January 22, 2013

MEMORANDUM

SUBJECT: Meeting Notes for the January 17, 2013 Conference Call with AF&PA and NCASI

FROM: Kelley Spence (EPA/OAR/OAQPS/SPPD/NRG)

TO: Docket EPA-HQ-OAR-2012-0640

This memorandum summarizes the conference call between the American Forest and Paper Association 

(AF&PA), National Council for Air and Stream Improvement (NCASI), member company 

representatives, and the U.S. Environmental Protection Agency (EPA) on January 17, 2013. The purpose 

of the meeting was to provide an update on the status of the Kraft Pulp Mills New Source Performance 

Standards (NSPS) review and discuss any outstanding issues.

Meeting Attendees:

Amy Artmeier - Kapstone Amy Marshall - URS Corp.

Rich Garber - Boise Inc. Annabeth Reitter - Domtar

Bill Heatley - Graphic Packaging Jeff Shumaker - International Paper

Tim Hunt - AF&PA Jim Taylor - MeadWestvaco

Steve List - NewPage Cliff Whitam - International Paper

John Pinkerton - NCASI

Vipin Varma - NCASI

Kelley Spence - EPA/SPPD

Katie Hanks - RTI

Tom Holloway - RTI

Discussion Points:

Discussions during the conference call dealt primarily with (1) potential regulatory options for opacity 

and associated allowances, (2) anomalies in the monitoring data for opacity and total reduced sulfur 

(TRS), (3) the overarching methodology used in the cost and impacts analyses of the NSPS regulatory 

options, (4) control of smelt dissolving tank (SDT) TRS emissions, and (5) Appendix F monitoring 

provisions.
2

Industry representatives noted that the NSPS PM emission limit is a continuous standard, and that opacity 

monitoring serves as an indicator but does not directly measure PM. They reiterated that opacity 

monitoring is an imprecise tool and that manual Method 9 opacity observations are only determined in 

5 percent increments of opacity. They suggested that a longer averaging time for opacity monitoring 

under the NSPS would require multiple compilations of opacity data (e.g., to meet a State 6-minute 

opacity limit or the subpart MM 6-minute opacity limit, and the revised NSPS opacity limit) and that a 

State may require a 6-minute averaging time even if the NSPS averaging time is lengthened to account for

startup and shutdown periods under the NSPS.

Industry representatives noted that one scenario in which modifications may occur is when the throughput 

is increased by upgrading a relatively modern emission unit in order to retire an aging emission unit. The 

industry representatives recommended that EPA’s cost analysis account for this possibility. 

Regarding TRS emissions from SDTs, the industry representatives noted that process parameters beyond 

the SDT scrubber water can affect SDT TRS emissions, referring to the findings in NCASI Technical 

Bulletin No. 895.

Industry representatives noted that Appendix F is meant for continuous emissions monitoring systems 

(CEMS) used and certified as compliance monitors, and that Appendix F was designed for higher 

concentrations (e.g., 200 part per million [ppm] limits for sulfur dioxide [SO2]) rather than lowconcentration standards like the 5- and 8-ppm kraft NSPS limits for TRS. They further noted that 

obtaining standardized cylinder calibration gases for TRS is an issue.

Action Items:

• Some industry representatives agreed to review their opacity and TRS monitoring data to 

determine the cause of what appear to be unexplained data spikes (e.g., whether these were highlevel calibration checks, or occurred for some other reason). EPA agreed to provide them with 

information on the mills and emission units involved and the times when the data spikes occurred.

• NCASI agreed to provide EPA with a copy of NCASI Technical Bulletin No. 895, which 

discusses the issues associated with control of SDT TRS emissions down to the current NSPS 

emission limit.

• NCASI also agreed to provide EPA with documentation relating to the history of Appendix F 

monitoring provisions for the Kraft Pulp Mills NSPS.