United States
Environmental Protection
Agency
Office of Water
Mail Code 4303
EPA-821-P93-004
November, 1993
FACT SHEET
PROPOSED EFFLUENT LIMITATIONS GUIDELINES AND
NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR
POLLUTANTS FOR THE PRODUCTION OF PULP, PAPER,
AND PAPERBOARD ~ OVERVIEW
BACKGROUND
The pulp and paper industry is one of the nation's largest industries. The U. S. Environmental
Protection Agency (EPA) estimates that there are approximately 565 manufacturing facilities located in 42
states. These facilities comprise either integrated pulp and paper mills, where pulp is manufactured on-stte
from virgin wood fiber, secondary fiber, or non-wood fiber, and paper or paperboard products are produced
from the pulp; and non-integrated paper mills where only paper or paperboard products are manufactured
from purchased pulp or pulp produced elsewhere. The facilities are owned by about 200 companies with
combined 1989 sales revenues of $65 billion for the industry. Pulp and paper mills consume large amounts
of wood products and, in 1992, generated over one and one-half trillion gallons of wastewater. Although
the quality of discharges is improving, production results in large amounts of pollutants discharged to the air
and to surface waters. The industry also generates large amounts of sludge as a product of waste
treatment.
The proposed regulation will provide important improvements in protecting human health and the
environment by reducing toxic and hazardous pollutant releases to all media. EPA estimates the integrated
rule will result in annual reductions of:
120,000 tons of hazardous air pollutants
716,000 tons of volatile organic chemicals (air)
2,800 tons of toxic water pollutants
200,000 tons of conventional water pollutants
Dioxin/furan in discharges to water and in sludge
INTEGRATED REGULATIONS
For the first time, EPA is proposing an
integrated regulation that includes guidelines and
standards to control the release of pollutants to
the water and to the air from one industry. The
regulations are being proposed jointly to provide
greater protection to human Health and the
environment and to reduce industry's cost of
complyingwrth the pollution control requirements.
By jointly proposing the air and water
requirements, EPA is promoting the concept of
pollution prevention and at the same time enabling
the industry to more effectively plan compliance
strategies. The integrated approach emphasizes
the multimedia nature of pollution control and
enables each facility to consider all requirements in
determining pollution control approaches. If
implemented, the proposed rule would greatly
reduce the amount of pollution entering the
environment through a combination of:
• Technologies that prevent many pollutants from
being created in the first place;
• Technologies that control the discharge of the
pollutants that are created; and
* Requirements for good
practices
ENVIRONMENTAL CONTROLS
"housekeeping"
Congress requires EPA to regulate
discharges to the air and water and has provided
specific legislation on how industrial discharges
are to be regulated. Under the authority of the
Clean Water Act, EPA develops effluent guidelines
for major industries. These guidelines are used for
setting discharge limits for specific facilities that
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discharge to surface waters or municipal sewage
treatment systems. Under the authority of the
Clean Air Act, EPA develops emission standards
for air pollutants for major sources of air
pollutants.
DISCHARGES TO WATER
EPA is proposing effluent limitations to
control toxic, conventional, and nonconventional
pollutants at both existing and new facilities that
discharge wastewater either directly to a surface
water or to a municipal sewage treatment system.
The effluent guidelines portion of the proposed
regulation will apply to mills in the U.S. that
produce pulp, paper, or paperboard as a final
product.
EMISSIONS TO AIR
EPA is proposing National Emission
Standards for Hazardous Air Pollutants
(NESHAP) that will apply to existing and new
sources of air emissions. These industry-specific
standards limit air emissions of any of 189
hazardous air pollutants.
The NESHAP portion of the proposed
regulation applies only to the pulping, bleaching,
and evaporation areas of approximately 160 mills
in the U.S. that produce pulp by chemically
processing virgin wood as the fiber source. These
160 mills are a subset of the mills subject to the
effluent guidelines. EPA plans to propose
NESHAP for the recovery loop and combustion
sources at these mills in late 1994 and promulgate
all of the standards in late 1995.
DEVELOPMENT OF THE REGULATIONS
The proposal date is tied to a consent
decree involving EPA, the Environmental Defense
Fund, and the National Wildlife Federation. The
consent decree requires the EPA to propose
effluent limitations for 104 pulp and paper mills to
address discharges of dioxin and furan (which are
both known carcinogens) by October 31, 1993.
The regulations were developed by EPA
through an open process involving meetings with
environmental groups, the regulated community,
and other interested parties. Five public meetings
were held between September 1992 and June
1993. EPA will be soliciting comments for 90
days (from the date the proposed regulation
appears in the Federal Register!.
REQUIREMENTS OF THE REGULATION
Although EPA established the proposed
effluent limitations and the air emission standards
based upon specific technologies, mills may
choose their own control technologies and
process change combinations to meet these
regulations. The proposed effluent guidelines
portion of the regulations separates the pulp and
paper industry into 12 groups, known as
subcategories, based upon either the method in
which the pulp is created or the type of paper or
paperboard product produced.
EFFLUENT GUIDELINES FOR CONVENTIONAL
POLLUTANTS
The proposed effluent guidelines set
limitations on conventional pollutants for all 12
subcategories of the industry. Conventional
pollutants controlled include biochemical oxygen
demand and total suspended solids. This portion
of the regulation will require all mills to meet
conventional pollutant limitations at least as good
as the level that the best 50 percent of the mills in
each subcategory are currently achieving.
EFFLUENT GUIDELINES FOR TOXIC
AND NONCONVENTIONAL POLLUTANTS
The proposed effluent guidelines set
limitations on specific toxic and nonconventional
pollutants for the 12 industry subcategories.
These limitations are based on the best available
technology economically achievable.
Limitations on nonconventional pollutants
(such as adsorbable organic halides, chemical
oxygen demand, and color) will apply at the point
where the effluent is discharged from the
millproperty.
Toxic pollutants (such as chloroform,
methylene chloride, and some chlorinated phenolic
compounds) will have limitations set in the
effluent from bleach plants, which are located
inside mill areas. Effluent limitations for two toxic
pollutants, chlorinated dioxins and furans, are
included in the proposed regulations for four
subcategories. These pollutants will have
limitations on the end-of-pipe effluent where the
effluent is discharged from the property.
In addition to limits on in-process
pollutants, mills that 4*se chemicals in the pulping
area will be required to implement good
housekeeping procedures to prevent and .contain
spills.
EFFLUENT GUIDELINES - POLLUTION
PREVENTION
The proposed effluent limitations for toxic
compounds are based on process changes in the
pulping and bleaching areas on these mills.
Changes in the pulping area include improved
uniformity of wood chips and better washing of
the pulp prior to bleaching. These changes reduce
the amount of bleaching chemicals required.
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Changes in the bleaching area include removing
the llgnin from the washed pulp using oxygen and
partially or totally substituting elemental chlorine
with other chlorinated chemicals. These changes
would reduce the amount of discharges of
dioxins, furans, chlorinated phenolics and other
compounds in discharges.
AIR EMISSION STANDARDS
The air emission standards address the
emission points that offer thebest opportunity for
integration with the effluent guideline; that is,
noncombustion points at mills that chemically pulp
wood fiber. They would not, however, regulate all
hazardous air pollutant emission points within the
source category.
The major hazardous air pollutants
(HAP's) emitted from the processes that would
be controlled by the standards include methanol,
hexane, toluene, methyl ethyl ketone, chlorine,
chloroform, formaldehyde, acrolein, and
acetakJehyde.
Many of the HAP's emitted from the pulp
and paper source category are also volatile
organic compounds (VOC's). These substances
are precursors to smog formation. Although the
air emission standards do not require control of
VpC emissions, the control technologies upon
which these standards are based also significantly
reduce VOC emissions. Air emissions of total
reduced sulfur (TRS) compounds from pulping
processes and process wastewater streams are
also controlled along with the HAP's and VOC's.
TRS compounds are a source of foul odors.
MACT FLOOR
Emission standards for new and existing
sources promulgated under the Clean Air Act must
represent the maximum degree of emission
reduction achievable, or the MACT. The Clean Air
Act establishes minimum levels, often referred to
as the MACT floor, for NESHAP.
EPA relied on an industry survey to
determine which control technologies were being
used in the industry and the extent to which they
are being used. EPA used this information to
establish the MACT floor for existing and new
sources.
COST AND IMPACT OF THE RULE
The total annualized cost to the industry is
estimated by EPA to be $600 million. EPA
estimates that the capital investment cost (which
include purchase price of capital equipment and
installation services) to meet the proposed
standards will be approximately $4 billion. Annual
operation and maintenance costs associated with
the capital equipment installed to meet the
standard will be $400 million.
EPA's economic analysis suggests that
the rule will be affordable for most companies.
EPA estimates that the compliance costs could
result in 11-13 plant closures (est. 5% of the total
number of plants) and between 2,800 -10,700 job
losses (est. <1%-4% of the total number of jobs
in the industry). The impact on consumers will be
small for most products. The greatest market
price change for consumers may be an increase of
less than 3% for uncoated free sheet (i.e., copy
and tablet paper).
ENERGY IMPACTS
According to the U.S. Department of
Energy, the pulp and paper industry is the fourth
largest industrial user of energy, accounting for
almost 10% of total U.S. industrial energy
consumption. Compliance with the proposed
regulations is anticipated to increase the industry's
energy usage by less than one percent. Among
the reasons for this increase are the energy
requirements for process equipment upgrades,
treatmentsystem upgrades, and equipment
upgrades that will be necessary. However,
compliance is anticipated to partially offset the
increase in energy usage industry-wide because of
the energy value of some
of the recovered material.
There are several other energy-related
impacts associated with the proposed rule.
Among the most important are reductions in the
volume of water discharged at many facilities and
the mass of wastewater treatment sludge
generated. The estimated reduction in water
usage for the industry is 1.2 billion liters per year.
The amount of industrial sludge produced as a
result of implementation of the rule will increase by
52,000 metric tons per year.
The quantity of bleaching chemicals used
in the industry is likely to change. Quantities of
hypochlorite, chlorine, and sodium hydroxide are
expected to decrease while quantities of chlorine
dioxide, oxygen, hydrogen peroxide, and ozone
are expected to increase. However, overall
chemical usage in the industry would
decline resulting in cost savings.
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