AQ_F_0400009_20190426_CMPL_NOV

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Governor
MICHAEL S.REGAN
Secretary
MICHAEL A.ABRACZINSKAS NORTH CAROLINA
Duecmr
Environmental Quality
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26 April 2019
CERTIFIED MAIL
RETURN RECIEPT REQUESTED
Mr. Charles Horne, Owner
Hornwood Inc.
766 Hailey's Ferry Road
Lilesville,NC 28091 9759
Subject: Notice of Violation
15A NCAC 2Q .0521 "Control of Visible Emissions"
15A NCAC 2Q .0611 "Condenser/Mist Eliminator Requirements"
Hornwood Inc Air Permit 04888R14
Lilesville;NC, Anson County, Facility ID No. 06/04-00009
Fee Category: Synthetic Minor
Dear Mr. Horne:
On 9 April 2019, Jeffrey Cole and Evangelyn Lowery-Jacobs of the Fayetteville Regional
Office Division of Air Quality (FRO DAQ) conducted an air quality compliance inspection at the
Hornwood Inc facility in Lilesville, Anson County. During the inspection, Mr. Cole and Ms.
Lowery-Jacobs noted the following violations of your current air quality permit:
1. 15A NCAC 2D .0521 Control of Visible Emissions
Your current permit contains the Specific Condition and Limitation A.6, 15A NCAC 02D
.0521 —Control of Visible Emissions, which requires that "visible emissions from the
emission sources, manufactured after July 1, 1971, shall not be more than 20 percent opacity
when averaged over a six-minute period, except that six-minute periods averaging not more
than 87 percent opacity may occur not more than once in any hour nor more than four times
in any 24-hour period. " Mr. Cole and Ms. Lowery-Jacobs noted excessive particulate
emissions coming from Condenser/Mist Eliminator (ES ID No. CD-1). They conducted a
24-minute, Method 9 Visible Emissions Evaluation on the emission release point for Tenter
No. 3, resulting in a calculated average opacity for the four 6-minute periods of 30.0%,
30.6%, 31.0% and 31.0%.
Failure to limit visible emissions to no more than 20% opacity is a violation of 15A
NCAC 02D .0521.
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North Carolina Department of Environmental Quality I Division of Air Quality y
Fayetteville Regional Office 1 225 Green Street,Suite 714 1 Fayetteville,North Carolina 28301-5094 f[
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II. 15A NCAC 2D .0611, Condenser/Mist Eliminator Requirements
Your current permit contains the Specific Condition and Limitation A.10, 15A NCAC 02D
.0611 — Condenser/Mist Eliminator Requirements, which requires that the Permittee shall
implement the wash procedure when the pressure drop across the Fiberglass Mist Eliminator
(FME) increases to 7.5 to 8.0 inches of water. " Mr. Cole and Ms. Lowery-Jacobs noted that
the Condenser/Mist Eliminator (ES ID No. CD-1) maintenance log documented 7 separate
instance (on 7 and 8 April 2019) where the pressure drop across CD-l's Fiberglass Mist
Eliminator (FME) was recorded as 10 inches of water. The records did not note that any
corrective actions were taken by the facility personnel, including implementing wash
procedures to clean the filters inside CD-1. Mr. Kelly of your staff confirmed that the filters
inside CD-1 were not cleaned during these dates.
Failure to implement the wash procedure when the pressure drop exceeded 7.5 inches
of water is a violation of 15A NCAC 02D .0611.
As stated in the "subject" above, this letter represents a Notice of Violation for the above-
cited violations. These violations and any future violation of an air quality regulation are subject
to the assessment of civil penalties per North Carolina General Statute 143-215.114A. In
addition, each day of continuing violation after written notification from the Division of Air
Quality shall be considered a separate offense.
Please submit a written response, due no later than 10 May 2019, documenting the
reasons you violated the above-cited permit requirements, the steps your facility has taken or
plans to take to ensure future compliance with these requirements, and the date by which you
anticipate achieving compliance.
We appreciate your immediate attention to this environmental concern. If you have any
questions about these violations, please contact Jeffrey Cole, Environmental Engineer, or me, at
[phone].
Sincerely,
Heather S. Carter
Regional Supervisor
NCDEQ, Division of Air Quality
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Enclosures:
cc: FRO Files
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North Carolina Department of Environmental Quality I Division of Air Quality
Fayetteville Regional Office 1 225 Green Street Suite 7141 Fayetteville,North Carolina 28301
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