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Weyerhaeuser Company

Weyerhauser Company: Public Comments on Draft FPA

Public Comments on Weyerhaeuser FPA

Sanford D. Bishop, Jr. Committee on Agriculture

Second District Georgia Subcommittees:

Democratic____at-Large Risk Management and Specialty Crops

Washington: Department Operations, Nutrition

1632 Longworth Building and Foreign Agriculture

Washington, D.C. 20515-1032 CONGRESS OF THE UNITED STATES Committee on Veterans' Affairs

Phone: (202) 225-3831 HOUSE OF REPRESENTATIVES Subcommittee:

Fax: (202) 226-2203 WASHINGTON, D.C. 20515-1002 Hospitals and Health Care

November 13, 1996

Ms. Michele Glenn

Weyerhaeuser Project XL Lead


Waste Management Division - 10th Floor

100 Alabama Avenue, S.W.

Atlanta, GA 30303-3104

Dear Ms. Glenn:
We are writing in response to your request for comments on a draft Final Project Agreement (FPA) recently published in the Federal Register for a pilot project at the Weyerhaeuser Company's Flint River Operations mill in Oglethorpe, Georgia. This FPA has been developed as part of Project XL, which was initiated last year to "devise and test more flexible approaches that result in both better environmental results and reduced compliance costs."

We commend EPA, the state of Georgia, Weyerhaeuser and all affected stakeholders for their efforts to assure that this project succeeds in achieving both superior environmental performance and innovative regulatory approaches. Under the proposal, the Flint River Operations mill would produce demonstrably superior environmental results, including: significant reductions in waste water effluent volume; more stringent water pollution limits; reducing solid waste generation by approximately 7,500 tons per year; reducing raw water demand; and implementing an enhanced environmental management system. At the same time, the mill would be granted regulatory flexibility for certain programs under the Clean Air Act, including flexible approaches for PSD permitting and developing innovative approaches to controlling hazardous air pollutants.

We understand that this FPA has the support of numerous stakeholders, including EPA, the state of Georgia, Weyerhaeuser, the Lake Blackshear Watershed Association, the City of Oglethorpe, the City of Montezuma, the Macon Correctional Institution, and the Macon County Local Emergency Panning committee. As members of the Georgia Congressional delegation, we also want to register our support for this effort. EPA's Project XL initiative enjoys bipartisan support (including specific language in support of the program from the House Appropriations Committee), and we are pleased that one of the first CL proposals to be issued for public comment is happening in Georgia. We look forward to finalization of the agreement and successful implementation of this project.

Thank you for your consideration of our views.

Sincerely yours,

Sanford D. Bishop, Jr.

Sam Nunn

Sandy Chambliss

Nathan Deal

John Lewis

Cynthia McKinney

Bob Barr

Paul Coverdell

Newt Gingrich

Mac Collins

Jack Kingston

John Linder

Charlie Norwood


P.O. BOX 425

Office of Mayor 113 ________ STREET Telephone: (912) 472-6485


Michelle Glenn

Weyerhaeuser Project XL Lead

U.S. EPA, Waste Management Division, 10th Floor

Atlanta Federal Center

100 Alabama Avenue, S.W.

Atlanta, GA 30303

Dear Ms. Glenn:

In representing Oglethorpe, Georgia in the capacity of Mayor, I am in support of Weyerhaeuser's Flint River Project XL. My association with Weyerhaeuser goes back to when they located here in 1978. The Flint River Plant was constructed with the latest environmental compliance record and has been awarded on numerous times for their air and water quality. The Georgia Chamber of Commerce has recently awarded them to be the 1996 Water Protection Citizen of the Year.

I have been actively involved in the Weyerhaeuser's Flint River Operations XL Program since it began. Having to comply with EPA regulations in my business and with the city has made me acutely aware that while we need to protect the environment another method other than the strict 1, 2, 3 step method needs to be developed.

Since the Weyerhaeuser's Flint River Mill intends to continue going beyond their regulatory requirements, and as an incentive for their level of superior performance the benefits from this project will be continued superior environmental results.

We attest our support for this program.


Gerald B. Beckum






TELEPHONE: (912) 472-7021

FAX (912) 472-5643


Charles W. Allen, Chairman OFFICERS:

Marvin Joiner, Vice-Chairman

Glen Lee Chase, Member Roselyn H. Starling, Clerk

Richmond Felton, Member Jon L. Coogle, Attorney

Roosevelt James, Member November 13, 1996

Michelle M. Glenn

Weyerhaeuser Project XL Lead

U.S. EPA, Waste Division, 10th Floor

Atlanta Federal Center

100 Alabama Avenue, S.W.

Atlanta, GA 30303

Dear Ms. Glenn:

Weyerhaeuser's Flint River Operations is a good corporate citizen who has been located in Macon County since 1978. The plant employs about 450 persons from the Middle Georgia area and has an annual payroll of $20 MM. Yearly plant donations to the surrounding communities support United Way campaigns, Georgia Southwestern College, the Macon County Emergency Planning Commission, area Literacy Programs, Habitat for Humanity, and recreational programs, to mention a few. Flint River was constructed with state-of-the-art environmental equipment and regular investments have helped to keep the plant on the leading edge of technology in the pulp making industry. The plant has had an outstanding environmental compliance record and has been used to set environmental standards by the U.S. EPA. Georgia EPD for the pulp and paper industry. Based on this, I can see why Weyerhaeuser is the first forest products industry in the nation to be accepted into the XL program.

As part of the XL program, community stakeholders were invited to participate in the Final Project Agreement (FPA) development. Weyerhaeuser has worked with EPA, Georgia EPD, Georgia Pollution Prevention Assistance Division, Lake Blackshear Watershed Association, to develop this FPA. Weyerhaeuser's Flint River Mill intends to continue to perform beyond regulatory requirements by continuing to evolve Minimum Impact Manufacturing (a holistic approach to pollution prevention) intend to provide more flexible and cost effective processes for regulatory management. The anticipated benefits from this project include continued superior environmental results while improving the ability of the mill to meet customer demands.

On behalf of the Commissioners of Macon County, I have been actively involved in the development of the Final Project Agreement and concur with the level of regulatory flexibility in the FPA.

I feel that Weyerhaeuser's Flint River Operations plays a very important role in Macon County and I wholeheartedly support their request to be included in the Project XL Program.


Charles W. Allen








(202) 387-3500

FAX: 202-234-6049

November 14, 1996

Ms. Michelle M. Glenn

Weyerhaeuser Project XL Head


Waste Management Division - 10th Floor

100 Alabama Avenue, S.W.

Atlanta, GA 30303-3104

Re: Comments on the draft Project XL Final Project Agreement developed for the Weyerhaeuser Flint River Operations pulp mill

Dear Ms. Glenn:

We appreciate the opportunity to comment on the draft Project XL Final Project Agreement developed for the Weyerhaeuser Flint River Operations pulp mill (referred to herein as the "Weyerhaeuser FPA"). While we support efforts to achieve superior environmental performance, engage the public, and reduce the burdens of complying with environmental regulations, certain conditions must be met in order for Project XL initiatives to credibly accomplish these purposes. Project XL proposals should demonstrate environmental leadership including mechanisms to:

extend meaningful opportunities to participate in environmental decisions to facility neighbors, workers, and others directly affected by pollution, and enhance