PPER (Part 2): How to prepare for Canada¡¯s updated Pulp and Paper Effluent Regulations
September 26, 2024
September 26, 2024
The federal government¡¯s modernized pollution control regulations will soon be official. What should Canadian pulp and paper mills consider?
If you¡¯re in the Canadian pulp and paper industry, you¡¯ve heard: New federal effluent regulations are on their way.
Of course, we¡¯re referring to the fact that Environment and Climate Change Canada (ECCC) has issued an updated detailed proposal for its Pulp and Paper Effluent Regulations (PPER). As we discussed in our previous blog on the regulations, the federal government has adjusted portions of the regulations in the past. But now, ECCC is performing a complete review of its protection, implementation, and compliance requirements.
And while the final regulations haven¡¯t been released yet, it¡¯s wise to start thinking about them and how you can prepare. Our last blog examined why the federal government is updating the PPER and what the proposed changes look like. Now that you understand the basics about the PPER changes, let¡¯s discuss some of the things you should be thinking about as the proposed modernized effluent regulations become official and come into effect.
OK, so what¡¯s next? First, it¡¯s time to get organized. Know the best management practices applicable to your plant or facility. Be aware of the technologies in your pulp and paper making process and in the treatment system. Understand your effluent treatment system¡¯s capacity.
Think about the changes your facility has made that deviate from the original design intent¡ªand why those changes were made. Consider the mill¡¯s long-term goals. How can all these changes impact your effluent treatment system¡¯s original capacity?
For example, we recently consulted for a Canadian mill that was dealing with exceedances for biochemical oxygen demand (BOD) and total suspended solids (TSS) in its existing effluent treatment system. The mill was also experiencing random toxicity issues.
Our first step was to collect and review the available data. We pored over documents and data ranging from 5 to 40 years into the past and tried to understand how things have changed. How was the effluent treatment system designed? How is it operating now and how has that differed since the exceedances and toxicity issues appeared? It took some detective work to identify the problem.
We first figured out that the mill was operating the effluent treatment system way above capacity, which was also obvious to the mill without the data analysis. It was our later findings, however, that weren¡¯t obvious to the mill. We found repeated short-duration high-strength chemical system upsets coming from the mill. This caused multiple-day performance challenges in downstream wastewater treatment units. The issue was being masked by misinterpretation of the data. It felt great to find the source of the problem. We were able to help the mill create a path to collect even more data to help them improve monitoring and control, so they could get back on track with compliance.
In this case, our client¡¯s current operation wasn¡¯t meeting the effluent limits as per today¡¯s regulations. Their excellent data-acquisition methods allowed us to find the root cause of the issue, a rare find in many facilities. If you¡¯re struggling with your current operation, you¡¯re going to have a bigger problem when limits get tighter in the future. If you have good process data, that¡¯s a great starting point for understanding your options.
If there¡¯s one thing we want you to remember, it¡¯s this: Don¡¯t wait until the final updated regulations are released. Act now.
Start doing scoping work. Understand how you can upgrade your internal pulp and papermaking operation to meet best practices or best technologies¡ªwhichever is more feasible. Then, look at the upgrades required for your effluent treatment system. Here are a few pointers on getting started within the mill.
Scoping work and studies take time and effort. Depending on what you may find after you do your study and what the needs are for your effluent treatment system upgrade, you might be looking at up to five years (or even more) to do the engineering, construction, and commissioning. That¡¯s why it¡¯s important to act now.
Don¡¯t wait until the final updated regulations are released. Act now.
When preparing for the updated pollution control regulations, you need to also think about the receiving environment. Suppose your mill discharges into an ecosystem or aquatic habitat (a stream, river, wetland, etc.). In that case, your effluent limits should be lower than the federal level to protect the fish and fish habitat of the receiving environment.
As you may know, mills prepare a study design for EEM. After ECCC approves the study, the mill carries it out. This involves collecting fish and benthic invertebrate samples along with water and sediment quality samples within the receiving environment. Then we analyze the impact of effluent on the fish and fish habitat. The mill then submits the study to ECCC for review of the effluent impacts on the mill¡¯s receiving environment.
So, make sure that you have a plan in place for compliance with the new requirements for EEM.
When hearing about the proposed updated PPER, your first thought might be: ¡°Do we have to upgrade?¡± We can sense the anxiety. You may not have any additional physical footprint available for an expansion. An expansion means you¡¯ll also have to consider capital/operational cost, maintenance, and operational changes.
Here¡¯s how we¡¯d respond: Look at your production best practices before anything else (like we discussed above). What can you change in your plant before the contaminants reach your effluent treatment system? Capturing contaminants at the source is the best way to avoid any treatment.
Maybe you don¡¯t need to expand the physical footprint of your wastewater treatment system. Is there a way to enhance your current treatment equipment? If you optimize your waste capture upstream within the facility, you may only need a minor expansion or an extra piece of equipment.?
If you¡¯re considering changes to align with the ECCC¡¯s proposed PPER updates, don¡¯t forget to look at the future goals for your facility. Don¡¯t assess the situation only based on past decades. What¡¯s the big picture? What¡¯s your plant¡¯s expansion plan? What new product lines might you offer? Consider future plant upgrades, process changes, and production increases, which would impact your effluent quantity and quality.
Pulp and papermaking facilities have many working parts. If you ignore the bigger picture, you might construct something too small, like buying a sweater for your kid that only fits for the coming month. You need to build for growth.
Don¡¯t forget the pollution-control side of your expansion project and the site implications of climate change. Budget for that as well.
Ensure that you¡¯re working toward meeting the stricter standards of the PPER. If not, you could be considered non-compliant when the final regulations are released, which could lead to fines or other enforcement actions.
We know it¡¯s not easy. Mitra remembers working at the environment department of a pulp mill when she first heard about the PPER modernization. She recalls reviewing her mill¡¯s effluent treatment system operation to see if they¡¯d be able to meet the newly proposed limits. And she remembers numerous discussions with her colleagues and the challenges they faced. Now, she¡¯s pleased to be able to provide practical advice to mills going through the same thing.
We¡¯ve thoroughly enjoyed our time working with pulp and paper clients in Canada. The country is one of the world leaders in pulp and paper products production. We wish you good luck as you make your plan to comply with the revised regulations. And don¡¯t forget¡ªwe¡¯re here to help you!