**From:** Ross, Sarah M. [mailto:Sarah.Ross@GAPAC.com]

**Sent:** Monday, April 30, 2012 5:41 PM **To:** PPSURVEY **Cc:** Hanks, Katie P. **Subject:** RE: NEI Site ID #54342 RTR Data Revisions for Georgia - Pacific, LLC - Crossett Paper Operations, Crossett, Arkansas My apologies for the delay. I would like to make the following clarifications/notes: SN61 (Line 2 Decker)

- This unit is on the 4 th floor (~223ft off the ground), inside a building in our Bleach Plant. This de cker (cylinder) spins inside of a vat that is 26ft by 10ft. SN76 (Black Liquor Storage Basin)
– the opening of this basin is ~15ft above ground level, but the basin is partly underground. The plan outlined below to keep the original stack diameter of 0 .003 ft, determine the area of the circular emission unit (A = πr 2 ) using the revised stack diameter of 434.5 ft, and assign the square root (385 ft) of that area to each of the fugitive length and width fields should accomplish your goal. Please let me k now if I can clarify further. Again, my sincere apologies for the delay. Sincerely, Sarah Ross Environmental Engineer (870) 567

- 8670 **From:** PPSURVEY [mailto:ppsurvey@rti.org] **Sent:** Tuesday, April 24, 2012 2:33 PM **To:** Ross, Sarah M. **Cc:** Bill Schrock; John Bradfield; Hanks, Katie P. **Subject:** RE: NEI Site ID #54342 RTR Data Revisions for Georgia - Pacific, LLC - Crossett Paper Operations, Crossett, Arkansas 

### Ms. Ross, I just wanted to follow up regarding the c orrections you provided to the model risk inputs for the Georgia
- Pacific facility in Crossett, Arkansas. I wanted to let you know that we plan to finalize our review of the revisions by May 4 th

### , and, before that happens, I wanted to see if you had any cha nges to make to the model risk inputs based on our questions in the e
- mail below. Thanks for taking a look into this for us. We appreciate your help. My contact information is provided below in case you have any questions. Thomas C. Holloway RTI International 3040 Cornwallis Rd., P.O. Box 12194 Research Triangle Park, NC 27709 Phone: (919) 316

-3733 Fax: (919) 541

- 7155 E
-mail: tcholloway@rti.org**From:** PPSURVEY

**Sent:** Wednesday, March 14, 2012 4:12 PM **To:** Sarah.Ross@gapac.com **Cc:** Bill Schrock; John Bradfield; Hanks, Katie P. **Subject:** RE: NEI Site ID #54342 RTR Data Revisions for Georgia - Pacific, LLC - Crossett Paper Operations, Crossett, Arkansas Ms. Ross, We are EPA’ s contractor for reviewing the revisions to the NEI file for the pulp and paper industry. We have reviewed your corrections to the model risk inputs for your facility (Georgia

- Pacific, LLC
– Crossett Paper Operations, NEI ID NEI54342). Thank you for taki ng the time to prepare the corrections. We have some questions about the revisions to emission release point type and/or stack parameters that you provided for a couple of emission units, specifically SN61 (Line 2 Decker) and SN76 (Black Liquor Storage Ba sin). In your corrections to SN61, the emission unit was changed from a fugitive source to a vertical point source, the stack diameter was changed from 0.003 ft to 26 ft, and the stack height was kept at 10 ft. EPA’s NEI guidance regarding non
-fugitive e mission release points states that the stack height may not be less than the stack diameter. Could you review the corrections that you provided for SN61 to see whether the source type (fugitive, point source) or stack parameters (stack diameter, stack heig ht) for this emission unit need to be changed? For example, instead of 26 ft, is the stack diameter for SN61 actually 2.6 ft or 26 inches (i.e., 2.17 ft)? If the stack diameter and stack height you’ve provided are correct, our plan is to keep this emissi on unit as a fugitive source, keep the original stack height of 10 ft and original stack diameter of 0.003 ft, determine the area of the circular emission unit (A = πr 2 ) using the revised stack diameter of 26 ft, and assign the square root (23 ft) of that area to each of the fugitive length and width fields. Please let us know what changes can be made to these data to be consistent with NEI guidance. While no change was made to the emission release point type for SN76 (fugitive), it was given a revised st ack diameter of 434.5 ft and a revised stack height of 15 ft. While the revision to the stack height is OK, EPA’s NEI guidance regarding fugitive sources requires that national defaults be assigned to the other stack parameters (including 0.003 ft stack diameter, 0.0003 ft/sec stack velocity, and 0 cubic ft/sec stack flow). Our plan is to keep the original stack diameter of 0.003 ft, determine the area of the circular emission unit (A = πr 2 ) using the revised stack diameter of 434.5 ft, and assign the square root (385 ft) of that area to each of the fugitive length and width fields. Do you agree with these changes? Thanks for looking into this for us. We really appreciate it. Let us know if you have any questions. Thomas Holloway RTI International ppsurvey@rti.org 1
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