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 4th floor (~223ft off the ground), inside a building in our Bleach Plant. This 

decker (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 = πr2) 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 know 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 corrections 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 4th, and, before that happens, I wanted to see if you had any changes 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 taking 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 Basin).

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 emission 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 height) 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 emission 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 = πr2) 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 stack 

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 = πr2) 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

1-877-834-7065