AQ_F_0400058_20160308_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: 05/16/2016
Facility Data Permit Data
Edwards Wood Products, Inc. -Peachland Permit 10146/RO1
160 Pulpwood Yard Road Issued 9/27/2012
Peachland,NC 28133 Expires 6/30/2016
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)Modification
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Robbie Fincher J.Lynn Greene J.Lynn Greene MACT Part Subpart 6J
Drying Manager Director of Human Director of Human NSPS: Subpart
Dc
[phone] Resources Resources
[phone] [phone]
Compliance Data
Comments:
Inspection Date 03/08/2016
Inspector's Name Mike Thomas
Inspector's Si ature: ( (O Operating Status Operating
r� ry C Compliance Code Violation-emissions
AAAA Action Code FCE
Vatic&Signature: On-Site Inspection Result Violation
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 inpounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
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
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 27 September 2012 until 30 June 2016.The facility was
last inspected by Mike Thomas on 20 August 2014.
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.
4) Permitted Emission Sources:
Stoker type wood-fired Boiler
ES-1 10.54 million Btu per hour maximum heat input
(NSPS,NESRAP) (300 BHP) j
Observed operating with 5%V.E.
Four(4)steam-heated lumber drying kilns
ES-2 62,000 board feet capacity each N/A
Observed operating
Four(4)steam-heated lumber drying kilns
ES-3 28,000 board feet capacity each
Observed operating
j
Insignificant/Exempt Activities:
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
5) Inspection Conference:
On 8 March 2016 I,Mike Thomas of FRO DAQ conducted a compliance inspection of The Edwards Wood
Peachland Plant. I met with Mr.Robbie Fincher,Drying Manager. We discussed the following:
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 is already scheduled to be 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 about the specific wood types that the facility uses to fire the boiler. Mr. Fincher stated that they
typically prefer to use sap gum wood but in the last few months they had been using more hardwoods like
hickory and oak due to it being too wet to harvest sap gum. Most recently the facility has been using red
oak. The saw dust is obtained as the waste product from the production done at the facility. They will
occasionally receive woodwaste from other Edward's facilities. I collected a representative sample.
c) I observed Mr. Fincher's logbook which contained daily, weekly, and monthly totals of wood burned in
the boiler.
d) I also spoke to Lynn Green,Director of Human Resources, who is also the Corporate Environmental
Officer for Edwards Wood. Mr. Green stated that the facility was planning on using the services of Mr.
Kermit Horne,an outside contractor,to handle their emissions inventory and permit renewal.
e) Throughputs:
2015 7,169 Tons of Wood
2014 —1,100 Tons of Wood
2013 982 Tons of Wood
6) Inspection Tour:
Mr. Fincher led me on a tour of the boiler facility,which was operating. We started with the area where the
woodwaste is stored before being used in the boiler. This area is a three sided building with a roof.
Woodwaste is piled inside the building and is fed into the system that feeds the boiler. Woodwaste was also
piled outside of the building during my inspection. This material is very damp and too heavy to blow around
very much. We then went inside the boiler building where I observed the automated fuel feeding system. I
verified the specifications on the manufacturing plate match the specs detailed in the permit. I also observed
ES-2 and ES-3
Mr. Fincher took me to observe IES-1 and IES-2,the band saw and circular saw operations. I observed no
issues with either of these operations.
7) Permit Stipulations:
a) A.2 2Q .0304 PERMIT RENEWAL AND EMISSION INVENTOR Y 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 is due to submit their EI and Permit Renewal by 1 April
2016. Neither have been received to date but according to Mr. Green they are being worked on.
b) A.3 2D .0504 PARTICULATE CONTROL REQUIREMENT—"articulates from Wood Burning
Indirect Heat Exchangers"-Particulate matter emissions shall not exceed 0.41 lbs/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 lbs/mmBTU,which is below the maximum allowable.
c) A.4 2D .0515 PARTICULATE CONTROL REQUIREMENT—"Particulates from Miscellaneous
Industrial Processes"—Particulate matter emissions shall not exceed>30 tons/hr.
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.5 213 .0516-SULFUR DIOXIDE EMISSIONS FROM COMBUSTIONSOURCES. Emissions of
sulfur dioxide from Boiler B1 shall not exceed 2.3 lbs/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 lbs/mmBtu. As long as the facility only combusts wood, compliance
is expected. This source was not operating during the inspection.
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 5%V.E. coming from the boiler.
f) A.7 213 .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 l
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. Year to date wood total
is 717 tons. 2015 total amount of wood burned was 7,169 tons.
g) A.8 213 .0535 NOTIFICATIONREQUIREMENT- 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 had no exceedances,breakdowns, or abnormal
conditions requiring notification according to Mr. Fincher.
h) A.9 2D .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.
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 2D .1100 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
1.17 tons/hr,not exceeding 3,030 tons per consecutive 12-month period. Records shall be kept
demonstrating compliance for these limits.
Appeared to be in Violation— The log book shows a total of 7,169 tons of wood burned during
2015. This is double the permitted amount of 3,030 tons. When I inquired about the increase,Mr.
Fincher stated that it was due to the two new high temperature kilns the facility added in 2014. I
clarified with Mr. Fincher that the facility had replaced two of the existing kilns with the high
temperature models as opposed to adding an additional two kilns at the facility. Mr.Fincher stated
that he did not know if a permit modification had been obtained but he would contact Mr. Lynn Green,
Edwards Wood's Corporate Environmental Officer to find out to date I have not received an answer).
Pollutant Limit Ibs/ r Actual Ibs/ r Limit Ibs/hr Actual Ibs/hr
Arsenic 0.60 1.419
Benzene 300 270.988
Chromium 0.15 1.129
Formaldehyde 0.0464 0.0464
Hydrogen Chloride 0.20 0.20
The numbers above were calculated using the DAQ wood combustion spreadsheet.
j) A.11 2D .11 I 1 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 malfunction 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 tune-up was conducted in
February 2015. NOCS was received via CEDRI on time. The Notice of Compliance Status was
available at the time of inspection. The facility's Biennial Compliance Certification was on file in Mr.
Green's office in Marshville. The next annual tune-up is scheduled for 14 March 2016.
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. Fincher 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
0.37 lbs/yr.
Appeared to be in Violation—Based on the 7,169 tons of wood burned in 2015 the actual Cadmium
emissions were 0.47 lbs/yr.
8) 112R Status
This facility neither uses nor stores chemical compounds that require a written risk management plan
under the Clean Air Act, Section 112R.
9) Non-compliance History Since 2010
25 February 2011 —Operation without a permit
10) Comments and Compliance Statement
Edwards Wood Products Inc. Peachland Appeared to be in Violation on 8 March 2016. This is based on
exceeding permitted limits of total wood combusted and toxic air pollutants (21) .1100 and 2Q .0711). I
recommend sending a notice of violation for exceeding permitted limits.
Pink Sheet:No comments.
/mst
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