Pulp and Paper Industry S ector Notebook Project

EPA/310-R-02-002

EPA Office of Compliance Sector Notebook Project


## Profile of the Pulp and Paper Industry 2 nd 

## Edition

Novem b er 2002

Office of Com p liance Office of Enforcem ent and Com p liance Assurance U.S. Environm ental Protection Agency 1200 Pennsylvania Avenue, NW (MC 2224-A) W a shington, DC 20460Pulp and Paper Industry S ector Notebook Project
This report is one in a series of volum es published by the U.S. Environme n tal Protection Agency (EPA) to provide infor m a t i on of general interest regarding environm ental issues associated with specific i ndustrial sectors. The docum ents were developed under contract by Abt Associates (Cam bridge, MA), GeoLogics Corporation (Alexa ndria, VA), Sci e nce Applications International Corporation (McLean, VA), and Booz-Allen & Ham ilt on, 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 we bsite at: www.epa.gov/com p liance/resources/publications/assistance/sectors/notebooks/.

Purchase pr i n t e d bound copies from the Government Printing Office (GPO) by consulting the order form at the back of this docum ent or orde r vi a the Internet by visiting the U.S. Governm e nt O n line B ookstore at: http://booksto re.gpo.gov/. Search using the exact title of the docum ent “Prof ile of the XXXX Industry” or sim p ly “Sector Notebook. ” W h en ordering, use the GPO docum ent

num ber found in the order form at the back of this docum ent.

A lim ited num ber of complimentary volumes are available to certain groups or s u bscribers, including public and academ ic libraries; federal, stat e, tribal, and local governm e nts; and the m e dia f r om EPA’s National Service Center for Environm ental Publications at 800-490-9198 or www.epa.gov/ncepihom

. W h en ordering, use the EPA pub lication num ber found on the following
page.

The Sector Notebooks were developed by the EP A’s Office of Com p liance. Di r ect general questions about the Sector Notebook Project to:

Coordinator, Sector Notebook Project US EPA Office of Com p liance 1200 Pennsylvania Ave., NW (2224-A) W a shington, DC 20460 202-564-2310

For further inform ation, and for answers to questi ons pertaining to these docum ents, please refer to the contacts listed on the following page.

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## A VAILABLE 

## S ECTOR 

## N OTEBOOKS

Questions and com m e nts regarding the individual docum ents should be directed to Com p liance Assistance and Sector Program s Division at 202 564-2310 unless otherwise noted below. See the Notebook web page at: http://www.epa.gov/compliance/resources/publicatio ns/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 Elect ronics and Com puter Industry* EPA/310-R-95-003. Profile of the W ood Furniture and Fixtures Industry EPA/310-R-95-004. Profile of the Inorganic Chem ical Industry* EPA/310-R-95-005. Profile of the Iron and Steel Industry EPA/310-R-95-006. Profile of the Lum b er and W ood Products Industry EPA/310-R-95-007. Profile of the Fabr icated Metal Products Industry* EPA/310-R-95-008. Profile of the Metal Mining Industry EPA/310-R-95-009. Profile of the Motor Vehicle Assem b ly 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 Or ganic Chem ical Industry, 2 nd 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, 2 nd 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 Tran sportation Equipm ent 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 W a ter Transportation Industry EPA/310-R-97-004. Profile of the Metal Casting Industry EPA/310-R-97-005. Profile of th e Pharm aceuticals Industry EPA/310-R-97-006. Profile of the Plastic Resin and Man-m a de 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 Ch em ical, 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 Governm e nt Operations

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

** This docum ent revises com p liance, enforcem ent, and t oxic release inventory data for a l l p r eviously published profiles. Visit the Sector Notebook web page to access the m o st current data.

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# DISCLAIMER

This Sector Notebook was created for em ployees of the U.S. Envi r onmental Protection Agency (EPA) and the general public for inform ational pur poses only. This docum ent has been extensively reviewed by experts from both inside and outside th e EPA, but its contents do not necessarily reflect the views or policies of EPA or any other organi zation m e ntioned within. Mention of trade nam e s

or com m e rcial products or events does not constitu te endorsem e nt or recom m e ndation for use. In addition, these docum ents are not intended and cannot be r e l i e d upon to create any rights, substantive or procedural, enforceable by any party in litigation with the United States.

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### Pulp and Paper Industry (SIC 2611 through 2631)

TABLE OF CONTENTS

LIST OF ACRONYMS

....................................................... v i i i

I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT .......................1 A. Sum m a ry of the Sector Notebook Project ..................................1 B

. A d d i t i o n a l I n f o r m a t i o n .................................................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. Econom ic Trends ..............................................1 1

III. INDUSTRIAL PROCESS DESCRIPTION .....................................1 5 A. Industrial Processes in the Pulp and Paper Industry .........................1 5 1

. P u l p M a n u f a c t u r e ..............................................1 8 2

. P u l p P r o c e s s i n g ................................................2 5 3. Bleaching ....................................................3 0 4

. S t o c k P r e p a r a t i o n ..............................................3 3 5

. P r o c e s s e s i n P a p e r M a n u f a c t u r e ...................................3 3 6

. E n e r g y G e n e r a t i o n .............................................3 4 B. Raw Material Inputs and Pollution Outputs in the Production Line .............3 5

IV. CHEMICAL RELEASE AND OTHER W A STE MANAGEMENT PROFILE .........4 5 A. EPA Toxics Release Inventory For the Pulp and Paper Industry ...............4 8 B

. S u m m a r y o f S e l e c t e d C h e m i c a l s R e l e a s e d ................................5 4 C

. O t h e r D a t a S o u r c e s ..................................................5 7 D. Com p arison of Toxic Release Inventory Between Selected Industries ...........5 9

V

. P O L L U T I O N P R E V E N T I O N O P P O R T U N I T I E S ................................6 2

VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS ...................6 8 A

. G e n e r a l D e s c r i p t i o n o f M a j o r S t a t u t e s ...................................6 8 B. Industry Specific Requirem e nts .........................................8 5 C. Pending and Proposed Regulatory Requirem e nts ...........................9 3

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VII. COMPLIANCE AND ENFORCEMENT HISTORY .............................9 5 A. Pulp and Paper Industry Com p liance History ..............................9 9 B. Com p arison of Enforcem ent Activity Between Selected Industries ............1 0 1 C

. R e v i e w o f M a j o r L e g a l A c t i o n s ........................................1 0 6 1

. R e v i e w o f M a j o r C a s e s .........................................1 0 6 2. Supplem entary Environm ental Projects ............................1 0 8

VIII. COMPLIANCE ACTIVITIES AND INITIATIVES ...........................1 1 0 A. Sector-Related Environm ental Program s and Activities .....................1 1 0 B. Trade Association/Industry Sponsored Activities ..........................1 1 4 1

. E n v i r o n m e n t a l P r o g r a m s .......................................1 1 4 2

. S u m m a r y o f T r a d e A s s o c i a t i o n s ..................................1 1 6

IX. CONTACTS/ACKNOW LEDGMENTS/RESOURCE MATERIALS/BIBLIOGRAPHY 119

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### LIST OF FIGURES

Figure 1: Pulp Production, 2000 ..................................................8 Figure 2: Em ploym ent and Value of Shipm e nts in the Paper and Allied Products Industry ...1 0 Figure 3: Geographic Distribution of Pulp, Paper, and Paperboard Mills ..................1 0 Figure 4: Capital Im provem e nts at Pulp and Paper Mills ..............................1 3 F i g u r e 5 : P a p e r R e c o v e r y R a t e s ..................................................1 4 F i g u r e 6 : S i m p l i f i e d F l o w D i a g r a m : I n t e g r a t e d M i l l ..................................1 7 F i g u r e 7 : K r a f t P u l p i n g P r o c e s s ( w i t h C h e m i c a l R e c o v e r y ) ............................2 9 Figure 8: Typical Bleach Plant ..................................................3 2 F i g u r e 9 : F o u r d r i n i e r P a p e r M a c h i n e ..............................................3 4 F i g u r e 1 0 : K r a f t P r o c e s s F l o w D i a g r a m ...........................................4 3 F i g u r e 1 1 : A i r P o l l u t a n t O u t p u t f r o m K r a f t P r o c e s s ..................................4 4 Figure 12: 2000 Sum m a ry of TRI Releases and Transfers by Industry ...................6 0



### LIST OF TABLES

T a b l e 1 : S I C a n d N A I C S C o d e s ..................................................5 T a b l e 2 : D e s c r i p t i o n o f P u l p i n g P r o c e s s e s ..........................................6 Table 3: Size of Paper and Allied Products Facilities ..................................9 T a b l e 4 : M a j o r P u l p a n d P a p e r M e r g e r s a n d A c q u i s i t i o n s .............................1 2 Table 5: General Classification of W ood Pulping Processes ...........................1 8 T a b l e 6 : P u l p M a n u f a c t u r i n g P r o c e s s S e q u e n c e .....................................1 9 Table 7: Relative W a stepaper Usage as Secondary Fiber in 1999 .......................2 1 Table 8: Com m on Chem icals Used in Elem ental Chlorine Free (ECF) and Total Chlorine Free (TCF) Bleaching Processes ...............................................3 1 T a b l e 9 : P a p e r a n d P a p e r b o a r d M a k i n g P r o c e s s .....................................3 3 Table 10: Estim ated Energy Sources for the U.S. Pulp and Paper Industry ................3 5 T a b l e 1 1 : P o t e n t i a l W a t e r P o l l u t a n t s F r o m P u l p a n d P a p e r P r o c e s s e s ....................3 7 T a b l e 1 2 : C o m m o n A i r P o l l u t a n t s F r o m P u l p a n d P a p e r P r o c e s s e s ......................3 8 Table 13: Kraft Chem ical Pulped Bleached Paper Production ..........................4 1 Table 14: 2000 TRI Releases for Pulp and Paper Facilities ............................5 0 Table 15: 2000 TRI Transfers for Pulp and Paper Facilities ............................5 2 Table 16: Ten Largest Volum e TRI Releasing Facilities in the Pulp and Paper Industry ......5 4 Table 17: Air Pollutant Releases by Industry Sector (tons/year) ........................5 8 Table 18: Toxics Release Inventory Data for Selected Industries ........................6 1 Table 19: Applicability of Clean W a ter Act Requirem e nts .............................8 9 Table 20: Five-Year Enforcem ent and Com p liance Sum m a ry for the Pulp and Paper Industry, b y R e g i o n ......................................................1 0 0 Table 21: Five-Year Enforcem ent and Com p liance Sum m a ry for Selected Industries ......1 0 2 Table 22: Two-Year Enforcem ent and Com p liance Sum m a ry for Selected Industries .......1 0 3 Table 23: Five-Year Inspection and Enforcem en t Sum m a ry by Statute for Selected Industries 104 Table 24: Two-Year Inspection and Enforcem ent Sum m a ry by Statute for Selected Industries 105 Table 25: FY-1996-1999 Supplem ental Environm ental Projects Overview ...............1 0 9

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### LIST OF ACRONYMS

AFS A IRS Facility Subsystem (CAA database) AIRS Aerom e tric Inf o rm ation Retrieval System (CAA database) AOR Area of Review (SDW A) AOX Adsorbable Organic Halides BAT B est Available Technology Econom ically Achievable BCT Best Conventional Pollutant Control Technology BIFs Boilers and Industrial Furnaces (RCRA) BMP B est Managem e nt Practice BOD B iochem ical Oxygen Dem a nd BPT B est Practicable Technology Currently Available CAA C lean Air Act CAAA Clean Air Act Am endm ents of 1990 CERCLA C om prehensive Environm ental Response, Com p ensation and Liability Act CERCLIS CERCLA Inform ation System CFCs Chlorofluorocarbons CFR C ode of Federal Regulations CGP C onstruction General Perm it (CW A ) CO Carbon Monoxide CO 2 Carbon Dioxide COD C hem i cal Oxygen Dem a nd CSI C om m on Sense Initiative CW A C lean W a ter Act CZMA Coastal Zone Managem e nt Act D&B D un and Bradstreet Marketing Index DOC United States Departm e nt of Com m e rce EIS E nvironm ental Im pact Statem ent EPA U nited States Environm ental Protection Agency EPCRA Em ergency Planning and Com m unity Right-to-Know Act ESA E ndangered Species Act FIFRA F ederal Insecticide, Fungicide, and Rodenticide Act FINDS Facility Indexing System FR Federal Register FRP F acility Response Plan HAPs H azardous Air Pollutants (CAA) HSDB Hazardous Substances Data Bank HSW A Hazardous and Solid W a ste Am endm ents IDEA Integrated Data for Enforcem ent Analysis LDR L and Disposal Restrictions (RCRA) LEPCs Local Em ergency Planning Com m ittees MACT Maxim u m Achievable Control Technology (CAA) MCLGs M axim um Contam inant Level Goals MCLs Maxim u m Contam inant Levels MEK M ethyl Ethyl Ketone MSDSs M aterial Saf e ty Data Sheets

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MSGP Multi-Sector General Perm it (CW A ) NAAQS National Am bient Air Quality Standards (CAA) NAFTA North Am erican Free Trade Agreem ent NAICS North Am erical Industr ial Classification System NCDB National Com p liance Database (for TSCA, FIFRA, EPCRA) NCP N ational Oil and Hazardous Substances Pollution Contingency Plan NEC N ot Elsewhere Classified NEIC National Enforcem ent Investigation Center NEPA National Environm ental Policy Act NESHAP National Em ission Standards for Hazardous Air Pollutants NICE 3 National Industrial Com p etitiveness Through Energy, Environm ent and Econom ics NO 2 Nitrogen Dioxide NOI Notice of Intent NOT Notice of Term ination NOV Notice of Violation NO

x Nitrogen Oxides NPDES N ational Pollution Discharge Elim ination System (CW A ) NPL N ational Priorities List NRC N ational Response Center NSPS New Source Perform a nce Standards (CAA) OAQPS O ffice of Air Quality Planning and Standards OAR Office of Air and Radiation OECA Office of Enforcem ent and Com p liance Assurance OMB O ffice of Managem e nt and Budget OPA O il Pollution Act OPPTS O ffice of Prevention, Pesticides, and Toxic Substances OSHA Occupational Safety and Health Adm i nistration OSW O ffice of Solid W a ste OSW E R O ffice of Solid W a ste and Em ergency Response OW Office of W a ter P2 Pollution Prevention PCS P erm it Com p liance System (CW A Database) PM10 Particulate Matter of 10 m i crons or less PMN P rem a nufacture Notice POTW Publicly Owned Treatm e nts W o rks PSD Prevention of Significant Deterioration (CAA) PT Total Particulates RCRA Resource Conservation and Recovery Act RCRIS RCRA Inform ation System RQ Reportable Quantity (CERCLA) SARA Superfund Am endm ents and Reauthorization Act SDW A Safe Drinking W a ter Act SEPs Supplem entary Environm ental Projects SERCs State Em ergency Response Com m i ssions SIC S tandard Industrial Classification SIP S tate Im plem entation Plan

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SO 2 Sulfur Dioxide SO

x Sulf ur Oxides SPCC S pill Prevention Control and Counterm easures STEP Strategies for Today’s Environm ental Partnership SW PPP Storm W a ter Pollution Prevention Plan (CW A ) TOC T otal Organic Carbon TRI T oxic Release Inventory TRIS Toxic Release Inventory System TCRIS T oxic Chem ical Release Inventory System TSCA Toxic Substances Control Act TSD T reatm e nt Storage and Disposal TSP T otal Suspended Particulates TSS T otal Suspended Solids UIC U nderground Injection Control (SDW A) USDW Underground Sources of Drinking W a ter (SDW A) UST U nderground Storage Tanks (RCRA) VOCs V olatile Organic Com pounds

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I. INTRODUCTION TO THE SECTOR NOTEBOOK PROJECT

I.A. Summary of the Sector Notebook Project

Environm ental policies based upon com p rehe nsive analysis of air, water and land pollution (such as econom ic sector, and com m unity-based approaches) are an im portant supplem ent to traditional single-m e dia approaches t o environm ental protection. Environm en tal regulatory agencies are beginning
to em brace com p rehensive, m u lti-statute solutions to facility perm itting,

com p liance assurance, education/outre a c h, research, and regulatory developm ent issues. The central concepts driving the new policy direction are that pollutant releases to each environm ental m e dium (air, water and land) affect each other, and that environm ental strat e gies m u st actively identify and address these interrelationships by de s i gni ng policies for the "w hole" f acility. O n e w a y to achieve a w hole f ac ility f o cus is to design envi r onmental policies for sim ilar industrial facilities. By doing so,

e nvi r onm ental concerns that are com m on to the m a nufacturing of sim ilar products can be addressed in a com p re hensive m a nner. Recognition of the need to develop the industrial 

### ? sector-based” appro ach w ith in th e E P A O f fice of Com p liance led to the creation of this docum ent.

The Sector Notebook Project was initiated by t h e Office of Com p liance within the Of f i ce of Enf o rcem ent and Com p liance Assurance (OECA) to provide its staff and m a nagers with s u mmary inform ation for eighteen specific industrial sectors. As other EPA offices, states, the regulated

com m unity, environm ental groups, and th e public becam e interested in this project, the scope of the original project was expanded. The ability to design

com p rehensive, com m on sense environm ental pr otection m e asures for specific industries is dependent on knowle dge of several interrelated topics. For the purposes of this proj e c t , t h e key elem ents chosen for inclusion are:
ge neral industry inform ation (econom ic and geographic); a description of industrial processes; pollution outputs; pollution prevention opportunities; federal statutory and regulatory fram ework; com p liance history; and a description of partnerships that have been form ed bet w e e n r e gulatory agencies, the regulated com m unity and the public.

For any given industry, each topic listed above could alone be the subject of a lengthy volum e. However, in order to produce a m a nageable docum ent, this project focuses on providing sum m a ry inform ation for each topic. This form at pr ovi de s the reader with a s ynopsis of each issue, and references where m o re in-depth inform ation is ava ilable. Text within each profile was researched from a variety of sources, and was usually condensed from m o re detailed sources pertaining to specific topics. This appr oa c h allows for a wide coverage of activities that can be f u rther explored based upon the ref e rences listed at the end of this prof ile. As a check on the inf o rm ation

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included, each notebook went through an external docum ent review process. The Office of Com p liance appreciates the ef f o rts of all those that participated in this process and enabled us to develop m o re com p lete, accurate and up-todate sum m a ries. Many of t hose who reviewed this notebook are listed as contacts in Section IX and m a y be source s of a d ditional inform ation. The individuals and groups on this list do not necessarily concur with all
statem ents within this notebook.

I.B. Additional Information

Providing Comments

OECA’s Office of Com p liance plans to periodically review and update the notebooks and w ill m a ke these update s available both in hard copy and electronically. If you have any com m e nts on the existing notebook, or if you would like to provide additional inform ation, plea s e s e nd a hard copy and

com puter disk to the EPA Office of Com p liance, Sector Notebook Project (2224-A), 1200 Pennsylvania Ave., NW , W a shington, DC 20460. Com m e nts

can also be sent via the Sector Notebooks web page at: http://w w w .epa.gov/com p liance/resources /publications/assistance/sectors/ notebooks/. If you are interested in assisting i n the developm ent of new Notebooks, or if you ha ve r e com m e ndations on which sectors should have a Notebook, please contact the Office of Com p liance at 202-564-2310.

Adapting Notebooks to Particular Needs

The scope of the industry sector descri bed in this notebook approxim a tes the national occurrence of facility types w ithin the sector. In m a ny instances, industries within specific geogr a phic regions or states m a y have unique characteristics that are not ful l y capt u red in these profiles. The Office of Com p liance encourages state and local environm ental agencies and other
groups t o s upplem ent or re-package the inform ation included in this notebook to include m o re specific industrial and regulatory inform ation that

m a y be available. Additionally, interest ed states m a y want to supplem ent the "Sum m a ry of Applicabl e Fe de r a l St a t ut es and Regulations" section w ith state and local requirem e nts. Com p liance or t e c hni c a l assistance providers m a y also want to develop the "Pollution Prevention" section in m o re detail.

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II. INTRODUCTION TO THE PULP AND PAPER INDUSTRY

This section provides background inform ation on the size, geographic distribution, em ploym ent, production, sales, and econom ic condition of the pulp and paper industry. Facilities describe d within the docum ent are also described in term s of their Standard Industrial Classification (SIC) codes.

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

The paper and allied products industry (SIC 26) com p rises two types of facilities: pulp and paper m ills that process raw wood fiber or recycled fiber
to m a ke pulp and/or paper, a nd converting facilities that use these prim ary

m a terials to m a nufacture m o re specialized products such as pa pe rboard boxes, writing paper, and sanitary paper. Portions of this notebook present i n form ation for all of SIC 26, but the notebook focuses prim arily on t h e greatest areas of environm ental concern w ithin the industry: those f r om pul p ma ki ng processes. Converting facilities are not discussed, and the
paperm aking stage of the pulp and paper process is de-em phasized.

The specific industry com ponents covere d in this industry are the following:

SIC 2611. Pulp mills. Pulp m ills separate the fibers of wood or from other m a terials, such as rags, linters, wastepaper, and straw in order
to c r e a te pulp. Mills m a y use chem ical, sem i -chem i cal, or m ech a n ic a l processes, and m a y create co-products such as turpentine and tall oil.

This SIC code does not include pulpm aking f a cilities that are part of an integrated paper or paperboard f acility; those would be categorized according to the appropriate final product. The following are types of pulp m ills included in this SIC code:

• D einking of newsprint

• F iber pulp: m a de from wood, rags, wastepaper, linters, straw, and bagasse

• P ulp m ills

• P ulp: soda, sulfate, sulfite, gr oundwood, rayon, and

sem i chem ical

• R ayon pulp

• W ood pulp

SIC 2621. Paper mills. Paper m ills prim arily are engaged in

m a nufacturing paper from woodpulp and ot he r fi ber pulp, and m a y also m a nufacture converted paper products. Establishm ents prim arily engaged in integrated operations of producing pulp and

m a nufacturing paper are included in this i n dustry if prim arily shipping paper or paper products. Establishm ents prim arily engaged

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in m a nufacturing c o nverted 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 prim arily are engaged in m a nufa c t u ring paperboard, including paperboard coated on the paperboa rd m achine, from wood pulp and other fibe r pulp; and m a y also m a nufacture converted paperboard products. Establishm ents prim arily engaged in m a nufacturing

c onverted paperboard products from purchased paperboard ar e classified in Industry Group 265 or Industry Group 267. Establishm ents prim arily engaged in m a nufacturing insulation board and other r e c ons t ituted wood fiberboard are classified in Industry 2493.

The following SIC codes are within SIC 26, but are not addressed in detail in this docum ent:

SIC 265 (2652-2657). Paperboard containers and boxes. Establishm ents in these SIC code s are engaged in the m a nufacture of corrugated and solid fiber boxes and conta i ners from purchased
pa perboard. The principal com m odities of this industry are boxe s , pads, partitions, display item s , pallets, corrugated sheets, f ood packaging, and non-food (e.g., soaps, cosm etics, and m e dici nal products) packaging.

SIC 267 (2671-2679). Miscellaneous converted paper products. The s e establishm ents produce a range of paper, paperboard, and plastic products with purchased m a terial. Com m on products include
pape r and plastic film packaging, specialty paper, paper and plastic bags, m a nila folders, sanitary paper products, envelopes, stationery, and other products.

SIC codes were established by the O ffice of Managem e nt and Budget (OMB) to track the flow of goods a nd services within the econom y. OMB has changed the SIC code system to a s y s t e m based on sim ilar production processes calle d the North Am erican Industrial Classification System (NAICS). Because m o st of the data presented in this notebook apply to the pulp and paper industry as defined by its SIC codes, this notebook continues to use the SIC system to define this sector. Table 1 presents the SIC codes for the pulp and paper industry and the corresponding NAICS codes.

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Table 1: SIC and NAICS Codes

1987 SIC SIC Description 1997 NAICS NAICS Description

2611 Pulp m ills 322110 Pulp m ills

2621 Paper m ills 322121 Paper (except newsprint) m ills (part)

322122 Newsprint m ills

2631 Paperboard m ills 322130 Paperboard m ills

2652 Setup paperboard boxes 322213 Setup paperboard box m f g

2653 Corrugated & solid fiber boxes 322211 Corrugated & solid fiber box m f g

2655 Fiber cans, drum s & sim ilar products 322214 Fiber cans, drum s & sim ilar products m f g

2656 Sanitary food containers 322215 Nonfolding sanitary food container m f g

2657 Folding paperboard boxes 322212 Folding paperboard box m f g

2671 Paper - coated & lam i nated, packaging 322221 Coated & lam i nated packaging paper & plastics film m f g

326112 Unsupported plastics packaging film & sheet mf g

2672 Paper - coated & lam i nated, n.e.c. 322222 Coated & lam i nated paper m f g (part)

2673 Bags - plastics, lam i nated, & coated 322223 Plastics, foil, & coated paper bag m f g

326111 Unsupported plastics bag m f g

2674 Bags - uncoated paper & m u ltiwall 322224 Uncoated paper & m u ltiwall bag m f g

2675 Die-cut paper & board 322226 Surface-coated paperboard m f g

322231 Die-cut paper & paperboard office supplies mf g ( p a r t )

322299 All other converted paper product m f g (part)

2676 Sanitary paper products 322121 Paper (except newsprint) m ills (part)

322291 Sanitary paper product m f g (part)

2677 Envelopes 322232 Envelope m f g

2678 Stationery products 322233 Stationery, tablet, & related product m f g

2679 Converted paper products, n.e.c. 322222 Co ated & lam i nated paper m f g (part)

322231 Die-cut paper & paperboard office supplies mf g ( p a r t )

322299 All other converted paper product mfg (part)

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

Sector Notebook Project 5 Novem b er 2002Pulp and Paper Industry I ntroduction, Background, and Scope

II.B. Characteriz a tion of the Pulp and Paper Industry

The pulp and paper industry converts wood (harvested by logging firm s in SIC 24) or recycled fiber i n t o pul p a n d prim ary form s of paper. Other

com p anies in the paper and allied pr oducts industry (SIC codes 265 and 267) use the products of the pulp and paper industry to m a nufacture specialized products including paperboard boxes, writing paper, and sanitary paper.

II.B.1. Product Characteriz a tion

The pulp and paper industry produces prim ary products – com m odity grades of wood pulp, printing and writing papers , sanitary tissue, industrial-type papers, containerboard and boxboard – using cellulose fiber from tim ber or purchased or rec y c l e d fi bers. The two steps are pulping and paper or paperboard m a nufacturing.

Pulping

Pulping is the process of dissolving wood chips into individual fibers by chem ical, sem i -chem i cal, or m echanical m e thods. The particul a r pulping process used affects the strength, appearance, and intended use characteristics of the resultant paper pr oduct. Pulping is the m a jor source of environm ental im pacts in the pulp and paper industry. There are m o re 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 environm ental

concerns. Table 2 provides an overvie w of the m a jor pulping processes and the m a in products that they produce.

Table 2: Description of Pulping Processes

Pulp Process D escription/Principal Products
Dissolving Kraft H ighly bleached and purif ied 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 Novem b er 2002Pulp and Paper Industry I ntroduction, Background, and Scope

Table 2: Description of Pulping Processes (continued)

Pulp Process D escription/Principal Products
Papergrade Sulfite Sulfite process wood pulp with or without bleaching used for products such as tissue papers, fine papers, and newsprint.

Sem i -chem i cal Pulp is produced by chem ical, pressure, and occasionally

m echanical forces with or without bleaching used for corrugating

m e dium (cardboard), paper, and paperboard.
Mechanical pulp P ulp m a nufacture by stone groundwood, m echanical refiner, therm o -m echanical, chem i-m echanical, or chem i-therm o

m echanical m eans for newsprint, coarse papers, tissue, m o lded fiber products, and fine papers.
Secondary Fiber Deink P ulps from recovered paper or paperboard using a chem ical or solvent process to rem ove contam inants such as inks, coatings and pigm ents 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, m o lded products and construction papers.

Non-wood Chem ical pulp Production of pulp from textiles (e.g.,rags), cotton linters, flax, hem p, tobacco, and abaca to m a ke cigarette wrap papers and other specialty paper products.

Source: U.S. EPA, 1993a.

The bleached and unbleached kraft processes are used to m a nufactur e t h e

m a jority of paper products. Together, these processes account for 83 percent of the pulp produc e d in the United States. Figure 1 presents the relative output of the m a jor pulping processes.

Sector Notebook Project 7 Novem b er 2002�������������������

�������������������������������������������������� Pulp and Paper Industry I ntroduction, Background, and Scope
Figure 1: Pulp Production, 2000

(Thousand Tons)

Semichemical

1,116 ������������������� ������������������� ������������������� ������������������� ������������������� ������������������� ������������������� �������������������������������������������������� �������������������������������������������������� ��������������������������������������������������
�������������������������������������������������� ��������������������������������������������������
�������������������������������������������������� �������������������������������������������������� �������������������������������������������������� �������������������������������������������������� Kraft -- Unbleached Sulfite Mechanical 6,501 3,976

Kraft -- Bleache d 31,978

21,281

Source: AF&PA, 2001.

The pulp m a nufactur i n g process is the m a jor source of environm ental concern for this industry. For exam ple, a bleached kraft pulp m ill requires 4,000-12,000 gallons of water and 14-20 m illion Btu of ene r gy pe r ton of pulp, of which roughly 8-10 m illion Btu t ypically are derived from biom assderived fuel from the pul pi ng process ( Pulp and Paper , 2001). Across all facilities in SIC 26, the pulp, paper, and allied products industry is the largest

consum er of process water and the third largest consum er of energy (behind the chem icals and m e tals industries) (U.S. Departm e nt of Com m e rce, 2000 and U.S. Depa r t me nt of Energy, 2000). The high use of water and energy, as well as the chem ical inputs described in Section III, lead to a vari e t y of environm ental concerns.

Paper and Paperboard Manufacturing

The paper or paperboard m a nufacturing process is s i m ilar for all types of pulp. In this process, pulp is spread out as a wet m i xture, or slu rry , onto a

screen. W a ter is rem oved by gravity and vacuum s, and the resulting layer of fibers is passed through a series of r o llers that com p ress the m a terial into sheets. Paper and paperboard m a nufacturers use nearly identical processes; the difference is that paperboard is thicker (m ore than 0.3 m m )

.

Sector Notebook Project 8 Novem b er 2002Pulp and Paper Industry I ntroduction, Background, and Scope

II.B.2. Industry Siz e and Geographic Distribution

The pulp and paper industry is characterized by very large facilities; of the 514 pulp and paper m ills in SIC codes 261-263 reported by the Bureau of the Census in 1998, 343 (67 percent) have 100 or mor e e m ployees. Across all of these facilities, there are 172,000 em ployees who produced $59 billion in shipme nt s ( i n 1998 dollars). In 2000, the industry em ployed 182,000 and produced $79 billion in shipm e nts.

In contrast, the downstream facilities (container and specialty product

m a nufacturers) tend to be m o re num erous but sm aller. More than 75 percent of these faciliti e s have fewer than 100 em ployees. Table 3 presents the

em ploym ent distribution f o r both pulp and paper f acilities and downstream

m a nufacturers in 1997 (the m o st recent data available) as reported by the U.S. Census Bureau. Because recent years have seen som e facility closures, the current num ber of f

acilities m a y be som e what lower.

Table 3: Siz e of Paper and Allied Products Facilities

Industry Employees per Facility (% of Total)

1-19 20-99 100-499 >499
Pulp m ills (SIC 261) 3 (7%) 14 (34%) 18 (44%) 6 (15%)
Paper m ills (SIC 262) 6 (2%) 63 (24%) 107 (41%) 83 (32%)
Paperboard m ills (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 em ploym ent a nd va l u e of shipm e nts for both the prim ary and secondary portions of the paper and allied products industry. Taken together, the industry is am ong the top 10 U.S. manufacturing industries in va l u e of shipm e nts. As noted in the two graphs, the pulp and paper portion of the industry (pul p, paper, and paperboard m ills) em ploys only 28 percent of the workers in th e industry, but produces over 40 percent of the shipm e nts.

Sector Notebook Project 9 Novem b er 2002��� ����������������������

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���������������������������������� Pulp and Paper Industry I ntroduction, Background, and Scope
Figure 2: Employment and Value of Shipments in the Paper and Allied Products Industry a

Employment Value of Shipments ($ million) Total: 609,480 Total: 145,655

��� ��� ��� ��� ���������������������� ���������������������� ���������������������� ���������������������� ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ��������������������������������������� ��������������������������������������� ��������������������������������������� ��������������������������������������� 10,247 Paper mills 107,552

Paperboard containers Pulp mills Pulp mills

Misc. paper products ����� ����� ����� ����� ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ������������������������ ���������������������������������� ���������������������������������� ���������������������������������� ���������������������������������� 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 m ills, which produce both pulp and paper (or pa perboard), are included in the paper (or p a p e rb o a rd) categories. The pulp m ill category includes only facilities producing pulp for the general m a rket. Source: U.S. Census Bureau, 2000b.

The geographic distribution of pulp and paper m ills varies according to the type of m ill. As there a r e trem endous variations in the scale of individual f acilities, tallies of the num ber of f

acilities m a y not represent the level of

econom ic activity (nor possible en v i ro n m en tal co n s eq u e n ces ). Pulp m ills are locate d prim arily in regions of the country where trees are harvested from natural stands or tree farm s: the Southeast, Northwest, Northeast, and North Central regions. Pulp m ills that process recycled f i ber are generally located near sources of waste paper. Paper m ills, however, are m o re widely distributed. They are located near pul ping operations and/or near converting

m a rkets. The distribution of paperboard m ills ref l ects the location of manufacturing in general, since such operations are the prim ary m a rket for paperboard products. Figure 3 presents the location of pulp and paper m ills in the U.S.

Sector Notebook Project 10 Novem b er 2002Pulp and Paper Industry I ntroduction, Background, and Scope

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

There are no currently active m ills 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 pa pe r i ndustry is one of the m o st im portant industries for the balance of trade in the U.S. This tr ade balance increased through m o st of the 1990s. In 1999, exports from SIC code s 261-263 were $8.5 billion. In recent years, however, exports have been declining and i m ports have been increasing. Between 1997 and 2000, exports declined 5.5% and im ports increased by m o re than 20%. The declining exports and increasing im ports are partly due to a strong dollar in this period and the recent slow down of the U.S. econom y (AF&PA, 2001).

The U.S. industry has several advantages over the rest of the world m a rket, including m odern m ills, a highly skilled work f o rce, a large dom estic

m a rket, and an efficient transportation infrastructure. Major export m a rkets for pulp are Japan, Italy, Germ any, Mexico, and France. The U.S. Departm e nt of Com m e rce anticipates exports to grow faster than production for dom estic m a rkets through 2004. W o rld Trade Organization (W TO) efforts to reduce tariffs include those on pulp and paper products; if these are successful, the U.S. industry expects pul p and paper export rates to increase even further.

Sector Notebook Project 11 Novem b er 2002Pulp and Paper Industry I ntroduction, Background, and Scope
However, pulp and paper are com m odities and therefore prices are vulnerable to global com p etition. Countries such as Brazil, Chile, and Indonesia have built m odern, advanced pulp facilities. These countries have faster-growing trees and lower labor costs. Latin Am erican and European countries also are adding paperm aking capacity. Furtherm or e, the strong value of the dollar has

m a de im ports less expensive r e l a tive to dom estically-produced goods. Because of this increased foreign co m p etition, im ports of paper to the U.S.

m a rket ar e e xpe c t ed to increase three percent annually through 2004 (U.S. Departm e nt of Com m e rce, 2000).

Industry Consolidation

In order to com p ensate f o r this increasingly com p etitive m a rket, pulp and
paper com p anies have undertaken a considerable num ber of m e rgers and acquisitions. Table 4 lists the m a jor transactions that occurred between 1997 and 2002.

Table 4: Major Pulp and Paper Mergers and Acquisitions
Buyer A cquired Value (million) Year

International Paper Co. C ham p ion International Inc. $9,600 2000
International Paper Co. U nion Cam p Corp. $7,900 1999

Jefferson Sm urfit Corp. S tone Container Corp. $6,400 1998

W e yerhaeuser Co. W illam e tte $6,000 2002
Fort Howard Corp. J am es 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

W e stvaco Mead $3,000 2002

Bowater Inc. Avenor Inc. $2,500 1997

W e yerhaeuser Co. M acMillan Bloedel Ltd. $2,450 1999

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

Largest m e rgers and acquisitions between 1997 and m i d-2000. Source: McLaren, J et al., 2000, and Pulp & Paper International, Septem ber 2002.

Sector Notebook Project 12 Novem b er 2002������ ������ ������ ����� ����� ������ ������
������ ������ ������ ����� ������ ������ ������ ������ ����� Pulp and Paper Industry I ntroduction, Background, and Scope
Capital Improvements

Historically, U.S. pulp and paper com p an ies have invested heavily in capital im provem e nts to their f acilities. Capital investm e nts in recent years, however, are well below historic levels due to the difficult m a rket conditions. For the first tim e, industry capacity act ually declined in 2001 (Pulp & Paper International, 2002). Because few new m ills are being built, most capital expenditures r e pr esent plant expansions, upgrades, and environm ental protection initiatives at existing f acilities. Figure 4 presents the rate of capital investm e nts within SIC 261-263. Throughout the tim e period shown, capital im provem e nts related to envir onm ental protection claim e d from 4% to 22% of the total investm e nts with si gnificant increases in the early and late 1990s (AF&PA, 2001).

Figure 4: Capital Improvements at Pulp and Paper Mills

������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ����� ����� ����� ����� ����� ����� ����� ����� ����� ����� ����� ����� ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������ ������

1985 1986 1987 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 $0 $1 $2 $3 $4 $5 $6 $7 $8 $9Capital Expenditures (Billion)

Paperboard Mills (SIC 263) ����� Paper Mills (SIC 262) Pulp Mills (SIC 261) Title

Source: AF&PA, 2001.

Recycling Efforts

A m a jor m ovem e nt 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 i s recovered and used either as recycled paper or as products such as hom e insulation. Furtherm ore, recovered paper contributes to U.S. exports; roughly ten m illion tons of recovered paper were exported in 2000 (AF&PA, 2001).

Sector Notebook Project 13 Novem b er 2002�������� �������� �������� �������� �������� �������� ��������� �������� �������� �������� �������� �������� �������� �������� �������� �������� Pulp and Paper Industry I ntroduction, Background, and Scope
Figure 5: Paper Recovery Rates

50%

40%

30%

20%

10%

0%
1985 1987 1989 1991 1993 1995 1997 1999 1986 1988 1990 1992 1994 1996 1998 2000 � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � ��� ����� � ��� ����� � ��� ����� � ��� ����� � ��� ����� � ��� ����� � ��� ����� � ��� ����� � ��� ����� � ��� ����� ��������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� �������� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� � �� ����� ��������Recovery Rate

The recovery rate is the ratio of recovere d paper collected to new supply of paper and paperboard. Source: AF&PA, 2001.

Sector Notebook Project 14 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description

III. INDUSTRIAL PROCESS DESCRIPTION

This section describes the m a jor indus trial processes within the pulp and paper industry, including the m a terials and e q uipm ent used, and the
processes em ployed. The section is desi gned f o r those interested in gaining a general understanding of the industry, a nd for those interested in the interrelationship be t w e e n the industrial process and the topics described in subsequent sections of this profile -- pollutant outputs, pollution prevention opportunities, and Feder a l r e gulations. This section does not attem p t to

r e pl i c a t e publ i s he d e ngi ne e r i ng i n for m a t i on t h a t i s a v ailable for this indust r y. Refer to Section IX for a list of reference docum ents that are available.

This section specifically contains a description of com m only used production processes, associated raw m a terials, the byproducts produced or released, and the m a terials either recycled or transf erred off-site. This discussion, coupled with schem a tic drawings of the iden tified processes, pr ovides a concise description of where wastes m a y be produced in the process. Thi s s e c tion also describes the potential f a te (via ai r, water, and soi l pa t h ways) of these waste products.

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

Sim p ly put, pa pe r i s manufactured by applying a watery suspension of cellulose f i bers to a screen which allows the water to drain and leaves the fibrous particles behind in a sheet. Most m odern paper products contain nonfibrous additives, but ot he r w i s e fall within this general definition. Only a few paper products for specialized uses are created without the use of water, via dry form ing techniques. The indivi dual fibers form ed into paper sheets is called pulp. The production of pulp is the m a jor source of environm ental im pacts in the pulp and paper industry.

Processes in the m a nufacture of paper and paperboard can, in general term s, be split into three steps: pulp m a ki ng, pulp processing, and paper/paperboard production. Paperboard sheets are thicker than paper sheets; paperboard is thicker than 0.3 m m

. In general, however, paper and paperboard production processes are identical. First, a stoc k pulp m i xture is produced by digesting

a m a terial into its f i brous constituents via chemical, m e chanical, or a

c o mbination of chem ical and m echanical m eans. In the case of wood, t h e

m o st com m on pulping m a terial, chem ical pulping actions release cellulose fibers by selectively destroying the chem ical bonds in the glue-like substance (lignin) that binds the fibers together. After the fibers are separated and im purities have been r e m oved, the pulp m a y be bleached to im prove brightness and processed to a form su itable for paper-m aking equipm ent. At the paper-m aking stage, the pulp can be combi n e d with dyes, strength building resins, or texture adding f ille r m a terials, depending on the intended end product. Aft e rwards, the m i xture is dewatered, leaving the fibrous

Sector Notebook Project 15 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description
constituents and pulp additives on a wire or wire-m esh conveyor. Additional additives m a y be applied after the sheet-m aking step. The fibers bond together as they are carried through a s e r i e s of presses and heated rollers. The final paper product is usua l l y s p ooled on large rolls for storage (see Figure 6).

The following discus s i on focuses m a inly on pulping processes due to their im portance in understanding industry environm ent a l i m pacts and current indus t r y regulatory classification schem e s. If m o re inform ation on
paperm aking processes is desired, the Development Document for Proposed Effl uent Limitations, Guidelines and Standards for the Pulp and Paper Industry, Point Source Category (EPA-821-R-93-019) is recom m e nded. Additional sources are listed in Section IX of this docum ent.

Sector Notebook Project 16 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description

Sector Notebook Project Novem b er 2002 17 Figure 6: Simplified Flow Diagram: Integrated Mill (Chemical Pulping, Bleaching, and Paper Production)

Source: Sm ook, 1992.Pulp and Paper Industry I ndustrial Process Description

III.A.1. Pulp Manufacture

At the pulping stage, the proc e ssed furnish (wood or other fiber source) is digested into its fibrous c ons t i t uents. The bonds between fibers m a y be broken chem ically, m echanically, or by a com b ination of the techniques called sem i -chem i cal pulping. The choi ce of pulping technique is dependent on the type of f

u rnish and the desire d qualities of the f i nished product, but chem ical pulping is the m o st prevalent. Table 5 presents an overview of the wood pu00lping types by the m e thod of fiber separation, resultant fiber quality, and percent of 1998 U.S. pulp production. Many m ills perf orm

m

u ltiple pulping processes at the sam e site, m o st frequently non-deink secondary fiber pulping and papergrade kraft pul ping (U.S. EPA, 1993a). The three basic types of wood pulpi ng processes 1) chem ical pulping, 2)

sem i -chem i cal pulping, and 3) m echanical 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 E xamples % of Total 1998 US Wood Pulp Production

Mechanical Mechanical
energy Short, weak, unstable, im pure fi bers Stone groundwood, refiner m echanical pulp 10%

Sem i

chem ical Com b ination of chem ical and

m echanical
treatm e nts “Interm e diate” pulp properties

(som e unique

properties) High-yield kraft, high-yield sulfite 6%

Chem ical Chem icals and heat Long, strong, stable fibers Kraft, sulfite, soda 84%

Sources: S m ook, 1992; AF&PA, 1999.

A variety of technologi e s a nd chem i cals are used to m a nufacture pulp, but

m o st pulp m a nufa c t ur i ng system s contain the process sequence shown in Table 6.

Sector Notebook Project 18 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description

Table 6: Pulp Manufacturing Process Sequence
Process Sequence D escription
Fiber Furnish Preparation and Handling Debarking, slashing, chipping of wood logs and then screening of wood chips/secondary fibers (som e pulp m ills purchase chips and skip this step)
Pulping C hem i cal, sem i -chem i cal, or m echanical breakdown of pulping m a terial into fibers
Pulp Processing Rem oval of pulp im purities, cleaning and thickening of pulp fiber m i xture Bleaching A ddition of chem icals in a staged process of reaction and washing increases whiteness and brightness of pulp, if necessary
Pulp drying and baling (non-integrated m ills) At non-integrated pulp m ills, pulp is dried and bundled into bales for transport to a paper m ill
Stock Preparation M ixing, refining, and addition of wet additives to add strength, gloss, texture to paper product, if
necessary

Overall, m o st of the pollutant releas es associated with pulp and paper m ills occur at the pulping and bleaching stages where the m a jority of chem ical inputs occur.

Furnish Composition

Furnish is the blend of fibrous m a terials used to m a ke pulp. According to the 1990 National Census of Pulp, Paper, and Paperboard Manufac turing Facilities , t h e m o st com m only used furnish m a terial is wood; it is used in

som e form by approxim a tely 95 percent of pulp and pa pe r m a nufacturers. Overall, wood furnish averages approxi ma tely 50 percent of pulp content industry-wide.

The m a jor source of fi be r for paper products com e s from the vegetative tissues of vascular plants. Although al m o st any vascular plant could be used for paper production, the econom ics of scale require a hi gh fiber yield for
paper m a nufacture. By far, the principl e source of paper-m aking fibers in the United States is wood from trees, the larg est vascular plants available. The fibrous particles used to m a ke paper are ma de of cellulose, a prim ary

com ponent of the cell walls of vascular plant tis s u e s

. The cellulose fibers

m

u st be rem oved from a chem ical m a trix (e.g., lignin, hem i celluloses, and resins) and result in a m i xture of relatively pure fibers.

Sector Notebook Project 19 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description

W ood used to m a ke pulp can arrive at the m ill in a variety of form s including wood logs, chips, and sawdust. Due to different physical and chem ical properties of different types of wood, certain pulping processes are m o st ef

f i cient on specif i c wood types. The type of wood used can also m a ke a difference in the final characteristics of the pulp. In general, softwood (e.g., pine and spruce) fibers are longer th an those from hardwood (e.g., birch and oak) a nd ha ve thinner cell walls. The longer fibers of softwood prom ote inter-fiber bonding and produce papers of greater strength.

Secondary fibers com p rise the next m o st com m on furnish constituent. Secondary fibers consist of pre-consum er fibers (e.g., m ill waste fibers) and post-consum er fiber. Post-consum er fi ber sources are diverse, but the m o st

com m on are newsprint and corrugated boxes (See Table 7). Although secondary fi be r s are not used in as great a proportion as wood furnish, approxim a tely 80 percent of pul p and paper m a nufacturers use som e secondary fibers in their pulp production and approxim a tely 200 m i l l s (approxim a tely 40 percent of total num ber of m ills) rely exclusively on secondary f i bers f o r their pulp f u rnish (AF&PA, 1999; AF&PA, 2000c). Secondary fibers m u st be processed to rem ove contam inants such as glues or bindings, but, depending on the end product, m a y or m a y not be processed
to rem ove ink contam inants or to brighten the pulp.

Secondary fiber use is i n c r e a s i ng in the pulp and paper industry due to

consum er dem a nd for products m a de from recycled paper. Recovered fiber accounted for 75 perc e n t of the industry’s increase in fiber consum ption between 1990 and 2000 (AF&PA, 2000a). The utilization of secondary fibers, expressed as the ratio of recovered paper consum ption t o t h e total
pr oduction of paper and paperboard, is at approxim a tely 39 percent and i s clim bing slowly (AF&PA, 20 01)

. In a resource-def icient country such as Japan, the secondary fiber utilization rate is at about 50 percent, whereas the average utilization rate in Europe is approxim a tely 40 percent (VDP, 1997). Due to losses of fiber substance and st rength during the recycling process, a 50 percent utilization rate is considered the present m a xim u m overall utilization rate for fiber recycling (Sm ook, 1992).

Secondary fiber sources are seldom used as feedstocks for high quality paper products. Contam inants (e.g., inks, paper colors) are often present, so production of low-purity products is of ten the m o st cost-effecti v e us e of secondary fibers, although decontam ination technologies are a v a ilable. Approxim a tely 68 percent of all secondary fiber in the U.S. is presently used f o r m u lti-ply paperboard or the corrugating paper used to m a nuf acture corrugated cardboard (AF&PA, 2000a). Ov er the next decade, an increasing proportion of the total am ount will be de inked for newsprint or other higherquality uses.

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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 l i nters, flax, hem p, bagasse, tobacco, and synthetic fibe r s s u c h as polypropylene. These substances are not used wi de l y, however, as they are typically for low volum e, specialty grades of paper.

The types of f

u rnish used by a pulp and paper m ill depend on the type of product produced and what is readily available. Urban m ills use a l a r g er proportion of seconda r y fi bers due to the post-consum er feedstock close at hand. More rurally located m ills are us ually close to tim ber sources and thus

m a y use virgin fibers in greater proportion.

Furnish Preparation

Furnish is prepared for pulp production by a process designed to supply a hom ogenous pulping feedstock. In the case of roundwood furnish (logs), the logs are cut to m a nageable size and th en debarked. At pulp m ills integrated with lum b ering facilities, acceptable lum b er wood is rem oved at this stage. At t h ese facilities, any residual or wa ste wood from lum b er processing i s returned to the chipping process; in-house lum b ering rejects can be a significant source of wood furnish at a fac ility. The bark of those logs not fit for lum b er is usually either stripped m echanically or hydraulically with high powered water jets in order to prev ent contam ination of pulping operations. Depending on the m o isture content of t h e ba rk, it m a y then be burned for energy production. If not burned for en ergy production, bark can be used for

m

u lch, ground cover, or to m a ke charcoal.

Hydraulic debarking m e thods m a y require a drying step before bur ni ng. Usually, hydraulically rem oved bark is co llected in a w a ter f l um e, dew a tered, and pr e s s e d before burning. Treatm e nt of wastewater from this process is difficult and costly, however, whereas dry debarking m e thods can channel

Sector Notebook Project 21 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description

the rem oved bark directly into a fu rnace (Sm ook, 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 m achines. Chippers usually produce uni for m wood pieces 20 m m long in the grain direction and 4 m m thick. The chips are then put on a set of vibrating screens
to rem ove t hose that are too large or sm all. Large chips stay on the top

scr eens and are sent to be recut, wh ile the sm aller chips are usually burned with the bark. Certain m echanical pul ping processes, such as stone
gr oundwood pulping, use roundwood; however, the m a jority of pulping operations require wood chips. No n-wood fibers are handled in ways specific to their com position. St e p s a r e always taken to m a intain fiber

com position and thus pulp yield.

Chemical Pulping

Chem ical pulps are typically m a nufactured into products that have highquality standards or require special pr operties. Chem ical pulping degrades wood by dissolving the lignin bonds holding the cellulos e fi be r s together. Generally, this process involves the cooking/digesting of wood chips in aqueous chem ical solutions at elevated tem p eratures and pr essures. There
are two m a jor types of chem ical pulping currently used in the U.S.: 1) kraft/soda pulping and 2) sulfite pulpi ng. These processes differ prim arily in the chem icals used for digesting. The specialty paper products rayon, viscose, acetate, and cellophane are m a de from dissolving pulp, a variant of standard kraft or sulfite chem ical pulping processes.

Kraft pulping (or sulfate) processes produced approxim a tely 83 percent of all US pulp tonnage during 2000 according to the Am erican Forest and Paper Association (AF&PA, 2001). The success of the process and its widespread adoption are due to several factors. Fir s t , because the kraft cooking chem icals are selective in their attack on wood constituents, the pulps produced are notably stronger than thos e from other processes (i.e., Kraft is Germ an for "strength"). The kraft pr oc e ss is also f l exible, in so f a r as it is

am enable to m a ny different types of ra w m a terials (i.e., hard or soft woods) and can tolerate contam inants frequen tly found in wood (e.g., resins). Lignin

r e m oval rates are high in the kraft process — up to 90 percent — a l l o wi ng high levels of bleaching without pulp degradat i on. Finally, the chem icals used in kraft pulping are readily recovered within the process, m a king it very

econom ical and reducing potential envi r o nm ental releases (See Chemical Recovery Systems below).

The kraft process uses a sodium -based alkaline pulping sol u tion (liquor) consisting of sodium sulfide (Na 2 S) and sodium hydroxide (NaOH) in 10 percent solution. This liquor (white liquor) is m i xed with the wood chips in

Sector Notebook Project 22 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description
a reaction vessel (digester). The out put products are separated wood fibers ( pulp) and a liquid that contains the dissolved lignin solids in a s o l u t i on of reacted and unreacted pulping chem icals (black liquor). The black liquor undergoes a chem ical recovery process (see Chemical Recovery Systems ) to regenerate white liquor for the first pul ping step. Overall, the kraft process converts approxim a tely 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 kr a f t process has virtually replaced the soda process due to the econom ic benefits of chem ical recovery and im proved reaction rates (t he soda process has a lower yield of pulp per pound of wood furnish than the kraft process).

Sulfite pulping was used for approxim a tel y two percent of U.S. pulp
pr oduction in 2000 (AF&PA, 2001). Softwood is the predom inant furnish used in sulfite pul pi ng pr ocesses. However, only non-resinous species are generally pulped. The sulfi t e pulping process relies on acid solutions of sulfurous acid (H 2 SO 3 ) and bisulfite ion (HSO 3 - ) to degrade the lignin bonds between wood fibers.

Sulfite pulps have less color than kraft pulps and can be bl e a c h ed m o re easily, but are not as strong. The efficiency and effectiveness of the sulfite
pr ocess is also dependent on the type of wood furnish and the a b s e nc e of bark. For these reasons, the use of su lfite pulping has declined in com p arison to kraft pulping over tim e.

Semi-chemical pulping

Sem i -chem i cal pulping com p rised six percent of U.S. pulp production in 2000 (AF&PA, 2001). Sem i -chem i cal pulp is often very stiff, m a king this
process com m on in corrugated container m a nufacture. This process prim arily uses hardwood as furnish.

The m a jor process difference between chem ical pulping and sem i -chem i cal pulping is that sem i -chem i cal pulping uses lower tem p eratures, m o re dilute cooking liquor or shorter cooking tim es, and m echanical disintegration for fiber separation. At m o st, the digestion step in the sem i -chem i cal pulping process consists of heating pulp in sodi um s u l f ite (Na 2 SO 3 ) and sodium carbonate (Na 2 CO 3 ) Other sem i -chem i cal processes include the Perm achem process and the two-stage vapor process. The yield of sem i -chem i cal pulping ranges from 55 to 90 percent, depending on the process used, but pulp residual lignin content is also high so bleaching is m o re difficult.

Sector Notebook Project 23 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description
Mechanical pulping

Mecha n ical pulping accounted for nine percent of U.S. pulp production in 2000 (AF&PA, 2001). Mec h anically produced pulp is of low strength and quality. Such pulps are used principally for ne ws pr i n t and other nonpe r m a n e n t paper goods. Mechanical pulping relies on physical pressure instead of c h e m i c als to separate fu rnish fibers; however, chem icals are

som e time s a dde d at the various stages of refining. Processes include: 1) stone groundwood, 2) refiner m echanical, 3) therm o -m echanical, 4) chem im echanical, and 5) chem i-therm o

- m e c hanical. The stone groundwood process sim p ly involves m echanical gr inding of wood in several high-energy refining system s. The refiner m echanical process involves refining wood chips at atm o spheric pr essure while the therm o -m echanical process uses
steam and pressure t o s o ft en the chips before m echanical refining. In the chem i-m echanical process, che m i c a l s can be added throughout the process to aid the m echanical refi ni ng. The chem i-therm o -m echanical process involves the treatm e nt of c h i p s with chem icals for softening followed by

m echanical pulping under heat and pr essure. M e c h a n ical pulping typically results in high pulp yields, up to 95 pe r c e n t when com p ared to chem ical pulping yields of 45- 50 percent, but en ergy usage is also high. To offset its structural weakness, m echanical pulp is often blended with chem ical pulp.

Secondary fiber pulping

Secondar y fi ber pulping accounted for 39 percent of dom estic pulp production in 2000 (AF&PA, 2001). Nearly 200 m ills re ly exclusively on recovered paper for pulp furnish, and roughly 80 percent of U.S. paper m ills use recovered paper in som e way (AF&PA, 2000c). In addition,

consum ption of fiber from recovered paper i s gr owing m o re than twice as fast as overall fiber consumpt i on. Secondary fibers are usually presorted before they are sold to a pul p a n d paper m ill. If not, secondary fibers are processed to rem ove contam inants before pulpi ng oc c u rs. Com m o n contam inants consist of adhesives, coatings, polystyrene foam , dense plastic chips, polyethylene film s, wet strength resins, and synthetic fibers. In som e cases, contam inants of greater density than the desired seconda r y fiber are

rem oved by centrifugal force while li ght c ontam inants are rem oved by flotation system s. Centri cleaners are al so used to rem ove m a terial less dense than fibers (wax and plastic particles) (AF&PA, 1995b).

Inks, another contam inant of secondary fibers, m a y be rem oved by heating

a mi xt ur e of secondary fibers with su rfactants. The rem oved inks are then dispers e d i n an aqueous m e dia to prevent redeposition on the fibers. Continuous solvent extraction has also been used to recover f i bers f r om paper and board coated with plastics and/or waxes.

Sector Notebook Project 24 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description
Secondary fiber pulping is a relatively sim p l e pr oc e s s

. The m o st com m o n pulper design consists of a large c ontainer f illed with water, which is

som e tim es he a t e d, and the recycled pulp. Pulping chem icals (e.g., sodium hydroxide, NaOH) are oft e n a dde d to prom ote dissolution of the paper or board m a trix. The source f i ber (corrugated containers, m ill waste, etc.) is dropped into the pulper and m i xed by a rotor. Debris and i m pur i ties are

rem oved by two m echanism s : a ragger a nd a junker. The ragger withdraws strings, wires, and rags from the stock secondary fiber m i xture. A t ypi cal ragger consists of a few "prim e r wires" that are rotated in the secondary fiber slurry. Debris accum u lates on the prim er wires, eventually form ing a "debris rope" which is then rem oved. Heavier debris are separated from the m i xture by centrifugal force and fa ll into a pocket on the side of the pulper. The junker consists of a grappling hook or elevator bucket. Heat, dissolution of chem ical bonds, shear forces created by stirring and m i xing, and grinding by

m echanical equipm ent m a y serve to dissociate fibers and produce a pulp of desired consistency.

Contam inant rem oval processes depend on the type and source of secondary f i b e r to b e p u l p e d. Mill pa p e r w a s t e c a n b e e a s ily r e p u l p e d w ith m i n i m a l
contam inant rem oval. Re c y c l ed post-consum er newspaper, on the other hand, m a y require extensive contam inan t rem oval, including deinking, prior
to reuse. As noted in Furnish Composition above, secondary fiber typically is used in lower-quality applications such as m u lti-ply paperboard or corrugating paper.

III.A.2. Pulp Processing

After pulp production, pulp processing rem oves im purities, such as uncooked chips, and recycles any resi dua l cooking liquor via the washing process (Figure 7). Pulps are processed in a wide variety of ways, depending on the

m e thod that genera t e d them (e.g., chem ical, sem i -chem i cal). Som e pulp processing steps that rem ove pulp im purities include screening, defibering, and deknotting. Pulp m a y also be thickened by rem oving a portion of the
water. At additional cost, pulp m a y be blended to ensure product uniform ity. If pulp is to be stored for long periods of tim e, drying steps are necessary to prevent fungal or bacterial growth.

Residual spent cooking liquor from ch em ical pulping is washe d from the pulp using brown stock washers. Efficient was h i ng i s critical to m a xim i ze return of cooking liquor to chem ical recovery (see C h em ica l Recovery Systems below) and to mi ni m i ze carryover of cooking liquor (known as brown s t oc k washing loss) into the bleach plant, because excess cooking liquor increases consum pt ion of bleaching chem icals. Specifically, the dissolved organic com pounds (lignins a nd hem i celluloses) contained in the liquor will bind t o bleaching chem icals and thus increase bleach chem ical

consum ption. In addition, these organic com pounds function as precursors

Sector Notebook Project 25 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description
to chlorinated organic com pounds (e.g., dioxins, furans), increasing the probability of their form ation. The m o st com m on washing technology is
rota r y va c u um washing, carried out sequentially in two or four washing units. Other washing technologies include diffusion washers, rotary pressure washers, h o r izontal belt f ilters, wash presses, and dilution/extraction washers.

Pulp scre e n i n g, rem oves rem a ining oversized particles such as bark fragm e nts, oversized chips, and uncooked chips. I n open screen room s, wastewater from the screening process goes to wastewater treatm e nt prior to di scharge. In closed loop screen room s, wastewater from the process is reused in other pulping operations and ultim ately enters the m ill' s chem ical recovery system

. Centrifugal c l e a n i ng (also known as liquid cyclone, hydrocyclone, or centricleaning) is used after screening to rem ove relatively dense contam inants such as sand and dirt

. Rejects from the screening process are either repulped or disposed of as solid waste.

Chemical Recovery Systems

The chem ical recovery system is a com p lex part of a chem ical pulp and paper

m ill and is subject to a variety of environm ental regulations. Chem ical recovery is a crucial com ponent of th e chem ical pulping process: it recovers process chem icals f r om the spent cooki ng liquor for reuse. The chem ical recovery process has im portant financia l and environm ental benefits for pulp and pa pe r m ills. Econom ic benefits include savings on chem ical purchase costs due to regeneration rates of pr ocess chem icals approaching 98 percent, and energy generation from pulp resi due burned in a recovery fur n ace (Sm o ok, 1992). Environm ental benef its include the recycle of process chem icals and lack of resultant discharges to the environm ent.

The kraft, sulfite, and sem i -che m i cal pulping processes all use chem ical recovery system s of som e form ; howev er, the actual chemi cal processes at work differ m a rkedly. Due to its wide spread usage, only the kraft chem ical recovery system will be covered in depth in this docum ent. Sulf ite chem ical recovery system s are discussed briefly at the end of this section.

Kraft Chemical Recovery Systems

Although newer technologies are always under developm ent, the basic kraft chem ical recovery process has not been fundam e ntally change d since its patent issue in 1884. T h e stepw i se progression of chem ical reactions has been refined; for exam ple, black liquor gasification processes are now in use in an experim e ntal phase. The preci s e det a ils of the chem ical processes at work in the chem ical recovery process can be found in Sm ook, Handbook for Pulp and Paper Technologists, 2nd Edition, 1992 and will not be discussed here. The kraft chem ical recovery pr ocess consists of the following general steps:

Sector Notebook Project 26 Novem b er 2002Pulp and Paper Industry I ndustrial 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 conc e n t r ation of solids in the weak black liquor is approxim a tely 15 percent; after the eva poration process, so lid s c o n centration can range f r om 60 - 80 percent. In som e older f acilities, th e liquor then undergoes oxidation for odor reduction. The oxidation step is necessary to reduce odor created when hydrogen sulfid e is stripped from the liquor during the subsequent recovery boiler burning proces s

. Alm o st all recovery furnaces installed since 1968 have non- contact evaporation processes that avoid these problem s, so oxidation processes are not usually seen in m ills with m odern recovery furnaces. Co m m on m odern evaporator types include

m

u ltiple effect evaporators as well as a variety of supplem ental evaporators. Odor problem s wi t h the kraft process have been the subject of control

m easures (See Section III.B. Raw Mate rial Inputs and Pollution Outputs in the Production Line for m o re inform ation).

Recovery boiler The strong black liquor from the evapor ators is burned in a recovery boiler. In this crucial step in the overall kraft chem ic a l recovery process, organic solids are burned for energy and the process chem icals are rem oved from the

m i xture in m o lten form

. Molten inorganic process chem icals (sm e lt) flow through the perforated floor of th e boile r t o wa ter-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 f acilities augm ent r ecovery boilers with f o ssil-f u el-f ired and wood-waste-f i red boilers (hogged f u el) to generate steam and of ten electricity. Industry-wide, the utilization of pulp wastes, bark, and other
paperm aking residues supplies 58 percent of the energy requirem e nts of pulp and paper com p anies (AF&PA, 1999) (see III .A.3. Energy Generation for

m o re inform ation).

Recausticizating Sm elt is recausticized to rem ove im purities left over from the furnace and to convert sodium carbonate (Na 2 CO 3 ) i n t o active sodium hydroxide (NaOH) and sodium sulfide (Na 2 S). The recausticization procedure begins with the

m i xing of sm elt with "weak" liquor to for m green liquor, nam e d for its characteristic color. Contam inant solid s, called dregs, are rem oved from the green liquor, which is m i xed with lim e (CaO). After the l i m e m i xing step, the m i xture, now called white liquor due to its new coloring, is processed to

rem ove a layer of lim e m ud (CaCO 3 ) that has precipitated. The prim ary chem icals recovered are caustic (NaOH) and sodium sulfide (Na 2 S). The

rem a ining white liquor is t h e n us e d in the pulp cooking process. The lim e

m

ud is treated to regenerate lim e in the calcining process.

Sector Notebook Project 27 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description
Calcining In the calcining process, the l i m e mud rem oved from the white liquor is burned to regenerate lim e for use in the lim e m i xing step. The vast m a jority of m ills use lim e kilns for this process, although a few m ills use fluidized bed system s in which the reactants are suspended by upward-blowing air.

Sulfite Chemical Recovery Systems

There are a variety of sulfite chem ical pulping recovery system s in use today. Heat and sulfur can be recovered from all liquors ge ne r a t e d, however the base chem ical can only be recover e d fr om m a gnesium and sodium base processes (see Sm ook, 1992 for m o re inform ation).

Sector Notebook Project 28 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description
Figure 7: The Kraft Pulping Process (w ith Chemical Recovery)

Source: Sm ook, 1992.

Sector Notebook Project 29 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description

III.A.3. Bleaching

Bleaching is defined as any process that chem ically alters pulp to increase its brightness. Bleached pulps create papers that are whiter, brighter, softer, and

m o re 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 wr apping papers, food contact papers). Unbleached pulp is typically used to produce boxboard, linerboard, and grocery bags. Of the approxim a tely 72 m illion tons of pulp production capacity in the United States in 2000, about 50 percent is for bleached pulp (AF&PA, 2001).

A n y ty p e o f p u l p m a y be bleached
, b u t th e ty p e (s ) o f f

i b e r f u rn is h a n d pulping processes used, as well as th e desired qualities and end use of the final product, greatly affect the type and degree of pulp bleaching possible. Printing and writing papers com p rise approxim a tely 60 percent of bleached paper production. The lignin content of a pulp is the m a j o r determ inant of its bleaching potential. Pulps w ith high lignin content (e.g., m echanical or

sem i -chem i cal) are di ffi cul t to bleach fully and require heavy chem ical inputs. Excessive bleaching of m echan ical and sem i -chem i cal pulps results in loss of pulp yield due to fiber dest ruction. Chem ical pulps can be bleached to a greater extent due to their low (10 percent) lignin content.

For m o re inform ation, the Sum m a ry of Technologies for the C ontrol and Reduc t i on of Chlorinated Organics from the Bleached Chemical Pulping Subcategories of the Pulp and Paper Industry , 1990 from the Office of W a ter Regul at i ons and St andar d s i s r ecommended. Typi cal bleaching processes for each pulp type are detailed below.

Chemical pulp bleaching has undergone signifi cant process changes since approxim a tely 1990. At that tim e, near ly every chem ical pulp m ill that used bleaching incorporated elem ent a l chlorine (Cl 2 ) into som e of its processes. Because of environm ental and health concerns about dioxins, U.S. pulp m ills now use elem ental chlorine free (E CF) and total chlorine f r ee (TCF) bleaching technologies. The m o st com m on types of ECF and TCF are shown in Table 8; the difference between ECF and TCF is that ECF m a y include chlorine dioxi de ( C lO 2 ) and hypochlorite (HClO, NaOCl, and Ca(OCl) 2 ) based technologies. In 2001, ECF technologies were used f o r about 95 percent of bleached pulp production, TC F technologies were used for about 1 percent of bleached pulp production, a nd elem ental chlorine was used for about 4 percent of production (AET, 2002).

Sector Notebook Project 30 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description

Table 8: Common Chemicals Used in Elemental Chlorine Free (ECF) and Total Chlorine Free (TCF) Bleaching Processes
Bleaching Chemical Chemical Formula E CF/TCF

Sodium Hydroxide NaOH ECF and TCF

Chlorine Dioxide ClO 2 ECF
Hypochlorite HClO, NaOCl, Ca(OCl) 2 ECF

Oxygen O 2 ECF and TCF

Ozone O 3 ECF and TCF
Hydrogen Peroxide H 2 O 2 ECF and TCF

Sulfur Dioxide SO 2 ECF and TCF

Sulf uric Acid H 2 SO 4 ECF and TCF

Source: U.S. EPA, 2001.

Chem ical pulp is bleached in traditiona l bleach plants (see Figure 8) where the pulp is processed through three to fi ve stages of chem ical bleaching and water washing. The num ber 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. Chem ical reactions with lignin during the acid stage of the bleaching process increase t h e whiteness of the pulp. The alkaline extraction stages dissolve the lignin/acid reaction products. A t th e w a shing stage, both solutions and

reac t i on products are rem oved. Chem icals used to perform the bleaching
process m u st have high lignin reactivity and selectivit y t o be efficient. Typically, 4-8 percent of pulp i s lost due to bleaching agent reactions with the wood constituents cellulose and hem i cellulose , but, these losses can be as high as 18 percent.

Sector Notebook Project 31 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description
Figure 8: Typical Bleach Plant

Source: U.S. EPA, 1993a.

Semi-chemical pulps are typically bleached with hydrogen peroxide (H 2 O 2 ) in a bleach tower.

Mechanical pulps are bleached with hydr ogen peroxide (H 2 O 2 ) and/or sodium hydrosul fi t e (Na 2 SO 3 ). Bleaching chem icals are either applied without separate equi pment during the pulp processing stage (i.e., in-line bleaching), or in bleaching towers. Full bleaching of m e chanical pulps is
gener a lly not practical due to bleaching chem ical cost and the negative im pact on pulp yield.

Deinked secondary fibers are usually bleached in a bleach tower, but m a y be bleached during the repulping proce ss. Bleach chem icals m a y be added directly into the pulper. The f o llowi ng are exam ples of chem icals used to bleach deinked secondary fibers: hypoc hlorite ( H ClO, NaOCl, Ca(OCl) 2 ), hydrogen peroxide (H 2 O 2 ), and hydrosulphite (Na 2 S 2 O 4 ).

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III.A.4. Stock Preparation

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

m a nufacture. Market pulp, whi c h i s to be shipped off-site to paper or paperboard m ills, is sim p ly dried and baled during this step. Processing of pulp in integrated m ills includes pulp blending specif i c to the desired paper product desired, dispersion in water, b eating and refining to add density and strength, and addition of any necessary wet additives. W e t additives are used to create paper product s wi th special properties or to facilitate the
paperm aking process. W e t additives include resins and waxes f o r water repellency, f illers such as clays, silicas, talc, inorganic/organic dyes f o r coloring, and certain inorganic chem icals (calcium sulfate, zinc sulfide, and titanium dioxide) f o r im proved texture, print quality, opacity, and brightness.

III.A.5. Processes in Paper Manufacture

The paper and paperboard m a king process consists of the following general steps:

Table 9: Paper and Paperboard Making Process
Sequential Process Description

W e t End Operations Form ation of paper sheet from wet pulp
Dry End Operations Drying of paper product, application of surface treatm e nts, spooling for storage

Wet End Operations

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

m achine, the m o st com m on of which is the Fourdrinier paper m achine (see Figure 9). In the Fourdrinier system , the pul p s l urry is deposited on a

m oving wire belt that carries it through the first stages of the process. W a ter is rem oved by gravity, vacuum cham bers, and vacuum rolls

. This waste water is recycled to the slurry depositi on step of the process due to its high fiber content. The continuous sheet is the n pr e s s e d between a series of rollers to rem ove m o re water and com p ress the fibers.

Sector Notebook Project 33 Novem b er 2002Pulp and Paper Industry I ndustrial 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 com p ress the sheets. In the calender process the sheet i s pr essed between heavy rolls to reduce paper thickness and produce a sm ooth surface. Coatings can be applied to the paper at this point to im prove gloss, color, printing detail, and brilliance. Lighter coatings are applied on-m achine
, while heavy coatings are perform e d off-m achine. The paper product is then spooled for storage.

III.A.6. Energy Generation

Pulp and paper m ill e n e r gy generation is provided in part from the burning of liquor w a ste solids in the recovery boiler, but other energy sources are

Sector Notebook Project 34 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description

needed to m a ke up the rem a inder of mill energy needs. Over the last 25 years, the pulp and paper industry ha s changed its energy generation m e thods f r om f

o ssil f u els to a greater utilization of processes or process wastes. The increase in use of wood wastes fr om the wood handling a nd c h i pping processes depicted in Table 10 below is one exam ple of this industry-wide

m ovem e nt. During the 1972-1999 period, the proportion of t o t a l industry power generation from the com b ination of woodroom wastes, spent liquor solids, and other self-generation m e t hods 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 m ills are sources of particulate em issions, sulf ur dioxide (S O 2) , and nitrogen oxides (NO

x ). Pollutants em itted f r om chem ical recovery boilers include SO 2 , and total reduced sulfur com pounds (TRS).

Table 10: Estimated Energy Sources for the U.S. Pulp and Paper Industry
Energy Source 1972 a 1979 a 1990 a 1999 b

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%

W a ste 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: a Am erican Paper Institute Data as presented in Sm ook, 1992.

b AF&PA, 2001.

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

Pulp and paper m ills use and generate m a terials that m a y be harm f u l to the air, water, and land: pulp and paper pr ocesses generate large volum es of wastewaters which m i ght adversely affect freshwater or m a rine ecosystem s , residual wastes from wastewater tr eatm e nt processes m a y contribute t o existing local and regional disposal pr oblem s, and air em issions from pulping

Sector Notebook Project 35 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description
processes and power generation facilities m a y release odors, particulates, or other pollutants. Major sources of pollutant releases in pulp a nd paper

m a nufacture are at the pulping and bleaching stages respectively. As such, non-integrated m ills (i.e., those m ills without pulping f acilities on-site) are not signif i cant environm ental concerns wh en com p ared to integrated m ills or pulp m ills.

Water

The pulp and paper industry is the larges t industrial process water user in the U.S. (U.S. Departm e nt of Com m e rce, 2000). I n 2000, a typical pulp and
paper m ill used 4,000-12,000 gallons of water per ton of pulp produced (Pulp and Paper, 2001). General water pollu tion concerns for pulp and paper m ills are effluent solids, biochem i cal oxygen dem a nd, and color. Toxicity concerns historically occurred fr om the potential presence of chlorinated organic com pounds such as dioxins, fura ns, and others (collectively referred to as adsorbable organic halides, or AOX) i n wa s t ewaters after the chlorination/extraction sequence. W ith the substitution of chlorine dioxide f o r chlorine, ef f l uent loads of the chlorinated com pounds decreased dram atically.

Due to the large volum es of water used in pulp and paper processes, virtually all U.S. m ills have prim ary and seconda r y wastewater treatm e nt system s installed t o rem ove particulate and biochem i cal oxygen dem a nd (BOD) produced in the m a nufacturing pr ocesses. These system s also provide significant rem oval (e.g., 30-70 percent) of other im portant param e ters such as AOX and chem ical oxygen dem a nd (COD).

The m a jor sources of ef f l uent pollutants in a pulp and paper m ill are presented in Table 11.

Sector Notebook Project 36 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description

Table 11: Potential Water Pollutants From Pulp and Paper Processes

Source Effluent characteristics

W a ter used in wood handling/debarking and chip washing Solids, BOD, color

Chip digester and liquor evaporator condensate Concentrated BOD, reduced sulfur

com pounds

"W hite waters" from pulp screening, thickening, and cleaning Large volum e of water with suspended solids, can have significant BOD
Bleach plant washer filtrates BOD, color, chlorinated organic com pounds
Paper m achinewater flows Solids
Fiber and liquor spills Solids, BOD, color

Source: Sm ook, 1992.

W ood processing operations in pul p mi l l s often use water for a variety of
purposes. The resulting wastewaters contain BOD, sus p e nded solids, and

som e color. The condensates from chip digesters and chem ical recovery evaporators are sources of BOD and reduced s u l f ur com pounds. W a stewaters containing BOD, color, and suspended solids m a y be generated from pulp screening operations in m ills using “atm o spheric” system s, though

m o st m ills have m odern pressure screens that virtually elim inate such
wastewaters. Kraft bleaching gene rates large volum es of wastewater
conta i ni ng BOD, suspended solids, color, and chlorinated organic

com pounds. From paper m achines, exces s white water (nam ed for its characteristic color) contains suspended solids and BOD. Fiber and liquor spills can also be a source of m ill ef f l uent. Typically, spills are captured and
pum ped to holding areas to reduce chem ical usage through spill reuse and to avoid loadings on f acility wastewater treatm e nt system s.

W a stewater treatm e nt syst ems can be a significant source of cross-m e dia pollutant transf er. F o r e x a m p l e, water borne particulate and som e chlorinated

com pounds settle or absorb onto treat m e nt sludge and other com pounds m a y volatilize during the wastewater treatm e nt process.

Sector Notebook Project 37 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description

Air

The following table is an overview of the m a jor 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

Sulf ite m ill operations Sulf ur oxides, am m onia
Kraft pulping and recovery processes R educed sulfur gases
Chip digesters and liquor evaporation V olatile organic com pounds
Pulp drying (non-integrated m ills) V olatile organic com pounds

All com bustion processes N itrogen oxides

Source: Sm ook, 1992.

W a ter vapors are the m o st visible air em ission f r om a pulp and paper mill, but are not usually regulated unl e s s t h ey are a significant obscurem e nt or clim ate m odifier.

Pulp and paper m ill power boilers are generic pulp and paper m ill sources of air pollutants such as particulates and nitrogen oxides. Chip digeste r s and chem ical recovery evaporators are the m o st concentrated sources of volatile organic com pounds. The chem ical recovery furnace is a source of fine
par t i c ul a t e em issions and sulfur oxides. In the kraft process, sulfur oxides

are a m i nor issue in com p arison to the odor problem s created by four reduced sulfur gasses, call e d together total reduced sulfur (TRS): hydrogen sulfide,

m e thyl m e rcaptan, dim e thyl sulfide, and dim e thyl disulfide. The TRS

em issions are prim arily released f r om wood chip digestion, black liquor evaporation, and chem ical recovery bo iler processes. TRS com pounds create odor nui sance problem s at lower concentrations than sulfur oxides: odor thresholds for TRS com pounds are appr oxim a tely 1,000 tim es lower than that for sulfur dioxide. Hum a ns can detect som e TRS com pounds in the air as a "rotten egg" odor at as little as one part per billion.

Pulp and paper m ills have m a de signif i cant investm e nts in pollution control technologies and processes. According to industry sources, t h e pulp and

Sector Notebook Project 38 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description
paper industry spe n t more than $1 billion per year from 1991-1997 on environme n t a l capital expenditures. In 1991 and 1992, this represented 20
pe r c e n t of t o t a l c a p i t a l e x penditures (AF&PA, 1994). Chem ic a l r e c ove r y a n d recycling system s in the c h e m i cal pulping process significantly reduce pollutant outputs while providing substantial econom ic return due to recovery of process chem icals. Chem i cal recovery is necessary for the basic

econom ic viability of the kraft process. According to EPA sources, all kraft pulp m ills worldwide have chem ical rec overy system s in place. Som e sulf ite

m ills, however, still do not have recovery system s in place. Scrubber system particulate "baghouses" or electrostatic precipitators (ESPs) are often m ill air pollution control com ponents.

Residual Wastes

The signif i cant residual waste stream s f r om pulp and paper m ills include
wastewater treatm e nt sludges, lim e m ud, lim e slaker grits, green liquor dregs, boiler and furnace ash, scr u bber sludges, and wood processing residuals. Because of the tendency for chlorinated organic com pounds to partition from effluent to solids, wastewater treatm e nt sludge is a significant environm ental concern for the pulp and paper industry.

W a stewater treatm e nt sludge is the largest volum e residual waste stream generated by the pulp and paper industry. Sludge ge neration rates vary widely am ong m ills. For exam ple, bleached kraft m ills surveyed as part of EPA’s 104-Mill Study reported sludge gene ration that ranged from 14 to 140 kg of sludge per ton of pulp (U.S. EP A, 1988). Total sludge generation for these 104 m ills was 2.5 m illion dry m e tric tons per year, or an average of approxim a tely 26,000 dry m e tric tons per year per pl a n t

. Pulpm a king operations are responsible for the bul k of sludge wastes, although treatm ent of paperm aking effluents also genera tes significant sludge volum es. For the

m a jority of pulp and integrated m ills that operate their own wastewater
treatm e nt system s, sludges are generated onsite. A sm all num ber of pulp

m ills, and a m u ch larger proportion of paperm aking establishm ents, discharge effluents to publicly-owned wastewater treatm e nt works (POTW s ).

Potential environm ental hazards from wastewater sludges are associated w ith trace constituents (e.g., chlorinated or ganic com pounds) that partition from the effluent into the sludge. It shoul d be noted, however, that recent trends away from elem ental chlorine bleach ing have r e duced these hazards. A continuing concern is the very high pH (>12.5) of m o st residual wastes. W h en these wastes are disposed of in an aqueous form, t h ey m a y m e et the RCRA definition of a corrosive hazardous waste (U.S. EPA, 2002).

Landfill and surface im poundm ent disposal ar e most often used for
wastewater tre a t me nt sludge, but a significant num ber of m ills dispose of sludge through land application, convers ion to sludge-derived products (e.g.,

Sector Notebook Project 39 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description

com post and anim al bedding), or com bustion for energy recovery (AF&PA, 2002).

Process Inputs and Pollutant Outputs

Kraft c h em ical pulping and chlorine-based (e.g., hypochlorite or chlorine dioxide) bleaching are bot h com m only used and m a y generate significant pollutant outputs. Kraft pulping processes produced approxim a tely 83
pe rcent of total US pulp tonnage during 1998 according to the Am erica n Forest and Paper Association (AF&PA, 1999). Roughly 60 percent of this

am ount is bleached in som e m a nner.

Pollutant outputs from m echanical, sem i -chem i cal, a nd secondary fiber pulping are sm all when com p ared to kraf t chem ical pulping. In the pulp and paper industry, the kraft pulping process is the m o st significant source of air pollutants. The following table and fi gures (Table 13 and Figures 10 and 11) illustrate the process inputs and pollu tant outputs f o r a pulp and paper m ill using kraft chem ic a l pulping and chlorine-based bleaching. The process outlined below produces a large portion of U.S. pulp.

Table 13 presents the process steps, m a terial inputs, and m a jor poll u t a nt outputs (by m e dia) of a kraft pulp m ill practicing traditional chlorine bleachi n g. The following resources are recom m e nded for pollutant production data (e.g., pounds of BOD per ton of pulp produced) f o r those pollutants presented in Table 13:

C Pollution Prevention Technologies for the Bleached Kr af t Segment of the U.S. Pulp and Paper Industry. August 1993. (EPA-600-R-93- 110)

C Develo p m en t D o cu m e n t fo r Proposed Effluent Limitations Guidelines and standards for the Pulp, Paper, and Pape r board Point Source Category . October 1993. (EPA-821-R-93-019)

• Pulp, Paper and Paperboard Industry - Background Information for Proposed Air Emission Standards : M anufacturing Processes at Kraft, Sulfite, Soda, and Semi-Chemical Mills, NESHAP. October 1993. (EPA-453-R-93-050a)

Figure 10 is a process f l ow diagram of the kraf t process, illustrating chem ical pulping, power recovery, and chem ical recovery process inputs and outputs. Figure 11 is a schem a tic of c h a r acteristic air em ission sources from a kraft

m ill.

Sector Notebook Project 40 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description

Table 13: Kraft Chemical Pulped Bleached Paper Production

Process Step Material Inputs Process Outputs M ajor Pollutant Outputs a Pollutant Media

Fiber Furnish Preparation W ood logs Chips Sawdust Furnish chips d irt, grit, fiber, bark Solid

BOD W ater

TSS

Chem ical Pulping Kraft
process Furnish chips B lack liquor (to chem ical recovery system ), pulp (to bleaching/ processing) resins, fatty acids Solid

color W ater

BOD

COD

AOX
VOCs [terpenes, alcohols, phenols,

m e thanol, acetone, chloroform , m e thyl ethyl ketone (MEK)]
VOCs (terpenes, alcohols, phenols,

m e thanol, acetone, chloroform , MEK) Air

Cooking chem icals: sodium sulfide (Na 2 S), NaOH, white liquor (from chem ical recovery) reduced sulfur com pounds (TRS)

organo-chlorine com pounds (e.g., 3,4,5- trichloroguaiacol)

Bleaching b Chem ical pulp B leached pulp d issolved lignin and carbohydrates W a ter

color

COD

AOX
inorganic chlorine com pounds (e.g., chlorate (ClO 3 - )) c

Hypochlorite (HClO, NaOCl, Ca(OCl) 2 )

Chlorine dioxide (ClO 2 ) VOCs (acetone, m e thylene chloride, chloroform , MEK, chlorom e thane, trichloroethane) Air / W a ter

Paperm aking A dditives, Bleached/ Unbleached pulp Paper/paperboard product particulate wastes W a ter
organic com pounds
inorganic dyes

COD

acetone

Sector Notebook Project 41 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description

Table 13: Kraft Chemical Pulped Bleached Paper Production (continued)

Process Step Material Inputs Process Outputs M ajor Pollutant Outputs a Pollutant Media

W a stewater Treatm e nt Facilities Process
wastewaters Treated effluent sludge Solid
VOCs (terpenes, alcohols, phenols,

m e thanol, acetone, chloroform , MEK) Air

BOD W ater

TSS

COD

color
chlorophenolics
VOCs (terpenes, alcohols, phenols,

m e thanol, acetone, chloroform , MEK)

Power Boiler C oal, W ood, Unused furnish Energy bottom ash: incom bustible fibers Solid

SO 2 , NO

x , fly ash, coarse particulates Air

Chemical Recovery System
Evaporators B lack liquor Strong black liquor evaporator noncondensibles (TRS, volatile organic com pounds: alcohols, terpenes, phenols) Air

evaporator condensates (BOD, suspended solids) Wa t e r

Recovery Furnace Strong black liquor Sm elt f ine particulates, TRS, SO 2 , NO

x Air
Energy
Recausticizing S m e lt Regenerated white liquor dregs S olids

Lim e m u d w aste m ud solids W ater, Solid
Slaker grits solids S olid Calcining (Lim e Kiln) Lim e m u d L im e f ine and coarse particulates Air

a Pollutant outputs m a y differ significantly based on m ill pro cesses and m a terial inputs (e.g., wood chip resin content).

b Pollutant list based on Elem ental Chlorine Free (ECF) bleaching technologies.

c Chlorate only significantly produced in m ills w ith high rates of chlorine dioxide use. Sources: EPA, 1993a; EPA, 1993b; and EPA, 1993c.

Sector Notebook Project 42 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description
Figure 10: Kraft Process Flow Diagram

Source: Sm ook, 1992.

Sector Notebook Project 43 Novem b er 2002Pulp and Paper Industry I ndustrial Process Description
Figure 11: Air Pollutant Output from Kraft Process

Source: Sm ook, 1992.

Sector Notebook Project 44 Novem b er 2002Pulp and Paper Industry C hemical Releases and Transfers

IV. CHEMICAL RELEASE AND OTHER WASTE MANAGEMENT PROFILE

This section is designed to provide background inform ation on the pollutant releases that are reported by this indus try in correlation with other industries. The best source of com p arative pollutant release and other waste

m a nagem e nt inform ation is the Toxic Release Inventory (TRI). Pursuant to the Em ergency Planning and Com m unity Right-to-Know Act, TRI includes self -reported f acility release and other waste m a nagem e nt data f o r over 650 toxic chem icals and chem ical categories. Facilities within SIC Codes 10 (except 1011, 1081, and 1094), 12 (ex cept 1241), 20-39, 4911 (lim ited to f acilities that com bust coal and/or oil f o r the purpose of generating electricity for distr i but ion in com m e rce), 4931 (lim ited to facilities that com bust coal and/or oil for the purpose of gene r a t i ng electricity for distribution in

com m e rce), 4939 (lim ited to facilities tha t c o mbust coal and/or oil for the
pur pos e of ge ne r a t i ng e l e c t r i c i t y for di s t r i but i on i n c o m m e rce), 4953 (li m i t e d to facilities regulated under the RCRA Subtitle C, 42 U.S.C. section 6921 et seq .) , 5169, 5171, and 7389 (lim ited to facilities prim arily engaged in solvents recovery services on a contract or fee ba s i s ) have m o re than 10

em ployees, and that m a nufactures, processes or otherwise uses li s t e d chem ical 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

m a nagem e nt quantities (on- and of f

- site ). The inf o rm ation presented within the sector notebooks is derived from the m o st recently available (2000) TRI reporting year (which includes over 650 chem icals and chem ical categories), and focuses prim aril y on the on-site releases reported by each sector. Because TRI requires consistent reporti ng r e gardless of sector, it is an excellent tool for drawing com p arisons across industries. TRI da t a provide the type, am ount and m e dia receptor of each chem ical released or otherwise

m a naged as waste.

Although this sector notebook does not pr esent historical inform ation regarding TRI chem ical releases over tim e, please note that in general, toxic chem ical 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 chem icals to the environm ent from original TRI reporting industries (SIC codes 20-39) decrease d by m o re than 8 percent (644 m illion pounds) between 1999 and 2000 (not including chem icals added and rem o ved from the TRI chem ical list during this period). Reported on-site releases dropped by alm o st 57 percent between 1988 and 2000. Reported transfer s of TRI chem icals to of f

- site locations f o r dis posal increased by alm o st 7 percent (28

m illion pounds) between 1988 and 2000. More detailed inform ation can be obtained from EPA' s annual Toxics Rel ease Inventory Public Data Release Report (which is available through the EPCRA Call Cent er at 800-424-9346), or directly from the Internet at www.epa.gov/tri

.

Sector Notebook Project 45 Novem b er 2002Pulp and Paper Industry C hemical Releases and Transfers

W h erever pos s i bl e , the sector notebooks present TRI data as the prim ary indicator of chem ical release within each industrial ca t e gor y. TRI data provide t h e t ype, am ount and m e dia receptor of each chem ical released or otherwise m a naged as was t e

. Whe n other sources of pollutant release data ha ve be en obtained, these data have been included to augm ent the TRI inf o rm ation.

TRI Data Limitations

Certain lim itations exist regarding TRI data. W ithin som e sectors, (e.g., printing and transportation equipm ent cl eaning) the m a jority of f

a cilities are not subject to TRI reporting either because t h e y do not fall under covered SIC codes, or because they are below the TRI reporting threshold am ounts. However, EPA lowe r e d threshold am ounts for persistent bioaccum u lative toxic (PBT) chem icals starting reporting year 2000. For these sectors, release inform ation from other sources has been included. In addition, m a ny facilities report to TRI under m o re than one SIC code, reflecting the m u ltiple operations carried out onsite whether or not the operations are the f acilities’ prim ary area of bus i ne s s a s reported to the U.S. Census Bureau. Reported chem icals are lim ited to the approxim a tely 650 TRI chem icals and chem ical categories. A portion of the em issions f r om pulp and paper m ills, theref ore, are not captured by TRI. Also, repor t e d r e leases and other waste

m a nagem e nt quantities m a y or m a y 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. W e ighting each pound of release equally does not factor in the relative toxicity of each chemi cal t h at is released. The Agency is in the process of developing an approach to assign toxicological weightings and population exposure levels to each chem ical released so that one can differenti a te between pollutants with signif i cant dif f e ren ces in toxicity. This project, the Risk Screening Environm ental Indicators Model, can be found at http://www.epa.gov/opptintr/rsei/.

As a prelim inary indication of the environm ental im pact of the industry' s

m o st com m only re l e a s ed chem icals, this notebook briefly sum m a rizes the toxicological properties of the top five chem icals (by weight) reported by the organic chem ical industry.

Definitions Associated w i th Section IV Data Tables

General Definitions

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SIC Code -- is the Standard Industrial Classification (SI C ) i s a statistical

c l a s s i fication standard used for all establishm ent-based Federal econom ic statistics

. T h e S I C co d e s facilitate com p arisons between facility and industry data.

TRI Facilities -- are f acilities that are within specif ied SIC codes that have 10 or m o re full-tim e em ployees and are above established threshold am ounts f o r m a nuf acture or process or otherwis e use activities in the course of a calendar year. These facilities are in st andard industrial classification codes 10 (except 1011, 1081, and 1094), 12 (except 1241), 20-39, 4911 (lim ited to f acilities that com bust coal and/or oil f o r the purpose of generating electricity for distributi on i n com m e rce), 4931 (lim ited to facilities that com bust coal and/or oil for the purpose of generating e l ectricity for distribution in

com m e rce), 4939 (lim ited to facilities that combust c o al and/or oil for the
pur pos e of ge ne r a t i ng e l e c t r i c i t y for di s t r i but i on i n c o mme r ce), 4953 (lim ited to facilities regulated under the RCRA Subtitle C, 42 U.S.C. section 6921 et seq .), 5169, 5171, and 7389 (lim ited to f acilities prim arily engaged in solvents recovery services on a contr act or f ee basis), and f e deral f a cilities. Facilities m u st subm it release and other waste m a nagem e nt estim ates f o r all chem icals that are on the EPA' s defined list and are above m a nufacturing or processing or otherwise use thresholds.

Data Table Column Heading Definitions

The following definitions are based upon standard definitions developed by E P A ’ s T o xic Release Inventory Program

. The categories belo w rep r es en t th e possible pollutant destinations that can be reported.

ON-SITE RELEASES -- are an on-site discharge of a toxic chem ical to the environm ent. This includes em issions to the air, discharges to bodies of

w a ter, releases at the f acility to la nd, as well as contained disposal into underground injection wells.

Releases to Air (Point and Fugitive Air Emissions) -- Include all air

em issions from industry activity. Poin t em issions occur through confined air
stream s as found in stacks, ducts, or pipes. Fugitive em issions include losses from equipm ent leaks, or evaporative losses from im poundm ents, spills, or leaks.

Releases to Water (Surface Water Discharges) -- encom p ass any releases going directly to stream s, rivers, lakes, oceans, or other bodies of water. Any estim ates for storm water runoff and non- point losses m u st also be included.

Releases to Land -- includes disposal of toxic chem icals in waste to on-site landfills, land treated or incorporation into soil, surface im poundm ents,

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spills, leaks, or waste piles. These activities m u st occur within the f acility' 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 transf er of toxic chem ic als in wastes to a f acility that is geogr a phically or physically separate from the facility reporting under TRI. The quantities reported represen t a m ovem e nt of the chemical away f r om the reporting f acility. Except f o r of f

- site transf ers f o r disposal, these quantities do not necessarily represent entry of the chemi c al into the environm ent.

Transfers to POTWs -- are waste waters transferred through pipes or sewers to a publicly owned trea tm ents works (POTW )

. Treatm e nt and chem ical

rem oval depend on the chem ical' s na ture and treatm e nt m e thods used. Chem icals not treated or destroyed by the POTW are generally released to surface waters or land filled within the sludge. Metals and m e tal com pounds transferred to POTW s are considered as released to surface water.

Transfers to Recycling -- are sent off-site for the purposes of regenerating or recovering still valuable m a terials. Once these chem icals have been recycled, they m a y be returned to the originating f acility or sold

com m e rcially.

Transfers to Energy Recovery -- are wastes com busted off-site in industrial furnaces for energy recovery. Treatm e nt of a chem ical by incineration is not considered to be energy recovery.

Transfers to Treatment -- are wastes m oved off-sit e for either neutralization, incineration, biological destruct i o n, or physical separation. In som e cases, the chem icals are not de stroyed but prepared for further waste

m a nagem e nt.

Tr ans f e r s to Disposal -- are wastes taken to another f a cility f o r 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 Inventor y (TRI) data from SIC codes 261-263, the pul p a nd paper industry released (to the air, water, or land) and transferred (shipped off-site) a tota l of approxim a tely 263 m illion pounds of

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toxic chem icals during calendar year 2000. 1 This represents approxim a tely 2.5 percent of the total pounds of TRI chem icals released and transferred by all reporting f acilities that year.

Media comparison of TRI releases

The total am ount of TRI toxic chem i cals generated by the pul p a nd pa per industry i s a gr os s profile of the types and relative am ounts of chem ical outputs f r om m ill processes. Additional inf o rm ation which can be related back to possible com p liance requirem e nt s is available f r om the distribution of chem ical releases across specific m e dia within the environm ent. The TRI data requires filers to separate the total re l e a s e s for the pulp and paper industry for air, water, and land releas es. This distribution across m e dia can also be com p ared to the profile of other industry sectors.

The pulp and paper industry releases 66 percent of its total TRI poundage to the air, approxim a tely 22 percent to water and POTW s, and 9 percent is disposed on land (on site and off site). This release profile differs from other TRI industries which average approxim a tely 63 percent to land, 27 percent to air, and 4 percent to water and POTW s. A larger proportion of water releases correlates with the water inte nsive processes of the pulp and paper industry. An average m ill requires 10 m illion gallons of influent water per day and will produce th e corresponding am ount of ef f l uent w a ters. Exa m i n ing the pulp and paper industry' s TRI reported toxic chem icals by chem ical, highlights the likely origins of industry releases (see Table 14).

Air releases can be traced to a variety of sources. Approxim a tely 63 percent

are m e thanol, a by-product of the pulp m a king process. The other m a jor air toxic chem icals, such as chlorinate d com pounds and sulfuric acid, originate in the bleaching stage. Methanol is th e m o st frequently reported chem ical by pulp and paper m ills, and it accounts for approxim a tely 15 percent of the water releases and 97 percent of transfers to POTW s by the industry. O v erall, m e thanol represents rough ly 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 chem icals found in the TR I report. The TRI chem ical released and transferred by the second largest num ber of m ills is am m onia, which is used as a buffer in acid sulfite pulping (Ai r & Wa s t e Managem e nt Association, 1992). In addition, som e TRI chem icals are only reported by a few m ills, suggesting process spe c i fi c needs such as paper finishing or use in wet additives.

1 Unless otherwise indicated, TRI data for SIC codes 261- 263 were used for pulp and paper release and transfer values in this section and the tables therein.
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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)

Chem ical Nam e # Repor ting Chem ical Fugitive Air Point Air Water Discharges Under g r ound Injection Lan d Disposal To tal Releases Avg. Releases Per Facility M e thanol 174 5, 368, 130 105, 189, 904 3, 011, 860 1, 014, 710 114, 584, 624 658, 532
Am m onia 166 514, 616 15, 782, 909 1, 884, 126 11, 939 18, 193, 590 109, 600 Hy dr ochlor ic Acid ( 1995 and after " A cid Aerosols" 137 8, 037 16, 114, 754 10 16, 122, 801 117, 685

Acetaldehy de 125 540, 704 7, 749, 806 177, 092 3, 789 8, 471, 391 67, 771
M a nganese Com pounds 124 1, 932 199, 238 4, 187, 964 8, 733, 410 13, 122, 544 105, 827 Poly cy clic Ar om atic Com pounds[PBT ] 122 57 114, 967 1, 472 2, 458 118, 954 975
For m aldehy de 116 57, 062 1, 865, 446 326, 507 9, 651 2, 258, 666 19, 471 Sulfur ic Acid ( 1994 and after " A cid Aero so ls" On ly 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 Chlor i ne 102 25, 236 449, 437 60, 185 17 534, 875 5, 244 Catechol 99 11 256 17, 493 605 18, 365 186
Bar i um Com pounds 96 13 252, 753 540, 545 2, 351, 605 3, 144, 916 32, 760 Nitr ate Com pounds 87 9, 791, 260 9, 234 9, 800, 494 112, 649 Chlor i ne Dioxide 80 2, 215 701, 625 703, 840 8, 798 Dioxin and Dioxin- L i ke Com pounds[PBT ] 77 55 103 162 320 4

Z i nc Com pounds 77 19 775, 453 324, 492 3, 255, 589 4, 355, 553 56, 566
M e r c ur y Com pounds[PBT ] 7 5 1 2, 149 56 535 2, 741 37
M e thy l E t hy l Ketone 64 98, 368 1, 024, 379 14, 909 5, 013 1, 142, 669 17, 854 Benzo( g, h, i) per y lene[PBT ] 6 3 1
, 060 115 163 1, 338 21
For m ic Acid 54 1, 210 1, 105 92, 178 2, 211 96, 704 1, 791 Chlor o for m 40 1, 076, 881 1, 810, 096 49, 459 12, 285 2, 948, 721 73, 718 Cr esol ( M ixed I s om er s) 32 363 827, 255 1, 097 708 829, 423 25, 919
M e r c ur y [ PBT ] 23 544 8 9 4 646 28 Hy dr ogen Fluor ide 1 7 442, 166 442, 166 26, 010 Vanadium Com pounds 16 6, 102 51, 541 20, 204 635, 418 713, 265 44, 579 Chlor o m e thane 1 5 6 2 492, 139 10 5 492, 216 32, 814 Copper Com pounds 15 8, 343 3, 591 50, 429 62, 363 4, 158 Nickel Com pounds 13 8, 021 3, 337 94, 451 105, 809 8, 139 Cer t ain Gly c ol E t her s 12 17, 410 54, 925 7, 919 2, 602 82, 856 6, 905 Chr o m i um Com pounds 9 3 0 1
, 409 10, 341 32, 731 44, 511 4, 946
E t hy lene Gly c ol 9 6 0 2
, 316 29, 596 5, 810 37, 782 4, 198
T o luene 9 81, 244 638, 734 19 719, 997 80, 000 Xy lene ( M ixed I s om er s) 7 33, 224 41, 507 202 1, 260 76, 193 10, 885 Poly chlor i nated Bipheny ls[PBT ] 7 31 31 4 Sty r ene 5 19, 000 53, 239 104 72, 343 14, 469 C. i. Dir ect Blue 218 5 2 0 1
, 704 1, 724 345
M a nganese 5 11, 163 94, 428 500, 902 606, 493 121, 299
Benzene 3 276, 814 276, 814 92, 271
Dazom e t 3 2, 792 600 3, 392 1, 131 Viny l Acetate 3 12, 303 16, 900 880 30, 083 10, 028 Bipheny l 3 117, 000 117, 000 39, 000 1, 2, 4- tr im ethy lbenzene 3 20, 920 13, 396 180 10 34, 506 11, 502 Diethanolam ine 3 549 6, 505 974 8, 028 2, 676
N- buty l Alcohol 3 29, 759 61, 970 10, 943 102, 672 34, 224 Nitr ic Acid 2 1 0 1
, 310 1, 320 660 Decabrom odiphenyl Oxide 2 5 1 ,100 1,105 552 Antim ony 2 350 350 175
L ead Com pounds[PBT ] 2 1, 698 796 2, 494 1, 247
N- hexane 2 4
, 100 46, 100 50, 200 25, 100
Ar senic Com pounds 2 360 6 366 183 Lead[ P BT] 1 Antim ony Com pounds 1

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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)

Chem ical Nam e # Repor ting Chem ical Fugitive Air Point Air Water Discharges Under g r ound Injection Lan d Disposal To tal Releases Avg. Releases Per Facility Chlordane[ PBT] 1
M a leic Anhy dr ide 1 200 210 410 410
E t hy lbenzene 1 290 90 380 380 Potassium Dim e thy l dithiocar bam a te 1 1 9 10, 394 10, 413 10, 413 O- xy lene 1 1 5 46, 430 5 46, 450 46, 450 Diisocy a nates 1 750 750 750 Ozone 1 102, 763 102, 763 102, 763 Naphthalene 1 8 3 17, 000 1 4
, 800 21, 884 21, 884 Copper 1
M e thy l M e thacr y l ate 1 750 1, 154 1, 904 1, 904 Acr y lic Acid 1 1 280 281 281
T r ichlor oethy l ene 1 Dichlor o m e thane 1 6 33, 316 1 33, 323 33, 323 Poly chlor i nated Alkanes 1
Bar i um 1 250 250 500 500
M i xtur e 1 1 4 5 5 268** 7, 940, 291 166, 187, 814 20, 684, 970 0 16, 749, 220 211, 562, 315 789, 411 [ P BT] Persistent, Bioaccum u lative, and Toxic * Refer to Section III for a discussion of the TRI data and its lim itations, m e thodology used to obtain this data, definitions of the colum n headings, and the def i nition of persistant, bi oaccum u lative, and toxic chem icals. **Total num ber of facilities (not chem ical repor ts) reporting to TRI in this industry sector.

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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)

Chem ical Nam e # Repor ting Chem ical POTW Transf ers Disposal Transf ers Recycling Transf ers Treatm e nt Transf ers En erg y Recover y To tal Transf ers Avg Transf ers Per Facility M e thanol 174 36, 098, 617 144, 671 24, 058 6, 993, 725 13, 736 43, 274, 807 248, 706 Am m onia 166 56, 000 79, 785 2, 966 138, 751 836 Hy dr ochlor ic Acid ( 1995 and after " A cid Aerosols" 137

Acetaldehy de 125 111, 435 757 25 10, 100 122, 317 979 M a nganese Com pounds 124 204, 150 2, 977, 098 152, 646 3, 333, 894 26, 886 Poly cy clic Ar om atic Com pounds[PBT ] 122 1, 224 1, 257 52 5 129 2, 667 22 For m aldehy de 116 116, 817 18, 814 63 53, 825 279 189, 798 1, 636 Sulfur ic Acid ( 1994 and after "Acid Aero so ls" On ly 113 5 5 0

Phenol 105 16, 753 2, 372 15 4, 983 2, 529 26, 652 254 Chlor i ne 102 14, 443 1 14, 444 142 Catechol 99 66, 175 602 3 630 2, 250 69, 660 704 Bar i um Com pounds 96 41, 058 1, 316, 911 86, 502 1, 444, 471 15, 047 Nitr ate Com pounds 87 40, 310 38, 220 118, 370 196, 900 2, 263 Chlor i ne Dioxide 80 Dioxin and Dioxin- L i ke Com pounds[PBT ] 7 7 2 1 101 6 1 0 138 2 Z i nc Com pounds 77 30, 256 1, 129, 573 72, 525 1, 232, 354 16, 005 M e r c ur y Com pounds[PBT ] 7 5 1 4 23, 862 95 23, 971 320 M e thy l E t hy l Ketone 64 56, 874 680 4, 350 20, 062 38, 121 120, 087 1, 876 Benzo( g, h, i) per y lene[PBT ] 6 3 7 101 3 2 2 115 2 For m ic Acid 54 6, 334 251 6, 585 122 Chlor o for m 40 155, 257 8, 630 308 164, 195 4, 105 Cr esol ( M ixed I s om er s) 32 4, 448 394 1, 600 6, 442 201 M e r c ur y [ PBT ] 23 485 485 21 Hy dr ogen Fluor ide 1 7 Vanadium Com pounds 16 1, 400 88, 540 11, 463 101, 403 6, 338 Chlor o m e thane 1 5 306 306 20 Copper Com pounds 15 1, 515 64, 245 65, 760 4, 384 Nickel Com pounds 13 2, 120 91, 928 180 94, 228 7, 248 Cer t ain Gly c ol E t her s 12 815 815 68 Chr o m i um Com pounds 9 1
, 351 71, 901 1, 000 74, 252 8, 250 E t hy lene Gly c ol 9 24, 658 2, 810 84, 004 111, 472 12, 386 T o luene 9 220 383, 822 384, 042 42, 671 Xy lene ( M ixed I s om er s) 7 5 10, 291 10, 296 1, 471 Poly chlor i nated Bipheny ls[PBT ] 7 207 57 264 38 Sty r ene 5 160 750 910 182 C. i. Dir ect Blue 218 5 1
, 984 3, 848 1, 065 6, 897 1, 379 M a nganese 5 38, 661 38, 661 7, 732 Benzene 3 Dazom e t 3 13, 535 13, 535 4, 512 Viny l Acetate 3 19 19 6 Bipheny l 3 1, 2, 4- tr im ethy lbenzene 3 4 4 1 Diethanolam ine 3 36, 070 483 715 37, 268 12, 423 N- buty l Alcohol 3 Nitric Acid 2 Decabrom odiphenyl Ox ide 2 26,600 26,600 13,300 Antim ony 2 251 6, 650 6, 901 3, 450 L ead Com pounds[PBT ] 2 127, 400 127, 400 63, 700 N- hexane 2 11, 000 11, 000 5, 500 Ar senic Com pounds 2 120 24, 200 24, 320 12, 160 L ead[PBT ] 1 350 350 350 Antim ony Com pounds 1 2
, 200 2, 200 2, 200 Chlordane[ PBT] 1 5 0 5 0 5 0 Maleic Anhydride 1 E t hy lbenzene 1 840 840 840 Potassium Dim e thyldithiocarbam a te 1 O- xy lene 1 Diisocyanates 1 Ozone 1 Naphthalene 1 Copper 1 675 675 675

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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)

Chem ical Nam e # Repor ting Chem ical POTW Transf ers Disposal Transf ers Recycling Transf ers Treatm e nt Transf ers En erg y Recover y To tal Transf ers Avg Transf ers Per Facility M e thy l M e thacr y l ate 1 750 750 750 Acrylic Acid 1 T r ichlor oethy l ene 1 4, 985 4, 985 4, 985 Dichlorom e thane 1 Poly chlor i nated Alkanes 1 24, 000 24, 000 24, 000 Bar i um 1 5
, 100 5, 100 5, 100 M i xtur e 1 268** 37, 103, 508 6, 306, 166 354, 926 7, 316, 423 463, 018 51, 544, 041 192, 328 [ P BT] Persistent, Bioaccum u lative, and Toxic * Refer to Section III for a discussion of the TRI data and its lim itations, m e thodology used to obtain this data, definitions of the colum n headings, and the def i nition of persistant, bi oaccum u lative, and toxic chem icals. **Total num ber of facilities (not chem ical repor ts) reporting to TRI in this industry sector.

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The TRI database contains a detailed com p ilation of self -reported, facilitys p e c i f i c c h e m ic a l r e le a s e s

. T h e to p r e p o r tin g f a c i litie s f o r

th is s e c t o ra r e 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 W estvaco Corporation - Covington, VA 5,066,296 I nternational Paper - Mansfield, LA 4,472,550 I nternational Paper Com p any Cam d en Facility - Cam d en, AR 3,842,484 I nternational Paper - Bleachboard De partm e nt - Riegelwood, NC 3,619,809 G eorgia Pacific Corporation Port Hudson Operations - Zachary, LA 3,292,540 S m u rfit Stone Container Corporation - Missoula, MT 3,133,396 G reat Southern Paper Co - Cedar Springs, GA 3,125,666 S tora Enso North Am erica Corporation - W i sconsin Rapids, W I 3,095,151 W eyerhaeuser Com p any - Valliant, OK 3,041,630 International Paper Georgeto wn Mill - Georgetown, SC 2,967,101 Source: 2000 Toxics Release Inventory Database

* Being included in this list does not m ean that the release is associated with non-com p liance with environm ental laws.

IV.B. Summary of Selected Chemicals Released

The following is a synopsis of current scie ntific toxicity and fate inform ation f o r the top chem icals (by weight) that f acilities within this sector self

reported as released to the environm ent based upon 2000 TRI data. Because this section is based upon self-reported release data, it does not attem p t to provide i n form ation on m a nagem e nt practices em ployed by the sector to reduce the r e leases of these chem icals. Inform ation regarding pollutant release reductions over tim e m a y be available from EPA’s TRI program , or directly from the industrial trade associ ations that are listed in Section IX of this docum ent. Since these descriptions are cursory, please consul t the sources referenced below for a m o re detailed description of both the chem icals described in this section, a nd the chem icals that appear on the full list of TRI chem icals appearing in Section IV.A.

The brief descriptions provided below were ta ken from the Hazardous Substan c e s Da t a Bank (HSDB), accessed via TOXNET. TOXNET is a

com puter system run by the Na t i onal Li brary of Medicine. It includes a

num ber of toxicological databases m a naged by EPA, National Cancer

Sector Notebook Project 54 Novem b er 2002Pulp and Paper Industry C hemical Releases and Transfers

Institute, and the National Institute f o r Occupational Saf e ty and Health. 2 HSDB contains chem ical-specific inform ation on ma nufacturing and use, chem ical and physical properties, safety and handling, toxicity and bi om edical effects, pharm acology, environm ental fate and exposure potential, exposure standards and regulations, m onitoring and analysis

m e thods, and additional references. The inform ation contained be l o w is based upon exposure assum p tions that have been conducted using standard scientific procedures. The effects listed below m u st be taken i n c ont e x t of these exposure assum p tions that are mo r e ful l y explained within the full chem ical profiles in HSDB. For m o re inform ation 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 g a s t ro in tes t inal tract and the respiratory tract, and is toxic to huma n s in m oderate to high doses. In the body, m e thanol is converted into form aldehyde and form ic acid. Methanol is excreted as form ic acid. Observ ed toxi c e ffe c t s at high dose levels generally include central nervous syst em dam a ge and blindness. Long-term exposure to high levels of m e thanol via inhalation cause liver and blood dam a ge in anim als.

Ecologically, m e thanol is expected to ha ve low toxicity to aquatic o r g a n i sm s. Concentrations lethal to half the or ganism s of a test population are expected to exceed one m illigram of m e thanol pe r liter of w a ter. Methanol is not likely to persist in water or to bioaccum u late in aquatic organism s.

Carcinogenicity. There is currently no evidence to sugge s t t h a t this chem ical is carcinogenic.

Envi ronmental Fate. Liquid m e thanol is likely to evaporate when left exposed. Methanol reacts in air to produce form aldehyde which contributes to the form ation of air pollutants. In the atm o sphere it can react with other
atm o spheric chem icals or be washed out by rain. Methanol i s r e a d i l y degraded by m i croorganism s in soils and surface waters.

Physical Properties. Methanol is highly flam m a ble.

2 Databases included in TOXNET are: CCRIS (Chem i cal Carcinogenesis Research Inform ation System ), DART (Developm ental and Reproductive Toxicity Database), DB IR (Directory of Biotechnology Inform ation Resources), EMICBACK (Environm ental Mutagen Inform ation Center Backfile), GENE-TOX (Genetic Toxicology), HSDB (Hazardous Substances Data Bank), IRIS (Integrated Risk Inform ation System ), RTECS (Registry of Toxic Effects of Chem ical Substances), and TRI (Toxic Chem ical Release Inventory).
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Ammonia (CAS: 7664-41-7)

Toxicity. Anhydrous am m onia is irritating to the skin, eyes, nose, throat, and upper respiratory system

. Ecologically, am m onia is a source of nitrogen (an essential elem ent for aquati c plant growth), and m a y therefore contribute to eutrophication of standing or slow-m oving surface water
, particularly in nitrogen-lim ited waters such as the Chesapeake Bay. I n addition, aqueous am m onia is

m oderately toxic to aquatic organism s.

Carcinogenicity. There is curre nt l y no evidence to suggest that this chem ical is carcinogenic.

Environmental Fate. Ammonia com b ines with sulf ate ions in the
atm o sphere and is washed out by r a i n fa l l
, resulting in rapid return of

am m onia to the soil and surface waters.

Am m onia is a central com pound in the environm ental cycling of nitrogen. Am m onia in lakes, rivers, and stream s is converted to nitrate.

Physical Properties. Am m onia is a corrosive and severel y i r ritating gas with a pungent odor.

Hydrochloric Acid (CAS: 7647-01-1)

Toxicity. Hydrochloric acid is prim arily a concern in its aerosol form

. Acid aerosols have been im plicated in causi ng and exacerbating a variety of respiratory ailm ents. Derm al exposur e and ingestion of highly concentrated hydrochloric acid can result in corrosivity.

Ecologically, accidental releases of so lution form s of hydrochloric acid m a y 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 evidenc e t o s uggest that this chem ical is carcinogenic.

Environmental Fate. Releases of hydrochloric acid to surface wa ters and soils will be neutralized to an extent due to the buf f e ring capacities of both system s. The extent of these reactions will depend on the characteristics of the specific environm ent.

Physical Properties. Concentrated hydrochloric acid is highly corrosive.

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Manganese Compounds

Toxicity. Manganese is an essential nut r i e nt for m o st plants and anim als. However, at high concentrations can pr oduce an irreversible syndrom e

resem b ling Parkinson' s disease.

Carcinogenicity. There is currently no evidence to suggest that m a nganese chem icals are carcinogenic.

Environmental Fate. As ions or insoluble soli ds , m o st m a nganese

com pounds are not expected to volatili ze from water and m o ist soil surfaces. M a nganese com pounds released into the am bient atm o sphere are expe c t e d to exist in the particulate phase. In the particulate phase, m a nganese

com pounds m a y be rem oved fr om t h e air by wet and dry deposition. Manganese com pounds do not bioconcentrate in hum ans and anim als.

Sulfuric Acid (CAS: 7664-93-9)

Toxicity. Concentrated sulfuric acid is corrosive. In its aerosol form
, sulfuric acid has been im plicated in causing and exacerbating a variety of respiratory ailm ents.

Ecologically, accidental releases of solution form s of sulfuric acid m a y adversely affect aquatic life by inducing a transient lowering of the pH (i.e., increasing the acidity) of surface w a ters. In addition, sulf uric acid in its aerosol form is also a com ponent of acid rain. Acid rain can cause serious dam a ge to crops and forests.

Carcinogenicity. The r e i s c u rrently no evidence to suggest that this chem ical is carcinogenic.

Environmental Fate. Releases of sulfuric aci d to surf ace waters and soils will be neutralized to an extent due to the buffering capacities of both system s. The extent of these reactions will depend on the characteristics of the specific environm ent.

In the atm o sphere, aeros ol form s of sulfuric acid contribute to acid rain. These aerosol form s can travel large distances from the poi nt of release before the acid is deposited on land and surface waters in the form of rain.

IV.C. Other Data Sources

The toxic chem ical release data obtained from TRI captures the vast m a jority of

f

acilities in the pulp and paper indust ry. It also allows f o r a com p arison across years and industry sectors. Reported chem icals are lim ited, however,

Sector Notebook Project 57 Novem b er 2002Pulp and Paper Industry C hemical Releases and Transfers
to the approxim a tely 650 required by TR I. Som e pulp and paper em issions

m a y not be captured by TRI. The EPA Office of Air Quality, Planning, and Standards ha s c o mpiled air pollutant em ission factors for determ ining the total air em issions of priority pollutants (e.g., total hydrocarbons, SO

x , NO

x , CO, particulates, etc.) from m a ny sources.

The EPA Office of Air’s Aerom e tric Inf o rm ation Retrieval System (AIRS) contains a wide range of inform ation related to stationary sources of air pollution, i n c l udi ng the em issions of a num ber of air pollutants which m a y be of conc e r n wi t h i n a particular industry. W ith the exception of volatile

or ga ni c com pounds (VOCs), there is little overlap with the TRI chem ical s reported above. Table 17 sum m a rizes re leases in 2001 of volatile or ganic

com pounds (VOCs), nitrogen oxides (NO

x ), carbon m onoxide (CO), sulfur dioxide (SO 2 ), and particulate m a tter of 10 m i crons or less (PM10).

Table 17: Air Pollutant Releases by Industry Sector (tons/year) Industry Sector CO NO 2 PM10 PM25 SO 2 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 Mi ning 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
Lum b er and W ood Products 142, 955 37,313 57,009 38,337 9,189 100,761
W ood 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 Chem icals 176, 697 94,938 19,549 12,586 201,994 43,563
Plastic Resins and Man-m a de Fibers 28,890 56,946 5,493 4,155 71,815 83,363
Pharm aceuticals 2 ,662 14, 676 2,273 1,455 17,132 13,407 Organic Chem icals 128,454 166,398 34,637 16,900 102,461 159,319 Agricultural Chem icals 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 Concre te 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 Com puters 22,105 6,428 3,184 2,349 6,882 27,453
Motor Vehicle Assem b ly 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
W a ter Transportation 8 3 153 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 a nd Radiation, AIRS Database, 2001.

Sector Notebook Project 58 Novem b er 2002Pulp and Paper Industry C hemical Releases and Transfers

IV.D. Comparison of Toxic Release Inventory Betw een Selected Industries

The following inform ation is presented as a com p arison of pollutant release and transfer data across industrial categories. It is provided to give a general sense as to the relative scale of rel eases and t r ansfers 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 i n c l uded in this project, and thus cannot be used to draw conclusi ons regarding the t o tal release and transfer am ounts that are reported to TRI. Sim ilar inform ation is available within the annual TRI Public Data Release Report.

Figure 12 is a graphical representation of a sum m a ry of the 2000 TRI data for the Pulp and Paper industry and the other sector s profiled in separate notebooks. The bar graph presents the total TRI releases and total transfers on the lef t axis and the triangle points show the average releases per f a cility
on t h e r i ght axis. Industry sectors are presented in the order of increasing total TRI releases. The graph is base d on the data shown in Table 17 and is

m eant to facilitat e c o mparisons betw een the relative am ounts of releases, transf ers, and releases per f acility both within and between these sectors. The reader shoul d not e , however, that differences in the proportion of facilities captured by TRI exist between industry sect ors. This can be a factor of poor SIC m a tching and relative dif f e rences in the num ber of f

acilities reporting to TRI from the va r i ous 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 prim ary SIC codes.

Sector Notebook Project 59 Novem b er 2002Pulp and Paper Industry C hemical Releases and Transfers
Figure 12: 2000 Summary of TRI Releases and Transfers by Industry

0 50 10 0 15 0 20 0 25 0 30 0 35 0 40 0 45 0

SI C R a n g eTotal Pounds (millions)

T o t a l R e le a s e s To t a l T r a n s f e r s10261-2632524222872862833, 28342821, 2823, 2824281271-27834333, 334332, 336331323029114911, 4933731372, 37637136

Key to Standard Industrial Classification (SIC) Codes

SIC Range I ndustry Sector SIC Range I ndus try Sector SIC Range I ndustry Sector

02 Agr i cultur a l Cr ops, For e str y 281 I nor ganic Chem icals 333, 334 Nonfer r ous M e tals

01, 08 Agr i cultur a l L i vestock 2821, 2823, 2824 Plastic Resins and M a n- m a de Fibers 34 Fabricated Metals

10 Metal Mining 2833, 2834 Pharm aceutical s 3 6 E lectronics and Com puters

13 Oil and Gas E x tr action 286 Or ganic Chem icals 371 M o tor Vehicle Assem b ly

14 Non- Fuel, Non- M e tal M i ning 287 Agr i cultur a l Chem icals 372, 376 Aer o space

22 Textiles 2911 Petroleum Refini ng 3731 Shipbuilding and Repair

24 L u m b er and W ood Pr oducts 30 Rubber and Plastic 40, 42, 46, 4922- 4925, 4932 Gr ound T r anspor tation

25 Fur n itur e and Fixtur es 32 Stone, Clay
, Gl ass and Concr e te 44 W a ter T r anspor tation

261- 263 Pulp and Paper 331 I r on and Steel 45 Air T r anspor tation

271- 278 Pr inting 332, 336 M e tal Casting 4911, 493 Fossil Fuel E l ectr i c Power Gener a tion

7216 Dr y cleaning

Sector Notebook Project 60 Novem b er 2002Pulp and Paper Industry C hemical Releases and TransfersAverage Releases+ Transfers perFacility (pounds)(million lbs.)(pounds)(million lbs.)(pounds)(million lbs.)Industrysectorcurrentlynot subject to TRIreporting.Industrysectorcurrentlynot subject to TRIreporting.695,731Industrysectorcurrentlynot subject to TRIreporting.Industrysectorcurrentlynot subject to TRIreporting.32,54533,80238,517112,15172,119110,006117,673274,041128,210109,34437,92148,45751,249228,31749,930312,59846,75094,24762,51454,95132,200Industrysectorcurrentlynot subject to TRIreporting.Industrysectorcurrentlynot subject to TRIreporting.Industrysectorcurrentlynot subject to TRIreporting.87,684Industrysectorcurrentlynot subject to TRIreporting.2,830,957456,285Total Releases+Transfers404.917.043.726.6263.170.5220.0334.5214.0593.6108.3114.7171.298.8453.292.3314.2330.3142.7179.735.46.4466.74,701.910,715.4Table 18: Toxics Release Inventory Data for Selected IndustriesTRITransfersAve. Transfersper Facility4,89415,5275,49719,60521,97121,97145,92172,139254,76680,83330,41711,97320,09929,389164,98140,849128,25838,99188,27943,01946,67412,31614,6471,213,016176,277TotalTransfers2.88.17.113.551.551.591.8205.1199.0374.330.136.271.056.7327.575.5128.9275.5133.7123.730.12.578.02,374.14,139.7TRI ReleasesAve. Releasesper Facility690,83717,01828,30518,91290,18050,14864,08545,53419,27547,37778,92725,94828,35821,86063,3369,081184,3407,7595,96819,4958,27719,88473,0371,617,941280,007TotalReleases402.18.936.613.0211.619.0128.2129.515.1219.478.178.5100.242.1125.716.8185.354.89.056.05.34.0388.72,327.86,575.7# TRIFacilities581944102802681633433691514671721621,1544843254471812,047419622184396139,55223,484SICRange201,08101314222425261,262,263271-2782812821,2823,28242833, 283428628729113032331332,336333,3343436371372,376373140,42,46,4922-4925,493244454911,4937216NANAIndustry SectorAgricultural Crops,ForestryAgricultural LivestockMetal MiningOil and Gas ExtractionNon-Fuel,NonMetal MiningTextilesLumberand Wood ProductsFurnitureand FixturesPulp and PaperPrintingInorganic ChemicalsPlastic Resins and Manmade FibersPharmaceuticalsOrganic ChemicalsAgricultural ChemicalsPetroleumRefiningRubberand PlasticStone,Clay,Glass and ConcreteIron and SteelMetal CastingNonferrous MetalsFabricated MetalsElectronics and ComputersMotorVehicle AssemblyAerospaceShipbuilding and RepairGround TransportationWaterTransportationAirTransportationFossil Fuel Electric PowerGenerationDrycleaningSector NotebookTotal2000 TRI TotalSource:US EPA Toxics ReleaseInventory Database, 2000.

Sector Notebook Project 61 Novem b er 2002Pulp and Paper Industry P ollution Prevention

V. POLLUTION PREVENTION OPPORTUNITIES

The best way to reduce pollution is to pr event it in the first place. Industries have creatively im plem ent e d pollution prevention techniques that im prove efficiency and increase profits while at t h e sam e tim e m i nim i zing envi r onme n tal im pacts. This can be done in m a ny ways such as reducing

m a terial inputs, re-engineering processes to reuse by-products, im proving

m a n a gem e nt practices, and em ploying substitution of toxic chem icals. Som e

sm aller f acilities are able to actually ge t below regulatory thresholds just by reducing pollutant releases through a ggressive pollution prevention policies.

In order to encourage t h ese approaches, this section provides both general and com p any-specific descriptions of som e pollution prevention a dva nces that have been im plemented within the pulp and paper industry. W h ile the list is not exhaustive, it does provide core inform ation that can be used as the starting point f o r f acilities interest ed in beginning th eir own pollution prevention projects. W h en possible, this section provides inform ation from real activities that can, or are being im plem ented by this sector -- including a discussion of associated costs, tim e fram es, and expected rates of return. This section provides sum m a ry inform ation f r om activities that m a y be, or are being im plem ented by this sector. W h en possible, i n for m ation 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 f acilities that f a ll within this sector. Facility-specif i c conditions m u st be carefully consid ered when pollution prevention options are evaluated, and the full im pacts of t h e change m u st exam ine how each option affects air, land and water pollutant releases.

Pollution Prevention Opportunities for the Pulp and Paper Industry

The chem ical recovery system s used in chem ical pulping processes are an

exam ple of pollution prevention technologies that have evolved alongsi d e pr oc ess technologies. An efficient chem ical recovery system is a cruc i a l

c o m ponent of chem ical pulping m ill operation: the chem ical recovery process regenerates process chem icals, reducing natural resource usage and associated costs, as w e ll as discharges to the environm ent and producing
energy. Many recent pollution preventi on effor t s i n the pulp and paper industry have focused on reducing the releases of toxics, in particular, chlorinated com pounds. Pollution prev ention techniques have proven to be

m o re effective in controlling these pollutants than conventional control and
treatm e nt technologies. Most conventional, e nd-of-pipe treatm ent technologies a r e not e ffe c t i v e i n de s t r oying m a ny chlorinated com pounds and often m e rel y transfer the pollutants to another environm ental m e dium

. Efforts to prevent chlorinat e d releases have, therefore, focused on source reduction and m a terial substitution techniques such as defoam ers, bleaching chem ical or wood chip substitution to reduce the industry' s use and releases

Sector Notebook Project 62 Novem b er 2002Pulp and Paper Industry P ollution Prevention

of

chlorinated com pounds. S u ch source reduction ef f o rts and m a terial substitutions usually require substantial changes in the production process. In addition to the m a jor proc e s s changes aim e d at reducing toxics releases, the industry is im plem enting a num ber of pollution prevention techniques to reduce water use and pollutant releases (BOD, COD, and TSS) such as: dry debarking, recycling of log flum e wa ter, im proved spill control, bleach f iltrate recycle, closed screen rooms, and improved storm water m a nagem e nt. The pulp and paper industry has also worked to increase the am ount of secondary and recycled fi be r s used for the pulping process. According to industry sources, the pulp and paper industry set and m e t a 1995 goal of 40 percent recycling and reuse of all paper consum ed in the U.S. Currently, the industry has set a new goal of recovering 50 percent of all paper consum ed in the U.S. for recycle and reuse. Th ese figures should be com p ared with the utilization rate of secondary f i bers (secondary f i bers as a percentage of the total fibers used to m a ke pulp) which is at approxi ma t e l y 37 percent and is clim bing slowly (AF&PA, 1999). Current secondar y 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 equipm ent l i f etim es, m ajor processchanging pollution prevention opportunities are expensive and require long tim e periods to im plem ent. The pul p and paper industry is a dynam i c one, however, that constantly m a kes process changes and m a terial substitutions to i n crease productivity and cut costs. The trend towards m a terials substitutions is ref l ected in an increasing dem a nd f o r alternative pulping and bleaching chem icals and in the partic ipation of m a ny facilities in voluntary environm ental program s (see Section VIII).

O n e of the f actors that is driving the industry tow a rds pollution prevention

m

u ch m o re rapidly is the integrated NESHAP and ef f l uent lim itation gui delines for the pulp and paper industry. (See Section VI.B. for a de s c r i pt i on of t h i s “ c l us t e r r

u l e .” ) The s e r e gulations were developed togethe r in part to reduce the costs of com p liance, to em phasize the m u lti-m e dia nature of pollution control, and to prom ote pollution prevention. Many of the technology-based effluent lim itation gui delines for the control of toxic releases consist of process changes that substitute chlorine dioxide for elem ental chlor i ne and that com p lete ly elim inate elem ental chlorine in bleaching processes. The NESHAP standards also allow Hazardous Air Pollutant (HAP) r e ductions through recy cling of wastewater stream s to a process unit and routing pulping em issions to a boiler, lim e kiln, or recovery furnace.

Brief descriptions of som e of the pollution prevention techniques found to be ef

f ective at pulp and paper f acilities are provided below. For m o re detail on the pollution prevention options listed below and for descript i o ns of additional alternative pulping and bleachi ng processes refer to the Office of

Sector Notebook Project 63 Novem b er 2002Pulp and Paper Industry P ollution Prevention

Pollution Preve n tion and Toxics' 1993 report, Pollution Prevention Technologies for the Bleached Kraft Segment of the U.S. Pulp and Paper Industry a nd ot he r pol l u t i on prevention/waste m i nim i zation docum ents l i s t e d in Resource Materials section. It s hould be noted that although m a ny of the pollution prevention opportunities listed below a r e prim arily aim e d at reducing toxics releases, the process changes can often lead to reductions in the conventional pollutants such as BOD 5 and TSS as well as COD, AOX, and contribute to reduced water use, sludge vol u me s generated, and air

em issions.

Extended Delignification. Extended delignification further reduces t h e lignin content of the pulp before it m oves to the bleach plant. Because the

am ount of bleaching chem icals required to achieve a certain paper brightness is proportional to the am ount of lignin rem a ining in the pulp after the pulping process, extended delignification can reduce the am ounts of bleaching chem icals needed. A num ber of differe nt extended delignification processes have been developed. These proce sses involve: increasing the cooking tim e; adding the cooking chem icals at several points thr oughout the cooking process; regulating the cooking tem p eratures; and carefully controlling the concentration of hydrogen sulfide ions and dissolved lignin. Im portantly, the
pr ocess changes do not degrade the cellulose which would norm a l l y

accom p any increased cooking tim e. Ex tended delignification processes have been developed for both batch and con tinuous pulping processes. The lignin
conte n t of t h e brownstock pulp has been reduced by between 20 and 50 percent with no losses in pulp yield or s t r e ngth using such processes. In consequence, chlorinated com pounds generated during bleaching are reduced in approxim a te proportion to reductions in the brownstock lignin content. In addition, the sam e changes have resu lted in significant reductions in BOD 5 , COD and color. One s t udy dem onstrat ed a 29 percent decrease in BOD 5 resulting f r om an extended delignif i cation process. Facility energy requirem e nts have been shown t o increase slightly with extended delignification. However, off-site power requirem e nts (associated with decreased chem ical use) have been estim ated to m o re than offset the on-site increases.

Oxyge n Delignification. Oxygen delignification also reduces the lignin content in the pulp. The process i nvolves the addition of an oxygen reactor between the kraft pulping stages and th e bleach plant. The brownstock pulp from the di ge s t e r is first washed and then m i xed with sodium hydroxide or oxidized cooking liquor. The pulp is fl uffed, deposited in the oxygen reactor,
steam heated, and injected wi t h gaseous oxygen wherein it undergoes oxidative de l i g nification. The pulp is then washed again to rem ove the dissolved lignin before m oving t o the bleaching plant. Oxygen delignification can reduce the l i gnin content in the pulp by as m u ch as 50 percent resulting in a potentially sim ila r reduction in the use of chlorinated bleaching chem icals and chlorinated co m pound pollutants. The process can

Sector Notebook Project 64 Novem b er 2002Pulp and Paper Industry P ollution Prevention

be used in com b ination with other process m odifications that can com p letely elim inate the need for chlorine-based bleaching agents. In addition, unlike bleach plant filtrate, the e ffl ue nt from the oxygen reactor can be recycled through the pulp m ill recovery cycl e , 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 ge ne r a tion. Facility
energy requirem e nts have been show n to increase w ith oxygen delignification, however, the decrease in off-site power requireme nts (associated with decreased chem ical us e) have been estim ated to exceed the on-site increases resulting in a decrease in overall energy requirem e nts. Also, the recovered energy and reduced chem ical use offset the cost.

Oz one Delignification. As a result of a considerable research effort, ozone delignification (ozone bleaching) is now being used in a lim ited num ber of pulp m ills. The technology has the potential to elim inate the need for chlorine in the bleaching process. Ozone delignification is perform e d using processes and equipm ent sim ilar to th at of oxygen delignification. The ozone process, however, m u st take place at a very low pH (1.0 to 2.0), requiring the addition of sulfuric acid to the pulp prio r to the ozonation. In addition to low pH, a num ber of process conditions are critical for ozone del i gni fication: organic m a terials m u st be alm o st com p letely washed out of the brownstock pulp; tem p eratures m u st stay at about 20 / C; and ozone reactive m e tals m u st be rem oved prior to the ozonation stage. Oxygen del i gni fication and/or extende d de l i gnification processes are considered a prerequisite for successful ozone bleaching. W h en used in com b ination, the two processes can result in a high quality bright pulp that requires little or no chlorine or chlorine dioxide bleaching. Overall em issions from the com b ination of the oxygen and ozone processes are substantially lower than c onventional processes because effluents from each st age can be recycled. Pilot system s consisting of ozone delignification i n c o mbination with oxygen delignification and oxygen extraction have shown reductions in BOD 5 of 62 percent, COD of 53 percent, color of 88 percent, and organic chlorine

com pounds of 98 percent. However, ozone is unstable and will decom pose to m o lecular oxygen, thus ozone m u st be ge ne r a ted on-site and fed im m e diately to the pulp reactor. Ozone generation system s are com p lex and account for a high percentage of the total costs. Facility energy use wi ll increase due to the on-site production of ozone, however, this energy will be offset by the energy that woul d nor ma lly be used to produce chlorine and chlorine dioxide.

Anthraquinone Catalysis. The addition of anthraquinone (a chem ical catalyst produced from coal t a r ) t o t h e pulping liquor has been shown to speed up the kraft pulping reaction and increase yield by protecting cellulose fibers from degradation. The anthra quinone accelerates the fragm e ntation of lignin, allowing it to be broken down m o re quickly by the pulping chem icals. Thi s l o wers the am ount of lignin in the prechlorination pulp, thus reducing

Sector Notebook Project 65 Novem b er 2002Pulp and Paper Industry P ollution Prevention

the am ount of bleaching chem icals needed. Anthraquinone catalysts are increasingly used in com b ination w ith oxygen delignification and extended delignif i cation to overcom e boiler capacity bottlenecks arising f r om these delignification processes.

Black Liquor Spill Control and Prevention. The m i xture of dissol v ed 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, a nd or ga nic com pounds. Spills of black liquor can result from overflows, leaks from proce s s e quipm ent, or from deliberate dum ping by operators to avoid a m o re serious accident. Spills of black liquor can have im pacts on receiving waters, are a source of air em issions, and can shock the

m i crobial action of wastewater treatm e nt system s. Black liquor losses also result in the loss of the chem ical and heat value of the m a terial. System s needed to control black liquor sp ills are a com b ina tion of good design, engineering, and, m o st im portantly, opera tor training. A few elem ents of an effe c tive spill control system include: physical isolation of pieces of equipm ent; f l oor drainage system s that allow spills to be collected; backup black liquor storage capacity; sensors that provide im m e diate warni ng of potential or actual spills; and enclosed washing and screening equipm ent.

Enz y me Treatment of Pulp. Biotechnology research has resulted in the identification of a num ber of m i croor ganism s that produce enzym e s capable of br e a k ing down lignin in pulp. Although the technology is new, it is believed that a num ber of m ills ar e c u r r e ntly conducting enzym e treatm ent trials. The m i croorganism s capable of producing the necessary enzym e s are called xylanases. Xylanases for pulp bleaching trials are avai l a ble from several biotechnology and chem ical com p anies. Since enzym e s are used as a substitute for chem icals in bleaching pulp, their use will result in a decrease in chlorinated com pounds released so m e what proportional to the reduction in bleaching chem icals used. Enzym e s are also being used to assist in the deinking of seconda r y fi ber. Research at the Oak Ridge National Laboratories has identif ied cellulase enzy m e s that will bind ink to the sm aller fiber particles facilitating recovery of the ink sludge. Use of enzym e s m a y also reduce the energy costs and chem i cal use in retrieving ink sludge from deinking effluent.

Improved Brow nstock and Bleaching Stage Washing. Liquor solids

rem a ining in t h e br ownstock pulp are carried over to the bleach plant and then com p ete with the rem a ining ligni n in the pulp for reaction with t h e bleaching chem icals. Im proved washing, therefore, can reduce the required

am ount of bleaching chem icals and the s ubsequent reductions in chlorinated

com pounds as well a s c onventional pollutants. Modern washing system s with im proved solids rem oval and energy efficiency are beginning to replace the conventional rotary vacuum washers. State-of-the-art washing system s include: atm o spheric or pressure diffusion washers, belt wa s h e r s, and pulp

Sector Notebook Project 66 Novem b er 2002Pulp and Paper Industry P ollution Prevention

presses. Opportunities for reduced e ffluent flows and wa t e r use are also present in the bleaching plant. Acid filtrates fr om hypochlorite or chlorine dioxide stages can be used as dilution and wash water for the first bleaching stage. Sim ilarly, second extraction stage filtrates can be used as dilution and wash water in the f i rst extraction stag e. Most new m ills are designed with these counter-current washing system s and som e m ills are retrofitting their existing wash system s.

Improved Chipping and Screening. The size and thickness of wood chips is critical for proper circulation and penetration of the pulping chem icals. Chip uniform ity is controlled by the chipper and screens that rem ove under and oversized pieces. Standard equipm ent norm a lly does not sort chi p s by thickness although it has been dem onstrated that chip thickness is extrem ely im portant in determ ining the ligni n content of pulp. Im proper chip thicknesses can therefore result in incr eased use of bleaching chem icals and the associated chlorinated com pounds and conventional pollutants. Som e

m ills are beginning to incorporate equipm ent that will separate chips according to their thickness as well as by length and width.

Oxygen-Reinforced/Peroxide Extraction. Oxygen-reinforced extracti on (or oxidative extraction) and peroxide-reinforced extraction processes used separately or together have been shown to reduce the am ount of elem ental chlorine and chlorine dioxide needed in the bleaching pr ocess while increasing the pulp br i ghtness. Gaseous elem ental oxygen (in the case of oxygen-reinforced extraction) a nd aqueous hydrogen peroxide (in the case of peroxide extraction) are used as a pa rt of the first alkaline extraction stage to f acilitate the solubilization and rem oval of chlorinated and oxidized lignin

m o lecules. Oxygen-reinforced extrac tion has seen widespread adoption by the industry in recent years. It is es tim ated that up to 80 percent of m ills in the U.S. are using oxyge n- reinforced extraction. The use of peroxide extraction is also increasing. As of 1987, it was estim ated that 25 percent of dom estic m ills were using peroxide extraction.

Improved Chemical Controls and Mixing. The form ation of chlorinated organics can be m i nim i zed by avoiding excess concentrati ons of chlorinebased bleaching chem icals within reactor vessels. This can be accom p lished by c a r e f ul l y c ont r o l l i ng t h e c h e m i c a l a pplication rates and by ensuring proper

m i x i n g of chem icals within the reactor. Modern chem ical application co n t ro l and m onitoring system s and high-shear m i xers have been developed which decrease form ation of chlorinated organic com pounds.

Sector Notebook Project 67 Novem b er 2002Pulp and Paper Industry F ederal Statutes and Regulations

VI. SUMMARY OF FEDERAL STATUTES AND REGULATIONS

This section discusses t h e federal regulations that m a y apply to this sector. The purpose of this section is to highlight and briefly describe the applicable federal requirem e nts, and to provide citations for m o re detailed inform ation. The three following sections are included:

C Section VI.A contains a general overview of m a jor statutes

C Section VI.B contains a list of regulations specific to this industry

C Section VI .C c o ntains a list of pending and proposed regulatory requirem e nts.

The descriptions withi n Se c t ion VI are intended solely for general inform ation. De pending upon the nature or scope of the activities at a particular facility, these sum m a ries m a y or m a y not necessarily describe all applicable environm ental requirem e nts. Moreover, they do not constitute f o rm al interpretations or clarif ications of the statut e s and regulations. For further inform ation, readers should consult the Code of Federal Regulations and other state or local regulatory ag encies. EPA Hotline contacts are also provided for each m a jor statute.

VI.A. General Description of Major Statutes

Clean Water Act

The prim ary objective of the F e deral W a ter P o llution Control Act, com m only referred to as the Clean W a ter Act (CW A ), is to restore and m a intain the chem ical, physi c al, and biological integrity of the nation' s surface waters. Pollutants regulated under the CW A are c l assified as either “toxic” pollutants; "conventional" polluta nts, such as biochem i cal oxygen dem a nd (BOD), total suspended solids (TSS), fecal coliform
, oil and grease, and pH; or "non-conventional" pollutants, i n c l uding any pollutant not identified as either conventional or priority.

The CW A regulates both direct and “indir e c t ” dischargers (those who discharge to publicly owned treatme nt works). The National Pollutant Discharge Elim ination System (NPDES) perm itting program (CW A section 402) controls direct discharges into na vigable waters. Direct discharges or "point source" discharges are from sources such as pipes and sewers. NPDES perm its, issued by either EPA or an authorized state (EPA has authorized 43 states and one territory to adm i nister the NPDES program ), contain industry-specific, technology-based and water quality-based lim its and establish pollutant m onitoring and reporting requirem e nts. A f acility that proposes to discharge into the nation' s waters m u st obtain a perm it prior to initiating a discharge. A perm it applicant m u st provide quantitative analytical data identif ying the types of pollutants present in the f acility' s

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effluent. The perm it will then set fort h the conditions and effluent lim itations under which a facility m a y m a ke a discharge.

W a ter quality-based discharge lim its are based on f e deral or state water quality criteria or standards, that were designed to protect designated uses of surface water s , s u ch as supporting aquatic life or recreation. These standards, unlike the technology-based standards, generally do not take into account technological feasibility or costs. W a ter quality criteria and standards va r y fr om state to state, and site to site, depending on the use classif i cation of the receiving body of w a ter. Most states f o llow EPA guidelines which propose aquatic life and hum an health criteria for m a ny of the 126 priority pollutants.

Storm W a ter Discharges In 1987 the CW A was am ended to require EPA to establ i s h a program to address storm water discha r g e s

. In response, EPA prom ulgated NPDES
perm itting regulations f o r storm water di scharges. These regulations require that f acilities with the f o llowing types of storm water discharges, am ong others, apply for an NPDES perm it: (1) a discharge associated with industrial activity; (2) a discharge from a large or m e di um municipal storm sewer system ; or (3) a discharge which EPA or the state determ ines to contr i bute to a violation of a water quality standard or is a signif i cant contributor of pollutants to waters of the United States.

The term “storm water discharge asso ciated with industrial activity” m eans a storm water discharge from one of 11 c a t egories of industrial activity defined at 40 CFR Part 122.26. Six of the categories a r e de fi ne d by SIC codes while the other five are identifie d through narrative descriptions of the regulated industrial activity. If the prim ary SIC code of the facility is one of those identif ied in the regulations, the f acility is subject to the storm water perm it application requirem e nts. If any activity at a f acility is covered by one of the five narrative categories, st orm water discharges from those areas where the activities occur are subject to storm water discharge permit application requirem e nts.

Those f acilities/activities that are subject to storm water discharge perm it application requirem e nts are identified below. To determ ine whether a particular facility falls within one of these categories, the regulation should be consulted.

Category i : Facilities subject to storm water ef f l uent guidelines, new source perform a nce standards, or toxic pollutant effluent standards.

Category ii: Facilities classified as SIC 24-lum b er and wood pr oducts (except wood kitchen cabinets); SIC 26-paper and allied products (except paperboard containers and products); SIC 28-chem icals and allied products

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(except drugs and pai n t s ); SIC 29- petroleum refining; SIC 311-leather tanning and finishing; SIC 32 (except 323 )-stone, clay, glass, and concrete; SIC 33-prim ary m e tals; SIC 3441-fabri cated structural m e tal; and SIC 373- ship and boat building and repairing.

Category iii: Facilities classif i ed as SIC 10-m e tal m i ning; SIC 12-coal

m i ning; SIC 13-oil and gas extraction; and SI C 14-nonm etallic m i neral

m i ning.

Category iv: Hazardous waste treatm e nt, storage, or disposal facilities.

Category v: Landfills, land application sites, and open dum ps that receive or have received industrial wastes.

Category vi: Facilities classified as SIC 5015-us ed m o tor vehicle parts; and SIC 5093-autom o tive scrap and waste m a terial recycling facilities.

Category vii: Steam electric power generating f acilities.

Category viii: Facilities classif i ed as S I C 4 0

- r a ilr o a d tr a n s p o r ta tio n ; S I C 4 1

- local passenger transportat i on; SIC 42-trucking and warehousing (except public warehousing and storage); SIC 43- U.S. Postal Service; SIC 44-water transportation; SI C 45-transportati on by air; and SIC 5171-petroleum bulk storage stations and term inals.

Category ix: Sewage treatm e nt works.

Category x: Construction activities except oper ations 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 m ill products; SIC 23-apparel related products; SIC 2434-wood kitchen cabinet s m a nufacturing; SIC 25-furniture and fixtures; SIC 265-paperboard c ontainers and boxes; SIC 267-converted paper and paperboard products; SI C 27-printing, publis hing, and allied industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer, enam els, and allied products; SIC 30-rubber and plastics; SIC 31-leather and leather products (except leather and tanning a nd finishing); SIC 323-glass products; SI C 34-fabricated m e tal products (except fabricated structural m e tal); SI C 35-industrial and com m e rcial m achinery and com puter equipm ent; SIC 36- elec t r oni c and other electrical equipm ent and com ponents; SIC 37- transportation equipm ent (except ship and boat building and repairing); SIC 38-m easuring, analyzing, and controlling in s t ru m e n t s ; S I C 3 9

- m i s cellan e o u s

m a nufacturing industries; and SIC 4221-4225-public warehousing and storage.

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Phase II storm water requirem e nts were established in 1999. Perm its are now required for certain sm all m unicipal separate storm sewer syst e m s (MS4s) and for construction activit y di s t ur bing between one and five acres of land (i.e., sm all construction activities). The Phase II rule also revised the “no exposure” exclusion and the tem porary exem ption for certain industrial facilities that had been established under Phase I regulations.

Pretreatm e nt Program Another type of discharge that is regulated by the CW A is one that goes to a publicly ow ned treatm e nt w o rks (P O T W ) . T h e national pretreatm e nt program (CW A section 307(b)) controls the indirect discharge of pollutants to POTW s by "industrial users." Facilities r e gul at ed under section 307(b)

m

u st m eet certain pretreatm e nt standards. The goal of the pretreatm e nt program is to protect m unicipal wastewater treatm ent plants from dam a ge that m a y 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 POTW s. Different standards apply to existing and new sources within each category. "Categorical" pretreatm e nt st andards applicable to an industry on

a nationwide basis are developed by EPA. In addition, another kind of pretreatm e nt standard, "local lim its," are developed by the POTW in order to assist the POTW in achieving the e f f l uent lim itations in its NPDES perm it.

Regardless of whether a state is authorized to im plem ent either the NPDES or the pretreatm e nt program , if it de velops its own program , it m a y enforce requirem e nts m o re stringent than federal standards.

W e tlands W e tlands, c o mmonly called swam ps, m a rshes, fens, bogs, vernal pools, playas, and prairie potholes, are a subset of “waters of the United States,” as de fi ne d in Section 404 of the CW A. The placem ent of dredge and fill material into wetlands and other water bodies (i.e., waters of the Uni t e d States) is regulated by the U.S. Arm y Corps of Engineers (Corps) under 33 CFR Part 328. The Corps regulates wetlands by adm i nistering the CW A Section 404 perm it program for activities that im pact wetlands. EPA’s authority under Section 404 includes veto power of Corps perm its, authority to interpret statutory exem ptions a nd jurisdiction, enforcem ent actions, and delegating the Section 404 program to the states.

EPA’s O ffice of Water, at 202-566-1730, w ill direct callers w ith questions about the CWA to the appropriate EPA office. EPA also maintai n s 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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Oil Pollution Prevention Regulation Section 311(b) of the CW A prohibits the discharge of oil, in such quantities

as ma y be harm ful, into the navigable waters of the United States and adjoining shorelines. The EPA Discharge of Oil regulation, 40 CFR Part 110, provides inform ation regarding these di s c ha rges. The Oil Pollution Prevention regulation, 40 CFR Part 112, under the authority of Section 311(j) of

the CW A, requires regulated f acilities to prepare and im plem ent Spill Prevention Contr o l and Counterm easure (SPCC) plans. The intent of a SPCC plan is to prevent the discharg e of oil fromonshore and offshore nontransportation-related facilities. In 1990 Congress passed the Oil Pollution Act which am ended Section 311(j) of the CW A to r e quire facilities that because of their location could reasonabl y be expected to cause “substantial harm ” to the environm ent by a discharge of oil to develop and im plem ent Facility Response Plans (FRP). The intent of a FRP is to provide for planned responses to discharges of oil.

A facility is SPCC-regulated i f 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 f acility m eets one of the following criteria regarding oil storage: (1) the capacity of any aboveground

s t orage tank exceeds 660 gallons, or (2) the total aboveground stor a g e capacity exceeds 1,320 gallons, or (3) the underground storage capacity exceeds 42,000 gallons. 40 CFR Part 112.7 c ontains the form at and content requirem e nts for a SPCC plan. In Ne w Jersey, SPCC plans can be com b ined with DPCC plans, required by the state, provided there is an appropriate cross-reference index to the requirem e nt s of both regulations at the front of the plan.

According t o t h e FRP regulation, a facility can cause “substantial harm ” if it meets one of the f o llowing criteria: (1 ) the f acility has a total oil storage capacity greater than or equal to 42,000 gallons and transfers oil over water to or f r om vessels; or (2) the f acility has a total oil storage capacity greater than or equal to one m illion gallons and meets any one of the f o llowing conditions: (i) does not have adequate secondary containm ent, (ii) a discharge could cause “injury” to f i sh and wildlif e and sensitive environm ents, (iii) shut down a public dr inking water intake, or (iv) has had a reportable oil spill grea t e r than or equal to 10,000 gallons in the past five
years. Appendix F of 40 CFR Part 112 contains the form at and content requirem e nts for a FRP. FRPs t h a t m eet EPA’s requirem e nts can be

com b ined with U.S. Coast Guard FRPs or other contingency plans, provided there is an appropriate cross-reference index to the requirem e nts of all applicable regulations at the front of the plan.

For add i t i onal information regarding SPCC plans, contact EPA’s RCRA, Superfund, and EPCRA Call Center, at 800-424-9346. Additional docum ents and resources can be obtained from the hotline’s hom epage 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 Saf e Drinking W a ter Act (SDW A) m a ndates that EPA establish

r e gulations to protect hum an health from contam inants in drinking water

. The law authorizes EPA to develop na tional drinking water standards and to create a joint federal-state system to ensure com p liance with these standards. The SDWA also directs EPA to pr otect underground sources of drinking water through the control of underground injection of fluid wastes.

EPA has developed prim ary and sec ondary drinking water standards under its SDW A authority. EPA and authorizedstates enforce the prim ary drinking water standards, which are contaminant-specif i c concentration lim its that apply to c e rtain public drinking wate r supplies. Prim ary drinking water standards consist of m a xim u m contam in ant level goals (MCLGs), which are non-enforceable health-based goals, and m a xim u m contam inant levels (MCLs), which are enforceable lim its set generally as close to MCLGs as possible, considering cost and f easibility of attainm e nt.

Part C of the SDW A m a ndates 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 com p ly with this m a ndate. The Underground Injection Control (UIC ) regulations break down injection wells into five different types, de pe ndi ng on the fluid injected and the form ation that receives it. The regulations also include construction,

m onitoring, testing, and operating require m e nts for injection well operators. All injection wells have to be aut horized by perm it or by rule depending on their potential to threaten Undergr ound Sources of Drinking W a ter (USDW )

. RCRA also regulates hazardous waste injection wells and a UIC p e rm it is considered to m eet the requirem e nts of a RCRA perm it. EPA has authorized delegation of the UIC f o r all wells in 35 states, im plem ents the program in 10 states and all Indian lands, and shares responsibility with five states.

The SDW A also provides for a federa lly-im p lem e nted Sole Source Aquifer
program , which prohibits federal funds from being expended on projects that

m a y contam inate the sole or pr i n cipal source of drinking water for a given area, and for a state-im plem ented W e llhead Protection program , designed to protect drinking water wells and drinking water recharge areas.

The SDW A Am endm ents of 1996 require states to develop and i m pl e m ent

sour c e wa t e r assessm ent program s (SW A Ps ) to analyze existing and potential threats to the quality of the public dri nking water throughout the state. Every state is required to subm it a program to EPA and to com p lete all assessm ents

w ithin 3 1⁄2 years of E P A approval of t h e program

. SW APs include: (1)

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delineating the source water protection area, (2) conducting a contam ina n t source inventory, (3) determ ining the susceptibility of the public water supply to contam ination from the inve ntories sources, and (4) releasing the results of the assessm ents to the public.

EPA’s Safe Drinking Water Hotline, at 800-426-4791, answers quest i ons and di st ributes 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 Sol i d Wa s t e Disposal Act (SW DA), as am ended by the Resource Conservation and Recovery Act (RCRA) of 1976, addresses solid and hazardous waste m a nagem e nt activities. The Act is com m only referred to as RCRA. The Hazardous and Solid W a ste Am endm ents ( H SWA) o f 1984 strengthened RCRA’s waste m a nagem e nt provisions and added Subtitle I, which governs underground storage tanks (USTs).

Regulations prom ulgated pursuant to Subtitle C of RCRA (40 CFR Parts 260-299) establish a “cradle-to-grave” system governing hazardous wast e from the point of generation to d i s p o s a l

. RCRA hazardous wastes include the specif i c m a terials listed in the regulations (discarded com m e rcial chem ical 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, designate d with the code "F") or m a terials which exhibit a hazardous waste characteristic (ignitability, corrosivity, reactivity, or toxicity and designated with the code "D").

Entities that generate hazardous waste a r e subject to waste accum u lation,

m a nifesting, and recordkeeping standards. A hazardous waste facility m a y

accum u late hazardous waste for up to 90 days (or 180 days depending on the

am ount generated per m onth) without a perm it or interim status. Generators

m a y al s o t r e a t hazardous waste in accum u lation tanks or containers (in accordance with the requirem e nts of 40 CFR Part 262.34) without a perm it or interim status. Facilities that treat, store, or dispose of hazardous waste are generally required to obtain a RCRA perm it.

Subtitle C perm its are required f o r treat m e nt, storage, or disposal f a cilities. These perm its contain general f acility standards such as contingency plans,

em ergency procedures, recordkeeping and reporting requirem e nts, financial

assurance m echanism s , and unit-specific standards. RCRA also contains provi sions (40 CFR Subparts I and S) for conducting corrective actions which govern the cleanup of releases of hazardous waste or constituents from solid waste m a nagem e nt units at RCRA treatm e nt, storage, or d i s posal f acilities.

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Al t h ough RCRA is a federal statute, m a ny states im plem ent the RCRA
pr ogr a m

. Currently, EPA has delegated its authority to im plem ent various provisions of RCRA to 47 of the 50 states and tw o U

. S. territories. Delegation has not been given to Alaska, Hawaii, or Iowa.

Most RCRA requirem e nts are not industry specific but apply to any com p any that generates, transports, treats, stores, or disposes of hazardous waste. Here

are som e im portant RCRA regulatory requirem e nts:

C Criteria for Classification of So lid Waste Disposal Facilities and Practices (40 CFR Part 257) establishes the criteria for determ ining which solid waste disposal f acilities and practices pose a reasonable probability of adverse ef f ects on health or the environm ent. The criteria were adopted to ensure non-m unicipal, non-hazardous waste disposal units that receive conditionally exem pt sm al l quantity generator waste do not pre s e n t r i sks to hum an health and environm ent.

C Criteria for Municipal Solid Waste Landfills (40 CFR Part 258) establishes m i nim u m national criteria f o r all m unicipal solid waste la n d f ill u n its
, in c l u d i n g th o s e th a t a r e u s e d to d i s p o s e o f s e w a g e sludge.

• Identification of Solid and Haz a rdous Wastes (40 CFR Part 261) establishes the standard to determ ine whether the m a terial in question is considered a solid waste and, if so, whether it is a hazardous waste or is exem pted from regulation.

• Standards for Generators of Haz a rdous Waste (40 CFR Part 262) establishes the responsibilit i e s of hazardous waste generators including obtaining an EPA i d e n tif ication num ber, preparing a

m a nifest, ensuring proper packagi ng and labeling, m eeting standards for wast e accum u lation units, and recordkeeping and reporting requirem e nts. Ge ne r a t o r s can accum u late hazardous waste on-site for up to 90 days (or 180 days depending on the am ount of wa s t e generated) without obtaining a perm it.

• Land Disposal Restrictions (LDRs) (40 CFR Part 268) are regulations prohibiting the disposal of hazardous waste on land without prior treatm e nt. U nder the L D R s program , m a terials m u st

m eet treatm e nt standards prior to placem ent in a RCRA land disposal unit (landf ill, land treatm e nt unit, waste pile, or surf ace im poundm ent). Generators of was t e subject to the LDRs m u st provide notif ication of such to the designated TSD f acility to ensure proper treatm e nt prior to disposal.

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• Used Oil Management Standards (40 CFR Part 279) i m pos e

m a nagem e nt requirem e nts affecting the storage, transportation, burning, processing, and re-refining of the used oil. For parties that

m e rely generate used oil, regulations establish storage standards. For a party considered a used oil processor, re-refine r , bur ner, or marketer (one who generates and sells off-specification used oi l dir e c t l y t o a used oil burner), additional tracking and paperwork requirem e nts m u st be satisfied.

• RCRA contains unit-specific standards for all units u s ed 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 m u st m e et em ission standards under RCRA. Re g u l a tions (40 CFR Part 264-265, Subpart CC) require generators to test the waste to determ ine the concentration of the waste, to satisfy tank and container e m i s s i ons standards, and to ins p ect and m onitor regulated units. These regulations apply to all f acilities who store such waste, including large quantity generators

accum u lating waste prior to shipm e nt offsite.

• Underground St o r a g e Tanks (USTs) containing petroleum and hazardous substances are regulated under Subtitle I of RCRA. Subtitle I regulations (40 C F R Part 280) contain tank design and release detection requirem e nts, as well as financial responsibility and corrective action standar d s for USTs. The UST program also includes upgrade requirem e nts for exis ting tanks that were to be m e t by Decem ber 22, 1998.

• Boilers and Industrial Furnaces (BIFs) that use or burn fue l containing hazardous waste m u st com p ly with design and operating standards. BIF regulations (40 CF R Part 266, Subpart H) address unit design, provide perform a nce standard s, require em issions m onitoring, and, in som e cases, restrict the type of waste that m a y be burned.

EPA's RCRA, Superfund, and EPCRA Call Center, at 800-424-9346, responds to questions and distri butes guidance regarding al l 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, e x c l uding federal holidays.

Comprehensive Environmental Response, Compensation, and Liability Act

The Com p rehensive Environm ental Response, Com p ensation, and Liability Act (CERCLA), a 1980 law com m only know n as Superfund, authorizes EPA to respond to releases, or t h r e a t ened releases, of hazardous substances that

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m a y endanger public he a l t h, welfare, or the environm ent. CERCLA also enables EPA to force parties responsible for environm ental contam ination to clean it up or to reim burse the Superf und for response or rem e diation costs incurred by EPA. The Superfund Am endm ents and Reauthorization Act (SARA) of 1986 revised various secti ons of CERCLA, extended the taxing authority for the Superfund, and created a free-standing law, SARA Title III, also known as the Em ergency Planni ng and Com m unity Right-to-Know Act (EPCRA).

The CERCLA hazardous substance release repor t i ng regulations (40 CFR Part 302) direct the person in charge of a facility to report to the Na t i ona l Response Center (NRC) any environm ental release of a hazardous substance which equals or exceeds a reportabl e quantity. Reportable quantities are listed in 40 CFR Part 302.4. A release report m a y trigger a response by EPA or by one or m o re federal or state em ergency response authorities.

EPA im plem ents hazardous substance respons e s a ccording to procedures outlined in the Nat i onal Oil and Hazardous Substances Pollution Contingency Plan (NCP) (40 CFR Pa rt 300). The NCP includes provisions for cleanups. The National Priorities List (NPL) currently includes approxim a t e l y 1,300 sites. Both EPA and states can act at other sites; however, EPA provides responsible parties the opportunity to conduct cleanups and encourages com m unity involvem e nt 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 pr ogram. Documents and re sourc e s can be obt ained 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 Am endm ents and Reau thorization Ac t ( S ARA) of 1986 created t h e Em ergency Planning and Com m unity Right-to-Know Act ( E PCRA, also known as SARA Title III), a statute designed to im prove

com m unity access to inform ation about ch em ical hazards and to facilitate the developm ent of chem ical em ergency response plans by state and local
governm e nts. Under EPCRA, states establish State Em ergency Response Com m i ssions (SERCs), responsible for coordinating certain em ergency response ac t i v ities and for appointing Local Em ergency Planning Com m ittees (LEPCs).

EPCRA and the EPCRA regulations ( 40 CFR Parts 350-372) establish four types of reporting obligations f o r f acilities which store or m a nage specif i ed chem icals:

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• EPCRA section 302 requires f acilities to notif y the SERC and LEPC of the presence of any extrem ely hazardous substance at the facility in an am ount in excess of the established threshold planning quantity. The list of extrem ely hazardous subs t a nces 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 em ergency plan. The plan m u st contain (but is not lim ited to) the identif ication of

f

acilities within the planning dist rict, likely routes f o r transporting
extrem ely haz a r dous substances, a description of the m e thods and procedures to be f o llowed by f acility owners and operators, and the designation of com m unity and facility em ergency response coordinators.

• EPCRA section 304 requires the f acility to notif y the SERC and the LEPC in the event of a release exceeding the reportable quantity of a CERCLA hazardous substance (defin ed at 40 CFR Part 302) or an EPCRA extrem ely hazardous substance.

• EPCRA sections 311 and 312 require a facility at which a hazardous chem ical, as defined by the Occupational Safety and Health Act, is present in an am ount exceeding a specified threshold to subm it to the SERC, LEPC and local fire departm e nt m a t e r i a l s a fety data sheets (MSDSs) or lists of MSDSs and h azardous chem ical inventory form s (also known as Tier I and II form s). This inform ation helps the local
governm e nt respond in the event of a spill or release of the chem ical.

• EPCRA section 313 requires certain covered f acilities, including SIC codes 20 through 39 and others, which have ten or m o re

em ploye e s , and which m a nufacture, process, or use specified chem icals in am ounts greater than threshold quantities, to subm it an annual toxic chem ical release repor t. This report, com m only known
as t h e For m R, covers releases and transfers of toxic chem icals to various f acilities and environm ental m e dia. EPA m a intains the data reported in a publically accessible database know n as the Toxics Release Inventory (TRI).

All inform ation subm itted 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 r e garding 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 operat es 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 am endm ents are designed to “protect and enhance the nation' s air resources so as to prom ote the public he a l t h and wel f a r e and the productive capacity of the population.” The CAA consists of six sections, known as Title s, which direct EPA to establish national standards f o r ambient air quality and f o r EPA and the states to im plem ent,

m a intain, and enforce these standards through a variety of m e chanism s

. Under the CAA, m a ny f acilities are requi red to obtain operating perm its that

c o nsolidate their air em ission requirem e nts. State and local governm e nts
oversee, m a nage, and enforce m a ny of the requirem e nts of the CAA. CAA regulations appear at 40 CFR Parts 50-99.

Pursuant to Title I of the CAA, EP A has established national am bient air quality standards (NAAQSs) to lim it levels of "criteria pollutants," including carbon m onoxide, lead, nitrogen di oxi de , particulate m a tter, ozone, and

su l f u r d i oxide. Geographic areas that m eet NAAQSs for a given pollutant are designated as attainm e nt areas; those that do no t meet NAAQSs are designated as non-attainm e nt areas. Under section110 and other provisions of the CAA, each state m u st develop a State Im plem ent a t i on Pl an (SIP) to identify sources of air pollution and to determ ine what reductions are required to m eet federal air quality sta ndards. Revised NAAQSs for particulates and ozone becam e effective in 2001.

Title I also authorizes EPA to esta blish New Source Perf orm a nce Standards (NSPS), which are nationally uniform em ission standards for new and

m odified stationary sources falling within particular industrial categories. NSPSs are based on the pollution con t r o l technology available to that category of industrial source (see 40 CFR Part 60).

Under Title I, EPA establishes and en f o rces National Em ission Standards f o r Hazardous Air Po llu tan t s (N E S H A P s), n a tio n a lly u n i form standards oriented toward controlling specific hazardous ai r pollutants (HAPs). Section 112(c) of the CAA further directs EPA to deve lop a list of sources that em it any of 188 HAPs, and to develop regulations for these categories of s our c e s

. To date EPA has listed 185 source categorie s and developed a schedule for the establis hme n t of em ission standards. The em ission standards are being developed for both new and existing s ources based on "m axim um achievable control technology” (MACT). The MACT is defined as the control technology achievi ng the m a xim u m degree of reduction in the em ission of the HAPs, taking into account cost and other factors.

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Title II of the CAA pertains to m obile sources, such as cars, trucks, buses, and planes. Reform ulated gasoline, autom obile pollution control device s, and vapor recovery nozzles on gas pum ps are a few of the m echanism s EPA uses to regulate m obile air em ission sources.

Title IV-A establishes a sulf ur dioxide and nitrogen oxides em issions
program designed to reduce the form ati on of acid rain. Reduction of sulfur dioxide releases wil l be obtained by granting to certain sources lim ited

em issions allowances that are set below previous levels of sulfur dioxide releases.

Title V of the CAA establishes an operating perm it program f

o r all "m ajor sources" (and certain other sources) regulated under the CAA. One purpose of the operating perm it is to include in a single docum ent all air em issions requirem e nts that apply to a given f ac ility. States have developed the perm it
program s in accordance wi t h gui dance and regulations from EPA. Once a state program is approved by EPA, perm its are issued and m onitored by that
state.

Title VI is intended to protect stratospheric ozone by phasing out the

ma nufacture of ozone-depleting chem icals and restricting their use a n d distribution. Produc t i o n of Class I substances, including 15 kinds of chlorofluorocarbons (CFCs), were phase d 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.e pa.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 rec e n t 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
pa s s e d i n 1947, and am ended num erous tim es, m o st recently by the Food Quality Protection Act (FQPA) of 1996. FIFRA provides EPA with the
aut hor i t y to oversee, am ong other things, the registration, distribution, sale and use of pesticides. The Act a ppl i e s t o all types of pesticides, including insecticides, herbicides, fungicides, rodenticides and antim icrobials. FIFRA covers both intrastate and interstate com m e rce.

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Establishm ent Registration Section 7 of FIFRA requires that establishm ents producing pesticides, or active ingredients used in producing a pesticide subject to FIFRA, register with EPA. Registered establishm en ts m u st report the types and am ounts of pesticides and active ingredients they produce. The Act also provides EPA inspection authority and enables the agency to take enforcem ent actions against f acilities that are not in com p liance with FIFRA.

Product Registration Under section 3 of FIFRA, all pestic ides (wi t h few exceptions) sold or distributed in the U.S. m u st be registered by EPA. Pesticide regist r a t i on is very specific and generally allows use of the product only as specified on the label. Each registration specifies th e use site i.e., where the product m a y be used and the am ount that m a y be applied. The person who seeks to register the pesticide m u st file an applica t i on for registration. The application process often requires either the citation or subm ission of extens i v e environm ental, health and safety data.

To register a pesticide, the EPA Adm i nistrator m u st m a ke a num ber of findings, one of which is that the pesticide, when used in a c c o r d a n ce with widespread and com m only recognized practice, will not gener a l l y cause unreasonable adverse effects on the environm ent.

FIFRA defines “unreasonable adverse e ffects on t h e environm ent” as “(1) any unreasonable risk t o ma n or the environm ent, taking into account the

econom ic, social, and environm ental cos t s and benefits of the use of the pesticide, or (2) a hum an dietary risk from residues that result from a use of a pesticide in or on any food inconsiste nt with the standard under section 408 of the Federal Food, Drug, and Cosm etic Act (21 U.S.C. 346a).”

Under FIFRA section 6(a)(2), after a pesticide is r e gistered, the registrant

m

u st also notify EPA of any additi onal facts and inform ation concerning unreasonable adverse environm ental effects of the pesticide. Also, if EPA determ ines that additional data are n eeded to support a registered pesticide, registrants m a y be requested to provide additional data. If EPA determ ines that the registrant(s) did not com p ly w ith their request for m o re inform ation, the registration can be suspended under FIFRA section 3(c)(2)(B).

Use Restrictions As a part of the pesticide regis t r a t i on, EPA m u st classify the product for general use, restricted use, or general for som e uses and restricted for others (Miller, 1993). For pesticides that m a y cause unreasonable adverse effects on the environm ent, including injury to the applicator, EPA m a y require that the pesticide be applied either by or unde r the direct supervision of a certified applicator.

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Reregistration Due to concerns that m u ch of the safety data underlying pesticide registrations becom e s outdated and inad equate, in addition to providing that registrations be reviewed every 15 y ears, FIFRA requires EPA to reregister all pesticides that were registered prior to 1984 (section 4). After reviewing existing data, EPA m a y approve the reregistration, request additional data to support the registration, cancel, or suspend the pesticide.

Tolerances and Exem ptions A tolerance is the m a xim u m am ount of pesticide residue that can be on a raw product and still be considered safe. Be fore EPA can register a pesticide that is used on raw agricultural products, it m u st grant a tolerance or exem ption from a tolerance (40 CFR Parts 163.10 through 163.12). Under the Federal Food, Drug, and Cosm etic Act ( FFDCA)
, a raw agricultural product is deem ed unsafe if it contains a pesticid e residue, unless the residue is within the lim its of a tolerance established by EPA or is exem pt f r om the requirem e nt.

Cancellation and Suspension EPA can cancel a r e gi st ration if it is determ ined that the pesticide or its l a beling does not com p ly with the requirem e nts of FIFRA or caus e s unreasonable adverse effects on the environm ent (Haugrud, 1993).

In cases where EPA believes that an “im m i nent hazard” would exist if a pesticide were to continue to be used through the cancellation proceedings, EPA m a y suspend the pesticide registra tion through an order and thereby halt the sal e , di s t ribution, and usage of the pesticide. An “im m i nent hazard” is defined as an unreasonable adverse e ffe c t on the environm ent or an unreasonabl e hazard to the survival of a threatened or endangered species that would be the likely result of allo wing continued use of a pesticide during a cancellation process.

W h en EPA believes an em ergency exists that does not perm it a hearing to be held prior to suspending, EPA can issu e an em ergency order which m a kes the suspension im m e diately effective.

Im ports and Exports Under FIFRA s e c t i on 17(a), pesticides not registered in the U.S. and intended solely for export are not require d to be registered provided that the exporter obtains and subm its to EPA, prior to export, a s t atem ent 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 statem ents to the governm e nt of the im porting country. FIFRA sets f o rth additional requirements that m u st be m e t by pesticides intended solely for export. The enforcem ent po licy for exports is codified at 40 CFR Parts 168.65, 168.75, and 168.85.

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Under FIFRA section 17(c), im ported pesticides a nd de vices m u st com p ly with U.S. pesticide law. Except where exem pted by regulation or statut e, im ported pesticides mus t be register ed. FIFRA section 17(c) requires that EPA be notified of the arrival of im ported pesticides and devices. This is

accom p lis h e d t h rough the Notice of Arrival (NOA) (EPA Form 3540-1), which is f illed out by the im porter prio r to im portation and subm itted to the EPA regional of f i ce applicable to the intended port of entry. U.S. Custom s regulations prohibit the im portation of pesticides without a com p leted NOA. The EPA-reviewed and signed for m i s returned to the im porter for presentation to U.S. Custom s when th e shipm e nt arrives in the U.S. NOA form s 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 pe s t i c i d e s can be obtained from a variety of s our c e s , including EPA’s Office of Pesticide Program s www.epa.gov/pesticides , EPA’s Office of Compliance, Agri c u l t u r e and Ecosystem Division http://www.epa.gov/com pliance/assistance/ sectors/agriculture.html , or The National Agriculture Compliance A ssistance Center, 888-663-2155 or http: / /

w ww.epa.gov/agriculture/

. Other sources include the National Pesticide Te lecommunications 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 fram ework t o c o l l ect data on chem icals in order to evaluate,
assess, m itigate, and control risks wh ich m a y be posed by their m a nuf acture, processing, and use. TSCA provides a va riety of control m e thods to prevent chem icals from posing unreasonable risk. It is im portant to note that pesticides as defined in FIFRA are not include d in the definition of a “chem ical substance” when m a nufactured, processed, or di stributed in

com m e rce for use as a pesticide.

TSCA standards m a y apply at any point during a chem ical’s life cycle. Under TSCA section 5, EPA has established an inventory of chem ica l substances. If a chem ical is not a l ready on the inventory, and has not been excluded by TSCA, a premanuf acture notice (PMN) m u st be subm itted to EPA prior to m a nufacture or im port. The PMN m u st identify the chem ical and provide available inform ation on health and environm ental effects. If available data are not sufficient to eval uate the chem ical’s effects, EPA can im pose restrictions pending the developm ent of inform ation on its health and environm ental effects. EPA can al s o r e strict significant new uses of chem icals based upon factors such as the projected volum e and use of the chem ical.

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Under TSCA section 6, EPA can ban the m a nufacture or distribution in

com m e rce, lim it the use, require labeling, or place other restrictions on chem icals that pose unreasonable risks. Am ong the chem icals EPA regulates under section 6 authority are asbestos, chlorofluorocarbons (CFCs), lead, and polychlorinated biphenyls (PCBs).

U nder T S C A section 8(e), E P A requi res the producers and im porters (and others) of chem icals to report info rm ation on a chem icals’ production, use, exposure, and risks. Com p anies pr oducing and im porting chem icals can be required to report unpublished health and safety studies on listed chem icals and t o collect and record any allegations of adverse reactions or any inform ation indicating that a substance m a y pose a substantial risk to hum ans or the environm ent.

EPA’ s TSCA Assistance Information Service, at 202-554-1404, answers questions and distributes guidance pertai ning t o 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 Managem e nt Act (CZMA) encourages states/tri b es to preserve, protect, develop, and where po ssible, restore or enhance valuable natural coastal resources such as wetlands, floodplains, e s t u aries, beaches, dunes, barrier islands, and coral reefs, as well as the fish and wildlife using those habitats. It includes are a s bordering the Atlantic, Pacific, and Arctic Oceans, Gul f of Mexico, Long Is land Sound, and Great Lakes. A unique feature of this law is that participation by states/tribes is voluntary.

In the Coastal Zone Managem e nt Act Reauthorization Am endm ents (CZARA) of 1990, Congress identified nonpoint source pollution as a m a jor factor in the continuing degr a d a tion of coastal waters. Congress also recognized that effective solutions to nonpoint source pol l u t i on could be im plem ented 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 m a nagem e nt program s to develop and im plem ent coastal nonpoint pollution control program s. The Section 6217
program is adm i nistered at the f e deral level jointly by EPA and the National Oceanic and Atm o spheric Agency (NOAA).

Section 6217(g) c a l l e d for EPA, in consultation with other agencies, to develop guidance on “m anagem ent m easures” 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 program s. 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 m a jor s ource categories of nonpoint pollution: (1) urban runoff, (2) agric u l t u re runoff, (3) forestry runoff, (4) m a rinas and recreational boating, and (5) hydrom odification.

Additional information on coastal z one 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. T h e N O

A A website, ht tp://www.ocrm.nos.noaa.gov/czm/ , also contains additional information on coastal zone management.

VI.B. Industry Specific Requirements

Clean Air Act (CAA)

National Am bient Air Quality Standards At pulp and paper m ills, air em issions f r om both process and com bustion units are regulated under the National Am bient Air Quality Standar d s (NAAQS) and the State Im plem entation Plans (SIP) that enf o rce the standards. States m a y im plem ent cont rols to lim it em issions of particulate

ma t t e r ( P M) , ni t r ogen oxides (NOx), volatile organic com pounds ( VOC)
, and sulfur dioxide (SO 2 ).

Although m a ny lim its are impl e m e n ted at the state level, there are national guidelines that serve as a basis for m o re specif i c lim its. Sources that are conside r e d "m ajor" under the Clean Air Act are subject to prevention of significant deterioration (PSD) or new s ource review (NSR). Both PSD and NSR are perm it program s f o r f acilities that were constructed or m odif i ed af

ter a certain date.

Fa c ilities in NAAQS attainm e nt areas m u st follow PSD requirem e nts by dem onstrating that the construction/m odif i cation project will not cause a violation of air quality lim its and by im plem enting the best available control technology (BACT).

N e w or m odif i ed f ac ilities in nonattainm e nt areas m u st f o llow N S R

r e quirem e nts, which require the source to m eet the lowest achievable

em is s i on rate (LAER) and to obtain em ission offsets to ensure that the nonattainm e nt problem is not m a de worse by the new/m odified source.

In addition to the PSD/NSR pre-construction obligations, there are processspecific operational standards: New S ource Perform a nce Standards (NSPS). 40 CFR 60 lists these standards, which serve as m i nim u m require me nt s i n states SIPs. Individual states m a y im pose requirem e nts that are m o re strict. The following NSPSs are particularly re levant to the pulp and paper industry:

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Subpart BB Kraft pulp m ills (Regulates PM and TRS em issions from new kraft

m ills.)

Subparts D, Db, Dc Industrial boilers (Regulates PM, nitrogen oxides (NOx) and s u lfur dioxide (SO 2 ) from ne w boi l e rs used at pulp and
paper m ills.)

Subpart GG Gas-fired turbines (Regulates PM, nitrogen oxides ( NOx) and sulfur dioxide (SO 2 ) from new gas-fired turbines used at pulp and paper m ills.)

Subpart K b Volatile Organic Li quid Storage V e ssels (Including Petroleum Liquid Storage Vessels) (Regulates VOC from applicabl e storage tanks containing volatile organic liquids at pulp and paper

m ills)

Hazardous Air Pollutants Air toxics regulations apply to seve ral parts of the pulp and paper m illing
process. National Em ission St a nda rds for Hazardous Air Pollutants (NESHAP) have been developed expressl y for two processes of the pulp and paper industry. Both NESHAPs establish process-based m a xim u m achieva bl e control technologies (MACT) for "m ajor sources," which are def i ned as f acilities that em it or have the potential to em it 10 tons per year

or m o re of any hazardous air pollutant (HAP) or 25 tons per year or m o re of
any com b ination 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 C ontrolling HAP em issions from the pul p and paper production areas of m ills usi ng the kraft, sulfite, sem i

chem ical, and soda pulping processes (MACT I), and controlling HAP em issions from pulp and paper production areas of m ills using m echanical, secondary fiber, and non-wood pulping, and paperm aking system s at all m ills (MACT II).

Subpart MM Cont r o lling HAP em issions from chem ical recove r y processes that involve the com bustion of spent pulping liquor at kraft, soda, sulfite, and stand-alone

sem i chem ical pulp m ills (MACT III).

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Other NESHAPs that are relevant for the industry are those for asbestos (relevant during dem o lition and renovation activit i e s) and m e rcury (im portant for sludge dryers and incine rators). Unlike the industry-specific NESHAP standards, chem ical-specif i c NESHAPs m a y apply to all f a cilities regardless of their size.

Risk Managem e nt Program Pulp and paper m ills are subject to section 112(r) of CAA, which states that stationary sources using extrem ely hazardous substanc e s ha ve a "general duty" to initiate specific activities to prevent and m itigate accidental releases. The general duty requi r e me nt s apply to stationary sources that produce, process, handle, or store these substances, regardless of the quantity of

m a naged at the facility. Although there is no list of "extrem e ly hazardous substances," EPA’s Chem ical Em ergency Preparedness and Pr e v e n tion Office provides som e guidance at its webs i t e : www.epa.gov/ceppo

. The general duty clause requires facilities to identify hazards that m a y result from accidental releases, to design and m a intain a safe facility, and to m i nim i ze the consequences of releases when they occur.

Most pulp and paper m ills are subject to additional, m o re explicit risk

m a nagem e nt requirem e nts. Facilities that have m o re than a threshold quantity of any of the 140 re gul a t e d substances in a single process are required to develop a risk m a nagem e nt progr a m a n d to sum m a rize their
program in a risk m a nagem e nt plan (RMP ). Mills subject to the requirem e nts were required to s ubmi t a r e gistrati on and RMP in 1999 or whenever they first exceed the threshold for a listed regulated substance after that date.

All f acilities m eeting the RMP threshold requirem e nts m u st f o llow Program 1 requirem e nts:

• A n offsi t e 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 m a nagem e nt plan, revised at least once every five years, that describes and docum ents these activities f o r all covered processes.

In addition, m o st pulp and paper facilitie s m a y be subject to the requirem e nts of Program 2 or 3. These additional requirem e nts include:

• A n integrated prevention program to m a nage risk. The prevention
program will include identificat i on of hazards, written operating procedures, training, m a intenance, and accident investigation.

• A n em ergency response program

.

• A n overall m a nagem e nt system to put t h e s e program elem ents into effect.

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The list of chem icals that trigger RMP requirem e nts can be found in 40 CFR 68.130; inform ation to determ ine the required program l e ve l also can be found in 40 CFR 68.

Title V perm its Title V requires that all "m ajor sources" (and certain m i nor sources) obtain an operating perm it. Many pulp and pape r m ills are required to have a Title V perm it, and m a y be r e quired to subm it inform ation about em issions, control devices, and the general pro cess at the f acility in the perm it application. Perm its m a y lim it pollutant em issions and im pose m onitoring, record keeping, and reporting requirem e nts.

Title VI Stratospheric Ozone Protection Many pulp and paper facilities operate industrial process refrigeration units, such as chillers f o r chlorine dioxide plants. For those units that utilize ozonedepleting chem icals, such as chlorofluorocarbons (CFCs) , facilities are required under Title VI to follow leak repair requirem e nts.

Clean Water Act ( C WA)

There are two industry-s p e c ific com ponents of the CW A requirem e nts: NPDES perm itt i ng a nd pretreatm e nt program s. Other general CW A requirem e nts, such as those for wetla nds and storm w ater, m a y also apply to the pulp and paper m ills and are described in Section VI.A.

Individual NPDES requirem e nts ha ve been developed for several

s ubc a t egories of the industry; they are described in 40 CFR 430. For e a c h of

these subcategories, the regulations outline som e or all of the f o llowing f o r f acilities that discharge wastewater directly to the environm ent:

• b est practicable control technology current l y a v ailable (BPT) and best conventional control technology (BCT) guidelines for t h e c ont r o l of

conventional pollutants (biological oxygen dem a nd, total suspended solids, and pH).

• b est available technology econom ically achievable (BAT) guidelines for the control of nonconventional and toxic pollutants (trichlorophenol and pentachlorophe nol, which are chem icals used as biocides).

• n ew sour c e perform a nce standards (NSPS) for the control of conventional, non-conventional, and toxic pollutants from ne w f acilities that discharge directly to the environm ent.

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For facilities that discharge their wast ewater to a publicly-owned treatm ent works (POTW ) , pretreatm e nt standards m a y apply. In addi t i on to general standards es t a bl i s hed by EPA that address all industries, there are Pretreatm e nt Standards f o r N e w S o u r ces (PSNS) and Pretreatm e nt Standards for Existing Sources (PSES) that are specific to the pulp and paper industry. These regulate the biocides trichlorophenol and pentachlorophenol
, with lim its that are specified for each subcategory of the industry.

In 1998, in conjunction with the developm ent of the pulp and paper cluster rule, EPA reorganized t h e regulations in order to group processes that are sim ilar. Table 19 pr esents the revised and original subcategory groupings, and sum m a rizes the portions of the CW A 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 D issolving Kraft D issolving Kraft (F) U U

B B leached Papergrade Kraft and Soda a Market Bleached Kraft (G) BCT Bleached Kraft (H) Fine Bleached Kraft (I) Soda (P) U U U

C U nbleached Kraft U nbleached Kraft (A)

• L inerboard

• B ag and Other Products Unbleached Kraft and Sem i -Chem i cal (D, V) U U

D D issolving Sulfite Dissolving Sulfite (K)

• N itration

• V i s c o s e

• C ellophane

• A cetate U U

E P apergrade Sulfite a Papergrade Sulfite (J, U)

• B low Pit W a sh

• D r u m W a s h U U U

F S em i-Chem ical Sem i -Chem i cal (B)

• A m m onia

• S odium U U

G M echanical Pulp Groundwood-Therm o -Mechanical (M) Groundwood-Coarse, Molded, News (N) Groundwood-Fine Papers (O) Groundwood-Chem i-Mechanical (L) U

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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 N on-W ood Chem ical Pulp Miscellaneous m ills not covered by a specific subpart U

I S econdary Fiber Deink Deink Secondary Fiber (Q)

• F i n e P a p e r s

• T issue Papers

• N e w s p r i n t U

J S econdary Fiber Non-Deink Tissue from W a stepaper (T) Paperboard from W a stepaper (E)

• C orrugating Medium

• N on-Corrugating Medium W a stepaper-Molded Products (W ) Builders’ Paper and Roofing Felt (40 CFR Part 431 Subpart A)

K F ine and Lightweight Papers from Purchased Pulp Nonintegrated Fine Papers (R)

• W ood Fiber Furnish

• C otton Fiber Furnish Nonintegrated Lightweight Papers (X)

• L ightweight Papers

• L ightweight Electrical Papers U

L T issue, Filter, Non-W oven, and Paperboard from Purchased Pulp Non-Integrated

• T issue Papers (S)

• F ilter and Non-W oven (Y)

• P aperboard (Z) U

Source: U.S. EPA, Pulp and Paper NESHAP: A Plain English Description, Novem b er, 1998, Pages 7 and 104.

a These subcategories are affected by the Cluster Rules (described below).

Cluster Rule

The cluster rule is an integrated, m u lti-m e dia regulation to control the release of pollutants to two m e dia (air and wa ter) from one industry. The intent of the rule is to allow individual m ills in particular segm ents of the industry to consider all regulatory requirem e nts at one tim e. This com b ined rule allows

m ills to select the best com b ination of pollution prevention and control technologies that provide the greatest protection to hum an he a l t h a nd the environm ent. Because som e air require m e nts that reduce toxic air pollutants

a l s o r e d u c e m ill w a s t e w a t e r to x i c p o llu ta n t lo a d in g s ( a n d w a te r tr e a tm e n t requirem e nts can reduce air im pacts), th e com b ined rules have a synergistic effect.

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Som e of the features of the coordinated rule include:

• A lternative em ission lim its

• V arying com p liance periods (3-8 years)

• N ew and existing source controls

• F lexibility for evolving technologies

• C om pl i a nce dates coordinated with effluent lim itations guidelines and standards

The rule sets new baseline lim its f o r the releases of toxics and nonconventional pollutants to the air and water. There are three significant

com ponents:

• Ai r Emissions Standards. New and existing pulp and paper m ill s

m

u st m eet air standards to reduce em issions of toxic air poll u t a nt s occurring at various points throughout the m ills. Specifically, EPA requires m ills to capture and treat toxic air pollutant em issions that occur during the cooking, washing, and bleaching stages of the pulp

m a nufacturing process.

• Water Effluent Limitations Guidelines and Standards. New and existing standards in the bleached papergrade kraft and soda subcategory and the bleached papergrade sulfite subcategor y must

m eet standards to reduce discharges of toxic and nonconventional pollutant s

. Specifically, EPA has set ef f l uent lim itations f o r toxic pollutants in t h e wastewater discha rged directly from the bleaching process and in the f i nal discharge f r om the m ills.

• Analytical Methods for 12 Chlorinated Phenolics and Ads o rbable Organic Halides (AOXs)

. Sam p les of air em issions and water discharges from each mi l l m u st be tested using the laboratory

m e thods included in the rule. The new m e thods will enable m o re tim ely and accurate m easurem ents of releases of these pollutants to the environm ent and will be used to ensure com p liance with air

em ission and water discharge perm it lim its.

Voluntary Advanced Technology Incentives Program (VATIP) Mills in the Bleached Papergrade Kraft and Soda Subcategory have additional flexibility under the cluster rule

. Mills m a y com p ly either with the baseline regulations, or with m o re st ringent wastewater regulations under a

m o re f o rgiving tim etable. This latter arrangem e nt, called the Voluntary Advanced Technology Incentives Program (VATIP), allows m ills to undertake custom ized com p liance and pollution reduction plans that further reduce environm ental im pacts.

Sector Notebook Project 91 Novem b er 2002Pulp and Paper Industry F ederal Statutes and Regulations
Under the VATIP, each participating m ill develops “Milestones Plans” for each fiber line that it enrolls in the program

. Perm it writers will use the Milestones Plan to incorporate enfor ceable interim requirem e nts into the

m ill’s discharge perm it. Specif i c requirem ents f o r the Milestones Plan are found in 40 CFR 430.24(b) and (c), but the three ba s i c c o mponents of a Milestones Plan are the following:

• A description of each technology com ponent or process m odification the m ill intends to im plem ent

• t he m a ster schedule showing the sequence of im pl e m e n t i ng new technologies and process m odifications

• d escriptions of the anticipated im provem e nts in ef f l uent quality.

Emergency Planning and Community Right-to-Know Act (EPCRA)

Three of the com ponents of EPCRA are di r e c t ly relevant to the pulp and paper industry:

• E m e rgency Planning (§302(a)) - Busi nesses that produce, use or store "hazardous substances" m u st: 1) subm it m a terial safety data sheets or the equivalent, and 2) Tier I/Tier II annual inventory report form s to the appropriate local em ergency planning com m i ssion. Those handling " e xtrem e ly hazardous substances" also are required to subm i t a one-tim e notice to the state em ergency response

c o mmi s s i o n

.

• E m e rgency Notification of Extr em ely Hazardous Substance Release (§304) - A business that u n i ntentionally releases a reportable quantity of a n extrem ely hazardous substance m u st report that release to t h e state em ergency planning com m i ssion and the local em ergency planning com m i ssion.

• R elease Reporting ( §313) - Manufacturing businesses with ten or

m o re em ployees that m a nufactured, processed, or otherwise used a listed toxic chem ical in excess of the "establis h e d threshold" m u st f ile annually a Toxic Chem ical Release form with EPA and the state. D o cum e ntation supporting release estim ates m u st be kept f o r three
years.

Resource Conservation and Recovery Act (RCRA)

The pulp and paper industry generates hazardous wastes, but m o st are associated with wastewater, which is rendered non-hazardous in wastewater

Sector Notebook Project 92 Novem b er 2002Pulp and Paper Industry F ederal Statutes and Regulations

treatm e nt or neutralization units within m a nuf acturing f acilities, and therefore is not subject to RCRA require m e nts. Also, black liquor is exem pt as a solid waste if it is recl ai med in a recovery furnace and reused in the pulping process. Therefore, m o st of the industry’s RCRA requirem e nts 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 St a ndards for the Pulp, Paper, and Paperboard Category, Phase II EPA will consider revi sing the technology-based effluent lim itations guidelines and standards for 8 of the 12 subcategory for this indus t rial category: Unbleached Kraft; Sem i -Che m i cal; Mechanical Pulp; Non-W ood Chem ical Pulp; Seconda r y Fiber Deink; Secondary Fiber Non-Deink; Fine and Lightweight Papers f r om Purcha sed Pulp; and Tissue, Filter, NonW oven, and Paperboard from Purchase d Pulp. EPA proposed guidelines and standards for t h e s e s ubcategories as pa rt of the Pulp and Paper Rules (also known as the Cluster Rules) in Decem ber 1993. The Age n c y intends to develop these revised effluent lim itations in close coordi na tion with the Office of Air Quality Planning and Standa rds. This is a long-term action; no definite schedule had been set at the tim e of the publication of this docum ent. (Don Anderson, Office of W a ter, 202-566-1021)

Effluent Guidelines and Standards for the Pulp, Paper, and Paperboard Point Source Category, Dissolving Kraft and Dissolving Sulf ite Subcategories (Phase III) In 1993, EPA proposed revised effluent lim itations, guidelines and standards and best m a nageme nt practices regulations for the Dissolving Kraft and Dissolving Sulfite Subcategories (also known as Phase III of the Cl ust e r Rules). There are f i ve m ills in these subcategories in the U.S. EPA anticipates that the f i nal rule will se t lim its f o r adsorbable organic halides (AOX), chem ical oxygen dem a nd (COD), chloroform , dioxin, furan, and 12 specific chlorinated phenolics. The rule is expected to be propose d i n m i d2003 and finalized in 2004. (Don Anderson, Office of W a ter, 202-566-1021)

Minim i zing Adverse Environm ental Im pact from Cooling W a ter Intake Structures at Exist i ng Facilities Under Section 316(b) of the Clean W a ter Act, Phase III This rulem a king af f ects existing f acilities that use cooling water intake structures, and whose intake flow le vels exceed a m i nim u m threshold EPA will determ ine. Pulp and paper m a nuf acturing f acilities are explicitly listed as af f ected f a c ilities. The rule w ill require that the location, design, construction, and capacity of cooling water intake structures reflect the best

Sector Notebook Project 93 Novem b er 2002Pulp and Paper Industry F ederal Statutes and Regulations
technology available for m i ni mi z i ng adverse environm ental im pact. The final rul e i s anticipated before D ecem ber, 2004. (Deborah Nagle, Office of W a ter, 202-566-1063 or J.T. Morgan, Office of W a ter, 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 aim e d at protecting visibility in 156 federa l a r e a s. The rule seeks to reduce the visibility im pairm e nt caused by m a ny s ources over a wide area. The haze rule requires states to establish goals f o r im p r o v i n g v i sibility in national parks and wilderness areas and to develop long-te rm strategies for reducing em issions of air pollutants that im pair visibilit y. Guidelines for BART were proposed
to am end the haze rule. The guidelines are for states in developing their plans for setting air pol l u tion lim its for utilities and other industrial plants built between 1962 and 1977 that have the potential to em it m o re than 250 tons a year of visibility im pairing pollution. These facilities fall into 26 categories, including pulp m ills. Many of these f acilities have previously been exem pt from federal pollution control require m e nts under the Clean Air Act. Som e of the guidelines m a y affect em issions from boilers and recover boilers. This proposed rule only provides guidelines for states in developing their im plem entation plans. In m o st parts of the country, the plans are due in 2008. (Tim Sm ith, Office of Air and Radiation, 919-541-4718)

Interstate Ozone Transport, NOX Stat e Im plem entation Plan Call (NOX SIP Call)

EPA has issued several actions and r u l e m a kings related to reducing the regional transport of ozone, including the final Regional Transport of Ozone Rule ("NOx SIP c a l l " ) requiring 22 eastern States and the District of Colum b ia to subm it State Im plem entation Plans that address the regional transport of ground-level ozone through reductions in nitrogen oxi des (a precursor t o oz one). W h ile m o st of the NOx SIP call was upheld, certain

a s pe c t s of EPA' s plan were rem a nded by court decisions, including a definition dealing with industrial boilers and cogenerati on. In February of 2002, EPA proposed rule s on a num ber of rem a nded item s , including rules for certain industrial boilers that m a y be present at pulp and paper m ill s

. 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 f o ssil f u els. Pulp and paper m ills in the eastern states should m onitor their state im plem entat i o n plans. Im plem entation of state plans will likely begin in 2003 in som e States or 2004 for other States. (Kevin Culligan, Office of Air and Radiation, 202-564-9172)

Sector Notebook Project 94 Novem b er 2002Pulp and Paper Industry C ompliance and Enforcement History

VII. COMPLIANCE AND ENFORCEMENT HISTORY

Background

U n til recently, EPA has focused m u ch of its attention on easuring com p liance with specific environm ental statutes. This approach all o ws t h e Agency to track com p liance with the Clean Air Act, the Resource Conservation and Recovery Act, the Clean W a ter Act, and other environm ental statutes. W ithin the last several ye a r s , the Agency has begun to supplem ent singlem e dia com p liance indicators with f acility -specif i c, m u ltim edia indicators of

com p liance. In doing so, EPA is in a better position to track com p liance with all statutes at the facility level, and within specific industrial sectors.

A m a jor step in buildin g the capacity to com p ile m u ltim edia data f o r industrial sectors was the creation of EP A' s Integrated Data for Enforcem ent Analysis (IDEA) system

. IDEA has th e capacity to "read into" the Agency' s single-m e dia databases, extract com p liance records, and m a tch the r ecords to individual f acilities. The IDEA sy stem can m a tch Air, W a ter, W a ste, T o x i cs /P es ticid es/EPCRA, TRI, and Enforcem ent Docket records for a g i v e n facility, and generate a list of histori cal perm it, inspection, and enforcem ent activity. IDEA also has the capability to analyze data by geographic area and corporate holder. As the capacity to generate m u ltim edia compliance data im proves, EPA will m a ke available m o re in-depth com p liance and enforcem ent inform ation. Additionally, sector-specific m easures of success for com p liance assistance efforts are under developm ent.

Compliance and Enforcement Profile Description

Using inspection, violation and enforcem ent data from the IDEA system , this section provides inform ation regarding the historical com p liance and enforcem ent activity of this sector. Com p liance and enforcem ent records f r om EPA' s data system s are com p iled to the f acility level using the Facility Registry System ' s (FRS) Master Source ID, which links records from virtually any of EPA' s data system s to a facility record. For each facility (i.e., Master Source ID), the Industry Se c t or Notebooks analysis uses the f acility-level SIC code that is desi gnated by IDEA, which can be described as f o llows:

1. If the f acility reports to TRI, then the designated SIC code is the prim ary SIC reported in the m o st recent TRI reporting year.

2. If the f acility does not report to TRI, the f i rst SIC codes f r om all linked AFS, PCS, RCRAInfo, BRS ID/per m its are assem b led. If m o re than
one perm it/ID exists f o r a particular pr ogram then only one record f r om that da t a system is used. The SIC code that occurs m o st often, if there is one,

Sector Notebook Project 95 Novem b er 2002Pulp and Paper Industry C ompliance and Enforcement History

becom e s the designated SIC code.

3. If the facility does not report to TRI and no SIC code occurs m o re often than others, the designated SI C code is chosen from the linked
program s in the following order: AFS, PCS, BRS, RCR, NCD, DCK. If m o re than one perm it/ID exists f o r a particul ar program then only one record f r om that data system is used.

Note that EPA does not attem p t to def i ne the actual num ber of f

acilities that fal l wi t h in each sector. Instead, the inform ation presented in this secti o n portrays the records of a subset of f

acilities within the sector that are well defined within EPA databases.

As a check on the relative size of the full sector universe, m o st notebooks contain an estim ated num ber of facilitie s within the sector according to the Bureau of Census (See Sect i o n II). W ith sectors dom inated by sm all businesses, such as m e tal finishers a nd printers, the reporting universe within
t h e EPA databases m a y be sm all in com p arison to Census data. Howeve r , the group selected for inclusion in this data analysis section should be consistent with this sector' s general m a ke-up.

Following t h i s introduction is a list defining each data colum n presented within this section. These values represent a re t r ospective sum m a ry of inspections or enforcem ent actions, and solely reflect EPA, state and local

com p liance 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 (Septem b er 16, 1997 to Septem ber 15, 2002) and the other for the m o st recent 24-m onth pe riod (Septem b er 16, 2000 to Septem ber 15, 2002). The five-year analysis gives an average level of activity for that period for com p arison to the m o re recent activity.

Because m o st inspections focus on single-m e dia requirem e nts, t h e data queries prese n t e d i n this section are taken from single m e dia databases. These databases do not provide data on whether inspections are s t a t e / local or EPA-led. However, the table breaking down the universe of violations does give the reader a general m easurem ent of the EPA' s and states' efforts within each m e dia program

. The presented data illustrate the variations across Regions for certain sectors. 3 This variation m a y be attributable to state/local data entry variations, specific geographic concent r ations,
p r o x i m ity to population centers, sensitive ecosys t em s , h i g h l y to x i c ch em icals used in production, or historical noncom pliance. 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, W V ); IV (AL, FL, GA, KY, MS, NC, SC, TN); V (IL, IN, MI, MN, OH, W I); VI (AR, LA, NM, OK, TX); VII (IA , KS, MO, NE); VIII (CO, MT, ND, SD, UT, W Y ); IX (AZ, CA, HI, NV, Pacific Trust Territories); X (AK, ID, OR, W A ).

Sector Notebook Project 96 Novem b er 2002Pulp and Paper Industry C ompliance and Enforcement History
do not rank regional perform a nce or necessarily reflect whi c h r e gions m a y have the m o st com p liance problem s.

Compliance and Enforcement Data Definitions

General Definitions

Fac i lity Registry System (FRS) -- this system assigns a com m on Mast e r Source ID to EPA single-m e dia perm it records. The Master Source ID allows EPA to com p ile and review a ll perm it, com p liance, enforcem ent and pollutant release data f o r any given regulated f acility.

Integrated Data for Enforcement Analysis (IDEA) -- is a data integration system that can retrieve inf o rm ation f r om the m a jor EPA program of f i ce databases. IDEA uses the FRS m a inta ined Master Source ID identification

num ber to "glue together" separate data records from EPA’s databases. This is done to create a "m aster list" of da ta records for any given facility. Som e of the data system s accessible thr ough IDEA a r e : AIRS (Air Facility I ndexing and Retrieval System , Office of Air and Radiation), PCS (Perm i t Com p liance System , Office of W a ter )
, RCRAInfo (Resource Conservation and Recovery Inform ation System , Offi ce of Solid W a ste), NCDB (National Com p liance Data Base, Office of Prevention, Pe s t i c i d es, and Toxic Substances), CERCLIS (Com prehensive Environm ental and Liabil ity Inform ation System , Superfund), a nd TRIS (Toxic Release Inventory System ). IDEA also contains inform a tion from outside sources such as Dun and Br adstreet and the Occupational Safety and Health Adm i nistration (OSHA). Most data queries displaye d in notebook sections IV and VII were conducted using IDEA.

Data Table Column Heading Definitions

Facilities in Search -- are based on the num ber of the FRS m a intained 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 s t a t e a g e n cy inspections f o r the f acilities in this data search. These values show what percentage of the f acility universe is inspected in a 24- or 60- m onth period.

Number of Inspections -- m easures the total num ber of inspections conducted in this sector. An inspection event is counted each tim e i t is entered into a single m e dia database.

Average Time Betw een Inspections -- provides an average length of tim e, expressed in m onths, that a com p liance inspection occurs at a f acility within

Sector Notebook Project 97 Novem b er 2002Pulp and Paper Industry C ompliance and Enforcement History

the defined universe.

Facilities w i th One or More Enforcement Actions -- expresses the num ber of

f

acilities that were party to at le ast one enf o rcem ent action within the defined tim e period. This category is broken down further into federal and state actions. Data are obtained f o r adm i nistrative, civil/judicial, and crim inal enforcem ent actions. Adm i nistrative actions include Notices of Violation (NOVs). A f acility with m u ltiple enf o rcem en t actions is only counted once in this colum n (facility with three enforcem ent actions counts as one). All percentages that appear are ref e renced to the num ber of f

a cilities inspected.

Total Enforcement Actions -- describes the total number of enforcem ent actions identified for an industrial sector across all environm ental statutes. A facility with m u ltiple enforcem ent act i ons is counted m u ltiple tim es (a facility with three enforcem ent actions counts as three).

State Lead Actions -- shows what percentage of the total enforcem ent actions are taken by state and local e nvironm ental agencies. Varying levels of use by states of EPA data syst e m s ma y lim it the volum e of actions accorded state enforcem ent activity. Som e states extensively r e por t enf o rcem ent activities into EPA data sy stem s, while other states m a y use their own data system s.

Federal Lead Actions -- shows what percentage of the t o t a l enforcem ent actions are taken by the United States Environm ent a l Protection Agency. This value includes referrals from state agencies. Many of these act i ons result from coordinated or joint state/federal efforts.

Enforcement to Inspection Rate -- expresses how oft e n enforcem ent actions result f r om inspections. This value is a ratio of enforcem ent actions to inspections, and is presented for com p arative purposes only. This m easure is a rough indicator of the relationshi p between inspections and enforcem ent. This m easure sim p ly indicates historically how m a ny enforcem ent actions can be attributed to inspection activity. Reported inspections and enforce m e n t a c t i ons under the Clean W a ter Act (PCS), the Clean Air Act (AFS) and the Resource Conservation and Recovery Ac t ( RCRA) are included in this rat i o. I n s p e c t i ons a n d actions from the TSCA/FIFRA/EPCRA database are not f actored into this ratio because m o st of t h e a c tions taken under these program s are not the result of facility inspections. This ratio does not account for enforcem ent actions arising from non-inspection com p l i ance m onitoring activities (e.g., self-reported water discharges) that can result in enfor cem ent action within the CAA, CW A and RCRA.

Facilities with One or Mo re Violations Identified -- indicates the

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percentage of inspected f

acilities having a violation identif ied in one of the following data categories: In Viola tion or Significant Violat ion Status (CAA); Reportable Noncom pliance, Current Ye a r Noncom pliance, Significant Noncom pliance (CW A ); Noncom pliance and Si gnificant Noncom pliance (FIFRA, TSCA, and EP CRA); Unresolved Violat i on and Unresolved High Priority Violation ( RCRA). The values presented for this colum n reflect the extent of noncom p liance within the m easured tim e fram e, but do not distinguish be t w e e n the severity of the noncom pliance. Percentages within this colum n can exceed 100 percent because facilities can be in violation status wi t h out being inspected. Violation status m a y be a precursor to an enforcem ent action, but does not necessarily indicate that an enf o rcem ent action will occur.

Media Breakdow n of Enforcem ent Actions and Inspections -- four colum n s identify the proportion of tota l inspections and enforcem ent actions within EPA Air, W a ter, W a ste, and TSCA/FIFRA/EPCRA databases. Each col u mn i s a percentage of either th e “Total Inspections,” or the “Total Actions” colum n

.

VII.A. Pulp and Paper Industry Compliance History

Table 20 provides an overview of the reported com p liance and enforcem ent data for the pulp and paper industry over the past five years (Septem b er 16, 1997 to Septem ber 15, 2002). These data are also broken out by EPA Region thereby perm itting geographical com p aris ons. A f e w points evident f r om the data are listed below.

C Regions 5, 4 and 1 contain the m o st pulp and paper f acilities, while Regions 4, 6, and 3 conducted the m o st inspections.

C Region 4 conducted, by far, the m o st inspections of pulp and paper f acilities, had the lowest average tim e between inspections, and had the m o st enforcem ent actions.

C Regions 2 and 10 had the m o st enforcem ent ac t i ons per inspection (0.19 and 0.13, respectively).

Sector Notebook Project 99 Novem b er 2002Pulp and Paper Industry C ompliance and Enforcement HistoryTable 20: Five-Year Enforcement and Compliance Summary for the Pulp and Paper Industry, by RegionJEnforcementto InspectionRate0.080.060.190.090.060.060.060.0300.090.13IPercent ofFederal LeadActions15%5%4%23%9%30%30%0%0%0%6%HPercent ofState LeadActions85%95%96%77%91%70%70%100%0%100%94%GTotalEnforcementActions5033773771164456101272FFacilities with1 or MoreEnforcementActions332383426904832201640EAverageMonthsBetweenInspections5101143123134094DNumber ofInspections6,3835713838992,024721944333140537CFacilitiesInspected4957357479612040721832BFacilities InSearch58592715710514445722237ARegionNational12345678910

Sector Notebook Project 100 Novem b er 2002Pulp and Paper Industry C ompliance and Enforcement History

VII.B. Comparison of Enforcement Activity Betw een Selected Industries

Tables 21 and 22 allow the com p liance history of the pulp and paper sector to be com p ared to the other industries covered by the indus try sector notebooks. Com p arisons between Tables 21 and 22 perm it the identif ication of trends in com p liance and enforcem ent records of the industry by

c o mparing data covering the last five years to that of the past two years. Som e points evident from the data are listed below.

C Pulp and paper m ills are tied with petroleum ref i neries as the m o st frequently inspected sectors of those listed.

C Pulp and paper m ills have a relatively high percent of f

acilities with violations and enforcem ent actions and a rel a tively high rate of enforcem ent per inspection com p ared to the other sectors listed.

Tables 23 and 24 provide a m o re in-d epth com p arison between the pulp and paper industry and other sectors by breaking out the compl i a nc e and enforcem ent data by environm ental statute. As in the previous Tables (Tables 21 and 22), the data cover the la st five years (Table 23) and the last two years (Table 24) to f acilitate the identif ication of re cent trends. Two points evident from the data are listed below.

C The m a jority of inspections and actions a r e c onducted under the CAA, followed by the CW A.

C In the past 2 years
, t h e por t i on of actions taken under the CAA is increasing, while that taken under the CW A is decreasing.

C The pulp and paper industry ha s one of the lowest percentages of RCRA inspections and actions of those sectors listed.

Sector Notebook Project 101 Novem b er 2002Pulp and Paper Industry C ompliance and Enforcement HistoryTable 21:Five-Year Enforcement and Compliance Summary for Selected IndustriesJEnforcementtoInspectionRate0.030.050.060.10.050.070.070.050.080.070.070.090.080.090.070.180.080.070.070.090.130.090.080.070.090.130.050.080.10.070.04IPercentFederalLeadActions40%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%HPercentStateLeadActions60%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%GTotalClosedEnforcementActions56606405482717593145033784214292158111601,1536859334933434461,59322038123911066233651,346141FFacilities with1 or MoreEnforcementActions108587945322788343863324343863202045742183488348383203382581,98229642425810079642721,062210EAverageMonthsBetweenInspections533718252119171852912914818527176221030372117162339391159DNumber ofInspections1641141,0036,38610,8064,00211,3365,8226,3835,1005,6544,9642,6058,8392,2906,2388,65113,1447,2853,7283,34016,9592,6705,3402,75685913,16040666918,1223,469CFacilitiesInspected73301881,6202,1939112,1811,1664951,5897005454638323753242,3132,2145178223585,2689251,2475491713,3161662422,3351,851BFacilitiesinSearch146712932,6753,7711,2843,2601,7465852,4451,0927796281,1076744763,8703,6257041,3835618,4261,6631,8807912304,9912634363,2953,390AIndustry SectorAgricultural Crop ProductionAgricultural Livestock ProductionMetal MiningOil and Gas ExtractionNon-Fuel,NonMetal MiningTextilesLumberand WoodWood Furnitureand FixturesPulp and PaperPrintingInorganic ChemicalsPlastic Resins and FibersPharmaceuticalsOrganic ChemicalsAg. Chem., Pesticide & FertilizerPetroleumRefiningRubberand PlasticStone,Clay,Glass and ConcreteIron and SteelMetal CastingsNonferrous MetalsMetal ProductsElectronics and ComputersMotorVehicle AssemblyAerospaceShipbuilding and RepairGround TransportationWaterTransportationAirTransportationFossil Fuel Electric PowerGenerationDryCleaningTransportation equipment cleaning sectornot included because sector is not classified by SIC code and no compliance data are available.*

Sector Notebook Project 102 Novem b er 2002Pulp and Paper Industry C ompliance and Enforcement History

Sector Notebook Project Novem b er 2002 103Table 22: Two-Year Enforcement and Compliance Summary for Selected IndustriesACDEFGHIndustry SectorFacilities inSearchFacilitiesInspectedNumber ofInspectionsFacilities with 1 or MoreViolationsFacilities with 1 or moreEnforcement ActionsTotal ClosedEnforcementActionsEnforcementto InspectionRateNumberPercent*NumberPercent*Agricultural Crop Production14638651026%25%10.02Agricultural Livestock Production71816675%675%50.31Metal Mining2931242907460%2823%230.08Oil and Gas Extraction2,6759312,13536339%54659%3520.16Non-Fuel,NonMetal Mining3,7711,3403,38932824%23417%2040.06Textiles1,2846301,25622035%17428%1450.12Lumberand Wood3,2601,4673,71458040%38026%3280.09Wood Furnitureand Fixtures1,7467521,91631642%18224%1390.07Pulp and Paper5853791,83723863%15842%1850.1Printing2,4458551,69935942%23427%1620.1Inorganic Chemicals1,0924731,79324251%17236%1410.08Plastic Resins and Fibers7794111,65221552%16440%1610.1Pharmaceuticals62828882815554%7626%620.07Organic Chemicals1,1075992,78236561%26444%2610.09Agricultural Chemical Pesticide & Fertilizer67423273410847%6026%370.05PetroleumRefining4762401,73819180%22493%4470.26Rubberand Plastic3,8701,4432,99264144%40828%3130.1Stone,Clay,Glass and Concrete3,6251,4884,25449633%38826%3510.08Iron and Steel7043732,20125067%14439%1490.07Metal Castings1,3834951,15330261%18036%1720.15Nonferrous Metals56122396515067%11853%1590.16Metal Products8,4262,9085,704172859%88430%5880.1Electronics and Computers1,66346986232068%14030%860.1MotorVehicle Assembly1,8808161,89741050%21827%1670.09Aerospace79132985417954%9629%690.08Shipbuilding and Repair2301002956363%4848%350.12Ground Transportation4,9912,0594,69649024%45822%3270.07WaterTransportation263811263138%67%40.03AirTransportation4361122165246%3229%180.08Fossil Fuel Electric PowerGeneration3,2951,8106,35570139%52029%4930.08DryCleaning3,3907851,21223830%749%500.04*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.BPercentages can exceed 100%Pulp and Paper Industry C ompliance and Enforcement History

Sector Notebook Project Novem b er 2002 104Table 23:Summary by Statute for Selected IndustriesIndustry SectorFacilitiesInspectedTotalInspectionsTotalClosedEnforcementActionsClean Air ActClean Water ActRCRAFIFRA/TSCA/EPCRA/Other% ofTotalInspections% ofTotalActions% ofTotalInspections% ofTotalActions% ofTotalInspections% ofTotalActions% ofTotalInspections% ofTotalActionsAgricultural Crop Production73164561%40%0%0%36%20%3%40%Agricultural Livestock Production30114648%50%0%17%49%17%3%17%Metal Mining1881,0036061%52%26%43%13%3%1%2%Oil and Gas Extraction1,6206,38664096%93%0%1%4%6%0%0%Non-Fuel,NonMetal Mining2,19310,80654897%98%1%1%1%1%0%0%Textiles9114,00227174%56%13%27%13%13%1%4%Lumberand Wood2,18111,33675977%73%1%2%22%24%1%2%Wood Furnitureand Fixtures1,1665,82231475%74%0%1%24%24%1%1%Pulp and Paper4956,38350368%73%24%20%7%5%1%2%Printing1,5895,10037865%66%0%0%35%32%1%2%Inorganic Chemicals7005,65442150%50%12%13%36%28%2%10%Plastic Resins and Fibers5454,96442951%55%19%22%29%21%2%3%Pharmaceuticals4632,60521548%46%6%8%44%36%2%10%Organic Chemicals8328,83981148%48%12%15%38%30%3%7%Agricultural Chemical Pesticide &Fertilizer3752,29016057%31%12%9%26%21%5%39%PetroleumRefining3246,2381,15363%79%12%8%24%12%1%1%Rubberand Plastic2,3138,65168569%69%1%1%29%24%1%6%Stone,Clay,Glass and Concrete2,21413,14493386%87%1%1%12%10%1%2%Iron and Steel5177,28549366%62%11%14%23%21%0%3%Metal Castings8223,72834364%60%2%3%33%33%1%5%Nonferrous Metals3583,34044665%68%7%8%27%22%1%2%Metal Products5,26816,9591,59345%41%2%2%52%51%1%7%Electronics and Computers9252,67022034%16%4%4%60%67%2%13%MotorVehicle Assembly1,2475,34038161%59%1%1%37%36%0%4%Aerospace5492,75623948%36%3%3%48%57%0%3%Shipbuilding and Repair17185911058%30%5%9%36%61%1%0%Ground Transportation3,31613,16066278%0%1%0%21%0%0%0%WaterTransportation1664063340%33%2%0%57%67%1%0%AirTransportation2426696531%28%2%5%67%66%0%2%Fossil Fuel Electric PowerGeneration2,33518,1221,34675%85%19%9%5%4%1%2%DryCleaning1,8513,46914136%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 EnforcementTransportation equipment cleaning sectorPulp and Paper Industry C ompliance and Enforcement History

Sector Notebook Project Novem b er 2002 105Table 24: Two-Year Inspection and EnforcementSummary by Statute for Selected IndustriesIndustry SectorFacilitiesInspectedTotalInspectionsTotalClosedEnforcementActionsClean Air ActClean Water ActRCRAFIFRA/TSCA/EPCRA/Other% ofTotalInspections% ofTotalActions% ofTotalInspections% ofTotalActions% ofTotalInspections% ofTotalActions% ofTotalInspections% ofTotalActionsAgricultural Crop Production3865159%100%0%0%37%0%5%0%Agricultural Livestock Production816581%60%0%20%19%0%0%20%Metal Mining1242902346%61%35%39%19%0%0%0%Oil and Gas Extraction9312,13535297%97%0%1%3%2%0%0%Non-Fuel,NonMetal Mining1,3403,38920497%99%1%1%2%1%0%1%Textiles6301,25614571%61%16%22%13%13%0%3%Lumberand Wood1,4673,71432875%75%1%1%24%22%0%2%Wood Furnitureand Fixtures7521,91613975%85%0%0%25%14%0%1%Pulp and Paper3791,83718564%81%28%13%7%4%0%1%Printing8551,69916264%0%0%0%35%0%1%0%Inorganic Chemicals4731,79314144%56%14%12%42%25%0%7%Plastic Resins and Fibers4111,65216150%65%21%14%29%19%0%2%Pharmaceuticals2888286244%45%7%11%49%37%0%6%Organic Chemicals5992,78226143%52%14%13%40%31%2%4%Agricultural Chemical Pesticide &Fertilizer2327343751%38%13%14%33%24%3%24%PetroleumRefining2401,73844752%83%16%6%32%10%0%1%Rubberand Plastic1,4432,99231369%79%2%0%29%20%0%2%Stone,Clay,Glass and Concrete1,4884,25435186%85%2%2%12%10%0%2%Iron and Steel3732,20114960%70%13%9%27%17%0%4%Metal Castings4951,15317258%60%3%2%38%33%0%4%Nonferrous Metals22396515959%80%8%3%32%16%0%2%Metal Products2,9085,70458843%46%3%1%54%43%0%9%Electronics and Computers4698628630%12%5%5%65%63%1%21%MotorVehicle Assembly8161,89716757%63%2%1%41%32%0%5%Aerospace3298546946%44%4%0%50%51%0%6%Shipbuilding and Repair1002953559%37%6%11%35%51%0%0%Ground Transportation2,0594,69632775%0%1%0%24%0%0%0%WaterTransportation81126443%50%2%0%56%50%0%0%AirTransportation1122161829%39%1%0%69%56%0%6%Fossil Fuel Electric PowerGeneration1,8106,35549373%87%21%8%6%3%0%2%DryCleaning7851,2125037%6%0%0%63%94%0%0%* Transportation equipment cleaning sector notincluded because sector is not classified by SIC code and no compliance data areavailable.Pulp and Paper Industry C ompliance and Enforcement History
Sector Facility Indexing Project -- Additional com p liance inf o rm ation f o r the pulp and paper industry is available through EPA’s Sector Facility Indexing Project (SFIP). This is a webs ite that brings together environm ental and other inf o rm ation f r om a number of data system s to produce facilitylevel profiles for five industry s ectors (pulp ma nufacturing, petroleum refining, iron and steel production, prim ary nonferrous m e tal refining and

sm elting, and autom obile assem b ly) and a subset of m a jor federal facilities. SFIP inf o rm ation relates to com p liance and inspection history, chem ical release s and spills, dem ographics of the surrounding population and production. (Contact: SFIP hotline at 617-520-3015 or the website at http://www.epa.gov/sfipm t n1/)

VII.C. Review of Major Legal Actions

This section provides sum m a ry inform ation about m a jor cases that have af

f ected this sector, and a list of Supplem entary E nvironm ental P r ojects (SEPs). SEPs are com p liance agreem en ts that reduce a f acility' s stipulated penalty in return f o r an environm ental project t h at exceeds the value of the reduction. Often, these projects fund pollution prevention activities that can signif i cantly reduce the f u ture pollutant loadings of a f acility.

This section discusses m a jor legal cases and pending litigation within the pul p and paper industry as well as supplem ental environm ental projects (SEPs) involving pulp and paper f acilitie s. Inf o rm ation regarding m a jor cases or pending litigation is available f r om the Of f i ce of Regulatory Enf o rcem ent.

VII.C.1. Review of Major Cases

In FY 1999 and FY 2000, three significant enforcem ent cases affecting the pulp and paper industry were concluded.

Potlatch Corporation. A Cl ean Air Act settlem e nt 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 m ill plant. In 1997, EPA issued Potlatch a Notice of Violation alleging that the burning of tir es resulted in sulfur dioxide em issions th at exceeded lim its in a Clean Air Act
perm it issued by EPA in 1980 and also ex ceeded lim its in a perm it issued by the State in 1979. The notice also alleged that the switch to burning tires was the t y pe of change that required Potlatch to first obtain a perm it under the Clean Air Act’s Prevention of Significant Deterioration prec onstruction review program

. Following issuance of the Notice of Violation, settlem e nt negotiations took place and an agreem ent was reached to settle the violations described in the notice by paym ent of a $500,000 civil penalty. Potlatch has the option of burning tires i f it obtains a perm it and installs the required pollution control devices, but has elected not to do so.

Sector Notebook Project 106 Novem b er 2002Pulp and Paper Industry C ompliance and Enforcement History

Crane & Co., Inc. Crane & Co., Inc. (“Crane”) , of Dalton, MA operates as

a m a nuf acturer and distributor of high quality specialty paper f o r the securities, legal, banking and business m a rkets. This f a m ily owned and run

com p any is nearly 200 years old, and ha s successfully held a currency paper contract with the U.S. Departm e nt of Trea s u r y for 121 years. EPA’s civil adm i nistrative com p laint under the Em ergenc y Pl anning and Com m unity Right to Know Act (EPCRA) focused on violations found at three of Crane’s f acilities in Dalton and Pittsf i eld, MA.

Since calendar year 1994, Crane failed to f ile chem ical inventory inform ation (Tier II f o rm s) f o r three of its m a nuf acturing f a cilities with the State Em ergency Response Com m i ssion (SERC), Local Em ergency Pla nning Com m ittee (LEPC) or local fire depa rtm e nts, as required by Section 312 of EPCRA. In total, Crane f a iled to repor t 28 chem icals, including sulfuric acid and form aldehyde (a com ponent of m e lam i ne r e s i n) , whi c h EPCRA c l a s s i fies as Extrem ely Hazardous Substances.

By the term s of the Septem ber 2000 settle m e nt of this action, Crane will pay a penalty of $8,164 and perform a supplem ental environm ental project (SEP) estim ated to cost between $26,832 and $100,000. The SEP consists of replacing s odi um hypochlorite as a bleaching agent in the non-wood pulp
paper-m aking processes at the Pioneer Mill in Dalton with a 50 percent hydrogen peroxide solution. Use of peroxide bleachi ng will reduce hum an and environm ental exposure to residual chlorine and chlorite ions that result from use of sodium hypochlorite. In addition, r e pl a c em ent of sodium hypochlorite with hydrogen peroxide wil l e l i m inate potential exposure of first responders and on-site workers to chlorine gas, which can be created if sodium hypochlorite is im properly m i xed, used, or stored. F i nally, discontinuing the use of sodium hypochl orite will reduce the environm ental threat posed by discharging chlorinated organic com pounds into the receiving waters of the Housatonic River.

Appleton Papers. Appleton Papers in Roaring Spring, Pennsylvania produces pulp using t h e kr aft process and paper using m e chanical paper

m achines. Initially EPA issued a com p liance order to Appleton requiring the initial perf orm a nce test of the brown stock washer system and installation of the continuous em ission m onitoring sy stem (CEMS) required by the NSPS of the Clean Air Act. These violations were subsequently referred t o t h e Departm e nt 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 settlem e nt which provided for a cash penalty of $490,000 and early

com p liance with the Pulp and Paper MA CT. The penalty reflects the avoided costs of installation of Total Reduced Sulf ur CEMS, as well as the company’s adherence to EPA’s initial com p liance order. The Consent Decree was lodged August 16, 2000.

Sector Notebook Project 107 Novem b er 2002Pulp and Paper Industry C ompliance and Enforcement History

VII.C.2. Supplementary Environmental Projects

SEPs are com p liance agre e m e n t s that reduce a facility' s non-com p liance penalty in return f o r an environm ental project that exceeds the value of the reduction. Often, these projects fund pollution prevention activities that can reduce the f u ture pollutant loadings of a f acility. Inf o rm ation on SEP cases can be accessed via the Internet at http://www.epa.gov/com p liance/resources/ policies/civil/seps/index.htm l

. Table 25 presents nine exam ples of SEPs negot i a ted with pulp and paper f acilities.

Six of the cases were associated with EPCRA – m o st relate to a f a ilure to notif y com m unity and state em ergency c oordinators of a hazardous substance release (§304), a violation of em ergency and hazardous chem ical inventory form requirem e nts (§312), or a violation of toxic che m ical release form requirem e nts (§313). In addition, there were m u ltiple cases involving a violation of perm it r e qui rem e nts for treatm e nt, storage, or disposal of hazardous waste (RCRA §3005).

There were three general types of SEPs seen within the pulp and paper settlem e nts:

• T hr e e of the SEPs involve emergency planning and response

. In each case, the defendants purchased equipm ent for local em ergency response authorities.

• F ive SEPs provide a form of pollution reduction

. These were facility-spe c i fi c , but generally involved the replacem ent of equipm ent that is m o re efficient or less prone to environm ental releases.

• T wo SEPs involve pollution prevention

. These projects involved the installation of technologies that reuse process waste.

Sector Notebook Project 108 Novem b er 2002Pulp and Paper Industry C ompliance and Enforcement HistoryTable 25: FY-1996-1999 Supplemental Environmental Projects Overview:Pulp and Paper ManufactureSupplemental Environmental Project InformationSEP DescriptionImprove emergencynotification to public bypurchasing dictaphone and 16-channel recorderPurchase emergencyresponse equipment forCowlitz CountyEmergencyRespondersProjectImplement fiber and chemical recoverysystemthat reducesfiber and chemical lossfrommanufacturing process.Donate emergencyequipment for five countiesat a cost of $285,000 and $10,000 for weatherweb page.Shut down and dismantle wood wasteincinerator and install wood-fired boiler withelectrified fluidized bed (EFB) ascontroldevice.Construct containment dams to capture andtreat spills entering Willamette River.Capture total reduced sulfur (TRS) gases frompump station for incineration.Remove, replace, and dispose of 2 PCBtransformers, 1 PCB-contaminatedtransformer.Removal, disposal, and replacement of 1950'sPCB transformer at the New Haven Board Milland a non-PCB transformer.SEP Category$10,720EmergencyPlanning andPreparedness$30,738EmergencyPlanning andPreparedness$31,910PollutionPreventionEmergencyPlanning andPreparedness$2,200,000PollutionPrevention,PollutionReduction$159,514PollutionReduction$460,000PollutionReduction$44,972PollutionReduction$50,000PollutionReductionViolation InformationSEP Cost toCompanyAssessedPenalty$2,680$8,539$2,450$400,000$359,000$5,602$200,000$6,500$13,600TypeEPCRA 312EPCRA304, 325RCRA 3005EPCRA304, 325CAA 165EPCRA 313CERCLA 103CWA 101CWA 307EPCRA 304RCRA 3005TSCA 6(e)EPCRA 313General InformationState/RegionALWALAWAAKORNHNYCTCompanyNameChampionInternationalCorporationLongviewFibreCompanyNicolausPaper, Inc.WeyerhaeuserCompanyKetchikanPulp CompanySmurfitNewsprintCorporationCrown PaperCo./JamesRiver PaperCo.Little RapidsCorp.SimkinsIndustriesDocket #04-1999-005210-1997-016306-1998-007410-1997-010710-94-019710-96-008701-94-000802-95-016501-95-0103FY199919981998199819971997199619961996

Sector Notebook Project 109 Novem b er 2002Pulp and Paper Industry A ctivities and Initiatives

VIII. COMPLIANCE ACTIVITIES AND INITIATIVES

This section highlights the activities undertaken by this industry sector and public agencies to voluntarily im prove the sector' s environm ental perf orm a nce. 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 Environm ental Perform a nce Track Pr ogram is designed to

m o tivate and reward top e nvi r o nm ental perform a nce. By encouraging a syste m a t i c a ppr oa ch to m a naging environm ental responsibilities, taking extra steps to r e duce and prevent pollution, and being good corporate neighbors, the program is rewarding com p anies that s t r i v e f o r

e n v i r onm ental excellence. At the sam e tim e, m a ny participating com p ani e s ar e finding that they are saving m oney and im proving producti vi t y. Five pulp and paper m ills are participating in the program

. (Contact: Perform a nce Tr a c k hotline at 888- 339-PTRK or the website at www.epa.gov/performancetrack/ .)

WasteWi$e Program

The W a steW i$e Program was started in 1994 by EPA’s Office of Solid W a ste and Em ergency Response. The program is aime d a t r e ducing

m

unicipal solid wastes by prom oting waste m i nim i zation, recycling collection and the m a nufacturing and pur chase of recycled products. As of 2001, the program had about 1,175 c o mpanies as m e m b ers, including a

num ber of m a jor corporations. Mem b ers agree to identify and im plem ent actions to reduce their solid wastes a nd m u st provide EPA with their waste reduction goals along with yearly progress repor t s

. EPA in turn provides techni cal assistance to m e m b er com p anies and allows the use of the W a steW i$e logo for prom otional purposes. Twenty one pulp and paper

com p anies are partners. (Contact: Jeff Tum a rkin at EPA’s Office of Solid W a ste and Em ergency Response at 703-308-8686 or Tum a rkin.Jef f @ epa.gov, or the W a steW i$e Hotline at 800-EPA

- W I SE (372- 9473) or www.epa.gov/wastewise .)

Project XL

Project XL, which stands for "eXcellence and Leadership," is a national pilot
program that a l l o ws state and local governm e nts, businesses and federal facilities to develop with EPA innovative strat e gi e s t o test better or m o re cost-effective ways of achieving environm ental and public health protection. In exchange, EPA will issue regulat ory, program , policy, or procedural

Sector Notebook Project 110 Novem b er 2002Pulp and Paper Industry A ctivities and Initiatives
flexibilities to conduct the experim e nt. Under Project XL private businesses, f e deral f acilities, business sectors and state and local governm e nts are conducting experim e nts that address the f o llow i ng eight Project XL selection criteria:

1. produce superior environm ental re sults beyond those that w ould have been achieved under curre nt and reasonably anticipated future regulations or policies

2. produce be ne fits such as cost savings, paperwork reduction, regulatory f l exibility or other type s of f

l exib ility that se rve 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 transf erable to other f a cilities

6. dem onstrate f easibility

7. establish accountability through agreed upon m e thods of m onitoring, reporting, and evaluations

8. avoid shifting the risk burden, i.e., do not create worker safet y or environm ental justice problem s as a result of the experim e nt.

By 2002, three pulp and paper com p anies (Georgia -Pacific, International Paper, and W e yerhaeuser) had undertak en projects under Project XL. (For

mor e i n form ation, contact Adam Lev itan in the Office of Reinvention Program s at 202-566-1466 or levi t an.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 orga nizations to proactively com b at pollution by installing energy efficient lighting technologies in thei r com m e rcial and industrial buildings. In April 1995, Green Light s ® e xpanded into Energy Star® Buildings— a strategy that optim izes whole-buildi ng energy-efficiency opportunities. The energy needed to run com m e rcia l and industrial buildings in the United States produces 19 percent of U.S. carbon dioxide em issions, 12 percent of nitrogen oxides, and 25 percent of sulf ur dioxide, at a cost of $110 billion a year. If im plem ented in every U.S. com m e rcial and industrial building, the Energy Star® Buildings upgrade approach could prevent up to 35 percent of the em issions associated with these bu ildings and cut the nation’s energy bill

Sector Notebook Project 111 Novem b er 2002Pulp and Paper Industry A ctivities and Initiatives
by up to $25 billion annually.

The m o re than 7,000 participants include corporations, sm all businesses, universitie s, health care facilities, nonpr ofit organizations, school districts, and federal and local governm e nts. Energy Star has successfully delivered energy and cost savings across the count ry, saving businesses, organizations, and consum ers m o re than $5 billion a year. Over the past decade, Energy Star has be e n a dr i v ing force behind the m o re widespread use of such technological innovations as LED traffic lights, efficient f l uorescent lighting,
power m a nagem e nt system s for office equipm e n t, and low standby energy

use.

Manufacturers can becom e partners in Energy Star by pledging to undertake the f o llowing steps:

1. Measure, track, and benchm ark their organization’s energy perform a nce by using tools such as those offered by Energy Star 2. Develop and im plem ent a plan to im prove energy perform a nce 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, a nd highlight our achievem e nts 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.shtm l.)

NICE 3

The U.S. Departm e nt of Energy adm i nisters a grant program called The National Industrial Com p etitiveness through Energy, Environm ent, a n d Econom ics (NICE 3 ). 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 becom e more energy-efficient and cost-com petitive through
waste m i nim i zat i on e fforts. Grants are used by industry to design, test, dem onstrate, and assess the feasibility of new processes and/or equipm ent with the potential to reduce pollution a nd increase energy efficiency. The
program is open to all industries; howev er, priority is given to proposals from participants in the chem icals, agricu lture, alum inum , pulp and paper, glass,

m e tal casting, m i ning, petr oleum
, and steel industries. (Contact: DOE’s Gol d e n Fi eld Office 303-275-4728, or see the website at www.oit.doe.gov/nice3 .)

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EPA Audit Policy

The U.S. Environm ental Protection Agency (EPA) e n c ourages com p anies with m u ltiple f acilities to take advantage of the Agency' s Audit Policy (Incentives for Sel f

- P olicing: Discovery, Disclosure, Correction and Prevention of Violations, 65 Fed. Reg. 19618 (April 11, 2000) ) to conduct audits and develop environm ental com p liance system s. The Audit Policy elim inates gravity-based penalties f o r com p anies that voluntarily discover,
prom ptly disclose and expedi t i ously correct violations of federal environm ental law. More inf o rm ation on EPA’ s Audit Policy can be obta i ne d from the W e b site at: http://www.epa.gov/com p liance/resources/policies/ incentives/ auditing/index.htm l

. Small Business Compliance Policy

The Sm all Business Com p liance Policy prom otes environm ental com p liance

am ong sm all businesses (those with 100 or fewer em ployees) by providing incentives to discover and correct environm ent a l problem s. EPA will elim inate or signif i cantly reduce penalties f o r sm all businesses that voluntarily discover violations of envi ronm ental law and prom ptly disclose and correct them . A wide range of resources are available to help sm all businesses learn about environm ental co m p liance and take advantage of the Sm all Business Com p liance Policy. These resources include: training, checklists, com p liance guides, m e ntoring program s, and other activities. Bus i ne s s e s can find m o re inform ation through links on the W e b site: http://www.epa.gov/sm allbusiness/.

Compliance Assistance Clearinghouse

The National Environm ental Com p lia nc e Assistance Clearinghouse is a W e b-based clearinghouse designed to provide quick access to com p liance assistance tools, contact s, and planned activities across EPA and other

com p liance assistance providers. The Clearinghouse also serves as a forum to collaborate and exchange inform ation. The Clearinghouse provides links
to com p liance assistance activities, tool s, or technical assistance that: 1) assist the regulated com m unity in understanding and com p lying with environm ental regulations ; or 2) assist com p liance assistance providers in helping the regulated com m unity to co m p ly with environm ental regulations. The Clearinghouse W e b site is http://www.epa.gov/clearinghouse/.

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VIII.B. Trade Association/Industry Sponsored Activities

VIII.B.1. Environmental Programs

Global Environmental Management Initiative

The Global Environm ental Managem e nt Initiative (GEMI) is m a de up of group of leading com p anies dedicated to fostering environm ental excellence by business. GEMI prom otes a worldw ide business ethic for environm ental

ma na gem e nt and sustainable developm ent, to im prove the environm ental perform a nce of business through exam ple and leadership. In 2001, GEMI’s

m e m b ership consisted of about 40 m a jor corporations including the pulp and
paper com p any Georgia-Pacific. (C ontact: GEMI at 202-296-7449 or see the website at: www.gemi.org .)

ISO 14000

ISO 14000 is a series of internationally -accepted standards f o r environm ental

m a nagem e nt. The series includes standards for environm ental m a nagem e nt system s (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 Septem ber 1996, while other elem ents of the ISO 14000 se ries are currently in dr a f t for m

. W h ile regulations and levels of envir onm ental control vary from country to

c o untry, ISO 14000 attem p ts to provide a com m on standard for environm ental m a nagem e nt. The governing body for I S O 14000 is the International Organization for Standa r d ization (ISO), a worldwide federation of over 110 country m e m b ers based in Geneva, Switzerland. The Am erican National Standards Institute (ANSI) is the United States representative to ISO. Inf o rm ation on ISO is available at the f o llowing Internet site: http://www.iso.ch/iso/en/ISOOnline.openerpage

. 50 Percent Paper Recovery Goal

A t the beginning of this decade, the U

. S. paper industry m a de an unprecedented public com m itm ent to expand paper recovery and recycling by establishing a goal to recover 40 percent of all the paper Am ericans used in 1995. That program involved a wide a rray of tools to encourage efficient paper recovery as well as a m a jor fi nancial com m itm ent by U.S. paperm akers to expand recycling capacity at their m ills. The public-private partnership that evolved proved enorm ously succe ssful: the industry' s goal was achieved a year ahead of schedule.

Given the success of this initiative, th e industry, through its trade association, the Am erican Forest & Paper Associa tion, established a new goal to recover 50 pe r c e n t of all the paper Am ericans use and to continue its work to

Sector Notebook Project 114 Novem b er 2002Pulp and Paper Industry A ctivities and Initiatives

prom ote ef f i cient paper recovery progr am s. 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 Allian ce (RPA-100%) is a group of leading North Am erican recycled paperboard m a nufacturers represent i ng near l y t w othirds of the recycled paperboard industry, and a sponsor of Am erica Recycles Day.

RPA-100% encourages packaged goods and com p anies to use 100% recycled paperboard and educates consum ers a bout the im portance of buying recycled. Alm o st fifty com p anies have joined a new intiative from the 100% Recycled Paperboard A lliance, displaying the " 100% Recycled Paperboard" sym bol on their brand nam e and private label products. (Contact: 100% Recycled P a p e rb oard Alliance at 877-772-6200 or see the website at www.rpa100.com .)

Agenda 2020

I n 1994, the Am erican Forest and Pape r Association joined with the U.S. Departm e nt of Energy to launch Ag enda 2020, an innovative, collaborative research program . Through Agenda 2020, a consortium of research institutions, industry, and national l a bor atories is developing new technologies, processes and m easurem ents t o ma nufacture products m o re efficiently and cost-effectively while reducing environm ental im pacts of operations and m a xim i zing the efficient use and reuse of resources.

To m eet these objectives, Agenda 2020 has identified six technology focus areas for collabor a t i v e research efforts. These six task groups represent a broad cross section of the forest products industry:

1. Sustainable Forest Managem e nt 2. Environm ental Perform a nce 3. Energy Perform a nce 4. Im proved Capital Effectiveness 5. Recycling 6. Sensors and Controls

Particularly noteworthy is the effort within the Agenda 2020 partnership to de velop biom ass gasification technologies. If fully com m e rcialized, t h e s e technologies could m a ke the U.S. forestproducts industry totally energy selfreliant and generate a surplus of 22 gi gawatts of power to the grid—the equivalent of one-half of California’ s peak sum m e rtim e electric use. The carbon displacem ent from biom ass gasificatio n co u l d b e ev en m o re dram atic,

Sector Notebook Project 115 Novem b er 2002Pulp and Paper Industry A ctivities and Initiatives

transform i ng the industry from emitting 24 m illion tons of carbon each year
to displacing at least 18 m i l lion 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 biom ass fuel c r e a t e d during the chem ical pulping process. Gasification conve r t s these pulping extractives and other form s of biom ass into com bustible gases t h a t can be ef

f i ciently burned like natural gas. If f u lly com m e rcialized, these technologies could produce enorm ous energy and environm ental benefits. The f i rst com m e rcial-scale biom ass (black liquor) plant is being built by Georgia-Pacific Corp. in Big Island, VA. It is slated to go on-line in 2003. Other com m e rcialization tests will continue over the next 10 years, if adequately funded. Industry participants are putt i ng up 50 percent of the investm e nt capital for these dem onstration pr oj e c t s

. (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 Am erican Forest and Pa per Association (AFPA), form erly the A m erican Paper Institute (A PI). Th ey have been actively involved in a

num ber of recent rulem a kings (under CAA, CW A and RCRA) that will affect their m e m b ers. The National Council of the Paper Industry for Ai r and Stream Im provem e nt (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 dissem i nate tec hni c a l inform ation to production facility staff throughout the U.S.

Am erican Forest and Paper Association 1111 19th Street, NW Mem b ers: 450 Suite 800 St aff: 140 W a shington, DC 20036 Contact: Josephine Cooper, Phone: 202-463-2700 V.P. for Environm ent and Fax: 202-463-2471 Regulatory Affairs Internet: www.afandpa.org

The National Forest Products Associati on m e rged with the Am erican Paper Institute (API) in 1993 to b ecom e the Am erican Forest and Paper Association (AF&PA). AF&PA is the national trade association f o r the f o rest, pulp, paper, paperboard, and wood products industry. The organization focuses on inform ation gathering/dissem i nation, re search on industry technical issues, and represents the industry in regulatory and legislative m a tters. The AF&PA takes an active role by representing its m e m b ers bef o re

Sector Notebook Project 116 Novem b er 2002Pulp and Paper Industry A ctivities and Initiatives

governme nt a l a g encies, such as on the recent integrated air and water rule. Som e current environm ental initiatives include the 2020 Research Agenda, 50 percent recycling goal, and the Su stainable Forestry Initiative. The AF&PA publishes a variety of doc u me nts for and about its m e m b ership. Som e relevant publications include the annual industry wide reviews Capacity Report and Statistics of Paper, Paperboard, and Wood Pulp , the Paper, Paperboard, and Wood Pulp M onthly Statistical Summary , and the Dictionary of Paper , published every ten ye a r s

. Circulation for these publications is listed at 1,000. The AF &PA holds an annual m e eting every March in New York City.

National Council of the Paper Industry for Air and Stream Im provem e nt P.O. Box 13318 Mem b ers: 78 Research Triangle Park, NC 27709 St aff: 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 f o r Air and St r eam Im provem e nt (NCASI) presently conducts research on environm e n t a l problem s related to indus t r ial forestry and the m a nufacture of pulp, paper, and wood products. NCASI produces tec hnical docum ents on environm ental issues facing the pulp and paper indus try and conducts industry conferences. Publications include: a biweekly bulle tin 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 Mem b ers: 33,000 St aff: 95 Budget: $13,000,000 Contact: Charles Bohanan Technical Divisions Operator

The Technical Association of the Pulp and Paper Indus t r y (TAPPI) represents executives, m a nagers, engine e r s , r e s e a r c h scientists, superintendents, and technologists in the pulp, packaging, paper, and allied industries. Founded in 1915, TAPPI is split into eleven divisions, which include: e nvironm ental, research and developm ent, paper and board

m a nufacture, and pulp m a nufacture. Though its headquarters are in Atlanta, TAPPI is also divided into 27 regional groups. Overall, TAPPI provide s a variety of s e r v i c e s to its m e m b ers. TAPPI conducts conferences on topics such as forest biology, environm ent, packaging, pulp m a nufacture, and R&D

Sector Notebook Project 117 Novem b er 2002Pulp and Paper Industry A ctivities and Initiatives

in addition to a mor e ge neral annua l conference. TAPPI also develops testing m e thodologies for process cont rol and laboratory analysis. The m a in annual project of the TAPPI Environm ental division consists of an environm ental issues industry c onference. In 1995, TAPPI launched a

cam paign to educate the public on industry e nvironm ental facts. TAPPI publications include a n annual Membership Directory , a m onthly TAPPI Journal , and the publication of research results. TAPPI' s publications are available via an online catalogue and r ecord retrieval systemcalled TAPPInet available at 800-332-8686.

Paper Industry Managem e nt Association 1699 W a ll Street, Suite 212 Mem b ers: 5,000 Mount Prospect, IL 60056 St aff: 14 Phone: 847-956-0250 Budget: $2,000,000 Fax: 847-956-0520 Contact: Scott Baum ruck, Chief Internet: www.pima-online.org Operating Officer

The Paper Industry Managem e nt Association, or PIMA, is a profess i onal
organ i zatio n o f p u l p , paper m ill, and paper converting production executives. The association has provided m a nagem e nt oriente d i n form ation to its

m e m b ership since 1919. This asso ciation goal is em bodied by their publications: an annual Handbook of the industry, a m onthly PIMA Mag a

z in e dedicated to im proving efficiency and productivity, and the annua l PIMA Pulp and Paper Mill Catalog r e ference for industry m a nagem e nt. This catalog contains inform ation regarding equipm ent, raw m a t e r i als, and chem ical products, in addition to a trade nam e directory, a l i s t i ng of

m a nufacturers and suppliers, and a listing of reports relevant to pul p a n d
paper m a nufacture.

Sector Notebook Project 118 Novem b er 2002Pulp and Paper Industry C ontacts and References

IX. CONTACTS/ACKNOWLEDGMENTS/R ESOURCE MATERIALS/BIBLIOGRAPHY

For further inform ation on selected topi cs within the pulp and paper industry a list of publications and contacts are provided below:

Contacts 4

Name Organiz ation T elephone/Email Subject

Scott Throwe U.S. EPA, Office of Com p liance 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 Com bustion MACT NESHAP Subpart S

Jeff Telander U .S. EPA, Office of Air and Radiation 919-541-5427 telander.jeff@epa.gov Non-com bustion MACT NESHAP Subpart MM

Don Anderson U.S. EPA, Office of Wa t e r 202-260-7189 anderson.donald@epa.gov Effluent guidelines and standards

Deborah Nagle U .S. EPA, Office of Wa t e r 202-260-2656 nagle.deborah Cooling water intake standards

Tim Sm ith Office of Air and Radiation 919-541-4718

sm ith.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. Departm e nt of Energy, Office of Industrial Technology 202-586-8501 dickson.ozokwelu@ee.doe.gov Technologies and processes with the potential for energy, environm ental, and cost savings

Jam e s Bond USDA Forest Service 608-231-9480 jbond@fs.fed.us Research on environm entally benign and resource-conserving processes for the production and utilization of wood pulp fibers and chem ical byproducts

4 Many of the contacts listed above have provided valu able background inform ation and com m e nts during the developm ent of this docum ent. EPA appreciates this support and acknowledges that the individuals listed do not necessarily endorse all statem ents m a de within this notebook.
Sector Notebook Project 119 Novem b er 2002Pulp and Paper Industry C ontacts and References

General Profile

AF&PA, 1999. 1999 Statistics: Data Through 1998 . Am erican Forest & Paper Association.

McLaren, J et al., 2000. “North Am erican 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. Departm e nt of Com m e rce/International Trade Adm i nistration, 2000. U.S. Industry & Trade Outlook 2000. U.S. Departm e nt of Com m e rce, McGraw-Hill.

U.S. Departm e nt of Energy, 2000. “Forest Produc ts Project Fact Sheet: Closed-Cycle Bleach Kraft Pulp Production.” Office of Industrial Technologies. October.

U.S. Environm ental Protection Agency, 1993. Development Document for Proposed Effluent Limitations Guidelines and Standards for the Pulp, Paper, and Paperboard Point Source Category. October.

U.S. Environm ental Protection Agency, 1999. Toxics Release Inventory Database.

Process Descriptions and Chemical Use Profiles

AF&PA, 1994. 1994 Statistics, Data Through 1993. W a shington, D.C.: Am erican Forest and Paper Association.

AF&PA, 1995a. Improving Tomorrow’s Environment Today . January.

Sector Notebook Project 120 Novem b er 2002Pulp and Paper Industry C ontacts and References

AF&PA, 1995b. Personal com m unication.

AF&PA, 1995c. Recovered Paper Deinking Facilities . Am erican Forest and Paper Association: Econom ics and Materials Departm e nt. 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. W r itten com m e nts from Richard W a sserstrom to Seth Hem i nway, EPA Office of Com p liance. March 7.

Richard J. Albert, "Ef f l uent-Free Pulp Mill Possible with Existing Fiberline Equipm ent," Pulp & Paper , 68(7), July 1994, pp. 83-89.

Alliance for Environm ental Technology, 2001. “Trends in W o rld Bleached Chem ical Pulp Production: 1990-2000.” January. http://www.aet.org/reports/market/aet_trends_2000.html

.

Am erican 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
, "Com prehensive Im pact Analysis of Future Environm entally Driven Pulping and Bleaching Technologies," 1992 TAPPI Pulping Conference
, Boston, MA.

David Forbes, "Mills Prepare for Next Cent ury 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 Novem b er 2002Pulp and Paper Industry C ontacts and References

Sm ook, G.A., 1992. Handbook for Pulp & Paper Technologists

. Second edition. Vancouver: Angus W ilde Publications.

U.S. Departm e nt of Com m e rce, 2000. U.S. Industry & Trade Outlook 2000 , McGraw-Hill Com p anies and U.S. Departm e nt of Com m e rce/International Trade Adm i nistration.

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 ( N

ESHAP)

.

U.S. EPA, 1995. Office of W a ter, Personal com m unication. June.

U.S. EPA, 2002. Personal com m unication from Jacquelyn Vega, National Enforcem ent Investigations Center, to Seth Hem i nway, Office of Com p liance. March 1.

VDP, 1997. Papier ‘97 - Ein Leistungsbericht. Verband Deutscher Papierfabriken: Bonn, Germ any.

Chemical Releases and Transfers

Air & W a ste Managem e nt Association, 1992. Air Pollution Engineering Manual

.

Sector Notebook Project 122 Novem b er 2002Pulp and Paper Industry C ontacts and References

U.S. EPA, 2001a. AIRS Database. Offi ce of Air and Radiation. Novem b er.

U.S. EPA, 2001b. Toxics Release Inventory Database.

Pollution Prevention

Chlorine-Free Bleaching of Kraft Pulp: Feasibility Study , sponsored by Dom t ar Inc., the Ontario Ministry of the Environm ent, and Environm ent Canada, June 1993. Available from Great Lakes Pollution Prevention Centre 519-337-3423.

Howard Deal, "Environm ental Pressure Causes Changes in Bleaching Technologies, Chem icals," Pulp & Paper , Nov. ' 91.

Bruce Flem ing, 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 W o rkshop-- 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 . Novem b er.

U.S. EPA, 1998. Pulp and Paper NESHAP: A Plain English Description . Novem b er.

U.S. EPA, 1999a. Kraft Pulp Mill Compliance Assessment Guide . May.

Sector Notebook Project 123 Novem b er 2002Pulp and Paper Industry C ontacts and References

U.S. EPA, 1999b. Questions and Answers for the Pulp and Paper NESHAP . Septem ber.

U.S. Governm e nt Printing Office, 2001a. Unified Agenda . Volum e 66, Num b er 93, Pages 26264-26265.

U.S. Governm e nt Printing Office, 2001b. Unified Agenda. Volum e 66, Num b er 93, Pages 26269-26270.

Sector Notebook Project 124 Novem b er 2002Charge your order, It’s easy!

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