FOLLOWING AN INVESTIGATION OF THE LOUSIANA-PACIFIC CORPORATION (LP), EPA BEGAN AN INVESTIGATION OF THE OTHER LEADERS IN THE WOOD PRODUCTS INDUSTRY TO DETERMINE THE STATUS OF THEIR COMPLIANCE WITH THE CAA. EPA'S INVESTIGATION OF THE GEORGIA-PACIFIC CORPORATION (GP) AT FIRST FOCUSED ON ITS ORIENTED STRAND BOARD (OSB) AND MEDIUM DENSITY FIBERBOARD (MDF) FACILITIES BUT WAS LATER EXPANDED TO INCLUDE PLYWOOD AND PARTICLEBOARD FACILITIES AS WELL AS SOME CHIP AND SAW AND STUDMILL FACILITIES. EPA HAS REVIEWED FACILITIES AT 26 LACATIONS USING EITHER CAA SECTION 114 INFORMATION REQUEST LETTERS OR INSPECTIONS BY EPA CONTRACTORS OR EPA PERSONNEL OR BOTH. AS A RESULT OF THIS INVESTIGATION, EPA FOUND THAT GP HAD FAILED TO OBTIAN PREVENTION OF SIGNINFICANT DETERIOATION (PSD) PERMITS AS REQUIRED BY SECTION 160-169A OF THE CAA, 42 U.S.C SECTION 7470-7479A, AT MANY OF ITS FACILITIES. FUNDAMENTAL TO GP'S FAILURE TO APPLY FOR PSD PERMITS WAS ITS FAILURE TO PROPERLY QUANTIFY VOLATILE ORGANIC COMPOUND (VOC) EMISSIONS FROM PROCESS EQUIPMENT, PRIMARILY DRYERS AND PRESSES. AS A RESULT OF GP'S FAILURE TO APPLY FOR PSD PERMITS, REQUIRED POLLUTION CONTROL EQUIPMENT HAS NOT BEEN INSTALLED ON PROCESS EQUIPMENT AT THE VIOLATING FACILITIES. GP'S FAILURE TO IDENTIFY VOC EMISSIONS ALSO ARE VIOLATIONS OF STATE IMPLEMENTATION PLANS (SIP) PROVISIONS DEALING WITH GENERAL PERMITTING REQUIREMENTS AP