United States
Agfericy
ERA Office Of Compli^g
Sector Notebook
't.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE ADMINISTRATOR
Message from the Administrator
Over the past 25 years, our nation has made tremendous progress in protecting public health and
our environment while promoting economic prosperity. Businesses as large as iron and steel
plants and businesses as small as the dry cleaner on the corner have worked with EPA to find
ways to operate cleaner, cheaper, and smarter. As a result, we no longer have rivers catching on
fire. Our skies are clearer. American environmental technology and expertise are in demand
throughout the world.
The Clinton Administration recognizes that to continue this progress, we must move beyond the
pollutant-by-pollutant approaches of the past to comprehensive, facility-wide approaches for the
future. Industry by industry and community by community, we must build a new generation of
environmental protection.
Within the past two years, the Environmental Protection Agency undertook its Sector Notebook
Project to compile, for a number of key industries, information about environmental problems and
solutions, case studies and tips about complying with regulations. We called on industry leaders,
state regulators, and EPA staff with many years of experience in these industries and with their
unique environmental issues. Together with notebooks for 17 other industries, the notebook you
hold in your hand is the result.
These notebooks will help business managers to better understand their regulatory requirements,
learn more about how others in their industry have undertaken regulatory compliance and the
innovative methods some have found to prevent pollution in the first instance. These notebooks
will give useful information to state regulatory agencies moving toward industry-based programs.
Across EPA we will use this manual to better integrate our programs and improve our compliance
assistance efforts.
I encourage you to use this notebook to evaluate and improve the way that together we achieve
our important environmental protection goals. I am confident that these notebooks will help us to
move forward in ensuring that — in industry after industry, community after community —
environmental protection and economic prosperity go hand in hand.
Carol M. Browni
Recycled/Recyclable • Printed with Vegetable Based Inks on Recycled Paper (20% Postconsumer)
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Sector Notebook Project
Pulp and Paper Industry
EPA/310-R-95-015
EPA Office of Compliance Sector Notebook Project
Profile of the Pulp and Paper Industry
September 1995
Office of Compliance
Office of Enforcement and Compliance Assurance
U.S. Environmental Protection Agency
401 M St., SW (MC 2221-A)
Washington, DC 20460
For sale by the U.S. Government Printing Office
Superintendent of Documents, Mail Stop: SSOP, Washington, DC 20402-9328
ISBN 0-16-048282-8
September 1995
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Sector Notebook Project
Pulp and Paper Industry
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 Inc.
(Cambridge, MA), and Booz-Allen & Hamilton, Inc. (McLean, VA). This publication may be
purchased from the Superintendent of Documents, U.S. Government Printing Office. A listing of
available Sector Notebooks and document numbers is included at the end of this document.
AH telephone orders should be directed to:
Superintendent of Documents
U.S. Government Printing Office
Washington, DC 20402
(202)512-1800
FAX (202) 512-2250
8:00 a.m. to 4:30 p.m., ET, M-F
Using the form provided at the end of this document, all mail orders should be directed to:
U.S. Government Printing Office
P.O. Box 371954
Pittsburgh, PA 15250-7954
Complimentary volumes are available to certain groups or subscribers, such as public and academic
libraries, Federal, State, local, and foreign governments, and the media. For further information, and
for answers to questions pertaining to these documents, please refer to the contact names and
numbers provided within this volume.
Electronic versions of all Sector Notebooks are available on the EPA Enviro$en$e Bulletin Board
and via the Internet on the Enviro$en$e World Wide Web. Downloading procedures are described
in Appendix A of this document.
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Sector Notebook Contacts
The Sector Notebooks were developed by the EPA's Office of Compliance. Particular questions regarding the
Sector Notebook Project in general can be directed to:
Seth Heminway, Sector Notebook Project Coordinator ,
US EPA, Office of Compliance
401MSt,SW(2223-A)
Washington, DC 20460 ;
(202) 564-7017 fax (202) 564-0050
E-mail: heminway.seth@epamail.epa.gov
Questions and comments regarding the individual documents can be directed to the appropriate specialists listed
below.
Document Number
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
EPA/310-
-R-95-001.
-R-95-002.
-R-95-003.
-R-95-004.
-R-95-005.
-R-95-006.
-R-95-007.
-R-95-008.
-R-95-009.
-R-95-010.
-R-95-011.
-R-95-012.
•R-95-013.
-R-95-014.
-R-95-015.
-R-95-016.
-R-95-017.
-R-95-018.
R-97-001.
R-97-002.
R-97-003.
.R-97-004.
R-97-005.
R-97-006.
R-97-007.
R-97-008.
R-97-009.
R-97-010.
EPA/310-B-96-003.
Industry Contact Phone (202)
Dry Cleaning Industry '.
Electronics and Computer Industry
Wood Furniture and Fixtures Industry
Inorganic Chemical Industry
Iron and Steel Industry
Lumber and Wood Products Industry
Fabricated Metal Products Industry
Metal Mining Industry
Motor Vehicle Assembly Industry
Nonferrous Metals Industry
Non-Fuel, Non-Metal Mining Industry
Organic Chemical Industry
Petroleum Refining Industry
Printing Industry '.
Pulp and Paper Industry ;
Rubber and Plastic Industry
Stone, Clay, Glass, and Concrete Industry
Transportation Equipment Cleaning Ind.
*Air Transportation Industry :
Ground Transportation Industry
*Water Transportation Industry
Metal Casting Industry
Pharmaceutical Industry
Plastic Resin and Man-made Fiber Ind.
*Fossil Fuel Electric Power Generation Ind.
* Shipbuilding and Repair Industry
Textile Industry
* Sector Notebook Data Refresh, 1997
Federal Facilities Jim Edwards 564-2461
Joyce Chandler
Steve Hoover
Bob Marshall
Walter DeRieux
Maria Malave
Seth Heminway
Scott Throwe
Keith Brown
Suzanne Childress
Jane Engert
Keith Brown
Walter DeRieux
Tom Ripp
Ginger Gotliffe
Maria Eisemann
Maria Malave
Scott Throwe
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Virginia Lathrop
Jane Engert
Emily Chow
Sally Sasnett
Rafael Sanchez
Suzanne Childress
Belinda Breidenbach
Seth Heminway
564-7073
564-7007
564-7021
564-7067
564-7027
564-7017
564-7013
564-7124
564-7018
564-5021
564-7124
564-7067
564-7003
564-7072
564-7016
564-7027
564-7013
564-7057
564-7057
564-7057
564-7057
564-5021
564-7071
564-7074
564-7028
564-7018
564-7022
564-7017
*Currently in DRAFT anticipated publication in September 1997
This page updated during June 1997 reprinting
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Sector Notebook Project
Pulp and Paper Industry
Pulp and Paper Industry Sector Notebook Contents
Exhibits Index iii
List of Acronyms v
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 4
1. Industry Size and Geographic Distribution 5
2. Product Characterization 10
3. Economic Trends 13
III. INDUSTRIAL PROCESS DESCRIPTION 15
A. Industrial Processes in the Pulp and Paper Industry 15
1. Pulp Manufacture 18
2. Pulp Processing 25
3. Bleaching 30
4. Stock Preparation 34
5. Processes in Paper Manufacture 35
6. Energy Generation 37
B. Raw Material Inputs and Pollution Outputs in the Production Line 38
C. Management of Chemicals in Wastestream 48
IV. CHEMICAL RELEASE AND TRANSFER PROFILE 51
A. EPA Toxics Releases Inventory For the Pulp and Paper Industry 54
B. Summary of Selected Chemicals Released 59
C. Other Data Sources 63
D. Comparison of Toxic Release Inventory Between Selected Industries 64
V. POLLUTION PREVENTION OPPORTUNITIES 69
VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS 77
A. General Description of Major Statutes 77
B. Industry Specific Requirements 88
C. Pending and Proposed Regulatory Requirements 92
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VH. COMPLIANCE AND ENFORCEMENT HISTORY 97
A. Pulp and Paper Industry Compliance History 101
B. Comparison of Enforcement Activity Between Selected Industries 103
C. Review of Major Legal Actions 108
1. Review of Major Cases 108
2. Supplementary Environmental Projects 109
VIII. COMPLIANCE ACTIVITIES AND INITIATIVES 113
A. EPA Voluntary Programs 113
B. Trade Association/Industry Sponsored Activities 119
1. Environmental Programs 119
2. Summary of Trade Associations 120
DC CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY . 123
End Notes 127
Appendix A- Instructions for Down Loading Notebooks A
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Exhibits Index
Exhibit 1: Large Facilities Dominate Industry (SICs 2611, 2621, 2631) 6
Exhibit 2: Geographic Distribution of Mills Differs According to Type of Mill 7
Exhibit 3: Pulp, Paper, and Paperboard Mills 8
Exhibit 4: Top U.S. Companies with Pulp and Paper Manufacturing Operations 9
Exhibit 5: Number of Mills in U.S. by Pulping Process 11
Exhibit 6: Simplified Flow Diagram: Integrated Mill 17
Exhibit 7: General Classification of Wood Pulping Processes 18
Exhibit 8: Pulp Manufacturing Process Sequence 19
Exhibit 9: Relative Wastepaper Usage as Secondary Fiber in 1992 21
Exhibit 10: The Kraft Pulping Process (with chemical recovery) 29
Exhibit 11: Typical Bleach Plant 31
Exhibit 12: Common Chemicals ; 32
Exhibit 13: Bleaching Sequences 33
Exhibit 14: Paper and Paperboard Making Process 35
Exhibit 15: Fourdrinier Paper Machine 36
Exhibit 16: Estimated Energy Sources for the U.S. Pulp and Paper Industry, 1972, 1979,
1990 by percentages 37
Exhibit 17: Common Water Pollutants From Pulp and Paper Processes 39
Exhibit 18: Common Air Pollutants From Pulp and Paper Processes 40
Exhibit 19: Kraft Chemical Pulped-Chlorine Bleached Paper Production 43
Exhibit 20: Kraft Process Flow Diagram 46
Exhibit 21: Air Pollutant Output from Kraft Process 47
Exhibit 22: Source Reduction and Recycling Activity for Pulp and Paper Industry
(SIC 26) as Reported within TRI 49
Exhibit 23: Releases for Pulp and Paper Facilities in TRI for 1993 56
Exhibit 24: Transfers for Pulp and Paper Facilities in TRI in 1993 57
Exhibit 25: Top 10 TRI Releasing Pulp and Paper Facilities, 1993 58
Exhibit 26: Top 10 TRI Releasing Facilities Reporting Pulp and Paper Industry
SIC Codes to TRI, 1993 59
Exhibit 27: Pollutant Releases (short tons/year) 64
Exhibit 28: Summary of 1993 TRI Data: Releases and Transfers by Industry 66
Exhibit 29: Toxics Release Inventory Data for Selected Industries 67
Exhibit 30: Scope of Proposed Integrated Air and Water Rules for Pulp and Paper 93
Exhibit 31: Five-Year Enforcement and Compliance Summary for Pulp and Paper Industry . 102
Exhibit 32: Five-Year Enforcement and Compliance Summary for Selected Industries 104
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Exhibit 33: One-Year Inspection and Enforcement Summary for Selected Industries 105
Exhibit 34: Five-Year Inspection and Enforcement Summary by Statute
for Selected Industries 106
Exhibit 35: One-Year Inspection and Enforcement Summary by Statute
for Selected Industries 107
Exhibit 36: FY-1993-1994 Supplemental Environmental Projects Overview Ill
Exhibit 37:33/50 Program Participants Reporting SIC 261 through 265 114
Exhibit 38: Contacts for State and Local Initiatives 118
September 1995
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Pulp and Paper Industry
List of Acronyms
AF&PA - American Forest & Paper Association
AFS - AIRS Facility Subsystem (CAA database)
AIRS - Aerometric Information Retrieval System (CAA database)
BIFs - Boilers and Industrial Furnaces (RCRA)
BOD - Biochemical Oxygen Demand
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 :
CO - Carbon Monoxide
COD - Chemical Oxygen Demand
CSI - Common Sense Initiative
CWA - Clean Water Act
D&B - Dun and Bradstreet Marketing Index
ELP - Environmental Leadership Program
EPA - United States Environmental Protection Agency
EPCRA- Emergency Planning and Community Right-to-Know Act
FIFRA - Federal Insecticide, Fungicide, and Rodenticide Act
FINDS - Facility Indexing System
HAPs - Hazardous Air Pollutants (CAA)
HSDB - Hazardous Substances Data Bank
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 '•
NAAQS - National Ambient Air Quality Standards (CAA)
NAFTA - North American Free Trade Agreement
NCDB - National Compliance Database (for TSCA, FIFRA, EPCRA)
NCP - National Oil and Hazardous Substances Pollution Contingency Plan
NEIC - National Enforcement Investigation Center
NESHAP - National Emission Standards for Hazardous Air Pollutants
NO2 - Nitrogen Dioxide
NOV - Notice of Violation
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Pulp and Paper Industry
NOX - Nitrogen Oxides
NPDES - National Pollution Discharge Elimination System (CWA)
NPL - National Priorities List
NRC - National Response Center
NSPS - New Source Performance Standards (CAA)
OAR - Office of Air and Radiation
OECA - Office of Enforcement and Compliance Assurance
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)
POTW - Publicly Owned Treatments Works
RCRA - Resource Conservation and Recovery Act
RCRIS - RCRA Information System
SARA - Superfund Amendments and Reauthorization Act
SDWA - Safe Drinking Water Act
SEPs - Supplementary Environmental Projects
SERCs - State Emergency Response Commissions
SIC - Standard Industrial Classification
SO2 - Sulfur Dioxide
SOX - Sulfur Oxides
TOC - Total Organic Carbon
TRI - Toxic Release Inventory
TRIS - Toxic Release Inventory System
TCRIS - Toxic Chemical Release Inventory System
TSCA - Toxic Substances Control Act
TSS - Total Suspended Solids
UIC - Underground Injection Control (SDWA)
UST - Underground Storage Tanks (RCRA)
VOCs - Volatile Organic Compounds
September 1995
VI
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Sector Notebook Project
Pulp and Paper Industry
I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT
I.A. 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 inter-relationships 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. The desire to move
forward with this "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 to
provide its staff and managers with summary information for eighteen
specific industrial sectors. As other EPA offices, states, the regulated
community, and the public became interested in this project, the Office of
Compliance expanded the scope of the original project. The ability to design
comprehensive, common sense environmental protection measures for
specific industries is dependent on knowledge of several inter-related 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 described 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 desired. 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
citations and references listed at the end of this profile. As a check on the
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information 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
The Office of Compliance plans to periodically review and update 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, 401 M St., SW
(2223-A), Washington, DC 20460. Comments can also be uploaded to the
Enviro$en$e Bulletin Board or the Enviro$en$e World Wide Web for general
access to all users of the system. Follow instructions in Appendix A for
accessing these data systems. Once you have logged in, procedures for
uploading text are available from the on-line Enviro$en$e Help System.
Adapting Notebooks to Particular Needs
The scope of the existing notebooks reflect an approximation of the relative
national occurrence of facility types that occur within each sector. In many
instances, industries within specific geographic regions or states may have
unique characteristics that are not fully captured in these profiles. For this
reason, 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. Please contact the appropriate specialist
listed on the opening page of this notebook if your office is interested in
assisting us hi the further development of the information or policies
addressed within this volume.
If you are interested in assisting in the development of new notebooks for
sectors not covered in the original eighteen, please contact the Office of
Compliance at 202-564-2395.
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Sector Notebook Project
Pulp and Paper Industry
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. The type of facilities described within the document
are also described in terms of their Standard Industrial Classification (SIC)
codes. Additionally, this section contains a list of the largest companies in
terms of sales. ,
II.A. Introduction, Background, and Scope of the Notebook
This notebook focuses primarily on the greatest areas of environmental
concerns within the pulp and paper industry: those from pulpmaking
processes. Due to this focus, some components of the pulp and paper
industry, as defined by SIC code 26, are not addressed in this notebook.
Converting facilities are not discussed, and the papermaking stage of the pulp
and paper process is de-emphasized. Data has been drawn from industry and
census sources in the preparation of this document.
According to a 1990 USEPA survey of pulp and paper mills and industry
statistics, there are approximately 555 facilities manufacturing pulp and
paper in the U.S. Of these facilities, about half are integrated facilities
manufacturing both pulp and paper products, half manufacture only paper
products and approximately 50 mills produce only pulp.3'1 In 1991, pulp and
paper mills employed approximately 198,000 people and produced $54
billion in shipments. Shipments from, facilities producing converted products
were approximately $75 billion.2 In comparison, the industry total value of
shipments (pulp and paper mills and converting facilities) accounted for
about 4 percent of the value of shipments for the entire U.S. manufacturing
sector and was similar to that of the petroleum refining sector. Pulp and
paper mills tend to be large and capital intensive. Almost three quarters of
U.S. mills employ over 100 people. Converting facilities tend to be smaller,
more numerous and more labor intensive. The geographic distribution of
mills producing pulp and paper and those producing only paper products
varies. Pulp and paper mills tend to be located where pulp trees are
harvested: Southeast, Northwest, Northeast, and North Central regions.
Paper and paper board mills are more widely distributed in the proximity of
pulping operations and near converting sector markets.3 Deinked pulp mills
are often located near recovered paper sources in urban areas.
a Variation in facility counts occur across data sources due to many factors, including reporting and
definitional differences. This notebook does not attempt to reconcile these differences, but rather reports the
data as they are maintained by each source.
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One important characteristic of the pulp and paper industry is the
interconnection of operations between pulp mills, of which there are fewer
than 60 hi the U.S., and downstream processing of pulp into paper,
paperboard and building paper. Another important characteristic of the pulp
and paper industry are the varied processes, chemical inputs, and outputs that
are used in pulp manufacture. Chemical recovery systems reuse many
process chemicals for some of these pulpmaking systems. On the whole,
however, pulp mill processes are chemical intensive and have been the focus
of past and ongoing rulemaking. In many analyses of the sector, they should
be considered separately. The Bureau of the Census1 two-digit SIC 26 also
includes a number of SIC codes related to converting, i.e., manufacturing
finished paper and paperboard products from paper and paperboard stock, not
milling. These converting operations fall under the three-digit SIC 265 -
Paperboard Containers and Boxes and SIC 267 - Miscellaneous Converted
Paper Products. Some companies are involved in both the manufacture of
primary products and converting, especially in the production of sanitary
tissue products, corrugated shipping containers, folding cartons, flexible
packaging, and envelopes. (These types of integrated facilities are among the
largest converters.) The following list includes pulp and paper mills
(italicized) as well as converted paper products included within SIC 26.
SIC 2611-Pulp mills
SIC 2621-Paper mills
SIC 2631 - Paperboard mills
SIC 2652 - Setup paperboard boxes
SIC 2653 - Corrugated and solid fiber boxes
SIC 2655 - Fiber cans, drums, and similar products
SIC 2656 - Sanitary food containers
SIC 2657 - Folding paperboard boxes
SIC 2661 - Building paper and building board mills
SIC 2671 - Paper coated and laminated, packaging
SIC 2672 - Paper coated and laminated, nee
SIC 2673 - Bags: plastics, laminated, and coated
SIC 2674 - Bags: uncoated paper and multiwall
SIC 2675 - Die-cut paper and board
SIC 2676 - Sanitary paper napkins
SIC 2677 - Envelopes
SIC 2678 - Stationery products
SIC 2679 - Converted paper products, nee
II.B. Characterization of the Pulp and Paper Industry
The pulp and paper industry produces commodity grades of wood pulp,
primary paper products, and paper board products such as: printing and
writing papers, sanitary tissue, industrial-type papers, container board and
boxboard. Pulp facilities are comprised of mills that only produce pulp
which is sold on the open market or is shipped via pipe, conveyor, truck,
train, or ship to another facility where it is utilized for the production of a
final product. Pulp and paper facilities are comprised of mills that produce
both pulp and primary paper products, and mills that produce only paper
products from pulp produced elsewhere. SIC code 26 also includes facilities
that "convert" primary paper and paper board products to finished paper
products such as: packaging, envelopes and shipping containers. In the
following analysis of the pulp and paper industry, converting facilities are
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treated separately from pulp and paper mills due to major differences in the
industrial processes, environmental releases, facility size and number, and
relevant environmental regulations.
The processes used to manufacture pulp (which is later converted into paper)
are the major sources of environmental concerns for this industry.
Pulpmaking processes are the sources of air and water pollutant outputs.
Although a variety of processes are used nationally, the vast majority of pulp
tonnage produced in the U.S. is manufactured by the kraft chemical pulping
process, which may release nuisance odors and particulates to the air.
Bleaching processes, primarily used to whiten and brighten pulps for paper
manufacture, may produce wastewaters containing chlorinated compounds
such as dioxins. Overall, the pulp and paper making process is water-
intensive: the pulp and paper industry is the largest industrial process water
user in the U.S.4 In 1988, a typical pulp and paper mill used 16,000 to
17,000 gallons of water per ton of pulp produced. This roughly translates
into an industry total discharge amount of 16 million m3/day of water.5 Pulp
and paper mills usually operate wastewater treatment plants to remove
biological oxygen demand (BOD), total suspended solids (TSS), and other
pollutants before discharging wastewaters to a receiving waterway. Mills
with indirect discharge may operate primary treatment systems designed for
TSS reduction prior to discharge to a POTW.
Generally speaking, the pulp and paper industry divides itself along pulping
process lines: chemical pulping (e.g., kraft chemical pulping), mechanical
pulping, and semi-chemical pulping. On a tonnage basis, chemical pulping
methods produced approximately 85 percent of the pulp manufactured
domestically in 1991, mechanical pulp 10 percent and semi-chemical five
percent.6
II.B.l. Industry Size and Geographic Distribution
The approximately 555 manufacturing pulp and paper mills in the U.S. can
be divided into three major categories, m the pulp and paper industry, some
mills produce pulp only (market pulp facilities), some only manufacture
paper from pulp (non-integrated facilities), and some produce the pulp they
use for paper manufacture on-site (integrated facilities). Of the estimated
555 pulp and paper facilities in the U.S.,: 55 are market pulp facilities, 300 are
non-integrated facilities, and 200 are integrated facilities.7
The Bureau of the Census tracks the pulp and paper industry at the two-digit
Standard Industrial Classification (SIC) code level using SIC 26 which
encompasses paper and allied products. Environmental regulations
frequently distinguish primary product mills (2611, 2621, 2631, 2661) from
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converting operations. The pulp and paper industry is a capital intensive
sector with large facilities. With increases in automation and industry
restructuring, the ratio of employees to value of shipments has declined since
1972 as have the number of facilities in operation (23 percent reduction since
1972). Almost three-quarters of U.S. mills in the 1992 Census of
Manufactures employ 100 people or more. Converting facilities, those that
use the primary pulp, paper and paperboard products, tend to be smaller,
more numerous and more labor-intensive.
Exhibit 1: Large Facilities Dominate Industry
(SICs 2611, 2621, 2631)
Employees per Facility
1-19
20-99
100-499
500-999
1,000-2,499
Percentage of Facilities (total=529)
2%
28%
44%
17%
9%
Source: U.S. Census of Manufactures, 1992
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 pulp trees are harvested
from natural stands or tree farms: the Southeast, Northwest, Northeast and
Northern Central regions. Paper mills, however, are more widely distributed,
located in proximity to pulping operations and/or near converting sector
markets. The distribution of paperboard mills follows the location of
manufacturing in general since such operations are the primary market for
paperboards products.
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Exhibit 2: Geographic Distribution of Mills
Differs According to Type of Mill
Mill Type
Pulp Mills
Paper Mills
Paperboard Mills
Top States, descending
(% of U.S. Total, by type)
WA, GA, WI, AL, CA, NC, TN,
AK, FL, ME, MS
(94%)
WI, NY, MA, MI
(42%)
CA, OH, PA, MI, GA, NY
(45%)
Secondary States
(% of U.S. Total, by type)
MI,KY
(6%)
PA, OH, ME, WA, NH, CA, MN, LA
(39%)
NJ, VA, AL, IN, IL, TN, CT, FL, LA,
OR,TX
(40%)
Note: States with three to five percent of the U.S. total of that mill type are listed as Secondary States.
Those with six percent or more of the U.S. total are listed as Top States. Those with two percent
or less are not listed.
Source: U.S. EPA, Development Documents for Proposed Effluent Limitations Guidelines and
Standards for the Pulp, Paper and Paperboard Point Source Category. October 1993.
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Exhibit 3: Pulp, Paper, and Paperboard Mills
200 400
(Source: U.S. EPA, Toxics Release Inventory Database, 1993.)
Ward's Business Directory of U.S. Private and Public Companies,
produced by Gale Research Inc., compiles financial data on U.S.
companies including those operating within the pulp and paper industry.
Ward's ranks U.S. companies, whether they are a parent company,
subsidiary or division, by sales volume within the four-digit SIC codes that
they have been assigned as their primary activity. Readers should note
that: 1) Companies are assigned a four-digit SIC that most closely
resembles their principal industry; and 2) Sales figures include total
company sales, including sales derived from subsidiaries and operations not
related to pulp and paper production. Additional sources of company-
specific financial information include Standard & Poor's Stock Report
Services, Dun & Bradstreet's Million Dollar Directory, Moody's Manuals,
Lockwood-Post's Directory, and annual reports.
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Exhibit 4: Top U.S. Companies with Pulp and Paper
Manufacturing Operations
Ranka
1
2
3
4
5
6
7
8
9
10
Company15
International Paper Co.
Weyerhaeuser Co.
Kimberly-Clark Corp.
Georgia-Pacific Corp. Pulp and Paper Group
Stone Container Corp.
Champion International Corp.
Mead Corp.
Boise Cascade Corp.
Union Camp Corp.
Jefferson Smurfit Corp.
1993 Sales
(millions of dollars)
12,703
8,702
6,777
6,702
5,384
4,786
4,579
3,951
2,967
2,940
Note: a When Ward's Business Directory listed both a parent and subsidiary in the
top ten, only the parent company is presented above to avoid double
counting sales volumes. Not all sales can be attributed to the companies'
pulp and paper operations.
b Companies shown listed SIC 261 1, 2621, or 263 1 as primary activity.
Source: Ward's Business Directory of U.S. Private and Public Companies, 1993.
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II.B.2. 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. Paper and Allied Products are categorized by
the Bureau of the Census as Standard Industrial Classification (SIC) code 26.
The industry's output is "converted" to finished products such as packaging,
envelopes and shipping containers by independent manufacturing facilities
or at facilities located adjacent to a mill. Converting operations are included
in SIC 26 but are not included in the following profiles of the pulp and paper
industry unless noted.
The products of the pulp and paper industry can also be categorized by the
pulping process used in paper and paperboard production. The pulping
process affects the strength, appearance, and intended use characteristics of
the resultant paper product. Pulping processes are the major source of
environmental impacts in the pulp and paper industry; each pulping process
has its own set of process inputs, outputs, and resultant environmental
concerns. Papermaking activities have not been associated with significant
environmental problems and are not addressed by EPA's ongoing regulatory
and nonregulatory initiatives. Industry representatives and EPA, in the
Proposed Effluent Limitations Guidelines and Standards for the Pulp, Paper
and Paperboard Point Source Category, have used pulpmaking techniques to
categorize the majority of the industry (Exhibit 5). Since many mills operate
a variety of pulping processes, the percentages hi Exhibit 5 are not additive.
In addition, the data indicates process prevalence at mills but does not
represent the proportion of pulp manufactured by each processes. For
example, many mills practice some form of deink secondary fiber pulping as
shown in Exhibit 5, but the great majority of U.S. pulp is produced by the
kraft chemical pulping process. (The pulp and papermaking processes
contained in Exhibit 5 are explained in Section III: Industrial Process
Description.)
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Exhibit 5: Number of Mills in U.S. by Pulping Process
Pulp Process
Dissolving Kraft
Bleached Papergrade Kraft and
Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-chemical
Mechanical pulp
% of Mills*
1
24
10
1
3
6
<12
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. |
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 mechanical
(sometimes) forces with or
without bleaching used for
corrugating medium (for
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.
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Exhibit 5: Number of Mills in U.S. by Pulping Process
Pulp Process
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
% of Mills*
2
8
61
44
Description/Principal Products
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.
Pulps from wastepapers 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
wastepapers or paperboard
without deinking processes to
produce tissue, paperboard,
molded products and
construction papers.
Paper production from
purchased market pulp or
secondary fibers to make clay
coated printing, uncoated free
sheet, cotton fiber writing, and
lightweight electrical papers.
Paper production from
purchased market pulp to make
paperboard, tissue papers, filter
papers, non-woven items, and
any products other than fine and
lightweight papers.
* Percents are not additive because many mills operate multiple fiber lines and processes.
Source: USEPA. Development Document for Proposed Effluent Limitations Guidelines and Standards for
the Pulp, Paper, and Paperboard Point Source Category. October 1993.
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II.B.3. Economic Trends
The pulp and paper industry is a capital intensive sector with large facilities
in terms of number of employees and chemical use. With increases in
automation and industry restructuring, the ratio of employees to value of
shipments has declined since 1972 as have the number of facilities in
operation (23 percent reduction since 1972). Almost three-quarters of U.S.
mills in the 1992 Census of Manufactures employ 100 people or more.
Converting facilities, those that use the primary pulp, paper and paperboard
products tend to be smaller, more numerous and more labor-intensive.
The Bureau of the Census estimates that in 1992, 198,000 people were
employed hi pulp and paper mills with a payroll of $8.25 billion. The value
of shipments generated by the pulp and paper sector totaled approximately
$54 billion. Industry growth is expected to average two percent per year
through 1998 due in large part to expected increases in exports.
The U.S. pulp and paper industry is recognized as a high-quality, high-
volume, low-cost producer that benefits from a large consumer base, a
modern technical infrastructure, adequate raw materials and a highly skilled
labor force. Profitability within the industry is a function both of raw
material prices and labor conditions as well as worldwide inventories and
demand. Reduced profitability since 1991 due to decreased demand, high
inventories, and higher prices of wood products led to rebuilding and
modifications of existing equipment rather than installation of new machines.
In 1993, domestic mills operated at between 92 and 95 percent of capacity.8
Within the manufacture of primary products, paper mills (SIC 2621) account
for 60 percent of the total value of shipments. The remaining shipments are
attributable to paperboard mills which account for 30 percent of total value
of shipments and pulp mills at 10 percent. The majority of converting
operations are operate independently of a primary product mill (e.g. a paper
stock mill). However, those mills that are integrated with primary product
mills account for the majority of the value of shipments.
The 1992 Census of Manufactures reports a payroll of $8.25 billion for
198,000 employees hi the primary products sectors, three-quarters of whom
are production workers. Labor relations are critical to the success of U.S.
pulp and paper operations. Employment is down slightly, caused by mergers,
consolidations and phasing out of older, less-efficient operations, a trend
which is expected to continue. Nonetheless, labor contracts are being signed
for longer periods and strikes are less frequent (one in 1993 versus 19 in
1983).
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Industry growth is driven by the performance of other manufacturing sectors
that use paper products in packaging and by demand for printing and writing
papers. Competitive pressures come from plastic packaging in the domestic
market. As foreign paper companies in developing countries improve their
product quality they are likely to become more competitive in the U.S. and
international markets. Current principal world market competition comes
from Canada and Scandinavia.
Exports of pulp and paper products are increasingly important to the
economic health of the industry, hi 1992, exports amounted to $10.1 billion
(seven percent of the total value of shipments of paper and allied products).
The major export markets for U.S. printed material are Canada, Mexico, and
Japan. Efforts by the U.S. paper industry to meet new European Community
guidelines and product standards should strengthen its competitive position
in European markets. During the same period, the U.S. imported $10.4
billion worth of pulp and paper products, principally from Canada. Even
with the recent weakness in Canada's economy, exports (particularly of
converted paper and paperboard packaging) are likely to grow due to the
U.S.-Canada Free Trade Agreement. A large number of U.S. paper and
paperboard companies that have not yet entered overseas markets will likely
do so if tariff and nontariff barriers are removed or reduced. Exports of
recovered paper, which are not included in the figures above, totaled $560
million in 1993; imports totaled $26 million.
Domestic demand for packaging and industrial-type paper grades and
strengthening export markets drive estimates for real growth of three percent
in shipments of paper and allied products in 1994. The successful conclusion
of the North American Free Trade Agreement (NAFTA) and the Uruguay
Round of the General Agreement on Tariffs and Trade (GATT) is also
increasing exports for the industry particularly to the European Community
and emerging economies in Pacific Rim countries. Industry growth is
expected to average two percent per year through 1998 due in large part to
expected increases in exports.
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III. 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, provide 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
celluose fibers to a screen which allows the water to drain and leaves the
fibrous particles behind in a sheet. Most modern 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 watery fibrous substrate 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. Generally speaking, 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. Currently one-fifth of all pulp and paper mills practice
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bleaching.9 At the paper-making stage, the pulp can be combined with dyes,
strength building resins, or texture adding filler materials, depending on its
intended end product. Afterwards, the mixture is dewatered, leaving the
fibrous 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 Exhibit 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, the 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.
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Exhibit 6: Simplified Flow Diagram: Integrated Mill
(Chemical Pulping, Bleaching, and Paper Production)
COOKING
WOODYARD AND CHIPPING
FINISHING DEPARTMENT
(Source: Smook, GA Handbook for Pulp & Paper Technologists. Second Edition. Vancouver: Angus Wilde
Publications, 1992.)
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III.A.I. Pulp Manufacture
At the pulping stage, the processed furnish 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. Exhibit 7 presents an overview of the wood pulping types
by the method of fiber separation, resultant fiber quality, and percent of 1990
U.S. pulp production. Many mills perform multiple pulping processes at the
same site, most frequently non-deink secondary fiber pulping (61 percent of
mills) and papergrade kraft pulping (24 percent of mills).10 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.
Exhibit 7: 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
1993 US
Wood Pulp
Production*
10%
6%
84%
*American Forest and Paper Association, 1994 Statistics, Data Through 1993. Washington, D.C.:AF&PA, 1994.
Source: Smook, G.A. Handbookfor Pulp & Paper Technologists. Second edition. Vancouver: Angus Wilde
Publications, 1992.
A variety of technologies and chemicals are used to manufacture pulp, but
most pulp manufacturing systems contain the following process sequence:
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Exhibit 8: Pulp Manufacturing Process Sequence
Process Sequence
Fiber Furnish Preparation
and Handling
Pulping
Pulp Processing
Bleaching
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
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
1990 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 furnish 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. The principle source of paper-making fibers in the
United States is wood from trees, the largest vascular plants available. The
fibrous particles used to make paper are made of cellulose, a primary
component of the cell walls of vascular plant tissues. The cellulose fibers
must be removed from a chemical matrix (e.g., lignin, hemicelluloses, and
resins) and result in a mixture of relatively pure fibers.
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Wood used to make pulp can be in a variety of forms and types. Wood logs,
chips, and sawdust are used to make pulp. Due to different physical and
chemical properties, however, certain pulping processes are most efficient on
specific wood types (see Pulping). The type of wood used can also make a
difference in the final characteristics of the pulp, hi general, softwood fibers
are longer than those from hardwood 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 Exhibit 9). Although
secondary fibers are not used in as great a proportion as wood furnish,
approximately 70 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.11 Office of Water estimates place the
number of mills relying completely on secondary fibers as a furnish source
at 285, approximately 50 percent of all mills.12 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 brighten the pulp.
Secondary fiber use is increasing in the pulp and paper industry due to
consumer demand for products made from recycled paper and a lack of
adequate virgin fiber (see Bleaching). Within the secondary fiber category,
consumption of fiber from recovered paper is growing more than twice as
fast as overall fiber consumption.13 The utilization of secondary fibers,
expressed as a percentage of the total fibers used to make pulp, is at
approximately 30 percent and is climbing slowly.14 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. 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.15
In 1992, corrugated containers comprised about 50 percent of the secondary
fiber used in paper and paperboard production. Secondary fiber sources are
seldom used as feedstocks for high quality or grade paper products.
Contaminants (e.g., inks, paper colors) are often present, so production of
low-purity products is often cost-effective use of secondary fibers, although
decontamination technologies are available. Approximately 75 percent of all
secondary fiber in North America is presently used for multi-ply paperboard
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or the corrugating paper used to manufacture corrugated cardboard. Over the
next decade, an increasing proportion of the total amount will be deinked for
newsprint or other higher-quality uses.
Exhibit 9: Relative Wastepaper Usage as Secondary Fiber in 1992
Paper Type
Mixed Paper
Old Newspaper
Old Corrugated Cardboard
Pulp Substitutes
High-grade Deinked
% of Total Wastepaper Usage in
1992
13%
17%
49%
11%
10%
Source: American Forest and Paper Association, 1994 Statistics, Data Through 1993. Washington, D.C.:AF&PA, 1994.
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 contaminantion of pulping operations.
Depending on the moisture content of the bark, it may then be burned for
energy production. Hydraulic debarking methods may require a drying step
before burning. Usually, hydraulically removed bark is collected in a water
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flume, dewatered, and pressed before burning. Treatment of wastewater
from this process is difficult and costly, however, whereas dry debarking
methods can channel the removed bark directly into a furnace.16 If not
burned for energy production, bark can be used for mulch, ground cover, or
as an ingredient in charcoal.
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 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 80 percent of
all US pulp tonnage during 1993 according to the American Forest and Paper
Association (AF&PA) and other industry sources. According to EPA
industry surveys, approximately 30 percent of all pulp and paper mills use the
kraft process for some portion of pulp manufacture.17 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 is high in the kraft process, up to 90 percent- allowing high
levels of bleaching without pulp degradation due to delignification (see Pulp
Bleaching). Finally, the chemicals used in kraft pulping are readily
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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 (Na^) and sodium hydroxide (NaOH) in 10
percent solution. This liquor (white liquor) is mixed with the wood chips in
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 unreapted 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 4 percent of U.S. pulp
production in 1993 (AF&PA). 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
(H2SO3) 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 6 percent of U.S. pulp production in 1993
(AF&PA). Semi-chemical pulp is often very stiff, making this process
common in corrugated container manufacture. This process primarily uses
hardwood as furnish. :
The semi-chemical process involves partial digestion of furnish in a weak
chemical solution followed by mechanical refining for fiber separation. At
most, the digestion step in the semi-chemical pulping process consists of
heating pulp in sodium sulfite (Na2SO3) and sodium carbonate (Nfi CO )
Other semi-chemical processes include the Permachem process and the two-
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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.
Mechanical pulping
Mechanical pulping accounted for 10 percent of U.S. pulp production in 1993
(AF&PA). Mechanically produced pulp is of low strength and quality. Such
pulps are used principally for newsprint and other non-permanent paper
goods. Mechanical pulping uses physical pressure instead of chemicals to
separate furnish fibers. Processes include: 1) stone groundwood, 2) refiner
mechanical, 3) thermo-mechanical, 4) chemi-mechanical, and 5) chemi-
thermo-mechanical. Pulp yields are high, up to 95 percent when compared
to chemical pulping yields of 45- 50 percent, but energy usage is also high.
To offset its weakness, mechanical pulp is often blended with chemical pulp.
Secondary fiber pulping
Secondary fiber pulping accounted for approximately 30 percent of domestic
pulp production in 1992 (AF&PA). More than 200 mills rely exclusively on
recovered paper for pulp furnish.18 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. According to the USEPA 1990 National
Census of Pulp, Paper, and Paperboard Manufacturing Facilities,
approximately 70 percent of all pulp and paper mills process secondary fiber
at their facilities in some way. 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).19
Inks, another contaminant of secondary fibers, may be removed by heating
a mixture of secondary fibers with surfactants. The removed inks are then
dispersed hi 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. Only 8 percent of U.S. mills
engaged in deinking of secondary fibers as of 1993. Deinking capacity is
rapidly increasing, however. There are currently 83 recovered paper
deinking facilities in operation in the U.S. with another 44 planned for
construction or start-up between 1995 and 1997.20
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Secondary fiber pulping is a relatively simple process. The most common
pulper design consists of a large container filled with water, which is
sometimes heated, and the recycled pulp. Pulping chemicals (e.g., sodium
hydroxide, NaOH) are often added to promote dissolution of the paper or
board matrix. The source fiber (corrugated containers, mill waste, etc.) is
dropped into the pulper and mixed by a rotor. Debris and impurities are
removed by two mechanisms: a ragger and a junker. The ragger withdraws
strings, wires, and rags from the stock secondary fiber mixture. A typical
ragger consists of a few "primer wires" that are rotated in the secondary fiber
slurry. Debris accumulates on the primer wires, eventually forming a "debris
rope" which is then removed. Heavier debris are separated from the mixture
by centrifugal force and fall into a pocket on the side of the pulper. The
junker consists of a grappling hook or elevator bucket. Heat, dissolution of
chemical bonds, shear forces created by stirring and mixing, and grinding by
mechanical equipment may serve to dissociate fibers and produce a pulp of
desired consistency in various pulping machinery.
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. Overall, the quality of secondary fiber strongly affects the quality
of the paper products. As noted in Furnish Composition., above,
approximately 75 percent of all secondary fiber in North America is presently
used for multi-ply paperboard or the corrugating paper used to manufacture
corrugated cardboard. Over the next decade, an increasing proportion of the
total amount will be deinked for newsprint or other higher-quality uses.
IILA.2. Pulp Processing
After pulp production, pulp processing removes impurities, such as uncooked
chips, and recycles any residual cooking liquor via the washing process
(Exhibit 10). 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 insure 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
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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
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 hi other pulping operations and ultimately enters the mill's chemical
recovery system. Centrifugal cleaning (also known as liquid cyclone,
hydrocyclone, or centricleaning) 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.21
Environmental benefits include the recycle of process chemicals and lack of
resultant discharges to the environment.
Both kraft and sulfite chemical pulping processes use chemical recovery
systems, although 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
The kraft chemical recovery process has not been fundamentally changed
since its patent issue in 1884, but has been refined into a stepwise
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progression of chemical reactions. New technologies are under development,
however, as two black liquor gasification processes (Chemtrec and MTCI)
were brought to the pilot stage at pulp mill sites in 1991.
The precise details of the chemical processes at work in the chemical
recovery process can be found in Smqok, 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:
Black liquor concentration
Residual weak black liquor from the pulping process is concentrated by
evaporation to form "strong black liquor." After brown stock washing (See
Pulp Processing) 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, however, so oxidation processes are not
usually seen in newer mills. Common modern 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 H.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 56 percent of the energy requirements of pulp
and paper companies.22 (See III.A3. Energy Generation for more
information). :
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Recausticizating
Smelt is recausticized to remove impurities left over from the furnace and to
convert sodium carbonate (TN^COj) into active sodium hydroxide (NaOH)
and sodium sulfide (Na^). 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 (Na^). The
remaining white liquor is then used in the pulp cooking process. The lime
mud is treated to regenerate lime in the calcining process.
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 now use newer
fluidized bed systems.
Sulfite 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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Exhibit 10: The Kraft Pulping Process (with chemical recovery)
CHIPS
Water
\
Blow Tank
,1
Washers
I
Weak Black
Liquor Storage
1
Evaporators
>.
•
v
•^
WHITE
STORAGE
^PULP
fin nf a m i n a tpr
Condensate
Grits
iT~
WHITE
LIQUOR
CLARIFIER
t
CAUSTICIZERS
t
Slaker
t
Green
Liquor
Storage
t
Green
Liquor
Clarifier
1
Weak Liquor
Storage
Water
t
Dregs
(Source: Smook, G.A. Handbook/or Pulp & Paper Technologists. Second Edition. Vancouver: Angus Wilde
Publications, 1992.)
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III.A.3. Bleaching
Bleaching is defined as any process that chemically alters pulp to increase its
brightness. Bleached pulps create papers that are whiter, brighter, softer, and
more absorbent than unbleached pulps. Bleached pulps are used for products
where high purity is required and yellowing (or color reversion) is not
desired (e.g. printing and wrapping papers, food contact papers). Unbleached
pulp is typically used to produce boxboard, linerboard, and grocery bags. Of
the approximately 72 million tons of pulp (including recycled pulp) used in
paper production in the United States in 1993, approximately 50 percent
percent was bleached in some fashion.23
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 fully and require heavy chemical
inputs. Excessive bleaching of mechanical and semi-chemical pulps results
hi 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, 1990 from the Office of Water
Regulations and Standards is recommended. Typical bleaching processes for
each pulp type are detailed below.
Chemical pulps are bleached in traditional bleach plants (see Exhibit 11)
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 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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Exhibit 11: Typical Bleach Plant
UNBLEACHED
PULP
HOT WATER
BLEACHED
PULP
(Source: U.S. EPA, Development Document for Proposed Effluent Limitations Guidelines and Standards for the Pulp,
Paper, and Paperboard Point Source Category. October 1993.)
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The most common chemicals used in the bleaching process are sodium
hydroxide, elemental chlorine, and chlorine dioxide. The use of chlorine
dioxide in the bleach process has steadily increased relative to molecular
chlorine usage due to its reduction in the formation of chlorinated organics
in bleach plant effluent and lower bleach plant chemical consumption.
Common bleaching chemicals are presented below along with the
approximate percentage of mills using them, their chemical formulae, and
bleach chemical code letter:
Exhibit 12: Common Chemicals Used in Bleaching Process
Bleaching Chemical
Sodium Hydroxide
Elemental Chlorine
Chlorine Dioxide
Hypochlorite
Oxygen
Hydrogen Peroxide
Sulfur Dioxide
Sulfuric Acid
Approximate
% of Mills8
100%
99%
89%
69%
64%
43%
10%
9%
Chemical Formula
NaOH
C12
C1O2
HC1O, NaOCl,
Ca(OCl)2
02
H202
SO2
H2SO4
Code
Letter
E
C
D
H
0
P
s
A
"Approximate percentage of total number of papergrade kraft, soda, and
dissolving soda mills that bleach chemical wood pulp in traditional bleach
plants; not based on amount of pulp bleached by mills.
Source: USEPA. 1990 National Census of Pulp, Paper, and Paperb oar d Manufacturing
Facilities. 1990.
Bleaching process descriptions commonly refer to chemical reaction stages
by therr chemical code letter. The following table represents the most
common bleaching sequences used in the U.S. and Canada in 1991.
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Exhibit 13: Bleaching Sequences
Sequence
C-E-D-E-D
C-E-H-E-D
C-E-H-D-E-D
C-E-H, C-E-H-P ;
Other (e.g., chlorine dioxide first stage)
Percent of Mills
38%
19%
13%
8%
22%
Source: Multimedia Analysis of Alternative Pulp and Paper Technologies, 1991.
The production of chlorinated pollutants such as dioxin as well as production
of chloroform results from the bleaching of pulps with chlorine and chlorine
derivatives. A variety of bleaching processes have been developed which
may be chlorine free, where bleaching chemicals such as ozone (Z), oxygen
(O), and peroxide (P), replace chlorine and chlorine derivatives. Currently,
at least one U.S. mill uses ozone in its bleaching process and others are
installing or actively considering ozone bleaching. Overall, there has been
a recent major trend in the industry toward reductions in both the types and
amount of chlorine and chlorine-containing chemicals used for pulp
bleaching, such that the data presented in the above table may not fully
represent the distribution of bleaching processes currently in use by the
industry. Some changes include: in 1994 chlorine dioxide usage (in tons)
was, for the first time, greater than elemental chlorine usage in the bleach
process,24 use of hypochlorite has diminished in response to concerns about
chloroform emissions, chlorine injection process modifications have been
made, and significant efforts have been made to improve delignification to
minimize dioxin formation while reducing bleach chemical usage. Some of
these delignification technologies include extended delignification during
kraft pulping, solvent pulping, and pulping in the presence of the catalyst
anthraquinone. Oxygen delignification is also used as a post-pulping method
of increasing delignification. These processes can be more costly, lead to
reduced pulp yield and strength, and be potential sources of other pollutants.
Some positive aspects of these processes may include: lower bleach chemical
costs, lower energy consumption, reduced toxicity, reduced color, and
reduced BOD. Totally chlorine-free (TCP) bleaching of selected market
grades of sulfite and kraft pulps has been demonstrated in Europe, but, as of
October 1993, no commercial production of market grade high brightness
softwood kraft pulps had been demonstrated in the United States. As of
1994, one mill has implemented a TCP process to produce mid to high
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brightness pulps. It should be noted, based on American Forest and Paper
Association data, that 9 out of 10 pulp and paper mills currently in operation
have non-detectable levels of dioxin in effluent.
Semi-chemical pulps are typically bleached with hydrogen peroxide (H2O2)
hi a bleach tower.
Mechanical pulps are bleached with hydrogen peroxide (H2O2) and/or
sodium hydrosulfite (Na^Os). Bleaching chemicals are either applied
without separate equipment during the pulp processing stage (i.e., in-line
bleaching), or hi 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 (HC1O, NaOCl, Ca(OCl)2),
hydrogen peroxide (H2O2)3 and hydrosulphite (Na^OJ.
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 processed little, if at all at this stage. Processing
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
unproved texture, print quality, opacity, and brightness.
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III.A.5. Processes in Paper Manufacture
The paper and paperboard making process consists of the following general steps:
Exhibit 14: 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
Exhibit 15). 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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Exhibit 15: Fourdrinier Paper Machine
Row
Spreader
Dryer Section
Calender
Stack
Reel
(Source: U.S. EPA, Development Document for Proposed Effluent Limitations Guidelines and Standards for the Pulp,
Paper and Paperooard Point Source Category. October 1993.)
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, hi 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.
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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
needed to make up the remainder of mill energy needs. Over the last decade
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 Exhibit 16 below is one example of this industry-wide
movement. During the 1972-1990 period, the proportion of total industry
power generation from the combination of woodroom wastes, spent liquor
solids, and other self-generation methods increased by approximately 15
percent, while fuel oil and natural gas use decreased 20 percent. Increases
in purchased steam and coal use, made up the difference.
Power boilers at pulp and paper mills are sources of particulate emissions,
SO2, and NOX. Pollutants emitted from chemical recovery boilers include
SO2, and total reduced sulfur compounds (TRS).
Exhibit 16: Estimated Energy Sources for the U.S. Pulp and Paper
Industry, 1972, 1979, 1990 by percentages
Energy source
Purchased steam
Coal
Fuel oil
Natural gas
Waste wood and wood
chips (Hogged fuel) and
bark
Spent liquor solids
Self-generated power
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
1990
7.3
13.7
6.4
16.4
15.4
39.4
1.2
Source: American Paper Institute Data as presented in Smook, G.A. Handbook for Pulp & Paper Technologists.
Second edition. Vancouver: Angus Wilde Publications, 1992.
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III.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
processes and power generation facilities may release odors, particulates, 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.25 In 1988, a typical pulp and paper mill used 16,000 to 17,000 gallons
of water per ton of pulp produced.26 General water pollution concerns for
pulp and paper mills are effluent solids, biochemical oxygen demand,
toxicity, and color. Toxicity concerns arise from the presence of chlorinated
organic compounds such as dioxins, furans, and others (collectively referred
to as adsorbable organic halides, or AOX) in wastewaters after the
chlorination/extraction sequence.
Due to the large volumes of water used hi 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 removals (e.g., 30-70 percent) of other important parameters such
as adsorbable organic halides (AOX) and chemical oxygen demand (COD).
The major sources of effluent pollution in a pulp and paper mill are presented
hi Exhibit 17.
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Exhibit 17: Common 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, can contain reduced
sulfur
Large volume of water with suspended solids,
can have significant BOD
BOD, color, chlorinated organic compounds
Solids, often precipitated for reuse
Solids, BOD, color
Source: Smook, G.A. Handbook/or Pulp & Paper Technologists. Second edition. Vancouver: Angus Wilde
Publications, 1992.
Screening and cleaning operations during the pulp processing stage are
usually sources of large volumes of wastewaters. This effluent stream, called
white water due to its characteristic color, can contain significant BOD if
washing efficiency is low and is always a source of suspended solids from
wood particles. Similar white water wastes are also produced during the
papermaking process. White waters can be reused to dilute furnish mixtures
or the solids can be collected for reuse. 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. Separate pump systems recycle
recoverable materials into the process cycle. The condensates from chip
digesters and chemical recovery evaporators are a low-volume, but high
BOD effluent source. Some of these condensates contain reduced sulfur
compounds.
Wastewater treatment systems can be a significant source of cross-media
pollutant transfer. For example, waterborne particulate and some chlorinated
compounds settle or absorb onto treatment sludge and other compounds may
volatilize during the wastewater treatment process.
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Air
The following table is an overview of the major types and sources of air
pollutant releases from various pulp and paper processes:
Exhibit 18: Common Air Pollutants From
Pulp and Paper Processes
Source
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
All combustion processes
Type
Fine particulates
Course particulates
Sulfur oxides
Reduced sulfur gasses
Volatile organic compounds
Nitrogen oxides
Source: Smook, G. A. Handbookfor Pulp & Paper Technologists. Second edition. Vancouver: Angus
Wilde Publications, 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 and chip digesters 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 particulate 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, and chemical recovery boiler processes.
TRS compounds create odor nuisance problems at lower concentrations than
sulfur oxides: odor thresholds for TRS compounds are approximately 1000
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 1 ppb.
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Pulp and Paper Industry
Residual Wastes
Pulp and paper mills have made significant investments in pollution control
technologies and processes. According to industry sources, the pulp and
paper industry spent more than $1 billion per year from 1991-1994 on
environmental capital expenditures. In 1991 and 1992, this represented 20
percent of total capital expenditures.27 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
particulate "baghouses" or electrostatic precipitators (ESPs) are are often
mill air pollution control components.
The significant residual waste streams from pulp and paper mills include
bark, 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
(including dioxins) to partition from effluent to solids, wastewater treatment
sludge has generated the most significant environmental concerns for the
pulp and paper industry. To a lesser extent, concern has also been raised
over whether chlorinated organics are partitioned into pulp products, a large
portion of which become a post-consumer residual waste.
With the exception of bark, 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 sludge per ton pulp.28 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. The 1988 results of the "104-Mill Study"
showed that dioxins and furans were present in bleached pulp mill sludges,
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Pulp and Paper Industry
resulting in calls to regulate both landfill disposal and land application of
such sludges (See Federal Regulations section). Landfill and surface
impoundment disposal are most often used for wastewater treatment sludge;
in 1988 only eleven of 104 bleached kraft mills disposed of any sludge
through land application or conversion to sludge-derived products (e.g.,
compost, animal bedding).
Process Inputs and Pollutant Outputs
Kraft chemical pulping and traditional chlorine-based bleaching are both
commonly used and may generate significant pollutant outputs. Kraft pulping
processes produced approximately 80 percent of total US pulp tonnage
during 1993 according to the American Forest and Paper Association
(AF&PA) and other industry sources. While the use of traditional chlorine
bleaching is hi decline, a significant proportion of kraft mills currently use
the process.
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. Pollutant outputs from chlorine bleaching, the chlorinated
by-products chloroform and dioxin, are particular problems due to their
persistence, non-biodegradability, and toxicity. The following table (Exhibit
19) and Exhibits illustrate the process inputs and pollutant outputs for a pulp
and paper mill using kraft chemical pulping and traditional chlorine-based
bleaching. Currently, extensive chlorine dioxide substitution is practiced in
many bleaching processes in place of traditional chlorine bleaching. The
process outlined below produces a large portion of U.S. pulp.
Exhibit 19 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 Exhibit 19:
• Pollution Prevention Technologies for the Bleached Kraft Segment
of the U.S. Pulp and Paper Industry. August 1993. (EPA-600-R-93-
110)
• Development Document for Proposed Effluent Limitations Guidelines
and standards for the Pulp, Paper, and Paperboard Point Source
Category. October 1993. (EPA-821-R-93-019)
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• 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)
Exhibit 20 is a process flow diagram of the kraft process, illustrating
chemical pulping, power recovery, and chemical recovery process inputs and
outputs. Exhibit 21 is a schematic of characteristic air emission sources from
a kraft mill.
Exhibit 19: Kraft Chemical Pulped-Chlorine Bleached Paper Production
Process Step
Fiber Furnish
Preparation
Chemical
Pulping Kraft
process
Material
Inputs
Wood logs
Chips
Sawdust
Furnish chips
Cooking
chemicals:
sodium sulfide
(NajS), NaOH,
white liquor
(from chemical
recovery)
Process Outputs
Furnish chips
Black liquor (to
chemical recovery
system), pulp (to
bleaching/processing)
Major Pollutant Outputs*
dirt, grit,
fiber, bark
BOD
TSS
resins, fatty acids
color
BOD
COD
AOX
VOCs (terpenes, alcohols, phenols,
methanol, acetone, chloroform, MEK)
VOCs (terpenes, alcohols, phenols,
methanol, acetone, chloroform, MEK)
reduced sulfur compounds (TRS)
organo-chlorine compounds (e.g.,
3,4,5- trichloroguaiacol)
Pollutant
Media
Solid
Water
Solid
Water
Air
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Exhibit 19: Kraft Chemical Pulped-Chlorine Bleached Paper Production
Process Step
Bleaching
Papermaking
Wastewater
Treatment
Facilities
Material
Inputs
Chemical pulp
Elemental
chlorine (Cy,
chlorine
containing
compounds
Hypochlorite
(HClO.NaOCl,
Ca(OCl)2)
Chlorine dioxide
(cicg
Additives,
Bleached/
Unbleached pulp
Process
wastewaters
Process Outputs
Bleached pulp
Paper/paperboard
product
Treated effluent
Major Pollutant Outputs*
dissolved lignin and carbohydrates
color
COD
AOX
inorganic chlorine compounds
(e.g., chlorate (C1O3'))'
organo-chlorine compounds (e.g.,
dioxins, furans, chlorophenols)
VOCs (acetone, methylene chloride,
chloroform, MEK, carbon disulfide,
chloromethane, trichloroethane)
particulate wastes
organic compounds
inorganic dyes
COD
acetone
sludge
VOCs (terpenes, alcohols, phenols,
methanol, acetone, chloroform, MEK)
BOD
TSS
COD
color
chlorophenolics
carbon disulfide
VOCs (terpenes, alcohols, phenols,
methanol, acetone, chloroform, MEK)
Pollutant
Media
Water
Air / Water
Water
Solid
Air
Water
September 1995
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Pulp and Paper Industry
Exhibit 19: Kraft Chemical Pulped-Chlorine Bleached Paper Production
Process Step
Power Boiler
Material
Inputs
Coal,
Wood,
Unused furnish
Process Outputs
Energy
Major Pollutant Outputs*
bottom ash: incombustible fibers
SO2, NOX, fly ash, coarse particulates
Pollutant
Media
Solid
Air
Chemical Recovery System
Evaporators
Recovery
Furnace
Recausticizing
Calcining
(Lime Kiln)
Black liquor
Strong black
liquor
Smelt
Lime mud
Strong black liquor
Smelt
Energy
Regenerated white
liquor
Lime mud
Lime
evaporator noncondensibles (TRS,
volatile organic compounds: alcohols,
terpenes, phenols)
evaporator, condensates (BOD,
suspended solids)
fine particulates, TRS, sulfur dioxide
dregs
waste mud. solids
fine and coarse particulates
Air
Water
Air
Solids
Water
Air
* Pollutant outputs may differ significantly based on mill processes and material inputs (e.g., wood chip resin content).
1 Chlorate only significantly produced in mills with high rates of chlorine dioxide substitution to reduce dioxin and furan
production.
Sources: Pollution Prevention Technologies for the Bleached Kraft Segment of the U.S. Pulp and Paper Industry (EPA-600-
R-93-1 10), Development Document for Proposed Effluent Limitations Guidelines and standards for the Pulp, Paper, and
Paperboard Point Source Category (1993) and air release data from Pulp, Paper and Paperboard Industry - Background
Information for Proposed Air Emission Standards: Manufacturing Processes at Kraft, Sulflte, Soda, and Semi-Chemical Mills
(NESHAP; 1993).
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Pulp and Paper Industry
Exhibit 20: Kraft Process Flow Diagram
Rocovoiy
Boiler
Chtpt Sttun
Washorc Wash Water
Rabumed Lime
(Source: Smook, Gary A. Handbook for Pulp and Paper Technologists. Second edition. Vancouver: Angus Wilde
Publications, 1992.)
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Sector Notebook. Project
Pulp and Paper Industry
Exhibit 21: Air Pollutant Output from Kraft Process
WOOD CHIPS ( "^
i V
D.rF_T BLOWTAh
DIGESTER >. &ACCUMULC
Q
t
L,MEK,LN J ""JSSS
' q
A
•^^ COMBINATION
) BOILER
r
JK WASHERS PULP TO THE PAPER MILL
OOP & SCREENS X
CD
*..--..• V — j**^r
,! t
50ND. WEAK B.L. MULTIPLE EFFECT
=IY OXIDATION EVAPORATORS
cp cp cp cp
SLAKER DISSOLVIN
* TANK
G _ RECOVERY i CONG. B.L. !
< SYSTEM 4 \ OXIDATION j
(Source: Smook, Gary A. Handbook for Pulp and Paper Technologies. Second Edition. Vancouver: Angus Wilde
Publications, 1992.)
September 1995
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Pulp and Paper Industry
III.C. Management of Chemicals in Wastestream
The Pollution Prevention Act of 1990 (PPA) requires facilities to report
information about the management of TRI chemicals in waste and efforts
made to eliminate or reduce those quantities. These data have been collected
annually in Section 8 of the TRI reporting Form R beginning with the 1991
reporting year. The data summarized below cover the years 1992-1995 and
are meant to provide a basic understanding of the quantities of waste handled
by the industry, the methods typically used to manage this waste, and recent
trends hi these methods. TRI waste management data can be used to assess
trends in source reduction within individual industries and facilities, and for
specific TRI chemicals. This information could then be used as a tool in
identifying opportunities for pollution prevention compliance assistance
activities.
From the yearly data presented below it is apparent that the portion of TRI
wastes reported as recycled on-site has increased and the portions treated or
managed through energy recovery on-site have decreased between 1992 and
1995 (projected). While the quantities reported for 1992 and 1993 are
estimates of quantities already managed, the quantities reported for 1994 and
1995 are projections only. The PPA requires these projections to encourage
facilities to consider future waste generation and source reduction of those
quantities as well as movement up the waste management hierarchy. Future-
year estimates are not commitments that facilities reporting under TRI are
required to meet.
Exhibit 22 shows that the pulp and paper industry managed about 2 trillion
pounds of production-related waste (total quantity of TRI chemicals in the
waste from routine production operations) in 1993 (column B). Column C
reveals that of this production-related waste, about 10 percent was either
transferred off-site or released to the environment. Column C is calculated
by dividing the total TRI transfers and releases by the total quantity of
production-related waste. In other words, about 90 percent of the industry's
TRI wastes were managed on-site through recycling, energy recovery, or
treatment as shown in columns E, F and G, respectively. The majority of
waste that is released or transferred off-site can be divided into portions that
are recycled off-site, recovered for energy off-site, or treated off-site as
shown in columns H, I and J, respectively. The remaining portion of the
production related wastes (three percent), shown in column D, is either
released to the environment through direct discharges to air, land, water, and
underground injection, or it is disposed off-site.
September 1995
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Exhibit 22: Source Reduction and Recycling Activity for
Pulp and Paper Industry (SIC 26) as Reported within TRI
A
Year
1992
1993
1994
1995
B
Quantity of
Production-
Related
Waste
(106 lbs.)a
2,080
1,958
1,991
1,949
C
% Released
and
Transferred11
10%
9%
—
—
D
% Released
and
Disposed0
Off-site
10%
9%
8%
. 8%
On-Site
E
%
Recycled
5%
5%
5%
5%
F
% Energy
Recovery
10%
10%
11%
11%
G
: %
Treated
74%
1 74%
73%
73%
Off-Site
H
%
Recycled
.02%
.02%
.02%
.02%
I
% Energy
Recovery
.02%
.03%
.03%
.02%
J
%
Treated
3%
2%
2%
2%
a Within this industry sector, non-production related waste < 1% of production related wastes for 1993.
b Total TRI transfers and releases as reported in Section 5 and 6 of Form R as a percentage of production related
wastes.
c Percentage of production related waste released to the environment and transferred off-site for disposal.
September 1995
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Pulp and Paper Industry
IV. CHEMICAL RELEASE AND TRANSFER PROFILE
This section is designed to provide background information on the pollutant
releases that are reported by this industry. The best source of comparative
pollutant release information is the Toxic Release Inventory System (TRI).
Pursuant to the Emergency Planning and Community Right-to-Know Act
(EPCRA), TRI includes self-reported facility release and transfer data for
over 600 toxic chemicals. Facilities within SIC Codes 20-39 (manufacturing
industries) that have more than 10 employees, and that are above weight-
based reporting thresholds are required to report TRI on-site releases and off-
site transfers. The information presented within the sector notebooks is
derived from the most recently available (1993) TRI reporting year (which
then included 316 chemicals), and focuses primarily on the on-site releases
reported by each sector. Because TRI requires consistent reporting
regardless of sector, it is a useful tool for drawing general comparisons
across industries.
Although this sector notebook does not present historical information
regarding TRI chemical releases, please note that in general, toxic chemical
releases have been declining over time. In fact, according to the 1993 Toxic
Release Inventory Data Book, reported releases dropped by 43 percent
between 1988 and 1993. Although on-site releases have decreased, the total
amount of reported toxic waste has not declined because the amount of toxic
chemicals transferred off-site has increased. Transfers have increased from
3.7 billion pounds in 1991 to 4.7 billion pounds in 1993. Better management
practices have led to increases in off-site transfers of toxic chemicals for
recycling. More detailed information can be obtained from EPA's annual
Toxics Release Inventory Public Data Release book (which is available
through the EPCRA Hotline at 800-535-0202), or directly from the Toxic
Release Inventory System database (for user support call 202-260-1531).
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
transferred. When other sources of pollutant release data have been
obtained, these data have been included to augment the TRI information.
TRI Data Limitations
The reader should keep in mind the following limitations regarding TRI data.
Within some sectors, the majority of facilities are not subject to TRI
reporting because they are not considered manufacturing industries, or
because they are below TRI reporting thresholds. Examples are the mining,
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Pulp and Paper Industry
dry cleaning, printing, and transportation equipment cleaning sectors. For
these sectors, release information from other sources has been included.
The reader should also be aware that TRI "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 to each chemical
released so that one can differentiate between pollutants with significant
differences in toxicity. As a preliminary indicator of the environmental
impact of the industry's most commonly released chemicals, the notebook
briefly summarizes the toxicological properties of the top five chemicals (by
weight) reported by each industry.
General Definitions
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 manufacturing facilities that have 10 or more full-time
employees and are above established pollutant release and transfer
thresholds. Manufacturing facilities are defined as facilities in Standard
Industrial Classification primary codes 20-39. Facilities must submit
estimates for all chemicals that are on the EPA's defined list and are above
throughput 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.
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 emission 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.
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Releases to Water (Surface Water Discharges) — encompass any releases
going directly to streams, rivers, lakes, oceans, or other bodies of water. Any
estimates for stormwater 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,
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 wastewaters 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 landfilled within the sludge.
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.
September 1995
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Pulp and Paper Industry
IV.A. EPA Toxics Releases Inventory For the Pulp and Paper Industry
According to Toxic Release Inventory (TRI) data from SIC codes 261-265,
the pulp and paper industry released (to the air, water, or land) and
transferred (shipped off-site) a total of approximately 218 million pounds of
toxic chemicals during calendar year 1993b. This represents less than 4
percent of the total pounds of TRI chemicals released and transferred by all
manufacturers that year. In comparison, the chemical industry (SIC 28)
produced 2.5 billion pounds that year, accounting for 33 percent of all
releases and transfers during that period.
The pulp and paper industry's releases have been declining in recent years.
The 1993 release total represented a 8 percent reduction over the previous
year, and a 22 percent reduction since 1988. This reduction was not as great
as manufacturers' average of 43 percent for that period. The pulp and paper
industry had the sixteenth lowest decrease in TRI releases and transfers of all
TRI reporting industries. The greatest reductions were achieved in the
electrical and electronic equipment sector (SIC 36) with a 69 percent
reduction.
Given that pulp and paper industry production increased approximately 20
percent during the 88-92 period, one possible reason for these reductions in
TRI data was the industry's efforts at pollution prevention. At the facility
level, the pulp and paper industry reported the ninth highest level of pollution
prevention activities among the 19 TRI reporting industries. Within the two
digit SIC code 26, which includes paper conversion in addition to pulp and
paper mills, 40 percent indicated source reduction activities at their facilities,
somewhat higher than the average for all TRI facilities. The activities cited
most often by the pulp and paper industry were good operating practices,
process modifications, and raw material modifications. The highest pollution
prevention activity was done by the laboratory, medical, and photographic
instrument manufacturing industry (SIC 38) at 54 percent industry
participation.
Comparisons of the pounds released or transferred per facility demonstrate
that the pulp and paper industry had the highest per facility TRI chemical
releases of all industries in 1993. The mean amount of toxic chemical
releases per facility was approximately 120,000 pounds for all TRI facilities.
The toxic chemical releases of the average pulp and paper facility were
fivefold that amount, approximately 550,000 pounds. The second highest per
b Unless otherwise indicated, TRJ data for SIC codes 261-265 were used for pulp and paper release and transfer values
in this section and the tables therein.
September 1995
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Pulp and Paper Industry
facility releases were from the chemical industry (SIC 28) at approximately
316,000 pounds per facility. The mean amount transferred by facilities was
greater than that of pulp and paper mills (202,000 pounds transferred off-site
per facility compared to 156,700 per mill). The industry with the largest
transfers per facility was the petroleum industry (SIC 29), which transferred
approximately 1,894,000 pounds per facility. This value was by far the
largest of TRI industries (three times that of the closest industry) and skewed
the TRI mean transfer value.
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 87 percent of its total TRI poundage to
the air, approximately 10 percent to water and POTWs, and 2 percent is
transferred off site or disposed on land. This release profile differs from
other TRI industries which average approximately 93 percent to air 6 percent
to land, and 1 percent to water. 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 Exhibit 23).
Air releases can be traced to a variety of sources. Approximately 50 percent
are methanol, a by-product of the pulp making process. The other major air
toxic chemicals: chlorinated compounds, sulfuric acid, and the chelator
methyl ethyl ketone, originate in the bleaching stage. Methanol also
accounts for approximately 40 percent of the water releases by pulp and
paper facilities. Overall, methanol represents over 49 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 used by
the greatest number of mills is sulfuric acid. In addition, some TRI
chemicals are each only used by a few mills, suggesting process specific
needs such as paper finishing or use in wet additives.
September 1995
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Sector Notebook Project
Pulp and Paper Industry
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September 1995
56
SIC 261 through 265
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Sector Notebook Project
Pulp and Paper Industry
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-------
Sector Notebook Project
Pulp and Paper Industry
The TRI database contains a detailed compilation of self-reported, facility-
specific chemical releases. The top reporting facilities for this sector are
listed below (Exhibit 25). Facilities that have reported only the SIC codes
covered under this notebook appear on the first list. The second list (Exhibit
26) contains additional facilities that have reported the SIC code covered
within this report, and one or more SIC codes that are not within the scope
of this notebook. Therefore, the second list includes facilities that conduct
multiple operations — some that are under the scope of this notebook, and
some that are not. Currently, the facility-level data do not allow pollutant
releases to be broken apart by industrial process.
Exhibit 25: Top 10 TRI Releasing Pulp and Paper Facilities, 1993C
Rank
1
2
3
4
5
6
7
8
9
10
Facility
Westvaco Corp. Kraft Div. - North Charleston, SC
Westvaco Corp. Bleached Board Div. - Covington, VA
ITT Rayonier Inc. Port Angeles Pulp Div. - Port Angeles, WA
Inland Container Corp. Rome Linerboard Div. - Rome, GA
Stone Container Corp. Containerboard & Paper Div. - Florence, SC
Scott Paper Co. - Mobile, AL
CPI Kraft Div. - Wisconsin Rapids, WI
Champion International Corp. Courtland Mill - Courtland, AL
Great Southern Paper - Cedar Springs, GA
Alabama River Pulp Co. Inc. -Claiborne, AL
Total TRI
Releases in Pounds
5,297,899
4,752,355
3,661,010
3,245,815
3,049,918
3,009,185
2,881,855
2,874,701
2,522,520
2,433,605
Source: U.S. EPA, Toxic Release Inventory Database, 1993.
1 Being included in this list does not mean that the release is associated with non-compliance with environmental laws.
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Exhibit 26: Top 10 TRI Releasing Facilities Reporting Pulp and Paper
Industry SIC Codes to TRI, 1993d
Rank
1
2
3
4
5
6
7
8
9
10
SIC Codes
Reported
in TRI
2611,2631
2631
2611
2611,2631,
2821,2653
2611,2631
2611,2621,
2631,2679
2621,2631
2621
2611
2621
Facility
Westvaco Corp. Kraft Div. - North Charleston, SC
Westvaco Corp. Bleached Board Div. - Covington, VA
ITT Rayonier Inc. Port Angeles Pulp Div. - Port Angeles, WA
Union Camp Corp. - Savannah, GA
Inland Container Corp. Rome Linerboard Div. - Rome, GA
Union Camp Corp. Fine Paper and Building Products Div. -Franklin,
VA
Stone Container Corp. Containerboard & Paper Div. - Florence, SC
Scott Paper Co. - Mobile, AL
CPI Kraft Div. - Wisconsin Rapids, WI
Champion International Corp. Courtland Mill - Courtland, AL
Total TRI
Releases
in Pounds
5,297,899
4,752,355
3,661,010
3,499,470
3,245,815
3,085,254
3,049,918
3,009,185
2,881,855
2,874,701
Source: U.S. EPA, Toxics Release Inventory Database, 1993.
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 1993 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 and 33/50
programs, 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
Being included on this list does not mean that the release is associated with non-compliance with environmental laws.
September 1995
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the chemicals described hi 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 1993 Toxics
Release Inventory Public Data Release (EPA, 1994), and 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 toxicological databases managed by EPA, National Cancer
Institute, and the National Institute for Occupational Safety and Health.6
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 hi HSDB. For more information on TOXNET, contact the
TOXNET help line at 800-231-3766.
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 1 mg methanol per liter water. Methanol is not likely to persist in
water or to bioaccumulate in aquatic organisms.
Carcinogemcity. There is currently no evidence to suggest that this
chemical is carcinogenic.
c Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research Information System), DART
(Developmental and Reproductive Toxicity Database), DBIR (Directory of Biotechnology Information Resources),
EMICBACK (Environmental Mutagen Information Center Backfile), GENE-TOX (Genetic Toxicology), HSDB
(Hazardous Substances Data Bank), IRIS (Integrated Risk Information System), RTECS (Registry of Toxic Effects of
Chemical Substances), and TRI (Toxic Chemical Release Inventory).
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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.
Hydrochloric Acid (CAS: 7647-01 -1)
Toxicity. Hydrochloric acid is primarily a concern in its aerosol form. Acid
aerosols have been implicated hi 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.
Sulfuric Acid TCAS: 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, hi 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.
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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.
Chloroform (CAS: 67-66-3)
Toxicity. Target organs of chloroform toxicity include the liver, kidneys,
heart, eyes, and skin. Short-term exposure to high concentrations of
chloroform leads to inebriation and excitation, followed by central nervous
system depression, including fainting, dizziness, and anesthesia;
gastrointestinal upsets, including nausea, vomiting, and salivation; kidney
damage; and liver damage. Exposure to very high concentrations of
chloroform may lead to respiratory depression, loss of motor functions,
coma, and death due to heart, liver or kidney failure. Long-term exposure to
chloroform is associated with liver and kidney damage, and mood changes.
Contact with the eyes and skin causes reversible damage.
Populations at special risk from exposure to chloroform include individuals
with liver, kidney, or central nervous system damage, and chronic alcoholics.
Carcinogenicity. Chloroform is a probable human carcinogen, based on
evidence in animals due to both oral and inhalation exposure.
Environmental Fate. The majority of chloroform releases to the
environment are to the atmosphere; releases to water and land will be
primarily lost by evaporation and will also end up in the atmosphere.
Atmospheric releases may be transported long distances and will
photodegrade with a half-life of a few months. Releases onto the land that
do not evaporate will also leach through the soil and persist in the
groundwater for a long time. Little chloroform is adsorbed to soil particles.
Biodegradation is generally slow.
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Chloroform is not expected to bioconcentrate in the food chain, though
contamination of food is likely due to its use as an extractant and its presence
in drinking water.
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.
IV.C. Other Data Sources
The toxic chemical release data obtained from TRI captures the vast majority
of facilities in the pulp and paper industry. It also allows for a comparison
across years and industry sectors. Reported chemicals are limited, however,
to the 316 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 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.
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Exhibit 27 summarizes annual releases of carbon monoxide (CO), nitrogen
dioxide (NO2), particulate matter of 10 microns or less (PM10), total
particulates (PT), sulfur dioxide (SO2), and volatile organic compounds
(VOCs).
Exhibit 27: Pollutant Releases (short tons/year)
Industry Sector
Metal Mining
Nonmetal Mining
Lumber and Wood Production
Furniture and Fixtures
Pulp and Paper
Printing
Inorganic Chemicals
Organic Chemicals
Petroleum Refining
Rubber and Misc. Plastics
Stone, Clay and Concrete
Iron and Steel
Nonferrous Metals
Fabricated Metals
Computer and Office Equipment
Electronics and Other Electrical
Motor Vehicles, Bodies, Parts
Dry Cleaning
CO
5,391
4,525
123,756
2,069
624,291
8,463
166,147
146,947
419,311
2,090
58,043
1,518,642
448,758
3,851
24
367
35,303
101
NO2
28,583
28,804
42,658
2,981
394,448
4,915
103,575
236,826
380,641
11,914
338,482
138,985
55,658
16,424
0
1,129
23,725
179
PM10
39,359
59,305
14,135
2,165
35.579
399
4,107
26,493
18,787
2,407
74,623
42,368
20,074
1,185
0
207
2,406
3
PT
140,052
167,948
63,761
3,178
113,571
1,031
39,062
44,860
36,877
5,355
171,853
83,017
22,490
3,136
0
293
12,853
28
S02
84,222
24,129
9,419
1,606
541,002
1,728
182,189
132,459
648,155
29,364
339,216
238,268
373,007
4,019
0
453
25,462
152
voc
1,283
1,736
41,423
59,426
96,875
101,537
52,091
201,888
369,058
140,741
30,262
82,292
27,375
102,186
0
4,854
101,275
7,3 1 0
Source: U.S. EPA Office of Air and Radiation, AIRS Database, May 1995.
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.
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Similar information is available within the annual TRI Public Data Release
Book.
Exhibit 28 is a graphical representation of a summary of the 1993 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 Exhibit 29 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
1993 TRI data presented here covers 309 facilities. These facilities listed SIC
2611-2631 (Pulp, Paper, and Paperboard Mills) as primary SIC codes.
September 1995
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September 1995
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September 1995
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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 hi 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
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chemical or wood chip substitution to reduce the industry's use and releases
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 by the year 2000. 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
30 percent and is climbing slowly.29 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 industry is moving towards
pollution prevention as illustrated by the above average percentage of
facilities in the industry (43.1 percent) reporting pollution prevention
activities to TRI and the above average participation in the 33/50 Program
(25 percent) to reduce toxic chemicals releases (See Section \III.C.1). The
trend towards materials substitutions is also reflected in an increasing
demand for alternative pulping and bleaching chemicals.
One of the factors that will drive the industry towards pollution prevention
much more rapidly in the future are the proposed integrated NESHAP and
effluent limitation guidelines for the pulp and paper industry. (See Section
I.E. - Future Regulatory Requirements.) These regulations are being
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 of the proposed technology-based effluent limitation
guidelines for the control of toxic releases consist of process changes that
will 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.
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Brief descriptions of some of 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
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 tune;
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. As of 1993, extended delignification accounted for 20 percent of
worldwide bleached kraft capacity and 21 percent of U.S. mills. A
significant number of changeovers to the process are currently underway.
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
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Pulp and Paper Industry
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
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. As of
1993, oxygen delignification projects have been installed or were planned for
27 U.S. pulp and paper mills, accounting for more than 40 percent of bleach
kraft pulp production.
Ozone Delignification. As a result of a considerable research effort, ozone
delignification (ozone bleaching) is now being used in the pulp and paper
industry. 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
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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
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
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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
presses. Opportunities for reduced effluent flows and water use are also
present hi 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.
Chlorine Dioxide Substitution. The substitution of chlorine dioxide for
elemental chlorine as a bleaching agent is gaining widespread use due to its
beneficial Impacts on pulp and effluent quality. The use of chlorine dioxide
hi place of chlorine increases the proportion of oxidative reactions thereby
reducing the formation of residual chlorinated organic pollutants. Chlorine
dioxide bleaching produces about 20 percent of the chlorinated compounds
produced using elemental chlorine. A substitution of 50 to 70 percent in the
first bleaching stage has become relatively common in recent years. Chlorine
dioxide substitutions approaching 100 percent have been shown to increase
pulp yields and quality. The use of chlorine dioxide, however, is two to four
times more expensive than the equivalent oxidizing power using elemental
chlorine. Because chlorine dioxide is unstable and cannot be stored, it must
be continually generated at the mill. The processes used to manufacture
chlorine dioxide generate a number of byproducts that may have
environmental impacts, including, spent acids, chlorine gas, salt cakes and
acid cakes. A number of alternative chlorine dioxide generation processes
are being developed to reduce or eliminate the formation of such byproducts.
Split Addition of Chlorine/Improved pH Control. Although these process
modifications are not widespread throughout the industry (currently in
practice at 11 mills), one company has reported notable results. Reducing the
chlorine concentration during the bleaching process by adding elemental
chlorine in incremental charges has been shown to reduce the formation of
unwanted chlorinated organic compounds. A high pH in the chlorination
stage is also known to reduce the formation of chlorinated organic
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compounds, but normally this also results in a decreased pulp yield. A high
pH, in combination with split chlorine addition, however, has been observed
to reduce the formation of chlorinated compounds without a loss of yield. It
was reported that by using split chlorine addition, the generation of certain
dioxin and furan molecules were reduced by up to 70 percent. With the
addition of pH control these discharges reportedly fell by 90 percent.
However, consistency in reduction of chlorinated organic pollutants has be
problematic.
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. As of 1993, EPA estimates
that approximately 70 percent of domestic mills practice some type of
enhanced extraction process.
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. Modern chemical application control
and monitoring systems and high-shear! mixers have been developed which
decrease formation of chlorinated organic compounds.
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VI. SUMMARY OF APPLICABLE FEDERAL STATUTES AND REGULATIONS
This section discusses the Federal statutes and 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 regulations
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
Resource Conservation and Recovery Act (RCRA)
The Resource Conservation And Recovery Act (RCRA) of 1976, which
amended the Solid Waste Disposal Act, addresses solid (Subtitle D) and
hazardous (Subtitle C) waste management activities. The Hazardous and
Solid Waste Amendments (HSWA) of 1984 strengthened RCRA's hazardous
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 (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") and
materials which exhibit a hazardous waste characteristic (ignitability,
corrosivity, reactivity, or toxicity and designated with the code "D").
Regulated entities that generate hazardous waste are subject to waste
accumulation, manifesting, and .record keeping standards. Facilities that
treat, store, or dispose of hazardous waste must obtain a permit, either from
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EPA or from a State agency which EPA has authorized to implement the
permitting program. Subtitle C permits contain general facility standards
such as contingency plans, emergency procedures, record keeping and
reporting requirements, financial assurance mechanisms, and unit-specific
standards. RCRA also contains provisions (40 CFR Part 264, Subpart S and
§264.10) for conducting corrective actions which govern the cleanup of
releases of hazardous waste or constituents from solid waste management
units at RCRA-regulated facilities.
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 46 of the 50 States.
Most RCRA requirements are not industry specific but apply to any company
that transports, treats, stores, or disposes of hazardous waste. Here are some
important RCRA regulatory requirements:
Identification of Hazardous Wastes (40 CFR Part 261) lays out the
procedure every generator should follow to determine whether the
material created is considered a hazardous waste, solid 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 ID number, preparing a manifest, ensuring
proper packaging and labeling, meeting standards for waste
accumulation units, and record keeping and reporting requirements.
Generators can accumulate hazardous waste for up to 90 days (or 180
days depending on the amount of waste generated) without obtaining
a permit.
• Land Disposal Restrictions (LDRs) are regulations prohibiting the
disposal of hazardous waste on land without prior treatment. Under
the LDRs (40 CFR Part 268), materials must meet land disposal
restriction (LDR) treatment standards prior to placement hi a RCRA
land disposal unit (landfill, land treatment unit, waste pile, or surface
impoundment). Wastes subject to the LDRs include solvents,
electroplating wastes, heavy metals, and acids. Generators of waste
subject to the LDRs must provide notification of such to the
designated TSD facility to ensure proper treatment prior to disposal.
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
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a party considered a used oil marketer (one who generates and sells
off-specification used oil directly to a used oil burner), additional
tracking and paperwork requirements must be satisfied.
• 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 generators operating under
the 90-day accumulation rule.
• Underground Storage Tanks (USTs) containing petroleum and
CERCLA hazardous substance ,are regulated under Subtitle I 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
establishes increasingly stringent standards, including upgrade
requirements for existing tanks, that must be met by 1998.
• Boilers and Industrial Furnaces (BIFs) that use or burn fuel
containing hazardous waste must comply with strict design and
operating standards. BEF regulations (40 CFR Part 266, Subpart H)
address unit design, provide performance standards, require
emissions monitoring, and restrict the type of waste that may be
burned.
EPA's RCRA/Superfund/UST Hotline, at (800) 424-9346, responds to
questions and distributes guidance regarding all RCRA regulations. The
RCRA Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., ET, excluding
Federal holidays. \
Comprehensive Environmental Response, Compensation, And Liability Act (CERCLA)
CERCLA, a 1980 law commonly known as Superfund, authorizes EPA to
respond to releases, or threatened releases, of hazardous substances that may
present an imminent and substantial endangerment to 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 Superfund
for response 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 HI, also known as the Emergency Planning and Community
Right-to-Know Act (EPCRA).
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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 exceeds a reportable quantity. Reportable quantities are defined and
listed in 40 CFR §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 permanent cleanups, known as remedial actions, and other cleanups
referred to as "removals." EPA generally takes remedial actions only at sites
on the National Priorities List (NPL), which currently includes approximately
1,300 sites. Both EPA and states can act at other sites; however, EPA
provides responsible parties the opportunity to conduct removal and remedial
actions and encourages community involvement throughout the Superfund
response process.
EPA's RCRA/Superfund/USTHotline, at (800) 424-9346, answers questions
and references guidance pertaining to the Superfund program. The CERCLA
Hotline operates weekdays from 8:30 a.m. to 7:30 p.m., ET, excluding
Federal holidays.
Emergency Planning And Community Right-To-Know Act (EPCRA)
The Superfund Amendments and Reauthorization Act (SARA) of 1986
created EPCRA, also known as SARA Title HI, 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. EPCRA required the establishment of 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:
EPCRA §302 requires facilities to notify the SERC and LEPC of the
presence of any "extremely hazardous substance" (the list of such
substances is in 40 CFR Part 355, Appendices A and B) if it has such
substance in excess of the substance's threshold planning quantity,
and directs the facility to appoint an emergency response coordinator.
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EPCRA §304 requires the facility to notify the SERC and the LEPC
in the event of a non-exempt release exceeding the reportable
quantity of a CERCLA hazardous substance or an EPCRA extremely
hazardous substance.
EPCRA §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 of chemical use
to submit to the SERC, LEPC and local fire department material
safety data sheets (MSDSs) or lists of MSDS's 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 §313 requires manufacturing facilities included in SIC codes
20 through 39, 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, and allows EPA to compile the national Toxic
Release Inventory (TRI) database.
All information submitted pursuant to EPCRA regulations is publicly
accessible, unless protected by a trade secret claim.
EPA's EPCRA Hotline, at (800) 535-0202, answers questions and distributes
guidance regarding the emergency planning and community right-to-know
regulations. The EPCRA Hotline operates weekdays from 8:30 a.m. to 7:30
p.m., ET, excluding Federal holidays.
Clean Water Act (CWA)
f
The primary objective of the Federal Water Pollution Control Act, commonly
referred to as the CWA, is to restore and maintain the chemical, physical, and
biological integrity of the nation's surface waters. Pollutants regulated under
the CWA include "priority" pollutants, including various toxic pollutants;
"conventional" pollutants, such as biochemical oxygen demand (BOD), total
suspended solids (TSS), fecal coliform, oil and grease, and pH; and "non-
conventional" pollutants, including any pollutant not identified as either
conventional or priority.
The CWA regulates both direct and indirect discharges. The National
Pollutant Discharge Elimination System (NPDES) program (CWA §402)
controls direct discharges into navigable waters. Direct discharges or "point
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source" discharges are from sources such as pipes and sewers. NPDES
permits, issued by either EPA or an authorized State (EPA has presently
authorized forty States to administer the NPDES program), contain industry-
specific, technology-based and/or water quality-based limits, and establish
pollutant monitoring reporting requirements. A facility that intends 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 effluent., The
permit will then set forth the conditions and effluent limitations under which
a facility may make a discharge.
A NPDES permit may also include discharge limits 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 technological 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 the
NPDES storm water permit application regulations. Stormwater discharge
associated with industrial activity means the discharge from any conveyance
which is used for collecting and conveying stormwater and which is directly
related to manufacturing, processing or raw material storage areas at an
industrial plant (40 CFR 122.26(b)(14)). These regulations require that
facilities with the following storm water discharges 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 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
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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
(except drugs and paints); SIC 291-petroleum refining; and SIC 311-leather
tanning and finishing.
Category iii: 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.
Category viii: Facilities classified as SIC 40-railroad transportation; SIC
41-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
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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
35-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-miscellaneous
manufacturing industries; and SIC 4221-4225-public warehousing and
storage.
Pretreatment Program
Another type of discharge that is regulated by the CWA is one that goes to
a publicly-owned treatment works (POTWs). The national pretreatment
program (CWA §307(b)) controls the indirect discharge of pollutants to
POTWs by "industrial users." Facilities regulated under §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 toxicity characteristics of sludge generated by these plants.
Discharges to a POTW are regulated primarily by the POTW itself, rather
than the State or EPA.
EPA has developed general pretreatment standards and technology-based
standards for industrial users of POTWs in many industrial categories.
Different standards may 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 hi 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.
EPA's Office of Water, at (202) 260-5700, 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
(202) 260-7786.
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Safe Drinking Water Act (SDWA)
The 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 liquid 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 as close to MCLGs as
possible, considering cost and feasibility of attainment.
The SDWA Underground Injection Control (UIC) program (40 CFR Parts
144-148) is a permit program which protects underground sources of
drinking water by regulating five classes of injection wells. UIC permits
include design, operating, inspection, and monitoring requirements. Wells
used to inject hazardous wastes must also comply with RCRA corrective
action standards in order to be granted a RCRA permit, and must meet
applicable RCRA land disposal restrictions standards. The UIC permit
program is primarily State-enforced, since EPA has authorized all but a few
States to administer the program.
The SDWA also provides for a Federally-implemented Sole Source Aquifer
program, which prohibits Federal funds from being expended on projects 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.
EPA's Safe Drinking Water Hotline, at (800) 426-4791, answers questions
and distributes guidance pertaining to SDWA standards. The Hotline
operates from 9:00 a.m. through 5:30 p.m., ET, excluding Federal holidays.
Toxic Substances Control Act (TSCA)
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.
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TSCA standards may apply at any point during a chemical's life cycle.
Under TSCA §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 chemicals 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.
Under TSCA §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 §6
authority are asbestos, chlorofluorocarbons (CFCs), and polychlorinated
biphenyls (PCBs).
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 from 8:30 a.m. through 4:30 p.m., ET,
excluding Federal holidays.
Clean Air Act (CAA)
The CAA and its amendments, including the Clean Air Act Amendments
(CAAA) of 1990, 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 CAAA, many
facilities will be required to obtain permits for the first time. State and local
governments oversee, manage, and enforce many of the requirements of the
CAAA. 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 classified as attainment areas; those that do not meet NAAQSs are
classified as non-attainment areas. Under §110 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.
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Title I also authorizes EPA to establish New Source Performance Standards
(NSPSs), which are nationally uniform emission standards for new stationary
sources falling within particular industrial categories. NSPSs are based on
the pollution control technology available to that category of industrial
source but allow the affected industries the flexibility to devise a
cost-effective means of reducing emissions.
Under Title I, EPA establishes and enforces National Emission Standards for
Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented
towards controlling particular hazardous air pollutants (HAPs). Title III of
the CAAA further directed EPA to develop a list of sources that emit any of
189 HAPs, and to develop regulations for these categories of sources. To
date EPA has listed 174 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.
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 establishes a sulfur dioxide 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, which,
beginning in 1995, will be set below previous levels of sulfur dioxide
releases.
Title V of the CAAA of 1990 created 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 are developing
the permit programs in accordance with guidance and regulations from EPA.
Once a State program is approved by EPA, permits will be 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), will be phased out entirely by the year 2000,
while certain hydrochlorofluorocarbons (HCFCs) will be phased out by
2030.
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EPA's Control Technology Center, at (919) 541-0800, provides general
assistance and information on CAA standards. The Stratospheric Ozone
Information Hotline, at (800) 296-1996, provides general information about
regulations promulgated under Title VI of the CAA, and EPA's EPCRA
Hotline, at (800) 535-0202, answers questions' about accidental release
prevention under CAA §112(r). In addition, the Technology Transfer
Net\vork Bulletin Board System (modem access (919) 541-5742)) includes
recent CAA rules, EPA guidance documents, and updates of EPA activities.
VLB. Industry Specific Requirements
Effluent guidelines were promulgated for various subcategories of the pulp
and paper industry in 1974 and 1977, with additional guidelines promulgated
in 1982, primarily in the secondary fiber and nonintegrated segments of the
industry. Pulp and paper facilities also may generate a number of
wastestreams that are subject to RCRA requirements. In addition, they are
frequently large emitters of VOCs, NOX, SOX and reduced sulfur compounds
and thus may be subject to state requirements established by the State
Implementation Plan (SIP) process. New Source Performance Standards
under the Clean Air Act have been in place since 1978. In addition, all but
the smaller pulp and paper mills, in terms of employees and chemical usage,
are also subject to Emergency Planning and Community Right-to Know Act
requirements.
Trends in the industry's production technologies and processes are greatly
influenced by a series of environmental regulations initiated in 1974. Pulp
and paper mills are currently the subject of an integrated rulemaking
covering effluent guidelines for process wastewater discharges and National
Emissions Standards for Hazardous Air Pollutants (NESHAP). RCRA rules
under development may also affect wastewater treatment in surface
impoundments. In addition, an ongoing risk assessment will determine the
need for additional restrictions on the disposal of wastewater treatment
sludge.
Federal Statutes
Clean Air Act (CAA)
In 1978, under §111 of the CAA, EPA promulgated New Source
Performance Standards (NSPS) to limit emissions of particulate matter (PM)
and total reduced sulfur (TRS) for kraft pulp mills (FR 7568). The NSPS
applied specifically to: recovery furnaces, smelt dissolving tanks, lime kilns,
digester systems, brownstock washer systems, multiple effect evaporators,
black liquor oxidation systems, and condensate stripper systems. The 1978
NSPS also applies to existing plants modified after September 24, 1976.
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Minor revisions and corrections to these regulations were promulgated on
May 20, 1986 (FR 18538) Under §lll(d), the CAA covers state plans for
control of existing sources of non-criteria pollutants (e.g., TRS). Section 112
concerns hazardous air pollutant standards, some of which affect the pulp
and paper industry.
Title I - Provisions for Attainment and Maintenance of the National Ambient
Air Quality Standards:
• NOX and SOX controls established as part of State Implementation
Plans (SIPs) may be applicable to energy generation at some mills.
Air emissions from pulp and paper mills are more often covered by state
regulations rather than federal regulations (although the state requirements
are often federally enforceable as part of the State Implementation Plan).
Kraft pulp mills that have been constructed or modified after September 24,
1976 may be subject to New Source Performance Standard (NSPS) emission
limitation, monitoring, and reporting requirements at 40 CFR Part 60 Subpart
BB, which limit particulate matter and total reduced sulfur (TRS). (Existing
kraftpulp mill sources are often covered by state TRS emission limitations,
many of which were established under Clean Air Act Section 11 l(d)). hi
addition, fossil-fuel-fired boilers that heat water or other heat transfer media
and have a heat input rate over 250 million Btu per hour are subject to NFS
limits for particulate, sulfur dioxide, and nitrogen oxide under 40 CFR Part
60 Subpart D, if constructed or "modified" after August 17, 1971. Fossil-
fuel-fired boilers that commence construction or "modification" after June
19, 1984 may be subject to more stringent limits for particulate, sulfur
dioxide, or nitrogen oxide under Subpart Db; those NPS regulations apply to
fossil-fuel-fired boilers greater than 100 million Btu per hour. NSPS for
smaller boilers, between 10 and 100 million Btu per hour, have construction
or "modification" after June 9, 1989. Some mills also operate gas turbines
subject to NSPS in 40 CFR Part 60 Subpart GG.
Frequently, pulp and paper mills have installed new equipment or modified
equipment that produced a significant net emissions increase above
thresholds for the Prevention of Significant Deterioration (PSD) or
nonattainment new source review (NSR) regulations. In those cases, the
source should have received a PSD/NSR permit from either EPA or the state
air pollution control agency, and such permits impose additional limitations
beyond those contained in federal and state categorical emission standards,
including emission limitations based on the Best Available Control
Technology (BACT) or Lowest Achievable Emission Rate (LAER) for
pollutants for which there was a significant increase.
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State air pollution regulations frequently impose numerous additional
limitations on emissions from pulp and paper mills, including limits on both
stack and fugitive emissions of particulate matter, volatile organic compound
emission limitations or usage restrictions, and TRS emission limitations
designed to control odor.
Resource Conservation and Recovery Act (RCRA)
The pulp and paper industry generates a variety of RCRA wastes, but most
are managed through wastewater treatment systems. RCRA listed wastes
outside of wastewater streams are typically generated in small quantities.
Other wastes may be managed on a case-by-case basis as hazardous where
one or more hazardous characteristics (e.g., ignitable, toxic, reactive,
corrosive) are found. The majority of the industry's wastestreams are
nonhazardous wastewaters and sludge. The industry has a pulping liquor
exemption.
As a result of an Environmental Defense Fund suit and resultant consent
decree, the "RCRA mega-deadline" requires EPA to consider whether paper
mill wastewater treatment sludges meet the criteria for listing as hazardous
wastes. This determination is expected to occur pursuant to completion of
the final effluent guidelines. The exception to this requirement is for effluent
guidelines based on the use of oxygen deligniftcation, ozone bleaching,
prenox bleaching, enzymatic bleaching, hydrogen peroxide bleaching,
oxygen and peroxide enhanced extraction, or any other technology involving
substantially similar reductions in uses of chlorine-containing compounds.
EPA has deferred any work on the proposed regulations regarding land
application of sludges because the AF&PA and EPA signed the land
application stewardship agreement.
Emergency Planning and Community Right-to-Know Act (EPCRA)
• Emergency Planning (§302(a)) - Businesses that produce, use or
store "hazardous chemicals" at or above "threshold planning
quantities" 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" are also 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.
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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.
Approximately 296 pulp and paper facilities nationwide submitted
forms summarizing their chemical releases in 1992. Documentation
supporting release estimates made must be kept for three years.
Clean Water Act (CWA)
On May 9, 1974, May 29, 1974 and January 6, 1977, EPA promulgated a
series of effluent guidelines for different subcategories within the pulp,
paper, and paperboard industry. These regulations focused on reducing
conventional pollutants, such as biochemical oxygen demand, suspended
solids, and pH following some revisions and additional focus on toxic
pollutant discharges regulations were revised in 1982 and 1986 (51 FR
45232). The existing effluent guidelines (BPT, BAT, NSPS, PSES, include
PSN (47 FR 52006) were promulgated on November 18,1982 for all but one
of the pulp, paper and paperboard subcategories. BCT standards were
promulgated in 1986.
Wastewater discharges from most pulp and paper mills are covered by BCT
and BAT effluent limitations guidelines (or, in the case of indirect
discharges, pretreatment standards) in 40 CFR Part 430. Those regulations
specify production-based effluent limitations for biochemical oxygen
demand, total suspended solids, and pH. Many pulp and paper mills have
NPDES permit limitations more stringent than the BCT and BAT guidelines
would allow, because they discharge to water-qualiry-limited streams. Those
limitations are derived by the permitting authority pursuant to Clean Water
Act section 301 (b)(l)(C) and 40 CFR § 122.44(d). For many bleached
chemical pulp mills, water-quality-based permit limitations for 2,3,7,8-
TCDD have been issued as Individual Control Strategies under Clean Water
Act Section 304(1).
Of course, pulp and paper mills are also potentially subject to numerous
other generic regulations under the Clean Water Act, such as stormwater
permitting requirements, spill control planning requirements for facilities that
store petroleum products, general pretreatment standards under 40 CFR Part
403 for indirect dischargers, and permitting for dredge and fill activities
under Clean Water Act Section 404. Most states also have their own
discharge permitting and water pollution control regulations.
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State Statutes
In 1986, six states (CA, KY, LA, MD, NC, and SC) had fully EPA-approved
Section lll(d) plans to control TRS at kraft pulp mills, two states had
approved TRS standards but their compliance schedules had not yet been
approved (AR and GA), and Tennessee's and Florida's plans had been
submitted to Region IV for approval. Since that time, a number of states
have received approval on their plans to control TRS from existing kraft pulp
mills under Section lll(d). In addition, in 1986, twelve states had state
regulations on kraft pulping TRS emissions outside of Section lll(d)
approved plans (AL, AZ, FL, ID, MT, NH, OH, OK, OR, TN, VA, and WA).
In general, particulate matter (PM) emissions limits are established on a per
ton of pulp produced basis and/or for specific processes (e.g., lime kilns,
smelt tanks, and recovery furnaces). Certain states also established opacity
limits and performance standards for specific processes. Investigations
related to the integrated rulemaking identified seventeen states with
regulations specific to the pulp and paper industry. (Contact: Debra Nicoll
OW, ESAB 202-260-5385)
VI.C. Pending and Proposed Regulatory Requirements
In 1992, the pulp and paper industry was identified in the Source Reduction
Review Project (SRRP) as an industry for which a more integrated (across
environmental media) approach to rulemaking was warranted. In addition,
the Senior Policy Council emphasized that upstream process controls were
to be investigated as possible regulatory control options (Contact: Jordan
Spooner 202-260-4418). On December 17,1993, EPA proposed integrated
NESHAP and effluent guidelines for the pulp and paper industry. The rules
apply to mills in SIC codes 2611, 2621, 2631, and 2661. One key element
of the integrated rulemaking was to propose revisions to EPA's
subcategorization scheme for effluent guidelines. (The table identifies which
proposed rules apply to the various pulp and paper subcategories.) The
Agency is currently re-evaluating the 1993 proposal based on comments and
new information.
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Exhibit 30: Scope of Proposed Integrated Air and Water Rules
for Pulp and Paper
Effluent Guidelines
Subcategory
Dissolving Kraft
Bleached Papergrade Kraft and Soda
Unbleached Kraft
Dissolving Sulfite
Papergrade Sulfite
Semi-Chemical
Mechanical Pulp
Non-Wood Chemical
Secondary Fiber Deink
Secondary Fiber Non-Deink
Fine and Lightweight Papers from
Purchased Pulp
Tissue, Filter, Nonwoven, and
Paperboard from Purchased Pulp
Subpart
A
B
C
D
E
F
G
H
I
J
K
L
CAA
NESHAP
X
X
X
X
X
X
Clean Water Act
Toxics:
BAT/PSES
X
X
X
X
X
X
X(New
Sources)
Conventionals:
BPT
X
X
X
X
X
X
X
X
X
X
X
X
BMPs*
X
X
X
X
X
X
X
* Under §304(e) of CWA, EPA proposed Best Management Practices to prevent spills and other losses of pulping
liquor.
Clean Air Act Amendments of 1990 (CAAA)
The Clean Air Act Amendments of 1990 included a number of provisions for
which the Agency will develop regulations likely to affect pulp and paper
facilities directly. Most relevant is the NESHAP for pulp and paper which
has been integrated with the proposed effluent guidelines under the Clean
Water Act in a recent proposal. (Contact: Penny Lassiter 919-541-5396)
Title I - Provisions for Attainment and Maintenance of the National Ambient
Air Quality Standards:
• Ozone nonattainment areas are classified as: marginal, moderate,
serious, severe, or extreme. "Major" stationary sources are defined
as having potential emissions of 50 tons of VOCs per year in serious
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areas; 25 tons per year in severe areas; and 10 tons or more in
extreme areas. For all other areas, a major source is one that releases
100 tons of VOCs per year. Based on TRI, over 150 pulp and paper
facilities release an average of almost 500 tons of methanol per year.
Pulp and paper facilities designated a major source are subject to
Reasonably Available Control Technology (RACT) requirements.
The state must develop and adopt non-CTG (Control Techniques
Guidelines) RACT rules for such sources.
Title IE - National Emissions Standards for Hazardous Air Pollutants
(NESHAP):
• Maximum Achievable Control Technology (MACT) standards are
scheduled for a list of 189 Hazardous Air Pollutants (HAPs) listed in
§112(b). MACT standards for the pulp and paper industry were
proposed along with the effluent guidelines in December 17, 1993.
The proposed MACT standard was assumed to control emissions of
methanol, hexane, toluene, methyl ethyl ketone, chloroform,
chlorine, formaldehyde, acrolein, and acetaldehyde, many of which
are VOCs subject to RACT rules under Title I. The air emission
points selected for the proposed regulations included all significant
points in the pulping and bleaching processes and in the process
wastewater collection and treatment systems. Air and water
sampling at 16 chemical pulp mills was conducted during 1993 and
1994 by American Forest and Paper Association member companies
and the National Council of the Paper Industry for Air and Stream
Improvement to assist EPA in developing MACT standards.
Clean Water Act (CWA)
As part of a consent decree with the Environmental Defense Fund and the
National Wildlife Federation, EPA was to review the need for revised
rulemaking applicable to dioxins and furans for the pulp and paper industry,
including wastewater treatment sludge. The analysis of risks pays particular
attention to cross-media exposure pathways. OSWER and OPPTS are the
lead offices for this effort. One of the key follow-up rulemaking efforts to
implement this decree were the revised effluent guidelines under the CWA.
In coordination with OSW and OAQPS, the Office of Water proposed
effluent guidelines for the pulp and paper industry. Revised BPT and BCT
limitations are proposed for all facilities to control conventional pollutants,
such as BOD and TSS. BPT concentration limits were based on water
recycling and end-of-pipe treatment. Limitations for toxic and non-
conventional pollutants were based on the Best Available Technology
Economically Achievable (BAT) to the assigned subcategory. BAT
technologies relied in-part on in-process controls and modifications. EPA
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also proposed NSPS and pretreatment standards for both new and existing
indirect dischargers. (Contact: Donald Anderson 202-260-7137; David
Layland, OSWER, 202-260-4796; Gale:Cooper, OPPTS, 202-260-1855)
Resource Conservation and Recovery Act (RCRA)
Two common practices in the pulp and paper industry may be affected by
upcoming RCRA rules. First, as a result of the multi-pathway risk
assessment, it may be determined that land application of wastewater
treatment sludge is too risky. A separate consent decree (EDF v. Reilly)
requires EPA to consider whether sludge meet the criteria for listing as
hazardous wastes, although EPA had proposed a TSCA §6 rule limiting soil
concentrations of dioxins and furans. Second, combining of wastewaters in
surface impoundments is allowed if there are no hazardous constituents after
dilution. The point of generation principle which does not allow dilution
prior to removal/minimization of the hazardous character of the waste (in this
case corrosiviry or ignitabiliry) does not strictly apply. Under an emergency
interim rule (58 FR 29860), CWA systems are not immediately affected and
current practices are acceptable for now. RCRA rulemakings addressing
these systems are scheduled to be finalized in 1995 and 1996 although some
requirements of the final integrated rule may address the issues of concern
under RCRA.
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VII. COMPLIANCE AND ENFORCEMENT HISTORY
Background
To date, EPA has focused much of its attention on measuring 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. In order to mirror the facility universe
reported in the Toxic Chemical Profile, the data reported within this section
consists of records only from the TRI reporting universe. With this decision,
the selection criteria are consistent across sectors with certain exceptions.
For the sectors that do not normally report to the TRI program, data have
been provided from EPA's Facility Indexing System (FINDS) which tracks
facilities in all media databases. Please note, in this section, EPA does not
attempt to define the actual number of facilities that fall within each sector.
Instead, the 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
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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 (August 10, 1990 to August 9, 1995) and the other
for the most recent twelve-month period (August 10, 1994 to August 9,
1995). 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/ 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
do not rank regional performance or necessarily reflect which regions may
have the most compliance problems.
Compliance and Enforcement Data Definitions
General Definitions
Facility Indexing System (FINDS) ~ this system assigns a common facility
number to EPA single-media permit records. The FINDS identification
number 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
* EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); III (DC, DE, MD, PA,
VA, WV); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, WI); VI (AR, LA, NM, OK, TX); VII (IA,
KS, MO, NE); VIII (CO, MT, ND, SD, UT, WY); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ID, OR, WA).
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databases. IDEA uses the FINDS identification number to "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), RCRIS (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 universe of TRI reporters within the
listed SIC code range. For industries not covered under TRI reporting
requirements, the notebook uses the FINDS universe for executing data
queries. 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 12 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
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 3 enforcement actions counts as
one). All percentages that appear are referenced to the number of facilities
inspected.
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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 3 enforcement actions counts as 3).
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/FEFRA/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
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
September 1995
100
SIC 261 through 265
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Sector Notebook Project
Pulp and Paper Industry
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
Exhibit 31 provides an overview of the reported compliance and enforcement
data for the pulp and paper industry over the past five years (August 1990 to
August 1995). These data are also broken out by EPA Region thereby
permitting geographical comparisons. A few points evident from the data are
listed below.
• The number of different pulp and paper facilities inspected was
slightly more than 86 percent of those identified in the IDEA search.
Also, these facilities were inspected on average every five months.
• The proportion of enforcement actions to inspections was relatively
low at 13 percent.
• Those facilities with one or more enforcement actions had, on
average, over the five year period, over four enforcement actions
brought against them.
September 1995
101
SIC 261 through 265
-------
Sector Notebook Project
Pulp and Paper Industry
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September 1995
102
SIC 261 through 265
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Sector Notebook Project
Pulp and Paper Industry
VII.B. Comparison of Enforcement Activity Between Selected Industries
Exhibits 32 and 33 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 Exhibits 32 and 33 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
year. Some points evident from the data are listed below.
• Of those sectors listed, the pulp and paper industry has been one of
the most frequently inspected industries over the past five years
based upon its low number of months between inspections.
• State lead actions have dominated the total number of enforcement
actions taken against the pulp and paper industry.
Over the past five years, the pulp and paper and the inorganic
chemicals sector have had equal rates of enforcement actions per
inspection. These rates are the median value for those industry
sectors listed.
Exhibits 34 and 35 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 Exhibits
(Exhibits 32 and 33), the data cover the last five years (Exhibit 34) and the
last one year (Exhibit 35) to facilitate the identification of recent trends.
Two points evident from the data are listed below.
• The number of inspections carried out under the Clean Air Act and
the Clean Water Act over the past five years account for close to
eighty percent of total enforcement actions within the sample. This
figure has increased to ninety percent over the past year.
• The number of enforcement actions taken under the CAA as a
percent of the total number of enforcement actions, has increased in
the past year compared to the average of the past five years. Over
this same time period, the percentage of total enforcement actions
under RCRA has decreased.
September 1995
103
SIC 261 through 265
-------
Sector Notebook Project
Pulp and Paper Industry
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104
SIC 261 through 265
-------
Sector Notebook Project
Pulp and Paper Industry
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September 1995
105
SIC 261 through 265
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Sector Notebook Project
Pulp and Paper Industry
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September 1995
106
SIC 261 through 265
-------
Sector Notebook Project
Pulp and Paper Industry
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September 1995
107
SIC 261 through 265
-------
Sector Notebook Project
Pulp and Paper Industry
VH.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. Four SEPs are reviewed.
VH.C.l. Review of Major Cases
The Office of Regulatory Enforcement does not regularly compile
information related to major cases and pending litigation within an industry
sector. The staff are willing to pass along such information to Agency staff
as requests are made. (Contact: Pete Rosenberg 202-260-8869) In addition,
summaries of completed enforcement actions are published each fiscal year
in the Enforcement Accomplishments Report; the summaries are not
organized by industry sector. (Contact: Robert Banks 202-260-8296)
EPA has entered into several consent decrees with public interest groups but
no significant litigation pending with the regulated community were
identified. Earlier lawsuits (e.g., Weyerhaeuser Company, et al. v. Costle,
590 F. 2nd 1011) concerned applicability of effluent guidelines promulgated
in 1974 and 1977. With one exception, the rules were upheld and have been
superseded by later rules. The agency is now in the midst of an integrated
rulemaking for the pulp and paper industry, the predominant regulations
being effluent guidelines and aNESHAP.
A recent report identifies a case where a bleached Kraft paper mill's pollution
prevention project, negotiated as part of an enforcement action, provided
injunctive relief. That is, the project itself was the means of correcting the
existing violation. This differs from supplemental environmental projects
(discussed below) which are incidental to the correction of the violation.
The facility faced a $2.9 million fine for violating NPDES permit limits for
chronic toxicity. While the fine was not reduced, the company investigated
and adopted a totally chlorine-free (TCP) bleaching process which eliminated
the use of chlorine and required some process modifications. Under a
September 1995
108
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Sector Notebook Project
Pulp and Paper Industry
consent decree to complete the project by 1995, they will use hydrogen
peroxide and oxygen for bleaching pulp and have added anthraquinone to the
digester to increase lignin removal prior to bleaching. Production costs are
expected to be higher and the pulp is not up to the product specifications of
commodity-grade market pulp, according to industry sources.30
Among the benefits accruing to the company were: reduced health and safety
hazards associated with handling and storing chlorine and chlorine dioxide
which are highly reactive, reduced costs of plant upkeep associated with the
corrosive nature of chlorine, improved community relations. A key factor in
selecting this project are the possible competitive advantages in domestic and
European markets where demand for TCP pulp exists and is growing. This
was the first commercial application of the process technology in the U.S.
and there is also the potential to license the technology to other U.S. pulp
mills.
VII.C.2. Supplementary Environmental Projects
Supplemental environmental projects (SEPs) are negotiated environmental
projects, of which a fraction of the costs may be applied to a facility's
original fine amount. Regional summaries of SEPs actions undertaken in the
1993 -1994 federal fiscal years were reviewed. Three SEPs in FY93 and no
SEPs in FY94 involved pulp and paper manufacturing facilities, as shown in
the following table.
Two of the three SEPs were associated with CERCLA violations, one was
associated with EPCRA violations (one facility was subject to both). The
specifics of the original violations are not known although some summaries
noted the specific sections of the statute violation. As is typical across
industry sectors, the cost of two of the pulp and paper SEPs was less than one
half the original fine amount. In one case, however, the cost of the SEP to the
company exceeded the original fine amount by three- to ten-fold.
All of the SEPs were done in Region IV - an area with significant pulping
and papermaking facilities. The SEPs fall into three categories:
• Non-process related projects: Two of the three SEPs involved projects not
directly related to the pulp and paper manufacturing processes or its outputs.
These projects involved contributions of equipment and/or funds to Local
Emergency Planning Committees (LEPCs). The cost to the companies of
these SEPs ranged from $6,000 to $9,656.
• Control and recovery technology installation: One of the three SEPs
involved installation of technological controls to minimize releases to the
September 1995
109
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Sector Notebook Project
Pulp and Paper Industry
environment (from spills) and to increase on-site recycling of process
chemicals. The project entailed construction of a spill containment and a
process chemical recycling system. The cost to company totaled $765,000,
the highest of all projects within the sector.
• Process change: One facility switched bleaching chemicals, eliminating
the use of molecular chlorine (a more difficult to handle and hazardous form)
from the manufacturing process. Specifically, the bleaching process will
now be based on bleaching pulp using sodium hypochlorite. The cost to
company of this process change totaled $72,000.
September 1995
110
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Sector Notebook Project
Pulp and Paper Industry
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J3 W W 0 c (0
cs <" T; to a c
0 S3 o o Bo
g -o (g « § u •-
B flj ^3 _^ CJ
° o >, ^ •- 3
H |" -a '5b ^s u ^
••§ "3 ^"S &> § *<
sllll 11-
*" H " S ^ ^
"g ^ i^U o « g
"a § "S S ° o -a
S dj C3 T3 •*-* | ) ^^
ts 73 ^" «3 8 W J^
"O -C S OH OH f-t "3
jS •— .g pj yq o .S
^ 5 PH CO C/3 JZ PH
September 1995
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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. EPA Voluntary Programs
3 3/50 Program
The "33/50 Program" is EPA's voluntary program to reduce toxic chemical
releases and transfers of seventeen chemicals from manufacturing facilities.
Participating companies pledge to reduce their toxic chemical releases and
transfers by 33 percent as of 1992 and by 50 percent as of 1995 from the
1988 baseline year. Certificates of Appreciation have been given out to
participants meeting their 1992 goals. The list of chemicals includes
seventeen high-use chemicals reported in the Toxics Release Inventory.
Exhibit 37 lists those companies participating in the 33/50 program that
reported the SIC code 261 through 265 to TRL Many of the companies
shown listed multiple SIC codes and, therefore, are likely to carry out
operations in addition to pulp and paper manufacturing. The SIC codes
reported by each company are listed hi no particular order. In addition, the
number of facilities within each company that are participating in the 33/50
program and that report SIC 261 through 265 to TRI is shown. Finally, each
company's total 1993 releases and transfers of 33/50 chemicals and the
percent reduction in these chemicals since 1988 are presented.
The pulp and paper industry as a whole used, generated or processed eight
target TRI chemicals. Of the target chemicals, chloroform, methyl ethyl
ketone, and toluene are released and transferred most by quantity.
Chloroform is released in the greatest quantity overall; chloroform releases
are almost ten times that of methylethyl ketone, the next largest release
quantity. These two chemicals account for approximately 65 percent of
33/50 chemical releases and transfers from pulp and paper facilities and six
percent of all of the industry's TRI: releases and transfers in 1993.
Chloroform and methylethyl ketone are also released by greatest number of
mills in comparison to the other 33/50 chemicals. Thirty one companies
listed under SIC 261-265) are currently participating in the 33/50 program.
They account for 13 percent of the 245 pulp and paper companies under SIC
261-265 which is slightly lower than the average for all industries of 14
percent participation. (Contact: Mike Burns 202-260-6394; or the 33/50
Program 202-260-6907.)
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Exhibit 37: 33/50 Program Participants Reporting SIC 261 through 265
(Pulp and Paper)
S'amc of Parent Company
Boise Cascade Corporation
Bomarko Inc.
Bowatcr Incorporated
Champion International Corp.
Consolidated Papers Inc.
Federal Paper Board Company
Fletcher Paper Company
Fort Howard Corporation
Georgia-Pacific Corporation
Green Bay Packaging Inc.
H Enterprises Intl.
International Paper Company
ITT Corporation
James River Corp Virginia
Kimberly-Clark Corporation
Louisiana-Pacific Corporation
Mead Corporation
Parsons & Whittemore Entps.
Potlateh Corporation
Procter & Gamble Company
Rivcnvood International USA
Scott Paper Company
Sibv/Ms Holdings Inc.
Simpson Investment Company
Sonoco Products Company
Temple-Inland Inc.
Tenneco Inc.
Union Camp Corporation
Wcstvaco Corporation
Weyerhaeuser Company
Willamette Industries Inc.
City, State
Boise, ID
Plymouth, IN
Greenville, SC
Stamford, CT
Wisconsin Rapids, WI
Montvale, NJ
Alpena, MI
Green Bay, WI
Atlanta, GA
Green Bay, WI
Minneapolis, MN
Purchase, NY
New York, NY
Richmond, VA
Irving, TX
Portland, OR
Dayton, OH
Port Chester, NY
San Francisco, CA
Cincinnati, OH
Atlanta, GA
Philadelphia, PA
Saint Louis, MO
Seattle, WA
Hartsville, SC
Diboll, TX
Houston, TX
Wayne, NJ
New York, NY
Tacoma, WA
Portland, OR
SIC Codes
Reported
2611,2621
2621,2671,2679
2611,2621
2621
2611,2621
2631
2621
2621
2611
2631
2657,2631
2631
2611
2621
2621,2611
2611
2631
2611,2621
2631
2611,2621,2676
2631
2611,2621
2631
2611,2621
2631,2655
2631
2631
2621
2621
2611,2621,2631
2611,2621
Number of
Participating
Facilities
6
1
2
6
2
2
1
3
13
1
1
13
3
7
2
1
4
1
3
3
2
6
3
3
1
3
3
4
4
5
3
1993
Releases and
Transfers
(Ibs)
866,153
12,000
238,409
1,356,355
252,940
1,197,941
1,001,714
381,712
2,722,182
4,730
164,345
2,784,831
735,332
961,588
488,160
294,823
163,512
149,405
276,643
612,520
70,161
1,288,876
721,549
749,525
621,380
166,410
1,272,423
835,696
877,866
1,006,356
677,090
%
Reduction
1988 to
1993
50
19
30
49
33
50
***
50
50
50
47
50
7
53
50
50
*
*
60
*
50
50
***
50
1
50
8
50
50
*
34
* » not quantifiable against 1988 data. ** = use reduction goal only. *** = no numerical goal.
Source: U.S. EPA, Toxics Re ease Inventory, 1993. 1
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Environmental Leadership Program
Project XL
The Environmental Leadership Program (ELP) is a national initiative piloted
by EPA and state agencies in which facilities have volunteered to
demonstrate innovative approaches to environmental management and
compliance. EPA has selected 12 pilot projects out of 40 applicants at
industrial facilities and federal installations which will demonstrate the
principles of the ELP program, hi return for participating, pilot participants
receive public recognition and are given a period of time to correct any
violations discovered during these experimental projects. The information
collected from the pilot ELP programs will be used to develop a full-scale
ELP program. Two pulp and paper companies (Simpson Tacoma Kraft
Company of Tacoma, WA and International Paper of Mansfield, LA)
submitted proposals. The Simpson Tacoma Kraft Company was selected to
participate in the pilot program. The company is an integrated pulp and
paper mill employing 560 that produces natural and bleached pulp, kraft
paper, and bleached kraft paper used primarily in the production of food and
industrial grade packaging products. Their proposal included 1) mechanism
to share audit information and conduct self-audits, 2) development of
incentives for company to go beyond compliance, 3) development of a new
approach to measure beyond compliance and pollution prevention efforts,
and 4) implementation of an "Adopt a Supplier" program. (Contact: Maria
Eisemann, (202) 564-7016, fax (202) 564-0050). Other proposals are
available for review from the Environmental Leadership Program.(Contact:
Tai-ming Chang, ELP Director, 202-564-5081 or Robert Fentress 202-564-
7023.).
Project XL was initiated in March 1995 as a part of President Clinton's
Reinventing Environmental Regulation initiative. The projects seek to
achieve cost effective environmental benefits by allowing participants to
replace or modify existing regulatory requirements on the condition that they
produce greater environmental benefits. EPA and program participants will
negotiate and sign a Final Project Agreement, detailing specific objectives
that the regulated entity shall satisfy. In exchange, EPA will allow the
participant a certain degree of regulatory flexibility and may seek changes in
underlying regulations or statutes. Participants are encouraged to seek
stakeholder support from local governments, businesses, and environmental
groups. EPA hopes to implement fifty pilot projects in four categories
including facilities, sectors, communities, and government agencies regulated
by EPA. Applications will be accepted on a rolling basis and projects will
move to implementation within six months of their selection. For additional
information regarding XL Projects, including application procedures and
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criteria, see the May 23,1995 Federal Register Notice, or contact Jon Kessler
at EPA's Office of Policy Analysis (202) 260-4034.
Green Lights Program
EPA's Green Lights program was initiated in 1991 and has the goal of
preventing pollution by encouraging U.S. institutions to use energy-efficient
lighting technologies. The program has over 1,500 participants which
include major corporations; small and medium sized businesses; federal, state
and local governments; non-profit groups; schools; universities; and health
care facilities. Each participant is required to survey their facilities and
upgrade lighting wherever it is profitable. EPA provides technical assistance
to the participants through a decision support software package, workshops
and manuals, and a financing registry. EPA's Office of Air and Radiation is
responsible for operating the Green Lights Program. (Contact: Maria Tikoff
202-233-9178 or the Green Light/Energy Star Hotline at 202-775-6650)
WasteWi$e Program
The WasteWiSe 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
1994, the program had about 300 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$e logo
for promotional purposes. The pulp and paper company Georgia-Pacific is
a WasteWi$e participant. (Contact: Lynda Wynn 202-260-0700 or the
WasteWi$e Hotline at 800-372-9473)
Climate Wise Recognition Program
The Climate Change Action Plan was initiated in response to the U.S.
commitment to reduce greenhouse gas emissions in accordance with the
Climate Change Convention of the 1990 Earth Summit. As part of the
Climate Change Action Plan, the Climate Wise Recognition Program is a
partnership initiative run jointly by EPA and the Department of Energy. The
program is designed to reduce greenhouse gas emissions by encouraging
reductions across all sectors of the economy, encouraging participation in the
full range of Climate Change Action Plan initiatives, and fostering
innovation. Participants in the program are required to identify and commit
to actions that reduce greenhouse gas emissions. The program, in turn, gives
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NICE3
organizations early recognition for their reduction commitments; provides
technical assistance through consulting services, workshops, and guides; and
provides access to the program's centralized information system. Currently,
the pulp and paper company Georgia-Pacific is a Climate Wise participant.
At EPA, the program is operated by the Air and Energy Policy Division
within the Office of Policy Planning and Evaluation. (Contact: Pamela
Herman 202-260-4407)
The U.S. Department of Energy and EPA's Office of Pollution Prevention
are jointly administering 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
pulp and paper, chemicals, primary metals, and petroleum and coal products
sectors. A project with a pulp and paper facility in California focused on
increasing the amount of post consumer waste (PCW) used hi the production
of the paper pallets used for freight transport. The company, Damage
Protection Products, will develop a 40 percent PCW pallet product and
demonstrate continuous production for 5 days. Every ton of PCW that is
substituted for wood fiber in this process decreases water use by 50 percent,
energy use by 60 percent, reduces wastewater production by 35 percent and
air pollution by 74 percent. (Contact: Bill Ives, DOE's Golden Field Office
303-275-4755).
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State and Local initiatives
Exhibit 38: Contacts for State and Local Initiatives
State
Alabama
California
Colorado
Florida
Indiana
Iowa
Kentucky
Maine
Massachusetts
Michigan
New Hampshire
New Jersey
New Mexico
North Carolina
Ohio
Oregon
Rhode Island
South Carolina
Washington
Program
AL Dept. of Env. Management, Ombudsman
and Small Business Assistance
AL WRATT Foundation
County Sanitation Districts of LA
Region VIII HW Minimization Program
FL Dept. of Env. Protection, Small Business
Assistance Program
IN Dept. of Env. Mgmt.
IA Dept. of Natural Resources
KY Partners, State Waste Reduction Center
ME Dept. of Env. Protection
ME Waste Mgmt. Agency
Northeast States Pollution Prevention
Roundtable, Northeast Waste Management
Officials' Association (NEWMOA)
Toxics Use Reduction Institute
University of Detroit Mercy
NH Small Business Technical and Env.
Compliance Assistance Program
NJ Technical Assistance Program for
Industrial Pollution Prevention (NJTAP)
Waste Management Education and Research
Consortium
NC State University
Institute of Advanced Manufacturing
Sciences
OR Dept. of Env. Quality, Air Quality Small
Business Assistance Program
RI Center for P2, URI
Southeast Manufacturing Technology Center
(SMTC)
WA State Dept. of Ecology
Contact
Blake Roper,
Michael Sherman
Roy Nicholson
Mischelle Mische
Marie Zanowich
Joe Schlessel
Tom Neltner
Larry Gibson
Joyce St. Clair
Ronald Dyer
Gayle Briggs
Terri Goldberg
Janet Clark
Daniel Klempner
Rudolph Cartier Jr.
Kevin Gashlin
Ron Bhada
Michael Overcash
Harry Stone,
Sally Clement
John MacKellar
Terry Obteshka
Stanley Barnett
Jim Bishop
Peggy Morgan
Telephone
(800) 533-2336
(205)271-7861
(205) 386-3633
(310)699-7411
(303) 294-1065
(904)488-1344
(317)232-8172
(515)281-8941
(502) 852-7260
(207)287-2811
(207) 287-5300
(617) 367-8558
(508) 934-3346
(313)993-3385
(603) 271-1370
(201) 596-5864
(505)646-1510
(919)515-2325
(513)948-2050
(503) 229-6828,
(503) 229-5946
(401) 792-2443
(803) 252-6976
(206) 407-6705
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Exhibit 38: Contacts for State and Local Initiatives
State
West Virginia
Wisconsin
Program
WV Div. of Env. Protection, Office of Water
Resources, P2 Services
WI Dept. of Development, Small Business
Assistance
Contact
Barbara Taylor
Dennis Leong,
Phil Albert
Telephone
(304) 256-6850
(608) 266-9869,
(608) 266-3075
VIII.B. Trade Association/Industry Sponsored Activities
VIII.B.l. Environmental Programs
Global Environmental Management Initiative
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 1994, GEMI's
membership consisted of about 30 major corporations such as the pulp and
paper company Georgia-Pacific.
50% Paper Recovery: A New Goal for a New Century
The membership of the American Forest and Paper Association (AF&PA) set
a goal to recover for recycling 50 percent of all paper used by Americans by
the year 2000. This program succeeds a voluntary program to reach a 40
percent paper recovery rate by 1995. These recovery rates were achieved in
1993, according to industry sources.
Annual Sustainable Forestry Report
In 1994, the AF&PA put a sustainable forestry initiative in place that
includes an annual report from each of its members on sustainable forestry
practices and accomplishments.
104 Mill Study
The pulp and paper industry participated voluntarily in the Five Mill Study
conducted in 1986 and in the 104 Mill Study in 1988. In 1992, API (now
American Forest and Paper Association) and the National Council of the
Paper Industry for Air and Stream Improvement (NCASI) surveyed 124
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chemical pulping facilities to determine baseline controls and components of
the MACT regulatory floor.
VIH.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) which 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
Suite 210
Washington, DC 20036
Phone: (202) 463-2700
Fax: (202) 463-2423
Members: 450
Staff: 140
Contact: Josephine Cooper,
V.P. for Environment and
Regulatory Affairs
The National Forest Products Association merged with the American Paper
Institute (API) hi 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
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 AF&PA Environmental, Health and Safety
Principles. 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 AFP A holds an annual meeting every
March in New York City.
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National Council of the Paper Industry
for Air and Stream Improvement
260 Madison Ave.
New York, NY 10016
Phone: (212) 532-9000
Fax: (212) 779-2849
Members: 100
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.
TAPPI
Technology Park/Atlanta
P.O. Box 105113
Atlanta, GA 30348
Phone:(404) 446-1400
Fax: (404) 446-6947
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
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, hi 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.
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Paper Industry Management Association
2400 E. Oakton St.
Arlington Heights, IL 60005
Phone: (708) 956-0250
Fax: (708) 956-0520
Members: 5,000
Staff: 14
Budget: $2,000,000
Contact: George J. Calimafde
The Paper Industry Management Association, or PIMA, is a professional
organization of pulp, paper mill, and paper 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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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:
Contacts8
Name
Maria Eisemann
Donald Anderson
Pamela Herman
Penny Lassiter
Debra Nicoll
Cindy Evans
Gary Stanley
Reid Miner
Program Director
Organization
U.S. EPA, Office of
Compliance
OSWER
U.S. EPA Air and
Energy Policy
Division
U.S. EPA
OW, ESAB
American Forest and
Paper Association
Department of
Commerce, Office of
Machinery, Materials
and Chemicals
National Council of
the Paper Industry
for Air and Stream
Improvement, Inc.
Telephone
202-564-7016
202-260-4796
202-260-4407
919-541-5396
202-260-5385
202-463-2582
202-482-0375
212-532-9349
Subject
Pulp and paper
industry sector lead;
pulp and paper ELP
project information
Solid waste
Climate Wise
Program
Clean Water Act
State statutes relevant
to pulp and paper
industry
Industry Statistics
Finance, international
and domestic
markets, and
production
Industry Technical
Information
g 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.
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General Profile
U.S. Industrial Outlook 1994, Department of Commerce
API, 1992, Statistics of 'Paper, Paperboard, & Wood Pulp.
Locfavood-Post's Directory of the Pulp and Paper and Allied Trades, 1995.
Institute of Paper Science and Technology on-line environmental abstracts.
Process Descriptions and Chemical Use Profiles
Richard J. Albert, "Effluent-Free Pulp Mill Possible with Existing Fiberline Equipment," Pulp &
Paper, 68(7), My 1994, pp. 83-89.
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.
Smook, G. A. Handbook for Pulp & Paper Technologists. Second edition. Vancouver: Angus Wilde
Publications, 1992.
Regulatory Profile
Federal Register, Proposed Rules, Friday December 17,1993, Part II pp. 66078-66216.
Penny Lassiter
Office of Air Quality Planning and Standards
(919)541-5396
Donald Anderson
Office of Water
(202) 260-7137
David Carver
Office of Solid Waste
(202) 260-6775
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Pollution Prevention
Pollution Prevention Technologies for the Bleached Kraft Segment of the U.S. Pulp and Paper
Industry, EPA/600/R-93/110
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.
Neil McCubbin, Costs and Benefits of Various Pollution Prevention Technologies in the Kraft Pulp
Industry, EPA-744R-93-002.
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.
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.
Supplemental Environmental Projects
Monica Becker, Nicholas Ashford, Recent Experience in Encouraging the Use of Pollution
Prevention in Enforcement Settlements, Final Report, MIT, May 1994.
Monica Becker, Nicholas Ashford, Encouraging the Use of Pollution Prevention in Enforcement
Settlements: A Handbook for EPA Regions, MIT, May 1994.
Trade Journals
American Papermaker (404) 325-9153
Board Converting News and Recycling Markets (202) 368-1225
Non Wovens Industry (201) 825-2552
Official Boards Markets (312) 93 8-23 00
Paper Age (202) 666-2262
Paperboard Packaging (800) 225-4569
Pulp and Paper (415) 905-2200
Pulp and Paper International (415) 905-2200
Recycled Paper News (703) 750-1158
TAPPIJournal (404) 446-1400
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Resource Materials
Supporting documents for the currently proposed integrated rulemaking
identify a number of research efforts and data source which were used by
EPA to characterize the pulp and paper industry and its processes and their
environmental consequences. A short summary of each is available in the
Federal Register Notice (58 FR 66092). They include:
1990 Census of Pulp and Paper Mills - Used §308 (CWA) survey to gather
technical (e.g., existing processes, performance, releases) and financial
information from 565 U.S. pulp and paper mills. Used as the primary
information source for the integrated rulemaking. Queries about state and
local regulatory requirements were included.
Swedish Studies - Summarizes a mid-1980s project to document the
biological effects of mills wastes on Baltic Sea species.
National Dioxin Study - A 1987 EPA report unexpectedly found elevated
levels of dioxin in fish tissues downstream from 57 percent of the pulp and
paper mill sites sampled. Further investigations found dioxin in wastewater
and wastewater treatment sludge from mills. Hypothesis made that chlorine
bleaching process was the source.
Five Mill Study - Cooperative effort with industry to collect detailed process
information including effluent sampling. Confirmed presence of dioxin in
wastewaters, pulps, and sludge.
104 Mill Study - Follow-up to Five Mill Study to determine extent of dioxin
formation by representative bleaching and production processes throughout
the industry.
National Study of Chemical Residues in Fish - Confirmed the pulp and paper
mills were dominant source of dioxins and furans in fish tissue.
Dioxin Risk Assessment - Results from the multiple pathway investigation are
scheduled for publication in late 1994.
September 1995
126
SIC 261 through 265
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Sector Notebook Project
Pulp and Paper Industry
End Notes
l.USEPA. 1990 National Census of Pulp. Paper, and Paperboard Manufacturing Facilities. 1990.
2. American Forest and Paper Association, 1994 Statistics. Data Through 1993. Washington,
D.C.:AF&PA, 1994.
3. American Forest and Paper Association, 1994 Statistics. Data Through 1993. Washington,
D.C.:AF&PA, 1994.
4. U.S. EPA, 1993. Effluent Limitations Guidelines, Pretreatment Standards, and New Source
Performance Standards: Pulp, Paper, and Paperboard Category; National Emission Standards for
Hazardous Air Pollutants for Source Category: Pulp and Paper Production. 40 CFR Parts 63 and
430.
5. Pollution Prevention Technologies for the Bleached Kraft Segment of the U.S. Pulp and Paper
Industry , 1993, (EPA-600-R-93-110)
6. American Forest and Paper Association, 1994 Statistics. Data Through 1993. Washington,
D.C.:AF&PA, 1994.
7. American Forest and Paper Association, 1994 Statistics. Data Through 1993. Washington,
D.C.:AF&PA, 1994.
8. U.S. Department of Commerce. U.S. Industrial Outlook: 1994. January, 1994.
9. American Forest & Paper Association. 1994.
10. USEPA. Development Document for Proposed Effluent Limitations Guidelines and Standards
for the Pulp. Paper, and Paperboard Point Source Category. October 1993.
11. AF&PA. Improving Tomorrow's Environment Today. January 1995.
12. Office of Water, Personal Communication. June, 1995.
13. USEPA. Development Document for Proposed Effluent Limitations Guidelines and Standards
for the Pulp. Paper, and Paperboard Point Source Category. October 1993.
14. American Forest and Paper Association, 1994 Statistics. Data Through 1993. Washington,
D.C.: AF&PA, 1994.
15. Smook, G.A. Handbook for Pulp & Paper Technologists. Second edition. Vancouver: Angus
Wilde Publications, 1992. '
16. Smook, G.A. Handbook for Pulp & Paper Technologists. Second edition. Vancouver: Angus
Wilde Publications, 1992.
September 1995
127
SIC 261 through 265
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Sector Notebook Project
Pulp and Paper Industry
17. USEPA. 1990 National Census of Pulp, Paper, and Paperboard Manufacturing Facilities. 1990.
18. AF&PA. Improving Tomorrow's Environment Today. January 1995.
19. AF&PA, personal communication.
20. AF&PA. Recovered Paper Deinking Facilities. American Forest and Paper Association:
Economics and Materials Department, January 1995.
21. Smook, G.A. Handbook for Pulp & Paper Technologists. Second edition. Vancouver: Angus
Wilde Publications, 1992.
22. AF&PA. Improving Tomorrow's Environment Today. January 1995.
23. American Forest and Paper Association, 1994 Statistics. Data Through 1993. Washington,
D.C.:AF&PAS 1994.
24. Thompson Avant International, Inc. Benchmarking and Documentation of Environmental
Performance in the Pulp and Paper Industry. Washington, DC.:AF&PA February, 1994.
25. U.S. EPA, 1993. Effluent Limitations Guidelines, Pretreatment Standards, and New Source
Performance Standards: Pulp, Paper, and Paperboard Category; National Emission Standards for
Hazardous Air Pollutants for Source Category: Pulp and Paper Production. 40 CFR Parts 63 and
430.
26. Pollution Prevention Technologies for the Bleached Kraft Segment of the U.S. Pulp and Paper
Industry, 1993, (EPA-600-R-93-110)
27. American Forest & Paper Association. 1994.
28. U.S. EPA. 104-Mill Study. 1988.
29. American Forest and Paper Association, 1994 Statistics. Data Through 1993. Washington,
D.C.:AF&PA, 1994.
30. American Forest & Paper Association. 1994.
September 1995
128
SIC 261 through 265
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APPENDIX A
INSTRUCTIONS FOR DOWNLOADING THIS NOTEBOOK
Electronic Access to this Notebook via the World Wide Web (WWW)
This Notebook is available on the Internet through the World Wide Web. The Enviro$en$e
Communications Network is a free, public, interagency-supported system operated by EPA's Office
of Enforcement and Compliance Assurance and the Office of Research and Development. The
Network allows regulators, the regulated community, technical experts, and the general public to
share information regarding: pollution prevention and innovative technologies; environmental
enforcement and compliance assistance; laws, executive orders, regulations, and policies; points of
contact for services and equipment; and other related topics. The Network welcomes receipt of
environmental messages, information, and data from any public or private person or organization.
ACCESS THROUGH THE ENVIRO$EN$E WORLD WIDE WEB
To access this Notebook through the EnviroSenSe World Wide Web, set your World Wide
Web Browser to the following address:
http://eS.inel.gOV/OeCa - then select "EPA Sector Notebooks"
Or after 1997, (when EPA plans to have completed a restructuring of its web site) set
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WWW.epa.gOV/OeCa - then select the button labeled Gov't and Business
The Notebook will be listed.
HOTLINE NUMBER FOR E$WWW: 208-526-6956
EPA E$WWW MANAGERS: Louis Paley 202-564-2613
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(This page updated June 1997)
Appendix A
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