Recommendations of Working Group I concerning: Categorization of Industry Objectives

1. Recommendations of Working Group I concerning: Categorization of Industry Objectives Proposed Norms Proposed Sction Points PROPOSED “CHARTER ON WATER RECYCLING & POLLUTION PREVENTION IN PULP & PAPER INDUSTRY”

2. Categories of Indian Pulp & Paper Mills Proposed Categorization under this Revised Charter A1: Wood Based Pulp & Paper Mills producing bleached grades of chemical pulps, papers, paperboards & newsprint A2: Wood Based Pulp & Paper Mills producing unbleached grades of chemical pulps, papers and paperboards B1: Agro Based Pulp & Paper Mills producing bleached grades of chemical pulps, papers, paperboards & newsprint B2: Agro Based Pulp & Paper Mills producing unbleached grades of papers and paperboards C1: RCF and Market Pulp Based Paper Mills producing bleached grades of papers, paperboards & newsprint C2: RCF and Market Pulp Based Paper Mills producing unbleached grades of papers and paperboards Mills that attract classification in more than one category will be deemed to be in the “highest” among those categories. For example, a mill that is both wood and agro based (A1 & B1) will be classified as A1.

3. Objectives of the Charter All time Compliance with Environmental Norms This compliance shall be determined by long-term performance criteria like a 30-day moving average. Besides, allowable “Exceedances” shall be permissible on the basis of an agreed: % of operating time that such exceedances occur number of such exceedances per year/month % by which each such exceedance can deviate from norm Start-up/shut-down periods, normal boiler soot-blowing sequences and exceptional circumstances (to be enumerated) should not be considered while determining all-time compliance. Water consumption, effluent generation and emission limits shall be reckoned per tonne of “product” and not just “paper”. Besides paper, paperboard and newsprint, “product” shall include air dry tonnes of surplus pulp produced for short term storage (as wet-lap) or for sale.

4. Objectives of the Charter Improved Environmental Performance beyond Regulatory Norms This will essentially be a voluntary effort by the mills with performance targets proposed in advance, properly documented, and then validated by third parties. Achievement of such improved performance should receive appropriate recognition from CPCB/SPCBs and, in particular, should qualify for fast-track environmental clearances.

5. Objectives of the Charter Increased Productivity Freedom to install minimum impact technology will not only improve better environmental performance but also ensure stakeholder relations, increased productivity, cost savings and competitive market advantages. Constrained by the General and Special Conditions imposed by Environmental Clearances and Operating Permits, increased productivity could only amount to achieving the same production levels with lesser specific consumption of any or all of the resources involved in mill operations.

6. Objectives of the Charter • Compliance with International Commitments Compliance with international commitments in the context of environmental regulation of the paper industry will be meaningful if effluent discharge standards are load based instead of the existing concentration based ones. Making ECF bleaching mandatory would then be the only residual issue. Internationally, ECF bleaching is mandatory (BAT standard) and the only wood pulp bleaching technology to ensure safe AOx levels. Well-managed agro-pulp bleaching could still hold AOx levels to that of wood based ECF pulp bleaching without eliminating elemental chlorine. India’s compliance, in an agro pulping context, should be decided only on prescribed AOx levels. Elimination of elemental chlorine in existing Agro mills, or wood pulp mills of capacity <200 tpd, could be either a voluntary initiative or a condition for expansion of capacity or establishment of new capacities.

7. Fresh Water Consumption Norms in the Revised Charter (m3/t of product) # Tentative norms for Mills manufacturing specialty paper. Wide variation can exist, determined by grades (Hygiene grades/FDA grades/coloured grades, etc). Case-to-case consideration, based on product portfolio, would be required

8. Proposed Effluent Generation Norms in the Revised Charter (m3/t of product) # Tentative norms for Mills manufacturing specialty paper. Wide variation can exist, determined by grades (Hygiene grades/FDA grades/coloured grades, etc). Case-to-case consideration, based on product portfolio, would be required

9. Proposed Norms for Treated Effluent Quality for Integrated Pulp & Paper Mills manufacturing Chemical pulp Deviation from the norms for a specified % of the time in a year (say, 5%) should be considered within compliance.

10. Proposed Norms for Treated Effluent Quality for RCF and Market Pulp Based Pulp & Paper Mills Deviation from the norms for a specified % of the time in a year (say, 5%) should be considered within compliance.

11. Water Consumption & Effluent Generation Norms w.r.t Irrigation Schemes • Mills that discharge all their treated effluents on land for irrigation through dedicated effluent distribution schemes have an obligation to dependent farmers. These mills will be entitled to a relaxation of water consumption and effluent generation norms, Such relaxation, to the extent required, shall be accorded to eligible mills through a validation protocol to be notified by CPCB. • Such relaxation shall, however, be subject to the following conditions: • The dedicated irrigation scheme should have been in practice for a period of not less than five (5) years • The scheme should have, during this 5-year period, used all the effluent generated by the mill. • The effluent ‘load’ generated by the mill shall not be in excess of the norms. In effect, any relaxation in volumetric terms would entail a corresponding reduction in the concentration terms.

12. Proposed Norms for Odorous Emissions * Recommended by the Expert Committee on “Odour Polluton & its Control” constituted by CPCB; Guidelines published May 2008. These emissions shall be measured twice a year, as an odour control assessment protocol, to identify and evaluate point source emissions of odorous gases. Mills that operate with a Soda Process and with mill-wide sulphur-free operations, shall be exempt from this section of the Charter.

13. Proposed Stack Emission Norms NOX & SOx has already been notified under National Ambient Air Quality Standards. H2S norms will be applicable only to stacks attached to Chemical Recovery Boilers. Deviation from the norms for a specified % of the time (say, 5%) should be considered within compliance.

14. Conditions Necessary for Timely Compliance with the Charter No regulatory impediments. Any process modification, construction activity or any other action required to be undertaken by a mill in pursuit of the objectives of this Charter should receive necessary environmental clearances from SPCBs with utmost speed. CPCB/MoEF should set in place a fast-track, single-window clearance mechanism. Zero Liquid Discharge (ZLD) Conditions not to apply. SPCBs should be advised not to prescribe a ZLD condition in any of their operating permits during the currency of this Charter. If mills were to be capable of achieving ZLD, there would be no need for this Charter. SPCBs’ active support, and understanding, The transition from Short Term compliance levels to the next two levels could entail disruptions in mill operations leading to temporary aberrations in quality of treated effluents.

15. Charter for Water Recycling & Pollution Prevention in Pulp & Paper Industries Action Points These action points are indicative of the systems, equipment, processes and practices that are considered essential to achievement of the objectives of this Charter. Actual actions required by individual mills may differ on account of their unique circumstances like ‘scale of operations’, ‘equipment & syatem configuration’, ‘product portfolio', 'raw material mix’, etc.

16. Category A1: Wood based - Bleached Grades of Pulps, Papers, Paperboards & Newsprint

19. Category A2: Wood based - Unbleached Grades of Pulps, Papers and Paperboards

22. Category B1: Agro based - Bleached grades of Pulps, Papers, Paperboards & Newsprint

25. Category B1: Agro based - Unbleached grades of Pulps, Papers, Paperboards & Newsprint

28. Category C1: RCF and Market Pulp based - Bleached grades of Pulps, Papers, Paperboards & Newsprint

31. Category C2: RCF and Market Pulp based - Unbleached grades of Pulps, Papers, Paperboards & Newsprint

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