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r 1 <br />LJ <br />• <br />0 <br />March 9, 2009 <br />LUMBER a POLE CO. <br />®N C E 1 9 0 9 i� <br />SwAwdahip • Excellence • EntepweurW Sp4ll <br />Mr. Grant Femehus <br />Community Development Director <br />City of New Brighton <br />803 Old Highway 8 N. W. <br />New Brighton, Minnesota 55112-2792 <br />Re: Evaluation of Air Emissions <br />Bell Lumber & Pole Company <br />New Brighton Minnesota <br />Dear Mr. Femehus: <br />778-1%t Street NW <br />P.O. Box 120785 <br />New Brighton, MN <br />65112-0024 <br />Phone. 881-633-4334 <br />Fax. 661.633-8862 <br />This letter provides a discussion and evaluation of the recent odor issues at Bell Lumber & Pole <br />Company (Bell). <br />Back round <br />In 2006, Bell experienced an increase in odor complaints at the New Brighton Facility. Through <br />subsequent testing of stack emissions and the wood treating solution, it was determined that <br />the problematic odors were mostly caused by the wood treating solution emissions from the <br />product recovery stack (PRS) on the Wood Treating Building. At the time, Bell was treating <br />wood with a DuraTreat 40 solution (manufactured by KMG Bernuth) in a No. 2 fuel oil carrier. <br />The testing showed that DuraTreat 40 contained significant concentrations of butyraldehyde <br />that has a low odor threshold and is readily noticeable at low concentrations. Information <br />received from KMG Bernuth on the DuraTreat 40 solution and the solvents used to make the <br />solution confirmed the presence of aldehydes. As a result of these studies, Bell discontinued the <br />use of DuraTreat 40 and switched to on site mixing pentachlorophenol (PCP) block in a No. 2 <br />diesel solution. Follow-up testing conducted in the summer of 2007 showed that odors from the <br />Facility were effectively reduced. <br />At the request of the City of New Brighton, Bell conducted air modeling to show that a <br />simulated 1991 scenario with emissions from the wood treating oil solution (P-9 oil) exiting the <br />product recovery stack at 365 acfim and an odor detection of 6,000 OU produced an estimated <br />maximum odor concentration of 1.2 OU at the northern border of the property. This formed the <br />basis of the Memorandum of Understanding (N40U) that was signed in November 2007. <br />