Key environmental issues (KEI) and BAT in Pulp and Paper Industry: Almut Reichart

German Environment Agency
Key environmental issues (KEI) and
BAT in Pulp and Paper Industry
Best Available Techniques (BAT) for Industrial Emission Prevention and
Control: Insights from Textiles and Paper/Pulp Manufacturing Sectors,
Webinar: 3 July 2025, 11:00-13:00 CET
Almut Reichart
almut.reichart@uba.de

Overview:
1. Introduction Pulp and Paper sector in Europe
2. BREF Pulp and Paper 2015
3. Examples for BAT for emissions to air
4. Example for BAT for emissions to water
5. Conclusions
04.03.2025 / KEIs and BAT in Pulp and Paper Sector / Almut Reichart 2

Environmental issues of the sector in Europe
• Increase of production by
50%
• electricity consumption, primary
energy consumption have
increased by 25%
• The water consumption and
some emissions like and NOx
and CO2 emissions stay around
the same high level
• other emissions are
decreasing significantly like
COD, SO2, BOD, AOX
• Substantially environmental
improvements in the production
have lead to a partially
decoupling of environmental
impacts from the production
Evolution of the absolute consumption and emissions in the European pulp and
paper industry from 1990 to 2008

Scope of the European BREF Pulp, Paper and Board
Scope:
i) chemical pulping: kraft (sulphate) and sulphite pulping process
(ii) mechanical and chemimechanical pulping
(iii) processing paper for recycling with and without deinking
(iv) papermaking and related processes
(v) all recovery boilers and lime kilns and dedicated burners for odorous gases
operated in pulp mills.
General considerations and definitions
• 18 BAT Conclusions on aspects applicable to all pulp and paper mills
Environment management systems; material management and good housekeeping,
energy, waste and waste water management, waste water treatment, odor, monitoring,
plant decommissioning and noise
• 35 BAT Conclusions for the individual processes and process steps as listed above

Example BAT for Emissions to air
(chapter 3.4.1 and 4.3.1 in OECD report)

Production of kraft
(sulphate) pulp
input/output
European BREF:
34 BAT- Associated
Emission Levels
(BAT AEL)
For emissions to air
from kraft pulp mills

Emissions to air from kraft pulp mills
Black liquor recovery
boiler
Major source of emissions
Incineration of black liquor from
pulping process in order to
generate steam and electricity
and to recover valubale
chemicals like Na and S
Waste gas flow:
6.000-9.000 Nm³/air dried ton of
pulp (ADt)
460.000 Nm³/hour
Steam production:
13 -18 GJ/ ADt
Type of pollutants:
nitrogen oxides, dust (primarily
sodium sulphate and sodium
carbonate), carbon monoxide,
sulphur dioxide and minor
concentrations of malodorous
compounds (hydrogen sulphide)

European BAT AELs for black liquor recovery boiler
Parameter and techniques Yearly average
values
mg/Nm³ at 6% O2
Yearly average values
kg S/ADT
Sulphur dioxide (as S)
Varying dry substance (DS) content of black liquor 5 - 50 DS <75%
5 - 25 DS >75%
0.03 – 0.17 DS < 75%
0.03 – 0.13 DS > 75%
Hydrogen sulphide or total reduced sulphur (TRS as S) 1 - 5
Nitrogene oxides (expressed as NO2)
Only primary measures, like computerized combustion
control, good mixing of fuel and air, for new plants: staged
air feed systems (using different air registers and air inlet
ports)
120 – 200 softwood 0.8 – 1.4 DS < 75%
1.0 – 1.6 DS > 75%
120 – 200 hardwood 0.8 - 1.4 DS < 75%
1.0 - 1.7 DS > 75%
Particulates PM after electrostatic precipitator or combination of ESP and wet scrubber
New or major refurbishment
Existing installation
10 - 25
10 - 40
0.02 – 0.20
0.02 – 0.3
BAT Nr. 20 – 23 includes lists of primary measures or abatement techniques,
information on applicability

Example BAT for emissions to water
(chapter 3.4.2 and 4.3.2 in OECD report)

Example:
input/output for
the production of
kraft pulp
European
BREF:
10 BAT-AEL
For emissions to
water from kraft
pulp mills

Example BAT for process integrated measures
Waste Water Flow
BAT 5: In order to reduce fresh water use and generation of waste water, BAT is to close
the water system to the degree technically feasible in line with the pulp and paper grade
manufactured by using a combination of techniques given below:
• Monitoring and optimisation
• Evaluation of water recycling opions, closing of water loops
• Separation of less contaminated sealing water from pumps, cooling water from contaminated
process water and reuse
• Inline treatment of process water to improve water quality for reuse
Sector BAT-associated waste water flow
Bleached kraft 25 – 50 m3
/ADt
Unbleached kraft 15 – 40 m3
/ADt
Bleached sulphite paper grade pulp 25 – 50 m3
/ADt
Magnefite pulp 45 – 70 m3
/ADt
Dissolving pulp 40 – 60 m3
/ADt
NSSC pulp 11 – 20 m3
/ADt
Mechanical 9 – 16 m3
/t
CTMP and CMP 9 – 16 m3
/ADt
RCF paper mills without deinking
1.5 – 10 m3
/t (the higher end of the range is
associated with mainly folding boxboard production)
RCF paper mills with deinking 8 – 15 m3
/t
RCF-based tissue paper mills with deinking 10 – 25 m3
/t
Non-integrated paper mills 3.5 – 20 m3
/t
The BAT
associated
waste water
flow
at point of
discharge after
waste water
treatment as
yearly average

Example BAT waste water flow
Waste water flow is an important parameter because:
• Pulp and Paper Industry is a water intensive industry
• Water flow is probably the key indicator for efficient use and management of
water and often also associated with the emission load.
• Maximum waste water flow is regulated in almost all permits for pulp and paper
mills in Germany and probably also in other countries
• In pulp and paper effluents pollutants are measured as concentrations. For the
calculation of the specific emission load the corresponding waste water flow is
necessary to calculate the pollution load (e.g. kg COD/t).

Continuous improvement in general waste water generation
in German Paper Mills
13
Specific
waste
water
flow
in
L/kg
product
Source: annual report 2023 and a publication on water and residues 2023

Emissions to water from kraft pulp mills
Bleach plant
Most important point of
discharge of pollutants to water
Can be entirely or partly closed
Waste water dicharge:
25 m³/ADt
Partly closed bleach plant can
reduce COD load 25-50% and
reduce waste water flow to 12
m³/ADt
bleaching with chlorine gas
is banned in Europe
Modern elementary chlorine
free bleaching (ECF) and
totally chlorine free
bleaching (TCF) is BAT

Modern ECF bleaching – BAT Nr. 19 + end of pipe 13-16
Minimises the consumption of chlorine dioxide by using a combination of the following
bleaching stages:
• Oxygen
• Hot acid hydrolysis stage
• Ozone stage at medium or high consitency,
• Stage with atmospheric hydrogene peroxide and pressurised hydrogene peroxide
• the use of hot chlorine dioxid stage
Achieved environmental benefit:
• reducing 2,3,7,8-TCDD and 2,3,7,8-TCDF to undetectable levels
• preventing chlorophenols and chloroform formation and reduces chlorinated organic
compound
• (AOX) formation
• reducing energy and water consumption
Environmental performance data:
• levels of organochlorinated substances of <0.2 kg AOX/Adt, advanced plants even
achieve <0.1 kg AOX/Adt

BAT Associated Emission Levels for Kraft Pulp Mills
Parameter Bleached kraft pulp in
kg/t as yearly average
Unbleached kraft pulp in
Chemical oxygen demand
(COD)
7 - 20 2.5 - 8
Total suspend solids (TSS) 0.3 – 1.5 0.3 – 1.0
Total nitrogen 0.05 – 0.25 (2) 0.1 – 0.2 (2)
Total phosphorus 0.01 – 0.03 (2)
Eucalyptus 0.02 – 0.11
0.01 – 0.02 (2)
Adsorbable organically
bound halogens (AOX)
0 – 0.2 (5) Not applicable
…
(2) A compact biological treatment plant can result in slightly higher emission values
…
(5) Production of pulp with high strenght, stiffness and high purity properties,
emssion level of AOX up to 0.25 kg/ADT may occure

BAT Associated Emission Levels for Recycled Fibre Mills
Parameter RCF without deinking in
RCF with deinking in kg/t
as yearly average
Chemical oxygen demand
(COD)
0.4 - 1.4 0.9 – 3.0
(4.0 for tissue)
Total suspend solids (TSS) 0.02 – 0.2 0.08 – 0.3
(up to 0.4 for tissue)
Total nitrogen 0.008 – 0.09 0.01 – 0.1
Total phosphorus 0.001 – 0.005 0.002 – 0.01
Adsorbable organically
bound halogens (AOX)
0.05 for wet strength
paper
0.05 for wet strength
paper
For mills with closed water circuits, there are no emissions of COD.
The BOD concentration in the treated effluents is expected to be low (around 25
mg/l as 24-hour composite sample)

Comparison of BAT- conclusion with National Binding Rules
… not included in
national requirements
so far
Additional national
requirements have to be
defined according to the
BAT conclusion
BAT conclusion and BAT AEL…
… are more demanding
than national
requirements
National requirements
have to be revised in
order to comply with
BAT
… are on equal level or
less demanding than
national requirements
National requirements
stay as they are

Monitoring and Control
• Federal states have individual systems for monitoring and control specified in local
water acts
• Control by local competent authority
− random checks without prior notification, with reasonable discretion, 1-4 times during
one year
− Analysis by methods specified in waste water ordinance (§ 4 Annex)
− Four out of five rule, no exceedance by 100% allowed
• Consequences of misconduct: higher waste water fee, additional administrative
fines, withdraw of permit for production
• Self-monitoring by the operator
− Continuous control and documentation of the performance of the waste water treatment
plant,
− Reporting to authorities
• Parameters: temperature, pH-value, (TOC), (CSB), (BSB5), (P), (NH4-N), (NO3-N),
(NO2-N), (Cl-) + additional relevant parameters (AOX), (TNb), heavy metals

Conclusions
• BAT is a dynamic concept that requires regular evaluation and updating of national
regulations and of individual permits, as well as occasional retrofitting of installations
• General binding rules are a clear guidance for permitting authorities as well as for the
operators. That leads to a level playing field of environmental standards for industrial
installations, operators know what they have to expect.
• For better implementation clear emission limit values are necessary that means that
e.g. point of reference, method, averaging period for requirements must be defined.
• Independent control by authorities is still needed for the enforcement of environmental
standards.
• Continuous self-monitoring of relevant parameters will provide a good basis for actions
to be taken by the operators in case of disturbance of the process.

Further Information
•German Environment Agency: http://www.umweltbundesamt.de/en
•European Industrial Emission Directive:
https://ec.europa.eu/environment/stories/industrial-emissions/
•BREF Documents: http://eippcb.jrc.ec.europa.eu/,
http://eippcb.jrc.ec.europa.eu/reference/
•BREF for the Production of Pulp, Paper and Cardboard:
https://eippcb.jrc.ec.europa.eu/sites/default/files/2019-
11/PP_revised_BREF_2015.pdf
•German Waste Water Ordinance: https://www.gesetze-im-
internet.de/abwv/index.html
•German Environment innovation program:
https://www.umweltinnovationsprogramm.de/

Thank you for your
attention!
Almut Reichart
almut.reichart@uba.de
www.uba.de

Back up

Air Emissions
• laid down as concentration (e.g. mg/m³) or together with the volumetric flow emitted as mass
flow (kg/h), or as specific emission limits (e.g. kg/t of product)
• Certain number of individual measurements (e.g. three) have to be made under normal
operating condition at period of representative emissions
• Continues measurement is a legal requirement in several countries for point sources of
emissions that exceed a certain threshold value of emission
• Monitoring data has to be converted to reference standard conditions (e.g. Nm³ → 0°C, 1atm)
• Reference oxygen content is defined
• Calculation of daily means are generally calculated on the basis of a certain number of half
hourly means (e.g. three)

Example for BAT conclusion on secondary measures
waste water treatment - Biofilter

waste water treatment - aerobic biofilter
Source: Hager + Elsässer

waste water treatment
Extended granular sludge
blanket EGSB reactor
Anaerobic IC-Reactor

Example for BAT Conclusion on End of Pipe Techniques
Waste Water Treatment (II)
General BAT 14:
In order to reduce emissions of pollutants into receiving waters, BAT is to use all of
the techniques given below:
• primary (physico- chemical) treatment
• Secondary biological treatment (1)
(1) Not applicable to plants where the biological load of waste water after the primary
treatment is very low; e.g. some paper mills producing speciality paper
• In addition process specific BAT for different products and products are mentioned in the
differend BAT conclusion sections

Waste Water Treatment (VI)
Combination of biological waste water treatment depending on the paper grade

Waste Water Treatment (VII)
Tertiary treatment – only BAT under special conditions
• Tertiary wastewater biofilter
• Membrane processes (ultrafiltration, nanofitration, RO)
• Evaporation
• Precipitation and coagulation
• Advanced oxidation processes
Draw backs: Energy and chemical intensive,
higher costs,
residues and concentrates

Key environmental issues (KEI) and BAT in Pulp and Paper Industry: Almut Reichart

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