperboard
mill  wastewaters  to  carbon  dioxide  and  water   is  a  significant
potential advantage of oxidation processes.  Partial oxidation coupled
with  biological  treatment  may  have   economic    and/or   technical
advantages over biological treatment alone.

Past  studies of oxidative processes dealt principally with COD or TOC
as a measure of performance.  Barclay, e_t  al.  completed  a  thorough
compilation of related studies and found that most were performed with
wastewater  other  than  those  resulting from the production of pulp,
paper, and paperboard.(187) Some tentative  conclusions,  though,  may
still be drawn:

     o Complete oxidation with air can occur under extreme temperature
     and  pressure,  high  intensity  irradiation, with air at ambient
     conditions  in  the  presence  of  excessive  amounts  of  strong
     oxidants  (03^,  E202  or  C102_),   or  with  air  or oxygen in the
     presence of catalysts such as certain metal oxides.

     o Sulfite wastes  can  be  partially  detoxified  by  simple  air
     oxidation for a period of seven days.

     o  Ozone oxidation achieved only slight detoxification of sulfite
     wastes after two hours and  partial  detoxification  after  eight
     hours.(187)

     o  Major  BOD5_  reductions  can only be achieved under conditions
     similar to those required for nearly complete oxidation.

No  data  specifically  relating  to  toxic  pollutant  removal   were
reported.

Steam Stripping

Steam  stripping  involves  the removal of volatiles from concentrated
streams.  Hough and Sallee report that steam stripping at a kraft mill
is capable of removing 60 to 85 percent of the  BODI5  from  condensate
streams.(188)    The   ability  of  the  process  to  remove  specific
pollutants (including toxic and nonconventional pollutants) depends on
the relative boiling points of the pollutants with respect to that  of
water  (i.e.,  the  pollutants  must  be  volatile).  Resin acids have
boiling points in the range  of  250°C  (482°F)  and,  thus,  are  not
readily stripped through application of this process.(189)

Steam  stripping was evaluated for its ability to detoxify condensates
from sulfite waste liquor evaporators.(190)  This stream accounted for
10 percent of the whole mill effluent toxicity and 28 percent  of  the
total  BOD5_ load.  Toxicity in the condensate stream was attributed to
                                 381

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acetic acid, furfural,  eugenol,   juvabione,   and  abietic  acid.   The
application  of  steam  stripping  had  no  observable  effect  on the
toxicity of  the  stream,   although  the  total  organic  content  was
reduced.

Steam  stripping of kraft  mill digester and evaporator condensates was
employed on a mill scale for control of  total  reduced  sulfur  (TRS)
compounds  and  toxicity.(191) The 96-hour LC-50 of the condensate was
altered from 1.4 percent to 2.7  percent.  Thus,  the  stream  remained
highly  toxic,  even after steam stripping.   The process did remove 97
percent of the TRS compounds.    Production  process  changes  such  as
minimizing   condensate   volume,  installation  of  spill  collection
systems, reduction of fresh water use, and conversion to dry debarking
along with the application of  steam stripping resulted in  a  nontoxic
effluent.

Ultrafiltration

Wastewater   treatment   by   ultrafiltration   involves   removal  of
macromolecules from wastewater by  means  of  membranes  of  specified
molecular  size.   Wastewater   is  forced  through the membranes under
pressure.  The size of  the  molecules  to  be  removed  dictates  the
permeability (size opening)  of the ultrafiltration membrane.

Data  are  available  from Easty for nonconventional pollutant removal
from two bleached kraft caustic  extraction  effluents  utilizing  two
types  of  ultrafiltration systems.(90)  Good removals of epoxystearic
acid, dichlorostearic acid,  trichloroguaiacol, and tetrachloroguaiacol
were obtained in each case.   Chlorinated resin acids were  effectively
removed by one system but  not  the other.

The  first  system  employed  only  one  spiral wound membrane, with a
surface area of 3.7 sq m  (40 sq ft).  Filtration of  suspended  solids
larger  than  10  micrometers   (0.004  in)  was  accomplished prior to
ultrafiltration.  The system was operated at 28.4  liters  per  minute
(7.5  gpm)  and  a  pH  of  11  to 11.5.  The system achieved 50 to 80
percent reduction of chlorinated phenolics but only 0  to  15  percent
removal  of  chlorinated  resin  acids.  The lower percent removals of
chlorinated resin acids reflect a low initial concentration  of  these
pollutants in the waste.

The second system treated an effluent volume of 12.5 liters per minute
(3.3  gpm)  using  a tubular cellulose acetate membrane with a surface
area of  1.1 sq m (12.1 sq ft).  The system operated at a pH of 9.5  to
10.5  and  inlet and outlet pressures of 15.0 ATM (220 psi) and 6.8 ATM
(100 psi), respectively.  Filtration of all particles larger  than  10
micrometers   (0.004  in)  was  accomplished  prior to ultrafiltration.
This system removed approximately 80 to 85 percent of all  chlorinated
resin acids, chlorinated phenolics, and other acids.

Lewell  and  Williams  studied  color, 1ignosulfonate, COD, and solids
removals   from   sulfite   liquor   after    the    application    of
ultrafiltration.(192)   Removals on the order of 30 to 50 percent were
                                 382

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observed for color, lignosulfonate, COD,  and  TSS.   No  toxicity  or
toxic  pollutant  data  were reported.  Costs (1971) were estimated at
$0.40/kl ($1.50/kgal) for a 3785 cu m (1.0 mgd)  permeate  flow.   The
authors  concluded that ultrafiltration could not compete economically
with lime as a means  of  removing  lignosulfonate,  color,  COD,  and
solids.(192)

Reverse Osmosis/Freeze Concentration

Reverse  osmosis  employs  pressure  to  force  a  solvent through the
membrane against the natural osmotic force.  This is the same type  of
process  as ultrafiltration except that the membranes used for reverse
osmosis reject lower molecular weight solutes.  This means that  lower
flux rates occur; there is also a need for a higher operating pressure
difference    across   the   membrane   than   those   necessary   for
ultrafiltration.

Reverse osmosis is employed at a Midwest NSSC mill where  270  kkg/day
(300  tpd)  of  corrugating  medium  are  produced.  The system allows
operation of a closed white water system.   Easty  reported  that  the
system  achieved  BOD5_  reductions  of  approximately  90  percent and
removed essentially all resin and fatty acids.(90) The 320  liter  per
minute  (85  gpm)  reverse osmosis unit employs 288 modules, each with
1.55 sq m (16.7 sq ft) of area provided by 18 cellulose acetate tubes.
The system operates at 41 ATM (600 psi)  and  38°C  (100 °Fj.   During
Easty's  testing,  the  white  water  feed  contained 300 mg/1 TSS and'
40,000 to 60,000 mg/1 total dissolved solids.  Initial resin and fatty
acid levels were:   abietic,  1.5  mg/1;  dehydroabietic,  2.62  mg/1;
isopimaric, 2.75 mg/1; pimaric,  0.82 mg/1; oleic, 4.86 mg/1; linoleic,
7.23 mg/1; and linolenic, 0.27 mg/1.(90)  The maximum removal capacity
is not known since final concentrations were below detection limits.

Reverse  osmosis  can  be followed by freeze concentration whereby the
effluent  is  frozen  to  selectively   remove   pollutants.    Freeze
concentration  takes  advantage  of  the  fact  that when most aqueous
solutions freeze, the ice crystal is almost 100 percent  water.   This
process   was   evaluated   by   Wiley,  et  al.   on  three  bleachery
effluents.(193) Reverse osmosis alone resulted in a concentrate stream
of roughly  10  percent  of  the  volume  of  the  raw  feed.   Freeze
concentration  reduced  the  concentrate  stream volume by a factor of
five while  essentially  all  the  impurities  were  retained  in  the
concentrate.   Thus the two processes employed in tandem resulted in a
concentrate stream consisting of roughly two percent of  the  original
feed   volume   that   contained  essentially  all  of  the  dissolved
solids.(193)  It was  reported  that  the  purified  effluent  was  of
sufficient  quality  that  it  could  be  returned  to the process for
reuse.(193)   Wiley  did  not  investigate  final  disposal   of   the
concentrate.
Amine Treatment
This  treatment
amines to
tment  is  based  upon*  the ability of high molecular weight
form  organophilic  precipitates.   These  precipitates  are
                                383

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separated  and  redissolved  in  a  small  amount  of  strong alkaline
solution (white water).  By so doing,  the  amine  is  regenerated  for
use, with no sludge produced.(194)

The  Pulp  and  Paper Research Institute of Canada (PPRIC) conducted a
study to determine the optimum process conditions for  employing  high
molecular  weight  amines  for color,  BODj^, and toxicity reductions of
bleached kraft mill effluents.(195)   While no specific data  on  toxic
or nonconventional pollutants were reported,  whole mill bleached kraft
effluent  remained  toxic  after  application  of the treatment in two
reported  tests.   Likewise,   acid  bleach  effluent  could   not   be
detoxified.    However, alkaline bleaching wastewater was detoxified in
three out of four samples at  65  percent  dilution.    Final  effluent
concentrations  for  BOD5^,  COD,  and color after treatment of bleached
kraft whole mill wastewater were 80  to 350 mg/1,  380 to 760 mg/1,   and
80  to  450 APHA units, respectively.   Reported removals were 10 to 74
percent, 36 to 78 percent, and 94 to 98 percent,   respectively,  using
Kemamine T-1902D in a solvent of Soltrol 170.

Polymeric Resin Treatment

Polymeric  resin wastewater treatment processes make use of adsorption
and ion exchange mechanisms to remove pollutants from the  wastewater.
Resin  columns  are  commonly  employed;  they  are  reactivated after
completion of the  treatment  cycle   by  means  of  acid  or  alkaline
solutions.    It  has  been  reported  that  weakly  basic ion exchange
resins,  based  on  a  phenol/formaldehyde  matrix,  are  superior  in
treating  pulp  and  paper bleach plant effluents.(196) Prior to resin
treatment,  it is advantageous to screen and filter the  waste  streams
and adjust the pH to 2 or 3.

The  resin  adsorption  approach  is being pursued by three companies:
Billerud Uddeholm, Rohm and Haas, and Dow Chemical Company.  The  Rohm
and  Haas and the Dow Chemical processes are at the pilot plant stage.
The Billerud Uddeholm color removal  process has  been  operated  as  a
full-scale batch process in Skoghall,  Sweden, since 1973.

Based  on  the  experience  gained through operation of the full-scale
system in treating the caustic first extraction stage  effluent  (E,),
treatment  was  expanded' to include chlorination stage washer effluent
(Cj).  The first full-scale continuous installation began in  December
of  1980  at  Skoghall, Sweden.   In this system,  a full countercurrent
wash is used, and the effluent from the E, stage is reused on  the  C,
stage  washer after color and toxicity removal through the application
of resin adsorption.(75)(197)

The pollutants may be removed from the resin by elution  with  caustic
or  oxidized  white liquor.  The eluate at 10 percent concentration is
mixed with the weak black liquor to be evaporated and  burned  in  the
recovery  boiler.   The  resin   is  reactivated  with the chlorination
effluent.  The chlorination stage effluent reactivates the  resin  and
is  simultaneously  decolorized  and  detoxified.  The total mill BODI5
                               384

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load is reduced by 30 percent and the color load by 90  percent.   The
flow diagram of this process is shown in Figure VII-33.

The  operating  costs for the Billerud Uddeholm system are reported as
$3.74 per kkg of production ($3.40 per ton of production) (1980).  The
investment cost of an installation for treatment of the effluent  from
a  310  kkg/day (340 tpd) kraft pulp mill bleach plant is $4.0 million
(1980) including close-up of the bleach plant.  The  costs  will  vary
depending  on  wood  species, kappa number, and local conditions.(197)
These costs are based upon a resin life of one and one-half years.

The Rohm and Haas process involves the use of Amberlite XAD-8 resin to
decolorize bleaching effluent after  filtration.   The  resin  can  be
reactivated without the generation of waste sludge.  This reactivation
may  be  accomplished  by  using mill white liquor.  In one study,  the
adsorption  capacity  of  Amberlite  XAD-2  resin  was   compared   to
Filtrasorb  300  activated carbon. (198)  The resin was more effective
in removing most aromatic compounds,  phthalate esters, and pesticides/
carbon was more effective at removing alkenes.  Neither adsorbant  was
effective  in  removing  acidic  compounds.  The tests involved use of
laboratory  solutions  of  100  organic  compounds   at   an   initial
concentration of 100 ug/1.

Another  study  has  shown synthetic resin to be capable of removing a
higher percentage of COD from biological effluent than  carbon.  (199)
Also,  resin  treated  wastewater  quality  was  improved when further
treated with carbon, although the reverse was not true.  The economics
of this system could prove favorable since resin may be regenerated in
situ.  Thus, total regeneration costs may be more economical than  for
either system alone since carbon life could be significantly extended.

Elimination  of  toxic  constituents from bleached kraft effluents has
been  achieved  with  Amberlite  XAD-2  resin.(200)(201)   Wilson  and
Chappel reported that treatment with Amberlite XAD-2 resin resulted in
a nontoxic semi-chemical mill effluent.(202)
                                 385

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                          MOM SCMCNW6
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                                                                                                  FIGURE OT- 33
                                                                                            BILLERUO-UOOEHOLM
                                                                                 NON-POLLUTING BLEACH PLANT

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                             SECTION VIII
             DEVELOPMENT OF CONTROL AND TREATMENT OPTIONS


INTRODUCTION

In Section VII, many control and treatment technologies are  discussed
and  information  is  presented  on  their capabilities for removal of
conventional, toxic, and nonconventional pollutants from pulp,  paper,
and  paperboard  industry  wastewaters.   From these technologies, EPA
identified alternative control  and  treatment  options  for  detailed
analysis  that  represent  a range of pollutant removal capability and
cost.  This section presents  the  options  that  were  considered  in
determining  BPT and BAT effluent limitations and NSPS, PSES, and PSNS
for the pulp, paper, and paperboard industry.

For  BPT,  treatment  options  have  been  developed  for  control  of
conventional   pollutants   for   new  subdivisions  of  two  existing
subcategories  (paperboard  from  wastepaper  and   nonintegrated-fine
papers)  and  for  four new subcategories (wastepaper-molded products,
nonintegrated-lightweight papers,  nonintegrated-filter  and  nonwoven
papers, and nonintegrated-paperboard).   For BAT, control and treatment
options  have  been developed for control of toxic and nonconventional
pollutants  being  discharged  directly  to  navigable  waters.   NSPS
treatment   options  for  the  control   of  toxic,  conventional,  and
nonconventional pollutants have been developed for  new  point  source
direct  discharging mills.  Options for control and treatment of toxic
pollutants discharged to POTWs have been developed  for  existing  and
for new indirect discharging mills (PSES and PSNS).

BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE (BPT)

General

Four  new  subcategories  of  the pulp, paper, and paperboard industry
have  been  identified:  wastepaper-molded  products,   nonintegrated-
lightweight  papers,  nonintegrated-filter  and  nonwoven  papers, and
nonintegrated-paperboard.  As discussed in Section  IV,  two  existing
subcategories have been divided into subdivisions: the paperboard from
wastepaper  subcategory  is  separated  into  the  corrugating  medium
furnish subdivision and the noncorrugating medium furnish subdivision;
the nonintegrated-fine papers subcategory is separated into  the  wood
fiber furnish subdivision and the cotton fiber furnish subdivision.

As  stated  previously,  the  Act  establishes  the  requirements  for
development of BPT limitations, which are basically the average of the
best existing performance.  The best  practicable  control  technology
currently  available  for  the wastepaper-molded products subcategory,
and for mills in the corrugating medium  furnish  subdivision  of  the
paperboard   from   wastepaper  subcategory  has  been  identified  as
biological treatment, which  is  also  the  technology  on  which  BPT
limitations  are  based  for  all other subcategories of the secondary
fibers segment of the pulp, paper, and paperboard industry.  The  best
                                387

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practicable  control  technology  currently available for mills in the
cotton fiber furnish  subdivision  of  the  nonintegrated-fine  papers
subcategory  has been identified as biological treatment which is also
the technology on which BPT limitations are based for all other  mills
in the nonintegrated-fine papers subcategory.

In   Table   VIII-1,  subcategory  average  BOD5_  and  TSS  raw  waste
characteristics for the  three  new  nonintegrated  subcategories  are
compared to the BOD5_ and TSS raw waste characteristics that formed the
basis  of  BPT  effluent limitations for the nonintegrated-fine papers
and the nonintegrated-tissue papers  subcategories.    This  comparison
indicates  that  raw  waste  loads  for  these  new  subcategories are
comparable to those of the  nonintegrated-tissue  papers  subcategory.
The   technology   basis   of   BPT   effluent   limitations  for  the
nonintegrated-tissue papers subcategory is primary treatment.  Primary
treatment, therefore, has been selected as the basis  for  development
of  BPT effluent limitations for the nonintegrated-lightweight papers,
nonintegrated-filter and nonwoven papers,  and nonintegrated-paperboard
subcategories.

The development of raw waste loads and final effluent  characteristics
for each subcategory is discussed below.

Development o_f_ Raw Waste Loads

Paperboard  from  Wastepaper.  Available raw waste load data for mills
in the subcategory are presented  in  Table  V-16.   As  discussed  in
sections  IV and V, the raw waste load BOD5. at mills where corrugating
medium furnish is processed has increased since BPT  was  promulgated.
At  that  time,  the  average  raw  waste  load  BOD5_  for mills where
corrugating medium furnish is processed was 11.3 kl/kkg  (22.5  Ib/t).
Recent  data  submitted  by representatives of mills 110025 and 110080
indicate that the current raw waste load BOD5_ for mills where recycled
corrugating  medium  is  processed  is  23.0   kg/kkg   (46.0   Ib/t).
Therefore,  raw waste loads for mills where corrugating medium furnish
is processed have been revised to account for  the  higher  raw  waste
BODS  and  are:  flow  -  30.0 kl/kkg (7.2 kgal/t); BOD5_ - 23.0 kg/kkg
(46?0 Ib/t), and TSS - 11.0 kg/kkg (21.9 Ib/t).

EPA evaluated available data for the mills where all  other  kinds  of
wastepaper  are processed; the Agency found that the original BOD5_ raw
waste load is still representative.  Therefore, BPT  raw  waste  Toads
for  noncorrugating  medium  furnish mills are as originally developed
for the subcategory: flow - 30.0 kl/kkg  (7.2  kgal/t);  BOD5  -  11.3
kg/kkg (22.5 lb/t); and TSS - 11.0 kg/kkg (21.9 Ib/t).

Wastepaper-Molded  Products.   Available raw waste load data for mills
in this subcategory are presented in Table V-18.  Raw waste  loads  on
which  BPT limitations are based are equal to the average of raw waste
loads at mills where extensive recycling of effluent is not practiced.
This yields flow, BOD5_, and TSS raw waste loads of 88.1  kl/kkg   (21.1
kgal/t),  7.9  kg/kkg  (15.8  Ib/t),  and  14.8  kg/kkg  (29.6  Ib/t),
respectively.
                                 388

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                                    TABLE VIII-1

                          AVERAGE RAW WASTE CHARACTERISTICS
                            FOR THE NONINTEGRATED SEGMENT
                     OF THE PULP, PAPER, AND PAPERBOARD INDUSTRY
Subcategory
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightweight
Papers
Nonintegrated-Filter and
Nonwoven Papers
Nonintegrated-Paperboard
BPT Technology
Basis
Biological Treatment
Primary Clarification
None*
None*
Hone*
Subcategory/Subdivision
Raw Waste Characteristics
Average BODS Average TSS
209 og/1
144 mg/1
120 ng/1
107 mg/1**
73 mg/1
122 mg/1**
678 mg/1
342 mg/1
323 mg/1
312 mg/1**
165 mg/1
685 mg/1**
'•''Mills in these subcategories were permitted on a case-by-case basis using
 "best engineering judgement."  BPT for these subcategories has been identi-
 fied as primary treatment, the same technology basis as for the Nonintegra-
 ted-Tissue Papers subcategory because of the similarity of raw waste BODS
 characteristics.

**Does not include production of electrical grades of papers.
                                          389

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Noninteqrated-Fine Papers.   Available raw waste  load  data  for  this
subcategory  are  presented  in  Table V-22.  Data for the subcategory
were reevaluated  based  on  comments  from  industry.   As  discussed
previously,  EPA  determined  that  raw waste load flow, BOD5_, and TSS
were comparable for mills where more  than  90.7  kkg  (100  tons)  of
product  per  day  are manufactured and those where less than 90.7 kkg
(TOO tons) per day are produced, excluding mills  where  cotton  fiber
comprises  a significant portion of the final product.  EPA determined
that the cotton fiber mills have higher raw waste flow and  BOD5_  than
other mills in the subcategory.  Based on this review, the subcategory
has  been  separated  into  two  subdivisions:  wood fiber furnish and
cotton fiber furnish.  The raw waste loads on  which  BPT  limitations
are  based  for nonintegrated mills where a significant portion of the
final product (greater than 4 percent) is comprised of  cotton  fibers
are  equal  to  the  average  of raw waste loads at these cotton fiber
furnish mills, or: flow - 176.5 kl/kkg  (42.3  kgal/t);  BOD5_  -  22.9
kg/kkg (45.8 lb/t); and TSS - 55.2 kg/kkg (110.4 Ib/t).

Noninteqrated-Liqhtweight  Papers.   Available raw waste load data for
this subcategory are presented in Table V-24.  BPT raw waste loads for
this subcategory are based on the average of raw waste loads at  mills
in  this  subcategory.   Two product sectors have been considered: (a)
lightweight papers and (b)  lightweight electrical  papers.   At  mills
where lightweight electrical papers are produced, substantially larger
quantities  of water are discharged than at mills where non-electrical
grades are produced.  At  the  only  mill  for  which  BOD5_  data  are
available  where  lightweight electrical grades are produced, the BODS^
raw waste load is lower than the average  for  non-electrical  grades.
Average  raw waste loads associated with the production of lightweight
papers are: flow-203.2 kl/kkg (48.7 kgal/t);  BOD5-21.7  kg/kkg   (43.3
lb/t);  and  TSS-63.4  kg/kkg (126.8 lb/t).  EPA assumed that BOD5. and
TSS raw waste loads  associated  with  the  production  of  electrical
grades are the same as for non-electrical grades.  This results in raw
waste  loads  for the lightweight electrical papers product sector of:
flow-320.9 kl/kkg (76.9 kgal/t); BOD5_ - 21.7 kg/kkg (43.3  lb/t);  and
TSS - 63.4 kg/kkg (126.8 lb/t).

Noninteqrated-Filter  and  Nonwoven  Papers.  Available raw waste load
data for mills in  this  subcategory  are  presented   in  Table  V-25.
Initially, it was assumed-that the subcategory average raw waste  loads
would  form  the  basis  for  proposed  BPT  effluent  limitations.  In
reviewing raw waste load flow data with respect to frequency of  waste
significant  grade  changes,  it  was determined that  none of the four
mills where more than one waste significant grade change occurred  per
day  exhibited  raw  waste load flows that were equal  to or lower than
the subcategory average raw waste loads.  Therefore, the proposed  BPT
flow  basis was revised to reflect the highest average for the various
grade change delineations.   The BPT raw waste load flow  is  based  on
those mills with less than one waste significant grade change per day.
The  raw  waste  loads  for flow, BOD5_, and TSS are 250.0 kl/kkg  (59.9
kgal/t),  12.2  kg/kkg  (24.3  lb/t),  and  27.4  kg/kkg  (54.7  lb/t),
respectively.
                                390

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Noninteqrated-Paperboard.    Available  raw  waste  load  data for this
subcategory are presented in Table V-26.  The subcategory average  raw
waste loads, exclusive of electrical and matrix board production, form
the  basis  for proposed BPT.  The raw waste loads for flow, BOD5^, and
TSS are 53.8 kl/kkg (12.9 kgal/t), 10.4 kg/kkg (20.8 Ib/t),  and  36.9
kg/kkg (73.7 Ib/t).

Development of_ Final Effluent Characteristics

In  the  Phase  II  Development  Document, EPA developed the following
relationship between the anticipated final effluent BOD5^ concentration
and the BOD5_ concentration  entering  a  biological  treatment  system
based  on treatment plant performance at those mills used to establish
BPT effluent limitations (see Phase II Development Document, page 402)
(48):

     Log BOD5. effluent (mg/1) = 0.601 Log BOD5. influent (mg/1) - 0.020

EPA used this relationship in establishing allowances to be  added  to
BPT  effluent  limitations if wet barking, log or chip washing, or log
flumes or ponds were  employed  at  individual  mills  (see  Phase  II
Development Document,  page 558).(48)

In  Figure  VIII-1,  EPA  has plotted the BOD5_ raw waste concentration
that  formed  the  basis  of  BPT  versus  the  final   effluent   TSS
concentration  that  formed the basis of BPT for the dissolving kraft,
market bleached kraft, fine bleached kraft, BCT  (board,  coarse,  and
tissue)  bleached  kraft,  dissolving sulfite pulp, papergrade sulfite,
soda, groundwood, and deink subcategories.  It is apparent that  final
effluent   TSS   concentrations   are   related   to  raw  waste  BOD5_
concentrations  when   biological   treatment   is   employed.    This
relationship is defined by the following equation:

     Final effluent TSS (mg/1) =  (8.95) (Raw Waste BOD5_ (mg/1))0-31

As  discussed  previously,  BPT   for  the  corrugating  medium furnish
subdivision of the paperboard  from  wastepaper  subcategory  and  the
wastepaper-molded   products   subcategory   has  been  identified  as
biological  treatment.   Therefore,  the  above  relationships,  which
predict  the  BOD5_  and  TSS final effluent concentrations that result
from the application  of  biological  treatment  consistent  with  the
biological  treatment  systems  that  form  the  basis of BPT effluent
limitations for the major portions of the pulp, paper, and  paperboard
industry,  are  applicable.   The  long-term  average BPT BOD5_ and TSS
final effluent concentrations for  mills  in  the  corrugating  medium
furnish  subdivision of the paperboard from wastepaper subcategory and
the wastepaper-molded products subcategory are based on the  predicted
performance     of     biological    treatment    applied    to    the
subcategory/subdi vision  average  BOD5>   raw   waste   concentrations.
Long-term  average  BPT  final  effluent  loads were calculated as the
product  of  the  long-term  average  BOD!>  and  TSS  final   effluent
concentrations  and  the  flows   that  form the basis of BPT for these
subcategory/subdivisions.
                                391

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  100-

   90-

   80-


   70-


   60-
   90-
                                    •  •
^  40H
9
v>
to
   30-
              REGKESSION EQUATION t
              M« O.TO
              ^ « 0.099
                                                          • B.99ia>l
   20-
   10-
     100
200           500      400     9OO    600   700  800 »00

        RAW WASTEWATER BODS • ">9/>
                                                             FIGURE
                                                   FINAL EFFLUENT TSS  VS
                                                   RAW  WASTEWATER BOD&
                                 392

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As discussed previously, BPT for the cotton fiber furnish  subdivision
of  the  nonintegrated-fine  papers subcategory has been identified as
biological treatment.  The BPT BOD5_  effluent  limitation  promulgated
for  the  nonintegrated-fine  papers  subcategory in 1977 is much less
stringent than BODj^ effluent limitations for other subcategories  with
comparable  BODS^  raw  waste  characteristics.  Therefore, EPA did not
base the long-term average BPT BOD5_ final effluent  concentration  for
this  new  subdivision on the relationship between BODS^ final effluent
concentration and BOD5_ raw waste concentration  discussed  previously.
Rather,  the  long-term  average BPT BOD5^ final effluent concentration
for the cotton fiber furnish  subdivision  of  the  nonintegrated-fine
papers  subcategory  is  based  on  the transfer of the performance of
biological  treatment  characteristic  of  all  other  mills  in   the
nonintegrated-fine  papers  subcategory.  EPA applied the same percent
reduction  in  BODS^  (77.7  percent)  that  forms  the  basis  of  BPT
limitations  promulgated  in  1977  for  the nonintegrated-fine papers
subcategory  to  the  BODS^  raw  waste   load   for   mills   in   the
newly-established    cotton   fiber   furnish   subdivision   of   the
nonintegrated-fine papers subcategory.  The long-term average BPT  TSS
final  effluent  characteristics  were developed from the relationship
illustrated in Figure VIII-1.  Long-term average loads were calculated
as the product of the long-term average BODS^ and  TSS  final  effluent
concentrations  and  the flow that forms the basis of BPT for this new
subdivision.

As discussed previously, BPT for the nonintegrated-lightweight papers,
nonintegrated-filter and nonwoven papers, and nonintegrated-paperboard
subcategories has been identified as primary treatment.  As  shown  in
Table  VIII-1,  raw  waste characteristics for these new subcategories
are   comparable   to    raw    waste    characteristics    for    the
nonintegrated-tissue  papers  subcategory.   EPA  believes  that it is
reasonable to predict that the application  of  primary  treatment  in
these three new subcategories will yield final effluent concentrations
identical to those that form the basis of BPT effluent limitations for
the nonintegrated-tissue papers subcategory.  Therefore, the long-term
average     BPT     final     effluent    concentrations    for    the
nonintegrated-lightweight papers,  nonintegrated-filter  and  nonwoven
papers,  and  nonintegrated-paperboard  subcategories  are  based on a
transfer  of  performance   from   the   nonintegrated-tissue   papers
subcategory.   Long-term  average loads were calculated as the product
of  (a)  the  long-term  average  BPT  BOD5>  and  TSS  final  effluent
concentrations that were developed for the nonintegrated-tissue papers
subcategory  and  (b)  the raw waste load flows that form the basis of
BPT for the three new subcategories.

BPT long-term average final effluent characteristics for the four  new
subcategories  and  two  new  subdivisions  of  the  pulp,  paper, and
paperboard industry are presented in Table VII1-2.
                                  393

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                                         TABLE VIII-2
                                     BPT LONG-TERM AVERAGE
                                FINAL EFFLUENT CHARACTERISTICS
                                       Flow
                                                           BODS
                                                                                 TSS
Subcategory
Paperboard From Wastepaper
o Corrugating Medium Furnish
Wastepaper-Molded Products
kl/kkg
30.0
88.1
(kgal/t)
(7.2)
(21.1)
kg/kkg
1.6
1.3
Ub/t)
(3.1)
(2.6)
kg/kkg
2.1
3.2
(lb/t)
(A. 2)
(6.4)
Nonintegrated-Fine Papers
 o Cotton Fiber Furnish           176.5   (42.3)        5.1   (10.2)        7.2   (14.3)

Nonintegrated-Ligbtweight Papers
 o Lightweight                    203.2   (48.7)        7.4   (14.7)        6.0   (12.0)
 o Electrical                     320.9   (76.9)       11.7   (23.3)        9.5   (18.9)

Nonintegrated-Filter and
 Nonwoven Papers                  250.0   (59.9)        9.1   (18.1)        7.4   (14.7)

Nonintegrated-Paperboard           53.8   (12.9)        2.0    (3.9)        1.6    (3.2)
                                           394

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BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY (BCT)

General

Section 301(b)(2)(E) of the Clean Water Act of 1977 requires that  BCT
effluent limitations are to be established for control of conventional
pollutants  from  existing  industrial  point  sources.   Conventional
pollutants are those defined in section  304(a)(4)  and  include  BOD,
suspended solids, fecal coliform, and pH and any additional pollutants
defined  by  the  Administrator as conventional (oil and grease/ 44 FR
44501,  July 30,  1979).

BCT is not an additional limitation, but replaces BAT for the  control
of conventional  pollutants.  In addition to other factors specified in
section  304(b)(4)(B),   the  Act  requires  that  BCT  limitations  be
assessed in light of a two part "cost-reasonableness"  test  (American
Paper Institute v.  EPA, 660 F.2d 954 (4th Cir. 1981)).  The first test
compares  the  cost  for  private  industry to reduce its conventional
pollutants with  the  costs  to  publicly  owned  treatment  works  for
similar  levels   of  reduction in their discharge of these pollutants.
The  second  test  examines  the  cost-effectiveness   of   additional
industrial  treatment  beyond BPT.  EPA must find that limitations are
"reasonable" under both tests before establishing them as BCT.   In  no
case may BCT be less stringent than BPT.

EPA  published  its  methodology  for carrying out the BCT analysis on
August 29, 1979  (44 FR 50732).  In the case mentioned above, the Court
of Appeals  ordered  EPA  to  correct  data  errors  underlying  EPA's
calculation  of   the  first  test,  and to apply the second cost test.
(EPA had argued  that a second cost test was not required.)

In a previous document, EPA identified four  technology  options  that
are   capable   of   removing   significant  amounts  of  conventional
pollutants, including:

     (A)  Option 1  - Base effluent limitations on  the  technology  on
     which  BPT is based for each subcategory plus additional in-plant
     production    process   controls.    No   additional   end-of-pipe
     technology beyond BPT is contemplated in this option.

     (B)  Option 2 - Base effluent  limitations  on  the  addition  of
     chemically   assisted clarification of BPT final effluents for all
     integrated  and  secondary  fiber  subcategories  and   for   the
     nonintegrated-fine  papers  subcategory  (for these subcategories
     BPT  is  based  on  biological  treatment).   For  the  remaining
     nonintegrated  subcategories,  for which primary treatment is the
     basis of existing BPT, effluent  limitations  are  based  on  the
     addition of biological treatment.

     (C)  Option 3 - Base effluent limitations on BCT  Option  1  plus
     the   addition  of  chemically  assisted  clarification  for  all
     integrated  and  secondary  fiber  subcategories  and   for   the
     nonintegrated-fine  papers  subcategory  (for these subcategories
                                 395

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     BPT  is  based  on  biological  treatment).    For  the  remaining
     nonintegrated  subcategories,   for which primary treatment is the
     basis of existing BPT,  effluent  limitations  are  based  on  the
     application  of  BCT  Option  1  plus  the addition of biological
     treatment.

     (D)  Option 4 - Base effluent  limitations on the levels  attained
     at  best  performing  mills in the respective subcategories.  The
     technologies for achieving Option  4  effluent  limitations  vary
     depending  on the types of treatment systems that are employed at
     mills in each subcategory.

Because EPA has not yet  promulgated  a  revised  BCT  methodology  in
response  to  the  American  Paper  Institute v. EPA decision mentioned
earlier, this document does not include specific information on  these
four  technology  options.   For  further  discussion  of  these  four
technology options, see (a)   46  FR  1430;  January 6,  1981  and  (b)
Proposed  Development Document for  Effluent Limitations Guidelines and
Standards for the Pulp, Paper, and  Paperboard and the Builders'   Paper
and Board Mills Point Source Categories, U.S. EPA, December 1980.(203)
EPA  is  deferring a final decision on the appropriate BCT limitations
until EPA promulgates the revised BCT methodology.

NEW SOURCE PERFORMANCE STANDARDS—CONVENTIONAL POLLUTANTS

General

Section 306 of the Clean Water Act  of 1977 requires  that  new  source
performance standards (NSPS) be established for industrial dischargers
based upon the best demonstrated technology.  NSPS include the control
of  conventional, toxic, and nonconventional pollutants.  In the pulp,
paper,  and paperboard industry, the Agency has  determined  that  NSPS
should control the same pollutants  controlled under BPT and BAT.  This
section  includes  a discussion of  those technology options considered
as the basis of control of conventional pollutants at new sources.

Two options have  been  developed  for  the  control  of  conventional
pollutants under NSPS:

     Option  1  -  Control  of  conventional  pollutants  based on the
     effluent limitations attained at best  performing  mills  in  the
     respective  subcategories.  The technology basis of NSPS Option  1
     varies depending on the type of treatment that formed  the  basis
     of BPT effluent limitations for each subcategory.

     Option  2  -  Control of conventional pollutants based on (a) the
     application of production process controls to  reduce  wastewater
     discharge  and  raw  waste loads and (b) end-of-pipe treatment in
     the form of biological treatment  for  all  subcategories  except
     nonintegrated-tissue  papers,   nonintegrated-lightweight  papers,
     nonintegrated-filter  and  nonwoven  papers,  and  nonintegrated-
     paperboard, where end-of-pipe treatment is in the form of primary
     clarification.
                                 396

-------
Option ]_

Option 1  standards are based on the levels attained at best performing
mills  in the respective subcategories.  This approach is described in
detail below and, in the majority of cases, involves an assessment  of
actual  effluent  data.  After determination of NSPS Option 1  effluent
standards, the Agency identified appropriate technologies  that  could
achieve  these  limitations.   As  discussed  below,  except  for  the
paperboard from wastepaper, tissue from wastepaper,  wastepaper-molded
products,  and builders' paper and roofing felt subcategories, EPA has
defined NSPS Option  1  to  include  the  application  of  end-of-pipe
treatment  of  those  raw  waste  loads  that  formed the basis of BPT
effluent limitations.  Therefore, except for  the  four  subcategories
mentioned above, the NSPS Option 1 raw waste loads which are presented
in  Table  VIII-3 are identical to the raw waste loads that formed the
basis of BPT effluent limitations.

The technologies for achieving  Option  1   effluent  limitations  vary
depending on the technology basis of BPT effluent limitations for each
subcategory.   As  discussed  in detail later in this section, for all
subcategories in the integrated segment and for the nonintegrated-fine
papers and deink subcategories, where BPT was identified as biological
treatment, the activated sludge process is  the  technology  basis  of
NSPS Option 1.  Treatment system design criteria were established that
reflect  attainment  of  NSPS  Option  1  effluent  standards  through
implementation of end-of-pipe treatment of the raw  waste  loads  that
form  the  basis  of BPT effluent limitations for these subcategories.
Treatment schemes were identified and used in the development of  cost
estimates  presented in Appendix A.  Specific design criteria are also
presented in Appendix A.  The activated sludge system  includes  spill
prevention  and  control  systems,  equalization,  aeration basins and
provision  for  operation  in  the  contact  stabilization  mode,  and
clarification and sludge handling equipment.

At  mills  in  the  nonintegrated  subcategories  where  BPT  effluent
limitations are based on primary treatment, the  technology  basis  of
NSPS   Option  1  is  primary  clarification.   Design  criteria  were
established  that  reflect  attainment  of  NSPS  Option  1   effluent
characteristics through implementation of end-of-pipe treatment of the
raw  waste  loads  that form the basis of BPT effluent limitations for
these  subcategories.   The  primary  clarification  system   includes
chemical coagulant addition and sludge handling capability.

At  mills  in the remaining subcategories  (paperboard from wastepaper,
tissue from  wastepaper,  wastepaper-molded  products,  and  builders'
paper  and  roofing felt), extensive use is made of production process
controls to reduce wastewater discharge.   NSPS  Option  1  for  these
subcategories   is  identical  to  NSPS  Option  2  and  includes  the
application of production process controls and  biological  treatment,
in  the  form  of  conventional  activated  sludge.   The  end-of-pipe
biological treatment systems are identical in size to those which form
the basis of BPT effluent limitations for these  subcategories   (i.e.,
biological  treatment  system  design  is  based  on attainment of BPT
                                397

-------
                                       TABLE VII]-3

                                 SUMMARY OF NSPS OPTION 1
                                      RAW WASTE LOADS

                                       Flow
Integrated Segment

Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
  o Linerboard
  o Bag
Semi-Chemical
Unbleached Kraft
  and Seni-Cheaical
Dissolving Sulfite Pulp
  o Nitration
  o Viscose
  o Cellophane
  o Acetate
Papergrade Sulfite2
Groundvood-The mo-Mechanical
Groundvood-CMN Papers
Groundwood-Fine Papers

Secondary Fibers Segment

Deink
  o Fine Papers
  o Tissue Papers
  o Newsprint
Tissue From Wastepaper
Paperboard Fron Wastepaper
  o Corrugating Mediun Furnish
  o Noncorrugating Mediun Furnish
Vastepaper-Molded Products
Builders' Paper and Roofing Felt

Nonintegrated Segaent
                                  kl/kkg  (kg«l/t)
                                                           BODS
 52.5
 52.5
 42.9
275.0
275.0
275.0
303
141
 88.0
 99.0
 91.0
4
9*
102.0
102.0
 67.6
 68.0
 13.4
 13.4
 23.8
 11.3
Nonintegrated-Fine Papers
  o Wood Fiber Furnish             63.0
  o Cotton Fiber Furnish          176.5
Nonintegrated-Tissue Papers        96.0
Nonintegrated-Lightweigbt Papers
  o Lightweight                   203.2
  o Electrical                    320.9
Nonintegrated-Filter
 and Nonwoven Papers              250.0
Nonintegrated-Paperboard           53.8
                     kg/kkg (Ib/t)
230.0   (55.1)
173.0   (41.6)
148.0   (35.4)
129.0   (30.9)
    (12.6)
    (12.6)
    (10.3)
 58.4   (14.0)
(66.0)
(66.0)
(66.0)
(72.7)
(34.0)*
(21.1)
(23.8)
(21.9)
    (24.4)
    (24.4)
    (16.2)
    (16.3)

     (3.2)
     (3.2)
     (5.7)
     (2.7)
        (15.2)
        (42.3)
        (22.9)

        (48.7)
        (76.9)

        (59.9)
        (12.9)
             66.5  (133.0)
             38.0   (75.9)
             38.4   (76.7)
             33.6   (67.2)

             16.9   (33.8)
             24.3   (48.6)
             25.2   (50.4)

             19.4   (38.8)
137.0
156.0
181.5
266.0
(274.0)
(312.0)
(363.0)
(531.9)
 92.5* (184.9)*
                 21.2
                 17.4
                 16.7
        (42.4)
        (34.8)
        (33.3)
             9C.O  (180.0)
             90.0  (180.0)
             15.9   (31.7)
              9.7   (19.3)

             23.0   (46.0)
             11.3   (22.5)
              5.5   (10.9)
              6.5   (13.0)
                 10.8   (21.5)
                 22.9   (45.8)
                 11.5   (22.9)
                 21.7
                 21.7

                 12.2
                 10.4
                    (43.3)
                    (43.3)

                    (24.3)
                    (20.8)
                                                                                 TSS
                                     kg/kkg (Ib/t)
                                    113.0  (226.0)
                                     45.0   (90.0)
                                     66.5  (133.0)
                                     75.0  (150.0)
                     21.9
                     21.9
                     12.3
92.
92.
92.
92.
90.0
39.9
48.5
52.5
                     63.4
                     63.4

                     27.4
                     36.9
                     (43.8)
                     (43.8)
                     (24.6)
                                     20.5   (41.0)
(185.0)
(185.0)
(185.0)
(185.0)
(180.0)
  79.8
  97.0
 105.0
                    202.5  (405.0)
                    202.5  (405.0)
                    202.5  (405.0)
                    110.5  (221.0)

                     11.0   (21.9)
                     11.0   (21.9)
                     14.8   (29.6)
                     35.0   (70.0)
                                 30.8   (61.6)
                                 55.2  (110.4)
                                 34.7   (69.4)
                    (126.8)
                    (126.8)

                     (54.8)
                     (73.7)
^Includes Fine Bleached Kraft and Soda subcategories.
'includes Papergrade Sulfite (Blow Pit Hash) and Papergrade Sulfite  (Driw Wash) subcate-
 gories.
*NSPS Option 1 raw waste flow and BOD5 vary with the percent sulfite pulp in the final
 product.  Flow (kl/kkg) * 52.87 •xp(0.017x), where x • percent sulfite pulp produced
 on-site in final product.  Raw waste loads shown are for a Bill where on-site paper-
 grade pulp production is 58 percent of the total product.
                                         398

-------
effluent limitations  through  the  application  of  activated  sludge
systems  to  treat  the  raw  waste  loads  that form the basis of BPT
effluent limitations for these four subcategories.)  NSPS Option 1 and
2 final  effluent  loads  are  lower  than  BPT  effluent  limitations
because,  after implementation of in-plant production process controls
which reduce wastewater flow, the detention  time  of  the  biological
treatment  system  has  been increased, thus reducing the load of BOD5_
and TSS.

General  Methodology.   This  option  involves  the  determination  of
effluent   characteristics   based   upon   the  capabilities  of  and
technologies employed at "best  performing"  mills.   Best  performers
were  selected  and  attainable  pollutant  reductions were determined
through a review of discharge monitoring reports (DMR)  and  long-term
conventional  pollutant  data obtained as a result of the verification
and the supplemental data request programs.  These data are summarized
in Tables VIII-4 through VIII-25.

The final effluent loads characteristic of the best  performing  mills
in  a  subcategory  form  the  basis  of  NSPS  Option  1 BOD5_ and TSS
discharge characteristics for that  subcategory.   EPA  has  generally
defined  best performing mills as those mills where both the long-term
average BOD5_ and TSS effluent loads are equal  to  or  less  than  the
long-term  average  BOD5_  and  TSS  BPT  effluent  limitations through
implementation of end-of-pipe technology of a type that is similar  to
that which forms the basis of BPT.  Generally, long-term average final
effluent  BOD5_ and TSS discharges per kkg  (ton) of product attained at
best performing mills were averaged; corresponding  concentrations  of
BOD5_  and  TSS were then determined at BPT flow.  In those cases where
Option 1 long-term average BOD5_ effluent concentrations  corresponding
to  BPT  flow  were  less  than  15  mg/1,  the long-term average BOD5_
concentration was revised upward to 15 mg/1.  The Agency believes that
15 mg/1 is a realistic estimate of  the  lowest  attainable  long-term
average   BOD5_  concentration  representative  of  the  capability  of
biological treatment in treating pulp, paper, and paperboard  industry
wastewaters.

A  description  of  the  specific  procedure used in establishing NSPS
Option 1 effluent characteristics for each  subcategory  follows.   As
described,  in  some  instances, EPA slightly modified the approach to
determining "best performers."

     Dissolving Kraft - As illustrated in Table  VIII-4,  the  general
methodology as described above was followed.  BPT effluent limitations
are being attained at mills 032002 and 032003.

     Market  Bleached  Kraft  -  As  illustrated  in Table VIII-5, the
general methodology was used  to  calculate  NSPS  Option  1  effluent
characteristics  for  the  market  bleached  kraft subcategory.  Mills
030028, 030030, 030031, 666666, 777777, and 900074 in this subcategory
are best performers and were used to determine long-term average final
effluent loads.  In addition to these mills, another mill (030011) was
included in the calculation.  At  this  integrated-miscellaneous  mill
                                399

-------
c
o
                                                                          TABLE VIII-4
                                                                DISCHARGE MONITORING REi'ORT DATA
                                                                  DISSOLVING KRAFT SUBC/TEGORY
                                                  Final Effluent
                                             Long-Term Average Levels
Mill How
Number kl/kkg (kgal/t)
032001 124. 
-------
                                                      TABLE VIII-3
                                            DISCHARGE MONITORING REPORT DATA
                                            MARKET BLEACHED KRAFT S'JBCATEGORY
                              Final  Effluent
                         Long-Tens Average Level»
Hill
Niuiber
030005
030009
030012
030028(a)
030030 (a)
030031 (a)
666666 (a)
777777(a)
9000 74 (a)
030011 (a )(b)
BPT-Final
Effluent
Leve 1 s
Average of
Hills
Attaining BPT
BOOS and TSS
Flow
BODS
kl/kkg (kgal/t) ks/kkg (Ib/t)
61.3
76.4
119.0
142.6
151.8
281.8
85.9
135.5
121.6
140.4


173.0




(14.68)
(18.32)
(28.52)
(34.18)
(36.38)
(67.53)
(20.59)
(32.46)
(29.13)
(33.65)


(41.6)




4.8
6.2
5.8
4.3
2.7
4.5
2.6
1.5
4.0
3.6


4.5



3.3
(9.65)
(12.40)
(11.60)
(8.55)
(5.41)
(8.94)
(5.16)
(3.08)
(7.94)
(7.25)


(9.0)



(6.62)
TSS
kg/kkg (Ib/t)
5.0
4.8
19.5
7.8
3.7
9.0
6.8
6.5
2.6
3.7


9.0



5.7
(9
(9
(39
(15
(7
(18
(13
(12
(5
(7


(18



(11
.97)
.66)
.03)
.65)
.37)
.03)
.57)
.98)
.16)
.34)


.0)



.44)
Start
Date
08/78
01/78
01/78
08/78
01/78
07/77
02/79
07/79
09/78
08/78







Number
Flow
29
39
36
31
38
33
23
16
31
21







Of Months Data
BODS
29
39
36
31
38
43
23
16
31
21







TSS
29
39
36
31
38
43
23
16
31
21







(a) TSS and BODS are less than or equal lo BPT.
(b) This Bill is an integrated miscellaneous mill where Market blea bed kraft comprises approximately 40 percent of the
    production.   Prorated BPT was determined for this Bill.  The pe cent effluent BODS and TSS reductions being
    attained were then applied to BPT BOU5 and TSS effluent levels  or the subcategory to obtain the effluent levels
    shown.

-------
where  BPT limits are being attained,  bleached kraft pulp is produced,
a significant portion of which is market pulp.  The approach  used  to
include  data  for  this mill involved comparing BOD5_ and TSS effluent
loadings to BPT limitations determined by prorating  limitations  from
appropriate subcategories.   The percentage reductions attained at this
mill  were  then  applied  to  market bleached kraft  BPT limitations.
Effluent BOD5_ and TSS characteristics for mill 030011 are 19.5 percent
and 59.2 percent below prorated BPT limitations.

     BCT  (Paperboard,  Coarse,  and  Tissue)  Bleached  Kraft  -   As
illustrated  in  Table  VIII-6,  the  general  methodology was used to
calculate  NSPS  Option  1   effluent  characteristics  for   the   BCT
(paperboard,   coarse,  and  tissue) bleached kraft subcategory.  Mills
030010, 030022, and 030032  are  best  performers  and  were  used  to
determine  long-term  average  final  effluent  loads.  In addition to
these mills,  two additional mills (030036 and 030044) were included in
the calculation.  At these integrated-miscellaneous  mills  where  BPT
limits  are  being  attained,  bleached  kraft  pulp  is  produced,  a
significant portion of which is used to manufacture paperboard, coarse
papers, or tissue papers.  The approach used to include data for these
mills involved  comparing  BOD5_  and  TSS  effluent  loadings  to  BPT
limitations  determined  by  prorating  limitations  from  appropriate
subcategories.  The percentage reductions attained at these two  mills
were then applied to the BCT (paperboard, coarse, and tissue) bleached
kraft BPT limitations.  Effluent BOD5_ and TSS characteristics for mill
030036  are  32.2 and 4.7 percent below prorated BPT limitations while
characteristics for 030044 are 68.0 and 40.1  percent  below  prorated
BPT limitations.

     Alkaline-Fine   (Fine  Bleached Kraft and Soda Subcategories) - As
illustrated in Table VIII-7,  the  general  methodology  was  used  to
calculate NSPS Option 1 effluent characteristics for the alkaline-fine
mill  grouping  (bleached  kraft  fine and soda subcategories).  Mills
030020, 030027, 030046, and 030052 were identified as best  performing
mills  and  were  used  to  determine long-term average final effluent
loads.  In addition to these mills, two additional mills  (030011  and
030044)    were    included    in    the    calculation.    At   these
integrated-miscellaneous mills where BPT limits  are  being  attained,
bleached  kraft  pulp  is  produced, a significant portion of which is
used to produce fine papers.  The approach used to   include  data  for
these  mills  involved comparing BOD5_ and TSS effluent loadings to BPT
limitations  determined  by  prorating  limitations  from  appropriate
subcategories.   The percentage reductions attained  at these two mills
were  then  applied  to  the  fine  bleached  kraft  BPT  limitations.
Effluent  characteristics  for  these  mills  relative to prorated BPT
limitations are discussed above.

Upon calculation of  the concentration of  BOD5_  corresponding  to  the
flow  that  formed   the  basis  of  BPT  for  the  fine bleached kraft
subcategory,  EPA  determined  that  the   resulting   BOD5_   effluent
concentration  was   below  15 mg/1.  Therefore, the  corresponding BOD5_
effluent concentration and effluent load were revised upward as  shown
in Table VIII-7.
                                  402

-------
o
u
                                                                            TABU VIII 6
                                                                  DISCHARGE MOMITORIKG REPORT DATA
                                                                   BCT BLEACHED KRAFT ; UBCATKGOKY
                                                    Final Effluent
                                               Long-Tem Average Levels
Hill
Number
030004
030010(a)
O30022(a)
030026
030032 (a)
030047
900010
030036 (a )(b)
030044(a)(b)
Bit-Final
Effluent
Levels
Average of
Hills
Attaining BPT
BOOS and TSS
Flow
kl/kki
208.0
170.9
150.0
136.0
106.8
151.7
121.1
129.8
117.3


148.0




(kf.l/t)
(49.84)
(40.95)
(35.94)
(32.59)
(25.60)
(36.35)
(29.02)
(31.11)
(28.12)


(35.4)




BOOS
kg/kkg (Ib/t)
4.6
2.5
3.9
4.9
2.5
5.4
4.5
2.7
1.3


4.0



2.6
(9.18)
(4.92)
(7.81)
(9.73)
(5.09)
(10.73)
(9.03)
(5.43)
(2.56)


(8.0)



(5.16)
TSS
kg/kkg (Ib/t)
4.2
4.3
1.
8.
4.
4.
4.
6.
4.3


7.1



4.3
(8
(8
(3
(17
(8
(8
(9
(13
(8


(14



(8
.49)
.69)
.54)
.25)
.95)
.56)
.03)
.53)
.50)


.2)



.64)
Start
Date
10/78
07/77
01/78
07/77
01/78
10/78
06/78
07/77
05/78







Muaber
Flow
28
43
39
42
38
25
31
33
34







Of Months Data
BODS
28
43
39
44
38
25
31
33
34







TSS
28
43
39
41
38
25
31
33
34







                      (a)  TSS and BODS are leaa than or equal  to BPT.
                      (b)  Mills are Integrated Miscellaneous Bills  where BCT bleached I raft comprise approximately 80 and SO percent of
                          the production,  reapectively.   Prorated BPT  was deteniined Tlie percent effluent BODS and TSS
                          reductiona being attained were then  applied  to BPT BODS and 'iSS effluent levels for the subcstegory
                          to obtain the effluent level* shown.

-------
                                              TABLE VI11-7
                                    DISCHARGE MONITORING REPORT DATA
                                              ALKALINE-FINE
                             Final Effluent
                        Long-Term Average Levels
Mi 1 1
Number
OJ0001
030013
030020(a)
030027(a)
030033
030034(a)(b)
030046(a)
030048
030052(a)
030058
0300fj7
030059
030060
130002
0300H(a)(c)
030044(a)(c)
BPT- Final
K» fluent.
Levels
Average of
Mills
Attaining BPT
BODS and TSS
Opt ion 1
Adjusted BOD5
(a) TSS and
lli) Data are
Flow
BODS
kl/kkg (kgal/t) kg/kkg (Ib/t)
107.2 (25.69)
138.4 (33.17)
112.3 (26.92)
63.4 (15.20)
147.1 (35.24)
69.6 (16.67)
137.6 (32.97)
110.3 (26.44)
127.7 (30.59)
124.0 (29.72)
114.2 (27.37)
143.4 (34.37)
247.5 (59.32)
70.1 (16.81)
140.4 (33.66)
117.3 (28.12)


129.0 (30.9)






2.7 (5.47)
2.7 (5.36)
1.3 (2.65)
0.7 (1.34)
6.8 (13.68)
1.0 (2.02)
2.1 (4.13)
5.7 (11.48)
3.1 (6.16)
4.1 (8.23)
7.1 (14.24)
2.7 (5.31)
31.8 (63.60)
2.3 (4.56)
2.5 (4.99)
1.0 (1.98)


3.1 (6.2)



1.8 (3.54)

1.9 (3.87)
TSS
kg/kkg (Ih/t)
10.9 (21.82)
8.5 (17.08)
2.5 (5.03)
2.1 (4.20)
21.4 (42.73)
2.7 (5.33)
3.1 (6.29)
13.4 (26.89)
3.8 (7.58)
7.4 (14.76)
5.8 (11.55)
11.2 (22.34)
25.1 (50.28)
8.5 (17.00)
2.7 (5.34)
3.9 (7.85)


6.6 (13.1)



3.5 (6.05)


Start
Date
11/78
01/78
12/78
04/78
01/78
10/79
07/77
01/78
01/80
07/77
07/77
05/78
02/78
07/78
08/78
05/78









Nuaber
Flow
26
27
24
33
35
18
27
36
12
33
44
36
33
18
21
34









Of Months Data
BODS
27
35
24
33
35
18
27
36
12
33
43
36
32
18
21
34









TSS
27
34
24
33
35
18
27
36
12
33
43
36
33
18
21
34









BOOS are less than or equal to BPT.
not included in
the average because this mill enpl
(<•) Mills are integrated miscellaneous mills
where fine papers
oys tertiary chemically assisted
comprise approximately 60 and 40
clarification.
percent


    of the production, respectively.  Prorated BPT was deterriiifd.  The percent effluent BOD5 and
    TSS reductions being attained were then applied to BPT BOD5 and TSS effluent levels for the
    subcategory to obtain the effluent levels shown.

Includes Fine Bleached Kraft and Soda subcategories.

-------
     Unbleached  Kraft  - As discussed previously, EPA has established
two subdivisions of  this  subcategory:  (a)  the  linerboard  product
sector  and  (b)  the  bag  and  other products product sector.  EPA's
review of the BPT final effluent characteristics  for  the  unbleached
kraft subcategory indicated that the final effluent BOD5_ concentration
that  forms  the  basis  of  BPT  for this subcategory is considerably
higher for the linerboard product sector than for other  subcategories
with   comparable   raw   waste   BOD5_  and,  therefore,  considerably
underestimates the pollutant  reduction  capability  in  this  sector.
Therefore,  to determine a more realistic set of best performing mills
in the linerboard product sector, the BPT final effluent BOD5_ load was
revised downward  based  on  the  relationship  of  BOD5_  influent  to
effluent presented previously and in the Phase II Development Document
(see  page  402).(48)  Employing  this methodology, the adjusted final
effluent BOD5_ long-term average load becomes 1.6 kg/kkg (3.2 Ib/t).

After  adjustment  of  the  BOD5_  final  effluent  load,  the  general
methodology   was  followed  for  the  linerboard  product  sector  as
illustrated in Table VIII-8.  The mills in this product  sector  where
revised  final  effluent  loads  are  attained  include  mills 010002,
010019, 010020,  010025,  010040,  and  010046.   For  the  linerboard
product  sector,  data for those mills with oxidation pond(s) (010020,
010025 and 010046) were excluded from the calculation.

As discussed in Section V, BOD5_ raw waste loads for the bag and  other
products  product  sector  are  substantially  higher  than those that
formed the basis of BPT effluent limitations.   To  determine  a  more
realistic  set  of  best performing mills for this product sector, EPA
revised the BPT final effluent BOD5_ load based on the relationship  of
BOD5_  influent  to  effluent  presented previously and in the Phase II
Development Document (see page 402).  (48) The Agency used the product
sector average BOD5_ raw waste load  in  this  calculation.   Employing
this  methodology,  the final effluent BOD5_ long-term average load was
adjusted upward to 2.0 kg/kkg (4.0 Ib/ton).

After  adjustment  of  the  BOD5_  final  effluent  load,  the  general
methodology was followed for the bag and other products product sector
as  illustrated  in  Table  VIII-8.   The mills in this product sector
where revised final effluent loads fcre attained are mills  010006  and
010008.

     Semi-Chemical   -   A   review   of   the   BPT   final  effluent
characteristics for the semi-chemical subcategory indicates  that  the
final effluent BOD5_ concentration that forms the basis of BPT for this
subcategory  is  considerably higher than for other subcategories with
comparable raw waste BOD5_ and, therefore, considerably  underestimates
the  pollutant  reduction  capability  in  this sector.  Therefore, to
determine a more realistic set of best performing mills, the BPT final
effluent BOD5_ load was revised downward based on the  relationship  of
BOD5_  influent  to  effluent  presented previously and in the Phase II
Development Document (see page 402).(48) Employing  this  methodology,
the  adjusted  final  effluent BOD5_ long-term average load becomes 1.9
kg/kkg (3.8 Ib/t).
                                405

-------
                                                      TABLE VIII-8
                                            DISCHARGE MONITORING KEPORT DATA
                                              UNBLEACHED KRAFT SUIICATEGORY
                              Final Effluent
                         Long-Tern Average Levels
Mill
Number
Linorboard
010001
010002(a)
010018
01001900
010020(a)(b)
010025(a)(b)
010032
010033
010038
010040(a)
010043
010046(a)(b)
010047
010057
010063
010064
BPT-Final
Effluent Levels
BODS Comparison
Level For NSPS
Flow
kl/kkg

46.4
52.7
54. 8
49.8
81.0
43.0
61. 5
68.1
111.3
62.3
42.6
33.3
22.0
42.9
29.3
21.7

52.5


(kgal/t)

(11.12)
(12.64)
(13.13)
(11.93)
(19.41)
(10.31)
(14.74)
(16.32)
(26.66)
(14.93)
(10.20)
(7.97)
(5.28)
(10.27)
(7.03)
(5.19)

(12.6)


BODS
kg/kkg (Ib/t)

1.8
1.4
3.1
1.1
1.1
0.5
2.5
1.9
3.6
1.3
0.7
1.3
1.9
4.2
2.6
1.8

1.9

1.6

(3.50)
(2.88)
(6.13)
(2.29)
(2.21)
(1.06)
(4.99)
(3.83)
(7.21)
(2.54)
(1.33)
(2.65)
(3.73)
(8.46)
(5.23)
(3.54)

(3.7)

(3.2)
TSS

kg/kkg (Ib/t)

3.1
2.7
3.5
2.7
1.0
0.6
2.2
0.4
6.0
1.1
5.0
0.8
0.9
2.6
5.3
3.0

3.6



(6
(5
(6
(5
(1
(1
(4
(0
(11
(2
(9
(1
(1
(5
(10
(6

(7



-14)
.44)
.97)
.47)
.99)
-11)
.30)
-77)
.98)
.20)
.91)
.69)
.81)
.24)
.54)
.02)

.2)


Start
Date

01/78
07/78
10/78
09/77
09/78
09/78
01/78
07/77
01/78
10/78
06/79
07/77
07/77
07/77
06/78
01/78




Number
Flow

36
33
11
36
13
31
06
29
40
25
20
29
38
36
34
35




Of Months
BODS

36
33
11
36
13
31
32
29
40
25
22
36
38
35
34
38




Data
TSS

36
33
11
36
13
31
32
29
40
25
22
35
38
35
34
38




Average of Milla
Attaining BFT TSS
and BODS Comparison
Level
1.3 (2.57)
2.2  (4.37)

-------
                                               TABU  VI11-8  (Continued)
                                            DISCHARGE  MONITORING  REPORT DATA
                                              UNBLEACHED KRAFT  SUBCATEGORY
                              Final Effluent
                         Long-Tens Average  Levels
Mill Flow
Number kl/kkg (kgal/t)
Bag Paper and Other
010003 52
010005 64,
01 0006 (a) 54
010008(/i) 43
010028 148
010034 84
01003S 168
010044 57
010048(a)(c) 134,
010055(a)(d) 42
010062 136
BPT-Final
Effluent Levels 52
BODS Comparison
Level For
NSPS
Average of
.4
.1
.5
.3
.6
.8
.9
.5
.7
.9
.0

.5




Mills Attaining BPT
anil BODS comparison
BODS
kg/kka (Ib/t)
TSS
kg/kkg (Ib/t)
Start
Date
Mixed Products
(12.
(15.
(13.
(10.
(35.
(20.
(40.
(13.
(32.
(10.
(32.

(12.




TSS
level
56)
35)
07)
37)
61)
31)
48)
78)
28)
28)
60)

6)






2
2
2
1
1
2
3
1
1
1
2

1


2


1
.0
.1
.0
.0
.9
.3
.4
.6
.4
.5
.5

.9


.0


.5
(4.
(4.
(3.
(2.
(3.
(4.
(6.
(3.
(2.
(3.
(4.

(3.


(4.


(3.
01)
20)
98)
02)
83)
64)
80)
19)
72)
00)
92)

7)


0)


00)
4.4
3.3
3.0
2.5
3.8
3.4
6.7
5.4
3.6
2.4
3.8

3.6





2.7
(8
(6
(5
(4
(7
(6
(13
(10
(7
(4
(7

(7





(5
.77)
.51)
.95)
.93)
.50)
.71)
.35)
.88)
.22)
.85)
.67)

.2)





.44)
12/78
06/79
07/77
07/77
03/79
01/78
12/78
09/78
02/80
06/80
07/77








                                                                                                    Number Of Months Data
                                                                                                            BODS ""   TSS
                                                                                                    Flow
25
22
42
23
23
37
27
24
16
07
45
25
22
42
39
23
37
28
24
16
07
45
25
22
42
39
23
37
28
24
16
07
45
(a)  TSS is less than or equal  to  BPT;  BODS  is  less  than or equal  to the BODS Comparison Level.
(t>)  Data are not included in the  averages because treatment includes an oxidation pond.
(c)  Data are not included in the  averages because mill  employs  a  two stage biological treatment system.
(J)  Mill is not included in the averages because  less  than 12 mouths of data are available.

-------
After  adjustment  of  the  BOD5_  final  effluent  load,  the  general
methodology was applied as illustrated in Table VIII-9.  Mills in this
subcategory  where  revised  effluent limitations are attained include
mills 060004, 020003, and 020009.  In addition  to  these  mills,  two
additional  mills  (020011  and  110068)   which  discharge  to a joint
treatment system were included  in  the  calculation.   A  significant
portion  of the wastewater discharged to the joint treatment system is
associated with the production of semi-chemical  pulp.   The  approach
used  to  include data for these mills involved comparing BOD5_ and TSS
effluent loads to BPT limitations determined by prorating  limitations
from appropriate subcategories.  The percentage reductions attained at
these  mills  were  then  applied  to  the  revised  semi-chemical BPT
effluent limitations.  Effluent BOD5_ and TSS characteristics for mills
020011  and  110068  are  36.7  and  34.9   percent   below   prorated
limitations.

     Unbleached  Kraft  and  Semi-Chemical - A review of the BPT final
effluent characteristics for the unbleached  kraft  and  semi-chemical
subcategory  indicates that the final effluent BOD5_ concentration that
forms the basis of BPT for this  subcategory  is  considerably  higher
than  for  other  subcategories  with  comparable  raw waste BOD5_ and,
therefore,  considerably  underestimates   the   pollutant   reduction
capability  in  this sector.  Therefore,  to determine a more realistic
set of best performing mills, the BPT final  effluent  BOD5_  load  was
revised  downward  based  on  the  relationship  of  BOD5_  influent to
effluent presented previously and in the Phase II Development Document
(see page 402).(48) Employing this  methodology,  the  adjusted  final
effluent BOD5_ annual average load becomes 1.9 kg/kkg  (3.7 Ib/t).

After  adjustment  of  the BOD5_ effluent load, the general methodology
was applied as illustrated in  Table  VIII-10.   Mills  where  revised
effluent limitations are attained include mills 015001 and 015004.

     Papergrade  Sulfite  (Papergrade  Sulfite  (Blow  Pijt  Wash)  and
Papergrade Sulfite (Drum Wash)  Subcategories)  -  In  reviewing  this
subcategory,  as  discussed  in Sections IV and V, EPA determined that
wastewater discharge is a function of the percentage of  sulfite  pulp
manufactured  on-site.   In  Section V, a mathematical relationship is
presented based on mill  data  that  relate  wastewater  flow  to  the
percentage  of sulfite pulp produced on-site.  From this relationship,
theoretical wastewater flows  were  obtained  for  each  mill  in  the
subcategory  based  on the percentage of sulfite pulp produced at each
mill.  Using the  calculated  wastewater  flow  and  actual  long-term
average  BOD5_  and  TSS  final effluent loads for each mill, long-term
average BOD5_ and TSS  final  effluent  concentrations  were  computed.
These  individual  values were compared to BOD5_ and TSS final effluent
concentrations of 51 mg/1  and  70  mg/1,  respectively  (the  highest
long-term   average  concentrations  that  formed  the  basis  of  BPT
regulations for the  two  papergrade  sulfite  subcategories).   Mills
where  the  calculated final effluent concentrations are lower than 51
mg/1 of BOD5_ and 70 mg/1 of  TSS  were  selected  as  best  performing
mills.   Five  mills (040001, 040011, 040013, 040015, and 040019) were
found to be best performers; however, as illustrated  in Table VIII-11,
                                408

-------
                                                      TABLE VI]1-9
                                            DISCHAKGE MONITORING REPORT DATA
                                                SEMI-CHEMICAL SIIBCATECORY
                              Final Effluent
                  	Long-Term Average Levels    _
Mill
Flow
Number kl/kkg (kgal/t)
020001
020002
020003(a)
020004(a)(b)
020006
020007
020008(a)(c)
020009 (a)
020010
0200il(a)(d)
020012
020014
020015
020016
020017
060004(a)
900011
BHT-Final
Effluent Level
BODS Comparison
Level For
NSPS
26.1
25.4
40.5
24.4
13.6
11.2
11.7
28.5
23.6
17.6
31.5
26.5
34.5
37.9
18.7
36.9
49.8

42.9



(6
(6
(9
(5
(3
(2
(2
(6
(5
(4
(7
.26)
.08)
.71)
.84)
.26)
.69)
.80)
.84)
.65)
.22)
.55)
(6.35)
(8
(9
(4
(8
(11

(10



.27)
.09)
.47)
.85)
.94)

.3)



BODS
kg/kkg (Ib/t)
3
3
0
1
2
3
1
1
2
1
3
3
11
2
2
1
4

3


1
. 1
.4
.4
.4
.7
.1
.1
.9
.0
.2
.7
.8
.1
.6
.5
.3
.3

.2


.9
(6
(6
(0
(2
(5
(6
(2
(3
(3
(2
(7
(7
(22
(5
(4
(2
(8

(6


(3
.10)
.88)
.71)
.80)
-41)
.28)
-11)
.80)
.94)
.40)
.46)
.54)
.13)
.19)
.99)
.53)
.54)

.4)


.8)
TSS
kg/kkg (Ib/t)
4
3
1
0
4
3
2
3
3
2
6
7
11
4
2
1
6

4



.5
.7
.5
.6
.4
.1
.2
.4
.3
.6
.4
.1
.8
.6
.7
.3
.4

.1



(8
(7
(2
(1
(8
(6
(4
(6
(6
(5
(12
(14
(23
(9
(5
(2
(12

(8



.93)
.49)
.95)
.29)
.89)
-11)
.30)
.75)
.51)
.27)
.76)
.10)
.67)
.25)
.36)
.61)
.85)

.1)



Average of Mills
Attaining BPT TSS
and BOD5 Comparison
Level
                                                                           Start
                                                                           Date^

                                                                           12/77
                                                                           07/78
                                                                           04/78
                                                                           01/78
                                                                           05/78
                                                                           07/77
                                                                           08/78
                                                                           10/78
                                                                           10/78
                                                                           11/78
                                                                           07/77
                                                                           07/78
                                                                           06/79
                                                                           06/80
                                                                           07/78
                                                                           10/78
                                                                           08/77
Number Of f!on_t_hs_ Da ta
Flow"   BOI)5  ""  TSS
20
29
25
39
36
27
28
27
30
27
44
30
22
07
29
27
33
20
29
25
39
36
23
28
26
30
28
43
30
22
07
29
27
31
20
29
25
39
;)6
23
28
27
30
28
43
:io
22
07
29
27
31
                                 1.2  (2.36)    2.2  (4.40)
(a)  TSS is less than or equal to BPT; BOD5 is less than or equal to the BODS Comparison  Level.
(b)  Data are not included in the average because mill employs inverse osmosis.
(c)  Data are not included in the average because this mill occasionally spray  irrigates  some  effluent.
(J)  This semi-chemical mill shares a joint treatment system with a paperboard  from wastepapcr mill.   It  contributes
     approximately 46 percent of the total production of both mills.  Prorated  BPT was determined.   The percent
     effluent BOD5 and TSS reductions being attained were then applied to the BPT TSS effluent level  and  BOO1)
     comparison level for the subcategory to obtain the effluent levels shown.

-------
                                                      TABLE VIII-10
                                            DISCHARGE MONITORING REPORT DATA
                                    UNBLEACHED KRAFT AND SEMI-CHKMICAL SUBCATEGORY
                              Final Effluent
                         Long-Term Average Levels
Mi 11
Flow
Number kl/kkg (kgal/t)
010017
015001 (a)
015002 (b)
015003
015004(a)
015005
015006
01 SOO 7
01 '.009 (c)
BrT- Final
Effluent Levels
BODS Comparison
Level For
NSHS
37.3
43.6
36.3
41.4
52.9
36.7
47.6
56.3
51.0

58.4



(8.94)
(10.46)
(8.70)
(9.91)
(12.68)
(8.80)
(H-41)
(13.48)
(12.23)

(14.0)



BODS
kft/kkg (lb/t)
2.6
1.9
1.7
3.9
0.9
2.4
3.3
2.1
4.8

3.0


1.9
(5.23)
(3-70)
(3.32)
(7.78)
(1-70)
(4.84)
(6.69)
(4.14)
(9.55)

(5.9)


(3.7)
TSS
kg/kkg (lb/t)
4.1
3.1
3.8
2.7
1.6
1.6
4.3
5.1
5.2

3.6



(8
(6
(7
(5
(3
(3
(8
(10
(10

(7



.25)
-19)
.50)
.39)
.20)
.14)
.64)
.18)
.38)

-1)



Start
Date
03/78
01/78
09/77
01/78
06/79
01/78
01/78
10/78
07/77





Number
Flow
34
39
42
40
13
32
38
29
18





Of Months Data
BODS
34
39
41
40
13
32
38
29
18





TSS
34
39
41
40
13
32
38
29
18





Average of Hills
Attaining BrT TSS
anil BODS Comparison
Level
1.4 (2.70)
2.4  (4.70)
(a)  TSS is less than or equal to BPT; BODS is less than or equal to BODS Comparison Level.
(b)  Mill discharges some effluent to percolation ponds in the summer.  Data are not representative of
     entire effluent discharge.
(c)  Mill now produces bleached kraft products.  Data presented .ire for the period prior to addition of
     bleaching processes.

-------
                                                      TABLE VI 1J- 11
                                            DISCHARGE MON1TOKING KKPORT DATA
                                             PAPKRGRADE SULFITE SUUCATEGORY

                              Final Effluent
                       	Long-Term Average Levels

                                                                           Stdrt
                                                                           Date

                                                                           07/77
                                                                           07/79
                                                                           07/80
                                                                           07/77
                                                                           04/80
                                                                           07/77
                                                                           11/79
                                                                           06/78
                                                                           06/77
                                                                           07/77
                                                                           07/77
                                                                           06/79
                                                                           09/79

BHT final effluent levels are based on the processes used to manufacture sulfite pulp.
Mill
Nurher
040001 (d)(e)
040002
040008(b)
04()OIO(c)
040011(d)(e)
040012
0400 1 3 (e)
0400 1 5 (e)
040016
040017
040018(1)
04()019(e)(g)
040()09(e)(h)
Flow
kl/kkg (kgal/t)
123.
305 .
219.
258.
60.
258.
100.
40.
116.
84.
85.
45.
89.
3
3
1
3
9
1
9
1
4
3
7
3
3
(29
(73
(52
(61
(14
(61
(24
(9
(27
(20
(20
(10
(21
.55)
.16)
.51)
.90)
.60)
.85)
-17)
.62)
.89)
• 21)
.53)
.86)
.41)
BODS
TSS
kg/kkg (lb/t) kg/kt
10
14
10
6
1
11
4
12
6
5
1
2
1
.7
.9
.3
.4
.4
.1
.5
.3
.5
.3
.8
.8
.5
(21.
(29.
(20.
(12.
(2.
(22.
(8.
(24.
(13.
(10.
(3.
(5.
(2.
.30)
86)
52)
72)
89)
21)
95)
68)
07)
57)
61)
66)
95)
9.1
25.4
12.4
6.1
2.5
14.2
7.4
12.7
14.9
10.0
1.7
3.5
4.8
ig (lb/t)
(18.
(50.
(24.
(12.
( 4.
(28.
(14.
(25.
(29.
(20.
( 3.
( 7.
( 9.
10)
,78)
,89)
15)
,92)
30)
88)
,34)
74)
09)
48)
,09)
66)
                                                                                    Number Of Months Data
Flow
32
19
9
46
14
31
17
36
35
45
27
19
21
BOD5
34
21
9
46
14
33
17
36
16
45
27
19
21
TSS
3.5
21
9
45
14
32
17
36
44
45
27
19
21
NSHS
Comparison Levels   *      *       51  mg/1

Calculated Comparison Level Flows
anil Theoretical Concent rat ions (i ):
 040013
 040015
 040019
137.0 (32.83)
289.4 (69.35)
128.0 (30.67)
32.69 mg/1
42.67 mg/1
22.13 Bg/1
                               70 »g/l
54.35 mg/1
43.81 mg/1
27.72 Bg/1
 Average Concentration
                   32.5   mg/1   42.0  mg/1
Option 1 Long-Term Average Final Effluent

B005 (kg/kkg) =1.72 exp (0.017x)
TSS (kg/kkg) = 2.22 exp (0.017x)
Where x equals the percent sulfite pulp
produced on-site.
                                                                                                Levels:
(a)  Data are not considered in the average because pulp is not bleached at this Bill.  Mill is now closed.
(h)  Data are not considered in the average because less than 12 months data are available.
(c)  Data are not considered in the average because glassine papers are produced at
     this will which is not typical of the subcategory.
(J)  Data are not considered in the average because mill employs .1 2-stage biological treatment system.
(c)  Theoretical concent rations are below the NSPS comparison levels.
(f)  Pulp Bill wastes are discharged to a POTW.
(g)  A portion of the wastewater discharge is not treated in the biological treatment system.
(h)  This papergrjde sulfite mill shares a joint treatment system with an alkaline-fine mill.  It contributes approx-
     mjtely 48 percent of the total production of both mills.  Prorated BPT was calculated and this mill was found
     to tueet BPT levels.  Data for this mill were not considered in the averages as the final effluent  is not
     typical of the subcategory.
(i)  The theoretical concentration is equal to the long-term aver.ige (lb/t) divided by (the theoretical comparison
     level flow for the mill times 0.00834 Ib/kgal).

 "   Comparison Level flow is based on the following equation rel.iting flow (kgal/t) to percent sulfite pulp (x)
     (produced on-site) in the final product, with theoretical concentrations calculated using this equation and
     the annual .iverage discharge levels reported above for each mill:
     flow (kgjl/l) = 12.67e
     How (k]/kks) = 52.87e
           0.017x
           0.017x

-------
mill 040011 was excluded from the calculation  because  its  treatment
system,  a  two  stage  biological  system,  is  not  considered to be
sufficiently representative of the technology on which BPT  is  based.
Mill 040001 was also excluded from the calculation because pulp is not
bleached at this mill.

Long-term  average  NSPS Option 1  loads were calculated as the product
of the average of the long-term average concentrations  of  the  three
mills   which   were  found  to  be  best  performers,  and  the  flow
corresponding to that calculated from the relationship  shown  in  the
footnote  to  Table  VIII-11.   The flow and, therefore, the long-term
average NSPS Option 1 loads will vary from mill to mill  depending  on
the percentage of sulfite pulp produced at a given mill.

     Dissolving  Sulfite  Pulp - As no best performing mills have been
identified in the dissolving  sulfite  pulp  subcategory,  the  Agency
relied  on  transfer  of  mill  performance  in the papergrade sulfite
subcategories to  determine  long-term  final  effluent  loads.   NSPS
Option  1  effluent  loads  were  determined by applying the following
methodology:

a.   The average TSS reduction of  40.0  percent  for  the  papergrade
     sulfite  subcategories  has  been  transferred  directly  to  the
     dissolving sulfite pulp subcategory.

b.   The long-term average BOD5_ effluent  concentrations  that  formed
     the basis of BPT for papeFgrade sulfite mills 040013, 040015, and
     040019   are   42,   50,   and   47  mg/1,  respectively.   These
     concentrations and the flow relationship shown in the footnote on
     Table VIII-11 were used to determine a  baseline  BOD5_  long-term
     average load for each mill.                          ~

c.   The percentage reduction  of  BOD5_  discharge  at  mills  040013,
     040015,  and  040019  were compared to the baseline calculated in
     "b" above.

d.   This reduction of 29.9 percent was applied to each product sector
     of the dissolving sulfite pulp  subcategory  to  yield  the  NSPS
     Option 1 long-term average BOD5_ loads.

Table  VIII-12  illustrates the calculation of NSPS Option 1 long-term
average loads and presents available discharge data for the dissolving
sulfite pulp subcategory.  EPA has determined that the characteristics
and  treatability  of  wastewaters  discharged  from  mills    in   the
dissolving  sulfite  pulp and the papergrade sulfite subcategories are
similar.   In fact, BPT effluent  limitations  for  both  subcategories
were  developed  from  the  same  relationship  between BOD5_ raw waste
concentrations and BOD5_ final effluent concentrations. (48)  Therefore,
the  Agency  believes  that  new dissolving sulfite pulp mills will be
able  to  attain  the  long-term  average  discharge   characteristics
presented  in Table VIII-12.
                                412

-------
CO
                                                                    TABLE  VI11-12
                                                          DISCHARGE  MONITORING REPORT DATA
                                                         DISSOLVING  SULFITE PULP SUBCATEGORY
                                                 Final Effluent
                                            Long-Tern Average Levels
Mill
Flov
Number kl/kkg
046001
046002
046003
046O04(a)
046005
046006
BPT final cffl ut
Nitration
Viscose
Ce 1 lophane
Acetate
224
397
277
174
352
135
275
275
275
303
.0
.0
.5
.5
.5
.0
.0
.0
.0
.4
BOD*
(kgal/t) kg/kkg
(53,
(95
(66,
(41,
(84
(32
(66.
(66
(66
(72
.68)
.14)
.50)
.82)
.47)
.36)
.0)
.0)
.0)
.7)
35.
47.
40.
10.
41.
.4
6
, 1
.3
.1
(Ib/t)
(70.
(95.
(80.
(20.
(82.
86)
17)
26)
.68)
.28)
TSS
kg/kkg (Ih/t)
22.
42.
11.
28.
51.
26.2 (52.30) 14.
*nd on grade of pu Ip •
12.1 (24.2) 20.
13,
14.
17,
.0
.1
.8
(25.
(28.
(35.
9)
,1)
.5)
20.
20.
20.
4
3
9
9
7
2
a
9
9
9
9
(44.74)
(84.59)
(23.74)
(57.86)
(103.32)
(28.40)
nu f a c tii red ,
(41.8)
(41.8)
(41.8)
(41.8)
 Stjrt
_Da_te	

 07/77
 01/79
 12/80
 04/79
 11/79
 07/77
                                                                                                                       Number Of Months Data
                                                                                                                       Flow 	BOD5	TSS
                                                                                                                        41
                                                                                                                        26
                                                                                                                         7
                                                                                                                        18
                                                                                                                        14
                                                                                                                        42
                                                                                                             43
                                                                                                             26
                                                                                                              7
                                                                                                             18
                                                                                                             14
                                                                                                             42
43
26
 7
17
14
42
                                                                                   as follows:
Basis tor Determining NSPS Coaparlson Leveli(b)
 040013                           42 «g/l        70
 040015                           50 mg/1        70 ng/1
 040019                           47 ng/1        70 Bg/1

Average
Percentage
Below Comparison
Level to be Appl ied
to Dissolving Sulfite
Pulp Suhcatpgory(c)               29.9          40.0

Option 1 long-tern average final effluent  levels depend  on grade of pulp Manufactured, as follows:
Ni t rat ion
Viscose
Cel lophane
Acetate
8.5 (16.96)
9.1 (18.15)
9.9 (19.70)
12.4 (24.88)
12.5 (25.08)
12.5 (25.08)
12.5 (25.08)
12.5 (25.08)
                   (a) This nill shares a joint treatnent system with a paper Bill.
                   (b) Concentrations are those forcing the basis of BPT for these papergrade aulfite Billtt and are process-dependent.
                   (c) These are the average percentages below BIT concentration bases (reported above) of the theoretical concentrations
                       shown on Table VIII-11.

-------
     Groundwood-Thermo-Mechanical  -  As illustrated in Table VIII-13,
the general methodology was followed;   BPT  effluent  limitations  are
being attained at mill 070001.

     Groundwood-Fine  Papers  -  As  illustrated in Table VIII-14, the
general methodology was followed.  BPT effluent limitations are  being
attained  at  mills  052003,  052007,   052008,  052014,  and 054014.  In
addition to these mills,  another mill  (052009)   was  included  in  the
calculation.  At this integrated miscellaneous mill where BPT effluent
limitations  are  attained, groundwood pulp is produced, a significant
portion of which is used to manufacture  fine  papers.    The  approach
used  to  include  data  for this mill involved comparing BOD5_ and TSS
effluent  loadings  to  BPT  limitations   determined   by   prorating
limitations from appropriate subcategories.  The percentage reductions
attained  at this mill were then applied to groundwood-fine papers BPT
limitations.  Effluent BOD5_ and TSS characteristics  for  mill  052009
are 14.6 percent and 26.5 percent below prorated BPT limitations.

Upon  calculation  of  the  concentration of BOD5_ corresponding to the
flow that forms the  basis  of  BPT  for  the  groundwood-fine  papers
subcategory,   EPA   determined   that  the  resulting  BOD5_  effluent
concentration  was  below  15  mg/1.   Therefore,  the   corresponding
long-term  average  BOD5_ effluent concentration and effluent load were
revised upward as shown in Table VIII-14.

     Groundwood-CMN Papers - As  illustrated  in  Table  VIII-15,  the
general   methodology   was  followed  in  establishing  BPT  effluent
limitations.  At mill 054015, BPT effluent limitations  are  attained.
For  the  nine  month  period  prior  to  December 1978, the long-term
average TSS for this mill was 2.2  kg/kkg  (4.4  Ib/t).   In  November
1978,  the NPDES authority increased the allowable TSS discharge.  For
the period after November  1978,  the  long-term  average  TSS  is  5.2
kg/kkg  (10.4  Ib/t).  This mill has demonstrated that 2.2 kg/kkg (4.4
Ib/t) can be attained.  Therefore, the long-term TSS effluent load  is
based on performance at mill 054015 prior to December  1978.

Upon  calculation  of  the  concentration of BOD5_ corresponding to the
flow that forms  the  basis  of  BPT  for  the  groundwood-CMN  papers
subcategory,   EPA   determined   that  the  resulting  BOD5_  effluent
concentration  was  below   15  mg/1.   Therefore,  the   corresponding
long-term  average  BOD5_ effluent concentration and effluent load were
revised upward as shown in Table VIII-15.

     Deink - As shown in Table VII1-16,  three  product  sectors  have
been considered: fine papers, tissue papers, and newsprint.

For  the deink-fine papers product sector, the general methodology was
followed.  BPT  effluent   limitations  are  being  attained  at  mills
140007, 140008, and  140019.

For  the  deink-tissue  papers product sector, the general methodology
was followed, although mills 140018 and  140030 were  not  included  in
the  calculation  of  attainable  effluent  levels.    Mill   140018 was
                                  414

-------
                                                      TABLE  VIIJ-13
                                            DISCHARGE  MONITORING  REPORT DATA
                                        GKOUNDWOOD-THERMO-MECHANICAL SUBCATEGORY
                              Final  Effluent
                     	Long-Term Average  Levels
Mi 1 1 Flow
Number kl/kkg (kgal/t)
070001(a) 87,9 (21.07)
070002 33,8 (8,10)
BIT-Final
Effluent Levels 88.0 (21.1)
BODS Comparison
Level for NSPS
Average of Hills'
Attaining BPT
TSS and BODS
Comparison Level
BODS TSS
kg/kkg (lb/t) kg/kkg (Ib/t)
1.6 (3.18) 2.1 (5.45)
3.6 (7.29) 6.2 (12.38)
3.1 (6.2) 4.6 (9.2)
2.3 (4.5)
1.6 (3.18) 2.7 (5.45)
Start Number Of Months Dal
Date Flow BODS TS!
05/79 20 20 20
06/79 22 22 22



(a) TSS ia less than or equal to  BPT;  BODS  is  less  than or equal  to the BODS Comparison Level.

-------
O1
                                                                          TABLE  VIII-14
                                                                DISCHARGE MONITORING REPORT  DATA
                                                               GROUNDWOOD-FINE PAPERS  SUBCATEGORY
                                                  Final Effluent
                                              Long-Tera Average Levels
Hill
Number
052003(a)
052004
052007(a)
052008(a)
052009(a)(b)
052014(a)
054014(a)
BPT-rinal
Effluent Levels
Flow
kl/kkg (kgal/t)
71.6 (17.16)
53.8 (12.89)
78.7 (18.87)
41.3 (9.89)
78.5 (18.82)
37.1 (8.89)
J5.6 ( 8.52)

91.0 (21.9)
BODS
kg/kkg (Ib/t)
0.8 (1.64)
2.2 (4.47)
0.9 (1.87)
0.4 (0.87)
1.7 (3.41)
0.3 (0.57)
1.3 (2.50)

2.0 (4.0)
TSS
kg/kkg (Ib/t)
3.0 (5.94)
3.1 (6.11)
2.6 (5.14)
1.3 (2.53)
2.5 (5.07)
0.4 (0.74)
2.3 (4.61)

3.5 (6.9)
Start
Date
08/77
09/77
01/78
01/78
07/77
02/78
05/78


                    Average  of Mills
                    Attaining BPT
                    BODS  and TSS

                    Option  1
                    Adjusted BOOS
0.9 (1.81)
1.4 (2.74)
2.0 (4.01)
                                                                                                                         Nuaber Of Months Data
                                                                                                                         Flow
                                                                                                                           8
                                                                                                                          45
                                                                                                                          38
                                                                                                                          36
                                                                                                                          37
                                                                                                                          39
                                                                                                                          33
                                                                                                                                 BODS
                                                                             41
                                                                             45
                                                                             38
                                                                             36
                                                                             30
                                                                             39
                                                                             33
                                                                                                                                          TSS
                                                                      41
                                                                      45
                                                                      38
                                                                      33
                                                                      30
                                                                      40
                                                                      33
                     (a)   TSS  and  BOD5  ate  less  than  or equal to BPT.
                     (b)   Mill  is  an  integrated  miscellaneous mill where groundwood-fine papers  comprise  .ipproximately  66  percent
                          of the production.   Prorated BPT was determined.  The percent effluent  BOD5 and TSS
                          reductions  being  attained were  then applied to BPT BOD5 and TSS effluent  levels for  the  subcategory
                          to obtain  the effluent levels shown.

-------
                                                      TABLE  VIII-15
                                            DISCHARGE MONITORING  RKPORT DATA
                                            CROUNDWOOD-CMN PAPERS SUBCATECORY
                              Final Effluent
                         Long-Tern Average Levels
Hi 11
Number
052015
01>40I5(a)(b)
0540I5(I>)
Flow BODS
kl/kkg (kgal/t) kg/kkg (It./t)
69.0 (16.53) 3.8 (7.68)
109.5 (26.25) 1.0 (1.99)
112.2 (26.89) 1.2 (2.48)
TSS
kg/kkg (Ib/t)
2.8 (5.57)
2.2 (4.41)
5.2 (10.44)
                                                                            Start
                                                                            Oate__

                                                                            01/78
                                                                            01/78
                                                                            12/78
                                                                    Number Of Months
                                                                    Flow    BOD5
                                                                      24
                                                                       9
                                                                      25
                                                               25
                                                                9
                                                               25
JJata
TSS

 25
 11
 25
Rl'T-Filial
F.I fluent Levels 99.0  (23.8)

Average of Mills
Al (.lining BPT
B01)r> and TSS

Option  I
Ad jus led BOD5
2.2 (4.4)



1.2 (2.35)(b)


1.5 (2.98)
3.8  (7.5)
 2.2 (4.41)
(a)  TSS and 601)5 are  less than or equal to BPT.
(li)  Hill operated at  the  lower effluent levels  listed  above until  their permitted TSS limits were  relaxed,  after  which
     it operateil jt the higher levels.  Long-term average  BOD5 wa;. determined by averaging data over  the  entire  period for
     which there are DMR data (weighted average  of  the  two  perioils).

-------
                                                                           TABLE VIII-16
                                                                 DISCHARGE MONITOKING KEPORT  DATA
                                                                         DEINK SUBCATI.GORY
CO
                                                   Final Effluent
                                              Long-Tera Average Levels	
Mi 1 1
Nuinlx'r
FI'IK- Papers
1 4000 7 ( j )
140008 (a)
I400l'j(a)
BrT-Final
hi Hue nt
Levels
Flow BODS TSS
kl/kkg (kgal/t) kg/kkg (Ib/t) kg/kkg (Ib/t)

48.0 (11.50) 2.2 (4.37) 4.0 (8.00)
55.5 (13.29) 3.2 (6.45) 3.2 (6.43)
11.2 (7.48) 2.0 (3.98) 3.8 (7.50)


102.0 (24.4) 5.3 (10.6) 7.1 (14.2)
Start
Date

03/78
07/77
07/77

^

Number
Flow

39
46
44



Of Hon
BOD5

39
46
43



Average of Mil Is
Attaining BPT
BOI)r> and TSS
Newsprint
90001/(a)(b)
BPT Kinal
El fluent
l.tvels
Tissue Papers
1400l4la)
14001.S(a)
140018(a)(c)
140021 (a)
140022
140024
140025(a)
1400:iO(a)(d)
900015(a)
900018
'JO 00 20
BHT- Final
F.I t 1 lien I
I.f ve 1 s
Average of
Mills
AUjining BPT
BOD5 arid TSS
(j) TSS and

2.5 (4.93) 3.7 (7.31)

56.1 (13.44) 1.4 (2.82) 1.1 (2.18)


102.0 (24.4) 5.3 (10.6) 7.1 (14.2)

84.3 (20.20) 4.4 (8.75) 7.1 (14.14)
94.6 (22.67) 3.4 (6.84) 4.7 (9.43)
17.6 (4.22) 3.1 (6.20) 1.4 (2.84)
100.1 (23.99) 2.2 (4.40) 4.1 (8.16)
108.7 (26.06) 12.4 (24.75) 5.1 (10.16)
7.9 (1.90) 12.1 (24.14) 7.2 (14.40)
57.9 (13.87) 4.3 (8.68) 4.5 (8.92)
68.1 (16.33) 2.0 (3.91) 2.5 (5.05)
39.4 (9.43) 2.3 (4.53) 2.3 (4.53)
55.0 (13.18) 8.1 (16.25) 2.7 (5.40)
134.4 (32.20) 9.1 (18.26) 15.4 (30.76)


102.0 (24.4) 5.3 (10.6) 7.1 (14.2)



3.3 (6.64) 4.5 (9.04)
BOD5 are less than of equal to BPT.
(b) This mill employs chemically assisted secondary clarificatii
Option I
(c) Data are
(,)) Data are
final effluent loads.
nut included in the average because less than 12 m<
not included in the average because only a small p.



01/80




07/77
11/77
12/79
09/77
03/79
07/77
04/78
07/77
02/79
07/77
01/79








>n. Data were not iif:ed in

>nths data are available.
•rcentage of deinked pulp



15




44
43
10
42
26
44
26
45
22
29
24








developing NSPS


is produced.



15




44
43
9
42
26
44
26
47
22
45
24












                                                                                                                                           TSS
                                                                                                                                            39
                                                                                                                                            46
                                                                                                                                            44
                                                                                                                                            15
                                                                                                                                            44
                                                                                                                                            43
                                                                                                                                            10
                                                                                                                                            42
                                                                                                                                            26
                                                                                                                                            44
                                                                                                                                            26
                                                                                                                                            47
                                                                                                                                            22
                                                                                                                                            45
                                                                                                                                            24

-------
eliminated because insufficient data were available; mill  140030  was
eliminated  because  of a very low on-site production of deinked pulp.
Mills 140014, 140015, 140021, 140025, and 900015 are included  in  the
calculation of long-term effluent loads.

At  the time of promulgation of BPT effluent limitations for the deink
subcategory, there  were  no  direct  discharging  deink  mills  where
newsprint was produced.  Now there is only one direct discharging mill
in  the deink-newsprint product sector.   It is not appropriate to base
NSPS  Option  1  effluent  loads  for  this  product  sector  on   the
performance  of this mill because the end-of-pipe treatment technology
employed is more  advanced  than  that  identified  as  BPT  for  this
subcategory.

The  manufacture  of  newsprint from deinked newsprint is a relatively
new  papermaking  process.   Flow  and  BOD5_  raw   waste   loads   at
deink-newsprint  mills  are  considerably lower than those that formed
the basis of BPT effluent limitations for the deink subcategory.   EPA
determined  NSPS  Option 1 final effluent loads based on the predicted
performance of biological treatment  applied  to  the  deink-newsprint
sector  average  BOD5^  raw  waste  concentration.  This methodology is
described in detail previously in this section in the  discussions  of
the  best  practicable  control  technology currently available.  NSPS
Option 1 long-term average BODI3 and TSS effluent loads were calculated
as the product of the long-term average final effluent  concentrations
and the average flow for the product sector.

     Tissue   from   Wastepaper   -  In  the  tissue  from  wastepaper
subcategory, extensive use of production process  controls  to  reduce
wastewater discharge is practiced.  NSPS Option 1 for this subcategory
is  identical  to  NSPS  Option  2  and  includes  the  application of
production process controls and biological treatment.  The methodology
for development  of  long-term  average  effluent  characteristics  is
described  in  detail  later  in  this  section  (see  NSPS Option 2).
Available effluent data for mills in this subcategory are presented in
Table VIII-17.

     Paperboard from Wastepaper - In the  paperboard  from  wastepaper
subcategory,  extensive  use  of production process controls to reduce
wastewater discharge is practiced.  NSPS Option 1 for this subcategory
is identical  to  NSPS  Option  2  and  includes  the  application  of
production process controls and biological treatment.  The methodology
for development of long-term average effluent characteristics for both
subdivisions  of this subcategory is described in detail later in this
section (see NSPS Option 2).  Available effluent  data  for  mills  in
both subdivisions of this subcategory are presented in Table VIII-18.

     Wastepaper-Molded  Products  -  In the wastepaper-molded products
subcategory, extensive use of production process  controls  to  reduce
wastewater discharge is practiced.  NSPS Option 1 for this subcategory
is  identical  to  NSPS  Option  2  and  includes  the  application of
production process controls and biological treatment.  The methodology
for development  of  long-term  average  effluent  characteristics  is
                                419

-------
PO
o
                                                                           TABLE VII1-17
                                                                 DISCHARGE MONITORING REPORT DATA
                                                                TISSUE FROM WASTEPAPEK SUBCATEGORY(a)
                                                   Final Effluent
                                              Long-Term Average Levels
Mil 1
Number
085004(g)
090002(b)(g)
090004(K)
090010(c)(g)
0
-------
                                                                          •IABLE VIII-18
                                                                DISCIIARGK MONITORING KKPORT DATA
                                                             HAPERBOAKD FROM WASTKPAMiR SUBCATEGORY(a)
-b
no
                                                  Final Effluent
                                              Long-Term Average Levels	
Hill
Number
Flow
kl/kkg (kgal/t)
BODS
TSS
kg/kkg (Ib/t) kg/kkg (Ib/t)
Nuncor ruga ting Medium Furnish
1 10001 00 (i)
1 10019(i)
1 10020
I10022(b)
110023
1 10031 (i)
110032(c)(i)
110034(i)
110043(i)
1 10052(i)
110060(d)
H0061(e)(i)
110062(i)
110067(1)
11006y(i)
110070(i)
110074(i)
1 J0077(i)
110080
110094(1)
20
29
35
68
11
7
25
6
17
23
2
19
10
15
29
18
3
2
32
21
.7
.9
.8
. 1
.9
.6
.8
.0
.1
.8
.6
.6
.4
.4
.3
.7
.8
.3
.6
.8
(4.
(7.
(8.
(16.
(2.
(1.
(6.
(1.
(4.
(5.
(0.
(4.
(2.
(3.
(7.
(4.
(0.
(0.
(7.
(5.
96)
16)
57)
31)
85)
83)
18)
44)
09)
71)
63)
69)
49)
69)
01)
49)
91)
54)
82)
23)
110096(i) — (f)
110IOO(d)(g)
110)03(c)(i)
1 10104(h) (i)
1 101 10(1)
1 I0113(i)
110119
-
18
1
4
17
12
--
.5
.0
.9
.3
.1
--
(4.
(0.
(1.
(4.
(2.
-
44)
23)
18)
14)
91)
0
1
0
1
1
0
0
1
0
0
2
0
0
0
0
0
0
0
2
0
0
4
0
1
0
0
2
. 1
.0
.8
.7
.3
.1
.9
.1
.8
.4
.2
.8
.5
.4
.2
.3
.1
.2
.8
.5
.1
.4
.2
.1
.2
.8
.7

(0
(1
(1
(3
(2
(0
(1
(2
(1
(0
(4
(1
(1
(0
(0
(0
(0
(0
(5
(0
(0
(8
(0
(2
(0
(1
(5

.27)
.97)
.66)
.46)
.58)
.27)
.76)
.11)
.56)
.77)
.45)
.58)
.09)
.86)
.46)
.57)
.24)
.33)
.62)
.95)
.15)
.83)
.35)
.27)
.39)
.69)
.34)

0
1
1
2
1
0
1
0
1
0
0
1
0
0
0
0
0
0
2
0
0
1
0
0
0
1
0

.3
. 1
.4
.2
.3
.2
.1
.8
.2
.5
.2
. 1
.6
.8
.7
.3
.3
.2
.8
.7
.0
.5
.3
.4
.8
.6
.5

(0.67)
(2.28)
(2.79)
(4.45)
(2.62)
(0.38)
(2.21)
(1.56)
(2.32)
(1.02)
(0.36)
(2.28)
(1.21)
(1.63)
(1.48)
(0.52)
(0.62)
(0.41)
(5.57)
(1.35)
(0.04)
(3-04)
(0.66)
(0.70)
(1.61)
(3.22)
(0.93)
                                                                                               Start
                                                                                               Date
07/77
OS/77
08/77
01/78
07/77
07/77
04/78
05/79
07/77
09/77
04/78
07/77
01/79
07/78
01/79
07/77
09/78
01/78
01/80
07/77
10/78
05/78
02/79
01/79
04/79
07/77
07/78
                         Number Of Months Data
                         Flow"   UOU3     TSS
37
25
41
20
45
42
34
22
29
13
16
46
27
29
24
43
30
15
14
45
27
0
26
24
25
46
9
:)6
:n
42
20
4r>
41
ts
16
43
It
16
46
27
:io
25
43
30
15
14
45
27
8
26
27
25
46
21
38
38
42
20
45
42
35
17
43
13
16
46
27
30
25
40
30
15
14
45
27
8
26
27
25
46
21

-------
ro
ro
                                                                     TABLE VilI-18 (Continued)
                                                                 DISCHARGE MONITORING KEPORT DATA
                                                              PAPERBOARD FROM WASTEPA1 ER SUBCATEGORY
                                                   Final  Effluent
                                              Long-Term Average  Leve1s
Mil 1
Number
110127
110131(b)(h)
1 10134
IlOlAl(e)
110144
110147
1 101Sl(i)
900023(c)(i)
900()24(g)(i)
900026(1)
Bl'T- Final
Effluent
Levels
Flow
kl/kkg (kgal/t)
12.6
16.2
1 1 .2
8.0
8.5
6.0
15.7
2B.4
2.1
34.2


30.0
(3.02)
(3.88)
(2.69)
(1.92)
(2.04)
(1.43)
(3.76)
(6.80)
(0.50)
(8.20)


(7.2)
BODS
kg/kkg (Ib/t)
0.9
4.9
.7
.5
.6
.7
.2
0.3
0.0
0.1


0.9
(1.81)
(9.82)
(3.31)
(2.99)
(3.23)
(3.35)
(2.45)
(0.62)
(0.08)
(0.24)


(1.7)
TSS
kg/kkg
0.8
1.1
2.4
0.6
1.3
1.4
0.9
0.4
0.1
0.8


1.2
(11
(1
(2
(4
(1
(2
(2
(1
(0
(0
(I


(2
Vt)
50)
23)
82)
12)
54)
82)
72)
74)
12)
52)


3)
Start
Date
07/77
01/78
10/78
07/77
01/80
07/77
07/77
07/77
10/77
02/79



Number
Flow
34
24
27
39
16
25
9
45
36
19



Of Months Data
BOD5
34
21
27
42
16
25
9
44
33
20



TSS
34
21
27
42
16
26
9
44
33
20



                     Corrugating Medium Furnish
                     110025(i)
                     110054
                     BHT-Final
                     Effluent
                     Level s
 7.6  (1.82)
58.6 (14.05)
 6.7  (1.60)
                                     30.0  (7.2)
0.8  (1.6?)
1.7  (3.35)
0.9  (1.71)
1.6  (3.1)
1.5  (3.04)
0.4  (0.88)
0.6  (1.23)
2.1  (4.2)
                                          03/79
                                          07/78
                                          07/77
                                                    21
                                                    12
                                                    46
21
12
46
21
12
46
                     (j)   NSPS  Option 1  final  effluent  levels  are  the  sane  as  those determined for NSPS Option 2.
                     (li)   Mill  is  now closed.
                     (c)   Biological  treatment ia followed by  sand filtration.
                     (d)   Mill  is  scheduled to discharge to a  FOTW.
                     (e)   This  mill  spray irrigates a portion  of  its  final  effluent;  djta  presented are not representative of total discharge.
                     (f)   Flows are  generally  less than 0.005  kgal/ton.
                     (g)   Mill  has no external treatment system.
                     (h)   Mill  has primary treatment only.
                     (i)   HODS  and TSS are less than or equal  to prorated BPT  for this.  mill.   Prorated BPT has been determined for each mill
                          based on tin- percent corrugated medium  furnish employed by  the mill.

-------
described  in  detail  later  in  this  section  (see  NSPS Option 2).
Available effluent data for mills in this subcategory are presented in
Table VIII-19.

     Builders' Paper and Roofing Felt - In  the  builders'  paper  and
roofing felt subcategory, extensive use of production process controls
to  reduce  wastewater discharge is practiced.  NSPS Option 1 for this
subcategory is identical to NSPS Option 2 and includes the application
of  production  process  controls  and  biological   treatment.    The
methodology    for   development   of   long-term   average   effluent
characteristics is described in detail later in this section (see NSPS
Option 2).  Available effluent data for mills in this subcategory  are
presented in Table VIII-20.

     Noninteqrated-Fine  Papers  -  Two  subcategory subdivisions have
been considered: wood fiber furnish and cotton fiber furnish.

For the wood  fiber  furnish  subdivision  of_  the  noninteqrated-fine
papers  subcategory,  as  illustrated  in  Table  VIII-21, the general
methodology was followed; however, data relating to mills  where  only
primary  treatment  is  employed  were excluded from the computations.
Data were reviewed with respect to waste  significant  grade  changes.
No  significant  difference  due  to  grade  change  was noted and the
combined data  were  used.   BPT  effluent  limitations  are  attained
through  the  application  of  biological  treatment  at mills 080007,
080027, 080041, and 080046.  Mill 080027 was also  excluded  from  the
calculations  because chemically assisted clarification is employed at
that mill.

For the cotton fiber furnish  subdivision  of_  the  nonintegrated-fine
papers  subcateqory, EPA determined NSPS Option 1 effluent loads based
on  the  transfer  of  the   performance   of   biological   treatment
characteristic of the wood fiber furnish subdivision.  EPA applied the
average  percent  reduction  for BOD^> and TSS from the best performing
mills in the wood fiber furnish subdivision (41.0 percent for BOD5_ and
51.1 percent for TSS) to BPT final effluent loads for the cotton fiber
furnish subdivision.  EPA  determined  that  the  characteristics  and
treatability  of wastewaters discharged from mills in both subcategory
subdivisions are similar.  Therefore, the  Agency  believes  that  new
mills  in  the cotton fiber furnish subdivision will be able to attain
the  NSPS  Option  1  long-term  average  discharge   characteristics.
Available   effluent  data  for  mills  in  this  subdivision  of  the
nonintegrated-fine papers subcategory are presented in Table VIII-21.

     Nonintegrated-Tissue Papers - As illustrated  in  Table  VIII-22,
the  general  methodology  was  followed;  however,  because  BPT  was
identified as primary clarification,  data  relating  to  mills  where
biological  treatment is employed were excluded from the computations.
BPT effluent limitations  are  attained  through  the  application  of
primary treatment at mills 090008, 090011, 090013, 090022, 090024, and
090028.   Data  were  reviewed with respect to waste significant grade
changes in three specific  delineations:  none,  less  than  one,  and
greater  than  one  waste  significant change per day.  For mills with
                                423

-------
ro
                                                                           TABLE  VIII-19
                                                                 DISCHARGE  MONITORING REPORT DATA
                                                              WASTEPAPER-MOLDED PRODUCTS SUBCATEGORY(a)
                                                        Final  Effluent
                                                   Long-Term Average  Levels	
Mill
Nuiiibc'r
150007(L)
150011
Ib0021(»>)(c)
1. 50025 (d)(e)(f)
BPT-Final
Effluent
Levels
Flow
kl/kkg (kgal/t)
56.7
48.2
1456. 2
1 05 . 5


88. 1
(13.58)
(11.55)
(348.96)
(25.29)


(21.1)
kg/
12
3
1
0


1
BODS
TSS
kkg (Ib/t) kg/kkg (Ib/t)
.0
.2
.9
.7


.3
(24
(6
(3
(1


(2
.05)
.36)
.87)
.38)


-6)
13.3
3.5
4.0
0.7


3.2
(26
(6
(7
(1


(6
.51)
.91)
• 91)
.37)


.4)
Start
Date
10/79
09/78
07/77
01/78



Number Of Months Data
Flow BODS TSS
12 12 12
28 28 28
30 30 30
12 11 11



                     (a)   NSPS  Option  1  final  effluent  levels  are  the  same  as  those  determined for NSPS Option 2.
                     (b)   This  mill  has  no external  treatment  system.
                     (c)   Mill  is  now  closed.
                     (il)   Effluent combined with  non-contact cooling water.
                     (e)   This  mill  has  primary  treatment  only.
                     (t)   TSS and  BOU5 are less  than or equal  to BPT.

-------
ro
on
                                                                           TABLE  VII1-20
                                                                DISCHARGE  MONITORING REPOKT DATA
                                                           BUILDERS'  PAPER  AND  ROOFING FELT SUBCATEGORY(a)
                                                   Final Effluent
                                              Long-Tern Average  Levels
Mill
Number
120004(c)
120006(b)(c)
120008
120020(b)(c)
120021(c)
BPT-Final
Effluent
Levels
Flow
kl/kkg
2.3
115.8
27.4
13.0
0.2


60.1
(kgal/t)
(0
(27
(6
(3
(0


(14
.54)
-74)
.56)
.11)
.05)


.4)
BOD5
kg/kkg
0.2
1.0
1.6
0.1
0.4


1.6
(Ib/t)
(0.31)
(2.09)
(3.11)
(0.11)
(0.77)


(3.2)
TSS
kg/kkg
0.5
0.3
1.7
0.1
0.0


1.6
(Ib/t)
(1
(0
(3
(0
(0


(3
.01)
.67)
.30)
.21)
.08)


.2)
Start
Date
07/77
07/77
07/77
07/78
10/79



Number
Flow
42
47
31
34
4



Of Mon
BODS
39
47
32
34
19



                     (a)   NSPS Option 1 final  effluent  levels  are  the  same as  those determined for NSPS Option 2.
                     (b)   This mill has primary treatment  only.
                     (c)   TSS and BOD5 are less than or equal  to BPT.
                                                                                                                                          TSS

                                                                                                                                           42
                                                                                                                                           40
                                                                                                                                           32
                                                                                                                                           34
                                                                                                                                           19

-------
                                                                              T\B[.E VIII-21
                                                                   DISCHARGE  MONITORING REPORT DATA
                                                                NONINTEGRATED-I--INE PAPERS SUBCATEGORY
ro
                                                     Final Effluent
                                                Long-Tern Average Levels
Mill Flow BODS TSS
Number kl/kkg (kgal/t) kg/kkg (Ib/t) kg/kkg ( Ib/t)
Wood Fiber Furninh
080007(a) 55.5 (13.31) 1.4 (2.88) 1.6 (3 28)
080009(b) 65.5 (15.69) 3.3 (6.60) 1.7 (3.48)
080018 30.2 (7.24) 2.8 (5.57) 2.0 (3.94)
080027(a)(c) 30.6 (7.34) 0.9 (1.82) 0.7 (1.31)
080030(h) 22.5 (5.39) — — 24.2 (48 48)
080033(b) 45.4 (10.87) 4.7 (9.40) 2.6 (5.25)
080040(b)(d) 103.0 (24.69) 13.4 (26.71) 14.6 (29 21)
080041(a) 113.9 (27.29) 1.7 (3.40) 1.4 (2 72)
080046(a) 53.2 (12.75) 1.1 (2.21) 1.8 (3 54)
080048(b)(d) 65.0 (15.57) 11.0 (22.09) 1.1 (2.15)
080049(b) 46.4 (11.11) 4.1 (8.17) 5.3 (10.60)
080051 53.5 (12.82) 2.7 (5.42) 2.5 (5 04)
105047(a)(b) 49.4(11.84) 1.8 (3.51) 1.1 (218)
900059(b) 40.4 (9.69) 3.0 (6.04) 1.6 (3 20)
BPT-Final
Effluent
Levels 63.0 (15.2) 2.4 (4.8) 3.3 (65)
Average of
Mills
Attaining BPT
BOD5 and TSS 1.4 (2.83) 1.6 (3.18)
Cotton Fiber Furnish
080003(a) 169.4 (40.59) 3.7 (7.33) 2.7 (5.44)
080032(e) 68.7 (16.46) 2.0 (3.98) 0.8 (1.65)
080042(d) 67.4 (16.15) 10.7 (21.35) 29.3 (53.61)
080044 155.4 (37.25) 6.9 (13.77) 2.2 (4.49)
BPT-Final
Effluent
Levels 176.5 (42.3) 5.1 (10.2) 7.2 (14.3)
(a) TSS and BODS are less than or equal to BPT.
(b) Data are not included in the average because this 'Mill employs
(c) Data are not included in the average because the mill employs
(d) This mill now discharges to a POTW.
(e) This mill discharges a variable amount of raw want'-water to a
Start 1
Date 1

08/77
01/78
09/78
01/78
07/77
07/77
07/77
11/78
03/79
04/79
08/78
10/79
07/77
11/77








07/77
01/79
07/78
11/79




primary treatment only.
chemically assisted clarification.

POTW.
Number
Flow

40
36
2r>
38
27
40
9
2fi
25
24
31
16
39
40








46
28
1H
13








Of Mon
B0!)5

4]
36
25
38
0
41
9
28
25
24
31
16
45
40








46
27
1H
14








                                                                                                                                              TSS
                                                                                                                                               40
                                                                                                                                               :'6
                                                                                                                                               2.5
                                                                                                                                               38
                                                                                                                                               27
                                                                                                                                               41
                                                                                                                                                9
                                                                                                                                               2fl
                                                                                                                                               25
                                                                                                                                               24
                                                                                                                                               31
                                                                                                                                               If.
                                                                                                                                               4r>
                                                                                                                                               46
                                                                                                                                               2S
                                                                                                                                               IS
                                                                                                                                               14

-------
ro
                                                                          TABLE  VIII-.!2
                                                                DISCHARGE  MONITORING KEPOKT DATA
                                                            NONINTEGRATED  -  TISSUR  PAPERS SUBCATEGOKY
                                                  Final  Effluent
                                             Long-Term Average  Levels
Mi 1 I
Flow
Nuul.er kl/kkg (kgal/t)
040006
090001 (a )(b)
090005(a)(b)(c)
090007(a)(b)
0'JOU08(a)
()900H(a)(c)
090013(a)
090019
090022(a)
090024(a)
090028(a)(c)
090031
090032
555555
BFT-Final
Effluent
Levels
Average of A] 1
Mills Attaining
BPT BODS
and TSS
91
70
11
92
57
53
29
80
62
81
91
97
133
73


96




.9
.8
.4
.7
.3
. 1
.5
.4
.1
.8
.8
.9
.9
.3


.0




(22.
(16.
(2.
(22.
(13.
(12.
(7.
(19.
(14.
(19.
(22.
(23.
(32.
(17.


(22.




03)
96)
73)
21)
74)
72)
06)
26)
87)
61)
00)
47)
08)
57)


9)




BOOS
TSS
kg/kkg (~lb/t) kg/kkg aWO
4
1
0
0
2
2
i
2
3
1
2
2
2
4


3


1

.9
.6
.2
.2
.2
.4
. 1
.9
.0
.0
.2
.0
.4
.9


.5


.6

(9
(3
(0.
(0,
(4,
(4,
(2,
(5
(6
a
(4,
(4.
(4
(9.


(7,


(3

.70)
.12)
.42)
.47)
.44)
.88)
.28)
.82)
.09)
.90)
.34)
.01)
.76)
.79)


.0)


.10)

2.6
1.0
0.2
0.6
0.7
1.2
0.6
3.3
2.7
0.7
1.9
3.2
3.4
7.6


2.9


1.1

(5.
(1.
(0.
(1.
(1.
(2.
(1.
(6.
(5.
(1-
(3.
(6.
(6.
(15.


(5.


(2.

28)
97)
45)
28)
31)
30)
24)
54)
46)
41)
82)
41)
88)
19)


7)


14)

                   Average  of  Mills  Attaining
                   BCT  BODS and  TSS

                   -No  waste significant  grade
                     changes per  day
                   -Less  than  one waste sign!'
                     ficant  grade change per  day
1.6  (3.17)

2.7  (5.49)
0.68 (1.36)

1.9  (3.88)
                                                                                               Start
                                                                                               Dale

                                                                                               08/79
                                                                                               07/77
                                                                                               09/77
                                                                                               07/77
                                                                                               07/77
                                                                                               07/77
                                                                                               08/77
                                                                                               07/77
                                                                                               07/77
                                                                                               07/77
                                                                                               01/78
                                                                                               07/77
                                                                                               08/77
                                                                                               04/79
                    (a)   TSS  and  BOD5  are  lets  than or equal  to  BPT.
                    (b)   Data not included in the  average becauae the Mill  employs  biological  treatment.
                    (c)   Mil]  is  now closed.
                                                                   Number Of Monllijs Data
                                                                   Flow    BOI)5     TSS
                                                                    21
                                                                    24
                                                                    29
                                                                    36
                                                                    47
                                                                    28
                                                                    40
                                                                    46
                                                                    20
                                                                    22
                                                                    36
                                                                    36
                                                                    26
                                                                    21
                                                              22
                                                              42
                                                              29
                                                              36
                                                              47
                                                              28
                                                              40
                                                              46
                                                              28
                                                              22
                                                              36
                                                              36
                                                              44
                                                              21
22
42
29
36
47
27
40
46
26
22
36
36
44
21

-------
data  available  on  grade  change,   EPA  found  that  a   significant
difference  in  long-term average discharge levels due to grade change
existed.  Therefore, the NSPS Option 1  effluent loads are based on the
highest long-term average loads,  which occurred at  those  mills  with
less than one grade change per day (mills 090011  and 090022).

     Noninteqrated-Liqhtweiqht  Papers  -  For both product sectors in
this new subcategory,  EPA determined  NSPS  Option  1  effluent  loads
based on the transfer of performance from the best performing mills in
the  nonintegrated-tissue papers subcategory.  EPA applied the average
percentage reductions beyond BPT for the  nonintegrated-tissue  papers
subcategory  (21.6  percent  for BODJ5 and 31.9 percent for TSS) to the
final BPT limitations for this subcategory.  As explained  previously,
EPA   determined   that   the   characteristics  and  treatability  of
wastewaters discharged from  mills  in  the  nonintegrated-lightweight
papers subcategory and the nonintegrated-tissue papers subcategory are
similar.   Therefore,   the  Agency  believes  that  new  mills  in the
nonintegrated-lightweight papers subcategory will be  able  to  attain
the   NSPS  Option  1   long-term  average  discharge  characteristics.
Available effluent data for mills in this subcategory are presented in
Table VIII-23.

     Nonintegrated-Filter  and  Nonwjaveji  Papers  -   For   this   new
subcategory,  EPA determined NSPS Option 1 effluent loads based on the
transfer  of  performance  from  the  best  performing  mills  in  the
nonintegrated-tissue  papers  subcategory.   EPA  applied  the average
percentage reductions beyond BPT for the  nonintegrated-tissue  papers
subcategory  (21.6  percent  for BOD!> and 31.9 percent for TSS) to the
final BPT limitations for this subcategory.  As explained  previously,
EPA   determined   that   the   characteristics  and  treatability  of
wastewaters discharged from  mills  in  the  nonintegrated-filter  and
nonwoven   papers  subcategory  and  the  nonintegrated-tissue  papers
subcategory are similar.  Therefore,  the  Agency  believes  that  new
mills in the nonintegrated-filter and nonwoven papers subcategory will
be  able  to  attain  the  NSPS  Option  1 long-term average discharge
characteristics.   Available  effluent  data   for   mills   in   this
subcategory are presented in Table VII1-24.

     Nonintegrated-Paperboard   -   For   this  new  subcategory,  EPA
determined NSPS Option 1 effluent  loads  based  on  the  transfer  of
performance from the best performing mills in the nonintegrated-tissue
papers  subcategory.   EPA  applied  the average percentage reductions
beyond BPT  for  the  nonintegrated-tissue  papers  subcategory   (21.6
percent  for  BOD5.  and  31.9  percent  for  TSS)  to  the  final  BPT
limitations  for  this  subcategory.   As  explained  previously,  EPA
determined  that  the  characteristics and treatability of wastewaters
discharged from mills in the nonintegrated-paperboard subcategory  and
the  nonintegrated-tissue  papers subcategory are similar.  Therefore,
the Agency believes that new  mills  in  the  nonintegrated-paperboard
subcategory will be able to attain the NSPS Option 1 long-term average
discharge  characteristics.  Available effluent data for mills in this
subcategory are presented in Table VIII-25.
                                 428

-------
                                                       TABLE V11J-23
                                            OISCHAKGE  HONITORINfi KEPOKT DATA
                                      NONINTEGRATED  -  LIGHTWEIGHT PAPERS SUBCATEGORy
                              Final Effluent
                   ^ ___ 	 LoDg'Term Average l.eyel_ii_
Mi] 1
                  Flow
                                   BOD5
             	Kl/kkg (kgal/t)  kg/kkg  (lb/t)
              	TSS_	
             .kg'/k'kg (lb/t)
                                    Start
                                    Date
                                                                                                     Number  Of  Months Data
                                                              Flow
                                                                      BODS
                                                                               TSS
I. < jj>i t ue i gh I
08002 ](d)(d)
080022(d)
0«0<>24(d)
090003 (b)(d)
090()l5(a)(il)
IOr>(H3(a)
1 05020 (d)
BFT- Final
Ef< luc-nl

66.
82.
41!.
63
117
319
IB').



.0
.0
.2
.4
.6
.9
.9



(15.
(19.

81)
.65)
(10.82)
(15.
(28
(76,
(45.


,20)
.18)
.65)
.51)



0.
1.
0.
3,
2,
7.
1,



9
3
6
.1
.3
.2
.3



(1
(2.
(1
(6
(4
(14,
(2,



.74)
.63)
.27)
.15)
.51)
.49)
.65)



0.
2.
0,
2,
2,
8.
1.



5
1
7
.0
. 1
.9
.8



(1.08)
(4.15)
(1.48)
(3.90)
(4.26)
(17.72)
(3.59)


                                                                            07/77
                                                                            01/78
                                                                            01/78
                                                                            08/77
                                                                            11/78
                                                                            07/77
                                                                            01/78
                                                                     34
                                                                     31
                                                                     23
                                                                     41
                                                                     30
                                                                     34
                                                                     3?
                                                                        34
                                                                        31
                                                                        23
                                                                        43
                                                                        30
                                                                        36
                                                                        3?
                                                                      34
                                                                      29
                                                                      23
                                                                      43
                                                                      30
                                                                      36
                                                                      37
               201.2 (48.7)
 7.4 (14.7)
          6.0 (12.0)
E J tM t r i
               417.3(100.00)
               678.1(162.49)
 4.6
 3.7
(9.17)
(7.41)
3.4
3.1
(6.78)
(6-17)
01/78
07/77
23
41
23
44
23
44
B»'T- Final
Eli turiil
I.evc-Js
               320.9 (76.9)
11.6 (23.2)
          9.5 O9.0)
(a)  This mill ti.is biological treatment.
0>)  This mill has no external treatment.
(c)  Mil) is now closed.
(ii)  TSS and ROD") are less than or equal  to  BPT.
 Uj.lion 1 levels are based on transfer of technology  from Nonintegrated-Tissue Papers Suhcategory.

-------
                                                                          TABLE VII1-24
                                                                DISCHARGE MONITORING REPORT DATA
                                                      NONINTKGRATED - FILTER AND NONVOVKN PAPERS SUBCATEGORY
-Fa
Co
O
                                                  Final Effluent

                                             Loan-Term Average Levels
Hill
Nunber
105033(a)(b)
105034(a)(b)
105051 (b)
105055(a)(b)
BPT-Final
Effluent
Levels
Flow
kl/kkg (kgal/t)
170.5
204.3
168.1
249.9


250.0
(40.86)
(48.95)
(40.28)
(59.88)


(59.9)
BODS
kg/kkg (Ib/t)
1.8
3.8
1.4
1.5


9.1
(3.56)
(7.51)
(2.83)
(2.99)


(18.1)
TSS
kg/kkg (Ib/t)
1.1
2.8
2.2
2.9


7.4
(2.
(5.
(4.
(5.


(14.
18)
63)
33)
77)


«)
Start
Date
07/77
07/77
07/77
12/77



Nuober
Flow
43
39
12
33



Of Months Data
BODS
44
44
12
33



TSS
44
44
12
33



                    (a)  This Bill has biological treatment.

                    (b)  TSS and BODS are less than or equal to BPT.
                     Option 1 levels are based on transfer of technology front Nonlntegrated-Tlssue Papers subcategory.

-------
CO
                                                                          TABLE VIII-25
                                                                DISCHARGE MONITORING REPORT DATA    ,
                                                              NONINTEGRATED - PAPERBoARD SUBCATEGOKY*
                                                  Final  Effluent
                                             Long-Term Average Levels
Hill
Number
085001 (a) (d)
085007
105002
105048(b)(d)
J05049(b)(c)
1 10021 (a)
BPT-Kinal
Et fluent
Levels
Flow
kl/kkg (kgal/t)
19.8 (4.75)
167.9 (40.24)
238.0 (57.04)
26.1 (6.26)
51.3 (12.30)
57.2 (13.70)
53.8 (12.9)
BOD5
kg/kkg (lb/t)
0.7 (1.43)
1.5 (3.09)
4.8 (9.66)
0.3 (0.59)
5.5 (10.99)
1.5 (3.03)
2.0 (3.9)
TSS
kg/kkg (lb/t)
0.4 (0.72)
2.2 (4.45)
2.2 (4.30)
0.2 (0.49)
0.5 (1.04)
2.7 (5.34)
1.6 (3.2)
                    (a)  This mill h.is biological treatment.
                    (b)  This mill has no external treatment.
                    (c)  This mill now discharges to a POTV.
                    (d)  TSS and BOU5 are less than or equal  to BPT.
Start
Date
07/77
07/77
07/77
01/78
03/78
07/77
Numbe r
Flow
44
46
30
33
11
41
Of Months
BODS
45
43
28
32
11
40
Data
TSS
44
40
28
33
11
40
                     Option 1 levels are based on transfer of technology from Nonintegrated-Tissue Papers subcategory.

-------
The NSPS Option 1  long-term average final effluent loads developed  as
described above are presented in Table VI11-26.

Attainment  of_  NSPS Option 1_.  Table VI11-27 summarizes the number of
mills attaining BPT and NSPS Option 1 long-term average final effluent
loads along with the  number  of  direct  discharging  mills  in  each
subcategory for which data were available.  At 44 percent of the mills
in  the  integrated  segment, 62 percent of the mills in the secondary
fibers segment, and 76 percent  of  the  mills  in  the  nonintegrated
segment  where  BPT  effluent  limitations are attained, NSPS Option 1
limits are also attained.

EPA compared the NSPS Option 1 final effluent loads presented in Table
VIII-26, the NSPS Option 1  raw waste loads shown in Table VIII-3,  and
the  raw  waste  and  final  effluent loads that form the basis of BPT
effluent limitations.  The Agency found that, for  all  subcategories,
compliance  with  NSPS  Option  1  final effluent loads would require a
higher BODS^ percent reduction than required  by  compliance  with  BPT
effluent  limitations.   Therefore,  the end-of-pipe systems that form
the basis of NSPS Option 1  must be more  efficient  in  removing  BOD5.
than the systems that form the basis of BPT effluent limitations.

To  determine  if  these higher percent reductions are demonstrated in
this industry,  for  all  mills  used  in  developing  NSPS  Option  1
long-term  average  final  effluent  loads, EPA compared BODj^ effluent
loads to BODjj^ raw waste loads.  Raw  waste  and  final  effluent  data
presented  in  Sections  V  and VIII, respectively, were used; in some
cases, more recent raw waste load data were available and were used in
the analysis.  The percent reductions in BOD5^ being attained at actual
mills were then compared to those that form the basis of  NSPS  Option
1,   which  are  presented  in  Table  VIII-28.    In  completing  this
assessment, EPA investigated eight major  industry  sectors:  bleached
kraft,  unbleached  kraft/semi-chemical,  sulfite,  groundwood, deink,
other  secondary  fibers,   nonintegrated-fine   papers,   and   other
nonintegrated.   As  shown  in  Table  VI11-29 and as discussed below,
mills in every major sector achieve the  percent  reductions  of  BOD5_
that  form  the basis of NSPS Option 1.  Because waste characteristics
and waste treatability are similar between the subcategories  in  each
sector,   EPA   has   determined  that  mills  representative  of  all
subcategories in each  sector  are  capable  of  achieving  equivalent
reductions.

In  the  bleached kraft sector, BOD5_ reductions that form the basis of
NSPS Option 1 range from 91 to 94 percent.   BOD5_  percent  reductions
within  this range are being attained at mills 030010, 030030, 030032,
030046, and 032002.  BOD5_ reductions of greater than  94  percent  are
being attained at mills 030020, 030027, and 777777.

In the unbleached kraft and semi-chemical sector, BOD5_ reductions that
form  the  basis  of  NSPS Option  1 range from 92 to 95 percent.  BOD5_
percent reductions within this  range  are  being  attained  at  mills
010008,  0150C4,  and  060004  and  at  mills  010020 and 010025 where
                               432

-------
                                       TABLE VIII-26

                                       NSPS OPTION 1
                                     LONG-TERM AVERAGE
                                 DISCHARGE CHARACTERISTICS

                                       Flow                BODS
                                  kl/kkg  (kgal/t)
                         kg/kkg (Ib/t)
Integrated Segment

Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
  o Linerboard
  o Bag
Serai-Chemical
Unbleached Kraft
  and Semi-Chemical
Dissolving Sulfite Pulp
  o Nitration
  o Viscose
  o Cellophane
  o Acetate
Papergrade Sulfite2
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers

Secondary Fibers Segment

Deink
  o Fine Papers
  o Tissue Papers
  o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
  o Corrugating Medium Furnish
  o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt

Nonintegrated Segment
    230.0
    173.0
    148.0
    129.0

     52.5
     52.5
     42.9
(55.1)
(41.6)
(35.4)
(30.9)

(12.6)
(12.6)
(10.3)
     58.A   (14.0)
    275.
    275,
    275.
    303.
     88.0
     99.0
     91.0
    102.0
    102.0
     67.6
     68.0

     13.A
     13.A
     23.8
     11.3
(66.0)
(66.0)
(66.0)
(72.7)
  *
(21.1)
(23.8)
(21.9)
(24.4)
(24.4)
(16.2)
(16.3)

 (3.2)
 (3.2)
 (5.7)
 (2.7)
 4.8
 3.3
 2.6
 1.9

 1.3
 1.5
 1.2

 1.4

 8.5
 9.1
 9.9
12.4
 *
 1.6
 1.5
 1.4
 2.5
 3.3
 1.7
 1.3
 (9.64)
 (6.62)
 (5.16)
 (3.87)

 (2.57)
 (3.00)
 (2.36)

 (2.70)

(16.96)
(18.15)
(19.70)
(24.88)
  *
 (3.18)
 (2.98)
 (2.74)
 (4.93)
 (6.64)
 (3.43)
 (2.56)
 1.1     (2.25)
 0.73   (1.46)
 0.60   (1.19)
 0.49   (0.98)
                                                                                 TSS
                                 kg/kkg (Ib/t)
 8.2
 5.7
 4.3
 3.0

 2.2
 2.7
 2.2

 2.4
12.5
12.5
12.5
12.5
 *
 2.7
 2.2
 2.0
 1.7
 4.5
 3.3
 2.8
(16.33)
(11.44)
 (8.64)
 (6.05)

 (4.37)
 (5.44)
 (4.40)

 (4.70)

(25.08)
(25.08)
(25.08)
(25.08)
  *
 (5.45)
 (4.41)
 (4.01)
 (7.31)
 (9.04)
 (6.57)
 (5.66)
              1.2    (2.41)
              0.97   (1.93)
              1.2    (2.30)
              0.73   (1.45)
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated- Paperboard

63.0
176.5
96.0

203.7
320.9

250.0
53.8

(15.2)
(42.3)
(22.9)

(48.7)
(76.9)

(59.9)
(12.9)

1.4
3.0
2.7

5.8
9.1

7.1
1.5

(2.83)
(6.01)
(5.49)

(11.56)
(18.26)

(14.22)
(3.06)

1.6
3.5
1.9

4.1
6.4

5.0
1.1

(3.18)
(7.00)
(3.88)

(8.16)
(12.88)

(10.03)
(2.16)
'includes Fine Bleached Kraft and Soda subcategories.
2Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash) subcate-
 gories .
*NSPS vary with the percent sulfite pulp in the final product.  These equations can be
 used to obtain annual average effluent characteristics for Papergrade
 Sulfite mills:
              Flow (kl/kkg)
              BOD5_ (kg/kkg)
              TSS (kg/kkg)
= 52.87 exp(0.017x)
=  1.72 exp(0.017x)
=  2.22 exp(0.017x)
 where x equals the percent sulfite pulp produced on-site in the final product.
                                          433

-------
                                       TABLE VIII-27

                  WMBEt Of f&CILITIES THAT ATTAIH BFT AHD 8SPS OPTION 1
                              FINAL EFFLUENT CHARACTERISTICS
«ill» with
Available
Data
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
o Linerboard
o Bag
Seai-Chcaicil
Unbleached Kraft
and Seal-Cheaical
Dissolving Sulfite Pulp
o Nitration
o Viacoae
o Cellophane
o Acetate
Papergrsde Sulfite2
Groundvood-Thermo-Mech»nic»l
Groundvood-CMN Papers
Groundwood-Fin* Papera
Second* ry Fiber* Segment
Deink
o Fine Papers
o Tiasue Papers
o Newsprint
Tissue Froa Waitepaper
Paperboard From Wastepaper
o Corrugating Mediuai Furnish
o Noncorrugating Medium Furni»h
Wa»tepaper-Molded Product*
Builders ' Paper and Roofing Felt
Honintegrated Segment
Honintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tis*ue Papers
Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard

3
9
7
14

16
10
15

9

0
2
1
2
11
2
2
6


3
10
1
9

3
37
4
5


12
2
14

7
2

4
5
Hill.
Attaining
BPT F.E.
Levels (a)

2
7
3
5

9
3
4

3

0
0
0
0
5
1
1
3


3
6
1
7

2
21
1
4


5
1
9

6
2

4
2
Mills
Attaining
NSPS Option 1
F.E. Levels(a)

1
1
1
3

4
2
2

1

0
0
0
0
2
1
1
2


0
3
1
2

1
18
0
3


2
0
6

6
2

4
2
'Includes Fine Bleached Kraft and Soda *ubcategories.
Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash)
 subcategorie*,

(a) F.E. = Final Effluent
                                          434

-------
                                       TABLE VIII-28

                                    PERCENT REDUCTIONS
                           REQUIRED TO ATTAIN NSPS OPTION 1 BOD5
                              FINAL EFFLUENT CHARACTERISTICS
                          FROM NSPS OPTION 1 BODS RAW WASTE LOADS
                                             Percent Reduction*
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
  o Linerboard
  o Bag
Semi-Chemi ca1
Unbleached Kraft
  and Serai-Chemical
Dissolving Sulfite Pulp
  o Nitration
  o Viscose
  o Cellophane
  o Acetate
Papergrade Sulfite2
Groundwood-Themo'Hechanical
Groundwood-CMN Papers
Groundwood-Fine Papers

Secondary Fibers Segment

Deink
  o Fine Papers
  o Tissue Papers
  o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
  o Corrugating Mediun Furnish
  o Noncorrugating Mediun Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt

Nonintegrated Segment

Nonintegrated-Fine Papers
  o Wood Fiber Furnish
  o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Vonintegrated-Lightweight Papers
  o Lightweight
  c Electrical
Nonintegrated-Filter
 and Nonwoven Papers
Nonintegrated-Paperboard
93
91
93
94

92
94
95

93

94
94
95
95
95
93
91
92
97
96
89
87

95
94
89
92
87
87
76

73
58

41
85
'Includes Fine Bleached Kraft and Soda subcategories.
"Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash) subcate-
 gories.

*Percent reduction
 = [raw waste load (Ib/t) - final effluent (lb/t)J x 100/raw waste load (Ib/t)
 except for Papergrade Sulfite subcategories for which percent reduction is defined in
 terras of concentrations (mg/1).
                                                435

-------
                   TABLE VI11-29

             PERCENT BOD5 REDUCTIONS
          ATTAINED AT SOME MILLS  MEETING
              BPT BODS AND TSS  FINAL
                  EFFLUENT LEVELS
Percent Reductions
                                                        Percent  Reduction
to attain NSPS
Option 1 BODS
Sector/Mill Number F.E. Levels(a)
Bleached Kraft 91-94
030010
030020
03002*
030030
030032
030046
032002
777777
Unbleached Kraft
and Semi -Chemical 92-95
010008
010020(c)
010025(c)
015004
020003
060004
Sulfite 94-95
040009 (d)
0400 1 6 (e)
0400 1 7 (e)
040019
Groundwood 91-93
052003
052007
052008
052014
054014
054015
070001
Deink 89-97
140007
140008
140014
140015
140019
140021
Other Secondary Fiber 87-95
C85004
100005
110001
110025
110031
110043
110052
110057
110062
110069
110110
12000*
Nonintegrated-Fine Papers 87
080041
080046
Raw Waste
Load BOD5(b)
(lb/t)

74.3
51.0
46,9(1)
88.]
66,1(1}
62,3
78.7
71,8(2)


37.6
41.0
27.8
34.2
50.5
37.4(1)

163.0(3)
218,5
194.2
93.1(4)

24.3
38.8(5)
20.1
24.0
33.6
42.7
38.0

110. 0
145.5
130.4(6)
72.2(5)
41.8
160.5

44.7
28.4
25.0
38.6
7.1(5)
23.5(5)
18.1
35.0
22.9
14.8
22.4
10.9

29.8
27.6
Final Effluent
BOD5(b)
(lb/t)

4.9
2.7
1.3
5.4
5.1
4.1
7.5
3.1


2.0
2.2
1.1
1.7
0.7
2.5

2.95(3)
13.07
10.57
3.92(4)

1.6
1.9
0.9
0,6
2.5
2.5
3.2

4.4
6.5
8,8
6.8
4.0
4.4

3,6
3,7
0.3
1.7
0.3
1.6
0.8
1.7
1.1
0.5
0.4
0.3

3.4
2.2
From Raw Waste
BODS to Final
Effluent B005

93
95
97
94
92
93
91
96


95
95
96
95
99
93

98
94
95
96

93
95
96
98
93
94
92

96
96
93
91
90
97

92
87
99
96
96
93
96
95
95
97
98
97

89
92
                          436

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                                              TABLE VIII-29 (cont.)
Other Nonintegrated
090008
090013
090022
105020
105051
41-85
30.6
12.6
18.2
16.5
9.9
4.4
2.3
6.1
2.7
2.9
86
82
66
84
71
(a)  These represent the range of the percent reductions required to attain the subcategory NSPS Option 1
     final effluent BODS levels from NSPS Option 1 raw waste loads.

     Percent reduction > [raw waste BODS (Ib/t) - final effluent BODS (lb/t)J
                             x 100/raw waste BODS (Ib/t)

     except for the Papergrade Sulfite subcategories for which the percent reduction is defined in terms of
     concentrations (ng/1).

(b)  The sources of the raw waste load data and the final effluent data are the 308 Survey and long-tern average
     BOD5 levels from the Discharge Monitoring Reports respectively except as noted below:

     (1)  Data are fron the Supplemental Data Request Prograa.
     (2)  One year raw waste data obtained from Bill representatives.
     (3)  The raw waste BOD5 load is the total load from mills 040009 and 030051, which share a joint treatment
          system.  Final effluent 4*ta are from the joint treatment system.
     (4)  The percent reduction is based on influent to and effluent from the biological treatment system.
          Data are from the Supplemental Data Request Program.
     (5)  Data are from the Verification Data Request Program.
     (6)  The percent reduction is based on raw waste BODS to biological treatment and total final effluent
          from both biological and primary treatment.

(c)  The treatment system used at this mill is a storage oxidation basin.

(d)  This mill shares a joint treatawnt system with a fine bleached kraft mill.  Approximately 40 percent of the
     combined output of the two mills is sulfite pulp.  Prorated BPT was calculated for the combined mills and
     it was determined that the treatment system attained BPT levels.

(e)  This mill attains the BOD5 comparison level but not the TSS comparison level.
                                                          437

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oxidation ponds are employed.  A BOD5_ reduction  of  greater  than  95
percent is being attained at mill 020003.

In  the  sulfite  sector,  BOD5_ reductions that form the basis of NSPS
Option 1  range from 94 to 95 percent.  A 96 percent BOD5_ reduction  is
now  attained  at mill 040019.  (At mill 040019, only pulp mill wastes
are biologically treated.)   [The BPT long-term average  BOD5_  effluent
load  is  now  attained  at  mills 040016 and 040017; however, the BPT
long-term average TSS effluent load is exceeded.  At mills 040016  and
040017,  BOD5_  percent  reductions  of  between  94 and 95 percent are
attained.  Also, mill 040009, a  papergrade  sulfite  mill,  shares  a
joint  treatment  system with a bleached kraft mill.  About 60 percent
of the BOD5_ raw waste load is associated with the  papergrade  sulfite
operations.   At  mill  040009, a BODS^ reduction of over 98 percent is
attained.]

In the groundwood sector, the BOD5_ reductions that form the  basis  of
NSPS  Option  1  range from 91 to 93 percent.  BOD5_ percent reductions
within this range are being attained  at  mills  052003,  054014,  and
070001 .  BOD5_ reductions of greater than 93 percent are being attained
at mills 052007, 052008, 052014, and 054015.

In  the  deink  sector,  BOD5_  reductions  that form the basis of NSPS
Option 1  range from 89 to 97 percent.  BOD!> percent reductions  within
this range are being attained at mills 140007, 140008, 140014, 140015,
and  140019.  A BOD5_ percent reduction of 97 percent is being attained
at mill 140021.

In the other secondary fibers sector, BOD5_ reductions  that  form  the
basis  of  NSPS  Option  1  range from 87 to 95 percent.  BOD5_ percent
reductions within this range  are  being  attained  at  mills  085004,
100005,  110043,  110057, and 110062.  BOD5. reductions of greater than
95 percent are being attained at mills 110001, 110025, 110031, 110052,
110069, 110110, and 120004.

In the nonintegrated-fine papers sector, the BOD5_ reduction that forms
the basis of NSPS Option 1 is 87  percent.   BOD5_  percent  reductions
equal to or in excess of 87 percent are being attained at mills 080041
and 080046.

In  the  other nonintegrated sector, the BOD5_ reductions that form the
basis of NSPS Option 1 range from 41 to 85 percent.   BODS^  reductions
within  this range are being attained at mills 090013, 090022, 105020,
and 105051.  A BOD!> percent reduction of greater than  85  percent  is
being attained at mill 090008.

As  shown  above,  end-of-pipe  biological  treatment  is  capable  of
attaining the percent reductions in BOD5_ that form the basis  of  NSPS
Option  1 in all subcategory sectors where biological treatment is the
technology basis of BPT  effluent  limitations.   Both  the  activated
sludge  process  and  aerated  stabilization  basins  are  capable  of
attaining these reductions.  In northern climates, available data show
that the activated sludge  process   is  superior  in  its  ability  to
                                438

-------
control  pulp,  paper, and paperboard industry discharges.(203)  In the
nonintegrated subcategories where primary treatment forms the basis of
BPT effluent limitations, end-of-pipe primary treatment is capable  of
attaining  the  percent reductions in BODjj that form the basis of NSPS
Option 1.

Some commenters on the January  1981   proposed  regulations  expressed
concern  that  few  existing  mills  in  the  integrated  segment were
attaining the proposed NSPS.  These commenters  stated  that  EPA  had
overstated  the  capability of biological treatment to reduce BODS^ raw
waste loads in this segment.  As discussed above, biological treatment
systems now employed in the integrated segment are capable of reducing
BODS^  to  the  extent  required  by  NSPS  Option  1 .     Because   the
conventional  activated  sludge  system  that  forms the basis of NSPS
Option 1  must achieve a higher BODS^ percent reduction than required by
compliance with BPT effluent limitations, the Agency conducted further
investigations to ensure that the  system that forms the basis of NSPS
Option 1  has been properly  sized  to  ensure  that  the  higher  BOD£
reductions would be attained at all mills.

In  the  development document supporting proposed rules, EPA published
the design criteria for end-of-pipe biological treatment systems  that
the   Agency   believed  to  be  capable  of  attaining  the  effluent
concentrations  required  to  attain  proposed .NSPS.    These   design
criteria,   which  are  identical to NSPS Option 1 design criteria, are
presented in Table VIII-30.  (This  table  also  presents  the  design
criteria  for  aerated  stabilization  basins  and  extended  aeration
activated sludge systems that  EPA  believes  are  equivalent  to  the
conventional  activated  sludge  systems  that  form the basis of NSPS
Option 1.   See Section  IX  of  the  development  document  supporting
proposed  rules.  (203)).   As  shown,  these systems are considerably
larger than those that form the basis of BPT effluent limitations.

Table VIII-31 compares EPA's design  criteria  to  the  actual  design
criteria  for  treatment  systems  employed at mills where the percent
reductions of BODS^ that are necessary to  attain  NSPS  Option  1  are
achieved.    As  shown,  conventional activated sludge systems (and the
equivalent  aerated  stabilization  basins   and   extended   aeration
activated  sludge  systems)  that  form the basis of NSPS Option 1 ate
larger than the systems generally employed at actual mills  where  the
percent  reductions  required  to  achieve  NSPS  Option  1  limits are
attained.   Therefore, the larger end-of-pipe  treatment  systems  that
form  the  basis  of  NSPS  Option  1 for the integrated segment, at a
minimum,  are capable of attaining the percent reductions in BODI5  that
are required by NSPS Option 1.

In summary, the percent reductions in BOD!> that form the basis of NSPS
Option  1   are being attained at mills in"~each subcategory or at mills
in   related   subcategories   where    wastewaters    have    similar
characteristics and treatability.  These reductions are being attained
through  the use of treatment systems that are even smaller than those
that form the  basis  of  NSPS  Option  1.   Mill  personnel  in  many
subcategories  of  the  pulp,  paper, and paperboard industry have not
                                439

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                                 TABLE VIII-30

                                A COMPARISON OF
                         NSPS OPTION I DESIGN CRITERIA
                            TO BPT DESIGN CRITERIA
Activated Sludge                                     BPT            NSPS

Primary clarification (cu m/d/sq m)                   24              20
Equalization (hours)                                  12              12
Aeration Basin
  o Detention Time (hours)                             8              12
  o Organic Loading (kg BOD5/d/cu m)                   0.8             0.5
Aeration (kg BOD5/d/HP)                               19              11.2
Secondary clarification (cu m/d/sq m)                 20              16

Extended Aeration

Primary clarification (cu m/d/sq m)                   24              20
Equalization (hours)                                  12              12
Aeration Basin
  o Detention Time (hours)                            30              48
  o Organic Loading (kg BOD5/d/cu m)                 0.3-0.6           0.2
Aeration (kg BOD5/d/HP)                               19              11.2
Secondary Clarification (cu m/d/sq m)                 20              16

Aerated Stabilization Basin

Primary Clarification (cu m/d/sq m)                   24              20
Aeration Basin
  o Detention Time (days)                             13              13
  o Organic Loading (kg BOD5/d/1000 cu m)             18.4            18.4
Aeration
  o Organic (kg BOD5/d/HP)                            15.3            15.3
  o Mixing (HP/1000 cu m)                            (a)               2.6
Settling (days)                                        1              10

(a) Aerator mixing was not considered in BPT design criteria.
                                       440

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                                    TABLE VIII-31

                            A COMPARISON OF NSPS OPTION I
                                 DESIGN CRITERIA TO
                          CRITERIA USED AT INTEGRATED MILLS
                 WHERE BOD5 REDUCTIONS COMPARABLE TO THOSE REQUIRED
                        TO ATTAIN NSPS OPTION I ARE ACHIEVED
Activated Sludge
  NSPS
 Design
Criteria
Primary clarification (cu m/d/sq m)    20
Aeration Basin
  o Detention Time (hours)             12.0
  o Organic Loading (kg BOD5/d/cu m)    0.5
Aeration (kg BOD5/HP)                  11.2
Secondary clarification (cu m/d/sq m)  16

Extended Aeration

Primary clarification (cu m/d/sq m)    20
Aeration Basin
  o Detention Time (hours)             48
  o Organic Loading (kg BOD5/d/cu m)    0.2
Aeration (kg BOD5/HP)                  11.2
Secondary clarification (cu m/d/sq m)  16

Aerated Stabilization Basin

Primary clarification (cu m/d/sq m)    20
Aeration Basin
  o Detention Time (days)              13
  o Organic Loading (kg BOD5/d/cu m)   18.4
Aeration
  o Organic Loading (kg BOD5/HP)       15.3
  o Mixing (HP/1000 cu m)               2.6
Settling (days)                        10
Average
20
7
0
17
18
35
45
0
17
25
19
9
30
16
2
9

.8
.9
.0


.2
.3
.5


.7
.5
. 7
.0
.9
Actual
Median
20
6
0
14
17
28
29
0
13
24
20
9
22
16
1
9

.9
.9
.9


.4
.2
.9


.7
.1
.2
.3
.9
Mill
Minimum
10
2
0
11
15
12
19
0
7
6
8
0
13
11
0
0

.9
.6
. 1


.0
.1
.3


.9
.2
.9
.6
.2
Maximum
28
16
1
29
23
63
117
1
32
43
25
15
94
24
6
22

.4
.2
.4


.6
.1
.8


.2
.9
.0
.6
.2
                                            441

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chosen to use these larger systems,  but  the  technology  is  readily
available  for  application  at new mills.  Because (a) larger systems
can be readily designed, constructed, and operated at new  sources  in
every subcategory and (b) the wastewater and operating characteristics
of  new  mills  are  similar  to  those  mills where the NSPS Option 1
reductions are now achieved, EPA has determined that all new mills  in
every   subcategory  will  be  capable  of  attaining  NSPS  Option  1
limitations  based  on  the  use  of  expanded  end-of-pipe  treatment
systems.

Option 2_

BPT  for  the pulp, paper, and paperboard industry was generally based
on the implementation of commonly-employed production process controls
and end-of-pipe treatment.  Biological treatment was  the  end-of-pipe
treatment  for all of the original subcategories with the exception of
the nonintegrated-tissue papers subcategory for which BPT was based on
primary treatment.  The technology basis for control  of  conventional
pollutants for NSPS Option 2 is implementation of additional commonly-
employed   production   process  controls  and  end-of-pipe  treatment
technologies.

By reviewing the previously published production process control items
that formed the basis of BPT and BAT effluent limitations (see Phase I
and Phase II Development Documents (46) (48))  and  the  data  request
program  responses  from 644 mills, EPA identified additional commonly
employed production process controls that can further reduce raw waste
loads.  These  controls  serve  as  the  basis  for  defining  a  NSPS
technology  option  (NSPS Option 2) in which raw waste loads are lower
than those that form the  basis  of  BPT  effluent  limitations.   The
controls  that  are generally applicable to each subcategory and which
form the basis of EPA's estimates of the cost of  attainment  of  NSPS
Option  2  raw  waste   loads  are  presented in Tables VII1-32 through
VI11-34.   NSPS Option 2 also includes the application  of  end-of-pipe
treatment  systems that are identical in design to those that form the
basis of NSPS Option 1  for each subcategory.

The methodology used to develop raw waste loads and anticipated  final
effluent characteristics are discussed below.

Development  of_  Raw  Waste  Loads.  NSPS Option 2 raw waste flows and
BODf> loads are generally based on the average discharge flow and  BODIi
raw  waste  loads  at mills where discharges are lower than those that
form the basis of BPT effluent limitations.  The  NSPS  Option  2  raw
waste  TSS  has  been   assumed  to be the same as that which forms the
basis of BPT because (a) the TSS raw waste  loads have  little,  if  any
effect  on final effluent BODJ> and TSS loads (as discussed previously,
the TSS final effluent  concentration is a function  of  the  BODS^  raw
waste  concentration)   and  (b) to ensure that EPA's cost estimates do
not understate the  cost  of  solid  waste  disposal   associated  with
primary clarification.  Because the Option  2 raw waste loads generally
were  derived  from  actual mill data, in the majority of cases it was
not necessary to predict what reductions  would  be  attained  through
                                  442

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                                                                                        TABLE VI11-37.

                                                                       PRODUCTION  PROCESS  CONTROLS FORMING THE BASIS OF
                                                                               COST ESTIMATES FOR  NSPS OPT/ON 2
                                                                                     INTEGRATED SEGMENT
              Control
              1_. Voodya rd/Wood rooa
                                                                                                       Subcategory	



•m
woodya rd
rat ion
ng water

Market
Dissolving Bleached
Kraft Kraft

-
X

BCT
Bleached Alkaline-
Kraft Fine1

X
-

Un-
bleached
Kraft

X
-



Unbleached Dissolving
Semi- Kraft and
Chemical Secni -Chemi cal

X X
-
Sulfite
Pulp

X
X
Papcrgrade
Sulflte2

X
-

(Ironnd-
wood-
TMP

X
X
Ground- Ground-
wood- wood-
CMN Finn
Papers Pani'r.s
X
-
                 Reuse  blow condensates
                 Reduce groundwood  thirfc-
                 ener overflow
                 Spill  Collection

                 Vaj»he_r«_and Screen Room
                 Add 3rd or 4th  stage
              h. Dec kerfilt rate  reuse
CO
k._ Bleaching
a.  Countcrcurrent washing
b.  Evaporate caustic extraction
   stage f i 1 1 rate

5 .  Ev.iporat ion and Reco ve ry A rr a s
a -  Replace baromet ric condenser   X
b .  Add hoi 1 out tank              X
r.  Neutralize spent sulfitr
   lignor
d.  Segreitate cooling water
e.  Spill Collection               X
f.  Reuse evaporator condrnsate

6^ Jaiquor Preparation Area
a.  Spill Collection               X
                      ___
                 Spi 1 1 Collection:
                 1.  Paper machine and
                    bleached  pulp
                 2 .  Co lor pl*nt

-------
                                                                                 TABLE VIII-32 (Continued)
-p.
-p.




Market
Dissolving Bleached
Control Kraft Kraft
7.
r .

d.

* .



i .
j-


n.
8.
Paper Hill (continued)
High pressure showers for
wire and felt cleaning X
White vater use for vacuiui
pimp sea] ing X
Paper machine white water
f
upsets and pulper dilution

Broke storage
Wet lap machine

White vater to pulp aill
Gland water reduction
Stead Plant and Utility Areas

BCT Un-
Bleached Alkaline- bleached
Kraft Fine' Kraft


-

X


.

X


...
- -


Unbleached
Senl- Kraft and
Chemical Semi -Chemical


-

-


X

X X


-
- -


Dissolving
Sulfite
Pulp


X

X



x

-

X
-



Papergrade
Sulfite2


X

X



x



-
-


Groimd-
wootl-
TMP


X

-


X

-
X

-
-

Croiind-
wood-
CMN
Papers


X

X


X

X
X

-
-

Gronnd-
WOOrl-
Fi fie
Paper*


X

X


X
x

X

-
"

             a.  Segregate cooling water
             b.  Lagoon for boiler blowdown
                and backwash waters
             9.  Miscellaneous Controls
             a.  Cooling Tower
             b.  pH Monitor
             c.  Level alams
             d.  Filters
             e.  Recycle of effluent
             (a)
Includes Fine Bleached Kraft and Soda subcategories.

Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash) subratrgorirs.

Costs were included with pulp Mill collection costs.

-------
                                          TABLE VIII-33

                        PRODUCTION PROCESS CONTROLS FORMING THE BASIS OF
                                COST ESTIMATES FOR NSPS OPTION 2
                                    SECONDARY FIBERS SEGMENT
Control
                                                           Subcategory
                                 Deink
                                          Tissue
                                           From
                                         Wastepaj)er
Paperboard
  From
Wastepaper
Wastepaper-
  Molded
 Products
Builders'
Paper and
 Rooflog
  Felt
1.  Woodyard/Woodroom
a.  Close-up or dry
   woodyard and
   barking operation
b.  Segregate cooling water

2.  Pulp Mill
a.  Reuse blow condensates
b.  Reduce groundwood thick-
   ener overflow
c.  Spill Collection

3.  Washers and Screen Room
a.  Add 3rd or 4th stage
   washer or press
b.  Decker filtrate reuse
*.  Bleaching
a.  Countercurrent washing          (1)
b.  Evaporate caustic extraction
   stage filcrate

5.  Evaporation and Recovery Areas
a.  Replace barometric condenser
b.  Add boil out tank
c.  Neutralize spent sulfite
   liquor
d.  Segregate cooling water
e.  Spill collection
f.  Reuse evaporator condensate

6.  Liquor Preparation Area
a.  Spill collection

7.  Paper Mill
a.  Spill collection:
   1 .  Paper machine and
      bleached pulp                X
   2.  Color plant
b.  Improve savea11
c.  High pressure showers for
   wire and felt cleaning          X
d.  White water use for vacuum
   pump sealing                    X
e.  Paper machine white water
   showers for wire cleaning
f.  White water storage for up-
   sets and pulper dilution
g.  Recycle press water             X
h.  Reuse of vacuum pimp water      X
i.  Broke Storage
j .  Vet lap machine                 X
k.  Segregate cooling water
1.  Cleaner rejects to landfill
ra.  White water to pulp mill
n.  Gland water reduction
                                            445

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                                    TABLE VIII-33  (Continued)
                                                          Subcategory
Control
                                 Deink
                                          Tiiiue     Piperboard   Waitepaper-
                                          Froa        Fro*         Molded
                                         Waitepaper  Wa»tepaper    Product*
Builden'
Paper and
 Roofing
  Felt
8. Steaa Plant and Utility Areai
a. Segregate cooling water
b. Lagoon Cor boiler blowdovn
   and backvaab wateri
9.
a.
b.
c.
d.
e.
Hiacellaneoui Controli
Cooling tower
pH Monitor
Level all rat
Filten
Recycle of effluent

X
-
-
X
X

X
-
X
X
X X

X
-
-
X
•
(1) Countercurreot cashing wai  included  only  for  the Ttnue product lector of the
    Drink lubcategory.
                                          446

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                                                    TABLE VI11-34

                                  PRODUCTION PROCESS CONTROLS FORMING THE BASIS OF
                                          COST ESTIMATES FOR NSPS OPTION 2
                                                NONINTEGRATED SEGMENT
                                                              Subcategory
Control
                            Nonintegrated- Nonintegrated-
                             Fine Papers   Tissue Paperj
 Nonintegrated-
Li&htweight Papers
 Nonintegrated-
  Filter and    Nonintegrated-
Noowoven Papers   Paperboard
1 .  Woodya r 'd/ Wood room
a.  Close-up or dry woodyard
   and barking operation
b.  Segregate cooling water

2.  Pulp Mill
a.  Reuse blow condensates
b .  Reduce groundwood thick-
   ener overflow
c.  Spill collection

3.  Washers and Screen Room
a.  Add 3rd or 4th stage
   washer or press
b .  Decker filtrate reuse

4.  Bleaching
a.  Counter-current washing
b .  Evaporate caustic extraction
   stage filtrate

5.  Evaporation and Recovery Areas
a .  Replace barometric condenser
b.  Add boil out tank
c .  Neutralize spent sulf ite
   liquor
d.  Segregate cooling water
e.  Spill collection
f .  Reuse evaporator condensate

6^jJiLotuor Preparation Area
a.  Spill collection

7.  Paper Mill
a.  Spill collection:
   1 .  Paper machine and
      bleached pulp
   2.  Color plant
b.  Improve saveall
c.  High pressure showers for
   wire and felt cleaning
d.  White water use for vacuum
   pump sealing
e .  Paper machine white wa ter
   showers for wire cleaning
f.  White water storage for up-
   sets and pulper dilution
g.  Re cy depress wa ter
h.  Reuse of vacuum pump water
i .  Broke Storage
j .  Wet lap machine
k.  Segregate cooling water
1.  Cleaner rejects to landfill
m.  White water co pulp mill
n.  Gland water reduction
8. Steam Plant and Utility Areas
a. Segregate cooling water         X
b. Lagoon for boiler blowdown
   and backwash waters             X
9^. Misjrelj.jneous Controls
j. Cooling tower
b. pH monitor
c. Leve L alarms
d. Filters
e. Recycle of effluent
                                                     447

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application  of  each  of the production process controls available to
the  mills  within  a  specific  subcategory.   However,  in   several
instances  where  only  limited  data  were  available,  EPA  found it
necessary to predict the raw waste load reductions attainable  through
the  application of specific production process controls identified as
NSPS Option 2 technologies.

The controls that serve as the basis of reductions of raw waste  loads
beyond  those  considered  in  developing BPT effluent limitations are
presented in Tables VIII-35 through VIII-37.  The controls  are  those
that  can be employed at mills in each subcategory to achieve the NSPS
Option 2 raw waste loads developed from actual mill data (presented in
Section V) for each subcategory.

     Dissolving Kraft - The dissolving kraft subcategory is  comprised
of three mills.  Raw waste load data for these mills and the raw waste
loads  that  formed the basis of BPT are presented in Table V-l.   Very
few mills are included in this subcategory and varying percentages  of
dissolving  pulp  are  produced at these mills; therefore, the general
methodology was not used as there was insufficient raw waste load data
available corresponding to the production of  100  percent  dissolving
kraft  pulp.   EPA  determined  NSPS  Option  2  raw  waste  loads  by
subtracting predicted waste load reductions from the raw  waste  loads
that  formed  the  basis of BPT.  Estimates were made of the raw waste
load reductions attainable  through  the  implementation  of  specific
production  process  controls  applicable  to  this  subcategory.   As
summarized, the subcategory average raw waste loads are:  flow - 198.2
kl/kkg (47.5 kgal/t), BOD5_ - 69.6 kg/kkg (139.1 Ib/t), and TSS - 111.3
kg/kkg (222.6 Ib/t).  The raw waste loads for BPT are:  flow  -  230.0
kl/kkg (55.1 kgal/t), BOD5_ - 66.5 kg/kkg (133.0 Ib/t), and TSS - 113.0
kg/kkg (226.0 Ib/t).

The   production   process  controls  that  have  been  identified  as
applicable in this subcategory and  that  form  the  basis  for  EPA's
estimates  of  attainable  raw  waste  load  reductions  are: improved
brownstock washing, improved utilization of digester blow condensates,
brownstock and  bleached  pulp  spill  collection,  additional   liquor
storage,  and  improved white water use.  The total projected flow and
BOD5. reductions are 18.4 kl/kkg (4.4  kgal/t)  and  8.2  kg/kkg  (16.3
Ib/t),   respectively.   Because  each  of  these  production  process
controls has  been  employed  at  dissolving  kraft  mills  and/or  at
bleached  kraft  mills  representative  of  other  subcategories,  EPA
believes that these technologies can be applied at new source mills in
this subcategory.  Based on engineering calculations supported by  the
literature   or  material  balances,  the  Agency  believes  that  the
application of these  production  process  controls  can  achieve  the
required degree of effluent reduction.
                                  448

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                                                                          TAI'LE VIJJ-35

                                              PRODUCTION PROCESS CONTROLS IN ADDITION TO THOSE THAT FORM THE  BASIS  OF
                                                                    BPT THAT CAN BE EMPLOYED TO
                                                               ACHIEVE NSPS OPTION 2 RAW WASTE LOADS
                                                                       INTEGRATED SEGMENT
                                                                           _	Subcategory	
Control
             Market      BCT                 UP-                 Unbleached  Dissolving               Ground-    wo mi-
Dissolving  Bleached   Bleached  Alkaline- ble.-iched    Semi-      Kraft and    Siilfite  Papergrade     wood-     CNN
  Kraft      Kraft	Kraft	Lin.?J	]?.'a_lX	Chemical  Semi-Chemical	Pulj>	Suirite2  	TMI>    _ Paju-rs
1. Woodyard/Woodroom
a. Close-up or dry woodyard
   and barking operation
b. Segregate cooling water        X

2. Pulp Mill
a. Reuse blow condensates         X
b. Reduce gronndwood thick-
   ener overflow
c. Spill collection               X

3. Washers and Screen Room
a. Add 3rd or 4th stage
   washer or press                X
b. Decker filtrate reuse

4. Bleaching
a. Countercurrent washing
b. Evaporate caustic extraction
   stage filtrate

5. Evaporation and Recovery Areas
a. Replace barometric condenser   X
b. Add boil out tank              X
c. Segregate cooling water
d. Spill collection               X

6. Liquor Preparation Area
a. Spill collection               X

7. Paper Mill
a. Spill collection:
   I. Paper machine and
      bleached pulp               X
   2. Color plant
                                                                                                                                                         Grnunil-
                                                                                                                                                          K i rrr
                                                                                                                                                         I'anr is

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                                                                      TABLE VIII-35  (Continued)


                                                                     	    _ 	Stihcategory
                                                                                                                                                   Ground-    liround-
                                             Market       BCT                 Un-                  IJnblcached  Dissolving               Ground-     wood-      wood-
                               Uissolving   Bleached   Bleached Alka1i ne-  bleached     Semi-       Kraf t and    Sulfi te  Papergrade     wood-      CHN        Fine
Control	 _	    _ KraU	Kcaft	 	_Krdtl  ._   FJM_ll.   -****<:	CluMiiical _^cmij:t:h^BiiraJ^  _  Pylj>  _SiiJlite2       IMP      fty??.™    _•*!!_>?"_

'_• j>aVcf  H' 1 {_  (cont inued)
b. Improve saved II                 ------             _             __           ___
c. High pressure  Hbowers for
   wire and  ft-lt  (leaning         X-----             -             X-           ___
d. White  water use  for vacuum
   pu«p sealing                    X-XX--             -             XX           -XX
e. Paper  machine  white water
   showem for wire  cleaning      ______             _             __           ___
f. Wh i te  water storage for itp-
   sels and  j>ulj>*-r  dilution       ______             -             x-           -X-
g. Recycle press  waler            X---XX             X             -X           -XX
h. Hcn.se  of  vacuum  t>unu water     ---XXX             X             XX           -XX
i . Broke  storage                   ______             _             __           ___
j. Wet lap machine                 ---X--             -             -X           XXX
k. Segregate cooling water        ------             _             --           ___
1. Cleaner rejects  to landfill
B. White  water to pulp Mill       ------             -             x-           ___
n. Gland  water reduction          ______             -             --.           ___

?_• ??*•*  JM^iL?- ?nrt  ut.*J_ity ._*£*•*
a. St'gregjte cooling water        X-----             -             X-           --X
b. Lagtxiii for hoi ler blowdown
   and bdckwdbh  w/itrra            X           X           X          X         -          -             -             -          X

S. Hi bceUaiieoiis  Control a
a. li i gh 1 eve I a 1 a rres             -            -____             .             _          -           „__
b. Coo ling I owe r                  ------             -             _____
c. Recycle of effluent           -            _____             _             __           __-
 includes Fine  blcached Kraft and Soda  subcatcgorLes.

 Includes P<*t>orgrade  Sulfite (Blow Pit  Wash)  and Papergrade Sultite (Drum Wash) subcategor ies.

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                                          TABLE VIII-J6

              PRODUCTION PROCESS CONTROLS IN ADDITION' TO THOSE THAT FORM THE BASIS
                                 OF EPT THAT CAN BE EMPLOYED TO
                              ACHIEVE NSPS OPTION 2 RAW WASTE LOADS
                                    SECONDARY FIBERS SEGMENT
                                                           Subcategory
Control
Tissue
From
Deink Wastepaper
Paperboard
From
Wastepaper
Wastepaper-
Molded
Products
Builders '
Paper and
Roofing
Felt
1. Vcodyard/W'oodroom
a. Close-up or dry
   woodyard and
   barking operation
b. Segregate cooling water

2. Pulp Hill
a. Reuse blow condensates
b. Reduce groundwood thick-
   ener overflow
c. Spill collection

3. Washers and Screen Room
a. Add 3rd or 4th stage
   washer or press
b. Decker filtrate reuse
4. Bleaching
a. Countercurrent washing
b. Evaporate caustic extraction
   stage filtrate

5. Evaporation and Recovery Areas
a. Replace barometric condenser
b. Add ooil out tanK
c. Segregate cooling water
d. Spill collection

6. Liquor Preparation Area
a. Spill collection

7. Paper Mill
a. Spill collection:
   1. Paper machine and
      bleached pulp
   2. Color plant
b. Improve saveall
c. High pressure showers for
   wire and felt cleaning
d. White water use for vacuum
   pump sealing
e. Paper machine white water
   showers for wire cleaning
f. White water storage for up-
   sets and pulper dilution
g. Recycle press water
h. Reuse of vacuum pump water
i. Broke storage
j. Wet lap machine
k. Segregate cooling water
1. Cleaner rejects to landfill
m. White water to pulp mill
n. Gland water reduction
8. Steam Plant and Utility Areas
3. Segregate cooling water
b. Lagoon for boiler biowdown
   and backwash waters
9. Miscellaneous Controls
a. High  level alarms
b. Cooling tower
c. Recycle of effluent
B-These production process controls were erroneously included as BPT production process
  controls.  They were included in EPA's determination ot N'SPS Opt.ion 2  raw waste  loads.
                                              451

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                                                    TABLE VIII-37

                        PRODUCTION PROCESS CONTROLS IN ADDITION TO THOSE THAT FORM THE BASIS
                                           OF BPT THAT CAN BE EMPLOYED TO
                                        ACHIEVE NSPS OPTION 2 RAW WASTE LOADS
                                                NONINTEGRATED SEGMENT


                            	Subcategory	
                                                                                  Nonintegrated-
                            Nonintegrated- Nonintegrated-    Nonintegrated-        Filter and    Nonintegrated-
Control	Fine Papers   Tissue Papers	Lightweight Papers   Nonwoven Papers   Paperboard

1.  Woodyard/Woodroom
a.  Close-up or dry woodyard
   and barking operation           ...                    _
b.  Segregate cooling water         -                                                    -                -

2.  Pulp Mill
a.  Reuse blow condensates          ...                    .
b.  Reduce groundwood thick-
   ener overflow                   ...                    -
c.  Spill collection                ...                    .

3.  Washers and Screen Room
a.  Add 3rd or 4th stage
   washer or press                 ...                    .
b.  Decker filtrate reuse           -                                                    -

4.  Bleaching
a.  Countercurrent washing          ...                    .
b.  Evaporate caustic extraction
   stage filtrate                  ...                    -

5.  Evaporation and Recovery Areas
i.  .Tspljce bjrc.netric condenser    -                                                    -
b.  Add boil out tank               ...                    -
c.  Segregate cooling water         -                                                    -
d.  Spill collection                ...                    .

6.  Liquor Preparation Area
a.  Spill collection                ...                    -

7.  Paper Mill
a.  Spill collection:
   1.  Paper machine and
      bleached pulp                X              X                                     X                -
   2-  Color plant                  X              -                -                    -                -
b.  Improve saveall                 -              -                X                    X                -
c.  High pressure showers for
   wire and felt cleaning          X              -                X                    X                -
d.  White water use for vacuum
   pump sealing                    X              -                X                                     X
e.  Paper machine white water
   showers for wire cleaning       ...                    XX
f.  White water storage for up-
   sets and pulper dilution                                        X                    -
g.  Recycle press water             ...                    -                X
h.  Reuse of vacuum pump water      X              -                -                    -                X
i.  Broke storage                                                   X                    -                -
j.  Wet lap machine                 -                                                    -
k.  Segregate cooling water         XXX                    -                -
1.  Cleaner rejects to landfill     -                                                    -
m.  White water to pulp mill        ...                    -
n.  Gland water reduction           ...                    -                -

8.  Steam Plant and Utility Areas
a.  Segregate cooling water         ...                    XX
b.  Lagoon for boiler blowdown
   and backwash waters             XXX                    -                -

9.  Miscellaneous Controls
a.  High level alarms               -              X                -                    -
b.  Cooling tower                   -                               -                    -                X
c.  Recycle of effluent             -              -                X                    XX


                                                        452

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The  resulting  NSPS  Option  2  flow  and  BOD5_  raw  waste loads are
presented below:


      Dissolving Kraft - Development of Option 2 Raw Waste Loads

                                 Flow                   BOD5_
                            kl/kkq (kqal/t)         kq/kkq (Ib/t)

BPT RWL                      230.0  (55.1)          66.5  (133.0)

Reductions Resulting from
Application of Specific
Production Process Con-
trols                         18.4  (4.4)            8.2  (16.3)

Option 2 RWL                 211.6  (50.7)          58.4  (116.7)

The TSS raw waste load for Option 2 has been assumed to be the same as
that used as the basis for  BPT,  or  113.0  kg/kkg  (226.0  Ib/t)  of
product.

     Market  Bleached  Kraft  -  Data  presented  in Table V-2 for the
production of both bleached hardwood kraft (HWK) and bleached softwood
kraft (SWK) pulp are arranged in order  of  increasing  softwood  pulp
production.   Of  the  mills  where  raw waste loads are lower than or
equal to those used to develop BPT, raw waste load BODj[ is essentially
the  same  at  both  hardwood  and  softwood  mills.   However,   when
considering  flow data, mills where bleached softwood pulp is produced
have a higher  average  flow.   The  average  flow  for  softwood  and
hardwood  mills  where flows are less than that which formed the basis
of BPT are 152.7 kl/kkg (36.6 kgal/t) and  120.6 kl/kkg (28.9  kgal/t),
respectively.   The  proposed  Option  2   flow  has been chosen as the
higher of the two, 152.7 kl/kkg (36.6 kgal/t).  This approach gives an
adequate allowance for all types  of  market  kraft  mills:  hardwood,
softwood,  and  mixtures of both.  The average BOD5_ raw waste load for
softwood and hardwood mills where BOD5_ raw waste loads are  less  than
the BPT basis are 29.3 kg/kkg (58.6 Ib/t)  and 26.6 kg/kkg (53.2 Ib/t),
respectively.   Since  the  data  for  both  types  of  wood pulps are
substantially the same, the higher BOD5_ raw waste  load,  29.3  kg/kkg
(58.6  Ib/t),  has  been assumed.  The TSS raw waste load for Option 2
has been assumed to be the same as that used as the basis of BPT.   In
summary,  the  Option  2 raw waste loads for the market bleached kraft
subcategory are: flow - 152.7 kl/kkg (36.6 kgal/t), BOD5. - 29.3 kg/kkg
(58.6 Ib/t), and TSS - 45.0 kg/kkg (90.0 Ib/t).

     BCT (Paperboard, Coarse, and Tissue)  Bleached Kraft -  Raw  waste
load  data  for  bleached kraft mills where paperboard, coarse papers,
and tissue papers are manufactured are presented in Table V-3.  Of the
eight mills for which data are presented,  five are achieving flows and
three are achieving BOD5_ raw waste loads   that  are  less  than  those
which  formed  the  basis  of  BPT.   For  one  of  the mills  (030039)
attaining a lower flow and BODjr raw waste  load,  data  correspond  to
                               453

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biological  treatment  plant influent rather than to a true raw waste.
These data were not used in any calculations of attainable NSPS Option
2 raw waste loads.  Option 2 raw waste loads for this subcategory  are
based  on  the  averages of those mills where raw waste loads that are
lower  than  those  which  formed  the  basis  of  BPT  are  attained.
Application  of  this  methodology  yields  Option 2 flow and BOD5_ raw
waste loads of 132.3 kl/kkg (31.7 kgal/t) and 35.1 kg/kkg (70.2 lb/t)f
respectively.  The TSS raw waste load for Option 2 has been assumed to
be the same as that used as the basis of BPT, or  66.5  kg/kkg  (133.0
lb/t) of product.

     Alkaline-Fine (Fine Bleached Kraft and Soda Subcategories) - Data
are  presented  in  Table  V-4 for 20 mills characteristic of the fine
bleached kraft subcategory.  There are 15 mills  in  this  subcategory
where  flow  and/or  BOD5_  raw  waste loads are lower than those which
formed  the  basis  of  BPT.   Option  2  raw  waste  loads  for  this
subcategory  are  based on the averages of those mills where raw waste
loads that are lower than those which formed  the  basis  of  BPT  are
attained.   Application  of  this methodology yields Option 2 flow and
BOD5_ raw waste loads of 104.7 kl/kkg (25.1  kgal/t)  and  27.1  kg/kkg
(54.1  lb/t),  respectively.   The TSS raw waste load for Option 2 has
been assumed to be the same as that used as the basis of BPT, or  75.0
kg/kkg (150.0 lb/t) of product.

     Unbleached  Kraft  -  Data  are  presented in Table V-5 for mills
characteristic  of  this  subcategory.   In  the'  development  of  BPT
effluent  limitations  guidelines,  the  unbleached  kraft subcategory
included mills manufacturing unbleached kraft linerboard, bag,  and/or
other  mixed  products.  Data provided in response to the data request
program suggest that there are differences  in  waste  characteristics
for  mills  manufacturing  linerboard and bag or other mixed products.
The following summarizes the subcategory averages for the two  product
sectors.


               Unbleached Kraft-Raw Waste Load Summary

                       Flow            BOD5            TSS
                  kl/kkq (kgal/t)  kq/kkq (lb/t)  kq/kkq  (lb/t)

Unbleached Kraft -
 Linerboard:         47.6  (11.4)     16.6 (33.2)     15.8  (31.6)

Unbleached Kraft -
 Bag and Other
 Products:          103.5  (24.8)     24.3 (48.6)     31.4  (62.8)
                                454

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In  establishing NSPS Option 2 raw waste loads, EPA evaluated data for
both the linerboard and bag product sectors.  NSPS Option 2 raw  waste
loads  for  the linerboard product sector are based on the averages of
those mills where raw waste loadings that are lower than  those  which
formed  the basis of BPT are attained.  For the bag and other products
product sector, NSPS Option  2  raw  waste  loads  are  based  on  the
averages  of  those  mills where (a) raw waste flow is lower than that
which formed the basis of BPT and (b) raw waste BOD5_ is lower than the
product  sector  average  raw  waste  load.    Application   of   this
methodology  yields  unbleached  kraft-linerboard  Option  2 raw waste
loads for flow and BOD5_ of 39.2 kl/kkg (9.4 kgal/t)  and  12.4  kg/kkg
(24.8 Ib/t), respectively, and unbleached kraft-bag and other products
raw  waste  loads  for  flow and BOD5_ of 47.6 kl/kkg (11.4 kgal/t) and
16.9 kg/kkg (33.8 Ib/t), respectively.  The TSS  Option  2  raw  waste
loads  for  both  product  sectors have been assumed to be the same as
that used as the basis of BPT, or 21.9 kg/kkg (43.8 Ib/t) of product.

     Semi-Chemical - Available raw waste load data  for  semi-chemical
mills are presented in Table V-6.  The data are presented according to
wastepaper  use  and  use  of  liquor  recovery.   Variable amounts of
wastepaper are utilized at mills  in  this  subcategory  according  to
relative  market  conditions  and pricing.  Because of this variation,
two mill groups were considered in the development of  NSPS  Option  2
raw  waste  loads.   The  groups  are:  (a) mills with liquor recovery
where less than one-third of the furnish is wastepaper and  (b)  mills
with  liquor  recovery  where  more  than  one-third of the furnish is
wastepaper.  Review of the data in  Table  V-6  indicates  significant
differences  in  flow between the two groups [35.9 kl/kkg (8.6 kgal/t)
versus 18.8 kl/kkg (4.5 kgal/t)], but  no  significant  difference  in
BOD5  [22.1  kg/kkg  (44.1  Ib/t)  versus  23.9  kg/kkg  (47.8 Ib/t)].
Therefore, the Option 2 raw waste load for flow is based on an average
of  those  mills  with  liquor  recovery  where  less  than  one-third
wastepaper  is  processed  and  a raw waste load lower than that which
formed the basis of BPT is attained.  The Option 2 raw waste load  for
BOD5_ is based on data from both groups of mills where a BOD5_ raw waste
load  lower  than  that  which  formed  the  basis of BPT is attained.
Application of this methodology yields NSPS Option 2 raw  waste  loads
of  flow  and  BOD5 of 30.5 kl/kkg (7.3 kgal/t), and 17.6 kg/kkg (35.2
Ib/t), respectively.   The TSS raw waste load for  Option  2  has  been
assumed  to be the same as that which formed the basis of BPT, or 12.3
kg/kkg (24.6 Ib/t) of product.

     Unbleached Kraft and Semi-Chemical - Table V-7 presents available
raw waste load data for this subcategory.  NSPS  Option  2  raw  waste
loads  for this subcategory are based on averages of those mills where
raw waste loads that are lower than those which formed  the  basis  of
BPT are attained.  Application of this methodology yields Option 2 raw
waste  loads  for  flow and BOD5_ of 48.0 kl/kkg (11.5 kgal/t) and 16.3
kg/kkg (32.5 Ib/t), resepctively.  The TSS raw waste load for Option 2
has been assumed to be the same as that which formed the basis of BPT,
or 20.5 kg/kkg (41.0 Ib/t) of product.
                                  455

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     Dissolving Sulfite Pulp - Table V-8 presents available raw  waste
load  data  for  this  subcategory.    In previous effluent limitations
guidelines development, EPA recognized that a variety of products  are
made  at  dissolving sulfite pulp mills that result in different waste
characteristics.(48)  However,  in  the  data  request  program,  only
limited  data  were provided for this subcategory on raw waste load by
product  types.   Consequently,   EPA  estimated  the  raw  waste  load
reductions  attainable  through the application of specific production
process controls.

Several  specific  production  process   control   modifications   are
applicable  in  this subcategory and are shown in Table VIII-35.  Each
of these controls has been employed at dissolving sulfite  pulp  mills
and,   therefore,    can  be  applied  at  new  source  mills  in  this
subcategory.  In general,  most of the items under consideration result
in minor  flow  reductions  with  the  exception  of  recycle  of  the
hydraulic barking water.  Flow reductions resulting from cooling water
segregation,  more  extensive use of white water in the pulp and paper
mills, and additional spill collection can reduce wastewater discharge
by 29.2 kl/kkg  (7.0 kgal/t).  Additional applicable production process
controls include implementation of liquor spill and pulp  dryer  spill
collection systems and improved recycle of decker filtrate.  Predicted
BOD5i  reductions  resulting  from the application of these controls in
addition to white water reuse total 5.0 kg/kkg (10.0  Ib/t).   Another
applicable  control,  caustic  filtrate  evaporation,  results in BOD^
reductions varying from 41.4 kg/kkg  (82.8  Ib/t)  for  the  nitration
grade  to  104.4  kg/kkg  (208.8  Ib/t)  for  the acetate grade.  This
technology is an expensive production process control,  yet  one  that
can  result  in  significant BODj> reduction.  This technology has been
employed at mills 046002 and 046006.

The resulting NSPS Option 2 BODS^ raw waste loads are presented  below.
Based  on  engineering  calculations  supported  by  the literature or
material balances, EPA believes that the application of  the  specific
production  process controls identified above can achieve the required
degree of effluent reduction.  This is further supported by  available
data.   The controls on which NSPS Option 2 are based are installed at
mill 046006.  As illustrated in Table V-8, when acetate grade pulp  is
produced  at  mill  046006,  the NSPS Option 2 flow and BOD5^ raw waste
loads are attained.
                                 456

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    Dissolving Sulf ite-Development of Option 2 BOD5_ Raw Waste Load
                                    BOD5_ - kg/kkg (Ib/t)
                   Nitration      Viscose      Cellophane     Acetate

BPT - RWL           137 (274)     156 (312)    181.5 (363)    266.0 (531. 9)1
Reductions Resulting
from Application of
Specific Production
Process Controls    46.4 (92.8)   63.4 (126.8)  71 .9 (143.8)  109.4 (218.8)

Option 2 BOD5_ RWL   90.6 (181.2)  92.6 (185.2) 109.6 (219.2)  156.6 (313.1)
     discussed in Section II, the  BPT  BOD5_  limitation  for  acetate
grade  production  in  the  dissolving  sulfite  pulp  subcategory was
remanded by the Court of Appeals.  The Agency has not yet  promulgated
the  BOD5_  limitation.  Therefore, a BODj> raw waste load corresponding
to BPT effluent limitations has not yet been  established.   The  BOD5_
raw  waste  load of 266.0 kg/kkg  (531.9 Ib/t) is representative of the
BOD5_ raw waste load associated with the production  of  acetate  grade
dissolving  sulfite  pulp at the time the remanded BPT BOD5_ limitation
was promulgated in 1977.]

The flow basis of BPT is 275.0 kl/kkg (66.0 kgal/t) except  for  mills
where  acetate  grade pulp is produced where the flow basis of BPT has
been assumed to be 303.4 kl/kkg  (72.7 kgal/t).   (The  flow  value  of
303.4  kl/kkg  (72.7  kgal/t) is representative of the wastewater flow
rate associated  with  the  production  of  acetate  grade  dissolving
sulfite  pulp  at  the  time  the  remanded  BPT  BOD5_  limitation was
promulgated  in  1977.)   Flow  reduction  through  implementation  of
production process controls is 29.2 kl/kkg (7.0 kgal/t).  This results
in  an  Option 2 flow of 246.2 kl/kkg (59.0 kgal/t) for the nitration,
viscose, and cellophane pulp grades and 274.2 kl/kkg (65.7 kgal/t) for
the acetate pulp grade.  The TSS raw waste load for Option 2 has  been
assumed  to be the same as that which formed the basis of BPT, or 92.5
kg/kkg (185.0 Ib/t) of product.

     Paperqrade  Sulfite  (Papergrade  Sulfite  (Blow  Pit  Wash)  and
Paperqrade  Sulfite  (Drum  Wash)  Subcateqories) - Table V-9 presents
available  raw  waste  load  data  for  this  subcategory.    In   the
development  of  BPT  effluent  limitations,  two  papergrade  sulfite
subcategories were established: blow pit wash and drum wash.  However,
as discussed previously in  Sections  IV  and  V,  the  percentage  of
sulfite pulp produced on-site is a better indication of raw waste load
characteristics  than  the  type of pulp washing system employed.  The
NSPS Option 2 flow is  based  on  flow  data  for  those  mills  where
discharge  flow  is lower than that defined by the regression equation
presented previously.  The percentage reductions in  flow  below  that
defined by the regression equation, taking into account the percentage
of  sulfite pulp produced on-site, were averaged and form the basis of
the NSPS Option 2 flow.  At four mills, discharge flow  is  less  than
the  predicted  flow,  with  the  average  percent  reduction being 28
percent.  Therefore, NSPS Option 2 flow is defined as  72  percent  of
the flow defined by the regression analysis.
                                457

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EPA  based  the  NSPS  Option  2 BOD5_ raw waste load on the average of
those papergrade sulfite mills where the BOD5_ raw waste load is  lower
than  that which formed the basis of BPT, or 66.1 kg/kkg (132.2 Ib/t).
As discussed in Section V, there is no definable relationship  between
BOD5_  raw  waste  load  and  the  percentage  of sulfite pulp produced
on-site.  Because  the  average  quantity  of  sulfite  pulp  produced
on-site  is  58  percent of the raw material furnish, EPA assumed that
this BOD5_ raw waste load is representative of a mill where 58  percent
of  the  raw  material  furnish  is  sulfite  pulp  produced  on-site.
Therefore, for a model mill where  58  percent  of  the  raw  material
furnish  is  sulfite pulp produced on-site, Option 2 flow and BOD5_ raw
waste loads would be 101.8 kl/kkg (24.4 kgal/t) and 66.1 kg/kkg (132.2
Ib/t), respectively.  The TSS raw waste load for Option 2 was  assumed
to  be  the same as that which formed the basis of BPT, or 90.0 kg/kkg
(180.0 Ib/t) of product.  The BOD5_ and  TSS  concentrations  for  this
model mill form the basis of BOD5_ and TSS raw waste concentrations for
NSPS  Option  2, regardless of the percentage of sulfite pulp produced
on-site.

     Groundwood-Thermo-Mechanical - Table V-10 presents available  raw
waste  load data for this subcategory.  As explained in Section V, the
flow and BOD5_ raw waste loads that formed the basis  of  BPT  effluent
limitations  are  not  reflective of raw waste loads characteristic of
the   groundwood-thermo-mechanical   subcategory.    Therefore,    EPA
developed  revised  BPT  raw  waste  loads for this subcategory.  NSPS
Option 2 raw waste loads are based on averages of those mils  in  this
subcategory  where raw waste loads that are lower than the revised BPT
raw waste loads are attained.  Application of this methodology  yields
Option  2  raw  waste  loads  for  flow  and BOD5_ of 57.6 kl/kkg  (13.8
kgal/t) and 17.6 kg/kkg (35.2 Ib/t), respectively.  The TSS raw  waste
load for Option 2 has been assumed to be the same as that which formed
the basis of BPT, or 39.9 kg/kkg (79.8 Ib/t) of product.

     Groundwood-CMN  Papers  - Table V-ll presents available raw waste
load data formills  in  this  subcategory.   At  no  mills  in  this
subcategory  are  BOD5_  raw  waste loads being attained that are  lower
than raw waste loads that  formed  the  basis  of  BPT.   Because  the
existing  performance is inadequate and does not achieve the pollution
reduction that is possible at mills  in  this  subcategory,  the  NSPS
Option  2  raw  waste loads were based on the subtraction of predicted
raw waste load reductions resulting from implementation  of  available
production  process  controls  applicable at mills in  this subcategory
from the raw waste loads that formed the basis of BPT.

The  production  process  controls  that  have  been    identified   as
applicable in this subcategory that form the basis for EPA's estimates
of  attainable  raw  waste load reductions are: segregation of  cooling
water in the woodroom, addition of pulp  mill  and  paper  mill   spill
collection  systems,  use  of  white water in vacuum pumps, recycle of
press effluent, and addition of centralized storage capacity for  white
water reuse.  The total projected flow and BOD5_  reductions  are  29.2
kl/kkg  (7.0 kgal/t) and 2.9 kg/kkg  (5.7  lbs/t)7 respectively.   Because
each  of  these  production  process controls has been employed at  (a)
                                 458

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groundwood-CMN mills, (b) groundwood  mills  representative  of  other
subcategories,  or (c) mills in other subcategories where similar pulp
or  papermaking  processes  are  employed,  EPA  believes  that  these
technologies  can  be applied at new source mills in this subcategory.
Based on engineering  calculations  supported  by  the  literature  or
material  balances,  the Agency believes that the application of these
production  process  controls  can  achieve  the  required  degree  of
effluent  reduction.   The  resulting  NSPS Option 2 flow and BOD5_ raw
waste loads are presented below:


    Groundwood-CMN Papers—Development of Option 2 Raw Waste Loads

                                Flow          BOD5_
                           kl/kkq (kgal/t)  kq/kkq (Ib/t)

BPT RWL                     99.3 (23.8)      17.4 (34.8)

Reductions Resulting From
Implementation of Specific
Production Process
Controls                    29.2 ( 7.0)       2.9 ( 5.7)

Option 2 RWL                70.1 (16.8)      14.6 (29.1)


The TSS raw waste load for Option 2 has been assumed to be the same as
that which formed the basis of BPT, or 48.5 kg/kkg  (97.0  Ib/ton)  of
product.

     Groundwood-Fine  Papers  - Available raw waste load data for this
subcategory are presented in Table V-12.   NSPS  Option  2  raw  waste
loads  for this subcategory are based on averages of those mills where
raw waste loads that are lower than those which formed  the  basis  of
BPT are attained.  Application of this methodology yields Option 2 raw
waste  loads  for  flow and BOD5 of 64.3 kl/kkg (15.4 kgal/t) and 12.5
kg/kkg (24.9 Ib/t), respectively.  The TSS raw waste load for Option  2
has been assumed to be the same as that which formed the basis of BPT,
or 52.5 kg/kkg (105.0 Ib/t) of product.

     Deink  -  Available  raw  waste  load  data  for  mills  in  this
subcategory  are presented in Table V-14.  A delineation has been made
between mills producing fine papers, tissue papers, and newsprint.

For mills where fine papers are produced from deinked wastepaper, NSPS
Option 2 raw waste loads are based on averages of  those  mills  where
raw  waste  loads  that are lower than those which formed the basis of
BPT are attained.  Application of this methodology yields Option 2 raw
waste loads for flow and BOD5_ of 66.4 kl/kkg (15.9 kgal/ton) and  37.3
kg/kkg (74.6 Ib/ton), respectively.

For  mills  where  tissue papers are produced from deinked wastepaper,
NSPS Option 2 raw waste loads are based on  averages  of  those  mills
                                  459

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where raw waste loads that are lower than those which formed the basis
of  BPT are attained.  Application of this methodology yields Option 2
raw waste loads for flow and BOD5_ of 81.4 kl/kkg (19.5  kgal/ton)  and
61.3 kg/kkg (122.6 Ib/ton), respectively.

As  explained  earlier  in  this section, for mills where newsprint is
produced from deinked wastepaper,  NSPS Option 2 is identical  to  NSPS
Option  1 .   Flow and BODj[ raw waste loads are based on the average raw
waste loads of all mills in this  product  sector.   This  results  in
Option  2  flow  and BOD5_ raw waste loads of 67.6 kl/kkg (16.2 kgal/t)
and 15.9 kg/kkg (31.7 lb/t), respectively.

For all three product sectors, the TSS raw waste load for Option 2 has
been assumed to be the same as that which formed the basis of BPT,  or
202.5 kg/kkg (405 lb/t) of product.

     Tissue   from   Wastepaper   -  In  the  tissue  from  wastepaper
subcategory, extensive use of production process  controls  to  reduce
wastewater  discharge  is practiced.  As seen in Table V-15, raw waste
load data were initially reviewed taking into account  the  production
of  industrial  and  sanitary  tissue.   It  was  determined  that  no
significant differences exist between the  two  product  sectors.   In
addition,   self-contained  mills have been identified where both types
of tissue are produced.

NSPS Option 2 raw waste  loads  for  this  subcategory  are  based  on
averages  of  those  mills  where  raw waste loads that are lower than
those which formed the basis  of  BPT  are  attained.   Mills  090006,
100012,  105007,  and  100014  are  excluded  from  Option 2 raw waste
averages because extensive wastewater  recycle  is  employed  and  raw
waste flows are significantly lower than for other mills.  Application
of  this methodology yields Option 2 raw waste loads for flow and BOD5_
of 68.0 kl/kkg (16.3 kgal/t) and 9.7 kg/kkg (19.3 lb/t), respectively.
The TSS raw waste load for Option 2 has been assumed to be the same as
that which formed the basis of BPT, or 110.5 kg/kkg  (221.0  lb/t)  of
product.

     Paperboard  from  Wastepaper  - Available raw waste load data for
mills in this subcategory are presented in Table V-16.   As  discussed
previously, EPA determined that BOD5^ raw waste loads are substantially
higher  when  recycled corrugating medium is processed than when other
types of wastepaper are processed.  No such correlation exists between
wastewater  flow  and  the  type  of  furnish  used.    As   discussed
previously,  two  subcategory  subdivisions  have  been  identified to
account for BOD5_ raw waste load differences that result from the  type
of furnish used.  NSPS Option 2 flows for each subcategory subdivision
are  based  on  the  average  of those mills where raw waste flows are
lower than those which formed the basis of BPT.  Application  of  this
methodology  yields  NSPS  Option 2 raw waste flow of 13.4 kl/kkg (3.2
kgal/t).  NSPS Option 2 BOD5_  raw  waste  loads  for  the  corrugating
medium  furnish and noncorrugating medium furnish subdivisions are the
same as those which formed the basis of  BPT,  or  23.0  kg/kkg   (46.0
lb/t)  and  11.3  kg/kkg  (22.5 lb/t), respectively.  The TSS raw waste
                                  460

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load for Option 2 has been assumed to be the same as that which formed
the basis of BPT, or 11.0 kg/kkg (21.9 Ib/t) of product.

     Wastepaper-Molded Products - Available raw waste  load  data  for
mills  in this subcategory are presented in Table V-18.   This is a new
subcategory for which BPT is now being promulgated.  A review of  data
request  responses  reveals  that  extensive  recycle  of  effluent is
practiced at several mills.  NSPS Option 2 raw waste loads  are  based
on  averages  for  those  mills  where extensive recycle is practiced.
Application of this methodology yields Option  2  flow  and  BOD5_  raw
waste  loads  of  23.8 kl/kkg (5.7 kgal/t) and 5.5 kg/kkg (10.9 Ib/t),
respectively.  The TSS raw waste load for Option 2 has been assumed to
be the same as that which forms the basis of BPT, or 14.8 kg/kkg (29.6
Ib/t) of product.

     Builders' Paper and Roofing Felt - Raw waste load data for  mills
in  this  subcategory  are presented in Table V-19.  NSPS Option 2 raw
waste loads for this subcategory are based on averages of those  mills
where  raw  waste  loadings that are lower than those which formed the
basis of BPT are attained.  Application  of  this  methodology  yields
Option 2 raw waste loads for flow and BOD5_ of 11.3 kl/kkg (2.7 kgal/t)
and  6.5 kg/kkg (13.0 Ib/t), respectively.  The TSS raw waste load for
Option 2 has been assumed to be the same  as  that  which  formed  the
basis of BPT, or 35 kg/kkg  (70 Ib/t) of product.

     Noninteqrated-Fine  Papers  -  Available  raw waste load data for
mills in this subcategory are presented in Table V-22.   As  discussed
previously in Section IV and V, two subdivisions have been considered:
the  wood  fiber  furnish  subdivision  and  the  cotton fiber furnish
subdivision.  Data were reviewed with  respect  to  waste  significant
grade changes in three specific delineations: none, less than one, and
greater   than   one  waste  significant  grade  change  per  day.   A
correlation is apparent;  flow  and  BOD5_  raw  waste  loads  tend  to
increase  with the frequency of waste significant grade changes.  NSPS
Option 2 raw waste loads for the nonintegrated-fine papers subcategory
are based on  the  highest  averages  for  the  various  grade  change
delineations for mills where raw waste loads that are lower than those
that  formed  the  basis  of  BPT  are  attained.  Application of this
methodology for the wood fiber furnish subdivision yields NSPS  Option
2  raw  waste  loads for flow and BOD5_ of 39.2 kl/kkg (9.4 kgal/t) and
7.5 kg/kkg (14.9 Ib/t), respectively.  Application of this methodology
for the cotton fiber furnish subdivision  yields  NSPS  Option  2  raw
waste  loads  for flow and BOD5 of 130.2 kl/kkg (31.2 kgal/t) and 14.0
kg/kkg (28.0 kg/kkg).  The TSS raw waste load for Option  2  has  been
assumed  to be the same as that which formed the basis of BPT, or 30.8
kg/kkg (61.6 Ib/t) of product for the wood fiber  furnish  subdivision
and  55.2  kg/kkg (110.4 Ib/t) of product for the cotton fiber furnish
subdivision.

     Noninteqrated-Tissue Papers - Available raw waste load  data  for
this  subcategory  are  presented  in  Table V-23.  As was done in the
nonintegrated-fine papers subcategory, data were reviewed taking  into
consideration  the  frequency  of waste significant grade changes.  In
                                461

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general, wastewater discharge and BOD5_ raw waste loads  increase  with
an increase in the frequency of grade changes.

NSPS  Option  2  raw waste loads for this subcategory are based on the
highest averages for the various grade change delineations  for  mills
where raw waste loads that are lower than those which formed the basis
of  BPT are attained.  Application of this methodology yields Option 2
raw waste loads for flow and BOD5_ of 79.7 kg/kkg (19.1 kgal/t) and 9.0
kg/kkg  (17.9 Ib/t), respectively.  The Option 2 flow is based on those
mills with greater than one waste significant grade  change  per  day.
The  Option 2 BOD5_ raw waste load is based on those mills with between
zero and less than one waste significant grade change  per  day.   The
TSS  raw  waste  load  for Option 2 has been assumed to be the same as
that which forms the basis of BPT,  or  34.7  kg/kkg  (69.4  Ib/t)  of
product.

     Nonintegrated  -  Lightweight  Papers  - Available raw waste load
data for this subcategory are presented in Table V-24.  This is a  new
subcategory  for  which BPT is being promulgated.  BPT is based on the
subcategory average raw waste loads.  Two product  sectors  have  been
considered - lightweight papers and lightweight electrical papers.

In  the  development  of  NSPS  Option  2  raw  waste loads, data were
reviewed with respect to waste significant grade changes.   Wastewater
discharge  and  BOD5_  raw  waste  loads increase with the frequency of
grade changes.  Option 2 raw waste flows for each product  sector  are
based on the highest average for the various grade change delineations
for mills where raw waste flows that are lower than those which formed
the  basis  of  BPT  are  attained.  Option 2 BOD5_ raw waste loads are
based on the highest average for the various grade change delineations
for mills where raw waste load BOD5_ is lower that that which forms the
basis of proposed BPT.  The Option 2 BOD5_  raw  waste  loads  for  the
lightweight  electrical papers product sector is identical to that for
the  lightweight  papers  product   sector.    Application   of   this
methodology  yields Option 2 flow and BOD5_ raw waste loads (a) for the
lightweight papers product sector of 159.4 kl/kkg  (38.2  kgal/t)  and
13.3  kg/kkg  (26.6  Ib/t),  respectively, and (b) for the lightweight
electrical papers product sector of 278.8  kl/kkg  (66.8  kgal/t)  and
13.3  kg/kkg (26.6 Ib/t), respectively.  For both product sectors, the
TSS raw waste load for Option 2 has been assumed to  be  the  same  as
that  which  forms  the  basis  of BPT, or 63.4 kg/kkg (126.8 Ib/t) of
product.

     Nonintegrated-Filter and Nonwoven Papers -  Available  raw  waste
load  data  for mills in this subcategory are presented  in Table V-25.
This  is  a  new  subcategory  for  which  BPT  is   currently   being
promulgated.   In  the  development  of NSPS Option 2 raw waste loads,
data were reviewed with respect to waste  significant  grade  changes.
Option  2  raw  waste  loads are based on the highest averages for the
various grade change delineations for mills where raw waste loads  are
lower   than  those  which  form the basis of BPT.  Application of this
methodology yields Option 2 flow and BOD5_ raw  waste  loads  of   198.2
kl/kkg  (47.5  kgal/t)  and 9.0 kg/kkg (17.9 Ib/t), respectively.  The
                                  462

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proposed TSS raw waste load for Option 2 has been assumed  to  be  the
same as that which forms the basis of BPT, or 27.4 kg/kkg (54.7 Ib/t).

     Noninteqrated-Paperboard - Available raw waste load data for this
subcategory  are  presented  in Table V-26.  This is a new subcategory
for which BPT is currently being promulgated.  The subcategory average
raw waste loads, exclusive of electrical and matrix board  production,
form the basis for BPT.

As for the other nonintegrated subcategories, raw waste load data were
reviewed with respect to frequency of waste significant grade changes.
Option  2  raw  waste  loads are based on the highest averages for the
various grade change delineations for mills with raw waste loads  that
are   lower   than  those  that  form  the  basis  for  proposed  BPT.
Application of this methodology yields Option  2  flow  and  BOD5_  raw
waste  loads  of 46.7 kl/kkg (11.2 kgal/t) and 8.2 kg/kkg (16.4 Ib/t),
respectively.  The TSS raw waste load for Option 2 has been assumed to
be the same as that which forms the basis of BPT, or 36.9 kg/kkg (73.7
Ib/t) of product.

     Summary of Option £ Raw Waste Loads - Table  VIII-38  presents  a
summary of Option 2 raw waste loads.

Development  of  Effluent Characteristics.  As discussed.previously in
this section, NSPS Options 1 and 2 are identical for the  tissue  from
wastepaper,  wastepaper-molded  products,  paperboard from wastepaper,
and builders'  paper  and  roofing  felt  subcategories  and  for  the
newsprint  product  sector  of  the deink subcategory.  For the tissue
from   wastepaper,   wastepaper-molded   products,   paperboard   from
wastepaper,  and  builders' paper and roofing felt subcategories, NSPS
Options 1 and 2 are based on the application  of  in-plant  production
process  controls  and biological treatment.  The biological treatment
systems are identical in size to those which form  the  basis  of  BPT
effluent  limitations  for  these  subcategories.   For  the newsprint
product sector of the deink subcategory,  the  end-of-pipe  biological
treatment system, is identical in design to that which forms the basis
of  BPT  effluent  limitations for the deink subcategory.   Because the
end-of-pipe treatment systems that form the basis of  NSPS  Options  1
and  2  for  these  four  subcategories and the subcategory sector are
identical to the  biological  systems  that  form  the  basis  of  BPT
effluent   limitations  for  these  subcategories,  the  relationships
discussed previously in this section apply.

The NSPS  Option  1  and  2  long-term  average  BODji  final  effluent
concentrations  for each of the four subcategories and the subcategory
product sector were determined from  the  equation  that  relates  raw
waste  BOD£  concentration  to  final  effluent  BODS^ concentration as
presented previously in this section and in the Phase  II  Development
Document (at page 402 (48)):

     Log BOD!> effluent (mg/1) = 0.601 Log BOD5. influent (mg/1) - 0.020
                                463

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                                       TABU VIII-38

                                 SUHMAR? OF HSPS OPTION 2
                                      RAW WASTE LOAM

                                     no*  	          BODS
Integrated Serpent
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
  o Liacrboard
  o Bag
S«*i-Che»ical
Unbleached Kraft
  and Se»i-Cheaic«l
Dissolving Sulfite Pulp
  o Nitration
  o Viscose
  o Cellophane
  o Acetate
Papergrade Sulfite*
Groundwood-Therno-Mechanical
Groundwood-CMH Papers
Oroundwood-Fine Papers
                                kJ7fckg   fcgal/t
211,6   (50.73
152.7   (36.6)
132.3   (31.7)
104.7   (23.1)
 39.2
 47.6
 30.5
246.2
246.2
246.2
274.2
101
8*
 57.6
 70.1
 64.3
Secondary Fibers Segnent
Deink
  o Fine Papers                  66.4
  "o Tissue Papers                81.4
  o Newsprint                    67.6
Tistue Fro* Waitepaper           68.0
Paperboard From Wastepaper
  o Corrugating Medium Furnish   13.4
  o Noacorrugating Mediua Fumishl3.4
Waatepapcr-Molded Products       23,8
Builders * Paper and Roofing Felt 11,3

Nonintegrmted Seitnent
Nonintegrated-Fine Papers
 o Wood Fiber Furnish            39.2
 o Cotton Fiber Furnish         130.2
Nonintegrated-Tissue Papers      79.7
Nonintegrated-Ligbtweight Papers
  o Lightweight                 159.4
  o Electrical                  278.8
Nonintegrated-Filter and
  Nonwoven Papers               198.2
Nonintegrated-Paperboard         46.7
     (9.4)
    (11.4)
     (7.3)
 48.0   (11.S)
(59,0)
(59.0)
(59.0)
(65.7)
(24.4)*
(13.8)
(16.8)
(15.4)
        (15.9)
        (19.5)
        (16.2)
        (16.3)

         (3,2)
         (3.2)
         (5,7)
         U.7)
         (9.4)
        (31.2)
        (19.1)

        (38.2)
        (66.8)

        (47,5)
        (11.2)
                     fcg/Mtg   Ib/t
 58.4  (116.7)
 29.3   (58.6)
 35.1   (70.2)
 27.1   (54.1)

 12.4   (24.8)
 16.9   (33.8)
 17.6   (35.2)

 16.3   (32.5)

 90.6  (181.2)
 92.6  (185.2)
109.6  (219.2)
156.6  (313.1)
 66.1* (132.2)*
        (35.2)
        (29.
17.6
14.6
12.5
                           .1)
                        (24.9)
                 37.3   (74.6)
                 61.3  (122.6)
                 15.9   (31.7)
                  9.7   (19.3)

                 23.0   (46.0)
                 11.3   (22,5)
                  5.5   (10.9)
                  6.5   (13.0)
                  7.5   (14,9)
                 14.0   (28.0)
                  9.0   (17.9)
                 13.3
                 13.3

                  9.0
                  8.2
                    (26.6)
                    (26.6)

                    (17.9)
                    (16.4)
                                               TSS
                                              Ib/t
                                113.0
                                 45,0
                                 66,5
                                 75.0

                                 21.9
                                 21.9
                                 12.3
92.5
92.5
92.5
92.
90.
39.
48.
52.5
                    63.4
                    63.4

                    27.4
                    36.9
                          (226.0)
                           (90.0)
                          (133.0)
                          (150.0)

                           (43.8)
                           (43.8)
                           (24.6)
                                     20.5   (41.0)
(185.0)
(185.0)
(185.0)
(185.0)
(180.0)
 (79.8)
 (97.0)
(105.0)
                                202.5  (405.0)
                                202.5  (405.0)
                                202.5  (405,0)
                                110.5  (221.0)

                                 11.0   (21.9)
                                 11.0   (21-9)
                                 14.8   (29.6)
                                 35.0   (70.0)
                                 30.8   (61.6)
                                 55.2  (110.4)
                                 34.7   (69.4)
      (126.8)
      (126.8)

       (54.7)
       (73.7)
'Includes Fine Bleached Kraft and Soda aubcategories.
"Include* Papergrade Sulfite (Blow Fit Wash) and Papergrade Sulfite  (Drum Wash)
 aubcategories.
*NSPS flow and BODS vary with the percent sulfite pulp in the final product:
 Flov (kl/Ucg) * 31.06 exp(0.017x), where x equals the percent aulfite pulp produced
 on-site in the final product.  Raw waste loads shown are for a «ill where on-site
 papergrade pulp production is 58 percent of the total product.
                                            464

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The   long-term   average   TSS  final  effluent  concentrations  were
determined from the relationship presented  in  Figure  VIII-1.   NSPS
Option  1   and  2  long-term average BOD!> and TSS final effluent loads
were calculated as the product of the long-term average final effluent
concentrations and the flow basis of NSPS Options 1  and 2.

For the remaining subcategories and subdivisions of subcategories,  the
end-of-pipe treatment systems that form the basis of NSPS Option 2 are
identical in design to those that form the basis of NSPS Option 1   for
these  subcategories.   However, these end-of-pipe systems have longer
detention times and increased clarifier capacity than the systems that
form the basis of BPT effluent limitations.  Therefore,  as  discussed
under  NSPS Option 1, they are more effective in removing conventional
pollutants.    In   those   subcategories   where   raw   waste   BOD5_
concentrations are equal to or lower than NSPS Option 1 raw waste BOD5_
concentrations,  these  systems  are  capable  of  attaining long-term
average BOD!> and TSS final effluent concentrations equal to  or  lower
than  NSPS  Option  1  long-term  average  BOD5. and TSS final effluent
concentrations.

As shown in Table VIII-39, NSPS Option 2 BOD5. raw waste concentrations
are equal  to  or  lower  than  the  NSPS  Option  1  BOD£  raw  waste
concentrations  for  the dissolving kraft, market bleached kraft,  fine
bleached kraft,  soda,  unbleached  kraft,  semi-chemical,  papergrade
sulfite,   dissolving   sulfite   pulp,  nonintegrated-tissue  papers,
nonintegrated-filter and  nonwoven  papers,  nonintegrated-lightweight
papers,  and  nonintegrated-paperboard subcategories, the cotton fiber
furnish subdivision of the nonintegrated-fine papers subcategory,   and
the  fine  and  tissue  product sectors of the deink subcategory.   For
these  subcategories  and  subcategory  subdivisions,  NSPS  Option  2
long-term average BOD5^ and TSS final effluent concentrations are equal
to  NSPS  Option  1  long-term  average  BODS^  and  TSS final effluent
concentrations.  NSPS Option 2 long-term average BOD5,  and  TSS  final
effluent loads were calculated as the product of the long-term average
final effluent concentrations and the flow basis of NSPS Option 2.

As shown in Table VIII-39, NSPS Option 2 raw waste BOD5. concentrations
are  greater  than  NSPS Option 1 raw waste BODjj concentrations in the
BCT bleached kraft, unbleached kraft  and  semi-chemical,  groundwood-
TMP,  groundwood-CMN  papers, and groundwood-fine papers subcategories
and the wood  fiber  furnish  subdivision  of  the  nonintegrated-fine
papers  subcategory.    As  discussed  previously,  BODiS  and TSS final
effluent concentrations  increase  as  raw  waste  BOD!>  concentration
increases.  Therefore, NSPS Option 2 final effluent concentrations for
these  five  subcategories  and  for  the  subcategory subdivision are
greater than NSPS Option 1 final effluent  concentrations.   Long-term
average  BOD£  final effluent concentrations were based on the percent
reductions in BOD5. that are characteristic  of  NSPS  Option   1.   EPA
calculated  the  percent  BOD5_ reduction for NSPS Option 1 for each of
the subcategories and subdivisions.  The Agency applied these  percent
reductions  to  the  NSPS  Option  2  raw waste BOD5. concentrations to
develop the  long-term  average  BOD5.  final  effluent  concentrations
characteristic  of  NSPS  Option  2.  [This is in contrast to proposed
                               465

-------
                                                  TABLE  VIII-39

                       COMPARISON OF  NSPS OPTION  1 RAW WASTE  LOADS AND  FINAL EFFLUENT  LEVELS
                           WITH  NSPS  OPTION  2 RAW WASTE LOADS AND FINAL EFFLUENT  LEVELS
                                          NSPS Option  1
                                                                                  NSPS  Option  2
Raw Waste
Flow
kl/kk«
Integrated Segnent
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
o Linerboard
o Bag
Seni-Chemical
Unbleached Kraft
and Semi-Chemical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite2
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Papers
o Tissue Papers
o Newsprint
Tissue Front Wastepaper
Paper-board Fran Wastepaper
o Corrugating Medina Furnish

230.
173.
148.
129.

52.
52.
<>2.

58.

275.
275.
275.
303.
*
88.
99.
91.


102.
102.
67.
68.

13.
o Noncorrugating Medium Furnish 13,
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
0 Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegra ted-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter and
Nonwoven Papers
Nonintegra ted-Paperboard
23,
11


63
176
96

203
320

250
53

0
0
0
0

5
5
9

it

0
0
0
4

0
,0
.0


0
,0
.6
,0

,4
.4
.8
.3


.0
.5
.0

.2
.9

.0
.8
kgal/t

(55.1)
(41.6)
(35.4)
(30.9)

(12.6)
(12.6)
(10.3)

(14.0)

(66.0)
(66.0)
(66.0)
(72.7)
*
(21.1)
(23.8)
(21.9)


(24.4)
(24.4)
(16.2)
(16.3)

(3.2)
(3.2)
(5.7)
(2.7)


(15.2)
(42.3)
(22.9)

(48.7)
(76.9)

(59.9)
(12.9)
BODS
•«/l

289
219
260
261

322
462
587

332

498
567
659
877
652
241
175
182


885
885
235
142

1724
843
229
577


170
130
120

107
68

49
193
Final
Effluent
BOOS
mg/1

21.0
19.1
17.5
15.0

24.5
28.6
27.5

23.1

30.8
33.0
35.8
41.0
32.5
18.1
15.0
15.0


24.2
32.6
25.4
18.8

84.2
54.8
25-0
43.6


22.3
17.0
28.7

28.5
28.5

28.5
28.5
TSS
•«/l

35.5
33.0
29.3
23.5

41.6
51.8
51.2

40.3

45.6
45.6
45.6
41.4
42.0
31.0
22.2
22.0


35.9
44.4
48.6
41.6

90.2
72.3
48.3
64.2


25.1
19.8
20.3

20.1
20.1

20.1
20.1
Raw Waste
Flow
kl/kkg

211.6
152.7
132.3
104.7

39.2
47.6
30.5

48.0

246.2
246.2
246.2
274.2
*
57.6
70.1
64.3


66.4
81.4
67.6
68.0

13.4
13.4
23.8
11.3


37.6
129.8
79.7

159.4
278.8

198.2
46.7
kgal/t

(50.7)
(36.6)
(31.7)
(25.1)

(9.4)
(11.4)
(7.3)

(11.5)

(59.0)
(59.0)
(59.0)
(65.7)
*
(13.8)
(16.8)
(15.4)


(15.9)
(19.5)
(16.2)
(16-3)

(3.2)
(3.2)
(5.7)
(2.7)


(9.4)
(31.2)
(19.1)

(38.2)
(66. S)

(47.5)
(11.2)
BODS
•8/1

276
192
266
2S8

316
356
578

339

368
376
445
313
650
306
208
194


563
754
235
142

1724
843
229
577


190
108
112

83
48

45
176
Final
Effluent
BODS
mg/1

21.0
19.1
17.9
15.0

24.5
28.6
27.5

23.6

30.8
33.0
35.8
41.0
32.5
22.9
17.8
16.0


24.2
32.6
25.4
18.8

84.2
54.8
25.0
43.6


24.9
17.0
28.7

28.5
28.5

28.5
28.5
TSS
mg/1

35.5
33.0
30.0
23.5

41.6
51.8
51.2

41.4

45.6
45.6
45.6
41.4
42.0
42.0
28.6
24.2


35.9
44.4
48.6
41.6

90.2
72.3
48.3
64.2


29.5
19.8
20.3

20.1
20.1

20.1
20.1
1 Includes Fine Bleached Kraft and Soda subcategories.
'Includes Papergrade Sulfite (Blow pit Wash) and Papergrade Sulfite (Drum Wash) subcategories.
*NSPS Option 1 and Option 2 vary with the percent sulfite pulp in the final product and are as fallows:

           NSPS Option 1 Flow = 52.87 exp(0.017x) kl/kkg
                              = 12.67 exp(0.017x) kgal/ton
           NSPS Option 2 Flow = 38.06 exp(0.017x) kl/kkg
                              =  9.12 exp(0.017x) kgal/ton

           where x equals the percent sulfite pulp produced on-site in the final product
                                                       466

-------
NSPS  in  which  the  Agency  assumed  BODjj  and  TSS  final  effluent
concentrations  would be identical to those characteristic of the best
performing mill option (equivalent to NSPS Option 1  in this  document)
even  when  the  raw  waste  BODjj  concentration  increased  after the
application of production process controls. ]  EPA also adjusted the TSS
final effluent concentrations accordingly.  The methodology  on  which
the  TSS  final  effluent  concentrations  were  adjusted  is based on
investigations conducted by McKinney. (204)

McKinney investigated  the  mathematics  of  complete-mixed  activated
sludge  systems  and developed the following relationship to determine
the effluent BODS^ discharged from activated sludge systems.

          Effluent BOD5 = F + kMa
          F = soluble     ^
          k = metabolism constant at 20°C over a 5-day period
          Ma = active or living mass of microorganisms

The constant, k, can be determined for each  subcategory  by  plotting
the  final  effluent  BOD5_ concentration versus the final effluent TSS
concentration for various levels of treatment.  The constant is  equal
to  the  slope of the straight line defined by the above relationship.
For each subcategory for which  the  NSPS  Option  2  BODI5  raw  waste
concentration  is  greater  than  the  NSPS  Option  1  BOD5_ raw waste
concentration, EPA determined k by plotting the long-term average BOD5.
final effluent concentration corresponding to BPT effluent limitations
and to NSPS Option 1 versus the long-term average TSS  final  effluent
concentration  corresponding  to  BPT  effluent  limitations  and NSPS
Option 1, respectively.

From the relationship developed by McKinney, if the increase in  final
effluent BOD£ concentration between NSPS Option 2 and NSPS Option 1 is
associated  with  an  increase  in TSS discharged (i.e., the increased
BOD£ is all insoluble BOD5.) , the increase in the  TSS  final  effluent
concentration can be determined from the following relationship:

          ATSS = (ABOD5)/k

The  NSPS Option 2 long-term average TSS final effluent concentrations
for the  BCT  bleached  kraft,  unbleached  kraft  and  semi-chemical,
groundwood-TMP,  groundwood-CMN  papers,  and  groundwood-f ine  papers
subcategories and for  the  wood  fiber  furnish  subdivision  of  the
nonintegrated-f ine  papers  subcategory  were  determined based on the
above relationship.

An illustration of how the Agency applied its methodology  to  compute
long-term  average  BOD5.  and  TSS  effluent  concentrations  in those
subcategories where NSPS Option 2 raw waste  BODS^  concentrations  are
greater  than NSPS Option 1 raw waste BOD!> concentrations is presented
in Table VIII-40 and Figure VIII-2.
                                467

-------
                                 TABLE VIII-40

     CALCULATION OF FINAL EFFLUENT LEVELS FOR SUBCATEGORIES FOR WHICH THE
          NSPS OPTION 2 RAW WASTE BOD5 CONCENTRATION IS GREATER THAN
                THE NSPS OPTION 1 RAW WASTE BOD5 CONCENTRATION
                       EXAMPLE:  GROUNDWOOD FINE PAPERS

	Sample Calculation 	
BOD5:

NSPS Option 1 BOD5 raw waste load (RWL) = 182 rag/1 (see Table VIII-39)

NSPS Option 1 BOD5 final effluent (F.E.) = 15.0 mg/1 (see Table VIII-39)

Percentage BOD5 reduction = 100 x (182 - 15.0)/182 = 91.76%

NSPS Option 2 BOD5 RWL = 194 mg/1 (see Table VIII-37)

NSPS Option 2 BOD5 FE level is defined as the NSPS Option 1 percentage  reduc-
tion applied to NSPS Option 2 BOD5 RWL = (194 mg/1) (1.00 - 0.9176) = 15.99 mg/1

NSPS Option 2 BOD5 long-terra average final effluent load

               = (NSPS Option 2 flow)x(NSPS option 2 BOD5 FE concentration)
               = (64.3 kl/kkg)(15.99 mg/1) = 1028 gm/kkg
               =1.0 kg/kkg

TSS:

NSPS Option 2 TSS FE level is equal to the NSPS Option 1 TSS FE level plus
ATSS where

                      ATSS = ABOD5/k

   ABOD5 is NSPS Option 2 BOD5 FE minus NSPS Option 1 BOD5 FE

                           = 15.99 rag/1 - 15.00 mg/1
                           = 0.99 mg/1

   k is the constant defined by the McKinney relationship and is the slope of the
   FE TSS versus FE BOD5 curve for the subcategory (see Fig. VIII-2).

                         k = 0.436

NSPS Option 1 TSS FE level =22.0 (see Table VIII-39)

NSPS Option 2 TSS FE level = NSPS Option 1 TSS FE level plus ABOD5/k
                           =22.0 mg/1 + 0.99 mg/1 / 0.436
                           = 24.27 mg/1

NSPS Option 2 TSS long-term average final effluent load
               = (NSPS Option 2 flow)x(NSPS Option 2 TSS FE concentration)
               = (64.3 kl/kkg)(24.27 mg/1) = 1561 gm/kkg
               =1.6 kg/kkg
                                      468

-------
                                                     FIGURE VW-2
                                     FINAL EFFLUENT TSS VS FINAL EFFLUENT BO05

                                  FOR THE GROUNDWOOD-FfNE PAF€RS SU8CATEGORY
                    30
                                                                                      FINAL EFFLUENT
                    ZO-
CTi
                4
                K
                u
                u
                z
                o
                u

                "I
                a
                o
                IB
  HSPS OPTION I

FIHAL CFFtUEMT
                    10-
                                           SLOPt k * 0 43«
                                       10
                                                         20



                                                       TSS CONCENTRATION
                                                                          30

-------
     Summary   of    NSPS    Long-Term    Average    Final    Effluent
Characteristics-Table VII1-41 presents a summary of the NSPS long-term
average BODS^ and TSS effluent loads.

Attainment of_ NSPS Option 2_

NSPS  Option 2 final effluent loads have been attained in 18 of the 22
subcategories where BPT is attained and in each  of  the  eight  major
industry  sectors  discussed  earlier in this section (bleached kraft,
unbleached  kraft/semi-chemical,   sulfite,  groundwood,   deink,  other
secondary  fiber, nonintegrated-fine papers, and other nonintegrated).
Table VIII-42 summarizes the number of mills attaining NSPS  Option  2
final  effluent  loads  and  the number of direct discharging mills in
each subcategory for which data were available.  At 23 percent of  the
mills  in  the  integrated  segment,   60  percent  of the mills in the
secondary  fibers  segment,  and  72  percent  of  the  mills  in  the
nonintegrated  segment  where  BPT  effluent limitations are attained,
NSPS Option 2 limits are also attained.

EPA reviewed the percent reductions required to attain NSPS  Option  2
effluent  loads  (see  Table VI11-43).  The percent reductions of BOD5.
that form the basis of NSPS Option 2 are equal to or less  than  those
that  form the basis of NSPS Option 1.  As discussed previously,  these
percent reductions have been  attained  in  all  of  the  eight  major
sectors of the industry.

Conventional Pollutant Variability Analysis

Pollutant  quantities  discharged  from  a wastewater treatment system
vary.  EPA accounts  for  this  variability  in  deriving  limitations
regulating  the  amount  of  pollutants  that may be discharged from a
treatment system.  The statistical procedures  employed  in  analyzing
variability  for  the conventional pollutants, BOD£ and TSS, regulated
under NSPS for the pulp, paper, and paperboard industry are  described
below.

Effluent  Limitations  Guidelines.  An effluent limitation is an upper
bound on the amount of pollutant discharge allowed per day or  average
of 30 days.  The limitations are determined by calculating the product
of  two  numbers  which  may  be  derived  from  effluent data: one is
referred to as a variability factor and the other is referred to as  a
long-term  average.   Two types of variability factors are derived for
the guidelines: a daily maximum factor and a  30-day  maximum  factor.
The  daily  maximum  factor  is the ratio of (a) a value that would be
exceeded rarely by the daily pollutant discharge to (b) the  long-term
average  daily  discharge.   The 30-day maximum factor is the ratio of
(a) a value that would be exceeded rarely by the average of  30 • daily
discharge  measurements  to  (b) the long-term average daily discharge.
The long-term average daily discharge quantity is an expression of the
long-run performance of the treatment or discharge process in units of
average daily kilograms (pounds) of  pollutant  discharged.   Given   a
daily maximum variability factor for a pollutant (denoted by VF) and  a
long-term  average  for the same pollutant  (denoted by LTA), the daily
                                 470

-------
                                       TABLE VIII-41

                                       MSPS OPTION 2
                                     LONG-TERM AVERAGE
                                 DISCHARGE CHARACTERISTICS
Flow
kl/kkg
Int_egfa_t_e_d__Seg_Hient
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
0 Linerboard
o Bag
Semi -Cheoi cal
Unbleached Kraft
and Semi-Chemical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite2
Groundwood-Theroo-Mechani ca 1
Grauadwood-CMK Papers
Grouadwood-Fine Papers
Secondary Fibers Segment
Deink
'i Fine Pacers
o Tissue Papers
o Newsprint
Tissue From Waatepaper
Paperboard From Wastepaper
o Corrugating Medium Furnish

211
152
132
104

39
47
30

48

246
246
246
274
*
57
70
64


66
81
67
68

13
o Noncorrugating Medium Furaishl3
Wastepaper-Malded Products
Builders' Paper and Hoofing Felt
Noniutegrated Segment
Xonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-lightweight Papers
o Lightweight
o Electrical
Nouintegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard
23
11


37
129
79

159
278

198
46

.6
.7
.3
,7

.2
,6
.5

.0

.2
.2
.2
.2

.6
.1
.3


.4
.4
.6
.0

.4
.4
,3
.3


,6
.8
.7

.4
.8

.2
.7
Ckgal/t)

(50
(36
(31
(25

(9
(11
(7

(11

(59
(59
(59
(65
*
(13
(16
(15


(15
(19
(16
(16

(3
(3
(5
(2


(9
(31
(19

(38
(66

(47
(11

.7)
.6)
.7}
.1)

.4)
.4)
.3)

.5)

.0)
.0)
.0)
.7)

-8)
.8)
.4)


.91
.5)
.2)
.3)

.2)
.2)
-7)
.7)


.4)
.1)
.1)

-2)
-8)

.5)
.2)
BODS
kg/kkg (Ib/t) kg/kkg

4
2
2
1

0
1
0

1

7
3
3
11
*
1
1
1


1
2
1
1

1
0
a
0


0
2
2

4
7

5
1

.4
.9
.4
.6

.n
.4
.8

.1

.6
.1
.8
.2

.3
.3
.0


.6
.7
.7
.3

.1
.73
,60
.49


.98
.2
.3

.5
.9

.6
,3

(8.
(5.
(4,
(3.

(1.
(2.
(1.

(2.

(15.
(16.
(17.
(22.
*
(2.
(2.
(2.


(3.
(5.
(3.
(2.

(2.
(1.
(1.
(0.


(1.
(4.
(4.

(f.
(15.

(11.
(2,

87)
82)
73)
14)

92)
71)
67)

26)

16)
22)
61)
48}

64)
SO)
05)


211
31)
43)
56)

25)
46)
19)
98)


96)
42)
58)

07)
86)

28)
66)

7.
5.
4.
2.

1.
2.
1.

2.

11.
11'.
11.
11.
*
1.
2.
I.


2.
3.
3.
2.

1.
0.
1.
0.


1.
2.
1.

3.
5.

4.
0.

5
0
0
5

6
5
6

0

2
2
2
3

4
0
6


4
6
3
8

2
97
2
73


2
6
6

2
6

0
94
TSS
Clb/t)

(15.03)
(10.06)
(7.94)
(4.92)

(3.26)
(4.92)
(3.12)

(3.97)

(22.42)
(22.42)
(22.42)
(22.66)
it
(4.84)
(4.01)
(3.11)


(4.761
(7.22)
(6.57)
(5.66)

(2.41)
(1.93)
(2.30)
(1.45)


(2.31)
(5.15)
(3,24)

(6.40)
(11.19)

(7.95)
(1.88)
'Includes Fine Bleached Kraft and Soda subcatsgories,
zlnclades Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash) subcate-
 gories.
*SSPS vary with the percent sulfite pulp in the final  product.  These equations can
 be used to obtain annual average effluent characteristics for Papergrade
 Sulfite mills:

              Flow (kl/kkg)   = 38.06 exp(C.O:?x)
              BOD5 (kg/kkg)   s  1.24 exp(0.017x)
              TSS (kg/kkg)    »  1.60 exp(0,Q17x)

 where x equals the percent sulfite pulp produced on-site rn the final product.
                                            471

-------
                                       TABLE VIII-42

                      NUMBER OF MILLS ATTAINING BPT AND NSPS OPTION 2
                                   FINAL EFFLUENT LEVELS




Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
o Linerboard
o Bag
Semi-Chemical
Unbleached Kraft
and Semi -Chemical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite2
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Pip«?r«
o Tissue Papers
o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
a Corrugating Medium Furnish

Hills with
Available
Data

3
9
7
14

16
10
15

9

0
2
1
2
11
2
2
6


3
10
1
9

3
o Noncorrugating Medium Furnish 37
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
.Voointegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated- Filter
and Non woven Papers
Nonintegrated-Papberboard
4
5


12
2
14

7
2

4
5
Mills
Attaining
BPT F.E.
levels(a)

2
/
3
5

9
3
4

3

0
0
0
0
5
1
1
5


3
6
1
7

2
21
1
4


5
1
9

6
2

4
2
Mills
Attaining
NSPS Option 2
F.E. levels(a)

1
1
0
1

1
1
1

1

0
0
0
0
2
0
0
2


0
2
1
2

1
18
0
3


1
0
6

6
2

4
2
'includes Fine Bleached Kraft and Soda subcategories.
Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash)
 subcategories.

(a)  F.E.  = Final Effluent
                                           472

-------
                                       TABLE VIII-43

                                    PERCENT REDUCTIONS
                           REQUIRED TO ATTAIN NSPS OPTION 2 BODS
                              FINAL EFFLUENT CHARACTERISTICS
                          FROM NSPS OPTION 2 BODS RAW WASTE LOADS
                                  	Percent Reduction*
Integrated Segment
Dissolving Kraft                                     92
Market Bleached Kraft                                90
BCT Bleached Kraft                                   93
Alkaline-Fine1                                       94
Unbleached Kraft
  o Linerboard                                       92
  o Bag                                              92
Semi-Chemical                                        95
Unbleached Kraft
  and Semi-Chemical                                  93
Dissolving Sulfite Pulp
  o Nitration                                        92
  o Viscose                                          91
  o Cellophane                                       92
  o Acetate                                          93
Papergrade Sulfite2                                  95
Groundwood-Therrao-Mechanical                         93
Groundwood-CMN Papers                                91
Groundwood-Fine Papers                               92

Secondary Fibers Segment

Deink
  o Fine Papers                                      96
  o Tissue Papers                                    96
  o Newsprint                                        89
Tissue Front Wastepaper                               87
Paperboard From Wastepaper
  o Corrugating Medium Furnish                       95
  o Noncorrugating Medium Furnish                    94
Wastepaper-Molded Products                           89
Builders' Paper and Roofing Felt                     92

Nonintegrated Segment

Nonintegrated-Fine Papers
  o Wood Fiber Furnish                               87
  o Cotton Fiber Furnish                             84
Nonintegrated-Tiasue Papers                          74
Nonintegrated-Lightweight Papers
  o Lightweight                                      66
  o Electrical                                       40
Nonintegrated-Filter
 and Nonwoven Papers                                 37
Nonintegrated-Paperboard                             84
'Includes Fine Bleached Kraft and Soda subcategories.
2Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash) subcate-
 gories.

*Percent reduction
 = (raw waste load (Ib/t) - final effluent (lb/t)] x 100/raw waste load (Ib/t)
 except for Papergrade Sulfite subcategories for which percent reduction is defined in
 terms of concentrations (mg/1).
                                             473

-------
limitation  is the product of the variability factor and the long-term
average (VF x LTA).  Similarly,  given  a  30-day  maximum  variability
factor  (VF30),  the limit for the average of 30 daily observations is
VF-,0 x LTA.

Daily Maximum Variability Factors.  Historically,  in  this  industry,
the  daily maximum variability factor has been defined as the ratio of
an estimated 99th percentile of the distribution  of  daily  pollutant
discharge  values  to  the estimated long-term average daily pollutant
discharge.   The  99th  percentile  of   daily   pollutant   discharge
represents  a  pollutant discharge value below which 99 percent of all
pollutant discharge values fall.  Estimates of the 99th percentile  of
daily   pollutant   discharge  distribution  may  be  calculated  from
available effluent data.  Percentiles may be estimated using either  a
parametric   or  nonparametric  approach.   To  utilize  a  parametric
approach, a distribution with a known functional form is  fit  to  the
data.   Past  guideline development has utilized such distributions as
the normal, lognormal, and  three-parameter  lognormal  distributions.
If  a  distribution  is  found to describe the data adequately, a 99th
percentile can be calculated through the use of the  known  functional
form of the assumed distribution.

Nonparametric  methods  may  also  be  used  to  estimate distribution
percentiles.  Such methods do not require that the particular form  of
the   underlying  distribution  be  known,  and  make  no  restrictive
assumptions about the distributional form of the data.  (Nonparametric
methods are discussed in many texts.  See, for example, J. D. Gibbons,
Nonparametric Statistical Inference, McGraw-Hill (1 971).(205)) EPA has
applied nonparametric methods to pulp, paper, and paperboard  industry
effluent  data  to  obtain  50  percent confidence level  (or tolerance
level) estimates of the 99th percentile of the distribution  of  daily
pollutant  discharge.  That is, an estimate of the 99th percentile was
determined such that the probability that the estimate  (which  is  of
the  form: the rth largest of n measurements) is greater  than or equal
to the 99th percentile of the daily pollutant  discharge  (denoted  as
K.,,)  is  no  less  than  0.5.   That is, n daily pollutant discharge
values were obtained and ordered from smallest to  largest   in  value.
The  rth  smallest  pollutant discharge value (where r is less than or
equal to n), denoted by X(r_), is chosen such that the probability that
X(r) is greater than or equal to K.9, is at least 0.5 (i.e., P[X(r)  >
K.,,]  >  0.5).  Utilizing this approach, the value of r  is determined
such that
        "I*/ x— K.(
                               474

-------
where p = .99

and /n\=     n!
         i! (n-i)S

The estimate is interpreted as the value below which 99 percent of the
values of a future sample of size n will fall with a probability of at
least 0.5.
                       Pollutant Discharge Values To  Determine  Daily
                                                  for
     Analysis of Pail
Maximum  Variability Factors - Daily measurements
                                                      the conventional
pollutants, BOD5_ and TSS^  were  submitted  by  mill  representatives.
Values  for  facilities  employing primary and/or biological treatment
were obtained through the supplemental data request  program.   Values
for   facilities  employing  chemically  assisted  clarification  were
obtained  through  the  supplemental  data  request  program  and  the
verification  sampling  program.   These values were used to calculate
daily maximum  variability  factors  and  30-day  maximum  variability
factors.

Initially,  a  parametric  approach  toward  estimation  of  the  99th
percentile  of  daily  pollutant  discharge  values  was   considered.
Mill-specific  daily  pollutant discharge values for BOD5_ and TSS were
fit to hypothesized normal and  lognormal  distributions.   To  assess
whether   mill-specific  sets  of  daily  pollutant  values  could  be
adequately  described  by  the  normal  or  lognormal   distributions,
Kolmogorov-Smirnov goodness-of-fit tests and frequency histograms were
performed.   The  goodness-of-fit  tests  indicated  that, in general,
neither the normal nor lognormal distribution adequately represent the
mill-specific daily  pollutant  discharge  values  of  BOD5_  and  TSS.
Because  of  these results, EPA decided to use nonparametrlc estimates
of the 99th percentile of the daily data.  The  50  percent  tolerance
level  criterion  described  above  was  used  to  estimate  the  99th
percentile.  Mill-specific  daily  maximum  variability  factors  were
                            the ratio of the 99th percentile estimates
                            discharge values.  The  effects  of  daily
                                              model that was developed
                                              (see
determined  by  calculating
to the average of the daily
dependence  were examined using a time series
for the timber products point source category
                                                    Final  Development
Timber  Products
Document  for  Effluent  Limitations  Guidelines and Standards for the
                  Point  Source  Category,  USEPA,  Washington,  D.C.,
               (206)).   The results show that maximum day variability
                                   to daily dependence  and  that  the
                                    representative variability factors
January  1981  (206)).   The
factors are relatively insensitive
nonparametric  methods  used  yield
for data examined in this study.
This is further supported by  additional  analyses  conducted  by  the
Agency.   On  a  mill-specific basis, each daily value was compared to
the  corresponding  mill-specific  99th  percentile  estimate.   Table
VIII-44  displays  the aggregate results of comparing each daily value
to its corresponding 99th percentile estimate  of  the  daily  maximum
discharges  of BOD5_ and TSS.  The percentage of daily values exceeding
the 99th percentile estimate is substantially the same as the expected
one percent.  Table VIII-45 displays mill-specific values for  maximum
                               475

-------
                                 TABLE VIII-44

                      DISTRIBUTION OF DAILY VALUES ABOUT
                      THE ESTIMATE OF THE 99th PERCENTILE
             Percentage of Points          Percentage of Points
	S99th Percentile	>99th Percentile	Totals

TSS                 99.2%                         0.8%                 100.0%
                  (29,755)*                      (247)*                (30,002)*

BOD5                99.2%                         0.8%                 100.0%
                  (28,860)*                      (244)*                (29,104)*
* Actual number of daily data points given in parentheses.
                                         476

-------
                            TABLE VI1I-45
                 VARIABILITY FACTORS FOR DETERMINING
                     MAXIMUM DAT LIMITATIONS(a)
            BIOLOGICAL TREATMENT:
           PRIMARY CLARIFICATION:
CHEMICALLY ASSISTED CLARIFJCATON:
SUBSETS (1), (2), (3), AND (4)
SUBSETS (5) AND (6)
SUBSET (7)
Mill
Number
MILLS WITH
032002
032003
030005
030032
030046
030027
030020
010002
010019
010005
020017
020009
060004
015001
015001
040012
040009
040019
040010
040010
070001
054015
052008
030044
140007
140019
140015
140015
140021
140021
140025
140030
100005
090004
110077
110031
080041
080046
BODS
Number
of Data
Points
BIOLOGICAL TREATMENT
1,000*
875*
859
916*
721*
986*
1,002*
568*
429*
1,004
914
332
957*
642
97*
522*
759*
127
369
541*
926
993*
952*
693*
778*
982*
153
710*
119
409*
295*
999*
141*
999
373
421*
968
396*
TSS
Msxinun
Day
Average

2.00
2.15
3.11
2.17
2.83
3.42
2.64
1.80
2.99
3.32
2.75
2.52
1.94
3.39
2.72
2.56
2.05
3.70
2.27
1.57
3.88
3.74
6.73
1.86
4.79
3.61
2.54
3.28
5.34
2.94
2.29
3.25
4.42
2.56
3.29
4.49
2.56
1.94
Number
of Data
Points

1,003*
837*
881
55*
730*
992*
998*
630*
424*
1,004
914
341
956*
652
104*
610*
759*
303
369
541*
971
954*
961*
701*
779*
983*
153
710*
119
409*
740*
999*
357
999
279
418*
974
396*
Max! nun
Day
Average

2.41
2.12
2.04
(b)
4.16
4.76
2.26
1.52
2.25
2.46
2.17
2.46
2.87
2.76
2.47
1.90
2.17
2.91
1.97
2.32
5.98
4.78
5.93
2.34
7.40
3.76
2.36
3.65
2.61
2.99
1.73
4.29
3.68
2.94
2.70
4.42
4.27
1.98
Mills Used to
Calculate Averagi
by Subsets

(D(2)(3)(4)
(1)
(1)
(D(2)(3)
(D(2)(3)
(D(2)(3)(4)
(1)(2)(3)(4)
(D(2)(3)
(D(2)(3)
(1)
(D(2)(3)
(1)
O)(2)(3)
(D(2)(3)
d)(2)(3)
(1)
(D(2)(3)
(D(2)(3)(4)
U)(2)(3)
(O(2)(3)
(1)(2)(3)
(1)
(1 )(2)(3)(4)
(D(2)(3)
U)(2)(3)
(1)(2)(3)(4)
U)(2)(3)(4)
(O(2)(3)
(D(2)(3)(4)
(D(2)(3)(4)
U)(2)(3)
(1)(2)(3)(4)
(1 )(2)(3)(4)
(1)(2)(3)
(D(2)(3)(4)
(D(2)(3)(4)
(O(2)(3)
(1)(2)(3)(4)

-------
                                                                           TABLE VIII-45 (cent.)
                     MILLS WITH PRIMARY CLARIFICATIOK
090008
090019
090019
090022
090022
080022
105020
105020
MILLS WITH
060001
080027
964*
797
181*
52
85*
898*
354
440*
CHEMICALLY ASSISTED CLARIFICATION
381*
456*
1.92
1.80
1.76
(b)
(b)
3.47
4.36
3.75

2.83
2.56
976*
797
181*
368
595*
898*
354
440*

379*
454*
5.49
2.59
2.09
3.36
2.68
2.85
4.01
2.93

2.39
2.92
(5)(6)
(5)
(5)
(5)
(5)
(5)(6)
(5)(6)
(5)(6)

(7)
(7)
                     *Denotes refrigerated data

                     (a)Subset Descriptions:

Oo                      (1)A11 mills with biological treatment.
                        (2)Mills with biological treatment; final effluent levels at or better than BPT.
                        (3)Mills with biological treatment; final effluent levels at or better than BPT.  Biological treatment in the
                           technology basis of BPT effluent limits.
                        (4)Mills with biological treatment; final effluent levels at or better than NSPS Option 1 levels.  Biological
                           treatment is the technology basis of  BPT effluent limits.
                        (5)Mills with primary treatment; final effluent levels at or better than BPT limits.  Primary clarification is
                           the technology basis of BPT effluent  limits.
                        (6)MilIa with primary treatment; final effluent levels at or better than NSPS Option 1 levels.   Primary
                           clarification is the technology basis of BPT effluent limits.
                        (7)A11 nills with chemically assisted clarification.

                     (b)Insufficient data for analysis.

-------
day variability factors for BOD5_ and TSS, obtained by calculating  the
quotient  of  the  99th  percentile  estimates  and  long-term average
pollutant values.

30-Day Maximum Variability Factors.  The approach for deriving  30-day
maximum variability factors is suggested by a statistical result known
as   the   Central  Limit  Theorem.   This  theorem  states  that  the
distribution of a mean of a sample of size n drawn from any one  of  a
large  class  of  different distributional forms will be approximately
normally distributed.  For practical purposes, the normal distribution
provides a good approximation to the distribution of the  sample  mean
for  samples  as  small  as  25  or  30  (see e.g., Miller and Freund,
Probability and Statistics for Engineers, Prentice - Hall,  1965,  pp.
132-34).(207)

     Analysis  of  30-Day  Averages  of  Pollutant Discharge Values To
Determine 30-Day Maximum Variability Factors - The mill-specific  data
for  each  pollutant  were  divided  into  periods  with  30  days  of
measurements.   These  periods  were  constructed  without  regard  to
whether  the  days  fell  into  a  calendar  month  period  or whether
measurements on adjacent days were available.   For  instance,  if  30
daily measurements were available from January 1 to February 15, these
30  measurements  were  used  to  construct  one  30-day average to be
included in the analysis.  If the next 30 measurements were  available
during February 16 to March 25, these would constitute the next 30-day
average  and  so on.  The mill-specific 30-day averages so constructed
were found to fit the normal distribution adequately on the  basis  of
goodness-of-fit  tests.   These tests were performed using the mean of
the 30-day means and the standard deviation of  the  30-day  means  to
estimate   the   mean  and  standard  deviation  of  the  hypothesized
distribution.  The results of the goodness-of-fit tests are summarized
in Table VIII-46 and are consistent with the  Central  Limit  Theorem.
Using  X30  and  S30  to denote the mean and standard deviation of the
30-day  averages,  respectively,  for  a  particular  mill,  the  99th
percentiles were estimated as X30 + 2.33 S30.

EPA also examined the effects of daily dependence, monthly dependence,
and  seasonality using a time series model.  A simpler version of this
time series  model  was  used  to  determine  maximum  30-day  average
variability   in  establishing  effluent  limitations  guidelines  and
standards for the Timber Products  Processing  Point  Source  Category
(see  Final  Development  Document for Effluent Limitations Guidelines
and Standards for the Timber Products  Point  Source  Category,"U.S.
Environmental   Protection  Agency,  Washington,  D.C.,  January  1981
(206)).  The results show that,  although  seasonality  has  the  most
important  effect  on  maximum 30-day average variability factors, the
method used in this study for estimating 99th percentiles accounts for
seasonality  and  provides  representative  maximum   30-day   average
variability factors.

This  is  further  supported  by  additional analyses conducted by the
Agency.  On a mill-specific basis, each 30-day average was compared to
the  corresponding  mill-specific  99th  percentile  estimate.   Table
                                 479

-------
                                                                                      TABLE  VI11-46




                                                          RESULTS OF COODNKSS-OF-FIT  TESTS  FOR  SUCCESSIVE .10-DAY AVERAGES(a)
cx>
o
801)5
Subcategory Name
Diftiiolving Kraft

Market Bleached Kraft
BCT Rlearhed Kraft
Alkaline-Fine(d)


Unbleached Kraft
o Mnerboard

o Bag
Semi -fhemi oal


Unbleached Kraft and
Srmi -Cbemi cal

Paper-grade Sulfite(f)




Groundwood-Fine Papers
G rou ndwood -The rmo-
Mechanical
Oroundwocid-CMN P.ipers
Integrated Mi ncel laneous

Deink
o Fine Papers

Hill
Number
032002*
032003*
030005
030032*
030046*
030027*
030020*

010002*
010019*
010005
020017
020009
060004*

015001
015001*
040012*
040009*
040019
040010
040010*
052008*

070001
054015*
030044*
060001*

140007*
1400)9*
Number
of
Means
33
29
28
30
24
32
33

18
14
33
30
11
31

21
3
17
25
4
12
IS
30

30
33
23
12

25
32
SI;
0.
0.
0.
0.
0.
0.
0.

0
0
0
0
0.
0

0
-
0
0
-
0
0
0

0.
0
0
0.

0
0
Test
itistic
.0530
.0899
.2274
. 1045
.2295
.0949
.1647

.1593
.1801
.1679
.1272
.1782
.0904

.2332

.2398
.1207

.1672
.0684
.2569

.1407
.0777
.0808
.2234

.2416
.1483
Critical
Value at
a = .01
0.
0,
0,
0.
0,
0.
0.

0
0
0
0.
0.
o

0
-
0
0
-
0
0
0.

0.
0.
0
0.

0.
0.
.1795
.1896
.1922
.1870
.2062
. 182.3
.1795

.2390
.2610
.1795
.1870
.2840
.1852

.2248

.2450
.2000

.2750
.2390
.1852

.1870
1795
2124
2750

.2000
. 1823
Decislon(b)
NS
NS
Sig a = 0.01
NS
Sig a = 0.01
NS
NS

NS
NS
NS
NS
NS
NS

Sig o = 0.01
-(c)
NS
NS
-(c-)
NS
NS
Sig o = 0.01

NS
NS
NS
NS

Sig a = 0.01
NS
Number
of
Means
33
27
29
1
24
33
13

21
14
33
30
11
31

21
3
20
25
10
12
IB
32

.12
31
23
1?

?S
:)2
Test
Statistic
0
o
0
-
0.
0
0.

0
o
0
o
0
0

0
-
0
0
0
o
0
0

0.
0.
0.
0.

0.
0.
.1085
.0719
.1289

.2715
1840
.0718

.1376
. 1989
.1815
.1234
.2581
.0984

.1180

. 1270
.1820
.2316
.2321
.2044
I4RO

.1622
1502
1819
2248

2020
1183
TSS

Critical
Valnr at
a - .01
0
0.
0
-
0.
0.
0

o
0
0
0
0.
0

0
-
0.
0
0.
0.
0.
0.

0.
0.
0.
0.

0.
0.
.1795
.1948
1896

.2062
.1795
1795

.2248
.2610
. 1795
. 1870
. 2840
. 1852

2248

2310
2000
2940
2750
2390
1871

182.1
i«r>;'
2124
2750

7.000
1821
Dc-cisi
NS
NS
NS
-(r)
Six a
Sic. a
NS

NS
NS
SIR u
NS
NS
NS

NS
-(<•)
NS
NS
NS
NS
NS
NS

NS
NS
NS
NS

S i p. n
NS
ion(h)




^001
= 0.01




= 0.01


















= 0.01


-------
                                                                                        TABLE VII1-46 (cent.)
OO





Tissue From Vastepaper

Paperboaid From Vafitepaper

Nonintrgraled-Fine Papers


Nonintegrat ed-Tissue Papers




140015
140015*
140021
140021*
1 40025*
140030*
100005**
090004
110077
110031*
080041
080046*
080027*
090008*
090019
090019*
090022
090022*
5
23
3
13
9
.13
4
33
12
14
32
13
14
32
26
6
1
2
0.1679
0.2082
-
0.1681
0.1469
0.1826
_
0.0896
0.2026
0.2303
0.1606
0.1270
0.2383
0.1333
0.1243
0.1816
-
-
0.
0.
-
I)
0.
0
-
0.
0
0.
0.
0.
0.
0
0.
0.
-
-
.4050
.2124

2680
.3110
1 795

.1795
2750
.2610
.1823
.2680
.2610
. 1823
. 1974
.3640


NS
NS
-(c)
NS
NS
Sig a = 0.01
-(c)
NS
NS
NS
NS
NS
NS(e)
NS
NS
NS
-(c)
-(c)
5
23
3
11
24
33
11
33
9
13
.12
13
15
32
26
6
12
19
(1.
0,
-
0.
0.
0.
0
0.
0.
0.
0.
0.
0.
0
0,
0
0
0
1427
1410

1518
0981
1526
1966
. 1 499
1 320
2212
1173
2576
.2009
.2080
,0781
.2375
.1178
.0974
0.4(150
0.2124
-
0.26RO
0.2062
0. 1795
0.2R40
0.1795
0.31 10
0.26RO
0. 1S2.1
0.26RO
0.2570
0. 1823
0. 1974
0 . 3640
0.2750
0.2:150
NS
NS
-<< )
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
Sig a - 0.01
NS
NS
NS
NS
Nonintegrated-Lightweight Papers
o Lightweight


080022*
105020
105020*
29
11
14
0.1050
0.1801
0.1277
0
0
0
.1896
.2840
.2610
NS
NS
NS
29
11
l/i
0
0
0
.1371
.2010
1749
0. 1896
0.2840
0.2610
NS
NS
NS
                      '''Refrigerated BOD5 and TSS data.
                     ^'Refrigerated BOD5 data only.

                     (a )Li 11 ief. ors, H.,  "On the Kolmogorov-Smi rnov Tests for Normality with Mean and Variance Unknown,"  J. Am. Statistical  A.ssor.,
                        Vol. 62, 1967. (208)
                     (b)Reject H  at the level a if teat statistic exceeds critical value for the particular sample size N.  NS denotes  hypothesis
                        test results not significant (i.e., do not reject H :  data comes fron a normal distribution).
                     (c)Insufficient data for analysis.
                     (d)Includes Fine Bleached Kraft and Soda subcategories.
                     (e)Altnough the set of successive 30-day averages was not found to be normally distributed,  the  set of  successive 31-day averages
                        was found to be normally distributed using the Lilliefors Test.
                     (f)Intludes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash) subratrgories.

-------
VIII-47  displays  the  aggregate  results  of  comparing  each 30-day
average  to  its  corresponding  99th  percentile  estimate   of   the
distribution  of 30-day averages of pollutant values for BODS^ and TSS.
The percentage  of  30-day  averages  exceeding  the  99th  percentile
estimate is substantially the same as the expected one percent.  Table
VIII-48  displays  mill-specific  maximum  30-day  average variability
factors for BOD£ and TSS, obtained by calculating the quotient of  the
99th percentile estimates and long-term average pollutant values.

Establishment  of  Variability  Factors  To  Be Applied for Rulemakinq
(BiologicalTreatment).    Tables  VIII-45  and  VIII-48  present  the
individual mills'30-day average and daily maximum variability factors
for  BOD£  and  TSS for those mills with biological treatment systems.
For many subcategories, biological treatment is the  technology  basis
for  achieving  the effluent reduction required under NSPS guidelines.
Variability factors compiled for each mill were averaged across  mills
and   one  daily  and  one  30-day  average  variability  factor  were
determined for BOD!> and TSS.  These two variability factors were  used
in  the  establishment  of  30-day  average and daily maximum effluent
limitations controlling the discharge of conventional pollutants  from
those  subcategories  where  biological treatment forms the technology
basis.

Minimum, maximum, and average variability factors were determined  for
each  of  four  subsets of mills.  These subsets were developed from a
group of mills with biological treatment systems and are as follows:

Subset Number            Subset Description

(1)                      Mills with biological treatment systems.

(2)                      Mills with biological treatment systems and
                         effluent levels at or better than BPT limita-
                         tions.  Biological treatment is not necessarily
                         the treatment technology on which BPT is based
                         for some of these mills (i.e., primary
                         treatment forms the basis of BPT effluent
                         limitations applicable to discharges
                         from some of these mills).

(3)                      Mills with biological treatment systems and
                         effluent levels at or better than BPT.  Biological
                         treatment is the technology on which BPT
                         effluent limitations are based for these
                         mills.

(4)                      Mills with biological treatment systems and
                         effluent levels at or better than NSPS Option  1
                         long-term average effluent loads.  Biological
                         treatment is the technology on which BPT effluent
                         limitations are based for these mills.
                                  482

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                                 TABLE VIII-47

                     DISTRIBUTION OF 30-DAY AVERAGES ABOUT
                      THE ESTIMATE OF THE 99th PERCENTILE
             Percentage of Points
             £99th Percentile
                        Percentage of Points
                        >99th Percentile
                     Totals
TSS
BODS
 98.2%
(961)*

 98.1%
(930)*
1.8%
(18)*

1.9%
(18)*
100.0%
 (979)

100.0%
 (948)
* Actual number of successive 30-day averages given in parentheses.
                                     483

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                                                                              TABLE VII1-48
                                                                   VARIABILITY FACTORS FOR DETERMINING
                                                                      MAXIMUM 30-DAY LIMITATrONS(a)
CO
                                                             BIOLOGICAL  TREATMENT:
                                                             PRIMARY CLARIFICATION:
                                                  CHEMICALLY ASSISTED CLARIF1CATON:
SUBSETS (1), (2), (3) AND (4)
SUBSETS (5) AND (6)
SUBSET (7)
Mill
Number
MILLS WITH
032002
032003
030005
030032
030046
030027
030020
010002
010019
01 0005
020017
020009
060004
015001
015001
040012
040009
040019
040010
040010
070001
054015
052008
030044
140007
140019
140015
140015
140021
140021
140025
140030
100005
090004
110077
110031
080041
080046

Number
of Data
Points
BIOLOGICAL
1,000*
875*
859
916*
721*
986*
1 ,002*
568*
429*
1,004
914
332
957*
642
97*
522*
759*
127
369
541*
926
993*
952*
693*
778*
982*
153
710*
119
409*
295*
999*
141*
999
373
421*
968
396*
BODS
Maximum
30-Day
Average
TREATMENT
1.49
1.56
2.02
1.86
2.00
1.47
1.73
1.56
1.68
2.00
2.02
1.65
1.46
2.55
(b)
1.76
1.51
(b)
1.91
1.30
1.89
2.12
2.82
1.34
2.42
2.09
1.77
1.80
(b)
1.71
1.58
2.08
(b)
2.11
2.08
2.37
1.85
1.39
TSS
Number
of Data
Points

1,003*
837*
881
55*
730*
992*
998*
630*
424*
1,004
914
341
956*
652
104*
610*
759*
303
369
541*
971
954*
961*
701*
779*
983*
153
710*
119
409*
740*
999*
356
999
279
418*
974
396*
Maximum
30-Day
Average

1.50
1.39
1.39
(b)
2.52
2.14
1.55
1.38
1.35
2.00
1.81
1.52
1.79
2.11
(b)
1.56
1.66
1.94
1.49
1.49
2.25
2.22
2.43
1.46
2.52
1.65
1.40
1.94
(b)
1.63
1.28
2.24
2.35
2.02
1.82
2.44
2.08
1.53
Mills Used to
Calculate Averages
by Subsets
U)(2)(3)(4)(5)(6)

(1)(2)(3)(4)
(1)
(1)
U)(2)(3)
(1)(2)(3)
(1)(2)(3)(4)
(1)(2)(3)(4)
(1)(2)(3)
(1X2H3)
(1)
(1X2X3)
(1)
UX2X3)
(1X2X3)
(D(2)(3)
(1)
(1)(2)(3)
(1X2X3X4)
U)(2)(3)
(1X2X3)
(1)(2)(3)
(1)
(1)(2)(3)(4)
(D(2)(3)
(1X2X3)
(1)(2)(3)(4)
(1)(2)(3)(4)
UX2X3)
(1)(2)(3)(4)
(1)(2)(3)(4)
(D(2)(3)
(1)(2)(3)(4)
(D(2)(3)(4)
UX2)(3)
(1X2X3X4)
(1)(2)(3)(4)
(D(2)(3)
(1)(2)(3)(4)

-------
                                                                          TAI'LE VIII-48 (cent.)
                    HILLS WITH PRIMARY CLARIFICATION
090008
090019
090019
090022
090022
080022
103020
10S020
MILLS WITH
060001
080027
964*
797
181*
52
85*
898*
354
440*
CHEMICALLY
381*
456*
1.32
1.45
1.53
(b)
(b)
1.64
1.62
1.48
ASSISTED CLARIFICATION
2.05
2. 10
976*
797
181*
368
595*
898*
354
440*

379*
454*
1.92
1.44
1.29
1.30
1.33
1.46
1.86
1.55

1.41
2.15
                                                                                                                              (5)
                                                                                                                              (5)
                                                                                                                              (5)
                                                                                                                              (5)
Q^                  UOUUU1           JO1"         f. . UJ                            JtV"           !.•*!                          (7)
in                  080027           456*         2.10                            454*           2.15                          (7)
                    ^Denotes refrigerated data

                    (a)Subset Descriptions:

                       (1)A11 mills with biological treatment.
                       (2)Mills with biological treatment; final effluent levels at or better than BPT.
                       (3)Mills with biological treatment; final effluent levels at or better than BPT.  Biological  treatment,  is  the
                          technology basis of BPT effluent limits.
                       (4)Mills with biological treatment; final effluent levels at or better than NSPS Option  1  levels.   Biological
                          treatment is the technology basis of BPT effluent limits.
                       (5)MilIs with primary treatment; final effluent level* at or better than BPT  limits.  Primary clarification  is
                         the technology basis of BPT effluent Units.
                       (6)Mills with primary treatment; final effluent level* at or better than NSPS Option  1 levels.   Primary
                         clarification is the technology basis of BPT effluent limits.
                       (7)A11 mills with chemically assisted clarification.

                    (b)Insufficient data for analysis.

-------
Maximum daily and maximum 30-day average variability factors for these
four subsets are shown in Table VIII-49.  Based on the results,  where
biological  treatment is the basis of NSPS technology options, EPA has
based the 30-day average and daily maximum  effluent  limitations  for
BOD5_  and  TSS  on  the  30-day  average and daily maximum variability
factors developed for subset (4), using refrigerated data, because (a)
subset (4) most resembles treatment system performance  that  will  be
required  of  new  sources  and  (b)  refrigeration of samples will be
required by permitting authorities.

Hence, for  BOD.5  and  TSS,   the  30-day  average  and  daily  maximum
variability  factors  to be applied for those technology options where
biological treatment is the technology basis are as follows:

                  30-Day Average Variability Factors
                (From Mills with Biological Treatment)

                             BOD5. = 1.91
                             TSS  = 1.90

                  Daily Maximum Variability Factors
                (From Mills with Biological Treatment)

                             BOD5. = 3.54
                             TSS  =3.64

Establishment of Variability Factors  To  Be  Applied  For  Rulemakinq
(Primary   Treatment).   Wastewater  data  from  mills  where  primary
clarification  is  employed  were  also  collected  as  part  of   the
supplemental  data  request program.  Daily maximum and maximum 30-day
variability  factors  for  subcategories  with  such  treatment   were
determined  using the methods described previously and applied to data
from mills with biological treatment systems.

Tables VIII-45 and VIII-48 present mill-specific daily maximum and 30-
day average variability factors, respectively.  Table VIII-49 presents
maximum, minimum, and average variability factors for BOD5_ and TSS for
those  mills  with  primary  clarification.   For  the   nonintegrated
subcategories,  with  the  exception  of the nonintegrated-fine papers
subcategory, primary clarification is the technology  basis  for  both
NSPS technology options considered.  Variability factors for each mill
were averaged and applicable daily maximum and 30-day average BODS^ and
TSS variability factors were determined.
                                  486

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                                                                                  TABLE VI11-49
                                                                     AVERAGE M\XIMUM 30-DAY AND MAXIMUM DAY
                                                      VARIABILITY FACTORS FOR SUBSETS (1), (2), (3), (4), (5), (6), and (7)
                        Subset
                                                                                           BODS
Maxima
30-Day
Average
Maximum
 Day
Average
                                                                                                                              'ITiS
                                                                                                                      Maximum
                                                                                                                      30-Day
              Maximum
               Day
              Averagi'
                        (1)   ALL MILLS WITH BIOLOGICAL TREATMENT

                             (A) With Refrigerated Sanple Collection
                                       Minimum
                                       Maximum
                                       Average
                             (B)  With Unrefrlgerated Sample Collection
.pa
CO
               Maximum
               Average

(2)  MILLS WITH BIOLOGICAL TREATMENT; FINAL EFFLUENT
     LEVELS AT OR BETTER THAN BPT

     (A)  With Refrigerated Sample Collection
               Minimum
               Maximum
               Average
     (B)  With Unrefrigerated Saaple Collection
               Minimum
               Maximum
               Average
  .30
  .82
  .79

  .65
  .55
                                                                                    1.99
   30
   82
   78

   77
   55
                                                                                    2 . 02
 1.57
 6.73
 2.97

 2.27
 5.34
 3.17
 1.57
 6.73
 2.99

 2.27
 5.34
 3.23
1.28
2.52
1.80
                                                                                                                         39
                                                                                                                         35
                                                                                                                       1.86
                                                                                                                       1.28
                                                                                                                       2.52
                                                                                                                       1.82
                                                                                                                         40
                                                                                                                         35
1.52
7.40
3.24

1.97
5-98
2.93
                 5?
                 40
                 28

                 97
                 9R
                                                                                                                       1.93
                                                                                                                                      3.12
                        (3)   MILLS WITH BIOLOGICAL TREATMENT;  FINAL EFFLUENT
                             LEVELS AT OR BETTER THAN BPT.   BIOLOGICAL TREATHt NT
                             IS THE TECHNOLOGY BASIS OF BPT EFFLUENT LIMITS
                             (A)  With Refrigerated Sample Collection
                                       Minima                                      1.
                                       Maxiaua                                      2
                                       Average                                      1.
                             (B)  With Unrefrigerated Sample Collection
                                       Minimum                                      1
                                       Maximum                                      2
                                       Average                                      2.02

                        (4)   MILLS WITH BIOLOGICAL TREATMENT; FINAL EFFLUENT
                             LEVELS AT OR BETTER THAN NSPS OPTION 1 LEVELS.
                             BIOLOGICAL TREATMENT IS THE TECHNOLOGY BASIS OF
                             BPT EFFLUENT LIMITS
   .30
   .82
   78

   77
   .55
 1.57
 6.73
 2.99

 2.27
 5.34
 3.23
1.28
2.52
1.82
1.40
2.35
1.93
                                                                                                                52
                                                                                                                40
                                                                                                                28

                                                                                                                97
                                                                                                                98
                                                    3.12
                             (A)  With Refrigerated Sample Collection
                                       Minimum
                                       Maxiaua
                                      ; Average
                             (B)  With Unrefrigerated Sample Collection
                                       Minimum
                                       Maximum
                                       Average
 1.39
 2.82
 1.91
   77
   08
 1.93
 1.93
 6.73
 3.54

 2.54
 5.34
 3.72
1.50
2.44
1.90
1.40
2.35
1.88
                                                                                                                 98
                                                                                                                 93
               3.65
                                                                                                                 36
                                                                                                                 68
                                                    2.85

-------
                                                                              TABLE VIII-49  (cont.)
                        (5)  HILLS WITH PRIMARY CLARIFICATION; FINAL EFFLUENT LEVELS
                             AT OR BETTER THAN BPT LIMITS.  PRIMARY CLARIFICATION  IS
                             THE TECHNOLOGY  BASIS OF BPT EFFLUENT LIMITS
                        (6)
                             (A)  With Refrigerated Saaple Collection
                                       Minima
                                       Max latin
                                       Average
                             (B)  With Unrefrigerated Sample Collection
                                       Minima
                                       Maxima
                                       Average
                                                             .32
                                                             .64
                                                             .49

                                                             .45
                                                             .62
                                                            1.54
     HILLS WITH PRIMARY CLARIFICATION;  FINAL EFFLUENT LEVELS
     AT OR BETTER THAN NSPS OPTION 1 LEVELS.   PRIMARY CLARIFI-
     CATION IS THE TECHNOLOGY BASIS OF BPT EFFLUENT MHITS
               1.76
               3.75
               2.73

               1.80
               4.3
               3.08
                    1.29
                    1.92
                    1.51
                      30
                      86
                                                                                               1.53
              2.09
              5.49
              3.21

              2.59
              4.01
              3.32
CO
CO
     (A)  With Refrigerated Saaple Collection
               Hiniaua
               Haxlaua
               Average
     (B)  With Unrefrigerated Saaple Collection
               Minlaua
               Haxiaua
               Average

(7)   MILLS WITH CHEMICALLY ASSISTED CLARIFICATION

     (A)  With Refrigerated Saaple Collection
               Miniaua
               Haxiaua
               Average
     (B)  With Unrefrigerated Sample Collection
               No Data Available.
1.32
 .64
 .48

 .62
 .62
 .62
                                                                                    2.05
                                                                                    2.10
                                                                                    2.08
1.92
3.75
3.05
                                                                                                      36
                                                                                                      36
                                                                                                    4.36
               2.56
               2.83
               2.70
.46
.92
.64

.86
.86
.86
                    1.41
                    2.14
                    1.78
                                                                                                                                        ,85
                                                                                                                                         49
                                                                                                                                       3.76
                                     01
                                     01
                                                                                                                                       4.01
              2.39
              2.92
              2.66

-------
Minimum,  maximum, and average variability factors were determined for
each of two subsets of mills.  These subsets were developed  from  the
group of mills with primary clarification and are as follows:

Subset Number            Subset Description

     (5)                      Mills with effluent levels at or better
                              than BPT with primary clarification as
                              the technology basis of BPT effluent
                              limits.

     (6)                      Mills with effluent levels at or better
                              than NSPS Option 1  with primary clari-
                              fication as the technology basis of
                              BPT effluent limits.

Average  maximum  daily and maximum 30-day average variability factors
for these two subsets are  shown  in  Table  VII1-49.   Based  on  the
results,  where  primary  clarification  is  the basis of BPT and NSPS
technology  options,  EPA  has  based  the  30-day  average   effluent
limitations for BODjj and TSS on the 30-day average variability factors
developed  for subset (6), using refrigerated data, because (a) subset
(6) most resembles treatment system performance that will be  required
at  new  sources  and (b) refrigeration of samples will be required by
permitting authorities.

The  resulting  BOD£  and  TSS  30-day  average  and   daily   maximum
variability  factors  to be applied for those technology options where
primary clarification is the technology basis are as follows:

                    30 Day Average Variability Factors

                              BOD5_ = 1 .48
                              TSS «  1.64

                    Daily Maximum Variability Factors

                              BOD5_ = 3.05
                              TSS  =3.76

A summary of the  variability  factors  established  for  conventional
pollutant NSPS is presented in Table VIII-50.

TOXIC AND NONCONVENTIONAL POLLUTANT REMOVAL TECHNOLOGY ASSESSMENT

The  factors  considered in establishing the best available technology
economically achievable (BAT) level of control  include  environmental
considerations  such  as  air pollution, energy consumption, and solid
waste generation, the costs of applying the  control  technology,  the
age of process equipment and facilities, the process employed, process
changes,  and  the  engineering  aspects  of applying various types of
control  techniques  (Section  304(b)(2)(B)).   In  general,  the  BAT
technology   level   represents,  at  a  minimum,  the  best  existing
                                489

-------
                                 TABIE VIII-50

                      SUMMARY OF NSPS VARIABILITY FACTORS

                              BODS                               TSS
               Maximum 30-Day     Maximum        Maximum 30-Day     Maximum
                  Average	Day	Average   	Day

                    1.91            3,54              1,90            3.64
The above variability factors apply for the following subcategories:

Dissolving Kraft                             Groundwood-Thermo-Mechanical
Market Bleached Kraft                        Groundwood-CMN Papers
BCT Bleached Kraft                           Groundwood-Fine Papers
Alkaline-Fine
 (including Fine Bleached Kraft and Soda)    Deink
Unbleached Kraft                             Tissue From Wastepaper
Seai-Chemical                                Paperboard From Wastepaper
Unbleached Kraft and Semi-Chemical           Wastepaper-Molded Products
Dissolving Sulfite Pulp                      Builders' Paper and Roofing Felt
Papergrade Sulfite (Blow Pit and Drum Wash)  Nonintegrated-Fine Papers


                   1.48            3.05              1.64             3.76
The above variability factors apply for the following subcategories:

Nonintegrated-Tissue Papers
Nonintegrated-Lightweight Papers
Nonintegrated-Filter and Nonwoven Papers
Nonintegrated-Paperboard
                                        490

-------
economically   achievable   performance   of    plants    of    shared
characteristics.    Where existing performance is uniformly inadequate,
BAT technology may be transferred  from  a  different  subcategory  or
industrial  category.   BAT  may  include  process changes or internal
controls, even when not common industry practice.

The primary determinant of BAT is effluent reduction capability  using
economically  achievable  technology.   As a result of the Clean Water
Act of 1977, the achievement of BAT has become the national  means  of
controlling  the  discharge  of  toxic pollutants.  The best available
technology economically achievable must be implemented no  later  than
July 1, 1984, for the control of toxic and nonconventional pollutants.

The  Clean Water Act requires that pretreatment standards for existing
sources (PSES) and  pretreatment  standards  for  new  sources  (PSNS)
control  the  discharge  of  pollutants  which pass through, interfere
with, or are otherwise incompatible with the operation of POTWs.   The
Act  also  requires  pretreatment  for  pollutants  that  limit sludge
management alternatives at POTWs,  including  the  beneficial  use  of
sludges on agricultural lands.

In   Section   VI,   EPA  recommended  that  effluent  limitations  be
established for the following three toxic pollutants:

     trichlorophenol,
     pentachlorophenol, and
     zinc.

Another  toxic  pollutant  that  could  prove  to  be  of  concern  is
chloroform.    However,   as  discussed  in  Section  VI,  the  Agency
determined that promulgation of uniform national BAT  limitations  and
PSES,  PSNS,  and  NSPS controlling the discharge of chloroform is not
justified.

The most important  nonconventional  pollutants  associated  with  the
production of pulp, paper, or paperboard are color, ammonia, and resin
acids  and  their  derivatives.   Uniform national pollutant discharge
standards  are  not  being  established  for   these   nonconventional
pollutants.   Color  and  ammonia  may  be  controlled  by  permitting
authorities on a case-by-case  basis  as  dictated  by  water  quality
considerations.   Limited  information  exists  on the levels of resin
acids and their derivatives present in wastewater discharges from  the
pulp,  paper, and paperboard industry.  This sparsity of data makes it
impossible at  this  time  to  establish  uniform  national  standards
limiting the discharge of these compounds.

Control  and treatment options have been identified for the control of
toxic  pollutants  (trichlorophenol,  pentachlorophenol,   zinc,   and
chloroform)  and  for the control and treatment of the nonconventional
pollutants (ammonia and color), should a case-by-case determination be
made that they should be regulated.
                                491

-------
Chlorophenolics

Trichlorophenol and pentachlorophenol can be  controlled  through  the
substitution  of  slimicides  and  biocide  formulations  that  do not
contain chlorinated phenolics to  replace  formulations  that  contain
these  toxic  pollutants.    Substitution would ensure that substantial
quantities   of   the   toxic   pollutants    pentachlorophenol    and
trichlorophenol  would  be  removed  from  pulp,  paper, and paperboard
industry wastewaters.

Chemicals containing pentachlorophenol (PCP) were being used at ten of
the 60 facilities sampled during   the  verification  program  and  at
neither  of  the  two  mills  sampled  during  the  long-term sampling
program.  Chemicals containing trichlorophenol (TCP) were used at  six
of  the  verification  mills  and  neither of the mills sampled in the
long-term  sampling  program.   Chlorophenolics  were   detected   and
reported  at  consistently  higher  levels  at  facilities where these
compounds were  used.   As  a  result,  chemical   substitution  is  an
applicable technology option for control of Chlorophenolics.  The data
used  in  assessing  the  capability  of  chemical  substitution  were
obtained during  the  verification  sampling  program,  the  long-term
sampling  program,   and  from industry comments on the January 6, 1981
proposed regulations.  These data have been adjusted according to  the
following formula:  Adjusted concentration = (Measured concentration) x
(Unit flow basis of BPT effluent limitations)/(Actual mill unit flow).
This  adjustment  was made to reflect the actual  mass discharge of TCP
and PCP from the sampled mills.   This ensures that TCP  and  PCP  data
used  in  assessing the capability of chemical substitution relate the
quantity of chlorinated phenolics discharged directly to production.

Data from mills where Chlorophenolic-containing biocides are used were
not included in assessing  the  capability  of  chemical  substitution
since  EPA was interested in determining what reductions occurred when
biocides were not used.  Only verification and long-term sampling data
were used in this assessment  because  industry  data  were  generated
using  a  different  analytical   method.   Industry  data were used to
determine  if  Agency  assessments  were  realistic.   Data  from  the
verification  and  long-term  sampling  programs were combined and are
presented in Tables VIII-51 through VIII-54.  The additional  TCP  and
PCP  data  submitted  by industry are summarized in Tables VIII-55  to
VIII-58.

EPA learned that chemical substitution does not prevent all discharges
of TCP and PCP.  TCP is  a  suspected  bleach  plant  by-product  when
chlorine  or  chlorine-containing  compounds  are used to bleach pulp.
PCP, historically used as a biocide in this and other industries, is a
known contaminant in wastepaper.  In order  to  differentiate  between
PCP  and  TCP  present  from  the  use of biocides and the PCP and TCP
present from other sources, EPA analyzed the quantity of PCP  and  TCP
present   in   the   wastewaters   from   mills   where   chlorine  or
chlorine-containing compounds are used to bleach pulp and  from  mills
where  PCP  contamination  is  likely  to  occur.  EPA then used these
quantities to determine what effluent limitations were  attainable  if
                               492

-------
the PCP/TCP contribution from biocides were eliminated.  (As explained
previously,  EPA  is  not  setting  limits  to  control  PCP  and  TCP
discharges resulting from bleaching or  raw  material  contamination.)
Where  PCP  and  TCP were present but not attributable to a particular
source,  EPA  established  the  effluent  limitation  at  the  highest
discharge   level   found.   To  assess  the  capability  of  chemical
substitution,  the industry  was  segmented  into  the  following  five
groupings:

(1)  Integrated mills where chlorine or chlorine-containing  compounds
     are  used  to  bleach  pulp  (at  these  mills,  TCP formation is
     possible, but PCP contamination is unlikely);
(2)
Integrated mills, excluding the semi-chemical subcategory,  where
chlorine-containing  compounds  are  not  used to bleach pulp (at
these mills,  TCP formation is unlikely and PCP  contamination  is
unlikely);
(3)  Deink mills where chlorine or chlorine-containing  compounds  are
     used  to  bleach  pulp (at these mills, TCP formation is possible
     and PCP contamination is likely);

(4)  The semi-chemical subcategory and other secondary fiber mills (at
     these mills, TCP formation is unlikely and PCP  contamination  is
     likely); and

(5)  Nonintegrated mills (at these mills, TCP formation  is  unlikely;
     because  some  wastepaper is used at a number of these mills, PCP
     contamination is possible).

As shown in Tables VIII-51 and VIII-52, wastewaters from  mills  where
chlorine or chlorine-containing compounds are used to bleach pulp have
higher  levels  of  TCP  than  wastewaters from other groups of mills.
Tables VIII-53 and VIII-54 show  that  wastewaters  from  mills  where
wastepaper  is used have higher PCP levels than wastewaters from other
groups of mills.

Efforts to characterize the distributional form of the available final
effluent data included fitting the normal and lognormal  distributions
to these data and using several power transformations to make the data
symmetric.  Results of these analyses showed that it was inappropriate
to apply parametric methods (i.e., methods that assume the data follow
a   particular   distributional   form)   to   the  data.   Therefore,
nonparametric methods were used to compute estimated 99th percentiles.
In this analysis,  data  reported  as  less  than  minimum  reportable
concentrations (MRC) were set equal to the MRC.

The  99th  percentile  (Q99)  is  defined  as the observation numbered
closest to .99N.  That is,

          Q,, = X (.99N) if .99N is an integer

              = X ([.99N]+1) if .99N is not an integer,
                                  493

-------
                                                     TABLE VIII-51

                                    SUMMARY OF UNCORRECTED TRICHLOROPHENOL RESULTS
                                  FOR MILLS WHERE VERIFICATION AND LONG-TERM SAMPLING
                            WERE CONDUCTED AND WHERE CHLOROPHENOLIC BIOCIDES WERE NOT USED
Mill Number
      Influent to Bio-Treatment
	Concentration (|jg/l)(a)
                         Number of
Average	Range	Observations
                                                                                           Final Effluent
                                                                                       Concentration
           Average
                                                                                               Range
                                                                                                         Number of
                                                                                                        Observations
MILLS THAT BLEACH PULP USING CHLORINE
OR CHLORINE CONTAINING COMPOUNDS

1.   MILLS THAT UTILIZE WASTEPAPER

          140014(b)                           47
          140014(c)
          140021                               8

2.   MILLS THAT DO NOT UTILIZE WASTEPAPER

          030013                               2
          030020                               3
          030030                              19
          030047                               9
          046004                               9
          046006                               5

MILLS THAT DO NOT BLEACH

1.   MILLS THAT UTILIZE WASTEPAPER

          110020                               5
          110032                               1
          110043                               1

2.   MILLS THAT DO NOT UTILIZE WASTEPAPER

     Not Detected
              27-70

               0-19
               0-6
               2-4
              12-24
               7-10
                9
               4-6
               3-7
               0-3
               0-2
 3

19
23
 3
 3
 3
 1
 3
39
26
 4
36-42
 8-68
 0-25
                0-11
                0-2
                 5
                 0
                 1
                3-4
                             0
                             0
                            0-4
 3
16
69
             69
              3
              3
              3
              1
              3
(a)  Concentrations are adjusted to BPT flow.
(b)  This mill biologically treats only a portion of the total mill effluent.  Data shown are representative of
     the secondary influent and effluent only.
(c)  The final effluent data shown are for the total effluent, and are based on an effluent monitoring program
     conducted by the mill.
                                                             494

-------
                                                     TABLE VIII-52
                                    SUMMARY OF UNCORRECTED TRICHLOROPHENOL RESULTS
                                  FOR MILLS WHERE VERIFICATION AND LONG-TERM SAMPLING
                              WERE CONDUCTED AND WHERE CKLOROPHENOLIC BIOCIDES WERE USED
Mill Number
      Influent to Bio-Treatment
	Concentration (ng/l)(a)	
                         Number of
Average	Range	Observations
          Final Effluent
 	Concentration (pg/l)(a)	
                         Number of
Average	Range	Observations
MILLS THAT BLEACH PULP USING CHLORINE
OR CHLORINE CONTAINING COMPOUNDS

1.   MILLS THAT UTILIZE WASTEPAPER

     140007                                3

2.   MILLS THAT DO NOT UTILIZE WASTEPAPER

     030004                                6
     030005                                1
     030027                               10
     030032                               10
     030046                                8
     040013                              152
     040017                                6

MILLS THAT DO NOT BLEACH

1.   MILLS THAT UTILIZE WASTEPAPER

     110087(b)                           278

2.   MILLS THAT DO NOT HTTLIZE WASTEPAPER

     Not Detected
              0-8
              0-10
              0-2
              7-12
              4-17
              6-12
            144-161
              5-6
            209-324
   1
   2
   4
   0
   2
  92
   1
                                       331
                                                     0-11
 0-3
 1-2
 3-4
  0
 1-2
74-118
 1-2
                                                   323-346
(a)  Concentrations are adjusted to BPT flow.
(b)  This mill is a high recycle facility and utilizes primary treatment only.  The influent
     data shown are for the influent to primary.  The final effluent data shown are primary
     effluent data.
                                                            495

-------
                                                     TABLE VII1-53
                                   SUMMARY OF UNCORRECTED PENTACKLOROPHENOL RESULTS
                                  FOR MILLS WHERE VERIFICATION AND LONG-TERM SAMPLING
                            WERE CONDUCTED AND WHERE CHLOROPHENOLIC BIOCIDES WERE NOT USED
Mill Number
      Influent to Bio-Treatment
	Concentration (pg/l)(a)	
                         Number of
Average	Range	Observations
          Final Effluent
 	Concentration (|jg/l)(a)	
                         Number of
Average	Range    Observations
MILLS THAT BLEACH PULP USING CHLORINE
OR CHLORINE CONTAINING COMPOUNDS

1.   MILLS THAT UTILIZE WASTEPAPER

     1400U(b)                              37
     140014(c)
     140021                                  4

2.   MILLS THAT DO NOT UTILIZE WASTEPAPER

     030013                                  1

MILLS THAT DO NOT BLEACH

1.   MILLS THAT UTILIZE WASTEPAPER

     020017                                  1
     110020                                 10
     110031                                  2
     110032                                  2
     120050(d)                              17

Z.   MILLS THAI DO NOT UTILIZE WASTEPAi-ER

     Not Detected
               9-55
               0-11
               0-11
               0-2
               0-16
               0-5
               0-5
              11-25
                                         33
                                         16
                           19
                           23
               29-36
                8-21
                0-22
                                                      0-7
                0-1
                0
                0
                0
 3
16
69
                                                                   69
(a)  Concentrations are adjusted to BPT flow.
(b)  This mill biologically treats only a portion of the total mill effluent.  Data shown are
     biological influent and effluent only.
(c)  This mill biologically treats only a portion of the total mill effluent.  The final
     effluent data shown are for the total effluent, and are based on an effluent monitoring
     program conducted by the mill.
(d)  This mill is a high recycle facility and discharges to a POTW.
                                                            496

-------
                                                     TABUE VIII-54
                                   SUMMARY OF L'NCORRECTED PENTACHLOROPHENOL RESULTS
                                  FOR MILLS WHERE VERIFICATION AND LONG-TERM SAMPLING
                              WERE CONDUCTED AND WHERE CHLOROPHENOLIC BIOCIDES WERE USED
Mill Number
      Influent to Bio-Treatment
	Concentration (pg/l)(a)	
                         Number of
Average	Range	Observations
                                   Final Effluent
                          	Concentration ((Jg/l)(j)	
                                                  Number of
                         Average	Range	Observations
MILLS THAT BLEACH PULP USING CHLORINE
OR CHLORINE CONTAINING COMPOUNDS

1.   MILLS THAT UTILIZE WASTEPAPER

     140007

2.   MILLS THAT DO NOT UTILIZE WASTEPAPER

     030004
     030046
     040013
     040017

MILLS THAT DO NOT BLEACH

1.   MILLS THAT UTILIZE WASTEPAPER

     015007
     110087(b)
     150011

2.   MILLS THAT DO NOT UTILIZE WASTEPAPER

     052004
    28
     7
     0
     6
     2
   811
     2
               5-13
  7-46
  5-10
  0-1
  5-6
  0-6
657-927
  0-5
                                                         3-8
 28
  1
  0
  0
  0
923
  1
                                                       2-10
 24-31
  0-1
   0
   0
846-1076
  0-3
                                                                                                 0-1
(a)  Concentrations are adjusted to BPT flow.
(b)  This mill is a high recycle facility and utilizes primary treatment only.  The influent data shown are
     for the influent to primary.  The final effluent data shown are primary effluent data.
                                                         497

-------
where X(.99N) is the (.99N)th ordered value in a sample  of  N  values
ordered  from  low to high on the random variable X,  and [.99N] is the
largest integer contained in (.99N).   For example, if N = 200, Q99  is
the  198th ordered daily value,  since .99N = 198.  If N is 201, .99N =
198.99, so that  [.99N]   =  198,  and  Q9,  =  199.    [Computation  of
percentiles  is  discussed  in  several  texts.  See,  for example,  R.A.
Fisher, Statistical Methods for Research Workers,  14th  Edition,   New
York, Hafner Publishing  Company (1973) ]  (209).

Assessment  of_  Trichlorophenol  Discharge  Characteristics  For Mills
Where Chlorine or Chlorine-Containing Compounds  Are  Used  to  Bleach
Pulp.     The   source   of   TCP   at   mills   where   chlorine   or
chlorine-containing compounds  are  used  to  bleach  pulp  and  where
chlorophenolic-containing  biocides  are  not  used,   is the bleaching
process.  At these mills, TCP  levels  are  directly  related  to  the
quantity  of  pulp  bleached and, therefore, should not be affected by
water use.  Therefore,  discharge levels (on a mass basis) at new mills
with lower flows should  be equivalent to discharge levels at  existing
mills.    A  summary  of   available data is presented in Table VIII-51.
TCP discharge characteristics were assessed using the 99th  percentile
estimated for each mill  from verification and long-term sampling final
effluent  data.   The  maximum  99th  percentile  estimate is 68 ng/1,
computed from 16  observations  from  mill  140014.    This  value  was
compared  to  data  submitted  by industry representatives and was not
exceeded by any other value.

The Agency also assessed TCP  discharge  characteristics  of  indirect
discharging  mills where chlorine or chlorine-containing compounds are
used to bleach pulp.  EPA determined that some treatment of TCP occurs
in biological systems.   Data  from  mill  140014  were  used  in  this
analysis.    Table VIII-51 presents a summary of these data, which were
obtained during the verification and long-term sampling programs.  The
discharge level for direct dischargers (68 ng/1) was  adjusted  upward
to  reflect the level of TCP present after biological treatment [i.e.,
EPA  determined  that  17  percent  removal  of  TCP  occurred  during
verification  sampling at mill 140014: (47 *g/l - 39 ng/l)/(47 ng/1) =
17 percent].  This results  in  a  discharge" level  of  82   ng/l  for
indirect  discharging  mills  where  chlorine  or  chlorine-containing
compounds are used to bleach pulp and where  chlorophenolic-containing
biocides  are  not  used.   As  discussed  previously,  TCP levels are
directly related to the quantity of pulp bleached and  should  not  be
affected  by water use.   Therefore, discharge levels (on a mass basis)
at new mills should be equivalent  to  discharge  levels  at  existing
mills.   Data submitted by industry representatives (see Table VIII-55)
shows that this level was not exceeded.

Assessment  of_  Pentachlorophenol  Discharge Characteristics  For Mills
Where  Wastepaper  j^s  Used.   The  source  of  PCP  at  mills   where
wastepapers are processed and chlorophenolic - containing biocides are
not  used  is  raw material contamination.  At these mills, PCP levels
are directly related to the  quantity  of  wastepaper  processed  and,
therefore,  should not be affected by water use.  Therefore,  discharge
levels on a mass basis  at  new  mills  with  lower  flows  should  be
                               498

-------
                                                     TABLE VIII-55
                                     SUMMARY OF CORRECTED TRICHLOROPHENOL RESULTS
                                 FOR MILLS WHERE CHLOROPHENOLIC BIOCIDES WERE NOT USED
                                                      NCASI DATA
Mill Identification
                                         Influent to Bio-Treatment
                                            Concentration (|Jg/l)(a)	
                                                              Number of
                                                             Observations
                                     Average
                                        12.1
                                        13.7
                                        21.0
                                        11.0
                                        14.1
                                         9.2
                                        10.
                                        66,
          A
          C
          D
          E
          F
          G
          I
          K
          L                             12.8
          MOO
          N                             10.5
          0(b)
          P
          QUO
          R
          S
          T
          A-100                         18.0
          B-100                         31.5

MILLS THAT DO NOT BLEACH

1.   MILLS THAT UTILIZE WASTEPAPER

          No Data.

2.   MILLS THAT DO NOT UTILIZE WASTEPAPER

          No Data.
                                         9.0

                                        14.1
                                        23.9
                                         3.2
                                                    Range
MILLS THAT BLEACH PULP USING CHLORINE
OR CHLORINE CONTAINING COMPOUNDS

1.   MILLS THAT UTILIZE WASTEPAPER

          No Data

2.   MILLS THAT DO NOT UTILIZE WASTEPAPER
10.5-13.6
12.1-15.3
13.9-28.0
8.4-13.5
13.2-14.9
8.3-10.1
8.6-11.8
60.5-73.2
12.8
10.2-10.8
7.8-10.1
4.0-24.1
20.6-27.2
3.1-3.3
12.4-25.4
24.1-37.8
2
2
2
2
2
2
2
2
1
2
2
2
2
2
13
11
                                                                                        Final Effluent
                                                                                     Concentration (ng/l)(a)
Average
   Range
                                                                                                      Number of
                                                                                                      Observations
 9.2
12.0
 6.3
 4.0
 1.0
 6.2
 6.6
 0.1
 3.7

 3.3

 6.5

 1.6
 1.2
 1.1
 5.5
23.7
 7.2-11.7
10.5-13.6
 1.3-8.3
 2.9-7.4
 0.4-1.9
 5.3-7.5
 1.7-10.6
 0.0-0.7
 2.7-5.0

 1.4-5.2

 5.0-8.5

 0.0-5.3
 0.8-1.9
 0.2-1.9
 0.8-25.4
16.4-27.1
 9
10
10
10
 9
10
10
10
 8

10

10

10
10
10
63
36
(a) Concentrations are adjusted to BPT flow.
(b) Mill biologically treat! only a portion of the total mill effluent.
    Data were not representative of total Bill effluent and were eliminated from the data base.
                                                              499

-------
                                                     TABLE VIII-56
                                     SUMMARY OF CORRECTED TRICHLOROPHENOL RESULTS
                                   FOR MILLS WHERE CHLOROPHENOLIC BIOCIDES WERE USED
                                                      NCASI DATA
Mill Identification
     Influent to Bio-Treatment
	Concentration (pg/l)(a)	
                          Number of
 Average	Range	Observations
          Final Effluent
	Concentration (pg/l)(a)	
                        Number of
 Average	Range	Observations
MILLS THAT BLEACH PULP USING CHLORINE
OR CHLORINE CONTAINING COMPOUNDS
1.
2.
     MILLS THAT UTILIZE WASTEPAPER

          No Data

     MILLS THAT DO NOT UTILIZE WASTEPAPER
                                        40.0
                                         3.7
                                         6.9
                                        11.6
              28.6-51.3
               3.0-4.4
                 6.9
              11.2-12.0
  23.8
   2.0
   6.2
  11.6
18.9-32.4
 0.7-4.9
 3.9-8.8
 8.8-15.6
10
10
10
 8
MILLS THAT DO NOT BLEACH

1.   MILLS THAT UTILIZE WASTEPAPER

          No Data

2.   MILLS THAT DO NOT UTILIZE WASTEPAPER


          No Data
(a) Concentrations are adjusted to BPT flow.
                                                           500

-------
equivalent  to  discharge  levels at existing mills.  A summary of the
available data is presented  in  Table  VIII-53.   As  with  TCP,  PCP
discharge  characteristics  were  assessed  using  the 99th percentile
estimated for each mill from verification and long-term sampling final
effluent data.  The maximum  99th  percentile  estimate  is  22  ug/1,
computed   from   69   observations   from   mill   140021.   Industry
representatives did not submit final effluent  data  for  mills  where
wastepaper is processed (see Table VI I 1-57).

Discharge  characteristics  of  indirect  discharging  mills were also
assessed to reflect the treatability of  PCP  in  biological  systems.
Data  from  mill  140014  were  used  in this analysis.  Table VIII-53
presents a summary  of  the  data,  which  were  obtained  during  the
verification   program.    The  maximum  discharge  level  for  direct
dischargers (22 *g/l) was adjusted upward to reflect the level of  PCP
present  after  biological  treatment  [i.e.,  EPA  determined that 11
percent removal of PCP occurred at  mill  140014  during  verification
sampling:  (37  ».g/l - 33 ».g/l)/(37 *g/l) = 11 percent].  This results
in a level of 25 *g/l for indirect discharging mills where  wastepaper
is  processed and chlorophenolic-containing biocides are not used.  As
discussed previously, PCP levels are directly related to the  quantity
of  wastepaper processed and. should not be affected by water use.  EPA
compared this level to data submitted by industry to determine if  the
Agency assessment is realistic.  EPA found that the discharge level of
25  *g/l  was  exceeded; a maximum value of 31.9 *g/l was reported for
mill IV (see Table VIII-57).  The Agency then adjusted its  evaluation
of  the maximum discharge level characteristic of indirect discharging
mills upward to 32
EPA then reassessed its evaluation  of  the  maximum  discharge  level
characteristic  of  direct discharging mills.  The Agency adjusted the
maximum discharge level  for  indirect  discharging  mills  (32  *g/l)
downward  to  reflect  the  degree  of  treatment  that occurs through
biological treatment.  This results in a  level  of  29  *g/l  as  the
maximum  PCP  discharge  level  characteristic  of  direct discharging
mills.

Assessment of_  Trichlorophenol  Discharge  Characteristics  For  Mills
Where  Chlorine  or  Chlorine-Containing  Compounds  Are Not Used.  As
shown in Table VI I 1-51, TCP has been measured at only very low  "levels
(all   measurements   were   less   than   10  »«g/l)  at  mills  where
chlorine-containing compounds are not used to bleach  pulp  and  where
chlorophenolic-containing  biocides  are  not  used.   Therefore,  the
Agency has assumed that 10 *g/l is the maximum TCP discharge level  at
these mills.

Assessment  of_  Pentachlorophenol  Discharge Characteristics For Mills
Where Wastepaper i^ Not Used.  As shown in Table VIII-53, PCP has been
measured at only very low levels (all measurements  were  11  *g/l  or
less)  at mills where chlorophenolic-containing biocides are not used.
Therefore, the Agency has assumed that 11  ug/1  is  the  maximum  PCP
discharge level at these mills.
                               501

-------
                                                     TABLE VIII-57
                                    SUMMARY OF CORRECTED PENTACHLOROPHENOL RESULTS
                                 FOR MILLS WHERE CH10ROPHENOLIC BIOCIDES WERE NOT USED
                                                      NCASI DATA
Mill Identification
     Influent to Bio-Treatment
	Concentration (MR/l)(a)	
                          Number of
 Average	Range	Observations
                                    Final Effluent
                          	Concentration (|Jg/l)(a)	
                                                  Number of
                           Average      Range	Observations
MILLS THAT BLEACH PULP USING CHLORINE
OR CHLORINE CONTAINING COMPOUNDS

1.   MILLS THAT UTILIZE WASTEPAPER

          No Datj

2.   MILLS THAT DO NOT UTILIZE WASTEPAPER
          A
          C
          D
          E
          F
          G
          I
          K
          L
          M(b)
          N
          0(b)
          P
          Q(b)
          R
          S
          T
          A-100
          B-100
     0.7
     1.6
     1.3
     2.0
     1.3
     2.5
     0.0
     0.8
     3.5

     0.0

     0.8

     3.0
     2.0
     0.4
     0.2
     1.2
0.5-0.8
    1.6
0.9-1.7
1.9-2.1
    1.3
2.4-2.6
    0.0
0.7-0.8
    3.5

    0.0

0.7-0.9

0.0-5.9
1.5-2.5
0.2-0.6
0.0-1.1
0.5-1.7
 2
 2
 2
13
11
0.3
0.8
0.5
1.2
0.9
2.7
0.1
0.0
2.1

0.0

0.2

0.9
0.5
0.2
0.0
0.9
0.0-0.5
0.5-1.7
0.0-1.1
0.0-2.0
0.7-1.1
2.2-3.1
0.0-0.8
    0.0
0.8-2.9

    0.0

0.0-0.9

0.0-2.5
0.0-1.1
0.1-0.3
    0.0
0.0-1.6
 9
10
10
10
 9
10
10
10
 8

10

10

10
10
10
63
36
MILLS THAT DO NOT BLEACH

1.   MILLS THAT UTILIZE WASTEPAPER

          I(c)                           6.9       6.1- 7.5
          II(c)                          7.8       6.1- 9.9
          III(c)                         7.9       5.6- 9.0
          IV(c)                         22.4      12.7-31.9
          V(c)                           9.5       6.4-13.8
          VI(c)                         18.6      13.9-23.5
          VII(c)                        15.0      10.4-19.6
          VIII(c)                        4.2       2.0- 5.5

2.   MILLS THAT DO NOT UTILIZE WASTEPAPER

     No Data
(a)  Concentrations are adjusted to BPT flow.
(b)  Mill biologically treat* only a portion of the total aill effluent.  Data were not representative of total
     •ill effluent and were eliminated from the data base.
(c)  Data for mills I-VIII are froa untreated wastewater samples from mills that manufacture vastepaper board.
     Most of these Bills discharge to POTWs.  It is assumed that they do not bleach.
                                                    502

-------
                                                     TABLE VIII-58
                                    SUMMARY OF CORRECTED PENTACHLOROPHENOL RESULTS
                                   FOR MILLS WHERE CHLOROPHENOLIC BIOCIDES WERE USED
                                                      NCASI DATA
Mill Identification
     Influent to Bio-Treatment
	Concentration (pg/l)(a)	
                          Number of
 Average	Range	Observations
                                     Final Effluent
                           	Concentration lpij/l)(a)	
                                                   Number of
                            Average	Range	Observations
MILLS TRAT BLEACH PULP USING CHLORINE
OR CHLORINE CONTAINING COMPOUNDS

I.   MILLS THAT UTILIZE WASTEPAPER

          No Data

2.   MILLS THAT DO NOT UTILIZE WASTEPAPER
          B
          H
          J
          V

MILLS THAT DO NOT BLEACH
    18.4
    16.0
     8.8
     4.1
1.9-34.9
6.8-25.1
     8.8
3.7- 4.5
12.5
 4.9
11.3
 6.4
1.0-23.9
1.0-13.4
9.0-15.7
3.6-10.4
10
10
10
1.    MILLS THAT UTILIZE WASTEPAPER

          No Data

2.    MILLS THAT DO NOT UTILIZE WASTEPAPER

          No Data
(a) Concentrations are adjusted to BPT flow.
                                                           503

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Tables  VIII-59 and VIII-60 present a summary of the TCP and PCP daily
maximum discharge  characteristics  for  each  of  the  five  industry
groupings.

Zinc

At  groundwood  mills,  zinc hydrosulfite can be used for the bleaching
of pulp.  Significantly higher quantities of zinc are discharged  from
mills  where  zinc  hydrosulfite  is  used than from mills where other
bleaching chemicals are used.   In 1977,  EPA  issued  BPT  regulations
controlling  the  discharge of zinc from groundwood mills based on the
application of lime precipitation.  The Agency determined that the BPT
zinc limitations  are  now  being  achieved  at  all  existing  direct
discharging  groundwood  mills  through  chemical substitution (sodium
hydrosulfite in place of zinc hydrosulfite).  Therefore, the  original
BPT  effluent limitations for zinc ensure that only low levels of zinc
are being discharged from direct discharging groundwood mills.

EPA believes that application of zinc limitations and standards  based
on   the   same   maximum  discharge  concentration  as  BPT  effluent
limitations will  have  the  identical  effect  as  the  original  BPT
regulations: sodium hydrosulfite rather than zinc hydrosulfite will be
used  to  bleach  groundwood  pulp.   This  would ensure that only low
levels of zinc would be  discharged  from  both  direct  and  indirect
discharging mills.

Therefore,   for  BAT  and  PSES,  zinc  limitations and standards were
determined as the product of (a) the maximum  discharge  concentration
that  forms  the basis of BPT effluent limitations for control of zinc
and (b) the flows that form the basis of BPT effluent limitations  for
each  of  the  groundwood  subcategories.   For  NSPS  and  PSNS, zinc
standards were determined as the product of (a) the maximum  discharge
concentration  that  forms  the  basis of BPT effluent limitations for
control of zinc and (b) the flows that form the basis of NSPS for each
of the groundwood subcategories.

Chloroform

The data used to  assess  chloroform  discharge  characteristics  were
obtained  during  the verification and long-term sampling programs and
from industry comments on the January 6, 1981, proposed regulations.

The Agency's review of available  data  indicates  that  there   is  no
correlation   between  biological  effluent  and  biological  influent
chloroform.  Table VIII-61 presents a summary  of  the  representative
data; these data are plotted in Figure VII1-3 and show that chloroform
is   effectively  controlled  by  BPT  technology  when  BPT  effluent
limitations are attained, with the exception of mills  employing  pure
oxygen  or  deep  tank  activated sludge systems.  The fact that mills
where  volatilization  is  inhibited  discharge   higher   levels   of
chloroform suggests that air stripping is the removal mechanism.
                                504

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                                 TABLE VIII-59

                    SUMMARY OF PENTACHLOROPHENOL (PCP) AND
                TRICHLOROPHENOL (TCP) DISCHARGE CHARACTERISTICS
                         FOR DIRECT DISCHARGING MILLS
                                                  PCP                 TCP
Mill Category	(Mg/D	(M8/D
1.   Integrated Mills Where Chlorine is           11                  68
     Used to Bleach Pulp

2.   Integrated (excluding Semi-Chemical)         11                  10
     Mills Where Chlorine
     is Not Used to Bleach Pulp

3.   Deink (excluding
     Newsprint) Mills                             29                  68

4.   Other Secondary Fiber
     and Semi-Chemical Mills                      29                  10

5.   Nonintegrated Mills                          29                  10
                                      505

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                                 TABLE VIII-60
                    SUMMARY OF PENTACHLOROPHENOL (PCP) AND
                TRICHLOROPHENOL (TCP) DISCHARGE CHARACTERISTICS
                        FOR INDIRECT DISCHARGING MILLS
                                                  PCP                 TCP
Mill Category	(pg/1)	(pg/1)
1.   Integrated Mills Where Chlorine is           11                  82
     Used to Bleach Pulp

2.   Integrated (excluding Semi-Chemical)         11                  10
     Mills Where Chlorine
     is Not Used to Bleach Pulp

3.   Deink (excluding Newsprint)
     Mills                                        32                  82

4.   Other Secondary Fiber and
     Semi-Chemical Mills                          32                  10

5.   Nonintegrated Mills                          32                  10
                                        506

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                                                     TABLE VIII - 61
                                            SUMMARY OF UNCORRECTED CHLOROFORM
                                  BIOLOGICAL INFLUENT AND EFFLUENT CONCENTRATIONS (pg/1)
                                  FROM THE VERIFICATION AND LONG-TERM SAMPLING PROGRAMS
                                          (CHLORINE BLEACHING FACILITIES ONLY)
Biological Influent
Subcategory/ Treatment
Mill Number System (a)
FACILITIES
MEETING BPT LIMITS
Average Range Number of
Observations



Biological Effluent
Average

Range Number of
Observations


Data Source(

Market Bleached Kraft
030005
030030
ASB
ASB
1,633
1,177
1300-2200
830-1600
3
3
17
7
12-20
6-7
3
3
(V)
(V)
BCT Bleached Kraft
030032
ASB
2,833
1400-4000
3
2
0-4
3
(V)
Alkaline-Fine(c)
030020
030027
030046
Papergrade
040018
Deink-Fine
140007
ASB
AS
ASB
Sulfite(d)
AS(c)
Papers
AS
1,081
1,400
963

3,100

4,190
43-1700
1100-1800
690-1100

1500-4700

670-9700
3
3
3

3

3
43
110
4

56

145
39-46
110
2-6

45-69

95-240
3
3
3

3

3
(V)
(V)
(V)

(V)

(V)
Deink-Iissue Papers
140014
140015
140021
FACILITIES
AS(e)
AS
AS
EXCEEDING BPT LIMITS
1,367
25
262

1000-1800
12-46
60-800

3
3
19

55
5
32

48-61
2-10
10-61

3
3
69

(V)
(V)
(L)

Dissolving Kraft

032001           AS

BCT Bleached Kraft

030C04          ASB

Alkaline-Fine(c)

030013            AS

Dissolving Sulfite Pulp
647   360-900
877   580-1400
404   227-772
                     23
                                      67     40-86
                                              5-6
                                      58
                                             21-230
                                                         69
     AS   = Activated Sludge System
     ASB  = Aerated Stabilization Basin
     CTAS = Deep Tank Activated Sludge System
     FF   = Trickling Filter
tb)  V    = Verification Sampling Program
     L    = Long-term Sampling Program
It)  Includes Fine Bleached Kraft and Soda subcategories
M)  Includes Fapergrane Sulfitp (Blow Pit) and Pipergrjde Sulfite (Drum Wash) subcategories
le;  Only pulp mill waste receives activated sludge treatment; data represents only that waste stream.
(V)
(V)
(L)
046004
046006
Papergrade
04C011
040017
AS
ASB
Sulfite
AS+TF
DTAS
320
250

2,033
4,867
320
110-360

1800-2200
1100-8600
1
3

3
3
42
3

573
380
42
1-5

530-620
130-600
1
3

3
3
(V)
(V)

(V)
CV)
                                                         507

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               cc
               o
               u_
               o
               (C
               o
                  600 -i
                  500 -
                  400-
                                          FIGURE VIII-3
                      AVERAGE BIOLOGICAL EFFLUENT CHLOROFORM VERSUS
                           AVERAGE BIOLOGICAL INFLUENT CHLOROFORM
                                                        LEQEND


                                                        O MILLS MEETING BPT LIMITS

                                                        A MILLS NOT MEETING BPT LIMITS
cn
O
O>
               i   300-
               4
               O

               (9
               O
               J  200-
               (9

               4
               (C
                  100 •
                        A
                       O

                       A
  o

An  O
0



G
   O
                               1000
                                           2000         3000



                                       AVERAGE BIOLOGICAL INFLUENT CHLOROFORM
                                                                   4000
                                                                               5000

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Data  from  the  verification  and  long-term  sampling  programs were
combined  and  are  presented  in  Table  VIII-61.    The   additional
chloroform data submitted by industry are summarized in Table VIII-62.
Only  verification  and  long-term  sampling  data  were  used in this
assessment because industry data  were  generated  using  a  different
analytical  method.   Industry  data  were used to determine if Agency
assessments are realistic.

Efforts to characterize the distributional form of the available final
effluent data included fitting the normal and lognormal  distributions
to  available  data.    Results  of  these  analyses showed that it was
inappropriate to apply parametric methods  to  the  data.   Therefore,
nonparametric  methods were used to compute estimated 99th percentiles
and resulting maximum day variability  factors.   These  methods  have
been described in detail earlier in this section.

EPA  computed  mill-specific  maximum day variability factors based on
available long-term chloroform data.  As shown in Table  VIII-63,  the
average  maximum  day  variability factor for chloroform is 2.94.  EPA
determined maximum anticipated  chloroform  discharge  levels  as  the
product   of   (a)  the  average  of  the  mill-specific  maximum  day
variability  factors  and  (b)  the  maximum  mill-specific  long-term
average  for  that  group  of  mills where BPT effluent limits are now
being attained.  As shown in Table VIII-61, the maximum  mill-specific
long-term  average  discharge concentration of chloroform is 145 ug/1.
This results in a maximum discharge level of 426 ug/1 (2.94 x 145 ug/1
= 426 ug/1).

EPA compared this level to data submitted by industry to determine  if
the  Agency  assessment  is  realistic.   The  Agency  found  that the
discharge level of 426 ug/1 was exceeded twice; a maximum value of 450
ug/1 was reported for mill  8 and a  maximum  value  of  610  ug/1  was
reported for mill 13 (see Table VIII-62).

Ammonia

The  discharge  of ammonia can be controlled at mills where ammonia is
used as a base chemical through (a) substitution to a  different  base
chemical  or  (b) through the application of biological treatment in a
mode to allow conversion of ammonia  to  nitrate.   Estimates  of  the
costs  associated  with  ammonia  removal  technology are presented in
Appendix A.

Substitution of a cooking liquor that does not contain  ammonia,  such
as sodium hydroxide,  is anticipated to eliminate virtually all ammonia
from  raw waste discharges.  As a result, ammonia may have to be added
to  the  influent  to  the  biological  system  to  ensure   effective
wastewater  treatment.  This would result in final effluent discharges
of ammonia that are similar to those discharged from all point sources
where wastewaters are nutrient deficient.

There are currently  no  biological  treatment  systems  designed  for
ammonia  removal  in  use  at mills in the pulp, paper, and paperboard
                               509

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                                  TABLE VIII-62
                  SUMMARY OF CORRECTED CHLOROFORM EFFLUENT DATA
                             SUBMITTED BY THE NCASI
                                     (M8/D
 Mill        Treatment                                            Number of
Number	System (a)	Average	Range	Observations

FACILITIES WITH BIO-TREATMENT MEETING BPT LIMITATIONS

  8            AS                   388            345-450            4
  9            AS                   288            235-315            3
 11            AS                   128             62-175            5
 13            ASB                  576            520-610            5
FACILITIES WITH BIO-TREATMENT EXCEEDING BPT LIMITATIONS
1
2

3

4
5
6
7
10
12
14
0 AS
(OS
2
(OS
2
CCAS
AS
AS
DTAS
AS
AS
ASB
1018
1261

1688

1669
186
232
1179
81
398
160
340-1855
1040-1415

1405-2490

1260-2160
150-210
145-330
915-1350
30-125
360-420
40-275
                                                                      5
                                                                      5
                                                                      9
                                                                      9
                                                                      5
                                                                      5
                                                                      5
                                                                      5
                                                                      4
                                                                      5
(a)  AS   = Activated Sludge System
     0 AS = Pure Oxygen Activated Sludge System
     DTAS = Deep Tank Activated Sludge System
     ASB  = Aerated Stabilization Basin
                                     510

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                                  TABLE VIII-63
                       MAXIMUM DAY CHLOROFORM VARIABILITY  , .
                   FACTORS COMPUTED USING UNCORRECTED DATA('aJ
Mill
Number
030013
140021
Number of Maximum Day Long -Term Does Mill Meet
Observations Variability Factor Mean (|Jg/l) BPT Limits?
69
69
Mean Variability Factor
3.97
1.91
2.94
58 No
32 Yes

(a)Data not adjusted based on BPT flow.
                                        511

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industry.  Existing biological treatment systems could be modified  to
achieve  ammonia removal through nitrification.   A review of available
literature indicates ammonia removal on the order of 90 percent may be
achieved through the application  of  a  biological  treatment  system
designed  to convert ammonia to nitrate.(100)(117)(121)(122)(123)(124 )
Table VIII-64 presents predicted  final  average  effluent  levels  of
ammonia  based  on  nitrification  technology  for  the semi-chemical,
dissolving sulfite pulp, and both papergrade sulfite subcategories.

Color

As discussed in Section VI, colored effluents may  be  of  concern  as
dictated  by  water  quality considerations.  Color removal technology
options have been identified and are discussed below.

In Section VII, four technologies were discussed that are  capable  of
removing color from pulp, paper, and paperboard effluents.  These were
as follows:

     1.   Minimum lime coagulation,
     2.   Alum coagulation,
     3.   Activated carbon adsorption, and
     4.   Polymeric resin ion exchange.

These  four  technologies  were  evaluated  based  on  the   following
criteria:

     1.   Stage of color reduction technology development,
     2.   Operating problems experienced,
     3.   Total operating cost,
     4.   Wastewater streams treated, and
     5.   Color reduction efficiency.

Based on these five criteria, minimum lime and alum  coagulation  were
identified as the most likely technology options to be used to control
color  in pulp, paper, and paperboard industry wastewaters.  Available
color  data  are  presented  in  Tables  V-32  and  V-36.   For  those
subcategories  where  highly-colored  effluents  are  discharged,  the
ranges of color levels remaining after the application  of  bi6logical
treatment are presented  in Table VII1-65.

Anticipated final effluent color levels resulting from the application
of  lime  or  alum  coagulation  are also shown in Table VIII-65.  For
alum, EPA assumed that the entire effluent would be treated.  Based on
the studies discussed in Section VII, the Agency determined that an 85
percent reduction in color can be attained through the application  of
alum coagulation.

EPA assumed that only the more highly-colored process streams, such as
the    first  stage  caustic  extraction  effluent  and/or  the  decker
filtrate, would be treated with lime  in the dissolving  kraft,  market
bleached  kraft,  BCT (paperboard, coarse, and tissue) bleached kraft,
fine   bleached  kraft,   soda,  dissolving  sulfite  pulp,   and   both
                                 512

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                         TABLE VIII-64

   PREDICTED RANGE OF AMMONIA FINAL EFFLUENT CONCENTRATIONS
                                          Final Effluent(a)
                         BPT RWL Flow          Ammonia
Subcategory	kgal/t	Ib/t	mg/1
Semi-Chemical               10.3           0.7-3.4   8-39
Dissolving Sulfite Pulp     66.0           1.3-6.3   2-11
Papergrade Sulfite          44.5           1.0-5.0   3-14
(a) As nitrogen.
                                 513

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                                                                                           TABU VIII -65
                                                                                SUMMARY OF ANTICIPATED COLOR LEVELS
                                                                                AFTER MINIMUM LIHK/ALUM COAGULATION
cn
                                                       Range of Color Levels
                                                      (Platiniisi Cobalt Unita}
                                                                Range  of  Color  Levels
                                                                Treated by  Line/Aim
                                                                (Platinuai  CobaIt Unita)
Subcategory	

Dissolving Kraft
  v/Lime Coagulation
  v/Aluai Coagulation

Market Bleached Kraft
  v/Lime Coagulation
  w/Aluai Coagulation

BCT Bleached Kraft
  v/Lime Coagulation
  w/Aluai Coagulation

Alkaline-Fine1
  v/Lime Coagulation
  w/Aliiot Coagulation

Unbleached Kraft
  o Linerboard
  w/Liste Coagulation
  w/Aluai Coagulation

  o Bag
  v/Lime Coagulation
  w/Aluai Coagulation

Sf»i-Che«ical
  v/Lime Coagulation
  w/Alim Coagulation

Unbleached Kraft aud Semi-Chemical
  w/Li«c Coagulation
  w/Alum Coagulation

Dissolving Sulfite Pulp
  v/Lime Coagulation
  w/Aluuj Coagulation

Papergr.ide Sulfite2
  w/Liwt' Coagulation
  w/Alum Coagulation
                    'includes Finer  Bleachrd  Kraft  and  Soda  subcategories.

                    2 Includes I'apcrgrade  Sulfite  (Blow Pit  Wash)  and  Papergrade  Sulfite  (Drum Wash) snbcategories.
 Color Level Reduction
(Platinuai Cobalt Unita)
935-1710
935-1710
1040-2360
1040-2360
1 160-2040
1160-2040
430-1480
430-1480
190-240
190-240
350-2400
350-2400
2350-6400
2350-6400
Iheuical
170-390
170-390
850-3600
850-3600
<5-3150
<5-3150
655-1197
935-1710
782-1652
1040-2360
812-1428
1160-2040
301-1036
430-1480
190-240
190-240
350-2400
2350-2400
2350-6400
2350-6400
170-390
170-390
595-2520
850-3600
<5-2205
<5-3150
524-958
795-1454
582-1322
884-2006
650-1142
986-1734
241-829
366-1258
152-192
162-204
280-1920
298-2040
1880-5120
1998-5440
136-312
145-332
476-2016
723-3060
<5-1764
<5-2678
 Range of Anticipated Color
Levels In the Final Effluent
 (PlaUnua Cobalt Units)
                                                                                                                                                      411-752
                                                                                                                                                      140-257
                                                                                                                                                     458-1038
                                                                                                                                                       156-354
                                                                                                                                                      510-898
                                                                                                                                                      174-306
                                                                                                                                                       189-651
                                                                                                                                                       64-222
                                                                                                                                                        38-48
                                                                                                                                                        28-36
                                                                                                                                                       70-480
                                                                                                                                                       52-360
                                                                                                                                                     470-1280
                                                                                                                                                      352-960
                                                                                                                                                        34-78
                                                                                                                                                        25-58
                                                                                                                                                     374-1584
                                                                                                                                                      127-540
                                                                                                                                                      
-------
papergrade  sulfite  subcategories.   The  cost  to  treat  the entire
wastewater  discharge  stream  at  mills  in  these  subcategories  is
substantially  greater using the lime coagulation process than if only
selected streams are treated for color removal.  EPA  determined  that
approximately  70 percent of the total color load can be attributed to
the first stage caustic extraction effluent  and  decker  filtrate  at
mills in these eight subcategories.

In  determining  attainable  final  effluent color levels, EPA assumed
that lime coagulation would be applied to treat the entire effluent at
mills in the unbleached kraft, semi-chemical, and unbleached kraft and
semi-chemical  subcategories.   Based  on  the  studies  discussed  in
Section  VII, EPA determined that an 80 percent reduction in color can
be attained through the application of lime coagulation.  This removal
is reflected in the anticipated final effluent color levels  shown  in
Table VIII-65.

Costs to achieve these color reductions are presented in Appendix A.
                                    515

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                              SECTION IX

     EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION OF THE
       BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
                   EFFLUENT LIMITATIONS GUIDELINES
GENERAL

The best practicable  control  technology  currently  available  (BPT)
generally  is based upon the average of the best existing performance,
in terms of treated effluent discharged, by plants of  various  sizes,
ages,  and  unit  processes  within an industry or subcategory.  Where
existing performance is uniformly inadequate, BPT may  be  transferred
from  a  different  subcategory  or  category.   Limitations  based on
transfer of technology must be supported  by  a  conclusion  that  the
technology  is,  indeed, transferable and a reasonable prediction that
it will be capable of achieving the prescribed  effluent  limits  (see
Tanners' Council of_ America v.  Train, 540 F.2d 1188 (4th Cir. 1976)).
BPT  focuses  on  end-of-pipe treatment technology rather than process
changes or internal controls except where such changes or controls are
common industry practice.

BPT considers the total cost  of  the  application  of  technology  in
relation  to  the  effluent reduction benefits to be achieved from the
technologies.   The  cost/benefit  inquiry  for  BPT  is   a   limited
balancing,  which  does not require the Agency to quantify benefits in
monetary terms (see, e.g., American Iron and Steel Institute  v.  EPA,
526  F.2d  1027  (3rd  Cir. 1975)).  In balancing costs in relation to
effluent reduction benefits, EPA considers the volume  and  nature  of
existing  discharges,  the  volume  and  nature  of  discharges  after
application  of  BPT,  the  general  environmental  effects   of   the
pollutants,  and  the  costs  and  economic  impacts  of  the required
pollution  control  level.   The  Act  does  not  require  or   permit
consideration  of  water  quality  problems attributable to particular
point  sources  or  industries,  or  water  quality  improvements   in
particular water bodies (see Weyerhaeuser Company v. Costle, 5907 F.2d
1101 (D.C. Cir. 1978)).

REGULATED POLLUTANTS

Pollutants regulated under BPT are BOD5_, TSS, and pH.

IDENTIFICATION  OF  THE  BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
AVAILABLE

The best practicable control technology currently  available  for  the
wastepaper-molded  products  subcategory  was identified as biological
treatment.  This is the same technology on which BPT  limitations  are
based  for  all other subcategories of the secondary fibers segment of
the pulp, paper, and paperboard  industry  that  are  subject  to  BPT
regulations issued in 1974 and 1977 (39 FR 18742 and 42 FR 1398).
                                   517

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EPA    also   determined   that   wastewater   discharges   from   the
nonintegrated-lightweight papers,  nonintegrated-filter  and  nonwoven
papers/  and  nonintegrated-paperboard  subcategories  are  similar in
nature to discharges from the nonintegrated-tissue papers subcategory.
For these  subcategories,  the  best  practicable  control  technology
currently  available was identified as primary clarification, which is
the  technology  on  which  BPT  limitations   are   based   for   the
nonintegrated-tissue papers subcategory.

Biological  treatment  was  identified as the best practicable control
technology currently available  for  the  corrugating  medium  furnish
subdivision  of  the  paperboard  from  wastepaper subcategory and the
cotton fiber furnish  subdivision  of  the  nonintegrated-fine  papers
subcategory.   Biological  treatment  is  the  technology on which BPT
limitations are based for all  other  mills  in  the  paperboard  from
wastepaper  and  the  nonintegrated-fine papers subcategories that are
subject to BPT regulations issued in 1974 and 1977 (39 FR 18742 and 42
FR 1398).

BPT EFFLUENT LIMITATIONS

BPT effluent limitations are presented in Table IX-1.

RATIONALE FOR THE SELECTION OF THE TECHNOLOGY BASIS OF BPT

The Clean Water Act requires the establishment of BCT limitations  for
industry   subcategories   from   which  conventional  pollutants  are
discharged.  In order to develop BCT limitations,  a  base  level  BPT
determination  is  desirable  because  the "cost-reasonableness test",
required as part of the BCT determination, rests  on  the  incremental
cost of removal of BOD5. and TSS from BPT to BCT.

As discussed in Section IV, four new subcategories of the pulp, paper,
and   paperboard  industry  have  been  identified:  wastepaper-molded
products, nonintegrated-lightweight papers,  nonintegrated-filter  and
nonwoven  papers,  and  nonintegrated-paperboard.   Additionally, as a
result of comments received on the proposed  rule,  two  subcategories
were  segmented  to  reflect raw waste load differences resulting from
the  types  of  raw  material  furnish  used.   EPA  established   the
corrugating   medium   furnish  subdivision  of  the  paperboard  from
wastepaper subcategory to account for the higher raw waste loads  that
result from the processing of recycled corrugating medium.  The cotton
fiber furnish subdivision of the nonintegrated-fine papers subcategory
was  established  to account for the higher raw waste loadings typical
of nonintegrated mills where significant quantities of  cotton  fibers
(equal  to or greater than four percent of the total product) are used
in the production of fine papers.

To provide uniform national BPT effluent limitations for all  segments
of  the pulp, paper, and paperboard industry and to aid in development
of BCT limitations, the Agency established  BPT  effluent  limitations
for  the wastepaper-molded products, nonintegrated-lightweight papers,
nonintegrated-filter and nonwoven papers, and nonintegrated-paperboard
                                   518

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                                                                                  TAR1.E IX-1
                                                                           Bl'1 EFFLUENT LIMITATIONS
                                                                            CONTINUOUS DISCHARGERS
                                                                           (kf Akg or lhs/1000  Ibs)

                                                                                    Maximum 30-Day Average
                                                   Siibcalegory	   _    _    	   BOD5      TSS

                                                   Secondary Fibers Segment
                                                                                 	Maxiaum Day
                                                                                 BODS       TSS
cn
                                                   Paperhoard From Wastepaper
                                                     o Corrugating Medium Furnish
                                                   Wastepaper-Molded Products

                                                   N?".i-D^p8rated Segment

                                                   Nonintegrated Fine Papers
                                                     o Cotlon Fiber Furnish
                                                   Nonintegrat ed-Lightweight Tapers
                                                     o Lightweight
                                                     o Electrical
                                                   Nonintcgrated-Filter and
                                                     Nonwoven Papers
                                                   Noninteg rated- Paper hoard
                                                            2.8
                                                            2.3
                                                            9.1
4.6
5.8
                                                                     13. 1
5.7
lt.lt
                                                                                 17.4
 9.2
10.8
                                                                                            24.3
13.2
20.9
16.3
3.6
10.6
16.7
13.0
2.8
24.1
38.0
29.6
6.5
21.6
34.2
26.6
5.R
                                                                           BPT EFFLUENT  LIMITATIONS
                                                                           NONCONTINIIOUS DISCHARGERS
                               Suhcalegory
                                                                    Annual Average
                                                              (kg/kkg or lbs/1000 Ibs)
                                                                         "      TSS
Secondary _F^be_rs Segment

Paperboard From Wastepaper
  o Corrugating Medium Furnish
Wrf.vtcpapcr-Molded Products

Non i ii leg ra t ed_Segjneii t

Nunintpgratrd Fine Papers
  o Cotlon Fiber Furnish
Non integrated-Li ghtwei ght Pape rs
  o Lightweight
  o Electrical
Noninlegratcd-Filter and
   Nonwoven Papers
Noninlrgraled-Paperboan)
                                                                      5.1
                                                                                7.2
                                                              Maximum 30-Day Average
                                                              	(mg_/l)	
                                                                BOU5      TSS
                  Maximum  Day
                  _
                  BOD5
                                                                                                                                  TSS
i i sh
1.6 2.1
J . 3 3.2
93
27
153
66
189
51
306
122
                                                                                                •S2
                                                                                                          74
                                                                                                                        99
                                                                                                                                  138
7.4
11.6
9. 1
2.0
6.0
9.5
7.4
1 .6
65
65
65
65
52
52
52
52
118
118
118
118
106
106
106
106

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subcategories.  Additionally, EPA amended the existing BPT limitations
for the paperboard from wastepaper and the  nonintegrated-fine  papers
subcategories.

METHODOLOGY USED FOR DEVELOPMENT OF BPT EFFLUENT LIMITATIONS

Biological  treatment  was  identified as the best practicable control
technology currently  available  for  the  wastepaper-molded  products
subcategory,   the  corrugating  medium  furnish  subdivision  of  the
paperboard from wastepaper subcategory, and the cotton  fiber  furnish
subdivision   of   the  nonintegrated-fine  papers  subcategory.   The
long-term average BPT  BOD£  final  effluent  concentrations  for  the
wastepaper-molded  products  subcategory  and  the  corrugating medium
furnish subdivision of the paperboard from wastepaper subcategory were
developed from the equation presented in Section VIII that relates the
final effluent BODjj concentration to the raw waste BOD5.  concentration
entering a biological treatment system.  This relationship is based on
biological  treatment  system  performance  at  those  mills  used  to
establish BPT effluent limitations for the major portions of the pulp,
paper, and paperboard industry.

The BPT BOD!5 effluent limitation promulgated  for  the  nonintegrated-
fine  papers  subcategory  in  1977  is  much less stringent than BODS^
limitations established for other subcategories with  comparable  BOD!>
raw  waste characteristics.  Therefore, EPA did not base the long-term"
average BPT BOD5^ final effluent concentration  for  the  cotton  fiber
furnish  subdivision  of  the nonintegrated-fine papers subcategory on
the relationship between BODj[ final effluent  concentration  and  BODi>
raw  waste  concentration  discussed  above.   Rather,  the  long-term
average BPT BODI5 final effluent concentration for this new subdivision
was developed by applying the same  percent  reduction  of  BOD5.  that
forms the basis of BPT effluent limitations for all other mills in the
nonintegrated-fine papers subcategory.

As  discussed in Section VIII, a relationship was also developed which
predicts the anticipated final effluent  TSS  concentration  resulting
from  biological treatment of wastewaters discharged from pulp, paper,
and paperboard mills.  This relationship  is  based  on  BPT  effluent
limitations  promulgated  in  1977  for  a  major portion of the pulp,
paper, and paperboard industry.  EPA based the long-term  average  BPT
TSS  final  effluent concentrations for the wastepaper-molded products
subcategory,  the  corrugating  medium  furnish  subdivision  of   the
paperboard  from  wastepaper, and the cotton fiber furnish subdivision
of the nonintegrated-fine papers subcategory on this relationship.

Long-term  average  BODi>  and  TSS  final  effluent  mass  loads  were
calculated  by multiplying attainable final effluent concentrations by
the     effluent     flow     rates     characteristic     of     each
subcategory/subdivision.

In  making  the  decision to base BPT effluent limitations for  the new
subcategory and the two new subdivisions mentioned above on biological
treatment,  the  Agency  determined  that  biological   treatment   is
                                   520

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available  and  is now employed at many mills in the wastepaper-molded
products subcategory, the corrugating medium  furnish  subdivision  of
the  paperboard  from  wastepaper  subcategory,  and  the cotton fiber
furnish subdivision of the nonintegrated-fine papers subcategory.  For
the wastepaper-molded products subcategory and the corrugating  medium
furnish subdivision of the paperboard from wastepaper subcategory, BPT
limitations  are  based  on the ability of biological systems to treat
the same pollutants (BODj[ and TSS) to  levels  representative  of  BPT
effluent   limitations   established   for  other  subcategories  with
comparable BODj[ raw  waste  characteristics.   For  the  cotton  fiber
furnish  subdivision of the nonintegrated-fine papers subcategory, BPT
limitations are based on the ability of biological treatment to remove
the same pollutants (BOD£ and TSS) to the same degree as occurs at all
other mills in the nonintegrated-fine papers subcategory.

When applied  at  mills  in  the  wastepaper-molded  subcategory,  the
corrugating   medium   furnish  subdivision  of  the  paperboard  from
wastepaper subcategory, and the cotton-fiber  furnish  subdivision  of
the  nonintegrated-fine  papers  subcategory,  biological treatment is
capable of attaining the BPT effluent limitations presented  in  Table
IX-1 .

Primary  treatment  was  identified  as  the  best practicable control
technology  currently  available  for  the   nonintegrated-lightweight
papers,  nonintegrated-filter  and nonwoven papers, and nonintegrated-
paperboard subcategories.  The  wastewater  characteristics  of  these
three  nonintegrated  subcategories are similiar in nature to those of
the nonintegrated-tissue papers subcategory.   Long-term  average  BPT
final  effluent  BOD!> and TSS concentrations were transferred from the
nonintegrated-tissue  papers   subcategory   to   the   nonintegrated-
lightweight  papers,  norrintegrated-filter  and  nonwoven  papers, and
nonintegrated-paperboard  subcategories.   Long-term   average   final
effluent   loads  were  calculated  by  multiplying  attainable  final
effluent concentrations by the effluent flow rates  characteristic  of
these subcategories.

The Agency determined that primary treatment is available and could be
employed  at  mills in the three new nonintegrated subcategories.  Raw
waste  characteristics  at  mills  in  the  nonintegrated-filter   and
nonwoven  papers,  nonintegrated-lightweight papers, and nonintegrated-
paperboard subcategories are comparable  to  those  at  mills  in  the
nonintegrated-tissue  papers  subcategory.   The  BPT  limitations are
based on the ability  of  primary  clarification  to  treat  the  same
pollutants (BOD!> and TSS) to the same levels as now occurs at mills in
the nonintegrated-tissue papers subcategory.  When applied at mills in
the   nonintegrated-lightweight   papers,   nonintegrated-filter   and
nonwoven  papers,   and  the  nonintegrated-paperboard   subcategories,
primary treatment is capable of attaining the BPT effluent limitations
presented in IX-1.

BPT   maximum   30-day  and  maximum  day  effluent  limitations  were
determined by multiplying long-term average  effluent  limitations  by
                                   521

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appropriate  variability  factors  developed  in the 1974 and 1977 BPT
rulemaking (see Table IX-2).

COST OF APPLICATION AND EFFLUENT REDUCTION BENEFITS

EPA anticipates that only one of the six subcategories for  which  new
or  revised  BPT  limitations  were  established will incur compliance
costs.  Four mills in the wastepaper-molded products  subcategory  are
expected  to  invest  a  total of $6.01  million and incur total annual
costs of $1.84 million (1978 dollars).

Upon compliance  with  BPT  effluent  limitations  for  the  four  new
subcategories,   the  Agency  estimates  that  conventional  pollutant
removals from industry raw waste discharges will be 3.5 million  kg/yr
(7.7  million  Ibs/yr)  of  BOD5_  and 13.5 million kg/yr (29.8 million
Ibs/yr) of TSS.  These represent removals of 66 percent  BOD5_  and  89
percent TSS from the raw waste levels of these pollutants for the four
new subcategories.

EPA  does  not  anticipate  any additional pollutant removals from the
corrugating  medium  furnish  subdivision  of  the   paperboard   from
wastepaper  subcategory  as  a  result  of  this  rulemaking since the
amended BPT effluent limitations  are  less  stringent  than  the  BPT
effluent  limitations  established  in  1974 for the entire paperboard
from wastepaper subcategory.   BPT limitations were  relaxed  for  this
new  subcategory  subdivision  to  account for an increase in BOD5_ raw
waste loads since the implementation of BPT in 1977.

Existing permits for the two direct discharging mills  in  the  cotton
fiber furnish subdivision of the nonintegrated-fine papers subcategory
are  more  stringent  than the final BPT effluent limitations for this
new subcategory subdivision; therefore, EPA anticipates no  additional
removal  of  conventional  pollutants  as a result of this regulation.
(Compliance with  final  BPT  effluent  limitations  would  mean  that
conventional pollutant removals from raw waste discharges from the two
direct  discharging  mills  in the cotton fiber furnish subdivision of
the nonintegrated-fine  papers  subcategory  would  be  165,200  kg/yr
(363,400  Ibs/yr)  of  BOD5_  and 691,400 kg/yr (1.5 million Ibs/yr) of
TSS.  These represent removals of 53 percent BOD5_ and 77  percent  TSS
from the raw waste levels of these pollutants for this subdivision.)

NON-WATER QUALITY ENVIRONMENTAL IMPACTS

Sections  304(b)  and  306  of  the  Act  require  EPA to consider the
non-water quality  environmental  impacts   (including  air  pollution,
solid   waste   generation,   and   energy  requirements)  of  certain
regulations.  In conformance with these provisions, EPA considered the
effect of this regulation on air pollution,  solid  waste  generation,
and  energy  consumption.   The  BPT  regulation  was  reviewed by EPA
personnel responsible for non-water quality related  programs.   While
it  is  difficult to balance pollution problems against each other and
against energy use, EPA believes this regulation will best serve often
competing national  goals.   The  Administrator  determined  that  the
                                   522

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                                      TABLE IX-2

       VARIABILITY FACTORS USED IN THE DEVELOPMENT OF BPT EFFLUENT LIMITATIONS1
                                   Maximum 30-Day Average          Maximum Day
Subcategory                           BOD5         TSS           BOD5        TSS


Secondary Fibers Segment

Paperboard From Wastepaper
o Corrugating Medium Furnish          1.77        2.18           3.54       4.36

Wastepaper-Molded Products            1.78        1.82           3.42       3.38

Nonintegrated Segment

Nonintegrated-Fine Papers             1.78        1.82           3.42       3.38
o Cotton Fiber Furnish

Nonintegrated-Lightweight Papers      1.79        1.76           3.25       3.60

Nonintegrated-Filter and              1.79        1,76           3.25       3.60
Nonwoven Papers

Nonintegrated-Paperboard              1.79        1.76           3.25       3.60
1 These variability factors were developed in the BPT rulemaking.(46)(48)
  Variability factors for the Nonintegrated-Lightweight Papers, Nonintegrated-
  Filter and Nonwoven Papers, and Nonintegrated-Paperboard subcategories are
  based on the variability factors originally developed for the Nonintegrated-
  Tissue Papers subcategory because BPT is based on primary treatment for each
  of these nonintegrated subcategories.  Variability factors for the Cotton
  Fiber Furnish subdivision of the Nonintegrated-Fine Papers subcategory and
  the Wastepaper-Molded Products subcategory are based on variability factors
  applicable to those Phase II subcategories where BPT was based on biological
  treatment.  Variability factors originally developed for the Paperboard
  From Wastepaper subcategory were applied to the Corrugating Medium Furnish
  subdivision of the Paperboard From Wastepaper subcategory.
                                      523

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non-water  quality  impacts  identified  below  are  justified  by the
benefits associated with compliance with the regulation.

Energy

EPA estimates that attainment of BPT  will  require  the  use  of  the
equivalent  of 604 thousand liters (3800 barrels) per year of residual
fuel oil, an increase of 0.0017 percent  of  current  industry  energy
usage.

Solid Waste

EPA  estimates that attainment of BPT will result in an additional 100
kkg (110 tons) per year of wastewater treatment solids.  This is equal
to 0.0042 percent  of  current  wastewater  solids  generated  in  the
industry.

Air and Noise

Attainment  of  BPT  will  have  no  measurable impact on air or noise
pollution.
                                   52*

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                              SECTION X

     EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION OF THE
          BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
                   EFFLUENT LIMITATIONS GUIDELINES
GENERAL

As a result of the Clean Water Act of 1977, the achievement of BAT has
become  the  principal  national  means  of   controlling   wastewater
discharges   of   toxic   pollutants.    The   factors  considered  in
establishing the best  available  technology  economically  achievable
(BAT)  level  of  control  include  the  costs of applying the control
technology, the age of process equipment and facilities,  the  process
employed, process changes, the engineering aspects of applying various
types  of  control  technologies,  and non-water quality environmental
considerations such as energy consumption, solid waste generation, and
air pollution (Section 304(b)(2)(B)).  In general, the BAT  technology
level  represents,  at  a  minimum,  the  best economically-achievable
performance of  plants  of  shared  characteristics.   Where  existing
performance is uniformly inadequate, BAT technology may be transferred
from  a different subcategory or industrial category.  BAT may include
process changes or internal controls, even when  not  common  industry
practice.

The  statutory  assessment  of  BAT  "considers"  costs,  but does not
require a balancing of costs against effluent reduction benefits  (see
Weyerhaeuser v. Costle, 590 F.2d 1011 (D.C. Cir. 1978)).  In assessing
BAT,  EPA has given substantial weight to the reasonableness of costs.
The Agency has considered the volume and the nature of discharges, the
volume and nature of discharges expected after application of BAT, the
general environmental effects of the pollutants,  and  the  costs  and
economic  impacts  of  the required pollution control levels.  Despite
this expanded consideration of costs, the primary determinant  of  BAT
is   effluent   reduction  capability  using  economically  achievable
technology.

REGULATED POLLUTANTS

Toxic Pollutants

The Agency  decided  to  regulate  three  different  toxic  pollutants
present  in  wastewater  discharges from mills in the pulp, paper, and
paperboard    industry:    zinc,    trichlorophenol     (TCP),     and
pentachlorophenol (PCP).  BAT effluent limitations were established in
all  subcategories  for  TCP  and  PCP.   Zinc  is  regulated  in  the
groundwood-thermo-mechanical,  groundwood-CMN  papers,   and   ground-
wood-fine papers subcategories.
                                625

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IDENTIFICATION   OF   THE   BEST   AVAILABLE  TECHNOLOGY  ECONOMICALLY
ACHIEVABLE

The Agency selected substitution of chemicals as the basis for control
of trichlorophenol and pentachlorophenol.   Fungicides  and  slimicides
containing  trichlorophenol  and  pentachlorophenol can be replaced by
formulations that do not contain these toxic pollutants.

In the groundwood subcategories, the  BAT  limitations  for  zinc  are
identical  to  BPT  limitations  for control of this toxic metal.  The
technology basis for BPT limitations is lime  precipitation;  however,
EPA  found  that  mills  in the groundwood subcategories have complied
with the BPT effluent limitations through the substitution  of  sodium
hydrosulfite, a bleaching chemical, for zinc hydrosulfite.

BAT EFFLUENT LIMITATIONS

BAT effluent limitations are presented in Table X-l.

RATIONALE FOR THE SELECTION OF THE TECHNOLOGY BASIS OF BAT

An  evaluation  of  verification data indicated that pentachlorophenol
and  trichlorophenol  are  not   effectively   removed   through   the
application  of  primary or biological treatment, the technology bases
of BPT effluent  limitations  for  all  subcategories.   EPA  selected
substitution    of    fungicides   and   slimicides   not   containing
trichlorophenol or pentachlorophenol as the basis for BAT  limitations
because  chemical  substitution greatly reduces the discharge of these
toxic  pollutants.   Total  removal  is  not  achieved  because   some
wastepapers  are  contaminated  with low levels of PCP and because low
levels of TCP are formed  when  pulp  is  bleached  with  chlorine  or
chlorine-containing   compounds.    EPA   estimates  that  alternative
chemicals are currently being used at approximately 80 percent of  the
mills  in  the  pulp,  paper,  and paperboard industry, supporting the
Agency's  decision  to   base   effluent   limitations   on   chemical
substitution.  A survey of chemical suppliers shows that no measurable
increase  in  production  costs  can  be expected as a result of using
biocides that do not contain chlorophenolics.

The presence of significant quantities  of  zinc  in  groundwood  mill
effluents at the time of development of BPT limitations was due to the
use of zinc hydrosulfite, a bleaching chemical.  After promulgation of
BPT  effluent limitations guidelines, the discharge of zinc from pulp,
paper, and paperboard mills was substantially reduced to levels  below
treatability  through the substitution of sodium hydrosulfite for zinc
hydrosulfite.  Regulation  of  zinc  at  BPT  levels  was,  therefore,
selected as the basis of BAT effluent limitations.

In  commenting  on  proposed BAT effluent limitations, some commenters
stated   that   tertiary   treatment   (i.e.,   chemically    assisted
clarification  or  CAC)  should  form  the technology basis of the BAT
effluent limitations for the toxic pollutants pentachlorophenol  (PCP),
trichlorophenol (TCP), and zinc.   Chemically  assisted  clarification
                                526

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                                 TABLE X-l

                         BAT EFFLUENT LIMITATIONS
                         (kg/kkg or lbs/1000 Ibs)
                                                Maximum Day
Subcategory
                                          PCP1
          TCP2
                                                          Zinc
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
  o Linerboard
  o Bag
Semi-Chemical
Unbleached Kraft and Semi-Chemical
Dissolving Sulfite Pulp
  o Nitration
  o Viscose
  o Cellophane
  o Acetate
Papergrade Sulfite4
Croundwood-Thermo-Mechani ca1
Groundwood-CMN Papers
Groundwood-Fine Papers

Secondary Fibers Segment
Deink
  o Fine Papers
  o Tissue Papers
  o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
  o Corrugating Medium Furnish
  o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
0.0025   0.016
0.0019   0.012
0.0016   0.010
0.0014   0.0088

0.00058  0.00053
0.00058  0.00053
0.0012   0.000^3
0.00064  0.00059
0.0030
0.0030
0.0030
0.0033
   *
0.00097
0.0011
0.0010
0.019
0.019
0.019
0.021
   *
0.00088
0.00099
0.00092
0.0030   0.0069
0.0030   0.0069
0.0030   0.0010
0.0030   0.0011

0.00087  0.00030
0.00087  0.00030
0.0026   0.00088
0.0017   0.00060
 NA
 .VA
 NA
 NA

 NA
 NA
 NA
 NA

 NA
 .VA
 NA
 NA
  *
0.26
0.30
0.27
           NA
           NA
           VA
           NA

           NA
           NA
           NA
           NA
Nonintegrated Segment
Nonintegrated-Fiae Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Non Integra ted-Paperboard


0.0018
0.0051
0.0028

0.0059
0.0093

0.0072
0.0016


0.00064
0.0018
0.00096

0.0020
0.0032

0 . 0025
0.00054


NA
NA
NA

NA
NA

NA
NA
^Papergrade Sulfite Equations:

  PCP = 0.00058 exp(0.017x)
  TCP = 0.0036 exp(0.017x)
  Where x equals percent sulfite pulp produced on-site in the final product.

'PCP = Pentachlorophenol

2TCP = Trichlorophenol

3Includes Fine Bleached Kraft and Soda subcategories.

4Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite
 (Drum Wash) subcategories.

NA = Not applicable.
                                   527

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                                            TABLE \'-1 (continued)

                                          BAT EFFLUENT LIMITATIONS
                                          NONCONTINUOUS DISCHARGERS
                                            (concentrations rag/1)
                                                                        Maximum Day
Subcategory
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
o Linerboard
o Bag
Semi -Chemical
Unbleached Kraft and Semi-Chemical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite4
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Papers
o Tissue Papers
o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
o Corrugating Medium Furnish
o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Non in teg rated- Paperboard
PCP1

(0.011H55.D/Y
(0.011)(41.6)/Y
(0.011)(35.4)/Y
(0.011)(30.9)/Y

(0.011)(12.6)/Y
(0.011)(12.6)/Y
(0.029)(10.3)/Y
(0.011)(14.0)/Y

(0.011)(66.0)/Y
(0.011)(66.0)/Y
(0.011)(66.0)/Y
(0.011)(72.7)/Y
*
(0.011)(21. 1)/Y
(0.011)(23.8)/Y
(0.011)(21.9)/Y


(0.029)(24.4)/Y
(0.029)(24.4)/Y
(.0.029)124. 4)/Y
(0.029)(25.2)/Y

(0.029)(7.2)/Y
(0.029)(7.2)/Y
(0.029)(21.1)/Y
(0.029)(14.4)/Y


(0.029)(15.2)/Y
(0.029)(42.3)/Y
(0.029)(22.9)/Y

(0.029)(48.7)/Y
(0.029)(76.9)/Y

(0.029)(59.9)/Y
(0.029)(12.9)/Y
TCP2

(0.068)(55.D/Y
(0.068)(41.6)/Y
(0.068)(35.4)/Y
(0.068)(30.9)/Y

(0.010)(12.6)/Y
(0.010)(12.6)/Y
(0.010)(10.3)/Y
(0.010)(14.0)/Y

(0.068)(66.0)/Y
(0.068)(66.0)/Y
(0.068)(66.0)/Y
(0.068)(72.7)/Y
*
(0.010)(21. 1)/Y
(0.010)(23.8)/Y
(0.010)(21.9)/Y


(0.068)(24.4)/Y
(0.068)(24.4)/Y
(0.010)(24.4)/Y
(0.010)(25.2)/Y

(0.010)(7.2)/Y
(0.010)(7.2)/Y
(0.010)(21.1)/Y
(0.010)(14.4)/Y


(0.010)(15.2)/Y
(0.010)(42.3)/Y
(0.010)(22.9)/Y

(0.010)(48.7)/Y
(0.010)(76.9)/Y

(0.010)(59.9)/Y
(0.010)(12.9)/Y
Zinc

NA
NA
NA
NA

NA
NA
NA
NA

NA
NA
NA
NA

(3.0)(21. 1)/Y
(3.0)(23.8)/Y
(3.0)(21.9)/Y


NA
NA
NA
NA

NA
NA
NA
NA


NA
NA
NA

NA
NA

NA
NA
Y = Mill wastewater discharged per ton of product.
NA = Not Applicable.

'•'•"Papergrade Sulfite Equations:
  PCP = ((0.011)(12.67) exp(0.0!7x))/Y
  TCP = l(0.068)(12.67) exp(0. 017x))/Y
  Where x equals percent sulfite pulp produced on-site in the final product.

'PCP = Pentachlorophenol

"TCP = Trichlorophenol

3Includes Fine Bleached Kraft and Soda subcategories .

""Includes Papergrade Sulfite (Blow Pit Wash) ana Papergrade Sulfite
 (Drum Wash) subcategories.
                                                 528

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(CAC)  is  an  end-of-pipe  treatment technology primarily employed to
achieve a further reduction in  suspended  solids  beyond  the  levels
attained  through  the  application of biological or primary treatment
only.  No data were submitted with comments, nor was the Agency  aware
of  any  data,  that  would  allow the EPA to establish a relationship
between removal of suspended solids and removal  of  the  three  toxic
pollutants  (PCP, TCP, and zinc).  Therefore, the Agency was unable to
establish regulations for control of PCP, TCP, and zinc based on  CAC.
Further, based on available data, the Agency determined that PCP,  TCP,
and  zinc can be effectively controlled through chemical substitution.
As discussed later in this  section,  limitations  based  on  chemical
substitution  will  lead  to significant removals of regulated toxics.
Thus, EPA based final regulations controlling PCP, TCP,  and  zinc  on
chemical substitution.

METHODOLOGY USED FOR DEVELOPMENT OF BAT EFFLUENT LIMITATIONS

Zinc

BAT  limitations for zinc are identical to BPT limitations for control
of this toxic metal.  Limitations are based on the maximum anticipated
discharge  concentration  of  zinc  after  the  application  of   lime
precipitation.  As explained previously, the Agency expects that these
limitations   will   be   attained   through  substitution  of  sodium
hydrosulfite for zinc hydrosulfite in bleaching groundwood pulp.

Trichlorophenol

The Agency assessed TCP discharge  characteristics  at  mills  in  the
pulp,  paper,  and  paperboard  industry  taking  into account whether
chlorophenolic-containing biocides  were  used  in  the  manufacturing
process.   EPA  found  that TCP discharges were significantly lower at
those mills where chlorophenolic-containing biocides  were  not  used.
To determine the discharge levels of TCP that result from substitution
of   chlorophenolic-containing   biocides,  the  Agency  assessed  all
available data for mills where chlorophenolic-containing biocides were
not employed.

EPA found that higher levels of TCP were discharged from  mills  where
chlorine-containing compounds were used to bleach pulp than from other
mills.   This is because low levels of TCP are formed in the bleaching
process at mills  where  chlorine-containing  compounds  are  used  to
bleach  pulp.   EPA determined the maximum discharge levels of TCP for
mills where chlorine-containing compounds were used in  the  bleaching
process  and  for  mills  where  no chlorine-containing compounds were
used.   Based  on  all   available   data,   the   maximum   discharge
concentration  of  trichlorophenol  at  direct discharging mills where
chlorophenolic-containing    biocides     are     not     used     and
chlorine-containing  compounds  are used to bleach pulp was determined
to be 68 ug/1.  The maximum discharge concentration of trichlorophenol
at direct discharging mills where  chlorophenolic-containing  biocides
were not used and where chlorine-containing compounds were not used to
bleach pulp was determined to be 10 ug/1.
                               529

-------
Pentachlorophenol

The  Agency  assessed  PCP  discharge  characteristics at mills in the
pulp, paper, and  paperboard  industry  taking  into  account  whether
chlorophenolic-containing  biocides  were  used  in  the manufacturing
process.  EPA found that PCP discharges were  significantly  lower  at
those  mills  where  chlorophenolic-containing biocides were not used.
To determine the discharge levels of PCP that result from substitution
of  chlorophenolic-containing  biocides,  the  Agency   assessed   all
available data for mills where chlorophenolic-containing biocides were
not employed.

EPA  found  that higher levels of PCP were discharged from mills where
wastepapers were processed than from other mills.   This is  caused  by
low level PCP contamination of wastepaper.  EPA determined the maximum
discharge  levels  of PCP for mills where wastepaper was processed and
for mills where wastepaper was not processed.  Based on all  available
data,  the  maximum  discharge  concentration  of pentachlorophenol at
direct discharging mills where chlorophenolic-containing biocides were
not used and where wastepaper was processed was determined  to  be  29
ug/1.   The  maximum  discharge  concentration of pentachlorophenol at
direct discharging mills where chlorophenolic-containing biocides were
not used and where wastepaper was not processed was determined  to  be
11 ug/1.

Mass  limitations  for  each subcategory in kg/kkg (lbs/1000 Ibs) were
calculated as the product of the anticipated maximum day TCP  and  PCP
effuent  concentrations  and  the flows that form the basis of BPT for
each subcategory.

A  more  detailed  discussion  of  the  development  of  BAT  effluent
limitations is presented in Section VIII.

COST OF APPLICATION AND EFFLUENT REDUCTION BENEFITS

Fungicide and Slimicide Substitution

Other  than  costs  associated  with  monitoring  for TCP and PCP, EPA
estimates that there is  no  cost  associated  with  this  technology;
substitute  chemicals  are  available  at comparable costs.  Since the
final BAT regulation does  not  require  monitoring  where  facilities
certify  that  substitute  chemicals are being used to control PCP and
TCP, EPA anticipates that monitoring will rarely be required.

EPA estimates that the total mass of regulated pollutants removed from
industry wastewaters that are discharged directly to navigable  waters
will be about 13,700 kg/yr (30,200 Ib/yr) of trichlorophenol and 9,590
kg/yr (21,100 Ib/yr) of pentachlorophenol.

Zinc Removal

There is no cost or pollutant removal associated with this technology.
BAT limitations are equivalent to existing BPT limitations.
                                530.

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NON-WATER QUALITY ENVIRONMENTAL IMPACTS

Sections  304(b)  and  306 of the Act require EPA to consider the non-
water quality environmental impacts (including  air  pollution,  solid
waste generation, and energy requirements) of certain regulations.  In
conformance with these provisions, the Agency considered the effect of
this  regulation  on air pollution, solid waste generation, and energy
consumption.  EPA anticipates that  attainment  of  these  limitations
will result in no increased energy usage nor will it contribute to air
pollution, noise generation, or solid waste generation.
                                531

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                              SECTION XI

       EFFLUENT REDUCTION ATTAINABLE THROUGH THE APPLICATION OF
            BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
                   EFFLUENT LIMITATIONS GUIDELINES


GENERAL

The  1977  amendments  added  section   301(b)(2)(E)   to   the   Act,
establishing  "best  conventional  pollutant control technology" (BCT)
for discharges of conventional  pollutants  from  existing  industrial
point  sources.   Conventional pollutants are those defined in section
304(a)(4)  (biological  oxygen  demanding  pollutants  (BOD5J,   total
suspended  solids  (TSS),  fecal coliform, and pH), and any"additional
pollutants defined by the Administrator  as  "conventional"   (oil  and
grease; 44 FR 44501, July 30, 1979).

BCT  is  not an additional limitation but replaces BAT for the control
of conventional pollutants.  In addition to other factors specified in
section  304(b)(4)(B),  the  Act  requires  that  BCT  limitations  be
assessed  in light of a two part "cost-reasonableness" test.  American
Paper Institute v. EPA, 660 F.2d 954 (4th Cir. 1981).  The first  test
compares  the  cost  for  private  industry to reduce its conventional
pollutants with the costs to publicly owned  treatment  works  (POTWs)
for   similar   levels  of  reduction  in  their  discharge  of  these
pollutants.   The  second  test  examines  the  cost-effectiveness  of
additional  industrial  treatment  beyond  BPT.   EPA  must  find that
limitations are "reasonable" under both tests before establishing them
as BCT.  In no case may BCT be less stringent than BPT.

EPA published its methodology for carrying out  the  BCT  analysis  on
August 29,  1979  (44 FR 50732).  BPT and BAT limitations, NSPS, PSES,
and PSNS were proposed for the pulp, paper, and paperboard industry on
January 6, 1981 (46 FR 1430).  At that time, BCT effluent  limitations
were  also  proposed.   However, EPA was later ordered by the Court of
Appeals for the Fourth Circuit  to  correct  data  and  methodological
errors  in its BCT cost test and to develop a new BCT methodology (see
American Paper Institute v.  EPA.  660  F.2d  954   (4th  Cir.  1981)).
Revised  BCT  limitations  were recently reproposed along with the new
BCT methodology (see 47 FR 49176, October 29, 1982).

This document does not address BCT limitations.  (For a discussion  of
control  and  treatment  options  known  to be capable of reducing the
discharge of conventional pollutants in pulp,  paper,  and  paperboard
industry  wastewaters,  see  the January 1981 proposal and Development
Document for Proposed Effluent Limitations  Guidelines  and   Standard's
for  the Pulp, Paper, and Paperboard and the Builders' Paper  and Board'
Mills Point Source Categories (U.S. "EPA, December,  1980
                                533

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                             SECTION XII

                   NEW SOURCE PERFORMANCE STANDARDS


GENERAL

The basis for new source performance standards  (NSPS)  under  section
306  of the Act is the best available demonstrated technology.  At new
plants, the opportunity exists to design the best and  most  efficient
production  processes and wastewater treatment facilities.  Therefore,
Congress directed  EPA  to  consider  the  best  demonstrated  process
changes,  in-plant  controls,  and  end-of-pipe treatment technologies
that  reduce  pollution  to  the  maximum  extent  feasible.   It   is
encouraged  that  at  new  sources,  reductions  in  the use of and/or
discharge of both water  and  wastewater  pollutants  be  attained  by
application of in-plant control measures.

REGULATED POLLUTANTS

Conventional Pollutants

Conventional pollutants regulated under NSPS are: BOD!>, TSS, and pH.

Toxic Pollutants

Toxic   pollutants   controlled   under   NSPS,   as   for   BAT,  are
pentachlorophenol (PCP), trichlorophenol (TCP), and zinc.

Nonconvention_al Pollutants

No nonconventional pollutants are regulated under NSPS.

IDENTIFICATION OF THE TECHNOLOGY BASIS OF NSPS

Conventional Pollutant Control

The technology basis for control of conventional pollutants under NSPS
is a combination of commonly employed production process controls  and
end-of-pipe treatment of the type that forms the basis of BPT effluent
limitations (either primary or biological treatment).

Toxic Pollutant Control

The  technology  basis  of  final  NSPS for zinc, trichlorophenol, and
pentachlorophenol  is  substitution  of  chemicals.    Fungicide   and
slimicide      formulations     containing     trichlorophenol     and
pentachlorophenol can  be  replaced  with  formulations  that  do  not
contain these toxic pollutants.  Zinc hydrosulfite, a chemical used to
bleach groundwood pulps, can be replaced with sodium hydrosulfite.
                                  535

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NEW SOURCE PERFORMANCE STANDARDS

New  source  performance  standards  for  conventional  pollutants are
presented in Tables XII-1 and XI1-2.  New source performance standards
for toxic pollutants are presented in Table XII-3.

RATIONALE FOR THE SELECTION OF THE TECHNOLOGY BASIS FOR NSPS

Conventional Pollutant Control Technology

Final NSPS,  like  proposed  NSPS,  are  based  on  commonly  employed
production process controls and end-of-pipe treatment of the type that
forms  the  basis  of  BPT  effluent  limitations  (either  primary or
biological  treatment).   However,  the  Agency   has   modified   the
methodology  used  at proposal to determine the conventional pollutant
final  effluent  loadings  that  result  from  application  of   these
technologies.

In  establishing  final NSPS, EPA considered a broader set of mills in
determining the raw waste flow and BOD!> reductions  that  will  result
from  application  of  in-plant  production process controls.  The raw
waste flows that form the basis of final NSPS have  been  demonstrated
at  mills  in  every  subcategory  of  the pulp, paper, and paperboard
industry.  The BOD!^ raw waste loads that form the basis of final  NSPS
have  been  demonstrated  in  23 of 24 subcategories.  The Agency also
adjusted its method of calculating attainable effluent  concentrations
of  BODI5  and TSS to account for those situations where BODj[ raw waste
concentrations increase after the application of  in-plant  production
process controls.  These modifications resulted in final NSPS that are
less  stringent  than  if  the  proposed methodology were used.  (This
revised methodology is discussed in detail in  Section  VIII  of  this
document.)

The  end-of-pipe  treatment  systems that form the basis of final NSPS
are the same as those commonly employed to comply  with  BPT  effluent
limitations  but are considerably larger, especially in the integrated
segment.   Therefore,  they  are   more   efficient   in   controlling
conventional   pollutants.   (For  example,  the  detention  time  for
activated sludge treatment is 12 rather than 8 hours).   These  larger
systems  are  now  employed  at  mills  in  many subcategories of this
industry.  Although these larger systems are not employed at mills  in
all  subcategories,  the  technology is readily available.  The Agency
determined that  these  systems  can  be  designed,  constructed,  and
operated  at  new sources in every subcategory of the pulp, paper, and
paperboard  industry  and,  in  combination  with  commonly   employed
production process controls, are capable of meeting the final NSPS.

The  combination  of  reduced  raw waste loads  (attainable through the
application of commonly employed in-plant production process controls)
and more efficient end-of-pipe treatment systems  (that can be designed
and  employed  in  this   industry)  form  the  basis  of  NSPS.   This
combination   of   technologies   results  in  conventional  pollutant
limitations that have not been achieved at  existing  mills  in  every
                                   536

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                                  TABLE XII-1

                       NEW SOURCE PERFORMANCE STANDARDS
                            CONVENTIONAL POLLUTANTS
                           (kg/kkg or lbs/1000 Ibs)
Maximum
Subcategory
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
o Linerboard
o Bag
Serai-Chemical
Unbleached Kraft and Semi-Cheraical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite2
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Papers
o Tissue Papers
o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
o Corrugating Medium Furnish
o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard
pH-Within the range 5.0
30-Dav
BODS

8.4
5.5
4.6
3.1

1.8
2.7
1.6
2. 1

14.5
15.5
16.8
21.4
*
2.5
2.5
1.9


3.1
5.2
3.2
2.5

2.1
1.4
1.1
0.94


1.9
4.2
3.4

6.7
11.7

8.3
1.9
to 9.0
Average
TSS

14.3
9.5
7.6
4.8

3.0
4.8
3.0
3.8

21.3
21.3
21.3
21.5
*
4.6
3.8
3.0


4.6
6.8
6.3
5.3

2.3
1.8
2.3
1.4


2.3
4.9
2.6

5.2
9.2

6.6
1.5
at all ti
Maximum Day
BODS

15.6
10.3
8.5
5.7

3.4
5.0
3.0
3.9

26.9
28.7
31.2
39.6
*
4.6
4.6
3.5


5.7
9.6
6.0
4.6

3.9
2.6
2.1
1.7


3.5
7.8
7.0

13.7
24.1

17.1
4.0
—
TSS

27.3
18.2
14.6
9.1

5.8
9.1
5.8
7.3

40.8
40.8
40.8
41.1
*
8.7
7.3
5.8


8.7
13.1
12.0
10.2

4.4
3.5
4.4
2.7


4.4
9.5
6.0

12.0
21.1

15.0
3.5

*Papergrade Sulfite Equations:

  Maximum 30-day average:

      BODS = 2.36 exp(0.017x)
      TSS  = 3.03 exp(0.017x)

  Maximum day:

      BODS = 4.38 exp(0.017x)
      TSS  = 5.81 exp(0.017x)
      Where x equals percent sulfite pulp produced on-site in the final product

'includes Fine Bleached Kraft and Soda subcategories.

zlncludes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite
 (Drum Wash) subcategories.


                                    537

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                                                 TABLE XII-2

                                      NEW SOURCE PERFORMANCE STANDARDS
                                           CONVENTIONAL POLLUTANTS
                                          NONCONTINUOUS DISCHARGERS
Annual Average H*xl«ma 30-Day Average
(ki/kk« or lba/1000 lb«) (•«/!)
Subcateiory
Integrated Segaent
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
o Linerboard
o Bag
Seal-Chemical
Unbleached Kraft and Seai-Cheaical
Dissolving Sulfite Pulp
o Nitration
o Viscoae
o Cellophane
o Acetate
Papergrade Sulfite1
Groundwood-Therao-Mechanica 1
Groundwood-CMH Papera
Groundwood-Fine Paperi
Secondary Fiber* Segaent
Deink
o Fine Paper*
o Tinue Paper*
o Newsprint
Tissue Froe Wtstepaper
Paper-board From Wastepaper
o Corrugating Median Furnish
o Noncorrugating Mediua Furnish
Wastepaper-Molded Producta
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightveight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard
pH-Within
BODS

4.4
2.9
2.4
1.6

0.96
1.4
0.84
1.1

7.6
8.1
8.8
11.2
*
1.3
1.3
1.0


1.6
2.7
1.7
1.3

1.1
0.73
0.60
0.49


0.98
2.2
2.3

4.5
7.9

5.6
1.3
the range 5.
TSS

7.5
5.0
4.0
2.5

1.6
2.5
1.6
2.0

11.2
11.2
11.2
11.3
*
2.4
2.0
1.6


2.4
3.6
3.3
2.8

1.2
0.97
1.2
0.73


1.2
2.6
1.6

3.2
5.6

4.C
0.94
,0 to 9.
BODS

40
36
34
29

47
55
52
45

59
63
68
78
62
44
34
31


46
62
49
36

161
105
48
83


48
33
43

42
42

42
42
.0 at all tiaes
TSS

68
63
57
45

79
98
97
79

87
87
87
79
80
80
54
46


69
84
92
79

171
137
92
122


56
38
33

33
33

33
33

Maxiaua Day
(•I/O
BODS

74
68
63
53

87
101
97
84

109
117
127
145
115
81
63
57


86
116
90
67

298
194
89
154


88
60
88

87
87

87
87

TSS

129
120
109
85

151
188
186
151

166
166
166
151
153
153
104
88


131
162
177
151

328
263
176
234


107
72
76

76
76

76
76

*Papergrade Sulfite (See Equations in Table 1-4).

   BOD5 Long-Tern Average = Maxiaun 30-day average -f 1.91
   TSS Long-Tern Average * Maximun 30-day average * 1.90

'Includes Fine Bleached Kraft and Soda subcategories

Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite  (Drua Wash)  subcategorie*.
                                                  538

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                                TABLE XII-3

                     NEW SOURCE PERFORMANCE STANDARDS
                             TOXIC POLLUTANTS
                         (kg/kkg or lbs/1000 Ibs)
Subcategory
                                          PCP1
        Maximum Day
          TCP2
                                                          Zinc
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
  o Linerboard
  o Bag
Semi-Chemical
Unbleached Kraft and Semi-Chemical
Dissolving Sulfite Pulp
  o Nitration
  o Viscose
  o Cellophane
  o Acetate
Papergrade Sulfite4
Groundvood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers

Secondary Fibers Segment
Deink
  o Fine Papers
  o Tissue Papers
  o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
  o Corrugating Medium Furnish
  o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
0.0025   0.016
0.0019   0.012
0.0016   0.010
0.0014   0.0088

0.00058  0.00053
0.00058  0.00053
0.0012   0.00043
0.00064  0.00059
0.0030
0.0030
0.0030
0.0033
   *
0.00097
0.0011
0.0010
  019
  019
  019
0.021
   *
0.00088
0.00099
0.00092
0.0030
0.0030
0.0030
0.0030
0.00087
0.00087
0.0026
0.0017
0.0069
0.0069
0.0010
0.0011
0.00030
0.00030
0.00088
0.00060
NA
NA
NA
NA

NA
NA
NA
NA

NA
NA
NA
NA
 *
0.17
0.21
0.19
                    NA
                    NA
                    NA
                    NA

                    NA
                    NA
                    NA
                    NA
Noointegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard


0.0018
0 . 005 1
0.0028

0.0059
0.0093

0.0072
0.0016


0.00064
0.0018
0.00096

0.0020
0.0032

0.0025
0.00054


NA
NA
NA

NA
NA

NA
NA
*Papergrade Sulfite Equations:

  PCP = 0.00058 exp(0.017x)
  TCP = 0.0036 exp(0.017x)
  Where x equals percent sulfite pulp produced on-site in the final product.

'PCP = Pentachlorophenol

"TCP = Trichlorophenol

3Includes Fine Bleached Kraft and Soda subcategories.

4Includes Papergrade Suifite (Blow Pit Wash) and Papergrade Sulfite
 (Drum Wash) subcategories.

NA = Not applicable.
                                     539

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                                        TABLE XII-3  (continued)

                                   NEW SOURCE PERFORMANCE  STANDARDS
                                           TOXIC POLLUTANTS
                                       NONCONTINUOUS DISCHARGERS
                                         (concentrations rag/1)
                                                                        Maximum Day
Subcategory
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
o Linerboard
o Bag
Semi-Chemical
Unbleached Kraft and Semi-Chemical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite4
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Papers
o Tissue Papers
o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
o Corrugating Medium Furnish
o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
N'onintegrated-Tissue Papers
Nonintegrated-Lightveight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated- Paperboard
PCP1

(0.012)(50.7)/Y
(0.013)(36.6)/Y
(0.012)(31.7)/Y
(0. 014)(25. 1)/Y

(0. 015X9. 4)/Y
(0. 012)(11. 4)/Y
(0. 041X7. 3)/Y
(0.013)(11.5)/Y

(0.012)(59.0)/Y
(0.012)(59. 0)/Y
(0. 012X59. 0)/Y
(0.012)(65.7)/Y
*
(0.017)(13.8)/Y
(0.016)(16.8)/Y
(0. 016)(15. 4)/Y


(0. 045X15. 9)/Y
(.0. 036X19. S)/Y
(0. 044)(16. 2)/Y
(0. 045)(16. 3)/Y

(0. 065X3. 2)/Y
(0.065)(3.2)/Y
(0.107)(5.7)/Y
(0.155)(2.7)/Y


(0. 047)(9. 4)/Y
(0. 039X31. 1)/Y
(0.035)(19.1)/Y

(0.037)(38.2)/Y
(0.033)(66.8)/Y

(0. 037X47. 5)/Y
(0. 033X11. 2)/Y
TCP2

(0. 074)(50. 7)/Y
(0.077)(36.6)/Y
(0.076)(31.7)/Y
(0. 084X25. 1)/Y

(0. 013X9. 4)/Y
(0.011)(11.4)/Y
(0.014)(7.3)/Y
(0.012)(11.5)/Y

(0. 076X59. 0)/Y
(0.076)(59.0)/Y
(0.076)(59.0)/Y
(0.075)(65.7)/Y
*
(0. 015X13. 8)/Y
(0. 014X16. 8)/Y
(0.014)(15.4)/Y


(0.104)(15.9)/Y
(0.085)(19.5)/Y
-(0. 015X16. 2)/Y
(0.015)(16.3)/Y

(0.023)(3.2)/Y
(0. 023X3. 2)/Y
(0.037)(5.7)/Y
(0. 053X2. 7)/Y


(0.016)(9.4)/Y
(0.014)(31.1)/Y
(0.012)(19.1)/Y

(0.013)(38.2)/Y
(0. 012)(66. 8)/Y

(0.013)(47.5)/Y
(0.012)(11.2)/Y
Zinc

NA
NA
NA
NA

NA
NA
NA
NA

NA
NA
NA
NA

(3.0)(13.8)/Y
(3.0)(16.8)/Y
(3.0)(15.4)/Y


NA
NA
NA
NA

NA
NA
NA
NA


NA
NA
NA

NA
NA

NA
NA
Y = Mill wastewater discharged per ton of product.
NA = Not Applicable

'•'"Papergrade Sulfite Equations:

  PCP = ((0.015X9.12) exp(0.017x))/Y
  TCP = ((0.094X9.12) exp(0.017x))/Y
  Vhere x equals percenc suliite pulp produced  on-site  in the final product.

 •PC? = Poni.icalorophencl

''TCP = TrichLorophenol

•JInciu
-------
subcategory.   This  is  because  the more efficient treatment systems
have not been employed at mills in every subcategory where  raw  waste
loads  have been reduced to the levels on which NSPS are based.  There
is no reason why the NSPS end-of-pipe treatment systems would be  less
efficient   in   controlling  the  conventional  pollutant  raw  waste
concentrations that result from implementation  of  in-plant  controls
than if these controls were not employed.  Therefore, the fact that in
some  subcategories  there  is no mill that currently meets final NSPS
does not mean that the technologies which form the basis of  NSPS  are
not  demonstrated.   In  fact,  final NSPS have been attained at mills
where every major  pulping  and  bleaching  process  (bleached  kraft,
unbleached kraft, groundwood,  semi-chemical, sulfite, deink, and other
secondary   fiber)   and   papermaking   process  are  employed.   The
technologies that form the basis of final NSPS either are now employed
or are available for application in every  subcategory  of  the  pulp,
paper,  and  paperboard  industry  and represent the best demonstrated
control technology for conventional pollutants.

Toxic Pollutant Control Technology

EPA selected substitution of fungicides and slimicides not  containing
trichlorophenol  or  pentachlorophenol  as  the basis for NSPS because
chemical substitution greatly reduces the  discharge  of  these  toxic
pollutants  from  new  sources.  Total removal is not achieved because
some wastepapers are contaminated with low levels of PCP  and  because
low  levels  of  TCP are formed when pulp is bleached with chlorine or
chlorine-containing compounds.  EPA estimates that alternate chemicals
are currently being used at approximately 80 percent of the  mills  in
the  pulp,  paper,  and  paperboard  industry, supporting the Agency's
decision to base effluent limitations  on  chemical  substitution.   A
survey  of chemical manufacturers shows that no measurable increase in
production costs can be expected as a result of using biocides that do
not contain chlorophenolics.

The substitution of  sodium  hydrosulfite  for  zinc  hydrosulfite  to
control  the  discharge  of zinc ensures substantial reductions in the
discharge of zinc at new direct  discharging  groundwood  mills  where
zinc  could  be  used  as  a  bleaching  chemical.  This technology is
readily transferable to new direct discharging mills as EPA found that
substitution of zinc hydrosulfite with sodium  hydrosulfite  has  been
widely  practiced  at  direct  discharging  groundwood mills to attain
existing BPT effluent limitations.

In commenting on proposed NSPS, some commenters stated  that  tertiary
treatment (i.e., chemically assisted clarification or CAC) should form
the    technology   basis   of   NSPS   for   the   toxic   pollutants
pentachlorophenol (PCP), trichlorophenol (TCP), and zinc.   Chemically
assisted  clarification  (CAC)  is an end-of-pipe treatment technology
primarily employed to effect a further reduction in  suspended  solids
than can be attained through application of biological treatment only.
No  data were submitted with comments, nor was the Agency aware of any
data, that would allow the EPA to  establish  a  relationship  between
removal  of suspended solids and removal of the three toxic pollutants
                                  541

-------
(PCP, TCP, and zinc).   Therefore,  the Agency was unable  to  establish
regulations  for control of PCP,  TCP, and zinc based on CAC.  Further,
based on available data, the Agency determined that PCP, TCP, and zinc
can be  effectively  controlled  through  chemical  substitution.   As
discussed  previously,   chemical  substitution will lead to significant
removals of regulated toxics.  Thus, EPA based final NSPS  controlling
PCP, TCP, and zinc on chemical substitution.

METHODOLOGY USED FOR DEVELOPMENT  OF NSPS

Conventional Pollutants

NSPS  long-term average final effluent characteristics were calculated
by multiplying (a) effluent concentrations determined from analysis of
control technology performance data for end-of-pipe treatment  systems
and  (b)  typical  wastewater flow for new sources in each subcategory
after implementation of in-plant  controls.  For most subcategories, as
discussed in Section VIII, the NSPS wastewater flow was based  on  the
average of flows less than the flow basis of BPT effluent limitations.
Long-term average BOD5^ and TSS effluent concentrations were determined
from  actual effluent data for operating mills in the pulp, paper, and
paperboard industry.  The development of final effluent concentrations
for each subcategory is discussed in detail in Section VIII.

EPA calculated"maximum 30-day and daily maximum  mass  limitations  by
multiplying  attainable  long-term  average  final  effluent  loads by
appropriate variability factors as discussed in Section VIII.

Toxic Pollutants

Zinc.  NSPS for zinc were determined as the product of (a) the maximum
discharge  concentration  that  forms  the  basis  of   BPT   effluent
limitations  for control of zinc and (b) the flows that form the basis
of NSPS for each of the three groundwood subcategories.  As  explained
previously,  the  Agency  expects  that this standard will be attained
through substitution of sodium hydrosulfite for zinc  hydrosulfite  in
bleaching groundwood pulp.

Trichlorophenol.  The Agency assessed TCP discharge characteristics at
mills  in the pulp, paper, and paperboard industry taking into account
whether  chlorophenolic-containing   biocides   were   used   in   the
manufacturing   process.    EPA   found   that   TCP  discharges  were
significantly lower at  those  mills  where  chlorophenolic-containing
biocides were not used.  To determine the discharge levels of TCP that
result  from substitution of chlorophenolic-containing biocides at new
sources, the Agency assessed all available  data  for  existing  mills
where chlorophenolic-containing biocides were not employed.

EPA  found  that  higher  levels  of TCP were discharged from existing
mills where chlorine-containing compounds were  used  to  bleach  pulp
than  from  other mills.  This is because low levels of TCP are formed
in the bleaching process at mills where chlorine-containing  compounds
are  used to bleach pulp.  EPA determined the maximum discharge  levels
                                  542

-------
of TCP for existing mills  where  chlorine-containing  compounds  were
used  in  the  bleaching  process  and  for  existing  mills  where no
chlorine-containing compounds were used.  Based on all available data,
the maximum discharge concentration  of  trichlorophenol  at  existing
direct discharging mills where chlorophenolic-containing biocides were
not  used  and  chlorine-containing compounds were used to bleach pulp
was determined to be 68 ug/1.  The maximum discharge concentration  of
trichlorophenol   at   existing   direct   discharging   mills   where
chlorophenolic-containing   biocides   were   not   used   and   where
chlorine-containing  compounds  were  not  used  to  bleach  pulp  was
determined to be 10 ug/1.

Mass limitations applicable to existing direct  discharging  mills  in
each  subcategory  were  calculated  as the product of the anticipated
maximum day TCP effluent concentrations and the flows  that  form  the
basis  of BPT for each subcategory.  As explained in Section VIII, TCP
discharges are directly related to the quantity of pulp bleached  and,
therefore,  should not be affected by water use.  Therefore, discharge
levels (on a mass basis) at new  mills  with  lower  flows  should  be
identical  to  discharge  levels  at  existing  mills.  Thus, NSPS are
identical to BAT effluent limitations for TCP.

Pentachlorophenol.  The Agency assessed PCP discharge  characteristics
at  mills  in  the  pulp,  paper,  and paperboard industry taking into
account whether chlorophenolic-containing biocides were  used  in  the
manufacturing   process.    EPA   found   that   PCP  discharges  were
significantly lower at  those  mills  where  chlorophenolic-containing
biocides were not used.  To determine the discharge levels of PCP that
result  from substitution of chlorophenolic-containing biocides at new
sources, the Agency  assessed  all  available  data  for  mills  where
chlorophenolic-containing biocides- were not employed.

EPA  found  that  higher  levels  of PCP were discharged from existing
mills where wastepapers were processed than from other mills.  This is
caused by low level PCP contamination of wastepaper.   EPA  determined
the   maximum  discharge  levels  of  PCP  for  existing  mills  where
wastepaper was processed and for existing mills where  wastepaper  was
not  processed.   Based  on  all available data, the maximum discharge
concentration of  pentachlorophenol  at  existing  direct  discharging
mills where chlorophenolic-containing biocides were not used and where
wastepaper  was  processed  was determined to be 29 ug/1.  The maximum
discharge  concentration  of  pentachlorophenol  at  existing   direct
discharging  mills  where  chlorophenolic-containing biocides were not
used and where wastepaper was not processed was determined  to  be  11
ug/1.

Mass  limitations  applicable  to existing direct discharging mills in
-each subcategory were calculated as the  product  of  the  anticipated
maximum  day  PCP  effluent concentrations and the flows that form the
basis of BPT for each subcategory.  As explained in Section VIII,  PCP
discharges   are  directly  related  to  the  quantity  of  wastepaper
processed and,  therefore,  should  not  be  affected  by  water  use.
Therefore,  discharge levels (on a mass basis) at new mills with lower
                                   543

-------
flows should be the same as discharge levels at existing mills.  Thus,
NSPS are identical to BAT effluent limitations for PCP.

A more detailed discussion of the development of toxic pollutant  NSPS
is presented in Section VIII.

COST OF APPLICATION AND EFFLUENT REDUCTION BENEFITS

The  cost  of attainment of NSPS varies by subcategory as discussed in
Appendix A.  EPA estimates that compliance with NSPS  will  result  in
incremental  capital  costs of $19.4 million and total annual costs of
$6.9 million (1978 dollars) for the period 1985 to 1990 based  on  the
projected  production  growth  rate.   (27)  Substantial reductions of
BODS., TSS, and zinc are ensured while  discharges  of  trichlorophenol
and  pentachlorophenol  resulting  from  the  use  of biocides will be
virtually eliminated.

NON-WATER QUALITY ENVIRONMENTAL IMPACTS

Non-water  quality  environmental  impacts  were  considered  and  are
discussed  in  Appendix  A.   Energy costs and the cost of disposal of
solid wastes  were  included  in  Agency  estimates  of  the  cost  of
attainment  of new source performance standards.  Energy use and solid
waste generation will vary at new sources depending on mill  size  and
the   subcategory   of   the  pulp,  paper,  and  paperboard  industry
considered.  EPA anticipates that attainment  of  NSPS  will  have  no
measurable impact on air or noise pollution.
                                   544

-------
                             SECTION XIII

             PRETREATMENT STANDARDS FOR EXISTING SOURCES


GENERAL

Section 307(b) of the Act  requires  EPA  to  promulgate  pretreatment
standards  for  existing  sources  (PSES) that must be achieved within
three years  of  promulgation.   PSES  are  designed  to  control  the
discharge  of  pollutants  that  pass  through, interfere with, or are
otherwise incompatible with the operation of POTWs.  The  Clean  Water
Act  of  1977  requires  pretreatment  for  toxic pollutants that pass
through the POTW in  amounts  that  would  violate  direct  discharger
effluent limitations or interfere with the POTWs treatment process or
chosen  sludge  disposal  method.  The legislative history of the 1977
Act indicates that pretreatment standards are to be  technology-based,
analogous  to  the  best  available  technology  for  removal of toxic
pollutants.  EPA has generally determined that there is  pass  through
of  pollutants if the percent of pollutants removed by a well-operated
POTW achieving secondary treatment is less than the percent removed by
the BAT model treatment system.  The general pretreatment regulations,
which  served  as  the  framework  for  the  categorical  pretreatment
regulations  for the pulp, paper, and paperboard industry can be found
at 40  CFR  Part  403  (43  FR  27736,  June 26,  1978;  46  FR  9462,
January 28, 1981).

REGULATED POLLUTANTS

EPA   established   PSES   for   control   of   the  toxic  pollutants
trichlorophenol   (TCP)   and   pentachlorophenol   (PCP)    in    all
subcategories.    PSES   were   also   promulgated  for  zinc  in  the
groundwood-thermo-mechanical, groundwood-CMN papers,  and  groundwood-
fine papers subcategories.  Pentachlorophenol and trichlorophenol have
been  observed  to pass through biological treatment systems.  Control
of the toxic metal zinc  is  necessary  to  minimize  sludge  disposal
problems and pass through of this pollutant.

IDENTIFICATION  OF  THE TECHNOLOGY BASIS OF PRETREATMENT STANDARDS FOR
EXISTING SOURCES

The Agency selected substitution of chemicals as  the  basis  for  the
control   of   trichlorophenol,   pentachlorophenol,  and  zinc  being
discharged to POTWs.  Fungicide and slimicide formulations  containing
trichlorophenol   and   pentachlorophenol   can   be   replaced   with
formulations  that  do  not  contain  these  toxic  pollutants.   Zinc
hydrosulfite,  a  chemical  used  to  bleach  groundwood pulps, can be
replaced with sodium hydrosulfite.

PSES

PSES are presented in Table XIII-1.

-------
                                           TABLE XIII-1

                            PRETREATMENT STANDARDS FOR EXISTING SOURCES
                                       (concentrations mg/1)
                                                                       Maximum Day
Subcategory
                                               PCP1
                         TCP2
                                                                                          Zinc
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
  o Linerboard
  o Bag
Semi-Chemical
Unbleached Kraft and Semi-Chemical
Dissolving Sulfite Pulp
  o Nitration
  o Viscose
  o Cellophane
  o Acetate
Papergrade Sulfite4
Groundvood-The mo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers

Secondary Fibers Segment
Deink
  o Fine Papers
  o Tissue Papers
  o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
  o Corrugating Medium Furnish
  o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
                                         (0.011)(41.6)/Y
                                         (0.011)(35.4)/Y
                                         (0.011)(30.9)/Y
                                                   . 6)/Y
(0.
                                         (0.032X10.3)/Y
                                         (0.011X14.0)/Y

                                         (0.011X66.0)/Y
                                         (0.011)(66.0)/Y
                                         (0.011X66.0)/Y
                                         (0.011)(72.7)/Y
                                         (0.011)(23.8)/Y
                                         (0.032X24.4)/Y
                                         (0.032)(24.4)/Y
                                         (0.032X24.4)/Y
                                         (0.032)(25.2J/Y

                                         (0.032X7.2)/Y
                                         (0.032)(7.2)/Y
                                         (0.032)(21.1)/Y
                                         (0.032X14.4)/Y
(0.082)(55.1)/Y
(0.082)(41.6)/Y
(0.082)(35.4)/Y
(0.082)(30.9)/Y

(0.010X12.6)/Y
(0.010)(12.6)/Y
(0.010)(10.3)/Y
(0.010)(14.0)/Y

(0.082)(66.0)/Y
(0.082X66.0)/Y
(0.082)(66.0)/Y
(0.082)(72.7)/Y
       *
(0.010)(21.1)/Y
(0.010X23.8)/Y
(0.010)(21.9)/Y
                    (0.082)(24.4)/Y
                    (0.082)(24.4)/Y
                    (0.010)(24.4)/Y
                    (0.010H25.2J/Y

                    (0.010)(7.2)/Y
                    (0.010)(7.2)/Y
                    (0.010)(21.1)/Y
                    (0.010)(14.4)/Y
NA
NA
NA
NA

NA
NA
NA
NA

NA
NA
NA
NA
                                            (3.0)(23.8)/Y
                                            (3.0)(21.9)/Y
                              NA
                              NA
                              NA
                              NA

                              NA
                              NA
                              NA
                              NA
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightveight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated- Paperboard


(0. 032X15. 2)/Y
(0. 032)(42. 3)/Y
(0. 032)(22. 9)/Y

(0. 032)(48. 7)/Y
(0. 032X76. 9)/Y

(0. 032)(59. 9)/Y
(0.032)(12.9)/Y


(0.010)(15.2)/Y
(0. 010)(42. 3)/Y
(0.010)(22.9)/Y

(0.010)(48.7)/Y
(0.010)(76.9)/Y

(0.010)(59.9)/Y
(0. 010)(12. 9)/Y


NA
NA
NA

NA
NA

NA
NA
Y = Mill wastewater discharged per ton of product.
NA = Not Applicable

^Papergrade Sulfite Equations:

  PCP = ((0.011X12.67) exp(0.017x))/Y
  TCP = ((0.082X12.67) exp(0.017x))/Y
  Where x equals percent sulfite pulp produced on-site  in the final product.

'PCP = Pentachlorophenol

''TCP - Trichlorophenol

^Includes Fine Bleached Kraft and Soda subcategories.

•"Includes Papergrade Sulfite  (Blow Pit Wash) and  Papergrade Suifite
  (Drum Wash) subcategories.
                                                  546

-------
                                TABLE XIII-1 (continued)

                                PSES OPTIONAL MASS LIMITS
                                 (kg/kkg or lb/1000 Ibs)
Subcategory
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
o Linerboard
o Bag
Semi-Chemical
Unbleached Kraft and Semi-Chemical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite4
Groundwood-The rue-Mechanical
Groundvood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Papers
o Tissue Papers
o Newsprint
Tissue Frosi Wastepaper
Paperboard From Wastepaper
o Corrugating Medium Furnish
o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
Konintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Konintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard

PCP1

0.0025
0.0019
0.0016
0.0014

0.00058
0.00058
0.0014
0.00064

0.0030
0.0030
0.0030
0.0033
*
0.00097
0.0011
0.0010


0.0033
0.0033
0.0033
0.0034

0.00096
0.00096
0.0028
0.0019


0 . 0020
0.0056
0.0031

0.0065
0.010

0.0080
0.0017
Maximum Day
TCP2

0.019
0.014
0.012
0.011

0.00053
0.00053
0 . 00043
0.00059

0.023
0.023
0.023
0.025
*
0.00088
0.00099
0.00092


0.0084
0.0084
0.0010
0.0011

0.00030
0.00030
0.00088
0.00060


0.00064
0.0018
0.00096

0.0020
0.0032

0.0025
0.00054

Zinc

NA
NA
NA
NA

NA
NA
NA
NA

NA
NA
NA
NA
NA
0.26
0.30
0.27


NA
NA
VA
NA

NA
NA
NA
NA


NA
NA
NA

NA
NA

NA
NA
Y = Mill wastewater discharged per ton of product.
NA = Not Applicable

*Papergrade Sulfite Equations:

  PCP = 0.00058 exp(0.017x)
  TCP = 0.0043 exp(0.017x)
  Where x equals percent sulfite pulp produced on-site in the final product.

'PCP = Pentachlorophenol

2TCP = Trichlorophenol

3lncludes Fine Bleached Kraft and Soda subcategories.

^Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite
 (Drum Wash) subcategories.
                                                    547

-------
RATIONALE FOR THE SELECTION OF_ THE TECHNOLOGY BASIS OF PSES

EPA selected substitution of fungicides and slimicides not  containing
trichlorophenol (TCP) or pentachlorophenol (PCP) as the basis for PSES
because  chemical  substitution greatly reduces the discharge of these
toxic pollutants to POTWs.  Total removal is not achieved because some
wastepapers are contaminated with low levels of PCP  and  because  low
levels  of  TCP  are  formed  when  pulp  is bleached with chlorine or
chlorine-containing  compounds.   EPA   estimates   that   alternative
chemicals  are currently being used at approximately 80 percent of the
mills in the pulp,  paper,  and  paperboard  industry,  supporting  the
Agency's   decision   to   base   effluent   limitations  on  chemical
substitution.  A  survey  of  chemical  manufacturers  shows  that  no
measurable increase in production costs can be expected as a result of
using biocides that do not contain chlorophenolics.

The  substitution  of  sodium  hydrosulfite  for  zinc hydrosulfite to
control the discharge of zinc ensures substantial  reductions  in  the
discharge  of zinc at indirect discharging groundwood mills where zinc
is  used  as  a  bleaching  chemical.   This  technology  is   readily
transferable   to   indirect  discharging  mills  as  EPA  found  that
substitution of zinc hydrosulfite with sodium  hydrosulfite  has  been
widely  practiced  at  direct  discharging  groundwood mills to attain
existing  BPT  effluent  limitations.   EPA   also   determined   that
substitution  to  the  use  of sodium hydrosulfite will not affect the
viability of indirect discharging groundwood mills.

In commenting on the proposed regulations, some commenter> stated that
tertiary treatment (i.e., chemically assisted  clarification  or  CAC)
should  form the technology basis of the PSES for the toxic pollutants
pentachlorophenol (PCP), trichlorophenol (TCP), and zinc.   Chemically
assisted  clarification  (CAC)  is an end-of-pipe treatment technology
primarily employed to effect a further reduction in  suspended  solids
than can be attained through application of biological treatment only.
No  data were submitted with comments, nor was the Agency aware of any
data, that would allow the EPA to  establish  a  relationship  between
removal  of suspended solids and removal of the three toxic pollutants
(PCP, TCP, and zinc).  Therefore, the Agency was unable  to  establish
regulations  for control of PCP, TCP, and zinc based on CAC.  Further,
based on available data, the Agency determined that PCP, TCP, and zinc
can be  effectively  controlled  through  chemical  substitution.   As
discussed  later  in this section, PSES based on chemical substitution
will lead to significant removals  of  regulated  toxics.   Thus,  EPA
based   final   PSES  controlling  PCP,  TCP,  and  zinc  on  chemical
substitution.

METHODOLOGY USED FOR DEVELOPMENT OF PSES

PSES for the control of pentachlorophenol, trichlorophenol,  and  zinc
were  developed  using the same general methodology as for development
of BAT effluent limitations for control of these toxic pollutants.

-------
Zinc

PSES for zinc are identical to BPT limitations  for  control  of  this
toxic metal.   Standards are based on the maximum anticipated discharge
concentration of zinc after the application of lime precipitation.  As
explained  previously,  the  Agency expects that this standard will be
attained  through  substitution  of  sodium  hydrosulfite   for   zinc
hydrosulfite in bleaching groundwood pulp.

Trichlorophenol

The  Agency  assessed  TCP  discharge  characteristics at mills in the
pulp, paper,  and  paperboard  industry  taking  into  account  whether
chlorophenolic-containing  biocides  were  used  in  the manufacturing
process.  EPA found that TCP discharges were  significantly  lower  at
those  mills  where  chlorophenolic-containing biocides were not used.
To determine the discharge levels of TCP that result from substitution
of  chlorophenolic-containing  biocides,  the  Agency   assessed   all
available data for mills where chlorophenolic-containing biocides were
not employed.

EPA  found  that higher levels of TCP were discharged from mills where
chlorine-containing compounds were used to bleach pulp than from other
mills.  This is because low levels of TCP are formed in the  bleaching
process  at  mills  where  chlorine-containing  compounds  are used to
bleach pulp.   EPA determined the maximum discharge levels of  TCP  for
mills  where  chlorine-containing compounds were used in the bleaching
process and for mills  where  no  chlorine-containing  compounds  were
used.    Based   on   all   available   data,  the  maximum  discharge
concentration of trichlorophenol at indirect discharging  mills  where
chlorophenolic-containing   biocides   were  not  used  and  chlorine-
containing compounds were used to bleach pulp was determined to be  82
ug/1.   The  maximum  discharge  concentration  of  trichlorophenol at
indirect discharging mills  where  chlorophenolic-containing  biocides
were not used and where chlorine-containing compounds were not used to
bleach pulp was determined to be 10 ug/1.

Pentachlorophenol

The  Agency  assessed  PCP  discharge  characteristics at mills in the
pulp, paper,  and  paperboard  industry  taking  into  account  whether
chlorophenolic-containing  biocides  were  used  in  the manufacturing
process.  EPA found that PCP discharges were  significantly  lower  at
those  mills  where  chlorophenolic-containing biocides were not used.
To determine the discharge levels of PCP that result from substitution
of  chlorophenolic-containing  biocides,  the  Agency   assessed   all
available data for mills where chlorophenolic-containing biocides were
not employed.

EPA  found  that higher levels of PCP were discharged from mills where
wastepapers were processed than from other mills.  This is  caused  by
low level PCP contamination of wastepaper.   EPA determined the maximum
discharge  levels  of PCP for mills where wastepaper was processed and

-------
for mills where wastepaper was not processed.  Based on all  available
data,  the  maximum  discharge  concentration  of pentachlorophenol at
indirect discharging mills  where  chlorophenolic-containing  biocides
were  not used and where wastepaper was processed was determined to be
32.0 ug/1.  The maximum discharge concentration  of  pentachlorophenol
at indirect discharging mills where chlorophenolic-containing biocides
were not used and where wastepaper was not processed was determined to
be 11 ug/1.

PSES   are   expressed   as  allowable  maximum  daily  concentrations
(milligrams  per  liter).   Final  pretreatment  standards  include  a
mathematical formula that accounts for flow differences to assure that
the   standards   do   not  discourage  the  implementation  of  water
conservation  technologies  at  indirect  discharging   mills.    Mass
limitations (kg/kkg or lb/1000 Ib of product) are provided as guidance
in  cases where it is necessary to impose mass limitations for control
of pollutants discharged from contributing pulp,  paper, and paperboard
mills to POTWs.  Mass limitations were calculated as  the  product  of
the  maximum  allowable  concentrations  and the flows that formed the
basis of BPT  limitations  for  each  subcategory.   A  more  detailed
discussion  of  the  development  of  PSES limitations is presented in
Section VIII.

COST OF APPLICATION AND EFFLUENT REDUCTION BENEFITS

Fungicide and Slimicide Substitution

Other than costs associated with  monitoring  for  TCP  and  PCP,  EPA
estimates  that  there  is  no  cost  associated with this technology;
substitute chemicals are available at comparable costs.  Since PSES do
not  require  monitoring  where  facilities  certify  that  substitute
chemicals  are being used to control PCP and TCP, EPA anticipates that
monitoring will rarely be required.

EPA estimates that the total mass of regulated pollutants removed from
discharges to POTWs will be 3390 kg/yr (7460 Ib/yr) of trichlorophenol
and 2050 kg/yr (4510 Ib/yr) of pentachlorophenol.

Zinc Hydrosulfite Substitution

EPA estimates that the cost (1978 dollars) of implementation  of  this
technology  will  be  $23,300 per year.  Only one indirect discharging
groundwood mill was identified where zinc  hydrosulfite  was  used  to
bleach  pulp.    EPA estimates that the total mass of zinc removed from
discharges to POTWs from groundwood subcategory  wastewaters  will  be
20,000 kg/yr (44,000 Ib/yr).

NON-WATER QUALITY ENVIRONMENTAL IMPACTS

Sections  304(b)  and  306  of  the  Act  require  EPA to consider the
non-water quality  environmental  impacts  (including  air  pollution,
solid   waste   generation,   and   energy  requirements)  of  certain
regulations.   In  conformance  with  these  provisions,  the   Agency
                                550

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considered the effect of this regulation on air pollution, solid waste
generation,   and  energy consumption.  EPA anticipates that compliance
with PSES will result in no increase in energy usage  nor  will  these
regulations  result in any increase in air pollution, noise pollution,
or solid waste generation.

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                             SECTION XIV

                PRETREATMENT STANDARDS FOR NEW SOURCES


GENERAL

Section 307(c) of  the  Clean  Water  Act  of  1977  requires  EPA  to
promulgate  pretreatment  standards for new sources (PSNS) at the same
time that it promulgates NSPS.  New  indirect  dischargers,  like  new
direct  dischargers,  have  the  opportunity  to  incorporate the best
available  demonstrated  technologies   including   process   changes,
in-plant  control measures, and end-of-pipe treatment and to use plant
site selection  to  ensure  adequate  treatment  system  installation.
Pretreatment  standards  for  new  sources  (PSNS),  like PSES, are to
control the discharge of pollutants that pass through, interfere with,
or are otherwise incompatible with the operation of POTWs.  The Agency
considers the same factors in promulgating PSNS  as  it  considers  in
promulgating PSES.

REGULATED POLLUTANTS

EPA   established   PSNS   for   control   of   the  toxic  pollutants
trichlorophenol   (TCP)   and   pentachlorophenol   (PCP)    in    all
subcategories.    PSNS   were   also   promulgated  for  zinc  in  the
groundwood-thermo-mechanical, groundwood-CMN papers,  and  groundwood-
fine papers subcategories.  Pentachlorophenol and trichlorophenol have
been  observed  to pass through biological treatment systems.  Control
of the toxic metal zinc minimizes sludge disposal  problems  and  pass
through of this pollutant.

IDENTIFICATION  OF  THE TECHNOLOGY BASIS OF PRETREATMENT STANDARDS FOR
NEW SOURCES

As for PSES,  the Agency selected  substitution  of  chemicals  as  the
basis  for the control of trichlorophenol, pentachlorophenol, and zinc
being discharged  to  POTWs.   Fungicide  and  slimicide  formulations
containing  trichlorophenol and pentachlorophenol can be replaced with
formulations  that  do  not  contain  these  toxic  pollutants.   Zinc
hydrosulfite,  a  chemical  used  to  bleach  groundwood pulps, can be
replaced with sodium hydrosulfite.

PSNS

PSNS effluent limitations are presented in Table XIV-1.

RATIONALE FOR THE SELECTION OF THE TECHNOLOGY BASIS OF PSNS

EPA selected substitution of fungicides and slimicides not  containing
trichlorophenol  or  pentachlorophenol  as  the basis for PSNS because
chemical substitution greatly reduces the  discharge  of  these  toxic
pollutants  to  POTWs from new sources.  Total removal is not achieved
because some wastepapers are contaminated with low levels of  PCP  and
                               553

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                                       TABLE XIV-1

                         PRETREATMENT STANDARDS FOR NEW SOURCES
                                  (concentrations mg/1)
                                                                       Maximum Dav
Subcategory
                                               PCP1
                                                                  TCP2
                                                                                          Zinc
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Unbleached Kraft
  o Linerboard
  o Bag
Semi-Chemical
Unbleached Kraft and Semi-Chemical
Dissolving Sulfite Pulp
  o Nitration
  o Viscose
  o Cellophane
  o Acetate
Papergrade Sulfite4
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers

Secondary Fibers Segment
Deink
  o Fine Papers
  o Tissue Papers
  o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
  o Corrugating Medium Furnish
  o Noncorrugating Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt

Nonintegrated Segment
Nonintegrated-Fine Papers
  o Wood Fiber Furnish
  o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightweight Papers
  o Lightweight
  o Electrical
Nonintegrated-Filter
  and Nonwoven Papers
Nonintegrated-Paperboard
                                         (0.012)(50.7)/Y
                                         (0.013X36.6)/Y
                                         (0.012X31.7)/Y
                                         (0.014)(25.1)/Y

                                         (0.015X9.4)/Y
                                         (0.012X11.4)/Y
                                         (0.045X7.3)/Y
                                         (0.013X11.5)/Y

                                         (0.012X59.0)/Y
                                         (0.012)(59.0)/Y
                                         (0.012)(59.0)/Y
                                         (0.012X65.7)/Y
                                                *
                                         (0.017)(13.8)/Y
                                         (0.016X16.8)/Y
                                         (0.016)(15.4)/Y
                                         (0.049)(15.9)/Y
                                         (0.040)(19.5)/Y
                                         (0.048X16.21/Y
                                         (0.049)(16.3)/Y

                                         (0.072)(3.2)/Y
                                         (0.072X3.2)/Y
                                         (0.118)(5.7)/Y
                                         (0.171)(2.7)/Y
(0.052)(9.4)/Y
(0.044)(31.1)/Y
(0.038)(19.I)/Y

(0.041)(38.2)/Y
(0.037)(66.8)/Y

(0.040)(47.5)/Y
(0.037)(11.2)/Y
                    (0.089X50.7)/Y
                    (0.093)(36.6)/Y
                    (0.092)(31.7)/Y
                    (0.013)(9.4)/Y
                    (0.011)(11.4)/'
                    (0.014)(7.3)/Y
                    (0.092)(59.0)/Y
                    (0.092)(59.0)/Y
                    (0.092)(59.0)/Y
                    (0.091)(65.7)/Y
                           *
                    (0.015X13.8)/Y
                    (0.014)(16.8)/Y
                    (0.014)(15.4)/r
                    (0.126)(15.9)/Y
                    (0.103X19.5)/Y
                    (0.015)(If.2)/Y
                    (0.015)(16.3)/Y

                    (0.023)(3.2)/Y
                    (0.023)(3.2)/Y
                    (0.037)(5.7)/Y
                    (0.053)(2.7)/Y
                                                             (0.016)(9.4)/Y
                                                             (0.013)(38.2)/Y
                                                             (0.012)(66.8)/Y

                                                             (0.013X47.5)/Y
      N'A
      NA
      NA
      NA

      NA
      NA
      NA
      NA

      NA
      NA
      NA
      NA

(3.0)(13.8)/Y
(3.0)(16.8)/Y
(3.0)(15.4)/Y
      NA
      NA

      NA

      NA
      NA
      NA
      NA
      NA
      NA
                                                                                           NA
      NA
      NA
Y = Mill wastewater discharged per ton of product.
NA = Not Applicable

••''Papergrade Sulfite Equations:

  PCP = ((0.015X9.12) exp(0.017x))/Y
  TCP = ((0.114X9.12) exp(0.017x))/Y
  Where x equals percent sulfite pulp produced on-site in the final product.

1PCP = Pentachlorophenol

''TCP = Trichlorophenol

3Includes Fine Bleached Kraft and Soda subcategories.

4Includes Papergrade Sulfite  (Blow Pit Wash) and Papergrade Sulfite
 (Drum Wash) subcategories.
                                                  554

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                                 TABLE XIV-1 (continued)

                                PSNS OPTIONAL MASS LIMITS
                                 (kg/kkg or lb/1000 Ibs)
Subcategory
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine3
Uobleached Kraft
o Linerboard
0 Bag
Semi-Chemical
Unbleached Kraft and Seoi-Cbesical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite4
Grouadwood-Therno-Mechanical
Groundwood-CMH Papers
Groiuidwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Papers
o Tissue Papers
o Newsprint
Tissue From wastepaper
Paperboard From Wastepaper
o Corrugating Median Furnish
o Noncorrugatiog Medina Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonintegr«ted-FiB* Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Sonintegrated-Tlisue Papers
Nonintegrated-Lightweight Papers
o Lightweight
o Hlectrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard

PCP*

0.0025
0.0019
0.0016
0.0014

0.00058
0.00058
0.0014
0.00064

0.0030
0.0030
0.0030
0.0033
*
0.00097
0.0011
0.0010


0.0033
0.0033
0.0033
O.U034

0 . 00096
0.00096
0.0028
0.0019


0.0020
0.0056
0.0031

0.0065
0.010

0.0080
0.0017
Maximum Day
TCP2

0.019
0.014
0.012
0.011

0.00053
0.00053
0.00043
0.00059

0.023
0.023
0.023
0.025
*
0.00088
0.00099
0.00092


0.0084
0.0084
0.0010
o.aoit

0 . 00030
0.00030
0 . 00088
0.00060


0.00064
0.0018
0,00096

0.0020
0.0032

0 . 0025
0.00054

Zinc

NA
NA
NA
NA

KA
HA
NA
NA

NA
NA
NA
NA
HA
0.17
0.21
0.19


NA
NA
NA
NA

NA
NA
NA
NA


NA
HA
NA

NA
NA

NA
NA
Y = Hill waatewater discharged per ton of product.
NA * Not Applicable

*P«pergrade Sulfite Equations:

  PCP = 0,00058 exp(0.017x)
  TCP = 0.0043 exp(0.017x)
  Where x equals percent sulfite pulp produced on-aite in the final product.

'PCP * Pentachlorophenol

2TCP = Trichlorophenol

3!ncludes Fine Bleached Kraft and Soda subcategories.

•"includes Papergrade Sulfite (Blow Pit tfash) and Papergrade Sulfite
 (Drum Wash) subcategories.
                                                555

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because  low  levels  of  TCP  are  formed  when pulp is bleached with
chlorine  or  chlorine-containing  compounds.    EPA   estimates   that
alternate  chemicals  are  currently  being  used  at approximately 80
percent of the mills in the  pulp,   paper,  and  paperboard  industry,
supporting  the  Agency's  decision  to  base  effluent limitations on
chemical substitution.   A survey of chemical manufacturers shows  that
no measurable increase in production costs can be expected as a result
of using biocides that do not contain chlorophenolics.

The  substitution  of  sodium  hydrosulfite  for  zinc hydrosulfite to
control the discharge of zinc ensures substantial  reductions  in  the
discharge  of  zinc at new indirect discharging groundwood mills where
zinc could be used  as  a  bleaching  chemical.   This  technology  is
readily  transferable  to  new indirect discharging mills as EPA found
that substitution of zinc hydrosulfite with  sodium  hydrosulfite  has
been widely practiced at direct discharging groundwood mills to attain
existing BPT effluent limitations.

In  commenting  on proposed PSNS, some commenters stated that tertiary
treatment (i.e., chemically assisted clarification or CAC) should form
the   technology   basis   of   PSNS   for   the   toxic    pollutants
pentachlorophenol  (PCP), trichlorophenol (TCP), and zinc.  Chemically
assisted clarification (CAC) is an  end-of-pipe  treatment  technology
primarily  employed  to effect a further reduction in suspended solids
than can be attained through application of biological treatment only.
No data were submitted with comments, nor was the Agency aware of  any
data,  that  would  allow  the EPA to establish a relationship between
removal of suspended solids and removal of the three toxic  pollutants
(PCP,  TCP,   and zinc).  Therefore, the Agency was unable to establish
regulations for control of PCP, TCP, and zinc based on CAC.   Further,
based on available data, the Agency determined that PCP, TCP, and zinc
can  be  effectively  controlled  through  chemical  substitution.  As
discussed previously, chemical substitution will lead  to  significant
removals  of regulated toxics.  Thus, EPA based final PSNS controlling
PCP, TCP, and zinc on chemical substitution.

METHODOLOGY USED FOR DEVELOPMENT OF PSNS

PSNS for the control of pentachlorophenol, trichlorophenol,  and  zinc
were  developed  using  the  same  general  methodology  used  in  the
development of PSES effluent limitations for control  of  these  toxic
pollutants.     PSNS   are   expressed   as   allowable  maximum  daily
concentrations  (milligrams per liter).  Final  pretreatment  standards
include  a  mathematical formula that accounts for flow differences to
assure that the standards do  not  discourage  the  implementation  of
water   conservation   at  indirect  discharging  new  sources.   Mass
limitations (kg/kkg or lb/1000 Ib of product) are provided as guidance
in cases where  it is necessary to impose mass limitations for  control
of pollutants discharged from contributing pulp, paper, and paperboard
mills to POTWs.

PSNS  mass  limits  for PCP and TCP are identical to PSES mass limits.
The allowable maximum daily concentrations  for  new  source  indirect
                                556

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dischargers  were  calculated  by dividing the PSES mass limits by the
flow basis on which NSPS are based for each subcategory.  As discussed
in Section VIII, mass limits for zinc were determined as  the  product
of  the  maximum  zinc discharge concentration that forms the basis of
BPT limitations and the flows that form the basis of NSPS for each  of
the three groundwood subcategories.

A  more detailed discussion of the development of PSNS  is presented in
Section VIII.

COST OF APPLICATION

The technology basis of PSNS is identical to the technology  basis  of
PSES  — chemical substitution to limit the discharge of PCP, TCP, and
zinc.  Therefore, there is no incremental cost attributable to PSNS.

NON-WATER QUALITY ENVIRONMENTAL IMPACTS

Sections 304(b) and 306 of the Act require EPA to  consider  the  non-
water  quality  environmental  impacts (including air pollution, solid
waste generation, and energy requirements) of certain regulations.  In
conformance with these provisions, the Agency considered the effect of
this regulation on air pollution, solid waste generation,  and  energy
consumption.  EPA anticipates that compliance with PSNS will result in
no  increase in energy usage nor will it result in any  increase in air
pollution, noise pollution, or solid waste generation.
                               557

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                              SECTION XV

                           ACKNOWLEDGEMENTS


The U.S. Environmental Protection Agency  wishes  to  acknowledge  the
contributions  to  this  project  by the E C. Jordan Co., of Portland,
Maine.  Donald R. Cote, P.E., Vice  President-Operations,  Willard  C.
Warren  III,  P.E.,  Project Manager, John C. Tarbell, P.E., Assistant
Project Manager, Conrad R. Bernier, Senior Project Engineer, Robert E.
Handy, P.E., Project  Engineer,  and  Charles  D.  Cox,  P.E.,  Senior
Project  Engineer,  were  the  key  contributors  in completion of the
detailed technical study and the drafting of  the  initial  report  on
which  this document is based.  Other personnel who contributed in the
project investigations were Neal A.  Jannelle,  Laurance  C.  Harbour,
Nancy  E.  Forrester,  Deborah A. Luciano, and Edward J. Doyle, of the
E.G. Jordan Co. and Raymond H. Myers, Ph.D., Statistical Consultant of
Virginia Polytechnic Institute, and Roger A. Novack,  Ph.D.,  formerly
of Gulf South Research Institute.

We  wish  to  acknowledge  the  mill  managers,  engineers,  and other
representatives  of  the  industry  without  whose   cooperation   and
assistance   in   site  visitations  and  information  gathering,  the
completion of this project would  have  been  greatly  hindered.   The
National  Council of the Paper Industry for Air and Stream Improvement
and the American  Paper  Institute  BAT  Task  Group  deserve  special
recognition.

The  EPA  also  thanks personnel in the EPA regional offices and state
agencies who supplied discharge  monitoring  report  (DMR)   data  and
related  information.   Contributing  to this effort were EPA staff in
Regions I, II, III, IV, VI, VIII, IX,  and  X  and  personnel  in  the
following state agencies: Maine, New Hampshire, Connecticut, New York,
Virginia,  Delaware,  Tennessee,  Mississippi, Alabama, Georgia, South
Carolina,  North  Carolina,   Ohio,   Indiana,   Illinois,   Michigan,
Wisconsin,   Minnesota,   Kansas,   Iowa,  California  Region  I,  and
California Region V (Redding Office).

The U.S. EPA Pulp and Paper  Technical  Working  Group  must  also  be
recognized for their valuable contributions:

     Danforth G. Bodien       U.S. EPA, Region X
     Joseph Davis             U.S. EPA, Region III
     Jack Newman              U.S. EPA, Region V
     Gary Milburn             U.S. EPA, Region V
     Frank Early              U.S. EPA, NEIC-Denver
     Michael Strutz           U.S. EPA, OR&D - Cincinnati
     Michael Tiami            U.S. EPA, Region IV
     Charles Whittier         U.S. EPA, Region VI
     Robert Gross             State of South Carolina
     Vincent Carpano          State of Virginia
     Paul Didier              State of Wisconsin
                               559

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Appreciation is expressed to those at EPA Headquarters who contributed
to  the  completion  of  this  project, including: Louis DuPuis, Renee
Rico, John Kukulka, Henry Kahn, Richard Kotz,  Allen  Leduc,  Dale  M.
Ruhter, Edward Sharter, Gail Coad, William Webster, and David Gibbons,
Office  of  Analysis  and  Evaluation, Office of Water Regulations and
Standards; Alexander McBride, Fred  Leutner,  Alexandra  Tarnay,  Lynn
Delpire,  Rod Frederick, Edmund M. Notzon, Monitoring and Data Support
Division, Office  of  Water  Regulations  and  Standards;  L.  Michael
Flaherty, Donald Ehreth, Patrick Tobin, and Joseph A. Krivak, Criteria
and  Standards  Division,  Office  of Water Regulations and Standards;
Richard Gardner, Nancy Othmer, Bruce Diamond, Gail Cooper,  and  Susan
G.  Lepow,  Office  of  General Counsel; J. William Jordan and Richard
Brandes, Office of Water Enforcement; Richard Raines and Mahesh Podar,
Office of Planning and Evaluation; and Matthew Straus, Office of Solid
Waste.

Within the Effluent  Guidelines  Division,  Robert  Southworth,  Linda
Wilbur,  Devereaux  Barnes, John E. Riley, Robert B. Schaffer, Jeffery
D. Denit, Arthur Shattuck, Craig Vogt, Mark Mjonness,  Teresa  Wright,
Gregory  Aveni,  Maureen  Treacy,  and  Lois Jennings made significant
contributions.  The performance and long hours  contributed  by  Carol
Swann  are  appreciated,  as  are the efforts of Glenda Colvin, Glenda
Nesby, and Pearl Smith.

We also wish to acknowledge Raymond  C.  Loehr,  Ph.D.,  Professor  of
Agricultural   Engineering   and  Environmental  Engineering,  Cornell
University, a special friend of the Effluent Guidelines Division,  who
helped us over the last hurdle.
                                 5bO

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                              APPENDIX A

             COST, ENERGY, AND NON-WATER QUALITY ASPECTS


Previous sections described the respective BPT, BAT, PSES,  PSNS,  and
NSPS.control options that were considered as the basis of regulations.
This  section summarizes the cost, energy, and other non-water quality
impacts of the various  control  and  treatment  options.   The  other
non-water   quality   aspects  addressed  in  this  document  are  (a)
implementation requirements, (b) air pollution, (c)  noise  pollution,
and (d) solid waste.

METHODOLOGY FOR DEVELOPMENT OF COSTS

Introduction

This  section  describes  how  EPA  developed estimates of the cost of
implementation  of  the  control  and  treatment  technology   options
considered in regulation development.  The actual cost of implementing
these  control  and  treatment  options  can  vary  at each individual
facility, depending on the design  and  operation  of  the  production
facilities  and local conditions.  EPA developed control and treatment
costs that are representative of each subcategory of the pulp,  paper,
and   paperboard  industry  based  on  engineering  estimates.   Where
possible, the cost  estimates  were  compared  to  costs  reported  by
industry  and  were revised, where appropriate.  Accounting procedures
used at different mills vary, thus complicating the  use  of  industry
cost data.

In  order  to  assess  the overall impact of the various treatment and
control options on the  pulp,  paper,  and  paperboard  industry,  EPA
developed   model   mill  costs  for  31  distinct  subcategories  and
sub-groups of the various subcategories.   Costs  were  developed  for
BPT,  BAT,  and  NSPS treatment options for direct dischargers and for
PSNS and PSES technology options for indirect dischargers.  The  model
mill   approach,  mill  and  site  specific  cost  factors,  and  cost
estimating criteria are discussed below.

Model Mill Approach

The costs of implementation of various control and  treatment  options
were  estimated  in  order  to  determine  the economic impact of each
technology option.  In order to develop  costs,  EPA  developed  model
mills that are representative of mills in each of the subcategories of
the  pulp,  paper,  and  paperboard  industry.   In  order to properly
reflect the effect of mill size on costs, as many as  three  different
model  mill sizes were selected for the respective subcategories.  EPA
based model mill sizes on the actual variation  of  size  within  each
subcategory; model mill sizes are presented by subcategory in Table A-
1 .
                                561

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                                      TABLE A-l

                                 MODEL MILL SIZES BY
                           SUBCATEGORY AND DISCHARGE TYPE
Subcategory
Indirect Dischargers (kkg/d)
        Existing      New
Direct Dischargers (kkg/d)
                  New
Integrated Segment
Dissolving Kraft
Market Bleached Kraft


BCT Bleached Kraft


Alkaline-Fine1


Unbleached Kraft
o Linerboard


o Bag


Semi -Chemical


Unbleached Kraft and Semi-
Chemical


Dissolving Sulfite Pulp

Papergrade Sulfite2


Groundwood-Thenno-Mechanical
Groundwood-CMN Papers


Groundwood-Fine Papers


Secondary Fibers Segment
Deink
o Fine Papers


o Tissue Papers


o Newsprint

NA
NA


NA


NA



NA


NA


NA



NA


NA

NA


NA
45
544
907
NA




NA


NA


NA

NA
NA


NA


NA



NA


NA


NA



NA


NA

NA


NA
45
544
907
68
454
680


NA


NA


NA

907
318
544
1,451
272
726
1,179
181
726
1,089

408
907
1,361
408
907
1,361
181
386
544

635
1,361
2,359
408
544
91
408
907
272
45
544
907
68
454
680


163
363
726
23
45
163
NA

907
680


454


680



454


907


454



1,361


454

680


454
454


454




454


91
454

454
                                     562

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TABLE A-l
(continued)
Indirect Dischargers (kkg/d)
Subcategory Existing New
Tissue From Wastepaper

Paperboard From Wastepaper


Wastepaper-Molded Products


Builders' Paper and
Roofing Felt

Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish


o Cotton Fiber Furnish


Nonintegrated-Tissue Papers


Nonintegrated-Lightweight Papers


Nonintegrated-Filter and
Nonwoven


Nonintegrated-Paperboard


NA

45
145
635
NA



NA



NA


NA


NA


NA



NA


NA


9
36
45
145
635
NA



NA



NA


NA


NA


NA



NA


NA


Direct Dischargers (kkg/d)
Existing New
9
36
45
145
635
18
45
136

91
204


32
195
907
9
45
91
32
163
907
9
54
181

5
18
41
9
36
68
9

91
454

45



68
136


227


27


45
227

45



23


45


1Includes Fine Bleached Kraft and Soda subcategories.

2Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash)
 subcategories.
                                       563

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Mill and Site Specific Cost Factors

Specific  mills  in a subcategory can be expected to differ in certain
respects from the representative model mills.  These  differences  can
alter  the  costs  for  achieving  the various effluent quality levels
specified for each subcategory.  Among the factors affecting costs are
location, climate, mill age, savings resulting from implementation  of
various   controls,   retrofit  requirements,  site  limitations,  raw
wastewater quality, and production capacity.   In addition, at  certain
mills,   different   combinations  of  production  processes  are  now
employed.

Location.  Differences exist in construction  practice,  labor  rates,
and  energy  costs  due  to geographic location.  EPA based model mill
costs on national averages.  Regional cost factors  are  presented  in
Table  A-2  for  the  purpose  of  adjusting  model  mill  costs to be
representative of specific geographic areas.(210)(211)(212)(213)

Climate.  Biological treatment systems constructed  in  cold  climates
often  require longer detention times than those constructed in warmer
climates; this is due to bio-kinetic relationships (see Section  VII).
Longer  detention  time  requires  higher capital and operating costs.
The costs presented are reflective of  design  in  areas  of  moderate
climate and represent the median values anticipated to be incurred.

Climate  can  also  affect  the  construction  details  of the various
components.  Open pit pumps, above ground piping, and exposed  process
equipment  are characteristic of warm climate mills, while at mills in
colder climates such designs cannot  be  utilized.   Model  mill  cost
estimates  reflect  design  based on cold climates.  At those mills in
warm climates, lower costs may be realized than are reflected  in  the
cost estimates.

Production   Capacity.   Economies  of  scale  can  be  realized  with
increasing size and are likely to vary depending on the  equipment  to
be constructed.  In order to account for the effect of mill size, each
control and treatment option was evaluated over a representative range
of mill sizes for each subcategory.

Age.   Mill  age  can  impact the cost of implementing various process
controls.  This factor was considered in the development of model mill
costs by accounting for the  relative  difficulty  of  installing  and
replacing process equipment and effluent sewers.

The chronological age of a mill, however, is not always a good measure
of  the  relative  ease  with which controls may be implemented.  This
results from the fact that at older  mills,   extensive  rebuilding  or
expansion   programs   have   been  implemented,  often  resulting  in
conditions  that  allow  for  ease  of  installation   of   additional
production process controls.
                                564

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Region/State
                              TABLE A-2

                  REGIONAL COST ADJUSTMENT FACTORS
                Operation
                   and
               Maintenance
Capital (210)   (211)(212)
Energy (213)
Northeast          1.03

North Central      1.02

South              0.90

Plains/Mountain    0.96

West               1.09

Alaska             1.38
                   0.97

                   1.15

                   0.81

                   0.99

                   1.12

                   1.78
   1.38

   1.18

   1.17

   1.02

   0.79

   1.16
                                  565

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Material  and  Energy Savings.  Where production process controls were
considered, more efficient mill operation and substantial  savings  of
material  and  energy  can  result.    Material and energy savings were
taken into account where  appropriate  and  net  costs  of  operation,
maintenance, and energy are presented.

Other  Savings.  There are other possible savings that may result from
implementation of production process controls in addition  to  savings
in  materials  and  energy.   Such  additional  savings, which are not
accounted for in  the  cost  estimates  presented  in  this  document,
include  the  benefits  that result from improved recovery systems and
the manufacture of by-products such as black liquor soap,  turpentine,
solvents,  glues,  and  human  and  animal  nutrients.  The recycle of
effluent streams may also allow for heat recovery that  can  represent
savings  at some mills, particularly in colder climates.  Such savings
may not be common to all mills in a subcategory, but may  be  realized
at  some  mills  depending  on such factors as location and production
processes employed.

Retrofit  Requirements.   EPA  based  BAT  model  mill  costs  on  the
assumptions   that  (a)  production  process  and  effluent  treatment
controls that form the basis of BPT  effluent  limitations  have  been
installed  and (b) all facilities are currently attaining BPT effluent
limitations.  For those cases where mills are not currently  attaining
existing BPT effluent limitations, an additional cost for retrofitting
existing  treatment  may be incurred if predicted levels of discharged
pollutants are to be attained.  These costs are not accounted  for  in
the cost estimates presented in this document as these costs have been
accounted for in previous rulemaking efforts.(48)

Site Limitations.  The implementation of additional production process
controls  or end-of-pipe treatment technologies can require additional
land.  Spatial  relationships  and  the  physical  characteristics  of
available  land can affect construction costs.  The impact of mill-by-
mill variations are lessened because the options being considered  are
not  land  intensive.  In addition,  where treatment facilities such as
clarifiers are added, the cost  of  pumping  to  these  facilities  is
included.   For those facilities where gravity flow is possible, costs
are considerably overstated.

Analysis of information  obtained  during  the  data  request  program
indicates  that  for  two-thirds  of  the  operating  facilities, land
availability is not a problem.  For that reason  and  because  of  the
extensive  variability  of  land  acquisition  costs, the cost of land
acquisition was not included in cost estimates.

Raw Wastewater Characteristics.   Flow,  BODj[,  and  TSS  loadings  at
individual  mills  may  vary  from  those  of  the  model mill.  These
variations can affect the cost of effluent  treatment.   However,  the
model  mill  approach  to cost development yields representative costs
within an acceptable confidence interval  without  requiring  specific
engineering  studies  at each mill in the industry.   It  is likely that
the approach to achieving effluent limitations chosen by management at
                                  566

-------
individual mills will vary from that considered  in  establishing  the
specific  limitations.   EPA  anticipates  that  mill  management will
choose the technology that is most cost-effective for each facility.

Cost Estimating Criteria for Control and Treatment Technologies

EPA developed capital, operation  and  maintenance,  and  energy  cost
estimates   based   on   the   criteria   presented   in   Table  A-3.
(211)(212)(213)(214)(215)(216)(217) The pre-engineering cost estimates
developed for this study are expected to have a variability consistent
with this type of estimate and are on the order of plus  or  minus  30
percent.

Capital Cost Criteria.  All costs presented in this section, except as
noted,  are in terms of first quarter 1978 dollars.  Since construction
costs  escalate,   these  estimates  may  be  adjusted  through  use of
appropriate cost indices.  The  most  accepted  and  widely-used  cost
index  in  the  engineering field is the Engineering News Record (ENR)
construction cost index.  The ENR index value of 2,683  used  in  this
report was taken from the "U.S.  - 20 Cities Average" for first quarter
1978. (214)

Equipment  costs  were based on supplier quotes, published literature,
engineering experience,  and  data  request  program  mill  responses.
Capital   costs   include   allowances   for  lost  production  during
construction  or  for  additional  power  facilities   as   warranted.
Additional costs such as engineering and contingencies were based on a
percentage  of capital and vary from 15 to 25 percent depending on the
technology.

A total labor rate of $23.00 per hour was assumed for installation  of
production  process  controls.   This wage rate is based upon a $19.00
national average wage  rate  including  fringe  benefits  plus  a  net
supervision   rate   of   $4.00   per   hour.(218)   Construction  and
installation cost estimates for effluent treatment were determined  as
an appropriate varying percentage of capital.

Annual  Fixed Charges.  The annual fixed charges are those annual costs
that  are  directly related to the construction of pollution abatement
facilities.   These charges commonly include such items as depreciation
of the control equipment and interest  on  the  capital  borrowed  for
construction.  In addition, such costs as maintenance materials, spare
parts,   insurance,  and taxes are expressed as a percentage of initial
capital expenditures.

The  useful  life  of  each  structure  and  mechanical  unit  varies.
Mechanical  equipment  operating  in  demanding service conditions may
have a useful life of 5 to 10 years compared to a building  which  may
have  a useful life of 40 to 50 years or more.   Depreciation costs are
those accounting charges for the eventual replacement of a given asset
(equipment or structure) at the end of its useful life.   Depreciation
of  the  capital   assets  may  be  by  accumulation  of  digits (rapid
depreciation) or  method of averages (straight-line).  A  NCASI  report
                                567

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                                   TABLE A-3

                           COST ESTIMATING CRITERIA1
1.   Capital costs are as of first quarter 1978:             ENR = 2,683

2.   Annual fixed (amortized)  costs are 22% of capital  expenditures

3-   Energy:        Electrical                              $0.0325/kwh
                    Fuel                                    $12.00/barrel

4.   Operation and Maintenance:
     Labor:         General                                 $10.35/hr
                    Solids disposal                         $  8.00/hr

     Chemicals:           alum                                $110/kkg, dry  basis
                         polymer                            $4.41/kg
                         85% phosphoric acid                $0.44/kg
                         anhydrous ammonia                  $154/kkg, dry  basis
                         50% sodium hydroxide               $l65/kkg
                         100% sulfuric acid                 $56/kkg


1Sources of Cost Data:

     Employment and Earnings,  U.S. Bureau of the  Census,  April 1978.  (211)

     Employee Benefits 1977, Chamber of Commerce  of the U.S.A.,
     April 1978. (212)

     Energy User News, Vol. 3, No. 32, August 7,  1978.   (213)

     Engineering News Record.  March 23, 1978.  (214)

     Monthly Energy Review, U.S Department of Energy, March 1979. (215)

     Municipal Sludge Landfills. EPA-625/1-78-010,  U.S. Environmental
     Protection Agency, Process Design Manual, October  1978.  (216)

     Chemical Marketing Reporter, November 6, 1978. (217)
                                       568

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shows  an  average  depreciation  rate  in the industry of 16.5 years
(219)

Interest is that annual charge for financing the capital  expenditures
for  construction  of  a  facility.   Such  financing  may  be through
corporate bonds, conventional lending markets, or tax-exempt municipal
revenue bonds.  Municipal revenue  bonds  have  lower  interest  rates
compared to corporate bonds.  A NCASI report states that 44 percent of
the  pollution  abatement  expenditures  in 1976 were financed through
tax-exempt municipal bonds. (219)

Costs for taxes, insurance, spare parts, and maintenance materials are
often expressed as a percentage of the capital investment.

For the purpose of calculating total annual costs, EPA used an average
fixed charge of 22 percent of the capital expenditures.   This  figure
includes  all of the above items.  EPA realizes that these charges may
vary and are dependent upon several factors, such as the  complexities
of  the  system installed, financing availability, insurance coverage,
property  tax  credits,  spare  parts   inventory,   and   maintenance
materials.

Energy  Costs.   An  average  national  electric  power cost for large
industrial users (200,000 kwh monthly, 1,000 kw demand) was  estimated
at $0.0366/kwh.  This figure was derived from average cost information
by  state  and  on  electric  rates  from approximately 200 public and
private utilities.(213)  Information concerning actual  revenues  from
approximately  200  public  and  private utilities indicated a cost of
$0.0281/kwh. (213) Based on that data, energy costs were estimated  at
$0.0325/kwh.

Fuel for steam generation was estimated at $12 per barrel. (215)

Operating  and  Maintenance  Labor.   The average nonsupervisory labor
rate in the pulp and paper industry was reported to be $7.14 per  hour
in  February  1978.(211)   Average total benefits for the pulp, paper,
lumber, and furniture industry for the year 1977 were reported  as  34
percent  of  wages.(212)   Although  no  industry-wide data concerning
supervisory costs were available, the proposed control  and  treatment
technologies  under  consideration  are  anticipated  to  require only
minimal additional supervisory labor.

A supervisory and benefits cost of 45 percent of the  labor  rate  was
assumed.  This results in a total labor rate of $10.35/hr.

Chemicals.    Chemical  costs  were  based  on  quotes  from  chemical
suppliers and chemical marketing reports.  Many  of  the  technologies
under  evaluation  include  the  use  of  chemicals,  including  alum,
polymer, phosphoric acid, sulfuric acid, anhydrous ammonia, and sodium
hydroxide.
                                569

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COSTS FOR IMPLEMENTATION OF BPT

EPA  identified  four  new  subcategories  of  the  pulp,  paper,  and
paperboard   industry   (wastepaper-molded   products,  nonintegrated-
lightweight papers,  nonintegrated-filter  and  nonwoven  papers,  and
nonintegrated-paperboard).   In  Section  VIII, BPT was identified for
these subcategories.  In this section, estimates  of  the  incremental
cost to achieve BPT effluent limitations are presented.

For  the  nonintegrated-lightweight  papers,  nonintegrated-filter and
nonwoven papers, and nonintegrated-paperboard subcategories,   BPT  was
identified  as  primary treatment.  At the direct discharging mills in
these  three   nonintegrated   subcategories,   in-place   end-of-pipe
treatment  consists  of  primary treatment (or its equivalent) or more
advanced   treatment   technology   (i.e.,   biological    treatment).
Therefore,  EPA anticipates that the incremental cost of attainment of
BPT in these subcategories is zero.

BPT was identified as biological treatment for  the  wastepaper-molded
products  subcategory.  In general, at the direct discharging mills in
this subcategory, primary treatment or  its  equivalent  is  in-place.
EPA's estimate of the incremental costs for attainment of BPT effluent
limitations  was  based  on  the  addition  of  a biological treatment
system.  Major unit operations include  (a)  wastewater  pumping,  (b)
flow equalization, (c) nutrient addition, (d) addition of an activated
sludge  basin  with  aerators,  (e) flotation thickening with chemical
addition, (f) solids dewatering with chemical addition, (g) biological
sludge transportation to landfill,  and   (h)  landfill  of  biological
solids.

The  design  criteria  on  which costs were determined for each of the
major unit processes are presented in Table A-4.   The  total  capital
and  total  annual costs for compliance with BPT are presented for the
wastepaper-molded products subcategory in Table A-5.

BPT limitations were also promulgated  for  new  subdivisions  of  the
paperboard    from    wastepaper    and    nonintegrated-fine   papers
subcategories.  As a result of comments on  the  proposed  rules,  EPA
obtained additional data relating to mills in these subcategories (see
(Section  IV).   The  Agency  determined  that  higher raw waste loads
result at paperboard from wastepaper mills where corrugating medium is
used as furnish; therefore, BPT  effluent  limitations  applicable  to
discharges  from  these mills were modified.  As discussed previously,
less stringent BPT effluent limitations than were previously in effect
now apply to existing direct discharging mills in the paperboard  from
wastepaper subcategory where recycled corrugating medium is processed.
For  this  reason,  no  costs  are associated with attainment of these
modified BPT limitations.

Subsequent to proposal, the Agency  reexamined  the  subcategorization
scheme  for  the  nonintegrated-fine papers subcategory.  As discussed
previously, EPA's review of data  for  the  nonintegrated-fine  papers
subcategory  revealed  that  segmentation  was warranted because mills
                                570

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                                   TABLE A-4

              DESIGN CRITERIA FOR BPT ACTIVATED SLUDGE TREATMENT
                    WASTEPAPER-MOLDED PRODUCTS SUBCATEGORY
Wastewater Pumping
     Design flow:  1.5 x average annual flow
     Basis for power cost:  12 m total dynamic head, 70% efficient

Flow Equalization
     Detention time:  12 hrs in concrete basin

Primary Clarification
     Overflow rate:  24 cu m/d/sq m
     Sidewater depth:  4 m

Secondary Clarification
     Overflow rate: 20 cu m/d/sq m
     Sidewater depth: 4 m

Activated Sludge Basin
     Number of basins:  2
     Loading rate  (use larger value):
          0.8 kg BOD5 applied/cu m/d, or
          8 hr hydraulic detention time
     Nutrient feed:  BOD5 removed:N:P = 100:5:1
     Aeration design requirements:
          1.5 organic peaking factor
          1 kg 0  /kg BOD5 removed
          19 kg 6  /aerator hp/d
     Length/width ratio: 4/1
     Sidewater depth: 4 m
     Sideslopes: 1/1

Dissolved Air Flotation Thickening for Biological Solids
     Sludge loading rate:  10 kg/hr/sq m
     Hydraulic loading rate:  46.9 cu m/d/sq m
     Chemical dosage:  4 kg of polymer/kkg of solids

Solids Dewatering
     Type:  horizontal belt-filter press
     Loading rate:  318 kg of dry solids/hr/m of belt width
     Chemical dosage: 4 kg of polymer/kkg of solids

Primary/Biological Sludge Transportation
     Haul distance:  16 km
     Sludge content:  primary and biological sludge at 30 percent solids (w/w)

Primary/Biological Sludge Landfill
     Sludge content:  primary and biological sludge at 30 percent solids (w/w)
     Landfill design:  normal landfill compaction and covering techniques
                                       571

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                                 TABLE A-5

         COST OF IMPLEMENTATION OF BPT ACTIVATED SLUDGE TREATMENT
                  WASTEPAPER-MOLDED PRODUCTS SUBCATEGORY
                            Operation
 Mill                          and                             Total
 Size        Capital       Maintenance        Energy           Annual
(kkg/d)       ($1.000)       ($l>000/yr)      ($1.000/yr)	($1.000)

  18             891            81               11              288
  45           1,542           113               19              471
 136           3,015           176               41              879
                                    572

-------
where cotton fibers  comprise  a  significant  portion  of  the  final
product  (equal to or greater than four percent) have higher raw waste
flow and BODi> than mills where only wood pulp is processed.   In  this
rulemaking,  EPA  established BPT limitations applicable to discharges
from these mills that are less stringent than for other faciliti.es  in
the  nonintegrated-fine  papers  subcategory.   The Agency anticipates
that there will be no costs associated with attainment of BPT effluent
limitations  in  the  cotton  fiber   furnish   subdivision   of   the
nonintegrated-fine papers subcategory because existing permits for the
two  direct discharging mills are more stringent than the BPT effluent
limitations.

COSTS FOR IMPLEMENTATION OF BAT OPTIONS

Toxic Pollutant Control Options

The Agency evaluated two options for control of  toxic  pollutants  in
pulp, paper, and paperboard industry discharges.  They are (a) control
of   zinc   at  groundwood  mills  through  the  application  of  lime
precipitation   and   control   of   pentachlorophenol     (PCP)    and
trichlorophenol  (TCP) through substitution of biocides containing PCP
and TCP with those that do not and (b) control of  chloroform  through
the application of additional aeration.

Option  1_.   This  includes the application of lime precipitation, the
technology basis of BPT effluent limitations, for control of  zinc  in
the  groundwood subcategories and chemical substitution to control PCP
and TCP in every subcategory.   The  Agency  determined  that  at  all
direct discharging groundwood mills, BPT zinc limits are now being met
through substitution of sodium hydrosulfite for zinc hydrosulfite as a
bleaching chemical.  Therefore, the Agency anticipates that there will
be  no  incremental  costs  associated  with attainment of zinc limits
based on this technology option.

The technology basis for control of PCP and TCP in  all  subcategories
is substitution to the use of biocides not containing these compounds.
Based  on  the  results  of  verification  sampling, process chemicals
containing pentachlorophenol were used at ten of the 60 sampled mills;
chemicals containing trichlorophenol were used at six of  the  sampled
mills.   Correspondence  with mill personnel indicate that: (a) at six
of the mills, PCP-containing process chemicals are no longer used  and
(b)  at  four  of  the  mills, TCP-containing process chemicals are no
longer used.  Inquiries of chemical suppliers on the relative costs of
substitute chemicals indicate that no definable cost  difference  will
result from chemical substitution.

Option   £.   This  technology  option  includes  the  application  of
additional  aeration   at   nine   mills   where   (a)   chlorine   or
chlorine-containing  compounds  are used to bleach pulp and (b) closed
biological systems are used that inhibit volatilization of chloroform.
Table A-6 presents the design criteria  for  the  additional  aeration
step  and  Table  A-7  presents  chloroform control costs for the nine
mills.
                                573

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                                   TABLE A-6

                    DESIGN CRITERIA FOR CHLOROFORM CONTROL
                        AT NINE MILLS WHERE CHLOROFORM
                          VOLATILIZATION IS INHIBITED
Earthen Basin
     Loading rate (use larger value):
         *0.8 kg BOD5 applied/cu ra/d, or
          8 far hydraulic detention time
     Aeration design requirements:
          19 kg 02 BOD5/d/aerator HP
     Sidewater depth: 4 m
     Sideslopes: 1/1
     Leachate collection
     Synthetic liner
* Based on BODS raw waste load.
                                        574

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                                   TABLE A-7

                COST FOR CHLOROFORM CONTROL AT NINE MILLS WHERE
                    CHLOROFORM VOLATILIZATION IS INHIBITED
Treatment
System/ Mill
Subcategory Number
Capital
($1,000)
Operation
and
Maintenance
($l,000/yr)
Energy
($l,000/yr)
Total
Annua 1
($1,000)
Oxygen Activated Sludge
Integrated-Miscellaneous
010010
010012
010015
010059
2,217
1,235
1,539
1,223
53
36
41
36
484
252
320
250
1,025
560
700
555
Alkaline-Fine and Papergrade Sulfite1

         030051 and 040009    3,133

DeepTank Aeration
66
699
1,454
Dissolving Sulfite
Papergrade Sulfite
TOTAL
046002
046005
040017

4,622
3,897
1,581
19,447
85
76
42
435
1,075
895
332
4,307
2,177
1,828
722
9,021
  Joint treatment.
                                     575

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Nonconventional Pollutant Control Options

Technologies  available  for  removal  of  nonconventional  pollutants
include:  (a)  color  removal by minimum lime or alum coagulation; and
(b) ammonia removal by biological  nitrification  or  substitution  of
chemical  pulping  bases.   The method of developing cost data and the
costs associated with  these  respective  technologies  are  presented
below.

Color Removal.   Estimates of costs for color removal were prepared for
two  alternative  treatment technologies: minimum lime coagulation and
alum  coagulation.   Costs  are  presented  in  Table  A-8  for   both
technologies  for those subcategories identified as having high levels
of color in effluent discharges.

     Minimum Lime Coagulation - Minimum lime coagulation treatment for
color load reduction  in  the  four  bleached  kraft,  the  dissolving
sulfite  pulp,  and the two papergrade sulfite subcategories is applied
only to highly-colored wastewater  streams.    These  streams  normally
represent  only  about  one-quarter  to  one-third of total wastewater
discharge from a mill.  The streams required to be  treated  would  be
the  highly-colored  bleach  plant  wastewater  (first  stage  caustic
extraction waste stream) and the screen room  (decker  or  pulp  mill)
wastewater.    For  the  remaining  subcategories  (unbleached  kraft,
semi-chemical,  and unbleached kraft and semi-chemical),  minimum  lime
is  applied  to the total wastewater discharge because (a) the flow is
much lower for mills in these subcategories and (b) the color does not
tend to be concentrated in streams of lesser flow.

The costs for the minimum lime  system  are  based  on  the  following
items:

     1.   wastewater transfer pump,
     2.   mixing  (in-line mixer),
     3.   lime feed system,
     4.   polymer feed system,
     5.   clarifier,
     6.   sludge holding tank with mixer,
     7.   lime mud dewatering system,
     8.   fluidized bed for lime mud incineration, and
     9.   pH adjustment following  minimum  lime  treatment  in  those
          cases where the total mill effluent is treated.

A  wastewater transfer pump with ancillary piping transports the first
caustic stage effluent from the  bleach  plant  to  the  minimum  lime
treatment  system.  An in-line mixer combines the lime slurry with the
wastewater.  For the purpose of the cost estimate, a  lime  dosage  of
2,250  mg/1  was  assumed.  Wastewater then flows to a color reduction
clarifier.  A polymer is metered into the wastewater stream  prior  to
the clarifier to aid in settling the lime precipitate.  Other settling
aids  (such  as  fiber  fines)  can  also be used at this point in the
minimum lime process.
                               576

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        TABLE A-8

COST FOR COLOR REDUCTION
 FOR DIRECT DISCHAKGERS
Subcategory and
Mill Size
Dissolving Kraft
907 kkg/d
Lirae
Alum
Market Bleached Kraft
318 kkg/d
Lime
Alum
544 kkg/d
Lime
Alum
1451 kkg/d
Lime
Alum
BCT Bleached Kraft
272 kkg/d
Line
Alum
726 kkg/d
Lime
Alum
1179 kkg/d
Lime
Alum
Alkaline-Fine
181 kkg/d
Lime
Alum
?26 kleg/rt
Liine
Alum
1089 kkg/d
Lime
Alum
Unbleached Kraft
408 kkg/d
Lime
Alum
90? kkg/d
Lime
Alum
1361 kkg/d
time
Alum
Capital
($1,000)


5,591
13,039


2,100
5,752

2,880
7,886

5,145
14,129


1,897
5,054

3,4^0
8,996

4,545
12,018


1,380
3,678

3,450
8,199

4,350
10,423


2,724
3,48!

4,350
5,511

5,572
6,984
Amortized
Capital
C$l,000/yr)


1,230
3,031


462
1,313

634
1,809

1,132
4,095


417
1,155

759
2,073

1,000
2,781


304
83S

759
1,894

957
2,419


599
791

357
1,260

1,226
1,602
Operation and
Labor
(51,000/yr)


151
912


89
476

101
597

143
914


86
444

in
671

132
830


82
371

111
658

127
784


100
342

132
472

158
560
Maintenance
Chemicals
(Sl,000/yr)


867
3,520


174
912

278
1,561

1,070
4,163


146
676

** ">A
1,801

610
2,927


92
400

370
1,592

556
2,391


308
362

684
800

1,027
1, 198
Energy
($l,000/yr)


1,218
243


245
75

405
116

771
275


205
60

5-ij
134

875
205


140
41

545
122

SOS
173


355
38

781
68

1,166
95
Total
Annual
($1,000)


3,466
7,706


970
2,776

1,417
4,083

3,116
9,447


854
2,335

i , 733
4,679

2,617
6 , 743


618
1,650

1,785
4,266

2,445
5,767


1,363
1 ,533

2,555
2,600

3,578
3 , 455
            577

-------
Subcategory and
Mill Size
Semi-Chemical
181 kkg/d
Lime
Alum
386 kkg/d
Lime
Alum
544 kkg/d
Lime
Alum
Unbleached Kraft and
634 kkg/d
Lime
Alum
1361 kkg/d
Lime
Alum
2359 kkg/d
Lime
Alum
Dissolving SulTite P
408 kkg/d
Lime
Alum
544 kkg/d
Lime
Alum
Papergrade Sulfite2
91 kkg/d
Lime
Alum
408 kkg/d
Lime
Alum
907 kkg/d
Lime
Alum
Capital
($1,000)


1,366
1,927

2,337
2,943

2,833
3,581
Semi-Chemical

3,746
4,630

5,998
7,220

8,235
9,985
alp

3,750
8,835

4,470
10,477


1,230
2,989

3,270
7,151

5,235
11,466
Amortized
Capital
($l,000/yr)


301
434

514
665

623
813


824
1,056

1,317
1,658

1,812
2,303


825
2,033

983
2,419


271
678

719
1,646

1,152
2,660
TABLE A- 8
(continued)
Operation and
Labor
($l,000/yr)


81
225

94
299

103
341


121
418

167
573

215
723


117
661

129
748


79
317

108
584

144
827
Maintenance
Chemicals
($l,000/yr)


114
130

235
275

339
388


532
617

1,142
1,324

1,964
2,296


450
1,869

598
2,493


83
281

355
1,278

780
2,841
Energy
(Sl,000/yr)


141
19

278
31

390
39


613
56

1,293
102

2,257
163


645
137

850
175


120
32

500
100

1,100
200
Total
Annual
($1,000)


638
808

1,122
1,270

1,456
1,581


2,091
2,147

3,921
3,657

6,248
5,485


2,037
4,700

2,560
5,835


553
1,308

1,682
3,608

3,176
6,528
'Includes Fine Bleached  Kraft  and  Soda  subcategories
2Includes Papergrade Sulfite  (Blow Pit  Wash)  and  Papergrade Sulfite  (Drum Wash) subcategories
                                                       578

-------
Sludge from the clarifier is pumped to a  sludge  holding  and  mixing
tank  or  directly  to the lime mud dewatering system.  After the lime
mud has been dewatered to  approximately  60  percent  solids,  it  is
transferred  to  a  fluidized  bed  for drying and calcining.  At this
point, recovered lime is transferred back to the slaker for  reuse  in
the  color  control  process.   Ninety  percent  recovery  of lime was
assumed.

In those cases where  the  total  mill  wastewater  is  treated  using
minimum  lime  coagulation,  EPA assumed that the decolored wastewater
would be further treated to lower the pH below the  maximum  allowable
discharge (9.0).  EPA assumed that sulfuric acid would be the chemical
used   for  pH  control.   This  pH  adjustment  system  includes  two
neutralization tanks in series, each equipped with a  mixer,  and  the
chemical  feed  and  storage  equipment  required  for  sulfuric  acid
addition.

     Alum  Coagulation  -  Alum  coagulation  is   another   available
technology  for  removing  color  and can be applied to the total mill
effluent for each  of  the  subcategories  from  which  highly-colored
effluents  are  discharged.  The costs for the alum coagulation system
are based on the following items:
     1 ,

     2,

     3,
wastewater pumping,

sulfuric acid feed system,

chemically   assisted    clarification
clarifier),
(solids
contact
     5,

     6,

     7.

     8,

     9,
chemical coagulation with alum (at a dosage appropriate  for
each subcategory) and polyelectrolyte addition (at 1  mg/1),

neutralization with 10 mg/1 sodium hydroxide,

solids dewatering,

dissolved air flotation thickening,

chemical sludge transportation to landfill, and

chemical sludge landfill.
Normally, the topography of  the  effluent  treatment  site  does  not
permit  gravity  flow through the entire treatment process.  Thus, EPA
assumed that it would be necessary to construct  an  effluent  pumping
facility  that  is  capable  of  pumping  the maximum daily flow to be
treated.

The design assumes the use of a solids-contact clarifier to accomplish
flocculation, settling, and sludge removal.  For flows  in  excess  of
18,900  cubic  meters  per  day  (5  MGD),  EPA assumed the use of two
parallel units, earh capable of handling 50 percent of the daily flow.
                                579

-------
At mills where activated sludge treatment is  employed,  the  chemical
clarification    design    reflects   an   additional   solids-contact
clarifier(s) following the existing  secondary  clarifier(s).    It  is
likely that at many mills, an existing secondary clarifier(s)  could be
modified  to allow for the addition of chemicals;  this would result in
significantly lower  capital  expenditure.    An  additional  clarifier
allows  for  the  recycle  of  biological  sludge  that  has  not been
contaminated by the addition of chemicals;  this would  allow  for  the
addition  of  a  chemical  recovery system,  if it were determined that
such a system is economically advantageous.

The primary flocculant is alum at a dosage rate  of  300  mg/1.    Alum
tends  to  lower the pH of the effluent.  Optimum alum flocculation is
reached at a pH of 4.0 to 6.0.(147)(148) Provision for the addition of
sulfuric acid was included to  optimize  alum  requirements.   If  the
effluent pH changes to a value where the effectiveness of flocculation
deteriorates  and/or  the  effluent  does  not  meet  pH  limitations,
neutralization   may   be   required.     Therefore,    EPA    included
neutralization with sodium hydroxide in the design.

Waste  chemical  solids  from  the secondary clarification process may
require thickening before they can be effectively dewatered.  If these
solids were not thickened, the capacity of a dewatering unit would  be
greatly   reduced.    EPA  selected  air  flotation  as  the  specific
thickening  process  in  the  development  of  costs.   Air  flotation
requires  that  a flocculant, such as a polymer, is added to the waste
solids prior to the thickening process.

Alum sludge is gelatinous  and  difficult  to  dewater.   Mixing  with
primary   sludge   and/or   the   addition   of  polymer  can  improve
dewaterability.  The cost of dewatering of alum sludge was  determined
assuming the use of a separate horizontal belt filter press dewatering
system  to  dewater  chemical solids only.   EPA assumed that dewatered
sludge would be landfilled.

Ammonia Removal.  EPA estimated the costs of ammonia removal at direct
discharging mills where  ammonia-based  cooking  chemicals  are  used.
These  costs  were  based  on  (a) substitution to a non-ammonia-based
cooking  liquor   and   (b)   ammonia   removal   through   biological
nitrification.   Model mill costs for direct dischargers are presented
in Table A-9 for  the  semi-chemical,   dissolving  sulfite  pulp,  and
papergrade sulfite subcategories.

Costs  for  substitution  of  chemical  bases  were developed based on
installation of a new spent liquor  recovery  furnace  and  additional
evaporation  capacity to allow for a change from ammonia-based cooking
to sodium-based cooking.(220) Increased evaporator capacity  would  be
required  to  increase  the  solids  content of the sodium-based spent
liquor and to account for the  increased  tendancy  for  scaling  (and
subsequent need for more frequent washing).   Spent sodium-based liquor
has  a lower heat value than spent ammonia-based liquor; EPA took this
into account in its cost estimates.  Another major cost item would  be
the  increased  cost  of  chemicals,   with  costs  for  NH3_ and Na2C03_
                                 580

-------
                                                  TABLE A-9

                                          COSTS FOR AMMONIA REMOVAL
                                           FOR DIRECT DISCHARGERS
Subcategory
Semi -Chemical














Dissolving Sulfite
Pulp









Papergrade Sulfite2














Mill
Size
(kkg/d)
181




386




544





408




544




91




408




907




Control '
I
II
III
IV
V
I
II
III
IV
V
I
II
III
IV
V

I
II
III
IV
V
I
II
III
IV
V
I
II
III
IV
V
I
II
III
IV
V
I
II
III
IV
V
Capital
($1,000)
1,500
510
850
277
6,010
2,857
1,021
1,586
528
9,440
3,846
1,429
2,079
733
11,610

12,640
2,841
5,429
700
26,570
16,181
3,785
6,886
930
31,580
1,896
369
1,207
215
7,450
6,647
1,575
4,235
881
18,370
13,070
3,498
8,287
1,957
29,650
Amortized
Capital
($l,000/yr)
331
112
186
61
1,322
628
225
349
116
2,077
846
314
457
161
2,554

2,780
625
1,194
154
5,845
3,560
833
1,515
205
6,948
417
81
265
47
1,639
1,462
347
932
194
4,041
2,875
769
1,823
430
6,523
Operation
and
Maintenance
($l,000/yr)
52
29
39
18
200
71
46
52
28
425
81
56
58
34
600

161
77
115
0
927
181
92
129
0
1,236
65
24
51
16
179
117 .
59
94
38
806
161
94
129
61
1,790
Energy
($l,000/yr)
137
117
71
51
134
291
249
150
108
285
411
351
212
152
402

889
612
92
0
1,125
1,185
816
123
0
1,500
105
85
61
41
220
475
384
276
186
990
1,055
854
614
413
2,200
Total
Annual
($1,000)
520
258
296
130
1,656
990
520
551
252
2,787
1,338
721
727
347
3,556

3,830
1,314
1,401
154
7,897
4,926
1,741
1,767
205
9,684
587
190
377
104
2,038
2,054
790
1,302
418
5,837
4,091
1,717
2,566
904
10,513
'Control:

  I - Modification of Activated Sludge at NSPS Option 1 (equal to BPT) raw waste loads
 II - Modification of ASB at N'SPS Option 1 (equal to BPT)  raw waste loads
III - Modification of Activated Sludge at NSPS Option 2 raw waste loads
 IV - Modification of ASB at NSPS Option 2 raw waste loads
  V - Change chemical base and add recovery system

^Includes  Papergrade Sulfite (Blow Pit Wash)  and Papergrade Sulfite (Drum Wash) subcategories
                                                      581

-------
reported  at   $0.088/kg   ($0.04/lb),   and   $0.154/kg   ($0.07/lb),
respectively.   At  this  cost  penalty  of  $0.066/kg  ($0.03/lb), an
increased cost of $5.50/kkg ($5/ton) of pulp  is  realized.   No  cost
credit was taken for the recovery or resale of chemicals.

EPA  also  developed costs for ammonia removal through the application
of end-of-pipe treatment.  EPA assumed that BPT  effluent  limitations
are being met at existing mills through the use of the technology that
formed the basis of BPT effluent limitations.  The Agency also assumed
that  existing  biological treatment systems would be converted to the
extended aeration mode of activated sludge.  Ammonia removal would  be
accomplished through single-stage nitrification.  Nitrification is the
process  where  specific  bacteria convert ammonia to nitrite nitrogen
and  then  to  nitrate  nitrogen  (see  Section  VII).    Conventional
activated  sludge  systems  and  aerated  stabilization  basins can be
converted to  the  extended  aeration  mode  by  system  modification.
Design  criteria include a volumetric loading of 0.24 kg BOD5/cu m/day
(15 Ib BOD5/1000 ftVday), air  requirements  of  1.5  kg  02/kg  BOD5_
removed  (T.5 Ib 02_/lb BOD5_ removed) and 3.1 kg 02_/kg NH3_ removed (3.1
Ib 02/lb NH3_ removed), aeration capacity of 17  kg  02_/hp/day  (37  Ib
02/hp/day),  and  a  48 hour aeration basin detention time.  All other
criteria are equivalent to those considered in estimating the cost  of
activated  sludge  systems  in  developing  estimates  of  the cost of
attainment of BPT effluent limitations.(48) The sludge  ages  for  the
modified biological treatment systems range from 24 to 37 days for the
four subcategories of concern (dissolving sulfite pulp, semi-chemical,
and  both  papergrade  sulfite  subcategories).   They are two to five
times greater than those cited in the literature (see Section VII).

Table A-9 presents the estimated costs to implement  this  end-of-pipe
technology.   The  costs  include  an  allowance  for repositioning of
existing aeration equipment in the aeration  basin.   Table  A-9  also
presents an estimate of costs assuming that conventional pollutant raw
waste load reductions to NSPS Option 2 levels were implemented.  These
estimates assume no reduction in the ammonia raw waste load.

The   sensitivity   of  the  nitrification  process  to  environmental
conditions is well documented (see Section VII).  Temperature, pH, and
dissolved oxygen levels have interrelated effects on the ability of  a
biological treatment system to nitrify ammonia.  The cost estimates in
Table A-9 do not include provisions to heat or cool the effluent or to
cover the aeration basin for temperature control.

COSTS FOR IMPLEMENTATION OF PSES AND PSNS

The  toxic pollutants zinc, trichlorophenol, and pentachlorophenol can
be controlled at new and existing indirect discharging  mills  through
substitution   of   process   chemicals.    Slimicide   and  fungicide
formulations containing chlorophenolics can be replaced by those  that
do  not  contain  these  compounds.   Inquiries  of chemical suppliers
indicate that no definable  cost  differences  will  result  from  the
application of this technology.
                                 582

-------
EPA estimated the cost of substitution of sodium hydrosulfite for zinc
hydrosulfite at indirect discharging mills.  These costs are presented
in Table A-l0.

COSTS FOR IMPLEMENTATION OF NSPS CONTROL AND TREATMENT OPTIONS

Conventional Pollutant Removal

Option  ]_.   NSPS Option 1  for conventional pollutant control is based
on the levels attained by best performing mills in  each  subcategory.
Best  mill  performance  for  a  subcategory  is generally the average
performance at all mills where BPT is attained  using  BPT  technology
(see   Section  VIII).   End-of-pipe  treatment  is  in  the  form  of
biological   treatment    for    all    subcategories    except    the
nonintegrated-tissue papers, nonintegrated-filter and nonwoven papers,
nonintegrated-lightweight    papers,    and   nonintegrated-paperboard
subcategories,  where  end-of-pipe  treatment  is  in  the   form   of
chemically  assisted  primary  clarification  (at a dosage rate of 150
mg/1 of alum).  The design basis of this option is presented in  Table
A-ll.   Costs  associated  with  implementation  of  this  option  are
presented in Table A-l2.

Option 2^  This option involves  the  application  of  (a)  production
process controls to reduce wastewater discharge and raw waste loadings
and  (b) end-of-pipe treatment in the form of biological treatment for
all   subcategories   except    the    nonintegrated-tissue    papers,
nonintegrated-filter  and  nonwoven  papers, nonintegrated-lightweight
papers, and nonintegrated-paperboard subcategories, where  end-of-pipe
treatment  is in the form of chemically assisted primary clarification
(at a dosage rate of 150 mg/1 of alum).   The  design  basis  of  NSPS
Option  2  end-of-pipe treatment is the same as for NSPS Option 1.  As
discussed earlier, the implementation of production  process  controls
can result in material and energy savings.  EPA estimated the economic
savings  associated  with the in-plant controls that form the basis of
NSPS Option 2.  These estimates are presented in Table A-l3.  Improved
by-product recovery may also result; however, no estimates of  savings
resulting  from  by-product  recovery  were  included  in  the figures
presented in Table A-l3.  NSPS Option 2 model mill costs are presented
in Table A-l4.

Example calculations for the costs of NSPS Option 2 production process
controls for a new alkaline-fine mill are  presented  in  Table  A-l5.
Tables  A-l6  and  A-l7  present  example  design  parameters and cost
calculations, respectively, for NSPS Option  2  end-of-pipe  treatment
for a new dissolving kraft mill.

Toxic Pollutant Removal

PCP,  TCP,  and zinc can be controlled at new sources through chemical
substitution.    Slimicide   and   biocide   formulations   containing
chlorophenolics  can be replaced with formulations that do not contain
these toxic pollutants.  Correspondence with chemical suppliers as  to
the relative cost of substitution to the use of process chemicals that
                                583

-------
                                      TABLE A-10

                      COSTS FOR SUBSTITUTING SODIUM HYDROSULFITE
                                 FOR ZINC HYDROSULFITE
Subcategory
 Mill
 Size
(kkg/d)
Sodium Hydrosulfite Used
(kg/kkg)	(kkg/yr)
            Cost Increase Due
            to Substitution
              ($1.000/yr)
PSES, PSNS (Indirect Dischargers - Existing and New)
Groundwood-Thermo-Mechanical

Groundwood-CMN Papers



Groundwood-Fine Papers



NSPS (Direct Dischargers - New)

Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
   272

    45
   544
   907

    68
   454
   680
   454
   454
   454
  1.0

  3.7



  6.7
  1.0
  3.7
  6.7
   95.2

   58.9
  712.5
1,188.0

  160.8
1,073.8
1,608.3
  158.9
  594.6
1,073.8
 37.8

 23.3
279.1
465.2

 63.4
422.6
633.8
 63.0
232.6
422.6
                                             584

-------
                                  TABLE A-11

                                 DESIGN BASIS
       FOR ESTIMATES OF COSTS OF END-OF-PIPE TREATMENT FOR ATTAINMENT OF
                             NSPS OPTIONS 1 AND 2
I.   Integrated Segment and Peink and Nonintegrated-Fine Papers Subcategories

A.   Primary Treatment

     1.   Clarification at an overflow rate of 20 cu ra/d/sq ra

B.   Activated Sludge Treatment

     1.   Equalization with aeration

          a.   12 hr detention at peak flow

     2.   Increase in aeration basin capacity with:

          a.   Aeration design requirements of:
               1.5 kg 0 /kg BOD5
               11.2 kg 62/aerator hp/d

          b.   Detention at 1.5 times BPT levels
          c.   Provisions for operation in a contact stabilization mode

     3.   Clarification at an overflow rate of 16 cu m/d/sq m

     4.   Solids handling system

II.  All Other Secondary Fibers Subcategories(a)

A.   Primary Treatment

     1.   Clarification at an overflow rate of 24 cu m/d/sq m

B.   Activated Sludge Treatment

     1.   Equalization with aeration

          a.   12 hr detention at peak flow

     2.   Aeration basin

          a.   Volume at the larger of 0.8 kg BODS applied/cu m/d, or 8 hr
               hydraulic detection time
          b.   Aeration design requirements of:
               1 kg 02/kg BODS
               19 kg 02/aerator hp/d

     3    Clarification at an overflow rate of 20 cu n/d/sq n

     4.   Solids handling system

III.   All Other Nonintegrated Subcategories

A.   Primary Treatment

     1.   Chemically assisted clarification with 150 mg alun/1 (flash mixing
          prior to clarifiers) at an overflow rate of 16 cu m/d/sq m

     2.   Solids handling system
(a)  End-of-pipe treatment system design for both NSPS Options 1  and 2 are
     based on the flow and BOD5 raw waste load that forms the basis of BPT
     effluent limitations.
                                       585

-------
                                  TABLE  A-12




                        COST SUMMARY FOR NSPS  OPTION
                                                       Operation and
Subcategory
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
o Linerboard
o Bag
Semi-Chemical
Uubleached Kraft and
Semi-Chemical
Dissolving Sulfite Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite2
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Papers
o Tissue Papers
o Newsprint
Mill
Size
(kkg/d)

907
680
454
680
454
907
454
1,361
454
454
454
454
680
454
454
454
454
91
454
454
Maintenance and Total
Capital Energy Annual
($1,000) ($l,000/yr) ($1,000)

32,093
20,388
17,992
20,787
13,060
20,247
13,130
26,709
30,429
31,721
33,404
39,312
37,319
12,219
11,496
11,248
17,131
6,089
17,131
11,171

4,930
2,403
1,918
2,517
1,802
2,825
2,334
3,762
6,059
6,366
6,777
8,251
7,194
1,636
1,357
1,363
3,027
968
3,027
2,343

11,990
6,889
5,876
7,090
4,675
7,280
5,223
9,638
12,753
13,344
14,125
16,899
15,404
4,324
3,886
3,838
6,796
2,307
6,796
4,300
Tissue From Wastepaper
1,384
208
512
                                     5S6

-------
TABLE A- 12
(continued)
Operation and
Mill Maintenance
Size Capital and Energy1
Subcategory (kkg/d) ($1,000) ($l,000/yr)
Total
Annual
($1,000)
Secondary Fibers Segment (continued)
Paperboard From Wastepaper
o Noncorrugating Medium Furnish
o Corrugating Medium Furnish

Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish '
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers
Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter
and Nonwoven Papers
Nonintegrated-Paperboard
91
454

91
454
45
68
136

227
27
45
227
45
45
23
45
2,465
6,146

2,585
6,528
2,271
2,652
3,929

5,889
2,564
2,148
5,711
2,119
2,470
1,307
1,291
299
747

326
842
252
343
492

604
304
371
912
524
600
321
342
842
2,099

895
2,279
752
927
1,356

1,899
868
843
2,169
990
1,144
609
626
Includes Fine Bleached Kraft and Soda subcategories.
2Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash)
 subcategories.
                                          587

-------
                                  TABLE A-13

                      GROSS OPERATION AND MAINTENANCE AND
                         ENERGY COSTS AND SAVINGS FOR
             NSPS OPTION 2 PRODUCTION PROCESS CONTROLS ($l,000/yr)
Subcategory
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine2
Unbleached Kraft
o Linerboard
o Bag
Semi-Chemical
Unbleached Kraft and
Semi-Chemical
Dissolving Sulfite Pulp
Papergrade Sulfite3
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Papers
o Tissue Papers

o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper

Wastepaper-Molded Products
Builders' Paper and
Roofing Felt

Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers

Nonintegrated- Lightweight
Papers
Nonintegrated-Filter and
Nonwoven Papers
Nonintegrated- Paperboard
Mill
Size
(kkg/d)

907
680
454
680

454
907
454

1,361
454
680
454
454
454


454
91
454
454
9
91
454
45

68
136


227
27
45
227

45

23
45
Gross
Operation and
Maintenance1
Cost

230.7
208.3
188. 1
263.7

120.0
183.2
151.4

386.5
922.7
1,130.1
105.2
48.3
131.2


60.9
35.8
97.4
60.9
9.3
24.1
50.6
19.3

17.6
25.8


32.3
9.0
9.7
26.0

29.8

20.2
13.0
Savings

524.3
89.6
185.4
120.2

176.5
350.7
137.2

449.2
776.3
1,172.7
124.5
38.0
299.6


186. 1
37.2
186.1
186.1
1.8
18.0
90.0
0.0

14.0
27.9


38.5
10.8
15.8
78.7

19.0

4.6
6.4
Gross Energy
Cost

691.0
363.3
288.5
309.3

109.3
218.6
204.5

788.9
1,237.4
1,517.0
33.3
40.3
80.5


123.8
29.4
138.2
123.8
4.8
46.3
231.7
11.2

27.5
55.1


48.3
13.5
7.0
33.8

16.5

7.8
5.3
Savings

80.6
55.9
23.1
82.9

119.2
210.6
80.4

336.9
116.9
253.6
20.4
150.8
152.3


112.7
41.8
198.1
112.7
2.2
22.0
110.0
8.4

4.3
8.6


100.2
28.1
8.0
18.6

16.7

11.2
6.2
'Excludes energy costs.
^Includes Fine Bleached  Kraft and Soda subcategories.
•"Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash)
 subcategories.
                                      588

-------
          TABLE A-14
COST SUMMARY  FOR NSPS OPTION 2
Mill
Size
Subcategory (kkg/d)
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
o Linerboard
o Bag
Semi-Chemical
Unbleached Kraft and
Semi -Chemical 1
Cissclviri,{ Euifiti Pulp
o Nitration
o Viscose
o Cellophane
o Acetate
Papergrade Sulfite2
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Croundwood-Fine Papers
Secondary Fibers Segment
Deink
o Fine Papers
o Tissue Papers

o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
o Noncorrugating Medium Furnish

o Corrugating Medium Furnish

Wastepaper-Molded Products
Builders' Paper jnd Hooi'ini< Fell


907
680
ASA
680

ASA
907
ASA

,361

ASA
ASA
ASA
ASA
680
ASA
ASA
ASA


ASA
91
ASA
ASA
9

91
ASA
91
ASA
A5
68
136
Capital
($1,000)

33,102
21.83A
17,699
20,233

8,635
1A.057
9,138

22,250

37,905
38.0A9
39,239
A2.99A
41,705
10,329
9, ASS
11,382


11,536
5,191
1A.055
11,171
1.38A

2.A65
6,1A6
2.585
6,528
2,271
2,652
3,929
Operation
and Total
Maintenance Energy Annual
($l,000/yr) (Sl.OOO/y'r) ($1,000)

3,371
1,742
1,439
1,983

738
1,145
689

1,554

2,369
2,386
2,520
2,947
2,503
1,029
1,073
1,071


2,260
316
2,393
2,185
196





233
301
A!5

1,865
829
665
687

1A6
298
306

968

2.0A8
2,06A
2,208
2,672
2,195
2A6
185
167


2A7
79
346
158
12

2993
7A73
3263
8A23
19
<«2
77

12,518
7,375
5,998
7,121

2.78A
A, 536
3,005

7,417

12,756
12,821
13,361
15,077
13,873
3,547
3,345
3,742


5.0A5
2,037
5,830
A, 800
512

8A2
2,099
895
2,279
752
927
1,356
                 589

-------
                                        TABLE A-14
                                        (continued)
Subcategory
Mill
Size
(kkg/d)
Capital
($1,000)
Operation
and
Maintenance
($l,000/yr)
Energy
($l,000/yr)
Total
Annual
($1,000)
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers

Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter and Nonwoven
Papers
Nonintegrated-Paperboard

227
27
45
227

45
45

23
45

4,339
2,129
1,647
4,077

2,711
3,081

1,698
1,616

504
261
354
835

492
565

310
341

42
18
8
49

14
19

7
7

1,500
747
724
1,781

1,102
1,262

690
704
'Includes Fine Bleached Kraft and Soda subcategories.
2Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash)
 subcategories.
^Separate operation and maintenance and energy costs for the Paperboard From Wastepaper
 subcategory are not presented.   These estimates include updated "pre-BPT" inter-
 nal control costs presented in the Phase I BPT Development Document which reported
 operation and maintenance and energy costs as a single figure.  (46)
                                             590

-------
                                  TABLE A-15

                   NSPS OPTION 2 PRODUCTION PROCESS CONTROLS
                           SAMPLE COST CALCULATIONS
                         680 kkg/d Alkaline-Fine Mill
A.
Item
1
2
3
4
5
6
7
8
9
10

Capital
No. Item
Dry Operation of Woodroom
Disposal of Digester Blow Condensates
Addition of Fourth Stage Brown Stock Washer
Spill Collection for Pulp Mill Brown Stock
Full Countercurrent Washing in Bleachery
Boil Out Tank for Evaporators
Spill Collection in Liquor Preparation Area
Segregation of Cooling Water in Utility Area
Boiler Slowdown and Backwash Lagoon
pH Monitors on Sewers

Cost
$1,433,300
24,200
838,000
300,000
2,731,000
46,400
349,000
69,700
124,800
8,000
$5,924,400
B.   Energy Requirements
Item No.
Item
   Increase
in Electricity
     Use
  (kwh/kkg)
Reduction or
  Increase
in Steam Use
 (kg/kkg)
1
2
3
4
5
6
7
8
9
10





Dry Operation of Woodroom
Disposal of Digester Blow Condensates
Addition of Fourth Stage Brown Stock Washer
Spill Collection for Pulp Mill Brown Stock
Full Countercurrent Washing in Bleachery
Boil Out Tank for Evaporators
Spill collection in Liquor Preparation Area
Segregation of Cooling Water in Utility Area
Boiler Slowdown and Backwash Lagoon
pH Monitors on Sewers


Cost of Electric Power = $0.0325/kwh x 16.35
Steam Saving = 107.9 kg/kkg x 2425 Btu/kg x
Net Increase in Cost of Energy =
__
1.22
7.70
2.48
2.15
0.46
1.55
0.33
0.46
--
16.35

kwh/kkg =
$1.24/106Btu

(48.7)
--
--
--
(33.6)
--
(4.8)
(20.8)
--
--
(107.9)
Cost
$ 0.53/kkg
= - 0.32/kkg
$ 0.21/kkg
C.    Annual Cost-Example

   3    Addition of Fourth Stage Brown Stock Washer

        Fixed Cost = 22% of $838,000
        Maintenance = 4.5% of capital
        Added Labor
        Electric Power = 233 kw x 24 hr/d x 352 d/yr
                                          x $0.0325/kwh
                                              Cost

                                            $ 184,360
                                               37,710
                                                    0

                                               63,972
                                            $ 286,042
                                      591

-------
                                  TABLE A-16

                      DESIGN PARAMETERS FOR .VSPS OPTION 2
                              EXAMPLE CALCULATION

                        907 kkg/d Dissolving Kraft Mill
Raw Waste:

     Flow = 211.6 kl/kkg
     BOD5 =  58.4 kg/kkg
     TSS  =113.0 kg/kkg

Design Parameters:

     Flow:
       907 kkg/d x 211.6 kl/kkg x 1 cu m/kl = 191,000 cu m/d

     BOD5 Removed (assume 15 percent of BOD5 is removed in primary
     system; therefore, 85 percent of BOD5 applied will be removed by biological
     system):
       907 kkg/d x 0.85 x 58.4 kg BOD5/kkg = 45,000 kg BOD5/d

Basin Volumes (assume 0.8 kg BOD5/cu m):
     Stabilization = 907 kkg/d x 58.4 kg BOD5/kkg x 1.25 cu m/kg BOD5 = 66,200 cu m
     Contact = one-half stabilization = 0.5 x 66,200 cu m = 33,100 cu m

Aeration (assume 11.2 kg BOD5/d/HP):
     907 kkg/d x 58.4 kg BOD5/kkg x 0.0893 HP/kg BOD5 = 4,730 HP

Solids Production:
     Primary (assume 75 percent of raw waste TSS applied is removed):
          0.75 x 907 kg/d x 113.0 kg TSS/kkg = 76,900 kg/d
     Biological (assume additional 10 percent of raw waste TSS is removed and
     32 percent of BOD5 applied becomes solids):
          907 kkg/d x [(0.10 x 113.0 kg TSS/kkg) + (0.32 x 58.4 kg BOD5/kkg)]
          = 27,200 kg/d
                                    592

-------
                                         TABLE A-17

                               COST SUMMARY FOR NSPS OPTION 2
                             UNIT PROCESS END-OF-PIPE TREATMENT
                                     EXAMPLE CALCULATION

                               907 kkg/d Dissolving Kraft Mill
Treatment
                         Operation
           Amortized        and                    Total
 Capital    Capital      Maintenance    Energy        Annual
($1,000)  ($1.0QO/yr)   ($l,QOO/yr)  ($l,000/yr)    ($1.000)
Flow Equalization with Aeration
  (peaking factor = 1.3)
Wastewater Pumping (peaking
  factor = 1.3}
Preliminary Treatment
Primary Settling
Acid Neutralization
Alkaline Neutralization
NaOH For Biological Treatment
Stabilization Basin
Contact Basin
Aeration
Secondary Clarification
Flow Monitoring
Outfall
Diffuser
Foam Collection Tank
Nutrient Addition
Flotation Polymer
Flotation Thickening
Dewatering Polymer
Horizontal Belt-Filter
Primary and Biological Sludge
  Transportation
Primary and Biological Sludge
  Landfill

     Subtotal
  1,591
              350
                            19
                                         66
435
1,744
328
3,969
55
55
0
3,061
1,758
3,312
6,427
43
23
414
92
0
0
1,552
0
2,218
0
1,202
27,843
384
72
873
12
12
0
673
387
729
1,314
10
5
91
20
0
0
342
0
488
0
264
6,125
25
27
51
22
22
223
94
71
0
74
63
0
0
0
417
218
61
828
91
789
274
3,371
112
0
5
10
10
0
0
0
946
38
0
0
0
0
0
0
55
0
13
0
0
1,255
520
99
929
44
44
223
768
458
1,675
1,525
73
5
91
20
417
218
458
828
592
789
539
10,751
                                             593

-------
do  not contain these toxic pollutants indicate that no definable cost
difference  will  result  from  the  implementation  of  this  control
technology.

Zinc  can  be  controlled  at new source groundwood mills by replacing
zinc hydrosulfite,  a bleaching  chemical,  with  sodium  hydrosulfite.
The  costs of this substitution at new sources in the three groundwood
subcategories are presented in Table A-10.

ENERGY AND NON-WATER QUALITY IMPACTS

Energy Requirements

EPA anticipates that the implementation of some of the various control
and treatment options considered as the basis  of  final  rules  could
affect  existing  energy demand.  Estimates of the energy requirements
of each specific technology option are presented in this section.   In
some  cases,  the  implementation  of  production process controls may
result in a net energy saving.  It is possible that, even where a  net
energy  saving  is  achieved in terms of net heat energy, energy costs
can increase because of the relative amounts of fuels and  electricity
used and their respective prices.

EPA  determined  total  energy  usage  prior  to implementation of the
various technology options  (baseline  energy  usage)  based  on  data
contained  in  the API monthly energy reports.  Average power and fuel
usages were determined from information obtained as a  result  of  the
data  request program.  An energy balance was developed for each model
mill;  the balance takes into account the energy of  spent  liquor  and
hogged fuel, if appropriate.

Table  A-18  summarizes  the  estimate  of total energy used at direct
discharging mills.   Total energy is presented  in  heat  energy  units
(Btu).   In  order  to  properly  account for energy requirements, EPA
converted electrical energy (kwh) to heat energy (Btu) at a conversion
of 10,500 Btu/kwh,  which reflects the average efficiency of electrical
power generation.

BPT.  EPA estimates that attainment of BPT  in  the  wastepaper-molded
products  subcategory  will  require  the  use  of  the  equivalent of
approximately 604 thousand liters (3.8 thousand barrels)  of  residual
fuel  oil  per  year,  a  0.0017 percent increase in estimated current
industry energy usage and a 1.8 percent  increase  in  current  energy
usage at mills in the wastepaper-molded products subcategory.  For the
nonintegrated-lightweight  papers,  nonintegrated-filter  and nonwoven
papers, and nonintegrated-paperboard subcategory and the cotton  fiber
furnish  subdivision  of  the  nonintegrated-fine  papers subcategory,
in-place technology or current permit conditions  are  such  that  EPA
anticipates   that  no  incremental  energy  usage  will  result  from
implementation of BPT effluent limitations.
                                594

-------
                                  TABLE A-18

            TOTAL ENERGY USAGE AT EXISTING DIRECT DISCHARGING MILLS
                                 (109 Btu/yr)
Subcategory
  Baseline1
Integrated Segment

Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine2
Unbleached Kraft
  o Linerboard
  o Bag
Semi-Chemical
Unbleached Kraft and
  Semi-Chemical
Dissolving Sulfite Pulp
Papergrade Sulfite3
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
Integrated-Miseellaneous

Secondary Fibers Segment

Deink
  o Fine Papers
  o Tissue Papers
Tissue From Wastepaper
Paperboard From Wastepaper
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Secondary Fibers-Miscellaneous

Nonintegrated Segment

Nonintegrated-Fine Papers
Nonintegrated-Tissue Papers
Nonintegrated-Lightweight Papers
Nonintegrated-Filter and
  Nonwoven Papers
Nonintegrated-Paperboard
Nonintegrated-Miseellaneous

Total
Residual Fuel Oil
 (106 barrels/yr)
   50,538
   68,856
   87,326
  128,775

  139,382
   86,048
   51,786

  124,954
   40,529
   56,305
    3,628
    9,061
   17,301
  454,353
    3,486
    8,715
    2,634
   30,725
    1,345
    1,705
    7,425
   27,947
    7,639
    6,777

      796
    1,362
    6,066

1,425,464

      227
Baseline energy use is based on data contained in API monthly energy reports.
2Includes Fine Bleached Kraft and Soda subcategories.
3Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash)
 subcategories.
                                      595

-------
BAT.  Because the technology basis  of  BAT  effluent  limitations  is
chemical  substitution,  implementation  of BAT will not result in any
increase in energy usage at existing direct discharging mills.

EPA estimates that implementation of chloroform removal technology  at
the  nine mills where closed biological treatment systems are employed
would increase the energy used to operate wastewater treatment systems
by over 70 percent.

If color were regulated based on the technologies discussed in Section
VIII, energy usage  would  increase  at  existing  direct  discharging
mills.   Table A-19 presents the Agency's estimate of the total energy
increase that  would  result  from  implementation  of  color  removal
technology  at  all  direct  discharging  mills  where  highly-colored
effluents are discharged.  EPA estimates that the energy increase over
current total energy usage at these mills would be equivalent to about
2.5 percent for minimum lime coagulation  and  0.5  percent  for  alum
coagulation.

Establishment of ammonia limits at the eight mills where ammonia-based
cooking  chemicals  are  employed might mean that the equivalent of 78
million liters (489 thousand  barrels)  and  44  million  liters  (277
thousand  barrels)  of residual fuel oil per year, respectively, would
be required  through  conversion  to  a  different  chemical  base  or
modification   of  existing  biological  treatment  to  operate  in  a
nitrification mode (assuming that raw waste  loads  are  identical  to
those  that formed the basis of BPT limitations).  This represents 6.2
and 3.5 percent, respectively, of current energy usage at these  eight
mills.

NSPS.   Table  A-20 presents an estimate of energy usage at new source
direct discharging mills for the base case (attainment of BPT effluent
limitations) and for NSPS Options 1  and  2.   In  order  to  properly
account  for  energy  requirements  of each alternative, EPA converted
electrical energy  (kwh) to heat energy (Btu) at a conversion of 10,500
Btu/kwh, which reflects the average  efficiency  of  electrical  power
generation.

Pretreatment Standards.  Because the technology basis of PSES and PSNS
is  chemical  substitution,  implementation  of PSES and PSNS will not
increase energy usage at indirect discharging mills.

Air Pollution

None of the technology options considered for BPT, BAT, NSPS, PSES, or
PSNS are expected  to result in significant increases in air pollution.
The technologies that form the bases of BAT effluent  limitations  and
pretreatment  standards  do  not generate air emissions.  Operation of
biological and primary treatment systems to comply with  BPT  effluent
limitations  and NSPS will not generally increase air emissions to any
significant extent.
                               596

-------
                                  TABLE A-19

         ADDITIONAL ENERGY USAGE AT EXISTING DIRECT DISCHARGING MILLS
              WITH THE IMPLEMENTATION OF COLOR REMOVAL TECHNOLOGY
                                 (109 Btu/yr)
Subcategory
  Baseline
  Lime
 Alum
Integrated Segment

Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine1
Unbleached Kraft
  o Linerboard
  o Bag
Semi-Chemical
Unbleached Kraft and
  Semi-Chemical
Dissolving Sulfite Pulp
Papergrade Sulfite2
Integrated-Miscellaneous
   50,538
   68,856
   87,326
  128,775

  139,382
   86,048
   51,786

  124,954
   40,529
   56,305
  413,779
 1,312
 1,348
 1,533
 2,439

 3,708
 2,289
 1,595

 3,828
 1,354
 1,810
 8,994
  262
  385
  378
  548

  323
  199
  178

1,066
  279
  362
1,922
Total
Residual Fuel Oil
 (106 barrels/yr)
1,248,278
      198
30,210
     5
5,902
    0.9
Includes Fine Bleached Kraft and Soda subcategories.
2Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash)
 subcategories.
                                        597

-------
                                         TABLE A-20
                     ENERGY USAGE AT NEW SOURCE DIRECT DISCHARGING MILLS
Mill
Size
Subcategory Ckkg/d)
Integrated Segment
Dissolving Kraft
Market Bleached Kraft
BCT Bleached Kraft
Alkaline-Fine2
Unbleached Kraft
o Linerboard
o Bag
Semi-Chemical
Unbleached Kraft and
Semi-Chemical 1
Dissolving Sulfite Pulp
Papergrade Sulfite2
Groundwood-Thermo-Mechanical
Groundwood-CMN Papers
Groundwood-Fine Papers
Secondary Fibers Segment
Deink
o 7iue Papers
o Tissue Papers

o Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
o Noncorrugating Medium Furnish

o Corrugating Medium Furnish

Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonintegrated Segment
Nonintegrated-Fine Papers
o Wood Fiber Furnish
o Cotton Fiber Furnish
Nonintegrated-Tissue Papers

Nonintegrated-Lightweight Papers
o Lightweight
o Electrical
Nonintegrated-Filter and
Nonwoven Papers
Nonintegrated-Paperboard

907
680
454
680

454
907
454

,361
454
680
454
454
454


••54
91
454
454
9

91
454
91
454
45
136


227
27
45
227

45
45

23
45
Energy Usage (109 Btu/yr)
Baseline1

14,886
8,178
6,163
9,303

4,876
9,752
4,050

10,364
6,824
9,696
4,134
5,316
4,968


3,17o
635
3,176
3,079
45

623
3,115
625
3,126
237
785


1,010
122
415
2,075

572
572

240
409
\SPS
Option 1

456
209
141
182

62
120
82

198
431
443
130
73
69


154
34
154
51
4

17
84
19
95
6
25


19
7
3
12

5
7

T
2
NSPS
Option 2

603
268
215
222

47
96
99

313
726
369
709
60
54


80
26
112
51
4

17
84
19
95
6
25


14
6
3
16

5
6

2
2
'Baseline energy use is based on data contained in API monthly energy reports
 and BPT Development Documents.
''Includes Fine Bleached Kraft and Soda subcategories.
3Includes Papergradn Sulfite (Bl^w Pit Wash) and Papergrade Suil'ite (Drum Wash)
 subcategories .
                                               598

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Most of the NSPS production process controls identified in NSPS Option
2 are  expected  to  have  little  direct  impact  on  air  emissions.
However,  if  additional  steam  is  required,  some increase in sulfur
dioxide generation could occur.  Such an increase  would  be  directly
proportional  to  the  increased  boiler  firing  rate  and the sulfur
content of the fuel used.  This situation is not unique to  the  pulp,
paper,   and  paperboard  industry,  but  exists  for  all  industrial
categories.   Air  pollution  control  techniques  are  available   to
minimize such increases.

Production  process controls that help retain more spent liquor in the
liquor recovery cycle include improved  brown  stock  washing,  decker
filtrate  reuse,  use  of  blow  condensates,  neutralization of spent
sulfite liquor before evaporation,  and more complete use of evaporator
condensates.  These controls tend  to  retain  more  sulfur-containing
compounds  in the liquor system.  As sulfur levels increase along with
increased total liquor solids to  recovery,  emissions  can  increase.
With  modern recovery systems of adequate capacity, emission levels of
mercaptans, hydrogen sulfide, and other compounds  to  the  atmosphere
would  not  increase  beyond  allowable limits.  Generally, the normal
variations in firing rates, sulfidity, and  liquor  solids  overshadow
the  effects  resulting  from implementation of the production process
controls considered.

Noise Potential

There is no identifiable potential  for substantially  increased  noise
associated  with  any  of the control and treatment technology options
considered.   Existing  effluent  treatment  processes   are   not   a
significant source of noise.

Solid Waste Generation

General.   A  study by Energy Resources Company quantified the various
solid wastes generated in 1977 in  the  pulp,  paper,  and  paperboard
industry.(221)  In  addition  to  sludge  generated  as  a  result  of
wastewater treatment, other types of solid  waste  generated  by  this
industry include chemical ash, pulping wastes,  and wood wastes.

The  kraft  and  sulfite  processes  produce  the majority of chemical
pulping wastes, consisting of green liquor dregs, lime wastes  (slaker
rejects  and  unburned  rejects from lime kilns), and cooking chemical
recovery process wastes.  Green liquor dregs are normally sewered and,
therefore, are likely to be included in wastewater  sludge  estimates.
Lime  wastes  and  recovery  wastes  (normally  oxides  of the cooking
chemical base from the sulfite process) were estimated to  be  535,000
metric tons (589,000 tons) in 1977. (221)

About  2,700,000  metric  tons (3,000,000 tons) of landfilled bark and
wood waste and approximately 1,000,000 metric tons (1,100,000 tons) of
coal ash were generated in 1977.(221)
                                599

-------
Miscellaneous  pulp,  paper,   and  paperboard  industry  solid   waste
included   1,700,000   metric  tons  (1,900,000  tons)  of  wastepaper
reclamation  waste  (i.e.,   strapping,   dirt,  metal,  and   ink)   in
1977.(221)  Other  wastes  include  evaporator  residue  and  tall oil
residue; these are generated in insignificant quantities when compared
to other solid wastes.   Total  1977  process  solid  waste  excluding
wastewater treatment sludge was about 5,900,000 metric tons (6,500,000
tons).

In  a  1974  study,  it was estimated that pulp,  paper, and paperboard
industry personnel generated about 0.23 kg  (0.5  Ib)  of  refuse  per
employee  per  shift,   resulting in a total annual industry generation
rate of 16,600 metric tons (18,300 tons).(48)  This  source  of  solid
waste is insignificant when compared to process-related sources.

Wastewater  treatment  facilities  produce both primary and biological
sludges that are usually dewatered prior to disposal.  The  amount  of
wastewater   treatment   sludge  generated  depends  on  a  number  of
conditions  including:  (a)  raw  waste   characteristics,   (b)   the
existence,  efficiency, and/or type of primary treatment, (c) the type
of biological treatment system employed, and  (d)  the  efficiency  of
biological  solids  removal  from  the  wastewater.  EPA estimated the
amount  of  primary  and  biological  sludges  generated   at   direct
discharging  mills in each subcategory.  These estimates were based on
sludge production criteria outlined in Section VII and  are  shown  in
Table A-21.

Toxic  Pollutant Control.  Chemical substitution, the technology basis
of BAT, PSES, PSNS, and NSPS toxic pollutant control options will  not
result  in  any  increase  in  solid  waste generation.  Additionally,
implementation of chloroform removal  technology  at  the  nine  mills
where  closed  systems  are  employed  would  not increase solid waste
generation at these mills.

Conventional Pollutant Control.  Attainment of BPT in the  wastepaper-
molded products subcategory may generate an additional 100 kkg/yr (110
tons/yr)  of  solid waste.   This is equal to 0.0042 percent of current
wastewater treatment solids generated in the industry and  20  percent
of  the  current  wastewater solids generated in the wastepaper-molded
products subcategory.

For the  nonintegrated-lightweight  papers,  nonintegrated-filter  and
nonwoven  papers,  and  nonintegrated-paperboard subcategories and the
cotton fiber furnish  subdivision  of  the  nonintegrated-fine  papers
subcategory, in-place technology or current permit conditions are such
that  EPA  anticipates that no incremental solid waste generation will
result from implementation of BPT effluent limitations.

Table A-22 presents an estimate of the solid waste generation  at  new
source  direct  discharging mills for the base case  (attainment of BPT
effluent limitations)  and for NSPS Options 1 and 2.
                                 600

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                                  TABLE A-21

                  TOTAL WASTEWATER SOLID WASTE GENERATION AT
                       EXISTING DIRECT DISCHARGING MILLS
                          (1,000 kkg/yr, dry solids)
                                                         Baseline1
Subcategory	Primary	Biological

Integrated Segment

Dissolving Kraft                                    91.0          35.3
Market Bleached Kraft                               65.2          32.6
BCT Bleached Kraft                                 112.6          43.0
Alkaline-Fine2                                     199.1          65.0
Unbleached Kraft
  o Linerboard                                      81.6          35.7
  o Bag                                             50.4          22.0
Serai-Chemical                                       23.4          22.6
Unbleached Kraft and
  Serai-Chemical                                     71.7          36.5
Dissolving Sulfite Pulp                             68.7          65.0
Papergrade Sulfite3                                118.3          64.8
Groundwood-Thermo-Mechanical                         6.6           3.4
Groundwood-CMN Papers                               19.2           5.2
Groundwood-Fine Papers                              38.9           9.9
Integrated-Miscellaneous                           543.2         213.5

Secondary Fibers Segment

Deink
  o Fine Papers                                     26.7           5.7
  o Tissue Papers                                   66.7          14.0
Tissue from Wastepaper                              10.2           1.5
Paperboard from Wastepaper                          17.4           5.6
Wastepaper-Molded Products                           0.5           0.1
Builders' Paper and Roofing Felt                     3.3           0.7
Secondary Fibers-Miscellaneous                      17.6           3.7

Nonintegrated Segment

Nonintegrated-Fine Papers                           34.4           6.5
Nonintegrated-Tissue Papers                         10.9           0
Nonintegrated-Lightweight Papers                     8.1           0
Nonintegrated-Filter and
  Nonwoven Papers                                    0.5           0
Nonintegrated-Paperboard                             1.5           0
Nonintegrated-Miscellaneous                          7.8           0.5

Total                                            1,695.5         692.8

1Baseline wastewater solid waste production is based on estimated BPT raw
 waste loads; baseline solid waste other than wastewater solids is 6,016,600
 kkg/yr.
2Includes Fine Bleached Kraft and Soda subcategories.
3Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash)
 subcategories.

                                     601

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                                          TABLE A-22
                           WASTEWATER SOLID WASTE GENERATION AT NEW
                                SOURCE DIRECT DISCHARGING MILLS
Subcategory
 Mill      Waatewater Solid Waste Generation (1,000 kkg/yr)
 Size                             NSPS              NSPS
(kkg/d)	Baseline1	Option 1	Option 2
Integrated Segment

Dissolving Kraft                    907
Market Bleached Kraft               680
BCT Bleached Kraft                  454
Alkaline-Fine2                      680
Unbleached Kraft
  o Linerboard                      454
  o Bag                             907
Semi-Chemical                       454
Unbleached Kraft and
  Semi-Chemical                   1,361
Dissolving Sulfite Pulp             454
Papergrade Sulfite3                 680
Groundwood-Therrao-Mechanical        454
Groundwood-CMN Papers               454
Groundwood-Fine Papers              454

Secondary Fibers Segment
                                                   37.9
                                                   11.9
                                                   11.2
                                                   17.9
                                                   11.8
                                                   22.6
                                                   27.2
                                                    7.7
                                                    7.9
                                                    8.4
                                  38.8
                                  12.7
                                  11.6
                                  18.7

                                   4.2
                                   8.3
                                   3.4

                                  12.4
                                  23.9
                                  28.2
                                   8.0
                                   8.2
                                   8.7
                                   37.1
                                   11.2
                                   11.0
                                   17.4

                                    3.8
                                    7.5
                                    2.7
                                   11.3
                                   17.7
                                   24.7
                                    6.8
                                    7.8
                                    8.2
  o Fine Papers
  o Tissue Papers

  o  Newsprint
Tissue From Wastepaper
Paperboard From Wastepaper
  o Noncorrugating Furnish

  o Corrugating Furnish

Wastepaper-Molded Products
Builders' Paper and
  Roofing Felt

N'onintegrated Segment

Nonintegrated-Fine Papers
  o Wood Fiber Furnish
   o Cotton Fiber Furnish
Nonintegrated-Tissue Papers

Nonintegrated-Lightweight Papers
  o Lightweight
  o Electrical
Monintegrateri-Filter and
  Nonwoven Papers
Nonintegrated-Paperboard
  454
   91
  454
  454
    9

   91
  454
   91
  454
   45

  136
  227
   27
   45
  227

   45
   23
   45
29.9
 6.0
29.9
29.9
 0.28

 0.34
 1.7
 0.40
 2.0
 0.22

 1.5
 2.3
 0.51
 0.43
 2.1

 0.66
 0.66
 0. 13
 0.27
                                                                    30.4
                                                                     6.1
                                                                    30.3
                                                                    28.1
                                                                     0.28

                                                                     0.35
                                                                     2.0
                                                                     0.43
                                                                     2.1
                                                                     0.21

                                                                     1.4
                                                                     2.5
                                                                     0.54
                                                                     0.55
                                                                     2.7

                                                                     0.95
                                                                     1.0

                                                                     0.22
                                                                     0.41
28.6
 5.8
29.2
28.1
 0.28

 0.35
 2.0
 0.43
 2. 1
 0.21

 1.4
 2.3
 0.49
 0.53
 2.7

 0.92
 0.99

 0.21
 0.41
 'Baseline wastewater solid waste generation is based on estimated BPT raw waste loads.
 ^Includes Fine Bleached Kraft and Soda subcategories.
 •'Includes Pjpprgrade Sulfite  ;Elow Pit Wash; anJ Papcrgrade Sulfite (Drum Wash)
 subcategories.
                                                  602

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Nonconventional Pollutants.  If color  were  regulated  based  on  the
technologies  discussed  in Section VIII, solid waste generation would
increase at existing direct discharging mills.   Table  A-23  presents
the  Agency's estimate of the total increase in solid waste that would
result from implementation of color removal technology at  all  direct
discharging mills where highly-colored effluents are discharged.

EPA  estimates  that  implementation  of  ammonia  removal  technology
(conversion to a different chemical base or modification  of  existing
biological  treatment  to  operate  in a nitrification mode) would not
result in any measurable increase in solid waste generation.

Disposal Methods.  Acceptable  techniques  for  solid  waste  disposal
include   incineration,  composting,  pyrolysis  -  gasification,  and
landfill.  McKeown  reported  that,  in  1975,  about  10  percent  of
wastewater sludges were incinerated and about 85 percent were disposed
of  by  land  application.(222) Incineration is a preferred method for
disposal of organic wastes with low  moisture  contents  such  as  log
sorting and mill yard wastes.

Composting  is  an  emerging  technology  that  theoretically could be
applied to pulp,  paper,  and  paperboard  mill  wastewater  treatment
sludges.   Through  proper  composting,  sludge  can  be  converted to
non-pathogenic  organic  material  that  may  be  used   as   a   soil
conditioner.

Pyrolysis-gasification may play a future role in solid waste disposal.
Commercial-scale  units  from  which  economic  effectiveness has been
proven or operating experience obtained have yet to be utilized.

Land application of wastewater treatment plant  sludges  is  a  viable
disposal  option.   Sludge can be applied to a field that will be used
for agricultural production.  The organics, nutrients, and sludge bulk
can serve to enhance crop production capacity.  A prerequisite for the
technique is that adequate and suitable land  is  available  within  a
reasonable proximity of the plant.

Landfills  are the most prevalent means of solid waste disposal in the
industry.  The primary environmental problem associated with  landfill
disposal   of   wastewater  sludges  is  the  potential  for  leachate
contamination of ground and surface waters.

Environmental safety procedures and knowledge  of  proper  landfill ing
practices  have  increased  widely  in  recent  years.   The  EPA  has
established  operating  and  design  criteria  for  several   landfill
techniques  for  sludges  ranging  from  20 to 30 percent solids.(216)
These techniques include a) area fill layer, b) area  fill  mound,  c)
diked  containment,  d)  narrow trench, e) wide trench, f) co-disposal
with soil, and  g)  co-disposal  with  refuse.   The  cited  reference
describes required site and operating conditions for each method.
                                603

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                                  TABLE A-23

                 ADDITIONAL WASTEWATER SOLID WASTE GENERATION
                     AT DIRECT DISCHARGING MILLS WITH THE
                  IMPLEMENTATION OF COLOR REMOVAL TECHNOLOGY
                                (1,000 kkg/yr)
Subcategory	Baseline	Lime	Alum	

Integrated Segment

Dissolving Kraft                  126.3             36.0         31.6
Market Bleached Kraft              97.8             35.7         37.0
BCT Bleached Kraft                155.6             41.6         41.3
Alkaline-Fine1                    264.1             65.3         62.5
Unbleached Kraft
  o Linerboard                    117.3             98.5         29.4
  o Bag                            72.4             60.8         18.2
Serai-Chemical                      46.0             40.2         11.0
Unbleached Kraft and
  Semi-Chemical                   108.2            102.7         29.1
Dissolving Sulfite Pulp           133.7             35.8         28.7
Papergrade Sulfite2               183.1             49.6         38.7
Integrated-Miscellaneous          549.7            241.4        164.6

Total                            1854.2            807.6        492.1

Includes Fine Bleached Kraft and Soda subcategories.
2Includes Papergrade Sulfite (Blow Pit Wash) and Papergrade Sulfite (Drum Wash)
 subcategories.
                                        604

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Implementation Requirements

Availability  of_  Equipment.   EPA  expects that present manufacturing
capabilities are such that required equipment can be readily produced.
Any increased demand for either production process  control  equipment
or  wastewater treatment equipment should be met without major delays.
No geographical limitations are anticipated because of the ability  of
this  industry to use local independent contractors for fabrication of
certain pieces of equipment.

Availability o_f Labor Force.  Manpower necessary for implementation of
technology  alternatives  could  come  from  two  sources:   a)   mill
personnel  and  b)  outside  contractors.   On  jobs  that  cannot  be
completed during a normal shut-down or are considered too complex  for
mill  personnel,  an  outside  contractor  can be hired to perform the
necessary tasks.

A Bureau of Labor Statistics study concluded that the availability  of
construction laborers to perform the required work is sufficient.(223)
This availability is based on two major factors.  This first factor is
the  short training time that is required for construction labor (6 to
12 months).  The second factor  is  the  willingness  of  construction
labor   to   relocate.    Therefore,  availability  of  labor  is  not
anticipated  to  be  a  problem   in   implementing   the   technology
alternatives.

Implementation  Time.   For  end-of-pipe  treatment facilities, normal
construction techniques and crews would be required.   The  bar  graph
presented in Figure A-1 shows the estimated time required to implement
the BPT and NSPS technologies.
                                 605

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                                                                                  MONTHS
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TIME REQUIRED TO  CONSTRUCT

SOLIDS CONTACT CLARIFIES/BIOLOGICAL SYSTEM

-------
                              APPENDIX B

                               GLOSSARY


Abaca - Manila fiber, or manila hemp, obtained from the leafstalk of a
variety of plantain or banana, native to the Philippine Islands.   Its
principal  usage is marine cordage, but is also used for rope, papers,
and tea bags.

Active Alkali - A measure of the strength of alkaline  pulping  liquor
indicating  the  sum  of  caustic soda and sodium sulfide expressed as
Na20.

Activated Sludge Process - A high rate biological  oxidation  process.
The   significant   feature  of  the  process  is  the  recycle  of  a
biologically-active  sludge  formed  by  settling  the   microorganism
population from the aeration process in a clarifier.  Waste is treated
in a matter of hours rather than days.

Aeration  -  The  process  of  being supplied or impregnated with air.
Aeration is used in biological treatment to  dissolve  oxygen  in  the
wastewater.   This  dissolved  oxygen is required by microorganisms as
they feed on organic matter in the wastewater.

Air Dry Ton (APT) - Measurement of  production  including  a  moisture
content of 10 percent by weight.

Alkali - NaOH + Na2_0, expressed as Na20 in alkaline cooking liquors.

Alpha-cellulose - The true cellulose content of a fibrous material.

Available  Chlorine  -  The  oxidizing  power  of  a  bleaching  agent
expressed in terms of elemental chlorine.

Bagasse - Crushed  stalks  of  sugarcane  after  the  sugar  has  been
removed.

Bag Paper - Paper used in making grocery bags or sacks.

Bale  - A standard bale of wastepaper is 72 in. long, 32 in. wide, and
28 in. deep,  with a content of about 37 cubic feet and weighing 900 to
1,000 Ibs.  The size and weight may vary with the grade of  paper.   A
bale of pulp varies in weight from 400 to 500 Ibs and is approximately
30x30x13  in.  in  size.   A bale of rags varies in weight from 700 to
1,300 Ibs and will vary in dimensions according  to  the  press  used.
Typical  dimensions are 26x30x72 in., 26x42x72 in., or 26x52x54 in.  A
bale of bags weighs 61 to 62 Ibs.

Barometric Leg  - A pipe drawing water from a decker or similar  piece
of equipment discharging below the surface of the water in a receiving
tank.  A syphon action is created thus drawing a vacuum on the decker.
                                 607

-------
Barker - A piece of equipment designed to remove the bark from a log.

Barking  -  The  operation  of  removing  bark  from pulpwood prior to
processing.  This is carried out by means of a knife, drum, mechanical
abrasion, hydraulic barker, or by chemical means.

Basis Weight - The weight of a sheet of paper of a given area.  It  is
effected by the density and thickness of the sheet.

Beater  -  A  machine  consisting  of  a tank or "tub," usually with a
partition or "midfeather,"  and  containing  a  heavy  roll  revolving
against  a  bedplate.   Both  roll and bedplate may contain horizontal
metal bars set on edge.  Pulp or wastepapers are put into the  tub  of
the  beater and water is added so that the mass may circulate and pass
between the roll and the bedplate.  This action separates the material
and frees the fibers  preparatory  to  further  processing.   Fillers,
dyestuffs,  and  sizing  materials may be added to the beater and thus
incorporated with the paper stock.  Many modifications in design  have
been  developed  without  changing  the  basic  principles.   See also
Refiner.

Biological Oxidation -  The  process  by  which  bacterial  and  other
microorganisms  oxidize complex organic materials to simpler compounds
and use these for growth and energy.  Self-purification  of  waterways
and  biological  waste  treatment  systems  such  as activated sludge,
trickling filter and aerated stabilization depend on this principle.

Black Liquor - The used cooking liquor recovered  from  the  digester.
It  may  also  be  referred  to as spent cooking liquor.  Strong black
liquor refers to the liquor after  it  has  been  concentrated  by  an
evaporator  to a level suitable for combustion.  Prior to evaporation,
it is referred to as weak black liquor.

Bleaching -  The  brightening  and  delignification  of  pulp  by  the
addition of oxidizing chemicals such as chlorine or reducing chemicals
such as sodium hypochlorite.

Blow  -  Ejection of the chips from a digester, or waste solids from a
boiler.

Slowdown - The  liquid  and  solid  waste  materials  ejected  from  a
pressure vessel such as a boiler.

Blow Pit - A large tank under a digester which receives the discharged
chips  and  liquor  from  the digester.  A constructed stainless steel
plate within the blow pit acts to break up  the  chip  structure  into
individual fibers of pulp upon impact.

Biochemical  Oxygen  Demand   (BOD5)  -  Quantity  of  dissolved oxygen
utilized in the biochemical oxidation of organic matter in a specified
time (5 days) and at a specified  temperature.  It  is  not  related   to
the  oxygen  requirements   in  chemical  combustion,  being determined
                                  608

-------
entirely by the biodegradability of the material and by the amount  of
oxygen utilized by the microorganisms during oxidation.

Boil-out - A procedure, usually utilizing heat and chemicals, to clean
equipment such as evaporators, heat-exchangers, and pipelines.

Bone Dry - See Oven Dry.

Break  - A term used to denote a complete rupture of a web of paper or
paperboard during  manufacture  or  some  subsequent  operation  which
utilizes rolls of paper.

Breaker  Stack  -  Two rolls, one above the other, placed in the dryer
section of a papermachine to compact the  sheet  and  smooth  out  its
surface defects.

Breast  Roll - A large diameter roll around which the Fourdrinier wire
passes at the machine headbox, just at or ahead of the point where the
stock is admitted to the wire by the stock inlet.  The roll is covered
with corrosion-resistant metal or fiberglass and is usually driven  by
the Fourdrinier wire.

Brightness  - As commonly used in the paper industry, the reflectivity
of a sheet of pulp, paper, or paperboard for specified light  measured
under standardized conditions.

Brightness Unit - An increment of measurement to assess the brightness
of paper.

Bristol - Paper characterized by its cardlike features.

Broke  -  Partly  or completely manufactured paper that does not leave
the machine room as salable paper or paperboard; also paper damaged in
finishing operations such as rewinding rolls, cutting, and trimming.

Brown Stock - Pulp, usually kraft or groundwood, not yet  bleached  or
treated other than in the pulping process.

Calcium  Hypochlorite - A chemical commonly used in the paper industry
for bleaching pulp, and in water treatment as a germicide.

Calender Stack - Two  or  more  adjacent  and  revolving  rolls  which
provide even thickness control of the sheet and the final finishing of
its surface.

Capacity - Production of a unit, usually in tons per day.

Causticizinq  -  Process  of  making white liquor from green liquor by
addition of slaked lime.  Most Na2C03^ is thereby converted to NaOH.

Cellulose - The major polysaccharide component of the  cell  walls  of
all  woods,  straws, bast fibers and seed hairs.  It is the main solid
                               609

-------
constituent of wood plants and is the principal raw material of  pulp,
paper and paperboard.

Central Limit Theorem - A statistical theorem.  If any random variable
X  may  be represented as a sum of any N independent random variables,
then in general, the sum X, for large  N,  is  approximately  normally
distributed.   The  importance  of the theorem is that the mean x of a
random sample from any distribution is approximately normal with  mean
n and variance rz/N if the sample size is large.

Chemical  Oxygen  Demand  (COD)  -  A  measure of the oxygen-consuming
capacity  of  organic  and  inorganic  matter  present  in  water   or
wastewater.   It  is expressed as the amount of oxygen consumed from a
chemical oxidant in a specific test.

Chemical Wood Pulp - Pulp obtained by digestion of wood with solutions
of various  chemicals.   The  principal  chemical  processes  are  the
sulfite, sulfate (kraft), and soda processes.

Chest   (or  Stock  Chest)  -  A  tank used for storage of wet fiber or
furnish.

Chipper -  A  machine  consisting  essentially  of  a  revolving  disk
equipped  with heavy radially-arranged knives, which cuts pulpwood and
sawmill waste into slices or chips, diagonal to the grain.

Chips - Small pieces of wood used to make pulp.

Chlorine Dioxide - A chemical C102. used  in pulp bleaching as  a  water
solution,  usually in one or more of the latter stages of a multistage
sequence.  It is prepared by a variety of processes at the plant  site
usually from sodium chlorate, acid, and  a reducing agent.

Chromophoric - Relating to color in a molecule, that can be attributed
to the presence of a chemical group or groups.

Clarifier  -  In  wastewater  treatment, a settling tank which removes
solids from wastewater through gravitational  settling.   The  settled
material,  called  sludge,  is  removed  from the tank bottom by a rake
arm.

Clay -  In general, a  natural,  earthy,  fine-grained  material  which
develops  plasticity  when  wetted,  but  is hard when baked or fired.
Used as filler and for coating paper sheets.

Cleaner - A device which creates a cyclone effect to remove  dirt  and
other  rejects  from  pulp  using the differences in density to aid in
separation.

Coarse Papers - Paper used for grocery and shopping bags,  sacks,  and
special industrial papers.
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Coated  -  A  term  applied to paper and paperboard, whose surface has
been treated with clay or some other pigment and adhesive  mixture  or
other  suitable  material,  to  improve  the  finish  with  respect to
printing  quality,  color,  smoothness,  opacity,  or  other   surface
properties.   The  term  is  also  applied  to lacquered and varnished
papers.

Color - Refers to standard APHA Platinum Cobalt Test, using  standards
for  color  intensity  of  water  samples.   Commonly,  standards  are
prepared at various concentrations which later may  be  referenced  as
units of color, derived from flow and concentration standard.

Color  Plant  -  The portion of a fine papermill where pulp is dyed or
colored prior to being made into paper.

Color Unit - A measure of color concentration  in  water  using  NCASI
methods.

Composite  Sample  -  A  mixture of grab samples collected at the same
sampling point at different times.

Confidence Level  (or Confidence Interval)  - An interval about a sample
quantity which is likely to contain the population  value,  with  some
specified assurance.

Consistency  -  The  percentage,  by  weight, of air dry (or oven dry)
fibrous material  in a stock or stock suspension.  It  is  also  called
density or concentration.

Converting  - Any operation in which paper is made  into a product, not
necessarily the final product to be made.

Cooking - Heating of wood, water, and chemicals  in  a  closed  vessel
under  pressure   to  a  temperature sufficient to separate the fibrous
portion  of  wood  by   dissolving   lignin   and   other   nonfibrous
constituents.

Cooking  Liquor   - The mixture of chemicals and water used to dissolve
lignin in wood chips.

Corrugating Medium - A paperboard used at corrugating plants  to  form
the corrugated or fluted  (wave-like) member in making such products as
corrugated combined board and corrugated wrapping materials.

Cotton Linters -  Short fibers surrounding the cotton seed.

Couch  Pit  -  A  pit or catch basin located under  the couch roll on a
fourdrinier machine to receive water removed at the couch or wet broke
in case of a wet  end break.

Couch Roll -  This  term  refers  to  a  roll  primarily  involved  in
dewatering and picking off, or couching, of the newly formed paper web
from  the  wire   on  which  it was formed and partially dewatered. The
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couch roll is involved in the transfer of the web  to  the  wet  press
felt for further dewatering.

Countercurrent  Washing  -  Refers  to a method of washing used on the
bleach plant or brownstock washers where fresh water is applied on the
last stage showers, and the effluent from each stage is  used  on  the
washer showers of the preceding stage.

Creped  -  A  light  crinkled  characteristic  imparted  to paper by a
creping device to increase surface area, absorption,  and  elasticity.
This  is  a  customary  procedure in tissue papers and fine decorative
papers.

Cylinder Machine - One of the principal types of papermaking machines,
characterized by the use of wire-covered cylinders or molds on which a
web is formed.

Debarking - See "Barking".

Decker - A piece of equipment  commonly  used  to  thicken  pulp.   It
consists of a wire-covered drum in a pulp vat.  A vacuum is applied to
the  center  of  the drum,  commonly by a barometric leg, to pull water
out of the stock slurry.

Deflaker - A high-speed mixing and agitating machine through  which  a
fibrous  stock  suspension  in  water  is  pumped  to  obtain complete
separation and dispersion of each individual fiber, and  break  up  of
any fiber lumps, knots, or bits of undefibered paper.

Deinking  -  The  operation  of  reclaiming  fiber from waste paper by
removing ink, coloring materials, and fillers.

Density - Weight per unit volume.

Diffusion Washing -  Washing  pulps  with  an  open  ended  vessel  by
diffusing or passing the wash media through the pulp mass.

Digester  -  The  vessel  used to treat pulpwood, straw, rags or other
such cellulosic materials with chemicals to produce pulp.

Disk Refiner - A motor-driven refiner whose working  elements  consist
of  one  or  more  matched  pairs  of  disks  having a pattern of ribs
machined into their faces and arranged so that one disk of the pair is
rotated.  The other disk is usually stationary, but may be  driven  in
the opposite direction of rotation.

Dissolved  Oxygen  -  Amount  of  oxygen,  expressed in milligrams per
liter, dissolved in water.

Dissolved Solids - The total amount of dissolved material, organic and
inorganic, contained in water or wastes.
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Dissolving Pulp - A special grade of chemical pulp made from  wood  or
cotton  1 inters  for  use  in the manufacture of regenerated cellulose
(viscose rayon  and  cellophane)  or  cellulose  derivatives  such  as
acetate and nitrate.

Doctor  Blade  - A thin plate or scraper of wood, metal, or other hard
substance placed along the entire length of a roll or cylinder to keep
it free from the paper, pulp, or  size,  thus  maintaining  a  smooth,
clean surface.

Dregs  -  The  inert rejects from the green liquor clarifier of a pulp
mill.

Dregs Washer - A piece of equipment used  to  wash  the  green  liquor
(Na2C03_) off the dregs prior to their disposal.

Dry  End  -  The mill term for the drying section of the papermachine,
consisting mainly of the driers, calenders, reels, and slitters.

Esparto - A grass whose bast fibers are  used  to  produce  high-class
book and printing papers and medium class writing papers.

Evaporators  -  Process  equipment  used  to concentrate spent pulping
liquors prior to burning.

Extended Aeration - A modification of  the  activated  sludge  process
that employs aeration periods of 18 hours or more.

Extraction Water - Water removed during a pulp manufacturing process.

Fatty Acid - A naturally-occuring organic compound of wood.

FeIt  - The endless belt of wood or plastic used to convey and dewater
the sheet during the papermaking process.

Fiber - The cellulosic portion of the tree used to make  pulp,  paper,
and paperboard.

Filler  - A material, generally nonfibrous, added to the fiber furnish
of paper.  In paperboard manufacturing, the inner ply or  plies  of  a
multiple layer product.

Fine Papers - Papers for printing, reproduction and writing.

Fines - Very short pulp fibers or fiber fragments and ray cells.  They
are sometimes referred to as flour or wood flour.

Finishing - The various operations in the manufacture and packaging of
paper   performed   after   it  leaves  the  papermachine.   Finishing
operations include  supercalendering,  plating,  slitting,  rewinding,
sheeting,   trimming,   sorting,  counting,  and  packaging.   Ruling,
punching,  pasting,  folding,  and  embossing   are   also   sometimes
considered as finishing operations.
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Flour  -  A  term  applied  to the fine fibers or fiber fragments of a
pulp.  They are also known as fines.

Flume - A sloped trough with flowing water used to  transfer  pulpwood
from one point to another.

Fourdrinier   Machine   -   A  papermaking  machine  employed  in  the
manufacture of all grades of paper and paperboard.  It may be  divided
into four sections, the wet end, the press section, the drier section,
and the calender section.

Freeness  - A measure of the rate with which water drains from a stock
suspension through a wire mesh screen or a perforated  plate.   It  is
also known as slowness or wetness.

Furnish  -  The  mixture  of  fibers and chemicals used to manufacture
paper.

Gland - A device utilizing a  soft  wear-resistant  material  used  to
minimize  leakage  between a rotating shaft and the stationary portion
of a vessel such as a pump.

Gland Water - Water used  to  lubricate  a  gland.   Sometimes  called
"packing water".

Glassine  Paper  - Paper used as protective wrapping of foodstuffs and
products including tobacco products, chemicals, metal parts,  as  well
as  for  purposes  where  its  transparent  features are useful (i.e.,
window envelopes).  This  paper  is  grease  resistant  and  has  high
resistance to the passage of air and many essential oil vapors.

Gloss  -  The  property  of a surface which causes it to reflect light
specularly and is responsible for its shiny or mirror-like appearance.

Grab Sample - A sample collected at a particular time and place.

Grade - The type of pulp or paper product manufactured.

Greaseproof Paper - Paper used  when  resistance  to  oil  and  grease
penetration is necessary.

Green  Liquor  -  Liquor  made  by dissolving the smelt from the kraft
process water and weak liquor preparatory to causticizing.

Green Liquor Clarifier - A piece of equipment  used  to  separate  the
dregs from the green liquor, allowing recovery of the green  liquor for
processing into white "cooking" liquor.

Grinder  - A machine for producing mechanical wood pulp or groundwood.
It is essentially a rotating pulpstone against which logs are  pressed
and reduced to pulp.
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Grindstone  -  A  natural  or  artifical  stone  which is channeled or
grooved and used for the manufacture of mechanical,  chemi-mechanical,
and groundwood pulp.

Groundwood  Papers  -  A  general term applied to a variety of papers,
other than standard newsprint, made with  substantial  proportions  of
mechanical  wood  pulp  together  with  chemical  wood pulps, and used
mainly for printing and converting purposes.

Hardwood - A term applied to wood obtained from trees  of  the  angio-
sperm  class,  such  as birch, gum, maple, oak, and poplar.  Hardwoods
are also known as porous woods.

Headbox - The area of the  papermachine  that  uniformly  spreads  and
distributes the dilute stock suspension and from which the stock flows
through a sluice onto the wire.

Hemicellulose  -  The  secondary  component  of  cell  walls  of  wood
consisting  primarily  of   short-chained   (low   molecular   weight)
polysaccharides.

Hemp  -  A  tall plant native to Asia having stems that yield a coarse
fiber used in the cordage and  textile  industry.   Enters  the  paper
industry as old cordage or rough textile waste.

Hot Ponds - Heated ponds of water used to thaw frozen logs.

Impregnation  -  The  process  of  treating a sheet or web of paper or
paperboard with a liquid such as hot asphalt or  wax,  a  solution  of
some  material  in a volatile solvent, or a liquid such as an oil.  It
is also used as a term to describe a treatment in  which  fibrous  raw
materials are infused with a chemical solution prior to a digesting or
fiberizing process.  Sometimes called pre-impregnation.

Integrated  -  A term used to describe a pulp and paper mill operation
in which all or some of the pulp is processed into paper at the mill.

Jordan - A refiner whose working elements consist of  a  conical  plug
rotating in a matching conical shell.  The outside of the plug and the
inside  of the shell are furnished with knives or bars commonly called
tackle.

Jumpstage Countercurrent Washing  -  Another  type  of  countercurrent
washing  in  which  fresh  water  is  used  on the last two stages and
filtrates from the acid stages are used on the  preceding  acid  stage
with  the  filtrate  from  the  final alkaline stage being used on the
preceding alkaline stage.

Jute - The glossy fiber of either of two East  Indian  plants  of  the
linden  family   used  chiefly  for  sackling  burlap  and  twine.  In
papermaking, cuttings from burlap manufacture, washed sugarbagging and
wool tares used in wrapping cotton bales  are  used  as  raw  material
sources.
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Kappa  Numbers  -  The  permanganate  number  of a pulp measured under
controlled conditions and corrected to be the equivalent of 50 percent
consumption of the permanganate solution in contact with the specimen.
It gives the degree of delignification of pulp through a  wider  range
than does the older permanganate number test.

Kiln  -  A furnace or oven used in the pulp and paper industry to burn
lime and calcium carbonate to produce CaO,  which is  used  again  with
green liquor to form white liquor.

Knots  -  An  imperfection  in paper or lumps in paper stock resulting
from: 1) incompletely defibered textile materials;  the  term  applies
especially  to rag paper manufacture; 2) small undefibered clusters of
wood pulp; and 3) the basal portion of a  branch  or  limb  which  has
become incorporated in the body of the tree.

Knotter  -  A  mechanical device,  usually a screen, for removing knots
from wood pulp.
Kolmoqorov  -
statistical  test
frequency  distribution
Smirnov  Goodness  of  Fit  Test  -   A   nonparametric
    of  goodness  of  fit  for  an  observed continuous
          to  the   expected   frequency   distribution
representing the hypothesis.

Kraft - A descriptive term for the (alkaline) sulfate pulping process,
the resulting pulp, and paper or paperboard made therefrom.

Lap - See Wet Lap.

Lignin  -  A  non-degradable organic compound of wood which is removed
during pulping.
Lime Mud - A solid residue generated from the white  liquor
in the lime recovery/white liquor preparation process.
                                              clarifier
Linerboard  -  A  paperboard made on a Fourdrinier or cylinder machine
and used as the facing material in the production  of  corrugated  and
solid fiber shipping containers.

Market Pulp - A pulp manufactured explicitly for purchase.

Mathieson Process - A process of producing chlorine dioxide, using 502^
as a reducing agent.
Mechanical
   - Pulp produced by physical means without the use of
chemicals or heat, often referred to as groundwood.

Metering Rod - A rod used to apply coating to the surface of a  sheet,
metering even thickness coating layers on the surface.

Molded  Pulp  Products  -  Contoured  products,  such as egg packaging
items, food trays, plates, and bottle protectors, made  by  depositing
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fibers from a pulp slurry onto a forming mold of the contour and shape
desired in the product.

Mud  Filter  -  A piece of equipment used to thicken and wash lime mud
prior to burning it in the lime kiln.

Mud Washer - A piece  of  equipment  used  to  wash  the  sodium  base
chemicals from the lime mud prior to burning it in the lime kiln.

Newsprint  -  Paper,  made  largely  from groundwood pulp with a small
percentage of chemical pulp added for strength, used  chiefly  in  the
printing of newspapers.

Nip - The point at which two adjacent rolls come together.

Nonparametic  Methods  -  Statistical methods which do not require the
assumption of a distributional form, such as a normal distribution.

Nonwood Fibers - Fibers not of the wood family used to  produce  pulp,
paper,  and paperboard.  Such as vegetable fibers (cotton, flax, jute,
hemp,  cereal  straw,  bagasse,   bamboo,   esparto,   abaca,   sisal,
pineapple),  animal fiber (wool), mineral fiber (asbestos, glass), and
man-made or artifical fiber (rayon, nylon, orlon, dacron).

Normal Distribution - A statistical distribution identified by a  bell
shaped   curve   which   is  the  most  important  of  all  continuous
distributions.  This distribution curve is symetrical about the mean.

Nutrients - Elements, or compounds, essential  as  raw  materials  for
organism growth and development (as in activated sludge process).

Opacity  -  A  measure  of  the  index  of  transparency  of paper, by
measuring the quantity of light that is transmitted through the  paper
sheet.

      Dry  - A pulp or paper which has been dried to a constant weight
     temperature of 100° to 105°C (212° to 221 OF).

Oxidation Pond - A low-rate biological  process  in  which  biological
treatment  takes  place  in  a  man-made  pond.   Dissolved  oxygen is
supplied  by  natural  aeration  processes  such   as   wind,   algae,
photosynthesis, and partial pressure.

Paperboard  -  One  of  the  two broad subdivisions of paper products.
Paperboard is heavier in basis weight, thicker, and  more  rigid  than
paper.   In  general,  all  sheets  12  points  (0.012 in.) or more in
thickness are  classified  as  paperboard.   There  are  a  number  of
exceptions based upon traditional nomenclature.  For example, blotting
paper,  felts, and drawing paper in excess of 12 points are classified
as paper while corrugating medium, chipboard, and linerboard less than
12 points are classified as paperboard.  Paperboard  is  made  from  a
wide   variety  of  furnishes  on  a  number  of  types  of  machines,
principally cylinder and fourdrinier.   The  broad  classes  are:   1)
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container  board,  which  is  used for corrugated cartons; 2) boxboard
which is further divided into,  a) folding boxboard,  b)  special  food
board,  and  c) setup boxboard; and 3) all other special types such as
automobile board, and building board.

Parametric Methods - Classical  statistical methods which are effective
for samples taken from normally distributed populations.
Permanganate Number (K NO.)  - This method (T-214-TAPPI Std.)  is  used
               the relative "hardness" or bleach requirements of pulp.
               it is the number of  milliliters  of  0.1  N  potassium
                        absorbed by 1  gram of moisture-free pulp under
to  determine
By definition,
permanganate  solution
specified control conditions.
Peroxide - A  chemical  used  in  bleaching  of  wood  pulps,  usually
groundwood pulps.

Porosity  -  A  measure  of  time  required for 100 cm3 of air to flow
through a sample area.  Also termed "air resistance" (in  seconds  per
100 cm3).

Precipitators  -  Equipment  used  to remove ash and other fine solids
from gases exiting the boilers and furnaces in a mill.

Precook ~ Prehydrolysis.

Prehydrolysis -  Pre-steaming  of  chips  in  the  digester  prior  to
cooking; usually associated with improved bleaching of kraft pulps.

Press - In a papermachine, a pair of rolls between which the paper web
is  passed  for one of the following reasons:  1) water removal at the
wet press; 2) smoothing and leveling  of  the  sheet  surface  at  the
smoothing press; and 3) application of surface treatments to the sheet
at the size press.

Printability - The ability of a paper surface to accept printing ink.

pth  Percentile  -  A  real  number  which  divides  the area under  a
probability   density   function   corresponding   to   a   continuous
distribution   into   two  parts  of  specified  amounts  (i.e.,  99th
percentile divides the  density  function  into  one  percent  and  99
percent of the population).

Pulp - Cellulosic fibers after conversion from wood chips.

Pulper  -  A  mechanical  device used to separate fiber bundles in the
presence of water prior to papermaking.

Pulping - The operation of reducing a cellulosic raw material, such as
pulpwood,  rags, straw, and reclaimed paper into a  pulp  suitable  for
papermaking.
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Pulpwood  -  Those  woods  which  are  suitable for the manufacture of
chemical or mechanical wood pulp.  The wood may be in the form of logs
as they come from the forest or cut into shorter lengths suitable  for
the chipper or the grinder.

Rag  Paper  - A paper product manufactured by use of such materials as
cotton or linen threads, flax and hemp, raw cotton, and other  textile
fibers and cotton linters, as well as rags.

Recovery  Furnace or Recovery Boiler - A boiler which burns the strong
black liquor.

Red Stock - Sulfite pulp after the pulping  process,  prior  to  other
treatments, such as bleaching.

Reel  -  1)  A  term  applied  to  the untrimmed roll of paper of full
machine  width  wound  on  a  large  shaft  at  the  dry  end  of  the
papermachine.   2) The shaft on which the paper is first wound when it
leaves the driers.  3) A term for the operation of winding paper  into
a reel.

Refiner  -  A  machine  used to rub, macerate, bruise, and cut fibrous
material, usually cellulose, in water suspension to  convert  the  raw
fiber  into  a  form  suitable  for  formation  into  a web of desired
characteristics on a papermachine.  See also Def.laker,  Disk  Refiner,
Jordan.

Refining  - A general term applied to several operations, all of which
involve the mechanical treatment of pulp  in  a  water  suspension  to
develop  the necessary papermaking properties of the fibers and to cut
the fibers to the desired length distribution.  See Refiner.

Rejects - Material unsuitable for pulp or papermaking which  has  been
separated in the manufacturing process.

Repulpinq  -  The  operation of rewetting and fiberizing pulp or paper
for subsequent sheet formation.  See also Pulper.

Resin - A special additive used to produce wet-strength  in  paper  or
board.

Resin Acid - A naturally occuring organic compound in wood.

Rewinder  -  The  term  rewinder  is  often used for the winder in the
finishing room, distinguishing it from the winder  which  follows  the
slitter at the end of the papermachine.

Rewinding - The operation of winding the paper accumulated on the reel
of  papermachine onto a core to give a tightly wound roll suitable for
shipping or for use in the finishing or converting department.

Rosin - A brittle  ye-llow  or  amber-colored  natural  resin  that  is
obtained  from  southern  pine,   (types:  gum  rosin,  wood rosin, and
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tall-oil rosin).  Used in paper-making for internal (beater) sizing  of
paper.

Roundwood  -  Logs  as  received in the woodyard.  The logs can be any
length and usually have not been debarked.

R-2_ Process - A modification of the Mathieson process.

Saltcake Loss - The loss of cooking chemical  from  the  kraft  cycle,
primarily at the brownstock washers or screen room.

Sample  Mean - The average of a population calculated from the sample;
it is the most commonly used measure of the center of a  distribution.
Its  value equals the sum of the values of the observations divided by
the number of observations.

Saveall - A mechanical device used to recover papermaking  fibers  and
other suspended solids from a wastewater or process stream.

Screening  -  1) The operation of passing chips over screens to remove
sawdust, slivers and oversize chips.  2) The operation of passing pulp
or paper stock through a screen  to  reject  coarse  fibers,  slivers,
shives, and knots.

Screw Press - A device used to recover spent liquor from cooked chips.

Scrubbers  -  Equipment for removing noxious gases from the exhaust of
certain areas in the mill, such as the bleachery or washers.

Sheet - A term used extensively in the paper industry meaning:   1)  A
single  piece  of pulp, paper, or paperboard; 2) the continuous web of
paper as it is being manufactured; 3) a general term for  a  paper  or
paperboard  in  any  form  and  in  any quantity which, when used with
appropriate  modifying  words,  indicates  with  varying  degrees   of
specificity,  attributes  of  the product such as quality, class, use,
grade,  or physical properties  (Examples:  a  bright  sheet,  a  kraft
sheet,   a  folding  boxboard sheet); and 4) to cut paper or paperboard
into sheets of desired size from roll or web.

Shive - A bundle of incompletely separated fibers which may appear  in
the finished sheet as an imperfection.

Side-Hill Screens - Steeply sloped screens usually used to remove some
water  from  suspensions  of stock or other solids while retaining the
solid on the screen surface.

Size - Any material used in the internal sizing or surface  sizing  of
paper  and  paperboard.   Typical  agents are rosin, glue and gelatin,
starch, modified celluloses, synthetic resins, latices, and waxes.

Size Press - A  unit of a paper machine, usually  located  between  two
drier  sections,  used to apply, meter and distribute evenly size onto
paper.
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Sizing -  1)   Relates  to  a  property  of  paper  resulting  from  an
alteration  of  fiber  surface  characteristics.  In terms of internal
sizing, it is a measure of the resistance to the penetration of  water
and  various  liquids.   In terms of surface sizing, it relates to the
increase of such properties as water resistance, abrasion  resistance,
abrasiveness,   creasibility,   finish,  smoothness,  surface  bonding
strength, printability, and the decrease of porosity and surface fuzz.
2)  The  addition  of  materials  to  a  papermaking  furnish  or  the
application  of  materials  to  the surface of paper and paperboard to
provide resistance to liquid penetration and, in the case  of  surface
sizing, to affect one or more of the properties listed in 1).

Slaker  - A device used to regenerate white liquor in the green liquor
recovery process.

Slasher - A saw or set of saws  used  to  cut  long  logs  to  desired
length.

Slitter  -  A  set  of  knives  used  to slit a reel of paper into the
desired widths as the reel is rewound.

Sludge - Semi-fluid mixture of fine solid  particles  with  a  liquid.
May contain fibrous and filler materials, and/or biological solids.

Slurry - A suspension of solid particles in a liquid.

Smelt  -  The  molten  inorganic  cooking  chemicals from the recovery
boiler.

Soda Process - The first process for the manufacture of chemical  wood
pulp.  Involves boiling wood in caustic alkali at a high temperature.

Softwood - Coniferous woods, such as pines, spruces, and hemlocks.

Solvay Process - A modification of the Mathieson process.

Spent  Cooking  Liquor  -  Cooking  liquor  after digestion containing
lignaceous,  as well as chemical, materials.

Stock - 1) Pulp which  has  been  beaten  and  refined,  treated  with
sizing,  color, filler, etc. and which, after dilution, is ready to be
formed into a sheet of paper.  2) Wet pulp of any type at any stage in
the manufacturing process.  3) Paper in inventory or in  storage.   4)
Paper  or  other  material  to  be printed, especially the paper for a
particular piece of work.  5) A term used to describe a paper suitable
for an indicated use, such as coating raw stock,  milk  carton  stock,
tag stock, and towel stock.

Stock  Preparation  -  A  term  for the several operations which occur
between  pulping  (or  bleaching)  and  formation  of  the  web  on  a
papermachine.   It  may  include,  for  example,  repulping,  beating,
refining, and cleaning.
                                621

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Stone - See Grindstone.

Sulfidity - Sulfidity is a measure of the amount of  sulfur  in  kraft
cooking  liquor.  It is the percentage ratio of NaS,  expressed as NaO,
to active alkali.

Thickener - A device using vacuum or gravity type suction mesh  screen
to remove excess water from pulp.

Tolerance  Level  -  Provides  an  interval  within  which  at least a
proportion of the population lies with probability 1-a or  more  (i.e,
99 percent of the observations lie below a given value with 70 percent
confidence).

Unbleached  -  A  term  applied  to  paper  or pulp which has not been
treated with bleaching agents.

Vegetable Parchment - A wet strength paper product  used  as  wrapping
for moist materials.

Virgin  Wood  Pulp  - Pulp made from wood, as contrasted to wastepaper
sources of fiber.

Viscosity - The resistance to flow in a liquid; a measurement used  in
stock preparation as an indicator of pulp condition.

Washer  -  A  piece of equipment, usually either a decker or side hill
screen type,  equipped with showers to wash chemicals from  pulp  stock
or reject solids.

Wastepaper  - A general term used to specify various recognized grades
such as No. 1 news, new  kraft  corrugated  cuttings,  old  corrugated
containers, manila tabulating cards, coated soft white shavings, etc.,
which are used as a principal ingredient in the manufacture of certain
types  of  paperboard, particularly boxboard made on cylinder machines
where the lower grades may go into filler stock, and the higher grades
into one or both liners.

Web - The sheet of paper coming from  the  papermachine  in  its  full
width or from a roll of paper in any converting operation.

Wet End - That portion of the papermachine between the headbox and the
drier section.  See Fourdrinier Machine.

Wet  Lap Machine - A machine used to form pulp into thick rough sheets
sufficiently dry to permit handling and folding  into  bundles  (laps)
convenient for storage or transportation.

Wet  Laps - Rolls or sheets of pulp of 30 to 45 percent consistency to
facilitate transportation of market pulp, and prepared  in  a  process
similar to papermaking.
                                622

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Wet  Press  -  The  dewatering unit used on a papermachine between the
sheet-forming equipment and the drier section.

Wet Strength - The strength of paper after  complete  saturation  with
water.

Wet   Strength  Additives  -  Chemicals  such  as  urea  and  melanine
formaldehydes used in papermaking to impart strength to papers used in
wet applications.

White Liquor - The name applied to liquor made by  causticizing  green
liquor.

White  Water - A general term for all papermill waters which have been
separated  from  the  stock  or  pulp  suspension,   either   on   the
papermachine  or accessory equipment, such as thickeners, washers, and
savealls, and also from pulp grinders.

Winder - The machine which winds into rolls, the paper coming from the
papermachine reel.

Wire - An endless moving belt made of metal or plastic,  resembling  a
window  screen, upon which a sheet of paper is formed on a Fourdrinier
machine.

Wire Pj.t - A pit under  the  wire  of  a  Fourdrinier  machine,  which
receives some of the water drained or pulled out of the paper sheet.

Wood  Flour  -  Finely  ground  wood or fine sawdust used chiefly as a
filler.

Wood Preparation - A series of operations utilized to prepare wood  to
a  suitable  state  for  further  development  into  pulp,  paper, and
paperboard.  These operations include barking, washing, and chipping.

Woodroom - The area of a pulp mill that handles the barking,  washing,
chipping or grinding of logs, and processing of purchased chips.

Woodyard  -  The area of a mill where roundwood is received and stored
prior to transport to the woodroom.

Yankee Machine - A papermachine using one  large  steam-heated  drying
cylinder for drying the sheet, instead of many smaller ones.  Commonly
used for manufacturing tissue.

Yield - In pulp and papermaking, the ratio of product to raw material.
                                623

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                              APPENDIX C



                       LEGEND OF ABBREVIATIONS





A:  Acid or Dechlorination



AA: Atomic Adsorption



ADT: Air Dry Tons



APHA:  American Public Health Association



API: American Paper Institute



ASB: Aerated Stabilization Basin



ATM: Atmospheres



Avg: Average



Ba:  Barometric



BAT:  Best Available Technology Economically Achievable



BCT: Best Conventional Pollutant Control Technology



BCT Bleached Kraft: Paperboard, Coarse, and Tissue Bleached Kraft



B1K:  Bleached Kraft



BMP: Best Management Practices



BODJ5: Biochemical Oxygen Demand (five day)



BP:  Blow Pit Wash



BPT:  Best Practicable Control Technology Currently Available



Brd:  Board or Paperboard



BS:  Bisulfite



Btu:  British thermal units



C:  Chlorination Stage (bleach)



°C:  Degrees Centigrade



Ca:  Calcium



CAC: Chemically Assisted Clarification
                                 625

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CaO: Calcium Oxide



CFR:  Code of Federal Regulations



Chg:  Change



CMN:  Coarse, Molded, Newsprint



CMP:  Chemi-Mechanical Pulp



COD:  Chemical Oxygen Demand



Cont:  Contained



Conv:  Converting



Corrug:  Corrugating



Ctd:  Coated



cu ft:  cubic feet



cu m: cubic meter



cu m/day: cubic meter per day



d:  day



D:  Chlorine Dioxide Stage (bleach)



DAF:  Dissolved Air Flotation



Dens:  Density



DI:   Deinked



Diss:  Dissolving



DMR: Discharge Monitoring Report



DO:   Dissolved Oxygen



DR:   Drum Wash



E:  Extraction Stage  (caustic bleach)



E. Coli.:  Escherichia Coliform



EC/GC: Electron Capture Detection/Gas Chromatography



EFF:  Effluent



ENR:  Engineering News Record
                                 626

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EPA: U.S.  Environmental Protection Agency



Est:  Estimate



Excl:  Excluding



F:  Fine



fps: feet per second



°F:  degrees Fahrenheit



ft: feet



ft3: cubic feet



FW:  Fresh Water



Fwp:  From wastepaper



GAC: Granular Activated Carbon



gal:  gallons



GC/MS: Gas Chromatography/Mass Spectrometry



gpd/sq ft:  gallons per day per square foot



gpm:  gallons per minute



GWD:  Groundwood



GW. Spec.:  Groundwood Specialties



H:  Hypochlorite stage (bleach)



ha:  hectare



hp:  horsepower



hr: hour



HS: Hydrosulfite (bleach)



HW:  Hardwood



H202: Hydrogen peroxide



HWK: Hardwood Kraft



Ind:  Industrial
                                 627

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Inf:  Influent
Insul:  Insulation
JTU:  Jackson Turbidity Unit
K:  Kraft
K.99:  99th Percentile of a Population
kg:  kilogram, 1000 grams
kg/ha: kilograms per hectare
kg/kkg:   kilograms per 1000 kilograms
kg/sq cm:   kilograms per square centimeter
kgal:  1000 gallons
kgal/ton or kgal/t:  1000 gallons per ton
kkg:  1000 kilograms (metric ton)
kkg/day: 1000 kilograms/day
kl/kkg:   kiloliters per thousand kilograms
kw:  kilowatt
kwh:  kilowatt hour
1: . liter
lb:  pound
Ib/ac/day:  pound per acre per day
Ib/gal:  pound per gallon
Ib/t:  pounds per ton
log: logarithm
mach: machine
MD: Maximum Day Limit
mg:  million gallons
mgd: million gallons per day
mg/1: milligrams per liter
                                 628

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MgO: Magnesium Oxide

min: minute

misc: miscellaneous

mkt: market

ml: milliliter

MLSS: Mixed Liquor Suspended Solids

MLVSS: Mixed Liquor Volatile Suspended Solids

MST: Median Survival Time

M30DA:  Maximum 30 Day Average Limit

n:  Number of daily observations

N.A.: Not Available or Not Applicable

Na:  Sodium

Na2C03:  Sodium Carbonate (Soda Ash)

NaOH: Caustic Soda (Sodium Hydroxide)

Na2S: Sodium Sulfide

Na2S04: Salt Cake (Sodium Sulfate)

Na2S03: Sodium Sulfite

NCASI: National Council of the Paper Industry for Air and Stream
       Improvement

NH3: Ammonia

No.:  Number

NPDES: National Pollutant Discharge Elimination System

NSPS: New Source Performance Standards

NSSC: Neutral Sulfite Semi-Chemical

0: Oxygen (bleach)

03: Ozone

O&M:  Operation & Maintenance
                                 629

-------
P: Peroxide (bleach)



PA: Peracetic Acid (bleach)



PCB:  Polychlorinated Biphenyl



PCP:   Pentachlorophenol



PFTBA: Perfluorotributylamine



pH: alkalinity



PIMA: Paper Industry Management Association



pkg:   packaging



POTW or POTWs:  Publicly Owned Treatment Works



ppb:  parts per billion



PPRIC: Pulp and Paper Research Institute of Canada



Pt-Co units: Platinum Cobalt Units



ppm:  parts per million



%: percent



Prf:   Proof



Print:  Printing



prod.: production



PS:  Post Storage



PSES: Performance Standards for Existing Sources



psi:  pounds per square inch



psig: pounds per square inch gauge



PSNS: Performance Standards for New Sources



purch:  purchased



PVA:   Polyvinylacetate



QC/QA: Quality Control/Quality Assurance



RBC:  Rotating Biological Contactor



RCRA:  Resource Conservation Recovery Act
                                630

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RWL: Raw Waste Load
S:  Surface Condenser
S&A: Sampling and Analysis
San: Sanitary
sat: saturated
SB:  Settling Basin
SCOT: Support-Coated Open Tubular Capillary Column
Semi-chem:  Semi-chemical
SOgi Sulfur Dioxide
spec:  speciality
sq ft: square feet
sq m: square meter
sq m/g: square meter per gram
SRP: Salt Recovery Process
SS: Stainless Steel
SSL: Spent Sulfite Liquor
Std Meth:  Standard Methods
Str:  Structural
SW:  Softwood
SWK: Softwood Kraft
t:  ton
TAPPI:  Technical Association of the Pulp and Paper Industry
TCP:  Trichlorophenol
TDK:  Total Dynamic Head
Tech:  Technical
Temp: Temperature
TMP: Thermo-Mechanical Pulp
                                 631

-------
TOC: Total Organic Carbon



TOD: Total Oxygen Demand



ton: 2000 pounds



t/d or tpd:  tons per day



TS:  Total Solids



TSS: Total Suspended Solids



TVS: Total Volatile Solids



U:  Unknown



UBK: Unbleached Kraft



Unctd:  Uncoated



USSR: Union of Soviet Socialist Republics



Vibra:  Vibrating



VOA: Volatile Organic Acid



Vr:  Vapor recompression



vs: versus



V/Q:  Volume to flow



v/v:  percent by volume



W: Water Soak



WATDOC: Canada's Inland Waters Directorate



WF:  Wood Flour



w/: w i th



w/o: without



WP:  Wastepaper



WW:  White Water



w/w:  water to water



n:  micro
                                632

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ug/1:  micrograms per liter
yr:  year
Z/A: Zurn/Attisholz

   less than
   less than or equal to
   greater than
   greater than or equal to
   plus
   minus
                                633

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            LEGEND OF SYMBOLS ON  FIGURES
Y
    PROCESS  DESIGNATIONS
    FLOW  DIRECTION
    VALVE (NORMALLY OPEN)
    VALVE (NORMALLY CLOSED)
    CONTROL VALVE (SHOWN OPEN)
     FLOOR DRAIN
                                       PUMP
                                       BLOWER
                                          SHOWERS




                                     A   DISTRIBUTION NOZZLE


                                        
-------
                              APPENDIX D

                              REFERENCES


1.   Natural Resources Defense Council, Inc. , e_t aj. v.  Train,  United
States  District  Court  for  the  District of Columbia,  (8 ERC 2120),
June 7, 1976.

2.   Natural Resources Defense Council, Inc. , e_t al. v. Costle,  United
States  District  Court  for  the District of Columbia, (12 ERC 1833),
March 9, 1979.

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

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

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

6.   Weyerhaeuser Co., e_t al. v. Douglas Costle, United States Court of
Appeals for the District of Columbia  Circuit, September 5,  1978.

7.   Federal Register, 45 FR 15952, 40 CFR 430, March  12,  1980.

8.    Federal Register, 46 FR 1430, 40 CFR Parts 430 and   431,  January
6,  1981.

9.   Federal Register, 42 FR 6476, 40  CFR 128, February 2,  1977.

10.    Rationale   for  the  Development  of_  BAT  Priority  Pollutant
Parameters, U.S. Environmental Protection Agency,  Effluent  Guidelines
Division,  Washington, D.C., May 24, 1977.

11.   Choi,  P.S.K.,  W.J.  Mueller,  J.A.  Jacomet,  D.L.  Hessel, J.A.
Gerling, and T.J. Collier, Multi-Media Pollution Assessment  ir\  Pulp,
Paper, and other Wood Products Industry, December  1976.

12.   Priority  Pollutant  Information  and Data Assessment, Edward C.
Jordan Co., Inc., Portland, Maine, June 1977.

13.  Survey Form—Pulp, Paper,and Paperboard Industry, Part I_ and Part
II, U.S. Environmental Protection Agency, October  1977.

14.  Survey Form—Pulp, Paper, and Paperboard Industry, Errata Sheets,
U.S. Environmental Protection Agency, October 1977.

15.  Sampling and Analysis  Procedures  for  Screening  of_ Industrial
Effluents  for  Priority  Pollutants,  U.S.  Environmental  Protection
Agency, Cincinnati, Ohio, April 1977.

16.  Procedures for Screening o_f Pulp, Paper, and  Paperboard Effluents
for Fourteen Nonconventional Pollutants, U.S. Environmental Protection
Agency, Washington, D.C., December 1980.
                              635

-------
17.   Screening Program Work  Booklet,  Edward  C.  Jordan  Co.,  Inc.,
September 1977.

18.    Standard  Methods  for  the Examination of Water and Wastewater,
American Public Health Association, American Water  Works  Association
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19.    Process  Data  -  Verification  Program Mill Survey for Priority
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July 1978.

20.    Verification  Program Work Booklet, Edward C. Jordan, Co., Inc.,
July 1978 (and all subsequent revisions).

21.   Private Communication with National Council of the Paper Industry
for Air and Stream Improvement, Inc., December 15, 1978.

22.   An Investigation o_f Improved Procedures for Measurement  o_f_  Mill
Effluent  and  Receiving  Water  Color,  National Council of the Paper
Industry for Air  and  Stream  Improvement,  Inc.  (NCASI),  Technical
Bulletin No. 253, December 1971.

23.   Federal Register, 44 FR 69464, 40 CFR 136, December 3, 1979.

24.   Procedures for Analysis of Pulp, Paper, and Paperboard  Effluents
for   Toxic   and   Nonconventional   Pollutants,  U.S.  Environmental
Protection Agency, Washington, D.C., December 1980.

25.   Long-Term Sampling Work Booklet,  Edward  C.  Jordan  Co.,  Inc.;
April, 1981.

26.   Long-Term Sampling Work Booklet for Pulp, Paper,  and  Paperboard
Mills  Manufacturing  Deink  Products,  Edward  C.  Jordan  Co., Inc.,
September, 1981.

27.   Economic  Impact Analysis of Effluent  Limitations  and  Standards
for  the  Pulp,  Paper,  and  Paperboard   Industry, U.S. Environmental
Protection Agency, October 1982.

28.   Pulp and Paper Manufacture; The Pulping  of  Wood,  Vol.   !_,   2nd
Edition, McGraw-Hill Book Co., New York, 1969.

29.    Rydholm,  S.A.,  Pulping Processes,  Interscience Publishers,  New
York, 1965.

30.   Scott, R.H. and H.K. Willard, "The U.S.  Sulfite   Industry Faces
Present  and  Future  Waste  Control  Needs,"  TAPPI,  Vol. 56, No.  9,
September 1973.

31.   Gehm, H.W., State-of-the-Art  Review  o_f  Pulp  and   Paper Waste
Treatment, EPA Contract No. 68-01-0012, April  1973.
                                636

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32.   Brown,  R.W.,  et  al.,  "Semi-Chemical  Recovery  Processes and
Pollution Abatement," Pulp and Paper Magazine of Canada, T-202,  March
1960.

33.   Hanson, James P., "No Sulfur Pulping Pushing Out NSSC Process at
Corrugating Medium Mills," Pulp and Paper, Vol. 52, No. 3, March 1978.

34.  TAPPI Standard Method T217m-48.

35«  The Bleaching of Pulp, TAPPI, Monograph Series, No. 27, 1963.

36.  LockwQodls Directory  of  the  Paper  and  Al1ied  Trades,  Vance
Publishing, 1978 Edition.

37.  Paper and Pulp  Mill  Catalog  and  Engineering  Handbook,  Paper
Industry Management Association (PIMA), 1978 Edition.

38-  Post's Pulp and Paper Directory, Miller Freeman Publications, San
Francisco, California, 1979 Edition.

39•  Aejrated Lagoon Treatment of Sulfite Pulping Effluents, Report  to
the  U.S.  Environmental  Protection  Agency,  Water Pollution Control
Research Series Program No. 12040 ELW, December 1970.

40.  Strier, Murray, Treat ability of_  Organic  Priority  Pollutants  -
Part   C   -   Their  Estimated  (30  Day  Average)  Treated  Effluent
Concentrat ions - h Molecular Engineering Approach, 1978.

41.  Development Document for Existing Source  Pretreatment  Standards
for  the  Electroplating  Point  Source  Category,  U.S. Environmental
Protection Agency, Washington, D.C., EPA 440/1-79-003, August 1979.

42.  Development Document for Proposed Effluent Limitations Guidelines
and Standards for the  Metal  Finishing  Point  Source  Category,  EPA
440/l-82/091b, August 1982.

43.  Fate of Priority Pollutants Jji Publicly  Owned  Treatment  Works,
U.S.   Environmental  Protection  Agency,  EPA 440/1-82/303, September
1982.

44.  Development Document for Proposed Effluent Limitations Guidelines
and Standards for Control of Polychlorinated Biphenyls  in  the  Deink
Subcategory  of the Pulp, Paper, and Paperboard Point Source Category,
U.S. Environmental Protection Agency, Washington, D.C., October 1982.

45.  Development Document for Effluent Limitations Guidelines and  New
Source  Performance Standards for the Builders' Paper and Roofing Fe1t
Segment of the Builders' Paper and Board Mills Point Source  Category,
U.S.  Environmental Protection Agency, Washington, D.C., EPA 440/1-74-
026a, May 1974.

46.  Development Document for Effluent Limitations Guidelines and  New
Source   Performance   Standards   for   the   Unbleached   Kraft  and
                                 637

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Semi-chemical Pulp Segment of the Pulp, Paper,  and  Paperboard  Mills
Point   Source   Category,   U.S.   Environmental  Protection  Agency,
Washington, D.C., EPA 440/I-74-025-a, May 1974.

47.  Development Document for  Interim  Final  and  Proposed  Effluent
Limitations  Guidelines  and Proposed New Source Performance Standards
for  the  Bleached  Kraft,  Groundwood,  Sulfite,  Soda,  Deink,   and
Non-Integrated  Paper  Mills Segment of_ the Pulp, Paper and Paperboard
Point Source Category - Vol. 1   &  2,  U.S.  Environmental  Protection
Agency, Washington, D.C., EPA 440/1-76/047-A, January 1976.

48.   Development Document for Effluent Limitations Guidelines for the
Bleached Kraft, Groundwood, Sulfite, Soda, Deink,  and  Non-Integrated
Paper  Mills  Segment  of_ the Pulp, Paper, and Paperboard Point Source
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440/1-76/047-b, December 1976.

49.   Ekono, Inc., "Process Design Manual for Pollution Control in the
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50.   Thompson, R., P.J. Savage, and C.Y. Chai, "In-Plant Reduction of
Suspended  Solids  at  Espanola,"  1974  Air  and  Stream  Improvement
Conference, Toronto,  Ontario.

51.   SSVL, "The Environmental Care Project Half Year Report - January
1973," Printed for Swedish Pulp and Paper Mission  to  North  America,
January 1973.

52.   SSVL  Environmental  Care Project- Technical Summary, Stockholm,
Sweden, 1974.

53.  Kramer, J. D., C.F.  Cornell,  D.C.  Pryke,  and  G.  Rowlandson,
"Spill  and  Effluent  Control in the Closed-Cycle Bleached Kraft Pulp
Mill," TAPPI Environmental Conference,  1979.

54.  Czappa, D. J.,  "In-Mill  Close-up,"  TAPPI,  Vol.  61,  No.  11,
November 1978.

55.   Becker, K.E., "Crown Simpson Finds Process Revisions Less Costly
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56.   A  Study   of_   the   Relation   Between   Residual   Soda   and
Water-Ex tractable  Components  of_ Vacuum Drum Washed Kraft Pulp and of
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Improvement Technical Bulletin No. 277, October  1974.

57.   Edde, H. and E. Sebbas - Bergstrom,  "Internal Pollution Controls
in the Pulping Industry," Journal WPCF, Vol. 46 No. 11,  1974.
                              638

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58.   Rapson,  William  H.  "Using  Caustic  Extraction  Effluent   in
Production  of  Bleached  Pulp," Canadian Patent 802,084, December 24,
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59.  Twitchell, J.  and  L.  Edwards,  "Kraft  Mill  Material  Balance
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60.   "Summary  Report  on  the Evaluation of Internal Process Control
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62.   Kalish,  John,  "Swedish Mill Modernizes and Looks to New Future
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64.   Rath,  P.,  "Process Wastewater: Reclamation or Disposal," TAPPI
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65.  "Pollution Reduction  by  Internal  Measures  at  Bleached  Kraft
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66.   "Proceedings  of  the  1976  NCASI Central-Lakes States Regional
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69.   Casey,  J.P.,  Pulp and Paper Chemistry and Chemical Technology,
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70.  Broughton, Robert W., "Needled Felts Get Another  Lease  on  Life
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71.  Mulford, J.E. and R. Cooke,  "Reuse  of  Nash  Vacuum  Pump  Seal
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72.   Brown,  G.W.,  "Computer  Simulation  of Papermaking to Evaluate
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                               639

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73.  David, E., et. al.,  "Oxygen Bleaching -  Two  Years  of  Operating
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74.   Myburgh, C.J.,  "Operation of the Enstra Oxygen Bleaching Plant,"
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75.  Andersson, K.A., "The Non-Polluting Bleach  Plant,"  TAPPI,  Vol.
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76.   Rapson,   W.H.,   D.W.  Reeve,  e_t al. , "The Closed Cycle Bleached
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77.  Rapson,  W.H., D.W.  Reeve, and J.A.  Isbister,  "The  Closed  Cycle
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78.  Anderson, L.G. and S. Lindberg, "Uddeholm Cleans Bleach Effluents
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79.   Lowe,  K.E.,  "Chesapeake  Launches  Oxygen Bleaching," Pulp and
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80.  MacLeod,  M., "Evolution and Revolution  in  Pulp  Bleaching  -  A
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81.   Carpenter,  W.L.,   I.  Gelman, e_t al., "A Comparison of Effluent
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82.  Mattson,  D., Unpublished Trip Report on ERCO Envirotech -  Closed
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84.   Gall,  R.J.  and F.H. Thompson, "The Anti-Pollution Sequence - A
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85.  Moy, W.A., K. Sharpe, and G. Betz,  "New  Bleaching  Sequence  for
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86.  Jenkin,  T.E.,  "Eastex  Displacement  Bleaching  Update,"  TAPPI,
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88.  Gould, M. and J. Walzer, "Mill Waste Treatment by  Floatation  at
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90.  Easty, Dwight B.,  L.G. Borchardt, and B. A. Wabers, Institute  of
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93.   Leach, J.M., J.C.  Mueller, and C.C. Walden, "Biodegradability of
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94.   Tracy,  J.C.,  "Secondary  Waste Treatment Nutrient and Aeration
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95.   Eckenfelder,  W.W.,  Jr.,  Industrial   Waste   Water   Control,
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97.  McKeown,  J.J.  and  D.B.  Buckley,  "Mixing  Characteristics  of
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98.  Chandrasekaran K.,  R.J.  Reis,  G.'C.  Tanner,  and  H.I.  Rogers,
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99.  McKeown, J.J., The  Effect  of_  Temperature  on  Treatment  Plant
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100.  Metcalf & Eddy, Inc., Wastewater Engineering,  McGraw-Hill  Book
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101.  Technical data supplied by Union Carbide Corp., Nov. 29, 1977.
                                 641

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102.  Harvey, E. and  H.  Vaandering,   "NSFI  Pilots  UNOX  System  for
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103.    Brock,  T.D.,  Biology  of_ Microorganisms, Prentice-Hall, Inc.,
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104.  Van Soest, R. and D. Guatam," Tertiary Treatment  Quality  for  a
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105.    Rice,  B.  and  R.  Van  Soest,  "Practical Experience of a New
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108.    Gillespie,  W.J.,  D.W.  Marshall,  and A.M. Springer, "A Pilot
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109.    T.W.  Beak  Consultants, Ltd.  and NCASI, Development  of. Biosurf
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110.   T.W. Beak Consultants, Ltd., Anaerobic  Contact  Filter  Process
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111.   McKinney, R.E., Microbiology for Sanitary Engineers, McGraw-Hill
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112.    Clark,  J.W.  and  W.  Viesman  Jr.,  Water Supply and Pollution
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114.    Vamvakias,  J.G.  and  J.P.   Miller,   "Temperature  Response of
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115.  T.W. Beak Consultants, Ltd., Biological Treatment  and  Toxicity
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116.   McKeown,  J.J.,  D.B.  Buckley,  and I. Gellman, "A Statistical
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119. Adams, C.E.  and  W.W.  Eckenfelder  Jr.,   "Nitrification  Design
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126.   Stumm,  W.  and   J.J.   Morgan,   Aquatic   Chemistry,   Wiley
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127.   Rebhun,  M.,  C.H. Saliternik, and H. Sperber, "Purification of
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128.   Ives, K.J., "Theory of Operation of Sludge Blanket Clarifiers,"
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                                643

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129.   Filtration and Chemically Assisted Clarification of Biologically
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130.  Rice, N., A.A. Kalinske,  and  W.I.  Arnold,  A  Pilot  Study  of
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131.  Personal Communication with  Dana  Dolloff,  International  Paper
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132.    Amberg,  H.R.,  I.  Gellman, and R.H. Scott, "The Status of Water
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133.  Scott,  R.H., "Sophisticated Treatment  of  Baikal  Pulp  Mill  in
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135.     Treatment   o_f_  Calcium-Organic  Sludges  Obtained  From  Lime
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136.    Oswalt, J. L.,  and J.G.  Land Jr., Color Removal from Kraft Pulp
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137.  Gould,  Matthew, "Color Removal from Kraft  Mill  Effluent  by  an
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138.  Gould,   Matthew,   "Physical-Chemical  Treatment  of   Pulp   Mill
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139.   Smith, O.D., R.M. Stein,  and C.E. Adams  Jr.,  "How  Mills  Cope
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140.   Peterson, R.R. and J.L. Graham, CH2M Hill,  Inc., Post Biological
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141.  Preliminary Data Base for Review of_  BATEA  Effluent  Limitations
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                                 644

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143. Cashen, R.F., St. Regis Paper  Co.,  Comments  on  E.C.  Jordan's
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144. Button, E.F., ITT Rayonier Inc., Comments on E.C. Jordan's  Draft
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145. Barton, Curtis A., The Proctor & Gamble  Co.,  Comments  on  E.C.
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146. National Council  of  the  Paper  Industry  for  Air  and  Stream
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147.  Olthof, M.G., "Color Removal from Textile  and  Pulp  and  Paper
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148.  Olthof, M.G. and W.W. Eckenfelder Jr., " A Laboratory  Study  of
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149.   Berov, M.B., et a1., "Optimum Conditions for Chemical Treatment
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152.  Vincent, D.L., Colour Removal From Biologically Treated Pulp and
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153.  Environmental Quality  Systems,  Inc.,  Technical  and  Economic
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155.   Timpe,  W.G.,  et al. ,  "Selection of Pilot Treatment Systems in
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156.  Bishop, D.F., e_t al., "Studies on Activated  Carbon  Treatment,"
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157.   Hansen,  S.P.  and  F.J.   Burgess,  "Carbon  Treatment of Kraft
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158. Timpe,  W.G.   and  E.W.  Lang,  "Activated  Carbon  Treatment  of
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159. Davis, John C.,  "Activated  Carbon  —  Prime  Choice  to  Boost
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160.   Callahan,   W.F.   and  A.B.  Pincince,   "An  Activated  Carbon
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161.   Taylor,  James L., "Full Scale Experience with Activated Carbon
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162. T.W. Beak Consultants, Ltd.,   Optimization  of  Physical-Chemical
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163.  Kimura  R.  and  K.  Izumisawa,  "Approach  to  Entirely  Closed
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164.  Smith,  D.R.   and H.F. Berger,  "Waste Water Renovation," TAPPI,
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165.  Weber, W.J.,  Jr. and J.C.  Morris,  "Kinetics  of  Adsorption  in
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166. DeWalle, F.B., E.S.K.  Chian,   and  E.M.  Small,  "Organic  Matter
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167. Button, David G., "Removal of Priority Pollutants with a Combined
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168.  Hutton,  D.G.  and  F.L.  Robertaccio,  U.S.  Patent  3,904,518,
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169. Crame, L.W., "Activated Sludge Enhancement:  A Viable Alternative
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171. Dehnert, J.F., "Case History -  The  Use  of  Powdered  Activated
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174. Ng, K.S.,  Pilot Plant Evaluation of Mechanical Foam Breaking and
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175. Brunner, C.A. and D.G. Stephan, "Foam Fractionation,"   Industrial
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176.  Miller,  J.K.P.  and  L.K.  Legatski,   "Investigation  of a High
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178. Walden, C.C. and J.C. Mueller, B.C. Research,   Investigation   of.
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179.  Bliss,  F.R.,  Polishing  of_  Paper  Mill  Effluents   by_ Micro-
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180.  Bliss,  F.R.,  Papermill Wastewater Treatment by_ Microstraining,
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181.  Oher,  Klaus,  "Electrochemical  Decolorization  of  Kraft  Mill
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                                 647

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182. Das Gupta, Sankar and S. Mohanta,  "Electrochemical  Process  for
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185.  Merer,  D.O.  and  F.E.  Woodard,   "Electrolytic Coagulation of
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186.  Chan,  A.,  D.W.  Herschmiller,   and D.R. Manolescu, Environcon,
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187.  Barclay,  H.G., C. Heitner, and S. Prahacs,  Review of_ Catalytic
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194.   Prahacs,  S., A. Wong, and H.G. Jones, "Amine Treatment Process
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196. Sanks, Robert L.  "Ion Exchange Color  and  Mineral  Removal  from
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198. Chriswell, C.D.,  et al.,  "Comparison of Macroreticular Resin and
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199. Kim, Byung R., V.L. Snoeyink, and F.M. Saunders,  "Adsorption  of
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200. Rogers, I.H., J.A. Servizi, and  R.W. Gordan, "An Effective Method
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203. Proposed Development Document for Effluent Limitations Guide!ines
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                                  649

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206.  Final Development Document for  Effluent  Limitations  Guidelines
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213.  Energy User News, A Fairchild Business Newspaper, Vol. 3, No. 32,
August 7,  1978.

214.  Engineering News Record, March 23, 1978.

215.   Monthly Energy Review, U.S. Department of Energy, March  1979.

216.  Process   Design   Manual   -   Municipal    Sludge    Landfills,
EPA-625/1-78-010, U.S. Environmental Protection Agency, October  1978.

217.  Chemical Marketing Reporter, November 6, 1978.

218.   Robert S. Means Co.,  Building Construction Cost Data 1979, 37th
Edition, 1978.

219.   A Survey of Pulp and  Paper  Industry  Environmental  Protection
Expenditures  and  Operating Costs-1976, National Council of the Paper
Industry for Air and Stream Improvement, Inc. (NCASI),  NCASI  Special
Report 77-06, August  1977.

220.  Edde, H., "Influence of Pulping Yield on the Cost of  Modernizing
Sulfite  Pulp  Mill  Liquor  Recovery,"  Proceedings of the 1978 TAPPI
Environmental Conference.
                                 650

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221.   The Energy Resources Company, Disposal  Practices  for  Selected
Industrial  Sol id  Wastes,  Final  Report  for  the U.S. Environmental
Protection Agency, Office of Solid Waste, Contract No. 68-01-5814, May
1980.

222.   McKeown, J.J.,  "Sludge  Dewatering  and  Disposal-A  Review  of
Practices  in  the U.S.  Paper Industry," TAPPI, Vol. 62, No. 8, August
1979.

223.   Communication between Joseph Aloisio and Mr. Howard Fullerton of
the U.S. Department of Labor, Bureau of Labor Statistics.
                                651

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                        CONVERSION TABLE
Multiply (English Units)           By
English Unit  	Abbreviation	Conversi on
  To Obtain (Metric Units)
Abbreviation  Metric Unit
acre
acre-feet
British Thermal
Unit
British Thermal
Unit/pound
cubic feet
per minute
cubic feet
per second
cubic feet
cubic feet
cubic inches
degree Farenheit
feet
gallon
gallon per
minute
gallon per ton
horsepower
inches
pounds per
ac
ac ft
BTU
BTU/lb
cfm
cfs
cu ft
cu ft
cu in
OF
ft
gal
gpm
gal/ton
hp
in
psi
0,405
1233.5
0.252
0.555
0.028
1.7
0.028
28.32
16.39
0.555(°F-32)*
0.3048
3.785
0.0631
4.173
0.7457
2.54
0.06803
ha
cu m
kg cal
kg cal /kg
cu m/min
cu m/min
cu m
1
cu cm
°C
m
1
I/sec
1/kkg
kw
cm
atm
hectares
cubic meters
kilogram-
calories
kilogram
calories
per kilo-
gram.
cubic meters
per minute
cubic meters
per minute
cubic meters
liters
cubic centi-
meters
degree
Centigrade
meters
liter
liters per
second
liters per
metric ton
kilowatts
centimeters
atmospheres
 square  inch
                 (absolute)
                              652

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                           (continued)
      Multiply (English Units)           By          To Obtain (Hetric Units
English Unit    Abbreviation    Conversion   Abbreviation  Metric Unit
million gallons
per day
pounds per square
inch (gauge)
pounds
board feet
ton
mile
square feet
MGD
psi
Ib
b.f.
ton
mi
ft2
3.7 x 10-3
(0.06805 psi + 1)*
0.454
0.0023
0.907
1.609
.0929
cu m/day
atm
Jcg
cu m, m3
kkg
km
m2
cubic meters
per day
atmospheres
kilograms
cubic meters
metric ton
kilometer
square meters
* Actual conversion, not a multiplier.
                                 653

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