1 

### 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 co mments:

1 As additional background, in addition to having an existing continuous process vent (Resin Spray Drye r), the GPC’s Crossett Chemical Plant also has a separa te Amino/Phenolic Resin Unit (“APPU”) which manufactures formaldehyde and urea formaldehyde con centrate (“UFC”). This unit currently only produces UFC which is part of the amino/phenolic resins grou p. The primary process equipment in this process un it includes: material transfer equipment; vaporizer, c onverter, absorber; and equipment related to the transfer, storage and loading of UFC. Although Subp art OOO currently does not require emission control s for continuous process vents within an existing aff ected 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 p roduction. Particularly, can you confirm that this continuous process vent is subject to OOO, as well as provide information on emissions and control device perform ance?

Response - The footnote referenced above describes a contin uous 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 d ryer process described elsewhere in GP’s comment letter. Although both processes have associated continuou s process vents subject to Subpart OOO, the differenc es in the underlying processes must be considered w hen comparing the emission control strategies for the a ssociated continuous process vents.

As background, GP provides the following brief desc ription of the formaldehyde/UFC and spray dryer processes at its Crossett Chemical Plant.

Formaldehyde/UFC Production: Urea Formaldehyde Concentrate (UFC) production is a ccomplished via raw material changes and minor process modifications to the formaldehyde productio n unit. The basic formaldehyde production unit is a continuous air oxidization reaction manufacturing p rocess which consists of the following unit operati ons:

• A vaporizer, where the feedstock, methanol (MeOH), is flashed and mixed with the air stream and a recycle stream which contains small amounts of form aldehyde and MeOH, reaction byproducts, water vapor and non-condensable vapors;

• A superheater, where the air-MeOH mixture is heate d by high pressure steam;

• A catalytic converter; an exothermic reaction of M eOH and oxygen in the catalytic converter produces formaldehyde and water and some reaction byproducts ;

• A trayed column absorber, where formaldehyde and w ater vapor are absorbed into water to produce various concentrations of formaldehyde solution (ty pically 50% solution).

Formaldehyde solution exits the bottom of the absor ber 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 rem aining tail gas is directed to the control device. If this2 process produced formaldehyde, the control of HAP e missions in this remaining tail gas stream would be required by the Hazardous Organic NESHAP (HON) regu lations, 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 swit ch from formaldehyde solution production to UFC produc tion by simply switching the absorber from cooled/c hilled water to urea solution, along with a few other mino r process modifications. The urea chemically reacts with the formaldehyde to form UFC, which serves as an interm ediate used in downstream amino resin production processes. UFC is not a chemical covered by the HO N regulations. Because the formaldehyde/UFC production unit is part of the equipment used to ma nufacture amino resins, along with the fact that UF C has been, and continues to be, the primary product prod uced by the formaldehyde/UFC production unit at the Crossett Chemical Plant, GPC has long considered th e 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 t he exhaust gas from the Formaldehyde/UFC process to th e Regenerative Thermal Oxidizer (RTO) to account fo r the possibility that the process could switch to fo rmaldehyde production, in which case the HON regula tions 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 chamb er 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 whic h are intended to collect the powdered resin produc t. After the cyclones, the air stream is vented through the spray dryer baghouse as the final particulate matte r control device. Because Subpart OOO does not require emiss ion controls for continuous process vents within an existing affected source, the HAP emissions from th e Spray Dryer are not controlled.

RTO Performance at the Crossett Chemical Plant You also requested information on emissions and con trol device performance for the RTO that receives exhaust gas from the formaldehyde/UFC process descr ibed above. Initially, it should be noted that thi s 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 st orage 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 vap or recovery tank. This combination of emission source s 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 outle t emissions to below 20 ppmv @ 3% oxygen. However, because the aggregate batch vent stream also contro ls the emissions from a HON Group 1 storage tank regulated by 40 CFR § 63.119(e), the RTO temperatur e range was established to meet an OHAP destruction efficiency level of 95 weight percent or more. A c opy 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 proc ess vents on affected APR sources at the Crossett, Taylorsville, or Conway facilities, regardless of w hether or not they are located on the dryer.

Response - GP does not have any other continuous process ve nt subject to Subpart OOO, other than those continuous process vents already disclosed to the a gency. These include:

• Crossett, Arkansas

o One Formaldehyde/Urea Formaldehyde Concentrate (UF C) 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 aggrega te vent stream.

o One APR Spray Dryer – uncontrolled.

• Conway, North Carolina3 o One APR Spray Dryer – uncontrolled.

• Taylorsville, Mississippi

o One APR Spray Dryer – uncontrolled.

Let me know me know if you have any questions regar ding 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 continu ous process vents, and look forward to receiving the add itional 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 d elay in responding to your request for additional information. Attached please find an updated Table 1 with the airflows corresponding to each emission s test that you requested. We are still researching the a dditional information you requested, and should be able to send you the rest of the information early next wee k. 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 que stions 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. Th anks.4 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 th e AMF-PC-P&R III RTR proposal (must’ve gotten lost in our mail system here), and we are currently reviewin g the emissions data that you submitted for the dry er continuous process vents at the Crossett, Taylorsvil le, and Conway facilities. However, in order for us t o properly evaluate the emission limits and control o ptions, there are a few additional pieces of informa tion that
we need:

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

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

1 As additional background, in addition to having an existing continuous process vent (Resin Spray Drye r), the GPC’s Crossett Chemical Plant also has a separate A mino/Phenolic Resin Unit (“APPU”) which manufacture s formaldehyde and urea formaldehyde concentrate (“UF C”). This unit currently only produces UFC which is part of the amino/phenolic resins group. The primary proces s equipment in this process unit includes: material transfer equipment; vaporizer, converter, absorber; and equipmen t related to the transfer, storage and loading of UF C. Although Subpart OOO currently does not require emi ssion controls for continuous process vents within an existing affected source, emissions from the UFC manufacturin g process are currently controlled by a Regenerativ e Thermal Oxidizer (“RTO”), which was installed to comply with the HON requirements for formaldehyde production. Particularly, can you confirm that this continuous p rocess vent is subject to OOO, as well as provide information on emissions and control device perform ance?

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

, or Conway facilities, regardless of whether or not t hey 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 M onday
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 Schem bechler