PPER (Part 2): How to prepare for Canada’s updated Pulp and Paper Effluent Regulations

Understand what’s happening with your current operation

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—and 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.

Look at mill best practices before effluent treatment system upgrades

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—whichever 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.

• Collect more meaningful and usable data on your mill’s water use, wastewater sources, and water quality throughout the mill. Are you monitoring for the newly proposed additional water quality parameters in the PPER?
• Optimize your water use, as most of it becomes effluent. Figure out how you can reuse or reduce water demand within your pulp and paper making process. Be mindful to also evaluate the impact on effluent concentration.
• Ensure that you’re managing your solids waste in solid form and it is not being directed to floor drains using wet cleaning methods. Keeping waste in solid form will support better water quality going into your effluent system. In the event of fiber losses to the effluent, it can have a huge impact on operational costs.
• Implement temperature control or heat recovery within the mill. Anything you do with temperature control—before the effluent reaches the treatment system—will help prevent expensive effluent cooling costs. Temperature control within the effluent treatment system can get complicated with odor issues. This is particularly of a concern if you’re close to the community.
• Upgrade your practices in pulp washing. Optimization techniques or more efficient technologies can reduce the number of contaminants that end up in wastewater. You can also find benefits in reduced chemical addition by recovering streams in bleach plant countercurrent washing or brownstock washing.
• Switch to dry technologies to scrub dust out of your emissions. Consider electrostatic precipitators (dry scrubbers) for dust removal.
• Reduce or contain operational issues that cause “upsets” or “spills” to the effluent treatment system. We all know how hard it can be to recover from these upset conditions.
• Install proper nutrient monitoring and develop an appropriate nutrient-control strategy for your effluent treatment system. Nutrient monitoring and control are going to be even more important than ever with both the nitrogen and phosphorous limits proposed.

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.

Know your environmental effects monitoring (EEM)

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.

Expansion vs. enhancement

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. 

Think about the future

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.

A world leader in pulp and paper

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—we’re here to help you!