EPA Questions-GP Responses

Questions Regarding Amino and Phenolic Resins Continuous Process Vents Facility = Conway, NC Crossett, AR Taylorsville, MS Crossett, AR
Continuous Process Vent = One APR Spray Dryer – uncontrolled. One APR Spray Dryer – uncontrolled. One APR Spray Dryer – uncontrolled. One Formaldehyde/Urea Formaldehyde Concentrate (UFC) Process which continues to predominately manufacture UFC.

1. Resin Production (Spray Dryer) 1. Resin Production (UFC) a. What types of resins are produced in the process unit(s) with continuous process vents? Urea Formaldehyde Concentrate

b. What are the raw material inputs? The raw materials used by the UFC process are Methanol, ambient air, and urea solution.

c. What is the resin production process (process description)? See Attachment A for a description of the UFC production process at the Crossett, AR, facility.

d. Does the resin production process operate continuously (8760 hours/year)
or on a reduced schedule? The Formaldehyde/ Urea Formaldehyde Concentrate production process is permitted to operate 24 hours a day, 7 days a week, 52 weeks per year. Actual operating hours are dependent upon the production and maintenance schedules.

2. Control Devices 2. Control Devices a. Are any HAP control devices present on the process unit(s)? If so, please
describe. Yes. This is an existing continuous process unit subject to Subpart OOO with no applicable MACT control requirements. However, the emissions from the UFC process are routed to an
RTO which also controls the emissions from several sources. The emission sources controlled by the RTO include: (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.

b. What is the HAP control efficiency of
those devices? Because the aggregate batch vent stream controlled by the RTO also includes the emissions from a HON Group 1 storage tank regulated by 40 CFR § 63.119(e), the RTO is required to
meet a 95% DRE. c. Are there any other air emissions control devices present that do not primarily control HAP? If so, please
describe. No

3. Emissions 3. Emissions
a. What have the total HAP emissions from continuous process vents been for each of the last 5 years? See Attachment B for the total HAP emissions from the RTO controlling emissions from the UFC process and other related sources for the last 5 years (2009-2013). 1) A dry powder form of amino phenolic resin is produced in the APR Spray Dryer. This powder resin is used in composite wood manufacturing.

There are no HAPs control devices on the APR Spray Dryer process. However, work practices (i.e., raw material specifications, scavengers like ammonia, urea, etc.) are in place to reduce HCHO emissions during the manufacturing of resins used in the APR Spray Dryer process. APR for Spray Dryers uses HCHO with low concentration of MeOH. In addition, similar work practices are used to reduce HCHO emissions in panel production as well as emissions from finished panels. Low molar ratios (HCHO to Phenol) to reduce free HCHO and produce a low HCHO PF resin are also used. Compliance with the current CARB Standard for HCHO and the proposed Formaldehyde Emissions Standard for Composite Wood Products under 40 CFR Part 770 (range: 0.05 to 0.13 ppm of HCHO emissions) will require resin manufacturers to maintain and/or develop resins with low free HCHO.

Not applicable since there are no HAPs control devices downstream of the APR spray dryer process.

Yes. The APR Spray Dryer process has a product collection system consisting of cyclones and a baghouse (fabric bag filters).

See Attachment B for the total HAP emissions from the APR Spray Dryer process at Conway, Crossett and Taylorsville facilities for the last 5 years (2009-2013). See Attachment A for a description of the APR Spray Dryer production process. The APR Spray Dryer process is essentially the same at the Conway, Crossett and Taylorsville facilities.

The Spray Dry resin production processes at Conway, Crossett and Taylorsville are essentially permitted to operate 24 hours a day, 7 days a week, depending on production and maintenance schedules. The raw materials into the APR Spray Dryer are liquid amino phenolic resins to form a dry powder product. The primary constituents (weight % over 1.0) of the resins are Phenol, Formaldehyde, Urea, Ammonia and Water. Small quantities of product specific additives are also included.EPA Questions-GP Responses

Questions Regarding Amino and Phenolic Resins Continuous Process Vents Facility = Conway, NC Crossett, AR Taylorsville, MS Crossett, AR
Continuous Process Vent = One APR Spray Dryer – uncontrolled. One APR Spray Dryer – uncontrolled. One APR Spray Dryer – uncontrolled. One Formaldehyde/Urea Formaldehyde Concentrate (UFC) Process which continues to predominately manufacture UFC.

b. What HAP are emitted from continuous process vents? Methanol, Formaldehyde and Phenol are
the HAPs emitted from the continuous process vent. HAP emissions testing was done in 2006 and Acetaldehyde was not speciated. However, it is believed to be
present. Methanol, Formaldehyde, Phenol and Acetaldehyde are the HAPs emitted from the continuous process vent. Methanol, Formaldehyde, Phenol and Acetaldehyde are the HAPs emitted from the continuous process vent. Methanol, Formaldehyde, Phenol and Acetaldehyde are HAPs expected to be emitted from the UFC process. Emissions data provided in Attachment B also includes concentrations of Cresols, Epichlorohydrin and HCl contributed by other sources.

c. How do you calculate your HAP emissions from continuous process vents? There is no emissions data available for the Crossett UFC process specifically. The emissions data presented in
Attachment B data correspond to emissions from an RTO that controls emissions from the UFC process as well as other related process units. Attachment C presents a rough estimate of the potential emissions from the UFC process based on tested emissions from a similar UFC process unit at GP's Columbus, OH chemical plant and the ratio of MeOH feed
rate at the Columbus Plant and the Crossett Plant.

d. What have the resin production rates been from process units with continuous process vents for each of the last 5 years? See Attachment D for the UFC production rates for each of the last 5 years (2009-2013). This information is being claimed as
Confidential Business Information (CBI).

4. Wastewater 4. Wastewater a. Is process wastewater generated at this facility? Yes.

b. If so, how is the process wastewater treated and disposed? See Attachment E for a description of the process wastewaters generated at the facility and respective disposal method.

5. Startup/Shutdown 5. Startup/Shutdown

a. What are the process startup and shutdown procedures? Emissions from the UFC process are controlled by an RTO which also controls emissions from several other regulated sources (refer to response 2.a. above for a list of sources controlled by the RTO). As such, the operation of the RTO and related CMS are addressed in the SSM plan. In general, the UFC process cannot start-up until the RTO has reached the required operating temperature. The RTO will remain online until the UFC process is shutdown.

b. Do you believe that a separate standard for continuous process vents would be needed for startup and shutdown periods? No. No. The HAPs emissions from APR Spray Dryer process are calculated by multiplying the hourly emission rate for the HAPs determined during the most recent engineering or compliance test by the total number of hours the facility operated for the corresponding year. Another way to calculate the emissions is to develop an emission factor, in the units of lbs pollutant per ton of resin manufactured, based on the hourly emission rate for the HAPs determined during the most recent engineering or compliance test and the corresponding hourly production rate (lbs HAPs per Ton of Product). Efforts were made to test emissions using the type of resin that generated the most total HAP emissions, normally the resin(s) believed to have highest HAPs concentrations and/or the Highest HAP and Predominant Product.

See Attachment D for the APR Spray Dryer production rates at Conway, Crossett and Taylorsville facilities for each of the last 5 years (2009-2013). This information is being claimed as Confidential Business Information (CBI).

See Attachment E for an inventory of process wastewaters generated at the facility and respective disposal method and associated cost where applicable. Yes.

There are procedures for the startup and shutdown of the APR spray dryers. A typical start up and shutdown procedure for APR spray dryer is presented in Attachment F

.Attachment A

HCHO Production-- The process begins with the mixing of filtered ambient air and a recycle stream from the absorber, which contains small amounts of HCHO reaction byproducts, water vapor, and non-condensable vapors. The air/recycle mixture is fed to the MeOH vaporizer by a positive displacement blower. The feed stock, MeOH, is purchased and delivered to an on-site fixed-roof, above ground storage tank (MEOH). MeOH from the storage tank is pumped to the vaporizer where it is flashed and mixed with the air stream. The air-MeOH mixture flows to the superheater where it is heated by 150 psig steam. From the superheater, the mixture passes through a static in-line mixer before entering the catalytic converter.

The exothermic reaction of MeOH and oxygen in the HCHO process catalytic converter produces formaldehyde and water and some reaction byproducts, such as dimethylether and carbon monoxide. The heat generated by the reaction is controlled by a heat transfer fluid vaporizing cooling system. Boiler feed water is used as the coolant in the condenser and 150 psig steam is produced. The capacity of the heat transfer cooling fluid to remove heat limits the HCHO production rate.

The air stream containing reaction products passes through a boiler feed water aftercooler to the absorber. The absorber is a counter-current trayed column where HCHO and water vapor are absorbed into water to produce an approximate 50 wt.% HCHO solution. The reaction byproducts and non-condensable vapors exit the absorber overhead, with a portion recycled and the remainder sent to the thermal oxidizer. A bottoms liquid stream is recycled to the absorber through spray nozzles to quench the incoming converter reaction products. From the absorber, the HCHO product solution is pumped to above-ground, fixed-roof storage tanks.

UFC Production-- Urea-formaldehyde concentrate (UFC) production uses the same equipment and process as HCHO production. The difference is that an approximate 50 wt.% urea solution , prepared in a urea solution tank, is fed to the absorber and the urea-formaldehyde distillate stream taken from the absorber is stored in above-ground, fixed-roof urea formaldehyde concentrate tanks. Using urea solution in lieu of process water, the absorber produces an 85% UFC solution that contains a maximum of 30% free HCHO.

APR Spray Dryer Production - - The liquid resin is pumped from the resin storage tank to the atomization chamber which is located in the air distributor at the top of the drying chamber. The drying air is drawn from the atmosphere through a filter by a supply fan and passed through the air heater to the air distributor. The resin droplets produced by the atomizer meet the hot air and evaporation takes place, which in turn cools the air. After the drying of the resin droplets in the chamber, the majority of the dried product (powder resin) falls to the bottom of the chamber and entrains in the air. The resin-entrained air stream is then passed through the cyclone for separation of the dried resin particles from the air. The resin particles leave the cyclone at the bottom via a rotary valve and are collected and packed for shipment. The fine particles will remain entrained in the air and then go through the baghouse and then to the atmosphere.Attchment B

Total HAPs Emissions for APR at Conway, NC (tons/year) 2009 2010 2011 2012 2013
MeOH 44.4 37.6 36.1 48.1 53.9
HCHO 13.7 11.6 11.1 14.8 16.6
Phenol 6.4 5.4 5.2 7.0 7.8
Total HAPs 64.5 54.6 52.5 69.9 78.2

Total HAPs Emissions for APR at Crossett, AR (tons/year) 2009 2010 2011 2012 2013
MeOH 29.1 27.3 9.7 16.7 9.6
HCHO 4.2 4.0 1.4 2.5 1.4
Phenol 2.1 1.9 0.6 0.9 0.5 Acetaldehyde 3.4 3.2 0.9 1.4 0.8
Total HAPs 38.7 36.3 12.6 21.5 12.4

Total HAPs Emissions for APR at Taylorsville, MS (tons/year) 2009 2010 2011 2012 2013
MeOH 64.4 67.0 54.2 60.6 80.6
HCHO 9.3 9.6 7.5 7.6 7.3
Phenol 1.3 1.3 0.8 0.8 0.9 Acetaldehyde 1.2 1.5 2.1 1.7 0.4
Total HAPs 76.3 79.5 64.5 70.8 89.2

Total HAPs Emissions for UFC at Crossett, AR (tons/year) - Post
Control * 2009 2010 2011 2012 2013
MeOH 1.1 1.1 1.3 1.1 1.3
HCHO 0.0 0.0 0.0 0.3 0.5
Phenol 0.0 0.0 0.0 0.0 0.0 Acetaldehyde 0.0 0.0 0.0 0.0 0.0 Cresols (mixed isomers) 0.0 0.0 0.0 0.03 0.04 Epichlorohydrin 0.2 0.2 0.2 0.0 0.0 Hydrochloric Acid (Aerosols Only -

From Comustion of EPI) 2.5 2.5 2.5 0.3 0.6
Total HAPs 3.8 3.8 4.1 1.9 2.5

* Refer to response to question 2.a. The RTO control emissions from several sources (aggregate batch vent stream) regulated under HON and Resin MACT. RTO is required to meet 95% DRE under 40 CFR § 63.119(e).Attchment C

Ratio Factor = 15/10= 0.667 Columbus, OH

UFC Process Sept 2011 Test
Data Ratio for

Crossett, AR
UFC Process
based on
MeOH
feedrates MeOH Feedrate (gpm) 15 10

Total VOC (as propane) (lb/hr) 49.09 32.73

Total VOC (FTIR) (lb/hr) 138.74 92.49

Total HAP (lb/hr) 19.08 12.72

Dimethyl Ether (lb/hr) 119.66 79.77

HAP- Acetaldehyde (lb/hr) 0.2 0.13

HAP- Formaldehyde (lb/hr) 0.02 0.01

HAP- Methanol (lb/hr) 18.61 12.41

Carbon Monoxide (lb/hr) 93.84 62.56Attchment D - CBI

2009 2010 2011 2012 2013 APR at Conway, NC - Dried Resin Production (tpy) 14,787 12,503 12,022 16,013 17,927

2009 2010 2011 2012 2013 APR at Crossett, AR - Dried Resin Production (tpy) 7,154 6,320 2,432 4,544 2,464

2009 2010 2011 2012 2013 APR at Taylorsville, MS - Dried Resin Production (tpy) 11,118 11,816 10,260 10,862 12,349

UFC at Crossett, AR 2009 2010 2011 2012 2013 UFC Production (tpy) 9,250 16,039 15,587 13,854 12,228Attachment E

CrossettBoth process waste waters and storm waters are sent to the Complex Waste Water

Treatment System (Crossett Paper Mill).

Conway- Storm Water- Discharged via an NPDES permit

Process Water- Recycled into process or discharged via a North Carolina surface irrigation permit or disposed of off-site, depending on volumes and concentrations. Non-contact Cooling Water- Discharges via NPDES permit

Off-site disposal cost (total, including transportation) = $0.516/ gal

Taylorsville- Storm Water- Discharged via an NPDES permit

Process Water- Recycled into process or disposed of off-site, depending on
volumes. Non-contact Cooling Water- Discharges via local POTW permit

Off-site disposal cost (total, including transportation) = $0.291/ gal

Average off-site disposal cost = $0.404/gal

# Attach ment F

Page 1 Typical Start Up and Shutdown Procedure for APR Spray Dryer

Norma l S tart U p P rocedure

1. Complete pre

- start check list
2. Make sure the feed pumps have been switched

. 3. Make sure the manual air valve to the air horn in the process area is open
4. Enable shut down alarms procedure
5. Start atomizer cooling fan

6. Initiate the atomizer oil pump start
7. Once all safety interlocks are satisfied the atomizer drive motor should be started
8. Start a ir broom drive
9. Start the conveying auger
10. Start the double flap valve, scalping / sweco filter, product cyclones rotary valves, and bag house rotary valve
11. With an op of 0 on the exhaust fan damper

, start t he exhaust fan motor
12. With an o p of 0 on the product conveying fan damper

, start the product conveying fan

motor 13. With an op of 0 on the secondary fan (collecting fan) damper

, start th e secondary fan

motor
14. Increase the exhaust fan damper op increment a l l y until you reach the target negative pressures in the drying chamber and process air flow

. 15. Increase the product conveying fan damper & the secondary fan damper increment ally until both dampers are @ 100%
16. Start the combustion air blower motor
17. Start the air broom blower motor
18. Enable the purge sequence on the burner
19. Start the air disperser cooling fan motor
20. Start the packaging exhaust fan motor which will initiate the small bag house purge

sequence 21. Start rework blower motor and additive blower motor

. 22. Start rotary air lock s for additives.
23. Start both of the fines conveying blower
24. Start your bag house clean sequence

, enable the run, click to run on the sonic horns
25. From the PLC plant control computer ensure that the burner inlet controller is in manual with an op of

- 5% & the burner outlet controller will show an interlock and stay in auto.
26. Start the burner from the burner control unit, after verifying the natural gas ble ed valves are closed

– if burner fails to light refer to the burner trouble shooting sop
27. From the DCS plant control computer (still in manual) change the burner chamber inlet controller to set point on the op
28. At this point start to slowly increase the exhaust fan damper incrementally toward s the set point while increasing the burner ch amber inlet incrementally to the specified chamber outlet temperature . At this time switch your burner chamber outlet to auto and the drying chamber inlet to cascade
29. While the plant is heating up go out an d feel the three bag house venture pipes and the bottom pipe work to the four main cyclones to ensure they are hot

# Attach ment F

Page 2 30. When all of your temperatures look correct

, open the resin f eed valve, open start up water valve and start feed pump . T he feed flow should be adjusted according to which pump you are running. It will vary on amount of flow, so set your percentage at a rate that will allow the pump to run but not flood the atomize r. 31. While monitoring your burner chamber outlet, set point temperature slowly increase op on your feed pump increment ally up to the op set point

. T ry to keep your outlet temp lower than your set point on the outlet.
32. At this time you will need to open the Strahman valve

. 33. Ensure that all of your pipe work is still hot at this time go out and recheck your bag house and mai n cyclone pipe work
34. If all your pipe work checks ok shut start up water valve and open resin bottom valve to start your resin feed.

. 35. It takes a few minutes for the resin to reach the atomizer after switching from water to resin. Maintain your feed flow there until you see the temperature change indicating resin is in the drying chamber.
36. If you will be running ground resin (all grinder air supply valves shoul d already be open at this point) . O pen your bottom valve

, start grinder and set the grinder speed in accordance with the resin run spec ification sheet . O pen top valve allow the grinder to ramp up to full speed before switching the conveying auger from by pass to grinder
37. S tart to open the resin temp erature valve in auto and increase set point temp
38. While monitoring drying chamber outlet temp erature, try to keep within 4

- 5 degrees of set point
39. Also while i ncreasing your resin feed rates to the desired optimal rate, increase resin temp erature toward your set point temp erature in auto
40. After you the process has been on resin for 10 minutes

, start your additives

. 41. Once your resin feed rates and resin temp eratures are at the target points, go out and recheck your pipe work to the bag house and under the main cyclone s also recheck your bag house temperature trends chart
42. Check your resin properties on the first bag of resin that you are running and make adjustments to the process as need ed
43. After all of your resin spec ification are met, refer to your rework powder blen d rates chart and start rework unit located at product packaging with any off spec ification product at the specified rate

# Attach ment F

Page 3 Normal Shutdown Procedure

1. Once you receive the low level tank alarm @ the set point, calculate your total run time
2. When you get within 10 minutes of your switch time

, start to lower your feed rates while monitoring your b urner chamber outlet
3. Close bottom valve on resin tank and open start up water valve
4. Continue lowering resin feed rate

. Look for the temperature to drop in the drying chamber to indicate you have wat er there.
5. S witch the resin temperature control valve from auto to manual and close your strahman valve
6. If you were running the grinder, be sure to stop the conveying auger, then put the conv eying auger in bypass, close the top valve of the grinder, turn off the grinder, and shut the bottom valve of the grinder
7. Also shut off additives units, if running
8. Continue to run water for 10 minutes to clear resin through the hydro heater and atomizer while continuing to reduce feed rates
9. Exhaust fan damper should remain at set point
10. Disable resin feed pump which will shut the burner controller to low fire, then close t he resin block valve
11. disable the burner and the inlet burne r controller will switch from cascade to manual with an op

- 5 %
12. Shut the manual gas valves; open bleed valves. From this point

, start your vessel ventilation time for a minimum of 20 minutes of full process air flow to purge the system.
13. Remove each of t he ventures (one at a time) under the bag house to inspect for any build up

. S ecure after inspection
14. Allow plant to cool down for 1 hour.
15. During plant coo l down use this time to make sure that all safe work, equipment opening and confined space permits are ready for shut down.
16. At the end of cool down period shut off bag house cleaning sequence disable the run, click to stop o n the sonic horns and manual sto p 17. Disabling the exhaust fan motor will cause a shut down because of the interlock system . This involves the product conveying fan motor, collecting fan motor, combustion air blower fan motor, air broom blower motor, disperser cooling air blower motor rewo rk blower motor additive blower motor both fine conveying blowers also the packaging exhaust fan

. 18. Cl ose dampers out puts back to 0 on exhaust fan, product conveying and the secondary
19. Disable air broom drive
20. Shut off atomizer which will start the atomiz er shut down sequence
21. Atomizer oil pump will continue to run until the atomizer drive motor coast to a complete stop to prevent any damage to the atomizer during coast down
22. Stop atomizer cooling fan motor

, double flap valve

, conveying auger

, product cycl one rotary valves

, small bag house rotary valve

, scalping / sweco filter

. 23. Disable CO2 system spark/detection system panel.
24. For an extended downtime period close the manual air valve to the air horn in the process area