INTERNETINTERNET EDITIONEDITION

PULP & PRODUCTION

CHAPTER V

ZEROING OUT DIOXIN IN THE GREAT LAKES: WITHIN OUR REACH

June 1996

CBNS CENTER FOR THE BIOLOGY OF NATURAL SYSTEMS QUEENS COLLEGE, CUNY FLUSHING, NEW YORK http://www.qc.edu/CBNS & PAPER PRODUCTION

CHAPTER V

ZEROING OUT DIOXIN IN THE GREAT LAKES: WITHIN OUR REACH

Barry Commoner Mark Cohen Paul Woods Bartlett Alan Dickar Holger Eisl Catherine Hill Joyce Rosenthal

June 1996

This report is the result of the second year’s work on a two-year project, “Economically Constructive Conversion of the Sources Contributing to the Chemical Pollution of the Great Lakes,” supported by The Joyce Foundation.

Printed on 100% post-consumer recycled paper processed without chlorine. TABLE OF CONTENTS

I. Introduction

II. Strategic Approach References

III. Medical Waste Incineration

A. Introduction B. Technical Background C. Economic Analysis of the Alternative Means of Medical Waste Disposal D. Conclusions References

IV. Municipal Solid Waste (MSW) Incinerators

A. Introduction B. The Regulatory Situation C. Implementation of An Intensive Recycling System In the Great Lakes Region D. Direct Economic Impact of the Intensive Recycling Programs E. Other Economic Impacts of Implementing the Intensive Recycling Programs F. Conclusions and Recommendations References Appendix

V. Paper and Pulp

A. Introduction B. Technical Background C. The Environmental Effects of Chlorine Dioxide-ECF and TCF Technology D. Economic Analysis E. Product Marketing and Demand References Appendix

VI. Iron Sintering

A. Introduction B. Technical Background C. Economic Analysis D. Conclusions and Recommendations References

VII. Cement Kilns Burning Hazardous Waste

A. Introduction B. The Regulatory Situation C. Technical Background D. The Economic Consequences of Preventing Dioxin Emissions E. Conclusions and Recommendations References

VIII. Conclusions References V-1

V. PULP & PAPER PRODUCTION

A. Introduction:

The paper and pulp mills that dispose of their effluent into the Great Lakes and their tributary rivers contribute a relatively small part of the total amount of dioxin1 that enters the lakes. Nevertheless, even this effect is important, for however dilute dioxin may be, it becomes concentrated in its passage through the food chain. Moreover, in effluent dioxin is accompanied by a large group of other chlorinated organic compounds, lumped together under the term “AOX”. Although in recent years the industry has made a successful effort to reduce the levels of dioxin in pulp mill effluent and the pulp itself, the levels of AOX and other pollutants remain relatively high. Even the most modern low effluent mills have toxic effects on aquatic organisms. Because of the multiplicity of pollutants produced by paper and pulp production, and the high cost of removing them once they are produced, there is a growing recognition that pulp and paper mills must move toward a design in which effluents, instead of being released, are recycled in a closed loop. As it happens, the technical possibility of achieving such a “Totally Effluent Free” (TEF) pulp mill is facilitated by the design changes that produce a “Totally Chlorine Free” (TCF) system -- which realizes the goal of completely preventing the formation of dioxin to begin with.

For these reasons, despite the considerable reduction in the ’s environmental impact on the Great Lakes, it remains important to consider what can be done to completely eliminate the production of dioxin and other chlorinated pollutants that are now generated by pulp and paper mills.

The response of industry and the regulatory agencies to the problem of waterborne dioxin created by pulp mills contrasts sharply with their response to the airborne sources that we have analyzed. The remedial approach to the airborne sources has relied on tacked-on control devices. In contrast, in the last decade the pulp and paper industry, faced with the issue of dioxin pollution, has made changes in the production process itself, applying the strategy of pollution prevention rather than control. And, like the most familiar successes of pollution prevention -- the more than 95% reduction in airborne lead emissions largely achieved by removing lead from the production of gasoline -- the strategy has worked equally well to reduce the dioxin content of pulp mill effluents. To this extent, the recent effort of the industry to deal with the dioxin problem can be regarded as a salutary example to other industries -- many of which regard pollution prevention as moreof a slogan than a principle of action.

1 As is the general case throughout this report, and noted earlier, we use the term “dioxin” here as it has become commonly used to denote the entire class of toxic polychlorinated dioxins and furans. When discussing empirical measurements or chemical mechanisms however, we will occasionally specify particular dioxin and furan congeners. V-2

B. Technical Background:

1. The basic process:

Wood is chiefly composed of two major substances; both are organic, that is, their molecules are built around chains and rings of carbon atoms. , which occurs in the walls of the plant cells, is the fibrous material that is used to make paper. is a large, complex molecule; it acts as a kind of glue that holds the cellulose fibers together and stiffens the cell walls, giving wood its mechanical strength. In order to convert wood into pulp suitable for making paper, the cellulose fibers must be freed from the lignin. In mechanical pulping this is done by tearing the wood fibers apart physically to create groundwood pulp, leaving most of the lignin intact in the pulp. The high lignin content of groundwood pulp leaves the paper products weak and prone to degradation (e.g. yellowing) over time. Mechanical pulp is used principally to manufacture and some magazines.

In most pulp production -- for example, the kraft (German for strong) process -- lignin is separated from the fibers chemically: wood chips are heated (“cooked”) in a solution of sodium hydroxide and sodium sulfide.2 The lignin is broken down into smaller segments and dissolves into the solution. In the next step, “brownstock washing,” the breakdown products and chemicals are washed out of the pulp and sent to the .3 Kraft unbleached pulp has a distinctive dark brown color, due to darkened residual lignin,4 but is nevertheless exceptionally strong and suitable for packaging, tissue and toweling.

For brighter and more durable products the pulp must be bleached: the color in the residual lignin is either neutralized (by destroying the chromophoric groups5 ) or removed with the lignin. This process traditionally has been accomplished for kraft pulp by chlorine bleaching, usually followed by washing and extraction of the chemicals and breakdown products. This process is not much different than washing clothes: the stains imbedded in cloth fibers are either neutralized by bleach, or broken down and washed out. Thus, the basic steps in pulp production are: delignification; brownstock washing;

2The kraft pulping process is the dominant chemical process in the United States as a whole and in the Great Lakes region. In another chemical process, the , pulp is produced by cooking wood chips in an acidic or neutral solution of bisulfides.

3The processing chemicals are recovered for reuse in this process, but not completely: the air emission of sulfur compounds produce the distinctive aroma of the kraft pulp mill.

4The traditional kraft cooking process removes 80% of the lignin. (Smook, 1992, pg 77).

5Chromophoric groups are particular chemical structures which absorb specific wave lengths of light, giving the substance color. Bleaching agents either restructure or break up the chromophoric groups by oxidation or chlorination reactions, thereby eliminating the color in the pulp. V-3 bleaching; and extraction. Additional bleaching and extraction stages are added to achieve the desired brightness. As the industry has developed, these basic steps have been refined and additional chemicals and sequences introduced. (See Figure V-A in Appendix.)

2. The pollution problem:

Long before the dioxin problem arose, pulp mills were notorious sources of environmental pollution. Although their most obvious environmental effect was foul sulfur odors, the more serious impact was on local rivers and lakes. The spent chemicals and waste products were dumped into the waters. In the 1930's, the industry developed a radical pollution prevention innovation: the brownstock washing was recirculated to a recovery boiler where the pulping chemicals were recovered for reuse and the lignin was used to generate energy. The cost savings made kraft mills more competitive. In the 70's and 80's end-of-pipe treatment dominated pollution reduction efforts in North America. In the Nordic countries the application of the principle of pollution prevention has led to a complex and flexible array of production processes, among them ones that have a crucial impact on the dioxin problem.

The most serious pollution problems have arisen from the use of chlorine in bleaching.6 Emitted into local bodies of water, these pollutants have rendered water unfit for drinking, made fish unsuitable for consumption and seriously harmed aquatic life. Chlorine, in the elemental form of chlorine gas, readily reacts with organic molecules. As a result, when chlorine enters the pulping process it reacts with lignin, its breakdown products, other organic plant components, and chemical contaminants to form numerous chlorinated organic chemicals, many of them toxic. These are referred to, collectively, as “AOX.” By 1993, more than 300 chlorinated organic compounds had been reported in pulp mill bleach plant effluents; but these were estimated to account for no more than 10% of the effluent components (Suntio et al., 1988; USEPA, August 1993, p. 2-10-11). As of 1994, 415 organic substances had been identified (Paper Task Force, 1995c, p. 34).

The bulk of the chlorinated organics (75-90%) are high molecular weight compounds (HMWC’s molecular weight > 1,000), which are difficult to characterize due to their large size and variable structures. The remaining chlorinated organics can be typified as: relatively water soluble (19%); potentially bioaccumulative, relatively fat soluble (0.09%); and bioaccumulative, highly fat soluble (0.1%). Identified chlorinated compounds include: chlorophenolics (phenols, guaiacols, catachols and vanillins);

6Conventional kraft pulp mills’ chlorine-based bleaching operations are responsible for 100% of the AOX, 30% of the BOD, 50% of the COD, 40% of the color, and 30% of the volume of the total pollutants produced by the pulp mill as a whole (Johansson & Fletcher, 1994). V-4

The Pulp and Paper Industry’s Commonly Measured Waterborne Pollutants:

 Adsorbable Organic Halides (AOX): Organic halides are organic compounds containing one or more of the halide atoms (chlorine, bromine, iodine and fluorine) linked to their carbon atoms. Since chlorine is generally the only halide involved in pulp processes, AOX is simply a collective measure of all the chlorinated organic compounds in the pulp mill effluent. They are analyzed by mixing crude effluent with active carbon and measuring the amount of total material and chlorine that is adsorbed on the carbon. Thus, AOX is an aggregate measure and does not reveal the specific chlorinated organics compounds it includes or their toxicities. Specific chlorinated organic compounds are measured on a less regular basis due to expense (e.g. dioxins, furans, phenols).

 Chloroform: Chloroform is toxic and carcinogenic. The highest emissions of chloroforms from chlorine compound bleaching are associated with the use of hypochlorite. The Toxic Release Inventory, published annually by the U.S. EPA, reported that 75% of chloroform releases in the United States in 1989 came from pulp and paper processes. (U.S. EPA, 1991; Mgmt. Inst. For Envir. & Bus., 1994)

 Total Suspended Solids (TSS): Solids from pulp mills consist of dirt, grit, fiber, lignin and other solid wood constituents. TSS can become deposited in receiving waters, blanket and destroy the habitat of bottom-living organisms. Many toxic chemicals, including dioxins, adsorb to TSS, which become vehicles for their release to the aquatic environment.

 Biological Oxygen Demand (BOD): BOD measures the consumption of oxygen in water (usually over a five-day period), resulting from the metabolic activity of oxygen-consuming microorganisms. BOD therefore reflects the effluent’s content of organic compounds, many of which are metabolized and therefore give rise to oxygen consumption. Effluents with high BOD deprive receiving waters of the oxygen necessary to support aquatic life.

 Chemical Oxygen Demand (COD): COD measures the amount of all organic compounds that can be oxidized chemically, for example by reacting with oxygen. It therefore measures not only the compounds that are responsible for BOD, but also the biologically inert oxidizable organics. Thus, COD measurements include compounds that are not readily degradable by microbiological processes. These are often persistent, and may bioaccumulate, as in the case of many toxic chlorinated organics, such as dioxin.

 Color: The primary objective of regulating color in effluent may be aesthetic, but some of the colored compounds are also responsible for long-term biological oxygen demand (BOD) -- i.e., over 20 to 100 days or more (U.S. EPA 1993, p. 2-6). For example, lignin and lignin derivatives are colored, take a relatively long time to break down, and become then capable of being metabolized, therefore contributing to long-term BOD.

 Aquatic Life Toxicity: Serious effects on aquatic life, especially fish, are often seen as the first signal of pollution: habitats are destroyed, populations decrease. However, this is not always the case: many chlorinated organics’ toxicities may bioaccumulate (e.g., dioxins, PCBs, mercury) and travel up the food chain into human consumption, or find their way into drinking water without necessarily affecting fish or other forms of aquatic life. Acute and sublethal effects on specific marine organisms are measured to assess effluent toxicity, but are difficult to generalize to other species. Model ecosystem studies supplement these efforts, but take a longer time to complete. V-5 cymenes; chloroforms; chlorinated dioxins and furans; chloro-acetones, aldehydes, acetic acids (McCubbin, et al., 1992; pp. 123-137).7 The toxicity of some of these chlorinated organics is well known; others have yet to be studied.

The problem of dioxin formation arises because some of the molecular structures characteristic of lignin coincide with the basic dioxin structure but lack dioxin’s chlorine atoms. Consequently, dioxin is almost certain to occur among the chlorinated organic compounds that are formed when chlorine is used in pulp production. Measures of AOX do not reveal the precise quantity of dioxin, but are indicators of its formation in the bleaching process. The Paper Task Force (1995a, pg. 206) concluded that, “The only way mills can ensure that no dioxins are generated during the bleaching process is to eliminate the use of all chlorine compounds.”

3. Modifications in the technology of pulp production that reduce or eliminate dioxin formation: the ECF/TCF issue:

With the recognition that dioxin and other chlorinated organic compounds are important sources of environmental pollution, in recent years the pulp and paper industry has instituted a series of changes in production technology that are intended to diminish their occurrence in pulp mill effluent. Strategically there are two ways in which this can be done. First, since elemental chlorine is essential to the formation of chlorinated organic compounds, the less it is used the less such formation will occur. Second, the removal of organic compounds that can react with chlorine, especially lignin, from the process before chlorine enters it, reduces the formation of chlorinated organic compounds. Both approaches, separately and in combination, have been used in the recent modifications of the pulp industry. They also, not coincidently, reduce other pollutants and often decrease operating costs as well, because costly inputs and treatment of waste products can be diminished. The chief changes are the following:

 Elimination of Synthetic Dioxin Precursors: Dioxin and/or dioxin precursors have been discovered in pentachlorophenol contaminated wood, paint, defoamers, cutting oils, and other inadvertent inputs to pulp-making. The precursors are easily chlorinated in chlorine-based bleaching, to yield dioxin among other compounds. Strict control is necessary for complete elimination. Enforcement can be difficult.

 Modified and/or Extended Cooking (delignification) results in a higher rate of delignification in the first processing stage. Since there is less residual lignin when the pulp is ready for chlorine bleaching, less chlorine is needed, tending to

7Non-phenolic chloro-aromatics (e.g. hexachlorobenzene) are not thought to be formed during chlorine bleaching, since they require pressure or combustion to chlorinate; the small amounts found in pulp effluent must ultimately be attributed to products of the chemical industry which inadvertently accompany pulp inputs. V-6

reduce the formation of chlorinated compounds, and the total quantity of bleach plant effluent (brownstock washing is recycled to the recovery boiler). Extended cooking can be introduced with relatively little capital investment if the existing equipment can be appropriately modified. The addition of anthraquinone can achieve similar results, with no capital expenditure.

 Improved Brownstock Washing: More efficient brownstock washing removes more of the degraded lignin and other wood by-products from the cooking process, thereby sending more of these wastes to the recovery boiler, rather than to the bleach plant where they would be available for chlorination and appear in the effluent as pollutants.

 Oxygen Delignification: Treatment with oxygen after cooking can degrade some of the remaining lignin, and also results in some bleaching. Oxygen delignification/bleaching produces no organochlorines. As in the case of extended cooking, it reduces the quantity of bleaching chemicals subsequently needed and the resulting pollutants. The washing from this stage is recycled to the recovery boiler; this significantly decreases the quantity of bleach plant effluent. A significant capital expenditure is needed to build the tower used to introduce oxygen. If the recovery boiler is at maximum capacity, additional expenditures may be necessary for modification or replacement.

 Ozone Bleaching/Delignification facilitates the use of smaller amounts of bleaching chemicals, thereby lowering operating costs. Ozone bleaching, if followed by hydrogen peroxide, can produce pulp as bright as chlorine processes. Ozone is generally manufactured on-site and therefore requires a substantial capital investment or leasing of an ozone generator.

 Chlorine Dioxide Delignification and Bleaching: The use of chlorine dioxide instead of chlorine to bleach pulp produces much smaller quantities of chlorinated organic compounds. Chlorine dioxide is a more selective delignifier than chlorine; it degrades less cellulose, but is more expensive. Chlorine dioxide is not believed to directly chlorinate organic molecules. However, reactions of chlorine dioxide during the delignification and bleaching process produce a small amount of elemental chlorine, so that some chlorination of organic compounds does occur. Because chlorine dioxide is extremely unstable, it must be manufactured on-site at the pulp mill, at an appreciable capital investment. Some generators can be upgraded to increase capacity at less cost than others.

 Hydrogen Peroxide bleaches without introducing new chlorinated pollutants. It is not an effective delignifier but is highly effective in brightening pulp (destroying chromophoric groups). It is most effective when extended cooking and oxygen delignification precedes bleaching. It can be purchased directly (i.e., it does not need to be generated on-site) and application to the pulp-making process V-7

requires little or no capital investment.

Additional process improvements are listed in Appendix Table V-A.2.

In the mid-1980's it became known that pulp mill effluents contain sufficient levels of dioxin to seriously affect the edibility of fish downstream. This was officially confirmed by an EPA study of five mills in 1987, which found that significant levels of dioxins were present in 60% of the effluents tested, in more than 75% of the pulps, and in 100% of the waste water treatment sludges (MEB, 1994). Based on these findings, the National Wildlife Foundation and the Environmental Defense Fund filed a lawsuit and obtained a consent decree (TetraTech 1990, pg. v). The U.S. EPA and the industry agreed to undertake a more comprehensive survey, the 1988 “104 Mill Study” and develop integrated regulations of air, water and land pollution, the 1993 “Cluster Rules.” It is probably no coincidence that, according to a recent industry publication (AET, 1995), “In the late 1980s the North American pulp and paper industry adopted an ambitious strategy to virtually eliminate dioxin.”

The industry’s effort to reduce the entry of dioxin into waterways has produced significant results. The U.S. EPA’s 1994 (pg. 3-17) draft dioxin reassessment estimated that dioxin effluent emissions were reduced from 356 grams TEQ per year in 1988 to 105 grams TEQ (in 1993) (based only on the tetra 2,3,7,8 dioxin and furan congeners). These results were achieved largely by making changes in production that were designed to reduce the formation of dioxins at various points in the pulp-making process. The first step was the elimination of possible sources of dioxin precursors that may appear in the brownstock pulp before it is bleached: pentachlorophenol contaminated wood chips, cutting and lubricating oils, defoamers, paints, and other chemical additives (Chung et al., 1990; Vaness et al., 1990; LaFleur et al., 1990; Dimmel et al., 1993). The use of advanced computerized control systems led to additional improvement (Bettis 1991, pp. 81-2).

The most significant change in North America in recent years was the progressive displacement of elemental chlorine with chlorine dioxide, a substance already used in the industry to some extent for lignin degradation. Typically, some fraction of the elemental chlorine used in the first bleaching stage (i.e., immediately following the cooking and brownstock washing stages) is replaced by chlorine dioxide.8 Chlorine dioxide can break down and (to some extent) bleach lignin, but it does not readily chlorinate lignin breakdown products (or other organic compounds). Hence, in

8This is peculiar to North America, in the Nordic countries, and modern mills elsewhere, the first bleaching stage usually follows extended cooking or an oxygen delignification stage. V-8

Environmental Regulations. The Canadian and U.S. governments have recently moved to place new limits on the amount of organochlorine compounds that the industry is allowed to discharge into the environment. In 1993 the U.S. EPA proposed regulations (Federal Register, 12/17/93 and 3/17/94) that mandate effluent and air pollutant limitations on pulp and paper mills, based on the “Best Available Technology” (BAT). In 1993, the U.S. EPA determined that the BAT for kraft mills was, oxygen delignification or extended cooking with complete substitution of elemental chlorine by chlorine dioxide for bleaching. (See Table V- 2 below for associated pollutant loadings.) The effect of these proposals was a rapid movement towards investments in chlorine dioxide substitution -- in effect, the ECF approach. The industry associations (AF&PA, NCASI, and AET) have been lobbying the U.S. EPA to relax the proposed AOX regulations to only require 100% chlorine dioxide substitution and not the extended cooking or oxygen delignification. Some U.S. companies that have adopted such technologies have lobbied the U.S. EPA to provide incentives for oxygen delignification (Pulp and Paper Week, April 1, 1996, pg.8-9). Final regulations are planned to be issued in 1996.

The Ontario rules proposed in 1993 (Ontario Gazette, 11/25/93) set a schedule for reduction of organochlorine loadings from pulp mills, with the goal of completely eliminating them by the year 2002. However, the intention of the new government in this regard is not clear. Ontario mills have had continual monitoring of effluent toxicity with direct oversight by the provincial government. Their mills are to reduce AOX emissions to 0.6 kilograms per metric ton of pulp by 1996.

In the Nordic and other European countries, the impact of environmental concerns on the development of pulp process technology has taken a different course. While in North America the industry responded to conventional pollutant problems with large investments in pollution control, primary and secondary treatment of effluent, the Nordic countries invested in pollution prevention, extended cooking and oxygen delignification.9 While these technologies have provided the basis for the development of a lower effluent, lower polluting ECF process than that being implemented in North America, they also paved the way to an alternative approach. Nordic countries have recognized the general desirability of the position developed by the International Joint Commission -- that wherever possible all uses of chlorine should be eliminated from manufacturing processes. In the Nordic countries this has encouraged the development of “Totally Chlorine Free” or TCF pulp- making. Regulations in the Nordic countries have encouraged these pollution prevention technologies and TCF. (See discussion below in section E).

The World Bank (1995, p. 2) identified the most significant environmental issue for the paper and pulp industry to be the use of chlorine bleaching. They determined that TCF is a demonstrated feasible technology for many pulp and paper products and recommended TCF bleaching in these instances.

9These are pollution prevention technologies, because they produce no chlorinated organics and recycle wastes to the recovery boiler. V-9 comparison with chlorine, the use of chlorine dioxide sharply reduces the chlorinated organic compounds (AOX) in the pulp mill effluent. However, even when elemental chlorine is entirely replaced with chlorine dioxide, the amount of AOX in the effluent is not reduced to zero, but by 80%. (See Appendix Table V-A.3) This means that some chlorination of organic compounds occurs even when bleaching is done with 100% chlorine dioxide, and no elemental chlorine is added. This appears to be the result of a tendency of chlorine dioxide to produce a small amount of elemental chlorine through reactions in the bleaching process. Chlorine produced in this way is then capable of chlorinating lignin breakdown products and other organic compounds. When elemental chlorine and hypochlorite is completely replaced by chlorine dioxide (100%), the process is known as Elemental Chlorine-Free (ECF) pulp production. However, as noted above, this term is not entirely correct, for a small amount of elemental chlorine accompanies the use of chlorine dioxide.

Table V-1 distinguishes the three major types of pulp-making and bleaching processes (see also Appendix Fig. V-A). The older, conventional, process uses elemental chlorine for the first delignification and bleaching stage; the chlorine dioxide- ECF process replaces elemental chlorine bleaching with chlorine dioxide; the TCF process uses extended cooking and oxygen to accomplish effective delignification and ozone and hydrogen peroxide -- in place of chlorine and chlorine compounds -- for bleaching.

The chlorine dioxide-ECF process has developed into three tracks:

 ECF-1: Adaptation of old chlorine and hypochlorite stages to chlorine dioxide, with investments in expanded chlorine dioxide capacity;

 ECF-2: Modernized mills with extended cooking and oxygen delignification converted to chlorine dioxide for bleaching (a process encouraged in the 1993 U.S. EPA proposals);

 ECF-3: Advanced mills also with extended cooking and oxygen delignification, that use chlorine dioxide only in the last stage of bleaching, after the pulp has been delignified and bleached by non-chlorine compounds, like ozone and hydrogen peroxide.

ECF-3 technology enables the wastes from all pulping and bleaching stages before chlorine dioxide to be recycled, and leaves little residual lignin to chlorinate and pollute. Union Camp has installed this process in a mill in Virginia. E.B. Eddy has been experimenting with an ozone pilot plant in Espanola, Ontario. Mills using chlorine dioxide ECF-2 and ECF-3 technologies can be converted to TCF processes, without significant additional capital expenditures. V-10

Table V-1 Kraft Chemical Pulping and Bleaching Processes*

Chlorine Dioxide, ECF TCF Process Stage & Elemental Totally Symbol Description Chlorine Adapted Modern Advanced Chlorine Traditional (ECF-2) Low Free (ECF-1) Effluent (ECF-3)

Conventional Delignification. Cooking with sodium Cooking hydroxide (NaOH) and sodium sulphide Yes Yes No No No

(Na2 S) liquor.

Extended Extended delignification with Cooking equipment modification or addition of No No Yes Yes Yes Anthraquinone, Aq.

Brownstock Recovery of cooking liquor and Yes Yes Yes Yes Yes Washing removal of lignin

Oxygen (O2 ) O Extends the delignification process No No Yes Yes

Delignification started with cooking. O2 Yes

Chlorine C Bleaching with further delignification Yes No No No No

Bleaching elemental chlorine, Cl 2

Hypochlorite H Bleaching with Sodium or Calcium Some- No No No No

Bleaching Hypochlorite, NaOCl or Ca(OCl)2 times

Chlorine Dioxide D Bleaching with further delignification, Some- Yes Yes Yes No

Bleaching ClO2 times

Ozone Bleaching Z Further delignification and bleaching for No No No Yes Some-

bright pulp. O3 times

Peroxide P Bleaches lignin and pulp with hydrogen No Rarely Rarely Some- Yes

Bleaching peroxide. H22 O times

Extraction E Caustic extraction (NaOH) of chlorinated and/or oxidized lignin; follows initial or intermediate C, D, or Z Yes Yes Yes No No stage.

Enhanced Eo Enhanced caustic extraction with Some- Some- Yes Yes Some- Extraction Ep oxygen and/or peroxide bleaching. times times times

Successive Bleaching stages are typically repeated Bleaching Stages 2 to 4 times for brighter and whiter Yes Yes Yes Some- Some- pulp. Intermediate stages are usually times times followed by extraction (except for peroxide).

* Kraft pulping is distinguished from soda and sulfite mills by cooking with sodium sulfide. Many of the same bleaching processes can be used for kraft, soda and sulfite mills. Ammonium based sulfite mills may have difficulties with TCF. V-11

All TCF processes require modern oxygen delignification and typically use anthraquinone or mechanical improvements to the cooking equipment for extended delignification. Production of TCF pulp has taken two tracks:

 The use of hydrogen peroxide instead of chlorine dioxide with basically the same capital equipment as ECF-2 (except the chlorine dioxide generation equipment);

 Investments in advanced ozone technology as the minimum effluent ECF-3, but with the use of hydrogen peroxide in the final stage.

The TCF mills can convert to closed loop totally effluent free (TEF) with known technologies. Chlorine dioxide mills that seek to adopt TEF technologies are still in the experimental stage. These mills have the special difficulty of removing chlorine chemicals from the filtrates so as not to damage equipment, and of disposing of the chlorinated organics produced by chlorine dioxide.

C. The Environmental Effects of Chlorine Dioxide-ECF and TCF Technology:

As noted earlier, the development of chlorine dioxide-ECF and TCF technologies have been motivated by the environmental importance of reducing the generation of dioxin and other toxic chlorinated organic compounds. There is evidence that this effort has succeeded in significantly reducing the amounts of these pollutants entering the Great Lakes from pulp mill effluents, but not in eliminating them.

This is evident, for example, from the U.S. EPA’s review of it’s own sample mill studies and it’s evaluation of dioxin data collected by the industry trade association, the National Council of the Paper Industry for Air and Stream Improvement (NCASI). Using the direct facility measurements of the 1988 104 mill study as a reference, U.S. EPA (1994) determined that the tetra-chlorinated dioxin in effluents declined in the U.S. from 356 g TEQ/ year in 1988 to 105 g TEQ/year in 1993, with a statistical variation estimated to be 74-150 g TEQ/yr.10 This amounts to a decrease of somewhere between 60 to 80%. NCASI has estimated a decrease of 90% to 34 g TEQ/yr in 1992. However, U.S. EPA found that NCASI’s method of aggregating the mill data was

10 U.S. EPA (1994, pg. 3-15, citing U.S. EPA, 1990b) has estimated that other dioxin and furan congeners add up to 10% of the TEQ values of the tetra congeners. Clement, et al., (1989) from the Ontario Ministry of Environment, centrifuged large volumes of effluent (480 L), enabling detection of toxic congeners in bleached kraft mill effluent not found by traditional methods. Their results demonstrate the importance of other dioxin congeners and mill-to-mill variance. Additionally, recent research documents shifting AOX composition in ECF effluent. These results suggest that congener distribution is of such variability from mill to mill that any analysis limited to tetra detection is not likely to be an accurate predictor of total TEQ, as U.S. researchers assume. Ontario survey data reported to CBNS reinforce these concerns: dioxin/furan congeners other than tetras were detected, and varied unpredictably from mill to mill. V-12 scientifically unacceptable because of the poor quality of many of the separate dioxin values reported to NCASI, and serious methodological deficiencies of the data collection. U.S. EPA readjusted the NCASI data for its own estimates; unfortunately, the methods used for this purpose are not available to independent researchers because they involve confidential mill data and unpublished U.S. EPA studies and documentation.

The same difficulties seem to apply to the changes in the dioxin content of effluents from the five U.S. kraft and soda mills in the Great Lakes region. The 104 mill 1988 study reported that these mills released 2.62 g TEQ of dioxin, of which we estimate that 2.09 g TEQ reached the lakes. The 1993 data available from NCASI exhibit the same sorts of problems that EPA has noted. It is apparent from the literature that a permanent reduction in the dioxin content of pulp mill effluent can only be accomplished by appropriately changing the production technology -- for example, by replacing elemental chlorine bleach with chlorine dioxide or a non-chlorine agent such as hydrogen peroxide. Thus, two of the Great Lakes mills (Mead, Escanaba, MI, and , Erie, PA), which made such changes in production technology between 1988 and 1993, report a 90% reduction in effluent discharge of dioxin. However, a number of other U.S. Great Lakes mills report similar reductions in dioxin discharges even though there were no reported changes in production technology that would be expected to cause this decrease were introduced during that period of time. Since the 1993 level is generally based on only one measurement, it is quite possible that its low value represented a temporary fluctuation in dioxin discharge rather than a permanent improvement.

Although 1988 dioxin discharge levels for the Canadian (Ontario) Great Lakes pulp mills are unavailable, their more recent measurements do not suffer from the problems noted by the U.S. EPA. Indeed, the Ontario data, although like the U.S. measurements are self-reported, have been confirmed by Environment Canada (IJC 1995, p. 39-40). It is also of interest that although all four Ontario mills had substituted chlorine dioxide for chlorine by 1993, the levels of dioxin in their effluents were generally higher than those reported by U.S. Great Lakes mills that had not made such dioxin-reducing changes in production technology during that same period.

The NCASI reporting procedure allows mills to choose what they consider samples of “representative of mill conditions,” so dioxin level variability and statistical calculations of means are not necessarily provided. What is chosen by a mill manager as representative conditions may be ideal conditions, yielding a downwardly biased estimate. When a mill reports a non-detect, NCASI allows this mill to reaffirm the non- detect status without further testing, provided that in their opinion, relevant mill conditions have not changed. This results in a structured sampling bias from the systematic attrition of data points. Consequently, the NCASI data may have a bias downward. What we see in more rigorous, regular testing with independent oversight, such as the Ontario data, is that samples will be interspersed with detects and non- V-13 detects.

In view of these uncertainties about the dioxin discharge data, it seems prudent to conclude that overall reductions in dioxin levels in the effluents from the Great Lakes pulp mills that can be related to the relevant changes (e.g., substitution of chlorine dioxide for chlorine bleach) in production technology probably reflect about the same reduction reported by U.S. EPA: 60-80%.

These developments have brought the issue of environmental improvement to a new level: should the levels of dioxin and other chlorinated pollutants be further reduced -- indeed to zero -- by eliminating the use of all forms of chlorine in pulp and paper production? The affirmative position is advocated by the International Joint Commission and environmental organizations; many, but not all, industry representatives have argued in the negative.

In order to understand the relative merits of these opposing views, it is useful, here, to clarify the operational meaning of pollution prevention. Pollution prevention is based on the strategy of altering a system of production by eliminating from it the component process that generates the pollutant. The classical example is the prevention of lead emissions from automobiles. This was accomplished by omitting from the production of gasoline the step in which tetraethyl lead is added as an anti- knock agent. This completely eliminates the possibility that lead additives will be emitted when the fuel is used. The component process that is responsible for the generation of dioxin in pulp production has been identified: it is the reaction of elemental chlorine with lignin residues to form dioxins and other chlorinated organic compounds. In this instance pollution prevention means totally eliminating the presence of elemental chlorine in the production system, thus ending any possibility that dioxin will be formed. In pulp production, pollution prevention, as applied to dioxin, means totally chlorine-free production: TCF.

The claim that ECF “virtually eliminates” dioxin in pulp processing also often reflects the fact that whereas measurable amounts of dioxin were found in the pulp and effluent produced by mills using chlorine bleaching, in corresponding measurements at ECF mills most of the readings are “not detected.” As pointed out in the accompanying box, this reading does not mean “zero,” but only that the amount of dioxin is below the level that the particular analytical procedure can detect. Hence, the actual dioxin level may be anywhere between zero and just below the detectable limit.

Although there are approximate methods based on statistical probability of interpreting the meaning of “non-detects,” these methods are applicable only when there is a sufficient mixture of detected measurements with non-detected measurements. In the absence of large sample sets, a good deal of uncertainty remains. Despite this difficulty there is evidence that dioxin is formed in chlorine dioxide-ECF mills and is not formed in TCF pulp mills. V-14

What “non-detect” means.

In spite of the fact that the technology for measuring pollutants in the environment has been improved over the years, there are limits to the measuring abilities of even the very best analytical equipment. When an environmental sample, e.g. a sample of pulp mill liquid effluent, is analyzed for a particular pollutant, such as 2,3,7,8-tetrachlorinated dioxin, there is a detection limit associated with the measurement. If the pollutant is present at an amount less than this limit, then the analytical procedure will not be able to detect it. There are many factors that can contribute to such a limitation. One common factor is “noise” in the electrical circuitry of the measuring technology. The detection limit will be different for each pollutant measured and will depend on the analytical methodology, the equipment utilized, and the nature of the environmental sample. Thus, there can be a different detection limit for the same compound in the same laboratory for a set of river water samples as compared to a set of pulp mill effluent samples.

Typical detection limits reported for dioxin congeners (such as 2,3,7,8-tetrachlorinated dioxin and 2,3,7,8-tetrachlorinated furan) measured in pulp mill effluent samples have been in the range of 1-5 picograms of pollutant per liter of water (1-5pg/lit). The U.S. EPA has typically required pulp mill samples to be analyzed with a detection limit no higher than 10 pg/lit. If the dioxin content of a pulp mill sample is less than the detection limit of the particular analytical situation, then it will be reported as “non-detect.” This does not mean that there are no dioxins or furans in the effluent. It only means that the level is probably less than the stated detection limit. Another confusing reporting practice occurs when dioxin is detected with a sensitive analytical technique, but reported as “below USEPA detection limit 10 pg/lit.” or “non-detect at 10 pg/lit., USEPA approved method,” leading the reader to believe dioxins were not detected. NCASI has extended this rational of non-detect to 100pg/lit for 2,3,7,8 tetrachlorinated furans, because the TEQ is 1/10th of 2,3,7,8 tetrachlorinated dioxin.

In using these data, one must consider that the actual level of each non-detected compound is somewhere between zero and the detection limit for that compound. A value of one- half the detection limit is generally chosen as a mid-range estimate of the compound’s actual concentration. Due to their extreme toxicity, the detection limit issue is of particular concern for dioxins. Because they can bioaccumulate, dioxins can be responsible for toxic effects in aquatic systems even if they are present in water at levels below conventional detection limits. Thus, even though 2,3,7,8-tetrachlorinated dioxin has never been measured above the detection limit in Great Lakes water, it is routinely found in the region’s fish and wildlife at toxicologically relevant concentrations.

Indirect but numerical evidence is available from measurements of AOX in pulp mill effluents. In such effluents AOX represents an unresolved mixture of a variety of chlorinated organic compounds, and a difference in AOX levels can in many instances reflect differences in the degree to which such compounds -- including dioxin -- are formed. Table V-2 summarizes several comparisons of the AOX concentrations in the bleach effluents of modified traditional mills, ECF and TCF kraft pulp mills. It is apparent from these reports that the AOX levels from the TCF plants are reduced at least a thousand-fold in comparison with the ECF plant’s levels -- and are perhaps indistinguishable from background levels. V-15

Table V-2 Pollutant Effluent Loadings of Different Processes: Elemental Chlorine, Chlorine Dioxide-ECF and TCF

AOX BOD5 COD Color Process kg/metric kg/metric kg/metric Pt-Coc ton pulp ton pulp ton pulp Chlorine Bleachinga (same mill, different process)(1) Traditional(1) 7.9 28 100 300 (1) O2 Deliginification 4.7 22 70 100 Modified Cooking & 3.6 20 55 80 (1) O2 Delignification

70%ClO2 /30%Cl2 & 1.9 20 55 65 Modified Cooking & (1) O2 Delignification

Chlorine Dioxide ClO2 Bleaching- ECFb ECF-1 1.5-2.1 8-13 (9) 32-60 23-43 (2) no (9) (8,9) Adapted Traditional (d,2) change ECF-2 .36-69 9.5-10.4 20.1-30.6 19.7-46.8 Modern (3,8) (4)

ECF-3 .04-.082.5-6.5 13.0-22.5 0.5-5.8 (3,4,6) (4,11) Advanced Low Effluent (3,7) (3,7) e TCFb Chlorine-Free nd -.002 8.4-23.0 16-77.8 2.0-6.6 (4,5) (3) (3,5) (3,4) range of technologies TEF (by definition) 0 0 0 0 Notes: a) Chlorine bleaching process combinations are from testing of the same mill. b) ECF and TCF loadings are from commercial mill and pilot mill data. c) Color is measured by chloroplatinate units (Pt-Co) and expressed as kg/metric ton. d) According to McCubbin and Paper Task Force, ECF itself does not have any effect on BOD or COD. e) Detection limits appear to be below .01, but have not been consistently reported. Sources: 1) Galloway, 1991, 2) McCubbin, 1992; McCubbin, et al., 1992, 3) deChoudens, et.al, 1995 4) Bicknell, et.al., 1995, 5) Vice, et.al., 1995, 6) Lancaster, et.al., 1992, 7) Nutt, et al., 1993 8) Panchapakesan, 1991, 9) Johansson and Fletcher, 1994, 10) Helge, 1995, 11) Trice, 1992.

The relative amounts of carbon atoms (C) bonded to chlorine (Cl) atoms in organic effluent wastes is an index (expressed as C/Cl ratio) of the degree of lignin chlorination and may be useful to indicate the degree that toxic chlorinated dioxin is V-16 formed, when quantification of such dioxin is not possible.11 Thus, a C/Cl ratio of 1000 means that, in the mixture of AOX compounds, on average there is only one carbon atom in every thousand to which a chlorine atom is attached -- that is, a low degree of chlorination. Studies of high molecular weight materials (HMWMs), the very large compounds which form the bulk of the chlorinated organics (AOX), yield the following results regarding C/Cl ratios in mill effluents:

 Chlorine dioxide ECF-1 processes produce the highest degrees of chlorination (C/Cl ~ 83-90);

 The process with the greatest delignification prior to chlorine dioxide bleaching (ECF-2) produces intermediate chlorination levels (C/Cl ~ 260);

 The TCF process produces the lowest degree of chlorination, which is “fully comparable to chlorine contents found in naturally occurring humic materials” (C/Cl ~ 590-1400) (Dahlman et al., 1994).

Studies on organic compounds more similar to dioxin, such as phenolics, have had similar results (Tsai, et al., 1994; Schwantes and McDonough, 1994). Kovacs, et al. (1995) discovered chlorinated phenolics in untreated (157µg/L) and treated ECF effluent (54.7µg/L) but none in untreated TCF effluent (the detection limit was 0.1µg/L). Phenolics are likely to be formed from lignin by the same process as dioxin, and may serve as the building blocks for dioxin. The detection of even small amounts of polychlorinated phenolics in the best ECF mills led Tsai et al. to conclude that their findings “support the hypothesis that elemental chlorine can be formed during the initial reaction of chlorine dioxide with some lignin structural units.” Saunamäki (1995, pg. 191), studying chlorinated phenolics and AOX, concluded that “TCF pulping produces no organic chlorine compounds.”

Another indirect method that may reveal the presence of dioxin, and other difficult-to-quantify toxic chlorinated organics, is to compare the sublethal effects (e.g. reproduction and growth) on aquatic life of TCF and ECF effluents. The most recent advanced sublethal toxicity studies have demonstrated that TCF mill effluent is less toxic than the modern ECF-2 effluents, which in turn are less toxic than the adapted ECF-1 effluent (Lövblad and Malström, 1995; Kovacs et al., 1995; Cates, et al., 1995;

11 Even if the bulk of chlorinated organics produced is the less toxic monochlorinated organics, as long as the chlorine to carbon ratio is substantially above natural levels, there will be a greater likelihood that a certain percentage of organic molecules will encounter a free chlorine atom a number of times, resulting in polychlorinated compounds, including dioxins. That is, the greater the chlorine to carbon ratio, the greater the likelihood of the creation of the toxic polychlorinated compounds, including dioxins. V-17

Paper Task Force, 1995c pg. 46).12 The low levels of toxicity observed in TCF effluent is thought to be derived from bioactive compounds naturally occurring in the trees (Paper Task Force, 1995c, pg. 44-50). Södra Cell, a producer of ECF and TCF pulp, found these toxicity studies to be so persuasive as to reverse its previous neutral position on modern ECF vs. TCF with extended cooking and oxygen delignification (often quoted by AET) and advocate TCF’s environmentally superior qualities, leading the company to convert all of its ECF mills to TCF (Södra Cell, 1995).

A direct test of the reality of the difference in dioxin formation at a modern (10%chlorine/90% chlorine dioxide13 ) ECF and TCF mill has very recently been provided by Rappe and Wagman, who measured the tetrachlorinated dioxin (TCDD) and tetrachlorinated furan (TCDF) content of pulp from the same mill operating in both the ECF and TCF configurations (Rappe and Wagman 1995). These measurements were made on the mill’s pulp, using an analytical technique about 30 times more sensitive than the conventional method. (Earlier studies have shown that the total output of dioxin from pulp bleach plants is approximately equally divided among the effluent, pulp, and effluent treatment sludge, U.S. EPA, 1994, pg. 3-16.)

Rappe and Wagman found that even with the highly sensitive analytical method, many of the measurements of TCDD in pulp were “non-detect.” However, all of the measurements of TCDF, which is known to occur at higher levels than TCDD in chlorine bleaching processes, were actual values above the detection limit.14 The TCDF results are summarized in Table V-3. In these computations we have used the numerical values not only for the final pulp, but also for the brownstock pulp and the analytical blank, as reported by Rappe and Wagman, to evaluate a specific effect -- that is, the amount of TCDF that is formed as a result of the bleaching process. For this purpose, it is important to note that the bleaching process -- which is, of course, the crucial difference between ECF and TCF -- acts on the brownstock pulp, which is thereby converted to the final pulp. Hence, any formation of TCDF that is caused by the bleaching process will show up as a difference between the TCDF content of the

12 An earlier laboratory study (O’Connor et al., 1994) showed greater toxicity of untreated TCF effluent and similar toxicity to ECF in treated effluent. Subsequent research has discovered this unusual result to arise from residual peroxide and a laboratory procedure to remove it with sodium meta bi-sulfite. Learning from these and other errors, studies now screen for residual hydrogen peroxide in TCF effluent and chlorate in ECF effluent, conditions easily prevented or removed during regular mill operations. (Nelson et al., 1994; Paper Task Force, 1995c, pg.45; Lövblad and Malstrom, 1995)

13 Some of the older chlorine dioxide generators can produce this amount of elemental chlorine as a by-product. Other mills intentionally bleach in these proportions rather than 100% chlorine dioxide to save on chemical costs or due to limited chlorine dioxide capacity.

14The TCDF analyses reported by Rappe and Wagman measure the concentration for a group of six TCDF congeners as a whole. The group includes 2,3,7,8-TCDF, which is the only toxic TCDF congener. In our discussion of this study we will refer to this group of six TCDF congeners as “TCDF.” V-18 pulp and the brownstock.

In Table V-3 we have corrected the brownstock and final pulp values by subtracting the values of the analytical blanks -- which represent the apparent TCDF value yielded by running the analytical procedure without an actual brownstock or final pulp sample. Then, in order to record the TCDF actually formed in the bleaching process, the corrected brownstock values are subtracted from the corrected pulp values. A clear-cut difference between the ECF and the TCF process can then be seen.

Table V-3: Concentration of 2,3,7,8-TCDF and 5 Other TCDF Isomers in ECF and TCF Pulp Samples (pg/g of pulp)

Mill ECF TCF Sample # 1 # 2 Average # 1 # 2 Average Pulp 0.29 0.25 0.270 0.08 0.09 0.085 Blank 0.05 0.05 0.050 0.04 0.04 0.040 Pulp-blank = Corrected 0.24 0.20 0.220 0.04 0.05 0.045 pulp Brownstock 0.06 0.07 0.065 0.07 0.06 0.065 Blank 0.05 0.05 0.050 0.04 0.04 0.040 Brownstock-blank = 0.01 0.02 0.015 0.03 0.02 0.025 Corrected brownstock Corrected pulp-corrected 0.23 0.18 0.205 0.01 0.03 0.020 brownstock Detection limit: 0.02 pg/g Source: Rappe and Wagman (1995)

 In the ECF process, the brownstock contains an average of 0.015 pg/g of TCDF and the pulp contains an average of 0.220 pg/g. Hence, ECF bleaching produces 0.205 pg/g of TCDF.

 In the TCF process, the brownstock contains an average of 0.025 pg/g of TCDF and the pulp contains an average of 0.045 pg/g of TCDF. The difference between these levels, 0.020 pg/g, would presumably represent the amount of TCDF produced in TCF bleaching. However, this difference, which is equal to the detection limit, is so small that it does not provide reliable evidence that V-19

TCDF was in fact formed. Hence these data, which are the most sensitive analysis of the process, fail to provide evidence that PCDF is formed during TCF bleaching.15

Two major conclusions can be drawn from the available evidence regarding the impact of conventional (chlorine) bleaching, ECF (chlorine dioxide) bleaching and TCF (totally chlorine free) bleaching on dioxin production. First, the substitution of chlorine dioxide for chlorine in the bleaching of virgin pulp can result in about a 10-fold reduction in the formation of dioxin, but does not eliminate it. Second, there is direct evidence, from the most sensitive comparison of dioxin formation in ECF and TCF pulp production, that while a measurable amount of dioxin (specifically, TCDF) is formed in ECF bleaching, there is no evidence that TCDF is formed in TCF bleaching, which is accomplished by the total absence of all forms of chlorine in the bleaching chemicals.

Finally, it should be noted that there is a realistic limit to what can be accomplished even in a TCF system, in which no chlorine in any form is added to the process. It has become literally impossible that any U.S. or Canadian industrial process that is exposed to the open air can be absolutely free of dioxin. As shown in our initial report, our analysis of the movement of the airborne emissions of dioxin in the United States and Canada show that they become widely disseminated in the atmosphere and deposit everywhere as a kind of chemical fallout. Simply stated, even if absolutely no chlorine or chlorine compounds are used in a pulp mill, the mill operations -- like every other activity in industrial countries -- and the trees that are made into pulp -- are exposed to the fallout of airborne dioxin, emitted by thousands of separate sources (most of them incinerators) and carried through the air for thousands of miles (see Cohen et al., 1995).

D. Economic Analysis:

1. The economic feasibility of ECF and TCF technology:

As we have seen, the pulp and paper industry’s response to the need for environmental improvements in the 1990s has been largely based on changes in the technology of production. Earlier, in the 1970s and 1980s their response to environmental regulations was largely to improve end-of-the-pipe control systems -- usually at high cost. However, since then, rather than attempting to control pollutants after they have been produced, the industry has been guided by the strategy of pollution prevention. In economic terms, this process is, of course, governed by investment decisions -- that is, by a company’s willingness and/or ability to undertake the capital expenditures that are needed in order to modify or replace the production

15 In the same study, ECF pulp from a different modern mill (100% chlorine dioxide) was analyzed and also found to produce significant increases in the amount of TCDF and, as represented in TEQ values, in other congeners as well. V-20 equipment. In turn, a major factor that influences the company’s ability to assemble the necessary investment funds is the expected return on the investment. This depends on the impact of the new production process on the price that the product can command, which finally depends on how much can be sold -- that is, on the demand for it.

Thus, in industrial practice, the decision to make a change in production technology depends on the balance between the cost of the necessary investment and the expected returns. Environmental factors can have a powerful effect on both sides of this equation. Changes in process technology that reduce the amount of pollutants generated during production can decrease expenditures for installing and operating pollution control systems required by environmental regulations. Often, these changes involve more efficient use of material inputs. These savings in capital and operating costs can help to compensate for the cost of the capital investment in the new pollution prevention technology.

The replacement schedule for existing, older capital equipment is another crucial factor affecting pollution prevention financial decisions. If existing equipment is physically degraded or obsolete, and therefore needs to be replaced, this can often be accomplished with equipment that prevents pollution at no more cost than replacing it with equipment of the original design. Mill expansions provide similar opportunities. Barriers to pollution prevention investment exist when a plant is still burdened with debt from its existing technology, or is extracting high economic returns from durable equipment it has already paid off. Another case arises when an entire mill production line has been under invested for some time. Such mills may be so obsolete that the company plans to use them until they fully deteriorate, and tend to resist modernization or investment in pollution prevention.

On the other side of the equation, environmental concerns can increase the demand for paper products free of dioxin and other chlorinated pollutants, enhancing the price that such products can command and creating a new distinct, market for them. Especially in recent years, the industry’s investment pattern has been strongly influenced by such environmentally motivated demand, especially for recycled and chlorine-free paper -- generally under pressure from environmental organizations and an environmentally aware public. Accordingly, in evaluating the feasibility of investments in environmentally motivated changes in production technology, it is important to consider as well the impact of environmental factors on both the availability of capital, and on the demand for the new products -- and hence the price at which they can be sold.

The industry has recently made a considerable effort to introduce changes in pulp production that can significantly reduce the levels of dioxin, and more generally of organochlorine compounds (AOX), in plant effluents. As we have seen, the complete substitution of chlorine dioxide for chlorine in the bleaching process (ECF) can reduce AOX levels by about 80%. ECF considerably reduces the generation of dioxin, but V-21 some is still produced during bleaching. In contrast, in the TCF process there is no convincing evidence that dioxin is produced at all during bleaching. Unlike ECF, the available evidence indicates that the TCF process does in fact eliminate the entry of industry-generated dioxin into the environment. The practical question is whether this difference is worth the effort -- and expenditure -- needed to achieve the more stringent, dioxin-free TCF condition.

The issue in the Great Lakes region, therefore, is to choose between chlorine dioxide-ECF and TCF as the goal to be reached in order to achieve the virtual elimination of dioxin in pulp mill effluents and paper. Such a decision involves a comparison of the relative costs of converting the existing pulp mills to ECF or TCF. But it also involves the relative impact of ECF and TCF on other environmental goals, for example the virtual elimination of organochlorine AOX pollutants other than dioxins, and on the possibility of moving toward totally effluent-free (TEF) production.

Accordingly, in what follows we analyze the economic consequences of converting the Great Lakes chemical pulp mills’ present elemental chlorine-based pulp processes to ones that conform to the chlorine dioxide-ECF and TCF criteria. Due to the objective of our study, virtual elimination of dioxins in the Great Lakes, we have limited our study to pulp and paper mills that release chlorinated effluents directly or indirectly into the Great Lakes. These include eight kraft mills, one soda mill, one sulfite mill, and ten mills.

a. Kraft and soda mills:

Kraft and soda pulp mills need to undergo the most substantial conversion in order to eliminate dioxin production. There are nine such mills that account for most of the waterborne organochlorine pollution entering the Great Lakes from pulp mills. They range in output from 225 to over 1500 metric tons of pulp per day. They ship $2.7 billion worth of pulp and paper, employ nearly 9,000 people, and have a payroll of nearly $400 million dollars (see Table V-4). The mills differ in their product lines and production technologies.

As noted earlier, the U.S. EPA is recommending the chlorine dioxide “” (ECF) strategy for kraft mills as a means of reducing organochlorine pollution. This strategy was proposed in the 1993 "cluster rules" (to be final in 1996 and implemented by 1999) -- a set of alternative process changes that firms can use to reduce air and water pollution, including waterborne dioxin. In particular, the cluster rules call for 100% chlorine dioxide substitution for elemental chlorine and the inclusion of either extended cooking delignification or oxygen delignification (what we call the V-22

Table V-4: Great Lakes Pulp & Paper Mills Economic Estimates 1992 Shipments, Expenditures, ($US millions) and Employment

Source Source Value ofEmploy- Payroll Value Materials Annual Name Location Shipments ment Added Cost Capital

KRAFT&SODA MILLS Canada Avenor Thunder Bay 540 1400 65 245 296 48 E.B.Eddy Espanola 262 860 36 119 143 23 James River Marathon 114 300 14 53 62 15 Kimberley-Clark Terrace Bay 278 720 33 130 151 37 Canadian Subtotal 1,195 3,280 148 547 652 123

United States Champion Quinnesec 395 1,490 65 185 212 49 International Paper Erie 243 1,070 45 113 131 28 Mead Escanaba 508 1,970 84 224 285 31 Potlatch Cloquet 228 880 38 100 128 14 S.D.Warren (Scott) Muskegon 86 330 14 38 48 5 U.S. Subtotal 1,460 5,740 246 660 804 127 Kraft & Soda Subtotal 2,655 9,020 394 1,206 1,456 251

SULFITE MILL Badger Paper MillsPeshtigo 65 230 9 31 34 4 DEINKING MILLS EcoFibre DePere 12 40 2 6 7 2 Fort Howard Green Bay 658 2,230 93 326 333 62 Fox River Fiber DePere 34 100 4 16 18 5 James River Ashland 19 70 3 10 10 2 James River Green Bay 138 470 20 68 70 13 Kerwin Appleton 39 170 7 18 22 5 Ponderosa Pulp Oshkosh 31 90 4 17 17 4 P.H. Glatfelter Neenah 117 490 20 52 66 14 Scott WorldWide Oconto Falls 13 40 2 7 8 2 Wisconsin Tissue Menasha 263 1160 49 122 142 30 Deinking Subtotal 1,328 4,850 203 638 693 138 TOTAL 4,050 14,090 606 1,876 2,183 393 Notes: The mill data are derived from general industry data and mill specific output and product lines. Actual mill data will vary due to product line concentration specialization, mill integration, technology and productivity. Sums may not always add due to rounding. Data Sources: 1993, 1994, 1995 Lockwood Post; 1992 U.S. Census of Manufacturers; Pulp & Paper 1994 North American Fact Book; Direct CBNS Survey; Corporate Annual Reports and SEC 10K Filings. V-23

“Modern ECF-2" mill in this report). This proposed regulation has already had a considerable influence on kraft pulp mills’ investment decisions; they have generally moved toward converting to 100% chlorine dioxide ECF processes.

Conversion to 100% chlorine dioxide substitution entails large capital investments. Chlorine dioxide is extremely unstable and must be generated on-site in specialized generators. A mill that invests in chlorine dioxide technology will have an incentive to recoup its investment within about 15 years. In a typical mill that has no existing chlorine dioxide capacity, the costs include about $15 million for a new chlorine dioxide generator (30 metric tons per day), $13.5 million for a new chlorine dioxide tower and washer (750 air-dried metric tons pulp per day), and $2 million for a recausticizing upgrade (Radian, 1995).

All of the kraft and soda mills in the Great Lakes region have already made some investments in equipment for generating chlorine dioxide -- which has been used for a long time as a way of achieving higher brightness and minimizing the fiber breakdown caused by 100% chlorine bleaching. As noted earlier, expanding usage to 100% chlorine dioxide reduces the formation of organochlorines (including dioxins), but does not entirely eliminate them from the effluent. This is particularly true when chlorine dioxide is used in the initial delignification stage; there, the relatively high concentrations of lignin considerably enhances the formation of chlorinated organic compounds from even the small amount of elemental chlorine generated by the use of chlorine dioxide.

The production sequences currently used in the nine Great Lakes kraft and soda mills are summarized in Table V-5. For this purpose we used the latest information on each mill's capacity, technology and bleaching sequence available from the 1996 Lockwood Post Directory, from a survey conducted for CBNS by the Ontario Forest Industries Association, and from the mills themselves. These data show that the Great Lakes kraft and soda mills, in different degrees, have been following the approach described in the proposed U.S. EPA regulations. Of the nine mills, four -- Avenor, James River-Marathon, Champion International, and Potlatch -- have adopted 100% chlorine dioxide bleaching; E.B. Eddy and Kimberly Clark are equipped to do so intermittently. Three mills have made this substitution only partially, and two mills are reported to still use 100% elemental chlorine in the first bleaching stage. Two of the mills have adopted oxygen delignification and extended modified cooking, and three are using hydrogen peroxide bleaching together with chlorine dioxide or chlorine.

As we have pointed out above, it is environmentally preferable to adopt the totally chlorine free (TCF) bleaching process and move towards a totally effluent free process. Here, we analyze the economic consequences of making the changes in production technology needed to convert the existing Great Lakes kraft and soda mills into either the ECF or TCF configurations. It is useful to start with analyses of the TABLE V-5: CHARACTERISTICS OF GREAT LAKES KRAFT & SODA PULP MILLS

PULP DELIGNIFICATION AND BLEACHING PROFILE GROUP TYPE

OUTPUT FIBER First Bleaching Stage Hydrogen Elemental Total Paper

METRIC BLEACHING FURNISH Extended or Oxygen Elemental ClO2 Peroxide Hypochlorite Chlorine Chlorine Radian Task

TONS/DAY SEQUENCE S-Softwood Modified Deliginification Chlorine % % P, Free Free Force

FACILITY NAME (1) (2) H-Hardwood Cooking O C D Ep or Eop H ECF TCF (3) (4)

CANADA

Avenor (former CPFP) 755 DREopDEpD S No No 0 100 Yes No Yes No 3 1

755 DEopDEpD H-S No No 0 100 Yes No Yes No 3 1,3

E.B. Eddy 500 O-DcEoDND S Yes Yes 0-50 50-100 No No On Demand No 4 2,4

500 O-DcEDND H Yes Yes 0-50 50-100 No No On Demand No 4 3,4

James River- Marathon 499 DEopDED S No No 0 100 Yes No Yes No 3 2

Kimberly-Clark 880 DcPEoDED S No No 0-40 60-100 Yes No Sometimes No 3 1

380 DcDED H No No 0-40 60-100 No No Sometimes No 3 3 UNITED STATES

Champion International 1,043 O-DEoDD H Yes Yes 0 100 No No Yes No 4 4

International Paper Co 885 C(E/H)PD H No No 100 0 Yes Yes No No 2 1,3

Mead Corp. 794 (D&C)EoDED S No No 60 40 No No No No 3 1

962 (D&C)EoDED H No No 60 40 No No No No 3 1,3

Potlatch Corp. 91 DEDED S No No 0 100 No No Yes No 3 2

399 DEDED H No No 0 100 No No Yes No 3 3

S.D. Warren Co. (Scott) 227 CEHD S-H No No 100 0 No Yes No No 2 2

TOTAL 8,669

NOTES (see appendix for further explanation for classification): (3) Radian Base Case Group Types (1) Metric ton refers to air dried metric ton of pulp. Radian Type Typical bleaching sequence Representative mill defining characteristicU.S. Mills '93 (2) The defining characteristics of the bleaching sequences are as follows: 1 CEH Traditional, no ClO2 on-site 8 D Chlorine Dioxide bleaching/delignification 3 DcEoDED High ClO2 substitution; no hypoclorite 11 E Extraction (caustic soda-NaOH) 4 ODEoDD O2 deliginification high ClO2 subst. 6 Eop Oxidative and peroxide extraction 5 CdEopDD Extended cooking; high ClO2 subst. 11 H Hypochlorite bleaching 6 OCdEdD O2 delign. & ext cooking; low ClO2 sub 8 N No wash stage, where ordinarily expected O; Eo Oxygen delignification; oxygen extraction (4) Paper Task Force Base Case Group Types ECF Elemental Chlorine Free PTF Type Typical bleaching sequence & Fibe Base case mill defining characteristics Capacity P; Ep Hydrogen peroxide bleaching; peroxide extraction 1 DcEDED Softwood 50% chlorine dioxide substitution 1000 R Papricycle 2 DcEDED Hardwood 50% chlorine dioxide substitution 500 Z Ozone delignification/bleaching 3 DcEDED Softwood 50% chlorine dioxide substitution 500 4 ODEDED Softwood O2 Delignification; 100% chlorine dioxide 1000 V-25 economic competitiveness of new, greenfield16 mills before we introduce the complexities of retrofitting. Richard Albert (1994a,b), a technical staff manager for the engineering firm Parsons Main has calculated such a comparison (see Table V-6). Each process takes advantage of the chemical cost savings and pollution prevention capabilities of extended delignification. His analysis has shown that the totally chorine and effluent free process (TCF-TEF) has unique cost advantages over the chlorine dioxide-ECF process. The most important of these are: avoided pollution control costs (for effluent treatment), process chemical cost savings and waste recovery. This can result, according to Albert, in an overall cost advantage for TCF-TEF of US$35 per ton of pulp.

TABLE V-6: Greenfield TCF-TEF Kraft Mill Costs Compared with Chlorine Dioxide-ECF Mill

Capital Operating Comp- Analysis and Mill Process Costs Costs arative US$ US$/ton Cost Millions US$/ton

R. Albert, Parson Mains (1994)

Totally Chlorine & Effluent Free: TCF-TEF 585 58 58

Chlorine Dioxide-Elemental Chlorine Free: 625 72 93 ECF

TCF-TEF Cost Advantage +40 +14 +35

AET Revisions (Forbes & Manolescu, 1994)

Totally Chlorine & Effluent Free TCF-TEF 623 45 45

Chlorine Dioxide-Elemental Chlorine Free: 631 40 44 ECF

TCF-TEF Cost Advantage +8 -5 +1

Notes: Fiber costs and labor costs not included in operating costs. Comparative costs are calculated to include the differences in capital and maintenance costs on a per ton basis.

The Alliance for Environmental Technology (AET), a group of chlorine and pulp manufacturers, enlisted David Forbes of BE&K, and Don Manolescu of Zerotech

16Mills are not called “greenfield” for environmental qualities, but simply as a way to distinguish new pulp mills from mills undergoing modernization. V-26

Technologies, Ltd (1994), to critique Albert’s work. They did not dispute that TCF was competitive with chlorine dioxide technologies, but after making adjustments, they found only a negligible difference between them, considering the uncertainty in engineering estimates. The Paper Task Force (1995a, pg.192; 1995b, pg.37-38), after evaluating many engineering studies, also concluded that there are essentially no substantial differences in the cost of TCF and chlorine dioxide-ECF production.

The economics of retrofitting old mills, such as those in the Great Lakes, presents special problems. The mills are not all alike. Even when they use the same production technology, they may differ in their physical condition or in the type of raw material, leading to different economic and environmental effects. Due to their worn and inflexible equipment, it is difficult for older mills to match the economic performance of a new mill. Nevertheless, such existing mills must replace equipment as it deteriorates, giving them an opportunity to modernize their operations and make them more efficient. The basic choice is to decide between moving toward the ECF design, based on the use of chlorine dioxide and the delignification improvements required by the EPA proposed regulations, or to adopt the state-of-the-art environmental technology, TCF.

For the reasons already discussed, this choice will determine whether the mill’s production of dioxin and other AOX pollutants will merely be reduced, or, in keeping with the principle of pollution prevention, actually eliminated. As a contribution to the development of policy to guide this transition in the Great Lakes mills, we have evaluated the economic consequences of converting them into three alternative forms of ECF and the TCF design:17

 ECF-1: Adapted Traditional Chlorine Dioxide. Adaptation of traditional elemental chlorine mills to chlorine dioxide, with no other substantial changes in delignification or bleaching technology. The conversion trend in the North American industry appears to be toward ECF-1.

 ECF-2: Modern Chlorine Dioxide. U.S. EPA recommended (in its1993 proposed cluster rules) modern, oxygen delignification (or extended cooking delignification), chlorine dioxide elemental chlorine-free system. This is the most

17The economic studies we apply do not include the TCF conversion scenario that has become the norm for modern hardwood mills in the Nordic countries: oxygen delignification; and multiple stages of hydrogen peroxide with chelant stages (“Q”) (chelation removes metals and optimizes TCF chemical use). This TCF process can be easily adapted to the ECF-2 capital equipment, but with higher chemical usage, and higher chemical costs when high brightness is required. The capital conversion costs from the base case to the to this hydrogen peroxide TCF process is less than for the ECF-2 case for mills that have low pre-existing chlorine dioxide capacity. This option is relatively more expensive for softwood bleaching, but still can be economical: Louisiana Pacific’s Samoa, California softwood mill employs this configuration. V-27

common type of retrofitted ECF mill in Europe.

 ECF-3: Advanced Low Effluent Chlorine Dioxide. A more advanced low effluent oxygen delignification, ozone bleaching, chlorine dioxide elemental chlorine-free system. The bleach plant effluent can be easily recycled up to the last chlorine dioxide stage. Union Camp, Virginia, has pioneered this ozone technology; Consolidated , Wisconsin Rapids, will be the first mill in the Great Lakes states to install this advanced technology.

 TCF: Advanced Low Effluent Totally Chlorine Free. Uses identical technology as ECF-3, but with hydrogen peroxide in place of chlorine dioxide. This configuration can be readily converted to a totally effluent free (TEF) mill. There is a stockholders movement at Union Camp demanding conversion to ozone TCF.

In each case we have estimated the change in the cost of pulp production (i.e., in comparison with the existing plant’s present cost) that would occur if each of the existing Great Lakes mills were converted to the new design. Each scenario maintains the same levels of pulp brightness. (At lower levels of brightness, TCF becomes more cost competitive with ECF. See Govers’ analysis reported in appendix Table V-A.7.)

Economic Data Sources: Radian Corporation and The Paper Task Force. To make our estimates, we have made use of the two most recent independent studies of such pulp process changes. The Radian Corporation (1995) and the Paper Task Force (1995a,c) analyzed alternative investment paths based on typical pulp mill base conditions. These analyses can be advantageously adapted to the Great Lakes mills, for they are based on otherwise unavailable proprietary data on actual mill conditions and provide a common reference point to our own analysis.

The Radian Corporation analysis (1995) has many useful features. They develop two chlorine dioxide-ECF scenarios (ECF-2 & ECF-3), which we could easily extend to a third, TCF scenario. They categorized U.S. mills into five groups of types, according to pulp and bleaching process technology. They used proprietary technological and economic data of actual U.S. mills to calculate conversion costs for an existing representative mill of each base case type. Minimal capital expenditures, i.e., for only the equipment necessary for the conversion were used. In contrast, operation and maintenance cost estimates were relatively high, especially for non- chlorine chemicals (e.g. they used a $2.00/kg price for leased ozone, when suppliers quote $1.30 to $1.60/kg). Their results are normalized to a typical mill output of 550 metric ton/ day, which we adjusted for scale relative to the actual sizes of the Great Lakes mills.

The Paper Task Force (1995a,c) developed relatively high capital estimates by including in the modernized equipment other pollution prevention measures not always V-28 required for reducing dioxin generation, but likely to accompany them. One result is that new bleaching chemicals are used more efficiently than they are in the Radian analysis. Separate hardwood and softwood base cases and two output levels (500 and 1000 metric tons/day) are analysed. Only two bleaching technologies -- 50% chlorine dioxide and oxygen delignification with 100% chlorine dioxide (softwood only) -- are analyzed. The latter case, the modern ECF-2, is similar to two mills in the Great Lakes. The Task Force constructed more alternative scenarios than Radian, including two that were useful for our objectives: 1) ECF-1, the current North American industry trajectory of 100% chlorine dioxide substitution with no delignification modernizations, and 2) a high consistency18 ozone stage for ECF-3, which entails a higher capital cost than the medium consistency stage that Radian selected, but which substantially reduces operating costs for TCF.

The Cost of Economic Conversion to ECF & TCF. In order to comply with expected future regulations and the international preference for ECF and TCF paper products, the Great Lakes mills will have to undertake one of the capital investment paths outlined above: ECF-1, ECF-2, ECF-3 or TCF. As environmental regulations become more strict, mills will need to adopt the more advanced pollution prevention technologies. We first present, in Table V-7 below, our total capital and weighted average cost estimates of converting the Great Lakes basin kraft and soda mills to each path. Then, in Tables V-8 and V-9 we present these results, separately, for each of the mills.19 The actual conversion costs are likely to be somewhere between the Radian and Paper Task Force estimates.

Aggregate (Weighted Average) Costs of Conversion. Table V-7 shows the

18Consistency, in pulping terminology, refers to the percentage of cellulose fibers in the solution of pulping chemicals.

19Adaptation of Technical Data to Great Lakes Mills: For the purposes of this study, we assigned each Great Lakes mill to the most similar base case for each of the two approaches. In the case of the Radian approach, we adjusted capital expenditures downward to correct for added investments that were already in place at the Great Lakes mill. We made an additional adjustment to the capital expenditures, for each approach, to account for the quantity of mill output. We used the conventional factor -- Great Lakes mill output/ base mill output raised to the power of 0.6 -- to adjust for economies of scale. Following the advice of the American Forest and Paper Association, we calculated separately the scale of production for each bleach line instead of aggregate output for all lines. We discovered that this increased aggregate capital estimates by 16-20%, as compared with an analysis based on the total aggregate output of each of the mills. Because some capital expenditures will not be duplicated in all the lines, scaling output separately for each of them will overstate actual capital expenses. A TCF scenario was constructed from Radian’s for capital conversion expenditures for ECF- 3, which is identical with TCF capital equipment, with an additional $10.49 in operating expenses to account for the increased quantities of hydrogen peroxide needed for TCF. (Based on data from an International Paper Company analysis, Lancaster et al., 1992.) A supplementary discussion of our methodology can be found in the appendix with tables showing the calculations for each mill (Tables V- A.4, V-A.5 and V-A.6). V-29 total cost of the capital equipment needed to convert all nine Great Lakes kraft and soda mills to the several ECF and TCF configurations and the annual expenditures that cost represents. Also shown are the weighted averages in annual operating costs (including capital, operating and maintenance costs) per metric ton of pulp.

The variation in the change of operating and maintenance costs ranged from an average saving of US$3/metric ton for the ECF-2 mill to an additional cost of US $7 for the medium consistency ozone TCF mill in the Radian application. The largest cost, allocated on a per ton basis, is the capital cost, testifying to the capital intensity of the pulp industry. Estimates of total costs (capital and operation and maintenance) vary from a low of US $6/metric ton for the ECF-2 mill in the Radian approach to US$20 for ECF-3 and TCF mills. The latter amount is about 4.3% of the average production cost of $460 (see box below). After the debt on capital equipment is paid off, the change in ongoing operating cost is at most 1.5% (Radian) and more likely to be even less (Paper Task Force).

As shown in Table V-7, the increases in overall production costs -- that is, the increased cost of producing a metric ton of pulp -- range from $4 to $20 among the several types of conversion. These increases need to be viewed against the background of two features of the overall pulp industry: (a) the range of production costs among the mills that the Great Lakes plants must compete with; and (b) the fluctuation in the market price of pulp.

First, Sinclair (1991) has reported that the range of production costs among all North American pulp manufacturers in 1988 was U.S.$170 in 1994 dollars per metric ton. 20 Other recent estimates of the range in production costs are between U.S.$35 per metric ton for U.S. plants in 1995 (The Paper Task Force, 1995b, p. 38) and U.S.$85 among four typical Canadian kraft mills (H.A. Simmons, 1992).21 Clearly, even the largest increase in production costs in converting the nine Great Lakes mills ($20) falls well within the normal range of variation in these costs among competing mills. This suggests that all but the highest cost marginal producers should be capable of coping with even the largest of the conversion costs.

Second, the indicated increase in production costs is also small relative to the extra earnings that mills make when the market price rises more rapidly than their production costs. These earnings, as represented by the difference between

20Currency conversions and adjustments for inflation are adjusted in this chapter according to the foreign exchange rates and producer price index in Tables 1417 and 760, Statistical Abstract of the United States: 1995, U.S. Commerce Department, Washington D.C.

21The typical carrying cost of capital expenses (borrowing) of these mills was Canadian $21 - $41/metric ton (‘94 US $18-$35). Note that total capital spending will be higher than these carry-over costs, since additional capital spending comes from retained earnings and other sources of equity. V-30 production costs and market price, have at times been more than $350 per metric ton in the last year -- or over 17 times the size of the largest conversion cost.22 Consequently, the conversion costs need not affect the market price of pulp, except perhaps during periods of oversupply where prices are at their lowest.

Thus, in economic terms, the increased cost of converting to ECF or TCF production falls well within the range of variations that are characteristic of the North American pulp market. The capital investments necessary for these conversions of the Great Lakes kraft mills will probably be between US$150-$450 million, or on an annualized pre-tax basis US$20-$60 million. This compares to the Great Lakes mills’ 1992 estimated total annual capital expenditures of US$250 million (‘94US$254 million, see Table V-4), which represents $88 per metric ton, and total annual revenue of US$2.6 billion, or $887/metric ton.23 Thus, the substantial capital investments needed for converting the Great Lakes mills to dioxin-free TCF production appear to be, in aggregate, well within the financial means of the region’s industry, provided adequate time is allowed.

22The price of bleached softwood market pulp has ranged from an average high of $855 per metric ton ($805 hardwood) in the 2nd quarter of 1995 to a current average quoted price of $505 ($365 hardwood) in the 2nd quarter 1996. Pulp and Paper Week, April 15, 1996.

23These values are calculated from estimated revenue of each mills product lines and national investment expenditures characteristic of the closest mill type reported in the 1992 U.S. Census of Manufacturers. V-31

TABLE V-7: Conversion Costs of Nine Great Lakes Kraft and Soda Mills to ECFand TCF Pulp Production Processes (1994US$)

Capital Expense Weighted Average Change Study Applied to Great Lakes Mills- (Millions of US$) in Operating Costs per Bleaching Process Scenario Metric Ton of Pulp (US$)

Total Annual Capital O & M Total

Radian Costs Applied Minimum Capital Estimates

ECF-1: Adapted Traditional ----- Chlorine Dioxide-Elemental Chlorine Free

ECF-2: Modern Oxygen Delignification, 150 20 +6 -3 +4 Chlorine Dioxide-Elemental Chlorine Free

ECF-3: Advanced Low Effluent 225 30 +9 -3 +6 Oxygen, Medium Consistency Ozone, Chlorine Dioxide-Elemental Chlorine Free

TCF: Advanced Low Effluent 225 30 +9 +7 +17 Oxygen, Medium Consistency Ozone, Hydrogen Peroxide-Totally Chlorine Free

Paper Task Force Costs Applied High Capital Estimates-includes ancillary costs

ECF-1: Adapted Traditional 160 21 +11 +7 +19 Chlorine Dioxide-Elemental Chlorine Free

ECF-2: Modern Oxygen Delignification, 285 38 +16 -0 +16 Chlorine Dioxide-Elemental Chlorine Free

ECF-3: Advanced Low Effluent 440 58 +18 +2 +20 Oxygen, High Consistency Ozone, Chlorine Dioxide-Elemental Chlorine Free

TCF: Advanced Low Effluent 450 60 +19 +1 +20 Oxygen, High Consistency Ozone, Hydrogen Peroxide-Totally Chlorine Free

Sources: Radian (1995); Paper Task Force (1995b) For full understanding of the power and limitation of this analysis, it is strongly recommended that these original sources be consulted. Notes: Numbers may not add in table due to rounding, see following tables and appendix for calculations and methodology. O&M: Operating and Maintenance cost. Annual: annual expenditures to cover debt, calculated at 10% interest over 15 years; not adjusted for taxes (the Paper Task Force had lower annualized capital costs due to adjustment for taxes). For purposes of comparison with Radian, and the inclusion of Canadian mills with a different tax rate, we omitted tax adjustments. V-32

Table V-8: Increment in Production Costs per Metric Ton of Pulp (U.S.$1994) for Conversion of Great Lakes Kraft & Soda Mills to ECF and TCF Processes (Radian Analysis Applied)

Output Annualized Capital Operation & Maintenance Total Plant Metric ton/day ECF-2 ECF-3 TCF ECF-2 ECF-3 TCF ECF-2 ECF-3 TCF

CANADA

1) Avenor 755S 14 +10 +10 -4 -7 +4 +3 +3 +14 755HS +10 +10 -4 -7 +4 +3 +3 +14

2) EB Eddy* 500S +1 +5 +5 +4 +8 +19 +5 +13 +24 500H +1 +5 +5 +4 +8 +19 +5 +13 +24

3) James Riv 500S +8 +12 +12 -4 -7 +4 +4 +5 +15

4) Kimberly- 880S +6 +9 +9 -4 -7 +4 +2 +2 +13 Clark 380H +9 +13 +13 -4 -7 +4 +5 +6 +17

UNITED STATES

5) Champion* 1040H +0 +8 +8 0 +8 +19 +0 +12 +22

6) Int’l Paper 880H +10 +12 +12 -4 -6 +5 +6 +6 +16

7) Mead 790S +7 +10 +10 -4 -7 +5 +2 +3 +13 960H +6 +9 +9 -4 -7 +4 +2 +2 +13

8) Potlatch 90S +16 +24 +24 -4 -7 +4 +12 +17 +27 400H +9 +13 +13 -4 -7 +4 +5 +6 +17

9) SD Warren 230SH +18 +20 +20 -4 -1 +9 +14 +19 +29

Weighted Average +6 +9 +9 -3 -3 +7 +6 +6 +17

*Without Champion&Eddy +8 +11 +11 -3 -6 +5 +4 +5 +16 Notes: H: Hardwood; S: Softwood; nc: no change in technological configuration from base case. Numbers may not add in table due to rounding, see appendix for calculations and methodology. *Champion & E.B. Eddy do not fit the base case type, producing misleading/y high operating cost estimates, they fit the Paper Task Force base case for ECF-3 and TCF scenarios much better. References: Radian (1995). V-33

The Impact of ECF and TCF Conversion on the Individual Mills:

Since there are significant differences among the existing designs and operations of the nine Great Lakes kraft and soda mills, the conversion process will represent different advantages and problems as well. Below, we summarize some of the specific effects on conversion on the individual mills.

Conversion of Modern Bleach Lines with Oxygen Delignification: Champion International and E.B. Eddy: These two mills are the most modern kraft pulp mills in the Great Lakes Basin and cost the least to convert to TCF: only $6-$8 per metric ton, with no significant differences in operating cost, according to our application of the Paper Task Force analysis.24 They are likely to realize additional chemical cost savings from modifications already made to their digesters for extended cooking. E.B. Eddy may require expanded investments in chlorine dioxide capacity to operate ECF on a permanent basis, making the low effluent ozone ECF-3 and TCF more attractive and timely. Indeed, E.B. Eddy has a pilot ozone plant and is considering implementing ozone on a mill scale.25 These two mills have the competitive advantage that Nehrt (1993, 1995) discovered to be keys to market share and profitablilty: early development and adaptation of advanced technology. They are also in the best situation to implement advanced TCF pollution prevention technologies.

Conversion of Bleach Plants with Partial Chlorine Dioxide Substitution: Kimberly Clark and Mead. These bleach lines represent an intermediate dioxin reduction step, with a small commitment to chlorine dioxide use arising from recent limited investments.

As we can see from Table V-9, converting the softwood lines to advanced low effluent TCF has a small total average cost advantage ($1-$2) over permanent 100% chlorine dioxide-ECF-1. What is more important in the long run, especially after the debt is paid off, is that there is a large operating cost advantage for TCF softwood conversions ($11 per metric ton). This shows that for the large softwood kraft mill, the larger initial capital expenditures for TCF technology is offset by economies of scale and more than compensated by savings in operation, providing a strong competitive

24The Radian analysis, did not have an appropriate base case for this configuration, so it overstates costs in the ECF-3 and TCF scenarios. The Paper Task Force base case is for a softwood mill: the capital costs should be similar for the hardwood lines, but the bleaching chemical usage is lower for hardwood, so chemical cost differences may be different than those predicted by our adaptation.

25Champion International’s corporate planning has taken a different tack, the development of a chlorine dioxide-elementally chlorine and effluent free process (ECF-TEF). But a low effluent TCF mill would be more economical for Champion’s Quinessec, Michigan mill: ECF-TEF has higher capital costs ($7 per metric ton) and operating costs ($6-$8 per metric ton) (adapted from Paper Task Force 1995b, pp. 39-42). V-34

Table V-9: Increment in Production Costs per Metric Ton of Pulp (U.S.$1994) for Conversion of Great Lakes Kraft & Soda Mills to ECF and TCF Processes (Paper Task Force Analysis Applied)

Output Annualized Capital Operation & Maintenance Total Plant Metric ton/day ECF- ECF- ECF- TCF ECF- ECF- ECF- TCF ECF- ECF- ECF- TCF 123 123 123

CANADA

1) Avenor 755S nc 30 +21 +22 nc -2 -2 -2 nc 28 +19 45 755HS nc +21 +22 nc +2 +6 +4 nc +26

2) EB Eddy 500S +18* nc +7 +8 +9* nc +1 +0 +22* nc +8 +8 500H +18* nc +7 +8 +6* nc +1 +0 +19* nc +8 +8

3) James Riv 500S nc +18 +26 +27 nc -2 -1 -2 nc +16 +24 +25

4) Kimberly- 880S +11 +14 +20 +20 +9 -2 -2 -2 +20 +11 +18 +18 Clark 380H +14 +20 +29 +29 +6 +2 +6 +4 +20 +22 +34 +33

UNITED STATES

5) Champion 1040H nc nc +5 +6 nc nc +1 +0 nc nc +6 +6

6) Int’l Paper 880H +10 +14 +19 +19 +6 +2 +6 +4 +16 +15 +25 +23

7) Mead 790S +12 +14 +20 +20 +9 -2 -2 -2 +20 +12 +19 +19 960H +9 +13 +19 +19 +6 +2 +6 +4 +16 +15 +25 +23

8) Potlatch 90S nc +36 +51 +52 nc -2 -1 -2 nc +34 +50 84 400H nc +20 +28 +29 nc +2 +6 +4 nc +22 +34

9) SD Warren 230SH +18 +25 +35 +36 +9 -2 -1 -2 +27 +23 +34 +35

Weighted Average +11 +16 +18 +19 +7 -0 +2 +1 +19 +16 +20 +20 excluding nc mills Notes: H: Hardwood; S: Softwood; nc: no change from base case, already in similar technological configuration. Numbers do not always add due to rounding, see appendix for calculations and methodology. *E.B. Eddy, does not fit the conversion case for ECF-1 well: it has advanced delignification technology, but does not operate at full chlorine dioxide substitution. References: Paper Task Force (1995b). V-35 advantage over the traditional ECF-1 path. The ECF-2 configuration is, however, the least expensive conversion due to capital expenditures that amount to $6 less per metric ton, so a regulatory or market incentive is nevertheless needed to realize the environmental gains of low effluent TCF.

In contrast, the hardwood lines do not enjoy the operating cost advantages (only $2 per metric ton) that would compensate for the higher capital costs of the more advanced technologies. TCF has an overall $7 disadvantage for Mead’s line and a $13 disadvantage for Kimberly Clark’s smaller line, which does not benefit from economies of scale. The hardwood lines are in a different situation because they use less bleaching chemicals in the first place (due to lower lignin content) and therefore have less operational costs to economize through increased capital substitution. These hardwood bleach plants, especially Kimberly Clark’s smaller line, may find that conversion to the less capital intensive chlorine dioxide ECF-2 configuration a more economical route to TCF conversion. A strong TCF market incentive could overcome these TCF hardwood handicaps. Hardwood market pulp is priced $50-$100 lower than softwood due to its shorter fibers. Even with a TCF premium price, hardwood pulp could be more inexpensive than softwood ECF pulp.

Conversion of Traditional Bleach Lines Adapted to Chlorine Dioxide-ECF-1: Avenor, James River, and Potlatch. Unlike investments in TCF technologies, these mills’ recent investments in 100% chlorine dioxide substitution-ECF-1 provides them with no economic advantage for adopting the more modern pollution prevention technologies. They face essentially the same modernization costs as mills with partial chlorine dioxide substitution, but face an additional handicap -- the debt burden from past chlorine dioxide invesments, which become redundant with modern bleach chemical economizing technologies. Consequently, these mills will be the most resistant to the adoption of TCF technologies until they fully recover their recent chlorine dioxide investments.

The Potlatch mill is in a different situation than the Avenor and James River mills. Its recent investments in additional chlorine dioxide generation are part of a comprehensive plan to expand its softwood line and convert the first chlorine dioxide stage to oxygen delignification (i.e., the modern ECF-2 configuration). While their recent investments in chlorine dioxide will not become redundant in the larger ECF-2 line, the additional chlorine dioxide would not be necessary in a plan to adopt the more advanced low effluent ECF-3 or TCF technologies. (The issues of converting Potlatch’s and other small bleach lines will be discussed further below.)

Conversion of a Hardwood Soda Mill: International Paper. This mill is only one of two mills in the United States that bleaches soda hardwood pulp; directly applicable economic conversion data are not available. Our analyses should be relatively accurate for capital expenses, but less so for operating expenses, since soda V-36 mills’ pulp requires even less bleaching chemicals than the typical hardwood mill.26 Consequently, this mill may face the same high cost of conversion to TCF as Mead and Avenor’s large hardwood lines. However, TCF conversion would be less costly for International Paper than for Mead and Avenor’s kraft mills, since TCF bleaching costs should be relatively lower. International Paper has taken one step toward TCF: it is the only one of the Great Lakes mills with a full hydrogen peroxide bleaching stage.

Conversion of Small Bleach Lines: S.D. Warren (Scott) and Potlatch. The greatest capital barriers to conversion toward the low effluent ECF-3 and TCF technology occurs in small bleach lines, which have diseconomies of scale: capital improvements cost more, on a per ton basis, than for larger mills. Thus, TCF conversion of S.D. Warren’s 230 metric ton per day mill would cost $35 per metric ton compared to $23 per metric ton for the less capital intensive ECF-2. TCF conversion of Potlatch’s 90 metric ton per day softwood line would result in a prohibitive $50 per metric ton cost increase compared to $34 for ECF-2. The best route in this situation is to expand capacity when modernizing to take advantage of economic returns to scale, 27 as Potlatch plans to do. In some cases, it may be more economically and environmentally advantageous for the Great Lakes region to consolidate the production of small bleach lines to fewer locations. Since fiber supply is a crucial limiting factor for pulp output in the Great Lakes region, any existing fiber supply that becomes available in the region from a small mill shutdown will probably be picked up by other mills in the region.28

Implementation; Economically Feasible Paths. Since pollution prevention technology replaces existing technology, the economic problem is a matter of scheduling financial investment. For any mill to survive and provide economic returns in the long run, it must have a modernization strategy. To do so, company engineers and executives must forecast what technologies will be needed in order to be competitive and to meet society’s environmental goals. Once these goals are clear, a technological investment path and schedule can be established. As we have shown, TCF-TEF technology is cost-effective for a modern mill and is therefore a reasonable

26Soda mills produce a lighter pulp than kraft mills because they do not use sulfides which darken residual lignin during the kraft cooking process. Their advantage is lower bleaching costs. is not as effective in delignification as the , so is less strong and commands a lower market price. 27 An additional option for the small mills is to convert to recycled fiber or non-wood fibers like agricultural waste, abundant in the Great Lakes region. These options are more economical to bleach TCF and do not require the same high scale of production as kraft. S.D. Warren’s tissue product line is particular amenable to recycled fiber (refer to the following deinking recycled mill section).

28 U.S. EPA’s recent impact analysis (November 1993, section 5) simply equates mill closure due to an environmental regulation as a loss of output, resulting in seriously over-projecting losses in national output. V-37

Why other studies’ TCF pollution prevention cost estimates appear prohibitively high:

Earlier ECF & TCF Conversion Studies: The studies by McCubbin, et al. (1992), Lancaster, et.al., International Paper (1992) and H.A. Simons Ltd. (1992) deserve special mention. While some TCF technologies were known in 1992, they were not adopted at the scale and range of conditions that they are today. As a result, the above 1992 studies seriously overestimated expenditures. The following three examples demonstrate these shortcomings:

1) Since 1992, it has been known that the addition of anthraquinone can substitute for extensive capital outlays in extended cooking, and still produce a viable TCF pulp. Some of the 1992 studies cited above advocated complete replacement of the pulp digesters with the new modern extended cookers ($36.4-$51.5 million; Paper Task Force, 1995b, p.53). New digester equipment can optimize the use of TCF bleaching chemicals, but there is no need to immediately install them.

2) Some analyses have added the cost of a new recovery boiler to TCF estimates ($84.4 million, Paper Task Force, 1995b, p.27; Lancaster et al., International Paper, 1992). Many recovery boilers have excess capacity (3 out of 4 of the Great Lake Ontario mills have excess capacity). Many of those at full capacity can be modified and expanded, at costs that the Paper Task Force estimated. A Weyerhauser study (Patrick, et al., 1994; Paper Task Force, 1995b, p.28) found that most United States mills’ recovery boilers will need to be rebuilt or replaced in any event in the next decade, due to their age; they are over 30 years old. In any case, normal replacement will include expanded capacity, since it is required of modernizing toward either process, TCF or ECF.

3) Since 1992, non-chlorine chemical usage has been optimized in TCF mills. Practical mill experience has fine-tuned the bleaching process and optimized TCF pulp quality and yield.

economic goal for the modernization of older mills. Moreover, for most mills in the Great Lakes, there exists a feasible investment path. For some of these mills ECF-2 and ECF-3 may be an appropriate intermediate step to adopting TCF-TEF processes. ECF-1 is not an appropriate intermediate. The smaller bleach lines will have the most difficulty and competitive problems, regardless of what minimal environmental objectives are implemented.

Modernization, at least in current practice, appears to generally result in reduced employment relative to output. That the conversion scenarios explored here may entail increasing the capital intensity and reduced employment is in keeping with the effect of recent modernization and productivity improvements on employment. (The U.S. Bureau of Labor Statistics (1994) predicts a 6.4% employment loss from 1992-2005.) If V-38 these declines are strictly proportional to capital investment, then the several conversion paths would have the following impact on employment and payroll (in 1992 U.S.$): traditional ECF-1, loss of 37 jobs and a $1.6 million payroll; modern ECF-2, a loss of 34 to 69 jobs and a $1.5 to $3 million payroll; advanced low effluent ECF-3 and TCF, loss of 52 to 106 jobs and a $2.3-4.6 million payroll. Actual job losses may be more attributable to investments in automation than to the environmentally motivated technological conversions.

The economic feasibility of conversion to TCF has in fact been demonstrated in practice: TCF plants have been built and operate successfully. As shown in Table V- 14 below, there are now 47 TCF pulp mills operating in Europe, and seven in Canada.29 There are only two TCF mills in the United States at present, a kraft mill operated by the Louisiana-Pacific Company in Samoa, CA, and a sulfite mill operated by Lyons Falls Pulp & Paper in Lyons Falls, NY. Their experiences are informative.

Louisiana-Pacific's Samoa kraft pulp mill, like many TCF mills in Europe, began converting to TCF as a means of reducing a number of pollution problems caused by the use of elemental chlorine. Conversion began on an experimental basis in 1991 and was completed in 1994, one year ahead of schedule. The plant is now able to achieve brightness of over 85 ISO with strength equivalent to that of chlorinated pulp (chlorine bleaching generally achieves a brightness of 90 ISO). Louisiana-Pacific has found a strong market for its TCF pulp in Europe, where it has commanded a premium price of up to $50 per metric ton (Louisiana Pacific, 1995). The Samoa plant has already diverted some of its effluent into closed-loop recycling systems, a step that may have contributed to the economic success of its conversion.

The Lyons Falls sulfite mill is another example of an economically successful U.S. conversion to TCF. One of its chief products is paper for book publishing. The company has actively promoted the use of TCF paper to publishers and now supplies several with paper for books that often bear a TCF logo.

The United States experience, however limited, indicates that TCF production is economically viable. Many North American pulp mills cite environmental problems as contributing factors to mill abandonment that could be solved with the closed loop technologies that become possible as TCF is adopted. Ultimately, closed loop technologies promise to reduce the costs of TCF pulp to that of ECF pulp, or less. To reach that goal, TCF needs the proper market incentives and regulatory signals in order to evolve and become internationally competitive. This aspect of the problem is discussed in section F below. b. Deinking pulp mills:

29Most of the Canadian TCF mills do not produce TCF on a permanent basis, but intermittently, in response to its European customers. These mills have not optimized their production equipment for TCF use, but use a combination of chemicals (e.g. anthraquinone and enzymes) to keep production costs down. V-39

1) Technology and environmental impact:

Of the 20 Great Lakes pulp and paper mills that use chlorine compounds and discharge effluent into the Great Lakes or their tributaries, 10 are solely devoted to the production of recycled paper. They employ about 4,800 employees, have a payroll of $203 million, and shipments of $1.3 billion (see Table V-4).

Technology: Since these plants manufacture pulp and paper directly from paper rather than wood, the manufacturing process is complicated by the removal of various impurities -- e.g., inks, fillers, coatings, and “” -- but in other respects entails less capital and operating costs. Chemical cooking is unnecessary; only water and agitation are needed to mash waste paper into pulp. Reagents are added to release the ink and other impurities from the paper fiber; these particles are then separated from the pulp, for example by flotation, and collected as a waste sludge. For some products the deinked pulp may need additional brightening. Since many wastepaper grades have been previously bleached, they require less bleaching than their virgin counterparts. Nine Great Lakes deinking plants presently use chlorine or hypochlorite as bleaching agents, and in one plant, reportedly as an agent to improve disposal in sewer systems. Bleaching chemicals have little effect on inks, but they do reduce the color of dyes, impurities, or yellowed lignin, brightening the pulp.

Dioxin Formation: Because it contains less lignin than virgin pulp, chlorine or hypochlorite is needed to bleach deinked pulp made from previously bleached waste paper. It follows that there is also less likelihood that dioxin will be synthesized in the bleaching of deinked pulp. Nevertheless, there is evidence that chlorine bleaching of recycled pulp does generate some dioxin. This is shown by the fact that samples of recycled paper produced by mills that use chlorine bleaching typically have a higher dioxin content than the virgin paper (Beck et al. 1988; Rotard et al., 1990; Fiedler & Timms 1990; Rappe et al. 1990; Santl et al. 1994). When the wastepaper has a relatively high lignin content -- as in the case of unbleached paper or wastepaper made from mechanical pulp -- chlorine bleaching is likely to produce higher levels of dioxin.

This view is supported by the U.S. EPA’s (October 1993, pg 7-9, 7-44) evaluation of a survey of 23 recycled paper deinking mills and 6 recycled paper non- deinking mills. They found that chlorine bleaching of recycled pulp produced chlorinated organic wastes similar to those produced at virgin chemical pulp bleach plants, but generally at much lower levels. In their 1989 one mill study, the U.S. EPA found a relatively high dioxin content in the wastepaper inputs, indicating that much of the dioxin in the sludge and bleach plant effluent originated from the wastepaper. U.S. EPA surmised that dioxin might have been formed in the chlorine bleaching of the virgin paper or resulted from fallout of dioxins from the atmosphere, that settled on the wastepaper. (See also Berry, 1993 and Rappe, et al. 1990.) Research in Germany has revealed other sources of waste paper dioxin: certain inks have high dioxin V-40 concentrations with a pattern of different congeners (“dioxin fingerprints”) consistent with that found in wastepaper; rosin agents used in paper production and wastepaper contaminated with pentachlorophenol (PCP) might be responsible as well (Santl, Gruber and Stöhrer, 1994a,b).

In the absence of chlorine-based bleaching the recycling process itself does not appear to contribute significantly to the dioxin problem (Santl et al., 1994). More than 90% of the dioxin in the input of a non-bleaching recycled paper mill was accounted for by the dioxin content of the waste paper; sizing agents accounted for the rest. The dioxin content of the recycled paper pulp was a third of the dioxin content of the waste paper used to manufacture it.

NCASI has provided us with unpublished data regarding the dioxin content of hypochlorite bleached and unbleached recycled pulp. The overall results are ambiguous and do not appear to establish that bleaching is entirely free of dioxin formation.30 In view of this uncertainty, it is prudent to consider non-chlorine bleaching alternatives, which will not compound the problem of dioxin formation.

2) Alternatives to chlorine-based bleaching:

Most recycled paper plants bleach in one- or two-stage bleaching with hypochlorite. For higher brightness a chlorine stage followed by a hypochlorite stage may be used. Hypochlorite efficiently strips the color from dyed paper and brightens the final paper product. Apart from pollution problems, one of the reasons for eliminating the use of hypochlorite for bleaching recycled pulp is that non-chlorine alternatives can produce brighter paper from mixed waste paper. As recycling production capacity has expanded the availability of high grade wastepaper has become more limited. This has encouraged many mills to use more flexible chemical bleaching technology. The most easily substituted chemicals are: hydrogen peroxide, sodium hydrosulfite, and formamidine sulfinic acid (FAS). They are used to produce “process chlorine-free” (PCF) pulp. Recently, firms interested in achieving a high level of brightness have taken advantage of this opportunity. For example, Kieffer Paper Mills’ chlorine-free bleached deinking mill has achieved 88% ISO31 brightness recycled

30 A thorough mass balance needs to be done to account for all of the dioxin going into and out of the bleach plant system. It is important that these studies are done for the mills that use chlorine compounds to bleach lower grade high lignin content papers into higher paper grades, an increasingly common practice.

31 ISO and GE are the names for two different scales used by the pulp and paper industry to measure the brightness of their market pulp and paper products. ISO is the more commonly used scale of measurement today; the GE scale is still used by many deinking mills to measure the brightness of deinked pulp. V-41 pulp, higher than that typically achieved by chlorine bleaching (Paper Age July 1995). They are experimenting with a third non-chlorine bleaching stage to reach a 91.5% ISO level of brightness.

3) The Economic Aspects:

The substitution of non-chlorine-based bleaching agents, such as sodium hydrosulfite or hydrogen peroxide, for chlorine-based agents in recycled pulp plants can involve little or no new equipment. Since most non-chlorine bleach chemicals do not need to be generated on-site (as do hypochlorite and chlorine dioxide), the necessary capital investment is negligible. The pre-existing pulping and bleaching equipment generally need only minor modifications, which may range from zero to $225,000 in cost (Radian 1995). As a result, the cost differential between the alternative bleaching strategies is influenced by the relative costs of the agents themselves. Sodium hypochlorite costs about half as much as sodium hydrosulfite or hydrogen peroxide (see Table V-10). On the other hand, there are significant economic advantages to the use of non-chlorine-based bleaching agents. In many conditions they can produce a higher level of brightness in the final product -- a property that can enhance its selling price. Non-chlorine-based alternatives also allow the use of less expensive wood- containing fiber (high lignin content “furnish”) because -- unlike hypochlorite -- they do not cause the yellowing of lignin. Thus, the use of hydrosulfite in place of hypochlorite enables a recycled pulp mill to replace some of the wood-free furnish costing from $120-$215 per ton (colored ledger to computer printout) with wood-containing furnish from $5-$55 per ton (mixed paper to old newspapers). 32

Based on these considerations, we have assembled data on several alternative ways of bleaching recycled pulp in order to estimate the relative costs of manufacturing it with sodium hypochlorite bleach or sodium hydrosulfite/hydrogen peroxide bleach to produce tissue-grade pulp with a target brightness of 80% (GE). The results are shown in Table V-10, which compares the production costs and brightness achieved in the various processes. When the process uses only wood-free33 furnish and is chlorine- free (PCF), the cost of production is about $4.60 more per ton than the cost of a comparable, chlorine-based process. This represents only 2% of material costs and less than 1% of the price of deinked bleached market pulp (according to Paper Age,

32 These are Chicago price quotes for November-December 1995 from Pulp & Paper Week. Prices and supply are volatile, but there are consistent price premiums for woodfree wastepaper grades.

33 Freesheet or woodfree refer to paper that contains no mechanical pulp fibers. V-42

Table V-10 Deinking Bleaching: Hypochlorite vs. Process Chlorine Free Cost Comparisons with Woodfree and Mixed Wastepaper Target 80% Brightness (GE) Tissue Grade Recycled Pulp

Wastepaper Furnish & % Quantity Cost Cost Brightness Bleaching Chemicals ton @100% US$ 1992 US$ 1995 % GE

Woodfree Wastepaper Hypochlorite Bleaching Woodfree Coated Book Furnish 100.0 1 ton 69.69 125.00 Sodium Hypochlorite 0.5 10 lbs 2.50 2.50 Sodium Hydroxide 1.0 20 lbs 6.40 2.80 Total Chemical & Furnish Costs 78.59 130.30 Brightness 80.9 Hydrosulfite Bleaching (PCF) Wood-Free Coated Book Furnish 100.0 1 ton 69.69 125.00 Sodium Hydrosulfite 0.5 10 lbs 7.10 7.10 Sodium Hydroxide 1.0 20 lbs 6.40 2.80 Total Chemical & Furnish Costs 83.19 134.9 Brightness 82.8

Mixed Wastepaper Hypochlorite Bleaching Woodfree Coated Book 70.0 0.7 ton 48.78 87.50 Groundw ood (Old New spapers) 30.0 0.3 ton 8.25 9.00 Sodium Hydroxide 1.0 20 lbs 6.40 2.80 Sodium Hypochlorite 0.5 10 lbs 2.50 2.50 Total Chemical & Furnish Costs 65.93 101.8 Brightness 72.2 Hydrosulfite/Peroxide Bleaching (PCF) Woodfree Coated Book 70.0 0.7 ton 48.78 87.50 Groundw ood (Old New spapers) 30.0 0.3 ton 8.25 9.00 Sodium Hydroxide 1.0 20 lbs 6.40 2.80 Hydrogen Peroxide 0.5 10 lbs 6.85 3.80 Sodium Hydrosulfite 0.5 10 lbs 7.10 7.10 Total Chemical & Furnish Costs 77.38 110.2 Brightness 81.0

Sources: Adapted from Timothy E.McKinney, "Alternative Chemicals Gain Popularity for Bleaching Woodfree Furnishes," Pulp & Paper March 1992 Chemical Marketing Reporter 1992-1995 did not show any differences in list prices for these bleaching chemicals. Contracted prices are lower and vary by sale and location. Price estimates for sodium hydroxide (13c/lb) and hydrogen peroxide (38c/lb) are those reported by Forbes and Manolescu (September 1994). 1995 waste paper prices were those reported by Paper Recycler for Chicago seller's f.o.b. in December. V-43

July 1995, $540/ton). However, when the chlorine-free process makes use of cheaper furnish -- i.e., wood-containing wastepaper such as old newspaper -- as a substitute for 30% of the wood-free furnish, then chlorine-free production of bleached wood-free pulp at a brightness of 80% GE costs about $20 less per ton than hypochlorite-based production. According to industry sources, PCF production costs for tissue products may increase up to $10 per ton if higher brightness is required.

Thus, conversion of many of the Great Lakes basin deinking pulp mills to process chlorine-free (PCF) operation34 can be done by simply substituting non-chlorine bleaching chemicals -- hydrogen peroxide, hydrosulfite or FAS -- for chlorine-based bleaching compounds such as chlorine, hypochlorite or chlorine dioxide. Oxygen or ozone bleaching may also be substituted for chlorine bleaching especially for brighter paper grades or certain types of wastepaper35 , but may entail additional capital outlays for an ozone generator and an oxygen bleaching tower. Since the outcome of conversion to PCF may be slightly higher costs or less bright product, increased public awareness of the environmental benefits may compensate in the marketplace for these disadvantages. The development of TCF and PCF product markets is discussed in section E below.

Conversion to PCF should not affect employment, payroll or sales. Some firms might incur slightly higher operating costs and slightly smaller profit margins, and would therefore resist conversion. All but one of the deinking mills surveyed by CBNS predicted no significant losses of employment due to environmental improvements. One mill reported that environmental improvements added 15-20 jobs. Another mill said that environmental improvements substantially reduced employee turnover. One mill said that it was conceivable that the proposed U.S. EPA cluster rules and Great Lakes Initiatives could result in mill closure. (It is interesting to note that this company had closed a hypochlorite bleaching deinking mill, which was successfully converted to a PCF mill by its successor.) Any possible declines in employment will be more than offset by the increased job opportunities generated by the expansion and new construction of deinking mills. Deinking capacity is expected to triple, as American paper companies have recently invested $7.5 billion in recycling capacity and plan to invest another $10 billion in the next five years. The limiting factor appears to be wastepaper supply, not the relatively small cost of bleaching recycled fiber.

Conclusion: An examination of 1994-1995 Pulp & Paper Project newsletters

34 Process Chlorine Free (PCF) does not necessarily result in Totally Chlorine Free (TCF) pulp and paper, because in recycling, waste paper often contains chlorine and organochlorines, such as dioxin, from the original chlorine manufacturing processes or inks.

35 Since the price of high-grade bleached wastepaper has gone up and availability down, recycled paper mills are beginning to use unbleached wastepaper with significant amounts of lignin that needs to be delignified for certain paper products (see Haywood, Pulp& Paper, Feb. 1995). Old Corrugated (OCC) can also be substituted for virgin fiber in a TCF kraft mill to produce high- grade papers of up to 87 ISO (Pichler et al., 1995). V-44 that report new planned bleached deink mills failed to identify any mill planning to use hypochlorite or chlorine. The Paper Task Force (1995a) forecast PCF for all new deinking mills and expected older mills to convert. Georgia-Pacific in Kalamazoo, Michigan, which bleaches 400 tons per day of deinked pulp recently converted their bleaching process from hypochlorite/hydrosulfite to hydrogen peroxide/hydrosulfite, and is now PCF (Lockwood Post 1995). Ponderosa has recently converted a mill to ozone bleaching of deinked market pulp. They are exploring the possibility of converting their Great Lakes mill to ozone or another PCF process.The trend in new U.S. facilities is toward totally chlorine-free production. For example, a new mill scheduled for completion this year in Michigan, Great Lakes Pulp and Fibre, will produce 715 tons per day of PCF deinked market pulp -- will reportedly be the largest plant in the world for deinking fine papers, according to the 1995 Lockwood-Post's Directory. Thus, there is practical evidence that both the construction of new PCF recycled pulp mills and the conversion of existing mills to PCF process is technologically and economically feasible. Nevertheless, this trend would be increased by government action. In particular, clear identification of PCF products and government regulatory and procurement policies that favor PCF would have a significant effect on conversion.36

c. Sulfite pulp mills:

There is one sulfite mill in the Great Lakes water basin -- Badger Paper -- which contributes dioxins to the Great Lakes. Badger, an integrated pulp and paper mill, has about $65 million in revenue and employs over 200 people. The bleaching process, chlorine-extraction-hypochlorite (CEH), is unchanged since the 1988 104 mill study, when its effluent dioxin samples ranged from 0.013 to 0.182 g TEQ per year (calculated from values reported in TetraTech, 1990). NCASI has indicated that they will release an estimated 0.0041 g TEQ/yr (medium) in 1993, based on self-reported data. We have not been given any indication of how this reported decline could have occurred with the continued use of 100% elemental chlorine in the first stage and hypochlorite in the last bleaching stage.

Like most sulfite mills in North America, Badger is relatively old; it was founded in 1929. The mill “cooks” with sulfurous acid instead of the sulfate-caustic soda solution used in the kraft process. This process produces brighter pulp at higher yield but which is less strong than kraft pulp. It requires less bleaching than kraft pulp, since sulfurous acid darkens pulp less than sulfate does.

It appears that considerable research and development would be needed to modernize Badger Paper. The relatively small size of Badger Paper makes it unlikely that substantial capital investment will be made, unless capacity were to expand and its

36 It is possible that Great Lakes chlorine dioxide bleached kraft mills would bleach secondary fiber with chlorine dioxide if they should develop secondary fiber sources and pulping capacity. V-45 wood fiber source capitalized. Badger Paper is in a difficult position; according to corporate reports, it has not been doing well financially. Rather than invest in modernization of its existing mill, it recently acquired another mill, which it couldn’t afford to keep and later had to sell. Indeed, Badger Paper company has announced the shutdown of their sulfite pulping operations in April 1996, citing that the variable costs of its sulfite pulp were higher than the pulp it could purchase on the market. They also mentioned the prohibitive expense of meeting the expected environmental guidelines.

This phenonomen is typical of many North American paper companies. When they are in a position to expand sales, they tend to favor acquisitions over modernizing expansions or building a new mill. This approach often requires less capital, but does not economize on operating costs, which are minimized through modernization. The result is often high debt, with no new capital equipment to show for it, or higher productivity which could enable the company to survive a downturn. Unlike European sulfite mills, most sulfite mills in North America have not modernized.This may be a contibuting factor to their demise; from 1980 to 1990, 60%of the sulfite mills in the United States closed. In constrast, Lyons Falls’ New York sulfite mill, like many such mills in Europe, has used TCF conversion as a successful strategy for modernization and survival.

E. Product Marketing and Demand:

The preceding analyses provide us with information about the economic feasibility of modifications in pulp production technology that can achieve the virtual elimination of dioxin (and of similar organochlorine pollutants). In the manufacture of virgin kraft pulp, the growing application of bleaching sequences based on the substitution of chlorine dioxide for chlorine (ECF) have significantly reduced the levels of dioxin, and of organochlorine pollutants generally, in the plant effluents. Nevertheless, the use of chlorine dioxide always releases a small amount of chlorine, which, reacting with residual lignin, produces dioxin and other organochlorine pollutants. Hence, ECF plants are not in fact entirely “chlorine-free,” “dioxin-free” or “organochlorine (AOX) pollutant-free.”

On the other hand, the available evidence shows that neither dioxin nor AOX is produced by the TCF bleaching process, which, in that sense, is both dioxin-free and AOX-free. It is fair to say, therefore, that although ECF mills are a considerable environmental improvement over elemental chlorine-based mills, it is only the TCF process that has achieved the goal of eliminating the dioxin that the production of non- TCF bleached pulp imposes on the environment. TCF also enjoys another environmental advantage over ECF: unlike ECF plants, TCF plants can be much more readily converted to an effluent-free status by recycling their effluents in closed-loop systems -- thus totally eliminating all waterborne pollutants and recapturing fuel and process chemicals. V-46

In sum, as a matter of policy, the goal of virtually eliminating the entry of dioxin and similar organochlorine pollutants into the Great Lakes from the pulp and paper industry ought to be implemented by converting the industry to TCF operations and, in the case of deinking recycling mills, to process chlorine-free (PCF) operation.

There is, however, an important economic barrier to the implementation of this environmentally motivated policy: TCF pulp is at present more costly for existing mills to produce than ECF pulp. This raises the question of whether TCF pulp and paper can command a correspondingly higher price and thereby motivate the necessary investment in the process. In turn, this issue depends on the demand for TCF paper.

The products manufactured by the 20 Great Lakes region pulp and paper mills include: papers, fine or writing papers, packaging and industrial converting papers, market pulp and tissue. The major Great Lakes products are coated papers, tissue, and market pulp. Together these three categories account for over three- quarters of the mills’ revenue. The Great Lakes mills account for about 30% of the North American production of coated papers, which are used in a wide range of business and consumer products where high-quality printing is important: magazines, business publications, annual reports, and advertising. These are items with considerable public visibility and therefore particularly sensitive to consumer demand and government procurement preference for recycled and chlorine-free paper.

The Great Lakes mills are also significant producers of tissue products, with an estimated 17% of the combined Canadian and U.S. production. The tissue products produced by these mills -- which are all made from recycled deinked pulp -- include napkins, table covers, as well as toilet paper, towels, sanitary and other tissues. Unlike high-grade printing paper, these end-uses often do not require high brightness. Market pulp is produced for sale to paper mills in open competition with other international pulp producers. The market pulp production capacity is concentrated in the region’s Canadian facilities. Most Canadian market pulp (59%) is shipped outside of North America; 31% is shipped to the U.S.; and 10% to paper companies in Canada (Pulp & Paper North American Fact Book, 1993, p. 301).

There is a rather close relationship between the supply of the several types of commodities produced by the Great Lakes mills and the estimated regional demand for them (defined as the demand arising from the eight Great Lakes states and the Province of Ontario). This is shown in Table V-11. The demand for paper products in the region arises principally from magazine, catalogue and other commercial printers (for coated freesheet), book publishers and printers and other commercial printers (for uncoated freesheet), government agencies (for uncoated freesheet and tissues), and households (for tissues). The largest demand arises from the printing and publishing industry, which is relatively concentrated in the region. The U.S. firms in the regional printing and publishing industry comprise almost 50% of the total U.S. industry in terms of value of shipments. (See Table V-12) Similarly, Ontario firms account for about one- V-47 half of Canada’s printing and publishing industry (Manufacturing Industries of Canada, Statistics Canada, 1991-92). Table V-11 shows that the existing regional demand is more than sufficient to absorb the regional supply of the major Great Lakes paper products.

It follows, then, that a policy directed at increasing the regional demand for TCF products could have a significant impact on the region’s suppliers, in the sense of justifying their investment in the transition to TCF. The printing and publishing industry is already playing a key role in this transition. Recent purchasers of TCF pulp and paper in the United States include book publishers; state and Federal government agencies;37 a Midwestern pulp converter manufacturing food-wrap papers38 ; non-profit environmental organizations (National Wildlife Federation and Environmental Defense Fund); magazines (e.g., Scuba Times), and fast-food chains such as McDonalds, which uses TCF in french fry bags.

Jossey-Bass Inc., a California-based publisher (a subsidiary of Simon & Schuster), has worked extensively to define environmentally responsible publishing practices, and is the first U.S. trade publisher to use TCF paper (Bruner, 1995). Jossey-Bass began using TCF uncoated paper for printing books in 1994, and after finding the price and quality acceptable, is using TCF stock for the majority of the company’s titles. The company prints about 140 new book titles, several hundred reprint titles, and about 90 journals annually (Bruner, 1995). Additionally, the University of California Press, one of the largest university presses in the United States, will soon convert a portion of their printing to TCF papers. By 1997 they expect to use TCF paper stock for about 50% of their new titles and book reprints.39 Most of the manufacturers contracted to print books for the University of California Press are

37Conversation with Mark Floegel, of Greenpeace, Oct. 13, 1995. Government agencies included State of Massachusetts and the U.S. General Services Administration.

38Conversation with Pat Wendell, of MoDoCell, Oct. 13, 1995, regarding purchasers of MoDo’s TCF pulp, who include a converter for food wrapping papers.

39 There are approximately 100 university presses in the United States, and an additional 6-10 in Canada, per telephone conversation with Tony Crouch, Director of Design and Production for the Univ. Of Calif. Press, Oct. 1995. V-48

TABLE V-11

DEMA ND FOR PULP A ND PA PER PRODUCTS IN THE GREA T LA KES REGION COMPA RED TO THE SUPPLY PRODUCED BY 20 GREA T LA KES MILLS

GREAT LAKES GREAT LAKES RATIO: COM M ODITY 20 M ILL SUPPLY CONSUM ER DEM AND REGIONAL DEM AND/ (1,000 tons) SECTOR (1,000 tons) MILLS SUPPLY

Market Pulp 2,321.48 Paper Mills 2,077.64 0.9

Coated Freesheet 1,196.29 Printing & Publishing 1,339.85 1.1 Papers Industries (1)

Uncoated Freesheet 490.01 Printing & Publishing 3,695.51 7.5 Papers Industries

Tissue Products 1,197.20 Consumer, 1,945.4 1.6 Commercial & industrial

Source: Pulp & Paper 1994 North American Factbook, 1995 Lockw ood-Post's Directory US Census of Manufactures, 1992 Notes : (1) Printing & Publishing Industries include: U.S. SIC 27 (except SIC 279, Printing Trade Services and 2711, New spapers) and Canadian Major Group 28. V-49

TABLE V-12: INDUSTRY PROFILE M AJOR SECTORS OF THE PRINTING AND PUBLISHING INDUSTRY IN THE GREAT LAKES STATES (U.S.)

Num be r ESTABL TOTAL ANNUAL V ALUE COST OF V ALUE OF OVER 20 NUM BER PAYROLL PROD. ADDED M ATERIALS SHIPM ENTS ESTABL PERSONS EMPLOYEES ($1,000) WORKERS ($1,000) ($1,000) ($1,000) COMMERCIAL PRINTING total Great Lakes: 12,100 2,140 228,533 $6,203,900 159,900 $13,181,800 $9,566,400 $22,762,600 total U.S.: 38,465 5,596 568,700 15,370,600 409,200 31,975,000 24,374,900 56,438,900 Ratio GL/US 31% 38% 40% 40% 39% 41% 39% 40% BOOK PUBLISHERS & PRINTERS total Great Lakes: 1,081 308 60,200 $2,050,100 24,500 $7,771,400 $4,013,700 $12,126,734 total U.S.: 3,267 793 130,500 $4,036,400 57,400 $14,328,000 $7,206,100 $21,419,000 Ratio GL/US 33% 46% 46% 51% 43% 54% 56% 57% PERIODICALS: PUBLISHING, OR PUBLISHING & PRINTING total Great Lakes: 1,278 405 48,800 $1,954,100 6,700 $8,716,200 $3,471,400 $13,641,200 total U.S.: 4,699 991 116,200 $4,074,500 20,100 $15,833,000 $6,200,900 $22,033,900 Ratio GL/US 27% 41% 42% 48% 33% 55% 56% 62% BUSINESS FORM PRINTING total Great Lakes: 299 183 17,600 $513,700 12,200 $1,440,500 $1,367,400 $2,807,700 total U.S.: 922 540 47,900 $1,343,200 33,600 $3,924,700 $3,499,900 $7,435,900 Ratio GL/US 32% 34% 37% 38% 36% 37% 39% 38% MISCELLANEOUS PUBLISHING total Great Lakes: 1,048 220 24,500 $657,000 9,000 $3,156,500 $1,069,200 $4,221,400 total U.S.: 3,390 570 65,400 $1,732,900 23,700 $8,524,900 $2,476,700 $10,977,100 Ratio GL/US 31% 39% 37% 38% 38% 37% 43% 38%

TOTAL US GREAT LAKES, MAJOR PUBLISHING AND PRINTING SECTORS 15,806 3,256 379,633 $11,378,800 212,300 $34,266,400 $19,488,100 $55,559,634 TOTAL U.S., MAJOR PUBLISHING AND PRINTING SECTORS: 50,743 8,490 928,700 $26,557,600 544,000 $74,585,600 $43,758,500 $118,304,800 RATIO, GREAT LAKES/U.S. 31% 38% 41% 43% 39% 46% 45% 47%

Source: Census of Manufactures, 1992. Great Lakes states includes: Illinois, Indiana, Michigan, Minnesota, New York, Ohio, Pennsylvania, Wisconsin. Note: Value of shipments estimated for Indiana Book Publishing (SIC 2731) and Book Printing (2732). V-50 located within the Great Lakes region -- chiefly in Michigan, New York and Pennsylvania. Clearly, publishers and printers in the Great Lakes region are in an excellent position to encourage regional pulp and paper mills to shift to TCF operations by providing substantial market incentives through their growing demand for chlorine- free and dioxin-free paper.

The public’s interest in environmentally benign paper products is also reflected in recent government actions. The U.S. General Services Administration has purchased over $1.1 million worth of PCF tissue (napkins, bathroom tissues and towels) and TCF bond, xerographic and envelopes during Fiscal Year 1995 and reports receiving requests from other Federal agencies for TCF paper procurement.40 In 1993, an effort was made to include TCF in the requirements for Federal government paper products, but this provision was eventually deleted from the Executive Order on purchasing requirements. However, several states and cities have passed ordinances to encourage the procurement of TCF paper products. (See Table V-13.)

Finally, households -- a large customer for tissue products -- are an important vehicle for generating a demand for TCF. The tissue products produced by the Great Lakes deinking mills -- such as the paper towels, napkins, and table covers produced by the large Fort Howard mill in Green Bay, WI -- are a major component of the region’s paper output. Increased consumer acceptance of slightly lower brightness (i.e., products in the range of 75-80 ISO) for sanitary tissues would encourage the adoption of PCF brightening for deinked pulp. In Europe, consumers in the Nordic and German- speaking countries seek out products made from TCF pulp in preference to higher- brightness ECF pulp, especially in sanitary products. It is now possible to produce PCF sanitary tissues with a high post-consumer recycled content (60% or more) from mixed waste paper and a brightness level of about 78% GE at competitive prices.

Thus, the Great Lakes region is in an advantageous position to implement a policy based on a demand-driven transition to TCF production by the region’s pulp mills. The region’s printing and publishing industry could take the lead, among industrial paper consumers, in shifting to TCF products. The Great Lakes Governor’s Council, which has been actively developing purchase programs for recycled paper, could extend them to include TCF and PCF paper. The Federal Administration could reverse its rejection of TCF requirements in government purchase program. Cities in the region could follow the example of Chicago and Ann Arbor, which have procurement policies favoring non-chlorine bleached paper products.

40 The following amounts of TCF paper were purchased by GSA: Napkins (4 types): $100,000; toilet tissue: $580,000; towels (3 types): $350,000; bond: $30,000; xerographic: $50,000; and an unspecified amount of envelopes; per telephone conversation with John Marrone, US General Services Admin., 10/16/95. V-51

Table V-13: Government Purchasing Policies: Totally Chlorine Free Paper

Legal Citation and Description Affects Additional Details Effective Date State of Oregon Develop purchasing State agencies, Dept. of General Governor’s Executive practices for paper contractors Services to provide Order No. EO-90-09 products made from guidelines, including 9/1/90 paper with no bleach or sources; DGS bidders without chlorine. to report whether their products are TCF City of Seattle Ord. Purchase recycled TCF City depts. Director of All City departments #116270, Sec. 4 of photocopy paper if Administrative Services shall change Municipal Code Section readily available and specifications to 3.18.918 priced similarly to non- conform to ordinance 7/8/93 TCF recycled. City of Chicago Purchase post- City purchasing agents, Printed pieces say if City Council Ord., Sec. consumer and TCF contractors, consultants TCF or recycled; TCF 2-92-590 of Chap. 2-92, recycled paper and must meet lowest Municipal Code 3/1/96 paper products; use recycled paper prices; equipment that re-evaluate standards operates with them. and specs; annual reports. City of Bellevue, WA All City departments City depts., contractors, Several departments Admin. Order No. 94-01 shall use paper that has consultants provide technical 3/1/96 not been bleached with assistance to chlorine. implement; annual reports. State of Phased-in program to State agencies must Current bid is for Massachusetts reduce chlorine buy from state contract, janitorial products. Environmental Policy bleached purchases. local governments may DPGS may expand to Statement by Dept. of TCF given preferences also. other paper and paper Procurement and when price is equal; products in the future. General Services in goal to eliminate Invitation for Bids chlorine-bleached Effective 4/26/95 products by 3/31/97 Source: Government Purchasing Project, Center for the Study of Responsive Law

In sum, the Great Lakes region is in an excellent position to implement the transition to TCF and PCF production in the region’s mills and thereby virtually eliminate their waterborne emissions of dioxin and other chlorinated pollutants.

Although the current markets for TCF pulp and paper products in the U.S. are small, the potential exists in the U.S. for the markets to grow substantially as a result of the same concerns that spurred development of the TCF market in Germany. The environmental and public health concerns that have created the existing markets for V-52

TCF production could create a rapid increase in demand in the U.S., similar in magnitude to the rapid development of markets for recycled post-consumer fibers in paper over the past ten years. Many of the same groups that first purchased recycled paper, such as colleges and universities, environmental organizations, and environmentally conscious corporations, are beginning to seek out TCF paper products. A number of grassroots citizens’ campaigns have recently emerged to inform purchasers about paper manufactured without chlorine-based bleaches, and to encourage consumers, government agencies, and institutions to purchase these papers.

For example, The “Reach for Unbleached” campaign, a coalition of citizens’ groups in Washington state led by the Washington Citizens for Recycling,41 publishes a consumers’ guide to stores in the Seattle area that sell different grades of paper and tissue products. In the Great Lakes region, students are working with the University of Michigan to alter procurement practices.42 Student organizations in other states, such as the Student Environmental Action group of the University of Virginia43 , have started campus campaigns to improve their colleges’ procurement of recycled and non-chlorine based paper.

The International Market for TCF and PCF Paper and Pulp

Another important policy consideration relates to the position of the U.S. pulp and paper industry -- and of its significant sector in the Great Lakes -- in the international market. Exports play an increasingly important role in the U.S. and Canadian pulp and paper industry, accounting for about 8.5% of the total value of U.S. paper goods shipments in 1992 (U.S. Industrial Outlook 1993, p. 10-4). U.S. exports of paper and allied products (including wastepaper) totaled an estimated $10.4 billion in 1992. These exports consisted mainly of market pulp (about 31% of the total value), printing and writing papers, including newsprint (15%), linerboard (11%), wastepaper (6%), boxboard (8%), and sanitary and all other converted products (almost 30%) (U.S. Industrial Outlook 1993, p. 10-3). The European Community is the principal regional export market for the U.S. paper industry, accounting for about 22% of the total value in 1992. Germany tops the list of European countries importing U.S. pulp and paper products, purchasing about $483 million of U.S. paper products (over 5% of the export

41 For information and brochures, contact Susan McLain, Program Director of the Washington Citizens for Recycling, (206) 343-5171.

42 “At the Source; Campaigns Aim for Zero Discharge in Great Lakes”, p.3, Scott Sederstrom, Great Lakes United, September/October 1995.

43 Contact Larry Ferber, University of Virginia Student Environmental Action, e-mail address: [email protected]. V-53 market) and 600,000 metric tons of market pulp worth, about $300 million (9% of U.S. exports of bleached kraft market pulp) in 1992 (U.S. Industrial Outlook 1993, p. 10-7). Canada supplies about one-third of Germany’s demand for bleached kraft pulp (MIT, 1993).

The conversion of the Scandinavian pulp and paper industry to TCF and ECF technologies came largely in response to market demand from Germany and to public demand for less pollution from pulp and paper mills. In November 1990, a German governmental scientific advisory group (Rat der Sachverstaendigen fuer Umweltfragen) called for a ban on chlorine bleaching in the pulp industry (Greenpeace 1994a). Although no subsequent legislation was passed, in 1991 the German government advised the pulp and paper industry to phase out all chlorine-based bleaching. These activities reflect the concern of European environmentalists and consumers over the health and environmental impacts of organochlorine pollution by the paper industry. This concern, coupled with proactive environmental regulators in Germany and the Nordic countries, has accelerated the adoption of TCF process changes in the Nordic paper industry over the past ten years (Greenpeace 1994a, p. 5). For example, an agreement of the Nordic Ministers of the Environment in 1990 regarding organochlorines stated, “The discharges of chlorinated organic substances should be eliminated altogether....The Nordic countries should aim at reaching this goal as soon as possible.” Additionally, the Nordic Environmental Labelling scheme, adopted in 1994 by the Swedish Standards Institution, creates a rating system for “Environmental labeling of (with and without wood pulp) for printing, writing and copying.” The formula for rating paper employed in this system favors the use of TCF over ECF papers, and sets a maximum limit of 0.40 kg AOX/ton of paper.

The results of these initiatives are impressive. According to the Confederation of European Paper Industries (CEPI), one million metric tons of TCF kraft pulp were consumed in Europe in 1993, accounting for 30% of the total market for printing and writing paper in the Nordic and Germanic countries. Several German magazines with large national circulation, including Der Spiegel, the largest circulation weekly in Germany, converted to the use of TCF paper in the early 1990s. Among other business purchasers of TCF paper, the international furniture company IKEA now prints its catalogue on paper made from Scandinavian TCF kraft (Greenpeace 1994b). Consumer demand for TCF has continued to rise: CEPI projected that by 1996, 60-70% of all printing and writing paper in the Germanic and Nordic countries will be TCF (Clark 1993). Industry sources estimate that approximately 50% of the woodfree printing and writing grades of paper used in the Germanic and Nordic countries currently is TCF.44 The Benelux countries -- Belgium, Netherlands and Luxemborg -- are also expected to increase their markets for TCF pulp and paper products.45 Additional, but smaller,

44 Soedra Cell, personal communication, 5/6/96. 45 International Papermaker, November 1995, Vol.58, No. 11,”TCF is the Right Product.” V-54 markets now exist in France, Italy and the United Kingdom. For example, over 100 brands of TCF papers are available to purchasers in the UK, including business stationary and office papers, coated and uncoated printing papers, specialty papers and .46

By mid-1994, 22 mills produced TCF bleached kraft pulp in Europe (see Table V- 14). There were also 17 mills in Europe producing TCF bleached sulfite pulp at this time, most of them integrated pulp and paper mills. The capacity to produce TCF kraft pulp in northern Europe continues to grow; the world’s first greenfield pulp mill producing TCF started in March 1996 at Rauma on Finland’s West Coast; it will produce 500,000 tons per year of TCF softwood pulp.47 Soedra Cell, Europe’s largest chemical pulp producer (and also largest TCF pulp producer) is also currently expanding its’ production of TCF market pulp. According to Soedra Cell, in 1995, 75% of their production was TCF, rising to 91% in February of 1996. Soedra Cell’s goal is to produce only TCF pulp within two years.48

As seen from Table V-14, many of the kraft mills listed as producing TCF pulp have used only a portion of their capacity to produce and market TCF pulp. As is typical of fast growing markets, the TCF capacity has become greater than what is currently supplied. This has occurred as the worldwide pulp and paper industry hit a peak in 1996; worldwide inventories and capacity overcame demand, causing market pulp prices to fall to unprofitable prices. This difference reflects the potential of many companies to increase their output of TCF pulp while they increase market share for these products. An ability to shift between production of either TCF and ECF pulp has enabled these mills to build-up their production of TCF while the markets develop. Rather than produce TCF on pure speculation, major TCF suppliers have adopted a degree of flexibility in their production that enables them to synchronize their TCF output with incremental increases in TCF demand. This assures that the TCF product can realize a market premium price for the environmental qualities that purchasers seek, and cover producer costs.

When TCF pulp was first introduced, careful supply management wasn’t necessary. As in many successful new product markets, demand outstripped supply,

46 The Soedra Cell Guide to TCF Papers, Soedra Cell (UK) Limited, 1996. 47 International Papermaker, Nov. 1995: The Metsa-Rauma plant representatives state that the mill design is aimed at maximum recirculation of process water and chemicals, and ultimately, totally effluent free (TEF) production.

48 Personal communication, Roland Loevblad, SOEDRA CELL AB, March 3, 1996. Also, Response from Soedra Cell, Autumn 1995. TABLE V-14: Worldwide TCF chemical pulp producers

Country/producer/location Metric Tons Grades Process Market Integrated SWEDEN Aspa Bruk, Aspa Bruk 115,000 S Kraft Oxygen + Peroxide X ASSI Doman Karlsborg (1) 260,000 H+S Kraft Oxygen + Peroxide X X Holmens Bruk, Wargons Bruk 45,000 S Sulfite Peroxide Koltneros 50,000 H+S Sulfite X Korsnas, Gavle Kraft Fluff Oxygen+Peroxide MoDo Paper, Domsjo 240,000 S Sulfite Oxygen+Peroxide X X MoDo Paper, Husum 100,000 H Kraft X X NCB Vallvik 200,000 S Kraft Oxygen+Peroxide X Rockhammer, Frovi 55,000 H+S CTMP Peroxide X Roltneros 60,000 S CTMP Peroxide X Roltneros 90,000 S Mech Peroxide X SCA Wifsta-Ostrand, Timra H+S Kraft Oxygen+Peroxide(Lignox) X Soedra Cell, Morrum Bruk 350,000 H+S Kraft Oxygen X Soedra Cell, Varo Bruk (Total for S Kraft Oxygen+Peroxide X Soedra Cell, Monsteras 3 Mills) H+Kraft Oxygen+Peroxide X Stora Cell, Norrsundet 275,000 S Kraft O Eop X Stora Cell, Skoghall 160,000 H+S Kraft Oxygen+Peroxide X Stora Cell, Skutskar 330,000 Kraft Fluff+H Kraft O Eop X Stora Papyrus, Nymolla 340,000 H+S Sulfite Oxygen+Peroxide X X Roltneros, Utansjo 70,000 H+S Sulfite Peroxide X Roltneros, Utansjo 80,000 S Mech NORWAY Borregaard Indust, Sarpsborg 160,000 S Sulfite Oxygen+Peroxide X , Tofte 50,000 H+S Kraft Oxygen+Peroxide(Lignox) X FINLAND Enocell, Ulma 100,000 H+S Kraft Oxygen+Peroxide X X Kymmene, Pietarsaari 100,000 H Kraft Oxygen+Peroxide X Metsa-Botnia, Kaskinen 300,000 H+S Kraft MCC+O-P-X X X Metsa-Botnia, Kemi 100,000 H+S Kraft MCC+O-P-X X X Metsa-Rauma (2) 500,000 S Kraft Metsa-Selia, Aanekoski H+S Kraft X Sunila, Sunila 100,000 S Kraft Oxygen+X+P Veitsiluoto, Kemijarvi 50,000 H+S Kraft Oxygen+Peroxide X X PORTUGAL Caima, Constancia 70,000 H Sulfite Peroxide X Celbi, Figueira daFoz 50,000 H Kraft Oxygen+Peroxide X SPAIN ENCE, Pontevedra 100,000 H Kraft Oxygen+Peroxide X USA Louisiana-Pacific, Calif. 10,000 S Kraft X Lyons Falls Pulp & Paper 40,000 Sulfite Peroxide-Hydrosulphite X GERMANY Hannover, Alfeld 90,000 S Sulfite X PWA, Manheim+Stockstadt 400,000 H+S Sulfite X Rosenthal, Blankenstein 150,000 S Sulfite X Schwabische Zellstoff, Ehingen 110,000 H+S Sulfite EOP-P-P X X Stora, Baienfurt 30,000 ASAM O-P X AUSTRIA Leykam, Gratkorn 220,000 H+S Magnefite Q-EOP-PNC/PNC X X Neusiedler, Kematen 40,000 S Sulfite X PWA, Hallein 110,000 S Sulfite EOP-P X FRANCE Stracel, Stasbourg 40,000 H+S Sulfite EO-P X SWITZERLAND Cellulose Attisholz, Luterbach 50,000 H Sulfite EOP,EOP-P,EOP-P-P-P-P X Cellulose Attisholz, Luterbach 50,000 S Sulfite EOP,EOP-P,EOP-P-P-P-P X CZECH REP. Biocel 50,000 S Sulfite X CANADA Atholville Pulp, Atholville 120,000 Sulfite Oxygen+Peroxide Closed Canfor, Prince George 20,000 S Kraft x Howe Sound, Howe Sound (1) 20,000 S Kraft Millar Western, Meadow Lake 240,000 H CTMP Peroxide x Stora Forest, Pt. Hawkesbury 100,000 S Sulfite x BRAZIL Aracruz 150,000 H Kraft x ITALY Cellulosa Calabra, Crotone 50,000 H NaCo Peroxide

Source: Pulp & Paper magazine, June 1994; 1995 Lockwood-Post's Directory Notes: (1) The Howe Sound mill in Canada and ASSI Doman Karlsborg mill in Sweden did not produce TCF pulp in 1995. (2) Metsa-Rauma, the world's first greenfield TCF pulp mill, was scheduled to start producing in March 1996. (3) The two Canadian kraft mills do not produce TCF on a permanent basis, but are capable of making TCF bleached pulp in response to requests from customers. V-56 no matter how fast industry increased output. But at this time, as capacity has caught up to demand, TCF suppliers have turned to aggressive marketing and appear to be restraing speculative output growth in order to maintain price premiums. AET (1996), competitors of TCF, have described the TCF output-capacity gap as evidence of TCF market limits, rather than as a typical characteristic of a developing new market. That TCF markets have not reached their limits, as ECF competitors claim, is evident from continued investment in TCF.

These developments in Europe suggest strongly that the future ability of the U.S. pulp and paper industry to compete in the international market will depend considerably on its ability to produce TCF pulp and paper. There was a substantial premium for TCF pulp in fourth-quarter 1995 market pulp prices, but this was expected to decline as additional TCF capacity comes on line in 1996.49 Apparently, consumers are willing to pay more for what they consider to be an environmentally superior product. Market pulp prices plunged rapidly during the first quarter of 1996, and TCF and ECF producers were not reporting prices differentials during this period. As market pulp prices stabilize in the near future, a premium price for TCF in the European market could be reestablished. The only TCF kraft chemical pulp producer in the U.S., Louisiana-Pacific, does not now receive a price premium for their TCF chemical pulp. The company views their current pulp pricing strategy as the necessary steps a producer must take to develop and expand demand for a new product in a supply driven market.50

For the reasons already cited, the Great Lakes pulp and paper industry is in an excellent position to move rapidly toward TCF production, and by doing so improve its position in the international market. Increased income from TCF sales could be used to justify the investments needed to expand TCF production in the United States and Canada.

In sum, there are both powerful environmental and economic reasons for a Great Lakes policy designed to implement the practical, achievable goal of converting the regional pulp and paper industry into one that is characterized by totally chlorine-free operations -- thereby ending the industry’s contribution to the environmental hazards of dioxin and its kindred, highly toxic chlorinated organic substances.

49 The fourth-quarter 1995 market pulp prices announced by global producers included a substantial premium for TCF, as compared to ECF, pulp. Fourth-quarter 1995 prices for TCF market pulp announced by global producers of market pulp include: for Northern Bleached Softwood Kraft: ECF $1000/ton; TCF $1080/ton (Sodra); ECF and TCF eucalpytus pulps: Ecu 735/ton and Ecu 795/ton, respectively. From Pulp & Paper International, This Week 10, no.25 (June 26-30, 1995). 50 Conversation with representative of Louisiana-Pacific, February 28, 1996. V-57

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1994: Charcterization of Effluent Fractions from ClO2 and Cl2 Bleaching of Unbleached and O2 Bleached Softwood Kraft Pulps. In 1994 Int’l Environmental Conference, TAPPI, Atlanta Georgia.

Sinclair, William F., Environment Canada, 1991: Controlling Effluent Discharges From Canadian Pulp and Paper Manufacturers. Canadian Public Policy - Analyse de Politiques XVII:1, 86-105.

Smook, Gary A., 1992: Handbook for Pulp & Paper Technologists, 2nd ed., Angus Wilde Publications: Vancouver, B.C. and Bellingham, WA.

Södra Cell, 1995: Responze, Växjö, Sweden. Spring.

Sonnenberg, L.B. and K.M. Nichols, 1995: Emissions of Hydrochloric Acid, PCDD and PCDF From the Combustion of Chlorine-Containing Kraft Pulp Mill Bleach Waste. Chemosphere 31(10): 4207-4224.

Suntio, Leena R., Wan Ying Shiu, and Donald MacKay, 1988: A Review of the Nature and Properties of Chemicals Present in Pulp Mill Effluents. Chemosphere, 17(7): 1249- 1290.

TetraTech, Inc, 1990: Risk Assessment for 2378-TCDD and 2378-TCDF Contaminated Receiving Waters from U.S. Chlorine- Bleaching Pulp and Paper Mills. Prepared for U.S. EPA, Office of Water Regulations and Standards, Assessment and Watershed Protection Division. Contract No. 68-C9-0013, Work Assignment No. 1-13. Fairfax Va., Aug.

Travis, Curtis C. and Miriam L. Land, 1990: Estimating the mean of data sets with nondetectable values, Env. Sci.& Tech., 24(7): 961.

Trice, William H., 1992: Bleaching Pulps with Oxygen and Ozone in a Commercial Installation. In Proceedings, Int’l Symposium on Pollution Prevention in the Manufacture of Pulp and Paper, Washington D.C. USEPA/744/R-93/002. NTIS PB94- 104312. Aug.

Tsai, Ted Y., Jean J. Renard, and Richard B. Phillips, Aug 1994: Formation of polychlorinated phenolic compounds during high chlorine dioxed substitution bleaching, Tappi Journal, 77(8): 149-157.

U.S. Bureau of Labor Statistics (BLS), 1994: Technology and Labor in Pulp, Paper, V-64

Paperboard and Selected Converting Industries. Bulletin 2443, June.

U.S. Environmental Protection Agency (U.S. EPA), 1990a: USEPA/ Paper Industry Cooperative Dioxin Study, “The 104 Mill Study,” Summary Report. Office of Water Regulations and Standards. July.

U.S. EPA, 1990b: Background document to the integrated risk assessment for dioxins and furans from chlorine bleaching in pulp and paper mills. Washington D.C. : Office of Toxic Substances. EPA/560/5-90-014

U.S. EPA, 1991: Toxics in the Community, National and Local Perspectives: The 1989 Toxics Release Inventory National Report.

U.S. EPA, 1992: Office of Pollution Prevention and Toxics. Int’l Symposium on Pollution Prevention in the Manufacture of Pulp and Paper. Aug.

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U.S. EPA, 1993: Development Document for Proposed Effluent Limitations, Guidelines and Standards for the Pulp, Paper and Paperboard Point Source Category. EPA-821- R-93-019. Oct.

U.S. EPA, 1993: Economic Impact and Regulatory Flexibility Analysis of the Proposed Effluent Guidelines and NESHAP for the Pulp, Paper and Paperboard Industry. EPA- 821-R-93-021. Nov.

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World Bank, 1995: Industrial Pollution Prevention and Abatement: Pulp and Paper Mills. pp 1-5. June 30. V-65

APPENDIX FOR CHAPTER V: Pulp and Paper Industry

Contents:

Figure V-A: Kraft Pulping and Bleaching Process

Table V-A.1: Pulp and Paper Mills Currently Operating in the Great Lakes Basin

Table V-A.2: Additional Pulping and Bleaching Process Improvements

Table V-A.3: Kraft Bleach Process Improvements of AOX

Table V-A.4: Notes on the Radian Analysis

Tables V-A.5(1-3): Applied Radian Analysis

Tables V-A.6(1-4): Applied Paper Task Force Analysis

Table V-A.7: TCF Operational Cost Competitiveness with ECF

V-68

TABLE V-A.1 Pulp and Paper Mills Currently Operating in the Great Lakes Basin (using chlorine compounds) State Mill Integrated Bleaching Sequence Mill Name City or Type with Products and Chlorine Prov. Paper Mill Compound(s) Used U.S. Badger Paper Mills Peshtigo WI Sulfite yes Bond, alkaline based, mimeo, unwatermarked CEH opaque, xerox, bristols, computer paper EcoFibre DePere WI Deinking no Market pulp C Fort Howard Green Bay WI Deinking yes Towel, napkins, place , dollies, table and DEH tray covers, coasters, wipers, tissue Fox River Fiber DePere WI Deinking no Market pulp, from post consumer waste. H International Paper Erie PA Soda yes Bond, cover, duplicator, xerographic, C(E/H)PD Hwd envelope, index bristol, ledger, mimeo, offset

James River Green Bay WI Deinking yes Sanitary tissue, towel and napkin converted H* products James River Ashland WI Deinking yes Machine creped tissue, plain printed and H** embossed napkins. Kerwin Paper Appleton WI Deinking yes Color, sulphite bond, fine papers, construction, H technical, tablet, envelope Mead Escanaba MI Kraft yes Coated book and publication papers, kraft (DC)EoDED Swd hardwood market pulp (DC)EoDED Hwd Ponderosa Pulp Products Oshkosh WI Deinking no Market pulp HH Potlatch Cloquet MN Kraft yes Coated offset, text and cover, coated web DEDED Swd papers. DEDED Hwd P.H. Glatfelter Neenah WI Deinking yes Recycled publishing, book, catalog, opaque, HH supercalendered, film coated, etc. Scott Worldwide, Scott Oconto Falls WI Deinking no Deinked pulp for internal use. C Paper S.D. Warren Co., Scott Muskegon MI Kraft yes Machine coated book, cover and matte coated CEHD Hwd Paper papers. Wisconsin Tissue Mills Menasha WI Deinking yes Napkins, place mats, disposable wipes, CEH bathroom tissue, 50% chlorine free V-69

Champion International Quinnesec MI Kraft yes Hardwood kraft market pulp and coated free ODEoDD Hwd sheet

Table V-A.1 continued Canada Avenor Thunder Bay ONT Kraft, yes Kraft market pulps, standard, recycled-content DREopDEpD Swd Deinking, newsprint DEopDEpD Hwd Ground- wood E.B. Eddy Espanola ONT Kraft yes Kraft market pulp, publishing and ODcEoDnD Swd industrial/specialty papers ODcEoDnD Hwd ODEoDnD (on demand) James River Marathon ONT Kraft no Softwood kraft market pulps DEopDED Swd Kimberly-Clark Terrace Bay ONT Kraft no Kraft market pulps: hardwood, softwood DcPEoDED Swd DcDED Hwd Sources: Lockwood Post's 1995 Directory, 1994 North American Pulp & Paper Factbook, individual mill surveys Abbreviations: Hwd: Hardwood; Swd: Softwood. For other abbreviations see Table V-5. Notes: * Survey response did not specify bleaching sequence. Probably use hypochlorite (H). ** Survey reported hypochorite (H) use for breaking (non-chlorine alternatives exist), but did not specify bleaching chemicals. V-70

Table V-A.2 Additional* Pulping and Bleaching Process Improvements

These improvements generally decrease the amount of bleaching chemicals needed and thereby improves emissions and conserves operating expenses of other bleaching chemicals.

Process Description Advantage/Disadvantage

Chelation Q Removes metals which Improves performance and efficiency of inhibit the oxidation peroxide (P) and ozone (Z) bleaching. reactions of peroxide and Makes brighter pulp posssible (Not needed ozone. for chlorine dioxide stage.) Metals may need alternative disposal or recovery technology.

Pressurized PO Peroxide bleaching under Economizes on peroxide use. For ECF, as a

Peroxide pressure with oxygen at substitute stage, it reduces usage of ClO2 . Bleaching higher temperatures. Uses Can make TCF competitive with ECF. 1/2 the chemical and 1/2 the Capital cost similar to conventional P stage, time of conventional but significant capital cost for upgrade. peroxide bleaching.

Enzyme X Improves bleachability and Low capital and low chemical usage since Pre-Bleaching extractability of lignin. catalytic reactive. Less oxidative chemicals Xylanese, mannanase, and usage results in higher brighteness. More lacase enzymes. commercial research is needed.

Peracid Paa Acidic delignification. Can substitute for Ozone delignification. Delignification Minimal capital expense, high chemical cost. Costs may improve with further research.

Polysulfide PS Polysulfide extended Extends delignification in the cooking stage. delignification. Requires new capital expenditures.

*Other process modifications--like oxygen, ozone and extended cooking -- are discussed in the text. V-71

Table V-A.3 Kraft Bleach Process Improvements of AOX

Process Improvement % AOX Capital Operating Decrease Cost $Mil. Cost

Extended/ Modified Cooking 10-65 10.0-45.0 Down

Anthraquinone Cooking AQ 10-20 .5 Up2

Improved Brownstock 5-10 6.0 Down Washing

Oxygen Deliginification O 25-35 20.0-25.0 Down

Pressurized Peroxide PO 20-40 3.0 Up3

100% Chlorine Dioxide D 80 3.0-20.0 Up Bleaching ECF

Totally Chlorine Free1 TCF 100 26.5-76.0 Up

Source: Arie van Donkelaar, “Dial in Compliance: The Cluster Rules,” March 1995. 1) Unlike other processes identified above, TCF includes a combination of the following processes, with substitution of hydrogen peroxide for chlorine: extended/modified or anthraquinone cooking, improved brownstock washing, and oxygen delignification. 2) When fiber or pulp prices rise to the levels such as in 1995, the larger pulp yield (increased productivity) induced by anthraqinone overcome the high chemical cost, and operating costs go down. 3) When compared to conventional peroxide bleaching, operating costs go down. V-72

Table V-A.4: (NOTES ON THE RADIAN ANALYSIS)

Radian Bleached Kraft Group Types

Radian Typical bleaching Representative mill defining characteristics U.S. Mills ‘93 Type sequence

1 CEH Traditional, no ClO2 on-site 8

2 CdEHD Traditional, some ClO2 on-site 41

3 DcEoDED High ClO2 substitution; no hypochlorite 11

4 ODEoDD O2 Delignification; High ClO2 Subst. 6

5 CdEopDD Extended Cooking; High ClO2 Subst. 11

6 OCdEdD O2 Delign. & Ext Cooking; Low ClO2 Sub 8

Radian grouped kraft bleached mills into these six categories and selected a representative mill from the USEPA 1993 study. Three Great Lakes mills do not fit well in the Radian categories. This affects the operating cost estimates, and thereby the comparisons between each scenario:

*E.B. Eddy and Champion have added extended/modified cooking, but also have substantial

ClO2 investments, unlike the representative mill used by Radian to make the estimates for Type 6. Consequently, we assigned these mills to group 4, which more closely represents the capital expenditures. The operating costs are likely to be lower for Eddy and Champion than the group 4 estimates for scenarios 2 and 3 due to the advantages that extended/modified cooking contributes. For example, anthraquinone is unnecessary and less bleaching chemicals will be needed due to the greater delignification.

*International Paper’s mill is the only one of two soda mills in the U.S. Kraft sulphate mills developed out of soda mills. The U.S. EPA proposed cluster rules classifies soda mills with kraft mills for regulation, due to process similarities. Economic comparisons are not likely to be as similar.

Due to the confidentiality of certain mill processes and economic data, we could not make direct estimates for each mill. The U.S. EPA provided confidential mill technological and economic data which Radian used to estimate conversion costs. They were unable to reveal the representative mills identity or detailed data.

Each Great Lake chemical mill will have particularities which will result in different actual costs. But generally comparisons between each scenario should be informative, except in the case of operating expenses noted in the cases of the three mills noted above.

Adaptation of the Radian Analysis: The Radian Corporation (1995) has investigated the costs that various types of kraft mills would incur in order to achieve an chlorine dioxide ECF bleaching sequence recommended by the U.S. EPA (oxygen delignification, 100% substitution of chlorine dioxide for elemental chlorine, and the use of hydrogen peroxide in the extraction stage). Radian has also investigated the cost of an alternative ECF-3 sequence in which chlorine dioxide is applied in a late stage rather than an early one (as in the case of ECF-2). For that purpose Radian has identified several characteristic types of existing pulp-making and bleaching sequences and for each of them has estimated the cost of the additional capital and changes in operating and maintenance expenditures that would be needed for a transition to the two alternative ECF sequences. The additional capital costs were normalized to a standard mill size of 550 metric ton per day.

Using these data we have estimated the incremental cost of these transitions for each of the nine kraft and soda mills listed in Table V-5. For this purpose each mill was assigned to the appropriate Radian type depending on the existing bleaching sequence. Then, as shown, for example, in Tables V- A5(1-3), the increased capital cost appropriate to each mill was estimated in two steps. First, the capital V-73 cost estimated by Radian for a standard 550 metric tons of air-dried pulp (tpd) plant was adjusted to take into account needed equipment that was already in place at each mill. Thus, several mills in Type 3 already have installed some capacity for hydrogen peroxide use, representing a savings of $225,000 (on the scale of 550 tpd) in the cost of this equipment. This adjusted capital cost was then further adjusted to reflect the actual size of the mill, in comparison with the standard 550 tpd mill. This involved the use of a scaling factor based on the ratio of the actual mill size to the 550 tpd standard, raised to the power of 0.6. (This exponent is derived from Radian estimates, based on the economy of scale due to the equipment characteristics.)

It is then possible, as shown in Table V-A5(1), to estimate the additional capital required to bring each of the Great Lakes kraft pulp mills to an EPA-recommended bleaching sequence (ECF-2). Finally, this value was converted to an annual cost, based on amortizing this investment at 10% over a 15-year period. This figure is used to compute the increased capital cost per metric ton (of air-dried pulp), which, together with Radian’s estimate of the added operating and maintenance cost per metric ton, yields the overall increment in each mill’s cost of pulp production due to the conversion to ECF-2. The next scenario ECF-3 was adopted in a similar manner as shown in Table V-A5(2).

The advanced low effluent TCF scenario was adopted from ECF-3 and is shown in Table V- A5(3). Essentially this TCF scenario uses the same capital equipment, but substitutes the use of hydrogen peroxide for chlorine dioxide in the last stage. Generally, greater quantities of hydrogen peroxide will be needed than chlorine dioxide in order to achieve the same brightness. Following International Paper as a high end estimate (Lancaster et al., 1992), a retrofitted mill could use up to $10.49 more in chemical costs per metric ton of pulp than ECF-3 (adjusting for chemical price differences since 1992). On the low end, mills with extended or modified delignification digesters would expect no significant differences (e.g., E.B. Eddy and Champion) in costs. Mills with difficult to bleach wood furnish and other suboptimal equipment, would have the high end. Since we did not have detailed information for each mill in these respects, we did not customize the operational cost differences of TCF for each mill, and used the higher estimate for a conservative analysis of TCF. TABLE V-A.5(1): Great Lake Kraft & Soda Mills Conversion Costs Radian: MODERN ECF-2

Technology: Oxygen Delignification, Chlorine Dioxide-Elementary Chlorine Free

PULP CAPITAL COST (US$)

OUTPUT AVERAGE

(METRIC) ADJUSTED FOR SCALE O & M TOTAL

RADIAN TONS ECONOMY ADJUSTMENT ADJUSTED PER PER PER

GROUP PER SCALING RADIAN TO RADIAN CAPITAL TOTAL METRIC METRIC METRIC

FACILITY NAME TYPE DAY) FACTOR (1) DATA DATA COST FIXED ANNUAL TON TON (2) TON

CANADA

Avenor (former CPFP) 3 755 S 1.21 12,000,000 225,000 11,775,000 14,240,049 1,872,193 6.89 -4.28 2.61

3 755 H-S 1.21 12,000,000 225,000 11,775,000 14,240,049 1,872,193 6.89 -4.28 2.61

E.B. Eddy 4 500 S 0.94 1,600,000 0 1,600,000 1,511,069 198,666 1.10 4.25 5.35

4 500 H 0.94 1,600,000 0 1,600,000 1,511,069 198,666 1.10 4.25 5.35

James River- Marathon 3 499 S 0.94 12,000,000 225,000 11,775,000 11,106,597 1,460,226 8.13 -4.28 3.85

Kimberly-Clark 3 880 S 1.33 12,000,000 225,000 11,775,000 15,611,078 2,052,447 6.48 -4.28 2.20

3 380 H 0.80 12,000,000 225,000 11,775,000 9,432,210 1,240,088 9.06 -4.28 4.78

UNITED STATES

Champion International 4 1,043 H 1.00 1,600,000 1,375,000 225,000 225,000 29,582 0.08 0.00 0.08

International Paper Co. 2 885 H 1.33 18,500,000 225,000 18,275,000 24,303,155 3,195,228 10.03 -3.69 6.34

Mead Corp. 3 794 S 1.25 12,000,000 0 12,000,000 14,955,074 1,966,200 6.88 -4.28 2.60

3 962 H 1.40 12,000,000 0 12,000,000 16,779,046 2,206,005 6.37 -4.28 2.09

Potlatch Corp. 3 91 S 0.34 12,000,000 0 12,000,000 4,069,900 535,085 16.38 -4.28 12.10

3 399 H 0.83 12,000,000 0 12,000,000 9,900,460 1,301,651 9.06 -4.28 4.78

S.D. Warren Co. (Scott) 2 227 S-H 0.59 18,500,000 0 18,500,000 10,872,721 1,429,478 17.51 -3.69 13.82

TOTALS & WEIGHTED AVERAGES 8,669 148,757,478 19,557,707 6.27 -2.71 3.56

Without Champion & E.B. Eddy 7.54 -3.59 3.95 & M: Operating and Maintenance Costs; H: Hardwood; S: Softwood ** These are fixed costs which do not vary significantly with plant size. Values displayed here are not rounded to significant digits in order to make calculations transparent. TABLE V-A.5(2): Great Lake Kraft & Soda Mills Conversion Costs Radian: ADVANCED LOW EFFLUENT ECF-3

Technology: Oxygen Delignification, Medium Consistency Ozone Bleaching,

Chlorine Dioxide-Elementary Chlorine Free

PULP CAPITAL COST (US$)

OUTPUT AVERAGE

(METRIC) ADJUSTED FOR SCALE O & M TOTAL

RADIAN TONS ECONOMY ADJUSTMENT ADJUSTED PER PER PER

GROUP PER SCALING RADIAN TO RADIAN CAPITAL TOTAL METRIC METRIC METRIC

FACILITY NAME TYPE DAY) FACTOR (1) DATA DATA COST FIXED ANNUAL TON TON (2) TON

CANADA

Avenor (former CPFP) 3 755 S 1.21 17,300,000 -225,000 17,075,000 20,649,582 2,714,879 9.99 -6.95 3.04

3 755 H-S 1.21 17,300,000 -225,000 17,075,000 20,649,582 2,714,879 9.99 -6.95 3.04

E.B. Eddy 4 500 S 0.94 7,200,000 0 7,200,000 6,799,812 893,997 4.97 8.21 13.18

4 500 H 0.94 7,200,000 0 7,200,000 6,799,812 893,997 4.97 8.21 13.18

James River- Marathon 3 499 S 0.94 17,300,000 -225,000 17,075,000 16,105,745 2,117,483 11.79 -6.95 4.84

Kimberly-Clark 3 880 S 1.33 17,300,000 -225,000 17,075,000 22,637,721 2,976,267 9.39 -6.95 2.44

3 380 H 0.80 17,300,000 -225,000 17,075,000 13,677,706 1,798,260 13.15 -6.95 6.20

UNITED STATES

Champion International 4 1,043 H 1.47 7,200,000 0 7,200,000 10,571,916 1,389,930 3.70 8.21 11.91

International Paper Co. 2 885 H 1.33 21,200,000 -225,000 20,975,000 27,893,772 3,667,300 11.52 -5.75 5.77

Mead Corp. 3 794 S 1.25 17,300,000 0 17,300,000 21,560,232 2,834,605 9.92 -6.95 2.97

3 962 H 1.40 17,300,000 0 17,300,000 24,189,791 3,180,323 9.19 -6.95 2.24

Potlatch Corp. 3 91 S 0.34 17,300,000 0 17,300,000 5,867,439 771,414 23.62 -6.95 16.67

3 399 H 0.83 17,300,000 0 17,300,000 14,273,163 1,876,547 13.06 -6.95 6.11

S.D. Warren Co. (Scott) 2 227 S-H 0.59 21,200,000 0 21,200,000 12,459,550 1,638,104 20.06 -1.36 18.70

TOTALS & WEIGHTED AVERAGES 8,669 224,135,823 29,467,983 9.44 -3.11 6.33

Without Champion & E.B. Eddy 10.60 -5.56 5.04

NOTES: (1) (output/550)^0.6 (2) O&M: Operating and Maintenance Costs, H: Hardwood, S: Softwood Values displayed here are not rounded to significant digits in order to make calculations transparent. TABLE V-A.5(3): Great Lake Kraft & Soda Mills Conversion Costs Radian: ADVANCED LOW EFFLUENT TCF

Technology: Oxygen Delignification, Medium Consistency Ozone Bleaching,

Hydrogen Peroxide-Totally Chlorine Free

PULP CAPITAL COST (US$)

OUTPUT AVERAGE

(METRIC) ADJUSTED FOR SCALE O & M TOTAL

RADIAN TONS ECONOMY ADJUSTMENT ADJUSTED PER PER PER

GROUP PER SCALING RADIAN TO RADIAN CAPITAL TOTAL METRIC METRIC METRIC

FACILITY NAME TYPE DAY) FACTOR (1) DATA DATA COST FIXED ANNUAL TON TON (2) TON

CANADA

Avenor (former CPFP) 3 755 S 1.21 17,300,000 -225,000 17,075,000 20,649,582 2,714,879 9.99 3.52 13.51

3 755 H-S 1.21 17,300,000 -225,000 17,075,000 20,649,582 2,714,879 9.99 3.52 13.51

E.B. Eddy 4 500 S 0.94 7,200,000 0 7,200,000 6,799,812 893,997 4.97 18.68 23.65

4 500 H 0.94 7,200,000 0 7,200,000 6,799,812 893,997 4.97 18.68 23.65

James River- Marathon 3 499 S 0.94 17,300,000 -225,000 17,075,000 16,105,745 2,117,483 11.79 3.52 15.31

Kimberly-Clark 3 880 S 1.33 17,300,000 -225,000 17,075,000 22,637,721 2,976,267 9.39 3.52 12.91

3 380 H 0.80 17,300,000 -225,000 17,075,000 13,677,706 1,798,260 13.15 3.52 16.67 UNITED STATES

Champion International 4 1,043 H 1.47 7,200,000 0 7,200,000 10,571,916 1,389,930 3.70 18.68 22.38

International Paper Co 2 885 H 1.33 21,200,000 -225,000 20,975,000 27,893,772 3,667,300 11.52 4.72 16.24

Mead Corp. 3 794 S 1.25 17,300,000 0 17,300,000 21,560,232 2,834,605 9.92 3.52 13.44

3 962 H 1.40 17,300,000 0 17,300,000 24,189,791 3,180,323 9.19 3.52 12.71

Potlatch Corp. 3 91 S 0.34 17,300,000 0 17,300,000 5,867,439 771,414 23.62 3.52 27.14

3 399 H 0.83 17,300,000 0 17,300,000 14,273,163 1,876,547 13.06 3.52 16.58

S.D. Warren Co. (Scott) 2 227 S-H 0.59 21,200,000 0 21,200,000 12,459,550 1,638,104 20.06 9.11 29.17

TOTALS & WEIGHTED AVERAGES 8,669 224,135,823 29,467,983 9.44 7.36 16.80

Without Champion & E.B. Eddy 10.60 4.91 15.51

NOTES: (1) (output/550)^0.6 (2) O&M: Operating and Maintenance Costs, H: Hardwood, S: Softwood Values displayed here are not rounded to significant digits in order to make calculations transparent. TABLE V-A.6(1): Great Lake Kraft & Soda Mills Conversion Costs Paper Task Force: ADAPTED TRADITIONAL ECF-1

Technology: Chlorine Dioxide-Elementary Chlorine Free

PAPER PULP CAPITAL COST (US$)

TASK FORC OUTPUT AVERAGE

GROUP (METRIC) ADJUSTED FOR SCALE O & M TOTAL

TYPE TONS ECONOMY PAPER ADJUSTMENT ADJUSTED PER PER PER

CAPITAL- PER SCALING TASK FORCE TO PTF CAPITAL TOTAL METRIC METRIC METRIC

FACILITY NAME O & M (2) DAY) FACTOR (1) DATA DATA COST FIXED ANNUAL TON TON (2) TON

CANADA

Avenor (former CPFP) 1 755 S NC NC NC NC NC NC NC NC NC

3 755 H-S NC NC NC NC NC NC NC NC NC

E.B. Eddy 3 500 S 1.00 18,000,000 0 18,000,000 18,000,000 2,366,528 13.15 8.70 21.85

3 500 H 1.00 16,800,000 0 16,800,000 16,800,000 2,208,759 12.27 6.40 18.67

James River- Marathon 2 499 S NC NC NC NC NC NC NC NC NC

Kimberly-Clark 1 880 S 0.93 28,900,000 0 28,900,000 26,766,245 3,519,059 11.11 8.70 19.81

3 380 H 0.85 16,800,000 0 16,800,000 14,249,428 1,873,426 13.69 6.40 20.09

UNITED STATES

Champion International 4 1,043 H NC NC NC NC NC NC NC NC NC

International Paper Co. 3 885 H 1.41 16,800,000 0 16,800,000 23,656,482 3,110,207 9.77 6.40 16.17

Mead Corp. 1 794 S 0.87 28,900,000 0 28,900,000 25,160,704 3,307,973 11.58 8.70 20.28

3 962 H 1.48 16,800,000 0 16,800,000 24,873,157 3,270,168 9.45 6.40 15.85

Potlatch Corp. 2 91 S 0.36 NC NC NC NC NC NC NC NC

3 399 H 0.87 NC NC NC NC NC NC NC NC

S.D. Warren Co. (Scott) 2 227 S-H 0.62 18,000,000 0 18,000,000 11,201,460 1,472,698 18.04 8.70 26.74

TOTALS & WEIGHTED AVERAGES 8,669 160,707,476 21,128,819 11.45 7.48 18.93

: Type 1 & 4: (output/1000)^0.6; Type 2 & 3 (output/500)^.6 (2) O&M: Operation and Maintenance Costs. H: Hardwood; S: Softwood. NC: No Change. PTF: Paper Task Force Values displayed here are not rounded to significant digits in order to make calculations transparent. TABLE V-A.6(2): Great Lakes Kraft & Soda Mills Conversion Costs Paper Task Force: MODERN ECF-2

Technology: Oxygen Delignification, Chlorine Dioxide-Elementary Chlorine Free Bleach

PAPER PULP CAPITAL COST (US$)

TASK FORC OUTPUT AVERAGE

GROUP (METRIC) ADJUSTED FOR SCALE O & M TOTAL

TYPE TONS ECONOMY PAPER ADJUSTMENT ADJUSTED PER PER PER

CAPITAL- PER SCALING TASK FORCE TO PTF CAPITAL TOTAL METRIC METRIC METRIC FACILITY NAME O & M (2) DAY) FACTOR (1) DATA DATA COST FIXED ANNUAL TON TON (2) TON

CANADA

Avenor (former CPFP) 1 755 S 0.84 35,800,000 0 35,800,000 30,244,833 3,976,402 14.63 -2.40 12.23

1-3 755 H-S 0.84 35,800,000 0 35,800,000 30,244,833 3,976,402 14.63 1.70 16.33

E.B. Eddy 4 500 S NC NC NC NC NC NC NC NC NC

4 500 H NC NC NC NC NC NC NC NC NC

James River- Marathon 2 499 S 1.00 25,100,000 0 25,100,000 25,068,563 3,295,859 18.35 -2.00 16.35

Kimberly-Clark 1 880 S 0.93 35,800,000 0 35,800,000 33,156,802 4,359,250 13.76 -2.40 11.36

3 380 H 0.85 25,100,000 0 25,100,000 21,289,324 2,798,988 20.46 1.70 22.16

UNITED STATES

Champion International 4 1,043 H NC NC NC NC NC NC NC NC NC

International Paper Co.* 1-3 885 H 0.93 35,800,000 0 35,800,000 33,258,749 4,372,653 13.73 1.70 15.43

Mead Corp. 1 794 S 0.87 35,800,000 0 35,800,000 31,167,931 4,097,766 14.34 -2.40 11.94

1-3 962 H 0.98 35,800,000 0 35,800,000 34,969,278 4,597,543 13.28 1.70 14.98

Potlatch Corp. 2 91 S 0.36 25,100,000 0 25,100,000 9,013,881 1,185,089 36.29 -2.00 34.29

3 399 H 0.87 25,100,000 0 25,100,000 21,927,213 2,882,854 20.06 1.70 21.76

S.D. Warren Co. (Scott) 2 227 S-H 0.62 25,100,000 0 25,100,000 15,619,813 2,053,596 25.15 -2.00 23.15

TOTALS & WEIGHTED AVERAGES 8,669 285,961,222 37,596,402 15.76 -0.26 15.50 : Type 1 & 4: (output/1000)^0.6; Type 2 & 3 (output/500)^.6 (2) O&M: Operation and Maintenance Costs. H: Hardwood; S: Softwood. NC: No Change. PTF: Paper Task Force Values displayed here are not rounded to significant digits in order to make calculations transparent. TABLE V-A.6(3): Great Lake Draft & Soda Mills Conversion Costs Paper Task Force: ADVANCED LOW EFFLUENT ECF-3

Technology: Oxygen Delignification, High Consistency Ozone Bleaching,

Chlorine Dioxide - Elementary Chlorine Free

PAPER PULP CAPITAL COST (US$)

TASK FORC OUTPUT AVERAGE

GROUP (METRIC) ADJUSTED FOR SCALE O & M TOTAL

TYPE TONS ECONOMY PAPER ADJUSTMENT ADJUSTED PER PER PER CAPITAL- PER SCALING TASK FORCE TO PTF CAPITAL TOTAL METRIC METRIC METRIC FACILITY NAME O & M (2) DAY) FACTOR (1) DATA DATA COST FIXED ANNUAL TON TON (2) TON

CANADA

Avenor (former CPFP) 1 755 S 0.84 50,800,000 0 50,800,000 42,917,250 5,642,493 20.76 -1.70 19.06

1-3 755 H-S 0.84 50,800,000 0 50,800,000 42,917,250 5,642,493 20.76 5.70 26.46

E.B. Eddy 4 500 S 0.66 15,000,000 0 15,000,000 9,896,309 1,301,105 7.23 0.60 7.83

4 500 H 0.66 15,000,000 0 15,000,000 9,896,309 1,301,105 7.23 0.60 7.83

James River- Marathon 2 499 S 1.00 35,000,000 0 35,000,000 34,956,164 4,595,819 25.59 -1.10 24.49

Kimberly-Clark 1 880 S 0.93 50,800,000 0 50,800,000 47,049,316 6,185,751 19.53 -1.70 17.83

3 380 H 0.85 35,000,000 0 35,000,000 29,686,309 3,902,971 28.53 5.70 34.23

UNITED STATES

Champion International 4 1,043 H 1.03 15,000,000 0 15,000,000 15,386,154 2,022,876 5.39 0.60 5.99

International Paper Co. 1-3 885 H 0.93 50,800,000 0 50,800,000 47,193,979 6,204,771 19.49 5.70 25.19

Mead Corp. 1 794 S 0.87 50,800,000 0 50,800,000 44,227,120 5,814,707 20.35 -1.70 18.65

1-3 962 H 0.98 50,800,000 0 50,800,000 49,621,210 6,523,888 18.85 5.70 24.55

Potlatch Corp. 2 91 S 0.36 35,000,000 0 35,000,000 12,569,157 1,652,515 50.60 -1.10 49.50

3 399 H 0.87 35,000,000 0 35,000,000 30,575,795 4,019,915 27.97 5.70 33.67

S.D. Warren Co. (Scott) 2 227 S-H 0.62 35,000,000 0 35,000,000 21,780,616 2,863,580 35.07 -1.10 33.97

TOTALS & WEIGHTED AVERAGES 8,669 438,672,939 57,673,988 18.48 1.78 20.26

: Type 1 & 4: (output/1000)^0.6; Type 2 & 3 (output/500)^.6 (2) O&M: Operation and Maintenance Costs. H: Hardwood; S: Softwood. NC: No Change. PTF: Paper Task Force Values displayed here are not rounded to significant digits in order to make calculations transparent. TABLE V-A.6(4): Great Lake Draft & Soda Mills Conversion Costs Paper Task Force: ADVANCED LOW EFFLUENT TCF

Technology: Oxygen Delignification, High Consistency Ozone Bleaching,

Hydrogen Peroxide Bleaching-Totally Chlorine Free

PAPER PULP CAPITAL COST (US$)

TASK FORC OUTPUT AVERAGE

GROUP (METRIC) ADJUSTED FOR SCALE O & M TOTAL

TYPE TONS ECONOMY PAPER ADJUSTMENT ADJUSTED PER PER PER

CAPITAL- PER SCALING TASK FORCE TO PTF CAPITAL TOTAL METRIC METRIC METRIC

FACILITY NAME O & M (2) DAY) FACTOR (1) DATA DATA COST FIXED ANNUAL TON TON (2) TON

CANADA

Avenor (former CPFP) 1 755 S 0.84 52,800,000 0 52,800,000 44,606,905 5,864,638 21.58 -2.20 19.38

1-3 755 H-S 0.84 52,800,000 0 52,800,000 44,606,905 5,864,638 21.58 4.00 25.58

E.B. Eddy 4 500 S 0.66 17,000,000 0 17,000,000 11,215,817 1,474,586 8.19 0.10 8.29

4 500 H 0.66 17,000,000 0 17,000,000 11,215,817 1,474,586 8.19 0.10 8.29

James River- Marathon 2 499 S 1.00 36,300,000 0 36,300,000 36,254,536 4,766,521 26.54 -1.50 25.04

Kimberly-Clark 1 880 S 0.93 52,800,000 0 52,800,000 48,901,651 6,429,285 20.29 -2.20 18.09

3 380 H 0.85 35,000,000 0 35,000,000 29,686,309 3,902,971 28.53 4.00 32.53

UNITED STATES

Champion International 4 1,043 H 1.03 17,000,000 0 17,000,000 17,437,641 2,292,593 6.10 0.10 6.20

International Paper Co.* 1-3 885 H 0.93 50,800,000 0 50,800,000 47,193,979 6,204,771 19.49 4.00 23.49

Mead Corp. 1 794 S 0.87 50,800,000 0 50,800,000 44,227,120 5,814,707 20.35 -1.50 18.85

1-3 962 H 0.98 50,800,000 0 50,800,000 49,621,210 6,523,888 18.85 4.00 22.85

Potlatch Corp. 2 91 S 0.36 36,300,000 0 36,300,000 13,036,012 1,713,894 52.48 -1.50 50.98

3 399 H 0.87 36,300,000 0 36,300,000 31,711,468 4,169,226 29.01 4.00 33.01

S.D. Warren Co. (Scott) 2 227 S-H 0.62 36,300,000 0 36,300,000 22,589,611 2,969,941 36.38 -1.50 34.88

TOTALS & WEIGHTED AVERAGES 8,669 452,304,981 59,466,244 19.05 0.89 19.94 : Type 1 & 4: (output/1000)^0.6; Type 2 & 3 (output/500)^.6 (2) O&M: Operation and Maintenance Costs. H: Hardwood; S: Softwood. NC: No Change. PTF: Paper Task Force Values displayed here are not rounded to significant digits in order to make calculations transparent. V-81

Table V-A.7: TCF Operational Cost Competitiveness with ECF

Scenario 3a: Capital and operational cost competitive with best ECF but lower brightness

Scenario 3b: Operational cost and brightness competitive with best ECF, but additional capital expenditure for retrofits

Scenario 1 Scenario 2 Scenario 3A Scenario 3B PARAMETER Modern Advanced Advanced AdvancedTCF ECF-1 ECF-2B TCF-A TCF-B

Bleaching Sequence ODEopD(ED) OAZEopD OAZEopP OQP(ZQ)(PO)

Brightness %ISO 90 90 82 90

AOX kg/metric ton pulp 0.80 0.05 0.00 0.00

Total chemical costs US$/metric ton pulp*

1) incl. ClO2 capital costs 28 25 22 20

2) excl. ClO2 capital costs 21 20 22 20

Notes: See Tables V-1 and V-5 for abbreviations. ClO2 : Chlorine dioxide; A: Acid stage; Q: Metal chelating stage. * Oxygen delignification precedes each scenario with identical costs (US$1.30/metric ton pulp) and is not included in chemical costs comparison presented in table. * Ozone capital costs included in its chemical costs (US$1.56/kg) for purposes of comparisons. Chlorine dioxide costs are calculated for two cases:

1) Capital costs included - reflects the cost comparisons for a mill without ClO2 capacity.

2) Capital costs excluded - reflects the cost comparisons for a mill with preexisting ClO2 capacity.

Costs calculated for 1000 metric ton pulp per day mill.

Source: Thomas R. Govers, Air Liquide, “Ozone in the Pulp Mill: Alternatives and Cost,” Proc. Int’l Non- chlorine Bleaching Conf., March 1994.