United Suia
Environmental Protection
Agmey
uidilinu Diviiion
Wh-SE?
Wat -non DC 20460
July 1384
Water
Guidance Manual
for Pulp, Paper,
and Paperboard and
Builders' Paper and
Board Mills Pretreatment
Standards
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REPORT DOCUMENTATION PAGE
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T PB92-231638
4. TITLE AND SUSTITLI
Guidance Manual for
and Builders' Paper
treatment Standards
:• > -.r. -<'*: •; •:• • ;; -.-.-.••
I. REPORT DATI
July \98>k
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OMB Vo ?"C-*-G f S3
"—:-«•»: VrVrViv'-V'-e =•=.•'•'•"»"• .''-* !.:--"»«"-'
3. SE?ORT TYPE AND DATES COVERED
Pulp, Paper, and Paperboard
and Board Mills Pre-
7. PERFORMING ORGANIZATION NAME(S) AND AOOSS55JIS)
9. SPONSORING, MONITORING AGENCY NAME(S) AND ADDR£SS(ESj
U«S» Environmental Protection Agency
Office of Water
Effluent Guidelines Division
'.Yashington , DC 20460
S, FUNDING NUMBERS
1
8, PfSFOSMING ORGAMZA'.CN >
REPORT NUMBER i
i
1
j
10.- SPONSORING - MONlTOSiNG
AGENCY RIPORT NUMBER
11. SUPPLEMENTARY NOTES
1ia. DISTRIBUTION AVAILABILITY STATEMENT
126. DISTRIBUTION CODE
13. ABSTRACT (Maximum 200 words)
Guidance manual on the application of categorical pretreatment
standards (40 CFR Part 425) to pulp, paper and paperboard and
builder s paper and board mills that discharge to publiclv owned
treatment works.
u, SUBJECT TERMS
17, SECURITY CLASSIFICATION 18. SECURITY CLASSIFICATION
OF REPORT OF THIS PAGI
unclassified unclassified
IS. NUMB!* OF PAGES
16. PRICE CODE
9. SECURITY CLASSIFICATION 20. LIMITATION C? - o$'.7ACT
OF A3STRACT
unclassified unlimited
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GUIDANCE MANUAL
FOR
PULP, PAPER, AM) PAPERBQARD
AND BUILDERS' PAPER AND BOARD MILLS
PRETREATMINT STANDARDS
Prepared by
The
Effluent Guidelines Division
Office of Water Regulations and Standards
and
permits Division
Office of water Enforcement and permits
September 1984
U.S. Environmental protection Agency
401 M. Street S.W.
Washington, DC 20460
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\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
" WASHINGTON, D.C. 20460
f
SiP2|
OFFICI OF
WATER
MEMORANDUM
SUBJECT: Guidance Manual for Pulp, Paper, and Paperboard
and Builders' Paper and Board Mills Pre treatment
Standards
FROM: Martha G. Prothro, Director
Permits Division (EN-336)
S^Jeffery D. Denit, Director
Effluent Guidelines Division (WH-552)
TO : Users of the Guidance Manual
This manual provides information to assist Control Authorities
and Approval Authorities in implementing the National Categorical
Pre treatment Standards for Pulp, Paper and Paperboard and Builders'
Paper and Board Mills (Pulp and Paper) Point Source Categories
(40 CFR Part 430). It Is designed to supplement the more detailed
documents listed as references in the manual; It is not designed
to replace them. If you need more complete information on a
specific item, you should refer to the appropriate reference.
IPA developed this manual to fill several needs. First, it
should be useful to Control Authorities In responding to most
routine inquiries from regulated mills. More complex inquiries
may require the use of the listed references.
Second, the manual addresses application of the combined
wastestream formula to Integrated facilities with regulated and
unregulated was tes treams . It also provides current information
on removal credits, variances and reporting requirements* It
further explains how facilities subject to these regulations
may use the certification procedure to minimize their sampling
and analysis for zinc, trichlorophenol, and pentachlorophenol .
This manual Is the second in a series of Industry-specific
guidance manuals for implementing categorical pretreatment
standards. The first manual for the electroplating and metal
finishing industry was published in February 1984 and several
others will be published soon. He also plan to issue manuals
covering removal credits, the combined wastestream formula and
the conversion of production-based categorical standards to
equivalent concentration-based standards.
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-2-
Please feel free to write to either the Office of Water
Regulations and Standards (WH-552) or the Office of Water
Enforcement and Permits (EN-336) with suggestions, additions, or
improvements.
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ACKNOWLEDGEMENTS
We wish to acknowledge the considerable efforts and cooperation of the
many people whose contributions helped in the successful completion of this
document.
This document was prepared under the direction of Mr. Marvin Rubin,
Office of Quality Review, Effluent Guidelines Division and Dr. James Gallup,
Hational Pretreatment Coordinator. Mr. Robert Bellinger and Ms. Wendy Smith
of the Effluent Guidelines Division, and Mr. Timothy Dwyer of the National
Pretreatnent Prograo are to be acknowledged for their valuable input. In
addition, members of the Office of General Counsel and other members of the
Effluent Guidelines Division and Office of Water Enforcement of Permits are
acknowledged for their Important contributions.
This document was prepared by JRB Associates under EPA Contract No.
68-01-6514.
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TABLE OP CONTENTS
Chapter ' Page
1. INTRODUCTION 1-1
1.1 HISTORY OF THE PULP, PAPER AND PAPERBOARD AND BUILDERS'
PAPER AND BOARD MILLS EFFLUENT LIMITATIONS GUIDELINES AND
STANDARDS..... 1-2
2. PULP, PAPER AND PAPERBOARD CATEGORICAL PRETREATMSNT
STANDARDS , 2-1
2.1 AFFECTED INDUSTRY 2-1
2.2 PRET1EATMENT STANDARDS FOR THE PULP, PAPER,
AND PAPERBOARD INDUSTRY 2-5
2.3 EXCEPTIONS FROM REGULATION COVERAGE: PCP/TCP/ZINC
CERTIFICATION , 2-10
2.4 POLLUTANTS EXCLUDED FROM REGULATION 2-11
2.5 COMPLIANCE DATES 2-11
3. TREATMENT TECHNOLOGIES 3-1
3.1 LIME PRECIPITATION 3-1
3.2 CHEMICAL SUBSTITUTION 3-1
4. REQUIREMENTS OF THE GENERAL PRETREATMENT REGULATIONS,.......... 4-1
4.1 INTRODUCTION 4-1
4.2 CATEGORY DETERMINATION REQUEST 4-2
4.3 MONITORING AND REPORTING REQUIREMENTS OF THE GENERAL
PRITREATMENT REGULATIONS 4-2
4.3.1 Baseline Monitoring Reports. 4-2
4.3.2 BMR Reporting of PCP/TCP/Zinc 4-3
4.3.3 BMR Due Dates , 4-3
4.3.4 BMR Content... 4-3
4.3.5 Report on Compliance. ...,.....,,, 4-4
4.3.6 Periodic Reports on Continued Compliance 4-5
4.3.7 Notice of Slug Loading , 4-5
4.3.8 Monitoring and Analysis to Demonstrate
Continued Compliance 4-5
4.3,9 Signatory Requirements for Industrial
User Reports 4-6
4.3.10 Recordkeeping Requirements 4-6
4.4 APPLICATION OF THE COMBINED WASTESTREAM FORMULA 4-6
4.5 REMOVAL CREDITS 4-8
4.6 FUNDAMENTALLY DIFFERENT FACTORS VARIANCE. 4-16
4.7 LOCAL LIMITS. 4-16
REFERENCES R-i
I//
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I. INTRODUCTION
The National Pretreatment Program establishes an overall strategy for
controlling the introduction of nondomestic wastes to publicly owned treatment
works (PQTWs) In accordance with the overall objectives of the Clean Water
Act. Sections 307(b) and (c) of the Act authorize the Environmental Protec-
tion Agency to develop national pretreatment standards for new and existing
dischargers to POTWs. The Act made these pretreatment standards enforceable
against dischargers to publicly owned treatment works.
The General Pretreatment Regulations (40 CFR Part 403) establish ad-
ministrative mechanisms requiring nearly 1,500 POTWs to develop local pre-
treatment programs to enforce the general discharge prohibitions and specific
Categorical Pretreatment Standards. These Categorical Pretreatment Standards
are designed to prevent the discharge of pollutants which pass through, inter-
fere with, or are otherwise incompatible with the operation of the POTWs. The
standards are technology-based for removal of toxic pollutants and contain
specific numerical limitations based on an evaluation of specific technologies
for the particular industrial categories. As a result of a settlement agree-
ment, the EPA was required to develop Categorical Pretreatment Standards for
34 Industrial categories with a. primary emphasis on 65 classes of toxic pol-
lutants.
This manual will provide guidance to POTWs on the application and
enforcement of the Categorical Pretreatment Standards for the Pulp, Paper and
Paperboard and Builders' Paper and Board Mills Point Source Categories. This
document is based primarily on two sources; federal Register notices, which
include the official announcements of the Categorical Standards, and the Final
Development Documents for the Pulp, Paper and Paperboard and Builders' Paper
and Board Mills, which provide a summary of the technical support for the
regulations. Additional information on the regulations, manufacturing
processes, and control technologies can be found in these sources. A listing
of the references used in the development of this manual is provided at the
end of this document.
1-1
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L.I HISTORY OF THE PULP, PAPER AND PAPERBOARD AND BUILDERS' PAPER AND BOARD
MILLS EFFLUENT LIMITATIONS GUIDELINES AND STANDARDS
EPA promulgated BPT, BAT, NSPS, and PSNS for the builders' paper and
roofing felt subcategory of the builders' paper and board mills point source
category on May 9, 1974 (39 FR 16578; 40 CFR Part 431). IPA promulgated BPT,
BAT, NSPS, and PSNS for the unbleached kraft, sodium-based neutral sulfite
semi-chemical, ammonia-based neutral sulfite semi-chemical, unbleached kraft-
neutral sulfite semi-chemical (cross recovery), and paperboard from wasCepaper
subcategorles of the pulp, paper, and paperboard point source category on May
%
29, 1974 (39 FR 18742; 40 CFR Part 430). EPA promulgated BPT for the dis-
solving kraft, market bleached kraft, BCT (board, coarse, and tissue) bleached
kraft, fine bleached kraft, papergrade sulfite (blow pit wash), dissolving
sulfite pulp, groundwood-thermo-mechanical, groundwood-CMN papers, groundwood-
fine papers, soda, deink, nonintegrated-fine papers, nonintegrated-tissue
papers, tissue from wastepaper, and papergrade sulfite (drum wash) subcate-
gorles of the pulp, paper, and paperboard point source category on January 6,
1977 (42 FR 1398; 40 CFR Part 430).
Several industry members challenged the regulations promulgated on May
29, 1974, and on January 6, 1977. These challenges were heard in the District
of Columbia Circuit Court of Appeals* The promulgated regulations were upheld
in their entirety with one exception. The Agency was ordered to reconsider
the BPT BODS limitation for acetate grade pulp production in the dissolving
sulfite pulp subcategory (Weyerhauser Company, et al. v. Costle, 590 F. 2nd
1011; D.C. Circuit 1978). In response to this remand, the Agency proposed BPT
regulations for acetate grade pulp production in the dissolving sulfite pulp
subcategory on March 12, 1980 (45 FR 15952). The Agency is currently assess-
ing the costs and economic impacts associated with attainment of the proposed
BPT limitation. Promulgation of this rule will occur at a later date.
IPA published proposed effluent limitations guidelines for BAT, BCT, '
NSPS, PSES, and PSNS for the pulp, paper, and paperboard and the builders*
paper and board mills point source categories in the Federal Register on
January 6, 1981 (46 FR 1430). At the time of proposal, the subcategorization
scheme was modified to include 25 subcategorles in the pulp, paper, and
paperboard industry.
1-2
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These 25 subeategories of the pulp, paper, and paperboard industry (40
CFR Parts 430 and 431) are as follows:
40 cm Part 430
* Subpart F - dissolving kraft
* Subpart G - market bleached
kraft
• Subpart H - board, coarse, and
tissue (BCT) bleached kraft
* Subpart I - fine bleached kraft
• Subpart P - soda
* Subpart A - unbleached kraft
• Subpart B - semi-chemical
t Subpart V - unbleached kraft and
semi-chemical (BFT limitations
for some mills in this
subcategory are included in
subpart D - unbleached kraft -
neutral sulfite semi-chemical
(cross recovery))
* Subpart K - dissolving sulfite
pulp
» Subpart J - papergrade sulfite
(blow pit wash)
* Subpart U - papergrade sulfite
(drum wash)
• Subpart L - groundwood-chemi-
mechanical
* Subpart M - groundwood-thermo-
mechanical
* Subpart N - groundwood-coarse,
molded, and news (CMN) papers
* Subpart 0 - groundwood-fine
papers
• Subpart Q - deink
• Subpart E - paperboard from
wastepaper
* Subpart T - tissue from waste-
paper
* Subpart W - wastepaper molded
products
* Subpart R - nonintegrated-fine
papers
• Subpart S - nonintegrated-tissue
papers
• Subpart X - nonintegrated-
lightweight papers
• Subpart Y - nonintegrated-filter
and nonwoven papers
* Subpart Z - nonintegrated-
paperboard
40 CFR Part 431
* Subpart A - builders' paper and
roofing felt
On November 18, 1982, EPA promulgated BPT effluent limitations for four
new subcategories of 40 CFR 430;
* Subpart W - Wastepaper Molded Products
* Subpart X - Nonintegrated-Lightweight Papers
• Subpart Y - Nonlntegrated-Filter and Nonwoven Papers
* Subpart Z - Nonintegrated-Paperboard.
and for new subdivisions of two existing subcategories of 40 CFR 430:
• Subpart E - Faperboard from Wastepaper
» Subpart R - Nonintegrated-Flne papers.
1-3
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BAT, NSPS, PSES and PSNS limitations were also promulgated for 24 of the
25 subcategories to control toxic pollutants. NSPS also controls conventional
pollutants.
All pulp, paper and paperboard and builders* paper and board mills must
comply with Pretreatment Standards for Existing Sources (PSES) for penta-
chlorophenol and trichlorophenol by July 1, 1984. In addition, Subpart M -
Groundwood-Thermo-Mechanieal, Subpart N - Groundwood-Coarse, Molded and News
(CMN) Papers, and Subpart 0 - Groundwood-Fine Papers oust comply with PSES for
zinc by July 1, 1984. A more complete discussion of compliance dates is
presented in subsequent sections of this manual*
1-4
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2. PULP, PAPER AND PAPERBOARD CATEGORICAL
PRETREATMENT STANDARDS (40 CF1 430)
2.1 AFFECTED INDUSTRY
The Pulp, Paper and Paperboard Categorical Pretreatnent Standards are
applicable to wastewater from mills wMch fall into three specific segments of
the industry:
(1) Integrated Segment
(2) Secondary Fibers Segment
(3) Nonintegrated Segment.
These three segments and their components are discussed below:
(1) Integrated Segment - Mills where pulp alone or pulp and paper or
paperboard are manufactured on-site are referred to as integrated
mills.
(2) Secondary Fiber Segment - Mills where wastepaper is used as the
primary raw material to produce paper or paperboard are referred to
as secondary fiber mills.
(3) Nonintegrated Segment - Mills where paper or paperboard are manu-
factured but pulp ie not manufactured on-site are referred to as
nonintegrated mills.
Each of the 25 subcategories of the pulp, paper and paperboard industry
falls into one of these segments. Table 2.1 lists the subcategories by
segment.
The following is a brief overview of the two major manufacturing opera-
tions of pulp, paper and paperboard mills: 1) pulp production and 2) paper
production.
2-1
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TABLE 2.1
PULP, PAPER AND PAPERBOARD SUBCATEGORIES GROUPED
BY MAJOR INDUSTRY SEGMENTS
to
to
Integrated Segment
Dissolving Draft
Market Bleached Draft
BCT (Board, Coarse, and
Tissue) Bleached Draft
Fine Bleached Draft
Soda
Unbleached Kraft
• Llnerboard
• Bag and Other Products
Semi-Chemical
Unbleached Kraft and Semi-Chemical
Dissolving Sulflte Pulp
• Nitration
• Viscose
• Cellophane
• Acetate
Papergrade Fulflte (Blow Pit Wash)
Papergrade Sulflte (Drum Wash)
Groundwood-Thermo-Mechanlcal
Groundwood - Coarse, Molded, and
News (C, M, N) Papers
Groundwood - Fine Papers
Groundwood-Cheml-Mechanlcal
Secondary Fibers Segment
Delnk
• Fine Papers
• Tissue Papers
• Newsprint
Tissue from Wastepaper
Paperboard from Wastepaper
• Corrugating Medium Furnish
• Noncorrugatlng Medium Furnish
Wastepaper-Molded Products
Builders' Paper and Roofing Felt
Nonlntegrated Segment
Nonlntegrated-Flne Papers
• Wood Fiber Furnish
• Cotton Fiber Furnish
Nonlntegrated-Tlssue Papers
Nonintegrated-Lightweight Papers
• Lightweight Papers
• Lightweight Electrical papers
Nonlntegrated-Fllter and Nonwoven
Papers
Nonlntegrated-Paperboard
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Pulp Production
The four major steps In the production of wood pulp are wood preparation,
pulping, washing and screening, and bleaching (if required). The end result
is a brown or white pulp that can be used in the manufacture of paper and
paperboard products.
The initial step in the production of wood pulp is raw material prepara-
tion. A common sequence of operations employed during preparation of whole
logs is slashing, debarking, washing, chipping, and storage. This may vary
depending on the form in which the raw materials arrive at the mill.
After preparation, the wood is reduced to a usable fora of fiber. This
operation is called "pulping" and is accomplished by several possible combina-
tions of mechanical and/or chemical "cooking" processes. The most common
typei of pulping processes employed are: 1) mechanical pulping (i.e.,
groundwood and thermo-mechanical) and 2) chemical pulping (i.e., alkaline
(kraft and soda), sulfite, or semi-chemical processes).
After pulping, the brown stock (pulp fibers) is washed and screened. The
screened rejects are then either repulped or discarded. Where a white or
lightly colored pulp is required, an optional stage, bleaching, is employed.
In the bleaching process, the brown stock is decolored (brightened or
whitened) through the use of chemicals such as chlorine, chlorine dioxide,
sodium hypochlorite, zinc hydrosulfite, or sodium hydrosulfite. The mechanism
of decoloring results from the removal or brightening of lignins and resins.
After the brown stock is washed and screened, or bleached, it is stored for
use in making paper or paperboard.
At secondary fiber mills, wastepaper is prepared to produce a stock to be
used in the manufacture of paper or board products. Fibers suitable for
papermaking result after wastepaper is cooked in a pulper, where it is
repeatedly exposed to rotating impeller blades. Depending on the end product
usage, heavily-printed wastepaper may be deinked. Ink and other nondesirable
components are removed by flotation and washing using detergents, dispersants,
fixing and softening agents, and other chemicals* If desired, these fibers
2-3
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can be bleached using chlorine, sodium hypochlorite, or chlorine dioxide; If
wastepaper is high in groundwood content, peroxides or hydrosulfites are used.
After washing and screening, the stock is stored prior to papermaking.
PaperProduction
At all mills (integrated, secondary fiber, or nonintegrated) where paper
or paperboard are produced, purchased pulp or pulp produced on-site Is
resuspended in water and blended with other components. The stock Is then
mechanically processed in beaters or continuous refiners to ensure that the
necessary matting characteristics are provided to obtain the desired strength
in the paper or paperboard. Another aspect of stock preparation is the
addition of chemical additives. The most common chemical additives are alum
and rosin (for sizing), fillers (clays, calcium carbonate, and titanium
dioxide for opacity, smoothness, and brightness), resins (to Improve wet
strength), dyes, and starches (for improved strength, erasability, and
abrasion resistance).
After the stock has been prepared to the specifications required to make
the product, the sheet (paper) or plies (paperboard) are made. There are two
principal methods to make paper or board: on a Fourdrlnier or a cylinder
machine. Both methods are similar with the major significant differences
occurring in the "wet-end" formation process. On the Fourdrinier machine, the
slurry (diluted pulp) flows from the headbox onto an endless moving wire
screen where the sheet is formed and through which water drains by gravity and
suction. On a cylinder machine, a revolving wire-mesh cylinder rotates in a
vat of diluted pulp and picks up a layer of fibers which are deposited onto a
moving felt. The cylinder machine has the capacity to make multi-layered
sheets, which accounts for its principal use in the manufacture of paperboard.
Both types of machines are equipped with press and dryer sections. The
sheet is transferred from the wire or felt to the press section where addi-
tional water is removed through mechanical means prior to drying. In the
dryer section, the sheet or board is carried through a series of heated hollow
steel or iron cylinders. Sizing or coatings can be applied at the dry end or
on separate machines. Following the drying section, the sheet can be calen-
dered for a smooth finish and packaged for shipment.
2-4
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A flow diagram depicting the major elements of pulp and paper production
is presented in Figure 2.1,
The pulp, paper, and paperboard industry is a high water use industry.
Major uses of water are industry-wide although the amount varies from segment
to segment. At some mills, recycle streams or evaporative techniques are used
so that little or no water is discharged or water that is discharged has been
utilized for a number of different purposes prior to discharge. Figure 2,1
indicates where water or recycle streams are utilized in the pulp and paper
production processes and the waste products (solid, liquid and gaseous)
associated with each.
It has been estimated that wastewater discharges from pulp, paper, and
paperboard mills total approximately 4,2 billion gallons per day. The largest
contributor of wastewater is the integrated segment where discharges total
approximately 3.6 billion gallons per day followed by the nonintegrated
segment (0.32 billion gallons per day) and the secondary fibers segment (0.26
billion gallons per day). In addition, approximately 37 percent of all pulp,
paper, and paperboard mills discharge their wastewater to publicly owned
treatment works (POTWs). However, the majority of these indirect discharging
mills fall into the lower water use segments (secondary fibers and non-
integrated). Therefore, although in general the pulp, paper, and paperboard
industry is a high volume water use industry, its Indirect dischargers are
average to low wastewater generators.
2.2 PRETREATMENT STANDARDS FOR THE PULP, PAPER, AND PAPERBOARD INDUSTRY
Indirect dischargers in 24 of the 25 subcategories that manufacture pulp,
paper, and paperboard, under the Pulp, Paper, and Paperboard and Builders'
Paper and Board Mills Point Source Categories (40 CFR Parts 430 and 431,
respectively), are currently subject to Categorical Pretreatment Standards for
pentachlorophenol (PCP) and trichlorophenol (TCP). The only subcategory
without PSES for PCP and TCP is groundwood chetnl-meehanical pulp. Zinc is
only controlled for groundwood mills. Table 2.2 presents PSES categorical
standards for the pulp, paper, and paperboard industry. Certification for PCP
and TCP as an alternative to these standards is explained in the next section.
2-5
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FIGURE 2.1
GENERAL FLOW SHEET
PULPING AND PAPERMAKING PROCESS
RAW MATERIALS
vot
AC 10 SULPITI uiauoft
ALKAUHI tULPATC LIOUM
(KRAFT)
ttlUfHAL 1ULFITI UQUOf)
PUHDAMtHTAL PHOCES3
JACTOUt
WA5TE3
HQUIO
• MlTC wATCt OR
*ATI»
*HITt WATC* OH
•LIACMIM AND OTMIft
MCCtSMRT CttC«Cftl«
•ATE* C«
•AT III
OTI L
tut r
AUUH I
•TA»CII I
VMItN HATfM OH M
VNITI WATtP MtUSI
COATIH* QHflilCAL*
PINISMIM* AND
CONVI»TI«i
COOCIPI* «*T|M
•AM •IPUSI
VOQD PAHTlCLEI
AHB iLIVtRi
•A«OU«T
•OLPITI
LiQUOk
ILO« PIT CCLLICTIO
COHDCMIATI
Mil *ASHIM«
HUD VAtriiNf
ACID »t,AMt
•AITI
MtlDUtt
•AIM
IA* LIOUOR
*A«TI MTIM
•LIACM
UP
VHtTK VATIM
CLtAK *
KNOTS
fill I
fltt*
OUT
F1LLIM
••OKI
COATIUM
PIHtlHID PAPtl
PRODUCT!
2-6
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TABLE 2.Z
PRETMATKEirT sfAKBAWJS FOR EXISTING SOURCES
(coocentrslions «•,/!)
Diy
Subca tenor?
Integrated Sefjwut
Dissolving Kraft
Market Bleached Iraft
8CT 8 leached Kraft
Alkaline-Fine*
Unbleached Kraft
a Linerboard
0 tig
S«sU-CbMical
Unbleached Kraft and Sni-ChcMieal
Dissolving Sulfite Pulp
o nitration
o Viicose
o Cellophane
9 Acetate
Paper jrade Sulfite*
Groundvc-Jd-Tbe two-Mechanical
Croundvood-CMt Papen
Crewwlw««i-riBe Papen
Secondary fibers Seieeat
Dei ok
o fine Papers
o Tissue Papers
o Kevtprint
Tissue free Maitepaper
Paperboard fro* w.»»tepaj>er
o Corrugattai ilediua Furaiih
0 Noncorrugatini lediun Furni»o
Wa»t«pap«r-Molded Product!
Builders' Paper and Roofia| Felt
o Wood Fiber fursim
o Cotton fiber Furnisb
Konifttegrated«Tisiue Papers
o Lightweight
o Electrical
NotUoleirited-niter
aad Xonwovea Papers
Son iotejra ted -Pjptr board
PCP1
{0.0113(S5.n/Y
(0. 011X41. 63/Y
(0. 0113(31. 4)/Y
(0. 0113(30. 9)/f
(0,0113(12.63/1
(0. 0113(12. 6}/Y
(0, 032X10. 33/Y
(0. 011X14. 03/T
(O.OU)(66.0)/Y
(0, 0113(66. 0)/Y
(0.011)(66.0)/T
(0, 0113(72. 7)/Y
*
(0. 0113(21, 13/T
(0. 0113(23. 83/y
(0. 011X21, 9}/Y
(0. 032X24. 4}/f
(0. 032X24. 4)/Y
(0. 0323(24. 4J/Y
(0,032>(1S.2^/Y
(0. 0325(7. 23/Y
(0. 0323(7. 2)/Y
(0.032)(21.1)/y
(0, 0323(14. 43/Y
(0, 032)(ii, 23/Y
(0. 0323(42, 3)/Y
(0. 032X22, 93/Y
(0. 0323(48, ?3/Y
(0-032)(76,93/Y
(0. 0323(59. 9)/Y
(0.0323(12. 93/Y
TCP1
(0.082)($S.1)/Y
(0.082)(4J.6)/¥
(0. 0823(35. 43/Y
(0. 0823(30. 93/?
(0.01Q)(12.6)/Y
(0. 0103(12. 63/Y
(0.0103(10. 33/Y
(0. 0103(14. 0)/Y
(0. 0823(66. 0}/Y
(0. 082X66. 03/Y
(0, 0823(66. 0)/Y
(0. 082X72, 7)/Y
*
(0. 010X21. 13/T
(0.010)(23. 83/Y
(0,010X21, 93/Y
(0,0823(24. 43/Y
(0. 0823(24, 4)/Y
(0.010)(24. 43/Y
10.0 JO;(25.iJ/ Y
(0. 0103(7. 2)/Y
(0. 010)(7. 23/Y
(0. 0103(21. 13/Y
(0.0103(14. 43/Y
(0 010)(I3. 23/Y
(0.0103(42. 33/Y
(0. 0103(22, 9)/Y
(0. 010)(48. ?)/Y
(Q.010)(76. 93/Y
(0,Q10)(59.93/Y
(0.8103(12. 93/Y
Ziac
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
KA
NA
(3,0X21 - U/Y
(3.0X23.8J/Y
(3. 03(21. 93/Y
NA
KA
NA
NA
NA
NA
NA
NA
NA
NA
NA
KA
NA
NA
NA
Y * Hill wattevstsr diicharged pet too of product.
NA « Hot AppUcablt— -
*Pip«rgride SuKit* Equations:
PCF * ((0.011X12, 673 ««p(O.OI7«3)/Y
TCF « ((0.082X12.673 **p(0.017«))/Y
Vhett m equals ptrcent sulfite pulp produced ao-iitt in tbc final product.
'PCP • PentJchloropheool
'TCP *
Fine Bl«»ched Kraft »n<1 Soda iubcat«fori.«i ,
M.-clud<« Piprnrade Sulfit* (Blow Pit Waifi) and Papergti'ie Suific*
', Drua Waih) jubcitejori««.
2-7
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TABU 2.2 (continued)
PSES QPTlOKAi MASS LIMITS
(k|/kJn or lb/1000 Ibi)
Subcateiory
I p t e ft r « t e d S e CT* ° t
Di*aoLviaj Kraft
Harket Sleiched Kraft
BCT Bletcbed Kraft
Alkaliae-Fine*
Unbleached Kraft
o Linerboird
o Big
Seat-Cbeaicil
Uableaehed Xraft and Seat"Ch*»ie«l
Ol»«olviaj Sulfite Pulp
o Nitration
o Viicoie
a Cellopfcjn*
a Acetate
Pipcrgrsde Sulfite*
GrouDduood-Hie rao~Kecliaai ca 1
Croundvood-OW Piperj
Crouodwood-Fioe Paperi
Secondary Fiber* iejoicct
Dei ok
o Ftne Piper*
o ?i**u« Piper*
o .Vewsprinc
Tljiue J"roa Wntepiper
Piperboird from Waitepiper
o Corrugicini Median Furaiib
o Noocorrugi tioj Medium Fumiah
W«*cep*pec-Kolded Product!
Builders' Paper and RaofiD| Felt
ypniB.tegf_« ted Segaent
Koointe|tited-Fin* Piperi
o Wood Fiber Furaiib
o Cotton Fiber Furaisb
Noniatt jnLed-Ti uue Piperi
NoaiotegraCed-tigktweigElt Pipers
o Lightweight
o Electrical
NoDiacejrated-FiUer
and Nonwoveo Paper*
Noolntegri ted-Piperb»ird
PCP1
0.0023
0.0019
0,0016
0,0014
0,00058
0.00058
0.0014
0.00064
0,0030
0.0030
0.0030
0.0033
*
0,0(3097
0.001!
0.0010
0.0033
0.0033
0 0011
0.0034
0.00096
O.OC096
0.0028
0.0019
0.0020
0.0056
0.0031
O.OOS5
0.010
0.0080
0.001?
MaxiBua Day
TCP1
0.019
0.014
0.012
a. on
0.00053
0.00023
0.00043
O.OOOS9
0.023
0.023
0 013
0.025
*
0.00088
O.OOOS9
0.00092
0,0084
0,0084
o ROTO
0.0011
0.00030
0.00030
0.00088
0.00060
0.00064
0.0018
0.00096
0.0020
0.0032
0.0025
0.00054
2ioe
HA
NA
HA
.VA
HA
MA
NA
KA
»A
MA
SA
MA
KA
0,26
Q.3Q
0,27
KA
NA
vr
KA
KA
NA
MA
NA
KA
NA
NA
NA
MA
!1A
:IA
T » Mill vattevater t)J»chirged per tea of product.
NA » Not Applicable —
*Papergrade Sulfite £<}u4tioai:
PCP • 0.00058 e>p(0.0l7c)
TCP * 0.0043 ejryCO.Gl?*)
Wbere I equal* percent lulfite pulp produced oa-fit« in tte fiail product.
*PCP » Peotachlorapbenol
3TCP » Tricijloropfeeool
'iQcludej Fine Alcactaed Kraft tad Soda tub-categories.
*Iacladea Papertride Sjlfite (Blow Pit Vnb} tod Psperfrade Sulfite
(Crua With) fubcicegorlea.
2-8
-------
PSSS for zinc are identical to BPT limitations for control of this toxic
metal. Standards are based on the maximum anticipated discharge concentration
of zinc after the application of lime precipitation. EPA expects that this
standard will be attained through substitution of sodium hydrosulflte for zinc
hydrosulfite in bleaching groundwood pulp.
EPA assessed TCP discharge characteristics at mills In the pulp, paper,
and paperboard industry taking Into account whether chlorophenollc-containing
bioeides were used in the manufacturing process. EPA found that TCP dis-
charges were significantly lower at those mills where ehlorophenolic-
containlng bioeides were not used. To determine the discharge levels of TCP
that result from substitution of chlorophenolic-contalnlng bioeides, EPA then
assessed all available data for mills where ehlorophenolic-rcontalnlng biocides
were not employed. EPA found that higher levels of TCP were discharged from
mills where chlorine-containing compounds were used to bleach pulp than from
other mills. This is because low levels of TCP are formed in the bleaching
process at mills where chlorine-containing compounds are used to bleach pulp.
EPA determined the maximum discharge levels of TCP for mills where chlorine-
containing compounds were used in the bleaching process and for mills where no
chlorine-containing compounds were used. Based on all available data, the
maximum discharge concentration of trlchlorophenol at indirect discharging
mills where chlorophenollc-containing biocides were not used and chlorine-
containing compounds were used to bleach pulp was determined to be 82 ug/1.
PSES were established using this concentration for those mills which bleach
pulp as part of their production processes. The maximum discharge concentra-
tion of trlchlorophenol at indirect discharging mills where chlorophenolic-
containing biocides were not used and where chlorine-containing compounds were
not used to bleach pulp was determined to be 10 ug/1. PSES were established
using this concentration for those mills which do not bleach pulp as part of
their production processes.
EPA assessed PCP discharge characteristics at mills in the pulp, paper,
and paperboard industry taking Into account whether chlorophenollc-containing
biocides were used in the manufacturing process. SPA found that PCP dis-
charges were significantly lower at those mills where chlorophenolic-
containing biocides were not used. To determine the discharge levels of PCP
2-9
-------
that result from substitution of chlorophenolic-containing blocldes, the
Agency assessed all available data for mills where chlorophenolic-containing
biocldes were not employed. EPA found that higher levels of PCP were dis-
charged from mills where wastepapers were processed than from other mills.
This is caused by low level PCP contamination of wastepaper. EPA determined
the maximum discharge levels of PCP for mills where wastepaper was processed
and for mills where wastepaper was not processed* Based on all available
data, the maximum discharge concentration of pentachlorophenol at indirect
discharging mills where chlorophenolic-containing biocides were not used and
where wastepaper was processed was determined to be 32.0 ug/1. PSES were
established using this concentration for those mills which utilize wastepaper
as a raw material. The maximum discharge concentration of pentachlorophenol
at Indirect discharging mills where chlorophenolic-containing biocides were
not used and where wastepaper was not processed was determined to be 11 ug/1.
PSES were established using this concentration for those mills which do not
utilize wastepaper as a raw material.
PSES are expressed as allowable maximum daily concentrations (milligrams
per liter). Final pretreatment standards include a mathematical formula .that
accounts for flow differences to ensure that the standards do not discourage
the implementation of water conservation technologies at indirect discharging
mills. Mass limitations (kg/kkg or lb/1000 Ib of product) are provided as
guidance in cases where it is necessary to impose mass limitations for control
of pollutants discharged from contributing pulp, paper, and paperboard mills
to POTWs. Mass limitations were calculated as the product of the maximum
allowable concentrations and the flows that formed the basis of BPT limita-
tions for each subcategory.
2.3 EXCEPTIONS FROM REGULATION COVERAGE: PCP/TCP/ZINC CERTIFICATION
As stated in previous sections, pretreatment standards for existing
(PSES) and new sources (PSNS) were promulgated in 24 of 25 subcategories for
pentachlorophenol and trichlorophenol and in three of 25 subcategories for
zinc. Pentachlorophenol (PCP) and trichlorophenol (TCP) are associated with
certain biocides and slimlcides used in pulp and paper production processes.
The basis of pretreatment standards controlling PCP and TCP was discussed in
the previous section. The categorical pretreatment standards allow, In
2-10
-------
situations where a mill can certify, through sampling and analysis of its
wastewaters or through careful inventory of its bioclde and sllmlcide formula-
tions that It does not utilize chlorophenolic-containing biocides and
alimlcides, the POTW authority to not require routine compliance monitoring
for verification of PSES and PSNS categorical standards. However, the
industry may be required to perform sampling and analysis of its wastewater
for purposes of Baseline Monitoring Reports (BMRs) (see Section 4.3.2). EPA
estimated that approximately 80 percent of all pulp, paper and paperboard
mills were already utilizing alternative formulations at the time of
promulgation.
As described previously, PSES and PSNS for zinc were promulgated for
three of the four groundwood subcategories because groundwood mills have
historically used zinc hydrosulfite as a bleaching chemical and zinc was found
to pass through POTWs (see Section 6 of EPA Document 440/1-82/025 for further
explanation of this). However, zinc categorical standards and routine
compliance monitoring requirements are only applicable to groundwood mills
using zinc hydrosulfite as a bleaching agent and will allow PQTW authorities
to not require this monitoring to verify PSES and PSNS if a mill can certify
that zinc hydrosulfite is not being used. However, groundwood mills must
perform sampling and analysis for zinc as part of the BMR efforts.
2.4 POLLUTANTS EXCLUDED FROM REGULATION
EPA excluded from regulation all but three of the 126 toxic pollutants
authorized for regulatory consideration. Tables 2.3 through 2,5 present the
criteria for which each pollutant was excluded from regulation under PSES.
2.5 COMPLIANCES DATES
As stated in earlier sections, all mills included in the Pulp, Paper and
Paperboard and Builders Paper and Board Mills Point Source Categories must
achieve compliance with applicable PSES categorical standards by July 1, 1984.
As discussed previously, mills may not have to perform routine compliance
monitoring with the approval of the POTW authority if they certify that (a)
chlorophenolic - containing biocides are not used at the mill, and/or (b) zinc
hydrosulfite is not used to bleach mechanical pulps. One mechanism commonly
2-11
-------
* TABLE 2,3
CRITERIA FOR U.IHIHATIOH OF TOXIC POLLUTANTS
BASED OH SCREENING PROGRAM RESULTS
AM) TOXIC POLLUTANTS ELIflJHATED
Paragraph 8 (a) (ill)
"For i apecific pollutant, the pollutant ti oat
detectable "
aceaaphLheac
acrolcia
l,2,4-irlcJiloreb«azeae
hexjchlorobenien*
herac Worse thin*
2-chloroetbylvinyl ether (nimed)
1,3-dicblorobciUMic
3,3'-dlcblorobeiLZidin*
1 ,2-dichloroprop«n«
1, J-dipbenylhydrjiine
1,
2.
8.
9.
12,
16,
19.
26.
28.
32.
37.
40.
«.
46.
52.
57. 2-nitrophenol
63. K-nitroiodi-a-propylanine
(1,2-becuDthraccne)
73.
76. 3,4-beozefluoraatbene
75. bettolk)fluorantheoe
(11,12-bcaxo fluoranthene)
79. beczo[ghljperyleae
4-broa»pb«oylpbeoyi ether
•ethyl broaide (b
88.
89.
90,
91.
92,
93.
94.
95,
96.
97,
91,
99.
100.
101,
102.
103.
104.
IDS.
113
116.
129.
vinyl cblorld* (ciloroetiylena)
ildrin
dieldrin
cblorduie (technical airturr an
••tabolitcs)
4,*' -BUT
4, 4 '-DOT (p.p'-DDI)
4,4'-DDD (p.p'-TBl)
o-eadoiul£«a
p-eadotulfiB
•adostilfin
end r In
eodrin aldehyde
heptachlor
heptachlor epoiide
a-BHC
P-BHC
Y-BHC (Undajje)
6-BHC
tozapbeae
iibcatoi (fibrouv)
2,3»?,8-tetr«cbIorodib*axo-p-dio«ia (TCBD)
SO. fluoreoe
S3. icdeuol1,2,3-cdJpyreae
2-12
-------
TABLE 2.3 (Continued)
Paragraph I (») (ill)
"For « •yetilic pollutiot if preheat la jaounti
tea laall to he effectively reduced by techaologiti
knovn to th« Adainlitr*tor "
3. jcryloaitrile
5. beozidiae
16. I, l,2-tnchloroeth«n«
20. 2-cnloronaphchalene
25. 1,2-dlcblorobeazeae
27. 1,4-dicb.lorobenieae
30. 1,2-dichloroethyltae
33. 1,3-dicbloropropyleae
(1,3-dicnloroprop«ne)
34. 2,4-dLmethylpheool
35. 2,4-dinitrotoiuene
36. 2,6-diaitrotoluene
42. bi»(2-chloroiaopropyl) ether
43. . bii(2-Chleroethoxy) methane
45. nethyl chloride
S3.
54.
sa.
60.
62.
71.
114.
115.
117.
111.
12S.
126.
127.
hex a chl o rocy e lop *nc.ad i«na>
nitrobenzene
4-nitropbenol
4,6-dlnitro-o-creaol
N-nitrojodlphenylaoiine
dimethyl phthilate
aritcic
berylliua
aeleniun
thallium
8 («) (lit)
"For * •pecifle pollutant 1» detectable in tn«
effluent fro* only a loull auaber of lourcei
ud toe pollutant Is uniquely related to only tho»o
jourcea "
13. bi> C2-cbloroethyi) etber
29. 1,1-di.cnloroelhyleoe
82. dibenzofa.hlanthracene
• (1,2,5 ,6-dibenuntnracene)
2-13
-------
TABLE 2.4
TOXIC POLLUTANTS ELIMINATED F10M ASSESSMENT
BASED ON VERIFICATION PROGRAM RESULTS
DETECTED BELOW TREATABILITY LEVEL
6. carbon tetrachloride
(tetrschloroaethsae)
?. chlorobenrene
10. 1,2-dichloroetcane
13. 1,1-dichloroethane
IS. 1,1,2,2-tetrachloroethane1
22. psrachlorometa cresol*
39. fluoranthene
44. methylene chloride3
(dlchloromethane)
48. dichlorobroBOOethane
51. cblorodib ronooethane
54. iaophorone
2,4-dinit rophenol*
bis(2-ethylhexyl) phthalate3
di-n-octyl phthalate
chrysene4
acenaphthyLene
anthracene
phenanthrene5
PCB-1221 (Arochlor 1221]
PCB-1232 (Arochlor 1232)
PCB-1016 (Arochlor 1016)
chromium (total)
copper (total)
mercury (total)
59.
66.
69.
76.
77.
78.
81.
108.
109.
112.
119.
120.
123.
124. nickel (total)
1 Not detected during verification sampling; detected in final effluent(a)
during screening program belov treatability level.
2 Not detected in raw waste or final effluent samples during screening or
verification programs.
3 Laboratory contaminant.
4 Not detected during verification sampling; detected in raw waste •trean(s)
below treatability levels during screening prograa.
8 Not detected during verification sampling; co-elutes with anthracene using
screening procedures.
2-14
-------
TABLE 2.5
EXCLUSION OF TOXIC POLLUTANTS Of POTENTIAL CONCERN F10M
PRETREATHENT STANDARDS
Toxic Pollutant
4. benzene
11. 1,1,1-trichloroethaoe
23. chloroform
24. 2-chloropbenol
31. 2,4-dichlorophenol
3fl. ethylbeozene
47. bromoform
55. naphthalene
65. phenol
67. butyl benzyl phthalate
68. di-n-butyl phthalate
Reason for Exclusion
Below treatabillty in raw waste
at all but one mill.
Below treatability in raw waste
at all but one mill.
Average POTW removal ia 61 percent1
However, the only POTW sampled by
EPA that receives wastewater from
a aill where chlorine is used to
bleach pulp removed 97.8 percent
of the raw waste chloroform1.
Direct discharger removal averages
96.7 percent. Pass through is
unlikely.
Below treatability in raw waste
at all but one mill.
Below treatability in raw waste
at all but one mill.
Below treatability in raw waste
at all but one mill.
Average raw waste discharge is
below treatability
Below treatability in raw waste
at all but two mills ia two
different subcategories.
POTW removal is 83 percent1.
Direct discharger removal ranges
from 0 to 100 percent; average
removal is approximately 91
percent. Pass through is
unlikely.
POTW removal is 99 percent1.
through is unlikely.
Pass
Below treatability in raw waste
at all but three mills in three
different subcategories.
2-15
-------
TABIE 2.5 (cont.)
70, diethyl phthalate
84, pyrene
85. tetrachloroethylene
86. toluene
87. tricbloroethylene
106. PCB-1242
107. PCB-1254
110. PCB-1248
111. PCB-1260
121. cyanide
122. lead
POTV removal is 99 percent1. Pass
through is unlikely.
Average raw waste discharge is
below treatability.
Below treatability in raw waste
at all but two mills in two
different subcategories.
POTW removal is 91 percent1. Direct
discharger removal ranges from
39.1 to 100 percent. Average
removal is approximately 90
percent. Pass through is unlikely.
Below treatability in raw waste
at all but one mill.
POTW removal is comparable to
proposed HAT2. Pas* through is
unlikely.
Never used in the manufacture of
carbonless copy paper. Found at
low levels only periodically.
Never used in the manufacture of
carbonless copy paper. Found at
low levels only periodically.
Never used in the manufacture of
carbonless copy paper. Found at
low levels only periodically.
POW removal is 61 percent1. Direct
discharger removal ranges from
31.2 to 91.6 percent; average
removal is approximately 70
percent. Pass through is unlikely.
Below treatability in raw waste
at all but four mills in four
different subcategories.
'Based on information contained in Fate of PriorityPollutants inPublicly
Owned Treatment_Wgrjcs, US Environmental Protection Agency, September 1982.
2Based on a comparison of information contained in Fate of Priority Pollutants
in Publicly Owned Treatment Works, US Environmental Protection Agency, September
1982 (43) and information contained in the Development Document for Proposed
Effluent Ljjnjj.aj.j.ons Guidelines and Standards for Control of Polychlprinated
Bipbenyla in the Deinfc Subgategory ofthe Pulp, Paper and Paperboard Point
Source Category US Environmental Protection Agency, October 1982
2-16
-------
used in the NPDES program when such monitoring is not required is to ban the
use of chlorophenolic - containing biocides and/or zinc hydrosulfite for the
life of the permit.
2-17
-------
3. T1EATMENT TECHNOLOGIES
As stated In earlier sections of this manual, the recommended treatment
option for control of toxic pollutants regulated under PSES categorical
standards is chemical substitution. As explained In Section 2.2 of this
manual, PSES for PCP and TCP were calculated using effluent data collected at
mills which were known not to utilize chlorophenolic-containlng biocides and
alimicides. Although chemical substitution of sodium hydrosulfite for zinc
hydroaulfite is recommended for control of zinc at groundwood mills, PSES for
zinc were calculated using treatment performance data for lime precipitation.
A brief description of the treatment options mentioned above is presented
below.
3.1 LIME PRECIPITATION
The removal of zinc from waste waters by groundwood mills using zinc
hydrosulfite as a bleaching agent can be achieved through either 1) chemical
coagulation and clarification or by 2) changing to another chemical bleaching
agent such as sodium hydrosulfite. Several alternative chemical coagulation
and clarification technologies and their application to industrial and
municipal waste waters are discussed below.
The lime application and settling process treatment consists of adding a
milk of lime slurry to the waste water to precipitate the hydroxide of the
heavy metals and reduce dissolved sulfate concentrations through the formation
°f gypsum* Sufficient lime is needed to adjust the pH to between 10 and 11.5.
Also, settling may have to be aided by adding small quantities of organic
polyelectrolytes.
3.2 CHEMICAL SUBSTITUTION
It is often possible to use different process chemicals to accomplish the
same goal. For example, both zinc hydrosulfite and sodium hydrosulfite can be
used to bleach mechanical (groundwood) pulps. In recent years, at most
groundwood mills, a substitution to-the use of sodium hydrosulfite rather than
zinc hydrosulfite has been made. This was prompted, at least In part, by the
establishment of BPT effluent limitations controlling the discharge of zinc.
3-1
-------
R'ather than Invest in costly end-of-plpe treatment, mill management determined
that a less costly and equally effective control option would be chemical
substitution. This substitution of chemicals resulted in attainment of BPT
effluent limitations. EPA believes that this treatment option Is readily
transferable to indirect discharging mills and will not affect their economic
viability.
Other opportunities exist to minimize the discharge of toxic and noncon-
ventional pollutants through chemical substitution and are discussed belov.
Toxic Pollutants. Slimlcide and bloclde formulations containing penta-
chlorophenol are used at mills In the pulp, paper, and paperboard industry.
Initially, pentachlorophenol was used as a replacement for heavy metal salts,
particularly mercuric types. Trichlorophenols are also used because of their
availability as a by-product from the manufacture of certain herbicides.
Formulations containing the following three types of materials are also
currently being used:
1, Organo-bromides,
2. Organo-sulfur compounds, and
3. Carbamates.
Substitution to the use of alternate slimicide and biocide formulations
can lead to the virtual elimination of pentachlorophenol and trichlorophenol
from these sources.
Hpncpnventtonal Pollutants.* Ammonia is used as a cooking chemical at
mills in the semi-chemical, dissolving sulflte pulp, and both papergrade
sulfite subcategories. One method for reducing ammonia (N!I3_) discharges Is
the substitution of a different chemical, such as sodium hydroxide, for
ammonia in the cooking liquor. The equipment changes necessary to receive and
feed a 50 percent solution of NaOH are not likely to be significant.
After conversion to the use of sodium-based chemicals, spent liquor could
be incinerated, and sulfur dioxide, sodium sulfate, carbonate, or sulfide
could be recovered. These compounds could be eold for use at nearby kraft
3-2
-------
mills or for other Industrial uses; however, markets are not likely to be
readily available.
Reducing smelting furnaces that produce a high-sulfidity, kraft-llke
green liquor are now employed at sodium-based sulfite mills. EPA anticipates
that it would be necessary to replace the existing recovery boilers at
ammonia-based mills if chemical substitution to a sodium base were employed.
Additionally, it is likely that, because the heat value of sodium spent liquor
is lower than ammonia spent liquor, evaporator modification may be required if
excess capacity does not now exist.
No indirect discharging mills in the semi-chemical, dissolving sulfite
pulp, and papergrade sulfite subcategories currently use ammonia-based
chemicals.
3-3
-------
4. REQUIREMENTS OF THE GENERAL PRETREATMENT REGULATIONS
4.1 INTRODUCTION
This section provides a brief overview of the General Pretreatment
Regulations and identifies those provisions of the Regulations which have a
direct bearing on the application and enforcement of Categorical Pretreatment
Standards for the pulp, paper, and paperboard industry.
The General Pretreatment Regulations for Existing and New Sources {40 CFR
Part 403) establish the framework and responsibilities for implementation of
the National Pretreatment Program. The effect of 40 CPU Part 403 is essen-
tially three-fold. First. the General Pretreatment Regulations establish
general and specific discharge prohibitions as required by Sections 307(b) and
(c) of the Clean Water Act. The general and specific prohibitions are
described in Section 403.5 of the Pretreatment Regulations and apply to all
nondomestic sources introducing pollutants into a POTW whether or not the
source is subject to Categorical Pretreatment Standards.
Second, the General Pretreatment Regulations establish an administrative
mechanism to ensure that National Pretreatment Standards (Prohibited Discharge
Standards and Categorical Pretreatment Standards) are applied and enforced
upon industrial users. Approximately 1,500 POTWs are required to develop a
locally run pretreatment program to ensure that non-domestic users comply with
applicable pretreatment standards and requirements.
Third, and most Importantly for the purposes of this guidance manual, the
General Pretreatment Regulations contain provisions relating directly to the
implementation and enforcement of the Categorical Pretreatment Standards.
Reporting requirements, local limits, monitoring or sampling requirements, and
category determination provisions are discussed. POTW representatives should
refer to 40 CFR Part 403 for specific language and requirements where appro-
priate.
4-1
-------
4.2 CATEGORY DETERMINATION REQUEST
An existing Industrial user (IU) or Its FOTW nay request written certi-
fication from EPA or the delegated State specifying whether or not the
Industrial user falls within a particular industry category or subcatefory and
Is subject to a categorical pretreatment standard. Although the deadline for
submitting a category determination request by existing industrial users
subject to the pulp, paper, and paperboard industry categorical pretreatment
standards has passed, a new industrial user or its POT¥ may request this
certification for a category determination anytime prior to commencing its
discharge. The contents of a category determination request and procedures
for review are presented in Section 403.6(a) of the General Pretreatment
Regulations.
4.3 MONITORING AND REPORTING REQUIREMENTS OF THE GENERAL PRETREATMENT
REGULATIONS
In addition to the requirements contained in the Pulp, Paper, and Paper-
board Categorical Pretreatment Standards, industrial users subject to these
Standards must fulfill the reporting requirements contained in Section 403.12
of the General Pretreatment Regulations. These requirements Include the
submission of baseline monitoring reports, compliance schedules, compliance
reports (initial and periodic), notices of slug loading, and recordkeeping
requirements. Each of these reporting requirements is briefly summarized
below.
4.3.1 Baseline Monitoring Reports
All industrial users subject to Categorical Pretreatment Standards must
submit a baseline monitoring report (BMR) to the Control Authority. The
purpose of the BMR is to provide information to the Control Authority to
document the Industrial user's current compliance status with a Categorical
Pretreatment Standard. The Control Authority is defined as the POTW if it has
an approved pretreatment program, otherwise the BMR will be submitted to the
State (if the State has an approved State Pretreatment Program) or to the EPA
Region. Additional guidance on BMR reporting Is available from the IPA
Regional Pretreatment Coordinator.
4-2
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4.3.2 BMR Reporting of PCP/TCP/Zlnc
8MR sampling requirements clearly apply to PGP, TCP, and zinc. However,
since monitoring for toxic organics such as PCP and TCP can be expensive, BMR
sampling and analysis will only be required for those pollutants "which would
reasonably be expected to be present" in the industrial user's effluent
[Section 413.03(c)]. For routine compliance monitoring, not BMR monitoring,
the regulations allow for the control authority to certify that the regulated
pollutants are not used at the facility. Even if the industrial user expects
to use the certification procedure to demonstrate regular compliance with the
PCP, TCP or zinc limitation, the user must still sample and analyze for PCP, -
TCP, or zinc if the pollutant is "reasonably expected to be present" for the
purpose of the baseline monitoring report. If these organics are not used or
expected to be discharged, monitoring for PCP or TCP ,1s not required for the
BMR.
4.3.3 BMRDueDates
Section 4Q3.12(b) requires that BMRs be submitted to the Control Author-
ity within 180 days after the effective date of a Categorical Pretreatment
Standard or 180 days after the final administrative decision made upon a
category determination request [403.6(a)(4)J, whichever is later. The due
date for pulp, paper, and paperboard industry BMRs was July 2, 1983.
4.3.4 BMR Content
A BMR must contain the following information as required by Section
403.12(b).
1. Name and address of the facility, including names of operator(s) and
owner(s).
2. List of all environmental control permits held by or for the facil-
ity.
3. Brief description of the nature, average production rate and SIC code
for each of the operations) conducted, Including a schematic process
diagram which Indicates points of discharge from the regulated
processes to the POTW.
4. Flow measurement information for regulated process streams discharged
to the municipal system, flow measurements of other wastestreaos
4-3
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will be necessary if application of the combined wastestream formula
is necessary.
5. Identification of the pretreatment standards applicable to each
regulated process and results of measurements of pollutant concen-
trations and/or mass. All samples must be representative of daily
operations and results reported must include values for daily maximum
and average concentration (or mass, where required). Where the flow
of the regulated stream being sampled is less than or equal to
250,000 gallons per day, the industrial user must take three samples
within a two week period. Where the flow of the stream is greater
than 250,000 gallons per day, the Industrial user must take six sam-
ples within a two week period. If samples cannot be taken immediate-
ly downstream from the regulated process and other wastewaters are
mixed with the regulated process, the Industrial user should measure
flows and concentrations of the other wastestreams sufficient to
allow use of the combined wastestream formula.
6. Statement of certification concerning compliance or noncompliance
with the Pretreatment Standards.
7. If not in compliance, a compliance schedule must be submitted with
the BMR that describes the actions the user will take and a timetable
for completing those actions to achieve compliance with the standard.
This compliance schedule must contain specific increments of progress
in the form of dates for the commencement and completion of major
events, however, no increment of the schedule shall exceed 9 months.
Within 14 days of each completion date in the schedule, the indus-
trial user shall submit a progress report to the Control Authority
indicating whether or not it complied with the increment of progress
to be met on such date, and, if not, the date on which it expects to
comply with this increment of progress and the steps being taken to
return to the schedule.
4.3.5 Report on^Compliance
Within 90 days after the compliance date for the Pulp, Paper, and Paper-
board Pretreataent Standards or in the case of a New Source following com-
mencement of the introduction of wastewater into the POTW, any industrial user
subject to the Standards must submit to the Control Authority a "report on
compliance" that states whether or not applicable pretreatment standards are
being met on a consistent basis. The report must indicate the nature and
concentration of all regulated pollutants in the facility's regulated process
wastestreams; the average and maximum daily flows of the regulated streams;
and a statement of whether compliance is consistently being achieved, and if
not, what additional operation and maintenance and/or pretreatment is neces-
sary to achieve compliance. See 40 CFR 403.l2(d).
4-4
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4.3.6 Periodic Reports on Continued Compliance
Unless required more frequently by the Control Authority, all Industrial
users subject to the Pulp, Paper, and Paperboard Categorical Pretreatment
Standards must submit a biannual "periodic compliance report" during the
months of June and December. The report shall indicate the precise nature and
concentrations of the regulated pollutants in its discharge to the POTW, the
average and maximum daily flow rates of the facility, the methods used by the
indirect discharger' to sample and analyze the data, and a certification that
these methods conformed to those methods outlined in the regulations. See 40
CFR 403.12(e).
4.3.7 Notice of Slug Loading
Section 403.12(f) requires industrial users to notify the POTW imme-
diately of any slug loading of any pollutant, including oxygen demanding
pollutants (BOD, etc.) released to the POTW system at a flow rate and/or
pollutant concentration which will cause interference with the POTW.
4.3.8 Monitoring and Analysisto Demonstrate Continued Compliance
Section 403.12(g) states that the frequency of monitoring to demonstrate
continued compliance shall be prescribed in the applicable Pretreatment Stan-
dard. The Pulp, Paper, and Paperboard Pretreatment Standards do not establish
any monitoring frequency. Therefore, the appropriate Control Authority muat
establish the monitoring frequency to adequately demonstrate that Indirect
dischargers subject to these pretreatment standards are in compliance with the
applicable standards. Unless otherwise noted in the appropriate paragraph of
Section 403.12, the monitoring frequency established by the Control Authority
shall be used in the baseline monitoring report (403.12(b)(5)), the report on
compliance with categorical pretreatment standard deadline (403.12(d)), and
the periodic reports on continued compliance (403.12(e)).
Sampling and analysis shall be in. accordance with the procedures estab-
lished in 40 CFR Part 136 and any amendments to it or shall be approved by
EPA. When Part 136 techniques are not available or are inappropriate for any
pollutant, then sampling and analysis shall be conducted in accordance with
procedures established by the POTW or using any validated procedure* However,
4-5
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all procedures for sampling and analysis not included in Part 136 must be
approved by EPA.
4,3.9 Signatory Requirements for IndustrialUser Reports
All reports submitted by industrial users (BMR, Initial Report on
Compliance, and Periodic Reports, etc.) must be signed by an authorized
representative in accordance with Section 403.12(k),
4.3.10 Recordkeeping Requirements
Any industrial user subject to the reporting requirements of the General
Pretreatment Regulations shall maintain records of all information resulting
from any monitoring activities required by 403.12 for a minimum of three years
(403.12(n)]. These records shall be available for inspection and copying by
the Control Authority.
4.4 THE COMBINED WASTESTREAM FORMULA
One provision of the General Pretreatment Regulations that will often be
necessary for POTWs and industries to properly monitor and report on compli-
ance with Categorical Pretreatment Standards is the Combined Wastestream
Formula (CWF) [40 CFR 403.6(e}]. The CW is a mechanism for calculating
appropriate limitations specified in applicable regulations to a wastewater in
which process wastestreams are mixed with regulated, unregulated or dilution
streams, thereby resulting in a mixed effluent. The CWF is applied to the
mixed effluent to account for the presence of the additional wastestreams.
The following definitions and conditions are important to the proper use
of the CWF.
Definitions
* Regulated Process Wastestream - an industrial process wastestream
regulated by National Categorical Pretreatment Standards.
* Unregulated Process Hastestream - an industrial process wastestream
that ie not regulated by a categorical standard.
Notes Definitions apply to individual pollutants. A wastestream from a
process may be "regulated" for one pollutant and "unregulated" for
ans\ t- K ja *•
another.
4-6
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* Dilute Wastestream - Boiler blowdown, sanitary wastewater, noncontact
cooling water or blowdown, and Paragraph 8 excluded wastestreams
containing none of the regulated pollutant or only trace amounts of
it.
• Concentration-basedLimit - a limit based on the relative strength of
a pollutant in a wastestreao, usually expressed in mg/1 (ib/gal).
* Mass—based Limit — a limitation based on the actual quantity of a
pollutant in a wastestream, usually expressed in kg/some unit of
production for a given operation such as kg of pollutant per kkg of
product.
CWF Conditions
To ensure proper application of the CWF, the following conditions must be
met by a municipality and its Industries [40 CFR 403.6(e)]:
• Alternative discharge limits that are calculated in place of a
Categorical Pretreattnent Standard must be enforceable as Categorical
Standards.
• Calculation of alternative limits must be performed by the Control
Authority (POTW) or by the industrial user with written permission
from the POTW.
* Alternative limits must be established for all regulated pollutants in
each of the regulated processes.
* The Control Authority and/or the industrial user may use mass-based
limitations in place of the concentration-based limitations, when they
are provided for by given Categorical Pretreatraent Standards such as
the pulp, paper, and paperboard standards, as long as a prior agree-
ment exists between the regulated industrial user and the municipality
that is receiving these wastes.
• Both dally maximum and long-term average (usually monthly) alternative
limits must be calculated for each regulated pollutant.
* If process changes at an industry warrant, the Control Authority may
recalculate the alternative limits at its discretion or at the request
of the industrial user. The new alternative limits must be calculated
and become effective within 30 days of the process change.
» The Control Authority may impose stricter alternative limits, but may
not impose alternative limits that are less stringent than the
calculated limits.
1 A calculated alternative limit cannot be used if it is below the
analytical detection limit for that pollutant. If a calculated limit
is below the detection limit, the IU must either: 1) not combine the
4-7
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dilute streams before they reach the combined treatment facility, or
2) segregate all wastestreams entirely.
* The categorical standards of the regulated wastestreams which are
applied to the CWF must be consistent in terms of the number of
samples the standard is based on.
Monitoring Requirements For Industrial Users Using the CWF
Self-monitoring requirements by an industrial user are necessary to
ensure compliance with the alternative .categorical limit. Because the Pulp,
Paper, and Paperboard Pretreatment Standards do not include self-monitoring
requirements, the Control Authority will establish minimum self-monitoring
requirements.
Application of the CWF
The actual combined wastestream formulas are presented in Table 4.1.
Table 4.2 presents examples of how the CWF is applied to specific pulp, paper,
and paperboard Industry situations.
4.5 REMOVAL CREDITS
A removal credit allows a POTW to provide categorical industrial users of
its system with a credit (in the form of adjusted categorical pretreatment
standards) for .removal of pollutants by the POTW. Industrial users receiving
such a credit are allowed to discharge to the POTW greater quantities of regu-
lated pollutants than otherwise permitted by applicable categorical standards.
Whether or not to seek authority to grant removal credits is completely at the
discretion of the POTW. Section 403.7 of the General Pretreatment Regulations
establishes the conditions under which a POTW would obtain approval to grant
removal credits and specifies the means by which these removal credits are to
be determined.
In 1977, Congress amended section 307(b) of the Clean Water Act to
provide for removal credits. EPA originally implemented that provision and
established the conditions under which POTWs could obtain authorization to
grant removal credits in the June 26, 1978 General Pretreatment Regulations.
On January 28, 1981, the removal credits provision, as well as many other
portions of the pretreatment regulations, were amended. On August 3, 1984
4-8
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TABLE 4.1
COMBINED WASTEST1EAM FORMULAS
Alternative Concentration Limit Formula:
,,
c „ i <«i 11
i n
F
i
C ~ alternative concentration limit for the pollutant
C - Categorical Pretreatment Standard concentration limit for the pollutant
in regulated stream 1
F - average daily flow (at least 30 day average) of regulated stream 1
F - average daily flow (at least 30 day average) of dilute wastestream(s)
d
F - average daily flow (at least 30 day average) through the combined
treatment facility (including regulated, unregulated and dilute
wastestreams)
N - total number of regulated streams
Alternate Mass Limit Formula
E
1=1
M - alternative mass limit for the pollutant
M - Categorical Pretreatment Standard mass limit for the pollutant in
regulated stream i
F - average dally flow (at least 30 day average) of regulated stream i
F - average daily flow (at least 30 day average) of dilute waatestream(s)
a
F ~ average dally flow (at least 30 day average) through the combined
treatment facility (including regulated, unregulated and dilute
wastestreams)
N - total number of regulated streams.
4-9
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TABLE 4.2
COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATIONS
The following examples provide calculations for determining alternate discharge limits for
pentachlorophenol (PCP) using the combined wastestreaa formula. Trichlorophenol- and zinc limits
would also be calculated in the same manner but examples of these limits will not be repeated here.
The limits for PCP are based on the compliance date of July 1, 1984, The following calculations
assume combinations of various regulated and unregulated wastestreams with the following charac-
teristics:
PSES
Daily Maximum PCP Limit
Subcategory
or Wastestream
Groundwood~Fine Papers
Deink-Fine Papers
Paperboard from Waste-
paper
Builders' Paper and
Roofing Felt
Nonintegrated-Fine Papers
(Wood Fiber Furnish)
Groundwood-Chemi-
Mechanical
Sanitary Waste
Boiler Slowdown
Wastestream Flow Q
Type (mgd)
Regulated 11.0
Regulated 3.6
Regulated 0.9
Regulated 2.0
Regulated 2,6
Unregulated 2.0
Dilution 0.05
Dilution 1.0
Concencration-based Production-based
(ing/1) kg/kkg or
lb/1000 Ibs
(0. 011X21. 9)/Y*
(0.032X24. 4)/Y*
(0. 032X7, 2)/Y*
(0. 032X14. 4)/Y*
(0,032)(15,2)/Y*
N/A
N/A
N/A
0.0010
0.0033
0. 00096
0.0019
0.0020
N/A
N/A
N/A
Production
Tons of
Product
Per Day
650.0
300.0
500.0
100.0
200.00
150.0
N/A
N/A
*Y =» mill wastewater discharged in kgal per ton of product
4-10
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TABLE 4.2 (Continued)
COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATIONS
EXAMPLE A
Alternative discharge limit for a groundwood-flne papers facility using chlorophenollc-
containing biocides which also discharges sanitary waste and boiler blowdown. The PCP concentra-
tion-based limit oust be calculated as follows:
PCP limit in mg/1 = (0.011)(21.9)/Y
Y • mill wastewater discharged in kgal per ton
of product
= 11.0 ngd = 16 9 kgal
650.0 tona of product per day * ton
PCP limit in mg/1 = (0.011X21.9)/(16.9) = 0.014 mg/1
Groundwood-Fine Papers
Q = n
PCP = 0.014 mg/1
Sanitary
Waste
Q =0.05 mgd
PCP = N/A
Boiler Blowdown
Q = 1.0 mgd
PCP = N/A
= 0*014 mg/1x 11.0mgd
cwf 11.0 mgd
PCP
PCP . = 0.014 x 0.913
cwf
PCP , = 0.013 mg/1
cwf
(11.0 mgd + 0.05 mgd + 1.0 mgd) - (0.05 mgd + 1.0 mgd)
11.0 mgd * 0.05 mgd + 1.0 mgd
4-11
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TABLE 4,2 (Continued)
COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATIONS
EXAMPLE B
Alternative discharge limit for a secondary fiber "miscellaneous" facility using ehloro~
phenolic-containing biocides and producing fine papers from deinked pulp and from purchased pulp.
The facility also discharges sanitary wastes. The PGP limits are calculated using the limits for
the deink-fine papers and the nonintegrated-fine papers subcategories as follows:
deink-fine papers
PCP limit in mg/1 = (0.032)(24.4)/Y
Y = mill wastewater discharged in kgal per ton of product
Y „ 3.6 mgd m 3600 kgal
300.0 tons product per day 300 tons
Y = 12.0
PCP limit in mg/1 ~ (0.032)(24.4)/12.0
= 0.065 mg/1
n on in t eg r a t ed- f i n e p_aj>e r_s
PCP limit in mg/1 - (0.032)(15.2)/Y
y = 2.6 mgd
200.0 tons product per day
Y = 13.0
PCP limit in mg/1 = (0.032)(15.2)/(13.0)
= 0.037 mg/1
2600 kgal
200 tons
Q - 3.
PCP - 0.
Deink-fine Papers
6 mgd
065 mg/1
Q- - 2.6
PCP =0.0
Nonintegrated-
fine Papers
mgd
37 mg/1
Q « 0.05
PCP - N/A
Sanitary
Waste
mgd
PCP
(0.065 mg/1 x 3.6 mgd) + (0.037 mg/1 x 2.6 mgd) 3.6 mgd * 2.6 mgd + 0.05 mgd - 0.05 mgd)
PCP
cwf 3.6 mgd + 2.6 mgd
0.23 + 0.096
3.6 mgd +2.6 mgd + 0.05 mgd
cwf
6.2
x (0.99)
PCP , - 0.053 x 0.99
cwf
PCP = 0.052 mg/1
cwf
4-12
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TABLE 4.2 (Continued)
COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATIONS
EXAMPLE C
Alternative discharge limit for a secondary fibers "miscellaneous" facility using
chlorophenolic-eontainlng bioeides and producing builders' paper and roofing felt and paperboard
from wastepaper. The facility also discharges sanitary wastes and boiler blowdown. The PCP limit
is calculated as follows.
builders' paper and roofing felt
PCP limit in mg/1 - (0.032)(14.4)/Y
Y » mill wastewater discharged in kgal per ton of product
Y . 2.0 "fid ' . 20i0 isal
100. 0 tons product per day * tons
PCP limit In mg/1 - (0.032)<14.4)/20.Q
- 0.023 mg/1
paperboard from waatepapera
PCP limit In mg/1 - (0.032)(7.2)/Y
0.9 mgd
500.0 tons product per day
1.8 kgal/ton
PCP Unit in mg/1 = (0.032)(7.2)/(1.8)
- 0.13 mg/1
Y -
Y =
Builders' Paper
and Roofing Felt
3. 6 mgd
3.023 mg/1
Paperboard from
Wastepaper
Q - 0.9 mgd
PCP - 0.13 mg/1
Sanitary
Waste
Q = 0.05 ragd
PCP - N/A
Boiler
Blowdown
Q = 1.0 mgd
PCP - N/A
PCP
cwf
PCP
cwf
(0.023 mg/1 x 0.6 mgd) + (0.13 mg/1 x 0.9 mgd)
0.6 mgd +0.9 mgd x
(0.6 mgd + 0.9 mgd + 0.05 mgd +1.0 mgd - 0.05 mgd. - 1.0 mgd)
0.6 mgd +0,9 mgd + 0.05 mgd +1.0 mgd
0.014 + 0.12 1.5
— x
1.5
2.55
PCP , - 0.089 x 0.59
cwf
P€Pcwf " °"°53
4-13
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TABLE 4.2 (Continued)
COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATIONS
EXAMPLE D
Alternative discharge limit for an integrated miscellaneous facility using chlorophenolic-
containing biocides and producing groundwood-flne papers and groundwood-cheni-mechanlcal pulp. The
facility also discharges a boiler blowdown. The limit is calculated as follows (note that no PSES
limitations for PCP are promulgated for the groundwood-chemi-mechanical subcategory):
PGP limit for groundwood-fine papers subcategory from Table 4.2 (Example A) = 0.014 mg/1
Groundwood-Fine Papers
Q = 11.0 mgd
-PCP = 0.014 mg/1
Groundwood-Chetni~
Mechanical
Q = 20.0 mgd
PCP = *
Boiler Blowdown
Q = 1.0 mgd
PCP = N/A
PCP
cwf
0.014 mg/l_x U_..0_mgd
11.0 mgd
T
(11.0 mgd + 20.0 mgd__+J_.0 mgd - 1J3 mgd)
(11.0 mgd + 20.0 mgd + 1.0 mgd)
PCP
cwf
PCP = 0.014 x 0.969
• cwf
PCP , = 0.014 fflg/1
cwf
Note: *The groundwood-chemi-mechanical wastestream is unregulated but it is not considered the
same as a dilute wastestream (e.g., boiler blowdown). Only dilute wastestreams are
subtracted from total flow in the numerator of the second term in the combined wastestream
formula. If the control authority determines that chlorophenolic containing biocides are
used in the groundwood-chemi-oiechanical portion of the operations, a PCP allowance may be
included based upon actual measurements. However, if It is determined that these types of
biocides are not used, then this stream should be treated as a dilution stream.
4-14
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TABLE 4.2 (Continued)
COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATIONS
EXAMPLE 1
In some cases, permit writers may wish to utilize mass limitations. This example shows the
calculation of an alternative limit for a facility which uses ehlorophenolle-cantainlng compounds
and produces nonintegrated-fine papers and deirik-fine papers. Sanitary wastes and boiler.blowdown
are also discharged. The mass limits are calculated as follows:
non i n t eg rated "fine paper
PGP limit » 0.0020 lbs/1000 Ibs product
long-term average m 200 tons product _ 400,000
day
product
production
PCP limit
PCP limit
0.0020 Ibs
1000 Ibs product x
0.80 Ibs/day
day
400fOOP Ibs product
day
detnk-ftne papers
PCP limit * 0.0033 lbs/1000 Ibs product
long-term average __ 300 tons product 600,000 lbs product
production day day
0.0033 Ibs
ru
PC
Q = 2
PCP = 0
t illUIL IQOO lbs product X
P limit = 1.98 Ibs/day
Nonintegrated-
flne Paper
.6 mgd
.8 lbs
day
Deink-f ine
Paper
Q = 3.6 mgd
PCP =1.98 lbs
day
day
Q = 0.05
PCP = N/A
Sanitary
Waste
ngd
Q = 1
PCP = N
Boiler
Blowdown
,0 mgd
/A
PCP
cwf
PCP
cwf
°-80 IM + l
day
2.8 Ibs/day
day
V
2.6 mgd + 3.6 mgd + 0.05 mgd + 1.0 ngd - 0.05 mgd
2.6 mgd + 3.6 mgd
- .1
4-15
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(49 Fed. Reg. 31212) the removal credits provision was again amended. Under
the current provision, any POTW seeking removal credit authority is required
to demonstrate its removal performance by sampling its influent and effluent
and calculating its removal rates based on this data. Removal capability of
each POTW, therefore, is to be determined on a case-by-case basis. In
addition to the sampling requirements, the provision specified the other
prerequisites for obtaining removal credit authority. Only the Approval
Authority (either EPA or the State) can grant removal credit authority to a
POTW.
4.6 FUNDAMENTALLY DIFFERENT FACTORS VARIANCE
A request for a fundamentally different factors (FDF) variance Is a
mechanism by which a Categorical Pretreatment Standard may be adjusted, making
it more or less stringent, on a case-by-case basis. If an Indirect dis-
charger, a POTW, or any interested person believes that the factors relating
to a specific indirect discharger are fundamentally different from those
factors considered during development of the relevant categorical pretreatment
standard and that the existence of those factors justifies a different
discharge limit from that specified in the Categorical Standard, then they may
submit a request to EPA for such a variance (See 40 CFR 403.13).
This section was the subject of a recent court decision (U.S. Court of
Appeals for the Third Circuit) in September of 1983. The Court held that the
EPA lacks authority to issue variances to indirect dischargers for toxic pol-
lutants. As a result of the Court's decision, FDF variances can only be
granted for non-toxic pollutants. Since the pulp, paper, and paperboard
categorical standards contain limits only for toxics, no variance is available
for this industry.
4.7 LOCAL LIMITS
Local limits are numerical pollutant concentration or mass-based values
that are developed by a POTW for controlling the discharge of conventional,
non-conventional or toxic pollutants from indirect sources. They differ from
National Categorical Pretreatment Standards in that Categorical Pretreatment
Standards are developed by EPA and are based upon the demonstrated performance
4-16
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of available pollutant control technologies (for specific categorical indus-
tries). These national technology-based categorical standards do not consider
local environmental criteria or conditions, and are only developed to assure
that each industry within a specified category meets a minimum discharge
standard which Is consistent across the United States for all POTWs. Local
Halts, on the other hand, are developed to address specific localized impacts
on POTWs and their receiving waters. Local limitations are typically designed
to protect the POTW fromt
* The introduction of pollutants Into the PQTW which could interfere
with its operation
* Pass-through of inadequately treated pollutants which could violate a
POTW's NPDES permit or applicable water quality standards
* The contamination of a POTW's sludge which would limit sludge uses or
disposal practices*
Local limits, as the name implies, take into consideration the factors
that are unique to a specific PQTW, whereas categorical pretreatment standards
are developed only for a general class of industrial dischargers. Local
limits are required under 40 CFR 403,5 and must be developed when it is
determined that Categorical Pretreatment Standards are not sufficient to
enable the POTW to meet the above three Pretreatment Program objectives.
To assist municipalities in developing defensible and technically sound
numerical effluent limitations, EPA has prepared some general guidelines on
limit development in its document "Guidance Manual for POTW Pretreatment
Program Development." Appendix L of this document lists the general method-
ology, required formulas and typical environmental criteria used to develop
local limits. This manual is available from EPA Regional offices and NPDES
States and should be carefully followed when developing local limits. Al-
though a detailed discussion of local limit development is beyond the scope of
this document, the general methodology includes the following four steps:
Step 1 - Determine the maximum headworks loading (for each specific
pollutant) that will assure that the three fundamental objec-
tives of the pretreatment program are met.
4-17
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Step 2 - Calculate the allowable loading to the POTW by subtracting the
uncontrollable portion of pollutant discharge to the POTW (from
domestic, commercial and infiltration/Inflow sources) from the
total headwork loading value.
Step 3 - Distribute the controllable loading to industrial users through
an allocation process.
Step 4 - Derive specific local limits from the allocation results.
The above four step process must be performed for each pollutant which
the POTW determines may need a specific local limitation. As a general rule,
the limit setting analysis should be performed for all pollutants which are
discharged to the POTW in significant quantities. The POTW should identify
pollutants of concern through an evaluation of the POTW's industrial waste
survey, A procedure for evaluating industrial waste survey results is
included in the EPA guidance manual mentioned earlier.
To assist POTWs with the development of local limits EPA has developed a
computer program that incorporates the general methodology required to develop
local Units and alleviates a substantial amount of the tedious calculations
required to develop these limits. This computer program has the following
capabilities to aid the POTW in limit development:
• Performs the four-step limit setting analysis on microcomputer or
mainframe
* Screens input data provided by the POTW
• Supplements POTW data with "built-in" files containing data on
Industrial/Municipal wastewater characteristics, POTW removal rates,
and POTW inhibition values
* Allocates controllable pollutant loads using several different
methodologies
9 Compares calculated local limits to EPA Categorical Standards.
POTWs may obtain information on this computer program by contacting any of the
ten EPA Regional offices. Instructions will be provided on how to use the
computer program as well as how to access a computer system which supports it.
4-18
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REFERENCES
PULP. PAPER. MD PAPERBOARD REGULATIONS
Proposed Regulations
Final Regulations Promulgated
•Federal Register Notice
1/06/81
11/18/82
46 FR 1430
47 FR 52006
General Pretreataent Regulations
40 CFR Part 403
01/28/81 46 FR 9404
Documents
October 1983
October 1983
Document No.
EPA
NTIS
Guidance Manual for POTW
Pretrestment Program
Development
Procedures Manual for
Reviewing a POTW
Pretreatment Program
Submission
Final Development Document October 1982 EPA 440/1-82/025 PB 83-163949
Copies of the technical and economic documents may be obtained from the
National Technical Information Services, Springfield, VA. 22161
(703/487-4650). Pretreament Program Manuals may be obtained from U.S. EPA,
Permits Division (EN-336), Washington, B.C. 20460
•U.S. GOVERNMENT PfUHTING OPPICI 1984: 421-S45/US39
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