Pulp & Paper Mills

Stormwater run-off could come in contact with chemicals, debris, fueling areas, wastes, holding ponds, and other outside storage at pulp and paper mill facilities. Stormwater can pollute soil, groundwater, or surface water if not properly controlled, contained, or pre-treated before discharge to surface water, sanitary systems, or storm drainage systems. Contaminants can also settle out of surface waters and impact underlying sediments. Human health, wildlife, and the environment can be impacted.

Wastewater generated by pulp and paper mills can contain solvents, chlorine compounds, biocides, nutrients, solids, dissolved matter, detergents, acids, caustics, oils, and other pollutants. Wastewater treatment systems may be present at facilities, or wastewater may be discharged to sanitary sewers or transported for off-site treatment. Releases of insufficiently treated wastewater could occur, or spills could occur during the cleaning, transport, or transfer of wastewater, creating environmental risks. Improper wastewater disposal or violations of wastewater discharge permit criteria could lead to environmental liability, civil fines, or legal consequences.

Pulp and paper mills produce significant air emissions, including particulates and other pollutants. They produce nitrogen oxides, sulfur oxides, and carbon dioxide, contributing to acid rain and climate change. EPA has identified metals as the hazardous air pollutants emitted in the greatest quantity from these operations. Other persistent organic pollutants emitted from these operations include dioxins and furans, hexachlorobenzene, and polycyclic aromatic hydrocarbons. Improper controls or malfunctioning equipment can exceed permit limits and cause regulatory violations. If accidentally released, chemicals used in the process may also produce a vapor cloud. Air emissions or a vapor cloud release can pose health hazards to third parties.

Sulfides, ammonia, and other organic compounds produced from pulp and paper mill processes generate odors. Under most weather conditions, the chemicals are diluted with clean air, so health problems are not created; however, the chemicals can become concentrated, causing eye and respiratory irritation, nausea, and headaches. Odors may particularly impact those with asthma, emphysema, COPD, and other respiratory diseases. Third-party bodily injury claims can result from odors.

Pulp and paper mills generate wastewater sludge. These residues may be landfilled, incinerated, or land applied as fertilizer or soil amendment products. These facilities also may generate hazardous wastes or other regulated wastes. Improper waste disposal could lead to environmental liability, civil fines, or legal consequences. Additionally, a facility can become a Potentially Responsible Party (PRP), liable for cleanup costs and third-party claims related to contamination at a non-owned disposal facility where they sent sludges or other wastes or at agricultural properties where fertilizer or soil amendments were applied.

Historically, various toxic and persistent organic pollutants were used or generated by pulp and paper mill operations. These have included dioxins, PCBs, and PFAS-containing chemicals. Spills or releases of these pollutants may have occurred and contaminated soil or groundwater. Also, wastewater and sludge containing these constituents were allowed by regulatory agencies to be discharged or land applied in the past. Previous use or generation of these toxic chemicals presents environmental liability risks for these facilities, including claims for cleanup, bodily injury and property damage, and natural resource damage. Additionally, the paper pulp was used in products such as feminine hygiene and other personal care products, potentially exposing people to these toxins and leading to product pollution liability claims.

Accidental releases while transporting products, chemicals, or wastes from a pulp and paper mill due to improper cargo securement, a loose valve, or vehicle upsets or overturns can result in environmental liability.