May 3 , 2012

EPA Docket Center (EPA/DC)

Environmental Protection Agency

Mailcode 2822T 1200 Pennsylvania Ave., NW Washington, DC 20460

VIA E

- MAIL: a

- and

- r

- docket@epamail.epa.gov

Subject: Attention Docket ID No. EPA

- HQ

- OAR

- 2007 0544, National Emission Standard s for

Hazardous Air Pollutants f rom the Pulp and Paper Industry (76 Federal Register 881328, December 27, 2011)

Updated Chloroform Emissions Information Weyerhaeuser Longview Mill, NEI ID 42341A

To Whom it May Concern :

Weyerhaeuser NR Company ow ns and operates a Pulp and Paper Mill in Longview, Washington that is subject to the Pulp and Paper NESHAP regulations. The site, also known as the Longview Mill, appreciates this opportunity to provide comments to the EPA regarding the proposed rule chang es for the Pulp and Paper NESHAP as a result of the EPA’s Risk and Technology Review (RTR).

The purpose of these comments is to specifically provide updated information to the Agency in the evaluation of Risk from the Longview Mill. In the preamble to the rule, EPA states “we conclude that the current standard, before the amendments propose d her e are put in place, protects public health with an ample margin of safety.” (See 76 Fed. Reg. 81344). Weyerhaeuser agrees with EPA’s conclusion, and the updated information provided here will further reduce the risk assessment for the Longview Mill as documented by the Agency in the Docket.

Chloroform

In the NEI (Part II of the Pulp and Paper ICR), the Longview Mill reported estimated 2009 annual

chloroform em issions from the Primary Clarifier of 12.87 tons per year. This estimate was based on what was the most recent Primary Clarifier inlet concentration data ( 240 μg/L

, from a single effluent sample taken in 2006) and a simple effluent partitioning model used since 2000 that assum ed v olatile

losses of 82.7% of the chloroform entering the wastewater treatment system

. Given EPA’s short

- term risk assessment showing relatively high risk for chloroform emissions from the Primary Clarifier, we

have re

- evaluated the a ssumptions behind our initial emission estimate.

To determine whether the 2006 primary clarifier influent data was representative, we collected six

a dditional Primary Clarifier inlet grab samples f or chloroform analysis, during normal mill operations on six different operating days in February and March, 2012

. As shown below, the

chloroform concentrations of these samples ranged from 37

- 55 μg/L, with a mean concentration of 47.3 μg/L, less than 20% of the concentration of the 2006 sample.

### Weyerhaeuser Longview Mill, NEI ID 42341A

Updated Chloroform Emissions Information Page 2

Primary Cla rifier

Inlet Grab Sample

Date Chloroform

Concentration, μg/L

2/29/2012 55

3/1/2012 41

3/2/2012 54

3/14/2012 55

3/15/2012 42

3/16/2012 37

Mean 47.3

We do not have sufficient information to confidently explain the difference in concentration between these recent samples and the single sample from 2006 . However, it is our view that the mean concentration of the recent samples represents the best available information

, reflective of our current pulping, bleaching and papermaking processes, for estimat ing wastewater chloroform

emissions for risk assessment purposes

.

We also reviewed current NCASI guidance for SARA 313 reporting

, to determine if more appropriate effluent partitioning models were available for estimating chloroform emissions from the

w astewater treatment plant. We found that NCASI has updated their effluent chloroform partitioning estimates for primary clarifiers and activated sludge treatment systems, using EPA’s WATER9

model.

For an “example” primary clarifier with a design simila r to the one at the Longview Mill, volatile emissions of chloroform are predicted to b e 9.8% of the inlet chloroform loading (NCASI SARA Handbook, Appendix 4.A, Table 6: WATER9 Estimates for Fugitive Emissions from Example Primary Clarifier).

For typica l Activated Sludge Treatment System similar to that used at the Longview Mill, volatile emissions of chloroform are predicted to be 33.5% of the inlet chloroform loading ( NCASI SARA Handbook, Chemical

- Specific Information for Chloroform, updated March 201 2; Table 6: WWTP Partitioning of Chloroform Using Typical WATER9 Predictions).

For the Effluent Cooling Towers, volatile emissions of chloroform are estimated to be 89% of the incoming chloroform load to the Cooling Towers, based on a Longview Mill Cool ing Tower mass balance evaluation conducted in 1999

- 2000.

Using the updated Primary Clarifier influent concentration data and the updated WWTP chloroform partitioning models, we have updated our 2009 chloroform emissions estimates as follows: Primary Cl arifier (ET

- Pri): 0.30 tons/year, vs. 12.87 tons/year initial estimate

. East and West Cooling Towers (ET

- CTE and ET

- CTW): 0.23 tons/year each, vs. 0.546 tons/year initial estimate

. Activated Sludge/Aerated Stabilization Tanks #1, #2 and #3 (ETAST1, ETAST2 and ETAST3): 0.15 tons/year, 0.31 tons/year and 0.31 tons/year, respectively, vs. no chloroform emissions initially estimated for these emission points.

### Weyerhaeuser Longview Mill, NEI ID 42341A

Updated Chloroform Emissions Information Page 3

If you have any questions upon receipt of this package, please contact Mr. Greg Bean of Weyerhaeuser b y phone at (360)578

- 4445 or by email at greg.bean@weyerhae u ser.com

.

Sincerely,

Timothy Haynes Vice President, Manufacturing

Attachments: NCASI SARA Handbook, Appendix 4.A NCASI SARA Handbook, Chemical

- Specific Information for Chloroform, March 2012

c c: ppsurvey@rti.org Schrock.Bill@epa.gov Bradfield.john@epa.gov Greg Bean, Weyerhaeuser Steve Woock, Weyerhaeuser