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Issue – PFAs

PPRC Position Paper on Per- and Polyfluorinated Alkyl Substances

 

Beneficial Use of Mill Residuals and Listing of PFOA and PFOS as CERCLA Hazardous Substances

The PPRC asks EPA to recognize and support the safe and beneficial use of mill residuals.

  • In the papermaking process, a large portion of mill residuals generated are composed of tree fiber (cellulose). PFOA and PFOS are widespread in the environment, and detection limits are extremely low, so they sometimes can be detected in residuals, albeit lower than the background levels found in common house dust.
  • These residuals are often used beneficially as soil amendments for agricultural or forest lands. They can reduce soil erosion, reduce the need for irrigation, increase soil nutrient-holding capacity, and reduce soil compaction, which improves plant growth.
  • The PPRC is concerned that the listing of PFOA and PFOS as hazardous substances under CERCLA (Comprehensive Environmental Response, Compensation and Liability Act), the Superfund law, could have the unintended outcome of impeding or preventing the safe and beneficial use of paper mill residuals as soil amendments.
  • The paper industry stopped using long-chain PFAS over a decade ago, so we are not a source of new loadings into the environment.
  • The PPRC would like EPA to recognize the safe and beneficial use of mill residuals as soil amendments. The CERCLA regulation should include a provision stating that the land application of paper mill residuals falls within the scope of the “normal application of fertilizer” exclusion from CERCLA whenever the concentrations of PFOA and PFOS in such residuals are comparable to the levels found in conventional fertilizers and soil conditioners. This is modeled on EPA’s position, since 1993, regarding land application of municipal biosolids as fertilizer or soil conditioner.
  • We strongly recommend that EPA exclude the beneficial and safe use of soil amendments from paper mills from the CERCLA listing. Specifically, CERCLA provides four exclusions for the use of a designated listing, including the normal application of fertilizer. Additionally, EPA interpreted the normal application of fertilizer exclusion to encompass application of biosolids as a fertilizer substitute or soil conditioner. Paper mill residuals are used as fertilizer substitutes and soil conditioners, and PFOA and PFOS incidentally contained in these residuals should be excluded from this rule.

National Administrative Positions

  • Information Technology Director
    David Cothren, USW Local 13-1149
    Graphic Packaging International
    Queen City, TX 75572
    David.Cothren@graphicpkg.com
  • Internal Communication Director
    Lloyd Allen, USW Local 9-983
    Graphic Packaging International
    Augusta, GA 30906
    Lloyd.Allen@graphicpkg.com
  • External Communication Director
    Doug Kinsey, IAM Local 414
    International Paper Company
    Rome, GA 30165
    James.Kinsey@ipaper.com
  • Scheduling Director
    Glenda Thompson, USW Local 9-425
    WestRock Company
    Roanoke Rapids, NC 27870
    Glenda@pprc.info

National Special Projects Coordinators at Large

  • Vince Geiser, NSC Recording Secretary
    IBEW Local 464
    WestRock Company
    Covington, VA 24426
    james.geiser@westrock.com
  • Andy Weeks, USW Local 9-978
    Packaging Corporation of America
    Counce, TN 38326
    weeksworks4@gmail.com,  aweekspprc@outlook.com
  • Matt Hall NSC Vice Chairman IBEW Local 464 
    WestRock Company
    Covington, VA 24426
    matt.hall@westrock.com 
  • Jason Etheridge, USW Local 9-0425
    WestRock Company
    Roanoke Rapids, NC 27870
    jasonetheridge78@yahoo.com

Executive Team

  • Clay Duke, Executive Director
    clay.duke@everpack.com | Pine Bluff, AR
  • David Wise, Chairman
    david.wise@westrock.com | Florence, SC
  • Matt Hall, Vice Chairman
    matt.hall@westrock.com | Covington, VA

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