If promulgated as proposed, effluent guidelines for the U.S. pulp and paper industry will impose average monthly and maximum daily numerical limits of discharged AOX (adsorbable organic halogen). At this time, it is unclear whether the maximum-day variability factor used to establish the proposed effluent guidelines will provide sufficient margin for mills to achieve compliance during periods of normal but variable operating conditions within the pulping and bleaching processes. Consequently, additional information is needed to relate transient AOX loadings with final AOX discharges. This paper presents a simplistic dynamic model of AOX decay during treatment. The model consists of hydraulic characterization of an activated sludge process and a first-order decay coefficient for AOX removal. Data for model development were acquired by frequent collection of influent and effluent samples at a bleach kraft mill during a bleach plant shutdown and startup sequence.

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