ENVIRONMENTAL FOOTPRINT COMPARISON TOOL A tool for understanding environmental decisions related to the pulp and paper industry

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ENVIRONMENTAL FOOTPRINT COMPARISON TOOL A tool for understanding environmental decisions related to the pulp and paper industry OVERVIEW OF EFFECTS OF DECREASED SOx AND NOx EMISSIONS Introduction Lingering environmental concerns associated with sulfur oxides (SOx) and nitrogen oxides (NOx) emissions prompt continued pressure for further emissions reductions. Forest products manufacturing is one of many industrial sources of these emissions. They originate as products of combustion that accompany steam and power generation, processing of pulping chemicals, and wood drying. In the US, electric utilities are by far the dominant sector for SOx and NOx emissions. In Canada, smelting (for SOx) and upstream oil and gas (for NOx) sectors dominate these releases. Since the 1980s, measures have been taken in North America to reduce atmospheric emissions of SOx and NOx where levels contributed to impaired environmental quality, as well as in response to government mandated performance standards. Considered together, these substances have been implicated in adverse respiratory effects where certain thresholds are exceeded, as well as acidic deposition thought to be of consequence to vegetation, soils, and surface waters. NOx emissions are also known to contribute to ozone formation and deposition-related eutrophication of surface waters. Most recently, SOx and NOx emissions are being scrutinized because of their role in the formation of fine particulate matter, which is an emerging health concern and a contributor to visibility impairment in certain geographic settings (USEPA 2007). SOx and NOx emissions are both largely the result of combustion processes. They differ, however, in the relative contributions from stationary and mobile sources, as indicated in Figures S1 and S2 for sources in the United States (USEPA 2012) and Figures S3 and S4 for sources in Canada (Environment Canada 2012). 3.7 Figure S1. U.S. SO 2 Emissions by Source Category (%), 2010 (USEPA, 2012) 10.1 2.2 2.2 Electric Utilities Fuel Combustion Industrial Fuel Combustion Other Fuel Combustion 13.9 Industrial Processes Mobile Sources 67.9 Miscellaneous

Figure S2. U.S. NO x Emissions by Source Category (%), 2010 (USEPA 2012) 2.5 14.3 Electric Utilities Fuel Combustion 9.5 Industrial Fuel Combustion Other Fuel Combustion 4.0 Industrial Processes 6.6 Mobile Sources 63.2 Miscellaneous Figure S3. Canadian SO 2 Emissions by Source Category (%), 2010 (Environment Canada 2012) 6.6 3.6 24.8 Electric Utilities 18.2 Industry (Fuel Combustion + Process): Smelt Refining + UOG Industry (Fuel Combustion + Process): Other Commercial & Residential Fuel Combustion Mobile Sources 46.7

Figure S4. Canadian NO x Emissions by Source Category (%), 2010 (Environment Canada 2012) 6.8 9.5 Electric Utilities 19.9 Industry (Fuel Combustion + Process): Smelt Refining + UOG Industry (Fuel Combustion + Process): Other 51.6 8.6 Commercial & Residential Fuel Combustion Mobile Sources 3.6 Natural Sources In the U.S., SOx emissions are dominated by stationary sources, foremost among them electric utilities. The fuel combustion-related emissions from utilities are about five times those associated with industrial fuel combustion, the second largest source. NOx emissions are dominated by mobile sources, which are nearly three times as great as those from utility and industrial fuel combustion combined. Emissions reductions since the 1980s have been dramatic. Ambient air quality standards for NO 2 are universally met across the United States, and the new more stringent short-term SO 2 standards are exceeded in just four limited areas in the nation (USEPA 2011). Further reductions in ambient concentrations will occur due to revision of performance standards, declining use of coal by electric utilities and industrial sources, and requirements that utilities and industry address emissions that contribute to regional haze and ozone. Industry Performance The most prominent source of SOx and NOx emissions at a pulp and paper mill is the power boilers that generate steam and electrical energy for the manufacturing process. Both SOx and NOx are the result of the combustion of sulfur- or nitrogen-containing fossil fuels and non-fossil fuels, respectively. Emission levels are driven largely by the choice of fuels, principally fossil fuels fired alone or in combination with wood-derived fuels, along with the facility s approach for controlling these emissions either in situ or postcombustion. The magnitude of boiler emissions in 2010 relative to those from process sources is illustrated in Table S1. Note that in the pulp and paper industry, SOx is typically measured as SO 2. NOx is made up of NO and NO 2, and all the NO is reported as though it were NO 2 (NCASI 2012). Table S1. Prominent Pulp and Paper Industry Sources of SOx and NOx (10 3 tons) Source SO 2 NOx Power Boilers 205 124 Kraft Recovery Furnaces* 29 55 Kraft Lime Kilns* 2 8 Kraft Thermal Oxidizers 1 1 *Includes units at one soda pulp mill

Kraft recovery furnaces are the second largest source after power boilers. Together, boilers and recovery furnaces constitute approximately 98% and 92% of the pulp and paper sector s SOx and NOx emissions, respectively. The pulp and paper industry has a history of reducing emission levels of SOx and NOx. Practices that have been applied or have potential application include increased energy efficiency; use of alternative fuels with low nitrogen and sulfur content or lower emission potential; decreasing the moisture content and increasing the heat value of pulping liquors fired in recovery furnaces; optimization of combustion conditions; and growing use of add-on control technologies. Wood products mills are smaller than pulp and paper mills, have lower overall emissions, and have received less attention over the years. Unlike for pulp and paper, NCASI does not track emission trends from wood products plants or estimate national emissions. SO x emissions from the wood products industry are small enough to be considered insignificant, as few wood products mills combust coal or oil and the amount of sulfur in wood is very small. NO x emissions at wood products plants are significant. Major sources of NO x are boilers, thermal oil heaters, and burners used to direct fire wood dryers. Trend in Pulp and Paper Industry SO x and NO x Emissions For its part, the pulp and paper industry has had a sustained reduction in emissions of SOx and NOx since the 1980s. In the U.S., SO 2 emissions have declined over 70% from 1980 levels despite increases in production. NO x emissions in 2010 were 30% lower than in 1980. Figure S5 illustrates these trends. In Canada, SO 2 emissions dropped by 51% between 2001 and 2010, from 2.29 kg/tonne to 1.13 kg/tonne (production-weighted mean). NO x emissions in Canada were more consistent during this period of time, but were reduced by 11%, from 1.42 kg/tonne to 1.27 kg/tonne (production-weighted mean) (NCASI file information).

Figure S5. U.S. Pulp and Paper Mill Emission and Production Trends, 1980 2010 (NCASI 2012) These reductions, in part, reflect a response to technology-driven regulatory standards, equipment modernization, improved operating and energy efficiency, alternative fuel selection, and industry restructuring.

Opportunities for Improvement Table S2 illustrates the range of observed SOx and NOx emissions from various pulp and paper mill sources, along with emission levels derived on the basis of control technology benchmarks. Data are derived from experience compiled for mills in the United States and the European Union (NESCAUM 2005; IPPC 2001). The span of the data for the various sources illustrates, in part, the physical and operational factors that limit options for emissions reduction, specific to each source type. Other factors include the choice of fuels, the site-specific manner in which total reduced sulfur emissions (TRS) are controlled, and the interdependence of pollutant response to control choices. Challenges to Reducing SOx and NOx There are significant barriers that limit the transfer of utility boiler emission control approaches and performance to industrial sources. Industrial combustion sources have smaller unit size and dimensions; an array of different fuel choices and properties; widely varying loads and capacity utilization generally lower than base-load power plants; greater emission variability; restrictive space limitations; and unique characteristics and process chemistry. The smaller size, lower capacity utilization, and more modest emission levels typically exhibited by industrial combustion sources also skew the economics of emissions control. Large-scale utility boilers enjoy an economy of scale and greater capacity utilization that is not possible for their smaller industrial counterparts. Therefore, the relative cost to achieve a given reduction in emissions may therefore be higher for industrial combustion sources. In addition, further control of SOx and NOx emissions cannot be addressed without considering implications for emissions of other substances from the same combustion sources and impact on related components of the manufacturing process. Non-air quality impacts, both beneficial and adverse, that accompany further controls are addressed elsewhere on this tab of the website.

Emission Source Recovery Furnace Table S2. Range of Observed Emissions of SOx and NOx from Pulp and Paper Mill Sources Observed Emission Levels Control Technology (BACT) a Technique (BATNEEC) b SOx United European United States Union States ~0 to 300 4 to 280 40 to 130 50 to 300 75 to 150 NOx European Union 49 to 127 1.8 to 18 40 to 58 Lime Kiln Observed Emission Levels Control Technology (BACT) Technique (BATNEEC) ~0 to 20 2 to 11 30 to 350 30 to 80 30 to 300 1.8 to 105 125 to 315 49 to 292 Wood and Wood/Gas Fired Boilers Observed Emission Levels Control Technology (BACT) Technique (BATNEEC) 0.025 (AP-42 Factor) 0.01 to 0.045 lbs /10 6 Btu 0.02 to 0.07 Heat Input 0.15 to 0.3 lbs /10 6 Btu 0.15 to 0.3 lbs /10 6 Btu 0.16 to 0.23 Heat Input <10 29 to 49 Wood/Coal and Wood/Oil Fired Boilers Observed Emission Levels Control Technology (BACT) Technique (BATNEEC) Depends upon fuel mix and coal/oil Sulfur content 0.3 to 0.5 lbs /10 6 Btu 0.12 to 0.47 (Oil @ 0.1 to 0.4 % S) 0.25 to 0.7 lbs /10 6 Btu 0.3 to 0.7 lbs /10 6 Btu 0.14 to 0.35 Heat Input a BACT/ Control Technology (United States): A site-specific emission limitation that considers the cost of energy, environment, and economics in developing a degree of emission reduction that is achievable through application of good production processes, control systems, and techniques (Finto et al. 2006). b BATNEEC/ Techniques Not Entailing Excessive Cost (European Union): The most efficient pollution control technique, including controls and management practices taking into account a balance between economic costs and environmental protection achieved (Slater and John 2001).

References Environment Canada. 2012. National Pollutant Release Inventory. http://ec.gc.ca/pdb/websol/emissions/ap/ap_query_e.cfm Finto, K., Harrison, C., Andracsek, R., Gaige, D., and Lomax, S. 2006. Debunking BACT. EM Magazine (a publication of the Air and Waste Management Association) November 2006. http://www.hunton.com/files/tbl_s47details%5cfileupload265%5c1641%5cdebunking_ BACT.pdf Integrated Pollution Prevention and Control (IPPC). 2001. Reference document on best available techniques in the pulp and paper industry. http://eippcb.jrc.ec.europa.eu/reference/bref/_bref_1201.pdf National Council for Air and Stream Improvement (NCASI). 2012. Pulp and paper mill emissions of SO 2, NO x, and particulate matter in 2010. Special Report No. 12-03. Research Triangle Park, NC: National Council for Air and Stream Improvement Inc. Northeast States for Coordinated Air Use Management (NESCAUM). 2005. Assessment of control options for BART-eligible sources. Steam electric boilers, industrial boilers, cement plants and paper and pulp facilities. Northeast States for Coordinated Air Use Management In Partnership with The Mid-Atlantic/Northeast Visibility Union. www.nescaum.org/documents/bart-controlassessment.pdf/ Slater, D. 2001. Integrated pollution protection and control. Chapter 21 in Pollution: Causes, effects and control, ed. R.M. Harrison, 548-562. Cambridge: Royal Society of Chemistry. http://dx.doi.org/10.1039/9781847551719 United States Environmental Protection Agency (USEPA). 2007. Fact sheet - Final Amendments to the regional haze rule and guidelines for Retrofit Technology (BART) determinations. Washington, DC: United States Environmental Protection Agency. http://www.epa.gov/visibility/fs_2005_6_15.html United States Environmental Protection Agency (USEPA). 2011. Sulfur dioxide designations and EPA response. Washington, DC: United States Environmental Protection Agency. http://www.epa.gov/air/sulfurdioxide/designations/state.html United States Environmental Protection Agency (USEPA). 2012. National Emissions Inventory (NEI) air pollutant emissions trends data: 1970-2012 average annual emissions, all criteria pollutants in MS Excel. Washington, DC: United States Environmental Protection Agency. http://www.epa.gov/ttn/chief/trends/index.html