ARCC Unions, Companies Support "Option A" for EPA's Cluster Rule

A top issue facing the U.S. pulp and paper industry is EPA's Cluster Rule. First released for public comment in 1994, the Cluster Rule will regulate air and water discharges from industry mills. Originally slated for release in 1995, the rule's final implementation has been delayed by the enormous volume of public comment - ranging from impassioned citizen letters to detailed technical critiques.

When EPA first announced that it would "cluster" air and water regulations for the industry, virtually every stakeholder applauded. But the rule as first proposed drew cries of dismay from labor and companies. It would have forced companies nationwide to install process changes running as high as $300-$400 million at any one site. Resulting job losses could have reached 40,000.

Worker representatives worked overtime to alert EPA officials and elected representatives to the potential human cost of implementing the rule as first proposed. Scientists and engineers from industry performed exacting technical analysis of the entire EPA proposal. Meanwhile, environmentalists pushed to make the rule even tighter. EPA, to its credit, took the public comments seriously, and after two years began releasing parts of the final rule for additional public comment.

In mid-1996, two parts of the air regulations - "MACT I and MACT III" (MACT means "Maximum Available Control Technology") were released for public comment. In Summer 1996, EPA released the part that covers water emissions from bleached kraft and soda mills and bleached papergrade sulfite mills. This portion is of greatest concern to the workers and companies.

This portion contains two possible options for regulating water discharges from bleached kraft and soda mills. One, called "Option A," would require complete conversion of the bleaching process in every affected U.S. mill from chlorine gas to chlorine dioxide, and would provide incentives for mills to go beyond the mandated targets. "Option B" would require the same conversion to chlorine dioxide, but would also require the addition of an oxygen delignification or extended delignification step in the bleaching process. The estimated cost of this additional step is as high as $1 billion.

Again, union members and others took their message to EPA and Congress. Many representatives and senators responded by contacting EPA to emphasize the human impact, and to urge selection of Option A. Hundreds of individual comments were sent. ARCC would like to say "Thank You" on behalf of the Paperworkers to everyone who registered comments.

Right now, EPA is poised to finish writing the final rules for MACT I, MACT III, and the water regulations for bleached mills. The next step is a review by the federal Office of Management and Budget, after which these portions of the rule will be put into effect.

Other segments of the Cluster Rule will probably be finalized piece-by-piece by EPA during 1997. Comments and action by all concerned parties will be needed because, in each case, the new comment period will be the last opportunity to influence each segment of the rule before it is published as final regulation.