AQ_F_0400058_20160413_CMPL_NOV

PAT MCCRORY
Governor
N'ro
DONALD R. VAN DER VAART
secremry
AirQua(ity SHEILA C. HOLMAN
ENVIRONMENTAL QUALITY Dneelor
13 April 2016
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Mr. J. Lynn Green,Director of Human Resources
Edwards Wood Products, Inc.
160 Pulpwood Yard Rd.
Peachland,NC 28133
SUBJECT: Notice of Violation
N.C.G.S.143-215.108 Control of Sources of Air Pollution; Permits Required
15A NCAC 2D .1100 Toxic Air Pollutant Emissions Limitations and Reporting
Edwards Wood Products Inc.—Peachland, Air Permit No. 10146/ROI
Peachland,North Carolina,Anson County 06/0400058
Fee Class: Small
Dear Mr. Green:
On 8 March 2016, Mike Thomas conducted a compliance inspection at your facility,
Edwards Wood Products, Inc- Peachland. During this inspection he discovered that the facility has
removed two (2) permitted 28,000 board foot capacity kilns and replaced them with two (2) 40,000
board foot high temperature kilns. North Carolina General Statute 143-215.108(a) provides that no
person shall do any of the following things unless that person has obtained a permit for the activity
from the Commission and has complied with any conditions of the permit:
1. Establish or operate any air contaminant source [143-215.108(a)(1)];
2. Build, erect, use, or operate any equipment that may result in the emission of an air
contaminant or that is likely to cause air pollution [143-215.108(a)(2)];
3. Alter or change the construction or method of operation of any equipment or process
from which air contaminants are or may be emitted [143-215.108(a)(3)].
Your facility installed and began operation of two (2) new air contaminant sources (the two
high temperature kilns) without first obtaining a permit, in violation of N.C.G.S. 143-215.108(a)(1)
and (2), and as specified in General Condition B.4 of your air permit.
Records also showed that the total amount of wood combusted by the facility in 2015 was
7,169 tons. Stipulation A.10, 15A NCAC 2D .1100 "Control of Toxic Air Pollutants," in your
current permit limits the allowable amount of wood combusted to 3,030 tons annually, in order to
remain compliant with the air toxics compliance modeling demonstration submitted and previously
approved by the Division. Your facility combusted more than double the permit allowable amount of
wood in 2015, and you are thus in violation of a permit limitation.
State orNRrth Carolina I Environmental Quality I Air Quality
Fayetteville Regional Office 1 225 Green Street,Suite 714 1 Fayetteville,NC 28301
910 433 3300 T 1 910 485 7467 F

Edwards Wood Products, Inc. —Peachland
13 April 2016
Page 2
As stated in the "subject" above, this letter represents a Notice of Violation for the cited
violations. These violations, and any future violation(s) of an air quality regulation are subject to the
assessment of civil penalties according to North Carolina General Statute 143-215.114A. In
addition, each day of continuing violation after written notification from the Division of Air Quality
shall be considered a separate offense.
Please provide to this office as soon as possible, but no later than 29 April 2016, a written
response to this Notice of Violation, detailing the reasons for the failure to obtain an air permit for
these new air emission sources and for exceeding the wood combustion limit in your current air
permit. The response should outline the steps that you plan to take or have taken to return to
i compliance, and should include any additional information or description of any mitigating
circumstances in reference to the violation. The response should also include a completed,signed
application for an air permit modification. Please contact Greg Reeves, Permits Coordinator,
at [phone], to discuss additional information needed regarding permitting of toxic air
pollutant emissions. Permit application forms and instructions can be found on the DAQ website at:
https:Hdeq.nc.gov/about/divisions/air-qualit /y air-quality-permits/application-forms-
instructi ons/appl ication-forms-air-qual itypermit-construct-operate-non-title-v-title-v-facilities
The Division strongly recommends that you carefully examine your current permit
stipulations. We appreciate your prompt attention to this matter. If you have any questions
regarding the cited violations, please contact Mike Thomas, Environmental Specialist, or Heather
Carter, Compliance Coordinator, at(910) 433-3300.
I
Sin ere
Steven F. Vozzo
Regional Air Quality Supervisor
NCDEQ, Division of Air Quality
SFV\mst
cc: FRO Facility Files