Pulp and Paper Manufacturing
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Final Rule: Mandatory Reporting of Greenhouse Gases Emmentai protection
United States
Under the Mandatory Reporting of Greenhouse Gases (GHGs) rule, owners or operators of facilities that produce
pulp or paper (as defined below) and that emit 25, 000 metric tons or more of GHGs per year (expressed as carbon
dioxide equivalents but excluding biogenic carbon dioxide [CO 2]) from pulp and paper manufacturing processes,
stationary combustion, miscellaneous uses of carbonate, and other source categories (see information sheet on
General Provisions) must report emissions. These sites must 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 are required to 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?
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), or 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 co-located 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 Must Be Reported?
Pulp and paper manufacturing facilities must 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, biogenic CO2, QL,, and N2O emissions from combustion of fossil fuels in each kraft or soda pulp mill
lime kiln.
• CO2, CUt, and N2O from stationary fuel combustion units, other than chemical recovery units and lime
kilns (e.g., boilers), by following the requirements of 40 CFRpart 98, subpart C (General Stationary Fuel
Combustion Sources).
Facilities must also report GHG emissions from other source categories for which calculation methods are provided
in other parts the rule, as applicable.
How Should GHG Emissions Be Calculated?
Calculate GHG 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.
40 CFR 98, subpart AA 1 EPA-430-F-09-020R
September 2009
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• 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 HHV, and default
emission factors according to the methodology for stationary combustion sources in 40 CFR
98.33(c).
o For biomass emissions, use measured quantities of spent liquor solids fired, site-specific HHV, and
default emission factors for kraft facilities.
• Calculate CO2 emissions from the use of makeup chemicals 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, CFU, and N2O emissions from combustion 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. 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.
A checklist for data that must be monitored is available at:
www.epa.gov/climatechange/emissions/downloads/checklists/pulpandpapermanufacturing.pdf
What Information Must Be Reported?
In addition to the information required by the General Provisions at 40 CFR 98.3(c), each annual report must
include the following information:
• Annual CO2, biogenic CO2, CH4, and N2O emissions for each chemical recovery unit and each lime kiln
(metric tons per year).
• Annual quantity of fossil fuels for each chemical recovery furnace, combustion unit, and lime kiln (short
tons for solid fuels, gallons for liquid fuels, and standard cubic feet for gaseous fuels).
• Default emission factor for CO2, CH4, orN2O, used in equation AA-1 of this subpart (kg CO2, CH4, or N2O
permmBtu).
• Annual mass of spent liquor solids fired at the facility (short tons per year).
• High heat value of spent liquor solids (mmBtu per kilogram).
• Carbon content of spent liquor solids fired at sulfite and stand-alone semichemical mills (percent by
weight, expressed as a decimal fraction).
• Annual steam purchases (pounds of steam per year).
• Annual quantities of makeup chemicals (carbonates) used (metric tons).
• Total annual production of pulp and/or paper products produced (metric tons).
For More Information
This document is provided solely for informational purposes. It does not provide legal advice, have legally binding
effect, or expressly or implicitly create, expand, or limit any legal rights, obligations, responsibilities, expectations,
or benefits in regard to any person. The series of information sheets is intended to assist reporting facilities/owners
in understanding key provisions of the final rule.
Visit EPA's Web site (www.epa.gov/climatechange/emissions/ghgrulemaking.html) for more information,
including the final preamble and rule, additional information sheets on specific industries, the schedule for training
sessions, and other documents and tools. For questions that cannot be answered through the Web site, please
contact us at: ghgmrrigiepa.gov.
40 CFR 98, subpart AA 2 EPA-430-F-09-020R
September 2009
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