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International Paper, Emissions Monitoring

Selection Letter to International Paper from John DeVillars, Administrator, EPA Region 1

March 29. 1999

Mr. Larry Norton, Plant Manager
International Paper
Androscoggin Mill
Jay, Maine 04239

Re: EPA Recommendation Regarding International Paper XL Proposal

Dear Mr. Norton:

Congratulations for developing an insightful Project XL proposal to develop, test and implement an innovative emissions monitoring system at International Paper's Androscoggin Mill. Also we would like to thank you and the rest of the Androscoggin Mill staff for their hard work in developing this project. The purpose of this letter is to formally accept the International Paper proposal as a potential Project XL pilot and to invite you to work with EPA staff to develop a draft Final Project Agreement for EPA and stakeholder review. While this letter does not represent final EPA approval, agency staff both at headquarters and at EPA - New England believe the proposal has significant merit and deserves to be further developed in the form of a Final Project Agreement ("FPA").

The potential benefits of your project include the testing and implementation of an emissions monitoring technology which: · would monitor particulate matter emissions on a continuous basis rather than once per year;
· through process optimization, improve operations while at the same time reducing emissions; and

In order to obtain the flexibility necessary to achieve the results described in your proposal, EPA, the State of Maine, the Town of Jay, interested stakeholders and IP will need to work together to address several key elements of the project in a draft FPA. These elements include:

1. Flexibility: Project XL is about testing alternative ways of protecting the environment. The draft FPA should specifically identify the nature of the alternative approach sought (in particular, any specific changes in regulatory requirements). EPA has not selected the most appropriate legal implementing mechanism to allow the flexibility requested. Selection of the most appropriate legal mechanism(s) would be the subject of discussions between IP, EPA, the Town of Jay, the State of Maine and stakeholders as the FPA is developed.

2. Monitoring, Reporting and Evaluation: In order to ensure the transparency and independent verification of the project's results, the quantity and quality of data reported must be sufficient to assure the public and the government that you are complying with the project's requirements and are meeting the project's goals. The draft FPA should describe how data will be collected and made available to the public.

The proposal indicates that emissions data points for NOx and SOx would not increase in frequency, but would be derived from PEM rather than CEM monitoring. Given this change from an existing monitoring method to an experimental method, EPA, IP and interested parties will need to work together to determine an appropriate length of time for CEM monitoring of SOx and NOx to remain in place until the accuracy of the PEM system has been verified (EPA suggests a two year period). At a minimum, the CEM system for NOx and SOx would need to remain in place until the state of Maine completes a SIP revision that allows for their removal.

It is EPA's understanding that IP will commit to some frequency of relative accuracy testing and stack testing during the life of the project to assure that the PEM system remains accurate. Additionally, the number of stack tests or quality assurance tests (such as RATA tests) and the frequency of those tests should be determined during FPA development with involvement from interested parties.

IP has expressed a willingness to consider use of a particulate matter continuous emission monitor (PM-CEM) as part of this project. EPA understands that a PM-CEM would only be used if it could be installed for no cost or a significantly reduced cost. EPA is interested in exploring the use of a PM-CEM and hopes to work with IP to identify an acceptable option for doing so.

3. Commitments: All XL Project Agreements should have clear objectives and requirements that will be measurable in order to allow you, EPA, state and local authorities and the public to evaluate the success of the project. The draft FPA should explain the different commitments which you are willing to make as well as those EPA will make. As noted above, the project will include use of some type of legal mechanism (to be determined) to incorporate your commitment to superior environmental performance and EPA's commitment to flexibility.

Again, I thank for you your participation in EPA's Project XL and I look forward to working with your team to develop the FPA and implement this project. As my staff have indicated, we are able to offer International Paper contractor assistance in identifying and convening appropriate stakeholders for this project. I know from speaking with my staff, that you are highly committed to the type of bold and responsible experimentation that will make our environmental protection system better for all.

Should the FPA be signed, the International Paper XL project will become an official XL Pilot. If I can be of any assistance in expediting the development and review of your Final Project Agreement, please do not hesitate to call.


John DeVillars
Regional Administrator

cc: Jay Benforado, EPA
Lisa Lund, EPA
Edward Sullivan, Commissioner, ME DEP
Ron Dyer, ME DEP
Bryce Sproul, ME DEP
Mark Dawson, Town of Jay
Chris Rascher

bcc: EPA XL Project Team
Chris Knopes, EPA

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