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HomeMy WebLinkAboutAQ_F_0400058_20181120_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: 11/26/2018 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 Classification Small SIC: 2421 /Sawmills&Planing Mills General Permit Status Active NAICS: 321113/Sawmills Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Travis York J.Lynn Greene J.Lynn Greene MACT Part Subpart 6J Drying Manager Director of Admin. Director of Admin. NSPS: Subparrtt Dc (704)506-6087 Services/Safety Services/Safety (704)624-5098 (704)624-5098 Compliance Data Comments: q / Inspection Date 11/20/2018 Inspector's Name Mike Thomas Inspector's S' n�e: Operating Status Operating l/l Compliance Code Compliance-inspection �{G_ Action Code FCE Date of Signature: On-Site Inspection Result Compliance —Z Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 *HAP 2015 7.65 0.8100 7.10 1.78 19.36 7.00 1226.00 *Highest HAP Emitted inpounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 04/13/2016 NOV NCGS 143-215.108 Control of sources of air pollution; 06/23/2016 permits required. 04/13/2016 NOV 2D.1100 Control of Toxic Air Pollutants 06/23/2016 Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested 1) Directions: From FRO take 195 Bus S and merge onto US 301 S towards Parkton,turn right onto NC HWY 71 and continue to follow NC HWY 71 until HWY 74. Follow HWY 74 W 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. If no one is in the boiler building,you will need to call the facility contact at the Marshville office (phone number above)and have him meet you there. The Marshville office is only a few minutes away from the Peachland facility. 2) Safety Considerations: Standard DAQ safety equipment.Watch for lumber trucks on facility roads and forklifts in kiln and warehouse areas. 3) 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-Fred boiler using self-generated sawdust from the sawmill at this facility. 4) Permitted Emission Sources Emission _Emission Source [ COnfrol Control System Source ID Description j System ID Description Stoker type wood-feed Boiler Multi-cylone with 8 ES-1 F million Btu per hour maximum heat input(300 CD-MC 1 nine inch diameter (NSPS,NESIIAP) BHP) tubes Operating with 0%V.E. F (4) Four 62,steam-heated lumber drying kilns 62000 board feet capacity each N/A N/A Operating with 0%V.E. Two(2)steam-heated lumber drying kilns FES-3 28,000 board feet capacity each N/A N/A Operating with 0%V.E. F F Two(2)steam-heated lumber drying kilns ES 4 62,000 board feet capacity each N/A N/A Operating with 0%V.E. Insignificant/Exempt Activities: Source of Source of Title Source Exemption Regulation TAPS? I V Pollutants? IES-I Band saw mill for green lumber,inside 2Q.0102(g)(12) No Yes building IES-2 Circular saw mill for green lumber,inside 2Q .0102(g)(l2) F No Yes building I-LPGBoiler LPG-fired bailer,7.53 mmBtu/hr 2Q.0102(h)(1)(B) Yes Yes maximum heat input 5) Inspection Conference: On 20 November 2018 I, Mike Thomas of FRO DAQ conducted a compliance inspection of The Edwards Wood Products, Inc. -Peachland Plant. I met with the Facility Contact,Travis York. We discussed the following: a) I verified the FACFINDER information: no changes are needed. b) I reviewed the facility's logbook that contains the total amount of wood burned in the wood-fired boiler. To date the facility has combusted 6,878.6 tons of wood. c) Throughputs: Year 12 Month Consecutive Tons Combusted 2018 YTD 6,878.6 2017 6,485.8 2016 7,459.3 2015 7,169 2014 —1,100 2013 982 6) Inspection Summary: Mr.York led me on a tour of the facility which was operating, starting at the boiler building. The boiler is continuously fed by a conveyor system that in turn is fed by a hopper. The hopper is filled periodically from a stockpile of wood material storedjust outside of the building. I observed 0%V.E. from the boiler. We then observed the kilns,all of which were in operation. I observed 0%V.E.from each of the kilns. 7) Permit Stipulations: a) A.2 2Q .0304 PERMIT RENEWAL AND EMISSIONINVENTORYREQUIREMENT—Entire facility subject. Submit permit renewal application and EI at least 90 days prior to permit expiration. Appeared to be in compliance—The facility was due to submit their EI and Permit Renewal by 1 April 2016. Both the EI and Permit Renewal were received on I April 2016. 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 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 Ibs/mmBTU,which is below the maximum allowable. c) A.4 2D .0515 PARTICULATE CONTROL REQUIREMENT—"Particulates from Miscellaneous Industrial Processes"—Particulate matter emissions shall not exceed allowable emissions rates. Appeared to be in compliance—Compliance was determined during the most recent permit review based on operating the source 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 COMBUSTIONSOURCES. Emissions of sulfur dioxide from Boiler B 1 shall not exceed 2.3 lbs/mmBtu. Appeared to be in Compliance—The facility combusts only wood, and the AP-42 emissions factor for SO2 for wood combustion is 0.025 lbs/mmBtu. As long as the facility only combusts wood,compliance is expected. e) A.6 213 .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 boiler and from the kilns. f) A.7 2D .0524 NEW SOURCE PERFORMANCE STANDARDS—For the wood-fired boiler,the permittee shall keep monthly and total annually: amount of wood, in tons, combusted each calendar day and retain those records for at least 2 years. Appeared to be in compliance—Facility keeps detailed records of the amount of wood burned daily, monthly and total annually. 2018 year to date total amount of wood burned was 6,878.6 tons. g) A.8 2D .0535 NOTIFICATIONREQUIREMENT- 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. York. 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.York stated there have not been any complaints. i) A.10 2D .1100 TOXICAIR POLLUTANT EMISSIONS LIMITATIONAND REPORTING REQUIREMENT—Toxic limitations apply to Arsenic(.60 lbs/yr),Benzene(300 Ibs/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 6,878.6 tons of wood burned during 2018 year to date,which is below 41,000 tons per year maximum. The facility maintains a log of daily wood burned to document compliance with this condition. j) A.11 2D .1111 GENERAL AVAILABLE CONTROL TECHNOLOGY— "Subpart JJJJJJ,NESHAP Industrial, Commercial and Institutional Boilers at Area Sources"- 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—Initial notification was received in FRO on 7 September 2011; facility conducted the energy assessment in February of 2012 and the last annual tune-up was conducted in March 2018. NOCS was received via CEDRI on time. The Notice of Compliance Status was available during my 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.York brings these items with him when he comes to the inspection). k) A.12 21) .18 06 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.York stated that he has not received any complaints related to odors. 1) A.13 2Q .0711 TOXICAIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT—The Permittee shall operate and maintain facility emissions of the listed TAP,Cadmium, so as not to exceed 0.37 lbs/yr. Appeared to be in Compliance—Compliance was determined during the most recent permit review based on operating the source as described in the permit conditions. No changes have been made to operations since that determination. 8) 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). 9) Non-compliance History Since 2010 13 April 2016—Operation without a permit and exceeding limits. 10) Comments and Compliance Statement Edwards Wood Products Inc.Peachland appeared to be in compliance with the in their current air permit on 20 November 2018. 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