Weyerhaeuser Company
Letter from Julie Frieder to Gary Risner
March 22
Gary Risner, Area Environmental Manager
Weyerhaeuser Company
115 Perimeter Center Place, Suite 950
Atlanta, GA 30346
Dear Mr. Risner:
In order for the Agency's internal review to
proceed quickly and completely, we would like to request more information
on a number of air toxics issues discussed below. Let me say at the outset
that I appreciate the amount of time and effort Weyerhaeuser is investing
in this proposal and we certainly have no intention of creating unnecessary
work for you by requesting more data.
The Agency requests more information to
determine whether Weyerhaeuser's XL Project will result in superior environmental
performance consistent with Project XL's first criterion - environmental
results. As stated in the May 23 Federal Register Notice, "Projects
that are chosen should be able to achieve environmental performance that
is superior to what would be achieved through compliance with current
and reasonably anticipated future regulation. Cleaner results can be achieved
directly through the environmental performance of the project or through
the reinvestment of the cost savings from the project in activities that
produce greater environmental results. Explicit definitions and measures
of cleaner results should be included in the project agreement negotiated
among stakeholders."
EMISSIONS DATA
Most importantly, the Agency would like
to see air emissions data, preferably in a chart format. Included the
chart should be the following information where available for total HAPs,
relevant individual HAPs, and relevant criteria pollutants:
1) actual emissions; We would like to see
the HAPs broken out and would like to know which air pollutants if any
in the miscellaneous category would be of concern to the Agency.
2) allowable emission rates assuming promulgation
of the cluster rule, or where a pollutant is not regulated in a speciated
manner, the estimated level assuming compliance with the cluster rule;
3) emissions levels anticipated under implementation
of XL proposal.
STAKEHOLDER INVOLVEMENT IN PLANNING, IMPLEMENTATION,
AND MONITORING?
The second data gap that interests the Agency
involves the role of local stakeholders in Weyerhaeuser's FPA development.
Clearly the Lake Blackshear Watershed Association brings expertise on
the water parts of the FPA. Is there a comparable group that is informed
about the air emissions data and trade offs? Strong stakeholder support
in planning, implementation and monitoring of XL projects will be a key
factor in the Agency's final determination. We encourage your continued
attention to this matter.
Sincerely,
Julie Frieder
cc: Russell Stevenson
Michelle Glenn
Penny Lassiter