Bisphenol A in paper recycling mill effluents: environmental performance agreement overview

This environmental performance agreement (the agreements) was in effect from March 5, 2013 to March 5 2017.

For a copy of the agreement, email: ec.epa-epe.ec@canada.ca

Objective

The objective of the agreement was to initiate action by paper recycling mills to minimize the risk of environmental impacts from their effluent releases of bisphenol A (BPA), where necessary, to the greatest extent practicable.

Signatories

The agreement was negotiated between Environment and Climate Change Canada and 13 paper recycling companies:

• Atlantic Packaging Products Ltd.
• Cascades Inc.
• Georgia-Pacific Canada LP
• J.D. Irving Limited
• Kruger Inc.
• Produits Kruger S.E.C.
• Kruger Wayagamack Inc.
• Kruger Publication Paper Inc.
• Resolute FP Canada Inc.
• RockTenn - Container Canada, L.P.
• Société en commandite Stadacona WB
• Sonoco Canada Corporation
• Strathcona Paper LP

Performance objectives

Performance objectives are based on whether the paper recycling mill deposits effluent into surface waters (direct deposit facilities) or the paper recycling mill deposits effluent into an off-site wastewater system (indirect deposit facilities). The agreement includes annual sampling and reporting requirements.  

Performance objectives for direct deposit facilities:

• a) Achieve and maintain an average annual BPA concentration of below 1.75 micrograms per litre (μg/L) in the Final Effluent at each Mill; or

• b) Achieve and maintain an average annual BPA concentration in the Final Effluent at each Mill, such that the Concentration of BPA in the Receiving environment does not exceed 0.175 μg/L within 100 m downstream of the point of deposit. This will be based solely on the Mill's contribution of BPA to the Receiving environment; or

If objectives (a) or (b) cannot be met, the following objective applies:

• c) The Direct Deposit Facility will develop and implement, to the greatest extent practicable, an approach to reduce the BPA concentration in the Final Effluent or Receiving environment, at each Mill, to as close to objective (a) or (b) as is technically and economically feasible.

Performance objectives for indirect deposit facilities:

• a) Achieve and maintain an average annual BPA concentration of below 1.75 μg/L in the Effluent at each Mill, prior to discharging to the Off-site Wastewater System;

• b) If objective (a) is not satisfied, the Indirect Deposit Facility will contact the owner or operator of the Off-site Wastewater System to explore opportunities to work collaboratively, with the following objectives:

  • 1. Achieve and maintain an average annual BPA concentration in the Final Effluent at the Off-site Wastewater System below 1.75 μg/L. The Mill's relative contribution of BPA may also be taken into account in this objective; or

  • 2. Achieve and maintain an average annual BPA concentration in the Final Effluent at the Off-site Wastewater System, such that the Concentration of BPA in the Receiving environment is below 0.175 μg/L within 100 m downstream of the point of deposit of the Final Effluent of the Off-site Wastewater System. This will be based solely on the Off-site Wastewater System's contribution of BPA to the Receiving environment. The Mill's relative contribution of BPA to the Off-site Wastewater System may also be taken into account in this objective;

• c) If neither (a) nor (b) is satisfied, the Indirect Deposit Facility will develop and implement, to the greatest extent practicable, an approach to reduce the BPA concentration in the Final Effluent or the Concentration of BPA in the Receiving environment to as close to objective (a) or (b) as is technically and economically feasible.

Progress under the agreement (year 1)

The following summarizes the reports provided by the mills after the first year of the period of effect (2013-2017) of the agreement. There were 21 paper recycling mills from 13 companies that originally signed the agreement. During the first year of the agreement, one company ceased operations for its paper recycling mill and ended its participation under the agreement. One mill re-opened its recycling operations and is now part of the Agreement.

Report submission and participation of facilities

All participating companies with operating mills submitted reports for the first year of reporting under the agreement.

Performance under the agreement

Environment and Climate Change Canada reviewed the reports against the objectives of the agreement.

Meeting the objectives

• Fourteen paper recycling mills are meeting the objectives of the agreement as of the first year. These facilities will conduct a sampling program in the final year of the agreement and submit their final report four months prior to the expiry of the agreement.

Working towards the objectives

• Four paper recycling mills are working towards meeting the objectives of the agreement. Effluent will be sampled during the second year of the agreement, and the mills will submit a progress report for that year.
• One indirect deposit facility is working with the operator of the off-site wastewater system to sample final effluent to confirm whether it is meeting the performance objective. The mill will submit a progress report in the second year.
• One facility has re-opened its recycling operations and is working towards implementing the sampling program. The mill will submit a progress report in the second year.

Mill closures

• One mill ceased operations for its paper recycling mill and ended its participation under the agreement. No further reports are expected from this mill unless it resumes its paper recycling activities.
• One paper recycling mill could not report, as its de-inking plant was shut down. No reports are expected for this mill until it resumes its paper recycling activities.

Path forward for the second year

During the second year of the agreement (2014-2015), Environment  and Climate Change Canada will continue to work in collaboration with mills to ensure that performance objectives are achieved and maintained.

Progress under the agreement (year 2)

During the second year of the agreement, six recycling mills were required to provide annual reports as they are working towards meeting the objectives of the agreement. Of those six recycling mills, one recycling mill deposits its final effluent into the environment (direct deposit mill) and five recycling mills deposit their effluent to municipally-owned wastewater systems (indirect deposit facilities).

Report submission and participation of facilities

Five out of the six paper recycling mills submitted annual reports for the second year of reporting under the agreement.

Performance under the agreement

Environment and Climate Change Canada reviewed the reports against the objectives of the agreement.

Working towards the objectives

• Four recycling mills are working towards meeting the objectives of the agreement. These participating mills will continue to sample their effluent during the third year of the agreement and will submit a progress report for that year.
• Of the four facilities:
  • two indirect deposit facilities will continue to work with the municipally-owned wastewater systems' operators to see whether sampling can be conducted for the third year of the agreement
  • one indirect deposit facility is planning to install technologies that have potential to reduce BPA that could help meet the objectives of the agreement. These technologies are anticipated to be operational by summer 2016
  • one direct deposit mill will continue to monitor the BPA levels in the untreated and treated effluent.

Meeting the objectives

• One indirect deposit facility has stated that it is meeting the objectives of the agreement as of the second year through detailed calculations. Environment and Climate Change Canada has asked the indirect deposit facility for additional information to support their conclusion with BPA sampling data from the municipally-owned wastewater system.
• One indirect deposit facility has stated it met the objectives of the agreement through detailed calculations as of the first reporting year. Environment and Climate Change Canada has asked the indirect deposit facility to see whether they can support their conclusion with BPA sampling data from the municipally-owned wastewater system. Environment and Climate Change Canada is working with the indirect deposit facility to see whether this information can be obtained.

Agreement challenges

Indirect deposit facilities are facing challenges to sample final effluent from the municipally-owned wastewater systems. In many cases, indirect deposit facilities have made an effort to collaborate with the municipally-owned wastewater systems to acquire sampling results of BPA in order to verify they are meeting the objectives. Due to legal and confidential business considerations, some information has not been always made available to participating facilities. The municipally-owned wastewater systems are regulated by the Wastewater Systems Effluent Regulations.

Path forward for the third year

During the third year of the agreement (2015-2016), Environment Climate Change Canada will continue to work in collaboration with mills to ensure that performance objectives are achieved and maintained.

Progress under the agreement (year 3)

During the third year of the agreement, four recycling mills were required to provide annual reports as they are working towards meeting the objectives of the agreement. Of those four recycling mills, one deposits its final effluent into the environment (direct deposit mill) and the three others deposit their effluent to municipally-owned wastewater systems (indirect deposit facilities). In addition, two indirect deposit facilities who were meeting their objectives as of year 2, also submitted reports as Environment and Climate Change Canada had asked them for additional information to support their conclusions. 

Report submission and participation of facilities

Six mills submitted reports under year 3 of the agreement.

Performance under the agreement

Environment and Climate Change Canada reviewed the reports against the objectives of the agreement.

Working towards the objectives

• Two recycling mills are working towards meeting the objectives of the agreement. These participating mills will continue to sample their effluent during the final year of the agreement and will submit a final report four months prior to the expiry date of the agreement.
  • One facility will undertake more comprehensive sampling to identify the exact source of BPA as there is variability on the recycle waste supplied used.  
  • The other facility is planning to install technologies that have potential to reduce BPA that could help meet the objectives of the agreement. These technologies are anticipated to be operational by summer 2016.

Meeting the objectives

• As of year 3, two mills met the objectives of the agreement.
  • One indirect deposit facility stated that they are meeting the objectives of the agreement through detailed calculations but will do additional testing before and after on-site treatment plant to determine the BPA reduction achieved.
  • One direct deposit mill stated that it is meeting the objectives of the agreement through sampling of the final effluent.
• Prior to year 3, two mills were meeting the objectives of the agreement but submitted reports to provide additional information.
  • One indirect deposit facility continued to state that they are meeting the objectives of the agreement through detailed calculations.
  • One indirect deposit facility continued to state that they are meeting the objectives of the agreement through detailed calculations. Environment and Climate Change Canada had asked to obtain sampling data from the municipally-owned wastewater systems to support their conclusions, however the mill was unable to obtain this data.

Mill closures

• One mill ceased its paper recycling operations and maintained its participation under the agreement. No further reports are expected from this mill unless it resumes its paper recycling activities.

Agreement challenges

Indirect deposit facilities are facing challenges to sample final effluent from the municipally-owned wastewater systems. In many cases, indirect deposit facilities have made an effort to collaborate with the municipally-owned wastewater systems to acquire sampling results of BPA in order to verify they are meeting the objectives. Due to legal and confidential business considerations, some information has not been made available to participating facilities. The municipally-owned wastewater systems are regulated by the Wastewater Systems Effluent Regulations.

Path forward for the final year

During the fourth, and final, year of the agreement (2016-2017), Environment and Climate Change Canada will continue to work in collaboration with mills to ensure that performance objectives are achieved and maintained within the final year of the agreement. Final results will be assessed in order to determine if additional risk management actions are necessary to ensure the protection of the environment or the human health from paper recycling Bisphenol A releases.

Background information

In 2007 and 2008, Environment Canada and Health Canada completed an environmental and health assessment of bisphenol A (BPA), and determined that BPA is a toxic substance as defined under section 64 of the Canadian Environmental Protection Act, 1999.

The paper recycling sector was identified as a source of BPA released into the environment. BPA is used in certain paper products where it acts as a colour developer and is also present in varieties of inks. As such, BPA is present as a contaminant in waste paper, i.e. recycled paper, and may be released in effluents by some paper recycling mills.

On April 14, 2012, the Government of Canada published a Pollution Prevention (P2) Planning Notice to manage releases of BPA from industrial effluents in the Canada Gazette, Part I. The BPA P2 Planning Notice includes an exemption for persons with effluents containing BPA resulting exclusively from pulp and paper recycling. An analysis of effluents conducted in 2011 by Environment Canada and volunteer paper recycling mills showed that most mill effluents had BPA concentrations below the risk management objective in the BPA P2 Planning Notice, while a few were moderately above.

To manage this risk, Environment Canada developed a voluntary control instrument, in the form of an Environmental Performance agreement, with the paper recycling sector. As a result of the agreement, the paper recycling sector agreed to initiate action to minimize the risk of existing environmental impacts from their effluent releases of BPA, where necessary, to the greatest extent practicable. The performance objectives in the agreement will generally align with the overall objectives of the BPA P2 Planning Notice.

Public consultations on the proposed agreement took place between April 24, 2012, and May 24, 2012. No comments were received on the proposed agreement during this consultation period.

Contact us

Regulatory Innovation and Management Systems
Environment and Climate Change Canada
351 Blvd Saint-Joseph
Gatineau QC K1A 0H3

Email: ec.epa-epe.ec@canada.ca