tembec 

Rooted Ln tomorrow. 

December 5, 2014 

The Honorable Gina McCarthy 

Administrator 

US Environmental Protection Agency 

William Jefferson Clinton Building 

Mail Code 1101A 

1200 Pennsylvania Ave., NW 

Washington, DC 20460 

-

Tembec BTLSR 

2112 Sylvan Avenue 

Toledo, OH 43606 

Re: Petition for Reconsideration and for Amendment of the October 2014 

Amino/Phenolic Resins MACT (40 CFR 63, Subpart 000) 

Dear Administrator McCarthy: 

Tembec BTLSR hereby petitions the U.S. Environmental Protection Agency ("EPA" or 

"Agency") for reconsideration and amendment of the National Emission Standards for 

Hazardous Air Pollutants: Manufacturing of Amino/Phenolic Resins (Amino/Phenolic 

Resins MACT) (79 Fed. Reg. 195 (October 8, 2014)). Tembec owns one facil ity and 3 

of the 6 resin spray dryers covered by the revisions to the Amino/Phenolic Resins 

MACT. As the rule is currently written, even though our 3 dryers are identified as the 

top 3 performers, they ZLOO not meet the continuous process vent emission standards 

that EPA finalized. 

Pursuant to§ 307(d)(7)(B) of the Clean Air Act ("CAA"), EPA is authorized to reconsider 

a UXOH where it was impracticable to raise an objection during the period of public 

comment or if the grounds for such objection arose after the SXEOLF comment period (but 

within the time specified for judicial review), and if such objection is of central relevance 

to the outcome of the UXOH. The January 9, 2014 proposal put forth continuous process 

vent standards based on a percent reduction or outlet concentration requirement. The 

October 8, 2014 rule finalized a standard for continuous process vents based on a 

pounds organic HAP per ton of resin emission rate. 

We submitted emissions information to EPA that was not considered in establishing the 

continuous process vent standards under the final rule (see docket item EPA-HQ-OAR2012-0133-0058). The EPA identified Tembec's 3 dryers as top performers and 

developed the emission limits for continuous process vents using annual emissions and 

production data we submitted to the Ohio EPA as part of the annual emissions inventory 

reporting. The data used does not represent all of the organic HAP emissions from our 

three dryers. The data EPA used only represents the "back half" organic catch from an 
December 5, 2014 

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EPA Method 5 particulate train and estimated emissions from the natural gas 

combusted to provide direct heat to our three dryers. An engineering test was 

conducted on one dryer in 2006 to estimate formaldehyde and methanol emissions; this 

test report was submitted to EPA but was not used. Incorporation of this data would 

substantially raise the continuous process vent emission limit because the estimated 

emission rates from our dryers are much higher than the emission rates used in EPA's 

MACT floor calculations, as shown below. 

Data Used Estimated 

by EPA, Emission Rate, 

Process Vent lb/ton lb/ton 

Spray Dryer A 0.1 >6 

Spray Dryer B 0.2 >3 

Spray Dryer C 0.7 >3 

Emission Limit 1.9 lb/ton 

Georgia-Pacific also owns 3 dryers that are subject to the new continuous process vent 

standards and is also submitting a petition for reconsideration of the Amino/Phenolic 

Resins MACT. Tembec supports the Georgia-Pacific petition. Both companies are 

concerned about the quality of the data and the calculation methodology used to set the 

continuous process vent organic HAP emission limits in the revised Subpart 000. We 

are committed to obtaining up to date emissions data for our dryers using EPAapproved test methods and will submit that data to EPA as soon as practicable. We are 

confident that EPA can improve the outcome of the rule with this new data and stand 

ready to work with EPA to provide you with the additional information necessary to 

perform a revised analysis. 

Please feel free to contact James Bennett or Tembec staff at (419) 244-5956, ext. 

45107 if you have questions or need more information. 

cc: Nick Parsons, EPA 

Penny Lassiter, EPA 

Sincerely, 

James Bennett 

Plant Engineer