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 Standards for 

Hazardous Air Pollutants from 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 owns 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 changes 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 proposed here 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 emissions 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 assumed volatile 

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 assumptions behind our initial emission estimate. 

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

additional Primary Clarifier inlet grab samples for 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 Clarifier 

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 estimating 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 

wastewater 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 similar to the one at the Longview Mill, volatile 

emissions of chloroform are predicted to be 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 typical 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 2012; 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 Cooling 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 Clarifier (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 by phone at (360)578-4445 or by email at greg.bean@weyerhaeuser.com.

Sincerely,

Timothy Haynes

Vice President, Manufacturing

Attachments:

NCASI SARA Handbook, Appendix 4.A

NCASI SARA Handbook, Chemical-Specific Information for Chloroform, March 2012

cc: ppsurvey@rti.org

Schrock.Bill@epa.gov

Bradfield.john@epa.gov

Greg Bean, Weyerhaeuser

Steve Woock, Weyerhaeuser