January 2 2 , 2013

MEMORANDUM

SUBJECT: Meeting N otes for the January 1 7 , 201 3 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 t he 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 K raft P ulp 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. The y reiterated that opacity monitoring is an imprecise tool and that manual M ethod 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 acc ount 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 proce ss parameters beyond

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

Bulletin No. 895.

Industry representatives noted that Appendix F is meant f or continuous emissions monitoring systems (CEMS) used and ce rtified as compliance monitors, and that Appendix F was designed for higher concentrations (e.g., 200 part per million [ppm] limits for sulfur dioxide [SO 2 ]) rather than low

concentration standards like the 5

- and 8

- ppm kraft NSPS limits for TRS. They furt her noted that

o btaining standardized cylinder calibration gases for TRS is an issue.

Action Items:

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

determin e the cause of what appear to be unexplained data spikes (e.g., whether these we re high

level 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 occ urred.

• 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

monitori ng provisions for the Kraft Pulp Mills NSPS.