UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 6

1445 ROSS AVENUE, SUITE 1200

DALLAS, TX 75202-2733

September 28, 2005

VIA CERTIFIED MAIL -RETURN RECEIPT REOUESTED

ARTICLE NUMBER 7003 0500 0003 0873 2796

AND VIA FIRST-CLASS MAIL

Timothy H. Crawford

Vice President, Port Hudson Operations

Georgia-Pacific Corporation

1000 W. Mt. Pleasant Road

P.O. Box 430

Zachary, Louisiana 70791

Re:

Administrative Compliance Order

Docket No. CAA-06-2005-3324

Part 70 Pennit No. 0840-00010-V2

Dear Mr. Crawford:

The purpose of this letter is to transmit an Administrative Compliance Order (Order)

designed to facilitate efforts to bring the No.1 Lime Kiln at Georgia-Pacific's Port Hudson facility

back into compliance with its Clean Air Act (CAA) permit.

The enclosed Order lists the environmental findings, identifies the specific CAA violations

that occurred, and sets forth the req~irements necessary for Georgia Pacific to return to compliance

with the CAA. This Order does not levy any penalties. Your cooperation and prompt attention will

be appreciated. If you have any questions, please contact Ms. Anupa Auhja, of my staff, at (214)

665-2701.

Sincerely yours,

../

Director

Compliance Assurance and

Enforcement Division

Enclosure

cc: Harold Leggett, Ph.D.

Louisiana Department of

Environmental Quality

Internet Address (URL) .http://www.epa.gov

Recycled/Recyclable .Printed with Vegetable 011 Based Inks on Recycled Paper (MInimum 25% Postconsumer)
UNITED STATES

ENVIRONMENTAL PROTECTION AGENCY

REGION 6

In the Matter of )

)

GEORIGIA-PACIFIC CORPORATION)

PORT HUDSON FACILITY )

Zachary, Louisiana )

CAA Docket No. CAA-O6-2005-3324

ADMINISTRATIVE

COMPLIANCE

ORDER

ORDER

STATEMENT OF A UTHORlTY ~~---

The following Administrative Compliance Order ("Order") is issued pursuant to the authority

of Section 113(a)(3) of the Clean Air Act, 42 U.S.C. § 7413(a)(3) (hereinafter referred to as "the

Act"). Section 113(a)(3) of the Act authorizes the Administrator of the United States Environmental

Protection Agency ("EP A") to issue an Order requiring compliance to any person whom the

Administrator finds to be in violation of the Act. The authority to issue this Order has been

delegated to the Director of the Compliance Assurance and Enforcement Division, EP A, Region 6.

FINDINGS OF FACT AND CONCLUSIONS OF LAW

1 Georgia-Pacific Corporation ("GP"), is a Georgia corporation and is licensed to do business

in the State of Louisiana.

2.

GP is a "person" as that term is defined in Section 302(e) of the Act, 42 U.S.C. § 7602(e).

3 GP owns and operates the Port Hudson facility located in East Baton Rouge Parish at

1000 W. Mt. Pleasant Road, Zachary, Louisiana (the "facility").

4.

On September 23, 2005, Hunicane Rita struck the Louisiana coast, causing wide-spread

devastation to the area including offshore and onshore natural gas production and storage

facilities in southern Lousiana.
5.

has received intermittent natural gas delivery since September 23,2005. EPA Region 6 has

confirmed with GP's natural gas supplier that natural gas supplies have been severely

curtailed. Regular natural gas supplies are not cuITently available to the facility.

6.

At all times relevant to this Order, GP was subject to the terms of Permit No. 0840-00010-

V2, issued by LDEQ under its operating pennit program authorized by EP A under Title V

of the Act and 40 C.F .R. Part 70 (the "Part 70 pennit"). Pursuant to the Part 70 pennit, and

prior to Hurricane Rita, the facility burned natural gas in its No.1 Lime Kiln (the "Kiln")

and is subject to an emission limit of 0.05 gr/dscf.

7 The No.1 Lime Kiln is capable of burning both natural gas and petroleum coke ("pet

coke"). The Part 70 permit does allow GP to bum pet coke in its Kiln, but only after

installation of a more-efficient scrubber to control particulate emissions.

8.

The burning of pet coke in the Kiln (utilizing the current, less-efficient scrubber) will cause

the facility to emit 0.13 gr/dscf, corrected to 10% oxygen, of particulate matter.

9. Discharge of particulate matter in this concentration is a violation of the facility's

Part 70 pennit, 40 C.F.R. § 60.282(a)(3)(i), and 40 C.F.R. § 63.862(a)(i)(C).

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ORDER

10. After a thorough investigation of the relevant facts, taking into account the seriousness of

noncompliance and efforts made by GP to comply with applicable Jregulations, and based

upon the foregoing Findings of Fact and Conclusions of Law and pursuant to the authority

vested in me under Section 113(a)(3) of the Clean Air Act, 42 V.S.C. § 7413(a)(3), it is

hereby ORDERED that

a. By November 5, 2005, GP shall cease the use of petroleum co,ke in the Kiln with the

existing scrubber.

b. On November 5, 2005, GP shall cease operation of the Killn while the existing

scrubber is being replaced with a new, more-efficient scrubber.

c. By November 27, 2005 GP shall install a new more-efficient. scrubber on the Kiln.

d.

GP shall not re-start operation of the Kiln before completing paragraph to.c.

e. At all times, GP shall continue to monitor and submit ana1ytic~ll results in accordance

with the permit requirements for particulate matter from the Kiln.

f. GP shall submit written notification to EP A and LDEQ within 7 days after

completing paragraphs to.b. and upon fe-starting operation of the Kiln

g. No later than 30 days after the effective date of this Order, GP shall submit to EPA

andLDEQ for EPA's approval a plan (the "Plan") to mitigat(: the 8.6 tons of excess

particulate matter emissions resulting from the burning of the pet coke in the Kiln for

the period from the effective date of this Order through Nov~~mber 5, 2005.

h The Plan shall propose actual particulate matter emission ireductions equal to or

greater than the excess particulate matter emissions.

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If EP A detennines that the plan is not acceptable to mitigate the 8.6 tons of excess

particulate matter emissions, EP A may pursue an enforcemel1t action to resolve the

violations listed in paragraph 9.

11. Any infonnation or correspondence submitted by GP to EPA undler this Order shall be

addressed to the following:

Anupa Ahuja

Air Enforcement Branch (6EN-AA)

EP A Region 6

1445 Ross Ave., Suite 1200

Dallas, TX 75202-2733

Fax: 214665 2168

Email: ahuja.anupa@epa.gov

12. Any information or co~espondence submitted by GP to WEQ under this Order shall be

addressed to the following:

Bryan Johnston

Louisiana Department of Environmental Quality

P. O. Box 4312

Baton Rouge, Louisiana 70821-4312

GENERAL PROVISIONS

13. The provisions of this Order shall apply to and be binding upon OP" its officers, directors,

agents, employees, and any successor(s) in interest.

14. The provisions of this Order shall be transferable to any other pat1y, upon sale or other

disposition of the facility. Upon such action, the provisions of this 'Order shall then apply

to and be binding upon any new owner/operator, its officers, directclrs, agents, employees,

and any successor(s) in interest.

15. Pursuant to Section 114 of the Act, 42 V.S.C. § 7414, the Administrator or authorized

representatives of EP A, upon presentation of his or her credentials, shall have the right of

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entry into, upon and through the GP facility, for the purpose of caIrying out any inspections,

taking photographs, and reviewing any records, and, subject to applicable safety

requirements, observing tests, and conducting any tests, which are deemed by EP A to be

necessary to ensure compliance with this Order.

16. Nothing in this Order shall be construed to affect EPA's authority under Section 114 of the

Act, 42 U.S.C. § 7414.

17. Nothing contained in this Order shall affect the responsibility of GP to comply with all other

applicable Federal, State or local laws or regulations, including Section 303 of the Act,

42 U.S.C. § 7603.

FAILURE TO COMPLY

Failure to comply with the above Order may result in an administrativ,e or judicial action for

appropriate injunctive relief, and penalties of up to $32,500 per day for con1tinued noncompliance

with the Order pursuant to Section 113(b) of the Clean Air Act, 42 U.~).C. § 7413(b), or in

appropriate cases, criminal penalties.

EFFECTIVE DATE

This Order shall become effective on the date of it signing. GP has, the right, pursuant to

Section 113(a)(4) of this Act, 42 U.S.C. § 7413(a)(4) to confer with EPA re!~arding this matter. In

the absence of a request for conference within seven (7) days the right to! a conference will be

deemed waived.

q...z.~-6- ,

Date

Director

Compliance Assurance and

Enforcement Division

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