Document mp1vJ84V9J3kyY3rjLwN5yRgk

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 5 77 WEST JACKSON BOULEVARD CHICAGO, ILLINOIS 60604 SUBJECT: FROM: THRU: TO: CLEAN AIR ACT INSPECTION REPORT Stella-Jones Corporation, Bangor, Wisconsin Dakota Prentice, Environmental Engineer AECAB (IL/IN) Nathan Frank, Section Supervisor AECAB (IL/IN) File BASIC INFORMATION Facility Name: Stella-Jones Corporation Facility Location: W1038 County Road U, Bangor, Wisconsin Date of Inspection: March 23, 2022 EPA Inspector(s): 1. Dakota Prentice, Environmental Engineer 2. Vicky Mei, Environmental Engineer 3. Tess Russell, Environmental Engineer Other Attendees: 1. Alex Clark, Stella-Jones - Environmental Manager (via phone) 2. Ryan Peterson, Stella-Jones - Plant Manager 3. Kyle Thompson, Stella-Jones - Safety Supervisor 4. Amy Werlein, Stella-Jones - EH&S Supervisor (via phone) 5. Jordan Haines, Stella-Jones - Treatment Supervisor Contact Email Address: Amy Werlein - awerlein@stella-jones.com Purpose of Inspection: to determine compliance with operating permits issued by the Wisconsin Department of Natural Resources and the Wisconsin state implementation plan. Facility Type: Treated Railway Tie Manufacturing Regulations Central to Inspection: The facility is subject to state implementation plan and operating permit requirements. Arrival Time: 8:50AM Departure Time: 11:20AM 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. Provided CBI warning to facility The following information was obtained verbally from Stella-Jones representatives unless otherwise noted. Process Description: Treated railway tie manufacturing begins with the delivery of wood via rail and truck from multiple sawmills. The facility manufactures the rail ties from hardwoods. The wood is cut to size for use as either a switch tie or a cross tie at onsite sawmills. The cut wood is then allowed to air dry onsite for an extended period. Although most wood is air dried prior to processing, some "green wood" or nonair dried wood is processed and treated at the facility. The facility has three treatment cylinders. Wood first enters a treatment cylinder to undergo either a rouping or boulton process. The rouping process is for wood that has been air dried, while the boulton process is for green wood. The boulton process uses vacuum and heat in the presence of a creosote/oil mixture to start the process, after which, the wood is handled in the same way as the air-dried wood through the rouping process. In the rouping process, the wood is exposed to elevated temperatures and pressures both with and without the cylinder being filled with the creosote/oil mixture. The process is completed after a final vacuum is applied to the cylinder after the creosote/oil mixture has been pumped out. The treated ties are then set briefly on a drip pad prior to going to storage for shipment to customers. Staff Interview: Each treatment cylinder has a dedicated work tank that holds the creosote/oil mixture used in that treatment cylinder. As the creosote/oil mixture is pumped from the work tank to the cylinder, displaced gas in the cylinder is sent to the work tank. The displaced gas after the work tanks is routed to a common knock-out tank before being vented to the atmosphere. When the cylinders are in a vacuum phase of the treatment cycle, emissions are routed to a boulton tank where oil and vapors separate. The vapors are sent to a condenser that sends liquid to the wastewater treatment plant. At Page 2 of 4 the treatment plant, the water goes through a product recovery step, consisting of oil separation and recovery, then to a pretreatment process, and finally to evaporators. TOUR INFORMATION EPA Tour of the Facility: Yes Data Collected and Observations: EPA walked the facility and observed a sawmill, the treatment cylinders, work tanks, and the wastewater treatment plant. At the work tanks, which are located indoors, EPA accessed the roof and observed that a modification has been made to how these units are vented to the atmosphere. A stack that historically had been the emission point for all the tanks had been capped to allow for these emissions to travel through a recently installed knock-out tank prior to venting to the atmosphere. Photos and/or Videos: were taken during the inspection. See Appendix A and B Field Measurements: were not taken during this inspection. RECORDS REVIEW 1. Plant diagram (copy obtained) 2. Two charge reports (copies requested) CLOSING CONFERENCE Provided U.S. EPA point of contact to the facility Requested documents: Permit application for construction of Cylinder No. 3 Most recent permit application for operating permit Creosote and oil usage - five years of data Cubic feet of railway tie production - five years of data Pressure drop reading at sawmill cyclones - last six months of data Charge reports reviewed during inspection Temperature records associated with the condenser - six months of data DIGITAL SIGNATURES DAKOTA Digitally signed by DAKOTA PRENTICE Date: 2022.04.08 Report Author: ______P_R__E_N__T_IC__E___1_5_:11_:2_8_-0_5'0_0_' _______ Section Supervisor: Frank, Digitally signed by Frank, Nathan N__a_t_h_a_n_______1_3:_13_:0_3 -_05_'0_0'______________ Date: 2022.04.13 Page 3 of 4 Facility Name: Stella-Jones Corporation Facility Location: W1038 County Road U, Bangor, Wisconsin Date of Inspection: March 23, 2022 APPENDICES AND ATTACHMENTS Appendix A - Digital Image Log Appendix B - Digital Video Log Page 4 of 4 Facility Name: Stella-Jones Corporation Facility Location: W1038 County Road U, Bangor, Wisconsin Date of Inspection: March 23, 2022 APPENDIX A: DIGITAL IMAGE LOG 1. Inspector Name: V. Mei Image Number 1 2 3 4 File Name IMG_0012.JPG IMG_0013.JPG IMG_0014.JPG IMG_0015.JPG 5 IMG_0016.JPG 6 IMG_0017.JPG 7 IMG_0018.JPG 8 IMG_0019.JPG 9 IMG_0020.JPG 10 IMG_0021.JPG 11 IMG_0022.JPG 12 IMG_0023.JPG 13 IMG_0024.JPG 2. Archival Record Location: Region 5 Electronic Records Center Date and Time (incl. Time zone and DST) 2022:03:23 09:07:57 Latitude and Longitude Not Available 2022:03:23 09:09:47 Not Available 2022:03:23 09:20:17 Not Available 2022:03:23 09:20:36 Not Available 2022:03:23 09:24:37 2022:03:23 09:24:46 2022:03:23 09:25:19 2022:03:23 09:26:48 2022:03:23 09:30:09 Not Available Not Available Not Available Not Available Not Available 2022:03:23 09:34:51 Not Available 2022:03:23 09:38:15 2022:03:23 09:43:56 2022:03:23 09:44:57 Not Available Not Available Not Available Description of Image Switch Tie Sawmill Cyclone Cross Tie Sawmill Cyclone Treatment Cylinder No. 3 Treatment Cylinder Nos. 1 (right) and 2 (left) Back of Cylinder No. 3 Back of Cylinder No. 2 Back of Cylinder No. 1 Work Tanks and Storage Tanks Condenser (foreground) and Bolton Tank (background) Bolton Tank Nos. 2 (left rear) and 3 (right rear) and Condenser Nos. 2 (right front) and 3 (left front) Work Tank Header Roof of Building Housing Work Tanks Roof of Building Housing Work Tanks Appendices Page 1 of 2 Facility Name: Stella-Jones Corporation Facility Location: W1038 County Road U, Bangor, Wisconsin Date of Inspection: March 23, 2022 APPENDIX B: DIGITAL VIDEO LOG 1. Inspector Name: T. Russell Video Number File Name 1 MOV_0164.mp4 2 MOV_0165.mp4 3 MOV_0166.mp4 4 MOV_0167.mp4 5 MOV_0168.mp4 6 MOV_0169.mp4 2. Archival Record Location: Region 5 Electronic Records Center Date and Time (incl. Time zone and DST) Latitude and Longitude 3/23/2022 11:43 Not Available 3/23/2022 11:45 Not Available 3/23/2022 11:46 3/23/2022 11:58 3/23/2022 11:59 3/23/2022 12:05 Not Available Not Available Not Available Not Available Description of Image Knock-out tank venting to atmosphere (Building 7) Capped work tank vent; knock-out tank vent (Building 7) Water treatment (Building 2) and Boiler (Building 1) stacks; view from Building 7 roof Boiler stacks (Building 1); view from ground Water treatment evaporator stack (Building 2); view from ground Knock-out tank (Building 7); view from ground Appendices Page 2 of 2