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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."


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.


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.


Julie Frieder

cc: Russell Stevenson
Michelle Glenn
Penny Lassiter

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