AQ_F_0400058_20170119_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: 01/312017
-Facility Data Permit Data
Edwards Wood Products,Inc.-Peachland Permit 10146/R02
160 Pulpwood Yard Road Issued 6/23/2016
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
NAICS: 321113/Sawmills Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Robbie Fincher 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
[phone] [phone]
Compliance Data
Comments:
Inspection Date O1/192017
Inspector's Name Mike Thomas
Inspector's Signature: Operating Status Operating
�1/�.� Compliance Code Compliance-inspection
jb/ Action Code FCE
Date f Signature: g/ y�C/� On-Site Inspection Result Compliance
/-3/-iix-
Total Actual emissions in TONS/YEAR:
TSP SO2 NOS VOC CO PMIO *HAP
2015 7.65 0.8100 7.10 1.78 19.36 7.00 1226.00
*Highest HAP Emitted(inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
04/132016 NOV NC General Statutes NCGS 143-215.108 Control of 0623/2016
sources of air pollution;permits required.
04/132016 NOV 2D.1100 Control of Toxic Air Pollutants 06232016
Performed Stack Tests since last FCE:None
Date Test Results Test Methodist Source(s)Tested
1) Location/Directions:
Edwards Wood Products Inc.-Peachland is located at 160 Pulpwood Yard Road,west of Peachland,NC in
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 Mr.Fincher is not at the boiler building then you will need
to call him 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.

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. 10146R01,effective from 23 June 2016 until 31 May 2016.The facility was last
inspected by Mike Thomas on 8 March 2016,
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 woad-fired boiler using self-generated sawdust
from the sawmill at this facility.
4) Permitted Emission Sources
Emission I Emission Source r Control Control Syste;
Source ID Description I System ID Description'
Stoker type wood-fired Boiler
( ES-1 ) 10.54 million Btu per how maximum heat input(300 � Multi-cylone with 8
NSPS,NES}IAP BHP) CD-MC] nine inch diameter
Operating with 0%V.E. tubes
Four 62,steam-heated lumber drying kilns
ES-2 62,000 board feet capacity each N/A F N/A
Operating with 0%V.E.
ES-3
Two(2)steam heated lumber drying kilns ��
ES-3 28,000 board feet capacity each N/A N/A
Operating with 0%V.E.
Two(2)steam-heated lumber drying kilns
ES-4 62,000 board feet capacity each N/A N/A
� ___ Operating with0%V.E.
Insignificant/Exempt Activities:
IES-1
Band sawmill for green lumber,inside F2Q.0102(cx2)(E)(i) No Yes
building_
IES-2
Circular saw mill for green lumber, inside 2Q.0102(cx2)(E)(i) No Yes
building
5) Inspection Conference:
On 19 January 2017 I,Mike Thomas of FRO DAQ conducted a compliance inspection of The Edwards Wood
Peachland Plant. Mr.Robbie Fincheq Drying Manager and Facility Contact was not available during the
inspection. A member of the maintenance staff gave me access to see the boiler and the emission point. I
later spoke with Mr.Fincher and had him provide me with copies of the latest maintenance records and total
amounts of wood combusted via email.

a) The facility's boiler is subject to the tune-up requirements set forth in Subpart JJJJJJ. The facility
complied with the initial tune-up date and subsequently has a tune-up due in April 2016. Mr.Fincher
stated that the tune-up was conducted on 14 March 2016. In addition,Mr. Fincher stated that the facility
continues to do weekly maintenance on the boiler as well as more in depth maintenance every three
months.
b) I inquired via email,as to how the facility determined how many tons of wood is getting fired in the boiler
daily. Mr. Fincher explained that the facility took 10 samples of material collected from a single turn of
the screw conveyor and averaged that weight in pounds,divided that amount by 2000 to get tons and came
up with a multiplier of 0.0026. The facility tracks how many times the screw tutus in 24 hours.The
number of turns in 24 hours times 0.0026 equals the firing rate in tonsthour.
c) Throu h uts:
Year 12 Mouth Consecutive Tons Combusted
2016 7,459.3 Tons of Wood
2015 7,169 Tons of Wood
2014 —1,100 Tons of Wood
2013 982 Tons of Wood
6) Inspection Tour:
Due to Mr. Fincher not being available I only observed the wood boiler(ES-1),the wood storage area,and the
emissions point. I also observed the kilns. I observed no problems in these areas.
7) Permit Stipulations:
a) A.2 2Q.0304 PERMIT RENEWAL AND EMISSIONINVENTORY REQUIREMENT-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.
b) A.32D.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 bums wood in ES-1. The AP-42 factor for
particulates from wood is 0.347 lbs/mmBTU,which is below the maximum allowable.
c) AA 2D M 15 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
operations since that determination.
d) A.5 2D .0516-SULFUR DIOXIDE EMISSIONS FROM COMBUSTIONSOURCES. Emissionsof
sulfur dioxide from Boiler BI shall not exceed 2.3 Ibs/mmBtu.
Appeared to be in Compliance—The facility combusts only wood,and the AP-42 emissions factor for
SO2 for wood combustion is 0.025 Ibs/mmBm. As long as the facility only combusts wood,compliance
is expected.
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-1 observed 0%V.E.coming from the boiler.

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. 2016 total amount of
wood burned was 7,459.3 tons.
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.
Appeared to be in Compliance—The facility has bad no exceedances,breakdowns,or abnormal
conditions requiring notification according to Mr.Fincher.
h) A.9 2D.0540 FUGITIVE DUST CONTROL REQUIREMENT-Pernittee shall not cause or allow
fugitive dust emissions to contribute to complaints or excess VE beyond the property boundary.
Appeared to be in Compliance-I observed no excess dust from the roads. Mr. Fincher stated there
have never been any complaints.
i) A.10 21) .1100 TOXICAIR 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
1.17 tons/Ir,not exceeding 10,258.9 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 7,459.3 tons of wood burned during
2016 which is below 10,258.9 tons per year maximum. A review of the daily entries for tons of wood
burned indicated that the facility was exceeding the 1.17 tons/hour limit stipulated in the permit(which
is not possible based on the size of the boiler). Further discussion with Mr.Fincher revealed that no
one records daily screw tarn numbers on the weekends and other shutdown periods. Their normal
practice is to make one entry for the shutdown period when they return to operation,resulting in a
single day total that was actually several days instead of one. Mr.Fincher went on to say that he does
not think that the employee tasked with recording the screw tam numbers daily is doing it at the same
time every day. He may record readings at 6:30 one day and 11:30 the next day. This scenario can
result in skewed data for several days. Heather Carter stressed the importance of the data recording
being accurate and offered suggestions to accomplish that. Mr. Fincher stated that he was going to
look into ways to improve their methods. Based on the information provided it does not appear that
the facility is exceeding the hourly firing rate limit. The hourly firing rate data will be reevaluated in
six months.
j) A.I 1 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 at the time of inspection. The facility's 2015 Biennial Compliance Certification was on
file in Mr. Green's office in Marshville.

k) A.12 2D .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.Fincher stated that he was unaware of any complaints related to odors.
1) A.132Q.0711 TOXICAIR POLLUTANTEMISSIONSLIMITATIONREQUIREMENT—The
Permittee shall operate and maintain facility emissions of the listed TAP,Cadmium, so as not to exceed
0.37 Ibs/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.
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.
3) Comments and Compliance Statement
Edwards Wood Products Inc. Peachland appeared to be in compliance with the conditions stipulated in their
current air permit on 19 January 2017.
Pink Sheet: Plan to discuss improvements in record keeping in 3 months and re-inspect in 6 months.
/mst