WS 04-14-2009 - Laserfiche WebLink

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• Page 2 Mr. Grant Fernelius Subsequent Odor Testing, of Cosolvent Oil Samples Bell continued wood treating operations throughout 2008 at the Facility without odor issues. Meanwhile, various alternatives to cosolvent additives (cosolvents increase carrier solubilities) to the No. 2 diesel fuel carrier were tested for odor and compared to the accepted modeling results and the MOU items. Bell also installed a booster fan on the product recovery stack (PRS) to dilute the odor emissions and allow for greater dispersion. In January 2009, Bell received from KMG Bernuth samples of a reformulated DT -40 concentrate, and the cosolvents used to make DT -40. These were identified as ACME Solvent A and Eastman KB -3. The information dial not indicate the presence of aldehydes in the solvents. Odor tests were conducted on the undiluted DT -40 solution, KB -3 and ACME Solvent A on January 21, 2009. The odor concentrations ranged from 5,800 OU for the DT -40 sample to 9,200 OU for the ACME Solvent A sample. Bell also submitted samples of the DT -40, KB -3, ACME Solvent A for speciation of organic compounds by gas chromatography/mass spectrometry (GCMS). The laboratory reported DT -40, KB -3 and ACME Solvent A have similar organic profiles and are composed mainly with ketones. ABell also contacted the KMG Plant that manufactures DT -40, and was informed that the plant had not received an odor complaint in over a year. Based on the evaluation conducted, the booster fan installation, and added dilution of DT40 with low sulfur diesel, Bell determined that emissions from the PRS using DT -40 solution would not exceed 1.2 OU at or beyond the property line. Bell thus purchased DT -40 concentrated for trial use. February 2009 Odor Issue Bell began treating wood with a new shipment of DT -40 solution on February 11, 2009 and odor complaints began soon after. Bell collected a sample of the DT -40 solution from the last tanker car and submitted the sample for odor and chemical analysis. Results from the odor test identified an odor concentration of 35,000 OU which was substantially greater than the 5800 OU reported for the DT -40 solution tested in January 2009. It should be noted, that no Bell employee, including those inclose proximity to the physical treating solution, has reported any health related issues associated with the new treating solution. Chemical analysis of the DT -40 solution that was delivered to the facility, identified that the solution differed significantly from the KMG sample of DT -40 analyzed in January 2009. Specifically, the new solution contained notable concentrations of butyl butryrate and 2- ethylhexanol. These compounds have relatively low odor thresholds and explain why the new solution was more odorous than the KMG sample of DT -40. .