March 5, 2013

MEMORANDUM

SUBJECT: Meeting Notes for the February 28, 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 February 28, 2013. The purpose 

of the meeting was to provide an update on the status of EPA activities on the Plywood and Composite 

Wood Products (PCWP) National Emissions Standards for Hazardous Air Pollutants (NESHAP), Kraft 

Pulp Mills New Source Performance Standards (NSPS) review, and Pulp and Paper Combustion Sources 

NESHAP (subpart MM) residual risk and technology review (RTR) and to discuss any outstanding issues.

Meeting Attendees:

Ray Andreu – Buckeye Steve Lomax – Koch

Kurt Bigbee – APA Lisa Bauer Lotto – Greenbay Packaging

Walter Boles – Graphic Packaging Skip Missimer – Glatfelter

Allan Boynton – Old Town Fuel and Fiber Lawrence Otwell – Georgia Pacific

Corey Brandt – RockTenn John Petchul – Grief

Traylor Champion – Georgia Pacific Janet Price – Rayonier

Kevin Cheung – WWPA Mary Lee Ransmeier – Boise

Mike Curtis – Georgia Pacific Lisa Reed – Anthony Forest

Jack Emerson – NCASI Annabeth Reitter – Domtar

Phil Ferguson – LP Martin Rollins – SLMA

Rich Garber – Boise Inc. Jeff Shumaker – International Paper 

Bill Heatley – Graphic Packaging Russell Strader – Boise Cascade

Richard Holland – PCA Jim Taylor – MeadWestvaco

Rob Kaufmann – Koch Nathan Waech – UPM

Mitchell Leu – Plum Creek Denise Wlodyka – Masonite

Marv Lewallen – Clearwater Steve Woock – Weyerhaeuser

Steve List – New Page Tammy Wyles – Georgia Pacific

Rob Crawford – NCASI

Vippin Varma – NCASI

David Word – NCASI
2

Tim Hunt – AF&PA/AWC

John Bradfield – EPA/SPPD

Kelley Spence – EPA/SPPD

Nick Swanson – EPA/SPPD

Katie Hanks – RTI

Discussion Points:

Regarding the PCWP MACT, EPA noted that the agency plans to conduct an Information Collection 

Request (ICR) for the PCWP sector in order to perform the RTR and address the PCWP remand. Major 

source lumber mills would part of the ICR effort. The industry representatives were asked to review the 

most recent PCWP mailing list, and it was noted that the national emission inventory (NEI) may play a 

role in the ICR effort and PCWP RTR. The industry representatives noted there has been considerable 

consolidation in the PCWP industry over the past several years. 

Next, an EPA representative discussed developments on the kraft pulp mill NSPS review. The potential 

for inclusion of electrostatic precipitator (ESP) parameter monitoring requirements (secondary voltage 

and secondary current) was discussed. Industry representatives stated that ESP current is a function of 

particulate loading to the ESP, moisture content, and particle resistivity. While current may be useful for 

large base-loaded utility boiler ESPs, it is of limited use for emission units with variable loads because 

current changes with load in modern ESPs. The industry representatives noted that many ESP vendors 

recommend secondary voltage as the most reliable indicator of ESP operation. The industry representative 

encouraged EPA to discuss ESP parameter monitoring with ESP vendors and provided contacts as a 

follow-up to the call.

Additional discussion items for an upcoming meeting on March 14th were noted, including: 

• Modified smelt dissolving tank (SDT) costs assuming that an existing scrubber would be 

upgraded instead of being replaced with the new scrubber;

• Averaging time for wet scrubber parameter monitoring (12 hour block average versus 3-hour 

block average, as required under subpart MM);

• TRS CEMS upper limits that would be used in conjunction with a monitoring allowance and 

availability of the CEMS data used in setting these restrictions.

Regarding subpart MM, an EPA representative noted that the RTR is likely to get underway once the 

kraft pulp mill NSPS is completed. The industry representatives were asked to review suspect dioxin data 

and consider accuracy of acrolein emissions estimates in preparation for risk modeling. The industry 

representatives noted the amount of time spent by both the industry and EPA to verify emissions 

estimates used in the subpart S risk modeling, and agreed that some of this preliminary work would be 

beneficial if there are known issues with the emissions estimates.