From:		Curtis, Michael [  HYPERLINK "mailto:MICHAEL.CURTIS@GAPAC.com" 
mailto:MICHAEL.CURTIS@GAPAC.com ]

Sent:		Friday, May 06, 2011 5:50 PM

To:		'Bradfield.John@epamail.epa.gov'

Cc:		'Schrock.Bill@epamail.epa.gov'; 'Spence.Kelley@epamail.epa.gov';
Hanks, Katie P.; Galler, Wayne J.; Cooley, Cindy S.; Bottini, John C.
(GP Law)

Subject: GP's New Substance Review Program

May 6, 2011

Mr. John Bradfield

U.S. EPA

Natural Resources Group

Sector Policies and Programs Division, OAQPS

109 T.W. Alexander Drive (E143-03)

Research Triangle Park, NC 27709

Subject:  Georgia-Pacific New Substance Review Program

Dear Mr. Bradfield:

As you request, Georgia-Pacific is providing EPA with the following
information regarding our “New Substance Review” (NSR) program. 
You asked for this information to assist EPA in developing a potential
work practice for 40 CFR Part 63, Subpart S sources under the Residual
Risk and Technology Review.  Our specific responses to your questions
are noted below.

1. Does G-P have their “New Substance Review” program written in
some document that they could share with EPA to use in formulating a
work practice?  

The following is a summary of Georgia-Pacific’s New Substance Review
Program rather than specific written documentation of the program.  The
documents Georgia-Pacific has are more comprehensive program reviews
that includes several areas of review beyond environmental.

Georgia-Pacific has developed and implemented a program to review and
approve new chemicals utilized in the manufacturing processes.  The New
Substance Review Procedure assists our facilities in evaluating the
environmental implications, if any, associated with changes in chemicals
used in operations. The program also assists some facilities in meeting
their environmental permitting requirements for evaluating
VOC-containing materials before using those materials in the regulated
paper machines.  The program requirements include obligations to:

develop and document facility administrative procedures for managing and

controlling chemical use; and 

manage new chemicals brought on-site and properly report chemical
inventories and releases.

The following is an overview of the New Substance Review Program
established for use in Georgia-Pacific operations.  This is a summary
of the minimum program expectations that will be implemented by business
within the company. 

Prequalification for Chemical Purchasing and Use

Before chemicals are ordered and brought on-site, these new substances
must be reviewed using a New Substance Review procedure.  This
procedure must meet the following minimum expectations:

Any substance used in the permitted manufacturing process must be
evaluated to determine if it contains any chemicals that have restricted
or limited uses set by the facility, business or regulations. 

The operating area wishing to use the new chemical must submit a new
substance review form for internal review.  This submittal must
include: the operational parameters for use, estimated use, and the
proposed system to monitor use of the substance, MSDS, Supplier product
information and any additional information that may be needed for
evaluation.  

The Environmental Approver(s) of the new substance must evaluate the use
of the substance at the facility.  This will include examining the new
substance review form, the MSDS, the Supplier Assurance Form, and
related information for the presence of any restricted/limited use
chemicals.  The Approver must identify any potential on-site
environmental issues or reporting requirements.  If necessary, the
Environmental Approver may seek technical assistance to determine if the
proposed use is appropriate.

The Environmental Approver must determine if there are any potential
environmental issues, use restrictions or reporting requirements
associated with using the chemical. Specific environmental limitations
or requirements will be identified in this review. 

Finally, a system must be in place to provide the purchasing department
at the facility or the divisional purchasing person with information
about approved/disapproved new substances or restrictions on their
use.  The purchasing department cannot order the chemical until it
knows that it was approved. 

The facility and/or business must maintain a list of these
restricted/limited use chemicals.

2. Which aspects of the “New Substance Review” program have been or
could be used generically at G-P?

The program noted in our response to question 1 is the generic program
used by GP.  The summary only highlights the environmental components
of the program. We also use this program to address safety and product
stewardship concerns.

3. Is there an estimate of the cost of developing and implementing the
program (e.g., in terms of labor hours)? 

Georgia-Pacific does not have a specific cost of developing and
implementing this program.  

4. How is continuous compliance with the program demonstrated (e.g.,
recordkeeping)?

Georgia-Pacific maintains a list of chemicals that have been reviewed
and approved through the program.  No new chemicals are purchased prior
to their approval through this process.

5. How many paper machine low VOC additive products have been reviewed
in GP's 'new substance review' protocol and adopted(at Crossett and
elsewhere if it has been adopted broadly)?

Typically, a tissue manufacturing facility will review approximately 40
chemicals per year for tissue paper machine applications.  The number
of chemicals reviewed depends upon on-going product development
activities. 

6. What can you tell us about VOC or HAP additives that they are finding
common replacements for?  For example:

Which low VOC products work with which additive requirements?

Which species of VOC are reduced/HAPs?

What are the relative costs of the reductions, as applied?

Due to the broad scope of this question and the limited time we have
been afforded to formulate a response, Georgia-Pacific is unable to
provide you with this information at this time.  

You additionally requested our estimate of time necessary to complete an
environmental review of a new chemical.  From our assessment, we found
it takes approximately two hours to prepare a NSR form and actual
environmental reviews can takes less than 30 minutes.

Georgia-Pacific looks forward to continuing to work with EPA in
addressing the Pulp and Paper Residual Risk and Technology Review.

Sincerely,

Mike Curtis

Director, Environmental Technical Support

Atlanta, GA

404-652-4133 (office)

386-530-1012 (mobile)

