# E C 

# / R Incorporated Providing Environmental Technical Support Since 1989

1 MEMORANDUM

DATE: May 2 2

, 201 4

TO: Nick Parsons

, EPA OAQPS/SPPD/ RC G

FROM: Jeff Harris , EC/R, Inc.

SUBJECT: Summary of the May 21

, 20 1 4

, 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

- HQ

OAR

- 2012

- 0133 ). The proposed rule for Amino/Phenolic Resin Production (APR) wa s 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 Harris2

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 represe ntatives 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 l iquid 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

se ries of cyclones, a secondary cyclone

, and a product cyclone

, all of which are intended to

colle ct the powdered resin product. After the cyclones, the air stream is vented through the spray dryer baghouse as the final part iculate matter control device. Bec ause 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 simi lar, 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 occa sional breaks for maintenance. They are generally a ble to change products without needing to shut down the proc ess. 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 th e product and additionally to control particulate

emissions

.3

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 provi ded by GP at a later date. These data are calculated using an emission factor based on the most recent per formance test. HAP emissions include methanol, formaldehyde, phenol, and acetaldehyde. The performance tests were performed during production of resin s 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 woul d 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 chang es 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:4

 A vaporizer, where the feedsto ck, 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 hi gh 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 abs orber

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 requ ired by the Hazardous Organic NESHAP (HON) regulations, and this is the main reason why this process unit is controlled with

a r egenerative thermal o xidizer ( 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 othe r mi nor process modifications. The urea chemically reacts with the formaldehyde to form UFC, which serves as

an intermediate used in downstream ami no resin production processes. UFC is not a chemical

c overed 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 continuous ly, with occasional breaks for maintenance. The process is permitted to run 8760 hours per year, and generally come close to that

.

Control Devices

A n RTO was installed previously for other processes compliance with volatile organic compound ( VOC ) limits due to P revention of S ignificant D eterioration ( 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, in cluding resin manufacturing, methanol storage, formaldehyde storage, and UFC/formaldehyde production.5

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 R TO 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 tot al 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), t he 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.A

- 1 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 presen t 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 continuou s 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?A

- 2 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?