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HomeMy WebLinkAboutAQ_F_0400058_20150820_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: 08/25/2015 Facility Data Permit Data Edwards Wood Products,Inc. -Peachland Permit 10146/ROl 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)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Robbie Fincher J.Lynn Greene J.Lynn Greene MALT Part Subpart 6J Drying Manager Director of Human Director of Human NSPS: Subpart Dc (704)624-5098 Resources Resources (704)624-5098 (704)624-5098 Compliance Data Comments: Inspection Date 08/20/2015 / Inspector's Name Mike Thomas Inspector, ig ture: Operating a Cod Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: P zs�S On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP No emissions inventory on record.The emissions inventory is due 04/01/2016. Highest HAP Emitted(in pounds) 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 Edwards Wood Products Inc. -Peachland is located at 160 Pulpwood Yard Road,west of Peachland,NC in Anson County. Directions 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. Safety Considerations: Standard DAQ safety equipment.Watch for lumber trucks on haul roads and forklifts in kiln and warehouse areas. 2) 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 7 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. a) Permitted Sources Stoker type wood-fired Boiler ES-1 10.54 million Btu per hour maximum heat input (NSPS,NESHAP) (300 BHP) Observed operating with 5%V.E. Four(4)steam-heated lumber drying kilns N/A j ES-2 62,000 board feet capacity each Observed operating Four(4)steam-heated lumber drying kilns ES-3 28,000 board feet capacity each Observed operating b) Insignificant/Exempt Activities hPIVP 1' IES-1 Band saw mill for green lumber, inside F2Q .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 c) Throughputs for 2014 Employees: 62 (same as in 2013) Hours: 7:OOAM—3:30 PM Production: —520 tons Jan-August(982.22 tons for 2013) 3) Inspection Conference On 20 August 2015, I Mike Thomas of FRO DAQ,met with Robbie Fincher,Drying Manager, We discussed the following: a) Verified the FACFINDER information;No changes required. b) I reviewed the daily log that is kept for measuring their wood combustion. Mr.Fincher keeps a written log that is kept in the boiler area, and an electronic log is also kept that includes gross weight,tare weight,net weight, and boiler saw dust loading rate(lbs/hr). All entries were up to date and complete. 4) Inspection Summary Mr. Fincher led me on a tour of the facility,which was operating.I verified the specifications of the boiler ES-1. I also observed the automated fuel loading system for the boiler. This system consists of vibrating conveyor that brings sawdust from the other parts of the plant to the boiler. Sawdust is then conveyed into the fire box automatically. The boiler was being fired at a rate of 5500 lbs/hr of steam production during this inspection. The boiler provides heat for 8 steam heated lumber kilns ES—2 and ES—3. I observed no problems with the boiler system. V.E.was 5%. Mr. Fincher showed me the band saw mill and the circular saw mill, which are listed as insignificant sources. I saw no problems with these sources. 5) Permit Stipulations a) A.3 2D .0504 PARTICULATE CONTROL REQUIREMENT—"Particulates from Wood Burning Indirect Heat Exchangers"-Particulate matter emissions shall not exceed 0.41 lbs/mmBTU. Appears to be in compliance—The AP-42 factor for particulates from wood is 0.347 lbs/mmBTU, which is below the maximum allowable. b) AA 2D .0515 PARTICULATE CONTROL REQUIREMENT—"Particulates from Miscellaneous Industrial Processes"—Particulate matter emissions shall not exceed>30 tons/hr. Appears to be in compliance—Latest permit review shows compliance. c) A.5 2D.0516 SULFUR DIOXIDE CONTROL REQUIREMENT—Sulfur Dioxide emissions from wood-fired boiler shall not exceed 2.3 lbs/mmBTU. Appears 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,which is well below the maximum allowable. d) A.6 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT—Visible emissions from the emission sources shall not be more than 20% in opacity. Appears to be in compliance—I did not observe any emissions>20% in opacity. c) A.7 2D .0524 NEW SOURCE PERFORMANCE STANDARDS—For the wood-fired boiler,the Permittee shall comply with notification,testing,reporting,recordkeeping and monitoring requirements. Appears to be in compliance—Initial notification was received on 7 September 2011. Facility keeps detailed records of the amount of wood burned monthly and total annually. Year to date wood total is 520 tons. 2014 total amount of wood burned was 825 tons. d) 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. Appears to be in compliance —The facility has had no exceedances, breakdowns, or abnormal conditions requiring notification. e) A.9 2D .0540 FUGITIVE DUST CONTROL REQUIREMENT—The Permittee shall not cause or allow fugitive dust emissions to cause or contribute to complaints or excess visible emissions beyond the property boundary. Appears to be in compliance—I did not observe any excess fugitive dust emissions within or beyond the facility's property line. t) A.10 2D .1100 TOXICAIR POLLUTANTEMISSIONSLIMITATIONAND REPORTING REQUIREMENT—Toxic limitations apply to Arsenic(.60 lbs/yr), Benzene(300 lbs/yr), Chromium (.15 lbs/yr),Formaldehyde(.0464 lbs/yr), and Hydrogen chloride (.20 lbs/yr). 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. Appears to be in compliance—An air dispersion modeling analysis was conducted on 6 June 2011, which showed compliance with the applicable ambient air limits(AALs)for the mentioned pollutants at the facility's property boundaries.According to the logbook,the facility is burning 2.75 tons of wood a day(0.11 tons/hour)which is well below the permitted limit of 1.17 tons per hour. The facility maintains a record of daily wood consumption as well as monthly totals for the previous 12 months. g) A.11 2D .1111 NESHAP Subpart JJJJJJ—The Permittee shall comply will all applicable provisions, including notification,testing and monitoring requirements; includes boiler tune-up by 21 March 2012 and biennial thereafter(with notice of compliance by 19 July 2012), one time energy assessment by 21 March 2014 (with notice of compliance by 19 July 2014). Appears to be in compliance—Initial response to 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. h) 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. Appears to be in compliance—I detected no objectionable odors within or beyond the facility's property. i) A.13 2Q .0711 TOXICAIR POLL UTANT EMISSIONS LIMITATIONREQUIREMENT—The Permittee shall operate and maintain facility emissions of the listed TAP, Cadmium, so as not to exceed 0.37 lbs/yr. Appears to be in compliance—Latest permit review demonstrates compliance (Cadmium has the potential to exceed TPER of 0.37 lbs/yr, although the expected actual emissions are below the TPER and do not require modeling). The process has not been changed since the permit review. 6) 112R Status This facility neither uses nor stores chemical compounds that require a written risk management plan under the Clean Air Act, Section 112R. 7) Non-compliance History Since 2010 a) 25 February 2011 —Operation without a permit 8) Comments and Compliance Statement Edwards Wood Products Inc.Peachland appeared to be in compliance on 20 August 2015. Pink Sheet: No comments. /mst