United States        Office of         EPA \Vi f^7>00
           Environmental Protection     Environmental Review     Sep'e^tx:- 1V/9
           Agency          Washi-^on DC 20460
SEPA     Environmental Impact
           Assessment Guidelines
           For New Source
           Pulp and Paper Mills

This document is available to the public through the National Technical
Information Service, Springfield, Virginia  22161.

                                      September,  1979


 for New Source Pulp and Paper Mills
             Prepared by

            WAPORA, Inc.
        6900 Wisconsin Avenue
       Washington, D.C.  20015
 EPA Task Officer:  John W. Meagher
   Office of Environmental Review
U.S. Environmental Protection Agency
       Washington, D.C.  20460

     This document is one of a series of industry specific Environmental
Impact Assessment Guidelines being developed by the Office of Environ-
mental Review for use in EPA's Environmental Impact Statement preparation
program on New Source NPDES permits.  It is intended to be used in
conjunction with Environmental Impact Assessment Guidelines for Selected
New Source Industries, on OER publication that includes a description of
impacts common to most industrial new sources.

     The requirement for federal agencies to assess the environmental
impacts of their proposed actions is included in Section 102 of the
National Environmental Policy Act of 1969 (NEPA), as amended.  The
stipulation that EPA's issuance of a New Source NPDES permit is an action
subject to NEPA is in Section 511(c)(1) of the Clean Water Act of 1977.
EPA's regulations for preparation of Environmental Impact Statements ^i-e
in Part 6 of Title 40 of the Code of Federal Regulations, NEPA procedures
for the jNew Source NPDES Program are described in Subpart F of Part 6.


List of Figures	    v^

List of Tables	vii



      I.E.  MAJOR PROCESSES	     7

            I.B.I.   Wood Preparation 	     7
            I.E.2.   Pulping  	     8

                    I.E.2.a.  Kraft Pulping  	     8
                    I.B.2.b.  Sulfite Pulping  	    12
                    I.B.2.C.  Neutral Sulfite Semichemical Pulping .  .    12
                    I.B.2.d.  Mechanical Pulping 	    14
                    I.B.2.e.  Waste Paperboard Production  	    15
                    I.B.2.f.  Deinking 	    16

            I.E.3.   Papermaking  	    20

      I.C.  TRENDS	    20

            I.C.I.   Location Changes 	    20
            I.C.2.   Raw Materials	    24
            I.C.3.   Processes  	    27
            I.C.4.   Pollution Control  	    29
            I.C.5.   Environmental Impact	, ,	    32
            I.C.6.   Markets and Demands	    33


            I.D.I.   Location .	    35
            I.D.2.   Raw Materials	    35
            I.D.3.   Processes  	    37
            I.D.4.   Pollution Control  	    37

      I.E.  REGULATIONS	    41

            I.E.I.   Water Pollution  	    41
            I.E.2.   Air Pollution	    47
            I.E.3.   Land Disposal of Wastes	    55



      II.A.  PROCESS WASTES	    57

             II.A.I.  Wood Preparation 	    57
             II.A.2.  Kraft Pulping  	    57
             II.A.3.  Sulfite Pulping  	    61
             II.A.4.  Neutral Sulfite Semichemical Pulping 	    67
             II.A.5.  Unbleached Kraft/NSSC (with cross recovery)  .  .    67
             II.A.6.  Mechanical Pulping 	    67
             II.A.7.  Waste Paperboard Production  	    69
             II.A.8.  Deinking 	    72
             II.A.9.  Papermaking  	    74


             II.B.I.  Toxicity 	    74
             II.B.2.  Other Potential Adverse Impacts  	    77

                      II.B.2.a.  Air Pollution 	    77
                      II.B.2.b.  Leachates 	  .....    79

      II.D.  OTHER IMPACTS	    80

             II.D.I.  Raw Materials and Byproducts Handling  	    80
             II.D.2.  Site Preparation	    81



              WASTE STREAMS	    83

              III.B.I.  Suspended Solids Reduction 	 •  •    86
              III.B.2.  BOD Reduction  	    86
              III.B.3.  Color Removal  	    87
              III.B.4.  Pretreatment   	    87


              III.C.I.  Kraft Mill Odors 	    88
              III.C.2.  Sulfur Dioxide 	    89
              III.C.3.  Miscellaneous Odor Problems	    90
              III.C.4.  Particulate Control	    91



             III.D.I.  Sludge Handling and Disposal  	  92
             III.D.2.  Disposal of Wood and Other Organic Wastes ...  93
             III.D.3.  Disposal of Inorganic Wastes  	  93

             CONSTRUCTION SITES  	  94
     III.F.   REGULATIONS 	  96


     IV. A.   AESTHETICS	  97
     IV.B.   NOISE	  97
     IV. C.   ENERGY SUPPLY	  97


     V.C.    NO-BUILD ALTERNATIVE  	 104



List of Figures

Number                                                                 Page

   1  Process flow and materials diagram for a 1,000-ton/day
      kraft linerboard mill	   10

   2  Process flow diagram for a typical sulfite pulp mill	   13

   3  Diagram for neutral sulfite semi-chemical pulping process  ...   15

   4  Diagram for groundwood pulping process 	   17

   5  Diagram for waste paperboard  mill pulping process 	   18

   6  Process flow diagram for deinking plant  	   19

   7  Process diagram for fourdrinier paper machine  	   21

   8  Distribution of kraft mills in the United States:  1973  ....   23

   9  Effluent characteristics for bleached kraft mill process
      waste	   59

  10  Effluent characteristics for sulfite mill pulping: Drum wash .  .   gg

  11  Effluent characteristics for groundwood (Coarse, molded,
      newsprint) mill	   71

  12  Effluent characteristics for deink mill process  	   73

List of Tables

Number                                                                 Page

   1  Geographic location of U.S. pulp and paper mills,
      by subcategory	   22

   2  Relative fiber consumption, by fiber source,  for the pulp
      and paper industry	   26

   3  Paper industry production:  1970-1990  	   34

   4  Major characteristics of process raw waste loads of  the
      pulp and paper mill industry	   38

   5  Promulgated and proposed Federal new source performance
      standards applicable to subcategories of the pulp,  paper,
      and paperboard point source categories 	   42

   6  New source performance standards for particulates  from kraft
      pulp mills	   48

   7  New source performance standards for total reduced  sulfur
      (TRS) for kraft pulp mills	   49

   8  Standards for power boilers:   Pulp and paper industry 	   50

   9  Federal ambient air standards for particulates 	   52

  10  Federal ambient air standards for sulfur dioxide 	   53

  11  Nondeterioration increments for S02 and particulate  matter
      in areas with different air quality classifications   	   54

  12  Woodyard effluents during wet barking operations 	   58

  13  Water quality values among unbleached kraft mills   	   gg

  14  Typical TRS emissions: Uncontrolled 907-kkg kraft mill 	   52

  15  Typical particulate emissions:  Uncontrolled 907-kkg
      kraft mill	   53

  16  Summary of raw waste characteristics of papergrade  sulfite
      mill effluents	   65

  17  The effects of furnish and waste liquor handing on  sodium
      base NSSC effluents	   68

  18  Range of BOD5 loads in effluents of groundwood processes  ....   70

  19  Water quality values for combined papermaking effluents
      by grade	   75

List of Tables (Continued)

Number                                                                 Page

  20  Internal control technologies used as applicable in pulp
      and/or paper mills and their effects on wastewater streams ...   84

  21  Typical acreage used for three subcategories of pulp
      and paper mills	,   95

  22  Energy requirements for pulp and papermaking operations  ....   99


The Clean Water Act requires that EPA establish standards of performance for
categories of new source industrial wastewater dischargers.  Before the
discharge of any pollutant to the navigable waters of the United States from
a new source in an industrial category for which performance standards have
been proposed, a new source National Pollutant Discharge Elimination System
(NPDES) permit must be obtained from either EPA or the State (whichever is
the administering authority for the State in which the discharge is proposed).
The Clean Water Act also requires that the issuance of a permit by EPA for a
new source discharge be subject to the National Environmental Policy Act
(NEPA) , which may require preparation of an Environmental Impact Statement
(EIS) on the new sources.  The procedure established by EPA regulations (40
CFR 6 Subpart F) for applying NEPA to the issuance of new source NPDES permits
may require preparation of an Environmental Information Document (EID) by the
permit applicant.  Each EID is submitted to EPA and reviewed to determine if
there are potentially significant effects on the quality of the human envi-
ronment resulting from construction and operation of the new source.  If
there are, EPA publishes an EIS on the action of issuing the permit.

The purpose of these guidelines is to provide industry specific guidance to
EPA personnel responsible for determining the scope and content of EID's and
for reviewing them after submission to EPA.  It is to serve as supplementary
information to EPA's previously published document, Environmental Impact
Assessment Guidelines for Selected New Source Industries, which include the
general format for an EID and those impact assessment considerations common
to all or most industries.  Both that document and these guidelines should
be used for development of an EID for a new source pulp and paper mill.
These guidelines provide the reader with an indication of the nature of the
potential impacts on the environment and the surrounding region from
construction and operation of pulp and paper mills.  In this capacity, the
volume is intended to assist EPA personnel in the identification of those
•impact areas that should be addressed in an EID.  In addition, the guidelines
present (in Chapter I) a description of the industry, its principal processes,
environmental problems, and recent trends in location, raw materials, processes,
pollution control and demand for industry output.  This "Overview of the
Industry" is included to familiarize EPA staff with existing conditions in
the pulp and paper industry.   '

Although this document may be transmitted to an applicant for information
purposes, it should not be construed as representing the procedural require-
ments for obtaining an NPDES permit or as representing the applicant's total
responsibilities relating to the new source EIS program.  In addition, the
content of an EID for a specific new source application is determined by EPA
in accordance with Section 6.604 of the Code of Federal Regulations and
this document does not supersede any directive received by the applicant from
EPA's official responsible for implementing that regulation.

These guidelines are divided into six sections.  Section I is the "Overview
of the industry," described above. Section II, "Impact Identification," dis-
cusses process-related wastes and the impacts that may occur during construction
and operation of the facility.  Section III, "Pollution Control," describes
the technology for contolling environmental impacts.  Section IV discusses

other impacts that can be mitigated through design considerations and proper
site and facility planning.   Section V, "Evaluation of Alternatives," dis-
cusses the consideration and impact assessment of possible alternatives to
the proposed action.   Section VI  describes regulations other than pollution
control that apply to the industry.


The importance of the pulp and paper industry in the NPDES permit program
is illustrated by its third-rank position among U.S. manufacturers in
quantity of wastewater discharged.  This industry is water-dependent, and
will remain so for the foreseeable future, in that wood or any other cellulose
fiber source is pulped in the presence of water and remains waterborne
throughout the process until the paper sheet has been formed.

Today, wood accounts for over 98% of the virgin fiber used, and such materials
as cotton linters, rags, and flax constitute the small remainder.  The term
"virgin" fiber is used to indicate pulp that has not been used previously.
Approximately 20% of the paper and paperboard produced in this country,
however, is also reused as recycled fiber.

The wood pulping process separates the fiber from other constituents of wood
and fiberizes it.  In some pulping methods, these steps are accomplished by
cooking the wood with chemicals and water under controlled conditions of heat
and pressure.  In others, a purely mechanical action is used, and some
technologies employ a combination of both.  The repulping of waste paper is
a hydraulic and mechanical process in which deinking may or may not be

Many pulps, which are naturally brown in color due to the lignin content of
wood, are bleached in one or more stages to provide fiber for light colored
or white papers.  Chlorine, chlorine dioxide, and hypochlorites are among
the bleaching agents used.  Bleaching is also an integral part of the process
for making dissolving pulps that consist of alpha cellulose and are used in
rayon, cellophane, and explosives.

There are three general categories of mills:

    •   Market pulp mills are mills that produce pulp only, which
        is shipped for use to another site, and do not engage in

    •   Nonintegrated paper mills are mills that receive pulp from
        other sources and engage solely in papermaking.  Tradi-
        tionally, these mills have been subdivided according to
        the general nature of their major product; that is, they
        are called fine, coarse, tissue, and newsprint mills.

    •   Integrated mills are mills that manufacture both pulp and
        paper; these mills are usually referred to by the predomi-
        nant pulping process used.  Some mills are complex in that
        they use more than one pulping technology and manufacture
        a broad range of paper grades.  A mill of this kind is
        designated by the process that accounts for its greatest
        pulping capacity; for example, a mill is known as a kraft
        mill if the kraft process accounts for the majority of
        its pulp production.

These categories were found to be inadequate, however, for use in estab-
lishing effluent limitations guidelines, new source performance standards

(NSPS), and pretreatment standards pursuant to the Federal Water Pollution
Control Act, now commonly referred to as the Clean Water Act (Public Laws
92-500 and 95-217).  Variations in production processes and raw materials
used within these categories result in significant differences in wastewater
characteristics, treatability, and available treatment technologies.  There-
fore, much narrower discrete subcategories were defined that do not conform
to Standard Industrial Classifications (SIC) 2611, Pulp Mills; 2621, Paper
Mills, except building paper; and 2631, Paperboard.


The subcategories of the pulp, paper, and paperboard industry are established
in 40 CFR, Part 430.  The order in which they are presented there departs
from the normal step-by-step progression from mechanical pulping to semi-
chemical to chemical.  To facilitate reference to the regulations, however,
the same order is maintained here.  The subcategories may be described as

     1.   Unbleached kraft mills use a "full cook" process to produce
         kraft pulp, using a highly alkaline cooking liquor contain-
         ing sodium hydroxide and sodium sulfide.  This basic kraft
         process is common to all kraft subcategories.  In this
         subcategory of mills, the pulp is not bleached and is used
         to manufacture the typical unbleached kraft products, which
         include linerboard (the smooth facing of corrugated boxes),
         wrapping paper, and paper for grocery bags and shipping

     2.   Neutral sulfite semichemical (NSSC) sodium base mills use
         a sodium base neutral sulfite semichemical process to make
         unbleached pulp and paper products, principally corrugated
         medium, the inner layer of the corrugated box "sandwich."

     3.   NSSC ammonia base mills are the same as those in Subcate-
         gory 2, except that ammonia is used as the cooking liquor
         base.  Ammonia cannot be recovered for reuse and it
         imparts different characteristics to the wastewater.

     4.   NSSC/unbleached kraft mills with cross recovery are com-
         bined mills in which spent sodium base NSSC liquor is
         recovered in the kraft mill recovery system.  This process
         is desirable because:

         •   Recovery of sodium in NSSC liquor alone is difficult

         •   Recovery of the NSSC liquor provides sodium sulfate,
             a make-up chemical for the kraft process

         •   Both components of the corrugated product are manu-
             factured on the same site

         •   Hardwood species present to some degree in softwood
             timber stands can be harvested and used by the NSSC

 5.  Waste paperboard mills are those in which waste paper is
    repulped  and  accounts for at least 80% of the fiber used
    primarily to  produce unbleached folding board products
    such as soap  cartons and bottle carriers.  No deinking is
    practiced in  connection with paperboard production, but
    the product is  frequently upgraded with an asphalt dis-
     persion process.

 6.   Bleached kraft:  dissolving  pulp mills produce  pulp  by  a
     "full  cook"  process,  utilizing a highly  alkaline  sodium
     hydroxide and sodium sulfide cooking  liquor.  Included
     in the manufacturing process is a  "pre-cook"  operation
     termed pre-hydrolysis.   The  pulp is subsequently  highly
     bleached and  purified to make dissolving pulp,  used
     principally  for the manufacture of rayon and  other
     products  requiring the  virtual absence of lignin  and
     a very high  alpha cellulose  content.

 7.   Bleached kraft;  market pulp mills produce pulp by a
     "full-cook"  process utilizing a highly alkaline sodium
     hydroxide and sodium sulfide cooking  liquor which is
     subsequently  bleached.   The  product is called paper-
     grade  market  pulp.

 8.   Bleached kraft;  paperboard,  coarse,  tissue  (BCT) papers
     subcategory  includes the integrated production  of bleached
     kraft  pulp and paper.   Integrated  production  is considered
     to be  pulp and paper manufacturing operations where  all or
     part of the manufactured pulp is processed into paper at
     common or adjacent sites.  The kraft  pulp is  produced in
     a "full cook" process utilizing a  highly alkaline sodium
     hydroxide and sodium sulfide cooking  liquor which is sub-
     sequently bleached.  The principal products include  paper-
     board  (B), coarse papers (C),  tissue  papers  (T),  and market

 9.   Bleached kraft;  fine papers subcategory includes the inte-
     grated production of bleached kraft pulp  and  paper.  Inte-
     grated production is considered to be pulp and  paper manufac-
     turing operations where all  or part of the manufactured pulp
     is processed  into paper at common  or  adjacent sites.  The
     kraft  pulp is produced  in a  "full  cook"  process utilizing a
     highly alkaline sodium  hydroxide and  sodium sulfide  cooking
     liquor which is subsequently bleached.   The principal pro-
     ducts  are fine papers which  include business, writing,  print-
     ing papers,  and market  pulp.

10.   Papergrade sulfite;  blow pit washing subcategory includes
     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 made by this  process  are  tissue  papers,
     newsprint,  fine papers, and market  pulp.

11.   Dissolving grade sulfite pulp 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 bleach-
     ed and purified to produce viscose, nitration,  cellophane,
     or acetate grades which are used principally for the manu-
     facture of rayon and other products that require the virtual
     absence of lignin.

12.   Groundwood;  Chemi-mechanical (CMP) subcategory includes
     the integrated production of chemi-mechanical groundwood
     pulp and paper.  The chemi-mechanical groundwood pulp  is
     produced utilizing a chemical cooking liquor to partially
     cook the wood followed by mechanical defibration by refining
     with or without brightening, resulting in yields of 90%  or
     greater.  The principal products include fine papers,  news-
     print, and molded fiber products.

13.   Groundwood;  thermo-mechanical (TMP) subcategory includes
     the production of thermo-mechanical groundwood  pulp and
     paper.  Thermo-mechanical groundwood is  produced by a
     brief cook utilizing steam, with or without  the addition
     of cooking chemicals such as sodium sulfite, followed by
     mechanical defibration by refiners  which are frequently
     under pressure, with or without  brightening, and result-
     ing in yields of approximately 95%  or greater.   The
     principal products of this process  are market pulp, fine
     papers, newsprint, and tissue papers.

14.   Groundwood:  coarse, molded, news (CMN)  papers  subcategory
     includes the integrated production  of groundwood pulp and
     paper.  The groundwood pulp is produced,  with or without
     brightening, utilizing mechanical defibration only, employ-
     ing either stone grinders or refiners.  The  principal pro-
     ducts made by this process include  coarse papers (C),
     molded fiber products (M), and newsprint (N).

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

16.   Soda subcategory includes the integrated production of
     bleached soda pulp and paper.  Soda pulp is  produced by
     a "full-cook" process utilizing a highly alkaline sodium
     hydroxide cooking liquor and is  subsequently bleached.
     The principal products are fine papers which include
     printing, writing, and business  papers.

      17.  Deink subcategory  includes  the integrated production of
          deinked pulp and paper.  The  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 or brightened to produce such products
          as printing, writing, and business papers,  tissue papers,
          and newsprint.

      18.  Non-integrated  (NI) fine papers subcategory includes non-
          integrated (NI) mills which produce fine papers from wood
          pulp or deinked pulp prepared at another site.   The principal
          products of this process are printing, writing, business,
          and technical papers.

      19.  Non-integrated  tissue papers subcategory includes non-integrated
          (NI) mills which produce tissue papers from wood pulp or de-
          inked pulp prepared at another site.  The principal products
          of this process include facial and toilet papers, glassine,
          paper diapers,  and paper towels.

      20.  Non-integrated  tissue from waste paper (FWP) subcategory in-
          cludes non-integrated (NI) mills which produce tissue papers
          from waste papers  (FWP) without deinking.  The principal pro-
          ducts made by this process include facial and toilet papers,
          glassine, paper diapers, and paper towels.

      21.  Papergrade sulfite:  drum washing 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.  Also included are mills using belt extraction systems
          for pulp washing.  The principal products made from pulp
          manufacturing by this process are tissue papers, fine papers,
          newsprint, and  market pulp.

The subcategories are itemized carefully because subcategorization of the
pulp and paper industry is an overriding consideration in an applicant's
initial determination of whether a proposed new mill or significant modifi-
cation to an existing mill can be,1 defined as a new source.  Subcategorization
is emphasized because,  as of this writing,  NSPS have been promulgated for
Subcategories 1-5, but have only been proposed for Subcategories 6-21.  In
addition, there are segments of the industry which have not yet been subcate-
gorized for purposes of effluent limitations guidelines or NSPS.

By definition (Section 306(a)(2)  of Public Law 92-500),  a new source is one
on which construction begins after applicable NSPS are proposed.   In turn,
Section 511(c)(l) of Public Law 92-500 authorizes application of the National
Environmental Policy Act to the National Pollutant Discharge Elimination
System permits for new sources so defined.

Although  the New Source Performance Standards for Subcategories 6-21 of
this  industry were proposed on 19 February 1976, they had not been promul-
gated as  of the writing of these guidelines.  In a decision issued on 28
August 1978, EPA's Office of General Counsel ruled that an NPDES application
in a  subcategory for which NSPS have been proposed but not promulgated is
considered a new source only if the NSPS are promulgated within 120 days
of proposal.  Therefore, the issuance of a permit for a discharge in Sub-
categories 6-21 will not be subject to NEPA until the NSPS for these sub-
categories are promulgated.  According to a Settlement Agreement between
EPA and the Natural Resources Defense Council, the NSPS for pulp and paper
mills are scheduled to be promulgated by 30 September 19SO.

New mills or expansions in the segments of the industry that have not been
subcategorized for the application of NSPS are not covered by the above
definition of a new source and cannot be so characterized.  Thus, their permits
do not require an environmental impact assessment or statement.   These include:

      •   Nonintegrated mills that make a wide variety of so-called
         specialty products such as industrial papers and electrical
         insulating board

      •   Mills that pulp materials other than wood or waste paper
          (cotton linters, flax, etc.), or use market pulp made from
         such materials, to make very fine papers such as cigarette
         tissue and currency,  Bible, and legal stock

Thus, the situation existing when this appendix was prepared requires that
parties concerned with NPDES permits for discharges by new sources in the
pulp  and paper industry ascertain:

      •   The precise type of facility proposed

      •   The current status of new source performance standards
         applicable to such a  mill


While applicants will find the subcategory definitions cited above useful in
determining the applicability  of the separate NSPS and pretreatment standards,
a more detailed discussion of  the major processes and subprocesses utilized
by the industry is presented here to support the characterization of its
process-oriented wastes and their impacts in Section II-A.

I.B.I  Wood Preparation

Wood  is received at the mills  in several forms requiring a variety of handling
techniques.  Saw mill scraps or barked logs can be chipped directly, a process
which utilizes minimal quantities of water.  Some mills still receive unbarked
roundwood in short lengths, however, and the bark must be removed before

Logs are stored in piles that are water sprayed occasionally to prevent
deterioration and maintain uniform water content, or are stored in water.
The former practice is more prevalent because of its lower cost, and because
wood solubles, silt, and bark debris collect in the storage water, increasing
with reuse.  Logs also are frequently shower washed before barking to remove

Most of the pulpwood used in this country is small in diameter and is barked
dry in drums.  However, when large diameter logs are used, wet barking is
practiced, using either drums, pocket barkers, or hydraulic barkers.

I.E.2.  Pulping

As suggested by the subcategories, the pulping processes fall into three major

     •   Mechanical

     •   Semichemical

     •   Chemical

There is some overlap among the processes in that some mechanical pulping
processes involve a mild chemical treatment ahead of pulping by attrition,
and the chemical application in semichemical pulping is essentially a cooking
process, although milder than that of full chemical pulping.

The users of this appendix are referred to two primary sources (EPA, 1974;
1976b) that describe all pulping applications and provide many references to
more specialized publications.

I.E.2.a.  Kraft Pulping.  Because about 80% of the chemical pulp produced in
the United States is manufactured by the kraft process, this process is
described in detail to illustrate the major elements of chemical pulping.
The interrelationship of the various steps involved is shown in Figure 1.

In kraft pulping:

     •   Wood chips are cooked either in batch or in continuous diges-
         ters with a mixture of caustic soda and sodium sulfide.

     •   When cooking is completed, the chips are "blown" into a tank;
         this action separates them into fibers.

     •   Subsequently, the spent cooking liquor is separated from the
         pulp by countercurrent washing.  The separated spent cooking
         liquor, known as weak black liquor, has a consistency ranging
         from 12 to 20% solids and is collected in tanks for recovery.

        Wood 2190 Tons
        546,000 Gal. Water1'
                                                                                 WASH WATER
                                                                                                      ROUND WOOD
                                                                                                      1168 Cords
                                                                                  j_  150.000_Gal.___     r
                         Cooling Hater  20n,200 Gal.
                                                          Wash Water
                                                          250.000 Gal.
  615 Tons
   58 Tons
    Water  1.000.000 Gal.
           NaOH   5.4 Tons
           Sulfur  4.6 Tons

14 Tons
r 1.4 Tons
16,000 Gal.


Na OH 33 Tons
Sulfur 13 Tons


\ B.L.



. t

.Org. 11 00 Tons
H 600 Tons
fur 50 Tons
er 220.000 Gal

~t Sul fur
J Water 2

•R A
fe, HOT 5
4.3 Tons
.000.000 Gal.

Cooling Water
11 MGO



llaOH 600 Tons
Sulfur 50 Tons
01s. Org. 1150 Tons
Water 2.400.000 Gal.

Mud   500 Tons
NaOH  5.0 Tons
Sulfur 1.1 Tons
Water 76.000 Gal.
                        ' > llaOH 135 Tons]
                1 .200.000 Sal.
                    HUD VfASHCR
                          WHITE LIQUOR
              5>IO Tons
         Sulfur  f,n Tons
         Intrts  10 Tons
           Water 10,000 Gal
                     LIME KILN

CaO 140 Tons ' '
f Im.-rts 12 Tons


I ,
                                                                    Inerts S Tons
                                                                    Water 24.100 Gal.
                                                                                                 01s.Org.    11 Tons
                                                                                                 Fiber & Add.  9 Tons
                                                                                                 NaOH      4.5 Tons
                                                                                                 Sulfur     .46 Tons
                                                                                                 Water 1.000.000 Gal.
US  Environmental Protection  Agency.   1976a.   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 the pulp, paper,  and  paperboard mills point  source category.
EPA 440/1-76/047-b,  Dec.
           Figure 1.   .Process  flow  and materials  diagram for a  1,000-ton/day kraft  linerboard mill

    •   An appropriate mixture of pulps is prepared in a beater to
        which needed filler, dyes, and sizing are added to impart
        the qualities required for various paper grades.

    •   After beating, the pulp is usually refined in a Jordan,
        which cuts the fibers to the final size desired and adjusts
        them to the proper uniform consistency.

    •   Finally, the pulp is evenly distributed from a headbox over
        a traveling belt of fine wire screening, known as a four-
        drinier paper machine, where the sheet is formed.  It is
        then carried to rolls and a series of dryers.  Most of the
        water in the pulp passes through the screen and is referred
        to as white water.  This water is typically reclaimed to
        recover the fiber and reuse the water.

In the chemical recovery system:

    •   Weak black liquor is concentrated to about 40 to 45% solids
        in long-tube multiple-effect evaporators and is then known
        as strong black liquor.  In the case of fatty woods, tall
        oil soap is skimmed from the tanks holding this strong
        black liquor before oxidation (if oxidation is practiced).
        The liquor is then concentrated further, and the skimmings
        sold as soap or first acidified to produce tall oil itself.
        Spent acid from the latter procedure consists mainly of a
        solution of sodium sulfate and is returned to the recovery
        system as chemical make-up.

    •   Strong black liquor is concentrated further to a consistency
        of 65 to 70% in a recovery furnace stack evaporator or in a
        concentrator, after which make-up chemicals in the form of
        new or recovered sodium sulfate or a residue high in content
        of this salt is added.  The heavy liquor is then burned, and
        the heat is recovered in a specially designed boiler.

    •   During burning, the organic sodium compounds are converted
        to soda ash and sulfates to sulfides.  The molten smelt of
        salts is dissolved in water to form green liquor, which is
        clarified by sedimentation and causticized with lime to
        convert the soda ash to caustic soda.

    •   After causticizing, the combined sodium sulfide-caustic
        soda solution is known as white liquor.  This liquor is
        settled and sometimes filtered through pressure filters,
        adjusted to the desired strength or concentration for
        cooking with weak black liquor, and stored for subsequent

    •   The calcium carbonate created by the causticizing reaction
        is settled out, dewatered,  and burned in a lime kiln to
        form quick lime.   This is returned for hydration with the
        green liquor to complete the chemical recovery (NCASI,


     •   Washed pulp is refined to remove knots and other nondisinte-
         grated material, bleached in some mills, and subsequently
         dried and delivered to the paper mill.

     •   Relief condensate from the digesters is condensed, and the
         turpentine recovered from it by decantation is sold.

I.B.2.b.  Sulfite Pulping. The sulfite process is illustrated in Figure 2,
Although this process is used to make two distinctly different types of pulp
—papermaking and dissolving—the basic process is the same for both, although
higher cooking temperatures and a stronger cooking liquor are utilized in the
dissolving process.  Cooking is continued until most of the lignin and part
of the cellulose are dissolved; in papermaking pulps only the lignin is
dissolved.  The spent liquor from dissolving thus has a higher solids content.

There is another distinction in sulfite mills between blow pit washing and
vacuum drum washing.  With the latter it is possible to recover 95% of the
liquor solids, but the limit is about 85% with displacement washing in blow

I.B.2.C.  Neutral Sulfite Semichemical Pulping.  This process, as its name
implies, incorporates some of the characteristics of both mechanical and
chemical pulping.  It is described as "neutral sulfite" since, by comparison
with the acidic basic sulfite process, the liquor utilized is neutral or
slightly alkaline—pH 7-9.

The  cooking liquor is commonly prepared by burning sulfur to sulfur dioxide
and absorbing the latter in soda ash or ammonia.  The major reasons for
selecting sodium as the base are:

     •   The use of this base is a well proven technology.

     •   It provides high quality products and high yields.

     •   It can utilize a wide variety of hardwoods.

     •   It can also utilize softwoods, including sawdust and
         other wastes.

     •   It does not involve handling gases other than S02, to
         which the industry is accustomed.

     •   Air and water pollution problems are minimized since the
         sodium base can be recovered.

     •   The use of sodium permits integration with a kraft mill
         and, thus, a cross recovery system (Worster, 1973).

The major reasons for selecting ammonia as the base are:

     •   Although pulp of similar quality and yield to that of
         sodium base NSSC can be achieved with an ammonia base,

        WOOD CHIPS
                          BLOW TANK
                                   _  i         7
                                             1   1
        PULP DRYER
US  Environmental Protection Agency.   1976a.  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  the pulp, paper, and paperboard
mills point source category.  EPA  440/1-76/047-b, Dec.
                     Figure 2.   Process flow diagram for
                          a typical sulfite  pulp mill

         ammonia is relatively cheap and is readily available in
         many areas.

     •   The spent liquor is more readily combustible than sodium
         base liquor.

     ••   It can be incinerated to a nearly ash-free product
         (Worster, 1972).

In this process, chips, as shown in Figure 3, are impregnated with cooking
liquor, subjected to a short cook, and mechanically fiberized.

The pulp then undergoes vacuum or pressure washing, screening, and/or centrifu-
gal cleaning.  In some mills, the relief and blow gas condensate is used.in
pulp washing.

A small percentage of repulped waste paper is added to the NSSC furnish for
corrugated products to impart desired characteristics.

I.B.2.d.  Mechanical Pulping.  Mechanical pulping is  segmented into five
distinct processes:

    •   Stone groundwood, the basic process, in which pulp is made
        by grinding short lengths of logs called billets on a

    •   Refiner groundwood, in which wood chips are passed through
        a disc refiner

    •   Chemi-groundwood (chemi-mechanical) in which  the billets
        are first pressure impregnated with a dilute  solution of
        sodium sulfite before grinding

    »   Cold soda pulping, in which chips are steeped in a caustic
        solution and refined

    •   Thermo-mechanical pulping, a new process, in which chips
        are first softened with heat and sometimes chemicals, then
        refined under pressure

These general descriptions are subject to modification in practice.

The official EPA subcategorization of the groundwood  segment of mills, however,
is an artificial division for regulatory purposes based on raw waste similari-
ties and dissimilarities among the five processes.  Although they were
established on the basis of data collected in mills distinguishable according
to the above segments, the subcategories established  are those described in
Nos. 12, 13, and 14 in Section I.A.  Stone and refiner groundwood were
combined to form the "groundwood  (coarse, molded, newsprint)" subcategory;
chemi-groundwood and cold soda were combined under "chemi-mechanical"; and
"thermo-mechanical" remains a separate subcategory.

          SO*- COt
          FLOOR  DRAINS
        PRODUCT a  RAW  MATL.
        CHEM. a LIQUORS	

                                          WATER TANK


                                           PAPER MACH.
                                            SAVE - ALL
        BACK WATER 	
        STEAM 8 GASES	,	
        EFFLUENT	•	
                                       EVAP.   COND.
                                      COOLING  Hj,0
Source:  US Environmental Protection Agency.  1976a.  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 the pulp, paper, and paperboard
        mills point source category.  EPA 440/1-76/047-b, Dec.
    Figure 3.  Diagram for neutral sulfite semi-chemical pulping process

As a result, no data and no process descriptions can be presented that
specifically fit these subcategorizations.  It is necessary, therefore, to
revert to traditional divisions of the mechanical pulping subcategory for
this discussion.

The basic mechanical pulping process, stone groundwood, is shown in Figure 4.
In this process:

    •   Billets are fed to the grinders by hand or automatically from
        a belt or chair conveyor and are.forced hydraulically against
        the large rotating grindstone specifically designed for the
        purpose (Gehm, 1973).  The grinding occurs in the presence of
        a large quantity of water that acts as both a coolant and a
        carrier to sluice the pulp from the body of the grinder.

    •   The pulp slurry is diluted to a consistency of from 0.6 to
        0.8% and is passed through coarse and fine screens and a centri-
        cleaner to remove dirt and shives.   Oversize rejects may be
        passed through a disc refiner and returned to the system ahead
        of the fine screens.

    »   The pulp slurry is then thickened on a decker to a consistency
        between 10 and 15% and discharged to a stock chest for mill
        use, bleached, or thickened further for transport to other
        mills (EPA, 1976a) either in the form of wet lap at about 25%
        consistency or nodules containing 50% fiber.

Groundwood pulp contains essentially all of the material contained in the
basic wood.  Because it is not subjected to extensive bleaching, the major
variables are reduced to the pulping process and the type of paper produced.

In the chemi-mechanical and thermo-mechanical subcategories, the most
significant variable is pulping, because in these processes, some pretreat-
ment in the form of chemicals and/or heat is used and, in thermo-mechanical,
pressure is added to the fiberization process as described under the
subcategories in Section I.A.  In the groundwood CMN subcategory, the paper
produced is the more significant variable, because no major distinction is
identified in the waste characteristics of stone and refiner groundwood.

I.B.2.e.  Waste Paperboard Production.  Waste paper is converted to secondary
fiber in a pulper employing water, chemicals, and steam (EPA, 1974) as shown
in Figure 5.  An attached junker removes extraneous solid materials.

I.B.2.f.  Deinking.  Deinking is closely related to chemical pulping in that
an alkaline solution is used (shown in Figure 6), consisting of soda ash,
caustic soda, sodium silicate, and sometimes sodium peroxide.  Some deinkers
employ dispersing agents.  The chemicals saponify the ink and solubilize
coating adhesives, allowing the ink, coatings, and fillers to be subsequently
washed from the pulp.  For newsprint, containing only fiber and ink, a
detergent is used to separate the ink which is washed away.

              WHITE  WATER
         FLOOR  DRAINS


                                     PRODUCT a RAW MAT'L •
                                          CHEM.a LIQUORS-
                                           PROCESS WATER	
                                              BACK WATER	
                                                 REJECTS *****
Source;  US Environmental Protection Agency.   1976a.   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  the pulp,  paper, and  paperboard
         mills point source category.   EPA  440/1-76/047-b, Dec.
             Figure 4.  Diagram for groundwood  pulping process

                                        •| CHEM.  [-
— *








" vlUII

!--+--»--»--»-• R

*-**+-| REJ

1 ^
1 	 *—-*—. *




i <-•»•*•»»•**
Source:  US Environmental Protection Agency..  1976a.   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 the pulp,  paper, and paperboard
         mills point source category.  EPA 440/1-76/047-b, Dec.
       Figure 5.  Diagram for waste paper board mill pulping process


                                                       MAIN PROCESS
                                                  	 SECONDARY PROCESS
                                                  	PROCESS WASTE LINE
Source:  US Environmental Protection Agency,   1976a..   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  the pulp,  paper, and paperboard
         mills point source category.  EPA  440/1-76/047-b,  Dec.
            Figure 6.  Process  flow diagram for deinking plant

I.E.3.  Papermaking

Papermaking is described above in conjunction with the kraft process.  One
major type of paper machine, the fourdrinier, is illustrated in Figure 7. The
other is the cylinder which revolves in the dilute pulp; it is used primarily
in making multi-stock sheets of paperboard.


I.C.I.  Location Changes

Table 1 shows the current geographic pattern of the U.S. pulp and paper
industry as it, has evolved after dramatic changes in structure.  The most
predominant changes from earlier patterns are the loss of a number of sulfite
pulp mills in New England, New York, Pennsylvania, and Wisconsin, and the
ascendancy of kraft pulping in the South.

Most of the sulfite mills in these areas which closed were small old mills
using calcium base cooking liquor.  It was not economic to recover  this base
and, without liquor recovery or byproduct production from the liquor, pollu-
tion control measures were not available to meet water quality standards or
effluent limitations.  In addition, they were confronted with the competition
from kraft mills several times their size, which could produce almost any
product the sulfite mills could produce and make it cheaper.

Kraft mills proliferated in the South because, in the 1930's, this process
was the only one capable of using the vast stands of southern yellow pines.
Similarly, the location of semichemical mills was wood-oriented to make use
of otherwise unusable hardwoods.

Pulping techniques have become much more versatile, however, and the location
of specific wood species is not the major influence it once was.  The industry
also has adjusted to and compensated for other locational factors up to the
present state-of-the-art of production and pollution control.  Hence, no new
locational shifts of the magnitude of those described here are anticipated.

The major growth at present remains in the South where one new integrated mill,
one market pulp, and two paper mills were in various stages of completion in
mid-1977 (Expansion Modernization, 1977).  Only one other new mill was under
construction in this country, in the far West.

Another type of growth which is also strongest in the South is the expansion
of existing mills.  In that area, this occurrence is largely a function of
the increasing demand for bleached kraft products for modern packaging,
especially foodboard for frozen foods.

Because the South is the center of kraft pulping, as shown in Figure 8, this
trend can also be expected to continue as long as there is growth in the
bleached kraft market and the unbleached kraft products as well.

Other historical factors have influenced growth in the South, although their
significance is diminishing.  One factor in this category was the availability
of a sustained wood supply enhanced by climate and shorter growing periods
than those required in other areas for other species.  This point is illustrated


                  COUCH  PIT
                   WIRE PIT



                                 PRODUCT and RAW MAT'L
                                 PROCESS WATER
                                 REFUSE WATER
Source:  US Environmental Protection Agency.   1976a.   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  the pulp,  paper, and paperboard
         mills point source category.  EPA  440/1-76/047-b,  Dec.
           Figure?.   Process diagram for  fourdrinier paper machine

            Table  1.   Geographic location  of U.S.  pulp
                 and  paper  mills, by subcategory
Unbleached kraft
NSSC (sodium base
and ammonia base)
kraft (with cross
Waste paperboard
Bleached kraft
(dissolving pulp)
Bleached kraft
(market pulp)
Bleached kraft
Bleached kraft
(fine paper)










































Groundwood:   chemi-
  mechanical,  thermo-
  mechanical,  CMN
  papers,  and  fine
  fine papers

Nonintegrated tissue
  papers and non-
  integrated tissue
  from waste paper

Dissolving sulfite
  (high alpha and
  low alpha)

Papergrade sulfite
  and papergrade
  market sulfite
*Includes de-inked newsprint.
Note.—See Section I.A.  for  definitions.

Sources:  US Environmental Protection Agency.  1976a.  Development document
          for effluent limitations  guidelines and new source performance
          standards for the  bleached kraft, groundwood, sulfite, soda, de-
          inked and non-integrated  paper mills of the pulp, paper, and paper-
          board mills  point  source  category.  EPA 440/1-76/047-b, Dec.

          US Environmental Protection Agency.  1974.  Development document
          for effluent limitations  guidelines and new source performance
          standards for the  unbleached kraft and semichemical pulp segment.
          EPA 440/1-74-025-a,  May.

                                                                                     UNBLEACHED KRAFT
                                                                                     BLEACHED KRAFT
                                                       ; NORTH DAKOTA   ;       -.
                                                      'NEBR       ^	-
                                                         |	\MISSOURI  '
                                                                                        u.^:....2 B   V
                                                                                   J-	pkLABAM'5
                                                                                  /      I
                                                                           h	,--    UU    \5U
                                                                           • LOUISIANA'.  2 B  '    7 B '
                                                                            y •» B /
                                                                                                                 UNITED STATES
                                                                                                                  0   100 ___ .yu   K
                                                                                                                     M II1 Ml 119
                             Figure 8.  Distribution  of kraft mills in  the United States:   1973

in that the 13 southern States produced approximately 30% of the Nation's
total wood supply in 1975.

According to the South's Third Forest Report, the forests of the South will
have to produce approximately 55% of the total by the year 2000, or two to
three times the current harvest.  Annual growth to meet this demand must
total 13 billion cubic feet, nearly 70% more softwood and 40% more hardwood
growth than in 1965.

There is concern in the industry, however, over the long-term adequacy of
quality timber at reasonable prices in the southern pine region (Zobel, 1977).
There are already varying degrees of pressure on high quality pines and hard-
woods, and there is a general excess of low quality hardwoods.  The continued
dominance of the South in paper industry growth will depend to a large degree
on the success of the industry's long-range planning and improved forest
practices in maintaining wood supply equal to demand in the geographical

Other reasons for the larger southern expansion include:

    •   An abundant water supply

    •   Tax concessions to attract industry in some States

    •   Good transportation, including water carriers
    •   Abundant and varied fuel supplies

    •   Somewhat lower wages and costs

The area differential in the last item is rapidly narrowing.  It must be
remembered, however, that expansion decisions are always based on a multitude
of specific considerations within broader areawide characteristics such as
those described herein.

I.C.2,  Raw Materials

The primary raw materials used in pulping and papermaking can be classified

    •   Wood

    •   Waste paper

    •   Chemicals for cooking and bleaching liquors

    •   Papermaking additives

In addition, small quantities of cotton and linen rags, cotton linters, jute,
hemp, flax, and old cordage are pulped for specialized products.  The total
tonnage of these materials used is miniscule compared to the quantities of
wood and waste paper pulped.

There is also one full-scale bagasse mill, and straw, cotton seed hulls,
esparto grass, bamboo, and corn stalks are used intermittently, either experi-
mentally or because of periodic shortages of the usual raw material.  The
quantities involved are even smaller than the amounts of textile fibers used,
and no increase is foreseen at present although there may be a long term
potential for the use of quick growing reedy plants.  Together all these
fiber sources account for 1.2% of the fiber consumed by this industry.

The relative importance of the various fiber sources is illustrated in Table 2.

Pulpwood, in the form of roundwood, chips, and forest and sawmill residue,
supplies 77.1% of the industry's fiber consumption.  Although historically
the use of delivered logs predominated, mills today are using a steadily
increasing percentage of chips prepared off-site.  The 1972 Census of
Manufacturers shows that chip use alone increased from 37 to 47% of total
softwood consumption between 1967 and 1972.  Chips and sawmill wastes together
accounted for 21% of hardwood consumption in 1972, but comparable data are not
available for 1967.  Recent statistics show that during the second quarter of
1977, roundwood consumption decreased 0.2% from the commensurate period in
1976 and chip use increased 26% (Statistical Summary, 1977).  The trend
toward increased use of chips is likely to continue because of the economics
of transporting chips as opposed to logs and because reductions in volume
of liquid effluent to be treated can be achieved in the absence of water
storage of logs and wet-barking processes.

The use of whole tree chipping (WTC) in the Northeast, the Great Lakes States,
and the South has increased considerably over the last decade.  This practice
has several advantages:

     H   It is particularly useful in mixed stands of timber and for
         thin diameter material.

     •   It does not require limbing and topping, which are the most
         expensive parts of wood handling.

     •   It results in higher fiber yield per acre, increased manpower
         productivity, reduced labor and transportation costs, and
         conservation of fuel (Whole Tree Chips, 1976).
These advantages currently are counterbalanced by:

     •   An increase in required mill maintenance

     •   Capital cost of equipment needed for WTC processing

     •   Adverse impact on product quality

     •   Increased wastewater loadings

As the problems are solved, the use of WTC will probably increase signifi-
cantly.  One company estimated that in 5 years 80% of its chips will be
field-chipped wood.

                   Table 2.  Relative fiber consumption,
                     by fiber source, for the pulp and
                               paper industry
                             1,000 short tons (rounded)
Wood pulp
Waste paper
Source:  Evans, J. C. W.   1977.   Wastepaper:   Outlook is for steady
         growth in U.S. utilization, strong advances in exports.
         Pulp & Paper 5/(7).

With softwood timber steadily becoming scarcer, the use of hardwood has in-
creased significantly in the last two decades.  Hardwoods have represented
the following approximate percentages of the total cords of pulpwood consumed:

     •   11.8% in 1950

     •   21.8% in 1960

     •   24.1% in 1970

     •   27% in 1974

The trend is expected to continue.

Recycling of paper was at its peak during World War II, when 40% of the paper
produced was recycled.  There was a steady decline in the succeeding two
decades, and then the trend reversed.  Reclamation is expected to remain at
about 25% for the next few years.  As shown earlier, waste paper consumption
is expected to be 16 million tons in 1977 and 17 million tons in 1978.   The
National Academy of Science has recommended that U.S. capacity to recycle
should reach 40 million tons per year by 1985.

Because of technological improvements in wood pulping, wood-content papers
have eclipsed rag-content papers, and rags now are used only in small
quantities to make very fine papers.  No significant increase can be forecast,
a conclusion supported by the short-range projections in Table 2.

The chemicals used in pulping include hydrate lime, sodium sulfide, sodium
hydroxide (caustic soda), sodium sulfate, and sodium carbonate (soda ash).
Unless new pulping methods are developed that do not use these substances,
fluctuations in their consumption will parallel fluctuations in pulp demand.
Bleaching chemicals include hydrogen peroxide, calcium and sodium hypochlorite,
chlorine dioxide, and chlorine.  The use of these chemicals will increase if
the demand for bleached products continues to rise.  Papermaking additives
include fillers and coatings such as clay, talc, gypsum, sizing (such as
rosin, casein, alum, and starch), pigments, and waxes.  The use of many of
these substances will also increase if the present upward trend in demand
for magazines and increasing use of coated stock in commercial printing
continues (Statistical Summary, 1977).

I.C.3.  Processes

The current process trends in this industry include a continuing decline in
sulfite pulping, further erosion in soda pulping, and the continued dominance
of kraft.  The versatility and favorable economics of kraft products are the
major reasons.  It can be expected, however, that the sulfite process will
continue to be a major factor in the production of fine papers.  The semi-
chemical process will also continue to be important as long as it is the major
producer of corrugated packaging products.

Other process changes in the pulp and paper industry will evolve from the
search for:

     •   Improved products

     •   New products

     •   More economic ways to make them

     •   Means to reduce both the cost and problems  of pollution control

In some cases, a change may respond to more than one of these considerations.
For example, in searching for ways to reduce both sulfur costs and sulfur
emissions, an NSSC corrugating medium producer developed a nonsulfur semi-
chemical process (Shick, 1977).  There are other such cases:

     •   Oxygen bleaching may become an acceptable substitute for more
         costly multiple bleaching systems used to achieve high bleach
         kraft pulp;  it is also effective in pollution control in that
         the bleach plant effluents can be recycled  to the pulp mill
         for evaporation and incineration with the black liquor.  Al-
         though the use of this system in existing mills currently is
         limited by the capacity of installed equipment, increased
         requirements for color reduction from kraft bleach plant
         effluents could stimulate a trend toward its use.

    •    A full scale bleaching process has  been installed in a new
         Canadian kraft mill which theoretically permits the bleaching
         system to be completely closed (Reeve, 1973).  It introduces
         a means to burn bleach plant effluent in the recovery system,
         thereby reducing the cost of effluent treatment and diminishing
         the color associated with bleach plant wastewaters.   Chlorine
         dioxide, an  effective bleaching agent, is also produced with
         chlorides recovered from the system.

    •    Oxygen pulping is a process under intensive study, the
         perfection of which is forecast for this decade (Advances,
         1972).  Cost savings will also provide the  major incentive
         toward this process.  Again, pollution control advantages—
         both air and water—would accrue.

    •    Polysulfide  pulping is another new process  under investigation.
         Its principal benefit is increased pulp yield, although it
         may reduce air emissions as well.

    •    Nitric acid  pulping and chlorine dioxide pulping are being
         studied.  They show some advantages such as high pulp yields,
         but there are many serious drawbacks to be  overcome before
         they can be  applied commercially (Cox and Wanster, 1977).

    •    Thermo-mechanical pulping has become a proven technology,
         although it  is relatively new in this country.  Capacity for
         this process is expected to increase by 482% from 1975 to
         1979—from 119,800 to 691,100 kkg (131,000  to 762,000 tons)
         (Towe, 1977).

 The ultimate goal of dry pulping processes  is  nowhere  near  achievement  and
 does not warrant  discussion here.   Dry paper forming processes  are  used
 abroad to a limited extent, however,  and at least  one  U.S.  company  has  acquired
 the rights to use a Danish-developed  system.   Capital  investment, it  is
 reported,  could be lower for dry forming—using air rather  than water to
 suspend or carry  fibers  during the papermaking process—for some products
 than it is for conventional systems (Tanazzi,  1971).   Use in specialty
 products mills—one U.S. mill reportedly already uses  the  technique for this
 purpose—is viewed as probably the only foreseeable application (Tanazzi,
.1971)  in this century.

 Some plastics are manufactured by paper companies  for  incorporation in  speci-
 fic packaging.  These do not replace  a substantial amount of paper, however,
 and are not likely to do so in the future.

 Trends in processes to produce new and improved products are difficult  to
 predict because competitive interest  precludes advance disclosure.

 I.C.4.   Pollution Control

 The status of innovations in pollution control should  be determined very
 early in the planning process.  Any major trends in internal measures will  be
 tied very closely to the potential developments in process  changes  described
 earlier.  Some improvements may accrue in recovery systems  such as  hydropyroly-
 sis  (Advances, 1972).   This method could replace  recovery  boilers  and
 incorporate production of activated carbon  from black  liquor.

 New deinking mills will also have an opportunity to  incorporate improve-
 ments that will substantially reduce traditional flows from this source.
 These improvements include continuous cooking  procedures as well as the
 application of air flotation separation of  ink and filler materials from the
 cooked pulp.  These techniques require entirely different machinery from that
 employed in established deinking mills.

 Wet barking operations are expected to decrease in order to eliminate this
 source of wastewater.  Dry barking and forest  chipping will be  substituted.
 A trend to greater use of vacuum drum washing  in sulfite mills  may  be expected
 to replace displacement washing in blow pits to enhance the recovery of solids.

 Increased recovery of turpentine and  tall oil  from kraft liquors may result
 from newer mill practices such as shorter storage  of chips, precooking
 extraction, or, in the case of tall oil, solvent extraction (Tapping, 1973).

 There are counterbalancing inhibiting factors, however, such as the increased
 use of continuous digesters, mixing pine and hardwood  black liquors,  and use
 of more hardwood, sawmill wastes,  and immature wood  (Barton, 1973;  Ellerbe,
 1973).   NPDES applicants should be current  on  the  status of research efforts
 on kraft byproduct recovery generally since the imposition  of effluent
 limitations may effect a stimulus in  this area.

 The future of this means for reducing the raw  waste load of sulfite mills
 does not appear to be as bright.  Currently, about 10% of the sulfite liquor
 produced in this  country is used and  there  is  little expectation that this
 percentage will increase (Craig, 1973).


New emphasis on heavy metals and exotic organics as water pollutants could
conceivably bring about the most significant change in the current external
control practices of the pulp and paper industry.  It is not possible, how-
ever, to evaluate potential trends at this juncture because the most defini-
tive  appraisal yet undertaken of the industry's effluents in terms of these
two classes of pollutants is not completed.  If ongoing analyses indicate
the existence of either or both classes in harmful concentrations, existing
NSPS  and pretreatment standards will be amended to require technologies for
controlling their discharge.  It is possible that NPDES applicants may in the
future be required to apply such technologies.  A precedent exists in that
groundwood mills using zinc hydrosulfite as a bleaching agent are already
required to use treatment to remove zinc from their effluent if they do not
elect to abandon the use of this compound.

The most recent modification in conventional wastewater treatment to be adopted
by this industry is the use of pure oxygen in biological processes.  Appli-
cants may wish to investigate performance at the several installations of
this  type in terms of improvements in sludge quantities and power requirements.

While early pilot studies on the application of the rotating biological
surface (RBS) process, a dynamic trickling filter device, to pulp and paper
effluents appeared promising (Gillespi, 1974; McAliley, 1974) they are
mechanically troublesome to operate and offer no great advantage over the
conventional trickling filter, which itself has seen little use in this
industry.  Each stage of the RBS becomes less effective, the sludge is
particularly difficult to dewater, and their use is not currently increasing.
Applicants may wish, however, to check with appropriate sources for the latest
developments in this technology.

Land  availability and cost will play a role in the type of biological treat-
ment  chosen by individual mills.  The methods that require the most land—
natural oxidation basins—are less expensive than the non-land-intensive methods
—aerated stabilization basins (ASB's) and activated sludge units; however,
they will probably be limited in use to some areas of the South by declining
land  availability and increasing land costs.

Whether color reduction technologies will be required for new or expanded
mills in subcategories where color is a problem (as discussed in Section
I.D.3), will depend on EPA's future course of action.  Currently, the color
NSPS  apply only to unbleached kraft mills and NSSC mills utilizing cross
recovery.  The NSPS proposed in February 1976 do not contain color limitations
because, as stated in an earlier version of the development document (EPA,
1975), the applicable technologies have not been demonstrated to the degree
of engineering and performance required by NSPS.  When color limitations are
imposed, mills will be faced with the following alternatives:              '

    •   Process change such as oxygen bleaching

    •   End-of-process treatment such as lime treatment, as
         recommended by EPA, or activated carbon, reverse osmosis,
         or ion exchange

   •     Some combination of the above

Sludge dewatering and disposal is an element of waste treatment that is now
in transition.  The use of filter presses, belt filters, screw presses, and
centrifuges is on the increase, and vacuum filters are no longer the obvious
choice for dewatering (Barnhill, 1974).  Automation and improved closures
have helped promote filter presses, as has their ability to produce dryer
cakes.  Belt filters of foreign design are being applied more often to highly
hydrous sludges, and screw presses are particularly successful with fibrous
sludges.  Centrifuges of both the disc and solid bowl type are being used
successfully where sand or grit is not present, although rapid wear contributes
substantially to the operating cost.

The various forms of heat treatment of sludges, with and without oxygen, are
now relatively common in processing municipal  sludges, and are under investi-
gation for use in the pulp and paper industry, but to date have not shown
much promise.  The multiple hearth furnace, units employing air suspension
drying and burning, and the fluid bed are used.  Some sludge is also inciner-
ated  with bark in bark boilers.  However, until the cost of incineration is
reduced the application of sludge incineration will be limited unless the
sludges can be dewatered to a point where they can more than support their
own combustion.

Landfilling of pulp and paper mill sludges should continue to be a viable
means of disposal if the sites used meet the constraints of the Resource
Conservation and Recovery Act, discussed in Section I.E.3, including leachate
control.  However, EPA's pulp and paper research and development waste treat-
ment program envisions study of the industry's sludges, with emphasis on
heavy metals.  The continuation of landfilling of sludge and the extent of
engineering precautions required could depend on the outcome of such a study.

New kraft mills can be expected to incorporate the most recent advances in
recovery furnace and liquor system design for odor control.  This feature
will be necessary to reduce total reduced sulfur (TRS) emissions to an
acceptable level.  The new air NSPS (discussed in Section I.E.2) applicable
to the TRS emissions from the lime kiln will also require improvements in the
mud washing system or air or molecular oxygen oxidation of the sulfides in
the mud.  In new mills, oxidation can be accomplished by installing vacuum
filters that have sufficient capacity to allow air or oxygen to be drawn
through the mud cake.           I

The collection and oxidation of miscellaneous sources of TRS in the digester
and evaporator systems will be designed into new mills.  These sources
include all the points of emissions regulated by the NSPS discussed in
Section I.E.2.

Improvements in sulfur dioxide scrubbing in acid sulfite and NSSC mills can
be anticipated as a result of a recent survey  (Rosenburg et al., 1975b) of
all mills in these segments of the industry.  The data collected can be
employed by NPDES applicants to allow selection of the best available system
to serve various specific needs.  The scale control system developed by
Rosenburg et al. also can be introduced.

Conversely, the lack of demonstrated control techniques prevented EPA from
applying S02 NSPS to kraft mill recovery furnaces and lime kilns (EPA,

1976b).  Thus, at the present state of the art, no projections can be made at
this time on the trend of efforts to control this pollutant from these sources.

The same is true of the carbon monoxide (CO) and nitrogen oxide (NOX) emis-
sions from these same sources.  Currently no control technology has been
demonstrated for these facilities (EPA, 1976b).  Similarly,, there are no
discernible trends in the control of NOX from ammonia base sulfite or NSSC

I.C.5.  Environmental Impact

Greater environmental impact due to growth in pulp and paper production
capacity can be expected from incremental expansion of existing facilities—
expanded -pulping capacity and additional paper machines—rather than from
completely new mills since the  current prevailing trend to modernization is
expected to continue (Michaud, 1977; New Plants, 1978).  However, the trend
toward increased size—whether in existing or new mills—can exert a strong
local aesthetic impact.

The trend toward countywide land use planning, which exists today in many
areas, should reduce the mistakes of the past when industrial zoning, if it
existed, was confined mostly to municipal communities.  In-town mills are
usually not of the very large dimensions envisioned here (although there are
some exceptions) and generally it is the countryside that will be most affected
by their appearance.

Environmental pollution from new or expanded mills may impact local and
regional environs to different degrees depending on site specific conditions,
type of facility proposed, and extent of pollution control and other miti-
gative measures.

In terms of air pollution, the impact of new .mills constructed in pristine
areas will be minimized by the significant deterioration regulations discussed
in Section I.E.2. The net impact of the emissions of new or expanded facilities
planned for industrialized areas also should be less than in the past because
of EPA's offset regulations, also discussed in Section I.E.2.

In terms of liquid effluents, while new mills have the advantage of incorpo-
rating new or improved processes, EPA's background study to establish effluent
guidelines and standards (EPA, 1976a) found no significant correlation between
age of the mill and raw waste load.   Many old mills have been upgraded and
modernized to remain competitive with new mills, and as a result have remained
competitive in waste treatment required.  Thus, if there are differences in
degree of water quality impact between new mills and old ones, they will
result primarily from variations in stringency of effluent limitations imposed.
Age of mills was not a determination in subcategorization of this industry.

The size of mills was similarly discounted in subcategorizing the industry
because the data available demonstrated no apparent correlation between size
of mill and raw waste flow and BOD load in terms of gallons and pounds per
ton of product, respectively  (EPA, 1976a), and the effluent limitations were
designed to equalize the requirements for all mills, regardless of size.
However, the potential effect of the effluents of larger mills on individual

stream assimilative capacity may indicate the need for water quality related
effluent limitations authorized by Section 302 of P.L. 92-500.   Applicants
should consider this potential early in the site selection process where
discharge into small streams is involved.

The process trends discussed in Section I.C.3 will tend to lessen adverse air
and/or water impacts if and when any of them are perfected for widespread use.

I.C.6.  Markets and Demands

In 1971, based on the anticipated performance of the gross national product
(GNP), the traditional bellwether of paper industry growth, the American
Paper Institute (API) made the projections shown in Table 3.  Due to the
economic recession during 1974, and concomitant slump in the GNP, actual
production is running far behind these projections.  Bureau of the Census
production data for 1976 (in 1,000 short tons) are:

     •   Paper, 26,573

     •   Paperboard, 28,439

     •   Total, 55,012 (excluding building paper and hardboard)

Because demand has not correlated well with the GNP since the recession, API
is not updating such long-range forecasts and does not plan to do so until
the industry stabilizes.  Thus, any estimates on the number of new mills or
the type or size required beyond the immediate future would be unreliable.

The short-range view is that if the predicted GNP growth for 1978 is accurate,
paper and board production is likely to rise by about 5% in 1978 (Towe, 1977).
This means that the industry could be operating at close to capacity in nearly
all grades.  This will not necessarily mean an intense effort to expand
existing capacity, however, because as indicated by Pulp & Paper (Towe, 1977),
when high operating rates are approached during an expanding economy, more
capacity is normally found than is reported.  Such increases are achieved by
maximizing grade mix and by lowering product standards.

The United States continues to lead the world in per capita consumption of
paper and paperboard.  In 1968, consumption was 551 pounds per year; in 1969,
it was 576 pounds, and in 1970, 556 pounds.  Sweden was second with figures
of 270, 410, and 420 pounds per year in 1968, 1969, and 1970, respectively.
Canada was in third place,  just slightly behind Sweden.  Current per capita
consumption is nearly 600 pounds per year in the United States and could reach
750 pounds per year by the year 2000 if present use trends continue.


When all recent Federal environmental control statutes are fully implemented
at the state and local level, environmental problems that could be classed as
"significant" should be greatly reduced  in  new or expanded pulp and paper
mills, under normal conditions, with one major exception.  This exception is
odor from kraft mills, which can remain detectable in the ambient air in the
part-per-billion range, even after regulatory requirements are met (NCASI/
EPA, 1973).


Table 3.  Paper industry production:  1970-1990
                          1,000 short tons
summary. 1977.
Other grades
American Paper Institute
    Monthly,  July.

I.D.I.  Location

Most of the largest mills will be constructed in relatively undeveloped, rural
areas or in areas of much smaller structures.  Such mills will be very large
in overall dimension to accommodate the great capacity for which they are
designed—paper machines may be a city block long.  Mills which engage in
pulping are also likely to be very tall to accommodate the height of large
digesters.  Thus, significant alteration to an existing landscape can occur.

The most effective mitigating measure appears to be siting the facility where
the least number of persons will be impacted by it.  Site locations of this
sort occur naturally in some areas where mills are located in a vast expanse
of wooded terrain that provides the raw material for the mill.

Any new mill designed to pulp wood grown on the premises will, of course, be
more amenable to this type of site selection.  Mills that are to use woods
chipped in off-site forests and brought in by truck or rail will have a wider
range of site choice and will probably constitute the more troublesome
location problem.

All pulp mills and most paper mills are located on bodies of water because of
the large quantities of water required for process and cooling use and ulti-
mately for wastewater discharge.  Compliance with applicable NSPS to be
imposed by EPA, or with the even stricter Section 302 site-specific effluent
limitations of P.L. 92-500, should minimize potential impacts on receiving
water bodies.

Similarly, mill location could be a factor in air pollution problems when new
or expanded mills are proposed for pristine areas.  All proposed facilities
are subject to prevention of significant deterioration (PSD) review by EPA,
and those proposed for such areas will be subject to standards which should
serve to minimize degradation of existing air quality.  The locational
significance of mills proposed for nonattainment air quality areas where
additional emissions would violate ambient air standards likewise is
reduced by the offset regulations.  Both situations are discussed in
Section I.E.2.

The impact of locating mills in wooded areas can be positive or negative
depending on the specific site.  If the forests are in nonrecreation areas
and the principal use would be to serve the mill, they can act as an effective
buffer in terms of public perception of odor and noise and can screen the mill
from public view.  Conversely, a mill location adjacent to a national forest,
for example, could interfere with public use and enjoyment of the forest.

Because the siting of pulp or paper mills can involve a significant change in
land use, particularly in rural areas, direct and indirect social and ecolog-
ical impacts can occur.   The direct impacts primarily will be a function of
the type of facility proposed and the site specific conditions; the magnitude
and significance of secondary or indirect impacts, such as induced growth,
infrastructure changes,  and demographic changes will depend largely on the
local economy, existing infrastructure, numbers and characteristics of
construction workers (e.g., local or nonlocal,  size of workers family),  and
other related factors.   Long-term secondary impacts usually are most

significant when the mill, because of its size, processing methods, and
location, employs a sufficiently large number of workers to lead to the
creation of a mill town.

Paperboard mills are most likely to be constructed in metropolitan areas which
supply their raw material.  Their impact will be felt in increased flow and
pollutant loads in the municipal wastewater treatment system into which they
discharge.  Due to the mandatory cost-sharing provisions of the Federal Water
Pollution Control Act imposed on users of publicly-owned treatment plants,
applicants should determine the relative costs of pretreating their wastes to
reduce loadings.  Although the wastes from paperboard mills are generally
compatible with municipal waste treatment9 pretreatment measures should be

Prudent site selection also can be a means to alleviate the kraft mill odor
problem.  The extent of community exposure can be minimized by careful study
of local meteorological conditions that affect the dispersion or dilution of
the odorous emissions to indicate the most favorable location from this

I.D.2.  Raw Materials
The raw materials enumerated earlier contribute substantially to the potential
environmental problems.  Fiber generates a large BOD raw waste load and
pulping chemicals, predominantly sulfur compounds, cause unpleasant odors.
Where ammonia is used as the pulping base in sulfite or NSSC mills, nitrogen
oxide (NOX) emissions may also result.   Chemical pulping and bleaching
operations also produce great quantities of color.  Fillers commonly used,
such as clay, talc, and gypsum, contribute to the suspended solids and
turbidity in the waste streams.  Wood,  where wet barking is practiced on the
premises, also contributes fine particles of bark and wood, as well as
dissolved solids, sand, and grit.

The unloading, storing, and handling of raw materials always have the potential
for causing environmental problems.  Spills and leaks of liquid chemicals,
such as caustic soda, ammonia, and sulfuric acid, from tank cars or tank
trucks do occur, and provisions should be made to contain, store, and treat
such chemicals.  Fuel oil leaks or spills should also be considered, and
procedures should be established to minimize impacts that could result from
such discharges.

The impacts associated with the harvesting of trees to supply the raw material
for pulping may also present environmental problems separate from those on the
mill site.  While these impacts are of concern, they are beyond the scope of
this guidance document.

For additional comments on raw material trends and associated impacts, see
Sections I.C.2. and II.B.l., respectively.

I.D.3.  Processes

Many pollution problems in this industry are process-oriented.  First,  the
processes employed will dictate, to a major extent, the use of certain types
of raw materials which generate the problems discussed above in I.D.2.  Second,
the processes themselves will bring about various chemical reactions that
directly affect the type and quantity of pollution generated.  The inter-
relationships of kraft pulp bleaching and color and kraft chemical recovery
and odor are major examples.  The process/pollution interface is further
delineated by the large number of separate subcategories necessary to account
for all of the process-oriented waste variations.

The major characteristics of the raw waste loads contributed by the primary
processes used by the industry are summarized in Table 4.

Foam on receiving waters is another problem which in some instances is
traceable to the process because it can result from black liquor losses.
Alkaline liquors have a strong propensity toward foaming.  Good loss control
should be practiced to avoid this problem.

The major air pollution problems related primarily to processes, in addition
to kraft odor, are:

     •   Sulfur dioxide (S02) emissions from kraft, sulfite, and
         NSSC mills

     •   SC>2 and particulate emissions from power boiler operations

Nitrogen oxides from kraft recovery operations and lime kilns, and, potentially
ammonia base sulfite and NSSC mills, along with carbon monoxide emissions from
the same kraft sources are much lesser problems (EPA,  1976b).

The major process-oriented solid wastes include:

     •   Bark and grit from wood preparation

     •   Bottom ash, clinkers, or fly ash from power boilers utilizing
         coal and/or bark

     •   Sludge from wastewater treatment
     •   Wire, strapping, tramp metal, glass, plastics, dirt, coatings,
         ink, and fillers from wastepaper reclamation

     •   Inert grits and dregs from kraft pulping

     •   Inert materials and some oxide of the base cooking chemical
         from sulfite pulping

     •   Shives  from groundwood pulping
     •   Unusable waste product in specialty mills such as glassine,
         zinc oxide, solvent, or plastic coated papers, and high
         wet-strength grades (Gorham, 1974a)

I.D.4.  Pollution Control

With proper control of losses from the mill, well-designed, maintained, and

       Table 4.  Major characteristics of process raw waste loads of
                      the pulp and paper mill industry
Wood preparation

Groundwood pulping (all types).

Kraft pulping

Soda pulping

Sulfite pulping
NSSC Pulping

    Fine papers


Groundwood bleaching
Kraft bleaching (papergrade
    and dissolving)
Sulfite bleaching (papergrade
    and dissolving)
Suspended organic and inorganic matter

Suspended and dissolved organic matter
Alkaline pH (chemigroundwood)

Suspended and dissolved organic matter
Aquatic toxicity
Slightly alkaline pH

Dissolved organic matter
Aquatic toxicity

Same as kraft  pulping

Suspended and dissolved organic matter
Heavy metals
Aquatic toxicity
Acidic pH

Suspended and dissolved organic matter
Aquatic toxicity
Dissolved organic matter
Slightly alkaline pH
Suspended organic and inorganic matter

Suspended and dissolved organic matter
   (carried over from pulping)
Zinc (if zinc hydrosulfite is used)
Suspended and dissolved organic matter
Heavy metals
Aquatic toxicity
Acidic pH
Dissolved organic matter
Heavy metals
Aquatic toxicity
Acidic pH

      Table 4.  Major characteristics of process raw waste loads of
               the pulp and paper mill industry—Continued
Suspended organic matter
Suspended organic and inorganic matter
Suspended organic matter
Varies according to product
*Not yet a subcategory.

Source:  Gehm, H.W.  1971.  Industrial waste study of the paper and allied
         products industries. EPA Contract No. 68-01-0012.  (unpublished)

operated aerobic primary and biological waste treatment systems should not
produce odor of public significance.  However, odors associated with anaerobic
decomposition are detectable in very low concentrations when this condition
is permitted to occur.  Some of these odors are sulfurous in nature while
others are characteristic of wood extractives (EPA, 1976a).   In the case of
kraft mills, good recovery of spent pulping liquors is particularly necessary
to reduce the TRS compounds reaching the treatment system to avoid odor from
this source.
Odor problems should also be minimal in land application of  well-digested or
otherwise stabilized wastewater treatment plant sludges.  Undigested sludges
used in this manner would certainly produce odor and create  insect problems
as well.  The odor of wet sludges can be particularly troublesome during
basin cleaning.
Because of the nature of pulp and paper mill sludges, high temperature
incineration using high-efficiency scrubbers should provide  an adequate safe-
guard against the release of air pollutants.  None of the substances that EPA
has designated as hazardous air pollutants is expected to be present in the
sludge.  The only possible exception is asbestos, which is used only inter-
mittently at a .very few specialty mills, if use of this material has not been
abandoned altogether.
The air pollution control equipment which will be required to meet the kraft
mill NSPS will not contribute significantly to land disposal problems.  The
dry-bottom electrostatic precipitator for control of recovery furnace and lime
kiln emissions is the only device which would collect particulates as a dry
mass.  The sodium sulfate collected from the recovery furnace will be reused,
and the sodium salts, calcium carbonate, and calcium oxide collected from the
lime kiln emissions can be similarly returned to the system (EPA, 1976b).
If the caustic scrubber is used to control lime kiln emissions, it may be
necessary to dispose of some sodium waste depending on the mill's ability to
accept the added sodium in the form of caustic.  Slurries from wet bottom
electrostatic precipitators on recovery furnaces and smelt tank scrubber
water are recycled to the recovery system (EPA, 1976b).  Power boiler scrubber
effluents are the only wastes of this type which are commonly lagooned although
some mills send them to the effluent line.

There has been virtually no measurement of leachate contamination from the
land disposal of pulp and paper mill solid wastes.  If studies of this kind
have been conducted at specific sites, the results are the property of the
mill.  Because of the nature of most of the industry's solid wastes, disposal
control agencies have in the past tended to be lenient in granting permits
without specific information on leaching potential (Gorham,  1974).
Bark, however, has sufficient leaching potential to require  careful disposal
in order to avoid ground and surface water contamination.  Leaching of its
water soluble components can generate color, COD, BOD, and bacterial oxygen
changes if anaerobic conditions exist (Hanson, 1972).  A number of organic
compounds could also be leached from bark on contact with waste solvents in
a disposal environment.  These include terpenes, fats, waxes, resins, tannins,
and many others (Gorham, 1974).  The impact of these types of leachates as
well as those from essentially inorganic wastes can be considerably reduced
by collecting and returning them to the waste treatment system.

A mixture of alkaline and acid wastewaters in mill sewering arrangements, air
entrainment in sewers, and aeration in biological treatment may also lead to
an unaesthetic foam problem.  Correct sewering arrangements, good outfall
design, diffusers, or, where necessary, foam control agents should be employed.


I.E.I.  Water Pollution

The Federal Water Pollution Control Act (FWPCA) Amendments of 1972 established
two major, interrelated procedures for controlling industrial effluents from
new sources, and specifically included pulp and paper mills in the list of
affected categories of sources.  The principal mechanism for discharge regula-
tion is the NPDES permit.  The other provision is the new source performance
standard.  The Clean Water Act of 1977 (P.L. 95-217), which amends P.L. 92-500,
made no change in these basic procedures.

The NPDES permit, authorized by "Section 402 of FWPCA, prescribes the conditions
under which effluents may be discharged to surface waters.  The conditions
applicable to new or expanded pulp and paper mills will be in accordance with
NSPS, adopted by EPA pursuant to Section 306, and pretreatment standards
promulgated to implement Section 307(b).  Different standards will be applica-
ble  nationwide  depending on the subcategory of mill under consideration.
Stricter effluent limitations may be applied on a site specific basis if
required to achieve water quality standards.

The effluent NSPS promulgated for new sources in the unbleached kraft, NSSC
sodium base, NSSC ammonia base, NSSC/unbleached kraft with cross recovery,
and waste paperboard subcategories are shown in Table 5.  Effluent NSPS are
proposed for the other 17 subcategories and also are included in Table 5.
If the proposed standards are adopted, most mills will be represented in
this table.  The absence of effluent NSPS applicable to specialty mills and
textile fiber mills means that new or expanded mills in these categories can-
not be defined as new sources and the issuance of NPDES permits by EPA is not
subject to NEPA.

New sources that discharge  wastewater to  publicly  owned treatment works
 (POTW's)are required  to  comply with EPA's pretreatment  regulations,  issued
in the June 26,  1978  Federal  Register (as 40 CFR 403).   These  regulations
stipulate that certain POTW's,  categorized by size and  influent  character-
istics,  develop  POTW  Pretreatment  Programs.   These programs  are  intended
to prevent the introduction of pollutants by industrial users  that would
interfere with the operations of  treatment works,  would pass through treat-
ment works,  or would  adversely affect opportunities to  recycle and reclaim
wastewaters and  sludges.

Regardless of  specific limitations required by the Pretreatment  Programs,
the regulations  (Section 403.5) state 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 in no case discharges  with pH lower  than  5.0, unless
          the works is specifically designed to accomodate such discharges.


                   Table 5.  Promulgated and proposed Federal new source performance standards
             applicable to subcategories of the pulp, paper, and paperboard point source categories
Total suspended solids
NSSC sodium
NSSC un-
recovery) *t
kg/kkg Ib/ton
of of
product product
3.1 6.2
5.2 10.4
7.5 15.0
3.8 7.6
1.5 3.0
11.75 23.5
3.8 7.6
Maximum average
of daily values
for 30 consecu-
tive days
kg/kkg Ib/ton
of of
product product
6.5 15.0
7.7 15.4
7.5 15.0
8.0 16.0
4.0 8.0
15.5 3.10
5.35 10.7
Maximum average
of daily values
for 30 consecu-
tive days
kg/kkg Ib/ton
of of
product product
3.75 7.5
3.85 7.7
3.75 7.5
4.0 8.0
2.0 4.0
8.35 16.7
2.9 5.8

              Table 5.   Promulgated and proposed Federal new source performance standards
        applicable to subcategories of the pulp, paper,  and paperboard point source categories—Continued
                       Total suspended solids
BCT bleached
Fine bleached
.P- kraft
Low alpha
Maximum average
of daily values
for 30 consecu-
tive days
Maximum average
of daily values
for 30 consecu-
tive days
 mechanical**    3.15     6.3

 mechanical**    4.45     8.9

 CMN papers**    3.85     7.7
1.65     3.3

         6.15    12.3
5.85    11.7
5.85    11.7
3.15     6.3
3.15     6.3

              Table 5.  Promulgated and proposed Federal new source performance standards
        applicable to subcategories of the pulp, paper, and paperboard point source categories—Continued
Total suspended solids
Maximum average
of daily values
1-day for 30 consecu- 1-day
Subcategory maximum tive days maximum
kg/kkg Ib/ton kg/kkg Ib/ton kg/kkg Ib/ton
of of of of of of
product product product product product product
papers** 3.7 7.4 1.9 3.8 5.6 11.2
Soda 6.0 12.0 3.15 6.3 7.95 15.9
Deink 7.5 15.0 3.9 7.8 7.45 14.9
Maximum average
of daily values
for 30 consecu-
tive days pH
kg/kkg Ib/ton
of of
product product
3.0 6.0 5.0-9.0
4.3 8.6 5.0-9.0
4.0 8.0 5.0-9.0
 fine paper      2.6      5.2      1.35     2.7      2.6      5.2

 tissue paper    4.15     8.3      2.15     4.3      4.1      8.2

 tissue from
 waste paper     3.7      7.4      1.9      3.8      3.65     7.3

High alpha dis-
 solved sulfite 26.5     53.0     13.8     27.6     17.6     35.2

Papergrade sul-
 fite market
 pulp           19.3     38.6      1.05    20.1     12.7     25.4
              1.4     2.8
              2.2     4.4
              1.9     3.9
              9.45   18.9
              6.85   13.7

              Table 5.   Promulgated and proposed Federal new source performance standards
         applicable to  subcategories of the pulp, paper, and paperboard point source categories—Continued

* Promulgated; all others proposed.

t The color limitations are as follows:                                „
                                                                       Maximum average
                                                                       of daily values
                                        1-day maximum               for 30 consecutive days
                                     kg/kkg         Ib/ton         kg/kkg          Ib/ton
                                   of product     of product     of product      of product

       Unbleached kraft                15.0           30.0           10.0            20.0
       NSSC/unbleached  kraft           25.0           37.5           12.5            25.0

**Mills using zinc hydrosulfite as a bleaching agent are subject to zinc pretreatment standards.

Source:  US Environmental Protection Agency.  1976a.   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 the pulp,  paper, and paperboard  mills  point
         source category.  EPA 440/1-76/047-b, Dec.

     •   Solid or viscous pollutants in amounts which cause obstruction
         to the flow in 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 in
         the POTW.

In addition, there is a restriction on thermal discharges that becomes
effective in June 1981.

Since new sources discharging to POTW's do not require NPDES permits, they
are not subject to NEPA under Section 511(c)(l) of the Federal Water
Pollution Control Act, as amended by the Clean Water Act of 1977.

NPDES permits also impose special conditions beyond the effluent limitations
stipulated, such as schedules of compliance and treatment standards.  Once
mills are constructed in conformance with all applicable standards of per-
formance, however, they are relieved by Section 306(d) from meeting any more
stringent standards of performance for 10 years or during the period of
depreciation or amortization, whichever ends first.  This guarantee does not
extend, however, to toxic effluent standards adopted under Section 307(a),
which can be added to the mill's NPDES permit when they are promulgated.

The toxic standards will be industry-specific—or possibly subcategory-specific
—and a study to determine the need for such standards in the pulp and paper
industry is currently in progress.  The outcome of this will not be known for
some time, although the EPA Administrator is under court order to promulgate
toxic effluent standards for a number of specified industries, including the
pulp and paper industry, no later than 30 September 1980>  if the finding is
that an industry's effluents contain more than trace amounts of the toxic
compounds itemized in the recent consent agreement.*  P.L. 95-217 also expands
Section 307(a) of P.L. 92-500 dealing with toxic standards or prohibitions on
existing sources.  Thus, any evaluation of the impact of new or expanded mills
should include a verification of the status of applicable toxic effluent

Many States have qualified, as permitted by Public Law 92-50.0, to administer
their own NPDES permit programs.  The major difference in obtaining an NPDES
permit through approved State programs vis-a-vis the Federal NPDES permit
program is that the Act does not extend the NEPA environmental impact assess-
ment requirements to State programs.  As of April 1976, however, 26 States
had enacted NEPA-type legislation and others plan to do so.  Thus, it is likely
that new mills or major expansions of existing mills will come under increased
environmental review in the future.  Because the scope of the implementing
regulations varies considerably, current information on prevailing requirements

*Natural Resources Defense Council, Inc., et al., v. Russel Train, Civil
 Action No. 2153, Final Order and Decree, U.S. District Court for the
 District of Columbia (1976).

                                     46   -

should be obtained early in the planning process from permitting authorities
in the appropriate jurisdiction.

I.E.2.  Air Pollution

The Federal regulations applicable to the air emissions from pulp and paper
mills are the particulate and sulfur dioxide ambient air quality standards and
NSPS on particulate and total reduced sulfur emissions of kraft mills.  The
NSPS, which are emission standards, were finalized in the Federal Register
of 23 February 1978, Part V.

The particulate standards (40 CFR Part 60, Subpart BB) are shown in Table 6.

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 recovery furnaces, cross
recovery furnaces, lime kilns, brown stock washer systems, black liquor
oxidation systems, condensate stripper systems, digester systems, multiple-
effect evaporator systems, and smelt dissolving tanks are shown in Table 7.
The standards for the last six of these sources may be waived if the off
gases are combusted in a lime kiln or recovery furnace which meets the require-
ments 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 stan-
dards, provided they are subjected to a minimum temperature of 649°C (1200°F)
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 particulate 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.  However, the EPA Administrator may exempt any new,
modified, or reconstructed black liquor oxidation system or brown stock
washer system at an existing kraft pulp mill from the TRS standard, provided
the owner or operator demonstrates that incineration of the exhaust gases
from such systems in an existing recovery furnace is not technologically and
economically feasible.  Any exempt system will become subject to the provi-
sions of this subpart if the recovery furnace is changed so that the gases
can be incinerated.

As of October 1974, 12 States and several California counties had adopted
emission standards applicable to all sources of TRS discharges or to kraft
mills in particular.  They range from 1.0 to 70.0 ppm and from 0.05 to 1.0
kg/kkg (0.1 to 2.0 Ib/ton) of ADP.  Promulgation of the Federal NSPS for TRS
emissions from kraft mills does not prevent state or local agencies from
adopting more stringent emission limitations for these sources.

Power boilers of  250 million Btu  input or larger operated on
fossil fuels are subject to the standard shown in Table 8.  EPA is considering
the applicability of the particulate standard to bark boilers, but the ques-
tion is not yet resolved.  There are currently no standards for smaller

                 Table 6.  New source performance standards for
                      particulates from kraft pulp mills
Recovery furnace
Smelt dissolving tank
Lime kiln:
    When gaseous fossil fuel
     is burned

    When liquid fossil fuel
     is burned
Maximum particulate matter
  0.10 g/d/stdm3 (0.044 gr/d/stdft3)
  at 8% oxygen
Maximum 35% opacity

Maximum particulate matter 0.1 g/kg
  black liquor solids
(BLS) (0.2 Ib/ton BLS) (dry weight)

Maximum particulate matter 0.15
  g/d/stdm3 (0.067 gr/d/stdft3)
  at 10% oxygen

Maximum particulate matter
  0.30 g/d/stdm3 (0.13 gr/d/stdft3)
  at 10% oxygen
Source: 40 CFR Part 60, Subpart B.B.

              Table 7.  New source performance standards for
                         total reduced sulfur (TRS)
                           for kraft pulp mills
g/kg(lb/ton)  BLS
 (dry weight)
Recovery Furnace

Cross Recovery Furnace

Lime Kiln

Brown Stock Washer System

Black Liquor Oxidation System

Condensate Stripping System

Digester System

Multiple-Effect Evaporator System

Smelt Dissolving Tank

  By volume dry basis.

  Corrected to 8% oxygen.

c Corrected to 10% oxygen.

                   Table 8.  Standards for power boilers:
                           Pulp and paper industry

               Component	Standard
Particulate                           No particulate in excess of 43 ng/J
                                        (0.10 Ib/millions Btu)

Opacity                               Exhibit>20% opacity except 40%
                                        opacity for 2 minutes in any hour

S0«                                   Maximum of 520 ng/J heat input
                                        (1.2 Ib/million Btu)
Source:  40 CFR Part 60.

The Federal NSPS do not impose SC>2 emission standards on processes of pulp
and paper mills.  As noted in Section I.C.4., the emissions of this pollutant
from kraft mill recovery furnaces and lime kilns were specifically excluded
from the NSPS because best demonstrated control techniques, considering costs,
have not been identified  (EPA, 1976b).  Some States have, however, adopted
such standards, although some of them apply only to specific industries or
only to combustion sources.  The applicability of these standards should be
clarified when considering the impact of any new source.

It is possible that the Federal SC>2  ambient air quality standards (40 CFR
Part 50), which are nonenforceable goals for acceptable levels of this pollu-
tant, may be exceeded in the  vicinity of kraft, sulfite, or NSSC pulp mills.
Depending on site-specific operations, ambient air standards for particulates
could be violated by many types of operations in this industry, although no
particulate-related problems are likely to be associated with enclosed
mechanical pulping operations.  Particulate standards are shown in Table 9;
S02 standards appear in Table 10.

Kraft mills with the potential to emit 91 kkg (100 tons) or more per year of
any air pollutant, or any other mills with the potential to emit 227 kkg (250
tons) or more per year of any pollutant, may be excluded from certain areas
under the Federal PSD regulations or be required to meet more stringent air
quality goals than the ambient air standards in others.  The Clean Air Act
Amendments of 1977 (Public Law 95-95) establish three types of areas:
    •    Class I areas, in which almost any deterioration of air
         quality is deemed significant
    •    Class II areas, in which a  moderate increase in pollution
         concentration is acceptable, to allow for moderate growth

    H    Class III areas, in which a greater pollutant  increase
         is acceptable

Increases in pollutant concentrations over baseline values are limited in
these areas to those shown in Table  11.  The allowable  increments are limited
to those which will not cause violations of the ambient air quality standards.

All international parks, national wilderness areas, and national memorial
parks that exceed 5,000 acres, and all national parks that exceed 5,000 acres
are classified as Class I areas.!  However, an exception may be granted to a
source exceeding the Class I allowable increase on these mandatory Class I
areas if a Federal land manager certifies that the facility will have no
adverse impact on the air-quality-related values, including visibility.  In
such cases, the allowable increases  listed in the last  column of Table 11

All other areas are designated as Class II, but States may redesignate these
areas as Class I or III, provided certain requirements  of Public Law 95-95
are fulfilled.

Similar air quality regulations may  be applied to new mills or significantly
modified existing mills in industrial areas where ambient air standards are
being exceeded.  Permits will be required for construction and operation of
major new or modified sources and applicants will be required to achieve the

          Table 9.  Federal ambient air standards for particulates
Primary standard:
    Annual geometric mean                                 75
    Maximum 24-hour concentration,
      not to be exceeded more than
      once a year                                        260

Secondary standard:
    Annual geometric mean                                 60
Source:  40 CFR Part 50.

                 Table 10.   Federal ambient  air
                  standards for sulfur dioxide
    Primary standard:

      Annual arithmetic mean
      Maximum 24-hour  concentration not
       to be exceeded  more than once a year   365

   Secondary standard:

      Maximum 3-hour concentration not
       to be exceeded  more than once a year  1300
Source:  40 CFR Part 50

              Table 11.  Nondeterioration increments for S0_ and
                     particulate matter in areas with
                   different air quality classifications

        „ nn .   .             Class.,1     Class_II   Class_III  Class I exception
        Pollutant            /  / 3N     /  / 3,    ,   , 3,         /•  / 3N
                             (yg/m )     (yg/m )    (yg/m )         (yg/m )
Particulate matter:

  Annual geometric mean         5          20         37              19

  24-hour maximum              10          37         75              37

Sulfur dioxide:

  Annual arithmetic mean       2           20         40              20

  24-hour maximum              5*          91        182              91

   3-hour maximum             25*         512        700             325
*A variance may be allowed to exceed each of these increments on 18 days
 per year, subject to limiting 24-hour increments of 36 yg/m3 for low
 terrain and 62 yg/m3 for high terrain and 3-hour increments of 130 yg/m3
 for low terrain and 221 yg/m3 for high terrain.  To obtain such a variance
 requires both State and Federal approval.

Source:  Clean Air Act Amendments of 1977.

"lowest achievable emission rate" of any pollutant which exceeds the standards.
This rate is defined as a rate of emissions which reflects:

          The most stringent emission limitation in the applicable State
          implementation plan unless the applicant can demonstrate that
          such limitations are not achievable; or

     0    The most stringent limitation which is actually achieved in
          practice by similar mills.

Public Law 95-95 further requires that the permit to construct and operate
may only be issued if:

     0    By the time the mill is to commence operation, total allowable
          emissions from all existing and new sources in the Air Quality
          Control Region, including the new or modified mill, will permit
          reasonable further progress toward attainment of the applicable
          national ambient air standard for the identified pollutant, or

     0    The emissions of such pollutant from the new or modified mill
          will not cause the total emissions of the pollutant to exceed
          the allowance permitted by the implementation plan for the
          pollutant from all new or modified sources in the area.

I.E.3.    Land Disposal of Wastes

The applicability of various provisions of the Resource Conservation and
Recovery Act (RCRA) to wastes of pulp and paper mills is not well defined at
present.  The most stringent provisions of this legislation deal with hazard-
ous wastes, and all parties who generate, transport, treat, store, or dispose
of hazardous wastes are subject to regulation, through EPA or a State with
an approved State program.

At the time of publication of these guidelines,  EPA's Hazardous Waste Manage-
ment Division had not listed the wastes of the pulp and paper industry that
are sent to land disposal, including waste treatment sludge, as hazardous
within the meaning of the Act.  Unless this situation changes, the pulp and
paper industry, as a whole, will riot be considered as an affected party
under Subtitle C of RCRA, which provides for regulation of hazardous wastes.
The determination of whether to list pulp and paper mill industry waste as
hazardous will be made in part on the outcome of studies on the concentrations
of toxic substances in pulp and paper mill sludges conducted by EPA's
Industrial Waste Laboratories.  Until such a determination is made, each new
proposed mill will be evaluated on a case-by-case basis.  The applicant
should present in the EID an analysis of the projected characteristics of
sludges from the facility.  The analysis should be based on the nature of
the raw materials to be used, on the types of production and waste treatment
processes proposed, and on data on sludges from comparable facilities.

The industry's other solid wastes for land disposal — inert grits and dregs,
bark, ash, trash, etc. — will be subject to the sections of RCRA dealing
with nonhazardous solid wastes.  In general, recovery or disposal in a
sanitary landfill will be required under a State regulatory program.  New
open dumps will be prohibited.


Existing State regulatory requirements for solid and hazardous waste disposal
that do not meet or exceed the new Federal requirements will be superseded,
and for purposes of this discussion,  they may be considered obsolete.   The
acceptable types of land disposal are discussed in Section III.



This subsection covers the generation of liquid effluents, stack emissions,
and wastes for land disposal.

II.A.I.  Wood Preparation

Where wet barking is practiced, total woodyard effluents that may be expected
are on the order of those shown in Table 12.

There are no data available on particulate emissions from pulp mill woodyards,
and airborne material will not be a problem in wet operations.  In the dry
barking  systems, there is a  potential  for minor problems  of  this type.

wood slivers.

II.A.2.  Kraft Pulping

The major sources of wastewater from the kraft pulping process are pulp
washing, digester and evaporator condensates, and chemical recovery.  Figure
9  shows the added contribution of bleaching in bleached kraft mills and the
papermaking operation.  These values represent an average mill, and reflect
minor variations from other data because of rounding.

Pollution components of kraft pulping  include suspended solids, dissolved
organics, electrolytes, and  inorganic  compounds attached to  the organic com-
pounds.  The biological degradable organics include fatty acids, methanol,
ethanol, turpenes, acetone,  and other  cellulose decomposition products
(Hruitford and McCarthy, 1967; NCASI,  1972; Wenzl, 1967; Wilson et al., 1972).
This  component accounts for  a major percentage of the BOD5 in kraft mill
effluent.  The nondegradable organic component—lignins and  tannins—is
responsible for a large part of the color.  Color is especially troublesome
in bleached kraft operations because bleaching extracts these color bodies.
Chlorides are also a major pollutant contributed by bleaching.

The  range in parameters among  the unbleached kraft mills  surveyed for the
effluent guidelines study is shown in  Table 13.  American Public Health
Association  (APHA) color units are typically in the 500-1,000 range.

In bleached kraft mills:

     •   Total suspended solids  (TSS)  concentrations in effluents range
         widely, but average between about 20 and 30 kg/kkg  (40 and 60
         Ib/ton) in well-operated mills.

     •   The average BOD5 load amounts to 12.5-25 kg/kkg  (25-50 Ib/ton).

     •   APHA color units during periods of normal operation range from
         500 to 2,000 values.

                       Table 12.   Woodyard effluents
                       during wet barking operations
                                     Type of pulping
Debarking :
Flow, in kl/kkg
BOD5, in kg/kkg
Log chip wash:
Flow, in kl/kkg
BOD5, in kg/kkg
Flow, in kl/kkg
BOD-5, in kg/kkg
























Papergrade kraft, Dissolving
soda, sulfite pulp



















• A)





• 6)


















Source:  US Environmental Protection Agency.   1976a.   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 the pulp, paper,  and
         paperboard mills point source category.  EPA 440/1-76/047-b,  Dec.

                             PULP MILL
                           BLEACH PLANT
                            PAPER  MILL
                                          1,000 GAL/TON
                                          2 LB BOD5/TON
                                          8 LB TSS/TON
                                          15 LB COLOR/TON
                                          6,000 GAL/TON
                                          23 LB  BOD5/TON
                                          17 LB TSS/TON
                                          65 LB  COLOR/TON
                                          9.6 pH
5,000 GAL/TON
                                          I I.OCO GAL/TON
                                          16 LB BOD5/TCN
                                          9 LB TSS/TGN
                                          65 LB COLOR/TON

                                          8,000 GAL/TON
                                          15 LB BOD5/TON
                                          5 LB TSS/TON
                                          145 LB COLOR/TON
                                          8,000 GAL/TON
                                          12 LB BOD5/TON
                                          34 LB TSS/TON
                                          5 LB COLOR/TON
                                          7.1 pH
          39,000 GAL/TON
          78 LB BOD5/TON
          100  LB TSS/TON
         300 LB COLOR/TON
 Source:   US Environmental Protection Agency.  1976a.   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  the pulp, paper,
           and paperboard mills point source category.   EPA 440/1-76/047-b, Dec.

Figure  9.   Effluent  characteristics for bleached kraft mill process waters

       Table 13.   Water quality values among unbleached kraft mills

        Item	Range	of mills	Mean
Flow                                          11
   kl/kg              39.2-112.6                               75
   gal/ton             9.4- 27.0                               18

BOD5                                           9
   kg/kkg             12.2-21.2                               17
   Ib/ton             24.5- 42.5                               34

TSS                                            7
'   kg/kkg             10.5- 28.0                               19
   Ib/ton             21.0- 56.0                               38

The kraft mill odor problem arises from the use of sodium sulfide as a
component of the cooking liquor.  In the digesters, the sulfide ion combines
with various organic side-chain radicals from the cellulose and the lignin
of wood chips to form such organic sulfides as methyl mercaptan, dimethyl
sulfide, dimethyl disulfide, and small amounts of similar ethyl sulfide
compounds.  In addition, hydrogen sulfide is formed in considerable amounts.
These gases are released with the digester relief and blow gases, as well as
from the recovery furnace, lime kiln, smelt dissolving tank, multiple-effect
evaporators, black liquor oxidation, brown stock washer, and condensate
stripping (Eddinger et al., 1974; NCASI, 1973).

Typical TRS emissions from an uncontrolled 907 kkg/d (1,000-ton/d) kraft
mill are shown in Table 14.

Particulate emissions occur primarily from the recovery furnace, the lime kiln,
and the smelt dissolving tank as follows:

     •   Recovery furnace emissions consist primarily of sodium sulfate
         and sodium carbonate.

     •   Lime kiln emissions are primarily sodium salts, calcium
         carbonate, and calcium oxide.

     •   Smelt dissolving emissions are caused primarily by the entrain-
         ment of particles and odorous materials in the vent gases.

Particulate emissions are also generated by power and bark boilers (NCASI,

Typical particulate emissions for an uncontrolled 907-kkg/d (1,000-ton/d)
kraft mill are shown in Table 15.

In addition to the bark generated in wood preparation, ash from the recovery
furnace and power boilers, and rejects and screenings, kraft mill  recovery
systems generate solid wastes that are largely peculiar to kraft pulping:

     •   Rejects from slakers and unburned lime rejects from the
         lime kilns

     •   Dewatered dregs from the green liquor clarifier, discharged
         as inert solid wastes, such as iron compounds, carbon, grit,
         and refractory materials, amounting to about 22.5 kg/kkg
         (45 Ib/ton) of pulp produced (EPA, 1974)

     •   Sodium salts removed with the dregs depending in amount on
         the completeness of the dregs-washing operation (Expansion,

II.A.3.  Sulfite Pulping

The most significant effects on sulfite effluent quantity and quality are
exerted by:

                       Table 14.   Typical TRS emissions:
                       Uncontrolled 907-kkg kraft mill
Exhaust gas
  flow rate
   (acfm)     ppm
             TRS emission rate
        kg/h   Ib/h   kg/kkg Ib/ton ADP
Digester system

  evaporator system

Brown stock washer

Black liquor oxidation

Recovery furnace system

Smelt dissolving tank

Lime kiln

Condensate stripping
9,500    28.6
6,800    19.0    42    0.5
Source:   National Council for Air and Stream Improvement/US Environmental Protection
          Agency.  1973.  Atmospheric emissions from the pulp and paper manufacturing
          industry.  Report 450/1-73-002, Sept.

                         Table 15.  Typical particulate emissions:
                             Uncontrolled 907-kkg kraft mill
 Exhaust  gas
   flow rate
                                                Particulate emission rate
gr/dscf g/dscm kg/h  Ib/h  k/kkg Ib/T ADP
Recovery furnace system     450,000

Smelt dissolving tank        58,000

Lime kiln                    79,200
                3.81     8.72   3,400  7,500   90       180

                1.39     3.18    151     333    4         8

                9.73    22.26   1,510  3,333   40        80
Source:  National Council for Air and Stream Improvement/US Environmental
         Protection Agency.  1973.  Atmospheric emissions from the pulp and
         paper manufacturing industry.  Report 450/1-73-002, Sept.

     •   The woodyard

     •   Pulp washing and recovery of the spent liquor

     •   Type of condenser

     •   Type of cooking liquor

     »   Bleaching

The effects exerted by barometric and surface condensers and the very acidic
cooking liquors (pH less than 3.0) as opposed to bisulfite liquors (pH between
3.0 and 6.0) are illustrated in Table 16,

Raw waste TSS levels in sulfite wastewaters—ranging between 50 and 100 kg/kkg
(100 and 200 Ib/ton)—are of secondary importance to BOD concentrations in
terms of the characteristics of treated effluents.  The solubles present in
the pulping effluent consist of lignosulfonates, lower fatty acids, alcohols,
ketones, wood sugars, and a number of other complex compounds (EPA, 1976a).

The relative contributions of the sulfite pulping and papermaking operations
are shown in Figure 10.

The dissolving sulfite subcategory uses essentially the same basic process
used in the papergrade subcategories; it generates a much stronger effluent,
however, because both the cooking and bleaching stages are more stringent—
to the point where over 60% of the wood becomes waste.

Sulfur dioxide is the principal^ air contaminant generated by sulfite pulping;
it derives mainly from the absorption towers used in producing the acidic
cooking liquor by reacting S02 with the desired base chemical, blow pit or
dump tank, multiple-effect evaporators, and chemical recovery systems.

The amount of S02 emitted from the absorption tower will depend on the design
and operating conditions of the individual tower.  S02 emissions from the
blow pit stack may range as follows (NCASI, 1973):

     •   Blow pit, hot blow:  100-125 Ib/ton ADP

     •   Dump tank:  10-25 Ib/ton ADP

The recovery practice and the 862 emissions will vary from one base to another
—i.e., sodium, magnesium, and ammonia.  Sulfur dioxide emissions from the
evaporators range from 5 to 10 kg/kkg (10 to 20 Ib/ton) (NCASI, 1973).

Solid wastes from sulfite pulping may include bark, rejects and screenings,
ash, and waste paper, as well as some inert materials and some oxide of the
base cooking chemical generated in the chemical recovery system.

In sulfite mills with recovery, solid waste generation averages about 5 kg/
kkg (10 Ib/ton) of pulp production.  In some cases, portions of these solid
wastes are deposited in the wastewater system for removal rather than
segregated for separate collection.

               Table 16.   Summary of raw waste characteristics
                     of papergrade sulfide mill effluents
kl/kkg    kgal/ton    kg/kkg    Ib/ton
Blow pit wash:

    Bisulfite/barometric      221
    Acid sulfite/barometric   221
    Bisulfite/surface         186
    Acid sulfite/surface      186

Drum wash:

    Bisulfite/barometric      221
    Acid sulfite/barometric   221
    Bisulfite/surface         186
    Acid sulfite surface      186

                         PULP MILL.
                      RECOVERY  UNIT
                       BLEACH PLANT
35,000 GAL/TON
180 LB
                        PAPER MILL
                                          15,000 GAL/TON
                                          10 LB BOD5/TOC
                                          110 LB TSS/TON
                                                     50,000 GAL/TON
                                                    190  LB 80D5/TON
                                                     160 LB  TSS/TON
Source:   US Environmental Protection Agency.  1976a.   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 the pulp, paper,  and
         paperboard mills point source category.  EPA 440/1-76/047-b,  Dec.

                   Figure 10.  Effluent characteristics
                   for sulfite mill pulping:  Drum wash

II.A.4.  Neutral Sulfite Semichemical Pulping

The raw waste load from NSSC mills depends largely on the base used (sodium
or ammonia), on whether chemical recovery is employed, and on the amount of
waste paper added to the furnish.  The effects of furnish and waste liquor
handling on sodium base NSSC effluents are illustrated in Table 17.

The wastewater characteristics of sodium base and ammonia base mills are
similar except for the nitrogen content of ammonia base effluents.  Typical
nitrogen values for an ammonia base effluent are 210 mg/1 Kjeldahl nitrogen
and 150 mg/1 ammonia nitrogen.  Only minor amounts of nitrogen are contained
in sodium base effluents.

Although extensive internal recycling has succeeded in reducing flow and BOD
loadings to very loV levels in some NSSC mills, this performance cannot be
maintained because of an intolerable build-up of spent cooking liquor in the
final product.  Thus, the high degree of recycle commonly practiced is fre-
quently accompanied by high BOD losses.

Sulfur dioxide is the primary air contaminant generated by NSSC mills and
occurs principally when the pulp is blown from the digester.  Sulfur dioxide
emissions will also result from the burning of ammonia base spent liquors, a
water pollution control measure.  The NSSC process is virtually free of
reduced sulfur compound emissions with minor exceptions.  No data were found
on particulates from the NSSC process.

The solid wastes generated by NSSC mills include bark, rejects and screenings,
chemical ash from bark incinerators and chemical combustion, and waste paper.
No data were found on typical quantities.

II.A.5.  Unbleached Kraft/NSSC (with cross recovery)

In combined NSSC/unbleached kraft operations, if the ratio of NSSC production
to kraft production does not exceed  1:3, the increase in  BOD and  TSS
of the kraft effluent is not expected to exceed 10%.  For surveyed NSSC/
unbleached kraft mills with cross recovery:

     n   Average flow is approximately 58.4 kl/kkg (14 kgal/ton)

     •   Average BOD load is about 19.4 kg/kkg (38.8 Ib/ton)

     •   Average TSS level is about 20.5 kg/kkg (41 Ib/ton)

The NSSC contribution to the combined effluent does not settle as well as
kraft effluent alone because of the higher load of fines.  The hardwoods used
in the NSSC mill also contribute somewhat more color than the softwoods used
in the kraft mill.

II.A.6.  Mechanical Pulping

As discussed in Section I.B.2.d., data on mechanical pulping effluents are
only available according to the traditional division of mills in this segment
of the industry—stone, refiner, chemi-groundwood, cold soda, and thermo-
mechanical.  It was the unexpected similarity in wastewater data among


                     Table 17.  The effects of furnish
           and waste liquor handling on sodium base NSSC effluents
Liquor handling
Flow Waste paper
kl/kkg furnish
k gal/ton (%)
Spray irrigation     44.6   10.7      33      8.5   17     8.5   17

Evaporation and
 incineration        48.8   11.7       6     31.0   62    17.5   35
                                      33     35.0   70
                                   27-37     24.0   48
                                   17-21     31.0   62

some of these processes that led to the regulatory division described in
Section I.A. and I.B.2.d.  Nevertheless, to illustrate the quantity and quality
of groundwood effluents, the background data must be employed.

Effluents from all of these processes contain suspended solids and dissolved
organic matter, both of which contribute to the BOD load (EPA, 1976a).   Chemi-
groundwood and cold soda process waters also contriubte electrolytes contain-
ing some ions of the residual and spent chemicals.

There is no discernible relationship between TSS effluent concentration and
the several groundwood processes.  One study (EPA, 1976a) found a TSS range
from 21 to 80 kg/kkg (42 to 161 Ib/ton).

The dissolved organic materials in groundwood effluents consist of wood sugars
and cellulose degradation products as well as resinous substances.  The BOD5
loads in the effluents of the various groundwood processes range as shown in
Table 18.  It is noted that the processes involving the use of chemical condi-
tioning agents show the higher BOD values.

The effluent flow from groundwood pulping is relatively low and can be expected
to range from 8.3 to 16.7 kl/kkg (2.0 to 4.0 kgal/ton).  However, the flow
from the groundwood papermaking operations is substantially higher.  This
relationship is illustrated in Figure 11.  The color is usually below 100
units.  New groundwood mills can be expected to replace traditional zinc
hypochlorite bleaching with another process to avoid high effluent concentra-
tions of zinc.

Limited data from two thermo-mechanical mills indicate, respectively:

     •   Flows of 86.7 (20.8) and 88.0 kg/kkg (21.1 kgal/ton)

     •   BOD5 at 19.8 (39.6) and 39.2 kg/kkg (78.4 Ib/ton)

     •   TSS at 49.2 (08.3) and 39.9 kg/kkg (79.8 Ib/ton)

No data were found on air pollution emissions from groundwood operations, and
there is less potential for this type of problem than in full chemical pulping.
Even in those processes where chemicals are used, they are not subjected to
the harsh heat and pressure conditions of chemical pulping.  Some volatile
organics may be expected, however.

Solid wastes from groundwood mills consist typically of bark (if barking is
performed on the premises), shives (small pieces of wood that will not grind
properly), screenings, ash, and waste paper.

II.A.7. Waste Paperboard Production

The raw waste load of waste paperboard mills is generated in the stock
preparation area and is mainly a function of the type of raw materials and
additives used.  In general, the higher the percentage of kraft or NSSC waste-
paper used in the furnish, the higher the BOD5 value per ton of product.
Mills whose wastes have the higher BOD5 values also generally include those
that employ an asphalt dispersion system in the stock preparation process in
order to melt and disperse the asphalt found in corrugated waste paper.


                       Table 18.   Range of BOD  loads
                    in effluents of groundwood processes
             Type of pulp




Cold soda

 4.0- 9.5




 8- 19

18- 32

69- 81

Source:  US Environmental Protection Agency.   1976a.   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 the pulp, paper, and paper-
         board mills point source category.  EPA 440/1-76/047-b, Dec.

                           PULP MILL
                                             3,000  GAL/TON
                                             36 LB TSS/TON
                          PAPER MILL
                                            21,000 GAL/TON
                                            92 LB  TSS/TON
                                                       24,000 GAL/TON
                                                      38  LB  BOD5/TO>
                                                       128  LB TSS/TON
                                                            6.1 pH
Source;  US Environmental Protection Agency.  1976a.  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 the pulp, paper, and paperboard mills point
         source category.   EPA 440/1-76/047-b, Dec.
                    Figure  11.  Effluent characteristics
               for groundwood  (coarse, molded, newsprint) mill

Compiled data on waste paperboard effluents indicate a flow range
from 14 to 100 kl/kkg (3 to 24 kgal/ton) for an average of 46 kl/kkg
(11 kgal/ton) (Bishop et al., 1968; Wisconsin State Department of Health,
1965; Michigan Water Resources Commission, undated), values that usually
reflect a high degree of water recycling.  If food board, which will be
adversely affected by accumulated taste and odor producing substances, is not
produced, the potential for reuse is greater and volumes should be smaller.
Effluent has been virtually eliminated at three waste paperboard mills because
the coarse grade of the products permits.

The data on waste paperboard mills also show a range of TSS losses from 4.0
to 61.5 kg/kkg (8 to 123 Ib/ton) for an average of 19.2 kg/kkg (38.4 Ib/ton).
BOD5 values ranged from 5.0 to 37.5 kg/kkg (10 to 75 Ib/ton).  Residual pulp-
ing liquor, starch, and other adhesives account for most of the BOD.  In a
later survey (EPA, 1974), the average BOD raw waste load was 11.2 kg/kkg
(22.5 Ib/ton), with a range of 4-20 kg/kkg (8-40 Ib/ton).

The wastepaper reclamation process has a unique solid waste generation problem
in that contaminants present in the wastepaper must be removed before new
paper and paperboard products can be manufactured from the available fiber.
The highly diversified contaminants were enumerated in Section I.D.3.  Some
of the heterogeneous materials removed will form a long continuous rope;
others, such as glass or  plastics, will break into small pieces.

The extent of contamination and the amount of cleaning required will vary
with each batch of wastepaper and with the specific end use.  For example,
mills using mixed wastepaper to produce lower grade products will generate
more solid waste than mills using high grade segregated wastepaper.

II.A.8.  Deinking

The major sources of effluent from the deinking process are the washers and
centricleaners; the remaining streams consist mainly of miscellaneous white
water overflows, floor drainage, washup, and cooling waters.  Clarified white
water from papermaking operations may supply a considerable part of the water
used for washing and cleaning.  The entire wastewater flow from a single stage
bleaching operation can also be used in deinking for dilution and preliminary
wash water.

The major polluting characteristics of deinking effluents are BOD5 and sus-
pended solids, both settleable and dispersed (Hodge and Morgan, 1947; NCASI,
1946).  Organics present include adhesives, products of hydrolysis, and fiber
lost in the process.  Inorganics derive from mineral fillers, ink pigments,.
and other materials separated from the fiber in wastepaper as well as
chemicals used in the process.  Included in the latter are dissolved electro-
lytes—mostly sodium salts—.and detergents, which add to the total solids and
foaming propensities of receiving waters.

BOD and TSS loads from deinking operations are in the neighborhood of 50 kg/kkg
(100 Ib/ton) and 150 kg/kkg (300 Ib/ton), respectively, on the basis of waste-
paper handled.

The relative contributions of the deinking process and the papermaking opera-
tion are shown in Figure 12.  The values in this diagram are not directly


                          11,000 GAL/TON
                          71 LB  BOD5/TON
                          180 LB TSS/TON
      9,000 GAL/TON
      4 LB  BOD5/TON
      80 LB TSS/TON
                                                      20,000 GAL/TON
                                                     75  LB BOD5/TON
                                                     260 LB TSS/TON
                                                          9.3 pH
Source:  US Environmental  Protection Agency.  1976a.  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 the pulp, paper, and paperboard
         mills point source category.
        Figure 12.   Effluent  characteristics for deink mill process

comparable with those values given in the preceding paragraph because they are
based upon thousands of kilograms (tons) of paper produced.

Because deinking also involves the use of wastepaper, trash such as that
described for waste paperboard will be generated to some extent.  The papers
are of much higher quality, however, and quantities should be smaller.  Some
solid wastes also accrue from the fillers and other solids separated from the
recycled paper.  The permit applicant should identify such wastes and suggest
appropriate measures to treat and/or dispose of them.

II.A.9.  Papermaking

The principal wastewater discharges from papermakirig  are as follows:

     •   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, discharge of tank dregs, and other non-
         equilibrium losses

     •   Cooling water discharges

     •   Boiler blowdown and other miscellaneous discharges

Data breakdowns on these individual discharges are not available because of
sewer interconnections and reuse complications.

Sources of BOD5 in papermaking wastewaters are the organic raw materials used
as the constituents of paper.  Cellulose is foremost, constituting 80% or more
of the weight of most papers.  Rosin sizings and starch or protein adhesives
also contribute to BOD5 loadings, as do many special organic chemicals such
as wet strength resins.  Some or all of these constituents,  including cellu-
lose 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 BOD5, but add to TSS loadings.

The combined papermaking effluents vary with the grade of paper produced.
Averages for nonintegrated paper mills, indicated by data developed during the
effluent guidelines study, are shown in Table 19.  There were insufficient
data on which to characterize the effluents of coarse paper mills, and there
is only one nonintegrated newsprint mill.


II.B.I.  Toxicity

Pulping effluents have historically been associated with fish kills downstream
of mills.  The substances in the raw pulping wastes to which these occurrences
were attributed include resin acids, fatty acids, other acidics, chlorinated
phenolics, and chloroform (Easty et al., 1978).


     Table 19.   Water quality values
for combined papermaking effluents by grade
              Flow	         BODs            TSS
Fine papers
kl/kkg kgal/ton
63.4 15.2
95.9 22.9
kg/kkg Ib/ton
10.75 21.5
11.5 22.9
kg/kkg Ib/ton
30.8 61.6
34.7 69.4

However, a Federal census of pollution-caused fish kills indicates that such
pulp mill related occurrences have become rare  (Pollution, 1960-68).  While
this can be attributed to several factors—such as more widespread use of and
improvements in spent liquor recovery systems and increased caution in avoid-
ing spills and leaks of potentially toxic materials—the greatest contributor
is biological treatment of effluents.  Efficiencies of up to 100% removal of
toxic compounds have been reported with good operating conditions and process
modifications (Mueller et al., 1977).

More recent EPA-sponsored research in this field indicates that advanced
waste treatment technologies can also accomplish good results in detoxifica-
tion of effluents (Easty et al., 1978).   Specific results of this study to be
considered by new source NPDES permit applicants include:

     •   Greater than 90% removal of fatty and resin acids was achieved
         by the treatment plants at 8 out of 13 mills.

     a   The levels of chlorinated fatty acids and resin acids reached
         detectable amounts (740 ppb) in the final effluents of only
         3 mills-

     •   Chloroform concentrations in treated effluents (8-75 ppb)
         compared favorably with levels reported in municipal drinking
         waters (3-152 ppb) .-

     •   Removal of fatty and resin acids greatly exceeded BOD removal
         in the lime precipitation system studied.

     •   Tertiary treatment by alum precipitation reduced fatty and
         resin acids and chlorinated fatty acids to below detection

     •   Reverse osmosis essentially completely rejected fatty and
         resin acids.

     •   The rejection by a pilot ultrafiltration system with a dynamic
         polymer was good, although such a unit with a synthetic polymer
         membrane was much less effective.

Other studies have demonstrated that the 96-hour LC^Q values of neutralized
bleached kraft effluents without further treatment commonly range from 15 to
50% v/v, and after biological treatment they are "essentially nontoxic"
(Warren, 1972).  Indications are that sulfite wastewater toxicity is similar
to that of kraft (Williams et al., undated; Wilson and Chappell, 1973), and
with a high degree of recycle, 96-hour LC5Q values in groundwood operations
can be reduced to as low as 1-2% v/v (Borton and Blosser, 1977).

After detoxification by effective biological treatment, pulp and paper
effluents will allow 50% or more survival of fish in a 96-hour exposure at
100% concentration, which is about 10-20 times what the no-stress level has
been determined to be (Mueller et al., 1977).  Because the removal of toxic
substances of the types identified above is proportional to BOD reduction,
this level of detoxification will be accomplished by the effluent NSPS BOD
removal requirements.  Still greater reduction can be achieved by final
effluent storage.


The high level of treatment embodied in the effluent NSPS is facilitated by
practices that hold the load of toxic substances reaching the treatment works
to reasonably low and constant levels.  These include diversion of washer and
evaporator sewers to storage during high liquor loss periods and careful con-
trol of turpentine decantation.  Because this type of control is not available
in the case of wet barking operations, bleach plants, and mechanical pulping,
treatment performance alone must meet the effluent NSPS.

A 20:1 receiving water dilution ratio, which with few exceptions is met or
exceeded by the streams receiving kraft mill effluents, will result in
maintenance of dissolved oxygen levels near saturation.

Any remaining potential for pulp and paper mill effluent toxicity, either
through system upset or the volume of discharge, is most important in the
waters inhabited by salmon and trout, because these species are the least
tolerant to the toxic constituents of pulp and paper mill wastes.  There is
abundant literature on the lethal and sublethal effects to these and other
members of the aquatic community (Mueller et al., 1977; Warren, 1971; Warren,
1972; William et al., undated; Wilson and Chappel, 1973).  Available data
show that concentrations of kraft effluent of 0.03-0.05 of the 96-hour LC5Q
are below the threshold considered deleterious, and that threshold concentra-
tions of various sublethal parameters are between 0.05 and 0.1 of the 96-hour
LC5Q (Warren, 1972).  Sublethal effects include poor growth, reduced swimming
speed, and a "general stress response" rather than a specific toxicological
effect within the fish (Borton and Blosser, 1977).

The results of the study of toxics in this industry sponsored by EPA's
Effluent Guidelines Division will determine what course of action applicants
must take to avoid toxicity occurrences.  As noted in Section I.C.4, technol-
ogy-oriented standards will be imposed by 30 September 1980 if warranted by
the study findings.

II.B.2.  Other Potential Adverse Impacts

II.B.2.a.  Air Pollution.  Generally, the most likely adverse impacts of air
pollution from pulp and paper mills can be characterized as follows (Stockman,

     •   Odor

     •   Visibility reduction

     •   Corrosion of metals

     •   Damage to painted surfaces

     •   Physiologic

     •   General dirtiness and soiling of surfaces

These factors vary from mill to mill and the degree to which they occur, if
at all, is dependent primarily on the process utilized and the degree of air
pollution abatement practiced.  Location and plant size may also be involved
as secondary functions.


The sulfur compounds associated with chemical pulp mills—SC>2 in all chemical
subcategories and TRS in kraft mills—and particulate matter represent the
greatest potential problems.  The group of TRS compounds, because of its
strong odor, is often identified as the most apparent pulp mill air pollutant
and the one of greatest concern to individuals.  The consensus of a national
advisory group to EPA was that TRS should be controlled, whether or not it is
linked to long term health effects, simply because it is a nuisance (Litton,
1969).  The effects of the presence of odor which have resulted in legal
redress for damages include loss of sleep, loss of appetite, nausea, and
reduced enjoyment of property (Copley, 1973).  It can be seen that these
nuisance factors may at some point also become inimical to amenity values and
economic interests.

Hydrogen sulfide (H2S), a compound of the TRS group, tarnishes silver and
copper, and darkens house paint containing lead, a situation which should not
occur in the future because of restrictions on lead based paint.  Ambient
levels of H2$ high enough to cause vegetative damage, eye or respiratory
irritation, systemic effects, or death are not anticipated (American Assn.,
1965; Goldsmith, 1962).

In contrast, sulfur dioxide has no discernible odor at the ambient concentra-
tions found in industrial communities.  However, since SC>2 damage to human
health, plants, livestock, materials (metals, building materials, fabric,
paper, and leather), can occur at relatively low levels, the national ambient
air quality standards have been set at levels which provide a margin of safety.

There is a synergistic effect between particulate matter and S02 and in
combination they may produce health effects greater than the sum of the effects
caused by these pollutants individually.  In addition, airborne SC>2 may
oxidize to sulfur trioxide which on contact with moisture in the atmosphere
converts to sulfuric acid.  This pollutant is potentially more damaging to
humans than SC-2 and may accelerate corrosion and deterioration of various
materials.  Sulfuric acid mists also scatter light to reduce visibility. This
phenomenon has been observed to increase with higher relative humidity.

The health effects of mixed particulate matter alone on the populations of
small communities are not well established.  However, low ambient concentra-
tions are desirable from the standpoint of economic and aesthetic benefits as
related to visibility, soiling, corrosion, and other adverse effects.  Again,
the particulate national ambient air quality standards are designed to provide
for these amenities.

Thus, the applicant should describe in his environmental information document the
measures to be taken to insure that neither the S02 or particulate standards
are exceeded in the environs of the mill.

The applicant is referred to two definitive documents on the effects of sul-
fur dioxide and particulates.  These are:

     •   Air Quality Criteria for Particulate Matter

     •   Air Quality Criteria for Sulfur Oxides

Both were published by the U.S. Public Health Service in 1969.


II.B.2.b.  Leachates.  There are no published studies on the specific effects
of leaching on groundwater from the land disposal of pulp and paper wastes.
However, there is a great body of literature on the use of treated and
untreated effluents for irrigation which indicates that the soil exerts a
purifying effect on the wastes.  During the years in which storage ponds have
been utilized for liquid wastes in areas of highly pervious soils, no adverse
incidents attributable to seepage have been reported, and one nonintegrated
paper mill in Pomona, California has utilized its effluents for direct ground-
water recharge.

However, it will be incumbent upon the applicant to demonstrate in the  EID
that leaching will be controlled and that no toxicity, tastes, odors, or other
undesirable characteristics will be introduced to groundwater from the mill's
land disposal facilities.


Although mill production operations may be regarded as a continuous sequential
balanced series of unit operations, in practice there is a discontinuity that
can create problems both in internal control and influences on external waste
treatment facilities.  The losses that occur when the production process is
not in equilibrium may account for one-third to one-half of the suspended
solids and BOD5 raw waste load in pulping operations, and from one-quarter to
one-half of paper mill losses.  These factors include:

     •   Spills

     •   Overflow

     •   Washup

     •   Breakdown of equipment

     •   Routine maintenance

     •   Planned shutdowns and start-ups

     •   Power failures

     •   Paper grade changes

Continuous monitoring, especially on conductivity, should be employed by the
applicant within mill sewers to give immediate warning of spills to facilitate
immediate remedial action.  Automatic diversion devices operated by the
conductivity measuring instruments may also be employed.  Mill personnel should
be trained to respond promptly with effective corrective measures in all cases.

Best practice also includes the use of storage facilities adequately sized to
avoid overflows in at least 90% of process upsets and during maintenance pro-
cedures such as evaporator "boil out."  Provision should be made to return
these stored materials to the originating subprocess at a later time.

If overflows would cause treatment plant upset or increased discharge of
pollutants, production ghould be curtailed as necessary if the overflows cannot


be prevented by some other means.  Sewer segregation can be used, especially
in new mills, to minimize these impacts, in conjunction with adequate storage.

Storage lagoons located before treatment may be provided to accept longer term
shock loads, the contents of which can then be  gradually returned to the pro-
cess or diverted to treatment without detriment to treatment operations.
Provision of storage lagoons also provides some period of time to correct
malfunction of external operations or offers temporary facilities for solids
sedimentation if properly designed to satisfy such uses.  Fresh water used to
cool bearings, variable speed couplings,  brake linings in paper rewind
applications, and similar areas throughout a mill can be collected and reused.
It is not contaminated and can be recycled either directly after heat removal
or indirectly by discharge into the fresh water system if heat buildup is
not a problem.

The impact of paper grade changes on wastewater quality may  be  mini-
mized by scheduling production so that one product is not immediately followed
by a completely"different one.  This practice also reduces the interim period
in which production meets the specification for neither product with a further
reduction in wastewater.

Some mills have extended the period between washups in recent years; these
periods, with foresight,  may be planned to coincide with felt or wire life
cycle and to permit changes of this equipment during scheduled shutdowns.

Nonequilibrium occurrences do not appear to have as significant an impact on
air pollution emissions,  with modern practice.  However, there may be some
incidental occurrences; the applicant, therefore, should estimate those
occurrences and discuss the specific abatement measures that are proposed to
mitigate potential adverse impacts.


II.D.I.  Raw Materials and Byproducts Handling

Many raw materials are prepared on the site by chemical reaction, and special
care should be taken to contain the byproducts of these materials.  Examples
of this type of operation are:

     •   The preparation of hydrogen or sodium peroxide for bleaching
         at groundwood mills

     •   Hypochlorites at kraft mills

     •   Sulfurous acid at sulfite mills

     •   Perhaps, in some new mills, oxygen for the new bleaching
         process using this element

Chlorine dioxide is always manufactured at the site because of the instability
of this compound.

Normally, the delivery of products from pulp and paper mills does not repre-
sent a signficant environmental impact vis-a-vis spills, ruptures, and so forth,


because most of the product is dry paper in one form or another.  There could
be exceptions; for example, the shipment of byproducts such as tall oil and
turpentine from kraft mills and concentrated liquor, lignosulfonates, ethanol,
furfural, and sulfuric acid from sulfite mills could pose a spill hazard.
Usually these materials have only a low or moderate toxicity rating, but spills
are not desirable aesthetically and the potential does exist for degradation
of water quality as a result of direct spillage or indirect contamination
through leaching.  Therefore the applicant should project the probability of
such accidents occurring and disclose any plans that are proposed to handle
these potential hazards.

One other mode of product delivery that must be handled with care to avoid
adverse effects is the shipment of groundwood pulp in a solution of sodium
silicate and hydrogen peroxide.  In this case, the tank car or truck acts as
the reaction vessel for bleaching.

II.D.2.  Site Preparation

The environmental effects of site preparation and construction of new pulp
and paper mills are common to land disturbing activities on construction sites
in general.  Erosion, dust, noise, vehicular traffic and emissions, and some
loss of wildlife habitats are to be expected and minimized through good con-
struction practices wherever possible.  At present, however, neither the
quantities of the various pollutants resulting from site preparation and
construction nor their effects on the integrity of aquatic and terrestrial
ecosystems have been studied sufficiently to permit broad generalizations.
Therefore, in addition to the impact assessment framework provided in the EPA
document, Environmental Impact Assessment Guidelines for Selected New Sources
Industries, the permit applicant-should tailor the conservation practices to
the site under consideration in order to account for and to protect certain
site specific features that warrant special consideration (e.g., critical
habitats, archaeological/historical sites, high quality streams, or other
sensitive areas on the site).  All mitigation/conservation measures that are
proposed should be discussed in the EID.

Additional guidance on pollution from construction sites is provided in Sec-
tion III.E.


The ability to forecast environmental impacts accurately often is improved by
the use of mathematical modeling of the dispersion and dissipation of air and
water pollutants as well as the effects of storm runoff.

Two of the most widely used and accepted models are:

     •   DOSAG (and its mofifications)

     •   The QUAL series of models developed by the Texas Water Develop-
         ment Board and modified by Water Resources Engineers, Inc.

Some of the parameters that these models simulate are:

     •   Dissolved oxygen

     •   BOD

     •   Temperature

     •   pH

     •   Solids

In addition, there are many available water quality models that were developed
in association with NPDES activity and the need for optimization of waste load
schemes for an entire river basin.

There are also available mathematical models that have been used for air
pollution sutdies and solid waste management optimization:

     •   For short-term dispersion modeling of point sources, EPA's
         PTMAX, PTDIS, and PTMTP models may be employed „

     •   For modeling of long-term concentrations over larger areas,
         the EPA Climatological Dispersion Model may be used for
         point and area sources

In general, the use of mathematical models is indicated when arithmetic cal-
culations are too repetitious or too complex.  Their use also simplifies
analysis of systems with intricate interaction of variables.  Models thus
offer a convenient way of describing the behavior of environmental systems.



Internal control measures are procedures to reduce pollutant discharges at
their origin, some of which result in the recovery of chemicals, fiber, and
byproducts and in conservation of heat and water.  Similar methods are
available to all subcategories and should be considered by the applicant as

     •   Effective pulp washing

     •   Chemical and fiber recovery

     •   Treatment and reuse of selected waste streams

     •   Collection of spills

     •   Prevention of accidental discharges

New processes to reduce pollutant loads are continually being developed.
Those currently available for incorporation in new mills are shown in Table
20.  There is, however, very little documentation on the magnitude of raw
waste reductions achieved through the use of a particular technology.  In
general, reductions in raw waste loads permit reductions in effluent flow
through recycle.

Although water recycle has been a major goal of the industry in recent years,
and great progress has been made, reuse is limited by several factors.
Impurities in water supply and raw materials can concentrate to the extent
that they cause corrosion or scaling.  Fines and dirt can also build up to
the point whjere product quality is affected.  As a result, a completely
closed system has been accomplished at only a few small mills—either because
coarse product quality permits or because of the relationship between product,
size, and water availability.

New mills are most capable of maximizing water reuse as the various integral
processes of the mills are designed.  The applicant should describe the
engineering concepts which will be utilized to decrease consumptive use of


The Federal Water Pollution.Control Act, as amended by the 1977 Clean Water
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.  The mills may elect to achieve
the required pollutant reduction with well-designed and -operated external
treatment systems or by a combination of both internal and external controls
that may prove to be more cost effective.

Table 20.  Internal control technologies used as applicable
                in pulp and/or paper mills
         and their effects on wastewater streams
Hot stock screening

Fourth stage brown stock washer
Decker filtrate for stock
  washer showers

Pulp mill spill collections

Jump stage countercurrent
  washing in bleaching

Evaporation boil-out tank

Liquor storage tank spill

Reuse of blow steam &
   evaporator condensate

Green liquor dregs filtering
High level alarms for chemical

Hot water collection and reuse

Paper machine saveall
Segregation of white water

Paper machine white water

Vacuum pump seal water reuse

Cooling water segregation and

Felt hair removal

Flow control of seal water
Avoid decker sewer losses

Improve liquor separation; reduce
  waste load

Reduce flow through reuse
Avoid shock load

Reduce flow through reuse; improve
  liquor recovery

Avoid shock load

Avoid shock load

Reduce flow
Improve separation; obtain cleaner

Avoid spills and shock load
Reduce flow

Reduce waste load through fiber

Maximize reuse and reduce fiber
  in waste

Reduce flow through reuse
Reduce flow

Reduce flow

Permit reuse of press water

Reduce gland water use

         Table 20.  Internal control technologies used as applicable
                         in pulp and/or paper mills
                  and their effects on wastewater streams (Continued)
Source:  US Environmental Protection Agency. 1976.  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 the pulp, paper, and paperboard mills
         point source subcategory.  EPA 440/1-76/047-b, Dec.

The internal controls vary to some degree among subcategories, but the external
treatment technologies employed by the pulp and paper industry are essentially
the same across the range of subcategories.  For this reason the discussion
that follows assumes the controls are applicable to all subcategories.

III.B.I.  Suspended Solids Reduction

The identified new source technology for suspended solids reduction for
the unbleached kraft, the sodium and ammonia base NSSC, the kraft NSSC with
cross recovery, and waste paperboard subcategories includes (EPA, 1974):

     •   An earthen sedimentation basin

     •   Mechanical clarification and sludge removal and/or dissolved
         air flotation

It is not anticipated that sedimentation basins will be used widely in new
mills because of large land requirements, inefficient performance, and high
cleaning costs.  The most common suspended solids removal technology and the
one likely to be employed by the greatest number of new mills is the mechanical
clarifier.  This device is usually a large circular tank of concrete with a
rotating sludge scraper mechanism mounted in the center.  It is capable of
95% reduction of the settleable suspended solids in the effluent, which
account, for example, for 85% of the total suspended solids in unbleached
kraft mills.  Since some of the settleable solids are biodegradable, clari-
fication results in some BOD reduction (EPA, 1974; 1976a).

Although dissolved air flotation has achieved up to 98% suspended solids
removal efficiency, this equipment is relatively costly and mechanically
complex and has a high power requirement.  Dissolved air flotation is used
extensively in save-alls, but it is not expected to be employed for full
effluent treatment except where space is at a premium (EPA, 1974; 1976a).

All clarification systems must be preceded by screening to remove bark or
trash materials that could seriously damage the equipment.

III.B.2.  BOD Reduction

The' new source technology for BOD removal consists of a biological oxidation
system with nutrient addition.  (Except for ammonia base NSSC and sulfite
mill wastes, pulp and paper mill wastes are almost devoid of phosphorus and
nitrogen, and the presence of one or the other, in appropriate quantity, is
necessary for biological treatment to function properly.)  The treatment
system may consist of the activated sludge process, aerated stabilization
basins,'and/or storage oxidation ponds.

The principal benefit gained from biological treatment is that the treated
effluents do not deplete the dissolved oxygen levels of receiving streams to
levels that would be inimical to aquatic life.  Other benefits include
reduction of toxicity, as noted earlier, reduction in foaming tendencies,
reduction of turbidity, and elimination of sliming tendencies.  Normally there
is also a slight reduction in color.

All types of biological treatment have advantages and disadvantages -related
to waste characteristics, waste volume, land availability, costs, and local-
ized factors.  The applicant should consider in further detail such charac-
teristics as the following:

Storage oxidation—large natural or man-made basins of various depths that
rely on natural reaeration from the atmosphere—can be expected to be used only
where large land areas of suitable topography and remoteness from dwellings
are available.  Its two principal advantages are that it is capalle of
handling accidental discharges of strong wastes without upset and has no
mechanical devices to generate maintenance problems.  Thus, efficient
continuous operation can be expected and, in addition to a reduction in BOD
of 85-90%, a significant reduction of suspended solids will be accomplished.

Aerated stabilization basins also achieve a high degree of BOD reduction,
with a significantly smaller land requirement than that of natural basins—
typically 0.21 ha/million liters (2 acres/264,200 gal.) as compared with 4.8
ha/million liters (40 acres/264,000 gal.).  Detention times in aerated
stabilization basins normally range from 5 to 15 days, averaging about 10
days.  Aeration is normally accomplished with gear-drive turbine type aerators,
direct-drive axial flow-pump aerators, or, in a few cases, diffused aerators.

The activated sludge process is similar to the aerated stabilization system
except that it is much faster, with total retention times ranging from 4 to
8 hours.  The biological mass grown in the aeration tank is settled in a
secondary clarifier and returned to the aeration tank, building up a large
concentration of active biological material.  This process is susceptible to
upset caused by shock loads, and it takes several days to return to normal
BOD removal rates.  It suffers several other disadvantages compared to the
aerated stabilization basin, but it requires even less land, and may be used
where the high cost or unavailability of land dictates.

III.B.3.  Color Removal

At present, color removal to enhance stream aesthetics is included in the
effluent NSPS treatment technologies only for unbleached kraft and NSSC/kraft
mills with cross recovery.  The NSPS for sodium base and ammonia base NSSC
mills do not include color limitations because the applicable treatment pro-
cess, reverse osmosis, has not been proven in NSSC mills (EPA, 1974).  It can
be expected that when NSPS are finally established for the remaining sub-
categories, color removal also will be required for bleached kraft mills and
perhaps sulfite operations.

The minimum lime treatment is recommended for color removal in unbleached
kraft mills and has achieved efficiencies of over 80% (David, 1971).

III.B.4.  Pretreatment

Only minimal pretreatment is required before the effluents of paper mills can
be discharged to municipal wastewater treatment plants.  The external pre-
treatment currently practiced is generally limited to suspended solids removal
and equalization.  In addition, in waste paperboard, tissue, reclaimed
newsprint, and fine paper mills, a high degree of internal fiber recovery is

required as a form of pretreatment before discharge to a municipal system,
along with means for controlling spills and handling wash-ups.  The applicant
can achieve, as applicable, this level of pretreatment through the use of
filtration, flotation, and sedimentation devices incorporated in the manufac-
turing process.

Only 5 pulp mills in the country discharge to municipal sewers, and in
these instances the treatment plants were designed to treat the combined waste
flow.  Increased use of public facilities for treating chemical pulp mill
wastes is doubtful, both because of the costs involved under the terms of
Public Law 92-500 and because most or all of them will have biological treat-


III.C.I.   Kraft Mill Odors

The technologies available to the applicant for reducing TRS emissions from
the following sources are:

     •   Digester and Evaporators:  Collection and thermal oxidation of
         the noncondensable gases, either in the lime kiln, special
         incinerators, or recovery boilers.

     •   Recovery Furnace:  Black liquor oxidation and substitution of
         contact evaporators with concentrators and recycle of stack
         gas into the secondary air supply of the furnace.  Improvements
         in furnace design and operation have also been incorporated
         at some mills.

     •   Lime Kiln:  Maintenance of proper process conditions 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 (Eddinger et al., 1974).
         Scrubbing the off-gases with a caustic solution increases the
         effectiveness of hydrogen sulfide and methyl mercaptan removal.
         Efforts are underway to minimize sulfide in the incoming mud
         by oxidizing it on the vacuum filter (Caron, 1977a).  In
         practice, this procedure reduced the TRS in the kiln discharge
         to less than 10% (Wilhelmsen, 1977).

     •   Smelt Dissolving Tank:  Modification of process conditions such
         as use of water low in sulfides.  This tank is a minor source of
         TRS emissions.

     •   Black Liquor Oxidation:  Collection and thermal oxidation of

     •   Brown Stock Washer:  Collection and thermal oxidation in
         recovery furnace or special incinerator, or, in some cases,
         the lime kiln.

     a   Condensate Stripping:  Collection and thermal oxidation in the
         lime kiln, recovery boilers, or special incinerators.

Recent studies on the ability of chlorine to oxidize TRS compounds and thus
reduce the most objectionable fraction of the kraft odor have been encouraging.
For this approach to be feasible for new mills, complete oxidation at practical
concentrations will be required.

Applicants seeking NPDES permits for new mills will also have an opportunity
to incorporate improved methods for handling the numerous small sources of
odor that  are not available to existing mills (Fisher, 1977).  Applicants
also should take advantage of improved monitoring methods (NCASI, 1975) and
studies on odor perception (NCASI, 1970; 1971).

III.C.2.  Sulfur Dioxide

Although S02 emissions may occur at all types of chemical pulp mills that use
sulfur compounds in their cooking liquors, an EPA study of kraft mill SC>2
emissions found that recovery furnaces and lime kilns in these mills are not
significant sources of S02-  EPA tests on 2 recovery furnaces and 3 lime kilns
indicated SC>2 emission levels of about 3.9 Ib/ton ADP (70 ppm) and 0.3 Ib/ton
ADP (30 ppm) respectively (EPA, 1976b).    Sulfidity of the cooking liquor has
been identified as the major factor in determining stack losses of S02 from
the recovery boilers, and the stack concentration can be kept below 100 ppm
if this value does not exceed 31% (Gansler, 1977).  It has also been shown
that S02 stack concentration is affected by, in descending order, excess
oxygen, total air flow, boiler load, and air distribution to the furnace.

Similarly, S02 losses can be minimized at NSSC mills by maintaining a proper
ratio of sodium to sulfur in the liquor.  Ammonia base systems recover S0£
in a manner similar to that used by acid sulfite mills, described below, and
the levels discharged by fluidized bed furnaces is low because of its reaction
with soda in the smelt (Collins, 1969; Galeano et al., 1971).

Methods are also available and in effect at most sulfite mills, which are
greater sources of this pollutant, for recovering S02  from the digester blow
and relief gases.  The gases are generally absorbed in a packed tower, and
the recovered 862 is reused in the process.  This system is about 75%
effective in absorbing S02 from,the blow pit stacks.

Abatement devices are also applied to the collected S02 emissions from more
minor sources such as the evaporators and washer heads (Caron, 1976b).  In
addition to packed towers, these include venturi scrubbers, turbulent contact
absorbers, and spray contact devices (Johnson and Gamsler, 1971; NCASI, 1973;
Rosenburg et al., 1975).  Recoveries as high as 97% have been reported, and
S02 emissions are reduced to acceptable levels.

S02 emissions from power boilers are a function of the sulfur content of the
fuel burned, and the use of low-sulfur fuels is the only means currently
available for minimizing these emissions from boilers of the size range used
by pulp and paper mills.   Mills required to use coal under the Energy Supply
and Environmental Coordination Act of 1974 (P.L.  93-319) instead of oil or
natural gas may be granted compliance date extensions if certain conditions
are met (40 CFR, Part 55).   The applicant should determine the sulfur content


of coals available to him and calculate the S02 emissions which would result
from their combustion.

III.C.3.  Miscellaneous Odor Problems

While odor control in external effluent treatment systems is not subject to
Federal new source performance standards, ambient odor from any source  is
subject to state and local regulation.  Thus, new source NPDES applicants
should demonstrate in their EIA's the measures to be utilized which will
effectively control odor from this source.

Abatement procedures begin with loss control in the mill.  This is especially
necessary in kraft mills to minimize the quantity of TRS compounds reaching
the treatment plant.

Good loss control is a function of a number of factors which should be con-
sidered by the applicant.  They include (EPA, 1976a):

     •   Process operational control practices such as the brown stock
         washing process

     •   Spill and leak control

     •   Process design efficiency—for example, no direct sewering of
         evaporator condensate and blow tank gases

     •   Production vs. design rate

     •   Practical efficiency limitations of the kraft process itself

Treatment plant odor generated because the mill does not recover turpentine
or because some crude turpentine escapes from the byproducts recovery process
to an aerated stabilization basin  may be controlled by initiating turpentine
recovery in the first instance or improving turpentine capture in the second.

Odor control in the treatment system itself relies largely on good system
design, operation, and maintenance.  However, if localized treatment system
odor which impacts the public cannot be alleviated by improved operation and
maintenance practices, specific control measures may be needed.

This situation is not, however, a broad general problem in this industry and
there is no general solution.  Measures which the applicant can consider

     •   Roofed concrete tanks, vented in one place, and oxidized with

     •   Ozonation of wastewater

Both technologies have been researched by EPA, and the current status of the
Agency's findings should be ascertained.  Ozone application as it applies to
municipal sewage treatment is covered in the publication Design Manual for
Small Wastewater Treatment Plants  (1976).  Other technologies which might be
investigated are discussed in EPA's publication Direct Environmental Factors
at Municipal Wastewater Treatment Works (1976).


If odor results from chlorine losses from bleach plant reaction towers, the
problems can be reduced to a large extent by the use of a scrubber in the
exhaust stack of the tower designed to remove over 95% of the gas (Morrison,
1968).  The scrubber water or alkali, as the case may be, can be employed in
the manufacture of hypochlorite for use in the bleachery.  In addition, some
reduction may be achieved by process control.

On occasion, odors caused by cellulose decomposition products, decaying size
materials, and sulfides from sulfate reduction are a source of air pollution
proximate to pulp and paper mills.  In general, these problems, which derive
from storage oxidation basins and sludge impoundments, are readily control-
lable.  In the case of oxidation basins, limited aeration can be added to
prevent localized anaerobic conditions.  In the case of sludge storage basins,
several control methods can be employed including dewatering of the sludge
before storage, pH control, and the addition of masking agents.  The dewater-
ing process has  proven to be by far the most effective odor control measure.

III.C.4.  Particulate Control

The three process areas where particulate control will be required in kraft
mills are the recovery furnace, the smelt dissolving tanks, and the lime kiln.
The technologies available to the applicant for meeting the NSPS are:

     •   Recovery Furnace:  Electrostatic precipitators and direct
         contact evaporators.  Although the purpose of the evaporator
         is to concentrate black liquor, it may also scrub particulate
         matter from the gas stream (EPA, 1976b).  Where cyclones or
         Venturis are used as direct contact evaporators, the black
         liquor serves as the particulate scrubbing liquor.  If two
         highly efficient Venturis are used in this manner, a pre-
         cipitator may not be necessary.

     •   Smelt Dissolving Tanks:  Scrubbers of several types, ranging
         from the low energy demister pads  (fine wire mesh screens)
         to low pressure drop Venturis, packed towers, and cyclones
         with water sprays.  The tank gases can also be combined with
         the recovery furnace gases and sent to the electrostatic
     •   Lime Kiln:  Usually venturi scrubbers with pressure drops
         ranging from 25 to 62.5 cm  (10 to  25 in.) of water.  Impinge-
         ment scrubbers are used less frequently.

Particulate emissions from power boilers may be controlled by the use of:

     •   Cyclone collectors

     •   Scrubbers

     •   Electrostatic precipitators


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 meets it particular needs and local conditions.  This system
should be described in detail in theEID.

The major solid waste problems are substantially 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 the inorganics and thus they require larger disposal areas.

III.D.I.  Sludge Handling and Disposal

Major efforts have been made to reduce sludge volume by reducing its 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 applica-
tion on agricultural land (Aspitarte et al., 1973; Wyson, 1976; Marshall and
Miner, 1976). Neither of these applications for disposal is yet in widespread
use, however, and land disposal remains the dominant method.

Despite the years of study and pilot plant work, the dewatering and disposal
of sludges resulting from the treatment of pulp and papermaking wastewaters
remains a major industry problem.  Today's requirement for secondary treat-
ment has resulted in the production of great quantities of gelatinous activated
sludge that is very difficult to dewater and dispose,  of.  The emphasis on
reuse has also compounded the problem in that far more fibers are captured
than in the past and now end up in the sludge.  However, primary sludges
rich in fiber are relatively easy to dewater.

A variety of thickening or dewatering processes are available and their
relative suitability for use at the posposed mill should be investigated.
They include (Gehm, 1973; 1976):

     •   Gravity thickening

     •   Mechanical thickening

     •   Flotation

     •   Vacuum filters

     •   Centrifuges

     •   Belt filters

     •   Presses

Although pulp and paper mill sludge can be thickened in the primary clarifier,
it is often withdrawn and thickened in a gravity thickener.  Either the conical
tank or "picket fence" type of thickener is employed, with the latter in more


common use today.  The rotation of a rake mechanism with a series of vertical
vanes accelerates the separation of the solids from the water.

Dissolved air flotation units have been used to separate pulp fines and fillers
from paper mill white waters.  Recently flotation has also been used to
thicken the thin, slimy sludges, such as activated and hydrous tissue mill

Continuous rotary vacuum filters are widely 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.
There has also been some use of heat conditioning and partial wet air
oxidation of sludges to improve dewatering.

Both disc and solid bowl centrifuges have been successfully applied to pulp
and paper industry sludges.  In most cases, sludge conditioning is necessary
to get appreciable increases in solids and satisfactory capture of solids.
Sand and grit not properly removed in earlier processing can be very trouble-
some, particularly in the solid bowl scrolls.

Several manufacturers have available belt-type filters that use a combination
of gravity and compression to remove water from sludges.  There has been a
revival in the use of filter pressing based on improved design of cloth and
closure plus the application of automation to reduce operating cost.

Sludge from smaller mills can be chemically stabilized to reduce odor.  Larger
new mills should provide for dewatering the sludge and returning the drainage
from the disposal areas to the treatment system for BOD removal.  Alternatively,
good landfill practices will be required to control odor.

III.D.2.  Disposal of Wood and Other Organic Wastes

Wood wastes and other organic waste materials are also disposed of on land.
Disposal of such wastes should be in accord with modern management techniques
as described in the EPA publication  janitary Landfill Design and Operation
(Brunner, 1971) and methodologies for reclaiming disposal sites (Gorham, 1974;
NCASI, 1977).  Wood waste deposits, particularly those containing a large
quantity of bark, produce a leachate containing considerable color.  It is
anticipated that either effluent]limitations on color or State regulations
under RCRA will require that the leachate be impounded and treated to remove
the color or that impervious containment areas be constructed.

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.  Standard landfills
appear to be an acceptable method for the dipsosal of waste paper and organic
trash material removed from it.

III.D.3.  Disposal of Inorganic Wastes

Leachate from land disposal of the inorganic portion of pulp and paper mill
solid wastes—deinking and decoating wastes, chemical recovery wastes (inert

grits and dregs), and coal and bark ash—usually does not present a problem
and can be combined with the mill's liquid waste stream before final treat-
ment or discharge  (Andersland and Laza, 1972).  New land disposal regulations
may require containment as an alternative and, therefore, the status and
applicability of such regulations should be determined by the permit applicant.

With the current emphasis on coal as a mandated fuel, the quantity of fly
ash requiring disposal will increase.  This may result in increased use of
spent cooking liquor as a fuel to avoid a vast ash disposal problem.

Methods are being developed for the recovery of deinking and decoating wastes
such as filler materials (S.D. Warren Company, 1972; Springer, 1976).  The
trash separated from waste paper in deinking, decoating, and waste paperboard
mills may include some inorganic material such as metal wire  which requires
standard landfill methods only.


The major pollutant at a construction site is loosened soil that finds its
way into the adjacent water bodies and becomes "sediment."  This potential
problem of erosion and sedimentation is not unique to pulp or paper mill
construction, but applies widely to all major land disturbing activities.
Common remedial measures include, but are not limited to, proper planning at
all stages of development and application of modern control technology to
minimize the production of huge loads of sediment.  Specific control measures

     •   The use of paved channels or pipelines to prevent surface

     •   Staging or phasing of clearing, grubbing, and excavation
         activities to avoid high rainfall periods

     •   The use of storage ponds to serve as sediment traps, where
         the overflow may be carefully controlled

     •   The use of mulch or seeding immediately following disturbance

If the applicant chooses to establish temporary or permanent ground cover,
grasses normally are more valuable than shrubs or trees because of their
extensive root systems that entrap soil.  Grasses may be seeded by sodding,
plugging, or sprigging.  During early growth, grasses should be supplemented
with mulches of wood chips, straw, and jute mats.  Wood fiber mulch has also
been used as an antierosion technique.  The mulch, prepared commercially from
waste wood products, is applied with water in a hydroseeder.

The extent of control technologies used will be determined, in part, by the
quantity of soil removed because there is a range in unit cost per acre.
The acreage involved from mill to mill will vary to some degree with capacity,
although limited data indicate an economy of scale in that acreage required to
accommodate larger mills does not increase commensurately  with increased
capacity (Table 21).  Products are not a significant factor in acreage.

                  Table 21.   Typical acreage used for three
                    subcategories of pulp and paper mills
                   Plant          Main mill      Waste treat-
                 capacity      	area	    ment basins   	Total	
Product	kkg/d   Tons/d  Hectares Acres  Hectares Acres  Hectares Acres

 mechanical     272      300     16.2    40     *        *      16.2     40

 kraft        1,088    1,200     32.4    80    64.8     160     97.2    240

 kraft        1,814    2,000     36.4    90    36.4      90     72.8    180
*Activated sludge included.


In addition to applying the best available technology to abate and control
adverse environmental impacts from air emissions, wastewater streams, and
land disposal of wastes, an NPDES permit applicant will be required to
demonstrate compliance with applicable pollution control regulations.  The
NPDES permit itself may require monitoring, recording, and recordkeeping on
flow and all pollutants that are subject to reduction or elimination under
the terms and conditions of the permit, as well as any other pollutant as
required by the State or EPA.  Monitoring intervals must be sufficiently
frequent to yield data that reasonably characterize the nature of the discharge.
These requirements are set forth in 40 CFR, Part 125.27.

The NSPS for the TRS and particulate emissions of kraft mills (Federal Register,
23 February 1978) also require testing, monitoring, and recordkeeping and set
forth required methods for measuring these two pollutants.  Similarly, moni-
toring of leachate, runoff, and air emissions will be required under the
Federal RCRA on sites where wastes determined to be hazardous are landfilled.
In addition, it is not inconceivable that some type of monitoring may be
required for some, if not all, disposal sites for nonhazardous wastes to
ensure that "there is no reasonable probability of adverse effects on health
or the environment" (Section 4004(a), RCRA).



The physical features of mills themselves that will impact the surroundings
are discussed in Section I.  Exterior design will be determined largely by
the processes—and thus the specific equipment—employed.  Digesters and
recovery furnaces require height and paper machines require breadth.  Capacity
is another design feature that will influence overall size.

New roads to the mill and/or railroad sidings and loading/unloading facilities
are also factors in new mill planning.  The magnitude and significance of
truck and equipment noise and emissions as well as other mobile emission
sources (vehicles of employees) must be assessed in the BID.

Locating mills and attendant facilities out of the view of major roads is a
primary consideration in any area, but the selection of other mitigating
locations is necessarily area specific.  It will be necessary for mill planners
to consider minimizing landscape disruption along with such factors as
convenience to raw material supply, markets, and water.

The intrusive nature 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 where such equipment is used (Hewson et al, 1973).
These opaque plumes are not harmful but can be seen for some distance.

In addition, ground visibility can be affected by the plumes, although such
occurrences are infrequent.  A local predisposition to fog formation makes
this effect more likely and increases importance of plumes.

Stack height, location, and configuration can influence the dispersion of
such plumes (ASME, 1968; Stockman, 1971).  The most serious uncertainty in
predicting plume behavior, however, appears to be the influence of the
aerodynamic downwash in the lee  of a plant building.  Computer models to
predict downwash are not available.  Interference with visibility at the
proposed mill can be alleviated, however, by giving careful attention to the
relationship of .prevailing winds, the mill site, and major roads, as well as
by constructing and locating cooling towers in accord with established
principles (Stockman, 1971).


Although considerably more attention has been given to internal noise at pulp
and paper mills, external noise also may be determined to be significant
(Gellman, 1974).  The following are the more common external sources of
noise (Phelps and Schuler, 1970):

     •   Log-barking drums

     ••   Chipper s
     •   Conveyors and log-handling equipment

     •   Fans and blowers
     m   Converting machinery
     •   Transportation equipment


In the case of most pulp mills, the major source of noise is wood preparation,
and this activity is frequently remote from habitation because of the size of
the site.  Sound measurements of similar activities at other sites can be used
in conjunction with standard noise diminution tables to determine local effect.
In addition, a survey of the effect of vegetation buffer strips in mitigating
noise levels will be helpful in planning a new mill.

Noise criteria for various areas have been suggested (Burgess-Manning, 1967),
and indicate that in heavy industrial areas pulp and paper mills will not
usually generate many serious ambient noise problems off the mill site,
especially when the community noise levels are in the common 50 dB range.
Perhaps the greatest noise contributions made by pulp and paper operations
are indirect, emanating from truck and rail transportation in the vicinity
of municipalities.

Although means exist to reduce the noise of particular sources, they are, in
most cases quite costly.  However, noise levels of equipment maintained in
good operating condition are usually considerably lower than if the equipment
is neglected.


Wood wastes in the form of bark and hog fuel with spent cooking liquors provide
over 61% of the fuel requirement of the pulp and paper industry; the liquors
account for 49.2% of the Btu employed.  The relative amounts of coal, oil, and
natural gas are in the process of change as mills switch from the use of oil
to coal as mandated by the Federal government.  A small amount of propane is
also used, together with some water power and a substantial quantity of
purchased power (Duke, 1974).

In addition, because of the impending energy shortage, as well as rising costs,
the industry has been  increasing the use of bark as fuel and the individual
mills have carried on a vigorous campaign for conserving energy (Urbas et al.,
1977).  The use of community solid wastes to supplement bark as fuel is also
being explored at two mills.  In one instance, a mill and a power station are
being linked in the use of municipal wastes, bark, and other mill wastes as
supplemental fuel.  In fact, all available organic residues are being examined
by the industry as possible fuel sources to supplement the present ones.

The energy requirements for common pulp and papermaking processes are shown
in Table 22.  The table illustrates that the steam requirements of chemical
pulping and papermaking are similar and that those of ancillary processes are
considerably less.  The mechanical pulping processes are all high consumers
of energy.

A daily Btu requirement of 240 x 10° was necessary to reach the 1977 level of
control of air and water pollution and 390 x  10  will be needed to reachIthe
1983 level  (Blosser, 1977; Roy F. Weston, Inc.,  1977).  The energy require-
ments to meet the 1977 control level are about equally divided between water
and air and over 60% of the total 1983 requirement is needed for water pollu-
tion, or about double that of the 1977 demand.   This substantial increase can
be accounted for largely by the addition of color reduction and effluent  fil-
tration.  The figures presented include both  separate and process-related
control techniques.


        Table 22.   Energy requirements for pulp and
                   papermaking operations
	Use	Process steam

Steam  (million Btu/adt):
    Paper drying (to 7% moisture)                   3.4
    Sizing                                          0.8
    Stack heating per 10° above 135°                0.8
    Batch pulping                                   3.5
    Continuous pulping                              2.5
    Evaporators                                     2.2
    Bleaching                                       1.3

Electrical power (kW/ton/ad):
    Woodroom and chipping                           110
    Digester                                        140
    Bleach plant                                    175
    Groundwood ADT                                1,400
    Pulp drying                                     450
 Source:   Blosser,  R.O.  1977.  Environmental protection
          engery use  in  the  pulp and paper industry.
          TAPPI, 60,  8.

In planning a new mill, all sources of energy available at a given site must
be considered, and their potential impact on the environment must be carefully
determined.  The need for meteorological studies to aid in this assessment
and the need to investigate such factors as stack height and vapor control are


The introduction of a large new pulp and/or paper mill into a community will
cause economic and social changes.  Therefore, it is necessary for an appli-
cant to understand the types of impacts or changes that may occur so that
they can be evaluated adequately.  The importance of these changes usually,
but not always, depends on the nature of the area where the mill is located
(e.g., size of existing community).  Normally, however, the significance of
the changes caused by a mill of a given size will be greater in a small,
rural community than in a large, urban area.  This is primarily because a
small, rural community is 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 a large urban area.  There
are situations, however, in which the changes in a small community may not be
significant and, conversely, in which they may be considerable in an urban
area.  For example, a small community may have had a manufacturing (or natural
resource) economic base that has declined.  As a result, such a community may
have a high incidence of unemployment in a skilled labor force and a surplus
of housing.  Conversely, a rapidly growing urban area may be severely strained
if a new pulp mill is located therein.

The rate at which the changes occur (regardless of^Etie circumstances) also is
often an important determinant of the significance of the changes.  The
applicant should distinguish clearly between those changes occasioned by the
construction of the mill, and those resulting from its operation.  The former
changes could be substantial but usually are temporary; the latter may or
may not be substantial, but normally are more permanent in nature.  The changes
which should be evaluated include:

     •   Increased sedimentation during construction

     •   Higher Runoff rate from developed land

     •   Increased emissions from space heating and vehicular traffic

     •   Loss of agricultural land and terrestrial habitat

     •   Higher noise levels

     •   Increased demand for water supply

     •   Increased sewage and solid waste production

During the construction phase, the impact will be greater if the project
requires large numbers of construction workers to be brought in from outside
the community than if local, unemployed workers are available.  The impacts
are well known and include:

     •   Creation of social tension

     •   Demand for increased housing, police and fire protection,
         public utilities, medical facilities, recreation facilities,
         and other public services

     •   Strained economic budget in the community-where existing
         infrastructure becomes inadequate

Various methods of reducing the strain on the budget of the local community
during the construction phase should be explored.  For example, the company
itself may build the housing and recreation facilities and provide the
utility services and medical facilities for its imported construction force.
Or the company may- prepay taxes, and the community may agree to a correspond-
ing reduction in the property taxes paid later.  Alternatively, the community
may float a bond issue, taking advantage of its tax-exempt status, and the
company may agree to reimburse the community as payments of principal and
interest become due.

During mill operation, the more extreme adverse changes of the construction
phase are likely to disappear.  Longer run changes may be profound, but less
extreme, because they evolve over a longer period of time and may be both
beneficial and adverse.

The permit applicant should document fully in the EID the range of potential
impacts that are expected and demonstrate how possible adverse changes will
be handled.  For example, an increased tax base generally is regarded as a
positive impact.  The revenue from it usually is adequate to support the
additional infrastructure required as the operating employees  and their
families move into the community.

The spending and respending of the earnings of these employees has a multi-
plier effect on the local economy, as do the interindustry linkages created
by the mill.  The linkages may be backward and forward.  Backward linkages
are those in the mill's suppliers.  Logging, hauling, and outfitting logging
and hauling operations are the more important linkages here.  Forward
linkages are those to the mill's markets.  The distant markets include those
demanding paper and those demanding pulp for a variety of uses, including
clothing.  The local markets include those that may use lumber cut but not
wanted by the mill, such as small sawmills, and those that may use the chips.
In extreme cases, the size of the mill may be so great as to induce logging
operations on a scale sufficient to justify the search for a market for
timber.  Finally, an assured local market for timber may lead  to an improve-
ment in  forest practices.

Socially, the community may benefit as the increased tax base permits the
provision of more diverse and higher quality services, and the variety of its
interests increases with growth in population.  Contrastingly, the transfor-
mation of a small, quiet, community into a larger, busier,  community may be
regarded as an adverse change by some of the residents, who chose to live in
the community, as well as by those who grew up there and stayed, because of
its amenities.

The applicant also should consider the economic repercussions if, for example,
the quality of the air and water declines as a result of various waste streams
from the mill.  In some cases, other, more traditional sections of economic
activity may decline as a consequence, or because labor is drawn away from
them into higher paying mill-related or tertiary sector activities.  As an
illustration, the fishing sector may decline if water pollution increases, or
if fishermen abandon the occupation in favor of mill-related activities.
Again, the tourist sector may decline if air and water pollution is noticeable
or if logging is practiced on such a scale that the landscape is degraded.

In brief, the applicant's framework for analyzing the socioeconomic impacts
of the location of a pulp and/or paper mill must be comprehensive.  Most of
the changes described can be measured, and should be measured to assess fully
the potential costs and benefits.  The applicant should distinguish clearly
between the short-term (construction) and long-term (operation) changes,
although some changes may be common to both (e.g., the provision of infra-
structure) because the significance of the changes depends not only on their
absolute magnitude, but on the rate at which they occur.

The applicant should develop and maintain close coordination with State,
regional, and local planning and zoning authorities to ensure full understand-
ing of all existing and/or proposed land use plans and other related regu-
lations .



As with all industries, the pulp and paper industry locates mills on the
basis of market demand for specific paper products, convenience to raw
materials, an adequate labor force and water supply, proximity to energy
supplies and transportation, minimization of environmental problems, and
other factors.  A variety of sites should be considered initially and,
following a detailed analysis of each one, a preferred alternative should be
selected that appears to satisfy the objectives and that is expected to
result in the least adverse environmental impact.

The factors considered in selecting each site, and especially those that
influenced a positive or negative decision on its suitability, should be
carefully documented in the permit applicant's EID.  Adequate information on
the feasibile alternatives to the proposed site is a necessary consideration
in issuing, conditioning, or denial of an NPDES permit (see 40 CFR, Part 6.924)

Specifically,the advantages and disadvantages of each alternative site must
be catalogued with due regard to preserving natural features such as wetlands
and other sensitive ecosystems and to minimizing significant adverse
environmental impacts.  The applicant should ascertain that all impacts are
evaluated as to their significance, magnitude, frequency of occurrence,
cumulative effects, reversibility, secondary or induced effects, and duration.
Accidents or spills of hazardous or toxic substances vis-a-vis site location
should be addressed.

When a proposed site is controversial, it may have to be abandoned for a
number of reasons.  Such opposition may derive from the fact that the proposed
mill would significantly impact a unique, recreational, archaeological, or
other important natural or man-made resource area.  It may destroy the rural
or pristine character of an area.  It may conflict with the planned develop-
ment for the area.  The site may be opposed by citizen groups.  It may have
to be discarded for meteorological and climatological reasons.  It may be
subject to periodic flooding, hurricanes, earthquake, or other natural

If the proposed site location proves undesirable, then alternative sites from
among those originally considered should be reevaluated, or new sites should
be identified and evaluated.  Expansion at an existing mill site also could
be a possible alternative solution.  Therefore, it is critical that a permit
applicant systematically identify and assess all feasible alternative site
locations as early in the planning process as possible.


Typically, when the decision is made to expand manufacturing capacity—either
through a new mill or an addition to an existing one—the type of facility to
be constructed is already fixed; that is, the demand for any given product
which initiated the decision would have dictated the type of process to be
used.  While the limitation on prdcess alternatives is not as severe as it
once was because of improved process versatility, it is still improbable, for
example, that a sulfite mill would be substituted for a kraft mill or a kraft


mill for a groundwood mill.  The kraft process can be used to make almost any
product, but groundwood is still preeminent in newsprint, as is sulfite for
some very fine paper grades.  In addition to demand, the process alternative
should be selected on the basis of availability of required raw material as
well as environmental considerations.  The applicant should present clearly
and systematically in the BID the methodology used to identify, evaluate, and
select the preferred process alternative.


In all proposals for facilities developed, the applicant must consider and
evaluate the alternative of not constructing the proposed new source facility.
Because this analysis is not unique to the development of pulp and/or paper
mills, no specific guidance is provided as part of this appendix.  The permit
applicant is, therefore, referred to Chapter IV (Alternatives to the Proposed
New Source) in the EPA document, Environmental Impact Assessment Guidelines
for Selected New Sources Industries, which was published in October 1975.


The applicant should be aware that there may be a number of regulations other
than pollution control regulations that have some application to the siting
and operation of new pulp and paper mills.  The applicant should coordinate
with the appropriate EPA Regional Administrator regarding applicability of
such regulations to the proposed new source.  Federal statutes which generated
regulations that may be pertinent to a proposed facility are:

     Coastal Zone Management Act of 1972

     The Fish and Wildlife Coordination Act

     The National Environmental Policy Act of 1969

     USDA Agriculture Conservation Service Watershed Memorandum 198 (1971)

     Wild and Scenic Rivers Act of 1969

     The Flood Control Act of 1944

     Federal-Aid Highway Act, as amended  (1970)

     The Wilderness Act (1964)

     Endangered Species Preservation Act, as amended (1973)

     The National Historical Preservation Act of 1974

     Executive Order 11593

     Archaeological and Historic Preservation Act of 1974

     Procedures of the Council on Historic Preservation (1973)

     Occupational Safety and Health Act of 1970

In connection with these regulations, the applicant should place particular
emphasis on obtaining the services of a recognized archaeologist to determine
the possibilities of disturbing an archaeological site, such as an early
Indian settlement or a prehistoric site.  The National Register of Historic
Places also should be consulted for historic sites such as battlefields. The
applicant should consult the appropriate wildlife agency (State and Federal)
to ascertain that the natural habitat of a threatened or endangered species
will not be adversely affected.

From a health and safety standpoint all complex industrial operations involve
a variety of potential hazards, and to the extent that these hazards could
affect the health of plant employees, they may be characterized as potential
environmental impacts.  These hazards exist in pulp and paper mills because
of the very nature of the operation—for example, the use of chemicals under
conditions of high temperatures and pressures—and all mill owners should
emphasize "that no phase of operation or administration is of greater importance
than safety and accident prevention.  Company policy should provide and


maintain safe and healthful conditions for its employees and establish
operating practices that will result in safe working conditions and efficient

The mill must be designed and operated in compliance with the standards of
the U.S. Department of Labor, the Occupational Safety and Health Administra-
tion, and the appropriate State statutes relative to industrial safety.  The
applicant also should coordinate closely with local or regional planning and
zoning commissions to determine possible building or land use limitations.


Advances in alakline pulping.  1972.  Pulp & Paper, Nov.

American Association for the Advancement of Science.  1965.  Air Conservation.
Publication No. 80.

American Society of Mechanical Engineers.  1968.  Recommended Guide for the
Prediction of the Dispersion of Airborne Effluents.  ASME, New York.

Andersland, O.B., and R. W. Laza.  1972.  Consolidation behavior of high ash
paper mill sludges.  NCASI Technical Bulletin No. 257.

Aspitarte, T.R., et al.  1973.  Pulp and paper mill sludge utilization and
disposal.  EPA Technology Series R-2-73-232.

Barnhill,  K. G.  1974.  Sludge dewatering.  Industrial Water Engineering,

Barton, J. S.  1973.  Future technical needs and trends of the paper industry
byproduct usage.  TAPPI, 56, 6.

Bishop, F. W., et al.  1968.  Biological waste treatment case histories in
the pulp and paper industry.  NCASI Technical Bulletin No. 220.

Blosser, R. 0.  1977.  Environmental protection energy use in the pulp and
paper industry.  TAPPI, 60, 8.

Borton, D. L., and R. 0. Blosser.  1977.  Effect of bleached kraft mill
effluents on growth and production of fish in experimental channels.  NCASI
Technical Bulletin No. 292.

Brunner, D. R. , and D. I. Keller.  1971.  Sanitary landfill design and
operation.  EPA.  PB 227 565 NTIS.

Burgess-Manning.  1967.  Silencing Handbook.

Can South provide more timber? ,1977.  Paper Trade Journal.  Mar.

Caron, A. L.  1977a.  Mud oxidation at the vacuum filter.  NCASI Special
Report No. 77-01.

Caron, A. L.  1978b.  Practices used by the sulfite pulping industry in the
handling and treatment of sulfur dioxide from miscellaneous sources.  NCASI
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Collins, T. C.  1969.  Development of sodium base sulfite chemical recovery.
Pt. 1.  Paper Trade Journal, June 30.

Copley International Corp.  1973.  A study of the social and economic impact
of odors.  EPA Contract No. 68-02-0095.  Feb.

 Cox, L. A., and H. E. Wanster.  1977.  An assessment of some sulfur-free
 chemical pulping processes.  TAPPI, 54, 11.

 Craig, D.  1973.  Justification for pulp and paper byproducts development.
 AIChE Synposium Series, 133, 69.

 David, C. L.  1971.  Color removal from kraft pulping effluent by lime addi-
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 Duke, J. M.  1974.  Patterns of fuel and energy consumption in the U.S. pulp
 and paper industry.  American Paper Institute.  Mar.

 Easty, D. B., et al.  1978.  Removal of wood derived toxics from pulping and
 bleaching wastes.  EPA Grant No. R-803525-04.  Feb.

 Edde, H.  1966.  A manual of practice for biological waste treatment in the
 pulp and paper industry.  NCASI Technical Bulletin No.  190.

 Ellerbe, R. W.  1973.  Why, where and how U.S. mills recover tall oil soap.
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kraft and semichemical pulp segment.  EPA 440/1-74-025-a, May.

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 limitations guidelines and new source performance standards for the bleached
kraft, groundwood, sulfite, soda, deinked and non-integrated paper mills of the
pulp, paper, and paperboard mills point source category.  EPA 440-1-75/04.

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kraft, groundwood, sulfite, soda, deinked and non-integrated paper mills of
 the pulp, paper, and paperboard mills point source category.  EPA 440/1-76/
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 Environmental Protection Agency.  1976b.  Standards  support and  environmental
 impact statement.  Vol. 1.  Proposed standards of performance for kraft paper
mills.  EPA 450/2-76-014-2,  Sept.

 Environmental Protection Agency.  1976c.  Design manual for  small waste-
water treatment plants.  Office of Technology Transfer.

 Environmental Protection Agency.  1976d.  Direct environmental factors at
municipal wastewater teatment works.  EPA-430/9-76-003.   Jan.

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fish kills.

 Fisher,  R.  P.   1977.   Advances  in source  emission  control.   NCASI  Special
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 Pt.  1.

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Hewson, E. W., et  al.  1973.  Factors  controlling formation and persistence of
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Hrutfiord, B. F., and J. L. McCarthy.  1967.  SEKOR-I volatile organic
compounds in kraft mill effluent streams.  TAPPI, 50, 2.

Johnson, W. D., and H. Gansler.  1971.  How Rayonier cuts blowpit sulfur
dioxide with chemical scrubbing system.  Pulp & Paper, 45, 13.

Kinstrey, R.  1977.  Odors from an aerated stabilization basin.  NCASI Special
Report No. 77-02.

Litton Systems, Inc.  1969.  Preliminary air pollution survey of hydrogen
sulfide.  APTD 69-37.  Oct.

McAliley, J. E.  1974.  A pilot study of a rotating biological surface for
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McLeay, D. J.  1975.  Journal of the Fisheries Board of Canada, 32, 753.

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pulp and paper industry sludges.  NCASI Special Report No. 77-02.

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Engineering  Progress, 71, 66.

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BAGASSE.  The fibrous material remaining after grinding sugarcane for its
     sugar juices.  It is normally recovered for use as a fuel for sugar mill
     boilers, but is also attractive as a raw material for papermaking.

BLACK LIQUOR.  Spent liquor recovered from a kraft digester up to the point
     of its introduction into the recovery plant.

BLEACHING.  The brightening and delignification of pulp by addition of
     chemicals such as chlorine or hypochlorite.

BLOW TANK.  A cylindrical tank with conical bottom into which the digester
     contents are blown tangentially at the top of the tank so that the stock
     drops to the bottom of the tank and the steam and gases escape from the
     top vent to a steam condenser.

BROKE.  Partly or completely manufactured paper that does not leave the
     machine room as saleable paper or board; also paper damaged in finish-
     ing operations such as rewinding rools, cutting, and trimming.

BROWN STOCK CHEST.  The tank into which the stock is dumped after leaving
     the brown stock washers and deckers.

CORD.  The quantity of wood contained in a pile of 4-foot wood 8 feet long
     and 4 feet high when the wood is stacked in an orderly manner with all
     logs parallel.

DECKER.  A mechanical device used to remove water or spent cooking liquor
     from pulp, and to thicken pulp consistency.

FIBER.  The cellulosic portion of the tree used to make pulp, paper, and

FOURDRINIER MACHINE.  The more popular papermaking machine using an endless
     moving belt made of metal or plastic, resembling a window screen, upon
     which a sheet of paper is formed.

FURNISH.  The mixture of fibers and chemicals used to manufacture paper.

JORDAN.  A type of refiner (see refiner).  Old-type Jordans used large
     hand-wheels for plug setting, with an improvised weight hung to it to
     prevent it brom backing off.  Modern units can be set either manually
     or automatically with precision and accuracy.

LIGNIN.  A nondegradable organic compound of wood.

MACHINE CHEST.  The tank into which the pulp from the refiners and recovered
     pulp from the save-alls is dumped before being delivered to the machine

REFINER.  A device used to reduce the size of the fiber in the stock.  It
     consists of a plug rotating in a shell, and both shell and plug are
     fitted with bars or knives in the axial direction.  The plug and shell
     may be tapered.  Then the stock is fed into the small end, sometimes
     under pressure, at a consistency usually in the range of 2 to 5% and
     discharged out of the top of the large end.

REJECTS.  Material unsuitable for pulp or papermaking that has been separated
     in the manufacturing process.

SCREENINGS.  Rejects from a pulp mill separating device such as a screen.

SKIVES.  Small pieces of wood that will not grind properly.

SULFIDITY.  Sulfidity is a measure of the amount of sulfur in kraft cooking
     liquor.  It is the percentage ratio of NaS, expressed as NaO, to active

TRIMMINGS.  The material cut off at the end of the papermaking machine, when
     the sheet is trimmed to meet a particular specification.

WASH-UP.  Periodic cleaning of equipment.

WHITE WATER.  Water that drains through the wire of a paper machine that
     contains fiber, filler, and chemicals.

                                   TECHNICAL REPORT DATA
                            (Please read Instructions on the reverse before completing)

                    3. RECIPIENT'S ACCESSION NO.

Environmental Impact Assessment Guidelines  for New

Source  Pulp  and Paper Mills
                    5. REPORT DATE
                     September. 1979
Gene V.  Beeland,   D. Keith Whitenight,
Kenneth  G.  Barnhill.

6900 Wisconsin Avenue, N.W.
Washington,  B.C.   20460
                    10. PROGRAM ELEMENT NO.
                    11. CONTRACT/GRANT NO.

                    68-01-4157, Task  003b
 EPA,  Office of Environmental Review
 401 M Street,  S.W.
 Washington, B.C.

                    14. SPONSORING AGENCY CODE

     EPA Task Officer is John Meagher,  (202)755-0790
      The report provides guidance  for evaluating the environmental  impacts of a
 proposed pulp and paper mill  requiring a new source National Pollutant  Discharge
 Elimination System (NPDES) permit  from the Environmental Protection Agency (EPA) to
 discharge wastewater to the navigable waters of the U.S.  The guidelines  are intended
 to  assist in the identification  of potential impacts, and the information requirements
 for evaluating such impacts,  in  an Environmental Information Document  (EID).   An EID
 is  a document prepared for EPA by  a new source permit applicant;  it is  used by the
 Agency to determine if the preparation of an Environmental Impact Statement (EIS)
 is  warranted for the proposed facility.

      The report includes guidance  on (1) identification of potential wastewater
 effluents, air emissions, and solid wastes from pulp and paper mills,  (2) assessment
 of  the impacts of new facilities on the quality of the environment,  (3) state-of-
 the-art technology for in-process  and end-of-process control of waste  streams,  (4)
 evaluation of alternatives, and  (5) environmental regulations that  apply  to the
 industry.  In addition, the guidelines include an "overview" chapter that gives a
 general description of the pulp  and paper industry, significant problems  associated
 with it, and recent trends in location,  raw materials, processes, pollution control, &
  the demand for industry output.   I	
                                KEY WORDS AND DOCUMENT ANALYSIS
                                              b.lDENTIFIERS/OPEN ENDED TERMS  C.  COSATI Field/GlOUp
   Paper Industry
   Pulp Mills
   Industrial Wastes
        Environmental  Impact

 Release Unlimited
       19. SECURITY CLASS (ThisReport)
              21. NO. OF PAGES
                                              20. SECURITY CLASS (Thispage)

                                                                        22. PRICE
EPA Form 2220-1 (9-73)