,<.»""'•"•<.,
'** \Profile of The
.2SZ/ Pulp And Paper Industry,
*""°" 2nd Edition
EPA Office of Compliance Sector Notebook Project
SECTOR
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Pulp and Paper Industry
Sector Notebook Project
EPA/310-R-02-002
EPA Office of Compliance Sector Notebook Project
Profile of the Pulp and Paper Industry
2nd Edition
November 2002
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
1200 Pennsylvania Avenue, NW (MC 2224-A)
Washington, DC 20460
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Pulp and Paper Industry
Sector Notebook Project
This report is one in a series of volumes published by the-U.S. Environmental Protection Agency
(EPA) to provide information of general interest regarding environmental issues associated with
specific industrial sectors. The documents were developed under contract by Abt Associates
(Cambridge, MA), GeoLogics Corporation (Alexandria, VA), Science Applications International
Corporation (McLean, VA), and Booz-Allen & Hamilton, Inc. (McLean, VA). A listing of available
Sector Notebooks is included on the following page.
Obtaining copies:
Electronic versions of all sector notebooks are available on the EPA's website at:
www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/.
Purchase printed bound copies from the Government Printing Office (GPO) by consulting the
order form at the back of this document or order via the Internet by visiting the U.S. Government
Online Bookstore at: http://bookstore.gpo.gov/. Search using the exact title of the document "Profile
of the XXXX Industry" or simply "Sector Notebook." When ordering, use the GPO document
number found in the order form at the back of this document.
A limited number of complimentary volumes are available to certain groups or subscribers,
including public and academic libraries; federal, state, tribal, and local governments; and the media
from EPA's National Service Center for Environmental Publications at 800-490-9198 or
www.epa. pov/ncepihom. When ordering, use the EPA publication number found on the following
page.
The Sector Notebooks were developed by the EPA's Office of Compliance. Direct general
questions about the Sector Notebook Project to:
Coordinator, Sector Notebook Project
US EPA Office of Compliance
1200 Pennsylvania Ave., NW (2224-A)
Washington, DC 20460
202-564-2310
For further information, and for answers to questions pertaining to these documents, please refer to
the contact names listed on the following page.
Sector Notebook Project
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Sector Notebook Project
AVAILABLE SECTOR NOTEBOOKS
Questions and comments regarding the individual documents should be directed to Compliance Assistance
and Sector Programs Division at 202 564-2310 unless otherwise noted below. See the Notebook web page
at: http://www.epa.gov/compliance/reiSources/pubtications/assistance/sectors/notebooks/ for the most
recent titles and links to refreshed data.
EPA Publication
Number
EPA/310-R-95-001.
EPA/310-R-95-002.
EPA/3IO-R-95-003.
EPA/310-R-95-004.
EPA/310-R-95-005.
EPA/310-R-95-006.
EPA/310-R-95-007.
EPA/310-R-95-008.
EPA/310-R-95-009.
EPA/3IO-R-95-010.
EPA/310-R-95-011.
EPA/310-R-02-001.
EPA/310-R-95-013.
EPA/310-R-95-014.
EPA/310-R-02-002.
EPA/310-R-95-016.
EPA/310-R-95-017,
EPA/310-R-95-018.
EPA/310-R-97-001.
EPA/310-R-97-002.
EPA/310-R-97-003.
EPA/310-R-97-004.
EPA/310-R-97-005.
EPA/310-R-97-006.
EPA/3IO-R-97-007.
EPA/310-R-97-008,
EPA/310-R-97-009.
EPA/310-R-97-010.
EPA/310-R-98-001.
EPA/310-R-00-001.
EPA/310-R-00-002.
EPA/310-R-00-003.
EPA/310-R-00-004.
EPA/310-R-99-001.
Industry
Profile of the Dry Cleaning Industry
Profile of the Electronics and Computer Industry*
Profile of the Wood Furniture and Fixtures Industry
Profile of the Inorganic Chemical Industry*
Profile of the Iron and Steel Industry
Profile of the Lumber and Wood Products Industry
Profile of the Fabricated Metal Products Industry*
Profile of the Metal Mining Industry
Profile of the Motor Vehicle Assembly Industry
Profile of the Nonferrous Metals Industry
Profile of the Non-Fuel, Non-Metal Mining Industry
Profile of the Organic Chemical Industry, 2nd Edition*
Profile of the Petroleum Refining Industry
Profile of the Printing Industry
Profile of the Pulp and Paper Industry, 2nd Edition
Profile of the Rubber and Plastic Industry
Profile of the Stone, Clay, Glass, and Concrete Ind,
Profile of the Transportation Equipment Cleaning Ind.
Profile of the Air Transportation Industry
Profile of the Ground Transportation Industry
Profile of the Water Transportation Industry
Profile of the Metal Casting Industry
Profile of the Pharmaceuticals Industry
Profile of the Plastic Resin and Man-made Fiber Ind.
Profile of the Fossil Fuel Electric Power Generation Industry
Profile of the Shipbuilding and Repair Industry
Profile of the Textile Industry
Sector Notebook Data Refresh-1997 **
Profile of the Aerospace Industry
Profile of the Agricultural Crop Production Industry
Contact: Ag Center, (888) 663-2155.
Profile of the Agricultural Livestock Production Industry
Contact: Ag Center, (888) 663-2155
Profile of the Agricultural Chemical, Pesticide and Fertilizer Industry
Contact: Agriculture Division, 202 564-2320
Profile of the Oil and Gas Extraction Industry
Government Series
Profile of Local Government Operations
Spanish translations available of Is' Editions in electronic format only.
This document revises compliance, enforcement, and toxic release inventory data for all previously published
profiles. Visit the Sector Notebook web page to access the most current data.
Sector Notebook Project
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DISCLAIMER
This Sector Notebook was created for employees of the U.S. Environmental Protection Agency
(EPA) and the general public for informational purposes only. This document has been extensively
reviewed by experts from both inside and outside the EPA, but its contents do not necessarily reflect
the views or policies of EPA or any other organization mentioned within. Mention of trade names
or commercial products or events does not constitute endorsement or recommendation for use. In
addition, these documents are not intended and cannot be relied upon to create any rights,
substantive or procedural, enforceable by any party in litigation with the United States.
Sector Notebook Project
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Pulp and Paper Industry
(SIC 2611 through 2631)
TABLE OF CONTENTS
LIST OF ACRONYMS viii
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT 1
A. Summary of the Sector Notebook Project 1
B. Additional Information 2
II. INTRODUCTION TO THE PULP AND PAPER INDUSTRY .,. 3
A. Introduction, Background, and Scope of the Notebook 3
B. Characterization of the Pulp and Paper Industry 6
1. Product Characterization 6
2. Industry Size and Geographic Distribution 9
3. Economic Trends 11
III. INDUSTRIAL PROCESS DESCRIPTION 15
A. Industrial Processes in the Pulp and Paper Industry 15
I. Pulp Manufacture 18
2. Pulp Processing 25
3. Bleaching 30
4. Stock Preparation 33
5. Processes in Paper Manufacture 33
6. Energy Generation 34
B. Raw Material Inputs and Pollution Outputs in the Production Line 35
IV. CHEMICAL RELEASE AND OTHER WASTE MANAGEMENT PROFILE 45
A. EPA Toxics Release Inventory For the Pulp and Paper Industry 48
B. Summary of Selected Chemicals Released 54
C. Other Data Sources 57
D. Comparison of Toxic Release Inventory Between Selected Industries 59
V. POLLUTION PREVENTION OPPORTUNITIES 62
VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS 68
A. General Description of Major Statutes 68
B. Industry Specific Requirements 85
C. Pending and Proposed Regulatory Requirements 93
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VII. COMPLIANCE AND ENFORCEMENT HISTORY 95
A. Pulp and Paper Industry Compliance History 99
B. Comparison of Enforcement Activity Between Selected Industries 101
C. Review of Major Legal Actions 106
1. Review of MajorCases 106
2. Supplementary Environmental Projects 108
VIII. COMPLIANCE ACTIVITIES AND INITIATIVES 110
A. Sector-Related Environmental Programs and Activities 110
B. Trade Association/Industry Sponsored Activities 114
1. Environmental Programs 114
2. Summary of Trade Associations 116
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY 119
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LIST OF FIGURES
Figure 1: Pulp Production, 2000 8
Figure 2: Employment and Value of Shipments in the Paper and Allied Products Industry ... 10
Figure 3: Geographic Distribution of Pulp, Paper, and Paperboard Mills 10
Figure 4: Capital Improvements at Pulp and Paper Mills 13
Figure 5: Paper Recovery Rates 14
Figure 6: Simplified Flow Diagram: Integrated Mill 17
Figure 7: The Kraft Pulping Process (with Chemical Recovery) 29
Figure 8: Typical Bleach Plant 32
Figure 9: Fourdrinier Paper Machine 34
Figure 10: Kraft Process Flow Diagram 43
Figure 11: Air Pollutant Output from Kraft Process 44
Figure 12: 2000 Summary of TRI Releases and Transfers by Industry 60
LIST OF TABLES
Table 1: SIC andNAICS Codes 5
Table 2: Description of Pulping Processes 6
Table 3: Size of Paper and Allied Products Facilities ; 9
Table 4: Major Pulp and Paper Mergers and Acquisitions 12
Table 5: General Classification of Wood Pulping Processes 18
Table 6: Pulp Manufacturing Process Sequence 19
Table 7: Relative Wastepaper Usage as Secondary Fiber in 1999 21
Table 8: Common Chemicals Used in Elemental Chlorine Free (ECF) and Total Chlorine Free
(TCP) Bleaching Processes 31
Table 9: Paper and Paperboard Making Process 33
Table 10: Estimated Energy Sources for the U.S. Pulp and Paper Industry 35
Table 11: Potential Water Pollutants From Pulp and Paper Processes 37
Table 12: Common Air Pollutants From Pulp and Paper Processes 38
Table 13: Kraft Chemical Pulped Bleached Paper Production 41
Table 14: 2000 TRI Releases for Pulp and Paper Facilities 50
Table 15: 2000 TRI Transfers for Pulp and Paper Facilities 52
Table 16: Ten Largest Volume TRI Releasing Facilities in the Pulp and Paper Industry 54
Table 17: Air Pollutant Releases by Industry Sector (tons/year) 58
Table 18: Toxics Release Inventory Data for Selected Industries 61
Table 19: Applicability of Clean Water Act Requirements 89
Table 20: Five-Year Enforcement and Compliance Summary for the Pulp and Paper Industry,
by Region 100
Table 21: Five-Year Enforcement and Compliance Summary for Selected Industries 102
Table 22: Two-Year Enforcement and Compliance Summary for Selected Industries 103
Table 23: Five-Year Inspection and Enforcement Summary by Statute for Selected Industriesl04
Table 24: Two-Year Inspection and Enforcement Summary by Statute for Selected Industries 105
Table 25: FY-1996-1999 Supplemental Environmental Projects Overview 109
Sector Notebook Project
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LIST OF ACRONYMS
AFS AIRS Facility Subsystem (CAA database)
AIRS Aerometric Information Retrieval System (CAA database)
AOR Area of Review (SDWA)
AOX Adsorbable Organic Halides
BAT Best Available Technology Economically Achievable
BCT Best Conventional Pollutant Control Technology
BIFs Boilers and Industrial Furnaces (RCRA)
BMP Best Management Practice
BOD Biochemical Oxygen Demand
BPT Best Practicable Technology Currently Available
CAA Clean Air Act
CAAA Clean Air Act Amendments of 1990
CERCLA Comprehensive Environmental Response, Compensation and Liability Act
CERCLIS CERCLA Information System
CFCs Chlorofluorocarbons
CFR Code of Federal Regulations
CGP Construction General Permit (CWA)
CO Carbon Monoxide
C02 Carbon Dioxide
COD Chemical Oxygen Demand
CSI Common Sense Initiative
CWA Clean Water Act
CZMA Coastal Zone Management Act
D&B Dun and Bradstreet Marketing Index
DOC United States Department of Commerce
EIS Environmental Impact Statement
EPA . United States Environmental Protection Agency
EPCRA Emergency Planning and Community Right-to-Know Act
ESA Endangered Species Act
FIFRA Federal Insecticide, Fungicide, and Rodenticide Act
FINDS Facility Indexing System
FR Federal Register
FRP Facility Response Plan
HAPs Hazardous Air Pollutants (CAA)
HSDB Hazardous Substances Data Bank
HSWA Hazardous and Solid Waste Amendments
IDEA Integrated Data for Enforcement Analysis
LDR Land Disposal Restrictions (RCRA)
LEPCs Local Emergency Planning Committees
MACT Maximum Achievable Control Technology (CAA)
MCLGs Maximum Contaminant Level Goals
MCLs Maximum Contaminant Levels
MEK Methyl Ethyl Ketone
MSDSs Material Safety Data Sheets
Sector Notebook Project
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MSGP Multi-Sector General Permit (CWA)
NAAQS National Ambient Air Quality Standards (CAA)
NAFTA North American Free Trade Agreement
NAICS North Americal Industrial Classification System
NCDB National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP National Oil and Hazardous Substances Pollution Contingency Plan
NEC Not Elsewhere Classified
NEIC National Enforcement Investigation Center
NEPA National Environmental Policy Act
NESHAP National Emission Standards for Hazardous Air Pollutants
NICE3 National Industrial Competitiveness Through Energy, Environment and Economics
NO2 Nitrogen Dioxide
NOI Notice of Intent
NOT Notice of Termination
NOV Notice of Violation
NOX Nitrogen Oxides
NPDES National Pollution Discharge Elimination System (CWA)
NPL National Priorities List
NRC National Response Center
NSPS New Source Performance Standards (CAA) -
OAQPS Office of Air Quality Planning and Standards
OAR Office of Air and Radiation
OECA Office of Enforcement and Compliance Assurance
OMB Office of Management and Budget
OPA Oil Pollution Act
OPPTS Office of Prevention, Pesticides, and Toxic Substances
OSHA Occupational Safety and Health Administration
OSW Office of Solid Waste
OS WER Office of Solid Waste and Emergency Response
OW Office of Water
P2 Pollution Prevention
PCS Permit Compliance System (CWA Database)
PM10 Particulate Matter of 10 microns or less
PMN Premanufacture Notice
POTW Publicly Owned Treatments Works
PSD Prevention of Significant Deterioration (CAA)
PT Total Particulates
RCRA Resource Conservation and Recovery Act
RCRIS RCRA Information System
RQ Reportable Quantity (CERCLA)
SARA Superfund Amendments and Reauthorization Act
SDWA Safe Drinking Water Act
SEPs Supplementary Environmental Projects
SERCs State Emergency Response Commissions
SIC Standard Industrial Classification
SIP State Implementation Plan
Sector Notebook Project
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S02 Sulfur Dioxide
SOX Sulfur Oxides
SPCC Spill Prevention Control and Countermeasures
STEP Strategies for Today's Environmental Partnership
SWPPP Storm Water Pollution Prevention Plan (CWA)
TOC Total Organic Carbon
TRI Toxic Release Inventory
TRIS Toxic Release Inventory System
TCRIS Toxic Chemical Release Inventory System
TSCA Toxic Substances Control Act
TSD Treatment Storage and Disposal
TSP Total Suspended Particulates
TSS Total Suspended Solids
UIC Underground Injection Control (SDWA)
USDW Underground Sources of Drinking Water (SDWA)
UST Underground Storage Tanks (RCRA)
VOCs Volatile Organic Compounds
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I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT
LA. Summary of the Sector Notebook Project
Environmental policies based upon comprehensive analysis of air, water and
land pollution (such as economic sector, and community-based approaches)
are becoming an important supplement to traditional single-media
approaches to environmental protection. Environmental regulatory agencies
are beginning to embrace comprehensive, multi-statute solutions to facility
permitting, compliance assurance, education/outreach, research, and
regulatory development issues. The central concepts driving the new policy
direction are that pollutant releases to each environmental medium (air, water
and land) affect each other, and that environmental strategies must actively
identify and address these interrelationships by designing policies for the
"whole" facility. One way to achieve a whole facility focus is to design
environmental policies for similar industrial facilities. By doing so,
environmental concerns that are common to the manufacturing of similar
products can be addressed in a comprehensive manner. Recognition of the
need to develop the industrial "sector-based" approach within the EPA Office
of Compliance led to the creation of this document.
The Sector Notebook Project was initiated by the Office of Compliance
within the Office of Enforcement and Compliance Assurance (OECA) to
provide its staff and managers with summary information for eighteen
specific industrial sectors. As other EPA offices, states, the regulated
community, environmental groups, and the public became interested in this
project, the scope of the original project was expanded. The ability to design
comprehensive, common sense environmental protection measures for
specific industries is dependent on knowledge of several interrelated topics.
For the purposes of this project, the key elements chosen for inclusion are:
general industry information (economic and geographic); a description of
industrial processes; pollution outputs; pollution prevention opportunities;
federal statutory and regulatory framework; compliance history; and a
description of partnerships that have been formed between regulatory
agencies, the regulated community and the public.
For any given industry, each topic listed above could alone be the subject of
a lengthy volume. However, in order to produce a manageable document,
this project focuses on providing summary information for each topic. This
format provides the reader with a synopsis of each issue, and references
where more in-depth information is available. Text within each profile was
researched from a variety of sources, and was usually condensed from more
detailed sources pertaining to specific topics. This approach allows for a
wide coverage of activities that can be further explored based upon the
references listed at the end of this profile. As a check on the information
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included, each notebook went through an external document review process.
The Office of Compliance appreciates the efforts of all those that participated
in this process and enabled us to develop more complete, accurate and up-to-
date summaries. Many of those who reviewed this notebook are listed as
contacts in Section IX and may be sources of additional information. The
individuals and groups on this list do not necessarily concur with all
statements within this notebook.
I.B. Additional Information
Providing Comments
OECA's Office of Compliance plans to periodically review and update the
notebooks and will make these updates available both in hard copy and
electronically. If you have any comments on the existing notebook, or if you
would like to provide additional information, please send a hard copy and
computer disk to the EPA Office of Compliance, Sector Notebook Project
(2224-A), 1200PennsylvaniaAve.,NW,Washington,DC20460. Comments
can also be sent via the Sector Notebooks web page at:
http://www.epa.gov/compliance/resources/publications/assistance/sectors/
notebooks/. If you are interested in assisting in the development of new
Notebooks, or if you have recommendations on which sectors should have
a Notebook, please contact the Office of Compliance at 202-564-2310.
Adapting Notebooks to Particular Needs
The scope of the industry sector described in this notebook approximates the
national occurrence of facility types within the sector. In many instances,
industries within specific geographic regions or states may have unique
characteristics that are not fully captured in these profiles. The Office of
Compliance encourages state and local environmental agencies and other
groups to supplement or re-package the information included in this
notebook to include more specific industrial and regulatory information that
may be available. Additionally, interested states may want to supplement the
"Summary of Applicable Federal Statutes and Regulations" section with state
and local requirements. Compliance or technical assistance providers may
also want to develop the "Pollution Prevention" section in more detail.
Sector Notebook Project
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Pulp and Paper Industry
Introduction, Background, and Scope
II. INTRODUCTION TO THE PULP AND PAPER INDUSTRY
This section provides background information on the size, geographic
distribution, employment, production, sales, and. economic condition of the
pulp and paper industry. Facilities described within the document are also
described in terms of their Standard Industrial Classification (SIC) codes.
ILA. Introduction, Background, and Scope of the Notebook
The paper and allied products industry (SIC 26) comprises two types of
facilities: pulp and paper mills that process raw wood fiber or recycled fiber
to make pulp and/or paper, and converting facilities that use these primary
materials to manufacture more specialized products such as paperboard
boxes, writing paper, and sanitary paper. Portions of this notebook present
information for all of SIC 26, but the notebook focuses primarily on the
greatest areas of environmental concern within the industry: those from
pulpmaking processes. Converting facilities are not discussed, and the
papermaking stage of the pulp and paper process is de-emphasized.
The specific industry components covered in this industry are the following:
SIC 2611. Pulp mills. Pulp mills separate the fibers of wood or from
other materials, such as rags, linters, wastepaper, and straw in order
to create pulp. Mills may use chemical, semi-chemical, or mechanical
processes, and may create co-products such as turpentine and tall oil.
This SIC code does not include pulpmaking facilities that are part of
an integrated paper or paperboard facility; those would be
categorized according to the appropriate final product. The following
are types of pulp mills included in this SIC code:
• Demking of newsprint
• Fiberpulp: made from wood, rags, wastepaper, linters, straw,
and bagasse
• Pulp mills
• Pulp: soda, sulfate, sulfite, groundwood, rayon, and
semichemical
• Rayon pulp
Wood pulp
SIC 2621. Paper mills. Paper mills primarily are engaged in
manufacturing paper from woodpulp and other fiber pulp, and may
also manufacture convertedpaperproducts. Establishments primarily
engaged in integrated operations of producing pulp and
manufacturing paper are included in this industry if primarily
shipping paper or paper products. Establishments primarily engaged
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Pulp and Paper Industry
Introduction, Background, and Scope
in manufacturing converted paper products from purchased paper
stock are classified in Industry Group 265 or Industry Group 267.
SIC 2631. Paperboard mitts. Establishments in this SIC code
primarily are engaged in manufacturing paperboard, including
paperboard coated on the paperboard machine, from wood pulp and
other fiber pulp; and may also manufacture converted paperboard
products. Establishments primarily engaged in manufacturing
converted paperboard products from purchased paperboard are
classified in Industry Group 265 or Industry Group 267.
Establishments primarily engaged in manufacturing insulation board
and other reconstituted wood fiberboard are classified in Industry
2493.
The following SIC codes are within SIC 26, but are not addressed in detail
in this document:
SIC 265 (2652-2657). Paperboard containers and boxes.
Establishments in these SIC codes are engaged in the manufacture of
corrugated and solid fiber boxes and containers from purchased
paperboard. The principal commodities of this industry are boxes,
pads, partitions, display items, pallets, corrugated sheets, food
packaging, and non-food (e.g., soaps, cosmetics, and medicinal
products) packaging.
SIC 267 (2671-2679). Miscellaneous converted paper products.
These establishments produce a range of paper, paperboard, and
plastic products with purchased material. Common products include
paper and plastic film packaging, specialty paper, paper and plastic
bags, manila folders, sanitary paper products, envelopes, stationery,
and other products.
SIC codes were established by the Office of Management and Budget (OMB)
to track the flow of goods and services within the economy. OMB has
changed the SIC code system to a system based on similar production
processes called the North American Industrial Classification System
(NAICS). Because most of the data presented in this notebook apply to the
pulp and paper industry as defined by its SIC codes, this notebook continues
to use the SIC system to define this sector. Table 1 presents the SIC codes
for the pulp and paper industry and the corresponding NAICS codes.
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Introduction, Background, and Scope
Table 1: SIC and NAICS Codes
1987
SIC
2611
2621
2631
2652
2653
2655
2656
2657
2671
2672
2673
2674
2675
2676
2677
2678
2679
SIC Description
Pulp mills
Paper mills
Paperboard mills
Setup paperboard boxes
Corrugated & solid fiber boxes
Fiber cans, drums & similar products
Sanitary food containers
Folding paperboard boxes
Paper - coated & laminated, packaging
Paper - coated & laminated, n.e.c.
Bags - plastics, laminated, & coated
Bags - uncoated paper & multiwall
Die-cut paper & board
Sanitary paper products
Envelopes
Stationery products
Converted paper products, n.e.c.
1997
NAICS
322110
322121
322122
322130
322213
322211
322214
322215
322212
322221
326112
322222
322223
326111
322224
322226
322231
322299
322121
322291
322232
322233
322222
322231
322299
NAICS Description
Pulp mills
Paper (except newsprint) mills (part)
Newsprint mills
Paperboard mills
Setup paperboard box mfg
Corrugated & solid fiber box mfg
Fiber cans, drums & similar products mfg
Nonfolding sanitary food container mfg
Folding paperboard box mfg
Coated & laminated packaging paper &
plastics film mfg
Unsupported plastics packaging film & sheet
mfg
Coated & laminated paper mfg (part)
Plastics, foil, & coated paper bag mfg
Unsupported plastics bag mfg
Uncoated paper & multiwall bag mfg
Surface-coated paperboard mfg
Die-cut paper & paperboard office supplies
mfg (part)
All other converted paper product mfg (part)
Paper (except newsprint) mills (part)
Sanitary paper product mfg (part)
Envelope mfg
Stationery, tablet, & related product mfg
Coated & laminated paper mfg (part)
Die-cut paper & paperboard office supplies
mfg (part)
All other converted paper product mfg (part)
Source: U.S. Census Bureau, 2000a.
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Pulp and Paper Industry
Introduction, Background, and Scope
II.B. Characterization of the Pulp and Paper Industry
The pulp and paper industry converts wood (harvested by logging firms in
SIC 24) or recycled fiber into pulp and primary forms of paper. Other
companies in the paper and allied products industry (SIC codes 265 and 267)
use the products of the pulp and paper industry to manufacture specialized
products including paperboard boxes, writing paper, and sanitary paper.
II.B.l. Product Characterization
The pulp and paper industry produces primary products - commodity grades
of wood pulp, printing and writing papers, sanitary tissue, industrial-type
papers, containerboard and boxboard - using cellulose fiber from timber or
purchased or recycled fibers. The two steps are pulping and paper or
paperboard manufacturing.
Pulping
Pulping is the process of dissolving wood chips into individual fibers by
chemical, semi-chemical, or mechanical methods. The particular pulping
process used affects the strength, appearance, and intended use
characteristics of the resultant paper product. Pulping is the major source of
environmental impacts in the pulp and paper industry. There are more than
a dozen different pulping processes in use in the U.S.; each pulping process
has its own set of process inputs, outputs, and resultant environmental
concerns. Table 2 provides an overview of the major pulping processes and
the main products that they produce.
Table 2: Description of Pulping Processes
Pulo Process
Dissolving Kraft
Bleached Papergrade
Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Description/Principal Products
Highly bleached and purified kraft process wood pulp suitable for
conversion into products such as rayon, viscose, acetate, and
cellophane.
Bleached or unbleached kraft process wood pulp usually converted
into paperboard, coarse papers, tissue papers, and fine papers such
as business, writing and printing.
Highly bleached and purified sulfite process wood pulp suitable for
conversion into products such as rayon, viscose, acetate, and
cellophane.
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Introduction, Background, and Scope
Table 2: Description of Pulping Processes (continued)
Pulp Process
Papergrade Sulfite
Semi-chemical
Mechanical pulp
Secondary Fiber Deink
Secondary Fiber Non-
deink
Non-wood Chemical
pulp
Description/Principal Products
Sulfite process wood pulp with or without bleaching used for
products such as tissue papers, fine papers, and newsprint.
Pulp is produced by chemical, pressure, and occasionally
mechanical forces with or without bleaching used for corrugating
medium (cardboard), paper, and paperboard.
Pulp manufacture by stone groundwood, mechanical refiner,
thermo-mechanical, chemi-mechanical, or chemi-thermo-
mechanical means for newsprint, coarse papers, tissue, molded fiber
products, and fine papers.
Pulps from recovered paper or paperboard using a chemical or
solvent process to remove contaminants such as inks, coatings and
pigments used to produce fine, tissue, and newsprint papers.
Pulp production from recovered paper or paperboard without
deinking processes to produce tissue, paperboard, molded products
and construction papers.
Production of pulp from textiles (e.g.,rags), cotton linters, flax,
hemp, tobacco, and abaca to make cigarette wrap papers and other
specialty paper products.
Source: U.S. EPA, 1993a.
The bleached and unbleached kraft processes are used to manufacture the
majority of paperproducts. Together, these processes account for 83 percent
of the pulp produced in the United States. Figure 1 presents the relative
output of the major pulping processes.
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Introduction, Background, and Scope
Figure 1: Pulp Production, 2000
{Thousand Tons)
Semichemical
3,976
Mechanical
6,501
Sulffle
1,116
Kraft - Unbleached
21,281
Kraft - Bleached
31,978
Source: AF&PA, 2001.
The pulp manufacturing process is the major source of environmental
concern for this industry. For example, a bleached kraft pulp mill requires
4,000-12,000 gallons of water and 14-20 million Btu of energy per ton of
pulp, of which roughly 8-10 million Btu typically are derived from biomass-
derived fuel from the pulping process (Pulp and Paper, 2001). Across all
facilities in SIC 26, the pulp, paper, and allied products industry is the largest
consumer of process water and the third largest consumer of energy (behind
the chemicals and metals industries) (U.S. Department of Commerce, 2000
and U.S. Department of Energy, 2000). The high use of water and energy,
as well as the chemical inputs described in Section III, lead to a variety of
environmental concerns.
Paper and Paperboard Manufacturing
The paper or paperboard manufacturing process is similar for all types of
pulp. In this process, pulp is spread out as a wet mixture, or slurry, onto a
screen. Water is removed by gravity and vacuums, and the resulting layer of
fibers is passed through a series of rollers that compress the material into
sheets. Paper and paperboard manufacturers use nearly identical processes;
the difference is that paperboard is thicker (more than 0.3 mm).
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Introduction, Background, and Scope
II.B.2. Industry Size and Geographic Distribution
The pulp and paper industry is characterized by very large facilities; of the
514 pulp and paper mills in SIC codes 261 -263 reported by the Bureau of the
Census in 1998, 343 (67 percent) have 100 or more employees. Across all
of these facilities, there are 172,000 employees who produced $59 billion in
shipments (in 1998 dollars). In 2000, the industry employed 182,000 and
produced $79 billion in shipments.
In contrast, the downstream facilities (container and specialty product
manufacturers) tend to be more numerous but smaller. More than 75 percent
of these facilities have fewer than 100 employees. Table 3 presents the
employment distribution for both pulp and paper facilities and downstream
manufacturers in 1997 (the most recent data available) as reported by the
U.S. Census Bureau. Because recent years have seen some facility closures,
the current number of facilities may be somewhat lower.
Table 3: Size of Paper and Allied Products Facilities
Industry
Pulp mills (SIC 261)
Paper mills (SIC 262)
Paperboard mills (SIC 263)
Paperboard containers and
boxes (SIC 265)
Misc. converted paper
products (SIC 267)
Employees per Facility (% of Total)
1-19
3 (7%)
6 (2%)
8 (4%)
748 (26%)
1,383 (44%)
20-99
14(34%)
63 (24%)
77 (36%)
1,311(46%)
1,116(36%)
100-499
18(44%)
107(41%)
96 (45%)
782 (27%)
597(19%)
>499
6(15%)
83 (32%)
33 (15%)
14 (<1%)
70 (2%)
Source: U.S. Census Bureau, 1998.
Figure 2 presents the employment and value of shipments for both the
primary and secondary portions of the paper and allied products industry.
Taken together, the industry is among the top 10 U.S. manufacturing
industries in value of shipments. As noted in the two graphs, the pulp and
paper portion of the industry (pulp, paper, and paperboard mills) employs
only 28 percent of the workers in the industry, but produces over 40 percent
of the shipments.
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Introduction, Background, and Scope
Figure 2: Employment and Value of Shipments in the Paper and Allied Products Industry"
Employment
Total: 609,480
Pulp mills
10,247
Use. paper products
228,967
Paper mills
107.562
Value of Shipments ($ million)
Total: 145,655
Pulp mills
4.073
Wise, paper products
46,154
Paperboard mills
54.643
Paperboard containers
208,071
Paperboard containers J
40,085
Paper mills
35.514
Paperboard mills
19,829
11 Integrated mills, which produce both pulp and paper (or paperboard), are included in the paper (or paperboard)
categories. The pulp mill category includes only facilities producing pulp for the general market.
Source: U.S. Census Bureau, 2000b.
The geographic distribution of pulp and paper mills varies according to the
type of mill. As there are tremendous variations in the scale of individual
facilities, tallies of the number of facilities may not represent the level of
economic activity (nor possible environmental consequences). Pulp mills are
located primarily in regions of the country where trees are harvested from
natural stands or tree farms: the Southeast, Northwest, Northeast, and North
Central regions. Pulp mills that process recycled fiber are generally located
near sources of waste paper. Paper mills, however, are more widely
distributed. They are located near pulping operations and/or near converting
markets. The distribution of paperboard mills reflects the location of
manufacturing in general, since such operations are the primary market for
paperboard products. Figure 3 presents the location of pulp and paper mills
in the U.S.
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Introduction, Background, and Scope
Figure 3: Geographic Distribution of Pulp, Paper, and Paperboard
Mills
A- *
ft
-•• 4
*~v#&j
p^.
N /
\ I
UK- n an >» Miii.
There are no currently active mills in Alaska or Hawaii.
Source: U.S. EPA, 1999.
II.B.3. Economic Trends
World Market Competition
The U.S. produces roughly 30 percent of the world's paper and paperboard.
The pulp and paper industry is one of the most important industries for the
balance of trade in the U.S. This trade balance increased through most of the
1990s. In 1999, exports from SIC codes 261-263 were $8.5 billion. In recent
years, however, exports have been declining and imports have been
increasing. Between 1997 and 2000, exports declined 5.5% and imports
increased by more than 20%, The declining exports and increasing imports
are partly due to a strong dollar in this period and the recent slow down of the
U.S. economy (AF&PA, 2001).
The U.S. industry has several advantages over the rest of the world market,
including modem mills, a highly skilled work force, a large domestic
market, and an efficient transportation infrastructure. Major export markets
for pulp are Japan, Italy, Germany, Mexico, and France. The U.S.
Department of Commerce anticipates exports to grow faster than production
for domestic markets through 2004. World Trade Organization (WTO)
efforts to reduce tariffs include those on pulp and paper products; if these are
successful, the U.S. industry expects pulp and paper export rates to increase
even further.
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Introduction, Background, and Scope
However, pulp and paper are commodities and therefore prices are vulnerable
to global competition. Countries such as Brazil, Chile, and Indonesia have
built modem, advanced pulp facilities. These countries have faster-growing
trees and lower labor costs. Latin American and European countries also are
adding papermaking capacity. Furthermore, the strong value ofthe dollar has
made imports less expensive relative to domestically-produced goods.
Because of this increased foreign competition, imports of paper to the U.S.
market are expected to increase three percent annually through 2004 (U.S.
Department of Commerce, 2000).
Industry Consolidation
In order to compensate for this increasingly competitive market, pulp and
paper companies have undertaken a considerable number of mergers and
acquisitions. Table 4 lists the major transactions that occurred between 1997
and 2002.
Table 4: Major Pulp and Paper Mergers and Acquisitions
Buyer
International Paper Co.
International Paper Co.
Jefferson Smurfit Corp.
Weyerhaeuser Co.
Fort Howard Corp.
Abitibi-Consolidated Inc.
Stora Enso Oy
Abitibi-Price Inc.
Westvaco
Bowater Inc.
Weyerhaeuser Co.
Madison Dearborn Industries Inc.
Acquired
Champion International Inc.
Union Camp Corp.
Stone Container Corp.
Willamette
James River Corp.
Donohue Inc.
Consolidated Papers Inc.
Stone-Consolidated Inc.
Mead
Avenor Inc.
MacMillan Bloedel Ltd.
Tenneco Packaging Inc.
Value
(million)
$9,600
$7,900
$6,400
$6,000
$5,800
$5,300
$4,800
$3,600
$3,000
$2,500
$2,450
$2,200
Year
2000
1999
1998
2002
1997
2000
2000
1997
2002
1997
1999
1999
Largest mergers and acquisitions between 1997 and mid-2000.
Source: McLaren, J et al., 2000, and Pulp & Paper International, September 2002.
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Introduction, Background, and Scope
Capital Improvements
Historically, U.S. pulp and paper companies have invested heavily in capital
improvements to their facilities. Capital investments in recent years,
however, are well below historic levels due to the difficult market conditions.
For the first time, industry capacity actually declined in 2001 (Pulp & Paper
International, 2002). Because few new mills are being built, most capital
expenditures represent plant expansions, upgrades, and environmental
protection initiatives at existing facilities. Figure 4 presents the rate of
capital investments within SIC 261 -263. Throughout the time period shown,
capital improvements related to environmental protection claimed from 4%
to 22% of the total investments with significant increases in the early and late
1990s (AF&PA, 2001).
Figure 4: Capital Improvements at Pulp and Paper Mills
Title
D Paper-board Mills (SIC 263)
M Paper Mills (SIC 262)
B Pulp Mills (SIC 261)
1965 1987 1989 1991 1993 1995 1997 1999
1986 1988 1990 1992 1994 1998 1998
Source: AF&PA, 2001.
Recycling Efforts
A major movement within the pulp and paper industry has been an increased
focus on the use of recovered paper. As shown in Figure 5, nearly 50 percent
of paper now is recovered and used either as recycled paper or as products
such as home insulation. .Furthermore, recovered paper contributes to U.S.
exports; roughly ten million tons of recovered paper were exported in 2000
(AF&PA, 2001).
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Figure 5: Paper Recovery Rates
50%
40%
30%
20%
10%
1985 1987 1989 1991 1993 1995 1997 1999
1986 1988 1990 1992 1994 1996 1998 2000
The recovery rate is the ratio of recovered paper collected to new supply of paper and
paperboard.
Source: AF&PA, 2001.
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Industrial Process Description
HI. INDUSTRIAL PROCESS DESCRIPTION
This section describes the major industrial processes within the pulp and
paper industry, including the materials and equipment used, and the
processes employed. The section is designed for those interested in gaining
a general understanding of the industry, and for those interested in the inter-
relationship between the industrial process and the topics described in
subsequent sections of this profile — pollutant outputs, pollution prevention
opportunities, and Federal regulations. This section does not attempt to
replicate published engineering information that is available for this industry.
Refer to Section IX for a list of reference documents that are available.
This section specifically contains a description of commonly used production
processes, associated raw materials, the byproducts produced or released, and
the materials either recycled or transferred off-site. This discussion, coupled
with schematic drawings of the identified processes, provides a concise
description of where wastes may be produced in the process. This section
also describes the potential fate (via air, water, and soil pathways) of these
waste products.
III.A. Industrial Processes in the Pulp and Paper Industry
Simply put, paper is manufactured by applying a watery suspension of
cellulose fibers to a screen which allows the water to drain and leaves the
fibrous particles behind in a sheet. Most modem paper products contain non-
fibrous additives, but otherwise fall within this general definition. Only a
few paper products for specialized uses are created without the use of water,
via dry forming techniques. The individual fibers formed into paper sheets
is called pulp. The production of pulp is the major source of environmental
impacts in the pulp and paper industry.
Processes in the manufacture of paper and paperboard can, in general terms,
be split into three steps: pulp making, pulp processing, and paper/paperboard
production. Paperboard sheets are thicker than paper sheets; paperboard is
thicker than 0.3 mm. In general, however, paper and paperboard production
processes are identical. First, a stock pulp mixture is produced by digesting
a material into its fibrous constituents via chemical, mechanical, or a
combination of chemical and mechanical means. In the case of wood, the
most common pulping material, chemical pulping actions release cellulose
fibers by selectively destroying the chemical bonds in the glue-like substance
(lignin) that binds the fibers together. After the fibers are separated and
impurities have been removed, the pulp may be bleached to improve
brightness and processed to a form suitable for paper-making equipment. At
the paper-making stage, the pulp can be combined with dyes, strength
building resins, or texture adding filler materials, depending on the intended
end product. Afterwards, the mixture is dewatered, leaving the fibrous
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Industrial Process Description
constituents and pulp additives on a wire or wire-mesh conveyor. Additional
additives may be applied after the sheet-making step. The fibers bond
together as they are carried through a series of presses and heated rollers.
The final paper product is usually spooled on large rolls for storage (see
Figure 6).
The following discussion focuses mainly on pulping processes due to their
importance in understanding industry environmental impacts and current
industry regulatory classification schemes. If more information on
papermaking processes is desired, fas Development Document for Proposed
Effluent Limitations, Guidelines and Standards for the Pulp and Paper
Industry, Point Source Category (EPA-821-R-93-019) is recommended.
Additional sources are listed in Section IX of this document.
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Industrial Process Description
Figure 6: Simplified Flow Diagram: Integrated Mill
(Chemical Pulping, Bleaching, and Paper Production)
COOKING
WOODYARD AND CHIPPING
FINISHING DEPARTMENT
Source: Smook, 1992.
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Industrial Process Description
11 I.A.I. Pulp Manufacture
At the pulping stage, the processed furnish (wood or other fiber source) is
digested into its fibrous constituents. The bonds between fibers may be
broken chemically, mechanically, or by a combination of the techniques
called semi-chemical pulping. The choice of pulping technique is dependent
on the type of furnish and the desired qualities of the finished product, but
chemical pulping is the most prevalent. Table 5 presents an overview of the
wood puOOlping types by the method of fiber separation, resultant fiber
quality, and percent of 1998 U.S. pulp production. Many mills perform
multiple pulping processes at the same site, most frequently non-deink
secondary fiber pulping and papergrade kraft pulping (U.S. EPA, 1993a).
The three basic types of wood pulping processes 1) chemical pulping, 2)
semi-chemical pulping, and 3) mechanical pulping are detailed below
followed by a discussion of secondary fiber pulping techniques.
Table 5: General Classification of Wood Pulping Processes
Process
Category
Mechanical
Semi-
chemical
Chemical
Fiber
Separation
Method
Mechanical
energy
Combination of
chemical and
mechanical
treatments
Chemicals and
heat
Fiber Quality
Short, weak,
unstable, impure
fibers
"Intermediate"
pulp properties
(some unique
properties)
Long, strong,
stable fibers
Examples
Stone
groundwood,
refiner mechanical
pulp
High-yield kraft,
high-yield sulfite
Kraft, sulfite, soda
% of Total
1998 US
Wood Pulp
Production
10%
6%
84%
Sources: Smook, 1992; AF&PA, 1999.
A variety of technologies and chemicals are used to manufacture pulp, but
most pulp manufacturing systems contain the process sequence shown in
Table 6.
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Industrial Process Description
Table 6: Pulp Manufacturing Process Sequence
Process Sequence
Fiber Furnish Preparation
and Handling
Pulping
Pulp Processing
Bleaching
Pulp drying and baling
(non-integrated mills)
Stock Preparation
Description
Debarking, slashing, chipping of wood logs and then
screening of wood chips/secondary fibers (some
pulp mills purchase chips and skip this step)
Chemical, semi-chemical, or mechanical breakdown
of pulping material into fibers
Removal of pulp impurities, cleaning and thickening
of pulp fiber mixture
Addition of chemicals in a staged process of
reaction and washing increases whiteness and
brightness of pulp, if necessary
At non-integrated pulp mills, pulp is dried and
bundled into bales for transport to a paper mill
Mixing, refining, and addition of wet additives to
add strength, gloss, texture to paper product, if
necessary
Overall, most of the pollutant releases associated with pulp and paper mills
occur at the pulping and bleaching stages where the majority of chemical
inputs occur.
Furnish Composition
Furnish is the blend of fibrous materials used to make pulp. According to the
J990 National Census of Pulp, Paper, and Paperboard Manufacturing
Facilities, the most commonly used furnish material is wood; it is used in
some form by approximately 95 percent of pulp and paper manufacturers.
Overall, wood ftrrnish averages approximately 50 percent of pulp content
industry-wide.
The major source of fiber for paper products comes from the vegetative
tissues of vascular plants. Although almost any vascular plant could be used
for paper production, the economics of scale require a high fiber yield for
paper manufacture. By far, the principle source of paper-making fibers in the
United States is wood from trees, the largest vascular plants available. The
fibrous particles used to make paper are made of cellulose, a primary
component of the cell walls of vascular plant tissues. The cellulose fibers
must be removed from a chemical matrix (e.g., lignin, hemicelluloses, and
resins) and result in a mixture of relatively pure fibers.
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Wood used to make pulp can arrive at the mill in a variety of forms including
wood logs, chips, and sawdust. Due to different physical and chemical
properties of different types of wood, certain pulping processes are most
efficient on specific wood types. The type of wood used can also make a
difference in the final characteristics of the pulp. In general, softwood (e.g.,
pine and spruce) fibers are longer than those from hardwood (e.g., birch and
oak) and have thinner cell walls. The longer fibers of softwood promote
inter-fiber bonding and produce papers of greater strength.
Secondary fibers comprise the next most common furnish constituent.
Secondary fibers consist of pre-consumer fibers (e.g., mill waste fibers) and
post-consumer fiber. Post-consumer fiber sources are diverse, but the most
common are newsprint and corrugated boxes (See Table 7). Although
secondary fibers are not used in as great a proportion as wood furnish,
approximately 80 percent of pulp and paper manufacturers use some
secondary fibers in their pulp production and approximately 200 mills
(approximately 40 percent of total number of mills) rely exclusively on
secondary fibers for their pulp furnish (AF&PA, 1999; AF&PA, 2000c).
Secondary fibers must be processed to remove contaminants such as glues or
bindings, but, depending on the end product, may or may not be processed
to remove ink contaminants or to brighten the pulp.
Secondary fiber use is increasing in the pulp and paper industry due to
consumer demand for products made from recycled paper. Recovered fiber
accounted for 75 percent of the industry's increase in fiber consumption
between 1990 and 2000 (AF&PA, 2000a). The utilization of secondary
fibers, expressed as the ratio of recovered paper consumption to the total
production of paper and paperboard, is at approximately 39 percent and is
climbing slowly (AF&PA, 2001). In a resource-deficient country such as
Japan, the secondary fiber utilization rate is at about 50 percent, whereas the
average utilization rate in Europe is approximately 40 percent (VDP, 1997).
Due to losses of fiber substance and strength during the recycling process, a
50 percent utilization rate is considered the present maximum overall
utilization rate for fiber recycling (Smook, 1992).
Secondary fiber sources are seldom used as feedstocks for high quality paper
products. Contaminants (e.g., inks, paper colors) are often present, so
production of low-purity products is often the most cost-effective use of
secondary fibers, although decontamination technologies are available.
Approximately 68 percent of all secondary fiber in the U.S. is presently used
for multi-ply paperboard or the corrugating paper used to manufacture
corrugated cardboard (AF&PA, 2000a). Over the next decade, an increasing
proportion of the total amount will be deinked for newsprint or other higher-
quality uses.
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Table 7: Relative Wastepaper Usage as Secondary Fiber in 1999
Paper Type
Mixed Paper
Old Newspaper
Old Corrugated Cardboard
Pulp Substitutes
High-grade Deinked
% of Total Wastepaper Usage in
1999
18%
19%
48%
6%
9%
Source: AF&PA, 2000b.
Other types of furnish include cotton rags and linters, flax, hemp, bagasse,
tobacco, and synthetic fibers such as polypropylene. These substances are
not used widely, however, as they are typically for low volume, specialty
grades of paper.
The types of furnish used by a pulp and paper mill depend on the type of
product produced and what is readily available. Urban mills use a larger
proportion of secondary fibers due to the post-consumer feedstock close at
hand. More rurally located mills are usually close to timber sources and thus
may use virgin fibers in greater proportion.
Furnish Preparation
Furnish is prepared for pulp production by a process designed to supply a
homogenous pulping feedstock. In the case of roundwood furnish (logs), the
logs are cut to manageable size and then debarked. At pulp mills integrated
with lumbering facilities, acceptable lumber wood is removed at this stage.
At these facilities, any residual or waste wood from lumber processing is
returned to the chipping process; in-house lumbering rejects can be a
significant source of wood furnish at a facility. The bark of those logs not fit
for lumber is usually either stripped mechanically or hydraulically with high
powered water jets in order to prevent contamination of pulping operations.
Depending on the moisture content of the bark, it may then be burned for
energy production. If not burned for energy production, bark can be used for
mulch, ground cover, or to make charcoal.
Hydraulic debarking methods may require a drying step before burning.
Usually, hydraulically removed bark is collected in a water flume, dewatered,
and pressed before burning. Treatment of wastewater from this process is
difficult and costly, however, whereas dry debarking methods can channel
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Industrial Process Description
the removed bark directly into a furnace (Smook, 1992). In part because of
these challenges, hydraulic debarking has decreased in significance within
the industry (Potlatch, 2002).
Debarked logs are cut into chips of equal size by chipping machines.
Chippers usually produce uniform wood pieces 20 mm long in the grain
direction and 4 mm thick. The chips are then put on a set of vibrating screens
to remove those that are too large or small. Large chips stay on the top
screens and are sent to be recut, while the smaller chips are usually burned
with the bark. Certain mechanical pulping processes, such as stone
groundwood pulping, use roundwood; however, the majority of pulping
operations require wood chips. Non-wood fibers are handled in ways
specific to their composition. Steps are always taken to maintain fiber
composition and thus pulp yield.
Chemical Pulping
Chemical pulps are typically manufactured into products that have high-
quality standards or require special properties. Chemical pulping degrades
wood by dissolving the lignin bonds holding the cellulose fibers together.
Generally, this process involves the cooking/digesting of wood chips in
aqueous chemical solutions at elevated temperatures and pressures. There
are two major types of chemical pulping currently used in the U.S.: 1)
kraft/soda pulping and 2) sulfite pulping. These processes differ primarily
in the chemicals used for digesting. The specialty paper products rayon,
viscose, acetate, and cellophane are made from dissolving pulp, a variant of
standard kraft or sulfite chemical pulping processes.
Kraft pulping (or sulfate) processes produced approximately 83 percent of
all US pulp tonnage during 2000 according to the American Forest and Paper
Association (AF&PA, 2001). The success of the process and its widespread
adoption are due to several factors. First, because the kraft cooking
chemicals are selective in their attack on wood constituents, the pulps
produced are notably stronger than those from other processes (i.e., Kraft is
German for "strength"). The kraft process is also flexible, in so far as it is
amenable to many different types of raw materials (i.e., hard or soft woods)
and can tolerate contaminants frequently found in wood (e.g., resins). Lignin
removal rates are high in the kraft process — up to 90 percent — allowing
high levels of bleaching without pulp degradation. Finally, the chemicals
used in kraft pulping are readily recovered within the process, making it very
economical and reducing potential environmental releases (See Chemical
Recovery Systems below).
The kraft process uses a sodium-based alkaline pulping solution (liquor)
consisting of sodium sulfide (Na2S) and sodium hydroxide (NaOH) in 10.
percent solution. This liquor (white liquor) is mixed with the wood chips in
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Industrial Process Description
a reaction vessel (digester). The output products are separated wood.fibers
(pulp) and a liquid that contains the dissolved lignin solids in a solution of
reacted and unreauted pulping chemicals (black liquor). The black liquor
undergoes a chemical recovery process (see Chemical Recovery Systems) to
regenerate white liquor for the first pulping step. Overall, the kraft process
converts approximately 50 percent of input furnish into pulp.
The kraft process evolved from the soda process. The soda process uses an
alkaline liquor of only sodium hydroxide (NaOH). The kraft process has
virtually replaced the soda process due to the economic benefits of chemical
recovery and improved reaction rates (the soda process has a lower yield of
pulp per pound of wood furnish than the kraft process).
Sulfite pulping was used for approximately two percent of U.S. pulp
production in 2000 (AF&PA, 2001). Softwood is the predominant furnish
used in sulfite pulping processes. However, only non-resinous species are
generally pulped. The sulfite pulping process relies on acid solutions of
sulfurous acid (H2S03) and bisulfite ion (HSO3") to degrade the lignin bonds
between wood fibers.
Sulfite pulps have less color than kraft pulps and can be bleached more
easily, but are not as strong. The efficiency and effectiveness of the sulfite
process is also dependent on the type of wood furnish and the absence of
bark. For these reasons, the use of sulfite pulping has declined in comparison
to kraft pulping over time.
Semi-chemical pulping
Semi-chemical pulping comprised six percent of U.S. pulp production in
2000 (AF&PA, 2001). Semi-chemical pulp is often very stiff, making this
process common in corrugated container manufacture. This process
primarily uses hardwood as furnish.
The major process difference between chemical pulping and semi-chemical
pulping is that semi-chemical pulping uses lower temperatures, more dilute
cooking liquor or shorter cooking times, and mechanical disintegration for
fiber separation. At most, the digestion step in the semi-chemical pulping
process consists of heating pulp in sodium sulfite (Na2S03) and sodium
carbonate (Na2CO3) Other semi-chemical processes include the Permachem
process and the two-stage vapor process. The yield of semi-chemical pulping
ranges from 55 to 90 percent, depending on the process used, but pulp
residual lignin content is also high so bleaching is more difficult.
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Mechanical pulping
Mechanical pulping accounted for nine percent of U.S. pulp production in
2000 (AF&PA, 2001). Mechanically produced pulp is of low strength and
quality. Such pulps are used principally for newsprint and other non-
permanent paper goods. Mechanical pulping relies on physical pressure
instead of chemicals to separate furnish fibers; however, chemicals are
sometimes added at the various stages of refining. Processes include: 1)
stone groundwood, 2) refiner mechanical, 3) thermo-mechanical, 4) chemi-
mechanical, and 5) chemi-thermo-mechanical. The stone groundwood
process simply involves mechanical grinding of wood in several high-energy
refining systems. The refiner mechanical process involves refining wood
chips at atmospheric pressure while the thermo-mechanical process uses
steam and pressure to soften the chips before mechanical refining. In the
chemi-mechanical process, chemicals can be added throughout the process
to aid the mechanical refining. The chemi-thermo-mechanical process
involves the treatment of chips with chemicals for softening followed by
mechanical pulping under heat and pressure. Mechanical pulping typically
results in high pulp yields, up to 95 percent when compared to chemical
pulping yields of 45- 50 percent, but energy usage is also high. To offset its
structural weakness, mechanical pulp is often blended with chemical pulp.
Secondary fiber pulping
Secondary fiber pulping accounted for 39 percent of domestic pulp
production in 2000 (AF&PA, 2001). Nearly 200 mills rely exclusively on
recovered paper for pulp furnish, and roughly 80 percent of U.S. paper mills
use recovered paper in some way (AF&PA, 2000c). In addition,
consumption of fiber from recovered paper is growing more than twice as
fast as overall fiber consumption. Secondary fibers are usually presorted
before they are sold to a pulp and paper mill. If not, secondary fibers are
processed to remove contaminants before pulping occurs. Common
contaminants consist of adhesives, coatings, polystyrene foam, dense plastic
chips, polyethylene films, wet strength resins, and synthetic fibers. In some
cases, contaminants of greater density than the desired secondary fiber are
removed by centrifugal force while light contaminants are removed by
flotation systems. Centri cleaners are also used to remove material less dense
than fibers (wax and plastic particles) (AF&PA, 1995b).
Inks, another contaminant of secondary fibers, may be removed by heating
a mixture of secondary fibers with surfactants. The removed inks are then
dispersed in an aqueous media to prevent redeposition on the fibers.
Continuous solvent extraction has also been used to recover fibers from paper
and board coated with plastics and/or waxes.
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Secondary fiber pulping is a relatively simple process. The most common
pulper design consists of a large container filled with water, which is
sometimes heated, and the recycled pulp. Pulping chemicals (e.g., sodium
hydroxide, NaOH) are often added to promote dissolution of the paper or
board matrix. The source fiber (corrugated containers, mill waste, etc.) is
dropped into the pulper and mixed by a rotor. Debris and impurities are
removed by two mechanisms: a ragger and a junker. The ragger withdraws
strings, wires, and rags from the stock secondary fiber mixture, A typical
ragger consists of a few "primer wires" that are rotated in the secondary fiber
slurry. Debris accumulates on the primer wires, eventually forming a "debris
rope" which is then removed. Heavier debris are separated from the mixture
. by centrifugal force and fall into a pocket on the side of the pulper. The
junker consists of a grappling hook or elevator bucket. Heat, dissolution of
chemical bonds, shear forces created by stirring and mixing, and grinding by
mechanical equipment may serve to dissociate fibers and produce a pulp of
desired consistency.
Contaminant removal processes depend on the type and source of secondary
fiber to be pulped. Mill paper waste can be easily repulped with minimal
contaminant removal. Recycled post-consumer newspaper, on the other
hand, may require extensive contaminant removal, including deinking, prior
to reuse. As noted in Furnish Composition above, secondary fiber typically
is used in lower-quality applications such as multi-ply paperboard or
corrugating paper.
IH.A.2. Pulp Processing
After pulp production, pulp processing removes impurities, such as uncooked
chips, and recycles any residual cooking liquor via the washing process
(Figure 7). Pulps are processed in a wide variety of ways, depending on the
method that generated them (e.g., chemical, semi-chemical). Some pulp
processing steps that remove pulp impurities include screening, defibering,
and deknotting. Pulp may also be thickened by removing a portion of the
water. At additional cost, pulp may be blended to ensure product uniformity.
If pulp is to be stored for long periods of time, drying steps are necessary to
prevent fungal or bacterial growth.
Residual spent cooking liquor from chemical pulping is washed from the
pulp using brown stock washers. Efficient washing is critical to maximize
return of cooking liquor to chemical recovery (see Chemical Recovery
Systems below) and to minimize carryover of cooking liquor (known as
brown stock washing loss) into the bleach plant, because excess cooking
liquor increases consumption of bleaching chemicals. Specifically, the
dissolved organic compounds (lignins and hemicelluloses) contained in the
liquor will bind to bleaching chemicals and thus increase bleach chemical
consumption. In addition, these organic compounds function as precursors
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to chlorinated organic compounds (e.g., dioxins, furans), increasing the
probability of their formation. The most common washing technology is
rotary vacuum washing, carried out sequentially in two or four washing
units. Other washing technologies include diffusion washers, rotary pressure
washers, horizontal belt filters, wash presses, and dilution/extraction washers.
Pulp screening, removes remaining oversized particles such as bark
fragments, oversized chips, and uncooked chips. In open screen rooms,
wastewater from the screening process goes to wastewater treatment prior to
discharge. In closed loop screen rooms, wastewater from the process is
reused in other pulping operations and ultimately enters the mill's chemical
recovery system. Centrifugal cleaning (also known as liquid cyclone,
hydrocyclone, or centric leaning) is used after screening to remove relatively
dense contaminants such as sand and dirt. Rejects from the screening process
are either repulped or disposed of as solid waste.
Chemical Recovery Systems
The chemical recovery system is a complex part of a chemical pulp and paper
mill and is subject to a variety of environmental regulations. Chemical
recovery is a crucial component of the chemical pulping process: it recovers
process chemicals from the spent cooking liquor for reuse. The chemical
recovery process has important financial and environmental benefits for pulp
and paper mills. Economic benefits include savings on chemical purchase
costs due to regeneration rates of process chemicals approaching 98 percent,
and energy generation from pulp residue burned in a recovery furnace
(Smook, 1992). Environmental benefits include the recycle of process
chemicals and lack of resultant discharges to the environment.
The kraft, sulfite, and semi-chemical pulping processes all use chemical
recovery systems of some form; however, the actual chemical processes at
work differ markedly. Due to its widespread usage, only the kraft chemical
recovery system will be covered in depth in this document. Sulfite chemical
recovery systems are discussed briefly at the end of this section.
Kraft Chemical Recovery Systems
Although newer technologies are always under development, the basic kraft
chemical recovery process has not been fundamentally changed since its
patent issue in 1884. The stepwise progression of chemical reactions has
been refined; for example, black liquor gasification processes are now in use
in an experimental phase. The precise details of the chemical processes at
work in the chemical recovery process can be found in Smook, Handbook for
Pulp and Paper Technologists, 2nd Edition, 1992 and will not be discussed
here. The kraft chemical recovery process consists of the following general
steps:
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Black liquor concentration
Residual weak black liquor from the pulping process is concentrated by
evaporation to form "strong black liquor." After brown stock washing in the
pulping process, the concentration of solids in the weak black liquor is
approximately 15 percent; after the evaporation process, solids concentration
can range from 60 - 80 percent. In some older facilities, the liquor then
undergoes oxidation for odor reduction. The oxidation step is necessary to
reduce odor created when hydrogen sulfide is stripped from the liquor during
the subsequent recovery boiler burning process. Almost all recovery
furnaces installed since 1968 have non-contact evaporation processes that
avoid these problems, so oxidation processes are not usually seen in mills
with modern recovery furnaces. Common modem evaporator types include
multiple effect evaporators as well as a variety of supplemental evaporators.
Odor problems with the kraft process have been the subject of control
measures (See Section III.B. Raw Material Inputs and Pollution Outputs in
the Production Line for more information).
Recovery boiler
The strong black liquor from the evaporators is burned in a recovery boiler.
In this crucial step in the overall kraft chemical recovery process, organic
solids are burned for energy and the process chemicals are removed from the
mixture in molten form. Molten inorganic process chemicals (smelt) flow
through the perforated floor of the boiler to water-cooled spouts and
dissolving tanks for recovery in the recausticizing step.
Energy generation from the recovery boiler is often insufficient for total plant
needs, however, so facilities augment recovery boilers with fossil-fuel-fired
and wood-waste-fired boilers (hogged fuel) to generate steam and often
electricity. Industry-wide, the utilization of pulp wastes, bark, and other
papermaking residues supplies 58 percent of the energy requirements of pulp
and paper companies (AF&PA, 1999) (see III.A.3. Energy Generation for
more information).
Recausticizating
Smelt is recausticized to remove impurities left over from the furnace and to
convert sodium carbonate (Na2C03) into active sodium hydroxide (NaOH)
and sodium sulfide (Na2S). The recausticization procedure begins with the
mixing of smelt with "weak" liquor to form green liquor, named for its
characteristic color. Contaminant solids, called dregs, are removed from the
green liquor, which is mixed with lime (CaO). After the lime mixing step,
the mixture, now called white liquor due to its new coloring, is processed to
remove a layer of lime mud (CaCO3) that has precipitated. The primary
chemicals recovered are caustic (NaOH) and sodium sulfide (Na2S). The
remaining white liquor is then used in the pulp cooking process. The lime
mud is treated to regenerate lime in the calcining process.
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Calcining
In the calcining process, the lime mud removed from the white liquor is
burned to regenerate lime for use in the lime mixing step. The vast majority
of mills use lime kilns for this process, although a few mills use fluidized bed
systems in which the reactants are suspended by upward-blowing air.
Sulftte Chemical Recovery Systems
There are a variety of sulfite chemical pulping recovery systems in use today.
Heat and sulfur can be recovered from all liquors generated, however the
base chemical can only be recovered from magnesium and sodium base
processes (see Smook, 1992 for more information).
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Figure 7: The Kraft Pulping Process (with Chemical Recovery)
CHIPS
Water
.[
Blow Tank
.1
Washers
1
Weak Black
1
WHITE
STORAGE
^PULP
Condensate
Grits
WHITE
LIQUOR
CLARIFIER
t
CAUST1CIZERS
t
Slaker
t
Green
Liquor
Storage
t
Green
Liquor
Clarifier
Weak Liquor
Storage
Dregs
t
Source: Smook, 1992.
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III.A.3. Bleaching
Bleaching is defined as any process that chemically alters pulp to increase its
brightness. Bleached pulps create papers that are whiter, brighter, softer, and
more absorbent than unbleached pulps. Bleached pulps are used for products
where high purity is required and yellowing (or color reversion) is not
desired (e.g. printing and wrappingpapers,foodcontactpapers). Unbleached
pulp is typically used to produce boxboard, linerboard, and grocery bags. Of
the approximately 72 million tons of pulp production capacity in the United
States in 2000, about 50 percent is for bleached pulp (AF&PA, 2001).
Any type of pulp may be bleached, but the type(s) of fiber furnish and
pulping processes used, as well as the desired qualities and end use of the
final product, greatly affect the type and degree of pulp bleaching possible.
Printing and writing papers comprise approximately 60 percent of bleached
paper production. The lignin content of a pulp is the major determinant of
its bleaching potential. Pulps with high lignin content (e.g., mechanical or
semi-chemical) are difficult to bleach ftilly and require heavy chemical
inputs. Excessive bleaching of mechanical and semi-chemical pulps results
in loss of pulp yield due to fiber destruction. Chemical pulps can be bleached
to a greater extent due to their low (10 percent) lignin content.
For more information, the Summary of Technologies for the Control and
Reduction of Chlorinated Organics from the Bleached Chemical Pulping
Subcategories of the Pulp and Paper Industry, 199Q from the Office ofWater
Regulations and Standards is recommended. Typical bleaching processes for
each pulp type are detailed below.
Chemical pulp bleaching has undergone significant process changes since
approximately 1990. At that time, nearly every chemical pulp mill that used
bleaching incorporated elemental chlorine (C12) into some of its processes.
Because of environmental andhealth concerns about dioxins, U.S. pulp mills
now use elemental chlorine free (ECF) and total chlorine free (TCP)
bleaching technologies. The most common types of ECF and TCP are shown
in Table 8; the difference between ECF and TCF is that ECF may include
chlorine dioxide (C1O2) and hypochlorite (HC10, NaOCl, and Ca(OCl)2)
based technologies. In 2001, ECF technologies were used for about 95
percent of bleached pulp production, TCF technologies were used for about
1 percent of bleached pulp production, and elemental chlorine was used for
about 4 percent of production (AET, 2002).
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Table 8: Common Chemicals Used in Elemental Chlorine Free
(ECF) and Total Chlorine Free (TCF) Bleaching Processes
Bleaching Chemical
Sodium Hydroxide
Chlorine Dioxide
Hypochlorite
Oxygen
Ozone
Hydrogen Peroxide
Sulfur Dioxide
Sulfuric Acid
Chemical Formula
.NaOH
C102
HC10, NaOCl,
Ca(OCl)2
02
03
H2O2
S02
H,SO,
ECF/TCF
ECF and TCF
ECF
ECF
ECF and TCF
ECF and TCF
ECF and TCF
ECF and TCF
ECF and TCF
Source: U.S. EPA, 2001.
Chemical pulp is bleached in traditional bleach plants (see Figure 8) where
the pulp is processed through three to five stages of chemical bleaching and
water washing. The number of cycles is dependent on the whiteness desired,
the brightness of initial stock pulp, and plant design.
Bleaching stages generally alternate between acid and alkaline conditions.
Chemical reactions with lignin during the acid stage of the bleaching process
increase the whiteness of the pulp. The alkaline extraction stages dissolve
the lignin/acid reaction products. At the washing stage, both solutions and
reaction products are removed. Chemicals used to perform the bleaching
process must have high lignin reactivity and selectivity to be efficient.
Typically, 4-8 percent of pulp is lost due to bleaching agent reactions with
the wood constituents cellulose and hemicellulose, but, these losses can be
as high as 18 percent.
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Figure 8: Typical Bleach Plant
WHITEWATER
UNBLEACHED
PULP
M - „
14-1
BLEACH ED
TO ACID TOALKALJNE
SEWER SEWER
Source: U.S. EPA, 1993a.
Semi-chemical pulps are typically bleached with hydrogen peroxide (H202)
in a bleach tower.
Mechanical pulps are bleached with hydrogen peroxide (H202) and/or
sodium hydrosulfite (Na2S03). Bleaching chemicals are either applied
without separate equipment during the pulp processing stage (i.e., in-line
bleaching), or in bleaching towers. Full bleaching of mechanical pulps is
generally not practical due to bleaching chemical cost and the negative
impact on pulp yield.
Deinked secondary fibers are usually bleached in a bleach tower, but may
be bleached during the repulping process. Bleach chemicals may be added
directly into the pulper. The following are examples of chemicals used to
bleach deinked secondary fibers: hypochlorite (HC10, NaOCl, Ca(OCl)2),
hydrogen peroxide (H202), and hydrosulphite (Na2S204).
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III.A.4. Stock Preparation
At this final stage, the pulp is processed into the stock used for paper
manufacture. Market pulp, which is to be shipped off-site to paper or
paperboard mills, is simply dried and baled during this step. Processing of
pulp in integrated mills includes pulp blending specific to the desired paper
product desired, dispersion in water, beating and refining to add density and
strength, and addition of any necessary wet additives. Wet additives are used
to create paper products with special properties or to facilitate the
papermaking process. Wet additives include resins and waxes for water
repellency, fillers such as clays, silicas, talc, inorganic/organic dyes for
coloring, and certain inorganic chemicals (calcium sulfate, zinc sulfide, and
titanium dioxide) for improved texture, print quality, opacity, and brightness.
III.A.5. Processes in Paper Manufacture
The paper and paperboard making process consists of the following general steps:
Table 9: Paper and Paperboard Making Process
Sequential Process
Wet End Operations
Dry End Operations
Description
Formation of paper sheet from wet
pulp
Drying of paper product, application
of surface treatments, spooling for
storage
Wet End Operations
The processed pulp is converted into a paper product via a paper production
machine, the most common of which is the Fourdrinier paper machine (see
Figure 9). In the Fourdrinier system, the pulp slurry is deposited on a
moving wire belt that carries it through the first stages of the process. Water
is removed by gravity, vacuum chambers, and vacuum rolls. This waste
water is recycled to the slurry deposition step of the process due to its high
fiber content. The continuous sheet is then pressed between a series of
rollers to remove more water and compress the fibers.
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Figure 9: Fourdrinier Paper Machine
Flow
Spreader
Mead Box Press Section
FourdrinierTable
Dryer Section
Calender
Stack
Reel
Source: U.S. EPA, 1993a.
Dry End Operations
After pressing, the sheet enters a drying section, where the paper fibers begin
to bond together as steam heated rollers compress the sheets, In the calender
process the sheet is pressed between heavy rolls to reduce paper thickness
and produce a smooth surface. Coatings can be applied to the paper at this
point to improve gloss, color, printing detail, and brilliance. Lighter coatings
are applied on-machine, while heavy coatings are performed off-machine.
The paper product is then spooled for storage.
III.A.6. Energy Generation
Pulp and paper mill energy generation is provided in part from the burning
of liquor waste solids in the recovery boiler, but other energy sources are
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needed to make up the remainder of mill energy needs. Over the last 25
years, the pulp and paper industry has changed its energy generation methods
from fossil fuels to a greater utilization of processes or process wastes. The
increase in use of wood wastes from the wood handling and chipping
processes depicted in Table 10 below is one example of this industry-wide
movement. During the 1972-1999 period, the proportion of total industry
power generation from the combination of woodroom wastes, spent liquor
solids, and other self-generation methods increased from about 41 percent to
about 58 percent, while coal, fuel oil and natural gas use decreased from
about 54 percent to about 36 percent.
Power boilers at pulp and paper mills are sources of particulate emissions,
sulfur dioxide (SO2), and nitrogen oxides (NOJ, Pollutants emitted from
chemical recovery boilers include S02, and total reduced sulfur compounds
(TRS).
Table 10: Estimated Energy Sources for the U.S. Pulp and Paper Industry
Enerev Source
Purchased steam
Coal
Fuel oil
Natural gas
Other purchased energy
Waste wood and wood
chips (Hogged fuel) and
bark
Spent liquor solids
Other self-aenerated oower
1972"
5.4%
9.8%
22.3%
21.5%
-
6.6%
33.7%
0.6%
1979"
6.7%
9.1%
19.1%
17.8%
-
9.2%
37.3%
0.8%
1990a
7.3%
13.7%
6.4%
16.4%
-
15.4%
39.4%
1.2%
1999b
1.5%
12.5%
6.3%
17.6%
6.7%
13.5%
40.3%
1.6%
Sources: "American Paper Institute Data as presented in Smook, 1992.
bAF&PA,2001.
IH.B. Raw Material Inputs and Pollution Outputs in the Production Line
Pulp and paper mills use and generate materials that may be harmful to the
air, water, and land: pulp and paper processes generate large volumes of
wastewaters which might adversely affect freshwater or marine ecosystems,
residual wastes from wastewater treatment processes may contribute to
existing local and regional disposal problems, and air emissions from pulping
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processes and power generation facilities may release odors, participates, or
other pollutants. Major sources of pollutant releases in pulp and paper
manufacture are at the pulping and bleaching stages respectively. As such,
non-integrated mills (i.e., those mills without pulping facilities on-site) are
not significant environmental concerns when compared to integrated mills or
pulp mills.
Water
The pulp and paper industry is the largest industrial process water user in the
U.S. (U.S. Department of Commerce, 2000). In 2000, a typical pulp and
paper mill used 4,000-12,000 gallons of water per ton of pulp produced (Pulp
and Paper, 2001). General water pollution concerns for pulp and paper mills
are effluent solids, biochemical oxygen demand, and color. Toxicity
concerns historically occurred from the potential presence of chlorinated
organic compounds such as dioxins, fiirans, and others (collectively referred
to as adsorbable organic halides, or AOX) in wastewaters after the
chlorination/extraction sequence. With the substitution of chlorine dioxide
for chlorine, effluent loads of the chlorinated compounds decreased
dramatically.
Due to the large volumes of water used in pulp and paper processes, virtually
all U.S. mills have primary and secondary wastewater treatment systems
installed to remove particulate and biochemical oxygen demand (BOD)
produced in the manufacturing processes. These systems also provide
significant removal (e.g., 30-70 percent) of other important parameters such
as AOX and chemical oxygen demand (COD).
The major sources of effluent pollutants in a pulp and paper mill are
presented in Table 11.
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Table 11: Potential Water Pollutants From Pulp and Paper Processes
Source
Water used in wood handling/debarking and
chip washing
Chip digester and liquor evaporator
condensate
"White waters" from pulp screening,
thickening, and cleaning
Bleach plant washer filtrates
Paper machinewater flows
Fiber and liquor spills
Effluent characteristics
Solids, BOD, color
Concentrated BOD, reduced sulfur
compounds
Large volume of water with suspended solids,
can have significant BOD
BOD, color, chlorinated organic compounds
Solids
Solids, BOD, color
Source: Smook, 1992.
Wood processing operations in pulp mills often use water for a variety of
purposes. The resulting wastewaters contain BOD, suspended solids, and
some color. The condensates from chip digesters and chemical recovery
evaporators are sources of BOD and reduced sulfur compounds.
Wastewaters containing BOD, color, and suspended solids may be generated
from pulp screening operations in mills using "atmospheric" systems, though
most mills have modem pressure screens that virtually eliminate such
wastewaters. Kraft bleaching generates large volumes of wastewater
containing BOD, suspended solids, color, and chlorinated organic
compounds. From paper machines, excess white water (named for its
characteristic color) contains suspended solids and BOD. Fiber and liquor
spills can also be a source of mill effluent. Typically, spills are captured and
pumped to holding areas to reduce chemical usage through spill reuse and to
avoid loadings on facility wastewater treatment systems.
Wastewater treatment systems can be a significant source of cross-media
pollutant transfer. For example, waterborne particulate and some chlorinated
compounds settle or absorb onto treatment sludge and other compounds may
volatilize during the wastewater treatment process.
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Air
The following table is an overview of the major types and sources of air
pollutant releases from various pulp and paper processes:
Table 12: Common Air Pollutants From Pulp and Paper Processes
Kraft recovery furnace
Fly ash from hog fuel and coal-fired
burners
Sulfite mill operations
Kraft pulping and recovery processes
Chip digesters and liquor evaporation
Pulp drying (non-integrated mills)
All combustion processes
TVDC
Fine particulates, nitrogen oxides
Coarse particulates
Sulfur oxides, ammonia
Reduced sulfur gases
•Volatile organic compounds
Volatile organic compounds
Nitrogen oxides
Source: Smook, 1992.
Water vapors are the most visible air emission from a pulp and paper mill,
but are not usually regulated unless they are a significant obscurement or
climate modifier.
Pulp and paper mill power boilers are generic pulp and paper mill sources of
air pollutants such as particulates and nitrogen oxides. Chip digesters and
chemical recovery evaporators are the most concentrated sources of volatile
organic compounds. The chemical recovery furnace is a source of fine
paniculate emissions and sulfur oxides. In the kraft process, sulfur oxides
are a minor issue in comparison to the odor problems created by four reduced
sulfur gasses, called together total reduced sulfur (TRS): hydrogen sulfide,
methyl mercaptan, dimethyl sulfide, and dimethyl disulfide. The TRS
emissions are primarily released from wood chip digestion, black liquor
evaporation, andchemicalrecoveryboilerprocesses. TRS compounds create
odor nuisance problems at lower concentrations than sulfur oxides: odor
thresholds for TRS compounds are approximately 1,000 times lower than that
for sulfur dioxide. Humans can detect some TRS compounds in the air as a
"rotten egg" odor at as little as one part per billion.
Pulp and paper mills have made significant investments in pollution control
technologies and processes. According to industry sources, the pulp and
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paper industry spent more than $1 billion per year from 1991-1997 on
environmental capital expenditures. In 1991 and 1992, this represented 20
percent of total capital expenditures (AF&PA, 1994). Chemical recovery and
recycling systems in the chemical pulping process significantly reduce
pollutant outputs while providing substantial economic return due to
recovery of process chemicals. Chemical recovery is necessary for the basic
economic viability of the kraft process. According to EPA sources, all kraft
pulp mills worldwide have chemical recovery systems in place. Some sulfite
mills, however, still do not have recovery systems in place. Scrubber system
paniculate "baghouses" or electrostatic precipitators (ESPs) are often mill air
pollution control components.
Residual Wastes
The significant residual waste streams from pulp and paper mills include
wastewater treatment sludges, lime mud, lime slaker grits, green liquor dregs,
boiler and furnace ash, scrubber sludges, and wood processing residuals.
Because of the tendency for chlorinated organic compounds to partition from
effluent to solids, wastewater treatment sludge is a significant environmental
concern for the pulp and paper industry.
Wastewater treatment sludge is the largest volume residual waste stream
generated by the pulp and paper industry. Sludge generation rates vary
widely among mills. For example, bleached kraft mills surveyed as part of
EPA's 104-Mill Study reported sludge generation that ranged from 14 to 140
kg of sludge per ton of pulp (U.S. EPA, 1988). Total sludge generation for
these 104 mills was 2.5 million dry metric tons per year, or an average of
approximately 26,000 dry metric tons per year per plant. Pulpmaking
operations are responsible for the bulk of sludge wastes, although treatment
of papermaking effluents also generates significant sludge volumes. For the
majority of pulp and integrated mills that operate their own wastewater
treatment systems, sludges are generated onsite. A small number of pulp
mills, and a much larger proportion of papermaking establishments,
discharge effluents to publicly-owned wastewater treatment works (POTWs).
Potential environmental hazards from wastewater sludges are associated with
trace constituents (e.g., chlorinated organic compounds) that partition from
the effluent into the sludge. It should be noted, however^ that recent trends
away from elemental chlorine bleaching have reduced these hazards. A
continuing concern is the very high pH (>12.5) of most residual wastes.
When these wastes are disposed of in an aqueous form, they may meet the
RCRA definition of a corrosive hazardous waste (U.S. EPA, 2002).
Landfill and surface impoundment disposal are most often used for
wastewater treatment sludge, but a significant number of mills dispose of
sludge through land application, conversion to sludge-derived products (e.g.,
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compost and animal bedding), or combustion for energy recovery (AF&PA,
2002).
Process Inputs and Pollutant Outputs
Kraft chemical pulping and chlorine-based (e.g., hypochlorite or chlorine
dioxide) bleaching are both commonly used and may generate significant
pollutant outputs. Kraft pulping processes produced approximately 83
percent of total US pulp tonnage during 1998 according to the American
Forest and Paper Association (AF&PA, 1999). Roughly 60 percent of this
amount is bleached in some manner.
Pollutant outputs from mechanical, semi-chemical, and secondary fiber
pulping are small when compared to kraft chemical pulping. In the pulp and
paper industry, the kraft pulping process is the most significant source of air
pollutants. The following table and figures (Table 13 and Figures 10 and 11)
illustrate the process inputs and pollutant outputs for a pulp and paper mill
using kraft chemical pulping and chlorine-based bleaching. The process
outlined below produces a large portion of U.S. pulp.
Table 13 presents the process steps, material inputs, and major pollutant
outputs (by media) of a kraft pulp mill practicing traditional chlorine
bleaching. The following resources are recommended for pollutant
production data (e.g., pounds of BOD per ton of pulp produced) for those
pollutants presented in Table 13:
• Pollution Prevention Technologies for the Bleached Kraft Segment
of the U.S. Pulp and Paper Industry. August 1993. (EPA-600-R-93-
110)
• Development Documentfor ProposedEffluent Limitations Guidelines
and standards for the Pulp, Paper, and Paperboard Point Source
Category. October 1993. (EPA-821-R-93-019)
• Pulp, Paper and Paperboard Industry - Background Information for
Proposed Air Emission Standards: Manufacturing Processes at
Kraft, Sulfite, Soda, and Semi-Chemical Mills, NESHAP. October
1993. (EPA-453-R-93-050a)
Figure 10 is a process flow diagram of the kraft process, illustrating chemical
pulping, power recovery, and chemical recovery process inputs and outputs.
Figure 11 is a schematic of characteristic air emission sources from a kraft
mill.
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Table 13: Kraft Chemical Pulped Bleached Paper Production
Process Step
Fiber Furnish
Preparation
Chemical
Pulping Kraft
process
Bleaching6
Papermaking
Material
Inputs
Wood logs
Chips
Sawdust
Furnish chips
Cooking
chemicals: sodium
sulfide (Na2S),
NaOH, white
liquor (from
chemical recovery)
Chemical pulp
Hypochlorite
(HC1O, NaOCl,
Ca(OCl)2)
Chlorine dioxide
(C102)
Additives,
Bleached/
Unbleached pulp
Process Outputs
Furnish chips
Black liquor (to
chemical recovery
system), pulp (to
bleaching/
processing)
Bleached pulp
Paper/paperboard
product
Major Pollutant Outputs8
dirt, grit, fiber, bark
BOD
TSS
resins, fatty acids
color
BOD
COD
AOX
VOCs [terpenes, alcohols, phenols,
methanol, acetone, chloroform, methyl
ethyl ketone (MEK)]
VOCs (terpenes, alcohols, phenols,
methanol, acetone, chloroform, MEK)
reduced sulfur compounds (TRS)
organo-chlorine compounds (e.g.,
3,4,5- trichloroguaiacol)
dissolved lignin and carbohydrates
color
COD
AOX
inorganic chlorine compounds
(e.g., chlorate (C1O3-))C
VOCs (acetone, methylene chloride,
chloroform, MEK, chloromethane,
trichloroethane)
particulate wastes
organic compounds
inorganic dyes
COD
acetone
Pollutant
Media
Solid
Water
Solid
Water
Air
Water
Air /Water
Water
Sector Notebook Project
41
November 2002
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Pulp and Paper Industry
Industrial Process Description
Table 13: Kraft Chemical Pulped Bleached Paper Production (continued)
Process Step
Wastewater
Treatment
Facilities
Power Boiler
Material
Inputs
Process
wastewaters
Coal,
Wood,
Unused furnish
Process Outputs
Treated effluent
Energy
Major Pollutant Outputs'
sludge
VOCs (terpenes, alcohols, phenols,
methanol, acetone, chloroform, MEK)
BOD
TSS
COD
color
chlorophenolics
VOCs (terpenes, alcohols, phenols,
methanol, acetone, chloroform, MEK)
bottom ash: incombustible fibers
SO2, NOK, fly ash, coarse particulates
Pollutant
Media
Solid
Air
Water
Solid
Air
Chemical Recovery System
Evaporators
Recovery
Furnace
Recaus ticizing
Calcining
(Lime Kiln)
Black liquor
Strong black liquor
Smelt
Lime mud
Strong black liquor
Smelt
Energy
Regenerated white
liquor
Lime mud
Slaker grits
Lime
evaporator noncondensibles (TRS,
volatile organic compounds: alcohols,
terpenes, phenols)
evaporator condensates (BOD,
suspended solids)
fine particulates, TRS, SO2, NOX
dregs
waste mud solids
solids
fine and coarse particulates
Air
Water
Air
Solids
Water,
Solid
Solid
Air
1 Pollutant outputs may differ significantly based on mill processes and material inputs (e.g., wood chip resin content).
b Pollutant list based on Elemental Chlorine Free (ECF) bleaching technologies.
c Chlorate only significantly produced in mills with high rates of chlorine dioxide use.
Sources: EPA, 1993a; EPA, 1993b; and EPA, 1993c.
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Pulp and Paper Industry
Industrial Process Description
Figure 10: Kraft Process Flow Diagram
Chlpi Steam
UME MUD
PROCESSING
RECOVERY [POWER)
RECOVERY (CHEMICALS) J
Dugs
Removal
Reburneti Ume
Source: Smook, 1992.
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November 2002
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Pulp and Paper Industry
Industrial Process Description
Figure 11: Air Pollutant Output from Kraft Process
^^x^"V~ - ^-^"N—
WOOD CHIPS T 1 ( )
i V V
E,GHSTER — , &ABC<-™™
o
, IMP k-ii M J TURPENTINE
LIME KILN -1 & RECQVE
NK . WASHERS Pl
ATOR & SCREENS
0 Q
COND. J i WEAKB.L |_
RY ! OXIDATION ;
ocp cp
I Tl t
-LM'ER :r DISSOLVI
oLAKtM < TAN|<
NQ RECOVERY ^_
* SYSIbM *~
cp
COMBINATION
BOILER
JLP TO THE PAPER MILL
O
t
MULTIPLE EFFECT
EVAPORATORS
• fc * •„
A
j CONG. B.L. i
OXIDATION i
___ ._. ._. ,-, , — -•- •— ' *-J
Source: Smook, 1992.
Sector Notebook Project
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Pulp and Paper Industry
Chemical Releases and Transfers
IV. CHEMICAL RELEASE AND OTHER WASTE MANAGEMENT PROFILE
This section is designed to provide background information on the pollutant
releases that are reported by this industry in correlation with other industries.
The best source of comparative pollutant release and other waste
management information is the Toxic Release Inventory (TRI). Pursuant to
the Emergency Planning and Community Right-to-Know Act, TRI includes
self-reported facility release and other waste management data for over 650
toxic chemicals and chemical categories. Facilities within SIC Codes 10
(except 1011, 1081, and 1094), 12 (except 1241), 20-39, 4911 (limited to
facilities that combust coal and/or oil for the purpose of generating electricity
for distribution in commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for distribution in
commerce), 4939 (limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in commerce), 4953 (limited
to facilities regulated under the RCRA Subtitle C, 42 U.S.C. section 6921 et
seq.), 5169, 5171, and 7389 (limited to facilities primarily engaged in
solvents recovery services on a contract or fee basis) have more than 10
employees, and that manufactures, processes or otherwise uses listed
chemical in quantities greater than the established threshold in the course of
a calendar year are required to report to TRI annually release and other waste
management quantities (on- and off-site). The information presented within
the sector notebooks is derived from the most recently available (2000) TRI
reporting year (which includes over 650 chemicals and chemical categories),
and focuses primarily on the on-site releases reported by each sector.
Because TRI requires consistent reporting regardless of sector, it is an
excellent tool for drawing comparisons across industries. TRI data provide
the type, amount and media receptor of each chemical released or otherwise
managed as waste.
Although this sector notebook does not present historical information
regarding TRI chemical releases over time, please note that in general, toxic
chemical releases have been declining. In fact, according to the 2000 Toxic
Release Inventory Public Data Release, reported on-site and off-site releases
of toxic chemicals to the environment from original TRI reporting industries
(SIC codes 20-39) decreased by more than 8 percent (644 million pounds)
between 1999 and 2000 (not including chemicals added and removed from
the TRI chemical list during this period). Reported on-site releases dropped
by almost 57 percent between 1988 and 2000. Reported transfers of TRI
chemicals to off-site locations for disposal increased by almost 7 percent (28
million pounds) between 1988 and 2000. More detailed information can be
obtained from EPA's annual Toxics Release Inventory Public Data Release
Report (which is available through the EPCRA Call Center at 800-424-9346),
or directly from the Internet at www.ezja.gov/ifn'.
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Pulp and Paper Industry
Chemical Releases and Transfers
Wherever possible, the sector notebooks present TRI data as the primary
indicator of chemical release within each industrial category. TRI data
provide the type, amount and media receptor of each chemical released or
Otherwise managed as waste. When other sources of pollutant release data
have been obtained, these data have been included to augment the TRI
information.
TRI Data Limitations
Certain limitations exist regarding TRI data. Within some sectors, (e.g.,
printing and transportation equipment cleaning) the majority of facilities are
not subject to TRJ reporting either because they do not fall under covered
SIC codes, or because they are below the TRI reporting threshold amounts.
However, EPA lowered threshold amounts for persistent bioaccumulative
toxic (PBT) chemicals starting reporting year 2000, For these sectors,
release information from other sources has been included. In addition, many
facilities report to TRI under more than one SIC code, reflecting the multiple
operations carried out onsite whether or not the operations are the facilities'
primary area of business as reported to the U.S. Census Bureau. Reported
chemicals are limited to the approximately 650 TRI chemicals and chemical
categories. A portion of the emissions from pulp and paper mills, therefore,
are not captured by TRI. Also, reported releases and other waste
management quantities may or may not all be associated with the industrial
operations described in this notebook.
The reader should also be aware that TRJ "pounds released" data presented
within the notebooks is not equivalent to a "risk" ranking for each industry.
Weighting each pound of release equally does not factor in the relative
toxicity of each chemical that is released. The Agency is in the process of
developing an approach to assign toxicological weightings and population
exposure levels to each chemical released so that one can differentiate
between pollutants with significant differences in toxicity. This project, the
Risk - Screening Environmental Indicators Model, can be found at
http://www.epa.gov/opptintr/rsei/.
As a preliminary indication of the environmental impact of the industry's
most commonly released chemicals, this notebook briefly summarizes the
toxicological properties of the top five chemicals (by weight) reported by the
organic chemical industry.
Definitions Associated with Section IV Data Tables
General Definitions
Sector Notebook Project
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Pulp and Paper Industry
Chemical Releases and Transfers
SIC Code - is the Standard Industrial Classification (SIC) is a statistical
classification standard used for all establishment-based Federal economic
statistics. The SIC codes facilitate comparisons between facility and industry
data.
TRI Facilities ~ are facilities that are within specified SIC codes that have
10 or more full-time employees and are above established threshold amounts
for manufacture or process or otherwise use activities in the course of a
calendar year. These facilities are in standard industrial classification codes
10(exceptl011,1081, and 1094), 12(except 1241), 20-39,4911 (limited to
facilities that combust coal and/or oil forthe purpose of generating electricity
for distribution in commerce), 4931 (limited to facilities that combust coal
and/or oil for the purpose of generating electricity for distribution in
commerce), 4939 (limited to facilities that combust coal and/or oil for the
purpose of generating electricity for distribution in commerce), 4953 (limited
to facilities regulated under the RCRA Subtitle C, 42 U.S.C. section 6921 et
seq.)> 5169, 5171, and 7389 (limited to facilities primarily engaged in
solvents recovery services on a contract or fee basis), and federal facilities.
Facilities must submit release and other waste management estimates for all
chemicals that are on the EPA's defined list and are above manufacturing or
processing or otherwise use thresholds.
Data Table Column Heading Definitions
The following definitions are based upon standard definitions developed by
EPA's Toxic Release Inventory Program. The categories below represent the
possible pollutant destinations that can be reported.
ON-SITE RELEASES ~ are an on-site discharge of a toxic chemical to the
environment. This includes emissions to the air, discharges to bodies of
water, releases at the facility to land, as well as contained disposal into
underground injection wells.
Releases to Air (Point and Fugitive Air Emissions) -- Include all air
emissions from industry activity. Point emissions occur through confined air
streams as found in stacks, ducts, or pipes. Fugitive emissions include losses
from equipment leaks, or evaporative losses from impoundments, spills, or
leaks.
Releases to Water (Surface Water Discharges) - encompass any releases
going directly to streams, rivers, lakes, oceans, or other bodies of water. Any
estimates for storm water runoff and non-point losses must also be included.
Releases to Land ~ includes disposal of toxic chemicals in waste to on-site
landfills, land treated or incorporation into soil, surface impoundments,
Sector Notebook Project
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Pulp and Paper Industry
Chemical Releases and Transfers
spills, leaks, or waste piles. These activities must occur within the facility's
boundaries for inclusion in this category.
Underground Injection ~ is a contained release of a fluid into a subsurface
well for the purpose of waste disposal.
TRANSFERS -- is a transfer of toxic chemicals in wastes to a facility that
is geographically or physically separate from the facility reporting under
TRI. The quantities reported represent a movement of the chemical away
from the reporting facility. Except for off-site transfers for disposal, these
quantities do not necessarily represent entry of the chemical into the
environment.
Transfers to POTWs ~ are waste waters transferred through pipes or sewers
to a publicly owned treatments works (POTW). Treatment and chemical
removal depend on the chemical's nature and treatment methods used.
Chemicals not treated or destroyed by the POTW are generally released to
surface waters or land filled within the sludge. Metals and metal compounds
transferred to POTWs are considered as released to surface water.
Transfers to Recycling -- are sent off-site for the purposes of regenerating
or recovering still valuable materials. Once these chemicals have been
recycled, they may be returned to the originating facility or sold
commercially.
Transfers to Energy Recovery -- are wastes combusted off-site in industrial
furnaces for energy recovery. Treatment of a chemical by incineration is not
considered to be energy recovery.
Transfers to Treatment - are wastes moved off-site for either
neutralization, incineration, biological destruction, or physical separation.
In some cases, the chemicals are not destroyed but prepared for further waste
management.
Transfers to Disposal - are wastes taken to another facility for disposal
generally as a release to land or as an injection underground.
IV.A. EPA Toxics Release Inventory For the Pulp and Paper Industry
According to Toxic Release Inventory (TRI) data from SIC codes 261 -263,
the pulp and paper industry released (to the air, water, or land) and
transferred (shipped off-site) a total of approximately 263 million pounds of
Sector Notebook Project
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Pulp and Paper Industry Chemical Releases and Transfers
toxic chemicals during calendar year 2000.' This represents approximately
2.5 percent of the total pounds of TRI chemicals released and transferred by
all reporting facilities that year.
Media comparison of TRI releases
The total amount of TRI toxic chemicals generated by the pulp and paper
industry is a gross profile of the types and relative amounts of chemical
outputs from mill processes. Additional information which can be related
back to possible compliance requirements is available from the distribution
of chemical releases across specific media within the environment. The TRI
data requires filers to separate the total releases for the pulp and paper
industry for air, water, and land releases. This distribution across media can
also be compared to the profile of other industry sectors.
The pulp and paper industry releases 66 percent of its total TRI poundage to
the air, approximately 22 percent to water and POTWs, and 9 percent is
disposed on land (on site and off site). This release profile differs from other
TRI industries which average approximately 63 percent to land, 27 percent
to air, and 4 percent to water and POTWs. A larger proportion of water
releases correlates with the water intensive processes of the pulp and paper
industry. An average mill requires 10 million gallons of influent water per
day and will produce the corresponding amount of effluent waters.
Examining the pulp and paper industry's TRI reported toxic chemicals by
chemical, highlights the likely origins of industry releases (see Table 14).
Air releases can be traced to a variety of sources. Approximately 63 percent
are methanol, a by-product of the pulp making process. The other major air
toxic chemicals, such as chlorinated compounds and sulfuric acid, originate
in the bleaching stage. Methanol is the most frequently reported chemical by
pulp and paper mills, and it accounts for approximately 15 percent of the
water releases and 97 percent of transfers to POTWs by the industry.
Overall, methanol represents roughly 60 percent of the pulp and paper
industry's TRI releases and transfers.
The diversity of processes in the pulp and paper industry can be seen in the
diversity of chemicals found in the TRI report. The TRI chemical released
and transferred by the second largest number of mills is ammonia, which is
used as a buffer in acid sulfite pulping (Air & Waste Management
Association, 1992). In addition, some TRI chemicals are only reported by a
few mills, suggesting process specific needs such as paper finishing or use
in wet additives.
1 Unless otherwise indicated, TRI data for SIC codes 261 -263 were used for pulp and paper release and transfer
values in this section and the tables therein.
Sector Notebook Project 49 November 2002
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Pulp and Paper Industry
Chemical Releases and Transfers
Table 14: 2000 TRI Releases for Pulp and Paper Facilities (SICs 261,262 and 263),
by Number of Facilities Reporting (Releases Reported in pounds/year)
'hemical Name
rfethanol
Ammonia
lydrochloric Acid (1995 and after "Acid
Aerosols"
Acetaldehyde
Manganese Compounds
'olycyclic Aromatic Compounds[PBT]
;ormaldehyde
Sulfuric Acid (1994 and after "Acid
Aerosols" Only
Phenol
Chlorine
Catechol
3arium Compounds
titrate Compounds
Chlorine Dioxide
3ioxin and Dioxin-Like
Compounds [PBT]
Zinc Compounds
Mercury Compounds[PBT]
Methyl Ethyl Ketone
Benzo(g Ji,i) perylene[PBT]
'ormic Acid
Chloroform
Cresol (Mixed Isomers)
Mercury [PBT]
hydrogen Fluoride
Vanadium Compounds
Chloromethane
Copper Compounds
Nickel Compounds
Certain Glycol Ethers
Chromium Compounds
Hthylene Glycol .
Toluene
Xylene (Mixed Isomers)
Polychlorinated Biphenyls[PBT]
Styrene
C.L Direct Blue 2)8
Manganese
Benzene
Dazomet
Vinyl Acetate
Biphenyl
1 ,2,4-trimethylbenzene
Diethanolamine
N-butyl Alcohol
Nitric Acid
Decabromodiphenyl Oxide
Antimony
Lead Compounds[PBT]
N-hexane
Arsenic Compounds
Lead[PBT]
Antimony Compounds
# Reporting
Chemical
174
166
137
125
124
122
116
113
105
102
99
96
87
80
77
77
75
64
63
54
40
32
23
17
16
15
15
13
12
9
9
9
7
7
5
5
5
3
3
3
3
3
3
3
2
2
2
2
2
2
1
1
Fugitive
Air
5,368,130
514,616
8,037
540,704
1,932
57
57,062
773
14,983
25,236
11
13
2,215
19
1
98,368
1,210
1,076,881
363
6,102
62
17,410
30
60
81,244
33,224
19,000
2,792
12,303
20,920
549
29,759
10
4,100
Point
Air
105,189,904
15,782,909
16,114,754
7,749,806
199,238
1 14,967
1,865,446
9,670,724
1,105,065
449,437
256
252,753
701,625
55
775,453
2,149
1,024,379
1,060
1,105
1,810,096
827,255
544
442,166
51,541
492,139
8,343
8,021
54,925
1,409
2,316
638,734
41,507
31
53,239
11,163
276,814
16,900
117,000
13,396
6,505
61,970
1,310
1,698
46,100
360
Water Underground
Discharees Iniection
3,011,860
1,884,126
10
177,092
4,187,964
1,472
326,507
9,244
60,185
17,493
540,545
9,791,260
103
324,492
56
14,909
115
92,178
49,459
1,097
8
20,204
10
3,591
3,337
7,919
10,341
29,596
19
202
104
20
94,428
600
880
180
974
10,943
5
796
Land
Disnosal
1,014,710
11,939
3,789
8,733,410
2.458
9,651
3,209
17
605
2,351,605
9,234
162
3,255,589
535
5,013
163
2,211
12,285
708
94
635,418
5
50,429
94,451
2,602
32,731
5,810
1,260
1,704
500,902
10
1,100
350
6
Total
Releases
114,584,624
18,193,590
16,122,801
8,471,391
13,122,544
118,954
2,258,666
9,671,497
1,132,501
534,875
18,365
3,144,916
9,800,494
703,840
320
4,355,553
2,741
1,142,669
1,338
96,704
2,948,721
829,423
646
442,166
713,265
492,216
62,363
105,809
82,856
44,511
37,782
719,997
76,193
31
72,343
1,724
606,493
276,814
3,392
30,083
1 17,000
34,506
8,028
102,672
1,320
1,105
350
2,494
50,200
366
Avg. Releases
Per Facilitv
658,532
109,600
117,685
67,771
105,827
975
19,471
85,588
10,786
5,244
1«
32,760
1 12,649
8,798
4
56,56(
37
17,854
21
1,791
73,718
25,919
28
26,010
44,579
32,814
4,158
8,139
6,905
4,946
4,198
80,00(
10,885
i
14,469
345
121,299
92,271
1,131
10,028
39,000
11,502
2,676
34,224
660
552
175
1,241
. 25,100
183
Sector Notebook Project
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Pulp and Paper Industry
Chemical Releases and Transfers
Table 14: 2000 TRI Releases for Pulp and Paper Facilities (SICs 261,262 and 263),
by Number of Facilities Reporting (Releases Reported in pounds/year)
Chemical Name
Chlordane[PBT]
Maleic Anhydride
Ethyl benzene
Potassium Dimethyldithiocarbamate
0-xylene
Diisocyanates
Ozone
Naphthalene
Copper
Methyl Methacrylate
Acrylic Acid
Trichloroethylene
Dichloromethane
Polychlorinated Alkanes
Barium
Mixture
ft Reporting Fugitive
Chemical Air
200
290
19
15
750
83
750
1
6
, 1
268** 7,940,291
Point
Air
210
90
46,430
102,763
17,000
1,154
280
33,316
4
166,187,814
Water Underground Land
Discharees Infection Disnosal
10,394
5
1 • 4,800
I
250 250
20,684,970 0 16,749,220
Total
Releases
410
380
10,413
46,450
750
102,763
21,884
1,904
281
33,323
500
5
211,562,315
Avg. Releases
Per Facility
41C
380
10,413
46,450
750
102,763
21,884
1,904
281
33,323
500
5
789,41 1
[PBT] Persistent, Bioaccumulative, and Toxic
* Refer to Section III for A discussion of the TRI data and its limitations, methodology used to obtain this data, definitions of the column headings,
and the definition of persistant, bioaccumulative, and toxic chemicals.
**Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
Sector Notebook Project
51
November 2002
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Pulp and Paper Industry
Chemical Releases and Transfers
Table 15: 2000 TRI Transfers for Pulp and Paper Facilities (SICs 261,262 and 263),
bv Number of Facilities Reporting (Transfers Reported in pounds/year)
# Reporting
Chemical Name Chemical
ilethanol
Ammonia
lydrochloric Acid (1995 and after "Acid
Aerosols"
Ac et aldehyde
Manganese Compounds
'oly cyclic Aromatic Compounds[PBT]
Formaldehyde
Sulfuric Acid (1994 and after "Acid
Aerosols" Only
Phenol
Chlorine
Catechol
Jarium Compounds
titrate Compounds
Chlorine Dioxide
)ioxin and Dioxin-Like Compounds[PBT]
Zinc Compounds
Mercury Compounds[PBT]
Methyl Ethyl Ketone
Benzo(g,h,i)pery lene[PBT]
•ormic Acid
Chloroform
Cresol (Mixed Isomers)
Mercury[PBT]
iydrogen Fluoride
Vanadium Compounds
Chloromethane
Copper Compounds
Nickel Compounds
Certain Glycol Ethers
Chromium Compounds
Ethylene Glycol
Toluene
Xylene (Mixed Isomers)
Polychlorinated BiphenylsfPBT]
Styrene
C,i. Direct Blue 21 8
Manganese
Benzene
Dazomet
Vinyl Acetate
Biphenyl
1 ,2,4-lrimethylbenzene
Diethanolamine
N-butyl Alcohol
Nitric Acid
Decabromodiphenyl Oxide
Antimony
Lead Compounds[PBT]
N-hexane
Arsenic Compounds
Lead[PBT]
Antimony Compounds
Chlordane[PBT]
Maleic Anhydride
Ethylbenzene
Potassium Dimethyldithiocarbamate
0-xylene
Diisocyanates
Ozone
Naphthalene
Copper
174
166
137
125
124
122
116
113
105
102
99
96
87
80
77
77
75
64
63
54
40
32
23
17
16
15
15
13
12
9
9
9
7
7
5
5
5
3
3
3
3
3
3
3
2
2
2
2
2
2
POTW
Transfers
36,098,617
56,000
111,435
204,150
1,224
116,817
5
16,753
14,443
66,175
41,058
40,310
21
30,256
14
56,874
7
6,334
155,257
4,448
1,400
306
1,515
2,120
1,351
24,658
1,984
13,535
36,070
251
120
Disposal
Transfers
144,671
79,785
757
2,977,098
1,257
18,814
2,372
602
1316,911
38,220
101
1,129,573
23,862
680
101
251
8,630
394
485
88,540
64,245
91,928
815
71,901
2,810
207
3,848
38,661
4
483
26,600
6,650
127,400
24,200
350
2,200
675
Recycling Treatment
Transfers Transfers
24,058 6,993,725
2,966
25 10,100
152,646
52 5
63 53,825
15 4,983
1
3 630
86,502
118,370
6 10
72,525
95
4,350 20,062
3 2
308
1,600
1 1 ,463
180
1,000
84,004
220
5
57
160 750
1,065
715
50
Energy
Recovery
13,736
129
279
2,529
2,250
38,121
2
383,822
10,291
19
11,000
840
Total Avg Translers
Transfers Per Facilitv
43,274,807
138,751
122,317
3,333,894
2,667
189,798
5
26,652
14,444
69,660
1,444,471
196,900
138
1,232,354
23,971
120,087
115
6,585
164,195
6,442
485
101,403
306
65,760
94,228
815
74,252
111,472
384,042
10,296
264
910
6,897
38,661
13,535
19
4
37,268
26,600
6,901
127,400
1 1 ,000
24,320
350
2,200
50
840
675
248,706
836
979
26,886
22
1,636
0
254
142
704
15,047
2,263
'i
16,005
320
1,876
"i
122
4,105
201
21
6,338
20
4,384
7,248
68
8,250
12,386
42,671
1,471
38
182
1,379
7,732
4,512
•
12,423
13,300
3,450
63,700
5,500
12,160
350
2,200
50
840
675
Sector Notebook Project
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Chemical Releases and Transfers
Table 15: 2000 TRI Transfers for Pulp and Paper Facilities (SICs 261, 262 and 263),
by Number of Facilities Reporting (Transfers Reported in pounds/year)
Chemical Name
Methyl Methacrylate
Acrylic Acid
Trichloroethylene
Dichloromethane
Polychlorinated Alkanes
Barium
Mixture
tt Reporting POTW Disposal
Chemical Transfers Transfers
I
1
1 4,985
1
1
1 5,100
1
268*' 37.103.508 6.306.166
Recycling Treatment Energy Total Avg Transfers
Transfers Transfers Recovery Transfers Per Facility
750 750
4,985
24,000 24,000
5,100
354.926 7.316.423 463.018 51.544.041
750
4,985
24,000
5,100
192.328
[PBT] Persistent, Bioaccumiilative, and Toxic
* Refer to Section III for a discussion of the TRI data and its limitations, methodology used to obtain this data, definitions of the column headings,
and the definition of persistant, bioaccumulative, and toxic chemicals.
"•Total number of facilities (not chemical reports) reporting to TRI in this industry sector.
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Chemical Releases and Transfers
The TRI database contains a detailed compilation of self-reported, facility-
specific chemical releases. The top reporting facilities for this sector are
listed below (Table 16).
Table 16: Ten Largest Volume TRI Releasing Facilities in the Pulp and Paper Industry*
Rank
1
2
3
4
5
6
7
8
9
10^
Facility
Westvaco Corporation - Covington, VA
International Paper - Mansfield, LA
International Paper Company Camden Facility - Camden, AR
International Paper - Bleachboard Department - Riegelwood, NC
Georgia Pacific Corporation Port Hudson Operations - Zachary, LA
Smurfit Stone Container Corporation - Missoula, MT
Great Southern Paper Co - Cedar Springs, GA
Stora Enso North America Corporation - Wisconsin Rapids, Wl
Weyerhaeuser Company - Valliant, OK
International Paner Georgetown Mill - Georgetown. SC
Total TRI Releases it
Pounds
5,066,296
4,472,550
3,842,484
3,619,809
3,292,540
3.133,396
3,125,666
3,095,151
3,041,630
2.967.101
Source: 2000 Toxics Release Inventory Database
* Being included in this list does not mean that the release is associated with non-compliance with environmental laws.
IV.B. Summary of Selected Chemicals Released
The following is a synopsis of current scientific toxicity and fate information
for the top chemicals (by weight) that facilities within this sector self-
reported as released to the environment based upon 2000 TRI data. Because
this section is based upon self-reported release data, it does not attempt to
provide information on management practices employed by the sector to
reduce the releases of these chemicals. Information regarding pollutant
release reductions over time may be available from EPA's TRI program, or
directly from the industrial trade associations that are listed in Section IX of
this document. Since these descriptions are cursory, please consult the
sources referenced below for a more detailed description of both the
chemicals described in this section, and the chemicals that appear on the full
list of TRI chemicals appearing in Section IV. A.
The brief descriptions provided below were taken from the Hazardous
Substances Data Bank (HSDB), accessed via TOXNET. TOXNET is a
computer system run by the National Library of Medicine. It includes a
number of lexicological databases managed by EPA, National Cancer
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Chemical Releases and Transfers
Institute, and the National Institute for Occupational Safety and Health.2
HSDB contains chemical-specific information on manufacturing and use,
chemical and physical properties, safety and handling, toxicity and
biomedical effects, pharmacology, environmental fate and exposure
potential, exposure standards and regulations, monitoring and analysis
methods, and additional references. The information contained below is
based upon exposure assumptions that have been conducted using standard
scientific procedures. The effects listed below must be taken in context of
these exposure assumptions that are more fully explained within the full
chemical profiles in HSDB. For more information on TOXNET, contact the
TOXNET help line at 800-231 -3766 or see the website at
http://toy.net. nlm. nih. g-ov/.
Methanol (CAS: 67-56-1)
Toxicity, Methanol is readily absorbed from the gastrointestinal tract and the
respiratory tract, and is toxic to humans in moderate to high doses. In the
body; methanol is converted into formaldehyde and formic acid. Methanol
is excreted as formic acid. Observed toxic effects at high dose levels
generally include central nervous system damage and blindness. Long-term
exposure to high levels of methanol via inhalation cause liver and blood
damage in animals.
Ecologically, methanol is expected to have low toxicity to aquatic organisms.
Concentrations lethal to half the organisms of a test population are expected
to exceed one milligram of methanol per liter of water. Methanol is not
likely to persist in water or to bioaccumulate in aquatic organisms.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. Liquid methanol is likely to evaporate when left
exposed. Methanol reacts in air to produce formaldehyde which contributes
to the formation of air pollutants. In the atmosphere it can react with other
atmospheric chemicals or be washed out by rain. Methanol is readily
degraded by microorganisms in soils and surface waters.
Physical Properties. Methanol is highly flammable.
2 Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research Information System), DART
(Developmental and Reproductive Toxicity Database), DBIR (Directory of Biotechnology Information Resources),
EM1CBACK (Environmental Mutagen Information Center Backfile), GENE-TOX (Genetic Toxicology), HSDB
(Hazardous Substances Data Bank), IRIS (Integrated Risk Information System), RTECS (Registry of Toxic Effects
of Chemical Substances), and TRI (Toxic Chemical Release Inventory).
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Chemical Releases and Transfers
Ammonia (CAS: 7664-41-7)
Toxicity. Anhydrous ammonia is irritating to the skin, eyes, nose, throat, and
upper respiratory system.
Ecologically, ammonia is a source of nitrogen (an essential element for
aquatic plant growth), and may therefore contribute to eutrophication of
standing or slow-moving surface water, particularly in nitrogen-limited
waters such as the Chesapeake Bay. In addition, aqueous ammonia is
moderately toxic to aquatic organisms.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate, Ammonia combines with sulfate ions in the
atmosphere and is washed out by rainfall, resulting in rapid return of
ammonia to the soil and surface waters.
Ammonia is a central compound in the environmental cycling of nitrogen.
Ammonia in lakes, rivers, and streams is converted to nitrate.
Physical Properties. Ammonia is a corrosive and severely irritating gas
with a pungent odor.
Hydrochloric Acid (CAS: 7647-01-1)
Toxicity. Hydrochloric acid is primarily a concern in its aerosol form. Acid
aerosols have been implicated in causing and exacerbating a variety of
respiratory ailments. Dermal exposure and ingestion of highly concentrated
hydrochloric acid can result in corrosivity.
Ecologically, accidental releases of solution forms of hydrochloric acid may
adversely affect aquatic life by including a transient lowering of the pH (i.e.,
increasing the acidity) of surface waters.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. Releases of hydrochloric acid to surface waters and
soils will be neutralized to an extent due to the buffering capacities of both
systems. The extent of these reactions will depend on the characteristics of
the specific environment.
Physical Properties. Concentrated hydrochloric acid is highly corrosive.
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Chemical Releases and Transfers
Manganese Compounds
Toxicity. Manganese is an essential nutrient for most plants and animals.
However, at high concentrations can produce an irreversible syndrome
resembling Parkinson's disease.
Carcinogenicity. There is currently no evidence to suggest that manganese
chemicals are carcinogenic.
Environmental Fate. As ions or insoluble solids, most manganese
compounds are not expected to volatilize from water and moist soil surfaces.
Manganese compounds released into the ambient atmosphere are expected
to exist in the paniculate phase. In the paniculate phase, manganese
compounds may be removed from the air by wet and dry deposition.
Manganese compounds do not bioconcentrate in humans and animals.
SuZfuric Acid (CAS: 7664-93-9)
Toxicity. Concentrated sulfuric acid is corrosive. In its aerosol form,
sulfuric acid has been implicated in causing and exacerbating a variety of
respiratory ailments.
Ecologically, accidental releases of solution forms of sulfuric acid may
adversely affect aquatic life by inducing a transient lowering of the pH (i.e.,
increasing the acidity) of surface waters. In addition, sulfuric acid in its
aerosol form is also a component of acid rain. Acid rain can cause serious
damage to crops and forests.
Carcinogenicity. There is currently no evidence to suggest that this
chemical is carcinogenic.
Environmental Fate. Releases of sulfuric acid to surface waters and soils
will be neutralized to an extent due to the buffering capacities of both
systems. The extent of these reactions will depend on the characteristics of
the specific environment.
In the atmosphere, aerosol forms of sulfuric acid contribute to acid rain.
These aerosol forms can travel large distances from the point of release
before the acid is deposited on land and surface waters in the form of rain.
IV.C. Other Data Sources
The toxic chemical release data obtained from TRI captures the vast maj ority
of facilities in the pulp and paper industry. It also allows for a comparison
across years and industry sectors. Reported chemicals are limited, however,
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Chemical Releases and Transfers
to the approximately 650 required by TRI. Some pulp and paper emissions
may not be captured by TRI, The EPA Office of Air Quality, Planning, and
Standards has compiled air pollutant emission factors for determining the
total air emissions of priority pollutants (e.g., total hydrocarbons, SOX, NOX,
CO, particulates, etc.) from many sources.
The EPA Office of Air's Aerometric Information Retrieval System (AIRS)
contains a wide range of information related to stationary sources of air
pollution, including the emissions of a number of air pollutants which may
be of concern within a particular industry. With the exception of volatile
organic compounds (VOCs), there is little overlap with the TRI chemicals
reported above. Table 17 summarizes releases in 2001 of volatile organic
compounds (VOCs), nitrogen oxides (NOX), carbon monoxide (CO), sulfur
dioxide (S02), and particulate matter of 10 microns or less (PM10).
Table 17: Air Pollutant Releases bv Industry Sc
Industry Sector
Metal Mining
Oil and Gas Extraction
Non-Fuel, Non-Metal Mineral Mining
Textiles
Lumber and Wood Products
Wood Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Plastic Resins and Man-made Fibers
Pharmaceuticals
Organic Chemicals
Agricultural Chemicals
Petroleum Refining
Rubber and Plastic
Stone, Clay, Glass and Concrete
Iron and Steel
Metal Castings
Nonferrous Metals
Fabricated Metal Products
Electronics and Computers
Motor Vehicle Assembly
Aerospace
Shipbuilding and Repair
Ground Transportation
Water Transportation
Air Transportation
Fossil Fuel Electric Power
Dry Cleaning
CO
8,039
151,763
27,001
7,448
142,955
7,046
567,542
604
176,697
28,890
2,662
128,454
18,492
438,375
2,515
161,113
1,080,576
104,350
418,647
6,029
22,105
13,439
2,832
471
711,155
83
5,231
436,151
217
N02
45,341
366,793
15,747
15,043
37,313
3,008
318,263
2,466
94,938
56,946
14,676
166,398
65,389
298,602
9,565
372,679
105,794
6,298
30,882
11,672
6,428
15,388
7,413
2,139
6,681,163
153
2,079
5,789,099
438
PM10
61,358
4,607
48,760
5,343
57,009
6,905
85,403
1,723
19,549
5,493
2,273
34,637
10,257
33,620
5,209
127,283
60,962
22,393
24,019
4,691
3,184
4,016
1,834
1,574
285,932
2,162
186
252,539
190
ctor ftons/vear)
PM25
32,534
4,379
20,956
3,386
38,337
5,260
63,577
1,723
12,586
4,155
1,455
16,900
7,311
26,870
3,217
78,647
47,501
15,654
17,433
3,264
2,349
2,270
1,287
753
165,029
733
140
141,002
117
S02
10,926
226,208
16,874
25,544
9,189
2,779
488,029
1,915
201,994
71,815
17,132
102,461
65,765
478,998
20,368
312,740
307,981
4,770
244,413
18,742
6,882
24,123
5,363
2,537
12,976,279
66
90
12,667,567
220
voc
2,109
94,549
3,806
18,286
100,761
62,457
144,373
80,982
43,563
83,363
13,407
159,3 It
12.70C
161,207
87,258
32,687
44,60*
17,285
8,663
90,575
27,453
95,861
7.44C
4,98'
191,063
6,787
2,398
54,727
3,163
Source: U S. EPA Office of Air and Radiation. AIRS Database. 2001 .
Sector Notebook Project
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Chemical Releases and Transfers
IV.D. Comparison of Toxic Release Inventory Between Selected Industries
The following information is presented as a comparison of pollutant release
and transfer data across industrial categories. It is provided to give a general
sense as to the relative scale of releases and transfers within each sector
profiled under this project. Please note that the following figure and table do
not contain releases and transfers for industrial categories that are not
included in this project, and thus cannot be used to draw conclusions
regarding the total release and transfer amounts that are reported to TRI.
Similar information is available within the annual TRI Public Data Release
Report.
Figure 12 is a graphical representation of a summary of the 2000 TRI data for
the Pulp and Paper industry and the other sectors profiled in separate
notebooks. The bar graph presents the total TRI releases and total transfers
on the left axis and the triangle points show the average releases per facility
on the right axis. Industry sectors are presented in the order of increasing
total TRI releases. The graph is based on the data shown in Table 17 and is
meant to facilitate comparisons between the relative amounts of releases,
transfers, and releases per facility both within and between these sectors. The
. reader should note, however, that differences in the proportion of facilities
captured by TRI exist between industry sectors. This can be a factor of poor
SIC matching and relative differences in the number of facilities reporting to
TRI from the various sectors. In the case of Pulp and Paper industry the
2000 TRI data presented here covers 268 facilities. These facilities listed SIC
2611 -2631 (Pulp, Paper, and Paperboard Mills) as primary SIC codes.
Sector Notebook Project
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Pulp and Paper Industry
Chemical Releases and Transfers
Figure 12: 2000 Summary of TRI Releases and Transfers by Industry
400 -
350 -
g 300 -
_o
1 250 -
en
TJ
= 200 -
i3
O
0.
5 150-
o
I-
100 -
50 -
-i
__ |»-
n
•
• • i
n 1 i-l 1
_ !-• 1 L PB 1 B 1 H 1 H 1
r
1 ^ i ' "^ i ' "" I r i i 1 T^ r T^
QCMM- LOcO'co *- S 3 S
T-CMCN CMCOl*- ^SS
•r '•• " CM CM
SS fc oo" co"
CN CN CM CO
29 w
CM CM
CO
CM
D Total Releases
[1
i
T
CO
1
i
rl
1
r
\
H
1
rl
JJ
T^ O OJ ^ ^? ^ ^ ^O ^
T" to co cO c^ (v rt en ^
•^
„
g g
SIC Range
• Total Transfers
CD T- CO
N- CO Ol
CO h- rf
- CO
CN T-
1^ T-
CO O)
xf
Key to Standard Industrial Classification (SIC) Codes
SIC Range
02
01, OR
10
13
14
22
24
25
261-263
271-278
Industry Sector
Agricultural Crops, Forestry
Agricultural Livestock
Metal Mining
Oil and Gas Extraction
Non-Fuel, Non-Metal Mining
Textiles
Lumber and Wood Products
Furniture and Fixtures
Pulp and Paper
Printing
SIC Range
281
2821,2823,
2824
2833, 2834
286
287
2911
30
32
331
332, 336
Industry Sector
Inorganic Chemicals
Plastic Resins and Man-made
Fibers
Pharmaceuticals
Organic Chemicals
Agricultural Chemicals
Petroleum Refining
Rubber and Plastic
Stone, Clay, Glass and Concrete
Iron and Steel
Metal Casting
SIC Range
333,334
34
36
371
372, 376
3731
40, 42, 46, 4922-
4925,4932
44
45
4911,493
7216
Industry Sector
Nonferrous Metals
Fabricated Metals
Electronics and Computers
Motor Vehicle Assembly
Aerospace
Shipbuilding and Repair
Ground Transportation
Water Transportation
Air Transportation
Fossil Fuel Electric Power Generation
Dry cleaning
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Chemical Releases and Transfers
CO
•3 IS I
« .a J
B H 'E
Sj^ ^
j3 pt
111
a u. j
« S .S
rf
n
n.
stry Secto
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Pulp and Paper Industry
Pollution Prevention
V. POLLUTION PREVENTION OPPORTUNITIES
The best way to reduce pollution is to prevent it in the first place. Industries
have creatively implemented pollution prevention techniques that improve
efficiency and increase profits while at the same time minimizing
environmental impacts. This can be done in many ways such as reducing
material inputs, re-engineering processes to reuse by-products, improving
management practices, and employing substitution of toxic chemicals. Some
smaller facilities are able to actually get below regulatory thresholds just by
reducing pollutant releases through aggressive pollution prevention policies.
In order to encourage these approaches, this section provides both general
and company-specific descriptions of some pollution prevention advances
that have been implemented within the pulp and paper industry. While the
list is not exhaustive, it does provide core information that can be used as the
starting point for facilities interested in beginning their own pollution
prevention projects. When possible, this section provides information from
real activities that can, or are being implemented by this sector - including
a discussion of associated costs, time frames, and expected rates of return.
This section provides summary information from activities that may be, or
are being implemented by this sector. When possible, information is
provided that gives the context in which the technique can be effectively
used. Please note that the activities described in this section do not
necessarily apply to all facilities that fall within this sector. Facility-specific
conditions must be carefully considered when pollution prevention options
are evaluated, and the full impacts of the change must examine how each
option affects air, land and water pollutant releases.
Pollution Prevention Opportunities for the Pulp and Paper Industry
The chemical recovery systems used in chemical pulping processes are an
example of pollution prevention technologies that have evolved alongside
process technologies. An efficient chemical recovery system is a crucial
component of chemical pulping mill operation: the chemical recovery
process regenerates process chemicals, reducing natural resource usage and
associated costs, as well as discharges to the environment and producing
energy. Many recent pollution prevention efforts in the pulp and paper
industry have focused on reducing the releases of toxics, in particular,
chlorinated compounds. Pollution prevention techniques have proven to be
more effective in controlling these pollutants than conventional control and
treatment technologies. Most conventional, end-of-pipe treatment
technologies are not effective in destroying many chlorinated compounds and
often merely transfer the pollutants to another environmental medium.
Efforts to prevent chlorinated releases have, therefore, focused on source
reduction and material substitution techniques such as defoamers, bleaching
chemical or wood chip substitution to reduce the industry's use and releases
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Pollution Prevention
of chlorinated compounds. Such source reduction efforts and material
substitutions usually require substantial changes in the production process.
In addition to the major process changes aimed at reducing toxics releases,
the industry is implementing a number of pollution prevention techniques to
reduce water use and pollutant releases (BOD, COD, and TSS) such as: dry
debarking, recycling of log flume water, improved spill control, bleach
filtrate recycle, closed screen rooms, and improved storm water management.
The pulp and paper industry has also worked to increase the amount of
secondary and recycled fibers used for the pulping process. According to
industry sources, the pulp and paper industry set and met a 1995 goal of 40
percent recycling and reuse of all paper consumed in the U.S. Currently, the
industry has set a new goal of recovering 50 percent of all paper consumed
in the U. S. for recycle and reuse. These figures should be compared with the
utilization rate of secondary fibers (secondary fibers as a percentage of the
total fibers used to make pulp) which is at approximately 37 percent and is
climbing slowly (AF&PA, 1999), Current secondary fiber utilization rates
in resource deficient countries such as Japan are close to 50 percent.
Because the pulp and paper industry is highly capital intensive and uses long-
established technologies with long equipment lifetimes, major process-
changing pollution prevention opportunities are expensive and require long
time periods to implement. The pulp and paper industry is a dynamic one,,
however, that constantly makes process changes and material substitutions
to increase productivity and cut costs. The trend towards materials
substitutions is reflected in an increasing demand for alternative pulping and
bleaching chemicals and in the participation of many facilities in voluntary
environmental programs (see Section VIII).
One of the factors that is driving the industry towards pollution prevention
much more rapidly is the integrated NESHAP and effluent limitation
guidelines for the pulp and paper industry. (See Section VLB. for a
description of this "cluster rule.") These regulations were developed together
in part to reduce the costs of compliance, to emphasize the multi-media
nature of pollution control, and to promote pollution prevention. Many ofthe
technology-based effluent limitation guidelines for the control of toxic
releases consist of process changes that substitute chlorine dioxide for
elemental chlorine and that completely eliminate elemental chlorine in
bleaching processes. The NESHAP standards also allow Hazardous Air
Pollutant (HAP) reductions through recycling of wastewater streams to a
process unit and routing pulping emissions to a boiler, lime kiln, or recovery
furnace.
Brief descriptions of some ofthe pollution prevention techniques found to be
effective at pulp and paper facilities are provided below. For more detail on
the pollution prevention options listed below and for descriptions of
additional alternative pulping and bleaching processes refer to the Office of
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Pollution Prevention
Pollution Prevention and Toxics' 1993 report, Pollution Prevention
Technologies for the Bleached Kraft Segment of the U.S. Pulp and Paper
Industry and other pollution prevention/waste minimization documents listed
in Resource Materials section. It should be noted that although many of the
pollution prevention opportunities listed below are primarily aimed at
reducing toxics releases, the process changes can often lead to reductions in
the conventional pollutants such as BOD5 and TSS as well as COD, AOX,
and contribute to reduced water use, sludge volumes generated, and air
emissions.
Extended Delignification. Extended delignification further reduces the
lignin content of the pulp before it moves to the bleach plant. Because the
amount of bleaching chemicals required to achieve a certain paper brightness
is proportional to the amount of lignin remaining in the pulp after the pulping
process, extended delignification can reduce the amounts of bleaching
chemicals needed. A number of different extended delignification processes
have been developed. These processes involve: increasing the cooking time;
adding the cooking chemicals at several points throughout the cooking
process; regulating the cooking temperatures; and carefully controlling the
concentration of hydrogen sulfide ions and dissolved lignin. Importantly, the
process changes do not degrade the cellulose which would normally
accompany increased cooking time. Extended delignification processes have
been developed for both batch and continuous pulping processes. The lignin
content of the brownstock pulp has been reduced by between 20 and 50
percent with no losses in pulp yield or strength using such processes. In
consequence, chlorinated compounds generated during bleaching are reduced
in approximate proportion to reductions in the brownstock lignin content. In
addition, the same changes have resulted in significant reductions in BOD5,
COD and color. One study demonstrated a 29 percent decrease in BOD5
resulting from an extended delignification process. Facility energy
requirements have been shown to increase slightly with extended
delignification. However, off-site power requirements (associated with
decreased chemical use) have been estimated to more than offset the on-site
increases.
Oxygen Delignification. Oxygen delignification also reduces the lignin
content in the pulp. The process involves the addition of an oxygen reactor
between the kraft pulping stages and the bleach plant. The brownstock pulp
from the digester is first washed and then mixed with sodium hydroxide or
oxidized cooking liquor. The pulp is fluffed, deposited in the oxygen reactor,
steam heated, and injected with gaseous oxygen wherein it undergoes
oxidative delignification. The pulp is then washed again to remove the
dissolved lignin before moving to the bleaching plant. Oxygen
delignification can reduce the lignin content in the pulp by as much as 50
percent resulting in a potentially similar reduction in the use of chlorinated
bleaching chemicals and chlorinated compound pollutants. The process can
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Pollution Prevention
be used in combination with other process modifications that can completely
eliminate the need for chlorine-based bleaching agents. In addition, unlike
bleach plant filtrate, the effluent from the oxygen reactor can be recycled
through the pulp mill recovery cycle, further reducing the non-pulp solids
going to the bleaching plant and the effluent load from the bleach plant. The
net effect is reduced effluent flows and less sludge generation. Facility
energy requirements have been shown to increase with ' oxygen
delignification, however, the decrease in off-site power requirements
(associated with decreased chemical use) have been estimated to exceed the
on-site increases resulting in a decrease in overall energy requirements.
Also, the recovered energy and reduced chemical use offset the cost.
Ozone Delignification. As a result of a considerable research effort, ozone
delignification (ozone bleaching) is now being used in a limited number of
pulp mills. The technology has the potential to eliminate the need for
chlorine in the bleaching process. Ozone delignification is performed using
processes and equipment similar to that of oxygen delignification. The ozone
process, however, must take place at a very low pH (1.0 to 2.0), requiring the
addition of sulfuric acid to the pulp prior to the ozonation. In addition to low
pH, a number of process conditions are critical for ozone delignification:
organic materials must be almost completely washed out of the brownstock
pulp; temperatures must stay at about 20 °C; and ozone reactive metals must
be removed prior to the ozonation stage. Oxygen delignification and/or
extended delignification processes are considered a prerequisite for
successful ozone bleaching. When used in combination, the two processes
can result in a high quality bright pulp that requires little or no chlorine or
chlorine dioxide bleaching. Overall emissions from the combination of the
oxygen and ozone processes are substantially lower than conventional
processes because effluents from each stage can be recycled. Pilot systems
consisting of ozone delignification in combination with oxygen
delignification and oxygen extraction have shown reductions in BOD5 of 62
percent, COD of 53 percent, color of 88 percent, and organic chlorine
compounds of 98 percent. However, ozone is unstable and will decompose
to molecular oxygen, thus ozone must be generated on-site and fed
immediately to the pulp reactor. Ozone generation systems are complex and
account for a high percentage of the total costs. Facility energy use will
increase due to the on-site production of ozone, however, this energy will be
offset by the energy that would normally be used to produce chlorine and
chlorine dioxide.
Anthraquinone Catalysis. The addition of anthraquinone (a chemical
catalyst produced from coal tar) to the pulping liquor has been shown to
speed up the kraft pulping reaction and increase yield by protecting cellulose
fibers from degradation. The anthraquinone accelerates the fragmentation of
lignin, allowing it to be broken down more quickly by the pulping chemicals.
This lowers the amount of lignin in the prechlorination pulp, thus reducing
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the amount of bleaching chemicals needed. Anthraquinone catalysts are
increasingly used in combination with oxygen delignification and extended
delignification to overcome boiler capacity bottlenecks arising from these
delignification processes. ,
Black Liquor Spill Control and Prevention. The mixture of dissolved
lignin and cooking liquor effluent from the pulping reactor and washed pulp
is known as black liquor. Raw black liquor contains high levels of BOD,
COD, and organic compounds. Spills of black liquor can result from
overflows, leaks from process equipment, or from deliberate dumping by
operators to avoid a more serious accident. Spills of black liquor can have
impacts on receiving waters, are a source of air emissions, and can shock the
microbial action of wastewater treatment systems. Black liquor losses also
result in the loss of the chemical and heat value of the material. Systems
needed to control black liquor spills are a combination of good design,
engineering, and, most importantly, operator training. A few elements of an
effective spill control system include: physical isolation of pieces of
equipment; floor drainage systems that allow spills to be collected; backup
black liquor storage capacity; sensors that provide immediate warning of
potential or actual spills; and enclosed washing and screening equipment.
Enzyme Treatment of Pulp. Biotechnology research has resulted in the
identification of a number of microorganisms that produce enzymes capable
of breaking down lignin in pulp. Although the technology is new, it is
believed that a number of mills are currently conducting enzyme treatment
trials. The microorganisms capable of producing the necessary enzymes are
called xylanases. Xylanases for pulp bleaching trials are available from
several biotechnology and chemical companies. Since enzymes are used as
a substitute for chemicals in bleaching pulp, their use will result in a decrease
in chlorinated compounds released somewhat proportional to the reduction
in bleaching chemicals used. Enzymes are also being used to assist in the
deinking of secondary fiber. Research at the Oak Ridge National
Laboratories has identified cellulase enzymes that will bind ink to the smaller
fiber particles facilitating recovery of the ink sludge. Use of enzymes may
also reduce the energy costs and chemical use in retrieving ink sludge from
deinking effluent.
Improved Brownstock and Bleaching Stage Washing. Liquor solids
remaining in the brownstock pulp are carried over to the bleach plant and
then compete with the remaining lignin in the pulp for reaction with the
bleaching chemicals. Improved washing, therefore, can reduce the required
amount of bleaching chemicals and the subsequent reductions in chlorinated
compounds as well as conventional pollutants. Modern washing systems
with improved solids removal and energy efficiency are beginning to replace
the conventional rotary vacuum washers. State-of-the-art washing systems
include: atmospheric or pressure diffusion washers, belt washers, and pulp
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presses. Opportunities for reduced effluent flows and water use are also
present in the bleaching plant. Acid filtrates from hypochlorite or chlorine
dioxide stages can be used as dilution and wash water for the first bleaching
stage. Similarly, second extraction stage filtrates can be used as dilution and
wash water in the first extraction stage. Most new mills are designed with
these counter-current washing systems and some mills are retrofitting their
existing wash systems.
Improved Chipping and Screening. The size and thickness of wood chips
is critical for proper circulation and penetration of the pulping chemicals.
Chip uniformity is controlled by the chipper and screens that remove under
and oversized pieces. Standard equipment normally does not sort chips by
thickness although it has been demonstrated that chip thickness is extremely
important in determining the lignin content of pulp. Improper chip
thicknesses can therefore result in increased use of bleaching chemicals and
the associated chlorinated compounds and conventional pollutants. Some
mills are beginning to incorporate equipment that will separate chips
according to their thickness as well as by length and width.
Oxygen-Reinforced/Peroxide Extraction. Oxygen-reinforced extraction
(or oxidative extraction) and peroxide-reinforced extraction processes used
separately or together have been shown to reduce the amount of elemental
chlorine and chlorine dioxide needed in the bleaching process while
increasing the pulp brightness. Gaseous elemental oxygen (in the case of
oxygen-reinforced extraction) and aqueous hydrogen peroxide (in the case
of peroxide extraction) are used as a part of the first alkaline extraction stage
to facilitate the solubilization and removal of chlorinated and oxidized lignin
molecules. Oxygen-reinforced extraction has seen widespread adoption by
the industry in recent years. It is estimated that up to 80 percent of mills in
the U;S. are using oxygen-reinforced extraction. The use of peroxide
extraction is also increasing. As of 1987, it was estimated that 25 percent of
domestic mills were using peroxide extraction.
Improved Chemical Controls and Mixing. The formation of chlorinated
organics can be minimized by avoiding excess concentrations of chlorine-
based bleaching chemicals within reactor vessels. This can be accomplished
by carefully controlling the chemical application rates and by ensuring proper
mixing of chemicals within the reactor. Modem chemical application control
and monitoring systems and high-shear mixers have been developed which
decrease formation of chlorinated organic compounds.
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VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS
This section discusses the federal regulations that may apply to this sector.
The purpose of this section is to highlight and briefly describe the applicable
federal requirements, and to provide citations for more detailed information.
The three following sections are included:
• Section VI.A contains a general overview of major statutes
• Section VLB contains a list of regulations specific to this industry
* Section VI.C contains a list of pending and proposed regulatory
requirements.
The descriptions within Section VI are intended solely for general
information. Depending upon the nature or scope of the activities at a
particular facility, these summaries may or may not necessarily describe all
applicable environmental requirements. Moreover, they do not constitute
formal interpretations or clarifications of the statutes and regulations. For
further information, readers should consult the Code of Federal Regulations
and other state or local regulatory agencies. EPA Hotline contacts are also
provided for each major statute.
VI.A. General Description of Major Statutes
Clean Water Act
The primary objective oftheFederal Water Pollution Control Act, commonly
referred to as the Clean Water Act(CWA), is to restore and maintain the
chemical, physical, and biological integrity of the nation's surface waters.
Pollutants regulated under the CWA are classified as either "toxic"
pollutants; "conventional" pollutants, such as biochemical oxygen demand
(BOD), total suspended solids (TSS), fecal coliform, oil and grease, andpH;
or "non-conventional" pollutants, including any pollutant not identified as
either conventional or priority.
The CWA regulates both direct and "indirect" dischargers (those who
discharge to publicly owned treatment works). The National Pollutant
Discharge Elimination System (NPDES) permitting program (CWA section
402) controls direct discharges into navigable waters. Direct discharges or
"point source" discharges are from sources such as pipes and sewers.
NPDES permits, issued by either EPA or an authorized state (EPA has
authorized 43 states and one territory to administer the NPDES program),
contain industry-specific, technology-based and water quality-based limits
and establish pollutant monitoring and reporting requirements. A facility that
proposes to discharge into the nation's waters must obtain a permit prior to
initiating a discharge. A permit applicant must provide quantitative
analytical data identifying the types of pollutants present in the facility's
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effluent. The permit will then set forth the conditions and effluent limitations
under which a facility may make a discharge.
Water quality-based discharge limits are based on federal or state water
quality criteria or standards, that were designed to protect designated uses of
surface waters, such as supporting aquatic life or recreation. These
standards, unlike the technology-based standards, generally do not take into
account technological feasibility or costs. Water quality criteria and
standards vary from state to state, and site to site, depending on the use
classification of the receiving body of water. Most states follow EPA
guidelines which propose aquatic life and human health criteria for many of
the 126 priority pollutants.
Storm Water Discharges.
In 1987 the CWA was amended to require EPA to establish a program to
address storm water discharges. In response, EPA promulgated NPDES
permitting regulations for storm water discharges. These regulations require
that facilities with the following types of storm water discharges, among
others, apply for an NPDES permit: (1) a discharge associated with industrial
activity; (2) a discharge from a large or medium municipal storm sewer
system; or (3) a discharge which EPA or the state determines to contribute
to a violation of a water quality standard or is a significant contributor of
pollutants to waters of the United States.
The term "storm water discharge associated with industrial activity" means
a storm water discharge from one of 11 categories of industrial activity
defined at 40 CFR Part 122.26, Six of the categories are defined by SIC
codes while the other five are identified through narrative descriptions of the
regulated industrial activity. If the primary SIC code of the facility is one of
those identified in the regulations, the facility is subject to the storm water
permit application requirements. If any activity at a facility is covered by
one of the five narrative categories, storm water discharges from those areas
where the activities occur are subject to storm water discharge permit
application requirements.
Those facilities/activities that are subject to storm water discharge permit
application requirements are identified below. To determine whether a
particular facility falls within one of these categories, the regulation should
be consulted.
Category i: Facilities subject to storm water effluent guidelines, new source
performance standards, or toxic pollutant effluent standards.
Category ii: Facilities classified as SIC 24-lumber and wood products
(except wood kitchen cabinets); SIC 26-paper and allied products (except
paperboard containers and products); SIC 28-chemicals and allied products
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(except drugs and paints); SIC 29-petroieum refining; SIC 311-leather
tanning and finishing; SIC 32 (except 323)-stone, clay, glass, and concrete;
SIC 33-primary metals; SIC 3441-fabricated structural metal; and SIC 373-
ship and boat building and repairing.
Category Hi: Facilities classified as SIC 10-metal mining; SIC 12-coal
mining; SIC 13-oil and gas extraction; and SIC 14-nonmetallic mineral
mining.
Category iv: Hazardous waste treatment, storage, or disposal facilities.
Category v: Landfills, land application sites, and open dumps that receive
or have received industrial wastes.
Category vi: Facilities classified as SIC 5015-used motor vehicle parts; and
SIC 5093-automotive scrap and waste material recycling facilities.
Category vii: Steam electric power generating facilities.
Categoryviii: Facilities classifiedas SIC 40-railroad transportation; SIC41-
local passenger transportation; SIC 42-trucking and warehousing (except
public warehousing and storage); SIC 43-U.S. Postal Service; SIC 44-water
transportation; SIC 45-transportation by air; and SIC 5171-petroleum bulk
storage stations and terminals.
Category ix: Sewage treatment works.
Category x; Construction activities except operations that result in the
disturbance of less than five acres of total land area.
Category xi: Facilities classified as SIC 20-food and kindred products; SIC
21-tobacco products; SIC 22-textile mill products; SIC 23-apparel related
products; SIC 2434-wood kitchen cabinets manufacturing; SIC 25-furniture
and fixtures; SIC 265-paperboard containers and boxes; SIC 267-converted
paper and paperboard products; SIC 27-printing, publishing, and allied
industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enamels, and
allied products; SIC 30-rubber and plastics; SIC 31-leather and'leather
products (except leather and tanning and finishing); SIC 323-glass products;
SIC 34-fabricated metal products (except fabricated structural metal); SIC
3 5-industrial and commercial machinery and computer equipment; SIC 36-
electronic and other electrical equipment and components; SIC 37-
transportation equipment (except ship and boat building and repairing); SIC
38-measuring, analyzing, and controlling instruments; SIC 39-misceIlaneous
manufacturing industries; and SIC 4221-4225-public warehousing and
storage.
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Phase II storm water requirements were established in 1999. Permits are now
required for certain small municipal separate storm sewer systems (MS4s)
and for construction activity disturbing between one and five acres of land
(i.e., small construction activities). The Phase II rule also revised the "no
exposure" exclusion and the temporary exemption for certain industrial
facilities that had been established under Phase I regulations.
Pretreatment Program
Another type of discharge that is regulated by the CWA is one that goes to
a publicly owned treatment works (POTW). The national pretreatment
program (CWA section 307(b)) controls the indirect discharge of pollutants
to POTWs by "industrial users." Facilities regulated under section 307(b)
must meet certain pretreatment standards. The goal of the pretreatment
program is to protect municipal wastewater treatment plants from damage
that may occur when hazardous, toxic, or other wastes are discharged into a
sewer system and to protect the quality of sludge generated by these plants.
EPA has developed technology-based standards for industrial users of
POTWs. Different standards apply to existing and new sources within each
category. "Categorical" pretreatment standards applicable to an industry on
a nationwide basis are developed by EPA. In addition, another kind of
pretreatment standard, "local limits," are developed by the POTW in order
to assist the POTW in achieving the effluent limitations in its NPDES permit.
Regardless of whether a state is authorized to implement either the NPDES
or the pretreatment program, if it develops its own program, it may enforce
requirements more stringent than federal standards.
Wetlands
Wetlands, commonly called swamps, marshes, fens, bogs, vernal pools,
playas, and prairie potholes, are a subset of "waters of the United States," as
defined in Section 404 of the CWA. The placement of dredge and fill
material into wetlands and other water bodies (i.e., waters of the United
States) is regulated by the U.S. Army Corps of Engineers (Corps) under 33
CFR Part 328. The Corps regulates wetlands by administering the CWA
Section 404 permit program for activities that impact wetlands. EPA's
authority under Section 404 includes veto power of Corps permits, authority
to interpret statutory exemptions and jurisdiction, enforcement actions, and
delegating the Section 404 program to the states.
EPA's Office of Water, at 202-566-J 730, will direct callers with questions
about the CWA to the appropriate EPA office. EPA also maintains a
bibliographic database of Office of Water publications which can be
accessed through the Ground Water and Drinking Water Resource Center,
at 1-800-426-4791.
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Oil Pollution Prevention Regulation
Section 311 (b) of the CWA prohibits the discharge of oil, in such quantities
as may be harmful, into the navigable waters of the United States and
adjoining shorelines. The EPA Discharge of Oil regulation, 40 CFR Part
110, provides information regarding these discharges. The Oil Pollution
Prevention regulation, 40 CFR Part 112, under the authority of Section 31 l(j)
of the CWA, requires regulated facilities to prepare and implement Spill
Prevention Control and Countermeasure (SPCC) plans. The intent of a
SPCC plan is to prevent the discharge of oil from onshore and offshore non-
transportation-related facilities. In 1990 Congress passed the Oil Pollution
Act which amended Section 311(j) of the CWA to require facilities that
because of their location could reasonably be expected to cause "substantial
harm" to the environment by a discharge of oil to develop and implement
Facility Response Plans (FRP). The intent of a FRP is to provide for planned
responses to discharges of oil.
A facility is SPCC-regulated if the facility, due to its location, could
reasonably be expected to discharge oil into or upon the navigable waters of
the United States or adjoining shorelines, and the facility meets one of the
following criteria regarding oil storage: (1) the capacity of any aboveground
storage tank exceeds 660 gallons, or (2) the total aboveground storage
capacity exceeds 1,320 gallons, or (3) the underground storage capacity
exceeds 42,000 gallons. 40 CFR Part 112.7 contains the format and content
requirements for a SPCC plan. In New. Jersey, SPCC plans can be combined
with DPCC plans, required by the state, provided there is an appropriate
cross-reference index to the requirements of both regulations at the front of
the plan.
According to the FRP regulation, a facility can cause "substantial harm" if
it meets one of the following criteria: (1) the facility has a total oil storage
capacity greater than or equal to 42,000 gallons and transfers oil over water
to or from vessels; or (2) the facility has a total oil storage capacity greater
than or equal to one million gallons and meets any one of the following
conditions: (i) does not have adequate secondary containment, (ii) a
discharge could cause '"injury" to fish and wildlife and sensitive
environments, (iii) shut down a public drinking water intake, or (iv) has had
a reportable oil spill greater than or equal to 10,000 gallons in the past five
years. Appendix F of 40 CFR Part 112 contains the format and content
requirements for a FRP. FRPs that meet EPA's requirements can be
combined with U.S. Coast Guard FRPs or other contingency plans, provided
there is an appropriate cross-reference index to the requirements of all
applicable regulations at the front of the plan.
For additional information regarding SPCC plans, contact EPA's RCRA,
Superfiind, andEPCRA CallCenter, at 800-424-9346. Additional documents
and resources can be obtained from the hotline's homepage at
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www. epa. fov/epaoswer/hotHne. The hotline operates weekdays from 9:00
a.m. to 6:00 p.m., EST, excluding federal holidays.
Safe Drinking Water Act
The Safe Drinking Water Act (SDWA) mandates that EPA establish
regulations to protect human health from contaminants in drinking water.
The law authorizes EPA to develop national drinking water standards and to
create a joint federal-state system to ensure compliance with these standards.
The SDWA also directs EPA to protect underground sources of drinking
water through the control of underground injection of fluid wastes.
EPA has developed primary and secondary drinking water standards under
its SDWA authority. EPA and authorized states enforce the primary drinking
water standards, which are contaminant-specific concentration limits that
apply to certain public drinking water supplies. Primary drinking water
standards consist of maximum contaminant level goals (MCLGs), which are
non-enforceable health-based goals, and maximum contaminant levels
(MCLs), which are enforceable limits set generally as close to MCLGs as
possible, considering cost and feasibility of attainment.
Part C of the SDWA mandates EPA to protect underground sources of
drinking water from inadequate injection practices. EPA has published
regulations codified in 40 CFR Parts 144 to 148 to comply with this mandate.
The Underground Injection Control (UIC) regulations break down injection
wells into five different types, depending on the fluid injected and the
formation that receives it. The regulations also include construction,
monitoring, testing, and operating requirements for injection well operators.
All injection wells have to be authorized by permit or by rule depending on
their potential to threaten Underground Sources of Drinking Water (USDW).
RCRA als'o regulates hazardous waste injection wells and a UIC permit is
considered to meet the requirements of a RCRA permit. EPA has authorized
delegation of the UIC for all wells in 35 states, implements the program in
10 states and all Indian lands, and shares responsibility with five states.
The SDWA also provides for a federally-implemented Sole Source Aquifer
program, which prohibits federal funds from being expended on proj ects that
may contaminate the sole or principal source of drinking water for a given
area, and for a state-implemented Wellhead Protection program, designed to
protect drinking water wells and drinking water recharge areas.
The SDWA Amendments of 1996 require states to develop and implement
source water assessment programs (S WAPs) to analyze existing and potential
threats to the quality of the public drinking water throughout the state. Every
state is required to submit a program to EPA and to complete all assessments
within 3 Vz years of EPA approval of the program. SWAPs include: (1)
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delineating the source water protection area, (2) conducting a contaminant
source inventory, (3) determining the susceptibility of the public water
supply to contamination from the inventories sources, and (4) releasing the
results of the assessments to the public.
EPA's Safe Drinking Water Hotline, at 800-426-4791, answers questions and
distributes guidance pertaining to SDWA standards. The Hotline operates
from 9:00a.m. through 5:30p.m,, EST, excluding federal holidays. Visit the
website at www.epa.gov/ogwdwfor additional material.
Resource Conservation and Recovery Act
The Solid Waste Disposal Act (SWDA), as amended by the Resource
Conservation and Recovery Act (RCRA) of 1976, addresses solid and
hazardous waste management activities. The Act is commonly referred to as
RCRA. The Hazardous and Solid Waste Amendments (HSWA) of 1984
strengthened RCRA's waste management provisions and added Subtitle I,
which governs underground storage tanks (USTs).
Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts
260-299) establish a "cradle-to-grave" system governing hazardous waste
from the point of generation to disposal. RCRA hazardous wastes include
the specific materials listed in the regulations (discarded commercial
chemical products, designated with the code "P" or "U"; hazardous wastes
from specific industries/sources, designated with the code "K"; or hazardous
wastes from non-specific sources, designated with the code "F") or materials
which exhibit a hazardous waste characteristic (ignitability, corrosivity,
reactivity, or toxicity and designated with the code "D").
Entities that generate hazardous waste are subject to waste accumulation,
manifesting, and recordkeeping standards. A hazardous waste facility may
accumulate hazardous waste for up to 90 days (or 180 days depending on the
amount generated per month) without a permit or interim status. Generators
may also treat hazardous waste in accumulation tanks or containers (in
accordance with the requirements of 40 CFR Part 262.34) without a permit
or interim status. Facilities that treat, store, or dispose of hazardous waste are
generally required to obtain a RCRA permit.
Subtitle C permits are required for treatment, storage, or disposal facilities.
These permits contain general facility standards such as contingency plans,
emergency procedures, recordkeeping and reporting requirements, financial
assurance mechanisms, and unit-specific standards. RCRA also contains
provisions (40 CFR Subparts I and S) for conducting corrective actions
which govern the cleanup of releases of hazardous waste or constituents from
solid waste management units at RCRA treatment, storage, or disposal
facilities.
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Although RCRA is a federal statute, many states implement the RCRA
program. Currently, EPA has delegated its authority to implement various
provisions of RCRA to 47 of the 50 states and two U.S. territories.
Delegation has not been given to Alaska, Hawaii, or Iowa.
Most RCRA requirements are not industry specific but apply to any company
that generates, transports, treats, stores, or disposes of hazardous waste. Here
are some important RCRA regulatory requirements:
• Criteria for Classification of Solid Waste Disposal Facilities and
Practices (40 CFR Part 257) establishes the criteria for determining
which solid waste disposal facilities and practices pose a reasonable
probability of adverse effects on health or the environment. The
criteria were adopted to ensure non-municipal, non-hazardous waste
disposal units that receive conditionally exempt small quantity
generator waste do not present risks to human health and
environment.
Criteria for Municipal Solid Waste Landfills (40 CFR Part 258)
establishes minimum national criteria for all municipal solid waste
landfill units, including those that are used to dispose of sewage
sludge.
Identification of Solid and Hazardous Wastes (40.CFR Part 261)
establishes the standard to determine whether the material in question
is considered a solid waste and, if so, whether it is a hazardous waste
or is exempted from regulation.
Standards for Generators of Hazardous Waste (40 CFR Part 262)
establishes the responsibilities of hazardous waste generators
including obtaining an EPA identification number, preparing a
manifest, ensuring proper packaging and labeling, meeting standards
for waste accumulation units, and recordkeeping and reporting
requirements. Generators can accumulate hazardous waste on-site for
up to 90 days (or 180 days depending on the amount of waste
generated) without obtaining a permit.
Land Disposal Restrictions (LDRs) (40 CFR Part 268) are
regulations prohibiting the disposal of hazardous waste on land
without prior treatment. Under the LDRs program, materials must
meet treatment standards prior to placement in a RCRA land disposal
unit (landfill, land treatment unit, waste pile, or surface
impoundment). Generators of waste subject to the LDRs must
provide notification of such to the designated TSD facility to ensure
proper treatment prior to disposal.
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Used Oil Management Standards (40 CFR Part 279) impose
management requirements affecting the storage, transportation,
burning, processing, and re-refining of the used oil. For parties that
merely generate used oil, regulations establish storage standards. For
a party considered a used oil processor, re-refiner, burner, or
marketer (one who generates and sells off-specification used oil
directly to a used oil burner), additional tracking and paperwork
requirements must be satisfied.
• RCRA contains unit-specific standards for all units used to store,
treat, or dispose of hazardous waste, including Tanks and
Containers. Tanks and containers used to store hazardous waste with
a high volatile organic concentration must meet emission standards
under RCRA. Regulations (40 CFR Part 264-265, Subpart CC)
require generators to test the waste to determine the concentration of
the waste, to satisfy tank and container emissions standards, and to
inspect and monitor regulated units. These regulations apply to all
facilities who store such waste, including large quantity generators
accumulating waste prior to shipment offsite.
Underground Storage Tanks (USTs) containing petroleum and
hazardous substances are regulated under Subtitle 1 of RCRA.
Subtitle I regulations (40 CFR Part 280) contain tank design and
release detection requirements, as well as financial responsibility and
corrective action standards for USTs. The UST program also
includes upgrade requirements for existing tanks that were to be met
by December 22,1998.
Boilers and Industrial Furnaces (BIFs) that use or burn fuel
containing hazardous waste must comply with design and operating
standards. BIF regulations (40 CFR Part 266, Subpart H) address unit
. design, provide performance standards, require emissions monitoring,
and, in some cases, restrict the type of waste that may be burned.
EPA's RCRA, Superfund, and EPCRA Call Center, at 800-424-9346,
responds to questions and distributes guidance regarding all RCRA
regulations. Additional documents and resources can be obtained from the
hotline's homepage at www.epa.gov/epaoswer/hotline. The RCRA Hotline
operates weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal
holidays.
Comprehensive Environmental Response, Compensation, and Liability Act
The Comprehensive Environmental Response, Compensation, and Liability
Act (CERCLA), a 1980 law commonly known as Superfund, authorizes EPA
to respond to releases, or threatened releases, of hazardous substances that
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may endanger public health, welfare, or the environment. CERCLA also
enables EPA to force parties responsible for environmental contamination to
clean it up or to reimburse the Superfimd for response or remediation costs
incurred by EPA. The Superfund Amendments and Reauthorization Act
(SARA) of 1986 revised various sections of CERCLA, extended the taxing
authority for the Superfund, and created a free-standing law, SARA Title III,
also known as the Emergency Planning and Community Right-to-Know Act
(EPCRA).
The CERCLA hazardous substance release reporting regulations (40 CFR
Part 302) direct the person in charge of a facility to report to the National
Response Center (NRC) any environmental release of a hazardous substance
which equals or exceeds a reportable quantity. Reportable quantities are
listed in 40 CFR Part 302.4. A release report may trigger a response by EPA
or by one or more federal or state emergency response authorities.
EPA implements hazardous substance responses according to procedures
outlined in the National Oil and Hazardous Substances Pollution
Contingency Plan (NCP) (40 CFR Part 300). The NCP includes provisions
for cleanups. The National Priorities List (NPL) currently includes
approximately 1,300 sites. Both EPA and states can act at other sites;
however, EPA provides responsible parties the opportunity to conduct
cleanups and encourages community involvement throughout the Superfund
response process.
EPA'sRCRA, Superfund and EPCRA Call Center, at 800-424-9346, answers
questions and references guidance pertaining to the Superfund program.
Documents and resources can be obtained from the hotline's homepage at
www.epa.s?ov/epaoswer/hotline. The Superfund Hotline operates weekdays
from 9:00 a.m. to 6:00 p.m., EST, excluding federal holidays.
Emergency Planning And Community Right-To-Know Act
The Superfund Amendments and Reauthorization Act (SARA) of 1986
created the Emergency Planning and Community Right-to-Know Act
(EPCRA, also known as SARA Title III), a statute designed to improve
community access to information about chemical hazards and to facilitate the
development of chemical emergency response plans by state and local
governments. Under EPCRA, states establish State Emergency Response
Commissions (SERCs), responsible for coordinating certain emergency
response activities and for appointing Local Emergency Planning
Committees (LEPCs).
EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four
types of reporting obligations for facilities which store or manage specified
chemicals:
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EPCRA section 302 requires facilities to notify the SERC and LEPC
of the presence of any extremely hazardous substance at the facility
in an amount in excess of the established threshold planning quantity.
The list of extremely hazardous substances and their threshold
planning quantities is found at 40 CFR Part 355, Appendices A and
B.
EPCRA section 303 requires that each LEPC develop an emergency
plan. The plan must contain (but is not limited to) the identification
of facilities within the planning district, likely routes for transporting
extremely hazardous substances, a description of the methods and
procedures to be followed by facility owners and operators, and the
designation of community and facility emergency response
coordinators.
EPCRA section 304 requires the facility to notify the SERC and the
LEPC in the event of a release exceeding the reportable quantity of
a CERCLA hazardous substance (defined at 40 CFR Part 302) or an
EPCRA extremely hazardous substance.
EPCRA sections 311 and 312 require a facility at which a hazardous
chemical, as defined by the Occupational Safety and Health Act, is
present in an amount exceeding a specified threshold to submit to the
SERC, LEPC and local fire department material safety data sheets
(MSDSs) or lists of MSDSs and hazardous chemical inventory forms
(also known as Tier I and II forms). This information helps the local
government respond in the event of a spill or release of the chemical.
EPCRA section 313 requires certain covered facilities, including
SIC codes 20 through 39 and others, which have ten or more
employees, and which manufacture, process, or use specified
chemicals in amounts greater than threshold quantities, to submit an
annual toxic chemical release report. This report, commonly known
as the Form R, covers releases and transfers of toxic chemicals to
various facilities and environmental media. EPA maintains the data
reported in a publically accessible database known as the Toxics
Release Inventory (TRI).
All information submitted pursuant to EPCRA regulations is publicly
accessible, unless protected by a trade secret claim.
i
EPA'sRCRA, SuperfimdandEPCRA Call Center, at 800-424-9346, answers
questions and distributes guidance regarding the emergency planning and
community right-to-know regulations. Documents and resources can be
obtained from the hotline's homepage at wwv^.epa.^qv/epaoswer/hptlin^.
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The EPCRA Hotline operates weekdays from 9:00 a.m. to 6:00 p.m., EST,
excluding federal holidays.
Clean Air Act
The Clean Air Act (CAA) and its amendments are designed to "protect and
enhance the nation's air resources so as to promote the public health and
welfare and the productive capacity of the population." The CAA consists
of six sections, known as Titles, which direct EPA to establish national
standards for ambient air quality and for EPA and the states to implement,
maintain, and enforce these standards through a variety of mechanisms.
Under the CAA, many facilities are required to obtain operating permits that
consolidate their air emission requirements. State and local governments
oversee, manage, and enforce many of the requirements of the CAA. CAA
regulations appear at 40 CFR Parts 50-99.
Pursuant to Title I of the CAA, EPA has established national ambient air
quality standards (NAAQSs) to limit levels of "criteria pollutants," including
carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, and
sulfur dioxide. Geographic areas that meet NAAQSs for a given pollutant
are designated as attainment areas; those that do not meet NAAQSs are
designated as non-attainment areas. Under sectionl 10 and other provisions
of the CAA, each state must develop a State Implementation Plan (SIP) to
identify sources of air pollution and to determine what reductions are
required to meet federal air quality standards. Revised NAAQSs for
particulates and ozone became effective in 2001,
Title I also authorizes EPA to establish New Source Performance Standards
(NSPS), which are nationally uniform emission standards for new and
modified stationary sources falling within particular industrial categories.
NSPSs are based on the pollution control technology available to that
category of industrial source (see 40 CFR Part 60).
Under Title I, EPA establishes and enforces National Emission Standards for
Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented
toward controlling specific hazardous air pollutants (HAPs). Section 112(c)
of the CAA further directs EPA to develop a list of sources that emit any of
188 HAPs, and to develop regulations for these categories of sources. To
date EPA has listed 185 source categories and developed a schedule for the
establishment of emission standards. The emission standards are being
developed for both new and existing sources based on "maximum achievable
control technology" (MACT). The MACT is defined as the control
technology achieving the maximum degree of reduction in the emission of
the HAPs, taking into account cost and other factors.
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Title II of the CAA pertains to mobile sources, such as cars, trucks, buses,
and planes. Reformulated gasoline, automobile pollution control devices,
and vapor recovery nozzles on gas pumps are a few of the mechanisms EPA
uses to regulate mobile air emission sources.
Title IV-A establishes a sulfur dioxide and nitrogen oxides emissions
program designed to reduce the formation of acid rain. Reduction of sulfur
dioxide releases will be obtained by granting to certain sources limited
emissions allowances that are set below previous levels of sulfur dioxide
releases.
Title V of the CAA establishes an operating permit program for all "major
sources" (and certain other sources) regulated under the CAA. One purpose
of the operating permit is to include in a single document all air emissions
requirements that apply to a given facility. States have developed the permit
programs in accordance with guidance and regulations from EPA. Once a
state program is approved by EPA, permits are issued and monitored by that
state.
Title VI is intended to protect stratospheric ozone by phasing out the
manufacture of ozone-depleting chemicals and restricting their use and
distribution. Production of Class I substances, including 15 kinds of
chlorofluorocarbons (CFCs), were phased out (except for essential uses) in
. 1996.
EPA's Clean Air Technology Center, at 919-541-0800 or
www.epa. qav/ttn/catc. provides general assistance and information on CAA
standards. The Stratospheric Ozone Information Hotline, at 800-296-1996
or www. epQ.gov/Q5one. provides general information about regulations
promulgated under Title VI of'the CAA; EPA's EPCRA Call Center, at 800-
424-9346 or www.epa. gov/epaoswer/hotline. answers questions about
accidental release prevention under CAA section 112(r); and information on
air toxics can be accessed through the Unified Air Toxics website at
http://www.epa. gov/ttn/atw/. In addition, the Clean Air Technology Center's
website includes recent CAA rules, EPA guidance documents, and updates
of EPA activities.
Federal Insecticide, Fungicide, andRodenticide Act
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was first
passed in 1947, and amended numerous times, most recently by the Food
Quality Protection Act (FQPA) of 1996. FIFRA provides EPA with the
authority to oversee, among other things, the registration, distribution, sale
and use of pesticides. The Act applies to all types of pesticides, including
insecticides, herbicides, fungicides, rodenticides and antimicrobials. FIFRA
covers both intrastate and interstate commerce.
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Establishment Registration
Section 7 of FIFRA requires that establishments producing pesticides, or
active ingredients used in producing a pesticide subject to FIFRA, register
with EPA. Registered establishments must report the types and amounts of
pesticides and active ingredients they produce. The Act also provides EPA
inspection authority and enables the agency to take enforcement actions
against facilities that are not in compliance with FIFRA.
Product Registration
Under section 3 of FIFRA, all pesticides (with few exceptions) sold or
distributed in the U.S. must be registered by EPA. Pesticide registration is
very specific and generally allows use of the product only as specified on the
label. Each registration specifies the use site i.e., where the product may be
used and the amount that may be applied. The person who seeks to register
the pesticide must file an application for registration. The application
process often requires either the citation or submission of extensive
environmental, health and safety data.
To register a pesticide, the EPA Administrator must make a number of
findings, one of which is that the pesticide, when used in accordance with
widespread and commonly recognized practice, will not generally cause
unreasonable adverse effects on the environment.
FIFRA defines "unreasonable adverse effects on the environment" as "(1)
any unreasonable risk to man or the environment, taking into account the
economic, social, and environmental costs and benefits of the use of the
pesticide, or (2) a human dietary risk from residues that result from a use of
a pesticide in or on any food inconsistent with the standard under section 408
of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 346a)."
Under FIFRA section 6(a)(2), after a pesticide is registered, the registrant
must also notify EPA of any additional facts and information concerning
unreasonable adverse environmental effects of the pesticide. Also, if EPA
determines that additional data are needed to support a registered pesticide,
registrants may be requested to provide additional data. If EPA determines
that the registrants) did not comply with their request for more information,
the registration can be suspended under FIFRA section 3(c)(2)(B).
Use Restrictions
As a part of the pesticide registration, EPA must classify the product for
general use, restricted use, or general for some uses and restricted for others
(Miller, 1993). For pesticides that may cause unreasonable adverse effects
on the environment, including injury to the applicator, EPA may require that
the pesticide be applied either by or under the direct supervision of a certified
applicator.
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Registration
Due to concerns that much of the safety data underlying pesticide
registrations becomes outdated and inadequate, in addition to providing that
registrations be reviewed every 15 years, FIFRA requires EPA to reregister
all pesticides that were registered prior to 1984 (section 4). After reviewing
existing data, EPA may approve the reregistration, request additional data to
support the registration, cancel, or suspend the pesticide.
Tolerances and Exemptions
A tolerance is the maximum amount of pesticide residue that can be on a raw
product and still be considered safe. Before EPA can register a pesticide that
is used on raw agricultural products, it must grant a tolerance or exemption
from a tolerance (40 CFR Parts 163.10 through 163.12), Under the Federal
Food, Drug, and Cosmetic Act (FFDCA), a raw agricultural product is
deemed unsafe if it contains a pesticide residue, unless the residue is within
the limits of a tolerance established by EPA or is exempt from the
requirement.
Cancellation and Suspension
EPA can cancel a registration if it is determined that the pesticide or its
labeling does not comply with the requirements of FIFRA or causes
unreasonable adverse effects on the environment (Haugrud, 1993).
In cases where EPA believes that an "imminent hazard" would exist if a
pesticide were to continue to be used through the cancellation proceedings,
EPA may suspend the pesticide registration through an order and thereby halt
the sale, distribution, and usage of the pesticide. An "imminent hazard" is
defined as an unreasonable adverse effect on the environment or an
unreasonable hazard to the survival of a threatened or endangered species
that would be the likely result of allowing continued use of a pesticide during
a cancellation process.
When EPA believes an emergency exists that does not permit a hearing to be
held prior to suspending, EPA can issue an emergency order which makes the
suspension immediately effective.
Imports and Exports
Under FIFRA section 17(a), pesticides not registered in the U.S. and
intended solely for export are not required to be registered provided that the
exporter obtains and submits to EPA, prior to export, a statement from the
foreign purchaser acknowledging that the purchaser is aware that the product
is not registered in the United States and cannot be sold for use there. EPA
sends these statements to the government of the importing country. FIFRA
sets forth additional requirements that must be met by pesticides intended
solely for export. The enforcement policy for exports is codified at 40 CFR
Parts 168.65, 168.75, and 168.85.
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Under FIFRA section 17fc), imported pesticides and devices must comply
with U.S. pesticide law. Except where exempted by regulation or statute,
imported pesticides must be registered. FIFRA section 17(c) requires that
EPA be notified of the arrival of imported pesticides and devices. This is
accomplished through the Notice of Arrival (NOA) (EPA Form 3540-1),
which is filled out by the importer prior to importation and submitted to the
EPA regional office applicable to the intended port of entry. U.S. Customs
regulations prohibit the importation of pesticides without a completed NOA.
The EPA-reviewed and signed form is returned to the importer for
presentation to U.S. Customs when the shipment arrives in the U.S. NOA
forms can be obtained from contacts in the EPA Regional Offices or
www.epa. %ov/oppfeadl/international/noalist.htm.
Additional information on FIFRA and the regulation of pesticides can be
obtained from a variety of sources, including EPA's Office of Pesticide
Programs www.epa. gov/pesticides, EPA's Office of Compliance, Agriculture
and Ecosystem Division http://www. epa. %ov/comnliance/assistance/
sectors/agriculture.html, or The National Agriculture Compliance Assistance
Center, 888-663-2155 or http://www.epa.%ovlagriculture/. Other sources
include the NationalPesticide Telecommunications Network, 800-858-7378,
and the National Antimicrobial Information Network, 800-447-6349.
Toxic Substances Control Act
The Toxic Substances Control Act (TSCA) granted EPA authority to create
a regulatory framework to collect data on chemicals in order to evaluate,
assess, mitigate, and control risks which may be posed by their manufacture,
processing, and use. TSCA provides a variety of control methods to prevent
chemicals from posing unreasonable risk. It is important to note that
pesticides as defined in FIFRA are not included in the definition of a
"chemical substance" when manufactured,'. processed, or distributed in
commerce for use as a pesticide.
TSCA standards may apply at any point during a chemical's life cycle.
Under TSCA section 5, EPA has established an inventory of chemical
substances. If a chemical is not already on the inventory, and has not been
excluded by TSCA, a premanufacture notice (PMN) must be. submitted to
EPA prior to manufacture or import. The PMN must identify the chemical
and provide available information on health and environmental effects. If
available data are not sufficient to evaluate the chemical's effects, EPA can
impose restrictions pending the development of information on its health and
environmental effects. EPA can also restrict significant new uses of
chemicals based upon factors such as the projected volume and use of the
chemical.
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Under TSCA section 6, EPA can ban the manufacture or distribution in
commerce, limit the use, require labeling, or place other restrictions on
chemicals that pose unreasonable risks. Among the chemicals EPA regulates
under section 6 authority are asbestos, chlorofluorocarbons (CFCs), lead, and
polychlorinated biphenyls (PCBs).
Under TSCA section 8(e), EPA requires the producers and importers (and
others) of chemicals to report information on a chemicals' production, use,
exposure, and risks. Companies producing and importing chemicals can be
required to report unpublished health and safety studies on listed chemicals
and to collect and record any allegations of adverse reactions or any
information indicating that a substance may pose a substantial risk to humans
or the environment.
EPA's TSCA Assistance Information Service, at 202-554-1404, answers
questions and distributes guidance pertaining to Toxic Substances Control
Act standards. The Service operates Jrom 8:30 a.m. through 4:30p.m., EST,
excluding federal holidays.
Coastal Zone Management Act
The Coastal Zone Management Act (CZMA) encourages states/tribes to
preserve, protect, develop, and where possible, restore or enhance valuable
natural coastal resources such as wetlands, floodplains, estuaries, beaches,
dunes, barrier islands, and coral reefs, as well as the fish and wildlife using
those habitats. It includes areas bordering the Atlantic, Pacific, and Arctic
Oceans, Gulf of Mexico, Long Island Sound, and Great Lakes. A unique
feature of this law is that participation by states/tribes is voluntary.
In the Coastal Zone Management Act Reauthorization Amendments
(CZARA) of 1990, Congress identified nonpoint source pollution as a major
factor in the continuing degradation of coastal waters. Congress also
recognized that effective solutions to nonpoint source pollution could be
implemented at the state/tribe and local levels. In CZARA, Congress added
Section 6217 (16 U.S.C. section 1455b), which calls upon states/tribes with
federally-approved coastal zone management programs to develop and
implement coastal nonpoint pollution control programs. The Section 6217
program is administered at the federal level jointly by EPA and the National
Oceanic and Atmospheric Agency (NOAA),
Section 6217(g) called for EPA, in consultation with other agencies, to
develop guidance on "management measures" for sources of nonpoint source
pollution in coastal waters. Under Section 6217, EPA is responsible for
developing technical guidance to assist states/tribes in designing coastal
nonpoint pollution control programs. On January 19, 1993, EPA issued its
Guidance Specifying Management Measures For Sources of Nonpoint
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Pollution in Coastal Waters, which addresses five major source categories
of nonpoint pollution: (1) urban runoff, (2) agriculture runoff, (3) forestry
runoff, (4) marinas and recreational boating, and (5) hydromodification.
Additional information on coastal zone management may be obtained from
EPA's Office of Wetlands, Oceans, and Watersheds, www.epa.goy/owow. or
from the Watershed Information Network www. epa. gov/win. The NOAA
website, http://www.ocrm.nos.noaa,gov/czm/. also contains additional
information on coastal zone management.
VLB. Industry Specific Requirements
Clean Air Act (CAA)
National Ambient Air Quality Standards
At pulp and paper mills, air emissions from both process and combustion
units are regulated under the National Ambient Air Quality Standards
(NAAQS) and the State Implementation Plans (SIP) that enforce the
standards. States may implement controls to limit emissions of paniculate
matter (PM), nitrogen oxides (NOx), volatile organic compounds (VOC), and
sulfur dioxide (SO2).
Although many limits are implemented at the state level, there are national
guidelines that serve as a basis for more specific limits. Sources that are
considered "major" under the Clean Air Act are subject to prevention of
significant deterioration (PSD) or new source review (NSR). Both PSD and
NSR are permit programs for facilities that were constructed or modified
after a certain date.
Facilities in NAAQS attainment areas must follow PSD requirements by
demonstrating that the construction/modification project will not cause a
violation of air quality limits and by implementing the best available control
technology (BACT).
New or modified facilities in nonattainment areas must follow NSR
requirements, which require the source to meet the lowest achievable
emission rate (LAER) and to obtain emission offsets to ensure that the
nonattainment problem is not made worse by the new/modified source.
In addition to the PSD/NSR pre-construction obligations, there are process-
specific operational standards: New Source Performance Standards (NSPS).
40 CFR 60 lists these standards, which serve as minimum requirements in
states SIPs. Individual states may impose requirements that are more strict.
The following NSPSs are particularly relevant to the pulp and paper industry;
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Subpart BB
Kraft pulp mills
(Regulates PM and TRS emissions from new kraft
mills.)
Subparts D, Db, DC Industrial boilers
(Regulates PM, nitrogen oxides (NOx) and sulfur
dioxide (S02) from new boilers used at pulp and
paper mills.)
Subpart GG
Subpart Kb
Gas-fired turbines
(Regulates PM, nitrogen oxides (NOx) and sulfur
dioxide (S02) from new gas-fired turbines used at
pulp and paper mills.)
Volatile Organic Liquid Storage Vessels (Including
Petroleum Liquid Storage Vessels)
(Regulates VOC from applicable storage tanks
containing volatile organic liquids at pulp and paper
mills)
Hazardous Air Pollutants
Air toxics regulations apply to several parts of the pulp and paper milling
process. National Emission Standards for Hazardous Air Pollutants
(NESHAP) have been developed expressly for two processes of the pulp and
paper industry. Both NESHAPs establish process-based maximum
achievable control technologies (MACT) for "major sources," which are
defined as facilities that emit or have the potential to emit 10 tons per year
or more of any hazardous air pollutant (HAP) or 25 tons per year or more of
any combination of HAPs, Standards for both MACT I & III standards are
integrated into one subpart (Subpart S) of 40 CFR 63. MACT II standards are
in a separate subpart (Subpart MM).:
Subpart S
Subpart MM
Controlling HAP emissions from the pulp and paper
production areas of mills using the kraft, sulfite, semi-
chemical, and soda pulping processes (MACT I), and
controlling HAP emissions from pulp and paper
production areas of mills using mechanical, secondary
fiber, and non-wood pulping, and papermaking
systems at all mills (MACT II).
Controlling HAP emissions from chemical recovery
processes that involve the combustion of spent
pulping liquor at kraft, soda, sulfite, and stand-alone
semichemical pulp mills (MACT III).
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Other NESHAPs that are relevant for the industry are those for asbestos
(relevant during demolition and renovation activities) and mercury
(important for sludge dryers and incinerators). Unlike the industry-specific
NESHAP standards, chemical-specific NESHAPs may apply to all facilities
regardless of their size.
Risk Management Program
Pulp and paper mills are subject to section 112(r) of CAA, which states that
stationary sources using extremely hazardous substances have a "general
duty" to initiate specific activities to prevent and mitigate accidental releases.
The general duty requirements apply to stationary sources that produce,
process, handle, or store these substances, regardless of the quantity of
managed at the facility. Although there is no list of "extremely hazardous
substances," EPA's Chemical Emergency Preparedness and Prevention
Office provides some guidance at its website: www.epa.gov/ceppo. The
general duty clause requires facilities to identify hazards that may result from
accidental releases, to design and maintain a safe facility, and to minimize
the consequences of releases when they occur.
Most pulp and paper mills are subject to additional, more explicit risk
management requirements. Facilities that have more than a threshold
quantity of any of the 140 regulated substances in a single process are
required to develop a risk management program and to summarize their
program in a risk management plan (RMP). Mills subject to the requirements
were required to submit a registration and RMP in 1999 or whenever they
first exceed the threshold for a listed regulated substance after that date.
All facilities meeting the RMP threshold requirements must follow Program
1 requirements:
* An offsite consequence analysis that evaluates specific potential
release scenarios, including worst-case and alternative scenarios.
• A five-year history of certain accidental releases of regulated
substances from covered processes.
• A risk management plan, revised at least once every five years, that
describes and documents these activities for all covered processes.
In addition, most pulp and paper facilities may be subject to the requirements
of Program 2 or 3. These additional requirements include:
An integrated prevention program to manage risk. The prevention
program will include identification of hazards, written operating
procedures, training, maintenance, and accident investigation.
An emergency response program.
An overall management system to put these program elements into
effect.
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The list of chemicals that trigger RMP requirements can be found in 40 CFR
68.130; information to determine the required program level also can be
found in 40 CFR 68.
Title V permits
Title V requires that all "major sources" (and certain minor sources) obtain
an operating permit. Many pulp and paper mills are required to have a Title
V permit, and may be required to submit information about emissions,
control devices, and the general process at the facility in the permit
application. Permits may limit pollutant emissions and impose monitoring,
record keeping, and reporting requirements.
Title VI Stratospheric Ozone Protection
Many pulp and paper facilities operate industrial process refrigeration units,
such as chillers for chlorine dioxide plants. For those units that utilize ozone-
depleting chemicals, such as chlorofluorocarbons (CFCs), facilities are
required under Title VI to follow leak repair requirements.
Clean Water Act (CWA)
There are two industry-specific components of the CWA requirements:
NPDES permitting and pretreatment programs. Other general CWA
requirements, such as those for wetlands and stormwater, may also apply to
the pulp and paper mills and are described in Section VI.A.
Individual NPDES requirements have been developed for several
subcategories of the industry; they are described in 40 CFR 430. For each
of these subcategories, the regulations outline some or all of the following for
facilities that discharge wastewater directly to the environment:
best practicable control technology currently available (BPT) and
best conventional control technology (BCT) guidelines for the control
of conventional pollutants (biological oxygen demand, total
suspended solids, and pH).
best available technology economically achievable (BAT) guidelines
for the control of nonconventional and toxic pollutants
(trichlorophenol and pentachlorophenol, which are chemicals used as
biocides).
new source performance standards (NSPS) for the control of
conventional, non-conventional, and toxic pollutants from new
facilities that discharge directly to the environment.
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For facilities that discharge their wastewater to a publicly-owned treatment
works (POTW), pretreatment standards may apply. In addition to general
standards established by EPA that address all industries, there are
Pretreatment Standards for New Sources (PSNS) and Pretreatment Standards
for Existing Sources (PSES) that are specific to the pulp and paper industry.
These regulate the biocides trichlorophenol and pentachlorophenol, with
limits that are specified for each subcategory of the industry.
In 1998, in conjunction with the development of the pulp and paper cluster
rule, EPA reorganized the regulations in order to group processes that are
similar. Table 19 presents the revised and original subcategory groupings,
and summarizes the portions of the CWA regulations that apply. More detail
can be found in 40 CFR 430.
Table 19: Applicability of Clean Water Act Requirements
Revised
Subpart of
40 CFR 430
A
B
C
D
E
F
G
Revised
Subcategory
Dissolving Kraft
Bleached
Papergrade Kraft
and Soda"
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite"
Semi-Chemical
Mechanical Pulp
Previous Subcategory
(Previous Subpart in Parentheses)
Dissolving Kraft (F)
Market Bleached Kraft (G)
BCT Bleached Kraft (H)
Fine Bleached Kraft (1)
Soda (P)
Unbleached Kraft (A)
• Linerboard
• Bag and Other Products
Unbleached Kraft and Semi-Chemical
(D,V)
Dissolving Sulfite (K)
Nitration
• Viscose
Cellophane
Acetate
Papergrade Sulfite (J, U)
Blow Pit Wash
• Drum Wash
Semi-Chemical (B)
• Ammonia
• Sodium
Groundwood-Thermo-Mechanical (M)
Groundwood-Coarse, Molded, News (N)
Groundwood-Fine Papers (O)
Groundwood-Chemi-Mechanical (L)
Applicable Regulations
BAT,
PSES,
and
PSNS
•
•
•
•
•
•
BPT,
BCT,
NSPS
•
•
•
•
•
•
•
BMP
•
•
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Table 19: Ap
Revised
Subpart of
40CFR430
H
1
J
K
L
Revised
Subcategory
Non-Wood
Chemical Pulp
Secondary Fiber
Deink
Secondary Fiber
Non-Deink
Fine and
Lightweight Papers
from Purchased
Pulp
Tissue, Filter,
Non- Woven, and
Paperboard from
Purchased Pulp
plicability of Clean Water Act Requirements
Previous Subcategory
(Previous Subpart in Parentheses)
Miscellaneous mills not covered by a
specific subpart
Deink Secondary Fiber (Q)
• Fine Papers
• Tissue Papers
• Newsprint
Tissue from Wastepaper (T)
Paperboard from Wastepaper (E)
• Corrugating Medium
• Non-Corrugating Medium
Wastepaper-Molded Products (W)
Builders' Paper and Roofing Felt (46
CFR Part 431 Subpart A)
Nonintegrated Fine Papers (R)
Wood Fiber Furnish
• Cotton Fiber Furnish
Nonintegrated Lightweight Papers (X)
Lightweight Papers
Lightweight Electrical Papers
Non-Integrated
Tissue Papers (S)
Filter and Non-Woven (Y)
Paperboard fZ)
Applicable Regulations
BAT,
PSES,
and
PSNS
BPT,
BCT,
NSPS
•
•
•
•
BMP
Source: U.S. EPA, Pulp and Paper NESHAP: A Plain English Description, November, 1998, Pages 7 and 104.
"These subcategories are affected by the Cluster Rules (described below).
Cluster Rule
The cluster rule is an integrated, multi-media regulation to control the release
of pollutants to two media (air and water) from one industry. The intent of
the rule is to allow individual mills in particular segments of the industry to
consider all regulatory requirements at one time. This combined rule allows
mills to select the best combination of pollution prevention and control
technologies that provide the greatest protection to human health and the
environment. Because some air requirements that reduce toxic air pollutants
also reduce mill wastewater toxic pollutant loadings (and water treatment
requirements can reduce air impacts), the combined rules have a synergistic
effect.
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Some of the features of the coordinated rule include:
• Alternative emission limits
• Varying compliance periods (3-8 years)
• New and existing source controls
• Flexibility for evolving technologies
Compliance dates coordinated with effluent limitations guidelines
and standards
The rule sets new baseline limits for the releases of toxics and
nonconventional pollutants to the air and water. There are three significant
components:
* Air Emissions Standards. New and existing pulp and paper mills
must meet air standards to reduce emissions of toxic air pollutants
occurring at various points throughout the mills. Specifically, EPA
requires mills to capture and treat toxic air pollutant emissions that
occur during the cooking, washing, and bleaching stages of the pulp
manufacturing process.
* Water Effluent Limitations Guidelines and Standards. New and
existing standards in the bleached papergrade kraft and soda
subcategory and the bleached papergrade sulfite subcategory must
meet standards to reduce discharges of toxic and nonconventional
pollutants. Specifically, EPA has set effluent limitations for toxic
pollutants in the wastewater discharged directly from the bleaching
process and in the final discharge from the mills.
• Analytical Methods for 12 Chlorinated Phenolics and Adsorbable
Organic Halides (AOXs). Samples of air emissions and water
discharges from each mill must be tested using the laboratory
methods included in the rule. The new methods will enable more
timely and accurate measurements of releases of these pollutants to
the environment and will be used to ensure compliance with air
emission and water discharge permit limits.
Voluntary Advanced Technology Incentives Program fVATIP)
Mills in the Bleached Papergrade Kraft and Soda Subcategory have
additional flexibility under the cluster rule. Mills may comply either with the
baseline regulations, or with more stringent wastewater regulations under a
more forgiving timetable. This latter arrangement, called the Voluntary
Advanced Technology Incentives Program (VATIP), allows mills to
undertake customized compliance and pollution reduction plans that further
reduce environmental impacts.
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Under the VATIP, each participating mill develops "Milestones Plans" for
each fiber line that it enrolls in the program. Permit writers will use the
Milestones Plan to incorporate enforceable interim requirements into the
mill's discharge permit. Specific requirements for the Milestones Plan are
found in 40 CFR 430.24(b) and (c), but the three basic components of a
Milestones Plan are the following:
• A description of each technology component or process modification
the mill intends to implement
• the master schedule showing the sequence of implementing new
technologies and process modifications
descriptions of the anticipated improvements in effluent quality.
Emergency Planning and Community Right-to-Know Act (EPCRA)
Three of the components of EPCRA are directly relevant to the pulp and
paper industry;
• Emergency Planning(§302(a))- Businesses thatproduce, use or store
"hazardous substances" must: 1) submit material safety data sheets or
the equivalent, and 2) Tier I/Tier II annual inventory report forms to
the appropriate local emergency planning commission. Those
handling "extremely hazardous substances" also are required to
submit a one-time notice to the state emergency response
commission.
Emergency Notification of Extremely Hazardous Substance Release
(§304) - A business that unintentionally releases a reportable quantity
of an extremely hazardous substance must report that release to the
state emergency planning commission and the local emergency
planning commission.
Release Reporting (§313) - Manufacturing businesses with ten or
more employees that manufactured, processed, or otherwise used a
listed toxic chemical in excess of the "established threshold" must file
annually a Toxic Chemical Release form with EPA and the state.
Documentation supporting release estimates must be kept for three
years.
Resource Conservation and Recovery Act (RCRA)
The pulp and paper industry generates hazardous wastes, but most are
associated with wastewater, which is rendered non-hazardous in wastewater
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treatment or neutralization units within manufacturing facilities, and
therefore is not subject to RCRA requirements. Also, black liquor is exempt
as a solid waste if it is reclaimed in a recovery furnace and reused in the
pulping process. Therefore, most of the industry's RCRA requirements are
those described in the general regulations outlined in Section VI.A.
VI.C. Pending and Proposed Regulatory Requirements
Clean Water Act
Effluent Guidelines and Standards for the Pulp. Paper, and Paperboard
Category. Phase II
EPA will consider revising the technology-based effluent limitations
guidelines and standards for 8 of the 12 subcategory for this industrial
category: Unbleached Kraft; Semi-Chemical; Mechanical Pulp; Non-Wood
Chemical Pulp; Secondary Fiber Deink; Secondary Fiber Non-Deink; Fine
and Lightweight Papers from Purchased Pulp; and Tissue, Filter, Non-
Woven, and Paperboard from Purchased Pulp. EPA proposed guidelines and
standards for these subcategories as part of the Pulp and Paper Rules (also
known as the Cluster Rules) in December 1993. The Agency intends to
develop these revised effluent limitations in close coordination with the
Office of Air Quality Planning and Standards. This is a long-term action; no
definite schedule had been set at the time of the publication of this document.
(Don Anderson, Office of Water, 202-566-1021)
Effluent Guidelines and Standards for the Pulp. Paper, and Paperboard Point
Source Category. Dissolving Kraft and Dissolving Sulfite Subcategories
(Phase IIP
In 1993, EPA proposed revised effluent limitations, guidelines and standards
and best management practices regulations for the Dissolving Kraft and
Dissolving Sulfite Subcategories (also known as Phase III of the Cluster
Rules). There are five mills in these subcategories in the U.S. EPA
anticipates that the final rule will set limits for adsorbable organic halides
(AOX), chemical oxygen demand (COD), chloroform, dioxin, furan, and 12
specific chlorinated phenolics. The rule is expected to be proposed in mid-
2003 and finalized in 2004. (Don Anderson, Office of Water, 202-566-1021)
Minimizing Adverse Environmental Impact from Cooling Water Intake
Structures at Existing Facilities Under Section 316(b) of the Clean Water
Act. Phase III
This rulemaking affects existing facilities that use cooling water intake
structures^and whose intake flow levels exceed a minimum threshold EPA
will determine. Pulp and paper manufacturing facilities are explicitly listed
as affected facilities. The rule will require that the location, design,
construction, and capacity of cooling water intake structures reflect the best
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technology available for minimizing adverse environmental impact. The
final rule is anticipated before December, 2004. (Deborah Nagle, Office of
Water, 202-566-1063 or J.T. Morgan, Office of Water, 202-564-7684)
Clean Air Act
Guidelines for Best Available Retrofit Technology (BART1
As required by the Clean Air Act, EPA issued a regional haze rule aimed at
protecting visibility in 156 federal areas. The rule seeks to reduce the
visibility impairment caused by many sources over a wide area. The haze rule
requires states to establish goals for improving visibility in national parks and
wilderness areas and to develop long-term strategies for reducing emissions
of air pollutants that impair visibility. Guidelines for BART were proposed
to amend the haze rule. The guidelines are for states in developing their plans
for setting air pollution limits for utilities and other industrial plants built
between 1962 and 1977 that have the potential to emit more than 250 tons a
year of visibility impairing pollution. These facilities fall into 26 categories,
including pulp mills. Many of these facilities have previously been exempt
from federal pollution control requirements under the Clean Air Act. Some
of the guidelines may affect emissions from boilers and recover boilers. This
proposed rule only provides guidelines for states in developing their
implementation plans. Inmost parts of the country, the plans are due in 2008.
(Tim Smith, Office of Air and Radiation, 919-541-4718)
Interstate Ozone Transport. NOX State Implementation Plan Call (NQX SIP
Cain
EPA has issued several actions and rulemakings related to reducing the
regional transport of ozone, including the final Regional Transport of Ozone
Rule ("NOx SIP call") requiring 22 eastern States and the District of
Columbia to submit State Implementation Plans that address the regional
transport of ground-level ozone through reductions in nitrogen oxides (a
precursor to ozone). While most of the NOx SIP call was upheld, certain
aspects of EPA's plan were remanded by court decisions, including a
definition dealing with industrial boilers and cogeneration. In February of
2002, EPA proposed rules on a number of remanded items, including rules
for certain industrial boilers that may be present at pulp and paper mills.
EPA's NOx SIP call potentially affepts industrial boilers that burn at least 50
percent fossil fuels. However, states are free to develop plans for reducing
nitrogen oxides at sources other than industrial boilers or at industrial boilers
that burn less than 50 percent fossil fuels. Pulp and paper mills in the eastern
states should monitor their state implementation plans. Implementation of
state plans will likely begin in 2003 in some States or 2004 for other States.
(Kevin Culligan, Office of Air and Radiation, 202-564-9172)
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VII. COMPLIANCE AND ENFORCEMENT HISTORY
Background
Until recently, EPA has focused much of its attention on easuring compliance
with specific environmental statutes. This approach allows the Agency to
track compliance with the Clean Air Act, the Resource Conservation and
Recovery Act, the Clean Water Act, and other environmental statutes.
Within the last several years, the Agency has begun to supplement single-
media compliance indicators with facility-specific, multimedia indicators of
compliance. In doing so, EPA is in a better position to track compliance with
all statutes at the facility level, and within specific industrial sectors.
A major step in building the capacity to compile multimedia data for
industrial sectors was the creation of EPA's Integrated Data for Enforcement
Analysis (IDEA) system. IDEA has the capacity to "read into" the Agency's
single-media databases, extract compliance records, and match the records
to individual facilities. The IDEA system can match Air, Water, Waste,
Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given
facility, and generate a list of historical permit, inspection, and enforcement
activity. IDEA also has the capability to analyze data by geographic area and
corporate holder. As the capacity to generate multimedia compliance data
improves, EPA will make available more in-depth compliance and
enforcement information. Additionally, sector-specific measures of success
for compliance assistance efforts are under development.
Compliance and Enforcement Profile Description
Using inspection, violation and enforcement data from the IDEA system, this
section provides information regarding the historical compliance and
enforcement activity of this sector. Compliance and enforcement records
from EPA's data systems are compiled to the facility level using the Facility
Registry System's (FRS) Master Source ID, which links records from
virtually any of EPA's data systems to a facility record. For each facility
(i.e., Master Source ID), the Industry Sector Notebooks analysis uses the
facility-level SIC code that is designated by IDEA, which can be described
as follows:
1. If the facility reports to TRI, then the designated SIC code is the
primary SIC reported in the most recent TRI reporting year.
2. If the facility does not report to TRI, the first SIC codes from all
linked AFS, PCS, RCRAInfo, BRS ID/permits are assembled. If more than
one permit/ID exists for a particular program then only one record from that
data system is used. The SIC code that occurs most often, if there is one,
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becomes the designated SIC code.
3. If the facility does not report to TRI and no SIC code occurs more
often than others, the designated SIC code is chosen from the linked
programs in the following order: AFS, PCS, BRS, RCR, NCD, DCK. If more
than one permit/ID exists for a particular program then only one record from
that data system is used.
Note that EPA does not attempt to define the actual number of facilities that
fall within each sector. Instead, the information presented in this section
portrays the records of a subset of facilities within the sector that are well
defined within EPA databases.
As a check on the relative size of the full sector universe, most notebooks
contain an estimated number of facilities within the sector according to the
Bureau of Census (See Section II). With sectors dominated by small
businesses, such as metal finishers and printers, the reporting universe within
the EPA databases may be small in comparison to Census data. However,
the group selected for inclusion in this data analysis section should be
consistent with this sector's general make-up.
Following this introduction is a list defining each data column presented
within this section. These values represent a retrospective summary of
inspections or enforcement actions, and solely reflect EPA, state and local
compliance assurance activity that have been entered into EPA databases.
To identify any changes in trends, the EPA ran two data queries, one for the
past five calendar years (September 16,1997 to September 15,2002) and the
other for the most recent 24-month period (September 16,2000 to September
15,2002). The five-year analysis gives an average level of activity for that
period for comparison to the more recent activity.
Because most inspections focus on single-media requirements, the data
queries presented in this section are taken from single media databases.
These databases do not provide data on whether inspections are state/local
or EPA-led. However, the table breaking down the universe of violations
does give the reader a general measurement of the EPA's and states' efforts
within each media program. The presented data illustrate the variations
across Regions for certain sectors.3 This variation may be attributable to
state/local data entry variations, specific geographic concentrations,
proximity to population centers, sensitive ecosystems, highly toxic chemicals
used in production, or historical noncompliance. Hence, the exhibited data
3 EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI);
III (DC, DE, MD, PA, VA, VW); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN,
OH, WI); VI (AR, LA, NM, OK, TX); VII (IA, KS, MO, NE); VIII (CO, MT, ND, SD, UT,
WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ID, OR, WA).
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do not rank regional performance or necessarily reflect which regions may
have the most compliance problems.
Compliance and Enforcement Data Definitions
General Definitions
Facility Registry System (FRS) --this system assigns a common Master
Source ID to EPA single-media permit records. The Master Source ID
allows EPA to compile and review all permit, compliance, enforcement and
pollutant release data for any given regulated facility.
Integrated Data for Enforcement Analysis (IDEA) - is a data integration
system that can retrieve information from the major EPA program office
databases. IDEA uses the FRS maintained Master Source ID identification
numberto "glue together" separate data records from EPA's databases. This
is done to create a "master list" of data records for any given facility. Some
of the data systems accessible through IDEA are: AIRS (Air Facility
Indexing and Retrieval System, Office of Air and Radiation), PCS (Permit
Compliance System, Office of Water), RCRAInfo (Resource Conservation
and Recovery Information System, Office of Solid Waste),NCDB (National
Compliance Data Base, Office of Prevention, Pesticides, and Toxic
Substances), CERCLIS (Comprehensive Environmental and Liability
Information System, Superfund), and TRIS (Toxic Release Inventory
System). IDEA also contains information from outside sources such as Dun
and Bradstreet and the Occupational Safety and Health Administration
(OSHA). Most data queries displayed in notebook sections IV and VII were
conducted using IDEA.
Data Table Column Heading Definitions
Facilities in Search - are based on the number of the FRS maintained
Master Source IDs that were designated to the listed SIC code range. The
SIC code range selected for each search is defined by each notebook's
selected SIC code coverage described in Section II.
Facilities Inspected - indicates the level of EPA and state agency
inspections for the facilities in this data search. These values show what
percentage of the facility universe is inspected in a 24- or 60- month period.
Number of Inspections - measures the total number of inspections
conducted in this sector. An inspection event is counted each time it is
entered into a single media database.
Average Time Between Inspections ~ provides an average length of time,
expressed in months, that a compliance inspection occurs at a facility within
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the defined universe.
Facilities with One or More Enforcement Actions - expresses the number
of facilities that were party to at least one enforcement action within the
defined time period. This category is broken down further into federal and
state actions. Data are obtained for administrative, civil/judicial, and
criminal enforcement actions. Administrative actions include Notices of
Violation (NOVs). A facility with multiple enforcement actions is only
counted once in this column (facility with three enforcement actions counts
as one). All percentages that appear are referenced to the number of facilities
inspected.
Total Enforcement Actions ~ describes the total number of enforcement
actions identified for an industrial sector across all environmental statutes.
A facility with multiple enforcement actions is counted multiple times (a
facility with three enforcement actions counts as three).
State Lead Actions - shows what percentage of the total enforcement
actions are taken by state and local environmental agencies. Varying levels
of use by states of EPA data systems may limit the volume of actions
accorded state enforcement activity. Some states extensively report
enforcement activities into EPA data systems, while other states may use
their own data systems.
Federal Lead Actions -- shows what percentage of the total enforcement
actions are taken by the United States Environmental Protection Agency.
This value includes referrals from state agencies. Many of these actions
result from coordinated or joint state/federal efforts.
Enforcement to Inspection Rate - expresses how often enforcement
actions result from inspections. This value is a ratio of enforcement actions
to inspections, and is presented for comparative purposes only. This measure
is a rough indicator of the relationship between inspections and enforcement.
This measure simply indicates historically how many enforcement actions
can be attributed to inspection activity. Reported inspections and
enforcement actions under the Clean Water Act (PCS), the Clean Air Act
(AFS) and the Resource Conservation and Recovery Act (RCRA) are
included in this ratio. Inspections and actions from the
TSCA/FIFRA/EPCRA database are not factored into this ratio because most
of the actions taken under these programs are not the result of facility
inspections. This ratio does not account for enforcement actions arising from
non-inspection compliance monitoring activities (e.g., self-reported water
discharges) that can result in enforcement action within the CAA, CWA and
RCRA.
Facilities with One or More Violations Identified -- indicates the
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percentage of inspected facilities having a violation identified in one of the
following data categories: In Violation or Significant Violation Status
(CAA); Reportable Noncompliance, Current Year Noncompliance,
Significant Noncompliance (CWA); Noncompliance and Significant
Noncompliance (FIFRA, TSCA, and EPCRA); Unresolved Violation and
Unresolved High Priority Violation (RCRA). The values presented for this
column reflect the extent of noncompliance within the measured time frame,
but do not distinguish between the severity of the noncompliance.
Percentages within this column can exceed 100 percent because facilities can
be in violation status without being inspected. Violation status may be a
precursor to an enforcement action, but does not necessarily indicate that an
enforcement action will occur.
Media Breakdown of Enforcement Actions and Inspections - four
columns identify the proportion of total inspections and enforcement actions
within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each
column is a percentage of either the "Total Inspections," or the "Total
Actions" column.
VILA. Pulp and Paper Industry Compliance History
Table 20 provides an overview of the reported compliance and enforcement
data for the pulp and paper industry over the past five years (September 16,
1997 to September 15,2002). These data are also broken out by EPA Region
thereby permitting geographical comparisons. A fewpoints evident from the
data are listed below.
• Regions 5, 4 and 1 contain the most pulp and paper facilities, while
Regions 4,6, and 3 conducted the most inspections.
• Region 4 conducted, by far, the most inspections of pulp and paper
facilities, had the lowest average time between inspections, and had
the most enforcement actions.
• Regions 2 and 10 had the most enforcement actions per inspection
(0.19 and 0.13, respectively).
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VII.B. Comparison of Enforcement Activity Between Selected Industries
Tables 21 and 22 allow the compliance history of the pulp and paper sector
to be compared to the other industries covered by the industry sector
notebooks. Comparisons between Tables 21 and 22 permit the identification
of trends in compliance and enforcement records of the industry by
comparing data covering the last five years to that of the past two years.
Some points evident from the data are listed below.
• Pulp and paper mills are tied with petroleum refineries as the most
frequently inspected sectors of those listed.
• Pulp and paper mills have a relatively high percent of facilities with
violations and enforcement actions and a relatively high rate of
enforcement per inspection compared to the other sectors listed.
Tables 23 and 24 provide a more in-depth comparison between the pulp and
paper industry and other sectors by breaking out the compliance and
enforcement data by environmental statute. As in the previous Tables
(Tables 21 and 22), the data cover the last five years (Table 23) and the last
two years (Table 24) to facilitate the identification of recent trends. Two
points evident from the data are listed below.
• The majority of inspections and actions are conducted under the
CAA, followed by the CWA.
• In the past 2 years, the portion of actions taken under the CAA is
increasing, while that taken under the CWA is decreasing.
• The pulp and paper industry has one of the lowest percentages of
RCRA inspections and actions of those sectors listed.
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Compliance and Enforcement History
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Sector Facility Indexing Project ~ Additional compliance information for
the pulp and paper industry is available through EPA's Sector Facility
Indexing Project (SFIP). This is a website that brings together environmental
and other information from a number of data systems to produce facility-
level profiles for five industry sectors (pulp manufacturing, petroleum
refining, iron and steel production, primary nonferrous metal refining and
smelting, and automobile assembly) and a subset of major federal facilities.
SFIP information relates to compliance and inspection history, chemical
releases and spills, demographics of the surrounding population and
production. (Contact: SFIP hotline at 617-520-3015 or the website at
http://www.epa.gov/sfipmtnl/)
VII.C. Review of Major Legal Actions
This section provides summary information about major cases that have
affected this sector, and a list of Supplementary Environmental Projects
(SEPs). SEPs are compliance agreements that reduce a facility's stipulated
penalty in return for an environmental project that exceeds the value of the
reduction. Often, these projects fund pollution prevention activities that can
significantly reduce the future pollutant loadings of a facility.
This section discusses major legal cases and pending litigation within the
pulp and paper industry as well as supplemental environmental projects
(SEPs) involving pulp and paper facilities. Information regarding major cases
or pending litigation is available from the Office of Regulatory Enforcement.
VII.C.l. Review of Major Cases
In FY 1999 and FY 2000, three significant enforcement cases affecting the
pulp and paper industry were concluded.
Potlatch Corporation. A Clean Air Act settlement was reached with the
Potlatch Corporation of Lewiston, ID. From 1991 to 1996, Potlatch burned
used tires in the boiler at its Lewiston, Idaho, pulp mill plant. In 1997, EPA
issued Potlatch a Notice of Violation alleging that the burning of tires
resulted in sulfur dioxide emissions that exceeded limits in a Clean Air Act
permit issued by EPA in 1980 and also exceeded limits in a permit issued by
the State in 1979. The notice also alleged that the switch to burning tires was
the type of change that required Potlatch to first obtain a permit under the
Clean Air Act's Prevention of Significant Deterioration preconstruction
review program. Following issuance of the Notice of Violation, settlement
negotiations took place and an agreement was reached to settle the violations
described in the notice by payment of a $500,000 civil penalty. Potlatch has
the option of burning tires if it obtains a permit and installs the required
pollution control devices, but has elected not to do so.
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Crane & Co., Inc. Crane & Co., Inc. ("Crane"), of Dalton, MA operates as
a manufacturer and distributor of high quality specialty paper for the
securities, legal, banking and business markets. This family owned and run
company is nearly 200 years old, and has successfully held a currency paper
contract with the U.S. Department of Treasury for 121 years. EPA's civil
administrative complaint under the Emergency Planning and Community
Right to Know Act (EPCRA) focused on violations found at three of Crane's
facilities in Dalton and Pittsfield, MA.
Since calendar year 1994, Crane failed to file chemical inventory information
(Tier II forms) for three of its manufacturing facilities with the State
Emergency Response Commission (SERC), Local Emergency Planning
Committee (LEPC) or local fire departments, as required by Section 312 of
EPCRA. In total, Crane failed to report 28 chemicals, including sulfiiric acid
and formaldehyde (a component of melamine resin), which EPCRA classifies
as Extremely Hazardous Substances.
By the terms of the September 2000 settlement of this action, Crane will pay
a penalty of $8,164 and perform a supplemental environmental project'(SEP)
estimated to cost between $26,832 and $100,000. The SEP consists of
replacing sodium hypochlorite as a bleaching agent in the non-wood pulp
paper-making processes at the Pioneer Mill in Dalton with a 50 percent
hydrogen peroxide solution. Use of peroxide bleaching will reduce human
and environmental exposure to residual chlorine and chlorite ions that result
from use of sodium hypochlorite. In addition, replacement of sodium
hypochlorite with hydrogen peroxide will eliminate potential exposure of
first responders and on-site workers to chlorine gas, which can be created if
sodium hypochlorite is improperly mixed, used, or stored. Finally,
discontinuing the use of sodium hypochlorite will reduce the environmental
threat posed by discharging chlorinated organic compounds into the
receiving waters of the Housatonic River.
Appleton Papers. Appleton Papers in Roaring Spring, Pennsylvania
produces pulp using the kraft process and paper using mechanical paper
machines. Initially EPA issued a compliance order to Appleton requiring the
initial performance test of the brown stock washer system and installation of
the continuous emission monitoring system (CEMS) required by the NSPS
of the Clean Air Act. These violations were subsequently referred to the
Department of Justice on 12/30/98, and a Notice of Violation was issued to
Appleton on 4/19/99. Following a series of negotiations, EPA and Appleton
reached a settlement which provided for a cash penalty of $490,000 and early
compliance with the Pulp and Paper MACT. The penalty reflects the avoided
costs of installation of Total Reduced Sulfur CEMS, as well as the
company's adherence to EPA's initial compliance order. The Consent Decree
was lodged August 16,2000.
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VII.C.2. Supplementary Environmental Projects
SEPs are compliance agreements that reduce a facility's non-compliance
penalty in return for an environmental project that exceeds the value of the
reduction. Often, these projects fund pollution prevention activities that can
reduce the future pollutant loadings of a facility. Information on SEP cases
can be accessed via the Internet at http://www.epa.gov/compliance/resources/
po licies/civil/seps/index .html.
Table 25 presents nine examples of SEPs negotiated with pulp and paper
facilities.
Six of the cases were associated with EPCRA - most relate to a failure to
notify community and state emergency coordinators of a hazardous substance
release (§304), a violation of emergency and hazardous chemical inventory
form requirements (§312), or a violation of toxic chemical release form
requirements (§313). In addition, there were multiple cases involving a
violation of permit requirements for treatment, storage, or disposal of
hazardous waste (RCRA §3005).
There were three general types of SEPs seen within the pulp and paper
settlements:
Three of the SEPs involve emergency planning and response. In
each case, the defendants purchased equipment for local emergency
response authorities.
Five SEPs provide a form of pollution reduction. These were
facility-specific, but generally involved the replacement of equipment
that is more efficient or less prone to environmental releases.
• Two SEPs involve pollution prevention. These projects involved
the installation of technologies that reuse process waste.
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Activities and Initiatives
VIII. COMPLIANCE ACTIVITIES AND INITIATIVES
This section highlights the activities undertaken by this industry sector and
public agencies to voluntarily improve the sector's environmental
performance. These activities include those independently initiated by
industrial trade associations. In this section, the notebook contains a listing
and description of national and regional trade associations.
VIII.A. Sector-Related Environmental Programs and Activities
National Environmental Performance Track
EPA's National Environmental Performance Track Program is designed to
motivate and reward top environmental performance. By encouraging a
systematic approach to managing environmental responsibilities, taking extra
steps to reduce and prevent pollution, and being good corporate neighbors,
the program is rewarding companies that strive for environmental excellence.
At the same time, many participating companies are finding that they are
saving money and improving productivity. Five pulp and paper mills are
participating in the program. (Contact: Performance Track hotline at 888-
339-PTRK or the website at www.epa.gov/performancetrack/.}
WasteWiSe Program
The WasteWi$e Program was started in 1994 by EPA's Office of Solid
Waste and Emergency Response. The program is aimed at reducing
municipal solid wastes by promoting waste minimization, recycling
collection and the manufacturing and purchase of recycled products. As of
2001, the program had about 1,175 companies as members, including a
number of major corporations. Members agree to identify and implement
actions to reduce their solid wastes and must provide EPA with their waste
reduction goals along with yearly progress reports. EPA in turn provides
technical assistance to member companies and allows the use of the
WasteWi$e logo for promotional purposes. Twenty one pulp and paper
companies are partners. (Contact: Jeff Tumarkin at EPA's Office of Solid
Waste and Emergency Response at 703-308-8686 or
Tumarkin.Jeff@epa.gov, or the WasteWi$e Hotline at 800-EPA-WISE (372-
9473) or www.epa. gov/wastewise.'}
Project XL
Project XL, which stands for "excellence and Leadership," is a national pilot
program that allows state and local governments, businesses and federal
facilities to develop with EPA innovative strategies to test better or more
cost-effective ways of achieving environmental and public health protection.
In exchange, EPA will issue regulatory, program, policy, or procedural
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flexibilities to conduct the experiment. Under Project XL private businesses,
federal facilities, business sectors and state and local governments are
conducting experiments that address the following eight Proj ect XL selection
criteria:
1. produce superior environmental results beyond those that would have
been achieved under current and reasonably anticipated future
regulations or policies
2. produce benefits such as cost savings, paperwork reduction,
regulatory flexibility or other types of flexibility that serve as an
incentive to both project sponsors and regulators
3. supported by stakeholders
4. achieve innovation/pollution prevention
5. produce lessons or data that are transferable to other facilities
6, demonstrate feasibility
7, establish accountability through agreed upon methods of monitoring,
reporting, and evaluations
8. avoid shifting the risk burden, i.e., do not create worker safety or
environmental justice problems as a result of the experiment.
By 2002, three pulp and paper companies (Georgia-Pacific, International
Paper, and Weyerhaeuser) had undertaken projects under Project XL. (For
more information, contact Chris Knopes in the Office of Reinvention
Programs at 202-260-9298 or Knopes. Christopher(3),epa. gov. or the website
at www.epa.gov/projectxl/.}
Energy Star
In 1991, EPA introduced Green Lights®, a program designed for businesses
and organizations to proactively combat pollution by installing energy
efficient lighting technologies in their commercial and industrial buildings.
In April 1995, Green Lights® expanded into Energy Star® Buildings— a
strategy that optimizes whole-building energy-efficiency opportunities. The
energy needed to run commercial and industrial buildings in the United
States produces 19 percent of U.S. carbon dioxide emissions, 12 percent of
nitrogen oxides, and 25 percent of sulfur dioxide, at a cost of $110 billion a
year. If implemented in every U.S. commercial and industrial building, the
Energy Star® Buildings upgrade approach could prevent up to 35 percent of
the emissions associated with these buildings and cut the nation's energy bill
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by up to $25 billion annually.
The more than 7,000 participants include corporations, small businesses,
universities, health care facilities, nonprofit organizations, school districts,
and federal and local governments. Energy Star has successfully delivered
energy and cost savings across the country, saving businesses, organizations,
and consumers more than $5 billion a year. Over the past decade, Energy
Star has been a driving force behind the more widespread use of such
technological innovations as LED traffic lights, efficient fluorescent lighting,
power management systems for office equipment, and low standby energy
use.
Manufacturers can become partners in Energy Star by pledging to undertake
the following steps:
NICE1
Measure, track, and benchmark their organization's energy
performance by using tools such as those offered by Energy Star
Develop and implement a plan to improve energy performance in
their facilities and operations by adopting the strategy provided by
Energy Star
Educate their staff and the public about our partnership with Energy
Star, and highlight our achievements with the Energy Star label,
where available.
-782-7937) or
1.
2.
3.
(Contact: Energy Star Hotline, 1-888-STAR-YES (1-
http://www.energystar.gov/default.shtml.)
The U.S. Department of Energy administers a grant program called The
National Industrial Competitiveness through Energy, Environment, and
Economics (NICE3). By providing grants of up to 50 percent of the total
project cost, the program encourages industry to reduce industrial waste at
its source and become more energy-efficient and cost-competitive through
waste minimization efforts. Grants are used by industry to design, test,
demonstrate, and assess the feasibility of new processes and/or equipment
with the potential to reduce pollution and increase energy efficiency. The
program is open to all industries; however, priority is given to proposals from
participants in the chemicals, agriculture, aluminum, pulp and paper, glass,
metal casting, mining, petroleum, and steel industries. (Contact: DOE's
Golden Field Office 303-275-4728, or see the website at
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EPA Audit Policy
The U.S. Environmental Protection Agency (EPA) encourages companies
with multiple facilities to take advantage of the Agency's Audit Policy
(Incentives for Self-Policing: Discovery, Disclosure, Correction and
Prevention of Violations, 65 Fed. Reg. 19618 (April 11, 2000)) to conduct
audits and develop environmental compliance systems. The Audit Policy
eliminates gravity-based penalties for companies that voluntarily discover,
promptly disclose and expeditiously correct violations of federal
environmental law. More information on EPA's Audit Policy can be obtained
from the Web site at: http://www.epa.gov/compliance/resources/policies/
incentives/ auditing/index, html.
Small Business Compliance Policy
The Small Business Compliance Policy promotes environmental compliance
among small businesses (those with 100 or fewer employees) by providing
incentives to discover and correct environmental problems. EPA will
eliminate or significantly reduce penalties for small businesses that
voluntarily discover violations of environmental law and promptly disclose
and correct them. A wide range of resources are available to help small
businesses learn about environmental compliance and take advantage of the
Small Business Compliance Policy. These resources include: training,
checklists, compliance guides, mentoring programs, and other activities.
Businesses can find more information through links on the Web site:
http ://www. epa.gov/smallbusiness/.
Compliance Assistance Clearinghouse
The National Environmental Compliance Assistance Clearinghouse is a
Web-based clearinghouse designed to provide quick access to compliance
assistance tools, contacts, and planned activities across EPA and other
compliance assistance providers. The Clearinghouse also serves as a forum
to collaborate and exchange information. The Clearinghouse provides links
to compliance assistance activities, tools, or technical assistance that: 1)
assist the regulated community in understanding and complying with
environmental regulations; or 2) assist compliance assistance providers in
helping the regulated community to comply with environmental regulations.
The Clearinghouse Web site is http://www.epa.gov/clearinghouse/.
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VIII.B. Trade Association/Industry Sponsored Activities
VIII.B.l. Environmental Programs
Global Environmental Management Initiative
ISO 14000
The Global Environmental Management Initiative (GEMI) is made up of
group of leading companies dedicated to fostering environmental excellence
by business. GEMI promotes a worldwide business ethic for environmental
management and sustainable development, to improve the environmental
performance of business through example and leadership. In 2001, GEMTs
membership consisted of about 40 major corporations including the pulp and
paper company Georgia-Pacific. (Contact: GEMI at 202-296-7449 or see the
website at: www.gemi.org.}
ISO 14000 is a series of internationally-accepted standards for environmental
management. The series includes standards for environmental management
systems (EMS), guidelines on conducting EMS audits, standards for auditor
qualifications, and standards and guidance for conducting product lifecycle
analysis. Standards for auditing and EMS were adopted in September 1996,
while other elements of the ISO 14000 series are currently in draft form.
While regulations and levels of environmental control vary from country to
country, ISO 14000 attempts to provide a common standard for
environmental management. The governing body for ISO 14000 is the
International Organization for Standardization (ISO), a worldwide federation
of over 110 country members based in Geneva, Switzerland. The American
National Standards Institute (ANSI) is the United States representative to
ISO. Information on ISO is available at the following Internet site:
http://www. iso. ch/iso/en/ISOOnline. openerpage.
50 Percent Paper Recovery Goal
At the beginning of this decade, the U.S, paper industry made an
unprecedented public commitment to expand paper recovery and recycling
by establishing a goal to recover 40 percent of all the paper Americans used
in 1995. That program involved a wide array of tools to encourage efficient
paper recovery as well as a maj or financial commitment by U.S. papermakers
to expand recycling capacity at their mills. The public-private partnership
that evolved proved enormously successful: the industry's goal was achieved
a year ahead of schedule.
Given the success of this initiative, the industry, through its trade association,
the American Forest & Paper Association, established a new goal to recover
50 percent of all the paper Americans use and to continue its work to
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promote efficient paper recovery programs. By 2000, the U.S. paper recovery
rate was 48 percent. (Contact: AF&PA at 202-463-2700 or see the website
at www. afandpa. org.)
100% Recycled Paperboard Alliance
The 100% Recycled Paperboard Alliance (RPA-100%) is a group of leading
North American recycled paperboard manufacturers representing nearly two-
thirds of the recycled paperboard industry, and a sponsor of America
Recycles Day.
RPA-100% encourages packaged goods and companies to use 100% recycled
paperboard and educates consumers about the importance of buying recycled.
Almost fifty companies have joined a new intiative from the 100% Recycled
Paperboard Alliance, displaying the " 100% Recycled Paperboard" symbol on
their brand name and private label products. (Contact: 100% Recycled
Paperboard Alliance at 877-772-6200 or see the website at
wwty.rpaJOO.com.')
Agenda 2020
In 1994, the American Forest and Paper Association joined with the U.S.
Department of Energy to launch Agenda 2020, an innovative, collaborative
research program. Through Agenda 2020, a consortium of research
institutions, industry, and national laboratories is developing new
technologies, processes and measurements to manufacture products more
efficiently and cost-effectively while reducing environmental impacts of
operations and maximizing the efficient use and reuse of resources.
To meet these objectives, Agenda 2020 has identified six technology focus
areas for collaborative research efforts. These six task groups represent a
broad cross section of the forest products industry:
1. Sustainable Forest Management
2. Environmental Performance
3. Energy Performance
4. Improved Capital Effectiveness
5. Recycling
6. Sensors and Controls
Particularly noteworthy is the effort within the Agenda 2020 partnership to
develop biomass gasification technologies. If fully commercialized, these
technologies could make the U. S. forest products industry totally energy self-
reliant and generate a surplus of 22 gigawatts of power to the grid—the
equivalent of one-half of California's peak summertime electric use. The
carbon displacement from biomass gasification could be even more dramatic,
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Activities and Initiatives
transforming the industry from emitting 24 million tons of carbon each year
to displacing at least 18 million tons of greenhouse gas from fossil fuels -
before taking into consideration the carbon sequestration benefits of forests.
Black liquor (see Section III for a description) is one biomass fuel created
during the chemical pulping process. Gasification converts these pulping
extractives and other forms of biomass into combustible gases that can be
efficiently burned like natural gas. If fully commercialized, these
technologies could produce enormous energy and environmental benefits.
The first commercial-scale biomass (black liquor) plant is being built by
Georgia-Pacific Corp. in Big Island, VA. It is slated to go on-line in 2003.
Other commercialization tests will continue over the next 10 years, if
adequately funded. Industry participants are putting up 50 percent of the
investment capital for these demonstration projects. (Contact: AF&PA at
202-463-2700 or see the website at www.a%enda2020.or?.}
VIII.B.2. Summary of Trade Associations
The trade and professional organizations serving the pulp and paper industry
are lead by the American Forest and Paper Association (AFPA), formerly the
American Paper Institute (API). They have been actively involved in a
number of recent rulemakings (under CAA, CWA and RCRA) that will affect
their members. The National Council of the Paper Industry for Air and
Stream Improvement (NCASI) does technical research for the industry. The
Technical Association of the Pulp and Paper Industry (TAPPI), is a technical
clearinghouse for the industry; they disseminate technical information to
production facility staff throughout the U.S.
American Forest and Paper Association
1111 19th Street, NW Members: 450
Suite 800 Staff: 140
Washington, DC 20036 Contact: Josephine Cooper,
Phone: 202-463-2700 V.P. for Environment and
Fax: 202-463-2471 Regulatory Affairs
Internet:
www. qfandpa. or%
The National Forest Products Association merged with the American Paper
Institute (API) in 1993 to become the American Forest and Paper Association
(AF&PA). AF&PA is the national trade association for the forest, pulp,
paper, paperboard, and wood products industry. The organization focuses on
information gathering/dissemination, research on industry technical issues,
and represents the industry in regulatory and legislative matters. The
AF&PA takes an active role by representing its members before
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governmental agencies, such as on the recent integrated air and water rule.
Some current environmental initiatives include the 2020 Research Agenda,
50 percent recycling goal, and the Sustainable Forestry Initiative. The
AF&PA publishes a variety of documents for and about its membership.
Some relevant publications include the annual industry wide reviews
Capacity Report and Statistics of Paper, Paperboard, and Wood Pulp, the
Paper, Paperboard, and Wood Pulp Monthly Statistical Summary, and the
Dictionary of Paper, published every ten years. Circulation for these
publications is listed at 1,000. The AF&PA holds an annual meeting every
March in New York City.
National Council of the Paper Industry for Air and Stream Improvement
P.O. Box 13318
Research Triangle Park, NC 27709
Phone:919-558-1999
Fax:919-558-1998
Internet: www.ncasi.ore
Members: 78
Staff: 90
Budget: $10,000,000
Contact: Dr. Ronald Yeske
Founded in 1943, the National Council of the Paper Industry for Air and
Stream Improvement (NCASI) presently conducts research on environmental
problems related to industrial forestry and the manufacture of pulp, paper,
and wood products. NCASI produces technical documents on environmental
issues facing the pulp and paper industry and conducts industry conferences.
Publications include: a biweekly bulletin on general issues and a variety of
technical bulletins (40/year). NCASI also holds an annual March convention
in New York City.
Technical Association of the Pulp and Paper Industry (TAPPI)
Techno logy Park/Atlanta
P.O. Box 105113
Atlanta, GA 30348
Phone:770-446-1400
Fax: 770-446-6947
Internet: www.taDiti.ors
Members: 33,000
Staff: 95
Budget: $13,000,000
Contact: Charles Bohanan
Technical Divisions Operator
The Technical Association of the Pulp and Paper Industry (TAPPI)
represents executives, managers, engineers, research scientists,
superintendents, and technologists in the pulp, packaging, paper, and allied
industries. Founded in 1915, TAPPI is split into eleven divisions, which
include: environmental, research and development, paper and board
manufacture, and pulp manufacture. Though its headquarters are in Atlanta,
TAPPI is also divided into 27 regional groups. Overall, TAPPI provides a
variety of services to its members. TAPPI conducts conferences on topics
such as forest biology, environment, packaging, pulp manufacture, and R&D
Sector Notebook Project
117
November 2002
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Pulp and Paper Industry
Activities and Initiatives
in addition to a more general annual conference. TAPPI also develops
testing methodologies for process control and laboratory analysis. The main
annual project of the TAPPI Environmental division consists of an
environmental issues industry conference. In 1995, TAPPI launched a
campaign to educate the public on industry environmental facts. TAPPI
publications include an annual Membership Directory, a monthly TAPPI
Journal, and the publication of research results. TAPPI's publications are
available via an online catalogue and record retrieval system called TAPPI-
net available at 800-332-8686.
Paper Industry Management Association
1699 Wall Street, Suite 212 Members: 5,000
Mount Prospect, IL 60056
Phone: 847-956-0250
Fax: 847-956-0520
Internet: www.mma-onUne.or2
Staff: 14
Budget: $2,000,000
Contact: Scott Baumruck, Chief
Operating Officer
The Paper Industry Management Association, or PIMA, is a professional
organization of pulp, paper mill, andpaper converting production executives.
The association has provided management oriented information to its
membership since 1919. This association goal is embodied by their
publications: an annual Handbook of the industry, a monthly PIMA Magazine
dedicated to improving efficiency and productivity, and the annual PIMA
Pulp and Paper Mill Catalog reference for industry management. This
catalog contains information regarding equipment, raw materials, and
chemical products, in addition to a trade name directory, a listing of
manufacturers and suppliers, and a listing of reports relevant to pulp and
paper manufacture.
Sector Notebook Project
118
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Pulp and Paper Industry
Contacts and References
IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY
For further information on selected topics within the pulp and paper industry
a list of publications and contacts are provided below:
Contacts4
Name
Scott Throwe
Steve Shedd
Jeff Telander
Don Anderson
Deborah Nagle
Tim Smith
Kevin Culligan
Dickson Ozokwelu
James Bond
Organization
U.S. EPA, Office of
Compliance
U.S. EPA, Office of Air
and Radiation
U.S. EPA, Office of Air
and Radiation
U.S. EPA, Office of
Water
U.S. EPA, Office of
Water
Office of Air and
Radiation
Office of Air and
Radiation
U.S. Department of
Energy, Office of
Industrial Technology
USDA Forest Service
Telephone/Email
202-564-7013
throwe.scott@epa.gov
919-541-5397
shedd.steve@epa.gov
919-541-5427
telander.jeff@epa.gov
202-260-7189
anderson.donald@epa.gov
202-260-2656
nagle.deborah
919-541-4718
smith.tim@epa.gov
202-564-9172
culligan.kevin@epa.gov
202-586-8501
dickson.ozokwelu@ee.doe.gov
608-231-9480
jbond@fs.fed.us
Subject
Pulp and paper industry
sector lead
Combustion MACT
NESHAP Subpart S
Non-combustion MACT
NESHAP Subpart MM
Effluent guidelines and
standards
Cooling water intake
standards
Guidelines on Best
Available Retofit
Technology (BART)
NOx SIP Call
Technologies and
processes with the
potential for energy,
environmental, and cost
savings
Research on
environmentally benign
and resource-conserving
processes for the
production and utilization
of wood pulp fibers and
chemical byproducts
4 Many of the contacts listed above have provided valuable background information and comments during the
development of this document. EPA appreciates this support and acknowledges that the individuals listed do not
necessarily endorse all statements made within this notebook.
Sector Notebook Project
119
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Pulp and Paper Industry
Contacts and References
General Profile
AF&PA, 1999.1999 Statistics: Data Through 1998. American Forest & Paper Association.
McLaren, J et al., 2000. "North American Status Report," Pulp & Paper. August.
Pulp & Paper Magazine, 2001. "PaperHelp Online."
httD://www.Darjerlooa£om/pD_rn av/Danerhelv/homeDave.sh tm I.
U.S. Census Bureau, 1998. 1997 County Business Patterns for the United States.
U.S. Census Bureau, 2000a. 7997 Economic Census: Bridge Between NAICS and SIC.
U.S. Census Bureau, 2000b. 1997 Economic Census: Comparative Statistics for United States
(1987 SIC Basis).
U.S. Department of Commerce/International Trade Administration, 2000. U.S. Industry & Trade
Outlook 2000. U.S. Department of Commerce, McGraw-Hill.
U.S. Department of Energy, 2000. "Forest Products Project Fact Sheet: Closed-Cycle Bleach
Kraft Pulp Production." Office of Industrial Technologies. October.
U.S. Environmental Protection Agency, 1993. Development Document for Proposed Effluent
Limitations Guidelines and Standards for the Pulp, Paper, and Paperboard Point Source
Category. October.
U.S. Environmental Protection Agency, 1999. Toxics Release Inventory Database.
Process Descriptions and Chemical Use Profiles
AF&PA, 1994. 7994 Statistics, Data Through 1993. Washington, D.C.: American Forest and
Paper Association.
AF&PA, 1995a. Improving Tomorrow's Environment Today. January.
Sector Notebook Project
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Pulp and Paper Industry
Contacts and References
AF&PA, 1995b. Personal communication.
AF&PA, 1995c. Recovered Paper Deinking Facilities. American Forest and Paper Association:
Economics and Materials Department. January.
AF&PA, 2000a. Paper Recovery Progress Report. May.
AF&PA, 2000b. 2000 Recovered Paper Statistical Highlights.
htto://\vww. afandpa, ore/recvcline/Rec introduction, html.
AF&PA, 2000c. Paper Recycling Facts.
http://www.afandpa.ore/recvcline/Rec panerrecfacts open.html.
AF&PA, 2002. Written comments from Richard Wasserstrom to Seth Heminway, EPA Office
of Compliance. March 7.
Richard J. Albert, "Effluent-Free Pulp Mill Possible with Existing Fiberline Equipment," Pulp &
Paper, 68(7), July 1994, pp. 83-89.
Alliance for Environmental Technology, 2001. "Trends in World Bleached Chemical Pulp
Production: 1990-2000." January.
http://www.aet.ofv/reDorts/market/aet trends 2000.html.
American Paper Institute. Report on the Use of Pulping and Bleaching Chemicals in the U.S.
P&P Industry, June 26,1992.
Lee Brunner and Terry Pulliam, "Comprehensive Impact Analysis of Future Environmentally
Driven Pulping and Bleaching Technologies," 1992 TAPPI Pulping Conference,
Boston, MA. ;
David Forbes, "Mills Prepare for Next Century with New Pulping, Bleaching Technologies,"
Pulp & Paper, Sept '92.
Pulp and Paper Magazine, 2001. PaperHelp Online Encyclopedia,
htto:'//www.DaDerlooD.com/DD mae/paverhelp.
Sector Notebook Project
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Pulp and Paper Industry
Contacts and References
Smook, G.A., 1992. Handbook for Pulp & Paper Technologists, Second edition. Vancouver:
Angus Wilde Publications.
U.S. Department of Commerce, 2000. U.S. Industry & Trade Outlook 2000, McGraw-Hill
Companies and U.S. Department of Commerce/International Trade Administration.
U.S. EPA, 1988.104-Mill Study,
U.S. EPA, 1990. Summary of Technologies for the Control and Reduction of Chlorinated
Organicsjrom the Bleached Chemical Pulping Subcategories of the Pulp and Paper
Industry.
U.S. EPA, 1990. 1990 National Census of Pulp, Paper, and Paperboard Manufacturing
Facilities.
U.S. EPA, 1993a. Development Document for Proposed Effluent Limitations Guidelines and
Standards for the Pulp, Paper, and Paperboard Point Source Category. October.
U.S. EPA, 1993b. Pollution Prevention Technologies for the Bleached Kraft Segment of the U.S.
Pulp and Paper Industry.
U.S. EPA, 1993c. Pulp, Paper and Paperboard Industry - Background Information for
Proposed Air Emission Standards: Manufacturing Processes at Kraft, Sulfite, Soda, and
Semi-Chemical Mills (NESHAP).
U.S. EPA, 1995. Office of Water, Personal communication. June.
U.S. EPA, 2002. Personal communication from Jacquelyn Vega, National Enforcement
Investigations Center, to Seth Heminway, Office of Compliance. March 1.
VDP, 1997. Papier '97 - Ein Leistungsbericht. Verband Deutscher Papierfabriken: Bonn,
Germany.
Chemical Releases and Transfers
Air & Waste Management Association, 1992. Air Pollution Engineering Manual.
Sector Notebook Project
122
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Pulp and Paper Industry
Contacts and References
U.S. EPA, 2001a. AIRS Database. Office of Air and Radiation. November.
U.S. EPA, 2001b. Toxics Release Inventory Database.
Pollution Prevention
Chlorine-Free Bleaching of Kraft Pulp: Feasibility Study, sponsored by Domtar Inc., the Ontario
Ministry of the Environment, and Environment Canada, June 1993. Available from
Great Lakes Pollution Prevention Centre 519-337-3423.
Howard Deal, "Environmental Pressure Causes Changes in Bleaching Technologies,
Chemicals," Pulp & Paper, Nov. '91.
Bruce Fleming, Alternative and Emerging Non-Kraft Pulping Technologies, EPA-744R-93-002.
Neil McCubbin, Costs and Benefits of Various Pollution Prevention Technologies in the Kraft
Pulp Industry, EPA-744R-93-002.
NCASI Technical Workshop— Effects of Alternative Pulping and Bleaching Processes on
Production and Biotreatability of Chlorinated Organics, NCASI Special Report No. 94-
01, Feb. 1994.
U.S. EPA, 1993. Pollution Prevention Technologies for the Bleached Kraft Segment of the U.S.
Pulp and Paper Industry, EPA/6QQ/R.-93/11Q
Regulatory Profile
U.S. EPA, 1997. Fact Sheet: EPA's Final Pulp, Paper, and Paperboard "Cluster Rule "
Overview. November.
U.S. EPA, 1998. Pulp andPaper NESHAP: A Plain English Description, November.
U.S. EPA, 1999a. Kraft Pulp Mill Compliance Assessment Guide. May.
Sector Notebook Project
123
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Pulp and Paper Industry
Contacts and References
U.S. EPA, 1999b. Questions and Answers for the Pulp and Paper NESHAP. September.
U.S. Government Printing Office, 2001 a. Unified Agenda, Volume 66, Number 93, Pages
26264-26265.
U.S. Government Printing Office, 2001b. Unified Agenda. Volume 66, Number 93, Pages
26269-26270.
Sector Notebook Project
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