Paper and cardboard manufacturing pollution prevention
How to prevent air, land and water pollution in paper and cardboard production and dealing with pollution incidents.
The paper and cardboard industry can cause significant pollution. The industry includes paper and paperboard manufacturers, and businesses that produce paper and paperboard products. It also includes businesses that carry out finishing activities, such as coating, covering, laminating and embossing paper or cardboard.
Your activities may cause air pollution from dust and fumes, water pollution from contaminated discharges or run-off, noise pollution from materials handling and deliveries to your site, and land contamination from accidental spills of solvents.
This guide describes your responsibilities for preventing pollution to air, land and water. It includes guidance on noise and vibration. It also covers how to prevent and deal with pollution incidents.
Paper manufacturing and air pollution
Types of air pollution from paper and cardboard production, and what you must do to reduce or prevent it.
Paper and cardboard businesses can emit dust, smoke, fumes and gases which affect air quality.
Types of paper manufacturing emissions and air pollution
Emissions to air include:
- oxides of nitrogen (NOx), sulphur (SOx) and carbon (COx) from combustion plant or liquor burning
- particulates and dust from combustion or paper handling
- formaldehydes and ammonia from wet strength resins
- solvents from cleaning or coating processes
- chloroform from the use of chlorine compounds in bleaching
- odorous substances from wet pulping or effluent treatment plants
Comply with your permit conditions
If your business has a pollution prevention and control (PPC) permit, you must meet the conditions it contains.
Your permit may contain conditions relating to odour and emissions to air, including controls on substances such as:
- halogens, eg chlorine, fluorine and bromine-containing substances
- NOx
- particulates, eg PM10 and dust
- SOx
- volatile organic compounds, eg formaldehyde
If you use organic solvents, you must comply with further requirements.
Avoid causing a nuisance
You must ensure that your activities do not create levels of dust, smoke or odour that could cause a nuisance to the surrounding community. If you do cause a nuisance, your local council can:
- impose restrictions on your operations
- stop your operations
- require you to take steps to reduce the nuisance
See noise pollution, odour and other nuisances.
Meet boiler and chimney requirements
If you operate a boiler, you are likely to have to meet tight controls on its emissions to air.
You must not cause or allow a chimney or bonfire on your site to emit dark smoke. There are some exemptions from this requirement, but only if your installation won't cause emissions that could damage health or cause a nuisance - see preventing air pollution.
Check for ozone-depleting substances (ODS) or fluorinated gases (F gases)
In most circumstances, you must not use ODS for any degreasing or solvent application. ODS include:
- hydrochlorofluorocarbons (HCFCs)
- chlorofluorocarbons (CFCs)
- 1,1,1-trichloroethane
- bromochloromethane
- carbon tetrachloride
F gases are powerful gases that contribute to climate change. Common F gas uses include:
- refrigeration and air-conditioning equipment in buildings and vehicles
- solvents
- firefighting and fire protection equipment
If your business uses or handles F gases or equipment that contains them, you must comply with special controls.
Good practice to prevent air pollution
To reduce dust, odours and fumes you should:
- establish systems to monitor, measure, control and minimise dust emissions
- damp down areas of your site that give rise to dust (particularly in dry weather), but don't allow run-off to enter surface water drains
- extract and filter dust-contaminated air during finishing
- install chemical recovery systems to capture chemicals in exhaust gases
- use filtered extraction hoods on paper machines to prevent emissions of odorous substances
- remove water vapour with a ventilator to prevent emissions of hazardous substances in the water vapour
- use low NOx burners if you have combustion plant
- keep covers on chemical containers to prevent odour and stop the escape of potentially harmful vapours and fumes - this may also save you money by reducing loss of materials through evaporation
To reduce the risk of harmful chemical emissions you should:
- reduce the use of bleaching chemicals by extending cooking and oxygen delignification
- use brightening techniques that do not dissolve the lignin when bleaching mechanical pulp or recovered mechanical pulp - this will reduce the chemical oxygen demand of water in the manufacturing process
- use chlorine-free techniques that do not use sulphur compounds when bleaching chemical or recovered chemical pulp
Paper manufacturing and noise pollution
What your business must do to reduce or prevent noise pollution from your paper and cardboard production.
Paper and cardboard businesses may create noise by:
- operating large processing plant and machinery, eg compressors, vacuum pumps and ventilators
- moving materials and goods to and from the site
- using vehicles on the site, especially if they have reversing alarms
Your activities can also create vibration. Noise nuisance also covers vibration and both are controlled at the same time.
If noise or vibration from your activities causes a nuisance to the surrounding community, your local council can limit your operations or even stop you from working. They can restrict:
- the machinery you use
- your working hours
- noise levels from your premises
If you have a permit, licence or exemption and you breach noise conditions the Northern Ireland Environment Agency (NIEA) or your local council can take enforcement action against you. If you do not address a noise problem you could face legal action and a fine.
You must comply with any noise conditions set out in the planning approval for your site.
Register your burglar alarms
If your business is located in an alarm notification area you must:
- register your burglar alarm with your local council
- provide the details of a person who holds the keys
- ensure the key holder knows how to use the alarm system
You could be fined if you do not register. Contact your local council to find out if your business is in an alarm notification area.
Protect your employees from loud noise
Loud noise can cause irreversible hearing damage. You must protect your employees' hearing.
Check your permit conditions
If you have a pollution prevention and control permit, a waste management licence or a waste exemption, it may contain conditions that control emissions, such as noise.
You must comply with all of the conditions in your permit, licence or exemption. If you don't comply, the NIEA or your local council can take enforcement action, such as issuing you with an enforcement notice or a suspension notice for breach of a condition.
Good practice to prevent noise pollution
Carry out noisy activities away from areas where noise may cause a nuisance. Position noisy equipment away from your site boundary. You can use existing buildings to shield the noise source.
Make sure your buildings have adequate soundproofing. Shutting your doors and windows will also reduce noise. Use solid panelled fencing around your site instead of wire fences. This can help to screen the source and reduce the level of noise from your site.
Keep external doors and loading bays closed when they are not in use. For example, fit automatic closing devices to help prevent excess noise causing a nuisance to your neighbours.
Chipping and pulping operations can be extremely noisy. If you carry out these activities you should do so in a section of your building that has adequate soundproofing or acoustic dampening to minimise the impact of the noise.
Reduce noise from your equipment and vehicles by servicing them regularly. Consider fitting noise-reducing devices, and when you replace equipment consider buying quieter alternatives.
You should regularly monitor noise from your site, when it is fully working and also when it is shut down. This will give you an idea of the impact of your work on noise levels in the surrounding community. Monitoring will also help you identify any change in noise levels. If you are in any doubt about noise levels, you should get advice from a noise expert.
Limit noisy activities to daylight hours as noise is more likely to be a nuisance at night.
If you operate a night shift, move materials into the work area during the day or early evening. This will reduce the risk of complaints from the local community.
If you receive a complaint make sure you deal with it properly. Find out how to deal with complaints with our good practice to avoid causing nuisance.
Paper manufacturing and water and sewer discharge
Preventing water pollution from paper and cardboard production, and authorisations needed for discharges to water.
If you pollute water or cause or risk causing environmental damage to water, you may be committing an offence.
Types of paper manufacturing effluent
Your paper and cardboard business may create wastewater or effluent from:
- process effluent, eg from de-inking operations
- effluent or other treatment plants
- boiler operations
- cooling processes
- cleaning operations
- site drainage and stormwater run-off
Your wastewater or run-off may contain:
- suspended solids
- oil and fuels
- heavy metals, such as mercury and cadmium
- acids and alkalis, which affect the pH of the water
- solvents
- softening or brightening agents
- biocides, eg plant protection chemicals
- cleaning products
You should handle these substances with care at all stages of processing and manufacture as they can pollute surface waters and groundwater.
Get permission to discharge to water and sewers
You must get a discharge consent or groundwater authorisation from the Northern Ireland Environment Agency (NIEA) before you discharge anything other than clean, uncontaminated water to surface waters or groundwater. You may also need consent if you need to construct a new outfall structure for your discharge.
You must comply with the conditions of your consent or authorisation or you may be prosecuted and fined.
You must have permission from NI Water before you discharge anything other than clean, uncontaminated water to their drainage system. If you discharge trade effluent to a public foul sewer, you must first have a trade effluent consent or agreement.
Prevent environmental damage
Water pollution can be classed as environmental damage in some circumstances.
You must prevent and clean up environmental damage that occurs from surface or groundwater pollution caused by your business activities. If anyone else reports environmental damage as a result of your activities, your enforcing authority will have to investigate - see pollution incidents and environmental damage - an overview.
Good practice to prevent water pollution
Store hazardous materials, fuel, oil and chemicals safely and in an area where you can contain spills. This may be a legal requirement if you store oil - see storing oil.
You should use an impermeable secondary containment system such as a:
- bunded area
- bunded pallet or spill pallet
- sump pallet
- bunded storage unit
- bunded drum store
- storage cabinet with an integral sump
Your bund and any bunded pallets should be able to contain at least 110 per cent of the volume of the largest tank or 25 per cent of the total volume you are likely to store, whichever is greater.
For information on managing your drainage system, see drainage system requirements to avoid pollution.
Follow the pollution prevention guidelines (PPGs) to avoid causing pollution. This is particularly important if your business is in an area that has vulnerable groundwater.
Prepare a pollution incident response procedure for dealing with spills. Make sure that your staff are familiar with the procedure and know how to implement it - see pollution incident prevention at paper and cardboard production sites.
Paper manufacturing site pollution incident prevention
Types of pollution incidents from paper and cardboard production, and how you can prepare for and deal with them.
Pollution incidents at your site can have serious environmental impacts. They may damage the water environment and biodiversity, cause air pollution and land contamination and harm human health. You can reduce the risk of pollution incidents with planning and preparation.
Examples of paper manufacturing pollution
Pollution incidents can be caused by:
- fuel drips, spills or overfilling during refuelling or tank filling
- plant, pipes, equipment or containers leaking oil or chemicals
- pump and pipeline failures
- treatment plant failures
- contaminated water entering a waterway or drain
- natural events, such as flooding, lightning strike and temperature extremes
- vandalism and theft
- deliberate acts, such as illegal disposal, dumping or fly-tipping
- wind blown dust and waste
Produce a pollution incident response plan
You should have a pollution incident response plan which outlines the actions you will take to reduce the chances that your business causes pollution from an incident or accident at your site.
Your plan should include:
- your site activities and operations
- what you store on your site
- emergency and out-of-hours contact details for key staff, regulators and emergency services
- a detailed site plan showing drainage layout, areas where the chances of causing pollution are high and areas vulnerable to pollution
- the actions to take in the event of an incident
Prevent and remediate environmental damage
A pollution incident may cause, or threaten to cause, environmental damage to water, land and biodiversity.
You must take action to prevent environmental damage and to remedy any damage you cause.
Prevent pollution from firefighting
Firewater is water that has become contaminated by being used for firefighting. It is polluting and may be classified as hazardous waste. Ensure you have a plan and equipment in place to collect or contain it in the event of an emergency. You should:
- store firewater correctly
- ensure firewater is treated and disposed of correctly
- prevent firewater from running into surface drains, polluting nearby waterways (rivers, streams and groundwater), foul drainage systems and land
Paper manufacturing and land contamination
Dealing with land pollution at paper and cardboard sites, and how you can avoid causing land contamination.
If you operate a paper and cardboard production business, you could be causing land contamination from:
- spills or leaks of fuel, oil or chemicals from your storage areas
- pollutants seeping from leaking pipes or poorly maintained drainage systems
- inappropriate handling or disposal of hazardous substances such as chemicals or fuel
The paper industry uses chemicals and materials that can cause contamination, including:
- metals and metallic compounds
- acids and alkalis
- inorganic elements and compounds
- solvents, oils and biocides
Many areas of land in Northern Ireland are contaminated by their past use. For example, land could be contaminated where chemicals have seeped into the land from previous industrial activities, or where previous owners have buried waste.
Responsibilities for cleaning up land contamination
You could be responsible for cleaning up land contamination, for example, if you:
- develop land that is contaminated
- cause environmental damage to land
- cause contamination in breach of your pollution prevention and control (PPC) permit
You could be required to clean up land contamination before you are allowed to carry out development.
If you cause serious land contamination that affects the water environment, protected species or habitats, or human health, this can be classed as environmental damage. You could be responsible for land contamination if it is classed as environmental damage - see responsibilities for land contamination.
You could also be responsible for land contamination if it is caused by you breaching the terms of your PPC permit.
Good practice to deal with contaminated land
Ask a consultant to carry out a desktop survey and possibly some site investigations to check if land could be contaminated before you purchase it.
Research the history of your site and the activities carried out on it. Investigate any land that could be contaminated and see if you can identify who may have caused any contamination.
Store oil and chemicals safely to avoid causing pollution.
Keep absorbent materials and other containment equipment close to where you might need them. Ensure that they are suitable for the type and quantity of fuel, oil and chemicals you store and use on site. Ensure that your staff know where they are and how to use them properly - see storing chemicals.
Have a pollution incident response procedure for dealing with spills and use it with your drainage plan. Ensure that all staff on site know about the procedure and how to put it into practice - see pollution incident prevention at paper and cardboard production sites.