Weyerhaeuser Company

Frequently Asked Questions about the Weyerhaeuser XL Project

Q: What is Project XL?

A: Project XL was launched by President Clinton on March 13, 1995 to create innovations for 21st Century environmental protection. Project XL is part of the President's overall strategy of Reinventing Environmental Regulation, and provides an opportunity to demonstrate eXcellence and Leadership. In creating Project XL, President Clinton remarked that, "[a]s we move towards a new century, it is imperative that we challenge ourselves to step outside the context of the established way of doing things to identify new and innovative means to achieve our goals." EPA is committed to taking what we learn from constructing and implementing XL projects and applying it to the broader system of environmental protection that applies to everyone.

Under Project XL, EPA, state environmental agencies, and regulated sources develop and implement alternative strategies that replace or modify specific regulatory requirements, produce superior environmental performance, and promote greater accountability to stakeholders. These three elements are equally important and equally necessary for a good XL project.

The best way to obtain more information on Project XL, on individual projects, and on the program itself, is through our site on the World Wide Web at "https://www.epa.gov/ProjectXL".

Q: What are examples of other XL projects?

A: Today's agreement with Weyerhaeuser is the third XL project implemented to date. In June, 1996, EPA and the State of Florida signed an agreement with Berry Corporation to consolidate permitting at its LaBelle, Florida, juice processing plant. That agreement will produce millions of dollars in savings while ensuring new voluntary investments in air pollution control equipment and in research on natural alternatives to toxic solvents. In November, 1996, EPA, the State of Arizona, Maricopa County, and local stakeholders signed an XL agreement with Intel for its new chip manufacturing plant in Chandler, Arizona. That agreement will increase Intel's competitiveness by eliminating permitting delays while providing enhanced benefits to the environment. As a result, this 800 acre, multi-billion dollar facility is among the cleanest in the world, a minor source of air pollution, and a recycler of nearly all of its process water.

Q: Why is Weyerhaeuser participating in Project XL?

A: Companies have a variety of reasons for participating in Project XL. Since 1992, Weyerhaeuser has focused on Minimum Impact Manufacturing (MIM), a holistic strategy for continuous environmental improvement. Weyerhaeuser has already completed the first three phases of its plan for implementing MIM at its Flint River Operations in Oglethorpe, Georgia (about two hours south of Atlanta). With the assistance of EPA and the Georgia Department of Natural Resources, Weyerhaeuser believes that further progress can be made during MIM Phases IV and V. Therefore, Weyerhaeuser submitted a proposal to EPA for an XL project.

Q: Why did EPA decide to accept and implement Weyerhaeuser's proposal for an XL project over other potential candidates?

A: First, today's agreement is founded on the vision of an ever-shrinking environmental footprint, combined with the management systems, regulatory requirements, and program of technological innovation to support that vision. This kind of 'continuous improvement' ethic must become widespread if we are to make environmental progress beyond where today's regulations will take us. Making minimum impact manufacturing work would be an important innovation for 21st Century environmental protection.

Second, today's agreement will help to create technological innovations for pollution prevention that dramatically reduce the environmental footprint of the pulp and paper industry. EPA values the final project agreement's quantitative commitments and program of technological research and development to reduce bleach plant flow, a major source of air as well as water pollution from pulp and paper mills. EPA is particularly pleased that the process of creating these innovations will be an open one, in which other companies, local and national environmental organizations, and the general public are invited to participate.

Third, today's agreement will improve water and habitat quality in the Flint River and other Georgia watersheds. These will come from actions at the mill and improved land management practices on Weyerhaeuser lands throughout the state.

Q: What is "Minimum Impact Manufacturing"? Is it more than corporate jargon?

A: This Weyerhaeuser concept employs the idea of continually striving to reduce the overall set of environmental impacts or the 'footprint' of Weyerhaeuser operations.

Weyerhaeuser has managed the Flint River mill using this philosophy for many years, with obvious results. The facility is a state-of-the-art mill producing 320,000 tons per year of fluff pulp, the absorbent component of diapers. The mill, located in Oglethorpe, Georgia, opened in 1981. Today it employs 500 people and contributes $75 million annually to the Georgia economy. The facility voluntarily installed oxygen delignification technology in 1980 and 100% chlorine dioxide substitution and bleaching in 1989. The facility was designed from the start to use less water than most mills of its kind. Flint River Operations was the benchmark for many of EPA's industry-wide effluent guidelines and best management practices. The mill already meets tough post-2000 industry water pollution standards proposed by EPA. And dioxin, a major health concern to many familiar with pulp and paper production, has never been detected in association with the Flint River mill. Finally, the mill has low emissions of total reduced sulfur - the source of the acrid smells associated with most pulp mills - significantly lower relative to other paper mills.

In addition to the specific limits, targets, and actions described in today's agreement, Weyerhaeuser is taking steps to ensure that the minimum impact philosophy remains part of day-to-day operations at the mill. For example, Weyerhaeuser has agreed to adopt the ISO 14001 standards for the mill's environmental management system. These standards will ensure that the mill, in its day-to-day operations, retains the goal of continuous improvement in environmental performance.

Q: Why is the Flint River important, and what are the environmental benefits of this agreement to the Flint River?

A: The Flint River and the Lake Blackshear watershed are important recreational and ecological resources in central Georgia. They are a regional hiking, canoeing, and camping destination. Local community members of the Lake Blackshear Watershed Association have a history of concern for, and protection of, the River. In the past, concerns have been raised about the health of turtles and other wildlife in the river due to pollution from pulp and paper mills on the Flint River. Protection and preservation of the river have been shared goals of Weyerhaeuser and the local community for many years.

Today's agreement provides several important new benefits for the Flint River. First, Weyerhaeuser has agreed to a voluntary target of cutting the effluent flow from the mill's bleach plant in half. Reducing bleach plant flow is important because the bleach plant's effluent contains the chemicals of greatest concern from the perspective of protecting human health and the environment, including chlorinated as well as non-chlorinated organic compounds. For example, nearly all of the mill's adsorbable organic halides (AOX) and total suspended solids (TSS), and two-thirds of the mill's biochemical oxygen demand (BOD), comes from the bleach plant. (Additional information on these pollutants is provided below). By cutting bleach plant flow in half, and moving even further toward a 'closed loop' system, Weyerhaeuser will make dramatic reductions in the discharge of these pollutants to the river.

Second, Weyerhaeuser has agreed to a voluntary target of cutting its raw water usage by almost one million gallons per day. That's more than the amount of water needed to fill one Olympic-sized swimming pool every day. Cutting bleach plant flow in half, as discussed above, could yield an additional 2 million gallon per day reduction. Limiting the amount of water extracted from the river is important because reduced freshwater flow can have negative ecological impacts downstream, particularly during the dry season.

Q: The agreement also includes changes in forest management practices. What are these and how will they affect water quality?

A: Weyerhaeuser has agreed to take important steps to change the management of its forestlands in ways that protect the health of the Flint River, other Georgia waterways, and surrounding habitats. Weyerhaeuser manages approximately 300,000 acres of timberland in Georgia, with impacts on more than half the river basins in the state. Most Weyerhaeuser lands are clustered around three watersheds from south-central to northeastern Georgia, the Flint, the Ocmulgee, and the Oconee, but runoff has impacts on over half the watersheds in the State. As such today's voluntary commitments will have positive impacts on land management and water quality across a wide swath of the State.

Weyerhaeuser will modify its management of timberland areas by designating forest buffers adjacent to bodies of water, placing and retiring roads to minimize soil erosion, improving management practices in streamside areas, and developing water bars (i.e., trenches to divert runoff from roads or trails) to stabilize soil. Weyerhaeuser has also agreed to continue to enhance wildlife populations within its forests by identifying and safeguarding unique habitats, implementing landscape planning for wildlife, establishing wildlife corridors, protecting threatened and endangered species, and cooperating with governmental agencies in studies of how company forestlands can contribute to the conservation of threatened and endangered species

Q: In addition to these voluntary targets and actions, what are the enforceable limits on water pollution in this XL agreement? How do those compare to the limits in the facility's current permit?

A: Weyerhaeuser has agreed to tighten the enforceable limits contained in its operating permits for the different types of water pollutants: biochemical oxygen demand (BOD), total suspended solids (TSS), and adsorbable organic halides (AOX). BOD is a measure of the amount of dissolved oxygen needed by bacteria to digest the organic matter in the effluent. High levels can result in fish kills because there is insufficient oxygen in the water remaining for fish and other aquatic life. The BOD limit under Project XL is 28% lower than the current limit, and 11% better than "best available technology" standards proposed by EPA. TSS affects the depth which sunlight can penetrate the effluent discharged to the river by Weyerhaeuser, which in turn affects the health of aquatic life. The TSS limit under Project XL is 29% lower than the current limit and 52% beyond best available technology standards proposed by EPA. AOX is a measurement of the amount of dissolved chlorinated organic matter in the waste stream. This measurement is important because chlorinated organic matter can build up in the tissue of fish and thereby get into the food chain. The AOX limit under Project XL is 4% beyond best available technology standards proposed by EPA. The facility's current permit contains no limit on AOX. Finally, Weyerhaeuser has agreed to establish an enforceable limit on total water use in addition to the more stringent voluntary target discussed above. Even if it uses as much water as permitted under this agreement, the facility will still be using 60% less water than the average pulp and paper mill.

The following chart details the quantitative commitments being made today by Weyerhaeuser and compares them to current environmental performance, otherwise applicable permit limits, and best available technology standards proposed by EPA.

Environmental Parameter	Current Actual ('93-'95 Avg.)	Current Permit Limit	Best Available Technology Economically Achievable	XL Permit Limit	Voluntary XL Targets 1997	Voluntary XL Targets 2002
Bleach Plant Flow cubic meters/ADMT)	20	none	none	none		< 10
Total Water Usage (million gallons/day)	11.18	14.34	none	11.5	10.18	8
BOD (lb per ADMT)	4.32	5.3	4.83	3.8		2.5
TSS (lb per ADMT)	4.65	5.8	8.58	4.09		2.1
AOX (kg per ADMT)	0.11	none	0.156	0.15

(ADMT means "air dried metric ton" of mill product)

(Best Available Technology Economically Achievable is the standard in EPA's proposed 'Cluster Rule' for pulp and paper mills)

Q: In the chart, the XL permit limits for AOX and for total water use are higher than current actual effluent levels. Doesn't that take us in the wrong direction?

A: The goal of minimum impact manufacturing is to shrink all aspects of the mill's environmental footprint, including total water use and AOX. These XL permit limits are more stringent than the mill's current permit, which contains no limit on AOX. Moreover, performance at the XL permit limits for AOX and total water use would put Weyerhaeuser's Flint River mill well below the typical pulp and paper mill. The XL permit limit for AOX is 4% beyond "best available technology" standards proposed by EPA. The XL permit limit for total water use is almost 60% beyond the performance of the typical pulp and paper mill.

Today's agreement commits Weyerhaeuser to do better than it's current environmental performance and better than the proposed XL permit limits on total water use and AOX. With respect to total water use, today's agreement includes a voluntary target that will cut its extraction of fresh water from the Flint River by one million gallons per day, about 10% of current water use, by the end of this year. Today's agreement also includes a voluntary target to reduce bleach plant flow by half, which would produce an additional 2 million gallons per day reduction in total water use. Since nearly all of the AOX comes from the bleach plant's effluent, achieving this voluntary target would also cut AOX by approximately 50% from today's levels.

Q: The XL agreement also talks about changing consumer demand. What is this about and how will it affect environmental performance at the mill?

A: A major barrier to better performance with respect to AOX and bleach plant flow is consumer demand for whiteness in the mill's diaper product. Today's agreement includes efforts to lower this barrier. AOX discharge is directly related to the amount of bleaching needed to produce the mill's diaper product. Bleaching is needed to make the product as white as possible. Unfortunately, consumers in Europe and Asia, where most of the mill's product is sold, have a strong cultural association between whiteness and purity, and as such, demand a white diaper product. However, whiteness does not in any way affect the usefulness of the product. As part of today's agreement, Weyerhaeuser, together with regulators, stakeholders, and its customers will seek to change that association by helping consumers understand that their beliefs lead to greater stress on the environment and not a better product.

Q: Will today's agreement improve other aspects of the mill's environmental performance beyond its impact on water and habitat quality?

A: Today's agreement includes specific items to reduce other aspects of the mill's environmental footprint, such as generation of solid waste and hazardous waste, energy consumption, and air pollutant emissions.

Weyerhaeuser has agreed to a voluntary target of cutting the mill's solid waste generation in half over the next ten years, largely by recovering and reusing wastes that, prior to XL, were simply thrown away. The mill will make product out of 7500 tons per year of knots and other irregular pieces of timber. The biggest gains will come from recovery and reuse of up to 75,000 tons per year of lime mud from the waste stream, in lieu of purchasing new lime for use in the mill's production. In both of these examples, investments in efficiency will yield benefits for both the environment and Weyerhaeuser's financial bottom line.

This can also be said of the mill's commitment to reduce energy consumption by about 10%. This reduction will be accomplished largely through the recovery and reuse of process steam generated by the mill's operations. By getting more energy from process steam and less from boilers powered by fossil fuels, the mill will save money while reducing emissions of carbon monoxide, particulates (soot), hazardous air pollutants, and greenhouse gases.

With respect to hazardous waste, the mill has committed to reduce its waste generation to a level where it will move from "very small quantity generator" to "conditionally exempt," a status that even many small businesses do not enjoy. To reach this goal, the facility will have to reduce waste generation to less than 220 pounds per month.

Today's agreement also includes efforts to reduce emissions of hazardous air pollutants (HAPs). Surprisingly, the major unregulated source of air pollutants at the mill is water. Pollutants are suspended in the mill's water discharges and later evaporate into the air. Today's agreement looks to reduce these emissions. For example, the bleach plant flow is an important source of HAPs just as it is an important source of various water pollutants. Weyerhaeuser has agreed to the voluntary target of cutting bleach plant flow in half. This would reduce by a comparable amount HAP emissions from this source.

Today's agreement also includes an alternative compliance regime that will make it easier for the mill to meet tough proposed EPA technology requirements to reduce more direct air emissions of HAPs, by allowing the mill to choose which technologies it will employ to meet the standards. These "Maximum Available Control Technology" standards will reduce HAP emissions from the mill by about 500 tons per year.

Q: What technologies will Weyerhaeuser put in place to meet the new limits and targets in today's agreement?

A: While today's agreement is not technology-specific, Weyerhaeuser has already identified pollution prevention technologies that it will use to achieve many of the agreement's goals. These are described in the text of the agreement. Moreover, the agreement commits Weyerhaeuser, regulatory agencies, and stakeholders to participate in a collaborative process of feasibility studies with specified milestones to further develop new technologies that achieve and go beyond today's targets. Further information on the feasibility studies is provided elsewhere in this package.

Q: What regulatory flexibility is Weyerhaeuser receiving in today's agreement and how does it support the idea of minimum impact?

A: EPA and the State of Georgia have agreed to propose changes in the rules that apply to the facility to support minimum impact manufacturing. These will result in a system of environmental rules at the mill that is different from what would generally apply in three key respects: (1) routine reporting will be consolidated into a single biannual report that is more accessible to the public; (2) plant managers will be able to select which technologies and emission points to control in order to meet proposed standards for control of hazardous air pollutants so long as they achieve the required emission reductions; (3) government review of certain air pollutant impacts prior to physical modification of the mill will be waived so long as the mill remains within prescribed emission limits for these air pollutants.

These changes will support minimum impact manufacturing in three ways. First, they make it easier for regulators, stakeholders, and the public to monitor the mill's bottom-line environmental performance. EPA's experience with the Toxic Release Inventory and other programs argues strongly that transparency provides a strong incentive for companies to continuously improve their environmental performance. Second, these areas of regulatory flexibility will produce real cost savings - through reduced control costs as well as through paperwork reduction - which are being reinvested in minimum impact technology development at the mill. Third, these changes are performance- rather than technology-based, again encouraging the mill's managers to focus on the environmental bottom-line.

Q: How will environmental reporting be consolidated at the mill?

A: Many more frequent reports will be consolidated into biannual and annual reports. Weyerhaeuser will provide regulators and stakeholders a summary report every six months and will make all backup data and reports available upon request. In each report Weyerhaeuser will provide a summary of the environmental performance data and will describe Weyerhaeuser's progress toward meeting the limits, targets, and conditions of this agreement. Weyerhaeuser will also describe the progress of feasibility studies on new technologies created by today's agreement. After two years of this type of reporting, the parties to today's agreement may choose to adopt annual in lieu of semi-annual reporting.

Q: Will consolidation of reporting reduce the amount of information available to regulators or the public, or the frequency of compliance tests and monitoring?

A: No. EPA believes that information will be more, rather than less, accessible under today's agreement. What once required complex training to understand and a trip to a record storage area to obtain can now be learned in a summary report or obtained through a phone call, letter, or electronic mail. While this agreement consolidates many types of frequent reporting, it does not generally change the more frequent testing, monitoring, and data collection requirements that go along with that reporting. Records of these items will be maintained and will be available from the mill upon the request of regulators, stakeholders, or other members of the general public. As such, today's agreement reduces the burden of unnecessary paperwork, creates cost savings, and enhances the public's ability to understand the environmental impacts of the mill and its compliance with applicable requirements, without compromising the integrity of regulatory controls.

Q: Will information on the mill's performance be available on the Internet?

A: Yes. EPA will place all reports that it receives pursuant to today's agreement, including information on the facility's environmental performance across all of the parameters discussed in today's agreement, on the Project XL site on the World Wide Web. The address is "https://www.epa.gov/ProjectXL". From that site, users will be able to access reports and request additional information from EPA, other regulators, or Weyerhaeuser, or to make comments regarding the agreement or its implementation.

Q: What flexibility is being granted with respect to rules governing hazardous air pollutant emissions?

A: Under the provisions of Section 112 of the Clean Air Act, EPA in 1996 proposed standards requiring that pulp and paper mills implement Maximum Available Control Technology (MACT) to reduce emissions of hazardous air pollutants (HAPs). The proposed rules specify emission limitations per unit of production for specific emission sources at pulp mills such as Weyerhaeuser's Flint River mill. (Other emission sources are not limited under the proposed rules). These limits would go into effect between 3 and 8 years after final promulgation of the MACT standards, which has not yet occurred.

When the MACT standards for the pulp and paper industry are promulgated, the State of Georgia and Weyerhaeuser will perform an assessment to quantify the reductions in hazardous air pollutants required of the facility under these rules. Under today's agreement, EPA and the State of Georgia have agreed to propose an alternative compliance regime for this mill. Under this regime, the mill will achieve a level of emission reduction equal to or greater than would be achieved by compliance with the rules applicable to other mills. These reductions will be achieved on or before the date they would be required by rules applicable to other mills. However, Weyerhaeuser will have the ability to choose the specific control measures and emission sources it will control to achieve these reductions. These may include emission sources not otherwise included in the MACT standards applicable to other mills. Weyerhaeuser's control plan for hazardous air pollutants must be approved by EPA and the State of Georgia.

It is expected that the mill will opt for those control measures that are the most cost effective (i.e. provide the most HAP control per dollar). As such, the regulatory flexibility contained in this agreement with respect to HAPs delivers cost savings without sacrificing environmental performance.

Because the MACT standards for pulp and paper mills are not yet final, today's agreement contemplates further negotiation between Weyerhaeuser, regulators, and stakeholders on this issue. These will take place after the standards that will generally apply to pulp and paper mills have become final, in all likelihood by the end of 1997.

Q: Does the agreement allow Weyerhaeuser to count already existing voluntary controls toward equivalence with MACT standards?

A: In general, today's agreement prevents Weyerhaeuser from claiming 'credit' for voluntary controls that existed prior to XL in calculating equivalence with what would occur under MACT requirements applicable to other mills. For example, many of the mill's emission sources already operate above the 95% control level generally required by MACT standards. It is fair to assume that these benefits to the environment, which came into being prior to XL, would remain with or without today's agreement. As such, these benefits, while laudable, may not be 'traded' for the additional emission reductions that would occur under the MACT standards.

Today's agreement does, however, include a single exception to this principle. The agreement permits credit for previously voluntary emission control devices on certain storage tanks and process vessels, installed to achieve the mill's impressive odor control but with the side benefit of reductions in HAP emissions. That is to say, the mill will be permitted to count these controls toward a level of performance equivalent with what would be achieved absent Project XL. Total HAP emission reductions from these units amount to about 40 tons per year, about 8% of what will be achieved through performance with the proposed MACT standards.

This exception is justified for several reasons. It is expected that other elements of today's agreement, outside of the areas governed under MACT, will produce significant reductions in HAP emissions. Most importantly, Weyerhaeuser has agreed to the voluntary target of a 50% reduction in bleach plant flow, which is not regulated by MACT. As discussed elsewhere, this is expected to significantly reduce HAP emissions. Today's agreement identifies several other specific areas for potential HAP reductions from the plant's wash water system, cylinder mould (dryer), and oxygen delignification system. Work on these items will begin immediately, months before the MACT standards are even promulgated, and up to 8 more years before those standards become effective. If the expected reductions do not materialize, EPA has authority to terminate this agreement and to require Weyerhaeuser to meet the more generally applicable MACT standards.

Thus, EPA believes that today's agreement will produce greater HAP reductions than would be achieved by the upcoming MACT standards, and has the authority to revert to those standards well in advance of their effective dates if this does not turn out to be the case.

Q: Today's agreement eliminates some reviews that normally protect against increases in emissions of "criteria" air pollutants. What new protections are provided?

A: This question refers to permit reviews normally required under the Clean Air Act's Prevention of Significant Deterioration (PSD) program, which aims to protect the environment in regions of the country that are not in violation of National Ambient Air Quality Standards. Traditionally, the PSD program has required permit reviews prior to the construction or modification of facilities such as Weyerhaeuser's Flint River mill. These reviews are meant to ensure that the modification will not increase emissions such that it causes or contributes to a violation of the National Ambient Air Quality Standards, and to ensure that the modification will include "best available control technology" where required. While requiring fewer permit reviews, today's agreement retains these same protections and adds several new ones. Today's agreement, unlike the current system, limits total emissions of each criteria pollutant from the mill. Today's agreement also includes commitments that will reduce criteria air pollutant emissions and a more general commitment to a minimum impact manufacturing strategy that aims to shrink this and all other aspects of the mill's environmental footprint.

Q: How will today's agreement limit criteria air pollutant emissions?

A: Under today's agreement, the State of Georgia will propose to replace a portion of the reviews mentioned above with an emission cap system. This 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. Under this system, the mill is limited by two enforceable emission caps: (1) a 'facility emissions cap' that governs emissions from most of the units at the mill, and (2) a 'major source' cap that governs a group of four units (the power boiler, recovery boiler, smelt dissolving tank, and calciner). This system is in EPA's view at least as protective, and in some sense more protective, than the otherwise required review process.

Emissions of each criteria pollutant from most of the facility will be capped at actual pre-XL levels. In general, units governed under this cap may be modified or constructed or run at any production level without prior permit review, so long as total annual emissions from this portion of the plant do not exceed the cap. If the facility wishes to modify or construct units in a way that would exceed this cap, it must go through the normal PSD permit review process.

Emissions of each criteria pollutant from four 'major sources' will be capped at pre-XL levels, but adjusted up to accomodate maximum utilization of these units. While this cap is more generous, it is also less flexible relative to the otherwise applicable system of permit reviews. Any physical or operational modification of these units would go through the normal PSD review process.

Q: How do we know that plant modifications will not pose an air quality problem?

A: Today's agreement includes a 'front loading' of the air quality analysis usually required under the PSD program. An air quality analysis and additional impacts analysis have been completed which evaluate the emissions of the units at full utilization under this system of caps. This analysis demonstrates that emissions at these levels will not cause or contribute to a violation of the National Ambient Air Quality Standards and other requirements. Today's agreement requires re-evaluation should the parameters of this analysis (e.g. stack heights) be changed by a future modification of the mill.

Q: How does this system encourage reductions in criteria air pollutant levels?

A: First, the cap that governs most units at the facility is set at pre-XL emissions so the facility will need to ensure that emissions are below that cap. Second, today's agreement includes commitments to specific actions that will reduce criteria air pollutant emissions. For example increased recovery of process steam will reduce energy demands on the mill's boilers. Third, these performance-based caps allow Weyerhaeuser to focus on its minimum impact manufacturing strategy for the mill as a whole, rather than compliance with unit-by-unit permit reviews.

Q: Why isn't the rest of the pulp and paper industry being given the same flexibility that EPA is giving to Weyerhaeuser's Flint River Operations?

A: We are pursuing this project with Weyerhaeuser rather than another company because Weyerhaeuser is the first pulp and paper company to submit an XL proposal. We would welcome proposals from other companies in the industry as well.

In addition, Weyerhaeuser's Flint River Operations differs from most pulp and paper mills in that the facility was built with environmental protection in mind, and it therefore incorporated innovative pollution prevention technologies in its design. For example, the plant was designed to use less water than most plants of its type. The facility's environmental performance has been recognized as superior within the bleached Kraft pulping industry. The facility was the first bleached Kraft pulp mill to employ commercially viable advanced technologies that minimize adverse impacts to the environment. Partly in recognition of the facility's use of innovative technologies, EPA used Flint River Operations as a benchmark facility for the bleached Kraft pulp manufacturing industry effluent guideline and best management practices regulations for liquor.

Q: What has been the public's involvement in the creation of this project?

A: Stakeholders who participated in the discussion of the terms of today's agreement include the citizen members of the Lake Blackshear Watershed Association, non-management employees at the Flint River mill, the City of Montezuma, the City of Oglethorpe, the Macon State Prison, the Macon County Local Emergency Planning Committee, and other leaders from Macon County. The Natural Resources Defense Council (NRDC), Environmental Defense Fund (EDF), and the Institute for Regulatory Policy also provided input at several stages in the development of today's agreement.

Prior to and during the process of negotiating the final project agreement, Weyerhaeuser took steps to contact and involve stakeholders. Weyerhaeuser has adopted a written Stakeholder Involvement Plan and has taken steps to involve stakeholders including personal contacts through telephone calls and meetings, publishing notices in three local newspapers on four occasions, and holding three open public meetings.

In October of 1996, an announcement of a draft final project agreement was published in local newspapers and the Federal Register, and was widely distributed for public comment. EPA received a number of comments, and has negotiated several significant changes as a result of these comments. A summary of public comments and EPA's response is contained in Appendix One of the final project agreement.

Q: Can I have any input into the development or implementation of the project?

A: Yes, we encourage your input. You may provide input by contacting Weyerhaeuser directly or by contacting the EPA. Your input may be oral or written and can be sent by postal mail or electronic mail. You can contact Weyerhaeuser through Janet McElmurray at 912/472-5230 or Weyerhaeuser Company, c/o Project XL, P.O. Box 238, Oglethorpe, GA 31068, and EPA through Michelle Glenn at 404/562-8674, glenn.michelle@epamail.epa.gov, or EPA Region IV, 100 Alabama Street, SW, Atlanta, GA 30303. To obtain more information on the Weyerhaeuser project or other XL projects, please visit our web page at https://www.epa.gov/ProjectXL or call our fax-on-demand line at 202/260-8590.

Q: Will I have another formal chance to comment before the changes take effect?

A: Yes. The final project agreement is a statement of the intent of the parties. It establishes certain voluntary commitments by the company. However, the final project agreement contemplates that significant portions of the project will be implemented through revisions of Weyerhaeuser's permits and through a site-specific rule making. Both the permit revisions and the site-specific rule making will be proposed for public comment prior to final implementation. This will be accomplished in accordance with EPA's public involvement guidance as stated in the permits and EPA's general regulations regarding permitting.

Q: Once the project has begun, how will we know that Weyerhaeuser is performing as promised?

A: EPA's Region IV Office will designate individuals who have continuous responsibility for monitoring compliance with the terms of this agreement. The agreement provides EPA with the means to verify whether or not the mill is meeting its obligations. Weyerhaeuser will provide semiannual reports to the EPA, the Georgia Environmental Protection Division, and the Georgia Pollution Prevention Assistance Division and make the reports available to local stakeholders. In addition, Weyerhaeuser will provide an annual summary report to all individual and group stakeholders interested in the project as well as to the EPA and the State of Georgia. Weyerhaeuser will also make all backup data and reports available to the public on request.

Q: Today's agreement includes a program of technology research and development, feasibility studies, etc. What if the results of the feasibility studies do not lead in the direction anticipated?

A: Today's agreement allows any of the parties to initiate a renegotiation of the agreement or to vacate the agreement and require Weyerhaeuser to comply with all regulations generally applicable to pulp and paper mills. EPA believes that this provision leaves the regulators with the flexibility to scale back portions of the agreement or to move in a different direction if research on new technologies does not produce real benefits at the plant.

Q: Does Weyerhaeuser get special funding from the government to implement this pilot project?

A: No, Project XL does not provide funding to companies that participate in the program.

Q: Will workers at the facility be subjected to increased risk as a result of the flexibility?

A: No. Today's agreement does not in any way remove protections provided by EPA, the Occupational Safety and Health Administration, or other regulations with respect to worker health and safety, nor does it in any way lessen regulations that affect worker exposure to pollutants regulated by EPA. Moreover, the agreement contains important voluntary and enforceable commitments to reduce emissions and discharges of regulated pollutants and to reduce hazardous waste generation and utilization at the mill.

Today's agreement also envisions worker participation in the development of new pollution prevention technologies that will further reduce the need for and use of toxic chemicals.

Q: What happens if Weyerhaeuser's senior management changes or the company is acquired?

A: In such a situation, EPA's first goal would be to establish with new management the senior level commitment that has made today's agreement possible. If for some reason this could not be accomplished, today's agreement provides for termination at any parties' request with 60 days notice. Therefore, if Weyerhaeuser's new management wanted to terminate the agreement or if EPA or the State of Georgia wanted to terminate the agreement as a result of a change in Weyerhaeuser's senior management, this could be accomplished. The facility would then be subject to all laws applicable to a facility of its type and all flexibility received as a result of Project XL would be rescinded, except where individual permits issued under this agreement specifically provide differently in accordance with applicable law.

Q: How does this project change the way Weyerhaeuser is monitoring and reporting emissions from the plant?

A: Weyerhaeuser will continue to monitor emissions in the same manner as they did prior to the project. With regard to the reporting of emissions, one of the goals in implementing this project is to reduce the burden of unnecessary paperwork and obtain resulting cost savings without compromising the integrity of regulatory controls. In addition, the project is intended to simultaneously enhance the stakeholders' ability to understand the environmental benefits of the project and track the facility's compliance with regulatory requirements and progress toward minimum impact manufacturing. Annual and semiannual reporting, together with the provision of backup data on request and annual stakeholder meetings, provide the information necessary to determine whether the project is meeting its goals.

Q: How long will Weyerhaeuser's XL project last?

A: The final project agreement provides that it will be effective for 15 years from the signature date. However, it may be terminated earlier at the option of any party. If the agreement is terminated, Weyerhaeuser will again become subject to all federal and state requirements that the facility would be subject to absent Project XL.

With this agreement as a framework, permits will be issued to the facility that will in general have a shorter duration. For example, general permits related to water discharges and air emissions have a five year life. Today's agreement is timed to take advantage of these milestones. For example, milestones in the research and development (R&D) portion of the agreement are timed to coincide with permit revisions, so that these revisions may take advantage of the R&D work.

Q: What happens when the XL project is over?

A: If the project has produced its expected results, EPA will seek to continue operation of this system at Flint River and to spread the technological, regulatory, and management innovations to other facilities.

Project XL was initiated to help EPA reinvent itself such that successful projects will lead to changes in EPA policy and regulations. Therefore, we hope to take the lessons learned from the Weyerhaeuser project through regulatory flexibility, the feasibility studies, and innovative technology developed, and apply them to the more generally applicable regulatory regime. We also hope that similar facilities will use the information developed by Weyerhaeuser to reduce their plants' impact on the environment.

On the other hand, the parties to today's agreement understand that it may not work as planned. Termination by either Weyerhaeuser or regulators at any time is provided for in today's agreement. The parties understand that when the agreement ends, the mill may indeed be returned to the otherwise applicable set of requirements at that time.

Weyerhaeuser Company

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