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 62.56
Attchment 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 12,228
Attachment 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
Attachment F

Page 1

Typical Start Up and Shutdown Procedure for APR Spray Dryer

Normal Start Up Procedure

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 air 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 the exhaust fan motor

12. With an op 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 the secondary fan 

motor

14. Increase the exhaust fan damper op incrementally 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 incrementally

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 locks 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 bleed 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 towards the

set point while increasing the burner chamber 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 and feel the three bag house venture pipes and the 

bottom pipe work to the four main cyclones to ensure they are hot 
Attachment F

Page 2

30. When all of your temperatures look correct, open the resin feed valve, open start up 

water valve and start feed pump. The 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 atomizer. 

31. While monitoring your burner chamber outlet, set point temperature slowly increase op

on your feed pump incrementally up to the op set point. Try 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 main 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 should already be open at 

this point). Open your bottom valve, start grinder and set the grinder speed in accordance 

with the resin run specification sheet. Open top valve allow the grinder to ramp up to full 

speed before switching the conveying auger from bypass to grinder 

37. Start to open the resin temperature valve in auto and increase set point temp 

38. While monitoring drying chamber outlet temperature, try to keep within 4-5 degrees of 

set point

39. Also while increasing your resin feed rates to the desired optimal rate, increase resin 

temperature toward your set point temperature 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 temperatures are at the target points, go out and 

recheck your pipe work to the bag house and under the main cyclones 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 needed

43. After all of your resin specification are met, refer to your rework powder blend rates chart 

and start rework unit located at product packaging with any off specification product at 

the specified rate
Attachment 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 burner 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 water there.

5. Switch 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 conveying 

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 the resin 

block valve

11. disable the burner and the inlet burner 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 the ventures (one at a time) under the bag house to inspect for any build up. 

Secure after inspection 

14. Allow plant to cool down for 1 hour. 

15. During plant cool 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 on the sonic horns and manual stop

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 rework blower motor 

additive blower motor both fine conveying blowers also the packaging exhaust fan.

18. Close 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 atomizer 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 cyclone 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