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Parsons, Nick

From: Vasquez, Paul J. <PJVASQUE@GAPAC.com>

Sent: Thursday, April 03, 2014 2:31 PM

To: Parsons, Nick

Subject: GP Comments Follow-up

Attachments: Crossett Test Summary May2012.pdf

Importance: High

Hi Nick, 

Below is the additional information you requested. 

- Additional explanation of the continuous process vent discussed in this footnote in your comments: 

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 As additional background, in addition to having an existing continuous process vent (Resin Spray Dryer), 

the GPC’s Crossett Chemical Plant also has a separate Amino/Phenolic Resin Unit (“APPU”) which 

manufactures formaldehyde and urea formaldehyde concentrate (“UFC”). This unit currently only produces

UFC which is part of the amino/phenolic resins group. The primary process equipment in this process unit 

includes: material transfer equipment; vaporizer, converter, absorber; and equipment related to the 

transfer, storage and loading of UFC. Although Subpart OOO currently does not require emission controls 

for continuous process vents within an existing affected source, emissions from the UFC manufacturing 

process are currently controlled by a Regenerative Thermal Oxidizer (“RTO”), which was installed to 

comply with the HON requirements for formaldehyde production. 

Particularly, can you confirm that this continuous process vent is subject to OOO, as well as provide 

information on emissions and control device performance? 

Response - The footnote referenced above describes a continuous process vent at GPC’s Crossett Chemical 

Plant that is subject to Subpart OOO, but which is associated with a process – the manufacture of 

formaldehyde or urea-formaldehyde concentrate (UFC) – that is significantly different than the spray dryer 

process described elsewhere in GP’s comment letter. Although both processes have associated continuous 

process vents subject to Subpart OOO, the differences in the underlying processes must be considered when 

comparing the emission control strategies for the associated continuous process vents. 

As background, GP provides the following brief description of the formaldehyde/UFC and spray dryer 

processes at its Crossett Chemical Plant. 

Formaldehyde/UFC Production: 

Urea Formaldehyde Concentrate (UFC) production 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: 

• 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; 

• 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 
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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 hence the main reason why this process

unit is controlled with an RTO. 

. 

The formaldehyde/UFC manufacturing production unit at GPC’s Crossett Chemical Plant, however, can switch 

from formaldehyde solution production to UFC production by simply switching the absorber from 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 has 

been, and continues to be, the primary product produced by the formaldehyde/UFC production unit at the

Crossett Chemical Plant, GPC has long considered the UFC production process to constitute a continuous

process vent that is subject to Subpart OOO. 

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 Regenerative Thermal Oxidizer (RTO) to account for 

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

would apply. 

Spray Dryer Process: 

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. 

RTO Performance at the Crossett Chemical Plant 

You also requested information on emissions and control device performance for the RTO that receives 

exhaust gas from the formaldehyde/UFC process described above. Initially, it should be noted that this RTO 

also controls emissions from several others sources at the Crossett Chemical Plant, including (a) three Subpart 

OOO resin batch reactors; (b) a HON Group 1 MeOH storage tank; (c) five HON Group 2 formaldehyde 

storage tanks; (d) one HON Group 2 formaldehyde and UFC load rack; (e) six UFC storage tanks; (f) two Wet 

Strength MACT (40 CFR 63, Subpart W) batch reactors; (g) one additional batch reactor; and (h) one vapor 

recovery tank. This combination of emission sources constitutes an “aggregate batch vent stream”. As

required by 40 CFR § 63.1408(a)(2), aggregate batch vent streams must reduce organic HAP (OHAP) 

emissions by 83 weight percent or reduce OHAP outlet emissions to below 20 ppmv @ 3% oxygen. However,

because the aggregate batch vent stream also controls the emissions from a HON Group 1 storage tank 

regulated by 40 CFR § 63.119(e), the RTO temperature range was established to meet an OHAP destruction

efficiency level of 95 weight percent or more. A copy of the most recent stack test summary is 

attached. Please note that this test was conducted with the heat recovery system on and off. 

- Information on any other continuous process vents on affected APR sources at the Crossett, 

Taylorsville, or Conway facilities, regardless of whether or not they are located on the dryer. 

Response - GP does not have any other continuous process vent subject to Subpart OOO, other than those 

continuous process vents already disclosed to the agency. These include: 

• Crossett, Arkansas 

o One Formaldehyde/Urea Formaldehyde Concentrate (UFC) Process which continues to 

predominately manufacture UFC. This is an existing continuous process unit subject to 

Subpart OOO with no applicable control requirements. However, emissions from this 

process is routed to the RTO as part of the aggregate vent stream. 

o One APR Spray Dryer – uncontrolled. 

• Conway, North Carolina 
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o One APR Spray Dryer – uncontrolled. 

• Taylorsville, Mississippi 

o One APR Spray Dryer – uncontrolled. 

Let me know me know if you have any questions regarding this information. Thanks. 

From: Parsons, Nick [mailto:Parsons.Nick@epa.gov] 

Sent: Friday, March 28, 2014 3:58 PM 

To: Vasquez, Paul J. 

Subject: RE: GP Comments Follow-up 

Hi Paul, 

Thanks for the update. I’ll let you know if there’s any other data we need on these particular continuous 

process vents, and look forward to receiving the additional information next week. 

- Nick 

From: Vasquez, Paul J. [mailto:PJVASQUE@GAPAC.com] 

Sent: Friday, March 28, 2014 3:52 PM 

To: Parsons, Nick 

Subject: RE: GP Comments Follow-up 

Importance: High 

Hi Nick, 

First of all, please accept our apologies for the delay in responding to your request for additional 

information. Attached please find an updated Table 1 with the airflows corresponding to each emissions test 

that you requested. We are still researching the additional information you requested, and should be able to 

send you the rest of the information early next week. Thank you for your understanding. 

From: Parsons, Nick [mailto:Parsons.Nick@epa.gov] 

Sent: Monday, March 24, 2014 11:04 AM 

To: Vasquez, Paul J. 

Subject: RE: GP Comments Follow-up 

Thanks Paul. Please let me know if you have any questions on the information I’ve requested. 

- Nick 

From: Vasquez, Paul J. [mailto:PJVASQUE@GAPAC.com] 

Sent: Monday, March 24, 2014 8:05 AM 

To: Parsons, Nick 

Subject: RE: GP Comments Follow-up 

Importance: High 

Nick, we are currently working on your request. Thanks. 

 
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From: Parsons, Nick [mailto:Parsons.Nick@epa.gov] 

Sent: Thursday, March 20, 2014 3:55 PM 

To: Vasquez, Paul J. 

Subject: GP Comments Follow-up 

Hi Paul, 

I finally received Georgia-Pacific’s comments on the AMF-PC-P&R III RTR proposal (must’ve gotten lost in 

our mail system here), and we are currently reviewing the emissions data that you submitted for the dryer 

continuous process vents at the Crossett, Taylorsville, and Conway facilities. However, in order for us to 

properly evaluate the emission limits and control options, there are a few additional pieces of information that 

we need: 

- The gas flow rates for the emissions tests reported in Attachment B – Table 1. 

- Additional explanation of the continuous process vent discussed in this footnote in your comments: 

1

 As additional background, in addition to having an existing continuous process vent (Resin Spray Dryer), the 

GPC’s Crossett Chemical Plant also has a separate Amino/Phenolic Resin Unit (“APPU”) which manufactures 

formaldehyde and urea formaldehyde concentrate (“UFC”). This unit currently only produces UFC which is part of 

the amino/phenolic resins group. The primary process equipment in this process unit includes: material transfer 

equipment; vaporizer, converter, absorber; and equipment related to the transfer, storage and loading of UFC. 

Although Subpart OOO currently does not require emission controls for continuous process vents within an existing 

affected source, emissions from the UFC manufacturing process are currently controlled by a Regenerative Thermal 

Oxidizer (“RTO”), which was installed to comply with the HON requirements for formaldehyde production. 

Particularly, can you confirm that this continuous process vent is subject to OOO, as well as provide 

information on emissions and control device performance? 

- Information on any other continuous process vents on affected APR sources at the Crossett, Taylorsville, 

or Conway facilities, regardless of whether or not they are located on the dryer. 

Please let me know if you have any questions. I’ll be out of the office tomorrow, but will be back on Monday 

next week. Thanks. 

-- 

Nick Parsons 

Environmental Engineer 

U.S. Environmental Protection Agency 

OAR/OAQPS/SPPD/RCG 

Research Triangle Park, NC 

919.541.5372 

parsons.nick@epa.gov

"No man is more important than the team." -Bo Schembechler