AQ_F_0400058_20220303_CMPL_NOV

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ROY COOPER = ``
Governor -
DIONNE DELLFGATTI
Secretary t•
MICHAEL ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
3 March 2022
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Chris Harrington,Director of EH&S
Edwards Wood Products,Inc.
Peachland,North Carolina 28133
Subject: Notice of Violation—Operation without an Air Permit
Edwards Wood Products,Inc.—Peachland; Air Permit No. 10146R03
Peachland,Anson County,North Carolina 06/04-00058
Fee Class: Small
Dear Mr. Harrington:
On 10 February 2022, Mike Thomas conducted a compliance inspection at your facility,
Edwards Wood Products,Inc-Peachland. On the day prior,you contacted Mr. Thomas and informed
him that you recently learned that this facility had installed a natural gas boiler without first obtaining
a permit. During the compliance inspection, Mr. Thomas verified that this facility installed and
began operation of a 16 mmBtu/hr(maximum heat input) natural gas-fired boiler in December 2021.
This facility is permitted to operate a 10.54 mmBtu/hr (maximum heat input) wood-fired boiler for
which modeling for specific air toxics was required and an air toxic compliance demonstration was
submitted and approved. The natural gas-fired boiler has pollutants in common with the modeled
wood-fired boiler and is not exempt from the toxics demonstration and is therefore not exempt from
permitting.
North Carolina General Statute 143-215.108(a) provides that "...no person shall do any of
the following things or carry out any of the following activities... unless that person has obtained a
permit for the activity from the Commission and has complied with any conditions of the permit:
1. Establish or operate any air contaminant source, except as provided in G.S. 143-
215.108A.
2. Build, erect, use, or operate any equipment that may result in the emission of an air
contaminant or that is likely to cause air pollution, except as provided in G.S. 143-
215.108A.
3. Alter or change the construction or method of operation of any equipment or process
from which air contaminants are or may be emitted."
Installing and operating the 16 mmBtu/hr (maximum heat input).natural gas-fired boiler
without first obtaining a permit is a violation of N.C.G.S. 143-215.108.
North Carolina Department of Environmental Quality I Division of Air Quality
E Fayetteville Regional Office 1 225 Green Street,Suite 714 1 Fayetteville,North Carolina 28301
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of E°y91 mudQum ✓ 910.433.3300 T 1 910.485.7467 F

Mr. Chris Harrington
3 March 2022
Page 2
As stated in the "subject" above, this letter represents a Notice of Violation for the cited
violation. This violation, and any future violation of an air quality regulation, is subject to the
assessment of civil penalties according to North Carolina General Statute 143-215.114A.
Please provide to this office, no later than 25 March 2022, a written response to this
Notice of Violation, including a completed and signed application for an air permit
modification with an air toxic compliance demonstration including the new boiler. The
response should detail the reason(s) for the failure to obtain an air permit for this new air emission
source and the steps that you plan to take or have taken to ensure future compliance with this
requirement. Permit application forms and instructions can be found on the DAQ website at:
hgps:Hdeq.nc.gov/about/divisions/air-quality/air-quality-permits/application-forms-
instructions/application-forms-air-quality-permit-construct-operate-non-title-v-title-v-facilities
The Division strongly recommends that you carefully examine your current permit
stipulations. If you have questions concerning the permitting requirements or your permitting
options,please contact Jeffrey Cole,Permits Coordinator, at(910)433-3374.
Sincerely,
Heather S. Carter
Regional Supervisor
Division of Air Quality,NCDEQ
HSCmst
cc:FRO Facility Files
North Carolina Department of Environmental Quality I Division of Air Quality
Of /j/ Fayetteville Regional Office 1 225 Green Street,Suite 714 1 Fayetteville,North Carolina 28301
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910.433.3300 T 1910.485.7467 F