,<.»""'•"•<.,
'** \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
11
                                                                       November 2002

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Pulp and Paper Industry
                                          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
                  111
November 2002

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Pulp and Paper Industry
                   Sector Notebook Project
                             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
IV
                            November 2002

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Pulp and Paper Industry
Sector Notebook Project
                          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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Pulp and Paper Industry
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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
Vll
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Pulp and Paper Industry
                   Sector Notebook Project
                            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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Pulp and Paper Industry
                    Sector Notebook Project
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
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Pulp and Paper Industry
Sector Notebook Project
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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Pulp and Paper Industry
Sector Notebook Project
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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Pulp and Paper Industry
Sector Notebook Project
                    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.
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          November 2002

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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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                      November 2002

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Pulp and Paper Industry
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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Pulp and Paper Industry
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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Pulp and Paper Industry
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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Pulp and Paper Industry
         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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Pulp and Paper Industry
         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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Pulp and Paper Industry
        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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Pulp and Paper Industry
         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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Pulp and Paper Industry
         Introduction, Background, and Scope
                     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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Pulp and Paper Industry
               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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Pulp and Paper Industry
               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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Pulp and Paper Industry
               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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Pulp and Paper Industry
               Industrial Process Description
                    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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 Pulp and Paper Industry
                 Industrial Process Description
                      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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Pulp and Paper Industry
               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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               Industrial Process Description
      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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                Industrial Process Description
                    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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               Industrial Process Description
                    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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                Industrial Process Description
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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               Industrial Process Description
       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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Pulp and Paper Industry
              Industrial Process Description
             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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Pulp and Paper Industry
               Industrial Process Description
                    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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Pulp and Paper Industry
                Industrial Process Description
                    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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  Pulp and Paper Industry
               Industrial Process Description
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
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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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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.
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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
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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,
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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
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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.

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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
50
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)
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
52
November 2002

-------
Pulp and Paper Industry
               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.
Sector Notebook Project
53
November 2002

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Pulp and Paper Industry
            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
 Sector Notebook Project
54
November 2002

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Pulp and Paper Industry
             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).
Sector Notebook Project
55
November 2002

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Pulp and Paper Industry
            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.
 Sector Notebook Project
56
November 2002

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Pulp and Paper Industry
             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,
Sector Notebook Project
57
November 2002

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Pulp and Paper Industry
            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
58
November 2002

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Pulp and Paper Industry
             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
59
November 2002

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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 -


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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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  Pulp and Paper Industry
            Chemical Releases and Transfers
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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 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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Pulp and Paper Industry
                         Pollution Prevention
                    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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                        Pollution Prevention
                    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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Pulp and Paper Industry
             Federal Statutes and Regulations
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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             Federal Statutes and Regulations
                     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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Pulp and Paper Industry
             Federal Statutes and Regulations
                    (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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             Federal Statutes and Regulations
                    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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            Federal Statutes and Regulations
                    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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            Federal Statutes and Regulations
                    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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               Federal Statutes and Regulations
                    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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             Federal Statutes and Regulations
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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             Federal Statutes and Regulations
                    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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            Federal Statutes and Regulations
                    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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        Compliance and Enforcement History
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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Pulp and Paper Industry                           Compliance and Enforcement History

                    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).

Sector Notebook Project                    96                           November 2002

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 Pulp and Paper Industry
         Compliance and Enforcement History
                     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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Pulp and Paper Industry
       Compliance and Enforcement History
                    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
  Sector Notebook Project
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                                                                          November 2002

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Pulp and Paper Industry
        Compliance and Enforcement History
                   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).
Sector Notebook Project
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November 2002

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Pulp and Paper Industry
        Compliance and Enforcement History



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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.
Sector Notebook Project
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November 2002

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Pulp and Paper Industry
                                        Compliance and Enforcement History
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Sector Notebook Project
103
November 2002

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Pulp and Paper Industry
        Compliance and Enforcement History
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105
November 2002

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Pulp and Paper Industry
        Compliance and Enforcement History
                    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.
 Sector Notebook Project
106
November 2002

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Pulp and Paper Industry
         Compliance and Enforcement History
                    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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        Compliance and Enforcement History
       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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Pulp and Paper Industry
        Compliance and Enforcement History




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Sector Notebook Project
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Pulp and Paper Industry
                     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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Pulp and Paper Industry
                      Activities and Initiatives
                    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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Pulp and Paper Industry
                                            Activities and Initiatives
                    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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                      Activities and Initiatives
       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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                      Activities and Initiatives
                    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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Pulp and Paper Industry
                     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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Pulp and Paper Industry
                      Activities and Initiatives
                    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
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                     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.
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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
November 2002

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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
120
November 2002

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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
121
November 2002

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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
November 2002

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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
November 2002

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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
124
November 2002

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