Revised Emission Standards for the Pulp and Paper Industry

The EPA is proposing amendments to the national emission standards for hazardous air pollutants for the pulp and paper industry.

As required by the Clean Air Act (CAA), the EPA must set industry air pollution standards that are up-to-date, ensuring that the standards reflect the newest available technology and provide protection for human health and the environment. As such, the EPA is proposing new National Emission Standards for Hazardous Air Pollutants (NESHAP) categorized under Subpart S. Subpart S controls hazardous air pollutant (HAP) emissions from the pulp and paper production areas of mills using the kraft, sulfite, semi-chemical, and soda pulp processes (MACT I) and HAP emissions from pulp and paper production areas of mills using mechanical, secondary fiber, and non-wood pulping, and papermaking systems at all mills (MACT III).

In February 2011, the EPA issued an information collection request (ICR), pursuant to CAA section 114, to United States pulp and paper manufacturers to gather information needed to conduct the regulatory reviews required under CAA sections 112(d)(6) and (f)(2).

According to results of the EPA’s 2011 pulp and paper ICR, there are a total of 171 major sources in the United States. Wisconsin is the state with the largest number of employees in the paper manufacturing subsector, with over 38,008 reported in the 2002 census.

The proposed amendments include revisions to the kraft pulping process condensates standards; a requirement for 5-year repeat emissions testing for selected process equipment; revisions to provisions addressing periods of startup, shutdown and malfunction; additional test methods for measuring methanol; and technical and editorial changes. The EPA estimates the new regulations will cost $6.2 million annually for emissions controls, testing, and monitoring.

This is the first in a series of rules being developed for the pulp and paper industrial sector. This MACT rule is the air portion of the Pulp and Paper Cluster Rule. The other portion of the Cluster Rule is the effluent limitations guidelines, pretreatment standards, and new source performance standards developed by EPA's Office of Water.

Comments must be received on or before February 27, 2012, but are best assured of having full effect if the Office of Management and Budget receives a copy of your comments on or before January 26, 2012.

This post was authored by GLLF staff attorney Emily Kelchen.