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epa wants more TCF info (cluster rule)
I fired off this message to Sodra Cell a few minutes ago. Sodra Cell is
Europe's largest producer of chemical pulp. They have moved to ~70% TCF
production. They are *very* aggressivly marketing their TCF line of pulp,
so it is a bit difficult to decide whether they are really a "good guy" or
if that is just the image they are trying to create.
I do not have time to persue this more fully.
I have no idea how Steve as a person or Sodra Cell as a company will react
to my request. It might be a very good idea if someone would write to Sodra
Cell and request exactly the information tha the EPA wants and then forward
the info to the EPA rather than relying on Sodra Cell to do it.
I'm not too sure that Sodra Cell wants to actively encourage competition on
this side of the Atlantic.
Sodra Cell's contact information follows:
I have corresponded with Steve Moldenius (Technical Director) in the
technical department
MAIL: Sodra Cell, S-375 22 Morrum, Sweden
TECHNICAL DEPARTMENT MAIL: Sodra Cell Technical Department, S-375 86 Morrum,
Sweden
PHONE: + 46 454 550 00
FAX: + 46 454 516 51
E-MAIL for Steve Moldenius: steve.moldenius@cell.sodra.se
>To: Steve Moldenius
>From: Maine People's Alliance <mpa@biddeford.com>
>Subject: epa wants more TCF info (cluster rule)
>
>Perhaps you could supply some of the information that the US EPA is asking
for in the memo that I have included below.
>
>First I should ask, do you activly support Kraft mills worldwide going TCF
or are you more intested in maintaining a tight hold on the TCF market?
>
>If you do not have a problem (as a corporation) advocating for regulatory
standards that would push other mills to TCF production then I would greatly
appreciate it if you would take some time to consider what information the
US EPA is looking for and provide them with whatever pertinent information
you have on hand.
>
>The US EPA is still taking the position that full brightness TCF pulp and
paper production is technologically infeasible. Sodra Cell is living,
breathing, black-bottom-line proof that that is not true.
>
>
>
>>Date: Tue, 16 Jul 1996 09:47:13 -0400 (EDT)
>>Errors-To: dioxin-l-owner@essential.org
>>Reply-To: cmcr@ism.net
>>Originator: dioxin-l@essential.org
>>Sender: dioxin-l@essential.org
>>From: cmcr@ism.net (Cold Mountain, Cold Rivers)
>>To: Multiple recipients of list <dioxin-l@essential.org>
>>Subject: epa wants more TCF info (cluster rule)
>>X-Listprocessor-Version: 6.0c -- ListProcessor by Anastasios Kotsikonas
>>
>>pls read the sentence i've copied in CAPS below, it's a p'graph from
>>yesterday's FR notice announcing epa's likely intentios (big suprise, yeah
>>right) to adopt either no advanced delignification + 100% ClO2
>>substitution, or advanced delignification + same as BAT for kraft pulp
>>mills (personally, i don't see how the 1st option possibly can be BAT when
>>~200 mills worldwide have abandoned the standard delig. for advanced delig,
>>but anyhoo..)
>>
>>**if you have any data, or know of a good contact regarding european tcf
>>mills (incl. markets for tcf paper as well as pollution data) _please_ use
>>the info below to get their comments in to epa by 14 august. **
>>
>> [snip]
>>This notice presents EPA's preliminary analysis of data pertaining to
>>Option A and compares it to Option B. In addition to obtaining and
>>analyzing data pertaining to Options A and B, the Agency also has
>>endeavored to obtain and analyze additional data for TCF process
>>technologies as a possible BAT technology. TCF technologies typically
>>incorporate OD while relying on peroxide and/or ozone, rather than
>>chlorine-containing compounds, to accomplish pulp bleaching and
>>brightening. Only one U.S. bleached papergrade kraft mill employs a TCF
>>process, and it produces a market pulp of somewhat less than full market
>>pulp brightness. Since proposal of this rule, the U.S. bleached papergrade
>>kraft TCF mill has achieved higher brightness targets, but still less than
>>full market brightness pulp of approximately 90 ISO. EPA obtained bleach
>>plant performance data from this mill, but because the mill discharges to
>>territorial seas under Section 301(m) of the Clean Water Act and thus does
>>not employ secondary treatment, end-of- pipe data reflecting the
>>performance of biological treatment were not available. European TCF mills
>>have achieved at or near full market brightness pulps for limited periods.
>>HOWEVER, EPA CONSISTENTLYREQUESTED BUT OBTAINED ONLY LIMITED PROCESS AND
>>POLLUTANT REMOVAL PERFORMANCE DATA FOR TCF MILLS IN EUROPE. The limited
>>range of papergrade TCF products currently produced and sold in the U.S.
>>market indicates that TCF technology is not yet available to make the full
>>range of products produced by ECF or similar chlorine-based processes.
>>Nonetheless, EPA continues to strongly encourage further development and
>>implementation of TCF technologies and products. It is also probable that
>>all TCF mills would qualify for the advanced technology incentives program
>>described below; this should provide an opportunity to stimulate
>>production and U.S. market share for TCF products.
>>
>> [snip]
>>
>>[Federal Register: July 15, 1996 (Vol.61, Number 136)] [Proposed Rules]
>>[Page 36835-36858]
>>40 CFR Parts 63 and 430 [FRL-5535-5] RIN 2060-AD03 and
>>2040-AB53
>>
>>Effluent Limitations Guidelines, Pretreatment Standards, and New Source
>>Performance Standards: Pulp, Paper, and Paperboard Category; National
>>Emission Standards for Hazardous Air Pollutants for Source Category: Pulp
>>and Paper Production; Availability
>>
>>AGENCY: Environmental Protection Agency (EPA). ACTION: Notice of
>>availability.
>>-----------------------------------------------------------------------
>>SUMMARY: On December 17, 1993, EPA proposed standards to reduce the
>>discharge of water pollutants and emissions of hazardous air pollutants
>>from the pulp, paper, and paperboard industry (58 FR 66078). This document
>>describes the Agency's goals for environmental improvement in this
>>industry, announces a framework for the final wastewater standards, and
>>presents the preliminary results of detailed analyses for a portion of this
>>industry.
>>
>>DATES: Comments on this notice are solicited and will be accepted until
>>August 14, 1996. Comments are to be submitted in triplicate, and also in
>>electronic format (diskettes) if possible.
>>
>>ADDRESSES: Comments are to be submitted to Mr. David Hoadley at the
>>following address: Engineering and Analysis Division (4303), EPA, 401 M
>>Street, SW., Washington, DC 20460. The framework and preliminary results
>>of detailed analyses being announced today are based on data and
>>information in the EPA Water Docket at EPA Headquarters at Waterside Mall,
>>room M2616, 401 M Street, SW, Washington, DC 20460, telephone (202)
>>260-3027. The Docket staff requests that interested parties call for an
>>appointment before visiting the Docket. A reasonable fee may be charged for
>>copying.
>>
>>FOR FURTHER INFORMATION CONTACT: For questions regarding wastewater
>>standards, contact Mr. Donald Anderson at the following address:
>>Engineering and Analysis Division (4303), EPA, 401 M Street, SW.,
>>Washington, DC 20460, telephone number (202) 260-7189, or Mr. Ronald Jordan
>>also at this address, telephone number (202) 260-7115. For questions
>>regarding air emissions standards, contact Ms. Penny Lassiter, Emissions
>>Standards Division (MD-13), U.S. Environmental Protection Agency, Research
>>Triangle Park, NC 27711, telephone number (919) 541-5396.
>>
>>Contents of This Notice
>>
>>I. Summary of Notices for this Regulation
>>II. EPA's Long-Term Environmental Goals
>>III. Anticipated Schedule for Issuing Final Wastewater Standards
>> A. Schedule for Proposed Bleached Papergrade Kraft and Soda and
>>Proposed Papergrade Sulfite Subcategories
>> B. Scheduled for Proposed Dissolving Kraft and Dissolving Sulfite
>>Subcategories
>> C. Schedule for the Remaining Proposed Subcategories
>>IV. Post-Proposal Data Gathering
>>V. Regulatory Framework and Preliminary Results
>> A. Proposed Bleached Papergrade Kraft and Soda Subcategory
>> 1. Preliminary Conclusion Regarding Technology Basis for BAT
>> 2. Incentives for Further Environmental Improvements
>> 3. Technology Options for BAT
>> 4. Framework for PSES
>> 5. Pollutant Parameters
>> 6. Best Management Practices
>> 7. Costs for Options A and B
>> 8. Effluent Reduction Benefits
>> 9. Revised Effluent Limitations
>> a. Changes to Statistical Methodology
>> b. Revised Effluent Limitations Being Considered
>> 10. Conventional Pollutant Limitations (BPT and BCT)
>> 11. Technology Options for NSPS
>> 12. Revised Economic Impact Results
>> a. Revisions to the Economic Analysis
>> b. Economic Impacts of BAT Options A and
>> c. Cost-Effectiveness
>> B. Proposed Papergrade Sulfite Subcategory
>> 1. Preliminary Conclusions Regarding Technology Basis for BAT
>> 2. Technology Options for BAT
>> 3. Costs
>> 4. Effluent Reduction Benefits
>> 5. Revised Effluent Limitations for BAT and PSES
>> 6. Conventional Pollutant Limitations
>> 7. Technology Options and Revised Effluent Limitations for NSPS
>> 8. Economic Impacts
>> a. Costs and Impacts
>> b. Cost-Effectiveness
>>VI. Environmental Assessment
>>VII. Best Management Practices
>>VIII. Pretreatment Standards
>>IX. Implementation Issues
>> A. Permit Limits for Multiple Subcategory Mills
>> B. New Sources
>> C. Monitoring
>> D. BMPs as NPDES Permit Special Conditions
>> E. Relationship Between the Cluster Rules and Project XL
>> F. Summary of Changes to Methods for Analysis of Pulp and Paper
>>Industry Wastewaters
>> 1. Method 1624, Volatiles by Purge-and-Trap and Isotope Dilution GC/MS
>> 2. Method 1650, AOX by Adsorption and Coulometric
>> 3. Method 1653, Chlorophenolics by In-Situ Derivatization and Isotope
>>Dilution GC/MS
>> 4. Method NCASI Technical Bulletin No. 253, Color
>> G. Regulatory Flexibility Analysis
>>X. Incentives for Further Environmental Improvements
>> A. Advanced Technology Tiers
>> 1. Definition of Incentives-Related BAT Limitations or NSPS by Tier
>> a. Tier I BAT Limitations
>> b. Tier II BAT Limitations and NSPS
>> c. Tier III BAT Limitations and NSPS
>> 2. Basis for Incentives-Related BAT Limitations and NSPS
>> 3. Legal Authority to Establish Incentives-Related BAT Limitations and
NSPS
>> B. Incentives Available Prior to Achievement of Incentives-Related BAT
>> 1. Extended Compliance Schedules
>> C. Incentives Available After Achievement of Advanced Technology BAT
>>Limitations and NSPS
>> 1. Greater certainty regarding permit limits and requirements
>> 2. Reduced effluent monitoring
>> 3.Reduced penalties
>> 4. Reduced inspections
>> 5. Public recognition programs
>> 6. Fast-track permit modification
>> D. Solicitations of Comments on Incentives Program
>> E. Alternative Incentives Programs and Provisions Suggested by
Stakeholders
>>
>>Tony Tweedale || "I'm not going to get involved in any
>>Bx 7941 || of that peer-reviewed mumbo-jumbo."
>>Missoula, Montana 59807 || -Rep. John Doo<-->little (R-CA)
>>406-542-1709, fax 728-0867 ||
>>cmcr@ism.net || " 'Are the people being protected?' is too
>>(Cold Mountain, Cold Rivers || narrow a question."
>>@ Internet Services of MT) || -API lobbyists meeting, 12 Dec. '96
>> ----------------------------------------
>>
>>
>>
>>
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