March 5 , 2013

MEMORANDUM

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

of the meeting was to provide an u pdate on the status of EPA activities on the Plywood and Composite Wood Products (PCWP) National Emissions Standards for Hazardous Air Pollutants (NESHAP), K raft

P ulp Mills New Source Performance Standards (NSPS) review , and Pulp and Paper Combustion Sourc es 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

– NCAS I 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

– Wey erhaeuser

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, EP A 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. W hile 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 14 th 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 aver age versus 3

- h our 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 represen tative 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.