Guidance

Paper and pulp: pollution inventory reporting

Updated 19 April 2024

Applies to England

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This publication is available at https://www.gov.uk/government/publications/pollution-inventory-reporting-guidance-notes/paper-and-pulp-pollution-inventory-reporting

If you operate an A1 facility you will need to submit data to the pollution inventory.

The ‘general guidance’ available in the pollution inventory reporting guidance gives information that applies to all business and industries. It explains what the pollution inventory is and how to report.

This guidance gives information specific to paper and pulp sector activities.

Emissions to air

Relevant pollutants

The most common air emissions from paper and pulp activities are:

  • carbon dioxide (CO2) – from effluent treatment plant (paper and pulp), and semi-chemical, with recovery (pulp)
  • carbon monoxide (CO) – from papermaking (paper), and effluent treatment plant (paper)
  • chloroform – from bleaching (paper), effluent treatment plant (paper), recycled fibre pulping and deinking (pulp), and bleaching with chlorine dioxide or sodium hypochlorite (pulp)
  • formaldehyde - from resins used in papermaking (paper)
  • methane (CH4) – from anaerobic effluent treatment plant (paper and pulp)
  • nitrogen oxides (NOx) – from effluent treatment plant (paper and pulp), and neutral sulfite semi-chemical, with recovery (pulp)
  • particulate matter – from finishing and converting operations (paper), and neutral sulfite semi-chemical, with recovery (pulp)
  • volatile organic compounds (VOCs) – from drying process (paper), and mechanical and chemi-mechanical pulp (pulp)

Use this list as a guide only and check that there are no other pollutants emitted from your installation. Combustion process releases are not included in this list.

Emission sources

Point source emissions

These emissions are exhausted through a stack or vent. That is, from a single point source into the atmosphere. Abatement equipment, for instance cyclones for removal of particulate matter, can be incorporated into the exhaust system prior to discharge to atmosphere.

Fugitive emissions

Fugitive emissions are those that are not released from a point source such as a stack. Fugitive emissions are not considered to be significant in the paper and pulp industry, however you still need to monitor for large releases.

Emissions to water

Emissions of substances to water can be either direct to controlled waters or indirect, following transfer to off-site effluent treatment plant. Most mills discharge through their own treatment works, or through a municipal one. Releases to water should be a major consideration for you. Although actual water loss to the environment is low, increased emissions come from the high volume of water you use.

Guidance on what constitutes an emission or transfer is contained in the pollution inventory general guidance.

Relevant pollutants and emission sources

A wide variety of substances are present in water discharges from paper and pulp processes. Some residual organic constituents of the effluent are not known in detail.

We have listed the most common pollutants emitted to water. Not all of these are substances are included on your pollution inventory return, but you need to think about any reportable substances emitted in association with them. For example, you need to consider metal contents incorporated with total suspended solids. Use the list as a guide only, and check that there are no other reportable substances emitted from your processes, or substances that are required to be monitored by permit condition.

The most common pollutants from papermaking are:

  • alcohols and acids
  • ammonia (NH3) (also from effluent treatment)
  • cadmium
  • defoamers
  • formaldehyde
  • heavy metals
  • mercury (Hg)
  • particulate matter, total suspended solids
  • pentachlorophenol
  • phosphates and nitrates (also from effluent treatment)
  • sulfides (also from effluent treatment)
  • sulfites and sulfates
  • surfactants
  • wood organics

The most common pollutants from pulp processes are:

  • alcohols and acids (from pulping)
  • cadmium (from pulping and bleaching)
  • chloroform (from bleaching, RCF pulping and de-inking)
  • defoamers (from RCF pulping and de-inking)
  • heavy metals (from pulping and bleaching)
  • mercury (Hg) (from pulping and bleaching)
  • particulate matter and total suspended solids (from pulping and bleaching)
  • pentachlorophenol (from RCF pulping and de-inking)
  • phosphates and nitrates (from pulping)
  • sulfides (from RCF pulping and de-inking, and mechanical pulping)
  • sulfites and sulfates (from RCF pulping and de-inking, and mechanical pulping)
  • surfactants (from RCF pulping and de-inking)
  • wood organics (from pulping and bleaching)

The discharge of the above substances depends on your ‘in process’ preventative measures (for example, good housekeeping and reuse). It also depends on the presence and technical standards of your wastewater treatment facilities.

Off-site transfers

You must classify wastes using the European Waste Catalogue 6-digit codes and the relevant Waste Framework Directive (WFD) disposal and recovery (D&R) codes. Check the ‘reporting codes list’ in the pollution inventory reporting guidance.

Relevant wastes

List of Waste (LoW) sub-chapter 03 03 contains codes that cover the majority of process wastes generated by paper mills: wastes from pulp, paper and cardboard production and processing.

We have given the most commonly used codes:

  • 03 03 01 waste bark and wood (waste wood and bark from wood pulping only)
  • 03 03 05 de-inking sludges from paper recycling (that is, de-inking sludges from paper recycling containing short and rejected fibres, fillers, including ink compounds, de-inking detergents and surfactants)
  • 03 03 07 mechanically separated rejects from pulping of wastepaper and cardboard (post pulping) (that is, mechanically separated rejected materials or contraries from the pulping process of wastepaper and cardboard and downstream screening of the resultant pulp - containing some rejected fibres, plastics, glass, metal and so on)
  • 03 03 08 wastes from sorting of paper and cardboard destined for recycling (pre-pulping) (that is, wastes from pre-sorting or separation of paper and cardboard prior to the pulping process and containing similar rejected materials or contraries to 03 03 07, but potentially more organic material and generally larger and drier than 03 03 07 materials - may come from an on-site MRF)
  • 03 03 10 fibre rejects, fibre, filler, and coating sludges from mechanical separation (that is, rejected or short fibres, fillers, coatings and sludges from mechanical separation, includes sludges from paper recycling activities where de-inking is not carried out – fibres and sludges from mills without a secondary ETP)
  • 03 03 11 sludges from on-site effluent treatment, other than those mentioned in 03 03 10 (that is, secondary effluent sludges from on site (aerobic or anaerobic) effluent treatment plants, other than those mentioned in 03 03 10 - may contain a mixture of primary and secondary sludges)
  • 03 03 99 wastes not otherwise specified (please do not use this code unless agreed with Environment Agency site inspector)

Where paper sludges are ‘mixed’ on site prior to recovery or disposal, use the code which best describes the largest or most significant fraction. For instance, if primary sludges and fibres (03 03 10) are mixed with secondary ETP sludges (03 03 11), then code the mixed waste stream according to the largest fraction. However, where de-inking sludges (03 03 05) are mixed with primary and secondary ETP sludges, the resultant mix should all be coded as de-inking sludges to prevent de-inking sludges going for unsuitable recovery operations.

Other LoW codes applicable to paper making activities are:

  • 19 12 01 waste paper and cardboard from mechanical treatment of waste (that is, waste paper and cardboard shredded before being sent off site, including paper spoil or broke that is sent for shredding and animal bedding under a U8 exemption)
  • 10 01 14* bottom ash, slag and boiler dust from co-incineration of paper sludge (PSA) – hazardous – (containing dangerous substances – use 10 01 15 only if it does not contain dangerous substances above the thresholds)
  • 10 01 16* fly ash from co-incineration of paper sludge containing dangerous substances (PSA) – hazardous – (there is a general expectation that fly ash containing APC residues will be classified as hazardous – use 10 01 17 only if it does not contain dangerous substances above the thresholds)
  • 19 01 11* bottom ash and slag from incineration of paper sludge (PSA) – hazardous – (containing dangerous substances, use 19 01 12 only if it does contain dangerous substances above the thresholds)
  • 19 01 13* fly ash from incineration of paper sludge containing dangerous substances (PSA) – hazardous – (there is a general expectation that fly ash containing APC residues will be classified as hazardous – use 19 01 14 only if it does not contain dangerous substances above the thresholds)

You must carry out a hazardous waste assessment of mirror entries (indicated here by an asterisk, *) in line with the waste classification technical guidance.

D&R codes

The most common D&R codes and their associated waste activities are:

  • D2: land treatment - disposal of sludge to land where land is performing a treatment process to the sludge, rather than the sludge is conferring a benefit to the land (these situations are increasingly rare, check with your Inspector before using this code)
  • D5: wastes sent to landfill
  • D10: incineration or co-incineration of paper sludge without energy recovery - see note 2 (above)
  • R1: incineration or co-incineration of paper sludge, where the activity is principally for the generation of energy
  • R3: recycling and reclamation of organic substances such as sludges and fibres through composting or other biological transformation, for example, anaerobic digestion (this WFD code should be used for animal bedding)
  • R4: recycling and reclamation of metals and metal compounds
  • R5: recycling and reclamation of other inorganic materials
  • R10: land spreading of sludge and fibre to land for agricultural benefit or ecological improvement, or land restoration, reclamation or improvement on non-agricultural land (under SR2010 No4 and No5 respectively)
  • R13: exchange of wastes for submission to any of the operations numbered R1 to R12 (this code should not be routinely used – however, it does apply to material that is stored prior to going for processing into refuse derived fuel (RDF))

When waste is transferred to a third party, the appropriate WFD code is determined by the relevant end use or recovery activity. If the third party varies these according to demand or available recovery options, you should decide the appropriate code by using the average split through the year.

Materials that are stored prior to going for processing into RDF can be coded to R13. The RDF production activity is typically coded to R3, R4 or R5. Note that the R1 code only applies to the actual energy recovery process. That is, the combustion or incineration plant that is using waste to generate energy.

Other notes to be aware of

You should not usually use R13 and D15 codes. These codes are normally only used for small quantities of waste in exceptional situations.

Only record wastes that are generated from your installation itself. Do not record wastes from areas of the site that are not within the installation boundary such as offices. The vast majority of wastes coded should be from paper making and associated activities.

Do not code wastepaper brought onto site for re-processing, other than that rejected and sent for further recovery or disposal off site. You do not need to report wastes treated, recovered, or disposed of within your permitted installation boundary. For example, this would include paper sludge which is sent to an on-site incinerator under the same permit. If you transfer waste to a separate permitted installation, even if you also operate that site, then it should be reported.

You should not record mill broke sent on to another site for re-working as it is deemed a by-product and not a waste.

Rejects of separated glass and metal should be coded to R4 or R5. The appropriate R code is determined by which portion is heaviest.

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