EIA Guidelines for Pulp and Paper
and Timber Products
Environmental Impact Assessment Guidelines
for New Source NPDES Permits
Pulp, Paper, and Paperboard
and
Timber Products Processing
Point Source Categories
September 1994
U.S. Environmental Protection Agency
Office of Federal Activities
401 M Street, S.W.
Washington, D.C. 20460
R*eycl*d/R*cyclaM«« Printed with Vegetable OO Based Inks on 100% Recycled Paper (50% Postconsumer) • Please recycle as newsprint
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DISCLAIMER
This document was prepared for the U.S. Environmental
Protection Agency by Science Applications International
Corporation in partial fulfillment of EPA Contract No. 68-W2-
0026, Work Assignment 26-1. The mention of company or
product names is not to be considered an endorsement by the
U.S. Government or by the Environmental Protection Agency.
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EIA Guidelines for Pulp & Paper and Timber Table of Contents
TABLE OF CONTENTS
Page
1. INTRODUCTION 1-1
1.1 PURPOSE OF ENVIRONMENTAL ASSESSMENT GUIDELINES 1-1
1.2 SCOPE OF THE INDUSTRY 1-2
1.3 ORGANIZATION OF GUIDELINES 1-4
2. NEPA REQUIREMENTS AND PROVISIONS 2-1
2.1 OVERVIEW 2-1
2.1.1 EPA REQUIREMENTS FOR ENVIRONMENTAL REVIEW UNDER NEPA 2-2
2.1.2 ENVIRONMENTAL REVIEW PROCESS FOR NEW SOURCE NPDES PERMITS 2-4
2.2 TRIGGERS FOR NEPA REVIEW ACnVrTIES 2-7
2.2.1 PRIMARY CONDITIONS THAT TRIGGER NEPA REVIEW 2-7
2.2.1.1 New Source Determination 2-7
2.2.1.2 EPA is the Permitting Authority 2-7
2.2.2 WHEN is AN EIS REQUIRED? 2-8
2.2.3 THE RELATIONSHIP BETWEEN NEPA REVIEW AND NPDES PERMITTING AcnvrnES . . 2-9
2.3 LEVELS OF REVIEW . 2-10
2.3.1 ENVIRONMENTAL INFORMATION DOCUMENT (EID) 2-10
2.3.2 ENVIRONMENTAL ASSESSMENT DOCUMENTS (EA) 2-10
2.3.3 ENVIRONMENTAL IMPACT STATEMENTS (EISs) 2-10
2.4 INFORMATION REQUIRED FROM PERMIT APPLICANTS 2-12
2.5 TIME INVOLVED IN PREPARING AND PROCESSING NEPA DOCUMENTS 2-12
2.6 LIMITATIONS ON PERMIT APPLICANT ACTIONS DURING THE REVIEW PROCESS . 2-14
3. OVERVIEW OF THE INDUSTRY 3-1
3.1 GENERAL 3-1
3.1.1 PULP AND PAPER 3-1
3.1.1.1 Industry Subcategorization for the Purposes of NPDES 3-1
3.1.1.2 Geographic Distribution of Activity 3-7
3.1.1.3 Economic Overview ..'.....'. 3-10
3.1.2 TIMBER PRODUCTS PROCESSING 3-11
3.1.2.1 Industry Subcategorization for Purposes of NPDES 3-11
3.1.2.2 Raw Materials 3-14
3.1.2.3 Log Imports & Exports 3-15
3.1.2.4 Geographical Distribution of Activity 3-16
3.1.2.5 Economic Overview 3-18
3.2 MAJOR PROCESSES 3-19
3.2.1 PULP AND PAPER 3-19
3:2.1.1 Wood Preparation and Handling 3-20
3.2.1.2 Pulping 3-22
3.2.1.3 Chemical Recovery Process 3-33
3.2.1.4 Pulp Processing 3-34
3.2.1.5 Bleaching 3-35
3.2.1.6 Stock Preparation 3-37
3.2.1.7 Pulp, Paper, and Paperboard Making 3-38
3.2.2 TIMBER PRODUCTS PROCESSING 3-39
3.2.2.1 Log Storage 3-39
3.2.2.2 Log Washing 3-40
3.2.2.3 Barking 3^0
3.2.2.4 Veneer and Plywood 3-41
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3.2.2.5 Hardboard ,. '. 3-43
3.2.2.6 Wood Preserving ' 3-50
3.2.2.7 Sawmills and Planing Mills . 3-57
3.2.2.8 Finishing 3-58
3.2.2.9 Particleboard ' 3-62
3.2.2.10 Insulation Board . 3-64
3.2.2.11 Furniture Manufacturing 3-67
3.3 PROCESS WASTES , . 3-70
3.3.1 PULP AND PAPER 3-70
3.3.1.1 Wastewater 3-70
3.3.1.2 Pulp and Paper (Air Emissions) 3-80
3.3.2 TIMBER PRODUCTS PROCESSING 3-86
3.3.2.1 Log Storage 3-86
3.3.2.2 Log Washing 3-88
3.3.2.3 Debarking 3-88
3.3.2.4 Veneer and Plywood 3-89
3.3.2.5 Hardboard—Dry Process , .t 3-92
3.3.2.6 Hardboard-Wet Process 3-96
3.3.2.7 Wood Preserving 3-96
3.3.2.8 Sawmills 3-97
3.3.2.9 Finishing Operations '. 3-99
3.3.2.10 Particleboard Manufacturing 3-99
3.3.2.11 Insulation Board 3-103
3.3.2.12 Wood Furniture and Fixture Production 3-105
3.4 CONTROL TECHNOLOGIES 3-110
3.4.1 PULP AND PAPER 3-110
3.4.1.1 Pulp and Paper (Wastewater) 3-110
3.4.1.2 State of the Art Technology (Wastewater) 3-121
3.4.1.3 Pulp and Paper (Air) 3-124
3.4.1.4 Solid Waste 3-132
3.4.2 TIMBER PRODUCTS PROCESSING 3-137
3.4.2.1 Timber Products Processing (Wastewater Effluent) 3-137
3.4.2.2 Timber Products (Solid Waste) 3-138
3.5 POLLUTION PREVENTION 3-144
3.5.1 PULP AND PAPER 3-144
3.5.1.1 Wood Yard Operations 3-145
3.5.1.2 Pulping 3-146
3.5.1.3 Bleaching 3-150
3.5.1.4 Pulp Drying and Papermaking 3-152
3.5.1.5 Solids Handling 3-153
3.5.1.6 Flow Reduction . . . 3-153
3.5.2 TIMBER PRODUCTS PROCESSING 3-155
4. MAJOR ENVIRONMENTAL ISSUES ASSOCIATED WITH THE PULP AND
PAPER AND TIMBER PRODUCTS PROCESSING INDUSTRIES 4-1
4.1 IMPACTS ON WATER QUALITY AND QUANTITY 4-1
4.1.1 WATER QUALITY IMPACTS ASSOCIATED WITH PULP AND PAPER . ; 4-4
4.1.1.1 Pollutants of Concern 4-4
4.1.1.2 TCDD and TCDF 4-6
4.1.1.3 Other Toxic and Nonconventional Contaminants 4-7
4.1.1.4 AOX 4-7
4.1.1.5 Color .' 4-8
4.1.1.6 Conventional Pollutants v ,.... 4-8
4.1.2 WASTEWATER GENERATION—TIMBER PRODUCTS PROCESSING 4-10
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EIA Guidelines for Pulp & Paper and Timber Table of Contents
4.1.3 WATER QUALITY—TIMBER PRODUCTS PROCESSING . 4-10
4.1.3.1 Biochemical Oxygen Demand (BOD) 4-10
4.1.3.2 Total Suspended Solids (TSS) 4-10
: 4.1.3.3 Oil and Grease (O&G) 4-11
4.1.3.4 pH (Alkalinity - Acidity) 4-11
4.1.3.5 Chemical Oxygen Demand (COD) 4-12
4.1.3.6 Phenols and Chlorophenols 4-12
4.1.3.7 Creosote and Polynucleated Aromatic Hydrocarbons (PAHs) . . . 4-13
4.1.3.8 Temperature 4-14
4.1.3.9 Dissolved Solids (DS) . 4-15
4.1.3.10 Phosphorus 4-15
4.1.3.11 Ammonia 4-16
4.1.3.12 Copper . 4-16
4.1.3.13 Chromium 4-17
4.1.3.14 Arsenic 4-17
4.1.3.15 Zinc 4-18
4.1.3.16 Fluorides 4-18
4.2 IMPACTS ON AIR QUALITY 4-19
4.2.1 Am QUALITY IMPACT ASSOCIATED WITH PULP AND PAPER 4-19
4.2.2 AIR IMPACTS ASSOCIATED WITH TIMBER PRODUCTS PROCESSING 4-19
4.2.2.1 Emissions From Onsite Power and Steam Generation 4-20
4.2.2.2 Emissions From Solvent Use 4-20
4.2.2.3 Reconstituted Panel and Plywood Manufacturing 4-21
4.2.2.4 Hardboard Tempering 4-21
4.2.2.5 Spills and Accidental Releases 4-21
4.2.3 POTENTIAL'IMPACTS OF EMISSIONS 4-21
4.2.3.1 Participates 4-21
4.2.3.2 Sulfur Dioxide and Nitrogen Oxides 4-21
4.2.3.3 VOCs and Hazardous Air Pollutants 4-22
4.3 SOLID WASTE MANAGEMENT IMPACTS 4-22
4.3.1 SOLID WASTE MANAGEMENT ISSUES ASSOCIATED WITH PULP AND PAPER 4-22
4.3.2 SOLID WASTE MANAGEMENT ISSUES ASSOCIATED WITH TIMBER PRODUCTS
PROCESSING 4-23
4.3.2.1 Chlorophenols 4-23
4.3.2.2 Polynuclear Aromatic Hydrocarbons 4-24
4.3.2.3 Inorganics 4-25
4.3.2.4 PCDDs and PCDFs 4-26
4.4 ISSUES RELATED TO SITING AND CONSTRUCTION 4-26
4.5 SOCIO-ECONOMIC ISSUES : 4-26
4.6 AESTHETICS 4-29
4.7 NOISE 4-29
5. IMPACT ANALYSIS REQUIREMENTS 5-1
5.1 DETERMINE THE SCOPE OF ANALYSIS 5-1
5.2 IDENTIFY ALTERNATIVES 5-2
5.2.1 ALTERNATIVES AVAILABLE TO EPA 5-3
5.2.2 ALTERNATIVES CONSIDERED BY THE APPLICANT 5-3
5.2.3 ALTERNATIVES AVAILABLE TO OTHER PERMITTING AGENCIES 5-4
5.3 DESCRIBE THE AFFECTED ENVIRONMENT 5-4
5.3.1 THE PHYSICAL-CHEMICAL ENVIRONMENT 5-5
5.3.1.1 Air Resources 5-5
5.3.1.2 Water Resources 5-6
5.3.1.3 Soils and Geology 5-7
5.3.2 BIOLOGICAL CONDITIONS 5-8
5.3.2.1 Vegetation 5-8
5.3.2.2 Wildlife 5-8
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Table of Contents EIA Guidelines for Pulp & Paper and Timber
5.3.2.3 Ecological Interrelationships . 5-9
5.3.3 SOCIOECONOMIC ENVIRONMENT . . . 5-9
5.3.3.1 Community Services 5-10
5.3.3.2 Transportation 5-10
5.3.3.3 Population 5-10
5.3.3.4 Employment 5-11
5.3.3.5 Health and Safety ; 5-11
5.3.3,.6 Economic Activity !..... 5-11
5.3.4 LAND USE . . 5-12
5.3.5 AESTHETICS 5-12
5.3.6 CULTURAL RESOURCES 5-12
5.4 ANALYZE POTENTIAL IMPACTS 5-12
5.4.1 METHODS OF ANALYSIS 5-13
5.4.2 DETERMINATION OF SIGNIFICANCE " 5-14
5.4.3 COMPARISONS OF IMPACTS UNDER DIFFERING ALTERNATIVES 5-16
5.4.4 SUMMARY DISCUSSIONS 5-16
5.5 DETERMINE MITIGATING MEASURES 5-17
5.6 CONSULTATION AND COORDINATION 5-18
6. REGULATORY OVERVIEW 6-1
6.1 CLEAN WATER ACT 6-1
6.1.1 PROCESS WATER 6-1
6.1.1.1 New Source Performance Standards (NSPS) . . . 6-2
6.1.1.2 Pretreatment Standards for New Sources (PSNS) 6-3
6.1.2 STORM WATER 6-7
6.2 CLEAN AIR ACT 6-8
6.2.1 CURRENT CLEAN Am ACT REQUIREMENTS : 6-10
6.2.2 CHANGES TO TAKE EFFECT AS 1990 AMENDMENTS ARE PHASED IN 6-13
6.3 RESOURCE CONSERVATION AND RECOVERY ACT 6-15
6.3.1 NON-HAZARDOUS WASTE REQUIREMENTS - SUBTITLE D 6-16
6.3.2 HAZARDOUS WASTE REQUIREMENTS - SUBTITLE C 6-16
6.3.3 LAND DISPOSAL RESTRICTIONS 6-17
6.3.4 RECYCLING AND REUSE EXEMPTIONS AND PROVISIONS 6-17
6.3.5 HAZARDOUS WASTE GENERATORS 6-17
6.3.6 HAZARDOUS WASTE TREATMENT, STORAGE, AND DISPOSAL FACILITIES 6-18
6.4 ENDANGERED SPECIES ACT 6-20
6.5 NATIONAL HISTORIC PRESERVATION ACT AND EXECUTIVE ORDER 11593 6-20
6.6 EXECUTIVE ORDER 11988 6-21
6.7 EXECUTIVE ORDER 11990 '. 6-21
6.8 WILD AND SCENIC RIVERS ACT 6-22
6.9 FISH AND WILDLIFE COORDINATION ACT 6-22
6.10 RIVERS AND HARBORS ACT 6-23
6.11 COASTAL ZONE MANAGEMENT ACT 6-23
6.12 POLLUTION PREVENTION ACT OF 1990 6-23
6.13 FARMLAND PROTECTION POLICY ACT 6-24
6.14 OTHER STATUTES 6-24
7. REFERENCES 7-1
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EIA Guidelines for Pulp & Paper and Timber Table of Contents
LIST OF EXHmiTS
Exhibit Page
2-1. NEPA Environmental Review Process for Proposed Issuance of New Source
NPDES Permits , 2-5
2-2. Model Schedules for EAs and EISs for Proposed Issuance of New Source
NPDES Permits . 2-13
3-1. Comparison of Existing and Proposed Effluent Limitation Guidelines 3-5
3-2. Geographic Profile of Pulp, Paper, and Paperboard Mills 3-8
3-3. Interrelationships of Major Product Processes of the Timber Products Processing
Industry 3-12
3-4. Net Volume of Sawtimber on Commercial Timberland by Region and Type in Board
Feed 3-16
3-5. Number of Facilities Located in Each EPA Region by SIC Code 3-17
3-6. Characteristics Mechanical Pulping 3-23
3-7. Mechanical Pulp Nomenclature and Pulping Methodology 3-24
3-8. Chemical Pulp Characteristics 3-27
3-9. Hybrid Pulping Characteristics 3-31
3-10. Detailed Process Flow Diagram for Veneer and Plywood Production 3-42
3-11. Schematic Representation of a Typical Dry Process Hardboard Mill '. . . . . 3-44
3-12. Schematic Representation of a Typical Wet Process Hardboard Mill 3-45
3-13. Basic Raw Materials Handling Sequence in the Hardboard Mill 3-46
3-14. Flow Diagram of a Typical Wet Process Hardboard Mill SIS Hardboard Production
Line 3-48
3-15. Flow Diagram of a Typical Wet Process Hardboard Mill S2S Hardboard Production
Line ' 3-49
3-16. Flow Diagram of Pressure/Vacuum Treatment Processes 3-54
3-17. Flow Diagram of Nonpressure Treatment Processes 3-55
3-18. Process Flow Diagram of Rough Green Sawmill 3-59
3-19. Process Diagram of Typical Band Sawmill 3-60
3-20. Process Diagram for a Typical Multiple Headrig Sawmill 3-61
3-21. Particleboard Process Flow Diagram 3-63
3-22. Flow Diagram for a Typical Insulation Board Process 3-65
3-23. Furniture Manufacturing Process Diagram—Prefinishing 3-68
3-24. Furniture Manufacturing Process Diagram—Finishing 3-69
3-25. Approximate Percentage of Total Industry Water Use and Wastewater Discharged by
Process Area 3-71
3-26. Average Production Normalized Flow Discharged in Treatment by Process Area and
Subcategory 3-72
3-27. Wastewater Generation Rate from Wood Preparation by Proposed NPDES Subcategory
(nWOMMT) 3-74
3-28. Woodyard Effluents During Wet Barking Operations 3-74
3-29. Wastewater Generation Rate from Chemical Pulping Proposed NPDES Subcategory
(m3/OMMT) 3-75
3-30. The Effects of Furnish and Waste Liquor Handling on Sodium Base NSSC Effluents . . . 3-76
3-31. Range of BOD5 Loads in Effluents of Groundwood Processes 3-77
3-32. Typical Vent and Wastewater Stream Characteristics For Kraft Pulping Emission Points . 3-81
3-33. Typical Uncontrolled Emission Factors For Kraft Pulping Facilities 3-82
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Table of Contents EIA Guidelines for Pulp & Paper and Timber
3-34. Composition of Raw Leachate From Logs in Water Storage for Seven Days ;. 3-87
3-35. Overview of Wastewater Generation and Characteristics for the Veneer and Plywood
. Industry 3-90
3-36. Characteristics of Steam Vat and Hot Water Steam Vat Raw Discharges 3-91
3-37. Analysis of Waste Loads Characteristic of Veneer Dryers 3-92
3-38. Ingredients of Typical Protein, Phenolic, and Urea Glue Waste 3-93
3-39. Average Chemical Analysis of Plywood Glue Wastewater (assuming a 20:1 dilution
with water) 3-94
3-40. Dry Process Hardboard Wastewater Flow and Source '. . .' 3-95
3-41. Analytical Data for Wastewaters From Creosote and Pentachlorophenol Treatments .... 3-98
3-42. Typical Sources and Volumes of Wastewater Generation From Finishing Plants 3-100
3-43. Estimated Flow Rates for Particleboard Plant Process and Cooling Water 3-101
3-44. Analysis of Major Wastewater Streams by Parameter for Various Particleboard
Manufacturing Plants 3-104
3-45. Characteristics of Wastewaters Produced by Various Insulation Board Plants 3-106
3-46. Wastewater Production Data for Various Furniture Plants 3-107
3-47. Analysis of Wastewater Characteristics Associated With the Major Waste Streams
From the Wood Furniture Industry . 3-108
3-48. Summary of Primary and Biological Wastewater Treatment Systems In Place at Pulp
and Paper Mills 3-111
3-49. Summary of Wastewater Treatment In Place at Direct-Discharging Mills, by
Subcategory 3-112
3-50. Summary of Primary Wastewater Treatment In Place at Pulp and Paper Mills' ...... 3-115
3-51. Types of Activated Sludge Processes In Place at Pulp and Paper Mills 3-117
3-52. Typical Operating Parameters for Activated Sludge Systems In Place at Pulp and Paper
Mills 3-118
3-53. Summary of Existing Techniques to Control Hazardous Air Pollutant (HAP) Emissions
From Pulping Vent Sources 3-125
3-54. Percent of Kraft Mills Using Combustion Control Devices 3-126
3-55. Summary of Sludge Handling/Dewatering Operations In Place at Pulp and Paper Mills . 3-134
3-56. Sludge Disposal Methods Used by Pulp and Paper Mills 3-136
4-1. Chemicals Reported as Released and Transferred in 1992 by Facilities in SIC
Code 26 (Pulp and Paper Manufacturing) 4-2
4-2. Chemicals Reported as Released and Transferred in 1992 by Facilities in SIC
Codes 24 (Wood Products) and 25 (Furniture Manufacturing) 4-3
6-1. New Source Performance Standards For The Timber Products Processing Industry .... 6-4
6-2. Federal New Source Performance Standards for the Pulp, Paper, and Paperboard
Point Source Category 6-5
6-2. Federal New Source Performance Standards for the Pulp, Paper, and Paperboard
Point Source Category (Continued) , 6-6
6-3. National Primary and Secondary Ambient Air Quality Standards (40 CFR Pan 50) .... 6-9
6-4. New Source Performance Standards for Particulates from Kraft Pulp Mills 6-12
6-5! New Source Performance Standards for Total Reduced Sulfur (TRS) for Kraft
Pulp Mills 6-13
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EIA Guidelines for Pulp & Paper and Timber Environmental Issues
1. INTRODUCTION
The National Environmental Policy Act of 1969 (NEPA, 42 U.S.C §4321 et seq.) was the first of
what has come to be an array of statutes whose individual and collective goals are the protection of
the human and natural environment from a variety of impacts that human activity can have. NEPA
requires Federal agencies to consider the environmental consequences of their actions and decisions as
they carry out their mandated functions. For "major Federal actions significantly affecting the quality
of the human environment," the Federal agency must prepare a detailed environmental impact
statement that assesses not only the proposed action but also reasonable alternatives.
The Federal Water Pollution Control Act (33 U.S.C. §§1251-1387), better known as the Clean Water
Act, seeks to restore and maintain the chemical, physical, and biological integrity of the Nation's
waters. One of the major mechanisms, to attain that goal, is the requirement that all point; source
discharges of pollutants to waters of the United States be controlled through permits issued under the
National Pollutant Discharge Elimination System (NPDES).
The Clean Water Act [§Sll(c)(l>] also requires that the issuance of a new source NPDES permit, by
the Environmental Protection Agency (EPA), be subject to NEPA. In 1979, EPA established
regulations to apply NEPA in such cases: "Environmental Review Procedures for the New Source
NPDES Program," 40 CFR 6 Subpart F. These regulations require EPA to prepare a written
environmental assessment based on information provided by the NPDES permit applicant and other
available documentation. If the environmental assessment concludes that no significant impacts will
result from the new source; EPA will issue a Finding of No Significant Impact (FNSI). If the
assessment concludes that there may be significant environmental impacts that cannot be eliminated by
changes in the proposed project, EPA must prepare (or participate hi the preparation of) an
environmental impact statement (EIS) that contains the information and analyses described in 40 CFR
Part 6 Subpart B and conforms with Council on Environmental Quality regulations (40 CFR Part
1502) governing NEPA compliance.
In preparing the initial environmental assessment (EA), EPA relies on information and analyses
provided by the applicant for the new source NPDES permit in an "environmental information
document." The scope and content of an EA is determined by EPA in consultation with the
applicant, with the regulatory caution that EPA "...keep requests for data to the minimum consistent
with his responsibilities under NEPA" [40 CFR 6.604(b)].
1.1 PURPOSE OF ENVIRONMENTAL ASSESSMENT GUIDELINES
Following the promulgation of New Source Performance Standards in the late 1970s and early 1980s,
EPA prepared a series of "Environmental Impact Assessment Guidelines" for use in determining the
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Environmental Issues EIA Guidelines for Pulp & Paper and Timber
scope and contents of EAs. The guidelines were intended to assist EPA staff in reviewing and
commenting on an applicant's environmental information document (EID) and in preparing,
overseeing the preparation of, or commenting on environmental assessments.
Two of the environmental assessment guidelines prepared by EPA addressed the forest products
industry: one addressed pulp and paper mills' and the other addressed timber product processing
facilities2. EPA's Office of Federal Activities, in cooperation with other EPA offices and Regions, is
now revising and updating these guidelines to incorporate new information. The intent is to make
them more useful in identifying and evaluating the potential environmental impacts from proposed
pulp and paper and timber products facilities. Because many of the potential impacts are common to
the pulp and paper and timber products processing industries, the two previous guidelines documents
have been combined into this single document.
These guidelines are expressly intended to provide background information for EPA staff, and new
source NPDES permit applicants, in the scope and contents of EAs. In addition, EPA anticipates
several other audiences for these guidelines including: EPA staff who review and comment on other
Federal agencies' environmental impact statements and regulations pursuant to §309 of the Clean Air
Act; new source NPDES permit applicants who must prepare an EID for EPA; other Federal agencies
responsible for regulating or overseeing the pulp and paper and timber products processing industries;
and State, local, and foreign government environmental officials. Officials in States that have been
authorized to implement the NPDES program may also find these guidelines useful in their review of
permit applications.
These guidelines supplement the more general document, Environmental Impact Assessment
Guidelines for Selected New Source Industries, which provides general guidance for preparing EAs
and presents impact assessment considerations that are common to most industries, including the pulp
and paper and timber products processing industries.
1.2 SCOPE OF THE INDUSTRY
Forests have always been an important natural resource in North America. One-third of the United
States is covered with forests. Of the nation's 2.3 billion acres of land, nearly 731 million acres are
forested. Current forest land amounts to slightly over two-thirds of the 1.04 billion acres of forest
land that was present in 1600 (USDA, 1993). Most of the roughly 307 million acres of forest cleared
1 U.S.. Environmental Protection Agency, Office of Environmental Review. 1979 (September). Environmental Impact
Assessment Guidelines for New Source Pulp and Paper Mills. EPA-130/6-79-002.
2 U.S. Environmental Protection Agency, Office of Federal Activities. 1981 (November). Environmental Impact
Assessment Guidelines for New Source Timber Products Processing Facilities. Prepared by Wapora, Inc. under contract 68-
01-4157.
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EIA Guidelines for Pulp & Paper and Timber Environmental Issues
since then have been converted to agriculture. Much of this conversion took place in the nineteenth
century; by the 1920s, the decline had largely halted. The acreage of forest in the United States has
remained roughly constant since that time. There is limited information available on the proportion of
old growth vs. secondary growth in the United States as a whole. Inventories for California, Orgeon,
and Washington, however, indicate that while total forest cover in those States decreased from 66
million acres to 63 million acres during the period from the 1930s until present, percentage of old
growth declined from 49 percent to 18 percent (Bolsinger, 1994).
Nearly 500 million acres of United States forest are primarily managed for the production of timber.
Therefore, the pulp and paper and timber products processing industry is a large and economically
important industrial sector. Owing to significant differences in climate and physiography, the timber
supply is not distributed equally throughout the country. For example, regions with abundant rainfall
tend to have lush forest growth with high productivity. In the United States, the principal timber
producing regions include the Northeast, North Central, Southeast, South Central, and Pacific
Northwest regions.
The United States has the world's largest per capita consumption of forest products. The pulp and
paper and timber products processing industries include diverse operations that range from the cutting
of timber to the production of a product. The basic raw material common to all pulp and paper and
timber product processing facilities is wood.
EPA has promulgated NDPES effluent limitations guidelines for discharges of pollutants from existing
and new sources in Timber Products Processing Point Source Category (40 CFR Pan 429). These
effluent limitation guidelines provide numeric limitations on discharges from timber products facilities
in various industry subcategories. The timber products processing point source category is defined by
Standard Industrial Classification (SIC) Major Groups 24 and 25. The industry segments that are
addressed in these guidelines include:
• SIC 2411 Logging
• SIC 2421 Sawmills and Planing Mills, General
• SIC 2426 Hardwood Dimension and Flooring Mills
• SIC 2429 Special Mill Products, Not Elsewhere Classified
• SIC 2431 Millwork
• SIC 2434 Wood Kitchen Cabinets
• SIC 2435 Hardwood Veneer and Plywood
• SIC 2436 Softwood Veneer and Plywood
• SIC 2491 Wood Preserving
• SIC 2511 Wood Household Furniture, Except Upholstered
• SIC 2512 Wood Household Furniture, Upholstered
• SIC 2517 Wood Television, Radio, Phonograph, and Sewing Machine Cabinets
• SIC 2521' Wood Office Furniture
• SIC 2531 Public Building and Related Furniture
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Environmental Issues EIA Guidelines for Pulp & Paper and Timber
•• SIC 2541 Wood Office and Store Fixtures, Partitions, Shelving, and Lockers
• SIC 2661 Building Paper and Building Board Mills.
Discharges of pollutants from existing and new source pulp and paper facilities are limited by the
Pulp, Paper, and Paperboard Point Source Category (40 CFR 430). The effluent limitation guidelines
promulgated in this category provide numeric limitations on discharges from pulp, paper, and
paperboard mills. The pulp and paper industry is defined by Standard Industrial Classification (SIC)
Major Group 26. The industry segments that are addressed in these guidelines include:
• SIC 2611 Pulp Mills
• SIC 2621 Paper Mills
• SIC 2631 Paperboard Mills.
1.3 ORGANIZATION OF GUIDELINES
This remainder of this document is organized as follows. Chapter 2 describes NEPA requirements
and provisions. This chapter provides a brief historical overview of EPA's NEPA environmental
review procedures and identifies the activities that trigger EPA environmental reviews. In addition,
this chapter identifies the types of information required from permit applicants and EPA's review and
ensuing actions.
Chapter 3 describes NPDES subcategorization groupings, major processes, and pollution prevention
and control technologies found at pulp and paper mills and timber products processing facilities.
Each subsection discusses the pulp and paper and timber products processing industries separately.
Chapter 4 discusses the major environmental issues and impacts that are of concern when evaluating
proposed pulp and paper or forest products processing operations. This chapter assesses water
quality, air quality, solid waste management, socio-economic, aesthetic, and noise issues. Water
quality, air quality, and solid waste management issues are addressed separately for each industry. -
Socio-economic, aesthetic, and noise issue are addressed jointly because of the potential similarity in
impacts caused by constructing or operating pulp and paper and timber product processing facilities.
The process of analyzing impacts within the context of NEPA and new source NPDES permits is
described in Chapter 5. Separate subsections describe each of the major steps in the impact analysis.
Chapter 6 provides information on the major Federal environmental and natural resource management
statutes that directly affect pulp and paper or timber products processing operations. The purpose and
broad goals of each of these statutes are described, along with a brief indication of the requirements
imposed by the statute and the implementing agency's regulatory or consultation programs.
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EIA Guidelines for Pulp & Paper and Timber Environmental Issues
Finally, references cited in the document are listed in Chapter 6, as are a number of other valuable
references. Appendix A presents an outline, in the form of a "checklist," of the types of information
and analyses that should go into an environmental impact assessment. Appendix B presents a glossary
of terms.
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EIA Guidelines for Pulp & Paper and Timber NEPA Requirements and Provisions
2. NEPA REQUIREMENTS AND PROVISIONS
2.1 OVERVIEW
NEPA serves as the basic national charter for environmental protection. Section 102 of NEPA
establishes environmental review requirements for Federal actions. These reviews or impact
assessments are required to be broad in scope, addressing the full range of potential effects of a
proposed action on the human and natural environment. A general framework for implementing these
requirements is presented in regulations issued by the Council on Environmental Quality (CEQ).
Federal agencies, in turn, have developed their own rules for NEPA compliance that are consistent
with the CEQ regulations but address their specific missions and program activities. Over the past 25
years, the NEPA framework for environmental review of proposed Federal actions has been
substantially refined, based on further congressional directives, action by CEQ, and an extensive body
of case law.
Congress has determined that most EPA activities are exempt from impact assessment requirements
under NEPA. In the case of EPA's water quality programs, Section Sll(c) of the Clean Water Act
(CWA) clearly specifies that actions taken by EPA under the Act shall not "be deemed a major
Federal Action significantly affecting the quality of the human environment within the meaning of the
National Environmental Policy Act of 1969." However, the Congress did make two important
exceptions to this exemption:
(1) the provision of financial assistance for the construction of publicly owned treatment works
(2) the issuance of NPDES permits for new sources as defined in Section 306 of the CWA.
The specific reference to NPDES new source permits makes clear EPA's responsibility to review
proposed permit issuance actions from the broader perspective of the NEPA environmental assessment
framework.
Since EPA does have responsibility for conducting environmental reviews for some types of proposed
activities, the Agency has developed and codified its own set of NEPA procedures. EPA's current
procedures occurred in several rulemakings described below;
• Initial EPA proposed rulemaking setting forth procedures for the preparation of EISs (37 FR
879; January 20, 1972)
• Interim EPA regulations—Preparation of Environmental Impact Statements (38 FR 1696;
January 17, 1973)
• Notice of proposed rulemaking—Preparation of EISs (39 FR 26254; July 17, 1974). This
proposed rulemaking reflects substantial public comment on the interim regulations as well
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NEPA Requirements and Provisions EIA Guidelines for Pulp & Paper and Timber
as additional CEQ requirements. The rulemaking addresses EPA's nonregulatory programs
only.
• Final EPA regulations on the preparation of Environmental Impact Statements (40 FR
16814, April 14, 1975). Although procedures for new source NPDES permits are not
included in this rulemaking, EPA notes in the preamble that such regulations will be
subsequently issued in 40 CFR Part 6.
• Preparation of Environmental Impact Statements, New source NPDES permits (42 FR 2450,
January 11, 1977). Presents an outline for the preparation of EISs for proposed new source
permitting action.
• Proposed rule—Implementation of Procedures on the National Environmental Policy Act (44
FR 35158; June 18, 1979). In response to major revision of CEQ's regulations in 1978,
EPA revises its procedures, accordingly. The revised procedures include streamlining and
clarification of procedures in general. In addition, requirements for NPDES new source
permitting actions were substantially revised and presented as Subpart F of the proposed
rule.
• Final rule—Implementation of Procedures on NEPA (44 FR 64174, November 6, 1979).
Issues raised during promulgation include limitation of construction activities during
permitting process and environmental review and the conditioning or denying of permits
based on factors identified during the NEPA review process.
• Minor changes to Subpart F, involving the changing of citations, were made on September
12, 1986 (51 FR 32606).
2.1.1 EPA REQUIREMENTS FOR ENVIRONMENTAL REVIEW UNDER NEPA
EPA's current National Environmental Policy Act Procedures (40 CFR 6) outline the Agency's
policies and processes for meeting environmental review requirements under NEPA. Subpart A of
the Procedures provides an overview of the Agency's purpose and policy, institutional responsibilities,
and general procedures for conducting reviews. Subpart A outlines EPA's basic hierarchy of NEPA
compliance documentation as follows:
• Environmental Information Document (EID), which is a document prepared by
applicants, grantees, or permittees and submitted to EPA. This document must be sufficient
in scope to enable EPA to prepare an environmental assessment.
• Environmental Assessment (EA), which is a concise document prepared by EPA that
provides sufficient data and analysis to determine whether an EIS or finding of no
significant impact is required.
• Notice of Intent (NOI), which announces the Agency's intent to prepare an EIS. The NOI,
which is published in the Federal Register, reflects the Agency's finding that the proposed
action may result in "significant" adverse environmental impacts and that these impacts can
not be eliminated by making changes in the project.
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EIA Guidelines for Pulp & Paper and Timber NEPA Requirements and Provisions
• Environmental Impact Statement (EIS), which is a formal and detailed,.analysis of
alternatives including the proposed action, is undertaken according to CEQ requirements
and EPA procedures.
• Finding of No Significant Impact (FNSI), which announces EPA's finding that the action
analyzed in an EA (either as proposed or with alterations or mitigating measures) will not
result in significant impacts. The FNSI is made available for public review, and is typically
attached to the EA and included in the administrative record for the proposed action.
• Record of Decision (ROD), which is a statement published in the Federal Register that
describes the course of action to be taken by an Agency following the completion of an
EIS. The ROD typically includes a description of those mitigating measures that will be
taken to make the selected alternative environmentally acceptable.
• Monitoring, which refers to EPA's responsibility to ensure that decisions on any action
where a final EIS is prepared are properly implemented.
Subpart B of EPA's Procedures provides a detailed discussion of die contents of EISs. This subpart
of the text specifies format and the contents of an executive summary, the body of the EIS, material
incorporated by reference and a list of preparers.
Subpart C of the Procedures describes requirements related to coordination and other environmental
review and consultation requirements. NEPA compliance involves addressing a number of particular
issues, including (1) landmarks, historical, and archaeological sites; (2) wetlands, floodplains,
important farmlands, coastal zones, wild and scenic rivers, fish and wildlife, and endangered species;
and (3) air quality. Formal consultation with other agencies may be required, particularly in the case
of potential impacts on threatened and endangered species and potential impacts on historic or
archaeological resources.
Subpart D of die Procedures presents requirements related to public and other Federal agency
involvement. NEPA includes a strong emphasis on public involvement in the review process.
Requirements are very specific with regard to public notification, convening of public meetings and
hearings, and filing of key documents prepared as pan of the review process.
Subpart F presents environmental review procedures for the New Source NPDES Program. This
Subpart specifies that die requirements summarized above (Subparts A through D) apply when two
basic conditions are met: (1) the proposed permittee is determined to be a new source under NPDES
permit regulations; and (2) die permit would be issued within a State where EPA is the permitting
authority (i.e., diat State does not have an approved NPDES program in accordance with section
402(b) of the (TWA). This Subpart also requires diat the processing and review of an applicant's
NPDES permit application must proceed concurrently with environmental review under NEPA.
Procedures for the environmental review process are outlined. Subpart F also provides criteria for
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NEPA Requirements and Provisions EIA Guidelines for Pulp & Paper and Timber
determining when EISs must be prepared, as well as rules relating to the preparation-, of RODs and
monitoring of compliance with provisions incorporated within the NPDES permit. (A more detailed
discussion of the environmental review process and triggers for certain specific environmental
assessment requirements are presented later in this chapter.)
The remaining Subparts of the EPA Procedures (i.e., Subparts E, G, H, I, and J) address aspects of
EPA's environmental review procedures that are not relevant to these guidelines for the proposed
issuance of new source NPDES permits.
2.1.2 ENVIRONMENTAL REVIEW PROCESS FOR NEW SOURCE NPDES PERMITS
As illustrated by Exhibit 2-1, the NEPA review of proposed new source permitting actions and the
process of NPDES permit issuance are to occur concurrently. However, completion of the
environmental review—either through the issuance of a FNSI or the issuance of a ROD—is to precede
actual permit issuance or denial.
As discussed in detail in a following section, EPA first must ensure that the two primary conditions
that trigger NEPA environmental review have been met. EPA Regional office staff then would
consult with the permit applicant to determine the scope of the information document; and upon
request by the permit applicant, to set time limits on the completion of the review process consistent
with 40 CFR 1501.8. (Information required from permit applicants is addressed in more detail later
in this chapter.)
Once the permit applicant has submitted the BID, EPA Regional office staff must review the
information provided by the applicant along with any other available information that is relevant.
EPA Regional staff men must prepare a written EA which identifies alternatives, including the
proposed action, presents a concise analysis of the potential impacts of these alternatives, and
identifies any mitigation measures that could be (or will be) undertaken to address potential significant
impacts.
The EA will result in one of two possible outcomes. If the review indicates that the proposed
issuance of the new source permit is likely to result in "significant" adverse impacts that cannot be
avoided through changes in the proposal, then EPA must initiate the more formal process of EIS
preparation. Should the EA review indicate that the proposed action would be unlikely to result in
significant adverse impacts or that those impacts could be avoided by modifying the proposal, EPA
would issue a FNSI.
A FNSI, which identifies any mitigation measures necessary to make a project environmentally
acceptable, must be made available for public review (typically through publication in the Federal
Register) and comment before issuing the permit.
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EIA Guidelines for Pulp & Paper and Timber
NEPA Requirements and Provisions
Exhibit 2-1. NEPA Environmental Review Process for Proposed Issuance
of New Source NPDES Permits
Pnm&y Condnfoiw tfwf Tnfffftf MCR4 £nv*Vo/inMni
i NPOES peimit cMemtined to to *MW touree
• Peimit would be iaaued in • atate whan EPA ia Remitting authority I
n EA4 and PamHAppOe*it
• SoopingAMnminatian of Momulion requirements
t of ton* limitj on review pronss
EPARmww
o(EID«od
OttMrAtmilabl*
Contuteten with ottwr
potMttally Mcmiltd Fcdtml
•g«nc>*s. dt«gn*tion of
lMd/caop«rating igwiews
lMuano*o(NOI
to Prepare EIS
ldMi%Altonwtiv*t
Seeping Itocting
Preparation of
DranEIS
inutdtorOmtt
NPDCSptimt
PubKcHMiing
Cammtnt Ptriod
R*«pon**to
Comments
Preparation of
RnalEIS
Preparation of
ROD
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September 1994
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NEPA Requirements and Provisions EIA Guidelines for Pulp & Paper and Timber
The process of preparing an EIS is a more complex and formal process that begins with EPA's
consultation with any other Federal agencies that may be involved in the project. Should EPA be
designated as "lead" agency for the EIS, EPA would then begin the process by publishing an NOI in
the Federal Register. EPA also may consult with the permit applicant at this point to discuss the
option of preparing the EIS through a "third-party method." If the applicant and EPA agree on this
method (and this agreement must be expressed in writing), the applicant would then engage and pay
for the services of a third-party contractor to prepare the EIS. Such an agreement will eliminate the
need for further independent preparation of EIDs by the applicant. EPA, in consultation with the
applicant, would choose the contractor, which must provide appropriate disclosure statements attesting
to a lack of financial or other conflicting interest in the outcome of the- EIS. EPA would manage the
contractor and would have sole authority for approval and modification of EIS conclusions.
At this early stage of the process, a preliminary set of alternatives would be identified, based on
several perspectives:
• Alternatives considered by the applicant
• Alternatives available to EPA
• Alternatives available to other agencies with jurisdiction over the facility,
Next is the scoping process, which involves identifying key issues, refining the list and description of
alternatives, and setting general parameters for. the data and analyses that will be required to complete
the assessment. Public involvement and interagency coordination are important parts of the scoping
process, which typically involves the convening of a scoping meeting attended by interested parties.
If a third-party contractor is to prepare the EIS, the contractor is not to begin work until after the
scoping meeting is held.
Following the scoping process, the potential impacts of alternatives, including the proposed action,
are analyzed and a Draft EIS (DEIS) is prepared in accordance with strict format and content
requirements. In the course of DEIS preparation, a number of specific coordination and consultation ,
requirements must be met. These include informal and/or formal consultation with the U.S. Fish and
Wildlife Service (and/or the National Marine Fisheries Service) regarding threatened and endangered
species issues as well as formal consultation with the State Historic Preservation Offices (SHPO) on
any relevant cultural and historic resource issues.
After the DEIS is reviewed internally by EPA, the public and interested parties are notified of its
availability through a Federal Register notice, notices in local newspapers, and letters to participants
in the scoping process. EPA also would conduct one or more public hearings to further solicit
comments on the DEIS.
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EIA Guidelines for Pulp & Paper and Timber
NEPA Requirements and Provisions
Following the comment period for the DEIS, EPA (or the third-party preparers as directed by EPA)
would respond to all comments and would prepare the final EIS (FEIS). After internal EPA review
of the FEIS, notification again is made through the Federal Register, notices, and letters to interested
parties. A final review period allows for any additional comments by the public and interested
government agencies.
The last step hi the EIS process is the preparation of die ROD, which summarizes the permitting
action that will be taken, as well as any mitigation measures that will be implemented to make the
selected alternative environmentally acceptable. (A discussion of the relationship between the NEPA
review and the permitting procedures is presented later in this chapter.)
2.2 TRIGGERS FOR NEPA REVIEW ACTIVITIES
2.2.1 PRIMARY CONDITIONS THAT TRIGGER NEPA REVIEW
As noted earlier in this chapter, the following two major conditions must be met before NEPA review
requirements apply.
2.2.1.1 New Source Determination
A proposed NPDES permittee must be determined to be a "new source" before NEPA review
requirement apply. The determination is made by the EPA Region in accordance with NPDES permit
regulations under 40 CFR 122.210) and 122.29(a) and (b).
2.2.1.2 EPA is the Permitting Authority
The second major condition that must be met before NEPA review requirements apply is that EPA is
the permitting authority. Under NPDES, States and Native American tribes with an approved
program may administer the permitting program. In such cases, the proposed issuance of a new
source permit would not be a Federal action (unless EPA issues a permit in an approved-program
State pursuant to 40 CFR 123.44(h)). Thus, NEPA requirements would not apply. As of mid-1994,
the NPDES permit program is administered in 40 States. In addition to tribal lands, States and other
jurisdictions where EPA is the permitting authority and where NEPA review requirements would
apply are listed below:
Alaska
Arizona
District of Columbia
Florida
Idaho
Louisiana
Maine
Massachusetts
New Hampshire
New Mexico
Oklahoma
Texas
American Samoa
Guam
Puerto Rico
U.S. Virgin Islands
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September 1994
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NEPA Requirements and Provisions EIA Guidelines for .Pulp & Paper and Timber
2.2.2 WHEN is AN EIS REQUIRED?
NEPA requires that an EIS be prepared for "major" Federal actions "significantly affecting the
human environment." Generally, the determination of the need for an EIS hinges on a finding that
the proposed action would result in significant adverse impacts.
EPA's procedures provide general guidelines and specific criteria for making this determination
(40 CFR 6.605). General guidelines are (40 CFR 6.605(a)):
• EPA shall consider both short- and long-term effects, direct and indirect effects, and
beneficial and adverse environmental impacts as defined hi 40 CFR 1508.8
• If EPA is proposing to issue a number of new source NPDES permits within a limited time
span and in the same general geographic area, EPA must consider preparing a
programmatic EIS. In this case the broad cumulative impacts of the proposals would be
addressed in an initial comprehensive document, while other EISs or EAs would be
prepared to address issues associated with site-specific proposed actions.
EPA's specific criteria for preparing EISs for proposed new source NPDES permits are found in 40
CFR6.605(b):
• The new source will induce or accelerate significant changes in industrial, commercial,
agricultural, or residential land use concentrations or distributions, which have the potential
for significant effects. Factors that should influence this determination include the nature
and extent of vacant land subject to increased development pressure as a result of the new
source, increases in population that may be induced, the nature of land use controls in the
area, and changes in the availability or demand for energy.
• The new source will directly, or through induced development, have significant adverse
effects on local air quality, noise levels, floodplains, surface or groundwater quality or
quantity, or fish and wildlife and their habitats.
• Any part of the new source will have significant adverse effect on the habitat of threatened
and endangered species listed either Federally or by the State.
• The new source would have a significant direct adverse impact on a property listed or
eligible for listing in the National Register of Historic Places.
• Any part of the new source will have significant adverse efforts on parklands, wetlands,
wild and scenic rivers, reservoirs or other important water bodies, navigation projects, or
agricultural lands.
The determination of significance can be challenging. CEQ provides some guidance in the form of a
two-step conceptual framework which involves considering the context for a proposed action and its
intensity (40 CFR 1508.27). Context can be considered at several levels, including the region,
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EIA Guidelines for Pulp & Paper and Timber NEPA Requirements and Provisions
affected interests, and the locality. Intensity "refers to the severity of the impact.". CEQ lists a
number of factors to be considered when judging severity, including:
• Effects on public health and safety
• Unique characteristics of the geographic area
• The degree to which effects are likely to be controversial
• The degree to which effects are uncertain or involve unique or uncertain risks
• Cumulative effect of the action
• Whether the action would threaten a violation of Federal, State, or local law or regulation.
In his review of legal issues associated with NEPA, Mandelker (1992) summarizes judicial criteria for
significance. He cites the results ofHanly v. Kleindienst (II), where the court stated four criteria that
could be used to make a significance determination:
"First, did the agency take a 'hard look' at the problem, as opposed to bald conclusions,
unaided by preliminary investigation? Second, did the Agency identify the relevant areas
of environmental concern? Third, as to problems studied and identified, does the agency
make a convincing case that the impact is insignificant? ... If there is an impact of true
'significance,' has the agency convincingly established that changes in the project have
sufficiently minimized it?"
2.2.3 THE RELATIONSHIP BETWEEN NEPA REVIEW AND NPDES PERMnriNG ACTIVITIES
How the NEPA review process affects NPDES permitting activities is a complex issue. EPA
regulations clearly establish procedural and timing relationships between the two processes.
However, how the findings of a NEPA review can affect the substantive outcome of the permitting
process is less certain. In particular, there is a gray area as to how EPA should address NEPA
review findings that are not related to water quality. As summarized by Mandelker (1992), in a
recent court case it was held that NEPA does not confer on EPA the authority to impose conditions of
effluent discharge permits that are not related to water quality or other areas within the purview of the
Clean Water Act.1 However, the court held that NEPA authorized EPA to impose NEPA-inspired
water-related conditions on permits for effluent discharges and to rely on NEPA to deny a discharge
permit. Thus, for example, if a NEPA review indicated that construction associated with a proposed
hew source discharge would adversely affect a significant historic resource, EPA would not be
authorized to include in the NPDES permit any conditions that related to that construction. However,
EPA would be authorized to deny issuance of the permit based on a finding that was not strictly
related to water quality.
'Natural Resources Defense Council, Inc. v. Environmental Protection Agency, 859 F.2d 156 (D.C. Cir. 1988).
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NEPA Requirements and Provisions EIA Guidelines for Pulp & Paper and Timber
2.3 LEVELS OF REVIEW
Environmental analysis under NEPA is a process that is attended by extensive internal, interagency,
and public review. In particular, NEPA involves a strong mandate to involve the public hi the
environmental analysis process. As discussed below, document review is an element of all major
aspects of the analysis process. The formality and intensity of review increases with each escalation
in the hierarchy of NEPA documentation. So, EIDs are subject to the least formal and extensive
review; while EISs are subject to the greatest level of review.
o
2.3.1 ENVIRONMENTAL INFORMATION DOCUMENT (BID)
The EED, which is prepared by the permit applicant, is reviewed by the EPA Region. Although no
formal public notice is involved at this stage, documents prepared as part of the NEPA review process
are intended to be readily available for public review. The applicant may request confidential
treatment of certain types of business information that is provided as part of the EID.
2.3.2 ENVIRONMENTAL ASSESSMENT DOCUMENTS (EA)
The EA, which is prepared by EPA regional office staff, is reviewed and approved by the EPA
Regional Administrator. The Regional Administrator is formally the "responsible official" for EPA's
action in this case.
Should the EA result in a FNSI, EPA's Office of External Affairs (OEA) is notified and the titles of
these documents are included by OEA in a list published in the Federal Register.
The Regional Administrator is required to make these documents available for public inspection. The
Regional Administrator also must maintain the documents as a monthly status report.
EAs and FNSIs are reviewed by staff responsible for making permitting decisions prior to those
decisions. Copies of EAs and FNSIs are included in the official administrative record for those
permitting actions.
2.3.3 ENVIRONMENTAL IMPACT STATEMENTS (EISs)
Notices, determinations and other reports and documentation related to an EIS are reviewed internally
by EPA to the level of the Regional Administrator who serves as the responsible official.
Through consultation processes with cooperating and other interested agencies, EPA provides
opportunities for joint decision making and review. These consultation activities take place
throughout the EIS preparation process, beginning with initial discussions regarding the determination
of the appropriate Federal lead agencies through review and comment on the ROD.
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EIA Guidelines for Pulp & Paper and Timber NEPA Requirements and Provisions
The public also is provided many opportunities for review and participation in the assessment process.
These opportunities include the following:
• Publication of the NOI in the Federal Register provides an opportunity for parties to express
their interest in an EIS action.
• A scoping meeting is held early hi the process to solicit public and government agency
advice on the issues that should be addressed and any relevant information that should be
considered in the assessment process.
• Draft EISs are made available for review by the public and interested government agencies.
Cooperating and interested parties are provided review copies of Draft EISs. Other copies
are provided in easily accessible areas, such as public libraries in the local area of the
proposed action. EPA must respond formally to all comments made on the Draft EIS.
Comments and responses are represented in a special section .of the final EIS.
• Similarly, notice is provided of the availability of Final EISs and RODs and copies are sent
to interested parties for their review and comment.
• OEA also maintains copies of EISs for public review and also provides a copy to CEQ for
its review and consideration.
Draft final EISs, and RODs are subject to EPA internal review prior to release. Generally reviews
will progress from the originating EPA Region to the NPDES permitting office, then up through
EPA's structure to the Regional Administrator. Depending upon the nature of the specific issue,
EPA's Office of General Counsel (OGC), OFA Headquarters Office, or the Office of the
Administrator may also be included in the internal review cycle.
In cases where government agencies differ in their assessment of procedural or substantive issues
relating to the NEPA process, issues may be elevated to CEQ for review and resolution.
2.4 INFORMATION REQUIRED FROM PERMIT APPLICANTS
In accordance with EPA NEPA procedures, the nature and extent of information required from
applicants as part of the EID is bounded by two separate requirements:
• EIDs must be of sufficient scope to enable EPA to prepare its environmental assessment.
• In determining the scope of the EID, EPA must consider the size of the new source and the
extent to which the Applicant is capable of providing the required information. EPA must
not require the Applicant to gather data or perform analyses which unnecessarily duplicate
either existing data or the results of existing analyses available to EPA. EPA must keep
requests for data to the minimum consistent with the Agency's responsibilities under NEPA.
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NEPA Requirements and Provisions EIA Guidelines for Pulp & Paper and Timber
The EPA procedures call for EPA to consult with the applicant to determine the scope of the EID at
the outset of the process. As discussed in more detail hi Chapter 5 of these guidelines, elements of
the EID will be consistent with general requirements for the contents of NEPA documents.
Among the types of information required for EIDs, is a balanced description of each alternative
considered by the applicant. These discussions should include the size and location of facilities, land
requirements, operation and maintenance facilities, waste management units, auxiliary structures such
as pipelines or transmission lines, and construction schedules.
2.5 TIME INVOLVED IN PREPARING AND PROCESSING NEPA DOCUMENTS
The time required to complete NEPA documentation requirements will vary depending upon the
complexity of issues, public controversy, and other factors. As shown on Exhibit 2-2, completion of
the EA process generally requires 5 to 6 months; while completion of the EIS process typically
requires between 12 to 20 months. As noted on this exhibit, some elements of the schedule (e.g.,
public review periods) are established by regulation, while others are more flexible.
Under EPA's NEPA procedures, the Applicant may request that EPA establish time limits for the
environmental review process consistent with 40 CFR 1501.8.
2.6 LIMITATIONS ON PERMIT APPLICANT ACTIONS DURING THE REVIEW
PROCESS
5*
EPA NEPA procedures state that actions undertaken by the applicant or EPA shall be "performed
consistent with the requirements" of Section 122.29(c) of 40 CFR Part 6 (see amendment in 51 R
32609, September 12, 1986). In his treatise on NEPA law and litigation, Mandelker (1992) cites a
key case that bears on this issue. In Natural Resources Defense Council, Inc. v. EPA,2 the court held
that an EPA regulation banning any on-site construction of a new private source of water pollution
until after die final issuance of the NPDES permit that incorporated appropriate impact assessment
requirements was not authorized under Section 511 (c)(l) of the CWA. Here, the court held that
NEPA did not broaden EPA's "substantive powers."
'Natural Resources Defense Council, Inc. v. Environmental Protection Agency. 822 F. 2d 104 (D.C Cir. 1987).
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EIA Guidelines for Pulp & Paper and Timber
NEPA Requirements and Provisions
Exhibit 2-2. Model Schedules for EAs and EISs for Proposed Issuance
of New Source NPDES Permits
Determination of New •
Source/EPA b
permitting authority
Action determined to •
be likely to result in
significant adverse.
impacts and action
cannot be modified to
be environmentally
acceptable
Applicant prepares and submits EID (1 month)
EPA preparation of Draft FNSI; internal review;
public notice (1 month)
±Mc*imd*riiay9Man arfmMvfntrW action •>
,c*nb9 tatonan tfMpemrif »ppKct&>n ';-.;•'-;'
Environmental Assessment (EA)
™
[*o* appropriate teadfl1
Drafting of NOI; internal review; publication and
dissemination to interested parties (1 month)
Preparation of draft EIS; internal reviews
(3-6 months)
CM
i
CM
Response to comments, preparation of final EIS;
internal review and issuance (2-4 months).
Issuance of ROD and dissemination to parties who
commented on draft or final EISs (1-2 months).
Public mv/ew
period o/45
day*
Environmental Impact Statement (EIS)
No EPA
EPA pwmJttncr *cM«i em «• maetf until th* fatar e/ tt» following ctote*.- ^ M «1*x* from Ott banning ol «h« Draft E/5 pub«c
'«r pwiotf; (2) 30 dmyt from tt>» beginning of th» Finul EIS public nvuw ptmxT.
' The raview period officially start* on the Fricky following the Fedeml Register reporting week when OFA receives S bound copies of a Draft
or Final EIS.
US'" ««epre»^tatjy» sehadutot. Schedulet tor specific caaes may vary baaed on Ih* complexity of issues, availability of data, and other
factors. Items shown in bold are mandatory in accordance with EPA NEPA procedure*.
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September 1994
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NEPA Requirements and Provisions EIA Guidelines for Pulp & Paper and Timber
2.6 LIMITATIONS ON PERMIT APPLICANT ACTIONS DURING THE REVIEW
PROCESS
EPA NEPA procedures state that actions undertaken by the applicant or EPA shall be "performed
consistent with the requirements" of Section 122.29(c) of 40 CFR Part 6 (see amendment in 51 R
32609, September 12, 1986). In his treatise on NEPA law and litigation, Mandelker (1992) cites a
key case that bears on this issue. In Natural Resources Defense Council, Inc. v. EPA,2 the court held
that an EPA regulation banning any on-site construction of a new private source of water pollution
until after the final issuance of the NPDES permit that incorporated appropriate impact assessment
requirements was not authorized under Section 511 (c)(l) of the CWA. Here, the court held that
NEPA did not broaden EPA's "substantive powers."
2Natural Resources Defense Council, Inc. v. Environmental Protection Agency. 822 F. 2d 104 (D.C Cir. 1987).
2-14 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
3. OVERVIEW OF THE INDUSTRY
3.1 GENERAL
3.1.1 PULP AND PAPER
The pulp and paper industry was originally located in the .New England States and in New York.
Spruce trees in these States made both excellent groundwood and sulfite pulp. Gradually, the industry
expanded westward to Wisconsin, Michigan, and Minnesota where there were also spruce and balsam
trees, and still further westward to Washington and Oregon, where hemlock and fir trees were
utilized. In the 1920s, the extension of the sulfate process to pine trees firmly established the
Southern States as an important pulp and paper producing area.
By the beginning of the 20th century, newsprint was mass-produced and newspapers multiplied. As
the century progressed, paper changed from a product primarily used for newspapers, books, and
writing paper to a basic product that could be used as wrapping paper, paper bags, signs, posters,
cartons, and corrugated and solid fiber boxes. Without plentiful, low-cost paper and paperboard, the
industrial revolution hi mass production, mass packaging, and mass shipping and distribution would
never have occurred. Because of the ever increasing demand, the pulp, paper, and paperboard sought
new ways to keep production high and costs low.
In the 1970s, the pulp, paper, and paperboard industry focused on increasing energy efficiency to
reduce its dependency on petroleum-derived fuels. During the 1980s, the industries automated,
simultaneously cutting production costs and improving product quality and consistency. In addition,
the late 1980s saw an increase in capacity from retrofitting of existing equipment, installation of new
machines, and construction of new facilities. In the 1990s, the pulp, paper, and paperboard industry
is under pressure to reduce the environmental impact of its effluent and to recycle more fiber.
Regulations and consumer demands led to an increase in nonchlorine bleaching alternatives and to the
increased use of secondary fibers as furnish for paper and paperboard products (U.S. Environmental
Protection Agency, 1993). The pulp and paper industry has also been affected by the economic
recession and evolving information technologies. As business and the public increasingly rely on
electronic media for information transfer, slower growth in demand is predicted for printing and
writing papers and for newsprint (U.S. Department of Commerce, 1994).
3.1.1.1 Industry Subcategorization for the Purposes of NPDES
The EPA promulgated National Pollution Discharge Elimination System (NPDES) effluent limitations
guidelines and standards for best available technology economically achievable (BAT), new source
performance standards (NSPS), pretreatment standards for existing sources (PSES), and pretreatment
standards for new sources (PSNS) for the pulp, paper, and paperboard industry on November 18,
3-1 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
1982. On December 17, 1986, the EPA promulgated best conventional pollutant control technology
(BCT) effluent limitations. These regulations are currently in effect.
Existing effluent limitations guidelines for the pulp, paper, and paperboard industry are established in
40 CFR 430. The pulp, paper, and paperboard industry is divided into 25 subcategories for the
NPDES permitting purposes. The 25 subcategories are described as follows:
A. Unbleached Kraft—This subcategory includes mills that use a highly alkaline cooking liquor
containing sodium hydroxide and sodium sulfide to "full cook" the kraft pulp. The pulp is not
bleached. The principal product is used to manufacture linerboard, wrapping paper, and paper
for grocery bags and shipping sacks (Wapora, 1979).
B. Semi-Chemical—This subcategory includes mills that use either sodium or ammonia as the base
liquor. The principal product is a corrugated medium, the inner layer of corrugated boxes
(Wapora, 1979).
C. Reserved.
D. Unbleached Kraft-Neutral Sulfite Semi-Chemical (Cross Recovery)—This subcategory includes
combined mills in which the spent sodium base liquor is recovered in the kraft mill recovery
system (Wapora, 1979).
E. Paperboard from Wastepaper—This subcategory includes mills that repulp wastepaper. Pulp
deinking is not practiced, but the product is frequently upgraded with an asphalt dispersion
process. The principal product is unbleached folding board products, such as soap cartons and
bottle carriers (Wapora, 1979).
F. Dissolving Kraft—This subcategory includes mills that use a highly alkaline sodium hydroxide
and sodium sulfide cooking liquor to "full cook" the pulp. The pulp is subsequently bleached
and purified. The principal product is used in the manufacture of rayon and other products
requiring the virtual absence of lignin and a very high alpha cellulose content and low
percentage of hemicellulose (Wapora, 1979).
G. Market Bleached Kraft—This subcategory includes mills that produce pulp by a "full cook"
process using a highly alkaline sodium hydroxide and sodium sulfide cooking liquor. The pulp
is subsequently bleached. The principal product is papergrade market pulp (Wapora, 1979).
H. Board. Coarse. Tissue Papers. Bleached Kraft—This subcategory includes the integrated
production of bleached kraft pulp and paper. The kraft pulp is produced in a "full cook"
process using a highly alkaline sodium hydroxide and sodium sulfide cooking liquor. The pulp
is subsequently bleached. The principal products include paperboard, coarse papers, tissue
papers, and market pulp (Wapora, 1979).
I. Fine Bleached Kraft—This subcategory includes the integrated production of bleached kraft and
paper. The kraft pulp is produced in a "full cook" process using a highly alkaline sodium
hydroxide and sodium sulfide cooking liquor. The pulp is subsequently bleached. The
principal products include business, writing, printing papers, and market pulp (Wapora, 1979)'.
3-2 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
J. Papererade Sulfite (Blow Pit Wash)—This subcategory includes the integrated, production of
sulfite pulp and paper. The sulfite pulp is produced in 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 separated from the pulp in blow pits. The principal
products are tissue papers, newsprint, fine papers, and market pulp (Wapora, 1979).
K. Dissolving Sulfite Pulp—This subcategory includes mills which produce pulp from softwoods by
a "full cook" process using strong solutions of sulfites of calcium, magnesium, ammonia, or
sodium. The pulp is subsequently highly bleached and purified to produce viscose, nitration,
cellophane, or acetate. These products are used in the manufacture of rayon and other products
requiring the virtual absence of lignin and a very high alpha cellulose content and low
percentage of hemicellulose (Wapora, 1979).
L. Groundwood-Chemi-Mechanical—This subcategory includes the integrated production of
groundwood pulp by partially cooking the pulp in a chemical cooking liquor. After cooking,
the pulp undergoes mechanical defibration in refiners. Chemi-mechanical pulp may or may not
be brightened, or bleached. The principal products include fine papers, newsprint, and molded
fiber products (Wapora, 1979).
M. Groundwood-Thermo-Mechanical—This subcategory includes the production of groundwood
pulp by a brief cook using steam. Cooking chemicals, such as sodium sulfite, may be added to
the cook. After cooking, the pulp undergoes mechanical defibration in refiners. Thermo-
mechanical pulp may or may not be brightened, or bleached. The principal products include
market pulp, fine papers, newsprint, and tissue papers (Wapora, 1979).
N. Groundwood-Coarse. Molded. News Papers—This subcategory includes the integrated
production of groundwood pulp by mechanical defibration. Defibration occurs by either stone
grinders or refiners. The groundwood pulp is produced, with or without brightening. The
principal end-products include coarse papers, molded fiber products, and newsprint (Wapora,
1979).
O. Groundwood-Fine Papers—This subcategory includes the integrated production of groundwood
pulp by mechanical defibration. Defibration occurs by either stone grinders or refiners. The
groundwood pulp is produced, with or without brightening. The principal products include
business, writing, and printing papers (Wapora, 1979).
P. Soda—This subcategory includes the integrated production of bleached soda pulp and paper.
Soda pulp is produced by a "full cook" process using a highly alkaline sodium hydroxide
cooking liquor. The pulp is subsequently bleached. The principal products include fine papers,
such as printing, writing, and business papers (Wapora, 1979).
Q. Deink—This subcategory includes the integrated production of deinked pulp and paper.
Deinked pulp is produced by applying an alkaline treatment to waste paper to remove
contaminants such as ink and coating pigments. The pulp is usually bleached. The principal
products include fine papers, tissue papers, and newsprint (Wapora, 1979).
R. Noninteerated-Fine Papers—This subcategory includes nonintegrated mills which produce fine
papers from wood pulp, or deinked pulp. The pulp is prepared at another site and shipped to
3.3 September 1994
-------
Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
the producer. The principal products include printing, writing, and business papers (Wapora,
1979).
S. Nonintegrated Tissue Papers—This subcategory includes nonintegrated mills which produce fine
papers from wood pulp, or deinked pulp. The pulp is prepared at another site and shipped to
the producer. The principal products include facial and toilet papers, glassine, paper diapers,
and paper towels (Wapora, 1979).
T. Nonintegrated Tissue from Wastepaper—This subcategory includes nonintegrated mills which
produce tissue papers from wastepaper. The pulp is prepared at another site and shipped to the
producer. The wastepaper is not deinked. The principal products include facial and toilet
papers, glassine, paper diapers, and paper towels (Wapora, 1979).
U. Papergrade Sulfite (Drum Wash)—This subcategory includes the integrated production of sulfite
pulp and paper. The sulfite pulp is produced in 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.
The pulp may also be washed using belt extraction systems. The principal products include
tissue papers, fine papers, newsprint, and market pulp (Wapora, 1979).
V. Unbleached Kraft and Semi-Chemical—This subcategory includes production of kraft wood pulp
using an alkaline cooking liquor. The pulp is not bleached. The principal products include
unbleached kraft market pulp.
W. Waste Paper: Molded Products—This subcategorv includes the production of deinked pulps
from wastepaper without deinking. The pulp is produced with or without bleaching. The
principal products are molded products.
>r
X. Nonintegrated Lightweight Paper—This subcategory includes the production of lightweight
papers produced from purchased virgin pulps or secondary fiber. The principal products
include lightweight electrical papers.
Y. Nonintegrated Filter and Nonwoven Paper—This subcategory includes the production of filters
and non-woven produced from purchased virgin pulps or secondary fiber.
Z. Nonintegrated Paperboard—This subcategory includes the production of paperboard from
purchased virgin pulps or secondary fiber.
On December 17, 1993, EPA proposed to replace the existing NPDES subcategorization scheme for
the pulp, paper, and paperboard industry (Part 430) with a revised subcategorization scheme. Below
in Exhibit 3-1 is a summary of the new subcategories that were proposed on December 17, 1993, and
the corresponding subcategories under the existing regulations.
The proposed NPDES permitting scheme will reduce the number of pulp, paper, and paperboard from
25 subcategories to 12. It is currently unknown if the proposed subcategorization will ultimately be
promulgated as final. However, description of the proposed subcategories is provided below.
3.4 September 1994
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EIA Guidelines for Pulp & Paper and Timber
Overview of the Industry
Exhibit 3-1. Comparison of Existing and Proposed Effluent Limitation Guidelines
Proposed
Snbpart
A
B
C
D
E
F
G
H
I
J
K
L
Proposed Subcategorization
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical Pulp
NonWood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-Deink
Fine and Lightweight Papers from
Purchased Pulp
Tissue, Filter, Non-Woven, and
Paperboard from Purchased Pulp
Existing Subcategorization
Dissolving Kraft (F)
Market Bleached Kraft (G)
BCT Bleached Kraft (H)
Fine Bleached Kraft (I)
Soda(P)
Unbleached Kraft (A)
Unbleached Kraft-Neutral Sulfite Semi-
Chemical (D)
Unbleached Kraft Semi-Chemical (V)
Dissolving Sulfite (K)
Papergrade Sulfite (Blow Pit Wash) (J)
Papergrade Sulfite (Drum Wash) (U)
Semi-Chemical (B)
Groundwood-Thermo-Mechanical (M)
Groundwood-Coarse, Molded, News
(N)
Groundwood-Fine Papers (0)
Groundwood-Chemi-Mechanical (L)
Miscellaneous mills not covered by a
specific subpart
Deink (Q)
Paperboard from Wastepaper (E)
Tissue from Wastepaper (T)
Wastepaper-Molded Products (W)
Builders' Paper and Roofing Felt (Pan
431 A)
Nonintegrated-Fine Papers (R)
Nonintegrated-Lightweight Papers (X)
Nonintegrated-Tissue Papers (S)
Nonintegrated-Filter and Non- Woven
00
Nonintegrated-Paperboard (Z)
»
Source: Federal Register, Volume 58, Number 241, page 66084.
3-5
September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
A. Dissolving Kraft Subcategorv—This subcategory includes the production of highly bleached and
purified kraft wood pulp using an alkaline sodium hydroxide and sodium sulfide cooking liquor
.With acid prehydrolysis. The principal product is used primarily for the manufacture of rayon,
viscose, acetate, and other products requiring a high percentage of alpha cellulose and a low
percentage of hemicellulose (U.S. EPA, 1993).
B. Bleached Papergrade Kraft and Soda Subcategorv—This subcategory includes production of a
bleached kraft wood pulp using an alkaline sodium hydroxide and sodium sulfide cooking
liquor. Principal products include papergrade kraft, market pulp, paperboard, coarse papers,
tissue papers, uncoated free sheet, and fine papers (U.S. EPA, 1993).
C. Unbleached Kraft Subcategorv—This subcategory includes production of kraft wood pulp using
an alkaline sodium hydroxide and sodium sulfide cooking liquor. The wood pulp is not
bleached. Principal products include unbleached kraft market pulp, bag papers, and liner board
(the smooth facing of corrugated boxes) (U.S. EPA, 1993).
D. Dissolving Sulfite Subcategorv-—This subcategory includes production of a highly bleached'and
purified sulfite wood pulp using acidic cooking liquors of calcium, magnesium, ammonium, or
sodium sulfites. Pulps produced by this process are used primarily for the manufacture of
rayon, cellophane, methyl cellulose, ethyl cellulose, nitra-cellulose, cellulose acetate, and other
products that require a high percentage of alpha cellulose and a low percentage of hemicellulose
(U.S. EPA, 1993).
E. Papergrade Sulfite Subcategorv—This subcategory includes production of sulfite wood pulp
using an acidic cooking liquor of calcium, magnesium ammonium, or sodium sulfites. The pulp
is produced with or without brightening or bleaching. Principal products include tissue papers,
fine papers, newsprint, and market pulp (U.S. EPA, 1993).
F. Semi-Chemical Subcategorv—This subcategory includes production of pulp from wood chips
under pressure using a variety of cooking liquors, including but not limited to neutral sulfite
semi-chemical (NSSC), sulfur free (sodium carbonate), green liquor, and Permachem*. The
cooked chips are usually mechanically refined. Pulp is produced with or without bleaching.
Principal products include corrugated medium, paper, and paperboard (U.S. EPA, 1993).
G. Mechanical Pulp Subcategory—This subcategory includes production of stone groundwood,
refiner mechanical, thermo-mechanical, chemi-mechanical, and chemi-thermo-mechanical pulps.
Mechanical pulps are produced using mechanical defibration by either stone grinders or steel
refiners. Thermo-mechanical pulp is produced using steam followed by mechanical defibration
in refiners. Chemi-mechanical pulp is produced by partially cooking the wood in a chemical
cooking liquor followed by mechanical defibration in refiners. Chemi-thermo-mechanical pulp
is produced using steam followed by chemical cooking and mechanical defibration in refiners.
Principal products include market pulp, newsprint, coarse papers, tissue, molded fiber products
and fine papers (U.S. EPA, 1993). ,
H. NonWood Chemical Pulp Subcategory—This subcategory includes production of nonwood pulps
from chemical pulping processes such as kraft, sulfite, or soda. Fiber sources include textiles
(rags), cotton linters, flax, hemp, bagasse, tobacco, and abaca. Principal products include
market pulp, cigarette plug wrap paper, and other specialty paper products (U.S. EPA, 1993).
3-6 September 1994
-------
EIA Guidelines for Pulp & Paper and Timber ' Overview of the Industry
I. Secondary Fiber Deink Subcateeorv—This subcategory includes production of deinked pulps
from wastepapers. A chemical, or solvent process, is used to remove contaminants such as
. inks, coatings, and pigments. Deinked pulps are usually brightened or bleached. Principal
products including printing, writing, and business papers, tissue papers, newsprint, and deinked
market pulp (U.S. EPA, 1993).
J. Secondary Fiber Non-Deink Subcategorv—This subcategory includes production of deinked
pulps from wastepaper without'deinking. Pulp is produced with or without brightening.
Principal products include tissue, paperboard, molded products, and construction papers.
Construction papers may be produced from cellulosic fibers derived from wastepaper, wood
flour and sawdust, wood chips, and rags (U.S. EPA, 1993).
K. Fine and Lightweight Papers from Purchased Pulp Subcategorv—This subcategory includes
production of fine and lightweight papers produced from purchased virgin pulps or secondary
fiber. Principal products include clay coated printing and converted paper, uncoated free sheet,
cotton fiber writing paper and thin paper, and lightweight electrical papers (U.S. EPA, 1993).
L. Tissue. Filter. Non-Woven, and Paperboard from Purchased Pulp Subcategorv—This
subcategory includes production of paperboard, tissue papers, filter papers, and non-woven
items from purchased virgin pulps or secondary fiber (U.S. EPA, 1993).
3.1.1.2 Geographic Distribution of Activity
The major pulp; paper, and paperboard production areas are the southeast, northwest, northeast, and
Great Lakes regions of the United States. Based on information collected for the EPA's 1990
National Census of Pulp, Paper, and Paperboard Manufacturing facilities, the EPA estimates that pulp
and paper is manufactured in 42 states (Exhibit 3-2 below). More than half these facilities
manufacture pulp and paper at integrated pulp and paper mills from virgin wood fiber, secondary
fiber, or non-wood fiber. The remaining facilities are nqnintegrated paper mills where paper or
paperboard products are manufactured from purchased pulp (U.S. EPA, 1993).
Raw Materials
There are four principal types of fiber furnish used in the manufacture of pulp, paper, and
paperboard. These include: hardwood; softwood; secondary fibers; and non-wood fibers. In the
United States, approximately twice as much softwood pulp is produced compared to hardwood pulp.
"Secondary fibers" are fibers obtained from the recycling of pre- and post-consumer papers and
paperboard. Nonwood fibers are most often used to produce low-volume, specialty grades of paper
(U.S. EPA, 1993).
Recycled-content mandates, procurement provisions, and recycling goals are forcing industry to
improve technology to manufacture products containing increased recycled materials. Old
newspapers, old corrugated containers, mixed papers, and office papers are adding to supplies of
high-grade deinking papers and pulp substitutes. Deinking capacity is expanding rapidly in the United
3.7 September 1994
-------
Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-2. Geographic Profile of Pulp, Paper, and Paperboard Mills
State
Alabama
Alaska
Arizona
Arkansas
California
siii^b^o-filllil
iiid*i«cliiciiftl!l
;ii^awaiii;:|i;ii
5M6na^f;i::t'?I;i|
lESto^:f:f:''];«ff
Hawaii
Idaho
Illinois
Indiana
Iowa,
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
All
Mills
19
2
2
8
34
liiil
Illolt
T^4$t
0
1
10
12
2
1
5
13
18
3
38
33
9
10
3
- l'":':
o
0 .:
12
14
1
51
16
0
30
Mill That
Manufacture
Chemical
Pulp*
. 14
2
1
7
3
' . :":•. :. •:'•'. '-.-:•:•. '•:'• •'•:-• •?'.•'.•'. '•:•:•*•.• ;. ;•-•: :•:•;•
'• .•:-;-'. ••'•: :• . '•'•'.< ••>*•• '•'•'•:•:•:•-• •.'.-:•:•:•:•:•:
mztMmtim
KfZMiikt'XS.
ll:II|0JlB;if
S;s;':'vl^S^::il
'::';::-:1'0:'-;:1/:':-;-X'|:A':i:'':::::::':^:::-:v:v:
•:::-; :--\':::.:::54*:;;iia;g:;||
0
1
0
0
0
0
2
10
8
1
0
3
2
4
0
•••' .:l-'""'s ".:
0
0
1
i :
0
3
6
0
1
Mills That
Bleach
Oiemicgl
Pulp"
11
2
1
4
3
liSiili:||
ll;:|:nl;110;lll!l!
0
1
0
0
0
0
2
4
8
1
0
3
2
4
0
'"• -;i;
0
0
: •• =1 .. • •.. ,.
•-1 " '
0
3
6
0
1
Mill That
Process
Secondary
:Ffte^>"-^
9
0
2
3
29
•m^^Mti&.-l-l
m:mffi.m:
m^'mm^:^
"m(X"'^-f
0
0
10
11
2
2
2
8
6
2
21
23
5
4
3
1
0
0
10
13
1
32
12
0 •
24
Mills That
Deink
Secondary
Fiber4
1
0
1
1
3
C:;.;;-4o-;;:,,:.;;
^•:; w.-: : .. .:
• > • • -.•iO--.- ,:.
•-••••. & •..,...:;.
••: . •^•••;-.:v.^
0
0
1
0
0
0
0
0
2
0
2
2
0
0
0
0
0
0
0
3
0
2
1
0
3
t
3-8
September 1994
-------
EIA Guidelines for Pulp & Paper and Timber
Overview of the Industry
Exhibit 3-2. Geographic Profile of Pulp, Paper, and Paperboard Mills (Continued)
.
State
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
TOTAL
'
All
Mills
6
12
31
0
9
0
13
11
0
6
12
20
2
46
0
565
Mill That
Manufacture
Chemical
Pulp"
,0
3
5 -
0
4
0
2
.5
0
0
4
10
0
9
0
154
Mills That
Bleach
Chemical
Pulp"
0
3
5
0
' 4
0
2
5
0
0
3
10
0
7
0
110
Mill That
Process
Secondary
Fiber1
6 ' -• : ;
8 - ' '?,
23
0
•4 " • • '
0
9
6
0
5
10
9
2
29
0
378
Mills That
Deink
Secondary
Fiber"
:.'• --:;2
:'".:2'.
1
0
0
0
1
0
0
1
0
0
0
10
0
43
a. Includes wood and nonwood chemical pulp mills (bleached and unbleached).
b. Includes wood and nonwood chemical pulp mills that subsequently bleach with or without
chlorine or chlorine derivatives with or without traditional bleach plants.
c. Includes all mills that process any secondary fiber with or without deinking
d. Includes all mills that deink and secondary fiber.
Source: U.S. Environmental Protection Agency, Office of Water. Development Document for
the Proposed Effluent Limitations Guidelines and Standards for the Pulp, Paper and
Paperboard Point Source Category. October 1993. EPA-821-R-93-019.
3-9
September 1994
-------
Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
States. Most of the tissue papers produced from 1990 to 1993 used deinked wastepaper. The use of
secondary fibers as furnishes has also increased the addition of biocides and wet and dry strength
agents (U.S. Department of Commerce, 1994).
Recycled furnishes made up approximately 31 percent of the fiber used at pulp and paperboard mills
in 1993, up from 23 percent in the mid-1980s. Consumption of fiber from recovered paper is
growing more than twice as fast as total fiber consumption. Most mill additions plan to use recycled
fibers as a significant source of fiber (U.S. Department of Commerce).
\
Process Changes
In response to environmental concerns, pulp and paper mills have implemented advanced pulping
technologies that provide greater delignification. The reduced lignin load to the bleach plant reduces
the need for bleaching chemicals. Some pulping technologies that increase delignification include
extended delignification driving kraft pulping, solvent pulping, and pulping in the presence of the
catalyst anthraquinone. Oxygen delignification is a post-pulping method used to lower the lignin
content of pulp entering the bleach plant. Adding hydrogen peroxide to an oxygen delignification
system further reduces the amount of lignin (U.S. EPA, 1993).
Environmental pressures have pushed mills to consider bleach modernization and to adopt novel
bleaching technologies as alternatives to chlorine bleaching. Completely chlorine-free pulp mills will
account for and estimated 10 percent of the total chemical market pulp volume in the year 2000.
Bleaching process modifications incorporated by the pulp, paper, and paperboard industry includes
chlorine dioxide substitution for elemental chlorine, enhanced caustic extraction with peroxide and
oxygen, ozone bleaching, and chlorine injection process modification. These modifications have
helped to reduce the environmental impact of bleach plant effluent (U.S. EPA, 1993).
3.1.1.3 Economic Overview
The U.S. paper industry began to feel the impact of the economic slowdown from the fourth quarter
of 1990 and into 1993. Reduced advertising expenditures in magazines and newspapers have resulted
in a lower demand for paper products. Similarly, the demand for uncoated free-sheet grades has
declined due to the recession and to increased electronic communications in the office environment.
Unbleached kraft packaging and industrial papers lost substantial market share to plastics during the
1980s. The decline is expected to continue as the recycled stocks gain market share in the 1990s.
Shipments of paper and allied products are expected to grow at an average annual rate of 2 percent
through 1998. But exports are expected to grow faster than domestic sales. However, competition
from abroad will intensify as foreign paper companies in developing countries improve their product
quality and compete more aggressively in major Western markets including the United States (U.S.
Department of Commerce, 1994).
3-10 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
3.1.2 TIMBER PRODUCTS PROCESSING
3.1,2.1 Industry Subcategorization for Purposes of NPDES
The timber products processing industry includes multiple processing techniques to transform
harvested logs into diverse intermediate and final products. The timber products processing industry
is defined in Major Group 24 (Timber Products Processing), 25 (Furniture Products), and 26
(Building Paper and Building Board Mills) of the Bureau of Census, Standard Industrial Classification
(SIC) manual. The industry segments addressed in these guidelines include:
• SIC 2411 Logging Camps and Logging Contractors
• SIC 2421 Sawmills and Planing Mills
• SIC 2426 Hardwood Dimension and Flooring Mills
• SIC 2429 Special Products Sawmills
• SIC 2431 Millwork
• SIC 2434 Wood Kitchen Cabinets
• SIC 2435 Hardwood Veneer and Plywood
• SIC 2436 Softwood Veneer and Plywood
• SIC 2491 Wood Preserving
• SIC 2499 Timber Products Not Elsewhere Classified (Hardboard)
• SIC 2511 Wood Household Furniture, Except Upholstered
• SIC 2512 Wood Household Furniture, Upholstered
• SIC 2517, Wood Television, Radio, Phonograph, and Sewing Machine Cabinets
• SIC 2521 Wood Office Furniture
• SIC 2531 Public Building and Related Furniture (Wooden)
• SIC 2541 Wood Partitions, Shelving, Lockers, and Office and Store Fixtures
• SIC 2661 Building Paper and Building Board Mills (Insulation Board).
The industry segments identified in the three Major Groups are highly interrelated. Individual
operations rarely stand alone within the industrial sector. This is particularly true for Major Group
24. These industry segments not only provide raw materials to die other groups and the pulp and
paper group, they also provide raw materials to other segments within Major Group 24. A
conceptual illustration of selected interrelationships of the industry segments is presented in Exhibit
3-3.
3-11 September 1994
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Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-3. Interrelationships of Major Product Processes of the Timber Products
Processing Industry
FOREST
RESOURCES
(Harvested
Timber)
LOG
1RANSPOR-
•TATION
TRUCK
RAIL OR
Mr AT F ft
tn
i
LOG SORTING 1
AND STORAGE
•.DRY DECK
ft. WET DECK
C. WATER STORAGE
•
BARK REMOVAL
•.HYDRAULIC
ft. MECHANICAL
MOUND WOOD
„ COKES|
4 I VENEERING
CORES
PLYWOOD
JL_i
1
SAW MILLS AND
PLANINO MILLS
AN»
9AV OUST
HARDBOARD
•.WET PROCESS
». DRY PROCESS
IT
9MAVIMC9
INSULATION
•OAJtO
T
1 f. LMMBf•
•CftAFt
PARTICLEBOARD
•.MAT
».EXTRUDED
FINISHING AND
MISCELLANEOUS
OPERATIONS
Source: U.S. EPA. 1974a. Development document for proposed effluent limitations
guidelines and new source performance standards for the wet storage, sawmills, particleboard
and insulation board segment of the timber products processing point source category. EPA
440/1-7/033. Washington DC.
3-12
September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
Recognizing these interrelationships, the National Pollutant Discharge Elimination System (NPDES)
combined these industry segments into one point source category for purposes of developing effluent
guidelines and standards. EPA promulgated regulations for direct and indirect point source
discharges in January 1981. These regulations can be found hi the Code of Federal Regulations
(CFR) at 40 CFR Part 429. The regulations establish performance standards for existing direct
discharge sources based on best practicable control technology currently available [at the time of
promulgation] (BPT) and best available control technology economically achievable (BAT). The
regulation also established new source performance standards (NSPS) for direct dischargers. For
indirect dischargers, the regulation issued pretreatment standards for existing sources (PSES) and
pretreatment standards for new sources (PSNS).
Within the Timber Products Processing Point Source Category, the industry segments are organized
into subcategories based on similarity of wastewater discharge characteristics, raw materials, final
products, water usage, manufacturing processes, equipment, and age and size of plant. The 16
subcategories are described below:
A. Barking—Operations resulting in the removal of bark from logs. Two types of barking
installations fall under this subcategory—mechanical barking and hydraulic barking.
B. Veneer—Operation to convert barked logs or heavy timber into thin sections of wood known as
veneer.
C. Plywood—Operation for laminating layers of veneer together by adhesive to form plywood.
D. Dry Process Hardboard—Operation for the production of finished hardboard from chips,
sawdust, or other raw materials using the dry-matting process.
E. Wet Process Hardboard—Defined the same as Subcategory D except the matting process is wet.
F. Wood Preserving—Waterborne or Any Non-Pressure Process—All nonpressure wood preserving
treatment operations and all pressure wood preserving processes employing waterborne salts.
G. Wood Preserving—Steam—All processes that employ direct steam impingement on wood as the
predominant conditioning method, processes that use the vapor drying process as the
predominant conditioning method, processes that use the same retort to treat with both salt and
oil type preservatives, and steam conditioning processes that apply both salt type and oil type
preservatives to the same stock.
H. Wood Preserving—Boulton—All wood-preserving operations that use the Boulton process for
conditioning wood. The Boulton process consists of heating wood in a preservative formulation
in a pressure treating cylinder under vacuum conditions, on order to vaporize water within the
wood.
I. Wet Storage—The holding of unprocessed wood before or after bark removal.
3-13 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
J. Log Washing—Operations where water is applied under pressure to the log to remove foreign
material from its surface.
K. Sawmills and Planing Mills—Processing operations, including sawing, resawing, edging,
trimming, planing, and/or machining.
L. Finishing—Operations including drying, dipping, staining, and coating.
M. Particleboard Manufacturing—Processes to produce particleboard through the bonding together
of wood particles or other ligno-cellulosic material with an.organic or inorganic adhesive.
N. Insulation Board—Facilities that produce a fiberboard from wood in a fibrous state (density less
than 0.5 grams per cubic centimeter, 31 pounds per cubic foot).
O. Wood Furniture and Fixture Production Without Water Wash Sprav Booth(s) or Without
Laundry Facilities—Furniture and fixture production facilities which neither employ water wash
spray booths nor have laundry facilities for finishing rags.
/
P. Wood Furniture and Fixture Production with Water Wash Sprav Booth(s) or with Laundry
Facilities—Furniture and fixture production facilities which employ no water wash spray booths
but have laundry facilities for finishing rags.
/
Source: USEPA. 1974a. Development document for proposed effluent limitations guidelines and
new source performance standards for the wet storage, sawmills, particleboard, and
insulation board segment of the timber products processing point source category. EPA
440/1-74/033. Washington DC.
. 1974b. Development document for proposed effluent limitations guidelines and new
source performance standards for the wood furniture and fixture manufacturing segment of
the timber products processing point source category. EPA 440/l-74-003a. Washington
DC.
. 1974h. Development document for effluent limitations guidelines and new source
performance standards for the plywood, hardboard, and wood preserving segment of the
timber products processing point source category. EPA 440/1 -74-023a. Washington DC.
. 1981. Development document for effluent limitations guidelines and standards for
the timber products processing point source category. EPA 440/1-81/023.
. 1991. Preliminary Data Summary for the Wood Preserving Segment of the Timber
Products Processing Point Source Category. EPA 440/1-91/023.
3.1.2.2 Raw Materials
Softwood and hardwood timber are the primary source of raw materials utilized by the wood products
industry. The particular process inputs may be in any of a number of forms, including roundwood
logs, chips, shavings or sawdust. Lumber mills and plywood and veneer facilities use roundwood
logs as their raw material. Reconstituted panel operations, such as particle board and oriented
3-14 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
strandboard use sawdust, shavings, chips and other residues as process inputs. The-furniture and
cabinets industries depend to a large degree on the supply of non-structural panel products (such as
particle board, hardboard, medium density fiberboard, and some plywood and veneer). Demand for
hardwood lumber is typically greatest in the furniture, flooring and pallet producing sectors. The
chips and other residues employed in reconstituted panel manufacture may be produced from
roundwood logs on site, brought in as waste from planing and sawmills or from whole-tree chipping
performed hi the forest. Other, non-wood process additives, such as resins or glues, various waxes,
oils and preservatives and insecticides comprise less than 15 percent of the industry's raw materials.
The Pacific Northwest, Southeast, and to a lesser extent the Northeast and Great Lakes Region, have
traditionally been the major timber producing regions of the country. Examination of historical timber
production and distribution data reveal several interesting trends (see Exhibit 3-4). Over the 10-year
period ending in 1987, hardwood saw timber resources on commercial lands in the North and
Southeast (the primary hardwood regions) grew 28.9 percent and 37.8 percent respectively. These
increases amounted to more than 179,000 board feet. Domestic hardwood timber production has
remained fairly constant over the past four years at roughly 44 million cubic meters.
Over the same period, though, there has been a steady shift in timber harvesting away from the
Pacific Northwest toward the Southeast. This may be reflected by the fact that the Pacific Northwest
net volume of saw timber fell by 7.6 percent in the 10 years prior to 1988. This was the only
significant decline in net saw timber volumes anywhere in the U.S. over that period. Other regions
slightly more than offset this resource loss in the Northwest, most significantly the Southeast. This
gradual shift has been caused by a number of factors, including higher forest growth rates and a
higher proportion of privately owned (and thus more accessible) timberlands in the Southeast, as well
as declining supplies hi the Pacific Northwest.
3.1.2.3 Log Imports & Exports
Imports and exports of raw logs have been undergoing significant changes in the last several years,
and are likely to continue to do so. Imports of roundwood logs have actually remained fairly constant
at roughly IS million cubic meters since 1986. Log exports, however, doubled hi the mid-1980s,
increasing from 425 million cubic meters in 1981, to 825 million cubic meters hi 1988 (USDA,
1992). Softwood log exports have traditionally accounted for 80-85 percent of total U.S. log exports.
Seventy-five percent of this volume has generally been provided by the Pacific Northwest.
Canada is the primary importer of U.S. hardwood logs, followed by Japan and Germany. Canada is
also the largest source of U.S. softwood log imports, supplying more than $26 million in 1991. This
will be even more likely if proposed legislation passes to restrict log exports from Federal lands
across the entire U.S. Imports of Canadian softwood logs are likely to increase if domestic*softwood
timber supplies' do not keep pace with demand, as is expected to be the case.
3-15 September 1994
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Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-4. Net Volume of Sawtimber on Commercial Timberland by Region and Type
in Board Feed
Region
1977
1987
% Change
Pacific Northwest
Softwood
Hardwood
911,892
38,434
842,862
45,908
-7.6
+ 19.4
Southwest
Softwood
Hardwood
255,611
9,105
289,189
23,969
+ 13.1
+ 163.3
Rocky Mountains
Softwood
Hardwood
Softwood
Hardwood
380,379
- 9,790
386,911
12,290
+ 1.7
+25.6
North
96,504
262,517
132,557
338,505
+37.4
+28.9
South
Softwood
Hardwood
341,023
273,686
380,135
377,012
+ 11.5
+37.8
Source: USDA. 1985, 1992. Agricultural Conservation and Forestry Statistics— 1985, 1992.
3.1.2.4 Geographical Distribution of Activity
Exhibit 3-5 lists the number of wood products facilities located within each EPA Region by major
activity. The major concentrations of facilities tend to coincide with the major timber producing
regions—Southeast, Pacific Northwest, Great Lakes and Northeast. The distribution of facilities also
appears to be influenced by population density. According to the Department of Commerce, the shift
in the location of timber harvesting noted in the previous section has been inducing a similar shift in
the location of wood products facilities (TTA, 1994). Although the Department of Commerce did not
provide specific figures, it did state that facilities had been closing in the Pacific Northwest and new
operations had been starting in the Southeast (ITA, 1994).
3-16
September 1994
-------
EPA
Region
1
2
3
4
5
6
7
8
9
10
SIC Codes and Definitions
2421
Sawmills
&
Planing
Mills
364
208
1023
1557
981
466
336
211
248
682
2426
Hardwood
Dimension
&
Flooring
71
65
163
589
239
95
54
29
126
59
2431
Millwork
463
475
533
988
1149
611
230
260
912
418
2434
Wood
Kitchen
Cabinets
369
533
613
1310
1090
702
311
276
1312
372
2435
Hardwood
Veneer &
Plywood
11
17
39
136
101
22
3
3
27
61
2436
Softwood
Veneer &
Plywood
1
6
6
29
7
17
1
1
7
67
2491
Wood
, Preserv-
ing
21
34
71
176
96
81
29
36
35
66
2499
Other
Wood
Products
514
474
460
798
1049
597
318
170
843
365
25XX
General
Furniture
Manufact-
ure-Wood
678
1092
996
2726
2071
1137
456
415
2322
599
Source: Dunn and Bradstreet Database
Note: Region 9 contains California, although most wood products activity probably occurs in the Northern part of that State,
closer to Region 10.
Exhibit 3-5. Number of Facilities Located in Each EPA Region by SIC Code 1
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
3.1.2.5 Economic Overview
The economic forecast for the wood products industry overall is positive. However, while the
forecast as a whole is good, domestic timber supply shortage can be expected to cause shirts in
market share between industry sub-sectors, most notably, as the traditional plywood loses ground to
the reconstituted panel industry.
The modest recovery of the U.S. economy in 1993, combined with economic growth seen in many
U.S. trading partners, and the implementation of several international trade agreements, have
produced a generally favorable economic picture for the U.S. wood products industry.
Domestic economic growth has spurred growth in the construction, and remodelling and repair
sectors, which are the main end-use markets for the U.S. wood products industry. Each of the wood
products industry's subcategories depend to a large extent on the health of one or more of these end
markets in both the U.S. and her major export buyers. Eighty percent of the softwood lumber, 65
percent of the structural panels and most of the millwork consumed in the U.S. is accounted for by
construction and related activity (ITA, 1994). Residential construction, and repair and remodelling
increased by roughly four percent in 1993, and are expected to maintain this level of growth for the
next few years. This will likely induce industry to increase production to remain competitive with
imports. Total wood products shipments are expected to increase by more than one percent hi 1994.
The U.S. Department of Commerce expects domestic shipments of wood products to remain near
their 1994 levels for the next 5 years or so. Residential housing starts are expected to remain at
roughly one million per year over roughly the same period. Other major markets are not expected to
grow appreciably.
Export markets, however, have the potential to grow significantly over the next several years. One
reason is that the economies of several U.S. trading partners appear to be on the upswing. In
addition, several international free trade agreements signed by the U.S. in the last few years are
anticipated to further strengthen the U.S. export market. The North American Free Trade
Agreement, and the U.S.-Canada Free Trade Agreement both eliminate or phase out tariffs on a
variety of wood products. The export situation with Mexico is made even more favorable due to
timber shortages and inadequate replanting programs in Mexico. This situation should provide
opportunities for U.S wood products exports to Mexico for some time in the future. Progress toward
implementing an accord signed with the Japanese may help open even more markets for U.S. wood
products in Japan. Additionally, world, and especially Japanese demand for U.S. temperate
hardwood products (as substitutes for tropical hardwoods) is expected to increase as well, due to
rising sentiment against tropical deforestation both in Japan and abroad. Japan has historically been
one of the world's leading importers of tropical hardwoods.
3-lg September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
The U.S. has traditionally been a net importer of wood products and is the world's .-leading wood
product importer. Both U.S. imports and exports of wood products increased steadily since 1950.
Values of both imports and exports of wood products are predicted to increase by about two percent
in 1994, and thus remain approximately equal. Softwood lumber is the dominant U.S import. The
U.S imported 15,259.9 million board feet of softwood lumber in 1993, up 14 percent from the year
before. Ninety-nine percent of this volume came from Canada, whose exports of softwood lumber to
the U.S. increased by 13.5 percent in 1993. Softwood lumber imports from Canada are expected to
increase again in 1994, as timber shortages continue. While the U.S. has a large wood product trade
deficit with Canada, it is currently offset by large U.S. exports to Mexico, the Pacific Rim (chiefly
Japan), and the European Economic Community.
Due mostly to the continued decline in domestic softwood resources, there has been incentive in the
industry to increase its efficiency of raw material usage. Because manufacture of reconstituted panels
generally makes much more efficient use of log inputs than conventional plywood manufacture
(sometimes using as much as 90 percent of raw log inputs, compared with 40 percent for normal
plywood), reconstituted panels have become an attractive means to offset domestic timber shortages
(TTA, 1994).
Most reconstituted panel producers were operating at, or near capacity in 1993. Several new mills
started operating in 1993, and because domestic softwood is expected to remain in short supply, more
will probably come on line over the next several years. Oriented strandboard, especially, has
experienced significant growth. The increase in reconstituted panel capacity is expected to be
mirrored by decreases in traditional softwood plywood capacity.
3.2 MAJOR PROCESSES
3.2.1 PULP AND PAPER
The pulp, paper, and paperboard industry includes mills that manufacture market pulp, paper, and/or
paperboard from wood or nonwood pulp. Wood and nonwood pulp may be derived from pre- and/or
post-consumer reclaimed fiber. There are four major types of fiber furnish used in the pulp, paper,
and paperboard industry: (1) hardwood; (2) softwood; (3) secondary fibers (recycled fibers); and (4)
non-wood fibers. Pulps produced from hardwood trees (oak, maple, birch, and others) contain short
fibers which produce high density pulp. Pulps produced from softwood trees (pine, spruce, hemlock,
and others) contain fibers 2 to 3 times longer larger than hardwood fibers in both terms of length and
diameter. Many papers are blends of hardwood and softwood to take advantage of the softwood pulp
strength and the hardwood pulp density. Secondary fiber includes all pre-consumer (e.g., mill broke)
and post-consumer fiber from offsite that are processed at the facility. Nonwood fibers include cotton
linters, cotton rags, flax, hemp, bagasse, tobacco, and other materials including synthetic fibers and
inorganics.
3-19 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
Many mills do not produce any pulp onsite or produce only some of their required pulp onsite.
These mills obtain pulp from other mills by purchase or intra-company transfer, to manufacture final
products. Mills that do not produce pulp onsite, or do not manufacture paper from pulp that is
produced onsite, are referred to as nonintegrated facilities.
In all cases, the type of fiber furnish used depends primarily upon mill location. For example,
integrated pulp mills typically pulp a furnish grown within an economically efficient distance to the
mill, whereas secondary fiber mills are typically located near urban areas, sources of post-consumer
fiber. This section briefly describes the manufacturing processes used by the industry. The only
processes common to all mills are pulp stock preparation and final product manufacture. For very
detailed descriptions of any of these process, please see the Handbook for Pulp & Paper Technologists
by Gary A. Smook.
3.2.1.1 Wood Preparation and Handling
Wood preparation includes converting pulp logs into a form amenable to chemical or mechanical
pulping. Logs arriving at the mill facility by truck or railcar are removed by either a crane or a
front-end loader. Logs arriving via barges are usually unloaded by cranes. The logs arrive in full
tree length, or sizing may have already occurred at the harvesting location. Intermediate log storage
can be either on land or in water. Full-length logs are transferred to the slasher where they are cut to
manageable lengths. Log washing may be performed to remove soil and debris to reduce wear on
wood preparation and handling equipment (Smook 1992).
t-
Debarking
Virtually all mills that handle logs perform debarking, because bark is considered to be a contaminant
in the pulping process. A variety of debarking processes may be used, including mechanical and
hydraulic debarkers. Debarkers differ in their energy requirements, wood loss, and ability to debark
frozen logs (Smook 1992). Five commonly used debarkers are:
• Drum Barking. This procedure employs a cylindrical shell which rotates on its
longitudinal axis. The tumbling and rolling action of the shell removes the bark. Water is
used to reduce dust, promote the thawing of wood in cold climates, and to reduce the bond
between the bark and wood. Drum barkers range from 2.4 to 4.9 meters (8 to 16 feet) in
diameter and up to 22.8 meters (75 feet) in length.
• Bag Barking. In this procedure the logs are rotated in simple stationary containers to
remove bark by abrasion. Water may be used for the same purposes as described above.
Bag barkers also are called pocket barkers.
• Hydraulic Barking. During this procedure a high pressure water jet is used to blast bark
from the log. Pressure ranging from 800 to 1,615 pounds per square inch (psi) is used,
with flow in the range of 400 to 1,600 gallons per minute (gpm).
3-20 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
• Ring Barking. As the name implies, this technique consists of a rotating ring on which
several arms are pivoted. A tool attached to each arm scrapes off the bark.
• Cutterhead Barking. A milling action of a cylindrical cutterhead is utilized as it rotates
parallel to the axis of the logs which are fed through the unit. No water is used during this
operation.
Hydraulic debarking is commonly used in the Pacific Northwest where they are commonly used on
large diameter logs. They operate by directing high pressure (> 1000 psig) jets of water against the
log to remove the bark. This system is effective in removing the bark, but capital costs and energy
requirements are high. Effluents from hydraulic debarking systems are difficult to clean. As a result,
many mills are converting to mechanical debarking systems (Smook, 1992).
Waste materials generated from debarking operations are collected, dewatered, pressed, and then
frequently incinerated. Because of high fuel costs, bark is a valuable fuel source. In addition, bark
may be landfilled or composted.
Chipping
Subsequent wood preparation operations depend upon the pulping process used at the mill. Certain
mechanical pulping processes, such as stone groundwood pulping are performed using logs.
However, most pulping operations require wood chips. There are several types of chipper designs,
the most common being the blades mounted on a rotating disk. Logs are usually fed through a
sloping spout to one side of the rotating disk so that the knives strike the log at 35 to 40° angle. The
ideal chip is usually 20 mm long in the grain direction, and about 4 mm thick (Smook, 1992).
After chipping, wood chips are passed over vibratory screens to remove oversized chips and fines.
Oversized chips are recycled to the chipper. Fines fall through the screens and are collected and
usually burned with the bark.
Once screened, the chips are transferred pneumatically, by conveyor belts, or augers to chip storage
areas. Similarly, if the chips are acquired from nonintegrated facilities they are unloaded and
transferred to the storage areas. Outside chip storage has been practiced since the 1950s because
large inventories can be stored onsite without the use of bins or silos. However, it is now recognized
that losses of 1 % wood substance per month are typical of'outside storage due to a combination of
respiration, chemical reactions, and micro-organism contamination. In addition, fines may be
entrained in air currents and transferred offsite (Smook, 1992).
Efficient chip pile management of outside storage piles has effectively minimized deterioration of the
chips. This includes providing a good base and ground barrier for the chip pile and the first-in/first-
out basis. Generally, chips are not fed directly into the pulping process from outside storage, but to
3-21 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
intermediate bins for metering and blending of the chip furnish. This is a necessity \yhen blends of
different tree species are desired (Smook, 1992).
Secondary Fiber Preparation and Handling
Secondary fiber preparation and handling involves sorting and classifying the materials into grades.
Generally, these operations are performed by the waste paper collector rather than at the mill. At the
mill, secondary fiber preparation and handling may consist of little more than storage and a transfer
and dewiring system for secondary fiber bales. Bales are charged directly to the pulper where
pulping and contaminant removal are performed (U.S. EPA, 1993).
Nonwood Fiber Preparation and Handling
After being harvested nonwood plant fibers are stored before being chopped, screened, and cleaned
prior to pulping. The handling methods are specific to each particular fiber to prevent fiber
degradation and dierefore produce the highest possible pulp yield (U.S. EPA, 1993).
3.2.1.2 Pulping
Pulping is any process by which wood is reduced to a fibrous mass by systematically rupturing the
bonds. The task can be accomplished mechanically, thermally, chemically, or by a combination of
these treatments. Existing commercial processes are broadly classified as mechanical, chemical, or
semichemical. A fourth process is secondary fiber pulping. Secondary fibers, by definition, have
previously undergone pulping, but still require additional processing to make them amenable to
forming into a sheet. The distinguishing characteristics and major products associated with each
pulping process are described below.
Mechanical Pulping
Mechanical pulping technology has undergone dramatic development in the past three decades. The
oldest and still a major method of mechanical pulping is the stone groundwood process, where a block
of wood is pressed lengthwise against a wetted, roughened grinding stone. Fibers are removed from
the wood, abraded and washed from the stone surface with water. The characteristics of mechanical
pulp are listed in Exhibit 3-6. In 1960, virtually all mechanical pulp was produced by the basic stone
groundwood (SOW) process. By 1975, SOW still accounted for 90% of the groundwood production
in North America. However, by 1990, SOW production accounted for less than 50% of the
mechanical pulp produced. The stimulus for this change resulted from three significant changes:
(1) utilization of sawmill residues (chips and saw dust) in place of log bolts; (2) higher pulp strength;
and (3) reduced labor cost (Smook, 1992).
3-22 September 1994
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EIA Guidelines for Pulp & Paper and Timber ' Overview of the Industry
Exhibit 3-6. Characteristics Mechanical Pulping
Pulping by mechanical energy (small amount of chemicals and heat)
High Yield (85-95%)
Short, impure fibers
•Weak
• Unstable
Good print quality
Examples:
• Stone groundwood
• Refiner mechanical pulp
• Thermo-mechanical pulp
A more recent mechanical pulping development is the shredding and defibering wood chips between
rotating disks of a refiner. The product, known as refiner mechanical pulp (RMP) typically contains
more long fibers than stone groundwood pulp and yields stronger paper. The basic RMP process has
recently undergone extensive development. Most new installations now employ thermal and/or
chemical pre-softening of the chips to modify both the energy requirements and the resultant fiber
properties. When wood chips are pretreated with pressurized steam, the resultant product, called
thermo-mechanical pulp (TMP), is significantly stronger than RMP (Smook, 1992).
While advancements have occurred in refiner pulping methodology, the stone grinding method still
has its advantages. Stone groundwood consumes less energy and has a higher scattering coefficient
(i.e., greater sheet opacity) than refiner methods. Also the development of pressurized, high-
temperature grinding has made possible the production of groundwood pulps that is more competitive
with respect to strength (Smook, 1992).
Because of proliferation of new and modified mechanical pulping processes, the TAPPI Mechanical
Pulping Committee published a mechanical pulping nomenclature in 1987. This nomenclature has
received wide acceptance. Each process and name and abbreviation refers to a specific combination
of temperature, chemical, pressure and refining action used to make the pulp. The nomenclature is
listed in Exhibit 3-7.
Stone Groundwood Process
Stone groundwood pulp is produced by pressing blocks of wood against a rotating stone surface. The
wood blocks are oriented parallel to the axis of the grindstone so that the grinding action removes
intact fibers. The basic groundwood process is virtually unchanged from the 1840s. Important
*
3-23 September 1994
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Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-7. Mechanical Pulp Nomenclature and Pulping Methodology
SOW
PGW
RMP
Stone Groundwood
• atmospheric grinding
Pressurized Groundwood
• grinding at temperature > 100° C
Refiner Mechanical Pulp
• atmospheric refining with no
pretreatment
TRMP Thermo-Refiner Mechanical Pulp
• presteaming of chips at > 100'C
• atmospheric refining
PRMP Pressure Refined Mechanical Pulp
• no presteaming
• first-stage refining at > 100°C
• second-stage refining at > 100°C
TMP Thermo-Mechanical Pulp
• presteaming of chips at > 100°C
• first-stage refuting at > 100°C
• second-stage atmospheric refining
PPTMP Pressure/Pressure Thermo-Mechanical Pulp
• presteaming of chips at > 100°C
• first-stage refining at > 100°C
• second-stage refining at > 100°C
CRMP Chemi-Refiner-Mechanical Pulp
• atmospheric (low-temperature) chemical
treatment
• atmospheric refining
CTMP Chemi-Thermo-Mechanical Pulp
• presteaming with chemical treatment at
> 100°C
• first-stage refining at > 100CC
• second-stage atmospheric refining
TCMP Thermo-Chemi-Mechanical Pulp
• presteaming with chemical treatment at
> 100°C
• atmospheric refining
TMCP Thermo-Mechanical-Chemi Pulp (or OPCO
Pulp)
• first-stage refining at > 100°C
• atmospheric chemical treatment
• second-stage atmospheric refining
LRCMP Long Fiber Chemi-Mechanical Pulp
CTLF Chemically Treated Long Fiber
• long fiber is separated from mechanical
pulp
• it is then chemically treated and refined
Source: Smook, Gary A. Handbook for Pulp & Paper Technologists. Second Edition. Angus Wilde Publications:
Vancouver, British Columbia. 1992.
developments have occurred in the design of the grinders, in wood handling and feeding techniques,
and hi the manufacture of pulpstones (grindstones). A modem groundwood plant will consist of four
to six grinders to supply a large paper machine. Automatic log feeders have drastically reduced labor
requirements from 2 to 3 manhours per ton of wood handled to 0.05 manhours per ton of wood
handled (Smook, 1992).
%
Controlled pressure is applied to the wood magazine, causing the log surfaces to be forced against the
face of the pulpstone. Showers wash fibers off of the stone into the pit, and keep the surface of the
pulpstone cool and clean. The pulpstones may be partially submerged in the pit to further cool the
stone. An adjustable dam or weir is used to control the stone's submergence in the pit. The pulp
slurry overflows the dam structure into a common channel leading from each grinder to a central
receiving tank. From here the stock is pumped to the stock room (Smook, 1992).
3-24
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
The key component of the grinder is the shaft mounted grindstone. The quality of the pulp produced
depends primarily on the surface characteristics of the stone. Virtually all stones used in North
America are artificially manufactured using a hard grit material. After a period of time, the stone
surface becomes relatively smooth and productivity decreases to the extent that it becomes necessary
to roughen the stone face. The grindstone is "sharpened" by imprinting a pattern on the surface
using a metal burr, a small patterned metal cylinder. Sharpening is necessary to maintain a constant
groundwood production rate. Stones are usually sharpened on a staggered cycle to that overall
blended pulp quality will change abruptly. Depending on use, grindstones are typically replaced after
two years of steady use (Smook, 1992).
In response to the success of thermo-mecnanical pulping, a modified process to grind wood in the
presence of pressure was developed in Finland in the late 1970s. The first commercial pressurized
ground-wood process (PGW) started in 1980. Currently 2.3 million tons per year of PGW capacity is
installed each year worldwide. PGW pulp is used mostly for printing and writing paper grades
(Smook, 1992).
PGW differs from SOW in two ways. First, grinder occurs in an over pressure of 30 psig, and
second, the pulpstone shower is < 95°C. The over pressure makes it possible to use higher grinding
temperatures. Higher temperatures allows for increased softening of the wood lignin and the fibers
are released from the wood matrix more easily. The long fiber content of PGW pulp is greater and
the fibers are more fibrillated and flexible than SGW pulp. A major advantage of PGW pulp is that
energy consumption is less than what is used for SGW and refiner pulps. The major limitation is that
the PGW system requires a furnish of logs instead of chips (Smook, 1992).
There have been two recent modifications to the PGW process. First, the development of a new
pressurized disk thickener allows shower water to be returned at temperatures > 140°C. This
process produces pulp of higher strength but has a slight loss in pulp brightness due to thermal
darkening. Second, the introduction of chemicals into the grinder showers has been effective for
pulping aspen. In 1990, the first chemi-pressurized ground-wood (CPGW) mill started in North
America which utilizes alkaline peroxide during the grinding operation, followed by a second stage of
peroxide bleaching (Smook, 1992).
Refiner Mechanical Pulping Process
Commercial production of refiner mechanical pulp (RMP) began in 1960. RMP is produced by the
mechanical reduction of wood chips, or sawdust, in a disk refiner. This process produces a longer
fiber pulp than the SGW process. As a result, it is stronger, freer, bulkier, but somewhat darker in
color, than SGW (Smook, 1992).
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
The center of the RMP system is the disk refiner. There are three basic types of disk refiners. First
is the double revolving unit, where each disk rotates in opposite directions. The second design
utilizes a revolving disk opposite a stationary disk. The third system is a revolving double-sided disk
rotating between two stationary disks. Clearance between the plates is critical and controlled by
either an electro magnet or hydraulicly. The material to be refined is introduced into the open eye of
the refiner by a screwfeeder. As the material moves through the refining zone towards the periphery
of the disks, the wood mass is progressively broken down into smaller fibers and eventually into
fibers. Water is supplied to the eye of the refiner to control the consistency of the pulp (Smook,
1992).
Refiner plates are designed with widely-space, thick breaker bars close to the eye. These bars shred
the chips and permit the development of centrifugal forces which move and align the wood particles
radially., The refining zone consists of progressively narrower bars and grooves wherein coarse
material is converted to pulp fibers (Smook, 1992).
The basic RMP process has now been surpassed by thermally and/or chemically modified methods
which produce better quality pulps. New facilities usually incorporate the new technologies and many
older mills have been retrofitted as well. However, the basic principles of the RMP apply to all
refiner pulping methods (Smook, 1992).
Thermo-Mechanical Pulping Process
Thermo-mechanical pulping (TMP) was the first major modification of the RMP. The process
involves steaming the raw material, under pressure, prior to and during refining. The steaming
softens the chips and results in pulps with a greater percentage of long fibers than RMP. Most often,
heating and first-stage refining is carried out under pressure (TMP). However, in a few systems,
pressurized heating is followed by atmospheric first-stage refining (TRMP). Originally, second-stage
refining was carried out at atmospheric pressure, but many new systems are pressurizing the second-
stage refining step to facilitate heat recovery (Smook, 1992).
Chemically Modified Mechanical Pulping Process
Chemical treatment of chips prior to refining, or during refining, were initially investigated as a
means of reducing energy consumption. However, it soon became apparent that the chemical
treatment altered the quality of the pulp by permanently softening the hydrogen bonds in the lignin.
Recently there has been a proliferation of chemical treatment processes (Smook, 1992). However,
this document only discusses the major processes.
Chemithermomechanical pulping (CTMP) has evolved as a modification of the TMP process. It
utilizes chemical impregnation during the steaming stage and peroxide bleaching to produce a high-
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
brightness pulp. Chemical treatment of softwoods is usually with sodium sulfite solution at
application levels between 1 % and 5% on dry wood. The resultant pulp is commonly used for
producing newsprint. Hardwood CTMP grades are produced utilizing an alkaline sulfite impregnation
and low temperature thermal softening (Smook, 1992).
\
Chemi-mechanical pulps (CMP) are produced by chemically treating the chips followed by
atmospheric refining. Depending on the severity of the cook (with respect to chemical application,
temperature and residence tune), the yield is usually in the 85 to 90% range. CMP grades are most
commonly used as reinforcement pulps in newsprint (Smook, 1992).
Chemical Pulping
Chemical pulping involves mixing the raw materials with cooking chemicals under controlled
temperature and pressure. Chemical pulps are manufactured into products that have high-quality
standards or require special properties. There are three chemical pulping-processes: sulfite; kraft;
and soda pulping. The three processes differ primarily in the types of chemical solutions and
chemical recovery processes used. All three processes include cooking (digesting) wood chips in
aqueous chemical solutions at elevated temperatures and pressures. The cooking process dissolves the
lignin that binds the cellulose fibers together. Cooking may be performed using either the batch
process or continuous process (Smook, 1992). The characteristics of chemical pulp are listed in
Exhibit 3-8.
Exhibit 3-8. Chemical Pulp Characteristics
Pulping with chemicals and heat (little or no mechanical energy)
Low Yield (40-55%)
Long, strong fibers
• Strong
• Stable
Poor print quality
Examples:
• Sulfite
•Kraft
• soda
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
Sulfite Pulping ,.
Sulfite pulping dates back to 1857 when it was discovered that wood could be softened and defibered
with sulfurous acid (H2SO3). The first commercial use of sulfite pulp occurred in Sweden in 1874.
Commercialization developed rapidly thereafter and for many decades the calcium acid sulfite process
was the most important pulping method around the world. Until 1950 advances hi the sulfite pulping
process came primarily from unproved equipment and better operating and control methods. The
basic chemistry remained virtually unchanged. Since 1950, the utilization of bases other than calcium
has been the major development. The most notable bases include magnesium, sodium, and
ammonium. These bases allowed for the utilization of tree species which were unsuitable for calcium
acid sulfite pulping. The newer cooking methods netted higher yields with a wide range of .
properties. The higher cost of magnesium and sodium base chemicals has encouraged the
development of efficient recovery systems, which are now vital for environmental control (Smook,
1992).
Recovery of chemicals in the classical calcium base system was never practiced. The waste liquor
was discharged into the nearest receiving water. Even when the liquors are evaporated and
incinerated, it is not economically feasible to recover usable chemicals from the ash because the
makeup chemicals, limestone and sulfur, are inexpensive and readily available (Smook, 1992).
The sulfite cooking liquor is usually prepared by burning sulfur to produce SO2 gas and then
absorbing the gas in an alkaline base solution. The raw cooking acid after SO2 absorption is a
mixture of free SO2 (sulfurous acid) and combined SO2 (calcium sulfite). Before the raw cooking acid
is used it is fortified with SO2 relief gas from the digesters. This fortification usually takes place in
low- or high-pressure accumulators (Smook, 1992).
The cooking operation is performed in a pressure vessel (digester) consisting of a stainless steel shell
with acid resistant lining. The digester is first filled with wood chips and capped. Hot acid is added
to the digester from the accumulator. The digester contents are heated through the circulation of the
cooking liquor. The wood chips increasingly absorb the hot acid as the temperature and pressure are
increased. A relatively low maximum temperature (130 to 140°C) and long overall cook (6 to 8
hours) are typical for acid sulfite cooking. The extent of cooking is dictated by the amount of
delignification that is desired. The point at which the individual cook is stopped is based on the
operator's judgement (Smook, 1992).
When 1 to 1V4 hours of cooking time remain, the heating is discontinued and the pressure is gradually
reduced by relieving gas and steam to the accumulator. When the pressure has been reduced to 20 or
25 psig, the digester contents are "blown" into die blow tank or blow pit. The gases are scrubbed to
recover SO2. In older mills, the pulp is washed to remove residual liquor. This batch washing
3-28 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
process requires large volumes of water and is continuous being replaced by methods that have lower
water requirements (Smook, 1992).
The major driving forces for conventional sulfite processes are pH, free SO, concentration, and
temperature. pH ranges from 1.5 to 2.0 for acid sulfite pulping and 4.0 to 5.0 for bisulfite pulping.
140°C is usually considered the maximum cooking temperature, but when monovalent bases are used,
at higher pH levels, the temperature can be increased to 160°C or higher. The cooking time must be
controlled to achieve a desired level of cooking. When the reaction rate is low, a longer cook is
required. "Slow cooks" can adversely affect the productivity of the pulp mill (Smook, 1992).
From 1960 to 1990, the portion of the world's annual wood production attributed to conventional
sulfite operations decreased from 20% to 8%. Researchers are currently concentrating on alkaline
sulfite pulping, which has shown to have a number of advantages over traditional sulfite pulping,
including: high pulp yield, high strength, insensitivity to wood species, high unbleached brightness,
and easy bleaching). However, there are still some problems, especially with the respect to liquor
penetration into the chips, before it becomes increasingly used (Smook, 1992).
Kraft Pulping Process
The soda process, the precursor to the kraft process was originally patented in 1854. Kraft pulping
was first used commercially in Sweden in 1885. A few soda mills are still in operation around die
world producing pulp from hardwoods and nonwood raw materials. However, the future for soda
mills is bleak. The dominance of the kraft process did not come until the 1930s when the final
evaporation and burning of spent liquor were combined with recovery of heat and chemicals in a
single process unit. Finally the development and promotion of chlorine dioxide bleaching in the late
1940s and early 1950s resulted in kraft pulps with brightness levels similar to sulfite pulps (Smook,
1992).
The digestion process can be either batch or continuous. In batch cooking, the digester is filled with
chips and liquor is added to cover the chips. The contents are then heated by the forced circulation of
the cooking liquor. The maximum cooking temperature is usually achieved after 1 to 1V£ hours. The
cook is then maintained at the maximum temperature (170°C) for up to 2 hours to complete the
cooking reactions. Once the digestion is completed, the chips are discharged into a blow tank, or pit,
where the softened chips are disintegrated into fibers (Smook, 1992).
In continuous cooking, the chips are carried through a steaming vessel to purge air and
noncondensibles. The preheated chips then move into the continuous digester. In the intermediate-
temperature zone (115 to 120°C) chemicals are allowed to penetrate into the chips. As the chips
move through the digester, they are heated to cooking temperature by the either the forced circulation
of liquor or through steam injection. This temperature is maintained for 1 to 1V6 hours. Following
«
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
completion of the cook, hot spent liquor is extracted into a low pressure tank. The pulp is then
usually quenched to < 100°C with cool liquor. The cooked pulp is separated from residual liquor in
a series of countercurrent vacuum washers in a controlled process known as brown stock washing
(Smook, 1992).
\
Wood chips are cooked in "white liquor" containing the active cooking chemicals, sodium hydroxide
(NaOH) and sodium sulfide (Na^). The cooking liquor remaining at the completion of the cook
contains the reaction products of lignin solubilization and is known as "black liquor". Black liquor is
concentrated and burned to yield an inorganic smelt of sodium carbonate (Na2CO3) and sodium
sulfide. The smelt is dissolved to form "green liquor" which is reacted with quick lime (CaO) to
convert NajCOa into NaOH and regenerate white liquor (Smook, 1992).
The major driving forces in the kraft pulping process are alkali concentration (as measured by either
effective alkali or active alkali) of the cooking liquor and temperature. Within the normal cooking
range of 155 to 175°C, the rate of delignification more than doubles for every 10°C increase.
During a typical cook approximately 80% of the lignin, 50% of the hemicellulose, and 10% of the
cellulose is dissolved (Smook, 1992).
The kraft process has become established as the world's dominant pulping method. Nonetheless, the
process has shortcomings including the low yield from wood, the high residual lignin content of
bleachable grades. Various modifications have been proposed over the years to overcome these
shortcomings, including cooking additives, chip pretreatments, and two-stage cooks. The progress
has been slow, but some technologies are emerging into prominence (Smook, 1992).
Sgmichemigfll Pulping
Semichemical pulping is a hybrid system which incorporates some of the characteristics of both
mechanical and chemical pulping. It involves processing wood chips hi a mild chemical solution
before mechanical refining for fiber separation. The chemical solution is usually a neutral sodium
sulfite/sodium carbonate liquor which softens and dissolves lignin to promote fiber separation. The
liquor utilized is neutral or slightly alkaline with a pH of 7 to 9. Therefore, semichemical pulp is
frequently called neutral sulfite semichemical (NSSC) pulp (Smook, 1992). The characteristics of
semichemical pulp process are listed in Exhibit 3-9.
The cooking liquor is prepared by absorbing SO2 gas in soda ash or ammonia. The main reason for
using the semichemical pulping process is that it provides high quality products and high yields, it can
utilize a wide variety of hardwoods, softwoods, and sawdust, and the spent liquor is easily recovered
or incinerated. Semichemical pulp can be very stiff, which makes it particularly useful as the center
layer hi corrugated container board (Smook, 1992).
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
Exhibit 3-9. Hybrid Pulping Characteristics
Pulping with combinations of chemical and mechanical treatments
Intermediate Yield (55-85%)
Intermediate pulp properties (some unique properties)
Examples:
• Neutral sulfite semichemical
• High-yield kraft
• High-yield soda
Secondary Fiber Processing
Secondary fiber processing includes the necessary operations to repulp pre- and post-consumer paper
products and to remove contaminants. Common contaminants include ink, adhesives and coatings,
plastic films (polyethylene), wet strength resins, latexes, waxes, asphalts, and vegetable and synthetic
fibers. The types of secondary fiber processing depend on the grade of waste materials and the
desired final product. For example, broke purchases from another mill may require simple repulping
and little contaminant removal. This high-grade secondary fiber replaces virgin pulp in
manufacturing a variety of products. On the other hand, recycled post-consumer newspaper may
require extensive contaminant removal, including deinking, before reuse in the manufacturing process
(Smook, 1992).
The prime objective when processing secondary fibers is to remove contaminants and upgrade the
material so the fiber is suitable to meet the specifications of the final product. Contaminants cannot
be totally avoided from incoming wastepaper and they must be dealt with in the process system. All
extraneous materials including dirt, rocks, and sand are considered contaminants.
Common to all secondary fiber processing operations is a pulper. Wastepaper is conveyed to the
pulper where the secondary fiber is dispersed into a wet pulp slurry. Rotors at the bottom of the
pulper spin the pulp arid separate the materials based on weight and consistency. In a continuous
pulper, strings, wires, and rags are withdrawn from the stock by die ragger. Initially a few primer
wires are rotated into the stock to start a debris rope, after which the rope builds upon itself. Heavy
objects are thrown into a recess at the side of the pulper by centrifugal force. This material is
removed from the junking tower by a grappling device or bucket elevator (Smook, 1992).
Many pulping systems may utilize a secondary pulper, which increases defiberization and further
separates trash materials from the pulp. A dispersion system is sometimes incorporated into the
3-31 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
secondary pulper to control glues, latexes, and "stickles". The dispersion system disperses
contaminants throughout the surface of the pulp, thereby nullifying any adverse effects.
The major variables affecting defibering are stock temperature and consistency. A higher temperature
stock will facilitate defibering, while power requirements are reduced because of increased fluidity.
Consistency is necessary to ensure good circulation and constant supplies for the paper machines
(Smook, 1992).
Deinking
Deinking of pulp fibers occurs when ink is a contaminant. Chemicals, heat, and mechanical energy
are used during repulping to separate ink particles from fibers and disperse them in the stock
suspension. The ink particles are separated from the grey stock by either a washing and/or a flotation
process. The key chemicals, or surfactants, used in the deinking process are mineral oils, caustic
soda, sodium silicate, and borax. Three types of surfactants are important in the deinking process:
(1) detergents - to remove ink from the fiber; (2) dispersants - to keep the ink particles dispersed and
prevent re-deposition onto fibers; and (3) foaming agents -to reduce the surface tension of water and
to promote foam formation (Smook, 1992).
' In the washing process, detergents and dispersants are added to the pulper to remove ink from the
fibers and disperse them into fine particles. The dispersed ink particles are separated from the pulp
by a multistage dilution/thickening washing sequence. The separation of the ink particles in the
washing process corresponds to the stock thickening process (Smook, 1992).
In the flotation process, chemicals are added to the pulper to promote flocculation of the ink particles
and the formation of foam. The grey stock is subsequently blended with small air bubbles in a series
of flotation cells. The air particles become attached to ink, causing them to rise to the surface of the
cell where they are removed as a dirt-laden layer of froth. Typical deinking facilities contain a series
of 6 to 10 flotation cells to ensure efficient ink removal. Froth that is collected in these cells is
subsequently cleaned in a secondary stage to recover good fibers (Smook, 1992).
Since each deinking method has its respective advantages, the idea of utilizing a hybrid process is
attractive. However, the principles involved and the chemicals used have different purposes. This
lack of compatibility has been a stumbling block. The objective of washing is to break ink down into
panicles under 15 microns, render them hydrophilic, and keep them highly dispersed. In the flotation
process, the ink particles must form hydrophobic floes, ideally in the range of 30 to 60 microns.
This incompatibility has been overcome by the development of a new surfactant. This surfactant
provides enough hydrophilicity for the ink particles to remain dispersed during washing, yet allows
them to maintain enough adhesion between ink particles and air bubbles for flotation to be effective.
For maximum ink removal, flexibility, and secondary fiber quality a two-stage hybrid system is now
3.32 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
preferred. Washing removes fines, fillers, and small ink particles. It also enhances the flotation
stage by removing contaminants that inhibit the attachment of the ink particles to bubbles. The
subsequent flotation stage is effective in removing lightweight contaminants and difficult to disperse
inks (Smook, 1992).
3.2.1.3 Chemical Recovery Process
Recovery, reconstitution, and reuse of spent cooking liquor are necessary for viable economic
operation of most chemical pulp mills. This section describes the liquor burning and chemical
recovery processes operated at kraft, sulfite, and semi-chemical pulp mills.
At kraft mills, weak black liquor recovered from pulp washing, screening, and knotting is
concentrated in multi-stage evaporators. The concentrated weak black liquor is burned in a recovery
boiler to generate energy and leaves a molten smelt consisting of sodium sulfide (Na2S) and sodium
carbonate (NajCOj). The smelt is dissolved in water to form green liquor. The green liquor is
causticized with lime, precipitating calcium carbonate and leaving an aqueous solution of sodium
hydroxide and sodium sulfide (fresh white liquor). The fresh white liquor is reused in the digesters.
The calcium carbonate is converted to quick lime for reuse in the recausticizing cycle (U.S. EPA,
1993).
At sulfite mills that use magnesium salts, spent red pulping liquor is concentrated in multi-stage
evaporators. The concentrated liquor is burned hi a recovery boiler to generate energy, magnesium
oxide (MgO) ash, and sulfur dioxide (SOj) gas. The magnesium oxide ash is slaked to form
magnesium hydroxide. The sulfur dioxide gas is stripped from the flue gas in a gas/liquid contractor
to generate acid, which reacts with magnesium hydroxide to regenerate the cooking liquor (U.S.
EPA, 1993).
At sulfite mills that use sodium salts, weak liquor is concentrated in multi-stage evaporators. The
concentrated liquor is burned in a recovery boiler to generate and leaves a molten smelt consisting of
sodium sulfide (Na2S) and sodium carbonate (Na2CO3). The smelt is similar to that generated from
burning kraft black liquor. Except, the sulfidity of the smelt and the sulfur dioxide content in the flue
gas is significantly greater. The smelt is dissolved in water to form, green liquor. The smelt
chemicals are then regenerated into cooking liquor (U.S. EPA, 1993).
At sulfite mills that use calcium salts, or ammonium salts, spent pulping liquor is burned to recover
energy. Chemical recovery is not possible because of the generation of calcium sulfate (CaSO4), or
elemental nitrogen and water, during the combustion of the cooking liquor (U.S. EPA, 1993).
At semi-chemical mills that also manufacture chemical pulp, spent cooking liquor from semi-chemical
pulping is recovered in the kraft or sulfite chemical recovery system (i.e., cross-recovery). At semi-
3.33 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
chemical mills that do not manufacture chemical pulp, the liquor is disposed through ,-fluidized bed
incineration. Pulping liquor may be recovered by adding the solid products from fluidized bed
incineration to a conventional recovery furnace for reduction, similar to die kraft recovery process
(U.S. EPA, 1993). \ '
At nonwood chemical pulp mills, spent pulping liquor may be evaporated and sold to mills with
excess recovery boiler capacity, evaporated and burned on-site, or discharged to a wastewater
treatment facility. Nonwood spent liquor handling and recovery processes differ from traditional
processes because small amounts of liquor are generated, and the liquor contains fewer combustible
organic constituents (U.S. EPA, 1993).
3.2.1.4 Pulp Processing
Pulps are subject to a wide range of processing, depending on their method of preparation and their
end use. Pulp processing is performed after pulping and before bleaching (if performed), or stock
preparation. The primary pulp processing operations include defibering, deknotting, brown stock
washing, pulp screening, and centrifugal cleaning (U.S. EPA, 1993).
Defibering is performed to all high-yield chemical and semichemical pulps following the cooking step.
Defibering is done to completely separate the fibers. A double-sided disk rotating between two
stationary disks is commonly used for defibering. Pulp is fed into the eye of the refiner and then
flows radially outward between each pair of facing disks. The fibers flow under pressure out of a
discharge port (Smook, 1992).
Deknotting removes knots and uncooked chips (rejects) prior to washing, although some mills wash
the pulp before deknotting. Rejects include materials that do not pass through a % inch perforated
plate. Two types of knotters are used. The older vibrating screen does an efficient job but generates
foam and splatter thereby requiring operator attention. The vibratory knotter is being replaced by a
pressure screen'knotter. This system is a totally enclosed cylindrical, perforated screen through
which stock flows. A series of pressure and vacuum pulses keep the screen clean. Knots are
continuously discharged. The knots and rejects are either disposed of as waste or recycled for
repulping (Smook, 1992).
/
Residual spent cooking liquor is washed from the pulp in brown stock washers. Efficient washing is
critical to maximize the return of cooking liquor to chemical recovery and to minimize carryover of
^ ,
cooking liquor into the bleach plant. Excess cooking liquor increases consumption of bleaching
chemicals. The dominant washing method is the rotary vacuum washer which employs a series of
rotary vacuum washers operating in a countercurrent flow sequence (U.S. EPA, 1993). The main
element of die vacuum washer is a cloth covered cylinder that rotates in a vat of pulp slurry. A
vacuum is applied to the drum as it enters die stock and a layer of pulp builds and adheres to die wire
3.34 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
face of the drum as it emerges from the vat. Wash water is applied to the drum, as it rotates, to
displace the black liquor. Finally, the vacuum is cut off and the washed pulp is removed from die
mold! A variety of other washing technologies are used including: pressure and atmospheric
diffusion washers; rotary pressure washers; horizontal belt washers; and dilution/extraction
equipment. However, they have not displaced die rotary vacuum washer in popularity (Smook,
1992).
i
In most pulp and paper processes, stock screening is required to remove remaining oversized
particles. The pulp passes through a perforated screen and rejects are continuously removed. All
screens must be equipped with some type of mechanism to continually clean the perforated screen.
Otherwise the screen would rapidly plug up. Rejects are removed from the screen by shaking and
vibration, hydraulic sweeping action, back-blushing, or pulsing the flow through the openings with
various moving foils, paddles, and bumps. Mills may operate open, partially closed, or closed screen
rooms. In open screen rooms, wastewater from the screening process is discharged to wastewater
treatment facilities. In closed screen rooms, wastewater is reused in other pulping operations and
ultimately enters the chemical recovery system (U.S. EPA, 1993).
Centrifugal cleaning is used to remove dense contaminants such as sand and dirt. Fiber stock enters
the cleaner tangentially and rotates within the cleaner. Centrifugal force causes the more dense
contaminants to concentrate at the bottom of die cleaner where they are removed. The cleaned pulp
exits through the top of the cleaner. A series of centrifugal cleaners of various diameters is used to
remove a variety of contaminants of different densities (U.S. EPA, 1993).
In pulp and paper mills it is necessary to pulp storage locations at appropriate points in the process to
allow for interruptions in either supply or demand. Mechanical mills may need substantial storage
capacity after the pulping process. But in kraft and sulfite pulping processes, storage capacity is a
requirement at several points hi the process. Storage capacity of at least a couple of hours is a
requirement after cooking and bleaching. In particular, blow tanks provide several hours of storage
and ensure a constant supply of stock to die brown stock washers (Smook, 1992).
3.2.1.5 Bleaching
Bleaching is any process that chemically alters pulp to increase its brightness. Bleaching may be
performed to simply brighten pulp, or to completely remove lignin. Virtually any type of pulp and
secondary fiber can be bleached. However, only chemical pulps are fully bleached. The type of
fiber and pulping processes used, and die end uses of the final product, influences the type and degree
of pulp bleaching required. For example, sulfite pulps and hardwood kraft pulps have a lower lignin
content and are therefore more easily bleached to a higher brightness than softwood kraft pulps.
3.35 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
Chemical Pulps :
The vast majority of bleached chemical pulps are bleached in traditional bleach plants consisting of
•>
multiple alternating stages of chemical bleaching and washing with water. The number of stages
typically ranges from two to six, depending upon the brightness of the unbleached pulp, and desired
final pulp brightness, and bleach plant design and operation. The purpose of the initial bleaching
stages is to dissolve and remove as much lignin as possible. While the purpose of later bleaching
stages is to decolor any remaining lignin. Typically, bleaching stages alternate between acid and
alkaline conditions. During the acid stages, the bleaching chemicals react with the lignin. In the
alkaline stages, the lignin reaction products are dissolved. The washing stages remove the active
bleaching chemicals and dissolved reaction products (U.S. EPA, 1993).
A critical step hi the bleaching process is the reactivity and selectivity of the bleaching chemicals with
lignin. The most common bleaching chemicals used are elemental chlorine, chlorine dioxide, and
hypochlorites (U.S. EPA, 1993).
Semi-chemical Pulps
Semi-chemical pulps are typically bleached with hydrogen peroxide in a bleach tower. Bleaching with
one or two stages or peroxide does not solubilize as much lignin as is dissolved using the traditional
bleaching process, but it increases the pulp brightness and retains a higher pulp yield (U.S. EPA,
1993).
Mechanical Pulps
Mechanical pulps are bleached with hydrogen peroxide and/or sodium hydrosulfite. Bleaching
chemicals may be applied in bleach towers or without the use of separate bleaching equipment.
Mechanical pulp bleaching brightens pulp by destroying at least some chromophoric, or colored
compounds, without significantly reacting with or removing lignin (U.S. EPA, 1993).
Secondary Fiber
/
Deinked secondary fiber is generally bleached with sodium or calcium hypochlorite or elemental
chlorine in bleach towers. Bleaching chemicals may also be added directly to the pulper. Mills that
manufacture newsprint from deinked secondary fiber generally bleach the pulp with sodium
hydrosulfite in bleach towers (U.S. EPA. 1993).
\
Non-deinked secondary fiber is generally bleached to remove dye from the fiber. Bleaching generally
involves adding sodium or calcium hypochlorite directly to the pulper, although some mills may apply
hypochlorite in bleach towers or to the pulp storage chest (U.S. EPA, 1993).
3.35 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
Non-chemical Nonwood Pulps
Mills that pulp cotton linters using non-chemical means generally bleach pulp by adding sodium or
calcium hypochlorite directly to the pulper or brown stock washer (U.S. EPA, 1993).
3.2.1.6 Stock Preparation
Stock preparation is the interface between the pulp mill and the paper machines. In integrated mills,
stock preparation begins with the dilution of stock hi pulp storage chests and ends with a blended
furnish hi the machine chest. In nonintegrated mills, stock preparation begins by feeding pulp bales
into a repulping system. The basic objective in stock preparation is to treat, modify, and combine
pulp and additives into a uniform papermaking stock. The primary concern in stock preparation is to
produce a stock that will ensure stable paper machine operation and produce high quality paper.
Preparation of stock involves four distinct operations. These are pulping, refining, introduction of
additives, and metering and blending. Other operations may be necessary depending of the
requirements of the particular system (Smook, 1992). The four main stock preparation operations are
discussed hi greater detail below.
Pulping
The first step in stock preparation is the mechanical dispersion of pulp hi water (repulping).
Purchased pulp, broke, and/or pulp from high density storage is slurried and defibered to completely
disperse all of the fibers. The operation can be either continuous or batch. In batch repulping
operations, the defibering is usually completed in a single vessel. With continuous repulping, a
supplemental treatment is commonly used, after the pulper, to ensure complete dispersion. Virgin
pulps, broke, and reclaimed papers have different energy requirements for repulping. Unbleached
kraft is difficult to reslurry and defiber, especially after storage at low moisture levels. The most
difficult raw material to repulp are reclaimed fibers (Smook, 1992).
Beating
Before making paper or paperboard, the pulp is beaten or refined. The objective of beating, or
refining, is to modify pulp fibers to meet the demands of the particular papermaking finish. This
makes the finished product stronger, more uniform, more dense, more opaque, and less porous.
Although refining and repulping are considered separate operations, there may be considerable
overlap hi practice. Mechanical modifications may occur during pulping. Likewise, refiners may
assist in the defibering process (Smook, 1992).
3.37 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
Additives .
Most paper is sized to resist penetration of liquids, either internally as the paper is being made on the
machine, or externally after the paper sheet is formed. Rosin, rosin size, emulsified waxes, fortified
sizes, bituminous emulsions, latex, and silicones are commonly used internal paper sizes. Paper
sizing is applied with various precipitants, including alum and sodium aluminate. Wet strength resins
are added when papers must retain considerable strength when wet, such as paper towels. Fillers are
added to improve texture, print quality, opacity, brightness, and to affect certain physical properties,
such as pore size for filterabiliry, porosity, burning rate (for cigarette paper), and formability. Fillers
commonly include clays, silicas, talc, and certain inorganic chemicals such as calcium sulfate, barium
sulfate, zinc sulfide, and titanium dioxide, which is also used as an optical brightener. Many papers
are colored by the addition of inorganic and organic synthetic dyes and pigments (U.S. EPA, 1993).
Metering and Blending
Metering and blending are important components of the stock preparation process. Accurate
proportioning of pulps and additives into a uniform blend depends on both the consistency and flow
rate of each component. Without a uniform pulp there is the tendency for erratic behavior on the
forming wire and subsequent paper machine steps (Smook, 1992).
3.2.1.7 Pulp, Paper, and Paperboard Making
Paper and paperboard making consist of "wet end" operations and "dry end" operations. Wet end
operations include sheet formation using either a Fourdrinier, twin wire, or cylinder press machine
process and pressing. Dry end operations include drying, calendaring, reeling, winding, and
application of surface treatments. Paper and paperboard making differ primarily in the thickness of
the sheet formed. Dry end operations consist only of pulp drying and on-machine slitting and sheet
cutting (U.S. EPA, 1993).
The Fourdrinier is the most common wet end system used for paper and paperboard formation. Pulp
fibers are distributed uniformly across the width of the headbox. The headbox deposits the fiber
slurry onto a thin moving wire mesh belt through which excess water drains. Suction from a series
of hydrofoils, vacuum boxes, and vacuum rolls further dewaters the formed sheet as it moves from
the headbox toward the press section. In a twin wire system, the fiber is deposited into the gap
between two converging wires. Excess water drains through the wire mesh. Additional dewatering is
performed from suction applied from both sides of the sheet. In all processes, excess water is
captured and the fibers entrained in the water are thickened and cleaned, and dien recycled into the
headbox (U.S. EPA, 1993).
From the wire, the formed sheet enters the press section where additional water is removed and the
fibers compacted together. The sheet then enters the dryer section where remaining water is
3.35 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
evaporated and the fibers begin to bond together. In the calendar section, the sheet; is pressed
between heavy rolls to reduce paper thickness and provide a smooth surface. Finally, the paper is
wound onto a reel for intermediate storage. On-or off-machine rewinding is then performed to cut
and wind the full-size reels into smaller, more manageable rolls. The rolls are then wrapped and
ready for distribution (U.S. EPA, 1993).
The production of market pulp uses the process described above, but the final dried product is rolled
or slit and cut on-machine to produced baled pulp sheets. Market pulp may be dried by the air float
process or by the flash drying process. In the air float process, the pressed pulp sheet passes through
a chamber where hot air dries the suspended sheet. In the flash drying process, die pressed pulp is
fluffed and injected into a series of drying towers. Hot gases in the towers vaporize moisture in the
pulp. The dried pulp is then compressed and formed into bales (U.S. EPA, 1993).
Paper finishing, if used, includes adding surface treatments, such as external sizing or coating, and
super calendaring. External surface sizing is generally applied in a size press or in the calendar
stack. Coatings are applied to provide various surface qualities, such as improved gloss, slickness,
color, printing detail, and brilliance. Lighter coatings are generally applied on-machine, while heavy
coatings are generally performed off-machine. Super calendaring consists of running the paper sheet
through a vertical stack of hard and soft rolls, providing a smooth, glazed appearance for high-quality
printing papers (U.S. EPA, 1993).
3.2.2 TIMBER PRODUCTS PROCESSING
The major components of the various processes and their purpose are described in this section. Often
process flow diagrams are provided to indicate the transformation of raw input materials to finished
products and to identify major associated waste streams. To the maximum extent possible, newly
introduced technical terms are defined clearly in the text and/or the Glossary. The principal basis
documents for this section.include U.S. EPA (1974a, 1974b, 1974c, 1981, 1991).
3.2.2.1 Log Storage
Because timber harvesting operations may be sporadic, log storage often is essential for uninterrupted
mill production. Logs may be stored either on land or in water. When stored on land ("land
decking"), there exists a tendency for the ends of the logs to dry and crack, which is known as "end
checking." To prevent end-checking, water is sprayed on the decks, a technique referred to in the
timber industry as "wet decking." Frequently the water recovered from wood processing activities
(e.g., sawguide and compressor water) is used for wet decking. The effluent from the wet decking in
some cases is collected and recycled, but more commonly it is discharged into a catch basin. For
some species wet-decking is necessary to prevent growth of blue stain fungus.
3.39 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
Logs are stored in water either individually or less commonly in bundles. Logs may. be stored in log
ponds, stream impoundments, mill ponds, and marine or estuarine waters. Log ponds are bodies of
water in which the influent and effluent either are small or controlled. An impoundment of sufficient
depth for log storage may be formed by the construction of a dam across a stream. Such an
impoundment is subject to the same types of operational restrictions as log ponds, the primary
difference being the greater flow of water through a stream impoundment. Mill ponds are manmade
water impoundments primarily used for sorting logs and feeding them into a plant. They typically
have low flow rates and short log-residence times. Logs also are stored in estuarine and ocean
waters, particularly in the Northwest and Alaska. These logs are placed into water, sorted, and
stored in a protective cove or bay, with provisions made for water level changes with the tide. Log
residence times are typically longer than in other storage areas.
3.2.2.2 Log Washing
Log washing often is desirable prior to barking and/or sawing operations to remove the soil particles
from the surface of the logs. While the desirability or necessity of this practice cannot be clearly
established, some of the reasons for its use are as follows: (1) where bark is utilized as a fuel, log
washing prior to barking reduces the amount of slag buildup on boiler grates and, consequently,
reduces frequency of grate washdown; (2) if bark is used for other purposes, a minimal amount of
grit is desirable; and (3) for mills not barking prior to sawing, log washing increases saw life. It is
carried out by spraying logs as they are transported to the headrig or stored in log ponds. Water
under pressure is utilized to remove the foreign material; the pressure and volume are about 68
atmospheres (100 psi) and 5 to 17 liters per second (80 to 265 gpm) respectively.
3.2.2.3 Barking
Throughout the timber products processing industry, the common starting point is the barking
operation, where the bark is removed from logs by one of several wet or dry processes. Barkers may
be wet or dry, depending on whether or not water is used in the operation. There are several types
of debarkers including drum barkers, ring barkers, bag barkers, hydraulic barkers, and cutterhead
barkers. With the exception of the hydraulic barker, all use abrasion or scraping actions to remove
bark. Hydraulic barkers utilize high pressure jets of water as the logs are rotated. Hydraulic barking
is less common now than it was before the 1981 effluent limitations were established for this
operation.
Increasingly harvested trees are debarked before delivery to the processing facility. Bark may be
peeled by hand at the harvesting site or with small mechanical barkers at the landing.
3-40 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
3.2.2.4 Veneer and Plywood ...
Plywood is an assembly of layers of wood (veneer) joined together by means of an adhesive.
Hardwood plywood is manufactured from broadleaf trees and is used primarily in furniture and
decorative panels, whereas softwood is made from conifer woods and is used commonly in
construction. In addition to its use in plywood manufacture, veneer is used in the manufacture of
several other wood products, primarily cabinets and furniture.
The operations to convert roundwood into veneer and finally into plywood chiefly are mechanical.
Exhibit 3-10 presents a flow diagram for veneer and plywood production. The following processes
typically are utilized during the manufacturing sequence of veneer and plywood.
• Log Conditioning (heating logs). This is the practice of adjusting moisture in logs by
heating prior to cutting to improve slicing properties of the wood (especially in plywood
bathing) and in some cases to facilitate debarking. Conditioning can be achieved by one of
two methods: (1) by directing steam onto the logs in a "steam vat," or (2) by heating the
logs in a hot water vat which, in turn, is heated either directly with live steam or indirectly
with steam coils.
• Veneer Cutting. The appearance of the grain pattern of a plywood panel largely is
dependent upon the manner in which the veneer is cut during this operation. There are five
basic methods, the most common of which are rotary cut and plain slicing.
Rotary cut veneer is produced by centering the log in a lathe and" rotating it against a
cutting knife which peels off continuous pieces of veneer. The log is rotated by chucks
positioned at each end of the log. The rotary cut produces a variegated grain.
Plain slicing produces a flat cut veneer panel. The veneer is sliced parallel to the
diameter of the center of the log. The panels display a cathedral grain. The log is
placed in a log bed that moves up and down. The veneer is sliced on each downward
stroke by a stationary knife.
Half-round slicing is a variation of plain slicing. The flat veneer panel is sliced at a
slight angle from the diameter of the center of the log. The angle is achieved by
mounting the flitch (piece of log) to a "stay log" and rotating it. It also produces a
cathedral grain effect.
Quarter slicing produces straight grain patterns by making slices perpendicular to the
annual growth rings of the log. The log is fixed to a mount that moves up and down,
slicing the veneer on the downward stroke.
Rift-cut is a variation of quarter slicing used for various species of oak. The flitch is
rotated slightly to minimize flake from the medullary ray cells.
3-4\ September 1994
-------
ib
LIQUID WASTE M
"GREEN END" fTf A|| OR|M WAa||
OVERFLOW FROM CONOINSATI AND OILUOt
LOO POND WATER
LOO STORAGE
(LOO POND, -' - r _ LO
COLO DECK OEIW
OR BOTH)
-./H'li.—.—
SOLIDS
LIQUIDS
1 EXHAUST
BASES
0 - LOO _ VENEER ^ VENEER 1
HKINO • STEAMINO "^ LAI HE "* OHIER "' '
BARK
OLUE V—
PREPARATIONT
OLUE Rf
VENEER ^ OLUE ' Rl
PREPARATION "* LINE
i
UNUSABLE
VENEER AND
TRIMMINGS
1
S
OLUE WASH *
WATER o
"ai
?
.CYCLE ^
2
•SSIN( _ FINISHINO ~>
* . °
„_. ,., -*
i
TRIM AND ^
SANDER g
OUST 0.
a
__ _j 1
SOLID WASTE IS BURNED IN BOILER 1
CHIPPED POM REUSE OR SOLO . ~
Source: U.S. EPA. 1974H. Development document for effluent limitations guidelines and new source performance g-
standards for the plywood, hardwood, and wood preserving segment of the timber products processing point source category. B
EPA-440/l-74-023a. Washington DC.
f
g
i
-------
EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
• Veneer Drying. Freshly cut veneers are dried before being glued together. Drying is
accomplished in a long chamber equipped with rollers on belts which advance the veneer
longitudinally. The fans and heating coils are located on the sides of the chamber to control
humidity and temperature. Veneer drying also is achieved by transferring the heat to the
air by heat exchangers. Progressive and compartment type lumber kilns also are used to
dry veneer.
• Gluing Operations. Before gluing, a series of minor operations that prepare or repair the
veneer stock often are performed. These operations may include grading and matching,
redrying, dry-clipping, jointing, taping and splicing, and inspecting. During the actual
gluing operations, a number of adhesives can be used to join veneer sheets together into
plywood. The three most commonly used classes of glues are: (1) protein, (2) phenol-
formaldehyde, and (3) urea-formaldehyde. The first is extracted from plants and animals
and is thermoplastic while the other two are synthetic and thermosetting.
• Pressing. This is achieved by subjecting the layers of veneer to pressure to ensure proper
alignment and an ultimate contact between the wood layers and the glue. Pressing may be
accomplished at room temperature (cold-pressing) or at high temperature (hot-pressing).
• Finishing. The final or finishing operation includes redrying, trimming, sanding, sorting,
molding, and storing. The particular finishing steps employed depend upon the process
chosen and the requirements of the final product.
3.2.2.5 Hardboard
The production of hardboard involves reducing trees to fibers and reforming these fibers into boards
with new properties not found in the raw unprocessed wood. Chemical additives are mixed with the
pulp prior to board formation to increase strength, water resistance, and to add other desirable
qualities.
Hardboard may be manufactured through use of a wet or dry process based upon die manner in which
the board is formed. Exhibits 3-11 and 3-12 show a typical in-plant diagram of a dry process and a
wet process, respectively. The main difference between the two processes is the manner in which the
fibers are carried and formed into a mat. The principal hardboard process steps are as follows:
• Raw Material Handling. The basic raw material for the production of'hardboard is wood
in the form of roundwood, wood chips from waste products from saw mills, or other
sources of wood fiber. Exhibit 3-13 illustrates the handling of raw material in the
hardboard industry. The species composition includes both hardwoods (oak, gum, aspen,
cottonwood, willow, sycamore, ash, elm, maple, cherry, birch, and beech) and softwoods
(pine, Douglas fir, and redwood).
• Chipping. Chips either are processed at hardboard manufacturing plants or converted from
larger pieces offsite and hauled to the mill. Of the several types of chippers utilized in the
timber products industry, die disc chipper is the most common. The size of chips is
controlled by screens which may be of the rotating, vibrating, or gyrating types.
Stockpiling of chips is in the open, under a roof, or in chip silos.
3-43 September 1994
-------
I
2,
t
CH IPS
STEAM
Fl BER
CHIPS
MAT
BOARD
TO ATMOSPHERE
AT
WtT FOMMINt
MACHINE
(80) \ (40)
SCREW
-FEED
TO
FINISHING
WATER IN
WATER OUT
(XX) APPROXIMATE PERCENT FIBER
(CONSISTENCY IN PROCESS)
Source: U.S. EPA. 1974h. Development document for effluent limitations guidelines and new source performance standards
for the plywood, hardboard, and wood preserving segment of the timber products processing point source category. EPA
440/l-74-023a. Washington DC.
i
o-
5
•c?
ft?
I
I
-------
CHIPS
u>
TO
FINISHING
(80)
CH I PS
FIBER
PREPRESS
MAT
(0)
BOARD
(XX) APPROXIMATE PERCENT MOISTURE
JP
"S
Source: U.S. EPA. 1974h. Development document for effluent limitations guidelines and new source performance standards
for the plywood, hardwood, and wood preserving segment of the timber products processing point source category. EPA
440/l-74-023a. Washington DC.
-------
Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-13. Basic Raw Materials Handling Sequence in the Hardboard Mill
Source: U.S. EPA. 1974h. Development document for effluent limitations guidelines and
new source performance standards for the plywood, hardboard, and wood preserving segment
of the timber products processing point source category. EPA-440/l-74-023a. Washington
DC.
3-46
September 1994
-------
EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
• Fiber Preparation. There are two basic methods of fiber preparation—the explosion
process and the thermal-plus-mechanical refining process. In the explosion process, the
: wood chips are subjected to high temperature steam in a "gun" or high pressure vessel and
ejected through a quick opening valve. The softened chips burst into a mass of fiber or
fiber bundles upon ejection. The thermal-plus-mechanical pulping process involves a
preliminary treatment of the raw material with heat in addition to mechanical action in order
to reduce the raw material to pulp.
• Forming Hardboard. Hardboard consists basically of reduced wood materials in a fibrous
state which are laminated together in the form of sheets or boards and which have
properties and characteristics not attainable in the natural wood. Chemical additives are
introduced to the pulp in order to give strength, water resistance, and other desirable
properties to the hardboard. After the inclusion of additives to the refined pulp, which may
be in the form of either a wet slurry or dry fluff, the pulp is ready for delivery to the board
former to begin the process of reassembling fibers into hardboard. The formation or felting
of fibers to form a mat may be accomplished by either the wet felting (wet matting) process
or the air felting (dry matting) process.
• Wet-Felting. Mat is formed by either the wet felting (wet matting) process or the air
felting (dry) process. During the wet process the mat usually is formed on a fourdrinier
type machine similar to those used in papermaking. The thickness of the wet mat normally
is three or four times the finished thickness of the hardboard to be produced. The wet mat
may be delivered directly to a platen press where water is removed by a combination of
pressing and heating or it may be conveyed to a heated roll dryer where water is evaporated
by heating alone.
• Dry-Felting. This denotes the formation of a fibrous felted mat from an air suspension of
damp or dry fibers and the arrangement of such fibers into a mat for paper or board.
Hence the main difference in the air felting (dry process) matting process and the wet-
felting process is that the dry process fibers are suspended in air rather than in water. The
equipment used to lay down a continuous mat of dry fibers is called a felter.
• Hardboard Press. After the reassembly of wood particles is completed, fibers are welded
together into a tough, durable, grainless board on die hardboard press. A combination of
heat and hydraulic pressure applied to mats in the press welds the fiber together. The
desired physical properties of the hardboard to be produced and the process selected dictates
the temperature, pressure, and time required for pressing.
• Pressing Operations. There are two basic types of hardboard, "smooth one-side" (SIS)
and "smooth two-side" (S2S). The direct press method is used to produce hardboard
smooth one-side (SIS) (Exhibit 3-14). The evaporative drying method is used to produce
smooth two-side (S2S) hardboard (Exhibit 3-15). In the SIS hardboard process, the wet
mat is fed into the press as it comes from the forming machine. Screens are used on the
back side of SIS mats in the press. Temperatures used in the production of SIS hardboard
approximate 190°C (380°F). The entire process of pressing the board is carefully
controlled by automated electrical equipment. During S2S hardboard production, the mat is
delivered from the forming machine into a hot air dryer where surplus moisture is
evaporated. This may require from one to several hours depending upon the weight of
board being produced. At this stage, me mat is trimmed to the desired length and width
and delivered to the S2S hardboard process. At this point, the board may have less than 1
percent moisture content, and it is strong and rigid enough to support its own weight.
Thus, board can be delivered directly into the press openings and pressed with smooth
3.47 September 1994
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Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-14. Flow Diagram of a Typical W
Producti<
LOGS
O
LOG
STORAGE
,
LOG WASH
I
OE BARKER
+.
CHIPPER
/
/STOf
\
»AGE\
1
^
TO PROCESS
et Process Hardboard Mill SIS Hardboard
on Line
U
Q
. i
o> br»
CHIPS a .c
/ STORAGE\ 1 §
L ^ '= •*
/CM
/ WA
EX
9b. Proposed development document for effluent limitations gi
r the timber products processing point source category. EPA>
r- ,0
ON <*-
— to
'I
ID §
si
ii
O ft)
00 0."
"
September 1994
-------
PMMVAIM
nun
too
STORAGE
DEBAMMNQ
CMP
STORAGE
CMP
CMP
WASHED
DIGESTER
1
rutm w*m
1
PMUARV
vim VATM
1
FIBEII
— •
rnuNWAim
1
SECONDARY
— •
vmt mum
*
STOCK
•VWOMIMW
t
— i
POMMIM
PUf DMVBI
WASH
HEFINEH
ENMCHD «Mti
•V MOMIC1 «Nt MCVCU
REFINER
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MACMNE
VO
•Mil WMU MCTCU I
•mm
nun
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OVEN
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WATOIM
I tVAMMUTNM
I
Source: U.S. EPA. 1979b. Proposed development document for effluent limitations guidelines and new source
performance standards for the timber products processing point source category. EPA 440/1-79-023b. Washington DC.
-------
Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
platens, or caul plates, directly against both sides. Caul plates may be smooth or embossed
for a special surface effect on the board. The press may be hand or automatically loaded
and unloaded. A dry-formed mat also may be used to produce S2S hardboard.
• Oil Tempering. Following the pressing operation, both SIS and S2S hardboard may
receive a special treatment called tempering which involves impregnating the sheets of
hardboard by dipping or roller-coating them hi various drying oils. After the oil bath, they
are passed through a series of pressure rollers which increases absorption of the oils and
removes any excess. The oil is stabilized by baking the sheet from two to four hours at
temperatures ranging from 143°C to 171°C (290° to 340°F). The purpose of tempering is
to increase hardness, strength, and water resistance.
• Humidification. Sheets of hardboard removed from the press or the tempering oven are
hot and dry; the boards must then be subjected to a seasoning operation called
" humidification." Humidification is performed to prevent warping and dimensional
changes. Humidification is achieved by conveying boards through a long tunnel humidifier
or in a high-humidity chamber.
3.2.2.6 Wood Preserving
Wood preservatives are used to delay deterioration and decay of wood caused by wood-destroying
organisms such as insects, fungi, and marine borers. The term "wood preservative" may also refer to
fire retardants, which prevent wood from supporting its own combustion. The wood-preserving
process consists of two basic steps: (1) conditioning the wood to reduce its moisture content, and
(2) impregnating it with the desired preservatives.
Conditioning
Wood preserving consists of the application of preservative chemicals to wood to protect against
decay and deterioration. Surface discoloration (sapstaining) can be adequately controlled by applying
a superficial coat of preservative, but for long-lasting effectiveness, deep and uniform penetration of
preservative into the wood is required. This type of penetration can only be achieved if the wood has
been properly conditioned before the preservative is applied. However, even with proper
conditioning, only a limited number of wood species are amenable to wood preservation (e.g., spruce
and fir do not treat well).
Seasoning and mechanical conditioning are the two most commonly used conditioning methods.
Untreated wood may undergo either one or both of these conditioning methods before preservative
application. Seasoning reduces the moisture content of freshly cut wood to a point where the
preservative can penetrate and be retained by the cells of the wood. Mechanical conditioning consists
of physically preparing the wood to improve the penetrability of the preservative, usually by making
holes or incisions along the wood surface. Seasoning conditioning methods are described below:
3-50 September 1994
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EIA Guidelines for Pulp & Paper ahd Timber Overview of the Industry
• Steam Conditioning. Conventional steam conditioning (open steaming) is a process in
which wood is subjected to direct steam impingement at an elevated pressure in a closed
vessel or retort, thus vaporizing the water content of the wood. Immediately following
steaming, a vacuum is applied for one to three hours to pull the steam and vaporized wood
water from the retort. Steam condensate that forms in the retort is removed through traps
and is generally conducted to oil/water separators for removal of free oils. The steam
condensate may be further treated prior to reuse or discharge offsite.
• Closed Steaming. A variation of conventional steam conditioning is closed steaming, in
which steam is generated in situ by covering coils in the retort with water from a reservoir
and heating the water by passing process steam through the coils. The water is returned to
the reservoir after oil separation and is reused during the next steaming cycle. A small
blowdown from the storage tank is necessary to remove excess water and control the level
of wood sugars in the water. Because the steaming water may be reused, closed steaming
generates less wastewater than open steaming.
• Modified Closed Steaming. Modified closed steaming is another variation of the steam
conditioning process in which steam condensate is allowed to accumulate hi the retort
during the steaming operation until it covers the heating coils. Direct steaming is then
discontinued and the remaining steam required for the cycle is generated within the retort
by using the heating coils. At the end of the steaming cycle, the water in the cylinder is
discharged after oil contaminants are removed.
• Vapor Drying. Vapor drying consists of exposing wood hi a closed vessel to vapors from
an organic chemical. Selected derivatives of petroleum and coal tar, such as high-flash
naphtha, or Stoddard solvent, are preferred; but numerous chemicals, including blends, are
also employed as drying agents hi this process. Vapors for drying are generated by boiling
the chemical in an evaporator. The vapors are conducted to the retort containing the wood,
where they condense on the wood, give up their latent heat of vaporization, and cause the
water hi the wood to vaporize. The water vapor thus produced, along with excess organic
vapor, is conducted from the vessel to a condenser and then to a gravity-type separator.
The water layer is discharged from the separator and the organic chemical is returned to the
evaporator for reused. At the end of the heating period, the flow of organic vapors to the
vessel is stopped, and a vacuum is applied for 30 minutes to 2 hours to remove the excess
vapor along with any additional water. Since the drying cylinder frequently serves as the
pressure treatment cylinder, the wood can be treated immediately after conditioning.
• Boulton Conditioning. Boulton conditioning consists of heating wood in a preservative
formulation in a pressure treating cylinder under vacuum conditions. The preservative,
which has a boiling point higher than the boiling point of water, serves as a heat transfer
medium. After the temperature in the treating cylinder is raised to operating temperature, a
vacuum is drawn and water vaporizes from the wood, passes through the preservative bath,
and is collected hi a condenser. The condensate then may go to an oil-water separator and
any further treatment or recycling steps. Boultonizing is usually limited to wood that is to
be treated with creosote or pentachlorophenol formulations through a pressure treatment
process.
• Kiln Drying. In kiln drying, lumber or poles are placed hi dry kilns in which air is
circulated. Drying temperatures and tunes vary with wood species and the type of product.
3.51 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
Kiln drying may produce wastewater in the form of condensate, which drains from the kiln
during the drying cycle. Wood treated with inorganic preservatives may be kiln dried after
. : treatment to remove excess water.
• Air Drying. Air drying consists of allowing wood to dry at ambient temperatures in
storage yards for several months or longer.
Preservative Application
After conditioning, preservatives may be applied by either pressure or nonpressure processes. The
three most commonly used types of wood preserving agents are creosote, pentachlorophenol (PCP),
and inorganic arsenical and/or chromate salts. The relative importance of inorganic preservatives has
surged in recent years, while PCP and creosote based preservative use has declined steadily. A
significant number of plants use more than one type of preservative, utilizing PCP in some
applications, and inorganics or creosote in others. Each of the three preservative classes are
described briefly below. Environmental effects associated with their constituents may be found in
Section 4.1.3. The following information on preservatives was taken from the U.S. EPA, Office of
Solid Waste document, Background Document Supporting the Listing of Wastes From the Wood
Preserving Processes. Vol.1:
• Pentachlorophenol (PCP). PCP-based preservatives are used mainly for treatment of
poles, crossarms, lumber, timber, and fence posts. PCP is in the chlorophenol group of
synthetic organic compounds produced by reacting chlorine with phenol. A wide array of
solvents are used to carry the PCP into the wood, including heavier fuel oils and creosote
oils, as well as more volatile solvents like alcohols or methylene chloride. Standard
petroleum oils are the most commonly used in formula preparation. PCP formulations
employing petroleum solvents typically contain 5 percent pentachlorophenol.
Concentrations have been reported to range from 2 to 9 percent. The stock PCP used to
prepare formula had been reported to contain roughly 83 percent PCP, 12 percent other
, chlorinated phenols, and 5 percent impurities such as chlorine compounds and inert
materials. The impurities may be comprised of significant amounts of dioxins, furans, and
polynucleated aromatic hydrocarbons (PAHs). Many of the PCPs found at wood preserving
facilities are chronic systemic toxicants. For more information on the environmental and
toxic effects of PCP, refer to sections 4.1.3.6 and 4.3.2.1.
• Creosote. Creosote formulations are used mainly for treating railroad ties, fence posts,
lumber and timbers, marine and freshwater pilings, crossarms, and poles. Creosote is a
generic term referring to relatively heavy residual oils derived from distilled tar or crude
oil. In general, only coal-tar based creosotes are accepted for use by the American Wood
Preservers Association. Creosote formulations may contain only pure coal-tar derivatives,
or they may be solutions, where the creosote has been blended with petroleum oil or crude
coal-tar. Occasionally, creosote formulations are fortified with insecticides.
Most formulations consist of pure coal-tar creosotes. This pure creosote is comprised of a
variety of PAHs and is about 1 to 3 percent water by volume. For the creosote blends of
petroleum oil or crude coal-tar, non-creosote components comprise from 40 percent to 70
3.52 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
percent of the preservative solution. The particular formulation used by ,-a facility depends
on the specific application involved, and on the local availability of blending agents and
other additives. Creosotes are also chronic systemic toxicants and some PAH constituents
are carcinogens.
• Inorganics. Inorganic preservative solutions are used mostly for treating lumber and
timber for the building industry. Inorganic preservatives are produced by dissolving
arsenical and chromate salts and fluorides in water. The most commonly used type, by far,
is chromated copper arsenate (CCA). Other inorganic preservatives include ammoniacal
copper arsenate (ACA), acid copper chromate (ACC), chromated zinc chloride (CZC), and
fluor-chrome-arsenate-phenol (FCAP). Prior to wood treatment, the CCA solution is
usually diluted to roughly 1 or 2 percent total CCA concentration. The CCA concentration
may be as high as 8 percent. The environmental effects of these solutions are primarily
attributed to the chromium, arsenic, and phenol constituents. Chromium and phenol are
acute toxins. Arsenic is a Class A carcinogen.
Pressure processes for applying wood preservatives employ a combination of air and hydrostatic
pressure and vacuum. Pressure treatment is accomplished by submerging wood hi a preservative
solution within a sealed cylinder, or retort. Nonpressure processes are usually carried out in open
tanks, at atmospheric pressure. Wood is immersed in the treating chemicals, which may be at
ambient temperature or above. Exhibits 3-16 and 3-17 present a flow diagram of the pressure/
vacuum and nonpressure treatment processes, respectively.
• Pressure Treatment Processes. There are two basic types of pressure treatment processes,
distinguished by the particular sequence of application of vacuum and pressure. The first
pressure method is referred to in the industry as the "empty cell" process. In the empty
cell process, the retort is first pressurized to force the preservative into the wood. The
pressure cycle is followed by a vacuum to remove excess preservative. The empty cell
process is used to obtain relatively deep penetration with limited adsorption of preservative,
typically desired for products such as railway ties, poles, fence posts, and construction
timber. The second method, known as the "full cell" process, results in higher retention of
preservative but limited penetration compared to the empty cell process. In the full cell
process, a vacuum is drawn on the retort, and the preservative is added, breaking the
vacuum. The preservative is then forced into the wood under pressure. The full cell
process is particularly desirable for wood used in the marine environment. The difference
between the empty cell and full processes can be viewed simply as whether the objective is
to fill the wood cells (full cell) or just to coat them (empty cell) with preservative. There is
no difference in the types of wastes generated by full cell and empty cell processes,
although wood treated by the full cell process may drip more and had a greater tendency to
bleed than wood treated by the empty cell process.
»
• Vacuum-only Process. A vacuum-only preservative process is also used. This process is
simpler to control than the pressure-vacuum processes but requires more complex
equipment than is generally used for nonpressure processes. The vacuum-only process is
performed by enclosing wood in an airtight container, pulling an initial vacuum, and adding
preservative solution to atmospheric pressure. The preservative is driven into the wood by
the pressure difference between the initial vacuum and the atmospheric pressure. A final
3.53 September 1994
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f
I
-------
Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
vacuum may be applied to control preservative retention and recover excess solution. The
vacuum-only method is commonly used to treat window sashes with pentachlorophenol.
• Nonpressure Treatment Processes. A limited quantity of wood is treated by nonpressure
processes. Nonpressure processes include brushing or spraying, dipping, soaking, and
thermal processes. The length of treatment and the concentration of the preservative are
important factors in nonpressure processes because the preservative is driven into the wood
by diffusion.
Brushing and Spraying. In the brushing and spraying methods of preserving wood,
the preservative is applied to the surface of the wood in a thick layer and is allowed to
soak in. Creosote and pentachlorophenol preservatives are generally applied by these
methods. Brushing and spraying are most effective when applied to end-grain surfaces
because better penetration occurs in the direction of the grain. The preservative is
usually mixed and stored in tanks or drums from which it is applied to the brush or
sprayer. Brushing requires very little equipment and results in quick, easy, and
inexpensive application of preservative to the wood.
- Dipping. Dipping is generally used to treat structural forms of timber and consists of
immersing wood in a bath of preservative for a few seconds or a few minutes. Like
brushing and spraying, dipping is also used to apply creosote and pentachlorophenol
preservatives, although it generally uses more preservative. Dipping has the advantage
over brushing and spraying of more adequately treating the wood by further penetration
due to the longer contact period between the wood and the preservative.
Soaking (Steeping). Soaking involves immersing wood in an unheated oil solution
(commonly a pentachlorophenol formulation) for periods ranging from two days to one
week. The wood must be well-conditioned, i.e., dry, to achieve maximum absorption
of the preservative. The effectiveness of treatment by soaking depends on the type of
wood and on the product being treated. It is also possible to soak wood in water-based
solutions for several days or even weeks at ambient temperature. This process is also
referred to as steeping.
Thermal Process. The thermal process involves the immersion of conditioned wood in
successive baths of hot and cool preservative. Each stage typically takes 8 to 48 hours,
depending on the ambient temperature and the water content of the wood. The hot
baths expand the outer layers of the timbers and evaporate moisture through the surface
of the wood. The cold bath causes the air and vapor in the outer shell of the wood to
contract, thereby forming a partial vacuum. Atmospheric pressure then forces the
surrounding preservative into the wood. Creosote and pentachlorophenol formulations
are generally used in the thermal process; however, inorganic formulations have been
used.
Dripping
After application of the preservative, the wood is moved to a drip pad. Drip pads are used to collect
excess preservative that drips from the treated wood. Plants that do not have surfaced drip-pads
3-56 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
generally allow excess preservative to drip directly onto the ground. Most of the plants that have
surfaced drip pads reuse the collected drippage.
3.2.2.7 Sawmills and Planing Mills
The primary function of any sawmill is to convert a log or cant to usable end products. Sawmills
consist of a combination of basic operations including:1
(1) Mill feed
(2) Log washing
(3) Debarking
(4) Sawing
(5) Resawing
(6) Edging
(7) Trimming
(8) Lumber handling and stacking
(9) Lumber finishing.
Brief descriptions of these operations are discussed in the following paragraphs.
• Mill-Feed. Storing of logs is accomplished either on land or water. Front-end loaders
commonly are used to pick up land-stored logs and place diem on a ramp or deck equipped
with moving chains for transport into the mill. If the logs are stored on water (ponds),
flumes, chains, or belts carry the logs from the water to the mill.
• Log Washing and Debarking Operations. Log washing and debarking operations are
identical to those discussed in Sections 3.2.2.2 and 3.2.2.3 respectively.
• Sawing. Machinery utilized for the initial breakdown of logs to boards, dimensions, or
cants is termed the headrig. A headrig consists of feed works, the setworks, the carriage
and shotgun, die headsaw, chipper or chipper saw, and the controls associated with these.
The basic headrig consists of a single diesel- or electric-powered circular saw and a log
carriage. The carriage is a platform on wheels equipped with hydraulic or electric setworks
which hold the log as the carriage moves parallel to the saw. The chipper, located ahead of
the saw, squares the side of the log prior to sawing and converts the slab into chips.
• Resawing, Edging, and Trimming. Unit operations which follow the headrig are gang
sawing, resawing, edging, and trimming. The gang saw consists of an array of parallel
blades mounted in a frame which moves up and down as a log is propelled. The gang saw
reduces a cant to lumber of desired thickness. Resaws usually are vertical band saws and
are used to saw thick boards into thinner ones. .Edgers vary widely in capacity and size but
usually consist of one stationary circular saw and one or more circular saws that can be
moved laterally on the arbor to permit ripping different widths. Trim saws are circular
saws used to square the ends of the lumber and to remove serious defects.
'All of these operations may or may not be utilized at a given facility.
3.57 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
• Lumber Handling. Following edging and trimming, the rough green lumber is sorted and
stacked. If the lumber is to be marketed green it then may be passed through a water-
,. . repellent bath, after which it is dried by either air-seasoning or kiln drying.
• Lumber Finishing. Often the dried lumber is planed to the desired smoothness. The
surfacing tools used are planer knives attached to a rotating cutterhead. The quality of
finish is a function of the number of knives, the rotations per minute of the cutterhead, the
feed rate of lumber through the planer, the precision of the tool, and the sharpness of the
knives.
After planing, the lumber may proceed through one or more of the following processes:
• Preservative dipping
• Staining
• End-coating
• Moisture-proofing.
Frequently sawmills in humid areas apply a surface protection to protect wood against sapstaining that
may occur during temporary lumber storage. While sapstain does not impact the structural integrity
of the wood, it does discolor the surface and may decrease the wood's value to buyers. To avoid
s
staining, many plants surface-coat lumber with chemicals using spraying or dipping techniques.
Planing mills may exist in combination with sawmills or may be independent mills buying from a
number of suppliers. It also should be emphasized that other operations may be present at a sawmill
or planing mill. The most common of these additional operations is edge- or end-jointing of lumber
in sawmills and millwork production in planing mills. Exhibits 3-18, 3-19, and 3-20 illustrate typical
process flow diagrams for rough green, band, and headrig sawmills respectively.
3.2.2.8 Finishing
In any timber products manufacturing process the final step, with the exception of packaging, is the
finishing operations. Finishing operations include sanding or planing, applications of liquid coatings,
or covering with various sheet materials. The type of finishing operation used and the method of
application depends on the type of panel and the desired properties of the finished product.
Application of liquid coatings can be achieved via spray coating, curtain coating, direct roll coating,
reverse roll coating, or knife coating. In an overlaying operation, the factory finishing of wood-based
panels involves various types of sheet materials bonded to the base panel by adhesive. The most
important types of overlaying materials are special plastic film, aluminum foil, and resin-impregnated
papers. On a smaller scale, other types of overlay operations are practiced, including overlaying of
hardboard and veneers onto particleboard panel substrates.
3.58 September 1994
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Guidelines for Pulp & Paper and Timber
Overview of the Industry
Exhibit 3-18. Process Flow Diagram of Rough Green Sawmill
MILL FEED
MECHANICAL DEBARKER
CIRCULAR HEADSAW
i
E06ER AND GANGSAW
1
TRIM SAW
I
GREEN CHAIN
1
SHIPPING
. Source: U.S. EPA. 1974a. Development document for proposed effluent limitations
guidelines and new source performance standards for the wet storage, sawmills, particleboard,
and insulation board segment of the timber products processing point source category. EPA
440/1-74/033. Washington DC.
3-59
September 1994
-------
Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
, -
Exhibit 3-19. Process Diagram of Typical Band Sawmill
j DRY STORAGE -^ p WET SIX
1.1
MECHANICAL DEBARKER |— *•
,
RAMD HFAn*iAVf — to-
4
VERTICAL RESAW | — *•
4
1 — ». EDGER |— *•
1
TRIM SAW
4
.- fipFFM run I
1 i
, ^ WATER
RESERVOIR
i
1 HOG CHIPPER
4
1 SHIPPING
] KILN DRYING 1 | AIR DRYING |
1 »[ ' PLANING MILL [*•—
1
1 SHIPPING 1
•
Source: U.S. EPA. 1974a. Development document for proposed effluent limitations
guidelines and new source performance standards for the wet storage, sawmills, particleboard,
and insulation board segment of the timber products processing point source category. EPA
440/1-74/033. Washington DC.
*
3-60
September 1994
-------
INFCCD
PEELER LOOS
INPCCP
SAW LOOS
•Y-PASS DECK
•ARKER
Cut-Off SAWS
PLVWOOO PLANT
PRELIMINARY BARK
PROCESS AND
COLLECTINO
I
Source: U.S. EPA. 1974a. Development document for proposed effluent limitations guidelines and new source performance
standards for the wet storage, sawmills, partideboard, and insulation board segment of the timber products processing point
source category. EPA-440/1-74-033. Washington DC.
3,
r
-------
Overview of tht Industry EIA Guidelines for Pulp & Paper and Timber
3.2.2.9 Particleboard
Wood residues are the primary raw materials used to produce particleboard; roundwood also is used
but to a much lesser extent. Presently, research is being conducted on the utilization of other raw
materials such as bark, wastepaper, and municipal solid waste from tree trimmings. Raw materials in
the particleboard manufacturing industry are transported to the plants by rail or truck and stored in
silos, covered sheds, or in the open until needed. Exhibit 3-21 shows a basic process flow diagram
for the manufacture of particleboard.
There are three basic steps in producing mat-formed particleboard:
(1) Particle Preparation
(2) Mat Formation
(3) Mat Consolidation.
Further, particle drying, additive blending, board cooling, and board finishing processes are
incorporated into these three primary operations.
• Particle Preparation. The equipment used for particleboard formation includes
hammermills, flakers, and mechanical and merino-mechanical refiners. Hammermills are
relatively simple machines with low cost wearing parts, which reduce the size of material
by a beating action. Flakers are particle formation machines which produce thin flat stock
for particleboard fabrication. This machine utilizes a series of knives to reduce roundwood
and residues to desirable particle sizes. The products from the mechanical refiners
generally are used as face stock. A thermo-mechanical disc refiner basically receives feed
material which has been subjected to steam pressure before entering the refiner.
• Classification. The classification of wood particles is primarily to remove particles of
undesired shape and size which could present problems during manufacture or which could
produce defects in the product. Another reason for classifying particles is to allow the use
of the finer particles to form the face of the board and the coarser particles to form the
core. Vibrating screens commonly are used for classification. The rejects which are too
large to pass through the screen are recycled back into the system for further reduction in
size. Unacceptable fines are discarded.
• Drying. Following the preparation process, particles are dried by heat to achieve a uniform
moisture content. The preferred moisture content of the particle at the drier exit usually is
between 5 and 15 percent. Fuels used in driers are gas, oil, wood residues, or a
combination of the above.
• Additive Blending. A critically important operation in terms of the quality of the bond of
the board is the application of additives. Two common resins used in manufacturing
particleboard are urea-formaldehyde and phenol-formaldehyde, although the former
accounts for about 90 percent of the resin usage in the United States. In addition'to resins,
a petroleum base wax often is added in blenders to the wood particles. A blender is used to
3-62 September 1994
-------
I
£
u>
WOOD
PINISHINt
Source: U.S. EPA. 1974a. Development document for proposed effluent limitations guidelines and new source performance
standards for the wet storage, sawmills, particleboard, and hardboard segment of the timber products processing point source
category. EPA-440/1-74-033. Washington DC.
i
2,
9
I
-------
Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
blend wood particles and additives in the production of particleboard. Blenders are of two
types: (1) a continuous type consists of a horizontal trough with mixing arms and sprayers.
. : Wood particles are fed into the trough while additives are blended in by means of spray
nozzles; and (2) a batch type consists of a mixing tank with agitation in which the particles
and additives are blended. The blending process simply agitates the particles while
uniformly spraying the additives over the wood. The formation of a uniform mat of
particles is the prime objective in particleboard manufacturing. A lack of such uniformity
will result hi physical property variation and an increased potential for warping.
• Pressing. Particleboard mat pressing is accomplished either by multi-opening hydraulic
presses, single opening hydraulic presses, or, occasionally, a continuous press. The
operating pressure of the presses depends upon the type of resin used in the process.
Pressures as high as 69 atmospheres (1,000 psi) and temperatures as high as 132°C to
204°C (270° to 4,000°F) commonly are utilized.
• Extruded Particleboard. Raw materials hi this process consist of dry wood with a large
proportion of furniture manufacturing scrap. Particle preparation primarily is accomplished
by hammermills. After preparation and classification, the wood particles are coated with
resin and wax. The coated particles then are forced through a heated dye by hydraulic
rams, the board emerges in a continuous strip, and is cut to size.
3.2.2.10 Insulation Board •
The principal raw materials used to produce insulation board include wood from a variety of softwood
and hardwood species, waste paper, minimal fiber, bagasse, and other fibrous material. Exhibit 3-22
shows the typical processes that characterize insulation board production. The principal types of
insulation board include: (1) building board, (2) insulating roof deck, (3) roof insulation, (4) ceiling
tile, (5) lay-in panels, (6) sheeting, and (7) acoustical insulation board. Plants utilizing wood may
receive it as roundwood, chips, or pulp. Roundwood usually is shipped to the plant by rail or truck
and stored hi a dry deck before use. The roundwood normally is debarked by drum or ring barkers
before use, although in some operations a percentage of bark is allowed in the board. The debarked
wood then may be chipped, in which case the processes are the same as for those plants using chips
exclusively. If groundwood is used, the logs normally are cut into 1.2 to 1.5 meter (4 to 5 feet)
sections either before or after debarking so that they can be fed into the groundwood machines.
Other key unit processes include:
c
• Refining Operations. Pulp preparation usually is accomplished by mechanical or thermo-
mechanical refining. Mechanical refiners consist of two discs between which the chips or
wood residues are passed. A thermo-refiner basically is the same as a disc refiner except
that the feed material is subjected to steam pressure. Pre-steaming softens the feed material
and thus makes refining easier; however, the yield may be reduced by up to 10 percent.
The longer the pretreatment and higher the pressure, the softer the wood becomes. After
the refining operation, the fibers produced are diluted with water to a consistency amenable
. to screening. Screening is done primarily to remove coarse fiber bundles, knots,.and
slivers. After screening, the fibers produced normally are sent to a decker or washer.
3.54 September 1994
-------
LOO
STORAGE
••
— ^
|
REFIMNa
^M
_-
•«
— «
CHIPPER
1
«OCK
— •
DECKER
«*
crap
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I
STOCK
^^m
J FORMINQ
— •
-
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Ji
MA
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omen
— ^
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I
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•ATOM
•Am our
se
re
Source: U.S. EPA. 1979b. Proposed development document for effluent limitations guidelines and new source performance
standards for the timber products processing point source category. EPA-440/l-79/023b.
-------
Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
• Decker Operations. Deckers are rotating wire-covered cylinders, usually with an internal
vacuum, into which the suspension of fibers in water is passed. The fibers are separated
and the water usually is recirculated into the system. The two primary reasons for washing
are to clean the pulp and to control consistency. Control of dissolved solids also is a factor
in some cases.
After the washing or decking operation, the pulp is reslurried in stages. The initial dilution
to approximately a 5 percent consistency usually is followed by dilutions to 3 percent and
finally, just prior to mat formation, a dilution to approximately 1.5 percent. This is done
to: (1) allow for accurate consistency controls and more efficient dispersion of additives;
and (2) reduce the required pump and storage capacities for the pulp. During the various
stages of dilution, additives also usually are added to the pulp suspension. These range
from 5 to 20 percent of the weight of the board depending on the product used. Additives
may include wax emulsion, paraffin, asphalt, starch, poly electrolytes, and aluminum sulfate.
The purpose of additives is to impart desired properties such as strength, dimensional
stability, and water absorption resistance to the board.
After passing through the series of storage and consistency controls, the pulp may pass
through a pump-through refiner directly ahead of the forming machine. The purpose of the
pump-through refiner is to disperse agglomerated fiber clumps and to shorten the fiber
bundles. The fibrous slurry, at approximately a 1.5 percent consistency, then is pumped
into a forming machine which removes water from the pump suspension to form the mat.
• Forming Operations. The two most common types of forming machines are the
fourdrinier and the cylinder machines. The fourdrinier machine is a papermaking machine
which utilizes the gravity dewatering of fibers through a wire screen. The stock is pumped
into the head box and on to a table with continuous traveling screen running over it. The
stock is spread evenly across the screen by special control devices. An interlaced fibrous
blanket (referred to as a mat) is then formed by allowing the dewatering of the stock
through the screen by gravity, assisted by a vacuum. The partially formed mat traveling on
the wire screen then passes through press rollers, sometimes with vacuum, for further
dewatering. ,
Cylinder machines are large rotating drum vacuum filters with screens. Stock is pumped
through a head box to a vat where a mat also is formed pnto the screen. In this case, the
mat is formed by use of a vacuum imposed on the ulterior of the rotating drum. Part of the
rotating drum is immersed into the stock solution. As water is forced through a screen, a
mat is formed when the section of the cylinder rotates beyond the water level in the tank
and the required amount of fiber is deposited on the screen. At this point, regardless of the
machine used, the mat leaves the forming screen and continues over a conveyer. The wet
mat then is cut to the desired width and length by a traveling saw which moves across the
mat on a bias.
After cutting, the mats are dried to a moisture content of 5 percent or less. Most dryers
now in use are gas- or oil-fired tunnel dryers. Mats are conveyed on rollers through the
tunnel with hot air circulated throughout. The dried board then goes through various
finishing operations, such as painting, asphalt coating, and embossing. Operations which
manufacture decorative products usually will have finishing operations which use water-base
paints containing such chemicals as inorganic pigments (e.g., clays, talc, carbonates) and
binders (e.g., starch, protein, PVA, PVAC, acrylics, urea formaldehyde resins, and
3-66 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
melamine formaldehyde resins). These coatings are applied in stages by .rollers, sprayers,
or brushes. The decorative tile then may be embossed, beveled, or cut to size depending on
the product desired.
Water used to process and transport the wood from the fiber preparation stage through mat
formation, referred to as process white water, accounts for more than 95 percent of a
plant's total wastewater discharge (excluding cooling water).
3.2.2.11 Furniture Manufacturing
Considerable variation occurs in the processes used in furniture manufacturing. The following
discussion is intended to provide a general overview of the operations which may be involved. All or
only some of these processes may be carried out at a given plant:
• Raw Materials Handling and Storage. The raw materials used to manufacture furniture
are lumber, veneer, plywood, hardboard, and particleboard. Lumber usually is stored in an
area protected from the weather until it is ready for kiln drying. A moisture content of
from 5 to 6 percent normally is maintained after kiln drying. Lumber may arrive at the
factory kiln-dried.
• Machining. The machining process consists of cutting the stock to the desired length,
width, and thickness. Prior to assembly, the stock is face-finished by means of routing,
boring, etc., and finally sanded on all faces that will be exposed on the finished product.
Defects such as knots are eliminated in machining.
• Wood Bending. Wood bending is achieved by a steam bending process. After the wood is
cut to the required size and length, it is placed in a steam chamber for about 30 minutes
depending on the species of wood and size. Next, metal bands are used to shape the wood
in hydraulic benders. The bend is secured by a metal strap and wood spacers are inserted
to hold the wood in the desired shape after pressure is released from the bender. Strapped
wood then is oven-dried and cooled at a controlled rate. Exhibit 3-23 illustrates the
interrelationships of the major prefinishing steps during the furniture manufacturing process.
• Assembly Operation. During the assembly process, the component parts that have been
fabricated are fastened together by the use of metal fasteners, wooden dowels, and/or glued
joints. The most common metal fasteners are nails, screws, and staples.
• Finishing Operations. The finishing operation is performed for beautification and
protection of the wood. Finishing consists typically of bleaching, staining, filling, sealing,
topcoat ing, and wood graining operations.
Frequently, spray booths are utilized to spray on finishing materials. There are two types
of spray booths—dry booth and w,ater-wash spray booth. The finishing materials also may
be applied by brush or roller. Exhibit 3-24 illustrates the sequence of events during the
finishing process for furniture manufacturing.
3-67 September 1994
-------
u>
oo
SP
•a
|*M*»»U | Q iV«* J
t
1 M«»«M j
|»»«iti»In| . |
1 !••••• iiitt t— i
, . 1 . '
I r^ U I
1 tvttiiitM ' Ituftiit t»l 1 •iitvr 1 " 1 T
| I'll [ r |iiii | | mm | 1
1 », . * .» ' — T '
1 J.I »lt«»l»«tl» 1 1 1
I r_.T. . _T.T | J MI.....MW | | "
1 I , n«irn«*MnM
.1.1. 1
- '
• riiiAiu^
COMPOSITION
BOARD
\
(•••• | jg<
?
CM
-. &
P 9
1 »•!;<•' «• j 1 €»ft«l t« 1 g_
(.,.. .r. , ,.
*
,,..,*^
i
IMMMIM .1 , li*m«*li*«
I 1
1 PUHNITUMt 1
M ASSEMBtr 1*
Source: U.S. EPA. 1974b. Development document for proposed effluent limitations guidelines and new source p
standards for the wood furniture and fixture manufacturing segment of the timber products processing point source
EPA-440/l-74/033a. Washington DC.
1 3
9l%l««l«C 1 a
5
- 1
I
erformance 3'
category.
-------
EIA Guidelines for Pulp & Paper and Timber
Overview of the Industry
Exhibit 3-24. Furniture Manufacturing Process Diagram— Finishing
I ASSEMBLY
*-
FINISHING OPERATIONS
.
?
•H *
(BLEACHING • SAP STAINING I 1 BARRIER COATS 1
SPRAY BOOTH SPRAY BOOTH 1 1 SPRAY BOOTH 1
I
_.f ,," .
STAINING
SPRAY BOOTH
4
I WASH COATING
SPRAY BOOTH
. 1
* 1 I—
WOOD FILLING
SPRAY BOOTH
1 J
SPRAY BOOTH
* -
TOPCOATING
SPRAY BOOTH
U 4
| RUBBING a POLISHING |
. *
I PACKING 8 SHIPPING 1
Source: U.S. EPA. 1974b. Development document for proposed effluent limitations
guidelines and new source performance standards for the wood furniture and fixture
manufacturing segment of the timber products processing point source category.
EPA^40/l-74-033a. Washington DC.
3-69
September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
3.3 PROCESS WASTES ' . - .; .
3.3.1. PULP AND PAPER
All pulp and papermaking processes require the use of water. However, water use, wastewater
sources, and wastewater characteristics for any mill are dependent upon the combination of raw.
material and processes used, and the products manufactured. The pulp and paper industry is the
largest industrial process water user in the United States. However, water use in the industry has
decreased approximately 30 percent since 1975, reflecting significant effort by the industry to reduce
consumption and increase wastewater reuse and recycle. Approximately 16 million cubic meters (m3)
of wastewater are discharged daily by pulp, paper, and paperboard manufacturers in the United
States. Approximately 84 percent of this volume is discharged directly, and 16 percent is discharged
indirectly. Exhibit 3-25 shows the total industry water use and wastewater discharge by process area.
Paper and paperboard making discharges the greatest volume of wastewater in the pulp, paper, and
paperboard industry. Bleaching and pulping operations also contribute major wastewater flows,
although not all mills have pulping and bleaching operations. Exhibit 3-26 includes the average
production flow discharged to treatment by process area and the new proposed subcategory. This
section describes water use, and the generation of effluents, air emissions, and solid wastes from the
manufacture of pulp, paper, and paperboard.
3.3.1.1 Wastewater
Wood Preparation
Approximately 2 percent of the wastewater discharged by the industry is generated from wood
preparation processes. Exhibit 3-27 presents average wastewater generation rates, from the
preparation of wood, for the new effluent limitations subcategories. Wastewater generation rates
range from 0.5 to 19.2 mVOMMT. Mills that manufacture dissolving grade products use more water
in wood preparation than mills that manufacture papergrade products. This is largely due to hydraulic
debarking (U.S.EPA, 1993).
Pulp mills that use logs as raw material may use water for three purposes to prepare wood for
pulping: log conveyance, log washing, and wet debarking. Log washing removes dirt and silt from
the log that will abrade debarking equipment. Wet debarking typically is accomplished by wet drum
barkers or hydraulic barkers. Untreated woodyard effluents, from facilities using wet debarking, can
be expected in the magnitude shown in Exhibit 3-28.
3.70 September 1994
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EIA Guidelines for Pulp & Paper and Timber
Overview of the Industry
J
Exhibit 3-25. Approximate Percentage of Total Industry Water Use and Wastewater
Discharged by Process Area
::;v:v':>^;.'':3?Pi»cess':3Area-:<:v';.- 'V £
Wood Preparation
Pulping
Chemical Recovery
Bleaching
Pulp Drying
Power Operation
Secondary Fiber Processing
Pulp Handling
Paper/Paperboard Making
Broke Processing and Storage
TOTAL
^::;:,tEDiaw«iwlfce
3%
15%
8%
13%
1%
8%
• 5%
7%
41%
1%
100%
Total Wastewater Discharged to
Treatment
2%
16%
9%
.21%
1%
6%
4%
4%
37%
<1%
100%
Source: U.S. Environmental Protection Agency, Office of Water. Development Document for Proposed
Effluent Limitations Guidelines and Standards for the Pulp, Paper and Paperboard Point Source
Category. October 1993. EPA-821-R-93-019.
Pulping
Water use and sources of wastewater for pulping vary according to the specific type of pulping
process used. Water use and wastewater sources are described in greater detail below for chemical
pulping, mechanical pulping, and secondary fiber processing.
Chemical Pulping
In all types of chemical pulping, wood chips are cooked in a digester in an aqueous chemical solution,
at elevated temperature and pressure. Water is used as solvent for cooking chemicals, as the pulp
cooking medium, as pulp wash water, and as a diluent for screening, cleaning, and subsequent pulp
processing. Sources of wastewater at mills using chemical pulping include digester relief and blow
condensates, wastewater from the screen room, cleaners, deckers, and spills (U.S. EPA, 1993).
Commonly practiced water conservation measures include reusing screen room, cleaner, or decker
filtrates for pulp washing. These measures reduce makeup water requirements and wastewater
pollutant loads. In addition, energy efficiency is unproved because more pulping chemicals and
dissolved wood components are captured in the chemical recovery system. Approximately 15 to 20
percent of the wastewater discharged by chemical pulping mills is generated from the pulping process.
3-71
September 1994
-------
U)
C/3
n
•s
Process Area
Wood Preparation
Pulping
Chemical Recovery
Bleaching
Pulp Drying
Power Operation
Secondary Fiber Processing
"Pulp Handling
Paper/Paperboard Making
Broke Processing and Storage
TOTAL
Production Normalized Flow Discharged to Treatment (mVOMMT of final product)
Dissolving
Kraft
7.2(5%)
28.0 (19%)
12.4 (8%)
68.7(46%)
13.8 (9%)
7.2 (5%)
—
—
11.9(8%)
0.3 (<1%)
149.5
(100%)
Dissolving
Sulfite
19.2 (9%)
29.8(14%)
18.1 (9%)
113.4(53%)
2.2(1%)
21.1 (10%)
—
—
8.5 (4%)
212.3
(100%)
Bleached
Papergrade
Kraft and
Soda
1.8(2%)
16.4(18%)
8.8 (10%)
27.3 (30%)
2.8 (3%)
5.7 (6%)
—
4.9 (5%)
23.2 (25%)
0.8 (<.!%)
91.6(100%)
Papergrade
Sulfite
3.1 (2%)
34.3 (18%)
10.4 (5%)
65.8 (35%)
7.1 (4%)
12.0 (6%)
—
3.4 (2%)
53.7 (28%)
—
189.7
(100%)
Unbleache
0.5(1%)
7.5 (1%)
4.2 (9%)
*—
—
7.6(16%)
1.6 (3%)
9.7 (20%)
17.5 (36%)
—
48.6
(100%)
Non-Wood
Chemical
—
31.9(8%)
12.8 (3%)
13.7 (3%)
—
9.9 (2%)
—
4.3(1%)
329.2 (82%)
—
401.8(100%)
"•„
R-
w
fe
•
*
n
1
*i
• Ifi*
5,8'
i»
V 1-1
B i
!&
?!
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S 0
*< BS'
8.
5*
H
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-------
Process Area
Wood Preparation
Pulping
Chemical Recovery
Bleaching
Pulp Drying
Power Operation
Secondary Fiber Processing
Pulp Handling
Paper/Paperboard Making
Broke Processing and Storage
TOTAL
Production Normalized Flow Discharged to Treatment (mVOMMT of final product)
Semi-
Chemical
1.3 (6%)
1.6(7%)
2.5 (8%)
—
—
2.1 (10%)
0.3(1%)
0.8 (4%)
12.9 (60%)
—
21.5 (100%)
Mechanical
5.2 (9%)
10.3 (17%)
—
2.9 (5%)
•
2.8 (5%)
—
6.0 (10%)
30.9 (52%)
1.0 (2%)
59.1 (100%)
Secondary
Fiber
Deink
—
—
—
3.2(4%)
—
1.6(2%)
40.3 (50%)
5.4(7%)
30.0(37%)
—
80.5 (100%)
Secondary
Fiber
Non-Deink
—
.
—
—
2.0 (6%)
8.9 (27%)
—
21.7(65%)
0.7 (2%)
33.3 (100%)
Fine and
Lightweight
Paper.
—
—
—
—
—
9.7(9%)
—
8.9 (8%)
64.2(61%)
23.3 (22%)
106.0
(100%)
Tissue, Filter,
Nonwoven,
and
Paperboard
—
—
—
•
—
8.1 (9%)
—
4.2 (5%)
60,2 (66%)
18.2 (20%)
90.6 (100%)
g:
K>
e\
cr£
Si
i ?
ri
ft
£«
If
*&
i?
^
|e
SLJi
Note: In normalizing production flow, EPA used off-machine metric tons (OMMT) of production (including additives and coatings, at -*-
-------
Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-27. Wastewater Generation Rate from Wood Preparation .by
Proposed NPDES Subcategory (m3/OMMT)
Subcategory
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical Pulping
Average Wastewater
Generation Rate from Wood
Preparation (m3/OMMT)
7.2
1.8
0.5
19.2
3.1
1.3
5.2
Source: U.S. Environmental Protection Agency, Office of Water. Development Document for
Proposed Effluent Limitations Guidelines and Standards for the Pulp, Paper and Paperboard
Point Source Category. October 1993. EPA-821-R-93-019.
Exhibit 3-28. Woodyard Effluents During Wet Barking Operations
Woodyard Operation
Debarking:
Flow, kl/kgg (kgal/ton)
BOD,, kl/kgg (Ib/ton)
Log Chip Wash:
Flow, kl/kgg (kgal/ton)
BOD5, kl/kgg (Ib/ton)
Flume/Pond:
Flow, kl/kgg (kgal/ton)
BOD5, kl/kgg (Ib/ton)
Type of Pulping
Groundwood
15.4 (3.7)
2.55 (5.1)
1.7 (0.4)
0.3 (0.6)
3.3 (0.8)
0.4(0.8) •
Papergrade |
Kraft, Soda,
Sulfite
30.8(7.4)
5.1 (10.2)
3.4 (0.8)
0.6(1.2)
6.6(1.6)
0.8(1.6)
Dissolving Pulp
42.5 (10.2)
7.0 (14.0)
4.6(1.1)
0.9(1.7)
9.2 (2.2)
1.1(2.2)
Source: U.S. Environmental Protection Agency. Development Document for Effluent
Limitations Guidelines and New Source Performance Standards for the Bleached Kraft.
Groundwood, Sulfite, Soda, Deinked, and Non-Integrated Paper Mills of Pulp, Paper, and
Paperboard Mills Point Source Category. 1976. EPA 440/1-76/047-b. .
3-74
September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
Exhibit 3-29 shows the wastewater generation rates from chemical pulping for the new effluent
limitation subcategories (U.S. EPA, 1993).
Below is a brief discussion on the process wastes generated from kraft, sulfite, neutral sulfite semi-
chemical, and unbleached kraft/NSSC pulping.
Exhibit 3-29. Wastewater Generation Rate from Chemical Pulping
Proposed NPDES Subcategory (mVOMMT)
Average Wastewater
_ . . Generation Rate from
Subcategory Chemical
Pulping (nrVOMMT)
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Non-Wood Chemical
28.0
16.4
7.5
29.8
34.3
3-1.9
Source: U.S. Environmental Protection Agency, Office of Water. Development Document for
Proposed Effluent Limitations Guidelines and Standards for the Pulp, Paper and Paperboard
Point Source Category. October 1993. EPA-821-R-93-019.
Kraft Pulping
The major sources of wastewater from the kraft pulping process are digester and evaporator
condensates, pulp washing and chemical recovery. Pollutants include suspended solids, dissolved
organics, electrolytes, and inorganic compounds attached to the organic compounds. The biological
degradable organics include fatty acids, methanol, ethanol, turpenes, acetone, and other cellulose
decomposition products. This accounts for most of the BOD5 in kraft mill effluent. Lignins and
tannins, the nondegradable organic component, are responsible for a large part of the color. Color is
especially troublesome in bleach kraft operations because bleaching extracts these color bodies.
Chlorides are also a major pollutant contributed by bleaching.
Sulfite Pulping
The quantity and quality of effluent from sulfite pulping operations are influenced by woodyard
operations, pulp washing and recovery of spent liquor, condenser type, type of cooking liquor, and
presence of bleaching chemicals. TSS levels are secondary to BOD concentrations in untreated sulfite
effluents. The solubles present include lignosulfonates, lower fatty acids, alcohols, ketones, wood
3.75 September 1994
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Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
sugars, and many other complex compounds. In mills using the dissolving sulfite generated a strong
effluent to the point where over 60 percent of the wood becomes waste.
Neutral Sulfite Semi-Chemical Pulping (NSSC)
Raw waste loads from NSSC mills depends largely on the base used (sodium or ammonia), the
presence of chemical recovery systems, and on the amount of waste paper added to the furnish. The
effects of furnish and waste paper on liquor handling type for sodium base NSSC effluents are
illustrated hi Exhibit 3-30.
J
J
Exhibit 3-30. The Effects of Furnish and Waste Liquor Handling on Sodium Base NSSC
Effluents _
Liquor
Handling
Spray
Irrigation
Evaporation
and
Incineration
Flow
kl/kkg
44.6
48.8
t
kgal/to
n
1.07
11.7
Waste
Paper
Furnish
%
33
6
33
27-37
17-21
BOD5
kl/kkg
8.5
31
35
24
31
Ib/ton
17
62
70
48
62
TSS
kl/kkg
8.5
17.5
Ib/ton
17
35
Source: U.S. Environmental Protection Agency. Development Document for Effluent
Limitations Guidelines and New Source Performance Standards for the Bleached Kraft,
Groundwood, Sulfite, Soda, Deinked, and Non-Integrated Paper Mills of Pulp, Paper, and
Paperboard Mills Point Source Category. 1976. EPA 440/1-76/047-b.
Wastewater characteristics from sodium and ammonia base mills are similar except for the nitrogen
content of ammonia base effluents.
Unbleached Kraft/NSSC (with cross recovery)
In combined unbleached kraft/NSSC operations, if the ratio of NSSC production to kraft production
does not exceed 3:1, the BOD and TSS component of the kraft effluent is not expected to increase
more than 10 percent. The NSSC contribution to the combined effluent does not settle as well as
kraft effluent because of the higher load of fines. Hardwood pulps used in the NSSC mill may
contribute more color to the combined mill effluent than the softwoods used in the kraft mill
(Wapora, 1979).
3-76
September 1994
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EIA Guidelines for Pulp & Paper and Timber
Overview of the Industry
Mechanical Pulping
In all mechanical pulping processes water is used as a coolant, as a carrier of sluice pulp from the
body of the grinder, and as a diluent for subsequent pulp screening and cleaning steps. In refiner
mechanical pulping, water is used to wash the chips before refining. Approximately 17 percent of the
wastewater discharged by mechanical pulping mills is generated from pulping processes. Pulping
wastewater is generated at a typical rate of 10.3 mVOMMT of final product (U.S. EPA, 1993).
All types of mechanical pulping operations contribute suspended solids and dissolved organic matter
to wastewater effluents. There is no discernable relationship between TSS effluent concentration and
the subsequent pulp screening and cleaning steps. In refiner mechanical pulping, water is used to
wash the chips before refining. Approximately 17 percent of the wastewater discharged by
mechanical pulping mills is generated from pulping processes. Pulping wastewater is generated at a
typical rate of 10.3 mVOMMT of final product (U.S. EPA, 1993).
All types of mechanical pulping operations contribute suspended solids and dissolved organic matter
to wastewater effluents. There is no discernable relationship between TSS effluent concentration and
the several groundwood processes. In addition, chemi-groundwood and cold soda pulping operations
also contribute electrolytes from residual and spent chemicals to wastewater effluents. The dissolved
organic materials in groundwood effluents consist of wood sugars and cellulose degradation products
and resinous substances. The ranges of BOD5 loads in the raw effluents from various groundwood
processes are shown in Exhibit 3-31. Processes involving the use of chemical conditioning agents
show higher BOD5 values (Wapora, 1979).
Sour
Umi
Groi
Papt
Exhibit 3-31. Range of BOD5 Loads in Effluents of Groundwood Processes
Type of Pulp
Stone
Refiner
Chemi-groundwood
Cold Soda
BOD5
kg/kkg
4.0-9.5
9.0-16.0
34.5-40.5
36.5-50.5
Ib/ton
8-19
18-32
69-81
73-101
ce: U.S. Environmental Protection Agency. 1976. Development Document for Effluent
tations Guidelines and New Source Performance Standards for the Bleached Kraft,
indwood, Sulfite, Soda, Deinked, and Non-Integrated Paper Mills of the Pulp, Paper, and
'.rboard Mills Point Source Category. EPA 440/1-76/047-b.
3-77
September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
Secondary Fiber Processing
The first step in secondary fiber pulping is to solubilize the furnish in water. When deinking is not
necessary, the contaminants are removed by physically means (sedimentation, flotation, and
filtration). When deinking is required surfactant chemicals such as detergents, dispersants, and
foaming agents are added to help the physical separation of ink particles from the fiber. The
wastewater is treated to remove or concentrate the contaminants. Recovered process water is reused
in the repulping process. Excess water is discharged. Approximately 30 to 50 percent of the
wastewater discharged by secondary fiber mills is generated from the secondary fiber processing.
Wastewater generation rates are typically 8.9 mVOMMT of the final product for non-deink mills and
40.3 MVOMMT for deinking mills (U.S. EPA, 1993).
/
The raw waste load is generated in the stock preparation area and is mainly a function of the type of
raw materials and additives used. Typically, the higher the percentage of kraft or NSSC wastepaper
used in the furnish, the higher the BOD5 value per ton of product. Mills whose wastes have higher
BODS values also include those that employ an asphalt dispersion system in the stock preparation
process. The dispersion system is used to melt and disperse the asphalt found in corrugated waste
paper (Wapora, 1979).
Chemical Recovery
Water use and sources of wastewater for chemical recovery vary according to the specific type of
chemical recovery operations performed. At kraft mills, pulping liquors are washed from the brown
stock pulp and recycled to the chemical recovery system. The pulp wash water is concentrated in
multistage evaporators. Condensate from the evaporators is the excess water from liquor
concentration. Evaporator condensates are frequently reused in other mill processes. Excess
condensate is discharged for treatment. Condensates may contain high concentrations of TRS,
methanol, and acetone or they may be relatively clean and suitable for reuse in several hot water
applications including pulp washings. This all depends on where the condensates are drawn off the
evaporator set. Foul condensates may be reused after steam stripping to remove TRS, methanol, and
acetone (U.S. EPA, 1993).
Water is also used to wash the solid precipitates formed during the recovery of kraft pulping
chemicals. Washing recovers sodium- and sulfur-containing compounds from green liquor dregs and
lime mud. This weak wash is reused to dissolve recovery furnace smelt and as a scrubbing medium
in air emission control scrubbers. Excess weak wash water is discharged for treatment (U.S. EPA,
1993).
Pulping chemical recovery is not as frequent at sulfite mills as at kraft mills. However, sulfite pulp
wash (weak red liquor) is evaporated, generating an evaporator condensate wastewater which is
3.73 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
frequently reused in other mill process. Excess condensate is discharged to wastewater treatment.
Concentrated red liquor is burned to recover heat, sulfur, or both sulfur and base. Magnesium sulfite
mills use water to wash and slake the ash formed during the burning of red liquor. The wash water is
discharged for treatment. Calcium- and sodium-base weak liquors may also be processed to recover
by-products such as lignin chemicals, yeast, and alcohol. Since a recovery system is not used,
recovery wastewaters are not generated (U.S. EPA, 1993).
Approximately five to 12 percent of the wastewater discharged by chemical pulping mills is generated
from chemical recovery. Wastewater generation rates range from 2.5 mVOMMT of final production
for semi-chemical mills to 18.1 m3/OMMT for dissolving sulfite mills (U.S. EPA, 1993).
Bleaching
Pulp bleaching is a multistage process that uses different chemicals and conditions in each stage.
Washing is performed between the stages to remove bleaching chemicals and any dissolved wood
components extracted during bleaching. Chlorine-containing compounds (chlorine, chlorine dioxide,
and hypochlorites) are the most widely used bleaching chemicals. Secondary water uses include
preparation of bleach chemical solutions and in air emission control scrubbers. The high chloride
content of bleaching wastewaters makes them incompatible with pulping chemical recovery processes
so they are discharged to wastewater treatment. Therefore, elimination of chloride from the bleaching
process will enable increased recovery of bleaching wastewaters (U.S. EPA, 1993).
Approximately 30 to 50 percent of the wastewater discharged by bleaching chemical pulp mills is
generated from the bleaching processes. Wastewater generation rates range from 13.7 mVOMMT of
final production to 113.4 mVOMMT for dissolving sulfite (U.S. EPA, 1993).
Deinking
The major sources of effluent from the deinking process are the washers and centrifugal cleaners.
The major pollutants include BOD5 and settleable and dispersed solids. Organic pollutants include
adhesives, products of hydrolysis, and lost fibers. Inorganic pollutants include mineral fillers, ink
pigments, materials separated from the fiber in wastepaper, and chemicals used in the process. The
chemicals are dissolved electrolytes, mostly sodium salts, and detergents, which add to the total solids
and foaming propensities of receiving waters (Wapora, 1979).
Pulp Handling and Papermaking
In preparation of papermaking, pulp is suspended in water and mechanically conditioned in beaters or
continuous refiners. Chemical additives are added either before or after beating and refining. The
pulp is further diluted with water and then transported to the paper machine. Water that drains from
the wet end of the paper machine is known as white water, and is largely captured and recycled to the
,••
3.79 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
paper machine, woodyards, mill utilities, brown stock washers, and bleach line washers. Excess
white water is discharged for treatment (U.S. EPA, 1993).
Approximately 40 percent of the wastewater discharged by the industry is generated from pulp
handling and papermaking processes. Wastewater generation rates for paper/paperboard making
range from 8.5 mVOMMT of final production for pulp produced at dissolving sulfite mills to 329.2
nrVOMMT for paper or pulp made by nonwood chemical pulp mills (U.S. EPA, 1993).
s
The predominant wastewater discharges from papermaking include: excess white water from seal pits
or other tank overflows; rejects from stock cleaning devices (centrifugal cleaners, screens, and junk
traps); felt and wire cleaning waters; spills, washups, and discharge of tank dregs; cooling water
discharges; and boiler blowdown and other miscellaneous discharges (Wapora, 1979).
The primary source of BOD5 in papermaking wastewaters is the organic raw material. Cellulose,
rosin sizings, and starch or protein adhesives contribute to BOD5 loadings, as do many special organic
chemicals such as wet strength resins. Some or all these constituents, including cellulose fibers, are
in the solid or precipitated state, and therefore also contribute to TSS loadings. Fillers and coating
pigments such as clay and titanium dioxide are responsible for virtually no BOD}, but add to TSS
loadings (Wapora, 1979).
3.3.1.2 Pulp and Paper (Air Emissions)
EPA is in the process of developing national emission standards for hazardous air pollutants for the
pulp and paper industry pursuant to Section 112(d) of the Clean Air Act, as amended in 1990.
Historically, odor and paniculate emissions from pulp and paper mills, particularly kraft mills, have
received considerable attention due to the wide area of influence from these emissions. Exhibit 3-32
presents typical vent and wastewater stream characteristics for kraft pulping emission points. Typical
uncontrolled emission factors for kraft pulping facilities are presented as Exhibit 3-33. A major
source of emissions from pulp mills is from operation of the plant or specific processes at overload or
upset conditions. As described earlier, primary pollutants of concern from pulp and paper mills
include particulates, TRS compounds, SO2, NO,, and volatile organics. Unless otherwise stated, the
discussion that follows focuses on kraft mills, with discussions of other types of mills provided where
appropriate.
Particulates
Paniculate emissions at pulp and paper mills are generated primarily from the boilers and furnaces.
At kraft mills, this is principally from the kraft recovery furnace (fine paniculate soda fumes) and hog
fuel and coal-fired boilers (fly ash). The lime kiln and smelt dissolving tank vent are also significant
sources of paniculate emissions. Particulates include sodium sulfite and sodium carbonate from the
3-80 September 1994
-------
oo
I
Emission Point
Batch Digester Blow Gas
Continuous Digester Blow Gas
Digester Relief Gas
Knotter Hood (Vibratory Screens)
Washer
Washer Seal and Foam Tank
Decker/Screen
Oxygen Delignification Blow Tank
Oxygen Delignification Washer and Seal
Tank
Evaporator/Hotwell
Condensate Stripper
Turpentine Condenser
Tall Oil Reactor
Weak Black Liquor/Storage Tank
Digester Blow Condensates
Turpentine Decanter Underflow
Evaporator Condensates
Minimum
Capacity -
(ADT/day)
94
94
94
94
65
65
65
498
498
65
94
94
65
65
94
94
65
Maximum
Capacity
(ADt/day) :
1800
1800
1800
1800
1625
1625
1625
1300
1300
1625
1800
1800
1625
1625
1800
1800
1625
Average
Capacity
(ADT/day)
720
720
720
720
650
650
720
930
930
650
720
720
720
650
720
720
650
Flow rate
(scmm/Mg pulp/day)
1.3
0.026
0.0026
0.9
0.9
0.18
0.9
0.026
0.18
0.0027
0.0027
0.00257
0.000069-0.00763
0.00274
0.69-1.4
0.11
4.2-4.9
Temp
CO
82.5
112.5
42.5
30
32.5
65
NA
NA
NA
112.5
112.5
42.5
40
NA
40
40
40
Moisture
Content
(%)
30-99
35-70
3-20
NA
2-10
15-35
NA
NA
NA
50-90
NA
NA
NA
NA
NA
NA
NA
Heat
Content
(Kj/son)
70
6
18,400
20
40
20
0.2
150
50
21.300
NA
18,800
210
2,000
NA
NA
NA
ADT = Air dried short tons per day.
Source: U.S. Environmental Protection Agency, Office of Air Quality. Pulp, Paper, and Paperboard Industry - Background Information for Proposed Air Emission
Standards, Manufacturing Processes at Kraft, Sulfite, Soda, and Semi-Chemical Mills. October 1993. EPA-453/R-93-050a.
g
V
£
**5
0 B.
Jl
& S
Zi
T3 CaU
TO ^
fii S-
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oo
to
I
; Emission Point
Batch Digester Blow Gas
Continuous Digester
Blow Gas
Digester Relief Gas
Knotter Hood (Vibratory
Screen)
Washer
Washer Seal and Foam
Tank
Decker/Screen
Oxygen Delignification
Blow Tank
Oxygen Delignification
Washer and Seal Tank
Evaporator/Horwell
Condensate Stripper
Turpentine Condenser
Tall Oil Reactor
Weak Black Liquor
Storage Tank
Digester Blow
Condensates
Turpentine Decanter
Underflow
Evaporator Condensates
Evaporator Surface
•Condenser Condensates
Total HAP
0.1
0.00035-0.00039
0.004
0.1-0.6
0.026-0.35
0.2
0.003-0.005
0.019-0.050
0.24
0.002-0.02
NA
0.004
NA
0.043-0.15
0.10=0.62
0.51
0.17-3.04
0.039-0.63
Total VQC
2.4-4.4
4-4.9
2.6-2.7
0.8-2.6
1.8-3.4
1.6-5.8
0.01-0.023
0.14
0.41
3.1-5.4
NA
4.1
0.006
0.069-0.15
0.34-1.20
0.97
0.17-3.04
0.11-0.71
::: Methanol
0.0062-0.091
0.00024-0.0003
0.003
0.02-0.03
0.0022-0.15
0.18-0.19
0.002-0.003
0.005-0.05
0.076
0.0014-0.02
NA
0.003
NA
0.043-0.1
0.1-0.59
0.5
0.15r3.0
0.31-0.62
Acetone
0.0015
0.00004-0.0002
0.00006
0.005-0.007
0.0005-0.033
0.01-0.04
0.005-0.007
0.001
0.073
0.000007-0.002
NA
0.0001
NA
0.0005-0.01
0.0012-0.0043
0.004
0.0039-0.01
0.0025-0.001
TRS -
2.37-4.02
2.4-4.0
2.6-2.7
NA
1.4-2.1
0.22
NA
NA
NA
3.5
NA
2.7
0.10
NA
0.33
0.07
0.52
0.26
All emission factors are in units of Kg/Mg.
HAP = Hazardous Air Pollutants •
VOC = Volatile Organic Compounds
TRS = Total Reduced Sulfur
Source: U.S. Environmental Protection Agency, Office of Air Quality. Pulp, Paper, and Paperboard Industry - Background Information for Proposed Air Emission
Standards. Manufacturing Processes at Kraft. Sulfite. Soda, and Semi-Chemical Mills. October 1993. EPA-453/R-93-050a.
S
£
u>
•
1
i.
I
»**
g
?
i
?
|
*i'
- ai
8
9
9
I
£
•o
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i
-------
EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
recovery boiler and sodium chloride where wood has been soaked in sea water (i.e,-, during transport
or storage). Calcium and sodium salts of carbonate, hydroxide, sulfate, and chloride are emitted
from the smelt-dissolving tank and the lime kiln. Fugitive paniculate emissions may also occur from
coal piles, paved and unpaved roads, bulk material handling (lime, limestone, starch, etc.) and wood
handling.
Paniculate emissions from acid sulfite pulp mills result only from spent sulfite liquor combustion.
Ammonia-based sulfite liquors produce less particulates than magnesium- or sodium-based liquors as a
result of the ammonia breaking down to nitrogen and water and becoming nonrecoverable.
i
Particulate emissions from NSSC pulp mills are only a concern where recovery furnaces are involved
(i.e., for mixed kraft and semi-chemical spent liquors), with emissions similar to kraft mill furnaces.
Another technique for NSSC pulping liquor disposal is the use of a non-kraft furnace, where liquor is
smelted into Na2CO3 and Na2S. Paniculate Na2SO4 is generated, similar to the kraft process.
Approximately 2 pounds of paniculate per ton of pulp is generated.
Mechanical pulping and paper and paperboard manufacturing produce no paniculate emissions.
Sulfur Oxides
Sulfur oxides are a minor problem at kraft mills. Recovery and power boilers generate small
quantities of SO2, but the concentrations are typically below the "nuisance level." Sulfur dioxide
emissions at kraft mills occur primarily from the recovery furnace flue gases. Hydrogen sulfide and
sulfur dioxide are of greatest concern for the new low-odor boilers. Concentration of SO2 in the
gases depends on (1) sulfidity, heat value, and solids content of the liquor, (2) combustion air and
liquor firing patterns, (3) and furnace design and operation. The SO2 emissions can be reduced by
lowering liquor sulfidity and optimizing liquor and combustion air properties and firing patterns to
improve furnace efficiency and maximize the temperature. Excess air exceeding 25 percent in the
recovery boiler can cause the formation of SO3 which makes particulates sticky and difficult to
remove. Sulfur dioxide and sulfur trioxide may also be formed in the lime kiln when fuel oil is
burned, although the lime acts as a scrubber to remove the SO2 forming CaSO3 and CaSO4. Often, a
venturi scrubber follows the lime kiln to further enhance SO2 removal. The SO2 emissions from
power boilers are a function of the sulfur content of the fuel and use of low-sulfur fuel is the only
current method of control for boilers of the size used at pulp and paper mills. Minimal levels of SO2
are also emitted from the smelt dissolving tank.
Sulfur oxides are the major pollutant of concern in sulfite mill emissions, although, with an odor
threshold of about 1,000 times that of TRS, odor problems at sulfite mills are much less than at kraft
mills. The digester, blow tank, and absorption towers used in producing the acidic cooling'liquor by
reacting SO2 with the desired base are the three major SO2 sources. The amount of SO2 emitted from
3.83 September 1994
-------
Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
the absorption tower will depend on the design and operation of the tower. Relief gases from the
digester and noncondensible gases from the presteaming vessel and flash evaporators are typically
returned to the acid-preparation system for SO2 recovery. Lowering digester pressure to as low as 3
psi before the blow, or pumping instead of blowing out the contents, will reduce SO2 emissions.
Spent sulfite liquor is evaporated similar to kraft liquors, making S02 emissions a problem during this
process as well. Spent cooking liquor is often collected and recovered for financial reasons, but also
has the benefit of reducing air emissions. Total SO2 emissions from acid sulfite mills may be on the
order of 200 or more pounds per ton of pulp.
Milder pulping conditions and the absence of sodium sulfide from the pulping liquor allow the NSSC
pulping process to generate fewer emissions than kraft or other chemical pulping techniques. The
primary source of SO2 in NSSC mills is from digester blows. Other sources include the SO2
absorber, blow pits, spent liquor evaporators and the fluidized bed reactor or recovery furnace.
Recovery of NSSC pulping liquor in a furnace generates SO2 emissions that are slightly higher than
those from black liquor. Approximately 12-40 pounds per ton of pulp is emitted, with variation
dependent upon the recovery process. These emissions can be minimized by maintaining a proper
ratio of sodium to sulfur in the liquor.
Nitrogen Oxides
Historically, nitrogen oxides (NO,) have been of little concern to pulp and paper mills; however, with
the known impact on the atmosphere, proper operation of boilers and kilns (i.e., minimum flame
temperature and limited excess air) is needed to avoid costly external controls. The NO, emissions at
kraft mills are generated primarily in recovery furnaces and lime kilns as a result of black liquor and
fossil fuel combustion, respectively. Recovery furnace emissions result from partial oxidation of
nitrogen in the black liquor. Typically, temperatures in recovery furnaces are not high enough to
form large amounts of NOX, but with the current trend being to burn black liquor with higher solids
content and at higher temperatures, NOX emissions from this source will increase. Temperatures
above 1300°C with oxygen content above 2 percent will generate considerable quantities of NO,.
Reduced Sulfur Compounds
The characteristic odor of kraft mills is a result of total reduced sulfur (TRS) compounds, the
byproduct of reactions of wood lignin and cellulose with the sulfite ions in kraft pulping liquors,
primarily due to four TRS compounds: hydrogen sulfide (rotten egg smell with an odor threshold of
approximately 1 ppb), methyl mercaptan (rotten cabbage smell with an approximate odor threshold of
1 ppb), dimethyl sulfide and dimethyl disulfide (both with a vegetable sulfide smell and an
approximate odor threshold of 10 ppb). Major sources of TRS are digester blow and relief gases,
multiple effect evaporator noncondensibles, and recovery furnace exhaust gases. The recovery
furnace is the largest source of TRS at kraft mills, although elimination of direct contact evaporation
3-84 September 1994
-------
EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
significantly reduces air emissions. New low-odor boilers generate hydrogen sulfide and sulfur
dioxide gases rather than TRS. Vent gases from the evaporator are condensed using direct contact
condensers or surface condensers, the latter being more desirable because much less water is used.
Often multiple condensers are used, whereby the initial condensation is suitable for reuse in the mill
and later condensates are sent to wastewater treatment. Brown stock washer and seal tank vents,
liquor storage vents, smelt dissolving tank vents, lime kiln vents, black liquor oxidation exhaust, and
slaker exhaust also contribute measurable quantities of TRS emissions. Recently, oxidation and
aeration lagoons have also been identified as TRS emission sources.
Acid sulfite mills do not generate TRS compounds during the lignin bisulfite reaction, except where
sodium-based sulfite pulping liquors are used. At these mills, some TRS emissions may occur.
The NSSC pulp mills produce TRS emissions in the liquor recovery furnace that are slightly higher
than those from kraft black liquor recovery.
Other Pollutants
Volatile organic compounds (VOCs), such as alcohols (methanol), terpenes, fatty and resin acids,
phenols, and acetone, are released primarily in non-condensible gases (NCGs) from digester relief and
spent liquor evaporation. VOCs have odors but act more to enhance TRS odors, acting as TRS
carriers, than to produce independent odors.
Some of the hazardous air pollutants, as defined in the Clean Air Act Amendments of 1990,
associated with process emissions from pulp and paper mills include:
• 1,4-Dichlorobenzene
• 2,4,5-Trichlorophenol
• 2-Butanone (MEK)
• Acetaldehyde
• Acetophenone
• Acrolein
• Carbon disulfide
• Carbon tetrachloride
• Chlorine
• Chloroform
• Formaldehyde
• Hexane
• Hydrochloric acid
• Methanol
• Methyl chloroform
+
3-85 September 1994
-------
Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
•• Methylene chloride
• Propionaldehyde
••'•• Toluene
Mechanical pulping and paper and paperboard manufacturing generate significant quantities of steam
and water vapor. V0(5s are emitted along with the steam from mechanical pulping and range from
about 1 pound of VOCs per ton of pulp from western white wood species to over 7 pounds of VOCs
per ton of pulp for southern pine. VOCs are expected to be present in small concentrations from
papermaking activities including pollutants such as formaldehyde and phenol (used in resins),
ammonia (added as a coating or for pH adjustment), chemicals such as hexane, xylene, naphtha, or
s
toluene (used to clean the equipment), and other additives (e.g., defoamers, pitch control agents,
bleach plant chemicals, etc).
Chlorine and chlorine dioxide emissions are generated in the bleaching process. Also, chloroform is
formed during bleaching, with about half of the chloroform generated released to the bleach plant
vents.
Lime kiln and recovery furnace flue gases contain small quantities of polynuclear aromatic
hydrocarbons (PAHs), some of which are known to be carcinogenic, although there is little data
readily available.
3.3.2 TIMBER PRODUCTS PROCESSING
3.3.2.1 Log Storage
The water pollution problem associated with log storage is one that is common to all phases of the
timber products processing industry. Pollution primarily occurs as a result of (1) leaching of soluble
organics from the bark and wood; and (2) loss of bark during water storage. Wet storage practices
where logs are stored hi ponds or waterways are more likely to impact water quality. However, wet
decking, the practice of spraying water over log piles, can cause similar impacts.
Leachate generally consists of tannic acid, wood sugar nutrients, and lignins. Leaching increases
where there is a high content of bark and actively circulating water. Tannin and lignins impart a
yellowish-brown color to water. The quality of organics released to surface waters depends on the
amount of bark adhering to the log, the species of wood, the surface area of the exposed log, and the
circulation of the water. The typical composition of leachates from logs in water storage is presented
in Exhibit 3-34.
3-86 September 1994
-------
oo
Log Sample
Designation
Douglas Fir
Segment 1
(50 yr old)
Segment 2
(50 yr old)
Segment 3
(120 yr old)
Ponderosa
Pine
Hemlock
*BOD and
Special Submerged
Conditions Area, HJ
w/bark 6.29
w/o bark 9.04
w/bark 7.00
w/o bark 9-30
w/bark 5.28
w/o bark 7.50
w/bark
w/o bark
w/bark 5.55
w/o bark 8.51
COD 25 mg/l In holding
BOD COD
mg/l* g/ft2 mg/l*
54 0.9 193
34 0.9 287
84 1.3 272
120 1.2 313
6 O.I 53
42 0.6 142
42 0.8 284
92 1.4 185
15 0.3 101
79 0.9 174
water (26 litres).
g/ft2
3.2
3.2
3.9
3.4
1.0
1.9
4.2
2.8
1.8
2.0
BOO: COD Wood Sugar Acute Toxlcity
g/ft2 Test Fish** Degree
N
lOt VIII In 60t
0.2ft 0.4l chlnook after 72 hr
6.29 0.41 salmon TLmg6 - 93t leachate
Urn . - 32t
0.31 0.66 chlnook TLmji- ~ 20*.
0.38 0.50 salmon Urn*" - 27*
TLm!»5 - 24J5
0.11 ' . 0.31 rainbow no kill - 96 hr
0.30 0.41 trout lOOt leachate
0.19 0.84 rainbow no kill - 96 hr
0.50 0.18 trout I00» leachate
0.15 0.23 chlnook no kill • 9* hr
0.45 0.18 salmon lOOt leachate
V
•
o
1
&r
o"
o
i
^
IT
&
??
i
5
£T
B-
B
**Test fish - 1 to 2 Inches long. . ^
Source:
Environmental Protection Service. 1977. Literature
technology In I lie wood
and timber processing
industry
review of wastcwiitcr i h.ir.irl i-r 1 st 1 1 ,m,l jh.n ,.|iu-nl
. KPS- J-WP-77-2. Tiir.iiii,,, C. iii.nl. i .
0
1
-------
Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
Higher concentrations of leachates are expected to accumulate in log ponds where the water
circulation is low and high volumes of wood are stored.
Repeated handling of logs during water storage results in the deposition of large amounts of bark.
The quantity of bark lost from a log depends on the species, size, handling technique time since cut in
the forest, and dumping procedure. Bark deposits undergo a lengthy decay process underwater during
which an oxygen demand is exerted on the water percolating through the water bed. During this
period, microbial activity results in leaching of organic compounds from the bark. The biochemical
oxygen demand exerted on overhead waters as a result of bark biodegradation largely depends upon
the:
• Areal extent of the benthic layer
• Temperature of the water
• Chemical composition of the bark.
3.3.2.2 Log Washing
The practice of log washing may or may not be common to all the timber products processing
subcategories. The method of washing, the amount of water used, and the resulting wastewater
characteristics will vary from mill to mill.
Log washing is used to remove debris and soil from the log surface; the total amount will vary
according to harvesting and storage techniques. The amount of water used for log washing ranges
from 400 1 per kkg (105 ga/ton) to 1,250 1/kkg (300 gal/ton). Chip water or the amount of water
used in chipping is similar to that for washing logs. Typically, log wash water will be low in COD
and solids. The COD values for the recycled systems indicate the possibility of a concentration
gradient which inhibits to a great extent further leaching from logs.
3.3.2.3 Debarking
The water used for debarking (hydraulic barking) purposes must be free of suspended solids to avoid
clogging nozzles. Only discharges from wet-barking pose a potential water quality impact, although
steam conditioning is sometimes used to facilitate dry debarking.
The total suspended solids content in the discharge from hydraulic barking ranges from 521 to 2,362
mg/1, while BOD values range between 56 and 250 mg/1. A comparison of effluent quality between
two types of wet-barking operations found that the BOD values typically are higher in drum barker
effluent compared to hydraulic barker effluents; however, there is no significant difference in the
amount of total suspended solids between the two debarking operations. The EID should present the
key physical and chemical characteristics of these process wastewater streams.
3-gg September 1994
-------
EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
3.3.2.4 Veneer and Plywood .•
Water usage in the veneer and plywood industry amounts to less than 3.15 I/sec (50 gpm) for a mill
producing 9.3 million m2/yr (100 million ftVyr). Exhibit 3-35 presents a qualitative overview of the
major processes, wastewater sources and wastewater characteristics associated with the veneer and
plywood industry. The major water usage is divided among the following four operations:
• Log conditioning
« Cleaning of veneer dryers
• Washing of the glue lines and glue tanks
• Cooling.
The source of wastewater during log conditioning is from the steam and hot water vats. Wastewater
from both vats contains leachates and wood particles. Log conditioning contributes the largest portion
of the total pollution load from a veneer mill. The detailed chemical characteristics of steam vat
discharge and hot-water steam discharge are shown in Exhibit 3-36. The magnitude of these waste
loads varies according to the size and number of vats.
Veneer dryers accumulate wood particles. Volatile hydrocarbons also will condense on the surface of
dryers to form an organic deposit called "pitch." To avoid excessive buildup of these substances,
dryers must be cleaned periodically. Wood particles can be removed either by flushing with water or
by blowing with ah". While some of the pitch can be scraped off, generally a high pH detergent is
used and then rinsed off with water. Owing to the nature of pollutants in dryer wash water (i.e.,
wood particles and pitch), wash water contributes a relatively small pollution load. For a typical mill,
dryer wash water is approximately 1,635 kg/day (3,600 Ib/day). (Typical waste loads from veneer
dryers and analysis of dryer wash water are given in Exhibits 3-37.
The main source of wastewater from a gluing operation results from washing of the glue spreaders
and mixing tanks. Exhibit 3-38 presents a list of typical ingredients for three categories of glue mixes
used in the veneer and plywood industry. The wastewater constituents from glue systems (wash
water) and accidental spills and leakages are particularly toxic. Exhibit 3-39 lists the results of
chemical analyses of typical mixtures of the different plywood glues, which are representative of the
wastewater characteristics for accidental spills and leakages.
The water associated with cooling operations is the residual water required to dissipate heat from the
air compressor as well as from machines such as the press and the lathe.
3-89 September 1994
-------
Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-35. Overview of Wastewater Generation and Characteristics for the Veneer and
Plywood Industry
BASK ptocnsnc
_ sootcr CTAMcmirrics
Ut StOTtt* Ut (toroi* Ut Scent*
- Poo4s - Pood - Luchoco
- Hoc Docklat - Ovorflov - tatk
• Dry aocklat - IMO<<
Ut OekortUt H*c Dohorklat (tat
Dot - tydruiUc - LOOCBICO*
- ta| (Pocket) . - Hood r
- OTOB
Dry - Cutuikood
U| rn»•< P«rtlcl«.
. Pboool-ronoldobfoo * - Sl«o («ro»- -
phowl-(on*ld*-
t. ote.
ClM UOO
^y^f^^d Proo* P&c Proo* Fit
- OBB* •• abov*
- lot
• Cold
- Cattlot
I. OK.
»Miei: bvtnoMaul mtoettM tairtu. !»»»• Ut««t«M «»l«» el «.t«.t.r
cbwMtuUtle ao« okuoHit ucMol^T «• «»• «~* «^ "•»•' »"c«»o«t
Uducry. «f»-J-«»-»»-J. tow«to.
3-90 September 1994
-------
EIA Guidelines for Pulp & Paper and Timber
Overview of the Industry
Exhibit 3-36. Characteristics of Steam Vat and Hot Water Steam Vat Raw Discharges
PU«t
•Unt
I^B^BB^BVBM
A
8
C
0*
E*
amamuvm m r*mgm*
000
88 TS
Turb. rbeool.
DH
470
3.11?
2.MO
1.499
1.294
476
8.310 2.430
4,005 —
8.670 i.080
3,435 2.202
3.312 2.429
1.668
917
2.940
86
370
389
107
74
$.370
5.4M)
2. Ml
2,536
991
450
24}
249
30
28
0.69
0.57
0.30
0.20
S6.8
16.5
39.)
1.87
4.73
5.70
14
0.171
1.9)
4.12
4.1-6.1
5.38
5.)
Characterlatica of tot Nicer eceaai vac ran diechargei.
ceo
OS
T*
».7W U.iOO 3.5JO
3,100 9.0M I.S70
326 I,»M I.JM
1.000
1.900 »,000 3D
2.S20
460
72
160 1,000
1,462 1.781
6.470
2,030
2.020
Turb.
too
Phenoli
•^•H^IB^
o.«o
KjId-N
26.4
2J.*
16.2
P" ,
5.*
3.8
6.9
4.5
unit* are In •*/! except turbidity ead pM — the mite tor tboae parae»tar> are JTU'i and negative
of the hydrogen lea concentration, respectively .
Source- USBPA 1974h Oavelonmnt docuMnt for effluent limitations guideline* and new aource
perforaance etandarda for the plvwtod. bardboard, and uood peraervlng aegwnt 01 the
tteber product, proceaalng point eource category loduatry. EPA-440/1-74-02)-a. Wa.h-
iogton DC.
3-91
September 1994
-------
Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-37. Analysis of Waste Loads Characteristic of Veneer Dryers
Plant BOD COP PS SS TS Phenol* Kjld-M T-F04-P
A 60.94 412 - 99.7 319 418 0.018 13.2 0.18
B 2.33 60.6 52.3 3.09 53.2 0.014 0.112 0.019
Hoc*: All unitf art In kilograms per Billion aquara aatara.
Source: USEPA. 1974h. Development document for effluent limitations guideline* and new source
performance standards for the plywood, hardboard, and wood preserving segment of the
timber producta processing point source category. EPA-440/l-74-023a. Washington DC.
3.3.2.5 Hardboard—Dry Process
Several processes in the dry process hardboard industry use water; however, no single dry process
hardboard mill uses water in all of the following processes (the applicant should indicate in the EID
specifically which processes use water and which do not):
• Log Washing
• Chip Washing
• Resin System
• Caul Washing
• Housekeeping.
The quantity of water used depends upon water employed in raw material handling and in-plant
processes, the recycle system utilized, specific housekeeping practices, and many other factors.
Exhibit 3-40 shows wastewater flows from 11 dry process hardboard mills.
Water is used to make up the resins which are added as binders for hardboard; hence water used in
the resin mix become part of the hardboard and is evaporated in the press.
3-92 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
Exhibit 3-38. Ingredients of Typical Protein, Phenolic, and Urea Glue Waste
Protein Clue far Interior Grade Plywood;
Water
Dried Blood
Soya FLour
Lime
Sodium Silicate
Caustic Soda
Foraaldehyde Doner for Thickening
Phenolic Clue for Exterior Grade Plywood
Vater
Furafil
Wheat Flour
Phenolic Formaldehyde Resin
Caustic Soda
Soda Ash
Prea Clue for Hardwood Plywood
Water
Befearner
Extender (Wheat Flour)
Urea Formaldehyde Resin
Source: USEPA. 1974h. Development document for effluent limitations guide-
lines and new source performance standards for the plywood, hsrdboard.
and wood preserving segment of the timber products processing point
source category. EPA-440/l-74-023a. Washington DC.
3.93 September 1994
-------
Analysis
And Units
COO,
mg/k«
BOO 5,
•g/kg
TOC,
mg/kj
Total Phosph'att,
mg/kg, as P
Total Kjeldahl Nitrogen,
mg/kg as N
Phenols,
mg/kg
Suspended Solids,
mg/kg
Dissolved Solids,
mg/kg
Total Solids,
mg/kg
Total Volatile
Suspended Solids, mg/kg
Total Volatile
Solids, ing/kg
.'Source: USEPA. I974h. Developue.it
for the plywood, hardboard,
Phenolic
Glue
32,650
—
8,800
6.0
60
25.7
15,250
15,250
19,850
4,200
8,600
document for effluent limitations
and wood preserving segment of the
Protein
Glue
8,850
MO'
2,600
IS
600
90.5
5,900
5,900
8,850
1,700
6,850
Urea
Glue
21,050
9,750
*,500
37.8
1,065
10,200
10,200
27,500
17,300
27,500
, g,
cr
X
SO
^ <
* Jo
I JL
* ff
te I
K»
H» j^
S &
&. "Si
^ o'
la
» 1.
^ o
ff
^
H
n
1-
?
guidol inus and new source performance st.iml.inls
timber products proc<
•ssnip point sourif « alrcor v
-------
EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
Exhibit 3-40. Dry Process Hardboard Wastewater Flow and Source
Mill
A
B
C
D**
B
F
C
H
I
j**
K
Log Chip Resin* Caul*
Hash Wash Hash Hash
0 0 0 0
0 00 570
00 38 110
YES 0 0 300
81,650 000
00 0 380
0 0 5,670 0
00 3 750
00 0 0
0 0 570 0
000 0
House- Cooling Hunidifi-
keeping* Hater cation
20,000 320,000 0
380 81,650 11,340
0 227,000 0
YES YES 0
YES 0
0 - 0
0 189,000 0
0 125,000 0
0 160.650 0
0 283.500 0
0+ 0
Mote: All flow* given in liters per day
* Actual Intermittent Flow Averaged Daily
** Total Vast*
Contained on Site
+ Cooling Hater Uaed For Boiler Makeup
3.95 September 1994
-------
Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
Minor wastewater streams can be expected from caul and press lathe wash water and .housekeeping.
The typical wastewater quantities from caul and press lathe processes range from 380 to 950 I/day
(100 to 250 gpd). Miscellaneous housekeeping wastewater streams range in quantity from 0 to less
than 1,500 I/day (400 gpd) for a typical mill.
3.3.2.6 Hardboard—Wet Process
The major sources of wastewater discharges from a wet process hardboard mill. Normally include
process waters from mat formation, pressing, and fiber washing. Other miscellaneous waste streams
include resin-system wash water, caul wash water, housekeeping water, and cooling water. The EID
also show the average volumes of wastewater discharges from their wet-process hardboard plant.
The wastewaters discharged from wet process hardboard mills typically have BOD concentrations
ranging from 700 mg/1 to 4,000 mg/1. Other analyses of raw wastewater discharged from a typical
wet-process hardboard mill are as follows (U.S. EPA, 1974h):
. >:. - '^-'';-;::::^:':-":;v;;¥;Parameter
BOD
COD
Suspended Solids
Total Dissolved Solids
Kjeldahl Nitrogen
Phosphate as P
Turbidity
Phenols
pH range
Concentration (mg/1)
1,300 to 4,000
2,600 to 12,000
400 to 1,100
500 to 4,000
0.17 to 4.0
0.3 to 3.0
80 to 700
0.7 to 1.0
4.0 to 5.0
The applicant should, to the extent possible, present the most accurate prediction of pollutant
concentrations (by parameters) in the EID.
3.3.2.7 Wood Preserving
The EID should identify the major wastewater streams associated with the wood preserving industry.
These usually are generated from the following major sources:
(1) Condensate from conditioning by steam
(2) Cooling water
(3) Rainwater runoff from process area
3-96 September 1994
-------
EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
(4) Steam condensate from heating coils
(5) Boiler blowdown water
(6) Vacuum water
(7) Washwater
(8) Water softener brine
(9) Non-pressure processes
(10) Leakages.
The most important source of wastewater, both hi terms of volume and level of contamination, is
cylinder condensate. The amount of wastewater from this source varies with the volume of green
stock and with the method of conditioning, whether steaming or boultonizing. With the exception of
single pass cooling water, conditioning water accounts for the largest volume. A typical wood-
preserving plant that uses steam conditioning produces wastewater amounting to approximately 15,000
gal/day, whereas a plant that uses boultonizing conditioning generates about 200 gal/day of
contaminated wastewater. Data from 18 boulton and 41 steaming plants showed average discharge
values of 6,785 and 7,375 gpd (25.6 and 27.9 m3/d), respectively. When only western boulton plants
were compared, the average discharge volumes were 3,425 and 3,215 gpd (13.06 and 12.2 m3/d),
respectively. Nationally, it is estimated that the average two-retort plant generates 8,000 gpd (30.3
m3/d) of wastewater, including 4,000 gpd (15.1 mVd) of contaminated rainwater"(U.S. EPA, 1979a).
Typical wastewater from creosote and pentachlorophenol treatments (where steam conditioning
generally is used) have high phenolic, COD, and oil contents and may have a turbid appearance
resulting from emulsified oil. Exhibit 3-41 shows the range of concentrations for selected wastewater
parameters after recovery of bulk oil. There also is a large volume of rainwater that falls on or in the
immediate vicinity of the retorts and storage tanks. Contaminated rainwater presents a treatment and
disposal problem at most plants, but can be especially troublesome for plants in areas of high rainfall.
It should be noted that treatment of wastewaters of wood-preserving plants using waterborne salt-type
preservatives and certain fire retardants results in waste streams that contain low organic content and
that also contain traces of heavy metals.
3.3.2.8 Sawmills
Sawmill water usage varies considerably, but is insignificant relative to other timber processing
operations. The variation in water usage is due to the fact that some sawmills produce their own
power, whereas others do not. Approximately 93% of the water used in the sawmill is for power
production, rather than for washing and sawing logs.
Cooling water for the saw is one source of water usage; however, no wastewater is produced.
Lubrication of chain belts and other conveyor systems is another use for water. Usually no
wastewater is generated, as the water is absorbed by bark or sawdust. Minor amounts of water are
3.97 September 1994
-------
Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-41. Analytical Data for Wastewaters From Creosote and Pentacbiorophenol
Treatments
Waste Parameterg
Total Phenolic Compounds
Pentachlorophenol
Chemical Oxygen Demand
Biochemical Oxygen Demand
Oil Content
Total Solids
Dissolved Solids
pH
Usual Range of
Concentrations
100-350
25-150
3,000-60,000
1.500-25,000
80-2,000
2,000-20,000
1,800-18,000
4.0-5.5
Average Concentration
for 24-Hour Composite
(Samples for Five
Plunrs)
137**
17,890**
8,732**
176
11,000
9,900
5.1**
* Units of measurement are mg/1 (ppm) for all parameters except pH.
** Each value is the average of from 125 to 250 .separate analyses.
Source: Environmental Protection Service. 1977. Literature review of waste-
water characteristics and abatement technology in the wood and timber
processing industry. EPS-3-WP-77-2. Toronto, Canada.
3-98
September 1994
-------
EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
used for surface protection processes aimed at presenting sapstain but no wastewate-r is generated.
Potential water quality impacts arise from spills and storm water contamination. The EID should
identify specific water uses at the proposed mills and determine the extent and nature of resultant
wastewater streams.
3.3.2.9 Finishing Operations
Water used in wood finishing operations primarily consists of solution make-up water and washwater
associated with the employment of water-soluble coatings and adhesives and in surface-cleaning
operations. The major source of wastewater in the finishing operation is from the washing of
equipment used for applying water-reducible coatings and water-soluble adhesives. Exhibit 3-42
presents the principal sources and volumes of wastewater generated from wood finishing plants.
Because both water and solvent-base coating materials are custom-formulated for each application,
extreme variations occur depending on the type of finished product produced, type of coatings
applied, and methods of application and drying used. Therefore no list of typical ingredients for
coating materials used in wood finishing is available, so an accurate characterization of the wastewater
is not possible.
3.3.2.10 Particleboard Manufacturing
The extent of water usage during the actual manufacture of particleboard is low. Water usage for raw
material handling is typical of that discussed elsewhere. The water within a typical plant may be used
for:
• Cleaning blenders
• Rinsing additive storage tanks
• Caul cooling sprays and mat sprays
• Fire suppression
• Cooling
• Scrubbing in connection with air emission control
• Other miscellaneous operations.
Wastewater from blender wash-up, additive storage wash-up, and press-pit operations are of most
concern. The total quantity of wastewater produced in a particleboard manufacturing plant may range
from less than 190 Ipd (50 gpd) to as much as 32,000 Ipd (8,500 gpd). Exhibit 3-43 presents
wastewater flow rates from particleboard manufacturing plants.
3.99 September 1994
-------
S
I
Plant
A
B
Annual Production Applicators of £?
Type of Finished of Finished Products Water-Reducible Volumes of E
Products Produced (Millions of Square Meters) Finishing Materials Wastewater Generated (liters S!
Preflnlshed Wall
Paneling and Vinyl
Overlaid Hardwood
Plywood
Preflnlshed Wall
Paneling
12 i Groove Striper 260 &
1 Adhesive Spreader
(Direct Roll) H
11 2 Filler Applicators i .360 i.
(fc verse Roll) c/>
2 Groove Stripers |
C
b
Preflnlshed Wall
Paneling
Preflnlshed Wall
Paneling
6 1 Grain Printer 75
(2 Rolls)
1
n
e
2 i Top Coater (Direct in a
tell) <
i Sealter Coater (Direct §•
E
r
6
H
Vinyl Overlaid
Hardboard Panels
Preflnlshed Wall
Paneling
Preflnlshed Wall
Paneling
Preflnlshed Wall
Paneling
Roll) ^
5" ft
4 i Adhesive Spreader 75 B *
(Direct Roll) * 2,
^i
11 i Sealer Coater (Direct iiO
Roll)
9 3 Sealer Coaters (Direct i70
Roll)
10 i Seller Coater (Direct 760
Roll)
1 Filler Coater (Reverse
1
§
1
i5
3
3
Roll) . a
o
J
Aluminum Overlaid
Softwood Plywood
Exterior Siding
•
1 Adhesive Spreader 450
2 Spray Booths
B
M
?
j«J ».
a
Source* USEPA. 197 Aa. Development document for proposed effluent limitations guidelines and new sourer
performance standards for the wet storage, sawmills, partlcleboard and insulation board segment
of the timber products processing point source category. EPA-MO/1-74-033. Washington DC.
nishino 1
9
1
2,
if
I
e
$
•O'
!»
?
1
I
f
-------
Guidelines for Pulp & Paper and Timber
Overview of the Industry
Exhibit 3-43. Estimated Flow Rates for Particleboard Plant Process and Cooling Water
Plant
Number
15
1
29
28
25
2
23
3
16
4
31
11
17
6
20
9
5
Production
(kkg/day)
8
18
54
136
136
140
261
272 1,
272
295
*L
297
317
317
336
356
363
363
Cooling
Wastevater Water Blender House- Press
Discharge Discharge Washout keeping Pit
(l/day> U7day) (I/day) (I/day) (I/day)
189 — 189 ~ —
— — __ —
— — 189 — — •
— 190,764 568 a_ — —
227 g 151,400 — 151 —
— 187,887 57 802 —
— 2,180,160 g_ — — —
097,650 £ 1,362,600 A — — 1,893 d
15,140 — _____
12.301 £ 55,658 d — 4.273 1.325
to ~" to
416,350 9,463
327,213 163,512 54,504 218.016 54,693
to
464,798
4,542 £ 654,048 189 76 —
— 545,040 d. — 1,893 £ —
— 11,335 1.325 — —
3,785 189.250 3,785 — —
— 10,901 £ 227 — —
to i
341
— 43,603 7,570 18,925 b —
Storage
Tank Wash
Waters
(I/day)
__
76 a
—
~
76
303
—
—
—
—
—
189
—
—
—
—
18,925 £
I/change
3-101
September 1994
-------
Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-43. Estimated Flow Rates for Particleboard Plant Process and Cooling Water
. . (Continued)
Waatevater
Plant Production Discharge
Number (kkg/day) (I/day)
Cooling Storage
Water Blender Bouse- Preas Tank Wash
Discharge Uashout keeping Pit Waters
(I/day) (I/day) U/day) (I/day) (I/day)
30
12
26
27
14
19
10
8
32
381
392
431
449
499
635
726
1,361
8,327
253,595
1,627,550
98,032 d.
2.180,160
2.180,160
1*771,380
— 21,953
7,570 —
757
— 2.839 c
— 454.200
Dry Clean — —
— 18,925 —
NOTE: No data available for plant numbers not listed.
£ once per week
jb once per 3-months
£ frequency varies
d, recycled
je includes blender wash
t_ scrubber effluent
£ estiaated
Source : USEPA. 1974a. Development document for proposed effluent limitations
guidelines and new source performance standards for the wet storage,
sawallls, particleboard and insulation board segments of the timber
products processing point source category. EPA-440/1-74/033. Washing-
ton DC.
3-102
September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
Blenders are used for applying additives (resins and waxes) uniformly over the furnish. Blenders
usually are cleaned with water, and sometimes by manual scraping followed by steaming action to
remove the remainder of the waste. Additive storage tanks also are cleaned occasionally to remove
residue. Other miscellaneous operations in particleboard mills that result in wastewater discharge
consist primarily of water and oil formed in the press pit from the leaking of the hydraulic system and
water used for general plant clean-up.
The composition of wastewater from blender washing normally consists of resin-dilution water as well
as wood particles. Urea resins have high nitrogen contents, whereas phenolic resins contain high
concentrations of phenols, which appear in the respective waste waters. The typical quantity of water
per wash is approximately 400 liters (100 gallons).
Waste streams generated from additive storage tank washing will contain various dilutions of
additives, resins, and waxes. Wastewater from wax-washing operations contains nitrogen or phenol,
depending on whether or not urea or phenolic resins are used. The amount of water used varies
significantly and can range from approximately 90 to 23,000 liters (20 to 6,000 gallons) per washing.
The waste streams generated by plant clean-up or waters pumped from the press pit vary widely in
degree of contamination. The plant clean-up wastewater normally will contain wood particles as well
as oils and resins. The waste streams from the press pit are composed of large amounts of fugitive
particles. Exhibit 3-44 presents an analysis for waste streams found in particleboard manufacturing
plants.
3.3.2.11 Insulation Board
The major source of waste water in insulation plants results from:
• Excess process white water
• Chip washing
• Dryer washing
• Finishing
• Air pollution control devices
• Handling and storage of raw materials.
The water used for chip washing usually is recycled to a large extent. There is no water discharge
from the dryer itself. However, occasionally it becomes necessary to clean the driers to prevent fire
danger and to maintain proper heat transfer. This dryer washwater waste amounts to about 11,000
liters (3,000 gallons) per week in most operations, but can vary somewhat depending on the
production levels. Plants that produce a coated product usually paint the board after it is sanded and
trimmed. Paint wash-up amounts to about 400 liters (100 gallons) of water per ton of product. To
control dust from trimming and sawing operations, wet scrubbers are used. The water that is fed into
3-103 • September 1994
-------
Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-44. Analysis of Major Wastewater Streams by Parameter for Various
: Partideboard Manufacturing Plants
PARAMETER
Plant No.
Flew (I/day)
pH (units)
Color (units)
Turbidity (JTU's)
BOD5*
COD
TS
SS
DS «,
ST.S
P04
Phenols
TN
KM
VS
P
•
TOC
SOURCE
Blender Wash
24
379
6.4
—
—
60
357
373
98
275
1
•1
—
0.75
—
18.3
—
' — ^
—
6
1325
7.0
433
5
31.500
9.523
4.385
1.650
2,735
„„
1.7
' —
1,340
—
—
^^
, i
—
Urea Resin
Tank Wash
4
1514
7.7
—
—
—'
—
—
—
. —
,,m
15
— '
. — .
—
—
^^
—
11
189
—
262
750
39.300
18,200
38.234
3,335
34,899
^-^
6.8
87.4
41,278
—
34.534
_ .
—
Press Pit
3
1893
7.4
—
—
500
13,200
5.638
155
5.483
__
—
35
—
52.2
5.079
3.14
—
5
95
7.3
—
—
150
414
697
/
225
472
1
—
0.005
—
64.5
—
1.85
148
NOTE: all parameters are mg/1 unless otherwise noted
Source: USEFA. 1974a. Development document for proposed effluent limitations
guidelines and new source performance standards for the wet storage.
sawmills, particleboard and insulation board segment of the timber
products processing point source category. EPA-440/1-74/033. Wash-
ington DC.'
3-104
September 1994
-------
EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
the scrubbers is sometimes excess process water. Other water use is for cooling, sealing in vacuum
pumps, screen washing, fire control, and general housekeeping. The miscellaneous water use
amounts to about 400 liters (100 gallons) per metric ton.
The major pollutants common to insulation board plant wastewater are leachates from the wood and
material added during the formation process. Process Whitewater accounts for over 95% of the
wasteload and flow from insulation board plants. This wastewater is characterized by high BOD,
COD, suspended solids, and dissolved solids. Raw material is the major source of dissolved and
suspended organic material. From 1 to 3% (on a dry-weight basis) of the wood is composed of
water-soluble sugars which enter the water to form a major source of BOD and COD. A significant
amount of BOD also results from additives.
Exhibit 3-45 presents wastewater characteristics by pollutant parameter for some insulation board
plants. ;
3.3.2.12 Wood Furniture and Fixture Production
The use of water in the furniture industry is highly variable primarily because its usage is not
required on a regular basis. The major sources of contaminated wastewater include water wash spray
booths, laundry facilities, and to some degree, the presence of glue applicators, which must be
cleaned. The volume of wastewater discharged depends on the size and number of water wash spray
booths and the number of loads of laundry washes per day. Exhibit 3-46 presents the wastewater
production for various furniture plants.
Other miscellaneous waste streams also should be identified and quantified in the EID. These result
from bleaching, bending, and air pollution control devices. The volume of wastewater resulting from
bleaching and bending operation amounts to about 570 liters/day (150 gpd). Wet scrubbers may
generate 8 to 40 liters (2 to 19 gallons) per minute.
The applicant should characterize in the EID the nature and quantity of major wastewater pollutants
associated with wood furniture and fixture production processes. The pollutants in the wastewater
discharged from spray booths largely is dependent on the amount and type of overspray material
captured by the water. Exhibit 3-47 presents results of chemical analyses on spray booth wastewater
containing various types of finishes after varying lengths of service. The pH, COD, and solids
concentrations (dissolved and nonvolatile) are high in the wastewater discharged from spray booth.
The high pH is due to the presence of alkaline agents in the water which are added to disperse the
finishing materials. Waterborne finishes are being developed that will offset the amount and nature of
waste waters.
3-105 September 1994
-------
Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-45. Characteristics of Wastewaters Produced by Various Insulation Board
Plants
Plant Production now BOO COO TS SS OS
No. KKo/dav 1/KKg Ka/KKq Kg/KKg Kg/KKq Kfl/KKo Ko/WCo
13
ni)
9
12(1)
«(A)
15 (1)
5(1)
17
4
11(3)
i
10(4)
14
3(J)
109
813
163
322
142
227
291
154
528
457
200
217
353
154
41.380
14.118
11.564
9.189
50.494
8,346
7,800
14,506
103.910
45.487
8.330
9.644
0.956
11.3 67.9 95.9 52.1 45.0
11.6 49.0 — 11.8 20.4
15.1 - - 14.1
15.1 20.3 - 4.2
27.5 — >- 14.5
32.3 62.5 48.1 11.7 36.3
33.7 72.4 - 3.0 8.0
33.7 ~ - 30.0
34.7 - - 24.7
35.2 181.8 278.9 235.0
39.0 94.5 93.9 10.5 83.4
40.9 - 98.2 25.7
44.6 88.7 ~ 52.3 -
valid data not available
1 Analysis taken after preliminary clarification
2 Forming machine production
3 Plant utilizes bagasse
4) Values do not represent present conditions due to experimental
changes In water systems
(5) Represents 70-90 percent of total load
Source: USEPA. 1974*. Developarat docuMot for proposed effluent limitation*
guidelines and am source performance standards for the wet storats.
sawmills. particlaboard and insulation board segment of the timber
products processing point source eatsgory. EPA-**0/ 1-74-033.
W«shinfton DC.
3-106
September 1994
-------
w
H-*
IP
•a
IB
1
H-
*
Plant
1
2
3
1,
5
6
7
8
9
10
11
12
13
1«»
15
Table 29.
Waatewater production data for
Weekly Spray tally Glue Dally Laundry
Booth Discharge Wash Discharge Discharge
(liter*) (liters) (liters)
6,250
11,700
—
—
5.700
_.
•
18,200
9,500
18,200
5,700
•
19,000
— —
—
75 COO
380
__
760 --
._
—
20 —
760 MOO
.
6.100 19.000
to -
190
—
380
various furniture plants.
Other Discharge A
(liters)
NA
Met scrubber dis-
charge 22,700/vk
Wood bending con-
Aenaate 170/
-------
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lll.ik* M.1H •».*•• ».'"• «*.•"* ^.X" 'I.*** **• '.«•» H > >*•*
)«.I4* 4I.OM I».M* II.M* M.im *.na *.BM in 111 ta.i >•«§
IJO~.>
01 <0 » 470
«>c«..t
01
<»clt
Q
I
i
r
-------
I
COO 800 TS TOS TSS TVS TVOS TVSS TOC TIC Color Phenol f. Co
11.470 I.S20 11.200 9.910 1.240 10.900 9.700 1.200 I.S47 1.300 7f (1 0.172
OltciMrae
ClM lirMfer 23.470
MtM«M
ClM tFr««dtr 41. MB
Mill
BltKh boot* 2.0BO
Uit scrubber 1.1 SO
7 4»i\
Net tcnibbor 1.190
21.000 17.100 1.700 10.500 K.900 3.(00 2.744 1.474 S.O 0 0.043
24.000 15.200 8.800 21.700 14.800 8.900 2.M8 1.517 4.4 8 0.1(7
90 24.UO 19.100 S.SOO 8.720 3.JOO S.420 10S 1.9S1 9.2 100 0.150
90 1.0*0 7S4 2M SBO 304 27( 18S 19$ (.8 12S
80 1.3(0 (35 72S 842 250 592 43( 2(0 7.( Ml
720 210 (71 S47 114 in MS 7 SM 12S 4.1 194 0.27(
MO/djy
22.700/««tk
3IO/d«y
I
Source: USEPA. I974b. Oevelopaent document for effluent li*it«tiona guidelines and npw source perfornance
•t«nd«rds for the Mood furniture and fixture Manufacturing segments of the timber processing point
source category. EPA-440/l-7*/033a. Washington DC.
-------
Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
For wastewater generated from the laundry facilities, high pH and concentrations of,-solids result from
the addition of soda ash, caustics, and clay to the wash water. These materials are used in
combination with strong detergents to clean the rags for wiping and rubbing furniture. The resulting
wastewater is highly pigmented and has high levels of COD and BOD. Glue and various other
miscellaneous wastewater characteristics are presented in Exhibit 3-47.
3.4 CONTROL TECHNOLOGIES
3.4.1 PULP AND PAPER
3.4.1.1 Pulp and Paper (Wastewater)
The Federal Water Pollution Control Act, as amended by the 1977 Clean Water Act and the 1987
Water Quality Act, does not require the use of specific treatment technologies. Instead, it leaves to
the discretion of individual mills the option as to how to meet the effluent limitations and NSPS
imposed. Effluent limitations are however, developed based upon the performance of specific
technologies. Mills may elect to achieve the required pollutant reduction with well-designed and well-
operated end-of-process controls or by a combination of both in-process and end-of-process controls
that may prove to be more cost effective. As presented earlier, in-process controls vary to a large
extent based on subcategories, but the end-of-process treatment technologies employed by the pulp
and paper industry are similar across the range of subcategories, employing both primary and
secondary treatment technologies. Unless noted, the discussion that follows is applicable to all
subcategories of the pulp and paper industry.
Major sources of wastewater at pulp and paper mills include:
• Wood handling/barking and chip washing
• Digester and evaporator condensates
• White waters from screening, cleaning, and thickening
• Bleach plant washer filtrates
• Paper machine white water
• Fiber and liquor spills
Notes: Hydraulic or wet drum debarking have significant TSS, BOD, and color problems. Recycling
this water can reduce load. Also, use of hot caustic extraction effluent from the bleach plant for this
process can further reduce overall volume of color as well as improve bark removal efficiency
(especially for frozen wood).
Pulp and paper mills have suspended solid levels and BOD levels comparable to municipal sewage,
making the wastewater treatment facilities comparable to that at publicly owned treatment works
(POTWs). Primary treatment consists of physical and chemical methods to remove solids, equalize
3-110 September 1994
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EIA Guidelines for Pulp & Paper and Timber
Overview of the Industry
and neutralize corrosive waste waters, and reduce color. At most pulp and paper mills, primary
treatment is followed by secondary treatment. Indirect dischargers (i.e., mills that discharge to
POTWs), often will not have secondary treatment, instead relying on the POTW to provide this
service. The most common types of secondary treatment used at mills include activated sludge,
aerated stabilization basins, and non-aerated stabilization basins. Often, mills will use both activated
sludge and stabilization to treat wastewater. Exhibit 3-48 presents a summary of wastewater treatment
systems in place at pulp and paper mills in the U.S. Following is a discussion of wastewater treatment
technologies commonly used at pulp and paper mills.
•
b
r
S
£
C
Exhibit 3-48. Summary of Primary and Biological Wastewater Treatment
Systems In Place at Pulp and Paper Mills
Discharge Status
Direct
Indirect
Non-discharging
Total
Type of Wastewater Treatment
Primary
Only
44
5
2
51
Activated:
Sludge
86
3
0
89
Basins
(Aerated and
Non-aerated)
154
10
2
166
Mixed
27
0
0
27
P«fr«-
5
0
0
5
Total
Number of
MfllsWhh
Wastewater
Treatment
316
18
4
338
Total
Number
of Mills
325
203
37
565
Mixed mills have both activated sludge and basin treatment.
Five mills with other types of treatment include four mills that have trickling filters and one that has a
Dialing biological contractor.
ource: U.S. Environmental Protection Agency, Office of Water. Development Document for Proposed
'ffluent Limitations Guidelines and Standards for the Pulp, Paper, and Paperboard Point Source
"Mtegory. October 1993. EPA-821-R-93-019.
Primary Treatment
Primary treatment typically precedes secondary treatment, although many mills do not need additional
secondary treatment to meet discharge requirements. Exhibit 3-49 presents a summary of primary
wastewater treatment in place at U.S. pulp and paper mills.
The first step in primary treatment is screening to remove bark or trash materials that could seriously
damage the treatment equipment. Two types of screens are most often used; bar screens (for coarse
materials) and fine gravity screens. Bar screening is the first treatment step and is used to remove
large solids from plugging subsequent treatment operations. Openings between bars is at least 1.5
cm, retaining solids such as wood chips, leaves, plastic, rags, and other debris. Few mills use fine
screens (e.g., microstrainers) to remove smaller solids because these devices are easily clogged by
3-111
September 1994
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Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-49. Sun
at Direct-E
Subcategory*
Dissolving Kraft
Bleached Papergrade
Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-chemical ,
Groundwood, Chcmi-
mechanical, Chemi-
thenno-mechanical
Non-wood Chemical
Pulp
Secondary Fiber Deink
Secondary Fiber Non-
deink
Fine and Lightweight
Papers from Purchased
Pulp
Tissue, Filter, Non-
Woven, and Paperboard
from Purchased Pulp
Total
unary of W
h'crhflrtrinp
astewater Treatment In Place
\lills, by Subcategory
Type of Wastewater Treatment
Primary
Only
0
1
0
0
1
0
0
0
1
7
8
26
44
Activated
Slodge
1
16
4
3
5
2
13
3
8
11
16
4
86
Basins
(Aerated
and Non-
aerated)
2
42
31
1
1
8
6
0
3
39
6
15
154
Mixed
0
9
3
1
0
1
0
0
5
0
5
3
27
Other
0
0
0
0
0
0
0
0
0
2
2
1
5
Total
3
68
38
5
7
11
19
3
16
59
37
49
316
* Mills were grouped into the subcategoiy that represented the largest percentage of their annual
production.
Source: U.S. Environmental Protection Agency, Office of Water. Development Document for Proposed
Effluent Limitations Guidelines and Standards for the Pulp, Paper, and Paperboard Point Source
Category. October 1993. EPA-821-R-93J019.
3-112
September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
mill wastewater, are expensive to maintain, and similar results can be achieved at lower cost using
clarification.
After large solids have been removed, some mills will remove sand and other inorganic particles
using grit removal systems to minimize abrasion of subsequent treatment equipment. Grit chambers
slow down the flow rate of the wastewater through treatment, allowing larger particles to settle out
and be removed. Suspended particles, however, can not be removed using this technology, regardless
of the length of time these particles are allowed to settle.
Suspended solids are removed from pulp and paper mill wastewater primarily through the use of
sedimentation. Removal of these solids prior to biological treatment significantly reduces the load and
load variability on the biological system, providing a less expensive and more efficient treatment
train. More than 90 percent of mills using activated sludge have some type of preceding
sedimentation process. Sedimentation is also the major treatment technique used at mills without
secondary treatment. Sedimentation equipment includes mechanical clarifiers and settling ponds using
chemically assisted clarification to promote sedimentation.
A mechanical clarifier is most often used in the industry at plants with biological treatment because
effluent from a mechanical clarifier produces a more uniform effluent that is less likely to impact
biological treatment operations due to load fluctuations common in raw mill wastewater. Where
biological treatment is not used, there does not appear to be any preference for the type of
sedimentation equipment used. Mechanical clarifiers may also follow activated sludge systems, where
biological solids are removed.
The typical mechanical clarifier is a circular, concrete structure, 3-4.5 meters deep, with a detention
time of 2-10 hours and an overflow rate of 2.5-15 nrVd/m2. Mills that do not use biological treatment
typically will have a longer detention time in the clarifier than mills without biological treatment.
Design of clarifiers must be based on pilot and laboratory testing rather than solely on theoretical
data. Settled sludge is removed from the clarifier using a rotating scraper on the floor of the clarifier
that maneuvers the concentrated sludge into the center hopper where it is pumped to sludge handling.
The floor of the clarifier is sloped towards the center (1:12 ratio) to promote sludge removal. Sludge
from the process is very conducive to incineration or landfilling.
Mechanical clarifiers can remove 80-90 percent of the suspended solids, 95-100 percent of the
settleable solids, and a portion of the biodegradable solids. Typically, clarifiers at paper mills will
remove more BOD than at integrated pulp and paper mills because paper mills tend to have less
soluble BOD. Clarified effluent from mechanical clarifiers is either discharged or routed to secondary
treatment.
3-113 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
(
Settling ponds are also used to remove suspended solids via sedimentation. At pulp-and paper mills,
settling ponds typically consist of unlined earthen basins, with detention times ranging from 12 hours
to several days. Settling ponds do not produce the consistent quality effluent that a mechanical
clarifier can produce, but will produce an effluent suitable for biological treatment. Settling ponds
are not widely used in the industry because of large land requirements and high cleaning costs.
To enhance sedimentation, many mills use flocculation to improve solids settling. Flocculation is a
process whereby chemical(s) are added to the wastewater with gentle agitation (either air mixing or
mechanical stirring) to generate floe. The most common chemicals used in the pulp and paper
industry to settle solids, in the order of usage frequency, are polymers, alum, lime, ferric and ferrous
sulfate, and others such as ferric chloride and calcium chloride. Mixing of the wastewater enhances
the contact of the floe with other particles and other floe, thereby increasing the size of the floe. As
the floe grows, it becomes heavier, getting to the point where it will settle out of the wastewater.
Flocculation is used more often at plants without biological treatment.
• Flotation clarification is another process used in the pulp and paper industry to remove
suspended solids (usually in lieu of biological treatment). In this process, fine gas bubbles
(air or pure oxygen) are introduced into the wastewater where the bubbles attach to the
solid particles, carrying the particles to the surface. Here, a skimmer collects and removes
the floating solids. Often, chemicals such as polymers, alum, or ferric chloride are used to
enhance solids removal. The most common flotation clarification procedure used in the
pulp and paper industry is dissolved air flotation (DAF), in which air is injected into
wastewater under pressure and as the pressure is reduced in the flotation tank, fine
supersaturated air bubbles are formed that carry the solids to the surface. Rotation
clarification is preferred over mechanical clarification techniques because of its ability to
remove extra fine particles, however energy and chemical costs have limited the usefulness
of this method except where space is limited or extremely tight effluent limitations exist.
• Equalization is used to minimize wastewater flow rate and pollutant concentration variability
to minimize the impact of these variations on treatment system performance. Treatment
systems operate at maximum efficiency where flow rate and pollutant concentration remain
constant. Flow equalization, with mixing, provides a stable wastewater flow and loading to
operations sensitive to variations. Equalization is used most often as a precursor to
activated sludge, primarily because of the microorganism's sensitivity to changing
conditions. At pulp and paper mills, equalization most often is conducted after
sedimentation and before biological treatment.
Similar to equalization, neutralization can be used to improve treatment system performance.
Biological treatment is most effective in the pH range of 6.5 to 7.5, less variable than the typical pulp
and paper mill raw wastewater pH that ranges from 5 to 9. As such, neutralization can be used to
reduce pH variability prior to biological treatment or for plants without biological treatment, prior to
discharge to the receiving stream.
3-114 September 1994
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EIA Guidelines for Pulp & Paper and Timber
Overview of the Industry
Secondary Treatment
The two most common types of secondary treatment in the pulp and paper industry are activated
sludge systems and stabilization basins (both aerated and non-aerated). As shown in Exhibit 3-50,
approximately twice as many mills use stabilization basins as activated sludge systems.
1
J
Exhibit 3-50. Summary of Primary Wastewater Treatment
In Place at Pulp and Paper Mills*
Primary
'Treatment
Screening
Grit Removal
Mechanical
Clarification
Flocculation
Settling Pond
Flotation
Clarifier
Equalization
Neutralization
Type of Wastewater Treatment at Mill
Primary
Only
18
3
21
22
8
15
6
17
Activated
Sludge
40
15
76
16
2
3
16
38
Basin
76
7
107
18
35
7
7
36
Mixed
14
3
25
3
2
1
1
12
Other
2
1
4
2
0
0
1
2
Total
150
29
233
61
47
26
31
105
1 Includes direct, indirect, and non-discharging mills.
Source: U.S. Environmental Protection Agency, Office of Water. Development, Document for Proposed
Affluent Limitations Guidelines and Standards for the Pulp, Paper, and Paperboard Point Source
Category. October 1993. EPA-821-R-93-019.
Activated sludge systems rely on the action of microorganisms in wastewater to oxidize
soluble and suspended organics to carbon dioxide and water in the presence of oxygen
(conducted in aeration basins). Some of the organic material is synthesized, producing new
cells or supporting existing cell growth. The excess comprises waste and excess sludge.
Effluent from the aeration basins flows to sedimentation basins (i.e., secondary clarifiers)
where excess sludge is removed from the bottom of the clarifier in a similar manner to
primary clarifiers. A fraction of the sludge from the secondary clarifiers is recycled back
to the aeration basin to maintain the level of suspended solids, known as mixed liquor
suspended solids (MLSS). Pulp and paper mills typically operate activated sludge aeration
basins at a MLSS concentration of 1,000-6,000 mg/1. The biggest advantage of activated
sludge systems over other types of secondary treatment is the high rate of biological
treatment provided in a relatively small space. The biggest disadvantage of activated sludge
3-115
September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
systems over basins is the high level of operation and maintenance required to achieve a
consistent high quality effluent.
Activated sludge systems are used by pulp and paper mills of all sizes and all subcategories. Most
aeration basins at pulp and paper mills are concrete with the remaining either lined or earthen.
Mechanical surface aerators, diffused air aerators, or mechanical submerged turbines supply air or
oxygen to the systems while also providing the necessary mixing. Approximately 1 kg of oxygen/kg
of BOD removed is supplied to these basins. Most mills also have to add nutrients (i.e., nitrogen and
phosphorus in the form of ammonia and phosphoric acid, respectively) to the aeration basins to allow
for adequate organism survival.
All pulp and paper mills with activated sludge systems use mechanical clarifiers for secondary
clarification. Design parameters for these clarifiers are similar to those for primary clarifiers except
that overflow rates may be twice that of the primaries. Occasionally, chemicals may be added to
improve settling in the secondary clarifiers.
Activated sludge systems achieve BOD removals of 80-90+ percent. The average effluent
concentration at mills using activated sludge systems is 33.7 mg/1 for BOD and 56.6 for TSS.
Approximately 13 percent of mills with activated sludge systems routinely achieve BOD
concentrations lower than 10 mg/1 while approximately 7 percent achieve TSS concentrations lower
than 10 mg/1. Activated sludge systems have been shown to be able to produce BOD and TSS
concentrations as low as 3.40 mg/1 and 6.90 mg/1, respectively. Activated sludge systems can be
upgraded by increasing the capacity of aeration basins (i.e., longer detention times and lower BODS-
to-microorganism ratios), by increasing the size of clarification, and by adding flocculent to improve
sludge settling.
Four types of activated sludge systems are used most often in the pulp and paper industry. These
include; conventional (plug-flow), extended aeration, high-rate aeration, and pure-oxygen aeration.
Other variations include complete-mix, oxidation ditch, step aeration, contact stabilization, and
reaeration. Types of activated sludge systems used by U.S. pulp and paper mills are presented in
Exhibit 3-51.
In conventional activated sludge systems, primary clarifier effluent and recycled activated sludge from
the secondary clarifiers are introduced into the aeration basin at the same point. Conventional
activated sludge systems are the most widely used, often the most versatile, and have a relatively low
initial cost.
About as many mills have extended aeration systems as have conventional activated sludge systems.
The basic difference with extended aeration systems is that the wastewater is retained in the aeration
basin for a sufficient period of time to allow the production of new cells to be the same as the decay
3-116 September 1994
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EIA Guidelines for Pulp & Paper and Timber
Overview of the Industry
Exhibit 3-51. Types of Activated Sludge Processes .
In Place at Pulp and Paper Mills
Process'
Conventional (5-18
hours)
Extended Aeration
(> 18 hours)
High Rate Aeration
(<5 hours)
Pure Oxygen Aeration
Other
Total'
Number of Activated
Sludge Mills
31
25
10
9
8
83
Number of Mixed
Mills"
7
8
i
6
0
0
21 .
Total
38
33
16
9
8
104
* The process used by each mill was determined from descriptions provided by mills in response to the
pulp and paper questionnaire. If no description was provided, detention time was used to identify the
process.
b Mixed mills have both.activated sludge and basin treatment.
c Some mills were not counted because they did not provide process descriptions or detention times and
some mills may use more than one process.
fi • /
Source: U.S. Environmental Protection Agency, Office of Water. Development Document for Proposed
Effluent Limitations Guidelines and Standards for the Pulp, Paper, and Paperboard Point Source
Category. October 1993. EPA-821-R-93-019.
rate of existing cells. As such, far less excess sludge is produced than with other activated sludge
systems (e.g., 25-75% less sludge than from conventional activated sludge systems).
»
Approximately one-fifth of activated sludge systems at paper mills use the high-rate process. This
process uses a relatively short detention time and high volumetric loading rate to the aeration basin.
These systems have not proven to be capable of producing low BOD concentrations consistently.
Pure oxygen systems use high-purity oxygen instead of air, effectively improving the efficiency of the
unit over a similarly sized air system. Typically, oxygen systems will operate at similar conditions to
that of high-rate systems. Oxygen systems are preferred where space is of greatest concern.
3-117
September 1994
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Overview of the Industry
EIA Guidelines for Pulp & Paper and Timber
Typical operating parameters for the four activated sludge systems described above are presented in
Exhibit 3-52.
;
Exhibit 3-52. Typical Operating Parameters for Activated Sludge
Systems In Place at Pulp and Paper Mills
Activated Sludge |
•':~ Process ": /• '„•„••.•••"
Conventional
Extended Aeration
High Rate Aeration
Pure Oxygen Aeration
Typical Detention
Tunes* (his)
4-8
>18
2-4
2-4
F/M Ratio*
0.2-0.4
0.05-0.15
0.4-1.5
0.25-1.0
MLSS Levels
Relative to
Conventional Process*
-
Lower
Higher
Higher
1 Values for each parameter were obtained from literature.
Source: U.S. Environmental Protection Agency, Office of Water. Development Document for Proposed
Effluent Limitations Guidelines and Standards for the Pulp, Paper, and Paperboard Point Source
Category. October 1991 EPA-821-R-93-019.
• Stabilization basins (or aerated and non-aerated lagoons) have longer detention times and
lower MLSS concentrations than activated sludge systems. Stabilization basins are the
preferred method of biological treatment, because of their ability to handle shock loads and
to produce a high quality effluent with minimal biological floe. Also, the level of TSS in
stabilization basins is low enough that secondary clarification is not needed. Historically,
aerated basins have been used much more than non-aerated basins; however, with the trend
towards water use reductions and more concentrated effluents, anaerobic systems are more
viable. One exception is that anaerobic systems produce hydrogen sulfide and methane,
limiting is usefulness at plants that use sulfur based pulping technologies.
Aerated stabilization basins are configured in two different ways. In one scenario, wastewater is
aerated as it enters the basins and then allowed to acquiesce in subsequent portions of the basin to
allow for solids settling. In the second configuration, wastewater is aerated throughout the entire
basin. Often, complete mix aeration basins are followed by non-aerated basins (i.e., polishing ponds)
to allow for solids settling. Polishing ponds also serve as equalization basins, muting any large
fluctuations that may otherwise occur. For the most part, polishing ponds serve only to settle out
solids; however, because biological solids still exist in the wastewater, biodegradation continues to
occur.
3-118
September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
Stabilization basins are typically earthen structures, only about 20 percent of which are lined, with a
depth of between 10 and 25 feet. Approximately 7 percent of mills with basins routinely achieve
BOD concentrations lower than 10 mg/1 while approximately 5 percent achieve TSS concentrations
lower than 10 mg/1. The effluent TSS concentrations achieved by basins are comparable to that of
activated sludge systems, while the BOD concentrations in basin effluent is slightly higher (i.e., 60.89
mg/1 for basins and 33.7 mg/1 for activated sludge systems). Basins have shown the ability to
produce effluent from mills with BOD and TSS concentrations as low as 3.0 and 2.0 mg/1,
respectively. Aerated stabilization basins can be upgraded by increasing the amount of aeration in
existing ponds, by increasing the volume of aerated ponds or by adding new ponds (i.e., increased
detention time), by adding nutrient supplements to the mill wastewater, and by providing additional
settling capacity for suspended solids removal.
Many mills will combine activated sludge systems and basins to treat mill effluent. These systems are
typically more efficient than either of the two systems operated independently, especially for reducing
BOD concentrations. Other biological treatment technologies used at a few mills include trickling
filters and rotating biological contactors (RBCs), both of which are fixed film type of reactors.
Trickling filters have not proven to be effective on pulp and paper wastes, achieving a maximum
BOD removal of about 50 percent. RBCs are a more effective method of biological treatment,
achieving BOD and TSS concentrations of 20 mg/1 each. One drawback to RBCs is the higher cost to
purchase, install, and operate these units. Granular filtration units are also effective for removing
suspended solids at pulp and paper mills, although these units are very expensive to operate and are
typically only used at smaller mills. Treatment techniques such as anaerobic digestion, land filtration,
comminution, oil skimming, and lamella separators have also been used at pulp and paper mills with
varied success.
Color Removal
Color removal technologies used in the pulp and paper mill can cost as much as 10 percent of the
value of the final pulp produced, explaining why color removal has not been a high priority in the
industry. Pulp mill effluent is brown in color, due to the lignin and tannin derivatives in the
wastewater. These compounds are slow to degrade, limiting the usefulness of biological treatment for
removal. In-plant changes are effective at reducing color loads, but not totally alleviating the
problem, especially for discharges into low flow receiving streams.
In response to concerns over colored effluent, numerous physicochemical methods have been
implemented to remove color, including:
• Lime precipitation or coagulation
• Lime and magnesium sulfate precipitation
• Alum coagulation or precipitation
3-119 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
• Polymer coagulation
• Membrane processes
• Activated carbon adsorption
• Rapid infiltration
• Enzyme pretreatment
• Ozone oxidation
• Ion exchange
• Aluminum oxide
• Wood shavings adsorption
• Polymeric adsorption
• Electrochemical treatment
• Amine treatment
• Precipitation with seawater
• Irradiation
• Ultrasonic oxidation
• MYCOR (i.e., biotreatment with white rot fungus)
Most of die color removal techniques identified above remove at least 90 percent of the color;
however, the high operating costs deters many facilities from installing color removal equipment.
Where color removal is used, lime coagulation is the most common approach. Lime addition, prior
to primary clarification helps to settle color panicles. The overflow from the clarifier is carbonated
using carbon dioxide from the kiln lime stack gas to precipitate residual soluble lime and color. The
effluent is again clarified. The lime sludge from the two clarifiers is thickened and reburned in the
lime kiln. Recently, coagulation processes have taken over as the preferred technology because of
improved color removal.
Membrane processes were originally investigated at pulp and paper mills for color removal; however,
the high costs prohibited widespan use. Fouling of the membranes represent the largest cost of the
systems, requiring frequent cleaning and membrane replacement. As a result of the increasing
concern with chlorinated compounds from mills and improved membrane technology, ultrafiltration
(UF) has found success as a treatment technique for raw alkaline stage filtrates for removal of high
molecular weight chlorinated lignins and resin acids. Since dioxins and furans may attach to high
molecular weight chlorinated lignins, a high rejection of dioxin and furans was anticipated. A
polysulfone membrane appears to have the most success for removal (at a pH of 10 to 11). Permeate
from the UF is then treated biologically with the UF concentrate incinerated. [Chlorinated organics
in the concentrate may cause problems when incinerated.] This technique is currently being
investigated for its application for removal of chlorinated compounds, but holds promise as a way to
remove dioxins and furans from effluents.
3-120 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
3.4.1.2 State of the Art Technology (Wastewater)
The basis for new source performance'standards (NSPS) is best available demonstrated technology in
that new facilities have the opportunity to install the latest and most effective technology for
minimizing the environmental impact from process wastewater without preventing the manufacture of
certain products. Accordingly, Congress directs EPA to consider the best demonstrated processes,
process changes, in-plant controls, and end-of-pipe wastewater treatment technologies that reduce
pollution to the maximum extent possible. EPA, as part of its proposed rulemaking for the pulp,
paper, and paperboard industry effluent limitations guidelines and standards development (58 Federal
Register 66078, December 17, 1993) identified NSPS that result in minimum discharges of
conventional pollutants as generally represented by the performance of the best existing mill in each
subcategory. Pollutants proposed for regulation are the same as those proposed for existing mills.
Alternative standards are also proposed for mills using totally chlorine free (TCP) bleaching
technologies. Whereas effluent guidelines are proposed for both the bleach plant effluent and the final
plant effluent for mills that use chlorine bleaching technologies, EPA proposes that only the final
effluent is regulated at plants that use TCP technology. Specific technologies considered to represent
best available demonstrated technology for each of the industry subcategories are described below.
Dissolving Kraft Subcategory
EPA selected oxygen delignification with substitution of chlorine dioxide (approximately 70 percent
substitution) for chlorine as the basis of NSPS for the dissolving kraft subcategory. In addition, the
proposed NSPS includes several elements that will further reduce pollutant generation. These
elements include:
• Wood chip size and thickness control
• Use of dioxin precursor-free defoamers and pitch dispersants
• Effective brown stock washing
• Closed pulp screening operations
• Pulping liquor spill prevention and control
• Use of chlorine dioxide instead of hypochlorites in brightening stages
• Oxygen- and peroxide-enhanced extraction in the bleach plant
• . High shear mixing for addition of bleaching chemicals in the first stage bleaching stage and
for addition of oxygen in reinforced extraction
• Flow minimization (i.e., process water reuse and recycle)
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• Best demonstrated end-of-pipe secondary biological wastewater treatment. •'
There is an indication that certain high purity dissolving kraft grades of pulp may need to use
hypochlorite. EPA is currently investigating this industry claim.
f
Bleached Papergrade Kraft and Soda Subcategory
EPA proposed similar elements of control for the bleached papergrade kraft and soda subcategory as •
for the dissolving kraft subcategory with the one major difference being the use of oxygen
delignification and extended cooking with 100 percent substitution of chlorine dioxide for chlorine
(i.e., no direct use of elemental chlorine).
Unbleached Kraft Subcategory
EPA proposed limits for COD, BOD5, and TSS for new sources. Proposed effluent limitations
guidelines are based on:
• Effective brown stock washing
• Closed pulp screening operations
• Pulping liquor spill prevention and control
• Flow minimization (process water reuse and recycle)
• Best demonstrated end-of-pipe secondary wastewater treatment.
These technologies are fully developed and implemented at existing unbleached kraft pulp mills.
Dissolving Sulfite Subcategory
EPA proposed similar elements of control for the dissolving sulfite subcategory as for the bleached
papergrade kraft and soda subcategory with two major differences, that being the complete
substitution of chlorine dioxide for chlorine in the first bleaching stage (i.e., no direct use of
elemental chlorine but use of hypochlorite) and no requirement for the use of oxygen- and peroxide-
enhanced extraction in the bleach plant. EPA considered proposing TCP bleaching for this
subcategory, but current information and data indicate that this technology is not fully developed for
the full range of dissolving pulp products in the United States (i.e., not fully developed for the highest
purity grades of dissolving sulfite pulp). EPA may promulgate TCP requirements for certain products
in this subcategory in the future.
Papergrade Sulfite Subcategory
EPA proposed similar elements of control for the papergrade sulfite subcategory with a few
differences, the major one being that totally chlorine free (TCP) bleaching must be used. Further,
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wastewater treatment must include extended residence time secondary clarification. Also, this option
does not require the use of high shear mixing for addition of bleaching chemicals in the first stage of
bleaching. TCP bleaching is fully demonstrated at papergrade sulfite mills in Europe, providing EPA
with the basis for concluding that this is applicable to similar mills in the United States.
Semi-Chemical Subcategory
EPA proposed limits for COD, BODS, and TSS for the semi-chemical subcategory. The basis of
pollutant limits for this subcategory include:
• Effective brown stock washing
• Pulping liquor spill prevention and control
• Flow minimization (process water reuse and recycle)
• Best demonstrated end-of-pipe secondary wastewater treatment.
These technologies are fully developed and implemented in the United States at existing semi-chemical
pulp mills.
Mechanical Pulp; Non-Wood Chemical Pulp; Secondary Fiber - Deink; Fine and Lightweight
Papers from Purchased Pulp; and Tissue, Filter, Non-Woven, and Paperboard from Purchased
Pulp Subcategories
EPA proposed limits for BOD, and TSS for each of these subcategories. EPA did not propose NSPS
for priority and nonconventional pollutants for these subcategories pending further study. The
primary purpose for EPA's revision to existing effluent limitations guidelines was to evaluate chlorine
bleaching operations from all pulp mills and PCB discharges from secondary fiber mills. Data
indicate that the rate of chlorine compound formation and the concentration of these pollutants are,
for the most part, lower than found at chemical pulp mills because of milder bleaching chemical
solutions. EPA plans to consider the need for establishing effluent limitation guidelines for non-
chemical pulp mills and non-wood chemical pulp mills that bleach with chlorine and chlorine-
containing compounds in the future.
Conventional pollutant limitations for these subcategories are based on flow minimization (i.e.,
process water reuse and recycle) and best demonstrated end-of-pipe biological wastewater treatment.
Secondary Fiber Non-Deink Subcategory
EPA proposed limits for conventional, non-conventional, and priority pollutants for this segment of
the industry. The industry was divided into two segments for purposes of regulation, mills that
produce paperboard, builders' paper, or roofing felt, and those mills that produce other products
(e.g., tissue and molded products). This subcategory is divided in two because EPA found that many
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
mills making paperboard, builders' paper, or roofing felt operated complete recycle .water systems
(i.e., no indirect or direct discharge of wastewater), while the other facilities may not. For the
paperboard, builders' paper, and roofing felt segment, EPA proposed effluent limitations based on
zero discharge of process wastewater, including in-mill water reuse and recycle, primary treatment,
and complete reuse of the primary treatment effluent. For other secondary fiber non-deink mills,
EPA proposed effluent limitations guidelines based on flow minimization (i.e., process water reuse
and recycle) and best demonstrated end-of-pipe secondary wastewater treatment.
3.4.1.3 Pulp and Paper (Air)
Air emission control is not new to the pulp and paper industry. The first attempts to control
paniculate emissions were made over 100 years ago, with widespread collection and treatment of air
emissions from kraft pulp mills having been practiced for over 40 years. Within the past 20 years,
sources beyond the major air emission sources have also been controlled. In the early days of air
pollution control at pulp and paper mills, controls focused on emissions from the digester and multiple
effect evaporator only; while now, additional sources such as brown stock washer hood vents,
condensate stripper system vents, turpentine decanter vents, and other sources are being controlled.
All types of airborne emissions may be partly controlled by operating strategies or by modifications to
the production process. A summary of existing techniques to control hazardous air pollutant
emissions from pulping vent sources is provided in Exhibit 3-53. Spill and loss control is one of
greatest odor control methods; although, some type of pollution control device is required in most
applications. While reduced sulfur is not hazardous, it does cause community resentment. Odor
elimination is more difficult than paniculate or odorless gas removal. Reduction of the odorant and
dispersion of remaining material is method to remove odors to below detection threshold (1 ppb for
TRS gases). While little can be done for existing mills, new mills should select sites based on
meteorological characteristics of site to account for prevailing winds, and topographic features that
affect plume diffusion and inversions.
A summary of air emission control strategies (both in-plant controls and end-of-pipe treatment
technologies) used in the pulp and paper industry are summarized below.
Kraft Mills
Many kraft mills currently control some or all of their pulping vents using a combustion device or
scrubbers. Exhibit 3-54 provides a summary of the combustion units currently used to control
different emissions from kraft mills. The noncondensible gases (NCGs), with TRS the primary
emission of concern, in the kraft pulping process are of two types; high volume, low concentration
(HVLC) and low volume, high concentration (LVHC). The LVHC gases include those from the
digester area, condensate strippers, evaporators, etc, while HVLC gases include those from brown
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Overview of the Industry
Exhibit 3-53. Summary of Existing Techniques to Control Hazardous Air
Pollutant (HAP) Emissions From Pulping Vent Sources
Vent Emission
Source
Batch Relief Gas
Continuous Relief
Gas
Batch Blow Gas
Continuous Blow
Gas
Turpentine Decanter
Vent
Evaporator (Hotwell
Noncondensibles)
Washer Screens
Washer Filtrate
Tanks
Washer Hood Vent
Deckers
Knotters
Percent Controlled in Industry
Kraft
97
95
91
88
73
88
5
11
6
9
8
Sulfite
100
0
92
0
0
55
0
57
-
38
0
0
Semi-Chemical
0
33
0
25
na
na
0
0
0
0
NA
All sources are assumed to be controlled with at least 98 percent destruction efficiency for
VOC and organic HAP.
NA = Only one semi-chemical mill was known to practice chemical recovery and none were
known to practice turpentine recovery or bleaching.
Source: U.S. Environmental Protection Agency, Office of Air Quality. Pulp, Paper, and
Paperboard Industry - Background Information for Proposed Air Emission Standards,
Manufacturing Processes at Kraft, Sulfite, Soda, and Semi-Chemical Mills. October 1993.
EPA-453/R-93-050a. • • ,
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EIA Guidelines for Pulp & Paper and Timber
Exhibit 3-54. Percent of Kraft Mills Using Combustion Control Devices
• *
/Emission Sources
Batch Digester
Relief Gas
Continuous
Digester Relief
Gas
Batch Digester
Blow Gas
Continuous
Digester Blow
Gas
Turpentine
Decanter Vents
Evaporator Vents
(e.g., .
noncondensibles,
hotwells)
Washer Screens
Washer Filtrate
Tanks
Washer Hood
Vent
Deckers
Knotters
Combustion Devices
Lime Kim
44
63
68
47
49
68
5
11
0
3
3
Power
Boiler
26
20
6
30
16
20
0
0
6
6
5
Recovery
Furnace
0
9
0
7
0
0
0
0
0
0
0
Incinerator
27
3
17
4
8
0
0
0
0
0
0
Total
97
95
91
88
73
88
5
11
6
9
8
stock washers, pulp knotters, and washer seal tanks. The LVHC gases are easily treated, typically
incinerated in lime kilns, power boilers, or special incinerators (i.e., it is becoming more
commonplace in the industry to have incinerators designed specifically to control air emissions).
These LVHC gases and vapors can be combined into one gas header for treatment in the lime kiln.
The recovery furnace can also be used when the lime kiln is not in operation, but increases the risk of
explosion. Hogged fuel boilers do not operate at high enough temperatures although oil- of gas-fired
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power boilers can be used, but again explosions are a concern. Gas concentrations, must be kept out
of the explosive range, although the LVHC gases are typically too rich to be flammable.
NCG are occasionally scrubbed with caustic prior to incineration to absorb sulfide, although
incineration destroys organics and converts TRS to S02, which can then be absorbed in a subsequent
scrubber.
The HVLC gases are more difficult to control, usually being burned in boilers that can accept such
large gas volumes. More effectively, these HVLC gases can be reduced using process changes that
reduce the emissions (e.g., black liquor oxidation, low odor recovery boiler design; and proper
operation of the recovery boiler).
Incineration of emissions containing TRS results in SO2 formation which is often followed by a
caustic scrubber for removal. Recovery furnaces and flares may also used. Additionally, venting
with the bleach plant stage washer vent gases provides chemical oxidation of the sulfur compounds.
Use of fresh water or stripped condensate as a washing medium in brown stock washers (as opposed
to dirty condensate) also reduces TRS emissions. The TRS emissions from kraft recovery furnaces
are most efficiently controlled by maintaining sufficient oxygen, residence time, and turbulence, and
avoiding overloading. Furnaces with direct contact evaporators rely additionally on black liquor
oxidation for TRS emission control.
Lime kiln TRS control involves maintaining a high degree of lime mud washing. Sodium sulfide in
the lime mud reacts with CO2 in the cold end of the kiln to form H2S emissions. Proper operation of
the lime mud filter prevents sodium sulfide in the lime kiln and allows for oxidation of N^S to
Na2S2Oj, keeping H2S to 8 ppm or less. The use of sulfide-free streams as scrubber makeup water
also minimizes H2S formation by contact with kiln gases.
To destroy TRS emissions, a temperature of 650-800°C is needed for incineration. Lower
temperatures can be used in catalytic combustion but with the presence of the lime kiln and power
boiler, catalytic combustion is rarely if ever used in the industry.
TRS emissions at kraft mills can be reduced by:
• Collection and thermal oxidation of digester and evaporator noncondensible gases, either in
the lime kiln, recovery boilers, or special incinerator.
• Black liquor oxidation, using either air or pure oxygen, and substitution of direct contact
evaporators with concentrators and recycling recovery furnace stack gas into the secondary
air supply of the furnace. Also furnace design and operation modifications may reduce
emissions. (Because TRS emissions are reduced, sulfur in the black liquor increases.
«
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Disadvantages to this oxidation process include possible reversion to TRS''compounds,
reduced heating value of the black liquor, and volatile sulfur emissions from the oxidation
: process.)
• Maintenance of proper process conditions hi the lime kiln including temperature at the point
of discharge, oxygen content of off-gases, sulfide content of lime mud feed, and pH and
sulfide content of the scrubbing water. Scrubbing off-gases with a caustic solution increases
the effectiveness of hydrogen sulfide and methyl mercaptan removal. Also, minimizing
sulfide hi the incoming mud by oxidizing it on the vacuum filter can reduce TRS emissions
in the kiln discharge to less than 10 percent.
• Modification of smelt dissolving tank conditions, such as use of water low in sulfides.
• Use of caustic soda (NaOH) or soda ash (NajCOj) as soda makeup rather than saltcake
(Na^SOJ to reduce sulfidity of the black liquor.
• Collection and thermal oxidation of black liquor off-gases from black liquor oxidation.
• Collection and thermal oxidation in recovery furnace, special incinerator, or lime kiln of
brown stock washer emissions.
• Collection and thermal oxidation in lime kiln, recovery boilers, or special incinerator of
condensate stripping NCGs.
• Cold digester blows, whereby hot black liquor is replaced with cooler liquor from the
filtrate tank and then the digester is blown with compressed ak. The displaced hot liquor is
used to heat incoming white liquor and preheat chips for the next cook.
The major in-plant control techniques for reducing ah- pollution are related to design and operation of
the recovery boiler system and the collection/incineration of noncondensible gases and vapors from
cooking and evaporation operations. TRS emissions from recovery boilers that use direct contact
evaporators can be controlled using the following guidelines:
• Furnace loading should not exceed the "critical level." This level has been found on some
boilers to be about 115 percent of the rated solids loading.
• Primary air should not exceed 65 percent of the total air supplied.
• Excess oxygen should be between 2 and 2.5 percent.
• Liquor sulfidity should be maintained at the lowest practicable level, but no higher than 20-
30 percent.
• Liquor solids concentration fired should be at least 62 percent.
• Black liquor inert inorganic compounds (e.g., Na2CO3 and NaCl) should be minimized.
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• Black liquor nozzle spray should be finely dispersed.
. • Secondary air should be highly turbulent.
• Scrub emissions with white liquor.
Common to the industry, recovery furnaces are undersized, causing increased TRS emissions when
overloaded. Addition of a fluidized bed incinerator to bum surplus black liquor can relieve the
recovery boiler.
Because of TRS emissions from direct contact evaporators, most new mills use low-odor recovery
boilers.
Odor control at pulp and paper mill wastewater treatment plants relies on good system design,
operation, and maintenance. Control measures may include roofed concrete tanks, vented in one
place and oxidized with ozone or ozonation of the wastewater. Additionally, initiation of turpentine
recovery, if not practiced at the facility, can reduce plant odors from the treatment plant.
On occasion, odors caused by cellulose decomposition products, decaying size materials, and sulfides
from sulfate reduction are a source of air pollution from these treatment processes. In general, these
problems are readily controllable through limited aeration of oxidation basins to prevent localized
anaerobic conditions to process controls at sludge storage basins, including dewatering of the sludge
before storage, pH control, and the addition of masking agents. Dewatering is, by far, the most
effective odor control measure.
Electrostatic precipitators (ESPs) have been used in the paper industry for over 100 years. Paniculate
control (i.e., soda fume - sodium sulfate and sodium carbonate) on recovery furnace exhausts with or
without direct contact evaporators is achieved primarily with electrostatic precipitators (ESPs),
providing 90 percent removal of participates greater than one micron in size for older ESP units to
over 99 percent in newer units. Now, ESPs are also being used to clean up lime kiln and bark boiler
exhaust gases. While ESPs are more expensive to install, they are cheaper to operate than wet
scrubbers. Key design parameters include: proper contact time, uniform gas distribution throughout
the electric fields, design and arrangement of the electrodes, techniques for maintaining clean
electrodes, and correct voltage. Efficiency of ESPs increase as flue gas temperature decreases, gas
velocity decreases, and plate area increases. As a further benefit, salt cake can be recovered from the
ESP for reuse. Occasionally, scrubbers can be installed following older ESPs to obtain better
paniculate removals. Use of two Venturis can be successfully used as direct contact evaporators,
eliminating the need for ESPs.
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Paniculate control for other mill operations include:
• Smelt dissolving tank - Scrubbers can be used or gases can be combined with recovery
furnace gases and sent to the ESP.
• Lime Kiln - Venturi scrubbers with pressure drops of 10-25 inches of water to remove
sodium salts, calcium carbonate, and calcium oxide.
• Paniculate emissions from power boilers can be controlled using cyclone collectors,
scrubbers, or ESPs. Cyclones are most effective on combination fuel and power boiler
systems where panicles are large (i.e., 75-96 percent efficiency for paniculates greater than
5 microns in diameter).
Scrubbers/mist pads have been used at mills for recovery boilers and lime kiln paniculate control for
over 35 years as well as on smelt-dissolving tanks and lime slaker vents. Water scrubbers on hogged
fuel boilers have shown 95-98 percent removal of paniculates, by weight, although visible water
plumes cause aesthetic concerns.
Fabric filters are not widely used in the industry, with limited use on coal-fired power boilers, wood-
fired boilers, and occasionally on lime storage fugitive dust collection systems. Temperature
sensitivity, among other factors, has limited their use.
Demister pads, packed towers, or venturi scrubbers are used to control paniculates from smelt-
dissolving tank vent gases. Most lime kirns are controlled by venturi scrubbers, with pressure drops
of 17-34 inches of water, although ESPs are frequently used hi newer mills.
Control strategies for fugitive paniculate emissions (e.g., wood piles and unpaved roads)-include
wetting, use of chemical agents, building enclosures and windscreens, paving roads, and modifying
handling equipment.
SO2 formed in the lime kiln is removed in the process as the regenerated quicklime acts as an in-situ
scrubbing agent. Typically, a venturi scrubber follows the kiln to augment the removal process.
NO, emissions from recovery furnaces and lime kilns are minimal; however, with the current trend of
burning higher solids content black liquor, higher temperatures are present in the furnace which will
raise the NO, concentration but will lower TRS and SO2 concentrations.
Scrubbers are used to control C12 and C1O2 emissions from bleach plants. Small scrubbers, used to
recover chemicals, are used on tower vents. Use of large scrubbers to control combined vent gases,
washer hoods, and seal tanks are also used. Caustic scrubbers are used to remove chlorine while,
chlorine dioxide can be removed using cold water, peroxide, or SO2 water. Elimination of
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hypochlorite from the bleaching process seems to reduce chloroform formation at many mills. The
feasibility of gas-phase scrubbing of chloroform from bleach plant vents has not yet been
demonstrated.
VOC and CO emissions from recovery furnaces and lime kilns result from incomplete combustion of
the organic matter in the fuel. Lime kiln VOC and CO emissions are small and are dependent on the
degree of mixing and the level of excess air used within the furnace. Incineration of some form is
used to control VOC emissions. Control strategies for CO and VOC reductions include: increased
residence time, oxygen content, temperature, and turbulence in the combustion area. While reducing
VOC and CO concentrations, excess air, residence time, and temperature increases do increase the
formation of NO,.
Sulfite Mills
The SO2 in digester blow gases are commonly scrubbed with an alkaline solution of the base (97
percent recovery) and returned to acid preparation. This method does not work with magnesium or
calcium bases (i.e., slurry scrubbers are required, making the operation less practical). In these
instances, the scrubber liquids are discharged to wastewater treatment.
Abatement devices are also applied to the collected SO2 emissions from more minor sources such as
the evaporators and washer heads. In addition to packed towers, these include venturi scrubbers,
turbulent contact absorbers, and spray contact devices. Recoveries as high as 97 percent have been
reported, and SO2 emissions are reduced to acceptable levels.
Methods are also in effect at some sulfite mills for recovering SO2 from the digester blow and relief
gases using a packed tower, where the absorbed SO2 is recovered and reused in the process. This
system is about 75 percent effective in absorbing S02 from the blow pit stacks.
Sulfur dioxide generated during evaporation is usually treated by absorption in an alkaline solution of
the base or sent to the acid plant for SO2 recovery. Some mills have used weak spent sulfite liquor
neutralization (usually magnesium-based) which nearly eliminates SO2 emissions during evaporation.
Scrubbing of collected gases from washing is accomplished by hooding to a direct-contact scrubber.
Sulfur is emitted as SO2 and recycled by absorption in aqueous ammonia to generate ammonium
bisulfite solution, which is then used to make cooking liquor.
Emissions from bleaching of sulfite pulps are similar to kraft pulping, but are dependent on the
bleaching sequence, the wood type, and the amount of residual lignin in the digested pulp.
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NSSC Mills
Milder pulping conditions allow the NSSC process to generate less emissions than kraft or other
chemical pulping processes. With proper operation and control of the NSSC furnace, comparable
emissions to that of kraft recovery furnaces can be achieved.
Preparation of NSSC pulping liquor produces significant quantities of hydrogen sulfide. This must be
oxidized to SO2 and then scrubbed. Emission points include absorbing towers, digester/blow tank
systems, and recovery furnaces.
Ammonia based systems recover SO2 in a manner similar to that used by acid sulfite mills as
described above.
Mechanical Pulping
Heat recovery from steam emissions is practiced extensively, reducing the emission of VOCs through
condensation. As the steam is released during the cooking and refining process, VOCs are also
released.
Paper and Paperboard Manufacture
Control equipment for paper machines are not used because of the high moisture content and minimal
pollutant concentrations. Waste minimization techniques, especially with the quantity of additives
used and method for chemical addition provide a greater reduction in emissions.
3.4.1.4 Solid Waste
The primary problem of solid waste disposal in many mills is the large quantity of waste generated.
It represents a materials handling problem for which there is no universal solution, and each mill
requires a system engineered to meet its particular needs and local conditions.
The major source of solid waste are substantial organic materials including wood wastes and treatment
plant sludges. Because of the high water content and the low specific gravity of these solids, their
bulk is greater than that of inorganics and thus they require larger disposal areas.
Sludge Handling
Major efforts have been made to reduce sludge volume by reducing water content. This process not
only reduces land requirements for disposal, but it also reduces odor since sludge cakes do not
produce odor. Dewatering also enhances the option for incineration and facilitates composting and
application on agricultural land. Historically, sludge from primary and secondary treatment has been
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dewatered using filtration or centrifugation followed by pressing to achieve a cake, with a solid content
of 35-40 percent at best (and often of 20 percent or less). Today, however, sludges with solids
content of 45-50 percent are possible. Benefits of reduced water content in sludge includes reduced
transport and disposal costs, easier handling, unproved Btu content for incineration, and less impact
when disposing in a landfill.
Pulp and paper mill wastewater treatment systems generate two distinct types of sludges, primary and
secondary, each requiring distinct handling practices. Primary sludges, containing greater than 20
percent fiber and less than 30 percent ash are the easiest sludges to dewater while secondary sludges
from high rate treatment systems are the most difficult. In general, the higher the fiber and lower the
ash content, the easier the sludge is to dewater.
Most mills ease the burden of dewatering "difficult sludges" by mixing these sludges with primary
sludges that are easier to dewater. [Mills must be careful not to add too much secondary sludge with
the primary sludge; a sludge that is 50 percent primary sludge and 50 percent secondary sludge is
very difficult to dewater. With the reduction in mill water usage in recent years, the ratio of primary
to secondary sludge is dropping, making the feasibility of combining all sludges generated less
productive.] In certain instances, it may be more appropriate to dewater the primary and secondary
sludges separately. For example, secondary sludges may be suitable for landfilling, while the primary
sludges cannot. Similarly, primary sludges may be reused within the manufacturing process whereas
secondary sludges cannot. Bark or sawdust may even be added to the sludge, acting as a filter aid to
enhance dewatering. Also, use of polymers is common to act as flocculents to dewater the sludge.
Mills that use basin systems to treat wastewater almost always generate primary sludge only; activated
sludge systems generate both primary and secondary sludges. Mills that operate other types of
treatment facilities, such as trickling filters, flotation clarifiers, and dissolved air flotation units, also
generate sludges requiring dewatering.
Existing sludge handling practices at pulp and paper mills are presented in Exhibit 3-55. Descriptions
of these practices are provided below.
Sludge conditioning and handling practices include activities such as grinding, blending, storage, and
thickening. Grinding is performed to remove large solids that could clog subsequent process
operations. As described above, difficult to dewater sludge may be blended with easier to dewater
sludge (e.g., primary sludge) to improve the dewatering. Many mills will store sludge in tanks,
basins, ponds, and lagoons so that a proper mix of sludge can be maintained to minimize sludge
variability.
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EIA Guidelines for Pulp & Paper and Timber
1
1
(
Exhibit 3-55. Summary of Sludge Handling/Dewatering Operations In Place at Pulp and
Paper Mills
Sludge Operations
Number of Mills
Sludge Conditioning and Handling
Blending
Storage
Thickening
Chemical Conditioning
21
43
68
73
Sludge Dewatering
Belt Filter Press
Screw Press
Vacuum Filter (Fabric Media)
Vacuum Filter (Coil Media)
V-Press
Sludge Lagoon
Other .
Total Number of Mills With Sludge
Operations1
122
53
40
15
11
35
29
262
The Sum of the number of mills having each operation does not necessarily equal the total
number of mills because most mills have more than one type of operation.
Source: U.S. Environmental Protection Agency, Office of Water. Development Document for
^roposed Effluent Limitations Guidelines and Standards for the Pulp, Paper, and Paperboard
Point Source Category. October 1993. EPA-821-R-93-019.
Next, many mill sludge are thickened using gravity or flotation thickeners. These thickeners operate
similar to gravity and flotation clarification. Thickening increases the solids content in the sludge
thereby improving sludge dewatering capabilities, equipment which requires higher solids content to
operate properly. Solids content for primary and secondary sludges after thickening are
approximately 4 percent and up and 10 percent, respectively.
After thickening, sludges can be chemically conditioned, typically using some combination of lime,
ferric chloride, and specialty polymers. These chemicals promote coagulation and floe formation of
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the sludge, separating the solids from the water. The cost of conditioning increases as the
dewaterability of the sludge decreases.
After conditioning and thickening, sludges are dewatered. By far, belt filter presses are the most
common type of dewatering device used in the pulp and paper industry. In general, sludge is fed
between two merging fabric or coil belts that enclose the sludge cake and pass it through a roller
configuration where pressure increases through subsequent rollers. Blades following the rollers
scrape the dewatered sludge off the belts and onto a conveyor or into a hopper.
Continuous rotary vacuum filters are also commonly used in the industry to dewater sludges. The
filter media is either cloth, wire mesh, or coil spring. Preconditioning the sludge is common practice
using a variety of polymers, lime, ferric chloride, alum, and additives such as fiber, fly ash, or coal.
This filter consists of a large horizontal cylinder (covered with a filter media) partially submerged in a
sludge tank. The cylinder rotates in the sludge at a rate of 1-2 rpm, collecting a layer of sludge on
the surface of the filter media. A vacuum is applied to the cylinder, extracting the water from the
sludge. A blade then scrapes the dewatered sludge cake from the cylinder. The solids content of
vacuum filter sludge ranges from about 20 to 30 percent solids.
Most new dewatering systems include a screw type filter. After processing through a gravity
thickener, the sludge is fed to a horizontal screw extruder. Water is squeezed out of the extruder
through a screen. Using screw type filters, solids contents of 50-55 percent are possible.
V-presses or mechanical presses are also used in the industry to dewater sludges, often succeeding
other dewatering devices (e.g., vacuum filters). These devices can dewater 30 percent solid sludges
to 45 percent solid cakes; a content that can be incinerated.
Sludge disposal methods employed by pulp and paper mills includes landfilling, impounding,
incineration, and land application. Landfills are the most common disposal method for treatment of
sludges, as shown in Exhibit 3-56. While incineration is a valuable management method for reducing
sludge volume, sludge has little heat value, thereby limiting its usefulness as a fuel. Adding bark or
hog fuel to the sludge does little to improve the viability of this option, only acting to reduce the
efficiency of the unit to generate steam. Dewatering sludges to 45-50 percent, make incineration a
more attractive option, making a boiler a more efficient alternative. Land application of sludge is
considered to be soil amendment, not meeting nutrient requirements to be considered fertilizer.
Sludge is a good amendment for sandy soils, however, solid waste restrictions may limit its use.
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EIA Guidelines for Pulp & Paper and Timber
t
Exhibit 3-56. Sludge Disposal Methods Used by Pulp and Paper Mills
Disposal Method
Landfill (Company-
owned)
Landfill (Municipal)
Landfill (Commercial)
Surface Impoundment
Incineration
Land Application
Saleable By-product
Recycle to Process
Composting
Number of Mills-
Primary
Sludge
63
15
23
28
8
10
4 ,
11
2
Biological
Sludge
16
2
3
8
2
9
1
5
1
Combined
Sludge
48
13
8
9
22
9
1
3
2
Total"
132
37
37
56
43
38
10
21
12
Source: U.S. Environmental Protection Agency, Office of Water. Development Document for
Proposed Effluent Limitations Guidelines and Standards for the Pulp, Paper, and Paperboard
Point Source Category. October 1993. EPA-821-R-93-019.
Disposal of Wood and Other Organic Wastes
Wood wastes and other organic waste materials are typically burned or disposed on land. Wood
wastes, especially those containing a large quantity of bark, produce a leachate containing
considerable color. In some cases bark can be sold as a mulching agent, and in large mills it can be
burned as a fuel in the power boilers. Wood wastes do not contain sufficient nitrogen to be used
successfully in composting. The kraft process also generates some unique wastes, such as slaker
grits, unburned lime rejects from the kiln, and dregs from die green liquor clarifiers. These wastes
can amount to 30-40 pounds per ton of pulp. Also, mechanical pulping generates approximately 5-10
pounds of screening rejects per ton of pulp. These wastes typically end up in the wastewater
treatment plant where they are removed as primary clarifier sludge.
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3.4.2 TIMBER PRODUCTS PROCESSING
3.4.2,1 Timber Products Processing (Wastewater Effluent)
The external treatment technologies employed by the timber products processing industry are
essentially the same across the range of subcategories. For this reason the discussion that follows
assumes the controls are applicable to all or most of the subcategories. For the timber products
industry, the physical and chemical treatment technologies available to meet New Source Performance
Standards include the following:
• Solids separation by screening. The purpose of such devices is to recover solids prior to
subsequent wastewater treatment. The types of screens available are tangential, cylindrical,
vibratory, and centrifugal. Other types of equipment available include inclined-trough
screens, drilled plates, bar screens, microstrainers, and basket screens. Often a coarse
screen will be used in front of a finer screen to improve performance. The performance of
screening devices will vary depending upon the wastewater characteristics, the equipment
selected, and the use of chemical additives. It is impossible to reduce suspended solid
levels as well as BOD and oil and grease associated with the solids.
• Oil separation. Oil removal can be used prior to solids removal to facilitate the operation
of that equipment. The common techniques used in the timber industry include in-line
grease traps and gravity separators. Other techniques such as dissolved ah- flotation (DAF)
and API-types oil-water separators also are available for this operation.
• Chemical coagulation and flocculation. As an alternative to ordinary sedimentation,
chemical addition prior to sedimentation has further increased the removal efficiencies of
primary clarifiers. Chemical coagulation results in higher removal of suspended solids,
BODS, sulfides, and chrome and alkalinity through flocculation of colloidal particles. Lime,
ferric chloride, various polyelectrolytes, and clays of several types are used in the industry
for this purpose.
An essential part of any chemical or chemically aided precipitation system is stirring or
agitation to increase the opportunity for particle contact (flocculation) after the
chemicals have been added. The action is sometimes aided by the installation of
stationary slats or stator blades located between the moving blades that serve to break
up the mass rotation of the liquid and promote mixing. Increased particle contact will
promote floe growth; however, if the agitation is too vigorous, the shear forces that are
set up will break up the floe into smaller particles. Agitation should be controlled
carefully so that the floe particles will be of suitable size and will settle readily.
Chemical coagulation and flocculation are accomplished by a combination of physical
and chemical processes which thoroughly mix the chemicals with the wastewater and
promote the aggregation of wastewater solids into panicles large enough to be separated
by sedimentation, flotation, media filtration, or straining. The strength of the
aggregated particles determines their limiting size and their resistance to shear in
subsequent processes.
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• Solids separation by sedimentation. This technology does not have a wide application in
the industry because of the relatively long detention times required to be effective.
: Conventional equipment includes grit chambers, clarifiers, and settling basins. Performance
of these systems is dependent on good design (i.e., elimination of short circuiting and fairly
constant flow rates).
• Physical-chemical treatment. Physical-chemical processes for treatment of wastewater are
desirable because they often have a smaller land requirement. Air flotation is a physical-
chemical process that have been used extensively in conjunction with the food processing
industry, often as preliminary treatment step prior to biological wastewater treatment.
Flotation technology is capable of removing BOD, suspended solids, and oil and grease,
with chemical coagulants usually required to optimize performance. Variations of the
technology include: vacuum flotation, dissolved ah* flotation, flotation, and electroflotation.
Other physical-chemical technologies that are being considered include reverse osmosis,
acid activated clay columns, carbon adsorption, and chemical coagulation/sedimentation
systems.
• High-rate aerobic biological systems. The industry wastewater is highly biodegradable
and is treated well by biological systems. The difficulties with such systems are due to
hydraulic surges (e.g., wash down or tank dumps) and shock loadings. Flow equalization is
a common approach to improving system operation. High rate systems that are available
and effective include activated sludge, rotating biologic contactors, and trickling filters.
Performance is dependent upon process kinetics and determined by the wastewater and the
system selected.
• Low-rate biological systems. These systems are effective in removing organics from the
wastewater stream, but they require longer detention times than high-rate systems and
therefore more land. These systems include aerobic lagoons (naturally aerated or
mechanically aerated) and anaerobic lagoons (possibly followed by an aerobic system).
These systems are reliable for treating the highly variable waste loads that are characteristic
of the industry. Performance is comparable to high-rate systems, but the system must be
designed carefully to consider other factors such as temperature.
• Land treatment. This technology is dependent on the availability of sufficient land with
the proper soil conditions. Three general approaches could be utilized: irrigation of a
cover crop or vegetation; overland flow; or infiltration-percolation. The performances of
these systems are dependent upon the wastewater characteristics (screening or other
preliminary treatment normally is required to remove solids), the soil characteristics, and
climatic factors (e.g., annual precipitation). Where these systems can be used, essentially
complete removal of pollutants found in timber industry wastewater is possible.
3.4.2.2 Timber Products Processing (Solid Waste)
There are four wastes from timber products processing facilities listed as hazardous under RCRA, and
all of them are from the wood preserving industry. These include wastewater, process residuals,
preservative drippage, and spent formulations from chlorophenolic, creosote, and chromium/arsenic
wood preserving operations, as well as sludge from treatment of PCP and/or creosote wood
preserving wastewaters (wastes F032, F034, F03S, and K001 respectively). More detailed definitions
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of these wastes can be found in Section 6.3.6. For each waste listed by EPA as hazardous, EPA
must also establish Best Demonstrated Available Technology (BOAT) and/or constituent standards
which must be employed or met prior to land disposal of the waste. EPA has already established
BDAT technology for waste K001, and is in the process of setting BDAT requirements for recently
listed wastes F032, F034, and F03S. The section below describes the established BDAT standards, as
well as other applicable technologies which could be incorporated into the pending BDATs.
For more detailed information on the technologies and listed wastes mentioned here, the following
sources should be consulted:
U.S. Environmental Protection Agency, Office of Solid Waste. May 1988. Proposed Best
Demonstrated Available Technology (BDAT) Background Document for K001. Volume 16.
EPA/530-SW-88-0009-0.
U.S. Environmental Protection Agency, Office of Solid Waste. August 1988. Final Best
Demonstrated Available Technology (BDAT) Background Document for F006. EPA/530-SW-88-
059M.
U.S. Environmental Protection Agency, Office of Solid Waste. November 1989. Proposed Best
Demonstrated Available Technology (BDAT) Background Document for Halogenated Pesticide
and Chlorobenzene, Halogenated Phenolic, and Phenolic Wastes. EPA/530-SW-88-012P.
U.S. Environmental Protection Agency, Office of Solid Waste. May 1990. Final Best Demonstrated
Available Technology (BDAT) Background Document for U and P Wastes and Multi-Source
Leachate (F039). Volume A. Wastewater Forms of Organic U and P Wastes and Multi-Source
Leachate (F039)for Which There Are Concentration-Based Treatment Standards. EPA/530-
SW-90-060F.
U.S. Environmental Protection Agency, Office of Solid Waste. May 1990. Final Best Demonstrated
Available Technology (BDAT) Background Document for U and P Wastes and Multi-Source
Leachate (F039). Volume C. Non-Wastewater Forms of Organic U and P Wastes and Multi-
Source Leachate (F039)for Which There Are Concentration-Based Treatment Standards.
EPA/530-SW-90-060H.
i
Chromium/Arsenic Wood Preserving Wastes (F035)
Non-Wastewater Wastes
For listed hazardous waste K001, EPA identified metal stabilization as the BDAT for metals in non-
wastewater wastes. Stabilization involves chemically and physically binding the metal constituents of
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the waste into the microstructure of a cementicious medium, resulting in reduced leaching potential.
Binding reagents include Portland cements, cement kiln dust, fly ash, quicklime, and hydrated limes.
It is likely that metal stabilization will be named as the BOAT for F035 non-wastewater wastes too,
because metals are the constituents responsible for F035's listing, and because few, if any, other
metals-toxicity reduction technologies have been commercially demonstrated for non-wastewater
wastes containing metals.
Wastewater Wastes
For other listed wastewaters (of K001) for which metals were among the listing constituents, EPA
specified chemical precipitation of metals followed by settling or filtration of metal precipitates, and
sludge dewatering as the BOAT for metals treatment. For chromium-containing wastewater wastes, a
chromium reduction (as opposed to oxidation) step may be necessary prior to chemical precipitation in
order to decrease hexavalent chromium concentrations. Because F03S contains similar metallic
constituents to these wastes, the BDAT for metals in F035 wastewaters may be similar to that of other
wastes.
The underlying principle of chemical precipitation is that metals in wastewater are removed by the
addition of a treatment chemical that converts the dissolved metal to a metal precipitate. This
precipitate is less soluble than the original metal compound and, therefore, settles out of solution,
leaving a lower concentration of the metal present in the solution. The principal chemicals used to
convert soluble metal compounds to the less soluble forms include: lime (Ca(OH>2), caustic (NaOH),
sodium sulfide (Na^S), and, to a lesser extent, soda ash (Na^Oj), phosphate, and ferrous sulfide
(FeS)..
After the waste is reacted with the treatment chemical, it flows to a quiescent tank where the
precipitate is allowed to settle and subsequently be removed. Settling can be chemically assisted
through the use of flocculating compounds. Flocculants increase the particle size and density of the
precipitated solids, both of which increase the rate of settling. The particular flocculating agent that
will best improve settling characteristics will vary depending on the particular waste; selection of the
flocculating agent is generally accomplished by performing laboratory bench tests. Settling can be
conducted in a large tank by relying solely on gravity or be mechanically assisted through the use of a
circular clarifier or an inclined separator.
Filtration can be used for further, removal of precipitated residuals both in cases where the settling
system is underdesigned and in cases where the particles are difficult to settle.
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Creosote and Chlorophenol Wood Preserving Wastes (F034, F032)
Non-Wastewater Wastes
EPA has established rotary kiln incineration as the BDAT for treating the non-wastewater portion of
creosote/PCP wood preserving wastewater treatment sludges (K001). The goal of incineration of such
a waste is to thermally destroy, or oxidize, its organic constituents.
A rotary kiln is a slowly rotating, refractory-lined cylinder that is mounted at a slight incline from the
horizontal. Solid wastes enter at the high end of the kiln, and liquid or gaseous wastes enter through
atomizing nozzles in the kiln or afterburner section. Rotation of the kiln exposes the solids to the
heat, vaporizes them, and allows them to combust by mixing with air. The rotation also causes the
ash to move to the lower end of the kiln where it can be removed. Rotary kiln systems usually have
a secondary combustion chamber or afterburner following the kiln for further combustion of the
volatilized components of solid wastes.
Due to the similarity between the organic listing constituents for wastes F034, F032, and K001, it is
not unreasonable to expect some form of incineration to be named as BDAT for F032 and F034 as
well. EPA has identified incineration as the BDAT for listed wastes with similar constituents in the
past. Other types of incineration technology that could potentially be named BDAT or used to
achieve BDAT concentration standards include liquid injection, iluidized bed and fixed hearth. These
are described briefly below.
Liquid Injection. The liquid injection system is capable of incinerating a wide range of gases and
liquids. The combustion system has a simple design with virtually no moving parts. A burner or
nozzle atomizes the liquid waste and injects it into the combustion chamber where it bums in the
presence of air or oxygen. A forced draft system supplies the combustion chamber with air to
provide oxygen for combustion and turbulence for mixing. The combustion chamber is usually a •
cylinder lined with refractory (i.e., heat resistant) brick and can be fired horizontally, vertically
upward, or vertically downward. In general, only wastes with low or negligible ash content are
suitable for liquid injection; therefore, this technology does not usually generate an ash residual.
Fluidized Bed. A fluidized bed incinerator consists of a column containing inert particles such as
sand which is referred to as the bed. Air, driven by a blower, enters the bottom of the bed to fluidize
the sand. Air passage through the bed promotes rapid and uniform mixing of the injected waste
material within the fluidized bed. The fluidized bed has an extremely high heat capacity
(approximately three times that of flue gas at the same temperature), thereby providing a large heat
reservoir. The injected waste reaches ignition temperature quickly and transfers the heat of
combustion back to the bed. Continued bed agitation by the fluidizing air allows larger particles to
remain suspended in the combustion zone.
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Fixed Hearth Incineration. Fixed hearth incinerators, also called controlled air or starved air
incinerators, are another major technology used for hazardous waste incineration. Fixed hearth
incineration is a two-stage combustion process. Waste is ram-fed into the first stage, or primary
chamber, and burned at less than stoichiometric conditions. The resultant smoke and pyrolysis
products, consisting primarily of volatile hydrocarbons and carbon monoxide, along with the normal
products of combustion, pass to the secondary chamber. Here, additional air is injected to complete
the combustion. This two-stage process generally yields low stack paniculate and carbon monoxide
(CO) emissions. The primary chamber combustion reactions and combustion gas are maintained at
low levels by the starved air conditions so that paniculate entrainment and carryover are minimized.
Combustion gases from an incinerator are subsequently fed to a scrubber system for cooling and
removal of entrained particulates and acid gases, if present. In general, with the exception of liquid
injection incineration, two residuals are generated by incineration processes: ash and scrubber water.
Ash residuals from K001 combustion have been reported to contain listing metals, and, depending on
the type of combustion technology employed, ash residuals from F032 and F034 may also contain
metals. This ash could need to be stabilized hi order to meet metals standards prior to land disposal.
Any metals volatilized during combustion may end up in the scrubber water. The scrubber water
may thus need treatment .via precipitation and filtration prior to land disposal, as described earlier.
Wastewater Wastes
&*•
The listing constituents from F032 and F034 wastewater form wastes are primarily PAHs and
chlorophenols. Many of these already have BOAT standards and technologies established under prior
hazardous waste listings. The pending BDAT wastewater standards for F032 and F034 may duplicate
the standards of these previous listings. Treatment technologies for these, and similar wastewater
constituents are described briefly below.
The concentrations and type(s) of waste constituents present in the waste generally determine which
technology is most applicable. Carbon adsorption, for example, is often used as a polishing step
following primary treatment by biological treatment, solvent extraction, or wet air oxidation.
Typically, carbon adsorption is applicable for treatment of wastewaters containing less than 0.1
percent total organic constituents. Wet air oxidation, PACT* treatment, biological treatment, and
solvent extraction are applicable for treatment of wastewaters containing up to 1 percent total organic
constituents. Some wastewaters may contain constituents that are too toxic to biomass, and therefore
cannot be treated effectively by biological treatment or PACTR treatment.
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Biological Treatment. Biological treatment is a destruction technology in which hazardous organic
constituents in wastewaters are biodegraded. This technology generates two treatment residuals: a
treated effluent and a waste biosludge. Waste biosludge may be land disposed without further
treatment if it meets the applicable BOAT treatment standards for regulated constituents. For further
information on biological treatment, see Section 3.4.2.1.
PACT8 Treatment. PACT" treatment is a combination of carbon adsorption and biological treatment
in which hazardous organic constituents are biodegraded or selectively adsorbed onto powdered-
activated carbon. This technology generates two treatment residuals: a treated effluent and spent
carbon/biosludge. The spent carbon may be regenerated and recycled to the process or may be
incinerated.
Carbon Adsorption. Carbon adsorption is a separation technology in which hazardous organic
constituents in wastewaters are selectively adsorbed onto activated carbon. This technology generates
two treatment residuals: a treated effluent and spent activated carbon. The spent activated carbon
can be reactivated, recycled, or incinerated.
Solvent Extraction. Solvent extraction is a separation technplogy in which organics are removed from
the waste due to greater constituent solubility in the solvent phase than in the waste phase. This
technology generates two residuals: a treated waste residual and an extract. The extract may be
recycled or treated by incineration.
Chemical Oxidation. Chemical oxidation is a destruction technology in which inorganic cyanide,
some dissolved organic compounds, and sulfides are chemically oxidized to yield carbon dioxide,
water, salts, simple organic acids, and sulfates. This technology generates one treatment residual:
treated effluent.
Wet Air Oxidation. Wet air oxidation is a destruction technology in which hazardous organic
constituents in wastes are oxidized and destroyed under pressure at elevated temperatures in the
presence of dissolved oxygen. This technology is applicable for wastes comprised primarily of water
and up to 10 percent total organic constituents. Wet air oxidation generates one treatment residual:
treated effluent. The treated effluent may require further treatment for hazardous organic constituents
by carbon adsorption or PACT* treatment. Emissions from wet air oxidation may also require further
treatment.
Stripping Treatment. Stripping treatment is a separation technology. Steam stripping is a technology
in which wastewaters containing volatile organics have the organics removed by application of heat
using steam as the heat source. Air stripping is a technology in which wastewaters containing volatile
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organics have the organics removed by volatilization. This technology generates one treatment
residual: treated effluent. Emissions from stripping treatment may require further treatment.
Reverse Osmosis. Reverse osmosis is a separation technology in which dissolved organics (usually
salts) are removed from a wastewater by filtering the wastewater through a semipermeable membrane
at a pressure greater than the osmotic pressure caused by the dissolved organics in the wastewater.
This technology generates two treatment residuals: the treated effluent wastewater and the
concentrated organic salt materials which do not pass through the membrane.
3.5 POLLUTION PREVENTION
Pollution prevention includes source reduction and other techniques that reduce or eliminate the
generation of pollutants. Historically, pollution prevention occurred only when economic incentives
enticed facilities to institute these measures. Recently, however, there has been increased pollution
prevention to benefit the environment irrespective of economic gain. Regulatory compliance has
become an incentive to adopt pollution prevention techniques. In the past several years, EPA has
published several policy statements regarding the inclusion of pollution prevention and recycling
provisions into all Agency programs, including the use of pollution prevention in enforcement
settlements. These pollution prevention settlement conditions are intended to correct any past
violations and reduce or eliminate the potential for future violations.
This section identifies a variety of pollution prevention techniques employed by the pulp and paper
and timber industries.
3.5.1 PULP AND PAPER
EPA developed a model pollution prevention plan for the industry to promote pollution prevention,
details of which are provided in:
• Pollution Prevention Opportunity Assessment and Implementation Plan for Simpson Tacoma
Kraft Company, Tacoma, Washington. EPA 910/9-92-027. U.S. Environmental Protection
Agency Region 10, August 1992.
• Model Pollution Prevention Plan for the Kraft Segment of the Pulp and Paper Industry.
EPA 910/9-92-030. U.S. Environmental Protection Agency Region 10, September 1992.
• Pollution Prevention for the Kraft Pulp and Paper Industry, Bibliography. EPA 910/9-92-
031. U.S. Environmental Protection Agency Region 10, September 1992.
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Additional information on pollution prevention techniques for the industry are available in:
6
.. • Summary of Technologies for the Control and Reduction of Chlorinated Organics from the
Bleached Chemical Pulping Subcategories of the Pulp and Paper Industry. U.S.
Environmental Protection Agency, Office of Water Regulations and Standards, April 27,
1990.
• Pollution Prevention Technologies for the Bleached Kraft Segment of the U.S. Pulp and
Paper Industry. EPA/600/R-93/110.. U.S. Environmental Protection Agency, Office of
Pollution Prevention and Toxics, August 1993.
Areas of the mill most conducive to pollution prevention include pulping, bleaching, chemical
recovery, and papermaking. Of note, many of the pollution prevention activities actually improve
product quality and production efficiency.
3.5.1.1 Wood Yard Operations
Raw Material Selection
Wood fiber should be used that has not been treated with wood preservatives (particularly
chlorophenols), eliminating a source of dioxin and furan precursors from the wood source.
Log Transport Water
Water used to convey logs can be recycled with minimal blowdown. Bark and fiber collected, in the
transport water can be burned in a hogged fuel boiler for energy recovery. Also, many mills
successfully use treated mill effluent as transport water. (Treated or partially treated effluent can also
be used for dust suppression on chip piles and roadways, and make-up to fire protection basins.)
Debarking
Dry drum debarkers reduce water consumption and effluent pollutant loadings to wastewater
treatment. Most wet debarkers have been replaced by dry debarkers. As an added benefit, bark from
dry barkers can be fed directly to energy recovery boilers without dewatering, unlike wet bark.
Storm Water Control
Chip storage and processing areas should be protected to minimize runon and runoff of storm water.
Storm water runoff should be collected and treated in the plant wastewater treatment system.
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3.5.1.2 Pulping
Chip Quality Control
Uniform chips stabilizes cooking and reduces digester chemical consumption, minimizes
overbleaching, and minimizes fines and screening rejects. Where purchased off-site, chips should
have minimal fines and be of uniform size and thickness. Where chipped pn-site, chippers should be
maintained to produce consistent quality chips. Addition of chip screening devices prior to pulping
promotes more efficient pulping and lower reject rates.
Def oamers and Pitch Dispersants
Defearners and pitch dispersants, added to pulp before the brown stock washers, should be used that
do not form dioxins and furans. This includes the use of oil-free defoamers or non-re-refined oils in
/
the defoamers can significantly reduce dioxin and furan formation.
Extended Cooking
Pulping for an extended period of time at modified temperatures and alkalinity reduces the Kappa
number of the pulp, thereby decreasing the amount of chemicals needed to bleach the pulp. Several
patented processes are currently being used for the continuous pulping process (i.e., Modified
Continuous Cooking [MCC*] developed by Kamyr Inc. and Kamyr AB and Extended Modified
Continuous Cooking [EMCC*] developed by Kamyr Inc.) with excellent success. Similarly, extended
cooking is also effective hi batch systems, with at least two systems available commercially (i.e., the
Rapid Displacement Heating [RDH*] System, sold by Beloit Inc., and the Super Batch9 System, sold
by Sunds Defibrator, Inc.
Brown Stock Washers . .
Effective brown.stock washing reduces the amount of organics carried over to the bleaching process,
thereby reducing the amount of chlorinated organic precursors. Also, the organics that enter the
bleaching process compete with the pulp fibers for the bleaching chemicals, thereby increasing the
amount of bleaching chemicals needed. Water conservation is also important in the brown stock
washers because all of this water typically is evaporated in the black liquor recovery. Traditional
rotary drum vacuum washers are typically supplemented or replaced by higher efficiency washers
such as diffusion washers, belt washers, and presses.
Diffusion Washers
i
Also, TRS emissions from washers are highly dependent on the washing equipment with less
dependency on the wood type, the sulfur content, the pH, and the temperature. Two types-of wash
systems are used in the pulp industry: displacement washing and diffusion washing., .Displacement
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washing is more common, with vacuum washing, the most common type of displacement washing.
Air emissions increase when condensates are used as washer water, unless the condensates are
stripped before use in the washers, as scrubbing fluid for lime kilns, or as white liquor makeup water.
(Steam stripping of the condensates can reduce plant BOD5 in the raw wastewater to the treatment
plant by one-third.) Incineration in an existing boiler is the only practical way to treat washer gases.
To reduce emission volume, some washer hoods are totally enclosed and pressurized. Washer
emissions can be totally eliminated using diffusion washer systems. Diffusion washing takes place in
a closed reactor, with no air (ideally). Vents from these washers emit approximately 1/lOOth the
concentration of TRS that is emitted by conventional drum washers.
Closed Screen Room Operations
Often, the filtrate from the decking operation is discharged directly without treatment. This filtrate
can be reused as dilution water for the screening operation or as brown stock wash water, eliminating
any discharge of wastewater from this process. Many mills in the U.S. currently practice this
technique. Elimination of decker filtrate can reduce the mill's BOD load by about one-third.
Screen Replacement
Adding pressure screens to the decker process, rather than gravity flow screens reduces air
entrainment and the resulting foaming problems.
Oxygen Delignification
Use of oxygen to remove lignin from pulp after the brown stock washing operation can reduce the
Kappa number by 50 percent, thereby reducing the amount of bleaching chemicals needed. Filtrate
from the delignification washers can be recycled back into the process.
Steam Stripping
Organic and sulfur compounds (primarily methanol) that can be emitted to the atmosphere from
condensates from evaporators, digester blow tanks, and turpentine recovery systems at kraft mills can
be controlled through the use of steam strippers. While controlling air emissions, these systems also
reduce the load of pollutants in the wastewater. Stripper overhead can be incinerated while stripper
bottoms can be reused in the brown stock washers. Steam stripping can reduce BOD loadings in raw
wastewater by one-third at bleached kraft mills and by even more at unbleached kraft mills.
Pulping Liquor Management, Spill Prevention, and Control
Management programs, in-plant controls, and monitoring systems can prevent and control pulping
liquor losses that occur as the result of spills, leaks, and bypasses. Approximately one-third to one-
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half of the BOD and TSS in wastewater from pulp mills is from this source. Practices that can
reduce these- losses include:
• . Operating the process at a constant rate
• Implementing a preventative maintenance program for pulping liquor handling equipment
• Installing spill detection devices and high/low alarms on pulping liquor tanks
• Regular inspection of pulping liquor equipment
• Secondary containment
• Spill retention systems for chemical recovery for sufficient capacity to store collected spills
and bypasses for eventual return to the process or to bleed to the wastewater treatment
system.
Specifics on best management practices that can be employed at pulp and paper mills to minimize
effluent discharges are provided in:
• Technical Support Document for Proposed Best Management Practices Programs, Pulping
Liquor Management, Spill Prevention and Control, U.S. EPA.
Maximizing Recovery Boiler Capacity
• <*•
Often, pulping is limited by the capacity of the recovery boiler for recovering pulping chemicals from
the black liquor. When mills modify plant operations, such as installing oxygen delignification
systems, there can be an increase in the organic content fed to the recovery boiler.
Recovery Boiler Expansion
Boiler capacity can be increased to bum more liquor solids. Often, minor adjustments or upgrades
can be made which will increase the effective capacity.
Air Systems Modifications
Improved air feed to recovery boilers can improve combustion, thereby increasing capacity.
Recently, high-pressure air systems, with the air fed through small ports to create a lot of turbulence,
have been introduced which effectively increase efficiency.
Recovery Boiler Operation
TRS emissions from recovery boilers can be minimized through proper boiler operation. When
running a recovery boiler, the liquor solids level should be as high as possible but within the optimum
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry-
boiler range, secondary and tertiary air should be greater than 35 percent of the total combustion air
supply, excess oxygen should be maintained between 2 and 2.5 percent, liquor sulfidity should be as
low as possible for the desired pulp quality, inerts should be prevented from entering the system, and
dispersion of liquor should be maximized through proper spray nozzles. In addition, old recovery
boilers (that can account for 60-80 percent of the total TRS emissions from a mill) can be modified to
a low odor design by elimination of direct contact evaporators, modification of secondary and tertiary
combustion air systems, and installation of a new economizer section.
Anthraquinone Addition
The addition of anthraquinone to the pulping liquor can reduce the loss of cellulose and hemi-cellulose
in the digestion, and increasing the yield of pulp. Anthraquinone also increases the speed of the
pulping process, and allows the digestion to occur at a lower temperature, without effecting pulp
strength and viscosity. Anthraquinone is removed hi the recovery boiler.
High-Consistency Black Liquor Solids Firing
Burning a black liquor that is 80 percent solids, rather than the traditional 60-70 percent solids can
increase boiler capacity. At the higher percentage of solids, less plugging is likely to occur, a higher
temperature will be achieved, thereby reducing TRS emissions and paniculate concentrations.
Vent Stream Collection
i
Collection and incineration of vent gases from brownstock washers, foam tanks, black liquor filters,
oxidation tanks, storage tanks, and other TRS containing streams not typically collected in NCG
systems can reduce TRS and VOC emissions by 10-20 percent.
Air Pollution Control Scrubber Water
Weak caustic wash water can be used in air scrubber systems to control emissions from smelt
dissolving tanks, bleach plant and chlorine dioxide vents, lime slakers, and lime kilns. Scrubber
water can be returned to the causticizer, effectively reducing water usage and chemical consumption.
/
Fluidized Bed Calciners
Use of fluidized bed calciners (i.e., lime kilns), replacing rotary kilns, almost totally eliminates TRS,
SO,, and NO, emissions.
3-149 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
3.5.1.3 Bleaching
Counter-current Washing
Use of countercurrent washing systems, where rinsewater and pulp flow in opposite directions,
drastically increases rinse efficiency. Effluent from the first bleach stage washer (having flowed
through each washer, is discharged to the treatment system. Typically, two bleach plant effluent are
generated, one alkaline and one acidic, although these can be combined if large capacity washers are
used to minimize the impact of foaming and precipitation, and showers are installed to remove scale
from the washer wires. Some mills are able to minimize water usage by recirculating water from the
pulp thickening area rather than the from the washers. This reduces water 60 percent compared to an
open system.
Ozone Bleaching
Use of ozone 'as a bleaching agent has long been researched, with full-scale installation of this
technology at a sulfite mill hi the United States hi 1991 and at a kraft mill in 1992. Medium and high
consistency pulps are used, with medium consistency showing the best results with ozone bleaching.
Oxygen delignification is needed prior to ozone bleaching to reduce the amount of ozone needed.
Effluent from the ozone bleaching step can be recycled to the recovery boiler, decreasing the amount
of effluent generated. Because chlorine and derivatives are not used, chlorinated organics are not
formed.
Split Addition of Chlorine
Introducing chlorine at several points hi the first bleaching stage of a kraft mill reduces the formation
of chlorinated phenolics, furans, and dioxins, while still retaining pulp quality.
Improved Mixing and Process Control
Use of high shear mixers and high pressure gas (i.e., ozone or chlorine) increases the mixing of the
pulp and bleaching chemicals, increasing process efficiency. Also, instrumentation to monitor and
control bleach addition, particularly hi the first bleaching stage, should be used to minimize bleach
chemical addition.
Chlorine Dioxide Substitution
\
\
It is now common to substitute chlorine dioxide, a more powerful oxidizer than chlorine, in the first
bleaching stage, reducing the formation of chlorinated organics and reducing chemical consumption.
3-150 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
Enhanced Extraction ~ .
Use of oxygen, hydrogen peroxide, or both, to enhance the fist caustic extraction of the bleaching
process reduces chlorine use in subsequent bleaching steps, reducing chlorine consumption and
reducing the formation of chlorinated organics in the effluent.
Hypochlorite Elimination
While hypochlorite is an effective bleaching chemical, an excess of chloroform is generated in the
bleaching process and ending up in the effluent. Replacing hypochlorite with chlorine dioxide
minimizes chloroform generation and also lowers operating costs because chlorine dioxide is less
expensive than hypochlorite. (Often, the hypochlorite bleaching tower must be replaced with a new
chlorine dioxide tower, washer, and ancillary equipment, because chlorine dioxide is more corrosive
than hypochlorite.)
High Temperature/High Alkalinity Hypochlorite Bleaching
Some mills that use hypochlorite bleaching may not be able to totally replace this chemical because of
adverse effects on pulp viscosity. As an alternative, mills can reduce chloroform generation using a
high-temperature (70 to 80°C), high-alkalinity (pH of 12 to 13) hypochlorite bleaching. This destroys
the chloroform after it is generated, but before it is emitted to air or water.
Enzyme Bleaching
Xylanase enzymes partially hydrolyze zylan, the major bonding chemical between lignin and cellulose
in wood, making lignin removal easier. Addition of xylanase enzymes after brown stock washing or
oxygen delignification reduces or eliminates the need for chlorine bleaching. Several mills worldwide
have shown full-scale trial success.
Peroxide Bleaching
Hydrogen peroxide can be used to bleach pulp, with the addition of several preparatory steps. Since
peroxides react with metal ions to form hydroxyl radicals that can degrade cellulose, these metals
must be removed prior to peroxide bleaching. This can be accomplished using chelating agents
followed by a wash step. Where peroxide bleaching follows a chlorine compound bleaching process,
chelation is not necessary since the chlorine bleaching effectively removes the metals. Both kraft
mills and sulfite mills have shown success using peroxide bleaching, although the high cost of
peroxide as compared to chlorine has limited its application.
3-151 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
Totally Chlorine-Free Bleaching of Paper-grade Kraft Pulps
\
Using a combination of oxygen, ozone, enzymes, and/or peroxide, totally chlorine free (TCP)
bleaching is possible. Numerous mills worldwide have installed TCP bleach lines, although the lower
pulp brightness has limited its market. Several mills worldwide have shown to be capable of
producing high-brightness pulp using various TCP sequences, although brightness is still a problem
with many TCP mills. Not only is chlorine eliminated from the process, color, BOD, and COD in
the effluent are significantly lower. Also, less .water is discharged and less heat is lost.
Totally Chlorine-Free Bleaching of Dissolving Kraft Pulps
The EPA is not aware of any dissolving kraft mills worldwide that are using TCP bleaching, nor is
EPA aware of any successful laboratory studies to this effect..
Totally Chlorine-Free Bleaching of Dissolving Sulfite Pulps
The EPA believes that TCP bleaching is viable for dissolved sulfite mills, although, at present, no
U.S. mills use this technology. One mill in Austria has shown success (brightness of 90-92 ISO).
Totally Chlorine-Free Bleaching of Papergrade Sulfite Pulps
No mills hi the U.S. use TCP bleaching for papergrade sulfite pulps, although, at least ten mills
worldwide are using this technology. The bleaching stages at most of these mills include oxygen
delignification followed by peroxide bleaching.
Vent Controls
Caustic scrubbing of vent gases from bleach tower vents, washer vents, seal tank vents, and chlorine
dioxide production vents should be implemented to reduce emissions of chlorine and chlorinated
compounds.
3.5.1.4 Pulp Drying and Papennaking
Savealls
Many years ago, the paper industry considered white water recovery as a sacrifice of paper quality.
Today however, white water recovery is a standard practice. Savealls are used to recovery fiber and
fillers from mill white water. Drum filters, flotation devices, and disc filters are used in the industry,
although, disc filters are preferred because they use minimal space and can handle variable quality
and quantities of white waters. Filtrate can be used elsewhere in the process (i.e., initial filtrate can
be used in stock preparation and the later clear filtrate can be used in paper machine showers or other
plant operations). Separate savealls should be used for each paper machine producing different
3-152 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
quality paper to enhance the reusability of the white water. Problems that may arise from extensive
water reuse include plugging problems in shower heads (from long fibers) and deposit buildups from
suspended solids, and corrosion, scale, color, slime, and foaming from dissolved solids buildup.
Dissolved solid buildup can be controlled through pH control, use of corrosion resistant material, and
addition of biocides/slimicides to control growth.
Vacuum Pump Seal Water Cascade System
Cascading pump seal water from high- to low-pressure pumps in the paper press area of the mill can
reduce water consumption from this process by SO percent. This technology is less expensive than
cooling towers, but is limited to areas with cooler fresh water sources (i.e., northern states).
Vacuum Pump Seal Water Cooling Tower System
Use of a cooling tower for vacuum pump seal water can save a lot of water compared to using once-
through cooling water. Wastewater discharge is limited to occasional bleeding of cooling system
water to prevent over-accumulation of corrosion inhibitors and biological inhibitors. This system is
applicable to areas where cool fresh water is unavailable.
Steam Condensate Recovery
Steam condensate from pulp dryers and paper machines can be collected and reused to reduce boiler
feedwater treatment costs.
3.5.1.5 Solids Handling
Lime Slaker Grits and Green Liquor Dregs
Lime slaker grits and green liquor dregs can be collected, dewatered and used as additives for cement
manufacturing, reducing the amount of solid waste to be landfilled.
Power Boiler Ash
Ash from boilers can also be used as an additive for cement manufacturing or as a soil conditioner in
combination with wastewater treatment sludge.
3.5.1.6 Flow Reduction
Countercurrent Brown Stock Pulp Washing
Most chemical pulp mills use countercurrent washing systems. This technique reduces the amount of
fresh water needed for brown stock washing.
3-153 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
Screen Room Closure
Screen room wash water can be reused in the brown stock washers rather than being discharged to
wastewater treatment. Complete reuse of this wash water can reduce water use by 10-15 at an
integrated mill.
Recycling Evaporator Condensates :
Evaporator condensates from brown stock washing, screening, cleaning, and thickening can be steam
stripped and reused as a hot water feed. The overhead vapor stream can be incinerated, thereby
reducing air emissions.
Bleach Plant Countercurrent and Jump-Stage Pulp Washing
Countercurrent washing or jump-stage washing in the bleaching process reduces water usage.
Flotation Clarification (Deinking)
Washing of secondary fibers to remove ink uses large amounts of water to dilute the fibers prior to
screening or pressing. Clarification of the filtrate from this process allows this water to be reused as
dilution water in the washing process while also keeping the heat and chemicals used in the washing
process. Sludge generated by the clarification process can be pressed into a high solids cake.
Gravity Strainers with High-Pressure, Self-Cleaning Showers
For saveall filtrate to be reused in paper machine showers, fibers must first be removed. Gravity
strainers can be used on the clear filtrate to remove fibers of all lengths and protect against process
upsets that may cloud the clear filtrate. High-pressure, self-cleaning showers are commonly installed
with gravity strainers. These showers use much less water than low-pressure, high volume showers
and can replace all mill showers (e.g., headbox showers, wire showers, knockoff showers, grooved
roll showers, and roll and fabric cleaning showers). The self-cleaning nozzles make these showers
more amenable to recycled water.
Adequate Water Storage
Storage facilities to handle upsets, spills, diversions, and surges is critical to maintain optimum water
recycling and reuse. Where closed water systems are used, disinfection is often required to control
biological contamination (although chlorine and peroxide compounds act as excellent biocides). Also,
installation of a basin for diversion of lime mud slurries during process upsets and lime mud clarifier
maintenance can prevent disposal of lime mud.
3-154 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
3.5.2 TIMBER PRODUCTS PROCESSING
Internal control measures are procedures to reduce pollutant discharges at their origin. Appraisals of
plant waste production must first investigate the manufacturing cycle for any modification which can
reduce the waste flow and the concentration of waste constituents. Particular emphasis must be
placed on reducing those factors which present problems in treatment of the total waste stream. In
some instances, the reuse or recovery of materials from process solutions can offer favorable
economies which will at least partially offset the associated costs. The following in-plant controls
(most of which have been identified by EPA to achieve NSPS) are available for consideration
evaluated by the applicant when applicable:
• Raw Material Handling. Better raw material handling methods can be used, such as land
decking, or substituting an on-site log storage pond for storage in streams.
• High Pressure Sprays. Product rinse waters (e.g., from surface protection) can be reduced
through the use of high pressure sprays rather than overflow wash vats. Also, maintaining
the spray units under negative pressure with an exhaust vent to control aerosols can reduce
worker exposure and increase chemical recovery and reuse.
• Solids Screening. Solids should be screened from wastes before large quantities of water
enter the waste stream.
• Waste Heat Recovery. Waste heat from on-site power generation or steam boilers can be
used to heat water or dry wood.
• Efficient Plant Design. Construction of plants taking into account designs that will
maximize clean-up and maintenance efficiency.
• Water Reuse and Recycle. Numerous techniques for flow reduction have been
demonstrated in the industry, but the application of these techniques are site-specific. The
application of water reuse and recovery should be considered for each process operation
(with the goal of zero discharge of process wastewater). Recommendations for specific
controls are as follows:
Recycle process water in wet barking techniques and effluents from hydraulic barkers
(using microscreeners)
Reuse water 'for make-up in hot water vats and steam vats
Conserve water during the cleaning of veneer dryers by manually scraping the dryer
and blowing it out with air prior to the application of water
Recycle glue washwater lines and conserve water by increasing the frequency and
effectiveness of cleaning operations in plywood manufacturing plants
Recycle log washwater after settling
3-155 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
- Recycle cooling water through cooling towers or a cooling pond in hardboard dry
process operations
Reduce water usage during additive blenders cleaning by using dry cleaning techniques
- Reuse barometric condenser water or replacement of barometric condensers with
surface condensers in wood preserving operations
- Eliminate water discharges by land-decking during log storage
- Bundle and debark logs prior to wet storage
Reduce the volume of water sprayed during wet decking
- Reduce storage inventory to a minimum operating level
- Cover decks with plastic sheets or other materials to prevent pollution runoff
- Install special flow control systems to minimize the volume of water
Reduce storage time for preservation by close control of inventory in wood treating
industry
Reduce risk of handling by purchasing pre-dissolved or pre-mixed preservative
Further use of clean-up water as make-up water for straining and application of
preservatives and coating compounds.
• Minimize Storage Contamination. Storage piles should be protected and closely
monitored to minimize the introduction of contaminants that can degrade product, raw
material, or waste quality. Use of silos or buildings to house raw materials, products, and
wastes can also minimize contamination. Also, the storage of wood chips in tall cone-
shaped piles have shown to attract moisture at a lower rate than other configurations.
• Minimize Residual Storage Time. Residues should be processed, or disposed of in a
timely fashion to prevent decomposition of wood materials that generate a rich organic
leachate and will also maintain the market value of the residue.
• Stormwater Diversion. Stormwater should be diverted away from storage areas to
minimize contact with raw material, waste, or product materials. Moisture can increase the
rate of decomposition, generate leachate, reduce the market value of the wet material, and
increase the cost of using or disposing of the materials. Also, locating storage areas away
from sensitive receptors (e.g., lakes or streams) can further minimize the impact of any
releases.
• Install Storage Pads. Wood storage piles, including chips and sawdust, should be
contained on compacted earth, stone, or shale pads to prevent permeation into the
underlying soils, to minimize the impact from moisture, and to control aerobic activity.
3-156 September 1994
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EIA Guidelines for Pulp & Paper and Timber Overview of the Industry
Also, runon and runoff controls should be instituted to prevent storm water from contacting
the piles and for containing the stormwater that does contact the piles.
• Install Sprinkler System for Sawdust Storage. Installation of sprinklers that can be
manually operated (typically only during hot, dry, or windy conditions) can prevent adverse
air quality impacts from sawdust participates.
• Drippage Return. Drippage from surface protection should be returned to the treatment
tank for reuse, either by allowing to drip directly over the tank or by installing sloped drain
boards that capture the drippage for return to the treatment tank. Also, increasing the time
allowed for drippage and lifting the wood at slight angles to permit greater drainage also
minimizes raw material losses.
• Non-Chemical Surface Protection. Use of kiln drying or air drying of lumber can
eliminate the need for surface protection. Kiln drying is economical at larger mills where
large quantities of wood residue can be used to fire the kiln. Air drying methods are also
effective at larger mills that can maintain a large inventory (i.e., it may take up to nine
months to air dry wood) or at mills with a favorable climate. Also, air drying may not dry
the wood fast enough to prevent sapstaining.
• Replacement of Sodium Chloroformate Surface Protectors. Use of less toxic surface
treatment chemicals (e.g., iodo-propynyl butyl carbamate, dimethyl sulfoxide, sodium
azide, didecyl dimethyl ammonium chloride, sodium ortho-phenylphenate, and zinc
naphdienate) can reduce the generation of hazardous waste.
• Contaminated Equipment Replacement. Facilities that used chlorpfonnate surface
protection chemicals hi,the past may have to replace existing equipment to eliminate dioxin
contaminated residues.
• Air Curtain Exhaust System. Use of an air curtain exhaust system to control vapors from
wood panel hot gluing can significantly reduce air emissions from this process (i.e., 94
percent containment).
• Use Narrow Sawblades. Use of narrow sawblades reduces the amount of sawdust
generated, thereby reducing the amount of waste.
• Proper Finishing Spray Techniques. Furniture manufacturers applying solvent based
lacquers should practice proper spray techniques to maximize transfer efficiency (e.g., SO
percent spray overlap, spray gun perpendicular to product surface, triggering the gun at the
beginning and end of each pass, holding the gun 6-8 inches from the part, and use of high
volume, low pressure spray nozzles).
• Inventory Control. Proper purchasing and control of furniture finishing materials can
minimize overpurchase and eliminate the need for disposal of large quantities of out-of-date
materials.
• In-House Solvent Recovery. Installation of stills at furniture manufacturers to recycle
spent solvents can eliminate transportation and disposal costs of waste solvents. Recovery
can be enhanced by minimizing the number of solvents used, segregating different solvents,
3-157 September 1994
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Overview of the Industry EIA Guidelines for Pulp & Paper and Timber
keeping solvents free from waste and other contaminants, and using countercurrent solvent
rinsing.
• Wood Reutilization. Various wood wastes can be reformulated into saleable products.
For example,
Clean wood chips and off-specification wood cuts from lumbering operations can be
sold to pulp mills for use in papermaking
Sawdust, wood chips, and planer shavings can be used to manufacture particle board
Bark and wood chips can be used as hog fuel for on-site energy generation
Extruded wood chips and sawdust can be used to produce fire logs for use in domestic
fireplaces
- Wood chips and bark can be processed in a hammer mill to make mulch and bark
nuggets for landscaping and gardening
Planer shavings and sawdust can be sold to livestock fanners for use as animal bedding
or used in the field as a soil conditioner.
3-158 September 1994
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EIA Guidelines for Pulp & Paper and Timber Major Environmental Issues
4. MAJOR ENVIRONMENTAL ISSUES ASSOCIATED WITH THE PULP
AND PAPER AND TIMBER PRODUCTS PROCESSING INDUSTRIES
All pulp and paper and timber products for processing facilities produce by-products and waste
materials that need treatment or disposal. However, the characteristic waste materials generated by a
mill is dependent upon the combination of raw materials, processes, and the products manufactured.
Some of the waste materials contain hazardous and toxic constituents. For instance, wastewater
effluents from pulp and paper mills have been found to be major contributors of dioxihs to the aquatic
environment. Wood preserving operations, both active and inactive, have contributed to sediment and
ground water contamination. These problems have, or are, being addressed by EPA. The control of
dioxin releases from pulp, paper, and paperboard facilities are currently being addressed under the
Clean Water Act and the Clean Air Act. Wood preservers have already been addressed by the
Resource Conservation and Recovery Act, which has resulted in the better storage and application
techniques of wood preservation chemicals. This section discusses the environmental issues related to
the pulp and paper and timber products processing industries, including water quality and quantity, air
emissions, and solid waste issues. The pulp and paper and timber products processing industries are
discussed separately for these three media. Other environmental issues/impacts are common to both
the pulp and paper and timber products processing industry and are discussed together. Exhibits 4-1
and 4-2 are provided to give a broad perspective of the industry's potential impacts by showing 1992
SARA Title 313 release reports for pulp and paper and timber products, respectively.
4.1 IMPACTS ON WATER QUALITY AND QUANTITY
All pulp, paper, and paperboard and timber products processing facilities require the use of water.
However, water use, wastewater sources, and wastewater characteristics are dependent upon raw
materials, processes, and the products manufactured. The pulp and paper industry is the largest
industrial process water user in the United States. However, water used in the industry has decreased
approximately 30 percent since 1975, reflecting significant effort by the industry to reduce
consumption and increase wastewater reuse and recycle.
Pulp and paper mill and timber products processing effluent discharges contain toxic chemical
compounds (including toxic contaminants on EPA's list of priority pollutants and nonconventional
pollutants), as well as conventional pollutants such as biological oxygen demand (BOD) and total
suspended solids (TSS). These contaminants may alter aquatic habitats, impact aquatic life, and
subsequently adversely affect human health through the consumption of contaminated fish and water
(U.S. EPA, 1993).
Sections 4.1.1 and 4.1.2 present a summary of the volume of wastewater generated and the
characteristics of pulp and paper mill effluents and a review of their chemical characteristics and their
4-1 September 1994
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Major Environmental Issues
EIA Guidelines for Pulp & Paper and Timber
Exhibit 4-1. Chemicals Reported as Released and Transferred in 1992 by Faculties in SIC
Code 26 (Pulp and Paper Manufacturing)
CHEMICAL NAME
METHANOL
TOLUENE
HYDROCHLORIC ACID
CHLOROFORM
SULFURICACID
AMMONIA'
ACETONE
METHYL ETHYL KETONE
CHLORINE
ZINC COMPOUNDS
CHLORINE DIOXIDE
XYLENE (MIXED ISOMERS)
GLYCOL ETHERS
AMMONIUM SULFATE (SOLUTION)
1,1.1 -TRICHLOROETHANE
CYCLOHEXANE
DICHLOROMETHANE
FORMALDEHYDE
PHENOL
ASBESTOS (FRIABLE)
METHYL ISOBUTYL KETONE
TETRACHLOROETHYLENE
CATECHOL
VINYL ACETATE
ETHYLENE GLYCOL
N-BUTYL ALCOHOL
BARIUM COMPOUNDS
MANGANESE
AMMONIUM NITRATE (SOLUTION)
CHROMIUM COMPOUNDS
NAPHTHALENE
VINYLIDENE CHLORIDE
BUTYL BENZYL PHTHALATE
U.4-TRIMETHYLBENZENE
13- BUTADIENE
STYRENE
TRICHLOROETHYLENE
MANGANESE COMPOUNDS
POLYCHLORINATED BIPHENYLS
PHOSPHORIC ACID
ISOPROPYL ALCOHOL
RELEASES
nb/yrt
112559967
26052192
30607033
16554777
14447193
13844049
11941998
5493561
3549198
2568143
3063865
1767896
836701
1610504
1207489
951458
913833
666836
573165
760
537469
86830
295993
91968
234558
264603
186636
198255
201142
200538
159179
156145
139075
124236
133872
128673
116832
76562
0
98433
90039
IKANM-tKii
flbAr)
SS&s3SSS5&!£Se3t£sSKtt4*Si
53519526
5842679
144172
504402
310127
615615
1445475
2250339
125373
1078692
0
458704
850909
4275
64934
236806
200934
328846
76188
595790
37018
479540
267312
353386
199524
78195
137742
122000
36709
10696
1250
1500
13093
24137
0
2965
11312
49900
108300
7323
14450
TOTAL
(Ib/yr)
166079493
31894871
30751205
17059179
14757320
14459664
13387473
7743900
3674571
3646835
3063865
2226600
1687610
1614779
1272423
1188264
1114767
995682
649353
596550
574487
566370
563305
445354
434082
342798
324378
320255
237851
211234
160429
157645
152168
148373
133872
131638
128144
126462
108300
105756
104489
* FACILITIES
REPORTING
210
150
191
111
287
206
181
166
214
57
101
49
68
14
. 37V
10
6
33
58
3
12
12
126
11
32
17
13
3
22
8
5
1
5
6
2
4
3
6
1
154
3
•
4-2
September 1994
-------
EIA Guidelines for Pulp & Paper and Timber
Major Environmental Issues
Exhibit 4-2. Chemicals Reported as Released and Transferred in 1992 by Facilities hi SIC
Codes 24 (Wood Products) and 25 (Furniture Manufacturing)
CHEMICAL NAME
•J^E^^^^^^^^^^^^^^^^^^^^^W
TOLUENE
XYLENE (MIXED ISOMERS)
METHANOL
METHYL ETHYL KETONE
ACETONE
FORMALDEHYDE
METHYL 1SOBUTYL KETONE
N-BUTYL ALCOHOL
CREOSOTE
NICKEL COMPOUNDS
GLYCOL ETHERS
STYRENE
ETHYLBENZENE
CHROMIUM COMPOUNDS
AMMONIA
DICHLOROMETHANE
U.4-TRIMETHYLBENZENE
PHENOL
ISOPROPYL ALCOHOL (MANUFACTURING. S*
TRICHLOROETHYLENE
ZINC COMPOUNDS
PENTACHLOROPHENOL
MANGANESE
COPPER
NICKEL
TOLUENEDIISOCYANATE (MKED ISOMERS)
METHYL METHACRYLATE
TETRACHLOROETHYLENE
COPPER COMPOUNDS
CHROMIUM
POLYCHLORINATED BIPHENYLS
ARSENIC COMPOUNDS
MANGANESE COMPOUNDS
COBALT
ETHYLENE GLYCOL
METHYLENEBIS(PHENYLISOCYANATE)
CYCLOHEXANE
BARIUM COMPOUNDS
1 RELEASES
flb/vri
23158711
16878583
11798486
8256347
6032801
3964343
3243938
3474860
1136990
667
1627943
1808936
1273823
4648
1060080
904353
487378
411254
344655
243740
510
16000
2059
2240
1966
. 526
175410
141202
3796
2368
0
4268
67612
250
111813
87380
102550
25508
TRANSFERRS
(Ib/vrt
5345155
3483022
820100
1890609
1114094
193407
720951
241296
1708985
2207048
235353
18353
330769
1278668
66779
221501
415932
11733
5568
48336
227570
179720
188955
186769
175025
176050
300
22380
157582
145389
124075
114980
50965
117767
5566
22109
2541
76791
TOTAL
(Ibfvr)
. 28503866
20361605
12618586
10146956
7146895
4157750
3964889
3716156
2845975
2207715
1863296
1827289
1604592
1283316
1126859
1125854
903310
422987
350223
292076
228080
195720
191014
189009
176991
176576
175710
163582
161378
147757
124075
119248
118577
118017
117379
109489
105091
102299
# FACILITIES
REPORTING
553
401
271
288
204
108
125
146
65
8
76
20
48
278
33
28
25
32
11
9
9
40
14
21
16
7
3
3
273
25
1
279
7
3
12
46
4
12
4-3
September 1994
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Mqjor Environmental Issues EIA Guidelines for Pulp & Paper and Timber
potential effects on aquatic life and human health. Sections 4.1.3 and 4.1.4 provide similar
information on the timber products processing industry.
4.1.1 WATER QUALITY IMPACTS ASSOCIATED WITH PULP AND PAPER
Toxic and nonconventional pollutants of concern in pulp and paper mill effluent include acetone,
ketones, catechols, guaiacols, aldehydes, chloroform, methylene chloride, chlorinated phenols,
polychlorinated dibenzo-p-dioxins (PCDDs) and polychlorinated dibenzofurans (PCDFs), adsorbable
organic halogens (AOX), chemical oxygen demand (COD), and color. Of particular concern are the
organichlorides, a class of compounds known for their resistance to biodegradation, toxicity to aquatic
life, and long-range environmental transport, as well as the level at which they concentrate in the fatty
tissues of organisms through either bioaccumulation or biomagnification (via the food chain). The
effects of toxic and nonconventional pollutants on aquatic life vary with the species, concentration of
the chemical, and duration of exposure. However, a number of studies have linked toxic or other
biological effects in fish, wildlife, and humans to exposure to these contaminants from pulp and paper
mill effluents (U.S. EPA, 1993).
Conventional pollutants (e.g., TSS) can also cause site-specific environmental impacts. For example,
habitat degradation can result from increased suspended paniculate matter that reduces light
penetration and, thus, primary productivity or from accumulation of fibers that can alter benthic
spawning grounds and feeding habitat. Wastewater discharges exerting BOD on aquatic systems may
alter ecosystem structural complexity and functional relationships as populations of planktonic and
macrobenthic organisms decrease or die out while pollution- or anoxia-tolerant bacteria flourish (U.S.
EPA, 1993).
4.1.1.1 Pollutants of Concern
From 1989 through 1993 EPA conducted short-term sampling episodes at several pulp and paper mills
located nationwide. The samples were analyzed for chlorinated dioxins and furans; chlorinated
phenolics; volatile organics; semivolatile organics; pesticides/herbicides; metals; conventional
pollutants (BOD; and TSS); and nonconventional pollutants [(COD, AOX, and total organic halogens
(TOX)]. A total of 159 analytes were detected in samples from 11 mills. Of the 159 compounds
identified, 36 are priority pollutants, 28 exhibit high to moderate acute toxicity in aquatic life, 37 are
systemic toxicants in humans, 55 have been identified as carcinogens/mutagens, and 38 have drinking
water criteria values. Fifty-seven of the contaminants do not have aquatic toxicity data, and the
effects on humans are unknown for a majority of the analytes. During the last several years, many
mills have made process technology and/or operating changes in the bleach plant to reduce the
formation of 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD), 2,3,7,8-tetrachlorodibenzofuran (TCDF),
and other chlorinated pollutants (U.S. EPA, 1993). These changes have resulted in much-improved
effluents.
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EIA Guidelines for Pulp & Paper and Timber Major Environmental Issues
A cooperative long-term sampling effort involving both the industry and EPA was .undertaken from
1991 to 1992. The cooperative agreement provided for the sampling of eight bleaching mills.
Samples were collected to characterize the bleach plant effluent, plant exports (final effluent, pulp,
and sludge), and wastewater treatment system performance. This sampling effort detected 49 unique
analytes in the mills' wastewater during any point in the production process. Of the 49 contaminants
detected, 13 are priority pollutants, 13 have been identified as carcinogens/mutagens, and 11 have
drinking water criteria values. The effects on humans are unknown for 50 percent of the
contaminants (U.S. EPA, 1993).
The short-term and long-term sampling studies support previous data indicating that most of the
priority pollutants are not present in bleached kraft mill effluents. However, among the priority
pollutants that were detected include TCDD, chloroform, and methylene chloride, .as well as
pentachlorophenol and trichlorophenols (U.S. EPA, 1993).
-\
Based on an evaluation of the short-term and long-term sampling data, EPA has identified 26 organic
compounds of particular concern belonging to three chemical groups—(1) dioxins and furans, (2)
volatile organic compounds, and (3) chlorinated phenolics. Of these 26 contaminants, 6 are priority
pollutants, 11 are systemic human toxicants, 6 are human carcinogens, 24 are aquatic life acute
toxicants, and 26 are aquatic life chronic toxicants. Ambient water quality concentrations (for the
ingestion of organisms and water and organisms) for the protection of human health have been
established for 12 and 13 of the contaminants, respectively (U.S. EPA, 1993).
Examples of observed effects of some of these systemic human toxicants include reproductive and
developmental effects, liver toxicity, and fetotoxicity. All of the human carcinogens evaluated are
classified as probable, or B2 carcinogens (indicating an agent for which there is sufficient evidence of
carcinogenicity based on animal studies but inadequate data regarding its carcinogenicity from human
epidemiological studies) (U.S. EPA, 1993).
The primary focus of this aquatic life and human risk assessment is on the 26 organic compounds of
particular concern that are produced as a result of the pulp bleaching process. Due to a lack of
information on human health toxicity, only the following 13 pollutants were evaluated for their
potential human health impacts:
Acetone
2-Butanone
Chloroform
4-Chlorophenol
2,4-Dichlorophenol
2,6-Dichlorophenol
Methylene chloride
Pentachlorophenol
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Major Environmental Issues E1A Guidelines for Pulp & Paper and Timber
2,3,7,8-TCDD V • '
2,3,7,8-TCDF
2,3,4,6-Tetrachlorophenol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol.
A review of potential impacts on aquatic life and human health from exposure to 2,3,7,8-TCDD and
TCDF, as well as other toxic pollutants (i.e., priority pollutants and nonconventional pollutants) and
conventional pollutants, is presented below.
4.1.1.2 TCDD and TCDF
TCDD and TCDF were found to occur at every bleaching mill sampled .in EPA's 104-Mill Study.
The identification of these highly toxic chemicals, and other PCDDs and PCDFs, in pulp and paper
mill effluents where chlorine bleaching is used has led to numerous research efforts on the effects of
these chemicals on aquatic life.
Although much of the research has focused on the effects of TCDD and TCDF on the physiology, life
history, and community structure of fish populations, many of the same impacts have been observed
in other aquatic species, as well as in terrestrial species that rely on aquatic species as a food source
(e.g., fish, Crustacea, birds, humans, and other mammals). Both TCDD and TCDF have the same
toxic endpoints. However, the toxicity of TCDD to aquatic life is estimated to be two orders of
magnitude greater than that of TCDF, and the toxicity of TCDD to humans is estimated to be one
order of magnitude greater than that of TCDF (U.S. EPA, 1993). Therefore, die following
discussion is primarily focused on the nature and properties of TCDD.
Gross signs of TCDD toxicity in laboratory-exposed fish are species-dependent but may include
decreased growth rate, fin necrosis, cutaneous hemorrhage, hyperpigmentation, and edema. Fish in
the early life stages are more sensitive than adults to TCDD toxicity; thus, environmental levels of
TCDD may affect fish populations through reduced hatchability and the development of hemorrhages
and subcutaneous yolk sac edema (accumulation of fluid in the membrane sac attached to the embryo)
similar to blue-sac disease. Other impacts on fish exposed to TCDD have also been observed in
laboratory studies. TCDF has been shown to adversely affect survival, growth, and behavior of fish
(U.S. EPA, 1993).
The degree of toxicity of the contaminants found in pulp and paper mill effluents is directly related to
the bioavailability of these compounds and the potential of organisms to absorb the contaminants in
their tissues. Analyses of the tissues of invertebrates and fish downstream from mill effluents have
revealed a variety of xenobiotics (foreign compounds not produced by an organism) compared to
organisms from upstream sites. The highly hydrophobic organic chemicals, such as TCDD and
TCDF, become tightly bound to organic carbon in the water column and in sediment particulates and
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EIA Guidelines for Pulp & Paper and Timber Major Environmental Issues
may not be detected in water. Significant quantities, however, may be taken up by organisms from
ingestion of sediments or contaminated organisms. Body burdens of these compounds may reach
toxic levels (U.S. EPA, 1993).
Other PCDD and PCDF congeners may be more readily metabolized in animals, resulting in lower
accumulations and relatively low toxicities. Examination of representatives from simple food chain/
web organisms have revealed biomagnification of TCDD and TCDF from phytoplankton and
zooplankton through mussels or fish to waterfowl. Terrestrial wildlife that feed on organisms
exposed to pulp and paper mill effluents are also at risk for toxic and reproductive effects (U.S. EPA,
1993).
The persistent and lipophilic nature of TCDD facilitates its bioaccumulation hi the fatty tissues of
•
aquatic organisms, particularly fish. In spite of its relative insolubility, TCDD will achieve a steady-
state equilibrium between the water column and the sediments (U.S. EPA, 1993). Concentrations of
TCDD hi the water column can become elevated relative to the concentrations in the sediments
because of the redistribution of contaminated sediments resulting from bioturbation and scouring
(U.S. EPA, 1993).
TCDD is known to be extremely toxic to aquatic life, with concentrations as low as 0.038 ng/L
producing 45 percent mortality hi rainbow trout over a period of 28 days. Although fewer studies
have been conducted on TCDF, it is less toxic than TCDD. With respect to human health, TCDD is
listed as a probable carcinogen and is known to have adverse effects on reproductive capacity and
liver function; TCDF has also been identified as a probable carcinogen. More than 99 percent of the
human health-based risk and noncarcinogenic hazard from bleached kraft pulp and paper mill effluent
estimated hi this assessment is directly related to TCDD and TCDF (U.S. EPA, 1993).
4.1.1.3 Other Toxic and Nonconventional Contaminants
Of the 57 volatile organic compounds sampled in the short- and long-term sampling Studies,
chloroform, methylene chloride, methyl ethyl ketone (2-butanone), and acetone were detected at all of
the mills (U.S. EPA, 1993). Chloroform and methylene chloride are priority pollutants; methyl ethyl
ketone and acetone are nonconventional pollutants.
4.1.1.4 AOX
Chlorinated compounds can also be measured collectively as AOX, TOX, or TOC1 (total organic
chlorine). The preferred test measure analyzes AOX concentrations. Historically, the use of AOX as
a universal parameter was based on past environmental studies conducted in Sweden. Observations
from studies in the Gulf of Bothnia off the coast of Sweden indicated decreases in the density and
diversity of fish populations, located near the discharges of bleached kraft mills. In addition, fish
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Major Environmental Issues EIA Guidelines for Pulp & Paper and Timber
populations near bleached kraft mill effluents exhibited higher incidences of skin diseases, skeletal
deformities, fungal infections, fin erosion, smaller reproductive organs, enlarged livers, higher levels
of liver detoxification enzymes, and alterations in blood chemistry and blood cell ratios (U.S. EPA,
1993).
Several objections have been raised regarding the use of AOX as a regulatory parameter and the
conclusion that the abnormalities found in the Swedish studies could be attributed to the discharge of
ogranochlorines. The Canadian government initiated some independent studies to address these
objections. Fish collected from Canadian study sites were compared to fish collected from reference
sites located away from the mills. Fish collected near the mills were found to have smaller
reproductive organs, enlarged livers, higher levels of liver detoxification enzymes, and lower levels of
sexual hormones in the blood, and they took longer to reach maturity and had fewer secondary sexual
characteristics. From this evidence, the Canadian government concluded that the findings of the Gulf
of Bothnia study were not unique in that similar effects occurred in the fish communities located near
the Canadian bleached kraft mills (U.S. EPA, 1993).
4.1.1.5 Color
Color is also a nonconventional pollutant of concern associated with pulp and paper mill effluent
discharges. The intense brown color associated with pulp mill effluents is caused by lignin and its
derivatives, which are relatively stable compounds that degrade very slowly in biological treatment
systems and in receiving waters. These compounds adsorb light at wavelengths between 400 and 500
nanometers, the same spectral band that contains the two most important wavelength peaks for
chlorophyll "a" and a majority of the other accessory pigments in algae. The absorption of these
important wavelengths can inhibit photosynthesis and, consequently, primary production and can
diminish the visual cues necessary for organisms to feed or to reproduce. The effect of color on
primary productivity is dependent on the concentration of the effluent in the receiving stream,
seasonal variations, depth distributions, and distance from the discharge site. The overall impact of
color on aquatic algae is difficult to determine. Algae are capable of adapting over time to shifts in
light levels, or they may become metabolically inactive until they are dispersed out of the effluent
plume (U.S. EPA, 1993).
4.1.1.6 Conventional Pollutants
Prior to the focus on toxic contaminants found in bleaching pulp and paper mill effluents and their
effects on the aquatic environment, the regulatory community required mills to comply with BPT
criteria. As efforts have shifted to the priority pollutants, the efforts to define the chemical
compounds in pulp mill effluents responsible for causing environmental impacts at the community and
population levels have been greatly complicated by the presence of conventional pollutants such as
organic and nutrient loadings, and fiber and suspended solids. Such pollutants, in addition to the
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EIA Guidelines for Pulp & Paper and Timber Major Environmental Issues
pulping and bleaching chemicals, can alter the quantity of oxygen in the water column and sediments
through biological oxidative reactions and may be assessed by measuring the parameters biochemical
oxygen demand (BOD}) and chemical oxygen demand (COD) in the water column (U.S. EPA, 1993).
Suspended solids such as bark, wood fiber, dirt, grit, and other debris can cause long-term damage to
benthic habitats in freshwater, estuarine, or marine ecosystems. Solids increase water turbidity and
reduce the amount and quality of light present, reducing the growth of phytoplankton, algae, and
submerged aquatic vegetation. Their presence in the water column can interfere with respiration and
feeding by clogging and abrading delicate gill lamellae in organisms such as bivalve mollusks and
fishes. As solids settle out of the water column, they physically cover and smother stationary or
immobile benthic flora and fauna. Freshwater mussels are sensitive to sedimentation stress, and a
number of species in the United States are considered endangered and threatened. Feeding and
reproductive habitat of more mobile species, such as crustaceans and fishes, may also be eliminated as
the result of solids settling on the bottom. Sediment in the water column or deposited on the bottom
can also increase the oxygen demand on the water column as the result of microbial respiration and
chemical oxidation of compounds. The resulting oxygen levels (hypoxia) can cause lethal and
sublethal effects on sedentary benthic invertebrate populations or lead to the replacement of sensitive -
species by species more tolerant of reduced oxygen (U.S. EPA, 1993).
Fiber mats are a particular problem associated with pulping effluents. Decomposition of organic
matter in the debris reduces dissolved oxygen levels in the water column and may lead to anoxic
conditions in the sediment with accompanying buildup of methane, hydrogen sulfide, and other toxic
gases. In the Gulf of Bothnia study off Sweden, oxygen levels in the water column were reduced
nearest the effluent, particularly during the summer, with anoxia found in the fiber mat as the result
of increased bacterial biomass and activity. Reduced levels of oxygen may also complicate efforts to
assess chemical toxicity. Studies of fish indicated that decreased oxygen led to increases in the
toxicity of both organic and inorganic chemicals by about 1.5-fold, as a result of the increased rate of
flow across the gills at reduced oxygen levels. The effect on lethal and sublethal toxicities appeared
slight; however, this activity resulted in higher concentrations of pollutants in the vicinity of gill
membranes and accompanying higher diffusion of the toxics across the membrane (U.S. EPA, 1993).
Where effluent discharge rates are too low for color to inhibit photosynthesis or in streams that are
too shallow for color to significantly attenuate the light, algae production can be greatly enhanced by
the nutrients contained in the effluents. Orthophosphate, and paniculate nitrogen and phosphorus, the
most prevalent nutrients in pulp mill effluents, have been shown to enhance algal productivity at
effluent concentrations in the receiving stream of up to 25 percent. However, algal production begins
to rapidly decline at paniculate nitrogen and phosphorus effluent concentrations above 25 percent
(U.S. EPA, 1993).
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Major Environmental Issues EIA Guidelines for Pulp & Paper and Timber
Studies of fish populations in pulp and paper mill effluent receiving streams have shown that adverse
effects on the reproductive organs, livers, detoxification enzymes, and sexual hormones continue
following modernization of technologies. The principal sources of soluble BOD materials are the
black liquor and associated soluble materials from the pulp washing, volatile organics from the
condensate streams, and various additive (U.S. EPA, 1993).
4.1.2 WASTEWATER GENERATION—TIMBER PRODUCTS PROCESSING
Throughout the timber products processing industry, water is used in various ways and a variety of
wastewater streams result. Chapter 3 subsection 3.2.2 outlines the industry's major wastewater
sources and characteristics. The source and volume of wastewater depends on the type of processes
used at a facility and on the size of the facility. In general, wood preparation activities such as log
storage, log washing, and debarking generate wastestreams with high BOD and TSS. Wood
processing activities such as veneer and plywood, hardboard, wood preserving, and insulation board
contribute other pollutants including oil and grease, phenols, PAH, and metals.
4.1.3 WATER QUALITY—TIMBER PRODUCTS PROCESSING
The following subsections discuss the principal pollutants or pollutant indicators contained in
wastewater streams generated by the timber products processing industry. These pollutants often
interact with natural ecosystems to cause changes in the water quality of bodies of water receiving
effluent.
4.1.3.1 Biochemical Oxygen Demand (BOD)
The BOD of a wastewater stream estimates the dissolved oxygen that will be required for the
degradation of waste materials. Therefore, this pollutant parameter represents the potential of the
waste to reduce the dissolved oxygen levels of a body of water. It is possible to reach conditions
whereby all the dissolved oxygen in the water is used, resulting in anaerobic conditions and the
production of undesirable gases such as hydrogen sulfide and methane. The decrease in dissolved
oxygen can be detrimental to fish survival, fish growth, and the life of other aquatic organisms. A
total void of oxygen will result in the death of all aerobic aquatic inhabitants in the affected area.
Water with high BOD concentrations indicated the presence of decomposing organic matter and
associated increased bacterial concentrations that degrade water quality and the subsequent potential
use of the water. High BOD resulting from decaying organic matter increases algal blooms.
4.1.3.2 Total Suspended Solids (TSS)
TSS in wood-processing wastewaters include both organic and inorganic materials. The organic
fraction includes grease, oil, and wood-waste. These solids settle out rapidly, bottom deposits being
often a mixture of both organic and inorganic solids. Solids may be suspended in water for a time
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EIA Guidelines for Pulp & Paper and Timber Major Environmental Issues
and then settle to the bed of the receiving water. They may be inert, slowly biodegradable materials,
or rapidly decomposable substances. While in suspension they increase the turbidity of the water,
reduce light penetration, and impair the photosynthetic activity of aquatic plants.
Aside from any toxic effect attributable to substances leached out by water, suspended solids may kill
fish and shellfish by causing abrasive injuries, clogging gills and respiratory passages, screening out
light which alters plant food for fish, and by promoting and maintaining the development of noxious
conditions through oxygen depletion. Suspended solids also reduce the recreational/aesthetic value of
the water, especially the black lignin component of wood.
Some of the solids generated with wood processing plants can be removed readily by fine screening;
other solids settle readily hi clarifiers. When not removed, these solids can foul or plug pipes,
pumps, and other mechanical equipment.
4.1.3.3 Oil and Grease (O&G)
Oil and grease cause troublesome taste and odor problems even in small quantities. They produce
scum lines on water treatment basin walls and other containers and adversely affect fish and
waterfowl. Oil emulsions adhere to the gills of fish, causing suffocation, and taint the flesh of fish
that are exposed to waste oil. Oil deposits hi the bottom sediments of water can serve to inhibit
normal benthic productivity. Oil and grease also exert a demand on oxygen from the water in the
process of degradation.
Oil and grease levels which are toxic to aquatic organisms vary greatly, depending on the, type of
pollutant and species susceptibility. Further, the presence of oil hi water can increase the toxicity of
other substances discharged into the receiving waters.
4.1.3.4 pH (Alkalinity - Acidity)
The pH of a wastewater stream has an effect on corrosion control, pollution control, disinfection, and
the toxicity of other pollutants. Water with a pH below 6.0 due to the pressure of acid-producing
chemicals in solution hi the water corrodes waterworks structures, distribution lines, and household
plumbing fixtures. This can result in added iron, copper, zinc, cadmium, and lead to drinking water.
Low pH waters not only tend to dissolve metals from structures and fixtures but also tend to
redissolve or leach metals from sludges and bottom sediments. pH can affect the taste and smell of
water; at a low pH, water smells and tastes "sour." Extremes of pH or rapid pH changes will injure
or kill aquatic life. Even moderate changes from "acceptable" pH limits can harm some species.
Changes in water pH increase the relative toxicity to aquatic life. Metalocyanide complexes can
increase a thousand-fold in toxicity with a drop of 1.5 pH. The bactericidal effect of chlorine hi most
4.11 September 1994
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Major Environmental Issues EIA Guidelines for Pulp & Paper and Timber
cases lessens as the pH increases, and it is economically advantageous to maintain pH levels close to
5.5.
4.1.3.5 Chemical Oxygen Demand (COD)
The COD test measures pollutants more resistant to biological oxidation than does the BOD test.
These pollutants are of concern because of their continuing oxygen demand for degradation and the
potential associated health effects. Some pollutants measured by the COD test have been found to
have carcinogenic and mutagenic effects. The long life of these pollutants in the environment, the
difficulty hi removing them by commonly used systems of water purification, and the potential for
converting them by chlorination into even more hazardous materials magnifies their significance.
4.13.6 Phenols and Chlorophenols
Phenols
As a class of compounds, phenols are characterized by a benzene ring and a hydroxyl group, and may
have other functional groups attached to the benzene ring, such as chlorines. Phenolic compounds
may adversely affect fish by direct toxic action or by imparting an objectionable taste to fish flesh.
The toxiciry of phenols to fish increases as the dissolved oxygen level decreases, as the temperature
increases. As water hardness decreases, phenol appears to affect nerves, causing too much blood to
flow to the gills and to the heart cavity. It appears to have a toxic threshold from 0.1 to 15 mg/1.
^
The human ingestion of a concentrated phenol solution results in severe pain, renal irritation, shock,
and possibly death. A total dose of 2.5 grams may be fatal. Phenols can be metabolized and
oxidized in waste treatment facilities containing organisms acclimated to the phenol concentration in
the wastes.
Chlorophenols
Except where noted, the following information regarding Chlorophenols was taken from the document
Chlorophenote Wood Protection—Recommendations for Design and Operation (Environment Canada,
1983). ,
Chlorination of waters can produce odoriferous and objectionable tasting Chlorophenols which may
include o-chlorophophenol, p-chlorophenol, 2,6-dichlorophenol, and 2,4-dichlorophenol. Toxicity
data indicate that PCP is very toxic to a large number of fish and aquatic invertebrates (World Health
Organization (WHO), 1987). Chlorophenol compounds hi general interfere with the cellular
metabolism, leading to energy starvation. The acute toxiciry of these compounds is thus not very
selective hi their action with regard to different fish species. Some fish are more sensitive to
chlorophenol effects than others, though. Fish such as salmonids may be killed within a time frame
4-12 September 1994
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EIA Guidelines for Pulp & Paper and Timber Major Environmental Issues
of a few hours to days when exposed to pentachlorophenate (the ionic form a pentachlorophenol)
levels of 100 parts per billion (ppb). Exposures in the parts per million (ppm) range can induce death
within minutes. Any overflows or spills of wood preservatives, protectants, or wastes containing
chlorophenols could potentially cause fish or other aquatic life kills.
Long-term exposure to chlorophenols and chlorophenates may cause chronic effects in fish such as
growth retardation and reproductive interference. These effects may not be immediately detectable
and can occur at levels far below those causing acute effects. Studies have shown reduced growth
rates and lower food conversion efficiency in sockeye salmon due to long-term exposure to a
pentachlorophenate concentration of 1,7 ppb.
Both tetra- and pentachlorophenol are resistant to natural degradation in the environment, and may
accumulate locally, or migrate long distances without degrading. Under favorable (generally aerobic)
conditions, however, a variety of microbes can metabolize and degrade these chemicals at significant
rates (WHO, 1987). In the absence of biodegradation, the general chemical stability and persistence
of chlorophenols can result in the build up of high concentrations in aquatic organisms.
Chlorophenols generally concentrate in fish tissues to levels roughly 100 times greater than levels in
the water to which the fish are exposed.
Many of the chlorophenols found in wastes and formula at wood treatment and protection facilities are
chronic systemic toxicants (USEPA, Nov. 1990). As with fish, the effects of chlorophenols in
humans are mainly the result of the chemicals' interference with basic cellular respiration, or energy
production. Symptoms of non-fatal chronic exposures to pentachlorophenol in humans may include
muscle weakness, headaches, loss of appetite, weight loss, abdominal pain, and irritation of the skin,
eyes, and respiratory tract. Ingestion can also cause liver, kidney, and lung damage (USEPA, Nov.
1990). Because PCP does not accumulate appreciably in the body, chronic health effects are believed
to be the result of high levels of continued, long-term exposure. 2,4,6-trichlorophenol has been
classified as a level Bj carcinogen. Oral PCP doses of 29 ppm have been reported fatal to humans.
Phenols can be successfully oxidized at treatment facilities containing organisms acclimated to the
phenol levels in the wastes being treated. Further information on chlorophenol toxicity may be found
in Section 4.3.2.1.
4.1.3.7 Creosote and Polymicleated Aromatic Hydrocarbons (PAHs)
Both wood preserving and wood surface protection operations often have formulations and wastes
onsite containing significant concentrations of PAHs. Creosote is the generic term for a variety of
formulations used in preserving wood. Spills or accidental releases of these into water could result in
significant harm to both humans and natural systems. The USEPA listed certain wastes from wood
preservation facilities as hazardous in 1990 partly because of their concentrations of PAHs. - Toxicity
data for PAH constituents of concern showed that all were chronic systemic toxicants, and some were
4-13 September 1994
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Major Environmental Issues EIA Guidelines for Pulp & Paper and Timber
also carcinogens (USEPA, Nov. 1990). While the literature does not provide as much information
for the effects of PAHs on fish or other aquatic life as it does for chlorophenols, it is still very
possible that the properties of PAHs causing toxic effects to laboratory animals would have similar
effects on aquatic life. More detailed information on laboratory PAH toxicity can be seen in Section
4.3.2.2.
4.1.3.8 Temperature
Temperature is one of the most important and influential water quality characteristics. Temperature
controls species presence; it activates the hatching of young, regulates their activity, and stimulates or
suppresses their growth and development. It may have a lethal effect when the water becomes too hot
or becomes chilled too suddenly. Colder water generally suppresses growth and development,
whereas wanner water generally accelerates activities and may be a primary cause for aquatic plant
nuisances when other environmental factors are favorable.
Temperature also is a prime regulator of natural processes within the water environment. It governs
physiological functions in organisms and, acting directly or indirectly in combination with other water
quality constituents, affects aquatic life. These effects include chemical reaction rates, enzymatic
functions, molecular movements, and molecular exchanges between membranes within and between
the physiological systems and the organs of an animal.
Chemical reaction rates vary with temperature and generally increase as the temperature is increased.
The solubility of gases in water varies with temperature. Dissolved oxygen is consumed by the decay
or decomposition of dissolved organic substances and the decay rate increases as the temperature of
the water increases, reaching a maximum at about 30° C (86° F). The temperature of stream water,
even during summer, is below the optimum for pollution-associated bacteria. Increasing the water
temperature increases the bacterial multiplication rate when the environment is favorable and the food
supply is abundant. Dissolved oxygen, therefore, diminishes with increasing temperature.
Reproduction cycles may be changed significantly by increased temperature because this function of
reproduction takes place under restricted temperature ranges. Water temperature need not reach lethal
levels to decimate a species. Temperatures that favor competitors, predators, parasites, and disease
can eliminate a species at levels far below those that are lethal.
Food organisms consumed by fish are altered severely when temperatures approach 90° F.
Predominant algal species change, primary production is decreased, and bottom-associated organisms
may be depleted or altered drastically both in number and distribution.
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EIA Guidelines for Pulp & Paper and Timber Major-Environmental Issues
Synergistic actions of pollutants likewise are more severe at higher water temperatures. Domestic
sewage, refinery wastes, oils, tars, insecticides, detergents, and fertilizers more rapidly deplete
oxygen in water at higher temperatures, increasing the toxicity of each.
4.1.3.9 Dissolved Solids (DS)
In waters, the dissolved solids consist mainly of carbonates, chlorides, sulfates, phosphates, and
possibly nitrates of calcium, magnesium, sodium, and potassium, with traces of iron, manganese, and
other substances. Waters containing more than 4,000 mg/1 of total salts generally are considered unfit
for human consumption, although in warm climates such higher salt concentrations may be tolerated.
Waters containing 5,000 mg/1 or more are reported to be bitter and to cause bladder and intestinal
irritation. It generally is agreed that the salt concentration of good, potable water should not exceed
500 mg/1.
Limiting concentrations of dissolved solids for freshwater fish may range from 5,000 to 10,000 mg/1,
according to species and prior acclimatization. Some fish are adapted to living in more saline waters,
and a few species have been found hi natural waters with a salt concentration of 15,000 to 20,000
mg/1. While fish slowly become acclimatized to higher salinity they cannot survive sudden exposure
to high salinity. Dissolved solids also may influence the toxicity of heavy metals and organic
compounds to fish and other aquatic life, primarily because of the effect of water hardness on metals.
Water with total dissolved solids over 500 mg/1 has decreasing utility for irrigation. Dissolved solids
in industrial water can cause foaming in boilers and interfere with cleanness, color, or taste of
finished products. A high content of dissolved solids also tends to accelerate corrosion.
4.1.3.10 Phosphorus
During the past 30 years, a strong case has been made to support the belief that increasing growth of
aquatic plants is frequently caused by increasing supplies of phosphorus from runoff. Although
phosphorus is not the sole cause of lake and river eutrophication, it is the key element. If phosphorus
is the "limiting factor," an increase in this essential element allows plants to consume other nutrients,
thereby encouraging plant growth. :
When a plant population is stimulated until it becomes a nuisance, potential liabilities become
apparent. Dense populations of pond weeds are detrimental to swimming, boating, water skiing, and
fishing. Excessive plant growth has been associate with stunted fish as well as poor fishing. Plant
nuisances also emit noxious odors, impact tastes and odors to water supplies, reduce the efficiency of
industrial and municipal water treatment, impair aesthetic beauty, reduce or restrict resort trade,
lower waterfront property values, cause skin rashes, and serve as a breeding ground for insects.
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Phosphorus in the elemental form is toxic and subject to accumulation in an organisms much the same
as mercury. Colloidal elemental phosphorus will poison marine fish (causing skin tissue breakdown
and discoloration).
4.13.11 Ammonia
Ammonia is a common production of the decomposition of organic matter. Dead and decaying
animals and plants along with human and animal body wastes account for much of the ammonia
entering aquatic ecosystems. Ammonia exists in its non-ionized form only at higher pH levels and is
most toxic in this state. The lower the pH, the more ionized ammonia is formed and its toxiciry
decreases. Ammonia, in the presence of dissolved oxygen, is converted to nitrate (NO3) by nitrifying
bacteria. Nitrite (NO^, an intermediate product between ammonia and nitrate, sometimes occurs in
appreciable amounts when oxygen levels are low.
.\ *
i
Nitrates are potentially poisonous ingredients of mineralized waters, with potassium nitrate being
more poisonous than sodium nitrate. Excess nitrates cause irritation of the mucous lining os the
gastrointestinal trace and the bladder. In most natural water, the pH range is such that ammonium
ions (NH4+) predominate. However, in alkaline waters, which concentrations of nonionized
ammonia in undissociated ammonium hydroxide increase the toxicity of ammonia solutions. In
streams polluted with sewage, up to one-half of the nitrogen may be free ammonia, and sewage may
carry up to 35 mg/1 of total nitrogen. At a level of 1.0 mg/1 nonionized ammonia, the ability of
hemoglobin to combine with oxygen is impaired and fish may suffocate. Evidence indicates that
ammonia exerts a considerable toxic effect on all aquatic life within a range of less than 1.0 mg/1 to
25 mg/1, depending on the pH and dissolved oxygen present.
Ammonia can aggravate eutrophication problems by supplying nitrogen. The usefulness of some
lakes in warmer climates and others that are aging is quickly limited by the nitrogen available.
Increasing nitrogen will speed up plant growth and organic decay processes.
4.1.3.12 Copper
Copper salts occur in natural surface water only in tract amounts (up to about 0.05 mg/1) so that their
presence generally is the result of pollution. This is attributable to the erosive action of water on
copper and brass pipes, to industrial effluents, and to the use of copper compounds for controlling
undesirable plankton.
Copper is not considered to be a cumulative system poison for humans, but it can cause
gastroenteritis, with nausea and intestinal irritations, at relatively low dosages.
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The toxicity of copper to aquatic organisms varies significantly not only with the species, but also
with the physical and chemical characteristics of the water, including temperature, hardness, turbidity,
and. carbon dioxide content. In hard water, the toxicity of copper salts is reduced by the precipitation
of copper carbonate or other insoluble compounds. The sulfates of copper and zinc and of copper
and cadmium are synergistic in their toxic effect on fish. In softwater especially, eopper
concentrations less than 1 mg/1 have been reported to be toxic to many kinds of fish, crustaceans,
mollusks, insects, phytoplankton, and zooplankton.
4.1.3.13 Chromium
\
Chromium, in its various valence states, is an acute systemic toxicant, primarily affecting the skin and
mucous membranes. It can produce lung tumors when inhaled and induces skin lesions. Large doses
of chromates have ulcerous effects on the intestinal tract and can cause inflammation of the kidneys.
The toxicity of chromium salts to aquatic life varies widely with the species, temperature, pH, valence
of the chromium, and synergistic or antagonistic effects, especially hardness. Fish are relatively
tolerant of chromium salts, but food organisms for fish and other lower forms of aquatic life are
extremely sensitive. Chromium also inhibits the growth of algae.
Chromium can cause reduced growth or death of some agricultural crops. Adverse effects of low
concentrations of chromium on corn, tobacco, and sugar beets have been documented.
4.1.3.14 Arsenic
Arsenic normally is present in sea water at concentrations ranging from 2 to 3 mg/1 and tends to be
accumulated by oysters and other shellfish. Arsenic is a cumulative poison with long-term chronic
effects on both aquatic organisms and on mammalian species. It has been listed by the EPA as a
Class A carcinogen, meaning there is sufficient epidemiological evidence to confirm it is a human
carcinogen. A succession of small doses add up to a final lethal dose. It is moderately toxic to plants
and highly toxic to animals.
Severe human poisoning also, can result from 100 mg concentrations; 130 mg has proven fatal. As
arsenic accumulates in the body faster than it is excreted, it can build to toxic levels small amounts
absorbed from air, water, and food and concentrated in lung and intestinal walls.
Arsenic is a normal constituent of most soils, with concentrations ranging up to 500 mg/kg.
Although low concentrations of arsenates may stimulate plant growth, the presence of excessive
soluble arsenic in irrigation waters reduces the yield of .crops, primarily through destruction of
chlorophyll in foliage.
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4.1.3.15 Zinc
Occurring abundantly in rocks and ores and in its refined metal form, zinc is readily refined into a
stable pure metal. It is used extensively in galvanizing, alloys, electrical equipment, printing plates,
dye-manufacture, dyeing processes, and other industrial purposes. Some zinc salts (e.g., zinc
chloride and zinc sulfate) are highly soluble in water; thus, zinc might occur in many industrial
wastes.
Concentrations of zinc in excess of 5 mg/1 in water used for drinking causes an undesirable taste
which persists through conventional treatment. Zinc also can have an adverse effect on man and
animals at high concentrations.
In soft water concentrations of zinc ranging from 0.1 to 1.0 mg/1 have been reported to be lethal to
fish. The sensitivity of fish to zinc varies with species, age, and condition as well as with the
physical and chemical characteristics of the water. The presence of copper in water also may increase
the toxicity of zinc to aquatic organisms, but the presence of calcium or water hardness may decrease
the relative toxicity. As zinc sulfate has been found lethal to many plants, it could affect agricultural
crop production.
4.1.3.16 Fluorides
As the most reactive non-metal, fluorine is never found free in nature. It occurs as a constituent of
fluorite or fluorspar,'calcium fluoride, in sedimentary rocks, and also as of cryolite, sodium
aluminum fluoride, in igneous rocks. Owing to their origin only in certain types of rocks and only in
a few regions, fluorides in high concentrations are not a common constituent of natural surface
waters. They may occur in detrimental concentrations in local ground waters, however.
Fluorides in sufficient quantity are toxic to humans, doses of from 250 to 450 mg causing severe pain
or death.
There are numerous articles describing the effects of fluoride-bearing waters on dental enamel. These
studies lead to the generalization that water containing less than from 0.9 to 1.0 mg/1 of fluoride will
seldom cause mottled enamel in children; and for adults, concentrations less than 3 or 4 mg/1 are not
likely to cause endemic cumulative fluorosis and skeletal effects.
Chronic fluoride poisoning of livestock also has been observed in areas where water contained 10 to
15 mg/1 fluoride.
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4.2 IMPACTS ON AIR QUALITY
4.2.1 Am QUALITY IMPACT ASSOCIATED WITH PULP AND PAPER
The major air pollutants from pulp and paper operations include reduced sulfur compounds,
particulates, volatile organic compounds (VOCs), and various hazardous air pollutants (HAP). EPA
estimates that noncombustion processes in the pulp and paper industry emit approximately 170,000
Mg of hazardous air pollutants annually. Air emissions of 1-butanone (MEK), 2-propane,
chloroform, hexane, methanol, and toluene comprise the majority of HAP emissions. Some of these
pollutants are known probable human carcinogens (chloroform), while others have been linked to
causing respiratory and other health problems in humans or animals (U.S. EPA, 1993).
Reduced sulfur compounds are associated with the kraft pulping process, and are generated from
chemical reactions of sodium sulfide that occur in the initial kraft cook (U.S. EPA, 1993). The
reduced sulfur compounds are often identified as the most apparent air pollutant and of greatest
concern to individuals because of its strong odor. Because certain sulfur compounds have low odor
thresholds, odors from uncontrolled paper milling operations can be detected many miles from the
mill sources. Kraft mill odor has resulted in loss of sleep, loss of appetite, nausea, and reduced
enjoyment of property. These nuisance factors may also lower personal amenity values and
community economics (Wapora, 1979).
VOCs are a broad class of organic gases such as vapors from solvents and gasoline, In the pulp and
paper industry, VOCs are generated from the complex reactions of lignin, carbohydrates, and
extractives in the pulp furnish. VOC emissions are of concern because they chemically react with
nitrogen oxide in the atmosphere to form harmful ground-level ozone, or. smog. Ozone has been
shown to be responsible for respiratory problems and premature aging of the lungs. Ozone has also
been linked to causing crop damage (U.S. EPA, 1993).
The major source of particulates are fly ash and bottom ash from power boilers and chemical
recovery furnaces. Fine particulates are a concern because they tend to settle from the atmosphere
and might be associated with more harmful health impacts (U.S. EPA, 1993). The health effects of
paniculate matter on inhabitants of small communities are not well established. However, low
ambient concentrations are desirable for economic and aesthetic benefits as related to visibility,
soiling, corrosion, and other adverse effects (Wapora, 1979).
4.2.2 Am IMPACTS ASSOCIATED WITH TIMBER PRODUCTS PROCESSING
Given that many of the compounds identified in the 1992 SARA Title 313 release reports (see Exhibit
4-2) are VOCs, hazardous air pollutants, or both, the wood products industry is a potentially
significant source of air pollution. Air emissions will vary for any given facility, depending on the
particular activities and processes carried out. The major sources, however, may include emissions
v
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from onsite power generation, the various pathways stemming from the use of solvents for cleaning
and formula preparation, and spills and accidental releases. Brief discussions of these sources are
included below, as well as sources specific to particular sub-sector operations. Following this is a
section discussing the major environmental impacts associated with each type of emission:
4.2.2.1 Emissions From Onsite Power and Steam Generation
On-site power and steam generating operations combusting wood residues or wood residues
supplemented with auxiliary fuels such as coal, oil, gas or tire-derived fuels are common in the wood
products industry. Particulates are generally an emissions concern, although often less of a problem
for the cleaner, drier wood waste produced at furniture manufacturing operations (Wapora, 1981).
Depending on the particular fuel mixture and process, combustion activities can emit sulfur dioxide
(SO^, nitrogen oxides (NO,), carbon monoxide (CO), and VOCs such as phenols and formaldehyde
as well. Wood wastes and other residues from finishing operations in the plywood and reconstituted
panels industries are apt to contain formaldehyde and phenol-formaldehyde resins, and are thus prone
to emit more of these contaminants upon combustion than "cleaner" wastes, such as untainted
sawdust, planer shavings or bark. Combustion of fuel mixtures containing coal, fuel-oil, or tire-
derived fuels emit more trace metals such as chromium, zinc, lead and cadmium, as well as more
sulfur dioxide (NCASI, July 1985). Some degree of increase in dioxin emissions is also to be
expected from such fuel mixtures.
4.2.2.2 Emissions From Solvent Use
Solvents are used in the wood products industry for cleaning equipment, machinery and other surfaces
of various residues and build-up. Solvents are also used by the wood preserving sector to prepare
pentachlorophenol (PCP) and creosote based preservative formulae. Solvents include methanol and
other alcohols, toluene, xylenes, methyl ethyl ketone, acetone and benzenes.
Because these compounds are VOCs, they are quick to volatilize on exposure to air. Sources include
the following:
• Cleaning of machinery and other surfaces.
• Solvent bearing rags.
• Leaks from solvent or solvent-based preservative containers.
• Leaks from pipes, flanges and pumps transporting solutions or wastewater containing
solvents.
• Volatilization from wastewater or solid waste storage areas such as lagoons or evaporation
towers.
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EIA Guidelines for Pulp & Paper and Timber Major Environmental Issues
• The opening and closing of wood preserving retort doors.
• Volatilization from drying creosote or PCP-treated wood.
• Any spill of solvent or solvent-bearing formula.
4.2.2.3 Reconstituted Panel and Plywood Manufacturing
Participates and VOCs are the air pollutants of concern during the manufacture of reconstituted panels
and plywood. Particulates are emitted during plywood and panel drying, cutting, and sanding
operations. VOCs are a concern during the drying and pressing operations. Both the thermal
decomposition of wood and the binding resin components contribute VOCs. Formaldehyde may be of
particular concern due to its presence in wood adhesives. Studies have shown the mass of
formaldehyde and VOCs emitted during drying of resinated wood, pressing, and product drying is
partly a function of the amount of adhesives used, the phenol/formaldehyde content of the adhesives,
the temperature of the pressing and drying stages, and the press residence time (NCASI, June 1986;
U.S. EPA, April 1991).
4.2.2.4 Hardboard Tempering
Fumes of acrolein stemming from aldehyde use can be emitted during the hardboard tempering
process. Components of any oils or solutions employed during tempering will also be emitted.
4.2.2.5 Spills and Accidental Releases
Spills of solvents, formaldehyde/phenol-formaldehyde resin, creosote or PCP based preservatives,
petroleum products from ancillary areas, or any volatile containing material or waste can all result in
emissions of VOC's and hazardous air pollutants. Blow-but vents or off-gassing from process
chambers and equipment are also potential sources of sudden, large releases of pollutants as well.
4.2.3 POTENTIAL IMPACTS OF EMISSIONS
4.2.3.1 Particulates
The primary effect of particulates is one of nuisance. When released in sufficient amounts,
particulates can cause reduced visibility, corrosion and wear of equipment, and soiling of surfaces
(Wapora, 1981). The settling out of finer particulates may cause more harmful health impacts, but
the exact effects are not well established (U.S. EPA, 1993).
4.2.3.2 Sulfur Dioxide and Nitrogen Oxides
For the last decade or so the main concern over these pollutants has been their tendency to act as
precursors for acid rain. Through atmospheric reaction, sulfur dioxides and nitrogen oxides can be
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Major Environmental Issues EIA Guidelines for Pulp & Paper and Timber
transformed into sulfuric and nitric acid, respectively. Effects of acid precipitation include
acidification of soils, surface waters and direct damage to crops and foliage, as well as deterioration
of buildings, statues and metal structures. Aquatic life such as fish and benthic macroinvertebrates
can be particularly sensitive to reduced pH.
Nitrogen oxides also contribute to air pollution by reacting in the atmosphere to induce the formation
of ozone. Ozone, an oxidant, is believed to cause respiratory problems, and has been linked to crop
damage (U.S. EPA, 1993). This ozone-precursor action of nitrogen oxides prompted Congress to
mandate more stringent regulation of their sources under the 1990 Clean Air Act Amendments.
4.2.3.3 VOCs and Hazardous Air Pollutants
A significant proportion of the potential emissions from wood products facilities are VOCs and
hazardous air pollutants. These chemicals include benzene, formaldehyde, methyl ethyl ketone,
methanol, toluene, catechol, cresols, naphthalene, aldehydes, and acrolein. Acrolein vapors have
irritating effects on the eyes, and have a characteristically pungent odor (Wapora, 1981). Many of
these chemicals were reported released in large quantities in 1992 (U.S. EPA, 1994). Many are
known or suspected carcinogens and mutagens.
The impact of VOC emissions depends to an extent on their volatility. The semi-volatile, or less
volatile VOCs often condense upon release to the atmosphere to form a bluish aerosol haze (Wapora,
1981). The more volatile organics remaining in the gas phase are a problem because they tend to
react photochemically with other atmospheric chemicals to form ground-level ozone. The tendency of
VOC's to act as ozone precursors, combined with widespread ozone pollution nationwide, has
prompted more stringent regulation of VOC sources under amendments to Clean Air Act.
4.3 SOLID WASTE MANAGEMENT IMPACTS
4.3.1 SOLID WASTE MANAGEMENT ISSUES ASSOCIATED WITH PULP AND PAPER
RCRA land disposal restrictions are applicable to the pulp and paper industry because the industry has
ignitable or corrosive wastes at the point of generation, and at some facilities the waste is
subsequently landfilled. There are no published studies on the specific effects of ground water
leaching from the land disposal of pulp and paper wastes. However, there is enormous literature on
the use of treated and untreated effluents for irrigation purposes. During the years in which storage
ponds have been used for liquid wastes in areas of highly pervious soils, no adverse incidents
attributable to seepage have been reported. In addition, one non-integrated paper mill in Pomona,
California has used its effluents for direct ground water recharge (Wapora, 1979).
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EIA Guidelines for Pulp & Paper and Timber Major Environmental Issues
4.3.2 SOLID WASTE MANAGEMENT ISSUES ASSOCIATED WITH TIMBER PRODUCTS PROCESSING
Impacts arising from solid waste management depend on the effectiveness of storage, handling,
treatment, and disposal activities. Like pulp and paper wastes, some residuals associated with the
timber products processing industry could negatively impact the environment if not properly managed.
Potential impacts include contamination of soil, surface water, ground water, and air; and
deterioration of human, animal, plant, and ecosystem health. Solid wastes associated with the timber
products industry include residuals from wood preserving operations, surface protection operations,
gluing operations, process wastewater treatment, air pollution control scrubber water treatment, and
contaminated soil.
Solid wastes generated by the wood preserving processes which use pentachlorophenol, creosote,
and/or inorganic preservatives pose the greatest potential threat to the environment. In 1991, EPA
added these wastes to the list of hazardous wastes from nonspecific sources. This decision was based
on findings that toxic constituents are detected in wood preserving wastes at levels that far exceed
health-based levels of concern and that projected ground water concentrations resulting from
mismanagement of these wastes exceeded established Agency health-based levels (EPA, 1990).
Investigations of many wood preserving plants revealed that toxic organic constituents of wood
preserving wastes are present in ground water, surface water, and soil.
Some of this contamination occurs because of spills or inappropriate materials management in process
or storage areas. However, most of this contamination is attributed to the practice of storing treated
wood in open storage yards where excess preservative drips from the wood or is washed away by
rain. The drippage and contaminated rainwater may be allowed to run onto the ground, collect in
ditches or ponds, or run into nearby surface water contributing to soil, surface water, and ground
water contamination.
Following is a description of the major classes of pollutants of concern.
4.3.2.1 Chlorophenols
Based on toxicity data, all the chlorophenols of concern are chronic systemic toxicants. One of them,
2.4.6-trkhloropfaenol, is Class B2 carcinogen (probable human carcinogen based on animal toxicity
data) with a Risk Specific Dose (RSD) of 1.8 x 103 ppm. The RSD estimates an increased cancer
risk of 1 in 1 million. It has caused lymphomas, leukemias, and hepatocellular carcinomas or
adenomas hi rats and mice, and has been reported to be weakly mutagenic. A Reference Dose (RfD)
is an estimated of a daily exposure that does not appear to increase the risk of deleterious effects
during a lifetime. An RfD of 1 ppm has been assigned to 2,3,4,6-tetrachlorophenol, supported by
subchronic oral and reproductive studies in rats. Increases in liver and kidney weight and centilobular
hypertrophy were observed in gavaged rats dosed with 99-percent pure 2,3,4,5-tetrachlorophenol.
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Major Environmental Issues EIA Guidelines for Pulp & Paper and Timber
Pentachlorophenol also has an RfD of 1 ppm and is highly toxic to humans. It causes contact
dermatitis, visual damage, and on ingestion, lung, liver, and kidney damage. Inhalation results in
acute poisoning centering on the circulatory system with accompanying bean failure. Oral doses of
29 ppm have been reported to be lethal to humans. Data from a recent National Toxicology Program
report provide evidence that pentachlorophenol may also be a carcinogen (McConnell, 1988).
4.3.2.2 Polvnudear Aromatic Hydrocarbons
Toxicity data on the polynuclear aromatic hydrocarbon constituents of concern reveal that all are
chronic systematic toxicants while some are also carcinogenic. One polynuclear aromatic
hydrocarbon, naphthalene, is currently being tested by EPA's Office of Solid Waste and has an
unverified RfD of 14 ppm. Benz(a)anthracene is a Class Bj carcinogen; the RSD by ingestion, at
the 10* risk level is 1.1 x 10"3 ppm. A gavage study showed elevated increase of lung adenomas and
liver hepatomas in male mice: A bladder implant study reported significant increases in bladder
carcinomas. Subcutaneous administration studies reported a high incidence of local sarcomas of both
sexes. Repeated dermal application of benz(a)anthracene to mice produced a dose-related increase in
malignant skin tumors.
Benzo(k)fluoranthene is a Class B2 carcinogen; its RSD, by ingestion, at the 104 risk level is 0.004
ppm. Available toxicity data (U.S. EPA, August 1987) demonstrate that it is carcinogenic to animals
and, according to the International Agency for Research on Cancer (IARC), benzo(k)fluoranthene is a
probable human carcinogen. Benzo(k)fluoranthene has been evaluated in dermal studies with mice, in
mouse-skin initiation-promotion assays using tetradecanoylphorbol acetate (TPA) (CAS #16561-29-8)
as a promoter, and in a subcutaneous injection study of mice. It has been shown to be active as an
initiator and produced injection site sarcomas in the subcutaneous study. Benzo(k)fluoranthene has
also been shown to be mutagenic in standard mutagenicity tests with Salmonella typhimurium strains
TA100 and TA98.
Benzo(a)pyrene is also a Class Bj carcinogen; its RSD, by ingestion, at the 10* risk level is 3 x 10"6
ppm in drinking water. Benzo(a)pyrene is both a local and a systematic carcinogen, producing
tumors in rats, mice, hamsters, guinea pigs, rabbits, and monkeys following oral, inhalation, or
dermal exposure. The tumors observed were as follows:
• Stomach tumors in mice and rats via feeding
• Lung adenomas in mice via feeding
• Lung tumors in rats and hamsters via intratracheal instillation
• Skin tumors hi mice, rates, and rabbits via skin painting
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• Local tumors in mice, rats, guinea pigs, monkeys, and hamsters via subcutaneous and/or
intramuscular injection.
i •
A few cases are available regarding the direct carcinogenic effects of benzo(a)pyrene on humans. In
an experimental application of benzo(a)pyrene to exposed and unexposed skin of patients, and in an
accidental exposure to benzo(a)pyrene, benign and reversible skin lesions were observed which were
thought to be potentially precancerous. While there have been no epidemiologic studies in human
populations exposed to benzo(a)pyrene alone, clear association between exposure and occurrence of
lung cancer has been shown for several mixtures of polynuclear aromatic hydrocarbons containing
benzo(a)pyrene. These mixtures include cigarette smoke, roofing tar, and coke oven emissions.
However, from this information it is not possible to conclude that benzo(a)pyrene is causally
associated with lung cancer.
Dibenz(a,h)anthracene is a Class Bj carcinogen. Its RSD, by ingestion, at the 104 risk level is
7 x 10"7 ppm. Via various routes of exposure, dibenz(a,h)anthracene has increased the occurrence of
cancer in various strains of mice. Dibenz(a,h)anthracene administered in drinking water increased the
frequency of pulmonary adenomas, and carcinomas of the lung, hemangioendotheliomas and
t
mammary glands. After dermal application, papillomas, and carcinomas of the skin and mammary
tumors were observed. Finally, a single subcutaneous injection of dibenz(a,h)anthracene caused a
single subcutaneous injection of dibenz(a,h)anthracene caused a significant increase in subcutaneous
sarcomas in male mice.
Indeno(l,2,3-c,d)pyrene is a Class C carcinogen, which means that only limited evidence of its
carcinogenicity exists from animal data; it has an RSD of 0.002 ppm. Specifically, skin carcinomas
and papillomas in mice have resulted from subcutaneous injection of and skin painting with
indeno( 1,2,3-c,d)pyrene.
4.3.2.3 Inorganics
Each of the inorganic constituents of concern (chromium, lead, and arsenic) has a Maximum
Contaminant Level (MCL) of 0.05 ppm. Chromium compounds are acute systemic toxicants, mainly
affecting the skin and mucous membranes. Lead is an accumulative poison; it can cause a number of
human physiological effects including kidney damage and reproductive disorders. EPA classifies
arsenic as a Class A carcinogen (there is sufficient evidence from epidemiological studies to confirm
that it is a human carcinogen.
At present, the collective evidence for an etiological role of inorganic arsenic in human cancers is
strongest for cancers of the skin and lungs. Cancer and possible precancerous lesion-producing
inorganic arsenic exposures have been demonstrated in both occupational populations, such-as copper
smelters, pesticide manufacturers, and agricultural workers, and in nonoccupational populations using
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Major Environmental Issues EIA Guidelines for Pulp & Paper and Timber
arsenical drugs or consuming arsenic-contaminated drinking water and/or food. An. excess mortality
in respiratory cancer has been noted among smelter workers and among workers engaged in the
production and use of arsenical pesticides. Most of the available information on the association and
use of arsenic with skin cancer has involved nonoccupational populations. In humans, chronic oral
exposure to arsenic induces a sequence of changes in skin epithelium, proceeding from
hyperpigmentation to hyperkeratosis characterized as keratin proliferation of a varicose nature, and
leading in some cases to late onset of skin cancer.
4.3.2.4 PCDDs and PCDFs
Refer to Section 4.1 for a presentation of the impacts of these constituents of concern.
i
4.4 ISSUES RELATED TO SITING AND CONSTRUCTION
*
Site preparation and construction for large, complex facilities includes some degree of land
disturbance. In the first stage of the construction activity, land is cleared and prepared for the storage
of building materials and for the building sites themselves. For very large facilities, portable concrete
plants may be located onsite.
Site preparation and construction alters habitats and generates construction pollutants. The extent to
which the habitat is affected by site clearing and grading depends on the extent to which natural
ecosystems were previously disturbed. Conversion of previously undisturbed areas results in greater
changes than conversion of an industrial site. The removal of native vegetation removes the
protective cover, food sources, nesting, and breeding areas for many species. Fugitive dust emission
may increase and so may the rate of runoff following precipitation events. Barren ground increases
the volume of water that must be carried by local streams and increases stream-bank erosion and
downstream migration of suspended and dissolved solids. The extent of these types of impacts are a
function of site-specific conditions. Therefore the applicant must consider the capacity of the soils
and geologic formations to accommodate raw material and waste storage areas, along with other
potentially limiting site features. Problems that would require special considerations are:
Soil characteristics including: stability, infiltration rate, permeability, and erodability
Slope steepness
Proximity to wetlands, farmlands, floodplains, wild and scenic rivers
Presence of endangered or threatened species, or their habitat
Existence of important archaeological, historical, or architectural cultural resources
Other environmentally sensitive or important site features.
4.5 SOCIO-ECONOMIC ISSUES
Pulp, paper, and paperboard facilities usually are very large complexes. Timber products facilities
vary from very small to very large. The construction and operation of a new facility may cause land
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EIA Guidelines for Pulp & Paper and Timber Major Environmental Issues
use, economic, and social changes. To minimize potentially adverse effects, an applicant should
evaluate the types of changes that may occur. The importance of these changes usually depends on
the size of the community where the facility is to be located, the significance of the changes being
greater near a small rural community than near a large urban area. This due to the fact that the small
rural community is more likely to have a nonmanufacturing economic base and a lower per capita
income, fewer social groups, a more limited socioeconomic infrastructure, and fewer leisure pursuits
than large urbanized areas. However, there are situations where changes in a small community may
be insignificant, while a more urbanized area may be significantly impacted. For example, a small
community may have had a manufacturing (or natural resource) economic base that has declined.
Consequently, such a community may have a high incidence of unemployment and a housing surplus.
Conversely, rapidly growing urban areas may have difficulty in providing the labor force and services
required for an expanding industrial base.
Often the rate at which changes occur is an important determinant of the significance of the changes.
When preparing the environmental information document (EID), the applicant should clearly
distinguish between those changes caused by the construction of the facility and those resulting from
its operation.
Construction-related changes could be substantial and are usually temporary. During the construction
phase, the impact on the community will be greater if construction workers are hired from outside the
community when unemployed workers are available from within the community. The applicant
should evaluate the potential impacts on the community caused by the construction of the facility.
• Creation of social tensions
• Short-term expansion of the local economy
• Increased traffic congestion and noise from construction traffic and workers
• Increased short-term demand on community services, including: housing, schools,
recreational facilities, police protection, medical care, energy, and water supply.
Various methods of reducing potential budgetary shortfalls on local communities during the
construction phase should be addressed. For example, the company could build the housing and
recreational facilities and provide the utility services and medical facilities for its imported
construction force.
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Major Environmental Issues EIA Guidelines for Pulp & Paper and Timber
Operation-related changes may or may not be substantial, but are permanent in nature. When
preparing the BID, the applicant should evaluate at least the following potential impacts:
• Increased land consumption and rate of land development
• Land use pattern and compatibility changes
• Economic base multiplier effects
• Increased tax base
• Population increases and composition changes
• Reduced unemployment
• Loss of agricultural land, forested areas, and environmentally sensitive areas
• Increased demand for community services, including: housing, schools, recreational
facilities, police protection, medical care, energy, water supply, sewage treatment, and solid
waste disposal.
A community may benefit socially and economically from the operation of a new facility. Socially,
an increased tax base may allow for more diverse and higher quality services to accommodate the
interests and needs of the growing community. Conversely, the transformation from a small village
into a larger community may be regarded as an adverse change by some of the current residents.
Economically, an increased tax base in generally viewed as a positive effect. The revenue from taxes
is usually adequate to support the additional infrastructure required by the families moving into the
community. In addition, the spending and re-spending of the earnings of these employees has a
multiplier effect on the local economy.
The applicant's framework for analyzing the socioeconomic impacts of a new facility must be
comprehensive. Most of the changes that might occur can and should be measured to assess the full
potential costs and benefits.
Within the past decade, it has become apparent that environmental impacts do not affect all people
equally. Executive Order 12898 directed each Federal agency to "develop an agency-wide
environmental justice strategy . . . that identifies and addresses disproportionately high and adverse
human health or environmental effects of its programs, policies, and activities on minority populations
and low-income populations." The applicant should provide sufficient demographic data to evaluate
whether potential environmental equity issues exist so that mitigation actions can be implemented.
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EIA Guidelines for Pulp & Paper and Timber Major Environmental Issues
4.6 AESTHETICS
The exterior design of mills will be determined largely by the processes and the equipment employed.
Digesters and recovery plants require height and paper machines require breadth. Mill capacity is
another issue that will influence overall size. The intrusive size of pulp mills is heightened to some
degree by moisture plumes emanating from their recovery systems and bark burning operations, as
well as cooling towers. These opaque plumes are not harmful but can be seen for some distance.
(Wapora, 1979). Stack height, location, and configuration can influence the dispersion of plumes.
Interference with visibility at the proposed mill can be alleviated by giving careful attention to
prevailing winds, the proposed mill site, and major roads.
Depending upon the capacity, timber product facilities can be small operations or they can be very
large. Exterior design will be dictated by the process and equipment employed. Locating mills out
of view and away from major roads is a primary consideration in any area, but the selection of other
mitigating factors is site specific. Mill planners must consider minimizing landscaping disruption
along with convenience to raw materials, water supplies, and markets (Wapora, 1979).
The applicant should consider the following factors to reduce potential aesthetic impacts:
• Existing Nature of the Area. The topography and major land uses in the area of the
candidate sites are important. Topographic conditions and existing trees and vegetational
visual barriers can be used to screen the operation from view. A lack of topographic relief
and vegetation would require other means of minimizing impact, such as regrading or the
planting of vegetation.
• Proximity of Parks and Other Areas Where People Congregate for Recreation and
Other Activities. The location of public-use areas should be mapped and presented in the
BID. Representative views of the mill site from observation points should be described.
The visual effects on these recreational areas should be described in the BID in order to
develop the appropriate mitigative measures.
• Transportation System. The visual impact of new access roads, barge docking, and
storage facilities on the landscape and waterfront should be considered. Locations,
construction methods and materials, and maintenance should be specified.
4.7 NOISE
The major source of noise pollution at pulp and paper and timber products facilities is wood
preparation. However, because of the size of this operation these sites are not frequently located in
developed areas.
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Major Environmental Issues EIA Guidelines for Pulp & Paper and Timber
The greatest noise contributions contributing to ambient noise levels are indirect to the operation of
the mill. Truck and rail transportation will have the greatest impact on surrounding communities,
especially if the major transportation route is near, or through, residential areas (Wapora, 1979).
The EPA has recommended a maximum 75 dBA, 8-hour exposure level to protect workers from loss
of hearing. A maximum 55 dBA background exposure level is recommended to avoid annoyance
during outdoor activity. A suitable methodology to evaluate noise generated from a proposed new
source facility requires the applicant to:
/*
• Identify all noise-sensitive land uses and activities adjoining the proposed plant site (e.g.,
schools, parks, hospitals, and businesses in the urban environment; homes and wildlife
sanctuaries in the rural environment)
• Measure the existing ambient noise levels of the areas adjoining the site
• Determine whether there are any State or local noise regulations that apply to the site
• Calculate the noise levels of the timber processing operations, and compare those values
with the existing area noise levels and the applicable noise regulations
• Assess the impact of the operation's noise and, if required, determine noise abatement
measures to minimize the impact (e.g., quieter equipment, noise barriers, unproved
maintenance schedules).
Although means exist to reduce the noise from specific sources, they often are costly. However, the
noise level of equipment maintained hi good operating condition ususally is considerably less than if
the equipment is maintained improperly. The BID should address operation and maintenance plans
for mill equipment to ensure that design noise levels are maintained
Other primary methods available to reduce noise generated by particular sources include:
• Enclose process machines
• Place effective mufflers on engines
• Establish sound barriers and isolate operations
• Use vibration insulation.
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EIA Guidelines for Pulp & Paper and Timber Impact Analysis Requirements
5. IMPACT ANALYSIS REQUIREMENTS
This chapter provides guidance on meeting specific NEPA documentation requirements. To assist the
reader, where appropriate we have distinguished among requirements that apply to EIDs, EAs, and
In many ways, this chapter builds on information presented earlier in this guidance document.
Chapter 2 provided an overview of requirements for NEPA reviews of new source NPDES permitting
actions. Chapter 4 identified the key environmental issues and impacts associated with the pulp and
paper and timber products industries.
5.1 DETERMINE THE SCOPE OF ANALYSIS
"Scoping" refers to the process of determining the nature and extent of significant issues associated
with a proposed action. Scoping is a key preliminary step for all types of assessments, allowing the
analyst to focus on what is most important.
In the case of EIDs, scoping is an informal process. As part of an initial consultation between EPA
and the Permit Applicant, the Applicant should be prepared to explain why a permit for a new source
discharge is being requested. The Applicant should be prepared to discuss the context for the permit
application and to address such questions as:
• How is the action related to your firm's business or other objectives?
• How would the proposed new industrial activities relate to any existing operations?
• What issues do you think might be important with regard to the new source permit (e.g.,
any additional employment opportunities or effects on the local economy, pollution, nearby
historic or cultural sites)?
• Are you aware of any environmental or other studies or data that may be helpful in this
review?
• Would you anticipate that the proposed new source discharge would raise any concerns
within your community?
• Are you aware of any groups or individuals likely to be particularly interested in or
concerned about the new wastewater discharge?
•
In preparing an EA on the proposed issuance of a new source permit, EPA will review information
provided by the Applicant to help identify any potentially significant issues. EPA also will contact
representatives of any Federal, State, or local government agencies that may have a particular interest
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Impact Analysis Requirements EIA Guidelines for Pulp & Paper and Timber
't ' .
in the proposed action. Among those agencies likely to offer information that may be helpful in the
early identification of key issues are local land use planning agencies, the State environmental
protection and natural resource management agencies, and the State Historic Preservation Officer
(SHPO). Contact with Regional representatives of the U.S. Fish and Wildlife Service and the
National Marine Fisheries Service can be helpful in early identification of any potential issues relating
to Federally listed threatened and endangered species.
Where an EIS is required, scoping becomes a formal process that involves public participation and
interagency coordination.
Generally, an NOI for EIS preparation will contain an initial identification of potentially important
issues associated with a proposed action. The NOI also will describe the proposed method for
conducting the scoping process and will identify the office or person responsible for matters related to
scoping.
EIS preparation also involves holding a scoping meeting, where affected Federal, State, and local
agencies, affected Tribes, and other interested persons, are invited to participate in the identification
of key issues. Participants help draw attention to any other actions or previous assessments that may
bear on the proposed action. In addition, the scoping process may involve addressing procedural
issues. For example, the review and consultation procedures for the process may be identified, a
planning schedule may be developed, and page and time limits for the assessment may be set.
.-.
5.2 IDENTIFY ALTERNATIVES
In accordance with NEPA, impact analysis requires a description of the proposed action as well as a
description of all reasonable alternatives. The identification of alternatives is an essential step in the
preparation of EIDs, EAs, and EISs. For EISs, alternatives would be described in great detail.
The description of alternatives should include an identification of any alternatives that were considered
and rejected during the planning process. The rationale for the elimination of any alternatives from
further consideration should be provided. Alternatives generally are rejected based on technical,
economic, environmental, or institutional considerations. In the case of an EIS, the decision to
dismiss an alternative must be supported by data sufficient to respond to a challenging question or
comment.
EPA's NEPA procedures recognize three general categories of alternatives: alternatives available to
EPA; alternatives considered by the applicant; and alternatives available to other permit agencies.
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EIA Guidelines for Pulp & Paper and Timber Impact Analysis Requirements
5.2.1 ALTERNATIVES AVAILABLE TO EPA
Three types of alternatives are available to EPA in assessing the potential impacts of a proposed new
source NPDES permitting action:
• Issue the NPDES permit
• Issue the NPDES permit with modifications to the proposal (including modifications that
may not have been considered by the Applicant)
• Deny the NPDES permit.
The third option is generally referred to as the "no action alternative." This alternative provides a
baseline for comparing the impacts of other options.
5.2,2 ALTERNATIVES CONSIDERED BY THE APPLICANT
As part of an EID, the Applicant should provide a detailed description of the proposed action as well
as a description of any alternatives that were considered, but rejected. The Applicant should also
consider the "no action alternative," which would be not to apply for the NPDES permit.
The Applicant should explain the implications of each option with regard to the firm's goals and
objectives. The Applicant should consider the full range of options for meeting these goals and
objectives, including options that do not involve a discharge subject to permit requirements.
EPA's NEPA procedures require that the Applicant provide: (1) "balanced" descriptions of each
alternative and (2) a discussion covering size and location of facilities, land requirements, operations
and management requirements, auxiliary structures such as pipelines or transmission lines, and
construction schedules.
When new industrial facilities are planned, operators typically undertake feasibility and planning
studies. Companies typically investigate processing options, markets, siting alternatives, and a host of
other technical, financial, and legal issues. These planning studies can be helpful in the early
identification of critical issues, including potential land use conflicts, proximity to protected natural
resources or historic sites, or any indication of hazard potential (e.g., location of facilities hi
floodplains).
The Applicant should explain his planning process to provide insight into the breadth and depth of
alternatives considered and rejected or pursued for further study. A well-documented explanation of
the Applicant's analysis of alternatives is critically important to the impact assessment process.
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Impact Analysis Requirements EIA Guidelines for Pulp & Paper and Timber
In particular, it is important for the Applicant to explore and document a broad scope of alternatives
that look at pollution prevention opportunities.
5.2.3 ALTERNATIVES AVAILABLE TO OTHER PERMITTING AGENCIES
A third category of alternatives are those available when EPA is preparing an EIS or other
environmental document in conjunction with another Federal or State agency. These additional
alternatives would be based on other relevant regulatory authorities. For example, in addition to a
new source NPDES discharge, a proposed project might involve dredging or filling of a wetland. In
this case, the U.S. Army Corps of Engineers would be responsible for issuing a permit under Section
404 of the CWA. Accordingly, environmental analysis would account for the various alternatives
available to the Corps of Engineers, which would include: granting the permit; granting the permit
with modifications or conditions; or denying the permit.
5.3 DESCRIBE THE AFFECTED ENVIRONMENT
The affected environment section of any NEPA document should be no longer or more detailed than
needed to understand potential environmental impacts. Background information on topics not directly
related to expected effects should be summarized, consolidated, or referenced to focus attention on
important issues.
The scope and content of this section of an EID will be determined during an initial consultation
between EPA and the Applicant. Generally, the Applicant will be required to provide any relevant
information that is readily available. In establishing the scope of this section of an EID, EPA will
consider the size of the new source in and extent to which the Applicant is capable of providing
information. Requests for data should be kept to a minimum consistent with requirements under
NEPA.
For an EA, the description of the affected environment should focus on key issue areas, including the
following:
• Current and projected land use within the project area and within the region
• Distribution of vacant land and current trends in the development of vacant land within the
region
• Current and projected population and population density
• Relevant land use regulations
• Local and regional patterns of energy demand and supply
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EIA Guidelines for Pulp & Paper and Timber Impact Analysis Requirements
• Local ambient air quality conditions
• Local ambient noise levels
• Location of designated fioodplains within the vicinity of the project
• Surface and ground water quality and quantity
• Local biological communities and fish and wildlife habitats
• Critical habitats of any Federally or State listed threatened or endangered species
• Location of any properties listed in or eligible for listing in the National Register of
Historic Places
• Location of specially protected areas, including parklands, wetlands, wild and scenic rivers,
navigational areas, or prime agricultural lands.
In the case of an EIS, the description of the affected environment is more extensive and detailed. The
breadth of topics typically addressed within an EIS is discussed below.
5.3.1 THE PHYSICAL-CHEMICAL ENVIRONMENT
The physical-chemical environment comprises the air, water, and geological characteristics of sites
where the environmental impacts of alternatives will be evaluated. This section of an EIS should
provide sufficient information to determine whether impacts are likely to be significant.
5.3.1.1 Air Resources
Air resources are described by the physical dynamic behavior of the lower atmosphere and by
variations in the concentrations of various gases and suspended matter. Physical dynamic behavior is
described by parameters such as the seasonal distribution of wind velocity and the frequency and
height of inversions. Wind velocity and the frequency of occurrence of inversions are often
determined by specific local topographic features, particularly surrounding hills or mountains. Air
quality is described by the variations in the concentrations of pollutant gases in the lower atmosphere.
Both are needed to determine the environmental impacts of facility stack emissions, the effects of
mobile sources on local air quality, and the likelihood that dust will be of importance during
construction.
The description of meteorological regime(s) should include a generalized discussion of regional and
site-specific climate including:
• Diurnal and seasonal ground-level temperature '
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Impact Analysis Requirements EIA Guidelines for Pulp &'Paper and Timber
• Wind characteristics at different heights and times (wind roses are particularly helpful and
provide wind speed, direction, frequency, and stability characteristics of the atmosphere)
• Total monthly, seasonal, and annual rainfall and frequency of storms and their intensity
• Height, frequency, and persistence of inversions and atmospheric mixing characteristics
• Description of pattern(s) evident for days of significant pollution episodes; evaporation.
Information on ambient air quality is often required to predict the impacts during construction and the
v
operation of a facility. Using existing air quality as the background, incremental increases in air
pollution concentrations can be predicted for comparison with various Federal, State, and local
standards. Depending on the scale of the analysis, data should be presented for the relevant airshed,
for the site itself, or both.
Emission inventories and ambient air quality as reported by State and local air pollution control
districts are the data sources for an air basin or regional airshed level analysis. At a minimum, major
stationary sources and their emissions should be characterized, with diurnal variations in emissions by
month, year, and peak season for pollutants of concern. Projections of increases in emissions and
long-term pollutant concentrations are also important at this level. The comparison of expected trends
with existing Federal, State, and local standards becomes a major design parameter for gaseous
emission controls.
Site-level analyses are more detailed in their geographic scope, but require similar information. One
of the major concerns at the site level is the transport of odors, dust, and emissions towards
potentially sensitive environments. Thus local variations in wind velocities, frequency of inversions,
and ambient pollutant concentrations may become important in determining local impacts. Air quality
models are often used to determine the directions and ground level concentrations of pollutants of
concern, and these, models require most of the information described in the previous paragraph along
with specific stack characteristics such as stack height, emission temperature, emission velocity, and
the chemical composition of the stack gases.
5.3.1.2 Water Resources
Information on water resources to be included in the affected environment chapter should cover a
description of local streams, lakes, rivers, and estuaries, as well as descriptions of groundwater
aquifers. Descriptions of water body types, flows and dilutions, pollutant concentrations, and habitat
types near potential discharges are necessary to determine the changes in the water environment that
will occur with facility construction and operation. Descriptions of groundwater aquifers are
necessary to determine the potential for contamination of groundwaters from site activities... Of key
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EIA Guidelines for Pulp & Paper and Timber Impact Analysis Requirements
importance here is the depth to the water table, and the nature of overlying soils and geologic
features.
Descriptions of surface waters should include seasonal and historical maximum, minimum, and mean
flows for rivers and streams, and water levels or stages and seasonal patterns of thermal stratification
for lakes and impoundments. The use of surface waters (diversions, returns > and reclamation) may
also be important in certain locations where water resources are scarce. Information on ambient
concentrations of pollutants is also necessary to determine resulting concentrations of pollutants with
new discharges.
Descriptions of groundwaters should include the location of recharge areas, and, in areas of water
shortage, their present uses. Chemical composition of groundwaters are not usually important unless
they are to be used as process water or are suspected to be contaminated.
If imported water is to be used at the site for process water or other purposes, the source, quantity,
and quality of the water should be described. Any existing NPDES permits should be identified along
with a description of wastewater flows and quality.
If the site might be subject to flooding (is within the 100-year iloodplain), the dates, levels, and peak
discharges of previous floods should be reported along with the meteorological conditions that created
them. Projections of future flood levels should also be included for typical planning levels of 50- and
100-year floods. These projections should include anticipated flood control projects such as levees
and dams that will be built.
5.3.1.3 Soils and Geology
The physical structure of soils and their underlying geologic elements determine the extent to which
soils will be affected by facility construction and operation. Useful parameters include permeability,
erodability, water table depth, and depths to impervious layers. The engineering properties and a
detailed description of surface and subsurface soil materials and their distribution over a site provide
most of the information necessary.
Local and regional topographic features such as ridges, hills, mountains, and valleys provide
information on watershed boundaries, and site topography (slope and elevation characteristics)
provides information that is needed in determining the potential for erosion.
Geological features are important when there may be significant mineral resources present or when
paleontological sites and other areas of scientific or educational value may be disturbed or overlain by
facility structures.
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Impact Analysis Requirements EIA Guidelines for Pulp & Paper and Timber
In regions of the country that are seismically active, the description of the affected environment
should information necessary to assess potential risks. Relevant information can include proximity to
faults, the history of earthquakes in the area, locations of epicenters, magnitudes, and frequency of
\
occurrence.
5.3.2 BIOLOGICAL CONDITIONS
Key elements of a description of biological conditions include the distribution of dominant species,
identification and description of rare, threatened, or endangered species, and a characterization of
ecological interrelationships.
5.3.2.1 Vegetation
To understand the significance of vegetation changes associated with construction and operation of a
facility, it is necessary to know the types of plant communities in the general area and the specific
distribution of vegetation types within the project area. The presence in the area of rare, threatened,
or endangered species and unique plant assemblages are particularly important, especially if any are
likely to occur at the site. There are a variety of ways to describe vegetation, but the most useful is
to divide the site flora into four or five "typical" assemblages and map their distribution and that of
recognized scientific and educational areas. For threatened, endangered, or rare species, however, it
is necessary to map their occurrence separate from the assemblages.
In areas subject to forest fires, fire hazard should be described by describing the history of fires in the
area, projecting the severity of fire hazard in the future, and describing existing fire control and
management actions.
Aquatic and marine vegetation, particularly in the vicinity of proposed discharges, also should be
characterized. General community characteristics, including dominant species diversity and relative
frequencies, should be identified.
5.3.2.2 Wildlife
The presence of wildlife at a site is largely dependent on the nature and distribution of vegetation.
Particular emphasis should be placed on the presence of rare, threatened, or endangered species in the
general vicinity of the site, and site-specific discussions are mandatory when the site provides habitat
that is used by rare, threatened, or endangered species. Under these circumstances, the relative
abundance of all rare, threatened or endangered species and the dominant wildlife fauna should be
surveyed onsite and presented in the BID.
A general cataloging and description of the area's year-round and seasonally resident species, along
with basic information about their natural history, would also be very useful. Valuable information
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EIA Guidelines for Pulp & Paper and Timber Impact Analysis Requirements
could include food, territory and habitat requirements for each species, as well as the timing of
mating and young rearing, and the timing and routes of migration, if applicable. This
characterization of the biological community will provide an aid for predicting the effects of facility
construction and operation. The more complete this cataloging is, the more accurate the reviewers'
picture of the biological community will be.
5.3.2.3 Ecological Interrelationships
A characterization of the key interrelations and dynamics within an ecosystem provides a foundation
for impact assessment.
Although it is difficult to determine the extent to which plants and animals are interdependent at a
given site, specific attention should be given to identifying the food sources of dominant or rare
animal species, the factors that limit these food sources (including factors such as soil structure and
moisture content, soil surface temperature ranges, and specific soil micronutrients), and the ability of
animal species to substitute food sources should current food sources be reduced in abundance.
Ecological interdependencies in aquatic systems are also important, and aquatic communities change
dramatically with large increases in nutrient or sediment discharges. While prediction of changes in
plant and animal populations is difficult under the best of circumstances, significant changes (either
positive or negative) cause concomitant changes in both terrestrial and aquatic fauna.
With the building of any large facility and associated infrastructure, there is potential for disturbance
of the biological community. The impact may be more significant in pristine, or relatively
undisturbed areas. In these areas especially, reviewers will want to assess the potential for ecosystem
fragmentation and edge effects, and disruption of migratory patterns.
The EID should provide information on the facility's potential for fragmenting ecosystems to the
extent that remaining habitat islands may: (1) be too small for some species' territorial or other
requirements, (2) cause crowding to an extent that aberrant behaviors such as conspecific egg-
dumping occurs, and (3) provide introduction routes or access (e.g., via the edge effect) for
previously absent opportunistic or predatory species (such as cowbirds and bluejays). Reviewers
should also be able to determine from die EID whether the facility's siting could potentially eliminate
or compromise habitat used by species such as certain, waterfowl, raptors, and ungulates along their
migration routes.
5.3.3 SOCIOECONOMIC ENVIRONMENT
The socioeconomic environment encompasses the interrelated areas of community services,
transportation, employment, health and safety, and economic activity. The activities associated with
the construction and operation of new source facilities must impact human resources (employment,
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Impact Analysis Requirements EIA Guidelines for Pulp & Paper and Timber
population, and housing), institutional resources (services or facilities), and economic activity. The
information required to assess impacts are described below.
5.3.3.1 Community Services
Community services such as water supply, sewerage and storm drainage, power supply, and
education, medical, and fire and police services are almost always affected by major new projects. It
is important in an EIS to describe the nature of existing public facilities and services within the
general vicinity, the quality of the service provided, and the ability of the existing public facilities and
services to accommodate additional users. The most critical consideration is the level of services that
would be provided in the anticipated peak year of construction assuming no project were to be
undertaken.
Permanent and temporary household relocations create demands on the housing market. The number
of nearby housing units, their cost, vacancy rates, and owner-occupancy rate are all significant factors
in determining the suitability of the existing housing stock for occupancy by a temporary or
permanent workforce. In addition, the present rate of growth within the housing sector can be
compared with the anticipated growth in housing supply and demand and the amount of land available
for new housing to determine whether existing policies and attitudes toward growth are adequate to
accommodate the additional residents.
5.3.3.2 Transportation
*C
/
Transportation systems provide access to a facility for the import of raw materials, export of final
products, and the movement of staff and service personnel. All relevant forms of transport for the
facility should be described. For all facilities, road-based transport is of potential significance, but
railways, airways, pipelines, and navigable waterways may also be important for some facilities.
Current traffic volumes, current traffic capacity, and an assessment of the adequacy of the systems for
meeting peak demands during construction or operation should be presented.
•v
5.3.3.3 Population
Total population, rate of growth, general socioeconomic, composition, transient population, and the
urban or rural nature of the local population are parameters needed to assess the importance of the
impacts of project-induced changes on the local community. Information on average household size,
average age, age/sex distributions, ethnic composition, average household income, percent of
households below poverty level, and median educational level allow a more refined analysis of
project-induced changes. Projections of demographic trends for the region and project area without
the project are also necessary to determine the relative impacts of the project in future years.
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EIA Guidelines for Pulp & Paper and Timber Impact Analysis Requirements
5.3.3.4 Employment
Employment is generated by the construction and operation of any new facility. Construction is
normally carried out by a temporary workforce of construction workers, not by the permanent
workforce in the area near the site. On the other hand, facility operation usually relies on a
permanent workforce, and the source of personnel for this workforce may be local or from other
parts of the country. In any case, increases in the number of personnel required to build or operate a
facility, direct employment, is accompanied by increases in employment in enterprises required to
support the facility, indirect (secondary, non-basic) employment, as demands for goods and services
are increased. The direct and indirect employment generated by a project, in rum, generates
movements of households, resulting in population shifts and changes hi the demographic
characteristics of communities.
To determine impacts of additional employment on the local environment, it is necessary to present
information about the local labor base—where people work, what they do, their skills and education
level, their rates of pay, and the unemployment rate. The characteristics of the unemployed
population are especially important if there is an expectation that a new facility will generate
employment for them. Projections should also be included on anticipated trends in employment and
unemployment without the project so that project-induced changes hi these parameters can be
compared against a baseline.
5.3.3.5 Health and Safety
Description of the present health and safety environment should include statistics on industrial
accidents hi the local area; a discussion of air, water, and radioactive emissions from existing
facilities and their effects on the health of the local population; and an analysis of present levels of
noise and then- impacts on people. The identification of applicable regulatory standards provides a
benchmark against which the present and future health and safety environment, with and without the
project, can be judged.
5.3.3.6 Economic Activity
Economic activity will always be affected by new facilities. Current economic activity should be
described by characteristics of local businesses (number and types of businesses, annual revenues, and
ownership patterns) and the availability of capital for future growth. To predict changes in the kinds
of economic activity that would occur with the project, it is necessary to describe the kinds of goods
and services that would be required by the project, or associated workforce and determine whether
they are provided locally or imported. Unique features of the business community such as high
seasonally, high outflow of profit, declining trade/or downtown revitalization should also be
included. /
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Impact Analysis Requirements EIA Guidelines for Pulp & Paper and Timber
5.3.4 LAND USE ;
A description of land use should identify the current use of land needed specifically for the facility, its
system components, its safe area, and its residuals, and land use patterns in the nearby area that will
be indirectly affected by the project. Particular emphasis should be placed on land uses that pose
potential conflicts for large-scale industrial activity—residential areas, agricultural lands, woodlands,
wetlands—and on the local or regional zoning laws that may limit the development of industry or
commercial activities on which it relies.
\
5.3.5 AESTHETICS
Aesthetics involve the general visual, audio, and tactile environment (imagine the sensory differences
among urban, industrial, agricultural, and forest environments). A description of the aesthetic
characteristics of the existing environment should include things that are seen, heard, and smelled in
and around the site and their emotional or psychological effect on people. Descriptions (or pictures)
of views of the site, of unique features or features deemed of special value, and public use and
appreciation of the site provide information that must be available for the assessment of impacts.
5.3.6 CULTURAL RESOURCES
Cultural resources is a broad category that encompass resources of current, prehistoric and historic
significance. The location of a facility near significant historical and cultural sites can degrade their
resource value or emotional impact. The location of the following kinds of sites should be described
in relation to the project site:
• Archeological sites (where man-made artifacts or other remains dating from prehistoric
times are found)
• Paleontological sites (where bones, shells, and fossils of ancient plants or animals are found
in soil or imbedded in rock formations)
• Historic sites (where significant events happened or where well-known people lived or
worked),
• Sites of particular educational, religious, scientific, or cultural value.
5.4 ANALYZE POTENTIAL IMPACTS
The major environmental issues associated with the pulp and paper and timber products industries
were discussed in the previous chapter. Although Chapter 4 presents guidance for the analysis of
impacts that tend to be common to these industrial categories, it is important to recognize that other
types of impacts are bound to be associated with specific proposed actions. Thus, reviewers must
ensure that all key issues identified during the scoping process are fully analyzed. The NEPA
*
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EIA Guidelines for Pulp & Paper and Timber Impact Analysis Requirements
checklist presented as Appendix A of this document provides additional guidance on the wide range of
impacts that may be encountered. The section below provides more specific guidance on the
preparation of the "Environmental Consequences" section of an EIS.
The "Environmental Consequences" section of an EIS forms the scientific and analytical basis for the
comparison of alternatives. It contains discussions of beneficial and adverse impacts of each
reasonable alternative and mitigation measure (40 CFR 1502.16 and 1508.8) including:
4
• Direct effects and their significance—direct effects are caused by the proposed action and
occur at the same time and place.
• Indirect effects and their significance—indirect effects are those caused by the action but are
later in time or farther removed hi distance, but are reasonably foreseeable. This also
includes growth effects related to induced changes in the pattern of land use, population
density, or growth rate and related effects on air, water, and ecosystems.
• Possible conflicts between proposed actions and the objectives of Federal, regional, State,
local and ... tribal... land use plans, policies, and controls for the area concerned.
• The environmental effects.
• Energy requirements and conservation potential.
• Natural or depletable resource requirements and conservation potential.
» Urban quality, historical and cultural resources, including reuse and conservation potential.
• Means to mitigate adverse environmental impacts not fully covered by the alternatives.
The potential impacts of each alternative are identified by a systematic disciplinary and
interdisciplinary examination of the consequences of implementing each alternative.
5.4.1 METHODS OF ANALYSIS
While information may be gathered from new source NPDES applications, EIDs, and other sources,
EPA is responsible for the scientific and professional integrity of any information used in their EISs.
The applicant's EID and other sources of data, therefore, must clearly explain all sources, references,
methodologies, and models used to analyze or predict results. The applicant must document
conformance to EPA guidelines, when applicable. For example, EPA models must be used when
required or validation of alternative models must be submitted if appropriate. Similarly, chemical
analysis must be performed according to EPA-approved methods. Applicants should consider the
uses and audiences for their data and EPA's affirmative responsibility in using them. EPA has the
same responsibility in the use of data submitted by other agencies, private individuals, or groups.
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Impact Analysis Requirements EIA Guidelines for Pulp & Paper and Timber
Each impact has its own means of identification, qualification, and quantification. For example, air
quality impacts are modeled using standard State or Federally approved programs. These numerical
models depend on standardized parameters and site-specific data. Stationary source emissions from
plant operation as well as mobile emissions related to traffic circulation from induced employment or
growth all contribute to air quality impact quantification. The goal is to quantify impacts on air
quality, water quality, employment, land use, and community services—categories that lend
themselves to numerical calculations, modeling, and projections. Some environmental elements like
aesthetics lend themselves to more qualitative or graphic analyses.
Biological impacts frequently are not readily quantifiable because absolute abundance of individual
species are difficult to determine. Impacts may be described as acres of habitat lost or modified or by
qualitative impact descriptions of population changes in major species or species groups. The key in
the Environmental Consequences section is to clearly and succinctly lead a reader through each impact
identification, qualification and/or quantification. Detailed methodologies or extensive data can be
incorporated by reference if the source is readily obtainable. Materials from applicants must carefully
follow this pattern to facilitate validation and incorporation in the EIS. General impacts likely to
occur with new source facilities are identified in later sections along with suggestions on the kinds of
information needed to analyze data and draw conclusions.
5.4.2 DETERMINATION OF SIGNIFICANCE
As discussed in Chapter 2 of these guidelines, The term "significant effect" is pivotal under NEPA,
for an EIS must be prepared when a new source facility is likely to cause a significant impact. What
is significant can be set by law, regulation, policy, or practice of an agency; the collective wisdom of
a recognized group (e.g., industry or trade association standards); or the professional judgment of an
expert or group of experts. CEQ (40 CFR 1508.27) explains significance hi terms of context and
intensity of an action. Context relates to scale—local, regional, State, national, or global; intensity
refers to the severity of the impact. Primary impact areas include affects on public health and safety,
and unique characteristics of the area (e.g., historical or cultural resources, parks, prime farm lands,
wetlands, wild and scenic rivers, or ecologically critical areas). Other important factors include:
• Degree of controversy
• Degree of uncertain or unknown risks
• Likelihood a precedent will be set >
• Occurrence of cumulative impacts (especially if individually not significant)
• Degree to which sites listed, or eligible for listing, in the National Register of Historic
Places may be affected
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EIA Guidelines for Pulp & Paper and Timber Impact Analysis Requirements
• Degree to which significant scientific, cultural, or historical resources are lost
• Degree to which threatened or endangered species or their critical habitat is affected
• The likelihood of violations of Federal, State, regional or local environmental law or
requirements.
EPA's NEPA procedures require that the Agency consider short-term and long-term effects, direct
and indirect effects, and beneficial and adverse effects. Of particular concern are the following types
of impacts:
• The new source will induce or accelerate significant changes in industrial, commercial,
agricultural, or residential land use concentrations or distributions which have the potential
for significant environmental effects. Factors that should be considered in determining
whether these changes are environmentally significant include but are not limited to:
The nature and extent of the vacant land subject to increased development
pressure as a result of the new source
The increases in population or population density which may be induced and the
ramifications of such changes
The nature of the land use regulation in the affected areas and their potential
effects on development and the environment
The changes in the availability or demand for energy and the resulting
environmental consequences.
• The new source will directly, or through induced development, have significant adverse
effects upon local ambient noise levels, floodplain, surface or groundwater quality or
quantity, fish, wildlife, and their natural habitats.
' • Any major part of the new source will have significant adverse effect on the habitat of
threatened or endangered species on the Department of the Interior's or a State's list of
threatened and endangered species.
• The environmental impacts of the issue of a new source NPDES permit will have significant
direct and adverse effect on property listed in the National Register of Historic Places.
• Any major part of the source will have significant adverse effects on park lands, wetlands,
wild and scenic rivers, reservoirs, or other important bodies of water, navigation projects,
or agricultural lands.
With the regulations in mind, it is ultimately up to the EIS preparer(s) to make judgments on what
constitutes a significant impact. The threshold of significance is different for each impact, and
those making the judgments need to explain the rationale for the thresholds chosen. Clear
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Impact Analysis Requirements _ EIA Guidelines for Pulp & Paper and Timber
descriptions of the choice of the threshold of significance provides a reviewer with a* basis for
agreeing or disagreeing with the determination of significance based on specific assumptions, criteria,
or data. Sometimes the thresholds are numerical standards set by regulation. In other cases, the
thresholds may be set by agency practice (e.g., the U.S. Fish and Wildlife Service may consider the
potential loss of a single individual of an endangered species as a significant impact), or the EIS
preparer's professional judgment that determines the rationale for the threshold. The NPDES permit
applicant may suggest a threshold for each impact identified in the BID, but it is critical to carefully
define how and why each particular threshold was chosen and applied.
5.4.3 COMPARISONS OF IMPACTS UNDER DIFFERING ALTERNATIVES
Alternatives can be compared in several different ways. All of the impacts associated with a single
alternative may be examined together and summarized in a final list of significant unavoidable
impacts, or the like impacts of all the alternatives can be determined and compared within a final
summarized list of significant unavoidable impacts. The choice of approach should be determined by
the EIS preparers based on the approach that would provide the most clear, concise evaluation for
decision makers and reviewers. The summary information on possible impacts and mitigation
measures is usually prepared in tabular form and included in the executive summary. Examples of
formats that can be used are found in standard environmental assessment technology texts, agency
*^ EISs, and similar documents.
5.4.4 SUMMARY DISCUSSIONS
*£^
CEQ and EPA NEPA guidelines describe the expected general contents of the section called
"Environmental Consequences." In addition to identifying, quantifying, and comparing the impacts
of each alternative, 40 CFR 1502.16 specifies that discussions will include "...any adverse
environmental impacts which cannot be avoided should the proposal be implemented, the relationship
between short-term uses of man's environment and the maintenance and enhancement of long-term
productivity, and any irreversible or irretrievable commitments of resources which would be involved
in the proposal should it be implemented."
Over the last 20 years, these three topics have been included as a separate chapters) hi draft EISs
along with chapters called cumulative impacts, adverse effects which cannot be avoided, or residual
impacts and mitigation. No matter what format is used with these topics, they often receive only
cursory treatment. Such a practice is unfortunate because these long-term, larger scale issues are
those that affect overall environmental quality and amenities. The important point is not the location
of these topics in the document, but the need to present data and analytical procedures used to qualify
and quantify these concerns.
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EIA Guidelines for Pulp & Paper and Timber Impact Analysis Requirements
A section called cumulative impacts can be addressed in several ways. Some EISs consider
cumulative impact sections to be summaries of all residual impacts for each alternative. They may
also Include any synergistic effects among impacts. A second, and more helpful, approach to
cumulative impacts reflects a broad view of environmental quality and suggests how impacts of the
proposed project or alternatives contribute to the overall environmental quality of the locale. In this
approach, the impacts of the new source project are considered in relation to the impacts associated
with projects approved, but not constructed; projects being considered for approval; or planned
projects. This "accumulating" impacts approach to cumulative impacts is particularly instructive
when no single project is a major cause of a problem, but contributes incrementally to a growing
problem.
All of these summary topics focus on broad views and long time lines in a attempt to put project
impacts in perspective. The data requests from EPA to applicants must specify the environmental
setting and consequences data needed to qualify and quantify the potential impacts and put each
potential impact in perspective in terms of local, regional and perhaps State or national environmental
quality.
5.5 DETERMINE MITIGATING MEASURES
Initial efforts to meet requirements under NEPA emphasized the identification of mitigation measures
for all potential impacts conceivably associated with a project or its alternatives. Current practices
emphasize avoiding and minimising potential impacts before a NEPA document is prepared. This is
accomplished by refining the proposed project and alternatives during siting, feasibility, and design
processes. The goal is to propose project alternatives with as few significant impacts as possible.
CEQ NEPA regulations define mitigation (40 CFR 1508.20) to include:
• Avoiding the impact altogether by not taking a certain action or parts of an action
• Minimizing impacts by limiting the degree or magnitude of the action and its
implementation
• Rectifying the impact by repairing, rehabilitating, or restoring the affected environment
• Reducing or eliminating the impact over time by preservation and maintenance operations
during the life of the action
• Compensating for the impact by replacing or providing substitute resources or
environments.
This listing of mitigation measures has been interpreted as a hierarchy with "avoiding impacts" as the
best mitigation and "compensating" for a loss as the least desirable (but preferable to loss without
5-17 September 1994
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Impact Analysis Requirements EIA Guidelines for Pulp & Paper and Timber
compensation). This hierarchy reinforces the present approach of trying to avoid or'minimize
potential impacts during project siting and design. The goal is to have the most environmentally
sound project and alternatives to carry into the impact assessment process of NEPA.
Even with the best project siting and design, there will be environmental impacts associated with each
of the alternatives. For the impacts, especially for the impacts judged to be significant impacts,
mitigation measures need to be suggested.
o
The first source of possible mitigation measures should be those offered in an applicant's EID. Each
mitigation measure should be described in enough detail so that its environmental consequences can
be evaluated and any residual impacts clearly identified.
The proposed project and its alternatives—or the suite of alternatives if there is no preferred
alternative—typically reflects choices among tradeoffs. The tradeoffs can include different sites,
processes, pollution control technologies, costs, or other features. Typically the tradeoffs are
complex for new source facilities with dissimilar beneficial and detrimental impacts among the
alternatives. The analysis should be deemed complete if:
• The alternatives brought forward for analysis are all reasonable
• All possible refinements and modifications for environmental protection have been
incorporated hi the alternatives
• Any residual impacts and consequences of mitigating those impacts have been evaluated.
5.6 CONSULTATION AND COORDINATION
Each of the many laws, regulations, executive orders, and policies identified in the Regulatory
Overview section of this guidance document should be addressed in the Consultation and Coordination
section of an EIS. The applicant should provide a record of their activities and actions under each of
the initiatives. The applicant provided environmental setting and environmental consequences
materials should include sufficient data on the environmental issues raised by these laws, regulations,
and orders to identify and analyze the potential impacts.
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EIA Guidelines for Pulp & Paper and Timber Regulatory Overview
6. REGULATORY OVERVIEW
6.1 CLEAN WATER ACT
The primary goal of the Clean Water Act (33 U.S.C 125 et seq.) is to "restore and maintain the
chemical, physical, and biological integrity of the Nation's water." The Act covers all pollutant
discharges to all waters of the United States. In achieving this goal, the Act established three major,
interrelated procedures for controlling industrial effluents from new sources, and specifically included
timber products/pulp and paper operations and related facilities in the list of affected source
categories. The principal mechanism to regulate discharges is the National Pollutant Discharge
Elimination System (NPDES) permit. The other provisions include New Source Performance
Standards (NSPS) and Pretreatment Standards for New Sources (PSNS).
i
The NPDES permit program is implemented by 40 States and Territories, and where a State or
Territory is not delegated authority for the program, NPDES permits are issued by the responsible
EPA regional office. An NPDES Permit is required prior to the discharge of any pollutant from a
point source into waters of the United States. Point sources are defined as discharges of process
water and/or storm water runoff associated with industrial activity from any discrete conveyance
including pipes, ditches, and swales.
6.1.1 PROCESS WATER
An NPDES permit prescribes the specific limits on concentrations or loadings of pollutants
discharges. Pollutant discharge limits for process water are set using one or more methods:
technology-based limits, water quality-based limits, and best professional judgement of the permit
writer. Technology-based limits are set for direct and indirect discharges to surface waters using
guidelines developed for particular industrial categories and their common pollutants. For discharges
that directly enter waters from a facility, EPA established effluent limitations guidelines for both
existing and new source facilities. Likewise, existing and new source facilities are regulated by
categorical pretreatment standards for indirect discharges to a waters of the U.S. Different standards
will be applicable nationwide depending on the subcategory of the industry under consideration (i.e.,
timber products/pulp and paper facilities). The Water Quality Act of 1987 mandated that all existing
facilities be in compliance with technology-based limitations by March 31, 1989. Any new source
facility subject to a technology-based limitation must be in compliance with the standards immediately
upon commencing operation.
In addition to technology-based limits, discharges may be controlled by "water quality-based" limits if
certain water quality standards must be achieved. Water quality-based limits are set using State
ambient water quality standards and the expected dilution of pollutants in the receiving water. Water
6-1 September 1994
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Regulatory Overview EIA Guidelines for Pulp & Paper and Timber
quality-based limits may be more restrictive than technology-based limits, in which case water quality-
based limits are those imposed.
In the absence of specific technology-based limitations and water quality-based limitations, however,
permit writers may use Best Professional Judgment (BPJ) to ensure that impacts of a discharge on
receiving waters are minimized.
At 40 CFR Parts 429 and 430, EPA established technology-based limits and guidelines for the timber
products/pulp and paper point source categories. Part 429 applies to timber products processing
operation, and plants producing insulation board with wood as the major raw material, that discharge
or may discharge process wastewater pollutants to the waters of the United States, or publicly owned
treatment works. Pan 430 applies to any pulp, paper, or paperboard mill which discharges or may
discharge process wastewater pollutants to the waters of the United States, or publicly owned
treatment works.
Within 40 CFR Parts 429 and 430, EPA has also set effluent limitations representing degrees of
effluent reduction attainable by the application of the best practicable control technology currently
available (BPT), the best conventional pollutant control technology (BCT), the best available
technology economically achievable (BAT) and pretreatment standards for existing sources. The New
Source Performance Standards (NSPS) and Pretreatment Standards for New Sources (PSNS) set forth
in 40 CFR Parts 429 and 430 are discussed below.
6.1.1.1 New Source Performance Standards (NSPS)
The basis for New Source Performance Standards (NSPS) under Section 306 of the Act is the best
available demonstrated control technology (BADCT). New facilities have the opportunity to design
the best and most efficient methods and wastewater treatment technologies. Therefore, Congress
directed the EPA to consider the best demonstrated process changes, in-plant controls, and end-of-
pipe treatment technologies which reduce pollution to the maximum extent feasible.
Application of NSPS to the Timber Products/Pulp and Paper Industry
Timber Products Industry
Within the effluent guidelines set forth in 40 CFR Part 429, EPA established New Source
Performance Standards (NSPS) for the following subcategories at new source timber products
processing facilities: barking, veneer, plywood, dry process hardboard, wet process hardboard, water
borne or nonpressure wood preserving, steam wood preserving, boulton wood preserving, wet
storage, log washing, sawmills and planing mills, finishing, particleboard manufacturing, insulation
board, and wood furniture and fixture production. New source facilities included in the majority of
these subcategories are subject to the "no discharge of process wastewater pollutants into navigable
6-2 September 1994
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EIA Guidelines for Pulp & Paper and Timber Regulatory Overview
waters" guideline (exceptions include hydraulic barking, wood preserving, and wet storage). Exhibit
6-1. exhibits the new source performance standards established for each of the 16 subcategories
identified in 40 CFR Part 429.
Pulp and Paper Industry
Within the effluent guidelines set forth in 40 CFR Part 430, EPA established New Source
Performance Standards (NSPS), and Pretreatment Standards for the following subcategories at pulp,
paper, and paperboard facilities: unbleached kraft, semi-chemical, unbleached kraft (cross recovery),
paperboard from wastepaper, dissolving kraft, market bleached kraft, BCT bleached kraft, fine
bleached kraft, papergrade sulfite, dissolving sulfite pulp, groundwood-chemi-mechanical,
groundwood-fine papers, soda, deink, nonintegrated-fine papers, nonintegrated-tissue papers, tissue
from wastepaper, papergrade sulfite, unbleached kraft and semi-chemical, wastepaper-molded
products, nonintegrated-lightweight papers, nonintegrated-filter and nonwoven papers, and
nonintegrated-paperboard.
NSPS are established for 26 of the 27 subcategories listed in 40 CFR Part 430, the Pulp, Paper, and
Paperboard Point Source Category. Exhibit 6-2 identifies the NSPS for each subcategory for which
standards have been established. The absence of NSPS applicable to specialty mills and textile fiber
mills means that new or expanded mills in these categories cannot be defined as new sources and the
issuance of NPDES permits by EPA is not subject to NEPA.
Revisions to the effluent guidelines for the pulp and paper industry were proposed in 1993, and are
expected to be finalized in 1995.
6.1.1.2 Pretreatment Standards for New Sources (PSNS)
At 40 CFR Part 403, EPA established General Pretreatment Regulations for Existing and New
Sources of Pollution, which requires certain POTWs, categorized by size and influent characteristics,
to develop POTW Pretreatment Programs. In general, these programs are intended to prevent the
introduction of pollutants by industrial users that would (1) interfere with the operation of treatment
works, (2) pass through treatment works, or (3) adversely affect opportunities to .recycle and reclaim
wastewaters and sludges. New source facilities are required to comply with the effluent limitations
guidelines established by the POTW's pretreatment program.
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Regulatory Overview
EIA Guidelines for Pulp & Paper and Timber
Exhibit 6-1. New Source Performance Standards :
For The Timber Products Processing Industry
Subcategory
A. Barking (Hydraulic Barking Installations
(Mechanical Barking Installations)
B. Veneer (Other)
(Softwood)
(Hardwood)
C. Plywood
D. Hardboard Dry Process
E. Hardboard Wet Process
F. Wood Preserving Water Borne or
Nonpressure
G. Wood Preserving Steam
H. Wood Preserving Boulton
I. Wet Storage
J. Log Washing
K. Sawmills and Planing Mills
L. Finishing
M. Panicleboard Manufacturing
N. Insulation Board
O. Wood Furniture and Fixture Production
without Water Wash Spray Booth(s) or
without Laundry Facilities
P. Wood Furniture and Fixture Production
with Water Wash Spray Booth(s) or with
Laundry Facilities
Pollutant or
Pollutant
Property .
BOD,
TSS
pH (s.u.)
BOD,
PH
BOD,
PH
Metric Units (kg/c3)
Maximum far Any 1 *%?** f '*f
^ J Values for 30
y Consecutive Days
1.5 0.5
6.9 2.3
Within the range 6.0 to 9.0 at all times.
No discharge of wastewater pollutants to
navigable waters.
' 0.72 0X24
With the range 6.0 to 9.0 at all times.
1.62 0.54
With the range 6.0 to 9.0 at all times.
No discharge of wastewater pollutants to
navigable waters.
No discharge of wastewater pollutants to
navigable waters.
No discharge of wastewater pollutants to
navigable waters.
No discharge of wastewater pollutants to
navigable waters.
No discharge of wastewater pollutants to
navigable waters.
No discharge of wastewater pollutants to
navigable waters.
There shall be no debris discharged and the
pH shall be within the range of 6.0 and 9.0
s.u.
No discharge of process wastewater
pollutants into navigable waters.
No discharge of process wastewater
pollutants into navigable waters.
No discharge of process wastewater
pollutants into navigable waters.
No discharge of process wastewater
pollutants into navigable waters.
No discharge of process wastewater
pollutants into navigable waters.
No discharge of process wastewater
pollutants into navigable waters.
No discharge of process wastewater
pollutants into navigable waters.
Source: 40 CFR 429; revised as of July 1, 1992.
\
6-4
September 1994
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Snbcatefory
A. Unbleached Kraft (facilities where
linerboard is produced)
A. Unbleached Kraft (facilities where
bag paper and other mixed
produced are produced
B. Semi -chemical
C. [reserved]
D. Unbleached Kraft— neutral sulfite
semi-chemical (cross recovery)
E. Paperboard from Wastepaper
F. Dissolving Kraft
G. Market Bleached Kraft
H. BCT Bleached Kraft
I. Fine Bleached Kraft
J. Papergrade Sulfite (Blow Pit
Wash)
K. Dissolving Sulfite Pulp (facilities
where Initiation grade pulp is
produced)
K. Dissolving Sulfite Pulp (facilities
where viscose grade pulp is
produced)
K. Dissolving Sulfite Pulp (facilities
where acetate grade pulp is
produced)
L. Envirorunental-Chemi-Mechanical
M. Groundwood— Thermo Mechanical
BOD,
1-Day Maximum
kg/tt«(or
pounds jMrtr
1 ,000 ib) or
product
3.4
5.0
3.0
3.9
2.6
15.6
10.3
8.5
5.7
4.38 exp (0.01 7x)
26.9
28.7
39.6
(reserved]
4.6
Maximum
Average of Dairy
Values for 30
Conseciitiyt
..: Day* :
k*/tt*>l>J
pnxnici .
0.00053
0.00053
0.00043
0.00059 .
0.00030
0.016
0.012
0.010
0.0018
(0.0036 exp
(0.017x)
0.019
0.019
0.021
0.00088
Zinc
1-Day Maximum
M/kk*(or
poiuMbptr
1,000 Ib) of
prtdOCt '• : - •
0.17
Exhibit 6-2. Federal New Source Performance Standards ; |
for the Pulp, Paper, and Paperboard Point Source Category 1
£
I
H
.5
9
-------
Snbcategory
N. Groundwood— CMN
O. Ground— Fine Papers
P. Soda
Q. Deink (facilities where fine paper
is produced)
Q. Deink (facilities where tissue
paper is produced)
Q. Deink (facilities where newsprint
is produced)
R. Nonintegrated Fine Papers (wood
fiber furnish subdivision)
S. Nonintegrated— Tissue Papers
T. Tissue from Wastepaper
U. Papergrade Sulfide (Drum Wash)
V. Unbleached Kraft and Semi-
chemical
W. Wastepaper— Molded Products
X. Nonintegrated— Lightweight
Papers
X. Nonintegrated— Lightweight
Papers (facilities where electrical
grade papers are produced)
Y. Nonintegrated— Fiber and
Nonwoven Papers
Z. Nonintegrated Paperboard
BOD,
i-Day Maximum
kf/kk|
-------
EIA Guidelines for Pulp & Paper and Timber Regulatory Overview
Regardless of specific limitations required by the Pretreatment Programs, 40 CFR Pan 403 requires
that the following may not be introduced into a POTW:
• Pollutants which create a fire or explosion hazard in the POTW
• Pollutants which will cause corrosive structural damage to the POTW, but hi no case
discharges with pH lower than 5.0, unless the treatment works specifically is designed to
accommodate such discharges
• Solid or viscous pollutants in amounts which cause obstruction to the flow hi sewers, or
other interference with the operation of the POTW
• Any pollutant, including oxygen-demanding pollutants, released in a discharge of such
volume or strength as to cause interference hi the POTW
In addition, there is a restriction on thermal discharges that became effective hi June 1981.
Pretreatment standards for new source pulp, paper, and paperboard facilities are established at 40
CFR Part 430 for pentachloropfaenol and trichlorophenol, and in some cases, zinc. The limits are not
shown hi this discussion since the permitting authority for these facilities is the POTW and thus,
exempts them from NEPA requirements for those discharges into a treatment works.
6.1.2 STORM WATER
Storm water runoff is regulated under the NPDES program at 40 CFR Parts 122, 123, and 124. In
1990, EPA issued regulations to address currently unpermitted discharges of storm water associated
with industrial activity. These storm water regulations are intended to reduce or eliminate pollutants
in discharges from construction activities disturbing five or more acres of land and certain industrial
facilities. To ease implementation of these regulations, EPA has issued construction and industrial
general permits under which eligible permittees are required to develop and implement storm water
pollution prevention plans. These plans must incorporate BMPs that control storm water discharges
and limit storm water contact with pollutants. The storm water regulations also allow permitting
authorities to issue individual storm water NPDES permits for discharges on a case-by-case basis.
Application to the Timber Products/Pulp and Paper Industry
Storm water discharges from the wood products/pulp and paper industry are regulated under 40 CFR
Part 122.26. The wood products industry is classified by Standard Industrial Classification (SIC)
codes 24 and 25, and the pulp and paper industry by SIC code 26. The SIC code manual describes
SIC group 24 as "establishments engaged in cutting timber and pulp wood; merchant sawmills, lath
mills, shingle mills, cooperage stock mills, planing mills, and plywood mills and veneer mills
engaged hi producing lumber and wood basic materials; and establishments engaged hi manufacturing
6-7 September 1994
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Regulatory Overview EIA Guidelines for Pulp & Paper and Timber
finished articles made entirely or mainly of wood or related materials." SIC group 26 is described as
"establishments primarily engaged in the manufacture of pulps from wood and other cellulose fibers,
and from rags; the manufacture of paper and paper board; and the manufacture of paper and
paperboard into converted products, such as paper coated off the paper machine, paper bags, paper
boxes, and envelopes."
, «
The wood products/pulp and paper industry is not subject to storm water effluent limitations
guidelines, therefore this industry has three permitting options under the storm water regulation.
These options are as follows: the general permit, the individual permit, and the group/multisector
permit. Facilities seeking coverage under the industrial general permit (57 FR 41236), must submit a
Notice of Intent (NOI) form, develop a pollution prevention plan, and wood treatment facilities are
subject to semi-annual monitoring requirements. For coverage under the individual permit, facilities
must complete Forms 1 (general information) and 2F (sampling data). EPA evaluates the individual
permit application and issues a facility-specific permit. Facilities that chose the group permit option
joined groups of facilities with similar industrial activities and submitted sampling data from
representative facilities within the group. EPA evaluated the sampling data and issued a draft
industry-specific multisector permit on November 19, 1993 (58 FR 61146). To obtain coverage
under this permit, facilities within the group must submit an NOI form, develop a pollution
prevention plan, and perform monitoring of storm water discharges.
6.2 CLEAN AIR ACT
The Clean Air Act (42 U.S.C. 7476(c), originally passed in 1967, and amended most recently in
November 1990, is the primary law protecting the Nation's air quality from pollutant emissions. The
Act requires EPA to promulgate a set of air quality standards, whose achievement is the overall
objective of the Act. These National Ambient Air Quality Standards (NAAQS) were established for
seven so-called "criteria" pollutants: ozone, carbon monoxide, particulates, sulfur dioxide, nitrogen
dioxide, and lead. The existing NAAQS for the seven pollutants are specified in Exhibit 6-3.
Primary standards are those necessary to protect the public health with an adequate margin of safety;
secondary standards are those necessary to protect the public welfare from any known or anticipated
adverse effects of air pollution. To achieve these standards, the Act requires States to develop State
Implementation Plans (SIPs) which combine region-specific compliance strategies with enforceable
emissions control requirements. Two additional programs that are designed to maintain the various
NAAQS include the New Source Review (NSR) and the New Source Performance Standards (NSPS)
that are applicable to major sources of emissions-of the seven criteria pollutants.
In addition to the criteria pollutants, the Act also requires control of emissions of toxic or hazardous
air pollutants (HAP) through establishment of the National Emission Standards for Hazardous Air
Pollutants (NESHAP) program.
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EIA Guidelines for Pulp & Paper and Timber
Regulatory Overview
Exhibit 6-3. National Primary and Secondary Ambient Air Quality Standards
(40 CFR Part 50)
Pollutant
Carbon monoxide
Nitrogen dioxide
Paniculate matter of
10 microns or less
(PM.10)
Sulfur dioxide
Lead
Ozone
Type of Standard
Primary
Primary and secondary
Primary
Secondary
Primary
Secondary
Primary
Primary and secondary
Averaging
Time
Ihr.
8hr.
lyr.
24 hr.
lyr.
24 hr.
lyr.
90 day
Ihr.
Frequency
Parameter
Daily maximum*
Daily maximum*
Arithmetic mean
Annual maximum0
Arithmetic meand
Annual maximum0
Arithmetic mean
Annual maximum0
Quarterly maximum'
Daily maTimum1
Concentration
ug/m3
40,000
10,000
100
150
50
365
80
1,300
1.5
235
ppm
35
9
0.05
-
-
0.14
0.13
0.5
0.12
* Expected exceedence less than or equal to one per year.
b Currently under review for possible revision.
0 Not to be exceeded more than once per year.
" As a guide in devising implementation plans for achieving oxidant standards.
' As a guide to be used in assessing implementation plans for achieving the annual maximum 24-hour
standard.
f Not to be exceeded more than once per 90 days.
Source: Adapted from U.S. Environmental Protection Agency. 1979a. A handbook of key Federal
regulations and criteria for multimedia environmental control. EPA-600/7-70-175. Research Triangle
Park, NC.
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Regulatory Overview EIA Guidelines for Pulp & Paper and Timber
While the November 15, 1990 amendments make significant changes to the Clean Air Act, these
changes are to be phased in over a number of years. Because of this transition period, it is necessary
to describe the Act as it stands now, as well as new provisions and when they will take effect.
6.2.1 CURRENT CLEAN Am ACT REQUIREMENTS
The three major existing requirements under the Clean Ah* Act, NSR, NSPS and NESHAP are
explained briefly below. .
Application to the Timber Products/Pulp and Paper Industry
The timber products processing industry generally is not considered a major source of air pollutant
emissions. Therefore, no national ah- pollution performance standards are established which apply to
atmospheric emissions from new source timber processing facilities. In the absence of Federal
emission standards for the timber industry, air quality impacts assessments are based on ambient air
quality standards and applicable State and local standards. However, timber products facilities may
be subject to New Source Review for non-attainment areas and the National Emissions Standards for
Hazardous Air Pollutants (NESHAPs).
New Source Performance Standards are established for kraft pulp mills. This subcategory as well as
others included in the pulp and paper industry may be subject to other requirements under the Clean
Air Act, including New Source Review and NESHAPs.
New Source Review
Newly constructed industrial timber products/pulp and paper facilities and expansions of existing
facilities that result in increased emissions are subject to a New Source Review (40 CFR Part 51).
The requirements of this review vary depending on whether or not air quality standards have been
attained in the area the site is located.
In areas already meeting air quality standards, rules for new sources are designed to prevent
significant deterioration (PSD) of air quality. The general requirements under these circumstances
arc:
• Compliance is necessary only for new major sources (potential emissions of any regulated
pollutant exceeding either 100 or 250 tons per year, depending on the source's industrial
category) and modifications to existing major sources (defined as 40 tons per year for sulfur
dioxide, nitrogen oxides, or volatile organic compounds [VOCs]).
• Construction of new sources cannot begin until a permit has been issued.
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Guidelines for Pulp & Paper and Timber Regulatory Overview
• Best Available Control Technology for controlling air pollutants (BACT), must be used.
BACT is identified by EPA on a case-by-case basis as the best state-of-the-art control
technology that could be used. The applicant must justify any departures from this
technology.
• After BACT requirements are satisfied, any residual emissions must be accounted for by an
available "increment" of air quality deterioration.
The restrictions are more severe in areas that have not attained the ambient air quality standards.
These requirements are outlined below:
• Compliance is necessary only for new major sources (potential emissions exceeding 100
tons per year of participates, sulfur dioxide, nitrogen oxides, VOCs, or carbon monoxide
and major modifications.
• Lowest Achievable Emission Rate technology (LAER) must be used. This technology must
be the most stringent control technology available.
• Any residual emissions after installation of LAER must be "offset" by emissions reductions
at other sources which must exceed the reductions expected from the application of LAER
technology.
PSD and non-attainment requirements are applied to each criteria pollutant separately. It is thus
possible for a new source to be required to meet non-attainment "offset" requirements for one
pollutant, while having to meet PSD "increment" requirements for another.
New Source Performance Standards (NSPS) a
Emissions limitations have been established for certain pollutants from new sources. Under the
current regulations, sources subject only to NSPS are not necessarily required to obtain a permit.
However, the NSPSs are self-implementing, meaning new sources are automatically subject to their
requirements.
New source performance standards have been promulgated affecting emissions from kraft pulp mills
(40 CFR Part 60, subpart BB). The paniculate standards are shown in Exhibit 6*4. The performance
standards mainly limit emissions of total reduced sulfur (TRS), which includes hydrogen sulfide, and
paniculate matter (PM) from various process areas in a kraft pulp mill. TRS emissions are regulated
from the following sources in a kraft mill:
• Digester system
• Brown stock washer system
• Multiple-effect evaporator system
• Condensate stripper system
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Regulatory Overview EIA Guidelines for Pulp & Paper and Timber
• Recovery furnace
• Lime kiln.
Exhibit 6-4. New Source Performance Standards for Particulates from Kraft Pulp Mills
Recovery furnace Maximum paniculate matter 0.10 g/d stdm3
(0.044 gr/d/stdft3) at 8% oxygen
Maximum 35% capacity
Smelt dissolving tank Maximum paniculate matter 0.1 g/kg black
liquor solids (BSL) (0.2 Ib/ton BLS) (dry
weight)
Limekiln: , Maximum paniculate matter 6.15 g/d/stdm3
When gaseous fossil fuel is burned (0.067 gr/d/stdft3) at 10% oxygen
When liquid fossil fuel is burned Maximum paniculate matter 0.30 g/d/stdm3
(0.13 gr/d/stdft3) at 10% oxygen
Source: 40 CFR Part 60, Subpart B.B.
Because quantification of odor is a subjective area in air pollution control, the TRS standards use
limitations on TRS emissions themselves rather than on the intensity of odors. This approach is
expected to ensure more objective and efficient enforcement. The TRS standards for the sources
listed above are presented in Exhibit 6-5. The standards for the last six of these sources may be
waived if the off gases are combusted hi a lime kiln or recovery furnace which meets the
requirements of the standards applicable to those sources, or in an incinerator or other device, or in a
lime kiln or recovery furnace not subject to the standards, provided they are subjected to a minimum
temperature of 649 degrees Celsius (1,200 degrees Fahrenheit) for at least 5 seconds.
These limitations are expected to prevent odor problems from most new kraft mills except in the
immediate vicinity when downwash conditions occur, and the proposed paniculate standards will
substantially reduce ground-level ambient air concentrations of that pollutant. These standards will
apply to all kraft pulp mills because they are not further subcategorized for purposes of air pollution
control.
PM emissions occur from:
• Recovery furnace
• Lime kiln
• Smelt dissolving tank.
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EIA Guidelines for Pulp & Paper and Timber
Regulatory Overview
1
1
<
Exhibit 6-5. New Source Performance Standards for Total Reduced Sulfur (TRS)
for Kraft Pulp Mills
System
Recovery Furnace
Cross Recovery Furnace
Lime Kiln
Brown Stock Washer System
Condensate Stripping System
Digester System
Multiple-Effect Evaporator System
Smelt Dissolving Tank
Pirn*
5"
25"
8e
5C
5C
5C
5C
g/kg Ob/ton) BLS
(dry weight)
0.016 (0.033)
'By volume dry basis.
•Corrected to 8% oxygen.
Corrected to 10% oxygen.
Source: 40CFRPart60
In order to satisfy the NSPS requirements, depending on the processes and control equipment at a
kraft mill, continuous emissions monitoring systems (CEMS) must be installed for taking opacity
measurements and concentrations of TRS or PM.
No performance standards have been established for new timber products sources. Although NSPS
does not exist for this category, all criteria and toxic air pollutants emissions from it would still be
subject to the new source and other applicable control requirements.
National Emissions Standards for Hazardous Air Pollutants (NESHAPs)
The 1970 Clean Air Act authorized EPA to set special standards for hazardous air pollutants. EPA
has established NESHAPs for seven substances: arsenic, asbestos, benzene, beryllium, mercury,
radionuclides, and vinyl chloride (see 40 CFR Part 61).
6.2.2 CHANGES TO TAKE EFFECT AS 1990 AMENDMENTS ARE PHASED IN
Several new or more stringent requirements will come into effect as the 1990 Clean Air Act
Amendments are implemented. A major difference in implementation of the results from the
enactment of these Amendments is the definition of nonattainment areas for criteria pollutants. With
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Regulatory Overview EIA Guidelines for Pulp & Paper and Timber
the enactment of the Amendments in November 1990, a nonattainment area for a criteria pollutant
was classified on the basis of severity of nonattainment of standard. This severity was determined by
comparison of ambient measurements of pollutant concentration with NAAQS. Other significant
changes relate to a new federal-level permit program and overhaul of the air toxics program. New
provisions are described briefly below.
Application to the Timber Products/Pulp and Paper Industry
Federal Permit Program
The new Amendments place much greater emphasis on federal control than the previous SIP-
dependent Act. They require virtually all significant sources of ah* emissions to obtain permits.
Definition of a significant source varies with the pollutant emitted and the area in which the emitting
source is located. For instance a source in a severe ozone nonattainment area emitting at least 50 tons
per year of VOC is considered significant while in a marginal nonattainment area a source emitting
at least 100 tons per year of VOC is significant. SIP requirements are often applied genetically,
permitting an array of industrial operations to take place as long as appropriate pollution controls are
installed. The permit program will be much more specific, defining applicable emissions limits for
each individual source. Any operational change that increases emissions above specified limits will
probably necessitate permit modifications.
New Source Review
Under the newly defined limits for New Source Review any existing source that emits or has the
potential to emit 100 tons or more per year of a pollutant becomes subject to modifications to its
permit if the source undertakes modifications to existing processes (40 CFR 51). However, this
threshold becomes more stringent if the source is located in a nonattainment area that has been
classified as severe or extreme. For instance in an ozone nonattainment area classified as extreme,
and increase in VOC emissions resulting from modifications to new sources or from construction of
new plants will require a review. Additionally, kraft pulp mills are defined as a major source
category from which fugitive emissions must be accounted for in any determinations that affect its
status for new source review (40 CFR 51).
Non-Attainment Offsets
Unless an area is covered by an EPA-approyed growth allowance, a major source or major
modification in a nonattainment area must obtain emissions offsets as a conditions of approval. These
offsets are generally obtained from existing sources located in the vicinity of a planned source so as:
to offset the increase in net emissions resulting from the new source; and to provide a net air quality
benefit. The offsets are to be reviewed by taking into account:
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EIA Guidelines for Pulp & Paper and Timber Regulatory Overview
• Pollutants requiring offsets and amount of offset required
• Location of offsets relative to the proposed source
. • Allowable source for offsets
• "Baseline" for calculating emissions reduction credits
• Enforceability of proposed offsets
New Source Performance Standards (NSPS)
Permits will be required for all new sources that are subject only to NSPS. Permits must be obtained
before any construction can begin.
National Emission Standard for Hazardous Air Pollutants (NESHAPs)
Section 112 of 1990 Clean Air Act required that NESHAP be promulgated for categories of major
sources of 189 hazardous air pollutants (HAPs). For the purposes of this section a major source is
defined as emitting at least 10 tons per year of a single HAPs or 25 tons per year of any combination
of HAPs. The original strategy for controlling these emissions was changed under Section 112(d)
from a substance-specific numerical approach, to one relying on the use of Maximum Achievable
Control Technology (MACT), which can take into account the associated costs of control.
An initial list of major source categories for HAPs was promulgated on July 16, 1992 (57 FR 31576)
which included pulp and paper (integrated, non-integrated and secondary fiber) mills as well as timber
products processing (wood treatment, plywood/particle board manufacturing). Final NESHAP
promulgation for pulp and paper, and timber processing industry is expected no later than 1997.
On December 17, 1993 (58 FR 66078) EPA published draft regulations that would limit some but not
all HAP emissions from pulp mills that use kraft, sulfite, soda and semi-chemical methods. EPA
expects these regulations to affect approximately 161 mills. The proposed MACT standards would
affect HAP emissions from non-combustion sources in these mills. The emitted HAPs that are likely
to be controlled by this regulation include methanol, hexane, toluene, methyl ethyl ketone,
chloroform, chlorine, formaldehyde, acrolein, and acetaldehyde. EPA expects to promulgate the final
NESHAPSs for this category in 1995.
6.3 RESOURCE CONSERVATION AND RECOVERY ACT
The Solid Waste Disposal Act (SWDA) of 1965 and major amendments of the Resource Conservation
and Recovery Act (RCRA) of 1976 and the Hazardous and Solid Waste Amendments (HSWA) of
1984 comprise the principal federal law mandating regulation of both solid and hazardous waste.
Collectively referred to as RCRA, the law consists of three basic parts: Subtitle D, which encourages
States to develop plans for controlling their non-hazardous solid waste, Subtitle I, which applies to
underground storage tanks (USTs), and Subtitle C, which mandates a system to regulate hazardous
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Regulatory Overview EIA Guidelines for Pulp & Paper and Timber
, j
wastes from the time of their generation to the time of their disposal. Because it has placed most of
the burden of non-hazardous waste regulation onto the States, RCRA is now synonymous with
hazardous waste regulation. Once a waste is determined to be hazardous, any generator, transporter
or manager of such waste must comply with the pertinent rules promulgated under Subtitle C.
A waste is regulated as hazardous if:
• It is not specifically excluded from regulation as a hazardous waste (40 CFR Part 261.4)
AND
• It exhibits one of the hazardous characteristics detailed in 40 CFR Part 261 Subpart C
(ignitability, corrosivity, reactivity, or toxicity)
OR
• It is specifically listed as a hazardous waste (40 CFR Part 261, Subpart D).
The wastes excluded from regulation typically include wastes recycled in certain ways, wastes
regulated under separate statutes (such as the Clean Water Act), and particular wastes from certain
industries.
6.3.1 NON-HAZARDOUS WASTE REQUIREMENTS - SUBTITLE D
Subtitle D's provisions include minimum standards for protecting human health and the environment
at solid waste landfills and technical guidance for States on establishing environmentally-sound solid
waste management plans. The specific regulatory controls on non-hazardous waste depend on the
requirements of State plans. For questions concerning non-hazardous waste regulation in a particular
State, a copy of the State's solid waste management plan should be consulted. 40 CFR Part 257
establishes criteria for the classification of solid waste disposal facilities and practices and applies to
non-hazardous waste generated at industrial facilities, other than those defined at point source
discharges.
6.3.2 HAZARDOUS WASTE REQUIREMENTS - SUBTITLE C
The hazardous waste regulations provide for a comprehensive "cradle to grave" system of
management and include rules governing waste disposed of on land, recycling, and generators, and
transport, storage, or disposal facilities (TSDFs). The applicability of these regulations is generally
uniform across industry, and is driven by the listing process. If a waste is hazardous, it is subject to
these regulations.
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EIA Guidelines for Pulp & Paper and Timber Regulatory Overview
6.3.3 LAND DISPOSAL RESTRICTIONS
The Hazardous and Solid Waste Amendments (HSWA) of 1984 (40 CFR Part 268) prohibits the land
disposal of any hazardous waste that does not meet certain treatment standards. Treatment standards
may be concentration-based (the most common) or technology-based (use of the best demonstrated
available technology [BOAT]). HSWA automatically prohibits the land disposal of hazardous wastes
if EPA fails to establish treatment standards for them by certain statutory deadlines (see 40 CFR
268.10 - 268.12). Wastes may be excluded from these land disposal restrictions (LDR) under
circumstances described at 40 CFR 268. l(c).
6.3,4 RECYCLING AND REUSE EXEMPTIONS AND PROVISIONS
Under 40 CFR 261.2(e), certain recyclable materials are exempt from hazardous waste regulation if
they qualify as one of the following:
• Wastes used or reused as ingredients in production without first being reclaimed
• Waste used or reused as substitutes for commercial products without first being reclaimed
• Wastes returned to the original process that generated them without first being reclaimed.
RCRA also contains standards at 40 CFR Part 266 concerning the land application of recyclable
materials derived from hazardous waste, the burning of hazardous waste for energy recovery, and the
burning of hazardous waste in boilers and industrial furnaces.
6.3.5 HAZARDOUS WASTE GENERATORS
All generators of hazardous waste are required to determine if the waste is hazardous and, in most
cases, determine the amount generated in each calendar month. Requirements for generators vary
according to the amount of waste produced, with small quantity generators subject to the least
stringent controls.
Medium and large quantity generators are facilities that generate between 100-1,000 kg and greater
than 1,000 kg of hazardous waste per month, respectively. They have similar types of requirements,
although some requirements are more strict for large quantity generators.
Medium and large quantity generators having waste transported off-site must certify that they have a
waste minimization program in place to reduce the amount and/or toxicity of the hazardous waste
generated prior shipment to a transport, storage, or disposal facility (TSDF).
Medium and large quantity generators may accumulate hazardous waste on site without obtaining a
TSDF permit provided they comply with the regulations regarding quantity limits, time constraints,
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Regulatory Overview EIA Guidelines for Pulp & Paper and Timber
and technical storage standards for on-site accumulation, and requirements for personnel training,
emergency procedures, and preparedness and prevention of accidents and spills (see 40 CFR 262.34).
6.3.6 HAZARDOUS WASTE TREATMENT, STORAGE, AND DISPOSAL FACILITIES
As with transporters, hazardous waste management facilities must obtain a permit before beginning
operations. Under such permits, TSDFs must comply with the following requirements:
• General waste handling requirements—personnel training, waste analysis prior to
management, location standards (fault zones and flood plains)
• Preparedness and Prevention
• Contingency plans and emergency procedures.
Ground Water Monitoring
In addition to the TSDF requirements outlined above, HSWA of 1984 added certain minimum
technical requirements (MTRs) for the construction of hazardous waste management facilities. All
new facilities completed after HSWA's enactment must have, at a minimum, double liners and
leachate detection and control systems in place. Retrofitting of most facilities existing at the time of
HSWA's enactment was to have been finished in 1988. Any waste exempt from the land disposal
restrictions of HSWA must still go to a MTR-equipped facility for its disposal or management.
Under Parts 264 and 265, RCRA also specifies more detailed operating parameters for the following
(Standards for these processes are specified only for interim status facilities [40 CFR Part 265]):
• Container storage units
• Tank systems
• Land treatment
• Incinerators
• Landfills
• Drip pads
• Surface impoundments
• Waste piles
• Underground injection wells
• Thermal treatment units
• Chemical, physical, biological treatment units.
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EIA Guidelines for Pulp & Paper and Timber Regulatory Overview
Application to the Timber Products/Pulp and Paper Industry
While the majority of RCRA's hazardous waste regulations apply generally to all facilities and wastes,
certain provisions and controls address specific industries. Several listed hazardous wastes result
from operations at timber products/pulp and paper processing facilities. Listed wastes from these
operations as classified under 40 CFR Parts 261.31 and 261.32 include the following:
F032 Wastewaters (except those that have not come into contact with process contaminants),
process residuals, preservative drippage, and spent formulations from wood preserving
processes generated at plants that currently use or have previously used chlorophenolic
formulations (except potentially cross-contaminated wastes that are otherwise currently
regulated as hazardous wastes (i.e., F034 and F035), and where the generator does hot
resume or initiate use of chlorophenolic formulations. This listing does not include K001
bottom sediment sludge from the treatment of wastewater from wood preserving processes
that use creosote and/or pentachlorophenol.
F034 Wastewaters (except those that have not come into contact with process contaminants),
process residuals, preservative drippage, and spent formulations from wood preserving
processes generated at plants that use creosote formulations. This listing does not include
K001 bottom sediment sludge from the treatment of wastewater from wood preserving
processes that use creosote and/or pentachlorophenol.
F035 Wastewaters (except those that have not come into contact with process contaminants),
process residuals, preservative drippage, and spent formulations from wood preserving
processes generated at plants use inorganic preservatives containing arsenic or chromium.
This listing does not include K001 bottom sediment sludge from the treatment of wastewater
from wood preserving process that use creosote and/or pentachlorophenol.
KOOl Bottom sediment sludge from the treatment of Wastewaters from wood preserving processes
that use creosote and/or pentachlorophenol.
Any wastes that meet these listing definitions are subject to RCRA hazardous waste regulations.
Also, any wastes that are mixed with these listed hazardous wastes becomes a listed hazardous waste
under the mixture rule (40 CFR Part 261.3).
In addition, KOOl wastes are subject to Land Disposal Restrictions (LDR) under 40 CFR Part 268.41
and 40 CFR Part 268.43. This waste cannot be disposed of in a land unit (i.e., land unit, surface
impoundment) unless it has been treated such that constituent levels in the waste are below certain
levels. Typically, this waste is incinerated hi a RCRA permitted hazardous waste incinerator. LDR
standards for F032, F034, and F035 are currently under development.
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Regulatory Overview EIA Guidelines for Pulp & Paper and Timber
Wastes excluded from listing as hazardous under 40 CFR Parts 261.31 and 261.32 include spent
wood preserving solutions that have been reclaimed and are reused for their original intended purpose
and wastewaters from the wood preserving process that have been reclaimed and are reused to treat
wood.
6.4 ENDANGERED SPECIES ACT
Established in 1973, the Endangered Species Act (16 U.S.C. 1531-1544; P.L. 93-205) provides a
means whereby the ecosystems supporting threatened or endangered species may be conserved and
provides a program for the conservation of such species. The Act requires that all federal
departments and agencies seek to conserve endangered and threatened species and cooperate with state
and local agencies to resolve water resource issues in concert with conservation of endangered
species.
Section 7 of the Act requires federal agencies to ensure that all federally associated activities within
the United States do not have adverse impacts on the continued existence of threatened or endangered
species or on designated areas (critical habitats) that are important in conserving those species.
Agencies undertaking a federal action must consult with the U.S. Fish and Wildlife Service
(USFWS), which inajntgjns current lists of species that have been designated as threatened or
endangered, to determine the potential impacts a project may have on protected species. The National
Marine Fisheries Service undertakes the consultation function for marine and anadromous fish species
while USFWS is responsible for terrestrial, wetland, and fresh water species.
Application to the Timber Products/Pulp and Paper Industry
The USFWS has established a system of informal and formal consultation procedures (40 CFR Part
402), and the results of informal or formal consultations with the USFWS under Section 7 of the Act
should be described and documented in the EIA/EIS. Sections of an EIA/EIS that should include
endangered and threatened species information are the Project Alternatives and the Affected
Environment sections. If a threatened or endangered species may be located within die project area
and may be affected by the project, a detailed endangered species assessment (Biological Assessment)
may be prepared independently or concurrently with the EIS and included as an appendix to the EIA/
EIS.
6.5 NATIONAL HISTORIC PRESERVATION ACT AND EXECUTIVE ORDER 11593
The National Historic Preservation Act of 1966 (16 U.S.C. 470 et seq., P.L. 89-665) as amended
(P.L. 95-515) establishes federal programs to further the efforts of private agencies and individuals in
preserving the historical and cultural foundations of the nation. The Act authorizes the establishment
of the National Register of Historical Places. It establishes an Advisory Council on Historic
Preservation authorized to review and comment upon activities licensed by the federal government
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EIA Guidelines for Pulp & Paper and Timber Regulatory Overview
t
that have an effect upon sites listed on the National Register of Historic Places or that are eligible to
be listed. The Act sets up a National Trust Fund to administer grants for historic preservation. The
Act authorizes the development of regulations under Section 106 to require a federal agency to take
into account the effects of federal-assisted activities on properties included in or eligible for the
National Register of Historic Places.
A series of amendments to the National Historic Preservation Act in 1980 contain codification of
portions of Executive Order 11593 (Protection and Enhancement of the Cultural Environment—
16 U.S.C 470). These amendments require an inventory of federal resources and federal agency
programs to protect historic resources and authorize federal agencies to charge federal permittees and
licensees reasonable costs for protection activities.
Application to the Timber Products/Pulp and Paper Industry
The Advisory Council on Historic Preservation has established a system of consultation procedures at
36 CFR Part 800, under which the responsible official should ensure compliance by documenting any
action that would affect any property listed or eligible for listing on the National Register of Historic
Places. Such properties include any historic, architectural, archeological or cultural entity identified
by the Department of Interior as valuable and listed on the National Register or determined to be
eligible for listing by the Keeper of the National Register. Other statutes which must be considered in
the EIA/EIS include the Historic Sites Act of 1935 (16 U.S.C. 461 et seq.), and the Archaeological
and Historic Preservation Act of 1974 (16 U.S.C 469 et seq.).
6.6 EXECUTIVE ORDER 11988
Executive Order 11988 (Floodplain Management) of 1977 requires a construction agency to "...avoid
to the extent possible the long- and short-term adverse impacts associated with the occupancy and
modification of floodplains and to avoid direct and indirect support of floodplain development
wherever there is a practicable alternative..." within the 100-year flood elevation.
Application to the Timber Products/Pulp and Paper Industry
For an EIA/EIS, this requires that alternatives to avoid development in a floodplain be considered. If
development requires siting in a floodplain, action shall be taken to modify or design the facility in a
way to avoid damage by floods.
6.7 EXECUTIVE ORDER 11990
Executive Order 11990 (Protection of Wetlands) of 1977 is similar to E.O. 11988 in that it requires a
construction agency to "...avoid to the extent possible, the long- and short-term adverse impacts
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Regulatory Overview EIA Guidelines for Pulp & Paper and Timber
associated with the destruction or modification of wetlands and to avoid direct or indirect support of
new construction in wetlands wherever there is a practicable alternative..."
Application to the Timber Products/Pulp and Paper Industry
When constructing a new facility, actions that minimize the destruction, loss, or degradation of
wetlands, and actions to preserve and enhance the natural and beneficial values of wetlands are
required. If there is no practicable alternative to wetland construction projects, the proposed action
must include measures to minimize harm. Construction in wetlands also falls under Section 404 of
the Clean Water Act administered by the U.S. Army Corps of Engineers.
6.8 WILD AND SCENIC RIVERS ACT
The Wild and Scenic Rivers Act of 1968 (P.L. 90-542, 16 U.S.C. 1273 et seq.) ensures that
"...Certain selected rivers...shall be preserved in a free flowing condition, and that they and their
immediate environments shall be protected for the benefit and enjoyment of present and future
generations." The Act, in Section 7, prohibits the issuance of a license-for construction of any water
resources project that would have a direct, adverse effect (stop free-flowing conditions of affect their
local environments) on the rivers of the United States selected as possessing remarkable scenic,
recreational, geologic, fish and wildlife, historic, cultural, or other similar values.
Application to the Timber Products/Pulp and Paper Industry
The National Rivers Inventory has selected rivers and streams placed by acts of Congress, while other
rivers and streams have been proposed to be included in the inventory. During project planning and
project impacts identification for an EIA/EIS, these rivers and streams must be considered and the
finding should be noted in a Wild and Scenic Rivers Act summary. While there is no legal
requirement to consider State-listed wild and scenic rivers and streams or unique areas during project
planning or in an EIA/EIS, it is recommended that any impacts to such areas be considered and
addressed as with the federal Wild and Scenic Rivers Act requirements.
6.9 FISH AND WILDLIFE COORDINATION ACT
Enacted in 1934, the Fish and Wildlife Coordination Act (16 U.S.C. 661 et seq., P.L. 85^624)
authorizes the Secretary of Interior to provide assistance to, and cooperate with, federal, State, and
public or private agencies and organizations in the development, protection, rearing, and stocking of
all species of wildlife, resources thereof, and their habitat. The majority of the Act is associated with
the coordination of wildlife conservation and other features of water-resource development programs.
6-22 September 1994
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EIA Guidelines for Pulp & Paper and Timber Regulatory Overview
Application to the Timber Products/Pulp and Paper Industry
The EIA/EIS should include a Fish and Wildlife Coordination Act report which includes all
coordination efforts in the planning process of the project with the Act, and recommendations of the
USFWS must be summarized in the EIA/EIS, usually as pan of the Consultation and Coordination
section.
6.10 RIVERS AND HARBORS ACT
Section 10 of the Rivers and Harbors Act of 1899 (33 U.S.C. 401-413; 33 CFR 322) prohibits the
unauthorized obstruction or alteration of any navigable waters of the United States. Under Section 10
of the Act, a permit is required from the U.S. Army Corps of Engineers for the construction of any
structure hi or over navigable waters of the United States. Section 10 is usually combined with
Section 404 of the Clean Water Act, which covers the discharges of fill to all waters of the United
States (as opposed to Section 10, which covers only navigable waters).
6.11 COASTAL ZONE MANAGEMENT ACT
The Coastal Zone Management Act's (15 CFR 930, P.L. 92-583) purpose is "to preserve, protect,
develop, and where possible, restore or enhance, the resources of the Nation's coastal zone for this
and future generations." To achieve this goal, the Act provides for financial and technical assistance
and federal guidance to States and territories for the conservation and management of coastal
resources.
c<
States are encouraged, but not required, by the Act to develop a coastal zone management program
considering such things as ecological, cultural, historic, and aesthetic values as well as economic
development needs. Section 307(c) of the Act prohibits the EPA from issuing a permit for any
activity affecting land or water use in the coastal zone until the applicant certifies that the proposed
activity complies with the State Coastal Zone Management program, and the state or its designated
agency concurs with the certification.
6.12 POLLUTION PREVENTION ACT OF 1990
The Pollution Prevention Act of 1990 establishes a national policy declaration that "...pollution should
be prevented or reduced at the source whenever feasible; pollution that cannot be prevented should be
recycled in an environmentally safe manner whenever feasible; pollution that cannot be prevented or
recycled should be treated in an environmentally safe manner whenever feasible; and disposal or other
release into the environment should be employed only as a last resort and should be conducted in an
environmentally safe manner."
6-23 September 1994
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Regulatory Overview EIA Guidelines for Pulp & Paper and Timber
In an effort to realize opportunities for source reduction and multi-media management of pollution,
and educate businesses about pollution prevention practices, EPA developed the Pollution Prevention
Act of 1990 as the Nation's preferred approach to environmental protection and waste management.
Through the Act, EPA encourages industry and Federal facilities to take voluntary action to identify
and implement pollution prevention, promulgates and enforces regulations thereby encouraging
industry and Federal facilities to minimize waste, and conducts a variety of initiatives designed to
promote pollution prevention.
6.13 FARMLAND PROTECTION POLICY ACT
Under the Farmland Protection Policy Act of 1980 (P.L. 97-98), the U.S. Soil Conservation Service
(SCS) is required to be contacted and asked to identify whether a proposed facility will affect any
lands classified as prime and unique farmlands.
6.14 OTHER STATUTES
There are various other statutes that may affect the review of NEPA documentation for new source
timber products/pulp and paper products facilities. These other acts are not discussed in this draft,
but include the Oil Pollution Control Act of 1990, Coastal Barrier Resources Act, the Toxic
Substances Control Act (TSCA), the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA),
the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), the Safe
Drinking Water Act, the Emergency Planning and Community Right-to-Know Act (EPCRA), Shore
Protection Act of 1988, and the Marine Protection, Research, and Sanctuaries Act of 1972.
6-24 September 1994
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EIA Guidelines for Pulp & Paper and Timber References
7. REFERENCES
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pp 167-171.
Hardwood, Plywood and Veneer Association. 1993. The Hardwood Pfywood Reference Guide and
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7-1 September 1994
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References EIA Guidelines for Pulp & Paper and Timber
Hampi, V., Johnston, O.E., and Watkins, D.S. 1988. "Application of an Air Curfain-exhaust
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NCASI. April 1984. The Trace Element Content of Effluents From Direct Steam Log Conditioning
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NCASI. April 1985. Volatile Organic Carbon Emissions From Wood Residue Fired Power Boilers in
the Southeast. Technical Bulletin No. 455.
NCASI. May 1985. The Land Application of Wastewater in the Forest Products Industry. Technical
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7-2 September 1994
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EIA Guidelines for Pulp & Paper and Timber References
NCASI. July 1985. Summary of West Coast Experience With Emissions From Wood-Residue Fired
Boilers While Burning Tire Derived Fuel (IDF) as a Supplemental Fuel. Technical Bulletin No.
465.
NCASI. December 1985. Recent Studies and Experience With the Use of Sludge and Ffy Ash on
Farm Crop and Forest Lands. Technical Bulletin No. 478.
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Industry. Technical Bulletin No. 504.
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Application of Wastewater Sludge in Maine. Technical Bulletin No. 525.
NCASI. October 1989. Pulping Effluents in the Aquatic Environment—Parti: A Review of the
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NCASI. October 1989. Pulping Effluents in the Aquatic Environment—Part tt: A Review of
Unpublished Studies ofln-Stream Aquatic Biota in the Vicinity of Pulp Mill Discharges.
Technical Bulletin No. 573.
NCASI. October 1989. The Use of Environmental Audits and Assessments by the Forest Products
Industry for Timberland Operations. Technical Bulletin No. 574.
NCASI. May 1990. U.S. Environmental Protection Agency/Paper Industry Cooperative Dioxin
Study: The 104 Mill Study. Technical Bulletin No. 590.
NCASI. May 1990. An Imensive Study of the Formation and Distribution of 2,3,7,8-TCDD and
2,3,7,8-TCDF During the Bleaching of Kraft Pulps. Technical Bulletin No. 591.
NCASI. September 1990. Experience With Anaerobic Treatment of Forest Products Industry
Effluents and Sludges in Laboratory Pilot Plant and Full-Scale Installations. Technical Bulletin
No. 596.
NCASI. November 1990. A Review of the Literature on Subsurface Biological Processes Which
Effect the Fate of Chemicals in Groundwater. Technical Bulletin No. 599.
NCASI. May 1991. 1990 Review of the Literature on Pulp & Paper Industry Effluent Management.
Technical Bulletin No. 607.
NCASI. May 1991. A Critical Review of the Literature on the Bioaccumulation of 2,3,7,8-
Tetrachlorodibenzo-P-Dioxin and Furan in Fish. Technical Bulletin No. 610.
7.3 September 1994
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References EIA Guidelines for Pulp & Paper and Timber
NCASI. September 1991. Bleach Plant Chlorine and Chlorine Dioxide Emissions and Their Control.
Technical Bulletin No. 616.
NCASI. September 1991. Characterization of Wastes and Emissions From Mills Using Recycled
Fiber. Technical Bulletin No. 613.
NCASI. December 1991. An Assessment of Exposure to Dioxin From Consumption of Fish Caught
in Freshwaters of the U.S. Impacted by Bleached Chemical Pulp Mills. Technical Bulletin No.
620.
NCASI. December 1991. Delignification and Bleaching of Chemical Pulps With Ozone: A
Literature and Patent Review. Technical Bulletin No. 619.
NCASI. January 31, 1992. Current Listing and Index of NCASI Technical Bulletins and Special
Reports. Bulletin #53.
NCASI. January 1992. A Study of Formaldehyde Emissions From Wood Residue-Fired Boilers.
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NCASI. July 1992. Stormwater From Log Storage Sites: A Literature Review & Case Study.
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NCASI. September 1992. Cesium-137 in Industrial Wood Ash: Concentrations, Fate, and Human
Health Risks. Technical Bulletin No. 639.
NCASI. September 1992. Sulfur Capture in Combination Bark Boilers. Technical Bulletin No. 640.
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7.4 September 1994
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EIA Guidelines for Pulp & Paper and Timber References
U.S. Department of Agriculture, Forest Service. September 1993. Forest Resources of the United
States, 1992. General Technical Report RM-234.
U.S. Department of Commerce, International Trade Administration. 1992. U.S. Industrial Outlook.
1992
U.S. Department of Commerce, International Trade Administration. 1993. U.S. Industrial Outlook.
1993
U.S. Department of Commerce, International trade Administration. 1994. U.S. Industrial Outlook.
1994
U.S. Department of Commerce, International Trade Administration. 1994. U.S. Industrial Outlook
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Limitations Guidelines and New Source Performance Standards for the West Storage, Sawmills,
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U.S. Environmental Protection Agency. 1974. Development Document for Proposed Effluent
Limitations Guidelines and New Source Performance Standards for the Wood Furniture and
Fixture Manufacturing Segment of the Timber Products Processing Point Source Category. EPA
440/l-74-033a.
U.S. Environmental Protection Agency. 1974. Development Document for Effluent Limitations
Guidelines and New Source Performance Standards for the Plywood, hardboard, and Wood
Preserving Segment of the Timber Products Processing Point Source Category. EPA 440/1-74-
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Limitations Guidelines and Standards for the Timber Products Processing Point Source
Category. EPA 440/l-79/023b.
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, Associated With Exposures to Mixtures of Chlorinated Dibenzo-P-Dioxins and Dibenzqfiirans
(CDDs and CDFs). Risk Assessment Forum. EPA/625/3-89/016.
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Final Listing of Wastes from Wood Preservation Processes.
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7.5 September 1994
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References EIA Guidelines for Pulp & Paper and Timber
U.S. Environmental Protection Agency, Industrial Technology Division. December-1986.
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Pulp, Paper, and Paperboard Industry - Background Information for Proposed Air Emission
Standard. Manufacturing Processes at Kraft, Sulfite, Soda, and Semi-Chemical Mills. EPA-
453/R-93-050a.
U.S. Environmental Protection Agency, Office of Pesticides and Toxic Substances. February, 1988.
Title III Section.313 Release Reporting Guidance: Estimating Chemical Releases from Wood
Preserving Operations. EPA 560/4-88-004p.
U.S. Environmental Protection Agency, Office of Pesticides and Toxic Substances. March, 1988.
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Presswood and Laminated Wood Products Manufacturing Operations. EPA 560/4-88-004i.
U.S. Environmental Protection Agency, Office of Pollution Prevention and Toxics. April 1994.
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Demonstrated Available Technology (BDAT) Background Document for K001. Volume 16.
EPA/530-SW-88-0009-0.
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U.S. Environmental Protection Agency, Office of Solid Waste. November 1989. Proposed Best
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7-6 September 1994
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EIA Guidelines for Pulp & Paper and Timber References
U.S. Environmental Protection Agency, Office of Solid Waste. May 1990. Final .Best Demonstrated
Available Technology (BOAT) Background Document for U and P Wastes and Multi-Source
Leachate (F039). Volume C. Non-Wastewater Forms of Organic U and P Wastes and Multi-
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7-7 September 1994
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References EIA Guidelines for Pulp & Paper and Timber
U.S. Environmental Protection Agency, Office of Water Regulations and Standards.: March 1988.
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Wapora, Inc. (prepared for U.S. Environmental Protection Agency, Office of Environmental
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Wapora, Inc. (prepared for U.S. Environmental Protection Agency, Office of Environmental
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World Health Organization (WHO). 1987. Environmental Health Criteria 71 Pentachlorophenol.
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Zaidi, A., Buisson, H., Sourirajan, S., and Wood, H. 1992. "Ultra and Nano-filtration in Advanced
Effluent Treatment Schemes for Pollution Control in the Pulp and Paper Industry." Water
Science and Technology. Vol 25., No. 10., pp. 263-276.
40 CFR Part 429
45 FR 33063
46 FR 3364
46 FR 8285
46 FR 57287
47 FR 9829
50 FR 26310
51 FR 32606
7.8 September 1994
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EIA Guidelines for Pulp & Paper and Timber References
55 FR 50450
56 FR 20541
56 FR 30912
56 FR 63848
.57FR1796
57 FR 61492
58 FR 63247
58 FR 65959
59 FR 12567
7-9 September 1994
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