MIDWEST
RESEARCH
INSTITUTE
Crossroads
Corporate
Park
5520
Dillard
Road
Suite
100
Cary,
North
Carolina
27511­
9232
Telephone
(
919)
851­
8181
FAX
(
919)
851­
3232
Date:
May
28,
2002
Subject:
Site
Visit­­
Georgia­
Pacific
Oriented
Strandboard
Plant
in
Brookneal,
Virginia
Plywood
and
Particleboard
MACT
Standard
EPA
Contract
No.
68­
D6­
0012;
Task
Order
No.
0017;
ESD
Project
No.
95/
11
MRI
Project
No.
104804.1.068
From:
Melissa
Icenhour,
MRI
Rebecca
Nicholson,
MRI
To:
Mary
Tom
Kissell
OAQPS/
ESD/
WCPG
(
C439­
03)
U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
27711
I.
Purpose
The
purpose
of
the
site
visit
to
the
Georgia­
Pacific
oriented
strandboard
(
OSB)
manufacturing
plant
in
Brookneal,
Virginia
was
to
collect
any
new
information
from
the
plant
since
a
previous
visit
by
EPA
representatives
on
March
11,
1998,
and
to
listen
to
Georgia­
Pacific
personnel's
ideas
on
alternatives
for
determining
the
capture
efficiency
of
full
and
partial
press
enclosures.
The
information
gathered
during
this
site
visit
will
be
used
in
the
development
of
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP)
for
the
plywood
and
composite
wood
products
(
PCWP)
manufacturing
industry.

II.
Place
and
Date
Georgia­
Pacific
Corporation
U.
S.
Highway
501
South
Gladys,
Virginia
24554
July
19,
2001
III.
Attendees
Georgia­
Pacific
Corporation
Paul
Vasquez,
Manager
of
Environmental
Engineering,
Building
Products
Wayne
Bales,
Plant
Operations
Manager
2
Mike
Robertson,
Environmental
Manager
Kenny
Richardson,
Safety
Manager
Virginia
Department
of
Environmental
Quality
(
VADEQ)

Craig
Nicol,
Compliance
Enforcement
Specialist
Sr.

U.
S.
Environmental
Protection
Agency
Mary
Tom
Kissell,
Environmental
Engineer
Candace
Sorrell,
Environmental
Engineer,
Emission
Measurement
Center
(
EMC)

Midwest
Research
Institute
(
MRI)

Melissa
Icenhour,
Environmental
Engineer
Rebecca
Nicholson,
Manager
of
Environmental
Engineering
Section
IV.
Discussion
A.
Background
Oriented
strandboard
is
a
sheathing,
roofing,
and
flooring
material
constructed
from
wood
flakes
which
are
blended
with
resin,
formed
into
a
layered
mat,
pressed,
and
trimmed
to
size.
The
Georgia­
Pacific
OSB
plant
in
Brookneal,
Virginia,
began
operation
in
1992.
In
2000,
the
plant
produced
407
million
square
feet
(
MMSF)
of
OSB
(
0.375­
inch
basis).
The
plant
has
a
rated
capacity
of
325
MMSF
(
0.375­
inch
basis);
however,
because
the
rated
capacity
is
a
conservative
estimate
of
the
plant's
actual
capacity,
the
plant
is
permitted
for
a
maximum
production
rate
of
424
MMSF
(
0.375­
inch
basis)
per
year.
The
plant
employs
a
total
of
130
people.

Because
this
plant
was
visited
in
1998,
the
remainder
of
this
trip
report
will
deal
with
changes
made
at
the
plant
following
that
visit.
For
more
information
on
the
process,
refer
to
document
II­
B­
16
in
Docket
A­
98­
44.

B.
Process
The
main
changes
in
the
OSB
production
process
since
1998
involve
the
raw
materials
and
the
drum
dryers.
The
Brookneal
plant
uses
approximately
70
percent
southern
pine
and
30
percent
soft
hardwoods
for
production
of
OSB.
This
is
in
contrast
to
the
50
percent
southern
pine
and
50
percent
soft
hardwoods
that
was
used
in
1998.
The
plant
now
operates
three
triplepass
rotary
drum
dryers
that
can
each
process
approximately
58,000
pounds
per
hour
(
lb/
hr)
of
green
flakes.
The
increase
of
8,000
lb/
hr
from
1998
is
due
to
the
addition
of
new
15
million
Btu
gas
rings.
3
C.
Control
of
Emissions
from
the
Press
1.
Background.
In
December
of
1997,
the
Brookneal
plant
installed
an
enclosure
around
the
hot
press
area
and
installed
a
Smith
Engineering
thermal
catalytic
oxidizer
(
TCO)
to
control
press
emissions.
Prior
to
the
TCO,
there
is
a
drop­
out
box
for
particulates.
However,
very
little
particulate
accumulates,
so
the
drop
box
only
requires
a
once­
per­
year
cleaning.
The
maintenance
of
the
TCO
requires
a
scheduled
shutdown
once
or
twice
a
year,
and
yearly
samples
of
catalytic
media
are
taken
to
determine
the
catalytic
activity.

2.
TCO.
The
TCO
was
selected
as
the
most
adequate
control
equipment
to
control
the
precipitation
of
pitch
and
waxes.
It
was
originally
installed
on
the
press
exhaust
to
control
condensible
materials
that
were
depositing
on
employees'
vehicles.
Other
control
technologies,
such
as
low­
and
high­
energy
scrubbers
and
a
wet
electrostatic
precipitator,
were
considered
and
evaluated.
These
technologies
were
rejected
because
of
the
estimated
amount
of
wastewater
to
be
generated.
In
addition
to
controlling
the
condensible
materials,
the
TCO
has
a
VOC
destruction
efficiency
of
about
94.1
percent
based
on
stack
tests
conducted
in
1996
and
1997.
The
TCO
was
not
selected
based
on
any
BACT
analysis.

The
set
temperature
in
the
TCO
combustion
chamber
is
used
to
monitor
and
control
the
operation
of
the
TCO.
The
TCO
has
five
thermocouples
used
to
monitor
temperature.
These
thermocouples
are
located
between
each
of
the
six
canisters.
Plant
personnel
determine
a
15­
minute
average
and
an
hourly
average
operating
temperature
for
the
TCO
by
averaging
the
readings
from
all
of
the
thermocouples.
The
individual
temperature
readings
from
these
thermocouples
may
vary
by
as
much
as
50

F,
because
one
canister
is
always
in
the
cooling
mode,
and
thus
has
a
lower
temperature
than
the
others.
However,
the
average
temperature
does
not
vary
much.

3.
Press
Enclosure.
When
designing
the
press
enclosure,
Georgia­
Pacific
had
to
include
the
loader,
press,
and
unloader
in
the
enclosure
because
of
the
tight
spacing
between
each
piece
of
equipment.
Other
companies
may
not
include
all
press­
related
equipment
in
the
enclosure,
but
either
type
of
enclosure
needs
openings
to
allow
the
boards
to
pass
through.
Some
companies
choose
to
install
high­
speed
"
garage
doors"
which
open
and
close
to
allow
product
through
the
enclosure.

The
Brookneal
enclosure
was
installed
by
the
same
company
that
installed
the
TCO.
The
walls
of
the
enclosure
are
corrugated
metal,
which
is
typical
of
most
press
enclosures
at
Georgia­
Pacific
plants.
The
capital
cost
of
these
types
of
enclosures
is
typically
$
1.00
to
$
1.70
per
actual
cubic
foot
per
minute
(
acfm)
of
press
exhaust.
Georgia­
Pacific
used
insulating
foam
to
fill
gaps
in
the
metal
walls
and
replaced
the
ill­
fitting
access
doors
with
new
ones.

The
requirements
regarding
press
enclosures
vary
from
state
to
state.
The
Brookneal
press
is
required
to
be
enclosed,
but
is
not
required
to
meet
EPA
Method
204,
although
the
enclosure
meets
most
of
these
design
requirements.
Plant
personnel
have
expressed
concerns
with
the
concentration
of
fumes
in
the
upper
corners
of
the
enclosure
and
the
subsequent
leakage
of
the
fumes
from
the
enclosure
to
the
building.
According
to
a
Georgia­
Pacific
analysis,
the
upper
4
portion
of
the
enclosure
is
pressurized,
which
causes
the
fumes
to
leak
through
small
openings
and
gaps.

4.
Concerns
of
Measuring
Capture
Efficiency
for
the
Press
Enclosure.
EPA
Method
204
(
Criteria
for
and
Verification
of
Permanent
or
Temporary
Total
Enclosure)
can
be
used
to
determine
the
capture
efficiency
of
press
enclosures
at
PCWP
plants.
If
the
enclosure
meets
the
criteria
in
EPA
Method
204
for
a
permanent
total
enclosure
(
PTE),
then
its
capture
efficiency
is
assumed
to
be
100
percent.
If
the
enclosure
is
not
a
PTE,
then
a
temporary
total
enclosure
(
TTE)
must
be
constructed
around
the
press
and
the
capture
efficiency
of
the
TTE
determined
according
to
the
procedures
in
EPA
Method
204.
Georgia­
Pacific
personnel
stated
that
EPA
Method
204
was
developed
for
applications
where
emission
gases
have
similar
physical
properties
such
as
temperature
and
density.
According
to
a
Georgia­
Pacific
analysis,
the
temperature
and
density
of
gases
change
as
the
OSB
press
opens
and
closes,
creating
layers
of
gases
with
different
physical
properties.
Other
layers
of
gases
with
different
physical
properties
are
also
introduced
by
the
fresh
air
and/
or
heat
radiated
from
hot
pipes
in
the
press
pit
area,
which
is
located
beneath
the
press.
The
interaction
between
the
layers
of
gases
results
in
the
formation
of
a
neutral
pressure
zone,
which
fluctuates
between
the
middle
and
upper
section
of
the
hot
press.
In
a
heated
enclosure,
the
area
above
the
neutral
line
is
at
a
higher
pressure
than
the
bottom
of
the
enclosure.
The
top
of
the
enclosure
also
has
a
higher
pressure
than
the
air
outside
the
enclosure,
whereas
the
bottom
of
the
enclosure
has
a
lower
pressure
than
the
outside
of
the
enclosure.
The
variation
in
pressure
and
temperature
between
the
layers
of
gases
prevents
them
from
mixing,
moving,
and
exiting
the
enclosure.
Georgia­
Pacific
personnel
believe
that
this
can
cause
an
increased
concentration
of
fumes,
dust,
wax,
oil,
and
hazardous
substances
which
could
create
a
hazardous
environment
for
employees
working
inside
the
enclosure.

To
study
this
phenomenon,
one
of
the
Brookneal
process
engineers
built
a
small­
scale
version
of
the
press
enclosure
and
used
it
to
simulate
press
heat
generation.
Emissions
were
also
simulated
using
smoke.
The
small
scale
study
indicated
that
Georgia­
Pacific
would
need
to
increase
the
airflow
through
the
press
enclosure
about
three
to
five
times
higher
than
the
existing
flow
rate
in
order
to
effectively
evacuate
the
enclosure.

As
an
alternative
to
increasing
the
flow,
the
press
pit
was
examined
for
possible
design
changes.
If
this
source
of
heat
could
be
lessened,
Georgia
Pacific
personnel
believe
that
the
temperature
inversion
problems
also
could
be
lessened.
The
press
pit,
which
slopes
to
a
depth
of
26
feet
below
the
press,
is
shown
in
Figure
1.
This
depth
allows
adequate
space
for
the
press
to
fully
open
and
also
contains
the
thermal
oil
pipe
network
necessary
to
heat
the
press.
To
lessen
the
temperature
inversion
problems,
engineers
tried
to
insulate
the
thermal
oil
pipes
to
reduce
heat
loss
into
the
press
enclosure.
Since
the
pipes
reach
temperatures
between
400

and
500

F
and
the
pipes
flex
during
the
pressing
operation,
finding
an
insulation
to
meet
both
demands
has
been
unsuccessful.

During
evaluations
of
a
partial
enclosure
designed
for
a
multiple
opening
press
at
another
OSB
facility,
Georgia­
Pacific
Corporation
employees
determined
that
effective
evacuation
of
the
gases
within
the
partial
enclosure
could
be
accomplished
by
using
a
hood
design
configuration
that
encapsulates
the
hot
plates
of
the
press
from
top
to
bottom,
thus
allowing
the
mixing
of
the
5
26
feet
Press
pit
thermal
oil
Unloader
Press
Loader
boards
3
press
vents
per
side
Figure
1.
Brookneal
Press
Pit
Area
cooler
air
with
the
hotter
air,
reducing
the
temperature
differential.
This
also
results
in
less
heat
rise
affect,
less
pressure
difference,
and
more
efficient
exhaust.
Visual
observations
of
the
partial
press
enclosure
indicate
no
visible
gases
escape
from
the
bottom
of
the
hood.
Although
these
are
valid
results
for
the
partial
enclosure,
this
OSB
facility
is
located
in
another
state,
and
press
enclosure
requirements
vary
from
state
to
state.
Some
states
require
press
enclosures
to
meet
EPA
Method
204
criteria,
and
other
states
may
only
require
a
"
smoke
test"
to
demonstrate
that
the
enclosure
is
working
properly.

Georgia­
Pacific
Corporation
plans
to
conduct
the
necessary
computational
models
and
gas
trace
analysis
to
determine
the
capture
efficiency
of
the
partial
enclosure
design.
In
addition,
Georgia­
Pacific
Corporation
and
independent
engineering/
software
companies
are
exploring
the
technical
feasibility
of
alternate
designs
using
computation
fluid
dynamics
for
modeling
the
enclosures.

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