Pulp and Paper Industry Sector Notebook Project 

EPA/310-R-02-002

EPA Office of Compliance Sector Notebook Project 

Profile of the Pulp and Paper Industry 

2nd Edition 

November 2002 

Office of Compliance

Office of Enforcement and Compliance Assurance

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, NW (MC 2224-A)

Washington, DC 20460
Pulp and Paper Industry Sector Notebook Project 

This report is one in a series of volumes published by the U.S. Environmental Protection Agency 

(EPA) to provide information of general interest regarding environmental issues associated with 

specific industrial sectors. The documents were developed under contract by Abt Associates 

(Cambridge, MA), GeoLogics Corporation (Alexandria, VA), Science Applications International 

Corporation (McLean, VA), and Booz-Allen & Hamilton, Inc. (McLean, VA). A listing of available 

Sector Notebooks is included on the following page. 

Obtaining copies: 

Electronic versions of all sector notebooks are available on the EPA’s website at: 

www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/. 

Purchase printed bound copies from the Government Printing Office (GPO) by consulting the 

order form at the back of this document or order via the Internet by visiting the U.S. Government 

Online Bookstore at: http://bookstore.gpo.gov/. Search using the exact title of the document “Profile 

of the XXXX Industry” or simply “Sector Notebook.” When ordering, use the GPO document 

number found in the order form at the back of this document. 

A limited number of complimentary volumes are available to certain groups or subscribers, 

including public and academic libraries; federal, state, tribal, and local governments; and the media 

from EPA’s National Service Center for Environmental Publications at 800-490-9198 or 

www.epa.gov/ncepihom. When ordering, use the EPA publication number found on the following 

page. 

The Sector Notebooks were developed by the EPA’s Office of Compliance. Direct general 

questions about the Sector Notebook Project to: 

Coordinator, Sector Notebook Project

US EPA Office of Compliance

1200 Pennsylvania Ave., NW (2224-A)

Washington, DC 20460

202-564-2310

For further information, and for answers to questions pertaining to these documents, please refer to 

the contacts listed on the following page. 

Sector Notebook Project ii November 2002 
Pulp and Paper Industry Sector Notebook Project 

AVAILABLE SECTOR NOTEBOOKS 

Questions and comments regarding the individual documents should be directed to Compliance Assistance 

and Sector Programs Division at 202 564-2310 unless otherwise noted below. See the Notebook web page 

at: http://www.epa.gov/compliance/resources/publications/assistance/sectors/notebooks/ for the most 

recent titles and links to refreshed data. 

EPA Publication 

Number Industry 

EPA/310-R-95-001. Profile of the Dry Cleaning Industry

EPA/310-R-95-002. Profile of the Electronics and Computer Industry*

EPA/310-R-95-003. Profile of the Wood Furniture and Fixtures Industry

EPA/310-R-95-004. Profile of the Inorganic Chemical Industry*

EPA/310-R-95-005. Profile of the Iron and Steel Industry

EPA/310-R-95-006. Profile of the Lumber and Wood Products Industry

EPA/310-R-95-007. Profile of the Fabricated Metal Products Industry*

EPA/310-R-95-008. Profile of the Metal Mining Industry

EPA/310-R-95-009. Profile of the Motor Vehicle Assembly Industry

EPA/310-R-95-010. Profile of the Nonferrous Metals Industry

EPA/310-R-95-011. Profile of the Non-Fuel, Non-Metal Mining Industry

EPA/310-R-02-001. Profile of the Organic Chemical Industry, 2nd Edition*

EPA/310-R-95-013. Profile of the Petroleum Refining Industry

EPA/310-R-95-014. Profile of the Printing Industry

EPA/310-R-02-002. Profile of the Pulp and Paper Industry, 2nd Edition

EPA/310-R-95-016. Profile of the Rubber and Plastic Industry

EPA/310-R-95-017. Profile of the Stone, Clay, Glass, and Concrete Ind.

EPA/310-R-95-018. Profile of the Transportation Equipment Cleaning Ind.

EPA/310-R-97-001. Profile of the Air Transportation Industry

EPA/310-R-97-002. Profile of the Ground Transportation Industry

EPA/310-R-97-003. Profile of the Water Transportation Industry

EPA/310-R-97-004. Profile of the Metal Casting Industry

EPA/310-R-97-005. Profile of the Pharmaceuticals Industry

EPA/310-R-97-006. Profile of the Plastic Resin and Man-made Fiber Ind.

EPA/310-R-97-007. Profile of the Fossil Fuel Electric Power Generation Industry 

EPA/310-R-97-008. Profile of the Shipbuilding and Repair Industry

EPA/310-R-97-009. Profile of the Textile Industry

EPA/310-R-97-010. Sector Notebook Data Refresh-1997 **

EPA/310-R-98-001. Profile of the Aerospace Industry

EPA/310-R-00-001. Profile of the Agricultural Crop Production Industry

Contact: Ag Center, (888) 663-2155

EPA/310-R-00-002. Profile of the Agricultural Livestock Production Industry

Contact: Ag Center, (888) 663-2155

EPA/310-R-00-003. Profile of the Agricultural Chemical, Pesticide and Fertilizer Industry

Contact: Agriculture Division, 202 564-2320

EPA/310-R-00-004. Profile of the Oil and Gas Extraction Industry

Government Series 

EPA/310-R-99-001. Profile of Local Government Operations

* Spanish translations available of 1st Editions in electronic format only. 

** This document revises compliance, enforcement, and toxic release inventory data for all previously published

profiles. Visit the Sector Notebook web page to access the most current data.

Sector Notebook Project iii November 2002 
Pulp and Paper Industry Sector Notebook Project 

DISCLAIMER

This Sector Notebook was created for employees of the U.S. Environmental Protection Agency 

(EPA) and the general public for informational purposes only. This document has been extensively 

reviewed by experts from both inside and outside the EPA, but its contents do not necessarily reflect 

the views or policies of EPA or any other organization mentioned within. Mention of trade names 

or commercial products or events does not constitute endorsement or recommendation for use. In 

addition, these documents are not intended and cannot be relied upon to create any rights, 

substantive or procedural, enforceable by any party in litigation with the United States. 

Sector Notebook Project iv November 2002 
Pulp and Paper Industry Sector Notebook Project 

Pulp and Paper Industry 

(SIC 2611 through 2631) 

TABLE OF CONTENTS 

LIST OF ACRONYMS ....................................................... viii

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT .......................1

A. Summary of the Sector Notebook Project ..................................1

B. Additional Information .................................................2

II. INTRODUCTION TO THE PULP AND PAPER INDUSTRY .......................3

A. Introduction, Background, and Scope of the Notebook ........................3

B. Characterization of the Pulp and Paper Industry .............................6

1. Product Characterization ..........................................6

2. Industry Size and Geographic Distribution ...........................9

3. Economic Trends ..............................................11

III. INDUSTRIAL PROCESS DESCRIPTION .....................................15

A. Industrial Processes in the Pulp and Paper Industry .........................15

1. Pulp Manufacture ..............................................18

2. Pulp Processing ................................................25

3. Bleaching ....................................................30

4. Stock Preparation ..............................................33

5. Processes in Paper Manufacture ...................................33

6. Energy Generation .............................................34

B. Raw Material Inputs and Pollution Outputs in the Production Line .............35

IV. CHEMICAL RELEASE AND OTHER WASTE MANAGEMENT PROFILE .........45

A. EPA Toxics Release Inventory For the Pulp and Paper Industry ...............48

B. Summary of Selected Chemicals Released ................................54

C. Other Data Sources ..................................................57

D. Comparison of Toxic Release Inventory Between Selected Industries ...........59

V. POLLUTION PREVENTION OPPORTUNITIES ................................62

VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS ...................68

A. General Description of Major Statutes ...................................68

B. Industry Specific Requirements .........................................85

C. Pending and Proposed Regulatory Requirements ...........................93

Sector Notebook Project v November 2002 
Pulp and Paper Industry Sector Notebook Project 

VII. COMPLIANCE AND ENFORCEMENT HISTORY .............................95

A. Pulp and Paper Industry Compliance History ..............................99

B. Comparison of Enforcement Activity Between Selected Industries ............101

C. Review of Major Legal Actions ........................................106

1. Review of Major Cases .........................................106

2. Supplementary Environmental Projects ............................108

VIII. COMPLIANCE ACTIVITIES AND INITIATIVES ...........................110

A. Sector-Related Environmental Programs and Activities .....................110

B. Trade Association/Industry Sponsored Activities ..........................114

1. Environmental Programs .......................................114

2. Summary of Trade Associations ..................................116

IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY 119

Sector Notebook Project vi November 2002 
Pulp and Paper Industry Sector Notebook Project 

LIST OF FIGURES 

Figure 1: Pulp Production, 2000 ..................................................8

Figure 2: Employment and Value of Shipments in the Paper and Allied Products Industry ...10

Figure 3: Geographic Distribution of Pulp, Paper, and Paperboard Mills ..................10

Figure 4: Capital Improvements at Pulp and Paper Mills ..............................13

Figure 5: Paper Recovery Rates ..................................................14

Figure 6: Simplified Flow Diagram: Integrated Mill ..................................17

Figure 7: Kraft Pulping Process (with Chemical Recovery) ............................29

Figure 8: Typical Bleach Plant ..................................................32

Figure 9: Fourdrinier Paper Machine ..............................................34

Figure 10: Kraft Process Flow Diagram ...........................................43

Figure 11: Air Pollutant Output from Kraft Process ..................................44

Figure 12: 2000 Summary of TRI Releases and Transfers by Industry ...................60

LIST OF TABLES 

Table 1: SIC and NAICS Codes ..................................................5

Table 2: Description of Pulping Processes ..........................................6

Table 3: Size of Paper and Allied Products Facilities ..................................9

Table 4: Major Pulp and Paper Mergers and Acquisitions .............................12

Table 5: General Classification of Wood Pulping Processes ...........................18

Table 6: Pulp Manufacturing Process Sequence .....................................19

Table 7: Relative Wastepaper Usage as Secondary Fiber in 1999 .......................21

Table 8: Common Chemicals Used in Elemental Chlorine Free (ECF) and Total Chlorine Free

(TCF) Bleaching Processes ...............................................31

Table 9: Paper and Paperboard Making Process .....................................33

Table 10: Estimated Energy Sources for the U.S. Pulp and Paper Industry ................35

Table 11: Potential Water Pollutants From Pulp and Paper Processes ....................37

Table 12: Common Air Pollutants From Pulp and Paper Processes ......................38

Table 13: Kraft Chemical Pulped Bleached Paper Production ..........................41

Table 14: 2000 TRI Releases for Pulp and Paper Facilities ............................50

Table 15: 2000 TRI Transfers for Pulp and Paper Facilities ............................52

Table 16: Ten Largest Volume TRI Releasing Facilities in the Pulp and Paper Industry ......54

Table 17: Air Pollutant Releases by Industry Sector (tons/year) ........................58

Table 18: Toxics Release Inventory Data for Selected Industries ........................61

Table 19: Applicability of Clean Water Act Requirements .............................89

Table 20: Five-Year Enforcement and Compliance Summary for the Pulp and Paper Industry,

by Region ......................................................100

Table 21: Five-Year Enforcement and Compliance Summary for Selected Industries ......102

Table 22: Two-Year Enforcement and Compliance Summary for Selected Industries .......103

Table 23: Five-Year Inspection and Enforcement Summary by Statute for Selected Industries104

Table 24: Two-Year Inspection and Enforcement Summary by Statute for Selected Industries 105

Table 25: FY-1996-1999 Supplemental Environmental Projects Overview ...............109

Sector Notebook Project vii November 2002 
Pulp and Paper Industry Sector Notebook Project 

LIST OF ACRONYMS

AFS AIRS Facility Subsystem (CAA database)

AIRS Aerometric Information Retrieval System (CAA database)

AOR Area of Review (SDWA)

AOX Adsorbable Organic Halides

BAT Best Available Technology Economically Achievable

BCT Best Conventional Pollutant Control Technology

BIFs Boilers and Industrial Furnaces (RCRA)

BMP Best Management Practice

BOD Biochemical Oxygen Demand 

BPT Best Practicable Technology Currently Available

CAA Clean Air Act

CAAA Clean Air Act Amendments of 1990

CERCLA Comprehensive Environmental Response, Compensation and Liability Act

CERCLIS CERCLA Information System

CFCs Chlorofluorocarbons

CFR Code of Federal Regulations

CGP Construction General Permit (CWA)

CO Carbon Monoxide 

CO2 Carbon Dioxide

COD Chemical Oxygen Demand 

CSI Common Sense Initiative 

CWA Clean Water Act

CZMA Coastal Zone Management Act

D&B Dun and Bradstreet Marketing Index

DOC United States Department of Commerce

EIS Environmental Impact Statement

EPA United States Environmental Protection Agency

EPCRA Emergency Planning and Community Right-to-Know Act 

ESA Endangered Species Act

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FINDS Facility Indexing System

FR Federal Register

FRP Facility Response Plan

HAPs Hazardous Air Pollutants (CAA)

HSDB Hazardous Substances Data Bank

HSWA Hazardous and Solid Waste Amendments

IDEA Integrated Data for Enforcement Analysis

LDR Land Disposal Restrictions (RCRA)

LEPCs Local Emergency Planning Committees 

MACT Maximum Achievable Control Technology (CAA)

MCLGs Maximum Contaminant Level Goals 

MCLs Maximum Contaminant Levels 

MEK Methyl Ethyl Ketone

MSDSs Material Safety Data Sheets 

Sector Notebook Project viii November 2002 
Pulp and Paper Industry Sector Notebook Project 

MSGP Multi-Sector General Permit (CWA)

NAAQS National Ambient Air Quality Standards (CAA)

NAFTA North American Free Trade Agreement

NAICS North Americal Industrial Classification System

NCDB National Compliance Database (for TSCA, FIFRA, EPCRA)

NCP National Oil and Hazardous Substances Pollution Contingency Plan 

NEC Not Elsewhere Classified

NEIC National Enforcement Investigation Center 

NEPA National Environmental Policy Act

NESHAP National Emission Standards for Hazardous Air Pollutants

NICE3 National Industrial Competitiveness Through Energy, Environment and Economics

NO2 Nitrogen Dioxide

NOI Notice of Intent

NOT Notice of Termination

NOV Notice of Violation 

NOx Nitrogen Oxides 

NPDES National Pollution Discharge Elimination System (CWA)

NPL National Priorities List 

NRC National Response Center 

NSPS New Source Performance Standards (CAA)

OAQPS Office of Air Quality Planning and Standards

OAR Office of Air and Radiation

OECA Office of Enforcement and Compliance Assurance

OMB Office of Management and Budget

OPA Oil Pollution Act

OPPTS Office of Prevention, Pesticides, and Toxic Substances

OSHA Occupational Safety and Health Administration 

OSW Office of Solid Waste

OSWER Office of Solid Waste and Emergency Response

OW Office of Water

P2 Pollution Prevention

PCS Permit Compliance System (CWA Database)

PM10 Particulate Matter of 10 microns or less

PMN Premanufacture Notice

POTW Publicly Owned Treatments Works 

PSD Prevention of Significant Deterioration (CAA)

PT Total Particulates

RCRA Resource Conservation and Recovery Act

RCRIS RCRA Information System

RQ Reportable Quantity (CERCLA)

SARA Superfund Amendments and Reauthorization Act 

SDWA Safe Drinking Water Act

SEPs Supplementary Environmental Projects 

SERCs State Emergency Response Commissions 

SIC Standard Industrial Classification 

SIP State Implementation Plan

Sector Notebook Project ix November 2002 
Pulp and Paper Industry Sector Notebook Project 

SO2 Sulfur Dioxide 

SOx Sulfur Oxides

SPCC Spill Prevention Control and Countermeasures

STEP Strategies for Today’s Environmental Partnership

SWPPP Storm Water Pollution Prevention Plan (CWA)

TOC Total Organic Carbon 

TRI Toxic Release Inventory

TRIS Toxic Release Inventory System

TCRIS Toxic Chemical Release Inventory System

TSCA Toxic Substances Control Act

TSD Treatment Storage and Disposal

TSP Total Suspended Particulates

TSS Total Suspended Solids 

UIC Underground Injection Control (SDWA)

USDW Underground Sources of Drinking Water (SDWA)

UST Underground Storage Tanks (RCRA)

VOCs Volatile Organic Compounds

Sector Notebook Project x November 2002 
Pulp and Paper Industry Sector Notebook Project 

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 an important supplement to traditional single-media approaches to 

environmental protection. Environmental regulatory agencies are beginning 

to embrace comprehensive, multi-statute solutions to facility permitting, 

compliance assurance, education/outreach, research, and regulatory 

development issues. The central concepts driving the new policy direction 

are that pollutant releases to each environmental medium (air, water and 

land) affect each other, and that environmental strategies must actively 

identify and address these interrelationships by designing policies for the 

"whole" facility. One way to achieve a whole facility focus is to design 

environmental policies for similar industrial facilities. By doing so, 

environmental concerns that are common to the manufacturing of similar 

products can be addressed in a comprehensive manner. Recognition of the 

need to develop the industrial ?sector-based” approach within the EPA Office 

of Compliance led to the creation of this document. 

The Sector Notebook Project was initiated by the Office of Compliance 

within the Office of Enforcement and Compliance Assurance (OECA) to 

provide its staff and managers with summary information for eighteen 

specific industrial sectors. As other EPA offices, states, the regulated 

community, environmental groups, and the public became interested in this 

project, the scope of the original project was expanded. The ability to design 

comprehensive, common sense environmental protection measures for 

specific industries is dependent on knowledge of several interrelated topics. 

For the purposes of this project, the key elements chosen for inclusion are: 

general industry information (economic and geographic); a description of 

industrial processes; pollution outputs; pollution prevention opportunities; 

federal statutory and regulatory framework; compliance history; and a 

description of partnerships that have been formed between regulatory 

agencies, the regulated community and the public. 

For any given industry, each topic listed above could alone be the subject of 

a lengthy volume. However, in order to produce a manageable document, 

this project focuses on providing summary information for each topic. This 

format provides the reader with a synopsis of each issue, and references 

where more in-depth information is available. Text within each profile was 

researched from a variety of sources, and was usually condensed from more 

detailed sources pertaining to specific topics. This approach allows for a 

wide coverage of activities that can be further explored based upon the 

references listed at the end of this profile. As a check on the information 

Sector Notebook Project 1 November 2002 
Pulp and Paper Industry Sector Notebook Project 

included, each notebook went through an external document review process. 

The Office of Compliance appreciates the efforts of all those that participated 

in this process and enabled us to develop more complete, accurate and up-todate summaries. Many of those who reviewed this notebook are listed as 

contacts in Section IX and may be sources of additional information. The 

individuals and groups on this list do not necessarily concur with all 

statements within this notebook. 

I.B. Additional Information 

Providing Comments 

OECA’s Office of Compliance plans to periodically review and update the 

notebooks and will make these updates available both in hard copy and 

electronically. If you have any comments on the existing notebook, or if you 

would like to provide additional information, please send a hard copy and 

computer disk to the EPA Office of Compliance, Sector Notebook Project 

(2224-A), 1200 Pennsylvania Ave., NW, Washington, DC 20460. Comments 

can also be sent via the Sector Notebooks web page at: 

http://www.epa.gov/compliance/resources/publications/assistance/sectors/ 

notebooks/. If you are interested in assisting in the development of new 

Notebooks, or if you have recommendations on which sectors should have 

a Notebook, please contact the Office of Compliance at 202-564-2310. 

Adapting Notebooks to Particular Needs 

The scope of the industry sector described in this notebook approximates the 

national occurrence of facility types within the sector. In many instances, 

industries within specific geographic regions or states may have unique 

characteristics that are not fully captured in these profiles. The Office of 

Compliance encourages state and local environmental agencies and other 

groups to supplement or re-package the information included in this 

notebook to include more specific industrial and regulatory information that 

may be available. Additionally, interested states may want to supplement the 

"Summary of Applicable Federal Statutes and Regulations" section with state 

and local requirements. Compliance or technical assistance providers may 

also want to develop the "Pollution Prevention" section in more detail. 

Sector Notebook Project 2 November 2002 
Pulp and Paper Industry Introduction, Background, and Scope 

II. INTRODUCTION TO THE PULP AND PAPER INDUSTRY 

This section provides background information on the size, geographic 

distribution, employment, production, sales, and economic condition of the 

pulp and paper industry. Facilities described within the document are also 

described in terms of their Standard Industrial Classification (SIC) codes. 

II.A. Introduction, Background, and Scope of the Notebook 

The paper and allied products industry (SIC 26) comprises two types of 

facilities: pulp and paper mills that process raw wood fiber or recycled fiber 

to make pulp and/or paper, and converting facilities that use these primary 

materials to manufacture more specialized products such as paperboard 

boxes, writing paper, and sanitary paper. Portions of this notebook present 

information for all of SIC 26, but the notebook focuses primarily on the 

greatest areas of environmental concern within the industry: those from 

pulpmaking processes. Converting facilities are not discussed, and the 

papermaking stage of the pulp and paper process is de-emphasized. 

The specific industry components covered in this industry are the following: 

SIC 2611. Pulp mills. Pulp mills separate the fibers of wood or from 

other materials, such as rags, linters, wastepaper, and straw in order 

to create pulp. Mills may use chemical, semi-chemical, or mechanical 

processes, and may create co-products such as turpentine and tall oil. 

This SIC code does not include pulpmaking facilities that are part of 

an integrated paper or paperboard facility; those would be 

categorized according to the appropriate final product. The following 

are types of pulp mills included in this SIC code: 

• Deinking of newsprint 

• Fiber pulp: made from wood, rags, wastepaper, linters, straw, 

and bagasse 

• Pulp mills 

• Pulp: soda, sulfate, sulfite, groundwood, rayon, and 

semichemical 

• Rayon pulp 

• Wood pulp 

SIC 2621. Paper mills. Paper mills primarily are engaged in 

manufacturing paper from woodpulp and other fiber pulp, and may 

also manufacture converted paper products. Establishments primarily 

engaged in integrated operations of producing pulp and 

manufacturing paper are included in this industry if primarily 

shipping paper or paper products. Establishments primarily engaged 

Sector Notebook Project 3 November 2002 
Pulp and Paper Industry Introduction, Background, and Scope 

in manufacturing converted paper products from purchased paper 

stock are classified in Industry Group 265 or Industry Group 267. 

SIC 2631. Paperboard mills. Establishments in this SIC code 

primarily are engaged in manufacturing paperboard, including 

paperboard coated on the paperboard machine, from wood pulp and 

other fiber pulp; and may also manufacture converted paperboard 

products. Establishments primarily engaged in manufacturing 

converted paperboard products from purchased paperboard are 

classified in Industry Group 265 or Industry Group 267. 

Establishments primarily engaged in manufacturing insulation board 

and other reconstituted wood fiberboard are classified in Industry 

2493. 

The following SIC codes are within SIC 26, but are not addressed in detail 

in this document: 

SIC 265 (2652-2657). Paperboard containers and boxes. 

Establishments in these SIC codes are engaged in the manufacture of 

corrugated and solid fiber boxes and containers from purchased 

paperboard. The principal commodities of this industry are boxes, 

pads, partitions, display items, pallets, corrugated sheets, food 

packaging, and non-food (e.g., soaps, cosmetics, and medicinal 

products) packaging. 

SIC 267 (2671-2679). Miscellaneous converted paper products. 

These establishments produce a range of paper, paperboard, and 

plastic products with purchased material. Common products include 

paper and plastic film packaging, specialty paper, paper and plastic 

bags, manila folders, sanitary paper products, envelopes, stationery, 

and other products. 

SIC codes were established by the Office of Management and Budget (OMB) 

to track the flow of goods and services within the economy. OMB has 

changed the SIC code system to a system based on similar production 

processes called the North American Industrial Classification System 

(NAICS). Because most of the data presented in this notebook apply to the 

pulp and paper industry as defined by its SIC codes, this notebook continues 

to use the SIC system to define this sector. Table 1 presents the SIC codes 

for the pulp and paper industry and the corresponding NAICS codes. 

Sector Notebook Project 4 November 2002 
Pulp and Paper Industry Introduction, Background, and Scope 

Table 1: SIC and NAICS Codes 

1987 

SIC 

SIC Description 1997 

NAICS 

NAICS Description 

2611 Pulp mills 322110 Pulp mills 

2621 Paper mills 322121 Paper (except newsprint) mills (part) 

322122 Newsprint mills 

2631 Paperboard mills 322130 Paperboard mills 

2652 Setup paperboard boxes 322213 Setup paperboard box mfg 

2653 Corrugated & solid fiber boxes 322211 Corrugated & solid fiber box mfg 

2655 Fiber cans, drums & similar products 322214 Fiber cans, drums & similar products mfg 

2656 Sanitary food containers 322215 Nonfolding sanitary food container mfg 

2657 Folding paperboard boxes 322212 Folding paperboard box mfg 

2671 Paper - coated & laminated, packaging 322221 Coated & laminated packaging paper & 

plastics film mfg 

326112 Unsupported plastics packaging film & sheet 

mfg 

2672 Paper - coated & laminated, n.e.c. 322222 Coated & laminated paper mfg (part) 

2673 Bags - plastics, laminated, & coated 322223 Plastics, foil, & coated paper bag mfg 

326111 Unsupported plastics bag mfg 

2674 Bags - uncoated paper & multiwall 322224 Uncoated paper & multiwall bag mfg 

2675 Die-cut paper & board 322226 Surface-coated paperboard mfg 

322231 Die-cut paper & paperboard office supplies 

mfg (part) 

322299 All other converted paper product mfg (part) 

2676 Sanitary paper products 322121 Paper (except newsprint) mills (part) 

322291 Sanitary paper product mfg (part) 

2677 Envelopes 322232 Envelope mfg 

2678 Stationery products 322233 Stationery, tablet, & related product mfg 

2679 Converted paper products, n.e.c. 322222 Coated & laminated paper mfg (part) 

322231 Die-cut paper & paperboard office supplies 

mfg (part) 

322299 All other converted paper product mfg (part) 

Source: U.S. Census Bureau, 2000a. 

Sector Notebook Project 5 November 2002 
Pulp and Paper Industry Introduction, Background, and Scope 

II.B. Characterization of the Pulp and Paper Industry 

The pulp and paper industry converts wood (harvested by logging firms in 

SIC 24) or recycled fiber into pulp and primary forms of paper. Other 

companies in the paper and allied products industry (SIC codes 265 and 267) 

use the products of the pulp and paper industry to manufacture specialized 

products including paperboard boxes, writing paper, and sanitary paper. 

II.B.1. Product Characterization 

The pulp and paper industry produces primary products – commodity grades 

of wood pulp, printing and writing papers, sanitary tissue, industrial-type 

papers, containerboard and boxboard – using cellulose fiber from timber or 

purchased or recycled fibers. The two steps are pulping and paper or 

paperboard manufacturing. 

Pulping 

Pulping is the process of dissolving wood chips into individual fibers by 

chemical, semi-chemical, or mechanical methods. The particular pulping 

process used affects the strength, appearance, and intended use 

characteristics of the resultant paper product. Pulping is the major source of 

environmental impacts in the pulp and paper industry. There are more than 

a dozen different pulping processes in use in the U.S.; each pulping process 

has its own set of process inputs, outputs, and resultant environmental 

concerns. Table 2 provides an overview of the major pulping processes and 

the main products that they produce. 

Table 2: Description of Pulping Processes 

Pulp Process Description/Principal Products 

Dissolving Kraft Highly bleached and purified kraft process wood pulp suitable for 

conversion into products such as rayon, viscose, acetate, and 

cellophane. 

Bleached Papergrade 

Kraft and Soda 

Bleached or unbleached kraft process wood pulp usually converted 

into paperboard, coarse papers, tissue papers, and fine papers such 

as business, writing and printing. Unbleached Kraft 

Dissolving Sulfite Highly bleached and purified sulfite process wood pulp suitable for 

conversion into products such as rayon, viscose, acetate, and 

cellophane. 

Sector Notebook Project 6 November 2002 
Pulp and Paper Industry Introduction, Background, and Scope 

Table 2: Description of Pulping Processes (continued) 

Pulp Process Description/Principal Products 

Papergrade Sulfite Sulfite process wood pulp with or without bleaching used for 

products such as tissue papers, fine papers, and newsprint. 

Semi-chemical Pulp is produced by chemical, pressure, and occasionally 

mechanical forces with or without bleaching used for corrugating 

medium (cardboard), paper, and paperboard. 

Mechanical pulp Pulp manufacture by stone groundwood, mechanical refiner, 

thermo-mechanical, chemi-mechanical, or chemi-thermomechanical means for newsprint, coarse papers, tissue, molded fiber 

products, and fine papers. 

Secondary Fiber Deink Pulps from recovered paper or paperboard using a chemical or 

solvent process to remove contaminants such as inks, coatings and 

pigments used to produce fine, tissue, and newsprint papers. 

Secondary Fiber Nondeink Pulp production from recovered paper or paperboard without 

deinking processes to produce tissue, paperboard, molded products 

and construction papers. 

Non-wood Chemical 

pulp 

Production of pulp from textiles (e.g.,rags), cotton linters, flax, 

hemp, tobacco, and abaca to make cigarette wrap papers and other 

specialty paper products. 

Source: U.S. EPA, 1993a. 

The bleached and unbleached kraft processes are used to manufacture the 

majority of paper products. Together, these processes account for 83 percent 

of the pulp produced in the United States. Figure 1 presents the relative 

output of the major pulping processes. 

Sector Notebook Project 7 November 2002 
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Pulp and Paper Industry Introduction, Background, and Scope 

Figure 1: Pulp Production, 2000 

(Thousand Tons) 

Semichemical 

1,116 

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Kraft -- Unbleached 

Sulfite 

Mechanical 

6,501 

3,976 

Kraft -- Bleached 

31,978 

21,281 

Source: AF&PA, 2001. 

The pulp manufacturing process is the major source of environmental 

concern for this industry. For example, a bleached kraft pulp mill requires 

4,000-12,000 gallons of water and 14-20 million Btu of energy per ton of 

pulp, of which roughly 8-10 million Btu typically are derived from biomassderived fuel from the pulping process (Pulp and Paper, 2001). Across all 

facilities in SIC 26, the pulp, paper, and allied products industry is the largest 

consumer of process water and the third largest consumer of energy (behind 

the chemicals and metals industries) (U.S. Department of Commerce, 2000 

and U.S. Department of Energy, 2000). The high use of water and energy, 

as well as the chemical inputs described in Section III, lead to a variety of 

environmental concerns. 

Paper and Paperboard Manufacturing 

The paper or paperboard manufacturing process is similar for all types of 

pulp. In this process, pulp is spread out as a wet mixture, or slurry, onto a 

screen. Water is removed by gravity and vacuums, and the resulting layer of 

fibers is passed through a series of rollers that compress the material into 

sheets. Paper and paperboard manufacturers use nearly identical processes; 

the difference is that paperboard is thicker (more than 0.3 mm). 

Sector Notebook Project 8 November 2002 
Pulp and Paper Industry Introduction, Background, and Scope 

II.B.2. Industry Size and Geographic Distribution 

The pulp and paper industry is characterized by very large facilities; of the 

514 pulp and paper mills in SIC codes 261-263 reported by the Bureau of the 

Census in 1998, 343 (67 percent) have 100 or more employees. Across all 

of these facilities, there are 172,000 employees who produced $59 billion in 

shipments (in 1998 dollars). In 2000, the industry employed 182,000 and 

produced $79 billion in shipments. 

In contrast, the downstream facilities (container and specialty product 

manufacturers) tend to be more numerous but smaller. More than 75 percent 

of these facilities have fewer than 100 employees. Table 3 presents the 

employment distribution for both pulp and paper facilities and downstream 

manufacturers in 1997 (the most recent data available) as reported by the 

U.S. Census Bureau. Because recent years have seen some facility closures, 

the current number of facilities may be somewhat lower. 

Table 3: Size of Paper and Allied Products Facilities 

Industry 

Employees per Facility (% of Total) 

1-19 20-99 100-499 >499 

Pulp mills (SIC 261) 3 (7%) 14 (34%) 18 (44%) 6 (15%) 

Paper mills (SIC 262) 6 (2%) 63 (24%) 107 (41%) 83 (32%) 

Paperboard mills (SIC 263) 8 (4%) 77 (36%) 96 (45%) 33 (15%) 

Paperboard containers and 

boxes (SIC 265) 

748 (26%) 1,311 (46%) 782 (27%) 14 (<1%) 

Misc. converted paper 

products (SIC 267) 

1,383 (44%) 1,116 (36%) 597 (19%) 70 (2%) 

Source: U.S. Census Bureau, 1998. 

Figure 2 presents the employment and value of shipments for both the 

primary and secondary portions of the paper and allied products industry. 

Taken together, the industry is among the top 10 U.S. manufacturing 

industries in value of shipments. As noted in the two graphs, the pulp and 

paper portion of the industry (pulp, paper, and paperboard mills) employs 

only 28 percent of the workers in the industry, but produces over 40 percent 

of the shipments. 

Sector Notebook Project 9 November 2002 
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Pulp and Paper Industry Introduction, Background, and Scope 

Figure 2: Employment and Value of Shipments in the Paper and Allied Products Industrya 

Employment Value of Shipments ($ million) 

Total: 609,480 Total: 145,655 

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10,247 Paper mills 

107,552 

Paperboard containers 

Pulp mills Pulp mills 

Misc. paper products 

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4,073 

Paperboard containers 

Paper mills 

Misc. paper products 46,154 35,514 

228,967 

Paperboard mills 

54,643 

Paperboard mills 

19,829 

208,071 40,085 

a

 Integrated mills, which produce both pulp and paper (or paperboard), are included in the paper (or paperboard) 

categories. The pulp mill category includes only facilities producing pulp for the general market. 

Source: U.S. Census Bureau, 2000b. 

The geographic distribution of pulp and paper mills varies according to the 

type of mill. As there are tremendous variations in the scale of individual 

facilities, tallies of the number of facilities may not represent the level of 

economic activity (nor possible environmental consequences). Pulp mills are 

located primarily in regions of the country where trees are harvested from 

natural stands or tree farms: the Southeast, Northwest, Northeast, and North 

Central regions. Pulp mills that process recycled fiber are generally located 

near sources of waste paper. Paper mills, however, are more widely 

distributed. They are located near pulping operations and/or near converting 

markets. The distribution of paperboard mills reflects the location of 

manufacturing in general, since such operations are the primary market for 

paperboard products. Figure 3 presents the location of pulp and paper mills 

in the U.S. 

Sector Notebook Project 10 November 2002 
Pulp and Paper Industry Introduction, Background, and Scope 

Figure 3: Geographic Distribution of Pulp, Paper, and Paperboard 

Mills 

There are no currently active mills in Alaska or Hawaii. 

Source: U.S. EPA, 1999. 

II.B.3. Economic Trends 

World Market Competition 

The U.S. produces roughly 30 percent of the world’s paper and paperboard. 

The pulp and paper industry is one of the most important industries for the 

balance of trade in the U.S. This trade balance increased through most of the 

1990s. In 1999, exports from SIC codes 261-263 were $8.5 billion. In recent 

years, however, exports have been declining and imports have been 

increasing. Between 1997 and 2000, exports declined 5.5% and imports 

increased by more than 20%. The declining exports and increasing imports 

are partly due to a strong dollar in this period and the recent slow down of the 

U.S. economy (AF&PA, 2001). 

The U.S. industry has several advantages over the rest of the world market, 

including modern mills, a highly skilled work force, a large domestic 

market, and an efficient transportation infrastructure. Major export markets 

for pulp are Japan, Italy, Germany, Mexico, and France. The U.S. 

Department of Commerce anticipates exports to grow faster than production 

for domestic markets through 2004. World Trade Organization (WTO) 

efforts to reduce tariffs include those on pulp and paper products; if these are 

successful, the U.S. industry expects pulp and paper export rates to increase 

even further. 

Sector Notebook Project 11 November 2002 
Pulp and Paper Industry Introduction, Background, and Scope 

However, pulp and paper are commodities and therefore prices are vulnerable 

to global competition. Countries such as Brazil, Chile, and Indonesia have 

built modern, advanced pulp facilities. These countries have faster-growing 

trees and lower labor costs. Latin American and European countries also are 

adding papermaking capacity. Furthermore, the strong value of the dollar has 

made imports less expensive relative to domestically-produced goods. 

Because of this increased foreign competition, imports of paper to the U.S. 

market are expected to increase three percent annually through 2004 (U.S. 

Department of Commerce, 2000). 

Industry Consolidation 

In order to compensate for this increasingly competitive market, pulp and 

paper companies have undertaken a considerable number of mergers and 

acquisitions. Table 4 lists the major transactions that occurred between 1997 

and 2002. 

Table 4: Major Pulp and Paper Mergers and Acquisitions 

Buyer Acquired Value 

(million) 

Year 

International Paper Co. Champion International Inc. $9,600 2000 

International Paper Co. Union Camp Corp. $7,900 1999 

Jefferson Smurfit Corp. Stone Container Corp. $6,400 1998 

Weyerhaeuser Co. Willamette $6,000 2002 

Fort Howard Corp. James River Corp. $5,800 1997 

Abitibi-Consolidated Inc. Donohue Inc. $5,300 2000 

Stora Enso Oy Consolidated Papers Inc. $4,800 2000 

Abitibi-Price Inc. Stone-Consolidated Inc. $3,600 1997 

Westvaco Mead $3,000 2002 

Bowater Inc. Avenor Inc. $2,500 1997 

Weyerhaeuser Co. MacMillan Bloedel Ltd. $2,450 1999 

Madison Dearborn Industries Inc. Tenneco Packaging Inc. $2,200 1999 

Largest mergers and acquisitions between 1997 and mid-2000. 

Source: McLaren, J et al., 2000, and Pulp & Paper International, September 2002.

Sector Notebook Project 12 November 2002 
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Pulp and Paper Industry Introduction, Background, and Scope 

Capital Improvements 

Historically, U.S. pulp and paper companies have invested heavily in capital 

improvements to their facilities. Capital investments in recent years, 

however, are well below historic levels due to the difficult market conditions. 

For the first time, industry capacity actually declined in 2001 (Pulp & Paper 

International, 2002). Because few new mills are being built, most capital 

expenditures represent plant expansions, upgrades, and environmental 

protection initiatives at existing facilities. Figure 4 presents the rate of 

capital investments within SIC 261-263. Throughout the time period shown, 

capital improvements related to environmental protection claimed from 4% 

to 22% of the total investments with significant increases in the early and late 

1990s (AF&PA, 2001). 

Figure 4: Capital Improvements at Pulp and Paper Mills 

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1998 

1999 

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Source: AF&PA, 2001. 

Recycling Efforts 

A major movement within the pulp and paper industry has been an increased 

focus on the use of recovered paper. As shown in Figure 5, nearly 50 percent 

of paper now is recovered and used either as recycled paper or as products 

such as home insulation. Furthermore, recovered paper contributes to U.S. 

exports; roughly ten million tons of recovered paper were exported in 2000 

(AF&PA, 2001). 

Sector Notebook Project 13 November 2002 
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Pulp and Paper Industry Introduction, Background, and Scope 

Figure 5: Paper Recovery Rates 

50% 

40% 

30% 

20% 

10% 

0%

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1986 1988 1990 1992 1994 1996 1998 2000

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Recovery Rate 

The recovery rate is the ratio of recovered paper collected to new supply of paper and

paperboard.

Source: AF&PA, 2001.

Sector Notebook Project 14 November 2002 
Pulp and Paper Industry Industrial Process Description 

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 interrelationship between the industrial process and the topics described in 

subsequent sections of this profile -- pollutant outputs, pollution prevention 

opportunities, and Federal regulations. This section does not attempt to 

replicate published engineering information that is available for this industry. 

Refer to Section IX for a list of reference documents that are available. 

This section specifically contains a description of commonly used production 

processes, associated raw materials, the byproducts produced or released, and 

the materials either recycled or transferred off-site. This discussion, coupled 

with schematic drawings of the identified processes, provides a concise 

description of where wastes may be produced in the process. This section 

also describes the potential fate (via air, water, and soil pathways) of these 

waste products. 

III.A. Industrial Processes in the Pulp and Paper Industry 

Simply put, paper is manufactured by applying a watery suspension of 

cellulose fibers to a screen which allows the water to drain and leaves the 

fibrous particles behind in a sheet. Most modern paper products contain nonfibrous additives, but otherwise fall within this general definition. Only a 

few paper products for specialized uses are created without the use of water, 

via dry forming techniques. The individual fibers formed into paper sheets 

is called pulp. The production of pulp is the major source of environmental 

impacts in the pulp and paper industry. 

Processes in the manufacture of paper and paperboard can, in general terms, 

be split into three steps: pulp making, pulp processing, and paper/paperboard 

production. Paperboard sheets are thicker than paper sheets; paperboard is 

thicker than 0.3 mm. In general, however, paper and paperboard production 

processes are identical. First, a stock pulp mixture is produced by digesting 

a material into its fibrous constituents via chemical, mechanical, or a 

combination of chemical and mechanical means. In the case of wood, the 

most common pulping material, chemical pulping actions release cellulose 

fibers by selectively destroying the chemical bonds in the glue-like substance 

(lignin) that binds the fibers together. After the fibers are separated and 

impurities have been removed, the pulp may be bleached to improve 

brightness and processed to a form suitable for paper-making equipment. At 

the paper-making stage, the pulp can be combined with dyes, strength 

building resins, or texture adding filler materials, depending on the intended 

end product. Afterwards, the mixture is dewatered, leaving the fibrous 

Sector Notebook Project 15 November 2002 
Pulp and Paper Industry Industrial Process Description 

constituents and pulp additives on a wire or wire-mesh conveyor. Additional 

additives may be applied after the sheet-making step. The fibers bond 

together as they are carried through a series of presses and heated rollers. 

The final paper product is usually spooled on large rolls for storage (see 

Figure 6). 

The following discussion focuses mainly on pulping processes due to their 

importance in understanding industry environmental impacts and current 

industry regulatory classification schemes. If more information on 

papermaking processes is desired, 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. 

Additional sources are listed in Section IX of this document. 

Sector Notebook Project 16 November 2002 
Pulp and Paper Industry Industrial Process Description

Sector Notebook Project 17 November 2002

Figure 6: Simplified Flow Diagram: Integrated Mill

(Chemical Pulping, Bleaching, and Paper Production)

Source: Smook, 1992.
Pulp and Paper Industry Industrial Process Description 

III.A.1. Pulp Manufacture 

At the pulping stage, the processed furnish (wood or other fiber source) is 

digested into its fibrous constituents. The bonds between fibers may be 

broken chemically, mechanically, or by a combination of the techniques 

called semi-chemical pulping. The choice of pulping technique is dependent 

on the type of furnish and the desired qualities of the finished product, but 

chemical pulping is the most prevalent. Table 5 presents an overview of the 

wood pu00lping types by the method of fiber separation, resultant fiber 

quality, and percent of 1998 U.S. pulp production. Many mills perform 

multiple pulping processes at the same site, most frequently non-deink 

secondary fiber pulping and papergrade kraft pulping (U.S. EPA, 1993a). 

The three basic types of wood pulping processes 1) chemical pulping, 2) 

semi-chemical pulping, and 3) mechanical pulping are detailed below 

followed by a discussion of secondary fiber pulping techniques. 

Table 5: General Classification of Wood Pulping Processes 

Process 

Category 

Fiber 

Separation 

Method 

Fiber Quality Examples 

% of Total 

1998 US 

Wood Pulp 

Production 

Mechanical Mechanical 

energy 

Short, weak, 

unstable, impure 

fibers 

Stone 

groundwood, 

refiner mechanical 

pulp 

10% 

Semichemical Combination of 

chemical and 

mechanical 

treatments 

“Intermediate” 

pulp properties 

(some unique 

properties) 

High-yield kraft, 

high-yield sulfite 

6% 

Chemical Chemicals and 

heat 

Long, strong, 

stable fibers 

Kraft, sulfite, soda 84% 

Sources: Smook, 1992; AF&PA, 1999. 

A variety of technologies and chemicals are used to manufacture pulp, but 

most pulp manufacturing systems contain the process sequence shown in 

Table 6. 

Sector Notebook Project 18 November 2002 
Pulp and Paper Industry Industrial Process Description 

Table 6: Pulp Manufacturing Process Sequence 

Process Sequence Description 

Fiber Furnish Preparation 

and Handling 

Debarking, slashing, chipping of wood logs and then 

screening of wood chips/secondary fibers (some 

pulp mills purchase chips and skip this step) 

Pulping Chemical, semi-chemical, or mechanical breakdown 

of pulping material into fibers 

Pulp Processing Removal of pulp impurities, cleaning and thickening 

of pulp fiber mixture 

Bleaching Addition of chemicals in a staged process of 

reaction and washing increases whiteness and 

brightness of pulp, if necessary 

Pulp drying and baling 

(non-integrated mills) 

At non-integrated pulp mills, pulp is dried and 

bundled into bales for transport to a paper mill 

Stock Preparation 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. By far, the principle source of paper-making fibers in the 

United States is wood from trees, the largest vascular plants available. The 

fibrous particles used to make paper are made of cellulose, a primary 

component of the cell walls of vascular plant tissues. The cellulose fibers 

must be removed from a chemical matrix (e.g., lignin, hemicelluloses, and 

resins) and result in a mixture of relatively pure fibers. 

Sector Notebook Project 19 November 2002 
Pulp and Paper Industry Industrial Process Description 

Wood used to make pulp can arrive at the mill in a variety of forms including 

wood logs, chips, and sawdust. Due to different physical and chemical 

properties of different types of wood, certain pulping processes are most 

efficient on specific wood types. The type of wood used can also make a 

difference in the final characteristics of the pulp. In general, softwood (e.g., 

pine and spruce) fibers are longer than those from hardwood (e.g., birch and 

oak) and have thinner cell walls. The longer fibers of softwood promote 

inter-fiber bonding and produce papers of greater strength. 

Secondary fibers comprise the next most common furnish constituent. 

Secondary fibers consist of pre-consumer fibers (e.g., mill waste fibers) and 

post-consumer fiber. Post-consumer fiber sources are diverse, but the most 

common are newsprint and corrugated boxes (See Table 7). Although 

secondary fibers are not used in as great a proportion as wood furnish, 

approximately 80 percent of pulp and paper manufacturers use some 

secondary fibers in their pulp production and approximately 200 mills 

(approximately 40 percent of total number of mills) rely exclusively on 

secondary fibers for their pulp furnish (AF&PA, 1999; AF&PA, 2000c). 

Secondary fibers must be processed to remove contaminants such as glues or 

bindings, but, depending on the end product, may or may not be processed 

to remove ink contaminants or to brighten the pulp. 

Secondary fiber use is increasing in the pulp and paper industry due to 

consumer demand for products made from recycled paper. Recovered fiber 

accounted for 75 percent of the industry’s increase in fiber consumption 

between 1990 and 2000 (AF&PA, 2000a). The utilization of secondary 

fibers, expressed as the ratio of recovered paper consumption to the total 

production of paper and paperboard, is at approximately 39 percent and is 

climbing slowly (AF&PA, 2001). In a resource-deficient country such as 

Japan, the secondary fiber utilization rate is at about 50 percent, whereas the 

average utilization rate in Europe is approximately 40 percent (VDP, 1997). 

Due to losses of fiber substance and strength during the recycling process, a 

50 percent utilization rate is considered the present maximum overall 

utilization rate for fiber recycling (Smook, 1992). 

Secondary fiber sources are seldom used as feedstocks for high quality paper 

products. Contaminants (e.g., inks, paper colors) are often present, so 

production of low-purity products is often the most cost-effective use of 

secondary fibers, although decontamination technologies are available. 

Approximately 68 percent of all secondary fiber in the U.S. is presently used 

for multi-ply paperboard or the corrugating paper used to manufacture 

corrugated cardboard (AF&PA, 2000a). Over the next decade, an increasing 

proportion of the total amount will be deinked for newsprint or other higherquality uses. 

Sector Notebook Project 20 November 2002 
Pulp and Paper Industry Industrial Process Description 

Table 7: Relative Wastepaper Usage as Secondary Fiber in 1999 

Paper Type % of Total Wastepaper Usage in 

1999 

Mixed Paper 18% 

Old Newspaper 19% 

Old Corrugated Cardboard 48% 

Pulp Substitutes 6% 

High-grade Deinked 9% 

Source: AF&PA, 2000b. 

Other types of furnish include cotton rags and linters, flax, hemp, bagasse, 

tobacco, and synthetic fibers such as polypropylene. These substances are 

not used widely, however, as they are typically for low volume, specialty 

grades of paper. 

The types of furnish used by a pulp and paper mill depend on the type of 

product produced and what is readily available. Urban mills use a larger 

proportion of secondary fibers due to the post-consumer feedstock close at 

hand. More rurally located mills are usually close to timber sources and thus 

may use virgin fibers in greater proportion. 

Furnish Preparation 

Furnish is prepared for pulp production by a process designed to supply a 

homogenous pulping feedstock. In the case of roundwood furnish (logs), the 

logs are cut to manageable size and then debarked. At pulp mills integrated 

with lumbering facilities, acceptable lumber wood is removed at this stage. 

At these facilities, any residual or waste wood from lumber processing is 

returned to the chipping process; in-house lumbering rejects can be a 

significant source of wood furnish at a facility. The bark of those logs not fit 

for lumber is usually either stripped mechanically or hydraulically with high 

powered water jets in order to prevent contamination of pulping operations. 

Depending on the moisture content of the bark, it may then be burned for 

energy production. If not burned for energy production, bark can be used for 

mulch, ground cover, or to make charcoal. 

Hydraulic debarking methods may require a drying step before burning. 

Usually, hydraulically removed bark is collected in a water flume, dewatered, 

and pressed before burning. Treatment of wastewater from this process is 

difficult and costly, however, whereas dry debarking methods can channel 

Sector Notebook Project 21 November 2002 
Pulp and Paper Industry Industrial Process Description 

the removed bark directly into a furnace (Smook, 1992). In part because of 

these challenges, hydraulic debarking has decreased in significance within 

the industry (Potlatch, 2002). 

Debarked logs are cut into chips of equal size by chipping machines. 

Chippers usually produce uniform wood pieces 20 mm long in the grain 

direction and 4 mm thick. The chips are then put on a set of vibrating screens 

to remove those that are too large or small. Large chips stay on the top 

screens and are sent to be recut, while the smaller chips are usually burned 

with the bark. Certain mechanical pulping processes, such as stone 

groundwood pulping, use roundwood; however, the majority of pulping 

operations require wood chips. Non-wood fibers are handled in ways 

specific to their composition. Steps are always taken to maintain fiber 

composition and thus pulp yield. 

Chemical Pulping 

Chemical pulps are typically manufactured into products that have highquality standards or require special properties. Chemical pulping degrades 

wood by dissolving the lignin bonds holding the cellulose fibers together. 

Generally, this process involves the cooking/digesting of wood chips in 

aqueous chemical solutions at elevated temperatures and pressures. There 

are two major types of chemical pulping currently used in the U.S.: 1) 

kraft/soda pulping and 2) sulfite pulping. These processes differ primarily 

in the chemicals used for digesting. The specialty paper products rayon, 

viscose, acetate, and cellophane are made from dissolving pulp, a variant of 

standard kraft or sulfite chemical pulping processes. 

Kraft pulping (or sulfate) processes produced approximately 83 percent of 

all US pulp tonnage during 2000 according to the American Forest and Paper 

Association (AF&PA, 2001). The success of the process and its widespread 

adoption are due to several factors. First, because the kraft cooking 

chemicals are selective in their attack on wood constituents, the pulps 

produced are notably stronger than those from other processes (i.e., Kraft is 

German for "strength"). The kraft process is also flexible, in so far as it is 

amenable to many different types of raw materials (i.e., hard or soft woods) 

and can tolerate contaminants frequently found in wood (e.g., resins). Lignin 

removal rates are high in the kraft process — up to 90 percent — allowing 

high levels of bleaching without pulp degradation. Finally, the chemicals 

used in kraft pulping are readily recovered within the process, making it very 

economical and reducing potential environmental releases (See Chemical 

Recovery Systems below). 

The kraft process uses a sodium-based alkaline pulping solution (liquor) 

consisting of sodium sulfide (Na2S) and sodium hydroxide (NaOH) in 10 

percent solution. This liquor (white liquor) is mixed with the wood chips in 

Sector Notebook Project 22 November 2002 
Pulp and Paper Industry Industrial Process Description 

a reaction vessel (digester). The output products are separated wood fibers 

(pulp) and a liquid that contains the dissolved lignin solids in a solution of 

reacted and unreacted pulping chemicals (black liquor). The black liquor 

undergoes a chemical recovery process (see Chemical Recovery Systems) to 

regenerate white liquor for the first pulping step. Overall, the kraft process 

converts approximately 50 percent of input furnish into pulp. 

The kraft process evolved from the soda process. The soda process uses an 

alkaline liquor of only sodium hydroxide (NaOH). The kraft process has 

virtually replaced the soda process due to the economic benefits of chemical 

recovery and improved reaction rates (the soda process has a lower yield of 

pulp per pound of wood furnish than the kraft process). 

Sulfite pulping was used for approximately two percent of U.S. pulp 

production in 2000 (AF&PA, 2001). Softwood is the predominant furnish 

used in sulfite pulping processes. However, only non-resinous species are 

generally pulped. The sulfite pulping process relies on acid solutions of 

sulfurous acid (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 six percent of U.S. pulp production in 

2000 (AF&PA, 2001). Semi-chemical pulp is often very stiff, making this 

process common in corrugated container manufacture. This process 

primarily uses hardwood as furnish. 

The major process difference between chemical pulping and semi-chemical 

pulping is that semi-chemical pulping uses lower temperatures, more dilute 

cooking liquor or shorter cooking times, and mechanical disintegration for 

fiber separation. At most, the digestion step in the semi-chemical pulping 

process consists of heating pulp in sodium sulfite (Na2SO3) and sodium 

carbonate (Na2CO3) Other semi-chemical processes include the Permachem 

process and the two-stage vapor process. The yield of semi-chemical pulping 

ranges from 55 to 90 percent, depending on the process used, but pulp 

residual lignin content is also high so bleaching is more difficult. 

Sector Notebook Project 23 November 2002 
Pulp and Paper Industry Industrial Process Description 

Mechanical pulping 

Mechanical pulping accounted for nine percent of U.S. pulp production in 

2000 (AF&PA, 2001). Mechanically produced pulp is of low strength and 

quality. Such pulps are used principally for newsprint and other nonpermanent paper goods. Mechanical pulping relies on physical pressure 

instead of chemicals to separate furnish fibers; however, chemicals are 

sometimes added at the various stages of refining. Processes include: 1) 

stone groundwood, 2) refiner mechanical, 3) thermo-mechanical, 4) chemimechanical, and 5) chemi-thermo-mechanical. The stone groundwood 

process simply involves mechanical grinding of wood in several high-energy 

refining systems. The refiner mechanical process involves refining wood 

chips at atmospheric pressure while the thermo-mechanical process uses 

steam and pressure to soften the chips before mechanical refining. In the 

chemi-mechanical process, chemicals can be added throughout the process 

to aid the mechanical refining. The chemi-thermo-mechanical process 

involves the treatment of chips with chemicals for softening followed by 

mechanical pulping under heat and pressure. Mechanical pulping typically 

results in high pulp yields, up to 95 percent when compared to chemical 

pulping yields of 45- 50 percent, but energy usage is also high. To offset its 

structural weakness, mechanical pulp is often blended with chemical pulp. 

Secondary fiber pulping 

Secondary fiber pulping accounted for 39 percent of domestic pulp 

production in 2000 (AF&PA, 2001). Nearly 200 mills rely exclusively on 

recovered paper for pulp furnish, and roughly 80 percent of U.S. paper mills 

use recovered paper in some way (AF&PA, 2000c). In addition, 

consumption of fiber from recovered paper is growing more than twice as 

fast as overall fiber consumption. Secondary fibers are usually presorted 

before they are sold to a pulp and paper mill. If not, secondary fibers are 

processed to remove contaminants before pulping occurs. Common 

contaminants consist of adhesives, coatings, polystyrene foam, dense plastic 

chips, polyethylene films, wet strength resins, and synthetic fibers. In some 

cases, contaminants of greater density than the desired secondary fiber are 

removed by centrifugal force while light contaminants are removed by 

flotation systems. Centri cleaners are also used to remove material less dense 

than fibers (wax and plastic particles) (AF&PA, 1995b). 

Inks, another contaminant of secondary fibers, may be removed by heating 

a mixture of secondary fibers with surfactants. The removed inks are then 

dispersed in an aqueous media to prevent redeposition on the fibers. 

Continuous solvent extraction has also been used to recover fibers from paper 

and board coated with plastics and/or waxes. 

Sector Notebook Project 24 November 2002 
Pulp and Paper Industry Industrial Process Description 

Secondary fiber pulping is a relatively simple process. The most common 

pulper design consists of a large container filled with water, which is 

sometimes heated, and the recycled pulp. Pulping chemicals (e.g., sodium 

hydroxide, NaOH) are often added to promote dissolution of the paper or 

board matrix. The source fiber (corrugated containers, mill waste, etc.) is 

dropped into the pulper and mixed by a rotor. Debris and impurities are 

removed by two mechanisms: a ragger and a junker. The ragger withdraws 

strings, wires, and rags from the stock secondary fiber mixture. A typical 

ragger consists of a few "primer wires" that are rotated in the secondary fiber 

slurry. Debris accumulates on the primer wires, eventually forming a "debris 

rope" which is then removed. Heavier debris are separated from the mixture 

by centrifugal force and fall into a pocket on the side of the pulper. The 

junker consists of a grappling hook or elevator bucket. Heat, dissolution of 

chemical bonds, shear forces created by stirring and mixing, and grinding by 

mechanical equipment may serve to dissociate fibers and produce a pulp of 

desired consistency. 

Contaminant removal processes depend on the type and source of secondary 

fiber to be pulped. Mill paper waste can be easily repulped with minimal 

contaminant removal. Recycled post-consumer newspaper, on the other 

hand, may require extensive contaminant removal, including deinking, prior 

to reuse. As noted in Furnish Composition above, secondary fiber typically 

is used in lower-quality applications such as multi-ply paperboard or 

corrugating paper. 

III.A.2. Pulp Processing 

After pulp production, pulp processing removes impurities, such as uncooked 

chips, and recycles any residual cooking liquor via the washing process 

(Figure 7). Pulps are processed in a wide variety of ways, depending on the 

method that generated them (e.g., chemical, semi-chemical). Some pulp 

processing steps that remove pulp impurities include screening, defibering, 

and deknotting. Pulp may also be thickened by removing a portion of the 

water. At additional cost, pulp may be blended to ensure product uniformity. 

If pulp is to be stored for long periods of time, drying steps are necessary to 

prevent fungal or bacterial growth. 

Residual spent cooking liquor from chemical pulping is washed from the 

pulp using brown stock washers. Efficient washing is critical to maximize 

return of cooking liquor to chemical recovery (see Chemical Recovery 

Systems below) and to minimize carryover of cooking liquor (known as 

brown stock washing loss) into the bleach plant, because excess cooking 

liquor increases consumption of bleaching chemicals. Specifically, the 

dissolved organic compounds (lignins and hemicelluloses) contained in the 

liquor will bind to bleaching chemicals and thus increase bleach chemical 

consumption. In addition, these organic compounds function as precursors 

Sector Notebook Project 25 November 2002 
Pulp and Paper Industry Industrial Process Description 

to chlorinated organic compounds (e.g., dioxins, furans), increasing the 

probability of their formation. The most common washing technology is 

rotary vacuum washing, carried out sequentially in two or four washing 

units. Other washing technologies include diffusion washers, rotary pressure 

washers, horizontal belt filters, wash presses, and dilution/extraction washers. 

Pulp screening, removes remaining oversized particles such as bark 

fragments, oversized chips, and uncooked chips. In open screen rooms, 

wastewater from the screening process goes to wastewater treatment prior to 

discharge. In closed loop screen rooms, wastewater from the process is 

reused in other pulping operations and ultimately enters the mill's chemical 

recovery system. Centrifugal cleaning (also known as liquid cyclone, 

hydrocyclone, or 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 

(Smook, 1992). Environmental benefits include the recycle of process 

chemicals and lack of resultant discharges to the environment. 

The kraft, sulfite, and semi-chemical pulping processes all use chemical 

recovery systems of some form; however, the actual chemical processes at 

work differ markedly. Due to its widespread usage, only the kraft chemical 

recovery system will be covered in depth in this document. Sulfite chemical 

recovery systems are discussed briefly at the end of this section. 

Kraft Chemical Recovery Systems 

Although newer technologies are always under development, the basic kraft 

chemical recovery process has not been fundamentally changed since its 

patent issue in 1884. The stepwise progression of chemical reactions has 

been refined; for example, black liquor gasification processes are now in use 

in an experimental phase. The precise details of the chemical processes at 

work in the chemical recovery process can be found in Smook, Handbook for 

Pulp and Paper Technologists, 2nd Edition, 1992 and will not be discussed 

here. The kraft chemical recovery process consists of the following general 

steps: 

Sector Notebook Project 26 November 2002 
Pulp and Paper Industry Industrial Process Description 

Black liquor concentration 

Residual weak black liquor from the pulping process is concentrated by 

evaporation to form "strong black liquor.” After brown stock washing in the 

pulping process, the concentration of solids in the weak black liquor is 

approximately 15 percent; after the evaporation process, solids concentration 

can range from 60 - 80 percent. In some older facilities, the liquor then 

undergoes oxidation for odor reduction. The oxidation step is necessary to 

reduce odor created when hydrogen sulfide is stripped from the liquor during 

the subsequent recovery boiler burning process. Almost all recovery 

furnaces installed since 1968 have non-contact evaporation processes that 

avoid these problems, so oxidation processes are not usually seen in mills 

with modern recovery furnaces. Common 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 III.B. Raw Material Inputs and Pollution Outputs in 

the Production Line for more information). 

Recovery boiler

The strong black liquor from the evaporators is burned in a recovery boiler.

In this crucial step in the overall kraft chemical recovery process, organic

solids are burned for energy and the process chemicals are removed from the

mixture in molten form. Molten inorganic process chemicals (smelt) flow

through the perforated floor of the boiler to water-cooled spouts and

dissolving tanks for recovery in the recausticizing step. 

Energy generation from the recovery boiler is often insufficient for total plant 

needs, however, so facilities augment recovery boilers with fossil-fuel-fired 

and wood-waste-fired boilers (hogged fuel) to generate steam and often 

electricity. Industry-wide, the utilization of pulp wastes, bark, and other 

papermaking residues supplies 58 percent of the energy requirements of pulp 

and paper companies (AF&PA, 1999) (see III.A.3. Energy Generation for 

more information). 

Recausticizating 

Smelt is recausticized to remove impurities left over from the furnace and to 

convert sodium carbonate (Na2CO3) into active sodium hydroxide (NaOH) 

and sodium sulfide (Na2S). The recausticization procedure begins with the 

mixing of smelt with "weak" liquor to form green liquor, named for its 

characteristic color. Contaminant solids, called dregs, are removed from the 

green liquor, which is mixed with lime (CaO). After the lime mixing step, 

the mixture, now called white liquor due to its new coloring, is processed to 

remove a layer of lime mud (CaCO3) that has precipitated. The primary 

chemicals recovered are caustic (NaOH) and sodium sulfide (Na2S). The 

remaining white liquor is then used in the pulp cooking process. The lime 

mud is treated to regenerate lime in the calcining process. 

Sector Notebook Project 27 November 2002 
Pulp and Paper Industry Industrial Process Description 

Calcining

In the calcining process, the lime mud removed from the white liquor is

burned to regenerate lime for use in the lime mixing step. The vast majority

of mills use lime kilns for this process, although a few mills use fluidized bed

systems in which the reactants are suspended by upward-blowing air.

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). 

Sector Notebook Project 28 November 2002 
Pulp and Paper Industry Industrial Process Description 

Figure 7: The Kraft Pulping Process (with Chemical Recovery) 

Source: Smook, 1992. 

Sector Notebook Project 29 November 2002 
Pulp and Paper Industry Industrial Process Description 

III.A.3. Bleaching 

Bleaching is defined as any process that chemically alters pulp to increase its 

brightness. Bleached pulps create papers that are whiter, brighter, softer, and 

more absorbent than unbleached pulps. Bleached pulps are used for products 

where high purity is required and yellowing (or color reversion) is not 

desired (e.g. printing and 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 production capacity in the United 

States in 2000, about 50 percent is for bleached pulp (AF&PA, 2001). 

Any type of pulp may be bleached, but the type(s) of fiber furnish and 

pulping processes used, as well as the desired qualities and end use of the 

final product, greatly affect the type and degree of pulp bleaching possible. 

Printing and writing papers comprise approximately 60 percent of bleached 

paper production. The lignin content of a pulp is the major determinant of 

its bleaching potential. Pulps with high lignin content (e.g., mechanical or 

semi-chemical) are difficult to bleach fully and require heavy chemical 

inputs. Excessive bleaching of mechanical and semi-chemical pulps results 

in loss of pulp yield due to fiber destruction. Chemical pulps can be bleached 

to a greater extent due to their low (10 percent) lignin content. 

For more information, the Summary of Technologies for the Control and 

Reduction of Chlorinated Organics from the Bleached Chemical Pulping 

Subcategories of the Pulp and Paper Industry, 1990 from the Office of Water 

Regulations and Standards is recommended. Typical bleaching processes for 

each pulp type are detailed below. 

Chemical pulp bleaching has undergone significant process changes since 

approximately 1990. At that time, nearly every chemical pulp mill that used 

bleaching incorporated elemental chlorine (Cl2) into some of its processes. 

Because of environmental and health concerns about dioxins, U.S. pulp mills 

now use elemental chlorine free (ECF) and total chlorine free (TCF) 

bleaching technologies. The most common types of ECF and TCF are shown 

in Table 8; the difference between ECF and TCF is that ECF may include 

chlorine dioxide (ClO2) and hypochlorite (HClO, NaOCl, and Ca(OCl)2) 

based technologies. In 2001, ECF technologies were used for about 95 

percent of bleached pulp production, TCF technologies were used for about 

1 percent of bleached pulp production, and elemental chlorine was used for 

about 4 percent of production (AET, 2002). 

Sector Notebook Project 30 November 2002 
Pulp and Paper Industry Industrial Process Description 

Table 8: Common Chemicals Used in Elemental Chlorine Free 

(ECF) and Total Chlorine Free (TCF) Bleaching Processes 

Bleaching Chemical Chemical Formula ECF/TCF 

Sodium Hydroxide NaOH ECF and TCF 

Chlorine Dioxide ClO2 ECF 

Hypochlorite HClO, NaOCl, 

Ca(OCl)2 

ECF 

Oxygen O2 ECF and TCF 

Ozone O3 ECF and TCF 

Hydrogen Peroxide H2O2 ECF and TCF 

Sulfur Dioxide SO2 ECF and TCF 

Sulfuric Acid H2SO4 ECF and TCF 

Source: U.S. EPA, 2001. 

Chemical pulp is bleached in traditional bleach plants (see Figure 8) where 

the pulp is processed through three to five stages of chemical bleaching and 

water washing. The number of cycles is dependent on the whiteness desired, 

the brightness of initial stock pulp, and plant design. 

Bleaching stages generally alternate between acid and alkaline conditions. 

Chemical reactions with lignin during the acid stage of the bleaching process 

increase the whiteness of the pulp. The alkaline extraction stages dissolve 

the lignin/acid reaction products. At the washing stage, both solutions and 

reaction products are removed. Chemicals used to perform the bleaching 

process must have high lignin reactivity and selectivity to be efficient. 

Typically, 4-8 percent of pulp is lost due to bleaching agent reactions with 

the wood constituents cellulose and hemicellulose, but, these losses can be 

as high as 18 percent. 

Sector Notebook Project 31 November 2002 
Pulp and Paper Industry Industrial Process Description 

Figure 8: Typical Bleach Plant 

Source: U.S. EPA, 1993a. 

Semi-chemical pulps are typically bleached with hydrogen peroxide (H2O2) 

in a bleach tower. 

Mechanical pulps are bleached with hydrogen peroxide (H2O2) and/or 

sodium hydrosulfite (Na2SO3). Bleaching chemicals are either applied 

without separate equipment during the pulp processing stage (i.e., in-line 

bleaching), or in bleaching towers. Full bleaching of mechanical pulps is 

generally not practical due to bleaching chemical cost and the negative 

impact on pulp yield. 

Deinked secondary fibers are usually bleached in a bleach tower, but may 

be bleached during the repulping process. Bleach chemicals may be added 

directly into the pulper. The following are examples of chemicals used to 

bleach deinked secondary fibers: hypochlorite (HClO, NaOCl, Ca(OCl)2), 

hydrogen peroxide (H2O2), and hydrosulphite (Na2S2O4). 

Sector Notebook Project 32 November 2002 
Pulp and Paper Industry Industrial Process Description 

III.A.4. Stock Preparation 

At this final stage, the pulp is processed into the stock used for paper 

manufacture. Market pulp, which is to be shipped off-site to paper or 

paperboard mills, is simply dried and baled during this step. Processing of 

pulp in integrated mills includes pulp blending specific to the desired paper 

product desired, dispersion in water, beating and refining to add density and 

strength, and addition of any necessary wet additives. Wet additives are used 

to create paper products with special properties or to facilitate the 

papermaking process. Wet additives include resins and waxes for water 

repellency, fillers such as clays, silicas, talc, inorganic/organic dyes for 

coloring, and certain inorganic chemicals (calcium sulfate, zinc sulfide, and 

titanium dioxide) for improved texture, print quality, opacity, and brightness. 

III.A.5. Processes in Paper Manufacture 

The paper and paperboard making process consists of the following general steps: 

Table 9: Paper and Paperboard Making Process 

Sequential Process Description 

Wet End Operations Formation of paper sheet from wet 

pulp 

Dry End Operations Drying of paper product, application 

of surface treatments, spooling for 

storage 

Wet End Operations 

The processed pulp is converted into a paper product via a paper production 

machine, the most common of which is the Fourdrinier paper machine (see 

Figure 9). In the Fourdrinier system, the pulp slurry is deposited on a 

moving wire belt that carries it through the first stages of the process. Water 

is removed by gravity, vacuum chambers, and vacuum rolls. This waste 

water is recycled to the slurry deposition step of the process due to its high 

fiber content. The continuous sheet is then pressed between a series of 

rollers to remove more water and compress the fibers. 

Sector Notebook Project 33 November 2002 
Pulp and Paper Industry Industrial Process Description 

Figure 9: Fourdrinier Paper Machine 

Source: U.S. EPA, 1993a. 

Dry End Operations 

After pressing, the sheet enters a drying section, where the paper fibers begin 

to bond together as steam heated rollers compress the sheets. In the calender 

process the sheet is pressed between heavy rolls to reduce paper thickness 

and produce a smooth surface. Coatings can be applied to the paper at this 

point to improve gloss, color, printing detail, and brilliance. Lighter coatings 

are applied on-machine, while heavy coatings are performed off-machine. 

The paper product is then spooled for storage. 

III.A.6. Energy Generation 

Pulp and paper mill energy generation is provided in part from the burning 

of liquor waste solids in the recovery boiler, but other energy sources are 

Sector Notebook Project 34 November 2002 
Pulp and Paper Industry Industrial Process Description 

needed to make up the remainder of mill energy needs. Over the last 25 

years, the pulp and paper industry has changed its energy generation methods 

from fossil fuels to a greater utilization of processes or process wastes. The 

increase in use of wood wastes from the wood handling and chipping 

processes depicted in Table 10 below is one example of this industry-wide 

movement. During the 1972-1999 period, the proportion of total industry 

power generation from the combination of woodroom wastes, spent liquor 

solids, and other self-generation methods increased from about 41 percent to 

about 58 percent, while coal, fuel oil and natural gas use decreased from 

about 54 percent to about 36 percent. 

Power boilers at pulp and paper mills are sources of particulate emissions, 

sulfur dioxide (SO2), and nitrogen oxides (NOx). Pollutants emitted from 

chemical recovery boilers include SO2, and total reduced sulfur compounds 

(TRS). 

Table 10: Estimated Energy Sources for the U.S. Pulp and Paper Industry 

Energy Source 1972a 1979a 1990a 1999b 

Purchased steam 5.4% 6.7% 7.3% 1.5% 

Coal 9.8% 9.1% 13.7% 12.5% 

Fuel oil 22.3% 19.1% 6.4% 6.3% 

Natural gas 21.5% 17.8% 16.4% 17.6% 

Other purchased energy - - - 6.7% 

Waste wood and wood 

chips (Hogged fuel) and 

bark 

6.6% 9.2% 15.4% 13.5% 

Spent liquor solids 33.7% 37.3% 39.4% 40.3% 

Other self-generated power 0.6% 0.8% 1.2% 1.6% 

Sources: aAmerican Paper Institute Data as presented in Smook, 1992. b

AF&PA, 2001. 

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 

Sector Notebook Project 35 November 2002 
Pulp and Paper Industry Industrial Process Description 

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. (U.S. Department of Commerce, 2000). In 2000, a typical pulp and 

paper mill used 4,000-12,000 gallons of water per ton of pulp produced (Pulp 

and Paper, 2001). General water pollution concerns for pulp and paper mills 

are effluent solids, biochemical oxygen demand, and color. Toxicity 

concerns historically occurred from the potential presence of chlorinated 

organic compounds such as dioxins, furans, and others (collectively referred 

to as adsorbable organic halides, or AOX) in wastewaters after the 

chlorination/extraction sequence. With the substitution of chlorine dioxide 

for chlorine, effluent loads of the chlorinated compounds decreased 

dramatically. 

Due to the large volumes of water used in pulp and paper processes, virtually 

all U.S. mills have primary and secondary wastewater treatment systems 

installed to remove particulate and biochemical oxygen demand (BOD) 

produced in the manufacturing processes. These systems also provide 

significant removal (e.g., 30-70 percent) of other important parameters such 

as AOX and chemical oxygen demand (COD). 

The major sources of effluent pollutants in a pulp and paper mill are 

presented in Table 11. 

Sector Notebook Project 36 November 2002 
Pulp and Paper Industry Industrial Process Description 

Table 11: Potential Water Pollutants From Pulp and Paper Processes 

Source Effluent characteristics 

Water used in wood handling/debarking and 

chip washing 

Solids, BOD, color 

Chip digester and liquor evaporator 

condensate 

Concentrated BOD, reduced sulfur 

compounds 

"White waters" from pulp screening, 

thickening, and cleaning 

Large volume of water with suspended solids, 

can have significant BOD 

Bleach plant washer filtrates BOD, color, chlorinated organic compounds 

Paper machinewater flows Solids 

Fiber and liquor spills Solids, BOD, color 

Source: Smook, 1992. 

Wood processing operations in pulp mills often use water for a variety of 

purposes. The resulting wastewaters contain BOD, suspended solids, and 

some color. The condensates from chip digesters and chemical recovery 

evaporators are sources of BOD and reduced sulfur compounds. 

Wastewaters containing BOD, color, and suspended solids may be generated 

from pulp screening operations in mills using “atmospheric” systems, though 

most mills have modern pressure screens that virtually eliminate such 

wastewaters. Kraft bleaching generates large volumes of wastewater 

containing BOD, suspended solids, color, and chlorinated organic 

compounds. From paper machines, excess white water (named for its 

characteristic color) contains suspended solids and BOD. Fiber and liquor 

spills can also be a source of mill effluent. Typically, spills are captured and 

pumped to holding areas to reduce chemical usage through spill reuse and to 

avoid loadings on facility wastewater treatment systems. 

Wastewater treatment systems can be a significant source of cross-media 

pollutant transfer. For example, waterborne particulate and some chlorinated 

compounds settle or absorb onto treatment sludge and other compounds may 

volatilize during the wastewater treatment process. 

Sector Notebook Project 37 November 2002 
Pulp and Paper Industry Industrial Process Description 

Air 

The following table is an overview of the major types and sources of air 

pollutant releases from various pulp and paper processes: 

Table 12: Common Air Pollutants From Pulp and Paper Processes 

Source Type 

Kraft recovery furnace Fine particulates, nitrogen oxides 

Fly ash from hog fuel and coal-fired 

burners 

Coarse particulates 

Sulfite mill operations Sulfur oxides, ammonia 

Kraft pulping and recovery processes Reduced sulfur gases 

Chip digesters and liquor evaporation Volatile organic compounds 

Pulp drying (non-integrated mills) Volatile organic compounds 

All combustion processes Nitrogen oxides 

Source: Smook, 1992. 

Water vapors are the most visible air emission from a pulp and paper mill, 

but are not usually regulated unless they are a significant obscurement or 

climate modifier. 

Pulp and paper mill power boilers are generic pulp and paper mill sources of 

air pollutants such as particulates and nitrogen oxides. Chip digesters and 

chemical recovery evaporators are the most concentrated sources of volatile 

organic compounds. The chemical recovery furnace is a source of fine 

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 1,000 times lower than that 

for sulfur dioxide. Humans can detect some TRS compounds in the air as a 

"rotten egg" odor at as little as one part per billion. 

Pulp and paper mills have made significant investments in pollution control 

technologies and processes. According to industry sources, the pulp and 

Sector Notebook Project 38 November 2002 
Pulp and Paper Industry Industrial Process Description 

paper industry spent more than $1 billion per year from 1991-1997 on 

environmental capital expenditures. In 1991 and 1992, this represented 20 

percent of total capital expenditures (AF&PA, 1994). Chemical recovery and 

recycling systems in the chemical pulping process significantly reduce 

pollutant outputs while providing substantial economic return due to 

recovery of process chemicals. Chemical recovery is necessary for the basic 

economic viability of the kraft process. According to EPA sources, all kraft 

pulp mills worldwide have chemical recovery systems in place. Some sulfite 

mills, however, still do not have recovery systems in place. Scrubber system 

particulate "baghouses" or electrostatic precipitators (ESPs) are often mill air 

pollution control components. 

Residual Wastes 

The significant residual waste streams from pulp and paper mills include 

wastewater treatment sludges, lime mud, lime slaker grits, green liquor dregs, 

boiler and furnace ash, scrubber sludges, and wood processing residuals. 

Because of the tendency for chlorinated organic compounds to partition from 

effluent to solids, wastewater treatment sludge is a significant environmental 

concern for the pulp and paper industry. 

Wastewater treatment sludge is the largest volume residual waste stream 

generated by the pulp and paper industry. Sludge generation rates vary 

widely among mills. For example, bleached kraft mills surveyed as part of 

EPA’s 104-Mill Study reported sludge generation that ranged from 14 to 140 

kg of sludge per ton of pulp (U.S. EPA, 1988). Total sludge generation for 

these 104 mills was 2.5 million dry metric tons per year, or an average of 

approximately 26,000 dry metric tons per year per plant. Pulpmaking 

operations are responsible for the bulk of sludge wastes, although treatment 

of papermaking effluents also generates significant sludge volumes. For the 

majority of pulp and integrated mills that operate their own wastewater 

treatment systems, sludges are generated onsite. A small number of pulp 

mills, and a much larger proportion of papermaking establishments, 

discharge effluents to publicly-owned wastewater treatment works (POTWs). 

Potential environmental hazards fromwastewater sludges are associated with 

trace constituents (e.g., chlorinated organic compounds) that partition from 

the effluent into the sludge. It should be noted, however, that recent trends 

away from elemental chlorine bleaching have reduced these hazards. A 

continuing concern is the very high pH (>12.5) of most residual wastes. 

When these wastes are disposed of in an aqueous form, they may meet the 

RCRA definition of a corrosive hazardous waste (U.S. EPA, 2002). 

Landfill and surface impoundment disposal are most often used for 

wastewater treatment sludge, but a significant number of mills dispose of 

sludge through land application, conversion to sludge-derived products (e.g., 

Sector Notebook Project 39 November 2002 
Pulp and Paper Industry Industrial Process Description 

compost and animal bedding), or combustion for energy recovery (AF&PA, 

2002). 

Process Inputs and Pollutant Outputs 

Kraft chemical pulping and chlorine-based (e.g., hypochlorite or chlorine 

dioxide) bleaching are both commonly used and may generate significant 

pollutant outputs. Kraft pulping processes produced approximately 83 

percent of total US pulp tonnage during 1998 according to the American 

Forest and Paper Association (AF&PA, 1999). Roughly 60 percent of this 

amount is bleached in some manner. 

Pollutant outputs from mechanical, semi-chemical, and secondary fiber 

pulping are small when compared to kraft chemical pulping. In the pulp and 

paper industry, the kraft pulping process is the most significant source of air 

pollutants. The following table and figures (Table 13 and Figures 10 and 11) 

illustrate the process inputs and pollutant outputs for a pulp and paper mill 

using kraft chemical pulping and chlorine-based bleaching. The process 

outlined below produces a large portion of U.S. pulp. 

Table 13 presents the process steps, material inputs, and major pollutant 

outputs (by media) of a kraft pulp mill practicing traditional chlorine 

bleaching. The following resources are recommended for pollutant 

production data (e.g., pounds of BOD per ton of pulp produced) for those 

pollutants presented in Table 13: 

C Pollution Prevention Technologies for the Bleached Kraft Segment 

of the U.S. Pulp and Paper Industry. August 1993. (EPA-600-R-93-

110) 

C 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) 

• Pulp, Paper and Paperboard Industry - Background Information for 

Proposed Air Emission Standards: Manufacturing Processes at 

Kraft, Sulfite, Soda, and Semi-Chemical Mills, NESHAP. October 

1993. (EPA-453-R-93-050a) 

Figure 10 is a process flow diagram ofthe kraft process, illustrating chemical 

pulping, power recovery, and chemical recovery process inputs and outputs. 

Figure 11 is a schematic of characteristic air emission sources from a kraft 

mill. 

Sector Notebook Project 40 November 2002 
Pulp and Paper Industry Industrial Process Description 

Table 13: Kraft Chemical Pulped Bleached Paper Production 

Process Step 

Material 

Inputs Process Outputs Major Pollutant Outputsa 

Pollutant 

Media 

Fiber Furnish 

Preparation 

Wood logs 

Chips 

Sawdust 

Furnish chips dirt, grit, fiber, bark Solid 

BOD Water 

TSS 

Chemical 

Pulping Kraft 

process 

Furnish chips Black liquor (to 

chemical recovery 

system), pulp (to 

bleaching/ 

processing) 

resins, fatty acids Solid 

color Water 

BOD 

COD 

AOX 

VOCs [terpenes, alcohols, phenols, 

methanol, acetone, chloroform, methyl 

ethyl ketone (MEK)] 

VOCs (terpenes, alcohols, phenols, 

methanol, acetone, chloroform, MEK) 

Air 

Cooking 

chemicals: sodium 

sulfide (Na2S), 

NaOH, white 

liquor (from 

chemical recovery) 

reduced sulfur compounds (TRS) 

organo-chlorine compounds (e.g., 

3,4,5- trichloroguaiacol) 

Bleachingb Chemical pulp Bleached pulp dissolved lignin and carbohydrates Water 

color 

COD 

AOX 

inorganic chlorine compounds 

(e.g., chlorate (ClO3 

-

))c 

Hypochlorite 

(HClO, NaOCl, 

Ca(OCl)2) 

Chlorine dioxide 

(ClO2) 

VOCs (acetone, methylene chloride, 

chloroform, MEK, chloromethane, 

trichloroethane) 

Air / Water 

Papermaking Additives, 

Bleached/ 

Unbleached pulp 

Paper/paperboard 

product 

particulate wastes Water 

organic compounds 

inorganic dyes 

COD 

acetone 

Sector Notebook Project 41 November 2002 
Pulp and Paper Industry Industrial Process Description 

Table 13: Kraft Chemical Pulped Bleached Paper Production (continued) 

Process Step Material 

Inputs 

Process Outputs Major Pollutant Outputsa Pollutant 

Media 

Wastewater 

Treatment 

Facilities 

Process 

wastewaters 

Treated effluent sludge Solid 

VOCs (terpenes, alcohols, phenols, 

methanol, acetone, chloroform, MEK) 

Air 

BOD Water 

TSS 

COD 

color 

chlorophenolics 

VOCs (terpenes, alcohols, phenols, 

methanol, acetone, chloroform, MEK) 

Power Boiler Coal, 

Wood, 

Unused furnish 

Energy bottom ash: incombustible fibers Solid 

SO2, NOx, fly ash, coarse particulates Air 

Chemical Recovery System 

Evaporators Black liquor Strong black liquor evaporator noncondensibles (TRS, 

volatile organic compounds: alcohols, 

terpenes, phenols) 

Air 

evaporator condensates (BOD, 

suspended solids) 

Water 

Recovery 

Furnace 

Strong black liquor Smelt fine particulates, TRS, SO2, NOx Air 

Energy 

Recausticizing Smelt Regenerated white 

liquor 

dregs Solids 

Lime mud waste mud solids Water, 

Solid 

Slaker grits solids Solid 

Calcining 

(Lime Kiln) 

Lime mud Lime fine and coarse particulates Air 

a

 Pollutant outputs may differ significantly based on mill processes and material inputs (e.g., wood chip resin content). b

 Pollutant list based on Elemental Chlorine Free (ECF) bleaching technologies. c

 Chlorate only significantly produced in mills with high rates of chlorine dioxide use.

Sources: EPA, 1993a; EPA, 1993b; and EPA, 1993c. 

Sector Notebook Project 42 November 2002 
Pulp and Paper Industry Industrial Process Description 

Figure 10: Kraft Process Flow Diagram 

Source: Smook, 1992. 

Sector Notebook Project 43 November 2002 
Pulp and Paper Industry Industrial Process Description 

Figure 11: Air Pollutant Output from Kraft Process 

Source: Smook, 1992. 

Sector Notebook Project 44 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

IV. CHEMICAL RELEASE AND OTHER WASTE MANAGEMENT PROFILE 

This section is designed to provide background information on the pollutant 

releases that are reported by this industry in correlation with other industries. 

The best source of comparative pollutant release and other waste 

management information is the Toxic Release Inventory (TRI). Pursuant to 

the Emergency Planning and Community Right-to-Know Act, TRI includes 

self-reported facility release and other waste management data for over 650 

toxic chemicals and chemical categories. Facilities within SIC Codes 10 

(except 1011, 1081, and 1094), 12 (except 1241), 20-39, 4911 (limited to 

facilities that combust coal and/or oil for the purpose of generating electricity 

for distribution in commerce), 4931 (limited to facilities that combust coal 

and/or oil for the purpose of generating electricity for distribution in 

commerce), 4939 (limited to facilities that combust coal and/or oil for the 

purpose of generating electricity for distribution in commerce), 4953 (limited 

to facilities regulated under the RCRA Subtitle C, 42 U.S.C. section 6921 et 

seq.), 5169, 5171, and 7389 (limited to facilities primarily engaged in 

solvents recovery services on a contract or fee basis) have more than 10 

employees, and that manufactures, processes or otherwise uses listed 

chemical in quantities greater than the established threshold in the course of 

a calendar year are required to report to TRI annually release and other waste 

management quantities (on- and off-site). The information presented within 

the sector notebooks is derived from the most recently available (2000) TRI 

reporting year (which includes over 650 chemicals and chemical categories), 

and focuses primarily on the on-site releases reported by each sector. 

Because TRI requires consistent reporting regardless of sector, it is an 

excellent tool for drawing comparisons across industries. TRI data provide 

the type, amount and media receptor of each chemical released or otherwise 

managed as waste. 

Although this sector notebook does not present historical information 

regarding TRI chemical releases over time, please note that in general, toxic 

chemical releases have been declining. In fact, according to the 2000 Toxic 

Release Inventory Public Data Release, reported on-site and off-site releases 

of toxic chemicals to the environment from original TRI reporting industries 

(SIC codes 20-39) decreased by more than 8 percent (644 million pounds) 

between 1999 and 2000 (not including chemicals added and removed from 

the TRI chemical list during this period). Reported on-site releases dropped 

by almost 57 percent between 1988 and 2000. Reported transfers of TRI 

chemicals to off-site locations for disposal increased by almost 7 percent (28 

million pounds) between 1988 and 2000. More detailed information can be 

obtained from EPA's annual Toxics Release Inventory Public Data Release 

Report (which is available through the EPCRA Call Center at 800-424-9346), 

or directly from the Internet at www.epa.gov/tri. 

Sector Notebook Project 45 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

Wherever possible, the sector notebooks present TRI data as the primary 

indicator of chemical release within each industrial category. TRI data 

provide the type, amount and media receptor of each chemical released or 

otherwise managed as waste. When other sources of pollutant release data 

have been obtained, these data have been included to augment the TRI 

information. 

TRI Data Limitations 

Certain limitations exist regarding TRI data. Within some sectors, (e.g., 

printing and transportation equipment cleaning) the majority of facilities are 

not subject to TRI reporting either because they do not fall under covered 

SIC codes, or because they are below the TRI reporting threshold amounts. 

However, EPA lowered threshold amounts for persistent bioaccumulative 

toxic (PBT) chemicals starting reporting year 2000. For these sectors, 

release information from other sources has been included. In addition, many 

facilities report to TRI under more than one SIC code, reflecting the multiple 

operations carried out onsite whether or not the operations are the facilities’ 

primary area of business as reported to the U.S. Census Bureau. Reported 

chemicals are limited to the approximately 650 TRI chemicals and chemical 

categories. A portion of the emissions from pulp and paper mills, therefore, 

are not captured by TRI. Also, reported releases and other waste 

management quantities may or may not all be associated with the industrial 

operations described in this notebook. 

The reader should also be aware that 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 and population 

exposure levels to each chemical released so that one can differentiate 

between pollutants with significant differences in toxicity. This project, the 

Risk Screening Environmental Indicators Model, can be found at 

http://www.epa.gov/opptintr/rsei/. 

As a preliminary indication of the environmental impact of the industry's 

most commonly released chemicals, this notebook briefly summarizes the 

toxicological properties of the top five chemicals (by weight) reported by the 

organic chemical industry. 

Definitions Associated with Section IV Data Tables 

General Definitions 

Sector Notebook Project 46 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

SIC Code -- is the Standard Industrial Classification (SIC) is a statistical 

classification standard used for all establishment-based Federal economic 

statistics. The SIC codes facilitate comparisons between facility and industry 

data. 

TRI Facilities -- are facilities that are within specified SIC codes that have 

10 or more full-time employees and are above established threshold amounts 

for manufacture or process or otherwise use activities in the course of a 

calendar year. These facilities are in standard industrial classification codes 

10 (except 1011, 1081, and 1094), 12 (except 1241), 20-39, 4911 (limited to 

facilities that combust coal and/or oil for the purpose of generating electricity 

for distribution in commerce), 4931 (limited to facilities that combust coal 

and/or oil for the purpose of generating electricity for distribution in 

commerce), 4939 (limited to facilities that combust coal and/or oil for the 

purpose of generating electricity for distribution in commerce), 4953 (limited 

to facilities regulated under the RCRA Subtitle C, 42 U.S.C. section 6921 et 

seq.), 5169, 5171, and 7389 (limited to facilities primarily engaged in 

solvents recovery services on a contract or fee basis), and federal facilities. 

Facilities must submit release and other waste management estimates for all 

chemicals that are on the EPA's defined list and are above manufacturing or 

processing or otherwise use thresholds. 

Data Table Column Heading Definitions 

The following definitions are based upon standard definitions developed by 

EPA’s Toxic Release Inventory Program. The categories below represent the 

possible pollutant destinations that can be reported. 

ON-SITE RELEASES -- are an on-site discharge of a toxic chemical to the 

environment. This includes emissions to the air, discharges to bodies of 

water, releases at the facility to land, as well as contained disposal into 

underground injection wells. 

Releases to Air (Point and Fugitive Air Emissions) -- Include all air 

emissions from industry activity. Point emissions occur through confined air 

streams as found in stacks, ducts, or pipes. Fugitive emissions include losses 

from equipment leaks, or evaporative losses from impoundments, spills, or 

leaks. 

Releases to Water (Surface Water Discharges) -- encompass any releases 

going directly to streams, rivers, lakes, oceans, or other bodies of water. Any 

estimates for storm water runoff and non-point losses must also be included. 

Releases to Land -- includes disposal of toxic chemicals in waste to on-site 

landfills, land treated or incorporation into soil, surface impoundments, 

Sector Notebook Project 47 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

spills, leaks, or waste piles. These activities must occur within the facility's 

boundaries for inclusion in this category. 

Underground Injection -- is a contained release of a fluid into a subsurface 

well for the purpose of waste disposal. 

TRANSFERS -- is a transfer of toxic chemicals in wastes to a facility that 

is geographically or physically separate from the facility reporting under 

TRI. The quantities reported represent a movement of the chemical away 

from the reporting facility. Except for off-site transfers for disposal, these 

quantities do not necessarily represent entry of the chemical into the 

environment. 

Transfers to POTWs -- are waste waters transferred through pipes or sewers 

to a publicly owned treatments works (POTW). Treatment and chemical 

removal depend on the chemical's nature and treatment methods used. 

Chemicals not treated or destroyed by the POTW are generally released to 

surface waters or land filled within the sludge. Metals and metal compounds 

transferred to POTWs are considered as released to surface water. 

Transfers to Recycling -- are sent off-site for the purposes of regenerating 

or recovering still valuable materials. Once these chemicals have been 

recycled, they may be returned to the originating facility or sold 

commercially. 

Transfers to Energy Recovery -- are wastes combusted off-site in industrial 

furnaces for energy recovery. Treatment of a chemical by incineration is not 

considered to be energy recovery. 

Transfers to Treatment -- are wastes moved off-site for either 

neutralization, incineration, biological destruction, or physical separation. 

In some cases, the chemicals are not destroyed but prepared for further waste 

management. 

Transfers to Disposal -- are wastes taken to another facility for disposal 

generally as a release to land or as an injection underground. 

IV.A. EPA Toxics Release Inventory For the Pulp and Paper Industry 

According to Toxic Release Inventory (TRI) data from SIC codes 261-263, 

the pulp and paper industry released (to the air, water, or land) and 

transferred (shipped off-site) a total of approximately 263 million pounds of 

Sector Notebook Project 48 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

toxic chemicals during calendar year 2000.1 This represents approximately 

2.5 percent of the total pounds of TRI chemicals released and transferred by 

all reporting facilities that year. 

Media comparison of TRI releases 

The total amount of TRI toxic chemicals generated by the pulp and paper 

industry is a gross profile of the types and relative amounts of chemical 

outputs from mill processes. Additional information which can be related 

back to possible compliance requirements is available from the distribution 

of chemical releases across specific media within the environment. The TRI 

data requires filers to separate the total releases for the pulp and paper 

industry for air, water, and land releases. This distribution across media can 

also be compared to the profile of other industry sectors. 

The pulp and paper industry releases 66 percent of its total TRI poundage to 

the air, approximately 22 percent to water and POTWs, and 9 percent is 

disposed on land (on site and off site). This release profile differs from other 

TRI industries which average approximately 63 percent to land, 27 percent 

to air, and 4 percent to water and POTWs. A larger proportion of water 

releases correlates with the water intensive processes of the pulp and paper 

industry. An average mill requires 10 million gallons of influent water per 

day and will produce the corresponding amount of effluent waters. 

Examining the pulp and paper industry's TRI reported toxic chemicals by 

chemical, highlights the likely origins of industry releases (see Table 14). 

Air releases can be traced to a variety of sources. Approximately 63 percent 

are methanol, a by-product of the pulp making process. The other major air 

toxic chemicals, such as chlorinated compounds and sulfuric acid, originate 

in the bleaching stage. Methanol is the most frequently reported chemical by 

pulp and paper mills, and it accounts for approximately 15 percent of the 

water releases and 97 percent of transfers to POTWs by the industry. 

Overall, methanol represents roughly 60 percent of the pulp and paper 

industry's TRI releases and transfers. 

The diversity of processes in the pulp and paper industry can be seen in the 

diversity of chemicals found in the TRI report. The TRI chemical released 

and transferred by the second largest number of mills is ammonia, which is 

used as a buffer in acid sulfite pulping (Air & Waste Management 

Association, 1992). In addition, some TRI chemicals are only reported by a 

few mills, suggesting process specific needs such as paper finishing or use 

in wet additives. 

1 Unless otherwise indicated, TRI data for SIC codes 261-263 were used for pulp and paper release and transfer 

values in this section and the tables therein. 

Sector Notebook Project 49 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

Table 14: 2000 TRI Releases for Pulp and Paper Facilities (SICs 261, 262 and 263), 

by Number of Facilities Reporting (Releases Reported in pounds/year) 

Chemical Name 

# Reporting 

Chemical 

Fugitive 

Air 

Point 

Air 

Water 

Discharges 

Underground 

Injection 

Land 

Disposal 

Total 

Releases 

Avg. Releases 

Per Facility 

Methanol 174 5,368,130 105,189,904 3,011,860 1,014,710 114,584,624 658,532 

Ammonia 166 514,616 15,782,909 1,884,126 11,939 18,193,590 109,600 

Hydrochloric Acid (1995 and after "Acid 

Aerosols" 

137 8,037 16,114,754 10 16,122,801 117,685 

Acetaldehyde 125 540,704 7,749,806 177,092 3,789 8,471,391 67,771 

Manganese Compounds 124 1,932 199,238 4,187,964 8,733,410 13,122,544 105,827 

Polycyclic Aromatic Compounds[PBT] 122 57 114,967 1,472 2,458 118,954 975 

Formaldehyde 116 57,062 1,865,446 326,507 9,651 2,258,666 19,471 

Sulfuric Acid (1994 and after "Acid 

Aerosols" Only 

113 773 9,670,724 9,671,497 85,588 

Phenol 105 14,983 1,105,065 9,244 3,209 1,132,501 10,786 

Chlorine 102 25,236 449,437 60,185 17 534,875 5,244 

Catechol 99 11 256 17,493 605 18,365 186 

Barium Compounds 96 13 252,753 540,545 2,351,605 3,144,916 32,760 

Nitrate Compounds 87 9,791,260 9,234 9,800,494 112,649 

Chlorine Dioxide 80 2,215 701,625 703,840 8,798 

Dioxin and Dioxin-Like 

Compounds[PBT] 

77 55 103 162 320 4 

Zinc Compounds 77 19 775,453 324,492 3,255,589 4,355,553 56,566 

Mercury Compounds[PBT] 75 1 2,149 56 535 2,741 37 

Methyl Ethyl Ketone 64 98,368 1,024,379 14,909 5,013 1,142,669 17,854 

Benzo(g,h,i)perylene[PBT] 63 1,060 115 163 1,338 21 

Formic Acid 54 1,210 1,105 92,178 2,211 96,704 1,791 

Chloroform 40 1,076,881 1,810,096 49,459 12,285 2,948,721 73,718 

Cresol (Mixed Isomers) 32 363 827,255 1,097 708 829,423 25,919 

Mercury[PBT] 23 544 8 94 646 28 

Hydrogen Fluoride 17 442,166 442,166 26,010 

Vanadium Compounds 16 6,102 51,541 20,204 635,418 713,265 44,579 

Chloromethane 15 62 492,139 10 5 492,216 32,814 

Copper Compounds 15 8,343 3,591 50,429 62,363 4,158 

Nickel Compounds 13 8,021 3,337 94,451 105,809 8,139 

Certain Glycol Ethers 12 17,410 54,925 7,919 2,602 82,856 6,905 

Chromium Compounds 9 30 1,409 10,341 32,731 44,511 4,946 

Ethylene Glycol 9 60 2,316 29,596 5,810 37,782 4,198 

Toluene 9 81,244 638,734 19 719,997 80,000 

Xylene (Mixed Isomers) 7 33,224 41,507 202 1,260 76,193 10,885 

Polychlorinated Biphenyls[PBT] 7 31 31 4 

Styrene 5 19,000 53,239 104 72,343 14,469 

C.i. Direct Blue 218 5 20 1,704 1,724 345 

Manganese 5 11,163 94,428 500,902 606,493 121,299 

Benzene 3 276,814 276,814 92,271 

Dazomet 3 2,792 600 3,392 1,131 

Vinyl Acetate 3 12,303 16,900 880 30,083 10,028 

Biphenyl 3 117,000 117,000 39,000 

1,2,4-trimethylbenzene 3 20,920 13,396 180 10 34,506 11,502 

Diethanolamine 3 549 6,505 974 8,028 2,676 

N-butyl Alcohol 3 29,759 61,970 10,943 102,672 34,224 

Nitric Acid 2 10 1,310 1,320 660 

Decabromodiphenyl Oxide 2 5 1,100 1,105 552 

Antimony 2 350 350 175 

Lead Compounds[PBT] 2 1,698 796 2,494 1,247 

N-hexane 2 4,100 46,100 50,200 25,100 

Arsenic Compounds 2 360 6 366 183 

Lead[PBT] 1 

Antimony Compounds 1 

Sector Notebook Project 50 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

Table 14: 2000 TRI Releases for Pulp and Paper Facilities (SICs 261, 262 and 263), 

by Number of Facilities Reporting (Releases Reported in pounds/year) 

Chemical Name 

# Reporting 

Chemical 

Fugitive 

Air 

Point 

Air 

Water 

Discharges 

Underground 

Injection 

Land 

Disposal 

Total 

Releases 

Avg. Releases 

Per Facility 

Chlordane[PBT] 1 

Maleic Anhydride 1 200 210 410 410 

Ethylbenzene 1 290 90 380 380 

Potassium Dimethyldithiocarbamate 1 19 10,394 10,413 10,413 

O-xylene 1 15 46,430 5 46,450 46,450 

Diisocyanates 1 750 750 750 

Ozone 1 102,763 102,763 102,763 

Naphthalene 1 83 17,000 1 4,800 21,884 21,884 

Copper 1 

Methyl Methacrylate 1 750 1,154 1,904 1,904 

Acrylic Acid 1 1 280 281 281 

Trichloroethylene 1 

Dichloromethane 1 6 33,316 1 33,323 33,323 

Polychlorinated Alkanes 1 

Barium 1 250 250 500 500 

Mixture 1 1 4 5 5 

268** 7,940,291 166,187,814 20,684,970 0 16,749,220 211,562,315 789,411 

[PBT] Persistent, Bioaccumulative, and Toxic 

* Refer to Section III for a discussion of the TRI data and its limitations, methodology used to obtain this data, definitions of the column headings,

and the definition of persistant, bioaccumulative, and toxic chemicals. 

**Total number of facilities (not chemical reports) reporting to TRI in this industry sector.

Sector Notebook Project 51 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

Table 15: 2000 TRI Transfers for Pulp and Paper Facilities (SICs 261, 262 and 263), 

by Number of Facilities Reporting (Transfers Reported in pounds/year) 

Chemical Name 

# Reporting 

Chemical 

POTW 

Transfers 

Disposal 

Transfers 

Recycling 

Transfers 

Treatment 

Transfers 

Energy 

Recovery 

Total 

Transfers 

Avg Transfers 

Per Facility 

Methanol 174 36,098,617 144,671 24,058 6,993,725 13,736 43,274,807 248,706 

Ammonia 166 56,000 79,785 2,966 138,751 836 

Hydrochloric Acid (1995 and after "Acid 

Aerosols" 

137 

Acetaldehyde 125 111,435 757 25 10,100 122,317 979 

Manganese Compounds 124 204,150 2,977,098 152,646 3,333,894 26,886 

Polycyclic Aromatic Compounds[PBT] 122 1,224 1,257 52 5 129 2,667 22 

Formaldehyde 116 116,817 18,814 63 53,825 279 189,798 1,636 

Sulfuric Acid (1994 and after "Acid 

Aerosols" Only 

113 5 5 0 

Phenol 105 16,753 2,372 15 4,983 2,529 26,652 254 

Chlorine 102 14,443 1 14,444 142 

Catechol 99 66,175 602 3 630 2,250 69,660 704 

Barium Compounds 96 41,058 1,316,911 86,502 1,444,471 15,047 

Nitrate Compounds 87 40,310 38,220 118,370 196,900 2,263 

Chlorine Dioxide 80 

Dioxin and Dioxin-Like Compounds[PBT] 77 21 101 6 10 138 2 

Zinc Compounds 77 30,256 1,129,573 72,525 1,232,354 16,005 

Mercury Compounds[PBT] 75 14 23,862 95 23,971 320 

Methyl Ethyl Ketone 64 56,874 680 4,350 20,062 38,121 120,087 1,876 

Benzo(g,h,i)perylene[PBT] 63 7 101 3 2 2 115 2 

Formic Acid 54 6,334 251 6,585 122 

Chloroform 40 155,257 8,630 308 164,195 4,105 

Cresol (Mixed Isomers) 32 4,448 394 1,600 6,442 201 

Mercury[PBT] 23 485 485 21 

Hydrogen Fluoride 17 

Vanadium Compounds 16 1,400 88,540 11,463 101,403 6,338 

Chloromethane 15 306 306 20 

Copper Compounds 15 1,515 64,245 65,760 4,384 

Nickel Compounds 13 2,120 91,928 180 94,228 7,248 

Certain Glycol Ethers 12 815 815 68 

Chromium Compounds 9 1,351 71,901 1,000 74,252 8,250 

Ethylene Glycol 9 24,658 2,810 84,004 111,472 12,386 

Toluene 9 220 383,822 384,042 42,671 

Xylene (Mixed Isomers) 7 5 10,291 10,296 1,471 

Polychlorinated Biphenyls[PBT] 7 207 57 264 38 

Styrene 5 160 750 910 182 

C.i. Direct Blue 218 5 1,984 3,848 1,065 6,897 1,379 

Manganese 5 38,661 38,661 7,732 

Benzene 3 

Dazomet 3 13,535 13,535 4,512 

Vinyl Acetate 3 19 19 6 

Biphenyl 3 

1,2,4-trimethylbenzene 3 4 4 1 

Diethanolamine 3 36,070 483 715 37,268 12,423 

N-butyl Alcohol 3 

Nitric Acid 2 

Decabromodiphenyl Oxide 2 26,600 26,600 13,300 

Antimony 2 251 6,650 6,901 3,450 

Lead Compounds[PBT] 2 127,400 127,400 63,700 

N-hexane 2 11,000 11,000 5,500 

Arsenic Compounds 2 120 24,200 24,320 12,160 

Lead[PBT] 1 350 350 350 

Antimony Compounds 1 2,200 2,200 2,200 

Chlordane[PBT] 1 50 50 50 

Maleic Anhydride 1 

Ethylbenzene 1 840 840 840 

Potassium Dimethyldithiocarbamate 1 

O-xylene 1 

Diisocyanates 1 

Ozone 1 

Naphthalene 1 

Copper 1 675 675 675 

Sector Notebook Project 52 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

Table 15: 2000 TRI Transfers for Pulp and Paper Facilities (SICs 261, 262 and 263), 

by Number of Facilities Reporting (Transfers Reported in pounds/year) 

Chemical Name 

# Reporting 

Chemical 

POTW 

Transfers 

Disposal 

Transfers 

Recycling 

Transfers 

Treatment 

Transfers 

Energy 

Recovery 

Total 

Transfers 

Avg Transfers 

Per Facility 

Methyl Methacrylate 1 750 750 750 

Acrylic Acid 1 

Trichloroethylene 1 4,985 4,985 4,985 

Dichloromethane 1 

Polychlorinated Alkanes 1 24,000 24,000 24,000 

Barium 1 5,100 5,100 5,100 

Mixture 1 

268** 37,103,508 6,306,166 354,926 7,316,423 463,018 51,544,041 192,328 

[PBT] Persistent, Bioaccumulative, and Toxic 

* Refer to Section III for a discussion of the TRI data and its limitations, methodology used to obtain this data, definitions of the column headings,

and the definition of persistant, bioaccumulative, and toxic chemicals. 

**Total number of facilities (not chemical reports) reporting to TRI in this industry sector.

Sector Notebook Project 53 November 2002 
1

2

3

4

5

6

7

8

9

10

Pulp and Paper Industry Chemical Releases and Transfers 

The TRI database contains a detailed compilation of self-reported, facilityspecific chemical releases. The top reporting facilities for this sector are 

listed below (Table 16). 

Table 16: Ten Largest Volume TRI Releasing Facilities in the Pulp and Paper Industry* 

Rank Facility Total TRI Releases in 

Pounds 

Westvaco Corporation - Covington, VA 5,066,296 

International Paper - Mansfield, LA 4,472,550 

International Paper Company Camden Facility - Camden, AR 3,842,484 

International Paper - Bleachboard Department - Riegelwood, NC 3,619,809 

Georgia Pacific Corporation Port Hudson Operations - Zachary, LA 3,292,540 

Smurfit Stone Container Corporation - Missoula, MT 3,133,396 

Great Southern Paper Co - Cedar Springs, GA 3,125,666 

Stora Enso North America Corporation - Wisconsin Rapids, WI 3,095,151 

Weyerhaeuser Company - Valliant, OK 3,041,630 

International Paper Georgetown Mill - Georgetown, SC 2,967,101 

Source: 2000 Toxics Release Inventory Database 

* Being included in this list does not mean that the release is associated with non-compliance with environmental laws. 

IV.B. Summary of Selected Chemicals Released 

The following is a synopsis of current scientific toxicity and fate information 

for the top chemicals (by weight) that facilities within this sector selfreported as released to the environment based upon 2000 TRI data. Because 

this section is based upon self-reported release data, it does not attempt to 

provide information on management practices employed by the sector to 

reduce the releases of these chemicals. Information regarding pollutant 

release reductions over time may be available from EPA’s TRI program, or 

directly from the industrial trade associations that are listed in Section IX of 

this document. Since these descriptions are cursory, please consult the 

sources referenced below for a more detailed description of both the 

chemicals described in this section, and the chemicals that appear on the full 

list of TRI chemicals appearing in Section IV.A. 

The brief descriptions provided below were taken from the Hazardous 

Substances Data Bank (HSDB), accessed via TOXNET. TOXNET is a 

computer system run by the National Library of Medicine. It includes a 

number of toxicological databases managed by EPA, National Cancer 

Sector Notebook Project 54 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

Institute, and the National Institute for Occupational Safety and Health.2 

HSDB contains chemical-specific information on manufacturing and use, 

chemical and physical properties, safety and handling, toxicity and 

biomedical effects, pharmacology, environmental fate and exposure 

potential, exposure standards and regulations, monitoring and analysis 

methods, and additional references. The information contained below is 

based upon exposure assumptions that have been conducted using standard 

scientific procedures. The effects listed below must be taken in context of 

these exposure assumptions that are more fully explained within the full 

chemical profiles in HSDB. For more information on TOXNET, contact the 

TOXNET help line at 800-231-3766 or see the website at 

http://toxnet.nlm.nih.gov/. 

Methanol (CAS: 67-56-1) 

Toxicity. Methanol is readily absorbed from the gastrointestinal tract and the 

respiratory tract, and is toxic to humans in moderate to high doses. In the 

body, methanol is converted into formaldehyde and formic acid. Methanol 

is excreted as formic acid. Observed toxic effects at high dose levels 

generally include central nervous system damage and blindness. Long-term 

exposure to high levels of methanol via inhalation cause liver and blood 

damage in animals. 

Ecologically, methanol is expected to have low toxicity to aquatic organisms. 

Concentrations lethal to half the organisms of a test population are expected 

to exceed one milligram of methanol per liter of water. Methanol is not 

likely to persist in water or to bioaccumulate in aquatic organisms. 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

Environmental Fate. Liquid methanol is likely to evaporate when left 

exposed. Methanol reacts in air to produce formaldehyde which contributes 

to the formation of air pollutants. In the atmosphere it can react with other 

atmospheric chemicals or be washed out by rain. Methanol is readily 

degraded by microorganisms in soils and surface waters. 

Physical Properties. Methanol is highly flammable. 

2 Databases included in TOXNET are: CCRIS (Chemical Carcinogenesis Research Information System), DART 

(Developmental and Reproductive Toxicity Database), DBIR (Directory of Biotechnology Information Resources), 

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). 

Sector Notebook Project 55 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

Ammonia (CAS: 7664-41-7) 

Toxicity. Anhydrous ammonia is irritating to the skin, eyes, nose, throat, and 

upper respiratory system. 

Ecologically, ammonia is a source of nitrogen (an essential element for 

aquatic plant growth), and may therefore contribute to eutrophication of 

standing or slow-moving surface water, particularly in nitrogen-limited 

waters such as the Chesapeake Bay. In addition, aqueous ammonia is 

moderately toxic to aquatic organisms. 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

Environmental Fate. Ammonia combines with sulfate ions in the 

atmosphere and is washed out by rainfall, resulting in rapid return of 

ammonia to the soil and surface waters. 

Ammonia is a central compound in the environmental cycling of nitrogen. 

Ammonia in lakes, rivers, and streams is converted to nitrate. 

Physical Properties. Ammonia is a corrosive and severely irritating gas 

with a pungent odor. 

Hydrochloric Acid (CAS: 7647-01-1) 

Toxicity. Hydrochloric acid is primarily a concern in its aerosol form. Acid 

aerosols have been implicated in causing and exacerbating a variety of 

respiratory ailments. Dermal exposure and ingestion of highly concentrated 

hydrochloric acid can result in corrosivity. 

Ecologically, accidental releases of solution forms of hydrochloric acid may 

adversely affect aquatic life by including a transient lowering of the pH (i.e., 

increasing the acidity) of surface waters. 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

Environmental Fate. Releases of hydrochloric acid to surface waters and 

soils will be neutralized to an extent due to the buffering capacities of both 

systems. The extent of these reactions will depend on the characteristics of 

the specific environment. 

Physical Properties. Concentrated hydrochloric acid is highly corrosive. 

Sector Notebook Project 56 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

Manganese Compounds 

Toxicity. Manganese is an essential nutrient for most plants and animals. 

However, at high concentrations can produce an irreversible syndrome 

resembling Parkinson's disease. 

Carcinogenicity. There is currently no evidence to suggest that manganese 

chemicals are carcinogenic. 

Environmental Fate. As ions or insoluble solids, most manganese 

compounds are not expected to volatilize from water and moist soil surfaces. 

Manganese compounds released into the ambient atmosphere are expected 

to exist in the particulate phase. In the particulate phase, manganese 

compounds may be removed from the air by wet and dry deposition. 

Manganese compounds do not bioconcentrate in humans and animals. 

Sulfuric Acid (CAS: 7664-93-9) 

Toxicity. Concentrated sulfuric acid is corrosive. In its aerosol form, 

sulfuric acid has been implicated in causing and exacerbating a variety of 

respiratory ailments. 

Ecologically, accidental releases of solution forms of sulfuric acid may 

adversely affect aquatic life by inducing a transient lowering of the pH (i.e., 

increasing the acidity) of surface waters. In addition, sulfuric acid in its 

aerosol form is also a component of acid rain. Acid rain can cause serious 

damage to crops and forests. 

Carcinogenicity. There is currently no evidence to suggest that this 

chemical is carcinogenic. 

Environmental Fate. Releases of sulfuric acid to surface waters and soils 

will be neutralized to an extent due to the buffering capacities of both 

systems. The extent of these reactions will depend on the characteristics of 

the specific environment. 

In the atmosphere, aerosol forms of sulfuric acid contribute to acid rain. 

These aerosol forms can travel large distances from the point of release 

before the acid is deposited on land and surface waters in the form of rain. 

IV.C. Other Data Sources 

The toxic chemical release data obtained from TRI captures the vast 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, 

Sector Notebook Project 57 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

to the approximately 650 required by TRI. Some pulp and paper emissions 

may not be captured by TRI. The EPA Office of Air Quality, Planning, and 

Standards has compiled air pollutant emission factors for determining the 

total air emissions of priority pollutants (e.g., total hydrocarbons, SOx, NOx, 

CO, particulates, etc.) from many sources. 

The EPA Office of Air’s Aerometric Information Retrieval System (AIRS) 

contains a wide range of information related to stationary sources of air 

pollution, including the emissions of a number of air pollutants which may 

be of concern within a particular industry. With the exception of volatile 

organic compounds (VOCs), there is little overlap with the TRI chemicals 

reported above. Table 17 summarizes releases in 2001 of volatile organic 

compounds (VOCs), nitrogen oxides (NOx), carbon monoxide (CO), sulfur 

dioxide (SO2), and particulate matter of 10 microns or less (PM10). 

Table 17: Air Pollutant Releases by Industry Sector (tons/year) 

Industry Sector CO NO2 PM10 PM25 SO2 VOC 

Metal Mining 8,039 45,341 61,358 32,534 10,926 2,109 

Oil and Gas Extraction 151,763 366,793 4,607 4,379 226,208 94,549 

Non-Fuel, Non-Metal Mineral Mining 27,001 15,747 48,760 20,956 16,874 3,806 

Textiles 7,448 15,043 5,343 3,386 25,544 18,286 

Lumber and Wood Products 142,955 37,313 57,009 38,337 9,189 100,761 

Wood Furniture and Fixtures 7,046 3,008 6,905 5,260 2,779 62,457 

Pulp and Paper 567,542 318,263 85,403 63,577 488,029 144,373 

Printing 604 2,466 1,723 1,723 1,915 80,982 

Inorganic Chemicals 176,697 94,938 19,549 12,586 201,994 43,563 

Plastic Resins and Man-made Fibers 28,890 56,946 5,493 4,155 71,815 83,363 

Pharmaceuticals 2,662 14,676 2,273 1,455 17,132 13,407 

Organic Chemicals 128,454 166,398 34,637 16,900 102,461 159,319 

Agricultural Chemicals 18,492 65,389 10,257 7,311 65,765 12,700 

Petroleum Refining 438,375 298,602 33,620 26,870 478,998 161,207 

Rubber and Plastic 2,515 9,565 5,209 3,217 20,368 87,258 

Stone, Clay, Glass and Concrete 161,113 372,679 127,283 78,647 312,740 32,687 

Iron and Steel 1,080,576 105,794 60,962 47,501 307,981 44,608 

Metal Castings 104,350 6,298 22,393 15,654 4,770 17,285 

Nonferrous Metals 418,647 30,882 24,019 17,433 244,413 8,663 

Fabricated Metal Products 6,029 11,672 4,691 3,264 18,742 90,575 

Electronics and Computers 22,105 6,428 3,184 2,349 6,882 27,453 

Motor Vehicle Assembly 13,439 15,388 4,016 2,270 24,123 95,861 

Aerospace 2,832 7,413 1,834 1,287 5,363 7,440 

Shipbuilding and Repair 471 2,139 1,574 753 2,537 4,984 

Ground Transportation 711,155 6,681,163 285,932 165,029 12,976,279 191,063 

Water Transportation 83 153 2,162 733 66 6,787 

Air Transportation 5,231 2,079 186 140 90 2,398 

Fossil Fuel Electric Power 436,151 5,789,099 252,539 141,002 12,667,567 54,727 

Dry Cleaning 217 438 190 117 220 3,163 

Source: U.S. EPA Office of Air and Radiation, AIRS Database, 2001. 

Sector Notebook Project 58 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

IV.D. Comparison of Toxic Release Inventory Between Selected Industries 

The following information is presented as a comparison of pollutant release 

and transfer data across industrial categories. It is provided to give a general 

sense as to the relative scale of releases and transfers within each sector 

profiled under this project. Please note that the following figure and table do 

not contain releases and transfers for industrial categories that are not 

included in this project, and thus cannot be used to draw conclusions 

regarding the total release and transfer amounts that are reported to TRI. 

Similar information is available within the annual TRI Public Data Release 

Report. 

Figure 12 is a graphical representation of a summary of the 2000 TRI data for 

the Pulp and Paper industry and the other sectors profiled in separate 

notebooks. The bar graph presents the total TRI releases and total transfers 

on the left axis and the triangle points show the average releases per facility 

on the right axis. Industry sectors are presented in the order of increasing 

total TRI releases. The graph is based on the data shown in Table 17 and is 

meant to facilitate comparisons between the relative amounts of releases, 

transfers, and releases per facility both within and between these sectors. The 

reader should note, however, that differences in the proportion of facilities 

captured by TRI exist between industry sectors. This can be a factor of poor 

SIC matching and relative differences in the number of facilities reporting to 

TRI from the various sectors. In the case of Pulp and Paper industry the 

2000 TRI data presented here covers 268 facilities. These facilities listed SIC 

2611-2631 (Pulp, Paper, and Paperboard Mills) as primary SIC codes. 

Sector Notebook Project 59 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers 

Figure 12: 2000 Summary of TRI Releases and Transfers by Industry 

0 

50 

100 

150 

200 

250 

300 

350 

400 

450 

SIC Range 

Total Pounds (millions) 

Total Releases Total Transf ers 

10 

261-263 

22 24 

25 

286 287 

2833, 2834 

2821, 2823, 2824 

281 

271-278 

34 

333, 334 332, 336 

331 

30 32 

2911 

4911, 493 

3731 

372, 376 

371 

36 

Key to Standard Industrial Classification (SIC) Codes 

SIC Range Industry Sector SIC Range Industry Sector SIC Range Industry Sector 

02 Agricultural Crops, Forestry 281 Inorganic Chemicals 333, 334 Nonferrous Metals 

01, 08 Agricultural Livestock 2821, 2823, 

2824 

Plastic Resins and Man-made 

Fibers 34 Fabricated Metals 

10 Metal Mining 2833, 2834 Pharmaceuticals 36 Electronics and Computers 

13 Oil and Gas Extraction 286 Organic Chemicals 371 Motor Vehicle Assembly 

14 Non-Fuel, Non-Metal Mining 287 Agricultural Chemicals 372, 376 Aerospace 

22 Textiles 2911 Petroleum Refining 3731 Shipbuilding and Repair 

24 Lumber and Wood Products 30 Rubber and Plastic 40, 42, 46, 4922-

4925, 4932 Ground Transportation 

25 Furniture and Fixtures 32 Stone, Clay, Glass and Concrete 44 Water Transportation 

261-263 Pulp and Paper 331 Iron and Steel 45 Air Transportation 

271-278 Printing 332, 336 Metal Casting 4911, 493 Fossil Fuel Electric Power Generation 

7216 Dry cleaning 

Sector Notebook Project 60 November 2002 
Pulp and Paper Industry Chemical Releases and Transfers Average Releases + Transfers per Facility (pounds) (million lbs.) (pounds) (million lbs.) (pounds) (million lbs.) 

Industry sector currently not subject to T

RI reporting. 

Industry sector currently not subject to T

RI reporting. 

695,731 

Industry sector currently not subject to T

RI reporting. 

Industry sector currently not subject to T

RI reporting. 

32,545 

33,802 

38,517 

112,151 

72,119 

110,006 

117,673 

274,041 

128,210 

109,344 

37,921 

48,457 

51,249 

228,317 

49,930 

312,598 

46,750 

94,247 

62,514 

54,951 

32,200 

Industry sector currently not subject to T

RI reporting. 

Industry sector currently not subject to T

RI reporting. 

Industry sector currently not subject to T

RI reporting. 

87,684 

Industry sector currently not subject to T

RI reporting. 

2,830,957 

456,285 

Total Releases 

+Transfers 

404.9 

17.0 

43.7 

26.6 

263.1 

70.5 

220.0 

334.5 

214.0 

593.6 

108.3 

114.7 

171.2 

98.8 

453.2 

92.3 

314.2 

330.3 

142.7 

179.7 

35.4 

6.4 

466.7 

4,701.9 

10,715.4 

Table 18: Toxics Release Inventory Data for Selected Industries 

TRI Transfers 

Ave. Transfers 

per Facility 

4,894 

15,527 

5,497 

19,605 

21,971 

21,971 

45,921 

72,139 

254,766 

80,833 

30,417 

11,973 

20,099 

29,389 

164,981 

40,849 

128,258 

38,991 

88,279 

43,019 

46,674 

12,316 

14,647 

1,213,016 

176,277 

Total 

Transfers 

2.8 

8.1 

7.1 

13.5 

51.5 

51.5 

91.8 

205.1 

199.0 

374.3 

30.1 

36.2 

71.0 

56.7 

327.5 

75.5 

128.9 

275.5 

133.7 

123.7 

30.1 

2.5 

78.0 

2,374.1 

4,139.7 

TRI Releases 

Ave. Releases 

per Facility 

690,837 

17,018 

28,305 

18,912 

90,180 

50,148 

64,085 

45,534 

19,275 

47,377 

78,927 

25,948 

28,358 

21,860 

63,336 

9,081 

184,340 

7,759 

5,968 

19,495 

8,277 

19,884 

73,037 

1,617,941 

280,007 

Total 

Releases 

402.1 

8.9 

36.6 

13.0 

211.6 

19.0 

128.2 

129.5 

15.1 

219.4 

78.1 

78.5 

100.2 

42.1 

125.7 

16.8 

185.3 

54.8 

9.0 

56.0 

5.3 

4.0 

388.7 

2,327.8 

6,575.7 

# TRI 

Facilities 

58 

194 

410 

280 

268 

163 

343 

369 

151 

467 

172 

162 

1,154 

484 

325 

447 

181 

2,047 

419 

622 

184 

39 

613 

9,552 

23,484 

SIC 

Range 

2 

01, 08 

10 

13 

14 

22 

24 

25 

261,262,263 

271-278 

281 

2821, 2823, 2824 

2833, 2834 

286 

287 

2911 

30 

32 

331 

332, 336 

333, 334 

34 

36 

371 

372, 376 

3731 

40, 42, 46, 4922- 4925, 4932 

44 

45 

4911, 493 

7216 

NA NA 

Industry Sector 

Agricultural Crops, Forestry Agricultural Livestock Metal Mining Oil and Gas Extraction Non-Fuel, NonMetal Mining Textiles Lumber and Wood Products Furniture and Fixtures Pulp and Paper Printing Inorganic Chemicals Plastic Resins and Manmade Fibers Pharmaceuticals Organic Chemicals Agricultural Chemicals Petroleum Refining Rubber and Plastic Stone, Clay, Glass and Concrete Iron and Steel Metal Casting Nonferrous Metals Fabricated Metals Electronics and Computers Motor Vehicle Assembly Aerospace Shipbuilding and Repair Ground Transportation Water Transportation Air Transportation Fossil Fuel Electric Power Generation Dry cleaning 

Sector Notebook Total 

2000 TRI Total 

Source: US EPA Toxics Release Inventory Database, 2000. 

Sector Notebook Project 61 November 2002 
Pulp and Paper Industry Pollution Prevention 

V. POLLUTION PREVENTION OPPORTUNITIES 

The best way to reduce pollution is to prevent it in the first place. Industries 

have creatively implemented pollution prevention techniques that improve 

efficiency and increase profits while at the same time minimizing 

environmental impacts. This can be done in many ways such as reducing 

material inputs, re-engineering processes to reuse by-products, improving 

management practices, and employing substitution of toxic chemicals. Some 

smaller facilities are able to actually get below regulatory thresholds just by 

reducing pollutant releases through aggressive pollution prevention policies. 

In order to encourage these approaches, this section provides both general 

and company-specific descriptions of some pollution prevention advances 

that have been implemented within the pulp and paper industry. While the 

list is not exhaustive, it does provide core information that can be used as the 

starting point for facilities interested in beginning their own pollution 

prevention projects. When possible, this section provides information from 

real activities that can, or are being implemented by this sector -- including 

a discussion of associated costs, time frames, and expected rates of return. 

This section provides summary information from activities that may be, or 

are being implemented by this sector. When possible, information is 

provided that gives the context in which the technique can be effectively 

used. Please note that the activities described in this section do not 

necessarily apply to all facilities that fall within this sector. Facility-specific 

conditions must be carefully considered when pollution prevention options 

are evaluated, and the full impacts of the change must examine how each 

option affects air, land and water pollutant releases. 

Pollution Prevention Opportunities for the Pulp and Paper Industry 

The chemical recovery systems used in chemical pulping processes are an 

example of pollution prevention technologies that have evolved alongside 

process technologies. An efficient chemical recovery system is a crucial 

component of chemical pulping mill operation: the chemical recovery 

process regenerates process chemicals, reducing natural resource usage and 

associated costs, as well as discharges to the environment and producing 

energy. Many recent pollution prevention efforts in the pulp and paper 

industry have focused on reducing the releases of toxics, in particular, 

chlorinated compounds. Pollution prevention techniques have proven to be 

more effective in controlling these pollutants than conventional control and 

treatment technologies. Most conventional, end-of-pipe treatment 

technologies are not effective in destroying many chlorinated compounds and 

often merely transfer the pollutants to another environmental medium. 

Efforts to prevent chlorinated releases have, therefore, focused on source 

reduction and material substitution techniques such as defoamers, bleaching 

chemical or wood chip substitution to reduce the industry's use and releases 

Sector Notebook Project 62 November 2002 
Pulp and Paper Industry Pollution Prevention 

of chlorinated compounds. Such source reduction efforts and material 

substitutions usually require substantial changes in the production process. 

In addition to the major process changes aimed at reducing toxics releases, 

the industry is implementing a number of pollution prevention techniques to 

reduce water use and pollutant releases (BOD, COD, and TSS) such as: dry 

debarking, recycling of log flume water, improved spill control, bleach 

filtrate recycle, closed screen rooms, and improved storm water management. 

The pulp and paper industry has also worked to increase the amount of 

secondary and recycled fibers used for the pulping process. According to 

industry sources, the pulp and paper industry set and met a 1995 goal of 40 

percent recycling and reuse of all paper consumed in the U.S. Currently, the 

industry has set a new goal of recovering 50 percent of all paper consumed 

in the U.S. for recycle and reuse. These figures should be compared with the 

utilization rate of secondary fibers (secondary fibers as a percentage of the 

total fibers used to make pulp) which is at approximately 37 percent and is 

climbing slowly (AF&PA, 1999). Current secondary fiber utilization rates 

in resource deficient countries such as Japan are close to 50 percent. 

Because the pulp and paper industry is highly capital intensive and uses longestablished technologies with long equipment lifetimes, major processchanging pollution prevention opportunities are expensive and require long 

time periods to implement. The pulp and paper industry is a dynamic one, 

however, that constantly makes process changes and material substitutions 

to increase productivity and cut costs. The trend towards materials 

substitutions is reflected in an increasing demand for alternative pulping and 

bleaching chemicals and in the participation of many facilities in voluntary 

environmental programs (see Section VIII). 

One of the factors that is driving the industry towards pollution prevention 

much more rapidly is the integrated NESHAP and effluent limitation 

guidelines for the pulp and paper industry. (See Section VI.B. for a 

description of this “cluster rule.”) These regulations were developed together 

in part to reduce the costs of compliance, to emphasize the multi-media 

nature of pollution control, and to promote pollution prevention. Many of the 

technology-based effluent limitation guidelines for the control of toxic 

releases consist of process changes that substitute chlorine dioxide for 

elemental chlorine and that completely eliminate elemental chlorine in 

bleaching processes. The NESHAP standards also allow Hazardous Air 

Pollutant (HAP) reductions through recycling of wastewater streams to a 

process unit and routing pulping emissions to a boiler, lime kiln, or recovery 

furnace. 

Brief descriptions of some of the 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 

Sector Notebook Project 63 November 2002 
Pulp and Paper Industry Pollution Prevention 

Pollution Prevention and Toxics' 1993 report, Pollution Prevention 

Technologies for the Bleached Kraft Segment of the U.S. Pulp and Paper 

Industry and other pollution prevention/waste minimization documents listed 

in Resource Materials section. It should be noted that although many of the 

pollution prevention opportunities listed below are primarily aimed at 

reducing toxics releases, the process changes can often lead to reductions in 

the conventional pollutants such as BOD5 and TSS as well as COD, AOX, 

and contribute to reduced water use, sludge volumes generated, and air 

emissions. 

Extended Delignification. Extended delignification further reduces the 

lignin content of the pulp before it moves to the bleach plant. Because the 

amount of bleaching chemicals required to achieve a certain paper brightness 

is proportional to the amount of lignin remaining in the pulp after the pulping 

process, extended delignification can reduce the amounts of bleaching 

chemicals needed. A number of different extended delignification processes 

have been developed. These processes involve: increasing the cooking time; 

adding the cooking chemicals at several points throughout the cooking 

process; regulating the cooking temperatures; and carefully controlling the 

concentration of hydrogen sulfide ions and dissolved lignin. Importantly, the 

process changes do not degrade the cellulose which would normally 

accompany increased cooking time. Extended delignification processes have 

been developed for both batch and continuous pulping processes. The lignin 

content of the brownstock pulp has been reduced by between 20 and 50 

percent with no losses in pulp yield or strength using such processes. In 

consequence, chlorinated compounds generated during bleaching are reduced 

in approximate proportion to reductions in the brownstock lignin content. In 

addition, the same changes have resulted in significant reductions in BOD5, 

COD and color. One study demonstrated a 29 percent decrease in BOD5 

resulting from an extended delignification process. Facility energy 

requirements have been shown to increase slightly with extended 

delignification. However, off-site power requirements (associated with 

decreased chemical use) have been estimated to more than offset the on-site 

increases. 

Oxygen Delignification. Oxygen delignification also reduces the lignin 

content in the pulp. The process involves the addition of an oxygen reactor 

between the kraft pulping stages and the bleach plant. The brownstock pulp 

from the digester is first washed and then mixed with sodium hydroxide or 

oxidized cooking liquor. The pulp is fluffed, deposited in the oxygen reactor, 

steam heated, and injected with gaseous oxygen wherein it undergoes 

oxidative delignification. The pulp is then washed again to remove the 

dissolved lignin before moving to the bleaching plant. Oxygen 

delignification can reduce the lignin content in the pulp by as much as 50 

percent resulting in a potentially similar reduction in the use of chlorinated 

bleaching chemicals and chlorinated compound pollutants. The process can 

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Pulp and Paper Industry Pollution Prevention 

be used in combination with other process modifications that can completely 

eliminate the need for chlorine-based bleaching agents. In addition, unlike 

bleach plant filtrate, the effluent from the oxygen reactor can be recycled 

through the pulp mill recovery cycle, further reducing the non-pulp solids 

going to the bleaching plant and the effluent load from the bleach plant. The 

net effect is reduced effluent flows and less sludge generation. Facility 

energy requirements have been shown to increase with oxygen 

delignification, however, the decrease in off-site power requirements 

(associated with decreased chemical use) have been estimated to exceed the 

on-site increases resulting in a decrease in overall energy requirements. 

Also, the recovered energy and reduced chemical use offset the cost. 

Ozone Delignification. As a result of a considerable research effort, ozone 

delignification (ozone bleaching) is now being used in a limited number of 

pulp mills. The technology has the potential to eliminate the need for 

chlorine in the bleaching process. Ozone delignification is performed using 

processes and equipment similar to that of oxygen delignification. The ozone 

process, however, must take place at a very low pH (1.0 to 2.0), requiring the 

addition of sulfuric acid to the pulp prior to the ozonation. In addition to low 

pH, a number of process conditions are critical for ozone delignification: 

organic materials must be almost completely washed out of the brownstock 

pulp; temperatures must stay at about 20 /C; and ozone reactive metals must 

be removed prior to the ozonation stage. Oxygen delignification and/or 

extended delignification processes are considered a prerequisite for 

successful ozone bleaching. When used in combination, the two processes 

can result in a high quality bright pulp that requires little or no chlorine or 

chlorine dioxide bleaching. Overall emissions from the combination of the 

oxygen and ozone processes are substantially lower than conventional 

processes because effluents from each stage can be recycled. Pilot systems 

consisting of ozone delignification in combination with oxygen 

delignification and oxygen extraction have shown reductions in BOD5 of 62 

percent, COD of 53 percent, color of 88 percent, and organic chlorine 

compounds of 98 percent. However, ozone is unstable and will decompose 

to molecular oxygen, thus ozone must be generated on-site and fed 

immediately to the pulp reactor. Ozone generation systems are complex and 

account for a high percentage of the total costs. Facility energy use will 

increase due to the on-site production of ozone, however, this energy will be 

offset by the energy that would normally be used to produce chlorine and 

chlorine dioxide. 

Anthraquinone Catalysis. The addition of anthraquinone (a chemical 

catalyst produced from coal tar) to the pulping liquor has been shown to 

speed up the kraft pulping reaction and increase yield by protecting cellulose 

fibers from degradation. The anthraquinone accelerates the fragmentation of 

lignin, allowing it to be broken down more quickly by the pulping chemicals. 

This lowers the amount of lignin in the prechlorination pulp, thus reducing 

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the amount of bleaching chemicals needed. Anthraquinone catalysts are 

increasingly used in combination with oxygen delignification and extended 

delignification to overcome boiler capacity bottlenecks arising from these 

delignification processes. 

Black Liquor Spill Control and Prevention. The mixture of dissolved 

lignin and cooking liquor effluent from the pulping reactor and washed pulp 

is known as black liquor. Raw black liquor contains high levels of BOD, 

COD, and organic compounds. Spills of black liquor can result from 

overflows, leaks from process equipment, or from deliberate dumping by 

operators to avoid a more serious accident. Spills of black liquor can have 

impacts on receiving waters, are a source of air emissions, and can shock the 

microbial action of wastewater treatment systems. Black liquor losses also 

result in the loss of the chemical and heat value of the material. Systems 

needed to control black liquor spills are a combination of good design, 

engineering, and, most importantly, operator training. A few elements of an 

effective spill control system include: physical isolation of pieces of 

equipment; floor drainage systems that allow spills to be collected; backup 

black liquor storage capacity; sensors that provide immediate warning of 

potential or actual spills; and enclosed washing and screening equipment. 

Enzyme Treatment of Pulp. Biotechnology research has resulted in the 

identification of a number of microorganisms that produce enzymes capable 

of breaking down lignin in pulp. Although the technology is new, it is 

believed that a number of mills are currently conducting enzyme treatment 

trials. The microorganisms capable of producing the necessary enzymes are 

called xylanases. Xylanases for pulp bleaching trials are available from 

several biotechnology and chemical companies. Since enzymes are used as 

a substitute for chemicals in bleaching pulp, their use will result in a decrease 

in chlorinated compounds released somewhat proportional to the reduction 

in bleaching chemicals used. Enzymes are also being used to assist in the 

deinking of secondary fiber. Research at the Oak Ridge National 

Laboratories has identified cellulase enzymes that will bind ink to the smaller 

fiber particles facilitating recovery of the ink sludge. Use of enzymes may 

also reduce the energy costs and chemical use in retrieving ink sludge from 

deinking effluent. 

Improved Brownstock and Bleaching Stage Washing. Liquor solids 

remaining in the brownstock pulp are carried over to the bleach plant and 

then compete with the remaining lignin in the pulp for reaction with the 

bleaching chemicals. Improved washing, therefore, can reduce the required 

amount of bleaching chemicals and the subsequent reductions in chlorinated 

compounds as well as conventional pollutants. Modern washing systems 

with improved solids removal and energy efficiency are beginning to replace 

the conventional rotary vacuum washers. State-of-the-art washing systems 

include: atmospheric or pressure diffusion washers, belt washers, and pulp 

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presses. Opportunities for reduced effluent flows and water use are also 

present in the bleaching plant. Acid filtrates from hypochlorite or chlorine 

dioxide stages can be used as dilution and wash water for the first bleaching 

stage. Similarly, second extraction stage filtrates can be used as dilution and 

wash water in the first extraction stage. Most new mills are designed with 

these counter-current washing systems and some mills are retrofitting their 

existing wash systems. 

Improved Chipping and Screening. The size and thickness of wood chips 

is critical for proper circulation and penetration of the pulping chemicals. 

Chip uniformity is controlled by the chipper and screens that remove under 

and oversized pieces. Standard equipment normally does not sort chips by 

thickness although it has been demonstrated that chip thickness is extremely 

important in determining the lignin content of pulp. Improper chip 

thicknesses can therefore result in increased use of bleaching chemicals and 

the associated chlorinated compounds and conventional pollutants. Some 

mills are beginning to incorporate equipment that will separate chips 

according to their thickness as well as by length and width. 

Oxygen-Reinforced/Peroxide Extraction. Oxygen-reinforced extraction 

(or oxidative extraction) and peroxide-reinforced extraction processes used 

separately or together have been shown to reduce the amount of elemental 

chlorine and chlorine dioxide needed in the bleaching process while 

increasing the pulp brightness. Gaseous elemental oxygen (in the case of 

oxygen-reinforced extraction) and aqueous hydrogen peroxide (in the case 

of peroxide extraction) are used as a part of the first alkaline extraction stage 

to facilitate the solubilization and removal of chlorinated and oxidized lignin 

molecules. Oxygen-reinforced extraction has seen widespread adoption by 

the industry in recent years. It is estimated that up to 80 percent of mills in 

the U.S. are using oxygen-reinforced extraction. The use of peroxide 

extraction is also increasing. As of 1987, it was estimated that 25 percent of 

domestic mills were using peroxide extraction. 

Improved Chemical Controls and Mixing. The formation of chlorinated 

organics can be minimized by avoiding excess concentrations of chlorinebased 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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Pulp and Paper Industry Federal Statutes and Regulations 

VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS 

This section discusses the federal regulations that may apply to this sector. 

The purpose of this section is to highlight and briefly describe the applicable 

federal requirements, and to provide citations for more detailed information. 

The three following sections are included: 

C Section VI.A contains a general overview of major statutes

C Section VI.B contains a list of regulations specific to this industry

C Section VI.C contains a list of pending and proposed regulatory

requirements. 

The descriptions within Section VI are intended solely for general 

information. Depending upon the nature or scope of the activities at a 

particular facility, these summaries may or may not necessarily describe all 

applicable environmental requirements. Moreover, they do not constitute 

formal interpretations or clarifications of the statutes and regulations. For 

further information, readers should consult the Code of Federal Regulations 

and other state or local regulatory agencies. EPA Hotline contacts are also 

provided for each major statute. 

VI.A. General Description of Major Statutes 

Clean Water Act 

The primary objective of the Federal Water Pollution Control Act, commonly 

referred to as the Clean Water Act (CWA), is to restore and maintain the 

chemical, physical, and biological integrity of the nation's surface waters. 

Pollutants regulated under the CWA are classified as either “toxic” 

pollutants; "conventional" pollutants, such as biochemical oxygen demand 

(BOD), total suspended solids (TSS), fecal coliform, oil and grease, and pH; 

or "non-conventional" pollutants, including any pollutant not identified as 

either conventional or priority. 

The CWA regulates both direct and “indirect” dischargers (those who 

discharge to publicly owned treatment works). The National Pollutant 

Discharge Elimination System (NPDES) permitting program (CWA section 

402) controls direct discharges into navigable waters. Direct discharges or 

"point source" discharges are from sources such as pipes and sewers. 

NPDES permits, issued by either EPA or an authorized state (EPA has 

authorized 43 states and one territory to administer the NPDES program), 

contain industry-specific, technology-based and water quality-based limits 

and establish pollutant monitoring and reporting requirements. A facility that 

proposes to discharge into the nation's waters must obtain a permit prior to 

initiating a discharge. A permit applicant must provide quantitative 

analytical data identifying the types of pollutants present in the facility's 

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effluent. The permit will then set forth the conditions and effluent limitations

under which a facility may make a discharge.

Water quality-based discharge limits are based on federal or state water

quality criteria or standards, that were designed to protect designated uses of

surface waters, such as supporting aquatic life or recreation. These

standards, unlike the technology-based standards, generally do not take into

account technological feasibility or costs. Water quality criteria and

standards vary from state to state, and site to site, depending on the use

classification of the receiving body of water. Most states follow EPA

guidelines which propose aquatic life and human health criteria for many of

the 126 priority pollutants.

Storm Water Discharges

In 1987 the CWA was amended to require EPA to establish a program to

address storm water discharges. In response, EPA promulgated NPDES

permitting regulations for storm water discharges. These regulations require

that facilities with the following types of storm water discharges, among

others, apply for an NPDES permit: (1) a discharge associated with industrial

activity; (2) a discharge from a large or medium municipal storm sewer

system; or (3) a discharge which EPA or the state determines to contribute

to a violation of a water quality standard or is a significant contributor of

pollutants to waters of the United States.

The term “storm water discharge associated with industrial activity” means 

a storm water discharge from one of 11 categories of industrial activity 

defined at 40 CFR Part 122.26. Six of the categories are defined by SIC 

codes while the other five are identified through narrative descriptions of the 

regulated industrial activity. If the primary SIC code of the facility is one of 

those identified in the regulations, the facility is subject to the storm water 

permit application requirements. If any activity at a facility is covered by 

one of the five narrative categories, storm water discharges from those areas 

where the activities occur are subject to storm water discharge permit 

application requirements. 

Those facilities/activities that are subject to storm water discharge permit 

application requirements are identified below. To determine whether a 

particular facility falls within one of these categories, the regulation should 

be consulted. 

Category i: Facilities subject to storm water effluent guidelines, new source 

performance standards, or toxic pollutant effluent standards. 

Category ii: Facilities classified as SIC 24-lumber and wood products 

(except wood kitchen cabinets); SIC 26-paper and allied products (except 

paperboard containers and products); SIC 28-chemicals and allied products 

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(except drugs and paints); SIC 29-petroleum refining; SIC 311-leather 

tanning and finishing; SIC 32 (except 323)-stone, clay, glass, and concrete; 

SIC 33-primary metals; SIC 3441-fabricated structural metal; and SIC 373-

ship and boat building and repairing. 

Category 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 

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. 

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Phase II storm water requirements were established in 1999. Permits are now

required for certain small municipal separate storm sewer systems (MS4s)

and for construction activity disturbing between one and five acres of land

(i.e., small construction activities). The Phase II rule also revised the “no

exposure” exclusion and the temporary exemption for certain industrial

facilities that had been established under Phase I regulations.

Pretreatment Program

Another type of discharge that is regulated by the CWA is one that goes to

a publicly owned treatment works (POTW). The national pretreatment

program (CWA section 307(b)) controls the indirect discharge of pollutants

to POTWs by "industrial users." Facilities regulated under section 307(b)

must meet certain pretreatment standards. The goal of the pretreatment

program is to protect municipal wastewater treatment plants from damage

that may occur when hazardous, toxic, or other wastes are discharged into a

sewer system and to protect the quality of sludge generated by these plants.

EPA has developed technology-based standards for industrial users of 

POTWs. Different standards apply to existing and new sources within each 

category. "Categorical" pretreatment standards applicable to an industry on 

a nationwide basis are developed by EPA. In addition, another kind of 

pretreatment standard, "local limits," are developed by the POTW in order 

to assist the POTW in achieving the effluent limitations in its NPDES permit. 

Regardless of whether a state is authorized to implement either the NPDES 

or the pretreatment program, if it develops its own program, it may enforce 

requirements more stringent than federal standards. 

Wetlands 

Wetlands, commonly called swamps, marshes, fens, bogs, vernal pools, 

playas, and prairie potholes, are a subset of “waters of the United States,” as 

defined in Section 404 of the CWA. The placement of dredge and fill 

material into wetlands and other water bodies (i.e., waters of the United 

States) is regulated by the U.S. Army Corps of Engineers (Corps) under 33 

CFR Part 328. The Corps regulates wetlands by administering the CWA 

Section 404 permit program for activities that impact wetlands. EPA’s 

authority under Section 404 includes veto power of Corps permits, authority 

to interpret statutory exemptions and jurisdiction, enforcement actions, and 

delegating the Section 404 program to the states. 

EPA’s Office of Water, at 202-566-1730, will direct callers with questions 

about the CWA to the appropriate EPA office. EPA also maintains a 

bibliographic database of Office of Water publications which can be 

accessed through the Ground Water and Drinking Water Resource Center, 

at 1-800-426-4791. 

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Pulp and Paper Industry Federal Statutes and Regulations 

Oil Pollution Prevention Regulation 

Section 311(b) of the CWA prohibits the discharge of oil, in such quantities 

as may be harmful, into the navigable waters of the United States and 

adjoining shorelines. The EPA Discharge of Oil regulation, 40 CFR Part 

110, provides information regarding these discharges. The Oil Pollution 

Prevention regulation, 40 CFR Part 112, under the authority of Section 311(j) 

of the CWA, requires regulated facilities to prepare and implement Spill 

Prevention Control and Countermeasure (SPCC) plans. The intent of a 

SPCC plan is to prevent the discharge of oil from onshore and offshore nontransportation-related facilities. In 1990 Congress passed the Oil Pollution 

Act which amended Section 311(j) of the CWA to require facilities that 

because of their location could reasonably be expected to cause “substantial 

harm” to the environment by a discharge of oil to develop and implement 

Facility Response Plans (FRP). The intent of a FRP is to provide for planned 

responses to discharges of oil. 

A facility is SPCC-regulated if the facility, due to its location, could 

reasonably be expected to discharge oil into or upon the navigable waters of 

the United States or adjoining shorelines, and the facility meets one of the 

following criteria regarding oil storage: (1) the capacity of any aboveground 

storage tank exceeds 660 gallons, or (2) the total aboveground storage 

capacity exceeds 1,320 gallons, or (3) the underground storage capacity 

exceeds 42,000 gallons. 40 CFR Part 112.7 contains the format and content 

requirements for a SPCC plan. In New Jersey, SPCC plans can be combined 

with DPCC plans, required by the state, provided there is an appropriate 

cross-reference index to the requirements of both regulations at the front of 

the plan. 

According to the FRP regulation, a facility can cause “substantial harm” if 

it meets one of the following criteria: (1) the facility has a total oil storage 

capacity greater than or equal to 42,000 gallons and transfers oil over water 

to or from vessels; or (2) the facility has a total oil storage capacity greater 

than or equal to one million gallons and meets any one of the following 

conditions: (i) does not have adequate secondary containment, (ii) a 

discharge could cause “injury” to fish and wildlife and sensitive 

environments, (iii) shut down a public drinking water intake, or (iv) has had 

a reportable oil spill greater than or equal to 10,000 gallons in the past five 

years. Appendix F of 40 CFR Part 112 contains the format and content 

requirements for a FRP. FRPs that meet EPA’s requirements can be 

combined with U.S. Coast Guard FRPs or other contingency plans, provided 

there is an appropriate cross-reference index to the requirements of all 

applicable regulations at the front of the plan. 

For additional information regarding SPCC plans, contact EPA’s RCRA, 

Superfund, and EPCRA Call Center, at 800-424-9346. Additional documents 

and resources can be obtained from the hotline’s homepage at 

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www.epa.gov/epaoswer/hotline. The hotline operates weekdays from 9:00 

a.m. to 6:00 p.m., EST, excluding federal holidays. 

Safe Drinking Water Act 

The Safe Drinking Water Act (SDWA) mandates that EPA establish 

regulations to protect human health from contaminants in drinking water. 

The law authorizes EPA to develop national drinking water standards and to 

create a joint federal-state system to ensure compliance with these standards. 

The SDWA also directs EPA to protect underground sources of drinking 

water through the control of underground injection of fluid wastes. 

EPA has developed primary and secondary drinking water standards under 

its SDWA authority. EPA and authorized states enforce the primary drinking 

water standards, which are contaminant-specific concentration limits that 

apply to certain public drinking water supplies. Primary drinking water 

standards consist of maximum contaminant level goals (MCLGs), which are 

non-enforceable health-based goals, and maximum contaminant levels 

(MCLs), which are enforceable limits set generally as close to MCLGs as 

possible, considering cost and feasibility of attainment. 

Part C of the SDWA mandates EPA to protect underground sources of 

drinking water from inadequate injection practices. EPA has published 

regulations codified in 40 CFR Parts 144 to 148 to comply with this mandate. 

The Underground Injection Control (UIC) regulations break down injection 

wells into five different types, depending on the fluid injected and the 

formation that receives it. The regulations also include construction, 

monitoring, testing, and operating requirements for injection well operators. 

All injection wells have to be authorized by permit or by rule depending on 

their potential to threaten Underground Sources of Drinking Water (USDW). 

RCRA also regulates hazardous waste injection wells and a UIC permit is 

considered to meet the requirements of a RCRA permit. EPA has authorized 

delegation of the UIC for all wells in 35 states, implements the program in 

10 states and all Indian lands, and shares responsibility with five states. 

The SDWA also provides for a federally-implemented Sole Source Aquifer 

program, which prohibits federal funds from being expended on 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. 

The SDWA Amendments of 1996 require states to develop and implement 

source water assessment programs (SWAPs) to analyze existing and potential 

threats to the quality of the public drinking water throughout the state. Every 

state is required to submit a program to EPA and to complete all assessments 

within 3 1⁄2 years of EPA approval of the program. SWAPs include: (1) 

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delineating the source water protection area, (2) conducting a contaminant 

source inventory, (3) determining the susceptibility of the public water 

supply to contamination from the inventories sources, and (4) releasing the 

results of the assessments to the public. 

EPA’s Safe Drinking Water Hotline, at 800-426-4791, answers questions and 

distributes guidance pertaining to SDWA standards. The Hotline operates 

from 9:00 a.m. through 5:30 p.m., EST, excluding federal holidays. Visit the 

website at www.epa.gov/ogwdw for additional material. 

Resource Conservation and Recovery Act 

The Solid Waste Disposal Act (SWDA), as amended by the Resource 

Conservation and Recovery Act (RCRA) of 1976, addresses solid and 

hazardous waste management activities. The Act is commonly referred to as 

RCRA. The Hazardous and Solid Waste Amendments (HSWA) of 1984 

strengthened RCRA’s waste management provisions and added Subtitle I, 

which governs underground storage tanks (USTs). 

Regulations promulgated pursuant to Subtitle C of RCRA (40 CFR Parts 

260-299) establish a “cradle-to-grave” system governing hazardous waste 

from the point of generation to disposal. RCRA hazardous wastes include 

the specific materials listed in the regulations (discarded commercial 

chemical products, designated with the code "P" or "U"; hazardous wastes 

from specific industries/sources, designated with the code "K"; or hazardous 

wastes from non-specific sources, designated with the code "F") or materials 

which exhibit a hazardous waste characteristic (ignitability, corrosivity, 

reactivity, or toxicity and designated with the code "D"). 

Entities that generate hazardous waste are subject to waste accumulation, 

manifesting, and recordkeeping standards. A hazardous waste facility may 

accumulate hazardous waste for up to 90 days (or 180 days depending on the 

amount generated per month) without a permit or interim status. Generators 

may also treat hazardous waste in accumulation tanks or containers (in 

accordance with the requirements of 40 CFR Part 262.34) without a permit 

or interim status. Facilities that treat, store, or dispose of hazardous waste are 

generally required to obtain a RCRA permit. 

Subtitle C permits are required for treatment, storage, or disposal facilities. 

These permits contain general facility standards such as contingency plans, 

emergency procedures, recordkeeping and reporting requirements, financial 

assurance mechanisms, and unit-specific standards. RCRA also contains 

provisions (40 CFR Subparts I and S) for conducting corrective actions 

which govern the cleanup of releases of hazardous waste or constituents from 

solid waste management units at RCRA treatment, storage, or disposal 

facilities. 

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Pulp and Paper Industry Federal Statutes and Regulations 

Although RCRA is a federal statute, many states implement the RCRA 

program. Currently, EPA has delegated its authority to implement various 

provisions of RCRA to 47 of the 50 states and two U.S. territories. 

Delegation has not been given to Alaska, Hawaii, or Iowa. 

Most RCRA requirements are not industry specific but apply to any company 

that generates, transports, treats, stores, or disposes of hazardous waste. Here 

are some important RCRA regulatory requirements: 

C Criteria for Classification of Solid Waste Disposal Facilities and 

Practices (40 CFR Part 257) establishes the criteria for determining 

which solid waste disposal facilities and practices pose a reasonable 

probability of adverse effects on health or the environment. The 

criteria were adopted to ensure non-municipal, non-hazardous waste 

disposal units that receive conditionally exempt small quantity 

generator waste do not present risks to human health and 

environment. 

C Criteria for Municipal Solid Waste Landfills (40 CFR Part 258) 

establishes minimum national criteria for all municipal solid waste 

landfill units, including those that are used to dispose of sewage 

sludge. 

• Identification of Solid and Hazardous Wastes (40 CFR Part 261) 

establishes the standard to determine whether the material in question 

is considered a solid waste and, if so, whether it is a hazardous waste 

or is exempted from regulation. 

• Standards for Generators of Hazardous Waste (40 CFR Part 262) 

establishes the responsibilities of hazardous waste generators 

including obtaining an EPA identification number, preparing a 

manifest, ensuring proper packaging and labeling, meeting standards 

for waste accumulation units, and recordkeeping and reporting 

requirements. Generators can accumulate hazardous waste on-site for 

up to 90 days (or 180 days depending on the amount of waste 

generated) without obtaining a permit. 

• Land Disposal Restrictions (LDRs) (40 CFR Part 268) are 

regulations prohibiting the disposal of hazardous waste on land 

without prior treatment. Under the LDRs program, materials must 

meet treatment standards prior to placement in a RCRA land disposal 

unit (landfill, land treatment unit, waste pile, or surface 

impoundment). Generators of waste subject to the LDRs must 

provide notification of such to the designated TSD facility to ensure 

proper treatment prior to disposal. 

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Pulp and Paper Industry Federal Statutes and Regulations 

• Used Oil Management Standards (40 CFR Part 279) impose 

management requirements affecting the storage, transportation, 

burning, processing, and re-refining of the used oil. For parties that 

merely generate used oil, regulations establish storage standards. For 

a party considered a used oil processor, re-refiner, burner, or 

marketer (one who generates and sells off-specification used oil 

directly to a used oil burner), additional tracking and paperwork 

requirements must be satisfied. 

• RCRA contains unit-specific standards for all units used to store, 

treat, or dispose of hazardous waste, including Tanks and 

Containers. Tanks and containers used to store hazardous waste with 

a high volatile organic concentration must meet emission standards 

under RCRA. Regulations (40 CFR Part 264-265, Subpart CC) 

require generators to test the waste to determine the concentration of 

the waste, to satisfy tank and container emissions standards, and to 

inspect and monitor regulated units. These regulations apply to all 

facilities who store such waste, including large quantity generators 

accumulating waste prior to shipment offsite. 

• Underground Storage Tanks (USTs) containing petroleum and 

hazardous substances are regulated under Subtitle 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 

includes upgrade requirements for existing tanks that were to be met 

by December 22, 1998. 

• Boilers and Industrial Furnaces (BIFs) that use or burn fuel 

containing hazardous waste must comply with design and operating 

standards. BIF regulations (40 CFR Part 266, Subpart H) address unit 

design, provide performance standards, require emissions monitoring, 

and, in some cases, restrict the type of waste that may be burned. 

EPA's RCRA, Superfund, and EPCRA Call Center, at 800-424-9346, 

responds to questions and distributes guidance regarding all RCRA 

regulations. Additional documents and resources can be obtained from the 

hotline’s homepage at www.epa.gov/epaoswer/hotline. The RCRA Hotline 

operates weekdays from 9:00 a.m. to 6:00 p.m., EST, excluding federal 

holidays. 

Comprehensive Environmental Response, Compensation, and Liability Act 

The Comprehensive Environmental Response, Compensation, and Liability 

Act (CERCLA), a 1980 law commonly known as Superfund, authorizes EPA 

to respond to releases, or threatened releases, of hazardous substances that 

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may endanger public health, welfare, or the environment. CERCLA also 

enables EPA to force parties responsible for environmental contamination to 

clean it up or to reimburse the Superfund for response or remediation costs 

incurred by EPA. The Superfund Amendments and Reauthorization Act 

(SARA) of 1986 revised various sections of CERCLA, extended the taxing 

authority for the Superfund, and created a free-standing law, SARA Title III, 

also known as the Emergency Planning and Community Right-to-Know Act 

(EPCRA). 

The CERCLA hazardous substance release reporting regulations (40 CFR 

Part 302) direct the person in charge of a facility to report to the National 

Response Center (NRC) any environmental release of a hazardous substance 

which equals or exceeds a reportable quantity. Reportable quantities are 

listed in 40 CFR Part 302.4. A release report may trigger a response by EPA 

or by one or more federal or state emergency response authorities. 

EPA implements hazardous substance responses according to procedures 

outlined in the National Oil and Hazardous Substances Pollution 

Contingency Plan (NCP) (40 CFR Part 300). The NCP includes provisions 

for cleanups. The National Priorities List (NPL) currently includes 

approximately 1,300 sites. Both EPA and states can act at other sites; 

however, EPA provides responsible parties the opportunity to conduct 

cleanups and encourages community involvement throughout the Superfund 

response process. 

EPA's RCRA, Superfund and EPCRA Call Center, at 800-424-9346, answers 

questions and references guidance pertaining to the Superfund program. 

Documents and resources can be obtained from the hotline’s homepage at 

www.epa.gov/epaoswer/hotline. The Superfund Hotline operates weekdays 

from 9:00 a.m. to 6:00 p.m., EST, excluding federal holidays. 

Emergency Planning And Community Right-To-Know Act 

The Superfund Amendments and Reauthorization Act (SARA) of 1986 

created the Emergency Planning and Community Right-to-Know Act 

(EPCRA, also known as SARA Title III), a statute designed to improve 

community access to information about chemical hazards and to facilitate the 

development of chemical emergency response plans by state and local 

governments. Under EPCRA, states establish State Emergency Response 

Commissions (SERCs), responsible for coordinating certain emergency 

response activities and for appointing Local Emergency Planning 

Committees (LEPCs). 

EPCRA and the EPCRA regulations (40 CFR Parts 350-372) establish four 

types of reporting obligations for facilities which store or manage specified 

chemicals: 

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• EPCRA section 302 requires facilities to notify the SERC and LEPC 

of the presence of any extremely hazardous substance at the facility 

in an amount in excess of the established threshold planning quantity. 

The list of extremely hazardous substances and their threshold 

planning quantities is found at 40 CFR Part 355, Appendices A and 

B. 

• EPCRA section 303 requires that each LEPC develop an emergency 

plan. The plan must contain (but is not limited to) the identification 

of facilities within the planning district, likely routes for transporting 

extremely hazardous substances, a description of the methods and 

procedures to be followed by facility owners and operators, and the 

designation of community and facility emergency response 

coordinators. 

• EPCRA section 304 requires the facility to notify the SERC and the 

LEPC in the event of a release exceeding the reportable quantity of 

a CERCLA hazardous substance (defined at 40 CFR Part 302) or an 

EPCRA extremely hazardous substance. 

• EPCRA sections 311 and 312 require a facility at which a hazardous 

chemical, as defined by the Occupational Safety and Health Act, is 

present in an amount exceeding a specified threshold to submit to the 

SERC, LEPC and local fire department material safety data sheets 

(MSDSs) or lists of MSDSs and hazardous chemical inventory forms 

(also known as Tier I and II forms). This information helps the local 

government respond in the event of a spill or release of the chemical. 

• EPCRA section 313 requires certain covered facilities, including 

SIC codes 20 through 39 and others, which have ten or more 

employees, and which manufacture, process, or use specified 

chemicals in amounts greater than threshold quantities, to submit an 

annual toxic chemical release report. This report, commonly known 

as the Form R, covers releases and transfers of toxic chemicals to 

various facilities and environmental media. EPA maintains the data 

reported in a publically accessible database known as the Toxics 

Release Inventory (TRI). 

All information submitted pursuant to EPCRA regulations is publicly 

accessible, unless protected by a trade secret claim. 

EPA's RCRA, Superfund and EPCRA Call Center, at 800-424-9346, answers 

questions and distributes guidance regarding the emergency planning and 

community right-to-know regulations. Documents and resources can be 

obtained from the hotline’s homepage at www.epa.gov/epaoswer/hotline. 

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The EPCRA Hotline operates weekdays from 9:00 a.m. to 6:00 p.m., EST, 

excluding federal holidays. 

Clean Air Act 

The Clean Air Act (CAA) and its amendments are designed to “protect and 

enhance the nation's air resources so as to promote the public health and 

welfare and the productive capacity of the population.” The CAA consists 

of six sections, known as Titles, which direct EPA to establish national 

standards for ambient air quality and for EPA and the states to implement, 

maintain, and enforce these standards through a variety of mechanisms. 

Under the CAA, many facilities are required to obtain operating permits that 

consolidate their air emission requirements. State and local governments 

oversee, manage, and enforce many of the requirements of the CAA. CAA 

regulations appear at 40 CFR Parts 50-99. 

Pursuant to Title I of the CAA, EPA has established national ambient air 

quality standards (NAAQSs) to limit levels of "criteria pollutants," including 

carbon monoxide, lead, nitrogen dioxide, particulate matter, ozone, and 

sulfur dioxide. Geographic areas that meet NAAQSs for a given pollutant 

are designated as attainment areas; those that do not meet NAAQSs are 

designated as non-attainment areas. Under section110 and other provisions 

of the CAA, each state must develop a State Implementation Plan (SIP) to 

identify sources of air pollution and to determine what reductions are 

required to meet federal air quality standards. Revised NAAQSs for 

particulates and ozone became effective in 2001. 

Title I also authorizes EPA to establish New Source Performance Standards 

(NSPS), which are nationally uniform emission standards for new and 

modified stationary sources falling within particular industrial categories. 

NSPSs are based on the pollution control technology available to that 

category of industrial source (see 40 CFR Part 60). 

Under Title I, EPA establishes and enforces National Emission Standards for 

Hazardous Air Pollutants (NESHAPs), nationally uniform standards oriented 

toward controlling specific hazardous air pollutants (HAPs). Section 112(c) 

of the CAA further directs EPA to develop a list of sources that emit any of 

188 HAPs, and to develop regulations for these categories of sources. To 

date EPA has listed 185 source categories and developed a schedule for the 

establishment of emission standards. The emission standards are being 

developed for both new and existing sources based on "maximum achievable 

control technology” (MACT). The MACT is defined as the control 

technology achieving the maximum degree of reduction in the emission of 

the HAPs, taking into account cost and other factors. 

Sector Notebook Project 79 November 2002 
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Title II of the CAA pertains to mobile sources, such as cars, trucks, buses, 

and planes. Reformulated gasoline, automobile pollution control devices, 

and vapor recovery nozzles on gas pumps are a few of the mechanisms EPA 

uses to regulate mobile air emission sources. 

Title IV-A establishes a sulfur dioxide and nitrogen oxides emissions 

program designed to reduce the formation of acid rain. Reduction of sulfur 

dioxide releases will be obtained by granting to certain sources limited 

emissions allowances that are set below previous levels of sulfur dioxide 

releases. 

Title V of the CAA establishes an operating permit program for all "major 

sources" (and certain other sources) regulated under the CAA. One purpose 

of the operating permit is to include in a single document all air emissions 

requirements that apply to a given facility. States have developed the permit 

programs in accordance with guidance and regulations from EPA. Once a 

state program is approved by EPA, permits are issued and monitored by that 

state. 

Title VI is intended to protect stratospheric ozone by phasing out the 

manufacture of ozone-depleting chemicals and restricting their use and 

distribution. Production of Class I substances, including 15 kinds of 

chlorofluorocarbons (CFCs), were phased out (except for essential uses) in 

1996. 

EPA's Clean Air Technology Center, at 919-541-0800 or 

www.epa.gov/ttn/catc, provides general assistance and information on CAA 

standards. The Stratospheric Ozone Information Hotline, at 800-296-1996 

or www.epa.gov/ozone, provides general information about regulations 

promulgated under Title VI of the CAA; EPA's EPCRA Call Center, at 800-

424-9346 or www.epa.gov/epaoswer/hotline, answers questions about 

accidental release prevention under CAA section112(r); and information on 

air toxics can be accessed through the Unified Air Toxics website at 

http://www.epa.gov/ttn/atw/. In addition, the Clean Air Technology Center’s 

website includes recent CAA rules, EPA guidance documents, and updates 

of EPA activities. 

Federal Insecticide, Fungicide, and Rodenticide Act 

The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was first 

passed in 1947, and amended numerous times, most recently by the Food 

Quality Protection Act (FQPA) of 1996. FIFRA provides EPA with the 

authority to oversee, among other things, the registration, distribution, sale 

and use of pesticides. The Act applies to all types of pesticides, including 

insecticides, herbicides, fungicides, rodenticides and antimicrobials. FIFRA 

covers both intrastate and interstate commerce. 

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Establishment Registration

Section 7 of FIFRA requires that establishments producing pesticides, or

active ingredients used in producing a pesticide subject to FIFRA, register

with EPA. Registered establishments must report the types and amounts of

pesticides and active ingredients they produce. The Act also provides EPA

inspection authority and enables the agency to take enforcement actions

against facilities that are not in compliance with FIFRA.

Product Registration

Under section 3 of FIFRA, all pesticides (with few exceptions) sold or

distributed in the U.S. must be registered by EPA. Pesticide registration is

very specific and generally allows use of the product only as specified on the

label. Each registration specifies the use site i.e., where the product may be

used and the amount that may be applied. The person who seeks to register

the pesticide must file an application for registration. The application

process often requires either the citation or submission of extensive

environmental, health and safety data. 

To register a pesticide, the EPA Administrator must make a number of

findings, one of which is that the pesticide, when used in accordance with

widespread and commonly recognized practice, will not generally cause

unreasonable adverse effects on the environment.

FIFRA defines “unreasonable adverse effects on the environment” as “(1)

any unreasonable risk to man or the environment, taking into account the

economic, social, and environmental costs and benefits of the use of the

pesticide, or (2) a human dietary risk from residues that result from a use of

a pesticide in or on any food inconsistent with the standard under section 408

of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 346a).”

Under FIFRA section 6(a)(2), after a pesticide is registered, the registrant

must also notify EPA of any additional facts and information concerning

unreasonable adverse environmental effects of the pesticide. Also, if EPA

determines that additional data are needed to support a registered pesticide,

registrants may be requested to provide additional data. If EPA determines

that the registrant(s) did not comply with their request for more information,

the registration can be suspended under FIFRA section 3(c)(2)(B).

Use Restrictions

As a part of the pesticide registration, EPA must classify the product for

general use, restricted use, or general for some uses and restricted for others

(Miller, 1993). For pesticides that may cause unreasonable adverse effects

on the environment, including injury to the applicator, EPA may require that

the pesticide be applied either by or under the direct supervision of a certified

applicator.

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Reregistration

Due to concerns that much of the safety data underlying pesticide

registrations becomes outdated and inadequate, in addition to providing that

registrations be reviewed every 15 years, FIFRA requires EPA to reregister

all pesticides that were registered prior to 1984 (section 4). After reviewing

existing data, EPA may approve the reregistration, request additional data to

support the registration, cancel, or suspend the pesticide.

Tolerances and Exemptions

A tolerance is the maximum amount of pesticide residue that can be on a raw

product and still be considered safe. Before EPA can register a pesticide that

is used on raw agricultural products, it must grant a tolerance or exemption

from a tolerance (40 CFR Parts 163.10 through 163.12). Under the Federal

Food, Drug, and Cosmetic Act (FFDCA), a raw agricultural product is

deemed unsafe if it contains a pesticide residue, unless the residue is within

the limits of a tolerance established by EPA or is exempt from the

requirement.

Cancellation and Suspension

EPA can cancel a registration if it is determined that the pesticide or its

labeling does not comply with the requirements of FIFRA or causes

unreasonable adverse effects on the environment (Haugrud, 1993). 

In cases where EPA believes that an “imminent hazard” would exist if a

pesticide were to continue to be used through the cancellation proceedings,

EPA may suspend the pesticide registration through an order and thereby halt

the sale, distribution, and usage of the pesticide. An “imminent hazard” is

defined as an unreasonable adverse effect on the environment or an

unreasonable hazard to the survival of a threatened or endangered species

that would be the likely result of allowing continued use of a pesticide during

a cancellation process.

When EPA believes an emergency exists that does not permit a hearing to be

held prior to suspending, EPA can issue an emergency order which makes the

suspension immediately effective. 

Imports and Exports

Under FIFRA section 17(a), pesticides not registered in the U.S. and

intended solely for export are not required to be registered provided that the

exporter obtains and submits to EPA, prior to export, a statement from the

foreign purchaser acknowledging that the purchaser is aware that the product

is not registered in the United States and cannot be sold for use there. EPA

sends these statements to the government of the importing country. FIFRA

sets forth additional requirements that must be met by pesticides intended

solely for export. The enforcement policy for exports is codified at 40 CFR

Parts 168.65, 168.75, and 168.85.

Sector Notebook Project 82 November 2002 
Pulp and Paper Industry Federal Statutes and Regulations 

Under FIFRA section 17(c), imported pesticides and devices must comply 

with U.S. pesticide law. Except where exempted by regulation or statute, 

imported pesticides must be registered. FIFRA section 17(c) requires that 

EPA be notified of the arrival of imported pesticides and devices. This is 

accomplished through the Notice of Arrival (NOA) (EPA Form 3540-1), 

which is filled out by the importer prior to importation and submitted to the 

EPA regional office applicable to the intended port of entry. U.S. Customs 

regulations prohibit the importation of pesticides without a completed NOA. 

The EPA-reviewed and signed form is returned to the importer for 

presentation to U.S. Customs when the shipment arrives in the U.S. NOA 

forms can be obtained from contacts in the EPA Regional Offices or 

www.epa.gov/oppfead1/international/noalist.htm. 

Additional information on FIFRA and the regulation of pesticides can be 

obtained from a variety of sources, including EPA’s Office of Pesticide 

Programs www.epa.gov/pesticides, EPA’s Office of Compliance, Agriculture 

and Ecosystem Division http://www.epa.gov/compliance/assistance/ 

sectors/agriculture.html, or The National Agriculture Compliance Assistance 

Center, 888-663-2155 or http://www.epa.gov/agriculture/. Other sources 

include the National Pesticide Telecommunications Network, 800-858-7378, 

and the National Antimicrobial Information Network, 800-447-6349. 

Toxic Substances Control Act 

The Toxic Substances Control Act (TSCA) granted EPA authority to create 

a regulatory framework to collect data on chemicals in order to evaluate, 

assess, mitigate, and control risks which may be posed by their manufacture, 

processing, and use. TSCA provides a variety of control methods to prevent 

chemicals from posing unreasonable risk. It is important to note that 

pesticides as defined in FIFRA are not included in the definition of a 

“chemical substance” when manufactured, processed, or distributed in 

commerce for use as a pesticide. 

TSCA standards may apply at any point during a chemical’s life cycle. 

Under TSCA section 5, EPA has established an inventory of chemical 

substances. If a chemical is not already on the inventory, and has not been 

excluded by TSCA, a premanufacture notice (PMN) must be submitted to 

EPA prior to manufacture or import. The PMN must identify the chemical 

and provide available information on health and environmental effects. If 

available data are not sufficient to evaluate the chemical’s effects, EPA can 

impose restrictions pending the development of information on its health and 

environmental effects. EPA can also restrict significant new uses of 

chemicals based upon factors such as the projected volume and use of the 

chemical. 

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Under TSCA section 6, EPA can ban the manufacture or distribution in 

commerce, limit the use, require labeling, or place other restrictions on 

chemicals that pose unreasonable risks. Among the chemicals EPA regulates 

under section 6 authority are asbestos, chlorofluorocarbons (CFCs), lead, and 

polychlorinated biphenyls (PCBs). 

Under TSCA section 8(e), EPA requires the producers and importers (and 

others) of chemicals to report information on a chemicals’ production, use, 

exposure, and risks. Companies producing and importing chemicals can be 

required to report unpublished health and safety studies on listed chemicals 

and to collect and record any allegations of adverse reactions or any 

information indicating that a substance may pose a substantial risk to humans 

or the environment. 

EPA’s TSCA Assistance Information Service, at 202-554-1404, answers 

questions and distributes guidance pertaining to Toxic Substances Control 

Act standards. The Service operates from 8:30 a.m. through 4:30 p.m., EST, 

excluding federal holidays. 

Coastal Zone Management Act 

The Coastal Zone Management Act (CZMA) encourages states/tribes to 

preserve, protect, develop, and where possible, restore or enhance valuable 

natural coastal resources such as wetlands, floodplains, estuaries, beaches, 

dunes, barrier islands, and coral reefs, as well as the fish and wildlife using 

those habitats. It includes areas bordering the Atlantic, Pacific, and Arctic 

Oceans, Gulf of Mexico, Long Island Sound, and Great Lakes. A unique 

feature of this law is that participation by states/tribes is voluntary. 

In the Coastal Zone Management Act Reauthorization Amendments 

(CZARA) of 1990, Congress identified nonpoint source pollution as a major 

factor in the continuing degradation of coastal waters. Congress also 

recognized that effective solutions to nonpoint source pollution could be 

implemented at the state/tribe and local levels. In CZARA, Congress added 

Section 6217 (16 U.S.C. section 1455b), which calls upon states/tribes with 

federally-approved coastal zone management programs to develop and 

implement coastal nonpoint pollution control programs. The Section 6217 

program is administered at the federal level jointly by EPA and the National 

Oceanic and Atmospheric Agency (NOAA). 

Section 6217(g) called for EPA, in consultation with other agencies, to 

develop guidance on “management measures” for sources of nonpoint source 

pollution in coastal waters. Under Section 6217, EPA is responsible for 

developing technical guidance to assist states/tribes in designing coastal 

nonpoint pollution control programs. On January 19, 1993, EPA issued its 

Guidance Specifying Management Measures For Sources of Nonpoint 

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Pollution in Coastal Waters, which addresses five major source categories 

of nonpoint pollution: (1) urban runoff, (2) agriculture runoff, (3) forestry 

runoff, (4) marinas and recreational boating, and (5) hydromodification. 

Additional information on coastal zone management may be obtained from 

EPA’s Office of Wetlands, Oceans, and Watersheds, www.epa.gov/owow, or 

from the Watershed Information Network www.epa.gov/win. The NOAA 

website, http://www.ocrm.nos.noaa.gov/czm/, also contains additional 

information on coastal zone management. 

VI.B. Industry Specific Requirements 

Clean Air Act (CAA) 

National Ambient Air Quality Standards

At pulp and paper mills, air emissions from both process and combustion

units are regulated under the National Ambient Air Quality Standards

(NAAQS) and the State Implementation Plans (SIP) that enforce the

standards. States may implement controls to limit emissions of particulate

matter (PM), nitrogen oxides (NOx), volatile organic compounds (VOC), and

sulfur dioxide (SO2). 

Although many limits are implemented at the state level, there are national 

guidelines that serve as a basis for more specific limits. Sources that are 

considered "major" under the Clean Air Act are subject to prevention of 

significant deterioration (PSD) or new source review (NSR). Both PSD and 

NSR are permit programs for facilities that were constructed or modified 

after a certain date. 

Facilities in NAAQS attainment areas must follow PSD requirements by 

demonstrating that the construction/modification project will not cause a 

violation of air quality limits and by implementing the best available control 

technology (BACT). 

New or modified facilities in nonattainment areas must follow NSR 

requirements, which require the source to meet the lowest achievable 

emission rate (LAER) and to obtain emission offsets to ensure that the 

nonattainment problem is not made worse by the new/modified source. 

In addition to the PSD/NSR pre-construction obligations, there are processspecific operational standards: New Source Performance Standards (NSPS). 

40 CFR 60 lists these standards, which serve as minimum requirements in 

states SIPs. Individual states may impose requirements that are more strict. 

The following NSPSs are particularly relevant to the pulp and paper industry: 

Sector Notebook Project 85 November 2002 
Pulp and Paper Industry Federal Statutes and Regulations 

Subpart BB Kraft pulp mills

(Regulates PM and TRS emissions from new kraft

mills.)

Subparts D, Db, Dc Industrial boilers 

(Regulates PM, nitrogen oxides (NOx) and sulfur 

dioxide (SO2) from new boilers used at pulp and 

paper mills.) 

Subpart GG Gas-fired turbines 

(Regulates PM, nitrogen oxides (NOx) and sulfur 

dioxide (SO2) from new gas-fired turbines used at 

pulp and paper mills.) 

Subpart Kb Volatile Organic Liquid Storage Vessels (Including 

Petroleum Liquid Storage Vessels) 

(Regulates VOC from applicable storage tanks 

containing volatile organic liquids at pulp and paper 

mills) 

Hazardous Air Pollutants 

Air toxics regulations apply to several parts of the pulp and paper milling 

process. National Emission Standards for Hazardous Air Pollutants 

(NESHAP) have been developed expressly for two processes of the pulp and 

paper industry. Both NESHAPs establish process-based maximum 

achievable control technologies (MACT) for "major sources," which are 

defined as facilities that emit or have the potential to emit 10 tons per year 

or more of any hazardous air pollutant (HAP) or 25 tons per year or more of 

any combination of HAPs. Standards for both MACT I & III standards are 

integrated into one subpart (Subpart S) of 40 CFR 63. MACT II standards are 

in a separate subpart (Subpart MM).: 

Subpart S Controlling HAP emissions from the pulp and paper 

production areas of mills using the kraft, sulfite, semichemical, and soda pulping processes (MACT I), and 

controlling HAP emissions from pulp and paper 

production areas of mills using mechanical, secondary 

fiber, and non-wood pulping, and papermaking 

systems at all mills (MACT II). 

Subpart MM Controlling HAP emissions from chemical recovery 

processes that involve the combustion of spent 

pulping liquor at kraft, soda, sulfite, and stand-alone 

semichemical pulp mills (MACT III). 

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Other NESHAPs that are relevant for the industry are those for asbestos 

(relevant during demolition and renovation activities) and mercury 

(important for sludge dryers and incinerators). Unlike the industry-specific 

NESHAP standards, chemical-specific NESHAPs may apply to all facilities 

regardless of their size. 

Risk Management Program 

Pulp and paper mills are subject to section 112(r) of CAA, which states that 

stationary sources using extremely hazardous substances have a "general 

duty" to initiate specific activities to prevent and mitigate accidental releases. 

The general duty requirements apply to stationary sources that produce, 

process, handle, or store these substances, regardless of the quantity of 

managed at the facility. Although there is no list of "extremely hazardous 

substances," EPA’s Chemical Emergency Preparedness and Prevention 

Office provides some guidance at its website: www.epa.gov/ceppo. The 

general duty clause requires facilities to identify hazards that may result from 

accidental releases, to design and maintain a safe facility, and to minimize 

the consequences of releases when they occur. 

Most pulp and paper mills are subject to additional, more explicit risk 

management requirements. Facilities that have more than a threshold 

quantity of any of the 140 regulated substances in a single process are 

required to develop a risk management program and to summarize their 

program in a risk management plan (RMP). Mills subject to the requirements 

were required to submit a registration and RMP in 1999 or whenever they 

first exceed the threshold for a listed regulated substance after that date. 

All facilities meeting the RMP threshold requirements must follow Program 

1 requirements: 

• An offsite consequence analysis that evaluates specific potential 

release scenarios, including worst-case and alternative scenarios. 

• A five-year history of certain accidental releases of regulated 

substances from covered processes. 

• A risk management plan, revised at least once every five years, that 

describes and documents these activities for all covered processes. 

In addition, most pulp and paper facilities may be subject to the requirements 

of Program 2 or 3. These additional requirements include: 

• An integrated prevention program to manage risk. The prevention 

program will include identification of hazards, written operating 

procedures, training, maintenance, and accident investigation. 

• An emergency response program. 

• An overall management system to put these program elements into 

effect. 

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The list of chemicals that trigger RMP requirements can be found in 40 CFR

68.130; information to determine the required program level also can be

found in 40 CFR 68.

Title V permits

Title V requires that all "major sources" (and certain minor sources) obtain

an operating permit. Many pulp and paper mills are required to have a Title

V permit, and may be required to submit information about emissions,

control devices, and the general process at the facility in the permit

application. Permits may limit pollutant emissions and impose monitoring,

record keeping, and reporting requirements.

Title VI Stratospheric Ozone Protection

Many pulp and paper facilities operate industrial process refrigeration units,

such as chillers for chlorine dioxide plants. For those units that utilize ozonedepleting chemicals, such as chlorofluorocarbons (CFCs), facilities are

required under Title VI to follow leak repair requirements.

Clean Water Act (CWA) 

There are two industry-specific components of the CWA requirements: 

NPDES permitting and pretreatment programs. Other general CWA 

requirements, such as those for wetlands and stormwater, may also apply to 

the pulp and paper mills and are described in Section VI.A. 

Individual NPDES requirements have been developed for several 

subcategories of the industry; they are described in 40 CFR 430. For each 

of these subcategories, the regulations outline some or all of the following for 

facilities that discharge wastewater directly to the environment: 

• best practicable control technology currently available (BPT) and 

best conventional control technology (BCT) guidelines for the control 

of conventional pollutants (biological oxygen demand, total 

suspended solids, and pH). 

• best available technology economically achievable (BAT) guidelines 

for the control of nonconventional and toxic pollutants 

(trichlorophenol and pentachlorophenol, which are chemicals used as 

biocides). 

• new source performance standards (NSPS) for the control of 

conventional, non-conventional, and toxic pollutants from new 

facilities that discharge directly to the environment. 

Sector Notebook Project 88 November 2002 
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For facilities that discharge their wastewater to a publicly-owned treatment 

works (POTW), pretreatment standards may apply. In addition to general 

standards established by EPA that address all industries, there are 

Pretreatment Standards for New Sources (PSNS) and Pretreatment Standards 

for Existing Sources (PSES) that are specific to the pulp and paper industry. 

These regulate the biocides trichlorophenol and pentachlorophenol, with 

limits that are specified for each subcategory of the industry. 

In 1998, in conjunction with the development of the pulp and paper cluster 

rule, EPA reorganized the regulations in order to group processes that are 

similar. Table 19 presents the revised and original subcategory groupings, 

and summarizes the portions of the CWA regulations that apply. More detail 

can be found in 40 CFR 430. 

Table 19: Applicability of Clean Water Act Requirements 

Revised 

Subpart of 

40 CFR 430 

Revised 

Subcategory 

Previous Subcategory 

(Previous Subpart in Parentheses) 

Applicable Regulations 

BAT, 

PSES, 

and 

PSNS 

BPT, 

BCT, 

NSPS 

BMP 

A Dissolving Kraft Dissolving Kraft (F) U U

B Bleached 

Papergrade Kraft 

and Sodaa 

Market Bleached Kraft (G) 

BCT Bleached Kraft (H) 

Fine Bleached Kraft (I) 

Soda (P) 

U U U

C Unbleached Kraft Unbleached Kraft (A) 

• Linerboard 

• Bag and Other Products 

Unbleached Kraft and Semi-Chemical 

(D, V) 

U U

D Dissolving Sulfite Dissolving Sulfite (K) 

• Nitration 

• Viscose 

• Cellophane 

• Acetate 

U U

E Papergrade Sulfitea Papergrade Sulfite (J, U) 

• Blow Pit Wash 

• Drum a W sh 

U U U

F Semi-Chemical Semi-Chemical (B) 

• Ammonia 

• Sodium 

U U

G Mechanical Pulp Groundwood-Thermo-Mechanical (M) 

Groundwood-Coarse, Molded, News (N) 

Groundwood-Fine Papers (O) 

Groundwood-Chemi-Mechanical (L) 

U

Sector Notebook Project 89 November 2002 
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Table 19: Applicability of Clean Water Act Requirements 

Revised 

Subpart of 

40 CFR 430 

Revised 

Subcategory 

Previous Subcategory 

(Previous Subpart in Parentheses) 

Applicable Regulations 

BAT, 

PSES, 

and 

PSNS 

BPT, 

BCT, 

NSPS 

BMP 

H Non-Wood 

Chemical Pulp 

Miscellaneous mills not covered by a 

specific subpart 

U

I Secondary Fiber 

Deink 

Deink Secondary Fiber (Q) 

• Fine ap P ers 

• Tissue Papers 

• Newsprint 

U

J Secondary Fiber 

Non-Deink 

Tissue from Wastepaper (T) 

Paperboard from Wastepaper (E) 

• Corrugating Medium 

• Non-Corrugating Medium 

Wastepaper-Molded Products (W) 

Builders’ Paper and Roofing Felt (40 

CFR Part 431 Subpart A) 

K Fine and 

Lightweight Papers 

from Purchased 

Pulp 

Nonintegrated Fine Papers (R) 

• Wood Fiber Furnish 

• Cotton Fiber Furnish 

Nonintegrated Lightweight Papers (X) 

• Lightweight Papers 

• Lightweight Electrical Papers 

U

L Tissue, Filter, 

Non-Woven, and 

Paperboard from 

Purchased Pulp 

Non-Integrated 

• Tissue Papers (S) 

• Filter and Non-Woven (Y) 

• Paperboard (Z) 

U

Source: U.S. EPA, Pulp and Paper NESHAP: A Plain English Description, November, 1998, Pages 7 and 104. a

These subcategories are affected by the Cluster Rules (described below). 

Cluster Rule 

The cluster rule is an integrated, multi-media regulation to control the release 

of pollutants to two media (air and water) from one industry. The intent of 

the rule is to allow individual mills in particular segments of the industry to 

consider all regulatory requirements at one time. This combined rule allows 

mills to select the best combination of pollution prevention and control 

technologies that provide the greatest protection to human health and the 

environment. Because some air requirements that reduce toxic air pollutants 

also reduce mill wastewater toxic pollutant loadings (and water treatment 

requirements can reduce air impacts), the combined rules have a synergistic 

effect. 

Sector Notebook Project 90 November 2002 
Pulp and Paper Industry Federal Statutes and Regulations 

Some of the features of the coordinated rule include: 

• Alternative emission limits 

• Varying compliance periods (3-8 years) 

• New and existing source controls 

• Flexibility for evolving technologies 

• Compliance dates coordinated with effluent limitations guidelines 

and standards 

The rule sets new baseline limits for the releases of toxics and 

nonconventional pollutants to the air and water. There are three significant 

components: 

• Air Emissions Standards. New and existing pulp and paper mills 

must meet air standards to reduce emissions of toxic air pollutants 

occurring at various points throughout the mills. Specifically, EPA 

requires mills to capture and treat toxic air pollutant emissions that 

occur during the cooking, washing, and bleaching stages of the pulp 

manufacturing process. 

• Water Effluent Limitations Guidelines and Standards. New and 

existing standards in the bleached papergrade kraft and soda 

subcategory and the bleached papergrade sulfite subcategory must 

meet standards to reduce discharges of toxic and nonconventional 

pollutants. Specifically, EPA has set effluent limitations for toxic 

pollutants in the wastewater discharged directly from the bleaching 

process and in the final discharge from the mills. 

• Analytical Methods for 12 Chlorinated Phenolics and Adsorbable 

Organic Halides (AOXs). Samples of air emissions and water 

discharges from each mill must be tested using the laboratory 

methods included in the rule. The new methods will enable more 

timely and accurate measurements of releases of these pollutants to 

the environment and will be used to ensure compliance with air 

emission and water discharge permit limits. 

Voluntary Advanced Technology Incentives Program (VATIP)

Mills in the Bleached Papergrade Kraft and Soda Subcategory have

additional flexibility under the cluster rule. Mills may comply either with the

baseline regulations, or with more stringent wastewater regulations under a

more forgiving timetable. This latter arrangement, called the Voluntary

Advanced Technology Incentives Program (VATIP), allows mills to

undertake customized compliance and pollution reduction plans that further

reduce environmental impacts. 

Sector Notebook Project 91 November 2002 
Pulp and Paper Industry Federal Statutes and Regulations 

Under the VATIP, each participating mill develops “Milestones Plans” for 

each fiber line that it enrolls in the program. Permit writers will use the 

Milestones Plan to incorporate enforceable interim requirements into the 

mill’s discharge permit. Specific requirements for the Milestones Plan are 

found in 40 CFR 430.24(b) and (c), but the three basic components of a 

Milestones Plan are the following: 

• A description of each technology component or process modification 

the mill intends to implement 

• the master schedule showing the sequence of implementing new 

technologies and process modifications 

• descriptions of the anticipated improvements in effluent quality. 

Emergency Planning and Community Right-to-Know Act (EPCRA) 

Three of the components of EPCRA are directly relevant to the pulp and 

paper industry: 

• Emergency Planning (§302(a)) - Businesses that produce, use or store 

"hazardous substances" must: 1) submit material safety data sheets or 

the equivalent, and 2) Tier I/Tier II annual inventory report forms to 

the appropriate local emergency planning commission. Those 

handling "extremely hazardous substances" also are required to 

submit a one-time notice to the state emergency response 

commission. 

• Emergency Notification of Extremely Hazardous Substance Release 

(§304) - A business that unintentionally releases a reportable quantity 

of an extremely hazardous substance must report that release to the 

state emergency planning commission and the local emergency 

planning commission. 

• Release Reporting (§313) - Manufacturing businesses with ten or 

more employees that manufactured, processed, or otherwise used a 

listed toxic chemical in excess of the "established threshold" must file 

annually a Toxic Chemical Release form with EPA and the state. 

Documentation supporting release estimates must be kept for three 

years. 

Resource Conservation and Recovery Act (RCRA) 

The pulp and paper industry generates hazardous wastes, but most are 

associated with wastewater, which is rendered non-hazardous in wastewater 

Sector Notebook Project 92 November 2002 
Pulp and Paper Industry Federal Statutes and Regulations 

treatment or neutralization units within manufacturing facilities, and 

therefore is not subject to RCRA requirements. Also, black liquor is exempt 

as a solid waste if it is reclaimed in a recovery furnace and reused in the 

pulping process. Therefore, most of the industry’s RCRA requirements are 

those described in the general regulations outlined in Section VI.A. 

VI.C. Pending and Proposed Regulatory Requirements 

Clean Water Act 

Effluent Guidelines and Standards for the Pulp, Paper, and Paperboard 

Category, Phase II 

EPA will consider revising the technology-based effluent limitations 

guidelines and standards for 8 of the 12 subcategory for this industrial 

category: Unbleached Kraft; Semi-Chemical; Mechanical Pulp; Non-Wood 

Chemical Pulp; Secondary Fiber Deink; Secondary Fiber Non-Deink; Fine 

and Lightweight Papers from Purchased Pulp; and Tissue, Filter, NonWoven, and Paperboard from Purchased Pulp. EPA proposed guidelines and 

standards for these subcategories as part of the Pulp and Paper Rules (also 

known as the Cluster Rules) in December 1993. The Agency intends to 

develop these revised effluent limitations in close coordination with the 

Office of Air Quality Planning and Standards. This is a long-term action; no 

definite schedule had been set at the time of the publication of this document. 

(Don Anderson, Office of Water, 202-566-1021) 

Effluent Guidelines and Standards for the Pulp, Paper, and Paperboard Point 

Source Category, Dissolving Kraft and Dissolving Sulfite Subcategories 

(Phase III) 

In 1993, EPA proposed revised effluent limitations, guidelines and standards 

and best management practices regulations for the Dissolving Kraft and 

Dissolving Sulfite Subcategories (also known as Phase III of the Cluster 

Rules). There are five mills in these subcategories in the U.S. EPA 

anticipates that the final rule will set limits for adsorbable organic halides 

(AOX), chemical oxygen demand (COD), chloroform, dioxin, furan, and 12 

specific chlorinated phenolics. The rule is expected to be proposed in mid2003 and finalized in 2004. (Don Anderson, Office of Water, 202-566-1021) 

Minimizing Adverse Environmental Impact from Cooling Water Intake

Structures at Existing Facilities Under Section 316(b) of the Clean Water

Act, Phase III

This rulemaking affects existing facilities that use cooling water intake

structures, and whose intake flow levels exceed a minimum threshold EPA

will determine. Pulp and paper manufacturing facilities are explicitly listed

as affected facilities. The rule will require that the location, design,

construction, and capacity of cooling water intake structures reflect the best

Sector Notebook Project 93 November 2002 
Pulp and Paper Industry Federal Statutes and Regulations 

technology available for minimizing adverse environmental impact. The 

final rule is anticipated before December, 2004. (Deborah Nagle, Office of 

Water, 202-566-1063 or J.T. Morgan, Office of Water, 202-564-7684) 

Clean Air Act 

Guidelines for Best Available Retrofit Technology (BART) 

As required by the Clean Air Act, EPA issued a regional haze rule aimed at 

protecting visibility in 156 federal areas. The rule seeks to reduce the 

visibility impairment caused by many sources over a wide area. The haze rule 

requires states to establish goals for improving visibility in national parks and 

wilderness areas and to develop long-term strategies for reducing emissions 

of air pollutants that impair visibility. Guidelines for BART were proposed 

to amend the haze rule. The guidelines are for states in developing their plans 

for setting air pollution limits for utilities and other industrial plants built 

between 1962 and 1977 that have the potential to emit more than 250 tons a 

year of visibility impairing pollution. These facilities fall into 26 categories, 

including pulp mills. Many of these facilities have previously been exempt 

from federal pollution control requirements under the Clean Air Act. Some 

of the guidelines may affect emissions from boilers and recover boilers. This 

proposed rule only provides guidelines for states in developing their 

implementation plans. In most parts of the country, the plans are due in 2008. 

(Tim Smith, Office of Air and Radiation, 919-541-4718) 

Interstate Ozone Transport, NOX State Implementation Plan Call (NOX SIP 

Call) 

EPA has issued several actions and rulemakings related to reducing the 

regional transport of ozone, including the final Regional Transport of Ozone 

Rule ("NOx SIP call") requiring 22 eastern States and the District of 

Columbia to submit State Implementation Plans that address the regional 

transport of ground-level ozone through reductions in nitrogen oxides (a 

precursor to ozone). While most of the NOx SIP call was upheld, certain 

aspects of EPA's plan were remanded by court decisions, including a 

definition dealing with industrial boilers and cogeneration. In February of 

2002, EPA proposed rules on a number of remanded items, including rules 

for certain industrial boilers that may be present at pulp and paper mills. 

EPA's NOx SIP call potentially affects industrial boilers that burn at least 50 

percent fossil fuels. However, states are free to develop plans for reducing 

nitrogen oxides at sources other than industrial boilers or at industrial boilers 

that burn less than 50 percent fossil fuels. Pulp and paper mills in the eastern 

states should monitor their state implementation plans. Implementation of 

state plans will likely begin in 2003 in some States or 2004 for other States. 

(Kevin Culligan, Office of Air and Radiation, 202-564-9172) 

Sector Notebook Project 94 November 2002 
Pulp and Paper Industry Compliance and Enforcement History 

VII. COMPLIANCE AND ENFORCEMENT HISTORY 

Background 

Until recently, EPA has focused much of its attention on easuring compliance 

with specific environmental statutes. This approach allows the Agency to 

track compliance with the Clean Air Act, the Resource Conservation and 

Recovery Act, the Clean Water Act, and other environmental statutes. 

Within the last several years, the Agency has begun to supplement singlemedia compliance indicators with facility-specific, multimedia indicators of 

compliance. In doing so, EPA is in a better position to track compliance with 

all statutes at the facility level, and within specific industrial sectors. 

A major step in building the capacity to compile multimedia data for 

industrial sectors was the creation of EPA's Integrated Data for Enforcement 

Analysis (IDEA) system. IDEA has the capacity to "read into" the Agency's 

single-media databases, extract compliance records, and match the records 

to individual facilities. The IDEA system can match Air, Water, Waste, 

Toxics/Pesticides/EPCRA, TRI, and Enforcement Docket records for a given 

facility, and generate a list of historical permit, inspection, and enforcement 

activity. IDEA also has the capability to analyze data by geographic area and 

corporate holder. As the capacity to generate multimedia compliance data 

improves, EPA will make available more in-depth compliance and 

enforcement information. Additionally, sector-specific measures of success 

for compliance assistance efforts are under development. 

Compliance and Enforcement Profile Description 

Using inspection, violation and enforcement data from the IDEA system, this 

section provides information regarding the historical compliance and 

enforcement activity of this sector. Compliance and enforcement records 

from EPA's data systems are compiled to the facility level using the Facility 

Registry System's (FRS) Master Source ID, which links records from 

virtually any of EPA's data systems to a facility record. For each facility 

(i.e., Master Source ID), the Industry Sector Notebooks analysis uses the 

facility-level SIC code that is designated by IDEA, which can be described 

as follows: 

1. If the facility reports to TRI, then the designated SIC code is the 

primary SIC reported in the most recent TRI reporting year. 

2. If the facility does not report to TRI, the first SIC codes from all 

linked AFS, PCS, RCRAInfo, BRS ID/permits are assembled. If more than 

one permit/ID exists for a particular program then only one record from that 

data system is used. The SIC code that occurs most often, if there is one, 

Sector Notebook Project 95 November 2002 
Pulp and Paper Industry Compliance and Enforcement History 

becomes the designated SIC code. 

3. If the facility does not report to TRI and no SIC code occurs more 

often than others, the designated SIC code is chosen from the linked 

programs in the following order: AFS, PCS, BRS, RCR, NCD, DCK. If more 

than one permit/ID exists for a particular program then only one record from 

that data system is used. 

Note that EPA does not attempt to define the actual number of facilities that 

fall within each sector. Instead, the information presented in this section 

portrays the records of a subset of facilities within the sector that are well 

defined within EPA databases. 

As a check on the relative size of the full sector universe, most notebooks 

contain an estimated number of facilities within the sector according to the 

Bureau of Census (See Section II). With sectors dominated by small 

businesses, such as metal finishers and printers, the reporting universe within 

the EPA databases may be small in comparison to Census data. However, 

the group selected for inclusion in this data analysis section should be 

consistent with this sector's general make-up. 

Following this introduction is a list defining each data column presented 

within this section. These values represent a retrospective summary of 

inspections or enforcement actions, and solely reflect EPA, state and local 

compliance assurance activity that have been entered into EPA databases. 

To identify any changes in trends, the EPA ran two data queries, one for the 

past five calendar years (September 16, 1997 to September 15, 2002) and the 

other for the most recent 24-month period (September 16, 2000 to September 

15, 2002). The five-year analysis gives an average level of activity for that 

period for comparison to the more recent activity. 

Because most inspections focus on single-media requirements, the data 

queries presented in this section are taken from single media databases. 

These databases do not provide data on whether inspections are state/local 

or EPA-led. However, the table breaking down the universe of violations 

does give the reader a general measurement of the EPA's and states' efforts 

within each media program. The presented data illustrate the variations 

across Regions for certain sectors.3 This variation may be attributable to 

state/local data entry variations, specific geographic concentrations, 

proximity to population centers, sensitive ecosystems, highly toxic chemicals 

used in production, or historical noncompliance. Hence, the exhibited data 

3

 EPA Regions include the following states: I (CT, MA, ME, RI, NH, VT); II (NJ, NY, PR, VI); 

III (DC, DE, MD, PA, VA, 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). 

Sector Notebook Project 96 November 2002 
Pulp and Paper Industry Compliance and Enforcement History 

do not rank regional performance or necessarily reflect which regions may 

have the most compliance problems. 

Compliance and Enforcement Data Definitions 

General Definitions 

Facility Registry System (FRS) -- this system assigns a common Master 

Source ID to EPA single-media permit records. The Master Source ID 

allows EPA to compile and review all permit, compliance, enforcement and 

pollutant release data for any given regulated facility. 

Integrated Data for Enforcement Analysis (IDEA) -- is a data integration 

system that can retrieve information from the major EPA program office 

databases. IDEA uses the FRS maintained Master Source ID identification 

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), RCRAInfo (Resource Conservation 

and Recovery Information System, Office of Solid Waste), NCDB (National 

Compliance Data Base, Office of Prevention, Pesticides, and Toxic 

Substances), CERCLIS (Comprehensive Environmental and Liability 

Information System, Superfund), and TRIS (Toxic Release Inventory 

System). IDEA also contains information from outside sources such as Dun 

and Bradstreet and the Occupational Safety and Health Administration 

(OSHA). Most data queries displayed in notebook sections IV and VII were 

conducted using IDEA. 

Data Table Column Heading Definitions 

Facilities in Search -- are based on the number of the FRS maintained 

Master Source IDs that were designated to the listed SIC code range. The 

SIC code range selected for each search is defined by each notebook's 

selected SIC code coverage described in Section II. 

Facilities Inspected -- indicates the level of EPA and state agency 

inspections for the facilities in this data search. These values show what 

percentage of the facility universe is inspected in a 24- or 60- month period. 

Number of Inspections -- measures the total number of inspections 

conducted in this sector. An inspection event is counted each time it is 

entered into a single media database. 

Average Time Between Inspections -- provides an average length of time, 

expressed in months, that a compliance inspection occurs at a facility within 

Sector Notebook Project 97 November 2002 
Pulp and Paper Industry Compliance and Enforcement History 

the defined universe. 

Facilities with One or More Enforcement Actions -- expresses the number 

of facilities that were party to at least one enforcement action within the 

defined time period. This category is broken down further into federal and 

state actions. Data are obtained for administrative, civil/judicial, and 

criminal enforcement actions. Administrative actions include Notices of 

Violation (NOVs). A facility with multiple enforcement actions is only 

counted once in this column (facility with three enforcement actions counts 

as one). All percentages that appear are referenced to the number of facilities 

inspected. 

Total Enforcement Actions -- describes the total number of enforcement 

actions identified for an industrial sector across all environmental statutes. 

A facility with multiple enforcement actions is counted multiple times (a 

facility with three enforcement actions counts as three). 

State Lead Actions -- shows what percentage of the total enforcement 

actions are taken by state and local environmental agencies. Varying levels 

of use by states of EPA data systems may limit the volume of actions 

accorded state enforcement activity. Some states extensively report 

enforcement activities into EPA data systems, while other states may use 

their own data systems. 

Federal Lead Actions -- shows what percentage of the total enforcement 

actions are taken by the United States Environmental Protection Agency. 

This value includes referrals from state agencies. Many of these actions 

result from coordinated or joint state/federal efforts. 

Enforcement to Inspection Rate -- expresses how often enforcement 

actions result from inspections. This value is a ratio of enforcement actions 

to inspections, and is presented for comparative purposes only. This measure 

is a rough indicator of the relationship between inspections and enforcement. 

This measure simply indicates historically how many enforcement actions 

can be attributed to inspection activity. Reported inspections and 

enforcement actions under the Clean Water Act (PCS), the Clean Air Act 

(AFS) and the Resource Conservation and Recovery Act (RCRA) are 

included in this ratio. Inspections and actions from the 

TSCA/FIFRA/EPCRA database are not factored into this ratio because most 

of the actions taken under these programs are not the result of facility 

inspections. This ratio does not account for enforcement actions arising from 

non-inspection compliance monitoring activities (e.g., self-reported water 

discharges) that can result in enforcement action within the CAA, CWA and 

RCRA. 

Facilities with One or More Violations Identified -- indicates the 

Sector Notebook Project 98 November 2002 
Pulp and Paper Industry Compliance and Enforcement History 

percentage of inspected facilities having a violation identified in one of the 

following data categories: In Violation or Significant Violation Status 

(CAA); Reportable Noncompliance, Current Year Noncompliance, 

Significant Noncompliance (CWA); Noncompliance and Significant 

Noncompliance (FIFRA, TSCA, and EPCRA); Unresolved Violation and 

Unresolved High Priority Violation (RCRA). The values presented for this 

column reflect the extent of noncompliance within the measured time frame, 

but do not distinguish between the severity of the noncompliance. 

Percentages within this column can exceed 100 percent because facilities can 

be in violation status without being inspected. Violation status may be a 

precursor to an enforcement action, but does not necessarily indicate that an 

enforcement action will occur. 

Media Breakdown of Enforcement Actions and Inspections -- four 

columns identify the proportion of total inspections and enforcement actions 

within EPA Air, Water, Waste, and TSCA/FIFRA/EPCRA databases. Each 

column is a percentage of either the “Total Inspections,” or the “Total 

Actions” column. 

VII.A. Pulp and Paper Industry Compliance History 

Table 20 provides an overview of the reported compliance and enforcement 

data for the pulp and paper industry over the past five years (September 16, 

1997 to September 15, 2002). These data are also broken out by EPA Region 

thereby permitting geographical comparisons. A few points evident from the 

data are listed below. 

C Regions 5, 4 and 1 contain the most pulp and paper facilities, while 

Regions 4, 6, and 3 conducted the most inspections. 

C Region 4 conducted, by far, the most inspections of pulp and paper 

facilities, had the lowest average time between inspections, and had 

the most enforcement actions. 

C Regions 2 and 10 had the most enforcement actions per inspection 

(0.19 and 0.13, respectively). 

Sector Notebook Project 99 November 2002 
Pulp and Paper Industry Compliance and Enforcement History Table 20: Five-Year Enforcement and Compliance Summary for the Pulp and Paper Industry, by Region J Enforcement to Inspection Rate 0.08 0.06 0.19 0.09 0.06 0.06 0.06 0.03 0 0.09 0.13 I Percent of Federal Lead Actions 15% 5% 4% 23% 9% 30% 30% 0% 0% 0% 6% H Percent of State Lead Actions 85% 95% 96% 77% 91% 70% 70% 100% 0% 100% 94% G Total Enforcement Actions 503 37 73 

77 

116 

44 56 

1 0 

12 72 

F 

Facilities with 

1 or More 

Enforcement 

Actions 

332 

38 34 26 90 48 32 

2 0 

16 40 

E 

Average 

Months 

Between 

Inspections 

5 

10 11 

4 3 

12 

3 

13 40 

9 4 

D 

Number of 

Inspections 

6,383 

571 383 899 

2,024 

721 944 

33 

3 

140 537 

C 

Facilities 

Inspected 

495 

73 57 47 96 

120 

40 

7 2 

18 32 

B 

Facilities In 

Search 

585 

92 71 57 

105 144 

45 

7 2 

22 37 

A 

Region 

National 

1 2 3 4 5 6 7 8 9 

10 

Sector Notebook Project 100 November 2002 
Pulp and Paper Industry Compliance and Enforcement History 

VII.B. Comparison of Enforcement Activity Between Selected Industries 

Tables 21 and 22 allow the compliance history of the pulp and paper sector 

to be compared to the other industries covered by the industry sector 

notebooks. Comparisons between Tables 21 and 22 permit the identification 

of trends in compliance and enforcement records of the industry by 

comparing data covering the last five years to that of the past two years. 

Some points evident from the data are listed below. 

C Pulp and paper mills are tied with petroleum refineries as the most 

frequently inspected sectors of those listed. 

C Pulp and paper mills have a relatively high percent of facilities with 

violations and enforcement actions and a relatively high rate of 

enforcement per inspection compared to the other sectors listed. 

Tables 23 and 24 provide a more in-depth comparison between the pulp and 

paper industry and other sectors by breaking out the compliance and 

enforcement data by environmental statute. As in the previous Tables 

(Tables 21 and 22), the data cover the last five years (Table 23) and the last 

two years (Table 24) to facilitate the identification of recent trends. Two 

points evident from the data are listed below. 

C The majority of inspections and actions are conducted under the 

CAA, followed by the CWA. 

C In the past 2 years, the portion of actions taken under the CAA is 

increasing, while that taken under the CWA is decreasing. 

C The pulp and paper industry has one of the lowest percentages of 

RCRA inspections and actions of those sectors listed. 

Sector Notebook Project 101 November 2002 
Pulp and Paper Industry Compliance and Enforcement History

Table 21: Five-Year Enforcement and Compliance Summary for Selected Industries 

J 

Enforcement 

to 

Inspection 

Rate 

0.03 

0.05 

0.06 

0.1 

0.05 

0.07 

0.07 

0.05 

0.08 

0.07 

0.07 

0.09 

0.08 

0.09 

0.07 

0.18 

0.08 

0.07 

0.07 

0.09 

0.13 

0.09 

0.08 

0.07 

0.09 

0.13 

0.05 

0.08 

0.1 

0.07 

0.04 

I 

Percent 

Federal 

Lead 

Actions 

40% 

67% 

18% 

6% 

6% 

14% 

15% 

14% 

15% 

13% 

26% 

16% 

22% 

28% 

48% 

31% 

12% 

10% 

28% 

22% 

11% 

25% 

26% 

18% 

38% 

26% 

0% 

18% 

26% 

17% 

9% 

H 

Percent 

State Lead 

Actions 

60% 

33% 

82% 

94% 

94% 

86% 

85% 

86% 

85% 

87% 

74% 

84% 

78% 

72% 

52% 

70% 

88% 

90% 

72% 

78% 

89% 

75% 

74% 

82% 

62% 

74% 

0% 

82% 

74% 

83% 

91% 

G 

Total 

Closed 

Enforcement 

Actions 

5 

6 

60 

640 

548 

271 

759 

314 

503 

378 

421 

429 

215 

811 

160 

1,153 

685 

933 

493 

343 

446 

1,593 

220 

381 

239 

110 

662 

33 

65 

1,346 

141 

F 

Facilities with 

1 or More 

Enforcement 

Actions 

10 

8 

58 

794 

532 

278 

834 

386 

332 

434 

386 

320 

204 

574 

218 

348 

834 

838 

320 

338 

258 

1,982 

296 

424 

258 

100 

796 

42 

72 

1,062 

210 

E 

Average 

Months 

Between 

Inspections 

53 

37 

18 

25 

21 

19 

17 

18 

5 

29 

12 

9 

14 

8 

18 

5 

27 

17 

6 

22 

10 

30 

37 

21 

17 

16 

23 

39 

39 

11 

59 

D 

Number of 

Inspections 

164 

114 

1,003 

6,386 

10,806 

4,002 

11,336 

5,822 

6,383 

5,100 

5,654 

4,964 

2,605 

8,839 

2,290 

6,238 

8,651 

13,144 

7,285 

3,728 

3,340 

16,959 

2,670 

5,340 

2,756 

859 

13,160 

406 

669 

18,122 

3,469 

C 

Facilities 

Inspected 

73 

30 

188 

1,620 

2,193 

911 

2,181 

1,166 

495 

1,589 

700 

545 

463 

832 

375 

324 

2,313 

2,214 

517 

822 

358 

5,268 

925 

1,247 

549 

171 

3,316 

166 

242 

2,335 

1,851 

B 

Facilities 

in 

Search 

146 

71 

293 

2,675 

3,771 

1,284 

3,260 

1,746 

585 

2,445 

1,092 

779 

628 

1,107 

674 

476 

3,870 

3,625 

704 

1,383 

561 

8,426 

1,663 

1,880 

791 

230 

4,991 

263 

436 

3,295 

3,390 

A 

Industry Sector Agricultural Crop Production Agricultural Livestock Production Metal Mining Oil and Gas Extraction Non-Fuel, NonMetal Mining Textiles Lumber and Wood Wood Furniture and Fixtures Pulp and Paper Printing Inorganic Chemicals Plastic Resins and Fibers Pharmaceuticals Organic Chemicals Ag. Chem., Pesticide & Fertilizer Petroleum Refining Rubber and Plastic Stone, Clay, Glass and Concrete Iron and Steel Metal Castings Nonferrous Metals Metal Products Electronics and Computers Motor Vehicle Assembly Aerospace Shipbuilding and Repair Ground Transportation Water Transportation Air Transportation Fossil Fuel Electric Power Generation Dry Cleaning 

Transportation equipment cleaning sector not included because sector is not classified by SIC code and no compliance data are available. * 

Sector Notebook Project 102 November 2002 
Pulp and Paper Industry Compliance and Enforcement History

Sector Notebook Project 103 November 2002 Table 22: Two-Year Enforcement and Compliance Summary for Selected Industries

A

C

D

E

F

G

H

Industry Sector Facilities in Search Facilities Inspected Number of Inspections

Facilities with 1 or More

Violations

Facilities with 1 or more

Enforcement Actions

Total Closed

Enforcement

Actions

Enforcementto Inspection

Rate Number Percent* Number Percent*

Agricultural Crop Production 146 38 65 10 26% 2 5% 1 0.02

Agricultural Livestock Production 71 8 16 6 75% 6 75% 5 0.31

Metal Mining 293 124 290 74 60% 28 23% 23 0.08

Oil and Gas Extraction 2,675 931 2,135 363 39% 546 59% 352 0.16

Non-Fuel, NonMetal Mining 3,771 1,340 3,389 328 24% 234 17% 204 0.06

Textiles 1,284 630 1,256 220 35% 174 28% 145 0.12

Lumber and Wood 3,260 1,467 3,714 580 40% 380 26% 328 0.09

Wood Furniture and Fixtures 1,746 752 1,916 316 42% 182 24% 139 0.07

Pulp and Paper 585 379 1,837 238 63% 158 42% 185 0.1

Printing 2,445 855 1,699 359 42% 234 27% 162 0.1

Inorganic Chemicals 1,092 473 1,793 242 51% 172 36% 141 0.08

Plastic Resins and Fibers 779 411 1,652 215 52% 164 40% 161 0.1

Pharmaceuticals 628 288 828 155 54% 76 26% 62 0.07

Organic Chemicals 1,107 599 2,782 365 61% 264 44% 261 0.09

Agricultural Chemical Pesticide & Fertilizer 674 232 734 108 47% 60 26% 37 0.05

Petroleum Refining 476 240 1,738 191 80% 224 93% 447 0.26

Rubber and Plastic 3,870 1,443 2,992 641 44% 408 28% 313 0.1

Stone, Clay, Glass and Concrete 3,625 1,488 4,254 496 33% 388 26% 351 0.08

Iron and Steel 704 373 2,201 250 67% 144 39% 149 0.07

Metal Castings 1,383 495 1,153 302 61% 180 36% 172 0.15

Nonferrous Metals 561 223 965 150 67% 118 53% 159 0.16

Metal Products 8,426 2,908 5,704 1728 59% 884 30% 588 0.1

Electronics and Computers 1,663 469 862 320 68% 140 30% 86 0.1

Motor Vehicle Assembly 1,880 816 1,897 410 50% 218 27% 167 0.09

Aerospace 791 329 854 179 54% 96 29% 69 0.08

Shipbuilding and Repair 230 100 295 63 63% 48 48% 35 0.12

Ground Transportation 4,991 2,059 4,696 490 24% 458 22% 327 0.07

Water Transportation 263 81 126 31 38% 6 7% 4 0.03Air Transportation 436 112 216 52 46% 32 29% 18 0.08

Fossil Fuel Electric Power Generation 3,295 1,810 6,355 701 39% 520 29% 493 0.08

Dry Cleaning 3,390 785 1,212 238 30% 74 9% 50 0.04

*Percentages in Columns E and F are based on the number of facilities inspected (Column C). because violations and actions can occur without a facility inspection.

Transportation equipment cleaning sector not included because sector is not classified by SIC code and no compliance data are available.

B

Percentages can exceed 100%
Pulp and Paper Industry Compliance and Enforcement History

Sector Notebook Project 104 November 2002 Table 23: Summary by Statute for Selected Industries Industry Sector Facilities Inspected Total Inspections Total Closed Enforcement Actions Clean Air Act

Clean Water Act RCRA

FIFRA/TSCA/EPCRA/Other

% of Total

Inspections

% of

Total

Actions

% of Total

Inspections

% of Total

Actions

% of Total

Inspections

% of

Total

Actions

% of Total

Inspections

% of

Total

Actions

Agricultural Crop Production 73 164 5 61% 40% 0% 0% 36% 20% 3% 40%

Agricultural Livestock Production 30 114 6 48% 50% 0% 17% 49% 17% 3% 17%

Metal Mining 188 1,003 60 61% 52% 26% 43% 13% 3% 1% 2%

Oil and Gas Extraction 1,620 6,386 640 96% 93% 0% 1% 4% 6% 0% 0%

Non-Fuel, NonMetal Mining 2,193 10,806 548 97% 98% 1% 1% 1% 1% 0% 0%

Textiles 911 4,002 271 74% 56% 13% 27% 13% 13% 1% 4%

Lumber and Wood 2,181 11,336 759 77% 73% 1% 2% 22% 24% 1% 2%

Wood Furniture and Fixtures 1,166 5,822 314 75% 74% 0% 1% 24% 24% 1% 1%

Pulp and Paper 495 6,383 503 68% 73% 24% 20% 7% 5% 1% 2%

Printing 1,589 5,100 378 65% 66% 0% 0% 35% 32% 1% 2%

Inorganic Chemicals 700 5,654 421 50% 50% 12% 13% 36% 28% 2% 10%

Plastic Resins and Fibers 545 4,964 429 51% 55% 19% 22% 29% 21% 2% 3%

Pharmaceuticals 463 2,605 215 48% 46% 6% 8% 44% 36% 2% 10%

Organic Chemicals 832 8,839 811 48% 48% 12% 15% 38% 30% 3% 7%

Agricultural Chemical Pesticide &Fertilizer

375 2,290 160 57% 31% 12% 9% 26% 21% 5% 39%

Petroleum Refining 324 6,238 1,153 63% 79% 12% 8% 24% 12% 1% 1%

Rubber and Plastic 2,313 8,651 685 69% 69% 1% 1% 29% 24% 1% 6%

Stone, Clay, Glass and Concrete 2,214 13,144 933 86% 87% 1% 1% 12% 10% 1% 2%

Iron and Steel 517 7,285 493 66% 62% 11% 14% 23% 21% 0% 3%

Metal Castings 822 3,728 343 64% 60% 2% 3% 33% 33% 1% 5%

Nonferrous Metals 358 3,340 446 65% 68% 7% 8% 27% 22% 1% 2%

Metal Products 5,268 16,959 1,593 45% 41% 2% 2% 52% 51% 1% 7%

Electronics and Computers 925 2,670 220 34% 16% 4% 4% 60% 67% 2% 13%

Motor Vehicle Assembly 1,247 5,340 381 61% 59% 1% 1% 37% 36% 0% 4%

Aerospace 549 2,756 239 48% 36% 3% 3% 48% 57% 0% 3%

Shipbuilding and Repair 171 859 110 58% 30% 5% 9% 36% 61% 1% 0%

Ground Transportation 3,316 13,160 662 78% 0% 1% 0% 21% 0% 0% 0%

Water Transportation 166 406 33 40% 33% 2% 0% 57% 67% 1% 0%

Air Transportation 242 669 65 31% 28% 2% 5% 67% 66% 0% 2%

Fossil Fuel Electric Power Generation 2,335 18,122 1,346 75% 85% 19% 9% 5% 4% 1% 2%

Dry Cleaning 1,851 3,469 141 36% 20% 0% 0% 64% 80% 0% 0%

* not included because sector is not classified by SIC code and no compliance data are available.

Five-Year Inspection and Enforcement 

Transportation equipment cleaning sector 
Pulp and Paper Industry Compliance and Enforcement History

Sector Notebook Project 105 November 2002 Table 24: Two-Year Inspection and Enforcement Summary by Statute for Selected Industries Industry Sector Facilities Inspected Total Inspections Total Closed Enforcement Actions Clean Air Act

Clean Water Act RCRA FIFRA/TSCA/

EPCRA/Other

% of Total

Inspections

% of

Total

Actions

% of Total

Inspections

% of

Total

Actions

% of Total

Inspections

% of

Total

Actions

% of Total

Inspections

% of

Total

Actions

Agricultural Crop Production 38 65 1 59% 100% 0% 0% 37% 0% 5% 0%

Agricultural Livestock Production 8 16 5 81% 60% 0% 20% 19% 0% 0% 20%

Metal Mining 124 290 23 46% 61% 35% 39% 19% 0% 0% 0%

Oil and Gas Extraction 931 2,135 352 97% 97% 0% 1% 3% 2% 0% 0%

Non-Fuel, NonMetal Mining 1,340 3,389 204 97% 99% 1% 1% 2% 1% 0% 1%

Textiles 630 1,256 145 71% 61% 16% 22% 13% 13% 0% 3%

Lumber and Wood 1,467 3,714 328 75% 75% 1% 1% 24% 22% 0% 2%

Wood Furniture and Fixtures 752 1,916 139 75% 85% 0% 0% 25% 14% 0% 1%

Pulp and Paper 379 1,837 185 64% 81% 28% 13% 7% 4% 0% 1%

Printing 855 1,699 162 64% 0% 0% 0% 35% 0% 1% 0%

Inorganic Chemicals 473 1,793 141 44% 56% 14% 12% 42% 25% 0% 7%

Plastic Resins and Fibers 411 1,652 161 50% 65% 21% 14% 29% 19% 0% 2%Pharmaceuticals 288 828 62 44% 45% 7% 11% 49% 37% 0% 6%

Organic Chemicals 599 2,782 261 43% 52% 14% 13% 40% 31% 2% 4%

Agricultural Chemical Pesticide &Fertilizer

232 734 37 51% 38% 13% 14% 33% 24% 3% 24%

Petroleum Refining 240 1,738 447 52% 83% 16% 6% 32% 10% 0% 1%

Rubber and Plastic 1,443 2,992 313 69% 79% 2% 0% 29% 20% 0% 2%

Stone, Clay, Glass and Concrete 1,488 4,254 351 86% 85% 2% 2% 12% 10% 0% 2%

Iron and Steel 373 2,201 149 60% 70% 13% 9% 27% 17% 0% 4%

Metal Castings 495 1,153 172 58% 60% 3% 2% 38% 33% 0% 4%

Nonferrous Metals 223 965 159 59% 80% 8% 3% 32% 16% 0% 2%

Metal Products 2,908 5,704 588 43% 46% 3% 1% 54% 43% 0% 9%

Electronics and Computers 469 862 86 30% 12% 5% 5% 65% 63% 1% 21%

Motor Vehicle Assembly 816 1,897 167 57% 63% 2% 1% 41% 32% 0% 5%Aerospace 329 854 69 46% 44% 4% 0% 50% 51% 0% 6%

Shipbuilding and Repair 100 295 35 59% 37% 6% 11% 35% 51% 0% 0%

Ground Transportation 2,059 4,696 327 75% 0% 1% 0% 24% 0% 0% 0%

Water Transportation 81 126 4 43% 50% 2% 0% 56% 50% 0% 0%

Air Transportation 112 216 18 29% 39% 1% 0% 69% 56% 0% 6%

Fossil Fuel Electric Power Generation 1,810 6,355 493 73% 87% 21% 8% 6% 3% 0% 2%

Dry Cleaning 785 1,212 50 37% 6% 0% 0% 63% 94% 0% 0%

* Transportation equipment cleaning sector not included because sector is not classified by SIC code and no compliance data are available.
Pulp and Paper Industry Compliance and Enforcement History 

Sector Facility Indexing Project -- Additional compliance information for 

the pulp and paper industry is available through EPA’s Sector Facility 

Indexing Project (SFIP). This is a website that brings together environmental 

and other information from a number of data systems to produce facilitylevel profiles for five industry sectors (pulp manufacturing, petroleum 

refining, iron and steel production, primary nonferrous metal refining and 

smelting, and automobile assembly) and a subset of major federal facilities. 

SFIP information relates to compliance and inspection history, chemical 

releases and spills, demographics of the surrounding population and 

production. (Contact: SFIP hotline at 617-520-3015 or the website at 

http://www.epa.gov/sfipmtn1/) 

VII.C. Review of Major Legal Actions 

This section provides summary information about major cases that have 

affected this sector, and a list of Supplementary Environmental Projects 

(SEPs). SEPs are compliance agreements that reduce a facility's stipulated 

penalty in return for an environmental project that exceeds the value of the 

reduction. Often, these projects fund pollution prevention activities that can 

significantly reduce the future pollutant loadings of a facility. 

This section discusses major legal cases and pending litigation within the 

pulp and paper industry as well as supplemental environmental projects 

(SEPs) involving pulp and paper facilities. Information regarding major cases 

or pending litigation is available fromthe Office of Regulatory Enforcement. 

VII.C.1. Review of Major Cases 

In FY 1999 and FY 2000, three significant enforcement cases affecting the 

pulp and paper industry were concluded. 

Potlatch Corporation. A Clean Air Act settlement was reached with the 

Potlatch Corporation of Lewiston, ID. From 1991 to 1996, Potlatch burned 

used tires in the boiler at its Lewiston, Idaho, pulp mill plant. In 1997, EPA 

issued Potlatch a Notice of Violation alleging that the burning of tires 

resulted in sulfur dioxide emissions that exceeded limits in a Clean Air Act 

permit issued by EPA in 1980 and also exceeded limits in a permit issued by 

the State in 1979. The notice also alleged that the switch to burning tires was 

the type of change that required Potlatch to first obtain a permit under the 

Clean Air Act’s Prevention of Significant Deterioration preconstruction 

review program. Following issuance of the Notice of Violation, settlement 

negotiations took place and an agreement was reached to settle the violations 

described in the notice by payment of a $500,000 civil penalty. Potlatch has 

the option of burning tires if it obtains a permit and installs the required 

pollution control devices, but has elected not to do so. 

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

Crane & Co., Inc. Crane & Co., Inc. (“Crane”), of Dalton, MA operates as 

a manufacturer and distributor of high quality specialty paper for the 

securities, legal, banking and business markets. This family owned and run 

company is nearly 200 years old, and has successfully held a currency paper 

contract with the U.S. Department of Treasury for 121 years. EPA’s civil 

administrative complaint under the Emergency Planning and Community 

Right to Know Act (EPCRA) focused on violations found at three of Crane’s 

facilities in Dalton and Pittsfield, MA. 

Since calendar year 1994, Crane failed to file chemical inventory information 

(Tier II forms) for three of its manufacturing facilities with the State 

Emergency Response Commission (SERC), Local Emergency Planning 

Committee (LEPC) or local fire departments, as required by Section 312 of 

EPCRA. In total, Crane failed to report 28 chemicals, including sulfuric acid 

and formaldehyde (a component of melamine resin), which EPCRA classifies 

as Extremely Hazardous Substances. 

By the terms of the September 2000 settlement of this action, Crane will pay 

a penalty of $8,164 and perform a supplemental environmental project (SEP) 

estimated to cost between $26,832 and $100,000. The SEP consists of 

replacing sodium hypochlorite as a bleaching agent in the non-wood pulp 

paper-making processes at the Pioneer Mill in Dalton with a 50 percent 

hydrogen peroxide solution. Use of peroxide bleaching will reduce human 

and environmental exposure to residual chlorine and chlorite ions that result 

from use of sodium hypochlorite. In addition, replacement of sodium 

hypochlorite with hydrogen peroxide will eliminate potential exposure of 

first responders and on-site workers to chlorine gas, which can be created if 

sodium hypochlorite is improperly mixed, used, or stored. Finally, 

discontinuing the use of sodium hypochlorite will reduce the environmental 

threat posed by discharging chlorinated organic compounds into the 

receiving waters of the Housatonic River. 

Appleton Papers. Appleton Papers in Roaring Spring, Pennsylvania 

produces pulp using the kraft process and paper using mechanical paper 

machines. Initially EPA issued a compliance order to Appleton requiring the 

initial performance test of the brown stock washer system and installation of 

the continuous emission monitoring system (CEMS) required by the NSPS 

of the Clean Air Act. These violations were subsequently referred to the 

Department of Justice on 12/30/98, and a Notice of Violation was issued to 

Appleton on 4/19/99. Following a series of negotiations, EPA and Appleton 

reached a settlement which provided for a cash penalty of $490,000 and early 

compliance with the Pulp and Paper MACT. The penalty reflects the avoided 

costs of installation of Total Reduced Sulfur CEMS, as well as the 

company’s adherence to EPA’s initial compliance order. The Consent Decree 

was lodged August 16, 2000. 

Sector Notebook Project 107 November 2002 
Pulp and Paper Industry Compliance and Enforcement History 

VII.C.2. Supplementary Environmental Projects 

SEPs are compliance agreements that reduce a facility's non-compliance 

penalty in return for an environmental project that exceeds the value of the 

reduction. Often, these projects fund pollution prevention activities that can 

reduce the future pollutant loadings of a facility. Information on SEP cases 

can be accessed via the Internet at http://www.epa.gov/compliance/resources/ 

policies/civil/seps/index.html. 

Table 25 presents nine examples of SEPs negotiated with pulp and paper 

facilities. 

Six of the cases were associated with EPCRA – most relate to a failure to 

notify community and state emergency coordinators of a hazardous substance 

release (§304), a violation of emergency and hazardous chemical inventory 

form requirements (§312), or a violation of toxic chemical release form 

requirements (§313). In addition, there were multiple cases involving a 

violation of permit requirements for treatment, storage, or disposal of 

hazardous waste (RCRA §3005). 

There were three general types of SEPs seen within the pulp and paper 

settlements: 

• Three of the SEPs involve emergency planning and response. In 

each case, the defendants purchased equipment for local emergency 

response authorities. 

• Five SEPs provide a form of pollution reduction. These were 

facility-specific, but generally involved the replacement of equipment 

that is more efficient or less prone to environmental releases. 

• Two SEPs involve pollution prevention. These projects involved 

the installation of technologies that reuse process waste. 

Sector Notebook Project 108 November 2002 
Pulp and Paper Industry Compliance and Enforcement History Table 25: FY-1996-1999 Supplemental Environmental Projects Overview: Pulp and Paper Manufacture Supplemental Environmental Project Information 

SEP Description 

Improve emergency notification to public by purchasing dictaphone and 16-channel recorder Purchase emergency response equipment for Cowlitz County Emergency Responders Project Implement fiber and chemical recovery system 

that reduces fiber and chemical loss from manufacturing process. 

Donate emergency equipment for five counties at a cost of $285,000 and $10,000 for weather web page. Shut down and dismantle wood waste incinerator and install wood-fired boiler with electrified fluidized bed (EF

B) as control 

device. 

Construct containment dams to capture and treat spills entering Willamette River. Capture total reduced sulfur (TRS) gases from pump station for incineration. Remove, replace, and dispose of 2 P

CB 

transformers, 1 PCB-contaminated 

transformer. 

Removal, disposal, and replacement of 1950's PCB transformer at the New Haven Board Mill 

and a non-PCB transformer. 

SEP Category 

$10,720 Emergency 

Planning and Preparedness 

$30,738 Emergency 

Planning and Preparedness 

$31,910 Pollution 

Prevention 

Emergency 

Planning and Preparedness 

$2,200,000 Pollution 

Prevention, Pollution Reduction 

$159,514 Pollution 

Reduction 

$460,000 Pollution 

Reduction 

$44,972 Pollution 

Reduction 

$50,000 Pollution 

Reduction 

Violation Information 

SEP Cost to 

Company 

Assessed 

Penalty 

$2,680 

$8,539 

$2,450 

$400,000 

$359,000 

$5,602 

$200,000 

$6,500 

$13,600 

Type 

EPCRA 312 

EPCRA 

304, 325 

RCRA 3005 

EPCRA 

304, 325 

CAA 165 

EPCRA 313 

CERCLA 103 

CWA 101 CWA 307 EPCRA 304 RCRA 3005 

TSCA 6(e) 

EPCRA 313 

General Information 

State/ 

Region 

AL WA LA WA AK OR NH NY CT 

Company 

Name 

Champion 

International Corporation 

Longview 

Fibre Company 

Nicolaus 

Paper, Inc. 

Weyerhaeuser 

Company 

Ketchikan 

Pulp Company 

Smurfit 

Newsprint Corporation 

Crown Paper 

Co./James River Paper Co. 

Little Rapids 

Corp. 

Simkins 

Industries 

Docket # 

04-1999-0052 

10-1997-0163 

06-1998-0074 

10-1997-0107 

10-94-0197 

10-96-0087 

01-94-0008 

02-95-0165 

01-95-0103 

FY 

1999 1998 1998 1998 1997 1997 1996 1996 1996 

Sector Notebook Project 109 November 2002 
Pulp and Paper Industry Activities and Initiatives 

VIII. COMPLIANCE ACTIVITIES AND INITIATIVES 

This section highlights the activities undertaken by this industry sector and 

public agencies to voluntarily improve the sector's environmental 

performance. These activities include those independently initiated by 

industrial trade associations. In this section, the notebook contains a listing 

and description of national and regional trade associations. 

VIII.A. Sector-Related Environmental Programs and Activities 

National Environmental Performance Track 

EPA's National Environmental Performance Track Program is designed to 

motivate and reward top environmental performance. By encouraging a 

systematic approach to managing environmental responsibilities, taking extra 

steps to reduce and prevent pollution, and being good corporate neighbors, 

the program is rewarding companies that strive for environmental excellence. 

At the same time, many participating companies are finding that they are 

saving money and improving productivity. Five pulp and paper mills are 

participating in the program. (Contact: Performance Track hotline at 888-

339-PTRK or the website at www.epa.gov/performancetrack/.) 

WasteWi$e Program 

The WasteWi$e Program was started in 1994 by EPA’s Office of Solid 

Waste and Emergency Response. The program is aimed at reducing 

municipal solid wastes by promoting waste minimization, recycling 

collection and the manufacturing and purchase of recycled products. As of 

2001, the program had about 1,175 companies as members, including a 

number of major corporations. Members agree to identify and implement 

actions to reduce their solid wastes and must provide EPA with their waste 

reduction goals along with yearly progress reports. EPA in turn provides 

technical assistance to member companies and allows the use of the 

WasteWi$e logo for promotional purposes. Twenty one pulp and paper 

companies are partners. (Contact: Jeff Tumarkin at EPA’s Office of Solid 

Waste and Emergency Response at 703-308-8686 or 

Tumarkin.Jeff@epa.gov, or the WasteWi$e Hotline at 800-EPA-WISE (372-

9473) or www.epa.gov/wastewise.) 

Project XL 

Project XL, which stands for "eXcellence and Leadership," is a national pilot 

program that allows state and local governments, businesses and federal 

facilities to develop with EPA innovative strategies to test better or more 

cost-effective ways of achieving environmental and public health protection. 

In exchange, EPA will issue regulatory, program, policy, or procedural 

Sector Notebook Project 110 November 2002 
Pulp and Paper Industry Activities and Initiatives 

flexibilities to conduct the experiment. Under Project XL private businesses, 

federal facilities, business sectors and state and local governments are 

conducting experiments that address the following eight Project XL selection 

criteria: 

1. produce superior environmental results beyond those that would have 

been achieved under current and reasonably anticipated future 

regulations or policies 

2. produce benefits such as cost savings, paperwork reduction, 

regulatory flexibility or other types of flexibility that serve as an 

incentive to both project sponsors and regulators 

3. supported by stakeholders 

4. achieve innovation/pollution prevention 

5. produce lessons or data that are transferable to other facilities 

6. demonstrate feasibility 

7. establish accountability through agreed upon methods of monitoring, 

reporting, and evaluations 

8. avoid shifting the risk burden, i.e., do not create worker safety or 

environmental justice problems as a result of the experiment. 

By 2002, three pulp and paper companies (Georgia-Pacific, International 

Paper, and Weyerhaeuser) had undertaken projects under Project XL. (For 

more information, contact Adam Levitan in the Office of Reinvention 

Programs at 202-566-1466 or levitan.adam@epa.gov, or the website at 

www.epa.gov/projectxl/.) 

Energy Star 

In 1991, EPA introduced Green Lights®, a program designed for businesses 

and organizations to proactively combat pollution by installing energy 

efficient lighting technologies in their commercial and industrial buildings. 

In April 1995, Green Lights® expanded into Energy Star® Buildings— a 

strategy that optimizes whole-building energy-efficiency opportunities. The 

energy needed to run commercial and industrial buildings in the United 

States produces 19 percent of U.S. carbon dioxide emissions, 12 percent of 

nitrogen oxides, and 25 percent of sulfur dioxide, at a cost of $110 billion a 

year. If implemented in every U.S. commercial and industrial building, the 

Energy Star® Buildings upgrade approach could prevent up to 35 percent of 

the emissions associated with these buildings and cut the nation’s energy bill 

Sector Notebook Project 111 November 2002 
Pulp and Paper Industry Activities and Initiatives 

by up to $25 billion annually. 

The more than 7,000 participants include corporations, small businesses, 

universities, health care facilities, nonprofit organizations, school districts, 

and federal and local governments. Energy Star has successfully delivered 

energy and cost savings across the country, saving businesses, organizations, 

and consumers more than $5 billion a year. Over the past decade, Energy 

Star has been a driving force behind the more widespread use of such 

technological innovations as LED traffic lights, efficient fluorescent lighting, 

power management systems for office equipment, and low standby energy 

use. 

Manufacturers can become partners in Energy Star by pledging to undertake 

the following steps: 

1. Measure, track, and benchmark their organization’s energy 

performance by using tools such as those offered by Energy Star 

2. Develop and implement a plan to improve energy performance in 

their facilities and operations by adopting the strategy provided by 

Energy Star 

3. Educate their staff and the public about our partnership with Energy 

Star, and highlight our achievements with the Energy Star label, 

where available. 

(Contact: Energy Star Hotline, 1-888-STAR-YES (1-888-782-7937) or 

http://www.energystar.gov/default.shtml.) 

NICE3 

The U.S. Department of Energy administers a grant program called The 

National Industrial Competitiveness through Energy, Environment, and 

Economics (NICE3

). By providing grants of up to 50 percent of the total 

project cost, the program encourages industry to reduce industrial waste at 

its source and become more energy-efficient and cost-competitive through 

waste minimization efforts. Grants are used by industry to design, test, 

demonstrate, and assess the feasibility of new processes and/or equipment 

with the potential to reduce pollution and increase energy efficiency. The 

program is open to all industries; however, priority is given to proposals from 

participants in the chemicals, agriculture, aluminum, pulp and paper, glass, 

metal casting, mining, petroleum, and steel industries. (Contact: DOE’s 

Golden Field Office 303-275-4728, or see the website at 

www.oit.doe.gov/nice3.) 

Sector Notebook Project 112 November 2002 
Pulp and Paper Industry Activities and Initiatives 

EPA Audit Policy 

The U.S. Environmental Protection Agency (EPA) encourages companies 

with multiple facilities to take advantage of the Agency's Audit Policy 

(Incentives for Self-Policing: Discovery, Disclosure, Correction and 

Prevention of Violations, 65 Fed. Reg. 19618 (April 11, 2000) ) to conduct 

audits and develop environmental compliance systems. The Audit Policy 

eliminates gravity-based penalties for companies that voluntarily discover, 

promptly disclose and expeditiously correct violations of federal 

environmental law. More information on EPA’s Audit Policy can be obtained 

from the Web site at: http://www.epa.gov/compliance/resources/policies/ 

incentives/ auditing/index.html. 

Small Business Compliance Policy 

The Small Business Compliance Policy promotes environmental compliance 

among small businesses (those with 100 or fewer employees) by providing 

incentives to discover and correct environmental problems. EPA will 

eliminate or significantly reduce penalties for small businesses that 

voluntarily discover violations of environmental law and promptly disclose 

and correct them. A wide range of resources are available to help small 

businesses learn about environmental compliance and take advantage of the 

Small Business Compliance Policy. These resources include: training, 

checklists, compliance guides, mentoring programs, and other activities. 

Businesses can find more information through links on the Web site: 

http://www.epa.gov/smallbusiness/. 

Compliance Assistance Clearinghouse 

The National Environmental Compliance Assistance Clearinghouse is a 

Web-based clearinghouse designed to provide quick access to compliance 

assistance tools, contacts, and planned activities across EPA and other 

compliance assistance providers. The Clearinghouse also serves as a forum 

to collaborate and exchange information. The Clearinghouse provides links 

to compliance assistance activities, tools, or technical assistance that: 1) 

assist the regulated community in understanding and complying with 

environmental regulations; or 2) assist compliance assistance providers in 

helping the regulated community to comply with environmental regulations. 

The Clearinghouse Web site is http://www.epa.gov/clearinghouse/. 

Sector Notebook Project 113 November 2002 
Pulp and Paper Industry Activities and Initiatives 

VIII.B. Trade Association/Industry Sponsored Activities 

VIII.B.1. 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 2001, GEMI’s 

membership consisted of about 40 major corporations including the pulp and 

paper company Georgia-Pacific. (Contact: GEMI at 202-296-7449 or see the 

website at: www.gemi.org.) 

ISO 14000 

ISO 14000 is a series of internationally-accepted standards for environmental 

management. The series includes standards for environmental management 

systems (EMS), guidelines on conducting EMS audits, standards for auditor 

qualifications, and standards and guidance for conducting product lifecycle 

analysis. Standards for auditing and EMS were adopted in September 1996, 

while other elements of the ISO 14000 series are currently in draft form. 

While regulations and levels of environmental control vary from country to 

country, ISO 14000 attempts to provide a common standard for 

environmental management. The governing body for ISO 14000 is the 

International Organization for Standardization (ISO), a worldwide federation 

of over 110 country members based in Geneva, Switzerland. The American 

National Standards Institute (ANSI) is the United States representative to 

ISO. Information on ISO is available at the following Internet site: 

http://www.iso.ch/iso/en/ISOOnline.openerpage. 

50 Percent Paper Recovery Goal 

At the beginning of this decade, the U.S. paper industry made an 

unprecedented public commitment to expand paper recovery and recycling 

by establishing a goal to recover 40 percent of all the paper Americans used 

in 1995. That program involved a wide array of tools to encourage efficient 

paper recovery as well as a major financial commitment by U.S. papermakers 

to expand recycling capacity at their mills. The public-private partnership 

that evolved proved enormously successful: the industry's goal was achieved 

a year ahead of schedule. 

Given the success of this initiative, the industry, through its trade association, 

the American Forest & Paper Association, established a new goal to recover 

50 percent of all the paper Americans use and to continue its work to 

Sector Notebook Project 114 November 2002 
Pulp and Paper Industry Activities and Initiatives 

promote efficient paper recovery programs. By 2000, the U.S. paper recovery 

rate was 48 percent. (Contact: AF&PA at 202-463-2700 or see the website 

at www.afandpa.org.) 

100% Recycled Paperboard Alliance 

The 100% Recycled Paperboard Alliance (RPA-100%) is a group of leading 

North American recycled paperboard manufacturers representing nearly twothirds of the recycled paperboard industry, and a sponsor of America 

Recycles Day. 

RPA-100% encourages packaged goods and companies to use 100% recycled 

paperboard and educates consumers about the importance of buying recycled. 

Almost fifty companies have joined a new intiative from the 100% Recycled 

Paperboard Alliance, displaying the "100% Recycled Paperboard" symbol on 

their brand name and private label products. (Contact: 100% Recycled 

Paperboard Alliance at 877-772-6200 or see the website at 

www.rpa100.com.) 

Agenda 2020 

In 1994, the American Forest and Paper Association joined with the U.S. 

Department of Energy to launch Agenda 2020, an innovative, collaborative 

research program. Through Agenda 2020, a consortium of research 

institutions, industry, and national laboratories is developing new 

technologies, processes and measurements to manufacture products more 

efficiently and cost-effectively while reducing environmental impacts of 

operations and maximizing the efficient use and reuse of resources. 

To meet these objectives, Agenda 2020 has identified six technology focus 

areas for collaborative research efforts. These six task groups represent a 

broad cross section of the forest products industry: 

1. Sustainable Forest Management 

2. Environmental Performance 

3. Energy Performance 

4. Improved Capital Effectiveness 

5. Recycling 

6. Sensors and Controls 

Particularly noteworthy is the effort within the Agenda 2020 partnership to 

develop biomass gasification technologies. If fully commercialized, these 

technologies could make the U.S. forest products industry totally energy selfreliant and generate a surplus of 22 gigawatts of power to the grid—the 

equivalent of one-half of California’s peak summertime electric use. The 

carbon displacement from biomass gasification could be even more dramatic, 

Sector Notebook Project 115 November 2002 
Pulp and Paper Industry Activities and Initiatives 

transforming the industry from emitting 24 million tons of carbon each year 

to displacing at least 18 million tons of greenhouse gas from fossil fuels – 

before taking into consideration the carbon sequestration benefits of forests. 

Black liquor (see Section III for a description) is one biomass fuel created 

during the chemical pulping process. Gasification converts these pulping 

extractives and other forms of biomass into combustible gases that can be 

efficiently burned like natural gas. If fully commercialized, these 

technologies could produce enormous energy and environmental benefits. 

The first commercial-scale biomass (black liquor) plant is being built by 

Georgia-Pacific Corp. in Big Island, VA. It is slated to go on-line in 2003. 

Other commercialization tests will continue over the next 10 years, if 

adequately funded. Industry participants are putting up 50 percent of the 

investment capital for these demonstration projects. (Contact: AF&PA at 

202-463-2700 or see the website at www.agenda2020.org.) 

VIII.B.2. Summary of Trade Associations 

The trade and professional organizations serving the pulp and paper industry

are lead by the American Forest and Paper Association (AFPA), formerly the

American Paper Institute (API). They have been actively involved in a

number of recent rulemakings (under CAA, CWA and RCRA) that will affect

their members. The National Council of the Paper Industry for Air and

Stream Improvement (NCASI) does technical research for the industry. The

Technical Association of the Pulp and Paper Industry (TAPPI), is a technical

clearinghouse for the industry; they disseminate technical information to

production facility staff throughout the U.S.

American Forest and Paper Association

1111 19th Street, NW Members: 450 

Suite 800 Staff: 140

Washington, DC 20036 Contact: Josephine Cooper,

Phone: 202-463-2700 V.P. for Environment and

Fax: 202-463-2471 Regulatory Affairs

Internet:

www.afandpa.org 

The National Forest Products Association merged with the American Paper 

Institute (API) in 1993 to become the American Forest and Paper Association 

(AF&PA). AF&PA is the national trade association for the forest, pulp, 

paper, paperboard, and wood products industry. The organization focuses on 

information gathering/dissemination, research on industry technical issues, 

and represents the industry in regulatory and legislative matters. The 

AF&PA takes an active role by representing its members before 

Sector Notebook Project 116 November 2002 
Pulp and Paper Industry Activities and Initiatives 

governmental agencies, such as on the recent integrated air and water rule.

Some current environmental initiatives include the 2020 Research Agenda,

50 percent recycling goal, and the Sustainable Forestry Initiative. The

AF&PA publishes a variety of documents for and about its membership.

Some relevant publications include the annual industry wide reviews

Capacity Report and Statistics of Paper, Paperboard, and Wood Pulp, the

Paper, Paperboard, and Wood Pulp Monthly Statistical Summary, and the

Dictionary of Paper, published every ten years. Circulation for these

publications is listed at 1,000. The AF&PA holds an annual meeting every

March in New York City. 

National Council of the Paper Industry for Air and Stream Improvement

P.O. Box 13318 Members: 78

Research Triangle Park, NC 27709 Staff: 90

Phone: 919-558-1999 Budget: $10,000,000

Fax: 919-558-1998 Contact: Dr. Ronald Yeske

Internet: www.ncasi.org

Founded in 1943, the National Council of the Paper Industry for Air and 

Stream Improvement (NCASI) presently conducts research on environmental 

problems related to industrial forestry and the manufacture of pulp, paper, 

and wood products. NCASI produces technical documents on environmental 

issues facing the pulp and paper industry and conducts industry conferences. 

Publications include: a biweekly bulletin on general issues and a variety of 

technical bulletins (40/year). NCASI also holds an annual March convention 

in New York City. 

Technical Association of the Pulp and Paper Industry (TAPPI) 

Technology Park/Atlanta 

P.O. Box 105113 

Atlanta, GA 30348 

Phone:770-446-1400 

Fax: 770-446-6947 

Internet: www.tappi.org 

Members: 33,000

Staff: 95

Budget: $13,000,000

Contact: Charles Bohanan

Technical Divisions Operator

The Technical Association of the Pulp and Paper Industry (TAPPI) 

represents executives, managers, engineers, research scientists, 

superintendents, and technologists in the pulp, packaging, paper, and allied 

industries. Founded in 1915, TAPPI is split into eleven divisions, which 

include: environmental, research and development, paper and board 

manufacture, and pulp manufacture. Though its headquarters are in Atlanta, 

TAPPI is also divided into 27 regional groups. Overall, TAPPI provides a 

variety of services to its members. TAPPI conducts conferences on topics 

such as forest biology, environment, packaging, pulp manufacture, and R&D 

Sector Notebook Project 117 November 2002 
Pulp and Paper Industry Activities and Initiatives 

in addition to a more general annual conference. TAPPI also develops

testing methodologies for process control and laboratory analysis. The main

annual project of the TAPPI Environmental division consists of an

environmental issues industry conference. In 1995, TAPPI launched a

campaign to educate the public on industry environmental facts. TAPPI

publications include an annual Membership Directory, a monthly TAPPI

Journal, and the publication of research results. TAPPI's publications are

available via an online catalogue and record retrieval system called TAPPInet available at 800-332-8686. 

Paper Industry Management Association

1699 Wall Street, Suite 212 Members: 5,000

Mount Prospect, IL 60056 Staff: 14

Phone: 847-956-0250 Budget: $2,000,000

Fax: 847-956-0520 Contact: Scott Baumruck, Chief

Internet: www.pima-online.org Operating Officer

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. 

Sector Notebook Project 118 November 2002 
Pulp and Paper Industry Contacts and References 

IX. CONTACTS/ACKNOWLEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY 

For further information on selected topics within the pulp and paper industry 

a list of publications and contacts are provided below: 

Contacts4 

Name Organization Telephone/Email Subject 

Scott Throwe U.S. EPA, Office of 

Compliance 

202-564-7013 

throwe.scott@epa.gov 

Pulp and paper industry 

sector lead 

Steve Shedd U.S. EPA, Office of Air 

and Radiation 

919-541-5397 

shedd.steve@epa.gov 

Combustion MACT 

NESHAP Subpart S 

Jeff Telander U.S. EPA, Office of Air 

and Radiation 

919-541-5427 

telander.jeff@epa.gov 

Non-combustion MACT 

NESHAP Subpart MM 

Don Anderson U.S. EPA, Office of 

Water 

202-260-7189 

anderson.donald@epa.gov 

Effluent guidelines and 

standards 

Deborah Nagle U.S. EPA, Office of 

Water 

202-260-2656 

nagle.deborah 

Cooling water intake 

standards 

Tim Smith Office of Air and 

Radiation 

919-541-4718 

smith.tim@epa.gov 

Guidelines on Best 

Available Retofit 

Technology (BART) 

Kevin Culligan Office of Air and 

Radiation 

202-564-9172 

culligan.kevin@epa.gov 

NOx SIP Call 

Dickson Ozokwelu U.S. Department of 

Energy, Office of 

Industrial Technology 

202-586-8501 

dickson.ozokwelu@ee.doe.gov 

Technologies and 

processes with the 

potential for energy, 

environmental, and cost 

savings 

James Bond USDA Forest Service 608-231-9480 

jbond@fs.fed.us 

Research on 

environmentally benign 

and resource-conserving 

processes for the 

production and utilization 

of wood pulp fibers and 

chemical byproducts 

4 Many of the contacts listed above have provided valuable background information and comments during the 

development of this document. EPA appreciates this support and acknowledges that the individuals listed do not 

necessarily endorse all statements made within this notebook. 

Sector Notebook Project 119 November 2002 
Pulp and Paper Industry Contacts and References 

General Profile 

AF&PA, 1999. 1999 Statistics: Data Through 1998. American Forest & Paper Association. 

McLaren, J et al., 2000. “North American Status Report,” Pulp & Paper. August. 

Pulp & Paper Magazine, 2001. “PaperHelp Online.” 

http://www.paperloop.com/pp_mag/paperhelp/homepage.shtml. 

U.S. Census Bureau, 1998. 1997 County Business Patterns for the United States. 

U.S. Census Bureau, 2000a. 1997 Economic Census: Bridge Between NAICS and SIC. 

U.S. Census Bureau, 2000b. 1997 Economic Census: Comparative Statistics for United States 

(1987 SIC Basis). 

U.S. Department of Commerce/International Trade Administration, 2000. U.S. Industry & Trade 

Outlook 2000. U.S. Department of Commerce, McGraw-Hill. 

U.S. Department of Energy, 2000. “Forest Products Project Fact Sheet: Closed-Cycle Bleach 

Kraft Pulp Production.” Office of Industrial Technologies. October. 

U.S. Environmental Protection Agency, 1993. Development Document for Proposed Effluent 

Limitations Guidelines and Standards for the Pulp, Paper, and Paperboard Point Source 

Category. October. 

U.S. Environmental Protection Agency, 1999. Toxics Release Inventory Database. 

Process Descriptions and Chemical Use Profiles 

AF&PA, 1994. 1994 Statistics, Data Through 1993. Washington, D.C.: American Forest and 

Paper Association. 

AF&PA, 1995a. Improving Tomorrow’s Environment Today. January. 

Sector Notebook Project 120 November 2002 
Pulp and Paper Industry Contacts and References 

AF&PA, 1995b. Personal communication. 

AF&PA, 1995c. Recovered Paper Deinking Facilities. American Forest and Paper Association: 

Economics and Materials Department. January. 

AF&PA, 2000a. Paper Recovery Progress Report. May. 

AF&PA, 2000b. 2000 Recovered Paper Statistical Highlights. 

http://www.afandpa.org/recycling/Rec_introduction.html. 

AF&PA, 2000c. Paper Recycling Facts. 

http://www.afandpa.org/recycling/Rec_paperrecfacts_open.html. 

AF&PA, 2002. Written comments from Richard Wasserstrom to Seth Heminway, EPA Office 

of Compliance. March 7. 

Richard J. Albert, "Effluent-Free Pulp Mill Possible with Existing Fiberline Equipment," Pulp & 

Paper, 68(7), July 1994, pp. 83-89. 

Alliance for Environmental Technology, 2001. “Trends in World Bleached Chemical Pulp 

Production: 1990-2000.” January. 

http://www.aet.org/reports/market/aet_trends_2000.html. 

American Paper Institute. Report on the Use of Pulping and Bleaching Chemicals in the U.S. 

P&P Industry, June 26, 1992. 

Lee Brunner and Terry Pulliam, "Comprehensive Impact Analysis of Future Environmentally 

Driven Pulping and Bleaching Technologies," 1992 TAPPI Pulping Conference, 

Boston, MA. 

David Forbes, "Mills Prepare for Next Century with New Pulping, Bleaching Technologies," 

Pulp & Paper, Sept. '92. 

Pulp and Paper Magazine, 2001. PaperHelp Online Encyclopedia, 

http://www.paperloop.com/pp_mag/paperhelp. 

Sector Notebook Project 121 November 2002 
Pulp and Paper Industry Contacts and References 

Smook, G.A., 1992. Handbook for Pulp & Paper Technologists. Second edition. Vancouver: 

Angus Wilde Publications. 

U.S. Department of Commerce, 2000. U.S. Industry & Trade Outlook 2000, McGraw-Hill 

Companies and U.S. Department of Commerce/International Trade Administration. 

U.S. EPA, 1988. 104-Mill Study. 

U.S. EPA, 1990. Summary of Technologies for the Control and Reduction of Chlorinated 

Organics from the Bleached Chemical Pulping Subcategories of the Pulp and Paper 

Industry. 

U.S. EPA, 1990. 1990 National Census of Pulp, Paper, and Paperboard Manufacturing 

Facilities. 

U.S. EPA, 1993a. Development Document for Proposed Effluent Limitations Guidelines and 

Standards for the Pulp, Paper, and Paperboard Point Source Category. October. 

U.S. EPA, 1993b. Pollution Prevention Technologies for the Bleached Kraft Segment of the U.S. 

Pulp and Paper Industry. 

U.S. EPA, 1993c. Pulp, Paper and Paperboard Industry - Background Information for 

Proposed Air Emission Standards: Manufacturing Processes at Kraft, Sulfite, Soda, and 

Semi-Chemical Mills (NESHAP). 

U.S. EPA, 1995. Office of Water, Personal communication. June. 

U.S. EPA, 2002. Personal communication from Jacquelyn Vega, National Enforcement 

Investigations Center, to Seth Heminway, Office of Compliance. March 1. 

VDP, 1997. Papier ‘97 - Ein Leistungsbericht. Verband Deutscher Papierfabriken: Bonn, 

Germany. 

Chemical Releases and Transfers 

Air & Waste Management Association, 1992. Air Pollution Engineering Manual. 

Sector Notebook Project 122 November 2002 
Pulp and Paper Industry Contacts and References 

U.S. EPA, 2001a. AIRS Database. Office of Air and Radiation. November. 

U.S. EPA, 2001b. Toxics Release Inventory Database. 

Pollution Prevention 

Chlorine-Free Bleaching of Kraft Pulp: Feasibility Study, sponsored by Domtar Inc., the Ontario 

Ministry of the Environment, and Environment Canada, June 1993. Available from 

Great Lakes Pollution Prevention Centre 519-337-3423. 

Howard Deal, "Environmental Pressure Causes Changes in Bleaching Technologies, 

Chemicals," Pulp & Paper, Nov. '91. 

Bruce Fleming, Alternative and Emerging Non-Kraft Pulping Technologies, EPA-744R-93-002. 

Neil McCubbin, Costs and Benefits of Various Pollution Prevention Technologies in the Kraft 

Pulp Industry, EPA-744R-93-002. 

NCASI Technical Workshop-- Effects of Alternative Pulping and Bleaching Processes on 

Production and Biotreatability of Chlorinated Organics, NCASI Special Report No. 94-

01, Feb. 1994. 

U.S. EPA, 1993. Pollution Prevention Technologies for the Bleached Kraft Segment of the U.S. 

Pulp and Paper Industry, EPA/600/R-93/110 

Regulatory Profile 

U.S. EPA, 1997. Fact Sheet: EPA’s Final Pulp, Paper, and Paperboard “Cluster Rule” – 

Overview. November. 

U.S. EPA, 1998. Pulp and Paper NESHAP: A Plain English Description. November. 

U.S. EPA, 1999a. Kraft Pulp Mill Compliance Assessment Guide. May. 

Sector Notebook Project 123 November 2002 
Pulp and Paper Industry Contacts and References 

U.S. EPA, 1999b. Questions and Answers for the Pulp and Paper NESHAP. September. 

U.S. Government Printing Office, 2001a. Unified Agenda. Volume 66, Number 93, Pages 

26264-26265. 

U.S. Government Printing Office, 2001b. Unified Agenda. Volume 66, Number 93, Pages 

26269-26270. 

Sector Notebook Project 124 November 2002 
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