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POLLUTION PREVENTION ASSESSMENT AND IMPLEMENTATION
AT A PULP AND PAPER MILL
Introduction
The Industrial Pollution Prevention Project (IPS) conducted one of its four regional
demonstration projects in the Pacific Northwest at a pulp and paper mill. The purpose of this
demonstration project was to (1) demonstrate pollution prevention opportunity assessment and
implementation at a specific pulp and paper mill in Tacoma, Washington; (2) develop a model
pollution prevention (P2) plan for use by other similar mills; and (3) provide a bibliography of
publications related to pollution prevention for the pulp and paper industry,. The project also sought
to demonstrate the use of the model P2 plan in permit writing and in the; enforcement settlement
process in other locations in the Pacific Northwest.
The demonstration began in late 1991 and involved conducting a detailed pollution
prevention opportunity assessment and developing a P2 implementation plan to be implemented by
the facility. The site for the demonstration was the Simpson Tacoma Kraft Company in Tacoma,
Washington. In addition to the P2 assessment and implementation plan developed specifically for
the Simpson Tacoma Kraft Company, a model P2 plan was also developed to be used with other
pulp and paper facilities in developing their own P2 plans.
The pulp and paper industry was selected for this Pacific Northwest regional demonstration
because of the number of pulp and paper facilities in the region and their contribution to multi-media
pollution loads and waste streams. U.S. EPA's Region 10 Office (in Seattle) sought to gain from the
demonstration ideas on integrating pollution prevention into their efforts with other pulp and paper
facilities throughout the region.
The pulp and paper industry was selected also because effluent guidelines for that industry
were being developed by U.S. EPA and because of the pulp and paper industry's involvement in
other major environmental programs administered by U.S. EPA.
The Simpson Tacoma Assessment and Implementation Plan
The Simpson Tacoma Kraft Company operates a kraft pulp and paper mill in Tacoma,
Washington producing natural and bleached pulp, kraft paper, and bleached kraft paper used
primarily for white and white-top liner board, natural bags, sacks, and similar food and industrial
grade packaging products. The fiber supply is principally Douglas fir, alder, and western hemlock
chips purchased from captive lumber yards and sawmills and on the open market. Wood chips are
received by barge, rail, and truck and stored on site.
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Production capacity is about 1,200 air-dried tons per day of pulp and paper products; as such,
the mill is classified as a medium-to-large operation. Depending on market conditions, about one-
third of the pulp produced is bleached. Simpson Tacoma has also installed a hydropulper for
processing recycled newspapers and double-lined kraft cuttings. The hydropulper has a capacity of
100 tons per day.
The U.S. EPA in cooperation with the Simpson Tacoma Kraft Company and the Washington
State Department of Ecology conducted a study of the opportunities for pollution prevention at the
company's Tacoma mill. The assessment identified and evaluated feasible process alternatives for
implementation by reviewing major process areas and equipment at the mill using on-site
observations, interviewing plant personnel, and evaluating emission and discharge estimates from
the Toxics Release Inventory (TRI) data.
Table 1 summarizes the P2 alternatives identified as feasible from the opportunity
assessment. The cost estimates for these projects range from several thousand dollars to several
million dollars. Information presented in the table includes description of the alternative, estimated
pollution reduction benefits, approximate cost, and suggested priority for implementation.
Recommendations were made to Simpson Tacoma to develop an ongoing P2 program and
implement near-term and long-term process modifications to attain P2 benefits.
The recommended near-term options, for implementation within 1 to 5 years, included:
(an asterisk (*) denotes the highest priority recommendations)
fugitive dust control for chip piles *
stormwater control related to chip piles
indirect heat exchangers on batch digesters *
utilization of boiler ashes and slaker grits *
exhaust smelt tank vents to No.7 power boiler
expansion of the non-condensible gas system *
black liquor spill prevention and recovery *
improved water conservation and reuse for the paper machines and pulp dryers *
improved steam condensate recovery for the paper machines and pulp dryers
ammonia discharge control
save-alls on pulp dryers
replacement of PCB-containing transformers *
asbestos removal *
increased bulk and semi-bulk purchases to eliminate drums *
minimization of miscellaneous hazardous wastes *
improved steam condensate recovery throughout the mill
improved water conservation and reuse throughout the mill *
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The recommended long-term options, for implementation within 5 to 10 years, included:
expansion of mill capacity with addition of secondary fiber
replacement of existing batch digester kraft capacity with addition of secondary fiber
replacement of No.2 and No.3 brownstock washers
upgrading or replacement of No.3 recovery boiler
new MCC (modified continuous cooking) digester for bleached stock
addition of oxygen delignification
operation of bleach plant at 100% chlorine dioxide substitution
installation of chip thickness screens
steam stripping of foul condensates or incineration in power boiler.
The P2 assessment and implementation plan for Simpson Tacoma also points out and
discusses the importance of and how to establish:
management commitment to P2
having a corporate framework for P2 (e.g., a P2 Committee)
incorporation of P2 within the company's planning processes (capital
appropriation and budgeting) as well as operating plans
an environmental auditing program
a tracking system for P2 successes
P2 awareness among company employees
Results
Simpson Tacoma has already implemented many P2 measures and is in the active process
of implementing many more. These include 11 of the recommended near-term options and 4 of the
recommended long-term options. The investment cost for all the measures implemented to date
totals over $100 million. Most of the major expenditures have been for process or utility system
upgrades that provide significant P2 benefits as well as product quality and resource utilization
benefits. For example, installation of the No.4 brownstock washer and associated screening and
deknotting systems and the new bleach plant resulted in substantial reduction in bleach plant
chemical consumption and the amounts of chlorinated compounds generated, while yielding
bleached pulp of higher quality suitable for a wider range of markets than would otherwise have been
possible. Installation of the No.7 power boiler resulted in significant atmospheric emission
reductions and improved resource utilization through enhanced combustion efficiency. Most of the
less expensive measures were primarily focused on water conservation.
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The generation of chloroform at Simpson Tacoma has been significantly reduced with
operation of the new bleach plant and elimination of the use of sodium hypochlorite as a bleaching
agent. The results demonstrate that formation of chloroform can nearly be eliminated if elemental
chlorine is replaced with chlorine dioxide for pulp bleaching in the first bleaching stage. (A short
technical description of the Simpson Tacoma mill's chlorine dioxide substitution results is an
appendix to the EPA published document referred to at the end of this section.)
Current operating practice at Simpson Tacoma is to operate at an average 85% chlorine
dioxide substitution rate for most grades and at 100% substitution for selected products. Simpson
Tacoma's P2 effort reduced dioxin to non-detect levels and AOX and chloroform by 80% and 90%
respectively.
In many cases, Simpson Tacoma has also realized cost savings from the pollution prevention
efforts. For example, water consumption savings of 2.9 mgd from reuse of evaporator condensates
result in an annual savings of about $300,000. The investment cost for that measure was only
$100,000.
Simpson Tacoma's pollution prevention accomplishments to date reflect what can be
achieved at basic industries involved in processing large amounts of raw materials. The major P2
benefits will accrue as production processes and utility operations are modernized and upgraded.
While such projects involve investment of many millions of dollars, they can result in order-of-
magnitude reductions in emissions, discharges, and generation of wastes.
Besides the several P2 measures already so successfully implemented, Simpson Tacoma
will be implementing additional measures over the coming years. One of the most significant long-
term recommendations, expansion of mill capacity with addition of recycle fiber, is presently under
construction. This $59 million project will result in the production of 400 tons per day of recycle
fiber and supplant a comparable quantity of chemically produced pulp. Through implementation of
this recommendation, significant multi-media P2 benefits will be realized. It is clear that Simpson
Tacoma's P2 efforts will continue to be an ongoing program.
Simpson Tacoma's P2 implementation plan, containing a commitment to make both near-
term and long-term process modifications, will be used by Simpson Tacoma and the Washington
State Department of Ecology as a partial fulfillment of the State's requirement for a pollution
prevention plan under the State's hazardous waste law. U.S. EPA will use the plan as an example
of a successful P2 plan for the pulp and paper industry.
This "Simpson Tacoma Assessment and Implementation Plan" aspect of this IPS
demonstration project is documented in the EPA publication:
Pollution Prevention Opportunity Assessment and Implementation Plan: For Simpson
Tacoma Kraft Company (EPA 910/9-92-027 August 1992).
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Model P2 Plan
The project also developed, for use at other mills, a model P2 plan for pulp and paper mills:
Model Pollution Prevention Plan for the Kraft Segment of the Pulp and Paper
Industry (EPA 910/9-92-030 September 1992).
The model P2 plan provides a generic process-by-process assessment of pollution prevention
opportunities for the kraft segment of the pulp and paper industry. The pirocess areas covered are:
woodyard operations
pulping and chemical recovery
pulp bleaching
pulp drying and papermaking
wastewater treatment
For each specific P2 option within each process area, the model P2 plan provides a:
description
cost estimate
discussion of applicability
estimate of environmental benefits
list of references
This model P2 plan also presents an organizational and management framework for
establishing a P2 program at a mill, describing the importance of:
management commitment
the establishment of a P2 team ;
tracking the performance of P2 measures after implementation.
Results
The primary reason for developing the model P2 plan was so that it could be used by other
pulp and paper mills. The model P2 plan has been made widely available, especially in the Pacific
Northwest, and has indeed been used by other pulp and paper mills.
Another reason for developing the model P2 plan was so that the model P2 plan could be
used, not only by other pulp and paper mills, but also by permit writers and by those involved in the
settlement of enforcement cases. The model P2 plan does contain much useful information for
permit writers and enforcement personnel, and numerous copies were distributed, especially in the
Pacific Northwest. Permit writers and those involved in enforcement settlements have indeed used
it, and it has proved to be very useful.
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Bibliography
This IPS demonstration project also produced an extensive, annotated bibliography on
pollution prevention for the kraft pulp and paper industry:
Pollution Prevention for the Kraft Pulp and Paper Industry: Bibliography
(EPA 910/9-92-031 September 1992)
It is organized by process area, as follows:
Chip Preparation
Chemical Pulping
Pulp Washing
Bleaching
Chemical Recovery
Recausticizing
Power Generation
Wastewater Treatment
Papermaking
General Plant
The document contains 269 citations. Each citation contains: title, author, reference, and a
brief synopsis.
EPILOGUE
As a result of participation in the IPS, Simpson Tacoma received very favorable local and
national recognition. This recognition resulted in benefits not originally expected by the company.
First, the company gained a fresh perspective on U.S. EPA and now sees the agency as more
man just a regulator. Simpson Tacoma now has increased confidence in dealing with the agency on
technical or process related issues. Simpson Tacoma also believes that its experience through the
IPS demonstration project has shown to other companies that EPA will work with companies in a
cooperative manner.
Second, the recognition has brought other state and federal voluntary programs to Simpson
Tacoma that have maintained the momentum of the original IPS effort. Subsequent to the IPS
demonstration at Simpson Tacoma and the company's implementation of the project's P2
recommendations, a State of Washington project on measuring pollution prevention has been
conducted at the facility. In addition, Simpson Tacoma submitted an application to U.S. EPA's
Environmental Leadership Program and was one of only 10 private companies selected nationwide!
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In light of the IPS's objective to spread the P2 ethic, it is perhaps not without significance that, under
the Environmental Leadership Program, one of Simpson Tacoma's projects will be to conduct a
supplier mentoring program whereby Simpson Tacoma will now work to help enhance the
environmental performance of its suppliers.
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Table 1
SIMPSON TACOMA KRAFT COMPANY
ADDITIONAL POLLUTION PREVENTION RECOMMENDATIONS
Project
Benefits
Estimated
Cost
Proposed
Priority
WOODYARD -CHIP HANDLING " ~ - > ! - >' '< " . < < -
1
2
3
Fugitive dust control
Stormwater control near chip unloading
station
Chip thickness screens
M Minimize dust emissions to St. Paul
waterway and Inner Commencement
Bay
L Minimize chip spillage to St. Paul
waterway and Inner Commencement
Bay
L More uniform pulp quality; less
bleach plant chemical consumption
Minor/Low
$100,000 - 1,000,000
Minor
< $100,000
Medium/High
$4 - 6,000,000
•
2
3
PULPING AND CHEMICAL RECOVERY '' " * ; '< . " - ' ' V
4
5
6
7
8
9
10
11
12
13
14
Expansion of NCG system
Replace No. 2 and 3 brownstock
washers
Black liquor spill prevention and
recovery
Steam stripping foul condensates or
incinerating emissions in the power
boiler
Expand mill capacity with addition of
secondary fiber
Replace existing batch digester kraft
capacity with secondary fiber
Exhaust smelt tank vents to No. 7
power boiler
Upgrade or replace No. 3 recovery
boiler
Now MCC digester for bleached stock
Uso indirect heaters on batch digesters
Utilization of boiler ashes (grate ash,
air heater/multiclone ash, fly ash)
M Incremental TRS reductions from
smelt tanks, liquor storage tanks and
filters
M TRS and VOC reductions;
water conservation
H TRS and VOC reductions;
BOD, reductions; WWTP efficiency
improvements;
cost savings
H TRS and VOC reductions;
water conservation
H Utilize waste material
H Utilize waste material; replace poorly
controlled kraft processes with low
pollutant generating process
M Reduce TRS emissions; reduce
particulate emissions
H Improve chemical recovery and mill
efficiency; reduce TRS and
particulate emissions
M More uniform pulp quality; less
bleach plant chemical consumption;
lower formation of chlorinated
compounds
M Condensate savings and water
conservation; lower hydraulic load on
evaporators
H Utilization of waste materials;
reduction in landfill use; more
effective use of hogged fuel; cost
savings
Medium
> $1,000,000
High
$20,000,000
Medium
>$ 1,000,000
Medium/High
$4 - 8,000,000
High
> $5,000,000
High
$10 - 12,000,000
Medium
> $1,000,000
High
$35 - 100,000,000
High
$50,000,000
Low
<$ 1,000,000
Low
<$ 1,000,000
1
2.
1
1
1
2
2
2
2
3
1
BLEACHING - ,,".-,*,> ' *> < > -~
15
16
Uso of oxygen delignif ication or
addition of bleaching or extraction
stage
Operate bleach plant at 100 % chlorine
dioxide substitution (would require
additional C1O2 generator capacity)
PULP DRYERS AND PAPER MACHINES
17
Save-alls on pulp dryers
H Reduce bleach plant chemical
consumption; reduce formation of
chlorinated compounds
M Reduced chloroform and chloro-
phenols generation; produce chlorine-
free pulp; better process control;
eliminate chlorine handling
V * " ' > ' ^"^
L Fiber recovery; water conservation
High
$15 - 20,000,000
High; Increase in
operating costs
$10,000,000
V/' < '„„ " -
Medium
> $1,000,000
2
2
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Table 1 (continued)
SIMPSON TACOMA KRAFT COMPANY
ApniTinNAI. POLLUTION PREVENTION RECOMMENDATIONS
Project
18
19
Improve steam condensate recovery
Improve water conservation and reuse
Benefits
L Condensate savings; energy savings;
reduce hot water to sewer; minimize
boiler feedwater treatment
L Water conservation; reduce hydraulic
and waste loading to WWTP
WA'STEWATERlTREATMENT .,.. "v • ', , V ' > *r Y ' ;~:- V / -'/- . '...
20
OKT«
21
22
23
24
25
26
Control ammonia addition to minimize
effluent residual
JERAL MILL OPERATIONS ,* */
Replace PCB transformers (ongoing)
Asbestos removal/renovation (ongoing)
Increase bulk/semi-bulk purchases;
eliminate drums (ongoing)
Increase steam condensate recovery
Improve water conservation and .reuse
Minimize miscellaneous hazardous
M Reduced effluent discharges of
ammonia to Inner Commencement
Bay; cost savings
M "Risk avoidance
M Risk avoidance; reduction in liability
L Risk avoidance; cost savings
L Condensate savings; energy savings;
reduce hot water to sewer; minimize
boiler feedwater treatment
L Water conservation; reduce hydraulic
and waste loading to WWTP
M Risk avoidance
Estimated
Cost
Low
< $1,000,000
Low
<$ 1,000,000
Proposed
Priority
2
1
Minor
<$ 100,000
Medium
>$ 1,000,000
Medium - High
>$ 1,000,000
Minor
<$ 100,000
.Low
<$ 1,000,000
Medium
>$ 1,000,000
Minor
2
3
3
1
2
1
1
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