From: Curtis, Michael [mailto:MICHAEL.CURTIS@GAPAC.com]

Sent: Friday, May 06, 2011 5:50 PM

To: 'Bradfield.John@epamail.epa.gov'

Cc: 'Schrock.Bill@epamail.epa.gov'; 'Spence.Kelley@epamail.epa.gov'; Hanks, Katie P.; 

Galler, Wayne J.; Cooley, Cindy S.; Bottini, John C. (GP Law)

Subject: GP's New Substance Review Program

May 6, 2011

Mr. John Bradfield

U.S. EPA

Natural Resources Group

Sector Policies and Programs Division, OAQPS

109 T.W. Alexander Drive (E143-03)

Research Triangle Park, NC 27709

Subject: Georgia-Pacific New Substance Review Program

Dear Mr. Bradfield:

As you request, Georgia-Pacific is providing EPA with the following information regarding our 

“New Substance Review” (NSR) program. You asked for this information to assist EPA in 

developing a potential work practice for 40 CFR Part 63, Subpart S sources under the Residual 

Risk and Technology Review. Our specific responses to your questions are noted below.

1. Does G-P have their “New Substance Review” program written in some 

document that they could share with EPA to use in formulating a work 

practice? 

The following is a summary of Georgia-Pacific’s New Substance Review Program rather than 

specific written documentation of the program. The documents Georgia-Pacific has are more 

comprehensive program reviews that includes several areas of review beyond environmental.

Georgia-Pacific has developed and implemented a program to review and approve new 

chemicals utilized in the manufacturing processes. The New Substance Review Procedure 

assists our facilities in evaluating the environmental implications, if any, associated with changes 

in chemicals used in operations. The program also assists some facilities in meeting their 

environmental permitting requirements for evaluating VOC-containing materials before using 

those materials in the regulated paper machines. The program requirements include obligations 

to:

 develop and document facility administrative procedures for managing and

controlling chemical use; and 

 manage new chemicals brought on-site and properly report chemical inventories and 

releases.

The following is an overview of the New Substance Review Program established for use in 

Georgia-Pacific operations. This is a summary of the minimum program expectations that will 

be implemented by business within the company. 
Prequalification for Chemical Purchasing and Use

Before chemicals are ordered and brought on-site, these new substances must be reviewed using 

a New Substance Review procedure. This procedure must meet the following minimum 

expectations:

 Any substance used in the permitted manufacturing process must be evaluated to 

determine if it contains any chemicals that have restricted or limited uses set by the 

facility, business or regulations. 

 The operating area wishing to use the new chemical must submit a new substance review 

form for internal review. This submittal must include: the operational parameters for use, 

estimated use, and the proposed system to monitor use of the substance, MSDS, Supplier 

product information and any additional information that may be needed for evaluation.

 The Environmental Approver(s) of the new substance must evaluate the use of the 

substance at the facility. This will include examining the new substance review form, the 

MSDS, the Supplier Assurance Form, and related information for the presence of any 

restricted/limited use chemicals. The Approver must identify any potential on-site 

environmental issues or reporting requirements. If necessary, the Environmental 

Approver may seek technical assistance to determine if the proposed use is appropriate.

 The Environmental Approver must determine if there are any potential environmental 

issues, use restrictions or reporting requirements associated with using the chemical. 

Specific environmental limitations or requirements will be identified in this review. 

 Finally, a system must be in place to provide the purchasing department at the facility or 

the divisional purchasing person with information about approved/disapproved new 

substances or restrictions on their use. The purchasing department cannot order the 

chemical until it knows that it was approved. 

 The facility and/or business must maintain a list of these restricted/limited use chemicals.

2. Which aspects of the “New Substance Review” program have been or 

could be used generically at G-P?

The program noted in our response to question 1 is the generic program used by GP. The 

summary only highlights the environmental components of the program. We also use this 

program to address safety and product stewardship concerns.

3. Is there an estimate of the cost of developing and implementing the 

program (e.g., in terms of labor hours)?

Georgia-Pacific does not have a specific cost of developing and implementing 

this program.

4. How is continuous compliance with the program demonstrated (e.g., 

recordkeeping)?

Georgia-Pacific maintains a list of chemicals that have been reviewed and approved through the 

program. No new chemicals are purchased prior to their approval through this process.
5. How many paper machine low VOC additive products have been reviewed 

in GP's 'new substance review' protocol and adopted(at Crossett and 

elsewhere if it has been adopted broadly)?

Typically, a tissue manufacturing facility will review approximately 40 chemicals per year for 

tissue paper machine applications. The number of chemicals reviewed depends upon on-going 

product development activities. 

6. What can you tell us about VOC or HAP additives that they are 

finding common replacements for? For example:

Which low VOC products work with which additive requirements?

Which species of VOC are reduced/HAPs?

What are the relative costs of the reductions, as applied?

Due to the broad scope of this question and the limited time we have been afforded to formulate 

a response, Georgia-Pacific is unable to provide you with this information at this time.

You additionally requested our estimate of time necessary to complete an environmental review 

of a new chemical. From our assessment, we found it takes approximately two hours to prepare 

a NSR form and actual environmental reviews can takes less than 30 minutes.

Georgia-Pacific looks forward to continuing to work with EPA in addressing the Pulp and Paper 

Residual Risk and Technology Review.

Sincerely,

Mike Curtis

Director, Environmental Technical Support

Atlanta, GA

404-652-4133 (office)

386-530-1012 (mobile)