
                      UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                          SECTOR POLICIES AND PROGRAMS DIVISION
                       OFFICE OF AIR QUALITY PLANNING AND STANDARDS
                               OFFICE OF AIR AND RADIATION


December 14, 2011

MEMORANDUM

SUBJECT:	Meeting notes for the September 26, 2011 meeting with Sierra Club and Earth Justice 
	
FROM:	Kelley Spence	
      John Bradfield
		
TO:		Docket EPA-HQ-OAR-2007-0544


This memorandum summarizes the meeting between Sierra Club and Earth Justice and the EPA on September 26, 2011.  This meeting was requested in response to the Risk and Technology Review (RTR) of the National Emission Standards for Hazardous Air Pollutants (NESHAP) for the pulp and paper industry. 

Meeting Attendees:
	
John Bradfield, EPA				Scott Jordan, EPA
Emma Cheuse, Earth Justice			Marguerite McLamb, EPA
Robin Dunkins, EPA				Bill Schrock, EPA
Chuck French, EPA				Kelley Spence, EPA
Eric Ginsburg, EPA				Jane Williams, Sierra Club	

Discussion Points:
	
* Progress report: Pulp and Papermaking RTR (Subpart S)
         o          Approximately 350 surveys were distributed (ICR)
         o          100% response rate
         o          Recent focus has been on the QC of the Part 2 database (NEI Update)
         o          Risk modeling (input file preparation)
         o          Schedule (management reviews in the next month)
* Outreach commitments and Environmental Justice
         o          Collected excess emission reports from states
         o          EJ/Community group outreach (national community call, state and region community calls and contacts) 
         o          Demographic analysis using the risk model will determine if any EJ communities are affected by industry
         o          Earth Justice requested list of facilities and groups contacted (EPA sent 10/12/11)
         o          Tribal brochures were mailed to tribes  -  2 were interested in Pulp and Paper (EPA sent 3/15/11)
* Individual HAP data
         o          Discussion of regulating HAPs individually
         o          Discussion of control device outlet measurements instead of assuming a % reduction in emissions
* Site visits
         o          Picked facilities for specific reasons (facility age, processes at the facility, etc.)
         o          Interesting fact: one of the facilities had completely redone their kraft mill in response to the original NESHAP
* Other questions and concerns
         o          Only addressing Subpart S on December 15[th] 
         o          Notice of the RTR be published on the national EJ list serve
         o          Concerns regarding risk at malfunction and compliance margins
         o          Discussion of monitoring data and Title V permits 
         o          Concerns regarding fugitive emissions and unregulated emission points
