AQ_F_0400058_20220210_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: 02/11/2022
Facility Data Permit Data
Edwards Wood Products,Inc.-Peachland Permit 10146/R03
160 Pulpwood Yard Road Issued 11/29/2017
Peachland,NC 28133 Expires 5/31/2024
Lat: 34d 59.5500m Long: 80d 17.7000m Class/Status Small
LA1
2421 /Sawmills&Planing Mills General Permit Status Active
S: 321113/Sawmills Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
MACT Part 63: Subpart 6J
Chris Harrington Chris Harrington Chris Harrington NSPS: Subpart Dc
Director of EH&S Director of EH&S Director of EH&S
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 02/10/2022
Inspector's Name Mike Thomas
Inspector's Signature: Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: Inspection Result Violation
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PMIO * HAP
2015 7.65 0.8100 7.10 1.78 19.36 7.00 1226.00
*Highest HAP Emitted inpounds)
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
I. Directions:
From FRO take Green Street to Gillespie and merge onto 195 BUS/301 S towards Parkton,turn right onto
NC HWY 71 and continue to follow NC HWY 71 for 28 miles until HWY 74. Follow HWY 74 W for 68
miles to Wadesboro. 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. You will need to call the facility contact at the Marshville

office(phone number above)and have the Facility Contact,Mr. Harrington meet you there. The Marshville
office is only a few minutes away from the Peachland facility.
II. Safety Considerations:
Standard DAQ safety equipment. Watch for lumber trucks on facility roads and forklifts in kiln and
warehouse areas.
III. Facility and Process 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 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.
IV. Permitted Emission Sources
Emission Emission S©urce +Ccn#rnl Cntc�i stn
©urce ID,: ; ~ llescript€�n System tU I7►escriptn
_.
Stoker type wood-fired Boiler 4. m
5 Multi-cylone with 8
ES-1 10.54 million Btu per hour maximum heat input(300
(NSPS,NESHAP) £ BHP) CD-MC1 nine inch diameter
r tubes
Boiler is currently inoperable.
Four(4)steam-heated lumber drying kilns
ES-2 62,000 board feet capacity each N/A N/A
Operating with 0%V.E.
Two(2)steam-heated lumber drying kilns
ES-3 28,000 board feet capacity each N/A N/A
Not at the facility.
Two(2)steam-heated lumber drying kilns
ES-4 62,000 board feet capacity each N/A N/A
See below.
Insignificant/Exempt Activities:
r
once � �x�e�n Ian� ��xinl��tt ou�rc of ��re c�f �te
[t�liit �
IES-1
Band saw mill for green lumber,inside 2Q .0102(g)(12) No I Yes
building t
4
p...u..r.w:.��...ha.z.«a.........a.a..vF... ..�w...:e.-.n....a...:.aa-�...�,.o..�..a....w.�.n........� .a...,.r�,.
IES-2
Circular saw mill for green lumber, inside 1 2Q .0102(g)(12) e No Yes
building
I f
I-LPGBoiler 2Q .0102(h)(1)(B)
LPG-fired boiler,7.53 mmBtu/hr ! Currently dismantled. yes
maximum heat input
Facility plans to remove it Yes
from the permit.
V. Inspection Summary:
On 10 February 2022,I,Mike Thomas of FRO DAQ,conducted a compliance inspection of The
Edwards Wood Products,Inc. -Peachland Plant. I met with the Facility Contact,Chris Harrington.
Mr. Harrington reviewed the FACFINDER information and indicated that no corrections were

needed. During a telephone conversation with Mr. Harrington the previous day, he informed me that
the facility had installed a natural gas fired boiler in early December 2012 and that to his knowledge
no permit modification was obtained prior to the installation and use of the boiler. I inquired about
the existing wood fired boiler and was told that it was currently not operational and not plumbed but
that the facility intended to keep it on the permit as a back up to the natural gas boiler. He also said
that there are errors in the list of permitted emission sources in the facility's current air permit. The
current air permit lists a total of six 62,000 board feet capacity steam kilns(ES-2 and ES-4)and two
28,000 board feet capacity steam kilns(ES-3). However,the facility only has four 62,000 board feet
capacity steam kilns.
Mr. Harrington led me to where the new natural gas fired boiler is located. The boiler is made by
Cleaver Brooks and is a 1991 model. The boiler is rated at 16,738,000 Btu. The boiler is not
designed to burn any fuel other than natural gas. Mr.Harrington then led me to the wood fired boiler,
which is no longer in use. Fuel in the form of saw dust is still located in the bin that feeds the boiler
but the boiler is not in use and is no longer connected/plumbed to anything.
I observed the four kilns(ES-2)which were operating.I observed no issues with the kilns.
I inquired if there were any other equipment onsite such as generators or fire pumps. Mr. Harrington
stated that there were none.
a) Throughputs:
Year 12 Month Consecutive Tons Combusted
2021 6,474.3
2020 5,817.7
2019 4,554.9
2018 6,878.E
2017 6,485.8
2016 7,459.3
2015 7,169
2014 _1,100
2013 982
VI. Permit Stipulations:
a) A.2 2D .0202 PERMIT RENEWAL AND EMISSION INVENTOR Y REQUIREMENT—Entire
facility subject. Submit permit renewal application and EI at least 90 days prior to permit expiration.
Appeared to be in compliance—The facility's next deadline for submission of their emissions
inventory and air permit renewal is February 2024 for the 2023 calendar year.
b) A.3 2D .0504 PARTICULATE CONTROL REQUIREMENT—"Particulates from Wood Burning
Indirect Heat Exchangers"-Particulate matter emissions from ES-1 shall not exceed 0.41 lbs/mmBTU.
Appeared to be in compliance—The facility only burns wood in ES-1. The AP-42 factor for
particulates from wood is 0.347 lbs/mmBTU, which is below the maximum allowable. The facility
stopped operating this boiler in December 2021, however they intend to keep it on the permit.

c) A.4 2D .0515 PARTICULATE CONTROL REQUIREMENT—"Particulates from Miscellaneous
Industrial Processes"—Particulate matter emissions from all non-combustion sources shall not exceed
allowable emissions rates.
Appeared to be in compliance—Compliance was determined during the most recent permit review
based on operating the sources as described in the permit conditions. No changes have been made to
operations since that determination.
d) A.5 2D .0516-SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES. Emissions of
sulfur dioxide from wood fired boiler ES-1 and new 16.7 mmBtu natural gas fired boiler shall not
exceed 2.3 lbs/mmBtu.
Appeared to be in Compliance—As of December 2021,the facility currently only combusts natural
gas. The AP-42 emission factor for SO2 for NG combustion is 0.0006 lb/mmBtu. The facility is also
permitted to operate a wood fired boiler. The AP-42 emissions factor for SO2 for wood combustion is
0.025 lbs/mmBtu. As long as the facility only combusts wood in this boiler,compliance is expected.
e) A.6 2D .0521 VISIBLE EMISSIONS CONTROL REQUIREMENT—Visible emissions from the
emission sources shall not be more than 20% in opacity.
Appeared to be in Compliance—I observed 0%V.E. coming from the new 16.7 mmBtu natural gas
boiler and from the kilns.
f) A.7 2D .0524 NEW SOURCE PERFORMANCE STANDARDS—For the wood-fired boiler,the
permittee shall keep the amounts of each fuel combusted during each month and retain those records
for at least 2 years. As it applies to the new 16.7 mmBtu natural gas boiler,the Permittee shall keep
records of the amount of natural gas burned monthly.
Appeared to be in Compliance—Facility only combusted wood during the period that ES-1 was in
operation and maintained daily,monthly and annual totals. Records are maintained for greater than
two years. The facility stopped operating this boiler in December of 2021.
For the new 16.7 mmBtu NG-fired boiler,the facility is complying with the requirements by having
records of monthly fuel useage.
g) A.8 2D .0535 NOTIFICATION REQUIREMENT- The facility is required to notify DAQ if excess
emissions occur for more than a 4-hour period caused by a breakdown or other abnormal condition.
Appeared to be in Compliance—The facility has had no exceedances,breakdowns, or abnormal
conditions requiring notification according to Mr. Harrington.
h) A.9 2D .0540 FUGITIVE DUST CONTROL REQUIREMENT—Permittee shall not cause or allow
fugitive dust emissions to contribute to complaints or excess VE beyond the property boundary.
Appeared to be in Compliance-I observed no excess dust from the roads. Mr. Harrington stated
there have not been any complaints. No complaints regarding dust from this facility have been
received at FRO.
i) A.10 2D .1100 TOXIC AIR POLL UTANT EMISSIONS LIMITATIONAND REPORTING
REQUIREMENT—Toxic limitations apply to Arsenic(.60 lbs/yr),Benzene(300 lbs/yr), Chromium
(.15 lbs/yr),Formaldehyde(.0464 lbs/hr), and Hydrogen chloride(.20 lbs/hr). Combusted wood is
limited to 4.68 tons/hr,not exceeding 41,000 tons per consecutive 12-month period. Records shall be
kept demonstrating compliance for these limits.
Appeared to be in Compliance— The log book shows a total of 6,474.3 tons of wood burned during
2021,which is below 41,000 tons per year maximum. The facility maintains a log of daily wood
burned to document compliance with this condition. Entries were complete and up to date. The
facility stopped operating this boiler in December of 2021.

j) A.11 2D .1111 GENERAL AVAILABLE CONTROL TECHNOLOGY— "Subpart JJJJJJ,NESHAP
Industrial, Commercial and Institutional Boilers at Area Sources." Requirements: Initial notification,
biennial tune-ups beginning 21 Mar 2014,NOCS, one-time energy assessment by 21 March 2014
(with notice of compliance by 19 July 2014),records of biennial compliance report(beginning 1 Mar
15 - submitted only if deviation or DAQ request)and pertinent maintenance(since 21 Mar 2014).
Appeared to be in Compliance—The facility's new 16.7 mmBtu natural gas fired boiler is exempt
from 6J requirements.
The following information pertains to the existing wood fired boiler that is no longer in use, as of
December 2021. Initial notification was received in FRO on 7 September 2011; facility conducted the
energy assessment in February of 2012. NOCS was received via CEDRI on time. The Notice of
Compliance Status was available during the previous inspection. The facility's 2015 Biennial
Compliance Certification was on file in Mr. Green's office in Marshville as was the 2017 Biennial
Compliance Certification(Mr. Harrington brings these items with him when he comes to the
inspection). The most recent biennial tune-up was completed on 23 January 2020.
k) 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.
Appeared to be in Compliance—I detected no objectionable odors within or beyond the facility's
property. Mr. Harrington stated that he has not received any complaints related to odors. FRO has not
received any complaints of odor regarding this facility.
1) A.13 2Q .0711 TOXIC AIR POLL UTANT EMISSIONS LIMITATION REQUIREMENT—The
Permittee shall operate and maintain facility emissions of the listed TAP, Cadmium, so as not to
exceed 0.371bs/yr.
Appeared to be in Compliance-The facility is no longer operating the wood-fired boiler(ES-1)
and is now operating a 16 mmBtu/hr NG fired boiler which is expected to comply with TPERs
based on best available emission factors. Based on the calculations from the NCDAQ emissions
spreadsheet for natural gas combustion,Cadmium emissions should be 0.00 for this source.
VII. 112R Status
This facility does not store any of the listed chemicals above the threshold quantities, and is not
required to maintain a written Risk Management Plan(RMP).
VIII. Non-compliance History Since 2010
13 April 2016—Operation of two 40,000 boardfoot kilns without a permit and exceeding wood-fired
boiler fuel limits based on conducted modeling(no apparent AAL violation occurred).
IX. Comments and Compliance Statement
Edwards Wood Products Inc. Peachland appeared to be operating in Violation of their current air
permit on 10 February 2021. The facility violated General Statute 143-215.108 by installing and
operating a 16 mmBtu/hr NG-fired boiler without first obtaining a permit. This source cannot be
exempt from permitting since the wood-fired boiler was modeled and this source has common
pollutants. Therefore,a permit and modelling demonstration is required.
I recommend issuing a Notice of Violation for installing and operating the NG-fired boiler without
first obtaining a permit.
Pink Sheet Comments:

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.
/mst