Anonymous public comment

Comments on The Proposed Rule National Emission Standards for Hazardous Air Pollutants From the Pulp and Paper Industry Amend the affected source definition in 63.440(b) to include all of the affected sources in 63.447(1)(a) to read: (1) affected source means the total of all HAP emission points in the pulping, bleaching, causticizing, and papermaking systems (exclusive of HAP emissions attributable to additives to paper machines and HAP emission points in the LVHC system). New technologies have been developed in at least two mills in the RTR data to control HAPs in paper making systems using easily transferable techniques such as temperature control of the white water and careful choice of the introduction point of fresh water. The CCA has allowed for these new technologies to be developed and either numerical limits or work practices or both could be established for paper making systems. Remove the exclusion for HAP additives from the CCA to allow for new technology to be developed in additives.