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| ![](media/imag     | >           |            | ***Environmental    |
| e1.emf){width="0.9 |  ![](media/ |            | Affairs\            |
| 569444444444445in" | image2.emf) |            | **133 Peachtree     |
| height="0.576      |             |            | Street NE           |
| 3888888888888in"}\ | September   |            | (30303-1847)\       |
| \                  | 8, 2005     |            | P.O. Box 105605\    |
| ***\               |             |            | Atlanta, Georgia    |
| *** *\             |             |            | 30348-5605\         |
| *                  |             |            | (404)* *652-4651    |
|                    |             |            | Telephone\          |
|                    |             |            | (404)* *654-4700    |
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Office of Air and Radiation Docket

Attention Docket No. OAR-2004-0094

U.S. Environmental Protection Agency

Dear Sir or Madam:

**Re**: **EPA Notice of Reconsideration of Final Rule and Proposed Rule,
[National Emission Standards for Hazardous Air Pollutants; General
Provisions]{.underline}**

Georgia-Pacific Corporation ("GP" or "the Company") welcomes the
opportunity to comment on EPA's Notice of Reconsideration of Final Rule
and Proposed Rule, [National Emission Standards for Hazardous Air
Pollutants \[NESHAP\]; General Provisions]{.underline} \[70 Fed. Reg.
43992 (July 29, 2005)\]. GP is a major manufacturer of pulp, paper and
wood products, with facilities located throughout the United States that
are subject to a variety of NESHAPs, and will be directly affected by
this proposed rule.

In addition to submitting the following comments, GP, as a member of the
American Forest and Paper Association (AF&PA), wishes to support and
incorporate by reference the comments being submitted by the American
Forest and Paper Association, Alliance of Automobile Manufacturers,
American Petroleum Institute, National Petrochemical Refiners
Association, and the Air Permitting Forum (collectively, the
"Associations").

# 

**GP strongly supports EPA's proposal to eliminate recordkeeping
requirements for startups and shutdowns during which applicable emission
standards are not exceeded.**

> [a. EPA has already promulgated changes that eliminated detailed
> reporting of startups and shutdowns when applicable emission standards
> are not exceeded.]{.underline}

Under the current General Provisions[^1], facilities are required to
maintain detailed records of each startup and shutdown, including
information on whether the facility's Startup, Shutdown and Malfunction
Plan (SSMP) was followed and whether there was an exceedance of the
emission limit during the startup or shutdown. As discussed in the
preamble[^2] to this Notice, in a May 30, 2003 final rule[^3] EPA
changed the reporting requirements of 40 CFR 63.10(d)(5)(i) so that
regulated sources did not have to submit specific details of startups
and shutdowns when applicable emission standards were not exceeded. This
common-sense change relieved facilities of the burdensome requirement to
report startups and shutdowns that had no environmental impact.
Georgia-Pacific supports EPA's proposal to make a conforming change to
the General Provisions that would allow sources not to keep records of
these events.

[b. Keeping startup and shutdown records for events where there is no
environmental impact is a huge burden on industrial
facilities]{.underline}

At large, complicated, but well-controlled plant commonly found within
Georgia-Pacific, there will typically be a large number of process and
control equipment startups and shutdowns; however, the vast majority of
these do not result in an exceedance of the underlying emission
standard. In fact, unless it is unsafe to do so, operators will bring
control equipment on-line before the related process equipment is
started, and will keep the control equipment running until the process
equipment is safely shut down to prevent any excess emissions.
Accordingly, keeping records of these frequent events, in the absence of
any environmental impacts, places an unnecessary burden on these
facilities and their operators and yields no data of any value. To
illustrate this point, we describe the process used at a typical large
pulp and paper mill to obtain the currently required startup and
shutdown records.

Georgia-Pacific operates a large mill in the southeast that produces
high quality printing papers and tissue products. This facility is
subject to NESHAP rules under Subpart S (pulp and paper production) for
its bleach plant, the low volume high concentration system and the high
volume low concentration gas collection system in the pulping area
(including two power boilers used as combustion devices), as well as
Subpart MM (pulp and paper combustion) for its two recovery furnaces,
three smelt dissolving tanks and two lime kilns[^4]. Both of these MACT
rules require SSMPs and compliance with the recordkeeping requirements
of the General Provisions. In the first quarter of 2005, this mill had
384 shutdowns or startups of process equipment in the process areas
covered by the two NESHAP rules. *During none of these shutdowns or
startups were the underlying emission standards exceeded.* Nevertheless,
for each of these 384 cases (or approximately 1,536 on an annual basis),
the process operators and environmental department staff had to use the
following procedures to assure that accurate records were kept to be in
compliance with 40 CFR 63.10(b)(2).

-   The operator of the process equipment fills out a computer form for
    each occurrence stating the duration of the startup or shutdown
    event, whether the SSMP was followed, and specifies any actions
    taken during the event.

-   After assuring that all required information is supplied, the
    operator electronically "signs" his name and enters the report into
    the mill's data collection system.

-   Every morning the environmental technician queries the system for
    any operator reports over the last 24 hours.

-   The technician then checks the daily air report to assure that all
    air exceedances for the day have a corresponding startup, shutdown
    (or malfunction) event reported on the operator's reports. He, or
    one of the environmental engineers, follows up on any discrepancies.

-   The reports are then printed and filed in a loose leaf binder.
    \[Reports for one quarter completely fill a three inch binder.\]

Mill staff estimates that about 5 minutes is required for the process
operator to complete each startup or shutdown report. On average, the
environmental technician and air engineer spend an additional 15 minutes
per event with the error checking, printing and filing duties. Finally,
the environmental engineer spends about 20 hours twice a year analyzing
and summarizing these data for the semiannual reports. This totals to
about 552 hours per year of work for no environmental benefit. It should
be apparent from this description that the mill has the systems in place
to allow operators to take appropriate actions (and keep appropriate
records) during those rare instances when emission standards are, or
could be, exceeded. However, in highly competitive manufacturing
environments, scarce resources should be directed away from events with
no environmental impacts. Removal of reporting and recordkeeping for
events without real emission impact will allow mill staff to
re-prioritize their schedules to focus on events with real potential
environmental impacts.

GP appreciates the opportunity to offer these comments for the record.

Sincerely,

Alan E. Stinchfield, Director

Environmental Technical Support

CC: Mr. Robert Kaufmann

[^1]: 40 CFR 63.10

[^2]: 70 *FR* 43994

[^3]: 68 *FR* 32586

[^4]: The mill will also be regulated under Subpart DDDDD (industrial
    boilers) effective September, 2007.