International Paper, Emissions Monitoring

Minutes from the May 20 Stakeholder Meeting

Stakeholders Meeting Minutes
International Paper Company
Androscoggin Mill Project XL Proposal

May 20, 1999
Jay, Maine

Attending the meeting:

Chris Knopes, U.S. EPA Headquarters
George Frantz, U.S. EPA Region I
Thomas Sandry, International Paper
Bryce Sproul, Maine DEP
Dan Williams, Alliance for Environmental Innovation
Joe Conroy, Enbatec Corp.
Debbie Burd, Western Mountains Alliance
John Hiss, Rupprecht & Patashnick Co., Inc.
Edward Burgher, Rupprecht & Patashnick Co., Inc.
Carlo Lodi, Environmental Science Services, Inc.
Chris Rascher, U.S. EPA, Region I
Carl Baumgardner, International Paper
Ron Kriesman, Maine Lung Association
Mark Dawson, Town of Jay, Maine
Shiloh Ring, Town of Jay, Maine
Dan Sosland, Environment NorthEast
Bruce Henning, Air Pollution Characterization and Control, Ltd.
Tom Saviello, International Paper, Androscoggin Mill
Dan Dozier, facilitator, TLI Systems, Inc.

The meeting was called to order at about 11:00 a.m. on Thursday, May 20, 1999. People were asked to introduce themselves and identify the organizations on whose behalf they were attending. Facilitator Dan Dozier then identified individuals who were not able to be in attendance, but who wished to possibly participate in additional meetings on this Project XL activity, if such meetings were to be held in the future. Such individuals and their organizations are:
Rosita White, Franklin County Soil & Water District
Darrell Harmon, Penobscot Indian Tribal Government
Rob Taylor, Jay High School
John Arnold, Mechanical Systems, Inc.
Mic Le Bel, Maine Pulp and Paper Association
Dave Rovell-Rixx, National Council of Air & Stream Improvement

A copy of the Stakeholder participants and their phone numbers and addresses is attached.

The group then discussed some brief groundrules for the conduct of the meeting including authority to maintain the schedule and to follow the agenda as modified and agreed to by the group. It was explained that the purpose of Project XL Stakeholder groups is to provide input to EPA, that that all discussions and procedural decisions would be managed by consensus, and that the role of the facilitator was relatively low-key; to assist the group to manage its time; and to record, briefly and in sum, the results of the discussion. Participants were asked if there were any questions or comments about the proposed groundrules. There were none.

One individual requested information from EPA about the role and function of Stakeholder groups. It was agreed that EPA would address this and other similar questions during discussion of the next agenda item. The facilitator then requested approval of the draft agenda, a copy of which had been circulated to potential stakeholders prior to the meeting. Participants agreed with the agenda with the understanding that there would be a discussion about the role and resources available to Stakeholder groups.

EPA then gave a short presentation about Project XL, which stands for "eXcellence and Leadership." Project XL is a national pilot program that tests innovative ways of achieving better and more cost-effective public health and environmental protection. Through site- or facility- specific agreements with project sponsors, EPA is attempting to gather data and experience to design better, faster, cheaper and more effective methods of protecting human health and the environment.

Stakeholder meetings are a method of obtaining input from potentially affected individuals and organizations. Stakeholders are grouped into three categories, each with a distinct role in developing and implementing Project XL:

Direct participants: are involved in the day-to-day aspects of project negotiations; they influence the design and development of projects; and their views strongly influence the details of the project and EPA's ultimate decision to approve or not each project proposal.
Commentors: EPA is also influenced by commentors who have an interest in the project but do not participate in the detailed discussions and negotiations about the project development; commentors express their perspective via written or oral comments.
The general public: is involved by having clear access to information on the development and environmental results of the project.
Both local citizen and national interest groups are welcome to participate in this (and all) XL projects.

One of the first lessons EPA learned from the early XL projects was that people who were satisfied with the project were those who were involved in the Stakeholder process. EPA will fully participate in the Stakeholder process, will not make any side deals or arrangements, and will inform all Stakeholders of its views on issues.

In response to a question from a participant, EPA explained how XL Stakeholder groups could obtain access to technical assistance from outside experts. A copy of a fact sheet describing the XL Technical Assistance grant policy is attached. While EPA has budgeted some money for Stakeholder technical assistance, EPA policy provides that the Stakeholder group, as a whole, must agree and apply for the Technical Assistance grant, not individual participants or organizations.

Participants then discussed the role of Stakeholder groups in approval of XL project applications, and the relationship between the substantive issues involved in the approval of such projects and the process. One participant asked whether EPA has committed to make its final project decision based on a consensus agreement from the Stakeholder group, or rather is the Stakeholder group able to provide input, but not make any final decision?

EPA's view is that the Stakeholder process is to provide input and information to EPA and the project applicant. Then EPA, as the Agency responsible for the protection of human health and the environment, will make the final decision, after strongly considering the views of the Stakeholders. EPA will participate fully and openly, will consider the fairness and openness of the Stakeholders process, and will consider all views carefully, but, in the end is required to make a determination.

There was a question about the role of the state and the town, both of which regulate IP air permits. There was discussion about the two sets of regulations, Federal and state, so both Federal and state policies must be addressed in this project. The state has looked at this project, has modeled the facility's particulate emissions, and the state, at some juncture, may have to change its policies. The state and town do have the ability to not enforce against permit violations. The state, however, supports this project and is a co-sponsor, with IP, of the application. The state is also participating as a Stakeholder in the group meetings.

The meeting then adjourned for a lunch break.

After lunch, the group heard a presentation from Tom Saviello, project sponsor, on behalf of International Paper Company's Androscoggin Mill, about the nature and scope of the project. The objective of this project is to provide assurances of acceptable emissions of particulates and other pollutants on a continuous basis from the Mill's waste fuel incinerator (WFI). There was a discussion of the history and background of emission monitoring in the U.S. and at this mill in particular.

IP has proposed to develop a predictive emissions monitor (PEM) system developed using a computer model with a high order nonlinear regression mathematical model using an advanced neural network to predict particulate matter, sulfur dioxide, nitrogen oxide, carbon monoxide, and carbon dioxide from the WFI. IP, supported by the town of Jay and the state, is proposing to develop a protocol using the PEM system to provide feedback on operational controls to maintain optimal emission rates and prevent potential license exceedances at the WFI. If the PEM development is successful, this system will replace existing applicable continuous emission monitors and stack testing requirements at the WFI.

To establish the necessary data to enable the PEM to work correctly, IP must obtain data showing exceedances above license limits for short periods of time. The model must be able to "recognize" potential violations in order to function properly, and the only way for it to do so is to obtain data on those exceedances.

There was a discussion among the members regarding the issues of stack testing and validation of data. The group generally agreed that, while many members, especially those from the vendor community, may have the technical background to critique and assist IP to address those issues, many members do not.

IP also provided a handout (attached) suggesting a possible schedule and timeline for stakeholders meetings and PEM project activities.
Ed Burgher and John Hiss from Rupprecht & Patashnick Company (R & P) made a short presentation on their company's mass sample monitoring system that may enable samples of particulate matter to be taken from the WFI in order to provide an independent validation of the PEM system. However, there are certain conditions under which the R & P units could not function. This may limit potential application to the PEM project.

The next discussion was on the question of how to make the Stakeholders process meaningful. Participants recognized that the PEM system may have great potential technical and environmental benefits, both at the Androscoggin mill and possibly elsewhere, but wanted to more clearly understand how the Stakeholder group would assist in this effort, and what value their participation would bring to the process. It was understood by all that in order for Stakeholders to effectively participate they would have to become educated on the technical and operational details of the IP proposal, of emission monitoring systems generally, about validation issues, and about the PEM system.

There was agreement among the members of the Stakeholders group that the greatest value of the PEM system would be if it were useable elsewhere. There was discussion of the resources that individual Stakeholders, as well as the group, would have to devote to the process and a recognition that the EPA technical assistance grants, while potentially useful, did not provide resources to individual groups that they might find necessary in order to participate as Stakeholders. It was pointed out that not all groups or individuals were required to participate in the same way and that some individuals or groups might choose to participate as commentors, not Stakeholders.

It was recognized that the Stakeholder process, to be successful, must build trust among the participants, including commentors, and that trust building can take time.

The participants also discussed the ramifications of the project. While the immediate permit waiver issues are important for IP to be able to conduct testing for development of the PEM, from the viewpoint of some stakeholders other policy-related issues such as the transferability of this technology, how to enforce limits based on a PEM system, and validation of stack testing results, are of greater significance.

EPA recognized that these were significant issues and that the Agency wanted to have some of these issues addressed by the group. There was discussion about whether there could be two different approaches to this project: one to look at the specific technical issues in connection with obtaining data, installing, testing, and validating the PEM system at the mill's WFI; and the other to look at the policy and technology transfer issues more broadly as this technology is developed, using the example of this project as a way to understand all of the issues.

From the mill's viewpoint, this approach is not a problem, as long as the schedule is not delayed this summer. IP needs to run the tests this summer in order to obtain the data necessary to install the PEM system.

Another suggestion was made that there were three major issues the Stakeholders could address. First to review IP's request to exceed its WFI permit limits to obtain necessary PEM data; second to evaluate the validation, enforcement and compliance issues associated with this project; and third, to consider the transferability of the technology, whether such technology is appropriate at other facilities, and how to enforce stack emission limits using PEM technology.

There was a consensus among all Stakeholders at the meeting that the longer term issues, that is items two and three above, are significant and appropriate for the Stakeholders group to address. To educate the Stakeholders, therefore, the next meeting should, at a minimum, address the test parameters, the experimental design, and testing and verification of the project. Finally all Stakeholder group members agreed that a valuable use of time at the next meeting would be to discuss the policy-related issues again, such as why this project is important to EPA, what are the enforcement and validation issues, what is at stake with this technology, and what are the potential environmental benefits of this technology.

Finally all members of the Stakeholders group agreed that this first meeting has begun the dialogue. There was discussion of the date for the next meeting and two potential dates were chosen, June 10th as a first choice, June 16th as the second choice. Parties will be informed quickly about which of those two dates would be selected, based on input from all parties, including those not present at this meeting.

International Paper, Emissions Monitoring

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