Georgia-Pacific 

VIA FEDERAL EXPRESS 

December 5, 2014 

The Honorable Gina McCarthy 

Office of the Administrator 

U.S. Environmental Protection Agency 

Room 3000, WJC Building 

1200 Pennsylvania Ave., NW 

Washington, DC 20460 

Georgia-Pacific LLC 

Traylor Champion 

Senior Vice-President, Environmental Affairs & 

Product Safety 

133 Peachtree Street NE 

Atlanta, Georgia 30303 

(404) 652-4776 

btchampl@gapac.com 

Re: Petition of Georgia-Pacific LLC for Reconsideration of EPA's Final Rule, 

''National Emission Standards for Hazardous Air Pollutants: Generic Maximum 

Achievable Control Technology Standards; and Manufacture of Amino/Phenolic 

Resins" 

Dear Administrator McCarthy, 

Georgia-Pacific LLC ("Georgia-Pacific") writes to request administrative reconsideration 

of the recently-announced rnle entitled "National Emission Standards for Hazardous Air 

Pollutants: Generic Maximum Achievable Control Technology Standards; and Manufacture of 

Amino/Phenolic Resins." 79 Fed. Reg. 60898 (Oct. 8, 2014) ("final rule" or "rule"). Our 

primary concern regarding this rule is the emissions standard for amino/phenolic resins 

production ("APR") for continuous process vents. In the proposed rule, the U.S. Environmental 

Protection Agency ("EPA" or the "Agency") expressed this standard as a percent reduction 

requirement. In the final rule, the standard was expressed as a production-based limit. GeorgiaPacific suggested in its comments on the proposed rule that EPA should adopt a productionbased limit and we continue to believe that such a form is appropriate. However, because EPA 

did not propose to adopt a production-based limit and did not include in the proposed rule key 

information that formed the basis of the final standard (such as the emissions and production 

information used to derive the standard), Georgia-Pacific did not have adequate notice of and 

opportunity to comment on the final production-based limit or essential data used in the 

development of the standard. 

Reconsideration of this rule is governed by§ 307(d)(7)(B) of the Clean Air Act ("CAA"), 

42 U.S.C. § 7607(d)(7)(B). This section provides that EPA "shall convene a proceeding for 

reconsideration of the rule" if "the person raising an objection" to the rule "can demonstrate to 

the Administrator that it was impracticable to raise such objection within [the public comment 

period] or if the grounds for such objection arose after the period for public comment (but within 

the time specified for judicial review)," provided that "such objection is of central relevance to 
The Honorable Gina McCarthy 

December 5, 2014 

Page2 

the outcome of the rule." 42 U.S.C. § 7607(d)(7)(B). As explained below, Georgia-Pacific's 

objections meet the CAA's standard for reconsideration. 

Because the mle is currently effective, Georgia-Pacific respectfully requests that EPA 

consider our petition expeditiously. If this matter cannot be quickly resolved, we request that 

EPA postpone the compliance deadline pending completion of the reconsideration process. 

This petition outlines the justification for reconsideration of the fmal rule. Section I 

explains how the proposed rule gave inadequate notice of the production-based standard that 

EPA adopted in the final rule. Section II details how this lack of notice impacted the final rule 

because it prevented Georgia-Pacific from notifying EPA of several flaws in the data used to 

calculate the MACT floor for continuous process vents. Finally, Section III lists the relief 

Georgia-Pacific seeks from the reconsideration process. 

I. The Proposed Rule Gave Inadequate Notice of the Production-Based Standard That 

Was Ultimately Adopted in the Final Rule 

In the final APR rule, EPA identified six units - all resin spray dryers - that are 

potentially subject to the final (rule's emission standards for continuous process vents. GeorgiaPacific owns and operates three of the six resin spray dryers. Georgia-Pacific's dryers 

predominantly dry phenolic resins (dry phenol-formaldehyde resins). Tembec Inc. operates the 

other three dryers, which produce only dry amino resins (urea-formaldehyde resins). 

On January 9, 2014, EPA published a proposed rule to amend the MACT standard for 

APR. 79 Fed. Reg. 1676 (Jan. 9, 2014). Prior to this proposal, EPA determined that two source 

types within the APR source category lacked a MACT emissions standard: "storage vessels and 

continuous process vents at existing facilities." Id. at 1701. EPA asserted that there were 

uncontrolled continuous process vents at two affected facilities: Georgia-Pacific's plant in 

Crossett, AR and Tembec's BTL Specialty Resins plant in Toledo, OH. EPA proposed "that the 

MACT floor level of control is to reduce organic HAP either by 85 percent or to a concentration 

of 20 parts per million by volume (ppmv), when using a combustion control device, or to a 

concentration of 50 ppmv when using a non-combustion control device." Id. at 1703. 

In its comments on the proposed rule, Georgia-Pacific informed EPA that there were 

additional continuous process vents that would be subject to the proposed rule. In addition, 

Georgia-Pacific reconunended that EPA "consider an uncontrolled production-based emission 

limit similar to that proposed for the Acrylic and Modacrylic Fibers (AMF) Production Source 

Category." Georgia-Pacific Comments at 2. We recommended this limit should be "based on 

the last 5 years of production, taking into account the expected variability in the drying of 

multiple resin types, at the facilities represented in the APR category with spray dryer continuous 

process vents." Id. at 6. To assist in this process, we submitted a summary of annual production 

and emissions data for our three continuous process vents. Id. Attachment B. 

EPA responded favorably in the final rule to Georgia-Pacific's comments. Instead of the 

85% reduction option, EPA promulgated a production-based standard of "0.95 kg organic 
The Honorable Gina McCarthy 

December 5, 2014 

Page 3 

HAP/Mg (1 .9 lb organic HAP/ton) of resin produced for continuous process vents." 79 Fed. 

Reg. at 60910. EPA determined this emission limit using the information Georgia-Pacific 

submitted in its comments and data submitted by Tembec to Ohio EPA (Tembec' s Annual Ohio 

EPA Emissions Inventory for 2009-2013). 

While we appreciate EPA' s effort to address our recommendations on the proposed rule 

and agree in concept with establishing production based limits, we unfortunately had no 

opportunity to offer comments on important details as to the basis for and ultimate level of the 

production-based standard that EPA adopted in the final rule. For example, we were unable to 

comment on flaws in the method that EPA used to calculate the production-standard or questions 

regarding the validity of Tembec's data. Similarly, Georgia-Pacific also did not have adequate 

notice that the 85% standard would be replaced with this production standard. In short, it was 

"impracticable to raise such objection[s]" during the public comment period because EPA's 

decision to set such a standard did not become apparent until well after the close of the public 

comment period. CAA§ 307(d)(7)(B). 

II. Georgia-Pacific's Objections to the Production-Based Limit Are of Central 

Relevance to the Outcome of the Rule 

The inadequate notice of the production-based standard resulted in a lost opportunity for 

Georgia-Pacific to comment on the proposal and the data on which it was based. Since the 

issuance of the final rule, Georgia-Pacific has spent considerable time analyzing the new 

production-based standard and the supporting data. Had Georgia-Pacific been afforded an 

opportunity to review this same info1mation during the public comment period, we would have 

raised a number of issues related to the data on which EPA relied in setting the standard and the 

methods that EPA used to calculate the standard. 

For example, Georgia-Pacific would have pointed out that the HAP emission rates that 

EPA attributed to Tembec's three dryers as part of the Agency's MACT floor calculations do not 

account for all HAP emissions from these three units. Under CAA section 112, the MACT floor 

for existing sources "may be less stringent than standards for new sources in the same category 

or subcategory but shall not be less stringent than ... the average emission limitation achieved 

by the best performing 5 sources (for which the Administrator has or could reasonably obtain 

emissions information) in the category or subcategory for categories or subcategories with fewer 

than 30 sources." 42 U.S.C. § 7412(d)(3). Because there are only six sources, EPA used what it 

determined to be the best five sources: Tembec's three dryers (A, B, and C) and GeorgiaPacific's dryers (D and E). 

A review of all of the emissions data Tembec submitted to EPA after the close of the 

comment period demonstrates that the data EPA relied upon did not account for all HAP 

emissions from Tembec's three dryers. Tembec provided EPA with emissions test reports and 

emissions inventory reports, yet EPA relied exclusively on Tembec's emissions inventory data to 

derive the HAP emission rates used in the Agency's MACT floor analysis. The emissions 

inventory data, however, failed to account for all of the methanol and formaldehyde emissions, 

as demonstrated by testing conducted by Tembec on dryer Bin October of 2006. A summary of 
The Honorable Gina McCarthy 

December 5, 2014 

Page4 

the results was e-mailed by Tembec to EPA on May 7, 2014 (see EPA-HQ-OAR-201 2-0133-

0058). The significance of this oversight is captured in EPA's own comments accompanying the 

proposed rule, where the Agency noted that " [m]ethanol, foimaldehyde and phenol account for 

the majority of the HAP emissions from the APR production processes" for the entire source 

category. 79 Fed. Reg. at 1683. Thus, the omission of methanol and fo1maldehyde emissions 

caused EPA to significantly underestimate the total HAP emissions from Tembec's sources. 

As the following table shows, the production-based HAP emission rate for the three 

Tembec dryers should be much higher than EPA's calculated values. These provisional 

calculations are based on provisional estimates ofTembec's methanol and formaldehyde 

emissions derived from Tembec's emissions inventory data and the emissions test reports 

Tembec previously submitted to EP A. 1 This conection would have significantly altered EPA's 

assessment of the MACT floor, which is "the average emission limitation achieved by the best 

performing 5 sources." 42 U.S.C. § 7412(d)(3). A review of the emissions data from the 

Provisional Calculations would suggest that none of the affected sources in the MACT floor 

could comply with the promulgated standard of 1.9 lbs. organic HAP/ton ofresin produced. 

MACT Floor and Production-Based 

Emission Limit for Spray Dryers 

EPA ID 

Dryer A (Tembec) 

Dryer B (Tembec) 

Dryer C (Tembec) 

Dryer D (GP) 

Dryer E (GP) 

Dryer F (GP) 

Median 

Mean or Average 

Standard Deviation 

%Std. Dev. 

Pounds of HAP/Ton of 

Resin Produced 

(EPA's Calculations) 

0.1 

0.2 

0.74 

8.7 

10.4 

13.46 

0.74 

4.0 

5.1 

127 

Emission Limit - Mean 10.2 

Pounds of HAP/Ton of 

Resin Produced 

(Provisional Calculations) 

6.4 

3,8 

3.2 

8.7 

11.5 

14.5 

6.4 

6.7 

3.5 

51.4 

6.9 

Emission limit- Median 1.9 6.6 

1 Upon request, Georgia-Pacific can provide details of the calculations behind the numbers in this table. 
The Honorable Gina McCarthy 

December 5, 2014 

Page 5 

Even if the data EPA relied upon had fully accounted for Tembec's HAP emissions, 

however, at least three errors in EPA's calculations remain. First, we believe that the dryer 

emission rate was improperly calculated. We believe that EPA calculated the emission rate by 

dividing the 5-year total emissions by the 5-year total resin production. This approach would 

mute the effect of shorter-te1m variability that we believe exists in production rates and 

conesponding HAP emissions, thus producing an emissions standard that does not adequately 

account for variability. We believe that the better approach - one that would better represent the 

actual variability experienced by the affected units - would be to calculate the standard by taking 

the maximum emission rate per ton of production from the 5-years data set. This is illustrated in 

the table above in the revised calculations for resin spray dryers A, B, C, D and E, which reflect 

a shift from calculating the standard using 5-year totals to using the average of the 1-year totals. 

Another relevant approach for calculating the production-based emission limit and accounting 

for the variability in the data is to apply a 99% upper prediction limit ("UPL") which results in a 

calculated 13. 8 lbs organic HAP /ton of resin produced. 

Second, EPA calculated the MACT floor and emission limit by taking the median of the 

best performing sources instead of the mean. We understand that EPA' s longstanding position is 

that the term "average" as used in§ l 12(d) should be constrned as any appropriate measure of 

central tendency - which might include the arithmetic average, but also might include other 

measures of central tendency such as the mode or median. We believe, however, that the better 

reading of the statute is that the term "average" unambiguously means "arithmetic average." 

And, in any event, even if that term might permissibly be interpreted to mean the "median" in 

some cases, use of the median in this case is not reasonable because it produces an emissions 

limit that is not representative of two of the five best performing units. As the table above 

shows, if EPA had used the mean value, the emission limit would have better reflected the 

performance of the Georgia-Pacific units. 

Third, EPA's calculations do not account for the recent change in control technology for 

Tembec's Dryer A. We understand that in 2012, Tembec replaced Dryer A's wet scrnbber with 

a baghouse to improve the control of particulate matter. The conesponding increase in HAP 

emissions associated with this change in control technology was not captured in the HAP 

emission data reported in Tembec's 2012 and 2013 emissions inventory reports, and thus was not 

incorporated into the HAP emission rate that EPA attributed to Dryer A in the Agency's MACT 

floor analysis. Georgia-Pacific does not believe it is appropriate to rely on emissions data for 

Dryer A that do not reflect the current configuration of that unit. 

If EPA agrees to grant this reconsideration request, Georgia-Pacific believes that the 

revised standard should be based on better emissions infmmation than currently is available from 

either Georgia-Pacific or Tembec. To that end, Georgia-Pacific is prepared in the very near term 

to conduct HAP emissions testing at each of its three affected spray dryers. We believe that 

Tembec also is prepared to test its three affected units. We have contacted EPA staff at the 

Emissions Measurement Center to discuss the preferred EPA test methodology to measure HAPs 

emissions from resin spray dryers. If reconsideration is granted, we will let you know once this 

task is completed and coordinate with EPA on completing the testing. 
The Honorable Gina McCarthy 

December 5, 2014 

Page 6 

Lastly, Georgia-Pacific notes that the available data suggest the possibility that 

subcategorization may be appropriate. Even with the provisional calculations presented above, 

the emissions rates from Georgia-Pacific's spray dryers appear to be significantly higher that the 

emissions rates from Tembec's spray dryers. While there are differences in the emissions 

controls on the various affected units, we do not believe that the difference in emissions rates is 

solely or predominantly attributable to that factor. We think the difference in emissions rates 

likely is attributable to fundamental differences in the design and operating characteristics of our 

units versus Tembec's - such as differences in resins types (phenolic resins for us versus ureaformaldehyde resins for Tembec) or differences in the size of the spray dryers (ours are 

significantly larger than Tembec's). Had Georgia-Pacific been able to comment on a proposal 

for a production-based standard and the accompanying data, we could have assessed these 

differences and possibly suggested that subcategorization is wananted. If EPA goes forward 

with reconsideration, this is an issue that should be explored. 

III. Requested Relief 

For the reasons discussed above, Georgia-Pacific respectfully requests EPA grant 

reconsideration of the final rule. Georgia-Pacific seeks the opportunity to work with EPA in 

developing revised proposed production-based standards and to comment on the proposed 

standards before they are finalized. To assist in that process, Georgia-Pacific would be willing to 

conduct HAP emissions testing on its affected spray dryers and submit this information to EPA 

for use in developing the revised standards. Because the rule cunently is effective, we ask for 

expeditious consideration of this request. If reconsideration cannot be completed reasonably 

quicldy, we believe that an extension of the compliance deadline may become warranted. 

Lastly, if EPA grants reconsideration on the spray dryer limits, we ask that EPA also 

consider revising the final rule to address one additional issue. The final rule expands the 

applicability of the storage tank standards "to be consistent with other storage vessel standards 

already required for the chemical industry regulated by the Hazardous Organic NESHAP for 

Synthetic Organic Chemical Manufacturing Industry (HON)." 79 Fed. Reg. at 60909. We do 

not object to the Agency's decision to expand applicability. But, in order to meet the goal of 

being wholly consistent with the HON storage tank standards, EPA also should include in the 

APR rule the HON storage vessel allowance for routine maintenance of a control device ( 40 

CFR § 63 .119( e )(3)) and the exemption for outages for processes reclaiming tank emissions 

when the liquid level in the tank is not increased during a process outage (Id. at§ 63.119(f)(3)). 

In addition to ensuring consistency, these provisions are needed because it is not possible 

without great effort to eliminate HAP emissions from a storage tank when non-routine conditions 

arise (such as a control device outage or a process outage). And, the effort to empty and degas a 

tank in many cases could result in greater HAP emissions than would occur if a limited 

allowance or exception were otherwise provided. 

* * * * * * * * * * 
The Honorable Gina McCarthy 

December 5, 2014 

Page 7 

Thank you for your consideration of this request. Please do not hesitate to contact me if 

you have questions or need more information. 

Sincerely, 

Senior Vice-President, Environmental Affairs & Product Safety 

Georgia-Pacific LLC 

cc: P. Tsirigotis (via e-mail) 

P. Lassiter (via e-mail)