Project XL

Via Fax
A. Stanley Meiburg
Deputy Regional Administrator
EPA, Region 4
345 Courtland St. N.E.
Atlanta, GA 30365

Dear Mr. Meiburg:

As per today's telephone conversation, I have enclosed a list of questions pertaining to EPA's written comment to Weyerhaeuser data May 29, 1996. These questions were prepared to help facilitate the discussions during Thursday's meeting, June 13, 1996. Please do not consider this list as everything we want to ask. I am sure that Thursday's discussion will stimulate other pertinent questions.

Also, as we discussed, Weyerhaeuser is not prepared at this time to offer a counter-proposal until we have a clearer understanding of EPA's current position regarding the Flint River Project. Weyerhaeuser is anticipating at Thursday's meeting that the EPA will provide an expanded overview of the written comments. Hopefully, the enclosed questions can assist the presenters as necessary with preparations.

Before the end of our meeting on Thursday, it is Weyerhaeuser's desire that all signatories are realigned to develop next steps that include associated time schedules for FPA completion.

Thank you for your support of our project and Project XL. You may call me at 770-668-1210 if you have questions.

Sincerely,



Gary Risner
Area Environmental Manager

Enclosure

CC: Michelle Glenn
David Word
Bob Donaghue

LIST OF TECHNICAL QUESTIONS


1. Weyerhaeuser requests a copy of the limits to be "proposed" in the "upcoming" tier (I, II, & III) incentives program now being "considered" for incorporation into the "anticipated" Cluster Rule to determine what these incentives mean to us in terms of economic and regulatory benefit(s).
2. Weyerhaeuser requests a copy of the latest "proposed" MACT standard with the "defined sources" list to be better able to determine MACT applicability to our facility.
3. Weyerhaeuser requests a copy of the MACT "floor" determination so we can determine how much HAP's control we must achieve to meet the floor level.
4. For comparison, we need a copy of the emissions calculations used to set the PSD applicability "caps" for the Power Boiler and Rest-of-Facility to insure we are talking the "same" numbers.
5. Weyerhaeuser requests a copy of the "Best Management Practices" for equivalent control of black liquor spill prevention required by the Cluster Rule since we are supposed to meet them.
6. What are MRR requirements? Weyerhaeuser requests a copy.
7. NPDES permit conditions and limits would be what? Proposed Cluster Rule?
8. What are the "proposed" less frequent monitoring requirements for dioxin, AOX, and furan?
9. What is required(?) USEPA input for developing a "workable implementation plan" with the outside stakeholders?
10. Explain how "HAP emission OFFSETS are only allowed within the source to be defined by the MACT standard.
11. Control of the cylinder mould, cylinder mould vacuum pump, and filtrate tank is clearly beyond MACT I. Why are these sources and the control of these sources to be included under MACT I.
12. EPA envisions that (HAP's) credits would not be provided from HAP reductions resulting from existing enforceable requirements. What are those "existing requirements"?
13. What is the specified date EPA would consider providing HAP credits from past voluntary actions?
14. What is EPA's methodology and calculation procedures for equivalency and trading of HAP emissions reductions?
15. What are the compliance assurance monitoring requirements specified in the MACT standard and defined by the Clean Air Act general provisions. Weyerhaeuser requests a copy if we are expected to comply with them.
16. What are the start up, shut down, and malfunction requirements defined by the MACT standard?

LIST OF LEGAL QUESTIONS