AQ_F_0400058_20180130_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Edwards Wood Products,Inc.-Peachland
NC Facility ID 0400058
Inspection Report County/FIPS:Anson/007
Date: 02/07/2018
Facility Data Permit Data
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Edwards Wood Products,Inc. -Peachland Permit 10146/R03
160 Pulpwood Yard Road Issued 11/29/2017
1 Peachland,NC 28133 Expires 5/31/2024
. Lat: 34d 59.5500m Long: 80d 17.7000m Classification Small
SIC: 2421 /Sawmills&Planing Mills General Permit Status Active
'! NAILS: 321113/Sawmills Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Travis York J.Lynn Greene J.Lynn Greene
MACT Part 63: Subpart 6J
Drying Manager Director of Human Director of Human NSPS: Subpart Dc
[phone] Resources Resources
r [phone] [phone]
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k Compliance Data
Comments:
Inspection Date 01/30/2018
Inspector's Name Mike Thomas
Inspector's Signature: Operating Status Operating
Compliance Code Compliance inspection
Action Code FCE
- Date Poi Signature: On-Site Inspection Result Compliance
4 Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2015 7.65 0.8100 7.10 1.78 19.36 7.00 1226.00
*Highest HAP Emitted in pounds
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Five Year Violation History:
!: Date Letter Type Rule Violated Violation Resolution Date
04/13/2016 NOV NC General Statutes NCGS 143-215.108 Control of 06/23/2016
sources of air pollution;permits required.
f 04/13/2016 NOV 2D.1100 Control of Toxic Air Pollutants 06/23/2016
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
1) Location/Directions:
Edwards Wood Products Inc. -Peachland is located at 160 Pulpwood Yard Road,west of Peachland,NC in
I Anson County. From Wadesboro,take HWY 74 west for 13.5 miles. Pulpwood Yard Road will be on the
► right and runs into the Edwards Wood facility. If no one is in the boiler building then you will need to call the
facility contact at the Marshville office(phone number above)and have him meet you there. The Marshville
office is only a few minutes away from the Peachland facility.
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2) Safety Considerations: Standard DAQ safety equipment.Watch for lumber trucks on facility roads and
forklifts in kiln and warehouse areas.
3) Facility and Process Description
Edwards Wood Products,Inc. is a hardwood sawmill and lumber drying kiln facility.This facility is permitted
under Air Permit No. 10146R03,effective from 29 November 2017 until 31 May 2024.The facility was
last inspected by Mike Thomas on 19 January 2017.
Edwards Wood Products,Inc.produces rough-cut green and kiln-dried hardwood lumber.No finished
lumber is produced at this facility. Green hardwood logs are brought to the facility by truck,the logs are
debarked,and then sawn into green dimension lumber. Some of the green lumber is dried in eight(8)steam-
heated lumber drying kilns. Steam is provided by a small wet wood-fired boiler using self-generated sawdust
from the sawmill at this facility.
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4 Permitted Emission Sources
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Stoker type wood-fired Boiler Multi-cylone with 8
ES-1 10.54 million Btu per hour maximum heat input(300 CD-MCI nine inch diameter
(NSPS,NESHAP) BHP) tubes a
Operating with 0%V.E.
Four(4)steam-heated lumber drying kilns
ES-2 62,000 board feet capacity each F N/A N/A =
Operating with 0%V.E.
Two(2)steam-heated lumber drying kilns
ES-3 28,000 board feet capacity each N/A N/A
Operating with 0%V.E.
.....
_......
. .......
.. . _____.._ .._......_. .._ _.._.._ _._ .. _..... .._...n..
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Two(2)steam-heated lumber drying kilns
ES-4 62,000 board feet capacity each FN/A N/A
Operating with 0%V.E.
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Insi2nificant/Exem t Activities r
IES-1
[Band saw mill for green lumber,inside 2Q.0102(c)(2)(E)(i) No Yes
building
IES-2
[Circular saw mill for green lumber,inside 2Q.0102(c)(2)(E)(i) No Yes
building
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5) Inspection Conference:
On 30 January 2018 I,Mike Thomas of FRO DAQ conducted a compliance inspection of The Edwards Wood
Products,Inc. -Peachland Plant. Upon arrival,I found no one in the boiler building or in the vicinity. I
called the office and was informed that Robbie Fincher no longer works at the facility. I was transferred to a
Mr.York's phone number but had to leave a voicemail. I waited for approximately thirty minutes without
hearing from Mr.York. I proceeded to view the visible emissions from the boiler and from the kilns,which I
could do from the location where I was waiting.
r.

On 7 February 2017,I received a call from the facility's new Drying Manager,Travis York. Mr. York
emailed me a copy of the daily wood log from 2017,which showed the facility to be in compliance in regards
to firing rates and yearly total wood combusted. I was also able to ask Mr.York about any dust or odor
complaints that the facility may have received.
a) Throughputs.
Year 12 Month Consecutive Tons Combusted
2017 6,485.8
2016 7,459.3
2015 7,169
2014 —1,100
2013 982
6) Permit Stipulations:
a) A.2 2Q .0304 PERMIT RENEWAL AND EMISSIONINVENTORYREQUIREMENT—Entire
facility subject. Submit permit renewal application and EI at least 90 days prior to permit expiration.
Appeared to be in compliance—The facility was due to submit their EI and Permit Renewal by 1
April 2016. Both the EI and Permit Renewal were received on 1 April 2016. The facility's current air
permit expires on 31 May 2024.
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b) A.3 2D .0504 PARTICULATE CONTROL REQUIREMENT—"Particulates from Wood Burning
Indirect Heat Exchangers"-Particulate matter emissions shall not exceed 0.41 Ibs/mmBTU.
Appeared to be in compliance—The facility only burns wood in ES-1. The AP-42 factor for
particulates from wood is 0.347 Ibs/mmBTU,which is below the maximum allowable.
c) A.4 213.0515 PARTICULATE CONTROL REQUIREMENT—"Particulates from Miscellaneous
Industrial Processes"—Particulate matter emissions shall not exceed allowable emissions rates.
Appeared to be in compliance—Compliance was determined during the most recent permit review
based on operating the source as described in the permit conditions. No changes have been made to
p operations since that determination.
d) A.5 213 .0516 -SULFUR DIOXIDE EMISSIONS FROM COMBUSTIONSOURCES. Emissions of
sulfur dioxide from Boiler B 1 shall not exceed 2.3 lbs/mmBtu.
Appeared to be in Compliance-The facility combusts only wood, and the AP-42 emissions factor for
G S02 for wood combustion is 0.025 Ibs/mmBtu. As long as the facility only combusts wood, compliance
is expected.
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e) A.6 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT—Visible emissions from the
emission sources shall not be more than 20% in opacity.
Appeared to be in compliance—I observed 0%V.E. coming from the boiler and from the kilns.
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f) A.7 2D .0524 NEW SOURCE PERFORMANCE STANDARDS—For the wood-fired boiler,the
Permittee shall notify the Regional Supervisor,DAQ, in writing of the actual start up date of an affected
source,within 15 days after such date,keep monthly and total annually: amount of wood, in tons,
combusted each calendar day and retain those records for at least 2 years.
Appeared to be in compliance—Initial notification was received on 7 September 2011. Facility keeps
detailed records of the amount of wood burned daily,monthly and total annually. 2017 total amount of
wood burned was 6,485.8 tons.
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g) A.8 2D .0535 NOTIFICATION REQUIREMENT- The facility is required to notify DAQ if excess
emissions occur for more than a 4-hour period caused by a breakdown or other abnormal condition.
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Appeared to be in Compliance—The facility has had no exceedances,breakdowns, or abnormal
conditions requiring notification according to Mr.York.
h) A.9 213 .0540 FUGITIVE DUST CONTROL REQUIREMENT—Permittee shall not cause or allow {
fugitive dust emissions to contribute to complaints or excess VE beyond the property boundary. 1
Appeared to be in Compliance-I observed no excess dust from the roads. Mr.York stated there have
not been any complaints.
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i) A.10 21) .110 0 TOXIC AIR POLLUTANT EMISSIONS LIMITATIONAND REPORTING
REQUIREMENT—Toxic limitations apply to Arsenic(.60 lbs/yr),Benzene(300 lbs/yr),Chromium(.15
lbs/yr),Formaldehyde(.0464 lbs/hr), and Hydrogen chloride(.20 lbs/hr). Combusted wood is limited to
4.68 tons/hr,not exceeding 41,000 tons per consecutive 12-month period. Records shall be kept
demonstrating compliance for these limits.
Appeared to be in Compliance— The log book shows a total of 6,485.8 tons of wood burned during
2017 which is below 41,000 tons per year maximum. The facility maintains a log of daily wood
burned to document compliance with this condition.
j) A.11 2D .1111 GENERAL AVAILABLE CONTROL TECHNOLOGY— "Subpart JJJJJJ,NESHAP
Industrial,Commercial and Institutional Boilers at Area Sources"-initial notification,biennial tune-
ups beginning 21 Mar 2014,NOCS,one-time energy assessment by 21 March 2014(with notice of
compliance by 19 July 2014),records of biennial compliance report(beginning 1 Mar 15 -submitted
only if deviation or DAQ request)and pertinent maintenance(since 21 Mar 2014).
Appeared to be in Compliance-Initial notification was received in FRO on 7 September 2011;
facility conducted the energy assessment in February of 2012 and the last annual tune-up was
conducted in March 2016. NOCS was received via CEDRI on time. The Notice of Compliance Status
was available during my previous inspection. The facility's 2015 Biennial Compliance Certification
was on file in Mr. Green's office in Marshville.I was unable to verify if the facility has completed the
2017 Biennial Compliance Certification, due to not actually being able to meet with anyone during this
inspection.
k) A.12 21) .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—There shall be no
odorous emissions from facility that causes or contributes to objectionable odors beyond the facility's
boundary.
Appeared to be in Compliance—I detected no objectionable odors within or beyond the facility's
property. Mr.York stated that he was unaware of any complaints related to odors.
1) A.13 2Q .0711 TOXICAIR POLLUTANT EMISSIONS LIMITATIONREQUIREMENT—The
Permittee shall operate and maintain facility emissions of the listed TAP,Cadmium, so as not to exceed
0.371bs/yr.
Appeared to be in Compliance—Compliance was determined during the most recent permit review
based on operating the source as described in the permit conditions. No changes have been made to
operations since that determination.
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1) 112R Status
This facility does not store chemical compounds that require a written risk management plan
under the Clean Air Act, Section 112R.
2) Non-compliance History Since 2010
13 April 2016—Operation without a permit and exceeding limits.

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3) Comments and Compliance Statement
Edwards Wood Products Inc. Peachland appeared to be in compliance with the in their current air permit on
30 January 2018.
Pink Sheet:None.
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