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" 

<MICHAEL.CURTIS@GAPAC.com>, "cbrandt2@rocktenn.com" <cbrandt2@rocktenn.com>, "sarah.hedrick@versopaper.com" 

<sarah.hedrick@versopaper.com>, "jpiotrowski@packagingcorp.com" <jpiotrowski@packagingcorp.com>, "gholton@packagingcorp.com" 

<gholton@packagingcorp.com>, James Taylor <james.taylor@mwv.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.org>

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

(352) 331-1745 | 

(904) 891-5021

vvarma@ncasi.org

February 15, 2012

TO: Robin Dunkins, Sector Policies 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 comments 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 and 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 operational 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 designing 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 of the same. This survey will attempt to provide relevant 
information on categories of “routine” releases that are operational or process driven and not SSM events, their 

frequency, duration, and other related information. 

Comprehensive industry responses 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