Document NdMaXYv0eZ7RX517oMMmpGrQ

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Bell Lumber and Pole Company, New Brighton, Minnesota Carlo Demma, Physical Scientist AECAB (MN/OH) Brian Dickens, Section Supervisor AECAB (MN/OH) File BASIC INFORMATION Facility Name: Bell Lumber and Pole Co. Facility Location: 778 1st St NW, New Brighton, MN 55112 Date of Inspection: April 29, 2022 EPA Inspector(s): 1. Carlo Demma, Physical Scientist (Air) 2. Tess Russell, Environmental Engineer Other Attendees: 1. Jennifer Carlson, Environmental Specialist, Minnesota Pollution Control Agency (MPCA) Air Compliance Unit 2. Brittney Fyock, Environmental Specialist, MPCA Air Compliance Unit 3. Brian Stepaniak, Environmental Health & Safety Manager, Bell Lumber and Pole 4. Kyle Nowatzke, Plant Manager, Bell Lumber and Pole 5. Forrest Shultz, Director of Research and Development, Bell Lumber and Pole 6. Shannon Froiland, Environmental Engineer, GHD (Consultant) Contact Email Address: Brian.Stepaniak@blpole.com Purpose of Inspection: EPA conducted this inspection to assess compliance with good air pollution control practices for minimizing air emissions found at 40 C.F.R. 63.6(e)(1) and NESHAP QQQQQQ. Facility Type: Wood Preserving Regulations Central to Inspection: Bell Lumber and Pole's wood preserving operation, specifically the pressure treating cylinders and preservative usage, is subject to the wood preserving requirements of Subpart 40 C.F.R. Part 63 Subpart QQQQQQ. Bell Lumber and Pole is also subject to 40 C.F.R. 63.6(e)(1) in Subpart A of the General Provisions of the CAA. Arrival Time: 8:15 AM CST Departure Time: 12:30 PM CST Inspection Type: Unannounced Inspection Announced Inspection OPENING CONFERENCE Presented Credentials Stated authority and purpose of inspection Provided Small Business Resource Information Sheet Small Business Resource Information Sheet not provided. Reason: Not a small business. Provided CBI warning to facility The following information was obtained verbally from Kyle Nowatzke, Brian Stepaniak, and Forrest Shultz unless otherwise noted. Process Description: Bell Lumber and Pole Company (Bell Pole) pressure treats wood utility poles, lumber, larch, and laminated wood products on a batch basis with a solution of a proprietary co-solvent, pentachlorophenol (PCP), and No. 2 diesel fuel. The facility has approximately 60 employees and treats wood products on a 24/7 basis. The yard operations are daily from 5:00AM until midnight, and framing operations are 5:00AM until 2:00AM. Bell Pole indicated that business has increased significantly since the price and demand for wood products has risen. Kyle Nowatzke identified red pine as the facility's current highest production wood type. Raw materials arrive onsite via truck and are stored in the yard in bunks. A shaver shaves a thin layer of wood off the poles before they go to framing, where poles are cut to length and drilled with holes to improve the efficacy of the treatment process. The poles may also be heated in one of two kilns, but not always. Then the poles go through the pressure treatment process in one of two treatment cylinders, to a drip pad in the treatment building, through QAQC checks, and either back to storage in the facility's bunks or shipped out to customers. Staff Interview: EPA was informed Bell Pole performs odor tests on a regular basis, though no timeframe was specified. The company informed EPA that the wood preserving industry is shifting away from the use of PCP, but that Bell Pole has enough PCP to potentially last several more years. The Page 2 of 7 company stated that DCOI (4,5-Dichloro-2-n-Octyl4-Isothiazolin-3-One) is being targeted as the next chemical to replace PCP. DCOI is a non-restricted use pesticide as compared to PCP which has been designated as restricted use since 1984. After the pressure treatment process, initial vacuum is applied to the cylinder. The cylinder door will not open until the 90-minute final vacuum process is completed. Emissions enter the product recovery system (PRS) consisting of a condenser and a scrubber. Bell Pole utilizes a "Crack and Vac" procedure after the final vacuum where the tank door is cracked slightly, and vacuum is applied for an additional 30 minutes. There is a hood directly above the cylinder door to capture any air emissions from the opening of the cylinder, and a drip pad directly below; the hood vents to the atmosphere with no air pollution controls. The condenser in the PRS runs only when vacuum is being pulled through the cylinder. Condensate is sent to a decant tank where separation processes separate oil to be re-used in the treatment process and non-oil waste liquid to go to wastewater treatment. The facility measures the quantity of condensate produced, and potentially the temperature of the exhaust downstream of the condenser, but facility representatives were unaware of other condenser parameters monitored on a regular basis. The condenser is not steam injected. Emissions from the condenser are routed to a recently replaced diesel scrubber at the roof of the treatment building. A dissolver tank is located in the mixing room where Bell Pole drops 2000-pound blocks of PCP twice a day. The PCP is agitated, and heat is applied; Diesel No 2 is also added along with proprietary co-solvent. Emissions from the dissolver tank are routed to the scrubber, but not first through the condenser. The company stated that a rubber seal which seals the mixing tank commonly becomes compromised and is regularly changed, on a one to six-month basis, but only after it fails. When the rubber gasket seal is broken all members of Bell Pole team in attendance stated, "you can smell it". Bell Pole is not required by any air permit to run the scrubber, but the facility's Management Plan requires the vapor recovery system (including the scrubber) to be in operation during the treatment process. Thus, Bell Pole's operating procedure is to immediately stop work if the scrubber fails or stops working. It was noted that un-controlled passive VOCs are emitted if the scrubber is turned off. Above the scrubber, the facility representatives mentioned there is a "damper" which has not been used in several years; it is not required by any permit. The facility does not deem it cost-effective to fix and bring the damper back into operation. The damper could be used to disperse the scrubber emissions higher into the air. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA parked the government vehicle at 840 2nd St. NW, New Brighton MN 55112, approximately 0.06 miles due west of the Bell Pole treatment building at the entry of the neighborhood to perform an observational smell test. It was 8:15 AM CST and ambient conditions were as follows: Temperature of 47F, Wind 11 Mph from the East/Southeast, Dew Page 3 of 7 Point 39, Humidity 72%, Pressure 29.95 (in). EPA immediately noted odors when downwind of the facility. EPA noted a smell of lacquer strong enough to irritate one's throat with mouth closed. EPA observed the same strong odors while inside the treatment building. When EPA parked in the guest parking lot at 8:30 AM, EPA observed large amounts of dust being generated by the Pettibone machine. Wind speeds were at 11 Mph from the East/Southeast. EPA inspected the following emission units while on site: pole shaver, two kilns, two oil heaters, cylinder 1, partial cylinder 2, and oil decant tank 1. EPA inspected the following Emissions Controls: cyclone, condenser 1, HVAC secondary building (roof) air filters, and the scrubber. Cylinder #2 was down at the time of the inspection due to a reoccurring failure of the cylinder's vacuum pump and the installation of two new valves. While Cylinder 1 was operating, the scrubber was at 13 psi and the condenser temperature was 109F. Inside the treatment building near the loading area for Cylinder 1, EPA observed one major section of the building's HVAC was damaged and nearly completely severed, yet Bell Pole still had air flow running through it. No temporary duct tape was affixed to the damaged duct work. Carbon filter air panels that were originally affixed to the treatment building's air filtration system were all removed. The carbon air filters were listed in a permit application form dated 1996. NESHAP QQQQQQ requires Bell Pole to operate the treatment process according to a management practice plan to minimize air emissions. EPA observed several poor housekeeping procedures which included: leaving entry and exit doors open which led into the treatment building, leaving the garage door in the tram transfer bay open, multiple holes in the treatment building's exterior walls, and oily rags left laying on equipment. EPA observed a leaking joint on a section of pipe directly affixed to the top of Cylinder 1 with the FLIR camera. Cylinder 1 was in an active charge mode. Bell Pole indicated to EPA that it may be a pressure return line, but that they were not sure. Inside the tram transfer bay in the treatment building, EPA observed a major spill of treatment product. Bell Pole informed EPA that it had been like this for approximately seven days. The primary containment drip pad below Cylinder 2 was completely submerged in treatment product. The tram transfer bay area has several large runners going across the length of the ground and in those runners are small holes where product spills are channeled down the length of the transfer bay. EPA's photograph clearly shows a dark stain or sludge line above the level of the current spill. EPA observed recently treated poles emanating fugitive organic material emissions with the FLIR Camera. The poles were no longer on the drip pad and were moved to the adjacent rail line for transport out of the treatment building. Bell Pole's plant manager told EPA the poles were removed from the drip pad approximately 3 hours earlier; the standard is to remove them from the drip pad is after the last drip. Page 4 of 7 EPA performed USEPA Method 082 on the fugitive emissions from the shaver. The shaver was not routing to the cyclone since it was routing to an enclosed trucking container. EPA observed no visible emissions from the shaver while it was being operated in this fashion. Results were 0% opacity over a six-minute average. Photos and/or Videos: were taken during the inspection. FLIR Infrared Thermal Imaging. Field Measurements: were taken during this inspection. Observational Odor Test (smell test). USEPA Method 082 Visible Emission Observations. CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: A copy of the agreement (MOU) with the City of New Brighton from November 13, 2007, regarding "legal non-conforming use". The results of the (new) scrubber efficiency test mentioned during the inspection (estimated date, Oct 2021). Manufacturer's specifications for the scrubber. Any maintenance logs indicating when maintenance is performed/leaks are addressed on the dissolver/mixing tank. Confirmation of the date of the latest stack test and conformation of the installation of the second cylinder. All documentation determining use of activated carbon air filters was no longer necessary and specify the date Bell removed them. The latest Management Practice Plan which details minimization of air emissions as required by NESHAP QQQQQQ and any other Operation Plan(s) that might be referenced in it, including but not limited to the Facility's SPCC Plan and the Facility's Contingency Plan. Provide Charge Records for the year-to-date for each cylinder with information including but not limited to: wood type, amount of preservative used, and pressure readings inside the cylinder. A statement regarding the spill USEPA observed in the loading area near Cylinder 2 and any corrective actions taken since EPA was on site. Copy of SDS sheets for compounds used to create formula for wood treating. Concerns: MPCA instructed the facility to control fugitives from the roadways through water application, when needed; MPCA suggested the facility maintain a speed limit for moving vehicles and a record of when and how much water is applied to control roadway fugitive emissions. EPA expressed concerns regarding Bell Pole's removal of the activated carbon filters from the wood treatment building's HVAC, and the damaged HVAC vent. EPA expressed the poor housekeeping procedures concerns to Bell Pole during the site tour. EPA expressed Page 5 of 7 concern regarding the leaking joint on Cylinder 1 during the site tour. EPA expressed concerns that any spills, but especially those dealing with preservative from the pressure cylinders, should be cleaned up promptly according to NESHAP QQQQQQ. DIGITAL SIGNATURES CARLO Digitally signed by CARLO DEMMA Report Author: _D_E__M__M___A________-_0_5'0_0_' ____________ Date: 2022.06.09 08:06:27 Section Supervisor: Digitally signed by Brian Brian Dickens Date: 2022.06.09 09:41:17 Dickens __________________-0_5_'0_0'_____________ Page 6 of 7 Facility Name: Bel Lumber and Pole Company Facility Location: 778 First Street Northwest Date of Inspection: April 29, 2022 APPENDICES AND ATTACHMENTS 1. Appendix A: Photo and Video Log 2. Appendix B: Field Measurement Data Page 7 of 7 Facility Name: Bell Lumber and Pole Company Facility Location: 778 First Street Northwest Date of Inspection: April 29, 2022 APPENDIX A: DIGITAL IMAGE AND VIDEO LOG 1. Inspector Name: Carlo Demma 2. Archival Record Location: ERC Enf_BellLumber&pole_MN_22_InspectionReport Image Number 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 File Name IMG_3042.JPG IMG_3043.JPG IMG_3044.JPG IMG_3045.JPG IMG_3046.JPG IMG_3047.JPG IMG_3048.JPG IMG_3049.JPG IMG_3050.JPG IMG_3051.JPG IMG_3052.JPG IMG_3053.JPG IMG_3054.JPG IMG_3055.JPG IMG_3056.JPG IMG_3057.JPG IMG_3058.JPG IMG_3059.JPG IMG_3060.JPG IMG_3061.JPG Date and Time (incl. Time zone and DST) 2022:04:29 08:59:30 2022:04:29 09:41:37 2022:04:29 09:41:45 2022:04:29 09:48:11 2022:04:29 09:51:08 2022:04:29 09:51:11 2022:04:29 09:56:10 2022:04:29 09:56:15 2022:04:29 10:01:34 2022:04:29 10:07:30 2022:04:29 10:15:12 2022:04:29 10:21:14 2022:04:29 10:29:17 2022:04:29 10:29:22 2022:04:29 10:29:32 2022:04:29 10:36:21 2022:04:29 10:36:29 2022:04:29 10:37:57 2022:04:29 10:38:02 2022:04:29 10:39:28 Description of Image Process flow diagram Road dust_1 Road dust_2 Treated laminated wood Untreated lumber and poles_1 Untreated lumber and poles_2 Bell Pole tag_1 Bell Pole tag_2 Oil decant tank #1 Recovery system control program Condenser #1 drain valve Drip tray and drip pads under leaky equipment Leaking joint off Cylinder #1 Leaking joint off Cylinder #1_2 Leaking joint off Cylinder #1_3 Cylinder #1 Door Open loadout door Treatment product spill_1 Treatment product spill_2 Pole drip pad Appendices Page 1 of 5 Facility Name: Bell Lumber and Pole Company Facility Location: 778 First Street Northwest Date of Inspection: April 29, 2022 21 IMG_3062.JPG 2022:04:29 11:06:56 22 IMG_3063.JPG 2022:04:29 11:07:11 23 IMG_3064.JPG 2022:04:29 11:07:26 24 IMG_3065.JPG 2022:04:29 11:07:41 25 IMG_3066.JPG 2022:04:29 11:07:56 26 IMG_3067.JPG 2022:04:29 11:08:11 27 IMG_3068.JPG 2022:04:29 11:08:26 28 IMG_3069.JPG 2022:04:29 11:08:41 29 IMG_3070.JPG 2022:04:29 11:08:56 30 IMG_3071.JPG 2022:04:29 11:09:11 31 IMG_3072.JPG 2022:04:29 11:09:26 32 IMG_3073.JPG 2022:04:29 11:09:41 33 IMG_3074.JPG 2022:04:29 11:09:56 34 IMG_3075.JPG 2022:04:29 11:10:11 35 IMG_3076.JPG 2022:04:29 11:10:26 36 IMG_3077.JPG 2022:04:29 11:10:41 37 IMG_3078.JPG 2022:04:29 11:10:56 38 IMG_3079.JPG 2022:04:29 11:11:11 39 IMG_3080.JPG 2022:04:29 11:11:26 40 IMG_3081.JPG 2022:04:29 11:11:41 41 IMG_3082.JPG 2022:04:29 11:11:56 42 IMG_3083.JPG 2022:04:29 11:12:11 43 IMG_3084.JPG 2022:04:29 11:12:26 44 IMG_3085.JPG 2022:04:29 11:12:41 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 Appendices Page 2 of 5 Facility Name: Bell Lumber and Pole Company Facility Location: 778 First Street Northwest Date of Inspection: April 29, 2022 45 IMG_3086.JPG 2022:04:29 11:12:56 46 IMG_3087.JPG 2022:04:29 11:13:11 47 IMG_3088.JPG 2022:04:29 11:13:26 48 IMG_3089.JPG 2022:04:29 11:13:41 49 IMG_3090.JPG 2022:04:29 11:13:56 50 IMG_3091.JPG 2022:04:29 11:14:11 51 IMG_3092.JPG 2022:04:29 11:14:26 52 IMG_3093.JPG 2022:04:29 11:14:41 53 IMG_3094.JPG 2022:04:29 11:14:56 54 IMG_3095.JPG 2022:04:29 11:15:11 55 IMG_3096.JPG 2022:04:29 11:15:26 56 IMG_3097.JPG 2022:04:29 11:15:41 57 IMG_3098.JPG 2022:04:29 11:15:56 58 IMG_3099.JPG 2022:04:29 11:16:11 59 IMG_3100.JPG 2022:04:29 11:16:26 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 USEPA Method 082 Appendices Page 3 of 5 Facility Name: Bell Lumber and Pole Company Facility Location: 778 First Street Northwest Date of Inspection: April 29, 2022 INFRARED OPTICAL GAS IMAGING LOG 1. Inspector Name: Tess Russell 2. Archival Record Location: ERC Enf_BellLumber&pole_MN_22_InspectionReport Image Number 1 2 3 4 5 6 7 8 9 10 11 12 File Name MOV_0260.mp4 MOV_0261.mp4 MOV_0262.mp4 MOV_0263.mp4 MOV_0264.mp4 MOV_0265.mp4 MOV_0266.mp4 MOV_0267.mp4 MOV_0268.mp4 MOV_0269.mp4 MOV_0270.mp4 MOV_0271.mp4 Date and Time (incl. Time zone and DST) 5/4/2022 11:53 5/4/2022 11:53 5/4/2022 11:53 5/4/2022 11:54 5/4/2022 11:54 5/4/2022 11:54 5/4/2022 11:54 5/4/2022 11:54 5/4/2022 11:54 5/4/2022 11:54 5/4/2022 11:54 5/4/2022 11:54 Description of Video Side vent off the wood treatment building Condenser and condensate collector for Cylinder 1 Drip pad between Cylinder 1 and associated Work Tank Leaking gasket atop Cylinder 1 Leaking gasket atop Cylinder 1 (2) Cylinder 1 door Spill in wood treatment building Spill in wood treatment building (2) Drying poles in wood treatment building Vent from wood treatment building Vent from wood treatment building Top of wood preserving building - scrubber stack Appendices Page 4 of 5 Facility Name: Bell Lumber and Pole Company Facility Location: 778 First Street Northwest Date of Inspection: April 29, 2022 APPENDIX B: FIELD MEASUREMENT DATA Attachment A VISIBLE EMISSION OBSERVATION FORM Form Number Page of Method Used Alternative Method 082 Equipment Digital Opacity Camera #2 Facility Name Bell Lumber and Pole Company EO Street Address 778 First Street Northwest EO City EO State New Brighton MN Process Wood Shaving Control Equipment Cyclone Unit Shaver Describe Emission Point Saw dust Continued on VEO Form Number Observation Date 4/29/2022 Time Zone CST 1 EO Zip 55112 2 0 0 0 0 Operating Mode 3 0 0 0 0 N/A 4 0 0 0 0 Operating Mode N/A 5 0 0 0 0 6 0 0 0 0 7 0 0 0 0 8 Wind Dir 9 Southeast 10 Vertical Angle to Obs, Pt. Direction to Obs. Pt 11 Start 5.41 End Same Start 86.9 End Same 12 Distance and Direction to Observation Point from Emission Point Start 348.71 / 9.9 End Same 13 Describe Emissions Start Brown Particles End Same 14 Emission Color Start Dust End Same Water Droplet Plume 15 Attached: ( ) Detached: ( ) N/A: ( X ) 16 Describe Plume Background Start White Truck End Same 17 Background Color Sky Conditions 18 Start Gray End Same Start Overcast End Same 19 Wind Speed Wind Direction Start 11 End Same Start 270 End Same 20 Ambient Temp. Wet Bulb Temp. RH Percent Start 50 End Same Start 37.66 End Same Start 31 End Same 21 22 23 24 25 26 27 Start Time 11:06:08 Comments End Time 11:12:08 6-minute avg = 0% Observers Name (Print) Carlo Demma Observers Signature Carlo Demma Organization USEPA Certified By CJD Date 04/29/2022 Date 4/29/2022 Longitude 45.03.06565 Latitude 093.11.49848 Declination Appendices Page 5 of 5