AQ_F_0400009_20190409_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Hornwood Inc
NC Facility ID 0400009
Inspection Report County/FIPS: Anson/007
Date: 04/22/2019
Facility Data Permit Data
Homwood Inc Permit 04888/R14
766 Hailey's Ferry Road Issued 5/23/2014
Lilesville,NC 28091 Expires 4/30/2022
Lat: 34d 57.2115m Long: 79d 57.6182m Class/Status Synthetic Minor
SIC: 2258/Warp Knit Fabric Mills Permit Status Active
NAICS: 313312/Textile and Fabric Finishing(except Broadwoven Fabric)Mills Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Benny Burr Charles Home Dale Kelly NSPS: Subpart Dc
Environmental Manager Owner Plant Engineer
[phone] [phone] [phone]
Compliance Data
Comments: /
Inspection Date 04/09/2019
� ®/ Inspector's Name Jeffrey D. Cole
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: ev/2Z/1�.7 On-Site Inspection Result Violation
Total Actual emissions in TONS/YEAR:
TSP SO2 NOX VOC CO PMIO * HAP
2013 8.97 0.0500 6.35 10.30 5.32 8.97 194.60
2008 23.58 0.0400 5.00 16.01 4.14 23.46 1878.00
*Highest 14AP 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 TO SITE: From FRO,take Hwy 401 S to Wagram,then right on Wire Road past Laurel
Hill.Turn right(west) onto Hwy 74 and travel 27 miles. Turn left onto Hailey's Ferry Rd/ SR 1801 /Pit
Road;the facility is located—1/4 mile away, on the right. Check in at the guard house prior to entry.
H. SAFETY: Standard FRO safety gear. Inspectors should be wary of hot surfaces.
III. FACILITY DESCRIPTION: Homwood, Inc. is a textile company that warps,weaves, dyes yarn,heat-
sets(tenter frame finishes) and doffs(textures)nylon and polyester knit fabrics. They produce baseball
uniforms, automobile seat fabric, cloth for reverse osmosis water purification, gauze liners for tennis
shoes,and cowboy shirts to name a few.
This process may be divided into several distinct operations as follows:
Warping: Yarn is spun onto a single spool for processing in the knitting room. Yarn may also be draw
warped which draws the diameter of the yarn down by heat and tension, and effectively reduces the size
of the yarn.
Knitting Room: Spools go onto a mandrel that feeds the knitting machines.
Middle Warehouse: This is where both finished and unfinished fabric is stored until either future
processing is done or shipped to the customer.
Dye House: Dye is added to the fabric in one of two processes, beam orjet dying. In beam dying,fabric
is wound onto a beam with holes that allow the dye to pass through. The dye solution is pumped from the
rear of the chamber and passes through holes in the beam and out through the fabric. In jet dying,the
cloth is pulled through a tube in the top of the dye chamber by means of a roller and is constantly in
motion through a dye water solution in the bottom of the chamber.
Finishing: Cloth is passed through one of four tenter frames which heat sets the fabric to reduce
shrinking and stretching; chemicals which stiffen or coat the material may be added.
Napping: One of three things may be performed on the material during this process. The fabric will be
napped which gives it the appearance of fleece, or shearing which cuts off the top of the fleece, or sueded
which sands the fabric.
Mist Eliminators: The exhaust air from the tenter frames flows through a pre-filter that takes out some
of the dry particles with a one-inch fiberglass mesh using two trays to pass the air through. In
Condenser/Mist Eliminator(ID No. CD-2),the air then passes over four(4)cold water coils and six(6)
spray rings that both condense the vapor prior to the mist eliminator. In Condenser/Mist Eliminator(ID
No. CD-1),the air passes over six(6) spray rings that help condense the vapor prior to the mist
eliminator. There are no cooling coils in CD-1. Both mist eliminators house sixteen(16)two-inch wire
mesh cylinders that are each surrounded by a fiberglass mesh. The condensed vapor passes through the
center of these filter tubes and then proceeds out the stack. The rinse water is collected at the bottom of
each collector unit and sent through oil/water separators to a single holding tank for collection and
disposal. Prior to the units being shut down for cleaning,jet nozzles located at the bottom center of each
filter tube are used to spray wash water into each.

The facility employs about 360 people and operates 24 hours per day, 6 days per week, 52 weeks per
year.
Throughputs:
2018 4,365,985
2017 7,636,000
2016 8,119,816
2015 7,908,000
2014 7,937,000
2013 10,312,041
IV. INSPECTION SUMMARY:
On 9 April 2019, I Jeffrey Cole and Evangelyn Lowery-Jacobs of FRO DAQ,conducted a compliance
inspection of Homwood,Inc. in Lilesville, Anson County. The facility was operating at the time of the
inspection. Upon approaching the facility from the front parking area we did not detect any visible
emissions from the two Condenser/Mist Eliminators and the rear of the facility. However, since it was a
cloudy overcast day we proceeded to the rear of the facility to observe the two Condenser/Mist Eliminator
stacks. From the rear of the facility we observed visible emissions from Condenser/Mist Eliminator
CD-1. We immediately went to the facility's front reception area to begin our inspection and to
specifically get to a proper Method 9 observation location on the facility's roof. We were told that the
facility contact, Mr. Dale Kelly, was out running an errand and not available. I told the receptionist that
we needed an escort immediately to begin our inspection. We were quickly greeted by Mr. Jay Stewart,
Maintenance Supervisor,who escorted us to the roof.
We found a spot on the roof that met the requirements for a proper Method 9 observation and Ms.
Lowery-Jacobs began the observation. During the observation Mr. Kelly met us on the roof. I told Mr.
Kelly that we would speak with him after we completed our observation. We were able to record a 24-
minute Method 9 observation before rain forced us off the roof. Before leaving the roof I pointed out to
Mr. Kelly the opacity we had been observing from Condenser/Mist Eliminator CD-I. He stated that he
had seen visible emissions around 27 March 2019 but had not had the chance to observe from the roof or
to inquire from his maintenance people what might be the cause. While on the roof, we also noted what
appeared to be VE at—5%opacity from the stack for Condenser/Mist Eliminator(ES ID No. CD-2).
Upon reentering the facility,we went to the control panel, on the inside wall near the Condenser/Mist
Eliminators, which graphically displays all of the unit's parameters. These parameters were as follows:
Condenser/Mist Eliminator(ES ID No. CD-1)
FME Inlet Temperature(°F) 250
FME Outlet Temperature(° F) 111
Pre-Filter Differential Pressure(Inches of H2O) 0.15
Overall(i.e.,Post-Filter) Differential Pressure (Inches of H2O) 10

Condenser/Mist Eliminator(ES ID No. CD-2)
FME Inlet Temperature(°F) 277
FME Outlet Temperature(°F) 149
Pre-Filter Differential Pressure(Inches of H2O) 3.4
Overall(i.e.,Post-Filter)Differential Pressure (Inches of H2O) 2.3
I noted to Mr. Kelly that maintenance log for CD-1 showed that the overall differential pressure was
reading 10 inches of H2O for 7 separate readings on 7 and 8 April 2019 while the column heading of the
log page showing that a pressure in the"good"range was between 3 to 6 inches of H2O. I also noted that
there was only a"93"noted in the notes section of the log for each operational day for each of the 7
separate readings. I asked Mr. Kelly what the"#3"stood for and he said that stood for the source,ES ID
No. Tenter 3 being the only source in operation when CD-1 was in operation during that time period. I
asked where the person filling out the log would have recorded a problem or its resolution and Mr.Kelly
stated it should be in the notes column of the log. After this we continued with our inspection.
We then went to Mr. Kelly's old office where the facility keeps their maintenance records. Mr. Kelly was
able to produce all maintenance and inspection records I requested and was able to produce the
production records and the natural gas usage records both monthly and annually for 2018. Mr. Kelly
verified the FacFinder data and he stated that no changes to the FacFinder were necessary. Mr. Kelly was
able to produce the facility's latest air quality permit.
I asked Mr.Kelly if fuel oil was combusted since the last inspection and specifically during the most
recent annual tune-up on the boiler. Mr. Kelly explained that facility had not had its natural gas supply
curtailed and had not performed a tune-up on their permitted boiler(ES ID No. Main-031)since the last
inspection in April 2018. Mr. Kelly stated that they planned to perform a tune-up in late May 2019 on
both natural gas and No. 2 fuel oil. I reminded Mr. Kelly that his Method 9 reading exemption
determined during his last Method 9 testing had expired on 3 June 2018 and that they would need to have
Method 9 reader conduct a VE observation during the tune-up when firing No. 2 fuel oil. Mr. Kelly
stated that he understood this requirement.
We then proceeded to the boiler room where I observed the Natural gas/No. 2 fuel oil-fired boiler(ID No.
Main-031),the Natural gas-fired therminol heater(ID No. I-Main-058)and the Natural gas/No. 2 fuel oil-
fired boiler(ID No. I-03)both operating on NG at 0%opacity. The Natural gas/No. 2 fuel oil-fired
therminol heater(ID No. I-01)was not operating.
We then had an exit conference with Mr. Kelly where I told Mr.Kelly that he would be receiving a letter
from our office about the apparent emissions violation observed. Mr.Kelly stated that he would have his
maintenance people open up and inspect Condenser/Mist Eliminator CD-1 during their facility's
shutdown and determine why emissions were exceeding their permitted limits. He also stated he would
let us know in an email of the results of the inspection.
On 15 April 2019,Mr.Kelly emailed me copies of the inspection work orders dated 11 through 12 April
2019 showing that the company's maintenance personnel had entered the Condenser/Mist Eliminator
CD-1 to ascertain what was causing the excess emissions. They had removed and replaced all of the
fiberglass filters(which surround metal cages)with clean filters. These clean filters had been pre-staged
for their annual(done semiannually)inspection and maintenance scheduled for July 2019. In examining

the removed filters,they found that a number of the filters had a hard coating and would not allow airflow
to pass through them and thus reduce particulate emissions. Mr. Kelly stated that their normal periodic
maintenance procedure for the condenser/mist eliminator was for the maintenance crew to spray the filters
(while in place)with a cleaning solution and then thoroughly rinsing each filter. This is done at the end
of each week's production. He suspects that some of the filters weren't rinsed thoroughly and the heat
from the tenter frames entering the condenser/mist eliminator hardened the chemical solution on the
filters. This reduced the unit's control effectiveness and the air flow found ways to bypass the plugged
filters causing the emissions. Mr.Kelly emailed photos of the stack operating after the filter change and
no visible emissions can be seen in the pictures. Mr.Kelly also stated that he had spoken with all the
maintenance personnel and reminded them of the proper procedures for cleaning and rinsing the filters.
He also told all personnel entering control device parameters in the log to make sure the parameters they
were recording in the log is within the log column's proper range and to advise the maintenance
supervisor if they are not. He also told them to note any trends towards the range limits and to advise the
maintenance supervisor of such.
V. PERMITTED EMISSION SOURCES:
mpg$ a'
dsCb rd'"i-� ul
Source �j, ) 'Deserts ,st ) � on�:lire.
oiler 0 erat!�lu&Q:`
Main-031 Natural gas/No.2 fuel oil-fired boiler
(NSPS) (44.398 mmBtu/hr maximum heat input) N/A N/A
O eratin an NG, 0% VE
Textile O erat6 mcludin .
Textile tenter frame(1,500 lbs of cloth per hour
maximum capacity)consisting of the following:
Tenter 1 a)pad-applied finishing station,and CD-2 Condenser/Mist
b)therminol(hot oil)heated oven. Eliminator
Operating and running style 115431 fabric and
appeared to show—5%opacity
Textile tenter frame(2,000 lbs of cloth per hour
maximum capacity)consisting of the following:
a)pad-applied finishing station,and Condenser/Mist
Tenter 2 b)natural gas-fired four zone heated oven CD-2 Eliminator
(7.2 million Btu per hour maximum heat input)
Operating and running style H3604 fabric and
appeared to show--5%opacirl,
Textile tenter frame(2,000 lbs of cloth per hour
maximum capacity)consisting of the following:
Tenter 3 a)pad-applied finishing station, and CD-1 Condenser/Mist
b)therminol(hot oil)heated oven Eliminator
Operating and running.style 1929 GBYfabric and
appeared to.show 30-35%o achy
Textile tenter frame(2,100 lbs of cloth per hour
maximum capacity)consisting of the following:
Tenter 4 a)pad-applied finishing station,and CD-1 Condenser/Mist
b)natural gas-fired six zone heated oven Eliminator
(6 million Btu per hour maximum heat input)
Not Operating

INSIGNIFICANT ACTIVITIES:
our�e r5txetnpttoiiRegu( ion T rp lt?Ie V
a
,�.
I-ES1 1
Surface Finishing Operation 2Q .0102(c)(2)(E)(i) Yes Yes
Not Observer!
I-Main-058
Natural gas-fired therminol heater
(15 mmBtu/hr maximum heat input) 2Q .0102(c)(2)(13)(ii) Yes Yes
(NSPS Subpart Dc)
Operating on NG
0% VE
I-01
Natural gas/No.2 fuel oil-fired therminol heater 2 0102 c 2 B i II Yes Yes
(9.06 mmBtu/hr maximum heat input) Q ' O( )( )()( )
Not operating
1-03
Natural gas/No.2 fuel oil-fired boiler
(22.65 marBm/hr maximum heat input) 2Q .0102 (c)(2)(B)(i)(fI) Yes Yes
Operating on NG at low fire status
0% VE
VI. APPLICABLE AIR QUALITY REGULATIONS:
1. 15A NCAC 2D .0202—PERMIT RENEWAL AND EMISSION INVENTORY REQIItEMENT
—The Permittee shall submit an application for permit renewal, including an emission inventory for
CY 2020,no later than 90-days prior to permit expiration.
APPEARED IN COMPLLANCE: The facility's current permit was renewed on time. The facility's
permit expires on 30 April2022, and the renewal application and El are due to be submitted no later
than 31 January 2022 for calendar year 2020.
2. 15A NCAC 2D .0503—PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS—Particulate emissions from the facility's boiler(ID No. Main-031) shall not
exceed 0.39 Ib/mmBtu.
APPEARED IN COMPLIANCE: The facility is permitted to combust both natural gas and No. 2
Fuel oil in Main-031, but combusts mainly natural gas. AP-42 emission factors for particulates from
combustion of natural gas and No. 2 fuel oil are 0.0007 lb/mmBtu, and 0.02 lb/mmBtu respectively.
3. 15A NCAC 2D .0515—PARTICULATES FROM MISC.INDUSTRIAL PROCESSES—PM
emissions shall not exceed emission rates as calculated by the following:
E=4.10 * (P)06' for P<=30 tons/hr,or
E= 55 * (P)0 '-40 for P>30 tons/hr
APPEARED INCOMPLIANCE. 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

4. 15A NCAC 2D .0516—SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES—
S02 emissions from the facility's combustion sources shall not exceed 2.3 lb/mmBtu.
APPEARED IN COMPLL4NCE: The facility combusts primarily natural gas, but may combust No.
2 fuel oil if necessary. The facility only accepts ultra-low su fNr diesel(ULSD), as verified by fuel
certifications. AP-42 S02 emission factors for natural gas and ULSD are 0.00061b/mmBtu, and
0.002 Zb/mmBtu respectively.
5. 15A NCAC 2D .0521 —CONTROL OF VISIBLE EMISSIONS—Visible emissions from each
emission source manufactured after 1 July 1971, shall not exceed 20%opacity when averaged over a
six-minute period.
APPEARED IN VIOLATION.• Based on the history of this facility we made it a paint to drive
around the facility before entering the facility to note any VE emissions present. We noted visible
emissions from Condenser/Mist Eliminator CD-1. We entered the facility and proceeded to the roof
to conduct a proper Method 9 observation. We were able to record a 24 minute Method 9
observation before rain forced us off the roof. The Method 9 observation resulted in 3 six-minute
averages above the facility's 20%opacity limit(30.0016, 30.6%and 31.095). We also noted
approximately 5%opacity from the stack for CD-2.
6. 15A NCAC 2D .0524—NEW SOURCE PERFORMANCE STANDARDS(Subpart Dc)—The
facility's boiler(Main-031)is subject. Fuel sulfur content<0.5 wt.% and monthly records of fuel
usage. VE<—20% opacity. Initial start-up testing, and periodic testing for visible emissions when
switching from natural gas to fuel oil. Semiannual reporting.
APPEARED IN COMPLL4NCE: The facility maintains the required fuel records, which show no
_/ael oil combustion in the last 12 months, and fisel certifications show that the facility only combusts
ULSD. Mr. Kelly stated that they planned to perform a tune-up in late May 2019 on both natural gas
and No. 2 fuel oil. I reminded Mr. Kelly that his Method 9 reading exemption determined during his
last Method 9 testing had expired on 3 June 2018 and that they would need to have Method 9 reader
conduct a VE observation during the tune-up when firing No. 2 f gel oil. Mr. Kelly stated that he
understood this requirement.
7. 15A NCAC 2D .0535—NOTIFICATION REQUIREMENT—Notify DAQ in the event of excess
emissions lasting longer than 4 hours.
APPEARED IN COMPLL4NCE. Mr. Kelly stated that the facility has had no exceedances,
breakdowns, or abnormal conditions requiring notification before our inspection.
8. 15A NCAC 2D .0540—PARTICULATES FROM FUGITIVE DUST EMISSION SOURCES—
Fugitive dust emissions shall not cause/contribute to substantive complaints or excessive VE across
property boundaries.
APPEARED IN COMPLL4NCE: No fugitive dust concerns were noted during the inspection.All
roads are paved, and there have not been any complaints received by DAQ. Mr. Kelly stated that
there had been no dust complaints in the past year.

9. 15A NCAC 2D .0611—CONDENSER/MIST ELIMINATOR REQUIREMENTS—Annual
internal and structural integrity inspections of CD-1 and CD-2. Change pre-filter weekly. Monitor
pressure drop daily and implement wash procedures when mist eliminator AP reaches 7.5-8.0"H2O,
or when water coil AP reaches 3.0"H2O. Weigh oil and particulate collected in the mist eliminator
weekly.
APPEARED IN VIOLATION: The facility monitors pressure drop across the mist eliminators
during each shift, and records the values in a logbook. All values in the log book were below the
level which would require a wash procedure except for the last 2 days before our inspection on 7 and
8 April 2019 for mist eliminator CD-1. For those 2 days the facility recorded 7 separate readings of
10 inches of H2O without any comments as to these readings being out of range. Also, the facility did
not implement wash procedures when mist eliminator CD-1's AP reached 7.5-8.0 inches of H2O as
required by their permit. We observed mist eliminator CD-01 (controlling ES-03 and ES-04[when
operatingi) at a AP of 10 inches of H2O during our inspection with opacity of 30 to 35%. We
observed a mist eliminator CD-02 (controlling ES-01 and ES-02) at a AP of 2.33"of H2O. Mr. Kelly
also stated that he had observed what appeared to be high opacity on 27 March 2019 but had not had
time to investigate.
The mist eliminators are also inspected semiannually with the most recent internal inspections
occurring on 5 January 2019 for CD-1 and 17 February 2019 for CD-2. The facility performs weekly
maintenance on both mist eliminators. The last weekly inspection on CD-01 was on 29 March 2019
and the last weekly inspection on CD-02 was on 31 March 2019. However, the weekly inspection on
29 March 2019 failed to detect the hardened filter issue discovered after our inspection in CD-01 (see
inspection summary).
10. 15A NCAC 2D .0958—WORK PRACTICES FOR SOURCES OF VOCs—Permittee shall adhere
to work practices as delineated in the permit.
APPEARED IN COMPLIANCE. During this inspection, lids were on tight and all cleaning rags
were properly stored. This stipulation will be removed from the permit at next permit opening since it
applies only in non-attainment areas and Anson County is in attainment.
11. 15A NCAC 2D .1806—CONTROL AND PROHIBITION OF ODOROUS EMISSIONS—
Permittee shall not cause or contribute to objectionable odors beyond the property boundary.
APPEARED IN COMPLL4NCE: No objectionable odors were noted as I approached the facility,
nor were there any noticeable odors while inside. Mr. Kelly stated that there had been no odor
complaints in the past year.
12. 15A NCAC 2Q.0102—FEDERAL AND STATE RULES APPLICABLE TO EXEMPTED
SOURCES—Insignificant boiler, I-Main-058, is subject to the requirements of NSPS Subpart Dc.
APPEARED IN COMPLIANCE: I discussed the fact that boiler (ID No. I-Main-058) is subject to
NSPS Subpart Dc with Mr. Kelly. The boiler is only capable of firing natural gas, and the facility
keeps appropriate records.

13. 15A NCAC 2Q .0315—SYNTHETIC MINOR FACILITIES—Operate within the following limits
to maintain S02 emissions less than 100 tons annually: 1)Amount of No. 2 fuel oil combusted
<2,800,000 gallons per consecutive 12-month period; 2) sulfur content of No.2 fuel less than 0.5%.
Annual reporting.
APPEARED IN COMPLIANCE: Records indicate the facility combusted no No. 2 fuel oil since
their last inspection. Fuel usage is tracked by taking monthly measurements of the fuel storage tank
levels. Fuel certifications were available, and show that the facility only receives ULSD. The annual
report was received on time on 2 January 2019, and indicated compliance.
14. 15A NCAC 2Q .0317—AVOIDANCE CONDITION FOR GACT 6J—The Permittee shall only
fire liquid fuels in Main-031 for periodic testing and during curtailments, gas interruptions, or start-
ups.
APPEARED IN COMPLIANCE: The facility normally fires boiler (ID No.Main-03) with natural
gas. Mr. Kelly explained that facility natural gas supply had not been curtailed since their last
inspection.
15. 15A NCAC 2Q .0711—EMISSION RATES REQUIRING A PERMIT—Emissions of toxic air
pollutants shall not exceed the following allowable emission rates: 0.96 Ib/hr for acetic acid,and 0.04
lb/hr for formaldehyde.
APPEARED IN COMPLLANCE: The permit review indicates compliance when the facility is
operated as permitted. There do not appear to be any changes in equipment, operations, or in
formulations of materials used.
VH. NON-COMPLIANCE HISTORY SINCE 2010:
04/28/2017 CAI issued expressing concern with VE from mist eliminators
05/16/2016 NOD issued for failure to perform M9 when burning No. 2 fuel oil, per NSPS Dc
requirements.
06/02/2015 CAI issued requesting records which were unavailable during the 05/26/2015 inspection.
VIH. RISK MANAGEMENT (112r): This facility does not store any 112(r) subject materials above threshold
limits. Therefore, it is not required to maintain a written Risk Management Plan(RMP).
IX. CONCLUSION AND RECOMMENDATIONS:
Hornwood,Inc. appeared to be operating IN VIOLATION with their air permit at the time of this
inspection as noted in sections VL5 and VI.9 above. I recommend the issuance of an NOV letter for
violations of 15A NCAC 2D .0521 "Control of Visible Emissions" and 15A NCAC 2D .0611
"Condenser/Mist Eliminator Requirements."
PINK SHEET ADDITIONS:
• None

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