1. Pulp & Paper Sector Strategy & New Source Performance Standards Strategy Peter Tsirigotis, Director Sector Policies & Programs Division National Association of Clean Air Agencies Spring Membership Meeting April 30-May 2, 2007

2. 2 Overview  Pulp & Paper Sector Strategy Background Status of Project Next Steps for Project

3. 3 Background – Pulp & Paper Sector Strategy  EPA encouraged by NAS/CAAAC to move toward multi-pollutant & sector-based approaches  In response to NAS/CAAAC recommendations, EPA initiated a study to identify candidate sectors for conducting integrated, multi-pollutant assessments  Pulp & paper sector identified as candidate for more comprehensive analyses and refined development and implementation of control strategies

4. 4 Background – Pulp & Paper Sector Strategy  Existing programs that affect pulp and paper sector Title V/NSR MACT  Upcoming programs that may affect pulp and paper sector NAAQS (PM2.5 and O3) Regional Haze Residual Risk under Toxics Program

5. 5 Status of Project  Worked with AF&PA to better characterize the industry’s environmental impact  As an initial “next” step, developed draft sector strategy framework that could incorporate requirements of several regulatory programs, including BART, RACT/RACM, NSR, Residual Risk, and Reasonable Progress  Draft framework has been shared with NACAA, states, and industry

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7. 7 Status of Project  Draft framework reflects possible emissions reduction requirements, baselines, and source monitoring requirements ~30-40% overall SO2 emissions reductions from the industry SO2 reductions are the more immediate reductions because of possible near-term BART, RACT requirements and potential for toxics co-benefits  Framework focuses on larger SO2 emissions reductions from bigger facilities in problem areas, e.g., ~70% emission reductions from facilities w/~>500 tpy of SO2 emissions near Class I or residual PM2.5 nonattainment areas Final criteria and list of specific facilities yet to be determined  Framework reflects reductions from specific facilities and potential region-wide reductions through “opt-in” facilities “Critical mass” of facilities would be needed to achieve emissions reductions and resulting environmental benefits that are equivalent to or greater than BART and RACT

8. 8 Status of Project  Framework may also address NOx emissions reductions  State-of-the-art combustion devices and practices, not post-combustion controls Residual risk requirements Options for off-site emissions reductions  Proposed Model Rule – Summer 2007

9. 9 New Source Performance Standards (NSPS)  Background CAA requires the Agency to review NSPS at least every 8 years and, if appropriate, revise such standards Agency has been sued for failing to comply with this requirement in approximately 15 standards  Up to 60 NSPS’ must be reviewed  Develop a national strategy for fulfilling our statutory obligation  Publish Strategy in Federal Register this summer

10. 10 New Source Performance Standard Strategy  The goals of this strategy are: Establish meaningful priorities for reviewing and revising NSPS standards rather than having the agenda dictated by litigation Position the Agency to better respond to future deadline suits Fulfill statutory obligations to review and if appropriate revise NSPS standards in a strategic manner integrated with other requirements (e.g., MACT technology, residual risk)