AQ_F_1900091_20181207_CMPL_InspRpt (4)

NORTH CAROLINA DIVISION OF Raleigh Regional Office
AIR QUALITY Carolina Wood Enterprises,Inc.
NC Facility ID 1900091
Inspection Report County/FIPS: Chatham/037
Date: 12/07/2018
Facility Data Permit Data
Carolina Wood Enterprises,Inc. Permit 08714/R05
902 South Chatham Avenue Issued 4/10/2014
Siler City,NC 27344 Expires 3/31/2022
Lat: 35d 42.8070m Long: 79d 27.5240m Classification Synthetic Minor
SIC: 2421 /Sawmills&Planing Mills General Permit Status Active
NAICS: 321999/All Other Miscellaneous Wood Product Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Clay Van Culberson Jr. Clay Van Culberson Jr. Clay Van Culberson Jr. MACT Part 63: Subpart 6JNSPS: Subpart Dc
President President President
[phone] [phone] [phone]
Compliance Data
Comments: In Compliance
Inspection Date 12/07/2018
Inspector's Name Matthew Mahler
Inspector's Signature: �� Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: %/Zy l Z� C, On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2012 186.37 0.5300 4.70 33.06 13.00 60.19 3182.00
2008 102.96 0.3700 3.23 18.60 8.80 10.90 1785.50
*Highest HAP Emitted(in pounds)
Five Year Violation History:
Date Letter Tyne Rule Violated Violation Resolution Date
03/14/2017 NOV 2Q .0315 Synthetic Minor Facilities 03/29/2017
03/16/2016 NOV Part 63 -NESHAP/GACT Subpart JJJJJJ Industrial, 05/05/2016
Commercial and Institutional Boilers at Area Sources
03/16/2016 NOV Permit Late Report(excluding ACC) 05/05/2016
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested
(n DIRECTIONS TOXACILITY: From RRO turn left on Barrett Drive,right on Six Forks Road,then turn left to merge onto
I-440W. Follow I-440 W for 7.4 miles, then keep left to continue on US-IS for 32.5 miles. Take the exit and merge onto
US-421 S. Follow US-421 S for 18.4 miles;take exit 168 toward Siler City. Turn left onto SR 2113 (.2 mi),continue onto S
Chatham Avenue Extension(1.8 mi),continue onto S Chatham Avenue(0.4 mi). Facility is 902 S Chatham Avenue on right.

(In FACILITY DESCRIPTION: Carolina Wood Enterprises is a lumber mill that receives southern yellow pine trees and then
produces kiln dried lumber.The facility operates on a 40-hr workweek employing—37 people and producing—320,000 board
feet/week. The normal hours of operation are 6:30 am—5:00 pm,Monday—Friday. The facility is normally scheduled down
the week of July 4 and the week of Christmas.
Safety notes: Standard PPE(hard hat,safety glasses,steel-toed shoes)are to be worn.Be watchful of heavy machinery and stay
close to your escort when touring the facility.
INSPECTION SUMMARY: On December 7, 2018, I (Matt Mahler) visited Carolina Wood Enterprises to conduct an air
quality inspection. I met with Mr. Clay Van Culberson,President and Facility Contact. We reviewed the permit stipulations.
Mr.David Purvis,Maintenance Manager,assisted with the records review. Mr.Purvis then led me on a tour of the facility. All
of the permitted emission sources were operating. The boiler was running at with 0-5%visible emissions(VE)observed from
its stack.The kiln was currently drying a load of green wood;steam was escaping from the kiln. No VE was observed from any
of the cyclones.
Overall,the facility appeared to be well run and maintained from an air quality perspective.
(IV) PERMITTED EMISSION SOURCES:
Emission Emission Sourcei Control Control System
Source ID Description System ID Description
ES-B1 (NSPS) rperh
fired boiler(28.7 million Btu AMC-1,MC-2 primary multicyclone((16)9-inch
urmaximum heat input) tubes),secondary multicyclone((44)
ng fly ash reinjection , 6-inch tubes)
ES-3 lwood planing operation I C-3 cyclone(96 inches in diameter)
ES-5 steam heated wood kiln NIA NIA
ES-2 ichipper I C-2 cyclone(48 inches in diameter)
ES-4 I sawdust transfer point C-4 (cyclone(48 inches in diameter)
All equipment was verified and operating during the inspection.
(V) SPECIFIC CONDITIONS AND LIMITATIONS:
A.1. APPLICABLE REGULATIONS —The Permittee shall comply with Title 15A NCAC, 2D .0202, 2D .0504, 2D .0512, 2D
.0516,2D.0521,2D.0524(40 CFR 60,Subpart Dc),2D.0535,2D.0540,2D.I 111 (40 CFR 63,Subpart JJJJJJ),2D.1806 and
2Q .0315.
Appeared to be in compliance—see below.
A.2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee, at least 90 days prior to the
expiration date of this permit,shall request permit renewal and submit the air pollution emission inventory report for the 2020
calendar year. �.
Appeared to be in compliance—I reminded Mr.Van Culberson of the March 31,2022 permit expiration, and the CY
2020 emissions inventory and the permit renewal,which are due by December 31,2021.
A.3. PARTICULATE CONTROL REQUIREMENT—As required by 15A NCAC 2D.0503,particulate matter emissions from the
wood burning indirect heat exchanger(ID No.ES-B1)shall not exceed 0.55 lbs/MMBtu
Appeared to be in compliance—compliance was determined during permit review process provided that the facility
operates using permitted air pollution control equipment.
A.4. PARTICULATE CONTROL REQUIREMENT — As required by 15A NCAC 2D.0512, the Permittee shall not discharge
particulate matter caused by the working, sanding, or finishing of wood without providing, as a minimum for its collection,
adequate duct work and properly designed collector.

Appeared to be in compliance—no VE were observed from the cyclones or any ductwork, it appeared that the dust
collection system was working properly. Mr. Purvis informed me that the system is checked weekly and repairs are
made as needed. Repairs are documented in the cyclone log.
A.5. SULFUR DIOXIDE CONTROL REQUIREMENT—As required by 15A NCAC 2D .0516 sulfur dioxide emissions from the
combustion sources shall not exceed 2.3 pounds per million Btu heat input.
Appeared to be in compliance — the facility only burns wood, which has a sulfur dioxide emission factor of 0.025
lbs/MMBtu as referenced in USEPA AP-42 Table 1.6-2.
A.6. VISIBLE EMISSIONS CONTROL REQUIREMENT—As required by 15A NCAC 2D.0521,VE from sources shall not be>
20%opacity when averaged over a six-minute period.
Appeared to be in compliance-VE was 0% opacity from the cyclones and 0-5%from the boiler stack.
A.7. 15A NCAC 2D .0524 NEW SOURCE PERFORMANCE STANDARDS —For the wood-fired boiler (ID No. ES-B1), the
Permittee shall comply with NSPS as promulgated in 40 CFR 60,Subpart Dc,including Subpart A"General Provisions."
a. NSPS Recordkeeping Requirements-the Permittee is required to maintain records of
i. the amounts of each fuel combusted during each month;and
ii. all records shall be maintained for a period of two years.
Appeared to be in compliance—the facility keeps track of the number of revolutions of the sawdust feed screw to ES-BI
and converts it to tons using the formula of 3.42 lbs per screw revolution. Mr. Purvis showed me the notebook
containing sheets of daily revolution readings and total amount combusted per month. The 2018 entries include
monthly totals of sawdust: January-433.15 tons,February—513.15 tons,March—432.50 tons. The 2017 yearly total
was recorded as 5,008.93 tons of sawdust. The entries of sawdust combusted from January through November 2018
totaled 4,580.2 tons.
A.8. NOTIFICATION REQUIREMENT—As required by 15A NCAC 2D .0535 the Permittee of a source of excess emissions
lasting>4 hr. and results from a malfunction,a breakdown of process or control equipment or other abnormal condition shall
notify DAQ-RRO by the next business day.
Appeared to be in compliance—Mr.Van Culberson stated that no such incidents have occurred.
A.9. FUGITIVE DUST CONTROL REQUIREMENT—As required by 15A NCAC 2D.0540,the Permittee shall not cause/allow
fugitive dust to cause/contribute to substantive complaints or excess VE beyond the property boundary.
Appeared to be in compliance—no fugitive dust was observed.No fugitive dust complaints are on file at RRO.
A.10. GENERALLY AVAILABLE CONTROL TECHNOLOGY - For the wood-fired boiler(ID No. ES-B1), the Permittee shall
comply with 15A NCAC 21) .1111, as promulgated in 40 CFR 63, Subpart JJJJJJ (6J), " National Emission Standards for
Hazardous Air Pollutants for Area Sources: Industrial,Commercial, and Institutional Boilers", including Subpart A"General
Provisions." See permit for extensive details.
Appeared to be in compliance—subsections of this stipulation are addressed as follows:
a. Compliance Dates—The Energy Assessment was conducted on May 19,2014; the report was dated July 14,2014.
b. Boiler Tune-up Requirements—The initial boiler tune-up was conducted on March 25,2014,in response to the March
21, 2014 NOD. The boiler runs consistently, so it is subject to biennial tune-ups. Records show a boiler tune-up was
conducted on February 18,2016. The most recent boiler tune-up was completed on January 18,2018.
c. Notification and Reporting Requirements — 2017 inspection notes that the revised Initial Notification was dated
February 25,2016.
d. Recordkeeping Requirements—Mr.Van Culberson has a file with copies of the Energy Assessment, the initial boiler
tune-up record, and the February 18, 2016 boiler tune-up record. Mr. Purvis was unable to produce a copy of the
January 12, 2018 tune-up report. Mr. Purvis stated that he would have Utility Plant Solutions email a copy of the
report emailed to his office; afterwards, he forwarded a copy of the report to the Raleigh Regional Office (RRO) on
December 10,2018.

A.11. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS —As required by 15A NCAC 2D .1806 the permittee shall
keep objectionable odors from advancing beyond the boundaries of the facility.
Appeared to be in compliance—only very mild wood odors were detected during the inspection; no complaints have
been filed against the facility.
A.12 LIMITATION TO AVOID 15A NCAC 2Q.0501 -Pursuant to 15A NCAC 2Q.0315"Synthetic Minor Facilities,"to avoid the
applicability of 15A NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit," as requested by the Permittee,
facility-wide emissions shall be less than 100 tons PM10 per 12-month period.
a. Operations Restrictions—sawdust combusted in ES-B 1 shall not exceed 8,100 tons per 12-month period.
b. Inspection and Maintenance Requirements-
i. Cyclone Requirements-the Permittee shall perform an annual inspection and periodic I&M of the cyclone
system.
ii. Multi-Cyclone Requirements - the Permittee shall perform an annual inspection and periodic I&M of the
multi-cyclone system.
c. Recordkeeping Requirements—
i. The Permittee shall record monthly and total annually the tons of sawdust combusted.
ii. A log book shall be kept on site for cyclones and multicyclones and made available to DAQ personnel upon
request.The Permittee shall record all inspection,maintenance and monitoring requirements listed above in
the log book.Any variance from the manufacturer's recommendations shall be investigated with corrections
made and date of actions recorded in the log book
Appeared to be in compliance—I reviewed the boiler fuel combustion records onsite, and it appeared complete and
up-to-date. The cyclone / multicyclone I&M log were not available for review during the inspection. Mr. Purvis
emailed a copy of the annual cyclone and multicyclone inspections to the RRO on December 10,2018. The most recent
annual inspection of the cyclone and multicyclone was conducted January 2, 2018. The most recent annual sawdust
report was received at the RRO on January 18,2018 and reviewed as complete. 5008 tons of sawdust were reported for
2017,which is less than the limit of 8,100 tons per 12-month period.
(VI) GENERAL PERMIT CONDITIONS:
B.14 PERMIT RETENTION REQUIREMENT-The Permittee shall retain a current copy of the air permit at the site.The Permittee
must make available to personnel of the DAQ,upon request, the current copy of the air permit for the site.
Appeared to be in compliance — Mr. Van Culberson presented a copy of Air Permit No. 087141105 during the
inspection.
B.15 CLEAN AIR ACT SECTION 112(r)REQUIREMENTS-Pursuant to 15A NCAC 2D .2100"Risk Management Program," if
the Permittee is required to develop and register a risk management plan pursuant to Section 112(r)of the Federal Clean Air
Act,then the Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part 68.
Not applicable—Carolina Wood Enterprises is not subject to 112(r).
(M) INSIGNICAN 1/EXEMPT SOURCES: The facility does not have any listed insignificant sources in its permit. However,
one 8,000-gallon diesel fuel talk was observed outside the office building. This should be added in the next permit revision.
(VIM EMISSION INVENTORY: Per the header on the first page of this report, emissions of all listed pollutants were higher in
2012 than in 2008.However,the DAQ internal comments in I-Beam's Emissions Data(ED)module note that comparing data
of the two inventory data is not feasible due to differences in calculating emissions,performed by different consultants who
used different control device efficiencies and different emission rates.For example,in 2008 the manufacturer source test data
was used and was found to be incorrectly calculated,whereas,in 2012 the default DAQ data was used.
(IX) SOURCE TEST REVIEW: Carolina Wood Enterprises has no history of source testing,and its current permit lacks a source
test requirement.

(X) COMPLIANCE HISTORY: A review of DAQ files revealed the following compliance actions triggered by the facility:
• March 14,2017—Notice of Violation was issued for the late submittal of the 2016 annual report.
• March 16,2016—Notice of Violation was issued for the late submittal of the 2015 annual report.
• April 15,2015—a Notice of Deficiency(NOD)was issued for failure to submit the annual report by the due date;
• March 28,2014—an NOD was issued for failure to comply with the Boiler GACT rule by the compliance due date;
• January 10,2014—an NOD was issued for failure to submit a permit renewal application and emissions inventory by
the due date.
• March 27, 2009—a Notice of Violation/Notice of Recommendation for Enforcement(NOV/NRE) was issued for
repeated failures to submit annual reports. A total of$1188.00 was assessed against the facility.
• March 22,2007—an NOWNRE was issued regarding the delinquent annual report for the calendar year 2006.A civil
penalty of$500.00 plus$188.00 investigative costs was assessed and paid in full.
• March 3,2005—an NOV was issued regarding the delinquent annual report for the calendar year 2004.
• June 7, 2004 — an NOV was issued regarding New Source Performance Standards (Subpart Dc) reporting
requirements.
(Xn CONCLUSIONS/RECOMMENDATIONS: At the time of the inspection,the facility appeared to be in compliance with all
permitting requirements.The diesel fuel tank observed should be added to the Insignificant/Exempt list. It is recommended that
the facility be re-inspected within one year. 0
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