# tembec

Rooted L n 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 ifthe grounds for such objection arose after the SXEOLFcomment period (but within the time specified forjudicial 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 requ irement. 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-OAR2012-0 133-0058). 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 ofthe 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 anDecember 5, 2014 Page 2 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 ofthis 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 DryerA 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 ofthe 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 ofthe 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 ifyou have questions or need more information.

cc: Nick Parsons, EPA Penny Lassiter, EPA Sincerely,

James Bennett Plant Engineer