Document x5r165Q3BjELjvM909m8zb25m

Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY (US EPA) REGION 6, 1445 ROSS AVENUE, DALLAS, TX 75202 EMERGENCY PLANNING AND COMMUNITY RIGHT TO KNOW ACT (EPCRA) SECTION 313 INSPECTION REPORT Report date: June 23, 2014 Revised: July 23, 2014 I. ESTABLISHMENT COVERED BY THIS INSPECTION REPORT This inspection reports covers only the Georgia-Pacific Crossett Pulp and Paper Operations which reported as a separate establishment. The other two Georgia-Pacific establishments (the Chemical Operations and the Plywood/Stud Mill) will be covered in separate inspection reports. II. FACILITY (ESTABLISHMENT) INSPECTED Inspection date: March 19, 2014 Name & address: Georgia-Pacific Crossett Paper Operations 100 Mill Supply Road Crossett, AR 71635 870-567-8000 Mailing address: Georgia-Pacific Crossett Paper Operations PO Box 3333 Crossett, AR 71635 Parent: Koch Industries, Inc. DUNS: 006944334 III. GEORGIA-PACIFIC CROSSETT, ARKANSAS COMPLEX The Georgia-Pacific Crossett, Arkansas Complex has consisted of the three establishments shown below over the period of the inspections Page 1 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Pulp and Paper Operations establishment (2008 to 2012, five years) (this report) PULP AND PAPER OPERATIONS NAICS code Primary Description 322110 Yes Pulp mills 322121 No Paper (except newsprint) mills 322130 No Paperboard mills Chemicals Operations establishment (2008 to 2012, five years) CHEMICALS OPERATIONS NAICS code Primary Description 325211 Yes Plastics material and resin manufacturing 325199 No All other basic organic chemical manufacturing 325191 No Gum and wood chemical manufacturing Plywood/Stud Mill establishment (2008 to 2011, four years) (operations at this establishment were idled in October 2011) (Attachment 1) PLYWOOD/STUD MILL NAICS code Primary Description 321212 Yes Softwood veneer and plywood manufacturing 321113 No Sawmills The reporting by year for each establishment is shown in the table below: REPORTING YEARS FOR EACH ESTABLISHMENT Establishment 2012 2011 2010 Pulp and Paper Operations Reported Reported Reported 2009 Reported 2008 Reported Chemicals Operations Reported Reported Reported Reported Reported Plywood/Stud Mill Note 1 Reported Reported Reported Reported Note 1: The Plywood/Stud Mill idled operations in October 2011 (Attachment 1). Page 2 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ IV. SEND REPLY TO The reply to the inspection report should be sent to: James W. Cutbirth Environmental Affairs Manager Georgia-Pacific Crossett Paper Operations PO Box 3333 Crossett, AR 71635 870-567-8144 Email: james.cutbirth@gapac.com The senior manager at the facility is: Gary W. Kaiser Vice President, Manufacturing Plant Manager Georgia-Pacific Crossett Paper Operations PO Box 3333 Crossett, AR 71635 V. INTRODUCTION EPCRA (Emergency Planning and Community Right to Know Act) 313 is also referred to as the TRI (Toxic Release Inventory). TRI is the actual name of the database which houses the information collected pursuant to EPCRA 313. This report documents the March 19, 2014, EPCRA 313 inspection of only the Georgia-Pacific Crossett Pulp and Paper Operations located in Crossett, Arkansas. The inspection was to determine compliance with EPCRA 313 reporting requirements. The inspection covered the reporting years 2008 to 2012. The Arkansas Department of Emergency Management was notified prior to the inspection as a courtesy (Attachment 2). No state has primary enforcement under EPCRA 313. The following information applies to the Pulp and Paper Operations establishment: Page 3 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ TRI identification number: 71635GRGPCPAPER NAICS code: 322110, pulp mills (primary) 322121, paper (except newsprint) mills 322130 paperboard mills DUNS numbers: 009020777, 132076480 (shown on the 2012 Form R, Attachment 17) Lat: 33.141395 (FRS, no collection method shown) (Attachment 3) Lon: -91.97395 (FRS, no collection method shown) (Attachment 3) Web site: www.gp.com Facility/parent state of incorporation: Delaware (Attachment 4) VI. BUSINESS RELATED INFORMATION The Crossett paper mill makes a variety of tissue, towel, paper and paperboard products (Attachment 5). Among the brands manufactured are Quilted Northern bath tissue, Angel Soft bath tissue and Sparkle paper towels. The facility operates its own pulping process prior to the paper and paperboard making operations. Information from the establishment's web site is shown in Attachments 5 and 6. Information from the 2010 Arkansas Manufacturers Register is shown in Attachment 7. Georgia-Pacific owns approximately 10,000 acres on which the Pulp and Paper Operations, the Chemical Operations, the Plywood/Stud Mill and the wastewater treatment plant are located. VII. ENVIRONMENTAL JUSTICE The Georgia-Pacific Pulp and Paper Operations meets the criteria for being a "Potential Environmental Justice Area of Concern". Details are shown in Attachment 8. Page 4 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ VIII. PRE AND POST INSPECTION CONTACTS Date 2-282014 2-282014 3-142014 3-192014 Type of contact Phone to Email & USPS Email to Phone to Person James Cutbirth & Richard Freeman James Cutbirth Richard Freeman James Cutbirth 3-202014 3-212014 3-272014 3-282014 3-282014 3-312014 3-312014 3-312014 4-1-2014 4-1-2014 4-1-2014 4-2-2014 In person In person Email to Email to Email to Email from Email to Email from Phone to Email to Email from Email to James Cutbirth James Cutbirth James Cutbirth James Cutbirth James Cutbirth James Cutbirth James Cutbirth James Cutbirth James Cutbirth James Cutbirth James Cutbirth James Cutbirth Comments Discussed upcoming inspection Notification of the upcoming inspection (Attachment 9) Requested directions Asked for a copy of Ms. Sarah Ross' list of questions and information requested. Cutbirth stated that the process flow diagram was not Confidential Business Information (CBI) Delivered additional information Delivered additional information Questions on hydrogen sulfide (Attachment 10). Questions on miscellaneous chemicals (Attachment 11). Questions on C -12 flow chart (Attachment 12). Answers on hydrogen sulfide questions (Attachment 10). Questions on C-2 flow chart (Attachment 10). Answer to questions on C-2 flow chart (Attachment 10). Questions about where H2S is manufactured. Question on non-condensable gases (Attachment 13). Request for copy of inspection report and answers to questions (Attachment 14) Questions on line 1 washer and decker (Attachment 15) Page 5 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ PRE AND POST INSPECTION CONTACTS CONTINUED Date Type of Person Comments contact 4-3-2014 Letter to James Request for MSDS's (Attachment 18). Cutbirth 4-3-2014 Email James Answers on line 1 washer and decker from Cutbirth (Attachment 15). 4-7-2014 Email to James Questions on 2012 lead and lead compounds Cutbirth (CBI Folder 2, tab 13). 4-7-2014 Email & James Answers to questions poised during the 8 at. Cutbirth inspection (CBI Folder 2, tabs 4, 5, 6, 7, and 8 from and Attachment 41). 4-7-2014 Email to James Questioned if the information sent earlier in the Cutbirth day CBI (Attachment 20). 4-7-2014 Email to James Questions 2012 chlorine dioxide usage Cutbirth (CBI Folder 2, tab 12). 4-7-2014 Email to James Inspector's error on question about 2011 Form R Cutbirth for barium compounds (Attachment 21) 4-7-2014 Email James Reply on barium compounds (Attachment 21). from Cutbirth 4-8-2014 Email to James Requested information for Dr. Wakeland on Cutbirth NAICS codes (Attachment 19) 4-8-2014 Email to Wakeland to Questions on the basis of estimate for releases James (Attachment 22). Cutbirth 4-8-2014 Email James Reply to basis of estimate questions from Cutbirth to (Attachment 22). Wakeland 4-9-2014 Email to Wakeland to Additional comments on the basis of estimate James (Attachment 22). Cutbirth 4-9-2014 Email to James Question on the products of combustion Cutbirth (Attachment 23) 4-9-2014 Email to James Question on hydrogen sulfide Cutbirth (CBI Folder 2, tab 14). 4-9-2014 Email to James Question on burning used (waste) oil Cutbirth (Attachment 24). 4-10- Email to James Question, where H2S is manufactured 2014 Cutbirth (Attachment 25). 4-11- Email James Answers to the burning of used oil 2014 from Cutbirth (Attachment 24). 4-11- Email James Answers to questions on chlorine dioxide 2014 from Cutbirth (CBI Folder 2, tab 12). Page 6 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ PRE AND POST INSPECTION CONTACTS CONTINUED Date Type of Person Comments contact 4-11- Email to James Question on Saline River Water Plant and single 2014 Cutbirth hog fuel pile (Attachment 26). 4-11- Email James Reply on the basis of estimate (Attachment 22). 2014 from Cutbirth to Wakeland 4-15- Email James Answers to questions on Saline River Plant and 2014 from Cutbirth hog fuel pile (Attachment 26). 4-16- Email to James Question on acetaldehyde (CBI Folder 2, tab 11). 2014 Cutbirth 4-17- Email James MSDS's are in the mail (Attachment 27). 2014 from Cutbirth 4-17- Email James Reply to Dr. Wakeland's question on NAICS 2014 from Cutbirth codes (Attachment 19). 4-21- Email James Reply on products of combustion 2014 from Cutbirth (Attachment 23). 4-22- Email to James Request methods of determining TRS releases 2014 Cutbirth (Attachment 27). 4-22- Email to James Questions on lead compounds (Attachment 28). 2014 Cutbirth 4-25- Email James Reply to questions on lead compounds 2014 from Cutbirth (Attachment 28). 4-25- Email James Reply to question on acetaldehyde 2014 from Cutbirth (CBI Folder, tab 11). 5-5-2014 Email James Answers to questions on hydrogen sulfide, TRS from Cutbirth and where H2S is manufactured (CBI Folder 2, tab 15). 5-20- Email to James Questions on C -12 flow chart (Attachment 12). 2014 Cutbirth 5-21- Email James Replied to question on C-12 flow chart 2014 from Cutbirth (Attachment 12) 5-29- Phone Rebecca James Cutbirth busy. Will return phone call 2014 from Blankenship later. 5-30- Email to James Request for information (Attachment 29). 2014 Cutbirth 5-30- Email to James Request for information (Attachment 30). 2014 Cutbirth Page 7 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ PRE AND POST INSPECTION CONTACTS CONTINUED Date Type of Person Comments contact 6-4-2014 Email to James Conference call and comments on CBI Cutbirth from (confidential business information). Morton Wakeland 6-6-2014 Email to James Conference call schedule, 9:30 am, 6-11,2014 Cutbirth 6-9-2014 Email to James Confirmed 6-11-2014 meeting and asked for Cutbirth from information prior to the meeting Mort (Attachment 62). Wakeland 6-10- Email James Conference call notice 2014 from Cutbirth 6-10- Email James Conference call notice 2014 from Cutbirth 6-10- Email to James Three more questions (Attachment 31). 2014 Cutbirth 6-10- Email James Information for conference call and answers to 2014 from Cutbirth questions (Attachments 32, 33 and CBI Folder 2, tab 17). 6-11- Email to James Confirmed receipt of information for conference 2014 Cutbirth from call and answers to questions. Morton Wakeland 6-11- Phone to James Requested conference call phone number. 2014 Cutbirth 6-11- Confere James Discussion on information contained in 2014 nce call Cutbirth and spreadsheets. GP people on conference call; others James Cutbirth, Richard Freeman, Mayes Starke, Mark Ruppel, Aimee Risher 6-11- Email to James Thank everyone for conference call input. 2014 Cutbirth from Morton Wakeland 6-20- Email James Reply to information requested during the 2014 from Cutbirth 6-11-2014 conference call. Reply was addressed to Wakeland and Stranne. (Attachment 64) 7-2-2014 Voice James Wants to discuss up dating flow chart. mail Cutbirth from Page 8 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Date 7-2-2014 7-3-2014 7-3-2014 7-112014 7-112014 7-112014 7-152014 7-222014 7-222014 Type of contact Email from Email to Email to Email from Email to Email from Email from Email to Email from Person James Cutbirth James Cutbirth James Cutbirth Richard Freeman Richard Freeman James Cutbirth James Cutbirth Morton Wakeland to James Cutbirth James Cutbirth to Morton Wakeland Comments Needs clarification on flow chart changes (Attachment 65). Please phone on Monday (Attachment 65). Questions for discussion on Monday.(Attachment 65). Provided revised flow charts (Attachment 38). Acknowledged receipt of revised flow charts (Attachment 38). Suggested changes to the draft inspection report (Attachment 66). Request for copy of Attachment 8 to the inspection report (Attachment 67). Provided copy of Attachment 8 (Attachment 67). Acknowledged receipt of Attachment 8 (Attachment 67). IX. INSPECTOR Lawrence V. Stranne, P.E. EPCRA 313 Inspector US EPA Region 6 1445 Ross Avenue Dallas, TX 75202 214-665-7337 Fax: 214-665-6655 E-mail: stranne.lawrence@epa.gov Page 9 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ X. PERSONS INTERVIEWED (Opening and closing conferences) Gary W. Kaiser Vice President, Manufacturing Plant Manager Georgia-Pacific Crossett Paper Operations PO Box 3333 Crossett, AR 71635 James W. Cutbirth Environmental Affairs Manager Georgia-Pacific Crossett Paper Operations PO Box 3333 Crossett, AR 71635 870-567-8144 Email: james.cutbirth@gapac.com Richard J. Freeman Environmental Engineer Georgia-Pacific Crossett Paper Operations PO Box 3333 Crossett, AR 71635 870-567-8177 Email: rjfreema@gapac.com Mr. Freeman was the Form R Technical Contact for 2012 reporting. Sarah M. Ross Georgia-Pacific Crossett Paper Operations PO Box 3333 Crossett, AR 71635 Rachel Johnson Georgia-Pacific Crossett Paper Operations PO Box 3333 Crossett, AR 71635 Page 10 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Saul J. Furstein, P.E. Sr. Environmental Consultant Environmental Affairs, Technical Support Georgia-Pacific 113 Peachtree Street, NE PO Box 105605 Atlanta, GA 30348-5603 404-652-5243 Email: sjfurste@gapac.com (Closing conference) John C. Bottini Senior Counsel Environmental Law Department Georgia-Pacific Chemicals 133 Peachtree Street, NE Atlanta, GA 30303-5605 404-652-4883 Email: john.bottini@gapac.com Mark Ruppel Headquarters Georgia-Pacific (Conference call) Aimee Risher Technical Support, Headquarters Georgia-Pacific (Closing conference) Scott Bailey Environmental Manager (NACP) Headquarters Georgia-Pacific (Conference call) Mayes Starke Technical Support, Water Headquarters Georgia-Pacific An attendance listing is shown in Attachment 35. Page 11 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ XI. ENVIRONMENTAL CONSULTANT USED FOR TRI REPORTING None. XII. INSPECTION A. OPENING CONFERENCE After arriving at the facility at approximately 8:15 am on March 19, 2014, I presented my credentials to Mr. Kaiser and the Staff. The purpose of the inspection was explained as a determination of compliance with EPCRA 313 toxic chemical release reporting requirements for the reporting years 2008 to 2012. The information sheets for the following areas were given to the facility: TRI-MEweb online reporting EPCRA 313 Region 6 staff U.S. EPA Small Business Resources Superfund, TRI, EPCRA, RMP& Oil Information Center Chemical Safety Awareness for Industrial and Municipal Facilities Attachment 36 is a map of the facility. Attachment 37 is a process flow diagram for the facility collected at the time of the inspection In an email dated July 11, 2014, Mr. Richard Freeman provided the following updated flow charts to replace the corresponding pages in Attachment 37 (Attachment 38): Figure C-2, pulp mill Figure C-5, causticizing area Figure C-12, wastewater treatment B. CONFIDENTIAL BUSINESS INFORMATION (CBI) Some of the material collected at the time of the inspection was marked CONFIDENTIAL BUSINESS INFORMATION (CBI). The CBI information collected at the time of the inspection was printed on 8-1/2 inch by 14 inch paper and is included in CBI Folder 1. CBI collected or generated since the inspection is included in CBI Folder 2. When the inspection report is complete both of the CBI folders will be given to the EPCRA 313 CBI Officer, David Riley. Page 12 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ C. REQUEST FOR A COPY OF COMPLETED INSPECTION REPORT In an email dated April 1, 2014, Mr. Cutbirth requested a copy of the completed inspection report (Attachment 39). D. RATIONAL FOR THE GP COMPLEX REPORTING AS THREE SEPARATE ELSTABLISHMENTS. The Georgia-Pacific Crossett Complex consisted of three establishment from 2008 to 2011. The Plywood/Stud Mill idled operations in October 2011 which resulted in only two establishment reporting in 2012. The Staff explained that each of the three establishments (the Pulp and Paper Operations, the Chemicals Operations and the Plywood/Stud Mill) is in a different Division of GP. Each Division has its own chain of management and financial results. GP Management wanted the environmental reporting also separated by the three Divisions. E. PREVIOUS RCRA (RESOURCE CONSERVATION and RECOVERY ACT INSPECTION, APRIL 10-12, 2012 The establishment's web site noted a prior RCRA (Resource Conservation and Recovery Act) inspection on April 10, 2012, (Attachment 39). A copy of the RCRA inspection report is shown in Attachment 40. F. STATUS OF INFORMATION REQUESTED PRIOR TO THE INSPECTION In an email and USPS letter dated February 28, 2014, Mr. James Cutbirth was requested to provide information at the time of the inspection (Attachment 9). All of the information was available at the time of the inspection. Additional information and corrected information was requested with an expected delivery date of April 9, 2014. The information was received as requested. Ms. Sarah Ross took notes during the inspection and a copy of her March 20, 2014, notes related to additional information to be provided is shown in Attachment 61. G. INFORMATION REQUESTED SUBSEQUENT TO THE INSPECTION In a letter sent April 3, 2014, Mr. James Cutbirth was requested to supply copies of the MSDS for all products used by the facility that contained TRI chemicals (Attachment 18). In an email dated April 17, 2014, Mr. Cutbirth said that the MSDS's were in the mail (Attachment 18). The letter attached to the email contained a listing of the MSDS's that were being sent. The MSDS's were received on April 18, 2014, by FedEx. The MSDS's were placed in the file folder. Page 13 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ H. FACILITY OWNERSHIP INFORMATION Georgia-Pacific has owned and operated the GP Crossett Paper Operations during the period of the inspection, reporting years 2008 to 2012 (Attachment 6). I. FACILITY INFORMATION, EMPLOYEES AND GROSS SALES The facility currently has approximately 1,250 employees. Mr. Kaiser provided the following number of employees and sales (Attachment 4). ESTABLISHMENT EMPLOYEES AND SALES Reporting year More or less than 50 employees More or less than $10 million sales 2112 More than More than 2011 More than More than 2010 More than More than 2009 More than More than 2008 More than More than J. MONITORING / MEASUREMENT DATA COLLECTION In his letter dated March 20, 2014, Mr. Gary Kaiser provided the following information on the collecting, monitoring and measurement data (Attachment 4 starting on page four). As set forth in more detail in the calculation spreadsheets that will be provided during your visit, GP's Paper and Pulp Facility utilizes many different types of data collected pursuant to regulatory monitoring/measurement requirements to calculate releases of EPCRA 313 chemicals utilized at the Facility. The following chart summarizes those regulatory monitoring/measurement requirements for which the Facility gathers monitoring or measurement data on an ongoing basis. Please note that based on our understanding of the scope of your information request, this chart does not include all ongoing monitoring or measurements that the Facility may collect for reasons other than regulatory compliance, nor does it include every monitoring or measurement that the Facility may have conducted for regulatory applicability or permitting purposes. To the extent the Facility relies on any monitoring or measurements to support its calculations of EPCRA 313 chemical releases, such data and the corresponding calculation methodologies for particular reporting years are available in the spreadsheets that will be provided during your visit. Page 14 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Page 15 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ K. WASTEWATER TREATMENT In an email dated July 11, 2014, Mr. James Cutbirth provided the following description of the wastewater treatment process (Attachment 66): Page 16 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Page 17 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ L. PROCESS WATER Make up process water is drawn from Lake Georgia-Pacific which is north of the facility. The water is chlorinated and distributed to the Pulp and Paper Operations, the Chemicals Operations and the Plywood/Stud Mill. In an email dated April 11, 2014, Mr. Cutbirth was asked to provide additional information on the source of the process water supply (Attachment 26). In an email dated April 15, 2014, Mr. Cutbirth provided the following reply. Water is pumped from the Saline River into GP Lake. From GP Lake, the water is pumped approximately seven miles to the Saline River Treatment Plant located within the utilities area of the mill. At the plant the water is treated for turbidity. Turbidity is cloudiness or haziness of the water caused by individual particles (total suspended or dissolved solids). M. POTABLE WATER Potable water (drinking quality water) for the Paper and Pulp Operations is drawn from nearby company owned wells and chlorinated. N. LANDFILLS In an email dated June 2, 2014, Mr. Cutbirth described the facility's landfills as shown below (Attachment 64): We have two Non-Commercial Class 3 solid waste landfills. One is for construction and demolition debris and the other is used for primarily paper and paper related waste; it is a Sub-title D landfill. There is also one land reclamation area, referred to as the sludge basin in Figure C-12. It is located near the primary clarifier. It is used for the disposal of dewatered sludge taken from the primary clarifier and boiler ash removed from the ash settling basins. O. RAW MATERIAL The major raw materials are: Pine and hardwood logs The major fuels are hog fuel (chipped wood waste), TFD (tire derived fuel), natural gas and oil. Page 18 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ P. PROCESS DESCRIPTION A process description provided by GR is shown on the following page (Attachment 4). Page 19 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Attachments 37 and 38 are process flow diagrams for the facility collected at the time of the inspection (37) and later revised (38). A description of the pulping process from the Wikipedia Encyclopedia is shown in Attachment 42. Q. FINAL PRODUCTS After manufacturing the wood pulp the Pulp and Paper Operations manufactures a variety of tissue, towel, paper and paperboard products (Attachment 5). Among the brands manufactured are Quilted Northern bath tissue, Angel Soft bath tissue and Sparkle paper towels. Byproducts of the pulping operation are turpentine and soap (page 6 of Attachment 42). R. ORIGINAL POSTMARK DATES OF SUBMITTED FORM R's/A's The original postmark dates of the Form R's submitted for reporting years 2008 to 2012 were on or before the final due date with the exception of the one chemical shown below (Attachment 43): CHEMICAL REPORTED LATE Reporting year Chemical Due date 2011 Nitrate compounds July 2, 2012 Postmark date Note 1 June 24, 2013 Period late 357 days Note 1: The term postmark date includes the actual postmark dates and the certification dates for Form R/A's sent electronically through TRI-MEweb. Nitrate compounds were reported on time for reporting year 2012 but were not reported for reporting years 2008, 2009 and 2010. S. TRI CHEMICALS REPORTED TO THE EPA (ENVIRONMENTAL PROTECTION AGENCY Attachment 45 is a listing showing the number of establishment that reported each chemical. At the time of the inspection the facility provided spreadsheets for the calculation of chemical usages and releases (CBI Folder 1). The spreadsheets included some of the formulas and basic calculations used in determining the threshold usage and emission values. Page 20 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ In an email dated April 7, 2014, Mr. Cutbirth provided summary spreadsheets for chemical threshold usage at all three establishment (CBI Folder 2, tabs 4, 5, 6, 7and 8). The table below shows the chemicals reported by the Paper and Pulp Operations (Attachment 45). CHEMICALS REPORTED TO THE TRI Chemical 2012 2011 Acetaldehyde Reported Reported 2010 Reported 2009 Reported 2008 Reported Ammonia Reported Reported Reported Reported Reported Barium compounds Reported Reported Reported Reported Reported Benzo(g,h,i)perylene Reported Reported Reported Reported Reported Catechol Reported Reported Reported Reported Reported Chlorine Reported Reported Reported Reported Reported Chlorine dioxide Reported Reported Reported Reported Reported Cresol (mixed isomers) Dioxin & dioxin like compounds Ethylene glycol Reported Reported Reported Formaldehyde Reported Reported Reported Reported Reported Reported Reported Reported Reported Reported Reported Below threshold NOTE 1 Reported Reported Reported Reported Reported Formic acid Reported Reported Reported Reported Reported Hydrochloric acid aerosols Hydrogen sulfide Lead compounds Reported Reported Reported Reported Not required Reported Reported Not required Reported Reported Not required Reported Reported Not required Reported Page 21 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ CHEMICALS REPORTED TO TRI CONTINUED Chemical 2012 2011 2010 Manganese Reported Reported Reported compounds Methanol Reported Reported Reported 2009 Reported Reported 2008 Reported Reported Nitrate compounds Reported Reported Below threshold Below threshold Below threshold Phenol Reported Reported NOTE 1 Reported NOTE 1 Reported NOTE 1 Reported Polycyclic aromatic compounds Sulfuric acid aerosols Reported Below threshold Reported Below threshold Reported Below threshold Reported Below threshold Reported Reported Toluene NOTE 1 Reported NOTE 1 Reported NOTE 1 Reported NOTE 1 Reported Reported Vanadium compounds Zinc compounds Reported Reported Reported Reported Reported Reported Reported Reported Reported Reported NOTE 1: An analysis of chemical usage is shown in CBI Folder 2 tab 16. T. CHEMICALS OF INTEREST IDENTIFIED PRIOR TO THE INSPECTION Hydrogen Sulfide (H2S) Hydrogen sulfide was added to the TRI chemical list via the Federal Register December 1, 1993. However, on August 22, 1994, an administrative stay of the reporting requirement was imposed. The stay was lifted effective October 1, 2011, with the first reports due July 1, 2013. The facility utilized a model generally described in the study "Estimating H2S and Methyl Mercaptan Emissions from Wastewater Treatment Systems" for estimating H2S (hydrogen sulfide) emissions at the wastewater plant (Attachment 46). The study separately analyses emissions of hydrogen sulfide and methyl mercaptan. Page 22 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ In an email dated June 10, 2014, Mr. Cutbirth provided a condensed version of the slides from the above study showing only the slides that address the specific manner in which GP conducted its calculations (Attachment 33). Mr. Furstein provided a listing of hydrogen sulfide releases from just paper and pulp mills. The Crossett Pulp and Paper Operations ranked number 4 from the top of hydrogen sulfide releasers in the Nation (Attachment 47). Shown below are the top five H2S releasers: 1. Rayonier Performance Fibers Jesup Mill, 4470 Savanna Hwy, Jesup, GA 31545 2. Georgia-Pacific Monticello LLC Sandifer Hwy, 5 Miles N of Monticello, Monticello, Mississippi 39654 3. International Paper, 100 Jensen Rd, Prattyville, Alabama 36067 4. Georgia-Pacific Plywood/Stud Mill Complex, 101 Plywood Mill Rd, Crossett, Arkansas (This is the name that the GP Pulp and Paper Operations reports under) 5. International Paper - Vicksburg Mill, 3737 Hwy 3 N, Redwood, Mississippi, 39156 Mr. Furstein provided a second listing of hydrogen sulfide releases from all industries. The Crossett Pulp and Paper Operations ranked number 6 from the top of hydrogen sulfide releases (Attachment 48). Shown below are the top five releasers: 1. Jal Gas Plant, 115 Sid Richardson Rd, Jal, New Mexico 88252 2. PCS Phosphate Co Inc., 1530 NC Hwy 306S, Aurora, North Carolina 27806 3. Rayonier Performance Fibers Jesup Mill, 4470 Savannah Hwy, Jesup, Georgia 31545 4. Georgia-Pacific Monticello LLC Sandifer Hwy, 5 Miles N of Monticello, Monticello, Mississippi 39654 5. International Paper, 100 Jensen Rd, Prattyville, Alabama 36067 6. Georgia-Pacific Plywood/Stud Mill Complex, 101 Plywood Mill Rd, Crossett, Arkansas (This is the name that the GP Pulp and Paper Operations reports under) 7. International Paper - Vicksburg Mill, 3737 Hwy 3 N, Redwood, Mississippi, 39156 Hydrogen sulfide (H2S) was manufactured (including coincidental), processed and/or otherwise used only at the Pulp and Paper Operations. The Chemicals Operations and the Plywood/Stud Mill did not have any usage of the chemical. Information from the chemical dictionary and Wikipedia on hydrogen sulfide is shown in Attachment 49). Page 23 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ The 2012 Form R for hydrogen sulfide indicated the "basis of estimate" for releases shown in the table below: METHODOLOGY FOR CALCULATING (ESTIMATING) RELEASES RELEASE BASIS OF ESTIMATE 5.1 Fugitive or non-point air emissions M2 - estimate is based on periodic or random monitoring data or measurements for the EPCRA 313 chemical 5.2 Stack or point air emissions E1 - estimate is based on published emission factors, such as those relating release quantity to through-put or equipment type (e.g., air emission factors) 5.3 Discharges to receiving streams or C - estimate is based on mass balance water bodies calculations, such a calculation of the amount of the EPCRA 313chemical in streams entering and leaving process equipment 5.5.2 land treatment/application farming C - estimate is based on mass balance calculations, such a calculation of the amount of the EPCRA 313chemical in streams entering and leaving process equipment In an email dated April 22, 2014, Mr. Cutbirth was asked to provide information and data on the methods used to determine H2S emissions from specific points (Attachment 27). In an email dated May 5, 2014, Mr. Cutbirth replied as follows (CBI Folder 2, tab 15). The calculated amounts of releases for H2S from the Lime kiln, Recovery boiler and Smelt dissolving tanks are based on NCASI H2S factors. The 2012 Form R for hydrogen sulfide reported the releases shown below. Reporting year 2012 was the first year that hydrogen sulfide was required to be reported. Page 24 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ RELEASES OF HYDROGEN SULFIDE AS SHOWN ON THE 2012 FORM R Line no. description Pounds released 5.1 Fugitive or non-point releases 517,048 5.2 Stack or point releases 4,632 5.3 Discharges to receiving streams of water bodies 305 5.5.2 Land treatment 1,477 7A.1a Waste stream: waste water Waste treatment methods H123, settling or clarification H081, biological treatment with or without precipitation 7B Onsite energy recovery processes U01, industrial kiln U03, industrial boiler 8.2 Quantity used for energy recovery onsite 309,899 8.6 Quantity treated onsite 283,290 The total of the values shown in the table significantly exceed the amount of hydrogen sulfide manufactured during 2012. An email dated April 9, 2014, was sent to Mr. Cutbirth asking him to explain the values (CBI Folder 2, tab 14). In an email dated May 5, 2014, Mr. Cutbirth replied as follows (CBI Folder 2, tab 14). The disparity in the total amount of hydrogen sulfide (H2S) manufactured in our original RY2012 calculations versus the total amount of H2S captured in Section 8 of our RY2012 Form R was caused by the double counting of controlled stack air emissions under both energy recovery (8.2) and treated on site (8.6). We have taken this opportunity to update our RY2012 calculations spreadsheet for H2S to improve and clarify our reporting. Energy recovery was eliminated as a response and only treated on site is now utilized. While energy recovery would be a correct response according to NCASI guidance, using the treated onsite category only seems a more appropriate classification in this case. When this doublecounting is eliminated, the revised total for Section 8 of the Form R equals the amount manufactured. The attached revised calculation sheet for H2S now shows the manufacturing total matching the sum of the responses in section 8. After the removal of line 8.6, quantity treated onsite, the corrected releases of hydrogen sulfide are shown below: Page 25 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ RELEASES OF HYDROGEN SULFIDE AS SHOWN ON THE 2012 FORM R AND REVISIONS Line no. description Pounds REVISED released 6-10-2014 shown on Pounds 2012 Form R released Note 1 5.1 Fugitive or non-point releases 517,048 517,042 5.2 Stack or point releases 4,632 29,007 5.3 Discharges to receiving streams of water bodies 305 305 5.5.2 Land treatment 1,477 1,477 7A.1a Waste stream: waste water Waste treatment methods H123, settling or clarification H081, biological treatment with or without precipitation 7B Onsite energy recovery processes U01, industrial kiln U03, industrial boiler 8.2 Quantity used for energy recovery onsite 309,899 0 8.6 Quantity treated onsite 283,290 284,587 Note 1: In his email dated June 10, 2014, Mr. Cutbirth provided the revised information (CBI Folder 2, tab 17). The pulping process takes place in a unit referred to as the digester. Hydrogen sulfide is coincidentally manufactured in the digester. Gases, including hydrogen sulfide, from the digester are routed to the blow tanks and then to the incinerator (thermal oxidizer) for treatment and energy recovery (Figure C-2 of Attachment 38). In an email dated April 11, 2014, Mr. Cutbirth was asked to provide additional information on the processing of gases exiting the digesters and blow tanks (Attachment 26). Mr. Cutbirth's reply is shown below (Attachment 26): Upon completion of each cook, the contents of each digester are emptied (blown) to a hardwood or softwood blow tank. The gases exiting the blow tanks are routed to the NCG collection system where the non-condensable portion of these gases is ultimately burned in the Incinerator. Each of the digesters also has a small vent that is directed to the turpentine system. Emissions from this system are combined back with the other digester gases and are routed to the incinerator. In an email dated March 27, 2014, Mr. Cutbirth was asked if the references to the kiln and the industrial boiler as hydrogen sulfide treatment equipment were correct Attachment 10). Mr. Cutbirth's March 31, 2014, reply is shown below (Attachment 10): Page 26 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ The reference to U03 in the 2012 Form R for hydrogen sulfide contemplates the combustion (for energy recovery and as a form of emissions control) of hydrogen sulfide gases that occurs in the on-site incinerator equipped with waste heat boiler, which is depicted on Figure C-2 of the process flow diagrams. As a backup to the incinerator, hydrogen sulfide emissions can be routed to the 9A Power Boiler. Both the incinerator and the 9A Boiler Power would fall within the U03 - Industrial Boiler code, as we understand the codes. Hydrogen sulfide gases are not routed to the recovery boiler for combustion. The reference to U01 in Section 7.b of the 2012 Form R for hydrogen sulfide appears to be in error. Although Figure C-5 does show non-condensable gases (NCGs) as an input to the lime kiln, NCGs (including hydrogen sulfide) were not burned for energy recovery in the lime kiln within the past 5 years. The piping system that would allow NCGs to be fed to the lime kiln has been blanked and/or removed. As explained above, no NCGs (including hydrogen sulfide gases) are routed to the lime kiln for incineration. The depiction of such activity in Figure C-5 is out of date. The lime kiln burner is fired with natural gas, although that fuel source is not depicted on Figure C-5. In general, the use of natural gas by equipment other than the power boilers is not depicted on process flow diagrams. As explained above, hydrogen sulfide should not be an input to the Recovery Boiler. In addition to these responses, we have also attached is a copy of a presentation that was given by Dr. Zach Emerson of NCASI and Mayes Starke of GeorgiaPacific (with whom you spoke over the telephone during your visit) at a recent NCASI conference. You requested a copy of this presentation during your visit. We can arrange for you to speak with Mayes in more detail regarding the contents of this presentation, if you would find that helpful. In an email dated April 10, 2014, Mr. Cutbirth was asked for a listing of where hydrogen sulfide is manufactured in the pulping process (Attachment 25). In an email dated May 5, 2014, Mr. Cutbirth replied as follows (CBI Folder 2, tab 15): There is no direct contact evaporator at the Crossett Paper mill. The Crossett Paper mill operates a non-direct contact evaporator, which is depicted in the Section 3.1 of the TRI calculation spreadsheet for H2S as "Recovery Furnace NDCE". The sources of H2S for which we have emissions data and/or factors are set forth in Section 3.1 of the attached TRI calculations. A more detailed chart of H2S sources is pasted below. Page 27 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ POINTS AT WHICH YDROGEN SULFFIDE IS MANUFACTURED Hydrogen sulfide sources Blow tanks (blow gases) Accumulator (relief gases) Brown stock Washers (line 1 washers) Brown stock Washers (line 2 washers) Line 1 Decker System Line 2 Decker System Weak Black Liquor (WBL) tanks* Strong Black Liquor (SBL) tanks # High Density Storage chests (UBP storage) Evaporators Recovery Furnace NDCE Smelt Dissolving Tanks White Liquor Storage Tanks Lime Kiln NCG Thermal Oxidizer Turpentine System Steam Stripper (Striper off gases) Pre-evaporators Concentrator Waste Water Treatment System: Primary Clarifier North ASB South ASB Surge Basin Ash Basin Number of each 2 1 1 1 1 1 6 5 3 6 1 2 4 1 1 1 1 1 1 1 1 1 1 1 Comments Controlled in NCG system Controlled in NCG system Controlled in NCG system Controlled in NCG system Controlled in NCG system Vented to atm. Vented to atm. (Note 1, Note 2) vented to atm. vented to atm. Controlled in NCG system Vented to atm. N/A (Note 4) Controlled in NCG system Controlled in NCG system Controlled in NCG system Controlled in NCG system (Note 3) Note 1: In his email dated June 10, 2014, Mr. Cutbirth clarified the location of the six weak black liquor storage tanks (Attachment 32). His comments are shown below: Page 28 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ The weak black liquor tanks accounted for within the TRI calculations are the pine and hardwood washer tanks, filtrate feed tank (controlled by Incinerator), the 12% BLT, the 17% BLT, and a Boil Out Tank. The process flow diagrams were taken from a past Title V Permit application, and thus do not necessarily track all the emission points captured in our TRI calculations. Not every tank within the Crossett facility is depicted within these PFD's. The C2 flow diagram does reflect "to black liquor storage" which would represent the hardwood weak black liquor tank, softwood weak liquor tank and the filtrate tank in the pulp mill. The C4 flow diagram reflects two weak black liquor tanks; the 17% WBL tank and the #1 WBL tank. A third WBL tank not shown on the drawing would be the Boil Out tank. Note 2: In his email dated June 10, 2014, Mr. Cutbirth explained the type of releases reported for the six weak black liquor tanks (Attachment 32). His comments are shown below: Of the six weak black liquor tanks identified in the TRI worksheet, only the filtrate feed tank is controlled by the thermal oxidizer. The other five weak black liquor tanks vent to the atmosphere, and thus noted as "uncontrolled" in our TRI worksheet. We characterize each of these six tanks as stack or point air emission sources, thus they are accounted for in Section 5.2 of our TRI worksheet. The Form R instructions note that storage tank emissions fall within 5.2 and thus we believe this is an appropriate characterization of the type of emission sources represented by the weak black liquor tanks. The spreadsheet associated with Section 5.2 correctly depicts the five heavy black liquor tanks as being "uncontrolled". The "uncontrolled" tank emissions and "controlled" tank emissions are then summed together as a "sum for all the tank emissions" identified. Again, we believe our approach of characterizing these storage tank emissions within Section 5.2 of our TRI worksheet is consistent with the Form R instructions. Note 3: In his email dated June 10, 2014, Mr. Cutbirth clarified the location of the ash basin shown under wastewater treatment (Attachment 32). His comments are shown below: There are two points within the system where ash accumulates and is removed for disposal; at the point ash immediately exits both 9A & 10A Boilers (Figure C-11), and then the ash settling basins located just south of the primary clarifier (figure C-12). The ash Page 29 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ basins depicted in C12 are the basins that we consider part of the wastewater treatment system. Note 4: In his email dated June 10, 2014, Mr. Cutbirth clarified the meaning of the notation "N/A" (Attachment 32). His comments are shown below: NA is intended to mean zero emissions. The underlying calculation spreadsheet depicts zero emissions based on information obtained from NCASI Guidance. In his email dated June 10, 2014, Mr. Cutbirth clarified the releases from the sludge basin shown on flow chart figure C-12, which is not shown in the above chart (Attachment 32). His comments are shown below: The H2S releases associated with the sludge basin are captured in Section 5.5.2 - Land Application of the H2S calculation worksheet, which depicts 1,477 lbs H2S released to land. This value was derived from NCASI guidance. In his email dated June 10, 2014, Mr. Cutbirth clarified releases from the aeration and stabilization basin (Attachment 32). His comments are shown below: Based on the sampling and modeling exercise that we can describe in more detail during our call Wednesday, GP has estimated H2S releases of 923.1 lbs/day from the north end of the ASB and 73.25 lbs from the south end of the ASB for a total of 996.35 lbs/day. In his email dated June 10, 2014, Mr. Cutbirth discussed hydrogen sulfide releases from the holding basin (Attachment 32). His comments are shown below: ADEQ classifies Mossy Lake (noted in Figure C-12) as water of the State, and thus the Crossett mill's NPDES permit does not consider Mossy Lake to be part of the Crossett mill's wastewater treatment system. Additionally, Mossy Lake serves as a drainage basin for a large footprint of land beyond Georgia Pacific's ownership. For that reason, Georgia-Pacific has not sampled or otherwise estimated releases of H2S from Mossy Lake. In his email dated June 10, 2014, Mr. Cutbirth discussed hydrogen sulfide releases from the black liquor storage basin (Attachment 32). His comments are shown below: Georgia-Pacific has not sampled or otherwise estimated releases of H2S from the black liquor storage basin noted on Figure C-4. NCASI has no emission factors for black liquor ponds, and thus Georgia Pacific is not aware of a reliable means by which to estimate emissions from the black liquor storage pond. Page 30 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ The great majority of the fugitive air releases of hydrogen sulfide are coincidentally manufactured in the aeration and stabilization basins of the wastewater treatment plant. The hydrogen sulfide coincidentally manufactured is released to the atmosphere. Mr. Cutbirth said the methodology presented in the paper titled ""Estimating H2S and Methyl Mercaptan Emissions from Wastewater Treatment Systems" was used to estimate releases at the wastewater treatment plant. The paper was coauthored by Georgia-Pacific and NCASI (National Council on Air and Stream Improvement) (Attachment 46). Hydrogen sulfide is also in the fuel gas stream which is routed to an incinerator which has a heat recovery boiler (Attachment 50). Ms. Rachel Johnson stated that ambient air levels of hydrogen sulfide at the wastewater treatment plan were low enough that maintenance personnel working on the aerators do not need to wear personal protective equipment (respirators). The wastewater treatment process encompasses the following phases (Figure C-12 of Attachment 38): Phase 1: Clarifier De-watering Sludge basin Phase 2: Two ash settling basins (in parallel) Surge basin Aeration and stabilization basin Holding basin (Mossy Lake) The clarified water (output) from Phase 1 is transferred to Phase 2 prior to the settling basins. In an email dated June 20, 2014, Mr. Cutbirth provided the following information the use of personal protective equipment (PPE) in the wastewater treatment plant area (Attachment 64): Employees working in the areas around the wastewater treatment system for extended periods do wear personal H2S monitors. This includes contract employees managing the sludge press, dredging contractors and GP maintenance personnel. We have not observed H2S levels above the OSHA Permissible Exposure Limit for an 8 hour period of 10 ppm and therefore we have never required PPE to work in these areas. Employee monitors are set to alarm at 10 ppm. Employees are directed, per a posted contractor procedure, to move away from the area where these levels are observed. In an email dated April 8, 2014, Dr. Wakeland requested information on the basis of estimate shown for release of hydrogen sulfide (Attachment 22). Mr. Cutbirth's reply is shown below (Attachment 22). Page 31 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ The model used calculated the emissions based on water quality measurements of aqueous sulfide and pH at various points in the system. The model also took into account the characteristics of the wastewater treatment system (types of units and dimensions). No air monitoring was done, as the model is entirely based on aqueous data. Emission factors were not used. The slides at the first of the presentation (Slides 6 through 10) describe the different types of ways of estimating emissions (as introduced on Slide 5 - Estimation Methods). The Zone Emissions Model (slide 10 and following) then discussed the model used for estimating emissions in this case. The third slide was meant to convey that the reporting would first take place in July of 2013 for calendar year 2012. The presentation was made in June of 2012 when everyone was in the midst of collecting data, estimating emissions, or determining whatever means they were going to use to report hydrogen sulfide by July of 2013. M2 code was used because the modeling was based on actual calculations (not emission factors) from various locations in the wastewater treatment system. The E1 Code was used for emission factors used to calculate stack releases. In an email dated April 9, 2014, Dr. Wakeland requested additional information related to the basis of estimate (Attachment 22). Mr. Cutbirth's reply is shown below (Attachment 22). Our selection of the M2 code appears to have been based on the fact that the fugitive H2S emission estimates were calculated, at least in part, by using wastewater monitoring conducted at the mill. The wastewater monitoring consisted of aqueous sulfide measurements that were then used as inputs to the NCASI model to predict potential H2S releases to the atmosphere. Based on your insight and feedback, we will utilize the E2 code in the future. In his letter dated May 30, 2014, Dr. Morton Wakeland provided the following information (Attachment 51): Upon further investigation and research, your (GP's) use of code M2 for fugitive emissions for hydrogen sulfide is acceptable. While "monitoring" is used in the first part of the definition, "or measurement" is used in the second half of the definition. Because you stated Georgia-Pacific periodically sampled (measured) the water to estimate hydrogen sulfide emissions, this code is acceptable. Page 32 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Chlorine Chlorine is coincidentally manufactured in the first bleaching stage for the wood pulp. Chlorine was reported by the establishment for the five years 2008 to 2012. The 2008 to 2012 air releases and treatment of chlorine shown on the Form R's are compared below: CHLORINE RELEASES AND TREATMENT BY TYPE Form R line 2008 2009 2010 2011 number releases, releases, releases, releases, pounds pounds rounds pounds 5.1, fugitive air 5 5 5 5 emissions 5.2, stack air 2,136 1,850 2,087 1,864 emissions Note 1 7A.1d, >50% but scrubber <95% efficiency 8.6, treated 12,346 10,484 11,829 10,564 onsite 2012 releases, pounds 5 0 Note 2 >99.9999% 13,144 Note 1: A NCASI factor was used to calculate emissions. Note 2: A stack test dated 9-21-2011 was used to calculate emissions. The stack air releases of chlorine from the first bleaching stage are processed through the bleach plant scrubber. Chlorine releases for the Georgia-Pacific complex are shown below: CHLORINE RELEASES FOR THE THREE ESTABLISHMENTS Establishment 2008 2009 2010 2011 2012 releases, releases, releases, releases, releases. pounds pounds pounds pounds pounds Paper and Pulp 5 1,959 2,092 1,869 5 Chemicals 520 240 300 250 150 Plywood/Stud NA NA NA NA Mill idled Mill TOTAL 525 2,199 2,392 2,119 155 Chlorine is otherwise used for disinfecting process water which is supplied to all three establishments. Chlorine is also used to disinfect well water for potable water use at the Page 33 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Paper Operations. There are no releases in chlorination process. The facility uses one ton cylinders of chlorine for the process. Chlorine Dioxide Chlorine dioxide is used in the first bleaching stage to bleach the kraft pulp to a white pulp. Chlorine dioxide is manufactured onsite using the following chemicals: Sulfuric acid Sodium chlorate Methanol Hydrogen peroxide The 2008 to 2012 air releases and treatment of chlorine dioxide shown on the Form R's are compared below: CHLORINE DIOXIDE RELEASES AND TREATMENT BY TYPE Form R line 2008 2009 2010 2011 number releases, releases, releases, releases, pounds pounds pounds pounds 5.1, fugitive air 5 5 5 5 emissions 5.2, stack air 3,329 3,110 3,170 3,194 emissions Note 1 7A.1d, >99% but >99% but >99% but >99% but scrubber <99.99% <99.99% <99.99% <99.99% efficiency 8.6, treated 329,585 307,867 313,852 316,174 onsite 2012 releases, pounds 5 0 Note 2 >99.9999% 313,963 Note 1: A NCASI factor was used to calculate emissions. Note 2: A stack test dated 9-21-2011 was used to calculate emissions. In an email dated June 10, 2014, Mr. Cutbirth was asked the following question (Attachment 31): The 2012 Form R for chlorine dioxide indicates 0 (zero) stack emissions. It was mentioned at the inspection that a September 21, 2011, stack test was used to determine this value. What was the detection limit for chlorine dioxide in this test? In an email dated June 20, 2014, Mr. Cutbirth replied as follows (Attachment 64): Page 34 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ The method utilized to determine CL and CLO2 concentrations is a titration using a color change indicator; NCASI Method TI-520. Method TI-520 does not depict a minimum detection level as it is wet chemistry. The stack air releases from chlorine dioxide manufacturing are processed through the bleach plant scrubber. In an email dated April 7, 2014, Mr. Cutbirth was asked to provide additional information on the 2012 usage of chlorine dioxide (CBI Folder 2, tab 12). The reason for the request was that the value shown in the spread sheet for the amount otherwise used does not equal the amount manufactured. In an email dated April 11, 2014, Mr. Cutbirth agreed that the amount of chlorine dioxide manufactured should equal the amount of chlorine dioxide otherwise used (CBI Folder 2, tab 12). Mr. Cutbirth's reply is shown below. The "manufactured" amount of... pounds of chlorine dioxide solution was the correct value to use for the threshold determination for reporting year 2012. Mr. Wakeland is correct in that the value of... utilized for "manufactured" should have also been the value for "otherwise used". Notwithstanding this oversight, we believe the "release" value originally reported remains accurate. Cresol The 2008 to 2012 air releases and treatment of cresol are compared below: RELEASES AND TREATMENT OF CRESOL BY TYPE Form R line 2008 2009 2010 2011 number releases, releases, releases, releases, pounds pounds pounds pounds 5.1, fugitive 6 5 5 5 air emissions 5.2, stack air 57,511 55,592 56,428 54,672 emissions Note 1 7A.1b, waste H040 H040 H040 H040 treatment H123 method H081 Note 3 7A.1d, >99% but >99% but >99% but >99% but treatment <99.99% <99.99% <99.99% <99.99% efficiency 8.6, treated on NA NA NA NA site Note 4 Note 4 Note 4 Note 4 2012 releases, pounds 4 1,625 Note 2 H040 >99% but <99.99 NA Note 4 Page 35 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Note 1: Emissions were calculated using a NCASI factor. Note 2: Emissions were calculated using a new NCASI factor. Note 3: H040, incineration - thermal destruction other than use as a fuel H123, settling or clarification H081, biological treatment with or without precipitation Note 4: Since a gas stream was sent to an incinerator there should be a value shown in line 8.6. The inspector requested a copy of the old and the new NCASI factors. The facility is to provide the factors by April 9th. The facility replied as follows (Attachment 41): As set forth in the TRI calculation spreadsheets we provided to you, Crossett Paper relies on NCASI-derived emission factors to measure releases of Creosol. For reporting years 2008 -2010 the NCASI guidance on Creosol emissions suggested using a median emission factor of < 5.0E-02 lbs/ton black liquor solids for the recovery furnace (referred to as a Recovery Furnace, NDCE). That emission factor was updated in the 2010 version of the NCASI guidance and was reported as "--". NCASI guidance provides that this symbol should be treated as an emission factor of 0.0E-0, which is the approach Crossett Paper followed in TRI reporting years 2011 and 2012 for this particular source. It would appear the Crossett Paper's failure to include any amounts in line 8.6 for treatment on-site was an oversight on our part, as the underlying calculation spreadsheets do estimate the amount of Cresol that was treated on-site. Lead and Lead Compounds Lead and/or lead compounds are found in the following: Wood logs Hog fuel Wood chips TDF (tire derived fuel) Oil (used to start recovery boiler) The 2008 to 2012 releases and treatment of lead and lead compounds shown on the Form R's are compared below: Page 36 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ LEAD AND LEAD COMPOUNDS RELEASES AND TRETMENT BY TYPE Form R line 2008 2009 2010 2011 2012 number releases, releases, releases, releases, releases, pounds pounds pounds pounds pounds 5.1, fugitive air NA NA NA NA NA emissions 5.2, stack air 137 172 161 144 183 emissions 5.3, discharges to 216 197 193 179 254 water 5.5, land onsite 186 322 483 595 909 12,241 10,194 11,219 9,452 848 Note 1 7A.1b, waste H123 H123 H123 H123 H123 treatment method H082 H082 H082 H082 H082 Note 2 7A.1d, treatment >50% but >50% but >50% but >50% but >50% but efficiency <95% <95% <95% <95% <95% 8.6, treated onsite NA NA NA NA NA Note 1: New NCASI factors were used for 2012 reporting. Note 2: H123, settling or clarification H082, adsorption The facility was requested to provide the old and new NCASI factors. The information is to be provided by April 9th. In an email dated April 7, 2014, the facility replied as follows (Attachment 41): The decrease in reported releases of Lead Compounds from RY2011 to RY2012 was primarily attributable to a change from the use of the mean value of the NCASI data set for the concentration of lead in various types of wood fuel to the use of the median value. In RY2012, Crossett Paper also changed the factor used to measure Lead Compound discharges to water - the facility switched from using a NCASI factor to using a factor based on facility-specific analytical data. This switch caused a slight increase in the value of Lead Compound discharges to water. The following additional information was shown on the 2012 Form R: Page 37 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Form R line number 8.10 8.11 Description Source Reduction Activities: W19 - other changes in operating practices Additional Information: W19 - mill wide effort to reduce process water use For both line 8.10 and 8.11 above, at the time of the inspection, the Staff was not able to explain how the above activities affected the reduction from 2011 to 2012 of the fugitive air, stack air and water releases. The Staff said that they would investigate and reply by April 9th. In an email dated April 7, 2014, Mr. Cutbirth was asked to provide additional information on the 2012 usage of lead and lead compounds (CBI Folder 2, TAB 13). In an email dated April 7, 2014, the facility replied as follows (Attachment 41): The references to "other changes in operating practices" and "mill-wide effort to reduce process water use" were included in Lines 8.10 and 8.11, respectively, to account for the concerted effort at Crossett Paper to reduce water use. This effort resulted in a decrease in the volume of water discharged to the Ouachita River. Because the volume of water discharged from the mill is one of the inputs into Crossett Paper's calculations of Lead Compound discharges to water, the mill's overall reduction in water use decreased the corresponding Lead Compound discharges to water. It should be noted, however, that the decrease in Lead Compounds discharges due to water use reductions was offset by the facility's transition to the use of a new factor based on facility-specific analytical data discussed above. In an email dated April 22, 2014, Mr. Cutbirth was asked to clarify the wastewater treatment of lead and lead compounds (Attachment 28). In an email dated April 25, 2014, Mr. Cutbirth provided the following answers (Attachment 28): As depicted in Figure C-12, Crossett Paper's wastewater treatment system receives some solids in the form of paper making residuals and boiler ash. Some portion of the lead compounds in the incoming wastewater streams attach to these solid materials and settle out prior to reaching the treatment system's permitted outfall. This adsorption/settling of lead compounds has been confirmed through comparative testing performed by NCASI of wastewater streams entering and exiting wastewater treatment systems. The adsorption/settling of lead compounds is accounted for by reference to H082 (adsorption) and H123 (settling or clarification) in Section 7A.1b of the Form R. Page 38 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ On the Form R's for lead compounds H123, settling or clarification, and H082, adsorption, are shown as wastewater treatment codes. Line 8.6, treated onsite, is shown as NA. Mr. Cutbirth replied as follows (Attachment 28). We think NA is the appropriate entry for Section 8.6 for Lead Compounds. Section 8.6 refers to treatment on-site, which EPA has defined in its Form R instructions as destruction. Settling or adsorption of lead compounds does not result in the destruction of the parent metal, and thus we believe NA is the appropriate entry in Section 8.6. That approach is endorsed in EPA's Form R instructions (Jan. 2014 version, page 67), which state that "for metals and metal category compounds, you should enter NA in Sections 8.2, 8.3, 8.6 and 8.7, as treatment and combustion for energy recovery generally are not applicable waste management methods for metals and metal compounds." Any amount of lead compounds that is subject to adsorption/settling in our treatment system (as referenced in Section 7A.1b) is accounted for in Sections 8.1a or 8.1b, not Section 8.6." Ethylene Glycol Ethylene glycol was not reported for reporting year 2009. Ethylene glycol is otherwise used at the establishment. The total of the 2009 usage of ethylene glycol at the three establishments was below the 10,000 pound otherwise use threshold (CBI Folder 2, tab 3). For 2008, 2010 and 2011 ethylene glycol was reported by all three establishments. For 2012 ethylene glycol was reported by the Pulp and Paper Operations and the Chemical Operations. Nitrate Compounds Nitrate compounds are coincidentally manufactured in the wastewater treatment plant. The 2011 and 2012 releases of nitrate compounds are shown below. Prior to reporting year 2011 nitrate compounds were not reported. NITRATE COMPOUND RELEASES` Form R line number 2008 to 2010 releases, pounds 5.3, discharges to Chemical not water onsite reported 2011 releases, pounds 55,852 2012 releases, pounds 62,403 The facility agreed to provide documentation on why nitrate compounds were not reported from 2008 to 2011. The documentation is to be provided by April 9th. Page 39 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ The facility replied as follows (Attachment 41). Attached please find excerpts from a study of the facility's wastewater treatment system, referred to as the Parsons Report, Event 2 - Conventional Pollutant Analysis issued by EPA and dated October 18, 2005. The Parsons Report indicated a nitrate reading at Mossy Lake of <0.2 mg/l, which represents a nondetect. Mossy Lake is directly downstream of Outfall 001 and prior to our discharge to the Ouachita River. This non-detect value supports the non-reporting of Nitrate Compounds for RY2008-RY2010. Crossett Paper obtained additional monitoring data in late 2010/early 2011. This data should have been utilized in the original RY2011 TRI report but was inadvertently overlooked. A new Form R for RY2011 nitrate compounds was submitted on 6/24/2013. A copy of the Parsons Report, Event1 to 4 - Conventional Pollutant Analysis issued by the EPA and dated October 18, 2005, is included in CBI Folder 2, tab 9. The following additional information was shown on the 2012 Form R: Form R line Description number 8.10 Source Reduction Activities: W19 - other changes in operating practices 8.11 Additional Information: W19 - mill wide effort to reduce process water use For both line 8.10 and 8.11 above, at the time of the inspection, the Staff was not able to explain how the above activities affected the reduction from 2011 to 2012 of the fugitive air, stack air and water releases. The Staff said that they would investigate and reply by April 9th. The facility replied as follows (Attachment 41): Similar to Lead Compounds, the references to "other changes in operating practices" and "mill-wide effort to reduce process water use" were included in Lines 8.10 and 8.11, respectively, of the Form R for Nitrate Compounds to account for the concerted effort at Crossett Paper to reduce water use. This effort resulted in a decrease in the volume of water discharged to the Ouachita River. Because the volume of water discharged from the mill is one of the inputs into Crossett Paper's calculations of Nitrate Compound discharges to water, the mill's overall reduction in water use decreased the corresponding Lead Compound discharges to water. Page 40 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Sulfuric Acid Aerosols The facility last reported sulfuric acid aerosols in 2008. The usage of sulfuric acid aerosols for the three establishments in 2008 to 2011 and for the two establishments in 2012 was below threshold (CBI Folder 2, Attachment 1). The facility reported sulfuric acid aerosols for 2008 even though the usage was below the 25,000 pound threshold. The sulfuric acid aerosols are a result of burning fuel oil to startup the recovery boiler. The aerosols are coincidentally manufactured in the stack after the gases pass through an electrostatic precipitator. An analysis of the manufacture of sulfuric acid aerosols is shown in the Confidential Business Information as CBI Folder 2, Attachment 1. There was an order of magnitude decrease in sulfuric acid aerosols from 2006 to 2012. Acetaldehyde The chemical dictionary information on acetaldehyde is shown in Attachment 60 The 2008 to 2012 releases and treatment of acetaldehyde shown on the Form R's are compared below: ACETALDEHYDE RELEASES AND TREATMENT BY TYPE Form R line 2008 2009 2010 2011 number releases, releases, releases, releases, pounds pounds pounds pounds 5.1, fugitive air 60,274 56,817 58,059 35,768 emissions 5.2, stack air 30,749 30,175 28,993 28,574 emissions 5.3, discharges to 7,960 7,503 7,806 7,997 water 5.5, land onsite 35 45 41 38 7A.1b, waste U01 U01 U01 U01 treatment method U02 U02 U02 U02 Note 1 H040 H040 H040 H040 H123 H123 H123 H123 H081 H081 H081 H081 8.1b, releases on 99,018 94,540 94,899 72,377 site 8.2 energy 69,840 65,938 67,333 68,994 recovery onsite 8.6, treated onsite 78,150 73,665 92,277 100,670 2012 releases, pounds 1,220 15,630 286 11 U01 U02 H040 H123 H081 17,147 67,322 72,291 Page 41 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Note 1: U01, industrial kiln U02, industrial boiler H040, incineration - thermal destruction other than use as a fuel H123, settling or clarification H081, biological treatment with or without precipitation The following additional information was shown on the 2012 Form R: Form R line Description number 8.10 Source Reduction Activities: W19 - other changes in operating practices 8.11 Additional Information: W19 - mill wide effort to reduce process water use At the time of the inspection the Staff was not able to explain how the above activities affected the reduction from 2011 to 2012 of the fugitive air, stack air and water releases. The Staff said that they would investigate and reply by April 9th. The facility replied as follows (Attachment 41): It appears the entries in Lines 8.10 and 8.11 of the RY2012 Form R for Acetaldehyde are incorrect, and likely resulted from a carryover of information from a Form R for another chemical. The correct code that should have been entered in Line 8.10 is W13 - Improved maintenance scheduling, record keeping or procedures. The RY2011 Form R for Acetaldehyde includes this correct code. That code is referenced to account for Crossett Paper's use of facility-specific analytical data for reporting release values. In an email dated April 16, 2014, Mr. Cutbirth was asked to clarify the 2012 Form R reporting of acetaldehyde (CBI Folder 2, Attachment 11). Mr. Cutbirth proved the following comments in his email of April 25, 2014, (CBI Folder 2, tab 11). The disparity in the total amount of Acetaldehyde manufactured in our original RY2012 calculations versus the total amount of Acetaldehyde captured in Section 8 of our RY2012 Form R can be explained by our mixing and matching of factors used to calculate the fate of Acetaldehyde entering the mill's wastewater treatment system (WWTS). In our original calculations, we used the value 1,220 lbs for the amount of Acetaldehyde volatized in our WWTS, as that value was based on the best information we had available at the time (facility-specific modeling). In those same calculations, we used NCASI factors to estimate the amount biodegraded and discharged in the effluent. The total of all three values was less than the total amount of Acetaldehyde entering our WWTS, and thus explains the "missing" volume in Section 8. In the course of researching your question, we have discovered several other improvements that could be made to the calculation spreadsheet for RY2012 for Acetaldehyde, and thus are now submitting a revised calculation for your review. To address the issue raised in Page 42 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ your question, these revised calculations still use the 1,220 lbs value as the amount of Acetaldehyde volatized from the WWTS, but we now use an discharge amount that is based on one-half the detection limit from our outfall sampling (Acetaldehyde is non-detect in our sampling) in place of the NCASI factor. Lastly, to calculate the amount biodegraded in our WWTS system, we take the total amount of Acetaldehyde entering the WWTS and subtract the amount volatized and the amount discharged (again, rather than using the NCASI factor). These revisions ensure that our total amount manufactured/processed/otherwise used will be equal to the total amount in Section 8 of the Form R. Ammonia Descriptive information on anhydrous ammonia is shown in Attachment 52. The following table summarizes the onsite releases and onsite treatment of ammonia shown on the Form R's from 2008 to 2012. AMMONIA RELEASES AND TREATMENT BY TYPE Form R line 2008 pounds 2009 pounds 2010 pounds 2011 pounds number 5.1, fugitive 500 500 500 500 air 5.2, stack air 132,018 133,042 130,742 123,090 2012 pounds 500 128,189 5.3 discharge to water 7A, onsite treatment methods Note 1 8.6, treated onsite 1073 H040 H123 H081 NA Note 2 1070 H040 H123 H081 NA 1070 H040 H123 H081 NA 941 H040 H123 H081 NA 870 H040 H123 H081 NA Note 1: H040, incineration - thermal destruction other than use as a fuel H123, settling or clarification H081, biological treatment with or without precipitation Note 2: With onsite treatment efficiencies greater than 50 percent there should be a value in line 8.6 treated onsite. The following additional information was shown on the 2012 Form R: Page 43 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Form R line number 8.10 8.11 Description Source Reduction Activities: W19 - other changes in operating practices Additional Information: W19 - mill wide effort to reduce process water use For both line 8.10 and 8.11 above, at the time of the inspection, the Staff was not able to explain how the above activities affected the 2012 reporting of the fugitive air, stack air and water releases. The Staff said that they would investigate and reply by April 9th. The facility replied as follows (Attachment 41): It would appear the Crossett Paper's failure to include any amounts in line 8.6 for treatment on-site was an oversight on our part, as the underlying calculation spreadsheets do estimate the amount of Ammonia that was treated on-site. Similar to Lead Compounds and Nitrate Compounds, the references to "other changes in operating practices" and "mill-wide effort to reduce process water use" were included in Lines 8.10 and 8.11, respectively, of the Form R for Ammonia to account for the concerted effort at Crossett Paper to reduce water use. This effort resulted in a decrease in the volume of water discharged to the Ouachita River. Because the volume of water discharged from the mill is one of the inputs into Crossett Paper's calculations of Nitrate Compound discharges to water, the mill's overall reduction in water use decreased the corresponding Lead Compound discharges to water. Barium Compounds The 2008 to 2012 releases and treatment of barium compounds is shown in the table below: Page 44 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ BARIUM COMPOUNDS RELEASES AND TREATMENT BY TYPE Form R line 2008 2009 2010 2011 number releases, releases, releases, releases, pounds pounds pounds pounds 5.1, fugitive NA NA NA NA air 5.2, stack air 244 243 229 210 2012, releases pounds NA 258 5.3 discharge to water 5.5, land onsite 7A, onsite treatment methods Note 1 14,906 721 84,648 A03 H123 H082 13,591 1,465 72,608 A03 H123 H082 13,351 2,259 78,730 A03 H123 H082 12,355 2,810 66,918 A03 H123 H082 33,602 4,342 66,573 A03 H123 H082 Note 1: A03, scrubber H123, settling or clarification H082, adsorption During the inspection, and based on incorrect information, the Inspector questioned the accuracy of the 2011 Form R for barium compounds. The facility replied as follows (Attachment 41): The Form R for Barium Compounds available on TRIME web appears to be correct and matches the file copy we have on-site. During your visit, we discussed this same issue, and it appeared that you may have been referring to a Barium Compounds Form R for a different facility. The facility was in fact correct. The Inspector had referred to a Form R for another chemical (Attachment 21). Benzo(g,h,i)perylene The total on site releases of benzo(g,h,i)perylene ranged from a high of 25 pounds in 2008 to a low of 20 pounds in 2012. The threshold for benzo(g,h,i)perylene is 10 pounds. The Pulp and Paper Operations reported benzo(g,h,i)perylene for each of the years 2008 to 2012. Page 45 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ U. OTHER CHEMICALS AND ITEMS OF INTEREST Boiler Ash The facility has two boilers that generate boiler ash. Both burn chipped bark and/or hog fuel. Hog fuel is wood chips or shavings, residue from sawmills, etc. The name, hog fuel, comes from the machine used to create hog fuel, a hammer hog. Part of the boiler ash is collected at the boilers and taken to the onsite land fill. The remainder is sluiced to the wastewater treatment plant. Sluicing consists of mixing the ash with water and transferring it to the wastewater treatment plant. At the wastewater treatment plant the boiler ash settles out in two ash settling basins and is transferred to the sludge basin (an onsite land fill). The boiler ash, collected at the boilers, is as used a cover material at the onsite land fill. No boiler ash is sold or given away. The cost of transporting the boiler ash to markets exceeds the value of the ash and the most economical disposal is to use it as landfill cover. A TCLP (t-clip) analysis of the boiler ash is shown in Attachment 53. TCLP (Toxicity Characteristic Leaching Procedure) is a chemical analysis employed as an analytical method to simulate leaching through a landfill (Attachment 54) Stack Descriptions A listing of the facility's stacks and emission points is shown in CBI Folder 2, tab 10. Benzene, CAS 71-43-2, de minimis = 0.1% The manufacture usage of benzene was below threshold for reporting years 2008 to 2012. An analysis of the manufacture use of benzene is shown in the CBI Folder 2, Attachment 2. Power boilers and electric generation The facility has two waste wood (hog fuel) fired boilers and two backup natural gas fired boilers (Figure C-11, steam generation, Attachment 37). Part of the steam from the boilers is routed through two steam turbines to generate electricity. Together with the steam turbine on the recovery boiler the facility generates approximately 70 percent of the facility's electricity needs. The facility also has the capacity and ability to provide steam to the Chemical Operations and/or the Plywood/Stud Mill during down time on their boilers. Page 46 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ In an email dated April 11, 2014, Mr. Cutbirth was asked to provide clarifying information on the wood piles for the two hog fuel fired boilers shown on the process flow diagram (Attachment 37, Figure C-11). Mr. Cutbirth's reply is shown below: You are correct, 9A and 10A Boilers each have a hog fuel storage pile (Figure C11 calls these two storage areas wood waste piles) associated with each boiler. The 9A bark pile is located northwest of 9A Boiler and the 10A bark pile is located just east of 10A Boiler. I see that the Facility Map calls 9A Boiler bark pile "bark storage" and the 10A Boiler bark pile is called "wood waste pile". All of these names are synonymous with "wood waste". Recovery boiler and electric generation The recovery boiler is fueled with concentrated black liquor and generates steam to run a steam turbine to generate electricity (Figure C-4, liquor recovery, in Attachment 37). The boiler also produces smelt which contains sodium sulfide which is mixed with process water to form green liquor. Green liquor is then reacted with lime to generate white liquor. For startup the recovery boiler is fired with oil. TRI chemicals in the oil are taken into consideration for the threshold calculations. In an email dated March 31, 2014, Mr. Cutbirth provided the following comments related to the recovery boiler (Attachment 10): The reference to U03 in the 2012 Form R for hydrogen sulfide contemplates the combustion (for energy recovery and as a form of emissions control) of hydrogen sulfide gases that occurs in the on-site incinerator equipped with waste heat boiler, which is depicted on Figure C-2 of the process flow diagrams. As a backup to the incinerator, hydrogen sulfide emissions can be routed to the 9A Power Boiler. Both the incinerator and the 9A Boiler Power would fall within the U03 - Industrial Boiler code, as we understand the codes. Hydrogen sulfide gases are not routed to the recovery boiler for combustion. No, as explained above, hydrogen sulfide should not be an input to the Recovery Boiler. NAICS codes for Paper operations The Pulp and Paper Operations reports the following NAICS codes (Attachment 55). Page 47 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ NAICS CODE 322110 322121 322130 PRIMARY YES NO NO NAICS CODE DESCRIPTION Pulp Mills Paper (except Newsprint) Mills Paperboard Mills 322110: The Pulp and Paper Operations receives both pine and hardwood logs and debarks them. They then chip the logs and pulp the chips. The pulp is then bleached. 322121: The Pulp and Paper Operations then takes the pulp and converts it into toilet tissue (paper) and paper towel stock. The stock is then made into rolls and packaged. 322130: The Pulp and Paper Operations then takes the pulp and converts it into paperboard (a thicker paper) which is used at another location to manufacture products such as paper plates. Dr. Wakeland requested additional information from the facility regarding NAICS codes for GP's three establishments (Attachment 19). In an email reply dated April 17, 2014, Mr. Cutbirth stated the following in response to Dr. Wakeland's questions (Attachment 19): Crossett Paper is an integrated pulp and paper mill that manufactures pulp to make paper towels, tissue and paperboard products. The paper towel and tissue manufacturing operations fall within NAICS code 322121, while the paperboard manufacturing operations fall within NAICS code 322130. From an accounting perspective, Crossett Paper tracks the finances of its towel & tissue production and paperboard production on separate ledgers at the mill level. That said, many operations and services at the mill are shared among the two product groups, including operations such as the wood yard, pulp production, and utilities along with capability groups such as accounting, EHS, maintenance, HR and mill leadership (i.e., a single Plant Manager oversees operations at the entire Crossett Paper Plant). Page 48 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Products of Combustion from Motor Vehicles Etc. In an email dated April 9, 2014, Mr. Cutbirth was asked to determine if the products of combustion from motor vehicles were taken into consideration during the calculations of releases at the Pulp and Paper Operations (Attachment 23). In an email dated April 21, 2014, Mr. Cutbirth replied to the above question and said that GP Crossett Paper had not included the products of combustion in their release calculations (Attachment 23). To respond to your question below, Crossett Paper has not typically accounted for the coincidental manufacture of TRI chemicals via the combustion of fuels by motor vehicles operated at the mill in its EPCRA 313 calculations. For that reason, we have not determined whether accounting for that activity would impact our release calculations. We have reviewed Mr. Wakeland's note to the Crossett Chemical plant, and we continue to believe that the guidance Mr. Wakeland references does not extend to the combustion of fuel products by motor vehicles operated by third parties that deliver materials to Crossett Paper. In any event, we will continue our research to clarify this issue to ensure that we are meeting the applicable regulations in future TRI reports, as we believe neither the rules nor readily available guidance are sufficiently clear on this point. On April 21, 2014, Mr. Cutbirth's reply was referred to Dr. Wakeland for his reply. The inclusion of the products of combustion would not only apply to motor vehicles by also other internal combustion engines such as fire pumps and standby electric generators. A discussion of several emails exchanged between Mr. Randy Roden (Georgia-Pacific Chemicals and the EPA is included in the March 20, 2014, inspection report for GeorgiaPacific Chemicals in Crossett, Arkansas. Tire Derived Fuel (TDF) The use of tire derived fuel (TDF) in the two wood fired boilers was discontinued during July 2013. Zinc compounds (zinc oxide) are the most significant TRI chemical in TDF and zinc compounds were included in the threshold calculations. The threshold calculations indicate that the zinc compounds were manufactured. Used (waste) Oil On April 9, 2014, an email was sent to Mr. Cutbirth asking if the boilers at the Pulp and Paper Operations were use to dispose of used oil (Attachment 24). Page 49 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ In his reply to the above question Mr. Cutbirth stated that used oil is collected and burned in the recovery boiler (Attachment 24). His comments are shown below: Yes Sir, we burn the used oil we collect and recycle it in the Recovery Boiler. If for some reason the used oil does not meet "used oil specifications" it will not be burned in the Recovery Boiler. We would manifest and dispose of the off-spec used oil through an outside vendor. Lime Kiln In an email dated March 31, 2014, Mr. Cutbirth provided information relative to the lime kiln (Attachment 10): The reference to U03 in the 2012 Form R for hydrogen sulfide contemplates the combustion (for energy recovery and as a form of emissions control) of hydrogen sulfide gases that occurs in the on-site incinerator equipped with waste heat boiler, which is depicted on Figure C-2 of the process flow diagrams. As a backup to the incinerator, hydrogen sulfide emissions can be routed to the 9A Power Boiler. Both the incinerator and the 9A Boiler Power would fall within the U03 - Industrial Boiler code, as we understand the codes. Hydrogen sulfide gases are not routed to the recovery boiler for combustion. The reference to U01 in Section 7.b of the 2012 Form R for hydrogen sulfide appears to be in error. Although Figure C-5 does show non-condensable gases (NCGs) as an input to the lime kiln, NCGs (including hydrogen sulfide) were not burned for energy recovery in the lime kiln within the past 5 years. The piping system that would allow NCGs to be fed to the lime kiln has been blanked and/or removed. As explained above, no NCGs (including hydrogen sulfide gases) are routed to the lime kiln for incineration. The depiction of such activity in Figure C-5 is out of date. The lime kiln burner is fired with natural gas, although that fuel source is not depicted on Figure C-5. In general, the use of natural gas by equipment other than the power boilers is not depicted on process flow diagrams. Hog fuel (wood waste) piles In an email dated April 11, 2014, Mr. Cutbirth was asked to clarify the Saline River Water Plant and what appears to be a single hog fuel (wood waste) pile rather than two (Attachment 26). He was also asked to clarify if the digesters are vented. In an email dated April 15, 2014, Mr. Cutbirth provided the following reply to the above questions (Attachment 26). You are correct, 9A and 10A Boilers each have a hog fuel storage pile (Figure C- Page 50 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ 11 calls these two storage areas wood waste piles) associated with each boiler. The 9A bark pile is located northwest of 9A Boiler and the 10A bark pile is located just east of 10A Boiler. I see that the Facility Map calls 9A Boiler bark pile "bark storage" and the 10A Boiler bark pile is called "wood waste pile". All of these names are synonymous with "wood waste". Non-condensable gases (NCG) Mr. Cutbirth provided the following information on non-condensable gases: Upon completion of each cook, the contents of each digester are emptied (blown) to a hardwood or softwood blow tank. The gases exiting the blow tanks are routed to the NCG collection system where the non-condensable portion of these gases is ultimately burned in the Incinerator. Each of the digesters also has a small vent that is directed to the turpentine system. Emissions from this system are combined back with the other digester gases and are routed to the incinerator. V. MATHEMATICAL PROCEDURES FOR CALCULATIONS Attachment 59 is a spreadsheet showing "Description of information used in making the Form R threshold determinations. W. MATHEMATICAL PROCEDURES FOR UTILIZING FORM A's The establishment did not utilize any Form A's for reporting for the years 2008 to 2012. X. TIER TWO REPORT A copy of the 2013 Tier Two Report is included in the inspection folder. The report was reviewed for TRI chemicals used at the facility. Y. ANNUAL EMISSIONS INVENTORY REPORT A copy of the 2012 Annual Emissions Inventory Report is included in the inspection folder. The report provides a second source of information on the chemical releases by the facility. Page 51 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ Z. LATITUDE AND LONGITUDE Source 2004 Form R Latitude 033 08' 41" 033.144722 Longitude 091 58' 17" 091.971389 Facility Registry 33.141395 System (FRS) -91.97395 Center of Manufacture 33.141395 -91.97395 Inspector Comments (Attachment 58) (Attachment 3) The Center of Manufacture is equal to the Facility Registry System latitude and longitude readings (Attachment 63) Readings were not taken. AA. CLOSING CONFERENCE The Staff was very cooperative throughout the inspection and tour. The inspection was concluded at approximately 4:45 pm. Lawrence V. Stranne, P.E. EPCRA 313 Inspector Attachments: 1. Plywood/Stud Mill idled production 2. Notification to the State of Arkansas 3. FRS lat and lon 4. Kaiser 3-20-2014 letter 5. GP web site information 6. History from GP web site 7. Information from the 2010 Arkansas Manufacturers Register 8. Environmental Justice Information 9. 2-28-2014 letter, notification of inspection 10. 3-27-2014 request for information on H2S etc. 3-31-2014 GP reply 3-31-2014 question on recovery furnace 3-31-2014 GP reply 11. 3-28-2014 request for miscellaneous information 12. 3-28-2014 request for information on flow chart 5-20-2014 request for copy of reply 5-21-2014 GP reply Page 52 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ 13. 4-1-2014 request for H2S information 14. 4-1-2014 GP request for copy of the inspection report 15. 4-2-2014 request for information on venting of equipment 4-3-2014 GP reply 16. None 17. Form R DUNS numbers 18. Request for copies of MSDS's 4-17-2014 GP reply 19. 4-8-2014 forwarded Wakeland request 20. 4-7-2014 GP reply on CBI 21. 4-7-2014 barium compounds 22. 4-8-2014 request for information on basis of estimate 4-8-2014 GP reply 4-9-2014 request for additional information 4-11-2014 GP reply 23. 4-9-2014 request for information on products of combustion 4-21-2014 GP reply 24. 4-9-2014 question on used oil 4-11-2014 GP reply 25. 4-10-2014 questions on H2S 26. 4-11-2014 questions on the facility map 4-15-2014 GP reply 27. 4-22-2014 request for information on TRS 28. 4-22-2014 question on wastewater flow chart 4-25-2014 GP reply 29. 5-30-2014 questions on flow chart and black liquor tanks 30. 5-30-2014 request for additional spread sheets for H2S 5-30-2014 questions of flow charts 31. 6-10-2014 questions on landfill and H2S emissions 32. 6-10-2014 GP provided information for the 6-11-2014 conference call 33. 6-10-2014 GP provided information on H2S and methyl mercaptan releases 34. None 35. 3-19-2014 sign in sheet 36. Map of facility 37. Process flow chart 38. Revised process flow charts 39. EPA RCRA inspection note 40. EPA RCRA inspection report 41. GP reply on wastewater treatment plant acreage 42. Description of the kraft process 43. Nitrate compounds Form R postmark date 44. None 45. Form R reports by the three facilities 46. Report on H2S and methyl mercaptan releases Page 53 of 54 Georgia-Pacific Crossett Paper Operations, 100 Mill Supply Road, Crossett, AR 71635 (Primary NAICS code 322110, pulp mills) March 19, 2014, EPCRA 313 Inspection Report ______________________________________________________________________________________ 47. List of pulp mills releasing H2S 48. List of all industries releasing H2S 49. Chemical dictionary and Wikipedia information on H2S 50. 3-31-2014 GP reply on H2S emissions 51. 5-30-2014 threshold and release calculations 52. Chemical dictionary information on anhydrous ammonia 53. 12-6-2012 TCLP test results 54. TLCP description 55. NAICS code information 56. None 57. None 58. Form R lat and lon 59. Threshold determinations 60. Chemical dictionary information for acetaldehyde 61. 3-20-2014 Sarah Ross notes 62. 6-9-2014 conference call on 6-11-2014 63. Center of manufacture lat and lon 64. 6-20-2014 reply to questions during conference call 65. Emails related to revising flow charts 66. Suggested changes to the draft inspection report 67. Request for copy of Attachment 8 Page 54 of 54