**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 Subst ance 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 per

mitting 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 controlli ng 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 b y 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 p rocedure. 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 , busines s 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 sy stem to monitor use of th e 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 necess ary , 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 sy stem 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 onl y 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 pri or 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)?** Ty pically , 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 f**  **inding 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 l imited 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. Fro m 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. Sincerel y, 

### Mike Curtis Director, Environmental Technical Support Atlanta, GA 404 - 652 - 4133 (office) 386 - 530 - 1012 (mobile)