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Weyerhaeuser Company

Letter from A. Stanley Meiburg to Stakeholders


October 10, 1996

Dear Stakeholder,

On October 9, 1996, the draft Project XL Final Project Agreement (FPA) developed for the Weyerhaeuser Flint River Operations pulp mill located in Oglethorpe, Georgia, was made available for public comment. The United States Environmental Protection Agency created Project XL in 1995 as a pilot program to provide regulatory flexibility to a limited number of facilities to achieve environmental performance superior to that which would be achieved through existing and reasonably anticipated future regulations. The mill was selected for participation in Project XL in December, 1995.

The FPA is the document which summarizes the intentions of all parties with regard to the XL project. The draft FPA offered for public comment summarizes the intentions of the following four entities: Weyerhaeuser, the Georgia Pollution Prevention Assistance Division, the Georgia Pollution Prevention Assistance Division, the Georgia Environmental Protection Division, and the United States Environmental Protection Agency. The draft FPA was developed with extensive input from the stakeholders affected by the pilot project, including representatives from the Cities of Montezuma, Oglethorpe, Cordele, and Americus, Macon County, the Macon Correctional Institute (a neighboring prison), and the Lake Blackshear Watershed Association.

Each project in the XL pilot program is a combination of enhanced environmental results and regulatory flexibility. So it is with this project. Weyerhaeuser has agreed to significant improvements in water quality and reductions in solid waste generation in return for flexibility in meeting other regulatory requirements.

Weyerhaeuser has agreed to implement a range of pollution prevention measures that will have superior environmental and related benefits. Weyerhaeuser will reduce bleach plant flows, enhance timberlands management programs, incorporate ISO 14001 standards into the upgrade of the plant's environmental management system, implement improved energy conservation, reduce solid waste generation, and decrease raw water demand. Weyerhaeuser also will conduct a variety of feasibility studies to further reduce the environmental impact of the mill, and share lessons learned with all parties to the FPA and stakeholders. In addition, the company has agreed to enforceable commitments in the mill's wastewater discharge permit that are more stringent than those called for in current or proposed effluent guidelines. Certain of these pollution prevention measures also will lead to reductions in air emissions in the long term.

Among the most significant pollution prevention provisions of Weyerhaeuser's XL project is their goal to reduce bleach plant flow to 10 cubic meters/air dried metric ton (ADMT) in ten years (by 2006), an important step toward an environmentally friendly closed loop mill. Current and proposed EPA regulations based on best available technology do not place curbs on bleach plant effluent flow. Effective implementation of pollution prevention technologies is capable of increasing reuse of recoverable materials and energy while concurrently reducing discharge of all water pollutants and consumption of raw materials (e.g., process water, unrecoverable chemicals, etc.), and reducing generation of air emissions and hazardous and non-hazardous wastes.

The water environmental benefits of achieving this reduced bleach plant flow include substantially reduced discharges of all chlorinated and nonchlorinated organic pollutants, reduced effluent chronic toxicity, and reduced water use. An important benefit of achieving reduced bleach plant flow and moving toward closed loop operations at this mill would be to generate data and information from a feasibility study delineating pollutant-specific effluent reduction benefits, as well as data on multimedia impacts and tradeoffs (specific hazardous air pollutant (HAP) and other air emissions, solid wastes, etc.). This feasibility study also would generate information on the process technologies necessary to achieve reduced bleach plant flow. The project also is expected to provide useful information on full scale demonstration of resource management practices on mill timberlands. These silvicultural practices are designed to prevent and control nonpoint source runoff while improving wildlife habitat, soil productivity, and wood furnish quality. Weyerhaeuser intends to incorporate these silvicultural practices in the mill's environmental management system (ISO 14001). EPA is hopeful that the feasibility study will demonstrate pollution prevention measures and management systems that will be transferable to the rest of the pulp and paper industry.

As the facility's National Pollutant Discharge Elimination System (NPDES) permit is reissued in the year 2002, the feasibility studies' findings will be used to determine the wastewater quantity and quality improvements that can be achieved by the facility in the year 2006, plus the nature of and schedule for interim milestones which precede attainment. The volume of bleach plant effluent flow, interim milestones, and schedule for attainment will be included in a draft NPDES permit as enforceable conditions. This permit will be subject to public review and comment.

Solid wastes generated by the process stream of the mill will be reduced by 50% by the year 2006, as compared to the 1995 actual solid waste generation figures. The preferred method of accomplishing this, in order, will be source elimination, in-process recycling, and reuse. The environmental benefits include eliminating landfilling lime mud, clarifier sludge and power boiler ash, eliminating purchased lime for slaking operations, improved wood fiber yield and conversion into finished product, and improved timberlands soil productivity from the application of residuals from the mill.

In addition, the mill's adoption of the ISO 14001 standard for its environmental management system will instill the principle of continuous environmental improvement into the mill's business management systems. The EMS will demonstrate to employees the impacts of their activities on their environment and encourages continuous improvement through pollution prevention versus end-of-pipe control.

This project provides regulatory flexibility too. Weyerhaeuser has requested that flexibility be granted in meeting reporting and testing requirements associated with a number of regulatory programs as well as some of the requirements of the Clean Air Act and the proposed Pulp and Paper Cluster Rules.

Emission and discharge testing will continue. Weyerhaeuser proposes, however, that routine reporting of such testing be replaced with mid-year and end-of-year compliance reports. All records of testing and results would continue to be available for examination at the facility. Enforcement mechanisms now available to the State and EPA would remain in place.

The State of Georgia would propose to modify the facility's current air quality permit to include a dual emission caps system. The system gives the facility the flexibility to make process changes or add equipment while providing a strong incentive to maintain or lower overall facility air emissions. The flexibility of the dual cap system would allow the facility to fully utilize several previously permitted units without triggering permitting requirements for otherwise minor changes in the plant. This would grant the facility flexibility in continuing to meet Prevention of Significant Deterioration requirements of the Clean Air Act as well as the testing and reporting requirements associated with new sources of emissions.

Once the final Maximum Achievable Control Technology (MACT) standards are published with the Pulp and Paper Cluster Rules, the State of Georgia and Weyerhaeuser will perform an assessment to quantify the reductions in hazardous air pollutants required of the facility under the MACT rule. The State of Georgia would propose to grant Weyerhaeuser the flexibility to demonstrate pollutant reductions using innovative and pollution prevention approaches in lieu of, or in addition to, end-of-pipe controls. A specific plan and schedule will be prepared to achieve the necessary reductions. Weyerhaeuser, of course, retains the option of complying with the rule by installing add-on control equipment.

Flexibility would be granted by the State for Weyerhaeuser to achieve its required pollutant reductions in any combination of (1) emissions control equipment, (2) pollution prevention or other innovative techniques or technology, and/or (3) add-on control devices. The primary flexibility granted here is that Weyerhaeuser would be able to use existing voluntary actions at non-MACT, non-regulated emission sources as well as future reductions at non-MACT sources for compliance purposes. Since Weyerhaeuser would be able to use specified existing reductions for non-regulated sources for compliance purposes, there is a possibility that, in the short term, the environment will not see the same amount of air emission reductions which would be realized by strict adherence to the letter of the MACT rule. Based on the types of pollution prevention technical and process evaluations that EPA expects Weyerhaeuser to undertake, EPA believes that long-term superior environmental benefits for air will be realized.

EPA believes the significant benefits described above more than offset the possibility of somewhat reduced performance with regard to emissions of hazardous air pollutants regulated by the MACT standard. The above-mentioned benefits are substantial and measurable. The company has agreed to enforceable permit limits in the foreseeable future. On balance, EPA believes that this project will achieve superior environmental performance.

After careful consideration of the benefits offered by the project, balanced against the flexibility granted to Weyerhaeuser, EPA believes that this draft Final Project Agreement meets the criteria for inclusion into Project XL. A final determination regarding this FPA will be made following a thorough review of public comments.

EPA wants to hear from you concerning this draft FPA in particular and Project XL in general. Send your written comments to:

You can also telephone Ms. Glenn at (404) 562-8674. Her fax number is (404) 562-8628. Comments should be submitted by November 7, 1996.


A. Stanley Meiburg

Deputy Regional Administrator


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