Issued 2012 Chloroform 

(Last Updated March 2012) p. 1

ncasi

Pulp and Paper Mills

PART II. CHEMICAL-SPECIFIC INFORMATION FOR CHLOROFORM 

SECTION 1. TOXIC CHEMICAL IDENTITY 

1.1 CAS Number - 67-66-3

1.2 Toxic Chemical or Chemical Category Name - Chloroform

SECTION 3. ACTIVITIES AND USES OF THE TOXIC CHEMICAL AT THE 

FACILITY 

3.1 Manufacture the toxic chemical:

 Chloroform is produced as a byproduct in the C, E and H stages of pulp bleaching and 

during pulping, chemical recovery and chlorination of water. 

Estimates for virgin pulp bleach plant chloroform emissions based on NCASI laboratory 

studies and field data are presented in Table 1 and Table 2 (NCASI 1988; NCASI file 

information). Table 1 gives the chloroform emissions from bleach plant vents and 

chloroform released to bleach plant sewers for bleaching sequences that include the use of 

hypochlorite. Table 2 provides estimates for total chloroform formed and released in the 

bleach plant for essentially hypochlorite-free bleaching sequences. From Technical 

Bulletin No. 558 (NCASI 1988) and other data in NCASI files (NCASI file information), 

of the total chloroform formed in the bleach plant an average of 52 percent (range 6 to 90 

percent) was found to be released through the bleach plant vents, with the remaining 48 

percent (range 6 to 94 percent) discharged with the bleach plant effluent to the waste 

treatment facility. 

Table 3 contains NCASI test data (NCASI 1993; NCASI file information) on chloroform 

formation during hypochlorite bleaching of repulped and deinked pulps. Although the 

data in Table 3 would suggest that as compared to bleaching of virgin fibers less 

chloroform is produced during hypochlorite bleaching of recovered fibers, the virgin fiber 

chloroform generation data in Table 1 include nearly 0.3 lb/ODTP of chloroform formed 

in the chlorination stage of virgin fiber bleaching. Excluding the impact of the 

chlorination stage, the chloroform generation estimates for recovered fibers in Table 3

seem to be consistent with the chloroform generation estimates for virgin fibers in Table 

1. Thus, if no mill specific information is available, one may estimate the amount of 

chloroform generated in recovered fiber bleaching by using the estimates for virgin fibers 

in Table 1, with a decrease of 0.3 lb CHCl3/ODTP in the absence of a chlorination stage 

in the recovered fiber bleaching sequence. 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 2

ncasi

Pulp and Paper Mills

TABLE 1 BLEACH PLANT CHLOROFORM FORMATION ESTIMATES FOR SEQUENCES WITH HYPOCHLORITE

BLEACHING SEQUENCE

HYPOCHLORITE USE*

CHLOROFORM, lb/ODT BROWNSTOCK

Air Emissions from Vents Discharge to Waste Treatment Facility Total

Range Average Range Average Range Average

0.1 to <0.5 percent 0.07 to 0.73 0.26 0.08 to 0.76 0.24 0.3 to 1.0 0.5

0.5 to 2 percent 0.12 to 1.10 0.52 0.14 to 1.14 0.48 0.5 to 1.5 1.0

>2 percent 0.24 to 2.19 0.78 0.27 to 2.28 0.72 1.0 to 3.0 1.5

*Percent hypochlorite use includes the hypochlorite generated by scrubbing Cl2 from ClO2 generator gases and used in the E stage. It is expressed as (lb available 

chlorine used/lb OD brownstock pulp) x 100. If sodium hypochlorite usage rates are known, then the following conversion applies: 

lb OD pulp brownstock 

lb used NaOCl 

 x

74.5

35.5

lb OD pulp brownstock 

used 2lb available Cl


Issued 2012 Chloroform 

(Last Updated March 2012) p. 3

ncasi

Pulp and Paper Mills

TABLE 2 BLEACH PLANT CHLOROFORM FORMATION ESTIMATES FOR 0.1 PERCENT HYPOCHLORITE SEQUENCES

PULP SPECIES, CHLORINATION STAGE CONDITIONS* TOTAL CHLOROFORM RELEASED, lb/ODT BROWNSTOCK

Hardwood, 70% Substitution 1.83 x Chlorine Factor - 0.06 eq. 1

Softwood, Chlorine Factor 0.15, Zero Chlorine Dioxide Substitution, or 

Simultaneous Addition of Chlorine and Chlorine Dioxide, or <40 Percent of Total

Available Chlorine Applied as Chlorine Dioxide is Added Before Chlorine. Total

Substitution May or May Not be Higher than 40 Percent.

4.06 x Chlorine Factor - 0.50 eq. 2

Softwood, Chlorine Factor <0.15, Zero Chlorine Dioxide Substitution, or 

Simultaneous Addition of Chlorine and Chlorine Dioxide, or <40 Percent of Total

Available Chlorine Applied as Chlorine Dioxide is Added Before Chlorine. Total

Substitution Between Zero and 90 Percent.

0.74 x Chlorine Factor eq. 3

Softwood, 40 Percent of Total Available Chlorine Applied as Chlorine Dioxide 

is Added Before Chlorine. Total Substitution 40 Percent and 70 Percent (2.91 x Chlorine Factor) - 0.09 eq. 4

100 Percent ClO2 Substitution, All Conditions 0.005

x100

lbODBrownstock

lbChlorine

Chlorine,Percent

KappaNo

Chlorine Percent

ChlorineFactor





.

,

*
Issued 2012 Chloroform 

(Last Updated March 2012) p. 4

ncasi

Pulp and Paper Mills

TABLE 3 CHLOROFORM FORMATION IN RECYCLED PULP BLEACHING

MILL

SECONDARY

FIBER

SOURCES

BLEACH

SEQUENCE

WEIGHT

PERCENT

HYPO USED**

CHLOROFORM DISCHARGED, lb/ODTP

Vents Sewers Total

A (2) Repulped H 1.10 0.07 0.62 0.69

B (2) Deinked H 0.56 <0.01 0.58 0.58

C (2) Repulped H 0.95 0.54 0.24 0.78

D (2) Repulped CH 1.92 2.03 1.27 3.30

E (3) Deinked H 0.25 0.07 0.04 0.11

F (3) Deinked HY* 0.30 0.01 0.29 0.30

*Y - hydrosulfite bleaching stage 

** - weight percent hypo as defined in Table 1

 Chloroform is also produced in trace quantities during the chlorination of water. 

According to EPA (EPA 1984), 3.4 lbs. of chloroform /109 gallons of water are formed 

and emitted during the chlorination of “once-through” cooling water systems. 

Additionally, 25.5 lb/106

gallons and 0.34 lb/106gallons of chloroform are formed and 

emitted during the chlorination of “recirculating” cooling water systems, and drinking 

water, respectively. 

 Trace quantities of chloroform have also been measured in various pulp and paper mill 

vents and these are summarized in Table 4 (NCASI 2010).

 For an unbleached mill or a mill practicing 100 percent ClO2 substitution, based on the 

amount of chloroform generated in bleaching (Table 2) and emission estimates for most 

major sources (Table 4), the total amount of CHCl3 inadvertently manufactured and 

emitted is likely to be <0.03 lb/ADTUBP. 

Sample Calculation for Threshold Determination: 

A kraft mill produces 1100 ADTUBP/day which is then bleached (100 percent ClO2 substitution) 

after O2 delignification to produce 1000 ADTBP/day. At this mill, brown stock washer vent 

gases are collected and treated in an incineration device. The pulping process generates 3300 lb 

BLS/ADTUBP which is fired in DCE furnaces and 0.275 ton CaO is regenerated in the lime kiln 

per ADTUBP. The mill operates a 500 x 106

Btu/hr wood-fired boiler and a 50 tpd tall oil plant. 

The final product is 1000 tons of bleached paper per day. The mill operates all 365 days/yr and 

discharges 20 x 106gpd. 

Table 5 shows the amounts of chloroform emitted from several major operations at this example 

mill as estimated using factors given in Table 4. Table 5 also shows the amount of chloroform 

manufactured and present in (1) in uncontrolled NCGs, (2) strong black liquors before 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 5

ncasi

Pulp and Paper Mills

TABLE 4 PULP AND PAPER MILL VENTS - EMISSIONS OF CHLOROFORM (NCASI 2010)

VENT DESCRIPTION UNITS

NO. OF 

SOURCES*

DETECTED

MIN MAX MEDIAN MEAN STD DEV

TESTED

INCLUDED

Kraft Mill Sources

Black Liquor Oxidation Tank lb/T BLS 10 3 3 1.30E-06 3.90E-05 3.80E-06 1.48E-05 2.12E-05

Brownstock Washer - All Otheralb/ADTUBP 8 6 2 <1.6E-06 2.50E-04 1.80E-06 4.32E-05 9.25E-05

Brownstock Washer - Vacuum Drum Type (>300 ppm)blb/ADTUBP 29 17 14 3.20E-06 2.30E-02 4.00E-04 2.81E-03 5.99E-03

Brownstock Washer - Vacuum Drum Type (<300 ppm)blb/ADTUBP 5 5 4 3.20E-06 1.90E-03 9.51E-05 4.04E-04 8.78E-04

ClO2 Generator Scrubber lb/T ClO2 4 4 2 <1.1E-03 1.10E-02 2.00E-03 5.08E-03 7.30E-03

Decker lb/ADTUBP 8 1 1 -- -- 3.60E-05 3.60E-05 --

Deknotter lb/ADTUBP 5 2 2 1.40E-06 2.20E-06 1.80E-06 1.80E-06 --

Lime Kiln lb/T CaO 34 11 4 <8.6E-05 1.80E-03 9.98E-05 3.91E-04 4.53E-04

NCG Thermal Oxidizer lb/ADTUBP 6 1 1 -- -- 1.00E-07 1.00E-07 --

Oxygen Delignification System lb/ADTUBP 10 7 5 1.10E-06 9.00E-04 5.12E-05 2.55E-04 3.50E-04

Paper Machine - Bleached Paper & Pulp lb/ADTFP 7 5 3 7.70E-07 5.80E-04 1.59E-04 2.02E-04 2.46E-04

Paper Machine - Unbleached Linerboard lb/ADTFP 2 2 0 <1.2E-02 <4.3E-02 -- -- --

Prewasher Screen lb/ADTUBP 2 2 0 <9.1E-05 <1.1E-04 -- -- --

Recovery Furnace, DCE lb/T BLS 20 9 4 8.00E-06 7.90E-03 2.08E-04 1.10E-03 2.45E-03

Recovery Furnace, NDCE lb/T BLS 27 14 3 7.70E-06 5.30E-04 1.42E-05 4.79E-05 1.34E-04

Slaker&Causticizer – Combinedelb/T CaO 4 4 0 <2.5E-06 <9.7E-04 -- -- --

Smelt Dissolving Tankelb/T BLS 32 12 4 <7.6E-06 2.10E-04 7.10E-06 3.00E-05 5.59E-05

Solvent Based Silicone Coater lb/ADTFP 1 1 0 <1.3E-02 <1.3E-02 -- -- --

Tall Oil Reactor lb/T TO 7 7 3 1.50E-04 8.00E-02 1.80E-03 1.16E-02 2.79E-02

Miscellaneous Kraft Mill Vents

Batch Digester Fill Exhaust lb/ODT chips 4 4 1 <2.4E-05 3.20E-03 4.80E-05 8.00E-04 --

Continuous Digester Chip Bin Exhaust lb/ODT chips 3 1 1 -- -- 8.20E-07 8.20E-07 --

Unbleached Pulp Storage Tank lb/hr/tank 5 4 3 1.30E-04 9.40E-02 4.83E-03 2.37E-02 4.06E-02

Weak Black Liquor Storage Tank lb/hr/tank 7 2 1 <1.1E-06 1.10E-06 8.34E-07 8.34E-07 --

Strong Black Liquor Storage Tank lb/hr/tank 9 6 4 <1.4E-06 1.00E-03 5.44E-05 2.03E-04 3.60E-04

Green Liquor Clarifierelb/T CaO 1 1 0 <5.6E-05 <5.6E-05 -- -- --
Issued 2012 Chloroform 

(Last Updated March 2012) p. 6

ncasi

Pulp and Paper Mills

TABLE 4 (Cont’d) PULP AND PAPER MILL VENTS - EMISSIONS OF CHLOROFORM (NCASI 2010)

VENT DESCRIPTION UNITS

NO. OF 

SOURCES*

DETECTED

MIN MAX MEDIAN MEAN STD DEV

TESTED

INCLUDED

Dregs Filter Hood Exhaustelb/T CaO 2 2 0 <1.9E-05 <3.6E-05 -- -- --

Green Liquor Surge Tankelb/T CaO 1 1 1 -- -- 2.00E-06 2.00E-06 --

White Liq./Weak Wash Pressure Filterelb/T CaO 1 1 0 <5.9E-04 <5.9E-04 -- -- --

White Liquor Pressure Filter Tankelb/T CaO 1 1 0 <5.8E-04 <5.8E-04 -- -- --

Lime Mud Dilution Tankelb/T CaO 1 1 0 <7.5E-05 <7.5E-05 -- -- --

Lime Mud Mix Tankelb/T CaO 1 1 0 <6.1E-06 <6.1E-06 -- -- --

Lime Mud Pressure Filterelb/T CaO 1 1 0 <2.1E-05 <2.1E-05 -- -- --

White Liquor Oxidation Tankelb/ADTUBP 2 2 0 <2.5E-05 <1.5E-04 -- -- --

Lime Mud Precoat Filterelb/T CaO 5 2 2 8.60E-06 1.90E-05 1.40E-05 1.40E-05 --

Precoat Filter Vacuum Pump Exhaustelb/T CaO 3 3 1 <2.8E-06 1.10E-04 5.06E-05 5.06E-05 --

Slaker Scrubber Vent lb/T CaO 3 3 0 <8.8E-07 <9.6E-04 -- -- --

Saltcake Mix Tank lb/T BLS 3 3 0 <6.6E-07 <1.4E-05 -- -- --

UNOX System Vent lb/ADTUBP 1 1 1 -- -- 1.73E-04 1.73E-04 --

Uncontrolled Kraft Pulp Mill NCGs

Low Volume High Conc. NCGsclb/ADTUBP 5 5 2 <2.2E-03 3.70E-02 1.50E-03 1.62E-02 1.47E-02

Stripper Off-Gasesclb/ADTUBP 3 2 2 1.10E-03 2.20E-03 1.60E-03 1.60E-03 --

Sulfite Mill Sources

All Pulping & Recovery Sources lb/ADTUBP 4 3 3 2.73E-04 4.91E-03 4.73E-04 1.87E-03 2.60E-03

Bleach Plant Scrubber lb/ADTBP 2 2 2 3.00E-03 1.45E-02 8.59E-03 8.59E-03 --

Recovery Furnace lb/T RLS 4 2 2 9.00E-05 1.90E-04 1.42E-04 1.42E-04 --

Semi-Chemical Mill Sources

Paper Machine, Corrugated lb/ADTFP 1 1 0 <3.1E-02 <3.1E-02 -- -- --

Non-Chemical Mill Pulping Area Sources

Deinking (With Bleaching) Operations lb/ADTP 6 6 4 <3.1E-05 1.20E-01 5.49E-03 3.69E-02 4.78E-02

OCC & Recycled Paperboard Stock Preparation lb/ADTP 1 1 1 -- -- 4.98E-05 4.98E-05 --

Pressurized Groundwood Pulping lb/ADTP 1 1 1 -- -- 9.80E-06 9.80E-06 --

Stone Groundwood Pulping lb/ADTP 5 5 2 <2.8E-04 7.70E-03 5.60E-04 2.90E-03 2.40E-03

Thermomechanical Pulping lb/ADTP 9 8 7 4.50E-06 1.50E-03 1.01E-04 3.84E-04 5.35E-04
Issued 2012 Chloroform 

(Last Updated March 2012) p. 7

ncasi

Pulp and Paper Mills

TABLE 4 (Cont’d) PULP AND PAPER MILL VENTS - EMISSIONS OF CHLOROFORM (NCASI 2010)

VENT DESCRIPTION UNITS

NO. OF 

SOURCES*

DETECTED

MIN MAX MEDIAN MEAN STD DEV

TESTED

INCLUDED

Non-Chemical Mill Paper Machines

100% Secondary Fiber Furnish lb/ADTFP 7 7 5 6.15E-06 1.51E-02 2.29E-03 3.22E-03 9.03E-03

Nonintegrated Mill lb/ADTFP 1 1 1 -- -- 4.87E-04 4.87E-04 --

Secondary Fiber & OtherdFurnish lb/ADTFP 1 1 0 <1.3E-02 <1.3E-02 -- -- --

Virgin Mech. & Chem. Pulp Furnish lb/ADTFP 11 8 5 <3.2E-04 2.20E-03 2.24E-04 6.18E-04 6.54E-04

Boilers (emissions after PM control devices)

Coal lb/ton -- -- -- -- -- 5.90E-05 5.90E-05 --

Wood Residues lb/106 Btu 6 4 3 2.55E-06 4.70E-05 3.52E-05 2.59E-05 2.59E-05

 Notes: a Other washers - diffusion, pressure, belt and baffle; b uncontrolled” emissions for VDWs with > or < 300 ppm methanol in final stage shower water 

(< 300 ppm methanol indicative of clean condensate or fresh water use); c same for mills with batch & continuous digesters; d Other – includes virgin chemical, 

groundwood and thermomechanical pulp e applies only to “Mills not using fresh water for mud washing” 

ADT & ODT - air dry & oven dry ton; FP - finished product; BP & UBP – bleached & unbleached pulp; BLS & RLS – black & red liquor solids; TO – tall oil 

*“No. of sources - Tested” represents total number of sources that were tested; “No. of sources - Included” represents sources for which data were included in the 

analysis for estimating averages; the difference represents sources whose data were rejected mainly because they were non-detects with detection limits exceeding the 

highest detected observation – occasionally, an observation confirmed to be a statistical “outlier” was also rejected
Issued 2012 Chloroform 

(Last Updated March 2012) p. 8

ncasi

Pulp and Paper Mills

TABLE 51 THRESHOLD DETERMINATION FOR CHLOROFORM MANUFACTURED - SAMPLE CALCULATION

PROCESS UNIT

EMISSIONS

MULTIPLIER TO GET lb/yr TOTAL MANUFACTURED, lb/yr

Rate, mean Units

BLO Tank 1.48E-05 lb/T BLS (3300/2000)*1100*365 10

Bleach Plant 2.60E-03alb/ADTBP (1000/1100)*1100*365 949

Brownstock Washers 2.81E-03 lb/ADTUBP b1100*365 1,128

Deckers 3.60E-05 lb/ADTUBP 1100*365 14

Lime Kilns 3.91E-04 lb/T CaO 0.275*1100*365 43

NCG Thermal Oxidizer 1.00E-07 lb/ADTUBP 1100*365 0

Oxygen Delignification 2.55E-04 lb/ADTUBP 1100*365 102

Paper Dryer 2.02E-04 lb/ADTFP (1000/1100)*1100*365 74

DCE Recovery Furnaces 1.10E-03 lb/T BLS (3300/2000)*1100*365 729

Slaker/Causticizer Vents (2.50E-06/2)dlb/T CaO 0.275*1100*365 0

Smelt Dissolving Tank 3.00E-05 lb/T BLS (3300/2000)*1100*365 20

Tall Oil Reactor 1.16E-02 lb/T TO (50/1100)*1100*365 212

Wood-Fired Boilers 2.59E-05 lb/106 Btu (500 x 24/1100)*1100*365 113

Uncontrolled NCGs 1.62E-02 lb/ADTUBP 1100*365 6,504

Uncontrolled SOGs 1.60E-03 lb/ADTUBP 1100*365 642

TOTAL MANUFACTURED AND EMITTED 10,541

AMOUNT RELEASED TO WWTPc= 876 lb/yr (from bleach plant) 876

AMOUNT IN STRONG BLACK LIQUOR 

= 1100 ADTUBP/d X 365 d/yr x (3300/2000) ton BLS/ADTUBP x 0.0 lb/ton BLS 0

TOTAL MANUFACTURED 11,417

a

 52% of CHCl3 generated in bleach plant is emitted; 0.52 x 0.005 = 2.6E-03 lb/ADTBP 

b

estimates for brown stock washer vent gases before collection and control 

c 48% of CHCl3 generated in bleach plant is released in effluent; 0 .48 x 0.005 x 1000 x 365 = 876 lb/yr 

d

 using 1⁄2 detection limit for NDs

 

1

If there are no mill-specific air emission measurements for chloroform, the information in Table 4 may be used. Table 4 presents both medians and means. In 

sample calculations presented here, means are used. Individual mills should select the approach with which they are most comfortable. 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 9

ncasi

Pulp and Paper Mills

combustion and (3) WWTP untreated effluents. For this example mill, based on the total amount 

of chloroform manufactured and either emitted or released to the WWTP, a SARA 313 report 

does not have to be filed as the amount does not exceed 25,000 lb/yr. 

3.2 Process the toxic chemical:

 The SARA Section 313 regulations define “processing” as an incorporative activity. 

Chloroform is generally not processed in this industry. 

3.3 Otherwise use the toxic chemical:

 This would be the sum of all the chloroform used at the manufacturing site. Chloroform 

is not used in this industry. 

SECTION 4. MAXIMUM AMOUNT OF THE TOXIC CHEMICAL ON-SITE AT 

ANY TIME DURING THE CALENDAR YEAR 

4.1 _____ (Enter two-digit code from instruction package.) 

Chloroform is expected to be present on the mill site only in the waste treatment plant 

(WWTP). For a kraft mill, in the absence of mill-specific information, the average 

concentration in the mill WWTP may be assumed to be 25 percent of the WWTP influent 

concentration. The WWTP influent concentration is estimated in Tables 1, 2 or 3. 

SECTION 5. RELEASES OF THE TOXIC CHEMICAL TO THE 

ENVIRONMENT ON-SITE 

5.1 Fugitive or non-point air emissions

Fugitive or non-point air emissions of chloroform are expected mainly from the 

wastewater treatment plant (WWTP). Fugitive emissions may also occur from 

wastewater conveyance systems that are open to the atmosphere. Fugitive emissions from

the WWTP are commonly modeled using the WATER9 software tool developed by US 

EPA. WATER9 (http://www.epa.gov/ttn/chief/software/water/) utilizes empirical 

correlations that relate mass transfer to the organic compound properties, WWTP 

characteristics, wind speed, etc. More details about typical parameters used to run this 

model are provided in Appendix 4.A of the SARA 313 Handbook. The following 

sections deal an approach one could use to estimate fugitive emissions from various 

components of a mill’s WWTP. 

(a) Primary Clarifier – Fugitive emissions from primary clarifiers are a function of 

the effluent flow rate, residence time, temperature, clarifier diameter, weir drop 

height, wind speed, and organic compound properties. WATER9 can be used to 

estimate fugitive emissions from clarifiers but has not been verified by field data. 

The reliability of estimates obtained using WATER9 is unknown at the present 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 10

ncasi

Pulp and Paper Mills

time. Results of application of WATER9 to an example primary clarifier (175 ft 

diameter, 12 ft depth, effluent temperature = 36 C, weir drop height = 10 inches, 

wind speed = 5 miles/hr) receiving 11 MGD of pulp mill effluent are shown in 

Table 6 of Appendix 4.A. It should be noted that site-specific parameters for the 

clarifier could have a significant influence on these estimates. Thus, the use of 

site-specific parameters to arrive at these estimates is recommended. 

(b) Secondary WWTP – Fugitive emissions from secondary WWTP are a function 

of the WWTP characteristics, wind speed, and organic compound properties. 

Table 6 provides estimates of chloroform partitioning in the secondary WWTP 

based on application of WATER9 to an example Aerated Stabilization Basin 

(ASB) and an Activated Sludge Treatment (AST) system. The characteristics of 

the ASB and AST used as model inputs in the WATER9 model are also provided 

in Appendix 4.A. 

TABLE 6 WWTP PARTITIONING OF CHLOROFORM USING TYPICAL WATER9 PREDICTIONS

Aerated Stabilization Basin (ASB) a, b Activated Sludge 

Treatment (AST)a One Basin Two Basin Three Basin

Percent Volatilized 47.0 53.8 56.7 33.5

Percent Biodegraded 50.3 45.2 43.2 65.1

Percent in Effluent 2.7 1.0 0.1 1.4

Percent Overall Removal 97.3 99.0 99.9 98.6

a

 Appendix 4.A 

b The one-basin model treats the WWTP as one well-stirred tank. The two-basin model treats three quarters of 

the WWTP as well stirred (with all the aeration HP) and the last quarter as a quiescent section (zero HP). The 

three-basin model treats the first 35% of the WWTP to be stirred with 50% of total HP, the next 40% to be stirred 

with the remaining 50% of total HP, and the last 25% to be quiescent. The two-basin and three-basin models are 

perhaps better representations of actual WWTP operation. 

Sample Calculations:

Case 1 - Bleaching Sequence with >0.1 Percent Hypochlorite

A mill bleaching 1000 ODT brownstock per day operates 365 day/yr, uses 1 percent hypochlorite 

in the bleach plant, and operates an aerated stabilization basin. 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 11

ncasi

Pulp and Paper Mills

From Table 1, CHCl3 sent to the waste treatment system 

= (0.48 lb CHCl3/ton pulp)(1000 tpd)(365 d/yr) = 175,200 lb/yr 

CHCl3 volatilized from the treatment basin using WATER9 predictions (three-basin model from 

Table 6) 

= 0.567 x 175,200 lb/yr = 99338 lb/yr 

Case 2 - A Mill Bleaching 1,000 ODT Brownstock per day Operates 365 day/yr, Uses a 100% 

ClO2 Substitution Bleaching Sequence, and Operates an Aerated Stabilization Basin.

CHCl3 formation 

= 0.005 lb/ODT brownstock 

CHCl3 to the waste treatment system 

= 0.48 x 0.005 lb/ODT brownstock = 0.0024 lb/ODT brownstock 

CHCl3 volatilized from the waste treatment system (using WATER9 three-basin model from 

Table 6) 

= 0.0024 x 0.567 = 0.0014 lb/ODT brownstock 

Annual fugitive emissions of CHCl3 from the treatment basin 

= 1000 ODT brownstock/day x 365 day/yr x 0.0014 lb/ODT brownstock = 511 lb/yr 

Case 3 - A Mill Bleaching 1,000 ODT Brownstock per day Operates 365 day/yr, Uses a less 

than 100% ClO2 Substitution Bleaching Sequence with 0.1 Percent Hypochlorite Use, and 

Operates an Aerated Stabilization Basin.

Example 1 – Simultaneous addition of 50 lb Cl2 and 19 lb ClO2 per odtbs to softwood pulp 

Kappa No. 28, Kappa Factor = 0.179, Chlorine Factor = 0.089 

 

Mixer

Pulp

ClO2 - 19 lb/ODTBS

Cl2 - 50 lb/ODTBS
Issued 2012 Chloroform 

(Last Updated March 2012) p. 12

ncasi

Pulp and Paper Mills

For the above bleach plant, 

0.089

28

2.5

 x 100 percent;2.5 Cl factor 

2000

50 napplicatio chlorine %   2 

ClO2 substitution, calculated as Cl2 equivalent (ClO2 has 2.63 times the oxidizing power of 

chlorine on a lb per lb basis) 

 

x 100 50%

2.63x9.5 25

2.63x9.5





 

Since the chlorine factor is <0.15 and all ClO2 is applied simultaneously with Cl2, equation 3 of 

Table 2 would apply. 

CHCl3 formation 

= 0.74 x 0.089 lb/ODT brownstock = 0.066 lb/ODT brownstock 

CHCl3 to the waste treatment system 

= 0.48 x 0.066 lb/ODT brownstock = 0.028 lb/ODT brownstock 

CHCl3 volatilized from the waste treatment system (using NOCEPM three-basin model from 

Table 6) 

= 0.028 x 0.567 = 0.016 lb/ODT brownstock 

Annual fugitive emissions of CHCl3 from the treatment basin 

= 1000 ODT brownstock/day x 365 day/yr x 0.016 lb/ODT brownstock = 5840 lb/yr 

Example 2 – Addition of 11.4 lb ClO2 per odtbs followed by addition of 70 lb Cl2 to softwood 

pulp, Kappa No. 28, Kappa Factor = 0.179, Chlorine Factor = 0.125 

For the above bleach plant, 

0.125

28

3.5

 x 100 percent;3.5 Chlorine factor

2000

70 napplicatio chlorine %   

Pulp

Mixer 1 Mixer 2

ClO2 - 11.4 lb/ODTBS

Cl2 – 70 lb/ODTBS
Issued 2012 Chloroform 

(Last Updated March 2012) p. 13

ncasi

Pulp and Paper Mills

ClO2 substitution prior to Cl2 application, calculated as Cl2 equivalent 

 

 x 30100 %

 2.63x 11.4 70

2.63x11.4







Since the chlorine factor is <0.15 and ClO2 substitution prior to Cl2 application is less than 40 

percent, equation 3 from Table 2 would apply. 

CHCl3 formation 

= 0.74 x 0.125 lb/ODT brownstock = 0.0925 lb/ODT brownstock 

CHCl3 to the waste treatment system 

= 0.48 x 0.0925 lb/ODT brownstock = 0.039 lb/ODT brownstock 

CHCl3 volatilized from the waste treatment system (using NOCEPM three-basin model from 

Table 6) 

= 0.039 x 0.567 = 0.022 lb/ODT brownstock 

Annual fugitive emissions of CHCl3 from the treatment basin 

= 1000 ODT brownstock/day x 365 day/yr x 0.022 lb/ODT brownstock = 8030 lb/yr 

Example 3 - Addition of 26.6 lb ClO2 per ODTBS followed by addition of 30 lb Cl2 to softwood 

pulp, Kappa No. 28, Kappa Factor = 0.179, Chlorine Factor = 0.054 

Pulp

Mixer 1 Mixer 2

ClO2 - 26.6 lb/ODTBS

Cl2 - 30 lb/ODTBS
Issued 2012 Chloroform 

(Last Updated March 2012) p. 14

ncasi

Pulp and Paper Mills

For the above bleach plant, 

0.054

28

1.5

 x 100 percent; 1.5 Chlorine factor

2000

30 napplicatio chlorine %   

ClO2 substitution prior to Cl2 application 

 

 x 70100 %

2.63x26.6 30

2.63x26.6







Since ClO2 substitution prior to Cl2 application is greater than 40 percent and ClO2 substitution 

is greater than 40 percent, equation 4 from Table 2 would apply. 

CHCl3 formation 

= (2.91 x 0.054 - 0.09) lb/ODT brownstock = 0.067 lb/ODT brownstock 

CHCl3 to waste treatment system 

= 0.48 x 0.067 lb/ODT brownstock = 0.028 lb/ODT brownstock 

CHCl3 volatilized from the waste treatment system (using NOCEPM three-basin model from 

Table 6) 

= 0.028 x 0.567 = 0.016 lb/ODT brownstock

Annual fugitive emissions of CHCl3 from the treatment basin 

= 1000 ODT brownstock/day x 365 day/yr x 0.016 lb/ODT brownstock = 5840 lb/yr 

Example 4 - Same as example 3, split addition of ClO2 

Pulp

ClO2- 19.0 lb/ODTBS

Cl2 - 30 lb/ODTBS

Mixer 1 Mixer 2

ClO2 - 7.6 lb/ODTBS
Issued 2012 Chloroform 

(Last Updated March 2012) p. 15

ncasi

Pulp and Paper Mills

For the above bleach plant, 

0.054

28

1.5

 x 100 percent;1.5 Chlorine factor

2000

30 % napplicatio chlorine   

ClO2 substitution prior to Cl2 application 

  

 x 50100 %

2.63 x7.6 19.0 30

2.63 x 19.0



 



Since ClO2 substitution prior to Cl2 application is greater than 40 percent, equation 4 from 

Table 2 would apply. 

CHCl3 formation 

= (2.91 x 0.054 - 0.09) lb/ODT brownstock = 0.067 lb/ODT brownstock 

CHCl3 to the waste treatment system 

= 0.42 x 0.067 lb/ODT brownstock = 0.028 lb/ODT brownstock 

CHCl3 volatilized from the waste treatment system (using NOCEPM three-basin model from 

Table 6) 

= 0.028 x 0.567 = 0.016 lb/ODT brownstock 

Annual fugitive emissions of CHCl3 from the treatment basin 

= 1000 ODT brownstock/day x 365 day/yr x 0.016 lb/ODT brownstock = 5840 lb/yr 

Example 5 – Same as example 2, but split addition of ClO2; 7.6 lb per odtbs followed by 3.8 lb 

per odtbs and 70 lb per odtbs Cl2, Kappa No. 28, Kappa Factor = 0.179, Chlorine Factor = 

0.125

Pulp

ClO2 - 7.60 lb/ODTBS

Cl2 - 70 lb/ODTBS

ClO2 - 3.80 lb/ODTBS

Mixer 1 Mixer 2
Issued 2012 Chloroform 

(Last Updated March 2012) p. 16

ncasi

Pulp and Paper Mills

For the above bleach plant, 

0.125

28

3.5

 x 100 3.5; Chlorine factor

2000

70 napplicatio chlorine %   

ClO2 substitution prior to Cl2 application 

  

 x 20100 %

 2.63 x3.8 7.6 70

2.63 x 7.6



 



Since the chlorine factor is <0.15 and ClO2 substitution prior to Cl2 application is less than 40 

percent, equation 3 from Table 2 would apply. 

CHCl3 formation 

= 0.74 x 0.125 lb/ODT brownstock = 0.0925 lb/ODT brownstock 

CHCl3 to the waste treatment system 

= 0.42 x 0.0925 lb/ODT brownstock = 0.039 lb/ODT brownstock 

CHCl3 volatilized from the waste treatment system (using WATER9 three-basin model from 

Table 6) 

= 0.039 x 0.567 = .022 lb/ODT brownstock 

Annual fugitive emissions of CHCl3 from the treatment basin 

= 1000 ODT brownstock/day x 365 day/yr x 0.022 lb/ODT brownstock = 8030 lb/yr 

(c) Surface impoundments and flow-through settling ponds – If a mill sends its 

WWTP residuals (before dewatering) or weak spent liquors to a surface 

impoundment on-site, or sends its effluent through a flow-through settling basin 

or lagoon, small amounts of fugitive emissions of chloroform would result. 

Fugitive emissions from these sources are a function of the effluent flow rate, 

residence time, temperature, exposed surface area, wind speed, and organic 

compound properties. These site-specific characteristics can be used in WATER9 

models to estimate such emissions (See discussion in Appendix 4.A).

5.2 Stack or point air emissions

 The only major source of stack or point air emissions of chloroform is the bleach plant 

vent. These emissions can be estimated from Tables 1, 2 and 3. Other minor sources of 

air emissions can be estimated from factors given in Table 4. 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 17

ncasi

Pulp and Paper Mills

Case 1 - Bleaching Sequence with >0.1 Percent Hypochlorite

From Table 1, for the plant described above in section 5.1 (b) Case 1, the air emissions of CHCl3

from the bleach plant 

= (0.52 lb CHCl3/ton pulp)(1000 tpd)(365 day/yr) 

= 189,800 lb/yr 

Case 2 - Bleaching Sequence with 100% ClO2 Substitution

From Table 2, for the plant described above in 5.1 (b) Case 2, the amount of CHCl3 formed in 

the bleach plant 

= 0.005 lb/ODT brownstock 

Air emissions of CHCl3 from bleach plant (using 52 percent emission from bleach plant vents) 

= 0.52 x 0.005 lb/ODT brownstock = 0.0026 lb/ODT brownstock 

Annual emissions of CHCl3 from bleach plant vents 

= 1000 ODT brownstock/day x 365 day/yr x 0.0026 lb/ODT brownstock = 949 lb/yr 

Case 3 - Bleaching Sequence Using <100% ClO2 Substitution & <0.1 Percent Hypochlorite

From Table 2, for the plant described above in 5.1 (b) Case 3, Example 1, the amount of CHCl3

formed in the bleach plant 

= 0.066 lb/ODT brownstock 

Air emissions of CHCl3 from bleach plant (using 52 percent emission from bleach plant vents) 

= 0.52 x 0.066 lb/ODT brownstock = 0.034 lb/ODT brownstock 

Annual emissions of CHCl3 from bleach plant vents 

= 1000 ODT brownstock/day x 365 day/yr x 0.034 lb/ODT brownstock = 12,410 lb/yr 

If kraft noncondensible gases are partially vented based on the operational characteristics 

of the incinerator, then the emission factors given in Table 42 may be used to estimate 

emissions of chloroform from the noncondensible gas handling system. They are not 

expected to be significant. 

 

2

 See footnote on page 4. 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 18

ncasi

Pulp and Paper Mills

Sample Calculation:

A kraft mill manufactures 1100 ATDUBP/day and burns pulping and evaporator NCGs and 

noncondensible stripper-off gases. They are vented to the atmosphere during 2 percent of the 

annual operating time. 

Amount of chloroform in NCGs and SOGs being burned (from Table 4, assuming batch digesters 

and using median with ND = 0) 

= 1100 ADTUBP/d x 365 d/yr x (0.011 + 0.0016) lb/ADTUBP = 5,059 lb/yr 

Chloroform vented to the atmosphere 

= 0.02 x 5,059 = 101 lb/yr 

5.3 Discharges to receiving streams or water bodies

 Typical applications of the WATER9 three-basin ASB model (as shown in section 5.1 

(b)) show that from 0.1 percent of the chloroform is discharged with the effluent. 

Sample Calculations:

Case 1 - Bleaching Sequence with >0.1 Percent Hypochlorite

For the plant described in 5.1 (b) Case 1, 175,200 lb/yr of CHCl3 was shown to be sent to the 

waste treatment system. CHCl3 discharged with the final effluent 

= 0.001 x 175,200 lb/yr 

= 175.2 lb/yr 

Case 2 - Bleaching Sequence with 100% ClO2 Substitution

For the plant described in 5.1 (b) Case 2, chloroform formed in the bleach plant 

= 0.005 lb/ODT brownstock 

Chloroform discharged to the waste treatment system 

= 0.005 x 0.48 = 0.0024 lb/ODT brownstock 

Chloroform discharged with the effluent 

= 0.001 x 0.0024 lb/ODT brownstock = 2.4 x 10-6 lb/ODT brownstock 

Annual discharge of CHCl3 with effluents 

= 1000 ODT brownstock/day x 365 day/yr x 2.4 x 10-6 lb/ODT brownstock = 0.88 lb/yr 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 19

ncasi

Pulp and Paper Mills

Case 3 - Bleaching Sequence Using <100% ClO2 Substitution & <0.1 Percent Hypochlorite

For the plant described in 5.1 (b) Case 3, Example 1, chloroform formed in the bleach plant 

= 0.066 lb/ODT brownstock 

Chloroform discharged to the waste treatment system 

= 0.066 x 0.48 = 0.032 lb/ODT brownstock 

Chloroform discharged with the effluent 

= 0.001 x 0.032 lb/ODT brownstock = 0.00003 lb/ODT brownstock 

Annual discharge of CHCl3 with effluents 

= 1000 ODT brownstock/day x 365 day/yr x 0.00003 lb/ODT brownstock = 11.0 lb/yr 

5.4 Underground injections on-site

 This does not typically apply to most mills. 

5.5 Releases to land on-site

 Discharges to land on-site could occur either through primary and/or secondary WWTP 

residuals (sludges). The primary and secondary sludges may be pumped to a surface 

impoundment, such as a holding pond or lagoon, or dewatered and sent to either an onsite landfill or a combustion device. Published reports and data available to NCASI show 

that the chloroform content of sludges ranges from 0 to 63.5 ppm on a dry basis, with a 

mean of 1.1 ppm (NCASI file information, Warzyn 1980; NCASI 1984). These data can 

be used to estimate chloroform losses with primary and secondary sludges. 

5.5.1B Other landfills 

Sample Calculation:

A mill produces 50 tons/day of sludge containing 40 percent solids. The sludge is sent to a 

landfill 365 day/yr. 

Chloroform released with the sludge 

= (50 tons wet sludge/day)(365 day/yr)(0.4 ton dry/ton wet) 

 x (1.1 x 10-6

ton CHCl3/ton dry sludge)(2000 lb/ton) = 16 lb/yr
Issued 2012 Chloroform 

(Last Updated March 2012) p. 20

ncasi

Pulp and Paper Mills

5.5.2 Land treatment/application farming

 If a mill landspreads WWTP residuals (sludges) on-site, then the amount of chloroform in 

these sludges needs to be reported in this section. These calculations are shown in section 

5.5.1.

5.5.3B Other surface impoundments

 If a mill sends its primary and/or secondary WWTP residuals (sludges) to a surface 

impoundment on-site, such as a holding or settling pond, lagoon, etc., then the amount of 

chloroform in sludges sent to this impoundment needs to be reported under this section. 

The amount of CHCl3 in sludges sent to the impoundment may be estimated in a manner 

similar to that shown in section 5.5.1. 

5.5.4 Other disposal

 Any chloroform released to land on-site that does not fit under the previous three 

categories should be reported here. 

SECTION 6. TRANSFERS OF THE TOXIC CHEMICAL IN WASTES TO 

OFF-SITE LOCATIONS 

These can be estimated from chloroform concentrations in waste streams such as WWTP 

residuals and mill effluent leaving the mill boundary. Note that this section only applies 

to toxic chemicals in waste streams. Thus, if a mill does not consider its spent liquor to 

be a waste stream, off-site transfers of spent liquor would not have to be reported in this 

section. 

6.1 Discharge to Publicly Owned Treatment Works (POTWs) 

 The quantity of reportable chemical transferred and basis of estimate should be provided 

for each wastewater discharge sent to a POTW. The amount of chloroform in untreated 

wastewater streams sent to POTWs may be estimated from the WWTP influent 

concentrations given in Tables 1, 2 or 3.

6.2 Transfers to other off-site locations 

According to EPA guidance, the EPA identification number (EIN), name and address for 

each off-site location to which the facility ships or transfers wastes containing the 

reportable chemical, needs to be reported in this section. The amount of reportable 

chemical transferred, basis of estimate, and the types of waste management (treatment/ 

disposal/recycling/energy recovery) should be provided for each off-site location. 

For mills that transfer spent liquors to other locations (mills) and consider such liquors to 

be “waste” streams, the transfer of chloroform (if present) in these liquors needs also to 

be considered in this section. The transfer of chloroform in other wastes such as WWTP 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 21

ncasi

Pulp and Paper Mills

residuals to off-site locations should also be considered in this section. (For example, the 

off-site transfer of residuals for land-spreading or landfilling.) 

SECTION 7. ON-SITE WASTE TREATMENT, ENERGY RECOVERY AND 

RECYCLING METHODS 

This section deals with the methods of waste treatment, energy recovery and recycling 

applied to the reported toxic chemical in “wastes” on site. Thus, if a mill does not 

consider a stream that contains a toxic chemical to be a “waste” and this stream is treated, 

burned for energy recovery, or recycled, this section does not apply to such a stream. For 

example, if a mill does not consider its spent liquor to be a “waste,” then the burning of 

this liquor in recovery furnaces for chemical or energy recovery should not be considered 

in this section. Furthermore, the applicability of this section to a waste stream that passes 

through a pollution control device when such a device was clearly not designed to treat or 

remove the toxic chemical contained in the waste stream is somewhat unclear. One 

interpretation is that if the overall percent removal efficiency for the toxic chemical in the 

waste stream passing through a pollution control device is expected to be close to zero, 

this section does not apply. A second interpretation is that this section applies to such a 

waste stream and the toxic chemical in it even when the percent removal efficiency 

through the control device is close to zero. The examples shown in this section assume 

the first interpretation. 

SECTION 7A. ON-SITE WASTE TREATMENT METHODS AND EFFICIENCY 

7A.1 Feed to Waste Treatment Systems

 7A.1a W

 7A.1b Waste Treatment Method(s) Sequence 

 H123 and H081

 7A.1c Waste Treatment Efficiency Estimate 

The overall treatment efficiency given by the WATER9 three-basin ASB 

model in Table 5 is 99.9% (range E3). 

SECTION 7B. ON-SITE ENERGY RECOVERY PROCESSES 

 If a mill considers spent liquors to be “waste” streams and burns these liquors in recovery 

furnaces, this activity is covered under section 7B and the quantity of chloroform in the 

liquors (chloroform expected to be present only in bleach plant spent liquors) burned 

should be reported in this section (check for consistency with section 8.2). 

If noncondensible gases (NCGs) containing chloroform are burned in a boiler (or 

recovery furnace) then this may be considered as energy recovery. However, if NCGs 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 22

ncasi

Pulp and Paper Mills

(including stripper gases) are burned in a lime kiln or thermal oxidizer (TO) then this may

be considered as energy recovery or treatment (see section 8.6). In either case, note that 

this section needs to be consistent with section 8.2. 

If a mill burns waste treatment plant residuals containing chloroform in a boiler on-site 

and considers this to be energy recovery and not treatment, the recovery code is U03 

(check for consistency with section 8.2). This section would not apply if the mill 

considers the residual to be a boiler fuel and not a waste stream. 

SECTION 7C. ON-SITE RECYCLING PROCESSES 

NA

SECTION 8. SOURCE REDUCTION AND RECYCLING ACTIVITIES 

It should be noted that, with the exception of section 8.1 which deals with total releases to 

the environment, sections 8.2 through 8.7 apply to source reduction and recycling 

activities concerned with “waste” streams only. 

8.1 Quantity released - Column B 

In this section, facilities report disposal and other releases. This includes onsite disposal and 

other releases in Section 5 and off-site disposal and other releases in Section 6 (releases plus 

transfers for disposal and transfers to POTWs of metals and metal compounds), but excludes 

quantities reported in Section 5 and 6 due to remedial actions, catastrophic events, or nonproduction related events (see the discussion on Section 8.8.) 

Sections 8.1a and 8.1b - Toxic chemicals disposed or otherwise released on site are reported in 

8.1a or 8.1b as appropriate. 

8.1a Quantity released - Column B – Current Reporting Year 

Total on-site disposal to Class I Underground Injection Wells, RCRA Subtitle C landfills, 

and other landfills 

§ 8.1a = § 5.4.1 + § 5.5.1A + § 5.5.1B – § 8.8 (on-site release or disposal due to 

catastrophic events)3

8.1b Quantity released - Column B – Current Reporting Year 

Total other on-site disposal or other releases 

§ 8.1b = § 5.1 + § 5.2 + § 5.3 + § 5.4.2 + § 5.5.2 + § 5.5.3A + § 5.5.3B + § 5.5.4 – § 8.8 

(on-site release or disposal due to catastrophic events)

 

3

§8.8 includes quantities of toxic chemicals disposed or otherwise released onsite or managed as a waste off site due 

to remedial actions, catastrophic events, or one time events not associated with the production process. 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 23

ncasi

Pulp and Paper Mills

Sections 8.1c and 8.1d - Toxic chemicals transferred off site to POTWs or other off-site 

locations that remain untreated4

should be reported in 8.1c or 8.1d as appropriate. For example, 

quantities of a toxic chemical sent to a POTW and subsequently sent to a landfill, or quantities of 

a toxic chemical sent to other off-site landfills that remain untreated, are reported in Section 8.1c. 

Quantities of a toxic chemical disposed or otherwise released by a POTW or other off-site 

locations to a stream are reported in Section 8.1d. Quantities of the toxic chemical sent to a 

POTW or other off-site locations and subsequently treated are reported in Section 8.7. Metals 

and metal category compounds sent to POTWs or other off-site locations should be reported in 

either section 8.1c or 8.1d and should not be reported as treated for destruction in Section 8.7. 

8.1c Quantity released - Column B 

Total off-site disposal to Class I Underground Injection Wells, RCRA Subtitle C 

landfills, and other landfills 

§ 8.1c = § 6.1 (portion5of transfer that is untreated and ultimately disposed of in UIC 

Class I Wells, RCRA Subtitle C landfills, and other landfills) + § 6.2 (quantities 

associated with M codes M64, M65 and M81) – § 8.8 (off-site disposal due to 

catastrophic events)

8.1d Quantity released - Column B 

Total other off-site disposal or other releases. 

§ 8.1d = § 6.1 (portion of transfer that is untreated and ultimately disposed of in UIC 

Class II-V wells, and land disposal other than to landfills) + § 6.2 (quantities associated 

with M codes M10, M41, M62, M66, M67, M73, M79, M82, M90, M94, M99) – § 8.8 

(off-site disposal due to catastrophic events) 

Sample Calculation:

For the mill described in section 5.1 (b) Case 1, section 5.2, Case 1, and section 5.3, Case 1, it 

was shown that chloroform discharged with treated effluents was 526 lb/yr, the fugitive 

emissions of chloroform were 164,338 lb/yr, and the total point source air emissions were 

189,800 lb/yr. For the mill described in section 5.5.1, the quantity of chloroform in the sludge 

sent to an on-site landfill was 16 lb/yr. In addition, if the mill sent a portion of its effluent 

containing 100,000 lb/yr of chloroform to a POTW for treatment, then 

(i) Quantity of chloroform released on-site 

= 526 lb + 164,338 lb + 189,800 lb + 16 lb = 354,680 lb 

 

4Metals and metal category compounds are not treated in a POTW. In addition, some chemicals might not be fully 

treated for destruction at a POTW. If you are able to quantify the amounts of a toxic chemical sent to a POTW that 

are treated for destruction and disposed or released from the POTW untreated, you should divide the amount 

reported in Section 6.1 between Sections 8.1c and 8.1d and 8.7 (quantity treated off site), as appropriate. Otherwise, 

report the entire amount in Section 8.7. 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 24

ncasi

Pulp and Paper Mills

(ii) Quantity of chloroform sent off-site for disposal 

= 100,000 lb 

(iii) Total quantity of chloroform released on-site or off-site 

= (354,680 + 100,000) lb = 454,680 lb 

8.1 Quantity released - Columns C and D

 These estimates can be based on projected bleached pulp production rates and source 

reduction activities. 

8.2 Quantity used for energy recovery on-site

 0 lb/yr. If the mill uses any of the interpretations in section 7B, the quantities should be 

reported here.

8.3 Quantity used for energy recovery off-site

 0 lb/yr 

8.4 Quantity recycled on-site

 0 lb/yr 

8.5 Quantity recycled off-site

 0 lb/yr 

8.6 Quantity treated on-site - Column B

 This section requires the quantity of chloroform treated on-site. 

Sample Calculation: 

For the mill described in section 5.1(b) Case 1, the mill sent 175,200 lb of chloroform to the 

waste treatment system. When the WATER9 (three-basin ASB model) was used for chloroform, it 

was determined that 43.2 percent of chloroform was biodegraded. 

(i) Quantity of chloroform treated on-site in the waste treatment system 

lb

100

43.2 x 175,200 













= 75686 lb

8.6 Quantity treated on-site - Columns C and D

 These can be estimated based on projected bleached pulp production rates and source 

reduction activities. 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 25

ncasi

Pulp and Paper Mills

8.7 Quantity treated off-site

 This section requires the quantity of chloroform sent off-site for treatment (6.1 + 6.2 

(treatment only)), minus the quantity reported as sent for off-site treatment under section 

8.8. Thus, if a mill’s effluent were sent to a POTW, the total quantity of chloroform in 

the effluent sent to the POTW would be reported in this section. Similarly, if a mill sends 

its WWTP residuals containing chloroform to be land-applied off-site and all of this 

chloroform is biodegraded, the amount of chloroform in the residuals should be reported 

under this section. 

8.8 Quantity released to the environment as a result of remedial actions, catastrophic 

events, or one-time events not associated with production processes

 This would be the amount of chloroform released, prior to any treatment, as a result of 

catastrophic events, remedial actions, or other one-time events not associated with other 

normal or routine production processes. 

8.9 Production ratio or activity index

 This section requires the reporting of a production ratio or activity index in the reporting 

year. The ACT requires that this ratio should most closely reflect all activities involving 

the toxic chemical. Since the major contributor to chloroform release (especially in a 

non-hypochlorite bleaching sequence) is the amount of bleached pulp produced, one 

could possibly report the ratio of bleached pulp production in the reporting year to 

bleached pulp production in the previous year. 

8.10 Source reduction activities (Column 1) 

 Data Elements 8.10.1, 8.10.2, 8.10.3, 8.10.4

 The following is a partial list of activities which would be considered source reduction 

activities for chloroform: 

(i) Reduction in hypochlorite usage in the bleach plant (Activity W58). 

(ii) Reduction in chlorine factor in the bleach plant through increased ClO2

substitution or other changes in the bleach plant (Activity W42). 

(iii) Modification of the Cl2 and ClO2 addition sequences so that a higher fraction of 

ClO2 is added after Cl2 has been applied (Activity W58). 

(iv) Operating the hypochlorite stage at an elevated temperature to reduce the amount 

of chloroform leaving that stage (Activity W58). 

(v) Changing product specifications so that a lower brightness pulp requiring less 

chlorine is used and the modified bleaching sequence produces less chloroform 

(Activity W81). 
Issued 2012 Chloroform 

(Last Updated March 2012) p. 26

ncasi

Pulp and Paper Mills

8.10 Methods to identify activity (Columns 2, 3, and 4) 

 Data Elements 8.10.1, 8.10.2, 8.10.3, 8.10.4

 Enter one or more of the codes from T01 to T11 if they apply. 

8.11 Source Reduction, Recycling, or Pollution Control Activities 

This is an optional section within EPA’s TRI-ME reporting software. It has a text box 

feature that allows brief reporting of applicable source reduction, recycling, and other 

pollution control techniques and activities undertaken for the chemical. Facilities may 

also submit hard copies of more detailed source reduction information. 

REFERENCES

Environmental Protection Agency (U.S.). 1984. Locating and estimating air emissions from 

sources of chloroform. EPA-450/4-84-007c. pp. 57-60. Research Triangle Park, NC: 

U.S. Environmental Protection Agency. 

National Council for Air and Stream Improvement, Inc. (NCASI). 1984. The land application 

and related utilization of pulp and paper mill sludges. Technical Bulletin No. 439. 

Research Triangle Park, NC: National Council for Air and Stream Improvement, Inc. 

 . 1988. Results of field measurements of chloroform formation and release from pulp 

bleaching. Technical Bulletin No. 558. Research Triangle Park, NC: National Council 

for Air and Stream Improvement, Inc. 

 . 1993. An investigation of factors that influence chloroform generation from recovered 

paper fiber bleaching with hypochlorite. Technical Bulletin No. 649. Research Triangle 

Park, NC: National Council for Air and Stream Improvement, Inc. 

 . 2010. Compilation of ‘air toxic’ and total hydrocarbon emissions data for pulp and 

paper mill sources – a second update. Technical Bulletin No. 973. Research Triangle 

Park, NC: National Council for Air and Stream Improvement, Inc. 

Warzyn Engineering, Inc. 1980. Documentation report: lime pits abandonment and mill refuse 

disposal site preparation. June 1980. Addison, IL:Warzyn Engineering, Inc.