United States
                Environmental Protection
                Agency
                               Office of Reinvention
                               Washington, DC 20460
                               Mail Code 1802
                      EPA/1 OO/F-99/004
                      March 1999
                      www.epa.gov
                XL  Project Progress  Report
                Weyerhaeuser Flint  River  Operations
^ •
On March 16,1995, the Clinton Administration announced a portfolio of reinvention initia-
tives to be implemented by the U.S. Environmental Protection Agency (EPA) as a part of its
efforts to achieve greater public health and environmental protection at a more reasonable
cost. Through Project XL, which stands for excellence and Leadership, EPA enters into
specific proj ect agreements with public or private sector sponsors to test regulatory, policy,
and procedural alternatives that will produce data and experiences to help the Agency make
improvements in the current system of environmental protection. The goal of Proj ect XL is to
implement 50 proj ects that will test ways of producing superior environmental performance
with improved economic efficiencies, while increasing public participation through active
stakeholder processes. As of October 1998,10 XL projects are in the implementation
phase and 20 XL projects are under development. Project XL Progress Reports provide
proj ect-specific overviews of the status of individual XL proj ects that are implementing Final
Project Agreements (FPAs). The progress reports are available on the Internet via EPAs
Project XL web site at http://www.epa.gov/ProjectXL. Or, hard copies may be obtained by
contacting the Office of Reinvention's Project XL Docket at 202-260-7434. General
information on Proj ect XL is available on the web site or by contacting the general informa-
tion number at 202-260-5754.

Background

Weyerhaeuser Company is one of the largest private owners of forest, with 5.4 million acres
in the United States.  Among its products are timber, paper, and pulp. Weyerhaeuser's Flint
River pulp manufacturing facility in Oglethorpe, Georgia, manufactures 320,000 tons per
year of absorbent fluff pulp used in diapers. The facility was opened in 1981 and is located
100 miles southwest of
Atlanta, Georgia.
Weyerhaeuser is striving to
minimize the environmental
impact of its manufacturing
processes on the Flint River
and the surrounding environ-
ment by pursuing a long-term
vision of a Minimum Impact
                                                                             Weyerhaeuser XL Project
                                                                             Oglethorpe, Georgia
    Major Milestones
     Septembers, 1995
     Weyerhaeuser XL
     Proposal Submitted
                 January 17, 1997
               Final Project Agreement
                     Signed
 January 28, 1998
   First Annual
Stakeholders Meeting
Montezuma, Georgia
       2006
Final FPA Commitments
     to be Met

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Weyerhaeuser XL Project                                                                  (3-31-991
  Mill. Through a combination of enforceable requirements and voluntary goals, the Weyerhaeuser XL project
  will improve the health of the nearby Flint River and surrounding watersheds by:
  •  Cutting bleach plant effluent by 50% over a 10-year period;
  *  Reducing water usage by 1 million gallons a day;
  •  Cutting solid waste generation by 50% over a 10-year period;
  «  Preparing and implementing a facility-wide plan to reduce energy use;
  •  Reducing the generation of hazardous waste to a level where the facility can qualify as a conditionally
     exempt small quantity generator;
  «  Maintaining criteria air pollutant emissions at levels below facility-wide emission caps;
  •  Preparing and implementing a site-specific alternative compliance plan for hazardous air pollutant emissions;
  «  Improving forest management practices in over 300,000 acres of land; and
  *  AdoptinglSO 14001, an international standard that defines the elements of a continually improving envi-
     ronmental management system.



  The Weyerhaeuser XL project establishes a long-term plan to continuously reduce the mill's impact on air,
  water, land, and the surrounding watersheds. As an incentive to achieve superior environmental performance
  at Weyerhaeuser's Flint .River facility, EPA and the Georgia Environmental Protection Division (EPD) will
  provide more flexible and cost-effective processes for regulatory compliance. Regulatory flexibility is being
  offered in the areas of environmental performance reporting, effluent permitting, air quality permitting, hazard-
  ous air pollutant compliance, and solid waste permitting.
  The statutory programs, and EPA offices administering those programs, that affect the Weyerhaeuser XL
  project are:
  *  Clean Water Act (CWA) programs administered by the EPA's Office of Wastewater Management and
     EPA's Office of Wetlands, Oceans, and Watersheds;
  •  Resource Conservation and Recovery Act (RCRA) programs administered by the EPA's Office of Solid
     Waste;
  •  Clean Air Act (CAA) programs administered by the EPA's Office of Air Quality Planning and Standards;
     and
  *  Pollution Prevention Act (PPA) programs administered by the EPA's Office of Prevention, Pesticides, and
     Toxic Substances.
  All permitting programs required to implement the Final Proj ect Agreement have been delegated by EPA to
  the State of Georgia. Permits are issued by Georgia EPD.
  Reporting. EPA Region 4 and the Georgia EPD are allowing Weyerhaeuser the flexibility to consolidate some
  of the facility's routine permitting reports into two reports per year. These reports are available on EPA's XL
  Homepage (http://yosemite.epa.gov/xl/xl_home.nsf/all/homepage).
  Effluent Permitting. EPA Region 4 and Georgia EPD have revised Weyerhaeuser's National Pollution
  Di scharge Elimination System (NPDES) permit to include more stringent effluent limits on biological oxygen
  demand (BOD), total suspended solids (TSS), and adsorbable organic halides (AOX); streamline the permit
  renewal process; eliminate fish tissue sampling requirements due to improvements in process technologies that

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 Weyerhaeuser XL Project                                                                  [3-31-991
have eliminated detectable dioxin level s in effluents; remove a requirement for additional assimilative capacity
studies; and allow annual compliance certification in lieu of periodic discharge monitoring reporting (DMR) due
to the company's 10-year history of meeting all required discharge levels.

Air Qualify Permitting. EPA Region 4 and Georgia EPD have modified the facility's existing air quality permit
to include dual emission caps for air pollutants. The caps reduce allowable air emissions by 60%. The dual
emission caps are: 1) a cap that allows the recovery furnace, smelt dissolving tank, calciner, and combination
boiler (the facility's four major sources of emissions) to be operated to their design capacity without triggering
permit review; and 2) a cap covering all facility sources except those four major sources. Thedual emission
caps apply to particulate matter, sulfur dioxide (SO,), nitrous oxides (NOx), carbon monoxide (CO), volatile
organic carbons (VOCs), and total reduced sulfur (odor causing pollutant). The modified air quality permit
streamlines the permit renewal process, includes alternate excess emi ssion reporting protocol s, and includes a
protocol for conducting manufacturing process experiments without triggering a permit review.

Hazardous Air Pollutant Compliance. EPA Region 4 and Georgia EPD have agreed to provide
Weyerhaeuser the flexibility to demonstrate hazardous air pollutant (HAP) emission reductions using innovative
pollution prevention approaches rather than end-of-pipe HAP controls. Weyerhaeuser will prepare an alterna-
tive compliance plan that will present the HAP emission reductions to be achieved by the facility following
promulgation of the Maximum Available Control Technology (MACT) Cluster Rule for the pulp and paper
industry.
Solid Waste Permitting. EPA Region 4 and Georgia EPD will modify Weyerhaeuser's solid waste permit to
allow nonhazardous industrial wastes containing free liquids to be di sposed of in a permitted, onsite landfill.

                               ail

Project XL provides EPA opportunities to test and implement approaches that protect the environment and
advance collaboration with stakeholders. EPA is continually identifying specific ways in which XL projects are
helping to promote innovation and system change. The innovations and system  changes that have emerged from
the Weyerhaeuser XL project are described below:
Pulp and Paper Cluster Rules. The Weyerhaeuser XL proj ect provides a pilot for testing alternative compli-
ance approaches to the new MACT standard portions of the Pulp and Paper Cluster Rules (promulgated on
April 15,1998). Weyerhaeuser will have the flexibility to control hazardous air pollutants through pollution
prevention approaches rather than end-of-pipe control measures.
Consolidated Reporting. The Weyerhaeuser XL project allows the facility to consolidate reporting for some
of the Federal, state, and local permitting and regulatory programs that apply to the facility into two compre-
hensive reports each year. The proj ect tests an approach to streamlining both permitting and the collection of
higher quality information from regulated industries. The project will influence development of the comprehen-
sive information management plan to be prepared by the EPA's new consolidated Environmental Information
Office.
Dual Emissions Caps. The Weyerhaeuser XL proj ect provides for dual emissions caps that limit facility-wide
emissions to levels 60% below those that would be required under a standard permitting scheme. In return,
Weyerhaeuser can change equipment operating conditions to respond to customer needs without triggering
permit reviews as long, as the lower cap is not exceeded.

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Weyerhaeuser XL Prelect
                                       (3-31-99)
 NPDESPermitting. Weyerhaeuser's NPDES permit has been revised to include more stringent effluent limits
 on biological oxygen demand, total suspended solids, and adsorbable organic halides. In return, Weyerhaeuser:
 1) is not required to conduct fish tissue sampling requirements because improvements in process technologies
 have eliminated detectable dioxin level s in effluents; 2) i s not required to conduct additional assimilative capacity
 studies of the Flint River; and 3) can provide an annual certification of compliance instead of periodic discharge
 monitoring reporting due to the company's 10-year history of meeting all required discharge levels.
 Comprehensive Environmental Management System. Weyerhaeuser will voluntarily institute an environmental
 management system at the Flint River facility that conforms to the International Organization for Standardization
 (ISO) 14001 standard. The facility is developing a comprehensive manual of standard work procedures for
 plant employees. As announced in the Federal Register on March 12,1998, EPA is evaluating options that will
 lead to development of an EPA policy on Environmental Management Systems (EMSs). The Weyerhaeuser XL
 proj ect will provide data on the compliance and environmental benefits of EMS approaches.



 This section summarizes proj ect commitments described in the FPA for Weyerhaeuser' s Flint River facility in
 Georgia The facility has completed Phases I. II, and III of its environmental management plans.
   Commitment
  Status
                      Minimum Impact Mill Phase IV Implementation Schedule
  Construct isothermal cooking (brownside
  optimization) equipment
Construction and process optimization were
completed in 1997.
  Upgrade odor control system
Construction and process optimization were
completed in 1996.
  Reduce energy steam use
Construction and process optimization were
completed in 1997.
  Revise existing EMS to conform to ISO 14001 EMS
  (nonenforceable), including operational procedures,
  record keeping, auditing, quality assurance, and
  permit requirements.
The process of ISO 14001 documentation originally
was scheduled to be completed in mid-1997. It has
proceeded slower than expected and now is sched-
uled to be completed and implementation to begin in
June, 1999.
                          Minimum Impact Mill Phase V Feasibility Studies
  Conduct feasibility studies for reducing solid waste
  generation through source elimination, by-product
  reuse, and energy recovery.
A compost using facility by-products that i s suitable
for land application has been produced; a summer
composting study is underway; and a small-scale land
application study is scheduled for the fall of 1998.
  Conduct an energy conservation study to identify
  potential conservation practices and prepare a long-
  term energy conservation plan to reduce plant energy
  demand and power boiler steaming rates.
Three small-scale energy conservation projects have
been completed (product unit condensate return to
boiler feedwater system, evaporator condensate
return to recaust area, and recovery boiler secondary
temperature reduction). A fourth small-scale project
is on hold pending results of a facility-wide energy
conservation study. The energy conservation study is
scheduled to be completed in December, 1998.

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Weyerhaeuser XL Project
13-31-991
Commitment Status
Minimum Impact Mill Phase V Feasibility Studies (continued)
Conduct studies of mill water use to reduce the
quantity of treated wastewater discharged into the
river.
Conduct feasibility studies, including studies of water
use, process elements, finished product quality, and
multimedia impacts, to determine how to reduce the
volume of bleach plant effluent flow.
Conduct HAP emission reduction feasibility studies to
identify pollution prevention approaches for achieving
HAP emission reductions.
Implement timberland resource strategies in over
300,000 acres of forest to designate forest buffers,
minimize erosion caused by roads, improve streamside
management, develop water bars to stabilize soils,
safeguard unique habitats, implement landscape
planning, establish wildlife corridors, and protect
threatened/endangered species.
Feasibility studies to reuse excess machine water,
partially replace flume water, and reuse cooling water
are expected to be completed by the end of March,
1999.
A series of bleach plant effluent reduction studies are
scheduled to be conducted from 1998 through 2003 .
An ultrafiltration pilot test proj ect is underway at
another Weyerhaeuser facility.
The schedule for conducting feasibility studies will be
detailed in Weyerhaeuser's MACT alternative
compliance plan.
Documentation and implementation of timberland
resource strategies was completed in the fall of 1 997.
Water
Reissue NPDES permit to provide more stringent
effluent limits for BOD, TSS, and AOX, streamline
permit renewal process, remove fish tissue sampling
requirement, remove requirement for additional
assimilative capacity study, allow annual compliance
certification in lieu of DMR reporting.
Modify surface water withdrawal permit to reduce
daily maximum withdrawal limits by 1 .0 million gallons
per day (MOD).
The NPDES permit was revised in July, 1 997.
The surface water withdrawal permit was scheduled
to be modified on January 1 , 1 998, but has been
delayed.
Solid Waste
Modify solid waste permit to allow nonhazardous
industrial wastes containing free liquids disposal into
permitted onsite landfill. Weyerhaeuser will continue
stormwater and leachate treatment and quarterly
ground water monitoring.
Permit modifications are expected during the second
half of 1998.
Hazardous Waste
Reduce the generation of hazardous wastes to a level
where the facility can qualify as a conditionally exempt
small quantity generator.
Designation as a conditionally exempt small quantity
generator was achieved in 1997 by recycling and
reusing a solvent (methyl ethyl ketone) used for
cleaning painting equipment.

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Weyerhaeuser XL Prelect
(3-31-99)
Commitment | Status
Air
Modify the facility's air quality permit to include dual
emissions caps, streamline the permit renewal
process, include alternate excess emission reporting
protocols, include alternate compliance testing
protocol, and include an experimental trials protocol
that will nottriggering permitting.
Revise Flint River's Title V permit to defer permit
modifications for activities undertaken pursuant to
XL proj ect until the permit comes up for renewal .
Prepare a site-specific MACT alternative compliance
pi an that will detail how Weyerhaeuser will reduce
HAP emissions to levels equal to or exceeding those
required under the MACT Cluster Rule.
The air quality permit was revised in December,
1997.
The permit was revised in December, 1997.
The MACT Cluster Rule for the pulp and paper
industry was promulgated in April 1998. EPA,
Georgia EPD, and Weyerhaeuser have met twice to
begin development of a site-specific MACT applica-
bility assessment. Upon approval of the applicability
assessment, Weyerhaeuser will prepare the MACT
alternative compliance plan
Reporting
Prepare annual reports for distribution to EPA, the
State of Georgia, and local stakeholders.
Prepare mid-year reports for distribution to EPA,
the State of Georgia, and local stakeholders.
Distribute data and reports to the public upon
request.
The first annual report was completed in January,
1998.
Mid-year reports have been completed for 1997
and 1998.
As needed.
Stakeholder Meetings
Conduct annual public meetings in January in the
vicinity of the Flint River facility.
The first annual stakeholders meeting was held in
Montezuma, Georgia on January 28, 1 998.

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 Weyerhaeuser XL Project
                                           13-31-991
This section summarizes Weyerhaeuser's progress in meeting environmental performance commitments de-
scribed in the FPA.
Rmv Water 'Usage: Reducing the facility's use of
water from the Flint River will reduce the quantity of
treated wastewater discharged back into the river.
Weyerhaeuser's goal is to reduce water withdrawal
from the Flint River to a voluntary limit of 10.18
million gallons a day (MGD) monthly average by
January 1,2000. Baseline water withdrawal at the
facility is 11.18 MGD monthly average. A study to
identify water reduction possibilities is in the plant's
technology plan for 1998. The facility's surface water
withdrawal permit was scheduled to be modified to
reduce enforceable withdrawal limits by 1.0 MGD, to
11.50 MGD monthly average, by January 1,1998.
Permit modification has been delayed.
                  Raw Water Useage
         1998YTD
        1987 Actual
        1996 Actual
      Voluntary Goal
          Baseline
(1993-95 monthly averages)
        Permit Goal
    Enforceable Permit
                                      11.40
                                           11.74
                                              11.91
                    10.18
                                                                                     11.18
                                       11.50
                                                      12.50
              10.00 10.25 10.50 10.75 11.00 11.25 11.50 11.75 12.00 12.25 12.50
                      (units in millions gallons per day)
Progress: The water reductions anticipated from modernization proj ects were not sufficient to offset increased
water usage from other facility process areas, which resulted in an increase to 11.74 MGD monthly average
for 1997. By mid-1998, water use was reduced to 1I.40 MGD monthly average through the daily water
conservation efforts of production operators. A feasibility study to reuse excess paper machine wastewater
was initiated in the fall of 1997. Reuse of this wastewater is expected to be completed by March 31,1999,
and recover approximately 1.0 MGD monthly average. Two other studies to partially replace flume water with
filtered water from other plant equipment and to reuse cooling water in the power boiler scrubber are expected
to be completed by March 31,1999.
                                                                                Bleach Plant Flow
                                                                     1998YTD
                                                                    1997 Actual
                                                                     FPA Goal
                                                                      by 2006
                             10.0
Bleach Plant Flow: Weyerhaeuser's long-term goal is to
reduce bleach plant effluent flow by 50% to 10 cubic meters
per air dried metric ton (ADMT) of finished product (fluff pulp
used to make diapers) by the year 2006. The environmental
benefits proj ected to be achieved include: 1) a two MGD
monthly average water-use reduction (bleach plant fl ow i s
approximately 48 to 49% of the total plant water usage); 2)
reductions in effluent BOD, TSS, and AOX; and 3) HAP
emission reductions. To reach its goal, Weyerhaeuser plans to
conduct feasibility studies on its management of water use. The
results of these studies will be used by EPA, the State of
Georgia, and Weyerhaeuser to negotiate a NPDES permit to
be issued in 2002. The permit will contain enforceable mea-
sures for reducing effluent flow to an agreed-upon level by 2006.
Progress: An ultrafiltration pilot test has been initiated at another Weyerhaeuser facility, the results of which
may be used to reduce bleach plant effluent flow at the Flint River facility. Bleach plant flow decreased in 1998
due to better process operation management and better measurement of bleach plant flows.
                                                                      Baseline
                                                           (1993-95 monthly averages)
                                                                                                         20.0
                                                                                                         20.0
                                                                                                         20.0
                                                                           9 10 11 12 13 14 15 16 17 18 19 20 21

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Weyerhaeuser XL Prelect
                                        (3-31-99)
  Biological Oxygen Demand (BOD) in Effluent:
  Weyerhaeuser has committed to reducing BOD
  levels in treated wastewater discharged to the Flint
  River. The facility's January 1998 NPDES permit
  allows the discharge of 3.8 pounds of BOD per
  ADMT of finished product.
  Progress: Weyerhaeuser has modernized several
  components of the pulping process, which has
  reduced the amount of organic materials in bleach
  plant wastewater. For every ton of finished product
  produced by Weyerhaeuser in 1998, the facility
  reduced BOD in its effluent to 2.01 pounds/ADMT
  (monthly average).
          1998YTD
         1996 Actual
          FPA Goal
       Effective 1-1-98

           Baseline
(1993-95 monthly averages)
                 Biological Oxygen Demand (BOD)
                1.5
                       2.01
                                  3.01
                                       3.52
                                                                                            3.80
                                                                                                 4.32
                     2.0
                          2.5   3.0   3.5
                           (units in Ibs/ADMT)
                                          4.0
                                               4.5
  Total Suspended       (TSS) in Effluent:
  Weyerhaeuser has committed to reducing TSS levels
  in treated wastewater discharged to the Flint River.
  The facility's January 1998 NPDES permit allows
  the discharge of 4.09 pounds of TSS per ADMT of
  finished product.
  Progress: Weyerhaeuser has modernized several
  components of the pulping process, which has
  reduced the amount of total suspended solids in
  bleach plant wastewater. For every ton of finished
  product produced by Weyerhaeuser in 1998, the
  facility reduced TSS in its effluent to 2.84 pounds/
  ADMT (monthly average).
          1998YTD
         1997 Actual
         1996 Actual
          FPA Goal
       Effective 1-1-98

           Baseline
(1993-95 monthly averages)
                     Total Suspended Solids
                                  3.58
                                                                                          4.09
                                                                                               4.65
                2.00     2.75     3.50     4.25
                           (units in Ibs/ADMT)
                                               5.00
  Adsor'bable Organic Halides (AOX) in Effluent:
  Weyerhaeuser has committed to reducing AOX levels
  in treated wastewater discharged to the Flint River. The
  facility's January 1998 NPDES permit allows the
  discharge of 0.15 kilograms of AOX per ADMT of
  finished product. This permit limit was agreed to in the
  FPA and is approximately 76% more stringent than
  the final Cluster Rule effluent guideline requirements.
         1998YTD
        1997 Actual
        1996 Actual
         FPA Goal
      Effective 1-1-98
                  Adsorbable Organic Halides
                                                              Baseline
                                                   (1993-95 monthly averages)
                                     0.10
                                                                                                 0.15
                                       0.11
                                                                   0.00
                                                                           0.04     0.08     0.12
                                                                               (units in kgs/ADMT)
                                                                                                  0.16
Progress: Weyerhaeuser has modernized several
components of the pulping process, which has
generally reduced levels of AOX in bleach plant
wastewater. The exception was 1997 to 1998,
when AOX levels increased to 0.13 kilograms/
ADMT (monthly average) of finished product, due to an increase in customer demand for high-brightness pulp,
which resulted in the facility altering its use of brightening chemicals in the bleach plant area.

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 Weyerhaeuser XL Project
                                13-31-991
Solid Waste Generation: Weyerhaeuser's FPA goal is to reduce the
1995 level of solid waste generation by 50% by the year of 2006.
Source elimination, by-product recycling and reuse, and by-product
energy recovery will be used to accomplish this goal. A feasibility
study for recovery of lime mud is scheduled for the year of 2002.

Progress: Weyerhaeuser has modernized several components of the
pulping process, which has generally reduced the amount of solid
waste generated by the plant. Feasibility studies are in progress on
composting facility by-products and applying the composted material
on timberlands. Increased solid waste generation in mid-1998 was
caused by decreased reliability in one step of the pulping process,
which resulted in higher lime mud solid waste generation.
     1997 Actual
     1996 Actual
      FPA Goal
       by 2006

       Baseline
     (1995 level)
                Solid Waste Generation
                         446
                      409
310
                             690
           300
                   400
                           500
                                   600
                                          700
Air Emissions of Particulate Matter: The facility's December
1997 air quality permit includes dual emission caps for air pollut-
ants. The dual emission caps are: 1) a cap encompassing the
recovery furnace, smelt dissolving tank, calciner, and combination
boiler, which are the facility's four maj or sources of emissions; and
2) a cap encompassing the entire facility except those four maj or
sources. The total cap on all emissions of particulate matter is 589
tons per year, which is a 60% reduction from the 1,472 tons per
year allowed under a standard permit.

Progress: The maintenance of air emissions to levels below the
new dual emission cap will be reported in Weyerhaeuser's 1998
annual report, scheduled to be completed in January, 1999.
                                                                              Particulate Matter
   1997 Actual
   1996 Actual
   Total Dual
 Emissions Cap
 Effective 12/97

Allowable Under
Standard Permit
         300
              385
               423
      589
                             1472
                540
                      780    1020
                        Tons/Year
                                   1260
                                         1500
Air Emissions of Total Reduced Sulfur: The facility's Decem-
ber 1997 air quality permit includes dual emission caps for air
pollutants. The total cap on all emissions of total reduced sulfur is
62 tons per year, which is a 60% reduction from the 155 tons per
year allowed under a standard permit.

Progress: The maintenance of air emissions to levels below the
new dual emission cap will be reported in Weyerhaeuser's 1998
annual report, scheduled to be completed in January, 1999.
    1997 Actual
    1996 Actual
    1995 Actual

     Total Dual
  Emissions Cap
  Effective 12/97

  Allowable Under
  Standard Permit
                 Total Reduced Sulfur
                    35
                     39
          62
                                                                                                       155
                                                                              30
                                                                                    60
                                                                                         90
                                                                                              120   150
                                                                                                         180
                                                                                       Tons/Year

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      Weyerhaeuser XL Prelect
                                      (3-31-99)
        Air Emissions of Sulfur Dioxide (SO): The facility's
        December 1997 air quality permit includes dual emission
        caps for air pollutants. The total cap on all emissions of
        SO2 is 879 tons per year, which is a 60% reduction from
        the 2,197 tons per year allowed under a standard permit.

        Progress: The maintenance of air emissions to levels
        below the new dual emission cap will be reported in
        Weyerhaeuser's 1998 annual report, scheduled to be
        completed in January, 1999. Emissions of SO2increased
        in 1.997 because steam energy conservation initiatives
        have reduced the power boiler steaming rate and furnace
        temperatures to a point where SCX is difficult to control.
    1997 Actual
    1995 Actual

     Total Dual
  Emissions Cap
  Effective 12/97

 Allowable Under
 Standard Permit
                    Sulfur Dioxide
                     624
587
    879
                     2197
                 500
                        1000
                              1500
                                     2000
                                           2500
                          Tons/Year
        Air Emissions of Nitrous Oxides (NOJ: The
        facility's December 1997 air quality permit includes dual
        emission caps for air pollutants. The total cap on all
        emissions of nitrous oxides is 1,300 tons peryear,
        which is a 60% reduction from the 3,250 tons per year
        allowed under a standard permit.

        Progress: The maintenance of air emissions to levels
        below the new dual emission cap will be reported in
        Weyerhaeuser's 1998 annual report, scheduled to be
        completed in January, 1999.
   1997 Actual
   1996 Actual
   1995 Actual

    Total Dual
 Emissions Cap
 Effective 12/97

Allowable Under
Standard Permit
                   Nitrogen Oxides
                769
                 832
                      3250
                                                                        500  1000  1500  2000  2500  3000  3500
                                                                                       Tons/Year
        Air Emissions of Carbon Monoxide (CO): The
        facility's December 1997 air quality permit includes dual
        emission caps for air pollutants. The total cap on all
        emissions of carbon monoxide is 2,516 tons peryear,
        which is a 60% reduction from the 6,290 tons per year
        allowed under a standard permit.

        Progress: The maintenance of air emissions to levels
        below the new dual emission cap will be reported in
        Weyerhaeuser's 1998 annual  report, scheduled to be
        completed in January, 1999.
   1997 Actual
   1996 Actual
   1995 Actual

    Total Dual
 Emissions Cap
 Effective 12/97

Allowable Under
Standard Permit
                                                                                Carbon Monoxide
                 1676
2516
                     6290
                                                                        1000  2000
                                                                                   3000  4000  5000
                                                                                       Tons/Year
                                                                                                   6000  7000
10

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 Weyerhaeuser XL Project
                               13-31-991
Air Emissions of Volatile Organic Carbon (VOC): The
facility's December 1997 air quality permit includes dual emission
caps for air pollutants. The total cap on all emissions of VOCs is
778 tons per year, which is a 60% reduction from the 1,945 tons
per year allowed under a standard permit.

Progress: The maintenance of air emissions to levels belowthe
new dual emission cap will be reported in Weyerhaeuser's 1998
annual report, scheduled to be completed in January, 1999. VOC
emissions increased in 1997 because steam energy conservation
initiatives have reduced the power boiler steaming rate and
furnace temperatures.
   1997 Actual
   1996 Actual
   1995 Actual
    Total Dual
 Emissions Cap
 Effective 12/97

Allowable Under
Standard Permit
              Volatile Organic Carbons
          500
               636
                  759
778
                  875
                         1250     1625
                        Tons/Year
                        1945

                      2000
Hazardous Air Pollutant (HAP) Emissions: HAP emission levels that Weyerhaeuser will be required to
attain under the new MACT rule will be determined based on a site-specific assessment, Weyerhaeuser's
development of an alternative compliance plan, and Federal and state agency approval of that plan.
Progress: Weyerhaeuser has modernized several components of the pulping process, which has reduced HAP
emissions from the bleach plant. Weyerhaeuser has hosted two meetings in 1998 with EPA and the State of
Georgia to begin the process of developing an alternative compliance plan for the facility. Details of the compli-
ance plan will be included in Weyerhaeuser's 1998 annual report.
Hazardous Waste Generation: Weyerhaeuser committed to reducing its hazardous waste generation to the
point where the facility's RCRA designation would be changed from a small-quantity generator to a condition-
ally exempt small-quantity generator.
Progress: Weyerhaeuser achieved this goal in 1997 by recycling and reusing a solvent (methyl ethyl ketone)
used for cleaning painting equipment.

Environmental Management System (EMS): EMSs instill the principles of continuous environmental
improvement through pollution prevention rather than end-of-pipe controls. The existing Flint River Operations
EMS will be revised to conform to the ISO 14001 EMS. When completed, the ISO 14001 EMS will docu-
ment the management systems required to comply with all applicable Weyerhaeuser policies and state, local,
and Federal rules and regulations.
Progress: Conversion of the existing EMS to the ISO 14001 standard has progressed slower than anticipated.
In mid-1998, Weyerhaeuser started identifying significant environmental activities throughout the facility leading
to the conversion of their existing EMS to the ISO 14001 standard by mid-1999.
Energy Conservation: Weyerhaeuser will conduct energy conservation studies to identify opportunities for
long-term reductions in facility energy demand. Based on these studies, a long-term goal for energy conserva-
tion will be determined and incorporated into the FPA. The potential environmental benefit expected from
these studies is a reduction in air pollutant emissions due to a reduction in the amount of fuel burned.

Progress: Four small-scale energy conservation projects were initiated in 1998. Three of the projects have
been completed, including returning product unit condensate to the boiler feedwater system, returning evapora-
tor condensate to the recaust area, and reducing recovery boiler secondary temperature. A fourth proj ect to
reduce recovery boiler soot blower steam use is on hold pending the results of a facility-wide energy conserva-
tion study. Weyerhaeuser has selected a consultantto perform a steam conservation study that will identify
steam savings projects throughout the facility. The study is expected to be completed by the end of 1998.
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     Weyerhaeuser XL Project                                                                 (3-31-991

        Weyerhaeuser Company worked to ensure that stakeholders were involved in the environmental design and
        impact assessment of its XL project and had an opportunity to participate fully in project development. The
        organizations directly involved in negotiating the FPA included Weyerhaeuser Company, U. S. EPA, Georgia
        EPD, Georgia Pollution Prevention Assistance Division, and the Lake Blackshear Watershed Association.
        Efforts to include a broad array of stakeholders as direct participants and to keep the public well informed
        included:
        «  A series of regional public meetings in Oglethorpe, Georgia;
        •  Personal contacts through telephone calls and meetings;
        *  Oral briefings and broad distribution of written descriptions of Proj ect XL to employees;
        •  Oral briefings and the distribution of a written proj ect summary to interested national, nongovernmental
          organizations; and
        •  Publication of notices in courthouses and local newspapers to convey an open invitation to scheduled public
          meetings.
        Complete listings of all stakeholders that participated in general public meetings held to discuss the
        Weyerhaeuser FPA are availabl e in its Appendix A.

        Weyerhaeuser has committed to holding annual stakeholder meetings in the vicinity of the Flint River facility.
        Reasonable advanced meeting notice will be provided to Federal, state, and local agencies and other stake-
        holders. The annual meeting is the platform for Weyerhaeuser to present the status of implementing the FPA
        and to answer stakeholder questions and concerns.
        On January 28,1998, the first Project XL annual stakeholders meeting was held in Montezuma, Georgia.
        Members of Weyerhaeuser's corporate leadership were in attendance as well as members from EPA head-
        quarters and Region 4, Georgia EPD, Weyerhaeuser employees, stakeholders,  and the general public. An
        audience of approximately 200 people received a review of the first Annual Project XL Progress Report and
        participated in an open question-and-answer period. Audience feedback was very supportive of both the
        Project XL program and Weyerhaeuser Company's environmental performance. No requests for changes in
        the direction or  scope of the FPA were received from the stakeholders or signatories during the meeting. A
        second annual stakeholders meeting is scheduled for January, 1999.



        The key focus areas for continued successful implementation of the FPA over the next six months will be the
        following:
        •  Continue the effort to convert Flint River Operation's EMS into ISO 14001 EMS.
        «  Maintain the current environmental management system to meet compliance and customer requirements.
        •  Identify and impl ement additional water conservati on measures.
        «  Complete the steam conservation study and begin development of an energy  conversation plan.
        •  Plan and hold the second Annual Stakeholders public meeting in January, 1999.
        *  Continue the  development of the MACT alternative compliance plan for the facility.
        •  Implement the MACT Cluster Rule requirements according to the regulation's timelines.
        «  Complete the modification of the solid waste handling permit to incorporate FPA flexibility.
12      *  Define possible water reuse and reduction opportunities that would reduce bleach plant effluent flow.

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 Weyerhaeuser XL Project                                                                 [3-31-991
• Mark Johnson, Weyerhaeuser, 770-396-8121
• Lee Page, EPA Region 4, 404-562-9131
• Nancy Birnbaum, EPA Headquarters, 202-260-2601
• David Word, Georgia, 404-656-4713
• Alan Leake, Georgia, 404-363-7138
• BobDonoghue, Georgia, 404-651-5120



The information sources used to devel op thi s progress report include: 1) discussions during a teleconference
among representatives of the U.S. Environmental Protection Agency, Weyerhaeuser Flint River Operations,
Georgia Environmental Protection Division, Georgia Pollution Prevention Assistance Division, and local commu-
nity stakeholders; 2) the Final Proj ect Agreement for the Weyerhaeuser XL proj ect; and 3) annual and semi-
annual status reports prepared by Weyerhaeuser. The information sources are current through December, 1998.

Adsorbable Organic Halide (AOX): A measurement of the amount of chlorinated organic compounds in an
effluent water sample.
Assimilative Capacity: The capacity of abody of water to receive wastewaters or toxic materials without
deleterious effects and without damage to either aquatic life or humans or to terrestrial animals that consume
the water.

Biological Oxygen Demand (BOD): The measurement in an effluent water sample of the oxygen consumed by
biological processes breaking down organic matter.

Brownside Optimization: The name given to Weyerhaeuser's proj ect to upgrade its pulp digester to isothermal
cooking technology, reinjection of wood knots, and change out of primary screens.
Carbon Monoxide (CO): A colorless, odorless, poisonous gas produced by incomplete fossil fuel combustion.
Clean Air Act (CA A): The Clean Air Act is the comprehensive Federal law that regulates air emissions from
area, stationary, and mobile sources. This law authorizes EPA to establish National Ambient Air Quality
Standards (NAAQS) to protect public health and the environment.
Clean Water Act (CWA): The Clean Water Act sets the basic structure for regulating discharges of pollutants
to waters of the United States. The law gives EPA the authority to set technology-based effluent standards on
an industry basis continues the requirements to set water quality standards for all contaminants in surface
waters. The CWA makes it unlawful for any person to di scharge any pollutant from a point source into navi-
gable waters unless a National Pollutant Discharge Elimination System (NPDES) permit is obtained under the
Act.
Conditionally Exempt Small-Quantity Generator: Persons or enterprises that produce less than 220 pounds of
hazardous waste per month. Exempt from most regulations, they are required merely to determine whether
their waste is hazardous, notify appropriate state or local  agencies, and ship the waste by an authorized trans-
porter to a permitted facility for proper disposal.

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     Weyerhaeuser XL Prelect
(3-31-99)
       Criteria Air Pollutants: The CAA requires EPA to set NAAQSs for certain pollutants known to be hazardous
       to human health. EPA has identified and set standards to protect human health and welfare for six criteria air
       pollutants—ozone, carbon monoxide, total suspended particulates, sulfur dioxide, lead, and nitrogen oxide.
       EPA must describe the characteristics and potential health and welfare effects of these pollutants. It i s on this
       basis that NAAQSs are set or revised.

       Dioxin: Any one of a family of compounds known chemically as dibenzo-p-dioxins. Concern about dioxin
       arises from the potential toxicity as a contaminant in commercial products. Tests on laboratory animals indicate
       that dioxin is one of the most toxic of man-made compounds.
       Effluent: Treated or untreated wastewater that flows out of a treatment plant, sewer, or industrial outfall.
       Generally refers to wastes discharged into surface waters.
       Emissions Cap: A limit designed to prevent projected growth in emissions from both existing and future
       stationary sources from exceeding any mandated limits. Generally, such provisions require that any emission
       increase from equipment at a facility be offset by emission reductions from other equipment under the same
       cap.
       End-of-Pipe Controls: Technologies, such as scrubbers on smokestacks and catalytic converters on automo-
       bile tailpipes, that reduce the emi ssion or discharge of pollutants to the environment after they have formed.
       Forest Buffers:  Strips of forests along each side of a stream that resist erosion and slow the runoff of sediment-
       laden rainwater into the stream.
       Hazardous Air Pollutants (HAPs):  Air pollutants that are not covered by the NAAQS but that may present a
       threat of adverse human health effects or adverse environmental effects. Such pollutants include asbestos,
       beryllium, mercury, benzene, coke-oven emissions, radionuclides, and vinyl chloride.
       International Organization for Standardization (ISO) 14000: ISO 14000 is primarily concerned with environ-
       mental management. The ISO 14000 series sets out the methods that can be implemented in an organization to
       minimize harmful effects on the environment caused by pollution or natural resource depletion.

       Leachate: Water that collects contaminants as it trickles through wastes, pesticides, or fertilizers. Leaching may
       occur in farming areas, feedlots, and landfills, and may result in hazardous substances entering surface water,
       groundwater, or soil.
       Maximum Available Control Technology (MACT): The emission standard for sources of air pollution requiring
       the maximum reduction of hazardous emissions, taking cost and feasibility into account. Under the CAA
       Amendments of 1990, the MACT must not be less than the average emission level achieved by controls on the
       best performing 12% of existing sources, by category, of industrial and utility sources.
       Methyl Ethyl Ketone (MEK): A solvent typically used in cleaning painting equipment.
       National Pollutant Discharge Elimination System (NPDES): A provision of the CWA that prohibits the dis-
       charge of pollutants into waters of the United States unless a special permit is issued by EPA, a state, or where
       delegated, by a Tribal government on an Indian reservation.
       Nitrous Oxides (NOx): An air pollutant that is the result of photochemical reactions of nitric oxide in ambient
       air. Typically, it is a product of combustion from transportation and stationary sources. It is a major contributor
       to the formation of tropospheric ozone, photochemical smog, and acid deposition.
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 Weyerhaeuser XL Project
13-31-991
Particulate Matter: Fine liquid or solid particles, such as dust, smoke, mist, fumes, or smog, found in air or
emissions.
Resource Conservation and Recovery Act (RCRA): RCRA gives EPA the authority to control hazardous
waste from the "cradle-to-grave." This includes the generation, transportation, treatment, storage, and disposal
of hazardous waste. RCRA also set forth a framework for the management of non-hazardous wastes. RCRA
enables EPA to address environmental problems that could result from underground tanks storing petroleum
and other hazardous substances. RCRA focuses only on active and future facilities and does not address
abandoned sites.
Small-Quantity Generator (SQG): Persons or enterprises that produce 220-2,200 pounds per month of
hazardous waste; they are required to keep more records than conditionally exempt generators. The largest
category of hazardous waste generators, SQGs include automotive shops, dry cleaners, photographic devel-
opers, and many other small businesses.
Sulfur Dioxide (SO,):  Sulfur-dioxide gases are formed when fuel containing sulfur (mainly coal and oil) is
burned and can be formed during metal  smelling and other industrial processes. Sulfur dioxide is  associated
with acidification of lakes and streams, accelerated corrosion of buildings and monuments, reduced visibility,
and such adverse health effects as inhibition of breathing, respiratory illness, and aggravation of existing cardio-
vascular disease.
Title V of the Clean Air Act: Establishes a federal operating permit program that applies to any major station-
ary facility or source of air pollution. The purpose of the operating permits program is to ensure compliance
with all applicable requirements of the CAA. Under the program, permits are issued by states or, when a state
fails to carry out the CAA satisfactorily, by EPA. The permit includes information on which pollutants are being
released, how much may be released, and what kinds of steps the source's owner or operator is  taking to
reduce pollution, including plans to monitor the pollution.

Total Suspended Solids (TSS): The measurement of the amount of suspended solids in an effluent water
sample.

Volatile Organic Compound (VOC): Any organic compound that easily evaporates and participates in atmo-
spheric photochemical reactions, except those designated by EPA as having negligible photochemical reactivity.

Wastewater:  The spent or used water from a home, community, farm, or industry that contains dissolved or
suspended matter.
Water Bars: An obstruction that slows the downhill flow of rainwater and, therefore, reduces erosion.
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