EPA-821 -B-05-007
Preliminary Report:
Pulp, Paper, and Paperboard
Detailed Study
U.S. Environmental Protection Agency
Engineering and Analysis Division
Office of Water
1200 Pennsylvania Avenue, NW
Washington, D.C. 20460
August 2005
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ACKNOWLEDGMENT AND DISCLAIMER
This report was prepared with the technical support of Eastern Research Group,
Inc. under the direction and review of the Office of Science and Technology. Neither the United
States Government nor any of its employees, contractors, subcontractors, or their employees
make any warrant, expressed or implied, or assume any legal liability or responsibility for any
third party's use of, or the results of, such use of any information, apparatus, product, or process
discussed in this report, or represents that its use by such party would not infringe on privately
owned rights.
The primary contact regarding questions or comments on this document is:
Carey Johnston
U.S. EPA Engineering and Analysis Division (4303T)
1200 Pennsylvania Avenue NW
Washington, DC 20460
(202) 566-1014 (telephone)
(202) 566-1053 (fax)
johnston.carey@epa.gov
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1-1
1.1 Industry Description 1-2
1.2 Regulatory Background 1-4
1.3 Detailed Study Scope 1-6
1.4 Detailed Study Status 1-7
2.0 DATA SOURCES 2-1
2.1 PCS 2-1
2.2 TRI 2-3
2.3 NPDES Permits 2-5
2.4 Information Provided by Industry and Trade Associations 2-7
3.0 PULP AND PAPER CATEGORY WASTEWATERPOLLUTANTS 3-1
3.1 Dioxins 3-1
3.2 PACs 3-3
3.3 PCSLoads2002 Results 3-5
3.4 TRIReleases2002 Results 3-9
4.0 CLUSTER RULE IMPLEMENTATION AND IMPACT 4-1
4.1 Detailed Summary of 1998 ELGs Revisions (Cluster Rules) 4-1
4.1.1 Best Available Technology and Pretreatment Standards 4-3
4.1.2 VATIP and Limits for TCP Mills 4-5
4.1.3 Support Documents 4-7
4.2 Incorporation of Cluster Rules into NPDES Permits 4-7
4.2.1 Bleached Papergrade Kraft Mills 4-8
4.2.2 POTWs 4-11
4.2.3 Papergrade Sulfite Mills 4-11
4.3 Analysis of Compliance Monitoring Data 4-13
4.3.1 Bleached Papergrade Kraft 4-14
4.3.2 Papergrade Sulfite 4-29
4.3.3 Washington State Paper Mills 4-31
5.0 REVIEW OF TRIDATA 5-1
5.1 TRIReleases2002 Results Discussed with AF&PA 5-2
5.2 TRI-Reported Dioxins Releases 5-3
5.3 Comparison of TRI and PCS Dioxins Discharge Data 5-7
5.4 TRI-Reported PACs 5-9
5.5 Metals and Other Chemicals Reported to TRI 5-12
6.0 STATUS OF THE DETAILED STUDY AND NEXT STEPS 6-1
6.1 Analysis of the Implementation and Impact of the Cluster Rules 6-1
6.2 Investigation of the Non-bleaching Sources of Toxic and
Nonconventional Pollutants 6-2
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TABLE OF CONTENTS (Continued)
Page
6.3 Requests for Additional Information 6-4
7.0 REFERENCES 7-1
Appendix A PCS DISCHARGE LOCATIONS AND EPA DESIGNATED PIPE USAGE
Appendix B CURRENT STATUS OF PHASE I MILLS
11
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LIST OF TABLES
Page
1-1 Number of Pulp and Paper Facilities 1-3
1-2 Relationship Between Pulp and Paper Regulatory Phases and
Subcategories 1-5
2-1 Phase I Mill NPDES Permits Collected 2-6
2-2 NPDES Permits Requested, But Not Received by July 2005 2-7
3-1 Dioxins and Their Toxic Weighting Factors 3-2
3-2 Definition of PACs 3-4
3-3 Top 10 Pollutants in PCSLoads2002, Discharges by Pulp Regulatory Phase . . 3-6
3-4 Results of Review of Mill-Provided PCS Corrections 3-7
3-5 PCSLoads2002 TWPE by Phase, With and Without Bowater
Catawba Mill TCDD Discharges 3-9
3-6 Top 10 Pollutants in TRIReleases2002, Releases by Regulatory Phase3 3-10
3-7 TRIReleases2002 TWPE by Regulatory Phase, with and without Dioxins .. 3-12
4-1 Compliance Points for Cluster Rules Regulated Pollutants 4-2
4-2 Subpart B (Bleached Papergrade Kraft and Soda) BAT Effluent Limitations
Guidelines and Pretreatment Standards for Existing Sources 4-4
4-3 Subpart E (Papergrade Sulfite) BAT Effluent Limitations
Guidelines and Pretreatment Standards for Existing Sources 4-5
4-4 Bleached Kraft Mills Operating Beyond Compliance 4-6
4-5 Number of Permits for Bleached Kraft Mills Missing Cluster Rules
Monitoring Requirements 4-8
4-6 Permits for Bleached Kraft Mills Missing Required Bleach Plant
Monitoring 4-9
4-7 Permits for Bleached Kraft Mills Missing Required Final Effluent
AOX Monitoring 4-11
111
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LIST OF TABLES (Continued)
Page
4-8 Operating Papergrade Sulfite Mills 4-12
4-9 Number of Permits for Papergrade Sulfite Mills Missing Cluster
Rules Monitoring Requirements 4-13
4-10 Comparison of Permit-Required Monitoring and Monitoring Data
in PCS, for Direct Discharge Bleached Kraft Mills 4-15
4-11 Number of Bleached Kraft Mills With Permit Limits but No Data
in PCS and Why Data are Missing 4-16
4-12 Number of Mills Reporting TCDD and TCDF Monitoring Data to
PCS, 1998 through 2004 4-16
4-13 Concentration of TCDD and TCDF Detected in Bleached
Papergrade Kraft Mill Wastewaters (pg/L) 4-18
4-14 Number of Bleached Papergrade Kraft Mills Reporting
Chlorinated Phenolic Compounds Data to PCS 4-20
4-15 Concentrations of Chlorinated Phenolic Compounds Detected in
Bleached Papergrade Kraft Mill Bleach Plant Effluent (|ig/L) 4-21
4-16 Number of Mills Reporting Chloroform Monitoring Data to PCS,
by Year, and Relative to Baseline 4-23
4-17 Annual Loads of Three Mills with Chloroform Loads Above
Baseline Loads 4-24
4-18 Number of Mills Reporting Monitoring Data for AOX, COD, and
Color to PCS by Year and Relative Baseline Loads 4-25
4-19 Number of Mills With COD or Color Data in PCS in 2004, by State 4-26
4-20 Mills for Which Calculated Annual Load Exceeded EPA
Estimated Baseline Load for More than One Pollutant 4-28
4-21 Weyerhaeuser Flint River Mill (Oglethorpe GA) Calculated
Annual Load Compared to EPA Estimated Baseline Load 4-28
4-22 Loads for Two Papergrade Sulfite Mills, 1995 Baseline and 1998
through 2004 4-30
IV
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LIST OF TABLES (Continued)
Page
4-23 Counts of TCDD and TCDF Detected in Washington State Phase I
Mill Bleach Plants 4-32
5-1 Top 10 Pollutants in TRIReleases2002, for Phase I and Phase II 5-2
5-2 Dioxin and Dioxin-Like Compound Releases to Water Reported in
TRI by Top 10 Mills for Reporting Year 2002 5-5
5-3 Number of Mills' TRI Estimation Techniques for Mills Reporting
Non-Zero Dioxins Discharges 5-7
5-4 Comparison of TRI and PCS; Number of Mills Reporting Non-
Zero Releases and Mass of Dioxins Released 5-7
5-5 PAC Releases to Water Reported in TRI by Top 10 Mills for
Reporting Year 2002 5-10
5-6 PAC Concentrations in Pulp Mill Effluents (H.-C. Lavellee, Inc. 1990)a 5-11
5-7 Number of Mills Reporting PAC TRI Estimation Techniques, by
Phase and Discharge Type 5-12
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ACRONYMS
2,3,7,8-TCDD
2,3,7,8-TCDF
AF&PA
AOX
BAT
BCT
BOD5
BPK
BPT
CDD
CDF
CFR
COD
CTMP
CWA
DCN
DMR
ECF
EDS
ELGs
EPA
FR
ML
NAICS
NCASI
NESHAP
NPDES
NSPS
PAC
PAH
PCS
pH
POTW
PS
PSES
PSNS
SIC
TCF
IMP
TRI
TWPE
TWFs
VATIP
2,3,7,8-tetrachlorodibenzo-/?-dioxin
2,3,7,8-tetrachlorodibenzofuran
American Forest and Paper Association
Adsorbable Organic Halides.
Best Available Technology Economically Achievable
Best Conventional Pollutant Control Technology
Five-day Biochemical Oxygen Demand
Bleached Papergrade Kraft
Best Practicable Control Technology
Chlorinated Dibenzo-p-Dioxins
Chlorinated Dibenzofurans
Code of Federal Regulations
Chemical Oxygen Demand
Chemi-Thermo-Mechanical Pulp
Clean Water Act
Document Control Number
Discharge Monitoring Reports
Elemental Chlorine-Free
Effluent Data Statistics
Effluent Limitations Guidelines and Standards
U.S. Environmental Protection Agency
Federal Register
Minimum Level
North American Industry Classification System
National Council of the Paper Industry for Air and Stream Improvement,
Inc.
National Emission Standards for Hazardous Air Pollutants
National Pollutant Discharge Elimination System
New Source Performance Standards
Polycyclic Aromatic Compounds
Polycyclic Aromatic Hydrocarbons
Permit Compliance System
Negative logarithm of the effective hydrogen-ion concentration in moles
per liter, a measure of acidity
Publicly Owned Treatment Works
Papergrade Sulfite
Pretreatment Standards for Existing Sources
Pretreatment Standards for New Sources
Standard Industrial Classification
Totally Chlorine-Free
Thermo-Mechanical Pulp
Toxics Release Inventory
Toxic-Weighted Pound Equivalents
Toxic Weighting Factors
Voluntary Advanced Technology Incentives Program
VI
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GLOSSARY
2,3,7,8-tetrachlorodibenzo-p-dioxin (2,3,7,8-TCDD) and 2,3,7,8-tetrachlorodibenzofuran
(2,3,7,8-TCDF) - Two CDD and CDF congeners with chlorine substitution of hydrogen atoms at
the 2, 3, 7, and 8 positions on the benzene rings. EPA promulgated 1998 Cluster Rules which
included ELGs for these two congeners. Because of the ELGs, most pulp and paper mills are
typically required to monitor for 2,3,7,8-TCDD and 2,3,7,8-TCDF and these monitoring results
are compiled in EPA's Permit Compliance System.
Adsorbable Organic Halides (AOX) - A bulk parameter that measures the total mass of
chlorinated organic matter in water and wastewater.
American Forest and Paper Association (AF&PA) - The national trade association of the
forest, pulp, paper, paperboard and wood products industry. AF&PA represent member
companies engaged in growing, harvesting and processing wood and wood fiber, manufacturing
pulp, paper and paperboard products from both virgin and recycled fiber, and producing
engineered and traditional wood products.
Bleach plant - All process equipment used for bleaching beginning with the first application of
bleaching agents (e.g., chlorine, chlorine dioxide, ozone, sodium or calcium hypochlorite, or
peroxide), each subsequent extraction stage, and each subsequent stage where bleaching agents
are applied to the pulp. For mills in Subpart E producing specialty grades of pulp, the bleach
plant includes process equipment used for the hydrolysis or extraction stages prior to the first
application of bleaching agents. Process equipment used for oxygen delignification prior to the
application of bleaching agents is not part of the bleach plant.
Bleach plant effluent - The total discharge of process wastewaters from the bleach plant from
each physical bleach line operated at the mill, comprising separate acid and alkaline filtrates or
the combination thereof.
Bleached pulp - Pulp that has been purified or whitened by chemical treatment to alter or
remove coloring matter and has taken on a higher brightness characteristic.
Bleaching - The process of further delignifying and whitening pulp by chemically treating it to
alter the coloring matter and to impart a higher brightness.
Bleaching chemicals - A variety of chemicals used in the bleaching of pulp such as chlorine
(C12), sodium hypochlorite (NaOCl), calcium hypochlorite (Ca(OCl)2), chlorine dioxide (C1O2),
peroxide (H2O2), oxygen (O2), ozone (O3), and others. Also referred to as bleaching chemical.
Conventional pollutants - The pollutants identified in Section 304(a)(4) of the CWA and the
regulations thereunder (biochemical oxygen demand (BOD5), total suspended solids (TSS), oil
and grease, fecal coliform, and pH).
Cluster Rules - The Cluster Rules apply to mills with operations subject to 40 CFR Part 430
Subpart B, Bleached Papergrade Kraft and Soda, and Subpart E, Papergrade Sulfite. The Cluster
VII
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GLOSSARY (Continued)
Rules regulate toxic and nonconventional pollutants that are characteristic of mills that bleach
chemical pulp with chlorine-containing compounds. These pollutants include adsorbable organic
halides (AOX), chloroform, TCDD, TCDF, and 12 chlorinated phenolic compounds.
Deinked Pulp - Fiber reclaimed from wastepaper by removing ink, coloring materials, and
fillers.
Dioxin and Dioxin-like Compounds - The 17 CDDs and CDFs compounds (called congeners)
which include chlorine substitution of hydrogen atoms at the 2, 3, 7, and 8 positions on the
benzene rings. The 17 congeners are referred to as 'dioxin-like,' because of the similar chemical
structure, similar physical-chemical properties, and invoke a common battery of toxic responses,
though the toxicity of the congeners varies greatly. The TRI method of reporting requires that
facilities report the total mass of all 17 congeners.
Direct discharger - A facility that discharges or may discharge treated or untreated process
wastewaters, non-contact cooling waters, or non-process wastewaters (including stormwater
runoff) into waters of the United States.
Discharge Monitoring Reports (DMRs) - Compliance reports required by NPDES permits.
Facilities with major discharges are required to monitor their discharges and submit monitoring
reports to their permitting authority at a frequency specified by the permit.
Effluent Data Statistics (EDS) - An EPA mainframe computer program than calculates facility
annual pollutant loads (kg/year) using compliance monitoring data reported in PCS.
Effluent limitation - Any restriction, including schedules of compliance, established by a State
or the Administrator on quantities, rates, and concentrations of chemical, physical, biological,
and other constituents which are discharged from point sources into navigable waters, the waters
of the contiguous zone, or the ocean.
Effluent limitations guidelines and standards (ELGs) - Categorical regulations developed by
EPA as required by the Clean Water Act.
Elemental chlorine-free (ECF) - Any process for bleaching pulps in the absence of elemental
chlorine and hypochlorite that uses chlorine dioxide as the only chlorine-containing bleaching
agent.
Fiber line - A series of operations employed to convert wood or other fibrous raw material into
pulp. If the final product is bleached pulp, the fiber line encompasses pulping, de-knotting,
brownstock washing, pulp screening, centrifugal cleaning, and multiple bleaching and washing
stages.
Final effluent - Pulp or paper mill wastewater discharges to receiving waters including streams,
lakes, and other waters of the U.S.
Vlll
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GLOSSARY (Continued)
Indirect discharger - A facility that discharges or may discharge wastewaters into a publicly
owned treatment works or a treatment works not owned by the discharging facility.
Integrated mill - A mill that produces pulp and may use none, some, or all of that pulp (often in
combination with purchased pulp) to produce paper or paperboard products.
Kraft process - Sulfate chemical pulping process.
Mechanical pulp - Pulp produced by reducing pulpwood logs and chips into their fiber
components by the use of mechanical energy (at CMP or CTMP mills, also with the use of
chemicals or heat), via grinding stones or refiners.
Minimum level (ML) - The level at which the analytical system gives recognizable signals and
an acceptable calibration point. The MLs for pollutants regulated by the Cluster Rules are
specified in 40 CFR 430.01(1).
North American Industry Classification System (NAICS) - A system for classifying
economic activity developed jointly by the U.S., Canada, and Mexico.
National Council of the Paper Industry for Air and Stream Improvement, Inc (NCASI) -
An independent, non-profit research institute that focuses on environmental topics of interest to
the forest products industry. NCASI is a source of data on environmental issues affecting this
industry, and has more than 75 member companies throughout the US and Canada.
Nonconventional pollutants - Pollutants that are neither conventional pollutants nor priority
pollutants (see 40 CFR Section 401.15 and Part 423, Appendix A).
National Pollutant Discharge Elimination System (NPDES) - The NPDES program is
authorized by the Clean Water Act and requires permits for the discharge of pollutants from any
point source into waters of the United States.
Outfall - The mouth of conduit drains and other conduits from which a mill effluent discharges
into receiving waters.
Picograms (pg) - one trillionth (10"12) of a gram. One pg/liter is equivalent to one part per
quadrillion (ppq).
Polycyclic Aromatic Compounds (PAC) - Sometimes known as polycyclic aromatic
hydrocarbons (PAHs), are a class of organic compounds consisting of two or more fused
aromatic rings.
PCSLoads2002 - A Microsoft Access™ database in which EPA has compiled data taken from
PCS, the calculated TWPE, and the relationship between SIC codes and regulatory categories.
IX
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GLOSSARY (Continued)
Permit Compliance System (PCS) - An EPA mainframe database created by EPA to track
permit, compliance, and enforcement status of facilities regulated by the National Pollutant
Discharge Elimination System (NPDES) program under the CWA.
Peroxide - A short name for hydrogen peroxide (H2O2) or sodium peroxide (Na2O2).
Polychlorinated dibenzo-p-dioxins (CDDs) and polychlorinated dibenzofurans (CDFs) -
CDDs and CDFs constitute a group of persistent, bioaccumulative, and toxic chemicals.
Facilities are required to report to EPA's TRI the total mass of 17 of these CDDs and CDFs
released to the environment every year. The 17 compounds (called congeners) are referred to as
'dioxin-like,' because they have similar chemical structure, similar physical-chemical properties,
and invoke a common battery of toxic responses, though the toxicity of the congeners varies
greatly.
Pretreatment standard - A regulation addressing industrial wastewater effluent quality required
for discharge to a POTW.
Process wastewater - For the effluent guidelines for Subparts B and E of the Pulp, Paper, and
Paperboard Category (40 CFR Part 430), process water is any water that, during manufacturing
or processing, comes into direct contact with or results from the production or use of any raw
material, intermediate product, finished product, byproduct, or waste product. For purposes of
Subparts B and E, process wastewater includes boiler blowdown; wastewaters from water
treatment and other utility operations; blowdowns from high rate (e.g., greater than 98 percent)
recycled non-contact cooling water systems to the extent they are mixed and co-treated with
other process wastewaters; wastewater, including leachates, from landfills owned by pulp and
paper mills subject to Subparts B or E if the wastewater is commingled with wastewater from the
mill's manufacturing or processing facility; and storm waters from the immediate process areas
to the extent they are mixed and co-treated with other process wastewaters. Contaminated
groundwaters from on-site or off-site groundwater remediation projects are not process
wastewater.
Process water - Water used to dilute, wash, or carry raw materials, pulp, and any other materials
used in the manufacturing process.
Pretreatment Standards for Existing Sources (PSES) - categorical regulations for indirect
dischargers designed to prevent the discharge of pollutants that pass through, interfere with, or
are otherwise incompatible with the operation of POTWs, including sludge disposal methods at
POTWs.
Pulp and Paper Category, Phase I - When EPA revised 40 CFR Part 430 in 1998, it
reorganized the category into 12 subcategories and promulgated new ELGs for two
subcategories, Subpart B (Bleached Papergrade Kraft and Soda) and Subpart E (Papergrade
Sulfite). Subparts B and E became known as Phase I; EPA promulgated revised ELGs for these
subparts April 15, 1998 (63 FR 18504; April 15, 1998).
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GLOSSARY (Continued)
Pulp and Paper Category, Phase II - EPA planned to promulgate ELGs for the Phase II
subcategories (Subparts C and F through L) after promulgating the final rules for the Phase I
subcategories.
Pulp and Paper Category, Phase III - The two dissolving pulp subcategories (Subpart A,
Dissolving Kraft, and Subpart D, Dissolving Sulfite).
Pulp bleaching - The process of further delignifying and whitening pulp by chemically treating
it to alter the coloring matter and to impart a higher brightness.
Secondary fiber - Furnish consisting of recovered material. Secondary fiber includes recycled
paper or paperboard known commonly as "post-consumer" recycled material. The term
secondary fiber is used both for the raw material (wastepaper, old corrugated containers, etc.)
and the pulp produced from the wastepaper and board.
Standard Industrial Classification (SIC) - A system for classifying economic activity
developed by the Office of Management and Budget and used by other government agencies,
including EPA, to promote data comparability. In the SIC system, each establishment is
classified according to its primary economic activity, which is determined by its principal
product or group of products. An establishment may have activities in more than one SIC code.
Soda process - A chemical pulping process that consists of the reduction of chips to their
individual fiber components by use of cooking liquor made up of caustic soda (NaOH) solution,
the recovery and preparation of this liquor, or the treatment of pulp and paper produced from it.
Sulfite process - An acid pulp manufacturing process in which chips are reduced to their
component parts by cooking (digesting) in a pressurized vessel using a liquor of calcium,
sodium, magnesium or ammonia salts of sulfurous acid.
Totally chlorine-free (TCF) bleaching - Pulp bleaching operations that are performed without
the use of chlorine, sodium hypochlorite, calcium hypochlorite, chlorine dioxide, chlorine
monoxide, or any other chlorine-containing compound.
Toxics Release Inventory (TRI) - TRI is the common name for Section 313 of the Emergency
Planning and Community Right-to-Know Act (EPCRA). Each year, facilities that meet certain
thresholds must report their releases and other waste management activities for listed toxic
chemicals. That is, facilities must report the quantities of toxic chemicals recycled, collected and
combusted for energy recovery, treated for destruction, or disposed of. A separate report must be
filed for each chemical that exceeds the reporting threshold. EPA compiles the reported
information into a publicly-available database known as the Toxics Release Inventory.
Toxic-weighted pound equivalents (TWPE) - Multiplying the pounds of pollutants discharged
by chemical-specific toxic weighting factors results in an estimate of toxic-weighted pound
equivalents (TWPE).
XI
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GLOSSARY (Continued)
Toxic weighting factors (TWFs) - Weighting factors that reflect both aquatic life and human
health effects and were developed by Office of Water/Engineering and Analysis Division (BAD)
for use in regulatory development.
TRIReleases2002 - A Microsoft Access™ database in which EPA has compiled data taken from
TRI, the adjusted releases from POTWs to surface waters, the calculated TWPE, and the
relationship between SIC codes and regulatory categories.
Unbleached pulp - Pulp that has not been treated in a bleaching process.
Voluntary Advanced Technology Incentives Program (VATIP) - The program established
under 40 CFR Part 430.24(b) (for existing direct dischargers) and 40 CFR Part 430.25(c) (for
new direct dischargers) whereby participating mills agree to accept enforceable effluent
limitations and conditions in their NPDES permits that are more stringent than the "baseline
BAT limitations or NSPS" that would otherwise apply, in exchange for regulatory- and
enforcement-related rewards and incentives.
Wastewater - Water carrying waste materials from a facility. It is a mixture of water, and
dissolved and suspended pollutants.
XII
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i.o INTRODUCTION
Section 304(b) of the Clean Water Act requires EPA to annually review and, if
appropriate, revise its technology-based regulations, called "effluent limitations guidelines and
standards" or "effluent guidelines." These guidelines limit the discharge of pollutants to waters
of the United States from various categories of industrial facilities. Every other year, Section
304(m) of the Clean Water Act requires EPA to publish a plan establishing a schedule for the
annual review and revision of effluent guidelines required by Section 304(b). EPA last
published an Effluent Guidelines Program Plan in 2004 (64 FR; 53705; September 2, 2004).
During its 2005 screening-level analysis of discharges from categories with
existing regulations, EPA determined that the Pulp, Paper, and Paperboard Point Source
Category ranked higher than any other category in discharges of toxic and nonconventional
pollutants1. For more information on the development of the category ranking see the 2005
Screening-Level Analysis Report [1]. Because of these findings, EPA is conducting a more
detailed study of this category. During this study, EPA will first verify that the pollutant
discharges reported to PCS and TRI for 2002 accurately reflect the current discharges of the
industry. EPA will also perform an in-depth analysis of the reported pollutant discharges, and as
appropriate, will review technology innovation and process changes including a preliminary
assessment of technology cost and affordability. Additionally, EPA will consider whether there
are industrial sectors not currently subject to effluent guidelines or pretreatment standards that
should be considered potential new subcategories of this category. The purpose of the detailed
study is to determine whether it would be appropriate for EPA to revise the existing effluent
guidelines. EPA's decision to conduct a detailed study on this category does not mean that EPA
is required to revise its regulations for this category. EPA will make such a decision as part of
the final 2006 Effluent Guidelines Program Plan.
'One mill accounted for more than 99% of 2,3,7,8-tetrachlorodibenzo-p-dioxin discharges tallied in EPA's Permit
Compliance System (PCS) for this industrial category in 2002. With or without these discharges from this one mill,
this category ranks higher than any other category in terms of the estimated combined 2002 toxic discharges from
EPA's Toxic Release Inventory (TRI) and PCS databases. See Section 3.3 for more discussion of this mill's
discharges.
1-1
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1.1 Industry Description
Mills that manufacture pulp, paper, or paperboard are generally classified under
three Standard Industrial Classification (SIC) codes that identify their principal product or group
of products. The three SIC codes assigned to the Pulp, Paper, and Paperboard Point Source
Category (hereafter, the Pulp and Paper Category) are:
SIC Code 2611 - Pulp Mills: Establishments primarily engaged in
manufacturing pulp from wood or from other materials, such as rags,
linters, wastepaper, and straw.
SIC Code 2621 - Paper Mills: Establishments primarily engaged in
manufacturing paper from wood pulp and other fiber pulp, and which may
also manufacture converted paper products.
SIC Code 2631 - Paperboard Mills: Establishments primarily engaged in
manufacturing paperboard, including paperboard coated on the paperboard
machine, from wood pulp and other fiber pulp; and which may also
manufacture converted paperboard products.
A mill may have activities in one or more SIC code. For example, integrated mills
make pulp from wood or other raw materials (SIC code 2611). They then use this pulp to make
paper (SIC code 2621) and/or paperboard (SIC code 2631). Thus, an integrated mill's primary
product may be paper, but it also manufactures pulp. The pulp manufacturing operations are
likely to be the major source of wastewater pollutants. A non-integrated mill does not make
pulp, but purchases pulp to make paper or paperboard.
Table 1-1 lists the three SIC codes assigned to the Pulp and Paper Category and
eight SIC codes for facilities that make products from paper or paperboard. EPA is considering
including operations of these eight additional SIC codes as potential new subcategories of the
Pulp and Paper Category. See Section 5.3 of the 2005 Screening-Level Analysis Report [1].
Table 1-1 also lists the North American Industrial Classification System (NAICS)
codes that apply to the pulp and paper industry. The U.S. Economic Census reports data by the
NAICS code. However, the wastewater discharge information in EPA's TRI and PCS databases
1-2
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is organized by SIC code. For this reason, to compare the number of facilities enumerated by the
census to the number of facilities in the EPA databases, the NAICS data in Table 1-1 have been
converted to the equivalent SIC code. Note that SIC codes 2621, 2671, and 2679 do not translate
directly to individual NAICS codes.
Table 1-1. Number of Pulp and Paper Facilities
SIC
Code
2611
2621
2631
NAICS
Code
3221-10
3221-21,
3221-22
3221-30
Point Source Category
Pulp Mills
Paper Mills
Paperboard Mills
2002 U.S.
Economic
Census
32
329
199
560
2002
TRI1
76
151
101
328
2002 PCS2
Major
88
120
44
252
Minor
9
21
10
40
Potential New Subcategories
2653
2655
2656
2657
2671
2672
2674
2679
3222-11
3222-14
3222-15
3222-12
3222-21,
326112
3222-22
3222-24
3222-31,
3222-99
Corrugated and Solid Fiber Boxes
Fiber Cans, Tubes, Drums, and
Similar Products
Sanitary Food Containers, Except
Folding
Folding Paperboard Boxes,
Including Sanitary
Packaging Paper and Plastics
Film, Coated and Laminated
Coated and Laminated Paper, Not
Elsewhere Classified
Uncoated Paper and Multiwall
Bags
Converted Paper and Paperboard
Products, Not Elsewhere
Classified
1,719
261
72
490
391
541
123
869
4,466
16
2
4
7
50
90
1
11
181
0
6
4
1
10
2
4
27
Source: U.S. Economic Census, 2002; TRIReleases2002; PCSLoads2002.
'Releases to any media.
2PCS is divided into major and minor dischargers.
As shown in Table 1-1, more facilities are identified as SIC code 2611 (pulp
mills) in EPA's TRI and PCS databases than are counted in the census as establishments
primarily engaged in manufacturing pulp. For the census, facilities are assigned to an SIC code
based on the revenues from products sold. For TRI, facilities identify the SIC codes that are the
1-3
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source of their toxic releases. For PCS, permitting authorities identify the SIC code that is the
sources of wastewater discharges. Many mills manufacture pulp but use it on site to make paper
instead of selling it on the market. Also, pulping operations generate more pollutant loads than
paper and paperboard manufacturing operations. For these reasons, the number of facilities
identified as pulp mills in EPA's databases is greater than the number of pulp mills counted by
the census .
Table 1-1 also shows that EPA's databases have information for more facilities in
the three SIC codes assigned to the Pulp and Paper Category than they do for the eight SIC codes
that are potential new subcategories. More than 50% of the facilities counted by the census for
the three SIC codes assigned to the Pulp and Paper Category have data in EPA's databases
compared to less than 5% of facilities in the eight SIC codes that are potential new
subcategories.
1.2 Regulatory Background
Between 1974 and 1986, EPA promulgated effluent limitations guidelines and
standards (ELGs) for the Pulp and Paper Category. For these regulations, EPA divided the
industry into 25 subcategories, based on the products made and processes used at the mills.
A 1988 legal suit obligated EPA to address discharges of poly chlorinated
dibenzo-(p)-dioxins and poly chlorinated dibenzofurans2 from 104 bleaching pulp mills,
including nine dissolving pulp mills. While meeting that obligation, EPA also reviewed ELGs
for the entire Pulp and Paper Category. As part of that review, EPA reorganized the category
into 12 subcategories. Although the Pulp and Paper Category regulations apply to all facilities in
SIC codes 2611, 2621, and 2631, the 12 subcategories are organized by process used and product
produced and do not correspond to SIC codes.
2Polychlorinated dibenzo-p-dioxins (CDDs) and polychlorinated dibenzofurans (CDFs) constitute a group of
persistent, bioaccumulative, and toxic chemicals. Facilities are required to report to EPA's TRI the total mass of 17
of these CDDs and CDFs released to the environment every year. In this report, EPA uses the term "dioxins" to
refer to the total mass of the 17 CDDs and CDFs, as reported to TRI.
For discharges from certain mills in the Pulp and Paper Category, EPA promulgated ELGs for two specific dioxins:
2,3,7,8-tetrachlorodibenzo-p-dioxin and 2,3,7,8-tetrachlorodibenzofuran. In this report, these compounds are
referred to as TCDD andTCDF, respectively. See Section 3.1 of this report for a discussion of dioxins.
1-4
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During its response to the 1988 legal suit, EPA decided to review and revise the
Pulp and Paper Category regulations in three phases. Table 1-2 presents these three phases and
atpcrnrips FPA nlfmnpH tn flHHrpss in par.h nl
A WAL/ Him A CIL/\^A >^tH\^g,V^A J L \^g,l4± CllA \ULLJ LLL LAAA WV L/AACUWkJ . Atl
the subcategories EPA planned to address in each phase.
Table 1-2. Relationship Between Pulp and Paper Regulatory Phases and Subcategories
Phase
I
I
II
II
II
II
II
II
II
II
III
III
Subpart
B
E
C
F
G
H
I
J
K
L
A
D
Subcategory
Bleached Papergrade Kraft and Soda
Papergrade Sulfite
Unbleached Kraft
Semi-Chemical
Groundwood, Chemi-Mechanical, and Chemi-Thermo-Mechanical
Non-Wood Chemical Pulp
Secondary Fiber Deink
Secondary Fiber Non-Deink
Fine and Lightweight Papers from Purchased Pulp
Tissue, Filter, Non- Woven and Paperboard from Purchased
Pulp
Dissolving Kraft
Dissolving Sulfite
Note: EPA promulgated revised ELGs for Phase I, known as the Cluster Rules, April 15, 1998. EPA has not
promulgated revised ELGs for Phase II or Phase III.
In revising the Pulp and Paper Category regulations, EPA first addressed two
subcategories, Subpart B (Bleached Papergrade Kraft and Soda) and Subpart E (Papergrade
Sulfite), because these subparts applied to the majority of the 104 mills identified in the 1988
suit. Subparts B and E became known as Phase I; EPA promulgated revised ELGs for these
subparts April 15, 1998 (63 FR 18504; April 15, 1998). EPA promulgated the Phase I ELGs at
the same time it promulgated National Emissions Standards for Hazardous Air Pollutants
(NESHAPs) for kraft and sulfite pulp mills. Because these water and air regulations were
developed, analyzed, and promulgated jointly, they are called the Cluster Rules.
Eight subcategories are known as Phase II and are listed in Table 1-2. EPA has
not revised the ELGs for these subcategories which were promulgated between 1974 and 1986.
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Phase III affected the two dissolving pulp subcategories (Subpart A, Dissolving
Kraft, and Subpart D, Dissolving Sulfite). EPA did not promulgate revised ELGs addressing
TCDD and TCDF for Phase III in 1998, because the affected companies were undertaking a
multiyear laboratory study and mill trial to develop alternative bleaching technologies. EPA
anticipated that final ELGs would be based on different technologies than those that served as
the basis for the Phase I regulations. As of August 2004, there were only four operating mills in
these two subcategories. As part of its 2004 Effluent Guidelines Program Plan, EPA determined
that rather than promulgate revised ELGs for Phase III mills, EPA would support NPDES permit
writers individually in developing permit-specific effluent limitations to control TCDD and
TCDF releases from these four mills.
1.3 Detailed Study Scope
EPA decided to conduct a detailed study of the Pulp and Paper Category because
it ranked highest among all point source categories for toxic and nonconventional pollutant
discharges in the 2005 Screening-Level Analysis Report [1]. Only Phase I and Phase II mills are
the subject of this study because, as noted above, EPA previously determined that it would not
promulgate revised ELGs for Phase III mills.
This study will focus, in part, on determining how the 1998 Cluster Rules have
been implemented and their effect on mill discharges. Because the Cluster Rules apply to Phase
I mills, but not to Phase II mills, the regulatory implementation part of the detailed study
addresses only Phase I mills. As an additional focus, this study will investigate the non-
bleaching sources of toxic pollutants discharged from pulp and paper mills. These pollutants
include dioxins, polycyclic aromatic compounds (PACs), metals, ammonia, and possibly others,
that are discharged from Phase I and Phase II mills.
EPA's detailed study plan identified key questions the detailed study will seek to
answer [2]. These questions include:
Have the Cluster Rules been incorporated into NPDES permits for Phase I
mills?
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Are Phase I mills in compliance with the Cluster Rules?
Are TCDD and TCDF present in bleach plant effluents? Are TCDD,
TCDF, or other dioxin congeners discharged from non-bleaching pulp and
paper mills? If so, what is the source of these discharges?
What are the sources of other toxic pollutants (PACs, metals, ammonia,
and possibly others) discharged from pulp and paper mills?
To what extent are facilities reporting wastewater discharges of toxic
chemicals to TRI? How are mills estimating their TRI-reported
discharges?
1.4 Detailed Study Status
This report describes the status of EPA's detailed study of the Pulp and Paper
Category (hereafter, pulp and paper detailed study) as of July 2005. EPA has made progress in
verifying TRI- and PCS-reported discharges and has collected Phase I mill NPDES permits with
the help of the trade association and industry. EPA is in the process of verifying that Cluster
Rules guidelines have been incorporated into permits and that Phase I mills are in compliance
with their Cluster Rules-based permit limits. EPA is continuing to collect information from
individual facilities and NPDES permit writers and is beginning to review published technical
information to understand potential pollutant sources and control alternatives.
This report presents the preliminary results of EPA's detailed study and details
EPA's request for additional information to support its completion of the study. This report is
organized in the following sections:
Section 2.0: Data Sources;
Section 3.0: Pulp and Paper Category Wastewater Pollutants;
Section 4.0: Cluster Rule Implementation and Impact;
Section 5.0: Review of TRI Data; and
Section 6.0: Next Steps.
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2.0 DATA SOURCES
This section describes the data sources used for the pulp and paper detailed study
as well as potential data quality limitations. Specific data sources used for this investigation
include readily available information from EPA's TRI and PCS databases, pulp and paper mill
National Pollutant Discharge Elimination System (NPDES) permits and related fact sheets, and
information provided by two industry groups, the American Forest and Paper Association
(AF&PA) and the National Council for Air and Stream Improvement (NCASI). AF&PA is the
national trade association of the forest, pulp, paper, paperboard, and wood products industry.
NCASI is an independent, nonprofit research institute funded by the forest products industry,
including pulp and paper companies, many of which are also members of AF&PA.
The data sources used to date by EPA for the detailed study are described in the
following subsections:
Section 2.1: PCS;
Section 2.2: TRI;
Section 2.3: NPDES Permits; and
• Section 2.4: Information Provided by Industry and Trade Associations.
2.1 PCS
For its 2005 screening-level analysis, EPA used discharge monitoring data
compiled in PCS to evaluate current mill discharges. PCS was created by EPA's Office of
Enforcement and Compliance Assurance to track permit, compliance, and enforcement status of
facilities regulated by the NPDES program under the Clean Water Act. This system contains
only permit-required monitoring data for direct-discharging facilities. As required by their
permits, mills file Discharge Monitoring Reports (DMRs) with the state once a month (or at
other specified frequencies). Each mill's NPDES permit specifies the pollutants to monitor and
at what frequency. Pulp and paper mills that discharge to a publicly owned treatment works
(POTW) or that transfer their wastewater to a private waste treater do not submit DMRs;
2-1
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therefore, their data are not included in PCS. In addition, PCS typically does not include data for
mills that states classify as "minor sources."
EPA used a mainframe computer program, the Effluent Data Statistics (EDS)
system, to calculate annual loads from facility DMRs. EPA estimated the toxicity of these
calculated annual loads using toxic weighting factors (TWF) to calculate toxic-weighted pound
equivalents (TWPE) [3] [4]. EPA multiplied the EDS-calculated annual loads by the chemical-
specific TWFs to calculate the TWPE, and compiled the EDS output data, TWFs, and related
information into a Microsoft Access™ database called PCSLoads2002. For the 2005 analysis,
EPA used 2002 discharge data to be consistent with the TRI2002 discharge data that are also
used, the most recent data available from TRI at the start of the 2005 screening-level analyses.
The development of the PCSLoads2002 database and its output are described in EPA's 2005
Screening-Level Analysis Report [1]. Section 3.0 of this detailed study report presents the
pollutant loads calculated for the Pulp and Paper Category.
The EDS mainframe computer program decision logic translates monitoring
results reported as less than a detection limit (e.g., <10 pg/L) to zero Ib/yr if the pollutant was
never detected at the monitoring location in 2002, or an estimated mass (Ib/yr) if the pollutant
was detected at least once at the monitoring location in 2002. These annual load results did not
provide sufficient detail to determine if Phase I mills are in compliance with their Cluster Rules-
based permits. To more accurately quantify periodic monitoring results, EPA retrieved DMR-
reported concentration data (after they had been converted to consistent units of measure by
EDS) for all Phase I mills for 1998 through 2004.
The following activities supported EPA's analysis of data reported to PCS:
NCASI contacted certain facilities to discuss reported discharges and
submitted findings to EPA; and
EPA determined the operating status and rulemaking phase of facilities
with data in PCS.
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Utility and Limitations of PCS Data
The data collected in PCS are particularly useful for the pulp and paper detailed
study for the following reasons:
PCS is national in scope, including data from all 50 states and U.S.
territories; and
Discharge reports included in PCS are based on metered flows and
effluent chemical analyses and indicate if the monitored pollutants were
present in concentrations above the method detection limits.
Limitations of the pulp and paper data collected in PCS include the following:
• Some states do not submit all DMR data to PCS, or do not submit the data
in a timely fashion. For example, Washington State receives internal
monitoring data from mills and examines the data for compliance, but
does not submit the data to PCS.
• Because of the structure of the PCS database, EPA could not always
identify which monitoring points represent bleach plant effluent, final
effluent, or other types of discharges
Despite these limitations, EPA determined that the data summarized in
PCSLoads2002 and the PCS monthly data were usable for the detailed study review of the Pulp
and Paper Category.
2.2 TRI
EPA used data reported to TRI to estimate the mass of pollutants discharged by
industry categories. Using the same methodology used with calculated PCS loads, EPA
estimated the toxicity of these discharges using TWFs to calculate TWPE, and compiled the TRI
data, TWFs, and related information into a Microsoft Access™ database called
TRIReleases2002. For the 2005 analysis, EPA used 2002 discharge data, because they were the
most recent data available from TRI when the analysis began. The development of this database
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and its output are described in EPA's 2005 Screening-Level Analysis Report [1]. Section 3.0 of
this detailed study report presents the pollutant loads calculated for the Pulp and Paper Category.
As part of this detailed study, EPA verified TRI data, particularly for those
facilities and pollutants with high TWPE. Facilities may estimate releases in a number of ways
when reporting to TRI. If a chemical is not detected in the effluent, facilities may estimate the
discharge by using one-half of the detection limit.
To verify the data reported to TRI, EPA:
• Contacted certain facilities to discuss reported discharges;
• Reviewed data submitted by NCASI; and
• Identified the operating status and rulemaking phase of facilities reporting
to TRI.
Utility and Limitations of TRI Data
The data collected in TRI are particularly useful as a starting point for the detailed
study for the following reasons:
• TRI includes data from all 50 states and U.S. territories;
• TRI includes releases to POTWs, not just direct discharges; and
• TRI includes releases of many chemicals, not just those limited in mill
discharge permits.
Limitations of the data collected in TRI include the following:
Small establishments (less than 10 employees) are not required to report,
nor are facilities that don't meet the reporting thresholds. EPA expects
that pulp and paper mills in all three regulatory phases meet the facility
size reporting threshold.
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Release reports are, in part, based on estimates, not measurements, and,
due to TRI guidance, may overstate releases.
Certain chemicals (PACs, dioxin and dioxin-like compounds, metal
compounds) are reported as a class, not as individual compounds.
Because the individual compounds in the class have widely varying toxic
effects, the potential toxicity of chemical releases can be inaccurately
estimated.
Despite these limitations, EPA determined that the data summarized in
TRIReleases2002 were useful for identifying pollutants of concern to examine further in the pulp
and paper detailed study.
2.3 NPDES Permits
One of the purposes of this detailed study is to evaluate how well the Cluster
Rules have been incorporated into permits issued after 1998. EPA collected permits for
currently operating Phase I mills and selected POTWs. POTWs receiving wastewater from
Phase I mills may include effluent discharge limits that are similar to mill limits. Table 2-1
shows the number of permits collected.
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Table 2-1. Phase I Mill NPDES Permits Collected
Phase I
Bleached Papergrade
Kraft Mills
Phase I
Papergrade Sulfite Mills
POTWs Receiving Phase
I Mill
Wastewater
Number of Mills
At promulgation (1998)
Idle or no longer in Phase
I, as of 2004
Operational in 2004
84
12
72
11
5
6
10
5
5
Number of Permits Collected
Industry provided
EPA collected
Total collected
Missing as of July 2005
48a
16
64
7d
3b
3
6
0
0
4C
4C
1
includes two permits that cover two mills: two Parsons & Whittemore mills (Alabama Pine Pulp and Alabama River
Pulp) in Claiborne, AL, both bleached papergrade kraft mills, share a single permit; and two Domtar mills (Nekoosa
-a bleached papergrade kraft mill and Port Edwards - a papergrade sulfite mill) share a permit. Includes one other
permit shared by the Boise Cascade mill and the City of St. Helens POTW.
blncludes a permit shared by two Domtar mills (Nekoosa - a bleached papergrade kraft mill and Port Edwards - a
papergrade sulfite mill).
Includes one permit that both the Boise Cascade mill and the City of St. Helens POTW share.
dEPA identified a total of 71 (64 + 71) permits for 72 bleached kraft mills, because the Alabama Pine Pulp and
Alabama River Pulp mills in Claiborne, share a single permit. EPA received 5 of the 7 missing permits in July 2005.
Because of the late arrival of these permits, EPA did not include their analysis in this report.
AF&PA and its member companies provided the majority of the permits. EPA
contacted state permitting authorities to obtain permits not readily available on the Internet and
not provided by AF&PA. As of July 2005, EPA had requested, but not received, permits for
seven mills and one POTW, listed in Table 2-2. After July 2005, EPA received an additional
five permits. EPA's analysis of these additional permits is not included in this preliminary
report, but will be included in the final report of this study.
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Table 2-2. NPDES Permits Requested, But Not Received by July 2005
Mill
Fraser Paper, Berlin8
Tembec, St. Francisvillea
S.D. Warren (SAPPI), Muskegon*
Lincoln Pulp & Paper Co.,
Lincoln,
Koch Industries, New Augusta3
Weyerhaeuser Co., Hawesvillea
Container Corp. of America,
Brewton
POTW Name
Bay County Wastewater
Treatment Plant, Panama City
Permit NPDES
Number
NH0000655
LA0003468
MI0001210
ME0002003
MS0031704
KY0001716
AL0002682
Permit NPDES
FL0002631
POTW Receiving
Phase I Mill
Wastewater
-
-
Muskegon County Wastewater
Management System
-
-
-
-
Mill Discharging
to the POTW
Smurfit Stone Container
POTW
Permit NPDES
-
-
MI0027391
-
-
-
-
Mill NPDES
FLR05B551
"Collected after July 2005; will be evaluated for the 2006 Plan.
2.4
Information Provided by Industry and Trade Associations
EPA met with representatives from AF&PA and NCASI on April 5, 2005. Prior
to the meeting, EPA sent both parties the results from its preliminary screening-level analysis of
2002 discharge data (PCSLoads2002 and TRIReleases2002) and a list of questions concerning
mill operating status, the incorporation of 1998 effluent guidelines, data estimation techniques,
and pollutant sources. Questions and topics discussed during the meeting included explanations
of screening-level review of discharge data [5].
EPA asked AF&PA and NCASI to provide information supporting the TRI-
reported PACs and dioxins releases. NCASI contacted representatives from 19 mills to discuss
their basis for TRI reporting, and provided this information to EPA. NCASI also provided
information on nine mills reporting to PCS. In addition, NCASI also provided EPA with
excerpts from a guidance document available to its members, its Handbook of Chemical-Specific
Information for SARA Section 313 Form R Reporting [6].
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s.o PULP AND PAPER CATEGORY WASTEWATER POLLUTANTS
As discussed in Sections 2.1 and 2.2, EPA used its TRIReleases2002 and
PCSLoads2002 databases to conduct a screening-level analysis of industry discharge data [1].
As it began the screening-level analysis, EPA found that the toxic and nonconventional pollutant
loadings were driven by two groups of pollutants: dioxins and poly cyclic aromatic compounds
(PACs).
This section discusses EPA's findings on the Pulp and Paper Category in the
following subsections:
Section 3.1: Dioxins;
Section 3.2: PACs;
Section 3.3: PCSLoads2002 Results; and
Section 3.4: TRIReleases2002 Results.
3.1 Dioxins
The following discussion is excerpted from EPA's Guidance for Reporting Toxic
Chemicals within the Dioxin andDioxin-like Compounds Category [7], which can be found on
EPA's TRI website (ht^ywww^pa^gQy/trj/guide^dQcs/X The term 'dioxins' refers to
polychlorinated dibenzo-p-dioxins (CDDs) and polychlorinated dibenzofurans (CDFs), which
constitute a group of persistent, bioaccumulative, and toxic chemicals. There are 17 CDDs and
CDFs compounds which include chlorine substitution of hydrogen atoms at the 2, 3, 7, and 8
positions on the benzene rings. For 15 of these congeners, other positions are also chlorinated.
The most toxic of the 17 is 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD). Table 3-1 lists these 17
compounds, their chemical name, common abbreviated name, and EAD's toxic weighting factor
(TWF) for each compound. The 17 compounds (called congeners) are referred to as 'dioxin-
like,' because they have similar chemical structure, similar physical-chemical properties, and
invoke a common battery of toxic responses, though the toxicity of the congeners varies greatly.
For additional discussion on toxic response, see Section 4 of the Technical Support Document
for the 2004 Effluent Guidelines Program Plan [8].
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Table 3-1. Dioxins and Their Toxic Weighting Factors
CAS
Number
Chemical Name
Abbreviated Name
Toxic Weighting
Factor1
CDDs
1746-01-6
40321-76-4
39227-28-6
57653-85-7
19408-74-3
35822-46-9
3268-87-9
2,3,7,8-tetrachlorodibenzo-p-dioxin
1 ,2,3 ,7,8-pentachlorodibenzo-p-dioxin
1,2,3,4,7,8-hexachlorodibenzo-p-dioxin
1,2,3,6,7,8-hexachlorodibenzo-p-dioxin
1,2,3,7,8,9-hexachlorodibenzo-p-dioxin
1,2,3,4,6,7,8-heptachlorodibenzo-p-dioxin
1,2,3,4,6,7,8,9-octachlorodibenzo-p-dioxin
2,3,7,8-TCDD
1,2,3,7,8-PeCDD
1,2,3,4,7,8-HxCDD
1,2,3,6,7,8-HxCDD
1,2,3,7,8,9-HxCDD
1,2,3,4,6,7,8-HpCDD
1,2,3,4,6,7,8,9-OCDD
421,600,000
215,384,615
43,076,923
41,791,045
43,076,923
4,179,104
423,510
CDFs
51207-31-9
57117-41-6
57117-31-4
70648-26-9
57117-44-9
72918-21-9
60851-34-5
67562-39-4
55673-89-7
39001-02-0
2,3 ,7,8-tetrachlorodibenzofuran
1 ,2,3 ,7,8-pentachlorodibenzofuran
2,3,4,7,8-pentachlorodibenzofuran
1 ,2,3 ,4,7,8-hexachlorodibenzofuran
1 ,2,3 ,6,7,8-hexachlorodibenzofuran
1,2,3,7,8,9-hexachlorodibenzofuran
2,3,4,6,7,8-hexachlorodibenzofuran
1,2,3,4,6,7,8-heptachlorodibenzofuran
1,2,3,4,7,8,9-heptachlorodibenzofuran
1,2,3,4,6,7,8,9-octachlorodibenzofuran
2,3,7,8-TCDF
1,2,3,7,8-PeCDF
2,3,4,7,8-PeCDF
1,2,3,4,7,8-HxCDF
1,2,3,6,7,8-HxCDF
1,2,3,7,8,9-HxCDF
2,3,4,6,7,8-HxCDF
1,2,3,4,6,7,8-HpCDF
1,2,3,4,7,8,9-HpCDF
1,2,3,4,6,7,8,9-OCDF
6,696,140
3,294,118
32,941,176
6,658,740
6,666,667
6,666,667
6,658,740
665,874
666,667
67,367
'From 2005 Screening-Level Analysis Report [1].
Beginning with reporting year 2000, facilities (including pulp and paper mills)
meeting certain reporting criteria were required to report to TRI the total mass of the 17 dioxin
and dioxin-like compounds released to the environment every year. (In this report, EPA uses
the term "dioxins" to refer to all 17 of the 2,3,7,8-substituted CDDs and CDFs, as reported to
TRI.) The TRI method of reporting the total mass of all congeners does not account for the
relative toxicities of the 17 compounds. However, reporting facilities are given the opportunity
to report a facility-specific congener distribution. As discussed in the 2005 Screening-Level
Analysis Report [1], EPA calculated dioxins TWPE using the TRI-reported congener distribution
to estimate the mass of each congener in the facility's reported releases to surface waters or
transfers to POTWs.
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If a facility did not report a congener distribution, EPA used an industry-average
distribution to calculate the mass of each congener released. For the Pulp and Paper Category,
EPA developed regulatory phases to prioritize mills that bleach. Because the congener
distribution is more related to the bleaching process than to the product, EPA calculated the
average dioxins distribution for each regulatory phase.
The Cluster Rules established ELGs for 2,3,7,8-TCDD and 2,3,7,8-TCDF,
referred to as TCDD and TCDF, respectively, in this report. EPA's analytical method (Method
1613B) establishes the minimum concentration at which these compounds can be reliably
quantified. The minimum level (ML) is the level at which the analytical system gives
recognizable signals and an acceptable calibration point, for Method 1613B and TCDD and
TCDF that level is 10 pg/L. The ELGs in the Cluster Rules for TCDD are
-------
Table 3-2. Definition of PACs
PAC Compound
Benzo(a)anthracene
Benzo(a)phenanthrene (chrysene)
Benzo(a)pyrene
Benzo(b)fluoranthene
Benzo(j)fluoranthene
B enzo (k)fluoranthene
Benzo(j,k)fluorene (fluoranthene)
Benzo(r,s,t)pentaphene
Dibenz(a,h)acridine
Dibenz(aj)acridine
Dibenzo(a,h)anthracene
Dibenzo(a,e)fluoranthene
Dibenzo(a,e)pyrene
Dibenzo(a,h)pyrene
Dibenzo(a,l)pyrene
7H-Dibenzo(e,g)carbazole
7, 12-Dimethylbenz(a)anthracene
Indeno( 1 ,2,3 -cd)pyrene
3 -Methy Icholanthrene
5 -Methy Ichrysene
1-Nitropyrene
CAS Number
56-55-3
218-01-9
50-32-8
205-99-2
205-82-3
207-08-9
206-44-0
189-55-9
226-36-8
224-42-0
53-70-3
5385-75-1
192-65-4
189-64-0
191-30-0
194-59-2
57-97-6
193-39-5
56-49-5
3697-24-3
5522-43-0
Toxic Weighting
Factor
36.2600
31.0100
100.6600
30.6600
30.6600
0.8290
30.6600
30.6600
PACs are likely present in petroleum products and form as the result of
incomplete combustion of organic compounds. PACs and closely related compounds are major
constituents of creosote, a commonly used wood preservative.
For TRI, facilities must report the combined mass of PACs released; they do not
report releases of individual compounds. In the preliminary screening-level review of the 2002
TRI database, EPA assumed that all of the PACs reported released by pulp and paper mills were
benzo(a)pyrene. Because benzo(a)pyrene has the highest TWF (100.66) of the PACs, this was a
"worst case" assumption.
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As discussed in Section 3.4.3 of the 2005 Screening-Level Analysis Report [1],
after its preliminary analysis, EPA used a different approach to estimate the TWF of PACs
discharged from the Pulp and Paper Category. NCAST's TRI-reporting guidance [6] includes a
table listing the concentrations of PAC compounds found in wastewaters for several types of
pulping (kraft, bisulfite, chemi-thermo-mechanical, thermo-mechanical). EPA calculated the
percentage of each PAC present in pulp mill wastewater based on the information provided by
NCASI. EPA used this distribution to calculate an adjusted TWF for Pulp and Paper Category
PACs by summing the product of each chemical's TWF and its percentage relative to the total
PACs in pulp mill wastewaters. The new pulp and paper industry PAC TWF is 34.21. For more
information on revisions to TWFs, see the 2005 Screening-Level Analysis Report [1].
3.3 PCSLoads2002 Results
Table 3-3 lists the 10 pollutants with the highest TWPE of PCS-reported
discharges for 2002, in order of descending TWPE. The largest contributor to the category
TWPE is TCDD. The table also shows the number of mills that reported discharges to PCS and,
for each pollutant, the TWF, the number of mills that reported discharges, the total pounds
discharged to surface waters, and the total category TWPE. The two subcategories of Phase I,
Bleached Papergrade Kraft and Soda (BPK) and Papergrade Sulfite (PS), are presented
separately. Phase III, although not part of this detailed study, is included to provide a
perspective on the total TWPE discharged by the Pulp and Paper Category. Table 3-3 does not
include pollutants for which EPA has not developed TWFs, such as BOD5, total suspended
solids, color, and adsorbable organic halides (AOX). The 1998 Cluster Rules established ELGs
for AOX, a bulk parameter which measures the total mass of chlorinated organic compounds.
EPA has not developed a TWF for AOX because it represents a group of diverse chemicals, not
a single compound.
5-5
-------
Table 3-3. Top 10 Pollutants in PCSLoads2002, Discharges by Pulp Regulatory Phase
Number of PCS-Reporting Facilities
Pollutants
TCDD
Aluminum
Chlorine0
Sulfide
Mercury
Nitrite Plus
Nitrate Total
IDet. (AsN)
Copper
Nitrogen,
Ammonia
TCDF
Arsenic
TWF
703,584,000
0.06469
0.50916
2.80
117
0.00560
0.63482
0.00151
43,819,554
4.04
Phase I
BPK ( 72 mills)
Mils"
71
11
20
1
8
3
8
29
46
4
Discharged
(Ibs)
0.00194
932,998
9,741
2,442
15
17
674
1,620,046
0.00010
118
PS ( 7 mills )
Mills"
NR
3
NR
NR
1
2
4
2
NR
NR
Discharged
(Ibs)
NR
15,640
NR
NR
0
417,048
2,834
9,819
NR
NR
Phase II
171 mills
Mills"
4
26
43
NR
12
19
63
59
4
6
Discharged
(Ibs)
0
243,967
37,364
NR
40
712,322
3,875
595,331
0
771
Phase ma
5 mills
Mills"
2
1
NR
NR
NR
NR
2
2
NR
NR
Discharged
(Ibs)
0
17,160
NR
NR
NR
NR
134
750,867
NR
NR
Total
Total Category
255 mills
TWPE
1,366,677
78,261
23,984
6,841
6,461
6,325
4,772
4,480
4,395
3,594
1,520,479
Source: PCSLoads2002 (these loads include the corrections to the 2002 PCS data described in Table 3-4).
BPK - Bleached Papergrade Kraft. PS - Papergrade Sulfite. NR - No mills reported discharging this parameter.
Thase III is not in the scope of the detailed study, but discharge loads are presented to provide total category perspective.
bNumber of mills monitoring the discharge of the parameter. Includes mills that never detected the parameter.
cTotal Residual Chlorine.
-------
The final effluent discharge from one mill (Bowater, Catawba SC) is responsible
for all of the pulp and paper TCDD discharge. In 2002, this mill discharged 0.88 grams of
TCDD, which equates to 1.37 million TWPE, or 90% of the Pulp and Paper Category's 1.52
million TWPE. Bowater reports that, since that date, neither TCDD nor TCDF has been
measured in mill wastewaters above the method detection limit. The mill is enrolled in Tier 1 of
EPA's VATIP and as such was provided with a six-year schedule for compliance with Cluster
Rules requirements. After 2002, the Bowater Catawba mill converted to 100% chlorine dioxide
bleaching and started up an advanced fiber line. See Section 4.3.1 for a more detailed
description of Bowater, Catawba SC mill operations.
The preliminary results of EPA's 2005 screening-level analysis indicated that
nine Phase I mills reported TCDD or TCDF discharges during 2002. As discussed in Section
2.4, NCASI contacted each of the nine mills reporting discharges, confirming for three mills that
concentrations measured above analytical detection limits in 2002 were correct. NCASI
identified errors for six mills in the data stored in PCS. These mills provided copies of
Discharge Monitoring Reports (DMRs) and/or laboratory analytical results documenting these
errors [9]. Table 3-4 summarizes EPA's review of the mill-submitted documentation. EPA
changed the TCDD load for five mills in its PCSLoads2002 database to zero pounds. EPA also
changed the TCDF load for one mill to zero pounds.
Table 3-4. Results of Review of Mill-Provided PCS Corrections
Facility
Pope & Talbot Inc,
Halsey
Weyerhaeuser,
Johnsonburg
Upper Potomac River
Comm STP, Westemport
Bowater Inc Southern
Division, Calhoun
NPDES Permit
Number
OR0001074
PA0002143
MD0021687
TN0002356
Findings from Review
The mill provided discharge monitoring data
for final effluent. Data in DMRs submitted in
2002 were below detection limit, but not
labeled with "less than" or a "non-detect."
The mill provided discharge monitoring data
documenting discharges below detection for
the entire year.
The POTW expressed that the "less than" sign
was omitted from the DMR. A corrected DMR
has been resubmitted to the state.
The mill provided lab reports for 2002. Each
dioxin and furan congener concentration
reported by the lab was either not detected or
estimated because it was below the calibration
curve.
Changes to
PCSLoads2002
Changed TCDD load to
zero pounds discharged.
Changed TCDD load to
zero pounds discharged.
Changed TCDD load to
zero pounds discharged.
Changed TCDD load to
zero pounds discharged.
5-7
-------
Table 3-4 (Continued)
Facility
Fort James Operating
Co, Wauna
Weyerhaeuser Co, Port
Wentworth Mill,
Savannah
Bowater Inc, Catawba
Boise Cascade Corp.,
Jackson
Alabama River Pulp,
Purdue Hill
NPDES Permit
Number
OR0000795
GA0002798
SC0001015
AL0002755
AL0025968
Findings from Review
The mill explained that the measurements
reported on the DMR for October and March of
2002 were below the Cluster Rule-established
minimum levels.
The mill explained that the laboratory reported
TCDF concentrations as "laboratory estimated
maximum" three times in 2002. All reported
concentrations were less than Method 1613B
ML (10 pg/L).
The mill explained that the TCDD discharge
was the result of a single unexplained 83.6
pg/L spike on May 13, 2002 in the final
effluent. Since that date no samples have been
collected above the method 1613B detection
limit (10 pg/L).
The mill explained that on October 31, 2002 a
TCDF concentration of 1 1 .3 pg/L was
measured in the bleach plant effluent. The
measurement was below the 3 1 .9 pg/L facility
permit limit.
The mill explained that on December 1 , 2002 a
TCDF concentration of 1 9 pg/L was measured
in the bleach plant effluent. The measurement
was below the 3 1 .9 pg/L facility permit limit.
Changes to
PCSLoads2002
Changed TCDD load to
zero pounds discharged.
Changed TCDF load to
zero pounds discharged.
No change to TCDD
pounds discharged.
No change to TCDF
pounds discharged.
No change to TCDF
pounds discharged.
Table 3-5 shows the total TWPE for each rulemaking phase. Mills with operations
in the Bleached Papergrade Kraft and Soda Subcategory are responsible for the majority (95.7%)
of the category TWPE. EPA recalculated the TWPE excluding the TCDD discharges from the
Bowater Catawba mill. With this data exclusion, the relative contribution of the Phase II mills
increases. There are more than twice as many Phase II mills as Phase I mills in the PCS database,
but Phase I mill discharges contribute 58% of the category TWPE.
-------
Table 3-5. PCSLoads2002 TWPE by Phase, With and Without Bowater Catawba Mill
TCDD Discharges
Number of PCS-
Reporting Facilities
TWPE
TWPE excluding
Bowater Catawba
TCDD
Phase I
BPK( 72 mills)
Total
TWPE
1,455,574
88,897
%of
Category
95.7
57.8
PS (7 mills)
Total
TWPE
6,628
6,628
%of
Category
0.4
4.3
Phase II
171 mills
Total
TWPE
55,232
55,232
%of
Category
3.6
35.9
Phase III
5 mills
Total
TWPE
3,045
3,045
%of
Category
0.2
2.0
Total Category
255 mills
TWPE
1,520,479
153,802
Source: PCSLoads2002.
BPK - Bleached Papergrade Kraft. PS - Papergrade Sulfite
EPA's classification of each Phase I mill's outfalls is presented in Appendix A of
this report. Because of the difficulty in identifying which outfall data in PCS represent bleach
plant effluent and which represent final effluent, a portion of the TWPE presented in Table 3-5
for the Phase I mills may represent bleach plant loads. In its Federal Register Notice of the
Preliminary 2006 Effluent Guidelines Program Plan, EPA will request that operators of the mills
listed in Appendix A confirm EPA's classification of its outfalls. See Section 4.3 for additional
information on compliance monitoring locations.
3.4
TRIReleases2002 Results
Table 3-6 lists the 10 pollutants with the highest TWPE of TRI-reported
discharges for 2002, in order of descending TWPE. The largest contributor to the category
TWPE is dioxins. Table 3-6 lists the number of mills that reported pollutant discharges to TRI
and, for each pollutant, the TWF, the number of mills that reported discharges, the pounds
discharged, and total category TWPE. Discharges include direct discharges to surface waters
and transfers to POTWs. POTW transfers are included in the total discharges after POTW
removals are taken into account. The two subcategories of Phase I are presented separately.
Phase III, although not part of this detailed study, is included to provide a perspective on the
total TWPE discharged by the Pulp and Paper Category. In addition, 21,253 TWPE was
discharged by facilities in SIC codes EPA identified as "potential new subcategories." Table 3-6
5-9
-------
does not includes releases from potential new subcategories. See Section 5 of the 2005
Screening-Level Analysis Report [ 1 ].
Table 3-6. Top 10 Pollutants in TRIReleases2002, Releases by Regulatory Phase"
Number of TRI-reporting Facilities
Pollutants
Dioxins
Manganese and
Manganese
Compounds
PACs
Lead and Lead
Compounds
Chlorine
Zinc and Zinc
Compounds
Potassium
Dimethyldithiocarba
mate
Mercury and Mercury
Compounds
Copper and Copper
Compounds
Vanadium and
Vanadium
Compounds
TWF
d
0.0144
34'
2.24
0.509
0.0469
0.933
117
0.6348
0.035
Phase I
BPK( 79 mills)
Mills
44
70
50
65
4
46
NR
31
2
24
Released
0bs)
0.115
3,403,539
863
11,876
22,682
228,492
NR
35
418
42,503
PS(8nrills)
Mills
3
2
1
6
1
1
NR
1
3
1
Released
0bs)
0.0185
32,832
20.9
841
3,700
5,751
NR
1.7
2,121
750
Phase II
169 mills
Mills
14
39
27
114
7
24
1
41
5
9
Released
0bs)
0.013
857,936
440
16,694
21,357
73,751
12,341
24
1,424
8,447
Phase III1"
5 mills
Mills
4
4
4
4
2
NR
NR
NR
3
Released
0bs)
0.005
187,780
119
735
73,000
NR
NR
NR
2,820
Total for All Pollutants
Total
Category"
261 mills
TWPE
2,854,324
64,690
49,355
67,528
24,307
14,783
11,519
7,087
2,516
1,908
3,107,425
Source: TRIReleases2002.
BPK - Bleached Papergrade Kraft. PS - Papergrade Sulfite. NR - None Reported
"Releases reported include both direct and indirect discharges (transfers to POTWs). Indirect discharges account for POTW removals.
b Phase III is not in the scope of the detailed study, but discharge loads are presented to provide total category perspective.
"Category total includes 21,253 TWPE discharged by facilities in SIC codes EPA identified as "potential new subcategories." See Section 5 of the
2005 Screening-Level Analysis Report [1].
dDioxin TWF calculated for each mill, based on reported congener distribution.
eEPA-calculated PAC TWF based on industry-submitted data [6].
Facilities in the Pulp and Paper Category reported discharges of 68.6 grams of
"dioxin and dioxin-like compounds" to TRI in 2002, totaling 2.85 million TWPE. (In
comparison, TCDD and TCDF discharges in PCS totaled 0.93 grams). Phase I and Phase II
mills reported more than 98% of the TRI-reported discharges (2.81 million TWPE, 66.4 grams)
of "dioxin and dioxin-like compounds." Dioxins discharges account for 91% of the category
TWPE. No single mill accounted for a majority of the TRI TWPE. In 2002, Bowater Catawba
3-10
-------
reported a TRI dioxins release of 3.6 grams, which is less than 6% of the Pulp and Paper
Category's total dioxins releases. (In comparison, using the TCDD discharge Bowater Catawba
reported on its DMR, EPA calculated that the mill discharged 0.88 grams of TCDD in 2002,
which accounted for 90% of the Pulp and Paper Category's PCS TWPE.)
For the total category, manganese and manganese compounds ranked second
highest in terms of TWPE. At this time, EPA has little information on how pulp and paper mills
estimate manganese releases. In its Federal Register Notice of the Preliminary 2006 Effluent
Guidelines Program Plan, EPA will request additional details of methods used to estimate
releases of toxic pollutant discharges reported to TRI, in particular those methods used by Phase
II mills (mills without bleached papergrade kraft or papergrade sulfite operations). EPA also
requests information about non-bleaching sources of toxic wastewater pollutants, such as metals
and metal compounds, including manganese, lead, zinc, and mercury. EPA will continue to
evaluate releases, in particular metals (manganese, lead, zinc, mercury), as it completes this
detailed study.
There is some pollutant overlap between the TRI and PCS data sources. Four
pollutants (dioxins, chlorine, mercury, and copper) are identified in the top 10 pollutants of
concern in both databases. "Lead and lead compounds" is the only pollutant for which Phase II
mill discharges exceed Phase I mill discharges.
Of the TRI-reported chemical discharges, PACs account for the third highest
TWPE, comprising 1.6% of the total Pulp and Paper Category TWPE. This is a significant
change from the April 5, 2005 results of EPA's screening-level analysis, which had assumed that
all reported PACs were benzo(a)pyrene. Using the TWF for benzo(a)pyrene, EPA calculated that
the category discharged over 140,000 TWPE of PACs. Using the TWF calculated based on
PACs distribution information provided by NCASI, EPA calculated that the category discharged
49,355 TWPE of PACs, a 65% reduction.
Table 3-7 shows the total TWPE for each Phase. Unlike PCS, one pollutant
(dioxins) but no single facility dominated the Pulp and Paper Category TWPE; therefore, EPA
3-11
-------
recalculated the total TWPEs excluding dioxins reported by all mills. When dioxins are excluded
from the totals, the relative contribution of the Phase II mills increases, though Phase I mills
always contribute more than half of the category TWPE.
Table 3-7. TRIReleases2002 TWPE by Regulatory Phase, with and without Dioxins
Number of TRI-
reporting facilities
TWPE
TWPE excluding
dioxins
Phase I
BPK( 79 mills)
Total
TWPE
1,779,702
139,722
%of
Category
57.3
55.2
PS(8mills)
Total
TWPE
1,127,204
6,995
%of
Category
36.3
2.8
Phase II
171 mills
Total
TWPE
143,581
97,218
%of
Category
4.6
38.4
Phase III
5 mills
Total
TWPE
56,938
9,165
%of
Category
1.8
3.6
Total
Category"
261 mills
TWPE
3,128,678
253,101
Source: TRIReleases2002.
a Category total includes 21,253 TWPE discharged by facilities in SIC codes EPA identified as "potential new subcategories." See Section 5 of
the 2005 Screening-Level Analysis Report [1].
3-12
-------
4.0 CLUSTER RULE IMPLEMENTATION AND IMPACT
One purpose of this detailed study is to evaluate how well the Cluster Rules
effluent limitations have been incorporated into NPDES permits issued after 1998. EPA
reviewed a total of 72 permits from operating Phase I mills and selected POTWs. Because Phase
II and III mills are not subject to the Cluster Rules, EPA did not collect or review permits for
these mills and they are not discussed in this section.
This section discusses EPA's analysis of the Cluster Rule ELGs implementation
in the following subsections:
Section 4.1: Detailed Summary of the 1998 ELGs Revisions;
Section 4.2: Incorporation of Cluster Rules into NPDES Permits; and
Section 4.3: Analysis of Compliance Monitoring Data.
4.1 Detailed Summary of 1998 ELGs Revisions (Cluster Rules)
The Cluster Rules apply to mills with operations subject to 40 CFR Part 430
Subpart B, Bleached Papergrade Kraft and Soda, and Subpart E, Papergrade Sulfite. The Cluster
Rules regulate toxic and nonconventional pollutants that are characteristic of mills that bleach
chemical pulp with chlorine-containing compounds. These pollutants include adsorbable organo-
halides (AOX), chloroform, TCDD, TCDF, and 12 chlorinated phenolic compounds3. Permit
writers issue permits that limit the discharge of these pollutants, following the Cluster Rules
effluent limitations guidelines.
In addition to limiting pollutant discharges, NPDES permits establish monitoring
and reporting requirements. Permits specify what discharge points must be monitored, for what
pollutants, and with what frequency. Permits also specify how frequently facilities report to their
permitting authority. Facility Discharge Monitoring Reports (DMRs) provide the permitting
34-trichlrosyringol; 3,4,5-trichlorocatechol; 3,4,6-trichlorocatechol; 3,4,5-trichloroguaiacol; 3,4,6-trichloroguaiacol;
4,5,6-trichloroguaiacol; 2,4,5-trichlorophenol; 2,4,6-trichlorophenol; tetrachlorocatechol; tetrachloroguaiacol;
2,3,4,6-tetrachlorophenol; and pentachlorophenol.
4-1
-------
authority with the information necessary to evaluate compliance with discharge limits. Table 4-1
summarizes the required compliance points for each pollutant regulated by the Cluster Rules.
EPA established less stringent monitoring requirements for mills that employ totally chlorine
free (TCP) bleaching.
Table 4-1. Compliance Points for Cluster Rules Regulated Pollutants
Pollutant"
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform
12 chlorinated
phenolic
pollutants
AOX
COD
SubpartB(BPK Mills)
Non-TCF
Bleach Plant
Bleach Plant
Bleach Plant
Bleach Plant
Final Effluent
(Directs)
Bleach Plant
(Indirects)
Reserved
TCF
Not required
Not required
Not required
Not required
Final Effluent
Reserved
Subpart E (PS Mills)
Calcium-, Sodium-,
Magnesium-Based
(Segment A)
Not required
Not required
Not required
Not required
Final Effluent
(Directs)
Bleach Plant
(Indirects)
Reserved
Ammonium-
Based
(Segment B)
Bleach Plant
Bleach Plant
Reserved
Bleach Plant
Reserved
Reserved
Specialty Grade
(Segment C)
Bleach Plant
Bleach Plant
Reserved
Bleach Plant
Reserved
Reserved
Source: Permit writers guidance document.
BPK - Bleached Papergrade Kraft. PS - Papergrade Sulfite. TCF - Totally Chlorine Free.
Table 4-1 presents monitoring locations information for Cluster Rules Pollutants. All Phase I mills must also monitor and
comply with BPT/BCT limits for pH, BOD5 and TSS at the final effluent. If they have not certified that they do not use
chlorophenolic-containing biocides, they must also monitor and comply with BAT limits for trichlorophenol and
pentachlorophenol at the final effluent.
Mills are required to demonstrate compliance at the following two locations:
The point where wastewater leaves the bleach plant, before being
combined with process wastewaters or noncontact cooling water from
other operations prior to treatment and discharge. Hereafter, this sample
location is referred to as "bleach plant."
The point where mills discharge their treated effluent to the receiving
streams; hereafter referred to as "final effluent."
Each mill with operations subject to Subpart B (hereafter, bleached kraft mills)
must demonstrate compliance with the limits for TCDD, TCDF, 12 chlorinated phenolic
pollutants, and chloroform in the effluent from the bleach plant of each individual fiber line.
4-2
-------
Chemical pulp bleaching is the principal source of these pollutants. EPA determined that bleach
plant limits for chloroform are necessary because there is potential for its volatilization and loss
in mill sewer systems. EPA determined that bleach plant limits are necessary for the other
pollutants because they are generated at very low concentrations and may be diluted to below
analytical detection limits when combined with other mill wastewaters. Indirect discharging
mills must also comply with an AOX limit at the bleach plant, while direct discharging mills are
required to monitor for AOX at the final effluent.
The limitations and monitoring requirements for mills with operations subject to
Subpart E (hereafter, papergrade sulfite mills) depend on the pulping base used at the mill. EPA
divided the Papergrade Sulfite Subcategory into three segments, listed in Table 4-1. Papergrade
sulfite mills in Segment A are required to monitor for only AOX, while mills in Segments B and
C are required to monitor for TCDD, TCDF, and the 12 chlorinated phenolic compounds, but not
AOX.
4.1.1 Best Available Technology and Pretreatment Standards
The Cluster Rules require that mills existing as of April 15, 1998 that discharge
directly to receiving streams control toxic and nonconventional pollutants at the best available
technology (BAT) economically achievable level of performance. EPA established Pretreatment
Standards for Existing Sources (PSES) that are based on control technologies similar to BAT for
indirect dischargers. As shown in Table 4-2, except for the monitoring location for AOX, the
Subpart B BAT limitations guidelines and PSES for indirect dischargers are the same. EPA
promulgated regulations for new sources (New Source Performance Standards, for direct
dischargers, and Pretreatment Standards for New Sources, for indirect dischargers). However no
new bleached kraft or papergrade sulfite mills have been constructed since 1998.
-------
Table 4-2. Subpart B (Bleached Papergrade Kraft and Soda) BAT Effluent Limitations
Guidelines and Pretreatment Standards for Existing Sources
Pollutants
1-Day Maximum"
Bleach Plant Effluent
TCDD
TCDF
Chloroform
Trichlorosyringol
3,4,5-Trichlorocatechol
3 ,4,6-Trichlorocatechol
3,4,5-Trichloroguaiacol
3 ,4,6-Trichloroguaiacol
4,5,6-Trichloroguaiacol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Tetrachlorocatechol
Tetrachloroguaiacol
2,3 ,4,6-Tetrachlorophenol
Pentachlorophenol
-------
Table 4-3. Subpart E (Papergrade Sulfite) BAT Effluent Limitations Guidelines and
Pretreatment Standards for Existing Sources
Pollutants
Segment A
Calcium, Magnesium, and
Sodium Sulfite3
Segment B
Ammonium Sulfite
Bleach Plant Effluent
TCDD
TCDF
Chloroform
Trichlorosyringol
3,4,5-Trichlorocatechol
3 ,4,6-Trichlorocatechol
3,4,5-Trichloroguaiacol
3 ,4,6-Trichloroguaiacol
4,5,6-Trichloroguaiacol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Tetrachlorocatechol
Tetrachloroguaiacol
2,3 ,4,6-Tetrachlorophenol
Pentachlorophenol
not regulated
not regulated
not regulated
not regulated
not regulated
not regulated
not regulated
not regulated
not regulated
not regulated
not regulated
not regulated
not regulated
not regulated
not regulated
-------
performance requirements, each with increasingly more effective levels of environmental
protection.
Totally chlorine free (TCP) bleaching is performed without using chlorine,
sodium or calcium hypochlorite, chlorine dioxide, chlorine monoxide, or any other chlorine-
containing compound. Each fiber line that uses exclusively TCP bleaching processes is required
only to comply with final effluent AOX limitations; no bleach plant limits are required.
One bleached kraft mill (Weyerhaeuser in Oglethorpe, GA) participates in EPA's
Project XL, which stands for "excellence and Leadership." This national pilot program allows
state and local governments, businesses, and federal facilities to work with EPA to develop more
cost-effective, strategies for achieving environmental and public health protection. In exchange,
EPA offers regulatory, program, policy, or procedural flexibility to conduct the program.
Table 4-4 lists the bleached kraft mills participating in these beyond compliance
programs.
Table 4-4. Bleached Kraft Mills Operating Beyond Compliance
NPDES Permit
Number
Beyond Compliance Program
VATIP Mills
International Paper, Eastover
Bowaterlnc., Catawba
Glatfelter, Spring Grove
International Paper, Franklin
SC0038121
SC0001015
PA0008869
VA0004162
VATIP; Tier 1
VATIP; Tier 1
VATIP; Tier 1
VATIP a
XL Mill
Weyerhaeuser/Flint River Mill, Oglethorpe
GA0049336
XL
TCF Bleaching Mill
Evergreen Pulp Company (formerly Louisiana-
Pacific), Samoa
CA0005894
TCF
VATIP - Voluntary Advanced Technology Incentives Program. XL - excellence and Leadership. TCF - Totally
Chlorine Free.
"Permit does not indicate VATIP Tier, believed to be Tier 1.
4-6
-------
4.1.3 Support Documents
EPA's supporting documents that describe the development and implementation
of the Cluster Rules ELGs explain in more detail the regulations reviewed in this section. These
documents, listed below, can be found at the EPA website
http://epa.gov/waterscience/pulppaper/.
Supplemental Technical Development Document for Effluent Limitations
Guidelines and Standards for the Pulp, Paper, and Paperboard Category:
Subpart B [Bleached Paper grade Kraft and Soda] and Subpart E
[Papergrade SulfiteJ. EPA-821 -R-97-011. October 1997.
Technical Support Document for the Voluntary Advanced Technology
Incentives Program, November, 1997.
Technical Support Document for Best Management Practices for Spent
Pulping Liquor Management, Spill Prevention, and Control. October
1997.
Permit Guidance Document for the Pulp, Paper, and Paperboard
Manufacturing Point Source Category (40 CFR 430).
EPA-82 l-B-00-003. May 2000.
4.2 Incorporation of Cluster Rules into NPDES Permits
EPA reviewed permits to determine if the appropriate Cluster Rules monitoring
requirements were included. Permits are issued to facilities for a specific time period (generally
five years) with a requirement to reapply prior to the expiration date. Permit writers are required
to use the Cluster Rules guidelines for permits issued after April 15, 1998. Thus, all permits for
affected mills should have had limits and monitoring requirements based on the new guidelines
by April 2003, unless permit renewal has been delayed or the mill was enrolled in the VATIP.
This subsection presents EPA's review of permits issued for bleached kraft mills,
POTWs receiving bleached kraft mill wastewater, and papergrade sulfite mills.
4-7
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4.2.1
Bleached Papergrade Kraft Mills
At the time the Cluster Rules were promulgated, 84 bleached kraft mills operated
in the United States. As of 2004, 72 mills continue to have bleached kraft operations. These
mills are listed in Appendix B to this report. The total includes one TCP mill, Evergreen Pulp
Company (formerly Louisiana Pacific) in Samoa, CA (which produces a chlorine-free product
using peroxide bleach), five mills operating in beyond-compliance programs, four indirect
discharging mills subject to PSES, and two mills that share a permit. EPA reviewed 64 permits
for these bleached kraft mills to determine if the appropriate Cluster Rules monitoring
requirements were included.
Table 4-5 presents the number of permits for bleached kraft mills that are missing
Cluster Rules monitoring requirements for AOX, TCDD, TCDF, chloroform and chlorinated
phenolic compounds. As shown in the table, permits for 15 mills permits have expired.
However, expired NPDES permits remain in effect until the new permit is issued, as long as a
complete application for permit renewal was submitted before the expiration date. EPA assumes
that these mills have submitted applications to the appropriate permitting authority and that the
expired permits remain in effect.
Table 4-5. Number of Permits for Bleached Kraft Mills Missing Cluster Rules Monitoring
Requirements
BPK mills, direct discharges not
listed below3
BPK mills, indirect dischargers
BPK mills, beyond compliance
(VATIP)
Domtar Mill - WIb
Boise Cascade - ORC
Evergreen Pulp Co.
(BPK TCP)
Permits
Collected
54
3
4
1
1
1
Permit
Has
Expired
13/54
1/3
1/4
0/1
0/1
0/1
Pollutant Missing Required Monitoring
AOX
4/54
2/3
0/4
0/1
0/1
0/1
TCDD, TCDF,
and chloroform
TCDD: 8/54
TCDF: 9/54
Chloroform: 9/54
1/3
0/4
0/1
0/1
0/1 d
Chlorinated
Phenolic
Compounds
9/54
1/3
0/4
0/1
0/1
0/1 d
4-8
-------
Table 4-5 (Continued)
Total
Permits
Collected
64
Permit
Has
Expired
15
Pollutant Missing Required Monitoring
AOX
6
TCDD, TCDF,
and chloroform
9
Chlorinated
Phenolic
Compounds
10
NOTE: EPA assumes that expired permits remain legally binding.
BPK - Bleached Papergrade Kraft. VATIP - Voluntary Advanced Technology Incentives Program. TCP - Totally Chlorine
Free.
^Includes minor discharger Weyerhaeuser/Flint River Mill in Oglethorpe, GA and the two Parsons & Whittemore mills (Alabama
Pine Pulp/Alabama River Pulp) in Claiborne, AL covered under a single permit.
Includes the Domtar Mill in Port Edwards, WI (papergrade sulfite), which shares its discharge with the Domtar Mill in Nekoosa,
WI (bleached kraft).
Includes the Boise Cascade bleached kraft mill and The City of St. Helens POTW, which share a permit.
dAlthough not required by the Cluster Rules, the permit for this TCP mill includes specific limits for these pollutants.
Permits for 12 mills (10 direct dischargers and two indirect dischargers) do not
include all Cluster Rules limits and monitoring requirements. These mills are listed Tables 4-6.
The majority of these permits have expired (9 of 12). Of the permits that do not include all
Cluster Rule-required monitoring, four were issued after the April 1998 Cluster Rules
promulgation date. EPA will request additional information for these mills from the state
permitting authorities to learn why Cluster Rules monitoring requirements are missing.
The Cluster Rules require mills to monitor for TCDD and chlorinated phenolic
compounds at the bleach plant. Table 4-6 shows that several permits improperly specify final
effluent as the compliance monitoring point.
Table 4-6. Permits for Bleached Kraft Mills Missing Required Bleach Plant Monitoring
Mill
NPDES
Permit
Number
Active
Permit
Expires
Pollutant
Absent from
Required
Monitoring
Pollutant
Limited at
FE not BP
Direct Discharge
International Paper Co., Cantonment
International Paper, Jay
New Page, Rumford
FL0002526
ME0001937
ME0002054
8/31/95
3/1/99
3/30/97
TCDD, TCDF,
chloroform, CP
TCDD, TCDF,
chloroform, CP
TCDD, TCDF,
chloroform, CP
-
TCDD. TCDF
TCDD
4-9
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Table 4-6 (Continued)
Mill
Weyerhaeuser Paper Co., Plymouth
International Paper Co., Riegelwood
Pope & Talbot Inc., Halsey
Georgia-Pacific, Port Hudson , Zachary
New Page, Chillicothe
Weyerhaeuser, Oglethorpe
International Paper Co., Texarkana
NPDES
Permit
Number
NC0000680
NC0003298
OR0001074
LA0005258
OH0004481
GA0049336
TX0000167
Active
Permit
Expires
5/31/02
11/30/01
7/1/98
1/1/07
1/31/09
7/30/02
1/1/01
Pollutant
Absent from
Required
Monitoring
TCDD, TCDF,
chloroform, CP
TCDD, TCDF,
chloroform, CP
CP, chloroform
TCDD, TCDF,
chloroform, CP
TCDF
TCDD, TCDF,
chloroform, CP
TCDD, TCDF,
chloroform, CP
Pollutant
Limited at
FE not BP
TCDD
TCDD, CP
-
TCDD,
TCDF, CP,
Chloroform
-
TCDD
TCDD
Indirect Discharge
New Page, Luke
Sappi Fine Paper, Cloquet
MD0001422
MN0001431
4/30/06
11/30/96
AOX
AOX,
TCDD,TCDF,
chloroform, CP
AOX
"
CP - Chlorinated phenolic compounds.
BP - Bleach Plant.
FE - Final Effluent.
Active permits from the four bleached kraft mills listed in Table 4-7 have no
AOX monitoring requirement. Each of these permits has expired and has not been reissued since
promulgation of the Cluster Rules. Even though the permit for the MeadWestvaco (New Page)
Mill in Rumford, ME reviewed for this study has no AOX limits, the PCS database contains
AOX discharge data at the final effluent for the mill. EPA contacted Maine and Florida and
confirmed that the permits listed in Table 4-7 are the current active permits. EPA will contact
North Carolina to confirm that the two permits for North Carolina mills listed in Table are the
current active permits.
4-10
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Table 4-7. Permits for Bleached Kraft Mills Missing Required Final Effluent AOX
Monitoring
Mill
International Paper Co, Cantonment
MeadWestvaco (New Page), Rumford
Weyerhaeuser Paper Co., Plymouth
International Paper Co., Riegelwood
NPDES Permit Number
FL0002526
ME0002054a
NC0000680
NC0003298
Active Permit Expires
8/31/95
3/30/97
5/31/02
11/30/01
"Mill has AOX discharge loads in PCS from 1997 through 2004.
4.2.2 POTWs
EPA reviewed permits for three POTWs that receive bleached kraft mill
wastewater. The Cluster Rules do not include ELGs for POTWs that receive Phase I pulp mill
wastewater. Instead, permit limits for Cluster Rules pollutants for POTWs are determined by
water quality standards and the professional judgment of the permit writer based on the types of
industrial wastewater received. Each permit EPA reviewed was issued in the past five years and
included TCDD limits at the final effluent. One permit, for the Western Lake Superior Sanitary
District POTW in Duluth MN, includes a chloroform final effluent monitoring requirement.
Only the permit for Upper Potomac River Commission POTW in Westernport, MD includes
limits for the pulp mill bleach plant discharges.
4.2.3 Papergrade Sulfite Mills
At the time the Cluster Rules were promulgated, 11 papergrade sulfite mills
operated in the United States. As of 2004, only six of these mills still had sulfite operations and
all were direct dischargers. Table 4-8 lists these mills, their NPDES permit number, and the
segment of the Subpart E regulations that applies to their discharges. None of the operating
papergrade sulfite mills produce speciality grade pulp (Segment C).
4-11
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Table 4-8. Operating Papergrade Sulfite Mills
Mill Name
Wausau Mosinee Paper Mills, Brokaw
Weyerhaeuser Paper Co., Rothschild
Fraser Paper, Park Falls
Domtar, Port Edwards
Kimberly-Clark, Everett
Finch Pruyn & Co Inc., Great Falls
NPDES Permit
WI0003379
WI0026042
WI0003212
WI0003620a
WA0000621
NY0005525
Segment
A (calcium, magnesium, or sodium sulfite)
A (calcium, magnesium, or sodium sulfite)
A (calcium, magnesium, or sodium sulfite)
A (calcium, magnesium, or sodium sulfite)
B (ammonium sulfite)
B (ammonium sulfite)
Segment A - Applies to mills that produce pulp using calcium, magnesium, or sodium sulfite acidic cooking liquors.
Segment B - Applies to mills that produce pulp using an ammonium sulfite acidic liquor.
"Two Domtar mills (Nekoosa - BPK mill & Port Edwards - a PS mill) share a NPDES permit.
The six operating papergrade sulfite mills include one facility that is counted in
both Subparts B and E. The Domtar Port Edwards Mill produces bleached magnesium-based
sulfite pulp (Segment A) and has been totally chlorine free since 1993.
Permits for papergrade sulfite mills with operations in Segment A (calcium-,
magnesium-, and sodium-based sulfite) should have AOX limits and monitoring at the final
effluent. Permits for papergrade sulfite mills with operations in Segment B (ammonium-based
sulfite) should have limits for TCDD, TCDF, and 12 chlorinated phenolic pollutants at the
bleach plant effluent from each individual fiber line. Permits for the two Segment B mills also
include bleach plant chloroform monitoring requirements, even though the Cluster Rules did not.
Table 4-9 presents the number of permits for papergrade sulfite mills that do not include Cluster
Rule monitoring requirements. Both permits for the two operating Segment B mills include the
Cluster Rule requirements.
4-12
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Table 4-9. Number of Permits for Papergrade Sulfite Mills Missing Cluster Rules
Monitoring Requirements
Segment
A - calcium,
magnesium, or
sodium sulfite
B - ammonium
sulfite
Total
Permits
Collected
3
2
5
Permit
Expired
0/3
0/2
0
Required Monitoring Missing3
FE-AOX
3/3
(Final Effluent)
Reserved
3
BP-TCDF
Not required
0/2
(Bleach Plant)
0
BP-TCDD
Not required
0/2
(Bleach Plant)
0
BP-CP
Not required
0/2
(Bleach Plant)
0
BP = Bleach Plant FE = Final Effluent CP = Chlorinated Phenolic Compounds
aNo active PS mills are indirect dischargers or in the specialty grade segment.
None of the permits for the three mills with operations in Segment A (calcium,
magnesium, or sodium sulfite) include required final effluent AOX monitoring. All three mills
are located in Wisconsin. EPA plans to contact the Wisconsin NPDES permitting authority to
discuss the AOX monitoring requirements. The PCS database contained no report AOX loads
for the Segment A mill during the study period, 1998 through 2004.
4.3
Analysis of Compliance Monitoring Data
EPA compared PCS data to the Cluster Rules ELGs. For this review, EPA
compiled data for the period 1998, when the Cluster Rules were promulgated, through 2004, the
most recent full year for which PCS data were available. For pollutants with concentration-
based guidelines (TCDD, TCDF, and the chlorinated phenolic compounds), EPA determined if
the mill was meeting the guidelines by examining PCS-reported concentrations. EPA could not
determine if the mill was meeting the guidelines for pollutants with mass-based guidelines
(chloroform and AOX), because PCS does not include production information. For these
pollutants, EPA evaluated the effectiveness of the ELGs in reducing pollutant discharges by
comparing the baseline pollutant load estimated during the development of the guidelines to the
discharge load calculated using PCS data. As part of the Cluster Rules development, EPA
estimated baseline pollutant loads for each mill. Because EPA did not have data from each mill
subject to Subpart B or E, EPA modeled baseline discharges for each mill, based on the
4-13
-------
operations in use and pulp production as of mid-1995. Hereafter, these production-normalized
loads are referred to as "baseline loads."
As discussed in Section 4.2, the Cluster Rules require monitoring for certain
pollutants at the bleach plant and for other pollutants at the final effluent. However, because the
descriptions of monitoring locations in PCS are incomplete, EPA could not always identify
which locations were bleach plant effluent and which were final effluent. For this reason, EPA
reviewed additional information from mill permits and communication with the mills to identify
the outfalls as bleach plant effluent, final effluent, or other outfalls not regulated by the Cluster
Rules (e.g., noncontact cooling water or stormwater runoff). EPA's classification of each Phase I
mill's outfalls is presented in Appendix A to this report.
4.3.1 Bleached Papergrade Kraft
EPA collected and reviewed 64 NPDES permits for bleached kraft mills.
Although most of the permits included limits based on the Cluster Rules ELGs, monitoring data
for many of the regulated pollutants was missing from PCS. Table 4-10 lists, for each of the
Cluster Rules pollutants, the number of bleached kraft mills for which EPA found permit limits
and the number of mills for which it identified 2004 monitoring data in PCS. Table 4-10 also
shows, for the mills with monitoring data in PCS, the number for which EPA did not find permit
limits and the number for which it has not yet reviewed permits.
For example, EPA found that permits for 53 direct discharging bleached kraft
mills included requirements for monitoring TCDD at the bleach plant, as required by the Cluster
Rules. However, EPA identified bleach plant TCDD monitoring data in PCS for only 41 mills.
Of these mills, one had no permit requirements for TCDD bleach plant monitoring and EPA has
not yet reviewed the permits for five mills. Thus, of the 53 mills with required TCDD
monitoring, EPA identified data in PCS for only 35, and data for 18 mills (53 - 35) were missing
from PCS.
4-14
-------
Table 4-10. Comparison of Permit-Required Monitoring and Monitoring Data in PCS, for
Direct Discharge Bleached Kraft Mills
Number of Mills
With Permits
that Include
Cluster Rules
Monitoring a
Number of Mills With 2004 Data in PCS
Total Mills
Monitoring
No permit
limits
Mill permit
not yet
reviewed
Bleach Plant
TCDD
TCDF
Any Chlorinated
Phenolic Compound
Chloroform
53
52
52
52
41
42
40b
28b
1
2
1
1
5
5
4
3
Final Effluent
AOX
57
37b
1
5
Number of
Mills with
Permit limits
but no data in
PCS
18
17
17
28
26
Excludes indirect dischargers because their monitoring data is not typically reported to PCS.
bTwo Parsons & Whittemore mills (Alabama Pine Pulp and Alabama River Pulp) share a permit and their monitoring
data are reported to PCS as a single facility; and counted as one reporting mill in this table.
Table 4-11 presents the number of bleached kraft mills with permit limits and no
data in PCS. The table also presents EPA's understanding, at this time, of why permit-required
monitoring data are missing from PCS. Washington State does not upload in-plant monitoring
data to PCS, which accounts for the TCDD, TCDF, chlorinated phenolic compounds, and
chloroform in-plant monitoring data missing for four mills. See Section 4.3.3 for more
discussion or the Washington State monitoring data. In addition, one TCP mill has bleach plant
limits, but is not required to monitor. EPA has no explanation for why most of the permit-
required monitoring data are missing from PCS.
EPA noticed, however, that discharges of some of the Cluster Rules pollutants are
reported to PCS at a monitoring location inconsistent with ELGs compliance points. During this
study, EPA may have incorrectly identified the bleach plant monitoring location as final effluent
or it may be incorrectly identified in PCS. In its Federal Register Notice of the Preliminary 2006
Effluent Guidelines Program Plan, EPA will request that operators confirm EPA's classification
of outfalls listed in Appendix A.
4-15
-------
Table 4-11. Number of Bleached Kraft Mills With Permit Limits but No Data in PCS and
Why Data are Missing
Data Not Expected in PCS (i.e., Not
Required at TCP Mill)
State Does Not Upload In-Plant Monitoring
to PCS
Reason for No Data in PCS Unknown
Total Number of Mills With Permit Limits
but No Data in PCS
TCDD
1
4
13
18
TCDF
1
4
12
17
Any Chlorinated
Phenolic Compound
1
4
12
17
Chloroform
1
4
23
28
AOX
26
26
Bleach Plant TCDD and TCDF
Table 4-12 presents the number of mills monitoring TCDD and TCDF at the
bleach plant and the final effluent over the period 1998 to 2004. Too few detectable
concentrations were available to conduct a trend analysis on the basis of calculated mass
(grams/year) discharged. As an alternative, EPA counted the number of mills monitoring for
TCDD and TCDF and the number detecting these pollutants at concentrations above analytical
detection limits. Because many mills have more than one bleach plant, for this analysis, EPA
counted the number of mills that monitor bleach plant effluent, not the number of bleach plants.
Table 4-12. Number of Mills Reporting TCDD and TCDF Monitoring Data to PCS, 1998
through 2004
TCDD at BP
TCDD at FE
TCDD at either
TCDF at BP
TCDF at FE
TCDF at either
1998
11
33
41
2
14
14
1999
14
34
44
5
15
17
2000
18
34
45
9
15
19
2001
24
34
45
20
15
29
2002
31
30
47
30
14
38
2003
34
32
50
34
13
42
2004
41
30
52
42
12
49
Stopped monitoring
between 1998 and
2004
13
3
6
FE - Final effluent.
BP - Bleach plant, internal monitoring location.
4-16
-------
Table 4-12 shows two trends are occurring with respect to TCDD bleach plant
monitoring. Significantly more mills monitored for these pollutants in 2004 than in 1998.
During that same period, 13 mills stopped monitoring; however, in all cases, the mills stopped
monitoring when they were issued a new permit. Trends in mill TCDF monitoring follow a
similar pattern. Final effluent monitoring for TCDD or TCDF is not required by the Cluster
Rules, although it may be necessary to ensure compliance with state water-quality standards.
For the mills that report discharges to PCS in 2002, EPA estimated the 1995
baseline loads of TCDD and TCDF were 17.9 million TWPE. In 2002, TCDD and TCDF
discharges from these mills accounted for only 1.3 million TWPE, a 92% reduction from
baseline. By 2004, TCDD and TCDF discharges were only 26,493 TWPE, more than 99%
reduction from the 1995 baseline.
Monthly data for two mills (International Paper in Pine Bluff, AR and Boise
Cascade in St. Helens, OR) were unavailable for the analysis described in this preliminary report
because they were not properly identified as pulp mills when the EDS system compiled
monitoring data from PCS. PCSLoads2002 contained calculated loads of 0 Ib/yr TCDD for
those two mills at the final effluent and bleach plant monitoring locations. Data from these mills
is excluded from Section 4.3 tables and analysis, but will be included in the final report of this
study that will be prepared in support of EPA's 2006 Effluent Guidelines Program Plan.
Table 4-13 presents the concentrations of TCDD and TCDF detected in
wastewaters from 15 bleached kraft mills during the period 2001 through 2004. These
concentrations include the corrections to the 2002 PCS data described in Section 3.3. All other
measurements included in PCS for this time period were reported as less than the detection limit.
The table includes several measured concentrations that are less than the minimum level (ML)
for Method 1613B (10 pg/L). Measurements below or equal to the ML demonstrate compliance
with the Cluster Rules-based permit limits.
4-17
-------
Table 4-13. Concentration of TCDD and TCDF Detected in Bleached Papergrade Kraft
Mill Wastewaters (pg/L)
Mill
(NPDES Permit Number)
Location
2001
2002a
2003
2004
TCDD Detects
Bowater, Catawba
(SC0001015)
Weyerhaeuser, Johnsonburg
(PA0002143)
Upper Potomac Paver
Commission, Westernport
(MD0021687)C
Georgia-Pacific, Brunswick
(GA0003654)
Westvaco, Wickliffe
(KY0000086)
Bowater, Calhoun
(TN0002356)
Pope & Talbot, Halsey
(OR0001074)
Simpson Kraft, Tacoma
(WA0000850)
FE
other0
FE
FE
BP
BP
FE
FE
1.7-28.9d
0.8 b
83.6
(confirmed)
0
(corrected)
0
(corrected)
0
(corrected)
0
(corrected)
5.2b
10
10
10
0.5-6.7b'd
10
3.6-4.7b>d
TCDF Detects
Parsons & Whittemore
Alabama River Pulp,
Claiborne
(AL0025968)
International Paper, Bastrop
(LA0007561)
Georgia-Pacific, Palatka
(FL0002763)
Weyerhaeuser, Port
Wentworth
(GA0002798)
Boise, Jackson
(AL0002755)
Bowater, Calhoun
(TN0002356)
BP
BP
FE
BP
BP
BP
19
(confirmed)
0
(corrected)
11.3
(confirmed)
10
12.8
12
4-18
-------
Table 4-13 (Continued)
Mill
(NPDES Permit Number)
Georgia-Pacific, Clatskanie
(OR0000795)
Location
FE
2001
2002a
0
(corrected)
2003
2004
FE - Final Effluent.
BP - Bleach Plant, internal monitoring location.
NOTE: if no value is shown, either TCDD and TCDF were not monitored, or reported value was less than detection
limit (e.g., <10 pg/L).
aScreening-level PCSLoads2002 data were provided to industry April 5, 2005. Industry confirmed TCDD and
TCDF concentrations retrieved from PCS and submitted written explanations where disagreements existed. EPA
evaluated the information provided and corrected PCSLoads2002.
bConcentrations less than method 1613 minimum level.
GOutfall is surface impoundment formerly used to treat mill effluent.
dMore than one concentration measured; measured concentrations presented as a range.
ePOTW receiving chemical pulp mill wastewater from Mead/Westvaco (New Page); Luke (MD0021687).
One mill (Bowater Catawba, SC) confirmed it measured a TCDD concentration of
83.6 pg/L in a final effluent sample collected May 13, 2002 [10]. Bowater reports that, since that
date, neither TCDD nor TCDF has been measured in mill wastewaters above the method
detection limit (10 pg/L). Bowater reported a TCDD concentration of 5.2 pg/L, also at the final
effluent, in 2003. This concentration is less than the Method 1613 ML and demonstrates
compliance with the mill's permit limits. Prior to 2002, Bowater Catawba was not yet using
Elemental Chlorine-Free (ECF) bleaching technology. The mill is enrolled in Tier 1 of EPA's
VATIP and as such was provided with a six-year schedule for compliance with the Cluster Rules
requirements. After 2002, the Bowater Catawba mill converted to 100% chlorine dioxide
bleaching and started up an advanced fiber line [10].
Table 4-13 includes the TCDD concentration measured in 2001 at the
Weyerhaeuser mill in Johnsonburg, PA The outfall in which TCDD was detected is a surface
impoundment that was previously used to treat mill effluent. In 1992, the impoundment was
drained and is currently in the process of nonhazardous waste closure. The impoundment is not
an active treatment facility, but the permitting authority, Pennsylvania Department of
Environmental Protection, requires TCDD monitoring of this outfall due to the accumulated
sludge deposits. Discharges from this monitoring location represent past practices and do not
reflect current mill operations [11]. Since 2001, no TCDD has been measured at the mill above
the method detection limit.
4-19
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Bleach Plant Chlorinated Phenolic Compounds
EPA analyzed PCS data for chlorinated phenolic compounds in bleach plant
effluent. This analysis was similar to the analysis of TCDD and TCDF discharges. Again, too
few detectable concentrations were available to analyze discharge loads (grams/year discharged).
Instead, EPA counted the number of mills monitoring for chlorinated phenolic compounds and
the number detecting them at concentrations above analytical detection limits.
Table 4-14 presents the number of mills for which chlorinated phenolic
compounds data were available in PCS for the period 1998 to 2004. By 2004, approximately 40
bleached kraft mills monitored for chlorinated phenolic compounds. Most of these mills monitor
for all 12 of the regulated chlorinated phenolic compounds.
Table 4-14. Number of Bleached Papergrade Kraft Mills Reporting Chlorinated Phenolic
Compounds Data to PCS
Trichlorosyringol
Total Trichlorophenol0
3,4,5-Trichlorocatechol
3,4,5-Trichloroguaiacol
3 ,4,6-Trichlorocatechol
3 ,4,6-Trichloroguaiacol
4,5,6-Trichloroguaiacol
Tetrachlorocatechol
Tetrachloroguaiacol
2,3 ,4,6-Tetrachlorophenol
Pentachlorophenol
Mills Reporting Chlorinated Phenolic Compounds Data3
1998
2
2
1999
o
J
2
o
J
1
3
3
3
o
J
o
J
o
J
5
2000
7
2
7
5
7
6
7
7
7
6
9
2001
18
1
18
14
18
17
18
18
17
17
18
2002
29
2
29
24
29
26
29
29
28
26
29
2003h
33
2
33
28
33
30
33
33
32
30
32
2004
41
2
40
34
40
38
41
41
40
38
40
Stopped
monitoring
between
1998 and
2004
1
""Operating under a single permit, the Parsons & Whittemore mills (Alabama Pine Pulp and Alabama River Pulp) in
Claiborne, AL reported data for 10 chlorinated phenolic compounds from 2002 through 2004. The identified mill
counts include the two Parsons & Whittemore mills.
bExcludes one mill (Willamette Industries Inc. in Bennetsville, SC), which measured 10 chlorinated phenolic
compounds in year 2003 and at no other time during the 1998 through 2004 study period.
°Cluster Rules include limitations for 2,4,6-trichlorophenol and 2,4,5-trichlorophenol. PCS contains only a total
trichlorophenol parameter.
4-20
-------
Although the Cluster Rules have ELGs for 2,4,6-trichlorophenol and 2,4,5-
trichlorophenol, no parameter code exists in PCS for either compound. PCS has a parameter
code for total trichlorophenol, and total trichlorophenol data are available in PCS for two mills.
Table 4-14 shows that PCS includes 1998 data for trichlorophenol and
pentachlorophenol for two bleached kraft mills, but no other chlorinated phenolic compounds.
The number of mills monitoring for chlorinated phenolic compounds has increased steadily over
time. As of 2004, PCS had data for at least one chlorinated phenolic compound for 40 bleached
kraft mills.
Table 4-15 presents the concentrations of chlorinated phenolic compounds
detected in wastewaters from the only two mills that reported these compounds at concentrations
above the MLs during the period 2001 to 2004. The MLs achievable by EPA Method 1653 for
chlorinated phenolic compounds vary by compound. EPA has confirmed the discharge from
International Paper mill in Georgetown, SC [12]. EPA has contacted representatives from the
Weyerhaeuser Port Wentworth mill to confirm reported concentrations, but has not yet received
a response. Because the Weyerhaeuser-reported concentrations are 1,000 times the method ML,
the units reported to PCS may be incorrect.
Table 4-15. Concentrations of Chlorinated Phenolic Compounds Detected in Bleached
Papergrade Kraft Mill Bleach Plant Effluent (ug/L)
Chlorinated Phenolic
Compounds
2001
2002
2003
2004
Weyerhaeuser, Pt. Wentworth NPDES Permit GA0002798
3,4,5-trichlorocatechol
3,4,6-trichloroguaiacol
BP
BP
2,500 - 5,000
(DL=5)
2,500 (DL=2.5)
International Paper, Georgetown NPDES Permit SC0000868
4,5,6-trichloroguaiacol
BP
3,100 (DL=2.5)
FE - Final effluent.
BP = Bleach plant, internal monitoring location.
4-21
-------
EPA estimated baseline loads for all mills, including those that share discharges
(i.e., Domtar mills in Wisconsin and Parsons & Whittemore mills in Alabama). For the pollutant
reduction calculations, EPA summed the baseline loads for the two mills.
For the mills that reported discharges to PCS in 2002, EPA estimated 1995
baseline loads of chlorinated phenolic compounds were 4,178 TWPE. In 2002, reported loads,
excluding the two Weyerhaeuser Port Wentworth measurements discussed above, were zero.
EPA concludes that the ELGs have been effective at reducing bleach plant discharges of
chlorinated phenolic compounds.
Bleach Plant Chloroform Loads
EPA analyzed PCS data for chloroform in bleach plant effluents. Unlike TCDD,
TCDF, and chlorinated phenolic compounds, chloroform is typically measured at concentrations
above method detection limits. For this reason, EPA was able to calculated the load (grams/
year) discharged in each mill's bleach plant effluent. Table 4-16 presents the number of mills for
which PCS contains bleach plant chloroform data for the period 1999 to 2004 (PCS contains no
bleach plant chloroform data for 1998).
In addition to estimating the annual discharge load for each mill, EPA compared
the estimated load to the baseline load it had estimated for the mill, and tallied the number of
mills for which the annual load was above the baseline and the number below. Table 4-16 shows
that the majority of mills (e.g., 26 of the 29 reporting in 2004) report loads below the facility-
specific baseline loads.
4-22
-------
Table 4-16. Number of Mills Reporting Chloroform Monitoring Data to PCS, by Year, and
Relative to Baseline
Total number of mills with
bleach plant chloroform data
in PCS
Number of mills operating
above EPA's estimate of
their 1995 baseline load
Number of mills operating
below EPA's estimate of
their 1995 baseline load
% reduction from baseline*
1998
0
-
1999
3
o
5
99%
2000
7
1
6
99%
2001
13
2
11
97%
2002
22
2
20
98%
2003
26
2
24
98%
2004
29
o
J
26
98%
Tercent reduction is (EPA estimate of 1995 baseline - PCS reported) / (EPA estimate of 1995 baseline) x 100.
EPA also calculated the difference between the estimated annual loads and
baseline loads, and the percent reduction from baseline for the mills with chloroform data in PCS
for each year. Table 4-16 presents the percent reduction from baselines for each year, 1999 to
2004. For the 29 mills with data in PCS in 2004, the total annual load was 98 percent less than
EPA's estimated 1995 baseline for these mills.
During the!998-to-2004 study period, chloroform bleach plant loads at three mills
were greater than EPA's estimate of their 1995 baseline loads. Table 4-17 presents the annual
chloroform loads for these three mills. EPA reviewed PCS permit compliance data for these
three mills and determined that they did not violate their chloroform permit limits during the
study period.
As of 1995, the mills included in Table 4-17 used no hypochlorite, but instead
complete substitution of chlorine dioxide (C1O2) for chlorine [8]. Changes in production or
bleaching activities might have occurred at each of these mills after 1995 so that discharged
loads may no longer be comparable to 1995 estimates. EPA will contact these mills to discuss
mill changes.
4-23
-------
Table 4-17. Annual Loads of Three Mills with Chloroform Loads Above Baseline Loads
Bowater, Coosa Pines
(AL0003158)
Weyerhaeuser, New Bern
(NC0003191)
Weyerhaeuser, Columbus
(MS0036412)
1995
Baseline
Load
(kg/yr)a
246
111
302
1995
Bleaching
Technology
No
hypochlorite;
100% C1O2
No
hypochlorite;
100% C1O2
No
hypochlorite;
100% C1O2
2000b
(kg/yr)
NR
NR
637
2001
(kg/yr)
317
NR
1,060
2002
(kg/yr)
383
NR
1,384
2003
(kg/yr)
292
NR
1,442
2004
(kg/yr)
271
145
958
NR - not reported; PCS does not contain chloroform monitoring data.
Estimated baseline is production multiplied by a discharge factor, based on a mills bleaching chemical.
bPCS does not contain chloroform data for any of the three mills prior to 2000.
Final Effluent AOX, COD, and Color Loads
EPA analyzed PCS data for AOX, COD, and color. Final effluent discharges of
these pollutants were analyzed during the development of the Cluster Rules because they are
generated in pulping and bleaching operations. For this reason, although COD and color
discharges are not regulated by the Cluster Rules, EPA analyzed their current discharges along
with the discharges of AOX. These pollutants are typically measured in final effluent at
concentrations above method detection limits. Consequently, EPA was able to calculate
discharge loads (kg/year). Table 4-18 presents the number of mills for which PCS contained
monitoring data for these pollutants for the period 1998 to 2004. PCS included data for AOX for
17 mills in 1998, increasing to 38 mills by 2004. PCS includes COD and color data for fewer
mills; in 2004, PCS included COD data for 7 mills and color data for 20 mills.
In addition to estimating annual discharge load of AOX, COD, and color for each
mill, EPA compared the estimated load to the baseline load it had estimated for the mill, and
tallied the number of mills for which the annual load was above the baseline and the number
below. Table 4-18 shows that, for AOX, the majority of mills (e.g., 30 of the 38 mills with data
in PCS for 2004) report loads below the facility-specific baseline loads.
4-24
-------
EPA also calculated the difference between the estimated annual loads and
baseline loads, and the percent reduction from baseline. Table 4-18 presents the percent
reduction from baseline for all reporting mills, for each year from 1998 to 2004. The calculated
annual load for most mills is below EPA's estimate of their baseline loads. During the study
period, the annual AOX, COD, or color loads for five mills were zero (kg/yr). EPA calculated
zero loads from monthly ML measurements or other "no data" indicators. Zero loads are
included in the analysis.
EPA suspects the 1999 AOX discharge from Georgia-Pacific in Port Hudson Mill
in Zachary, LA may also be erroneous because it is a hundred times greater than any other
calculated load. It has a significant impact on the percent reduction for 1999 and is responsible
for the gain with respect to the baseline loads for 1999 shown in Table 4-18. As it completes this
study, EPA will contact the Zachary, LA mill to verify the accuracy of the 1999 AOX data in
PCS.
Table 4-18. Number of Mills Reporting Monitoring Data for AOX, COD, and Color to
PCS by Year and Relative Baseline Loads
1998
1999
2000
2001
2002
2003
2004
AOX
Total number of mills with AOX data in
PCS
Number of mills operating above EPA's
estimate of their 1995 baseline load
Number of mills operating below EPA's
estimate of their 1995 baseline load
% load reduction (gain) from baseline
17
4
13
60%
19
5
14
(334%)
21
4
17
70%
27
o
3
24
74%
35
8
27
69%
41
8
33
66%
38
8
30
61%
COD
Total number of mills with COD data in
PCS
Number of mills operating above EPA's
estimate of their 1995 baseline load
Number of mills operating below EPA's
estimate of their 1995 baseline load
% load reduction (gain) from baseline
0
-
-
-
1
1
-
(6%)
o
J
-
3
53%
2
1
2
39%
6
-
6
38%
6
-
6
39%
7
-
7
45%
4-25
-------
Table 4-18 (Continued)
1998
1999
2000
2001
2002
2003
2004
Color3
Total number of mills with color data in
PCS
Number of mills operating above EPA's
estimate of their 1995 baseline load
Number of mills operating below EPA's
estimate of their 1995 baseline load
% load reduction (gain) from baseline
18
9
9
6%
18
8
10
22%
17
7
10
30%
18
6
12
29%
21
6
15
39%
21
8
13
14%
20
8
12
8%
aVATIP mills excluded from counts.
EPA did not promulgate limits for COD or color under the Cluster Rules, but the
state permit writers have the authority to develop facility permit limits that are protective of state
water-quality standards (i.e., water-quality-based effluent limits (WQBEL)). Some states with
sensitive receiving streams have chosen to include final effluent limits for COD and/or color in
bleached kraft mill permits. Table 4-19 presents the number of mills with COD or color data in
PCS, by state.
Table 4-19. Number of Mills With COD or Color Data in PCS in 2004, by State
Alabama
Maine
Washington
Wisconsin
Georgia
Pennsylvania
Texas
Arkansas
Florida
Louisiana
North Carolina
South Carolina
Mill Population
in 1998
BPK
11
7
4
2
5
5
5
4
4
4
4
4
PS
1
3e
5
1
Mills with 2004 Data
in PCS
BPK
8
6
4
2
3
3
2
4
2
4
4
4
PS
1
3
Report
COD8
2004C
1
2
1
Report Color"
2004
1
3
2
3
1
2
2
Between
1998 and 2004
1
5d
2
o
6
i
2
3
4-26
-------
Table 4-19 (Continued)
Michigan
Mississippi
Oregon
Virginia
California
Kentucky
Minnesota
New York
Tennessee
Idaho
Maryland
Montana
New Hampshire
Ohio
Total
Mill Population
in 1998
BPK
o
J
3
3
3
2
2
2
1
2
1
1
1
1
1
84
PS
1
11
Mills with 2004 Data
in PCS
BPK
2
2
3
3
1
2
1
1
2
1
1
1
66
PS
1
5
Report
COD3
2004C
3
7
Report Color*
2004
1
3
1
1
20
Between
1998 and 2004
2
3
1
1
24
a>bPCS does not include COD or color data for papergrade sulfite mills.
°No mills that reported COD loads to PCS have stopped monitoring during the study period (1998 through 2004).
The population of mills reporting COD is greatest in 2004.
dThe only Maine mill that did not report a color load to PCS is Lincoln Pulp & Paper (ME0002003). EPA has not
collected the mill's permit. The Lincoln mill's active permit was issued on 1/23/1997 and expired 3/31/2002.
During the study period, annual loads of either AOX, COD, or color for 21 mills
were greater than EPA's estimate of their baseline load. Table 4-20 presents estimated loads for
the five mills for which the calculated annual load for more than one pollutant was observed
above baseline. Changes in production or bleaching activities might have occurred at each of
these mills after 1995 so that discharged loads might no longer be comparable to 1995 estimates.
4-27
-------
Table 4-20. Mills for Which Calculated Annual Load Exceeded EPA Estimated Baseline
Load for More than One Pollutant
Kimberly-Clark Corp, Coosa
Pines
(AL0003158)
Weyerhaeuser, Port Wentworth
(GA0002798)
Pope & Talbot, Halsey
(OR0001074)
Weyerhaeuser, Bennettsville
(SC0042188)
Stone Container, West Point
(VA0003115)
Pollutant
AOX
Color
AOX
Color
AOX
Color
AOX
Color
COD
Color
EPA's
Estimated
Baseline Load
(kg/y)
126,126
15,110,200
115,045
18,165,000
66,633
7,540,050
92,329
10,447,710
10,668,616
16,383,946
Highest
Measured
Load (yr)
2001
1998
2004
2003
2003
1999
1999
1998
1999
1999
Highest
Measured
Load (kg/y)
172,460
84,844,730
256,020
39,235,226
380,037
13,113,683
279,528
30,733,522
11,342,612
23,364,280
2004 Load
(kg/y)
125,880
31,937,542
256,020
24,631,232
33,026
3,251,130
not reported
not reported
8,949,075
19,067,745
The Weyerhaeuser Flint River Mill is classified as a minor discharger by the state
of Georgia; therefore, PCS does not contain discharge data for that mill. The mill voluntarily
supplied final effluent monitoring data for AOX, color, and various other conventional pollutants
that are measured at the facility [13]. Table 4-21 shows AOX and color loads for this mill; each
were significantly below EPA's estimated baseline loads.
Table 4-21. Weyerhaeuser Flint River Mill (Oglethorpe GA) Calculated Annual Load
Compared to EPA Estimated Baseline Load
Weyerhaeuser/Flint River Mill
Oglethorpe, GA
Pollutant
AOX
Color
EPA's
Estimated
Baseline
Load
(kg/y)
213,629
13,695,500
Highest
Measured
Load (yr)
2002
2004
Highest
Measured
Load (kg/y)
33,371
380,305
2004 Load
(kg/y)
7,468
380,305
4-28
-------
4.3.2 Papergrade Sulfite
As discussed in Section 4.2.3, at the time the Cluster Rules were promulgated, 11
papergrade sulfite mills operated in the United States. EPA identified six papergrade sulfite
mills operating in 2004. These six mills include four mills that produce pulp using calcium,
magnesium, or sodium sulfite acidic cooking liquors (Segment A); and two mills that produce
pulp using an ammonium sulfite acidic liquor ( Segment B). Monitoring results for one of these
six mills (Domtar Port Edwards) were analyzed with the bleached kraft mill data, because this
mill shares a wastewater treatment facility and an NPDES permit with the Domtar Nekoosa
bleached kraft mill.
Cluster Rules ELGs for papergrade sulfite mills differ from the ELGs for
bleached kraft mills. As summarized in Table 4-3, the ELGs for direct discharging papergrade
sulfite mills include:
Limits only for final effluent AOX for calcium, magnesium, or sodium
sulfite mills (Segment A); and
Bleach plant limits for TCDD, TCDF, and chlorinated phenolic
compounds, but not for chloroform or final effluent AOX limits, for
ammonium-based sulfite mills (Segment B).
Data are available in PCS for only two papergrade sulfite mills, one magnesium-
sulfite mill (Segment A) and one ammonium sulfite mill (Segment B). Table 4-22 presents the
baseline loads for these two mills and the estimated loads for 1998 through 2004. Available
loading information for each segment is discussed below.
Calcium, Magnesium, or Sodium-Based Sulfite Mills (Segment A)
Although the Cluster Rules require Segment A mills to monitor AOX at the final
effluent, permits for the three Segment A mills do not contain AOX limits, and PCS contains no
AOX loads for these mills for 1998 through 2004. Table 4-22 presents data for one mill
4-29
-------
(Weyerhaeuser in Rothschild, WI). The concentrations of TCDD and TCDF in final effluent
reported for this mill were below the Method 1613B detection limit.
Ammonium-Based Sulfite Mills (Segment B)
PCS includes monitoring data for all Cluster Rules pollutants for only one of the
two ammonium-based sulfite mills (Finch Pruyn in Glens Falls, NY). Table 4-22 presents
calculated annual loads where data were available. It should be noted that Finch Pruyn
experienced periods of low paper production from 2001 through 2004 due to labor and market
conditions, so AOX and other discharges during that period do not reflect normal mill
operations.
EPA has not analyzed PCS discharge data for the other ammonium-based sulfite
mill (Kimberly-Clark Worldwide in Everett, WA). Washington State has examined this mill's in-
plant monitoring data for compliance, but did not submit the data to PCS. See Section 4.3.3 for a
discussion of Washington State data.
Table 4-22. Loads for Two Papergrade Sulfite Mills, 1995 Baseline and 1998 through 2004
Weyerhaeuser, Rothschild
(WI0026042)
Magnesium Sulfite, Segment A
TCDD (final effluent)
TCDF (final effluent)
Finch Pruyn; Glens Falls
(NY0005525)a
Ammonium Sulfite, Segment B
AOX
Chlorinated Phenolic Compounds
(bleach plant)
Trichlorosyringol
3,4,5-Trichlorocatechol
3,4,5-Trichloroguaiacol
3,4,6-Trichlorocatechol
3,4,6-Trichloroguaiacol
4,5,6-Trichloroguaiacol
IPA's
Estimated
Baseline Load
(kg/y)
0
0
IPA's
Estimated
Baseline Load
(kg/y)
323,559
53
347
117
11
21
83
1998
(kg/y)
ND
ND
1998
(kg/y)
1999
(kg/y)
ND
ND
1999
(kg/y)
2000
(kg/y)
ND
ND
2000
(kg/y)
2001
(kg/y)
ND
ND
2001
(kg/y)
41,834
ND
ND
ND
ND
ND
ND
2002
(kg/y)
2002
(kg/y)
1,826
ND
ND
ND
ND
ND
ND
2003
(kg/y)
2003
(kg/y)
63,692
ND
ND
ND
ND
ND
ND
2004
(kg/y)
2004
(kg/y)
190,568
ND
ND
ND
ND
ND
ND
4-30
-------
Table 4-22 (Continued)
Finch Pruyn; Glens Falls
(NY0005525)"
Ammonium Sulflte, Segment B
Tetrachlorocatechol
Tetrachloroguaiacol
2,3,4,6-Tetrachlorophenol
Pentachlorophenol
TCDD (bleach plant)
TCDF (bleach plant)
EPA's
Estimated
Baseline Load
(kg/y)
88
45
6
11
0.0002 (g/yr)
0.0018 (g/yr)
1998
(kg/y)
1999
(kg/y)
2000
(kg/y)
2001
(kg/y)
ND
ND
ND
ND
ND
ND
2002
(kg/y)
ND
ND
ND
ND
ND
ND
2003
(kg/y)
ND
ND
ND
ND
ND
ND
2004
(kg/y)
ND
ND
ND
ND
ND
ND
a2001 to 2004 was a period of low production due labor and market conditions.
ND - Concentrations were below the method detection limit.
4.3.3
Washington State Paper Mills
During this detailed review, EPA found that data from only two of the six
Washington State mills are included in PCS from 1998 through 2004. As of 2004, six active
pulp and paper mills were located in Washington State, including five bleached kraft and one
papergrade sulfite mill. In 2004, each of these mills monitored mill effluents for TCDD and
TCDF. Typically, these data are submitted to the Washington Department of Ecology, imported
into the state's database (the Water Quality Permit Lifecycle System), examined for compliance
by the state, and transferred to EPA's PCS system. Because of an error in this transfer process,
data from only two of the six Washington State mills are included in PCS (Weyerhaeuser in
Cosmopolis and Simpson Kraft in Tacoma). All values of TCDD but one that are included in
PCS for these mills are "not detected." The exception is one 2001 measurement from the
Simpson Tacoma Kraft Mill, reported as 0.8 pg/L, which is less than the Method 1613 ML of 10
Pg/L.
EPA contacted the Washington Department of Ecology about the missing data.
The Department of Ecology provided bleach plant concentration data for each of its active mills,
but no discharge flow data [14]. Table 4-23 summarizes the reported TCDD and TCDF data,
presenting the number of times the pollutant was detected during the reporting year and the
number of measurements. For example, the TCDD counts for 2001 for Boise, Wallula are
shown as 0/6. This means that all six TCDD measurements made in 2001 were nondetects.
4-31
-------
Table 4-23. Counts of TCDD and TCDF Detected in Washington State Phase I Mill Bleach
Plants
NPDES Permit
Dates
Pollutant
Number of Detects/Number of Measurements
2001
2002
2003
2004
Bleached Kraft Mills
Boise, Wallula
(WA0003697)
Simpson Tacoma
Kraft, Tacoma
(WA0000850)
Weyerhaeuser,
Longview
(WA0000124)
James River"
(Georgia-Pacific),
Camas
(WA0000256)
issued: 7/1/01
expires: 7/1/06
issued: 11/1/01
expires: 11/1/06
issued: 6/1/04
expires: 6/1/09
issued: 4/15/03
expires: 4/15/08
TCDD
TCDF
TCDD
TCDF
TCDD
TCDF
TCDD
TCDF
0/6
2/6
0/1
0/1
0/12
1/12
0/12
0/12
0/12
0/12
0/12
0/12
K4: 0/8
K5: 0/8
K4: 0/8
K5: 0/8
0/12
2/12
0/12
0/12
0/7
3/7
K4: 0/12
K5: 0/12
K4: 0/12
K5: 0/12
Papergrade Sulfite Mill (Ammonium-Based, Segment B)
Kimberly-Clark,
Everettb
(WA0000621)
issued: 11/15/04
expires: 2/1/09
TCDD
TCDF
TCDF (intake) b
2/12
13/14
0/13
12/13
1/17
16/17
10/11
0/14
10/12
8/12
NOTE: If no value is shown, the mill did not monitor for that pollutant.
aThe James River in Camas, WA monitors TCDD and TCDF at two fiber lines (K4 and K5).
bSamples were collected at water intake to determine the extent of external TCDF formation.
As shown in Table 4-23, TCDF was detected in bleach plant effluent from three
of the Washington State Phase I mills. Although the Boise, Wallula and Weyerhaeuser,
Longview mills detected TCDF, the concentrations were less than the Cluster Rules daily
maximum limitation (31.9 pg/L). The Kimberly-Clark, Everett mill detected TCDF at
concentrations greater than the Cluster Rules daily maximum limitation and it also exceeded
Cluster Rules daily maximum limitations for TCDD. The Kimberly-Clark mill in Everett is
discussed in more detail in Section 5.0.
4-32
-------
s.o REVIEW OF TRI DATA
As noted in Section 1.0, EPA is conducting this detailed study of the Pulp and
Paper Category because it ranked highest among all point source categories for toxic pollutant
discharges [1]. EPA calculated this rank using the sum of the TRI-reported pounds, weighted by
toxicity, and the estimated PCS annual discharges, weighted by toxicity. EPA refers to pounds
weighted by toxicity as toxic-weighted pound equivalents (TWPE). For the Pulp and Paper
Category these estimates are:
(TRI) 3.13 million TWPE + (PCS) 1.52 million TWPE = 4.65 million TWPE
As discussed in Section 4.3.1, EPA estimated that, in 2002, one bleached kraft
mill, Bowater Catawba, SC, discharged 0.88 grams of TCDD, which equates to 1.37 million
TWPE.4 This mill has since changed its operations and has not detected either TCDD or TCDF
in its discharges since 2002. Without the Bowater-related PCS TWPE, the category discharges
are:
(TRI) 3.13 million TWPE + (PCS) 0.15 million TWPE (without Bowater Catawba) =
3.28 million TWPE
The TRI TWPE for the Pulp and Paper Category is almost four times greater than
any other category. Because of this very large TRI TWPE, even without the Bowater-related
PCS TWPE, this category ranks highest among all point source categories for toxic and
nonconventional pollutant discharges.
This section presents EPA's preliminary analysis of the Pulp and Paper Category
pollutant discharges reported to TRI. Both Phase I and Phase II mills are included in this
analysis. Phase III mills are not included because, as discussed in Section 1.2, in 2004 EPA
determined that it would not promulgate revised ELGs for Phase III mills. EPA's analysis of TRI
data is presented in the following subsections:
"Although this mill dominates the PCS TWPE, it does not similarly dominate the TRI TWPE. Its 2002 dioxins
release is less than 6% of the Pulp and Paper Category's total TRI-reported dioxins releases.
5-1
-------
Section 5.1: TRIReleases2002 Results Discussed with AF&PA;
Section 5.2: TRI-Reported Dioxins Releases;
Section 5.3: Comparison of TRI and PCS Dioxins Discharge Data;
Section 5.4: TRI-Reported Poly cyclic Aromatic Compounds (PACs); and
Section 5.5: Metals and Other Chemicals Reported to TRI.
5.1
TRIReleases2002 Results Discussed with AF&PA
Table 5-1 lists the 10 pollutants with the highest TWPE of TRI-reported
discharges for 2002, in order of descending TWPE. Table 5-1 lists the number of mills that
reported pollutant discharges to TRI and for each pollutant, the number of mills that reported
discharges, the pounds discharged, and TWPE. Discharges include direct discharges to surface
waters and transfers to POTWs. POTW transfers are included in the total discharges after
POTW removals are taken into account.
Table 5-1. Top 10 Pollutants in TRIReleases2002, for Phase I and Phase II
Number of TRI-reporting
Facilities
Pollutants
Dioxins
Lead and Lead Compounds
Manganese and Manganese
Compounds
PACs
Chlorine
Zinc and Zinc Compounds
Potassium
Dimethyldithiocarbamate
Mercury and Mercury
Compounds
Copper and Copper
Compounds
Vanadium and Vanadium
Compounds
Phase I
87 mills
Mills
47
71
72
51
5
47
NR
32
5
25
Released
(Ibs)
0.1334
12,717
3,436,371
884
26,382
234,243
NR
37
2,539
43,253
TWPE
2,760,188
28,485
49,597
30,231
13,433
10,983
NR
4,289
1,612
1,514
2,906,906
Phase II
169 mills
Mills
14
114
39
27
7
24
1
41
5
9
Released
(Ibs)
0.0129
16,695
857,936
440
21,357
73,751
12,341
24
1,424
8,447
TWPE
46,363
37,396
12,383
15,067
10,874
3,458
11,519
2,798
904
296
143,581
Total
256 mills
TWPE
2,806,551
65,881
61,980
45,298
24,307
14,441
11,519
7,087
2,516
1,809
3,050,487
Source: TRIReleases2002.
NR - Not Reported.
5-2
-------
The largest contributor to the TWPE for both Phase I and Phase II is dioxins,
which account for 95% of the Phase I TWPE and 92% of the Phase II TWPE.
EPA met with AF&PA and NCASI April 5, 2005. Prior to that meeting, EPA
provided AF&PA with a spreadsheet listing the category's 2002 TRI-reported discharges [15].
Following the meeting, EPA revised its estimates of toxic-weighted TRI-reported discharges, in
part because of information provided by AF&PA. The data presented in Table 5-1 reflect
EPA's revised estimates. As discussed in more detail later in this section, EPA's revisions
included developing a category-specific TWF for PACs discharged by pulp and paper mills and
correcting the dioxin congener distribution for one mill [1].
At the time of the April 5 meeting, EPA estimated that dioxins releases amounted
to 2.8 million TWPE, accounting for 90% of the category TWPE. Using a worst-case
assumption that all PACs discharged by the category were benzo(a)pyrene, EPA estimated that
PACs releases amounted to 140,733 TWPE, accounting for 4% of the category TWPE. To
provide EPA with a better understanding of the basis for mill-reported releases, NCASI
contacted the 9 mills with the highest reported dioxins releases, the 10 mills with the highest
reported PACs releases, and also provided EPA with information from NCASI's Handbook of
Chemical-Specific Information for SARA Section 313 Form R Reporting (SARA Handbook) [6].
In EPA's April 5 estimates of TRI-reported toxic discharges, lead, manganese, and other metals,
ranked below dioxins and PACs in total category TWPE. Because these pollutants contributed
less to EPA's earlier estimates of the category TWPE, AF&PA did not provide EPA with
information about how mills estimate releases of metals and metal compounds.
5.2 TRI-Reported Dioxins Releases
NCASI contacted 9 of the 10 mills that reported the largest dioxins releases for
2002 (one mill, Durango, has closed and was not contacted). Table 5-2 presents the information
about these mills that NCASI provided to EPA [16]. Six of the nine mills contacted by NCASI
estimated their discharges based on information contained in the SARA Handbook. One mill
5-2
-------
(Blandin) used a mass balance developed using SARA Handbook factors combined with its
chemical analysis of untreated wastewater.
Two mills, both in Phase I, used monitoring data to estimate their 2002 TRI-
reported dioxins discharges. Kimberly-Clark, Everett, WA has monitoring data for TCDF, but
(as reported by NCASI) subtracts the contribution from its water supply. Bowater, Catawba, SC
had effluent monitoring data, including detected concentrations of TCDD and TCDF5 and
detected concentrations of other congeners. (As previously noted, Bowater has not detected
TCDD or TCDF in its effluent above the Method 1613B ML since 2002.) AF&PA provided
EPA with the monitoring data Bowater used to estimate its 2002 TRI release [17]. Using these
monitoring data, EPA adjusted the congener distribution used to calculate the mill-specific
dioxins TWF. This adjustment reduced the estimated TWPE for the Bowater discharges.
Most of the mills contacted by NCASI used dioxins concentrations presented in
SARA Handbook Table 14 (PCDD/F Concentrations in Eight ECF Bleached Chemical Pulp
Mill Treated Effluents (NCASI 2002)) [18] to estimate their releases. The mills used the total
CDD/Fs value of 88.2 pg/L, a sum calculated using zero for congeners not detected [16]. The
mills multiplied their annual wastewater discharge flow by this concentration to calculate the
annual mass discharge reported to TRI.
5Bowater Catawba, SC provided a table showing that it detected 2.7 pg/L TCDD and 2.1 pg/L TCDF in mill effluent.
Both concentrations are less than the Method 1613B ML (minimum level) of 10 pg/L [17].
5-4
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Table 5-2. Dioxin and Dioxin-Like Compound Releases to Water Reported in TRI by Top 10 Mills for Reporting Year 2002
Facility and Location
Kimberly-Clark Worldwide Inc.,
Everrett, WA
Fort James Operating Co.,
Pennington, AL
Georgia-Pacific Crossett Paper
Ops., Crossett, AR
Potlatch Corp. Idaho Pulp &
Paperboard, Lewiston, ID
Bowater Inc. Coated & Specialty
Papers Div., Catawba, SC
Fort James Camas L.L.C., Camas,
WA
Durango-Georgia Paper Co., St.
Marys, GA
Georgia-Pacific Corp. Port Hudson
Ops., Zachary, LA
Blandin Paper Co., Grand Rapids,
MN
Domtar Maine Corp., Baileyville,
ME
Basis for Report
Mill used process mass
balance.
Mill used NCASI factors [18].
Mill used NCASI factors [18].
Mill used NCASI factors [18].
Effluent analyses [17].
Mill used NCASI factors [18].
Mill is closed, NCASI did not
contact.
NCASI factors (estimated
using NCASI Handbook Table
12 - for non-ECF mills) [19].
Actual data for untreated
wastewater less contributions
from raw water (SARA
Handbook Table 17) and clay
(SARA Handbook Table 20)
[20].
NCASI factors [18].
Annual Wastewater Flow
(million gallons/yr)
-
15,950.5
14,801
12,472
7,738
10,728
NA
8,293
9,437.5
Effluent Concentration
Used for Reporting (pg/L)
-
88.2
88.2
88.2
121.9
88.2
NA
105.7
88.2
Release to Water
Reported (Ib/yr)
0.0180
0.0117
0.0109
0.00941
0.00806
0.0079
0.00745
0.00731
0.0414
0.00695
Source: NCASI, April 29, 2005 [16].
NA -Not Applicable.
-------
In addition to the amount of each toxic chemical released, facilities are required to
report to TRI the method used to estimate the releases. Table 5-3 presents the methods for
estimating dioxins releases reported by pulp mills. TRI defines the estimation methods
presented in the table as follows:
M - Monitoring Data or Direct Measurement: An accurate method for
developing chemical releases. Monitoring required to be performed under
the Cluster Rules or other regulations should be available for developing
estimates. If only a small amount of direct measurement data are available
or the data are not representative, another technique may give a more
accurate result.
E - Emission Factor: A representative value that attempts to relate the
quantity of a chemical released with an associated activity. These factors
are usually expressed as the weight of chemical released divided by a unit
weight, volume, distance, or duration of activity releasing the chemical
(e.g., pounds of chemical released per pound of product produced.
C - Mass Balance: Calculation method to determine the amount of
chemical entering and leaving an operation. Most useful for chemicals
that do not become part of the final product, such as catalysts. For large
inputs and outputs, such as wastewater flow, a mass balance may not be
the best estimation method. Slight uncertainties in mass calculation can
yield significant errors in the release or other waste management
activities.
O - Engineering Calculation: Assumptions and/or judgements used to
estimate quantities of chemical released. The quantities are estimated by
using physical and chemical properties and relationships or by modifying
an emission factor to reflect the chemical properties of the chemical in
question.
As shown in Table 5-3, 53% of Phase I mills and no Phase II mills which reported
dioxins releases reported using emission factors to estimate their releases.
5-6
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Table 5-3. Number of Mills' TRI Estimation Techniques for Mills Reporting Non-Zero
Dioxins Discharges
Estimation Method
Engineering Calculations (O)
Direct Measurement (M)
Emission Factor (E)
Mass Balance (C)
Total Number of Reported Releases
Phase I
Number
8
10
23
2
43
Percent
19%
23%
53%
5%
Phase II
Number
4
2
-
o
6
9
Percent
44%
22%
-
33%
Source: TRIReleases2002.
5.3
Comparison of TRI and PCS Dioxins Discharge Data
Table 5-4 compares TRI and PCS data for the number of mills reporting non-zero
dioxins discharges and the mass released. For TRI, 47 Phase I and 15 Phase II mills reported
releases of a total of 68.6 grams of dioxin and dioxin-like compounds in 2002. In contrast, PCS
contains data for only one mill (Bowater, Catawba, SC) that reported final effluent discharge of
either TCDD or TCDF. Based on PCS data, EPA estimated that the Bowater Catawba mill
discharged 0.88 grams of TCDD in 2002.
Table 5-4. Comparison of TRI and PCS; Number of Mills Reporting Non-Zero Releases
and Mass of Dioxins Released
Phase I
Phase II
TRIReleases2002
Mills reporting dioxin and dioxin-like compounds
greater than zeroa
Total reported category discharge15
Number of mills
Grams/yr
47
60.4
14
5.9
PCSLoads2002
Mills reporting TCDD greater than zeroa
Total category discharge
Mills reporting TCDF greater than zeroa
Total category discharge
Number of mills
Grams/yr
Number of mills
Grams/yr
1
0.88
0
0
0
0
0
0
aMills reporting discharge of zero are not presented.
blndirect and direct discharges reported; indirect account for POTW removal (83% estimated for dioxin and
dioxin-like compounds).
5-7
-------
Bowater reported to TRI that they discharged 3.6 grams of dioxin and dioxin-like
compounds in 2002. According to information provided by NCASI, this estimate was based on
the average daily flow of 21.2 million gallons per day (MGD) and "total CDD/Fs" concentration
of 121.9 pg/L [17]. Using concentration and flow information in PCS, EPA calculated that the
mill discharged 0.88 grams of TCDD in 2002. The Bowater PCS discharge was the result of a
single measurement (83.6 pg/L) above the method detection limit (10 pg/L). Because this
concentration was measured on a quarterly reporting cycle, to calculate the annual discharge
load (pounds/year), EPA assumed it represented the mill's effluent concentration for three
months.
Kimberly-Clark in Everett, WA had the largest 2002 TRI-reported releases of
dioxins and dioxin-like compounds (8.19 grams), but no TCDD or TCDF data are reported to
PCS for this mill.
Based upon discussions of the PCS reported load that EPA had with the mill and
Washington Department of Ecology, there are two factors that contribute to the mill's TCDF
discharges. First, the Washington Department of Ecology, Kimberly-Clark, and EPA's
Chemical Engineering Branch have determined that the mill's water intake contains
unchlorinated TCDF precursors, and at certain times of the year TCDF formation occurs [21].
Second, the chlorination process used at the mill is atypical and has been shown to generate
2,3,7,8-TCDF, which transfers to the mill process water [16]. To quantify intake loadings, the
mill collects TCDF measurements of the chlorinated process water. The mill's NPDES permit
contains Cluster Rules TCDD and TCDF bleach plant monitoring requirements and an allowance
for TCDF periodic measurements above the method detection limit (10 pg/L). Compliance
monitoring data were not contained in PCS, but were provided by the Washington Department of
Ecology. Kimberly-Clark has measured TCDF in both the process water and bleach plant
effluent from 2001 through 2005 [14]. EPA will continue to investigate TCDD and TCDF loads
at the Everett mill.
-------
5.4 TRI-Reported PACs
NCASI contacted the 10 mills that reported the largest PACs releases for 2002.
Table 5-5 presents the information about these mills NCASI provided to EPA [16]. Seven of the
nine mills for which NCASI obtained information estimated their discharges based on
information contained in the SARA Handbook. The two remaining mills estimated releases
based on results of chemical analysis of their wastewater. For both mills, concentrations of all
PACs were less than analytical detection limits, but the mills used a fraction of the detection
limit to estimate a pollutant mass discharged for TRI.
The mills that used the SARA Handbook to estimate their TRI releases used
Table 5 PAC Concentrations in Pulp Mill Effluents. This table is reproduced as Table 5-6.
NCASI explained that where mills chose to use the data in SARA Handbook Table 5, they used
the value in the "TOTAL" column that corresponded to their pulping type.
EPA used the data from Table 5-6 to calculate a category-specific toxicity
weighting factors (TWF) for PACs discharged by pulp and paper mills [1]. Because there are
few bisulfite, chemi-thermo- mechanical pulp, and thermo-mechanical pulp mills compared to
the number of kraft mills, EPA used the kraft mill concentrations to calculate the category PAC
TWF.
5-9
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Table 5-5. PAC Releases to Water Reported in TRI by Top 10 Mills for Reporting Year 2002
Facility and Location
Groveton Paper Board, Inc.,
Groveton
Meadwestvaco Maryland Inc.,
Luke
Alabama River Pulp Co. Inc.,
Perdue Hill
Ray order Performance Fibers
Jesup Mill, Jesup
Weyerhaeuser Pulp Mill,
Cosmopolis
Domtar Inds. Inc. Ashdown
Mill, Ashdown
Monadnock Paper Mills, Inc.,
Bennington
International Paper, Augusta
SP Newsprint Co. Newbert
Mill, Newberg
International Paper Courtland
Mill, Courtland
Basis for Report
Mill believes it produces PACs in semi-chemical liquor
combustion kiln that is fitted with a wet scrubber. Treated
effluent analysis for 10 PACs made in conjunction with an
NPDES Permit application showed all PACs analyzed (10
cmpds) were not detected at 5 ppb. Mill used 1 ppb for all
analyzed PACs as the basis for reporting [22] .
Mill used annual priority pollutant scan for which 8 PACs
were reported to be not detected at a detection limit of 5.0
ppb. Mill used 1A of detection limit for reporting [23].
Mill used NCASI factors [24].
Mill used NCASI factors [24].
Mill used NCASI factors [24].
Mill used NCASI factors [24].
Mill has not responded to request for information.
Mill used NCASI factors. Mill has since identified an error
in the calculation and will be filing a correction.
Mill used NCASI factors [24].
Mill used NCASI factors [24].
Annual
Wastewater Flow
(million gallons/yr)
1,788.5
7,641.3
14,288.7 (kraft)
1,768.0 (IMP)
20,576
7,394
20,121
4,716
17,045.9
Effluent Concentration
Used for Reporting
(u,g/L - unless otherwise
stated)
10 ppb (1 ppb for each of
10 PACs)
20 ppb (2.5 ppb for each
of 8 PACs)
0.213 (kraft)
0.789 (IMP)
0.213
0.605
0.213
0.789
0.213
Release to
Water
Reported
(Ib/yr)
149.2
1,269.5
(transferred to
POTW)
39
37
37
35.7
32.1
30.8
30.24
Source: NCASI, April 29, 2005 [16].
TMP - Thermo-mechanical pulp.
-------
Table 5-6. PAC Concentrations in Pulp Mill Effluents (H.-C. Lavellee, Inc. 1990)a
Pulping
Type
Kraft
Bisulfite
Chemical
Thermo-
mechanical
Pulp
Thermomech
anical Pulp
Fine Paperd
N"
2
4
4
2
1
PAC->
1
2
3
4
5
6
Total0
Concentration (ppb or jig/L)
MDL
Range
Average
Range
Average
Range
Average
Range
Average
Range
Average
0.05
ND
NDto
0.07
0.036
ND
ND
ND
0.05
ND
ND
ND
NDto
0.13
0.078
ND
0.05
ND
ND
ND
NDto
0.65
0.338
ND
0.1
ND
ND
ND
ND
ND
0.05
NDtoTr
0.038
NDto
1.6
0.419
NDto
0.055
0.033
NDto
0.42
0.223
ND
0.1
ND
ND
ND
ND
to 0.1
0.075
ND
0.213
0.605
0.208
0.789
ND (0.40)
MDL - Method Detection Limit.
Tr - Trace (assumed equal to MDL).
ND - Not Detected.
aOnly for mills that use chemicals containing trace quantities of PACs; PACs are not manufactured during pulping or
bleaching (Young et al. 1990).
bNumber of mills tested.
°Compounds reported as less than the detection limit have been included in the total at one-half the detection limit.
dNon-integrated mill.
PACs in the Table:
1 - Benzo(a)anthracene; 2 - Benzo(a)pyrene; 3 - Benzo(b+k)fluoranthene; 4 - Dibenzo(a,h)anthracene; 5 -
Fluoranthene; 6 - Indeno(l,2,3-c,d)pyrene.
NCASI calculated the emission factors for the industry based on six PACs:
benzo(a)anthracene, benzo(a)pyrene, benzo(b+k) fluoranthene, dibenzo(a,h)anthracene,
fluoranthene, and indeno(l,2,3-c,d)pyrene. For the kraft mills, only fluoranthene was detected
above the method detection limit; however, four of the other five compounds were detected
above the method detection limit for the other pulping types. Because the calculated TWF will
be used for all mills in the Pulp and Paper Category, EPA used one-half the detection limit for
compounds that were not detected in kraft mill wastewaters. NCASI also calculated the
emission factor using one-half the detection limit for compounds that were not detected. As
shown in Table 5-1, when the PACs TWPE is calculated using the category-specific TWF, PACs
account for the fourth highest TWPE of the TRI-reported chemical discharges for Phase I and
5-11
-------
Phase II mills, comprising 1.5% of Phase I and Phase II TWPE. This is a significant change
from the April 5, 2005 results, in which PACs comprised 4% of the Phase I and Phase II TWPE.
Table 5-7 presents the methods for estimating PACs releases reported by pulp and
paper mills. As shown in Table 5-7, 77% of Phase I mills and 65% of Phase II mills that reported
PACs releases reported using emission factors to estimate their releases.
Table 5-7. Number of Mills Reporting PAC TRI Estimation Techniques, by Phase and
Discharge Type
Engineering Calculations (O)
Direct Measurement (M)
Emission Factor (E)
Mass Balance (C)
Total Number of Reported Releases
Phase I
Number
10
3
44
-
57
Percent
18%
5%
77%
-
Phase II
Number
8
1
17
-
26
Percent
31%
4%
65%
-
Source: TRIReleases2002.
Note: See descriptions of O, M, E, and C on page 5-6.
5.5
Metals and Other Chemicals Reported to TRI
As shown in Table 5-1, after dioxins, the pollutants with the largest TWPE
reported discharged by Phase I and Phase II mills are lead and lead compounds and manganese
and manganese compounds. A total of 185 Phase I and Phase II mills reported discharges of
lead and lead compounds, more mills than reported discharges of any other pollutant. As it
completes this detailed study, EPA will discuss with AF&PA and NCASI how mills estimate
their TRI-reported discharges of these pollutants. EPA will also investigate technical literature
to learn more about possible process sources of these wastewater pollutants.
Thirteen mills reported wastewater discharges of chlorine (C12). However,
chlorine reacts very quickly with water to form HOC1, C1-, and H+. This is an equilibrium
reaction (at a pH above 4, the equilibrium shifts almost completely toward formation of these
products). Because pulp and paper mills discharge wastewater at between pH 7 and pH 9, EPA
5-12
-------
expects no releases of chlorine (C12) in wastewater. As it completes this detailed study, EPA
plans to investigate these chlorine releases and discuss them with industry.
5-13
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6.0 STATUS OF THE DETAILED STUDY AND NEXT STEPS
This report presents the preliminary results of EPA's detailed study of the pulp
and paper industry. EPA began the study during its 2005 annual review of existing effluent
guidelines and will complete the study during its 2006 annual review. The results of the study
will be published with EPA's 2006 Effluent Guidelines Program Plan. EPA has prepared this
preliminary report to provide the public opportunity to comment on the data collected to date and
EPA's analysis of these data. In its Federal Register Notice of the Preliminary 2006 Effluent
Guidelines Program Plan, EPA will request additional information about the pulp and paper
industry to support the completion of this study.
EPA's progress in addressing the two main issues of this study and the steps it
will take to continue the study are summarized in the following subsections:
• Section 6.1: Analysis of the Implementation and Impact of the Cluster
Rules;
• Section 6.2: Investigation of the Non-bleaching Sources of Toxic and
Nonconventional Pollutants; and
• Section 6.3: Requests for Additional Information.
6.1 Analysis of the Implementation and Impact of the Cluster Rules
EPA has made substantial progress in determining how the 1998 Cluster Rules
have been implemented and their effect on mill discharges.
EPA collected 73 permits applicable to Phase 1 mills and reviewed them to
determine if they were developed using Cluster Rules effluent limitations guidelines. EPA
received another five permits after completing of the analyses described in this preliminary
report. EPA found that most of the permits it analyzed followed the Cluster Rules guidelines,
though at least seven permits issued after April 15, 1998 did not. To complete the detailed study,
EPA will:
6-1
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Analyze late-arriving permits; and
Contact the state staff that developed the seven permits that do not
incorporate the guidelines to understand how they were developed.
EPA analyzed data available in PCS to assess the impact of the Cluster Rules on
wastewater discharges. As discussed in Section 4.0, for mills with data available in PCS, EPA
found that by 2004, almost all of them met Cluster Rules concentration-based guidelines for
TCDD, TCDF, and chlorinated phenolic compounds. For pollutants with mass-based guidelines,
EPA found that the majority of mills discharged less than EPA's estimated baseline loads
(pounds/year). However, EPA found that data for Cluster Rules pollutants were missing from
PCS for many mills. To complete the detailed study, EPA will:
Contact mills that EPA identified as discharging pollutant loads
(pounds/year) much greater than EPA's baseline estimate. These include
three mills with chloroform loads above baseline and one mill for which
PCS data indicate the AOX load was much higher in one year than in
other years. EPA will contact the mills to verify that the data in PCS are
correct.
Discuss with EPA's Office of Enforcement and Compliance Assurance
(OECA) the permit-required monitoring data that are missing from PCS.
OECA is responsible for maintaining PCS.
Discuss with state permitting authorities the permit-required monitoring
data that are missing from PCS. States are responsible for loading
Discharge Monitoring Report (DMR) data into PCS.
Correct the identification of mill outfalls using information provided by
industry or others, and update the analysis of industry discharges.
6.2 Investigation of the Non-bleaching Sources of Toxic and Nonconventional
Pollutants
EPA has not yet focused on investigating non-bleaching sources of toxic
pollutants (dioxins, PACs, metals, ammonia, and possibly others). Non-bleaching sources
include discharges from Phase II mills as well as non-bleaching sources at Phase I mills, such as
papermaking and recovery operations. As of July 2005, EPA had analyzed TRI-reported
6-2
-------
discharges of dioxins and PACs, by reviewing information provided by AF&PA. In addition,
EPA has made a preliminary analysis of nutrient (nitrogen- and phosphorus-containing
parameters) discharges reported in PCS. EPA found that the Pulp and Paper Category ranked
high in both nitrogen and phosphorus discharges reported to PCS [25]. To complete the detailed
study, EPA will:
Discuss with AF&PA and NCASI how Phase I and Phase II mills estimate
TRI-reported releases of toxic pollutants other than dioxins and PACs,
particularly lead, manganese, zinc, and other metals.
Contact mills with high TRI-reported releases of toxic compounds
(including the one mill that reported releases of potassium
dimethyldithiocarbamate) to understand how they estimated their releases.
Further analyze nitrogen and phosphorus data in PCS, including the
reported concentrations and locations of mills that report nutrient
discharges.
Investigate the process sources and potential control technologies for
nitrogen and phosphorus discharged by pulp and paper mills.
Review technical literature focusing on:
— Spent pulping liquor from unbleached kraft mills and
papermachine additives and coatings, which are potential sources
of toxic pollutant releases,
— Wastewater pollutants derived from combustion-related activities,
— Applicability, performance, and cost of nitrogen and phosphorus
control technologies used in the pulp and paper industry,
— Changes in the production process implemented so mills will
comply with the Cluster Rules, to identify process improvements
or additional pollution prevention programs implemented since
1998 and compile the available information on the pollutant
reductions, and
— EPA's National Listing of Fish Advisories (NLF A) which presents
the current status of advisories against consuming dioxin-tainted
fish. The NLF A provides tracking information from 1993 to the
present. EPA will compare current fish advisories to the fish
consumption advisories in place at the time of the 1998 ELGs
revision.
6-3
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6.3 Requests for Additional Information
This subsection presents the requests for additional information that EPA will
make in its Federal Register Notice of the Preliminary 2006 Effluent Guidelines Program Plan.
As discussed in Section 4.0, to evaluate the implementation of the Cluster Rules,
EPA reviewed pipe and outfall descriptions contained in PCS for bleached papergrade kraft and
papergrade sulfite mills (Phase I mills). EPA identified these pipes and outfalls as bleach plant
effluent, final effluent, or other type of monitoring location. EPA requests that operators of these
Phase I mills verify EPA's identification of their PCS monitoring locations listed in Appendix A
of this report.
Some permits require in-process monitoring (bleach plant effluent monitoring)
but the permitting authority (state) does not include in-process monitoring results in PCS. EPA
requests that operators of bleached papergrade kraft or papergrade sulfite mills provide results of
their permit-required (or other) bleach plant effluent monitoring, where these monitoring results
are missing from PCS.
As presented in Section 5.0, EPA reviewed the information provided by AF&PA
and its member companies regarding the measurement techniques used to calculate TRI-reported
toxic discharges at 19 individual Phase I mills. EPA requests additional details of methods used
to estimate releases of toxic pollutant discharges reported to TRI, in particular those methods
used by Phase II mills (mills without bleached papergrade kraft or papergrade sulfite operations)
to estimate releases of dioxins, PACs, and toxic metals.
EPA requests information about non-bleaching sources of toxic wastewater
pollutants, such as pollutants derived from combustion-related activities, spent pulping liquor
from unbleached kraft mills, and papermachine additives and coatings.
EPA requests examples (i.e., case studies) of mill process changes implemented
in response to the Cluster Rules, including the wastewater pollution reduction benefits of
6-4
-------
installing best available control technologies (BAT) and using best management practices
(BMPs) for the control of spent pulping liquor losses.
6-5
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7.0 REFERENCES
1. U.S. EPA. Screening-Level Analysis Report. Washington, D.C. 2005. DCN
02173
2. Eastern Research Group, Inc. Pulp and Paper Detailed Study Plan. April 2005.
DCN 01760.
3. Eastern Research Group, Inc. Toxic Weighting Factor Development in Support of
the 304(m) Planning Process. January 1, 2005. DCN 02013
4. Eastern Research Group, Inc. Toxic Weighting Factor Development in Support of
the 304(m) Planning Process - Spreadsheet. January 1, 2005. DCN 02173A1
5. Eastern Research Group, Inc. Memorandum: Kickoff Meeting Between EPA and
AF&PA. April 15, 2005. DCN 01709.
6. NCASI. Handbook of Chemical-Specific Information for SARA Section 313 Form
R Reporting. Full report available only member companies, excerpts provided.
DCN 01753, 01754, 01755, and 01759.
7. U.S. EPA. Emergency Planning and Community Right-to-Know, EPCRA Section
313, Guidance for Reporting Guidance for Reporting Toxic Chemicals within the
Dioxin andDioxin-like Compounds Category. EPA 745-B-00-021. December
2000.
8. Supplemental Technical Development Document for Effluent Limitations
Guidelines and Standards for the Pulp, Paper, and Paperboard Category: Subpart
B [Bleached Papergrade Kraft and Soda] and Subpart E [Papergrade Sulfite].
EPA-821-R-97-011. October 1997.
9. Jerry Schwartz, Senior Director, Water Quality Programs AF&PA to Lynn Zipf,
U.S. EPA. Memorandum: Industry Information on EPA Effluent Limitations
Guidelines Program Plan Rankings. May 2, 2005. DCN 01710.
10. Larry Bowling, Bowater Catawba to Jay Unwin, Northern Regional Manager
NCASI. Enclosure 1, Re: 2002 Discharge Monitoring Report Dioxin Data. April
15, 2005. DCN 01744.
11. Personal Communication. Amy Schaffer, Federal Regulatory Affairs Manager
Weyerhaeuser and Andy Redmond, Environmental Manager Weyerhaeuser
Johnsonburg Mill to Bryan Lange, Eastern Research Group, Inc. May 19, 2005.
DCN 01740.
7-1
-------
12. Jeffrey Lynn, External Regulatory Affairs Manager, International Paper to Jerry
Schwartz, Senior Director, Water Quality Programs AF&PA. Re: International
Paper Data on Cluster Rule BAT Monitoring. June 24, 2005.
13. Personal Communication and Data Submittal. Willard Parker, Weyerhaeuser Flint
River to Karrie-Jo Robinson-Shell, U.S. EPA. April 14, 2005.
14. Personal Communication and Data Submittal. Merley McCall, Washington
Department of Ecology to Bryan Lange, Eastern Research Group, Inc. May 24,
2005. DCN01729.
15. Personal Communication and Data Submittal. Lynn Zipf, U.S. EPA to Jerry
Schwartz, Senior Director, Water Quality Programs AF&PA. Questions and
information for next Tuesday's meeting. March 29, 2005. DCN
16. Paul Wiegand, Vice President Water Quality Programs, NCASI. Memorandum to
Jerry Schwartz, Senior Director, Water Quality Programs AF&PA. April 29,
2005. DCN 01743.
17. Paul Wiegand, Vice President, Water Quality Programs NCASI. Memorandum to
Jerry Schwartz, Senior Director, Water Quality Programs AF&PA. Enclosure 15,
Facility Specific Effluent Dioxin Data for Bowater in Catawba South Carolina.
April 29, 2005. DCN 01758.
18. Paul Wiegand, Vice President, Water Quality Programs NCASI. Memorandum to
Jerry Schwartz, Senior Director, Water Quality Programs AF&PA. Enclosure 11,
PCDD/F Concentrations in Eight EFC Bleached Chemical Pulp Mill Treated
Effluents (NCASI 2002). April 29, 2005. DCN 01754.
19. Paul Wiegand, Vice President, Water Quality Programs NCASI. Memorandum to
Jerry Schwartz, Senior Director, Water Quality Programs AF&PA. Enclosure 12,
Mean PCDD/F Concentrations in Eight Bleached Chemical Pulp Mill (Mostly
Non-ECF) Treated Effluents From EPA 's Guidance Document. April 29, 2005.
DCN 01755.
20. Paul Wiegand, Vice President, Water Quality Programs NCASI. Memorandum to
Jerry Schwartz, Senior Director, Water Quality Programs AF&PA. Enclosures 16
through 18, Calculation of Facility Specific Indirect Discharge Dioxin Data using
NCASI SARA Handbook Tables. April 29, 2005. DCN 01759.
21. M. Ahmar Siddiqui, U.S. EPA. Memorandum to Don Nelson, Washington
Department of Ecology. June 9, 2003. DCN 01729A.
22. Paul Wiegand, Vice President, Water Quality Programs NCASI. Memorandum to
Jerry Schwartz, Senior Director, Water Quality Programs AF&PA. Enclosure 13,
Facility Specific Effluent Polycyclic Aromatic Compounds Data for Grovetown
Paper Mill in Grovetown New Hampshire. April 29, 2005. DCN 01756.
7-2
-------
23. Paul Wiegand, Vice President, Water Quality Programs NCASI. Memorandum to
Jerry Schwartz, Senior Director, Water Quality Programs AF&PA. Enclosure 14,
Facility Specific Indirect Discharge Polycyclic Aromatic Compounds Data for
MeadWestvaco in Luke Maryland. April 29, 2005. DCN 01757.
24. Paul Wiegand, Vice President, Water Quality Programs NCASI. Memorandum to
Jerry Schwartz, Senior Director, Water Quality Programs AF&PA. Enclosure 10,
PAC Concentrations in Pulp Mill Effluents (B.C. Lavallee, Inc. 1990. April 29,
2005. DCN 01753.
25. Eastern Research Group, Inc. Point Source Category Rankings by Nitrogen and
Phosphorus Loads Calculated using 2002 PCS Data. August 1, 2005.
-------
Appendix A
PCS DISCHARGE LOCATIONS AND EPA DESIGNATED PIPE USAGE
-------
Appendix A
PCS Discharge Locations and EPA Designated Pipe Usage
The attached table lists National Pollutant Discharge Elimination System
(NPDES) permits that EPA is reviewing as part of the pulp and paper detailed study. The
permits listed are for Phase I mills (mills with wastewater discharges that meet the applicability
of 40 CFR 430 Subpart B (Bleached Papergrade Kraft and Soda) and Subpart E (Papergrade
Sulfite). Permits for four POTWs receiving significant amounts of pulp mill wastewater are also
included. The table includes the following:
•Mill NPDES ID number;
Discharge Pipe - numbers that appear in PCS for each NPDES permit.
For example, NPDES AL000396 has 12 discharge pipes, numbered 1
through 12.
Designated Pipe Usage - EPA's best guess at the usage of the discharge
pipe. EPA has designated pipes and outfalls as:
FE- Final Effluent;
BE - Bleach Plant; or
OOS - Out of Scope. Out of scope pipes include stormwater
runoff, non-contact cooling water, emergency overflow, etc;
Evidence - a code for the evidence that EPA used to categorize the
discharge pipe. EPA used permits and PIPE descriptions contained in the
PCS database to designate location. If these two resources provided
insufficient information to identify the discharge pipe, EPA used the
pollutant discharged as indicator. For example, the Cluster Rules require
final effluent AOX monitoring. Absent additional information, the
presence of AOX indicates final effluent. EPA used the following codes to
describe the evidence it used to categorize the discharge pipe:
1 - permit;
2- PCS pipe description; or
3- pollutant as an indicator.
• Pipe or Outfall Description - taken from PCS or the NPDES permit.
EPA requests operators of the mills listed in Appendix A confirm the monitoring
location designations.
A-l
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
AL0000396
AL0000396
AL0000396
AL0000396
AL0000396
AL0000396
AL0000396
AL0000396
AL0000396
AL0000396
AL0000396
AL0000396
AL0000396
AL0000396
AL0000396
AL0002682
AL0002682
AL0002755
AL0002755
AL0002755
AL0002755
AL0002780
AL0002780
AL0002780
AL0002780
AL0002780
AL0002780
AL0002780
Discharge
Pipe
(DSCH)
001
001
001
001
002
003
004
005
006
007
008
009
010
Oil
012
001
002
001
001
001
002
001
002
003
004
005
006
009
EPA Designated
Pipe Usage a
BP
BP
FE
BP
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
BP
FE
FE
BP
BP
DOS
FE
DOS
DOS
DOS
DOS
DOS
DOS
Evidence b
2
2
2
3
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
o
6
2
2
2
2
2
2
2
2
Pipe or Outfall Description
2003 PERMIT NO 1/2 HARDWOOD
2003 PERMIT NO 3 SOFTWOOD
COMBINED PROCESS & SANITARY
BP in 2002 and prior
STORM WATER SEMI-ANNUAL
STORM WATER SEMI-ANNUAL
STORM WATER SEMI-ANNUAL
STORM WATER SEMI-ANNUAL
STORM WATER SEMI-ANNUAL
REPORT
SEMI-ANNUAL
MONITORING/REPORTI
STORM WATER SEMI-ANNUAL
REPORT
COMBINED STORM WATER 002 &
003
COMBINED STORM WATER 004-006
RIVER INTAKE PUMP FILTER SC BW
2003 PERMIT ANNUAL
BLEACH PLT ALK 001A/B REPORTIN
OXIDATION POND EFFLUENT
PROCESS & NON-CONTACT
WSTWTR
BLEACH PLANT INTERNAL
DISCHARG
BP in 2000 and prior
DSN002 STORMWATER ANNUAL
PROCESS WASTEWATER
DISCHARGE
WOOD YARD STORM DRAINAGE
DSN003 STORMWATER
STORM WATER
STORM WATER SEMI-ANNUAL
REPORT
STORM WATER
STORM WATER
A-2
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
AL0002780
AL0002780
AL0002780
AL0002780
AL0002780
AL0002801
AL0002801
AL0002801
AL0002801
AL0002801
AL0002801
AL0002801
AL0002801
AL0002801
AL0002801
AL0002801
AL0002801
AL0002801
AL0002828
AL0002828
AL0002828
AL0002828
AL0002828
AL0002828
AL0003018
AL0003018
Discharge
Pipe
(DSCH)
010
Oil
012
013
014
001
002
003
004
007
008
009
010
012
013
019
021
022
001
001
001
001
005
006
002
003
EPA Designated
Pipe Usage a
DOS
DOS
DOS
DOS
DOS
FE
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
BP
BP
BP
FE
DOS
DOS
FE
BP
Evidence b
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
3
2
2
2
1
1
Pipe or Outfall Description
FIRE & STORM WATER, STEAM CON
STORM WATER
STORM WATER VARIOUS AREAS
STORM WATER
STORM WATER
TIER I LIMITS
DSN002 STORM WATER NON-
PROCESS
STORMWATER
(UNCONTAMINATED)
DSN004 STORM WATER NON-
PROCESS
NONCONTACT COOLING WATER
EMERGENCY BYPASS.
DSN009 STORM WATER
WOODYARD
STORMWATER
(UNCONTAMINATED)
STORM WATER
DSN013 STORM WATER NON-
PROCESS
DSN019 STORM WATER NON-
PROCESS
DSN021 STORMWATER
STORM WATER VARIOUS AREAS
DSN001A BLEACH PLANT
INTERNAL
DSN001B BLEACH PLANT
INTERNAL
BP in 2000 and prior
PROCESS
ASH POND & AIR SCRUBBER
STORM WATER
PROC, SANTRY STRMWTR DSN 002
DRID (A = No. 1 (Hardwood) Bleach
plant internal requirement; B = No. 2
(Softwood) Bleach plant internal
requirement
A-3
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
AL0003018
AL0003018
AL0003018
AL0003018
AL0003018
AL0003018
AL0003158
AL0003158
AL0003158
AL0003158
AL0003158
AL0003158
AL0003158
AL0003158
AL0003301
AL0003301
AL0003301
AL0003301
AL0003301
AL0003301
AL0003301
AL0025968
AL0025968
Discharge
Pipe
(DSCH)
004
005
006
007
008
Oil
001
001
001
001
002
003
004
006
001
001
001
001
001
002
003
001
001
EPA Designated
Pipe Usage a
DOS
DOS
DOS
DOS
DOS
DOS
BP
BP
BP
FE
DOS
DOS
DOS
DOS
BP
BP
BP
FE
FE
DOS
DOS
BP
BP
Evidence b
2
2
2
2
2
2
2
2
3
2
1
1
1
1
2
2
3
2
2
1
1
1
1
Pipe or Outfall Description
STORMWATER QUARTERLY
REPORTING
STORMWATER QUARTERLY
REPORTING
STORMWATER QUARTERLY
REPORTING
STORMWATER NO
MONITORING/REPOR
DSN008 STORMWATER NO
MONTI/REP
DSN011 STORMWATER
DSNOO ID BEGIN 040101
DSNOO IE BEGIN 040 101
BP in 2002 and prior
PROCESS WASTEWATER
NC COOLING/ASH POND OF/STORM
DSN003 SEMI ANNUAL
MONITORING;
DSN003 SEMI ANNUAL
MONITORING;
DSN006 STORMWATER SEMI-
ANNUAL;
DSNOO 1 A BLEACH PLANT
INTERNAL
DSNOO IB BLEACH PLANT
INTERNAL
BP in 2000 and prior
DSNOO 1 AOX REPORTING
PROCESS
LANDFILL STORMWTR W/O
LEACHATE
LANDFILL STORMWTR W/O
LEACHATE
Alkaline discharge into the effluent
treatment system from the Alabama Pine
Pulp (APP) bleach line
Alkaline discharge into the effluent
treatment system from the Alabama River
Pulp (ARP) bleach line
A-4
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
AL0025968
AL0025968
AL0025968
AL0025968
AL0025968
AL0025968
AL0025968
AL0025968
AL0025968
AR0001210
AR0001210
AR0001210
AR0001210
AR0001210
AR0001210
AR0001210
AR0001601
AR0001601
AR0001601
AR0001601
AR0002968
AR0002968
AR0002968
AR0002968
AR0002968
Discharge
Pipe
(DSCH)
001
001
001
001
002
003
004
005
006
001
002
101
102
103
SMS
TX1
001
002
SUM
TX1
001
01A
01B
01C
TX1
EPA Designated
Pipe Usage a
BP
FE
BP
BP
DOS
DOS
DOS
DOS
DOS
FE
DOS
BP
BP
BP
DOS
DOS
DOS
DOS
DOS
DOS
FE
BP
BP
BP
DOS
Evidence b
o
J
2
1
1
2
2
2
2
2
1
2
1
1
1
2
2
1
2
2
2
1
1
1
1
2
Pipe or Outfall Description
BP in 2001 and prior
TOTAL FACILITY DISCHARGE
Acid discharge into the effluent treatment
system from the APP bleach line
Acid discharge into the effluent treatment
system from the ARP bleach line
RIVER WATER FROM CYCLONE
SEPAR
DSN003 ANNUAL STORM WATER
OVERFLOW TREATED MILL FRESH
WA
2002 PERMIT ANNUAL; WAST=03
2002 PERMIT ANNUAL; WAST=03
QUARTERLY REPORTING
CONTROLLED DSCH FROM MOSSY
LK
101-MONTHLY-LINE 1A HARD
WOOD
102-MONTHLY-LINE IB HARD
WOOD
103-MONTHLY-LINE 2 SOFT WOOD
SMS002-DOWNSTREAM
MONITORING
00 1 -QUARTERLY-CHRONIC
TOXICITY
TOTAL FACILITY OUTFALL
002-MONTHLY-EMERGENCY
OVERFLOW
001 & 002 COMBINED
001 -SEMIANNUAL-ACUTE TOXICITY
PROCESS/SANI WW; CONTAM.
STORM
01A-INTERNAL-LINE 1A-
HARDWOOD
01B-INTERNAL-LINE IB-
HARDWOOD
01C-INTERNAL-LINE 2-SOFTWOOD
CHRONIC TOXICITY REPORTS
A-5
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
AR0035823
AR0035823
AR0035823
AR0035823
AR0035823
AR0035823
CA0004065
CA0005894
CA0005894
CA0005894
CA0005894
FL0002526
FL0002631
FL0002763
FL0002763
FL0002763
FL0020206
GA000195
GA000195
GA000279
GA000279
GA000280
GA000280
GA000365
GA000365
GA000365
GA000365
GA000365
GA000365
GA000365
GA000365
GA000365
Discharge
Pipe
(DSCH)
001
002
003
004
101
TX1
001
001
101
201
INF
001
001
001
002
003
001
001
002
001
006
001
010
001
002
003
004
005
010
Oil
020
021
EPA Designated
Pipe Usage a
FE
DOS
DOS
DOS
BP
DOS
FE
FE
BP
DOS
DOS
FE
FE
FE
DOS
BP
FE
DOS
DOS
FE
BP
FE
DOS
FE
DOS
BP
BP
BP
DOS
DOS
DOS
DOS
Evidence b
1
2
2
2
1
2
2
1
1
2
2
1
2
1
1
1
2
3
3
1
1
1
o
6
i
2
1
1
1
3
2
2
2
Pipe or Outfall Description
TOTAL FACILITY DISCHARGE
002-MONTHLY-WTR TRMT TNK
BOTTM
003 -MONTHLY-RUNOFF & COOLING
004-MONTHLY-SAND FLTR
BACKWASH
101-INTERNAL-BLEACH PLANT
001 -QUARTERLY- ACUTE TOXICITY
NON-SEASONAL PARAMETERS
PULPMILL 00 I/MONTHLY
WTR PLANT 10 I/MONTHLY
WTR SUPPLY/MONTHLY
INFLUENT/MONTHLY
PROCESS AND SLOWDOWN
DISCHARGE
TOTAL FACILITY DISCHARGE
PERMIT MONITORING POINT A
MONITORING POINT C
INSTREAM MONITORING POINT R3
TREATED WASTEWATER
PROCESS WASTEWATER
** BLEACH PLANT EFFLUENT
ANNUAL
QUARTERLY
TIDAL DISCHARGE 001
PARSHALL FLUME
BLEACH PLNT#1
BLEACH PLNT # 2
BLEACH PLNT # 3
** 001-TREATED PROCESS WATER**
NONCNT COOL WTR#008,0 18,0 19,020
** 002 TPW--PARSHALL FLUME ***
CAR WASH
A-6
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
GA000365
GA000365
GA000365
GA000365
GA004933
GA004933
ID0001163
KY0000086
KY0000086
KY0000086
KY0000086
KY0000086
KY0001716
KY0001716
KY0001716
KY0001716
KY0001716
KY0001716
KY0001716
KY0001716
KY0001716
LA0003468
LA0003468
LA0003468
LA0003468
LA0003468
LA0003468
LA0003468
LA0003468
LA0003468
Discharge
Pipe
(DSCH)
030
050
OAO
OBO
001
OAO
001
001
002
003
004
BPO
001
002
003
004
005
006
007
008
BPO
001
009
010
Oil
012
013
014
015
016
EPA Designated
Pipe Usage a
DOS
DOS
DOS
DOS
FE
DOS
FE
FE
DOS
DOS
DOS
BP
FE
DOS
DOS
DOS
DOS
DOS
DOS
DOS
BP
FE
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
Evidence b
2
2
o
J
3
1
3
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Pipe or Outfall Description
OUTFALL 003 BLEACH PLNT. # 1
OUTFALL 005 BLEACH PLNT. # 2
Process Wastewater
001 DSCHG UNDER LOW FLOW
PROCESS WASTEWATER
UPSTREAM STORMWATER
MONITORING
DOWNSTREAM STORMWATER
MONITORG
STORMWATER RUNOFF FROM
LANDFIL
BLEACH PLANT EFFLUENT
FINAL EFFLUENT LIMITS
PROCESS WATER (CORRUGATED)
STORMWATER RUNOFF
STORMWATER RUNOFF
STORMWATER RUNOFF
STORMWATER RUNOFF
STORMWATER RUNOFF
STORMWATER RUNOFF
BLEACH PLANT #2 INTERNAL
POINT
PROCESS WASTEWATER
INTAKE WATER TREATMENT
PLANT
STORM WATER RUNOFF
STORM WATER RUNOFF
STORM WATER RUNOFF
PLANT SITE STORMWATER
STORM WATER RUNOFF
PLANT SITE STORMWATER
PLANT SITE STORMWATER
A-7
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
LA0003468
LA0003468
LA0003468
LA0005258
LA0005258
LA0005258
LA0005258
LA0005258
LA0005258
LA0005258
LA0007561
LA0007561
LA0007561
LA0007561
LA0007561
LA0007927
LA0007927
LA0007927
LA0007927
MD000142
MD000142
MD000142
MD000142
MD000142
MD000142
MD000142
MD000142
MD000142
MD000142
MD000142
Discharge
Pipe
(DSCH)
017
101
TX1
001
002
101
201
301
SUM
TX1
001
101
202
203
TX1
001
002
101
TX1
001
002
003
004
005
006
007
01S
02S
03S
04S
EPA Designated
Pipe Usage a
DOS
BP
DOS
FE
DOS
BP
BP
BP
DOS
DOS
FE
DOS
BP
BP
DOS
FE
DOS
BP
DOS
DOS
DOS
DOS
DOS
DOS
DOS
FE
DOS
DOS
DOS
DOS
Evidence b
2
2
2
1
1
1
1
1
2
2
1
2
1
1
1
1
1
1
o
J
1
1
1
1
1
1
1
2
2
2
2
Pipe or Outfall Description
STORM WATER RUNOFF
BLEACH PLANT EFFLUENT
10/02-12/02 DMR TOXIC RPT
TREATED PROCESS WASTEWATER
PLANT SITE STORMWATER
Bleach Plant No. 1
Bleach Plant No.2
Bleach Plant No. 3
SUM OF OUTFALL 001 & 003
WHOLE EFFLUENT TOXICITY
TREATED PROCESS WASTEWATER
WASTEWATER FROM WHAM
BRAKE
WASTEWATER FROM A-LINE
BLEACH
WASTEWATER FROM B-LINE
BLEACH
QUARTERLY 48HR. ACUTE
TOXICITY
TREATED PROCESS WASTEWATER
NON-PROCESS AREA STORMWATER
PROCESS WASTEWATER
QUARTERLY CHRONIC TOXICITY-
001
NONCONTACT COOLING WATER
NONCONTACT COOLING WATER
ASH/WATER SLUDGE SUPERNATE
NONCONTACT COOLING WATER
NONCONTACT COOLING WATER
NONCONTACT COOLING WATER
influent chamber of the POTW
01S OUTFALL
02S OUTFALL
ASH & RAW WATER SLUDGE
04S OUTFALL
A-8
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
MD000142
MD000142
MD000142
MD002168
MD002168
MD002168
ME000016
ME000016
ME000016
ME000016
ME000016
ME000187
ME000187
ME000187
ME000193
ME000200
ME000200
ME000202
ME000202
ME000202
ME000202
ME000202
ME000202
ME000205
ME000205
ME000205
ME000205
ME000232
ME000232
ME000232
ME000232
ME002152
Discharge
Pipe
(DSCH)
058
06S
101
001
01S
101
001
002
003
009
020
001
002
003
001
001
003
001
002
003
004
006
100
001
002
003
004
001
002
003
100
001
EPA Designated
Pipe Usage a
DOS
DOS
DOS
FE
DOS
DOS
FE
DOS
DOS
DOS
DOS
FE
DOS
DOS
FE
FE
DOS
FE
DOS
DOS
DOS
DOS
BP
FE
DOS
DOS
DOS
FE
DOS
DOS
BP
FE
Evidence b
2
2
2
1
3
3
2
2
2
2
2
1
2
2
1
2
2
1
1
1
1
1
1
1
2
2
2
2
2
2
2
1
Pipe or Outfall Description
OUTFALL 058
OUTFALL 06S
UGS GAUGING STATION LUKE
IND AND MUN WASTEWATER
OUTFALL01S
INFLUENT/CHLORMUN SEWAGE
TREATED PROCESS WASTEWATER
RECOVERY COMPENSATE &
COOLANT
FILTER HOUSE BCKWASH WATER
TRASH SCREEN SHOWER WATER
COOLING WATER RECOVERY
PLANT
TREATED PROCESS WASTEWATER
COOLING,CONDENSATE & STORM
H2O
TURBINE/BLEACH PLANT COOLING
TREATED PROCESS WASTEWATER
TREATED PROCESS WASTEWATER
TOXICITY TESTING AND TCDD
TREATMENT PLANT EFFLUENT
NON CONTACT COOLING WATER
FILTER BACKWASH WATER
STEAM CONDENSATE/WOOD ROOM
STEAM COMPENSATE
INTERNAL WASTE STREAM
TREATED PROCESS WASTEWATER
NON CONTACT COOLING WATER
NON CONTACT COOLING WATER
NON CONTACT COOLING WATER
TREATED PROCESS WASTEWATER
SANDFILTER BACKWASH
NON CONTACT COOLING WATER
INTERNAL WASTE STREAM
TREATED PROCESS WASTEWATER
A-9
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
ME002152
ME002152
ME002152
ME002152
ME002152
ME002152
MI0000027
MI0000027
MI0000027
MI0001210
MI0027391
MI0027391
MI0027391
MI0042170
MI0042170
MN000143
MN000143
MN000143
MN000143
MN000164
MN000164
MN000164
MN000164
MN000164
MN000164
MN000164
MN004978
Discharge
Pipe
(DSCH)
002
003
004
005
007
100
001
002
OOA
001
001
002
101
001
001
010
020
030
701
001
030
040
050
060
501
950
010
EPA Designated
Pipe Usage a
DOS
DOS
DOS
DOS
DOS
BP
FE
DOS
BP
DOS
FE
DOS
DOS
FE
BP
DOS
DOS
FE
DOS
FE
DOS
DOS
DOS
DOS
DOS
BP
FE
Evidence b
2
2
2
2
2
1
1
2
2
2
1
2
2
2
2
2
2
2
2
1
2
2
2
2
2
2
2
Pipe or Outfall Description
STORMWATER RUNOFF
STORMWATER RUNOFF
STORMWATER RUNOFF
STORMWATER RUNOFF
STORMWATER RUNOFF
BLEACH PLANT
WASTEWATER TO ESCANABA
RIVER
NONCONT COOL H2O TO
ESCANABA R
OUTFALL OOA THROUGH 001;
WAST=01
001A/NONCONTACT COOLING
001 MOSQUITO CREEK DISCHARGE
002 WASTEWATER BIG BLACK
CREEK
101 WASTEWATERS MUSKEGON
RIVER
FACILITY DISCHARGE
001B BLEACH PLT PROCESS
WASTEW
010 NON-CONTACT COOLING
WATER
Clearwell overflow discharge
Proc water supply line dschg
Stream monitoring
Total process effluent discharge
Dioxin & Furan Monitoring
LIFT STATION #8 BYPASS
LIFT STATION #2 BYPASS
LIFT STATION #3 BYPASS
PRIMARY & SECONDARY SLUDGES
BLEACH PLANT EFFLUENT
DRID Q=Quarterly effluent; DRID
M=001 Total Facility Discharge;
Identified as 001 in Permit issued 8-27-
2002
A-10
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
MN004978
MN004978
MN004978
MS000267
MS003170
MS003170
MS003170
MS003641
MS003641
MS003641
MT000003
MT000003
MT000003
MT000003
MT000003
MT000003
MT000003
NC000027
NC000027
NC000027
NC000068
NC000068
NC000068
NC000319
NC000319
NC000329
NH000065
NH000065
NH000065
NH000065
NH000065
Discharge
Pipe
(DSCH)
701
702
703
001
001
002
003
001
002
003
001
002
003
004
CDD
RIV
SUM
001
002
003
001
002
005
001
003
001
001
003
005
009
010
EPA Designated
Pipe Usage a
DOS
DOS
DOS
FE
FE
DOS
BP
FE
DOS
BP
FE
FE
FE
DOS
DOS
DOS
DOS
FE
BP
BP
FE
DOS
DOS
FE
BP
FE
DOS
DOS
DOS
DOS
DOS
Evidence b
2
2
2
2
2
2
2
1
2
1
2
2
2
2
2
2
2
2
2
2
1
1
2
1
1
1
2
2
2
2
2
Pipe or Outfall Description
Blatnik Bridge Monitoring
Raw water intake
SUPERIOR/CLOQUET WATER
INTAKE
TOTAL PROCESS OUTFALL
PROCESS WASTEWATER
SANITARY WASTEWATER
INTERNAL OUTFALL PROCESS WW
PROCESS WASTEWATER
MILL STEAM COMPENSATES FIRE
INTERNAL OUTFALL-PROCESS WW
DISCHARGE FROM OUTFALL 001
DISCHARGE FROM OUTFALL 002
DISCHARGE FROM OUTFALL 003
UNCONTAMINATED COOLING
WATER
COLLECTIVE DIRECT DISCHARGE
CLARK FORK RIVER
COMBINED ANNUAL DISCHARGE
EFF
Pine bleach plant
Hardwood bleach plant
PROCESS WATER
PROCESS WW
NONCONTACT COOLING/FINE
PAPER
EFF
bleach plant effluent
EFF
NON-CONTACT COOLING WATER
NON-CONTACT COOLING WATER
NON-CONTACT COOLING WATER
NON-CONTACT COOLING WATER
BURGESS FILTER HOUSE
BACKWASH
A-ll
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
NH000065
NH000065
NH000065
NH000065
NH000065
NH000065
NH000065
NH000065
NH000065
NY0004413
NY0004413
NY0004413
NY0005525
NY0005525
NY0005525
NY0005525
NY0005525
OH000448
OH000448
OH000448
OH000448
OH000448
OH000448
OH000448
OH000448
OH000448
OH000448
OH000448
Discharge
Pipe
(DSCH)
Oil
013
014
015
016
017
018
100
SUM
001
002
01A
008
009
Oil
012
08A
001
002
003
004
005
006
007
008
009
582
586
EPA Designated
Pipe Usage a
DOS
DOS
DOS
DOS
FE
DOS
DOS
BP
DOS
FE
DOS
BP
FE
DOS
DOS
DOS
BP
FE
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
Evidence b
2
2
2
2
2
2
2
2
2
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Pipe or Outfall Description
NON-CONTACT COOLING WATER
BURGESS HOT WATER OVERFLOW
NON-CONTACT COOLING WATER
NON-CONTACT COOLING WATER
PROCESS AND STORMWATER
CASCADE FILTER
BACKWASH/OVERFL
CASCADE TREATED
PROCESS/WASTEW
TESTING BLEACH PLANT
EFFLUENT
COMBINATION OUTFALLS 016 & 018
PROCESS WASTEWATER
SANITARY WASTEWATER
BLEACH PLANT WASTEWATER
INTNL
PROCESS DISCHARGE
Stormwater
Cooling Water, Fresh Water Overflow to
Forebay (Hudson River)
Cooling Water, Fresh Water Overflow to
Hudson River
Bleach Plant Effluent
001 EFFLUENT
Storm water effluent
Storm water effluent
Storm water effluent
Storm water effluent
Storm water effluent
Storm water effluent
Storm water effluent
Storm water effluent
582 (BYPRO) SLUDGE REMOVED
FRO
586 (BYPRO) SLUDGE REMOVED
FRO
A-12
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
OH000448
OH000448
OH000448
OH000448
OR000079
OR000079
OR000079
OR000079
OR000079
OR000107
OR000107
PA0002143
PA0002143
PA0002143
PA0002143
PA0002143
PA0008265
PA0008265
PA0008265
PA0008265
PA0008265
PA0008265
PA0008265
PA0008265
PA0008265
PA0008265
PA0008265
PA0008265
PA0008265
PA0008265
PA0008265
Discharge
Pipe
(DSCH)
600
802
902
903
001
002
003
004
FAC
001
OOS
001
002
004
102
202
001
002
003
004
005
006
007
008
009
010
Oil
012
013
014
015
EPA Designated
Pipe Usage a
BP
OOS
OOS
OOS
FE
OOS
OOS
OOS
BP
FE
OOS
OOS
FE
OOS
OOS
BP
FE
OOS
OOS
OOS
OOS
OOS
OOS
OOS
OOS
OOS
OOS
OOS
OOS
OOS
OOS
Evidence b
1
1
1
2
1
2
1
2
2
2
2
1
1
2
1
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Pipe or Outfall Description
600 INTERNAL MONITORING
STATIO
802 PAINT CREEK, UPSTREAM OF 0
902 PAINT CREEK,DOWNSTREAM
OF
903 PAINT CREEK, DOWNSTREAM 1,
PROCESS EFFLUENT
CRAWFORD CREEK STORM WATER
WTP FILTER BACKWASH DITCH
LOG WASHER EFFLUENT
BLEACH PLANT STREAM
PROCESS & SANITARY
WASTEWATER
SANITARY STP EFFLUENT
001 -DILL HILL CLOS ACT RUNOFF
002 MILL & MISC WASTEWATER
004 PULP MILL SW RUNOFF-EMER
#5 PAPER MACHINE AREA SW
RUNOF
Bleach Plant
TOTAL FACILITY DISCHARGE
STORMWATER OUTFALL 002
STORMWATER OUTFALL 003
STORMWATER OUTFALL 004
STORMWATER OUTFALL 005
STORMWATER OUTFALL 006
STORMWATER OUTFALL 007
STORMWATER OUTFALL 008
STORMWATER OUTFALL 009
STORMWATER OUTFALL 010
STORMWATER OUTFALL Oil
STORMWATER OUTFALL 012
STORMWATER OUTFALL 013
STORMWATER OUTFALL 014
STORMWATER OUTFALL 015
A-13
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
PA0008265
PA0008265
PA0008265
PA0008265
PA0008265
PA0008265
PA0008869
PA0008869
PA0008869
PA0008869
PA0008869
PA0008869
PA0008869
PA0008869
PA0008869
PA0008869
PA0008885
PA0008885
PA0026301
PA0026301
PA0026301
PA0026301
SC0000868
SC0000868
SC0000868
SC0000868
SC0001015
SC0001015
SC0001015
SC0001015
SC0001015
SC0038121
Discharge
Pipe
(DSCH)
016
017
018
019
020
101
001
002
101
102
Sll
S27
S40
S41
S42
SW1
001
003
001
002
101
201
001
01A
01B
01C
001
003
005
01A
01B
001
EPA Designated
Pipe Usage a
DOS
DOS
DOS
DOS
DOS
BP
FE
DOS
BP
BP
DOS
DOS
DOS
DOS
DOS
DOS
FE
DOS
FE
DOS
BP
DOS
FE
BP
BP
BP
FE
DOS
DOS
DOS
BP
FE
Evidence b
2
2
2
2
2
1
1
2
1
1
2
2
2
2
2
2
3
2
3
2
2
2
1
1
1
1
2
o
J
o
J
1
1
1
Pipe or Outfall Description
STORMWATER OUTFALL 016
STORMWATER OUTFALL 017
STORMWATER OUTFALL 018
STORMWATER OUTFALL 019
STORMWATER OUTFALL 020
101-1ST,2ND,3RD STAGE BLEACH P
OUTFALL 001
002-NON CONTACT COOLING
WATER
IMP 101-BLEACHPLTEFFL-SOFTWD
IMP 102-BLEACH PLT EFFL-
HARDWD
STORMWATER OUTFALL SW1 1
STORMWATER OUTFALL SW27
STORMWATER OUTFALL SW40
STORMWATER OUTFALL SW41
STORMWATER OUTFALL SW42
STORMWATER OUTFALL SW1
OUTFALL 001
003 EMER SPILL BASIN OUTFALL
OUTFALL 001
ORF OVERFLOW
INTERNAL MP 10 I/MAIN TPWS
EFFLUENT FROM OVERFLOW RET
FAC
TOTAL FACILITY DISCHARGE
Line A
LineB
LineC
001 PROCESS WASTEWATER
facility's sanitary wastewater
Bleach Plant Testing, internal point source
PROCESS/SANITARY/RUNOFF
A-14
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
SC0038121
SC0038121
SC0038121
SC0042188
SC0042188
SC0042188
SC0042188
SC0042188
SC0042188
SC0042188
TN0001643
TN0001643
TN0001643
TN0001643
TN0001643
TN0001643
TN0001643
TN0001643
TN0001643
TN0001643
TN0001643
TN0001643
TN0001643
TN0001643
TN0001643
TN0001643
TN0002356
TN0002356
TN0002356
TN0002356
Discharge
Pipe
(DSCH)
01A
01B
01C
001
01A
01B
Til
T12
TB1
TB2
001
005
01A
01T
S07
SOS
S09
S10
Sll
S12
S13
S14
S16
S17
S18
S19
001
003
004
005
EPA Designated
Pipe Usage a
DOS
BP
BP
FE
DOS
BP
DOS
DOS
DOS
DOS
FE
DOS
BP
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
FE
DOS
DOS
DOS
Evidence b
1
1
1
1
3
1
o
6
o
6
o
6
o
6
i
i
i
2
2
2
2
2
2
2
2
2
2
2
2
2
1
1
1
1
Pipe or Outfall Description
TREATED SANITARY EFFLUENT
Bleach Plant
Bleach Plant
RAW TRE,POW GEN,PUL/PAP, ST
WA
NONCONTACT COOLING WATER
Internal monitoring point, effluent from
bleach plant only
ANNUAL BIOMONITORING
STORMWATER RUNOFF
STORMWATER RUNOFF
STORMWATER RUNOFF
STORMWATER RUNOFF
STORMWATER RUNOFF
STORMWATER RUNOFF
STORMWATER RUNOFF
STORM WATER RUNOFF
STORMWATER RUNOFF
STORM WATER RUNOFF
STORMWATER RUNOFF
STORMWATER RUNOFF
RAIN RUNOFF-COAL STORAGE
AREA
UNCONTAMINATED COOLING
WATER
TRAV SCRE FILT BKW/PUMP COOL
W
TRAV SCRE FILT BW/PUMP COOL
WA
A-15
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
TN0002356
TN0002356
TN0002356
TN0002356
TN0002356
TX0000167
TX0000167
TX0000167
TX0000167
TX0001643
TX0001643
TX0001643
TX0003891
TX0003891
TX0003891
TX0003891
TX0003891
TX0003891
TX0003891
TX0003891
TX0052591
TX0052591
TX0052591
TX0052591
TX0052591
TX0052591
TX0052591
TX0053023
TX0053023
TX0053023
TX0053023
TX0053023
Discharge
Pipe
(DSCH)
006
01A
01B
01T
02A
001
101
102
103
001
002
TX1
001
002
01A
101
102
201
TX1
TXA
001
01A
01B
SLD
SLL
SLS
TX1
001
002
003
004
SLD
EPA Designated
Pipe Usage a
DOS
BP
BP
DOS
BP
FE
DOS
DOS
DOS
FE
DOS
DOS
FE
DOS
FE
BP
DOS
BP
DOS
DOS
FE
DOS
DOS
DOS
DOS
DOS
DOS
FE
DOS
DOS
DOS
DOS
Evidence b
1
1
1
2
2
1
1
o
J
3
2
2
2
2
2
2
1
1
1
2
2
2
2
2
2
2
2
2
2
2
2
2
2
Pipe or Outfall Description
COAL PILE RUNOFF, STORMWATER
PROCESS WW
PROCESS WW
BI-ANNUAL BIOMONITORING
INTERN MONIT PT, TREA DOMES
WW
TREATED PROCESS WASTEWATER
TREATED PROCESS WASTEWATER
at the aeration pond
YEARLY REPORTING - OUTFALL 102
YEARLY REPORTING - OUTFALL 103
TREATED PROCESS WASTEWATER
STORMWATER RUNOFF
TOXICITY REPORTING FOR 001
PROCESS DISCHARGE
STORMWATER RUNOFF
PROCESS WASTEWATER - 01A
Bleach plant No. 4
FILTER BACKWASH
Bleach plant No. 5
48-HOUR ACUTE FRESHWATER -001
24-HOUR ACUTE FRESHWATER - 001
TOTAL TREATED EFFLUENT
OUTFALL
QUARTERLY REPORTING FOR 00 IB
ANNUAL REPORTING
LANDFILL
LAND APPLICATION
SURFACE DISPOSAL
TOXICITY REPORTING FOR 00 IB
TOTAL REGULATED DISCHARGE
STORMWATER - 002
STORMWATER - 003
STORMWATER - 004
QUARTERLY REPORTING - SLUDGE
A-16
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
TX0053023
TX0053023
VA0003115
VA0003115
VA0003115
VA0003115
VA0003115
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0003646
VA0004162
VA0004162
VA0004162
VA0004162
WA000012
WA000012
Discharge
Pipe
(DSCH)
TX1
TXA
001
005
008
101
102
001
002
003
004
005
006
007
008
009
010
Oil
012
013
014
015
301
302
303
401
999
001
101
102
103
001
003
EPA Designated
Pipe Usage a
DOS
DOS
FE
DOS
DOS
BP
BP
DOS
DOS
FE
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
BP
BP
BP
DOS
DOS
FE
BP
BP
BP
FE
DOS
Evidence b
2
2
3
3
3
o
J
o
J
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Pipe or Outfall Description
TOXICITY REPORTING FOR 001
SEMI-ANNUAL 24HR ACUTE TOX-
001
internal outfall on A unit bleach line
internal outfall on B unit bleach line
internal outfall on C unit bleach line
Final Effluent
"D" Bleach Plant Effluent
"E" Bleach Plant Effluent
"F" Bleach Plant Effluent
COMBINED OUTFALL 001/002
Stormwater
A-17
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
WA000012
WA000025
WA000025
WA000025
WA000062
WA0000621
WA0000621
WA0000621
WA0000850
WA0001091
WA0003697
WI0003212
WI0003212
WI0003212
WI0003212
WI0003379
WI0003379
WI0003379
WI0003379
WI0003620
WI0003620
WI0003620
WI0003620
WI0003620
WI0003620
WI0003620
WI0003620
WI0003620
WI0003620
WI0003620
Discharge
Pipe
(DSCH)
005
001
002
OOS
001
003
008
OOF
001
009
001
001
005
006
009
002
003
004
104
001
002
003
005
006
007
008
009
Oil
013
099
EPA Designated
Pipe Usage a
OOS
FE
OOS
OOS
FE
OOS
OOS
OOS
FE
FE
FE
FE
OOS
OOS
OOS
OOS
OOS
FE
OOS
OOS
FE
OOS
OOS
OOS
OOS
OOS
OOS
OOS
OOS
OOS
Evidence b
2
1
1
1
3
1
1
1
1
1
1
1
1
1
1
1
1
1
o
J
1
1
2
2
2
2
2
2
2
2
2
Pipe or Outfall Description
SANITARY SEWAGE TREATMENT
PLNT
PULP MILL & STP DISCHARGE
DISCHARGE TO BLUE CREEK
SEWAGE PACKAGE PLANT
PAPER FROM PURCHASED PULP
COMMENCEMENT BAY DISCHARGE
TOTAL PLANT DISCHARGE
PULP & PAPER MILL DISCHARGE
TREATED PROCESS
WASTEWATER
EVAPORATORWATERS
006A VACUUM PUMP SEAL
006B NONCONTACTCOOL
WATER
OUTFALL 002 DISPOSAL WELL
OUTFALL 003 BARRIER WELL
TREATED PROCESS
WASTEWATER
REPORT 004AAS 104
CLO2 LIFT STA EMERG. OVERFLOW
WWTP EFFLUENT
PE#8 PAPERMACH CLEARWTR
SEWER
NEPCO LAKEALUM SLDG SETTLE
BSN
NEKOOSA CLEARWATERSEWER
PE BLEACH PLT EMERG OVERFLOW
NEK COLL. TANK EMER. OVERFLOW
PECOLL. TANK EMER.OVERFLOW
NEKOOSA STNDPIPE OVERFLOW
PIPE 099 RENUMBERED AS 013
COMBINED DISCH FROM1,2,7,8,9
A-18
-------
PCS Discharge Locations and EPA Designated Pipe Usage
MID
NPDES
WI0026042
WI0026042
WI0026042
WI0026042
WI0026042
WI0026042
WI0026042
WI0026042
WI0030651
WI0030651
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
WI0037991
Discharge
Pipe
(DSCH)
010
Oil
012
013
014
015
098
110
001
701
001
010
Oil
012
013
014
015
016
017
018
019
020
021
022
098
111
201
211
EPA Designated
Pipe Usage a
FE
DOS
DOS
DOS
DOS
DOS
DOS
DOS
FE
DOS
FE
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
DOS
Evidence b
1
1
1
1
1
1
1
1
2
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Pipe or Outfall Description
WWTP EFFLUENT
EMERGENCY PULP MILL
OVERFLOW
EMERGENCY PAPER
MILLOVERFLOW
WOODROOM SEWER
PIPE 098 RENUMBERED 014
NCCW
010, Oil, 012 & 013 COMBINED
ZID MONITORING
PLANT EFFLUENT
INFLUENT TO PLANT
WATER QUALITY CENTER
NONCONTACT COOLING WATER
BIRON DIV.STORMWATER
BIRON DIV.SEAL WATER
BIRON DIV NCCW
BIRON DIV EMERGENCY OUTFALL
WIS RAPIDSSEAL WATERNCWW
WIS RPD DIV EMERGENCY
OUTFALL
WIS RAPIDSINFILT. NCCWWIRP
CRANBERRY CREEK OUTFALL
WIS
RAPIDSSTORMWATERSEAL WATER
WR PULP MILLS OVERFLOW
KRAFT DIV NCCW
PIPE 098 RENAMED 022
001,014,016,201 COMBINED
BIRON DIV NCCW
KRAFT DIV PUMP STN EMRGNCY
0V
BIRON DIV NCCW EFFL
a - EPA has designated pipes and outfalls as either Final Effluent (FE), Bleach Plant (BP), Out of Scope (OOS). Out
of scope pipes include stormwater runoff, non-contact cooling water, emergency overflow, etc.
A-19
-------
PCS Discharge Locations and EPA Designated Pipe Usage
b - EPA used permits and PIPE descriptions contained in the PCS database to designate location. If these two
resources provided insufficient information the pollutant discharged was used as indicator. For example, the Cluster
Rules require final effluent AOX monitoring, absent additional information the presence of AOX indicates FE. The
data source is indicated with either: 1 - permit, 2- PCS pipe description, or 3- pollutant as an indicator.
A-20
-------
Appendix B
CURRENT STATUS OF PHASE I MILLS
-------
Appendix B
Current Status of Phase I Mills
The attached table lists mills that EPA identified as Phase I mills (mills with at
least some portion of their wastewater discharges that met the applicability of 40 CFR 430
Subpart B (Bleached Papergrade Kraft and Soda) and Subpart E (Papergrade Sulfite) as of April
15, 1998, when the Cluster Rules were promulgated. The table includes the following:
• Mill Name (updated to the 2005 ownership).
City.
State.
Phase I Subcategory which EPA believes applies to at least a portion of
mill discharges. Phase I subcategories include bleached papergrade kraft
and soda (BPK) and papergrade sulfite (PS).
Discharge status of the mill, either discharge directly to surface waters
(i.e., direct dischargers) or to a POTWs (indirect dischargers).
• SIC code included in PCS. If the mill is not included in PCS (for instance,
if it is an indirect discharge mill) there is no SIC code. The pulp, paper,
and paperboard industry corresponds to three separate Standard Industrial
Classification (SIC) codes: 2611 (pulp mills), 2621 (paper mills excluding
building paper mills), and 2631 (paperboard) which identify the facilities
principal product or group of products For a given mill, the SIC code in
PCS may differ from the primary SIC code identified in TRI.
NPDES permit number, for direct discharges.
TRI ID number.
• SID - The site identification number given to the mill for EPA's 1990
industry-wide survey.
Comment - about the current operating status of the mill.
EPA requests operators of the mills listed in Appendix B confirm current
mill operating status.
B-l
-------
Current Status of Phase I Mills
Mill Name
Container Corp. of America
Parsons & Whittemore
(Alabama River Pulp Co.
Inc.)
(Parsons & Whittemore)
Alabama Pine Pulp
Kimberly-Clark Corp
Champion International
Corp.
Gulf States Paper Corp.
Boise Cascade Corp.
James River Corp. (Naheola
Mill)
International Paper Co.
(Riverdale)
Domtar
Georgia-Pacific Corp.
Potlatch
International Paper
Co . (Hammermill)
Evergreen Pulp Co.
Champion International
Corp.
Georgia-Pacific Corp.
Stone Container Corp.
Federal Paper Board Co.
Koch Cellulose LLC
Weyerhaeuser/Flint River
Mill
Stone Container (Savannah
River)
Potlatch
City
Brewton
Claiborne
(Perdue Hill)
Claiborne
(Perdue Hill)
Coosa Pines
Courtland
Demopolis
Jackson
Pennington
Selma
Ashdown
Crossett
McGehee
Pine Bluff
Samoa
Cantonment
(Pensacola)
Palatka
Panama City
Augusta
Brunswick
Oglethorpe
Pt. Wentworth
Lewiston
State
AL
AL
AL
AL
AL
AL
AL
AL
AL
AR
AR
AR
AR
CA
FL
FL
FL
GA
GA
GA
GA
ID
Phase I
Sub-
category *
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
Dis-
charge *
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
I
D
D
D
D
D
SIC Code
2611
2621
2611
2621
2631
2621
2631
2611
2611
2621
2631
2611
2611
2621
2621
2611
2611
2611
2611
2611
2621
NPDES
AL0002682
AL0025968
AL0003158
AL0000396
AL0002828
AL0002755
AL0003301
AL0003018
AR0002968
AR0001210
AR0035823
AR0001970
CA0005894
FL0002526
FL0002763
FLR05B551
GA0002801
GA0003654
GA0049336
GA0002798
ID0001163
TRIID
36426-CNTNR-HIGHW
36470-LBMRV-OFFHI
35044-SPLPN-ALABA
35618-CHMPN-POBOX
36732-GLFST-HIGHW
36545-BSCSC-307WE
36916-JMSRV-ROUTE
3670 1-HMMRM-RIVER
71822-NKSPP-HIGHW
71635-GRGPC-PAPER
7 1 654-PTLTC-HIGHW
71611-NTRNT-FAIRF
95564-LSNPC-LPDRI
32533-CHMPN-375MU
32078-GRGPC-STATE
32401-STNCN-1EVER
30913-FDRLP-HIGHW
31520-BRNSW-WEST9
3 1068-BCKYC-OLDST
31407-STNCN-1BONN
83501-PTLTC-805MI
SID11
9177
7901
5298
697
8040
9233
1895
6515
2899
4771
9700
335
2910
5540
1513
7805
3771
310
3611
3114
9982
2216
Comment
Shares NPDES and TRI with BPK
- SID:5298
Shares NPDES and TRI with BPK
- SID:7901
Phase II mil in close proximity
(NPDES:AR0001601; Mid-
America Packaging)
TCF Mill (uses peroxide
bleaching); operates on the edge of
profitability; recently bought by
Chinese company.
indirect; not in PCSLoads2002
(POTW=FL0002631; Bay County
Wastewater Treatment Plant)
minor; not in PCSLoads2002;
Project XL participant
-------
Current Status of Phase I Mills (Continued)
Mill Name
Willamette Industries Inc.
New Page
International Paper Co.
Boise Cascade Corp.
Tembec
Georgia-Pacific Corp.
New Page
International Paper Co.
(And'scogn)
S.D. Warren (SAPPI)
Lincoln Pulp & Paper Co.
Georgia-Pacific
New Page
Domtar Industries Inc.
New Page
SAPPI Fine Paper NA
Champion International
Corp.
SAPPI
Boise Cascade Corp.
Weyerhaeuser Paper Co.
Koch Cellulose LLC
Weyerhaeuser Paper Co.
City
Hawesville
Wickliffe
Bastrop
Deridder
St. Francisville
Zachary (Port
Hudson)
Luke
Jay
Hinckley
(Skowhegan)
Lincoln
Old Town
Rumford
Woodland
(Baileyville)
Escanaba
Muskegon
Quinnesec
(Norway)
Cloquet
International
Falls
Columbus
New Augusta
New Bern
(Vanceboro)
State
KY
KY
LA
LA
LA
LA
MD
ME
ME
ME
ME
ME
ME
MI
MI
MI
MN
MN
MS
MS
NC
Phase I
Sub-
category "
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
Dis-
charge *
D
D
D
D
D
D
I
D
D
D
D
D
D
D
I
D
I
D
D
D
D
SIC Code
2611
2621
2611
2621
2611
2621
2621
2621
2621
2611
2621
2621
2411
2611
2621
2611
2611
2611
2621
2611
2611
NPDES
KY0001716
KY0000086
LA0007561
LA0007927
LA0003468
LA0005258
MD0001422
ME0001937
ME0021521
ME0002003
ME0002020
ME0002054
ME0001872
MI0000027
MI0001210
MI0042170
MN0001431
MN0001643
MS0036412
MS0031704
NC0003191
TRIID
42348-WLLMT-POBOX
42087-WSTVC-HIGHW
71220-NTRNT-705CO
70634-BSSTH-USHIG
70775-JMSRV-ENDOF
7079 1 -GRGPC-ZACHA
21540-WSTVC-300PR
04239-NTRNT-RILEY
04976-SDWRR-RFD3U
04457-LNCLN-KATAH
04468- JMSRV-PORTL
04276-BSCSC-ROUTE
04694-GRGPC-MILLA
49829-MDPBL-COUNT
49443-SDWRR-2400L
49876-CHMPN-USHIG
55720-PTLTC-NORTH
56649-BSCSC-SECON
39703-CLMBS-CARSO
39462-LFRVR-HWY29
28560- WYRHS-STREE
SID"
8897
6360
1907
9747
5677
181
9926
6139
832
7254
9195
4084
2374
1492
5844
3042
2212
1052
8662
8525
5657
Comment
Recycled cbrd mill closed
according to AF&PA, Oct 2002.
Pulp and paper mill still open
indirect; PCSLoads2002 contains
TSS, oil & grease, and Aluminum
(POTW=MD0021687; Upper
Potomac River Commission)
indirect; PCSLoads2002 contains
Chlorine (POTW=MI0027391;
Muskegon County Wastewater
Management System)
indirect; not in PCSLoads2002
(POTW=MN0049786; Western
Lake Superior Sanitary District)
-------
Current Status of Phase I Mills (Continued)
Mill Name
Federal Paper Board Co.
Blue Ridge Paper
Weyerhaeuser Paper Co.
James River Corp. (Crown
Paper Co.)
Finch Pruyn & Co Inc.
International Paper Co.
New Page
Georgia-Pacific
Georgia-Pacific
Boise Cascade Corp.
Willamette (Penntech Papers
Div.)
Appleton Papers Inc.
P. H. Glatfelter Co.
Bo water Inc.
Union Camp Corp.
International Paper Co.
Willamette Industries Inc.
Willamette Industries Inc.
Bo water Inc.
International Paper Co.
Temple Inland Forest
Products
Westvaco Corp.
Union Camp Corp.
Smurfit-Stone
Weyerhaeuser Paper Co.
Boise Cascade Corp.
Georgia-Pacific
Scott Paper
City
Riegelwood
Canton
Plymouth
Berlin
Glens Falls
Ticonderoga
Chillicothe
Clatskanie
Halsey
St. Helens
Johnsonburg
Roaring
Spring
Catawba
Eastover
Georgetown
Bennetsville
Kingsport
Calhoun
Texarkana
(Queen City)
Evadale
(Silsbee)
Covington
Franklin
West Point
Longview
Wallula
Camas
Everett
State
NC
NC
NC
NH
NY
NY
OH
OR
OR
OR
PA
PA
PA
SC
SC
SC
SC
TN
TN
TX
TX
VA
VA
VA
WA
WA
WA
WA
Phase I
Sub-
category "
BPK
BPK
BPK
BPK
PS
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
BPK
PS
Dis-
charge *
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
D
SIC Code
2631
2621
2621
2611
2611
2611
2621
2611
2611
2611
2621
2611
2621
2611
2621
2631
2621
2621
2621
2621
2631
2631
2611
2611
2611
2611
2611
2611
NPDES
NC0003298
NC0000272
NC0000680
NH0000655
NY0005525
NY0004413
OH0004481
OR0000795
OR0001074
OR0020834
PA0002143
PA0008265
PA0008869
SC0001015
SC0038121
SC0000868
SC0042188
TN0001643
TN0002356
TX0000167
TX0003891
VA0003646
VA0004162
VA0003115
WA0000124
WA0003697
WA0000256
WA0000621
TRIID
28456-FDRLP-RIEGE
28716-CHMPN-MAINS
27962-WYRHS-TROWB
03570-JMSRV-650MA
12801-FNCHP-1GLEN
12883-NTRNT-SHORE
45601-MDCRP-401SP
970 1 6- JMSRV- WAUNA
97348-PPTLB-30480
97051-BSCSC-1300K
15845-PNNTC-100CE
16673-PPLTN-100PA
17362-PHGLT-228SO
29704-BWTRC-5300C
29044-NNCMP-ROUTE
29442-NTRNT-KAMIN
29512-WLLMT-HWY91
37662-MDPPR-POBOX
37309-BWTRS-ROUTE
75504-NTRNT-POBOX
77656-PLPPP-POBOX
24426-WSTVC-RIVER
23851-NNCMP-HIGHW
23181-CHSPK-19THM
98632-WYRHS-3401I
99363-BSCSC-POBOX
98607-JMSRV-NE4TH
98201-SCTTP-2600F
SID"
2608
4572
8544
1688
1277
5123
4696
2818
1811
644
4491
5701
4920
2449
1421
7647
1908
1146
9523
8135
2647
4318
6412
5187
8668
732
324
5124
Comment
PS-B; Ammonium
Shares NPDES with POTW
VATIP-Tier 1
VATIP-Tier 1; PCS dioxin detect
in 2002 confirmed by mill
(83.6pg/L)
VATIP-Tier 1
VATIP-Permit does not indicated
Tier
PS-B; Ammonium based
-------
Current Status of Phase I Mills (Continued)
Mill Name
Simpson Tacoma Kraft Co.
Wausau Paper Mills Co.
SmartPapers LLC
Stora Enso
Weyerhaeuser Paper Co.
Domtar Industries Inc.
Domtar Industries Inc.
International Paper Co.
Scott Paper Co./SAPPI
Simpson Paper Co.
St. Joe Forest Products Co.
Oilman Paper Co.
Great Northern Paper Co.
SAPPI Fine Paper NA
International Paper Co.
Stone Container Corp.
Procter & Gamble Paper
International Paper Co.
Champion International
Corp.
City
Tacoma
Brokaw
Park Falls
Wisconsin
Rapids
Rothschild
Nekoosa
Port
Mobile
Mobile
Anderson
Port St. Joe
St. Marys
Millinocket
Westbrook
Moss Point
Missoula
Mehoopany
Erie
Houston
(Sheldon)
State
WA
WI
WI
WI
WI
WI
WI
AL
AL
CA
FL
GA
ME
ME
MS
MT
PA
PA
TX
Phase I
Sub-
category "
BPK
PS
PS
BPK
PS
BPK
PS
BPK
BPK
BPK
BPK
BPK
PS
BPK
BPK
BPK
PS
BPK
BPK
Dis-
charge *
D
D
D
D
D
D
D
D
D
D
I
D
D
D
I
D
D
I
D
SIC Code
2611
2611
2621
2611
2621
2611
2621
2621
2621
2611
2621
2621
2621
2611
2621
2611
2621
NPDES
WA0000850
WI0003379
WI0003212
WI0037991
WI0026042
WI0003620
AL0002780
AL0002801
FLR10K742
GA0001953
ME0000167
ME0002321
MS0002674
MT0000035
PA0008885
PA0000124
TX0053023
TRIID
98421-SMPSN-801PO
54417-WSPPR-2NDST
54552-FLMBP-200NO
54494-CNSLD-950FO
54474- WYRHS-200GR
54457-NKSML-MARKE
54469-PRTDW-100WI
36652-SCTTP-BAYBR
31558-GLMNP-10000
04462-GRTNR-1KATA
04092-SDWRR-89CUM
59806-STNCN-MULLA
1 8629-PRCTR-ROUTE
16533-HMMRM-1540E
77044-CHMPN-11611
SID"
3720
7080
23
7850
4139
4468
7163
6354
4774
8657
3820
8850
6841
130
7115
3218
7401
3982
4545
Comment
PS-A; Magnesium-based bisulfite
process
PS-A; Calcium based
In 2002, mill submitted 3 separate
TRI release reports (pulp mill,
paper mill, and water quality
center)
PS-A; Calcium based
Shares NPDES with PS -
SID:7163
PS-A; Shares NPDES with BPK -
SID:4468
idle in '02; PCSLoads2002
contains dioxin, TSS, iron, etc.
idle after '02; PCSLoads2002
contains BODS, oil & grease, TSS,
etc
idle in '02
idle in '02; not in PCSLoads2002
idle after '02; PSCLoads2002
contains dioxin, BODS, and TSS.
According to AF&PA, closed
October 2002.
phase II
phase II
idle in '02; PCSLoads2002
contains BODS, TSS, dissolved
oxygen
phase II
phase II
phase II (POTW=PA0026301;
Erie City/Erie Sew Auth).
According to AF&PA closed June
2002.
idle after '02; PCSLoads2002
contains AOX, COD, dioxin, etc.
-------
Current Status of Phase I Mills (Continued)
Mill Name
Champion International Corp
Simpson Paper Co.
James River II Inc
Georgia-Pacific Corp.
Badger Paper Mills Inc.
City
Lufkin
Pasadena
Camas
Bellingham
Peshtigo
State
TX
TX
WA
WA
WI
Phase I
Sub-
category "
BPK
BPK
PS
PS
PS
Dis-
charge *
D
I
D
D
I
SIC Code
2621
2621
2611
NPDES
TX0001643
WA0001091
TRIID
75902-CHMPN-HIGHW
77506-PSDNP-901NS
98225-GRGPC-300WL
SID"
4079
2816
324
4005
3764
Comment
idle after '02; PCSLoads2002
contains AOX, dioxin, TSS, etc.
According to AF&PA idled
indefinitely Oct. 2003
phase II (POTW=TX0005380;
Gulf Coast Waste Disposal Auth)
idle in '02; Factsheet (issued 4-3-
03) excerpt: August 27, 2001, the
Camas Mill announced the
permanent closure of the sulfite
pulp mill and four paper machines
idle after '02; PCSLoads2002
contains TSS, mercury, BODS; (at
promulgation the only mill in the
specialty grade mills segment)
phase II (POTW=WI0030651;
Peshtigo City WWTF)
a - Phase I subcategories include bleached papergrade kraft (BPK) and papergrade sulfite (PS) pulping operations.
** b - Mill either discharge directly to surface waters (i.e., direct dischargers) or to a POTWs (indirect dischargers).
"^ c - The pulp, paper, and paperboard industry corresponds to three separate Standard Industrial Classification (SIC) codes: 2611 (pulp mills), 2621 (paper mills excluding building
paper mills), and 2631 (paperboard) which identify the facilities principal product or group of products. Table lists the SIC code listed in PCS. For a given facility, the SIC code in
PCS may differ from the primary SIC code identified in TRI.
d - EPA performed an industry-wide survey in 1990. Each mill was given a survey identification number (SID).
------- |