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/R Incorporated Providing Environmental Technical Support Since 1989

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MEMORANDUM

DATE: May 22, 2014

TO: Nick Parsons, EPA OAQPS/SPPD/RCG

FROM: Jeff Harris, EC/R, Inc.

SUBJECT: Summary of the May 21, 2014, Meeting with Georgia Pacific, LLC and the U.S. 

Environmental Protection Agency

I. INTRODUCTION

Georgia Pacific, LLC requested this meeting with EPA to discuss the status of the Final 

Rule for the Amino/Phenolic Resin Production NESHAP (40 CFR Part 63, subpart OOO). This 

meeting summary will be available in the docket for this rulemaking (Docket ID No. EPA-HQOAR-2012-0133). The proposed rule for Amino/Phenolic Resin Production (APR) was 

published in the Federal Register on January 9, 2014 (79 FR 1676).

II. ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency

Nick Parsons

Georgia Pacific, LLC

Michael Curtis, Technical Support Group Director

Paul Vasquez, Corporate Environmental Affairs Project Lead

Tommy Adkins, Facility Environmental Manager

EC/R Incorporated

Lesley Stobert

Jeff Harris
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III. SUMMARY OF DISCUSSION

Appendix A includes a copy of the questions that were provided to Georgia Pacific (GP) in 

advance of the meeting. Discussion focused on process vents from two different processes: resin 

spray dryers and urea-formaldehyde concentrate (UFC) production. Spray dryers were discussed 

first because they are present at multiple GP facilities, followed by discussion of UFC 

production, which only occurs at a single GP facility. GP provided draft responses to the 

questions, which were collected by the GP representatives after the meeting concluded. Final 

responses will be provided by GP in the near future.

A. Resin Spray Dryers

Process

Spray dryers are present at three GP APR facilities: Crossett, AR, Conway, NC, and 

Taylorsville, MS.

The Spray Dryer Plant is a continuous process used to dry certain types of liquid resins to a 

powder form. Liquid resin is atomized into a drying chamber and mixed with air heated by a 

large burner/air heater. From the drying chamber, the dry powdered resin is processed through a 

series of cyclones, a secondary cyclone, and a product cyclone, all of which are intended to 

collect the powdered resin product. After the cyclones, the air stream is vented through the spray 

dryer baghouse as the final particulate matter control device. Because Subpart OOO does not 

require emission controls for continuous process vents within an existing affected source, the 

HAP emissions from the Spray Dryer are not controlled.

The resin spray dryers produce a variety of resin products, all generally similar, with slightly 

different formulations according to their intended use. The primary ingredients (phenol and 

formaldehyde) are the same for all, with some product specific additives. The resins are used by 

GP in production of wood products such as plywood and oriented strand board (OSB).

The spray dryers operate continuously, with occasional breaks for maintenance. They are 

generally able to change products without needing to shut down the process. The processes are 

permitted to run 8760 hours per year, and generally come close to that.

GP pointed out that there are some minor-source third-party operations who perform spray 

drying of resins produced elsewhere, as a service to other resin manufacturers.

Control Devices

None of the continuous spray dryers operated by GP are equipped with HAP emissions 

controls. As mentioned previously, they are equipped with particulate controls (cyclones and 

fabric filters), which are used to collect the product and additionally to control particulate 

emissions.
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One work practice employed is injection of a scavenger into the dryer with the liquid 

resin, which removes residual formaldehyde and phenol.

Emissions

Additional emissions data will be provided by GP at a later date. These data are 

calculated using an emission factor based on the most recent performance test. HAP emissions 

include methanol, formaldehyde, phenol, and acetaldehyde. The performance tests were 

performed during production of resins known to have the highest emissions.

Absence of acetaldehyde in emissions data from the Conway, NC facility is suspected to 

be because the data is from an older test, which may not have included a test for acetaldehyde. 

There is no known process-based reason for its absence. 

Production data will be provided at a later date, and will be considered confidential.

Wastewater

There is some variation among the plants with regard to wastewater facilities.

The Crossett, AR facility is co-located with a pulp mill/plywood mill/paper mill that has 

its own wastewater treatment plant, and is included in the NPDES permit for the paper mill.

The Taylorsville, MS facility discharges a small amount of non-contact cooling water to 

the POTW.

The Conway, NC and Taylorsville, MS facilities both re-use process wastewater when 

possible. Any unusable process wastewater from these facilities is trucked away by a wastewater 

disposal firm.

Startup/Shutdown

The spray dryer process has no specific conditions which would necessitate a different 

standard during startup or shutdown.

B. Urea-Formaldehyde Concentrate (UFC) Production

Process

Urea Formaldehyde Concentrate (UFC) production is present only at the Crossett, AR 

facility, and is accomplished via raw material changes and minor process modifications to the 

formaldehyde production unit. The basic formaldehyde production unit is a continuous air 

oxidization reaction manufacturing process which consists of the following unit operations: 
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 A vaporizer, where the feedstock, methanol (MeOH), is flashed and mixed with the air 

stream and a recycle stream which contains small amounts of formaldehyde and MeOH, 

reaction byproducts, water vapor and non-condensable vapors;

 A superheater, where the air-MeOH mixture is heated by high pressure steam;

 A catalytic converter; an exothermic reaction of MeOH and oxygen in the catalytic 

converter produces formaldehyde and water and some reaction byproducts; and

 A trayed column absorber, where formaldehyde and water vapor are absorbed into water 

to produce various concentrations of formaldehyde solution (typically 50% solution).

Formaldehyde solution exits the bottom of the absorber and is transferred to storage, 

completing the manufacturing process. The non-condensable vapors exit the absorber 

overhead. A portion of the vapor stream vents back to the vaporizer(s) while the remaining tail 

gas is directed to the control device. If this process produced formaldehyde, the control of HAP 

emissions in this remaining tail gas stream would be required by the Hazardous Organic 

NESHAP (HON) regulations, and this is the main reason why this process unit is controlled with 

a regenerative thermal oxidizer (RTO).

The formaldehyde/UFC manufacturing production unit at GP’s Crossett Chemical Plant, 

however, can switch from formaldehyde solution production to UFC production by simply 

switching from use of cooled/chilled water to urea solution, along with a few other minor process 

modifications. The urea chemically reacts with the formaldehyde to form UFC, which serves as 

an intermediate used in downstream amino resin production processes. UFC is not a chemical 

covered by the HON regulations. Because the formaldehyde/UFC production unit is part of the 

equipment used to manufacture amino resins, along with the fact that UFC is now the primary 

product produced by the formaldehyde/UFC production unit at the Crossett Chemical Plant, the 

unit is subject to Subpart OOO. 

The Crossett facility has another unit dedicated to formaldehyde production, so for the last 

six years or so, the unit in question has been producing 100% UFC, although it is permitted to 

produce both UFC and formaldehyde. 

The UFC process operates continuously, with occasional breaks for maintenance. The 

process is permitted to run 8760 hours per year, and generally come close to that.

Control Devices

An RTO was installed previously for other processes compliance with volatile organic 

compound (VOC) limits due to Prevention of Significant Deterioration (PSD) permitting. At or 

near the time HON was first being promulgated, the Crossett Chemical Facility elected to route 

the exhaust gas from the Formaldehyde/UFC process to the existing RTO to account for the 

possibility that the process could switch to formaldehyde production, in which case the HON 

regulations would apply. The air volume exhausted is approximately one-tenth that of the spray 

dryer. The RTO controls emissions streams from multiple processes, including resin 

manufacturing, methanol storage, formaldehyde storage, and UFC/formaldehyde production.
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The RTO meets the required control efficiency of 95+% for the HON, and actually 

achieves in excess of 97% control.

Emissions

HAP emissions from the RTO include methanol, formaldehyde, acetaldehyde, 

epichlorohydrin, cresols, and HCl. However, these are not all emitted by the UFC process. GP 

will provide additional data regarding emissions from the RTO, and will attempt to estimate the 

portion of the total emissions (and the specific pollutants) resulting from the UFC production 

process. These will be calculated using engineering estimates.

Wastewater

The UFC process has a small wastewater stream, which is discharged to the on-site 

wastewater treatment facility.

Startup/Shutdown

Because the RTO operates continuously due to its use for multiple processes (including 

storage tanks), the UFC process has no specific conditions which would necessitate a different 

standard during startup or shutdown. The process is also currently operating under the SSM 

provisions of the HON.
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APPENDIX A

Questions Provided to Georgia Pacific in Advance of the Meeting

Draft Questions Regarding Amino and Phenolic Resins Continuous Process Vents

1. Resin Production

a. What types of resins are produced in the process unit(s) with continuous process 

vents?

b. What are the raw material inputs?

c. What is the resin production process (process description)?

d. Does the resin production process operate continuously (8760 hours/year) or on a 

reduced schedule?

2. Control Devices

a. Are any HAP control devices present on the process unit(s)? Briefly describe 

them.

b. What is the HAP control efficiency of those devices?

c. Are there any other air emissions control devices present that do not primarily 

control HAP?

3. Emissions

a. What have the total HAP emissions from continuous process vents been for each 

of the last 5 years?

b. What HAP are emitted from continuous process vents?

c. How do you calculate your HAP emissions from continuous process vents?

d. What have the resin production rates been from process units with continuous 

process vents for each of the last 5 years?

4. Wastewater

a. Is process wastewater generated at this facility?
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b. If so, how is the process wastewater treated and disposed?

5. Startup/Shutdown

a. What are the process startup and shutdown procedures?

b. Would a separate standard be needed for startup and shutdown periods?