From: "Varma, Vipin" < vvarma@NCASI.org >

To: Robin Dunkins/RTP/USEPA/US@EPA, John Bradfield/RTP/USEPA/US@EPA, Bill Schrock/RTP/USEPA/US@EPA, Peter Tsirigotis/RTP/USEPA/US@EPA Cc: Jeff Shumaker < jeffrey.shumaker@ipaper.com >, " RichGarber@BoiseInc.com " < RichGarber@BoiseInc.com >, " Robert.Kaufmann@kochps.com " < Robert.Kaufmann@kochps.com >, " MICHAEL.CURTIS@GAPAC.com " < MI CHAEL.CURTIS@GAPAC.com >, " cbrandt2@rocktenn.com " < cbrandt2@rocktenn.com >, " sarah.hedrick@versopaper.com " < sarah.hedrick@versopaper.com >, " jpiotrowski@packagingcorp.com " < jp iotrowski@packagingcorp.com >, " gholton@packagingcorp.com " < gholton@packagingcorp.com >, James Taylor < ja mes.taylor@mw

v.com >, " guy.martin@domtar.com " < guy.martin@domtar.com >, "Woock, Steve (steve.woock@weyerhaeuser.com )" < steve.woock@weyerhaeuser.com >, "Reitter, Annabeth" < Annabeth.Reitter@newpagecorp.com >, " Tim_Hunt@afandpa.org " < Tim_Hunt@afandpa.org >, "'Noe, Paul' ( Paul_Noe@afandpa.org )" < Paul_Noe@afandpa.org >, "Pinkerton, John" < JPinkerton@NCASI.o rg > Date: 02/15/2012 09:40 AM Subject: Targeted industry survey pertaining to excess emissions and request to extend timeline for comments 

# ncasi

**NATIONAL COUNCIL FOR AIR AND STREAM IMPROVEMENT, INC. P.O. Box 13318, Research Triangle**  **Park, NC 27709 -**  **3318 Phone (919) 941**  **- 6400 |**  **Fax (919) 941 -**  **6401 Vipin K. Varma,**  **PhD (**  **3 52) 331**  **- 1745 |**  **(904) 891 -**  **5021 vvarma@ncasi.org**  

### February 15, 2012 TO: Robin Dunkins, Sector Poli cies and Programs Division, OAQPS FROM: Vipin Varma and John Pinkerton Dear Ms Robin Dunkins, In the December 27, 2011 Federal Register Residual Risk and Technology Review proposal for the Pulp and Paper industry, EPA requested comme nts on whether to remove or modify excess emissions allowances for Low Volume High Concentration, High Volume Low Concentration, and steam strippers (see FR 76 p. 81346). Specifically, EPA has requested information on the following: 1. Circumstances for excess emissions and whether they qualify as Start

- up, Shutdown and Malfunction (SSM) events (and if not, why not) 2. General categorization of excess emissions events (and causes) 3. Differentiating between routine excess emissions events an d SSM events 4. Frequency and duration of occurrences and, if available, quantities of emissions 5. Compilation of prevalent monitoring procedures and work practices, and 6. Whether excess emission periods are needed for technology or operat ional reasons The assembly of this kind of information, in the form of substantive comments reflecting industry

- wide practices, is a complex endeavor and cannot be accomplished by February 27

– the end of the comment period. NCASI is currently designin g a targeted survey, working with AF&PA and the industry, that attempts to address EPA’s questions and information needs. NCASI has a strong track record of conducting surveys around complex technical and regulatory issues and providing thorough reviews o f the same. This survey will attempt to provide relevantinformation on categories of “routine” releases that are operational or process driven and not SSM events, their

frequency, duration, and other related information. Comprehensive industry respo nses and subsequent assimilation of all data is time consuming , especially considering other ongoing projects and research. Therefore, we request that EPA extend the timeline for comments pertaining to excess emission allowances by four months until June 27th. This extension will enable a more comprehensive and deliberate data collection process and more substantive and responsive comments. The idea of undertaking such a survey has been broached with member companies and they are willing to respond to this survey later this spring. I have copied some of our member companies on this e

- mail with whom we will be working to acquire this additional information. Please do not hesitate to contact me if you have any questions. Best Regards Vipin Vipin K . Varma, PhD NCASI Inc. (352) 331 1745 x 260 (904) 891 5021 vvarma@ncasi.org