AQ_F_0400058_20140807_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: 08/19/2014
Facility Data Permit Data
Edwards Wood Products,Inc. -Peachland Permit 10146/R01
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 LDireetor
uthorized Contact Technical Contact SIP
Robbie Fincher nn Greene J.Lynn Greene MACT Part rt Subpart 6J
Drying Manager of Human Director of Human NSPS: Subpart Dc
[phone] urces Resources
)624-5098 [phone]
Compliance Data
Comments:
Inspection Date 08/07/2014
Inspector's Name Mike Thomas
Inspector's Si at re: Operating Status Operating
�9 �9 Pl,✓i Compliance Code Compliance-inspection
\� Action Code FCE
Date of Signature: On-Site Inspection Result Compliance
-1, —/
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 6 August 2013.
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.
IF Four(4)steam-heated lumber drying kilns i N/A
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) 7nsrgnificant/Exemp4Activities
IES-1
Band saw mill for green lumber,inside 2Q .0102(c)(2)(E)(i) T No f Yes
building --jr _
IES-2
Circular saw mill for green lumber, inside 2Q .0102(c)(2)(E)(i) No Yes
building
c) Throughputs for 2013
Employees: 62(same as in 2012)
Hours: 7:OOAM—3:30 PM
Production: —498.8 tons Jan-August(982.22 tons for 2013)

3) Inspection Conference
On 7 August 20141 I Mike Thomas of FRO DAQ, met with Lynn Green, Director of Human Resources and
Robbie Fincher,Drying Manager, We discussed the following:
a) Verified the FACFINDER information;Robbie Fincher has replaced Mr. Green as the facility contact.
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).
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. This system was added a couple of years ago. Mr.Fincher said that being able to
control the flow of sawdust continually has greatly increased the efficiency of the boiler operations and
emissions. The boiler was being fired at a rate of 5500 lbs/hr 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%.
I also observed 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 .041 lbs/mmBTU.
Appears to be in compliance—The AP-42 factor for particulates from wood is 0.347 lbs/mmBTU.
Latest permit review indicates compliance.
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. The firing rate during
the inspection was 5,500 lbs/hr,which is well below 30 tons/hr.
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 SOZ for wood combustion is 0.025 lbs/mmBtu which equals 0:264 lbs/hr.
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—Facility keeps detailed records of the amount of wood burned monthly
and total annually. Year to date wood total is 498.8 tons.

d) 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.
e) A.10 2D .1100 TOXICAIR POLLUTANT EMISSIONS LIMITATIONAND REPORTING
REQUIREMENT—Toxic limitations apply to Arsenic(.60 lbs/yr),Benzene(300 lbs/yr), Chromium
(.15 lbs/yr),Formaldehyde(.04641bs/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 6 tons of wood
a day(0.25 tons/hour)which is well below the permitted limit of 1.17 tons per hour.
f) 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 2014. NOCS was received via CEDRI on time.
g) 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.
h) 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.
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).
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) DAQ Compliance History
a) 25 February 2011 —Operation without a permit
8) Comments and Compliance Statement
Edwards Wood Products Inc. Peachland appeared to be in compliance on 7 August 2014.
Pink Sheet:No comments.
/mst