EHS Considerations in the Paperboard Converting Industry

While the process of converting paperboard into corrugated sheets and containers seems rather straightforward, there are a wide array of environmental, health, and safety (EHS) challenges faced when manufacturing these products. As experts in both the converting process and EHS permitting and compliance, here are a few things ALL4 recommends you consider.

Emissions Sources and Air Permits

Have each of the units that emit regulated pollutants to the atmosphere been accounted for in your air permit? Including that diesel-fired fire pump engine sitting in the back corner of the warehouse? Is that parts washer exempt, or does that need to be on the permit too?

Many converting plants can be classified as minor sources of criteria and hazardous air pollutants, which means that the permitting requirements vary greatly from state to state. What could be exempt from permitting in one state may require a state operating permit and air dispersion modeling in another. Emissions reporting for minor sources can also vary greatly and may not be required on an annual basis. Irregular reporting deadlines can lead to confusion and missed reports if a robust compliance calendar is not in place.

The primary pollutants of concern for most converting facilities are generated at the converting equipment and the wastepaper handling system, which respectively emit Volatile Organic Compounds (VOC) and Particulate Matter (PM). Although facilities may have boilers or emergency engines, emissions from these units are typically small and may only result in regular tuning or maintenance requirements. Watch out for state air quality requirements around replacing burners or other combustion equipment, however. Your new burner may need to meet a certain emissions level.

VOC emissions, including hazardous air pollutants (HAP), come from residual VOC in the paper as well as the adhesives or additives used in the converting process, whether that’s for the corrugator or a specific color of ink. VOC emissions come with their own challenges as many states can regulate the toxic air pollutants/contaminants (TAP/TAC) at the state level, and those restrictions arise from health-based studies of these pollutants in the environment. In addition, some states require potential emissions be based on fairly unrealistic assumptions around ink and coating usage. You may be able to reduce your permitting burden by evaluating whether alternative inks with lower VOC or HAP/TAP content can be used.

While we certainly have to consider particulate emissions with respect to air quality requirements, there are other media to consider.

• PM emitted from a roof vent can collect on surfaces and later be washed off during a rain event. It then becomes part of the plant’s stormwater, contributing to the total suspended solids (TSS) loading of the discharge. A starch silo can also contribute PM to air and stormwater emissions if it is not maintained properly.
• Because the PM emitted from a converting plant originates from paper, it is defined as a combustible dust. While external emissions of paper dust do not pose a combustion risk, enclosed spaces with high concentrations of dust (e.g., a baler or hogger) should be assessed for hazard risks.

Discharges to a POTW

The majority of converting plants will discharge wastewater to their municipality’s publicly owned treatment works (POTW). Depending on the municipality requirements and the site’s specific wastewater, pretreatment may be required to meet discharge limits. All POTWs will require sampling on some frequency and will monitor discharge status. Discharge limits often include pH, TSS, chemical oxygen demand (COD), and color. Changes to the inks and additives used on-site can impact wastewater quality. As POTW permits change or as regulatory agencies request information from POTW on emerging contaminants such as PFAS, impacts may be felt upstream by industrial dischargers including converting operations. Changes may come in the form of new or reduced discharge limits, data collection, or additional monitoring requirements.

Chemical Storage

In addition to the actual physical chemical storage requirements, there are several regulations to keep in mind. Spill Prevention, Control, and Countermeasure (SPCC) plans are required for certain volumes of oil storage. Reporting and tracking is required for certain chemicals stored above their listed thresholds under the Emergency Planning and Community Right-to-Know Act (EPCRA) and Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) requirements. This can open your site to requirements to maintain a Facility Response Plan (FRP) or fall under Risk Management Plan (RMP) guidelines, especially if you are co-located with a paper mill.

Stormwater

Many converting operations have the potential to impact stormwater discharge, requiring them to obtain and maintain stormwater permit coverage, most often in the form of coverage under a state general permit. These permits often require sampling, inspections, training, reporting, recordkeeping, and implementing and maintaining a Stormwater Pollution Prevention Plan (SWPPP). When general permits renew, sites are required to register for continued coverage and update their SWPPP and onsite practices, as required, to comply with the renewed permit.

Safety

In addition to the combustible dust concerns mentioned above, another key safety program at converting plants is lockout/tagout. The converting equipment contains knives to cut the paperboard, as well as multiple pinch points due to the large amount of rollers. Also, these plants will certainly have powered industrial trucks (PIT) inside the manufacturing and warehouse areas. Therefore, a robust pedestrian safety program is necessary for each facility. You also want to make sure your safe work procedures are well laid out and easy to follow so your expectations for workers are clear.

EHS Staff Turnover

Typically, the EHS Department at a converting plant consists of only one or two employees. When the department changes hands, knowledge can easily be lost. The following best practices can prevent a critical knowledge gap when roles change.

• Document decisions made internally or by a regulatory agency (e.g., memo to file).
• Maintain an organized file system – both electronic and physical.
• Use a compliance calendar to track all reporting and compliance due dates.
• Prepare a quick reference sheet for environmental permits and plans.
• Document all assumptions and emissions factors in air emissions calculations.
• Have at least two individuals who can access online reporting systems within the organization.

How Can ALL4 Help?

Do EHS concerns at your converting plant keep you up at night? ALL4 can help – from air permitting to SPCC plans to lockout/tagout programs and everything in between. Reach out to your ALL4 contact or Anna Richardson at arichardson@all4inc.com for more information.