AQ_F_0400058_20111130_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Rebel Lumber Company; Inc.
NC Facility ID 0400058
Inspection Report County/FIPS: Anson/007
Date: 12/01/2011
Facility Data Compliance Data
Rebel Lumber Company, Inc. Inspection Date 11/30/2011
160 Pulpwood Yard Road Inspector's Name Cindy Grimes
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/R00
Steve McEwen Scott Little Steve McEwen Issued 7/26/2011
Expires 6/30/2016
Treasurer Vice President Treasurer �
[phone] [phone] [phone] Classification Small
Permit Status Active
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Inspector's Signatu/'• •., Comments:
Date of Signature: t 3 {
t
MACT/GACT Applicability:subject to Subpart 6J,"Industrial, Commercial, and Institutional Boilers";
facility has existing>10 rnmBTU wood-fired boiler; not subject to Subpart 4D "Plywood and Composite
Wood Products",since facility is not a Title III Major source for HAPs; not subject to Subpart 4Z,RICE,
since facility has no emergency generators on site.
1) Location
Rebel Lumber Company 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 1/2 in i Ies 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 annileage on
Hwy 74 is 48 '/z 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 asl: 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
Rebel Lumber Company is a hardwood sawmill and lumber drying kiln facility. This facility is permitted under
Air Permit No. 10146R00, effective fronn 26 July 20I1 until M June 2016. This is the facility's first
compliance inspection since the permit was issued.

Rebel Lumber Company,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 instal l the
boiler.
a) Permitted Sources
Emission Y rn Emission Source Control
Source ID Description, System ID 1 Description' j
ES-1 Stoker type wood-fired Boiler
F10.54 million Btu per hour maximum heat input
(NSPS,NESHAP) (300 BHP)
ES-2 Four(4)steam-heated lumber drying kilns N/A
62,000 board feet capacity each
ES-3 Four(4)steam-heated lumber drying kilns
28,000 board feet capacity each
b) Insignificant/Exempt Activities
1 Source-of Title
Saurce- Exemption Regulation !tSource of TAPs?
Pollutants?:
IES-1
Band saw mill for green lumber,inside 2Q.0102(e)(2)(E)(i) No Yes
building
IES-2 j
Circular saw mill for green lumber,inside 2Q .0102(c)(2)(E)(i) No Yes �
building
c) Throughputs for 2010/2011
Employees: 62
Hours: 7:OOAM—3:30 PM
Production: 982.22 tons(from 10/15/2010— 11/29/2011)
3) Inspection Conference
On 30 November 2011, I(Cindy Grimes)met with Greggie Mull,invoice Contact and Accounting Supervisor,
and Steve McEwen,Facility Contact and Plant Manager,to conduct their facility's first compliance inspection.
We discussed the following:
a) Verified the FACFINDER information; nothing has changed since initial permit was issued.
b) Went over their new permit in detail, including the NESHAP Subpart 6J Boiler MACT provisions. They
will be required to conduct a biennial tune-up and a one-time energy assessment, as well as annual
compliance certification reports. I provided Ms.Mull with information regarding DAQ grant funding for
the energy assessment.
c) I reviewed the daily log that is kept for measuring their wood combustion. Mr. McEwe❑ keeps a written
log that is kept in the boiler area,and an electronic log is also kept that includes gross weight,tare�a�eight,
net weight, and boiler saw dust loading rate(ibs/hr). The only thing I suggested was to keep a cumulative
total column. Ms. Mull provided me with a copy of the log dating back from the initial recording, which
was oil 15 October 2010.

4) Inspection Summary(facility was operating during inspection)
a) ES-1 Woad-fired Boiler(10.54 mmBTU/hr): This stoker-type boiler was manufactured by burst Boiler
Company in 1994 with amaximum ratting of 10,350 lbs steam/ln; Within the boiler are au 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 tile boiler for more
efficient energy(e.g.the pressure within'the boiler decreases'until the next load of fuel is being)'ed into it).
The settings include low steam pressure,high steam pressure,temperature controls, as well as a-phone
dialer that will notify Mr.McEwen of an emergency during off hours. Furnace temps vary from
900-1200T. There is also a flow chart that records 24/7.Mr. McEwen cleans out the firebox—eve 2
days,which lie records in a ivai tenance 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,w th the remainder emitted th-u the stack on the
roof.'Mr.McEwen said that the white/red oak sawdust that'is'used now buries better and has fewer residues
thanother 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 froin the storage area onto a conveying system inside the boiler room,and finally moved by au auger,
directly into the boiler,
As the boiler came on and shut off,I observed'VE ranging'from 0%- 15%.
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 illy
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 harrower 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.
d) IES-2 Circular Saar Mill:This process is located in a separate area from the kihis and boiler. Its building
is one of two located across the road from the inain office(looking from Pulpwood Yard Road, it is the
buildingon 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 I 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
Indirect Heat Exchangers"-Particulate matter emissions shall not exceed .041 lbs/mmBTU.
Compliance Indicated—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 froin Miscellaneous
Industrial Processes"—Particulate matter emissions shall not exceed>30 tons/fir".
Compliance Indicated-Latest permit review shows`compliance.

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e} A.5 2D .0516 SULFUR DIOXIDE CONTROL REQUIREMENT— Sulfur Dioxide emissions from
wood-fired boiler shall not exceed 2.3 lbs/mmBTU.
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Compliance Indicated-The facility combusts only wood,and the AP-42 emissions factor for SO,
for wood combustion is 0.025 lbs/mmBtu.
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d) A.6 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT—Visible emissions fi-om the
emission sources shall not be more than 20% in opacity.
Compliance Indicated—I did not observe any emissions> 20% in opacity.
e) A.7 2D .0524 NEW SOURCE PERFORMANCE STANDARDS—For the wood-fired boiler, the
Permittee shall comply with notification,testing, reporting, recordkeepiug and monitoring requirements.
Compliance Indicated—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 the monthly and annually amount of combustcd wood.
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f) 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.
Compliance Indicated—I did not observe any excess fugitive dust emissions within or beyond the
facility's property line.
(Y) A.10 2D .1100 TOXIC AIR POLLUTANT EMISSIONS LIIVIITATIONAND 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
j kept demonstrating compliance for these limits.
Compliance Indicated—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. Facility records show that 780.83 tons of wood were combusted during
j the 12-month period of 15 October 2010 thru 15 October 2011.
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h) A.11 2D .1111 NESHAPSub1)artJJJJJJ—The Permittee shall comply will all applicable provisions,
jincluding 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 ou 7 September
2011;requirements and compliance dates were discussed with facility.
i) A.12 2D .1806 CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—There steal I be no
odorous emissions from facility that causes or contributes to objectionable odors beyond the facility's
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boundary.
Compliance Indicated—I detected no objectionable odors within or beyond the facility's property.
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j) A.13 2Q .0711 TOXICAIR POLLUTANT EMISSIONS LIMTTATION REQUIRE,MENT—Tire
Permittee shall operate and maintain facility emissions of the listed TAP, Cadmium, so as not to exceed
0.37 lbs/yr.
Compliance Indicated—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).
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6) Reporting Requirements
The construction notification requirement was removed from the NSPS Dc stipulation,since the existing boiler
was constructed in 1994.Reporting requirements forNESHAP 6.1 are fouled below Columents and Compliance
Statement.
7) 112R Status
This facility neither uses nor stores chemical compounds that require a written risk management plan
under the Clean Air Act, Section 112R.
8) DAQ Compliance History
a) 25'February 2011'—Operation without a permit
9) Comments and Compliance Statement
After its ls`compliance inspection,this facility appears to be doing everything and willing to comply with
DAQ regulations. During 2012 inspection, inspector should verify 6J requirements.
Rebel 1 umber Company appeared to be in compliance on 30 November 2011.
NESHAP 6J requirements;
a) , Initial notification letter from FRO DAQ asking for facility status Was sent out iin August 2011,
b)! Facility replied oi9 September,2011,confirming itwas subject.
c),, Facility needs to comply with the,following(inspector should verify during 2012 inspection):
i) Tune-up and fuel records - The first tune-up should be completed by March 21, 2012. The ncxt
biennial tune-up should,be completed no later than 25,months after the 'initial tune-up. Retain this
form on site for each bole-up and maintain fuel records.
ii) Energy Assessment— Conduct and document the one-time energy assessment by March,21;, 2014 A
facility is not required to implement the identified energy conservation measures.
iiij Notification of Compliance Status—Submit by July 19,2012 for the tune-up.If the,compliance status
notification for the energy assessment is not included in the July 19,2012 notification, a separate
notification for this requirement is required by July 19,,2014.
Note: EPA has recently(11/2011)proposed a delay for the current 6J requirements. As a result,the existing
regulations may not be in effect during the 2012 compliance inspection,and therefore,the inspector should be up
to date regarding these requirements.
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