Study Of The Pulp & Paper Industry In Region IV


EPA
Study of the
Pulp & Paper
Industry
in Region IV

,—i
Water Management Division
Facilities Performance Branch
September 1986

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» 303SS
SHJDY DIRECTORS
John T. Marlar
Gil Wallace
STUDY MANAGER
Curt Fehn
PRINCIPAL AUTHOR
Kenneth Kwan
CONTRIBUTING AUTHORS
Curt Fehn
Larry Brannen
Phil Vorsatz
John Schoolfield
Jim Wang
CLERICAL SUPPORT
Harriet Brothers
Linda Kidd
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TABLE OF CONTENTS
Page
I.	INTRODUCTION	1
A.	Purpose	1
B.	Methodology	2
II.	CONCLUSIONS AND RECOMMENDATIONS	6
III.	DISCUSSION OF THE PULP AND PAPER INDUSTRY IN REGION IV	18
A.	General Background Information	18
1.	Process and Product Subcategories	18
2.	Type of Mills Surveyed	20
3.	Age of Mills	20
4.	Employment	20
5.	Production	23
6.	Water Use	23
B.	Basic Pulp and Paper Industry Process	27
C.	Characteristic of Pulp and Paper Waste	31
1.	Wastewater Production	31
2.	Waterwater Production vs Mill Age	34
3.	Influent and Effluent Waste Characteristics	37
4.	Influent and Effluent Waste Characteristics vs Mill Age	43
D.	Wastewater Treatment Systems Carcnonly Employed	44
E.	Camparision of EPA BPT Design Criteria to Design Criteria
Used by the Industry	49
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TV. PERFORMANCE EVALUATION OF EXISTING TREATMENT SYSTEMS	55
A.	Effect of Operating Parameters on Treatment
Performance	55
B.	Impact of Temperature and Geographical Location on
Treatment System Performance	66
C.	Compliance Rates for Pulp and Paper Facilities	90
1.	Industrial Performance Ccmpared with Permit Limits	91
2.	Industrial Performance Compared With Definition of
Significant Noncompliance	102
3.	Industrial Performance Ccmpared with Best Practicable
Control Technology Currently Available (BPT) Limits	118
D.	Performance Required to Meet BPT Limits	124
E.	Effect of Various Treatment Systems on Permit Compliance	128
F.	Current Control Technologies for Color Removal	133
V. SUMMARY OF ON-SITE INSPECTIONS	138
A.	Best Management Practices	140
B.	Spill Control	140
C.	Water Conservation	141
D.	Chemical Recovery	142
E.	Cannon Operational Problems	142
F.	NPDES Inspection Results	142
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VI. EVALUATION OF STATE NPDES PROGRAM	143
A.	NPDES Permit Program	143
1.	Permit Procedures	144
a.	Background	144
b.	Evaluation	147
2.	Permit Quality	149
a.	Background	149
b.	Application of the Guidelines	151
c.	Evaluation of Best Practicable Control
Technology Currently Available (BET)
Permit Limits	154
d.	Evaluation of Best Available Technology
Economically Achieveable (BAT) Permit
Requirements and Use of Best Management	165
Practices Plans
e.	Evaluation of Water Quality Based Permit	167
Requirements
f.	Conclusions and Recommendations	170
B.	NPDES Compliance Program	172
1.	Compliance Monitoring	172
a.	Compliance Review	172
b.	Data Management	176
c.	Compliance Inspections	181
d.	Discharge Monitoring Report Quality Assurance	186
(DMR QA) Program
2.	Enforcement Response	193
* a. Level of Response	193
b. Timeliness of Response	205
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APPENDIX
Page
A.	File Review Checklist for the Pulp and Paper Industry Study	206
B.	On-Site Technical Inspection Report for the Pulp and Paper
Industry Study	217
C.	NPDES Carpiiance Inspection Report (EPA Form 3560-3)	231
D.	Definition of Significant Noncompliance	235
E.	Calculation of Production-Based Effluent Limits	243
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PULP AND PAPER INDUSTRY STUDY
INTRODUCTION
A. Purpose
Increased responsibility and flexibility in implementing NPDES programs
by the states which have been delegated this authority has indicated a
need to determine whether these programs are being implemented
consistently. • The purpose of this study is to evaluate the permitting
of waste discharges and the compliance with these permits for one
particular industry. The pulp and paper industry was selected for
evaluation because it is of major economic importance to the Southeast,
it is large enough to provide a suitable cross-section for determining
trends in data, and it is represented in each Region IV State.
Additionally, Best Practicable Control Technology Currently Available
(BPT) requirements have been promulgated for this industry and compliance
tracking and enforcement of these permits should be straightforward.
At the moment, seven States in Region IV have been delegated the NPDES
program and EPA is inplementing the program in one State. The Kentucky
program was delegated at the end of 1983. All State agencies seek to
follow the Federal statutes, regulations and policies. However, the
NPDES program is complex and allays room for judgement in decision-making.
Therefore, this study attenpts to determine whether agencies involved
are'consistent in inplementing the NPDES program and how closely the
statutes, regulations, and policies are followed.

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B. Methodology
As a part of this study, on-site inspections were conducted at each of
the 56 major pulp and paper facilities in Region IV with the exception
of 1 mill in South Carolina where a telephone survey was conducted.
Specifically, those facilities selected were in the Standard Industrial
Classification (SIC) Codes of 2611 (Pulp Mills), 2621 (Paper Mills,
Except Building Paper Mills), and 2631 (Paperboard Mills). These
mills are distributed geographically as indicated.
State	Number of Facilities
Alabama	15
Florida	6
Georgia	10
Kentucky	3
Mississippi	5
North Carolina	7
South Carolina	6
Tennessee	4
TOTAL, REGION IV	56
In addition to the site inspections, files relative to these mills
were audited at each of the respective state agencies or at the EPA
Regional Office.
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Data were collected on three separate forms of which two were specifically-
designed for the study. These forms included a File Review Checklist
(Appendix A), an on-site Technical Inspection Report (Appendix B), and
a standard EPA NPDES Gornpliance Inspection Report (Appendix C).
Investigators were frctn the Facilities Performance Branch of the Water
Management Division (WMD), the Engineering Support Branch of the
Environmental Services Division (ESD), and respective State agencies
in Region IV. The study was coordinated, and the report prepared by
the Facilities Performance Branch of the Water Management Division.
As many Conpliance Sartpling Inspections (CSI's) and Performance Audit
Inspections (PAI's) were performed as possible. The ESD chose PAI's
based on Discharge Monitoring Report quality assurance data. All work
was coordinated with the state agencies and, where a CSI or PAI was
not performed, a joint Conpliance Evaluation Inspection (CEI) with the
appropriate state agency was conducted, if possible.
For each facility, a permit file audit was made of how effluent limits
were determined and also the technical basis of these limits. The pro-
cedures involved in issuing the permit were examined including the
fact sheet, draft permit, public notice, and the administrative record
supporting differences between the draft and final pemit.
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Also, for each facility, a compliance file audit was made verifying
the existence of operational procedures to receive, track, review, and
evaluate all reports submitted by the individual permittees. Of
particular importance in these procedures were basic elements such as
the existence of a comprehensive and accurate review of all compliance
materials relating to the NPDES permit; maintenance of complete and
current record files; an adequate procedure of tracking compliance
information; submittal of complete and accurate Quarterly Noncompliance
Reports; an adequate compliance inspection program; and consistent
enforcement actions.
Following the permit and compliance file audit, an on-site inspection
was conducted at each facility. This inspection included such things
as a comparison of actual operating conditions to the information
supplied on the permit application, the procedures used in monitoring
the waste discharges, sampling procedures, laboratory procedures, record
keeping at the facility, and reporting procedures to the responsible
agency. The efficiency of the treatment systems and the use of Best
Management Practices (BMP's) were also examined.
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Finally, information on file at EPA was conpared with information
available in the State files. This review included whether the PCS
inventory coincided with the State's inventory, whether the State's
technical review criteria were appropriate to screen DMR's and whether
EPA's list of facilities in significant nonconpliance was accurate.
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II. CONCLUSIONS AND RECOMMENDATIONS
Pulp and Paper Industry
1- Pulp and paper mills are a major ccnponent of industry in the Southeast.
The most cannonly found mills produce bleach kraft products, and
most mills in this study enplcy 500 or more people.
2.	The pulp and paper industry is a heavy water user. Surface vater
use ranges frcm 3.5 to 60 million gallons per day (MGD), groundwater
use ranges frcm 0.83 to 75 M3D, and municipal water use ranges from
1.4 to 11 MGD.
3.	Of the eight product subcategories studied, mills producing dissolving
sulfite pulp (K) and fine bleached kraft (I) products have the
highest influent loading to the treatment system.
Wastewater Treatment Systems
4.	All mills enplcy seme type of wastewater treatment system for BOD
and TSS removal. These systems basically consist of pretreatment,
primary treatment and biological treatment. Mditional treatment
processes beyond biological treatment were not found except for a
few mills that use polymers to iirprove settleability of the suspended
solids. Biological treatment ccrnmcnly used in the pulp and paper
industry are: aerated stabilization basins (ASB), oxidation basins
(OB), and the activated sludge process (AS). Aerated stabilization
basins are the predominant type of biological treatment.
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Performance of Treatment System
5.	Comparison of BPT design criteria to the operating parameters for the
38 ASB's revealed the following results: 24 (63%) operate at a
detention time under the reconroended period of 13 days; 30 (79%)
operate at a BOD loading rate over 1.13 lbs/BOD/1000 cu ft./day; and
14 (34%) operate at a aeration organic loading over 42 lbs BOD/hp/day.
6.	Temperature changes were found to have an impact on the efficiency
of biological treatment systems. Comparison of sunmer to winter
values give an overall improvement in removal rate of 21% in BOD during
the sunmer. As might be expected, treatment systems with shorter
detention times are less affected by temperature changes. These
effects are found in all Region IV states although seasonal temperature
impact is not as great in Florida since temperature variation is less.
7.	Statistical analysis of various treatment system's performance with
BPT design criteria and operational parameters results in a very low
correlation. None of the five operational parameters studied were
found to have a significant impact on treatment efficiency. A
single operational parameter apparently cannot be used to characterize
the variability of treatment performance for the activated sludge,
aerated stabilization basin, and oxidation pond process.
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Compliance Rates
The compliance of wastewater treatment plants is analyzed in three
ways: any permit violation, a significant violation, and a violation
of a Best Practicable Control Technology Currently Available (BPT)
limit.
8. Any Permit Violation:
Overall permit compliance considering monthly average BOD and TSS
violations, of Region IV pulp and paper mills is calculated to be
82% for the two year study period. Three of the eight Region IV
states have permit compliance rates less than 80% (Alabama, North
Carolina, Tennessee). This is a poor performance for such a large
industry. At present, the States rarely take formal enforcement
actions against permit violations until the violations become significant
(i.e., covered under the definition of significant noncompliance).
The effect of this policy on the construction and operation of waste
treatment facilities is to use as a compliance base 140% of permit
limits for BOD and TSS as opposed to the permit limits themselves.
EPA should ensure that States address all permit violations in
keeping with their Enforcement Management System.
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9. Significant Violation:
Using EPA's definition of significant noncompliance, the pulp and
paper industry taken as a whole, has a better compliance rate than
the average for all major industries in Region IV based on Quarterly
Noncompliance Reports (QNCRs) submitted to EPA. In all, the percent
of those not in significant noncompliance was 94% for the pulp and
paper industry and 92% for all major industries. Only six mills
(11%) had instances of significant noncompliance during the two year
study period. No mills were in significant noncompliance during the
study period in three states.
10. Violation of Best Practicable Control Technology Currently Available
(BPT) Limit:
A comparison of facility performance to BPT limits when calculated
using the highest annual average production figures between 1979 and 1983
show that 19 of 56 mills studied (35%) did not consistently meet monthly
BPT limits for BOD and TSS. Further analysis of operational data
for the 13 aerated stabilization basin treatment facilities revealed
at least 8 (62%) operate their treatment system at a higher BOD
loading rate than the recommended range for BPT design on an annual
average basis. It appears that as pulp and paper mills have expanded
production, the wastewater treatment plants have not been redesigned
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to produce a discharge meeting BPT guideline requirements. Thus,
there is a significant portion of the industry that will need to
make improvements in its wastewater treatment plants. In sane
cases, this will occur when present permit limits are tightened
(see no. 17). Also States must ensure that all permit violations
are addressed (see No. 8).
11. Despite the inability of sane individual mills (35%) to meet monthly
BPT guideline limits as discussed previously, the annual average
performance of mills in most subcategories is well within the range
required to meet BPT limits on an annual basis. However, additional
treatment capacity may be needed to handle the peak monthly variations.
12. Based upon observation of monthly BOD and TSS violations over a 24
month period, oxidation ponds appear to be far superior in their
ability to meet permit limits than the mechanical treatment systems
studied. Statistical analysis of the five mechanical treatment
systems utilizing the Chi-Squared (X2) Test indicated a probability
of no significant difference among them in their ability to meet
permit limits at 5% signficance level.
13. Of the fifty-six pulp and paper mill in the survey, there are only
two that currently have limits for color. They are Bcwater
Carolina (SC) and Bcwater Southern Paper (IN). The color limit for
these facilities basically consist of flow control release.
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14.	Current control for color abatement includes such approaches as
ultra-filtration and massive lime treatment. Unfortunately, none of
these methods have enjoyed full scale operational success in Region
IV, due to either operational reliability problems or expected high
costs developed frcm demonstration projects or treatability studies.
To minimize the aesthetic concerns of effluent color, mills in Region
IV often rely on holding ponds to control their discharge. Another
approach is internal load control. Newly constructed mills using an
oxygen delignification process prior to the bleaching sequence has
showed a pronounced improvement in effluent color as compared to a
more conventional bleaching line.
Surtmary of On-Site Inspection
15.-	All mills effectively have portions of a Best Management Practices
Plan (BMP), even though it was not referred to as such. Mills use
various procedures for spill control and chemical recovery. The
vast majority have high level alarms, conductivity probes in U-drains,
diking around fuel tanks, and curbing around chemical process areas.
16.	Field inspection data for this study was reported on EPA's four page
NPDES Compliance Inspection Report (Form 3560-3). Inspection results
at each mill indicate that thirty-nine of the fifty-five mills are
in ixxnpliance with all of the items examined. Of the sixteen mills
where one or more of the items are unsatisfactory, eight have problems
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with sampling, four have flow monitoring problems, three have incomplete
or incorrect recordkeeping systems, and one has a laboratory deficiency.
Of the ten mills where sampling was conducted, two of the facilities
also exceeded permit limits. These problems constitute permit violations.
The States and EPA must follow with enforcement actions to assure
that these violations are corrected.
NPDES Permit Program
Results frcm yearly EPA audits of NPDES permits in Region IV show
that virtually all of the required permit issuance procedures are
presently being implemented. The quality of the permits region wide
continues to advance as procedures are further clarified and as EPA
and the states gain experience in their respective roles. A survey
of 56 pulp and paper mill permits issued frcm 1979 through 1983,
however, found that seme permits did not appear to follow guideline
requirements for obtaining mill production rates, and many files lacked
proper certification for non-use of chlorophenolic-containing biocides.
17. Twenty-one (38%) of 56 pulp and paper mills surveyed in Region IV
(issued 1979 through 1983) were found to have one or more limits
more lenient than required by EPA BPT regulations. Sixteen (29%) of
the 56 mill permits surveyed were found to contain one or more limits
significantly more lenient (greater than 3%) than required by
regulations. Two of these were a result of the use of seasonal
limits, which take into account the seasonal "high flew" and "lew
flow" periods of the receiving waters. Five of these 16 permits,
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however, listed production rates based on plant design capacity
or maximum production, and were considered not issued according to
guidelines. One resulted from a change in mill production levels,
and the remaining 8 of the 16 permits did not contain proper documentation
to support the production rates or limits they contained. The EPA
regulations on this matter are inconsistent and leave room for
interpretation. The Agency has attempted to eliminate the resulting
confusion by issuing a memorandum stating its policy as to what may
be considered appropriate in determining a mill's "annual average"
production rate. For the 16 facilities with significantly more
lenient limits, the States and EPA should reopen these permits and,
if the current limits can not be supported, reissue the permit.
Also, EPA should undertake regulatory revisions to eliminate confusion
and inconsistencies between requirements.
18.	Twenty (36%) of 56 pulp and paper mill permits surveyed (issued 1979
through 1983) were found not to have limits for pentachlorophenol
and trichlorophenol, and also did not have present in the permit
file a certification of non-use of chlorophenolic-containing biocides.
The guidelines require mills which do not have these limits to
certify that they do not use chlorophenolic-containing biocides.
EPA and the States should contact the facilities involved and obtain
the necessary certifications.
19.	Twenty-nine facility permits (52%) of the 56 studied are believed
to have permit limits adequate to protect water quality standards.
Through program activities not directly connected with this study,
EPA has identified 10 of the 56 (18%) facilities included in this
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study as having inadequate effluent limitations to maintain instream
water quality standards. Program actions to correct this situation
are underway. Seventeen facility permits (30%) of the 56 facilities
studied have not received a comprehensive review to deterine if
water quality standards are protected. A review of these permits
will be scheduled in the normal course of State and EPA program
implementation.
NPDES Compliance Program
20.	The NPDES permit requires that the permittee notify the regulatory
agencies and submit a noncompliance report for each instance of
noncompliance. However, only half of the 164 permit violations are
known or properly documented. Of the 56 mills listed, a total of 15
mills (27%) have seme deficiencies in this area of noncompliance
reporting. For mills with SNC violations, the noncompliance reporting
records are even worst. Written records of noncompliance reports
were submitted to Region IV states and EPA only 33% of the time for
SNC violations. Of the 6 mills with significant violations, only
one properly notified the state of its noncompliance by written
notice. This report is a regulatory requirement. EPA and the
States must work to improve compliance with the notification requirement.
EPA should increase its overview activities to assure compliance
with all Clean Water Act requirements.
21.	With few exceptions, state data management systems are found to be
complete and current and adequate to provide proper surveillance.
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22.	States are required to submit quarterly noncompliance reports to EPA
describing violations at major facilities. These reports, which are
made public and used to monitor trends in the effectiveness of the
NPDES program, include only major discharges and only facilities in
significant violation of their permit, as discussed above, as opposed
to any permit violation. Based on the file review at each NPDES
state office and EPA, six pulp and paper mills were found to be in
significant noncompliance at some point during the study period.
These six mills should have been reported on the QNCR for all instances
of significant noncompliance; however, NPDES states reported mills
in significant nonccnpliance on an average of only 44% of the time
that these reports were required to be made. Because of the importance
of this report to Congress, the public, and EPA, and the small number
of facilities involved, immediate efforts should be made by the
States to assure its accuracy. EPA needs to increase its overview
activities to assure compliance with all Clean Water Act requirements.
23.	EPA believes an inspection should be made at each major facility at
least once in each twelve month period. Correlations between the
number of inspections performed and the number of pulp and paper
mills in the study revealed that enough inspections are made to
cover each facility on the average of once eight months.
However, since sane mills are inspected more frequently, not all
mills are inspected annually. In approximately half of the Region IV
states, all mills are not receiving yearly inspections. Each state
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should re-evaluate its strategy and priority for conducting routine
and special inspections. Each facility should be inspected every
year. Where States are unable or unwilling to make this yearly
inspection, EPA should conduct the inspection.
24.	In the past five Discharge Monitoring Report Quality Assurance (DMR QA)
studies (1980-1985), the pulp and paper industry performance (success
rate) was higher than other Region IV industries and the national
average in all studies except one. The degree of improvement in
performance from Study 1 (82.1% success rate) to Study 5 (85.8%
success rate) was not very significant with small increases in performance
frcm study to study. The percentage of mills reporting a 100% success
rate for Study 5 (58.5%) indicates that further improvement is
needed.
25.	EPA and delegated states response to non-significant violations are
within the framework of the Enforcement Response Guide (ERG) as
detailed in EPA's Enforcement Management System (EMS). These minor and
isolated violations are enforced uniformly and consistently among
the states in Region IV.
26.	Of the 6 mills in significant non-compliance, two were in this
category with short duration (lasting one quarter). No enforcement
actions were taken by the states or EPA because each ccmpany notified
the regulatory agency of the problem and permit violations ceased
quickly.
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27.	Four mills in four separate states were found to have significant
violations with long duration (lasting two quarters or more).
Delegated states took only informal actions which proved to be
ineffective in limiting these violations. Using the criteria in EPA's
Enforcement Management System, state enforcement response was found
to be inadequate in these four cases. States must take forceful
enforcement action more quickly in these cases. EPA should increase
its overview of state enforcement activities to ensure that appropriate
action is taken in a timely manner.
28.	Since the study period, EPA policy has required, and the states have
agreed, that formal action should be taken against all facilities
who are in significant noncompliance with their permit for two
consecutive quarters (this includes violations of less than six
months duration). Of the four states with mills in significant
noncompliance for two consecutive quarters or more, only one took a
formal enforcement action. This record will improve as the new
policy continues to be implemented. EPA must assure, through
independent enforcement actions if necessary, that formal actions
are taken ori a timely basis.
29.	Considering the timeliness of actions, when taken, EPA and delegated
state have an adequate record. Most informal actions were acted
upon within 30 days. Formal actions were acted upon within 60 days.
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III. DISCUSSION OF THE PULP AND PAPER INDUSTRY" IN REGION IV
A. General Background Information
1. Process and Product Subcategories
In order to establish effluent limitations, new source performance
standards, and pretreatment standards, the EPA has categorized the
pulp, paper and paperboard, and the builders' paper and board
mills point source categories into three segments: Integrated,
Nonintegrated, and Secondary fibers. These three segments have
been subcategorized further by manufacturing process and product
as follows:
Integrated Segment
Dissolving Kraft (F)
Market Bleached Kraft (G)
BCT (Board, Coarse, and Tissue) Bleached Kraft (H)
Fine Bleached Kraft (I)
Soda (P)
Unbleached Kraft (A)
. Linerboard
. Bag and Other Products
Semi-Chemical (B)
Unbleached Kraft and Semi-Chemical (V)
Unbleached Kraft-Neutral Sulfite Semi-Chemical (Cross-Recovery) (D)
Dissolving Sulfite Pulp (K)
. Nitration
. Viscose
. Cellophane
. Acetate
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Papergrade Sulfite (Blew Pit Wash) (J)
Papergrade Sulfite (Drum Wash) (U)
GroundwDod-lhermD-Mechanical (M)
Groundwood-Coarse, Molded, and News Papers (N)
Grcundwood-Fine Papers (O)
Groundwood-Chemi-Mechanical (L)
Nonintegrated Segment
Nonintegrated-Fine Papers (R)
. Vfood Fiber Furnish
. Cotton Fiber Furnish
Nonintegrated-Tissue Papers (S)
Nonintegrated-Li^itwei^it Papers (X)
. Lightweight Papers
. Lightweight Electrical Papers
Nonintegrated-FiIter and Nonwoven Papers (Y)
Nonintegrated-Paperboard (Z)
Secondary Fibers
Deink (Q)
. Fine Papers
. Tissue Papers
. Newsprint
Tissue frcm Wastepaper (T)
Paperboard fran Wastepaper (E)
. Corrugating Medium Furnish
. Noncorrugating Medium Furnish
*Wastepaper-Molded Products (W)
Builders' Paper and Roofing Felt
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2.	Type of Mills Surveyed
The mills surveyed represents a wide range of product subcategories.
Of the fifty-six mills located in EPA Region IV, those producing kraft
products are the most coimton. Table 1 lists the distribution of
production rates for 1983 in annual air dried tons/day by EPA
subcategory. As shewn in this table, eighteen mills are involved
totally or partially in the production of unbleached kraft products.
The next most common types of mill are those producing BCT bleached
kraft products (16) and market bleached kraft pulp (13). There
are two mills in Region IV which are not included in the preceding
subcategorization scheme. One of the mills produces cotton linter
pulp for use in the production of currency papers and the other
produces builder's paper.
3.	Age of Mills
The majority of the mills in Region TV have been built since 1949.
Six of the mills are more than fifty years old and only three are
ten years old or less. The age distribution of the mills in
Region IV is shown in Figure 1.
4.	Employment
The number of people employed at the mills is generally high, with
employment ranging frcm 90 to 3500. Of the forty-eight mills
reporting their employment, twenty-one employ a thousand or more
people and thirty-five employ five hundred or more people.
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TABLE 1
1963 PRODUCTION PROFILE OF PUP AM) PAPER MILLS IN REGION IV RY PROMT SUOCRTEGDRY (AMML AIR DRIED IONS / DAY)
Mia MME
LOC
COTTON
BUILDERS L INTER
I PAPER PaP TOT*
I
I-O
ALTW HI MM)
~MAKER CORP
in
ST. REGIS PAPER ICHWP. INPL)
UXEVE miUffif CORP
ae6 ia
KIMEALV-ONK
SIDE CMTAIKR
BOATER CAUL IMA
INTEMATIBML R»
icstvrcocorp
IMIEMATIMRL PAPER VIC
ST. RESIS PAPER ML -PACIFIC)
UflEMATIONAL PAPER NAT
jRoisoi cd pdnt ruihiintl p.)
MEYERHREUBER CO
RDMRTER SOUnCM PAPER
mm cm
IftJM OMTHIICII
IBM RIVER MLPIPRPER
ALAHNA NMFT,GA RRRFT
CMMPim PAPER
BOLD AM KIILSII6
HU-F STATES PAKR
HRMKMIU. PURER
Kim.Y-aiW
iMiwaw
AUMNA RIVER PILP CO
AU.IEI PAPER,S HILL
CDHTAIK1 CORP
BIIIE MOT« II
NRCMURNRUOa
RIVER)
MNU NATER SERVICE IP
aeon Arrr.mmu ma
STK CmTMMER CORP
CWTIIBmR. FORESTIFEKRn. P.)
INTERSTATE PRO CORP
SOUTKABT PNPU m
m RMRI1ER
MESNROFIK PMEK
W1LU1CTTE IM ID MILL
UlliNCm M N KMFT
ALMA CELLULOSE
ICYEMSSR M
ICYEWAEIJBER H.
CHMPIOI PAPERS
ma MLODRF-OO* INT'L
am CORP iECUSTA CORP)
a
a
a
a
a
a
sc
sc
sc
sc
sc
sc
MB
IB
K
W
MS
w
IN
IN
m
«L
A.
AL
AL
RL
AL
AL
AL
a.
AL
m.
AL
rl
AL
«.
OR
OA
an
OR
OA
80
an
en
RY
KY
RY
IC
e
ic
NC
NC
NC
NC
ni
RI7.3
1000
1330
ate
1907
1393
1997
300
1311
270
lit
734
676
736 497
276.1
237
130
R6I.7
121.2
130.6
109
ill
142 404 39.1
393
243.9 626.4 663.2
37R
333
275
933
1633.R
11*1
2167
9(6
1141
70S
919
351
1941
113.7
imi
196.7
90
1016.9
3B1
1074
467
230
997.3
100
997
632
1010
326
97L2
IIS
107 773
608
234
946.4
94 204
330
26.4
301.R
1033
2R79 64
2353
330
616 343
70
160
1337 416
999
913
747
603
132.6
964
1020
799
3RI	R74
69R 1021
107
11/
791.0
1997.0
300.0
1093.4
1319.0
1000.0
239.6
1330.0
1679.1
400.0
2562.0
RS.0
1307.0
1393.0
123X0
•61.7
710.0
2166.7
633.0
333.0
1767.5
1181.0
1359.3
191.7
719.0
1016.5
1R39.0
2167.0
1074.0
603.0
1190.0
1010.0
16310
937.5
1743.0
1924.6
915.0
1612.0
951.0
521.2
2941 0
1733.0
1941.0
11R5.0
23510
13710
747.0
336-0
603.0
132.6
1*4.0
799.0
221k. 0
1719.0
1105.0
310.0

-------
FIGURE 1
AGE DISTRIBUTION
MILL AGE (YEARS)

-------
Production
As shown in Table 1 the major products produced in 1983 by the mills
observed during this study were unbleached kraft products (22,242
tons/day), BCT bleached kraft products (10184 tons/day), market
bleached kraft pulp (9060 tons/day), unbleached kraft-neutral
sulfite semi-chemical (Cross Recovery)(9140 tons/day); and fine
bleached kraft (6274 tons/day). The remaining products
produced by mills are included in the following subcategories: semi-
chemical (1611 tons/day); dissolving kraft (2715 tons/day);
dissolving sulfite pulp (500 tons/day); paperboard from wastepaper
(1577 tons/day); groundwood chemi-mechanical (244 tens/day);
groundwood thermo-mechanical (1313 tons/day); groundwood CMJ
papers (2398 tons/day); groundwood fine paper (39.1 tons/day);
soda (378 tons/day); Deirik (534 tons/day); non-integrated fine
papers (737 tons/day); nonintegrated tissue papers (181 tons/day);
tissue from wastepaper (109 tons/day); non-integrated lightweight
papers (117 tons/day); builders paper (199 tens/day); and cotton
linter pulp (133 tons/day).
Water Use
A majority of the mills surveyed used surface water sources for at
least part of their process water needs. Only eighteen mills
utilized ground water sources, and four of these also utilized
surface water or municipal water. Surface water use ranged fran
3.5 to 60 MGD, ground water use ranged frcm 0.83 to 75 MGD, and
municipal water use ranged frcm 1.4 to 11 MGD. Table 2 lists the
average daily water use of each mill surveyed.
- 23 -

-------
TABLE 2
HATERUSE DATA FOR RESION IV KILLS
MILL NAC
STATE
PRODUCT
SUBCATEGORY
AGE
(YEARS)
AVERAGE
WATER USE
(N6D)
MATER *
SOURCE
UESTVACO CORP	SC
GEORGIA KRAFT	GA
ST. REGIS PAPER (GA.-PACIFIC)	MS
ALABAMA KRAFT,GA KRAFT	AL
STONE CONTAINER CORP	GA
UNION CAMP	flL
STONE CONTAINER	SC
INTERSTATE PAPER CORP	GA
(MENS ILL	Fl
INTERNATIONAL PAPER VIC	MS
A
A
A
A
A
A
A
A
A
A
48
31
17
19
37
IB
22
17
31
18
20.0
23.0
20.0
24.0
13.0
21.0
15.0
9.0
12.0
29.0
MACMILLAN BLOEDEL
A/D/E
17
20.0
ALTON BOX BOARD	FL
TEW RI\ER PULPtPAPER	TN
HOERKR WALDORF-CHAMPION INTL NC
A/E
A/E
A/E
46
24
76
8.0
24.0
28.0
ST. REBIS PAPER (CHPMP. INTL) FL
A/H
44
24.0
MOBILE HATER SERVICE
(INTERNATIONAL PAPER)
INUW CONTAINER
(CAD CORP
TN
AL
A/H/I/N/M
15
11
34. B
3.5
3.8
GOLD BOW BUILDING
ALPHA mnitWF
Buildars Papar	29
Cotton Lintar Pulp	17
0.8
1.4
CONTAIWH
UILLflfCTTE m IP MIU.
GREAT SOUTHEM PAPER
FL
KY
GA
D
D
D
47
18
21
42.0
2.7
25.0
UNION CAW
INTERNATIONAL PAPER
SOWCO PRODUCTS
BUCKEYE CnilinRF CORP
6A
SC
FL
D/E
D/H
E/B
50	27.0
11.0
48	NO DATA AVAILABLE
86	NO DATA AVAILABLE
31	54.0
G
M
- 24 -

-------
TABLE 2 (CONT'D)
WATERUSE MTA FOR REGION IV HILLS
PRODUCT AGE AVERAGE	WATER ~
KILL MflKE STATE SUBCATEGORY (YEARS) HATER USE	SOURCE
(USD)
INTERNATIONAL PAPER NAT W F/6 36 36.8	6
ALABAMA RIVER PULP CO
UILLAHETTE If® u kraft
WEYERHAEUSER NB
HAHCRHILL PAPER
PL
KY
NC
AL
7
16
17
19
23.0
a.s
31.0
25.0
BRIHSHICK PULPtPAPER
in RAYONIER
SA
GA
6/H
6/F
47
31
49.4
24.2
75.0
BOHATER CAROLINA
JACKSON CO PORT AUTH IP
DIXIE NORTHERN INC
(JAIES RIMER CORP)
SC
16
AL
6/WH/1/W/0
H
H
72
27
37.0
0.1
16.9
49.0
6
S
6ILMN PAPER
CONTAINER CORP
GA
AL
M
H/A
44
26
30.0
7.0
23.0
6
S
S
FEDERAL PAPER BOARD
NC
H/6
34
43.0
GULF STATES PAPER
H/6/B
28
21.4
9C0n PAPER, MOBILE MILL
H/I
46
60.0
boater same* pmi

mm.
43.0
axTimm. forest iw
(FEDERAL PAPER BOARD)
CHAMPION PAPER
ALLIED PAPER,S "ILL
UESTVACO F1IC PAPERS
GA
RL
AL
KY
H/N/B/S
14
21
13
38.7
34.0
17.3
22.6
S
S
s
UEYERHAEUSER PL
NC
I/D/6/E
62.3
CHANP10N PAPERS
I/H/6
- 25
79
43.0

-------
TABLE 2 (CONT'D)
HATERUSE DATA FOR REGION IV KILLS
PRODUCT	AGE	AVERAGE	HATER ~
MILL NRK STATE SUBCATEGORY	(YEARS)	HATER USE	SOURCE
(M6D)
ITT FL K	47	25.0	G
HEYERHAEUSER CO MS K/R	3	6.2	6
KlfBERLY-CLARK AL N/G/H/N	36	60.0	S
ICAD CORP TN P/R	66	12.0	S
SOUTKAST PAPER IFB GA fi/M	6	6.0	S
KIWERLY-CLARK SC S/T	17	4.0	S
QLIN CORP (EDJSTA CORP) NC X/R/I	46	24.5	S
»
6 - GROUWUATER
S - SURFACE HATER
H - MUNICIPAL HATER
- 26 -

-------
B. Basic Pulp and Paper Industry Processes
As indicated by the number of process and product subcategories, the
pulp and paper industry is made up of marry different types of production
facilities. Therefore a wide variety of production processes exist within
the industry. However, for the purposes of this report, a general
description of the basic mill processes will be presented in order to
acquaint the reader with basic mill operations and the sources of wastatfatetr
in the industry. Following sure surmary descriptions of each of the nine
fundamental processes identified in Figure 2 .
Wood Preparation - operations which prepare the wood for the pulping
digester, including debarking, chipping, chip screening, and disposal of
bark and wood wastes. Wastewaters resulting from these operations include
log flume blowclawn and barker bearing cooling water.
Pulping - process by which wood fibers are softened, loosened, and
separated by mechanical and chemical processes. Wastewaters produced
in the process include wash waters, condensate, chemical by-products
and residues, and blew pit collected spills. A high percentage of
these waste products are recovered.
Screening - process by which foreign natter such as dirt, slivers, knots,
grit, bark, sand, and uncooked chips are removed from the pulp. Wastewater
produced in this step is characteristically a weak liquor with high solids
content resulting frexn the recycling of white water or other recycled
waters prior to the screening operations.
- 27 -

-------
FIGURE 2
GENERAL FLOW SHEET
PULPING AND PAPERMAKING PROCESS
HAW MATCWIAlt
rUXOAMCHTAL PWOCtS*

WASTES
LIQUID
SOLID
pulp toot
*000
PatPABATION
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coouaa «atc*
•AIM VATt*
• AN M'UJl
voop »»»Tieut»
A»0 tklVlM
«a«ouit
ACIO OUkPlTf UOUO*
AbKAU*C tUkPATt U*
tap aptl
MtwrnAb tutriTK LIQUOR

CMianoN
nwi
NIU9I
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TIOM U A IT*
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llUFT
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IMIOOIOM
kial KlkN IMItatON
atcovtar puaaAct
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llltPIYt IPCaT
uauoa
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MWO WAOHIKO
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TMCftCMNS
~L
UHOLIACKtO PUt*
-J	
-paiiN «atc* o« »wTf _r
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afAacN
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Aae AOntlivt*
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rim
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stock
PftCPABATIOM
CLCAW
•AT t»

papck
¦ACMIMI
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vapoo
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T
CIS AM • UP
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OIKT
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taoci
aaoai
COATIMI
- 28 -

-------
Washing - process by which fine pulp resulting from screening operations
is washed with white water or fresh water to remove fine particles of
bark, sand, grit and other small solids. Wastewaters include white or
fresh waters with high solids content.
Thickening - process by which purified pulp is dewatered. Wastewaters are
similar to those produced by washing operations.
Bleaching - process by which color is removed from pulp following the
thickening process. These bleaching processes consist of a sequence of
stages which can be varied depending on the type of pulp and the degree of
bleaching desired. The stages are identified by the chemical used in the
stage and consist of chlorination (C), alkaline extraction (E), sodium
hypochlorite (H), and chlorine dioxide (D). Two of the most ccrrmon kraft
bleaching processes used today are the CEDED and CEHDED sequences. Wastes-
waters consist of diluted solutions of these chemicals and white water,
which are used to wash the pulp between bleaching stages. These wastes are
typically caustic and their disposal is one of the most difficult waste
disposal problems for kraft mills.1
Stock Preparation - includes a number of processes involving repulping
and blending of pulps, addition of chemicals and fillers, and mechanical
treatment, all of which are directed at preparing pulp for the paper
machines. Wastewaters produced during this process consist of cleanup
waters and dilute solutions of the chemicals used in the process.
llhe Basic Technology of the Pulp and Paper Industry and Its Waste Reduction
Practices, EPS 6-WP-74-3; p. 77; Canadian Water Pollution Control Directorate;
August, 1974.
- 29 -

-------
Paper Machine - the mechanical system used to convert the pulp suspension
into paper. Wastewaters collected during this stage are high in fiber
content and are collected in "Saveall" collection pits, then recycled.
Finishing and Converting - these operations prepare the paper for shipment
and include surface finish improvement, sizing of rolls, cutting of sheet
paper and off-machine coating. These operations produce little wastewater
except for clean-up water.
- 30 -

-------
C. Characteristics of Pulp and Paper Waste
The following sections present information on the wastewater production
and wastewater characteristics of pulp and paper mills in Region IV.
Sources of information to characterize flew, mill age, influent, and
effluent data are based upon EPA's Oi-Site Technical Inspection Report
(see Appendix B) and Discharge Monitoring Report (DMR) from State
regulatory agencies and EPA.
1. Wastewater Production
In order to evaluate the effect of product subcategory on wastewater
volume, EPA identified a total of 26 mills that produce only one
product ("primary mill"). This criteria was established to ensure
that the selected mills would be representative of the normal manufacturer
processes and product grcuping. Table 3 presents available survey
data on wastewater volume and production for "primary mills" in the
following subcategory: unbleached kraft (A); send-chemical (B) ;
unbleached kraft-neutral sulfite semi-chemical (D); dissolving
kraft (F); market bleached kraft (G); BCT bleached kraft (H); fine
bleached kraft (I); and dissolving sulfite pulp (K). Figure 3
shows the ratio of wastewater volume to production against the
eight product subcategories listed. The highest ratio of wastewater
volume to production was observed in the BCT bleached kraft (H)
subcategory, while the lowest ratio was observed in the semi-chemical
subcategory (B).
-31 -

-------
TABLE 3
WASTEWATER PRODUCTION
(1983 Average)
Product
No. of
Total
Tbtal
Waste/rater Volume/
Subcategory
Mills
Wastewater Volume
Production
Production


(mgd)
(tons/day)
(1,000 gal/ton)
A
10
162
14967
10.82
B
2
6.99
1493
4.68
D
3
41.6
4908
8.48
F
1
43.06
1319
32.65
G
4
85.4
3493
24.45
H
2
62.4
1872
33.32
I
3
91.9
2911
31.57
K
1
12.32
500
24.64
- 32 -

-------
FIGURE 3
WASTERWATER PRODUCTION
CJ
CO
c
o
s
a
a
o
DC
-------
2. Wastewater Production vs Mill Age
Unbleached kraft (A) products have been shown to be the most
significant effort of the pulp and paper industry in the southeast
during 1983. Therefore, it is appropriate to analyze wastewater
production with mill age for unbleached kraft mills. For the other
seven subcategories, EPA was unable to determine a correlation of
wastewater production with mill age because of the limited number
of mills that could be used for statistical analysis. Table 4
lists the name, age, and wastewater production for each mill under
the unbleached kraft product subcategory. By using the average mill
age of 26 years as a reference point, wastewater production for
mills under 26 years is 9.96 Kgal/ton, whereas wastewater production
for mills over 26 years is 13.94 Kgal/ton. Figure 4 illustrates
the relationship of wastewater production to mill age by the use of
linear regression analysis. The resulting correlation coefficient
between these two variables is 0.2. This figure indicates a low
correlation between wastewater production and mill age. Causes for
the low correlation may be partly explained by the fact that seme
older mills have continually upgraded and modernized their production
facilities to remain competitive with newer mills using the latest
technologies. A typical case of mill upgrading, rebuilding, modernizing
and expanding is Georgia Kraft (wastewater production = 7.94 Kgal/ton).
A review of survey data indicated at least three major and extensive
improvement programs were undertaken between 1962 and 1979. Therefore,
the age of the mill is not a good parameter for statistical analysis.
Evaluation of the age of equipments may offer more insight into the
effectiveness of water reuse and internal process control.
- 34 -
-------
TABLE 4
WASTERWATER PRODUCTION VS KILL AGE
PRODUCT AGE WASTEWATER
MILL NAfC STATE SUBCATEGORY (YEARS) PRODUCTION
-------
30
28
26
24
22
20
18
16
14
12
10
8
6
4
2
0
FIGURE 4
WASTERWATER PRODUCTION VS
MILL AGE - 1983 AVERAGE
~
—r~
25
35
45
MILL AGE (years)
-------
3. Influent and Effluent Waste Characteristics
Table 5 presents survey data on the influent and effluent waste
characteristics of BOD and TSS at mills representing the eight
product subcategories. The influent values were the average of
twelve monthly sampling results taken by mill personnel at points
prior to primary clarification. For cases where sampling results
were taken after primary clarification, the influent values were
multiplied by a kncwn factor. This factor is based upon the performance
of primary clarifiers treating wastewater from various subcategories
of the pulp and paper industry. Removal rates through the primary
clarifier can range frcra 10% to 35% for BOD and 66% to 85% for TSS
depending on the subcategory. EPA's clarifier performance data
came mainly from literature1 and experts from EPA's Effluent Guideline
Division in Washington, D.C. Figures 5 to 8 are presented to
demonstrate the effects of the eight product subcategories on
influent arid effluent waste loading. Influent BOD and TSS values
for Dissolving Sulfite Pulp (K) and Fine Bleached Kraft (I) subcategories
were much higher than the other subcategories. This is due to the
fact that their final products reguired a higher percentage of
Alpha-Cellulose than the others. As result, more waste products
such as lignin, dissolved solids, and other impurities are taken
out in their process and discharged to the waste treatment plant.
Istate-of-the-Art Review of Pulp and Paper Waste Treatment, EPA-R2-
73-184; P.39 and P.42; Environmental Protection Technology Series;
April 1973.
- 37 -
-------
TABLE 5
INFLUENT AND EFFLUENT WASTE CHARACTERISTICS BY PRODUCT SUBCATEGORY
PRODUCT NO. OF AV8. FLOW
SUBCATEGORY MILLS (lOOOGAL/TON)
A lO 16.20
B a S. OS
D 3 7.94
F 1 33.98
8 4 24.48
H 2 32.39
I 3 31.01
K 1 24.63
ANNUAL AVERAGE - 1983
INFLUNT (LBS/DAY) EFFLUNT (LBS/DAY)
BOD TSS BOD TSS
73. 42 2. 91 3. 34
68.98 6.30 13.42
33.82 3.38 4.71
132.15 6.13 18.04
77.32 8.00 9.34
81.06 6.70 8.08
211.83 4.83 4.91
229.99 36.27 21.73
32. 83
63.09
34.41
31.41
68.50
83. 77
119. 78
136.39
-------
FIGURE 5
CO
VO
Z
o
I-
K
hi
£L
O
O
o
(A
a
RAW WASTE CHARACTERISTICS
FOR BOD - 1983 AVERAGE
F C
SUBCATEGORIES
-------
FIGURE 6
-C»
O
o
H
<£
Id
-------
FIGURE 7
EFFLUENT WASTE CHARACTERISTICS
FOR BOD - 1983 AVERAGE
F G
SUBCATEGORIES
-------
FIGURE 8
EFFLUENT WASTE CHARACTERISTICS
FOR TSS - 1983 AVERAGE
F G
SUBCATEGORIES
-------
4. Influent and Effluent Waste Characteristics vs Mill Age
Efforts to correlate waste characteristics with mill age were also
found to be inconsistent. There appears to be no relationship
between these two variables through linear regression analysis.
There are many external factors that can affect influent and effluent
loading other than age of the mills. Some of these factors may
include raw materials, filler, coating, spills, liquor losses,
temperature variation and size of treatment system.
- 43 -
-------
D. Wastewater Treatment Systems Camionly Employed
All fifty-six (56) mills evaluated in this study employ some type of
wastewater treatment systems for BOD and TSS removal. These systems
basically consist of pretreatment, primary treatment and biological
treatment. Additional treatment processes (i.e., filtration, carbon
adsorption, chemical coagulation) beyond biological treatment was not
found e>fcept for a few mills that use polymers to improve the settleability
of the suspended solids. This section presents a general survey of
the treatment systems employed.
Pretreatment
The study gathered information on the type of pretreatment systems
employed by Region IV mills. Table 6 summarizes the result of
this survey. A total of 23 mills (41%) reported the use of nutrient
addition on a continuous or seasonal basis. These additions are
usually made in the form of aitmonia and phosphoric acid. They are generally
used during low temperature conditions and for biological treatment
systems with lew detention time. Efforts to correlate nutrient addition
to mill subcategory were spotty and no meaningful trends could be
extracted. pH adjustment was practiced in 14 mills (25%) and is not a
common pretreatment practice. In addition, scxne mills have been able
to utilize the neutralizing capacities of their acidic and alkaline
waste component for pH control. Flow equalization and/or the use of a
- 44 -
-------
TABLE 6
PRETREATMEOT OF MILL WASTEWATER PRIOR TO TREATMENT
No. of Mills Practicing
Nutrient Addition 23
pH Adjustment 14
Cooling Tcwer 3
Flow Equalization Basin 1
- 45 -
-------
cooling tcwer are rare practices among the pulp and paper mills in
Region IV. Flew equalization is used to equalize the hydraulic loading
to the treatment system, and cooling towers are used to pre-cool the
influent wastewater tenperature from around 110°F to below 100°F.
Pre-cooling of wastewater is used mainly on a seasonal basis. When
used, both flew equalization and cooling tewers are found predominantly
with the activated sludge treatment systems.
Priirary Treatment
In the primary treatment unit the settleable suspended solids can be
removed by sedimentation, flotation, or filtration. Sedimentation is
the most widely used. Sedimentation can be acccnplished in mechanical
clarifiers with sludge removal or sedimentation lagoons. Our study
found that forty-seven (47) mills use mechanical clarifiers and eight
(8) mills use sedimentation lagoons. One (1) mill uses hydrasieves
for primary treatment. The trend in this industry is strongly toward
the mechanical clarifier. They have been found to be effective in
removing 66% to 85% of TSS and 10% to 35% of BOD frcm the effluent
prior to biological treatment.
- 46 -
-------
Biological Treatment
Biological treatment corrmonly used for BOD and TSS removal are: aerated
stabilization basins (ASB's), oxidation ponds, and the activated
sludge (AS) process. ASB remains the most widely applied type of
biological treatment in Region IV. Table 7 presents the breakdown of
the treatment systems employed by the pulp and paper industry. Forty-one
mills operate ASB's. Three mills have ASB's in series with the AS
process. Five mills operate oxidation ponds. A total of seven mills
operate the activated sludge process, of these, two are extended aeration,
three are pure oxygen and two are air activated sludge plants.
To improve final effluent quality, most of the biological treatment
process had additional settling following aeration. For the 41 ASB
processes, 29 have settling ponds, 3 have mechanical clarifiers plus
settling ponds, and 9 have no additional basins following aeration.
For the 3 ASB/AS processes, 1 has a mechanical clarifier, and 2 have
mechanical clarifiers plus settling ponds. For the 7 AS processes, all
have mechanical clarifiers, of which 3 add polymers when needed to
improve settleability of the suspended solids in the final clarifiers.
- 47 -
-------
TABLE 7
TREATMENT SYSTEMS EMPLOYED BY THE
PULP AND PAPER INDUSTRY
Type of Treatment tfo. of Mills Using
AS (Conventional) 2
AS (Extended Aeration) 2
AS (Pure O2) 3
AS/ASB 3
ASB 41
Oxidation Pond 5
REGION IV TOTAL 56
- 48 -
-------
Final Sludge Disposal
Table 8 .summarizes the type of sludge disposal methods utilized
throughout the industry. Landfill of sludge remains the most widely
used form of final disposal. A total of 25 mills reported the
use of landfill. Sludge lagooning is the second most frequent method
(13 mills). Among other methods utilized are: incineration (6 mills);
land application (4 mills); and recycle (1 mill).
E. Comparison of EPA BPT Design Criteria to Design Criteria Used by the
Industry
In the "Development Document for Effluent Limitations Guidelines and
Standards for the Pulp, Paper and Paperboard", EPA provides the BPT
design criteria for aerated stabilization basins, extended aeration
and conventional activated sludge systems. In this section, a comparison
of EPA design criteria to design criteria used by the mills will be
made in regard to primary clarification, equalization, aeration basins
and secondary clarification.
Primary Clarification
Table 9 shows for primary clarification the overflow rates for the 40
mills range frcm 294 gpd/sq ft to 1049 gpd/sq ft with an average of
500 gpd/sq ft; whereas the BPT criteria is 600 gpd/sq ft. Among the
eight states there is no significant variation in the overflow rate
used by the mills as shown in Table 10 .
- 49 -
-------
TABLE 8
FINAL SLUDGE DISPOSAL PRACTICES USED BY
THE PULP AND PAPER INDUSTRY
No. of Mills Using
Landfill 25
Land Application 4
Sludge Lagoon 13
Incineration in Power Boilers 6
Recycle Back to Process 1
- 50 -
-------
Activated Sludge
There are two mills with conventional activated sludge plants. For
primary clarification, the overflew rates for these plants are compatible
with the BPT criteria as shown in Table 9 . Flew equalization
basins which are included in the BPT design are not available at these
plants. The hydaulic detention time in the aeration basin is 5% lewer
than the BPT criteria at one mill and 40% lewer at the other mill, as a
result, their organic loadings are much higher than the BPT criteria as
shewn in Table 9 . The aeration capacities are close to the BET criteria.
The overflow rates of the final clarifiers are about 30% higher than
the BPT criteria.
Extended Aeration
There cure two mills with extended aeration plants. Only one mill uses
a mechanical clarifier for primary treatment, and the overflow rate
is 14% "higher than the BPT criteria. Flow equalization, which is
included in the BPT design is not available at these two plants. The
hydraulic detention time in the aeration basin is 500% higher than the
BPT criteria at one mill and 20% lewer at the other. Hcwever, the
organic loadings for these two plants are approxinately the same and
they are within the range of BPT criteria as shewn in Table 9 . In
terms of aeration capacity, both plants have lewer capacities than the
BPT criteria. The overflow rate of the final clarifier is 45% lower
than the BPT critiera at one mill and 9% lower at the other mill.
- 51 -
-------
Aerated Stabilization Basin
The hydaulic detention times in the aeration basins range from 1 to 24
days with an average of 10 days; whereas the EPT criteria is 13 days.
Table 10 shows that those mills in Mississippi, North Carolina, South
Carolina and Tennessee have longer detention times than those in
Alabama, Florida, Georgia and Kentucky.
The organic loadings in the aeration basins range fran 0.2 to 7.9 lb
BDD/d/1000 cf with an average of 2.4 lb BOD/d/lOOO cf; whereas the
BPT criteria is 1.13 lb BOD/d/lOOO cf. The high organic loadings are
probably due to the small aeration basin sizes used by the mills.
Table 10 shows that mills in Mississippi, North Carolina, South Carolina
have lew organic loadings (which are about the same as BPT), and they
have relatively long detention times or large aeration basins.
The aeration capacities range from 11 to 68 lbs BOD/HP with an average
of 42 lbs BOD/HP; whereas the BPT criteria is 33.7 lbs BOD/HP. Among
the eight states, there is no significant variation in the aeration
capacity used by the mills. Table 10 shows that mills in Mississippi
have the lowest average aeration capacity.
The detention times in the settling basins range from 0.4 to 100 days
with an average of 17 days; whereas the BPT criteria is 1 day. It
should be recognized that in addition to settling of suspended solids,
the long detention times also provide additional BOD removal and/or
storage capabilities for the mill effluents. Among the eight states,
the detention times vary significantly. Table 10 shews that mills in
Florida, Georgia, and Kentucky generally have the lewer detention times.
- 52 -
-------
TABLE 9
A COMPARISON OF BPT DESIGN CRITERIA TO CRITERIA USED AT MILLS
Activated Sludge
Primary clarification (gpd/sq ft)
Equalization (hours)
Aeration Basin
. Detention Time (hours)
. Organic loading (lb BODs/d/lOOO cf)
Aeration (lb BOD5/HP)
Secondary clarification (gpd/sq ft)
BPT
Design
Average
600
12
8
50
41.8
500
Average
528
6.2
83
47
625
Actual Mill
Minimum
456
4.8
76
38
600
Maximum
600
7.6
90
56
650
Extended Aeration
Primary clarification (gpd/sq ft)
Equalization (hours)
Aeration Basin
. Detention Time (hours)
. Organic Loading (lb BOD5/d/1000 cf)
Aeration (lb BOD5/HP)
Secondary clarification (gpd/sq ft)
600
12
30
18.75 - 37.5
41.8
500
685
84
16.2
28
365
685*
24
14.1
26
274
685*
144
18.4
30
456
Aerated Stabilization Basin
Primary clarification (gpd/sq ft)
Aeration Basin
. Detention Time (days)
. Organic Loading (lb BODij/d/1000 cf)
Aeration
. Organic Loading (lb BOD5/HP)
Settling (days)
600
13
1.13
33.7
1
500
10
2.4
42
17
294
1
0.2
11
0.4
1049
24
7.9
68
100
A.C. - 2 plants
Extended Aeration - 2 plants
asb - 41 plants
-------
TABLE 10
A COMPARISON OF BPT DESIGN CRITERIA TO AN AVERAGE OF TOE DESIGN
CRITERIA USED AT MILLS BY STATES
BPT
Design
Criteria
i
i
Aerated Stabilization Basin
Nmtoer of Mills
Primary clarification (gpd/sq ft)
Aeration Basin
. Detention Time (days)
. Organic loading (lb BOD^/d/lOOO cf)
Aeration
. Organic Loading (lb BOD5/HP)
Settling (days)
600
13
1.13
33.7
1
AL
Avg.
12
511
9.5
2.3
49
25
FL
Avg.
GA
Avg.
3 8
407* 495
6.1
3.3
41
1*
7.9
2.8
46
5.0
KY
Avg.
3
1049*
7.3
2.9
41
6.8
MS
Avg.
3
471
NC
Avg.
5
468
10.6 12.6
1.08 1.66
32 39
17** 12.8
SC
Avg.
2*
560
14
1.8
43
53
TN
Avg.
4
777
1L
3.6
50
18
*1 mill
**2 mills
-------
IV. Performance Evaluation of Existing Treatinent Systems
A. Effect of Operating Parameters on Treatinent Performance
In the previous section, design criteria for various treatment systems
were discussed. This section will examine the sizing of these treatment
systems and determine the actual operating parameters. The operational
parameters will then be compared with BPT design criteria to determine
if the treatment systems were operating within BPT guideline. Also, the
study will attempt to identify and qualify which operational parameters
would have a significant impact on treatment performance.
To initiate the data analysis, survey data on flow, aeration volume,
aeration horse power, final settling volume, influent loading, and
effluent discharge were collected. These data were then used to
calculate actual operational parameters, which consist of aeration
detention time, BOD loading rate, aeration organic loading, aeration
mixing, and final settling. The following pages of this section will
discuss the effects of these parameters for the various type of treatment
systems used by the pulp and paper industry.
Activated Sludge Process
Table 11 summarizes the calculated operational parameters for each
modification of the activated sludge process. Listed in the Table are
the recommended BPT design criteria, actual operational parameters and
the relationship of these parameters to the removal of BOD and TSS.
- 55 -
-------
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17.11
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iwtfarnr
ncnn. puwt dpcmtioml matins rot ebiw iv ml* m ma mas
wt ffinriH cmrin newt in final
remtim kibtiim m mumm w ok umiic m. miim m srmic inwi
WW II* KSIM Ilk* n/IOOO cf/dl BESIBt (Ik* MB/HP/dl DESIH (HP/HtOO cf) BESISN SETTLING MB TSS
2000
0.00 In
1 In
9S.K
30
24.14
41.1
2.294
noM
FC
15 »
2900
(.12 hr*

101.17

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1.(40

FC
17 %
4000
27.79 In
10 hra
11.20
11-37.3
2120
41.0
o.m
nan
FC
71 73
9(0
I07.il In

10.05

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FC
17 70
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MM
16150
mm
121. Ot
MM
1.351
tow
FC
* (7
400
(.19 In

07.00

41.31

2.122

FC
75 30
MS
1(0 In

191.09

7141

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FC
14 94
mt
in*ii
MM
2.76
nam
37.(6
DOT*
0.071
IM
FC
01 91
4990
(.90 toy*

6.41

71.71

0.010

FC«HP
10 99
1200
2.07 toy*

11.72

41.57

0.202

FC»SIMW
14 70
mm
12.49 toy*
11 toy*
0.06
1.13
30.11
42
0.020
now
NDC
00 91
900
191 toy*

1.01

3l.fi

0.231

NM
90 100
900
23.36 toys

4.06

36.10

0.072

MME
90 06
M
l(.Stoy*

1.02

30.01

0.026

KK
¦7 74
2100
10.36 toy*

32.47

0.121

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73 91
em
IS 0tyt

0.00

0.07}

1729
I2.«0(yi

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29.(6

0.036

NK
91 79
M0
14.9* toyi

0.00

0.045

NDC

1100
10.59 toys

1.20

37.M

0.032

NM
13 97
IM0
3.29 toy*

1.14

27.94

0.070

NM
07 1/
¦29
(.17 toy*

2.73

0.000

NK
07 93
2700
11.10 toy*

2.07

34. *

0.051

KK
02 90
2779
11.76 toy*

1.49

17.91

0.013

SP
« 13
I7J7
12.20 toy*

1.33

46.01

0.021

SP
04 09
1790
12.41 toy*

2.16

4146

0.040

SP
07 01
1400
4.(5 toy*

2.11

12.74

0.011

SP
11 90
1000
11(7 toy*

0.*

2175

0.034

SP
76 19
760
27.14 toy*

1.01

16.16

0.064

SP
% 99
1940
23.21 toy*

0.71

21M

0.025

SP
17 %
2900
14.47 toy*

2.61

4110

0.051

SP
09 06
2335
LB toy*

2.07

43.10

0.040

SP
S 94
900
1(1 toy*

4.22

(6.74

0.0(3

SP
93 95
900
111 toy*

170

00.(0

0.072

SP
91 92
4320
11.71 toy*

1.13

2166

0.0(7

SP
93 94
2775
7.01 toy*

2.30

30.15

0.060

SP
16 rt
400
IL7I toy*

1.30

77.76

0.010

SP
09 99
1(00
12.41 toy*

1.15

37.17

0.036

SP
94 95
MO
1105 toy*

6.20

31.71

0.120

SP
90 11
1(0
0.00 toy*

EMI

1700
10.93 toy*

1.(7

30.44

0.021

. SP
M n
3175
17.92 toy*

0.17

9.91

0.090

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93 T>
2030
& 04 toy*

0.73

30.69

0.019

5P
•9 11
1200
14.53 toy*

1.51

44.30

0.034

SP
09 Tl
1(00
7.1( toy*

113

100.13

0.029

SP
95 V
1000
12.23 toy*

7.23

41.10

0.1/6

SP
96 V
1300
1132 toy*

1.51

~o. rt

0.0.17

r.p
% ¦«
1200
1144 toy*

1.03

32. 16

0.0 V

r,p
9J '>«
320
0. II day*

5.21

41. b")

0. I<"j

',p
»> HA
-------
TABLE 11 (CONT'D)
IICTURL PUNT OPEORTIMHL PHWCTUK FOR ICG1W IV PULP M POPED HILLS

flEMTION
TOML
PEHRTIM

AERRTIM

RERRTIOI

FINAL

TUDICNT
aw
itr no
WUK
ABMTION
KIENTIM
OPT HO LOOIIC
IPT
MB LIMINE
IPT
HUIN6
IPT
SETTLING
* DOM
MU. NK
STATE
TYPE
<*|/dl
(lte/dl
(Ml (it*
(HP)
Tilt
KSiai in* mi tooo cf/d>
KS1GK lib* BOO/H>/d)
DES16N
IHl>/IOOO cf)
DESIGN
SETTLING
no
TSS
SIME CONDUm CMP
m
too
22.30
30610
132.30
1100
6.Mday*
1.90

27.74

0.094

SP
03

IMIONOmP
PL
m
33.52
133490
113.00
024
ill day*
10.16

106.23

0.055

SO
95
91
~MrniK* cup
(L
ago
33.32
33664
71.60
900
2.13 day*
3.60

34.76

0.102

SP
91
9*
MTBHiriML MED VIC
m
oiibpm
4.(1
11910
1(4.44 ac

129.40 day*
row 70.50
lbs/ac/day
MM
HR

NR
SP
60
9i
QUB6 ia
a
m» pm
nr
70607
774.90 ac

127.24 day*
91.22
lba/ac/day

SP
»
61
KIMEHV-aJW
sc
an pom
toe
2300
460.00 ac

in. 34 day*
117
lta/ac/day

SP
92
91
IKTERSTATt PMER CMP
m
an mo
i*
7071
630.00 ac

197.30 day*
12.11
lb*/ac/day

SP
93
91
SIDE COmllCR
sc
an pm
12.94
42411
1479.00 ac

2(6.33 day*
20.73
Ito/K/day

SP
92
91
I
t_n
-¦J
I
-------
All values reported are based upon annual average data for 1983. As
indicated.in this Table, there are only a limited number of activated sludge
treatment systems in use by the pulp and paper industry in. Region IV.
Therefore, BFT and statistical analysis of the data with respect to
treatment performance were not made.
Aerated Stabilization Basin
Table 11 also sumnarizes the operational data for the aerated stabilization
basin (ASB) process ertployed by Region IV mills. The study initially was
made on 41 ASB's. Hcwever, 3 mills with ASB's have no influent data
and were excluded from this study. Comparison of BPT design criteria
to the operational data for the 38 ASB's revealed the following results:
24 (63%) operate at a detention time under the recommended period of 13
days: 30 (79%) operate at a BOD loading rate over 1.13 lbs BOD/IOOO
cu ft./day; and 14 (34%) operate at an aeration organic loading over
42 lbs BOD/hp/day. The impact of this on permit and BPT compliance
will be discussed in later sections.
Further studies were then made on each of the operational parameters
to determine which parameters would have a more significant impact on
ASB performance.
Table 11 presents the range of aeration detention time and
its relationship to removal of BOD and TSS. A review of
- 58 -
-------
the data gives no indication of a critical time where treatment performance
either increases or decreases. Overall BOD and TSS removal are slightly
higher for mills operating belew BPT design of 13 days (90% and 92%)
than above 13 days (89% and 90%). The effect of aeration detention
time on BOD removal rate is shewn in Figure 9. No apparent relationship
between these two variables was observed.
The relationship between loading rate and BOD removals are shown in
Figure 10. BOD removal rate at all loading ranges followed a
highly disperse pattern. The lack of correlation indicated a lew
linear relationship between these two variables. For the 31 ASB's,
the correlation coefficient between loading rate and BOD removal were
calculated to be 0.2.
The correlation analysis between aeration organic loading and BOD
removal is shown in Figure 11. BOD removal followed similar patterns
to other operational parameters discussed early. The figure shows a
high distribution of BOD removal rate in all ranges of aeration organic
loading. Statistical analysis of these two variables indicated a low
correlation coefficent vtfiere no apparent relationship exists.
The results of aeration mixing to BOD removal is shewn in Figure 12.
Overall BCD removal is slightly hic^ier as aeration mixing capacity
increases. As a result, aeration mixing does not appear to have a
significant impact on ASB performance.
- 59 -
-------
98
96
94
92
90
88
86
84
82
80
78
76
74
72
FIGURE 9
REMOVAL OF BOD IN RELATIONSHIP
TO AERATION DETENTION TIME
10 14 18 22
AERATION DETENTION TIME (days)
-------
98
96
94
92
90
88
86
84
82
80
78
76
74
72
FIGURE 10
REMOVAL OF BOD IN RELATIONSHIP
TO BOD LOADING
~
*0 D
n O D ~~
~
~
~
~
~
~
~ D ~
CD
VP
D ~ 00
~
T 1 1 1 1 1 1 1 1 1
2 4 6 8 10
BOD LOADING (lbs BOD/1000 cu ft/day)
-------
98
96
94
92
90
88
86
84
82
80
78
76
74
72
FIGURE 11
REMOVAL OF BOD IN RELATIONSHIP
TO AERATION ORGANIC LOADING
D
~
~ ~
~~
o°Dd
* %
~
a
*
a
~
~

~
~
~
i 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1—
20 40 60 80 100 120 140 160 180
AERATION ORGANIC LOADING (lbs BOD/HP/d)
-------
98
96
94
92
90
88
86
84
82
80
78
76
74
72
FIGURE 12
REMOVAL OF BOD IN RELATIONSHIP
TO AERATION MIXING
n
AERATION MIXING (HP/1000 cu ft)
-------
Finally, an analysis was made on the impact of the type of final
settling upon BOD and TSS removal efficiency. Two types of final
settling are used with the ASB process. They are final "clarifier
(PC) and settling pond (SP). Mills with area designated for settling
in the ASB and with no additional treatment following the ASB were
considered to have no final settling for this analysis. A review
of BOD and TSS data in Table 11 shews that mills with final clarifiers
following the ASB generally achieved the highest treatment efficiency (BOD
= 92% and TSS = 92%) than with settling ponds (BOD = 90% and TSS =
92%) or with no settling process following the ASB (BOD = 86% and TSS
= 89%).
Oxidation Pond
The impact of BOD loading rate to the removal of BOD and TSS for the
oxidation pond process are presented in Table 11. Since BPT design
criteria were not available for this process, typical design ranges
(20 to 50 lbs BOD/acre/day) compiled by Eckenfelder^ were used for
performance evaluation. At loading rates under 50 lbs BOD/acre/day,
overall BCD and TSS removal are higher (92% and 98% respectively) than
at loading rate above 50 lbs BOD/acres/day (BOD = 78% and TSS = 80%).
1 Proceedings of Seminars on Water Pollution Abatement Technology in the Pulp
and Paper Industry, EPS 3-WP-76-4; P. 69; Canadian Water Pollution Control
Directorate; March, 1976.
-------
Conclusion
Statistical analysis of various treatment systems performance with BPT
design and operational parameters results in a very lew correlation.
None of the five operational parameters were found to have a significant
impact, if any, on treatment efficiency. It appears that a single
operational parameter apparently cannot be used to characterize the
variability of treatment performance for the three types of treatment
systems studied. A multiple regression analysis of operational parameters
which was not performed in this study may explain some of the BOD and
TSS variations. Also, in defining plant performance other factors can
contribute to treatment variations. These factors may be a result of
human factors, operational and maintenance procedures, sampling procedures,
analytical techniques, and measurement errors. Data on discharge
monitoring report quality assurance programs (Section VI.B.l) revealed
that only 58.5% of mills submitted acceptable data for all parameters
required by their permit in Study 5. The percentage of acceptable data
(success rate) is only 85.8% for Region IV mills. Also, according to
Standard Methods (16th Edition) the coefficient of variation of TSS
measurement can range frcm 0.76% to 33% depending on the concentration of
suspended matter in the sample. For BOD, the coefficient of variation
can range fran 15% to 33%*. Therefore, the precision and accuracy of
these tests may have a more significant impact on the treatment results
since most BCD and TSS treatment performance data fall within a range
of 10% (approximately 84% to 94% removal rate).
^¦Methods of Chemical Analysis of Water and Waste, 83 Edition, EPA 660-4-79-020.
- 65 -
-------
B. Impact of Temperature and Geographical Location on Treatment System
Performance
Impact of Temperature
The impact of temperature on biological treatment system performance
has been demonstrated in many studies. As noted in these studies, a
temperature decrease tends to cause a significant increase in both the
BCD and TSS levels in the effluent. This phenomenon is mainly due to
the decrease in biological activity and the increase of viscosity of
water resulting from a temperature reduction which affects the
settleability of solids.
For this study, treatment system performance was calculated for both
summer and winter conditions to determine the effect of this phenomenon
on Region IV pulp and paper mills. Effluent BOD and TSS data for
winter months and corresponding summer months were compared with the
"average" performance. Sunnier months were arbitrarily determined to be
the months of July through September, and winter months were arbitrarily
determined to be the months of January through March. The "average"
performance was determined by averaging the monthly performance of
each mill over a 24 month period from January 1982 to December 1983.
Table 12 sumnarizes the winter and sunmer variation over the "average"
effluent values for each type of treatment system. Considerably better
BCD performances were experienced in the sunmer months for activated
sludge + aerated stabilization basin (AS + ASB), aerated stabilization
- 66 -
-------
TABLE 12
IMPACT OF TEMPERATURE ON TREATMENT SYSTEM PERFORMANCE
BOD TSS
Treatment Overall Overall
System Sumner* Winter* Variation Sumner* Winter* Variation
CAS - 9% +2% 11% -10% + 4% 14%
EAS +12% +17% 5% -12% +25% 37%
OAS +7% +8% 1% +16% +15% 1%
AS + ASB -21% + 8% 29% -16% + 3% 19%
ASB -23% +28% 51% -14% +15% 29%
OP -10% +20% 30% +31% -10% 41%
Overall - 7% +14% 21% - 1% +9% 10%
~Percent variation from average effluent values:
(-): Percent decrease in effluent values from average
(+): Percent increase in effluent values from average
- 67 -
-------
basin (ASB), and the oxidation pond (OP) treatment system. All these
treatment systems produce a lower percentage of BOD discharge compared
to the "average". The percent decrease in BOD of the "average"
effluent'value ranges from 10% for OP to 23% for ASB during the summer montns.
Looking at the winter data, the level of BOD in the effluent increased
considerably. The percentage increases in BOD discharge over the average
effluent value for AS + ASB, ASB, and OP are 8%, 28%, and 20% respectively.
The overall temperature effect in BOD performance from summer to winter
conditions are a decrease of 29% for AS + ASB, 51% for ASB, and 30%
for OP. For other treatment systems such as conventional activated
sludge (CAS), extended activated sludge (EAS) and oxygen activated
sludge (OAS), the suntner and corresponding winter BOD variations over
the "average" are not as apparent as the other treatment systems
discussed previously. CAS, EAS and OAS all have a shorter detention
time and are not affected by temperature changes as much. The overall
temperature variation in BOD performance from surtmer to winter conditions
are a decrease of 3% in CAS, 5% for EAS and 1% for OAS. With regard
to the TSS f the performance data failed to show any consistent or
significant temperature related trend for the six types of treatment
systems listed. As a result, the temperature effect on TSS performance
did not warrant any definite conclusions.
It can be concluded, hcwever, that temperature does have a bearing on
BOD performance for most treatment systems used by the pulp and paper
industry in Region IV. For CAS's, EAS's and QAS's, the variations were
minimal due to their short detention time (0.1-8 days) and small
surface area. For AS + ASB's, ASB's and OP's, the variations were
more pronounced because of their long detention time (1-268 days) and
large surface area.
-------
Impact of Geographical Location
Removal rates for each type of treatment system located throughout
Region IV were evaluated to determine the difference in treatment
performance among the states. Of the six treatment systems evaluated,
however, only the aerated stabilization basin (ASB) has a sufficient
data base of mills in each state. Performance data for the remaining
treatment systems were not sufficient to warrant any further analysis.
The study investigated average monthly influent and effluent values
over a span of two years for each ASB. Removal rates obtained for
41 ASB's are shown in Table 13. The performance of ASB's are
fairly consistent among the states. Average removal of BOD ranges
from 83 percent in Florida to 95 percent in South Carolina, and average
removal of TSS ranges from 88 percent in Tennessee to 95 percent in
North Carolina. BOD and TSS data in Table 13 are plotted in Figures 13
and 14, respectively. As shown from these graphs, there are no states
that have an overall advantage in BOD and TSS performance. It appears
that geographical location has a minimum impact on ASB treatment
system performance in Region IV states.
Next, the study evaluated for each state the changes in effluent quality
due to seasonal variation. Again, only the ASB treatment system was
considered because of the large data base of mills. Figures 15 to 22
show the seasonal changes in monthly BOD over a period of 24 months for
each state. As indicated from these Figures, seasonal temperature variation*^
- 69 -
-------
TABLE 13
AERATED STABILIZATION BASIN (ASB) PERFORMANCE
IN REGION IV STATES
Percent Removal
STATES BOD TSS No. of ASB
AL 91 94 12
FL 83 94 3
GA 87 92 8
KY 90 89 3
MS 90 94 3
NC 92 95 5
SC 95 93 3
TO 90 88 4
- 70 -
-------
FIGURE 13
ASB PERFORMANCE
FOR THE REMOVAL OF BOO
-------
FIGURE 14
r>o
i
o
e
0.
100
ASB PERFORMANCE
FOR THE REMOVAL OF TSS
-------
have a significant bearing on effluent BOD discharge in the states of
Alabama, Georgia, Kentucky, Mississippi, North Carolina, South Carolina
and Tennessee. These seven states have the highest effluent BOD
discharged during January to March as monthly effluent BOD tends to go
up considerably during the colder months and down during the warmer
months. The only state where seasonal temperature does not cause the
BOD discharge level to vary between sunmer and winter period is Florida.
This is probably due to the fact that seasonal temperature variation is less „
With regard to effluent TSS quality, Figures 23 to 30 illustrate the
effect of seasonal temperature variations in ASB performance for each state.
As shown from these Figures, the monthly effluent TSS discharge was randomly
distributed throughout the year for all states. The lack of consistent
and significant temperature related trends indicates that seasonal
temperature variation has little impact upon effluent TSS quality in
Region IV states.
- 73 -
-------
FIGURE 15
EFFLUENT BOD DATA
FOR ASB IN AL
MONTH
-------
FIGURE 16
EFFLUENT BOD DATA
FOR ASB IN GA
1 1 1 1 1 1 1 1 1 1 1 1 I 1 1 1 1 1 1 1 1 1
1/82 4 8 12/82 4 8 12/83
MONTH
-------
FIGURE 17
EFFLUENT BOD DATA
FOR ASB IN FL
MONTH
-------
FIGURE 18
EFFLUENT BOD DATA
FOR ASB IN KY
-vl
(L O
O 3
Oo
a»£
9
1/82
12/83
MONTH
-------
13
12
11
10
0
8
7
6
5
4
3
2
FIGURE 19
EFFLUENT BOD DATA
TOR ASB IN MS
—i—i—i—i—i—i—i—i—r
82 4 8
i—i—i—i—i—r
12/82 4
MONTH
i—r
i—r
8
i—r
12/83
-------
FIGURE 20
*-sl
KD
i
s
TJ
0.0
o"
oo
3
12
11 A
10 -
EFFLUENT BOD DATA
FOR ASB IN NC
MONTH
-------
FIGURE 21
00
O
Si
_ •
03
oo
w
9
o
EFFLUENT BOD DATA
FOR ASB IN SC
1/82
MONTH
-------
FIGURE 22
EFFLUENT BOD DATA
FOR ASB IN TN
MONTH
-------
FIGURE 23
EFFLUENT TSS DATA
FOR ASB IN AL
MONTH
-------
15
14
13
12
11
10
9
8
7
6
5
4
FIGURE 24
EFFLUENT TSS DATA
FOR ASB IN FL
1 T
i—r
12
i—r
8
i—r
i—i—r
12/82
i—i—i—i—i—i—i—i—r—
4 8 12/
MONTH
-------
19
18
17
16
15
14
13
12
11
FIGURE! 25
EFFLUENT TSS DATA
FOR ASB IN GA
1—i—i—i—I—I—I—I—I—I—I—I—I—I—I—I—I—i—i—i—i—r
4 8 12/82 4 8
MONTH
-------
FIGURE 26
EFFLUENT TSS DATA
FOR ASB IN KY
MONTH
-------
FIGURE 27
EFFLUENT TSS DATA
FOR ASB IN MS
L
' K-S
8 SIS
»
C/>3
9
1/82
12/03
MONTH
-------
FIGURE 28
EFFLUENT TSS DATA
FOR ASB IN NC
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 I I I I I I T
4 8 12/82 4 8 1
MONTH
-------
FIGURE 29
EFFLUENT TSS DATA
FOR ASB IN SC
MONTH
-------
figure: 30
00
l£>

11 -

10.5 -

10 -

9.5 -
V

9 J
£5?

£LO
» j. j
W3
*
go
8 -
9

7.5 -J
EFFLUENT TSS DATA
FOR ASB IN TN
6
1/82
MONTH
-------
C. Compliance Rates for Pulp and Paper Facilities
A discussion of compliance rates can take many forms. Three methods
are used for the purposes of this report: any permit violation, a
significant violation, and a violation of a Best Practicable Control
Technology Currently Available (BPT) limit.
The NPDES permit stipulates the "self monitoring" requirements that
are the responsibility of the discharger. Typically, this portion of
the permit lists each regulated constituent, gives a minimum or maximum
level for the constituent, and describes an applicable monitoring and
reporting frequency. Any violation of a permit limit, monitoring
frequency, or reporting frequency is a permit violation and makes the
facility owner and/or operator liable for civil fines up to $10,000
per day or criminal fines up to $25,000 per day. Therefore, individual
violations are viewed as important.
Significant violations of the permit are used in the NPDES program to
provide consistent information on the compliance status of permitted
facilities and to evaluate changes in compliance status. A facility
with significant violations is defined as being in "significant noncompli-
ance" (SNC) if it meets the criteria of the definitial listed in
Appendix D. The definition of SNC is used as part of the administrative
procedure for screening NPDES self-monitoring data and reporting
instances of noncompliance which are of major concern to a regulatory
agency.
- 90 -
-------
It is important to note that any violation of an NPDES permit is a
violation of the Clean Water Act (CWA) for which the permittee is
strictly liable. The designation of a significant violation indicates
that a violation is of sufficient magnitude and/or duration to be
considered among the regulatory agency's priorities for regulatory
review and response. An agency's decision as to what enforcement
action, if any, should be taken in such cases is based on an analysis
of all of the facts and relevant legal provisions involved in any
particular case.
Finally, a discussion of compliance with BPT limits is important
because all facilities are required by statute to meet BPT guideline
requirements. Permit values are calculated from plant production
levels with the use of nationally promulgated effluent guidelines.
This study will compare actual mill performance with performance
required by BFT guidelines.
1. Industry Performance Compared with Permit Limits
This section discusses compliance in terms of strictly meeting absolute
permit limits. Discharge Monitoring Report (DMR) data for all 56
mills were analyzed to determine the number of mills with permit
violations and the frequency of violations. Table 14 sunmarizes
all instances of permit violations for the pulp and paper industry in
Region IV. Listed in this Table are the permit limits in effect
- 91 -
-------
TABLE 14
WES PEWIT amiflKE ft* RESKM IV PULP M) PWCR HILLS
STUDY PERIOD -• 1/(2 - IJ/4J
mill i
STBTE :
•DUES PEWIT LIMITS j
MHTH.T 06 ILBS/BAY)
HO TSS
ALT» 101 HMD
FL
5310
10631
COKTAltCR COW
FL
US60
21230
m
FL
31500
23000
ST. NE6IS PAPER (CHAW IMTL)
a
3100
13000
mora miiinsf corp
FL
13200
29000
0UEN5 ILL
FL
SIX
107(0
KIWERLY-OAW
SC
3(25
2900
ST OS CONTAINER
sc
11200
24000
(OUTER CRHOLINR
SC
20733
40029
INTEMATIONAL PRPER
9C
19142
31M2

lists

ICSTVRC0 CORP
SC
13014
27000
9MC0 PROUdS
9C
2723
3102
1KTCWATI0NPL PRPER VIC
NS
•422
1«MI
ST. IBIS PRPER (6R-PC1FIC!
K
9B0
22320

780

IKTEWRTIONRL PAPER MIT
W
27493
47395
JRCXSn CO PORT OUTH IP
RB
itoo
1(000

4&S

ICYEMEUBER CO
HB
2130
3124
(OHATER aamON prkr
T*
2SI39
43510
KM CORP
IN
4100
13000

soo

MJM CWTAIIO
IK
4400
(MO
TEW RIVER MLMPRPER
TM
¦700
10900
ALPMM MHFT,8R tUMFT
PL
lUk
13(00

4200

GHflRPIOf HKI
tL
12422
tax
BOLD KM RilLOINB
a
as
9B
GULF STATES PRPER
a.
11214
19431

lOtlfc
1MB
iiwowia PRPER
a
17710
soto
KlMEtLY-aRM
a
71(*/l>
123<*/1>
win crrp
a
11771
21(49
PLABPM RIVER HIP CO
a
7100
19000
ALLIED PRPER, S H1U
a
7190
7101
CONTRIKR CORP
a
WO
11000
Ml OF NO. OF TlltS MKTM.Y MS.
MMT)« PEWIT LIMITS CPE EXCEEDED
OATA HD TSS
MX
TSB
owe wmcw *
MOMLLPR UEKL PL
mn CORP PL
1(000
C7M
1J000
17112
tooeo
7020
21
22
24
24
22
24
24
23
23
24
24
24
21
24
24
24
17
24
24
M
24
24
a
24
24
a
24
a
24
20
21
a
24
0
1
11
0
2
7
1
0
2
»
3
0
3
0
0
0
0
0
It
0
2
»
0
1
1
0
2
1
2
0
0
0
100
100
92
83
100
100
100
100
100
100
too
X
100
13
X
X
100
100
s
94
i«0
*
70
«
100
91
100
«7
100
too
100
100
100
91
X
100
too
100
100
100
100
100
100
100
100
100
100
100
100
100
100
a
100
100
9
MO
100
91
X
90
too
100
100
[MCE
NPDE5
(UNIT
TOTAL
con. i ocx
100
in-c«p
X
OHW
94
WK-CW
92
NOt-COMP
100
itt-cw
100
iK-car
100
IIKOT
100
IN-CWP
100
IN-CWP
100
in-omp
100
UKDV
X
MM-CO*
100
IN-CWP
92
lOt-CWP
X
•OH3MP
X
MM-CMP
100
IN-C0H>
100
91
44
100
92
39
91
93
100
n
X
OS
100
100
100
IN-CIMP
NM-COP
m-cw
NBKWP
M-CMP
IOHW
OKOMP
IOKMP
ItKSV
OKU*
1H-CO*
- 92 -
-------
TABLE 14. (CONT'D)
NPOES PEWIT OWLinCE FDR IE6I(M IV PILP
iN-coe
1N-COV
IIHW
in-cwp
KM-cmp
iM-ca*
MM-CONP
ItKO*
IlKnp
IN-CM*
IIKOMP
MM-CHP
NDM-COMP
MM-C0N>
MM-CB*
MM-CONP
(Ot-cw
IN-CWP
IN-CONP
TOTAL ML OF HILLS i 36
TOTAL NO. OF NILLS IN-CONP ¦ 27
TOTAL NO. OF MILLS IN MM-CONP i 29
- 93 -
-------
at the time of the study and the number of monthly average BOD and
TSS violations. Region IV mills have a total of 164 permit vio-
lations. There are slightly more BOD related violations (93) than
TSS related violations (71). Of a total of 56 mills, 29 mills had
exceeded their permit for at least one month during the 24 month
study period. The compliance analysis of these 29 mills on a
quarterly review basis are shown in Table 15. The Table lists the
number and the percentage of mills with permit violation in any
given fiscal year quarter. For this study, a mill is considered
to be in noncompliance for the entire quarter if monthly permit
limits are exceeded for any one month or more. The violation
frequency ranges frcrt a low of 5 mills in 3rd quarter FY'82 to a
high of 16 mills in 2nd quarter FY'82. The average permit ccmpliance
rate for the eight quarterly periods was calculated to be 82% for
the pulp and paper industry. This rate is derived by averaging
the number of mills not meeting permit limits at a particular quarter
to the total number of quarters studied. Data on permit ccmpliance
for Region IV states are shown in Figure 31. As indicated in this
Figure, permit compliance rates were below the regional average for
mills located in Alabama, North Carolina, and Tennessee.
The 29 mills with permit violations were further analyzed to
determine the extent and causes of noncompliance. Figure 32
shows the number of monthly average BOD and TSS violations by each
fiscal year quarter. For BOD, the highest quarter of exceedance
occurred during the 2nd quarter (January to March) and the lowest
occurred during the 4th quarter (July to September) of each year.
- 94 -
-------
TABLE 15
number of hills not in permit compliance
STATE
ALABAMA
FLORIDA
6E0REIA
KENTUCKY
MISSISSIPPI
NORTH CAROLINA
SOUTH CAROLINA
TENNESSEE
TOTALS
PERCENTAGE OF HILLS IN PERMIT COMPLIANCE
NO. OF
STATE HILLS 2QFYB2 3BFY62 40FYB2 1DFY83 28FY83 3BFY83 46FYB3 18FYB4 OVERALL
ALABAMA
IS
602
932
BOX
801
73X
*71
B71
802
782
FLORIDA
6
471
1001
1001
100X
B3X
831
1001
671
BB1
6E0R6IA
10
802
100X
90X
902
BOX
902
801
801
861
KENTUCKY
3
671
1001
671
till
671
1001
1001
1001
831
MISSISSIPPI
5
BOX
BOX
SOX
100X
801
1001
801
1001
8BZ
NORTH CAROLINA
7
711
711
MX
43X
711
711
711
711
701
SOUTH CAROLINA
4
100Z
100X
1001
1001
031
1001
1001
1001
981
TENNESSEE
4
MX
m
1001
751
75X
751
731
751
751
TOTALS
56
71X
¥11
881
B2X
771
821
862
821
821
- 95 -
NO. OF
HILLS 20FYB2 3QFYB2 43FYB2 1BFY83 2BFYB
l!
10
1
0
0
0
1
2
0
1
56
3
0
1
1
0
4
0
1
10
38FY83 4SFY3J 18FY8
5
1
1
0
0
2
0
1
10
-------
FIGURE 31
NPDES PERMIT COMPLIANCE RATE FOR
REGION IV PULP & PAPER MILLS
82 A
STATE
-------
FIGURE 32
10
cn
z
o
t—
5
o
>
o
z
2Q-FY82
DISTRIBUTION OF ANY PERMIT
VIOLATIONS BY QUARTER
~ BOD VIOLATIONS
1Q—FY83
FISCAL YEAR QUARTER
+ TSS VIOLATIONS
1Q-FY84
-------
They corresponded favorably with the results of the seasonal
temperature impact discussed in Section IV(B). For TSS, the
Figure failed to show any trend. The randomness of TSS violations
over the study period indicated little dependence on the seasonal
tenperature variation.
The causes of noncompliance were found to vary considerably. For this
study, EPA reviewed delegated state's files and identified all
written notices of noncompliance for each mill. Each instance of
noncompliance was grouped together in three general categories.
Those that are treatment plant related, mill process related, or
unknown.
The three categories are then divided into the following subcategories:
1. Treatment Plant Related:
(a) Adverse weather (cold tenperature, freezing conditions,
heavy rainfall, and wind).
(b) Treatment plant problems (malfunction of aerators, hydaulic
or organic overloading, clarifier problems, pump failure,
etc.).
(c) Maintenance or upgrading of treatment plant (cleaning of
ponds, replacing aerators, upgrading or repairing plant, etc.).
2. Mill Process Related:
(a) High liquor losses or spills (high water loss, organic and
chemical losses from bleach plant, evaporator problems,
recovery boiler problems, overflow of process chemicals,
leakage from storage tanks, etc.).
(b) Production process or start-up problems (changing grade
or final product, increased production, adding new process
units, etc.).
3. Unknown:
(a) No information in file.
(b) Problems officially listed as unkncwn.
- 98 -
-------
As Table 16 demonstrates, the most frequently known problems re-
sponsible for 18.3% of the monthly average BOD and TSS violations
were associated with adverse weather or cold temperature. This
was followed by treatment plant problems with 9%, production process
or startup problems with 8%, high liquor losses or spills with 6.7%,
maintenance or upgrading of plant with 5.5%, and power failures
with 2.5%. The breakdown between the three general categories are
32.8% for the treatment plant related, 17.2% for the mill process
related and 50% for the unknown category. Because only 50% of
the permit violations are known and/or properly documented, a greater
emphasis is needed by the mills to document the cause and effect
relationship in treatment plant operations. Of those not known or
documented in the files, 70% occurred at four facilities experiencing
extended violations.
In conclusion, the treatment system performance of Region IV mills
based on meeting absolute permits limit needs to improve. Reasons
for permit violations are both treatment plant related (32.8%) and
mill process related (17.2%). It appears that a combination of
inproved treatment and internal modification will be required to
consistently meet permit guideline requirements. At present,
little attention is paid by the States and EPA to the enforce-
ment of permit violations until the violations become significant
(i.e., covered under the definition of significant noncompliance).
The effect of this policy on the construction and operation of
- 99 -
-------
TABLE 15
MUM CflUSES OF M0NM.Y MB M TSS VIOLATIONS FOR K6I0N IV WLP I PAPER MILS
TWIIIWI PLANT RELATES t
mas mm
IOTA. ML ms PEWIT
STATE OF HILLS VIQUIT I0K fSuL I
Torn. ML OF :
IQD I T9E i
MILL PRESS (ELATED mihiiiiiihiii •
: tOT DOCUMENTED
CONTAIIER
m
ST. BIS
INPL)
adverse mna twtkkt iunt mainihmce or
l HISH LUMP LOBSES MODICTIW PROCESS
VlOLflTIDS i OR OU TO».
UPGRPBIMB OF PUNT : OR SPILLS
OR
OR STARTUP PROBLEMS POER FAILURE : CAUSES UMOOM
soMEOPauns
ST. REEIS NKR (OL-flCIFtCI *
INTEIMTIML PAPER NAT 1
I CO PORT RUIN I INPL P.) 1
«
MUM CONTAIIER
V
1
II
IS
(A KRAFT
OMPIRN PRPER
SOLD KM RJIUINB
UT STATES PAPER
IIRRERMIU. PRPER
KIMKK.V-OAW
OMAHA RIVER RU CO
RU.IO PAPER, S MILL
OMTA1IE* COMP
MOilLE HATER SERVICE, IP
SOffT PAPER, NOillE HIU.
I
4
2R
1
I
3
3
I
5
4
Z
20
1
10
sine comma cohp
rhumb nlp t paper
HUM PRPER
6
13
I
Kl
MUJKTTE !• IINMFT
10
TOTAL
ALMA CELUUBE
FQERRL PAPER
NEYEMEUBER
IEVERHAEUSER
CWMPIOK ARPERS
m
h
29 (32 *>
TDTDL
3
24
3
I
I
164
31 120.1 *)
IS 19 *>
9 <3.5 <>
II 16.7 Kl
13 (8 »>
4 12.5 *1
4
22
4
I
79 146.1 1)
-------
waste treatment facilities is to use as a compliance base 140% of
permit limits for BOD and TSS as opposed to the permit limits
themselves. EPA should ensure that States address all permit
violations in keeping with their Enforcement Management System.
- 101 -
-------
2. Industry Performance Compared with Definition of Significant
Noncompliance
The definition of significant noncompliance (SNC) plays an
important role in the regulatory agencies' enforcement evaluation
procedure. It is used as a screening tool to identify all instances
of noncompliance that are of major concern to enforcement
officials. It is also used for all reporting of noncompliance in
the NPDES program to EPA, the public, and Congress. EPA defines
SNC as violations that exceed the Technical Review Criteria (TRC)
over a review period of 3 to 6 months. For BOD and TSS, the TRC
is 40% over the permit limit. Facilities that have discharges
over the TRC range would be considered in SNC. In some cases, a
facility will constantly violate the monthly permit limit but not
exceed the TRC. These chronic violations would be considered
SNC if monthly permit limits were exceeded by 4 months in 6 months.
Based on these criteria, the study revealed that 6 of 29 mills
that exceeded their permit limits were considered to be in SNC.
Table 17 presents the mills that met EPA's definition of SNC. The
Table lists the permit limits, the total number of permit violations,
the number of times permit violations were significant, and the
quarters the mills were in SNC. Mills that meet EPA's definition
of SNC are noted as being in non-conpliance with the definition
for this analysis. No mills were in significant nonqctnpliance
- 102 -
-------
TABLE 17
COMPLIANCE STATUS OF REGION IV PULP AND PAPER MILLS USING EM'S DEFINITION OF SIGNIFICANT NONQMHIflNCE <9C)
STUDY PERIOD ; 2nd BURRTER FISCAL YEAR 82 TO lit QUARTER FISCAL YEAR 04 (1/02 - 12/63)
O
U>
Mia NMC
STATE
I NPOES PERMIT LIMITS :
l R0NTM.Y AM6 ILK/MY) :
I ROD TSS t
i :
NO. OF
MONTHS
DATA
TOTAL NUNER OF N0NIM.Y
(WEARS PERMIT VIOUTIK
ROD TSS
NO. OF TICS PEWIT
VIOLATIONS HERE IN SNC
DOD TSS
NO. OF
BUARTERS
IN SNC
QUARTERS
IN SK
w. of coaamvE
OURRTERS IN SNC
ten epa INT'LI
a
9100
13000
24
4
0
0
0
0

0
NO
IN-COHP
BUDtm milllBF CORP
a
13200
23000
22
0
0
0
0
0

0
NO
IN-COHP
OMENS ILL
a
91X
10710
24
0
0
0
0
0

0
»
IN-COHP

a TOTAL :
"T~
KIMBLY-GLMK
sc
sa
2900
24
0
0
0
0
0

0
NO
IN-OMP
STO* CONTAIICR
sc
11200
24000
23
0
0
0
0
0

0
NO
IN-COHP
BOWTER CAROLINA
sc
20733
40829
23
0
0
0
0
0

0
«
IN-COHP
INTEIMTian. PAPER
sc
19142
31082
24
0
0
0
0
0

0
«
IN-COHP

11363

UESTVACO CORP
sc
13014
27000
24
0
0
0
0
0

0
NO
iN-cmp
SONOCO PMOUCTS
sc
2723
9ioe
24
1
0
0
0
0

0
NO
IN-COHP

SC TOTAL :
t
INTERNATIOML PAPER VIC
NB
1422
10040
21
0
0
0
0
0

0
n
IN-COHP
ST. AEGIS PAPER ISA-PRCIFIC)
16
9990
22320
24
4
0
1
0
0

0
NO
IN-COHP

7200

INIERNATtONAL PAPER NAT
C
27493
47395
24
1
0
0
0
0

0
NO
IN-OMP
JACKSOI CO PORT AUTH IP
NS
(COO
10000
24
1
0
0
0
0

0
»
IN-COHP

4(39

ICYERHAEUSER CO
IB
2130
3124
17
0
0
0
0
0

0
NO
IN-COHP

m TOTAL :
_5
ROHATER SDUTKM PRPER
TN
29039
43910
24
0
0
0
0
0

0
NO
IN-CMP
IBS CORP
TN
4100
13000
24
1
0
0
0
0

0
m
IN-COHP

sot

INJM CDNTAIICR
ID
4400
KOO
24
11
1(
2
14
(
30FY82 1 1SFY83-1SFY84
5
YES
NON-COHP
TEM RtVCR WLPMAPER
TN
1700
10900
24
0
0
0
0
0

0
NO
IN-COHP

TN TOTAL :
4
ALAMO) WINFT.GA KMFT
ft.
UJL
13000
23
1
0
0
0
0

0
NO
IN-COHP

4200

~«NPI« PAPER
AL
12422
21376
24
2
2
2
1
1
3RFY03
0
YES
NON-CONP
BOLD MM RUILOING
RL
383
383
23
7
21
4
IS
6
2VY12 - 10FY04
0
YES
NON-COHP
GULF STATES PAPER
RL
I121(
19439
24
1
0
0
0
0

0
NO
IN-COHP

10216
10439

MMDWILL PAKR
AL
17710
3(000
24
0
1
0
0
0

0
NO
IN-COHP
KIMERLY-ClA*
AL
71(^/1)
I29<*/I1
23
2
1
0
0
0

0
NO
IN CMP
UWMCRNP
AL
11771
21(49
24
0
0
0
0
0

0
NO
IN-CONP
AUVAHA RIVER U.P CO
AL
7200
15000
23
3
2
1
0
0

0
NO
IN COHP
ALLIEB PAPER, S Hill
AL
7150
7100
24
0
1
0
0
0

0
NO
INtCMP
CONTAIICR CORP
AL
(0(0
11000
20
3
2
1
0
0

0
NO
IN COHP

4450

DIKE NDRTICRN (JAMES RIVER)
RL
1(000
11000
21
0
0
0
0
0

0
NO
IN CflNP
MRCMILLAN RUKKL
RL
0390
17112
23
0
0
0
0
0

0
NO
IN COHP
-------
mm IttM
TABLE 17 (CONT'D)
CONSUME STATUS OF REEION IV PULP M MCR MILLS UG1K EIWS DEFINITION OF SIWIFIOMT MHXHUfME (SNC)
MU. I
STWI
I iptES PERMIT UMTS
i MM1H.Y AW (IK/MV)
l U TSB
O
¦F-
MBILE NR1ER SERVICEUNTL PI
AL
14726
26909
SCOTT PRKR,M»Il£ MILL
RL
22177
31463
STOK CWTAIIO CORP
GR
6700
10700
~MTIIOTAL FOREST (FEI.PRPER)
GR
27111
499R2
M1ERSTRTE PAPER CORP
BR
1100
|M
2054
souncm paper we
GR
RW
3000
3363
IMONCAW
BR
23000
40400
¦nana pulpmwer
GR
13440
39300

issoo

BQKia KRAFT
GR
10B2R
24624

5071

6ium PRPER
GR
12000
24000
GREAT SMICM PRPER
BR
19360
22700
ITT NMNIEl
BR
30000
42010

22)01

M5IVAC0 FIIC PRPERS
KY
moo
•000
MUACTTE IW KB MIX
KY
4043
3B0

2343

MLUICTTE IM II KRAFT
KY
10626
1366*

tfOI
6432
ALPHR CaLULOGE
NC
132
3B
FEKRRL PRPER KURD
NC
3000
42700
lEVEMABEER M
NC
3300
•230
ICYERHABJSER PL
n:
2294
41139
DVMPIW PRPERS
m:
•094
43443
MERNER WUBRF - OMP IHTL
K
6720
14400
OLM CORP tECUBTR CMP)
NC
6317
13601

43S7
10963
: STIDV 10100 : 2nd BURRTER FISCAL TERR 12 TO tit BURRTER FISCAL TEAR M (1/(2 - 12/831
I
I ML OF
: HMDS
¦ vm
i
TOT*. NMER V Mm*.!
: PERMIT VHLRTHMG
TSB
ML OF TUES PEWIT
VIOLfiTIK (CAE M 9C
MB TSB
ML OF
OURRTERS
IN SNC
OURRTERS
IN SMC
ML OF CONSECUTIVE
OURRTERS IN SNC
KET EPfl'S
DEF1NITIW CWPllAMX
OF SNC STATUS
24
24
24
24
24
24
24
24
24
24
21
24
24
2
0
0
0
0
10
2B-3BFYS3 I 10FYM
2BFYI3
Ml
M)
PL TOTAL
MI-
ND
NO
NO
NO
YES
Ml
NO
NO
NO
GR TOTAL
M)
NO
YES
KY TOTAL ;
IN-C0NP
IN-CONP
15
iN-aw
IN-CONP
IN-CONP
IN-C0NP
in-cwp
NON-CONP
IN-CONP
IN-COMP
IN-CONP
IN-CONP
IN-CONP
IN-CONP
NON-CONP
21
3
2
0
0
0

0
Ml
IN-CONP
24
24
0
19
0
B
2GFYI2 - 1IFYS4
8
YES
PDN-CONP
23
2
3
1
0
0

0
NO
IN-CONP
24
1
0
I
0
0

0
Ml
IN-CONP
24
1
0
0
0
0

0
NO
IN-CONP
24
0
0
0
0
0

0
NO
IN-COMP
IN-COMP : li
NON-CONP :
NON-CflHP : I
-------
during the study period in Florida, Mississippi, and South Carolina.
The 6 mills with instances of significant noncompliance during
these 8 fiscal year quarters are as follows:
Champion Paper
Gold Bond Building Products
Brunswick Pulp & Paper
Federal Paper Board
Inland Container
Willamette Ind. (W. Kraft)
Alabama
Alabama
Georgia
North Carolina
Tennessee
Kentucky
Table 18 presents data on the percentage of pulp and paper mills
not in significant noncompliance over a span of eight fiscal year
quarters frcm 2nd quarter 1982 to 1st quarter 1984. Also, presented
is similar data on all major industrial facilities in EPA Region IV.
The quarterly significant noncompliance rate for this analysis is
based on the number of mills not meeting EPA's definition of
noncompliance divided by the total number of mills. By this
measure, the pulp and paper industry has excellent SNC compliance
rates. The overall compliance rate for this industry is 94% versus
91% for all major industries. Of the eight quarters studied,
Figure 33 shows the pulp and paper industry met or exceeded
overall EPA Region IV compliance rates in six quarters. Data on
SNC carpiiance for each state are taken from Table 18 and are
plotted on Figure 34 through Figure 41. These graphs compare
the SNC compliance rate of the pulp and paper industry with the
other major industries by each Region IV state. With the exception
of North Carolina and Tennessee, most states have a higher SNC
compliance for pulp and paper industry than the other jnajor industries.
- 105 -
-------
TABLE 18
8W&TERLY COMPLIANCE RATE OF THE PULP AM PAPER INDUSTRY NITH MAJOR INDUSTRIAL FACILITIES INSE6ION IV
PULP AND PAPER INDUSTRY
Z NOT IN SIGNIFICANT NONCOMPLIANCE
NO. OF
STATE MILLS 2&FY62 36FY82 48FY82 16FY83 2BFY63 30FYS3 4QFYB3 lflf¥84 OVERALL
ALABAMA
15
93
93
93
93
93
87
93
93
92
FLORIDA
6
100
100
100
100
100
100
100
100
100
GEORGIA
10
100
100
100
100
90
90
100
90
96
KENTUCKY
3
100
100
100
67
100
100
100
100
96
MISSISSIPPI
3
100
100
100
100
100
100
100
100
100
NORTH CAROi-INA
7
06
84
86
86
86
86
86
86
86
SOUTH CAROLINA
6
100
100
100
100
100
100
100
100
100
TENNESSEE
4
100
75
100
75
75
75
75
75
81

"*54

95
Tt
93
93
—
~~95
93
94
MJDR INDUSTRIAL FACILITIES
2 NOT IN SIGNIFICANT NONCOMPLIANCE
NO. OF
STATE
FACILITIES
26FY82
3QFY82
4SFYB2
1BFY83
28FYB3
36FY83
4SFY83
1BFY84
OVERALL
ALABAMA
122
92
88
91
94
96
95
90
90
92
FLORIDA
115
87
90
97
97
96
98
94
98
95
GEORGIA
62
91
92
91
94
91
94
92
92
92
KENTUCKY
179
77
U
92
82
90
91
96
98
89
MISSISSIPPI
40
BO
87
90
90
90
92
85
87
88
NORTH CAROLINA
127
95
94
97
97
96
96
92
94
95
SOUTH CAROLINA
119
94
91
93
92
92
92
96
97
93
TENNESSEE
75
63
91
92
93
BS
85
87
85
85

i§i

~~90
93
92
93
93
93

"""92
- 106 -
-------
figure: 33
o
Ixl
o
z
<
-J
CL
25
o
o
z
LU
o
on
Ul
Q-
COMPLIANCE ANALYSIS OF P&P INDUSTRY
10D
WITH MAJOR INDUSTRIAL FACILITIES
90 -
80 -
70 -
60
50
2Q-FY82
~
1Q-FY83
FISCAL YEAR QUARTER
P&P INDUSTRY + MAJOR IND FAC
1Q-FY84
-------
FIGURE 34
COMPLIANCE ANALYSIS - ALABAMA
100
o
00
III
O
Z
<
-I
-------
COMPLIANCE
o
vO
111
O
z
2
O
o
z
hi
O
OC
Ul
Q.
100 -B
90
70 -
60 -
50
2Q
—T~
3Q
—r~
40
~ P*P INDUSTRY
FIGURE 35
ANALYSIS - FLORIDA
-e-
r~
1Q
—r~
20
—i—
30
—r~
40
10
QUARTER
+ MAJOR IND FAC
-------
COMPLIANCE
ui
o
100 •»
90 -
0
1
O
O
80 -
Id
O
ft
UI
IL
70 -
60
50
—r~
4Q
2Q
I
3Q
~ PAP INDUSTRY
FIGURE 36
ANALYSIS - GEORGIA
10 2Q 30 40 10
QUARTER
+ MAJOR IN0 FAC
-------
FIGURE 37
COMPLIANCE ANALYSIS - MISSISSIPPI
~ P&P INDUSTRY
QUARTER
+ MAJOR IND FAC
-------
FIGURE 38
COMPLIANCE ANALYSIS - KENTUCKY
100 ¦»
K>
hi
O
~
a.
2
O
a
z
hi
O
a
hi
a.
PAP INDUSTRY
QUARTER
4- MAJOR IND FAC
-------
FIGURE 39
COMPLIANCE ANALYSIS - NORTH CAROLINA
100
(JO
Ul
O
Z
<
-J
-------
FIGURE 40
COMPLIANCE ANALYSIS - SOUTH CAROLINA
100 -»
4>
t
LI
o
~
0.
2
O
O
I-
z
UJ
o
0c
Ui
IL
o P&P INDUSTRY
QUARTER
+ MAJOR IND FAC
-------
COMPLIANCE
100 -B B
t—1
Ln
UJ
o
z
<
~
OL
2
O
O
z
UJ
o
K
u
OL
90 -
80
70 H
60 -
50 -| 1 1
2Q 3Q 4Q
D P&P INDUSTRY
FIGURE 41
ANALYSIS - TENNESSEE
I
1Q
I
2Q
I
30
4Q
1Q
QUARTER
+ MAJOR IND PAC
-------
To sunmarize SNC compliance, compliance rates from Table 18 are
plotted on Figure 42. The Figure illustrates the compliance
status of Region IV states using EPA's definition of SNC. Three
states have compliance rates below the regional average of 94%.
These states are Alabama, North Carolina, and Tennessee with
percentage of mills not in SNC shown as 92%, 86%, and 81% respectively.
- 116 -
-------
FIGURE 42
COMPLIANCE STATUS OF REGION IV MILLS
WITH EPA'S DEFINITION OF SNC
100
94 AVG
-------
3. Industrial Performance Compared with Best Practicable Control Technology
Currently Available (BPT) Limits
On May 25, 1974 (Phase I) and on January 6, 1977 (Phase II), EPA
published final effluent guidelines for the pulp and paper industry
(40 CFR Parts 430 and 431). The guidelines require all subcategories
of the industry to incorporate Best Practicable Control Technology
Currently Available (BPT) treatment levels for discharge into
surface waters. The BPT limits are based on the average of the
best existing performance of the treatment system within the
industry or subcategory. This average is not determined on a
broad range of values, but upon performance levels achieved by
exemplary plants of various sizes, ages, and treatment units. In
setting the monthly permit limits under the BPT guideline, EPA
gathered data on long term average performance levels for these
mills for each product subcategory. EPA then determined performance
relationship between maximum month levels and long term average
levels. The resulting ratio between maximum month and long term
average (variability factors) were then applied to the long term
average data to determine the monthly average BOD and TSS limits.
These limits represent BPT performance, and are values that should
rarely be exceeded by the mill. By statistical analysis, EPA
defined this value as the 99th percentile probability of occurrence.
The 99th percentile represents a pollutant discharge level between
which 99 percent of all pollutant discharge values fall.
For this analysis, the 99th percentile will be used to determine
conformance with BPT limits by the pulp and paper industry in
Region IV. By using the monthly average data from the discharge
- 118 -
-------
monitoring report (DMR), a mill is considered to be out of conformance
with BPT if that mill exceeded BPT limits more than once in 100
months. Therefore, any monthly BOD or TSS violations over the 24
month study period by the Region IV mills would be considered as
nonconformance with BPT guideline limits under this criteria.
The study obtained actual production figures from each mill as
part of the data gathering effort for the On-site Technical Inspection
Report (See Appendix B). The highest 12 consecutive months of
production were collected for a 5-year period from 1979 through
1983. This production figure (expressed in air dried ton/day) was
irultiplied by the mass discharge limitation (expressed in pound/1000
pound of product) listed in the effluent limitation guidelines to
establish a BPT limit in pounds of pollutants per day. EPA compared
the resulting BPT limits to the effluent discharge in the Discharge
Monitoring Reports (DMRs). Table 19 presents a listing of the
56 surveyed mills showing the number of times the EPA calculated
BPT limits were exceeded by Region IV mills. Mills with discharges
that exceeded these limits were noted as not meeting BPT guideline
limits in the Table. Of a total of 56 mills studied, 19 mills
(35%) did not conform to BPT limits and 1 mill was not evaluated.
This mill was not evaluated for conformance with BPT because no
guidelines were available for the cotton linter pulp subcategory.
There were more mills that failed to conform to BPT limits for BOD
(16) than for TSS (9). These figures are not surprising since
seme mills have higher organic loading to the treatment system
than the recommended range for BPT. Comparison of the 13 mills
- 119 -
-------
TABLE 19
ffiSE99CMr OF am-lMCE WITH BEST PRACTICABLE cwrm. TEMeUBY CURttNTlY AVAILABLE (BPT) lIMTS for RE6IW IV PULP MC PAPER HILLS
hUi
STATE
: HIGH '79—'S3
i PRODUCTION
t IADT/D)
PRODUCTION
by product
SUBCATEGORY
ALTW BOl HMD
~MTAItER COUP
m
ST. AESI5 PAPE*
(CHAMP. INTL CORP)
BUCKEYE milinRF COOP
HOC ILL
KIMBLY-CLANK
STOC CMTAIICR
BOUATER CAROLINA
INTEMATIOML PAPER
ICSTVKO GOV
BDMC0 PRODUCTS
intentional wed vic
ST. REBIS PAPER
MA.-PACIFIC CORP)
IKTDWATIQNRL PAPER NAT
JACKSON CO PORT AUDI IP
MEYEMSJKR CO
KMATER 90UTKM PAPER
m» COW
HUM CWTAKO
TEW RIVER PULPtPAPE*
ALAMNA KRAFT, BB KRAFT
CHANPION PAPER
OLD BOB BUILDIM
BULF STATES PAPER
KimatY-am
(JIIIN2**
MM* RIVER WLP CO
ALLIED PAPER,S KILL
aMTAIIER CORP
dixie wnoi itc
a
FL
FL
a
a
a
x
sc
X
sc
X
«
m
m
m
m
IN
TN
T*
TN
a.
«L
Rl
RL
RL
AL
RL
RL
731.00
1977.00
~92.00
1093.40
1319.00
1000.00
239.60
1550.00
1679.00
1720.00
234100
<32.00
1307.00
1679.30
1233.00
<61.30
710100
2260.70
663.00
535.00
17(7.50
1111.00
1391 JO
20*.00
71100
1016.30
1U9.00
2173.00
1074.00
631.00
1I9L00
1019.00
Ai 791.0
Dil997.0
Ki 492.0
A> 817.3
Hi 276.1
Fi1319.0
Ai1000.0
Si 130.6
Tt 109.0
Ai1330.0
61 676.0
Hi 237.0
11 161.0
Rl 142.0
Ml 404.0
Oi 39.0
011363.0
Hi 337.0
Ai2341 0
It 116.0
E< 734.0
As1307.0
Ai 16713
Fi 736.0
61 497.0
Hi 861.3
Nt 335.0
Ri AO
Hi 723.2
Li 243.9
Hi 6214
Ni 663.2
Pi 3710
Hi 217. •
ll 533.0
Ai 1633.1
El 133.7
Ri2171.0
111339.3
KUdara f^mr
Hi 317.0
Bi 90.0
Oi 32.0
It 1016.3
Ni 7319
B) 6212
Hi 39S.3
Ri 106.9
AI2173.0
Bt1074.0
Ii 631.0
Ai SK.0
Hi 632.0
Hi1019.0
:~ HIGH '79-'S3 PROD • :
:~ BASES BPT LIMITS • :
:• BOD TSS • s
:• « :
4430
13976
27000
MSB
32316
3600
3431
<660
21324
16132
14347
3137
1216B
17291
7194
12460
14979
9492
24963
23000
16931
12000
3312
16600
40962
31873
30744
MSI
26032
33227
13364
23962
26096
ML OF
pome
DATA
IT
22
24
24
22
24
24
23
23
24
24
24
NO. OF TIICS KNTH.Y RV6.
BPT LIMITS WERE EXCEEDED
BOD TSS
24
23
24
20
21
9
0
3
0
0
0
0
0
0
1
0
1
0
0
0
0
0
0
OiKturgc
BPT Lmtt
BOD TSS Both
"5 IE «
YES YES YES
NO NO «
YES YES YES
YES YES YES
YES YES YES
YES YES YES
YE5 YES YES
YES YES YES
YES YES YES
YES YES YES
YES YES YES
<439
INK
21
0
0
YES YES YES
9404
20132
24
4
0
W YES Ml
2(741
473B9
24
2
1
9
9
9
12236
22231
24
0
0
YES YES YES
3124
4199
17
0
0
YES YES YES
26331
49MB
24
0
0
YES YES YES
7706
13224
24
0
0
YES YES YES
4260
3330
24
11
20
K) NO NO
no
20273
24
0
0
YES YES YES
1614
14172
23
1
0
N> YES »
17132
37111
24
2
0
NO YES NO
1192
1192
23
3
4
h n a
1M0B
20122
24
0
0
YES YES YES
16773
34361
24
0
0
YES YES YES
23312
44771
23
1
I
NO M) Ml
YES YES YES
YES YES YES
YES YES YES
NO YES M
YES YES YES
- 120 -
-------
TABLE 19 (CONT'D)
AGSESGKNT IF CORIMZ WITH BEST PRACTICABLE COfTHDL TEDML06V CURRENTLY flVAIUMi IBPT) LIMITS FOR IEEI0N IV PU.P WO PAPER NILLS

H1BH 'TV83
PRODUCTION
:t Him '79-'83 PROD « :
NO. OF
«. of tiks nmtY as. •.
Diichv-ft torts ;

punrriw
by prooutt
:* BAGED BPT UNITS * :
MONTHS
BPT LIMITS HERE E1CEEEED :
BPT Liaiti
MILL nam
STATE
(flOT/D)
SUBCATEGORY
it BOD
:*
TS6 • :
» •
DATA
BOO
TSE
BOO TSS Both :
ones mvgi corp. >

MCMILLAN BLDEBEL
RL
1438.00
At 1141.0
11091
20984
23
0
0
YES YES YES

Dt 467.0

El 230.0

CAD CORP
AL
957.50
Bt 938.1
4330
10633
24
0
0
YES YES YES

Et 19.4

NBILE HATER SERVICE
PL
17*3.00
Ai 705.0
16401
31773
24
4
0
NO YES NO
UNTEiMTian. paper)

Hi 526.0

I: 234.0

Ml 54.0

Nt 204.0

scon PAPER, KBILE MILL
AL
1924.60
Hi 978.2
23164
9084
24
0
0
YES YES YES

Ii 946.4

STDC COMTAItCR COW
BA
936.00
Ai 936.0
5242
11232
23
9
0
« YES W
CGHTlMENTn. FOREST IK)
BR
1612.00
Hi 1132.0
21463
39460
24
0
0
YES YES YES
(federal prper torn)

Mi 100.0

Nl 350.0

Si 30.0

INTERSTATE PAPER CORP
BR
St. 00
At S1.0
3046
66U
24
0
0
YES YES YES
souneei paper m
BR
SL»
Hi 26.4
9727
13417
24
0
0
YES YES YES

Bi 501.8

UNIIMCMP
BA
3144.00
DI2966.0
24906
34406
24
0
0
YES YES YES

Et 214.0

(PART *54) Dl 466.0

(RAIT
454)C| 14.0

HUeuia MMPAPER
BA
1806.00
Bt 1427.0
24357
56344
24
0
2
YES NO NO

Ht 179.0

GE0R6IA KRBFT
BA
1991.00
Ai1991.0
11150
23492
24
0
1
YES NO NO
6ILNAN PRPER
BA
1234.00
Ai 711.0
12547
24296
24
0
1
s
8
8

Hi 523.0

BRERfT SOUnCM PRPER
SA
2673.40
D12S75.4
21403
33443
24
0
0
YES YES YES
ITT AATOIIEJ!
BR
1373.00
ft 640.0
30869
3(412
24
0
0
YES YES YES

Bi 913.0

CSTVPCO FIH PAPERS
KV
747.00
It 747.0
9711
1777B
21
0
0
YES YES YES
WILUKTTE IW MB) MILL
KY
334.00
Di 354.0
2464
4473
24
1
0
NO YES K)
UlLLftCTTE IN) U KRAFT
KV
603.00
Bi 603.0
9950
aoooe
24
4
0
» YES tO
RUH) railing
IC
132.10
COTTOI LINTER PULP NO BPT BUHELIICS
21

nx in in*
FEKRAL PRPER BOARD
NC
1984.00
8l 964.0
30111
34327
24
0
0
YES YES YES

Hi 10(0.0

CYERHREUBER M
NC
825.00
Bi 825.0
13243
27060
23
0
0
YES YES YES
ttKBWQBER PL
NC
2216.00
Di 616.0
22608
44172
24
1
0
NO YES NO

El 345.0

Bi 3BI.0

It 874.0

ORMP10H PRPERS
K
111100
Si 44.0
22944
46470
24
0
0
YES YES YES

Hi 706.0

Ii 933.0

HH4CR MALDORF-GIWP. INTL
NC
1KB. 00
AiM&O
6006
12770
24
1
0
ID YES NO

El 70.0

(LIN CORP (EQSTA CORP)
IC
391.00
II 93.0
6432
8269
24
0
0
YES YES YES

Ri 116.0

Ii 126.0

TDTiL IC OF NILLS : 36

CELLOi 63.0

TOTAL NO. OF NILLS COrOIMINB TO
BPT LIMITS : 36

TOTAL ML OF HILLS NOT CDFOMINB TO
IPT LIMITS i 19

» NO BPT LIMITS i 1

- 121

-------
with ASB process not meeting BPT limits to the operational
BOD.loading parameter in T&ble 11 showed at least 8 mills (62%)
have BOD loading higher them the recommended loading of 1.13
pounds of BOD/1000 cu ft/day on an annual average basis, it)
inprove the BPT conformance rate, seme Region IV mills mi^rt need
to implement additional internal control measures to reduce the
amount of loading to the treatment system and/or modify treatment
systems to accomodate the increased load.
The overall BPT carpliance rate was calculated to be 65% (19/55)
for the entire 24-month review period. A 24-month review period
instead of a quarterly review period was utilized in this case
because of the 99th percentile criteria (cue violation in 100 months).
Figure 43 illustrates the BPT carpliance status for Region IV
states. There are 4 states, which fall below the regional average
of 65%. BPT conformance rates for these states are 60% for Alabama,
60% for Georgia, 33% for Kentucky, and 60% for Mississippi.
- 122 -
-------
FIGURE 43
COMPLIANCE STATUS OF REGION IV MILLS
G
U)
in
i—
CL
m
o
H
O
2
K
O
o
o
100
WITH BPT LIMITS
65 AVG
-------
D. Performance Required to Meet BPT Limits
In light of the fact that only 65% of the mills in Region IV can
conform to BPT guideline limits, the study examines the question of whether
higher levels of BCD and TSS reductions are needed for this industry
to meet BPT limits. Previous inflow data (Table 5) and BPT guideline
limits (Table 19) were used to calculate the percentage Removal necessary
to meet BPT on an annual basis. The resulting BPT performance is
compared with the 1983 influent and effluent performance data from
Table 5 for each product subcategory. These comparisions are
are summarized in Table 20. This Table lists the product subcategory,
the number of mills in each respective subcategory, the actual percent
removal, and the percent removal required to meet BPT limits. Again,
only "primary" mills producting one product are considered. Fran
Table 20, it can be seen that BPT guideline limits call for treatment
efficiencies in the range of 52% to 90% for BOD and 46% to 89% for TSS.
The average performance compared to BPT performance is illustrated in
Figure 44 for BOD and Figure 45 for TSS. As shown in these Figures
most mills in each subcategory can achieve the necessary reduction of BOD
and TSS required to meet BPT. The only exception was TSS in the
semi-chemical subcategory (B). However, this product subcategory
contains only one mill, and should not be considered representative of
the subcategory. In conclusion, the data showed that despite the inability
of same individual mills to meet monthly BPT limits as discussed in
the previous compliance section, the annual average performance of
mills in most subcategories was well within the range required to meet
BPT limits on an annual basis. It seems that the overall performance
of mills in each subcategory as a whole is sufficient to achieve BPT
guideline limits on a long term basis. However, additional treatment
capacity may be needed to handle the peak monthly variations.
- 124 -
-------
TABLE 20
ACTUAL PERFORMANCE COMPARED TO PERFORMANCE REQUIRED TO MEET BPT LIMITS
No. of Actual Performance Required
Sub Mills Performance to Meet BPT Limits
BOD TSS BOD TSS
A 10 88 90 75 71
B 1 90 77 90 89
D 3 90 90 77 73
F 1 88 91 52 70
G 4 88 84 76 46
H 2 92 87 81 61
I 3 95 96 88 75
K 1 73 91 68 67
- 125 -
-------
FIGURE U
ACT % REMOVAL VS % REMOVAL REQ
TO MEET BPT LIMITS FOR BOD
100
90 -
80

VA
70 -
60
50 -
40 -
30 -
20 -
to H
0

¦N
N

N
N
\J
N
\
J
P7:
Z
A
\
\
\
\

\
\
\
2K
ABO
1771 ACTUAL X REMOVAL
73
V
/.

k
4V

\l
N
V
-i\
H
Y^A

v
V S
'¦•K\
.-K\
V
/: ;i
V '
\ / I N
/A;
-/v
// v
'A
A
,y. h

1
1
"i
N
'"\N-
/\N
4> N
nN

I
SUBCATEGORY
fVS] K REMOVAL FOR BPT
f7
r
/ /I
/t
' /
Y,
Y/
•N
VN
1\
A
Y/
• /
//V
'/ /
t *
A
/
Y
yy.
rz
A
,\
\N
, x ^
K ,\l
K
-------
FIGURE 45
ACT % REMOVAL VS % REMOVAL REQ
100
90
80
v\

70 -
60
50 -
40
30 H
20
£
K
,?r^
\

\
M
V
\
\
\

s
\
\
\
TO MEET BPT LIMITS FOR TSS
/ s\

v
\
\
\
\
Vs
77
/>
~

N
\
\
N
&
/

/
\
1\N
rl\ N \ / \N
y\N k/\N

N
\
V7\
//
A
VA
V
/
/
/
*\ N
l^K
/
i
y
\
K4\^
\
/\
B
V
I

/
/
/
CA

i//\\
V/\<
l/y<\
//w
//\\
\
\
\>
s
\
N
\
/f \
\Z7\ ACTUAL * REMOVAL
H
SUBCATEGORY „
gS * REMOVAL FOR BPT
V/
/
/
YA-H
r
K/V|
V / ^ N
./
/
V
\
\
\
!/' /\ N
A
\
\
\
Va
-KN
v N
[ / \
-t V.-
t-^
K
-------
E. Effect of Various Treatment Systems on Permit Compliance
An analysis was made to compare the compliance rates of the six
types of treatment systems surveyed. Data obtained from table 14 were
used for this study. The Table listed, for a 24 month period, the
number of monthly violations and the percent of time in compliance for
each mill. These data were then grouped together by their respective
treatment system. The treatment systems studied included conventional
activated sludge (CAS), extended aeration activated sludge (EAS),
oxygen activated sludge (CAS), activated sludge and aerated stabilization
basin (AS + ASB), aerated stabilization basin (ASB) and oxidation pond
(OP). For this study EPA calculated a treatment compliance ratio by
dividing the number of monthly violations by the total number of monthly
data. These ratios were converted to percentages and are displayed in
Table 21. Examination of these results in Table 21 show that mills
using OP achieved the highest permit compliance rate with 100% compliance
for both BC® and TSS. Oxidation ponds were the most reliable treatment
system because they are quite large (Region IV range: 164 to 1475
acres) and are obviously effective in equalizing any changes in waste
loading from the mills. Figures 46 and 47 demonstrate the TSS and
BOD conpliance rate for each treatment system. To determine the
significance of the observed data, statistical analysis using the Chi-
Squared (X2) Test was performed. The test is used for assessing the
significance of an observed difference between each category of treatment
system. This is done with the usual tentative assumption that there is
no significant difference between them, and the probability of this
being the case is then calculated to find out if this assumption is
reasonable. The analysis involves comparing the observed number with
- 128 -
-------
the expected number. The expected number is calculated by simple
proportions. These proportionate calculations give the expected number
of monthly violations and non-violations for each category of treatment
system. The expected numbers are then used for determining the value
of X^. The results of the Discharge Monitoring Report (DMR) data for
each category of treatment system are put into a table as follows:
Violations Non-violations Total
CAS 1 95 96
EAS 6 84 90
CAS 6 126 132
AS + ASB 6 158 144
ASB 145 1769 1914
164 2212 2376
In our earlier observation, it is obvious that difference in performance
between OP (zero violations) and other mechanical treatment systems
appear to be significant. It will not distort the purpose of this
analysis if the OP system is taken out of the analysis. As a result,
the Test will focus on determining whether there is a significant
difference between the five mechanical treatment systems utilized by
the pulp and paper industry. A computer program was developed to
perform the analysis of the data. The resulting value for the is
calculated to be 9.31. The x2 table shows that with four degrees of
freedom the value of X^ indicates a probability of no significant
difference between the five treatment systems is greater that 5%.
Therefore, difference is not proven at the 5% level of significance
since the analysis was not able to reject the null hypothesis of no
difference among the five categories of mechanical treatment systems in
their ability meet permit limits.
- 129 -
-------
TABLE 21
TREATMENT SYSTEM COMPLIANCE RATES OF THE PULP AND PAPER INDUSTRY
IN REGION IV
Percent in Carpi iance
Conventional Activated Sludge (CAS)
Extended Aeration Activated Sludge (EAS)
Oxygen Activated Sludge (OAS)
Activated Sludge + Aerated
Stabilization Basin (AS + ASB)
Aerated.stabilization Basin (ASB)
Oxidation pond (OP)
BOD
TSS
OVERALL
98
100
99
91
88
90
96
97
97
97
94
96
92
94
93
100
100
100
-130 -
-------
FIGURE 46
TSS COMPLIANCE RATES
by treatment system
TREATMENT SYSTEM
-------
FIGURE 47
100
BOD COMPLIANCE RATES
BY TREATMENT SYSTEM
U>
K>

90 -

80 -
LJ

O
70 -
a.
60 -
2

o
50 -
z

SE
40 -
111

AC
UJ
30 -
CL

20 -

10 -

0 -
CAS
EAS
OAS AS+ASB
TREATMENT SYSTEM
ASB
-------
F. Current Control for Color Removal
Of the fifty-six pulp and paper mills in the survey, there are two
that currently have limits for color. They are Bowater Carolina (SC) and
Bowater Southern Paper (TO). One other mill, Champion International Papers
(NC), will have color limits added to their permit upon issuance by EPA,
Region IV. In addition to these, the state of Georgia is the only state
in our Region to incorporate monitoring requirements for color on most
of their pulp and paper permits.
Current control for color abatement includes such approaches as ultra-
filtration and massive lime treatment. Unfortunately, none of these
methods have enjoyed full scale operational success in Region IV, due
to either operational reliability problems or expected high costs
developed from demonstration projects or treatability studies. To
minimize the aesthetic concerns of effluent color, mills in Region IV
often rely on holding ponds to control their discharge. Wastewater
effluent is diverted to holding ponds during low flew conditions
(typically suntner months) and slowly discharged from the holding pond
during high river flew conditions (typically winter-spring months).
The additional discharges during winter-spring are compensated by
higher stream flews and dilution factors. This operational strategy
requires a large amount of land since storage time can range for 30 to
100 days. Another approach is internal load control. Jfewly constructed
- 133 -
-------
mills using an oxygen delignification process prior to bleaching
sequence has shewed a pronounced improvement in effluent color as
carpared to a more conventional bleaching line. A list ojf mills with
their controls for removal of color are discussed below:
Bowater Carolina (SC);
The mill utilizes a holding pond with storage time ranging frcm 2 to
100 days. The holding pond minimizes the color increase in the Catawba
River by diverting a portion of treated effluent flow during low flow
conditions and discharging the collected wastewater frcm the pond
during high flew conditions.
Bowater Southern Paper (TO):
This mill also utilizes a holding pond with storage time of approximately
31 days to control color. In 1984, the apparent color limit was
revised frcm an average of 12 standard platinum cobalt color units to
33 based on an additional water quality study. Prior to that time,
the ccrrpany could not consistently meet a limit of delta change in
background color of no more than 12 units downstream without restricting
their discharge to a point where their ponds filled up.
Champion International Paper (NC):
i
The company has performed several studies directed at errpicying the
ultrafiltration process. This process is similar to reverse osmosis.
- 134 -
-------
The colored stream from the bleaching stage (major source of the total
mill color load) is passed over membrane filters with tiny molecular
size openings. However, results of the pilot study in 1985 revealed
the process to be less efficient than expected (72% removal efficiency)
and capable of operating at only 75% of design flow when optimized. The
failure of this process to meet expected effluent color values was due
in part to a finding that the anticipated portion of total mill color was
not concentrated in the pine bleaching. Additional load was found to be
contributed by the caustic extract filtrate from the hardwood bleachery.
A full scale plant would have a capital cost of $47 million to construct
and $10 million in annual operating expenses. Almost half of this annual
cost is tied to utilities charges associated with separating, evaporating
and incinerating the color concentrate. This process is considered by the
company to be economically infeasible for full-scale application.
Buckeye Cellulose Corp (GA):
This is a new mill not included in our study. Color control consists
of both internal load control and a holding pond. For internal load
control, the company utilizes a kraft oxygen delignification process.
This process reduces the lignin content in the pulp prior to the
bleaching stage. As a result, more color wastes are recycled back to
the recovery process. Also, the process modified the remaining lignin
so that less color is produced in the subsequent bleaching stages.
Study has shown that the performance of this mill with the kraft oxygen
- 135 -
-------
process and holding pond to be the best in terms of effluent color for
the bleached kraft industry. Average effluent color was 75% belcw a
typical bleached kraft mill. Hcwever, the oxygen delignification
stage may degrade the finished product strength to an unacceptable
level. For a new mill, this process can still be a viable approach if
there is a need to reduce color and if product quality allows.
CONVENTIONAL KRAFT PROCESS
Ti
FLINT RIVER KRAFT-OXYGEN PROCESS
(IRntiM Mcytte
It
- 136 -
-------
Union Camp (SC):
This is also a new bleached kraft mill not included in our study. The
facility has a controlled release color limit. Effluent discharge is
regulated to prevent a color change of not more than 40 color units
after mixing in the Wateree River. The holding pond has a storage
time of approximately 60 days with a surface area of 200 acres. For
internal color control, the mill utilized oxygen bleaching.
Interstate Paper Corp. (GA);
In 1968, the company, under an EPA grant, developed a full scale color
removal process. This process employs lime treatment typically exceeding
1,000 ppm. The principle advantage with this approach is that lime is
used extensively in the pulping process and is thus readily available
at the plant. Operating experience of this process have shown to
reduce color frcm 1,200 ppm APHA color unit to 125 ppm (90% removal).
However, the operation of this treatment process was very difficult to
maintain due to the corrosive property and clotting ability of the lime.
The process produces a voluminous sludge with poor settling and dewatering
characteristics. Calcium hydroxide in solution tends to overflow from
the clarifier into the oxidation pond and reacts with atomsphere CO2
to form a calcium carbonate precipitate. This precipitation reduced
the surface area of the pond from 680 acres to 560 acres during the
life of the project. The lime treatment process was later discontinued
in 1974 when the permits were modified to monitor for color only (no
limits).
- 137 -
-------
V. SUMMARY" OF ON-SITE INSPECTIONS
All field investigations at the 55 pulp and paper mills were done con-
currently with NPDES activities. Fifteen were performance a&dit inspections,
ten were canrpliance sanpling inspections and thirty were ccrrpliance evaluation
inspections. The NPDES inspections at all facilities included a review of
monitoring records, sanpling methods, flew measuring practices and
laboratory procedures. For the conpliance sanpling inspections, samples
were collected and permit limitations were examined.
At each of the mills, information was requested concerning best management
practices, spill control, water conservation, chemical recovery and ccmton
operational problems with the wastewater treatment system.
Most mills acknowledged having partial controls cn water conservation
or reuse. A "yes".(see attached list) response indicated at least partial
practice, and in sate cases, 100 percent. Therefore, in the discussion
below, the significance of an affirmative response should be remenibered.
Table 22 summarized the results of the on-site inspections.
- 138 -
-------
TABLE 22
SUWttRV or ON-SITE INSPECTION RESULTS
MILL NMC
NPDES
NJMBER
spill
CONTROL
HATER
CONSERVATION
OCNICAL
RECOVERY
BM>
COMCN OPERATIONAL PROBLEMS
WITH WASTEWATER TREATIEKT SYSTEMS
EPO-FORM
3360-3
ALABAMA K8RFT.6A KRAFT
AL0000617
YES
YES
YES
NO
COLD MEATIER
uwatIawlT"
AUttAMA: RlVEfl PULP CO
RL0025968
YES
YES
YES
IB
FOAM W OCCASION
SATISFACTORY
ALLIED PAPER, S HILL
RL0002755
YES
YES
YES
»

UEAT-SAMPL.
flLWfi CELLULOSE
C0005321
YES
YES
N/A
ND

(MSAT-RECORDS
ALTON BOX BOARD
FLOOOOM8
YES
YES
YES
ID

SATISFACTORY
BOUATER CAROLINA
SCOOOI015
YES
YES
YES
«

SATISFACTORY
SOHATER S0UT1CRN PAPER
TN0002356
YES
YES
YES
ND

SATISFACTORY
BRUNSWICK WLPIPfiPER
BA0003654
YES
YES
YES
M)
AERATOR MAINTENANCE
SATISFACTORY
BUCKET CELLULOSE CORP
FL0000676
YES
YES
YES
W)
FOM 1 MAINTENANCE OF AERATORS
SATISFACTORY
CHAMPIW PAPER
RL00003%
YES
YES
VES
ID

SATISFACTORY
WWPIDN PAPERS
ICOOOOe72
YES
YES
YES
VES

SATISFACTORY
CONTAINER CORP
AL000268?
YES
YES
YES 1 NO
10

SATISFACTORY
CONTAIICR CORP
FLOOOUM
YES
YES
VES
YES

SATISFACTORY
CWTIICNTAL FINEST (FEDERAL P.)
GA0002S01
YES
YES
VES
ND

SATISFACTORY
DIXIE NORDCRN (J«€S RIVER)
AL0003301
YES
YES
YES
VES
LOU TEMPS. IN WINTER/OCCASIONAL pH
uwbt-sanpl.
FEDERAL PAPER BOARD
ICOOOX%
YES
YES
YES
ID
AERATOR MAINTEMAMX
U6AT-EFF LIN.
GEORGIA KRAFT
SAOOOIIM
YES
VES
VES
m
FOAM COKTROL IN DRY HEADER
SATISFACTORY
6ILNAN PAPER
BAOOOI353
YES
YES
YES
NO
AERATORS
SATISFACTORY
GOLD BOM) BUILDING
AL0003930
YES
N/A
N/A
ID
AERATORS
IMSAT-SRMPL.
GREAT SOUTHERN PAPER
BR0OOI2O1
YES
YES
YES
NO

SATISFACTORY
GULF STATES PAPER
noooaa
YES
YES
VES
ND
DEBTOR DEADER/NOZZLES
SATISFACTORY
HPWCRxriL PAPER
AL0003018
YES
YES
VES
ID
LIMITED TO *-m. DISDWE/DAY IN SUM.
SATISFACTORY
HDEWER WALDORF CHAMPION
W00007SE
YES
YES
YES
VES
ODORS FROM SLUDGE LABOW
UGAT-LAB
INLAW CONTAIICR
TN0002763
YES
YES
VES
NO
90LIDS/TVEWAL IWO6I06/P0M) SIZE
UNSAT-EFF LIN.
INTEMATIONRL PAPER
SCOOOOK8

YES
VES
NO

(1GAT-SAMPL.
INTEWAT10NAL PAPER NAT
MG0000213
YES
YES
VES
NO

SATISFACTORY
INTERNATIONAL PAPER VIC
160000191
YES
YES
YES
NO

SATISFACTORY
INTERSTATE PAPER CORP
9A0003590
YES
YES
YES
ND
LOW D.O. FROM BCD OOLOAOING
SATISFACTORY
ITT
R0000701
YES
VES
VES
NO

SATISFACTORY
ITT RAYONIER
6A0003620
YES
YES
VES
W
0000076
YES
YES
VES

SATISFACTORY
(MENS ILL
fuxmkbi

ND
FLDODIIG FROM RAIN
SATISFACTORY
scon PAPER, WBILE NILL
AL0002901
YES
YES
VIS
VES
flENATOR DOUN TIIC
SATISFACTORY
SDM3CO PRODUCTS
SC0003042
IOT INSPECTED

SOUTHEAST PAPER *6
BA0032620
YES
YES
N/A
ND
HYDMLIC OVERLOAD IF SEC. CUW1FIER
SATISFACTORY
STOE CONTAIICR
900000676
YES
VES
YES
M)
flocoi*
SATISFACTORY
STOC CONTAIICR CORP
BA0002TO
YES
YES
VES
Ml
POTENTIAL SPIUS - LIQUOR ETC.
(MEAT. RECORD
ST. REGIS PAPER (CHAMP. INT'L)
FL0Q02526
YES
VES
»
ND
MAINTENANCE OF AERATORS
SATISFACTORY
ST. REGIS PAPER (Gft. -PACIFIC)
IC00029M
YES
VES
VES
N)

SATISFACTORY
TENNESSEE RIVER PIP
TM0002232
YES
YES
YES
Ml
AERATOR MAINTENANCE
SATISFACTORY
INIOM CAMP
OLQ003113
YES
VES
YES
»
FORM
WBAT-SANB..
UNION CAMP
BM001M
YES
VES
YES
ND
LOU PUMT EFFICIENT IN COUI READER
SATISFACTORY
ICSTVACO CORP
SC0001739
VES
VES
VES
YES
9DLID6 RETENTION
SATISFACTORY
IESTVACO FIIE PAPERS
KVOOOOOK
YES
VES
VES
YES
AERATOR NAtNTEIWCE
satisfactory
CKRHAEU5ER IS
IC0003191
YES
YES
VES
VES
ICES CONTROL ON DIKES
SATISFACTORY
MEYEIMAEUGER PL
MXOOOGBO
VES
YES
VES
ND

SATISFACTORY
ICVEMAEUGER CO
*0036*12
VES
YES
ND
NO

UNSAT-FLOU
UIUAMETTEIW) CD NIL!
KY0001708
VES

Ml
AERATOR MAINTENANCE
SATISFACTORY
UILLWETTE IND U KRAFT
KY0001716
YE5

Ml
AERATOR MAINTENANCE
SATISFACTORY
- 139 -
-------
A. Best Management Practices
Eight of the 55 facilities were required by the permit to have a best
management practices (BMP) plan; seven actually had a plin; one was in
the process of preparing a plan. However, all mills effectively had
portions of a BMP, even though it was not referred to as such by
facility personnel. These are discussed in the following sections on
spill controls, water conservation and recovery capacities.
B. Spill Control
Spill control information requested, included utilization of:
1. Spill collection tanks or sumps
2. Level or flow alarms for warning
3. Conductivity probes in U-drains
4. Diking around fuel and chemical plants
5. Curbing and drainage of chemical process areas
Of the 55 mills visited, 38 had seme methods of spill collection, 40
had alarm systems, 34 used conductivity probes, 46 had the fuel/chemical
storage tanks diked and 46 provided curbing/drainage in chemical
process areas. Eight mills did not respond to all these questions
(depending on the question); the remaining mills had negative responses.
- 140 -
-------
C. Water Conservation
Water conservation information requested included:
1. Keeping washdown hoses and water valves closed except when needed
2. Use of surface condensers instead of direct contact condensers
3. Minimization of pump seal water loss
4. Reuse of Whitewater
5. Reuse of process condensate
6. Reuse of steam condensate
Water conservation practices, concerning using washdown hoses and
leaving valves open only when necessary, were answered affirmatively by
30 of the 55 mills; two mills answered negatively; one indicated that
they attempted to conserve; 22 did not respond. Surface condensers
are used either exclusively or along with other condensers in 39 mills;
2 mills don't use thesm; 13 mills did not respond.
The minimizing of pump seal water losses was practiced in 40 of the mills;
one mill stated this was not practiced; the remaining mills had no response
(14).
Whitewater, process condensate and steam condensate reuse was practiced
in 46, 43, and 47 mills, respectively. Information was not obtained from
about 6 mills. Reuse in the remaining mills was either not done for
one or more of the reuse categories, was not applicable, or was partially
practiced.
- 141 -
-------
Chemical Recovery
Chemical recovery included the recovery boiler and evaporator capacities.
About 38 mills stated they had adequate capacity; 3 had inadequate
capacities while 14 either did not respond or indicated that they were
marginally or partially adequate.
Canmon Operational Problems
Thirty-one of the mills discussed their most conmon operational problems
with the wastewater treatment systems. Aerator maintenance was
acknowledge by 13 of the mills as their primary problem. Foaming was
mentioned by 5 facilities; cold weather was indicated by 4; remaining
problems were flooding, hydraulic and organic overloading, solids
retention and weed control.
NPDES Inspection Results
During the field inspections, the EPA NPDES Compliance Inspection Report
was completed for each facility (see Appendix C). This report covers
such items as Records and Reports, Permit Verification, Operation and
Maintenance, Compliance Schedules, Self-Monitoring Program and Effluent/
Receiving Water Observations. An evaluation of the mill's NPDES
programs indicated 39 were in compliance with the items examined. Of
the 16 mills where one or more of the items were unsatisfactory, 8 had
problems with sampling, 4 had flow measuring problems, 3 had incomplete
or incorrect recordkeeping syterns, and 1 had laboratory deficiencies.
Of the 10 mills where sampling was conducted, 2 of the facilities also
exceeded permit limits. These problems constitute permit violations.
The states and EPA must follow with enforcement actions whetfe appropriate
to assure that these violations are corrected.
- 142 -
-------
EVALUATION OF STATE NPDES PROGRAMS
A. NPDES Permit Program
In November 1972, Congress passed water pollution control legislation
featuring the NPDES permit program as the centerpiece of a national
water pollution control effort. Hie first round of NPDES permits were
issued between 1972 and 1976, and focused on "traditional" pollutants
such as BOD, TSS, pH, oil and grease. Amendments to the 1972 legislation
(Clean Vfeter Act of 1977) enphasized controlling toxic discharges, and
the "second round" of permitting began in 1977.
The majority of the early major industrial permits were based on "best
professional judgement" (BPJ) because regulations prescribing nationally
uniform effluent limitations were generally unavailable. The NPDES
program evolved and inproved as permitting procedures were developed and
clarified. Permit quality continues to advance as EPA gains experience
in its role and better guidance is available for the states. The pulp
and paper study reviewed permit procedures and permit quality as they
apply to the pulp and paper industry.
- 143 -
-------
1. Permit Procedures
a. Background
The first step in processing an NPDES permit is a thorough review
of the permit application. The application may be for a new
discharge or for renewal of a current permit. If the application
is complete and accurate, the next step is the preparation of a
draft permit. The draft permit, at a minimum, must contain effluent
limitations, monitoring requirements, and standard conditions.
Special conditions may also be appropriate.
Limits for conventional pollutants must at least require the
application of the best practicable control technology (BPT)
currently available^. Conventional pollutants include such parameters
as biochemical oxygen demand (BOD), total suspended solids (TSS),
fecal coliform, pH, oil and grease. BPT represents the average of
the best existing waste treatment performance within each industry
category or subcategory.
J-The Clean Water Act also requires attainment of best conventional pollutant
control technology (BCT) by July 1, 1984. EPA, however, has not promulgated
effluent guidelines for BCT. Generally, for the pulp and paper industry,
Region IV has determined that BCT equals BPT plus Best Management Practices,
plus biomonitoring where appropriate, plus a reopener clause for promulgated
BCT limitations.
- 144 -
-------
Limits for nonconventional and toxic pollutants mast at least
require the application of the best available technology (BAT)
economically achievable (except for publicly owned treatment
works). Itoxic pollutants include heavy metals and certain man-
made organic compounds. Nonconventional pollutants include
those that are not classifed under the conventional and toxic
pollutant categories, and include such parameters as chemical
oxygen demand (COD) and color.
New dischargers mast meet new source performance standards (NSPS),
which are generally more stringent than BPT and BAT based limits.
EPA has developed effluent guideline requirements for achieving
NSPS, BPT, and BAT for the majority of the pulp and paper
industrial categories and subcategories. Effluent guideline
requirements for the pulp and paper industry, are published
in the Federal Register, 40 CFR, Part 430.
- 145 -
-------
In the absence of prcmulgated effluent guidelines, a permit can
also be written using best professional judgement (EPJ). In this
instance, the permit writer determines on a case-by-case basis,
after consideration of all reasonably available and pertinent
data, what limitations are necessary to achieve BPT and BAT, or NSPS.
The draft rrust also include any more stringent limitations required
fcy state law or required to meet the water quality standards of
the receiving waters. Fbr major dischargers a fact sheet should be
included to document and detail the principle facts that establish
the basis for the limits and special conditions contained in the
draft permit.
After the draft permit has been prepared, a copy is sent to the
applicant and a public notice is published. A minimum of thirty
(30) days is allowed for comments and questions from the public
and the applicant. If no significant cciments or objections are
submitted, the final permit may then be issued after the close of
the public notice period and after receipt of state certification
(for permits issued by EPA). NPDES permits are issued for a period
of 5 years or less, and upon expiration of the permit a new permit
must be issued if the discharge is to continue.
- 146 -
-------
b. Evaluation
An examination of the pulp and paper mill permits in Region IV was
conducted as part of the pulp and paper mill study. This study
looked at mill permits issued during the five year period frcm
1979 through 1983, and found seme emissions and inconsistencies
in the permits issued at that time. These "short comings" can in
some cases be linked to specific permit procedures that were
misinterpreted or were not followed. Ttoo ccnrnon problem areas
were identified and are explained below.
1. The methods used to determine seme production rates were
inappropriate or, in some instances, no basis or rationale was
presented to support the production rate given. This is
significant because the production rate is used to calculate
effluent guidelines-based limits, with higher production rates
resulting in less stringent limits.
2. A number of mill permits were found not to have limits on
chlorcphenolic-containing biocides, and the permit files also
did not contain a letter certifying that they do not enploy
these biocides. Regulations state that only those mills that
certify non-use of chlorcphenolic-containing biocides are not
required to have these limits.
- 147 -
-------
These problem areas are discussed in more detail in the following
section on permit quality.
Because the pulp and paper study examined mill permits issued
during the 1979-1983 period, yearly advances in the NPDES
program inplemented after 1983 were not seen in those permits,
and inprovements achieved during that period were evident in
seme of the permits tut not in the earlier ones of that period.
EPA conducts yearly audits to evaluate how well the states in
Region IV are progressing in implementing their NPDES program.
These audits shew that although specific procedures may vary
frcm state to state, virtually all of the required procedures
are presently being implemented and the states are continuing
to inprove the quality of their NPDES permits.
- 148 -
-------
Permit Quality
The review of the NPDES permit program required an assessment of
permit quality. Permit quality is generally viewed in terms of how
effectively a permit regulates the discharge of pollutants and protects
water quality. The primary mechanism for controlling and regulating
these discharges is the permit limits. The NPDES permits for 56
pulp and paper mills in EPA Region IV were evaluated to determine
whether the limits for these mills were set consistantly across the
Region and according to guidelines. The methods used to derive
the limits in each permit were examined, and permits that appeared
inadequate or incorrectly issued were identified.
Background
Permit limits for pulp and paper mills are normally calculated using
effluent limitations guidelines where it has been determined that the
water quality standards will not be contravened. Effluent limitations
guidelines are expressed in terms of allowable pollutant discharge
rate per unit of production rate. Ihe estimated long term annual
- 149 -
-------
average production rate that is expected during the term of the
permit is multiplied by the appropriate guideline to calculate the
permit limits (i.e., the higher the production rate, the more
waste can be discharged). Effluent guidelines for the pulp, paper and
paperboard point source category are published in the Code of
Federal Regulations, Part 430. These regulations specify BPT
limits for BOD and TSS discharges, BAT limits on pentachlorophenols
and trichlorcphenols for mills that employ chlorophenolic-containing
biocides, and new scurce performance standards (NSPS) for nw dischargers.
Many pulp and paper mill permits, however, were originally written
using best professional judgement (BPJ), or were negotiated through
enforcement conferences, because effluent guidelines for their
industrial subsegment had not yet been developed. The majority of
these permits have been readjusted and improved over the years due
to promulgation of effluent guidelines and the development of
water quality based limits for many mills. In cases where BPJ
based limits were more stringent than required ty effluent guidelines
or water quality standards, the "anti-backsliding rule" (40 CFR
122.44(1)), was invoked. This rule prevents any relaxation of BPJ
based limits to less stringent levels provided the mill has demon-
strated that it can meet the BPJ based limits.
- 150 -
-------
The majority of mill permits in Region IV are based primarily on
the effluent guidelines, although many contained scxne water quality
based limits. Thirty (30) of the 56 (fifty-six) permits surveyed
contained one or more water quality based limits, that is, they
contained additional limits supplementing (or in seme cases
replacing) the effluent guidelines based limits. Typical examples
of water quality based limits aire limits covering receiving water
conditions (receiving water color, dissolved oxygen level, etc.).
The survey also found 3 permits that contained BPJ based limits,
and were more stringent than would otherwise be required by effluent
guidelines or water quality standards.
Application of the Guidelines
One of the major concerns that surfaced during the course of this
survey centered around the application of the effluent guidelines
in developing permit limits. The effluent guidelines, developed
to provide a nationally uniform set of standards, were not being applied
consistantly in nary cases. The primary source of this problem is
a conflict in the Federal Regulations on hew to properly determine
the "production" of a facility.
- 151 -
-------
Effluent guideline limitations are expressed in terms of an allowable
pollutant discharge rate per unit of production. Production is
defined in 40 CFR 430.01 Effluent Guidelines, as "annual" production
based on past production practices, present trends and committed
growth. 40 CFR Part 122.45(b), of the NPDES permit program regulations
further states that production-based limits "shall be based not
upon the designed production capacity, but rather upon a reasonable
measure of actual production of the facility". The regulations,
hcwever, go on to state that "The time period of the of production
shall correspond to the time period of the calculated permit
limitations: for example, monthly production shall be used to
calculate average monthly discharge limitations." This last statement
conflicts with the production definition in 40 CFR Part 430, and
has caused confusion in the proper development of effluent guidelines
based limits. (A previous promulgation of Part 122.45 also stated
that maximum day production shall be used to calculate maximum day
discharge limitations).
- 152 -
-------
In an attempt to clarify this discrepancy, EPA Headquarters provided
a memorandum to all Regions on December 18, 1984, summarizing the
correct procedure for calculating production based limits (Appendix E) .
Basically, the Headquarters memorandum clarifies that for industries
such as pulp and paper, where the effluent guidelines were developed
from national annual production data, the mills historical annual
average production^ should be used to calculate its permit limits.
Variability factors were included in the monthly average and daily
maximum effluent guideline numbers, to account for normal
flunctuations in mill production and also for normal flunctations
in the performance of the wastewater treatment plant. To
apply these effluent guidelines to a mill's maximum monthly or
maximum daily production is, in effect, to "double count" the
variability factors. One of the objectives of this study was to
determine if this conflict in EPA's regulations caused a significant
problem with the development of production based limits in Region
IV NPDES permits.
2usually a five year production history should be used to determine the apropriate
production value. This single production value is then multiplied by both the
daily maximum and monthly average guideline limitations to obtain the permit
limitations. Where expansion or significant production increases or decreases
are projected it may be appropriate to include staged or alternate permit
limits in the permit.
- 153 -
-------
c. Evaluation of Best Practicable Control Technology Currently
Available (BPT) Permit Limits
Hie following method was used to screen the permits for consistency
with effluent guidelines: the highest yearly production reported
by each mill was determined for a five year period ranging frcm
1979 through 1983. The "high year production" was then used to
calculate BAT and BPT limit "values" to be ccnpared against the
existing permit limits. The mill permits vdiich contained limits
that exceeded corresponding high year limit numbers were subsequently
locked at more closely to determine how large the discrepancies
were, and why these discrepancies exist.
T&ble 23 sumarizes the results of this analysis. The table
lists the current permit in effect at the time of the study and the
calculated BPT limit "values". Twenty-one (38%) of the 56 permits
showed sere exceedance of the independently calculated effluent
guidelines based limitations. T&ble 24 lists the 21 permits in
order of increased percent discrepancy. Of these 21 permits, 16
contain*^ discrepancies that were considered significant (i.e.,
more than a 3% difference in any permit limit for BOD or TSS).
- 154 -
-------
TABLE 23
ASSESSKNI OF (EMIT UNLITY FOR 8EB1IN IV UP M PAPER HltlS

PEMIT

LIMITS ,

Hi* 'Tb'U

• HIBH '79
- '*3 PN0
D MSED OPT LIMITS •

KET OPT LIMITS

MES
ISSUE
PEMIT
I 1
MX
TSS
POmiON
poor
Prod.
LOB
1 00*
TSS »
i
HO
TSS
«MIT 1
ma mc
NMER
M1E
im
¦ MS
¦
MI
AW
NU i
I
mm
SUCATEHMY
YEA*
FLUNB
• ffilG
•
m
AW
MM >
•
*W
mi
AVE
MU
BPT LIN
flLinniam
FLOOOOM2
9/27/1*
EFF. L.
4430
M59
9492
109*4
791.00
Ri 791.0
19*3
NO
4430
8*39
9492
109*4
YES
YES
YES
YES
YES
CONTAINER CMP
noooiiM
3/2/83
IPJ
11360
23120
21230
42900
19*7.00
*lI9I7.0
19*3
M
19976
31992
24963
49929
YES
YES
YES
YES
YES
ITT
aoooowi
vnm
EFF. L.
27000
47290
23000
42710
*92.00
Ml 492.0
5/79-4/80
YES
27000
47230
23000
42710
YES
YES
YES
YES
YES

vats 241.0

viKi 162.4

Ctlll 41.*

nitri 41.1

ST. IBIS PMER
aoooesa
1/3/83
RPJ
5100
7650
13000
30000
109140
#1*17.3
19*3
M
*49*
16692
16931
32868
YES
YES
YES
YES
YES
(CHMP. WPL CMP.)

Hi 276.1

MXEYE CELLUJHE CORP
floooook
6/25/84
ML
13200
19*00
23000
90000
131100
FillllO
19*3
ND
32316
62237
32*92
91397
YES
YES
YES
YES
YES
0MD6 ia
aooooeat
9/2*/*4
ML
3550
11100
10760
16140
1000.00
*i 1000.0
19*3
«
9600
11200
12000
24000
YES
YES
YES
YES
YES
KiiKny-cum
SCOOMSK
I/I2/H
EFF. L.
3390
6320
3350
6940
239.(0
St 130.6
19*3
»
3431
6421
3512
6804
YES
YES
YES
YES
YES

Ti 109.0

stk container
300000*76
i/wta
EFF. L
11200
22*00
24000
4*000
1350.00
*11390.0
19*3
»
KM
173M
18600
37200
IB
K>
ND
NO
NO
HMTER CMLIM
sctoiow
5/29/7?
¦ L
20733
39012
40529
73293
1679.00
Si 676.0
19*3
YES
21524
40749
40902
76109
YES
YES
YES
YES
YES

Hi 237.0

II 1*1.0

Ni 142.0

Hi 404.0

Hi 39.0

MIERNRTIIM. ma
9D000006J
12/13/81
«L
11X5
17340
3IM2
61996
1720.00
•¦1361.0
1979
YES
16152
2674*
31*75
52104
»
M>
W
NO
NO

19142
37709

Hi 337.0

Ksrauiaap
SCOPOI739
6/24/*3
EFF. L
1301*
260B9
27000
55776
2862.00
0)2962.0
19*3

14347
2*694
30744
6I4M
YES
YES
YES
YES
YES
SDNDCO PROMTS
SC0003042
l/4/*4
H*L
1490
2900
5102
9149
052.00
¦i 118.0
19*3
M
5137
10127
8051
13019
YES
YES
YES
YES
YES

2721
4290

Ei 734.0

INTEMflTI (ML PRKR VIC NBOOOOI9I
*/2/*2
ffF. U
*422
11*44
1*04*
36096
1307.00
Hi 1907.0
19*3
ND
*439
16*7*
1*0*4
36IU
YES
YES
YES
YES
YES
ST. IBIS PRPER
mtoeMi
am nt
ML.
72M
14310
22320
44640
1679.30
A|1679.3
19*0
M
9404
1**0*
20132
40304
NO
«
10
MJ
m
(BA.-PACIFIC am

9950
19900

INIERMTIOOL MEI MT NB00002I3
8/2/82
EFF. L.
27493
32MB
47390
**097
1231.00
Fl 736.0
19*3
YES
2674*
51377
473*9
8*401
ND
n
YES
YES
NO

•l 497.0

jkrsw co port rum ipmombt*
1/17/13
NQL.
4(95
9025
1*000
36000
161.30
Hi *61.3
19*3
M
12236
23324
22231
41362
YES
YES
YES
YES
YES

(COO
13200

ICYHMBBER CD
H00364I2
10/l/M
HL
2130
3692
3124
3254
710.00
hi mo
19*3
m
3124
5751
4*99
7952
YES
YES
YES
YES
YES

*1 335.0

mna souticm mn
TMOKB
VI/84
«L
26132

49479
50000
2260.70
Hi 723.2
19*3
YES
263B1
51179
45405
•4394
YES
YES
NO
YES
NO

Li 243.9

Hi 620.4

Hi 6612

imcohp
1
I
I/I/I2
ML
3508
MOO
13000
£6000
(63.00
Pi 376.0
19*2
its
7706
14*67
13224
25400
YES
YES
YES
NO
ND

4000
7200

*1 2*7.0

hum coHTAim
TM00P763
Vl/M
EFF. L
5400
10976
SOU
13720
535.00
*i 535.0
19*3
m
42*0
8BM
5350
10700
ND
NO
ND
NO
NO
TDD RIVER NLP6PAPER
1*0002232
10/1/83
HL
9000
10000
19000
3*000
1767.30
*¦1633.*
19*3
w
9650
19101
20275
40548
YES
YES
YES
YES
YES

El 133.7

PUMM NMFT,« KMF
T OLOOOOOl?
12/26/79
« L.
4200
6636
*400
13373
13*00
27600
11*1.00
AilMI.O
1983
ND
6614
13227
14172
28344
NO
NO
YES
YES
ND
~«*»!« PRPEI
810000396
4/22/82
EPF. L.
12422
223*9
21576
40949
1399.30
11)589.3
19*3
NI
17152
33057
37111
69077
YES
YES
YES
YES
YES
OLD B(M UILDIK
AL0003930
*/13/84
kl
3*3
*73
3*5
1170
204.00
Ivi Mn Pipar
1979
W
1192
1987
1192
1987
YES
YES
YES
YES
YES
Uf STATES WEI
AL0002828
7/17/81
we.
10216
11216
19615
21533
18439
19439
34112
35962
719.00
Ht 597.0
6c 90.0
B: 32.0
1983
YES
10858
20837
20122
37358
NO
ND
YES
YES
NO
HfMEMILL PRPER
AL0003218
3/1/82
VOL.
17710
33990

66M0
1016.50
6)1016.5
19*3
YES
16773
32223
34561
64141
NO
NO
NO
NO
NO
KIMEHY-CUMK
*0003158
12/15/83
MB l.
2299*
4346?
4IM9
77433
1*39.00
N; 73*. 9
6i 629.2
Hi 395.3
Ni 106.9
19*1
YES
23312
44497
44771
82625
YES
YES
YFS
YES
YES
-------
TABLE 23 (CONT'D)
ASSESSOR OF KMT WtlTt FOB «KIW IV U) M MKI IUU.S
MES
ma i
•EMIT
ISSUE
M1E
PEWIT I
• PEWIT UMTS Hi* 'TV'U
• T9S : MORCTUM
TYfE i M Ml
AW
MAI :
imimgwp
nmm river pilr co
allies «kh,s ma
CONTAIKR CtMP
B11IE MmCM INC
(MCB IIVEI CORD
MACMtUJM 8UE9EL
KAB CUV
Mill MIE* SERVICE
nmEiMTian. paper)
AL0003II3
(menu
N.00027S5
KLOooete
PL0003301
PL0002674
9C0TT PAPER, WILE DILI AL0002801 7/13/83
4/I/B2
NBL
nm
19942
21649
41648
8/19/81
EFT. t.
7200
13600
13000
26400
8/30/B2
NBL
7130
11379
7108
13738
9/3/82
NBL.
483ft
10000
11000
17000

6060
10000

10/6/71
BE. U
16000
20000
11000
22000
6/3/84
MB L
8338
16717
17112
34224
3/21/84
NBL.
67*4
12368
7020
13840

82*4
16386
10020
20040
6/1/83
NBL.
14726
2*308
26989
31131
7/13/83
ETT. L
24831
47630
4HB0
91089
11/30/82
EFT. L
6780
13400
10700
21400
11/30/82
EPF. L.
27181
32033
499BB
83641
(FID.
INTERSTATE WEI CO* BA0003390 11/30/82
snunosr two m bn»3262o ii/jo/k
Ul
CT>
mitocm
HUBIIIK UPUHH
GE0A6I# NIMFT
6IUM (WED
BA00019M 11/30/62
BA0003634
8A0001I04
BA000I933
12/30/82
I1/30/12
12/1/(3
MB I.
m
BT. L.
HL
MB L.
EFT. L
100
1100
3000
1M0
2200
4630
2084
S3
MOT
CUT
23000 90000 MMO 80800
15800
19440
son
10321
12000
33000
101S2
2MB
24000
3W0
24624
24000
78600
49248
43000
ICYERKUSER NB
UEYEMCUBER PL
CWWPION PAPERS
NC0003I9I
NC0000680
3/14/73
6/3/81
(€0000272 6/19/81
NBL.
MB L.
NO L.
3760
7423
18000
22000
12300
16000
36000
44000
1230
41139
26700
7S232
(ABT/B)
SUHATEBDAY
2173.00
1074.00
631.00
1198.00
1014.00
1131.00
987.50
1743.00
1*4.60
»«
lilt.00
331.00
321.20
3IM.00
#12173.0
6(1074.0
It 631.0
Ai 366.0
Hi 632.0
Hi 1019.0
AtlMl.O
li 467.0
El 230.0
It 937.3
Ai 708.0
Hi 326.t
It 294.0
Hi 34.0
Mi 204.0
Hi 971.2
II 946.4
Hi 936.0
Hi 1132.0
•l 100.8
Hi 330.0
Bl 30.0
At 3BI.0
Ml 26.4
Bl 9DI.I
Ii2966.0
El 211.0
(MAT 434»i4tt,0
(MKT 434ICI 14.0
1806.00 SiI427.0
Hi 379.0
1991.00 #11991.0
1234.00
6RE8T SOUDCM MEI
BA0OOI2OI
11/30/82
EFT. L.
19960
34208
22700
63310
2673.40
ITT RmMlER
8A0003620
12/30/82
NBL
22300
33430
42010
77600
137X00

30000
43000

ICSTVHCO F1K PAPERS
KVOOOOM6
1/23/83
IN
8BOO
13200
8000
16000
747.00
ttlLUMTTTE Itt KB Hill
KVOOOI708
11/7/84
EFT. L.
2343
3090
3850
7700
338.00

4043
8090

miluktte iw m man
KY008I716
11/7/84
EFT. U
10626
20394
14632
27602
603.00
ALPHA CELULIBE
NC000832I
3/1/84
EFF. L.
332
664
333
710
132.60
FEKML PAPER BOARS
IC0003298
10/11/84
MB L.
7000
28000
67618
231080
1984.00
8094 12141 45443 84687
823.00
2216.00
1683.00
Hi 711.0
Hi 323.0
012673.4
F: 660.0
6i 9110
Ii 747.0
Di 338.0
6t 403.0
ton Llnttr P
Bi 964.0
Hi 1020.0
6i 823.0
D: 616.0
E: 343.0
Gi 381.0
I: 874.0
6i 46.0
H: 743.0
HEM
LOB
FUK
1982
1983
1982
1983
1982
1979
I9BI
I9B3
I9B3
I9B3
1980
R>
M
YES
YES
YES
1983 Ml
1983 Ml
1303 NO
7/81-6/82 M
6/83-5/84 »
1980
3/B3-4/84
1983
1983
1983
1983
1983
1983
1979
1983
1979
VES
NO
VES
«
M
NO
VES
W
MB
MB
NO
MO
VES
NO
NO
YES
IBM '79 - '
e
1
HSEB BPT LIMITS t

*ET BPT LIMITS

ROD

TSS
•

too
TSS

PEWIT KET
MS
MM
aw
MAI •
•
M
MAI
AUG
MAI
BPT LINUS
12168
24336
26076
52152
VES
VES
VES
YES
YES
17291
33187
35227
63299
VES
VES
VES
VES
YES
7194
13863
13364
28969
VES
YES
YES
YES
VES
12460
24162
23982
~5500
VES
YES
VES
YES
VES
14979
27573
26088
48480
M)
YES
VES
YES
H
11091
22046
20388
41083
VES
VES
VES
YES
YES
8330
16660
10333
21066
fES
VES
VES
YES
VES
16401
31826
31773
6030)
VES
VES
YES
VES
VES
25168
48974
30268
93308
VES
YES
YES
VES
YES
3242
10483
11232
22464
NO
ND
YES
VES
NO
21463
41166
39460
73331
NO
to
NO
NO
NO
3006
6171
6612
13224
YES
YES
VES
VES
VES
9727
18725
13437
24958
VES
VES
VES
VES
VES
24906
49750
38406
77026
NO
NO
HO
NO
MO
28337
54441
36384
104954
VES
VES
YES
YES
YES
11130
22300
23892
47789
YES
YES
M)
NO
NO
12387
24290
24296
46148
YES
YES
VES
VES
YES
21403
42*06
33443
ujir
VES
M)
VES
VES
NO
30869
39364
36412
104746
VES
YES
YES
YES
YES
9711
13836
17778
33092
VES
VES
YES
YES
YES
2864
5728
4473
8990
ND
ND
YES
VES
NO
9950
19115
20302
38049
NO
NO
VES
YES
ND
NO BPT LIMITS FDA
THIS SUB.

—
—
—
—

30111
57835
38327
112338
VES
VES
NQ
NO
NO
13283
25493
27060
50160
VES
YES
YES
VES
VES
22608
44091
44172
83631
VES
YES
VES
YES
VES
22948 440% 46470 86457
VES
VES
VES
YES
VES
-------
TABLE 23 (CONT'D)
ASSESSOR IF PEWIT OURLiry FBI NEBIOM IV IU.P M W» MILLS
ma mk
MB
NMEN
PEWIT
ISSUE
KITE
KIM? : I
TYPE i MS
• PEWIT LIMITS Hi|h •79-'U
S TSS i PURCTION PMUCT l>rod.
MM M6 MM t (flOT/D) SUBCBTEBOMY VEM
MEMR MLKMF-CHMP
INT'L OMR
OLIN CORP
NC00007K un/u
mcooooots 10/14/u
EFF. L.
¦ L.
MK 13703
OKI
9174
817*
18340
145K
13601
291(4
2(11(
IIOS.00
moo
ii mo
Rl
Al1035.0
El 70.0
li 93.0
ll 11&.0
li t2(.0
CfellM (3.0
• HIW '79 - >13 PHD BASED BPT LIMITS •
LOB i M» TSS f
FLIK i M Ml MG MM •
1913
1*1
NO
YES
KET BPT LIMITS
BOO TSS PEWIT ICFT
M Mftl AV6 MM BPT LIMITS
«XK 12012 12770 J5540
(432 12190 B2t9 15782
NO
MO
NO
NO
NO
NO
ND
ND
TOTAL NO. OF lESION IV PULP I PAPER PEWITS :
TOTAL W. OF PEWITS KETN6 BPT LINUS :
TOTAL KL OF PEWITS NOT NEETINS BPT LIMITS :
TOTAL NO. OF PEWITS WITH NO BPT GUIDELINES :
NO
NO
X
34
21
I
Ul
-------
3%
10%

TABLE 24

1^bif-SfiPUlP M111 Permits Vyhere Effluent Limits Exceed BPT Effluent
Guidelines, Using the Annual Average Production Definition in 40 CFR 430

% Permit Limits Exceed BPT
Calculations
Mill Name
State
BOD
Avg Max
Avg
TSS
Max
Bowater Southern
AL Kraft, GA Kraft
Tennessee
Alabaira
0.33%
1.10%
¦-
0.16%
Mead Cbrp.
Tennessee
-
—
__
2.3%
Int'l Paper, Natchez
Mississippi
2.7%
2.7%

Georgia Kraft
Georgia
-
-
3.0%
3.0%
Gulf States Paper
Alabama
3.2%
3.2%

Hammermill Paper
Alabama
5.3%
5.2%
4.2%
4.1%
Union Canp
Georgia
0.38%
0.5%
4.9%
4.7%
Dixie Northern (James River)Alabama
6.4%
-
—

Williamette, Ind. W. Kraft
Kentucky
6.4%
6.3%
—
_
St. Fegis (GA Pacific)
Mississippi
5.5%
5.5%
9.7%
9.7%
Hoerner Vfeldorf,
Chanpion Int'l
North Carolina
12.4%
12.4%
12.4%
12.4%
Continental Forest (Fed. P)
Georgia
21.0%
21.0%
14.2%
14.4%
Great Southern Paper
Georgia
-
21.0%
-
—
Stone Container
Georgia
21.8%
21.8%
-
—
Inland Container
Tennessee
22.0%
22.0%
22.0%
22.0%
Stone Container
South Carolina
22.5%
22.5%
22.5%
22.5%
Federal Paper
North Carolina
-
-
-
29.0%
International Paper
South Carolina
15.6%
29.0 %
<0.1%
16.0%
Williamette Ind., Med.
Kentucky
29.2%
29.2%
-
-
Olin (Ecusta Corp.)
North Carolina
29.0%
33.6%
39.2%
39.6%
Total: 21
Ttotal where difference is judged significant (>3%): 16
- 158 -
-------
The permit files for the 21 permits that showed exceedance of the
independently calculated limitations were examined to determine
the cause of the discrepancies. The discrepancies were generally
found to be production related in origin, although two resulted
frcm the use of seasonal limits. The discrepancies and the
production rates used in permit development are summarized in Table
25.
- 159 -
-------
TABLE 25
Sumary of Production Data, Bases for Production in Permit, and Cause of Discrepancy
State
Mill Name
High '79-'83 Annual
Production Reported
By Mill for this Study
(air-dried ton/day)
Production Rate
Used in Permit
(air-dried ton/day)
Bases for Production
Rate in Permit
Development
Cause of Permit
Discrepancy with
BPT Guidelines
AL
AL Kraft, GA Kraft

A = 1181
A = 1200
Not Documented
Permit Application
(12/22/80)
Discrepancy
Insignificant

Gulf States Paper

H = 597
G = 90
Q = 32
H = 627
G = 25
Q = 75
Not Documented
Permit Rationale
(5/28/81)
Seasonal Limits

Harmentri.ll Paper

G = 1017
G = 1100
Not Documented
Permit Application
(9/24/81)
Higher Production
Basis, Unknown
Source

Dixie Northern
(James River Corp)

H = 1019
H = 1131
Not Documented
Permit Application
(3/30/81)
Higher Production
Basis, Unknown
Source
GA
Georgia Kraft

A = 1991
A = 2052
Che Month Maximum
Permit Application
(8/5/82)
Different Weigh-
ing of Production
Among Subcate-
gories

Union Caiqp D = 2966 D = 2997
E = 218 E = 177
(Part 454) D = 466 (Part 454) D = 466
(Rart 454) G = 14 (Part 454) G = 14
Cue Month Maximum
Conpany Letter
(10/12/82)
Higher Production
Basis, Source
Unknown

Continental Forest
Ind. (Federal Paper
Board)
H = 1132
G = 100
N = 350
S = 30
Total =2290
Not Documented
Fact Sheet
(9/2/81)
Unable to Deter-
mine Non-Contin-
uous Discharge
Based Limits May
Contribute, Penai t
May be Based on
Increase*.] Pro-
duction .
-------
TABLE 25 (CONT'D)
Suttnary of Production Data, Bases for Production in Permit, and Cause of Discrepancy
State Mill Name
High '79-'83 Annual
Production Reported
By mill for this Study
(air-dried ton/day)
Production Rate
Used in Permit
(air-dried ton/day)
Bases for Production
Rate in Permit
Development
Cause of Permit
Discrepancy With
BPT Guidelines
GA
Great Southern Paper
D = 2675.4
D = 2420
Previous Permit
Permit Rational
(9/30/82)
Unable to Deter-
mine Non-Continu-
ous Discharge
Based Limits May
Contribute
Stone Container
A = 936
A = 919
Not Documented
Permit Rational
(9/29/82)
Unable to Deter-
mine
KY Willamette Ind.
W. Kraft
Willamette Ind.
Med. Mill
G = 603
D = 358
MS International Paper F = 737
Natchez G = 490
St. Regis (GA Ifecific) A = 1679.3
G = 660
D = 380
F = 905
G = 284
A = 1843
die Month Maximum
t^ct Sheet
(8/17/82)
Plant Capacity
Cb. Letter
(11/22/78)
Not Documented
Ecict Sheet
(No date)
Not Documented
Permit Rational
(10/16/81)
Use of Max. Month
Production Basis
Use of design
capacity and other
unknown factors.
Discrepancy
Insignificant
Higher Production
Basis Source
Unknown Seasonal
Limits May Contri-
bute
-------
T^ble 25 (CONT'D)
Sumary of Production Data, Bases for Production in Permit, and Cause of Discrepancy
State Mill Name
High '79-'83 Annual
Production Reported
By Mill for this Study
(air-dried ton/day)
Production Rate
Used in Permit
(air-dried ton/day)
Bases for Production
Rate in Permit
Development
Cause of Permit
Discrepancy with
BPT Guidelines
NC Hoerner Vfeldorf
Champion Int'l
A = 1035
E = 70
A = 1186
E = 70
One Month Maximum
Permit Rational
(12/19/83)
Use of Max. Month
Production Basis
Federal Paper Board
Olin (Ecusta Cbrp)
SC
Stone Container
G = 964
H = 1020
Z = 93
R = 116
X = 126
Cellophane
A = 1550
= 63
G = 500
H = 1000
Z = 171
R = 235
X = 215
Cellcphane
A = 2000
= 63
Not Documented
Fact Sheet
(5/3/78)
Plant Capacity
Fact Sheet
(8/18/83)
Plant Capacity
E^ct Sheet
(7/20/83)
Unable to Deter-
mine (48-Hr Limit
Used in Lieu of
Daily Max.)
Use of Design
Capacity for Pro-
duction
Use of Design
Capacity for Pro-
duction
International Paper
D = 1363
H = 357
D = 2006
Not Documented
F&ct Sheet
(Updated)
Unable to Deter-
mine
TN
Bcwater Southern
H = 723.2
L = 243.9
M = 628.4
N = 665.2
H = 791
L = 253
M = 654
N = 881
Not Documented
Permit Retional
(3/27/83)
Discrepancy
Insignificant
Mead Corp.
P = 376
R = 287
P = 432
R = 355
One Day Maximum
Permit Application
(3/16/81)
Discrepancy
Insignificant
Inland Container
B = 535
B = 686
Plant Capacity
Permit Rational
(2/83)
Use of Design
Capacity for
Production
-------
Sixteen (16) of the permits contained discrepancies that were
considered significant (>3%). Of. these, the discrepancies in 10
were production related. Four of the permits with'production
related discrepancies did not document the basis for production.
Two permits contained seasonal limits which allowed discharges to
exceed guidelines during the seasonal "high-flow" months of the
receiving waters, but these were in turn compensated for by more
stringent or even "zero discharge" limits during the seasonal "low-
flow" months. (The "annual average" of the seasonal limits do
meet guideline levels.) Four of the older permit files did not
contain adequate documentation to explain how the limits were developed.
The results can be summarized as follows:
Cause of Discrepancy No. of Facilities
- Production related:
Design Capacity Production Used for Permit 3
Monthly Maximum Production Used for Permit 2
Unknown Production Basis for Permit 4
Caused by Changes in Production Levels (Among
Multiple Product Categories) 1
- Seasonal Limits or Non-Continuous Discharges:
Permit Allows Monthly or Daily Exceedances Over
Effluent Guideline Limits, Compensated by More
Stringent Than Guidelines Limits at Other Times 2
- Unknown:
Unknown, not production related 2
Unkncwn, possibly production related 2
- 163 -
-------
The discharge monitoring data for the 16 mills with significant
discrepancies was reviewed to examine whether these mills could
have met the more stringent EPA calculated BPT values during the
study period, or vAiether additional treatment was needed. This
review shewed that 7 of the 16 mills can meet the more stringent
values. They are listed as follows:
AL Gulf States Paper
Hammermill Paper
Dixie Northern Inc. (James River Corp.)
GA Continental Forest Ind. (Federal Paper Board)
Union Canp
NC Federal Paper Board
SC Stone Container
Poor documentation was more evident in the older permit files of
the study period, while the more recently renewed permits were
much better documented. In recent years EPA's state overview
program has stressed the importance of proper documentation for
NPDES permits.
- 164 -
-------
d. Evaluation of Best Available Technology Economically Achievable (BAT)
Permit Requirements and Use of Best Management Practices Plans
Federal regulations require mills where chlorophenolic-containing
biocides are used shall be subject to pentachlorophenol and trichlo-
rophenol limitations. Mills not using chlorophenolic-containing
biocides must certify to the permit-issuing authority that they
are not using these biocides. Of the 56 pulp and paper mill
permits that were surveyed, 10 contained limits for pentachlorophenol
and trichlorophenol, and 32 contained a certification letter
stating that these biocides were not used at these mills. The
remaining 14 permits did not contain limits for pentachlorophenol
and trichlorophenol, and also did not have present a letter certifying
non-use of chlorophenolic-containing biocides. Listed below are
mills that do not appear to meet the BAT requirement regarding
chlorophenolic-containing biocides at the time of file review.
International Paper - SC
Jackson Co. Part Auth (IP) - MS
Bowater Southern Paper - TO
Stone Container Corp. - GA
Interstate Paper Corp. - GA
Southeast Paper Mfg. - GA
Continental Forest Ind.
(Federal Paper) - GA
Brunswick Pulp and Paper - GA
Great Southern Paper - GA
ITT Rayonier - GA
Westvaco Fine Papers - KY
Weyerhaeuser NB - NC
Weyerhaeuser PL - NC
Champion Papers - NC
Although not a requirement, EPA strongly recommends that major
industrial permits contain provisions for a Best Management Practices
(BMP) plan. BMPs are measures to prevent or mitigate pollution
- 165 -
-------
related spills or accidents through better management and employee
awareness, and BMPs have proven successful and cost-effective
where implemented. Twenty-one of the 56 permits under review
included a Best Management Practices plan. The majority of the
permits reviewed fran Florida, South Carolina, Alabama, and Kentucky
contained BMPs, while those from Mississippi, Tennessee, Georgia, and
North Carolina did not contain BMP requirements. Because of the
time elapsed since our file review, this situation may have changed.
- 166 -
-------
e. Evaluation of Water Quality Based Permit Requirements
Although the permitting portion of this report focused primarily
on the application of effluent guidelines in the pulp and paper
industry, an additional cursory review was performed regarding
whether water quality standards based limitations have been adequately
included in NPDES permits (primarily BOD). The information below
is based on available file information and not on any new analysis
or review performed during the conduct of this study.
Category Is Permit limits appear adequate to meet Water Quality
Standards (WQS) for dissolved oxygen.
Mobile Water Service
Scott Paper, Mobile
Alton Packaging
Georgia Kraft
Continental Forest (Fed. Paper)
Weyerhaeuser
Olin Gorp.
Hoener-Vfeldorf
Weyerhaeuser
I.P.
Mead Corp.
Buckeye Cellulose
ALO002780
AL0002801
PL0000892
GAD001104
GAD002801
MS0036412
NOO000078
N00000732
NC0003191
SC0000868
TOO001643
FLD000876
- 167 -
-------
Charrpion
Hammermill Paper
Union Canp
Kirriberly Clark
Mead Corp.
AL River Pulp
Westavco Fine P.
Williamette Medium
Williamette Kraft
I.P., Vicksburg
I .P., Natchez
Kiiriberly Clark
Westvaoo
IN River Pulp
Bowaters
Inland Containers
Weyerhaeuser, Plymouth
AL0000396
ALD003018
ALO003115
AL0003158
ALO022314
AL0025968
KYO000086
KY0001708
KYO001716
MS0000171
MS0000213
SC0000582
SOO001759
TN0002232
TN0002356
TN0002763
NC0000680 Exp. 06/30/91
Category 2: Permit limits do not appear adequate to neet WQS for
dissolved oxygen.
Subcategory A: EPA has reviewed and the permit limits have been
determined not to be adequate to meet WQS.
Brunswick Paper GA0003654
Subcategory B - EPA has reviewed, water quality problems are
indicated, and additional water quality work and review to determine
final limits is needed. Program activities are in progress to
establish appropriate effluent limitations for these facilities.
Expiration Date
St. Regis (Chanpicn)
FLO002526
01/03/88
ITT, Fernandina
FL0000701
10/31/89
Owens/Illinois
FL0000281
10/31/86
Gillitan Paper
GA0001953
09/30/88
Union Canp, Savannah
GA0001988
11/15/87
Stone Container
GA0002798
11/15/87
Jackson Co. Port Auth. {I.P.)
MS0002674
12/31/87
Chanpicn
N00000272
04/30/90
Federal Paper Board
NCO003298
12/31/87
- 168 -
-------
Category 3: EPA has not reviewed recently, a full review will be
scheduled as part of normal overview of permit issuance activities.
AL Kraft
MacMillan Bloedal
Container Corp.
Allied Paper
Gulf States
Dixie Northern (James River)
Gold Bond
Container Corp.
Great So. Paper
Interstate Paper
ITT Rayonier
S.E. Paper
St. Regis (GA Pacific)
Alpha Cellulose
Stone Container
Bowater Carolina
Sonoco Prod.
AL0000817
ALO002674
ALO002682
ALO002755
AL0002828
ALO003301
ALO003930
FLO001104
GA0001201
GA0003590
GAD003620
GA0032620
MS0002941
NC0005321
SCO000876
SCO001015
SCO003042
10/01/89
07/01/89
09/14/87
08/31/87
07/17/86
03/31/81
08/20/89
04/02/88
11/15/87
11/15/87
12/05/87
11/15/87
12/31/86
04/30/89
08/31/88
12/31/81
01/31/89
The above information is basically a status report of the establishment,
of appropriate water quality based effluent limitations fcy the
various NPDES authorities. EPA, through either direct permit
issuance or overview of state NPDES programs, has not yet ocrrpleted
a review of the water quality standards based effluent limitations
for about half the facilities examined in this study.
- 169 -
-------
f. Conclusions and Reccnmendations
1. Sixteen (29%) of the 56 mill permits surveyed in Region IV
(issued 1979 through 1983) were found to contain one or more
limits significantly more lenient (greater than 3%) than
required by regulations. TWo of these permits enployed
seasonal limits (which "average" guideline levels). Five of
the permits listed production rates based on plant design
capacity or maximum production, and were considered not
issued according to guidelines. The remaining 9 permits did
not present proper documentation to support the production or
limits they contained. The regulations covering this matter,
however, are not consistent and leave roam for interpretation.
EPA and involved State agencies should recpen the 16 permits
with significant discrepancies, obtain prcper documentation,
and permits fcund not stringent enough to meet regulations
should be modified to revise the limitations. In addition,
EPA should initiate proceedings for amending 40 CFR F&rt
122.45(b) of the NPDES permit program regulations to eliminate
inconsistencies in the regulations regarding the prcper averaging
period for determination of a facilities production.
- 170 -
-------
TWenty (36%) of 56 pulp and paper mill permits surveyed (issued
1979 through 1983) were found not to have limits for penta-
chlorophenol and trichlorophenol, and also did not have
present in the permit file a certification of non-use of
chlorophenolic-containing biocides. The guidelines require
mills vtfiich do not have these limits must certify that they
do not use chlorophenolic-containing biocides. EPA and the
States should contact the facilities involved and obtain the
necessary certifications.
TWenty-nine facility permits (52%) of the 56 studied are be-
lieved to have permit limits adequate to protect water quality
standards. Through program activities not directly connected
with this study, EPA has identified 10 of the 18 (20%) facilities
included in this study as having inadequate effluent limitations
to maintain instream water quality standards. Program actions
to correct this situation are underway. Seventeen facility
permits (30%) of the 56 facilities studied have not received
a catprehensive review to deterine if water quality standards
are protected. A review of these permits will be scheduled
in the normal course of State and EPA program implementation.
- 171 -
-------
B. NPDES Compliance Program
1. Compliance Monitoring
Gonpliance monitoring is a process whereby ccnpliance inforrration is
systematically collected, evaluated and translated into tiirely and
appropriate enforcement response. This process is essential to naintain
the overall integrity of the NPDES permit program and for identifying
instances of nonccnpliance so that EPA and NPDES states can initiate
appropriate action as needed. Ccnpliance monitoring is comprised of
four main subactivities - ccnpliance review, data management, ccnpliance
inspection and discharge monitoring report quality assurance
(DMR QA.) program.
a. Gonpliance Review
Ccnpliance review consists of the review of all written reports or mterials
relating to the status of the permittee's ccnpliance with the NPDES
permit. Ihe review includes but is not limited to Discharge Monitoring
Reports (DMR's) and noncompliance reports. These reports originated
frcm the permittee and usually played an iirportant role in ccnpliance review.
Tb determine ccnpliance, the ccnpliance review process starts with DMR's.
The DMR's show, for a given period, a mill's actual discharge versus
the permit limits. If violations are found, the violations are ccnpared
to the technical review criteria (TRC) used in the determination of
- 172 -
-------
"significant noncompliance" (SNC) as discussed in Section IV.C.2. The
TRC criteria focus on the magnitude of the violations. Violations that
fall outside the TRC range will be given priority for subsequent enforce-
ment action. In this study, NPDES state procedures werfe judged against
these standard procedures. All states were found to have adequate
procedures to review compliance information and to identify violations
using EPA's definition of SNC.
Once a violation is identified in the DMR's, the next step in the
compliance review process is to determine its causes and circumstances.
The NPDES permit requires that the permittee notify the regulatory agencies
and submit a noncompliance report for each instance of noncompliance.
The noncompliance report must contain a description of the violation
and its cause, the period of occurence, including exact dates and
times; and if the violation has not been corrected, the anticipated
time it is expected to continue, and steps taken or planned to reduce,
eliminate, and prevent reoccurrence of the violation. For this study,
EPA conducted independent reviews of compliance files in each state office
and EPA. All documents relating to the noncompliance report are noted
in EPA's File Review Checklist Form (Appendix A). Review of the files
for 1982 and 1983 indicated these reporting requirements are not being
consistently complied with by the pulp and paper mill industry in Region IV.
A previous table on the causes of permit violations (Table 16) shewed
that only half of the 164 permit violations were knewn or properly documented.
- 173 -
-------
Of the 56 mills listed, a total of 15 mills (27%) have same deficiencies in
this area of noncompliance reporting, "or mills with SNC violations,
the noncompliance reporting records are even worse. Table 26 correlates
the number of quarters a mill is in SNC to the number of corresponding
noncompliance reports found in state and EPA files. On a regional
average, written records of noncompliance reports were submitted to
Region IV states and EPA only 33% of the time for SNC violations. Of
the 6 mills with significant violations only 1 mill had properly notified
the state or EPA of its noncompliance at all times. This mill was
located in Alabama. This report is a regulatory requirement. EPA and
the states must work to improve compliance with the notification
requirement. EPA should increase its overview activities to assure
compliance with all Clean Water Act requirements.
- 174 -
-------
TABLE 26
NONCOMPLIANCE REPORTING RECORD FOR MILLS WITH FREQUENT SNC VIOLATIONS*
State
Mill Name
Nuntoer of Number of Nonoortpliance Ccnplete Documentation of
Quarters in SNC Reports in File Noncompliance Report
Alabama
Chanpion Paper
yes
Gold Bond Building
Products
8
no
Georgia
Brunswick Pulp and
Paper
no
Kentucky
Willamette Industries
Inc., W. Kraft
no
North Carolina Federal Paper Board
8
no
Tennessee
Inland Container
no
REGION IV TOTAL:
27
9 (33%)
~Frequent Significant Noncompliance (SNC) Violations Means: (1) Chronic, four exceedance of monthly average
effluent limit in a six month period, regardless
of the rragnitude of the violation;
-OR-
(2) Two exceedance of monthly average effluent limit
tr/ 40% in a six uontYv period.
-------
b. Data Management
Data management consists of maintaining and handling compliance materials
relating to the NPDES program. It can be viewed as an organized system of
various components which include the following:
1. Maintenance of complete and current records
2. Adequate system of tracking compliance information
3. Submittal of complete and accurate Quarterly Noncompliance Reports
(QNCR).
Maintenance of Complete and Current Records
Region IV states maintain and update compliance records on individual
permittees by means of two systems. The first system is a manual system.
It consists of a separate file for each facility. The other is a
computerized system called the Permit Compliance System (PCS). It
is primarily used as an information system and an administrative
tool for the NPDES program. All official actions by Region IV
states are based on the files and not the PCS system. To evaluate
the manual system, compliance files for each of the eight states in
Region IV were reviewed for the study. The review focused on file
content which included such items as the NPDES permit, correspondences,
OMR's and inspection reports. The files, for most NPDES states,
were complete, accurate, and current. Compliance materials and
DMR's were well organized and in chronological order. The only
exception was the State of Tennessee where DMR's were not secured
in file folders and were not in chronological order.
- 176 -
-------
In order to move states closer to an automated data management system,
NPDES states are strongly urged to utilize the PCS directly. If
the states do not use PCS directly, the state must submit necessary
information in a suitable form to EPA for data enty. States who enter
PCS data directly are Georgia, Kentucky, South Carolina, and Tennessee.
States vfrio currently submit PCS data to the EPA Regional Office for
data entry are Alabama, Mississippi, and North Carolina. It is the
responsibility of each direct PCS user to naintain current, accurate,
and ccrrplete PCS data. In the carpliance program, PCS is used to
store and retrieve inspection data and DMR results. Since the
loading of the DMR data into PCS was just beginning to be implemented,
the study concentrated only on the inspection data. A comparative
review of inspection records in a state's file with the PCS printout
indicated that most NPDES states have coded in all necessary inspection
data. The only exception was Georgia. There were nine instances
between 1982 and 1983 where inspection results in Georgia's files
failed to show up in the PCS printout.
Adequate System of Tracking Compliance Information
Ccrpliance tracking is used to record and log all instances of non-
compliance. Review of the state files revealed there is no program
deficiency in this area of data management. All states have adequate
procedures of tracking ccrpliance data. For most states in Region IV
this process is done manually. Historical reference on all instances
of noncompliance are recorded either on a violation sunrrary report or
- 177 -
-------
in a notebook system. The use of the computerized system to detect,
store, and track compliance information has not been fully developed
at the time of file review. Only the State of Mississippi has developed
a computer system that identifies violations at all facilities. The
system is presently used for their Quarterly Noncompliance Report
(QNCR) submittal to EPA. Because of the time elapsed since our file
review, this situation has changed. All states are presently required
under the Permit Compliance System (PCS) Policy Statement to use PCS
directly and to track compliance by PCS.
Submittal of a Canplete and Accurate Quarterly Noncompliance Report (QNCR)
The QNCR is an important document designed to report noncompliance.
EPA requires each state to prepare a QNCR which shows only the major
facilities in SNC. The report surmarizes the nature of violations
and the enforcement activities associated with those facilities.
The QNCR is generated quarterly and represents the ccmpliance status
of a facility for a review period ranging frcm 3 to 6 months. EPA
Region IV reviews the quality of the QNCR for Federal regulation
requirements and enforcement actions. This review is intended to
track and evaluate the effectiveness of the state compliance record
and enforcement actions. To determine the completeness and accuracy
of QNCRs submitted by delegated states, EPA reviewed the DMR's in
each state file and identified all pulp and paper mills in SNC
during 1982 and 1983. The results revealed that seme states have
not properly documented all instances of significant noncompliance
- 178 -
-------
(SNC) to EPA. Table 27 correlates the number of quarters a mill
was in SNC to the number of times it was listed on QNCR. A total of
6 pulp and paper mills were found to meet EPA's definition of SNC
at some point during the 24-month period ending December 31, 1983.
These six mills should have been listed on the QNCR for all instances
of SNC. However, Alabama, Georgia, Kentucky, North Carolina and Tennessee
reported mills in SNC on an average of only 44% of the times that
reports were required to be made. Because of the importance of this
report to Congress, the public, and EPA and the small number of facilities
involved, immediate efforts should be made by the states to assure its
accuracy. EPA needs to increase its overview activities to assure
compliance with all Clean Water Act requirements.
- 179 -
-------
TABLE 27
QNCR SUBMITTAL RECORD BY REGION IV DELEGATED STATES
State Mill Name Number of Number of Times Ccnplete Record of All Quarters
Quarters in SNC Listed on QNCR in SNC Listed Cn QNCR
Alabama Champion Paper 10 no
Gold Bond Building
Products 8 5 no
Georgia Brunswick Pulp and
Paper 3 2 no
Kentucky Willamette Industries
Inc. (W. Kraft) 10 no
North Carolina Federal Paper Board 8 1 no
Tennessee Inland Container 6 4 no
REGION IV TOTAL:
27
12 (44%)
-------
c. Compliance Inspections
Another integral part of the compliance monitoring process is compliance
inspections. The NPDES program requires the regulatory agencies to
conduct inspections of a permittee's facility to verify that all permit
requirements are being met. Such inspections may include a Compliance
Evaluation Inspection (CEI), a Compliance Sampling Inspection (CSI), or
a Performance Audit Inspection (PAI). A CEI is a non-sampling inspection
designed for facility record reviews and visual observations of the
treatment facilities. A CSI is a sampling inspection in which a representative
sample of the permittee's effluent is collected. A PAI is a quality assurance
inspection designed to verify the permittee's reported data through a
check of laboratory techniques and records frcm sample collection to
final report. In addition to their respective task, both CSIs and PAIs
also involve the same non-sampling tasks of the CEI.
It is the responsibility of delegated states and EPA to schedule inspections
on a rotating basis for all major facilities. To determine if this
requirement had been made, the study examined inspection reports for
each of the fifty-six pulp and paper mills in Region IV. As shown in
Table 28, NPDES states and EPA performed a total of one hundred
sixty-seven inspections for 1982 and 1983. CEIs were the predominant
type of inspections with one hundred and six performed. CSIs were next
with forty-six inspections performed. PAIs were the least predominant
type of inspection with only fifteen performed. Regulations require
that an inspection be made at each major facility at least once within a
- 181 -
-------
TABLE 28
INSPECTION ACTIVITIES OF REGION IV STATES
DURING 1982 AND 1983
STATE
NUMBER OF PULP
TYPE OF INSPECTIONS
TOTAL
INSPECTIONS
ANNUAL INSPECTION
RATIO
& PAPER MILLS
CEI
CSI
PAI
Alabama
15
18
33
3
54
1.3
Florida
6
6
10
3
19
1.6
Georgia
10
0
20
1
21
1.1
Kentucky
3
2
3
2
7
1.2
Mississippi
5
7
14
3
24
2.4
North Carolina
7
8
11
1
20
1.4
South Carolina
6
1
14
0
15
1.3
Tennessee
4
4
1
2
7
0.9
Region IV Totals: 56
46
106
15
167
1.4
-------
twelve month period. Correlation between the number of inspections
performed to the number of pulp and paper mills (Table 28) reveals
that enough inspections are made to cover each facility on average of
1.4 times per year or once every 8.6 months. This inspection rate far
exceeds EPA's requirement of one inspection per twelve months for
all major facilities. However, some mills are inspected more frequently
than others and as a result not all mills are inspected on an annual
basis. Mills not inspected in 1982 were Owens Illinois (FL), Southeast
Parer (GA), Stone Container (GA), Olin (Ecusta Corp., NC), Weyerhaeuser
PL (NC), and Mead (TN). Mills not inspected in 1983 were Westvaco (KY),
Mead (TN), and Tennessee River Pulp and Paper (IN). Figures 48 and 49
compare inspection rates for each of the Region IV states for 1982 and
1983. In 1982, states with inspection rates of 100 percent were Alabama,
Kentucky, Mississippi, and South Carolina and states with less than 100
percent were Florida (83%), Georgia (80%), North Carolina (71%) and
Tennessee (75%). For 1983, the number of states with 100 percent
inspection rates increased fran four states to six states. Inspection
rates coverage in Florida, Georgia, and North Carolina have all risen
to the 100 percent level.
In conclusion, inspection activities on an regional basis were adequate
with an annual inspection ratio higher than EPA's requirement of one
inspection per twelve months. However, each state should re-evaluate
its strategy and priority for conducting routine and special inspections.
If states are unable or unwilling to make a yearly inspection, EPA
should conduct the inspection.
- 183 -
-------
figure: +b
1982 INSPECTION RATE
CO
o
Id
I-
o
lii
CL
in
z
3
2
u.
o
100
-------
FIGURE 49
1983 INSPECTION RATE
-------
d. Discharge Monitoring Report Quality Assurance (DMR QA) Program
The DMR QA program is designed to assess the quality of self-monitoring
data reported by the NPDES permit holders. These studies are conducted
annually and are intended to include only major permittees. The program
consists of mailing a set of sample concentrates that contain constituents
normally analyzed by the permittees. Each permittee is instructed to
have the laboratory analyze these sample concentrates on a voluntary
basis. Once the samples have been analyzed, the permittee reports the
analytical data to an EPA contractor for compilation. A performance
report identifying reported values, true values, and data acceptability
is provided to the permittee, the state program coordinator, and EPA the
regional program coordinator.
When the study is completed, follow-up activities are conducted by
delegated states and EPA. These activities mainly focus on permittees
that either were listed as non-responding or had results less than
satisfactory on any reported parameter. Many permittees initiate
voluntary follow-up by troubleshooting lab procedures or checking
calculations. Hcwever, delegated states and EPA follow-up activities
normally include performance audit inspections (PAI's), compliance
sampling inspections (CEI's), follow-up letters or telephone calls.
- 186 -
-------
Table 29 surtnarizes the DMR QA results for Region IV pulp and paper
mills. The table lists by state the performance record in the past
five studies. The data in the table includes the number of samples
analyzed, the percentage of samples inside acceptance limits (success
rate), and the percentage of mills with 100% success rate. Four of the
eight states (Florida, Tennessee, Alabama and Kentucky) shewed an
improvement in success rate from Study 1 to Study 5. The state of
Kentucky showed the largest increase with 41% in Study 1 versus 88% in
Study 5. In terms of percentage of mills submitting 100% success data,
only 3 states (Florida, Tennessee, and Kentucky) shewed an improvement
from Study 1 to Study 5. The state of Tennessee and Kentucky showed
the largest improvement. Both states increased frcm 0% of mills with
100% success rate in Study 1 to 100% for Tennessee and 66% for Kentucky
in Study 5.
Figure 50 shows a comparision of success rate for the pulp and paper
industry versus other industries in Region IV and the national DMR QA
average. In all studies except one (Study 5), the pulp and paper
industry performance was higher than other Region IV industries and the
national average. With regard to percentage of permittees who submitted
100% success data, Figure 51 showed the pulp and paper industry performance
was higher in all five studies compared to other Region IV industries
and the national average.
- 187 -
-------
TABLE 29
aiMRRY OF DM) OA RESULTS
HILL NOME WOES i hhhw STUDY 1 hhhihi • mmw STUDY 2 mmim : »»«•«~»»•
NUMER I • OF SUCCESS * WITH : * OF SUCCESS * U1TH : I OF
S SfWPUS RATE 100% : SAMPLES RATE 100* : SOMUS
ALTON 101 BOARD aOOOOM2
CONTAIKR CORP R0001104
in aooooni
sr. REGIS PAPER (MWP. IMT'L) a00Q2526
BUCKEYE CELLULOSE CORP FL0000876
OEMs ill aooooesi
100.0
te.7
66.7
100.0
tt.7
66.7
100.0
75.0
66.7
100.0
100.0
a AUG.
77.8
13.3*
86.3
60.0*
KIMEILY-CLAM
STOC CWTAINER
BOUATER CAROLINA
INTERNATIONAL (WES
UESTVACO CORP
SOMCO PRODUCTS
scoooosae
SC0000676
SC0001015
scooooau
SC0001759
SC0003042
100.0
100.0
100.0
•0.0
100.0
100.0
100.0
75.0
100.0
SC MG.
96.0
80.0*
93.8 73.0*
00
oo
INTERNATIOML PAPER VIC *90000191
ST. REGIS PAPER (BA.-PACIFIC) 160002941
INTERNATIMRL PAPER NAT 160000213
JROtSON CO PORT AUTH (INPL P.) 160002674
UEYEIHflEUSERCO NS0036412
100.0
100.0
100.0
66.7
100.0
100.0
100.0
16 RV6.
100.0 100.0*
91.7 75.0*
BOUATER SOUTHERN PAPER
MEAD CORP
IKJM CONTAIICH
TEMCSSEE RIVER P I P
TN00023S6
TN0001643
TN0002763
TND002232
12
S
4
4
83.3
80.0
50.0
75.0
100.0
80.0
75.0
75.0
TN AW.
72.1
0.0*
12.5
25.0*
AUSRNA KRAFT, BA KRAFT AL0000817
CHAMPION PAPER HL0000396
BOLD BOM) BUILDING BL0003930
GULF STATES PAPER AL000282B
HAMEIMILL PAPER AL0003018
KIMERLY-CUWK AL0003I58
IMION CAMP flL0003115
ALABAMA RIVER PULP CO AL002S968
ALLIES PAPER,S MILL RL0002755
CONTAINER CORP AL0002H2
DIXIE N0RT1CRN (JttCS RIVER) AL0003301
MACMILU* BLOEOEL AL0002674
KflO CORP AL0022314
MOBILE HATER SERVICE IP AL0002780
SCOTT PAPER, MOBILE Mia AL0002801
0.0
100.0
100.0
100.0
100.0
100.0
0.0
100.0
100.0
66.7
100.0
100.0
66.7
100.0
100.0
66.7
100.0
66.7
100.0
100.0
66.7
33.3
100.0
100.0
33.3
flL DVS.
BO. 6
79.5
53. At
STUDY 3 HUHOH : imnnn
SUCCESS * WITH : I OF
RATE 100* : SAMPLES
STUDY 4 ttttmttf : iiHmm
SUCCESS * UITH : I OF
RATE 100* : SAMPLES
STUDY 5 »»»~»««»«
SUCCESS * UITH
RATE 100*
3
100.0 3
66.7 3
64.3 15
100.0 3
66.7 3
7915 40.0*
66.7 3
100.0 3
100.0 3
50.0 4
75.0 5
80.0 4
716 33.3*
100.0 3
100.0 3
100.0 3
100.0 3
100.0 100.0*
100.0 3
100.0 5
100.0 4
75.0 3
93.8 75.0*
66.7 3
3
3
100.0 3
66.7 3
4
100.0 3
100.0 3
66.7 3
100.0 3
100.0 3
100.0 3
100.0 3
<¥> fi 71. in
66.7 4
100.0 4
100.0 6
06.7 15
100.0 3
66.7 3
86.7 50.0*
66.7
100.0
66.7
100.0
100.0
100.0
88.1 66.7*
100.0 4
66.7 3
100.0 3
100.0 3
6
91.7 75.0*
100.0 3
80.0 5
100.0 4
100.0 3
95.0 75.0*
100.0 3
33.3 3
100.0 4
100.0 3
100.0 3
100.0 4
100.0 3
100.0 3
100.0 3
66.7 3
100.0 3
100.0 3
33.3 3
4
100.0
75.0
100.0
93.3
100.0
100.0
94^7 66.7*
66.7
50.0
66.7
75.0
100.0
100.0
7M 33.3*
50.0
100.0
100.0
100.0
83.3
86.7 60.0*
100.0
100.0
100.0
100.0
100.0 100.0*
66.7
33.3
100.0
66.7
100.0
100.0
66.7
100.0
100.0
100.0
tou.o
66.7
lUO.O
jO.O
-------
TABLE 29 (CONT'D)
SUMMARY OF OMR OA RESULTS
HILL NOME WOES s hwmm* STUDY 1 »»»•»#~»»# : «mi»i STUDY 2 t umiiw
KMER : I OF SUCCESS * WITH : I OF SUCCESS « WITH i I OF
I SAMPLES RATE 10M : SAMPLES RATE 100* : SAMPLES
SDK CONTAim CORP
COtTIKNTAL FOKT (FEDERAL
INTERSTATE PAPER COUP
SOUTHEAST PAPER tFfi
1MI0N CAMP
MMSUICK PULP4PAPER
GEORGIA KRAFT
6ILHRM PAPER
GREAT SOUTICRN PAPER
ITT RAMMER
P.)
6A0002798
GA0002B01
GA0003590
6A0032620
GA0001988
SANUtM
GA0001104
BA0001953
6A0001201
GA0003620
100.0
100.0
£6.7
100.0
100.0
tt.7
100.0
75.0
100.0
100.0
75.0
100.0
100.0
100. p
100.0
100.0
100.0
100.0
en mb.
•9.8
66.7*
97.2
88.9*
UESTVACO FIIC PAPERS
I WILLAMETTE IM> NED Mia
^UlLLACm IND U KRAFT
CO
KY0001708
KY0001716
Iff MS.
25.0
£6.7
33.3
4l77
0.0*
100.0
100.0
66.7
*9
66.7*
ALPHA CELLULOSE
FEKRflL PAPER HARD
ICYERHAEUSER tt
HEYERHAEUSER B.
CHAMPIOI PAffiRS
WERKR WALDORF CHAMPION
XIN CORP (ECUSTA CORP)
MXM0S32I
NC0003298
NC0003191
NC000de72
*0000758
NC000007S
IC MB.
57.1
50.0
100.0
100.0
100.0
100.0
£1 66.7*
71.4
60.0
60.0
40.0
100.0
100.0
7K9
313*
KG. PIP MB.
REE. IV AVE.
WT. AVE.
82.1
72.8
73.9
58.3*
31.4*
31.7*
85.8 60.4*
79.4 41.3*
78.9 41.9*
STUDY 3 HHHiiH ; iHimm STUDY 4 ititwttfi ¦ (tiMHm STUDY 5 ihhiiik
SUCCESS * WITH : I OF SUCCESS * WITH : I OF SUCCESS * WITH
RATE 100* : SAMPLfS ARTE 100* i SAMPLES RATE 100*
100.0
100.0
100.0
100.0
£6.7
100.0
66.7
100.0
100.0
100.0
100.0
100.0
66.7
100.0
100.0
66.7
100.0
100.0
100.0
100.0
66.7
100.0
33.3
100.0
90.5
71.4*
95.8
87.5*
85.2
66.7*
100.0
100.0
100.0
100.0 100.0*
100.0
100.0
100.0 100.0*
66.7
100.0
100.0
88.9
66.7*
100.0
100.0
75.0
100.0
100.0
100.0
95.8 8X3*
50.0
80.0
75.0
100.0
66.7
100.0
78.6 33.3*
100.0
80.0
75.0
80.0
100.0
66.7
83.6 33.3*
90.1
83.8
82.8
68.9*
52.7*
49.7*
89.2
66.9
85.4
69.4*
56.8*
54.6*
85.8
86.5
85.5
58.5*
55.9*
56.0*
-------
100
88
88
84
82
80
88
88
84
82
80
78
78
74
72
70
~
FIGURE 50
SUMMARY OF DMR QA RESULTS
*P AVG.
STUDY NUMBER (1880-198S)
O REG. IV AVG.
NAT. AVG.
-------
100
90
80
70
60
50
40
30
20
~
FIGURE 51
PERMITTEES WITH 10056 SUCCESS RATE
kP AVG.
STUDY NUMBER (1980-1985)
« REG. IV AVG.
HAT. AVG.
-------
In general, there is no correlation between the states regarding the
DMR OA program. The results lack any significant trend among the states
from study to study. The degree of improvement for Region IV pulp and
paper mills shows a slight increase in success rate from Study 1 (82.1%)
to Study 5 (85.8%). The improvements have been accomplished gradually
with small increases. The percentage of mills reporting 100% success
rate for Study 5 (58.5%) indicates that further improvement is needed.
- 192 -
-------
2. Enforcement Response
a. Level of Response
The Clean Water Act, Section 309 requires EPA or delegated states to
respond to NPDES permit violations by initiating tinely and apprporiate
enforcement response. Enforcement response involves a series of
actions, starting with a phone call or warning letter and proceeding
to an administrative order and judicial action.
EPA and delegated states have specific procedures for reviewing and
addressing instances of noncompliance. One procedure is the use of
the definition of significant nonccfrp 1 iance (Appendix D). The
definition discussed earlier is used to highlight those dischargers
that should receive priority attention for enforcement actions.
The other procedure is the use of the Enforcement Management System
(EMS). The regulatory agency has historically maintained an EMS
which' serves as a guide for enforcement officials. Within the EMS,
is an Enforcement Response Guide (ERG) which directs the enforcement
officials to various levels of enforcement response to violations.
The guide lists three escalated levels of available enforcement
response depending on the magnitude, frequency and duration of
violations.
- 193 -
-------
The levels of available enforcement responses are discussed below:
EPA Enforcement Response Guide
Enforcement Response Circumstances
No Action
For facilities with non-SNC
violations (violations within TRC
range).
Informal Actions
(Phone call, warning letters,
notice of nonconpliance or show
cause meeting)
May be used against any violations,
but generally used for facilities
with SNC violations that are low in
frequency or duration.
Formal Actions
(Administrative Order, or Referral
for judicial action)
May be used against any violations,
but generally used for facilities
with SNC violations that are high
in frequency or duration, have
potential water quality inpact,
or recur after informal action.
When making determinations on the levels of enforcement response, enforce-
ment officials mast consider other factors such as past violation
history of the mill, pronptness in correcting previous problems, and
attitude. Hcwever, it is anticipated that in most cases enforcement
response will be within the framework outlined in the ERG.
With the above enforcement response available, the study determined
the extent to vdiich EPA and delegated states had taken no actions,
informal actions, and/or formal actons against the pulp and paper
industry in Region IV. Of the 56 pulp and paper mills studied, 29
mills (52%) have instances of permit violations at one time or
another during 1982 and 1983. Based upon the magnitude and duration of
- 194 -
-------
the violations, these 29 mills are grouped into the following categories:
those with non-SNC violations; those with SNC violations that are
short in duration (lasting 1 quarter), and those with SNC violations
that are long in duration (lasting 2 quarters or more).
Non-SNC Violations
Table 30 summarizes mills with non-SNC violations over the 24
month study period. The Table lists the number of monthly average
BOD and TSS violations and the corresponding enforcement response
for each instance of permit violation. From the Table, a total of
23 mills have at one time or another violated their NPDES permit.
Delegated states and EPA took the following enforcement actions: 17
mills received no action response; 1 mill received a warning letter
and a notice of noncompliance (NNC) letter; 3 mills received a NNC
response; 1 mill was called to a show cause meeting; and finally 1
mill received a fine. The show cause meeting and the fine involved
a mill in Georgia and a mill in Mississippi respectively. For the
Georgia mill, the company had numerous permit violations in 1982
(prior to EPA's study period). The mill was issued a consent order
(administrative order) with conditions that a fine be collected
if permit conditions were violated any time in the near future. As
a result of a violation in 1983, the company was assessed a fine.
For the Mississippi mill, the company had numerous spills. Previous
spills had not caused any permit violation. Hcwever, a black
- 195 -
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TABLE 30
SttWARY OF STATE AND EPA ENFORCEMENT ACTIVITIES FOR MILLS WITH NON-SNC VIOLATIONS
State
Mills with Non-SNC
Violations
Total No.
Monthly BOD
& TSS Viol.
Enforcement Response for Each Monthly Instance of Permit
Violation
No Action | Hnone Call Warning Letter | NNC Show Cause Fine
AL
AL Kraft, GA Kraft
1
1
Gulf State Efeper
1
1
Hantnermill Paper
1
1
Kirrberly CLark
3
3
Alabama River Pulp Oo.
5
5
Allied Paper, S Mill
1
1
Container Corp.
5
5
Mobile Water Service, IP
4
4
Scott Paper, Mobile Mill
2
2
FL
Container Cbrp
1
1
ITT
3
3
St. Regis Paper
(Chanpion Int'l)
4
2 2
GA
Stone Container
6
5 1
Gilman Paper
1
1
KY

MS
St. Regis (GA Efecific)
4
4
International Paper NAT
1
1
Jack sen Go. Port Auth.
(Int'l Paper)
1
1
NC
Alpha Cellulose
5
3 11
Weyerhaeuser NB
5
5
Weyerhaeuser PL
1
1
Champion Paper
1
1
SC
Sonoco Products
1
1
TN
Mead Corp.
1
1
TOTALS
23 | 58
50 15 1 I
-------
liquor spill in September, 1983 caused the mill to be in violation
of its BOD limit. As a result, the state requested the Jackson
County Port Authority (International Paper) to be present at the
state office to discuss in-mill and treatment plant improvements.
Based on these facts, the hiqher level enforcement response for
these two mills appears to be appropriate. Overall, EPA and delegated
state's enforcement actions to non-SNC violations are within the
framework of responses outlined in the ERG. Of a total of 58 monthly
non-SNC violations involvinq 23 mills, a large percentage of the
responses were in the no-action category (86%).
SNC Violations With Short EXiration
Table 31 summarizes Region IV mills with SNC violations with short
duration (lasting one quarter). A quarterly review instead of
monthly review of the enforcement actions are used because EPA's
definition of significant noncompliance (SNC) are based on a review
period ranging frcm 3 to 6 months. According to the definition, a
facility is listed as being in SNC for the entire quarter if it has
2 SNC violations or 4 violations (chronic) of the permit limit in
any amount over the review period. There were two mills in Region
IV that have violations that fall under this review criteria. Each
mill had violations of sufficient magnitudes and frequency to trigger
- 197 -
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TABLE 31
SUMMARY OF STATE AND EPA ENFORCEMENT ACTIVITIES FOR MILLS WITH SNC VIOLATIONS LASTING ONE QUARTER

Enforcement Response
State
Mill Name
No. Non-
SNC Viol.
No. SNC
Viol.
No. of Qtr.
in SNC
Informal Action
Fbrmal Action
No Phone Warning
Action Call Letter
Show Cause
NNC Meeting
Referral for
A.O. Judicial Action
AL
Chanpion Paper
1
3
1
1

KY
Williamette Ind.
W. Kraft
8
2
1
1

TOTAL
2
2 | 0 | 0
0 | 0
0 | 0
-------
a technical review by the regulatory agencies. In both cases no
action was taken. A review of circumstances surrounding the violations
revealed that state and EPA actions in these two instances were
appropriate. For the case involving Champion Paper, the Company
had made numerous contacts with state officials concerning
their on going modification of the treatment plant. The Company
had maintained optimum treatment performance for a period of two
months with half of their activated sludge units in operation. For
the case involving Williamette Industry (Western Kraft Paper Group),
the Company constructed a new paper machine and bleach plant that
came on line December 15, 1981. Total production was increased
by 30%. The company had a difficult time meeting limits during the
4 month period from October 1982 to January 1983. During that period,
the Company was in SNC with chronic violations of the TSS limits.
However, a new permit was issued in the following quarter to reflect
the production increase. As a result of these new permit limits
the company has not had a permit violation since. Therefore, state
and EPA action in these two cases appeared to be within the framework
outline in the ERG.
- 199 -
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SNC Violations with Long Duration
Table 32 summarizes Region IV mills with SNC violations that were
long in duration (lasting two quarters or more). The Table correlates
the quarter of a mill in SNC to the corresponding enforcement
responses by each delegated state. A total of 4 mills had frequent
violations over the 24 month study period. State's enforcement
actions against most of these mills had little impact on permit
canpliance. Only 1 out of 4 mills had returned to permit compliance.
The one instance involved a mill in Georgia. The company was able
to return to compliance after a formal action by the State. The
other three mills with SNC violations received numerous informal
actions instead of formal action during the 24 month study period.
Enforcement respond frcm the states of Alabama, North Carolina and
Tennessee consisted of 1 phone call, 8 notices of noncompliance
(NNC), and 2 show cause meetings. The result of the informal
action against these mills was not very effective as violations
continued months afterward.
- 200 -
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TABLE 32
SIM4AKY OF STATE AND EPA ENFORCEMENT ACTIVITIES FOR MILLS WITH SNC VIOLATIONS
LASTING TOO QUARTERS OR MORE
Enforcement Response for Each Quarter in SNC
State
Mill Name
No. Non-
SNC Viol.
No. SNC
Viol.
No. Qtr.
in SNC
Informal Action
Ebrmal Action
No
Action
Phone
Call
Warning
Letter
NNC
Shotf Cause
Meeting
1 Referral for
A.0.1 Judicial Action
AL
Gold Bond Bldg.
8
20
8
6 1 1

GA
Brunswick Pulp
& Riper
10
3
3
2
1
KY

NC
Federal Paper
Board
5
19
8
3 5

TN
Inland Container
11
16
6
2 3 1

TOTAL
25
13
1
0
8
2
1 0
-------
Review of the state's file revealed that all three mills needed
additional treatment plant improvements in order to meet permit
limits. For example, Gold Bond Building in Alabama and Federal
Paper Board in North Carolina both have water quality based permit
limits that are more stringent than comparable production mills
with HPT based limits. Additional treatment and aeration capacity
are needed to improve treatment efficiency. These mills never
received any formal enforcement actions although it appears an
administrative order with interim limits and/or construction schedule
was justified. Using the criteria in the ERG, state enforcement
response for frequent significant violators was judged inadequate
in all three cases involving mills in Alabama, North Carolina, and
Tennessee. States must take forceful enforcement action more
quickly in these cases. EPA should increase its overview of State
enforcement activities to ensure that appropriate action is taken
in a timely manner.
All states have since signed an Enforcement Agreement with EPA in
which the states agreed to maintain current enforcement response
procedures that are consistent with EPA's Enforcement Response Guide as
well as an up-to-date strategy for addressing instances of significant
noncaipliance consistent with national and state priorities. These
procedures set forth: an analytical process for determining the
appropriate level of action for specific categories of violation; pro-
cedures for preparing and maintaining accurate and complete documentation
that can be used in future formal enforcement actions; and time frames
- 202 -
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for escalating enforcement responses where the noncompliance has rv.:t
been resolved. Each state should be able to demonstrate that its
enforcement procedures result in: appropriate initial and follow-up
enforcement actions that are applied in a uniform, consistent and timely
manner; formal enforcement actions that clearly define what the permittee
is expected to do by a reasonable date certain; and compilation of
complete and accurate permit records that can be used in future formal
enforcement actions. In the case of major permittees, by the time a
permittee appears on the QNCR, the states are expected to have already
initiated enforcement action to achieve compliance. Prior to a
permittee appearing on the subsequent QNCR for the same violation, the
permittee should either be in compliance or the state should have taken
formal enforcement action to achieve the final compliance. This formal
action is usually defined as a legally binding administrative order or
a referral for judicial action. These standards are essentially
unchanged from those in effect at the time of the file reviews with the
exception of a requirement for formal action by the time a permittee
appears on two QNCRs for the same violation. Using this criteria,
four mills in the Region TV states had continuous violations in SNC
which lasted for two quarters or more. Table 33 correlates the number
of successive quarters these violations were in SNC to the number of
formal actions taken. Only one State met this criteria. Of the
four states with mills in SNC for two consecutive quarters or more,
only Georgia took a formal enforcement action. By presently used
criteria,, this was a poor record. Initiation of the new national
enforcement policy has improved the situation markedly. EPA must
assure through independent enforcement actions if necessary, that
formal actions are taken on a timely basis.
- 203 -
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TABLE 33

MILLS IN SIGNIFICANT NONCOMPLIANCE IN STUDY
PERIOD
Mill Name
Number of Successive Quarters
State in snc
Number of Pontal
Actions Taken
Gold Bond
Alabama
8
0
Brunswick Pulp
and Paper
Georgia
2
1
Federal Paper
Board
North Carolina
8
0
Inland Container
Tennessee
6
0
- 204 -
-------
b. Timeliness of Response
Another key element in enforcement response is the timeliness with
which the response is initiated. The study reviewed all enforcement
actions issued by EPA and delegated states during the two year study
period. These actions involved 13 Notices of Noncompliance (NNC), 1
Consent Order (administrative order), and 2 show cause meetings.
Of these 13 NNC's, 10 required less than thirty days to issue and 3
required more than thirty days after identification of the violation.
The three instances where the NNC was issued after thirty days of
the violations involved a North Carolina mill and a Florida mill.
With regard to the Consent Order, it was issued in a timely manner.
State officials in Georgia were able to issue a Consent Order
within two quarters after the violations occurred. Of the two show
cause meetings, all were held in a timely manner. State officials
in Alabama and Tennessee have scheduled show cause meetings after
the mills were issued NNC's the previous quarter. In conclusion,
the enforcement response time of Region IV states was judged adequate.
Informal actions, in most cases, were taken within 30 days and
formal actions were taken within 60 days of documentation of the
violations.
- 205 -
-------
APPENDIX A
FILE REVIEW CHECKLIST
FDR THE
PULP AND PAPER INDUSTRY STUDY
Name of Facility:
Address of Facility:
NPDES Permit No:
Issuance Date:
Expiration Date:
Reviewer:
Date of Review:
- 206 -
-------
PERMIT FILE CHECKLIST
I* Permit Processing
1. Was the application received 180 days
prior to
- start of discharge or
- expiration date of permit?
Was a draft permit prepared and sent
to the applicant?
2. Was a public notice prepared?
3. Was notice ccrplete and apprqpriate?
4. Was at least 30 days given for ccrment?
5. Were ccrments received for the draft permit?
6. Have ccrments which were received been
evaluated and changes made in the permit
where warranted?
7. Were there requests for a public hearing?
8. Were there enough requests to warrant
holding a hearing?
9. Was a hearing held?
10. Was a tape recording or written transcript
made of the hearing?
11. Was testimony/information received which
warranted changes in the permit?
12. Have these changes been made?
II. Technical Development
1. Is fact sheet ccrplete and accurate?
2. Is rationale complete and accurate?
3. Are prcrnulgated BPT/BAT (toxic) or
NSPS guidelines properly applied?
(use BPT limitation calculation sheet
in this attachment)
fed 2
Yes
No
N/A

- 207 -
-------
Yes I No I N/A
4. What is the basis of the total production?
(e.g., long term average, maximum production,
highest annual average of last 5 years, etc.)
5. Are pounds/day and kg/day calculations
correct?
6. If permit is not technology based, are
limits based on waste load allocations
either approved by EPA or calculated by
methodology approved by EPA?
7. Has a bioassay been performed on this
discharge?
8. If bioassay(s) has shown this discharge
to be toxic, have toxicity limits or a
toxicity reduction plan been included in
the permit?
9. Have any BPJ limits been developed where
guidelines are not promulgated?
10. Is there ample documentation fo all BPJ
decisions?
11. Does the rationale underlying BPJ
decisions support the limits?
12. Has permittee certified not to be a user
of chlorophenolic biocides?
13. If not, have BAT limits for PCP and TCP
been incorporated in the permit?
14. Does the permit contain a requirement for
a BMP plan?
15. Does the fact sheet support the BMP
requirement?
- 208 -
-------
Yes
III. Perm it Issuance
1. If a renewal, is the permit at least as
stringent as the previous permit?
2. If not, have the requirements of
40 CFR 127.44(1), "Reissued Permits"
been met?
3. Are all the effluent limits effective
immediately, or is a ccnpliance schedule
contained in the permit?
4. If so, does the fact sheet support using
a ccnpliance schedule?
5. Are monitoring requirements appropriate?
6. Ar£ all required general and special
cond it ions included?
7. Is permit term five years or less?
8. Does the permit as issued accurately reflect
the draft permit as well as any changes
warranted by public participation?
9. Have copies of the issued permit been sent
to:
- Applicant?
- EPA?
- Anyone requesting a copy?
- 209 -
-------
COMPLIANCE FILE CHECKLIST
Pre-Enforcement Evaluat ion
1. Are there variances or stays?
a. If so, what type?
b. Are they being followed?
2. Is the permittee oh a compliance schedule?
a. What is the completion date?
b. Is the schedule being met?
c. If not, has action been taken?
d. If not, what has been done to achieve
ccnpl iance?
Compliance Tracking System
1. Are DMR's and other related correspondence
submitted in a timely manner?
a. If not, what has been done to achieve
ocnpl iance?
2. Are all monitoring data and reporting
requirements included in the DMR's?
a. If not, what has been done to
achieve canpliance?
- 210 -
-------
Enforcement Evaluation
1. Are they using EPA's definition of
significant noncompliance to screen
out violations in the DMR's?
2. If notf what definition is used?
3. Are there instances of nonccnpliance
in calendar years 1982 and 1983?
a. If yes, what are the types of
violat ions?
significant?
nonsignif icant?
b. What actions were taken?
c. Are the actions pending?
d. Have the actions resolved satisfactorily
e. Are actions taken apprqpriate
to the situation?
f. What is the average response time
for significant effluent violations
in days?
- 211 -
-------
Yes
g. Are all responses and resolutions properly
documented, i.e., date and level of sign-
off?
h. Are all instances of significant
noncompliance reported in the state's QNCR?
i. Has enforcement response resulted in
carpi iance?
IV. Compliance, Surveillance, & Monitoring Program
1. Have any inspections been performed at
the facility? (If so, answer 2, 3, & 4.)
2. CEI's
a. Date performed .
b. Deficiencies found.
c. Actions taken and status.
3. CSI's
a. Date performed
b. Deficiencies found.
- 212 -
-------
CSI1s - cont inued
c. Actions taken and status
PAI's
a. Date performed
b. Deficiencies found.
c. Actions taken and status
-------
F E B 2 1394
CALCULATION OF BPT LIMITATIONS
Product ion Rate*
Subcategory ADT/day
BOD Average Limit TSS Average Limit
Guideline BPT Limit Guideline BPT Limit
#/1000 # #/day #/1000 # #/day
X2
X2
X2
X2
X2
X2
X2
X2
X2
X2
X2
X2
X2
X2
X2
X2
TOTAL
COMPARISON OF PERMIT TO BPT LIMITATIONS
BOD TSS
#/day #/day
Permit limitation
BPT limitation
* Taken from application or fact sheet in Air Dried Tons (ADT) per day.
- 214 -
-------
FACILITY NAME:
BOD
ro
t—•
in
I
Flow
Monitoring Avg. Max.
Per ioti MGD MGD
1982
January
Februa ry
March
April
May
June
July
August
September
October
November
December
Average
Cone. Loading
mg/1 lb/day
Maximum
Cone. Loading
mg/1 lb/day
TSS
Average
Cone. Loading
mg/1 lb/day
Maximum
Cone.
mg/1
Load ing
lb/day
Tonp
°K
pH
D.O.
Nlly-N
Okic. I/nd i n<]
mg/1 1 h/« t,) y
I'eccil Colifonn
#/100 ml
Other;
-------
FACILITY NAME:
BOO
TSS
Flow
Monitoring Avg. Ma*.
Period MGD MGD
i
ro
i—'
cr>
1983
January
February
March
April
May
June
July
August
September
October
Average
Gone. Loading
mg/1 lb/day
Max lmun
Cone. Loading
mg/1 lb/day
Average
Cone. Loading
mg/1 lb/day
Maximmi
Cone. Loading
mg/1 lb/day
Tenp
Op
pH
D.O.
NH-i-N
Cone. Leading
mg/1 lh/day
Fecal conform
1/100 ml
Others
November
December
-------
APPENDIX B
ON-SITE TECHNICAL INSPECTION REPORT
FDR THE
PULP AND PAPER INDUSTRY STUDY
Name of Facility
Address of Facility
NPDES Permit No.
Issuance Date
Expiration Date
Reviewer
Date of Review
- 217 -
-------
2
I. NARRATIVE DESCRIPTION OF THE FACILITY
(Such as: Plant size, age, raw material usage, production process,
water use, control employed, products manufactured, etc.)
1. Type of mill and product produced.
2. Year operation started.
3. Number of employees.
4. Type of raw material used: % pine, % hardwood, %wastepaper.
5. Number of digesters.
6. Digester type and design capacity.
7. Number of paper machines and design capacity.
8. Source and amount of raw water.
9. In mill water reuse or fiber recovery system used.
II. PRODUCTION
Annual Air Dried Tons/Day*
Subcategory 1979 1980 1981 1982 1983
Total
* Annual Air Dried Tons/Day = Total Annual Air Dried Tons
Total Days in Operation IXiring the Year
- 218 -
-------
r ¦- "> o "iOp/i
t-i
III. DISCUSS TOE MAIN SOURCE OF WASTEWATER FLOW AND ITS CHARACTERISTICS
(Attach a copy of plant process flow diagram showing water balance.)
- 219 -
-------
FFv 2 '.284
IV. WASTE TREATMENT PROCESS DESCRIPTION
A. Size of treatment facility: Avg. design flow
Max. design flow
B. Average monthly influent/effluent wastewater values for 1983.
Month Flof(MGD) BOD(mg/l) TSS(mg/l) Tenperature pH MLSS
Inf. Eff. Inf. Eff. Inf. Eff.
January
February
March
April
May __
June
July
August
September
October
November
December
- 220 -
-------
In the space below, draw the layout of the treatment unit
processes, including the sizing of each unit.
- 221 -
-------
(A.)PROCESS EVALUATION POR AERATED LAGOON TREATMENT
1. Give design criteria used to size each unit process:
Primary Treatment
a. Clarifer overflew rate gpd/ft2.
b. Hydraulic detention hrs.
Secondary Treatment
a. Detention time days.
b. BOD loading rate lb/acre/day.
c. Surface aerator requirement
Number of units .
Hp of each unit .
Oxygen transfer lb 02/hp/hr.
efficiency
Discuss any preliminary or chemical treatment of raw wastewater.
Discuss methods of sludge treatment and disposal.
- 222 -
-------
On-site Evaluation Checklist.
a. Number of treatment units/cells
b. Capacity of each cell ~
c. What are the lagoon dimensions? •
(List size in acres and depth in feet.)
d. Are lagoon contents mixed thoroughly?
e. Are all mechanical aerators operating
properly? •
What is the frequency of operation? •
f. Does the lagoon basin have a foam or scum control
system?
g. If multiple lagoons are operating, is the flow
distributed equally? .
h. Are they operated in series or
parallel? .
i. When was the last time the lagoon was
dredged/cleaned? .
j. Is there vegetation growing in the
lagoon? .
k. What are the most ccrtnon problems the operator has
had with the lagoon system? .
- 223 -
-------
(B.)PROCESS EVALUATION FOR ACTIVATED SLUDGE AND CLARIFICATION TREATMENT
1. Give design criteria used to size each unit process:
Primary Treatment
a. Clarifer overflew rate gpd/ft^.
b. Hydraulic detention time hrs.
Secondary Treatment
Process Regime
Conventional Extended aeration
Complete mix Pure oxygen system
Step aeration Other (specify)
a. Hydraulic detention time hrs.
b. BOD loading rate # BOD/IOOO ft^.
c. Mean cell residence time/sludge age days.
d. F/M ratio .
e. MLSS mg/1.
f. MLVSS mg/1.
g. Type aeration
Mechanical aeration .
Fine bubble diffused
aeration .
Coarse bubble diffused
aeration .
h. Number of aerators/blowers .
i. Hp of each unit .
j. O2 transfer efficiency lb 02/hp/hr.
- 224 -
-------
r- 2 1984
k.
Recirculation ratio

1.
Return AS flew
MGD.
m.
Waste AS flew
MGD.
n.
Waste AS conc.
mg/1
o. Sludge Volume Index .
p. Clarifer overflew rate gpd/ft2.
q. Solids loading rate lb/day/ft2.
r. Side-water depth ft.
Discuss any preliminary or chemical treatment of raw wastewater.
Discuss methods of sludge treatment and disposal.
Discuss any supernatant return frcm sludge treatment and give average
flows and concentrat ion.
2. On-Site Evaluation Checklist
a. Number of basins
b. Capacity of each basin
- 225 -
-------
FTS 2 1334
c. Are tank contents mixed thoroughly?
d. Are all diffusers or mechanical aerators operating
properly?
What is the frequency of operation?
e. Do there appear to be dead spots in the aeration
tanks?
If yes, at what location?
f. Are all return activated sludge punps operating?
If not, what is the reason?
g. Are there flew measurement devices for return activated
sludge and waste activated sludge systems? .
Are they operable .
h. Does the aeration basin have a foam control
system? .
i. If multiple basins are operating, is the flow distributed
equally?
How is it distributed?
- 226 -
-------
Is operation of the system:
Manual Semi-autcmat ic
Automatic Computer Controlled
Other
Does the final clarifer surface indicate inproper sludge
withdrawal? (i.e. excessive floating solids, gas, high
sludge blanket, etc.?)
What are the most cannon problems the operator has had with the
activated sludge system?
- 227 -
-------
^ n 2 1984
VI. BMP PLAN
1. Has a BMP plan been prepared? Yes No
If so, does it contain the following elements and are
these elements implemented?
A. General Requirements In Plan
Yes
No

1. Name and location of facility.

2. Statement of BMP policy and
objectives.

3. Review by plant manager.

Being
Implemented
B. Specific Requirements
Yes
No
1. BMP Conn it tee

2. Risk Identification and Assessment

3. Reporting of BMP incidents

4. Materials Compatibility

5. Good Housekeeping

6. Preventive Maintenance

7. Inspections and Records

8. Security

9. Employee Training

- 228 -
-------
BMP Checklist
Spill Control
1. Use of spill collection tanks or sumps?
2. Use of level or flew alarms for early warning?
3. Use of conductivity probes in U-drains?
4. Proper diking around fuel and chemical tanks?
5. Proper curbing and drainage of chemcial process
areas?
Water Conservat ion
1. Washdcwn hoses and water valves closed except
when needed?
2. Use of surface condensers instead of direct
contact condensers for evaporators?
3. Minimizing loss of pump seal water?
4. Reuse of Whitewater?
5. Reuse of process condensate?
6. Reuse of steam condensate?
7. Vfriat is the waste flow/ton of
production? .
Recovery
1. Adequate recovery boiler capacity?
2. Adequate evaporator boiler capacity?
- 229 -
-------
rEO 2 1984
Other Ccnrnents
Please add any other ccnrnents about the facility's
BMP.
- 230 -
-------
APPENDIX C
Forrr Approve?
OWB \o. 155 ¦ H
TRANSACTION
CODE
NP DES COMPLIANCE INSPECTION REPORT (Coding Instructions on back of last page)
NPDES
YR MO DA
U LlI L
_J 2 2_
11
_12_
_U_
INSPEC FAC
TYPE TOR TYPE
u u u
IS 19 20
TIME
REMARKS
I l l ! ! I I ll

70
ADDITIONAL
SECTION A - Permit Summary
name AND ADDRESS OF FACILITY (Include County, State and ZIP code)
EXPIRATION DATE
ISSUANCE DATE
RESPONSIBLE OFFICIAL
TITLE
PHONE
FACILITY REPRESENTATIVE
TITLE
PHONE
SFrTlON B - P^luent Characteriitiei (Additi<~>"ol f^eerf nrtarhp/J j
PARAMETER/
OUTFALL
MINIMUM
AVERAGE
MAXIMUM
ADDITIONAL
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SAMPLE
MEASUREMENT
PERMIT
REQUIREMENT
SECTION C - Facility Evaluation fS = Satisfactory, U = Unsatisfactory, N/A = Not applicable)

EFFLUENT WITHIN PERMIT REQUIREMENTS

OPERATION AND MAINTENANCE

SAMPLING PROCEDURES

RECORDS AND REPORTS

COMPLIANCE SCHEDULE

LABORATORY PRACTICES

PERMIT VERIFICATION

FLOW MEASUREMENTS

OTHER:
SECTION D • Comments
SECTION E - inspection/Review
CNFORCEMEN7 j
DIVISION i
USE ONLY j
SIGNATURES
AGENCY
DATE
INSPECTED BY

COMPLIANCE STATUS ]
t
<.*cs j
e
,
i
INSPECTED SY

REVIEWED BY

EPA FORM 3560-3 (9-77) REPLACES EPA FORM T-51 (9-761 WHICH IS OBSOLETE. PAGE 1 OF 4
- 231 -
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Forr. Approved
OMB Vo ;55 • ROOT3
Sections F thru L: Complete on all inspections, as appropriate. N/A
= Not Applicable

PERM
T NO.

SECTION F • Facility and Permit Background
AOORESSOF PERMITTEE if DIFFERENT FROM FACILITY
(Including City, County and ZIP code)
DATE OF LAST PREVIOUS INVESTIGATION BY EPA/STATE

FINDINGS
SECTION G - Record* and Reports
RECORDS AND REPORTS MAINTAINED AS REQUIRED BY PERMIT.
~ YES ~ NO ~ n/a (Further explanation attached
I
DETAILS:

(•) ADEQUATE RECORDS MAINTAINED OF:
(i) SAMPLING DATE, TIME, EXACT LOCATION

~ YES
~ NO
~ N/A
(ill ANALYSES DATES, TIMES

~
YES
~ NO
~ n/a
C,ii) INDIVIDUAL PERFORMING ANALYSIS

~
YES
~ NO
~ N/A
(iv) ANALYTICAL METHODS/TECHNIQUES USED

~ YES
~ NO
G N/A
(v) analytical RESULTS (e.g., consistent with self-monitoring report data)
~
res
~ NO
~ N/A
(b) MONITORING RECORDS (e.g.,flow, pH, D.O., etc.) MAINTAINED FOR a MINIMUM OF THREE YEARS
INCLUDING ALL ORIGINAL STRIP CHART RECORDINGS (e.g. continuous monitoring instrumentation,
calibration and maintenance records).
~ Y6S
~ NO
~ n/a
<6> LAB EQUIPMENT CALIBRATION ANO MAINTENANCE RECORDS KEPT.
~ YES
~ NO
~ n/A
(dl FACILITY OPERATING RECORDS KEPT INCLUDING OPERATING LOGS FOR EACH TREATMENT UNIT. Q YES
~ NO
~ N/A
(•) QUALITY ASSURANCE RECORDS KEPT.

~ YES
~ NO
~ N/A
(f) RECOROS MAINTAINED OF MAJOR CONTRIBUTING INDUSTRIES (and their compliant tUttU) USING
PUBLICLY OWNED TRfeATMENT WORKS.
~ YES
~ NO
~ n/a
SECTION H - Permit Verification
INSPECTION OBSERVATIONS VERIFY THE PERMIT. QYES ~ NO ~ N/A (Furth; att«rh*i
1

DETAILS'.

(a) CORRECT NAME AND MAILING ADDRESS OF PERMITTEE.

~ YES
~ NO
~ n/a
(b) FACILITY IS AS DESCRIBED IN PERMIT.

~ YES
~ NO
~ n/a
(e) PRINCIPAL PRODUCT(S) AND PRODUCTION RATES CONFORM WITH THOSE SET FORTH IN PERMIT
APPLICATION.
~ YES
~ NO
~ n/a
(d) TREATMENT PROCESSES ARE AS DESCRIBED IN PERMIT APPLICATION.
~ YES
~ NO
~ n/a
(•) NOTIFICATION GIVEN TO EPA/STATE OF NEW, DIFFERENT OR INCREASED DISCHARGES.
~ YES
~ NO
~ n/a
(f) a;Z(SRATE RECORDS OF RAW WATER VOLUME MAINTAINED.

~ YES
~ NO
~ n/a
(a) NUMBER AND LOCATION OF DISCHARGE POINTS ARE AS DESCRIBED IN PERMIT.
~ YES
~ NO
~ n/a
(h) CORRECT NAME AND LOCATION OF RECEIVING WATERS.

~ YES
~ NO
~ n/a
(i) ALL DISCHARGES ARE PERMITTED.

~ YES
~ NO
~ n/a
SECTION 1 • Operation and Maintenance
TREATMENT FACILITY PROPERLY OPERATEO ANO MAINTAINED. ~
DETAILS:
yes ~ NO ~ n/a (Further explanation attached .
1
(a) STANDBY POWER OR OTHER EQUIVALENT PROVISIONS PROVIOED.
~ YES
~ NO
~ n/a
(b) ADEQUATE ALARM SYSTEM FOR POWER OR EQUIPMENT FAILURES AVAILABLE.
~ YES
~
z
O
~ n/a
(e) REPORTS ON ALTERNATE SOURCE OP POWER SENT TO EPAjfcTATE AS REQUIRED BY PERMIT.
~ YES
~ NO
~ n/a
(d) SLUOGES ANO SOLI OS AO»QUATSLY OISPOSEO.

~ YES
~ NO
~ n/a
(•) ALL TREATMENT UNITVINSERVICE.

~ YES
~ NO
~ n/a
(f) CONSULTING ENGINE!!* RETAINED OR AVAILABLE FOR CONSULTATION ON OPERATION ANO
MAINTENANCE PRQBLEMBi
~ YES
~ NO
~ n/a
la) QUALIFIED OPE RATI NO STAFF PROVIDED.

~ YES
~ NO
~ n/a
th) ESTABLISHED PROCEOURES AVAILABLE FOR TRAINING NEW OPERATORS.
~ YES
~ NO
~ n/a
(j) FILES MAINTAINED ON SPARE PARTS INVENTORY, MAJOR EQUIPMENT SPECIFICATIONS, ANO
PARTS ANO EQUIPMENT SUPPLIERS.
~ YES
~ NO
~ n/a
[j) INSTRUCTIONS FILES KEPT FOR OPERATION ANO MAINTENANCI OP BACH ITEM OP MAJOR
EQUIPMENT.
~ YES
~ NO
~ n/a
(It) OPERATION ANO MAINTENANCE MANUAL MAINTAINED.

~ YES
~ NO
~ n/a
[t> SPCC PLAN AVAILABLE.

~ YES
~ NO
~ n/a
[ml REGULATORY AGENCY NOTIFIED OP BY PASSING. (Dates
1
~ YES
~ NO
~ n/a
In) ANY BY-PASSING SINCE LAST INSPECTION.

~ YES
~ NO
~ n/a
to) ANY HYDRAULIC AND/OR ORGANIC OVERLOADS EXPERIENCED.

~ YES
~ NO
~ n/a
EPA FORM 3560-3 (8-77) PAGE 2 OF 4
- 232 -
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OVfB
A LO
Vo
55 'rootj

Permit
„1 ...
NO.

SECTION J - Compiianc* SchadulM
permittee is MEETING COMPLIANCE SCHEDULE. l]yES ~ no lDn/A (Further explanation attached
CHECK APPROPRIATE PHASE(S):
~ !al THE PERMITTEE MAS OBTAINED THE NECESSARY APPROVALS FROM THE APPROPRIATE
AUTHORITIES TO BEGIN CONSTRUCTION.
C id) proper arrangement has BEEN MADE FOR financing /mortgage commitments, grants, etc.).
~ !c) CONTRACTS FOR ENGINEERING SERVICES HAVE BEEN EXECUTED.
~ id) DESIGN PLANS AND SPECIFICATIONS HAVE BEEN COMPLETED.
~ I»| CONSTRUCTION HAS COMMENCED.
~ ifl CONSTRUCTION AND/OR EQUIPMENT ACQUISITION IS ON SCHEDULE.
~ ;g) CONSTRUCTION HAS BEEN COMPLETED.
Z n) START UP HAS COMMENCED.
~ Tm£ PERMITTEE HAS REQUESTED AN EXTENSION OF TIME.

SECTION K • Self-Monitoring Program
Part 1 - Flow measurement (Further explanation attached j
PERMITTEE FLOW MEASUREMENT MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT.
DETAILS
~ YES
~
NO
C N. A
la) PRIMARY MEASURING DEVICE PROPERLY INSTALLED.
~ YES
~
NO
~ N/A
TYPE OF DEVICE: CjWEIR ~ PARSHALL FLUME DmaGMETER ~ VENTURl METER ~ OTHER (Specify

idi calibration FREQUENCY ADEQUATE. /Date of last calibration 1
~ YES
~
NO
~ n/a
(c) primary FLOW MEASURING OEVICE PROPERLY OPERATED AND MAINTAINED.
~ YES
~
NO
~ N/A
(d)SECONDARY INSTRUMENTS (totalizers, recorders, etc.) PROPERLY OPERATED AND MAINTAINED
~ YES
~
NO
~
•"X,
z
~
le> FLOW MEASUREMENT EQUIPMENT ADEQUATE TO HANDLE EXPECTED RANGES OF FLOW RATES
~ YES
~
NO
~ N/A
Part 2 - Sampling (Further explanation attached j
PERMITTEE SAMPLING MEETS THE REQUIREMENTS AND INTENT OF THE PERMIT.
DETAILS:
~ YES
~
NO
~ N/A
(al LOCATIONS ADEQUATE FOR REPRESENTATIVE SAMPLES.
~ YES
~
NO
~ N/A
(bl PARAMETERS AND SAMPLING FREQUENCY AGREE WITH PERMIT.
~ YES
~
NO
~ N/A
-------
dr~ Aocrovec
OVS Vo IS3 ¦ ROO"
! P E R V
SECTION L • Effluant/Ractiving W«t«r Observations I Further exolanation attached
OUTFALL NO.
OIL SHEEN
GREASE
TURBIDITY
VISIBLE
FOAM
VISIBLE
FLOAT SOL
COLOR
OTHER
(Sections M and N: Complete as appropriate tor sampling inspections)
[SECTION M • S»mpling Impaction Procaduras and Obaarvations tFurther explanation attached )
~ GRAB SAMPLES OBTAINED
~ COMPOSITE OBTAINED
~ FLOW PROPORTIONED SAMPLE
~ AUTOMATIC SAMPLER USED
~ SAMPLE SPLIT WITH PERMITTEE
~ CHAIN OF CUSTODY EMPLOYED
~ SAMPLE OBTAINED FROM FACILITY SAMPLING OEVICE
ICOMPOSITING FREQUENCY
PRESERVATION
SAMPLE REFRIGERATED DURING COMPOSITING: DYES DnO
ISAMPLE REPRESENTATIVE OF VOLUME AND NATURE OF DISCHARGE.
I SECTION N • Analytical Raiultt (Attach report if necessary)
EPA Form 3560-3 (9-77)
- 234 -
PAGE * OF 4
-------
APPENDIX D
Definition of Significant Noncorpliance
In order Co manage mosc effectively che NPDES program with che limited
resources available, EPA has developed criteria for tracking and acting upon
priority violations as directed by the Strategic Planning and Management System
(SPMS). These violations have been defined as a 3ubset of those instances of
noncompliance reported on the Quarterly Noncompliance Report (QNCR) and are
called Significant Noncompliance (SNC). SNC for Che tnosc part is che same as
Category I with some exceptions. See Appendix I for details.
3NC is used Co report priority violations within EPA's management accounta-
bility system and generally indicates the need for agency action unless the
problems are corrected. This in no way implies thac action will not be initiated
against permittees with violations that do not meet SNC criteria. It merely
indicates chat attention should be focused on chose priority violations within
the timeframes specified in the Agency Guidance.
The following sections (II.A-C) assume reader familiarity with the QNCR
reporting criteria. SNC as a subset of the QNCR is shown in chart form in
Appendix I.
II. DEFINITION
SNC is currently defined by criteria for violations of permic, adminiscra-
tive order, and judicial order requirements.
A. PERMIT SIGNIFICANT NONCOMPLIANCE
1. Effluent
Permit effluent SNC criteria are the same as permit effluent QNCR criteria
with the exception of violations that are of concern to the Director but have
not caused or did not have the potential to cause a water quality or health
problem:
- 235 -
-------
a. Violation of Monthly Average Effluent Limits
1) TRC Violations
A violation of a given Group I or Group II parameter at a given dis-
charge point that equals or exceeds the product of TRC times the limit for
any two or raore months during the two quarter review period is SNC.
2) Chronic Violations
Violation of a given Group I or Group II parameter limit at a given
pipe by any amount (not necessarily TRC times the limit or greater) for any
four or more months during the two quarter review period is SNC.
b. Violation of Other Limits
Any effluent violation that causes or has the potential to cause a wacar
quality or health problem is SNC.
2. Schedule
Permit schedule SNC criteria are the same as permit schedule Category I
QNCR criteria. Therefore, Failure to Start Construction, End Construction, or
Attain Final Compliance within 90 days of the scheduled date is SNC.
3. Reporting
Permit reporting SNC criteria are the same as permit reporting Category I
QNCR criteria. Therefore, OMRs, Pretreatment Reports, and the Compliance
Schedule Final Report of Progress (i.e., attain final compliance) that are
submitted 30 or more days late are SNC.
4. Other
There are no "other" permit SNC violations.
B. ADMINISTRATIVE ORDER SIGNIFICANT NONCOMPLIANCE
1. Effluent
Administrative order effluent SNC criteria are currently determined by the
- 236 -
-------
level (stringency) of the effluent limitations estaolished compared to the
permit limitations.
a. Effluent limitations that are as stringent as the current permit (or in the
case of an order issued with the reissuance of a permit such as BAT permits,
as stringent as the prior (or BPT) permit).
Administrative order effluent SNC criteria in this case are the same as
permit effluent SNC criteria:
1) Violation of Monthly Average Effluent Limits
a) TRC Violations
A violation of a given Group I or Group II parameter at a given
discharge ooint that equals or exceeds the product of TRC times the limit
for any two or more months during the two quarter review period is SNC.
b) Chronic Violations
Violation of a given Group I or Group II parameter limit at a given
pipe by any amount (not necessarily TRC tlaes the limit or greater) for
any four or more months during the two quarter review period is SNC.
2. Violation of Other Limits
Any effluent violation that causes or has the potential to cause a
water quality or health problem is SNC.
b. Effluent limitations that are less stringent than the current permit.
Administrative order effluent SNC criteria in this case are the same as
enforcement order effluent QNCR criteria:
1) Violation of Monthly Average Effluent Limits
Any violation of a monthly average effluent limitation cited in an
enforcement order is SNC.
2) Violation of Other Limits
Any violation of an effluent limitation cited in an enforcement order
that causes or has the potential to cause a water quality or health problem
is SNC.
- 237 -
-------
2. Schedule
Administrative order SNC criteria are the same as enforcement order
schedule Category I QNCR criteria. Therefore, Failure to Start Construction,
End Construction, or Attain Final Compliance within 90 days of the scheduled
date is SNC.
3. Reporting
Administrative Order reporting SNC criteria are the same as enforcement
order reporting Category I QNCR criteria. Therefore, DMRs, Pre treatment
Reports, and the Compliance Schedule Final Report of Progress (i.e. , attain
final compliance) that are submitted 30 or more days late are SNC.
4. Other
Any violation of an administrative order requirement other than an
effluent, schedule, or reporting requirement Is SNC. These violations vould
include failure to pay stipulated penalties, maintain required staffing or
follow prescribed operation and maintenance procedures.
C. JUDICIAL ORDER SIGNIFICANT NONCOMPLIANCE
Since violations of judicial orders are of special concern to EPA, judicial
order SNC criteria are the same as enforcement order QNCR criteria:
1. Effluent
a. Violation of Monthly Average Effluent Limits
Any violation of a monthly average effluent limitation cited in a
judical order is SNC.
b. Violation of Other Limits
Any violation of an effluent limitation cited in a judicial order that
causes or has the potential to cause a water quality or health problem is
SNC.
- 238 -
-------
2. Schedule
a. Failure to Start Construction, End Construction, or Attain Final Compliance
within 90 days of the scheduled date is SNC.
b. Failure to achieve any other schedule milestone (other than a report) within
90 days of the scheduled date is SNC. This includes all milestones and
events scheduled as part of the pretreatment program.
3. Reporting
a. DMRs, Pretreatment Reports, and the Compliance Schedule Final Report of
Progress (i.e., attain final compliance) that are submitted 30 or more davs
late are SNC.
b. Additional reports that are submitted 30 days or more late are SNC.
c. All reports (including DKRs, Pretreatment Reports, the Compliance Schedule
Final Report of Progress, and any other reports) that are incomplete or
deficient are SNC.
A. Other
Any violation of a judicial order requirement other than an effluent,
schedule, or reporting requirement is SNC. These violations would include
failure to pay stipulated penalties, maintain required staffing or follow
prescribed operation and maintenance procedures.
D. RESOLUTION OF SIGNIFICANT NONCOMPLIANCE
An instance of SNC is considered resolved when the SNC criteria are no
longer met (e.g., neither two TRC nor four chronic violations of permit
monthly averages occur over the two quarter period) during the review period
or when the permittee formerly in SNC exhibits compliance for all three months
of the most recent quarter.
- 239 -
-------
III. EXCEPTIONS LIST
The Exceptions List Is a report chat is submitted as part of the SPMS
reports. Its purpose is to track timely enforcement against major permittees
that are in SNC in accordance with the Guidance for Oversight of >JPDES Programs
and the Enforcement Management System Guide.
Any major permittee chat is listed on the QNCR tor two consecutive auarters
for the same instance of SNC (e.g., same pipe, same parameter for effluent viola-
tions; same milestone for schedule violations; same report for reporting viola-
tions; and same^requirement for "other" violations) must be listed on the Excep-
tions List unless the permittee was addressed with a formal enforcement order
prior to the completion date of the second QNCR:
February 28 for permittees in SNC on the July-September and October-December
QNCRs;
May 31 for permittees in SNC on the October-December and January-March
QNCRs;
August 31 for permittees in SNC on the January-March and April-June QNCRs;
November 30 for permittees in SNC on the April-June and July-September
QNCRs.
For the purposes of the Exceptions List, a formal enforcement order is
defined in the National Guidance for Oversight of NPDES Programs FY 1986 (page
19). Orders are to be counted as follows:
- Administrative orders and State equivalents are counted when issued
(signed);
- Judicial referrals are counted when forwarded to Headquarters, the
Departaent of Justice, or the State Attorney General.
Permittees ehat appear on the Exceptions List must be accompanied with a justi-
fication of the administering agency's failure to respond to these "priority
violations" with a formal enforcement order within the timeframes specified.
- 240 -
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Group I Pollutants - TRC=1.4
Oxygen Demand
Biochemical Oxygen Demand
Chemical Oxygen Demand
Total Oxygen Demands
Total Organic Carbon
Other
Solids
Total Suspended Solids (Residues)
Total Dissolved Solids (Residues)
Other
Nutrients
Inorganic Phosphorus Compounds
Inorganic Nitrogen Compounds
Other
Detergents and Oils
MBAS
NTA
Oil and Grease
Other detergents or algicides
Minerals
Calcium
Chloride
Fluoride
Magnesium
Sodium
Potassium
Sulfur
Sulfate
Total Alkalinity
Total Hardness
Other Minerals
Metals
Aluminum
Cobalt
Iron
Vanadium
- 241 -
-------
Group II Pollutants - TRC=1.2
Metals (all forms)
Other metals not specifically listed under Group I
Inorganic
Cyanide
Total Residual Chlorine
Organics
All organics are Group II except those specifically listed under
Group I
- 242 -
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f \ UNITED STATES ENVIRONMENTAL PROTECTION AGENC
im * WASHINGTON, D.C. ;.045D
DEC IS 1984
"< md*-"
APPENDIX E office oc
WAT E W
MEMORANDUM
SUBJECT: Calculation of Production-Based Effluent' Limits
FROM: J. William Jordan, Chief
NPDES Technical Support Brarrch (EN-336)
TO: Regional Permits Branch Chiefs
The purpose of this memorandum is to clarify the procedure
for calculating production-based effluent limitations and to pro-
vide guidance on the use of alternate limitations. Many effluent
guidelines are expressed in terms of allowable pollutant dis-
charge rate per unit of production. To determine permit limits,
these standards are multiplied by an estimate of the facility's
actual average production.
Section 122 . 45(b) of the NPDES perr.it program regulations
sets forth the requirements for calculating production-based
effluent limitations. The central feature of this section is the
requirement that limitations be based upon a "reasonable measure
of the actual production of the facility", rather than upon design
capacity. Interpretation of this requirement has proven confusing
in the past. This memorandum provides recommendations for devel-
oping production-based limitations and alternate limitations. Tne
Agency is also pla-nning to revise this portion of the regulations,
and has revised Part III of Application Form 2C, in order to clarify
language which might lead to the use of inappropriate production-
based limitations.
Background
The proper application of production-based effluent limita-
tion guidelines is dependent upon the methodology that is used to
develop the guidelines. When most guidelines are developed, a
single long term average daily production value and its relation-
ship to flow are determined. This is combined with effluent
concentration data collected from plants to form the basis of
the guideline standards. Variability factors are developed on
concentration data obtained from samples taken during periods
of varying production. The variability factors and performance
data are then used to derive the guideline standards.
Calculation of Limitations
To apply these guidelines, perm,it writers should aererr.ine
- 243 -
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a single estimate of the expected production over the life of
the permit using the long term average production from the plant's
historical records. Usually,.a five year production history
would be used to derive this value. This single production value
is then multiplied by both the daily maximum and monthly average
guidelines limitations to obtain permit limits. In determining
this single estimate, the permit writer should take into account
the distribution of production by analyzing data taken as fre-
quently as possible. For most cases, monthly data compiled from
daily data would be sufficient.
The permit writer should avoid the use of a limited amount
of production data in estimating the production for a specific
facility. For example, the data from a particular month may
be unusually high and thus lead to the derivation of effluent
limitations which are not actually reflective of normal plant
operations. As previously explained, effluent limitations
guidelines already account for some of the variations which
occur within long term production rates. Therefore, the use of
too short a time frame in the calculation of production based
limitations for a specific industrial facility may lead to
"double accounting" of the variability factors.
In some cases, the historical data may show large random
or cyclic fluctuations in production rates, of either a short
or long term nature. In those situations, it may be appropriate
to have alternate limits which are applicable at some increased
production rate (see discussion of Alternate Limits) or setting
the limit based upon a level of production higher than the
average (e.g. 10-20 percent or higher).
However, the primary objective is to determine a production
estimate for a facility which approximates the long term aver-
age production rate (in terms of mass of product per day) which
can reasonably be expected to prevail during the next term of
the permit. The following example illustrates the proper apDli-
cation of guidelines:
Example: Company A has produced 331,500 tons, 292,000
tons, 304,000 tons, 284,000 tons, and 312,00n tons per year
for the previous five years. The use of the highest year of
production (331,500 tons per year) might be an appropriate
and reasonable measure of expected production. ;One check
on this could be to determine if maximum.year!y values are
within a certain percent of the overage, such as 20 percent.
iOne of several methods may be appropriate to convert
from the annual production rate to average daily production.
One method takes the annual production rate and divides it
by the number of production days per year. To determine the
number of production days, the total number of normally sche-
duled non-production days are subtracted from the total days
in a year.
This method is appropriate in cases where the plant
- 2M -
-------
discharges intermittently as a direct result of proc'jcticn
flows. In cases where the plant discharges continuouslv ,
even on days when there are no production activities, ctr.e
methods may be appropriate.
If Company A normally has 255 production days per yea
which are approximately equal to the number of discharge d
the annual production rate of 331,500 tons per year would
yield an average daily rate of 1,300 ton's per day. If pel
tant X has an effluent limitation guideline of 0.10 lbs'./I
lbs. for the monthly average and 0.15- lbs ./1000 lbs. for t'
maximum daily average, the effluent limitations would be
calculated as follows:
Monthly Average Limit (Pollutant X)
1,300 tons x 2000 lbs, x 0.10 lbs. = 260 lbs./rt*„
daV ton 1000 lbs.
Daily Maximum Limit (Pollutant X)
1 ,300 tons X 2000 lbs. X O.IS 1 h«. = 390 1bs./rt,„
day ton 1000 lbs.' "
'!]e fxamP^e above, the production during the hiahes*-
year of the last five years was used as the estimate of pro-
duction. This estimate is appropriate when production is not
expected to change significantly during the permit term. How-
6Vfr' ?iS'°rlfaLtrends' forces, or company plans
indicate that a different level of production will prevail d„.
tion shoulc^be us*™.' * ^ £°r «timatinPg produc-'
Alternate Limits
. If Pro^V^tio" f,ates are expected to change signif icantl v
during the life of the permit, the permit can incite alTiHt-e
Units. These alternate limits would become effective when
production exceeds a threshold value, such as during seasonal
production variations Definitive guidance is not available
with respect to the threshold value which should "trigger-
alternate limits. However, it is generally agreed that a 10
to 20 percent fluctuation in production is within the range
ty' rhile chan9« in production substantial^
higher than this range (such as SO percent), could warrant con-
SJ Imitations. The major characterises
limits are best described by illustration and exa-p
7?n'"nnn;|-r.Plar'Ln !?aS produced 486 ,000 tons, 260 ,400 tons,
the '1111°™ '£ < 'y °rs°nVe^ • 2h°6 '5°° t0n£ ¦
araument'that'16 T* ^ ^ mX^Sble
The auidplino Productlon is expected to return to that •pvs
nnn-Mvi n Pollutant x is 0.8 lbs./lOOO lbs. £ — the
"¦ v •»* 0.1,: lb. /L00O in for tV^
- 7SS, -
-------
mum. The alternate effluent limitations could be calculated
as follows:
Primary Limits:
o Basis of calculation: 260,400 tons/yr. = 1 ,050 tons/day
(2-48 production days per year)
o Applicable level of production: less than 1 ,050 tons
per day average production rate for the month
Monthly Average Limit
1 ,050 tons x 2000 lbs. x 0.08 1bs. = 168 lbs ./day
day ton 1000 1bs.
Daily Maximum Limit
1 ,050 tons x 2000 lbs. x 0.14 lbs. ¦ 294 lbs ./day
day ton 1000 lbs.
Alternate Limits:
o Applicable threshold level of production = more than 1 ,260
tons/day average production rate for the month (20 percent
above normal production levels)
o Basis of calculation: 486,000 tons/yr. - 1,350 tons/day
(based upon historical data and to be applicable beyond
a 20 percent increase in production)
Monthly Average Limit = 216 lbs./day
Daily Maximum Limit = 378 lbs./day
Alternate limits should be used only after careful consider-
ation and only when a substantial increase or decrease in produc-
tion is likely to occur. In the example above, the primary limits
would be in effect when production was at normal levels. During
periods of significantly higher production, the alternate limits
would be in effect. When production reverted to normal levels, the
primary limits would have to be met. The thresholds, measures of
production, and special reporting requirements must be detailed in
the permit.
If you have any questions concerning the calculation of pro-
duction-based limitations or the use of alternate limitations,
please call me or have your staff contact James Taft at (202/FTS-
426-7010).
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