Weyerhaeuser Company

Proposed Relief/Pathway Document

Weyerhaeuser Company - PROJECT XL WATER
PROPOSED RELIEF	PATHWAY
1. No Effluent Color Limits	1. Modifying existing NPDES Permit to remove Color effluent limitation. Substitute less different monitoring than current requirement. Remove "Daily" and "24-Hour Outfall Composite" monitoring requirement from Part I.A.1 of NPDES Permit No. GA 0049336. Revise Part III.B.2 of the Permit to describe Instream Color measurement system.
2. Effluent Guidelines (Proposed) - No Effluent Color or Dioxin Requirements based on Cluster Rule.	2. Revised proposed Part 430 Subpart B, Bleached Papergrade Kraft and Soda Subcategory, to provide that a point source that is equipped with oxygen delignification and is a party to a Project XL Final Project Agreement covering bleach plant emissions at the source, shall comply with the terms of the FPA in lieu of the categorical standard for BAT. Insert, as new subparagraph (b) in proposed 40 C.F.R. 430.20 (p. 66195), the following. Any point source subject to a Project XL Final Project Agreement that covers wastewater discharges from the facility's bleach plant shall maintain such controls as are required by the Agreement in lieu of the categorical effluent limitations provided by 40 C.F.R. 430.24(a) or 40 C.F.R. 430.24(b), with respect to color. Renumber existing subparagraphs (b) and (c) to be (c) and (d), respectively.
3. Best Management Practices - No BMPs for Pulping Liquor based on Cluster Rule	3. Revised proposed 40 C.F.R. 430.03 (pp. 66189 - 66190) to provide that a point source that is a party to a Project XL Final Project Agreement covering liquor management practices at the source shall comply with the terms of the FPA and that measures provided under the FPA shall constitute best management practices at that facility. Insert a new sentence in proposed 40 C.F.R. 430.03(c) to provide: (c) Owners or operators of pulp, paper, or paperboard mills with pulp production in Subparts A, B, C, D, E, F, or H shall prepare and implement a Best Management Practices Plan, hereafter referred to as a "BMPs plan," for each mill on or before the compliance dates set out in this part. New sources must develop BMPs plans, and these plans must be incorporated in their NPDES permits prior to discharging. The BMPs plan shall contain the elements set out in, and be prepared in accordance with, 430.03(j). The BMPs plan shall be prepared within 120 days from the effective date of this part and shall be fully implemented within thirty months from the effective date of this part. Any point source subject to a Project XL Final Project Agreement that covers liquor management practices at the facility shall maintain such controls as are required by the Agreement in lieu of the categorical best management practices provided in this section. New language is underlined.
4. No Effluent Dioxin	4. Modify NPDES Permit to remove Dioxin effluent limitation based on nondetection in effluent. Remove "Dioxin (2,3,7,8-TCDD)" effluent limitation and monitoring requirement from Part I.A.2 of NPDES Permit No. GA 0049336.
5. No Fish Tissue Sampling	5. This requirement is tied to the Dioxin effluent limitation change.
6. Variable Effluent Discharge Limits	6. Continue seasonal effluent limits as in NPDES Permit No. GA 0049336.
7. Extend NPDES Permit Life	7. In order to streamline the NPDES current renewal process, include language for FPA as follows: Upon expiration of NPDES Permit No. GA 0049336 on August 31, 1997, Weyerhaeuser will not be required to submit any of the information required by Georgia Rules for Water Quality Control, Section 391-3-6-.06(5)(a)-(b). A new Permit will be issued after said expiration by the Georgia Environmental Protection Division (EPD) based on a certification from Weyerhaeuser that all effluent and other permit requirements are being met at the time of such application for a new permit.
8. No Additional Assimilative Capacity	8. This requirement for a study of the Flint River's assimilative capacity at time of NPDES renewal would be addressed by the language in No. 5 above.
9. No Nutrient Limits	9. The NPDES Permit was recently modified to drop N, P and TKN monitoring. Future Lake Blackshear WQ stds. could require new effluent limits for the mill. Include language in FPA as follows: No effluent limitations and/or requirements will be imposed on the mill for Nitrate/Nitrite as N; Total Phosphorus; and total Kjeldahl Nitrogen relating to nutrient loadings in the Flint River and Lake Blackshear, unless such requirements are demonstrated to be necessary by a future study involving both EPD and Weyerhaeuser.
10. No Fees Assessed on Effluent	10. Future legislation issue in Georgia.
11. Exempt Mill from Wastewater Treatment Plant Operator and Laboratory Analyst Requirements	11. Exempt Mill from the Rules (Chapter 750) of the Georgia State Board of Examiners for Certification of Water and Wastewater Treatment Plant Operators and Laboratory Analysts. This will avoid unnecessary time and expense for training that is not applicable to Weyerhaeuser's operation.

Weyerhaeuser Company - PROJECT XL SOLID WASTE
PROPOSED RELIEF	PATHWAY
1. Exempt from "No Free Liquids" requirement for landfilled materials.	1. Amend Solid Waste Permit 094-004D(L)(I) for the landfill (including a comparable amendment to the Design and Operational Plan) to allow certain liquid waste to be placed in the landfill as follows: Liquid Wastes may be placed in the landfill, even though said wastes contain "free liquids" under Method 9095 (Paint Filter Liquids Test).
2. Maintain exemptions as a private industrial landfill vs. municipal	2. This is current status, with request that Subtitle D landfill rules not be extended to this landfill. Future Georgia legislation issue as well.
3. No fee assessment on solid waste tonnage to onsite landfill	3. Future Ga. statutory/regulatory issue.
4. No mandated reduction percentages	4. Issue of implementation of current Ga. statute and rules, with some future implication as well.
5. Exempt forestry Land Application from agricultural Land Application requirements	5. Current Georgia Rules and guidelines do not recognize that the criteria which apply to the application of mill sludge and other wastes (e.g., lime mud) to forestry land should be less stringent than those applicable to materials land applied to agricultural land. Place language in FPA such as follows: Weyerhaeuser's materials which are to be land applied exclusively to forest land areas are not required to comply with Georgia Rules 391-3-6-.17 and accompanying Guidelines in order to be permitted under Rules 391-3-6-.11 or 391-6-6.19.
6. Provide for statewide application permit on forest lands	6. Weyerhaeuser can apply for a General Permit for a Land Application System under Georgia Rules 391-3-6-.19 which allows for multiple land application activities in a defined geographic area. This general permit rule only became effective on September 19, 1995.

Weyerhaeuser Company - PROJECT XL WATER USE
PROPOSED RELIEF	PATHWAY
1. Extend Surface and Groundwater Withdrawal Permit life	1. Current permit terms are 10 years for groundwater withdrawal and 17 years for surface water. Explore statutory change to allow for longer permit terms or in the alternative, follow No. 2 below.
2. Exemption from mandated water conservation planning and usage impact studies	2. To obtain flexible interpretation of water use regulations applicable to the mill, add language to FPA as follows: Based on current mill water use and water conservation practices, Georgia will not impose any additional water conservation or usage impact requirements on the mill, unless so required by legislation enacted after the effective date of this agreement.

Weyerhaeuser Company - PROJECT XL EMERGENCY PLANNING AND SPILL CONTROL
PROPOSED RELIEF	PATHWAY
1. Eliminate SPCC Plan	1. EPA Rules require SPCC Plan. Flexible interpretation and/or variance needed to eliminate paperwork, updates and staff that are costly and without substantive impact. Longer term view related to ISO 14000. Add language to FPA as follows: Based on the documented emergency planning and spill control procedures described in Attachment __ to this Agreement, Weyerhaeuser is not required to comply with the requirements of 40 C.F.R. Part 112.
2. Maintain existing storm water discharge requirements.	2. Currently addressed in NPDES permit. Add language to FPA as follows: Weyerhaeuser shall not be required to prepare a Storm Water Pollution Prevention Plan nor receive a permit for its storm water discharge other than NPDES Permit No. GA 0049336.

Weyerhaeuser Company - PROJECT XL HAZARDOUS WASTE
PROPOSED RELIEF	PATHWAY
1. Removal from Ga. HSI List	1. Provide for the following in the FPA: Hazardous Site Inventory Site Number 10013 is removed from the Hazardous Site Inventory pursuant to Georgia Rules 391-3-19-.05(4).
2. No Hazardous Waste Fees	2. For offsite hazardous waste disposal there is a $100 annual fee required for the mill, because it is a small quantity generator. If the mill becomes a conditionally exempt small quantity generator then they are exempt from all hazardous waste fees. There is a future Georgia legislative issue as to onsite hazardous waste handling, such as characteristically hazardous wastewater going into an elementary neutralization unit, becoming subject to fees.
3. Land Disposal Restrictions -- LDR rules do not apply to Wastewater Treatment System (WWTS)	3. Interpret "elementary neutralization system" (40 C.F.R. 260.10) to cover process at Flint to neutralize acidic and caustic wastewaters prior to discharge to the surface impoundments. Include in FPA language accepting process chemical spill management/removal system at Flint as adequate (in the abstract) to be covered under the heading of immediate response to a discharge of materials which may be hazardous waste when discharged and, thus, excluded from RCRA permitting requirements. See, 40 C.F.R. 270.1(c)(3).

Weyerhaeuser Company - PROJECT XL

AIR

PROPOSED RELIEF

PATHWAY

1. MACT (proposed) - No MACT VOC collection/ incineration requirement.

1. Revise proposed Pulp, Paper and Paperboard NESHAP, Part 63, Subpart S, to provide that a source (as defined by the proposed standard) that is equipped with oxygen delignification and is a party to a Project XL Final Project Agreement covering HAP emissions from pulping, bleaching and process wastewater components at the source, shall comply with the terms of the FPA in lieu of the categorical MACT standard.

(a) Applicability to pulping component, proposed 40 C.F.R. 63.444(a) (p. 66176).
Add, after subparagraph (3),

Any source subject to a Project XL Final Project Agreement that covers HAP emissions from the source's pulping component shall maintain such controls as are required by the Agreement in lieu of additional or alternative measures otherwise required by this section.(b) Applicability to bleaching component, proposed 40 C.F.R. 63.445 (p. 66177)

Add new paragraph (b) as follows:

Any source subject to a Project XL Final Project Agreement that covers HAP emissions from the source's process wastewater component shall maintain such controls as are required by the Agreement in lieu of additional or alternative measures otherwise required by this section.

Renumber existing paragraph (b) to be paragraph (c).

(c) Applicability to process wastewater component, proposed 40 C.F.R. 63.446 (p. 66,177-8)
Add new subparagraph (a)(4) as follows:

Weyerhaeuser Company

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