Modernization of the Pulp and Paper Effluent Regulations – Updated detailed proposal for consultation - January 2024

Alternate format

List of abbreviations and acronyms

AOX

Adsorbable organic halides

BMS

Biological monitoring study

BOD

Biochemical oxygen demand

CES

Critical effect size

COD

Chemical oxygen demand

DO

Dissolved oxygen

ECCC

Environment and Climate Change Canada

EEM

Environmental Effects Monitoring

ENGOs

Environmental Non-Governmental Organizations

ISO

International Organization for Standardization

kg

Kilogram

L

Liter

mg

Milligram

N

Nitrogen

P

Phosphorus

pH

Potential hydrogen 

PNECs

Predicted no effect concentrations

PPER

Pulp and Paper Effluent Regulations

RPR

Reference production rate

SS

Suspended solids

T

Ton

TDS

Total dissolved solids

TOC

Total organic carbon

°C

Degree Celsius

1.0 Introduction

The 1992 Pulp and Paper Effluent Regulations (PPER) were put in place to streamline the existing 1971 regulations, improve the protection of fish and their habitat, and widen their application to all mills. The effluent limits were developed based on the performance of a group of Canadian mills that were considered good environmental performers in the late 1980s, and what was achievable through their secondary effluent treatment system at the time. Although portions of the PPER have been amended over the last 30 years, a complete review of the regulations has not been done.

In September 2017, Environment and Climate Change Canada (ECCC) shared the document entitled Proposed Modernization of the Pulp and Paper Effluent Regulations – Consultation Document with industry, environmental non-governmental organizations (ENGOs), Indigenous Peoples, provincial governments, and other interested parties. The document sought input on 4 broad themes:

• Scope of regulations
• Environmental Protection Measures
• PPER Administration
• Compliance and Administrative Requirements

In May 2019, ECCC published a second document entitled Proposed Modernization of the Pulp and Paper Effluent Regulations – Detailed Proposal for Consultation, which included the input received on the 2017 Proposed Modernization of the Pulp and Paper Effluent Regulations – Consultation Document. The Detailed Proposal for Consultation proposed the following changes to the PPER:

• widened the scope of the PPER to include facilities producing non-traditional products from wood, other plant material, pulp or a pulping process
• improved environmental protection by:
  • lowering effluent limits for currently regulated substances
  • adding effluent limits for additional substances, temperature and pH
• simplified administration of the PPER by:
  • Improving the efficacy and efficiency of Environmental Effects Monitoring (EEM) requirements by:
    • focusing biological monitoring requirements on the effects that are potentially of a higher risk to the environment
    • adding quarterly effluent characterization and water quality monitoring requirements
    • reducing the time spent by regulatees on investigation studies
    • requiring the submission of a study design by all mills
    • requiring the implementation of solutions identified in EEM studies
  • clarifying the process and effluent limits for idled, closing and closed mills
  • revising effluent limits for off-site landfills and expanding the scope to landfills owned by a third party
• modernized methods and schedule for monitoring and reporting by:
  • including requirements for effluent characterization and water quality monitoring
  • incorporating a pH stabilization protocol to be used in conjunction with the existing test method for acute lethality
  • updating requirements for analytical methods
  • updating schedule for requirements for compliance monitoring and reporting

The modernization of the PPER was initiated because:

• EEM studies submitted under the PPER have shown that the effluents from 70% of pulp and paper mills are impacting fish and/or fish habitat, and that the impacts at 55% of these mills pose a potentially higher risk to the environment
• the Canadian industry is diversifying the products made from wood and other plant materials to include non-traditional products such as nanocrystalline cellulose, lignin and hemicellulose
• what is achievable through process control and effluent treatment has improved since 1992 when the PPER were put in place, and best technologies and techniques are well documented

Following the publication of the Proposed Modernization of the Pulp and Paper Effluent Regulations – Detailed Proposal for Consultation in 2019, ECCC held 45 consultation sessions and received feedback from interested parties. ECCC has since considered all feedback received, and is proposing the following updates to the modernization proposal outlined in this document. ECCC has analyzed the current state of the Canadian pulp and paper sector using all available regulatory data collected under the PPER from 2012 to 2022 and data provided by our provincial partners under their respective regulatory framework. This document also provides additional information to clarify certain aspects of the proposal.

2.0 Updates to scope of regulations

2.1 Finished product definition

What was proposed

In 2019, ECCC proposed to change the definition of “Finished Product” to mean pulp, paper, cellulose-based and sugar-based products that has completed the production process at a mill.

What is being updated

ECCC is proposing to remove the sugar-based products from the proposed definition of finished products.

“Finished product” means pulp, paper and cellulose-based product that has completed the production process at a mill.

Mills producing products not captured by the finished product definition could apply for the proposed supplementary discharge allocation described in section 3.3.

ECCC took into consideration:

• clarifying the definition of finished products
• ensuring that the definition of finished products covers products that have an impact on mill effluent

3.0 Updates to environmental protection measures

3.1 Intensity factors for BOD, SS and COD for operating mills

What was proposed

In 2019, ECCC proposed to review intensity effluent factors for biochemical oxygen demand (BOD), suspended solids (SS), and add an intensity factor for chemical oxygen demand (COD). These effluent limits aimed to further improve environmental protection, with existing secondary treatment while not requiring tertiary treatment.

What is being updated

ECCC is proposing to update the proposed intensity factors for BOD, SS and COD to reflect what is achievable using a well operated, maintained and monitored secondary effluent treatment system. ECCC is proposing to update the limits for SS and COD for chemical mills, as well as the limits for SS and BOD for mechanical mills, shown in bold below.

ECCC took into consideration:

• the advice from expert consultants that a well operated, maintained and monitored secondary effluent treatment system should achieve an annual average concentration of 20 mg/L or below of BOD and 30 mg/L or below of SS
• that a safety factor of 50% should be added to the proposed limits to account for shutdowns and upsets
• that mills have reduced their water use in recent years

3.2 Authorization for high-brightness mechanical mills

What was proposed

In 2019, ECCC proposed the introduction of 3 mill process categories: chemical, mechanical and paper recycling. High-brightness mechanical mills were included under the mechanical mill category.

What is being updated

ECCC is proposing a new authorization for mechanical mills producing high-brightness pulp (>65% ISO) that meet certain criteria to have higher BOD and SS effluent limits.

Criteria to be eligible for this authorization include:

• not being able to meet the effluent limits for mechanical mills
• demonstrate with data that all measures to reduce effluent BOD and SS have been implemented
• demonstrate that the treatment system achieves a minimal reduction rate of 90% for BOD and SS and 60% for COD

The authorization would allow the lowest effluent standard that can be achieved by the mill, not exceeding the following intensity factors:

• Daily SS: 6.1 kg/t
• Monthly SS: 3.6 kg/t
• Daily BOD: 5.4 kg/t
• Monthly BOD: 3.3 kg/t
• Daily COD: 50 kg/t
• Monthly COD: 30 kg/t

The authorization would be valid for 5 years and mills could reapply as necessary.

ECCC took into consideration that:

• the production of high-brightness mechanical pulp results in a larger quantity of BOD than the typical mechanical mill
• requiring mills producing high-brightness mechanical pulp to meet the effluent limits for typical mechanical mills could require tertiary treatment

3.3 Adjustment to RPR for biotransforming mills

What was proposed

In 2019, ECCC proposed allowing mills producing bioproducts to apply for an interim reference production rate (RPR) when the production of bioproducts accounted for more than 25% of the total RPR and increased the organic loading to the effluent treatment system by more than 25%.

What is being updated

ECCC is proposing to allow mills producing bioproduct(s) to apply for a supplementary discharge allocation.

• The supplementary discharge allocation would be based on the BOD, COD and SS loading to the effluent treatment system resulting from the production of the bioproduct(s)
• To qualify:
  • mills would be required to meet applicable limits prior to application
  • the bioproduct(s) would have to result in a minimum 10% increase in BOD, COD and SS loading to the effluent treatment system above the loading from conventional finished products
• Mills would apply for the allocation once, and the allocation limit would be re-calculated annually based on the previous year’s daily loading data

• B_o is the average^{Footnote 1} daily BOD loading resulting from biotransformation production
• S_o is the average^{Footnote 1} daily SS loading resulting from biotransformation production
• C_o is the average^{Footnote 1} daily COD loading resulting from biotransformation production
• D is the number of days in the month
• For mills producing only bioproducts, they would have to submit:
  • plans outlining the production process
  • a description of steps taken to reduce BOD, SS and COD at the production stage
  • a description of the effluent treatment system and its capacity to meet the required limits
• For effluent containing one or more substances from Schedule 1 of the Canadian Environmental Protection Act as a result of biotransformation, the effluent would not be able to exceed the predicted no effect concentrations (PNECs) of those substances

ECCC took into consideration:

• comments indicating that the use of an interim RPR to accommodate biotransformation would present implementation challenges when regulating biotransformation processes, given the unknown nature of the deleterious substance loadings from these processes
• what is achievable using a well operated, maintained and monitored effluent treatment system

3.4 Concentration-based limits for phosphorus and nitrogen

What was proposed

In 2019, ECCC proposed to implement weekly maximum average, and monthly maximum average concentration-based limits for nitrogen and phosphorus.

What is being updated

ECCC is proposing to update the concentration-based limits for phosphorus to reflect what is achievable using a well operated, maintained and monitored secondary effluent treatment system, shown in bold below.

ECCC took into consideration that:

• proposed concentration-based limits should align with what is technically achievable, and account for treatment system variability

3.5 Temperature limit

What was proposed

In 2019, ECCC proposed to limit effluent temperature for all final effluents for all mills to a maximum daily temperature of 40°C and a maximum monthly average temperature of 35°C.

What is being updated

ECCC is proposing to limit effluent temperature for all final effluents to a maximum daily temperature of 45°C, with no requirement for a monthly temperature limit.

ECCC took into consideration:

• optimal biological treatment temperature for a well operated, maintained and monitored secondary effluent treatment system
• effluent temperature fluctuations
• the water quality temperature guidelines for various Canadian fish species

3.6 pH limit

What was proposed

In 2019, ECCC proposed to limit final effluent pH to within a range of 6.0 to 9.5 for freshwater receiving environments, and 6.5 to 9.2 for marine receiving environments.

What is being updated

ECCC is proposing to limit final effluent pH for all mill effluents in all receiving environments to the range of 6.0 to 9.5.

ECCC took into consideration:

• comments received during consultation that the marine range may not be achievable
• aligning with other modern Fisheries Act regulations such as the Metal and Diamond Mining Effluents Regulations

4.0 Updates to PPER administration

4.1 New provisions for closed and closing mills

What was proposed

In 2019, ECCC proposed to require a two-phase procedure for mills planning to close:

• Phase 1: Preparation for closure
• Phase 2: Closure of mill

What is being updated

Phase 1 Clarifications:

• Following the public announcement of closure, a mill will be given a period of time (e.g. 30 days) to notify ECCC, and an additional period of time (e.g. 45 days) to prepare and submit a closure plan that would be required before the process of closing the mill began
• ECCC will provide a list of eligible 'key pieces of equipment' for removal to inform the mill closure plan

ECCC took into consideration:

• comments that mills are often not able to disclose their intent to close until this information is first released to the public

4.2 New provisions for idled mills

What was proposed

In 2019, ECCC proposed to require the owner or operator of a mill to notify ECCC when the mill has stopped or is expected to stop production for 100 consecutive days or more. The mill would then enter idled mill status.

What is being updated

ECCC is proposing to extend the requirement for a mill to notify when it has stopped or is expected to stop production from 100 consecutive days to 6 consecutive months.

ECCC took into consideration:

• comments that some major mill upgrades or investments may take longer than 100 consecutive days to complete, and during an extended maintenance shutdown, a mill should not be considered idled as it would intend to restart production once the maintenance is complete  

4.3 Study designs for environmental effects monitoring (EEM)

What was proposed

In 2019, ECCC proposed that all mills submit study designs for biological monitoring and investigation studies.

What is being updated

ECCC is proposing that mills consider and include information and data provided by Indigenous people when developing the design of required studies. The intent of this update is to provide a mechanism to seek Indigenous communities’ perspective on the site-specific elements of EEM study design to help inform how and where these studies should be conducted to best assess potential effects of mills’ effluent on fish, fish habitat, and use of fish by humans.

Each mill would:

• inform and invite Indigenous peoples that use the waters in which the mill discharges effluents, to share any information or data they feel is relevant
• describe how the information provided was taken into account in the design of any required studies
• continue to take into account the information and data shared by Indigenous peoples in the design of any subsequent studies

ECCC took into consideration:

• comments indicating that some Indigenous groups would like to be directly involved in local EEM studies

4.4 Water quality monitoring and effluent characterization

What was proposed

In 2019, ECCC proposed that mills characterize their final effluent and conduct water quality monitoring studies. The list of substances to be measured as part of these 2 requirements was not specified.

What is being updated

ECCC is proposing to require the following list of substances/parameters be measured through effluent characterization and/or water quality monitoring.

Following is a list of substances/parameters measured through effluent characterization and water quality monitoring:

• Conductivity (freshwater/estuarine)
• Hardness (freshwater/estuarine)
• Alkalinity (freshwater/estuarine)
• Temperature
• pH (freshwater/estuarine)
• Total Organic Carbon (TOC)
• Total Dissolved Solids (TDS)
• Adsorbable organic halides^{Footnote 2}  (AOX)
• Hydrocarbons C10-C50
• Total Phenols
• Triarylmethane^{Footnote 3}
• Aluminum
• Arsenic
• Boron
• Cadmium
• Chromium
• Cobalt
• Copper
• Iron
• Lead
• Manganese
• Mercury^{Footnote 4}
• Nickel
• Selenium
• Silver
• Thallium
• Vanadium
• Zinc

Following is a list of substances/parameters measured through water quality monitoring only:

• Deleterious substances (TSS, COD, P, N)
• Dissolved oxygen (DO)
• Water depth
• Salinity (estuarine/marine)
• Turbidity

ECCC took into consideration:

• substances that are important to assess performance of pulp and paper effluent treatment
• substances used or generated by mills known to potentially impact fish and fish habitat

4.5 Investigation studies and implementation of solutions

What was proposed

In 2019, ECCC proposed one study period of 3 years to determine the cause of environmental effects of effluent and, when applicable, to identify solutions for those effects.

In addition, ECCC proposed that mills be required to implement the solutions they identified to mitigate the environmental effect(s) of their effluent, within a 3-year timeframe. After 3 years, studies to re-assess effects would be required.

What is being clarified

ECCC is providing more details to clarify the proposed investigation studies and implementation of solutions requirements.

Timelines

At the registration of the modernized PPER, biological monitoring study (BMS) requirements would be paused for all mills. All other EEM requirements would come into force at the registration of the regulations. The following requirements would restart when the new limits come into force:

1. 3 years after registration or
2. Up to 5 years after registration for mills with a transitional authorization^{Footnote 5}

After the new limits are in force, the first biological monitoring study report would be due in 3 years.

Results of 2 consecutive biological monitoring studies would determine the overall mill effect designation, which set the type and timing of subsequent studies. The first biological monitoring study results after the registration of the modernized PPER would be used in conjunction with the previous biological monitoring study results to reassess the overall mill effect designation.

The following list indicates the type and timing of the subsequent studies.

Type of study and timelines for study report submission set by designation

• Confirmed no effect designation: Biological monitoring study due 6 years after previous report was due
• Unconfirmed^{Footnote 6} effect designation: Biological monitoring study due 3 years after previous report was due
• Confirmed effect less than CES designation: Biological monitoring study due 3 years after previous report was due
• Confirmed effect equal or greater than CES, or without CES designation: Investigation Study due 3 years after previous report was due 

Investigation studies

Investigation studies would include a study to identify the causes of the effects and, where applicable, an identification of possible solutions to mitigate the effects. If there are multiple effects, mills would be required to identify causes for each effect and, where applicable, solutions for each effect.

Implementation of solutions

Starting when the investigation study reports are due, mills would be subject to the implementation of solution(s) requirements:

1.       3 months after investigation study reports are due, the Declaration of Solution Implementation Plan submission, a short document with a proposed ECCC template, would be required. It would include:

• A description of the proposed solutions
• The timeframe for implementing the solutions
• What effects are being addressed by the solutions
• How the solutions would help mitigate the effects

2.       The Declaration That Solutions Have Been Implemented would be submitted once the solution is fully implemented. It would include:

• A description of the implemented solutions
• The date when the solution was fully implemented

If the solution(s) has not been fully implemented within 3 years, an annual interim progress report would be required until the solution is fully implemented and the final declaration has been submitted. It would include:

• An update on the timeframe for implementing the solutions
• If applicable, any change to the description of the proposed solutions
• If applicable, any change on how the solutions would help mitigate the causes of the effects

Reassessment of effects

The biological monitoring studies assessing effects would resume 3 years after the investigation study reports are due, regardless of the completion of the implementation of solutions. The new biological monitoring study results would be used in conjunction with the previous biological monitoring study results to reassess the overall mill effect designation.

ECCC took into consideration:

• Comments received requesting more clarification on proposed investigation studies and implementation of solutions

Figure 1. Type of required studies and associated timelines for report submission

4.6 Requirements for off-site landfills

What was proposed

In 2019, ECCC proposed to include specific concentration-based limits for BOD, SS and COD in effluents (leachate) generated by all off-site landfills. ECCC also proposed to expand the scope of the PPER to regulate off-site landfills containing mill residues owned or operated by a third party whose purpose is to collect mill residues.

What is being updated

ECCC is proposing the following:

• mill residue would be defined as: bark, wood residue, pulp, paper and paperboard discards, ash from a combustion facility, sludge from process water treatment, de-inking sludge, lime sludge, green liquor dregs, residues from lime slaking and any other residue from the pulp or paper product manufacturing process that is not a hazardous material
• off-site landfills would be subject to the PPER for one year after the landfill stops accepting mill residue and then would be subject to the Fisheries Act
• the monitoring frequency for off-site landfills is presented in section 5.1 below
• the proposed off-site landfill requirements would apply to all off-site landfills discharging directly to the environment that treat only pulp and paper mill residue (not landfills accepting waste from multiple sources)
• remove the proposed requirements for a daily and weekly limit
• remove the proposed limits for temperature, total phosphorus, and total nitrogen

The proposed effluent limits for off-site landfills are now to include only the following:

ECCC took into consideration:

• comments questioning the need for nutrient limits in off-site landfills
• comments on the relevance of a temperature limit, since leachate temperature is a function of the ambient temperature
• comments to clarify what constitutes “mill residue”
• the intermittent nature of the discharge of leachate from pulp and paper mill off-site landfills
• the need for information on leachate characteristics to assess potential environmental risks

4.7 Clarification for unauthorized deposits

What was proposed

In 2019, ECCC proposed to use the term “unauthorized deposits of deleterious substances” instead of “deposits out of the normal course of events”.

ECCC also proposed to clarify sampling requirements for evaluating the effect of an unauthorized deposit, requiring that the sampling be done at the place where the unauthorized deposit occurred.

What is being updated

ECCC is proposing to:

• clarify that the sampling occurs at the same place as the unauthorized deposit, regardless of whether it consists of an outfall structure or any other place where the deposit can reach water frequented by fish
• add a requirement to subject the sample to a chemical oxygen demand (COD) test

ECCC took into consideration:

• comments requesting clarity on the requirements proposed in 2019

4.8 Site-specific requirements for Port Alberni mill

What was proposed

In 2019, ECCC proposed to lower and align the site-specific effluent loading limits for the Port Alberni mill with the limits proposed for all operating mills, and to repeal the specific requirement to measure dissolved oxygen.

What is being updated

ECCC proposes to remove all site-specific requirements for the Port Alberni mill. The mill would be subject to the general limits.

ECCC took into consideration:

• comments requesting the removal of site-specific requirements for the Port Alberni mill;
• the current site-specific limits for the mill would align with what is proposed for mechanical mills, making the current site-specific limits obsolete
• the current dissolved oxygen program would be repealed and replaced with water quality monitoring requirements that would apply to all mills

4.9 Authorization to treat other sources

What was proposed

In 2019, ECCC proposed to remove the authorization for a mill to exceed the maximum quantities of deleterious substances when it treats wastewater from other sources in addition to its own effluent.

What is being updated

ECCC proposes to keep this authorization with the following conditions:

• remove the requirement that a mill must be opened before 1971, allowing all mills to apply
• the authorization would only apply for treating municipal wastewater sources
• an allocation for COD would be added
• mills would no longer be required to take all applicable preventative measures at the production stage to reduce BOD, SS and lethality

• B_o the average daily BOD in the other sources wastewater before it is treated by the mill
• S_o the average daily SS in the other sources wastewater before it is treated by the mill
• C_o the average daily COD in the other sources wastewater before it is treated by the mill
• D is the number of days in the month
• B_o, S_o and C_o are calculated using loading data from the previous calendar year and expressed in kilograms

ECCC took into consideration:

• comments that some mills treat other sources such as municipal wastewater
• considering the newly proposed maximum effluent loading limits, this additional allocation may now be necessary to accommodate facilities treating municipal wastewater

5.0 Updates to compliance and administrative requirements

5.1 Effluent monitoring and testing schedule

What was proposed

In 2019, ECCC proposed a schedule for monitoring existing and new parameters, and tests for mill effluent.

What is being updated

ECCC proposes the following updates to the effluent monitoring and testing schedule:

• Increase the threshold for reducing COD monitoring from 20 mg/L to 100 mg/L.
• Increase the threshold for reducing Daphnia magna testing from 20 mg/L of COD to 100 mg/L and add that, in the previous quarter, the effluent did not fail the Daphnia magna test

Proposed monitoring requirements for off-site landfills

Parameter/test

Frequency – Weekly:

• BOD
• SS
• COD
• pH
• Effluent volume
• Total nitrogen
• Total phosphorus

Frequency – Quarterly: Acute lethality of rainbow trout

ECCC took into consideration:

• comments that the proposed COD criteria for reduced monitoring was not achievable for the average facility
• alignment of the COD reduced monitoring frequency to the monitoring frequency of BOD and SS
• clarifying the monitoring requirements for off-site landfills
• ensuring continued protection of Canadian fish and fish habitat from acutely lethal pulp and paper effluent

5.2 Coming into force

What was proposed

In 2019, ECCC had not proposed any schedule for when the amendments would come into force for facilities.

What is being updated

ECCC proposes that all amendments come into force on the day of registration of the revised PPER, except for the following items:

Amended limits

• The new amended limits would come into force 3 years following the registration of the revised PPER
• Eligible mills that cannot meet the new limits for one or more regulated parameters would have the option to apply for a transitional authorization within 12 months of registration of the revised PPER
• Mills would be eligible if the average loading of the previous 3 years before the registration of the revised PPER exceed the new limits and if they justify that more than 3 years is required to complete the necessary changes
• The application for a transitional authorization would require the following information:
  • Data of the previous 3 years to demonstrate eligibility for each parameter
  • Detailed project plans that would be used to meet the new limits, including specific timelines
• The transitional authorization would give an additional 2 years to meet the new limits for one or more regulated parameters. Mills would have to submit annual progress reports to demonstrate their progress to meet the new limits

Environmental Effects Monitoring (EEM)

• The first EEM biological monitoring study report would be due 3 years after the new limits come into force (i.e. by the sixth year after registration of the revised PPER)
• For mills with a transitional authorization, the first EEM biological monitoring study report would be due 3 years after the expiry of their transitional authorization

ECCC took into consideration:

• flexibility necessary for the planning and costing that may be required by facilities to come into compliance with newly proposed regulatory requirements
• the level of improvements required to come into compliance with the proposed regulation can vary between facilities
• minimizing the delay for the implementation of new proposals to improve environmental protection

5.3 Data reporting frequency

What was proposed

In 2019, ECCC proposed that reporting of monitoring results and production information be submitted to the Minister of the Environment on a quarterly basis within 45 days after the end of the quarter.

What is being updated

ECCC is proposing to maintain the current reporting frequency of monitoring results and production information, with monthly submissions required to the Minister of the Environment.

ECCC took into consideration:

• comments that monthly reporting would result in less administrative burden for mills, and align with provincial regulations

6.0 Next steps

What was proposed

In 2019, ECCC proposed the following key target dates for regulatory development:

What is being updated

ECCC proposes the following update for key target dates regarding this proposal:

7.0 Providing feedback

We would like to invite all interested parties to provide comments and feedback on the modernization of the Pulp and Paper Effluent Regulations. Please send your feedback in writing to:

Bernard Lupien, Manager, EEM and Forest Products
Forest Products and Fisheries Act Division – PPER Modernization
351, Boulevard Saint-Joseph - 19th Floor,
Gatineau QC  K1A 0H3
e-mail: refpppper@ec.gc.ca

Annex A – Summary of proposals

A.1 “Mill” definition

2019 proposal (section 2.0)

“Mill” means a facility that is used or designed to produce:

1. pulp from wood or from other plant material or paper products or
2. any product made directly from pulp or a pulping process

2024 proposal

No change from 2019 proposal

A.2 “Finished product” definition

2019 proposal (section 2.0)

“Finished Product” means pulp, paper, cellulose-based and sugar-based products that has completed the production process at a mill

2024 proposal (section 2.1)

Removal of sugar-based products from the definition:

“Finished product” means pulp, paper and cellulose-based product that has completed the production process at a mill

A.3 Mill categories

2019 proposal (section 3.0)

Introduction of 3 process categories:

• Chemical mills
• Mechanical mills
• Paper recycling and papermaking mills

2024 proposal

No change from 2019 proposal

A.4 Intensity factors for BOD, SS and COD for chemical mills

2019 proposal (section 3.0)

• Daily BOD: 4.25 kg/t
• Monthly BOD: 2.6 kg/t
• Daily SS: 6.25 kg/t
• Monthly SS: 3.75 kg/t
• Daily COD: 75 kg/t
• Monthly COD: 45 kg/t

2024 proposal (section 3.1)

• Daily BOD: 4.25 kg/t
• Monthly BOD: 2.6 kg/t
• Daily SS: 7.65 kg/t
• Monthly SS: 4.6 kg/t
• Daily COD: 80 kg/t
• Monthly COD: 48 kg/t

A.5 Intensity factors for BOD, SS and COD for mechanical mills

2019 proposal (section 3.0)

• Daily BOD: 1.25 kg/t
• Monthly BOD: 0.75 kg/t
• Daily SS: 2.5 kg/t
• Monthly SS: 1.5 kg/t
• Daily COD: 50 kg/t
• Monthly COD: 30 kg/t

2024 proposal (section 3.1)

• Daily BOD: 1.8 kg/t
• Monthly BOD: 1.1 kg/t
• Daily SS: 3.4 kg/t
• Monthly SS: 2.0 kg/t
• Daily COD: 50 kg/t
• Monthly COD: 30 kg/t

A.6 Intensity factors for BOD, SS and COD for paper recycling / papermaking mills

2019 proposal (section 3.0)

• Daily BOD: 1.25 kg/t
• Monthly BOD: 0.75 kg/t
• Daily SS: 2.5 kg/t
• Monthly SS: 1.5 kg/t
• Daily COD: 12.5 kg/t
• Monthly COD: 7.5 kg/t

2024 proposal (section 3.1)

No change from 2019 proposal

A.7 Multiple facilities discharging into one wastewater treatment system

2019 proposal (section 3.0)

Formulas were provided to calculate the maximum loadings in the case of multiple facilities of different process categories discharging into one wastewater treatment system

2024 proposal

No change from 2019 proposal

A.8 Authorization for high-brightness mechanical mills

2019 proposal

Not included in 2019 proposal

2024 proposal (section 3.2)

Authorization for mechanical mills producing high-brightness pulp (>65% ISO) meeting certain criteria for higher intensity factors up to:

• Daily SS: 6.1 kg/t
• Monthly SS: 3.6 kg/t
• Daily BOD: 5.4 kg/t
• Monthly BOD: 3.3 kg/t

A.9 Biotransforming mills

2019 proposal (section 3.0)

Introduction of an adjustment to the RPR available for mills producing bioproducts not defined as a “finished product”

2024 proposal (section 3.3)

Instead of the interim RPR, biotransforming mills could apply for a supplementary discharge allocation for BOD, SS and COD under certain conditions

A.10 Concentration-based limits for phosphorus

2019 proposal (section 3.0)

• Weekly max. average: 2.0 mg/L
• Monthly max. average: 1.5 mg/L

2024 proposal (section 3.4)

• Weekly max. average: 2.5 mg/L
• Monthly max. average: 2.0 mg/L

A.11 Concentration-based limits for nitrogen

2019 proposal (section 3.0)

• Weekly max. average: 20 mg/L
• Monthly max. average: 15 mg/L

2024 proposal (section 3.4)

No change from 2019 proposal

A.12 Temperature limit

2019 proposal (section 3.0)

• Monthly max. average: 35 °C
• Max. daily: 40 °C

2024 proposal (section 3.5)

• Monthly max. average: no limit
• Max. daily: 45 °C

A.13 pH limit

2019 proposal (section 3.0)

• Freshwater: 6.0 to 9.5
• Marine/estuary: 6.5 to 9.2

2024 proposal (section 3.6)

6.0 to 9.5 for all receiving environments

A.14 New provisions for closing and closed mills

2019 proposal (section 4.0)

Two phases for closing a mill and associated requirements:

• Phase 1: Preparation for closure, which includes requirements for the mill to notify ECCC when it intends to close, and provide a closure plan
• Phase 2: Closure of a mill, during which the conditions would remain the same as an operating mill, except for the limits, and after one year, the mill would no longer be subject to the PPER

2024 proposal (section 4.1)

Clarifications are provided on Phase 1:

• Following the public announcement of closure, a mill would be given a period of time to notify ECCC and to prepare and submit a closure plan
• ECCC would provide a list of eligible 'key pieces of equipment' for removal to inform the mill closure plan

A.15 New provisions for idled mills

2019 proposal (section 4.0)

• To enter idled mill status, a mill would notify ECCC when it has stopped or is expected to stop production for 100 consecutive days or more
• All conditions would remain the same as an operating mill, except for certain limits

2024 proposal (section 4.2)

To enter idled mill status, a mill would notify ECCC when it has stopped or is expected to stop production for 6 months or more

A.16 Effluent limits for idled and closed mills

2019 proposal (section 4.0)

• Daily max. BOD: 50 mg/L
• Monthly max. average BOD: 30 mg/L
• Daily max. SS: 50 mg/L
• Monthly max. average SS: 30 mg/L
• Daily max. COD: 300 mg/L
• Monthly max. average COD: 180 mg/L
• Other limits are the same as operating mills

2024 proposal

No change from 2019 proposal

A.17 Incorporation of critical effect size (CES) in EEM requirements

2019 proposal (section 4.0)

• Introduction of CES for all effect indicators except one
• An investigation of cause and solution study would be required only if an effect indicator ≥ CES, or if there is no CES

2024 proposal

No change from 2019 proposal

A.18 Study designs for EEM

2019 proposal (section 4.0)

• All mills would be required to submit study designs for biological monitoring and investigation studies
• Reduced requirements for mills with rapid effluent dilution

2024 proposal (section 4.3)

New requirement for mills to consider Indigenous perspectives in EEM study designs

A.19 Water quality monitoring and effluent characterization

2019 proposal (section 4.0)

• New EEM requirement to characterize mill effluent by analyzing a list of substances and parameters (list under development)
• New EEM requirement to conduct water quality monitoring studies in the exposure area of each effluent deposit and related reference areas by analyzing a list of substances and parameters (list under development)

2024 proposal (section 4.4)

List of substances/parameters to be analyzed is provided

A.20 Investigation studies and implementation of solutions

2019 proposal (section 4.0)

• Mills would have one study period of 3 years to determine the cause of effects of effluent and to identify solutions for those effects
• Mills would be required to implement identified solutions within a 3-year timeframe

2024 proposal (section 4.5)

New clarifications are provided, including:

• Mills could take more than 3 years to implement solutions, and in that case, annual interim progress reports would be required
• Biological monitoring studies would resume 3 years after investigation study reports, regardless of the completion of the implementation of solutions

Additional details on the steps and timelines for investigation studies and solution requirements are provided

A.21 Requirements for off-site landfills

2019 proposal (section 4.0)

• PPER would apply to off-site landfills owned or operated by a third-party whose purpose is to collect mill residue
• Daily max. BOD: 50 mg/L
• Monthly max. average BOD: 30 mg/L
• Daily max. SS: 50 mg/L
• Monthly max. average SS: 30 mg/L
• Daily max. COD: 300 mg/L
• Monthly max. average COD: 180 mg/L
• pH range for freshwater: 6.0 to 9.5
• pH range for marine/estuary: 6.5 to 9.2
• Weekly max. average phosphorus: 2 mg/L
• Monthly max. average phosphorus: 1.5 mg/L
• Weekly max. average nitrogen: 20 mg/L
• Monthly max. average nitrogen: 15 mg/L
• Daily max. temperature: 40°C
• Monthly max. average temperature: 35°C

2024 proposal (section 4.6)

• New definition for mill residue and clarification that requirements apply to off-site landfills that treat only pulp and paper mill residue
• No daily limit for BOD
• Monthly max. average BOD: 30 mg/L
• No daily limit for SS
• Monthly max. average SS: 30 mg/L
• No daily limit for COD
• Monthly max. average COD: 180 mg/L
• pH range of 6.0 to 9.5 for all receiving environments
• No limits for phosphorus
• No limits for nitrogen
• No limits for temperature

A.22 Clarification for unauthorized deposits

2019 proposal (section 4.0)

The sampling occurs at the same place as the unauthorized deposit

2024 proposal (section 4.7)

• The sampling occurs at the same place as the unauthorized deposit, regardless of whether it consists of an outfall structure or any other place where the deposit can reach water frequented by fish
• Sample subjected to a COD test

A.23 Site-specific requirements for Port Alberni mill

2019 proposal (section 4.0)

• Limits lowered and aligned with general limits
• Dissolved oxygen program repealed

2024 proposal (section 4.8)

• All site-specific requirements repealed
• Mill subject to general limits

A.24 Authorization to treat other sources

2019 proposal (section 4.0)

Removal of the authorization for a mill to exceed the maximum quantities of deleterious substances when it treats other sources of effluent in addition to its own

2024 proposal (section 4.9)

The authorization to treat other sources will be maintained with new conditions

A.25 Authorization for dissolving grade sulphite pulp

2019 proposal (section 4.0)

Removal of the authorization for dissolving grade sulphite pulp

2024 proposal

No change from 2019 proposal

A.26 Authorization to combine effluents

2019 proposal (section 4.0)

• New requirement to re-apply for authorization every 5 years
• Mills to reduce COD before the effluent is treated and demonstrate that treatment removes at least 60% of COD

2024 proposal

No change from 2019 proposal

A.27 Non-acute lethality requirements

2019 proposal (section 5.0)

New acceptable method for pH stabilization (RM 59) to be used in conjunction with the existing test method for acute lethality (RM 13)

2024 proposal

No change from 2019 proposal

A.28 Effluent monitoring and testing schedule

2019 proposal (section 5.0)

New schedule for monitoring existing and new parameters, as well as thresholds for reduced and increased testing frequency, including:

• Threshold to reduce COD monitoring included that COD was less than 20 mg/L in the previous quarter
• Threshold to reduce Daphnia magna testing included that COD was less than 20 mg/L in the previous quarter

2024 proposal (section 5.1)

Proposed effluent monitoring and testing schedule is maintained, with the following updates:

• Increase of the threshold for reducing COD monitoring from 20 mg/L to 100 mg/L in the previous quarter
• Increase of the threshold for reducing Daphnia magna testing from 20 mg/L of COD to 100 mg/L in the previous quarter
• New requirement that effluent did not fail the Daphnia magna test in the previous quarter for reduced Daphnia magna monitoring
• New monitoring frequency for off-site landfills

A.29 Coming into force

2019 proposal

Not included in 2019 proposal

2024 proposal (section 5.2)

Following publication of the revised PPER:

• Amended limits would come into force in 3 years
• Mills could obtain a transitional authorization for an additional 2 years to meet the limits
• EEM biological monitoring studies would be due 3 years after the limits, or after the end of a transitional authorization

A.30 Data reporting frequency

2019 proposal (section 5.0)

Reporting of monitoring results and production information would be submitted on a quarterly basis

2024 proposal (section 5.3)

The current reporting frequency of monitoring results and production on a monthly basis would be maintained

A.31 Public availability of information

2019 proposal (section 5.0)

Information related to deposit of deleterious substances and EEM study results would be made publicly available and accessible

2024 proposal

No change from 2019 proposal