1111 Nineteenth Street, NW, Suite 800 ▪ Washington, DC 20036 ▪ 202 463-2700 Fax: 202 463-2785 ▪ www.afandpa.org February 3, 2012 Via Electronic Mail

Robin Dunkins Office of Air Quality Planning and Standards U.S. Environmental Protection Agency 109 T.W. Alexander Drive Research Triangle Park, NC 27709 Email: dunkins.robin@epa.gov

Re: Supplementary Material fo r Request for Extension of the Comment Period on Proposed National Emission Standards for Hazardous Air Pollutants from the Pulp and Paper Industry, Docket ID Number EPA-HQ-OAR-2007-0544

Dear Ms. Dunkins:

On January 20, 2012, we sent Gina McCarthy a request for an extension to the comment period that included a reques t to “decouple” the excess emission allowance issue from the base Residual Risk and Technology Review proposal since it is totally separate from the Agency’s 112(f) and 112(d)(6) review responsibilities. This letter provides more information to support the need for at least 120 days to provide meaningful responses to the ques tions posed in the December 23, 2011 Federal Register notice.

As you know, the industry has not been interacting with OAQPS staff on these excess emission allowance issu es the way we have on other issues addressed in the proposed rule. So we have not provided EPA with information on these issues recently, as we have for other issues in the proposed rule, and we are basically starting from scratch in terms of our own analysis.

In the Federal Register EPA asks for co mment on the followi ng aspects of the excess emission allowances: 1. The circumstances where a llowances have been relied upon

2. Whether those circumstances incl ude periods of start-up, shutdown or malfunction and if not, why 3. Information on the frequency of use 4. And more specifically: a) Typical reasons for the releases including a description of the

nature and causeMs. Dunkins February 3, 2012 Page 2

b) Frequency, c) Duration, d) Estimated amount of emissions, e) Any work practices employed to reduce emission, and f) Any procedures used to monitor releases. 5. Necessity of releases for technology reasons (equipment or operational)

6. The time needed to switch between routine controls and available backup controls and whether venting is necessary during these times.

EPA goes on to ask for feedback on opti ons EPA is considering including:

 Narrowing the provisions (suc h as when they would apply)

 Setting an alternative num erical emission limit

 Setting a work practice under section 112(h) or

 Lengthening the averaging period of the current standard to accommodate the periods of excess emissions

AF&PA and its member companies do not currently have any of the information on occurrences and frequency in a readily available format for compilation and analysis. It will take at least th ree months to gather the information in a form that would be useful to assess. T he first step is to get relevant information from the member companies including current emission repor ts and/or the details of why and when these allowances are used. There are many different circumstances and approaches companies take and we would want to be sure we had the breadth of information to make informed comments to EPA. Mills are busy preparing for other rulemaking comments (Boiler MACT) includi ng the RTR proposal itself as well as other reporting responsibilitie s that occur during the fi rst quarter of the year. Therefore, AF&PA ca nnot expect information back fr om member companies for at least eight weeks and more likely ten weeks. Then, as with any data collection effort, there needs to be extensive follow- up to ensure the data is understood and interpreted properly. For example, underst anding the reasons for these events and how they are different from malfunction situations. EPA has had a similar experiences reviewing and interpreting the data from the Informa tion Collect Request (ICR) to support the rulemaking.

Once data is collected, AF&PA will require another six to eight weeks to then compile the information, conduct detailed an alyses and put the data into a form that appropriately characterizes what we k now about frequency, duration, cause and amount of emissions. For a trade associ ation, like EPA’s rulemaking workgroup process, this requires numerous calls and ev en face-to-face meetings to discuss the information, determine if any conclusion s that can be drawn from it, and preparing the conclusions for submittal to EPA.Ms. Dunkins February 3, 2012 Page 3

The efforts to gather the information on cu rrent practices is only half the task being requested in the preambl e of the proposal. The questions on alternatives to the current excess emissi on allowances will require an even more involved enterprise for AF&PA and its me mbers. To comment constr uctively we need to get far enough through the data collection phase, wh ich will take a couple of months, to have the information to make informed a ssessments. Since t he current use of emission allowances is working fine in our view, the industry has never studied the merits of a work practice or numeric standard or the potentia l compliance costs and other impacts of any alternatives. This wi ll take significant time, easily another two months, to sort through the nuances of how the options might work in the day-to-day circumstances of each mill. Developing t he documentation for any final conclusions in comments will take the same sort of back and forth to make sure we have well thought through comments from a technical, policy, legal and economic perspective involving both members and consultant s. Again, these are not the only responsibilities our member co mpanies have so it can take a week or two even to get everyone together especially when some of the experts on use of excess emission allowances are running oper ations at the mills.

These steps will easily take four months to complete and possibly more so a “decoupling” of the e xcess emission allowance issues is justified to give until June 27, 2012 to provide additional feedback on the questions and issues raised in the December 27, 2011 Federal Register not ice. Please note that, by requesting additional time and collecting and submitti ng additional information, AF&PA is not conceding that it could be appropriate or legally permissible for EPA to change the excess emission allowances currently c ontained in the Subpart S MACT standards.

If you have further questions on this proce ss, please contact Tim Hunt at 202-463-2588. Sincerely,

/s/

Paul Noe

Cc: Peter Tsirigotis, OAQPS John Bradfield, OAQPS Bill Schrock, OAQPS