AQ_F_0400058_20130806_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: 09/05/2013
Facility Data Compliance Data
Edwards Woad Products,Inc. -Peachland Inspection Date 08/06/2013
160 Pulpwood Yard Road Inspector's Name Mike Thomas
Peachland,NC 28133 Operating Status Operating
Lat: 34d 59.5500m Long: 80d 17.7000m Compliance Code Compliance-inspection
SIC: 2421 /Sawmills &Planing Mills General Action Code FCE
NAICS: 321113/Sawmills On-Site Inspection Result Compliance
Contact Data Permit Data
Facility Contact Authorized Contact Technical Contact Permit 10146/R01
J.Lynn Greene J.Lynn Greene J.Lynn Greene Issued 9/27/2012
Director of Human Director of Human Director of Human Expires 6/30/2016
_ Resources Resources Resources Classification Small
[phone] [phone] [phone] Permit Status Active
Inspector's Sign tore: Comments:
Date of ignature:
1) Location
Edwards Wood Products Inc. -Peachland is located at 160 Pulpwood Yard Road,west of Peachland,NC in
Anson County.
Directions
From FRO,take Hwy 401 South to Wagram. Turn right onto Old Wire Road(Hwy 144)and go-- 11 '/2 miles
to Laurel Hill. Turn right onto US 74 West and go through Richmond County to Anson County. Go through
Wadesboro and through the west side of Anson County until you get to the Union County line.Plant is just
before Union County line on right hand side, across the road from Quikrete permitted facility(total mileage
on Hwy 74 is—48 1/2 miles). Main office directions: From Hwy 74, turn right onto Old Hwy 74 West(—.4
mile past Caudle Road),go— 100 yards and then turn right onto Pulpwood Yard Road. Cross railroad tracks
and office will be the building nearest the road on the right, surrounded by trees.Enter at front door and ask
for Greggie Mull.
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. 101461100, effective from 26 July 2011 until 30 June 2016.The facility
was last inspected by Cindy Grimes on 30 November 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.
Note: Before the wood-fired boiler was purchased in 2010,the facility had been operating their lumber
drying kilns by direct firing them with propane. When this process became too costly,Rebel decided to
install the boiler.
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
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) Insigniticant/Exempt Activities
SEIM rt
IES-1 i
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
c) Throughputs for 2012
Employees: 62(same as in 2011)
Hours: 7:OOAM—3:30 PM
Production: —990 tons (982.22 tons for 2011)
3) Inspection Conference
On 6 August 2013, I Mike Thomas of FRO DAQ, met with Robbie Fincher, Drying Manager,We discussed
the following:
a) Verified the FACFINDER information;nothing has changed since initial permit was issued.
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).Mr.Fincher stated that significant
improvements in boiler operation and efficiency have been achieved in the past year.
4) Inspection Summary(facility was operating during inspection)
a) ES-1 Wood-fired Boiler(10.54 mmBTU/hr): This stoker-type boiler was manufactured by Hurst
Boiler
Company in 1994,with a maximum rating of 10,350 lbs steam/hr. Within the boiler are an induced draft
fan and an under fire air fan, as well as a 30 HP motor, all which can run on variable frequency drives to
ensure the proper mix of combustion air to fuel. Rebel installed a control box for the boiler for more
efficient energy(e.g.the pressure within the boiler decreases until the next load of fuel is being fed into
it).The settings include low steam pressure,high steam pressure,temperature controls, as well as a
phone dialer that will notify Mr.Fincher of an emergency during off hours.Furnace temps vary from
900-1200°F. There is also a flow chart that records 24/7. Mr.Fincher cleans out the firebox—every 2
days,which he records in a maintenance log that is kept near the boiler. Semi-annual inspections are also
performed, usually in January and July,which includes cleaning out the fire tube. The last cleaning was
on 27 July 2011. Any residual particulate matter from the boiler goes thru a collective ductwork system;
the heavier PM is then"dumped" into an ash collection barrel,with the remainder emitted thru the stack
on the roof Mr. Fincher said that the white/red oak sawdust that is used now bums better and has fewer
residues than other mixed woods that were initially used.The barrel is emptied—once/week.
The boiler and the sawdust used as fuel are located in one enclosed building, each area separated by a
concrete wall(the sawdust storage area is—30' x 25'). The sawdust burned is all green and is brought
into its storage area via a small front loader(that collects sawdust from the sawing areas),then
automatically fed from the storage area onto a conveying system inside the boiler room, and finally
moved by an auger directly into the boiler.
b) ES-2 Steam-heated Lumber Drying Kilns: There are four of these kilns, each capable of drying 62,000
board feet of lumber.Two are located within a brick building built in 1994, and the other two are located
within a prefab building built in 2010. They were operating during my inspection, and I saw no issues.
c) ES-3 Steam-heated Lumber Drying Kilns: There are four of these kilns, each capable of drying 28,000
board feet of lumber.They are located within an older building and are only used for lower grade lumber,
since they don't have the venting capacity that the newer kilns do. They were not in use during my
inspection, and I saw no issues.
d) IES-1 Band Saw Mill: This process is located in a separate area away from the kilns and boiler. Its
building is one of two located across the road from the main office(looking from Pulpwood Yard Road, it
is the building on the right). Band mills produce a narrower kerf(loss of wood to sawdust with each pass)
than circular mills,thus producing less dust. The mill is mainly used for wood-chipping and has 2 truck
load outs at the rear. Only green wood is chipped. I observed no problems in this area.
c) IES-2 Circular Saw Mill: This process is located in a separate area from the kilns and boiler.Its
building is one of two located across the road from the main office(looking from Pulpwood Yard Road,
it is the building on the left). Production is faster here, since more logs can be cut within a time frame
with circular saws than with band saws;therefore,this mill tends to waste more wood and produce more
dust with a greater kerf. There is 1 truck load out on the north side of the mill. Only green wood is used.
I observed no problems in this area.
5) Permit Stipulations
a) A.3 2D .0504 PARTICULATE CONTROL REQUIREMENT—"Particulates from Wood Burning
hidirect 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) A.4 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 SOZ for wood combustion is 0.025 lbs/mmBtu.
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.
d) 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 started boiler up on 25 October 2010, amongst initial confusion
as to what state agency and which.DAQ regional office should determine if permit was required. After
finally determining that a permit was needed through FRO, an NOV was issued to facility for operating
without an air permit. Facility maintains a detailed log for daily and annual amount of combusted wood.
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.
f) A.10 2D .1100 TOXICAIRPOLLUTANTEMISSIONSLIMITATIONAND 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 6 tons of wood
a day(0.25 tons/hour)which is well below the permitted limit of 1.17 tons per hour.
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).
Compliance to be Determined—Initial response to notification was received in FRO on 7
September 2011;requirements and compliance dates were discussed with facility. The initial tune-up
was completed in April 2012. The facility has not conducted an energy assessment as of yet.
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 TOXICAIRPOLLUTANTEMISSIONS LIMITATION REQUIREMENT—The
Pennittee 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 6 August 2013.
/mst