May 4, 2012

Thomas Holloway RTI International 3040 Cornwallis Road Research Triangle Park, NC 27709

Re: Packaging Corporation of America – Counce, TN Part II Information Collection Request (ICR) Revision RTI Mill #142, NEI Site ID 41552

Dear Mr. Holloway:

On behalf of the Packaging Corporation of Am erica (PCA), All4 Inc. (ALL4) is providing a revised Part II response to U.S. Environmental Protection Agency’s (U.S. EPA’s) February 22, 2011 Information Collection Request (ICR) for PC A’s Counce, Tennessee Pulp and Paper Mill (Mill). The Mill submitted its original respon se to the Part II ICR on June 6, 2011 and has revised its submittal in order to reflect the following:

• Updated acetaldehyde emission rates associated with the Mill’s two (2) paper machines (Emission Unit IDs G301 and G302). The re vised emission rat es are based upon the results of recent whitewater sampling perfo rmed by the Mill and Mill-specific emission factors developed by National Council for Air and Stream Improvement (NCASI).

• Updated acetaldehyde emission rates associated with the Mill’s wastewater treatment plant sources (Emission Unit IDs P10370 a nd P10371). Acetaldehyde emissions from the Mill’s primary settling basin have been deleted based upon clarification from NCASI that acetaldehyde would not be present in the Mill’s primary wastewater treatment stage since all acetaldehyde is present in the hard-p iped condensate which is sent to the aerated stabilization basin. Acetaldehyde emissions associated with the aerated stabilization basin have been updated based upon the results of more representative sampling performed during 2012.

• Updated physical exhaust characteristics of multiple emission release points in order to be consistent with the Mill’s original submittal and/or actual configuration during Calendar Year 2009.

• Updated latitude and longitude of the wastewater treatment plant.

• A revised Source Classification Code (SCC) for the No. 4 White Liquor/Green Liquor storage tank (Emission Unit ID T6061) which restores the Mill’s originally-reported value.

• Deleted rows corresponding to incorrect Emission Unit ID and Emission Release Point ID pairings for the #2 Heavy Black Liquor Storage Tank (Emission Unit ID T7223) and the 63% Black Liquor Storage Tank (Emission Unit ID T7227).Page 2 of 2

5/3/2012 Document1 • Added rows corresponding to corrected Emis sion Unit ID and Emission Release Point ID pairings for the #2 Heavy Black Liquor Storage Tank (Emission Unit ID T7223) and the 63% Black Liquor Storage Tank (Emission Unit ID T7227).

As ALL4’s Eric Swisher indicated to you duri ng a telephone conversation on April 25, 2012, numerous major equipment changes occurred at the Counce Mill during the 2011 calendar year. These changes, and the associated impact on th e emission rates of various compounds, will be addressed in future NEI updates. Therefore, the Counce Mill’s revised response continues to include information representative of operati ons and emissions during Calendar Year 2009.

Along with the revised Part II response, we are also providing a plot plan for the Mill in order to ensure that on-site receptors are not modeled by U.S. EPA.

PCA is submitting the enclosed detailed information with the expectation that it is to be used only for the purposes stated in the ICR and reserves th e right to object to any other use of the information by U.S. EPA or any other governmental entity, and the right to contest the use of the submitted information by any non- governmental entity for any purpose including, but not limited to, in any court of law.

If you have any questions or require additiona l information regarding this submittal, please contact me at 610-933-5246, extension 14, ( jegan@all4inc.com ) or Mr. Robin Ashe, Counce Mill Environmental Manager, at 731-689-1290 ( rashe@packagingcorp.com )

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Sincerely, All4 Inc.

John P. Egan Principal Consultant

Cc: Robin Ashe, PCA Richard Holland, PCA Eric Swisher, ALL4 Megan Uhler, ALL4