United States Office of Water EPA-821-B-00-003
Environmental Protection (4303) May 2000
Agency
&EPA
Permit Guidance Document
Pulp, Paper and Paperboard Manufacturing
Point Source Category
(40 CFR §430)
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1 Introduction 1-1
2 Overview of NPDES Program and National Pretreatment Program 2-1
What is the NPDES Permit Program? 2-1
What are Effluent Limitations Guidelines? 2-1
What are Water-Quality-Based Effluent Limitations (WQBELs)? . 2-1
What is the National Pretreatment Program? 2-2
What are National Pretreatment Standards? 2-2
Applicability of Effluent Limitations Guidelines and Standards 2-2
3 Overview of 40 CFR §430 3-1
What is the New Subcategorization Scheme? 3-1
4 What are the New Pollutants Regulated by the Rule? 4-1
5 What are the Regulatory Bases for Effluent Limitations Guidelines and
Standards for Subparts B and E? 5-1
What are the Model Process Technologies and Treatment Systems? 5-1
Subpart B - Bleached Papergrade and Kraft and Soda Mills 5-1
Subpart E - Papergrade Sulfite Mills 5-2
6 Where Are Mills Required to Demonstrate Compliance? 6-1
Direct Dischargers 6-1
Indirect Dischargers 6-2
7 What are the Effluent Limitations Guidelines and Standards for Subparts
BandE? 7-1
Direct Dischargers 7-1
BAT and BPT/BCT 7-1
Subpart B - Bleached Papergrade Kraft and Soda 7-1
Subpart E - Papergrade Sulfite 7-7
NSPS 7-8
Subpart B - Bleached Papergrade Kraft and Soda Subcategory . . . 7-9
Subpart E - Papergrade Sulfite 7-9
Indirect Dischargers 7-9
PSES and PSNS 7-9
Subpart B - Bleached Papergrade Kraft and Soda 7-10
Subpart E - Papergrade Sulfite 7-10
8 How Do I Develop Permits for Mills with Operations in Subparts
BandE? 8-1
Pre-Application Activities 8-2
Reviewing Permit Applications 8-3
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Developing Permit Limits 8-4
What are the Two Types of ELG&S? 8-4
How Do I Use Production Information to Develop Permit Limits? 8-5
What Production Definition Must Be Used to Calculate AOX and
Chloroform Limits? 8-5
What Production Definition Must Be Used to Calculate Conventional
Pollutant Limits? 8-6
How Do I Calculate the Production Rate? 8-7
How Do I Determine Whether the Mill is Subject to the Specialty-
Grade Segment of Subpart E? 8-12
Should the Permit Include Limits Based on ELGs or WQBELs? . 8-12
Developing Monitoring Requirements 8-14
What are the Monitoring Locations? 8-15
What are the Monitoring Frequencies? 8-17
During What Bleaching Conditions Should Mills Collect
Samples? 8-18
Should Mills be Required to Measure Bleach Plant Flows? 8-19
What are Appropriate Sample Collection Methods? 8-20
What are the Appropriate Analytical Methods? 8-22
What is the Minimum Level of Detection? 8-23
What are Reporting and Recordkeeping Requirements? 8-25
When May Mills Certify to use of Certain Processes in Lieu of
Monitoring? 8-25
Developing Compliance Schedule 8-26
When Must Existing Mills Comply With Cluster Rules? 8-26
What if Existing Direct Dischargers Cannot Meet Cluster Rules
Immediately? 8-26
What are Typical Implementation Periods for Subpart B Model
Process Technologies? 8-27
Compliance Schedule Examples 8-31
When Must New Sources Comply with the Cluster Rules? 8-32
How Do Compliance Schedules for Air and Water Regulations for
Pulp and Paper Mills Overlap? 8-32
Developing Special Conditions 8-34
Extending Standard Conditions for Bleach Plant Permit Limits 8-36
9 Best Management Practices Requirements 9-1
What are BMPs? 9-1
How Do I Incorporate BMPs into Permits? 9-2
BMP Plan 9-2
What Are the Implementation Requirements for BMPs? 9-4
What is Tank Integrity Testing? 9-5
What Are the BMP Monitoring Requirements? 9-6
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Monitoring of Tanks, Sumps, and Sewers as Elements of BMPs . . 9-6
Monitoring of BMP Effectiveness 9-6
What Are the BMPs Compliance Deadlines? 9-8
10 How are Permits Established for Mills that Decide to Enter the Voluntary
Advanced Technology Incentives Program? 10-1
What Are the VATIP ELG&S? 10-1
What are the Extended Compliance Dates? 10-2
Must I Require the Mill to Submit a Milestones Plan? 10-3
Scope of the Milestones Plan 10-3
How Do I Establish Permit Limits That Reflect the VATIP Schedule? . . 10-3
Initial Limitations (Stage 1) 10-4
Intermediate Milestones 10-6
Ultimate Limitations (Stage 2) 10-6
What are the Reduced Monitoring Requirements? 10-7
How Does VATIP Enrollment Affect MACT Compliance Schedule? . . 10-8
11 Case Studies 11-1
Case Study #1 11-2
General Site Description 11-2
Relevant Information for Establishing Permit Limits 11-2
Determining Permit Limits for Pollutants Regulated Under BPT . 11-4
Determining Permit Limits for Pollutants Regulated Under BAT . 11-5
Final Permit Limits for Softwood Paper 11-7
Case Study #2 11-9
General Site Description 11-9
Relevant Information for Establishing Permit Limits 11-9
Determining Permit Limits for Pollutants Regulated Under BPT . 11-9
Determining Permit Limits for Pollutants Regulated Under BAT 11-11
Final Permit Limits for White Bright Paper Company 11-11
Case Study #3 11-13
General Site Description 11-13
Relevant Information for Establishing Permit Limits 11-13
Determining Permit Limits for Pollutants Regulated Under BPT 11-15
Determining Permit Limits for Pollutants Regulated Under BAT 11-16
Final Permit Limits for Acme Paper 11-18
Case Study #4 11-20
General Site Description 11-20
Relevant Information for Establishing Permit Limits 11-20
Determining Permit Limits for Pollutants Regulated Under BPT 11-21
Determining Permit Limits for Pollutants Regulated Under BAT 11 -23
Final Permit Limits for Pulpco Corporation 11-25
ill
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Case Study #5 11-27
General Site Description 11-27
Relevant Information for Establishing Permit Limits 11-27
Determining Permit Limits for Pollutants Regulated Under BPT 11-30
Determining Permit Limits for Pollutants Regulated Under BAT 11-30
Final Permit Limits for United Papers Corporation 11-32
Case Study #6 11-34
General Site Description 11-34
Relevant Information for Establishing Permit Limits 11-34
Determining Permit Limits for Conventional Pollutants Regulated
Under BPT and NSPS 11-35
Determining Permit Limits for Pollutants Regulated Under BAT 11-37
Final Permit Limits for PaperTech Corporation 11-39
Case Study #7 11-42
General Site Description 11-42
Relevant Information for Establishing Pretreatment Limits .... 11-42
Determining Permit Limits for Toxic and Nonconventional Pollutants
Regulated Under PSES 11-42
Final Pretreatment Limits for Commerce Pulp 11-45
Case Study #8 11-47
General Site Description 11-47
Permitting Information 11-47
Establishing Stage 1 Permit Limits 11-48
Intermediate Milestones 11-56
Milestones Plan 11-56
Stage 2 Permit Limits 11-56
Case Study #9 11-59
General Site Description 11-59
Relevant Information for Establishing Permit Limits 11-59
Determining Permit Limits for Pollutants Regulated Under BPT 11 -60
Determining Permit Limits for Pollutants Regulated Under BAT 11 -62
Final Permit Limits for Sunburst Paper 11-63
12 Where to Get Additional Help 12-1
Information Relating to the Pulp and Paper Rule 12-1
Documents Supporting the 1998 Promulgated Rule 12-2
Documents Relating to Implementation/Enforcement of the 1998
Promulgated Rule 12-4
General Information About Permits and NPDES Program 12-4
General Information About Pulp and Paper 12-4
Databases 12-5
Websites 12-6
IV
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Other Sources and Contacts 12-6
EPA Headquarters Information Resource Center 12-6
National Technical Information Service (NTIS) 12-7
EPA Regional Contact 12-7
A Subpart B and E Mills A-l
Appendix B Sample Collection Methods B-l
€ BMP NPDES Permit Language C-l
Appendix D Glossary D-l
Appendix E Existing Effluent Quality (EEQ) Calculation Procedures E-l
Appendix F Bleach Plant Flow Measurements F-l
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1 Subpart B BAT Effluent Limitations Guidelines xii
2 Subpart B BPT Effluent Limitations Guidelines xiii
3 Subpart B PSES Effluent Limitations Guidelines xiv
4 BAT Effluent Limitations Guidelines for Subpart E Ammonium-Based
and Specialty-Grade Sulfite Pulp Segments xv
5 BAT Effluent Limitations Guidelines for Calcium-, Magnesium-, or
Sodium-Based Sulfite Segments xv
6 Subpart E BPT Effluent Limitations Guidelines xvi
7 PSES Effluent Limitations Guidelines for Subpart E Ammonium-Based
and Specialty-Grade Sulfite Pulp Segments xvii
8 PSES Effluent Limitations Guidelines for Calcium-, Magnesium-, or
Sodium-Based Sulfite Segments xvii
9 Subpart B New Source Performance Standards xiii
10 Subpart B Pretreatment Standards for New Sources xix
11 Subpart E New Source Performance Standards for Conventional
Pollutants xx
12 Pretreatment Standards for New Sources for Subpart E Ammonium-Based
and Specialty-Grade Sulfite Pulp Segments xx
13 Pretreatment Standards for New Sources for Calcium-, Magnesium-, or
Sodium-Based Sulfite Segments xxi
14 VATIP Effluent Limitations Guidelines and Standards xxi
2-1 Effluent Limitations Guidelines and Standards Applicable to Each
Program 2-3
3-1 Revised Subcategorization Scheme (with Previous Subparts Noted) 3-2
4-1 Pollutants Regulated Under 40 CFR 430 4-1
5-1 BAT and NSPS Technology Bases for Papergrade Sulfite Subcategory .. 5-3
VI
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6-1 Compliance Points for Each Regulated Pollutant 6-2
7-1 SubpartB BAT Effluent Limitations Guidelines 7-11
7-2 Subpart B BPT Effluent Limitations Guidelines 7-12
7-3 BAT Effluent Limitations Guidelines for Subpart E Ammonium-Based
and Specialty-Grade Sulfite Pulp Segments 7-13
7-4 BAT Effluent Limitations Guidelines for Calcium-, Magnesium-, or
Sodium-Based Sulfite Segments 7-13
7-5 Subpart E BPT Effluent Limitations Guidelines 7-14
7-6 Subpart B New Source Performance Standards 7-15
7-7 Subpart E New Source Performance Standards for Conventional
Pollutants 7-16
7-8 Subpart B Pretreatment Standards for AOX 7-16
8-1 Concentration- or Mass-Based ELG&S 8-5
8-2 Typical Bleaching Shrinkage Factors 8-6
8-3 Common Production Measures in the Pulp and Paper Industry 8-7
8-4 Minimum Monitoring Frequencies for Mills with Operations in Subparts
BandE 8-17
8-5 Recommended Bleach Plant Effluent Sampling Collection Methods .... 8-22
8-6 Analytical Methods 8-23
8-7 Model Process Technologies that Typically Need Significant
Implementation Time 8-30
9-1 Annual Tank Testing Frequency 9-6
9-2 BMP Compliance Deadlines Schedule for Existing Direct and Indirect
Dischargers 9-8
VII
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9-3 BMP Compliance Deadlines Schedule for New Sources 9-9
10-1 VATIP Effluent Limitations Guidelines and Standards 10-2
10-2 Minimum Monitoring Frequencies for Chlorinated Compounds and AOX
for Fiber Lines Enrolled in VATIP 10-7
11-1 Summary of Case Studies 11-2
11-2 NPDES Permit Limits, Softwood Paper Corporation 11-8
11-3 Permit Limits for White Bright Paper Company 11-12
11-4 Permit Limits for Acme Paper Company 11-19
11-5 Permit Limits for Pulpco Corporation 11-26
11-6 Permit Limits for United Papers Corporation 11-33
11-7 Permit Limits forPaperTech Corporation 11-40
11-8 Permit Limits for Commerce Pulp Company 11-46
11-9 Stage 1 Permit Limits, Great American Paper 11-54
11-10 Stage 2 Permit Limits, Great American 11-57
11-11 Permit Limits for Sunburst Paper 11-63
A-l Bleached Papergrade Kraft Mills A-l
A-2 Papergrade Sulfite Mills A-4
E-l Number of Samples for Each Pollutant E-3
E-2 Variability Factors for AOX, Chloroform, and TCDF E-6
VIM
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7-1 Applicability of Subpart B ELG&S 7-2
7-2 Applicability of Subpart B ELG&S 7-3
7-3 Applicability of Subpart E Standards 7-4
7-4 Applicability of Subpart E Standards 7-5
7-5 Diagram of Subpart E BPT Segments 7-6
8-1 Papergrade Sulfite Facility Segment Identification 8-13
8-2 Sampling Locations for Various Acid and Alkaline Sewer Stream
Configurations 8-16
10-1 Permit Process for Direct Discharges During Each Phase of VATIP .... 10-5
12-1 Information Resources Map 12-2
IX
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Disclaimer
This guidance is designed to help implement national policy on effluent limitations guidelines and
standards for the pulp, paper, and paperboard industry. This document does not, however, substitute
for the CWA or EPA's regulations, nor is it a regulation itself. Thus, it cannot impose legally binding
requirements on EPA, states, or the regulated community and may not apply to a particular situation
based upon these circumstances. EPA and state decisionmakers retain the discretion to adopt
approaches on a case-by-case basis that differ from this guidance where appropriate. EPA may change
this guidance in the future.
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_^ -." . n April 15, 1998, the U.S. Environmental Protection Agency (EPA) promulgated revised
• : ' ', regulations for the pulp, paper, and paperboard category to control both effluent discharges
• _^ _ and air emissions. The promulgation of the revised regulations marks the completion of the
T'"" ,
" ~- first of three phases of the Cluster Rules. As part of Phase I, EPA established effluent
limitations guidelines and standards under 40 CFR Part 430 for the following two subcategories:
Subpart B - Bleached Papergrade Kraft and Soda; and
Subpart E - Papergrade Sulfite.
At the time of publication of this guidance manual, EPA is continuing with Phases II and III to establish
revised effluent limitations and standards for the remaining subparts. Over the next several years, EPA
plans to complete these phases and will update 40 CFR Part 430 after the completion of each phase.
The purpose of this guidance document is to help you, the permit writer, develop appropriate National
Pollutant Discharge Elimination System (NPDES) permits and pretreatment requirements for mills with
operations in Subparts B and E. The material presented is intended solely for guidance and does not alter
any statutory requirements. For an overview of the NPDES and National Pretreatment Programs, you may
refer to Section 2 of this document or to the U.S. EPA NPDES Permit Writer's Manual (EPA-833-B-96-
003) for more detailed information.
The tables below summarize the April 15, 1998 promulgated regulations for Subparts B and E.
XI
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Table 1: Subpart B BAT Effluent Limitations Guidelines
Pollutant
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
AOX
COD
BAT(c),(d)
Continuous Dischargers
1-Day Maximum
(kg/kkg)
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Table 2; Subpart B BPT Effluent Limitations Guidelines
Pollutant
BPT Limitations (b)
Continuous Dischargers
1-Day Maximum
Average of Daily Values for
30 Consecutive Days
Non-Continuous
Dischargers
Annual Average
Point of Compliance
Bleached Kraft Mills Producing Market Pulp Segment
BOD5
TSS
pH
15.45 kg/kkg
30.4 kg/kkg
(a)
8.05 kg/kkg
16.4 kg/kkg
(a)
4.52
9.01
(a)
Final Effluent
Final Effluent
Final Effluent
Bleached Kraft Mills Producing Paperboard, Coarse Paper, and Tissue Paper Segment
BOD5
TSS
pH
13.65 kg/kkg
24 kg/kkg
(a)
7.1 kg/kkg
12.9 kg/kkg
(a)
3.99
7.09
(a)
Final Effluent
Final Effluent
Final Effluent
Bleached Kraft Mills Producing Pulp and Fine Paper Segment
BOD5
TSS
pH
10.6 kg/kkg
22. 15 kg/kkg
(a)
5.5 kg/kkg
11. 9 kg/kkg
(a)
3.09
6.54
(a)
Final Effluent
Final Effluent
Final Effluent
Soda Mills Producing Pulp and Paper Segment
BOD5
TSS
pH
13.7 kg/kkg
24.5 kg/kkg
(a)
7.1 kg/kkg
13.2 kg/kkg
(a)
3.99
7.25
(a)
Final Effluent
Final Effluent
Final Effluent
(a) Within the range of 5.0 to 9.0 at all times.
(b) See 40 CFR 430.22(b), (c), and (d) for additional limitations that apply to mills that use wet wood yard operations.
XIII
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Table 3; Subpart B PSES Effluent Limitations Guidelines
Pollutant
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
AOX
BAT(c),(d)
Continuous Dischargers
1-Day Maximum
(kg/kkg)
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Ta:,
for
.:..':
Pollutant
TCDD(a)
TCDF(a)
Chloroform(a)
rrichlorosyringol(a)
?,4,5-Trichlorocatechol(a)
?,4,6-Trichlorocatechol(a)
?,4,5-Trichloroguaiacol(a)
?,4,6-Trichloroguaiacol(a)
\, 5,6-Trichloroguaiacol(a)
2,4,5-trichlorophenol(a)
2,4,6-trichlorophenol(a)
retrachlorocatechol(a)
retrachloroguaiacol(a)
2,3,4,6-Tetrachlorophenol(a)
5entachlorophenol(a)
AOX
COD
Continuous Dischargers
1-Day Maximum
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Table 6; Subpart E BPT Effluent Limitations Guidelines(l)
Segment
Papergrade Sulfite Mills Using Blow
Pit Washing Techniques (2)
Papergrade Sulfite Mills Using
Vacuum or Pressure Drums to Wash
Pulp (2)
Papergrade Sulfite Using Vacuum or
Pressure Drums to Wash Pulp (2)
Pollutant (a)
BPT Limitations in kg/kkg (or pounds per 1,000 Ibs) of product
Continuous dischargers
1 Day Maximum
Average of daily values for
30 consecutive days
Noncontinuous dischargers
Annual Average
Point of Compliance
Bisulfite liquor/surface condensers
BOD5
TSS
31.8
43.95
16.55
23.65
9.3
13
Final Effluent
Final Effluent
Bisulfite liquor/barometric condensers
BOD5
TSS
34.7
52.2
18.05
28.1
10.14
15.44
Final Effluent
Final Effluent
Acid sulfite liquor/surface condensers
BOD5
TSS
32.3
43.95
16.8
23.65
9.44
13
Final Effluent
Final Effluent
Acid sulfite liquor/barometric condensers
BOD5
TSS
35.55
52.2
18.5
28.1
10.39
15.44
Final Effluent
Final Effluent
Bisulfite liquor/surface condensers)
BOD5
TSS
26.7
43.95
13.9
23.65
7.81
13
Final Effluent
Final Effluent
Bisulfite liquor/barometric condensers
BOD5
TSS
29.4
52.2
15.3
28.1
8.6
15.44
Final Effluent
Final Effluent
Acid sulfite liquor/surface condensers
BOD5
TSS
29.75
43.95
15.5
23.65
8.71
13
Final Effluent
Final Effluent
Acid sulfite liquor/barometric condensers
BOD5
TSS
32.5
52.2
16.9
28.1
9.49
15.44
Final Effluent
Final Effluent
Continuous digester
BOD5
TSS
38.15
53.75
19.85
28.95
11.15
15.91
Final Effluent
Final Effluent
(1) See 40 CFR 430.52(b), (c), and (d) for additional limitations that apply to mills that use wet woodyard operations.
(2) Each segment includes pH limitations guidelines within the range of 5.0 to 9.0 at all times.
XVI
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7; for
Pollutant
TCDD(a)
TCDF(a)
Trichlorosyringol(a)
3,4,5-Trichlorocatechol(a)
3,4,6-Trichlorocatechol(a)
3,4,5-Trichloroguaiacol(a)
3,4,6-Trichloroguaiacol(a)
4, 5,6-Trichloroguaiacol(a)
2,4,5-trichlorophenol(a)
2,4,6-trichlorophenol(a)
Tetrachlorocatechol(a)
Tetrachloroguaiacol(a)
2,3,4,6-Tetrachlorophenol(a)
pentachlorophenol(a)
Continuous Dischargers
1-Day Maximum
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Table 9; Subpart B New Source Performance Standards (c), (d)
Pollutant
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
AOX
BOD5
TSS
pH
COD
Bleach Plant Effluent
Continuous Dischargers
1-Day Maximum
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Table 10: Subpart B Pretreatment Standards for New Sources (c), (d)
Pollutant
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
AOX
BOD5
TSS
pH
COD
Bleach Plant Effluent
Continuous Dischargers
1-Day Maximum
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11; E for • -
Pollutant
Parameter
BOD5
TSS
pH
Final Effluent
Kg/kkg (or pounds per 1,000 Ibs) of Product
Continuous Dischargers
1 Day Maximum
4.38exp(0.017x)
5.81exp(0.017x)
(a)
Average of Daily Values for
30 Consecutive Days
2.36exp(0.017x)
3.03exp(0.017x)
(a)
Noncontinuous Dischargers
Annual Average
Average of daily values for 30
consecutive days divided by
1.91
Average of daily values for 30
consecutive days divided by
1.90
(a)
x - Percent sulfite pulp in final product.
(a) Within range of 5 to 9.
12; for for
.
Pollutant
TCDD(a)
TCDF(a)
Trichlorosyringol(a)
3,4,5-Trichlorocatechol(a)
3,4,6-Trichlorocatechol(a)
3,4,5-Trichloroguaiacol(a)
3,4,6-Trichloroguaiacol(a)
4, 5,6-Trichloroguaiacol(a)
2,4,5-trichlorophenol(a)
2,4,6-trichlorophenol(a)
Tetrachlorocatechol(a)
Tetrachloroguaiacol(a)
2,3,4,6-Tetrachlorophenol(a)
pentachlorophenol(a)
Continuous Dischargers
1-Day Maximum
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1 1 •: i i ,
or
Pollutant
AOX
Final Effluent in kg/kkg (or pounds per 1,000 Ibs) of Product
Continuous Dischargers
1-Day Maximum
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n April 15, 1998, the U.S. Environmental Protection Agency (EPA) promulgated final effluent limitations
guidelines and standards under 40 CFR 430 of the Clean Water Act (CWA) for the following two subcategories of
the pulp, paper, and paperboard industry:
Subpart B Bleached Papergrade Kraft and Soda
Subpart E Papergrade Sulfite.
Mills with operations in these subparts are required to comply with the regulation by April 15, 1999, or at the time their
permit is reissued, whichever is later. Permit writers and control authorities are required to issue permits and pretreatment
agreements to ensure that affected mills are complying with the new regulations. This document is specifically written to
provide guidance to permitting and pretreatment control authorities in issuing NPDES permits and pretreatment
agreements to pulp and paper mills which fall within the purview of these two subparts. Therefore, the "you"
throughout this document is addressed to permit writers and control authorities, as appropriate.
You, as a permitting or pretreatment control authority, will need to determine which mills fall under 40 CFR Part 430 and
how to write the permits/pretreatment agreements for these mills to ensure their compliance under the new regulations. To
help you in this process, EPA has addressed the following topics:
» Section 2 presents a brief overview of the National Pollutant Discharge Elimination System (NPDES)
Program and the National Pretreatment Program;
" Section 3 presents an overview of the promulgated subcategorization of the Pulp, Paper, and Paperboard
Category (40 CFR 430);
• Section 4 discusses the pollutants regulated under 40 CFR 430 for mills with operations in Subparts B and
E;
" Section 5 discusses the technology bases for the effluent limitations guidelines and standards promulgated
for mills with operations in Subparts B and E;
• Section 6 discusses the in-process and end-of-pipe points where affected mills must demonstrate
compliance with the rule;
PULP5\0408-01.RR
1-1
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• Section 7 presents the effluent limitations guidelines and standards promulgated for mills with operations in
Subparts B and E;
• Section 8 walks through the process of establishing permit limits for mills with operations in Subparts B
andE;
• Section 9 discusses the requirements for establishing Best Management Practices (BMPs) permit
requirements;
• Section 10 discusses the permit requirements for mills enrolling in the Voluntary Advanced Technologies
Incentives Program (VATIP);
• Section 11 presents nine case studies as examples of establishing permits for mills with operations in
Subparts B and E; and
• Section 12 contains a list of resources for additional guidance in establishing permits for affected mills.
This guidance manual also has a number of appendices that contain additional information that may be useful to you in your
permitting responsibilities. Please refer to the table of contents at the beginning of this document for more information on
appendix contents.
EPA is hopeful that this manual provides guidance on issuing permits and pretreatment agreements to mills with operations in
these two subparts in an easy-to-read format. While this manual attempts to address as many permitting issues and situations
that may be covered by the regulation, there are other sources that you may wish to consult in issuing permits/pretreatment
agreements for mills with operations in Subparts B and E. Therefore, the manual identifies and references other sources
throughout the text that you can access to get additional guidance. We have also included in Section 12 a list of these and
other sources and how to order them, as well as a list of EPA and other authorities to contact for more guidance.
PULP5\0408-01.RR
1 • Introduction 1 -2
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"his section presents a brief overview of the NPDES Permit Program and the National Pretreatment Program. For
more background information regarding EPA's programs to develop national standards for point source categories,
refer to the U.S. EPA NPDES Permit Writer's Manual (EPA-833-B-96-003).
Section 301 (a) of the CWA prohibits the discharge of pollutants except in compliance with CWA Section 402, among other
sections. Section 402 authorizes the issuance of NPDES permits for direct dischargers (i.e., existing or new industrial
facilities that discharge process wastewaters from any point source into receiving waters). You must develop NPDES permits
to control these discharges, using effluent limitations guidelines and water-quality based effluent limitations.
EPA establishes ELGs to require a minimum level of process control and treatment for industrial point sources. They are
based on the demonstrated performance of model process and treatment technologies that are within the economic means of
an industrial category. Although ELGs are based on the performance of model process and treatment technologies, EPA does
not mandate the use of specific technologies; therefore, dischargers are free to use any available control technique to meet the
limitations.
All receiving waters have ambient water quality standards that are established by the states or EPA to maintain and protect
designated uses of the receiving water (e.g., aquatic life-warm water habitat, public water supply, primary contact recreation).
Some of you may find that the application of the ELGs result in pollutant discharges that exceed the water quality standards in
particular receiving waters. In such cases, you are required by the CWA and federal guidelines to develop more stringent
WQBELs for the pollutant to ensure that the water quality standards are met. States can use the total maximum daily load
(TMDL) process as one way of quantifying the allowable pollutant loadings in receiving waters, based on the relationship
between pollution sources and in-stream water quality standards.
Because EPA and state permitting authorities are familiar with their respective water quality standards and knowledgeable in
waste load allocations and other procedures to maintain water quality standards, these issues are not addressed in this
document. To learn more about how TMDLs are developed, you should refer to Guidance for Water-Quality-Based
Decisions: The TMDL Process (EPA 440/4-91-001). To leam how to apply water quality standards in NPDES permits, refer
to the Technical Support Document for Water Quality-Based Toxics Control (EPA/505/2-90-001).
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is the
Section 402(b)(8) of the CWA requires that permits for certain publicly owned treatment works (POTWs) (i.e., those
receiving pollutants from significant industrial sources subject to pretreatment standards under CWA Section 307(b)) must
establish a pretreatment program to ensure compliance with these standards. EPA has published regulations to define the
requirements of this POTW pretreatment control program.
are
Section 403.5(a)(l) generally prohibits users of a POTW (indirect dischargers) from discharging pollutants to the POTW that
cause pass-through or interference. Therefore, POTWs that receive wastewater from indirect dischargers subject to
categorical pretreatment standards must develop and enforce local limits to comply with the National Pretreatment Standards.
Pass-through is defined as a discharge that exits the POTW into waters of the United States in quantities or concentrations
that, alone or in conjunction with a discharge or discharges from other sources, causes a violation of any requirement of the
POTW's NPDES permit. Interference is defined as a discharge that, alone or in conjunction with a discharge or discharges
from other sources, both: (1) inhibits or disrupts the POTW, its treatment processes, or its operations; or its sludge processes,
use, or disposal; and (2) causes the POTW to violate any requirement of its NPDES permit, or prevents sewage sludge use or
disposal (40 CFR §403.3).
Of
Mills that discharge waters to receiving streams or POTWs are required to meet one (or more) of the following ELG&S (as
well as BMPs) established by the CWA.
Guideline or Standard for the control of:
toxic and conventional pollutants at an
existing direct discharger
conventional pollutants at an existing direct
discharger
toxic and nonconventional pollutants at an
existing direct discharger
conventional, toxic, and nonconventional
pollutants at a new source, direct discharger
toxic and nonconventional pollutants at an
existing indirect discharger
toxic and nonconventional pollutants at a
new source, indirect discharger
losses and spills from process equipment
Is:
best practicable control technology
currently available
best conventional pollutant control
technology
best available technology economically
achievable
new source performance standards
pretreatment standards for existing sources
pretreatment standards for new sources
best management practices
Acronym
BPT
BCT
BAT
NSPS
PSES
PSNS
BMP
With the April 15, 1998 promulgation of the regulation, EPA has established new BAT, NSPS, PSES, PSNS, and BMPs in
addition to the BPT, BCT, BAT, NSPS, PSES, and PSNS already established for the pulp, paper, and paperboard category.
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Note that although this document focuses on these new ELG&S and BMPs, all previous ELG&S remain in effect.
Table 2-1 summarizes the applicability of these ELG&S.
Table 2-1: Effluent Limitations Guidelines and Standards Applicable to Each Program
Program
NPDES Permit
Program
National
Pretreatment
Program
Type of
Discharger
Direct
Discharger
Indirect
Discharger
Existing or New
Source?
Existing Source
New Source
Existing Source
New Source
Applicable ELG&S
Previously Established
BCT
BPT
BAT
NSPS
PSES
PSNS
Additional ELG&S
(from 4/15/98 Rule)
BAT
BMP
NSPS
BMP
PSES
BMP
PSNS
BMP
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Hhe pulp, paper, and paperboard category was reorganized by the promulgated rule (April 15, 1998). As part of the
reorganization of the category, EPA revised the subcategorization scheme. This section presents the new
subcategorization scheme that EPA adopted, explains how it is different from the previous subcategorization
scheme, and, most importantly, describes how to determine the subcategories applicable to each mill. Appendix A
lists the mills that are subject to ELG&S under the reorganized Subparts B and E.
In the original rule, EPA established 26 subcategories defined by the products manufactured at a mill. In the revised rule,
EPA reorganized these 26 subcategories into 12 subcategories by grouping mills with similar processes. EPA only
promulgated additional ELG&S for reorganized Subparts B and E. Table 3-1 presents the final subparts and how they relate
to the previous subcategories.
As Table 3-1 shows, under the new subcategorization scheme, Subpart B is comprised of four segments which used to be
Subparts G, H, I, and P under the previous subcategorization scheme. Subpart E includes former Subparts U and J, and has
been reorganized into three segments (calcium-, magnesium-, and sodium-based; ammonium-based; and specialty-grade
segments).
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Final Codified
Subpart
A
B(a)
C
D
Ew
F
G
H
I
Revised Subcategorization Scheme
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Digester
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
« Calcium-, Magnesium-, and
Sodium-based Segment
« Ammonium-based Segment
« Specialty grade
Semi-Chemical
Mechanical Pulp
Non-Wood Chemical Pulp
Secondary Fiber Deink
Previous Subcategorization Scheme
(With Previous Subparts Noted)
Dissolving Kraft (F)
Market Bleach Kraft (G)
Bleached Kraft (H) - including paperboard, coarse
paper, and tissue.
Fine Bleached Kraft (I)
Soda (P)
Unbleached Kraft (A)
« Linerboard Segment
« Bag and Other Products Segment
Dissolving Sulfite (K)
« Nitration Segment
« Viscose Segment
« Cellophane Segment
« Acetate Segment
Papergrade Sulfite - Drum Wash (U)
< '. Bisulfite liquor/surface Condensers Segment
< '. Bisulfite liquor/barometric Condensers Segment
< '. Acid sulfite/surface Condensers Segment
< '. Acid sulfite/barometric Condensers Segment
c Continuous Digester Segment
Papergrade Sulfite - Blow Pit Wash ( J)
i : Bisulfite liquor/surface Condensers Segment
i : Bisulfite/barometric Condensers Segment
i : Acid/surface Condensers Segment
i : Acid/barometric Condensers Segment
Semi-Chemical (B)
i : Ammonia Segment
i : Sodium Segment
Groundwood-Thermo-Mechanical (M),
Groundwood-Coarse, Molded, News (N)
Groundwood-Fine Papers (O)
Groundwood-Chemi-Mechanical (L)
Miscellaneous mills not covered by a specific subpart
Deink Secondary Fiber (Q)
« Fine Papers
« Tissue Papers
« Newsprint J Secondary Fiber Non-Deink Tissue from
Wastepaper (T)
Paperboard from Wastepaper (E)
i : Corrugating medium
i : Non-Corrugating Medium
Wastepaper-Molded Products (W)
Builders' Paper and Roofing Felt (40 CFR Part 431 Subpart
A)
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Final Codified
Subpart
K
L
Revised Subcategorization Scheme
Fine and Lightweight
Papers from Purchased Pulp
Tissue, Filter, Non- Woven, and
Paperboard from Purchased Pulp
Previous Subcategorization Scheme
(With Previous Subparts Noted)
Nonintegrated Fine Papers (R)
• Wood Fiber Furnish
• Cotton Fiber Furnish
Nonintegrated Lightweight Papers (X)
• Lightweight Papers
• Lightweight Electrical PapersL Tissue, Filter, Non-
Woven, and Paperboard from Purchased Pulp
Nonintegrated
• Tissue Papers(S)
• Filter and Non- Woven (Y)
• Paperboard (Z)
Nonintegrated
• Tissue Papers (S)
• Filter and Non- Woven (Y)
• Paperboard (Z)
(a) EPA has promulgated ELG&S for Subparts B and E. EPA intends to revise ELG&S as appropriate for
the remaining subparts over the next few years.
To issue or reissue permits or pretreatment agreements, you must be aware not only of the
reorganization of the subcategories covered under 40 CFR 430, but also which ELG&S apply to
mills in the pulp and paper category. Mills with operations in Subparts B and E are subject to
not only the ELG&S promulgated on April 15,1998, but previously established guidelines
and standards for this category as well. Below are a few examples showing the ELG&S that
apply to mills with operations covered by Subparts B and E.
ixample 1 : Mill A is an existing direct discharger which falls under Subpart B. The mill
produces market pulp and tissue. The mill is subject to which effluent guidelines and
standards?
Answer: As a existing direct discharger, Mill A is subject to BMP and to revised BAT, as well
as previously established BAT and BPT for the Market Bleached Kraft Segment (former
Subpart G) and the Bleached Kraft (including paperboard, coarse paper, and tissue) Segment
(former Subpart H).
Subpart
Subpart B -
Bleached
Papergrade
Kraft and Soda
Discharge Status
Direct Discharger
Mill Subject to Previously
Established ELG&S
BPT and BAT for Market
Bleached Kraft Segment
(former Subpart G)
BPT and BAT for Bleached
Kraft Segment (former Subpart
H)
Also Subject to
Following under
15, 1998 ELG<
BAT
BMP
the
Lpril
S
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]
]
]
]
Example 2: Mill B is an existing indirect discharger that falls under Subpart B. The mill
sroduces market pulp and fine paper. The mill is subject to which effluent guidelines and
standards?
Answer: As an existing indirect discharger, Mill B is subject to BMP and to revised PSES. In
addition, because Mill B falls under two segments for the previously established PSES, you
nust apply PSES for the Market Bleached Kraft Segment (former Subpart G) and the Fine
Bleached Kraft Segment (former Subpart I).
Subpart
Subpart B -
Bleached
Papergrade
Kraft and Soda
Direct or Indirect
Discharger
Indirect Discharger
Mill Subject to Previously
Established ELG&S
PSES for Market Bleached
Kraft Segment (former Subpart
G)
PSES for Fine Bleached Kraft
Segment (former Subpart I)
Also Subject to
Following under
15, 1998 ELGi
PSES
BMP
the
Lpril
S
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In the April 15, 1998 rule, EPA established ELG&S for toxic and nonconventional pollutants that
are characteristic of Subpart B and E mills that bleach pulp with chlorine-containing compounds.
Table 4-1 shows which pollutants are regulated for mills with operations in Subpart B and E. Each
of these pollutants is discussed below.
' ,le 4-1; ' • • 40 430
Pollutants
Chloroform (a)
2,3,7,8-TCDF
2,3,7,8-TCDD
12 Chlorinated Phenolic
Compounds
AOX (a)
COD
Subpart B
/
/
/
/
/
Reserved
Subpart E
NH4-Based
Segment
Reserved
/
/
/
Reserved
Reserved
Na-,Ca-, Mg-
Based Segment
No requirement
No requirement
No requirement
No requirement
/
Reserved
Specialty-Grade
Segment
Reserved
/
/
/
Reserved
Reserved
Chloroform. Chloroform is an extremely volatile compound that is generated during the
bleaching of pulp with hypochlorite, chlorine, or chlorine dioxide. Hypochlorite bleaching results
in the greatest amount of chloroform generation while chlorine dioxide bleaching results in the
least amount of chloroform generation. As chloroform is generated, it partitions to air and to
bleach plant effluent (though, some of the chloroform remains with the pulp). Any chloroform
found in bleach plant effluent that is not emitted to the air prior to reaching the wastewater
treatment plant is volatilized and degraded during secondary treatment.
2,3,7,8-TCDD (Dioxin) and 2,3,7,8-TCDF (Furan). The dioxin congener consists of two
benzene rings connected by two oxygen bridges. There are eight positions where substitution of
hydrogen atoms by other atoms or by organic or inorganic radicals can occur. 2,3,7,8-TCDD is
one of 75 dioxin congeners and is the most toxic. The chlorinated dibenzofurans have similar
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structure, but have only one oxygen bridge rather than two. 2,3,7,8-TCDF is the most toxic of 135
chlorinated dibenzofurans.
During the late 1980s, bleaching with chlorine and hypochlorite were discovered to be sources of
dioxin and furan. Although use of chlorine dioxide (C1O2) bleaching minimizes the formation of
chlorinated pollutants, measurable quantities of 2,3,7,8-TCDF and possibly 2,3,7,8-TCDD may
still be formed. Dioxin and furan are not effectively degraded during wastewater treatment; they
partition either to sludge or pass into receiving waters untreated.
Chlorinated Phenolic Compounds. Chlorinated phenolic compounds include phenols, guaiacols,
catechols, and vanillins substituted with from one to five chlorine atoms per molecule. Typically,
bleaching processes that result in the formation of 2,3,7,8-TCDD and 2,3,7,8-TCDF also generate
the higher substituted tri-, tetra-, and penta-chlorinated compounds. EPA established effluent
limitations guidelines and pretreatment standards for the following 12 chlorinated phenolic
compounds:
• 4-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
• Pentachlorophenol
Secondary treatment can generally achieve about 50% removal of these compounds.
Adsorbable Organic Halides (AOX). AOX is a measure of the total amount of halogens
(chlorine, bromine, and iodine) bound to dissolved or suspended organic matter in a wastewater
sample. In the effluent of Subpart B and E mills, essentially all of the AOX is chlorinated
compounds formed during bleaching with chlorine and other chlorinated bleaching agents.
Inefficient application of chlorine-containing bleaching chemicals can generate increased levels of
AOX. Minimizing AOX will usually have the effect of reducing the generation of chloroform,
2,3,7,8-TCDD, 2,3,7,8-TCDF, and chlorinated phenolic compounds. Some AOX is biodegraded
during secondary treatment.
Chemical Oxygen Demand (COD). COD is a measure of the quantity of chemically oxidizable
material present in wastewater. Sources of COD include the pulping area, recovery area, bleaching
area, and papermaking area. A portion of COD is readily biodegradable while the rest is resistant
to biodegradation (i.e., "refractory"). The refractory portion is derived from spent pulping liquor
(i.e., kraft mill "black liquor" or sulfite mill "red liquor"), thus, COD biodegradability indicates the
degree to which spent pulping liquor is recovered from brown stock pulp. Wastewater COD loads
also correlate with discharges of toxic organic pollutants that are not readily biodegraded. (Note:
EPA has not established COD ELG&S; however, EPA plans to do so in a future rulemaking.).
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PA established numerical ELGs and pretreatment standards for Subparts B and E based
on model process technologies and wastewater treatment technologies. Although you
must apply the ELGs in the NPDES permit or pretreatment control agreement, mills with
operations in Subpart B and E are not required to implement the specific process and/or
technologies upon which they are based. Mill owners and operators may use any combination of
process technologies and in-process or end-of-pipe wastewater treatment technologies to comply
with the permit limits.
This section outlines the model technologies that form the regulatory bases of the ELG&S
presented in Section 4. This discussion is broken out by subpart.
For direct dischargers, the model technology basis of BAT for the Bleached Papergrade Kraft and
Soda Subcategory is conventional pulping followed by complete substitution of chlorine dioxide
for elemental chlorine, as well as the nine elements identified below:
1. Adequate chip thickness control;
2. Closed brown stock pulp screen room operation (i.e., screening filtrates are
returned to the recovery cycle);
3. Effective brown stock washing (i.e., washing that achieves a soda loss of less
than or equal to 10 kg Na2SO4 per air dried metric ton (ADMT) of pulp
(equivalent to 99% recovery of pulping chemicals from the pulp);
4. Use of TCDD- and T CDF-precursor-free defoamers (water-based defoamers or
defoamers made with precursor-free oils);
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5. Elimination of hypochlorite (i.e., replacing hypochlorite with equivalent
bleaching power, such as adding peroxide and/or oxygen to the first extraction
stage and/or additional chlorine dioxide in final brightening stages);
6. Use of strategies to minimize kappa factor and TCDD- and TCDF-precursors in
brown stock pulp;
7. High-shear mixing to ensure adequate mixing of pulp and bleaching chemicals;
8. Oxygen and peroxide enhanced extraction, which allows mills to eliminate
hypochlorite and/or use a lower kappa factor in the first bleaching stage; and
9. Efficient biological wastewater treatment, removing 90% or more of influent
five-day biochemical oxygen demand (BOD5).
The technology basis of NSPS is equivalent to that of BAT with the addition of extended
delignification (oxygen delignification and/or extended cooking). For the purpose of estimating
effluent pollutant reductions, EPA defines extended delignification as the operation of such
equipment to a kappa number of 20 or less for softwoods and less than 13 for hardwoods.
For indirect dischargers, the technology bases of PSES and PSNS are equivalent to that of BAT
and NSPS technologies, respectively, except without efficient biological wastewater treatment.
POTWs are expected to perform efficient biological wastewater treatment.
Subpart E - Papergrade Sulfite Mills
As discussed in Section 3, EPA reorganized Subpart E for BAT, PSES, NSPS, and PSNS into the
following three segments:
• Calcium-, magnesium-, or sodium-based sulfite segment: Papergrade sulfite
mills where pulp and paper are produced using calcium, magnesium, or sodium
sulfite acidic cooking liquors, unless those mills are specialty-grade sulfite mills.
• Ammonium-based sulfite segment: Papergrade sulfite mills where pulp and
paper are produced using an ammonium sulfite acidic liquor, unless those mills
are specialty-grade sulfite mills.
• Specialty-grade sulfite segment: Papergrade sulfite mills that produce at least
25% pulp with a high percentage of alpha cellulose and high enough brightness
to produce end products such as plastic molding compounds, saturating and
laminating products, and photographic papers. The specialty-grade segment also
includes mills that produce most of their pulp at 91 ISO brightness and above.
For each papergrade sulfite segment, BAT and NSPS are equivalent. Table 5-1 presents the
technology bases for BAT and NSPS for each segment of the Papergrade Sulfite Subcategory.
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s
„ for
Technology Basis for:
Calcium-, Magnesium-,
and Sodium-Based Segment is:
1 . Totally chlorine -free bleaching (bleaching
with peroxide);
2. Use of TCDD- and TCDF -precursor-free
defoamers (water-based defoamers or
defoamers made with precursor-free oils);
3. Oxygen and peroxide enhanced extraction;
4. Improved pulp cleaning; and
5. Efficient biological wastewater treatment.
Ammonium Sulfite Segment is:
1 . Complete substitution of chlorine dioxide
for chlorine;
2. For mills with ECF bleaching, elimination of
hypochlorite (i.e., replacing hypochlorite
with equivalent bleaching power, such as
adding peroxide to the first extraction stage
and/or additional chlorine dioxide in final
brightening stages);
3. Use of TCDD- and TCDF -precursor-free
defoamers (water-based defoamers or
defoamers made with precursor-free oils);
4. Peroxide enhanced extraction;
5. High-shear mixing; and
6. Efficient biological wastewater treatment.
Specialty-Grade Sulfite Segment is:
1 . Complete substitution of chlorine dioxide
for chlorine;
2. For mills with ECF bleaching, elimination of
hypochlorite (i.e., replacing hypochlorite
with equivalent bleaching power, such as
adding peroxide and/or oxygen to the first
extraction stage and/or additional chlorine
dioxide in final brightening stages);
3. Use of TCDD- and TCDF -precursor-free
defoamers (water-based defoamers or
defoamers made with precursor-free oils);
4. Oxygen and peroxide enhanced extraction;
5. High-shear mixing; and
6. Efficient biological wastewater treatment.
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The technology bases of PSES and PSNS for each segment include all the model BAT and NSPS
technologies except for efficient biological wastewater treatment, because POTWs are expected to
perform efficient biological wastewater treatment.
For a complete description of each technology element, refer to the Supplemental Technical
Development Document for the Pulp, Paper, and Paperboard Category Effluent Limitations
Guidelines and Standards, and New Source Performance Standards (EPA-82 l-R-97-011,
October 1997, www.epa.gov/ost/pupppaper/jd/stdd-v4.pdf).
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/ly his section discusses EPA's determination of points at which mills with operations in
Subparts B and E must show compliance with the rule. The regulation requires mills to
demonstrate compliance with limitations at the point where wastewater leaves the bleach
plant, as well as at the point where they discharge their treated effluent to the receiving
stream (for direct dischargers). The following subsections discuss the rationale for establishing the
bleach plant compliance point; for a more complete discussion of the legal basis for requiring
monitoring of in-process streams, refer to Section 8.2.3 of the Supplemental Technical
Development Document (EPA 821-R-97-011, October 1997
www.epa.gov/OST/pulppaper/id/stdd-v4.pdf).
Table 6-1 summarizes the compliance points for each pollutant regulated by the rule.
Note: Some mills operate several individual fiber
lines and associated bleach plants. As a result, these
mills must meet limits for pollutants with bleach plant
effluent limits for each individual fiber line bleaching
plant.
Under 40 CFR 430, a direct discharger must
demonstrate compliance with the limits for
TCDD, TCDF, 12 chlonnated phenolic
pollutants, and chloroform at the point where
the wastewater containing these pollutants
leaves the bleach plant from each individual
fiber line before being combined with process
wastewaters or noncontact cooling water from other operations. (EPA refers to these in-process
limits as "bleach plant effluent limits"). EPA determined that bleach plant effluent limits are
necessary for these pollutants because chemical pulp bleaching is the principal source of these
pollutants; the effluent from a mill's bleach plant is typically combined with other process
wastewater and noncontact cooling water prior to treatment and discharge. Because of this, you
would not be able to accurately assess compliance at the final mill effluent due to dilution with
other mill wastewaters. In addition, bleach plant limits for chloroform are necessary because there
is potential for volatilization and loss in mill sewer systems. For AOX, however, direct discharge
mills must comply with end-of-pipe limits at the point where the final mill process wastewater
effluent is discharged to receiving waters (i.e., at the end of the pipe).
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Indirect dischargers must also demonstrate compliance with bleach plant effluent limits for TCFF,
TCDF, 12 chlorinated phenolic pollutants, and, for mills with operations in Subpart B only,
chloroform. EPA also established bleach plant effluent limits for AOX, rather than final effluent
limits, because POTWs cannot achieve, through wastewater treatment alone, the degree of AOX
removal achieved by the in-process technologies that form the basis of BAT. For more discussion
on AOX bleach plant limits, refer to the Supplemental Technical Development Document.
Pollutant
TCDD
TCDF
Chloroform
12 chlorinated
phenolic
pollutants
AOX
COD
Subpart B
Bleach Plant
Bleach Plant
Bleach Plant
Bleach Plant
Final Effluent
(Directs)
Bleach Plant
Effluent
(Indirects)
Reserved
Subpart E
Ammonium-
Based Segment
Bleach Plant
Bleach Plant
Reserved
Bleach Plant
Reserved
Reserved
Calcium-,
Sodium-,
Magnesium-
Based Segment
No requirement
No requirement
No requirement
No requirement
Final Effluent
(Directs)
Bleach Plant
(Indirects)
Reserved
Specialty-Grade
Segment
Bleach Plant
Effluent
Bleach Plant
Effluent
Reserved
Bleach Plant
Effluent
Reserved
Reserved
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"his section discusses the numerical ELGs and standards that EPA has promulgated for mills
with operations in Subparts B and E. For a discussion of BMP regulations, which apply to
all mills with operations covered by Subparts B and E, see Chapter 9. Figures 7-1 through
7-4 summarize the rule for these subparts in four flowcharts:
Subpart B direct dischargers;
Subpart B indirect dischargers;
Subpart E direct dischargers; and
Subpart E indirect dischargers.
This subsection discusses the BAT and BPT/BCT ELGs promulgated for direct dischargers with
operations in Subparts B and E. As noted in Section 2, EPA did not revise BPT ELGs for
conventional pollutants. As a result, you must establish permit limits based on the revised BAT
ELGs and the BPT ELGs that were previously established.
40 CFR 430.24 establishes BAT effluent limitations guidelines for AOX, TCDD, TCDF,
chloroform, and 12 chlorinated phenolic pollutants. Mills are subject to the ELGs for the
chlorinated pollutants listed in Table 7-1 unless the mill certifies that they use a totally chlorine
free (TCP) bleaching process (see 40 CFR 430.24(a)(2)). Note that there are additional BAT
ELGs for mills that use chlorophenolic biocides (see 40 CFR 430.24(d)); however, many mills, if
not all, certify they do not use these compounds. (Refer to Section 10 for discussions of
developing permits for mills enrolling in VATIP.)
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Mill Performs Operations in Subpart B
Is the mill a direct discharger?
Direct Discharger
Existing Source
BPT (40 CFR 430.22)
If mill operations fall under
one or more of the following
four segments: Market Bleach
Kraft; Bleach Kraft-Including
Paperboard, Coarse Paper,
and Tissue; Fine Bleach Kraft;
and Soda, then subject to:
40 CFR 430.22(a)
If mill performs wet barking
operations in one or more of
four mentioned segments,
then subject to:
If mill performs log washing
or chip washing in one or more
of above mentioned segments,
then subject to:
If mill uses log flumes or
log ponds in one or more of
above mentioned segments,
then subject to:
40 CFR 430.22(b)
40 CFR 430.22(c)
40 CFR 430.22(d)
BAT (40 CFR 430.24)
If mill does not certify to use
TCF or enroll in VATIP,
then subject to:
If mill certifies use of TCF,
then, subject to:
If mill enrolls in VATIP,
then subject to:
(Note: mills may enroll in VATIP on a
line-by-line basis. Non-participating
fiberlines are subject to one of above)
If mill use chlorophenolic
biocides, then also subject to:
40CFR430.24(a)(1)
40 CFR 430.24(a)(2)
40 CFR 430.24(b)
40 CFR 430.24(d)
->• (See Figure 7-2)
New Source
1 BMPs
40 CFR 430.03
NSPS (40 CFR 430.25)
If mill was constructed
between June 15, 1988
and June 15, 1998, then
remains subject to:
If mill is constructed after
June 15, 1998, then subject
to:
If mill certifies use of TCF,
then subject to:
If mill uses chlorophenolic
biocides, then also subject to:
If mill enrolls in VATIP, then
subject to: (NOTE: mills may
enroll in VATIP on a line-by-
line basis)
40 CFR 430.25(a)
40 CFR 430.25(b)
40 CFR 430.25(b)(2)
40 CFR 430.25(d)
40 CFR 430.25(c)
Figure 7-1: Applicability of Subpart B ELG&S
7-2
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Mill Performs Operations in Subpart B
Is the mill an indirect discharger?
(See Figure 7-1)
Indirect Discharger
Existing Source
PSES (40 CFR430.26)
If mill does not certify using
TCP, then subject to:
If mill certifies use of TCP,
then subject to:
40CFR430.26(a)(1)
40 CFR 430.26(a)(2)
If mill uses chlorophenolic
biocides, then also subject to:
40 CFR 430.26(b)
T
New Source
BMPs 40 CFR 430.03
PSNS (40 CFR430.27)
If mill does not certify using
TCF, then subject to:
If mill certifies use of TCF,
then subject to:
40CFR430.27(a)(1)
40 CFR 430.27(a)(2)
If mill uses chlorophenolic
biocides, then also subject to:
40 CFR 430.27(b)
Figure 7-2: Applicability of Subpart B ELG&S
7-3
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Mill Performs Operations in Subpart E
Is the mill a direct discharger?
(See Figure 7-4)
Direct Discharger
Existing Source
BPT (40 CFR 430.50)
If mill operations fall under one or more
of the following nine segments:
Papergrade Sulfite - Drum Wash:
- Bisulfite Liquor/Surface Condenser Segment;
- Bisulfite Liquor/Barometric Condenser Segment;
- Acid Sulfite/Surface Segment;
- Acid Sulfite/Barometric Segment; and
- Continuous Digester Segment.
Papergrade Sulfite - Blow Pit:
- Bisulfite Liquor/Surface Condenser Segment;
- Bisulfite Liquor/Barometric Condenser Segment;
- Acid Sulfite/Surface Segment; and
- Acid Sulfite/Barometric Segment.
Then subject to:
40 CFR
430.50(a)
If mill uses wet barking
operations, then subject to:
If mill uses log washing
or chip washing operations,
then subject to:
If mill uses log flumes of
log ponds, then subject to:
40 CFR 430.52(b)
40 CFR 430.52(c)
40 CFR 430.52(d)
New Source
BMPs 40 CFR 430.03
BAT (40 CFR 430.54)
Mill operations fall under one
or more of the following
segments:
Calcium, magnesium, and
sodium-based segment
Ammonium-based segment
Specialty-grade segment
40 CFR 430.54(b)
40CFR430.54(a)(1)
40 CFR 430.54(a)(2)
40 CFR 430.54(a)(3)
NSPS (40 CFR 430.55)
NSPS for
conventional
pollutants
40 CFR
430.55(a)
NSPS for toxic and
nonconventional pollutants:
Calcium, magnesium, and
sodium-based segment
Ammonium-based segment
Speciality-grade segment
40 CFR 430.55(b)
40CFR430.55(b)(1)
40 CFR 430.55(b)(2)
40 CFR 430.55(b)(3)
If mill uses chlorophenolic
biocides, then also subject to:
40 CFR 430.54(b)
If mill uses chlorophenolic
biocides, then also subject to:
40CFR430.55(c)
Figure 7-3: Applicability of Subpart E Standards
7-4
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Mill Performs Operations in Subpart E
Is the mill an indirect discharger?
(See Figure 7-3)
I
Indirect Discharger
Existing Source
PSES (40 CFR 430.56)
If mill questions fall under
one or more of the
following three segments:
Calcium, Magnesium, and
Sodium-Based Segment
Ammonium-Based Segment;
Speciality Grade Segment
40CFR430.56(a)(1)
40 CFR 430.56(a)(2)
40 CFR 430.56(a)(3)
If mill uses chlorophenolic
biocides, then also subject to:
40 CFR 430.56(b)
New Source
BMPs
40 CFR 430.03
PSNS (40 CFR 430.57)
If mill questions fall under
one or more of the
following three segments:
Calcium, Magnesium, and
Sodium-Based Segment
Ammonium-Based Segment;
Speciality Grade Segment
40CFR430.57(a)(1)
40 CFR 430.57(a)(2)
40 CFR 430.57(a)(3)
If mill uses chlorophenolic
biocides, then also subject to:
40 CFR 430.57(b)
Figure 7-4: Applicability of Subpart E Standards
7-5
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Papergrade
Sulfite
Mills
Note: Currently, there are no mills that
perform blow pit washing.
Blow Pit Washing
Acid Sulfite
Surface Condenser
Barometric Condenser
Bisulfite
Vacuum or Drum
Washing
Acid Sulfite
Surface Condenser
Barometric Condenser
Surface Condenser
Barometric Condenser
Bisulfite
Surface Condenser
Barometric Condenser
Continuous Digester
Figure 7-5: Diagram of Subpart E BPT Segments
7-6
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BPT
40 CFR 430.22 establishes BPT ELGs for
BOD5, TSS, and pH. You must establish
Note: EPA plans to promulgate discharge limits for
. .. . . . . . COD in a future rulemaking. In the interim, COD
permit limits based on the products ,. . rV-^n-, • • ; 111 / i r>
Limits and COD monitoring should be based on Best
ProfessionalJudgement (BPJ).
manufactured (and pulping process in the
case of soda mills) at the mill. Mills may be
subject to BPT ELGs for one or more of the
following four segments:
1. Production of market pulp using a bleached kraft pulping process;
2. Integrated production of paperboard, coarse paper, and tissue paper from pulp
made using a bleached kraft pulping process;
3. Integrated production of fine paper from pulp made using a bleached kraft
pulping process; and
4. Production of market pulp and fine paper using a soda pulping processes.
Mills that perform wet woodyard operations are subject to additional BPT ELGs; however, few
mills, if any, continue to perform such operations (refer to 40 CFR 430.22(b), (c), and (d)).
':•'
EAT
40 CFR 430.54 establishes BAT effluent limitations guidelines for the three segments of Subpart E
(calcium-, magnesium-, and sodium-based, ammonium-based, and specialty-grade pulp). Tables 7-
3 and 7-4 list the ELGs for each pollutant regulated for the three segments. Note that there are
additional BAT ELGs for mills that use
chlorophenolic biocides (see 40 CFR 54(b));
however, many mills, if not all, certify they do forpoUutants that have reserved ELGs.
Note: BPJ should be used to establish permit limits
'i ail, ceruiy mey uo
not use these compounds.
BPT
40 CFR 430.52 establishes the BPT ELGs for BOD5, TSS, and pH. You must establish permit
limits based on mill process operations. Mills are subject to one of the following. The nine BPT
segments are defined as "papergrade sulfite mills where":
1. Blow pit washing techniques are used (bisulfite liquor/surface condensers);
2. Blow pit washing techniques are used (bisulfite liquor/barometric condensers);
3. Blow pit washing techniques are used (acidic liquor/surface condensers);
4. Blow pit washing techniques are used (acidic liquor/barometric condensers);
5. Vacuum or pressure drums are used to wash pulp (bisulfite liquor/surface
condensers);
7-7
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NSPS
6. Vacuum or pressure drums are used to wash pulp (bisulfite liquor/barometric
condensers);
7. Vacuum or pressure drums are used to wash pulp (acidic liquor/surface
condensers);
8. Vacuum or pressure drums are used to wash pulp (bisulfite liquor/barometric
condensers); and
9. Vacuum or pressure drums are used to wash pulp (continuous digester).
Figure 7-5 presents a diagram of the Subpart E BPT segments. Table 7-5 lists the BPT limitations
for each Subpart E segment. Mills that perform wet woodyard operations are subject to additional
BPT ELGs; however, few mills, if any, perform such operations (see 40 CFR 430.52(b), (c), and
(d)).
The NSPS promulgated under Subparts B and E apply to any mill subject to those subparts that is
a "new source" as defined in 40 CFR 430.01Q, such as any newly constructed direct discharger
(i.e., greenfield mill) that is located at a site where no other source is located, or an existing mill
that extensively modifies its fiber line(s), or constructs a new fiberline.
A/rii j-f.- tu • ru r M- Note: See 40 CFR 430.01 (i) for the definition of New
Mills modifying their fiber lines or adding new „ , ;
Source as it relates to Subparts B and h.
fiber lines are likely to be the most common
trigger of NSPS. In this case, NSPS are
applicable to the modified fiber line only; the remainder of the mill remains an existing source
subject to BAT. Section 430.010 of the rule outlines the following types of changes to existing
mills to which you must apply NSPS (this discussion also applies to PSNS described later in this
section):
1. The modified fiber line completely replaces an existing source. This definition
does not include fiber lines enrolled in the Voluntary Advanced Technology
Incentives Program or fiber lines modified to comply with baseline BAT (see
Section 9).
Note that the following changes do not cause an existing fiber line to be
considered a new source:
• Upgrades of existing pulping operations;
• Upgrades or replacement of pulp screening and brown stock pulp
washing operations;
• Upgrading bleach plant unit operations;
7-8
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« Installation of extended cooking and/or oxygen delignification systems
or other post-digester, pre-bleaching delignification systems;
« Changes in methods or amounts of bleaching chemical applications;
« Changes in the types of bleaching chemicals used;
« Installation of new bleaching towers to facilitate replacement of sodium
or calcium hypochlorite; and
« Installation of new bleached pulp washing systems.
2. The modified fiber line is substantially independent of an existing source at the
same site (i.e., an existing mill builds and operates an entirely new fiber line that
supplements the capacity of an existing fiber line).
A mill is considered a new source under NSPS if it meets the two requirements above and if it
begins discharging after June 15, 1998.
40 CFR 430.25 establishes NSPS for AOX, TCDD, TCDF, chloroform, 12 chlorinated phenolic
pollutants, BOD5, TSS, and pH for new mills with operations in Subpart B. Table 7-6 lists the
limits for each pollutant regulated by NSPS for Subpart B. Mills are subject to the standards for
chlorinated pollutants unless the mill certifies that they use TCP bleaching processes (see 40 CFR
430.25(b)(2)). (Refer to Section 10 for discussion of developing permits for mills enrolling in
VATIP.)
40 CFR 430.55 establishes NSPS for TCDD, TCDF, 12 chlonnated phenolic pollutants, BOD5,
TSS, and pH for new mills with operations in Subpart E. NSPS for toxic and nonconventional
pollutants are equivalent to the BAT guidelines (see Table 7-3 and 7-4). EPA did not revise NSPS
for conventional pollutants; therefore, you must use the standards for BOD5, TSS, and pH
established in 1982. Table 7-7 presents these previously established NSPS.
Indirect
and
This section discusses PSES and PSNS for existing and new indirect dischargers with operations in
Subparts B and E. Refer to above discussion of new sources for a definition of mills subject to
PSNS, and refer to 40 CFR 430.1 (j) and 403.3 (k).
7-9
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If an existing indirect discharger "commences construction" of a new fiber line or other installation
that would fall within the Part 430 definition of "new source," and if it commences construction
after December 17, 1993 (see 40 CFR 403.3(k)), that post-1993 installation would be subject to
PSNS.
•
40 CFR 430.26 and 430.27 establish PSES and PSNS for AOX, TCDD, TCDF, chloroform, and
12 chlorinated phenolic pollutants. EPA has made no pass-through determination for COD;
therefore, there are no COD pretreatment standards for Subpart B at this time. PSES are
equivalent to BAT guidelines for all pollutants except AOX (see Table 7-1).
Table 7-8 lists the PSES and PSNS for AOX. Note that indirect discharge mills must assess
compliance with AOX limitations at the bleach plant.
40 CFR 430.56 and 430.57 establish PSES and PSNS for each segment of Subpart E. PSES and
PSNS are equivalent to BAT guidelines for all pollutants, except chloroform, AOX, and COD.
Under BAT, EPA has reserved ELGs for these pollutants. For PSES and PSNS, however, EPA
has made no pass-through determination for chloroform or AOX in the ammonium and specialty-
grade segments (nor for COD for all of Subpart E). As a result, there are no pretreatment
standards for chloroform or AOX for the ammonium and specialty-grade segments or COD for any
Subpart E segment. At this time, EPA has insufficient data to characterize the performance of the
model BAT technologies for chloroform, AOX, and COD for Subpart E and to subsequently
conduct a pass-through analysis. When these data become available, EPA will make pass-through
determinations and (if warranted) will set pretreatment standards for these pollutants.
7-10
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Table 7-1: Subpart B BAT Effluent Limitations Guidelines
Pollutant
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
AOX
COD
BAT(c),(d)
Continuous Dischargers
1-Day Maximum
(kg/kkg)
-------
Table 7-2; Subpart B BPT Effluent Limitations Guidelines
Pollutant
BPT Limitations (b)
Continuous Dischargers
1-Day Maximum
Average of Daily Values for
30 Consecutive Days
Non-Continuous
Dischargers
Annual Average
Compliance Point
Bleached Kraft Mills Producing Market Pulp Segment
BOD5
TSS
pH
15.45 kg/kkg
30.4 kg/kkg
(a)
8.05 kg/kkg
16.4 kg/kkg
(a)
4.52
9.01
(a)
Final Effluent
Final Effluent
Final Effluent
Bleached Kraft Mills Producing Paperboard, Coarse Paper, and Tissue Paper Segment
BOD5
TSS
pH
13.65 kg/kkg
24 kg/kkg
(a)
7.1 kg/kkg
12.9 kg/kkg
(a)
3.99
7.09
(a)
Final Effluent
Final Effluent
Final Effluent
Bleached Kraft Mills Producing Pulp and Fine Paper Segment
BOD5
TSS
pH
10.6 kg/kkg
22. 15 kg/kkg
(a)
5.5 kg/kkg
11. 9 kg/kkg
(a)
3.09
6.54
(a)
Final Effluent
Final Effluent
Final Effluent
Soda Mills Producing Pulp and Paper Segment
BOD5
TSS
pH
13.7 kg/kkg
24.5 kg/kkg
(a)
7.1 kg/kkg
13.2 kg/kkg
(a)
3.99
7.25
(a)
Final Effluent
Final Effluent
Final Effluent
(a) Within the range of 5.0 to 9.0 at all times.
(b) See 40 CFR 430.22(b), (c), and (d) for additional limitations that apply to mills that use wet wood yard operations.
7-12
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for
.
Pollutant
TCDD(a)
TCDF(a)
Chloroform(a)
rrichlorosyringol(a)
?,4,5-Trichlorocatechol(a)
?,4,6-Trichlorocatechol(a)
?,4,5-Trichloroguaiacol(a)
?,4,6-Trichloroguaiacol(a)
\, 5,6-Trichloroguaiacol(a)
2,4,5-trichlorophenol(a)
2,4,6-trichlorophenol(a)
retrachlorocatechol(a)
retrachloroguaiacol(a)
2,3,4,6-Tetrachlorophenol(a)
5entachlorophenol(a)
AOX
COD
Continuous Dischargers
1-Day Maximum
-------
Table 7-5; Subpart E BPT Effluent Limitations Guidelines(l)
Segment
Papergrade Sulfite Mills Using Blow
Pit Washing Techniques (2)
Papergrade Sulfite Mills Using
Vacuum or Pressure Drums to Wash
Pulp (2)
Papergrade Sulfite Using Vacuum or
Pressure Drums to Wash Pulp (2)
Pollutant (a)
BPT Limitations in kg/kkg (or pounds per 1,000 Ibs) of product
Continuous dischargers
1 Day Maximum
Average of daily values for
30 consecutive days
Noncontinuous dischargers
Annual Average
Point of Compliance
Bisulfite liquor/surface condensers
BOD5
TSS
31.8
43.95
16.55
23.65
9.3
13
Final Effluent
Final Effluent
Bisulfite liquor/barometric condensers Kg/kkg (or pounds per 1,000 Ib) of product
BOD5
TSS
34.7
52.2
18.05
28.1
10.14
15.44
Final Effluent
Final Effluent
Acid sulfite liquor/surface condensers
BOD5
TSS
32.3
43.95
16.8
23.65
9.44
13
Final Effluent
Final Effluent
Acid sulfite liquor/barometric condensers
BOD5
TSS
35.55
52.2
18.5
28.1
10.39
15.44
Final Effluent
Final Effluent
Bisulfite liquor/surface condensers)
BOD5
TSS
26.7
43.95
13.9
23.65
7.81
13
Final Effluent
Final Effluent
Bisulfite liquor/barometric condensers
BOD5
TSS
29.4
52.2
15.3
28.1
8.6
15.44
Final Effluent
Final Effluent
Acid sulfite liquor/surface condensers
BOD5
TSS
29.75
43.95
15.5
23.65
8.71
13
Final Effluent
Final Effluent
Acid sulfite liquor/barometric condensers
BOD5
TSS
32.55
52.2
16.9
28.1
9.49
15.44
Final Effluent
Final Effluent
Continuous digester
BOD5
TSS
38.15
53.75
19.85
28.95
11.15
15.91
Final Effluent
Final Effluent
(1) See 40 CFR 430.52(b), (c), and (d) for additional limitations that apply to mills that use wet woodyard operations.
(2) Each segment includes pH limitations guidelines within the range of 5.0 to 9.0 at all times.
7-14
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Table 7-6; Subpart B New Source Performance Standards
Pollutant
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
AOX
BOD5
TSS
pH
COD
Bleach Plant Effluent
Continuous Dischargers
1-Day Maximum
-------
Tar- .
E for
Pollutant
Parameter
BOD5
TSS
pH
Final Effluent
Kg/kkg (or pounds per 1,000 Ibs) of Product
Continuous Dischargers
1 Day Maximum
4.38exp(0.017x)
5.81exp(0.017x)
(a)
Average of Daily Values for
30 Consecutive Days
2.36exp(0.017x)
3.03exp(0.017x)
(a)
Noncontinuous Dischargers
Annual Average
Average of daily values for 30
consecutive days divided by
1.91
Average of daily values for 30
consecutive days divided by
1.90
(a)
x - Percent sulfite pulp in final product.
(a) Within range of 5 to 9.
'
fc :
Regulation
PSES
PSNS
Pollutant
AOX
AOX
Bleach Plant Effluent
1-Day Maximum
(kg/kkg)
2.64
1.16
Monthly Average
(kg/kkg)
1.41
0.814
7-16
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his section discusses the step-by-step process of establishing permit limits using ELG&S for
mills with operations in Subparts B and E. The discussion covers the following topics to aid
you in establishing permits:
STEP1
Pre-Application Activities
STEP 2
Reviewing Permit Applications
STEPS
Developing Permit Limits
STEP 4
Developing Monitoring Requirements
STEPS
Developing Compliance Schedules
STEP 6
Developing Special Conditions
STEP 7
Extending Standard Conditions
for Bleach Plant Permit Limits
8-1
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STEP 2
Reviewing Permit Applications
STEP 3
Developing Permit Limits
STEP 4
Developing Monitoring Requirements
STEPS
Developing Compliance Schedules
STEP 6
Developing Special Conditions
STEP 7
Extending Standard Conditions
for Bleach Plant Permit Limits
Before a permit application is submitted by a mill, the permit writer should work to become
familiar with the mill's situation, its personnel, and its compliance status. These pre-application
activities could include the following:
1. Reviewing the mill's current NPDES permit, supporting record, and compliance
history.
2. Developing an effective relationship with mill personnel and corporate officials
who complete the application and provide supplemental information needed to
finish a draft permit. This can be started by setting up meetings with mill
officials before an application for a permit is submitted to discuss the mill's
current compliance, current mill operations, and new standards or limitations that
will be incorporated in the new permit. These meetings will be critical in
supporting a timely completion of the draft permit and in Agency preparation for
any legal response that may be expected from the applicant if the permit
conditions are not to their liking.
3. If an Agency lacks permit experience, then a mill visit by the permit writer is
strongly suggested so that the site operations are understood "first hand" and so
that information from the visit can be used by the permit writer in the permit
preparation.
8-2
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STEP1
Pre-Application Activities
- Ill Ill ,!" : in:
STEP 3
Developing Permit Limits
STEP 4
Developing Monitoring Requirements
STEPS I
Developing Compliance Schedules I
STEP 6
Developing Special Conditions
STEP?
Extending Standard Conditions
for Bleach Plant Permit Limits
Permit
'tj in in
All mills that discharge process wastewaters into receiving streams must submit the following
forms when applying for an NPDES permit:
1. Form 1, which includes basic mill information and the SIC codes for the
products manufactured; and
2. Form 2C (existing sources) or Form 2D (new sources), which includes outfall
information, flow information or projections, and production information or
projections.
These forms, if completed properly, should provide most of the information necessary for
establishing NPDES permits for mills. The two forms, however, are generic for all facilities with
manufacturing, commercial, mining and silvacultural operations (see the U.S. EPA NPDES Permit
Writer's Manual (EPA-833-B-96-003) for more information about NPDES permit application
forms). For pulp and paper mills, you may need additional information to issue appropriate
permits. Two issues that you must be aware of when reviewing permit applications include:
1. 40 CFR 430 has been reorganized so the subparts address similar processes, and
not by products manufactured (see Section 3). On the permit applications,
however, mills note SIC codes of the products manufactured, not mill processes.
If the mill's processes are difficult to identify, you may need to contact the
facility to accurately identify process operations. To help you identify the
applicable ELG&S for existing direct dischargers, you may refer to Appendix A
which lists all existing mills with operations in Subparts B and E (the appendix
also indicates whether the mill performs operations that are covered under other
subparts).
2. The amount of final product manufactured is not sufficient for establishing some
permit limits. Required production information is described in more detail
below.
8-3
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As part of the permit process, you must apply the ELG&S developed by EPA to establish
numerical permit limits for mills. Note that permits may also include WQBELs (see section 2);
however, this document focuses on the development of permit limits based on ELG&S for the pulp
and paper industrial category.
After reviewing the permit application and determining the application is complete, you must
establish numerical permits limits for pollutants regulated by ELG&S. Some of the ELG&S are
mass-based while others are concentration-based (see Table 8-1). Concentration-based ELG&S
are simply the allowable pollutant concentration in a regulated effluent stream, and are
independent of a mill's production. For those pollutants that are concentration-based, you must
include the concentration value of the ELG&S for the pollutant as the permit limit. Mass-based
ELG&S are expressed as an allowable mass of pollutant discharge per unit of production and are
directly related to a particular mill's production.
Alert! It is important to obtain accurate production information to
establish permit limits for mass-based ELG&S.
8-4
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I .He 8 1
Or ' "d I ill '„,;•'•.'.'•':
Pollutants
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform
12 chlorinated phenolic pollutants
AOX
COD
BOD5 (for direct dischargers)
TSS (for direct dischargers)
pH (for direct dischargers)
Units
Pg/L
Pg/L
g/kkg
ug/L
kg/kkg
Reserved
kg/kkg
kg/kkg
pH units
Concentration-Based
/
/
/
Reserved
NA
Mass-Based
/
/
Reserved
/
/
NA
NA = Not applicable for this pollutant
Alert! Production is defined as off machine tons for
BOD5 and TSS limits, but as air-dried tons of
unbleached pulp entering the bleach plant for AOX
and chloroform limits.
. . e to 1
For pollutant limits that have mass-
based ELG&S, you must first
identify the mill's appropriate
production rate, and then multiply
that rate by the mass-based limit to
determine the permit limits (the
allowable mass of pollutant in a
mill's bleach plant or final effluent).
Note that there are two production definitions, one used to determine permit limits for AOX and
chloroform and another used to determine permit limits for conventional pollutants. This section
discusses the difference between the two production definitions and demonstrates how to
determine appropriate production rates.
Be to and I
For AOX and chloroform, EPA defines production as ". . . the annual unbleached pulp entering the
first stage of the bleach plant divided by the number of operating days during that year." The
unbleached pulp must be measured in air-dried metric tons (air-dried means 10% moisture) of
brown stock pulp entering the bleach plant at the stage where chlorine or chlorine-containing
compounds (i.e., chlorine dioxide) are first added. For mills that use TCP bleaching, unbleached
pulp production must be measured as the amount of brown stock pulp entering the first stage of the
bleach plant from which wastewater is discharged (see 40 CFR 430.0l(n)).
Note that mills typically measure the amount of bleached pulp that exits the bleach plant, and not
the amount of brown stock pulp that enters the first stage of the bleach plant. These are two
8-5
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different values; the amount of pulp leaving the bleach plant is less than the amount of pulp
entering the bleach plant because a certain amount of pulp is lost during the bleaching process.
This pulp loss is known as bleaching "shrinkage." Bleaching shrinkage depends on the fiber
furnish (i.e., hardwood versus softwood), bleaching process operations (i.e., oxygen
delignification, types of bleaching chemicals) and chemical application rate (i.e., greater amount of
chemical use results in greater shrinkage).
Most mills know the bleaching shrinkage value associated with their process. You may require the
mill to report the amount of brownstock pulp entering the bleach plant, or use the bleaching
shrinkage value provided by the mill to calculate that amount. If the mill doesn't know the
bleaching shrinkage, you can estimate bleaching shrinkage by referring to Table 8-2, which
presents bleaching shrinkage values used by paper industry engineers for design and analysis.
Mills will typically measure bleached pulp in terms of
air-dried metric tons (ADMT) or air-dry tons (ADT), standard units of measure in the pulp and
paper industry defined as 10% moisture. Therefore, you will not have to adjust the production to
10% moisture content.
General Bleaching Process
Chlorine-Based or Chlorine Dioxide-Based Bleaching Sequence
Oxygen Delignification + Chlorine -Based or Chlorine Dioxide -Based
Bleaching Sequence
Extended Cooking + Chlorine -Based or Chlorine Dioxide -Based
Bleaching Sequence
Extended Cooking + Oxygen Delignification + Chlorine -Based or
Chlorine Dioxide -Based Bleaching Sequence
Hardwood
4%
4%
2%
2%
Softwood
8%
8%
4%
4%
*Source: BAT Cost Model Support Document. Prepared by Radian Corporation for EPA, 1996. Pulp, Paper, and Paperboard
Rulemaking, Section 23.1.2, DCN 13593.
Be to
For conventional pollutants, production is defined as ". . . the annual off-the-machine production
(including off-the-machine coating where applicable)." Note that coatings and other additives
(e.g., clay, pigments, sizing, strengthening agents) may account for 10 to 40% of a final paper
product's weight. The production definition for conventional pollutants includes the weight
contributed by coatings and additives. For those mills that produce pulp as the final product (i.e.,
"market" pulp), the definition of production for conventional pollutants is that amount of pulp "...
measured in air-dry tons (10% moisture)" (see 40 CFR Part 430.01(n)).
As part of business operations as well as permit requirements, mills record production of all final
products. Paper products are typically measured in OMMT or OMT, which is consistent with the
production definition for conventional pollutants. Mills that manufacture market pulp typically
measure this product in terms of ADT with 10% moisture content, which is consistent with the
8-6
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production definition for conventional pollutants. You may find that some mills report market
pulp production with variable moisture content. If so, you must either obtain the pulp moisture
content information from the mill, and then normalize the pulp production to 10% moisture
content, or require the mill to do so.
Table 8-3 lists production measures common to the pulp and paper industry.
Note: You should review product information submitted by existing
direct discharges because you may find they have increased or
decreased production or they manufacture new products.
Production Measure
Off -the -machine
Air-dry
Oven-dry
Bone-dry
Metric
Units
OMMT
ADMT
ODMT
BDMT
Notes
Used when measuring final paper product. Regulatory definition does
not specify standard moisture content. Moisture content is variable for
final paper products. Typical moisture content is 7% (±2%).
Standard industry term, defined as 10% moisture content. Typically used
when measuring market pulp or bleached pulp production.
Standard industry term, defined as 0% moisture content.
Old term for oven-dry.
T - English ton.
MT - metric ton.
Note: 1 ton = 0.907 metric ton.
H •>.•;.w Do 1 the
The production rate is determined by dividing the annual production in metric tons by the number
of operating days during that annual period.
EPA has established general permitting regulations at 40 C.F.A. § 122.45(b) that specify a
production rate calculation method that you may use to determine permit limits for pollutants that
have mass-based EG&S. Applying that method, however, may result in different permit limits than
those derived using the method outlined in the definition of production described above. Because
the general permitting regulations serve a general purpose, you should use the definitions described
above, which specifically refer to establishing permit limits for pulp and paper mills.1
'Applying the production rate calculation method in 40 CFR Part 430, instead of the analogous provisions in
Part 122 in this situation, is consistent with the principle of statutory and regulatory construction that the
more specific requirements takes precedence over the more general one. Moreover, 40 CFR §122.44(a)
specifically requires each NPDES permit to include permit limits based on ELG&S promulgated by EPA
under CWA Section 301 (e.g., BAF) and CWA Section 306 (e.g., NSPS). Fhe EFG&S in Part 430 are
premised on the use of the term "production" as defined in 40 CFR §430.01(n). Fherefore, calculating
permit limits for pollutants with mass-based EFG&S using §122.45(b) instead of §430.01(n) would be
inconsistent with both Part 430 and, by extension, §122.44(a).
8-7
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Using the definitions of production specified in 40 CFR 430.01(n), you must determine production
rate based on "past production practices, present trends, or committed growth." This means that
the production rate should be based on past and/or projected mill data. As a part of their permit
applications, mills should be asked to provide monthly production and the corresponding number
of operating days data for the five years prior to the expiration of their current permit. If monthly
production data is not available, you can also use the annual production data and the corresponding
number of operating days for the five years prior to the expiration of their current permit.
The pulp and paper industry operates 24 hours per day, seven days per week. Most mills only
have shut downs during scheduled maintenance periods or if market conditions require a mill to
stop production for a period of time. Scheduled maintenance shut downs typically occur once or
twice a year. Therefore, the number of operating days per year to use in determining production
rate is the number of days during the year minus maintenance shut downs and any special market-
driven shut downs (e.g., a typical mill's operating days per year will be about 350).
You should calculate permit limits based on the maximum 12-month production demonstrated by
the facility over the last five years. The maximum 12-month production can be calculated either as
the maximum rolling 12-month production over the last five years or as the maximum yearly
production over the last five years. If a facility has papermaking operations that are completely
independent of pulp operations, then there may be cases where you would calculate permit limits
using different 12-month maximum production dates.
You must ensure that the mill provides (or calculates using bleaching shrinkage) unbleached kraft
pulp production for each bleach plant, in order to establish the appropriate permit limits for
chloroform (and AOX for indirect dischargers). You may find that some complex mills operate as
many as four bleach plants. In this case, you must use four production rates, one for each bleach
plant.
In certain circumstances, you will find that evaluating the production rate using the suggested
method is not appropriate. Some mills may have recently changed operations (e.g., a mill installed
a new paper machine within six months of permit reissuance). In these cases, you should only use
data that reflect recent operation. Other mills may plan to change operation during the term of the
permit (e.g., a mill plans to reduce or increase bleaching operations or to retire or add a paper
machine). For those mills, you may establish multiple sets of limits based on tiered production
values that reflect current and projected mill operation.
Three examples of how to determine production are presented below.
8-8
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Example 1:
to produce t
production (
production
Mill A prov
their permit
follows:
The product
Mill A produces bleached kraft pulp to manufacture fine papers. The mill operates one bleach plant
tie bleached pulp and one paper machine to manufacture fine papers. Upon reviewing the mill's
iata, you find that over the past five years, the sum of their bleached kraft production and fine paper
Deaked between June 1996 and May 1997. The raw data during this time period is as follows:
Date
June 1996
July 1996
August 1996
September 1996
October 1996
November 1996
December 1996
January 1997
February 1997
March 1997
April 1997
May 1997
Total (ADMT or OMM17 year)
Total Operating Days/Year
Total (ADMT or OMMT/day)
Bleached Kraft Pulp
Production (ADMT/mo)
22,900
23,000
23,200
22,700
29,400
29,000
12,000
22,800
22,300
22,900
22,600
23,000
275,800
350
788
Fine Paper Production
(OMMT/mo)
27,900
27,800
28,000
27,700
27,600
27,600
27,300
28,100
27,900
29,000
27,350
27,300
333,500
350
953
ided an 8% shrinkage factor for the bleached papergrade kraft pulp production data submitted with
application. Based on this information, calculate the production rate for AOX and chloroform as
7887(1-0.08) = 857 ADMT of unbleached papergrade kraft pulp entering the bleach plant.
ion rates for Mill A are as follows:
Production Rate for AOX and Chloroform 857 ADMT
Production Rate for Conventional Pollutants that Result from 953 OMMT
Fine Paper Manufacturing
8-9
-------
Ex
bk
re\
prc
In
prc
rat
Th
ample 2: Mill B produces bleached kraft pulp to manufacture fine papers and tissue. The mill operates two
ach plants to produce the bleached pulp and two paper machines to manufacture fine papers and tissue. After
dewing the previous five years of data, you find that the sum of bleached kraft pulp, fine papers, and tissue
)duction peaked during the following time period:
Date
1/97
2/97
3/97
4/97
5/97
6/97
7/97
8/97
9/97
10/97
11/97
12/97
Total (ADMT or
OMMT/yr)
Total Op. days/yr
Total (ADMT or
OMMT/dy)
their perm
jduction d
es for AO
e producti
Bleach Plant #1
(ADMT/mo)
12,500
12,700
12,300
12,300
12,900
12,100
11,800
13,000
12,500
12,700
12,900
13,150
150,850
350
431
Bleach Plant #2
(ADMT/mo)
18,000
18,300
18,200
17,600
18,150
18,700
17,600
19,000
18,500
18,500
18,300
18,600
219,450
350
627
Combined Bleach
Plant
(ADMT/mo)
30,500
31,000
30,500
29,900
31,050
30,800
29,400
32,000
31,000
31,200
31,200
31,750
370,300
350
1,058
Fine Paper
(OMMT/mo)
16,000
15,750
15,400
15,300
15,800
15,650
15,750
15,100
15,950
16,250
15,800
16,250
189,000
350
540
Tissue
(OMMT/mo)
22
,900
23,100
23
,000
23,400
23
,500
23,500
23
,000
24,000
23
,200
23,600
22
,400
22,300
277,900
350
794
it application, Mill B provided an 8% and a 4% shrinkage factor for the bleached kraft pulp
ata for Bleach Plants #1 and #2, respectively. Based on this information, calculate the production
X and chloroform as follows:
Bleach Plant #1 = 4317(1-0.08) = 468 ADMT of unbleached papergrade kraft pulp
Bleach Plant #2 = 6277(1-0.04) = 653 ADMT of unbleached papergrade kraft pulp
Combined Bleach Plants = 468 + 653 = 1,121 ADMT of unbleached papergrade kraft pulp
on rates for Mill B are as follows:
Production Rate for combined bleach plants (for AOX permit limits in final effluent)
Production Rate for chloroform for Bleach Plant #1
Production Rate for chloroform for Bleach Plant #2 (for chloroform permit limits in
bleach plant effluent)
Production Rate of fine paper that results in the maximum conventional pollutants
permit limits
Production Rate of tissue that results in the maximum conventional pollutants permit
limits
1,121 ADMT
468 ADMT
653 ADMT
540 OMMT
794 OMMT
8-10
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Example 3
operates o
mill has p]
OMMT of
that the bit
years of dt
the follow
Mill C pro
their perm
follows:
The produ
: Mill C produces bleached kraft pulp to manufacture bleached market pulp and fine papers. The mill
tie bleach plant to produce the bleached pulp and one paper machine to manufacture fine papers. The
ans to begin operation of a new paper machine in September 2000 to manufacture an additional 200
fine paper. At that time, the mill will decrease market pulp manufacture by approximately 20% so
;ached kraft pulp can be used to increase fine paper production. After reviewing the previous five
ita, you find that the sum of bleach kraft pulp, fine paper, and market pulp production peaked during
ng time period:
Date
7/97
8/97
9/97
10/97
11/97
12/97
1/98
2/98
3/98
4/98
5/98
6/98
Total (ADMT or
OMMT/year)
Total Op. Days/yr
Total (ADMT or
OMMT/day)
Bleached Kraft Pulp
(ADMT/mo)
26,750
25,800
25,900
26,100
26,015
26,000
25,800
25,700
25,800
25,500
25,600
25,500
309,465
345
897
Fine Paper
(OMMT/mo)
7,900
8,000
8,100
8,000
8,090
8,100
8,300
8,350
8,550
8,100
7,900
7,900
97,290
345
282
Market Pulp
(ADMT/mo)
20,000
20,100
20,350
20,550
20,300
20,415
19,900
20,100
20,400
20,600
20,500
20,700
243,915
345
707
vided an 8% shrinkage factor for the bleached papergrade kraft pulp production data submitted with
it application. Based on this information, calculate the production rate for AOX and chloroform as
8977(1-0.08) = 975 ADMT of unbleached papergrade kraft pulp entering the bleach plant.
ction rates for Mill C for the noted time period are as follows:
Production rate for AOX and Chloroform
Production rate of fine papers that results in maximum
conventional pollutants permit limits
Production rate of market pulp that results in maximum
conventional pollutants permit limits
From Permit
Reissuance to 9/00
975 ADMT
282 OMMT
707 ADMT
From 9/00 to Expiration of
Permit
975 ADMT
482 OMMT
566 ADMT
8-11
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II '. [ '. the is to the of E?
To determine whether a mill is subject to ELG&S for the specialty-grade sulfite segment of
Subpart E, you must review mill production information. Papergrade sulfite mills subject to
ELG&S for the specialty-grade segment produce pulp characterized by a high percentage of alpha
cellulose and high brightness sufficient to produce end products such as plastic molding
compounds, saturating and laminating products, and photographic papers. (EPA considers a
significant portion of production to be 25% or more.) Mills subject to BAT limitations for the
specialty-grade segment also include those mills where a major portion (e.g., greater than 50%) of
the production is 91 ISO brightness and above. Mills that do not meet these criteria are subject to
BAT limitations for the ammonium-based segment or the calcium-, magnesium-, and sodium-based
segment, depending on the mill's pulping process. Figure 8-1 illustrates how you must determine a
papergrade sulfite mill's appropriate segment.
You should consider the expected production mix at the mill over the full term of the permit. For
mills that plan to begin to manufacture products that would require the mill to comply with
limitations for the specialty-grade segment, you should establish permit limits that reflect
operations for the full permit term. For example, if a mill states that they wish to be considered
part of the specially grade segment but will not meet the production criteria until the last year of a
5-year permit, then they must meet limitations for the appropriate non-specialty grade segment
until conversion to specialty grade operations.
the I on El Gs or s?
All receiving waters have water quality standards that are established by the states or EPA that
protect the designated uses of the receiving water. After determining the allowable limits based on
ELGs, you must compare them to the receiving water's WQBELs. If limits based on ELGs for a
particular pollutant result in discharges that exceed the WQBELs for the receiving water, you must
establish permit limits that are based on WQBELs (see Section 2 for more information regarding
WQBELs).
8-12
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Subpart E - Papergrade Sulfite
Mill has Operations in:
Is
>25% of
Facility's Production
Characterized by Pulp with
High Alpha Cellulose
Content and High
Brightness
Specialty-Grade
Sulfite Segment
Is
>50% of
Production 91 ISO
or Above
t
Does
Facility Use
Ammonium-Based
Sulfite Pulping
Base
Ammonium-Based
Sulfite Segment
Calcium-, Magnesium,
or Sodium-Based
Sulfite Segment
Figure 8-1. Papergrade Sulfite Facility Segment Identification
8-13
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One of your responsibilities is to establish monitoring requirements for mills with operations
subject to Subparts B and E. NPDES permits require dischargers to monitor their effluent to
ensure that they are complying with permit limitations. As specified in 40 CFR 122.41, 122.44,
and 122.48, all NPDES permits must specify requirements for using, maintaining, and installing (if
appropriate) monitoring equipment; monitoring frequencies; analytical methods; and reporting and
recordkeeping. This section focuses on the following unique aspects of the revised rule:
* How do you specify appropriate in-process monitoring locations?
« What are the required minimum monitoring frequencies?
« What are the required analytical methods and the minimum levels of detection of
each method?
« What other process parameters must be monitored to demonstrate that samples
are representative?
Note that the mandatory BMPs also have monitoring requirements. These requirements are
discussed in Section 9. In addition, those mills enrolling in VATIP have reduced monitoring
requirements. The VATIP requirements are presented in Section 10.
8-14
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What are the Monitoring Locations?
You must require mills to monitor their effluent in order to determine compliance with the ELG&S
promulgated by EPA (see Section 6). For direct dischargers who must demonstrate compliance
with AOX limits at the final effluent, you may simply require monitoring at the outfall where
conventional pollutants are currently monitored. For TCDD, TCDF, chloroform, and the 12
chlorinated phenolic compounds (and AOX at indirect discharges), you must specify bleach plant
monitoring locations.
The rule defines bleach plant effluent as "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 (40 CFR §430.01). At most mills, wastewaters from
acid and alkaline bleaching stages are discharged to separate sewers. For these mills, you should
specify a monitoring location for each sewer. The monitoring locations should be situated after the
sewers have collected all of the acid or alkaline bleaching stage discharges and before they are
mixed with other mill wastewaters. Because chloroform concentrations may change through air
stripping as the samples are collected, measured, and composted or through chemical reaction
when the acid and alkaline samples are combined, the acid and alkaline monitoring locations
should be at the point as close as possible to where bleach plant wastewater is discharged from
process equipment. Figure 8-2 illustrates appropriate monitoring locations for separate acid and
alkaline streams at a generic mill.
At some mills, bleach plant wastewaters are discharged to a combined sewer containing both acid
and alkaline wastewaters. For TCDD, TCDF, and the chlorinated phenolic compounds (and AOX
at indirect discharges), compliance with the effluent limitations and standards can be demonstrated
by collecting separate samples of the acid and alkaline discharges and preparing a flow-
proportioned composite of these samples, resulting in one sample of bleach plant effluent for
analysis. In determining the limitations, EPA used data from acid and alkaline bleach plant
effluents that had been analyzed separately and also data from combined sewers. Unless
prohibited by the mill's construction,
chloroform must be monitored in the
., , „ ,. Alert! Given the wide variety of bleach plant and
separate acid and alkaline streams at „. ,. . , ...
r sewer configurations, you must evaluate mills on a
case-by-case basis to determine appropriate
monitoring locations.
the point closest to where bleach
plant wastewater is discharged from
process equipment. Otherwise,
chloroform may change through
chemical reaction when the acid and alkaline samples are combined. Figure 8-2 illustrates an
appropriate monitoring location for mills that use a combined acid and alkaline sewer.
Mills certifying that they use exclusively TCP bleaching processes are not subject to ELG&S for
any chlorinated compounds other than AOX. You may require direct dischargers that certify using
exclusively TCP processes to monitor for AOX at the same location where they currently monitor
for conventional pollutants, or use your discretion to establish a bleach plant effluent monitoring
location. For indirect dischargers making this certification, you must require AOX monitoring at
an appropriate bleach plant monitoring location.
8-15
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Separate Acid and Alkaline Sewer Streams
Fresh or
White Water
Fresh or
White Water
Unbleached
Pulp
EOP
Alkaline Sewer
Acid Sewer
Combined Acid and Alkaline Sewer Streams
Fresh or
WhiteWater
Fresh or
White Water
foX
Unbleached
Pulp
EOP
Stage
i
r
y.
S | |
X--
=n
Stage
i
V
E
Stage
i
1,
fpl
Combined Sewer
p:\graphlcsVpulp\dan-e4.cdr
Monitoring Points
= Appropriate Bleach Plant Effluent Monitoring Locations.
Bleached
Pulp
Bleached
Pulp
To
Wastewater
Treatment
Other
Mill
Wastewater
I' for /l.tfd -" "..•
wer
8-16
-------
are the
Unlike other ELG&S, the pulp and paper regulations require minimum monitoring frequencies for
AOX, TCDD, TCDF, chloroform, and 12 chlorinated phenolic compounds, the toxic and
nonconventional pollutants regulated under Subparts B and E (see 40 CFR 430.02). You must
incorporate these minimum monitoring frequencies in permits for mills subject to those subparts
(see Table 8-4 below). For all other pollutants, such as BOD5 and TSS, you must establish
monitoring frequencies in accordance with 40 CFR § 122.44(1), using BPJ. You may also use BPJ
to specify more frequent monitoring on a case-by-case basis.
Note that you must require mills to monitor at the minimum frequencies shown in Table 8-4 as of
the date EPA amends the NPDES Discharge Monitoring Report ICR No. 229 (to be published in
the Federal Register; current OMB approval number 2040-0004)). Until then, you must establish
monitoring frequencies using BPJ, under 40 CFR § 122.41. For indirect dischargers, you must
require mills to monitor at the minimum required frequency on or before April 16, 2001.
Mills must monitor at the minimum required frequency for five years (40 CFR §430.02(b)), which
is the duration of the permit. This will provide data that will be useful to you in establishing
monitoring frequencies in the next revised permit. For direct dischargers, the five-year period is
measured from the date the applicable limitations or standards are first included in the discharger's
NPDES permit. For existing indirect dischargers, the five-year monitoring period is April 16,
2001 until April 17, 2006. New indirect dischargers must monitor their effluent at the specified
monitoring frequencies for five years starting on the date the discharger commences operation.
After the five-year "minimum monitoring period" ends, you may adjust monitoring requirements
as you deem appropriate on a case-by-case basis. You should consider the mill's compliance and
enforcement history in determining monitoring frequencies. For those mills consistently
demonstrating pollutant reductions better than permit requirements, you may establish less frequent
monitoring requirements. Conversely, you may consider establishing more frequent monitoring
requirements for mills with a poor compliance history.
in B
Us
Pollutant
12 chlorinated phenolic pollutants
2,3,7,8-TCDD
2,3,7,8- TCDF
Chloroform
AOX
Minimum Monitoring Frequency
Non-TCF (a)
monthly
monthly
monthly
weekly
daily
TCF (b)
(c)
(c)
(c)
(c)
none specified
(a) non-TCF: Pertains to any fiber line that does not use exclusively TCF bleaching processes.
(b) TCF: Pertains to any fiber line that uses exclusively TCF bleaching processes, as disclosed by the discharger in its
permit application under 40 CFR §122.21(g)(3) and certified under 40 CFR §122.22, or for indirect dischargers, as
reported to the pretreatment control authority under 40 CFR §403.12 (b), (d), or (e).
(c) Limit is not specified for this pollutant.
8-17
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EPA has issued The Interim Guidance for Performance-Based Reductions of NPDES Permit
Monitoring Frequencies, which may be useful to you in determining alternative monitoring
frequencies at the end of the five-year period. You also may find this guidance useful in setting
monitoring frequencies for indirect dischargers.
Because the regulation does not specify a minimum monitoring frequency for mills that certify they
use exclusively TCP bleaching processes, you must specify the AOX monitoring frequency based
on BPJ (see Section 2). In this case, EPA recommends monthly AOX monitoring. You may wish
to include provisions for mills to decrease their monitoring frequency if they demonstrate
nonexistent or minimal pollutant discharge.
During What Bleaching Conditions Should Mills Collect Samples?
The ELG&S are based on complete substitution of chlorine dioxide for chlorine and hypochlorite
(i.e., ECF bleaching). However, because EPA does not mandate the use of model process
technologies you may find some mills use chlorine and/or hypochlorite during bleaching
operations while complying with BAT. Compared to chlorine dioxide bleaching, these chemicals
generate greater quantities of chlorinated pollutants. A mill's bleaching practices must be
considered carefully when determining how the mill should demonstrate compliance with permit
limits on chlorinated pollutants in bleach plant effluent.
Section 122.41Q of EPA's permitting regulations provides that "[sjamples and measurements
taken for the purpose of monitoring shall be representative of the monitored activity." Therefore,
if a mill's bleaching operations are so variable that samples collected once per month (for TCDD,
TCDF, and the 12 chlorinated phenolic compounds) and once per week (for chloroform) may not
be representative of all typical mill operations, you must require more frequent monitoring in order
to satisfy the requirement of §122.410.
Alternatively, you could require sampling at the minimum monitoring frequency for each
chlorinated pollutant, but require that the samples reflect the "worst case" condition of the bleach
plant effluent with respect to chlorinated pollutants of concern. Note that because, by definition,
the "worst case" is not representative of the monitored activity, you would need the mill's consent
to this monitoring approach. EPA anticipates that when given the choice mills may opt to sample
during "worst case" conditions rather than assume the costs of more frequent monitoring.
To determine "worst case" conditions, you should consider the following factors:
1. Chlorine and/or hypochlorite application rates (kg of bleaching chemical/MT of
pulp bleached). Mills typically monitor and record information such as chemical
application rates in order to optimize and control the bleaching process. You
should review these records to select operations that represent "worst case"
conditions. For those mills that continue to use chlorine and/or hypochlorite
bleaching, you may require monitoring during operations that use these
chemicals.
2. Kappa factor (equivalent chlorine +• kappa number). The kappa number
indicates the lignin content of the pulp. The pulping process removes much of
8-18
-------
the lignin and mills generally measure the kappa number after pulping to
properly adjust chemical application rates and otherwise optimize bleaching
parameters. The lower the kappa number, the lower the required chemical
application rate to produce a given pulp quality. Kappa factor is the ratio of
chlorine bleaching chemicals applied to the lignin content of the pulp. Use of a
lower kappa factor reduces the potential for formation of chlorinated pollutants.
High kappa factors may lead to excessive discharges of chlorinated pollutants.
You should review mill records to determine what kappa factors represent
"worst case" conditions, and consider requiring monitoring during use of those
kappa factors.
3. Final product brightness. Greater chemical application rates are required to
achieve higher brightness pulps. Typically, higher brightness pulps are produced
through the application of increased rates of chlorine dioxide, chlorine, or
hypochlorite. You may require monitoring during production of the highest
brightness pulps.
4. Other indicators of bleaching intensity. One indicator is the types of furnish.
Softwood furnish has a lignin content that is greater than that of hardwood
furnish. As a result, softwood furnishes typically require increased bleaching
chemical application rates. The type of furnish should be especially important
with respect to "worst" case conditions for mills that use "swing" fiber lines.
"Swing" fiber lines refer to pulping and/or bleaching systems that are used for
both hardwood and softwood furnishes. In selecting "worst case" conditions for
a "swing" line, you may require monitoring during worst case conditions for
softwood bleaching.
5. Other measures demonstrated to be predictive of effluent pollutant loads.
NCASI and IPST, for example, have developed a model that predicts AOX
loadings based on inputs such as bleaching chemical application rates, kappa
numbers, and type of furnish. This model can be used to determine the
combination of bleaching conditions that represents "worst case." You may
consider requiring monitoring during those conditions.
Note that identifying "worst case" conditions may be impossible for mills with extremely variable
bleaching practices. For these mills, sampling during "worst case" conditions is not appropriate
and you should require more frequent monitoring.
Should Mills be Required to Measure Bleach Plant Flows?
EPA strongly recommends that you require mills to continuously measure their bleach plant flows
as a permit condition. Because the ELG&S for TCDD, TCDF, and the 12 chlorinated phenolic
compounds are expressed as
concentrations, continuous bleach
, .„ , .,, Note: EPA strongly recommends that you require
plant now measurements will .„ ,•,,,, m ™
mills to measure their bleach plant effluent flow as a
indicate whether increases in bleach pemlt condltlon
plant flow coincide with compliance
sampling. Periodic increases in
8-19
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bleach plant effluent flow that are not representative of mill operations are in violation of Section
122.410. EPA included costs to install continuous bleach plant effluent flow measurement as part
of the economic analysis for this final regulation. Only in the case where a facility can
demonstrate that their flow measurement costs are wholly disproportionate to EPA's estimated
costs should you consider continuous flow measurement to be impractical.
To ensure the mill collects samples that are representative of normal operations, you should require
mills to:
1. Perform compliance sampling at the appropriate location(s). Appropriate
sampling locations are discussed above.
2. Use appropriate flow measurement device(s) at the specified location(s). You
will find that few mills with operations in Subpart B and E currently measure
their bleach plant flow. Refer to Appendix F for a list of various flow
measurement devices available to these mills.
3. Keep records of daily flow measurement records onsite for 3 years so inspectors
can determine if samples were collected during normal operations and were
representative of typical discharge flow.
What are Appropriate Sample Collection Methods?
In addition to establishing the frequency of compliance monitoring, you must specify the types of
samples the mill should collect. This section summarizes the sample collection methods for each
pollutant at the point at which compliance must be demonstrated.
You can find more detailed information on sample collection protocols in EPA's Generic
Sampling and Analysis Plan for the U.S. Environmental Protection Agency and Paper Industry
Cooperative Long-Term Variability Study. This plan was written for a sampling effort performed
jointly by EPA, the American Forest and Paper Association (AF&P) and the National Council of
the Paper Industry for Air and Stream Improvement (NCASI) to collect data necessary to establish
the revised rule, and details sample collection methods approved by industry for each pollutant at
the appropriate compliance point.
Bleach Plant Effluent
2.3.7.8-TCDD: 2.3.7.8-TCDF: and the Chlorinated Phenolic Compounds (and AOX for indirect
dischargers'). At each bleach line, mills should collect grab composite samples from both the acid
sewer and alkaline sewers. Each composite should be collected every four hours, for 24 hours,
from the monitoring location (at the identified tap, valve, or sump) specified in the permit. Mills
may use a continuous automated sampling device, if it can be operated reliably at the appropriate
monitoring location. Alternatively, mills may prepare one flow-proportioned composite of the acid
and alkaline sewer samples (i.e., one bleach plant effluent sample). EPA did receive information
during the comment period of the rule related to Method 1653. The commenter reported problems
in achieving the Minimum Level in Method 1653 for samples of composited acid and alkaline
filtrates. If necessary, to achieve the minimum level, EPA recommends that the facility test the
effluents separately for reliable determination of the chlorophenolics, TCDD, and TCDF.
8-20
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Chloroform. Mills must collect separate samples of acid and alkaline bleach plant filtrates for
chloroform analysis. This is to prevent the loss of chloroform through air stripping as the samples
are collected, measured, and composited, or through chemical reaction when the acid and alkaline
samples are combined. If the mill
does not have separate acid and
„ ,. . .. Alert! Samples to be analyzed for chloroform
alkaline sewers, they must collect . : .. ... , „.. „
J require special handling because of chloroform s
volatility.
compliance samples at the point
closest to the bleach plant that is, or
can be made, physically accessible.
Samples to be analyzed for chloroform should be collected every four hours, for 24 hours. Mills
must never collect samples using a continuous automated sampling device because chloroform is
volatile. In addition, the following special sampling procedures apply:
1. Samples should be cooled during collection because the bleach plant effluent
streams are hot and if collected hot will result in trapped air bubbles in the
sample container;
2. Samples should be collected as grabs (6 pairs of samples per 24 hours), 40
milliliters (mL) each from acid and alkaline stream (one set is back-up), which
will be composited at the laboratory; and
3. Samples must not contain air bubbles.
Final Effluent
AOX (for direct dischargers'). Unless you specify otherwise in the permit, mills may collect
samples to be analyzed for AOX as grab samples or continuous automatic composited samples at
the same point where the mill is required to monitor for BOD5, TSS, and pH. If grab samples are
appropriate, the mill should collect them every four hours, for 24 hours.
Table 8-5 summarizes recommended sample collection methods for each regulated pollutant. For
a more detailed description of suggested sample collection methods, see Appendix B.
8-21
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Pollutant
Monitored
Chloroform
2,3,7,8-TCDD and
2,3,7,8-TCDF
Chlorinated
phenolic
compounds
AOX
Container
Glass vial with
Teflon septum
Amber glass
bottle with
Teflon lid liner
Amber glass
bottle with
Teflon lid liner
Amber glass
bottle with
Teflon lid liner
Preservative(a)
3 granules (lOmg)
Na2S2O3 per vial, 2
drops HC1 per vial,
4°C
Na2S2O3, 4°C
Na2S2O3, H2SO4 to
pH 2-3, 4°C
Na2S2O3, HNO3 to
pH 2-3, 4°C
Sample
Volume
12x40mL
each
2x1,000
mL
3 x 1,000
mL
500 mL
Collection Method
•Grab (2 vials every 4 hours)
•24-hour composite prepared
by lab
•Grab (1 every 4 hours) or
continuous automatic
composite
•24 -hour composite
(a)Note: sodium thiosulfate (Na2S2O3) is required only if free chlorine is present in the wastewater.
are the
Under the permitting regulations at 40 CFR § 122.44(1), NPDES permits must require mills to
monitor regulated pollutants using the analytical methods approved for those pollutants, under 40
CFR § 136. EPA has established analytical methods for each pollutant regulated under Subparts B
and E (62 FR 48394, 63 FR 18504 and 18723). Note that Method 1613, for TCDD and TCDF,
was promulgated on September 15, 1997 (62 FR 48394). In addition, Method 1650, for AOX, and
Method 1653, for chlorinated phenolic compounds, were promulgated as Appendix A to Part 430
(63 FR 18504 and 18723 (April 15, 1998)). These methods will be incorporated into 40 CFR
§ 136 when it is next published. Table 8-6 lists the appropriate analytical test method for each
regulated pollutant.
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Table 8-6; Analytical Methods
Pollutant
Tetrachlorocatechol
Tetrachloroguiacol
Trichlorosyringol
4,5,6-trichloroguaiacol
3,4,6-trichlorocatechol
3,4,5-trichlorocatechol
3,4,5-trichloroguaiacol
2,3 ,4,6-tetrachlorophenol
3,4,6-trichloroguaiacol
Pentachlorophenol
2,4,6-trichlorophenol
2,4,5-trichlorophenol
2,3,7,8-TCDD
2,3,7,8- TCDF
Chloroform (1)
AOX
Method
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1653
1613
1613
1624B
1650
Minimum Level
5.0 ng/L
5.0 ng/L
2.5 ng/L
2.5 ng/L
5.0 ng/L
5.0 ng/L
2.5 ng/L
2.5 ng/L
2.5 ng/L
5.0 ng/L
2.5 ng/L
2.5 ng/L
10 pg/L
10 pg/L
lO^g/L
20ng/L
(1) Other approved EPA methods for chloroform are Methods 601 and 624, and Standard Methods 6210B and
6230B.
What is the Minimum Level of Detection?
For various pollutants, EPA has established ELG&S that are expressed as less than the Minimum
Level (
-------
the first situation, the laboratory could have used the method specified but referred to the
measurement as "detected" although it was
-------
are
In accordance with Section 122.44(i)(2), you must require mills to report the results of compliance
monitoring at least once per year. You may require mills to submit the results of more frequently
if you wish. As a result of new monitoring requirements for mills with operations in Subpart B and
E, the reports:
1. Must include results of monitoring at the bleach plant for 15 chlorinated
pollutants;
2. Must include results of monitoring final effluent for AOX (bleach plant effluent
for indirect dischargers);
3. Must include BMPs reporting (discussed in Section 9); and
4. Should include continuous bleach plant flow measurements.
All monitoring records must be kept for a period of at least 3 years and made available to
inspectors.
to of in of
Mills that certify in their permit application that they use exclusively totally chlorine-free (TCP)
bleaching processes (40 CFR §430.02(a) and (c)-(e)) are not subject to minimum monitoring
frequencies. EPA believes it is appropriate to exclude TCP mills from minimum monitoring
requirements for chlorinated compounds because EPA does not expect TCP bleaching processes to
produce chlorinated compounds. The mill would need to notify you if in the future they decide to
use chlorinated chemicals in the bleach plant operations (following a certification as TCP). In that
event, you must reopen the permit and establish new permit limits that reflect the new process and
include minimum monitoring frequencies. Mills entering the Voluntary Advanced Technology
Incentives Program (VATIP) also qualify for reduced monitoring frequencies. For details, see
Section 8 and Section IX.B.2 of the Preamble (63 PR 18609-18610).
EPA has proposed to allow mills to demonstrate compliance with chloroform limitations by
certifying that they use ECF bleaching processes (63 PR 18796). If this proposal is promulgated,
you may reduce or eliminate chloroform monitoring at some mills. Final action has not been
taken on this proposal as of the date of publication of this document.
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For direct dischargers, you must establish NPDES permits that contain chlorinated pollutant permit
limits based on the newly promulgated BAT ELGs on the date the NPDES permit is issued. Under
the Clean Water Act, the NPDES permit must require immediate compliance with those new
limitations (see CWA Section 301(b)(2)(C)-(F)). Therefore, as a matter of law, NPDES permits
cannot include a compliance schedule for the achievement of the new chlorinated pollutant permit
limits.
For indirect dischargers, however, the Clean Water Act imposes different compliance
requirements. Under CWA Section 307(b)(l), existing indirect dischargers must comply with
applicable pretreatment standards by the date specified in such standards, with the time for
compliance not to exceed three years from the date of promulgation. As specified in the
regulation, existing indirect dischargers subject to Subparts B or E must comply with pretreatment
control limits based on the newly promulgated PSES on or before April 16, 2001 (see 40 CFR
§430.26(a) and §430.56(a)).
EPA strongly urges you to require mills to meet permit limits for all pollutants on the date the
NPDES permit is issued. Since the statutory deadline for BAT passed in 1987, Agency guidance
has stressed the importance of prompt modification of permits to incorporate more stringent
limitations, focusing on those facilities that are not already in compliance with the new effluent
limitations guidelines or on water bodies not complying with water quality standards. The
technology basis of the final rule, ECF bleaching, was key to the proposed rule, published
December 17, 1993, and has not changed since that time. Therefore, the industry has been on
notice regarding ECF bleaching for more than five years. Mills have had little reason to delay all
compliance activities until the final rule was signed (November 14, 1997) and no reason to delay
any compliance activities beyond that date. Allowing other mills to receive additional time is
unfair and undermines the effectiveness of the VATIP. For all practical purposes, most facilities
8-26
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are capable of demonstrating compliance within this time-frame. In fact, some mills already
employ several (or all) of the model process technologies that form the basis of BAT.
Some mills, however, may indicate that they need additional compliance time to implement several
(or all) of the model process technologies to comply with the new ELGs for chlorinated pollutants.
For these mills, you may exercise your enforcement discretion by either: 1) issuing a punitive order
with a daily fine that accumulates or escalates over time until the mill comes into compliance; or 2)
issuing an administrative order accompanying the permit that authorizes additional time for
compliance.
You should evaluate requests for additional compliance time on a case-by-case basis. You should
work closely with each facility, reviewing all materials and data that supports a mill's decision to
implement a technology. (EPA reiterates, however, that a mill whose permit is reissued after April
15, 1999, is unlikely to be able to make a reasonable case that it needs additional time for
compliance in view of the length of time it has been on notice of the BAT requirements to which it
would be subject.)
are for B
Remember, EPA does not mandate the implementation of specific model process technologies to
achieve the ELGs. Rather, mills currently incapable of achieving the effluent limitations and
guidelines and standards may choose to implement any process technology or effluent controls that
will enable the facility to comply with permit limits. Therefore, in the rare instances when
additional compliance time is appropriate, you need to understand the basis for the additional time.
To do this, you need to understand the implementation requirements of each model process
technology to help you establish an appropriate administrative order for additional compliance
time. You also need to determine how much progress the facility has made in implementing a
process upgrade. They may have completed engineering studies and the procurement process. In
this case, they would not need the complete time discussed below. (Note: mills may implement
other process technologies. In this case, you should review mill plans to determine an appropriate
administrative order.)
Of the model process technologies that form the basis of the revised regulation, the following may
require significant implementation time in some cases:
1 100% substitution of chlorine dioxide;
-j Effective brown stock washing;
-j Closing brown stock pulp screen room;
1 Elimination of hypochlorite;
j Oxygen and peroxide enhanced extraction; and
~i High shear mixing.
You should note that the minimum implementation time associated with the model process
technologies that require construction activities is at least 6 months. This minimum
implementation time allows for sufficient engineering studies that must be performed prior to
construction. Some process technologies, such as installation of oxygen and peroxide enhanced
extraction, do not need extensive procurement and construction periods. For several of the process
technologies, however, such as new brown stock washing systems, new chlorine dioxide towers, or
8-27
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oxygen delignification systems, fabrication of appropriate equipment designed to meet the mill's
specific requirements may require up to a year. However, facilities may expedite implementation
schedules by performing most of the site construction activities while they are waiting for their
equipment to be fabricated and delivered.
Oxygen delignification is not one of the model process technologies that forms the basis of BAT;
however, a facility may decide to install oxygen delignification to ensure it meets environmental
regulations and to benefit from reduced operating costs. Consequently, a discussion of the time
necessary to install oxygen delignification is included in this section.
Table 8-7 summarizes reasonable implementation times for the EPA model process technologies
that require significant time. The major construction elements of each model process technology
are also included in the table. The information discussed is based on actual project data collected
by EPA. These time requirements are discussed in detail, below. You should note that the time
periods shown in Table 8-7 are for individual process technologies. In those cases, where more
than one major process technology is necessary, the time periods presented are not necessarily
additive and should be adjusted when appropriate phases of these projects can be combined.
100% substitution of chlorine dioxide. Full implementation of 100 percent substitution could
take between 12 to a maximum of 24 months from the time that preliminary engineering studies are
started. The amount of time depends on the scope of the project. If a facility currently uses 50
percent chlorine dioxide substitution, the facility may only need to expand the capacity of the
existing chlorine dioxide generator, which will take not more than 12 months. For a facility that
employs less than 50 percent substitution, the mill could need 18 months to replace (or augment)
the existing chlorine dioxide generator with a new chlorine dioxide generator with increased
capacity. A facility that does not perform any chlorine dioxide substitution could need 24 months
to construct a new chlorine dioxide generator and to install chlorine dioxide bleaching towers with
appropriate metallurgy. As a general guide, 50% substitution distinguishes mills that need to
expand the chlorine dioxide generator from mills that need to install a new unit. A few pre-1970
mills operate chlorine dioxide generators, such as R-2, Mathieson or Solvay processes. These
mills may require up to 18 months to install a new chlorine dioxide generator to replace the
outdated equipment.
Effective brown stock washing. Facilities may decide to upgrade brown stock washing systems
or install new brown stock washing systems to minimize the amount of pulping liquor carried over
to the bleach plant with the pulp. Facilities that decide to upgrade existing brown stock washing
systems by adding an extra stage to the existing washing equipment are capable of implementing
this modification within 18 months from the time that preliminary engineering studies are started.
Facilities that decide to completely replace the existing washing system could need up to 24
months.
Closed brown stock pulp screen room. Some facilities may opt to close the screen room to
optimize wash water use and to prevent the overflow of decker filtrate to the sewer. Some
facilities configure a closed screen room so that it operates like an extra brown stock washing
stage. Installation of this model process technology at most facilities could be accomplished in
less than 12 months.
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Elimination of hypochlorite. Facilities that perform hypochlorite bleaching could need up to 24
months to engineer and implement bleaching changes that allow elimination of hypochlorite. For
some facilities, particularly those with short bleaching sequences that do not use chlorine dioxide
at all (e.g., CEH), eliminating hypochlorite may require replacement of the hypochlorite bleaching
tower with a new chlorine dioxide tower, washer, and auxiliaries made of materials resistant to the
more corrosive environment of chlorine dioxide bleaching. Some facilities may be able to modify
the bleaching chemical additions to other stages (i.e., adding oxygen and/or peroxide to the first
extraction stage) and abandon the hypochlorite stage, rather than replacing it. This may apply to
mills with a CEHDED-type of bleaching sequence. This change may be accomplished in a matter
of months, with little or no procurement and construction time.
Oxygen and peroxide enhanced extraction. Facilities may opt to install oxygen and/or peroxide
enhanced extraction (Eo, Ep, or Eop) equipment to eliminate hypochlorite bleaching or to reduce
the amount of chlorine dioxide required for bleaching. Installation of oxygen and peroxide
enhanced extraction can take up to 8 months because of the need to install either an upflow
extraction tower or a downflow tower preceded by a small upflow pre-retention tube to supply
pressurized oxygen.
High shear mixing. To realize the full benefits of 100 percent chlorine dioxide substitution,
oxygen-enhanced extraction, and oxygen delignification on the bleach plant effluent quality, the
pulp and bleaching agents must be well-mixed and the chemical addition rate controlled as
precisely as possible. New mixers are normally installed when mills increase chlorine dioxide
substitution to 100%, install oxygen enhanced extraction, and/or install oxygen delignification. No
additional installation time is necessary for installing new mixers because they are integral parts of
the aforementioned upgrades.
Oxygen delignification. Facilities with outdated process equipment that face major process
changes to comply with the regulations may decide to install oxygen delignification. To
implement this technology, facilities need to install an oxygen reactor (with appropriate mixing and
control) for use prior to the chlorine dioxide bleaching stages. In addition to the reactor, facilities
need to include a post-oxygen washing system and oxidized white liquor equipment. Design and
installation of oxygen delignification can be completed in 24 months. Concurrent upgrades in
brown stock washing and screening are often required, and can be implemented in the same time
frame. (Note: facilities that decide to install this process technology may enter the Voluntary
Advanced Technology Incentives Program discussed in Section 8, which provides extended
compliance time.)
Permitting authorities should note that Subpart B facilities do not need time to implement the
following model process because these technologies do not require construction, have been
implemented throughout the industry within the past few years, or have been part of industry
operation for many years (i.e., biological treatment):
• Use of TCDD- and T CDF-precursor-free defoamers;
• Use of strategies to minimize kappa; and
• Efficient biological wastewater treatment.
8-29
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' ' *"^.7'.t
•ie
Model Process Technology
Major Construction Elements (a)
Reasonable Project
Duration
100% Chlorine Dioxide Substitution
a) >50% substitution at a mill that uses an R3 or
SVP generator
b) <50% substitution (or mills that do not use R3
or SVP generators that need to increase capacity)
c) 0% chlorine dioxide use on mill site.
• upgrade existing chlorine dioxide generator to expand capacity.
• installation of new chlorine dioxide generator
• upgrade mixing and process control systems
• additional C1O2 storage facilities
• installation of new chlorine dioxide generator, including sodium chlorate unloading
and storage facilities
• upgrade mixing and process control
• additional C1O2 storage facilities
• installation of new corrosion- resistant chlorine dioxide bleaching tower
12 months
18 months
24 months
Effective Brown Stock Washing Systems
a) Upgrade existing system
b) Installation new system
Closed Screening Room
• installation of extra washing stage
• installation of new process unit (including screens)
• replace atmospheric screens with pressure screens
18 months
24 months
12 months
Elimination of Hypochlorite
a) 1) (CD)EHD, or similar, for softwood
furnish
2) bleaching sequences with two H stages
and only one, or no, chlorine dioxide
stages
3) CEH
b) (CD)EHDED, or similar
Oxygen and Peroxide Enhanced Extraction
Oxygen Delignification
• replace H stage with D stage
• installation of corrosion-resistant chlorine dioxide bleaching tower
• mixing and process control systems
• increase bleaching chemical in other stages to compensate for the elimination of H
• installation of upflow extraction tower or a downflow tower preceded by a small
upflow retention tube
• high shear mixers
• oxygen reactor
• post-oxygen washing system
• mixing and control systems
• white liquor oxidizing equipment
24 months
0 months
8 months
24 months
(a) Does not include minor elements such as pumps, fans, piping, etc
8-30
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Compliance Schedule Examples
The text box below presents several examples of how you may determine compliance schedules for
Subpart B existing dischargers. For the purposes of these examples, it is assumed that facilities
will implement all model process technologies that are not currently in place.
t
I
^
r
c
(
r
r
"he table b
[he table b
o impleme
probably w
tudies to c
slow presents the status of five example mills:
Mill
A
B
C
D
E
Effective
BSW?
N
N
Y
N
Y
Closed
Screening
Room?
N
N
Y
Y
Y
EC/OD?
N
N
N
N
N
Bleach
Sequence
CEH
D/CEHDED
D/CED
DEDED
DEopDD
% C1O2
Substitution
0%
45%
65%
100%
100%
slow shows the model process technologies the mills will implement, assuming that the mills decide
at all of the model process technologies. The table includes an estimate of the amount of time that
ould be needed in order to implement the processes, from initiation of preliminary engineering
ammissioning of equipment.
Model Process Technology
100% Substitution
Effective Brown Stock Washing
Closed Screening Rooms
Eliminate H
Eop
Oxygen Delignification
Compliance Time Frame
Mill A
/
/
/
/
/
/(a)
<24 months
MillB
/
/
/
/
/
<18 months
MillC
/
/
/
<12 months
MillD
/
/
/
0-24
months (b)
MillE
0 months
a) Because Mill A faces significant process changes to comply with BAT, Mill A decided to install oxygen delignification to benefit from
educed operating costs and further environmental improvement. The mill may decide to enroll in VATIP to take advantage of an extended
ompliance time.
3) Mill D may be able to meet BAT limitations because the mill employs complete substitution; therefore, immediate compliance with new
egulation would probably be appropriate. However, if the mill demonstrates installation of upgraded or new brownstock washing systems are
equired to meet AOX ELG, an appropriate compliance schedule could be 12 to 24 months. ]
8-31
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the
The owner or operator of a new source subject to Subpart B or E must install and have in operating
condition, at "start up," all pollution controls necessary to meet the applicable NSPS/PSNS before
beginning discharge. The mill must meet permit limitations based on those standards within 90
days of commencing discharge (see 40 CFR §122.29(d)(4)).
Do for Air for
Mills with operations in Subparts B and E must comply with air regulations, as well as the
ELG&S. Under Maximum Achievable Control Technology (MACT) - based NESHAPs, these
mills must reduce air emissions from bleaching systems, pulping systems, and kraft pulping
process condensates. EPA has developed compliance schedules for air regulations that provide
sufficient time for mills to resolve the cross-media technical issues. This section discusses the
compliance schedule issues that overlap for MACT and BAT. For more information on the
applicability of the MACT rules, see The Pulp and Paper NESHAP: A Plain English Description.
Mills with operations in Subparts B and E must comply with the air regulations established for
bleaching systems by April 15, 2001. Because many mills will modify their bleaching processes to
comply with BAT and PSES, EPA feels this three-year compliance period provides individual
mills enough time to install air controls subsequent to installing any appropriate bleaching process
equipment. To comply with MACT requirements, mills must achieve a 99% reduction of all
chlorinated hazardous air pollutants (HAPs), except chloroform, by installing closed vent systems
on the bleaching system.
The MACT technology basis for chloroform emission control is complete chlorine dioxide
substitution and elimination of hypochlorite bleaching. As discussed earlier, these two process
changes are also integral elements of the technology basis for the effluent limitation guidelines and
standards. As a result, mills must demonstrate compliance with the chloroform emission standards
by meeting the applicable BAT and PSES effluent limitations guidelines and standards.
For mills entering VATIP, bleaching system compliance requirements are relaxed by up to three
additional years so that these mills are required to demonstrate compliance no later than April 15,
2004 (see Section 9).
Mills with operations in Subparts B and E are allowed under the air regulation up to eight years to
install controls for high-volume/low-concentration (HVLC) gas streams from the kraft pulping
process, which include HVLC gases collected from brownstock washing systems and oxygen
delignification (40 CFR §63.440). Although oxygen delignification is not included as part of the
BAT technology basis, EPA established an the eight-year compliance period to encourage mills to
install advanced pollution prevention technologies to reduce toxic air emissions and water
pollutant discharges from pulping processes.
Process
Some mills may opt to use biological treatment (i.e., "hard-piping") as an option to comply with
the standards established for kraft pulping condensates by April 15, 2001. The air regulations
8-32
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require these mills to achieve a 92% reduction in HAPs by weight. By sending kraft pulping
condensates to the wastewater treatment plant, mills will contribute loadings of conventional
pollutants, particularly BOD5, to the wastewater treatment plant. However, you should not adjust
conventional pollutant limitations that are based on BPT and a mill's production.
Note that mills choosing this option must conduct a third type of monitoring program at the
wastewater treatment plant. In addition to performing final effluent monitoring and BMP
monitoring (see Section 8), these mills must conduct wastewater treatment monitoring to ensure
92% HAPs reduction as required by 40 CFR §63.453.
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STEP1
Pre-Application Activities
STEP 2
Reviewing Permit Applications
STEP 3
Developing Permit Limits
STEP 4
Developing Monitoring Requirements
STEPS I
Developing Compliance Schedules I
STEP 7
Extending Standard Conditions
for Bleach Plant Permit Limits
I"' •
Develo|iin< i ,• ;ial Conditions
Special conditions are included in permits to require facilities to implement additional non-
numerical measures of control that reduce pollutant discharges. EPA recommends that you
include the following two special conditions in the permit of each mill with operations in Subparts
B and E:
1) Reopener clause. A reopener clause does not provide an additional measure of control.
However, by including a reopener clause in permits, you may revise a permit at any time
during its duration to include more stringent numerical limits during the term of the
permit. This is especially important for:
a) COD permit limits for mills with operations in Subpart B and COD,
chloroform, and AOX permit limits for mills with operations in Subpart E. EPA
has reserved ELGs for these pollutants at this time. EPA suggests that you
establish permit limits for these pollutants using BPJ or, at a minimum, require
mills to perform monthly monitoring and report the results. Where a facility has
current COD effluent data, a BPJ permit limit could be set using the existing
COD discharge concentrations. Monitoring of effluent COD is recommended so
that you will have a basis (and baseline data) for developing a COD limit for the
mill in the future and to provide COD data for helping the mill to develop a
pollution control strategy. When EPA promulgates ELGs for these pollutants,
the reopener clause will allow you to revise the permits to include limits based
on ELGs.
b) VATIP requirements (for those mills choosing to enroll). Mills enrolling in
VATIP will rebuild and update their pulping and bleaching operations. By
including the reopener clause in permits, you may update limits to reflect
improved effluent quality that results from these more extensive voluntary mill
renovations. This is discussed in more detail in Section 10.
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2) BMP requirements. Mandatory BMPs are included in 40 CFR 430. Therefore, permits
for mills with operations in Subparts B and E must include BMP requirements as a special
condition. For a discussion of BMPs, refer to Section 9. Appendix C presents sample
language that you may include in the permit.
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EPA's permitting regulations provide standard conditions (i.e., "boiler plate" conditions) that are
typically included in permits. These conditions, which are found in Section 122.41 and 122.42,
include legal, administrative, and procedural requirements of the permit that support the numeric
permit limits. Because mills with operations in Subparts B and E are subject to ELGs that require
compliance in bleach plant effluent, EPA recommends you extend the following standard
conditions to include situations specific to bleaching process operations at these mills:
1) Require daily bleach plant flow measurements to ensure mills do not achieve compliance
with their permit limits by increasing their bleach plant effluent flow rate during
monitoring. Daily flow measurements will enable inspectors to determine whether
monitoring occurred during representative mills operations. You should require mills to
keep records of these measurements for three years.
2) Extend upset provision covered under 122.41 (n) to include pulping and bleaching process
upsets that affect compliance with bleach plant permit limits. Section 122.41(n) defines
an upset as "an exceptional incident in which there is an unintentional and temporary
noncompliance with technology based permit effluent limitations because of factors
beyond the reasonable control of the permittee." Because some of the ELGs require
compliance in bleach plant effluent, process upsets that affect pulping and bleach plant
operations are subject to upset provisions. Upset provisions are not meant to cover
improper operation and maintenance, but to provide relief in the event of unusual,
unforseen circumstances over which the mill operator has no control. A few process
upsets that could affect pulping and bleach plant operations that would be covered under
this provision include:
a) major power outages,
b) tank failure due to metal fatigue,
c) flooding of operations, and
d) lightning strikes.
For a list of additional standard conditions that may apply to the facility you are permitting, you
may refer to Chapter 9 of the U.S. EPA NPDES Permit Writer's Manual (EPA-833-B-96-003).
8-36
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This section describes actions you must take to implement best management practices
(BMPs) and suggests some areas where you may choose to go beyond the national
regulations. This section also describes the mandatory components of the BMPs,
focusing on the BMP monitoring requirements and the BMP plan, and outlines the BMP
compliance schedule. For additional guidance on implementing BMPs, refer to Technical Support
Document for Best Management Practices for Spent Pulping Liquor Management, Spill
Prevention, and Control (EPA 821-R-97-011).
BMPs establish practices, rather than numerical limits, that reduce the release of toxic,
conventional, and nonconventional pollutants to receiving waters. Under CWA 402(a)(l) and 40
CFR §122.44(k), BMPs can be imposed on a case-by-case basis. However, EPA decided to
implement the BMP program by regulation for Subparts B and E to ensure that mills with
operations in those subparts have effective BMP programs and to ensure uniform application of
regulatory requirements across industry segments. You may, subject to state law, require more
stringent BMPs than those required by the federal regulations.
The principal objective of BMPs is to prevent losses and spills of spent pulping liquor (i.e., black
liquor) from process equipment; the secondary objective is to contain, collect, and recover, or
otherwise control, spills, losses, and intentional diversions that do occur. BMPs also apply to
turpentine and soap (pulping byproducts), for mills that generate these materials.
BMPs require mills to implement practices intended to prevent losses and spills of spent liquor.
EPA has identified equipment and procedures that could be used to implement effective BMPs;
however, EPA intends that mill owners and operators should have maximum flexibility to address
management and control of spent pulping liquor at their mills, within the context of the general
implementation requirements. Therefore, it is up to mill owners and operators to decide which
equipment and control strategies are appropriate and effective at their mill.
9-1
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Do i
BHP Plan
You must incorporate BMP requirements for new and existing direct dischargers as special
conditions in NPDES permits (see 40 CFR §430.030). Appendix C contains example permit
language. For indirect dischargers, BMPs are pretreatment standards that must be included in
updated pretreatment agreements.
of BMP to 11 E
EPA has promulgated BMPs only for Subparts B and E but has proposed BMPs for mills with
chemical pulping operations (covered in Subparts A, C, D, F, and H). You may use the BMP
requirements for Subparts B and E as guidance in issuing permits containing BMPs for mills with
operations in other subparts. Similarly, for indirect dischargers, you may impose BMPs as local
limits for mills with production in subparts for which BMPs have not yet been established.
of BMP to Fresh
The BMP requirements specified by EPA apply to spent pulping liquors, soap, and turpentine.
Depending upon mill circumstances and the likelihood of losses, you may use BPJ to decide if
white or green liquors (Subpart B) or fresh sulfite pulping liquor (Subpart E) should be included in
BMPs (see below).
The rule requires mills to develop and implement a BMP plan (40 CFR §430.03(d)). The BMP
plan documents each mill's approach to achieve full BMP implementation, and must:
« Contain a detailed engineering review of the mill;
« Specify procedures and practices to be implemented to meet the requirements of
every mandatory component;
« Detail the construction that the mill determines is necessary to meet the
mandatory components, including the construction schedule; and
« Describe the monitoring program that will be used to meet the BMPs monitoring
requirements (discussed in detail in Section 9).
E n gi ri n g Rev iew
The rule requires each mill to conduct a detailed engineering review of its pulping and chemical
recovery operations — including but not limited to process equipment, storage tanks, pipelines and
pumping systems, loading and unloading facilities, and other appurtenant pulping and chemical
recovery equipment in spent pulping liquor, soap, and turpentine service — to determine potential
leaks, spills, and intentional diversions of spent pulping liquors, soap, and turpentine during the
following periods of operation (40 CFR §430.03(d)(2)):
-..' Process startups and shutdowns;
••> Maintenance;
i Production grade changes;
-..' Storms or other weather events;
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« Power failures; and
« Normal operations.
As part of the engineering review, mills must determine whether:
« Existing spent pulping liquor containment facilities have enough capacity to
collect and store anticipated intentional liquor diversions as well as potential
spills.
« Continuous, automatic monitoring systems are needed to detect and control leaks
and spills of spent pulping liquor, soap, and turpentine;
« Process wastewater diversion facilities are needed to protect end-of-pipe
wastewater treatment facilities from adverse effects of spills and diversions of
spent pulping liquors, soap, and turpentine;
« Potential for contamination of storm water from the immediate process areas
exists; and
« Segregation and/or collection and treatment of contaminated storm water from
the immediate process areas is appropriate.
of
The regulation requires mills to amend the BMP plan whenever there is a change in mill design,
construction, operation, or maintenance that affects the potential for leaks and spills from the
immediate process areas (40 CFR §430.03(e)).
Each mill must review and evaluate the BMP plan five years after it is first prepared and, unless
there are substantial changes necessitating more frequent review, once every five years thereafter.
The mill must amend the BMP plan within three months of the review if the mill determines that
any new or modified management practices are necessary to reduce significantly the likelihood of
spills and leaks.
of
The BMP plan, and any amendments, must be reviewed by the senior technical manager at the mill
and approved and signed by the mill manager. Any person signing the BMP plan must certify to
you under penally of law that the BMP plan has been prepared in accordance with good
engineering practices and in accordance with the regulation. You are not required to approve the
BMP plan or any future amendments (40 CFR §430.03(f)).
The rule requires mills to maintain a complete copy of the current BMP plan on site (40 CFR
§430.03(g)). As specified in the rule, mills must maintain records that demonstrate compliance
with BMP implementation requirements. The mill must maintain the following records for three
years from the date they are created:
« Records tracking repairs performed as part of the mill's repair program
(§430.03(b)(2));
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« Records of initial and refresher training (40 CFR §430.03(b)(4));
« Reports of reviews of spills and intentional diversions (40 CFR §430.03(b)(s);
and
« Records of wastewater monitoring to detect leaks and spills, track the
effectiveness f the BMPs, and detect trends in spent pulping liquor losses (40
CFR §430.03(b)(10) and (h)).
The BMP plan and records must be made available to you or your authorized enforcement
personnel upon request.
the for
The rule outlines the components of BMPs considered integral to preventing leaks and spills of
spent pulping liquors, soap, and turpentine (40 CFR §430.03(c)). Under the rule, mills must
implement the following BMPs:
1. Return spilled or diverted spent pulping liquors, soap, and turpentine to the
process to the maximum extent practicable as determined by the mill.
2. Establish a program to identify and repair leaking equipment. The program must
include:
« Regular visual inspections of process areas with spent pulping liquor,
soap, and turpentine service equipment;
« Immediate repairs of leaking equipment (if not immediate, then the mill
must control the leak and repair the equipment as soon as possible);
« Identification of conditions under which production will be curtailed or
halted to repair leaking equipment or to prevent leaks and spills; and
« A system of tracking repairs over time to identify equipment that may
need to be upgraded or replaced because of frequency and severity of
leaks, spills, or failures.
3. Operate continuous, automatic monitoring systems to detect and control leaks,
spills, and intentional diversions. These monitoring systems may be integrated
with the mill process control system and may include high-level monitors and
alarms on storage tanks, and conductivity (or pH) monitors and alarms in process
areas, process area sewers, process wastewater, and the wastewater treatment
plant.
4. Establish a training program for operators, maintenance personnel, and other
technical and supervisory personnel who operate, maintain, or supervise the
operation and maintenance of equipment in spent pulping liquor, soap, and
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turpentine service. Conduct refresher training at least annually. The training
program must be documented.
5. Prepare a brief report that evaluates each spill and any intentional diversion that
are not contained at the immediate process area. The report must describe the
equipment involved, the circumstances leading to the incident, the effectiveness
of the corrective actions taken to contain and recover the spill or intentional
diversion, and plans to develop any necessary changes to equipment and
operating and maintenance practices to prevent recurrence. The annual refresher
training must include discussion of these reports.
6. Establish a program to review any planned modifications to the pulping and
chemical recovery facilities and any construction activities in the pulping and
chemical recovery areas before these activities commence. This review is to
prevent leaks and spills during the planned modifications and to ensure that
construction and supervisory personnel are aware of possible liquor diversions
and of the requirement to prevent leaks and spills during construction.
7. Install and maintain secondary containment constructed of materials impervious
to pulping liquors for spent pulping liquor bulk storage tanks equivalent to the
volume of the largest tank plus enough capacity for precipitation (e.g., rainfall).
An annual tank integrity testing program, if combined with other containment or
diversion structures, may be substituted for secondary containment of these
tanks.
8. Install and maintain secondary containment for turpentine bulk storage tanks.
9. Install and maintain curbing, diking, or other means of isolating soap and
turpentine processing and loading areas from the wastewater treatment plant.
10. Conduct wastewater monitoring to detect leaks and spills, to track the
effectiveness of the BMPs, and to detect trends in spent pulping liquor losses.
What is Tank Integrity Testing?
Annual tank integrity testing should consist of two components:
1. Annual visual inspections to check for leaks, cracks, corrosion points, paint
peeling bulges, dents, etc., and
2. Ultrasonic thickness (UT) testing.
Mills personnel should perform annual visual inspections and record the results of the inspection.
The frequency ofUT testing is determined by the mill. Factors that should be considered when
determining appropriate testing frequency should include the types of tanks (i.e., pressure versus
atmospheric), tank metallurgy (i.e., carbon steel versus stainless steel), and age. Table 9-1
summarizes acceptable UT testing frequencies based on these factors. Of course these factors vary
9-5
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from mill to mill and from tank to tank. For those mills that do not perform UT testing, they may
also refer to the American Petroleum Institute API 653 standards or the American Standards for
Testing Materials ASTM G158 standards for information regarding the use of UT testing of
metals. (Note: some mills currently perform UT testing on black liquor storage tanks at a specified
frequency to comply with their insurance policies.)
I abi
II ,'iii'i 'Ill I '•ifi!< Ill '.; ullliifi"! Ill if
Type of Tank
Pressure Tank
Atmospheric
Tank
Tank Metallurgy
Carbon Steel
Stainless Steel
Carbon Steel
Stainless Steel
Age
< 1 5 years
> 1 5 years
< 1 5 years
> 1 5 years
< 1 5 years
> 1 5 years
< 1 5 years
> 1 5 years
UT Testing Frequency(a)
every 2 years
every year
every 4 years
every 2 year
every 5 years
every 3 years
every 10 years
every 5 year
,-r. lllli'
IP
There are two types of monitoring associated with BMPs: 1) monitoring of tanks, sumps, and
sewers as an element of the BMP program, and 2) monitoring of BMP effectiveness.
of " , • " of
As discussed below, the rule requires that the mill assess the possible sources of spent pulping
liquor, turpentine, and soap releases to determine what additional spent pulping liquor containment
facilities, monitoring systems, and operating practices may be necessary to detect and control
leaks, spills, and intentional diversions. Some mills may implement an effective BMP program by
adding conductivity or color monitors at strategic locations within the mill. By placing monitors in
sumps, tanks and sewers, the mill would contain some spills and detect leaks early, thereby
reducing the amount of spent pulping liquor reaching the wastewater treatment plant. The BMP
plan should explain the rationale for the number and placement of such monitors as well as
describing the response to alarm levels for these monitors. Explanation of the function of and
response to monitors and alarm eaves should be part of the BMP training program.
of
The rule requires a mill to collect daily measurements of a parameter at the influent to wastewater
treatment (or some other appropriate location as described below) to monitor the performance of
the BMP program (40 CFR §430.03(i)). This monitoring is intended to systematically measure
progress in reducing losses of spent pulping liquor, turpentine, and soap by effectively using BMPs
9-6
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and to assure that the BMP program continues to be effective over time. This monitoring program
is not a substitute for spill and leak detection monitoring that is conducted as part of the BMPs.
Action Levels
To establish an effective monitoring system, the rule requires existing dischargers to conduct an
initial six-month monitoring program to characterize wastewater treatment influent (40 CFR
§430.03(h)). Based on the results of this initial monitoring program, the mill will determine action
levels. An action level is a pollutant loading determined by statistical analysis of six months of
daily measurements (40 CFR §430.03(b)(l)). The action levels must consist of a lower action
level, which if exceeded, will trigger investigation requirements, and an upper action level, which
if exceeded, will trigger corrective action requirements. The Technical Support Document for Best
Management Practices for Spent Pulping Liquor Management, Spill Prevention, and Control
provides an example based on actual mill data and suggests that the 75th- and 90th-percentile
values might be appropriate levels for investigative and action responses, respectively. The mills,
however, may establish alternative action levels based on an examination of the variability of the
specific parameter they have chosen.
The rule requires mills to complete a second six-month monitoring program to determine revised
action levels as soon as possible after they have implemented the BMP requirements outlined
earlier in this section (40 CFR §403(h)(4)). These revised action levels will then be used to
measure full BMP effectiveness implementation.
Because new mills must implement all BMP requirements when they start operation, the rule
requires new mills to complete one six-month monitoring program to develop the lower and upper
action level limits based on the results of that program (40 CFR §430.03(h)(5)).
Monitoring Pollutant Parameters
Although mills are required to implement a BMP monitoring program, they have flexibility in
selecting the specific parameter to be measured. EPA recommends using COD because of its
sensitivity to turpentine, soap, and spent pulping liquor. However, the rule allows Total Organic
Carbon (TOC) and 24-hour averages of color or specific conductivity as alternatives. For mills
that do not pulp softwood furnish or mills that effectively isolate turpentine or soap from all
pathways that could enter the wastewater treatment plant, mills may select alternatives to COD.
(See Technical Support Document for Best Management Practices for Spent Pulping Liquor
Management, Spill Prevention, and Control for more details.)
Direct dischargers must conduct monitoring at the point influent enters the wastewater treatment
system, whereas indirect dischargers must conduct monitoring at the point of discharge to the
POTW (40 CFR §430.03(h)(2)). Mills may also sample at locations other than the discharge to the
wastewater treatment plant. For example, a mill may choose to monitor locations "upstream" of
the combined mill influent-to-treatment to better identify the problem areas at the mill (e.g., pulp
mill, chemical recovery operations, and bleach plants), as long as there are no points
"downstream" of the sample points where waters potentially containing spent pulping liquor,
turpentine, or soap enter the wastewater stream.
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Corrective
Whenever monitoring results exceed the lower action level, the rule requires mills to investigate
the cause. Whenever monitoring results exceed the upper action level, the rule requires mills to
take corrective action to bring the wastewater treatment system influent mass loading below the
lower action level as soon as practicable. While exceeding an action level does not constitute a
violation of an NPDES permit or pretreatment standard, failure of the mill to investigate and take
corrective action does (40 CFR §430.03(i)(2)).
Mills are required to report to you the following: a summary of the monitoring results, the number
of times and dates action levels were exceeded, and brief descriptions of any actions taken to
correct the situation. You must establish the frequency of report submissions, but they must be
submitted at least once a year (40 CFR §430.03(i)(4)).
I •. ifv. : •
For existing direct discharges, you must establish NPDES permits that contain the deadlines
outlined in Table 9-2. If one or more of the deadlines has passed at the time a mill's NPDES
permit containing BMP requirement is issued, you must ensure that the permit requires the mill to
immediately comply with the BMP requirement for which compliance dates have passed. For
existing indirect dischargers, pretreatment control agreements must be updated so that BMPs are
implemented by the schedule in Table 9-2.
1 • j '•' !'• Dmpliance Deadlines Schedule for Existing Direct ari
-------
Table 9-3: BMP Compliance Deadlines Schedule for New Sources
BMPs Requirements
Establish action levels
Compliance Deadline
12 months from the commencement of wastewater
discharge
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EPA established the Voluntary Advanced Technology Incentives Program (VATIP) to
encourage existing and new direct dischargers subject to Subpart B to achieve more
stringent ELG&S by implementing advanced pollution prevention controls (40 CFR
§430.24(b)) and §430.25(c)). By enrolling in VATIP, mills receive additional time to
comply with the rule and reduced monitoring requirements (among other incentives). This section
presents the VATIP ELG&S, the extended compliance dates, and the reduced monitoring
requirements. Note that there is no comparable program for mills subject to Subpart E or for
indirect discharging mills. Refer to the Voluntary Advanced Technology Incentives Program
Technical Support Document for more detail.
VATIP comprises three tiers of ELG&S that reflect increasingly more effective levels of
environmental protection that mills can achieve by implementing advanced pollution prevention
technologies. Table 10-1 presents the VATIP requirements for each tier. Existing direct
dischargers are eligible to enroll in any one of the three tiers (Tier I, II, or III) and new direct
dischargers are eligible to enroll in either of the two more stringent tiers (Tier II or III).
Mills can choose to enroll in VATIP on a line-by-line basis. For instance, a mill subject to Subpart
B with more than one fiber line may decide to enroll all or some of its fiber lines in VATIP. Only
those lines enrolling in VATIP are subject to VATIP requirements. For nonparticipating fiber
lines, you must apply BAT, if the mill is an existing source, or NSPS, if the mill is a new source.
Mills may choose to meet VATIP requirements immediately, but they are not required to do so.
Mills have six or more years to meet the requirements of the selected tier. Before that time, you
must apply appropriate conventional pollutant limits and continuously revise permit limits for all
chlorinated pollutants during phases of the VATIP process.
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Tier
Tier I
Tier II
Tier III
Kappa
Number
(Annual
Average)
20 for SW
ISforHW
NA
NA
Filtrate
Recycling
(b)
(b)
(b)
Total Pulping Area
Condensate,
Evaporator
Condensate, and
Bleach Plant
Wastewater Flow
(Annual Average)
NA
lOmVkkg
SrrrYkkg
End-of-Pioe AOX (kg/kits)
Non-TCF (a)
Maximum
for Any
One Day
0.58
0.23
0.11
Annual
Average
0.26
0.10
0.05
TCF
Maximum
for Any
One Day
-------
the •• • • a
In the July 7, 1999 Federal Register (36580-36586), EPA promulgated additional language to the
VATIP requirements that would require mills to prepare a Milestones Plan covering all fiber lines
enrolled in the program to their permitting authority (reserved in Section 430.24(c)). The
milestones plan will reflect how the mill determined how to ultimately achieve the limitations for
their selected tier. The plan will provide you with the information necessary to develop interim
milestones for the mill.
of
The Milestones Plan must describe each technology component or process modification the mill
intends to implement to achieve the VATIP BAT limits. In addition, the plan must include a
master schedule showing the sequence of implementing the new technologies and process
modifications and identifying critical path relationships within the sequence. For each individual
technology or process modification, the Milestones Plan must include:
1. A schedule listing the anticipated date(s) that associated construction, installation, or
process changes will be initiated and completed;
2. The anticipated date that the process or individual component will be fully demonstrated
as operational; and
3. The anticipated reductions in effluent quantity and improvements in effluent quality as
measured at the bleach plant and, for AOX, at the end of the pipe.
For those technologies or process modifications that are not commercially available or
demonstrated on a full-scale basis when the plan is developed, the plan must include a schedule for
research (if necessary), process development, and mill trials. This schedule must show major
milestone dates and the anticipated date the technology or process change will be available for mill
implementation. The plan must also include contingency plans in case any of the technologies or
process modifications specified in the Milestones Plan need to be adjusted or alternative
approaches or processes developed to ensure that the mill will meet the ultimate tier limits by the
dates in the master schedule.
Do 1 ' t
For existing mills that enroll in VATIP, you must establish enforceable permit requirements that
become progressively more stringent over time to ensure that mills achieve performance of the
selected tier. EPA has established three phases to measure mills' progress in complying with these
permit requirements and to ensure their compliance with the selected tier limitations.
••> Initial limitations ("Stage 1");
i Intermediate milestones; and
-..' Ultimate limitations ("Stage 2").
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You should include reopener clauses in the NPDES permit of a mill enrolling in VATIP. This will
allow you to adjust the permit to reflect the results as the mill implements advanced pollution
prevention technologies and improves their effluent quality. Figure 10-1 summarizes the permit
process discussion presented below.
Initial Limitations (Stage 1)
Initial limitations (Stage 1) for each fiber line enrolled in VATIP must reflect either existing
effluent quality (EEQ) or the technology-based limits in the mill's last permit, whichever is more
stringent. EEQ refers to the current levels of chlorinated pollutants in the mill's effluent. For
pollutants limited in bleach plant effluent (e.g., TCDD), you must determine EEQ at the bleach
plant. For AOX, which is limited in the final effluent, you must determine EEQ based on the
loadings attributable to the fiber line enrolled in VATIP (i.e., the fiber line's percentage of
production multiplied by total AOX load). Appendix E presents detailed procedures for
calculating EEQ. Stage 1 limitations ensure that, at a minimum, EEQ is maintained as the mill
moves toward achieving Stage 2 limitations in its selected tier.
You must require mills to meet these Stage 1 limitations immediately by including them in the
permit because the limitations constitute BAT for enrolled fiber lines engaged in the initial phase
of achieving the ultimate limitations (Stage 2). Under the CWA, mills must immediately comply
with BAT promulgated after March 31, 1989 (CWA §301(b)(2)). As discussed in more detail in
the preamble to the rule (63 FR 18600-06), the remaining VATIP limitations and requirements
become BAT over a period of time. The rule requires immediate compliance with those
limitations as well (e.g., the "Stage 2" limitations), but only if they have ripened into BAT. For
example, for Stage 2 limitations for Tier II, that would be April 15, 2009. See 40 CFR
§430.24(b)(4)(n)(B).
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Figure 10-1: Permit Process for Direct Discharges During Each Phase of VATIP
Mills must meet BAT for TCDD, TCDF, chloroform,
and the 12 chlorinated phenolic compunds as
well as Stage 2 VATIP for AOX and kappa numbers.
Tier I
(Existing
Sources Only)
Mills must meet BAT for AOX, TCDD, TCDF,
chloroform, and the 12 chlorinated phenolic
compounds.
Mills must meet Stage 2 VATIP for AOX
and flow reduction for the selected tier
Tier II
(Existing or
New Sources'")
Tier III
(Existing or
New Sources'")
April 15,1999
Stage 1
April 15,2004 Intermediate BAT
Limitations and stage 2 for Tier I
April 15,2009
Stage 2 for Tier II
April 15, 2014
Stage 2 for Tier III
Mills enrolling in VATIP must receive new permit during
this period. Mills may enroll anytime after April 15,1999,
but they may not receive additional compliance time to
meet the deadlines for the selected tier. For those fiber
lines enrolled, permit limits for chlorinated pollutants must
be based on EEQ or the technology based limits in the
previous permit, whichever is more stringent. Enrolled
lines are also subject to conventional pollutant limits.
Non-participating fiber lines are subject to BAT and BPT.
Interim Milestones. Permits may be updated with
narrative or numeric conditions that reflect progress
towards stage 2.
D
'' Note: New sources must comply with VATIP upon commencing operations.
10-5
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Intermediate Milestones
You must establish two sets of interim milestones that are critical in assuring that mills
incrementally improve their effluent quality prior to achieving Stage 2 limits.
1. Intermediate BAT Limitations
You must require existing mills enrolled in all three tiers to comply with interim
limitations equivalent to BAT for the 15 regulated chlorinated pollutants no later
than April 15, 2004. At that time, note that those mills enrolled in Tier I are also
required to fully comply with Stage 2 limitations for AOX and kappa number
limits.
EPA anticipates that mills that enroll in Tiers II or III will achieve limits for
chlorinated pollutants by April 15, 2004, by substantially modifying pulping and
bleaching processes (i.e., installing oxygen delignification, ECF, or TCP). Mills
will most likely install oxygen delignification and ECF or TCP processes before
achieving the wastewater flow objectives to allow them enough time to design,
test, and install emerging or yet-to-be-developed wastewater flow reduction
processes to help meet the Stage 2 limitations.
You should note that some mills required to achieve WQBELs or other ELG&S
equivalent to one or more of the VATIP EPG&S are eligible to enroll in VATIP
and to receive the incentives for achieving all VATIP ELG&S. However, you
must require mills to comply with existing WQBELs and other ELG&S by the
compliance data specified by the applicable law.
2. Interim Milestones
In addition to establishing intermediate BAT limitations, you may wish to
establish interim milestones using the information provided by the mill in their
Milestones Plan and BPJ to ensure that the mill is progressing toward the Stage 2
limitations. These intermediate milestones, which may be expressed as narrative
or numeric conditions in the NPDES permit (40 CFR §430.24(b)(2)), should
reflect progressive steps toward achieving limitations in the mill's selected tier.
Ultimate Limitations (Stage 2)
You must require mills to meet ultimate limitations no later than the effective date of the selected
tier. Remember, new mills must achieve Stage 2 limitations when they commence operation.
Note that, in addition to VATIP ELG&S, mills enrolled in the incentives program must also meet
applicable ELG&S for conventional pollutants (e.g., BOD5, TSS, and pH), as well as BMP
requirements and any appropriate WQBELs.
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are the
Table 10-2 presents the reduced minimum monitoring frequencies established for mills that enroll
in VATIP. You may reduce the monitoring frequency for mills enrolled in VATIP only after they
have met Stage 2 requirements.
During the time between Stage 1, when mills must meet EEQ or the technology-based limits in the
last permit, and Stage 2, you should require all mills that enroll in VATIP to monitor at the
minimum frequencies established for all chlorinated pollutants (see Table 8-4). This monitoring
requirement assures that mills demonstrate that they are consistently achieving EEQ and/or BAT
limitations. Keep in mind that EPA did not establish minimum monitoring requirements for those
mills that certify that they perform TCP bleaching. For these mills, you may use BPJ to establish
monitoring frequencies.
Note that VATIP rewards mills that implement advanced pollution prevention technologies that
reduce the amount of chlorine and chlorine dioxide used during bleaching. For those mills that
certify that they perform advanced ECF bleaching, the required monitoring of TCDD, TCDF,
chloroform, and chlorinated phenolic compounds may be suspended and AOX monitoring may be
relaxed one year after the mill meets Stage 2 limitations.
1 10 2: I- iiiiiiiii mm III for
• d III Ill in VA II IIP
Pollutant
12 chlorinated phenolics pollutants
2,3,7,8-TCDD
2,3,7,8-TCDF
Chloroform
Pollutant
AOX
Minimum Monitoring Frequency
non-ECF (a)
monthly
monthly
monthly
weekly
non-ECF,
any Tier (a)
daily
Advanced ECF (b)(e)
monthly (f)
monthly (f)
monthly (f)
monthly (f)
Advanced ECF -
Tier I (b)
weekly (for 1 year
after achieving
Stage 2)
monthly (for years
2 through 5 after
achieving Stage 2)
Advanced ECF -
Tier II (b)
weekly (for 1 year
after achieving
Stage 2)
quarterly (for years
2 through 5 after
achieving Stage 2)
Advanced ECF -
Tier III (b)
weekly (for 1 year
after achieving
Stage 2)
annually (for
years 2 through 5
after achieving
Stage 2)
TCF (c)
(d)
(d)
(d)
(d)
TCF (c)
(d)
(a) Pertains to any fiber line that does not use exclusively ECF or TCF bleaching operations.
(b) Pertains to any fiber line that uses exclusively Advanced ECF bleaching processes.
(c) Pertains to any fiber line that uses exclusively TCF bleaching processes.
(d) This regulation does not specify a limit for this pollutant for TCF bleaching processes. Use BPJ.
(e) You must determine the appropriate monitoring frequency for these pollutants after one year under 40 CFR
§122.44(i).
(f) The minimum monitoring frequency applies during the initial compliance demonstration period.
10-7
-------
''" ' " ' III,"' •:". ;'.'
EPA recently promulgated MACT-based NESHAPs for the pulp and paper industry (see 63 FR
18399 and 40 CFR Part 63). For bleaching operations at existing sources, control of chloroform
emissions is based on compliance with the BAT ELG&S. Control of other chlorinated HAPs is
based on the use of caustic scrubbing of bleach plant air emissions. Existing sources are required
to comply with the NESHAP no later than April 16, 2001.
EPA was concerned that requiring mills to comply in three years with MACT standards based on
C1O2 substitution would discourage mills from enrolling in the VATIP. This is largely because a
mill that installs or upgrades a C1O2 generator before it installs oxygen delignification is likely to
construct more capacity than it ultimately will need. A mill that has invested in a large C1O2
generator would be very reluctant to abandon a portion of that investment soon afterwards in order
to participate in the VATIP.
To encourage mills to participate, EPA extended the date for compliance with the bleach plant
standards for mills that enroll in VATIP. The NESHAP sets out a two-phased compliance
schedule.
1. Phase One: June 15, 1998 through April 15, 2004. For existing sources enrolled in
VATIP, MACT allows no increase in the existing HAP emission levels from the
papergrade bleaching system—i.e., no backsliding—during the initial period when the mill
is working toward meeting its VATIP BAT requirements. The effective date of the first
phase requirements is June 15, 1998. Mills may not increase their application rates of
chlorine or hypochlorite above the average rates determined for the three-month period
prior to June 15, 1998.
2. Phase Two: After April 15, 2004. For existing sources enrolled in VATIP the mill must
achieve the MACT standard for chloroform emission reduction; it must also apply
controls for other chlorinated HAPs. To comply with the chloroform standard the mill
may either:
a. comply with baseline BAT for all pollutants, or
b. certify that chlorine and hypochlorite are not used in the bleach plant.
All mills that enroll in the VATIP must comply with the second phase of existing source
MACT no later than April 15, 2004.
The MACT rule also allows an extended compliance time for all mills to collect and control
HVLC gas streams from the kraft pulping process (that is, air emissions from brownstock washing
and oxygen delignification). The compliance time is extended from three years to eight years (until
April 17, 2006). This time extension will allow mills to make changes needed to comply with
BAT, such as upgrading brownstock washing and closing pulp screening, prior to collecting and
controlling air emissions from these processes. It will also allow mills to make changes needed to
comply with VATIP, such as installation of oxygen delignification, prior to controlling air
emissions.
10-8
-------
10-9
-------
B
ecause there are complex permitting issues associated with 40 CFR 430, this section
presents case studies showing the development of NPDES permits for mills subject to
BPT and BAT under Subparts B and E. There are nine case studies, which cover a
variety of mill types and complexity. Each case study presents the following:
Example mill's current permit status;
General site description;
Information about mill operations relevant to establishing permit limits;
Step-by-step approach to determining limits for each regulation (e.g., BPT,
BAT); and
Final limits as they would appear in each example mill's permit.
Table 11-1 summarizes the nine case studies to assist you in selecting the one(s) of most interest to
you.
11-1
-------
Tat'. •• "". ". ... • of
Case
Study #
1
2
3
4
5
6
7
8
9
Description of Mill
Bleached kraft mill with multiple products
Papergrade sulfite mill with multiple products
Colocated bleached papergrade kraft and papergrade sulfite
mills with multiple products
Colocated bleached papergrade kraft, thermomechanical, and
secondary deink fiber mills with multiple products
Bleached papergrade kraft mill with multiple products and
seasonal discharge
Bleached papergrade kraft mill with multiple products and one
existing fiber line and one new fiber line
Bleached papergrade kraft mill that discharges to a POTW
Bleached papergrade kraft mill with multiple products and one
existing fiber line and one new fiber line enrolling in VATIP
Bleached papergrade kraft mill with purchased pulp in addition
to an existing fiberline
Discharge
Status (Direct
or Indirect)
D
D
D
D
D
D
I
D
D
Subpart(s)
Covering
Operations
Subpart B
Subpart E
Subparts B and E
Subparts B, G, and I
Subpart B
Subpart B
Subpart B
Subpart B
Subpart B
Is Mill
Enrolling in
VATIP?
X
#1
The Softwood Paper Corporation
manufactures fine paper and market
pulp. The mill, which discharges
effluent into the Seneca River, has
submitted an application for a new
NPDES permit because their current
permit expires September 16, 1999.
#1
1. Permit process for direct discharging mill with
operations in Subpart B.
2. Production rate determination.
The Softwood Paper Corporation operates one bleached kraft fiber line and two paper machines,
one to produce fine paper and another to produce market pulp.
for
The table below summarizes the information from the permit application you need to calculate
discharge limits for the reissued NPDES permit.
11-2
-------
Information Needed to Establish Permit Limits for Case Study #1
What type of discharger is the mill?
Under which subpart(s) do the mill's operations fall?
The mill is subject to which ELG&S?
Is the mill planning on entering VATIP?
Does mill use wet barking; log washing or chip
washing; or log flumes or log ponds?
Does the mill certify using TCP?
Does the mill use chlorophenolic biocides?
Direct
Subpart B
BPT (40 CFR 430.22)
Fine Paper Segment
Market Bleached Kraft Pulp Segment
BAT (40 CFR 430.24)
No
No
No
No
Softwood Paper manufactures bleach kraft pulp and two products (fine paper and bleached kraft
market pulp). The two products fall under two segments of Subpart B. Because BPT ELGs for
conventional pollutants and BAT for AOX and chloroform are mass-based, you must review the
production information submitted with the mill's permit application to determine production rates
for each product and for bleached pulp to calculate their BPT and BAT limits. The table below
explains how to calculate production rates (also see Section 8 for a description of how to determine
production rates).
11-3
-------
In revi<
maxim
period
AOX,
CASE STUDY #1
swing the monthly production data for Softwood paper from the last five years, you find that the
um production occurred from August 1 996 - July 1 997. The monthly production data from this time
will determine the production rate that results in the maximum permit limits for conventional pollutants,
and chloroform.
Date
August 1996
September 1996
October 1996
November 1996
December 1996
January 1997
February 1997
March 1997
April 1997
May 1997
June 1997
July 1997
Production Total
(ADMT or
OMMT/yr)
Total Op. Days/yr
Total
(ADMT or
OMMT/day)
Bleached Kraft
Pulp Production
(ADMT/mo)
30,600
30,650
30,400
30,800
30,900
30,300
30,700
30,400
30,750
30,500
30,600
30,900
376,500
350
1,050
Fine Paper Segment
Production Rate
(OMMT/mo)
19,000
19,250
19,300
19,500
19,600
19,200
19,000
18,900
19,000
19,100
19,525
19,625
231,000
350
660
Market Pulp
Production Rate
(ADMT/mo)
14,100
14,200
14,500
14,650
14,750
14,600
14,500
14,500
14,700
14,800
14,900
4,800
175,000
350
500
Determining Permit Limits for Pollutants Regulated Under BPT
You may then calculate conventional pollutant permit limits using the following equation:
where:
PROD,
LIMIT,
Final Effluent Limit = £ (PROD, x Limit,)
Production rate
ELG for conventional pollutant
Segment
11-4
-------
Final Effluent Limit = (PRODfinepaper x LIMITfinepaper) + (PRODmarketpulp x LIMITmarketpulp)
The table below presents the conventional pollutant permit limits calculated for this mill.
BPT Segment
Fine Paper
Market Pulp
Production
660 kkg/day
500 kkg/day
BPT Final Effluent Limit Totals
TSS
Daily Maximum
ELG
22.15
kg/kkg
30.4
kg/kkg
Subtotal
14,600
kg/day
15,200
kg/day
29, 800 kg/day
Monthly Average
ELG
11.9
kg/kkg
16.4
kg/kkg
Subtotal
7,850
kg/day
8,200
kg/day
16,050 kg/day
BOD5
Daily Maximum
ELG
10.6
kg/kkg
15.45
kg/kkg
Subtotal
7,000
kg/day
7,730
kg/kkg
14, 730 kg/day
Monthly Average
ELG
5.5
kg/kkg
8.05
kg/kkg
Subtotal
3,600
kg/day
4,030
kg/day
7,630 kg/day
for SAT
The bleaching operations at Softwood Paper are covered under Subpart B. BAT ELGs for the
regulated toxic and nonconventional pollutants are either concentration-based or mass-based. For
concentration-based ELGs, you may simply include the limit specified in 40 CFR 430.24 for each
pollutant as the permit limit.
TCDF: Maximum for one day = 31.9 pg/L
TCDD:
-------
In your revie1
results in ma?
Softwood Pa
production dc
production ra
10507(1-0
CASE STUDY #1
w of the permit application, you determine that the following production rate
dmum AOX and chloroform permit limits.
Date
August 1996
September 1996
October 1996
November 1996
December 1996
January 1997
February 1997
March 1997
April 1997
May 1997
June 1997
July 1997
Production Subtotal (ADMT/yr)
Total Op. Days/Year
Production Subtotal (ADMT/yr)
Bleached Kraft Pulp
Production (ADMT)
30,600
30,650
30,400
30,800
30,900
30,300
30,700
30,400
30,750
30,500
30,600
30,900
376,500
350
1,050
)er used an 8% shrinkage factor for the bleached papergrade kraft pulp ;j
ita submitted with their permit application. As a result, you can calculate the ;:
te for determining AOX and chloroform permit limits as follows: ;
08) = 1,141 ADMT/day of unbleached papergrade kraft pulp entering the bleach '•
plant. ':•
You may then determine permit limits for AOX and chloroform using the following equation:
Bleach plant or final effluent limit = PROD x LIMIT
where:
PROD
LIMIT
Production rate for AOX and chloroform (MT/day = kkg/day)
ELG for AOX or chloroform
11-6
-------
Alert! Remember, the mill must demonstrate
compliance with chloroform limits at bleach plant
effluent but with AOX limits at the final effluent.
The table below presents the limits calculated for AOX and chloroform.
Mill
Softwood paper
Production
1,141
kkg/day
Chloroform
Daily Maximum
ELG
6.92
g/kkg
Total
7.90 kg/day
Monthly Average
ELG
4.14
g/kkg
Total
4.72 kg/day
AOX
Daily Maximum
ELG
0.951
kg/kkg
Total
1,085
kg/day
Monthly Average
ELG
0.623
kg/kkg
Total
711
kg/day
Final Permit Limits for Softwood Paper
Table 11-2 presents the permit limits for Softwood Paper Corporation's NPDES permit.
Under the Clean Water Act, the NPDES permit must require immediate compliance with the new
limitations. The permit will be issued in September 1999 (which is over a year after the
promulgation of the final rule), and you are requiring Softwood Paper to meet permit limits
immediately upon the reissuance of the permit. As shown in Table 11-2, using BPJ, you have
included in the permit:
1. COD monitoring requirements;
2. Monitoring frequencies for conventional pollutants; and
3. Mandatory flow measurement and recording of bleach plant and final effluent.
Make sure you also include the following in the permit:
• A reopener clause so that you may include COD permit limits when EPA
promulgates ELGs for this pollutant (see Section 8);
• Dilution prohibition as a permit condition (see Section 8);
• Process upsets as a permit condition (see Section 8); and
• BMP requirements as permit conditions (see Section 9).
11-7
-------
Table 11-2; NPDES Permit Limits, Softwood Paper Corporation
Pollutant
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
AOX
COD*
BOD5
TSS
PH
Flow*
Flow*
Permit Limits
1-Day Maximum
<10 pg/L
31.9pg/L
7.90 kg/day
<2.5 ^g/L
<5.0 ^g/L
<5.0 Mg/L
<2.5 Mg/L
<2.5 ^g/L
<2.5 Mg/L
<2.5 ^g/L
<2.5 Mg/L
<5.0 Mg/L
<5.0 ^g/L
<2.5 ^g/L
<5.0 ^g/L
1,085 kg/day
Report
14, 730 kg/day
29, 800 kg/day
5-9
Report
Report
Monthly Average
-
-
4.72 kg/day
-
-
-
-
-
-
-
-
-
-
-
-
711 kg/day
-
7,630 kg/day
16,050 kg/day
-
Report
Report
Effluent Monitoring Location
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent**
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Bleach Plant Effluent
Final Effluent
Sample
Frequency
Monthly
Monthly
Weekly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Daily
Weekly
3 Days/Week
3 Days/Week
5 Days/Week
Continuous
Continuous
Sample Collection
Method
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
Grab
Recorder
Recorder
*Reporting for COD and flow determined using Best Professional Judgment (BPJ).
**Acid and alkaline streams monitored separately.
11-8
-------
#2
The White Bright Paper Company manufactures fine paper. Wastewaters produced during mill
operations are treated using primary
and secondary treatment prior to
discharge into the Falls River. The
mill has submitted a permit
application to you because their
NPDES permit expired
January 1, 1998.
#2
1. Permit process for direct dischargers with
operations in Subpart E.
2. Production rate determination.
The White Bright Paper Company operates a papergrade sulfite process to produce pulp which it
bleaches, and then uses it to make fine paper. The sulfite process uses a continuous digester and is
ammonium-based. Prior to bleaching, the pulp is washed using vacuum washers.
for
The table below summarizes the information from the permit application you need to calculate
discharge limits for the reissued NPDES permit.
Information Needed to Establish Permit Limits for Case Study #2
What type of discharger is the mill?
Under which subpart(s) do the mill's operations fall?
The mill is subject to which ELG&S?
Is the mill planning on entering VATIP?
Does mill use wet barking; log washing or chip
washing; or log flumes or log ponds?
Does the mill certify using TCP?
Does the mill use chlorophenolic biocides?
Direct
Subpart E
BPT (40 CFR 430.52)
Papergrade Sulfite with Continuous
Digester Segment
BAT (40 CFR 430.54)
Ammonium-based Segment
No
No
No
No
for
White Bright uses a vacuum washer and continuous digester and, therefore, the mill is subject to
the segment of Subpart E that covers these operations. Because the BPT ELGs for conventional
pollutants are mass-based, you must review their permit application to determine a production rate
to calculate their BPT limits. The table below explains how to calculate production rate.
11-9
-------
In revie
the last
August
determ
conven
CASE STUDY #2
wing the monthly production data for White Bright Paper Company from
five years, you find that the maximum 12-month production occurred from
1996 - July 1997. The monthly production data from this time period will
ne the production rate that results in the maximum permit limits for
tional pollutants.
Date
August 1996
September 1996
October 1996
November 1996
December 1996
January 1997
February 1997
March 1997
April 1997
May 1997
June 1997
July 1997
Production Total (OMMT/year)
Total Op. Days/Year
Production Total (OMMT/day)
Fine Paper
Production
(OMMT)
23,000
22,500
22,700
22,100
22,300
22,100
22,500
22,300
22,600
22,950
23,000
21,910
269,960
340
794
You may then calculate conventional pollutant permit limits using the following equation:
Final Effluent Limit = £ (PROD, x Limit,)
where:
PROD,
LIMIT,
i
Production rate
ELG for conventional pollutant
Subpart E Segment - Facilities with vacuum washers and
continuous digesters
11-10
-------
JittlUent Limit (r KUL) Subpart E Segment - Facilities with vacuum washers and continuous digesters) X
V-jllVH J- Subpart E Segment - Facihties with vacuum washers and continuous digesters/
The table below presents the conventional pollutant permit limits calculated for this mill.
BPT Segment
Papergrade Sulfite
with Vacuum
Washer and
Continuous
Digester
Production
794 kkg/day
TSS
Daily Maximum
ELG
53.75
kg/kkg
Subtotal
42,700
kg/day
Monthly Average
ELG
28.95
kg/kkg
Subtotal
23,000
kg/day
BOD5
Daily Maximum
ELG
38,15
kg/kkg
Subtotal
30,300
kg/day
Monthly Average
ELG
19.85
kg/kkg
Subtotal
15,800
kg/day
for fiAT
Since all BAT ELGs for Subpart E are concentration-based, you must simply include the limit
specified in the regulation for each pollutant as the permit limit.
TCDD: Maximum for one day =
-------
Table 11-3; Permit Limits for White Bright Paper Company
Pollutant
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
AOX*
COD*
BOD5
TSS
PH
Flow*
Flow*
Permit Limits
1-Day Maximum
<10 pg/L
<10 pg/L
Report
<2.5 ng/L
<5.0 ng/L
<5.0 ng/L
<2.5 ng/L
<2.5 ng/L
<2.5 ng/L
<2.5 ng/L
<2.5 ng/L
<5.0 ng/L
<5.0 ng/L
<2.5 ng/L
<5.0 ng/L
Report
Report
30,300 kg/day
42,700 kg/day
5-9
Report
Report
Monthly Average
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
15, 800 kg/day
23,000 kg/day
-
Report
Report
Effluent Sampling Location
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent**
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Bleach Plant Effluent
Final Effluent
Sample Frequency
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Weekly
3 Days/Week
3 Days/Week
5 Days/Week
Continuous
Continuous
Sample Collection
Method
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
Grab
Recorder
Recorder
"--" Monthly averages do not apply for pollutant.
*Reporting for chloroform, AOX, COD, and flow determined using
**Acid and alkaline streams monitored separately.
BPJ.
11-12
-------
Acme Paper Company manufactures
office paper, tissue, and clay-coated
printing papers. The company
operates both a bleached kraft fiber
line and a papergrade sulfite fiber
line. All process wastewater
generated by Acme Paper is treated
using primary and secondary treatment prior to discharge into the Tyler River. The mill has
submitted a permit application because their current NPDES permit expires in August 2000.
#3
1. Permit process for mill with operations in
multiple subparts (Subparts B and E).
2. Production rate determination.
Acme Paper operates a bleached kraft fiber line producing bleached pulp that is used to
manufacture fine papers and tissue. The papergrade sulfite fiber line bleaches pulp that is
primarily used to manufacture printing paper and some of the bleached papergrade sulfite pulp is
used to manufacture tissue. The tissue product is made up of both bleached kraft pulp and
bleached sulfite pulp. The sulfite process is ammonium-based and the papergrade sulfite fiber line
uses a pressure drum washing system prior to bleaching the pulp.
for
The mill has certified in their permit application that they use TCP bleaching to produce
papergrade sulfite pulp. The table below summarizes relevant information for establishing permit
limits for pollutants with ELGs.
Information Needed to Establish Permit Limits for Case Study #3
What type of discharger is the mill?
Direct
Under which subpart(s) do the mill's operations fall?
Subparts B and E
The mill is subject to which ELG&S?
Subpart B
BPT (40 CFR 430.22)
Fine Paper Segment
Paperboard, Coarse Paper, and Tissue
Segment
BAT (40 CFR 430.24)
Subpart E
BPT (40 CFR 430.52)
Papergrade Sulfite with Vacuum or
Pressure Drum (bisulfite liquor/surface
condenser) Segment
BAT (40 CFR 430.54)
Ammonium-Based Segment
11-13
-------
Information Needed to Establish Permit Limits for Case Study #3
Is the mill planning on entering VATIP?
Does mill use wet barking; log washing or chip
washing; or log flumes or log ponds?
Does the mill certify using TCP?
Does the mill use chlorophenolic biocides?
No
No
Only
on the papergrade sulfite line.
No
Acme Paper Company manufactures papergrade kraft pulp, papergrade sulfite pulp, and three
products (fine paper, tissue, and clay-coated printing papers). Two of the products (fine paper and
tissue) Acme Paper manufactures fall under two segments of Subpart B. In addition, the Subpart
E regulations also apply to the tissue production. The third product (clay-coated printing papers)
is comprised of bleached papergrade sulfite pulp and, therefore, falls under Segment E. Because
BPT ELGs for conventional pollutants and BAT for AOX and chloroform are mass-based, you
must review the production information submitted with the mill's permit application to determine
appropriate production rates for each product and for bleached pulp to calculate their BPT and
BAT limits.
The table below explains how to calculate production rates (also see Section 8 for a description of
how to determine production rates).
11-14
-------
In
the
fro
CO]
#j
su
CASE STUDY #3
reviewing the monthly production data for Acme Paper Company from the last five years, you find that
maximum 12-month production occurred from April 1998 - March 1999. The monthly production data
m this time period will determine the production rate that results in the maximum permit limits for
wentional pollutants, AOX, and chloroform.
Date
April 1998
May 1998
June 1998
July 1998
August 1998
September 1998
October 1998
November 1998
December 1998
January 1999
February 1999
March 1999
Production Total
(ADMT or
OMMT/yr)
Total Op.
Days/Year
Production Total
(ADMT or
OMMT/day)
Bleached
Kraft Pulp
Production
(ADMT/mo)
26,900
26,100
26,250
26,800
26,250
26,100
26,300
27,000
26,300
26,100
25,500
25,400
315,000
350
900
Bleached
Sulflte Pulp
Production
(ADMT/mo)
17,100
17,300
17,500
17,700
17,900
17,600
17,500
17,600
17,300
17,400
17,500
17,600
210,000
350
600
Fine Paper
Production
(OMMT/mo)
16,300
15,800
15,750
15,300
15,800
16,300
15,750
15,750
15,400
15,950
15,500
15,400
189,000
350
540
Tissue
Production
(OMMT/mo)
14,600
14,500
14,500
14,400
14,100
14,600
14,850
14,400
14,500
14,850
14,900
14,800
175,000
350
500*
Printing Paper
Production
(OMMT/mo)
13,400
13,400
13,500
13,600
13,700
13,500
13,400
13,200
13,100
13,100
13,400
13,700
161,000
350
460
tie tissue production is comprised of 360 OMMT/day bleached kraft pulp and 140 OMMT/day bleached
fite pulp.
for
You may then calculate conventional pollutant permit limits using the following equation:
Final Effluent Limit = £ (PROD, x Limit,)
where:
PROD,
LIMIT,
Production rate
ELG for conventional pollutant
Subpart B - Fine paper segment; Subpart B - paperboard,
coarse paper, and tissue segment; and Subpart E - papergrade
sulfite with vacuum or pressure drum segment
11-15
-------
Final Effluent Limit = (PRODSubpart 0. fae paper x LIMITSubpart B. fine paper) -
(PRODSubpartE.v.
racuum or pressure drum
:LIMITSubpartE.v;
racuum or pressure drum)
The table below presents the conventional pollutant permit limits calculated for this mill.
Subcategory
Subpart B
Subpart B
Subpart E
Segment
Fine Paper
Paperboard,
Coarse Paper, and
Tissue
Papergrade Sulfite
with Vacuum or
Pressure Drum
(bisulfite
liquor/surface
condenser)
Production
540 kkg/day
360 kkg/day
600 kkg/day
BPT Final Effluent Limit Totals
TSS
Daily Maximum
ELG
22.15
kg/kkg
24.0
kg/kkg
43.95
kg/kkg
Subtotal
12,000
kg/day
8,600
kg/day
26,370
kg/day
46,970 kg/day
Monthly Average
ELG
11.9
kg/kkg
12.9
kg/kkg
23.65
kg/kkg
Subtotal
6,430
kg/day
4,600
kg/day
14,190
kg/day
25,220 kg/day
BOD
Daily Maximum
ELG
10.6
kg/kkg
13.65
kg/kkg
26.7
kg/kkg
Subtotal
5,720
kg/day
4,900
kg/day
16,020
kg/day
26,640 kg/day
Monthly Average
ELG
5.5 kg/kkg
7.1 kg/kkg
13.9
kg/kkg
Subtotal
3,000
kg/day
2,600
kg/day
8,340
kg/day
13,940 kg/day
Determining Permit Limits for Pollutants Regulated Under BAT
The bleaching operations at Acme Paper are covered under Subparts B and E. Subpart B ELGs
for the regulated toxic and nonconventional pollutants are either concentration- or mass-based
permit limits. For concentration-based limits, you must simply include the limit specified in 40
CFR 430.24 for each pollutant as the permit limit. The Subpart E BAT ELGs for TCDD, TCDF,
chloroform, and 12 chlorinated compounds do not apply to fiber lines that use a TCP bleaching
process. Since this mill's bleached sulfite pulping process does use TCP bleaching, there are no
limits for these pollutants. Limits for AOX and COD are reserved under BAT for this subpart.
11-16
-------
In your revie
results in ma
Acme Paper
production c
production r
9007(1-0.1
CASE STUDY #3
w of the permit application, you determine that the following production rate
ximum AOX and chloroform permit limits for the Subpart B operations.
Date
April 1998
May 1998
June 1998
July 1998
August 1998
September 1998
October 1998
November 1998
December 1998
January 1999
February 1999
March 1999
Production Total
(ADMT/year)
Total Op. Days/year
Production Total (ADMT/day)
Bleached Kraft Pulp
Production (ADMT/mo)
26,900
26,100
26,250
26,800
26,250
26,100
26,300
27,000
26,300
26,100
25,500
25,400
315,000
350
900
provided a 1 0% shrinkage factor for the bleached papergrade kraft pulp
ata submitted with their permit application. As a result, you can calculate the
ate for determining AOX and chloroform permit limits as follows:
3) = 1 ,000 ADMT = 1 ,000 kkg of unbleached papergrade kraft pulp entering the
bleach plant.
11-17
-------
Example: Concentration-Based Limit Calculation
TCDF: Maximum for one day = 31.9 pg/L
Example: Mass-Based Limit Calculation
For mass-based limits established in Subpart B, you must calculate the kraft mill fiber line's
production rate of unbleached kraft pulp entering the first stage of the bleach plant. Using the
maximum production time period illustrated above, the following table explains how to calculate
the production rate (also see Section 8 for a description of how to determine production rate).
Because the only BAT ELG for this segment is
-------
3. Mandatory flow measurements of bleach plant and final effluent.
Make sure you also include the following in the permit:
• Because AOX and COD limits are reserved, a reopener clause so that you may
include AOX and COD permit limits when EPA promulgates ELGs for these
pollutants (see Section 8);
• Dilution prohibition as a permit condition (see Section 8);
• Process upsets as a permit condition (see Section 8); and
• BMP requirements as permit conditions (see Section 9).
Table 11 -4. Permit Limits for Acme Paper Company
Pollutant
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
AOX
COD*
BOD5
TSS
PH
Flow*
Flow*
Flow*
Permit Limits
1 Day Maximum
<10 pg/L
31.9pg/L
6. 9 kg/day
<2.5 ug/L
<5.0 ug/L
<5.0 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<5.0 ug/L
<5.0 ug/L
<2.5 ug/L
<5.0 ug/L
951 kg/day
Report
26,640 kg/day
46,970 kg/day
5-9
Report
Report
Report
Monthly
Average
-
-
4.1 kg/day
-
-
-
-
-
-
-
-
-
-
-
-
623 kg/day
-
13,440 kg/day
25,220 kg/day
-
Report
Report
Report
Effluent Sampling Location
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE**
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Kraft Mill Fiber Line BPE
Sulfite Mill Fiber Line BPE
Final Effluent
Sample Frequency
Monthly
Monthly
Weekly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Daily
Weekly
3 Days/Week
3 Days/Week
5 Days/Week
Continuous
Continuous
Continuous
Sample Collection
Method
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
Grab
Recorder
Recorder
Recorder
"--" Monthly averages do not apply for pollutant.
BPE - Bleach Plant Effluent.
*Reporting for COD and flow based on BPJ.
**Acid and alkaline streams monitored separately.
11-19
-------
#4
Pulpco Corporation is an integrated
pulp and paper mill that manufactures
paperboard and three types of market _ - ... ..
1 Permit process for mills with operations in
#4
multiple subparts (Subparts B, G, I).
2. Production rate determination.
pulp. Pulpco operates a bleached
papergrade kraft fiber line, a
secondary deink fiber line, and a
thermo-mechanical fiber line. All
process wastewaters generated by
Pulpco Corporation are treated using primary and secondary treatment prior to discharge into the
Murray River. The mill has submitted a permit application because their current NPDES permit
expires December 2000.
Pulpco operates a bleached kraft fiber line producing bleached pulp that is either sold as market
pulp or used to manufacture paperboard. Pulpco uses some of the secondary deink fiber in their
paperboard production. The secondary deink fiber makes up 10% of the paperboard while the rest
is sold to other paper manufacturers for use in a variety of products. All of the thermo-mechanical
pulp is sold to a newsprint manufacturer.
for 1
The table below summarizes the relevant information from the permit application you need to
calculate discharge limits for the reissued NPDES permit.
11-20
-------
Information Needed to Establish Permit Limits for Case Study #4
What type of discharger is the mill?
Under which subpart(s) do the mill's operations fall?
The mill is subject to which ELG&S?
Is the mill planning on entering VATIP?
Does mill use wet barking; log washing or chip
washing; or log flumes or log ponds?
Does the mill certify using TCP?
Does the mill use chlorophenolic biocides?
Direct
Subparts B, G, and I
Subpart B
BPT (40 CFR 430.22)
Market Bleached Kraft Pulp Segment
Paperboard, Coarse Paper, and Tissue
Segment
BAT (40 CFR 430.24)
Subpart G
BPT (40 CFR 430.72)
Pulp and Paper at Groundwood Mills
Through the Application of Thermo-
mechanical Process Segment
BAT (40 CFR 430.74)
Subpart I
BPT (40 CFR 430.92)
BAT (40 CFR 430.94)
No
No
No
No
Determining Permit Limits for Pollutants Regulated Under BPT
Pulpco manufactures two products (paperboard and bleached market pulp) that fall under two
segments of Subpart B. The secondary fiber deink production is subject to BPT ELGs for Subpart
I. The thermo-mechanical pulp production falls under one segment (i.e., the Pulp and Paper at
Groundwood Mills Through the Application of Thermo-Mechanical Process Segment) of Subpart
G. Because BPT ELGs are mass-based, you must review their permit application to determine
production rates for each product to calculate their BPT limits. The table below explains how to
calculate production rates (also see Section 8 for a description of how to calculate production
rates).
11-21
-------
Inr
ma>
date
limi
API
100
Pap
CASE STUDY #4
sviewing the monthly production data for Pulpco from the last five years, you find that the
dmum production occurred from November 1997 - October 1998. The monthly production
i from this time period will determine the production rate that results in the maximum permit
ts for conventional pollutants.
Date
11/97
12/97
1/98
2/98
3/98
4/98
5/98
6/98
7/98
8/98
9/98
10/98
Production
Total (ADMT
or OMMT/yr)
Total Op.
Days/Year
Production
Total (ADMT
or OMMT/day)
Coated
Paperboard
Production
(OMMT/mo)
29,500
29,100
29,150
29,000
28,950
29,100
28,590
29,150
29,500
29,100
29,000
29,500
350,000
350
1,000
Market Pulp
Production
(OMMT/mo)
11,100
11,300
12,400
11,200
12,500
11,200
11,400
1,600
11,700
11,900
11,800
11,900
140,000
350
400
Secondary
Deink Fiber
(ADMT/mo)
8,000
7,500
7,900
7,900
8,000
7,600
7,200
7,800
7,900
8,000
8,000
8,000
93,800
350
268
Thermo-
Mechanical
Pulp
(ADMT/mo)
8,900
8,750
8,200
8,400
8,750
8,750
8,100
8,750
9,100
9,300
9,000
9,000
105,000
350
300
)roximately 10% of paperboard is comprised of secondary deink fiber (or approximately
ADMT/year). As a result, you can calculate the production rate for Paperboard, Coarse
er, and Tissue subject to Subpart B ELGs as follows:
Production rate for Paperboard, Coarse Paper, and Tissue subject to Subpart B ELGs
= 1,000 ADMT/day - 100 ADMT/day = 900 ADMT/day
= 900 kkg/day
11-22
-------
You may then calculate conventional pollutant permit limits using the following equation:
where:
PROD,
LIMIT,
Final Effluent Limit = £ (PROD, x Limit,)
Production rate
ELG for conventional pollutant
Segment
Final Limit = (PRODpaperboald x LIMITpaperboald) + (PRODbleachkraftpulp) x LIMITbleachklaftpulp)
+ (PRODthemlo.mechmical pulp x LIMIlthemlo.mechanicalpulp) + (PRODsecond!oy deink fiber x LlMllsec
-------
Example: Mass-Based Limit Calculation
For mass-based ELGs, such as those for chloroform and AOX, you must calculate the production
rate of unbleached pulp entering the bleach plant. Using the maximum production rate time period
illustrated above, the following table explains how to calculate the production rate for these
pollutants (also see Section 8 for a description of how to determine production rate).
In your review
rate results in tl
Pulpco provide
data submitted
AOX and chlor
UOOAD1N
CASE STUDY #4
of Pulpco 's permit application, you determine that the following produ
le maximum AOX and chloroform permit limits.
Date
11/97
12/97
1/98
2/98
3/98
4/98
5/98
6/98
7/98
8/98
9/98
10/98
Total Production (ADMT/year)
Total Op. Days/Year
Total Production (ADMT/day)
Bleached Kraft Pulp
Production (ADMT)
37,500
37,500
37,900
38,100
38,400
38,000
38,300
38,300
37,500
37,600
37,900
38,000
455,000
350
1,300
d a 10% shrinkage factor for the bleached papergrade kraft pulp produ
with their permit application. As a result, the production rate for calcu
oform permit limits is as follows:
/1T/(1-0. 10) = 1,444 ADMT of unbleached papergrade kraft pulp ente
bleach plant.
ction
ction
lating
ring the
You may then determine permit limits for AOX and chloroform using the following equation:
11-24
-------
Bleach plant or final effluent limit = PROD x LIMIT
where:
PROD
LIMIT
Production rate for AOX and chloroform; and
Toxic and nonconventional pollutant ELG.
ALERT! Remember, chloroform is limited in bleach
plant effluent while AOX is limited in final effluent.
The table below presents the limits calculated for AOX and chloroform.
Subcategory
Subpart B
Production
l!444kkg/day
Chloroform
Dally Maximum
ELG
6.92 g/kkg
Total
9.99
kg/day
Monthly Average
ELG
4. 14 g/kkg
Total
5.98
kg/day
AOX
Daily Maximum
ELG
0.951
kg/kkg
Total
1,270
kg/day
Monthly Average
ELG
0.623
kg/kkg
Total
830 kg/day
Final Permit Limits for Pulpco Corporation
Table 11-5 presents the permit limits for Pulpco. Under the Clean Water Act, the NPDES permit
must require immediate compliance with the new limitations. The permit is being reissued in
December 2000 (over two years after the promulgation of the final rule), and you are requiring the
mill to comply with permit limits for chlorinated pollutants immediately. Also shown in the table,
you exercised BPJ to include the following in the permit:
1. COD monitoring requirements;
2. Monitoring frequencies for conventional pollutants; and
3. Mandatory flow measurements of bleach plant and final effluent.
Make sure you also include the following in the permit:
• A reopener clause so that you may include COD permit limits when EPA
promulgates ELGs for this pollutant (see Section 8);
• Dilution prohibition as a permit condition (see Section 8);
• Process upsets as a permit condition (see Section 8); and
• BMP requirements as permit conditions (see Section 9).
11-25
-------
Table 11-5: Permit Limits for Pulpco Corporation
Pollutant
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
AOX
COD*
BOD5
TSS
PH
Flow*
Flow*
Permit Limits
1 Day Maximum
<10 pg/L
31.9pg/L
10.0 kg/day
<2.5 ug/L
<5.0 ug/L
<5.0 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<5.0 ug/L
<5.0 ug/L
<2.5 ug/L
<5.0 ug/L
1,270 kg/day
Report
26, 500 kg/day
44,920 kg/day
5-9
Report
Report
Monthly
Average
-
-
6.0 kg/day
-
-
-
-
-
-
-
-
-
-
-
-
830 kg/day
-
13, 800 kg/day
24, 150 kg/day
-
Report
Report
Effluent Sampling Location
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Kraft Mill Fiber Line BPE
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Kraft Mill Fiber Line BPE
Final Effluent
Sample Frequency
Monthly
Monthly
Weekly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Daily
Weekly
3 Days/Week
3 Days/Week
5 Days/Week
Continuous
Continuous
Sample Collection
Method
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
Grab
Recorder
Recorder
*Reporting for COD and flow based on BPJ.
11-26
-------
#5
1. Production rate determination.
2. Permit limits for non-continuous dischargers.
United Papers Corporation is an
integrated pulp and paper mill that
manufactures office paper and market
pulp. All process wastewaters
generated by United Paper are treated
and discharged to a holding pond.
The mill discharges wastewater to
Johnstone Creek nine months of the year. Wastewater is not discharged during July, August, and
September due to Johnstone Creek's low flow and inability to assimilate oxygen-demanding
wastewater during these months. The mill has submitted a permit application because their current
NPDES permit expires January 2001.
United Papers operates a bleached papergrade kraft fiber line and two paper machines. In 1998,
the mill purchased a second paper machine to increase office paper production. United Paper
reduced the amount of market pulp sold to paper manufacturers and used the pulp for their
increased office paper production.
for
The table below summarizes the relevant information from the permit application you need to
calculate discharge limits for the reissued permit.
Information Needed to Establish Permit Limits for Case Study #5
What type of discharger is the mill?
Under which subpart(s) do the mill's operations fall?
The mill is subject to which ELG&S?
Is the mill planning on entering VATIP?
Does mill use wet barking; log washing or chip
washing; or log flumes or log ponds?
Does the mill certify using TCP?
Does the mill use chlorophenolic biocides?
Direct (non-continuous discharger)
Subpart B
BPT (40 CFR 430.22)
Fine Paper Segment
Market Bleached Kraft Pulp Segment
BAT (40 CFR 430.24)
No
No
No
No
11-27
-------
ALERT! Non-continuous discharge mills are subject
to annual average ELGs for conventional pollutants;
however, maximum one-day and 30-day average
limitations may be required to protect receiving water
quality.
United Papers manufactures
bleached kraft pulp and two
products (office papers and
bleached market pulp) that fall
under two segments of Subpart B.
Note that as a non-continuous
discharger, the mill is subject to
annual average permit limits, rather than maximum one-day and 30-day permit limits, for
conventional pollutants regulated in final effluent. Because BPT ELGs for conventional pollutants
and BAT for AOX and chloroform are mass-based, you must review the production information
submitted with the mill's permit application to determine production rates for both products and
bleached pulp to calculate their BPT and BAT limits. The table below explains how to calculate
production rates for United Papers (also see Section 8 for a description of how to calculate
production rates).
11-28
-------
]
t
(
1
CASE STUDY #5
n reviewing the monthly production data for United Papers from the last five years, you find that
he maximum production occurred from September 1998 - August 1999. The monthly production
iata form this time period will determine the production rate that results in the maximum permit
imits for conventional pollutants, AOX, and chloroform.
Date
9/98
10/98
11/98
12/98
1/99
2/99
3/99
4/99
5/99
6/99
7/99
8/99
Total Production
(ADMT or OMMT/yr)
Total Op. Days/Year
Total Production
(ADMT or OMMT/day
Bleached Kraft
Pulp Production
(ADMT/mo)
33,300
32,600
32,900
32,750
32,850
32,600
33,800
33,250
32,700
34,000
33,000
33,500
397,250
350
1,135
Fine Paper
Production
(OMMT/mo)
20,700
20,400
20,500
20,100
20,350
20,100
20,600
20,350
20,100
20,600
20,400
20,800
245,000
350
700
Market Pulp
Production
(ADMT/mo)
12,600
12,200
12,400
12,650
12,500
12,500
13,200
12,900
12,600
13,400
12,600
12,700
152,250
350
435
11-29
-------
for
You may then calculate conventional pollutant permit limits using the following equation:
where:
PROD,
LIMIT,
i
Final Effluent Limit = £ (PROD, x Limit,)
Production rate
ELGs for conventional pollutant
Segment
Final effluent limit = (PRODfinepaper x LIMITfinepaper) + (PRODmarketpulp x LIMITmarketpulp)
The table below presents the conventional pollutant permit limit calculated for this mill.
Subcategory
Subpart B
Subpart B
Segment
Fine Paper
Market Pulp
Production
700 kkg/day
435 kkg/day
BPT Final Effluent Limit Totals
TSS
Annual Average
ELG
6.54kg/kkg
9.01 kg/kkg
Subtotal
4,580 kg/kkg
3,920 kg/day
8,500 kg/day
BOD
Annual Average
ELG.
3.09 kg/kkg
4. 52 kg/kkg
Subtotal
2, 160 kg/day
2,000 kg/day
4, 160 kg/day
for
The bleaching operations at United Papers are covered under Subpart B. Although United Papers
non-continuously discharges final effluent, the mill performs bleach plant operations continuously
and, therefore, bleach plant effluent is continuously generated. As a result, the ELGs for those
pollutants limited in bleach plant effluent are equivalent to those for direct dischargers.
BAT ELGs for the regulated toxic and nonconventional pollutants are either concentration-based
or mass-based. For concentration-based ELGs, you may simply include the limits specified in 40
CFR 430.24 for each pollutant as the permit limit.
TCDF: Maximum for one day = 31.9 pg/L
TCDD: Maximum for one day:
-------
illustrated above, the following table explains how to calculate the production rate for these
pollutants (also see Section 8 for a description of how to determine production rate).
In your review of 1
rate results in the n
United Papers prcn
data submitted wit
and chloroform pe
1,1357(1-0.08) =
CASE STUDY #5
Jnited Papers' permit application, you determine that the following production
naximum AOX and chloroform permit limits.
Date
9/98
10/98
11/98
12/98
1/99
2/99
3/99
4/99
5/99
6/99
7/99
8/99
Total Production
(ADMT/year)
Total Op. Days/Year
Total Production
(ADMT/day)
Bleached Kraft Pulp
Production (ADMT)
33,300
32,600
32,900
32,750
32,850
32,600
33,800
33,250
32,700
34,000
33,000
33,500
397,250
350
1,135
/ided an 8% shrinkage factor for the bleached papergrade kraft pulp production
i their permit application. As a result, the production rate for calculating AOX
mit limits is as follows:
1,230 ADMT/day of unbleached papergrade kraft pulp entering the bleach plant.
11-31
-------
You may then determine permit limits for AOX and chloroform by using the following equation:
Bleach plant or final effluent limit = PROD x LIMIT
where:
PROD
LIMIT
Production rate for AOX and chloroform; and
Toxic and nonconventional pollutant ELG
ALERT! Remember, chloroform is limited in bleach
plant effluent while AOX is limited in final effluent.
The table below presents the limits calculated for AOX and chloroform.
Subcategory
Subpart B
Production
1,230
kkg/day
Chloroform
Daily Maximum
ELG
6.92
g/kkg
Subtotal
8.51
kg/day
Monthly Average
ELG
4.14
g/kkg
Subtotal
5.09
kg/day
AOX
Annual Average
ELG
0.512
kg/kkg
Subtotal
630
kg/day
Final Permit Limits for United Papers Corporation
Table 11-6 presents the permit limits for United Papers Corporation. Under the Clean Water Act,
the NPDES permit must require immediate compliance with the new limitations. The permit is
being reissued in January of 2001 (which is over a year after the promulgation of the final rule),
and you are requiring the mill to comply with permit limits for chlorinated pollutants immediately.
Also shown in Table 11-6, you exercised BPJ to include the following in the permit:
1. COD monitoring requirements;
2. Monitoring frequencies for conventional pollutants; and
3. Mandatory flow measurements of bleach plant and final effluent.
Make sure you also include the following in the permit:
• A reopener clause so that you may include COD permit limits when EPA
promulgates ELGs for this pollutant (see Section 8);
• Dilution prohibition as a permit condition (see Section 8);
• Process upsets as a permit condition (see Section 8); and
• BMP requirements as permit conditions (see Section 9).
11-32
-------
Table 11-6; Permit Limits for United Papers Corporation
Pollutant
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
AOX
COD*
BOD5
TSS
PH
Flow*
Flow*
Permit Limits
1-Day
Maximum
<10 pg/L
31.9pg/L
8.51 kg/day
<2.5 ug/L
<5.0 ug/L
<5.0 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<5.0 ug/L
<5.0 ug/L
<2.5 ug/L
<5.0 ug/L
Report
-
-
5-9
Report
Report
Monthly
Average
-
-
5.09 kg/day
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Report
Report
Annual
Average
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
630 kg/day
-
4,160
kg/day
8,500
kg/day
-
Report
Report
Effluent Sampling Location
BPE
BPE
BPE
BPE
BPE
BPE
BPE
BPE
BPE
BPE
BPE
BPE
BPE
BPE
BPE
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Final Effluent
BPE
Final Effluent
Sample
Frequency
Monthly
Monthly
Weekly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Daily
Weekly
3 Days/Week
3 Days/Week
5 Days/Week
Continuous
Continuous
Sample Collection
Method
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
Grab
Recorder
Recorder
*Reporting for COD and flow based on BPJ.
11-33
-------
PaperTech Corporation manufactures
market pulp and fine paper. The
company has two bleached kraft
fiber lines, one of which was recently
installed. All process wastewaters
generated by PaperTech are treated
using primary and secondary
treatment prior to discharge into the
Jackson River. The mill has
submitted a permit application since
they are to begin operation of their
new fiber line in March 2001.
#6
1. Permit process for mill that triggers NSPS.
2. Permit limits that include NSPS conventional
pollutant contribution.
3. Production rate projections for new mill
operations.
PaperTech operates two bleached kraft fiber lines. The existing line (Fiber line #1) produces
bleached pulp that is used to manufacture market pulp and fine papers. To expand operations,
PaperTech has installed a new bleached kraft fiber line and paper machine. PaperTech's new line
(Fiber line #2) has a capacity to produce 583 ADMT/yr of bleached kraft pulp to produce fine
papers.
for I
The table below summarizes relevant information from the permit applications you need to
calculate discharge limits for the NPDES permit. Note that the Fiber line #2 triggers new source
requirements and is subject to NSPS. Fiber line #1 remains subject to existing source requirements
and is subject to BAT and BPT.
11-34
-------
Relevant Information for Establishing Permit Limits for Case Study #6
What type of discharger is the mill?
Under which subpart(s) do the mill's operations fall?
The mill is subject to which ELG&S?
Is the mill planning on entering VATIP?
Does mill use wet barking; log washing or chip
washing; or log flumes or log ponds?
Does the mill certify using TCP?
Does the mill use biocides?
Direct
Subpart B
Subpart B
Fiber Line #1
BPT (40 CFR 430.22)
Fine Paper Segment
Market Bleached Kraft Pulp
Segment
BAT (40 CFR 430.24)
Fiber Line #2
NSPS (40 CFR 430.25)
No
No
No
No
Determining Permit Limits for Conventional Pollutants Regulated Under BPT and NSPS
Both products (market pulp and fine paper) manufactured by PaperTech fall under two segments
of Subpart B. The ELG&S for conventional pollutants are mass-based. As a result, you must
review the production information submitted with the mill's permit application to determine
appropriate production rates for calculating conventional pollutant limits. Note that the production
must be separated by the portion attributable to each line. You must apply BPT for the market
pulp and fine paper production attributable to Fiber line #1 and NSPS for the fine paper production
attributable to Fiber line #2.
11-35
-------
In
th
Pi
m
S
oi
P<
P<
CASE STUDY #6
reviewing the monthly production data for Paper Tech from the last five years, you find that
e maximum production occurred from September 1999 - August 2000. The monthly
•eduction data from this time period will determine the production rate that results in the
aximum permit limits for conventional pollutants.
Date
9/99
10/99
11/99
12/99
1/00
2/00
3/00
4/00
5/00
6/00
7/00
8/00
Total Production
(ADMT or OMMT/yr)
Total Op. Days/Year
Total Production
(ADMT or OMMT/day)
Fine Paper Production
(OMMT)
17,500
17,400
17,800
18,000
17,400
18,000
17,500
17,200
17,000
17,200
17,500
17,500
210,000
350
600
Market Pulp
Production
(ADMT)
3,200
2,900
2,700
3,300
2,800
2,700
3,300
2,700
2,400
2,900
2,900
3,200
35,000
350
100
tailing in March 2001, PaperTech expects to continue to produce approximately 600 OMMT
'fine paper and 100 ADMT of market pulp as well as the projected 700 OMMT of fine
iper from their new paper machine. As a result, you should must determine conventional
jllutant limits that also account for the new production.
You may then calculate conventional pollutant permit limits using the following equation:
where:
PROD,
LIMIT,
Final Effluent = £ (PROD, x LIMIT,)
BPT or NSPS production for conventional pollutants; and
Conventional pollutant effluent limitation guideline for
appropriate BPT or NSPS segment; and
Segment.
11-36
-------
Final Effluent Limit = Fiberline #1 + Fiberline #2
• LIMIT,™,fnr«„,,„„,„) + (PRODHpTfnrm,,ri,,,tI,,,ll, x LIMIT,,
- (PRODfinepaper x LIMITBPTforfinepaper) + (PRODBPTformarketpulp x LIMITBPTformarketpulp)
(PRODfinepaper x LIMITNSPSformarketpulp)
The table below presents the conventional pollutant permit limits calculated for this mill.
Subpart
B
Fiber
line
#1
#2
Guideline
or
Standard
BAT
NSPS
Segment
Fine
Paper
Market
Pulp
Fine
Paper
Production
600 kkg/day
100 kkg/day
700 kkg/day
Limit Totals
TSS
Daily Maximum
ELG
22.15
kg/kkg
30.4
kg/kkg
9.1
kg/kkg
Subtotal
13,300
kg/day
3,040
kg/day
6,400
kg/day
22,740 kg/day
Monthly Average
ELG
11.9
kg/kkg
16.4
kg/kkg
4.8
kg/kkg
Subtotal
7,140
kg/day
1,640
kg/day
3,400
kg/day
12, 180 kg/day
BOD
Daily Maximum
ELG
10.6
kg/kkg
15.45
kg/kkg
5.7
kg/kkg
Subtotal
6,360
kg/day
1,550
kg/day
4,000
kg/day
11,910 kg/day
Monthly Average
ELG
5.5
kg/kkg
8.05
kg/kkg
3.1
kg/kkg
Subtotal
3,300
kg/day
805
kg/day
2,200
kg/day
6,305 kg/day
Alert! PaperTech operates two fiber lines that
discharge bleach plant effluent. You must establish
permit limits for those pollutants regulated in bleach
plant effluent for each fiber line.
for SAT
PaperTech is subject to BAT ELGs for mills with operations in Subpart B. You must establish
concentration- and mass-based
permit limits. For concentration-
based limits, you must include the
concentration value specified in 40
CFR 430.24 for each pollutant as the
permit limit. Note that permit limits
for those pollutants regulated in
bleach plant effluent must be established for each fiber line.
TCDF: Maximum for one day = 31.9 pg/L
TCDD: Maximum for one day =
-------
CASE STUDY #6
In your review of Paper!ech's permit application, you determine that the following production rate that
results in the maximum AOX and chloroform permit limits.
Date
9/99
10/99
11/99
12/99
1/00
2/00
3/00
4/00
5/00
6/00
7/00
8/00
Total Production
(ADMT/year)
Total Op. Days/Year
Total Production
(ADMT/year)
Fiber Line #1 Bleached Kraft
Pulp Production (ADMT)
17,500
17,400
17,800
18,000
17,400
18,000
17,500
17,200
17,000
17,200
17,500
17,500
210,000
350
600
In their permit application, PaperTech provided a 4% shrinkage factor for the bleached papergrade kraft
pulp production data for Fiber line #1. As a result, the production rate for calculating AOX and
chloroform permit limits is as follows:
6007(1-0.04) = 625 ADMT of unbleached papergrade kraft pulp entering the bleach plant.
PaperTech projects that their new fiber line, at full capacity, will produce 583 ADMT/yr of bleached kraft
pulp. In mill studies, PaperTech calculated that the softwood furnish will experience 8% shrinkage
during bleaching operations. As a result, the production rate for calculating AOX and chloroform permit
limits is as follows:
5837(1-0.08) = 634 ADMT of unbleached papergrade kraft pulp entering the bleach plant.
11-38
-------
You may then determine permit limits for AOX and chloroform by using the following equation:
Bleach plant or final effluent limit = PROD x LIMIT
where:
PROD
LIMIT
Production rate for AOX and chloroform; and
Toxic and nonconventional pollutant ELG.
Alert! Remember, chloroform is limited in bleach
plant effluent while AOX is limited in final effluent.
The table below presents the limits calculated for AOX and chloroform.
Subpart
Subpart
B
Fiberllne
#1
#2
Guideline
or
Standard
BAT
NSPS
Production
625 kkg/day
634 kkg/day
Toxic and Nonconventional Limit Totals
Chloroform
Daily Maximum
ELG
6.92
g/kkg
6.92
g/kkg
Subtotal
4.33
kg/day
4.39
kg/day
8.72 kg/day
Monthly Average
ELG
4.14
g/kkg
4.14
g/kkg
Subtotal
2.59
kg/day
2.62
kg/day
3.21 kg/day
AOX
Daily Maximum
ELG
0.951
kg/kkg
0.476
kg/kkg
Subtotal
594
kg/day
302
kg/day
896 kg/day
Monthly Average
ELG
0.623
kg/kkg
0.272
kg/kkg
Subtotal
389
kg/day
172
kg/day
561 kg/day
Final Permit Limits for PaperTech Corporation
Table 11-7 presents the permit limits for PaperTech. Under the Clean Water Act, the NPDES
permit must require immediate compliance with the new limitations. The permit is being reissued
in March 2001 (which is almost two years after the promulgation of the final rule), you are
requiring the mills to comply with permit limits for chlorinated pollutants immediately. As shown
in Table 11-7, you exercised BPJ to include the following in the permit:
1. COD monitoring requirements;
2. Monitoring frequencies for conventional pollutants; and
3. Mandatory flow measurements of bleach plant and final effluent.
Make sure you include the following in the permit:
• A reopener clause so that you may include COD permit limits when EPA
promulgates ELGs for this pollutant (see Section 8);
• Dilution prohibition as a permit condition (see Section 8);
• Process upsets as a permit condition (see Section 8); and
• BMP requirements as permit conditions (see Section 9).
11-39
-------
Table 11-7; Permit Limits for PaperTech Corporation
Pollutant
TCDD
TCDD
TCDF
TCDF
Chloroform
Chloroform
Trichloro sy ringol
Trichloro sy ringol
3,4,5-
Trichlorocatechol
3,4,5-
Trichlorocatechol
3,4,6-
Trichlorocatechol
3,4,6-
Trichlorocatechol
3,4,5-
Trichloroguaiacol
3,4,5-
Trichloroguaiacol
3,4,6-
Trichloroguaiacol
3,4,6-
Trichloroguaiacol
4,5,6-
Trichloroguaiacol
4,5,6-
Trichloroguaiacol
2,4,5-
Trichlorophenol
2,4,5-
Trichlorophenol
Permit Limits
1-Day
Maximum
<10pg/L
<10pg/L
31.9pg/L
31.9pg/L
4.33 kg/day
4.39 kg/day
<2.5 ng/L
<2.5 ng/L
<5.0 ng/L
<5.0 ng/L
<5.0 ng/L
<5.0 ng/L
<2.5 ng/L
<2.5 ng/L
<2.5 ng/L
<2.5 ng/L
<2.5 ng/L
<2.5 ng/L
<2.5 ng/L
<2.5 ng/L
Monthly
Average
--
--
--
--
2.59
kg/day
2.62
kg/day
--
--
—
--
--
—
--
—
—
--
—
--
--
—
Effluent Sampling Location
BPE for Fiber Line #1
BPE for Fiber Line #2
BPE for Fiber Line #1
BPE for Fiber Line #2
BPE for Fiber Line #1
BPE for Fiber Line #2
BPE for Fiber Line #1
BPE for Fiber Line #2
BPE for Fiber Line #1
BPE for Fiber Line #2
BPE for Fiber Line #1
BPE for Fiber Line #2
BPE for Fiber Line #1
BPE for Fiber Line #2
BPE for Fiber Line #1
BPE for Fiber Line #2
BPE for Fiber Line #1
BPE for Fiber Line #2
BPE for Fiber Line #1
BPE for Fiber Line #2
Sample
Frequency
Monthly
Monthly
Monthly
Monthly
Weekly
Weekly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Sample
Collection
Method
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
11-40
-------
Pollutant
2,4,6-
Trichlorophenol
2,4,6-
Trichlorophenol
Tetrachlorocatechol
Tetrachlorocatechol
Tetrachloroguaiacol
Tetrachloroguaiacol
2,3,4,6-
Tetrachlorophenol
2,3,4,6-
Tetrachlorophenol
Pentachlorophenol
Pentachlorophenol
AOX
COD*
BOD5
TSS
pH
Flow*
Flow*
Flow*
Permit Limits
1-Day
Maximum
<2.5 ng/L
<2.5 ng/L
<5.0 ng/L
<5.0 ng/L
<5.0 ng/L
<5.0 ng/L
<2.5 ng/L
<2.5 ng/L
<5.0 ng/L
<5.0 ng/L
896 kg/day
Report
11,9 10 kg/day
22,740 kg/day
5-9
Report
Report
Report
Monthly
Average
-
—
-
-
-
-
-
—
-
-
561 kg/day
-
6,305
kg/day
12,180
kg/day
-
Report
Report
Report
Effluent Sampling Location
BPE for Fiber Line #1
BPE for Fiber Line #2
BPE for Fiber Line #1
BPE for Fiber Line #2
BPE for Fiber Line #1
BPE for Fiber Line #2
BPE for Fiber Line #1
BPE for Fiber Line #2
BPE for Fiber Line #1
BPE for Fiber Line #2
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Final Effluent
BPE for Fiber Line #1
BPE for Fiber Line #2
Final Effluent
Sample
Frequency
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Daily
Weekly
3 Days/Week
3 Days/Week
5 Days/Week
Continuous
Continuous
Continuous
Sample
Collection
Method
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
Grab
Recorder
Recorder
Recorder
"--" Monthly averages do not apply for pollutant.
BPE - Bleach Plant Effluent.
*Reporting for COD and flow based on BPJ.
11-41
-------
Commerce Pulp Company manufactures market pulp and printing papers. The company operates a
bleached kraft fiber line. All
process wastewaters generated by
Commerce Pulp is sent to the Sutton
City POTW. The POTW is revising
the pretreatment control agreement
to include discharge limits for
chlorinated pollutants.
#7
1. Pretreatment control agreements for mills with
operations in Subparts B.
2. Production rate determination.
Commerce Pulp operates a bleached kraft fiber line that generates bleached pulp that is used to
manufacture market pulp and printing papers.
for 1
The table below summarizes relevant information for establishing a pretreatment control
agreement for Commerce Pulp Company.
Information Needed to Establish Pretreatment Limits for Case Study #7
What type of discharger is the mill?
Under which subpart(s) do the mill's operations fall?
The mill is subject to which E.G.&S?
Is the mill planning on entering VATIP?
Does mill use wet barking; log washing or chip
washing; or log flumes or log ponds?
Does the mill certify using TCP?
Does the mill use biocides?
Indirect
Subparts B
PSES (40 CFR 430.26)
No
No
No
No
1 I
c
Commerce Pulp is subject to PSES for mills with operations and Subpart B. You must establish
concentration- and mass-based permit limits. For concentration-based limits, you must simply
denote the concentration value specified in 40 CFR 430.24 for the appropriate compliance point in
the permit.
11-42
-------
Example: Concentration-Based Limit Calculation
TCDF: Maximum for one day = 31.9 pg/L
TCDD: Maximum for one day =
-------
In review
years, y
Decemt
determii
permit 1
Comme
kraft pu
you can
permit 1
900
CASE STUDY #7
wing the monthly production data for Commerce Pulp from the last five
DU find that the maximum production occurred from January 1997 -
er 1 997. The monthly production data from this time period will
le the production rate that results in the maximum AOX and chloroform
units.
Date
1/97
2/97
3/97
4/97
5/97
6/97
7/97
8/97
9/97
10/97
11/97
12/97
Total Production
(ADMT/year)
Total Op. Days/Year
Total Production
(ADMT/day)
Bleached Kraft Pulp
Production (ADMT/month)
25,500
25,125
25,125
25,600
25,125
24,700
24,900
25,225
25,100
25,600
24,800
24,700
301,500
335
900
rce Pulp provided an 8% shrinkage factor for the bleached papergrade
p production data submitted with their permit application. As a result,
calculate the production rate for determining AOX and chloroform
units as follows:
/(I -0.08) = 978 ADMT = 978 kkg of unbleached papergrade kraft pulp
entering the bleach plant.
11-44
-------
You may then determine permit limits for AOX and chloroform by using the following equation:
Bleach Plant or Final Effluent Limit = PROD x LIMIT
where:
PROD
LIMIT
Production rate for AOX and chloroform; and
Toxic and nonconventional pollutant E.G.
Subcategory
Subpart B
Production
978
kkg/day
Chloroform
Daily Maximum
Standard
6.92
g/kkg
Total
6.8
Kg/day
Monthly Average
Standard
4.14
g/kkg
Total
4.0
kg/day
AOX
Daily Maximum
Standard
2.64
kg/kkg
Total
2,580 kg/day
Monthly Average
Standard
1.41
kg/kkg
Total
1,380 kg/day
Final Pretreatment Limits for Commerce Pulp
The table below presents the pretreatment limits for Commerce Pulp Company. As shown in the
table, the pretreatment control
authority decided to include the
following in the permit:
Note. For indirect dischargers, pretreatment limits
for AOX must be established for bleach plant effluent.
2.
3.
COD monitoring
requirements.
Monitoring frequencies for conventional pollutants.
Mandatory flow measurements of bleach plant and final effluent.
In addition, the pretreatment control authority must require Commerce Pulp to implement BMPs
by the schedule specified in the regulation.
11-45
-------
Table 11-8; Permit Limits for Commerce Pulp Company
Pollutant
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
AOX
COD*
Flow*
Flow*
Permit Limits
1-Day Maximum
<10 pg/L
31.9pg/L
6. 8 kg/day
<2.5 ug/L
<5.0 ug/L
<5.0 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<5.0 ug/L
<5.0 ug/L
<2.5 ug/L
<5.0 ug/L
2,580 kg/day
Report
Report
Report
Monthly
Average
-
-
4.0 kg/day
-
-
-
-
-
-
-
-
-
-
-
-
1,380 kg/day
-
Report
Report
Effluent Sampling Location
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
Bleach Plant Effluent
End-of-Pipe Effluent
Bleach Plant Effluent
End-of-Pipe Effluent
Sample
Frequency
Monthly
Monthly
Weekly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Monthly
Daily
Weekly
Continuous
Continuous
Sample Collection
Method
24 hr composite
24 hr composite
6 grabs/24 hr
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
Recorder
Recorder
"--" Monthly averages do not apply for pollutant.
*Reporting for COD and flow based on BPJ.
11-46
-------
The Great American Paper
Company manufactures fine
paper and paperboard. The
mill, which discharges
wastewater into the Redbanks
River, has informed you that
they wish to enter Voluntary
Advanced Technology
Incentives Program (VATIP).
Although their NPDES permit
does not expire until February
15, 2000, the company has
indicated its intent to enroll in
the program by submitting a letter to the permitting authority. The letter was signed by the
corporate officials as specified in 40 CFR 122.22.
#8
1. VATIP permit process
2. VATIP compliance schedules
3. Calculation of EEQ
4. VATIP monitoring requirements
5. Accelerated VATIP rewards.
The Great American Paper Company operates two bleached kraft fiber lines to produce fine paper
and paperboard. One fiber line
(Fiber Line #1) is dedicated to
pulping and bleaching pine, a
softwood, to produce bleached kraft
pulp used in the manufacture of
Note. Installation of oxygen delignification does not
trigger NSPS. See "new source " definition in
Section 7.
paperboard. In 1992, the mill
installed oxygen delignification systems on Fiber line #1 to improve mill productivity and effluent
quality. Fiber Line #1 currently meets BAT Tier I limits. A second fiber line (Fiber Line #2)
pulps and bleaches birch, a hardwood, to produce fine paper. The mill has approved a plan to
install a two-stage oxygen delignification system on Fiber line #2 by June 2003, so they can enroll
Fiber Line #2 in VATIP. Pertinent process information for each fiber line, including the planned
bleach sequence for Fiber Line #1, is summarized below:
Fiber line
Fiber line #1
Fiber line #2
Current Bleach
Sequence
ODEoD
CdEDED
Kappa Number
after Oxy Delig
17
12
Future Bleach
Sequence
ODEoD
OODED
The mill has informed you that they would like to enroll both fiber lines in Tier I of VATIP. In
order to immediately receive rewards associated with the program, the mill elected to by-pass EEQ
and interim milestones for Fiber line #1 altogether, achieving all of the VATIP limitations for Tier
1 immediately. Because the mill does not plan to install and operate oxygen delignification on
11-47
-------
Fiber Line #2 until June 2003, you must establish Stage 1 permit limits for Fiber Line #2 that are
based on either EEQ or current permit limits (if any) for the chlorinated pollutants. The table
below summarizes relevant information for establishing permit limits.
Relevant Information for Establishing Permit Limits for Case Study #8
What type of discharger is the mill?
Under which subpart(s) do the mill's operations fall?
The mill is subject to which ELG&S?
Is the mill planning on entering VATIP?
Does mill use wet barking; log washing or chip
washing; or log flume or log ponds?
Does the mill certify using TCP?
Does the mill use biocides?
Direct
Subpart B
BPT (40 CFR 430.22)
Fine Paper Segment
BAT (40 CFR 430.24)
Yes, therefore, in addition to BPT, the mill is subject
to the following BAT regulation under 40 CFR
430.24:
1) Immediate Stage 1 permit limits based on VATIP
Tier I for Fiber line #1 and EEQ (or current permit
limits) for Fiber line #2
2) Interim milestones based on progress in installing
and operating two-stage OD system on Fiber line #2.
Since mill intends to install and operate OD by June
2003, you should consider establishing interim
milestones at or prior to that time.
3) Stage 2 permit limits that include Tier I ultimate
VATIP requirements for both lines no later than
April 15, 2004.
No
No
No
Establishing Stage 1 Permit Limits
Remember, Stage 1 permit limits are intended to ensure that, at a minimum, existing effluent
quality is maintained as the mill moves toward meeting Stage 2 permit limitations. Since Great
American Paper has elected to accept Stage 2 permit limits for Fiber Line #1, permit limits as the
mill enters the program must include:
1. Conventional pollutant permit limits based on BPT for the fine paper segment
and the paperboard, coarse paper, and tissue segment.
2. Toxic and nonconventional pollutant permit limits for Fiber line #1 based on
baseline BAT and VATIP requirement for Tier I (see Step #5 for AOX).
11-48
-------
3. Toxic and nonconventional pollutant permit limits for Fiber line #2 based on
EEQ.
4. AOX permit limits based on the load attributable to Fiber line #1 (using Tier I
BAT) and the load attributable to Fiber line #2 (using EEQ).
5.
A reopener clause.
Step #1 - Conventional pollutant permit limits - BPT
Great American Paper manufactures two products (fine paper and paperboard) that fall under two
segments of Subpart B. Because conventional pollutant ELGs are mass-based (with the exception
of pH), you must review the mill's permit application to determine production rate. The text box
below presents the production rate.
1
1
\. review of their permit application reveals that the production rates that result in
he maximum pollutant loads are from the following data.
Date
12/97
1/98
2/98
3/98
4/98
5/98
6/98
7/98
8/98
9/98
10/98
11/98
Total Production
(OMMT/year)
Total Op. Days/Year
Total Production
(OMMT/day)
Paperboard Segment
Production Rate
(OMMT/month)
22,600
22,700
22,700
22,500
22,600
22,750
22,300
23,200
22,750
22,800
23,300
22,800
273,000
350
780
Fine Paper Production
Rate
(OMMT/month)
18,300
17,900
17,700
18,500
18,300
18,000
17,500
17,900
17,700
18,200
18,400
18,600
217,000
350
620
11-49
-------
You may then calculate the conventional pollutant permit limits by using the following equation:
Final Effluent Limit = £ (PROD, x LIMIT,)
where:
PROD, = Production Rate
LIMIT; = ELG for conventional
i = Segment
Final Effluent Limit = (PRODfinepaper x LIMITflnepaper) + (PRODpaperboard x LIMITpaperboard)
Refer to Table 11-X which presents the calculated Stage 1 permit limits.
#2 - #1
VATIP I
Because the mill elected to receive Stage 1 requirements immediately, you must establish permit
limits for Fiber Line #1 based on baseline BAT for TCDD, TCDF, chloroform, and the 12
chlorinated phenolic compounds and Tier I VATIP requirements for AOX and kappa number
(AOX permit limits are discussed in Step #5). With the exception of AOX and chloroform, which
have mass-based ELGs, you must simply denote the concentration-based limit specified as BAT
for the chlorinated pollutants limited in Fiber line #l's bleach plant effluent.
For AOX and chloroform permit limits, you must first determine the production rate of unbleached
pulp entering the bleach plant. Using the maximum production time period illustrated above, the
following table explains how to calculate the production rate for these pollutants (also see Section
8 for a description of how to determine production rate).
11-50
-------
Data from
Fiber line t
Great Ame
pulp produ
rate for cal
6247(1-0.
the permit application that yield the production rate for AOX and chloroform for
tl.
Date
12/97
1/98
2/98
3/98
4/98
5/98
6/98
7/98
8/98
9/98
10/98
11/98
Total Production (OMMT/yr)
Total Op. Days/Year
Total Production (OMMT/day)
Fiber line #1 Bleached Pulp
Production Rate (OMMT)
18,200
17,900
18,200
17,600
18,400
18,600
18,500
18,200
18,200
18,000
18,100
18,500
218,400
350
624
rican Paper provided an 8% shrinkage factor for the bleached papergrade kraft
ction data submitted with their permit application. As a result, the production
sulating AOX and chloroform permit limits is as follows:
38) = 687 OMMT of unbleached papergrade kraft pulp entering the bleach plant.
With the production rate, you may determine permit limits for AOX and chloroform by using the
following equation:
Bleach Plant or Final Effluent Limits = PROD x LIMIT
where:
PROD
LIMIT
Production rate for AOX and chloroform
Toxic and non-conventional pollutant ELG
Refer to Table 11-9 which presents the calculated Stage 1 permit limits.
11-51
-------
Step #3 - Toxic and nonconvcntional pollutant permit limits for Fiber line #2 based on EEQ.
In their previous permit, Great American Paper was not subject to permit limits for any chlorinated
pollutants. Since Great American Paper uses chlorine on Fiber Line #2, the fiber line has existing
effluent quality (EEQ) that is of poorer quality than baseline BAT. As a result, you must establish
permit limits for chlorinated pollutants based on EEQ (Note: EPA recommends you calculate EEQ
permit limits expressed as mass/day rather than concentrations or mass per unit production). EEQ
permit limits should be calculated by using mill sampling results, estimating a "long term average"
(in mass/day) for each pollutant, and multiplying the long term average by a variability factor.
Appendix E presents detailed calculation procedures for determining EEQ. The calculation of
EEQ for AOX is shown below.
• Step 1 - Collect Wastewater Samples
You receive the 30 days of data the mill has collected for AOX (with flow
measurements for each sample collected).
• Step 2 - Review Wastewater Sampling Data
In your review of the data, you make sure Great American did not submit
multiple sampling measurements from the same day.
Step 3 - Calculate Mass/Day for Each Sampling Result
Using the data points, you calculate the mass per day of each sample collected.
AOX Data Point
1
2
30
Concentration
20.5 g/L
30.1 g/L
25.2 g/L
Final Effluent
106,400,000 L/day
100,000,000 L/day
103,450,000 L/day
Mass/Day
2, 180 kg/day
3,010 kg/day
2,600 kg/day
11-52
-------
production).
Step 4 - Calculate Long-Term Averages (LTAs) for Each Pollutant
Using the calculated mass per day, you may determined the LTA.
AOX Data Point
1
2
30
LTA
Mass/Day
2, 180 kg/day
3,010 kg/day
2,600 kg/day
2,800 kg/day
Step 5 - Calculate EEQ Permit Limits by Applying Variability Factors
Use the following variability factor suggested in Appendix E to develop the daily
maximum and monthly average for AOX:
Limitation
Daily Maximum
Monthly Average
Variability Factor
(VF)
1.86
1.22
Mass/Day
2,800 kg/day
2,800 kg/day
VF x Mass/Day
5,200 kg/day
3,420 kg/day
Also, you could do your own variability analysis of data if there is an adequate
number of data points.
Step 6 - Determining AOX Load Attributable to Fiber Line #2
This may be determined by attributing the Fiber Line #1 fraction of total
unbleached pulp production. The following table summarizes the AOX loads:
Type of
Limitation
Daily Maximum
Monthly Average
Limit
5,200 kg/day
3,480 kg/day
Attributable Load
(a)
45%
45%
Limit x
Attributable Load
2,340 kg/day
1,530 kg/day
(a) This is calculate as Fiber Line #2 production + (Fiber Line #1 + #2
Step 7 - Compare Permit Limits Based on EEQ with Existing Permit Limits
Previously, Great American was not subject to AOX limits; therefore, the sum of
EEQ had from Fiber Line #2 and the BAT allowable load from Fiber Line #1
serves as Stage 1 permit limit.
11-53
-------
#4 - on to #1
and the to #2
Because AOX is limited in final effluent, Stage 1 permit limits must equal the sum of AOX load
from Fiber line #1, which is the product of the line's production rate and the baseline Tier I AOX
ELG, and the AOX load from Fiber line #2, which is based on EEQ. Stage 1 permit limits are as
follows:
AOX 1-Day Maximum Limit = (AOX load form Fiber Line #1 based on BAT) +
(AOX load from Fiber Line #2 based on EEQ) = (687 kkg x 58 kg/kkg x 55% (production load for
Line #1) + (2,340 kg from Step 3)
AOX 1-Day Maximum Limit = 2,560 kg/day
AOX Monthly Average Limit = (687 kkg x 0.58 kg/kkg x) + (1,520 kg/day from Step 3) = 1,750
kg/day
#5 -
Great American Paper's next permit should include a reopener clause. By including the reopener
clause, you may modify permit limits at any time. This is especially important for interim
milestones, which may need to be adjusted during the permit period. The interim milestones
should be adjusted, if necessary, to reflect the results of research, process development, mill trials,
and contingencies.
Great American Paper Stage 1 Permit. The table below presents Great American Paper's Stage
1 permit limits. Note that because Fiber Line #2 is subject to ultimate Stage 2 VATIP
requirements for Tier I, the mills must perform monthly chloroform sampling on Fiber Line #1 is
reduced from weekly to monthly (and then quarterly after the first year in the program).
1
Pollutant
TCDD
TCDD (a)
TCDF
TCDF (a)
Chloroform
Chloroform (a)
Trichlorosyringol
Trichlorosyringol (a)
3,4,5-Trichlorocatechol
3,4,5-Trichlorocatechol (a)
3,4,6-Trichlorocatechol
3,4,6-Trichlorocatechol (a)
Permit Limits
IDay
Maximum
<10 pg/L
512g/day
3 1.9 pg/L
620 g/day
4. 7 kg/day
11.7 kg/day
<2.5 ng/L
31 g/day
<5.0 ug/L
1,370 g/day
<5.0 ug/L
375 g/day
Monthly Average
-
-
-
-
2. 8 kg/day
7.0 kg/day
-
-
-
-
-
-
Effluent Sampling
Location
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
Sample Frequency
Monthly (lyr)(b)
Monthly
Monthly (lyr)(b)
Monthly
Monthly (lyr)(b)
Weekly
Monthly (lyr)(b)
Monthly
Monthly (lyr)(b)
Monthly
Monthly (lyr)(b)
Monthly
Sample Collection
Method
24 hr composite
24 hr composite
24 hr composite
24 hr composite
6 grabs/24 hr
6 grabs/24 hr
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
11-54
-------
Pollutant
3,4,5-Trichloroguaiacol
3,4,5-Trichloroguaiacol
(a)
3,4,6-Trichloroguaiacol
3,4,6-Trichloroguaiacol
(a)
4, 5,6-Trichloroguaiacol
4, 5,6-Trichloroguaiacol
(a)
2,4,5-Trichlorophenol
2,4,5-Trichlorophenol (a)
2,4,6-Trichlorophenol
2,4,6-Trichlorophenol (a)
Tetrachlorocatechol
Tetrachlorocatechol (a)
Tetrachloroguaiacol
Tetrachloroguaiacol (a)
2,3,4,6-Tetrachlorophenol
2,3,4,6-Tetrachlorophenol
(a)
Pentachlorophenol
Pentachlorophenol (a)
AOX
COD
BODj
TSS
PH
Flow
Flow
Flow
Kappa Number
Permit Limits
IDay
Maximum
<2.5 ug/L
1,100 g/day
<2.5 ug/L
353 g/day
<2.5 ug/L
195 g/day
<2.5 ug/L
235 g/day
<2.5 ug/L
3 13 g/day
<5.0 ug/L
391 g/day
<5.0 ug/L
509 g/day
<2.5 ug/L
548 g/day
<5.0 ug/L
275 g/day
2,560 kg/day
Report
14, 721 kg/day
28,819 kg/day
5-9
Report
Report
Report
18 kappa units
Monthly Average
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
1,750 kg/day
-
7,655 kg/day
16,054 kg/day
-
Report
Report
Report
-
Effluent Sampling
Location
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Final Effluent
BPE from Fiber line #1
BPE from Fiber line #2
Final Effluent
Fiber Line #1 - pulp exiting
OD system prior to bleaching
Sample Frequency
Monthly (lyr)(b)
Monthly
Monthly (lyr)(b)
Monthly
Monthly (lyr)(b)
Monthly
Monthly (lyr)(b)
Monthly
Monthly (1 yr)
Monthly (b)
Monthly (lyr)(b)
Monthly
Monthly (lyr)(b)
Monthly
Monthly (lyr)(b)
Monthly
Monthly (lyr)(b)
Monthly
Daily
Weekly
3 Days/Week
3 Days/Week
5 Days/Week
Continuous
Continuous
Continuous
Sample Collection
Method
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
Grab
Recorder
Recorder
Recorder
BPE = Bleach Plant Effluent
(a) Based on EEQ.
(b) Sampling frequency reduced to quarterly after the first year because Fiber Line #2 meets Tier I Stage 2.
11-55
-------
Intermediate Milestones
To help you update permit limits based on the mill's progress in implementing technologies, you
require the Great American Paper Company to submit a Milestones Plan.
Milestones Plan
EPA published new regulatory language on July 7, 1999 in the Federal Register (36580-36586)
describing the Milestones Plan in §430.24(c). You must require the plan under your authority to
use Best Professional Judgement to establish permit conditions. For example, Great American's
Milestone Plan must lay out (in much more detail) the following schedule:
Technology
install additional brown stock washing stage
install two-stage oxygen delignification system,
including post-oxygen washing and mixing and control
systems
upgrade white liquor oxidizing equipment to increase
capacity
upgrade existing chlorine dioxide generator to expand
capacity
add chlorine dioxide storage facilities
Begin
Construction
March 1999
April 2001
April 2002
June 2002
January 2003
Complete
Construction
October 1999
April 2003
April 2003
September 2003
September 2003
Process Fully
Operational
January 2000
June 2003
June 2003
January 2004
January 2004
In addition, the Milestone Plan must present the anticipated reductions in effluent quantity and
improvements in effluent quality as measured at the bleach plant (for bleach plant, pulping area
and evaporator condensates flow and BAT parameters other than Adsorbable Organic Halides
(AOX)) and at the end of the pipe (for AOX).
Interim Milestones
You musts develop enforceable interim milestones to ensure that Great American Paper makes
continuous progress on the improvements to Fiber Line #2. The milestones, based on your
professional judgment and information provided in Great American's Milestone Plan, can be
expressed as narrative or numeric conditions in the mill's permit.
Stage 2 Permit Limits
By April 15, 2004, you must establish Stage 2 permits limits based on the ultimate limitations for
the selected tier for each fiber line. In this case, you must update permit limits for Fiber line #2 so
that they include the baseline BAT and ultimate VATIP requirements for Tier I. You should
revise the permit to include:
1. Updated conventional pollutant limits based on BPT for the fine paper segment and the
paperboard, coarse paper, and tissue segment. Or, if the mill has modified paper
manufacturing operations, you must account for new production (for the purpose of this
11-56
-------
case study, we assume that Great American Paper continues to manufacture fine paper
and paperboard at constant production rates. For an actual permit, you must review
production data to make this determination.).
2. Updated mass-based toxic and nonconventional pollutant limits (i.e., AOX and
chloroform) for Fiber line #1 based on baseline BAT and VATIP Tier I (for the purpose
of this case study, we assume that unbleached kraft pulp production rate has remained
constant).
3. Toxic and nonconventional pollutant limits for Fiber line #2 based on baseline BAT and
VATIP Tier I.
4. AOX permit limits based on the allowable loads, as limited by Tier I, attributable to both
fiber lines.
#3 - Toxic for #2 on BAT
VATIP for Tier I,
For Stage 2 permit limits, you must establish updated permit limits for Fiber line #2 based on
baseline BAT for TCDD, TCDF, chloroform, and the 12 chlorinated phenolic compounds and Tier
I VATIP requirements for AOX and kappa number (AOX permit limits are discussed in Step #4).
#4 - on the as In Tier I,
to
Since AOX is limited in final effluent, you must simply multiply the total unbleached pulp
production rate by the AOX limit. See Table 11-10 below.
Stage 2 permit limits. The table below presents Great American Paper's Stage 2 permit limits. If
Great American Paper consistently meets permit limits, you have included a provision that allows
for reduced monitoring frequencies for chlorinated pollutants. The permit allows for reduced
monitoring one year after consistently meeting baseline BAT and VATIP requirements. The table
below presents the mill's Stage 2 permit limits.
1 '"'.III I I III" Sta«
in III limits,
Pollutant
TCDD
TCDD
TCDF
TCDF
Chloroform
Chloroform
Trichlorosyringol
Trichlorosyringol
3,4,5-Trichlorocatechol
Permit Limits
IDay
Maximum
<10 pg/L
<10 pg/L
3 1.9 pg/L
3 1.9 pg/L
4. 7 kg/day
3.6 kg/day
<2.5 ug/L
<2.5 ug/L
<5.0 ug/L
Monthly
Average
-
-
-
-
2. 8 kg/day
2. 1 kg/day
-
-
-
Effluent Sampling Location
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
Sample Frequency
Quarterly
Monthly (1 yr) (a)
Quarterly
Monthly (1 yr) (a)
Quarterly
Monthly (1 yr) (a)
Quarterly
Monthly (1 yr) (a)
Quarterly
Sample Collection
Method
24 hr composite
24 hr composite
24 hr composite
24 hr composite
6 grabs/24 hr
6 grabs/24 hr
24 hr composite
24 hr composite
24 hr composite
11-57
-------
Pollutant
3,4,5-Trichlorocatechol
3,4,6-Trichlorocatechol
3,4,6-Trichlorocatechol
3,4,5-Trichloroguaiacol
3,4,5-Trichloroguaiacol
3,4,6-Trichloroguaiacol
3,4,6-Trichloroguaiacol
4, 5,6-Trichloroguaiacol
4, 5,6-Trichloroguaiacol
2,4,5-Trichlorophenol
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,6-Trichlorophenol
Tetrachlorocatechol
Tetrachlorocatechol
Tetrachloroguaiacol
Tetrachloroguaiacol
2,3,4,6-
Tetrachlorophenol
2,3,4,6-
Tetrachlorophenol
Pentachlorophenol
Pentachlorophenol
AOX
COD
BOD5
TSS
PH
Flow
Flow
Flow
Kappa Number
Kappa Number
Permit Limits
IDay
Maximum
<5.0 ug/L
<5.0 ug/L
<5.0 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<2.5 ug/L
<5.0 ug/L
<5.0 ug/L
<5.0 ug/L
<5.0 ug/L
<2.5 ug/L
<2.5 ug/L
<5.0 ug/L
<5.0 ug/L
712 kg/day
Report
14, 721 kg/day
28,819 kg/day
5-9
Report
Report
Report
1 8 kappa units
13 kappa units
Monthly
Average
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
320 kg/day
-
7,655 kg/day
16,054 kg/day
-
Report
Report
Report
-
-
Effluent Sampling Location
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
BPE from Fiber line #1
BPE from Fiber line #2
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Final Effluent
BPE from Fiber line #1
BPE from Fiber line #2
Final Effluent
Fiber Line #1 - pulp exiting
OD system prior to bleaching
Fiber Line #2 - pulp exiting
OD system prior to bleaching
Sample Frequency
Monthly (1 yr) (a)
Quarterly
Monthly (1 yr) (a)
Quarterly
Monthly (1 yr) (a)
Quarterly
Monthly (1 yr) (a)
Quarterly
Monthly (1 yr) (a)
Quarterly
Monthly (1 yr) (a)
Quarterly
Monthly (1 yr) (a)
Quarterly
Monthly (1 yr) (a)
Quarterly
Monthly (1 yr) (a)
Quarterly
Monthly (1 yr) (a)
Quarterly
Monthly (1 yr) (a)
Daily (yr 1)
Monthly (after yr 1)
Weekly
3 Days/Week
3 Days/Week
5 Days/Week
Continuous
Continuous
Continuous
Sample Collection
Method
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
24 hr composite
Grab
Recorder
Recorder
Recorder
BPE = Bleach Plant Effluent
11-58
-------
1. Permit process for integrated mills with
operations in Subpart B who also purchase pulp.
2. Production rate determination.
Sunburst Paper is an integrated pulp
and paper mill that manufactures fine
paper. Sunburst Paper operates a TCP
bleached papergrade kraft fiber line
and also purchases market pulp for use
in their fine paper production. All
process wastewaters generated by
Sunburst Paper are treated using
primary and secondary treatment prior
to discharge into the Eva River. The
mill has submitted a permit application because their current NPDES permit expires December
2000.
3.
AOX contributions from purchased pulp where
on-site pulp bleaching is TCP.
Sunburst Paper operates a TCP bleached kraft fiber line producing bleached pulp that is used along
with purchased pulp to manufacture fine papers. The purchased pulp makes up 50% of the final
fine paper product.
for I
The table below summarizes the relevant information from the permit application you need to
calculate discharge limits for the reissued NPDES permit.
11-59
-------
Information Needed to Establish Permit Limits for Case Study #9
What type of discharger is the mill?
Under which subpart(s) do the mill's operations fall?
The mill is subject to which ELG&S?
Is the mill planning on entering VATIP?
Does mill use wet barking; log washing or chip
washing; or log flumes or log ponds?
Does the mill certify using TCP?
Does the mill use chlorophenolic biocides?
Direct
Subparts B
Subpart B
BPT (40 CFR 430.22)
Pulp and Fine Paper Segment
BAT (40 CFR 430.24)
[Note: The Subpart K ELG&S do not apply since
this is an integrated mill]
No
No
Yes (The mill also purchases pulp that is not TCP.)
No
Determining Permit Limits for Pollutants Regulated Under BPT
Sunburst Paper manufactures one product (fine paper) that falls under one subcategory of Subpart
B. Because BPT ELGs are mass-based, you must review their permit application to determine
production rates for each product to calculate their BPT limits. The table below explains how to
calculate the production rate (also see Section 8 for a description of how to calculate production
rates).
11-60
-------
In reviewing th
that the maxim
production dat
maximum pern
CASE STUDY #9
e monthly production data for Sunburst Paper from the last five years, you find
um production occurred from November 1997 - October 1998. The monthly
i from this time period will determine the production rate that results in the
ait limits for conventional pollutants.
Date
11/97
12/97
1/98
2/98
3/98
4/98
5/98
6/98
7/98
8/98
9/98
10/98
Production Total
(OMMT/yr)
Total Op. Days/Year
Production Total
(OMMT/day)
Fine Paper Production
(OMMT)
11,100
11,300
12,400
11,200
12,500
11,200
11,400
1,600
11,700
11,900
11,800
11,900
140,000
350
400
11-61
-------
You may then calculate conventional pollutant permit limits using the following equation:
where:
Final Effluent Limit = PROD x Limit
PROD
LIMIT
Production rate (kkg/day)
ELG for conventional pollutant (kg/kkg)
The table below presents the calculation of conventional pollutant permit limits calculated for this
mill.
Subcategory
Subpart B
Segment
Fine Paper
Production
400 kkg/day
TSS
Dally Maximum
ELG
22.15
kg/kkg
Subtotal
8,860
kg/day
Monthly Average
ELG
11.9
kg/kkg
Subtotal
4,760
kg/day
BOD
Daily Maximum
ELG
10.6
kg/kkg
Subtotal
4,240 kg/day
Monthly Average
ELG
5.5
kg/kkg
Subtotal
2,200
kg/day
Determining Permit Limits for Pollutants Regulated Under BAT
The TCP bleaching operations at Sunburst Paper are covered under Subpart B. The BAT ELG&S
include a maximum daily limitation for AOX at the mill final effluent of
-------
The mill purchases 200 ADMT/day of non-TCF pulp. The mill no-net AOX balance shows that 0.2
kg/kkg of AOX results from the use of the purchased pulp. The AOX allowable limit is therefore:
AOX Allowable Limit = 200 kkg/d x 0.2 kg/kkg = 40 kg/d
Final Permit Limits for Sunburst Paper
Table 11-11 presents the permit limits for Sunburst Paper. The table also shows that you exercised
BPJ to include the following in the permit:
1. COD monitoring requirements;
2. Monitoring frequencies for conventional pollutants; and
3. Mandatory flow measurements of bleach plant and final effluent.
Make sure you also include the following in the permit:
• A reopener clause so that you may include COD permit limits when EPA
promulgates ELGs for this pollutant (see Section 8);
• Dilution prohibition as a permit condition (see Section 8);
• Process upsets as a permit condition (see Section 8); and
• BMP requirements as permit conditions (see Section 9).
Table 11-11: Permit Limits for Sunburst Paper
Pollutant
AOX
COD*
BOD5
TSS
PH
Flow*
Flow*
Permit Limits
1 Day Maximum
40 kg/day
Report
4,240 kg/day
8,860 kg/day
5-9
Report
Report
Monthly
Average
-
-
2,200 kg/day
4,760 kg/day
-
Report
Report
Effluent Sampling Location
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Final Effluent
Kraft Mill Fiber Line BPE
Final Effluent
Sample Frequency
Daily**
Weekly
3 Days/Week
3 Days/Week
5 Days/Week
Continuous
Continuous
Sample Collection
Method
24 hr composite
24 hr composite
24 hr composite
24 hr composite
Grab
Recorder
Recorder
*Reporting for COD and flow based on BPJ.
**Using BPJ you may want to reduce the AOX sample frequency after sufficient data is provided that shows consistent
compliance with the "no-net" AOX limits.
11-63
-------
This section presents additional sources of information, as well as EPA contacts, that may
help you obtain additional information related to implementation of the final pulp and
paper effluent limitations guidelines and standards for Subparts B and E. Specifically,
the section presents a list of selected documents, databases, and websites either relating
generally to the pulp and paper industry, or specifically to the pulp and paper Cluster Rules. These
lists also include information on how to reach EPA program personnel and how to access these
information sources.
Questions specifically related to the effluent limitations guidelines and standards for the pulp and
paper industry should be directed to:
Mr. Troy Swackhammer
Engineering and Analysis Division
Office of Water
U.S. EPA (4303)
401 M Street, SW
Washington, DC 20460
Tel: (202) 260-7128
Fax:(202)260-7185
E-Mail: swackhammer.j-troy@epa.gov
lp
This manual is one element in a broad spectrum of materials that are available related to the
regulations promulgated April 15, 1998 for mills with operations in Subparts B and E. The April
15, 1998 rule can be accessed at www.epa.gov/ost/pupppaper/id/finwtr2.pdf. Figure 12-1
illustrates some of the information currently available, as well as some other information resources
the Agency plans to develop in connection with the Cluster Rules. Following Figure 12-1 is a
summary of each resource and how to obtain the resource or more information about it.
12-1
-------
Documents Supporting the
1998 Promulgated Rule
Cluster Rule Support Documents
EPA Internet Homepage
CD-ROM
Documents Relating to
Implementation/Enforcement
of the 1998 Promulgated Rule
MACT Implementation Guide
OECA Compliance Guide
General Information About
Permits and NPDES Program
NPDES Permit Writers Guide
WQBEL Documents
NPDES Compliance Inspection Manual
Introduction to the National Pretreatment Program
General Information About
Pulp and Paper
Sector Notebook
Handbook for Pulp and Paper Technologists
Databases
SFIP
PCS
IDEA
ERNS
TRI
Websites
the
EPA Internet Homepage
EPA/OST Pulp and Paper Website
EPA/OAQPS Pulp and Paper Website
TAPPI Website
Cluster Rule Support Documents. In support of the proposed and final cluster
rule, EPA developed technical support documents for both the water and air
regulations. These documents present the information and rationale supporting
the MACT-based NESHAPs and the effluent limitations guidelines and
standards. They provide background information on industrial processes and
regulatory requirements; summarize data collection methods; provide a detailed
overview of air emission and wastewater characteristics, and the selection of
pollutant parameters; and discuss pollution prevention and control standards and
technologies, including cost estimates. Below is a list of these documents:
12-2
-------
Supplement Technical Development Document for the Pulp, Paper, and
Paperboard Category Effluent Limitations Guidelines and Standards,
and New Source Performance Standards (Subparts B and E), EPA-821-
R-97-011, October 1997
Technical Support Document for the Voluntary Advanced Technology
Incentives Program
Environmental Assessment
Technical Support Document for Best Management Practices for Spent
Pulping Liquor Management, Spill Prevention, and Control, EPA-821 -
R-97-011, October 1997
Analysis of Impacts of BAT Options on the Kraft Recovery Cycle
(abbreviated title: Recovery Impacts Document), August 12, 1997
Preliminary Report on the Relationship Between Dioxin Emissions
from Kraft Recovery Boilers and the Chloride Content of the Fuel,
November 1997
BAT Cost Model Support Document, June 14, 1996
Memorandum: Costing Revisions Made Since Publication of July 15,
1996 Notice of Data Availability (61 FR 36837), September 10, 1997
Data Available for Limitations Development for Toxic and
Nonconventional Pollutants, November 12, 1997
Final Analysis of Data Available for Development of COD Limitations,
August 25, 1997
Statistical Support Document for the Pulp and Paper Industry, Subpart
B, November 1997
• Background Information Document for the Final Air Rules
• Spent Pulping Liquor BMP Support Document. This 1997 document
("Technical Support Document for Best Management Practices for Spent
Pulping Liquor Management, Spill Prevention and Control, EPA-821-R-97-
011, October 1997) has been developed as part of developing the final cluster
rule and provides the technical background for BMP programs applicable to
spent pulping liquor management, spill prevention, and control at pulp and paper
facilities. The document includes chapters discussing wood pulping processes
and chemical recovery systems; the composition, toxicity, and source of spent
pulping liquor; current industry pollution control practices; and BMP
implementation, with estimated costs and effluent reduction benefits. See
http://www.epa.gov/ost/rules/Sfinal.
In addition, EPA plans to place a number of these documents on a CD-ROM to facilitate
their availability to the public. To be completed.
12-3
-------
to
The Pulp and Paper NESHAP: A Plain English Guide
::j OECA compliance guide
1 Kraft Pulp Mill Compliance Assessment Guidance
« NPDES Permit Writer's Manual. This 1996 EPA manual (EPA-833-B-96-
003) was prepared to provide the basic regulatory framework and technical
considerations that support the development of wastewater discharge permits as
required under the National Pollutant Discharge Elimination System (NPDES)
program.
« NPDES Compliance Inspection Manual. This 1994 EPA manual (EPA-300-
B-94- 014) was developed to support wastewater inspection personnel in
conducting NPDES field inspections, and to provide standardized inspection
procedures. The manual encourages a consolidated inspection approach, and is
organized in two parts. The first part addresses basic inspection components,
including technical information on documentation, recordkeeping and reporting,
sampling, and laboratory procedures. The second part provides information on
specific types of inspections, concluding with a discussion of multi-media
concerns. Contact NTIS (1-703-487-4650) to order a copy of this report.
« Guidance for Water Quality-Based Decisions: The TMDL Process. This
document (EPA-440-4-91-001) is intended to define and clarify the
requirements under Section 303(d) of the Clean Water Act. Its purpose is to aid
state water-quality program managers in understanding the application of total
maximum daily loads within the water quality-based approach to establish
pollution control limits for waters not meeting water quality standards.
« Technical Support Document for Water Quality-Based Toxics Control.
This document (EPA/505/2-90-001) was prepared as technical guidance for
assessing and regulating the discharge of toxic substances to waters of the United
States.
« Industrial User Permitting Guidance Manual. This document is intended to
provide guidance to Publicly Owned Treatment Works (POTWs) on the
development and issuance of industrial user (IU) permits.
EPA
« Sector Notebook. The EPA Office of Compliance in 1995 developed the
"Profile of the Pulp and Paper Industry" (EPA/310-R-95-015) as part of
EPA's sector notebook project. This notebook provides a sector-based profile of
air, water, and land pollution regulations for the pulp and paper industry. The
notebook reflects EPA's desire to move toward comprehensive sector-based
compliance programs for all industrial sectors. The notebook includes a detailed
discussion of paper and pulp industrial processes, chemical profiles, pollution
prevention opportunities, a summary of applicable federal statutes and
12-4
-------
Other
Databases
regulations, compliance history and initiatives, and resource lists. See
http://es.epa.gov.
Pollution Prevention Technologies for the Bleached Kraft Segment of the
U.S. Pulp and Paper Industry (1993). This report, published in 1993 by EPA's
Office of Pollution Prevention and Toxics (EPA/600/R-93/110), provides a
detailed description of pollution prevention techniques for pulp and paper
facilities, and includes a discussion of alternative pulping and bleaching
processes. Contact NTIS (1-703-487-4650) to order a hardcopy version of this
report.
Model Pollution Prevention Plan for the Kraft Segment of the Pulp and
Paper Industry (1992). This document, a product of EPA's Industrial Pollution
Prevention Project (EPA 910/9-92-030), provides a model pollution prevention
plan for the kraft segment of the pulp and paper industry as a whole. This model
plan includes both general background information, and numerous pollution
prevention options applicable to kraft processes. The model plan was developed
after implementation of a specific plan for the Simpson Tacoma Kraft Mill.
Contact NTIS (1-703-487-4650) to order a hardcopy version of this report.
Simpson Tacoma Pollution Prevention Plan (1992). This report ("Pollution
Prevention Opportunity Assessment and Implementation Plan for Simpson
Tacoma Kraft Company, Tacoma, Washington (EPA 910/9-92-027) reflects
a specific pollution prevention opportunity assessment and voluntary
implementation plan for a single kraft pulp mill. The plan was developed by
EPA Region 10 to serve as background for development of a model pollution
prevention plan for the kraft segment of the pulp and paper industry as a whole.
Contact NTIS (1-703-487- 4650) to order a hardcopy version of this report.
Handbook for Pulp & Paper Technologists (2d ed. 1992). This handbook,
written by pulp and paper expert G.A. Smook, provides technical information
relevant to pulp and paper processes, and includes information on the economic
and environmental benefits of various pollution minimization efforts. See
http://www.tappi.org for information on obtaining a copy of this handbook.
Sector Facility Indexing Project (SFIP). The SFIP is a pilot data integration
effort initiated by EPA's Office of Enforcement and Compliance Assurance that
synthesizes environmental records from several compliance-related data sources
into a system that allows facility-level and sector analysis. The SFIP is currently
a pilot project covering five industry sectors, including the pulp mill sector. The
SFIP provides the public with better access to compliance-related information
and allows for sector-based analyses. See http://es.epa.gov/oeca for further
details.
PCS. The Permit Compliance System (PCS) is a national information system
that automates entry, updating and retrieval of NPDES data and tracks permit
issuance, permit limits, and monitoring data for NPDES facilities. Public access
is available by obtaining a mainframe account on EPA's National Computer
Center. See http://es.epa.gov/oeca/datasys for further details.
12-5
-------
IDEA. The Integrated Data for Enforcement Analysis System (IDEA) is an
interactive data retrieval and integration system developed by EPA's Office of
Enforcement and Compliance Assurance. Users can retrieve data for performing
multimedia analyses of regulated facilities, produce compliance histories of
individual facilities, identify a group of facilities that meet user-defined criteria,
and produce aggregated data on selected industries. Public access is available by
obtaining a mainframe account on EPA's National Computer Center. See
http://es.epa.gov/oeca/idea for further details.
ERNS. Through The Emergency Response Notification System, EPA maintains
a database of reported spills of oil and other materials. See
http://www.epa.gov/docs/ernsacct for further details.
TRI Data. The Toxics Release Inventory (TRI) provides the public with
information on toxic chemicals being used, manufactured, transported, or
released into the environment. See http://www.epa.gov/opptintr/tri for access
to numerous TRI topics, including; "What is TRI", "Accessing and Using TRI
Data", "Tn Forms and Reporting Requirements", "TRI chemicals", "TRI
Program Development", "TRI National and International Programs", "TRI
Contacts", and "What's New with TRI". See
http://www.epa.gov/opptintr/tri/ttpubacc.htm to learn more about TRI
information found on CD-ROM, the Right-to-Know Network (RTK NET),
Envirofacts, TOXNET (user fee), and TRI User Support (TRI-US).
EPA on the World Wide Web. EPA's webserver is the primary public access
mechanism on the Internet for EPA. The webserver provides a range of EPA-
generated information in electronic format, and also offers access to OLS, the
national online catalog of the EPA library network. It includes the catalogs of
the Headquarters Information Resource Center and all the Regional libraries.
Via Internet:
EPA's homepage on the World Wide Web: http://www.epa.gov
EPA's pulp and paper rulemaking actions homepage on the World Wide Web:
http://www.epa.gov/ost/pulppaper (water documents)
http://www.epa.gov/tth/oarpq (air documents)
TAPPI Internet Website. The Technical Association of the Pulp and Paper
Industry (TAPPI) maintains a website on the Internet (http://www.tappi.org)
that provides references to available pollution prevention materials as well as
links to other related websites, such as the sites maintained by the National
Council of the Paper Industry for Air and Stream Improvement (NCASI)
(http://www.ncasi.org) and the American Forest and Paper Association
(AF&PA) (http://www.afandpa.org)
a-
.
12-6
-------
The EPA Headquarters Information Resource Center provides information support services to
EPA staff and maintains a varied collection of environmental resources, including CD-ROMs, an
online catalog, and other program-specific services. The library provides services to the general
public and develops several publications, including newsletters and brochures. Library hours are
8:00 a.m. to 5:00 p.m. ET, Monday through Friday. EPA's Online Library Service (OLS) is
available through Telnet: "epaibm.rtpnc.epa.gov."
Located in the U.S. Department of Commerce, the National Technical Information Service (NTIS)
is the central source for the public sale of U.S. Government-sponsored research, development, and
engineering reports. It is also a central source of federally generated machine processible data
files. It contains reports on air pollution, acid rain, water pollution, marine pollution, marine
ecosystems, land use planning, fisheries management, solar energy, offshore oil drilling, solid
wastes, traffic noise, and radiation monitoring.
For more information, contact:
Chief, Order Processing Branch
National Technical Information Service
5285 Port Royal Road
Springfield, Virginia 22161
Tel: (703) 487-4650
Fax:(703)321-8547
: " ...
Contacts for permitting assistance for mills covered by the pulp and paper regulation at the
regional level are:
Karrie-Jo Robinson-Shell
U.S. EPA Region 4
Atlanta Federal Center
61 Forsyth Street, S.W.
Atlanta, GA 30303
(404) 562-9308 (tel)
(404) 562-8692 (fax)
shell .karrie-j o@epa. gov
Danforth Bodien
U.S. EPA Region 10
1200 6th Avenue
Seattle, WA 98101
(206) 553-1491 (tel)
(206) 553-0119 (fax)
bodien.danforth@epa.gov
12-7
-------
Appendix A
Subpart B and E
Facilities
Table A-l identifies the 86 facilities regulated by the April 15, 1998 publication of the revised regulations
for Subpart B - Bleached Papergrade Kraft and Soda Subcategory. Because many pulp and paper facilities
operate several mills, the table displays the other subparts applicable to the facility.
Table A-1: Bleached Papergrade Kraft Mills
Facility Name
Boise Cascade Corp
Champion International
International Paper Co
Kimberly-Clark Tissue Co.
International Paper Co
Container Corp. Of America
Alabama River Pulp Co. Inc
Alabama Pine Pulp
Alliance Forest Products
Gulf States Paper Corp
Fort James Corp.
Georgia-Pacific Corp
Georgia-Pacific Corp
International Paper Co
Potlatch Corp
Louisiana-Pacific Corp
Plainwell Shasta Paper Co.
Georgia-Pacific Corp
Stone Container Corp
Champion International
City
Jackson
Courtland
Mobile
Mobile
Selma
Brewton
Perdue Hill
Perdue Hill
Coosa Pines
Demopolis
Pennington
Ashdown
Crossett
Pine Bluff
McGehee
Samoa
Anderson
Palatka
Panama City
Cantonment
ST
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AL
AR
AR
AR
AR
CA
CA
FL
FL
FL
B
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
c
X
X
X
X
E
F
G
X
X
I
X
J
X
K
X
X
X
X
X
L
X
X
X
A-1
-------
Facility Name
Florida Coast Paper Co. L.L.C.
Federal Paper Board Co. - Int'l
Paper
Stone Container Corp-Savannah
River Div
Georgia-Pacific Corp.
Weyerhaeuser Co.
Oilman Paper Co
Potlatch Corp
Westvaco Corp
Willamette Industries Inc.
Georgia-Pacific Corp-Port
Hudson Oper.
Crown Vantage Inc.
Boise Cascade Corp
International Paper Co
Westvaco Corp
SD Warren Co. - Hmckley
S D Warren Co
International Paper Co
Mead Corp.
Fort James Corp.
Eastern Paper Co. Inc.
Georgia-Pacific Corp
Champion International
Mead Corp.
S D Warren Co
Boise Cascade Corp
Potlatch Corp
Georgia-Pacific Corp.
International Paper Co
Weyerhaeuser Co.
Stone Container Corp
Carolina Paper
Weyerhaeuser Co.
Weyerhaeuser Co.
Federal Paper Board Co. - Int'l
Paper
City
Port St. Joe
Augusta
Port Wentworth
Brunswick
Oglethorpe
St. Marys
Lewiston
Wickhffe
Hawesville
Zachary
St. Francisville
DeRidder
Bastrop
Luke
Skowhegan
Westbrook
Jay
Rumford
Old Town
Lincoln
Woodland
Quinnesec
Escanaba
Muskegon
International
Falls
Cloquet
New Augusta
Moss Point
Columbus
Missoula
Canton
New Bern
Plymouth
Riegelwood
ST
FL
GA
GA
GA
GA
GA
ID
KY
KY
LA
LA
LA
LA
MD
ME
ME
ME
ME
ME
ME
ME
MI
MI
MI
MN
MN
MS
MS
MS
MT
NC
NC
NC
NC
B
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
c
X
X
X
X
X
X
X
X
E
F
G
X
X
X
X
X
X
I
J
X
X
X
X
X
X
X
X
X
K
X
X
X
X
X
X
X
X
X
X
X
X
L
X
X
X
X
X
X
X
X
X
A-2
-------
Facility Name
Crown Vantage Inc.
International Paper Co
Mead Corp.
Boise Cascade Corp
Fort James Corp.
Pope & Talbot Inc.
Willamette Industries Inc.
P. H. Glatfelter Co
International Paper Co.
Appleton Papers Inc.
International Paper Co.
Willamette Industries Inc.
Bowater Incorp
International Paper Co
Bowater Newsprint
Willamette Industries Inc.
International Paper Co
Donohue Inc.
Donohue Inc.
Pasadena Paper Company
Temple-Inland Inc. - Evadale
Westvaco Corp
St. Laurent Paper Products Corp.
International Paper Co.
Simpson Tacoma Kraft Co
Boise Cascade Corp
Port Townsend Paper Corp
Fort James Corp.
Longview Fibre Co
Weyerhaeuser Co.
Consolidated Papers Inc.
Georgia-Pacific Corp. at
Nekoosa Mill
City
Berlin
Ticonderoga
Chillicothe
St Helens
Clatskanie
Halsey
Johnsonburg
Spring Grove
Erie
Roaring Spring
Eastover
Bennettsville
Catawba
Georgetown
Calhoun
Kingsport
Texarkana
Sheldon
Lufkin
Pasadena
Silsbee
Covington
West Point
Franklin
Tacoma
Wallula
Port Townsend
Camas
Longview
Longview
Wisconsin
Rapids
Port Edwards
ST
NH
NY
OH
OR
OR
OR
PA
PA
PA
PA
SC
SC
SC
SC
TN
TN
TX
TX
TX
TX
TX
VA
VA
VA
WA
WA
WA
WA
WA
WA
WI
WI
B
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
c
X
X
X
X
X
X
X
X
X
E
X
F
X
X
G
X
X
X
X
X
X
I
X
J
X
X
X
X
X
X
X
K
X
X
X
X
X
X
X
X
X
X
L
X
X
X
X
X
A-3
-------
Table A-2 identifies the 10 facilities affected by the April 15, 1998 publication of the revised regulations
for Subpart E - Papergrade Sulfite Subcategory. Because many pulp and paper facilities operate several
mills, the table displays the other subparts applicable to the facility.
Table A-2: Papergrade Sulfite Mills
Facility Name
Great Northern Paper Co.
Finch Pruyn & Co Inc.
Procter & Gamble Paper Products Co.
Kimberly-Clark Corp.
Georgia-Pacific Corp.
Fort James Corp.
Weyerhaeuser Co.
Wausau Paper Mills Co.
Fraser Papers Inc.
Georgia-Pacific Corp.
City
Millinocket
Glens Falls
Mehoopany
Everett
Bellingham
Camas
Rothschild
Brokaw
Park Falls
Port Edwards
ST
ME
NY
PA
WA
WA
WA
WI
WI
WI
WI
B
X
c
X
E
X
X
X
X
X
X
X
X
X
X
G
X
X
X
J
X
X
X
K
X
X
X
X
X
X
L
X
X
A-4
-------
Appendix B
Sample Collection
Methods
B. 1 BLEACH PLANT WASTEWATER
Samples of bleach plant wastewater must be analyzed for chloroform, TCDD, TCDF, and
chlorinated phenolic compounds (and AOX at indirect dischargers). Six pairs of 40 milliliter vials will be
filled during each 24-hour compositing period. Samples to be analyzed for TCDD, TCDF, and chlorinated
phenolic compounds (CPs) may be collected as 24-hour manual composites, by collecting 1.5 liters of
sample every 4 hours for 24 hours. Alternatively, samples to be analyzed for TCDD, TCDF, and CPS may
be collected as continuous automatic composites.
Prior to sample collection, the following equipment should be set up at the sampling
point:
A sample cooling system, consisting of Teflon® tubing attached to a valve at
one end and coiled and placed in a tub of ice and water at the other;
A sump or other container (e.g., a bucket under the tap/valve from which the
sample is collected) in which to dispose of sample that is purged from the
tap/valve prior to sample collection;
A padlocked cooler that is double-lined with large plastic bags and contains a
specially-cleaned 10-liter glass storage jar in which the sample will be
composited, a specially-cleaned 1 -liter glass j ar with which sample aliquots will
be collected (the jar should be marked to show the half-full level), a specially-
cleaned 500-milliliter glass jar with which field measurements will be obtained, a
foam block for holding 40 milliliter glass vials, and fifteen 40-milliliter glass
vials;
Large plastic bags, twist-ties, plastic zip-lock freezer bags, and labels for each
pair of glass vials;
A pH meter or four-color pH paper, a temperature probe or thermometer, and a
wash bottle filled with deionized water;
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A test kit for free chlorine (consists of a disposable pipette or eyedropper, a 40-
milliliter clear glass vial, latex gloves, 1.0 N sodium thiosulfate solution,
potassium iodide crystals, starch solution, and concentrated acetic acid);
A sampling log containing field data sheets (see Figure 3-1 of this document);
A box in which to store sampling equipment between the collection of sample
aliquots during the 24-hour compositing period; and
Ice.
Samples must be collected as follows:
1. The sample to be analyzed for chloroform will be collected first.
2. Two 40-milliliter glass vials are required. Use bottles that are certified clean by
the manufacturer. If chemical preservation is required at this sampling point,
make sure that the vials have been pre-preserved in the staging area (see Section
3.5 of this document). Do not touch the inside of the bottle or the lined bottle
cap.
3. Turn on the tap/valve and allow the sample to flow through the cooling system
into a sump (or bucket) for 2 to 3 minutes, to purge the line.
4. Insert the Teflon® tubing into the bottom of a vial and fill it with sample while
slowly withdrawing the tubing from the vial. Fill the vial to overflowing.
5. Seal the vial by placing the septum (Teflon® side down) on the convex sample
meniscus and screwing down the cap. To ensure that the sample has been
properly sealed, invert the sample: the absence of air bubbles indicates a proper
seal.
6. If air bubbles are present, discard the vial and fill a new one. Seal the vial and
test that it is hermetically sealed, as described above. (Note: if the vial was pre-
preserved with chemicals, use another pre-preserved vial to collect the sample a
second time).
7. Collect sample in the second vial in the same manner as used for the first vial.
Close the tap/valve.
8. Place both vials in one plastic zip-lock freezer bag, along with a label identifying
the pair of aliquots. Place the plastic zip-lock freezer bag in the double-lined
cooler.
9. Record the date and time of sample collection on the field data sheet.
10. The remaining sample fractions must NOT be collected through the Teflon®
tubing. If a three way valve has not been installed in the sample line, remove the
tubing from the tap/valve and place a small plastic bag around the tip of the
tubing. Then place the tubing in a large plastic bag. Close the bag with a twist-
tie and place it in a box near the cooler.
11. A specially-cleaned 1 -liter glass j ar is required to collect the sample aliquots for
the composite sample. A 500-milliliter specially-cleaned glass jar is required to
collect sample to measure the pH and temperature of the sample. Use jars that
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are certified clean by the manufacturer. Do not touch the inside of the jar or the
lined jar cap.
12. Test the acid stage filtrate for free chlorine as follows:
Fill the 40-milliliter clear vial to the bottom of the neck with sample;
If the sample is not acidic (pH 3 to 4), add a few drops of acetic acid,
cover the vial with a gloved hand, and mix by inverting the vial a few
times;
Add a few potassium iodide crystals and repeat the mixing step;
If the sample turns black or blue/black, residual chlorine is present and the
following steps are required:
Add one- or two-drop increments of sodium thiosulfate to the vial with
mixing between additions;
Record the number of drops of sodium thiosulfate required to clear the
sample of the blue color on the field measurements data sheet. Two
milliliters of sodium thiosulfate will be added to the composite for
every drop required to clear the sample.
13. Fill the 500-milliliter glass j ar approximately 3/4 full and use the pH meter or pH
paper to measure the pH. Use a temperature probe or thermometer to measure
the temperature of the sample. Record this information on the field data sheet
and discard the sample into a sump. The sampler should also measure and
record the pH and temperature of the final composite sample.
14. Fill the 1-liter amber glass jar with sample and add 1.0 N sodium thiosulfate
solution to the glass storage jar; 2 milliliters of sodium thiosulfate should be used
for every drop required for the titration described in step (12). Pour this sample
into the 10-liter glass storage jar. Do not touch the inside of the glass storage
j ar. Next, fill the 1 -liter glass j ar halfway full of sample (to the mark) and turn
off the tap/valve. Record the volume of sodium thiosulfate added to the
composite on the field measurements data sheet. Seal the glass storage jar by
screwing on the lid.
15. Put the lids on the 1 -liter amber glass j ar and the 500-milliliter glass j ar and
place them in plastic zip-lock freezer bags. Seal the bags and place them back in
the cooler.
16. Place ice in the cooler, outside the double lining of plastic bags. Arrange the
bags of ice around the 10-liter glass storage jar. More ice should be used when
temperatures are very high. Check the ice in the cooler periodically and replace
it as necessary.
17. Close and lock the cooler.
18. Rinse the pH probe in deionized water before its next use. Discard rinsate into a
sump.
19. Repeat the above 18 steps for each sample aliquot. Aliquots will be collected
every 4 hours during the 24-hour compositing period, for a total of six sample
aliquots. At the end of the 24-hour compositing period, the cooler should
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contain approximately 9 liters of sample in the 10-liter glass storage jar and
twelve 40-milliliter vials of samples in the VOA block.
Take the cooler containing the samples to the staging area. Mix the contents of
the 10-liter glass storage j ar using a glass stirring rod. Alternatively, carefully
screw on the lid of the glass storage jar and invert it several times to thoroughly
mix the contents. After the sample is thoroughly mixed, pour it from the storage
jar into five 1-liter amber glass bottles using the following procedure:
Swirl and shake the storage jar to re-suspend settled solids;
Fill each sample jar to about % of its empty volume;
Mix the remaining volume in the storage j ar;
In reverse order, add another % volume aliquot to each sample jar; and
Repeat until the sample j ars have been filled.
Follow the preservation procedures discussed in B.3 of this appendix if samples
are to be shipped to an off-site laboratory.
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B.2 WASTEWATERS FROM THE TREATMENT SYSTEM
To demonstrate compliance with new limitations for toxic and nonconventional
pollutants, samples of wastewaters from the treatment system must be analyzed for AOX. Samples to be
analyzed for AOX may be collected as 24-hour manual composites, by collecting 1.5 liters of sample every
4 hours for 24 hours. Alternatively, they may be collected as continuous automatic composites.
Prior to the sample collection of manual composites, the following equipment should be
set up at the sampling point:
A sump or other container (e.g., a bucket under the tap/valve from which the
sample is collected) to dispose of sample that is purged from the tap/valve prior
to sample collection;
A padlocked cooler that is double-lined with large plastic bags and contains a
specially-cleaned 10-liter glass storage jar in which the sample will be
composited, a specially-cleaned 1 -liter glass j ar with which sample aliquots will
be collected (the jar should be marked to show the half-full level), a specially-
cleaned 500-milliliter glass jar with which field measurements will be obtained, a
VOA block, and fifteen 40-milliliter pre-preserved glass vials;
Plastic zip-lock freezer bags and labels for each pair of glass vials;
A pH meter or four-color pH paper, a temperature probe or thermometer, and a
wash bottle filled with deionized water;
A sampling log containing field data sheets (see Figure 3-1 of this document);
A box in which to store sampling equipment between the collection of sample
aliquots during the 24-hour compositing period; and
Ice.
Manual composite samples should be collected as follows:
1. A 1 -liter specially-cleaned glass jar is required to collect the sample aliquots for
the composite sample. A 500-milliliter specially-cleaned glass jar is required to
collect a sample to measure the pH and temperature of the sample. Use bottles
that are certified clean by the manufacturer. Do not touch the inside of the bottle
or the lined bottle cap.
2. Fill the 500-milliliter glass jar approximately 3A full and use the pH meter or pH
paper to measure the pH. Use a temperature probe or thermometer to measure
the temperature of the sample. Record this information on the field data sheet
and discard the sample into a sump. The sampler should also measure and
record the pH and temperature of the final composite sample.
3. Fill the 1-liter glass jar with sample and pour this sample into the 10-liter glass
storage jar. Do not touch the inside of the glass storage jar. Repeat, only filling
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the 1-liter glass jar halfway full (to the mark) this second time and turn off the
tap/valve. Seal the glass storage jar by screwing on the lid.
4. Put the lids on the 1-liter amber glass jar and the 500-milliliter glass jar and
place them in plastic zip-lock freezer bags. Seal the bags and place them back in
the cooler.
5. Place ice in the cooler, outside the double lining of plastic bags. Arrange the
bags of ice around the 10-liter glass storage jar. More ice should be used when
temperatures are very high. Check the ice in the cooler periodically and replace
it as necessary.
6. Close and lock the cooler.
7. Rinse the pH probe in deionized water before its next use. Discard the rinsate
into a sump.
8. Repeat the above 7 steps for each sample aliquot. Aliquots will be collected
every 4 hours during the 24-hour compositing period, for a total of six sample
aliquots. At the end of the 24-hour compositing period, the cooler should
contain approximately 9 liters of sample in the 10-liter glass storage j ar.
9. Take the cooler containing the samples to the staging area. Mix the contents of
the 10-liter glass storage j ar using a glass stirring rod. Alternatively, carefully
screw on the lid of the glass storage jar and invert it several times to thoroughly
mix the contents. After the sample is thoroughly mixed, pour it from the storage
jar into seven 1-liter amber glass bottles and one 500-milliliter amber glass bottle
using the following procedure:
Swirl and shake the storage jar to re-suspend settled solids;
Fill each sample jar to about % of its empty volume;
Mix the remaining volume in the storage j ar;
In reverse order, add another % volume aliquot to each sample jar; and
Repeat until the sample j ars have been filled.
10. Follow the preservation procedures discussed in B.3 of this appendix if samples
are to be shipped to an off-site laboratory.
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B.3 SAMPLE PRESERVATION
After collection, all samples require some preservation to prevent the degradation of the
target analytes. The sample analyses and required preservation for a water sample set are discussed below.
All samples will be stored and shipped in coolers packed with ice to maintain the sample
at 4°C. Additional chemical preservation requirements are discussed below for each analytical parameter.
Reagent grade chemicals will be used for preservation. Due to the corrosivity of these chemicals, personnel
should always wear gloves when chemically preserving these samples. The amount of preservative added
to each sample should be documented on a Preservation Log Sheet.
Chloroform
Samples of acid stage filtrate may require dechlorination using sodium thiosulfate. The
acid stage filtrate is assumed to contain free chlorine, at least intermittently. These samples will be
dechlorinated by adding a few sodium thiosulfate crystals (10 mg) to each 40-milliliter vial prior to sample
collection. Document the amount of preservative added in a preservation log book.
By pre-preserving the vial, rather than adding preservatives after the sample has been
collected, a hermetic seal can be maintained on each vial after sample collection. Some samples to be
analyzed for volatile organics will have to be poured out and collected in a new vial because they were not
hermetically sealed. For this reason, plan to have extra pre-preserved vials at each sampling point, rather
than taking preservatives to each sampling point.
Chlorinated Dioxins and Furans
Samples of acid stage filtrate may require dechlorination using sodium thiosulfate. Mill
personnel will monitor the free chlorine content of the acid stage filtrate prior to the collection of each
sample aliquot. If the aliquot contains free chlorine, 1.0 N sodium thiosulfate solution will be added to 1
liter of the sample aliquot before pouring the aliquot into the glass storage j ar. The determination for free
chlorine and the volume of sodium thiosulfate to use is discussed in item 12, on page B-3 of this appendix.
Chlorinated Phenolic Compounds
Samples to be analyzed for chlorinated phenolic compounds will be preserved with
sulfuric acid. Samples of acid stage filtrate may also require dechlorination using sodium thiosulfate. Mill
personnel will monitor the free chlorine content of the acid stage filtrate prior to the collection of each
sample aliquot. If the aliquot contains free chlorine, 1.0 N sodium thiosulfate solution will be added to 1
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liter of the sample aliquot before pouring the aliquot into the glass storage jar. The volume of thiosulfate
used will be determined by an on-site test, as described in Appendix B of this document.
After sample collection for the 24-hour compositing period is complete, the sampler will
take the glass storage j ar to the staging area, mix the contents of the j ar, and pour the sample from the
storage jar into the appropriate sample containers.
To preserve a sample to be analyzed for chlorinated phenolic compounds, use a Pasteur
pipette to add a few drops of sulfuric acid to each 1-liter amber glass bottle. Document the amount of
preservative added in the preservation log book. Mix the acid with the sample by drawing the sample into a
second pipette and expelling this volume back into the sample jar, repeating this several times.
Alternatively, the acid may be mixed with the sample by stirring with the pipette or capping the sample jar
and inverting it.
After the acid is mixed with the sample, test the pH of the mixture by drawing a small
volume into the pipette and placing a drop of sample on the 4-color pH test paper. Record the pH. If the
pH is not between 2 to 3, add a larger dose of acid, document the amount of preservative added, mix the
acid with the sample, and test and record the pH again. Repeat this procedure until either the pH is adjusted
to between 2 to 3 or the volume of preservative added to the sample jar equals 5% of the sample volume (50
milliliters for a 1-liter jar).
Alternatively, samples may be preserved with sulfuric acid by adding a fixed volume of
acid to the appropriate sample containers. The volume of acid to be added would be predetermined weekly,
based on a titration of the composite sample with sulfuric acid. After adding the fixed volume of sulfuric
acid to the sample containers, the sampler should verify that the pH of the acidified sample is between 2 to
3 and add additional sulfuric acid if needed. As discussed above, the sample should be acidified until either
the pH is adjusted to between 2 to 3, or the volume of preservative added to the sample j ar equals 5% of the
sample volume.
AOX
Samples to be analyzed for AOX will be preserved with nitric acid. Samples of the acid
stage filtrate may also require dechlorination using sodium thiosulfate. Mill personnel will monitor the free
chlorine content of the acid stage filtrate prior to the collection of each sample aliquot. If the aliquot
contains free chlorine, 1.0 N sodium thiosulfate solution will be added to 1 liter of the sample aliquot before
pouring the aliquot into the glass storage jar. The volume of sodium thiosulfate used will be determined by
an on-site test, as described in Appendix B of this document.
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After sample collection for the 24-hour compositing period is complete, the sampler will
take the glass storage j ar to the staging area, mix the contents of the j ar, and pour the sample from the
storage jar into the appropriate sample containers.
To preserve a sample to be analyzed for AOX, use a Pasteur pipette to add a few drops of
nitric acid to each 500-milliliter amber glass bottle. Document the amount of preservative added in the
preservation log book. Mix the acid with the sample by drawing the sample into a second pipette and
expelling this volume back into the sample jar, repeating this several times. Alternatively, the acid may be
mixed with the sample by stirring with the pipette or capping the sample jar and inverting it.
After the acid is mixed with the sample, test the pH of the mixture by drawing a small
volume into the pipette and placing a drop of sample on the 4-color pH test paper. Record the pH. If the
pH is not between 2 to 3, add a larger dose of acid, document the amount of preservative added, mix the
acid with the sample, and test and record the pH again. Repeat this procedure until either the pH is adjusted
to between 2 to 3 or the volume of preservative added to the sample jar equals 5% of the sample volume (25
milliliters for a 500-milliliter jar).
Alternatively, samples may be preserved with nitric acid by adding a fixed volume of acid
to the appropriate sample containers. The volume of acid to be added would be predetermined weekly,
based on a titration of the composite sample with nitric acid. After adding the fixed volume of nitric acid to
the sample containers, the sampler should verify that the pH of the acidified sample is between 2 to 3 and
add additional nitric acid if needed. As discussed above, the sample should be acidified until either the pH
is adjusted to between 2 to 3, or the volume of preservative added to the sample jar equals 5% of the sample
volume.
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Appendix C
BMP NPDES Permit
Language
Appendix C presents example permit language to assist permitting authorities establish appropriate BMP
requirements in NPDES permits.
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PageIV-1
Permit No.
PART IV
BEST MANAGEMENT PRACTICES PLAN
A. SPECIALIZED DEFINITIONS
(1) Action Level: A daily pollutant loading that when exceeded triggers investigative or corrective action.
Mills determine action levels by a statistical analysis of six months of daily measurements collected at the
mill. For example, the lower action level may be the 75th percentile of the running seven-day averages (that
value exceeded by 25 percent of the running seven-day averages) and the upper action level may be the 90th
percentile of the running seven-day averages (that value exceeded by 10 percent of the running seven-day
averages).
(2) Equipment Items in Spent Pulping Liquor, Soap, and Turpentine Service: Any process vessel,
storage tank, pumping system, evaporator, heat exchanger, recovery furnace or boiler, pipeline, valve,
fitting, or other device that contains, processes, transports, or comes into contact with pulping liquor, soap,
or turpentine. Sometimes referred to as "equipment items."
(3) Immediate Process Area: The location at the mill where pulping, screening, knotting, pulp washing,
pulping liquor concentration, pulping liquor processing, and chemical recovery facilities are located,
generally the battery limits of the aforementioned processes. "Immediate process area" includes spent
pulping liquor storage and spill control tanks located at the mill, whether or not they are located in the
immediate process area.
(4) Intentional Diversion: The planned removal of spent pulping liquor, soap, or turpentine from
equipment items in spent pulping liquor, soap, or turpentine service by the mill for any purpose including,
but not limited to, maintenance, grade changes, or process shutdowns.
(5) Mill: The owner or operator of a direct or indirect discharging pulp, paper, or paperboard manufacturing
facility subject to this section.
(6) Senior Technical Manager: The person designated by the mill manager to review the BMP Plan. The
senior technical manager shall be the chief engineer at the mill, the manager of pulping and chemical
recovery operations, or other such responsible person designated by the mill manager who has knowledge
of and responsibility for pulping and chemical recovery operations.
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Permit No.
(7) Soap: The product of reaction between the alkali in kraft pulping liquor and fatty acid portions of the
wood, which precipitate out when water is evaporated from the spent pulping liquor.
(8) Spent Pulping Liquor: For kraft and soda mills "spent pulping liquor" means black liquor that is used,
generated, stored, or processed at any point in the pulping and chemical recovery processes. For sulfite
mills " spent pulping liquor" means any intermediate, final, or used chemical solution that is used, generated,
stored, or processed at any point in the sulfite pulping and chemical recovery processes (e.g., ammonium-,
calcium-, magnesium-, or sodium-based sulfite liquors). [Note: permitting authorities may consider
green liquor, white liquor or fresh sulfite pulping liquor as a spent pulping liquor and require mills to
include management of these materials in the BMPs.]
(9) Turpentine: A mixture of terpenes, principally pinene, obtained by the steam distillation of pine gum
recovered from the condensation of digester relief gases from the cooking of softwoods by the kraft pulping
process. Sometimes referred to as sulfate turpentine.
B. REQUIREMENT TO IMPLEMENT BEST MANAGEMENT PRACTICES
The permittee must implement the Best Management Practices (BMPs) specified in paragraphs B.(l)
through B.(10) (below). BMPs must be developed according to best engineering practices and must be
implemented in a manner that takes into account the specific circumstances at each mill. The BMPs are as
follows:
(1) The permittee return spilled or diverted spent pulping liquors, soap, and turpentine to the process to the
maximum extent practicable as determined by the mill, recover such materials outside the process, or
discharge spilled or diverted material at a rate that does not disrupt the receiving wastewater treatment
system.
(2) The permittee must establish a program to identify and repair leaking equipment items. This program
must include:
(I) Regular visual inspections (e.g., once per day) of process areas with equipment items
in spent pulping liquor, soap, and turpentine service;
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Permit No.
(ii) Immediate repairs of leaking equipment items, when possible. Leaking equipment
items that cannot be repaired during normal operations must be identified, temporary
means for mitigating the leaks must be provided, and the leaking equipment items
repaired during the next maintenance outage;
(iii) Identification of conditions under which production will be curtailed or halted to
repair leaking equipment items or to prevent pulping liquor, soap, and turpentine leaks
and spills; and
(iv) A means for tracking repairs over time to identify those equipment items where
upgrade or replacement may be warranted based on frequency and severity of leaks,
spills, or failures.
(3) The permittee must operate continuous, automatic monitoring systems that the mill determines are
necessary to detect and control leaks, spills, and intentional diversions of spent pulping liquor, soap, and
turpentine. These monitoring systems should be integrated with the mill process control system and may
include, e.g., high level monitors and alarms on storage tanks; process area conductivity (or pH) monitors
and alarms; and process area sewer, process wastewater, and wastewater treatment plant conductivity (or
pH) monitors and alarms.
(4) The permittee must establish a program of initial and refresher training of operators, maintenance
personnel, and other technical and supervisory personnel who have responsibility for operating,
maintaining, or supervising the operation and maintenance of equipment items in spent pulping liquor, soap,
and turpentine service. The refresher training must be conducted at least annually and the training program
must be documented.
(5) The permittee must prepare a brief report that evaluates each spill of spent pulping liquor, soap, or
turpentine that is not contained at the immediate process area and any intentional diversion of spent pulping
liquor, soap, or turpentine that is not contained at the immediate process area. The report must describe the
equipment items involved, the circumstances leading to the incident, the
effectiveness of the corrective actions taken to contain and recover the spill or intentional diversion, and
plans to develop changes to equipment and operating and maintenance practices as necessary to prevent
recurrence. Discussion of the reports must be included as part of the annual refresher training.
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Permit No.
(6) The permittee must establish a program to review any planned modifications to the pulping and
chemical recovery facilities and any construction activities in the pulping and chemical recovery areas
before these activities commence. The purpose of such review is to prevent leaks and spills of spent pulping
liquor, soap, and turpentine during the planned modifications, and to ensure that construction and
supervisory personnel are aware of possible liquor diversions and of the requirement to prevent leaks and
spills of spent pulping liquors, soap, and turpentine during construction.
(7) The permittee must install and maintain secondary containment (i.e., containment constructed of
materials impervious to pulping liquors) for spent pulping liquor bulk storage tanks equivalent to the
volume of the largest tank plus sufficient freeboard for precipitation. An annual tank integrity testing
program, if coupled with other containment or diversion structures, may be substituted for secondary
containment for spent pulping liquor bulk storage tanks.
(8) The permittee must install and maintain secondary containment for turpentine bulk storage tanks.
(9) The permittee must install and maintain curbing, diking or other means of isolating soap and turpentine
processing and loading areas from the wastewater treatment facilities.
(10) The mill must conduct wastewater monitoring to detect leaks and spills, to track the effectiveness of
the BMPs, and to detect trends in spent pulping liquor losses. Such monitoring must be performed in
accordance with paragraph H.
C. REQUIREMENT TO DEVELOP A BMP PLAN
(1) The permittee must prepare and implement a BMP Plan. The BMP Plan must be based on a detailed
engineering review as described in paragraphs C.(2) and C.(3) (below). The BMP Plan must specify the
procedures and the practices required for each mill to meet the requirements of paragraph B., the
construction the mill determines is necessary to meet those requirements including a schedule for such
construction, and the monitoring program (including the statistically derived action levels) that will be used
to meet the requirements of paragraph H. The BMP Plan also must specify the period of time that the mill
determines the action levels established under paragraph G may be exceeded without triggering the
responses specified in paragraph H.
(2) The permittee must conduct a detailed engineering review of the pulping and chemical recovery
operations — including but not limited to process equipment, storage tanks, pipelines and pumping systems,
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Page IV-5
Permit No.
loading and unloading facilities, and other appurtenant pulping and chemical recovery equipment items in
spent pulping liquor, soap, and turpentine service — for the purpose of determining the magnitude and
routing of potential leaks, spills, and intentional diversions of spent pulping liquors, soap, and turpentine
during the following periods of operation:
(I) Process start-ups and shut downs;
(ii) Maintenance;
(iii) Production grade changes;
(iv) Storm or other weather events;
(v) Power failures; and
(vi) Normal operations.
(3) As part of the engineering review, the permittee must determine whether existing spent pulping liquor
containment facilities are of adequate capacity for collection and storage of anticipated intentional liquor
diversions with sufficient contingency for collection and containment of spills. The engineering review must
also consider:
(I) The need for continuous, automatic monitoring systems to detect and control leaks and
spills of spent pulping liquor, soap, and turpentine;
(ii) The need for process wastewater diversion facilities to protect end-of-pipe wastewater
treatment facilities from adverse effects of spills and diversions of spent pulping liquors,
soap, and turpentine;
(iii) The potential for contamination of storm water from the immediate process areas;
and
(iv) The extent to which segregation and/or collection and treatment of contaminated
storm water from the immediate process areas is appropriate.
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Permit No.
D. AMENDMENT OF BMP PLAN
(1) The permittee must amend its BMP Plan whenever there is a change in mill design, construction,
operation, or maintenance that materially affects the potential for leaks or spills of spent pulping liquor,
turpentine, or soap from the immediate process areas.
(2) The permittee must complete a review and evaluation of the BMP Plan five years after the first BMP
Plan is prepared and, except as provided in paragraph D.(l) (above), once every five years thereafter. As a
result of this review and evaluation, the permittee must amend the BMP Plan within three months of the
review if the mill determines that any new or modified management practices and engineered controls are
necessary to reduce significantly the likelihood of spent pulping liquor, soap, and turpentine leaks, spills, or
intentional diversions from the immediate process areas, including a schedule for implementation of such
practices and controls.
E. REVIEW AND CERTIFICATION OF BMP PLAN
The BMP Plan, and any amendments, must be reviewed by the senior technical manager at the mill and
approved and signed by the mill manager. Any person signing the BMP Plan or its amendments must certify
to [Name of the Permitting Authority] under penalty of law that the BMP Plan (or its amendments) has
been prepared in accordance with good engineering practices and in accordance with this regulation. The
mill is not required to obtain approval from the [Name of the Permitting Authority] of the BMP Plan or
any amendments. [Note: Permitting authorities have discretion to review/approve BMP Plan if they
choose.]
F. RECORD KEEPING REQUIREMENTS
(1) The permittee must maintain on its premises a complete copy of the current BMP Plan and the records
specified in paragraph F.(2) (below) and must make such BMP Plan and records available to [Name of the
Permitting Authority] or his or her designee for review upon request.
(2) The mill must maintain the following records for three years from the date they are created:
(I) Records tracking the repairs performed in accordance with the repair program
described in paragraph B.(2);
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Page IV-7
Permit No.
(ii) Records of initial and refresher training conducted in accordance with paragraph
B.(4);
(iii) Reports prepared in accordance with paragraph B.(5) of this section; and
(iv) Records of monitoring required by paragraphs B.(10) and H.
G. ESTABLISHMENT OF WASTEWATER TREATMENT SYSTEM INFLUENT
ACTION LEVELS
(1) The permittee must conduct a monitoring program, described in paragraph G.(2), for the purpose of
defining wastewater treatment system influent characteristics (or action levels), described in paragraph
G.(3), that will trigger requirements to initiate investigations on BMP effectiveness and to take corrective
action.
(2) The permittee must employ the following procedures in order to develop the required action levels:
(I) Monitoring parameters. The permittee must collect 24-hour composite samples and
analyze the samples for a measure of organic content (e.g., Chemical Oxygen Demand
(COD) or Total Organic Carbon (TOC)). Alternatively, the permittee may use a measure
related to spent pulping liquor losses measured continuously and averaged over 24 hours
(e.g., specific conductivity or color). [Note: Permitting authorities may specify
monitoring parameter, if they choose.]
(ii) Monitoring locations. For direct dischargers, monitoring must be conducted at the
point influent enters the wastewater treatment system. For indirect dischargers monitoring
must be conducted at the point of discharge to the POTW. For the purposes of this
requirement, the permittee may select alternate monitoring point(s) in order to isolate
possible sources of spent pulping liquor, soap, or turpentine from other possible sources
of organic wastewaters that are tributary to the wastewater treatment facilities (e.g.,
bleach plants, paper machines and secondary fiber operations).
(3) By the date prescribed in paragraph I.(l)(iii) the permittee must complete an initial six-month
monitoring program using the procedures specified in paragraph G.(2) and must establish initial action
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Permit No.
levels based on the results of that program. A wastewater treatment influent action level is a statistically
determined pollutant loading determined by a statistical analysis of six months of daily measurements. The
action levels must consist of a lower action level, which if exceeded will trigger the investigation
requirements described in paragraph H, and an upper action level, which if exceeded will trigger the
corrective action requirements described in paragraph H.
(4) By the date prescribed in paragraph I.(l)(vi), the permittee must complete a second six-month
monitoring program using the procedures specified in paragraph G.(2) of this section and must establish
revised action levels based on the results of that program. The initial action levels shall remain in effect
until replaced by revised action levels.
(5) Action levels developed under this paragraph must be revised using six months of monitoring data after
any change in mill design, construction, operation, or maintenance that materially affects the potential for
leaks or spills of spent pulping liquor, soap, or turpentine from the immediate process areas.
[Note: By the date prescribed in paragraph I. (2) of this section, each new source must complete a six-
month monitoring program using the procedures specified in paragraph G. (2) and must develop a lower
action level and an upper action level based on the results of that program.]
H. MONITORING, CORRECTIVE ACTION, AND REPORTING REQUIREMENTS
(1) The permittee must conduct daily monitoring of the influent to the wastewater treatment system in
accordance with the procedures described in paragraph G.(2) for the purpose of detecting leaks and spills,
tracking the effectiveness of the BMPs, and detecting trends in spent pulping liquor losses.
(2) Whenever monitoring results exceed the lower action level for the period of time specified in the BMP
Plan, the permittee must conduct an investigation to determine the cause of such exceedance. Whenever
monitoring results exceed the upper action level for the period of time specified in the BMP Plan, the
permittee must complete corrective action to bring the wastewater treatment system influent mass loading
below the lower action level as soon as practicable.
(3) Although exceedances of the action levels will not constitute violations of [make specific for mill being
permitted], failure to take the actions required by paragraph H.(2) as soon as practicable will be a
violation.
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Permit No.
(4) The permittee must report to [Name of the Permitting Authority] the results of the daily monitoring
conducted pursuant to paragraph H.(l). Such reports must include a summary of the monitoring results, the
number and dates of exceedances of the applicable action levels, and brief descriptions of any corrective
actions taken to respond to such exceedances. Submission of such reports shall be at [specify desired
frequency but in no case less than once per year].
I. COMPLIANCE DEADLINES
(1) The permittee is subject to this section to meet the following deadlines:
(I) Prepare BMP Plans and certify to the permitting or pretreatment authority that the
BMP Plan has been prepared in accordance with this regulation not later than April 15,
1999;
(ii) Implement all BMPs specified in paragraph B that do not require the construction of
containment or diversion structures or the installation of monitoring and alarm systems
not later than April 15, 1999.
(iii) Establish initial action levels required by paragraph G.(3) not later than April 15,
1999.
(iv) Commence operation of any new or upgraded continuous, automatic monitoring
systems that the mill determines to be necessary under paragraph B.(3) (other than those
associated with construction of containment or diversion structures) not later than April
15,2000.
(v) Complete construction and commence operation of any spent pulping liquor,
collection, containment, diversion, or other facilities, including any associated continuous
monitoring systems, necessary to fully implement BMPs specified in paragraph B not
later than April 15, 2001.
(vi) Establish revised action levels required by paragraph G.(4) of this section as soon as
possible after fully implementing the BMPs specified in paragraph B, but not later than
January 15,2002.
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Permit No.
Note: new sources must meet the deadlines set forth below:
(2) New Sources. Upon commencing discharge, new sources must implement all of the BMPs specified in
paragraph B, prepare the BMP Plan required by paragraph C, and certify to the permitting or
pretreatment authority that the BMP Plan has been prepared in accordance with this regulation as
required by paragraph E., except that the action levels required by paragraph G. (5) must be established
not later than 12 months after commencement of discharge, based on six months of monitoring data
obtained prior to that date in accordance with the procedures specified in paragraph G. (2).
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Appendix D
Glossary
Adsorbable organic halides (AOX) - A bulk parameter that measures the total mass of chlorinated organic
matter in water and wastewater.
Average monthly discharge limitation - The highest allowable average of "daily discharges" over a
calendar month, calculated as the sum of all "daily discharges" measured during the calendar month divided
by the number of "daily discharges" measured during the month.
Biocide - Toxic material for microbiological control.
Black liquor - Spent pulping liquor from the digester prior to its incineration in the recovery furnace of a
sulfate (kraft) recovery process. It contains dissolved organic wood substances and residual active alkali
compounds from the pulping process.
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 specially 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.
Bleach sequence - Sequence in which chemicals are used to bleach pulp.
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.
Bleaching stage - One of the unit process operations in which a bleaching chemical or combination of
chemicals is added in the sequence of a continuous system of bleaching pulp.
Boiler - Any enclosed combustion device that extracts useful energy in the form of steam and is not an
incinerator.
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Brightness - As commonly used in the paper industry, the reflectivity of a sheet of pulp, paper, or
paperboard for specified light measured under standardized conditions, relative to a magnesium oxide
standard.
Brown stock - Pulp, usually kraft sulfite or groundwood, not yet bleached or treated other than in the
pulping process.
Chemical oxygen demand (COD) - A bulk parameter that measures the oxygen-consuming capacity of
organic and inorganic matter present in water or wastewater. It is expressed as the amount of oxygen
consumed from a chemical oxidant in a specific test.
Continuous digester - A wood-cooking vessel in which chips are reduced to their fiber components using
suitable chemicals under controlled temperature and pressure in a continuous operation.
Continuous discharge - Discharge that occurs without interruption throughout the operating hours of the
facility.
Conventional pollutants - The pollutants identified in sec. 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).
Daily discharge - The discharge of a pollutant measured during any calendar day or any 24-hour period
that reasonably represents a calendar day. For pollutants with limitations expressed as mass, the daily
discharge is calculated as the total mass of the pollutant discharged over the day. For pollutants with
limitations expressed in other units of measurement, the daily discharge is calculated as the average
measurement of the pollutant over the day.
Defoamer - Surface-active agent that inhibits the formation of foam or acts on foam or entrapped air to
cause the bubbles to break and allow air to escape.
Deinked Pulp - Fiber reclaimed from wastepaper by removing ink, coloring materials, and fillers.
Delignification - The process of degrading and dissolving away lignin and/or hemicellulose.
Digester - A pressure vessel used to chemically treat chips and other cellulosic fibrous materials such as
straw, bagasse, rags, etc., under elevated temperature and pressure in order to separate fibers from each
other.
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.
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.
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Elemental chlorine-free (ECF) - Any process for bleaching pulps in the absence of elemental chlorine and
hypochlorite that uses exclusively chlorine dioxide as the only chlorine-containing bleaching agent.
Emission - Passage of air pollutants into the atmosphere via a gas stream or other means.
Emission point - Any location within a source from which air pollutants are emitted, including an
individual process vent, opening within a wastewater collection and treatment system, or an open piece of
process equipment.
End of the pipe - The point at which final mill effluent is discharged to waters of the United States or
introduced to a POTW.
Existing effluent quality (EEQ) - The level at which the pollutants identified in Section 403.24(a)(l) are
present in the effluent of a mill "enrolled" in the Voluntary Advanced Technology Incentives Program.
Extended delignification - A process that enables a mill to lower the Kappa number of the pulp entering
the bleach plant further than is possible with traditional pulping technology. Extended delignification can
be in the form of extended cooking or oxygen delignification.
Furnish - Raw materials (hardwood or softwood) used to manufacture market pulp, paper, or paperboard.
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.
Fine papers - High-quality writing, printing, and cover-type papers having excellent pen and ink writing
surface characteristics.
Green liquor - A solution made by dissolving the sodium and sulfur-containing smelt from the kraft
recovery process prior to causticizing.
Hardwood - Pulpwood from broad-leaved dicotyledonous deciduous trees, such as birch, aspen, oak, etc.
Hypochlorite - Reducing-type of bleaching chemical, usually in the form of calcium hypochlorite
(Ca(OCl)2) or sodium hypochlorite (NaOCl), used in the bleaching of chemical pulps.
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.
Influent - Mill wastes, water, and other liquids, which can be raw or partially treated, flowing into a
treatment plant, reservoir, basin, or holding pond.
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.
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Kappa number -A value obtained by a laboratory test procedure (TAPPI method T-236) for indirectly
indicating the lignin content, usually with pulp yields of 70 percent or less.
Kraft process - Sulfate chemical pulping process.
Lignin - A brown-colored organic substance which acts as an interfiber bond in woody materials. It is
chemically separated from cellulose during the chemical cooking process to form pulp, and is removed
along with other organic materials in the spent cooking liquor during subsequent washing and bleaching
stages.
Market pulp - Bleached or unbleached pulp in the form of bales or sheets for transfer or sale off site.
Maximum daily discharge limitation - The highest allowable daily discharge of a pollutant measured
during a calendar day or any 24-hour period that reasonably represents a calendar day.
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.
Metric ton - One thousand (103) kilograms (abbreviated as kkg), or one megagram. A metric ton is equal
to 2,204.5 pounds.
Minimum level (ML) - The level at which the analytical system gives recognizable signals and an
acceptable calibration point.
New source -(1) Notwithstanding the criteria codified at 40 CFR 122.29(b)(l) and 403.3(k), a source
subject to Subpart B or E is a "new source" if it meets the definition of "new source" at 40 CFR 122.2 and
(i) It is constructed at a site at which no other source is located; or (ii) It totally replaces the process or
production equipment that causes the discharge of pollutants at an existing source, including the total
replacement of a fiber line that causes the discharge of pollutants at an existing source, except as provided
in paragraph (j)(2) of this section; or (iii) Its processes are substantially independent of an existing source at
the same site. In determining whether these processes are substantially independent, the Director shall
consider such factors as the extent to which the new facility is integrated with the existing plant; and the
extent to which the new facility is engaged in the same general type of activity as the existing source. (2)
The following are examples of changes made by mills subject to Subparts B or E that alone do not cause an
existing mill to become a "new source": (i) Upgrades of existing pulping operations; (ii) Upgrades or
replacement of pulp screening and washing operations; (iii) Installation of extended cooking and/or oxygen
delignification systems or other post-digester, pre-bleaching delignification systems; (iv) Bleach plant
modifications including changes in methods or amounts of chemical applications, new chemical
applications, installation of new bleaching towers to facilitate replacement of sodium or calcium
hypochlorite, and installation of new pulp washing system; or (v) Total replacement of process or
production equipment that causes the discharge of pollutants at an existing source (including a replacement
fiber line), but only if such replacement is performed for the purpose of achieving limitations that have been
included in the dischargers' NPDES permit pursuant to 430.24(b).
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Non-continuous discharge - Discharge that occurs only during specific periods of time (seasons, or
operating shift variations). Does not apply to treatment plant or process upset conditions; periods of no
discharge are at least 24 hours in duration.
Nonconventional pollutants - Pollutants that are neither conventional pollutants nor priority pollutants
(see 40 CFR Section 401.15 and Part 423, Appendix A).
NPDES - National Pollutant Discharge Elimination System. 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.
Off-machine metric tons (OMMT) - Mass of final product, including coatings where applicable, at the
off-machine moisture content. For market pulp, the off-machine moisture content is defined to be 10
percent moisture. OMMT is the production normalizing parameter for end-of-pipe limitations for BOD5
and TSS.
Oven dry (OD) - Moisture-free conditions of pulp and paper and other materials used in the pulp and paper
industry. It is usually determined by drying a known sample to a constant weight in a completely dry
atmosphere at a temperature of 100°C to 105°C (212°F to 221 °F). Also called bone dry (BD).
Outfall - The mouth of conduit drains and other conduits from which a mill effluent discharges into
receiving waters.
Oxygen delignification - An extended delignification process used after pulping and brown stock washing
and prior to bleaching. In this process, which can be used on both kraft and sulfite pulps, oxygen gas is
used in an alkaline environment to delignify pulp. Because oxygen delignification typically precedes the
application of chlorine, oxygen delignification wastewaters can be rerouted to the pulping liquor recovery
cycle.
Paper machine - The primary machine in a paper mill on which slurries containing fibers and other
constituents are formed into a sheet by the drainage of water, pressing, drying, winding into rolls, and
sometimes coating.
Peroxide - A short name for hydrogen peroxide (H2O2) or sodium peroxide (Na2O2).
POTW - Publicly-owned treatment works as defined at 40 CFR 403.3(o).
Pretreatment standard - A regulation addressing industrial wastewater effluent quality required for
discharge to a POTW.
Process wastewater - For Subparts B and E only, 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
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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.
Production for chloroform and AOX - The annual unbleached pulp production entering the first stage of
the bleach plant divided by the number of operating days during that year. Unbleached pulp production
shall be measured in air-dried-metric-tons (10% moisture) of brownstock pulp entering the bleach plant at
the stage during which chlorine or chlorine-containing compounds are first applied to the pulp. In the case
of bleach plants that use totally chlorine free bleaching processes, unbleached pulp production shall be
measured in air-dried-metric tons (10% moisture) of brownstock pulp entering the first stage of the bleach
plant from which wastewater is discharged. Production shall be determined for each mill based upon past
production practices, present trends, or committed growth.
Production for conventional pollutants - The annual off-the-machine production (including off-the-
machine coating where applicable) divided by the number of operating days during that year. Paper and
paperboard production shall be measured at the off-the-machine moisture content, except for Subpart C (as
it pertains to pulp and paperboard production at unbleached kraft mills including linerboard or bag paper
and other mixed products, and to pulp and paperboard production using the unbleached kraft neutral sulfite
semi-chemical (cross recovery process), and Subparts F and J (as they pertain to paperboard production
from wastepaper from noncorrugating medium furnish or from corrugating medium furnish) where paper
and paperboard production shall be measured in air-dry-tons (10% moisture content). Market pulp shall be
measure in air-dry tons (10% moisture). Production shall be determined for each mill based upon past
production practices, present trends, or committed growth.
Pulp - A fibrous material produced by mechanically or chemically reducing woody plants into their
component parts from which pulp, paper, and paperboard sheets are formed after proper slushing and
treatment, or used for dissolving purposes (dissolving pulp or chemical cellulose) to make rayon, plastics,
and other synthetic products.
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.
Pulp washer - A piece of pulp mill equipment designed to separate soluble, undesirable components in a
pulp slurry from the acceptable fibers, usually by some type of screening method combined with diffusion
and displacement with wash liquors, utilizing vacuum or the natural force of gravity.
Red liquor - Sulfite pulping liquor.
Screen - A device that removes oversized particles from the pulp slurry after the pulp washer system and
prior to the papermaking equipment. Equipment used to remove oversized particles prior to the pulp
washer system is considered knotters.
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Screen room - The area in a pulp mill where unwanted particles called rejects or tailing are separated from
the accepted fibers with the use of equipment such as knotters, rifflers, refiners, separators, thickeners, and
flat or rotary screens. Closed screen room operation, or screen room closure, refers to the elimination of
wastewater discharge from knotting and screening operations. It is generally accomplished through reusing
the wastewater (screen decker filtrates) as pulp dilution water ahead of the screens, or as wash liquor on a
preceding stage of washing.
Seal tank - A receiving tank located beneath vacuum-type washers and filters. Wash water drops into it
through a pipe and forms a seal to create a vacuum in the sheet-forming cylinder portion of the unit.
Sometimes referred to as a seal pit.
Secondary fiber - Furnish consisting of recovered material. For the purposes of this preamble, secondary
fiber does not include broke but does include 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.
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.
Sodium hydroxide (NaOH) - A strong alkali-type chemical used in making up cooking liquor in alkaline
pulp mills. It is commonly referred to in the mill as caustic or caustic soda.
Softwood - Pulpwood obtained from evergreen, cone-bearing species of trees, such as pine, spruce,
hemlock, etc., which are characterized by having needles.
Spent liquor - Used cooking liquor in a chemical pulp mill which is separated from the pulp after the
cooking process. Spent liquor from kraft pulping is called black liquor. Spent liquor from sulfite pulping is
called red liquor.
Sulfate process - An alkaline pulp manufacturing process in which the active chemicals of the liquor used
in cooking (digesting) wood chips to their component parts in a pressurized vessel (digester) are sodium
sulfide (Na2S) and sodium hydroxide (NaOH) with sodium sulfate (Na2SO4) and lime (CaO) being used to
replenish these chemicals in recovery operations. Also referred to as the kraft process.
Sulfate pulp - Fibrous material used in pulp, paper, and paperboard manufacture, produced by chemically
reducing wood chips into their component parts by cooking in a vessel under pressure using an alkaline
cooking liquor. This liquor consists of sodium sulfide (Na2S) and sodium hydroxide (NaOH). Also
referred to as kraft pulp.
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.
TCDF - 2,3,7,8-tetrachlorodibenzo-p-furan.
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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.
Unbleached pulp - Pulp that has not been treated in a bleaching process.
Variability factor - The daily variability factor is the ratio of the estimated 99th percentile of the
distribution of daily values divided by the expected value, or mean, of the distribution of the daily data.
The monthly variability factor is the estimated 95th percentile of the monthly averages of the data divided
by the expected value of the monthly averages.
Voluntary Advanced Technology Incentives Program (VATIP) - The program established under
Section 430.24(b) (for existing direct dischargers) and Section 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.
Washer - Pulp mill equipment designed to separate soluble, undesirable components in a pulp slurry from
the acceptable fibers. It usually consists of some type of screening method combined with diffusion and
displacement with wash liquid, utilizing vacuum, or the natural force of gravity.
Wastewater - Water carrying waste materials from a mill. It is a mixture of water, and dissolved and
suspended pollutants.
Waters of the United States - As defined in 40 CFR § 122.2. This definition includes all waters that are
currently used, may be used in the future, or were used in the past, in interstate or foreign commerce
(including all waters subject to the ebb and flow of the tide) and adjacent wetlands.
Wet barking - Wet barking operations include hydraulic barking operations and wet drum barking
operations which are those drum barking operations that use substantial quantities of water in either water
sprays in the barking drums or in a partial submersion of the drums in a "tub" of water.
White liquor - A solution of kraft pulping liquor chemicals. White liquor can be made by re-causticizing
green liquor, produced in the kraft recovery cycle, with slaked lime.
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Appendix E
Existing Effluent
Quality (EEQ)
Calculation
Procedures
Background
For those mills that enroll all or some fiber lines in VATIP, and whose existing effluent quality (EEQ) is of
poorer quality than baseline BAT, you must establish Stage 1 permit limits for chlorinated pollutants
equivalent to EEQ or the technology-based limits in the mill's last permit, whichever is more stringent for
each chlorinated pollutant.
Although expressed in the regulation in narrative form, EPA intends that you calculate numeric EEQ
limitations for each participating mill on a case-by-case basis. You must establish "Stage 1" limitations for
TCDD, TCDF, chloroform, AOX, and 12 chlorinated phenolic pollutants that, for each pollutant, are
equivalent to the more stringent of either the technology-based limit on that pollutant in the mill's last
permit or the mill's current effluent quality with respect to that pollutant. EEQ for AOX must be determined
at the end of the pipe based on loadings attributable to that fiber line; for all other pollutants, such as dioxin,
EEQ must be determined at the point where the wastewater containing those pollutants leaves the bleach
plant. These "Stage 1" BAT limits represent the first step in the VATIP and are enforceable against the
participating mill as soon as they are placed in the mill's NPDES permit.
The purpose of the "Stage 1" BAT limits is to ensure that, at a minimum, EEQ is maintained while the mill
moves toward achieving the ultimate VATIP performance requirements for the tier selected by the mill. As
permits are reissued for Tier II or Tier III mills, updated "Stage 1" limitations must be established to reflect
the improving effluent quality of that mill.
EEQ permit limits should be expressed as mass/day (not concentrations or mass per unit production).
EPA suggests mass/day values rather than concentration-based permit limits or production normalized
mass-based permit limits for the following reasons:
1. Many mills enrolling in VATIP will have measurable concentrations of TCDD, TCDF, and
chlorinated phenolic pollutants in their bleach plant effluent. When developing ELG&S, EPA
established concentration-based limitations for TCDD, TCDF, and the 12 chlorinated phenolic
compounds because the model process technologies result in concentrations that are less than or
slightly above the ML for the appropriate test method. When mills enroll in VATIP, however,
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they may not initially operate model process technologies and may be discharging measurable
concentrations of these pollutants.
In addition, as mills install advanced technologies, they will reduce their wastewater discharges,
resulting in increased pollutant concentrations. In this situation, mass limits are more equitable
than concentration limits.
2. Mass/day limits are consistent with the way permits are typically established and assume
production remains constant. Therefore, if a mills makes significant changes in production, you
should reestablish EEQ.
You should calculate EEQ permit limits by using mill sampling results, estimating a "long-term
average" for each pollutant, and multiplying the long-term average (LTA) by a variability factor.
EPA developed ELG&S using sampling data from mills that use the model process technologies that are the
basis of BAT and NSPS. Using these sampling results, EPA calculated an LTA to represent the typical
performance of the technology. EPA also developed variability factors from which the daily maximum
limitations and 30-day average limitations are calculated. EPA recommends that you follow a similar
procedure, using mill-supplied sampling results and EPA's variability factors. Note that although the
variability factor for TCDF was used to determine concentration-based ELG&S, EPA believes it is
reasonable to apply the variability factor to the mass/day LTA for TCDF. EPA also believes it is
reasonable to use the TCDF variability factor for TCDD and the 12 chlorinated phenolic compounds
because these pollutants are all generated during the same process.
To calculate permit limits based on EEQ, follow these procedures:
1. Collect wastewater samples;
2. Review wastewater sampling data;
3. Calculate mass/day for each sampling result;
4. Calculate LTAs for each pollutant;
5. Calculate EEQ permit limits by applying variability factors (VFs); and
6. Compare permit limits based on EEQ with existing permit limits.
These steps are discussed in detail below.
Step 1 - Collect Wastewater Samples
You must require mills to perform wastewater sampling for each chlorinated pollutant. Make sure mills
measure wastewater flows for each sample collected. Table E-l presents the total number of samples EPA
recommends collecting for each chlorinated pollutant. The mill should collect samples to be analyzed for
AOX from its permitted discharge point, and collect samples for the other chlorinated pollutants from each
bleach plant they are enrolling in VATIP. You should recommend that mills use the sampling procedures
outlined in Section 8.
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Pollutant
AOX
TCDD
TCDF
Chloroform
12 Chlorinated Phenolic Compounds
Number of Samples
>30
>3
>3
>7
>3
Note the following special sampling considerations:
Effluent samples should represent the mill's full range of products and processes.
For that reason, samples should not be collected on consecutive days (exception
for AOX), unless mill operations during the sampling period represent the full
range of bleaching operations.
For those mills that continue to bleach with chlorine and/or hypochlorite, at least
one sample to be analyzed for TCDD, TCDF, chloroform, and the 12 chlorinated
phenolic compounds should be collected during such "worst case" bleaching
operations (see Section 8 "When Should Mills Collect Samples?"). Remember,
although mills will most likely convert to full chlorine dioxide substitution to
comply with VATIP limitations, they may initially bleach with chlorine and/or
hypochlorite. Sampling during "worst case" bleaching operations is particularly
important for characterizing chloroform in bleach plant effluent because
chloroform is generated in significant quantities during chlorine and
hypochlorite bleaching.
EPA suggests the mill collect a minimum of seven samples for chloroform
analysis. EPA recommends collecting more samples of chloroform than of the
other pollutants because chloroform's high volatility may lead to losses during
sampling and handling. Remember, specific chloroform sampling procedures
should be followed to prevent losses during sampling and handling (see Section
Once all the samples have been collected and analyzed using the specified test method (see Section 8), you
must review the data to:
1. Confirm that the correct method was used for each sample.
2. Confirm that QC requirements were performed and were in an acceptable range.
3. Ensure the mill reported sampling point flow measurements for each sample.
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4. Make sure the mills reported production information. For AOX, make sure the
mill reported the amount of unbleached kraft pulp entering each bleach plant
during sampling. This is important for determining the AOX load attributable to
only the fiber line(s) enrolling in VATIP. (For the remaining chlorinated
pollutants, you need only review the amount of unbleached kraft pulp entering
the bleach plant of the fiber line enrolling.)
Production information is also important for determining whether sampling
occurs during periods representative of the mill's production. You should
confirm that the production information is consistent with any value(s) specified
in the mill's permit.
5. Make sure sampling occurs during periods representative of the mill's bleach
plant operation. You should confirm that at least one sample was collected
during "worst case" bleaching operations by reviewing chemical application
rates and product records (higher-brightness products may indicate higher
chlorine use). See Section 8 for more details on determining "worse case."
, - " for
For each pollutant, calculate the mass as the product of the wastewater flow and the concentration. Before
calculating the mass, look for the following:
1. Results reported as less than a detection limit. If some results are reported as not
detected, you should use the analytical method's ML to represent the
concentration of the sample. For example, if a TCDF result is reported as "<7
pg/L," use 10 pg/L to calculate the TCDF mass in the sample, since the Method
1613 ML for TCDF is 10 pg/L. See Section 8 for a listing of the minimum
levels for each test method.
2. Multiple measurements. Some mills may submit more than one concentration
measurement for samples collected on the same day. If you receive multiple
measurements, you should count them as one data point by averaging the values.
The text box below demonstrates how to calculate mass/day.
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]
j
]
Example 1 . Calculate the mass/day for the following TCDD sampling results. In this case,
rCDD results were reported in \\%IL and bleach plant flow was reported in L/day. The
bllowing conversion is used:
(51 ng/L of TCDD) x (25,000 L/day of flow) - (ng/1,000,000 pg) = 1.4 ng/day
Data
Point
1
1A
2
3
Sample
Date
4/15/99
4/15/99
4/21/99
4/28/99
TCDD
Concentration
54^g/L
60^/L
32^g/L
<6ng/L
Average or
Adjusted
Concentrations
57ng/L
NA
lO^g/L
Bleach Plant
Flow
25,000 L/day
28,000 L/day
30,000 L/day
Mass/Day
1.4 |ig/day
0.9 ng/day
0.3 (ig/day
sTA - not applicable
1 '"
ige i
ich
Calculate the LTA as the arithmetic average of the mass/day values. The text box below presents an
example.
Example 2.
TCDD.
Average all
Using the results from Example 1, calculate the LTA for
data points, treating Data Point (1 + 1 A) +• 2 as one point.
Data Point
(1 + lA)-2
2
3
LTA
Mass/Day
1.4 (ig/day
0.9 ng/day
0.3 (ig/day
0.9 u^/day
5 - by i' •«"
To calculate an EEQ permit limit, multiply the LTA by a variability factor to account for the variability
associated with process and treatment operations. In developing ELG&S for chlorinated pollutants, EPA
calculated variability factors for AOX, chloroform, and TCDF. EPA did not calculate variability factors for
TCDD and the 12 chlorinated phenolic compounds because the ELG&S for these pollutants are
concentrations that are less than their test method's ML (refer to the Statistical Support Document for the
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Pulp and Paper Industry: Subpart B for more detail regarding statistical development of ELG&S). You
should use the EPA-developed variability factors presented in Table E-2.
'-.'• i".-'[•' .. • • .•:
Analyte
AOX
Chloroform
TCDF (a)
Variability Factors Used to Develop Mass-Based ELG&S for
Chlorinated Pollutants
1-day VF
1.86
2.24
2.75
4-day VF
n/a
1.34
n/a
30-day VF
1.22
n/a
n/a
(a) Use the TCDF variability factor to calculate EEQ permit limits for TCDF, TCDD, and the 12
chlorinated phenolic compounds.
The text box below presents an example of calculating an EEG limit:
Example 3. Using the LTA calculated in Example 2, apply the appropriate
variability factors to determine EEQ permit limits.
TCDD daily maximum limitation = (LTA) x (1-day variability factor) = 0.9
Hg/day x 2.75 = 2.5 (ig/day
(Note: Because once per month is the minimum monitoring frequency for TCDD, TCDF, and the
chlorinated phenolic compounds, there is no 3-day variability factor for these pollutants. Also, there are no
3-day average limits.)
6 -
You may find that permits for some mills include limits for some chlorinated pollutants. Compare limits for
any of the 15 regulated chlorinated pollutants to the permit limit calculated in Step 5. Whichever value is
more stringent (lower) must be used in the reissued permit.
Some permits may include limits for chlorinated pollutants in final effluent whereas EEQ limits for all
chlorinated pollutants (except AOX) must be established in bleach plant effluent. For example, the State of
Maine requires all mills that chemically bleach pulp to meet nondetect permit limits for TCDD and TCDF
in final effluent. In this case, the reissued permit must contain nondetect permit limits for TCDD and TCDF
in final effluent, as required by law, as well as EEQ permit limits for these pollutants in bleach plant
effluent.
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Appendix F
Bleach Plant Flow
Measurements
Mills with operations in Subparts B and E have been subject to E.G.&S that limit pollutant discharges in
final effluent (i.e., end-of-pipe) for direct dischargers and in influent to POTWs for indirect dischargers.
You will find that many, if not all, mills have flow measurement devices or established methods for
measuring their total mill discharge. As specified in the regulation, mills must also comply with bleach
plant effluent limits. For many mills, accurately measuring these streams will be a new task. Mills that do
not currently measure bleach plant effluent flow should install a continuous flow measurement device. This
appendix focuses on:
~i Characteristics of bleach plant effluent flow; and
::j Various flow measurement devices and methods.
' • •.
There are two types of wastewater flows: open channel flow and closed channel flow. Open channel flow is
flow in any channel in which the liquid flows with a free surface. Partially filled pipes, not under pressure,
are also classified as open channel flows. Final effluent is typically discharged in an open channel. Closed
channel flow occurs under pressure in a conduit filled with liquid (e.g., a pipe). Bleach plant effluent
discharges are typically closed channel flow/pressurized pipes. Usually, the sampling location is a tap or
valve on the pressurized pipe.
are the of
EPA strongly recommends mills use flow
, , • , , -., Note: EPA strongly recommends that mills that
measurement devices (meters) to ensure & J
accurate bleach plant effluent flows. These
devices range from relatively simple devices
to complex automated devices. Typical
devices used to measure closed channel flow
include:
Venturi meters,
Pilot tubes,
operate more than one bleach plant be equipped
with measurement devices that monitor the
effluent flow from each bleach plant.
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« Paddle wheels,
« Electromagnetic flowmeters, and
« Ultrasonic flowmeters.
In general, the devices measure the velocity of the flow and then multiply the velocity by the cross-sectional
area of the pipe to calculate the flow rate.
Typical devices used to measure open channel flow include:
« Flumes, and
« Weirs.
To accurately measure open channel flow, flumes and weirs must be coupled with floats, ultrasonic
transducers, or bubblers. The coupled device measures the flow's liquid depth in a flume or a weir to
calculate a flow rate, using established mathematical relationships.
' ' .'
When establishing an appropriate location for flow measurement devices, you must select a location that is
adjacent to the sampling point (tap or valve) but not so close that sample collection interferes with flow
measurement. Refer to flow meter specifications for more detail.
1. NPDES Compliance Inspection Manual (EPA 300-B-94-014)
2. Brater, Ernest F. and Horace Williams King. Handbook of Hydraulics for the Solution of
Hydraulic Engineering Problems. McGraw-Hill, Inc. 1976.
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