AQ_F_1000060_20200605_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Wilmington Regional Office
AIR QUALITY Carolina Pole Leland,Inc.
NC Facility ID 1000060
Inspection Report County/FIPS: Brunswick/019
Date: 06/05/2020
Facility Data Permit Data
Carolina Pole Leland, Inc. Permit 03753 /R13
1901 Wood Treatment Road Issued 4/20/2017
Leland,NC 28451 Expires 12/31/2021
Lat: 34d 15.2640m Long: 78d 4.4640m Classification Synthetic Minor
SIC: 2491 /Wood Preserving Permit Status Active
NAICS: 321 114/Wood Preservation Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SII'
Mike Rouse Mike Rouse Jane House MACT Part 63: Subpart 6J, Subpart 6Q
Facility Manager Facility Manager Corporate EHS NSPS: Subpart Dc
[phone] [phone] [phone]
910 620-0465 cell
Compliance Data
Comments: Inspect facility as scheduled.
Inspection Date 05/19/2020
Inspector's Name Scott Sanders
Inspector's Signature: Scott Sanders C� Operating Status Operating
Compliance Code Compliance-inspection
Action Code PCE
Date of Signature: 6/5/20 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2012 30.94 1.33 11.71 49.04 31.93 27.52 4187.00
2007 46.41 1.71 15.05 46.06 41.04 35.36 3919.00
* Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s) Tested

Carolina Pole Leland,Inc.
June 5,2020
Location and Driving Directions from WiRO
Carolina Pole (CP) Leland, Inc. is located at Wood Treatment Road near the Leland
Industrial Park off US-74/76 West. Turn right onto Cardinal Drive as you leave the office.
Turn left onto Market Street and then turn right onto MLK Parkway (US 74 West) and
continue on the parkway for approximately five miles. Take the US 74 West/NC 133 S
ramp to Whiteville. Cross the Isabel Holmes Bridge and turn left onto US-17/421/74.
Travel approximately one mile and then merge onto US-17 S/US-74 W/US-76 W. Travel
on US-74/76 West going straight for approximately eight miles bypassing all Leland exits.
After passing the Lanvale Road/Mt.Misery Road Leland exit,take the 2nd left onto Wood
Treatment Road off US-74/76. Carolina Pole Leland's office is located approximately ''/9
of a mile down on the right and immediately after crossing the railroad tracks.
Safety Equipment Requirements
CP can require DAQ personnel to use safety shoes, safety glasses, head protection (hard
hat), ear protection(ear plugs), and a safety vest during plant inspections.
General Process Description
A wood preserving process that produces 90% utility poles (primary product) and 10%
foundation pilings (secondary product) is operated at this site. The poles and pilings are
treated with pentachlorophenol (PCP) or chromated copper arsenate (CCA) and then
transferred to a drip area. PCP is dissolved in a petroleum solvent before use and CCA is
an aqueous mixture or solution of chromium, copper, and arsenic oxides.
The wood preserving process consists three pressurized treatment cylinders. The CCA
cylinder is equipped with a vacuum system that vents to an all in one storage and vent tank,
which are two different tanks that share a common vent to the ambient air. The PCP
cylinders are equipped with one vacuum system (two pumps — one vent system) that
transfers preservative into a common vent and recovery tank that also vents to the ambient
air. The three pressure treatment cylinders are located under one shed roof.
Southern yellow pine is unloaded in the wood yard, debarked, and the wood waste is
transferred to a fuel storage area where it is eventually burned in the boiler. After
debarking,the remaining wood poles and pilings are transferred to framing for drilling and
branding.
The poles and pilings are dried in kilns after leaving the framing area and are then treated
with chemicals in an autoclave(cylindrical vessel)that applies the appropriate preservative
to the product through hydraulic pressure. The treated poles are then transferred to a drip
area designed to capture preservative chemicals that discharge after treatment.
The poles are inspected for quality assurance purposes, inventoried, and shipped.
Some poles arrive debarked and are ready for drying after framing.
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Carolina Pole Leland,Inc.
June 5,2020
Recent Permit Activity
On January 9, 2014, a permit renewal of 3753R10 was done. Other changes were made to
the permit as well:
• 6J Boiler GACT was added to the ES-1 boiler.
• Two insignificant/exempt activities were moved into the main permit because of the
emissions inventory that indicated both sources potential emissions of VOC's before
controls were above 5 tons per year. These are listed as ES-2 (three steam heated dry
kilns) and ES-3 (wood preserving operations) in the new air permit.
On April 19, 2016, the facility requested a permit modification to air permit 3753RI I for
the replacement of one of the existing kilns at the facility. The kilns are part of existing
emission source ES-2. The smaller previous kiln(4,000 cubic feet capacity,part of ES-2)
has been replaced with a bigger kiln(12,000 cubic feet capacity,part of ES-2). The facility
was previously classified as a Small source—but because of this permit revision for a larger
kiln replacement, they will now be a Synthetic Minor source. This also triggered NC
toxics.
On April 20, 2017, the facility requested a permit modification to air permit 3753R12 to
add a 20.1 MMBtu/hr Hurst wood boiler (Emission Source ID No. ES-4) and two
multicyclones in series(Control System ID No. CD2). No other changes to the air quality
permit were requested. This newer, additional boiler is needed because of the old age of
the existing boiler.
The application was received in this office on March 1, 2017. The application included a
check in the amount of$400.00 and Forms Al, A2, A3, B, B1, C4, D, and Dl. Emission
calculations accompanied Form D1. A Zoning Consistency Determination was also
included. The permit acknowledgement letter was sent by the Permit Coordinator on
March 2, 2017.
The project involved the installation of a 20.1 MMBtu/hr (600 horsepower) 150 psi Hurst
Hybrid boiler system. The boiler system consists of a Hurst 10"underfeed stoker(auger)
system with fly ash reinjection. Particulate emissions will be controlled through two Hurst
Multi-cyclone mechanical collectors in series. The boiler system was constructed in 1999.
The existing 16 MMBtu/hr boiler system will remain operational,however only one boiler
system will be operated at a time. A single set of feed water pumps will provide service
water to only one boiler at a time to ensure only one boiler at any given time can be
operated.
Specific Condition and Limitation A.5 was added to this permit revision(R13)for the new
wood-fired boiler (20.1 MMBtu/hr, constructed 1999, ES-4). The new boiler (ES-4) is
subject to the New Source Performance Standard 40 CFR Part 60, Subpart Dc. Since
this boiler fires wood only and its maximum heat input capacity is less than 30 MMBtu/hr,
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Carolina Pole Leland,Inc.
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the SO2 and PM emission limitations are not applicable and are therefore not included in
this condition. This condition includes only the recordkeeping and reporting requirements
from Subpart Dc as follows:
15A NCAC 02D .0524 "NEW SOURCE PERFORMANCE STANDARDS" -For one
wood-fired boiler (20.1 million Btu per hour maximum heat input, constructed 1999,
ES-4), the Permittee shall comply with all applicable provisions, including the
notification, testing, reporting, recordkeeping, and monitoring requirements contained
in Environmental Management Commission Standard 15A NCAC 02D .0524 "New
Source Performance Standards" (NSPS) as promulgated in 40 CFR 60, Subpart Dc,
including Subpart A "General Provisions."
a. NSPS Reporting Requirements - In addition to any other notification
requirements to the Environmental Protection Agency(EPA),the Permittee
is required to NOTIFY the Regional Supervisor,DAQ,in WRITING,of the
following:
i. The date construction (40 CFR 60.7) or reconstruction (40 CFR
60.15)of an affected source is commenced,postmarked no later than
30 days after such date. This requirement shall not apply in the case
of mass-produced facilities which are purchased in completed form;
ii. The actual date of initial start-up of an affected source,postmarked
within 15 days after such date. If the affected source is permitted to
burn multiple fuels, then the actual date of start-up, for each fuel,
must be submitted and postmarked within 15 days after such date;
b. NSPS Recordkeeping Requirements - In addition to any other
recordkeeping requirements of the EPA, the Permittee is required to
maintain records as follows:
i. The amounts of each fuel combusted during each month; and
All records required under this section shall be maintained for a period of two years
following the date of such record.
The new 20.1 MMBtu/hr boiler (ES-4) was added to the sources subject to 15A NCAC
02D .1111 pursuant to 40 CFR 63, Subpart JJJJJJ(6J)at Specific Condition and Limitation
A.10.
The 20.1 MMBtu/hr wood-fired boiler(ES-4) is exempt from toxics modeling pursuant to
02Q .0702(a)(27)(B), which exempts affected sources subject to 40 CFR Part 63. This
emission source (ES-4) is subject to Part 63, Subpart JJJJJJ(W).
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Carolina Pole Leland, Inc.
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Specific Condition and Limitation A.3 "Particulate Control Requirement'was modified to
include one wood-fired boiler (20.1 MMBtu/hr maximum heat input, ES-4) with an
emission limit of 0.60 lb/million Btu.
Permit No. 03753R13—Current Air Permit
Permit No. 03753R13 was issued for the construction and operation of the following
equipment:
Emission Emission Source Control Control System
Source ID Description System ID Description
one wood/bark-fired boiler
(16.0 million Btu per hour one m-five tubes,
clone
ES-1 maximum heat input) CDl (thirty-five tubes, 9
(NESHAP 6J) constructed 1951,put in inches in diameter
service in 1988 each)
Three steam heated dry
kilns (approximately two X
ES-2 9,000 cubic feet each and N/A N/A
I
one X 12,000 cubic feet)
ES-3 wood preserving operations, N/A mm N/A
j (NESHAP 6Q) fugitive emissions
one wood-fired boiler(20.1 two (2)
ES-4 million Btu per hour CD2 multicyclones in
(NSPS De, NESHAP maximum heat input) series(16 tubes, 6
6J) constructed 1999, put in inches in diameter
service in 2017 each)
Applicable Air Ouality Rules
15A NCAC 2D .0202, "Registration of Air Pollution Sources"
15A NCAC 2D .0504, "Particulates from Wood Burning Indirect Heat Exchangers"
15A NCAC 2D .0521, "Control of Visible Emissions"
15A NCAC 2D .0524, "NSPS 40 CFR Part 60, Subpart Dc"
15A NCAC 2D .0535, "Excess Emissions Reporting and Malfunctions"
15A NCAC 2D .0540, "Particulates from Fugitive Dust Emission Sources"
15A NCAC 2D .0611, "Monitoring Emissions from Other Sources (Multi-Cyclone
Requirements)"
15A NCAC 2D .1100, "NC Air Toxics"
15A NCAC 2D .I 111, "40 CFR 63, Subpart JJJJJJ(Boiler GACT)"
15A NCAC 2D .I 111, "40 CFR 63, Subpart QQQQQQ—Wood Preserving Area
Sources"
15A NCAC 2Q .0315, "Synthetic Minor Facilities"
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' Carolina Pole Leland,Inc.
June 5,2020
Boilers /Multicvclones/Kiln Information
The wood fired boilers provide steam for the three (3) steam heated dry kilns located on
site. The boilers are each controlled by one or two multicyclones equipped with tubes.
The inspection and maintenance requirements and the recordkeeping requirements for the
multicyclones are described in Condition No. A (7) of the current air permit (3753R13).
The multicyclones are inspected at a minimum at least one time per year and records are
maintained electronically. The boilers are inspected on a semi-annual basis and records
are maintained electronically.
There were two stacks that were arranged in series and associated with the old boiler(ES-
1). The first stack was capped and a heat exchanger was located between this stack and
the emission point or second stack. The heated air generated by the heat exchanger
provided energy required to dry product in the third kiln. The heat exchanger is no longer
being operated because a new pole mill was recently installed which currently provides for
more stable fuel flow to the boiler.
The boiler feed system involves conveying wood waste by chain to the boiler inlet where
it is transferred to the combustion chamber and distributed across pinhole grates. In
January 2013, the facility discontinued the use of a pneumatic transfer system and now
uses a conveyor system. Approximately 50%of the fuel burns on the grating system. The
other 50% burns in suspension. The maximum feed rate is 1.5 tons per hour based on the
capacity of the existing wood transfer and feed system.
The boilers are normally fired with the wood and bark waste generated in the pole peeling
(debarking) process and the pole and piling manufacturing process (shavings, trim waste,
and pulpwood).
The automated airflow system that was installed in the past improved visible emissions.
This system is more responsive from a time standpoint to fuel changes(moisture,feed rate,
temperature, etc.) than the manual system it replaced.
Particulate emissions collected by the multicyclone are re-injected into the wood waste
boiler. The use of this fuel improves fuel efficiency, improves visible emissions, and
eliminates afire hazard. The new boiler system reinjects flyash back into the boiler at the
first cut through, not the second cut.
Flyash is defined as finely grained particles entrained in flue gases. Past and present
samples of the emissions collected by the multicyclone have revealed that most of the
material consists of 500 plus micron size particles of unburned fuel or carbon. Sand and
the finely divided particles associated with noncombustible bottom ash are barely
detectable.
Flyash collection by the multicyclones may be limited because the velocity through the
unit is so high that it allows the flyash to pass through. As previously indicated, the
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June 5,2020
multicyclone on boiler ES-1 is followed by a heat exchanger that was used to heat one of
the three dry kilns located on site. Flyash collects on the steel plates located near the
exchanger tubes at the end of the heat exchanger and is periodically cleaned. Flyash is also
periodically cleaned and scraped from each of the boilers fireboxes. The flyash is disposed
of in a landfill. A 55 gallon drum of flyash is disposed of every week.
6J Boiler GACT Applicability:
15A NCAC 2D .1111, "General Available Control Technology" — 40 CFR 63, Subpart
JJJJJJ applies to both boilers. The 6J GACT as Specific Condition A.10 reads as follows:
GENERALLY AVAILABLE CONTROL TECHNOLOGY-For the one wood/bark-fired
boiler (16.0 million Btu per hour maximum heat input, constructed 1951, No. ES-1) and
one wood-fired boiler (20.1 million Btu per hour maximum heat input, constructed 1999,
ES-4),the Permittee shall comply with all applicable provisions,including the notification,
testing, and monitoring requirements contained in Environmental Management
Commission Standard 15A NCAC 2D .1111, as promulgated in 40 CFR 63, Subpart
JJJJJJ, " National Emission Standards for Hazardous Air Pollutants for Area Sources:
Industrial, Commercial, and Institutional Boilers", including Subpart A "General
Provisions."
a. Compliance Dates(40 CFR 63.11196)-The owner or operator of an existin¢source
is required to comply with the tune-up and the energy assessment requirements no
later than March 21, 2014.
b. Compliance Requirements - As required by 15A NCAC 2D .1111, the Permittee
shall comply with the following requirements:
i. General Duty Clause (40 CFR 63.11205(a)) - At all times the Permittee shall
operate and maintain any affected source, including associated air pollution
control equipment and monitoring equipment, in a manner consistent with
safety and good air pollution control practices for minimizing emissions.
ii. Boiler Tune-up (40 CFR 63.11223) - An initial boiler tune-up is required by
March 21, 2014. If the unit is not operating on the required date for a tune-up,
the tune-up must be conducted within thirty days of startup. The Permittee shall
comply with the following with respect to the tune-up:
A. Periodic tune-ups: A biennial tune-up is required and shall be conducted no
more than 25 months after the previous tune-up. The following units are
only required to conduct a tune-up every five years: seasonal boilers
(shutdown for 7 consecutive months or 210 consecutive days each 12-
month period due to seasonal conditions; only biomass or oil), limited-use
boilers,and units with oxygen trim systems,as defined in 40 CFR 63.11237.
Each five-year tune-up must be conducted within 61 months of the previous
tune-up.
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Carolina Pole Leland, Inc.
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B. Fuel required for the tune-up: The permittee shall conduct the tune-up while
burning the type of fuel (or fuels in the case of boilers that routinely burn
two types of fuels at the same time) that provided the majority of the heat
input to the boiler over the 12 months prior to the tune-up.
C. As applicable, inspect the burner, and clean or replace any components of
the burner as necessary.The Permittee may delay the burner inspection until
the next scheduled unit shut down, but must inspect each burner at least
once every 36 months (72 months for 5-year tune-ups).
D. Inspect the flame pattern, as applicable, and adjust the burner as necessary
to optimize the flame pattern. The adjustment should be consistent with the
manufacturer's specifications, if available.
E. Inspect the system controlling the air-to-fuel ratio,as applicable,and ensure
that it is correctly calibrated and functioning properly. The Permittee may
delay the air to fuel ratio inspection until the next scheduled unit shutdown,
but must conduct the inspection at least once every 36 months (72 months
for 5-year tune-ups).
F. Optimize total emissions of carbon monoxide. This optimization should be
consistent with the manufacturer's specifications, if available, and with any
nitrogen oxide requirement to which the unit is subject.
G. Measure the concentrations in the effluent stream of carbon monoxide in
parts per million, by volume, and oxygen in volume percent, before and
after the adjustments are made(measurements may be either on a dry or wet
basis, as long as it is the same basis before and after the adjustments are
made). Measurements may be taken with a portable CO analyzer.
iii. Energy Assessment (40 CFR 63.11214(c)) - A one-time initial energy
assessment is required by March 21, 2014. The energy assessment must be
performed by a qualified energy assessor. An energy assessment completed on
or after January 1,2008,that meets or is amended to meet the energy assessment
requirements in this section satisfies the energy assessment requirement. This
energy assessment requirement does not apply to limited use boilers as defined
in 40 CFR 63.11237. A facility that operates under an energy management
program compatible with ISO 50001 that includes the affected units satisfies
the energy assessment requirement. The energy assessment must include:
A. A visual inspection of the boiler system.
B. An evaluation of operating characteristics of the facility, specifications of
energy using systems, operating and maintenance procedures, and unusual
operating constraints.
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Carolina Pole Leland,Inc.
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C. Inventory of major systems consuming energy from affected boilers and
which are under control of the boiler owner or operator.
D. A review of available architectural and engineering plans,facility operation
and maintenance procedures and logs, and fuel usage.
E. A list of major energy conservation measures that are within the facility's
control.
F. A list of the energy savings potential of the energy conservation measures
identified.
G. A comprehensive report detailing the ways to improve efficiency, the cost
of specific improvements, benefits, and the time frame for recouping those
investments.
c. Notification and Reporting Requirements-In addition to the notification and reporting
requirements of the Environmental Protection Agency(EPA),the Permittee is required
to NOTIFY the Regional Supervisor,DAQ, in WRITING, of the following:
i. Initial Notification(per 40 CFR 63.9(b)and 40 CFR 63.11225(a)(2))is required
by January 20, 2014.
ii. Notification of Compliance Status(40 CFR 63.11225(a)(4))is required by July
19, 2014.
iii. Compliance Report must be prepared by March 1 of every other year(or every
five years depending on the frequency of the tune-up requirements) starting
March 1 the year following the first periodic tune-up, and submitted upon
request. The report must meet the requirements of 40 CFR 63.11225(b)(1-2).
d. Recordkeeping Requirements - In addition to any other recordkeeping requirements of
the EPA, the Permittee shall maintain the following records as defined under 40 CFR
63.11225(c):
i. Copies of all required notifications.
ii. Maintain the following records to document conformance with the work
practices, emission reduction measures, and management practices:
A. Tune-up records - records must identify each boiler, the date of tune-up, the
procedures followed for tune-up,the manufacturer's specifications to which the
boiler was tuned, and the following:
I. The concentrations of CO in the effluent stream in parts per million, by
volume, and oxygen in volume percent, measured at high fire or typical
operating load, before and after the tune-up of the boiler.
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II. A description of any corrective actions taken as a part of the tune-up of
the boiler.
III. The type and amount of fuel used over the 12 months prior to the tune-
up of the boiler but only if the unit was physically and legally capable
of using more than one type of fuel during that period. Units sharing a
fuel meter may estimate the fuel use by each unit.
B. A copy the Energy Assessment required by 40 CFR 63.11214(c).
C. Seasonal boilers - For each boiler that meets the definition of seasonal boiler,
you must keep records of days of operation per year.
D. Records of non-waste determinations per 40 CFR 63.11225(c)(2)(ii).
iii. Malfunction Records - Records of the occurrence and duration of each
malfunction of the boiler, or of the associated air pollution control and
monitoring equipment. Records of actions taken during periods of malfunction
to minimize emissions in accordance with the general duty to minimize
emissions in 40 CFR 63.11205(a), including corrective actions to restore the
malfunctioning boiler, air pollution control, or monitoring equipment to its
normal or usual manner of operation.
iv. Record Retention - You must keep each record for 5 years following the date
of each recorded action.
Carolina Pole Leland, Inc. is in compliance with these boiler tune-up and energy
assessment requirements. The initial boiler tune up on ES-1 was conducted in early
2012. NOCS was received by DAQ for the initial boiler tune-up on April 24, 2012.
The 2"d biennial tune-up was conducted on the boiler on January 16,2014. An energy
assessment was done at the facility on February 6, 2014. This was done ahead of the
March 21, 2014 deadline. A copy of the energy assessment was previously attached.
Carolina Pole Leland,Inc.has moved steam lines from underground to above ground.
This was recommended in the energy assessment. This has allowed the boiler to
operate more efficiently. The facility entered the tune-up and energy assessment
information into CEDRI(EPA reporting database)on May 20,2014. The 3r'biennial
tune-up was conducted on the boiler on January 27, 2016. The 4th biennial tune-up
was conducted on the boiler on February 11, 2018. The initial boiler tune-up was
conducted on the recently installed 20.1 million Btu per hour wood-fired boiler (ES-
4) on October 17, 2018 (paperwork attached to last inspection report). The 511
biennial tune-up was conducted on the old boiler (ES-1) recently on May 13, 2020
(paperwork attached).
Subpart 60 Applicability:
40 CFR 63, Subpart QQQQQQ — National Emission Standards for Hazardous Air
Pollutants for Wood Preserving Area Sources — 2D .1111 can be described as a MACT
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Carolina Pole Leland,Inc.
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since the preserving process is a NESHAP source that is covered under 40 CFR 63. Subpart
6Q addresses only pressure treatment and thermal treatment processes using wood
preservatives containing chromium,arsenic,methylene chloride, and dioxins as hazardous
air pollutants (HAPs) released from the wood preserving operations. Chromium and
arsenic are present in the Copper-Chromium-Arsenic (CCA) preservative. Dioxins are
present in the pentachlorophenol preservative as chemical contaminants.
The wood preserving MACT standard, 40 CFR 63 Subpart QQQQQQ, remains in the Air
Permit as permit Specific Condition A.11. and reads as follows:
15A NCAC 2D .1111 "MAXIMUM AVAILABLE CONTROL TECHNOLOGY" - For
the following equipment, the Permittee shall comply with all applicable provisions,
including the notification, testing, and monitoring requirements contained in
Environmental Management Condition Standard 15A NCAC 2D .1111, "Maximum
Achievable Control Technology" as promulgated in 40 CFR 63, Subpart(s) below,
including Subpart A "General Provisions."
Emission Source(s) F Regulation
1 Facllrty Wide Subpart QQQQQQ—Wood Preserving Area Sources
Pressure treatment processes. These requirements are only for facilities using wood
preservatives containing chromium, arsenic, dioxin/furan or methylene chloride.
a. Emission Standards- Pursuant to 40 CFR 63.11430.
i. Wood preservatives shall be applied to the wood product inside a retort or
similarly enclosed vessel. This is being done. CCA and PCP treatments are
applied inside enclosed vessels (cylinders).
ii. Treated wood product shall be stored on drip pads or in a primary containment
area to convey preservative drippage to a collection system until dripping has
ceased. This is being done. Poles are not removed from cylinders until they
have 6 to 8 hours of vacuum pressure applied to them. This eliminates
drip.
iii. The pressure retort or vessel shall be fully drained to the extent possible prior
to opening the vessel door. This is being done.
iv. All spills shall be promptly collected. This is being done.
V. In the event of a malfunction, corrective actions or preventative measures shall
be completed prior to resuming operation. A secondary chamber outside each
cylinder can be utilized in case of a malfunction in the primary chamber.
b. Recordkeeping Requirements - Pursuant to 40 CFR 63.11430
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i. The owner or operator shall maintain records of the following:
A. The type of treatment process
B. The types and amounts of wood preservative used at the facility
C. Charge records identifying the pressures inside the retorts.
ii. The Permittee shall make the records available for inspection upon request of
DAQ personnel.
iii. These records must be maintained for 5 years, with the last 2 years of data
retained on site. The remaining 3 years of data may be maintained offsite. All
records such as type of treatment processes,the types and amounts of wood
preservative used, and charge records identifying the pressures inside the
cylinders for each batch are maintained onsite and never removed
regardless of date. Production records are also kept onsite forever.
c. Reuortine Requirements-Pursuant to 40 CFR 63.11431,the Permittee shall submit the
following reports to the DAQ:
i. Initial notification form of applicability no later than 90 days after the
compliance date of July 17,2007. (This was completed on August 27,2007.)
ii. Notification of compliance status report no later than 90 days after the
compliance date of July 17, 2007. This notification shall list:
A. The following certification of compliance statement:"This facility complies
with the management practices to minimize air emissions from the
preservative treatment of wood in accordance with 40 CFR 63.11430."
B. The signature of a responsible official.
(Note: A and B were completed on August 27,2007.) This was previously attached.
iii. A report of any deviations from the requirements of Subpart QQQQQQ within
30 days of the deviation.
Carolina Pole Leland, Inc. is in compliance with the MACT for Wood Preserving
Area Sources (Subpart QQQQQQ).
Newer Regulations (NC Toxics (A.9) and Synthetic Minor(A.12)):
The following two new regulations were added to the permit at the previous permit revision
on April 19, 2016 (R12):
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15A NCAC 2D .1100, "Control of Toxic Air Pollutants"—The permit condition to address
this regulation remains unchanged with the latest permit modification done on April 20,
2017.
TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING
REOUIREMENT - Pursuant to 15A NCAC 2D .1100 "Control of Toxic Air Pollutants,"
and in accordance with the approved application for an air toxic compliance demonstration,
the following permit limits shall not be exceeded:
Affected Source(s) Toxic Air Emission
Pollutant Limit
Three steam heated dry kilns (approximately two X (Acrolein
9,000 cubic feet each and one X 12,000 cubic feet, ES- '{107-ein 0.1841b/hr
2)
Three steam heated dry kilns(approximately two X Formaldehyde
9,000 cubic feet each and one X 12,000 cubic feet, ES- (50-00-0) [504 lb/hr
2)
a. Recordkeeping Requirements - The following recordkeeping requirements apply:
i. The three kilns were modeled at the maximum batch capacity; meaning Kiln 1
and 2 together (9,000 cubic feet each) at a capacity of 108,000 bd-ft total
softwood per 55 hours (or 1,964 bd-ft per hour) and Kiln 3 (12,000 cubic feet)
at a capacity of 144,000 bd-ft softwood per 72 hours (or 2,000 bd-ft per hour).
This equates to 3,458,333 cubic feet of total wood dried annually. Thus, the
facility shall keep a logbook of all batch production cycles showing the amount
of cubic feet in each kiln during each batch during the calendar year. This
logbook shall be kept on site at all times and made available to the DAQ
inspector upon request. No reports are required to be sent to the Regional
Supervisor.
b. Reporting Requirements-For compliance purposes,the following shall be retained
on site for review and inspection by the Regional Inspector, DAQ at any time:
i. The kiln drying production rates as described in paragraph a.(i). No reports are
required to be sent to the Regional Supervisor. These records shall be kept on
site for a minimum of two years.
15A NCAC 20 .0315, Synthetic Minor Facilities" — The Synthetic Minor Condition was
updated with the permit modification on April 20, 2017 to reflect the increase in VOC
emissions (from 1.19 ton/yr to 1.50 ton/yr)from the new 2 0.1 MMBtu/hr boiler (ES-4)
LIMITATION TO AVOID 15A NCAC 20 .0501 - Pursuant to 15A NCAC 2Q .0315
"Synthetic Minor Facilities," to avoid the applicability of 15A NCAC 2Q .0501 "Purpose
Page 13 of 18

Carolina Pole Leland,Inc.
June 5,2020
of Section and Requirement for a TV Permit," as requested by the Permittee, facility-wide
emissions shall be less than the following:
Pollutant Emission Limit
(Tons per consecutive period)
VOC 100 _.._.- _. -. ------
a. Operations Restrictions - To ensure emissions do not exceed the limitations above,
the following restrictions shall apply:
i. The total amount of board-feet dried in kiln# 3 shall be less than 144,000 bd-ft
per batch in 72 hours (on average) throughout the calendar year. The total
amount of board-feet dried in kiln # 1 and 2 shall be less than 108,000 bd-ft
total per batch in 55 hours (on average) throughout the calendar year. These
are the same operational limits as in the toxics condition above (A.9.).
ii. Kiln Annual Limit and VOC emissions; 41,500,000 bd-ft total annual actual
production = 84.9 ton/yr VOC. Plus: 41,500,000 bd-ft (which converts to
3,458,333 cu. ft. per year) = 13.1 ton/yr VOC from the Wood Preserving
operation. Plus: VOC PTE emissions from the woodibark fired boiler are 1.50
ton/yr. Summation=(84.9 + 13.1 + 1.50) =99.5 ton/yr VOC.
b. Recordkeeping Requirements - The Permittee shall record monthly and total
monthly(for the previous 12 months)the following:
i. Kiln Annual Limit = 41,500,000 bd-ft total annual actual production is
equivalent to 3,458,333 cu. ft.dried per year. The facility shall record the actual
amount of softwood dried in all three kilns in cu. ft. per batch per month
throughout the calendar year. The same limit applies to the wood preserving
operation (this applies to the pentachlorophenol or any other organic (VOC)
wood preserving operation and recordkeeping is required to verify this limit
also). No recordkeeping is required for the boiler use since the VOC PTE
(8,760 hours)= 1.50 ton/yr accounted for above.
c. Reporting Requirements - Within 30 days after each calendar year quarter,
regardless of the actual emissions,the Permittee shall submit the following:
i. emissions and/or operational data listed above in paragraph b. The data should
include monthly and 12 month totals for the total amount of cu. ft. dried per
month and per year on a rolling monthly basis throughout the calendar year. A
running 12 month total shall be reported to the DAQ Regional Supervisor every
quarter.
The first quarterly report was due by July 30,2016 for the 2"d quarter of 2016. This
report and subsequent reports have all been received on time and indicate
compliance. The most recent reports are attached for reference. In CY 2019,
Page 14 of 18

Carolina Pole Leland,Inc.
June 5,2020
1,980,032 cubic feet of wood were dried in the kilns. 1,718,324 cubic feet went through
the wood preserving operation. These reports indicate the facility is operating well
below the Synthetic Minor limitation(3,458,333 cubic feet).
Permitting Considerations Concernin¢Toxic Air Pollutant Evaluation
Requirements (copied from recent permit review on April 19,2016)
NC TAP Emission Exceedances:
A review of NC TAPs emission data for the entire facility in the application showed the
following:
NC TAP Acrolein Formaldehyde
Two Kilns 9,000 0.1102 lb/hr 0.3024 lb/hr
New Kiln(12,000) 0.07341b/hr 0.2016 lb/hr
Sub-Total * 0.184 lb/hr 0.504 lb/hr
Boiler 0.064 lb/hr 35% increase 0.0704 lb/hr 14% increase
Wood Presery Op. ------ ------
Total 0.248 lb/hr 0.57441b/hr
TPER a Table 1 0.021b/hr 10.041b/hr
%AAL 56 % 83 %
* The Sub-Total emissions are what was modeled by the applicant.
The following was submitted in memo form by the Raleigh AQAB to the Wilmington
Regional Office on March 1, 2016.
Maximum Impacts for Carolina Pole,Brunswick County,NC
Pollutant Averaging Perio Maximum Concentrati AAL %of AAL
m m3 m m3
Acrolein 1 hour 46 80 56 %
Formaldehyde I hour 125 150 83 %
The above toxic emissions were modeled at maximum batch production rates for all three
kilns. The resulting AAL % was Acrolein = 56 % and Formaldehyde = 83 %. (The
emissions from the boiler (DAQ wood waste combustion spreadsheet) were Acrolein =
0.0641b/hr and Formaldehyde = 0.0704 lb/hr. This represents an additional 0.064/0.184
or 34.8 % increase in the Acrolein emissions and 0.0704/0.504 or 14.0 % increase in the
Formaldehyde emissions. This results in a final AAL%(if linear) of Acrolein=75 % and
Formaldehyde = 94.6 %. The wood preserving operation was confirmed to have no
acrolein nor formaldehyde emissions. No reports are required to be sent to the Regional
Supervisor.
Per Session Law 2012-91,facilities that are subject to MACT/GACT rules are not required
to comply with the NC air toxics rules (2Q .0711 / 2D .1100). The 6J Boiler and the 6Q
Wood Preserving emissions were not required to modeled by the facility — but NC DAQ
Page 15 of 18

Carolina Pole Leland,Inc.
June 5,2020
does have to provide a risk analysis to the public health due to this permit revision. The 6J
Boiler provided a small amount of addition emissions of acrolein and formaldehyde and
have been accounted by engineering judgment (linear ratio) and the 6Q Wood Preserving
was confirmed to have no acrolein or formaldehyde emissions. The % AAL with the
additional amounts were still below 100 %,thus, the risk to public health is believed to be
minimal.
The%AAL with the new boiler's emissions substituted in the place of the existing boiler's
emissions in the NC TAP Emissions Data table above result in Acrolein and Formaldehyde
emissions still remaining below 100 % of their respective AALs.
Facility-Wide Emissions Summary:
The following are the facility-wide emissions from Form D 1 which includes the new 20.1
MMBtu/hr boiler(ES-4) but does not include the emissions from the existing boiler(ES-
1) since only one boiler will be operating at any given time.
Criteria Air Pollutant Emissions Facility-Wide
Pollutant Expected Actual Potential Emissions Actual Emissions
Emissions* (before (2012)
(after controls/limitations) (after
controls/limitations) tons/year controls/limitations)
tons/year tons/year
PM 30.55 30.55 30.55
PM10 27.03 27.03 27
PM2.5 1 23.51 23.51 23.51
S02 2.20 2.20 1.3
NOx 19.37 19.37 12
CO 52.82 1 52.82 1 32
VOC 99.5 1 124 49.04
Hazardous/Toxic Air Pollutants from ES-4
Pollutant Expected Actual Emissions Potential Emissions
(After Controls/Limitations) (Before Controls/Limitations)
tons/year tons/year
Acetaldehyde 0.073 0.073
Acrolein 0.352 0.352
Formaldehyde 0.387 0.387
Inspection Comments
• Mr. Rouse was contacted by telephone to conduct a Partial Compliance Evaluation(PCE).
The permit, applicable rules, boiler maintenance procedures and recordkeeping
requirements were discussed with Mr. Rouse.
Page 16 of 18

Carolina Pole Leland, Inc.
June 5,2020
• Carolina Pole Leland, Inc. employs 51 people. 30-35 employees work onsite and the other
employees are in sales and trucking. Business is actually slightly up since the last
compliance inspection, which was performed on September 19, 2019. The Covid-19
pandemic has had only minimal impact on the plant. They have only minimal
administrative staff currently working onsite. No Covid-19 cases have been reported at the
plant or in the entire company as a whole.
• The facility operates from 6 am to 10 pm(2 shifts),5 days per week for treating and 6 days
per week for drilling(framing).
• The boilers operate 24 hours a day and 7 days per week (one at a time). The boilers only
shut down for maintenance or malfunctions.
• Boiler (ES-1) was reported to be operating during the inspection. The newly installed
boiler (ES-4) was reported down for maintenance during the inspection. They were
reported to be working on the water feed system to the unit which will be going to
automation. This new boiler is operating much more efficiently than the old boiler(ES-1)
and using less fuel.
• Last scheduled internal boiler inspection and maintenance on ES-1 was performed on
March 16, 2020. The internal inspection revealed all was good. The heat exchanger was
cleaned and some loose refractory was repaired and replaced at that time. Last scheduled
internal boiler inspection and maintenance on ES-4 was performed on August 26, 2019.
The internal inspection indicated all was good with no issues noted. The multicyclones
were clear with no ash accumulation and the ash reinjection fan was serviced at that time.
All accumulated ash was removed from the fire tube end and from the heat exchanger at
the bottom of the stack. Records are maintained by the facility electronically and are
attached to this report. The facility appears to do a good job with maintaining the boilers
to ensure they operate at optimum efficiency.
• Records also indicate the multicyclones are inspected at least once per year.
• The facility was hoping to have the newly permitted boiler(ES-4) up and running by July
1, 2017. NSPS notification of initial startup of the boiler was received by DAQ on
December 19, 2017 (letter previously attached) for the boiler to go into operation the
following day on December 20, 2017. This new boiler had not run consistently for a while
due to poor system design which had resulted in malfunction and mechanical failure in
parts of the unit. The initial conveyor was not conveying properly to feed the boiler with
wood fuel. Larger pieces of wood were getting hung up in the auger. The facility now
finally has this problem solved and the new boiler is up and running.
• All three (3) steam heated dry kilns were reported being used during the inspection. Kiln
No. 3 (12,000 cubic feet) is relatively new and began operating in the summer of 2016.
Page 17 of 18

Carolina Pole Leland, Inc.
June 5,2020
• All three (3) cylinders for the wood preserving pressure treatment process were reported
being used during the inspection. Two were reported processing the PCP treated poles and
the other was being used for the CCA.
• Carolina Pole was believed to be the source of an odor causing many complaints in the
past. DAQ felt the odor was coming from the large volume of product stored on site.
Various size light poles were stored on the yard in stacked piles where they could basically
vent VOC into the atmosphere. The odor was believed to be from the
Pentachlorophenol/Diesel (PCP) treated stock. Therefore, Carolina Pole has cut the
amount of inventory (treated poles) on the yard by 50% since January 2012. This was
achieved by not treating or loading the PCP treated poles that are exported via railroad cars
until their departures date is within one week. 50% of the PCP treated poles are shipped
by railroad car and truck to the Northeast.
• There were new quarterly reporting requirements contained in the air permit as part of the
new Synthetic Minor Condition. The I'quarterly report was due by July 30, 2016 for the
2ad quarter (April, May & June). This report and subsequent reports have been received
on time and indicate compliance. Copies of the most recent quarterly reports are attached.
• This facility does not have emergency generators.
• This facility has not received any NOD's,NOV's, or NRE's in the last five years.
• Caroline Pole Leland, Inc. does not receive 112(r) inspections. This facility does not
manufacture or store regulated substances above threshold quantities that would trigger the
112(r)requirements.
• Carolina Pole Leland, Inc. appeared to be operating in compliance with applicable DAQ
rules during this partial compliance evaluation.
Page 18 of 18

Quarterly Reporting(Submission within 30 days.2 copies mailed) YEAR 2019
Facility Name Carolina Pole Leland i PERMIT LIMITS
Location Leland,NC IFacilitylD# 1000060 1 Kilns Comb 3,458,333 ICubic Feet
Condition No. A.11 I Permit No. 1 037531112 jWd Pres Production Penta same as above
Report period 2019 Syn Minor
Wood Wood
Kiln 1, (2,3 Kilns Rolling 12 Preservation
Month/Year Preservation Send to
Combined Pentachloro h Month Sum Rolling 12
Quarter One Cubic Foot p Cubic Foot month Sum
enol)cubic Foot Scott Sanders
Cubic Foot
Monthly Monthly NC Division of Air Quality
February'18 136,440 144,352 136,440 144,352 Wilmington Regional Office
March '18 177,196 150,184 313,636 294,536 127 Cardinal Drive Extension
April'18 115,446 131,158 429,082 425,694 Wilmington,NC28405
May'18 143,688 141,697 572,770 567,391 910-796-7215
June'18 107,614 131,347 680,384 698,738
July'18 147,871 199,174 828,255 897,912
August'18 123,665 156,964 951,920 1,064,876
September'18 84,345 98,970 1,036,265 1,153,846
October'18 145,062 173,100 1,181,327 1,326,946
November'18 125,783 120,265 1,307,110 1,447,211
December'18 123,217 106,863 1,430,327 1,554,074
January'19 151,598 162,616 1,581,925 1,716,690
February'19 146,703 130,086 1,592,188 1,702,424
March'19 186,418 155,986 1,601,410 1,708,226
Apri I'19 184,333 144,843 1 1,670,297 1,721,911
May'19 162,653 137,442 1,689,262 1,717,656
June'19 198,906 156,020 1,780,554 1,742,329
July'19 193,295 187,683 1,825,978 1,730,838
August'19 208,537 204,557 1,910,850 1,778,431
September'19 172,710 132,693 1,999,215 1,812,154
October'19 1,854,153 1,639,054
November'19 1,728,370 1,518,789
December'19 1,605,153 1,411,926

Quarterly Reporting(Submission within 30 days 2 copies mailed) YEAR 2019
Facility Name Carolina Pole Leland PERMIT LIMITS
Location Leland,NC Facility ID It 1000060 Kilns Comb 3,458,333 Cubic Feet
Condition No. A.11 Permit No. 037531112 jWd Pres Production Penta same as above
Report period 2019 Syn Minor
Wood
Kiln 1,2,3 Wood Kilns Rolling 12 Preservation
Month/Year Preservation Send to
Combined h Month Sum Rolling 12
Quarter One Cubic Foot (pentachloro P Cubic Foot month Sum
enol)cubic Foot Cubit Foot Scott Sanders
Monthly Monthly NC Division of Air Quality
February'18 136,"0 144,352 136,440 144,352 Wilmington Regional Office
March'18 177,196 150,184 313,636 294,536 127 Cardinal Drive Extension
April'18 115,446 131,158 429,082 425,694 Wilmington,NC 28405
May'18 143,688 141,697 572,770 567,391 910-796-7215
June'18 107,614 131,347 680,384 698,738
July'18 147,871 199,174 828,255 897,912
August'18 123,665 156,964 951,920 1,064,876
September'18 84,345 98,970 1,036,265 1,153,846
October'18 145,062 173,100 1,181,327 1,326,946
November'18 125,783 120,265 1,307,110 1,447,211
December'18 123,217 106,863 1,430,327 1,554,074
January'19 151,598 162,616 1,581,925 1,716,690
February'19 146,703 130,086 1,592,188 1,702,424
March'19 186,419 155,986 1,601,410 1,708,226
April'19 1 184,333 144,843 1,670,297 1,721,911
May'19 162,653 137,442 1,689,262 1,717,656
June'19 198,906 156,020 1,780,564 1,742,329
July'19 193,295 187,683 1,825,978 1,730,838
August'19 208,537 204,557 1,910,850 1,778,431
September'19 172,710 132,693 1,999,215 1,812,154
October'19 175172 210,841 2,029,325 1,849,895
November'19 177:399 136,742 2,080,940 1,866,372
December'19 173,907 121,431 2,131,630 1,880,940

Quarterly Reporting(Submission within 30 days.2 copies mailed) YEAR 2020
Facility Name Caro Ina Pole Leland PERMIT LIMITS
Location Leland,NC Facility ID R 1000060 Kilns Comb 3,458,333 Cubic Feet
Condition No. A.31 Permit No. 03753R12 Wd Pres Production Penta same as above
Report period 1 2020 jSyn Minor
Month/Year Kiln 11 213 Wood Preservation Kilns Wood Send to
Combined (Pentachlorophenol) Rolling 12 Preservation
Quarter One cubic Foot cubic Foot Month Rollin 12 Scott Sanders
Monthly Monthly NC Divlsion of Air Quality
February719 146,703 130,086 246,703 130,086 Wilmington Regional Office
March'19 186,418 155,986 333,121 286,072 127 Cardinal Drive Extension
April'19 184,333 144,843 517,454 430,915 Wilmington,NC29405
May'19 162,653 137,442 680,107 568,357 910-796-7215
June'19 198,906 1 156,020 879,013 724,377
July'19 193,295 187,683 1,072,308 912,060
August'19 208,537 204,557 1,280,845 1,116,617 RECEIVED
September'19 172,710 132,693 1,453,555 1,249,310
October'19 175,172 210,841 1,628,727 1,460,151
November'19 177,398 136,742 1,806,125 1,596,893 APR r, on?o
December'19 173,907 12l,431 1,980,032 1,718,324
January'20 170,394 215,879 2,150,416 1,934,203
February'20 137,320 133,394 2,141,033 1,937,511 pqQ WIRO
March'20 146,133 208,803 2,100,748 1,990,328
April'20 1,916,415 1,845,485
May'20 1,753,762 1,708,043
June'20 1,554,856 1,552,023
July'20 1,361,561 1,364,340
August'20 1,153,024 1,159,783
5eptember'20 980,314 1,027,090
October'20 805,142 816,249
November'20 827,7" 679,507
December'201 1 453,837 553,076

DATE DESCRIPTION OF WORK
12/15/2007 Replaced rotary lock on ash collector
08/25/2008 Inspected steam and mud drum
08/25/2008 Inspection went well,and scale has been reduced since the last inspection
08/25/2008 Repaired refractory inside the fire box
08/25/2008 Replaced three broken grates
08/25/2008 Inspected inside ash collector. All looked good.
O8/2S/2008 Replaced 2"Apollo ball valve on blowdown line
08/25/2008 Cleaned out heat exchanger/precipitator
10/14/2008 Replaced transition on I/D side between stack and fan
10/17/2008 Repaired transition between the air to air heat exchanger and the stack.
10/17/2008 Cleaned out heat exchanger/precipitator
10/21/2009 Inspected steam and mud drum
10/21/2009 Scale continued to be reduced
10/21/2009 Replaced main blowdown valve
10/21/2009 Repaired refractory inside the fire box 55 cartons
10/21/2009 Repaired feed chute
10/21/2009 Inspected inside ash collector. All looked good. Removed some sand that had stuck to sides.
10/21/2009 Cleaned out heat exchanger/precipitator
12/27/2010 Inspected steam and mud drum
Inspection went well. Some scale has built up snce the last inspection
Joe Moore repaired refractory inside the fire box
Inspected inside ash collector
Cleaned out heat exchanger/precipitator
10/14/2011 Replaced refractory in front doors
10/14/2011 Replaced 2"feed water valve and line below check vales going into that steam drum.
10/14/2011 Replaced blowdown line for header at hand holes on the backside that was leaking _
11/16/2011 Replaced seals on both feedwater pumps
12/19/2011 Joe Moore replaced refractory and did an internal inspection with the state rep.,inspected the flue and cleaned out the heat exchanger
12/21/2011 Had Leon Plummer with X-Act Controls here to do the work for the GACF inspection and tuning

12/21/2011 Leon instructed the operators how to set air pressures to minimize smoke emissions
12/21/2011 Air pressure ranges to maintain were marked on gauges
12/21/2011 Cleaned out precipitants from the heat exchanger
03/05/2012 Shaft on feed hopper broke and was replaced (boiler was down for one day)
02/25/2013 Did annual internal inspection with state rep. Cleaned the heat exchanger and inspected inside of the ash collector.All looked good.
03/02/2013 Replaced feedwater pump"A"
04/03/2013 Removed the south facing wall entirely and replaced all refractory tiles, insulation,and sheeting $47,500.00
08/23/2013 Rolled tube on third row facing the front of the manway inside the steam drum
O1/16/2014 Had Leon Plummer with X-Act Controls do the GMAC Subpart JJIJJJ inspection,training, and recommendations
03/17/2014 Replaced refractory in doors. Installed 25 boxes of plastic refractory in the firebox. All work done in-house.
03/17/2014 Bill Gatlin did internal inspection fo the pressure vessel
07/11/2014 Replaced inner seal on feedwater pump"A"
08/24/2014 Bill Graham came by and did an "in operation inspection"
09/04/2014 Changed motor on the FD fan
09/24/2014 Replaced feedwater pump"B" $5,250.00
10/31/2014 Replaced reinjection fan and motor with new model due to the fan on the old one coming apart
10/31/2014 Joe Moore rolled two tubes and plugged two tubes
O1/21/2015 9 tubes were plugged,two were opened up with turbine and 5 by hydroblasting
Down Time Joe Moore turbined all tubes
4 days Thompson Industries hydroblasted the tubes
Replaced 1" ball valve on bottle blowdown line
Joe Moore repaired refractory in the doors and in the fire box. Used 20 boxes
O1/25/2015 Pressure washed through the back door(soot box)
Repaired refractory in the front and both sides. —
01/27/2016 Did MACT test with Leon Plummer from XACT Controls.
05/02/2016 Replaced aurora pump on the feedwater side$5391
05/16/2016 Delagged walls inside firebox pathe the refractory in front and rear walls with Surgun 60 By Joe Moore
Patched the fron doors with Blu Ram refractory
Did internal inspecton with state on steam drum mud drum and hand holes in headers(All OK)
Replaced McDonnell Miller water level control

Inspected ash multicone ash collector and rebohed one end cap.
Cleaned air to air heat exchanger at stack.
07/19/2016 Repaired one tube in the rear access door with welding.Joe Moore and company did the work
04/05/2017 Replaced aurora pump"B"
06/15/2017 Did internal inspection on boiler checked both drums and hand holes at each end of header.Justin Royster.All good.
Patched the back wall and front wall along with the front doors with Blu Ram By Cox personnel
Cleaned air to air heat exchanger at stack and tie in with new boiler exahaust.
inspected ash multicone ash collector and all cones were in place.
07/20/2017 Made repairs to refractory in north wall with Blu Ram by Cox personnel.
07/25/2018 Arise Insurance did internal inspection on the CE boiler and all was good.He asked that we put a camera on the sight glasses on both boilers.
Joe Moore and Company replaced refractory on west wall and south wall with gunnit and put castable in both doors.
Cleaned air to air heat exchanger at stack and tie in with new boiler exahaust.
Replaced aurora feed water pump"A"
Did inspection on muiticyclone and all cones were in place.
O8/06/2018 Removed old lose refractory and replaced as needed on CE boiler.
02/08/2019 JOMOCO cut top of boiler to find leak and plugged one tube and hydrotested to 150 psi.
04/15/2019 Removed and replaced loose refractory.Cleaned heat exchanger and inspected multiclone. Had to bolt one multiclone tube back up.
05/21/2019 Rolled 32 tubes and plugged 5 tubes on CE boiler. Hydro tested to 150 psi.By JOMCO.
03/16/2020 Did internal inspection with Mike Morgan"Arise"and all was good.
Cleaned heat exchanger and repaired and replaced loose refractory with Blu Ram plastic.

yUrf
DATE DESCRIPTION OF WORK
02/08/2019 JOMOCO changed out feedwater auto control valve.Old valve was not dosing properly.
02/12/2019 Did internal inspection with Mike Morgan from Arise and recommendations were made to replace header blowdown lines with 1'.
03/12/2019 JOMOCO changed out 300N non return valve on top of boiler and installed one with a safety drain tap.Old valve was leaking around bonnet.
03/20/2019 JOMOC installed vent pipe on main header
Removed 3/4"header blowdown lines and installed 1"lines for both headers.
Changed one 6'valve on header and put a blind flange on the one that could be opened to atmosphere.
Changed out all of bolts on header to high carbon bolts.
06/19/2019 JOMOCO reomoved all of the refractory in the floor and north side wail.
Reomoved old air box and Installed all new air box
Installed a new air box along with all frame work in the floor.
Installed a new Blu Ram refractory in floor and north sidewall.
08/26/2019 Mike Morgan with arise did Internal inspection on boiler.No issues were noted.
Multiclones were clear with no ash accumulation and ash reinjection fan was serviced.
All accumulated ash was removed from fire tube end and from heat exchanger at the bottom of the stack.
10/21/2019 Plant personel replaced feedwater pump under deareator on east side.

Tune-up Record and Compliance Certification
National Emission Standards for Hazardous Air Pollutants for Area Sources:
Industrial, Commercial, and Institutional Boilers
40 CFR Part 63 Subpart JJJJJJ
This form shows examples of what on site records should be maintained to document your tune-up.
Your regulated boiler may require additional detail, depending on your boiler design. This list is not all-
Inclusive, because It is not modeled after a particular system, but instead gives only general
Information that is applicable to most systems.
What is the purpose of this form?
You may use this form to meet the requirements for completing and documenting a tune-up
under the National Emission Standards for Hazardous Air Pollutants for Area Sources:
Industrial, Commercial, and Institutional Boilers. However, you may also record the information
in another form or format.
SECTION I: INSTRUCTIONS
Check the applicable box below:
® My boiler Is subject to a tune-up requirement.
If you did not check the box above, do not use this example record. See
htto�l/www.epa.aov/ttn/atw/boiler/bQilerpq.htm for additional implementation tools.
When is this form due (§63.11225(b))?
Existing Sources: For each tune-up conducted, Sections I-V of this form are records that you
should keep to demonstrate compliance with this rule. The first tune-up should be
completed by March 21, 2014. Subsequent biennial or 5-year tune-ups, as
applicable, should be completed no later than 25 months or 61 months,
respectively, after the previous tune-up.
The first Compliance Certification Report (Section VI of this form) must be
prepared by March 1, 2015. Later certifications must be prepared by March 1 of
the year following the calendar year during which a biennial or 5-year tune-up is
completed.
New Sources: For each tune-up conducted, Sections I-V of this form are records that you
should keep to demonstrate compliance with this rule. The first biennial or 5-year
tune-up, as applicable, must be no later than 25 months or 61 months,
respectively, after the initial startup of the boiler. Subsequent biennial or 5-year
tune-ups, as applicable, should be completed no later than 25 months or 61
months, respectively, after the previous tune-up.
llrai, e

SECTION IV: RECORD OF MANUFACTURER SPECIFICATIONS (§63.11225(c)(2))
If your boiler has manufacturer specifications for adjusting the flame patterns or optimizing total emissions of carbon monoxide,
maintain a copy of these specifications in your records.
SECTION V: RECORD OF FUEL TYPE AND AMOUNT USED OVER THE 12 MONTHS PRIOR TO THE TUNE-UP, BUT ONLY IF THE
BOILER WAS PHYSICALLY AND LEGALLY CAPABLE OF USING MORE THAN ONE TYPE OF FUEL DURING THAT PERIOD
(§63.11223(b)(6)(i ii))
Amount of fuel used or delivered for the 12 months preceding the tune-upe
Fuel Delivery Date
Typed Or Period of Units of
Consumption measuref
Green Pine chips, dust,
and bark.
[Add rows to the table for additional fuels, as necessary.]
If you have more than one boiler that must conduct a tune-up, please repeat Sections II, 111, IV, and V for each boiler.
Otherwise, proceed to Section VI below.
d Report all fuels used In each of the units subject to the standard(e.g.,bituminous coal,#6 fuel oil,#2 fuel oil,natural gas,bark,lumber, etc.).See the definition of fuel
type in §63.11237.
EPA recognizes that not all facilities have fuel metering capabilities.Records of fuel delivery-instead of fuel consumption-will also meet the rule requirements. Affected
sources have discretion on the periods of fuel records maintained on-site.The records may be annual,monthly,or periodic,depending on fuel delivery frequencies.
e.g.,Gallons,tons,standard cubic feet(scf),etc.
al ° . l; -

SECTION III: RECORD OF TUNE-UP PROCEDURES (§63.11225(c)(2)and (§63.11223(b)(6))
Check the applicable box when the procedure is completed. If the procedure does not apply to
you, indicate 'not applicable'or 'NA'in the comments column.
Requirement Description Inspector Comments/
Corrective Actions Taken
® Inspect the burners Clean or replace any components of the No Changes to burner. Fuel
burner, as necessary is fed by drag chain then
blown in.
® Inspect the flame Adjust the burner as necessary to Fuel piles up slightly just in
pattern optimize the flame pattern. The front of the fuel feed. Fairly
adjustment should be consistent with the even layer of fuel on top of
manufacturer's specifications, if available. the grates.
Inspect air-to-fuel ratio Ensure system is calibrated and Air to fuel system is
control system° functioning properly, if such a system is manually adjusted. All fans
installed on the boiler and drives are functioning
properly.
Optimize emissions of Optimize emissions consistent with the Combustion Analyzer was
carbon monoxide (CO) manufacturer's specifications, if available, used to adjust fans and fuel
and with any nitrogen oxide requirement to optimize CO.
to which the boiler is subject.
® Measure CO and 02 Parameter Before After Boiler adjusted to improve
levels in exhaust, Basis Dry 02 and CO
before and after tune- wet or d
UPC CO (ppmv) 480 1274
02 (% by volume) 14.7% 111.1%
''You may delay the inspection until the next scheduled unit shutdown,but you must inspect each burner at least once every 36
months if subject to biennial tune-ups,and at least once every 72 months if subject to 5-year tune-ups.
I Measurements may be made on either a dry or wet basis,as long as it is the same basis before and after the tune-up adjustments
are made.CO concentration measurements must be made in units of parts per million by volume(ppmv).Oxygen(Oz)
concentration measurements must be made as percent by volume.
31Pa � c

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BAAARWII, K.
PCA ;f 8At1h1Xrd:ll, Iw.
S11: 16OW76 PCA 3
---= SN: 16012176
mp: I1:2I:2:I AN
---------___
w1m: (15/13/20 1 im:: 12:52:30 I'M
Uaty: QSiIWO
Fuel
Ob FueI
01)
Oil 14.7 %
W 480 ppm Uu 11.1 %
Err 81.3 % CO Z74 ppm
(X)i 6.0 % Err 81.8 %
T-SU 244 F Cih 0.6 %
T-Air 80.0 E T-Stk :W F
EA 233.3 % T-Air 115.0 f
(11(0) IN-3 ppm I•:A 111.2 %
NO u: ppm (m(0) rm ppm
NOi ` ppm NO ppm
NDx ppm NO. ppm
SOe : ppm NUx ppm
110(0) ,c}3 ppm SW ppm
1101(0) ppm 110101 ppm
NUx(0) ` ppm 11Oi10) : . ppm
S0:(0) r: ppm NOx(0) ppm
SO.(0) ppm
tbmmcni.s: -------
G,mm:nla:

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The first Compliance Certification Report (Section VI of this form) must be
prepared by March 1 of the year following the calendar year during which the first
biennial or 5-year tune-up is completed. Later certifications must be prepared by
March 1 of the year following the calendar year during which a biennial or 5-year
tune-up is completed.
Where do I send this form (§63.11225(b))?
This certification does not need to be submitted, but it must be maintained on site as a record and
may be requested by the delegated authority.
SECTION II: RECORD OF GENERAL BOILER INFORMATION
Date: 5/13/2020
Reporting Period:
Boiler Operator:_ Mike Rouse
Boiler Emission Unit IDa: 1951 CE Boiler#1
Tune-Up Conducted By: Stephen McAdams, Joe Moore and Company, Inc. _
Please Print
'Use the boiler emission unit ID consistent with the ID provided in the Initial Notification Report.
21Pi , c