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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