This document was developed for the Proposed Mandatory GHG Reporting Rule. For
the final document, please visit the final Mandatory Reporting of Greenhouse
Gases Rule.
Pulp and Paper Manufacturing
United Slates
Proposed Rule: Mandatory Reporting of Greenhouse Gases Environmental Protection
Under the proposed Mandatory Reporting of Greenhouse Gases (GHGs) rule, owners or operators
of facilities that contain pulp and paper processes (as defined below) and that emit 25,000 metric
tons of GHGs per year or more (expressed as carbon dioxide equivalents [CO26] and excluding
biogenic carbon dioxide [CO 2]) from stationary combustion, miscellaneous use of carbonates and
other source categories (see information sheet on General Provisions) would report emissions from
pulp and paper processes and all source categories located at the facility for which calculation
methods are defined in the rule. Owners or operators would collect emission data; calculate GHG
emissions; and follow the specified procedures for quality assurance, missing data, recordkeeping,
and reporting.
How Is This Source Category Defined?
Under the proposal, this source category consists of facilities that produce market pulp (i.e., stand-alone pulp
facilities), manufacture pulp and paper (i.e., integrated mills), produce paper products from purchased pulp,
produce secondary fiber from recycled paper, convert paper into paperboard products (e.g., containers), and
operate coating and laminating processes.
This source category consists of the following processes:
• Chemical recovery furnaces at kraft and soda mills (including recovery furnaces that burn spent
pulping liquor produced by both the kraft and collocated semichemical process).
• Chemical recovery combustion units at sulfite mills.
• Chemical recovery combustion units at stand-alone semichemical mills.
• Systems for adding makeup chemicals (calcium carbonate [CaCO3], sodium carbonate [Na2CO3]).
• Lime kilns at kraft and soda pulp mills.
What GHGs Would Be Reported?
The proposal calls for pulp and paper manufacturing facilities to report:
• CO2, biogenic CO2, methane (CFL,), and nitrous oxide (N2O) emissions from each chemical recovery
furnace at kraft or soda mills and from each chemical recovery combustion unit at sulfite or stand-
alone semichemical mills.
• CO2 emissions from addition of makeup chemicals.
• CO2, CUt, and N2O emissions from combustion of fossil fuels in each kraft or soda pulp mill lime
kiln.
• CO2, CFL,, N2O, and biogenic CO2 emissions from stationary fuel combustion units, other than
chemical recovery units and lime kiln (e.g., boilers), by following the requirements of 40 CFRpart
98, subpart C (General Stationary Fuel Combustion Sources).
• CFL, from onsite landfills by following the requirements of 40 CFR part 98, subpart FiH (Landfills).
• CFL, from onsite wastewater treatment systems by following the requirements of 40 CFR part 98,
subpart II (Wastewater Treatment).
How Would GHG Emissions Be Calculated?
March 2009 1 EPA-430-F-09-020
-------
This document was developed for the Proposed Mandatory GHG Reporting Rule. For
the final document, please visit the final Mandatory Reporting of Greenhouse
Gases Rule.
Under the proposal, owners or operators of pulp and paper manufacturing facilities would calculate
emissions as follows:
• Calculate CO2 emissions from fossil fuels used in chemical recovery furnaces using direct
measurement of fossil fuels consumed and default emission factors according to the Tier 1
methodology for stationary combustion sources in 40 CFR part 98, subpart C.
• Calculate biogenic CO2 emissions from combustion of biomass in spent pulping liquor using:
o Measured quantities of spent liquor solids fired, site-specific high heating value (HHV), and
default or site-specific emission factors for each chemical recovery furnace located at kraft
or soda facilities.
o Measured quantities of spent liquor solids fired and the carbon content of the spent liquor
solids for each chemical recovery unit at sulfite or stand-alone semichemical facilities.
• Calculate QrU and N2O emissions as the sum of emissions from the combustion of fossil fuels and
the combustion of biomass in spent pulping liquor, as follows:
o For fossil fuel emissions, use direct measurement of fuels consumed, a default FiFfV, and
default emission factors according to the methodology for stationary combustion sources in
40CFR98.33(c)(2)and(3).
o For biomass emissions, use measured quantities of spent liquor solids fired and a default
emission factors for spent pulping liquor combustion according to the methodology for
stationary combustion sources in 40 CFR 98.2(b)(3).
• Calculate CO2 emissions from the use of makeup chemicals in lime kilns, using direct or indirect
measurement of the quantity of chemicals added and ratios of the molecular weights of CO2 and the
makeup chemicals.
• Calculate CO2, CFi4, and N2O emissions from combustion1 of fossil fuels in lime kilns using direct
measurement of fossil fuels consumed and default emission factors and heating values found in 40
CFR part 98, subpart C.
What Information Would Be Reported?
In addition to the information required by the General Provisions at 40 CFR 98.3(c), the proposal calls for
each annual report to include the following information:
• CO2, biogenic CO2, CFI4, and N2O emission estimates presented by calendar quarters for each
chemical recovery unit, each lime kiln, and all makeup chemicals.
• Consumption of all biomass fuels by calendar quarter.
• Quantity of spent liquor solids fired at the facility by calendar quarter.
• Annual steam purchases.
• Annual quantities of makeup chemicals (carbonates) used.
For More Information
This series of information sheets is intended to assist reporting facilities/owners in understanding key
provisions of the proposed rule. However, these information sheets are not intended to be a substitution for
the rule. Visit EPA's Web site (www.epa.gov/climatechange/emissions/ghgrulemaking.html) for more
information, including the proposed preamble and rule and additional information sheets on specific
1 Biogenic CO2 from the conversion of CaCO3 to CaO in kraft or soda pulp mill lime kilns is accounted for
in the biogenic CO2 emission factor for the recovery furnace.
March 2009 2 EPA-430-F-09-020
-------
This document was developed for the Proposed Mandatory GHG Reporting Rule. For
the final document, please visit the final Mandatory Reporting of Greenhouse
Gases Rule.
industries, or go to to access the rulemaking docket (EPA-HQ OAR-2008-0508).
For questions that cannot be answered through the Web site or docket, call 1-877-GHG-l 188.
March 2009 3 EPA-430-F-09-020
------- |