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epa wants more TCF info (cluster rule)
pls read the sentence i've copied in CAPS below, it's a p'graph from
yesterday's FR notice announcing epa's likely intentios (big suprise, yeah
right) to adopt either no advanced delignification + 100% ClO2
substitution, or advanced delignification + same as BAT for kraft pulp
mills (personally, i don't see how the 1st option possibly can be BAT when
~200 mills worldwide have abandoned the standard delig. for advanced delig,
but anyhoo..)
**if you have any data, or know of a good contact regarding european tcf
mills (incl. markets for tcf paper as well as pollution data) _please_ use
the info below to get their comments in to epa by 14 august. **
[snip]
This notice presents EPA's preliminary analysis of data pertaining to
Option A and compares it to Option B. In addition to obtaining and
analyzing data pertaining to Options A and B, the Agency also has
endeavored to obtain and analyze additional data for TCF process
technologies as a possible BAT technology. TCF technologies typically
incorporate OD while relying on peroxide and/or ozone, rather than
chlorine-containing compounds, to accomplish pulp bleaching and
brightening. Only one U.S. bleached papergrade kraft mill employs a TCF
process, and it produces a market pulp of somewhat less than full market
pulp brightness. Since proposal of this rule, the U.S. bleached papergrade
kraft TCF mill has achieved higher brightness targets, but still less than
full market brightness pulp of approximately 90 ISO. EPA obtained bleach
plant performance data from this mill, but because the mill discharges to
territorial seas under Section 301(m) of the Clean Water Act and thus does
not employ secondary treatment, end-of- pipe data reflecting the
performance of biological treatment were not available. European TCF mills
have achieved at or near full market brightness pulps for limited periods.
HOWEVER, EPA CONSISTENTLYREQUESTED BUT OBTAINED ONLY LIMITED PROCESS AND
POLLUTANT REMOVAL PERFORMANCE DATA FOR TCF MILLS IN EUROPE. The limited
range of papergrade TCF products currently produced and sold in the U.S.
market indicates that TCF technology is not yet available to make the full
range of products produced by ECF or similar chlorine-based processes.
Nonetheless, EPA continues to strongly encourage further development and
implementation of TCF technologies and products. It is also probable that
all TCF mills would qualify for the advanced technology incentives program
described below; this should provide an opportunity to stimulate
production and U.S. market share for TCF products.
[snip]
[Federal Register: July 15, 1996 (Vol.61, Number 136)] [Proposed Rules]
[Page 36835-36858]
40 CFR Parts 63 and 430 [FRL-5535-5] RIN 2060-AD03 and
2040-AB53
Effluent Limitations Guidelines, Pretreatment Standards, and New Source
Performance Standards: Pulp, Paper, and Paperboard Category; National
Emission Standards for Hazardous Air Pollutants for Source Category: Pulp
and Paper Production; Availability
AGENCY: Environmental Protection Agency (EPA). ACTION: Notice of
availability.
-----------------------------------------------------------------------
SUMMARY: On December 17, 1993, EPA proposed standards to reduce the
discharge of water pollutants and emissions of hazardous air pollutants
from the pulp, paper, and paperboard industry (58 FR 66078). This document
describes the Agency's goals for environmental improvement in this
industry, announces a framework for the final wastewater standards, and
presents the preliminary results of detailed analyses for a portion of this
industry.
DATES: Comments on this notice are solicited and will be accepted until
August 14, 1996. Comments are to be submitted in triplicate, and also in
electronic format (diskettes) if possible.
ADDRESSES: Comments are to be submitted to Mr. David Hoadley at the
following address: Engineering and Analysis Division (4303), EPA, 401 M
Street, SW., Washington, DC 20460. The framework and preliminary results
of detailed analyses being announced today are based on data and
information in the EPA Water Docket at EPA Headquarters at Waterside Mall,
room M2616, 401 M Street, SW, Washington, DC 20460, telephone (202)
260-3027. The Docket staff requests that interested parties call for an
appointment before visiting the Docket. A reasonable fee may be charged for
copying.
FOR FURTHER INFORMATION CONTACT: For questions regarding wastewater
standards, contact Mr. Donald Anderson at the following address:
Engineering and Analysis Division (4303), EPA, 401 M Street, SW.,
Washington, DC 20460, telephone number (202) 260-7189, or Mr. Ronald Jordan
also at this address, telephone number (202) 260-7115. For questions
regarding air emissions standards, contact Ms. Penny Lassiter, Emissions
Standards Division (MD-13), U.S. Environmental Protection Agency, Research
Triangle Park, NC 27711, telephone number (919) 541-5396.
Contents of This Notice
I. Summary of Notices for this Regulation
II. EPA's Long-Term Environmental Goals
III. Anticipated Schedule for Issuing Final Wastewater Standards
A. Schedule for Proposed Bleached Papergrade Kraft and Soda and
Proposed Papergrade Sulfite Subcategories
B. Scheduled for Proposed Dissolving Kraft and Dissolving Sulfite
Subcategories
C. Schedule for the Remaining Proposed Subcategories
IV. Post-Proposal Data Gathering
V. Regulatory Framework and Preliminary Results
A. Proposed Bleached Papergrade Kraft and Soda Subcategory
1. Preliminary Conclusion Regarding Technology Basis for BAT
2. Incentives for Further Environmental Improvements
3. Technology Options for BAT
4. Framework for PSES
5. Pollutant Parameters
6. Best Management Practices
7. Costs for Options A and B
8. Effluent Reduction Benefits
9. Revised Effluent Limitations
a. Changes to Statistical Methodology
b. Revised Effluent Limitations Being Considered
10. Conventional Pollutant Limitations (BPT and BCT)
11. Technology Options for NSPS
12. Revised Economic Impact Results
a. Revisions to the Economic Analysis
b. Economic Impacts of BAT Options A and
c. Cost-Effectiveness
B. Proposed Papergrade Sulfite Subcategory
1. Preliminary Conclusions Regarding Technology Basis for BAT
2. Technology Options for BAT
3. Costs
4. Effluent Reduction Benefits
5. Revised Effluent Limitations for BAT and PSES
6. Conventional Pollutant Limitations
7. Technology Options and Revised Effluent Limitations for NSPS
8. Economic Impacts
a. Costs and Impacts
b. Cost-Effectiveness
VI. Environmental Assessment
VII. Best Management Practices
VIII. Pretreatment Standards
IX. Implementation Issues
A. Permit Limits for Multiple Subcategory Mills
B. New Sources
C. Monitoring
D. BMPs as NPDES Permit Special Conditions
E. Relationship Between the Cluster Rules and Project XL
F. Summary of Changes to Methods for Analysis of Pulp and Paper
Industry Wastewaters
1. Method 1624, Volatiles by Purge-and-Trap and Isotope Dilution GC/MS
2. Method 1650, AOX by Adsorption and Coulometric
3. Method 1653, Chlorophenolics by In-Situ Derivatization and Isotope
Dilution GC/MS
4. Method NCASI Technical Bulletin No. 253, Color
G. Regulatory Flexibility Analysis
X. Incentives for Further Environmental Improvements
A. Advanced Technology Tiers
1. Definition of Incentives-Related BAT Limitations or NSPS by Tier
a. Tier I BAT Limitations
b. Tier II BAT Limitations and NSPS
c. Tier III BAT Limitations and NSPS
2. Basis for Incentives-Related BAT Limitations and NSPS
3. Legal Authority to Establish Incentives-Related BAT Limitations and NSPS
B. Incentives Available Prior to Achievement of Incentives-Related BAT
1. Extended Compliance Schedules
C. Incentives Available After Achievement of Advanced Technology BAT
Limitations and NSPS
1. Greater certainty regarding permit limits and requirements
2. Reduced effluent monitoring
3.Reduced penalties
4. Reduced inspections
5. Public recognition programs
6. Fast-track permit modification
D. Solicitations of Comments on Incentives Program
E. Alternative Incentives Programs and Provisions Suggested by Stakeholders
Tony Tweedale || "I'm not going to get involved in any
Bx 7941 || of that peer-reviewed mumbo-jumbo."
Missoula, Montana 59807 || -Rep. John Doo<-->little (R-CA)
406-542-1709, fax 728-0867 ||
cmcr@ism.net || " 'Are the people being protected?' is too
(Cold Mountain, Cold Rivers || narrow a question."
@ Internet Services of MT) || -API lobbyists meeting, 12 Dec. '96
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