ERI Home IRR Home Last updated 8/11/04
Some industry sectors must appear to environmental regulators as overloaded eighteen-wheelers must look to the highway patrol; others may look like the reckless red convertible weaving from lane to lane. The pulp and paper industry is a regulatory entity of a different sort entirely, perhaps more like the senior citizen in the full-sized fifteen-year-old luxury car proceeding in its measured pace while traffic piles up behind.
The sector certainly carries a lot of weight in the regulatory sense. It is the largest single water consumer of any sector in the national economy, and its products constitute the largest single component of municipal solid waste. Pulp mills announce their presence for miles downwind with emissions of reduced sulfur compounds, and the effluent from their pulp digesting operations may be detectable for miles downstream. As significant producers of combustion energy, they are responsible for substantial quantities of nitrogen oxides and fine particulate emissions, thus contributing to local ground-level ozone and regional haze problems. And just as the seemingly cautious driver might at any moment have a lapse of attention that suddenly puts the vehicle in an unfamiliar situation, it seems that papermaking processes that have been carried out unremarkably for decades are now suddenly found to have unexpected consequences -- the bioaccumulative properties and the genetic effects at minute concentrations of dioxins produced in bleaching operations, for example, or the endocrine disrupting properties of various surfactants.
Yet this venerable sector can point to factors that indicate ways in which it might be considered a solid environmental citizen. Its raw material is a renewable resource -- is even, in fact, a sink for rather than a source of greenhouse gases. Its growing ability to find appropriate uses for recovered fiber has made it one of the recycling success stories of the past decade. It has shown a capacity for great improvement in its manufacturing processes over the years. The main problem facing the sector now is how to take advantage of an array of promising new technologies while living on a fixed income in somewhat straitened circumstances.
The question of impacts, risks, and regulations on this heavily regulated sector has inspired a number of excellent studies and overviews, of which several noteworthy examples appear in the Information Sources section.
Environmental impacts and risks
Effects of existing and future regulations on impacts
The basic constituent of all paper products is cellulose fiber, a natural constituent of plant tissue. Since plants are a renewable resource, harvested materials like wood and paper differ fundamentally from most other common industrial materials, in that they are available in theoretically inexhaustible supply -- so long as world demand does not outstrip the land available for their cultivation.
Otherwise, paper production is analogous to the production of many other materials from their ores or unrefined forms found in nature. Logging operations correspond to mining. Pulping operations correspond to smelting of metal from ores, or to fractionation of petroleum products from crude oil. And downstream operations involving the forming of pulp into finished paper products are analogous to operations like metal forming and finishing. Just as with other materials, the most resource-intensive step in the paper production process, and the step responsible for the highest levels of emissions, is the primary separation of the desired material from the matrix in which it naturally occurs.
In the case of paper, the ability to produce the "ore", rather than simply mining or extracting it, entails a set of environmental impacts not found in the case of metals or fossil fuels. Forest management issues encompass a number of potential environmental problems, ranging through land use questions, habitat destruction, effects of monoculture, and the presence of fertilizers or pesticides in runoff. This analysis will concentrate on that part of the chain involving pulp and paper mills, and will not extend to the upstream production of the source plant material. However, a full life-cycle accounting of the impacts of paper manufacture and use would have to include these matters as well.
The 1997 Economic Census lists 549 pulp, paper, and paperboard mills under NAICS code 3221, of which 39 are pulp producers only, with 293 paper mills and 217 paperboard mills. Many paper mills also manufacture pulp for internal use; plants of this type are referred to as "integrated facilities".
Pulping of primary fiber sources is typically carried out in large plants located close to the source of supply. Thus mills producing pulp from wood are generally located close to forested areas, such as the Pacific Northwest coast, upper New England, the upper Great Lakes, and throughout the Southeast. Secondary fiber from recycled material is a significant and growing source of pulp. Plants producing secondary fiber are more geographically dispersed. This trend is likely to continue as programs to remove paper from municipal solid waste create significant sources of supply associated with population centers all across the country.
Integrated mills, and mills producing finished products from purchased pulp, are as likely to be located closer to their customers as to their suppliers, and are therefore more dispersed geographically than mills specializing in pulp production.
Technical Association of the Pulp and Paper Industry (TAPPI), http://www.tappi.org/index.asp
American Forest & Paper Association (AF&PA), http://www.afandpa.org/
National Council for Air and Stream Improvement (NCASI) http://www.ncasi.org/
Most of the environmental impact from this sector is associated with the manufacturing process (particularly with pulping), with the environmental fate of the product representing a secondary, but still significant concern. (Regarding the impact of the product, it should be noted that paper products constitute the largest single fraction of municipal solid waste. The EPA Municipal Solid Waste Factbook indicates that paper constitutes about 40% by weight of items discarded in municipal waste nationwide in 1995 before recycling, decreasing to about 32% after recycling. However, the effect of the product is due more to its quantity than to its characteristics, since paper is, as waste materials go, relatively benign.)
Focusing on the manufacturing process, TRI data for 1999 indicate that the paper sector as a whole (SIC code 26) represented the following percent total of all sectors:
|
Releases to: |
Air | Water | Land | Off-site | Total |
| Paper (lb) | 185,968,357 | 19,118,393 | 15,268,270 | 5,201,498 | 225,556,518 |
| All sectors (lb) | 2,029,364,423 | 258,881,776 | 4,746,722,774 | 462,215,492 | 7,754,829,609 |
| Paper (%) | 9.2% | 7.4% | 0.3% | 1.1% | 2.9% |
The paper sector as a whole was the third largest contributor of all sectors to total reported TRI air releases in 1999, behind electric utilities at 41%, and chemicals, at 14%. It was the fourth largest contributor to direct water releases, behind chemicals (30%), primary metals (24%), and food (19%). In terms of overall water use, the EPA Sector Notebook for the sector indicates that, "the pulp and paper industry is the largest industrial process water user in the U. S."
Greenhouse gas emissions from a number of energy-intensive sectors have been calculated by NCMS on the basis of 1998 fuel consumption data from the Energy Information Administration (EIA) of the U. S. Department of Energy, and from greenhouse gas inventory data from the EPA (Inventory of U.S. Greenhouse Gas Emissions and Sinks). The results are posted in a summary document, Greenhouse Gas Estimates for Selected Industry Sectors. According to that calculation, the pulp and paper sector was responsible for 198.8 Tg CO2 equivalent (1 Tg, or teragram = 1 million metric tons). This is one of the top five sectors in terms of total greenhouse gas impact (the others being electric power, petroleum refineries, chemicals, and iron and steel mills).
Evaluating the impact of the pulp and paper sector on greenhouse gas emissions is complicated by the fact that atmospheric carbon dioxide is the ultimate carbon source for the sector's product. As long as the carbon is sequestered in paper, it is not contributing to global warming. Thus a case could be made for subtracting some portion of the total greenhouse gas emissions attributable to the sector (primarily due to its energy consumption) to account for the carbon removed from the atmosphere. Such an argument would be most convincing when applied to durable products with an expected lifetime measurable in many decades (such as construction materials), or when applied to products which displace others made from nonrenewable sources (such as packaging materials used as an alternative to plastics derived from fossil fuels). However, much of the output of the sector is back in the atmosphere after a relatively short period of time (having been burned, or having decomposed biologically), and would not account for a meaningful reduction over the life-cycle of the product.
Air emissions data for certain key criteria pollutants (ozone precursors) are available from the National Emission Trends (NET) database (1999), and hazardous air pollutant emissions data are available from the National Toxics Inventory (NTI) database (1996 is the most recent year for which final data are available). For the pulp and paper sector, the total emissions are:
These are significant quantities. For VOCs, the pulp and paper sector is the second highest emitter of all manufacturing sectors, second only to commodity chemicals. For NOx, pulp and paper is the fourth highest, behind electric power, oil and gas extraction, and commodity chemicals. For fine particles, it is second only to electric power. For HAPs, it stands fifth, behind commodity chemicals, construction, petroleum refining, and furniture.
A Progress Report issued by the American Forest and Paper Association (AF&PA) in December, 2002 lists a number of industry benchmarks, based on 1999 data from its members. Among the benchmarks listed for pulp and paper mills are:
Major types of environmental risk associated with the impacts include:
The most significant recent rulemaking activities affecting the pulp and paper sector are referred to collectively as the Cluster Rules (1998). This refers to a set of air and water rules that were issued simultaneously. The rules include:
Estimates of the emissions reductions expected from the NESHAP (as listed in a plain language overview, pp. 8-9) include:
The water quality standards specified under the Cluster Rules regulate concentrations of dioxins and furans (specifically TCDD and TCDF), as well as adsorbable organic halogens (such as chloroform) and chemical oxygen demand (COD). The standards actually represent a compromise that allow the substitution of chlorine dioxide for elemental chlorine in the bleaching process. A stronger set of standards, which would have required technologies that avoided the use of chlorine altogether, was not selected. The consequences of this regulatory choice are discussed in a case study included in a report on Barriers to Environmental Technology Innovation and Use, (1998) from the Environmental Law Institute.
The Regional NOx Transport rule (1998) requires 22 eastern states to institute measures to decrease their overall emissions of nitrogen oxides. The affected states are required to have controls on large industrial sources in place by 2003, and to meet overall NOx limits by 2007. Since individual states have considerable flexibility in devising their own specific implementation plans, the effect on pulp and paper facilities is likely to vary considerably, depending on location.
New standards for emissions of ozone precursors and and fine particles may affect some pulp and paper mills, particularly those impacting ozone non-attainment areas.
The Regional Haze Rule, finalized in 1999, calls for states to establish goals and develop long term strategies for improving visibility, particularly in national parks and wilderness areas. It is possible that pulp and paper mills located in certain regions (such as mills directly upwind of sensitive areas) may be called upon to meet more stringent emissions limits for particulates and aerosol precursors.
The Total Maximum Daily Load (TMDL) program, which defines the maximum amount of pollutants a given body of water can receive and still meet water quality standards, may have a significant effect on the operations of many pulp and paper facilities. Due to their high water use, pulp mills generally tend to be among the most significant impactors of the water bodies on which they are situated. State agencies will be responsible for establishing effluent reduction levels for individual facilities. (On July 16, 2001, the EPA announced that the effective date of the rule would be deferred for 18 months to allow for further review. Final rules are unlikely before about 2003, but TMDL standards are likely to start having a significant effect on water effluent limits sometime this decade.)
The ELI report mentioned above also discusses potential effects on pulp and paper operations due to the Endangered Species Act. These effects mainly concern forest management and pulpwood supply issues, rather than the pulp manufacturing process itself.
The EPA-OECA Sector Notebook on the Pulp and Paper Industry is an excellent source of industry and regulatory information through 1995, at http://es.epa.gov/oeca/sector/sectornote/pdf/pulppasn.pdf
The DoE Office of Industrial Technologies deals with the pulp and paper sector under the Forest Products category in its Industries of the Future program. Useful publications include:
The National Council for Air and Stream Improvement (NCASI) summarizes a number of environmental issues in a discussion of ongoing research topics in its Annual Report for 1999, available at http://www.ncasi.org/publications/ncasi_99.pdf
A path-breaking report from the World Resources Institute (WRI) is tangentially a very useful reference source in this context. The ultimate purpose of the report is to demonstrate a method for estimating environmental risk on a company-specific basis in a financially meaningful way. Understandably, financial consequences and the implications for corporate disclosure requirements are the primary focus of the document. But one element of the demonstrated methodology requires a thorough analysis of potential regulatory developments affecting a given company, and necessarily entails a review covering the industry sector within which the company operates. As it happens, the report used the pulp and paper industry to demonstrate the method on a real-world example, and thus provides a detailed description of future regulatory issues relevant to that sector. As a bonus, the report provides an illuminating discussion of the differential effects that individual regulatory developments would be expected to have on 13 actual (but unnamed) pulp and paper companies. The full report is available at:
Repetto, Robert and Duncan Austin, Pure Profit: The Financial Implications of Environmental Performance, World Resources Institute, 2000, http://www.wri.org/capmarkets/pdf/pureprofit.pdf
Additional information on the pulp and paper sector may be found in a report from the Environmental Law Institute, Barriers to Environmental Technology Innovation and Use, 1998. Chapter Five deals specifically with Technology Barriers in the Pulp and Paper Industry, and focuses on bleaching technology. The full report is available at http://www.epa.gov/opispdwb/ebarr.pdf
A very readable plain language guide to the pulp and Paper NESHAP is available at http://www.epa.gov/ttnatw01/pulp/plainrpt.pdf
The EPA Office of Water maintains a pulp and paper information source page, including links to pages on rulemaking, fact sheets and supporting documents, and technical contacts, at http://www.epa.gov/ost/pulppaper/
The December, 2002 Progress Report from the American Forest and Paper Association (AF&PA) is a good source of environmental performance information for AF&PA member companies. (It also includes health and safety data.) It is available at http://www.afandpa.org/iinfo/environment/EHSpg01.pdf