AQ_F_0400058_20220429_PRMT_PmtRvw_R04

. NORTH CAROLINA DIVISION OF Region: Fayetteville Regional Office
�
AIR QUALITY County: Anson
Application Review NC Facility ID: 0400058
Inspector's Name: Mike Thomas
Date of Last Inspection: 02/10/2022
Issue Date: 04/29/2022 Compliance Code: W/Violation-procedures
Facility Data Permit Applicability(this application only)
Applicant(Facility's Name): Edwards Wood Products,Inc.-Peachland SIP:
NSPS:
Facility Address: NESHAP:
Edwards Wood Products,Inc.-Peachland PSD:
160 Pulpwood Yard Road PSD Avoidance:
Peachland,NC 28133 NC Toxics:
112(r):
SIC: 2421 /Sawmills&Planing Mills General Other:
NAICS: 321113/Sawmills
Facility Classification: Before: Small After: Small MODIFICATION
Fee Classification: Before: Small After: Small Addition of Boiler ID No. ES-5
Contact Data Application Data
Facility Contact Authorized Contact Technical Contact
Application Number: 0400058.22A
Chris Harrington Chris Harrington Chris Harrington Date Received: 03/28/2022
Director of EH&S Director of EH&S Director of EH&S Application Type: Modification
[phone] [phone] [phone] Application Schedule: State
2215 Old Lawyers Road 2215 Old Lawyers Road 2215 Old Lawyers Road Existing Permit Data
Marshville,NC 28103 Marshville,NC 28103 Marshville,NC 28103 Existing Permit Number: 10146/R03
Existing Permit Issue Date: 11/29/2017
Existing Permit Expiration Date: 05/31/2024
Review Engineer: Evangelyn Lowery-Jacobs Comments/Recommendations:
Issue 10146/R04
Review Engineer's Signature: Date: Permit Issue Date: 04/29/2022
, Permit Expiration Date: 05/31/2024
04/29/2022 it
1. Purpose of Application
Edwards Wood Products, Inc.—Peachland is a hardwood sawmill and lumber drying kiln facility
located in Peachland,Anson County. The company has requested a permit modification to add a new
natural gas-fired boiler,which provide process steam to the lumber drying kilns on site. They have
also requested corrections to the permit to reflect changes in equipment at the facility.
The modification was a result of a violation for installation of a 16mmBtu/hr Natural gas-fired boiler
without first obtaining a permit. This permit modification consists of:
• Adding one natural gas-fired boiler(rated at 16.739 mmBtu/hr maximum heat input).

Edwards Wood Products, Inc.—Peachland
Permit R04 Review
Page 2 of 10
• Corrections to existing permit source ES-2 (in permit R03 listed as Four(4) steam-heated
lumber drying kilns 62,000 board feet capacity each))based on changes at the plant not
ry g ( P ty
reflected in the current permit. The facility requested removal of two of the four steam-
heated lumber drying kilns(62,000 board feet capacity each; from ID No. ES-2)that were
never installed at the site.
• Delete emission source ES-4 (in permit R03 listed as"Two(2) steam-heated lumber drying
kilns, 62,000 board feet capacity each") from the permit. The facility indicated these kilns
have been relocated to Edwards Wood Products, Inc. Laurinburg plant.
This facility is classified as Small.
The application did not contain any confidential information.
The facility Pink Sheet contains one applicable item which is addressed in section 5.
The facility contact for the application is Chris Harrington, Director Environmental Health and Safety
(704-624-3611). The company utilized a consultant to prepare the permit application, Daryl H.
Grassick, Senior Air Consultant(919-602-4662).
Throughputs:
12-Month Consecutive
Tons Combusted
2021 6,474.3
�-2020— 5,817.7
2019 4,554.9
2018 6,878.6
2617 6,485.8
2016 7,459.3
2015 -� - 71,169
w1)014
—1,100
i
2013 982
2. Facility Description
Edwards Wood Products, Inc. is a hardwood sawmill and lumber drying kiln facility. The facility
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 four(4) 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.

Edwards Wood Products, Inc.—Peachland
Permit R04 Review
Page 3 of 10
3. Zoning
The permit application received on 03/28/2022 included a request for a Zoning Consistency
Determination from the Anson County Zoning and Planning Department dated 03/22/2022. The
determination was signed by Larry Newton, Planning Director, dated 03/29/2022, indicating that
"The proposed operation IS consistent with applicable zoning ordinances. "
4. Application Chronology
Date Activity .
02/10/2022 Mike Thomas of FRO DAQ inspected the facility and found it to be in
apparent violation for installing and operating a 16 mmBtu/hr Natural
gas-fired boiler without first obtaining a permit. This source cannot be
exempt from permitting since the wood-fired boiler was modeled and this
new source has common pollutants. Therefore, a permit is required.
02/28/2022 NOV issued for installing and operating the 16mmBtu/hr natural gas-fired
boiler without first obtaining a permit is a violation of N.C.G.S. 143-
215.108.
03/18/2022' Jeffrey Cole spoke with Daryl H. Grassick, an Air Quality Consultant for
Edwards Wood Products. Mr. Grassick asked if the facility would need to
model again because they installed the NG-fired boiler. Mr. Cole explained
that the natural gas-fired boiler was not exempt from permitting(02Q
.0102(b)(2)). If the facility wanted both the boilers to operate at the same
time,then they would need to remodel for toxics. This was due to the '
combined expected actual emissions(as TPERs had been exceeded for the
wood-fired boiler originally and the NG-fired boiler emissions would add
to those emissions).
03/18/2022 Jeffrey Cole confirmed with Tom Anderson that if the facility requested a
stipulation restricting operations to one boiler at a time, they would not
need to remodel for toxics. This was due to the NG-fired boiler emissions
alone not exceeding TPER.
_- --____
03/28/2022 FRO received the application for modification of the air permit. The
application included a properly completed Form A and a check in the
amount of$50 for the applicable permit processing fees. There was no
request to keep any information confidential. The application appeared to
be complete for processing.
03/29/2022 FRO sent the facility a letter acknowledging receipt of the permit
application.
03/31/2022 The permit application was forwarde 11 d to the permit engineer.

Edwards Wood Products,Inc.—Peachland
Permit R04 Review
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5. Changes in Equipment, Emissions and Regulations and PE Review Requirements
This permit modification application is for the following changes to the current air permit:
• Add one natural gas-fired boiler(rated at 16.739 mmBtu/hr maximum heat input).
• Corrections to existing permit source ES-2(in permit R03 listed as Four(4)steam-heated
lumber drying kilns(62,000 board feet capacity each))based on changes at the plant not
reflected in the current permit. The facility requested removal of two of the four
steam-heated lumber drying kilns(62,000 board feet capacity each; from ID No. ES-2)that
were never installed at the site.
• Delete emission source ES-4(in permit R-3 listed as"Two(2)steam-heated lumber drying
kilns, 62,000 board feet capacity each")from the permit. The facility indicated these kilns
have been relocated to Edwards Wood Products,Inc.Laurinburg plant.
There is one relevant pink sheet item to be addressed in this permit revision.
• "Facility may want to remove some of the kilns listed on the permit that are not installed.
Engineer should confirm with facility during next permit mod or renewal." The facility
requested a correction in this modification application to existing permit source ES-2 to
indicate two(2) steam-heated lumber drying kilns rather than four.
A 02D .1100"Control of Toxic Air Pollutants"Ad-Hoc Operational Restriction has been
incorporated into the permit: "The Permittee shall only operate either the Natural gas-fired boiler
(16.739 mmBtu/hr maximum heat input) (ID No. ES-S) or the Stoker type wood-fired Boiler(10.54
mmBtu/hr maximum heat input(300 BHP)) (ID No. ES-1), not both simultaneously, to ensure
emissions do not exceed Toxic Permit Emission Rates (TPERs)."
The latest updated permit condition for 15A NCAC 02D .0521 "Control of Visible Emissions" has
been incorporated into the permit.
The latest updated permit condition for 15A NCAC 02D .1 100 "Toxics Above TPER Limits" has
been incorporated into the permit.
PE Seal—A PE Seal was not required for this application.
The facility's permitted emission sources are as follows:
Emission Emission Source Control Control System
Source ID a-� - ��T�= Description — System ID _s Description,, w ;
j Stoker type wood-fired Boiler i
ES-1 (10.54 mmBtu/hr CD-MCI Multiclone with 8
(NSPS,NESHAP) nine inch diameter tubes
maximum heat input(300 BHP))
Two(2)steam-heated lumber drying kilns
ES-2 (62,000 board feet capacity each)
ES-3 Two(2)steam-heated lumber drying kilns N/A
(28,000 board feet capacity each)
ES-5 Natural gas-fired boiler
(16.739 mmBtu/hr maximum heat input)

Edwards Wood Products, Inc.—Peachland
Permit R04 Review
Page 5 of 10
The facility's insignificant/exempt activities are as follows:
Source of Source of
Source Exemption Regulation Title V
TAPS. O s?
..� �.. 11u tan t IES-1
Band saw mill for green lumber 02Q .0102 (g)(12) No Yes
(inside building) f
Circular saw mill for green lumber I 02Q .0102 (g)(12) No Yes
(inside building)
I-LPGBoiler
LPG-fired boiler 02Q .0102 (h)(1)(B) Yes Yes
(7.53 mmBtu/hr maximum heat input)
6. Background
The following information is excerpted from the Permit R03 Review on 11/29/2017 by Greg Reeves.
A review of the toxics emissions submitted with their 05/06/16 permit renewal and administrative
amendment package showed that the facility projected actual emissions (based on emissions from the
wood-fired boiler [ID No. ES-I] only as steam heated kilns only emit VOCs)would exceed the TPER
for several toxic pollutants, specifically, arsenic, benzene, chromium. This required the facility to
perform an air dispersion analysis to demonstrate compliance with the AALs for these pollutants.
Data was supplied by the company regarding emissions, emission locations, and terrain, and RCO
AQAB performed a dispersion modeling analysis based on this data. Emission rates were not
optimized for maximum allowable AALs. The results of this modeling analysis were as follows:
Concentration at AAL o L
x
Pollutant Emission Rate Property Boundary (µg�m3) /o AA
(ftg/m )
Arsenic 2.03 lbs/yr 1.3 8 E-04 0.0021 6.6
_
Benzene 387.81bs/yr 2.63E-02 0.12 21.9
Chromium 0.323 lbs/yr 1.32E-04 0.62 0.02
Hydrogen Chloride j 2.00 lbs/hr 1.19E-01 700 0.02
Formaldehyde 0 0464 lbs/hr 2.76E-01 150 0.18
Based on this modeling analysis, a limitation of 1.17 tons wood combusted per hour was placed into
the 02D .1100 toxics permit condition.
In 2017 the facility exceeded the hourly wood combustion limit. Review of modeling analysis
showed emission rates had not been optimized for allowable AALs. RCO AQAB agreed that
optimizing emission rates would have increased limits by factor of 5 or more.

Edwards Wood Products,Inc.—Peachland
Permit R04 Review
Page 6of10
In Permit R03 the limits in this condition were increased by a factor of 4 as shown in the table below:
Pollutant Emission Rate
Arsenic ` lbs/yr
Benzene -387.81bs/yr
Chromium 1551.20 lbs/yr
Hydrogen Chloride -�8.00 lbs/hr
Formaldehyde 0.18561bs/hr
7. NSPS,NESHAP,PSD, 112(r) & Attainment Status
• NSPS—
✓ The wood-fired boiler(ID No. ES-1)and natural gas-fired boiler(ID No.ES-5)are subject to
NSPS Subpart Dc"Small Industrial-Commercial-Institutional Steam Generating Units"
because both were constructed after June 95 1989(constructed in 1994 and 1991,
respectively)and have a maximum heat input greater than 10 mmBtu/hr but less than or equal
to 100 mmBtu/hr.
✓ The LPG-fired boiler(ID No. I-LPGBoiler)is not subject to NSPS Subpart Dc because it has
a maximum heat input less than 10 mmBtu/hr.
• NESHAP—
✓ The wood-fired boiler(ID No. ES-1) is subject to 40 CFR 63 Subpart JJJJJJ"National
Emission Standards for Hazardous Air Pollutants for Area Sources: Industrial,Commercial,
and Institutional Boilers". The boiler is considered an existing biomass-fired boiler under
this regulation, as it was constructed in 1994. The initial notification for this boiler was
received at FRO on 09/07/11. The energy assessment was conducted in February 2012.
NOCS was submitted on time. The latest biennial tune-up of the boiler was conducted on 23
January 2020.
✓ The LPG-fired boiler(ID No.I-LPGBoiler)and natural gas-fired boiler(ID No. ES-5)are not
subject to NESHAP Subpart JJJJJJ because both are gas-fired boilers and exempt from the
regulation.
• PSD—Emissions from this facility are below PSD thresholds.
• 112(r)—The facility is not subject to 112(r). None of the listed chemicals are stored in quantities
above the threshold quantities. The facility is therefore not required to maintain a written risk
management plan.
• Attainment—Anson County is in attainment.

Edwards Wood Products, Inc.-Peachland
Permit R04 Review
Page 7 of 10
8. Emissions Review
Overall emissions are expected to decrease due to this permit modification. The addition of one (1)
natural gas-fired boiler(16.739 mmBtu/hr maximum heat input), removing two of the four
steam-heated lumber drying kilns(62,000 board feet capacity each; from ID No. ES-2) and removing
two (2) steam-heated lumber drying kilns(62,000 board feet capacity each; ID No. ES-4)will
decrease Potential Emissions for PM(TSP), PMIo, PM2.5,NOx, CO and VOC.
The following table shows the facility-wide net change in potential emissions:
_ Net Change in Net Change in
Potential Emissions Potential Emissions
Pollutant Before Controls/ After Controls/
Limitations Due to Limitations Due to
This Modification This Modification
tons/yr tons/yr . W "
PM(TSP) -0.02 0
PMIo 0.01 -0.01
PM2.5 -0.01 -0.01
E
NOx -4.69 -4.69
CO ' . 2 70 _ 2.70
VOC -6.13 -6.13
Facility-wide Emissions after this modification:
CY 2015 Potential Before Potential After
Pollutant Actual Emissions Controls/Limitations Controls t Limitations
tons/yr tons/yr tons/yr
i
PM(TSP) 7.65 16.02 10.96
PMIo 7.00 14.17 � 10.02-F..-��
PM2.5 j� 4.42 -� _ 12.33 6.32
SOz 0.81 �. 1.15 1.15 W
NOx 7.10 10.16 1 10.16
�
CO �19.36 27.70 27.70
...VOC �- 1.78 5.28 5.28
CY 2015 emissions are from the 2015 AQE1. Worst case scenario Potential Emissions of PM, PMlo,
PM2.5, SOz,NOx, CO, and volatile organic compound(VOC)from wood combustion were derived
from the NCDEQ Wood Waste Combustion Emissions Calculator Revision L 09/03/2019. Actual
yearly fuel usage is based on the combustion of 6,473 ton/yr of wood(the facility's total wood
combusted in 2021) in their wood-fired boiler(ID No. ES-1). The facility will only operate either the
natural gas-fired boiler or wood fired boiler,not both simultaneously. Potential VOC emissions from
the facility's wood kilns were derived from the NCDEQ Wood Kiln Emissions Calculator Revision C
July 2007. The potential bd-ft/year of steam heated kiln dried lumber was taken from the 2016
renewal dated 06/23/2016.

Edwards Wood Products,Inc.—Peachland
Permit R04 Review
Page 8 of 10
9. Air Toxics
See the Background discussion in Section 6 above for a discussion of toxics.
The permit contains both a 02D .l 100 and a 02Q .0711 toxics condition. The facility will only
operate either the natural gas-fired boiler or wood fired boiler,not both simultaneously,to ensure
emissions do not exceed TPER limits.
10. Compliance History
03/03/2022 NOV issued for installed 16mmBtu/hr NG boiler without permit. Due to
wood-fired boiler modeling,NG boiler is not exempt.
02/10/2022 Mike Thomas inspected the facility and found the facility in violation for
installation of a16mmBtu/hr NG boiler without first obtaining a permit
01/19/2017 The facility was inspected five(5)times by Mike Thomas and Jeffrey Nelson. The
through facility was found to be in apparent compliance each time.
03/3 0/2021
04/13/2016 NOV for operating non-permitted sources and for sources exceeding fuel
combustion limits under 15A NCAC 2D .1100 "Control of Toxic Air Pollutants."
03/08/2016 Mike Thomas inspected the facility and found the facility in violation of the fuel
throughput limit under the 2D .1100 toxics condition.
11/30/2011 The facility was inspected four(4)times by Cindy Grimes and Mike Thomas. The
through facility was found to be in apparent compliance each time.
08/20/2015
11. Stipulation Review
Regulation Affected Sources Emission Limit Or Requirement
15A NCAC 02D .0202 I Facility Wide f Permit Renewal&Emissions Inventory Submittal
1 A5 NCAC 02D .0504 ES-1 PM<0.41 lbs/mmBtu
15A NCAC 02D .0515 ES-2 E=4.10 * (P)0-67 for P<30 tons/hr
ES-3 E= 5 5 * (P)o.i i—40 for P>30 tons/hr
15A NCAC 02D .0516 ES-1 SOz <2.3 lbs/mmBtu
ES-5 —
15A NCAC 02D .0521 Facility Wide VE <20% Opacity
�15A NCAC 02D .0524 � ES-1
NSPS Subpart De ES-5 Records of Each Fuel Combusted Each Month
15A NCAC 02D.0535 Facility Wide Excess Emissions Notification Requirement
15A NCAC 02D .0540 F Facility Wide Fugitive Dust Control Requirement

Edwards Wood Products, Inc.—Peachland
Permit R04 Review
Page 9 of 10
Emission Limit Or Requirement
i
Toxics Limitations for Arsenic, Benzene, Chromium,
Formaldehyde, and Hydrogen Chloride
15A NCAC 02D .1100 Facility Wide Limits on wood combusted daily and annually
Records of wood combusted daily, monthly, annual
No Reporting Required
Operational Restriction ES-5 Do not operate Boilers ES-1 and ES-5 simultaneously E
15A NCAC m02D .1111 _ Boiler Tune-up biennially
NESHAP Subpart ES-1 Annual Compliance Certification Report
.. .7
JJJJJJ (Submitted only if requested)
E 15A NCAC 02D .1806 Facility Wide No objectionable odors beyond the facility's boundary
15A NCAC 02Q .0711 ES-1 Toxics Emissions exceeding TPERs requires permitting
ES-5
12. Conclusions,Comments and Recommendations\
• I recommend issuing permit no. 10146R04 to Edwards Wood Products, Inc.—Peachland facility
(Facility ID 0400058).
• Modifications to IBEAM:
✓ Highlighted headers,adjusted column widths and borders for improved clarity and
appearance.
✓ Added a comma in both the Perchloroethylene(tetrachloroethylene)(127-18-4) (13,000
Carcinogens(lb/yr))and the Methylene chloride(75-09-2)(1,600 Carcinogens(lb/yr)) TPER
limit for clarity.
�9
1/9
Review Engineer 1-'f "- � -�' '`..-.-.--- Date 04/29/2022
J
Permit Coordinator �� G�''� Date eX Z .Z Z
DAQ Supervisor Date a022
/elj
c: FRO Files

Edwards Wood Products, Inc.-Peachland
Permit R04 Review
Page 10 of 10
IM54 mrnSW/hr Stoker Wood-fired floileF(ES-1) FacRity-Wide
ACTUAL EMISSIONS POTENTIAL EMSSIONS POTENTIAL EMSSIONS
(AFTER C014TWXS/ (BEFORE:CONTROLS(AFTER,CONTROLS I (BEFORE CONTROLS(AFTER CONTROLS
LIMITS) /LIMITS) umffs.) /LIMITS) LIMITS)
AM POil-LITANT EMITTED lb/hr torm/yr ft/hr -/W "r -5/VT AIR POLLUTANT EMITTED torm/w tom/yr
PARTICULATE MATTER(PM) 2-50 6.90 3:66 16.02 2.50 10.94 PAR-"CULATE MATTER 4PM) 16.92 10.134
PARTICULATE MATTER<10 MICRONS(PM10) 2.29 6-32 3-24 1A.17 2.29 10.02 PARTICULATE MATTER<10 MICRONS(PMIG) 14.17 10.02
PARTICULATE MATTER-2.S MICRONS(PM2..S) 1-44 3.99 2.91 12.33 144 6.32 PARTICULATE MATTER<2-S MICRONS(PM2..5) 12.33 C32
SULFUR DIOXIDE(SO2{) 0.26 0-73 0-26 1.15 0,26 1.15 SULFUR DIOXIDE 4502) 1.15 1.1S
NITROGEN OXIDES(NOX) 2-32 6.41 2.32 10.16 2.32 10.16 NITROGEN OXIDES(NOx) 110.16 10.16
CARBON MONOXIDE(CO) 6,32 17AS 6-32 27.79 632 27.70 CARBON MONOXIDE(CO) 27.70 27.70
VOLATILE ORGANIC COMPOUNDS(VOC) 0.18 0.50 0.18 M78 0.18 0.78 VOLATILE ORGANIC COMPOUNDS(VOC) 5.28 5.22
LEAD O-CK) 0.00 0.00 0-00 0.00 0.00
16.739 mmbtu/hr NG Boiler(ES-S)
ACTUAL EMISSIONS POTENTIAL EMSSIONS
(AFTER CONTROLS (BEFORE CONTROLS(AFTER CONTROLS
LIMITS) /LIMITS) LIMITS)
AIR POLLUTANT EMITTED Ibl%r to-shr "Whr towwlyr ra/hr t--/YV
PART4CULATE MATTER(Total) 0-01 0.03 0.01 0-04 0.01 0.04
PARTICULATE MATTER(Fifterable) 0-00 0.01 ODD 0-01 0.00 0-01
PARTICULATE MATTER(Condensable) 0.01 0.02 0,01 0�02 0.01 0.02
PM 2.5(Total) 0-01 O.Cr2 0.01 0..03 0.01 0.03
PM 2:S(Filterable) 0.00 0.01 0.00 0.01 0.00 0-01
SULFUR DIOXIDE-(SOZ) 0-01 0.03 0.01 0..04 0.01 0-04
NITROGEN OXIDES(NOX) 1.64 S..75 1-64 7A9 1-464 7.19
CARBON MONOXIDE JCO) 1-38 4.83 1.39 6D4 1-38 6-04
VOLATILE ORGANIC COMPOUNDS(VOC) 0.09 032 0-09 0.40 0.09 0.40
WoodKiIns Emissions(20 62AM BF capacity&2e 29,000 BF capacity)
20 62..OW BF
ACTUAL EMISSIONS POTENTIAL EMSSIONS
(BEFORE tim"s) {AFTER LIMITS)
AM POLLUTANT EMITTED Ih/hr NWhr Ib/hr
PARTICULATE MATTER(PM) 0 0 0
VOLATILE ORGANIC COMPOUNDS(VOC) 213 3.0.9 3,09
24LD 2S,000 OF
ACTUAL EMISMONS POTENTIAL EMSSIONS
(BEFORE LIMITS) (AFTER urm-l-S)
AIR POLLUTANT IEMFFTEV tonsfyw -/VW- to-fyr
PARTICULATE MATTER(PM) 0 0 0
VOLATILE ORGANIC COMPOUNDS(VOC) 2.13 1.40 1.40