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An estimate of the total annual carbon dioxide ([CO.sub.2]) emissions resulting from compliance with current, proposed, and anticipated federal environmental regulations has been developed for the U.S. forest and paper industry. This estimate of emissions from the industry's primary manufacturing facilities was developed to examine the extent to which other federally mandated environmental goals might need to be balanced against the greenhouse gas emission reduction targets set forth in the Kyoto Protocol. Energy use was estimated for each regulation believed to result in significant energy consumption or savings by calculating the industry-wide electricity, steam, and fuel requirements associated with established or expected control technologies. Estimates were based on industry databases, engineering calculations, U.S. government documents, and the technical literature. Industry-specific [CO.sub.2] emission factors were used to translate energy use into [CO.sub.2] emissions. Based on 1995 data, an estimated 1.45 million metric tons (tonnes) of carbon are emitted annually as a result of current environmental compliance activities. New regulations, which include recently promulgated, proposed, and expected rules, are predicted to increase compliance-related emissions to as much as 2.52 million tonnes of carbon per year. These amounts represent 4.8 and 8.4 percent, respectively, of the industry's estimated total 1995 emissions of30 million tonnes of carbon (11). The [CO.sub.2] emissions predicted to result from compliance with the proposed wood products maximum achievable control technology rule represent about one-third of the total expected from new regulations.

Greenhouse gas emission reduction targets established by the Kyoto Protocol of the United Nations Framework Convention on Climate Change would, if ratified by the U.S. Senate, require that the United States reduce its emissions of greenhouse gases (primarily carbon dioxide ([CO.sub.2]) to a level 7 percent below 1990 emissions. This would have to be accomplished in the 2008 to 2012 time frame. Although reliance on fossil fuels declined by over 40 percent per tonne of product between 1972 and 1997, industry production of pulp and paper increased by over 60 percent over this time frame and is projected to continue to increase over the next two decades (4). Superimposed on the emissions increases due to projected growth in production are increases expected to result from recently promulgated or currently expected environmental regulations. The Kyoto Protocol goal must be considered against the backdrop of these expected emissions increases.

The study discussed herein was undertaken to estimate the extent to which the industry's efforts to comply with environmental regulations might contribute to increased [CO.sub.2] emissions. The intent was to provide a basis for analyzing the potential cross-media impacts associated with these regulations and their significance to the industry's ability to meet the Kyoto Protocol goal. Compliance with environmental regulations often results in energy consumption to operate new or modified processes and pollution control equipment. In some instances, however, the opposite may be true. Some compliance activities involve, for instance, improved recovery of wastes with significant fuel value. Others might result in reduced energy requirements for treatment of wastes or emissions, and some can lead to general improvements in operating efficiencies. Therefore, in examining the energy and [CO.sub.2] implications of complying with environmental regulations, it is necessary to examine both the energy costs and savings attributable to these rules. This requires that each environmental compliance requirement be examined to 1) identify the available compliance strategies; 2) anticipate which strategies will be chosen; and 3) estimate the energy and [CO.sub.2] implications of those choices.

As a first step, a list of existing, proposed, and expected environmental regulations was compiled, and each regulation was assessed for its potential to result in significant energy impacts. For those rules that were deemed to be significant, the existing or likely control technologies needed for compliance were identified, and an industry-wide estimate of the energy use associated with each control was developed. Energy use as electricity, steam, and fuel was calculated as appropriate for each technology. The calculations were based on information taken from industry databases, engineering calculations developed for typical mill installations, and the technical literature.

Energy use values were subsequently used to estimate [CO.sub.2] emissions, using emission factors developed specifically for the forest and paper industry for purchased electricity, steam generated at mills, and fuel used directly for compliance activities. Total [CO.sub.2] emissions are reported in tonnes (thousand kilograms) of carbon per year, to allow direct comparison to other estimates of greenhouse gas emissions.


The existing environmental regulations for which energy and [CO.sub.2] emissions were estimated include: 1) Clean Water Act provisions requiring control of oxygen demanding organic matter (as measured by the 5-day biochemical oxygen demand assay ([BOD.sub.5])) and suspended solids in the effluents discharged from all primary manufacturing facilities; 2) Clean Air Act provisions for controlling particulate matter (PM) from industry combustion sources and total reduced sulfur compound emissions from kraft mills; and 3) effluent limitations guidelines for bleached kraft and sulfite mills, best management practices (BMPs) for spent pulping liquor containment, and Maximum Achievable Control Technology (MACT) standards for hazardous air pollutant (HAP) emissions from pulp and paper mill production sources (commonly known as MACT I), which are components of the so-called pulp and paper industry Cluster Rule.

The proposed or expected environmental regulations for which estimates were prepared include: 1) Cluster Rule HAP standards for pulp and paper process combustion sources (commonly known as MACT II); 2) MACT emission standards for wood panel manufacturing plants; 3) the Industrial Boiler MACT standards for fine particulate air emissions; and 4) implementation of revised National Ambient Air Quality Standards (NAAQS) for ozone. The regulations and their associated parameters and sources for which energy and carbon dioxide emissions were estimated are given in Table 1.

Several other proposed or anticipated regulations were considered but not explicitly included in the [CO.sub.2] estimate. The proposed MACT-based standards for paper coating and flat wood panel coating emissions, the New Source Performance Standards (NSPS) Subpart Db revisions for oxides of nitrogen ([NO.sub.x]), and the Cluster Rule effluent guidelines for the remaining paper industry manufacturing sectors, are all expected to have a relatively small overall impact on the industry's energy consumption. The proposed revisions to the NAAQS for PM, which include proposed standards for fine particulate matter ([PM.sub.2,5]), and the proposed standards to address visibility in Class I areas (regional haze initiative), were not included in the analysis for a different reason. The anticipated requirements of these initiatives for controlling fine particulate matter and its precursors are expected to overlap substantially with those of the expected or proposed Industrial Boiler MACT, MACT II, and ozone NAAQS implem entation regulations.


Methods for calculating energy use varied depending on the availability of information. In some cases, calculations were done by two or more methods to test the validity of the primary method and assumptions. A variety of information sources were used to calculate energy use, including confidential databases of industry combustion sources, engineering calculations developed for typical mill installations, Environmental Protection Agency documents, and other technical literature. The specific calculation methods and assumptions are described in the following sections.


Provisions in the Clean Water Act require mills to treat their wastewater to remove suspended solids and [BOD.sub.5] prior to discharge to receiving streams. Estimates of electricity use for pumping wastewater and treatment plant residuals, primary clarification, secondary (biological) treatment aeration and mixing, and dewatering wastewater treatment residuals, as well as steam and fuel use for residuals dewatering and hauling to landfill were taken from a report prepared for the Department of Commerce [12]. The values were consolidated into five industry categories for which annual production statistics are available. These values were expressed on a per-unit-of-production basis, and were multiplied by 1995 production figures [3] to estimate total energy use by the industry for effluent treatment and disposal of residual solids.

A separate, independent estimate of the electricity needed for secondary effluent treatment, by far the largest component of wastewater treatment energy consumption, was calculated using average industry [BOD.sub.5] loads [8], a widely accepted aeration energy use factor of 4.5 MJ/kg [BOD.sub.5] removed [19], and total industry production values. This second estimate of the power required for secondary treatment was within approximately 5 percent of the first estimate.


Federal and state regulations imposed under the authority of the Clean Air Act require that all pulp and paper mills employ PM controls on combustion source flue gases, and that kraft pulp mills collect and incinerate concentrated sources of reduced sulfur compounds.

Particulate matter controls. -- The amounts of energy used to operate particulate control devices on recovery furnaces, lime kilns, smelt-dissolving tanks, and power boilers were estimated. For each type of combustion source (e.g., coal-fired boiler) the number of sources, the average capacity of those sources, and the number of each type of particulate control device were calculated from industry databases. Flue gas flow factors and scrubber and electrostatic precipitator (ESP) power use factors developed for typical mill installations were applied to estimate the total energy use on an industry-wide basis. Energy requirements for the 197 wet scrubbers [17] on smelt-dissolving tanks were based on an estimate for a typical installation.

Total reduced sulfur controls. -- An estimate of the steam required for ejectors to transport the low-volume, high-concentration (LVHC) noncondensable gases from their sources to their points of incineration was developed for a typical 1,000-tonne-per-day kraft mill. This value was scaled to an industry-wide estimate based on 1995 kraft pulp production. Incineration of the LVHC gases was assumed to require no additional fuel to support their combustion in kilns and boilers. For mills with stand-alone incinerators, fuel use was estimated from a 1995 industry database.

Oxidation of spent pulping (black) liquor is required in mills that employ recovery furnaces in which the flue gas comes into direct contact with the liquor. Energy requirements for black liquor oxidation (BLO) units were estimated for a typical 1,000-tonne-per-day kraft mill. The per-ton value was multiplied by the estimated total 1995 pulp production associated with direct contact recovery furnaces. The majority of the energy consumed is due to a reduction in heating value of the black liquor, caused by partial oxidation of the liquor components. This effect reduces the amount of steam generated per unit mass of black liquor solids burned [1].


Elemental chlorine free bleaching. -- The recently promulgated Cluster Rule contains standards based on the performance of mills that bleach pulp using complete chlorine dioxide ([CIO.sub.2]) substitution (also known as elemental chlorine free or ECF bleaching). An estimate of the total amount of [CIO.sub.2] associated with converting all U.S. bleached kraft mills to ECF bleaching was developed based on assumptions about: 1) the level of [CIO.sub.2] substitution typically used for maximizing product qualities (to establish the baseline); 2) the lignin contents of pulps manufactured by various delignification processes that precede the bleach plant; and 3) typical [CIO.sub.2] charges used in mills that have already converted to ECF bleaching.

Using these assumptions, 1995 production data, and delignification technology installation statistics generated by EPA [17], an estimated 386,000 tonnes of additional [CIO.sub.2] per year will be required to move the entire U.S. bleached kraft sector from baseline to complete substitution levels. A second estimate of the incremental [CIO.sub.2] consumption based on estimated industry chlorine use gave a value 21 percent greater than the first estimate, which suggests that the first estimate is somewhat conservative.

This estimate of incremental [CIO.sub.2] use (386,000 tonnes per year) was used to estimate the total energy consumed to manufacture the additional sodium chlorate (used as a feedstock at mills to generate [CIO.sub.2] and the energy consumed to generate the additional [CIO.sub.2] at mills. A credit was taken for the energy not used to manufacture the chlorine being replaced with [CIO.sub.2] Values published by the EPA [17] for energy use associated with chlorate and chlorine manufacturing were used in this analysis. Although the EPA values were used in this analysis, the credit given by EPA for chlorine elimination based on reducing the output of chlor-alkali plants appears to be overly optimistic, as industry demand for the sodium hydroxide co-produced in these plants is not expected to decrease significantly. It should be noted that the energy consumption and credit, while a direct result of achieving compliance with the Cluster Rule effluent guidelines, primarily occur "off-site" at chlorate and chlorine manufacturing plants.

Improved washing and BMPs. -- In addition to changes in pulp bleaching chemical use, the Cluster Rule will also result in changes in pulp washing and spill control practices. Brown stock pulp washing improvements to achieve a washer loss of 10 kg sodium sulfate or less per 1000 kg of pulp is a component of Best Available Technology [18]. Reductions in inadvertent black liquor losses through BMPs are also part of the Cluster Rule [18]. Both of these control techniques would result in increased recovery of black liquor, which in turn would lead to reduced [BOD.sub.5] loads to effluent treatment systems, increased steam generation from the recovered black liquor solids, and increased steam consumption to evaporate the water recovered with the liquor solids. A reduction in electricity for effluent treatment and a net increase in steam generated from improved washing and BMPs were calculated using average values for incremental evaporation load and solids recovery published by the EPA [15].


Collection and incineration of HVLC gases. -- An estimate of the power required to collect and transport the dilute kraft mill vent gases was developed for a typical 1000-tonne-per-day kraft mill. Boiler energy balance calculations were made to determine the loss in steam-generating efficiency in boilers in which these gases were assumed to be incinerated. The values were used to estimate annual energy use for the entire kraft sector based on 1995 production statistics.

Steam stripping of kraft mill condensates. -- Steam stripping of kraft mill condensates is one of the options to achieve compliance with the new MACT I HAP standards [18]. Industry databases indicate that about one-third of kraft mills already have condensate strippers. The assumption was made that an additional one-third of mills will install this capability, and the other mills will opt for "hard piping" of condensates directly to secondary treatment systems. Thus, about two-thirds of the total kraft production will ultimately incur energy impacts associated with steam stripping.

Electricity requirements for condensate pumping were developed for a typical mill installation. Total steam requirements were estimated based on typical condensate flows (1.6 [m.sup.3]/1000 kg pulp), published values for steam use (200 kg/[m.sup.3]) to achieve the required 92 percent efficiency [17], industry production statistics, and an assumption that 75 percent of the heat applied as steam would be recovered and used in the kraft process.

Stripping and incinerating the volatile organic compounds (VOCs), primarily methanol, from the condensates reduces the [BOD.sub.5] load to effluent treatment and reduces fossil fuel use in mills where the stripper off-gases are incinerated in a lime kiln or power boiler. A credit was taken for reduced fuel use calculated from the total methanol expected to be recovered from both bleached and unbleached kraft mills, the heating value of methanol (21.04 MJ/kg), and an estimation (based on a 1995 industry database) that 65 percent of kraft mills are likely to burn their stripper off-gases in a boiler or lime kiln.

A factor of 1.08 kg of [BOD.sub.5] per kilogram of methanol recovered [6] and a power application of 4.5 MJ/kg [BOD.sub.5] removed [17] were used to estimate the reduction in electrical power required for effluent treatment due to steam stripping of condensates. No credit was taken for reduced generation of treatment plant residuals.


The EPA has proposed standards on PM and gaseous organic HAP emissions from industry and sulfite and semi-chemical process liquor combustion units [19]. As specified in the proposed rule, kraft mill sources were assumed to require upgrades to existing PM controls, whereas sulfite and semi-chemical mill sources were assumed to require new control technologies.

PM HAP standards for recovery furnaces. -- EPA predicts that 52 of the 215 recovery furnaces will require additional particulate matter controls to meet proposed PM HAP standards [19]. Information on specific precipitator design capacities was not available, so the simplifying assumption was made that the precipitators to be upgraded would require one-third more capacity, such that energy use would increase by 33 percent over the average energy currently consumed to comply with existing air rules.

PM HAP standards for lime kilns. -- The EPA predicts that 60 percent of the lime kilns can now meet the proposed PM HAP standard [19]. Since the control technology upon which the standard is based is an ESP or high-efficiency scrubber, it was assumed that 40 percent of the lime kiln scrubbers would require an upgrade to a high-efficiency device, which was assumed to be a 138 kPa pressure drop venturi scrubber. The energy consumption this represents was calculated from the energy use factors used to estimate the requirements under existing air rules, and an assumption that energy requirements are linearly proportional to the drop in pressure across the devices. Of those units in need of upgrading, the non-venturi scrubbers were assumed to be 13.8 kPa devices, and the venturi units were assumed to be 69 kPa devices.

It should be noted that the EPA projected a net energy use reduction as a result of complying with these regulations based on the assumption that all mills currently unable to achieve the new standards would choose to replace their entire scrubber system with an ESP, which is a more energy-efficient technology [19]. The assumption used in our analysis was that the savings in capital associated with reusing an existing scrubber's infrastructure and avoiding installation of an ESP would outweigh the operating energy cost advantage of the ESP.

PM HAP standards for smelt-dissolving tanks. -- The EPA predicts that 75 percent of smelt-dissolving tank vents can now meet the proposed PM HAP standard [19]. The remaining 56 vents would require either that an existing demister unit be replaced with a wet scrubber or that a low-efficiency scrubber be upgraded. Energy use was estimated for a typical (69 kPa system pressure drop) installation, using assumed exhaust fan and scrubbing liquid pump sizes, and multiplying by the number of affected units.

PM HAP standards for sulfite liquor combustion devices. -- To meet the proposed PM HAP standard, the proposed MACT floor for sulfite liquor combustion units is a fiber bed demister [19]. The proposed rule indicates that 13 of the 21 sulfite units already have this technology installed, and the other 8 have some type of wet scrubber. It was assumed that conversion of these eight units to fiber bed demisters would result in no additional energy consumption.

PM and gaseous organic HAP standards for semi-chemical liquor combustion units. -- Seven of the 14 units at stand-alone semi-chemical pulp mills are predicted to require upgrading to the proposed "beyond the floor" MACT, which is a wet ESP followed by a regenerative thermal oxidizer (RTO) [19]. Values for electricity use were taken from the literature for the wet ESP [20] and from 1995 industry data compiled for RTOs deployed at oriented strand-board (OSB) facilities. Each of the seven units was assumed to have an actual flue gas flow rate of 47 [m.sup.3]/sec. It was also assumed that auxiliary fuel would not be required to sustain oxidation in these units.


It was assumed that most panel manufacturing plants would be required to install RTOs on their press and dryer exhaust gas streams to comply with expected gaseous organic HAP emissions standards. Factors for flue gas flow rates were calculated from measurements made by NCASI at many particleboard, medium density fiberboard (MDF), OSB, softwood plywood, and fiberboard plants [9,10]. For RTO systems used to control organic vapors, average natural gas use and purchased electricity (for exhaust fans) factors were developed based on actual energy use for RTOs in OSB plants. It was assumed that these energy use factors would be representative of RTOs on other types of panel plants. Industry-wide natural gas and electricity use values were calculated using the estimated flue gas flows, energy factors, and 1997 production figures [2,5,7].

Industrial boiler MACT. -- This yet-to-be-proposed regulation is expected to require high-efficiency particulate control devices on all industry coal-fired and wood-fired power boilers. Average energy use calculations for venturi scrubbers and ESPs described previously were used as the basis for estimating the incremental power requirements for upgraded particulate control devices. It was assumed that all inadequate scrubbers would be upgraded to high-efficiency scrubbers, and that ESPs would be expanded to increase their capacity. For the potentially affected power boilers, all venturi scrubbers were assumed to be already high-efficiency (138 kPa) units. Other wet scrubbers were assumed to be 13.8 kPa devices requiring upgrading to 138 kPa venturis. Energy use was assumed to be linearly proportional to pressure drop. All ESPs on potentially affected boilers were assumed to require one-third more capacity.

Implementation of NAAQS for ozone. -- Implementation of the revised 1997 NAAQS for ozone will likely require advanced controls on many sources of [NO.sub.x] and VOCs, which are ground-level ozone precursors, in nonattainment areas [16]. Energy use was estimated for collecting and incinerating all vent gases from atmospheric black liquor oxidation units located in the eastern United States. Other sources of VOCs were assumed to be controlled to the degree feasible by the various MACT standards and other applicable standards. Energy impacts associated with transporting the vent gases and incinerating them in a boiler were estimated for a typical mill installation. These values were used to calculate an industry-wide total using 1995 production values for the affected facilities.

Energy use was also estimated for [NO.sub.x] controls on power boilers in the eastern United States. The estimate is shown for two groups of boilers: coal-and oil-fired units larger than 75 GJ/sec., and all other boilers. This was done because the regulation may only affect large coal- and oil-fired boilers. Selective catalytic reduction (SCR) was assumed to be the required [NO.sub.x] control technology. SCR energy requirements for typical coal- or wood-fired units and oil- or gas-fired units were estimated. Energy is used in the form of electricity for fans to move the gases through the SCR unit, and for sootblowing steam to cleanse the catalytic bed and air heater. Boiler PM controls as required by existing and expected regulations were assumed to be sufficient to control excessive fouling of the catalytic bed with PM.


[CO.sub.2] emissions were calculated using the energy use estimates for each regulation. The [CO.sub.2] emission factors are listed in Table 2. The factors represent average or representative [CO.sub.2] emissions associated with an amount of energy consumed. The [CO.sub.2] emission factors for natural gas, coal, and oil used in this analysis are those published by the U.S. Department of Energy (DOE) [14]. No factor was given for diesel fuel, so it was assumed to be the same as distillate oil. The factors for natural gas and diesel fuel were used for those energy estimates where direct fuel use or savings were estimated. The factors for coal and residual oil were used only in deriving the emission factor for steam use.

The [CO.sub.2] emission factor for steam is based on the assumption that all the steam used for environmental controls is supplied from power boilers burning fossil fuels. Biomass fuels (spent pulping liquor and wood waste) were not included in calculating this emission factor because their use is closely tied to facility production rate, and they normally cannot be regulated to meet incremental changes in steam use on a sustained basis. Such changes typically would be met by adjusting the fossil fuel input to power boilers. The industry-specific emission factor for steam is a fuel-weighted average based on 1995 industry coal, oil, and natural gas use estimates [3], [CO.sub.2] emission factors for these fuels [13], and typical fuel-to-steam boiler efficiencies (84.4% for coal, 79.7% for oil, and 81.9% for gas).

Similar to the factor for steam, the [CO.sub.2] emission factor for electricity is based on the assumption that environmental control-related power consumption represents incremental change in usage, which would typically be met by adjusting the amount of electricity purchased from the grid. The emission factor for electricity used in this assessment is a national average value specific to the U.S. forest and paper industry. It represents an average of state [CO.sub.2] emissions factors for purchased electrical power weighted by the amount of pulp and paper produced in each state. The state [CO.sub.2] factors were developed by the DOE, and take into consideration the mix of fuels and methods (i.e., hydroelectric, coal-fired power boilers, etc.) used in each state to generate the electricity available on the grid (13). This approach differs somewhat from the approach used for steam in that the electricity factor is based on power generated from all sources, not just fossil-fuel-based ones. Using only fossil-f uel-based sources for this factor risks oversimplifying the decision-making by utilities in responding to incremental changes in power demand and may overstate the impact of environmental control energy use on total industry [CO.sub.2] emissions.



Estimates of electricity, steam, and fuel use for each regulation and associated controls covered by this assessment are listed in Table 3. Totals for each category can be found at the bottom of the table. The regulations that are the most electricity intensive are the existing water and air rules and the Cluster Rule effluent guidelines. The existing air and MACT I rules are the most steam-intensive regulations, and the expected wood products MACT rule is the only regulation for which substantial direct fuel use is indicated or expected.

Energy use estimates for the implementation of ozone NAAQS are shown in three categories. The first two of these, collection and incineration of spent pulping liquor oxidizer vent gases, and [NO.sub.x] controls on large coal- and oil-fired boilers, are likely to be realized. The third category includes all other power boilers in the eastern United States, many of which may not be required to install [NO.sub.x] controls. Subtracting the energy use associated with operating [NO.sub.x] controls on these other boilers would reduce expected energy use by 83 percent for this regulation, or by about 4 percent of the total energy use for all the regulations considered.

Overall, electricity represents about 47 percent, steam represents about 36 percent, and direct fuel (primarily natural gas) consumption represents the remaining 17 percent of total estimated energy used and predicted to be used to comply with U.S. federal environmental regulations.


Each energy use estimate listed in Table 3 was multiplied by an appropriate emission factor from Table 2 to determine the resulting annual [CO.sub.2] emissions. Table 4 summarizes [CO.sub.2] emissions associated with each regulation, total [CO.sub.2] emissions, and the percentage contributed by each regulation.

Total [CO.sub.2] emissions for the industry for environmental control is 1.45 million tonnes of carbon annually based on 1995 data. Recently promulgated regulations and regulations expected to be promulgated in the near future will generate between about 0.95 to 1.07 million tonnes of additional carbon per year, depending on the number of boilers required to install [NO.sub.x] controls to achieve compliance with the NAAQS for ozone. Almost half of the expected incremental carbon emissions will be attributed to the Cluster Rule effluent and air standards, and another third to the proposed air standards for the wood products sector of the industry.

In general, the estimates of energy use and carbon emissions are considered to be somewhat conservative. However, there are some uncertainties associated with the proposed or expected regulations that could lower the overall estimate. Specifically, the MACT II standards for industry lime kilns could require that all scrubbers be replaced with ESPs. This would lower the estimated increase of 0.95 to 1.07 million tonnes by about 0.05 million tonnes of carbon per annum. Significant changes in the proposed Wood Products MACT regulation are not expected, but widespread adoption of control technologies that are less energy intensive than an RTO could significantly lower the estimate. Uncertainty with respect to ozone NAAQS implementation impacts have been addressed in the calculations.


Compliance with existing air and water pollution control regulations results in the forest products industry emitting approximately 5.37 million tonnes of [CO.sub.2] annually (1.45 million tonnes carbon equivalents). This amount includes both direct emissions from the mill site and indirect emissions related to purchased power and off-site manufacture of important bleaching chemicals. The emissions due to current environmental regulations are divided approximately equally between air- and water-related compliance requirements. These emissions represent 4.8 percent of the industry's mid-1990s annual total [CO.sub.2] emissions, estimated to be 30 million tonnes carbon equivalents [11].

A variety of newly promulgated or currently expected environmental regulations will impact the industry's emissions of [CO.sub.2] during a time when the industry might be called upon to reduce [CO.sub.2] emissions to meet the Kyoto Protocol goal. Key among these regulations are: 1) recently promulgated effluent limitations guidelines governing discharges of chlorinated organic materials from pulp bleaching; 2) recently promulgated rules requiring BMP plans for control of pulping liquors and other pulping by-products; 3) recently promulgated MACT standards requiring control of pulping-, bleaching-, and wastewater-related emissions of HAPs; 4) proposed MACT standards intended to limit HAPs emissions from process-related combustion sources; 5) expected MACT standards for wood panel plants; 6) expected MACT standards for large industrial power boilers; and 7) expected requirements for some facilities to reduce [NO.sub.x] and VOC emissions to address ozone nonattainment issues in eastern states. Although not all o f the new rules will increase [CO.sub.2] emissions (indeed, at least one is projected to reduce [CO.sub.2] emissions) in total, these new and expected environmental regulations are expected to increase the emissions of [CO.sub.2] from the forest products industry by 0.95 to 1.07 million tonnes carbon annually. This represents 3.2 to 3.6 percent of mid-1990s forest products industry total carbon emissions. On this relative basis, the increase may not appear to be significant. However, the absolute amount represents real potential carbon reductions that could be required of the forest products industry.

The authors are, respectively, Senior Research Engineer, West Coast Regional Center of the National Council of the Paper Industry for Air and Stream Improvement (NCASI), P.O. Box 458, Corvallis, OR 97339; Vice President, Water and Pollution Prevention Programs, NCASI, P.O. Box 13318, Research Triangle Park, NC 27709; Program Manager, NCASI, Gainesville, FL; and Vice President and President, EKONO, Inc., 11061 NE Second St., Bellevue, WA 98004. This paper was received for publication in April 2000. Reprint No. 9110.

(*.) Forest Products Society Member.

[C] Forest Products Society 2001.

Forest Prod. J. 51(5):25-31.


(1.) Adams, T.N. 1977. Kraft recovery boilers. TAPPI, Atlanta, GA. p77.

(2.) American Fiberboard Association. 1997. Annual shipments report. AFA, Palatine, IL.

(3.) American Forest & Paper Association. 1997. 1997 statistics of paper, paperboard and wood pulp. AF&PA, Washington, DC.

(4.) _____. 1999. U.S. pulp and paper industry energy report 1998. AF&PA, Washington, DC.

(5.) APA--The Engineered Wood Association. 1997. Annual Rept. APA, Tacoma, WA.

(6.) Barton, D.A., G.T. Hickman, K.O. Matthews, and M.H. Tielbaard. 1998. In: Proc. 1998 TAPPI Inter. Environmental Conf. TAPPI, Atlanta, GA. pp 521-37.

(7.) Composite Panel Association. 1997. Annual shipments report & downstream market survey. CPA, Gaithersburg, MD.

(8.) National Council of the Paper Industry for Air and Stream Improvement, Inc. 1991. Progress in reducing water use and wastewater loads in the U.S. paper industry. Tech. Bull. No, 603. NCASI, Research Triangle Park, NC.

(9.) _____. 1995. Particleboard and medium density fiberboard air emission databases. Tech. Bull. No. 693. NCASI, Research Triangle Park, NC.

(10.) _____. Oriented strandboard and plywood air emission databases. Tech. Bull. No. 694. NCASI, Research Triangle Park, NC.

(11.) _____. 1999. Estimated costs for the U.S. forest products industry to meet the greenhouse gas reduction target in the Kyoto Protocol. Special Rept. No. 99-02. NCASI, Research Triangle Park, NC.

(12.) U.S. Department of Commerce, Office of Environmental Affairs. 1977. Energy requirements for environmental control in the pulp and paper industry. USDOC, Washington, DC.

(13.) U.S. Department of Energy. 1994. General guidelines, voluntary reporting of greenhouse gases under Section 1605(b) of the Energy Policy Act of 1992. Appendix C. Government Printing Office, Washington, DC.

(14.) _____. 1997. Emissions of greenhouse gases in the United States 1996, DOE/EIA0573(96). Appendix B. Government Printing Office, Washington, DC.

(15.) U.S. Environmental Protection Agency, Office of Science and Technology. 1996. Analysis of impacts of BAT options on the kraft recovery cycle. EPA, Washington, DC.

(16.) _____. 1996. National ambient air quality standards for ozone: Proposed rule. Federal Register 61, No. 241 (December 13, 1996). EPA. Washington, DC.

(17.) _____. 1997. Supplemental technical development document for effluent limitations guidelines and standards for the pulp, paper, and paperboard category. EPA821-R-97-011. EPA, Washington, DC.

(18.) _____. National emission standards for hazardous air pollutants for source category: pulp and paper production; effluent limitations guidelines, pretreatment standards, and new source performance standards: pulp, paper, and paperboard category; final rule. Federal Register, No. 72 (April 15, 1998).

(19.) _____. National emission standards for hazardous air pollutants; proposed standards for hazardous air pollutants from chemical recovery combustion sources at kraft, soda, sulfite, and stand-alone semi-chemical pulp mills; proposed rule. Federal Register, No. 72 (April 15, 1998).

(20.) Wark, K. and C.F. Warner. 1976. Air Pollution: Its Origin and Control. Harper & Row, New York. 225 pp.
 Forest and paper industry
 environmental regulations and
 associated controls for which
 [CO.sub.2] emissions were estimated.
Regulation Parameters and sources controlled
Clean Water Act - Existing Biochemical oxygen demand
 Effluent Regulations ([BOD.sub.5]) and suspended solids
 from mill effluents
Clean Air Act - Existing Particulate emissions from boilers,
 Emissions Regulations furnaces, like kilns, and smelt-
 dissolving tank vents; reduced
 sulfur compounds from kraft
 process vents
Cluster Rule - Effluent Chlorinated organic matter from
 Guidelines and Best kraft mill bleach plants; spent
 Management Practices pulping liquor and liquor
 by-product losses from kraft mills
Cluster Rule - MACT I Hazardous air pollutants (HAPs)
 Air Standards from kraft mill process vents and
Cluster Rule - MACT II Particulate HAPs from recovery
 Air Standards furnaces, lime kilns, dissolving
 tank vents, and sulfite furnaces;
 particulate and gaseous organic
 HAPs from semi-chemical liquor
 combustion units
Wood Products MACT- HAPs from medium density fiberboard
 Based Air Standards (MDF), oriented strand-board
 (OSB), softwood veneer,
 fiberboard, and particleboard
 dryers, and MDF and OSB presses
Industrial Boiler MACT Fine particulate emissions from
 coal- and wood-fired boilers
Implementation of Oxides of nitrogen ([NO.sub.x])
 NAAQS for Ozone from all or a portion of the power
 boilers in the eastern United
 States; volatile organic compounds
 (VOCs) from black liquor oxidation
 vents in the eastern United States
 [CO.sub.2] emission factors used.
Form of energy consumed [CO.sub.2] emitted
 (kg carbon/GJ)
Electricity purchased from the grid 39.02
Steam generated at mills from fossil fuels 22.46
Natural gas 13.72
Diesel (assumed same as distillate oil) 18.91
Coal 24.29
Residual oil 20.37
 Estimated annual energy use associated
 with U.S.forest and paper industry
 environmental controls.
Regulation Energy used associated with
Clean Water Act - Existing Primary and secondary effluent
 Effluent Regulations treatment and solids disposal
Clean Air Act - Existing Combustion source PM controls
 Emission Regulations
 TRS gas collection and
 Spent pulping liquor oxidation
 for TRS control
Cluster Rule - Effluent Replacing chlorine with chlorine
 Guidelines and BMPs dioxide in kraft bleach plants
 Recovering additional spent
 pulping liquor
Cluster Rule - MACT I Collecting and incinerating dilute
 Air Standards process vent gas HAPs
 Stripping and incinerating HAPs
 in evaporator condensates
Cluster Rule - MACT II Upgraded PM controls on spent
 Air Standards pulping liquor combustion sources
Wood Products MACT- Thermal oxidizers on press and
 based Standards dryer exhaust gases
Industrial Boiler MACT Upgraded PM control devices on
 coal- and wood-fired boilers
Implementation of Collect and incinerate spent pulping
 NAAQS for Ozone liquor oxidizer vent gases
 New [NO.sub.x] controls on large
 coal/oil boilers
 New [NO.sub.x] controls on all other
Total energy use
Regulation Electricity Steam Fuel
 ([10.sup.3] GJ)
Clean Water Act - Existing 15,440 4,233 138
 Effluent Regulations
Clean Air Act - Existing 8,672 0 0
 Emission Regulations
 0 2,962 605
 958 13,229 0
Cluster Rule - Effluent 8,621 5,378 0
 Guidelines and BMPs
 -1,066 -6,450 0
Cluster Rule - MACT I 328 1,772 0
 Air Standards
 -263 8,158 -2,260
Cluster Rule - MACT II 864 0 0
 Air Standards
Wood Products MACT- 2,704 0 16,256
 based Standards
Industrial Boiler MACT 2,196 0 0
Implementation of 130 198 0
 NAAQS for Ozone
 450 320 0
 2,4l2 [a] 1,198 [a] 0
Total energy use 41,446 30,998 14,739
(a.)These energy amounts may be
overstated if this regulation does
not impact smaller power boilers.
 Estimated annual U.S. forest and paper
 industry [CO.sup.2] emissions resulting
 from federal environmental regulations.
Regulation [CO.sub.2] emissions
 ([10.sup.6] kg carbon)
Clean Water Act - Existing Effluent 700
Clean Air Act - Existing Emissions 748
Cluster Rule - Effluent Guidelines 271
and BMPs
Cluster Rule - MACTI Air Standards 195
Cluster Rule - MACT II Air Standards 34
Wood Products MACT-based Air 328
Industrial Boiler MACT 86
Implementation of NAAQS for Ozone 156 [a]
Total estimated annual emissions 2,518
 related to compliance with
 environmental regulations
Total estimated forest products 30,000
 industry emissions in 1995
 (% of total)
Clean Water Act - Existing Effluent 27.8
Clean Air Act - Existing Emissions 29.7
Cluster Rule - Effluent Guidelines 10.8
and BMPs
Cluster Rule - MACTI Air Standards 7.7
Cluster Rule - MACT II Air Standards 1.4
Wood Products MACT-based Air 13.0
Industrial Boiler MACT 3.4
Implementation of NAAQS for Ozone 6.2
Total estimated annual emissions 100.0
 related to compliance with
 environmental regulations
Total estimated forest products
 industry emissions in 1995
(a.)These emissions may be overstated if
this regulation does not impact smaller
power boilers. The magnitude of the
overstatement is approximately 122 x
[10.sup.6] kg carbon/yr.
COPYRIGHT 2001 Forest Products Society
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 2001 Gale, Cengage Learning. All rights reserved.

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Publication:Forest Products Journal
Article Type:Statistical Data Included
Geographic Code:1USA
Date:May 1, 2001

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