EPA drafts Clean Water Act/Clean Air Act standards for pulp and paper industry.

recent pulp and paper draft ruling will affect nonwovens as well, although right now the EPA will concentrate only on water issues; proposed ruling expected in October

The Environmental Protection Agency (EPA) is drafting proposed rules to implement effluent control standards under the Federal Clean Water Act and emission reduction standards under the Federal Clean Air Act for the pulp and paper industry.

The rules are expected to be released in proposed form this October and could result in hundreds of millions of dollars of additional equipment and process changes" - especially for manufacturers of bleached wood pulp necessary to meet tougher pollution control requirements.

The proposed rules will also likely include revisions to the current standards for - best practicable control technologies" (BPT) and -best conventional pollutant control technologies" (BCT), which are required for nonwovens manufacturers by the EPA under 40 CFR 430.250.

INDA is working with its members to ensure that the interests of the nonwovens industry are presented to the EPA prior to the release of any proposed rules. Moreover, once the proposed version has been released, INDA will continue working with its members to represent our industry's interests to the EPA before the rule is finalized.

The Regulatory Process

And Impact On Nonwovens

The EPA is under a court order to develop proposed rules regarding limits on air and water pollutants produced by the pulp and paper industry. While air and water standards are typically developed under separate rule-making procedures, issued by separate divisions within the EPA, the process being used in this case is unique in that the EPA win issue an "integrated" rule jointly drafted by its divisions that have jurisdiction over air and water issues.

Under this process, some manufacturers within the pulp and paper industry may find themselves facing tougher pollution control standards for both air and water releases, while others could face new standards on either air or water releases, but not both.

For the nonwovens industry as a whole (an industry that the EPA views as a "subcategory" of pulp and paper manufacturing), the EPA intends to address only water issues under the proposed rule.

While it is possible that its scope may be broadened between now and October, EPA sources have indicated that the agency will limit its review to possible changes in BPT and BCT standards required for nonwovens manufacturers under 40 CFR 430.250.

Changes to pretreatment standards for our industry may be included as well, but the EPA has not yet made a final decision on the matter.

Potential changes to BPT and BCT standards (which were last updated in 1986) would be based on a survey conducted by the EPA in 1990 of nearly 600 pulp and paper mills in the U.S. and a handful of foreign mills as well. The survey was designed, in part, to determine what type of technology is in use throughout the industry and its effectiveness in curbing pollution.

Under current BPT and BCT standards for the nonwovens industry there can be no more than 29.6 kilograms of material that consumes oxygen in water (known as BOD5, this includes mostly chemicals, sewage and organic material) or 29.6 kilograms of suspended solid pollution known as TSS and referred to as "junk that floats" by EPA staff) released on a daily basis for every 1000 pounds of product produced.

In addition, the average daily values for any 30-day period cannot be higher than 16.3 kg of BOD5 and 13.0 kg of TSS.

Recommendations that these standards be raised, based on current industry practices revealed in the survey, could be included in the EPA:S proposed rule.

Certain elements of the nonwovens industry could face a greater burden under the proposed rule, however. For instance, the EPA intends to require that those who produce bleached wood pulp meet maximum achievable control technology (MACT) standards for their air emissions and tough new standards for effluent releases as well.

In a meeting held last month in Durham, NC, the EPA outlined 11 potential "regulatory alternatives" being considered for producers of bleached pulp under the integrated rule. The EPA estimates that the least expensive alternative would result in industry-wide annualized costs of $170 million and the most expensive would require an annualized cost of nearly $1.3 billion.

Next Steps

INDA is currently working with its members to present any relevant information involving BCT and BPT standards to the EPA prior to release of the proposed rule and INDA members have been requested to forward any information that would be helpful to the EPA during its review of these standards as soon as possible.

Regarding issues that apply to elements of the nonwovens industry - but not to the industry as a whole - INDA intends to work with its impacted member companies and with other associations, especially the American Forest and Paper Association (formerly the American Paper Institute), to address these matters.

The EPA has scheduled public meetings to outline its intent in developing these rules and to receive industry input in May, June and July. Based on information obtained during these meetings, the EPA intends to finalize its draft of the proposed rules in late summer/early fall and issue the rules in proposed form by mid-to-late October.