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HomeMy WebLinkAboutAQ_F_0400009_20180425_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Hornwood Inc NC Facility ID 0400009 Inspection Report County/FIPS:Anson/007 Date: 05/11/2018 Facility Data Permit Data Hornwood 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 Classification 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 Horne Dale Kelly NSPS: Subpart Dc Environmental Manager Owner Plant Engineer (704)848-4121 (704)848-4121 (704)848-4121 Compliance Data Comments: Inspection Date 04/25/2018 Inspector's Name Jeffrey D. Cole Inspector's Signature: Operating Status Operating Compliance Code Compliance-inspection Action Code FCE Date of Signature: ` //��/ On-Site Inspection Result Compliance Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 * 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 HAP Emitted in ounds 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. II. SAFETY: Standard FRO safety gear. Inspectors should be wary of hot surfaces. III. FACILITY DESCRIPTION: Hornwood,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 or jet 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 fiberglass cylinders that are each surrounded by a wire 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: Now PR I ,. odul 7,636,000..._ � �. 2017 . 2016 � 8,119,816 2015 7,908,000 2014 7,937,000 2013 10,312,041 IV. INSPECTION SUMMARY: On 25 April 2018,I Jeffrey Cole,FRO DAQ, conducted a compliance inspection of Hornwood,Inc. in Lilesville,Anson County. The facility was operating at the time of the inspection. I met with Dale Kelly, Plant Manager, and first verified the FacFinder data. Mr. Burr stated that no changes to the FacFinder were necessary. Mr.Kelly was able to produce the facility's latest air quality permit. Mr.Kelly was also 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 2017. 1 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 its natural gas supply curtailed for part of 3 January 2018, from 4 through 6 January 2018 and for part of 16 and 17 January 2018. The facility combusted a total of 16,850 gallons of No. 2 fuel oil during the curtailment period in January 2018. Also,during that time period,the company contracted for a Method 9 reader to conduct a VE observation as required but could not coordinate a boiler tuning contractor in that brief time period. The M9 observer noted(on 3 January 2018)that the facility's sources emitted at 0 to 5%opacity. Based on this result,the facility would not have to have another M9 observation(while oil is being combusted) until after 3 June 2018. We then proceeded on inspecting the facility. I noted the large amount of inventory stacked on shelves inside the facility and Mr.Kelly noted that the company had increased production due to a doubling of their contract with Nike. He stated that they are looking into starting up Tenter 4 which has not been needed for production in quite a few years. He also stated that they were exploring switching from a hot oil heating system on Tenter 1 to a natural gas-fired heating system similar to Tenter 2. I observed the Condenser/Mist Eliminator(ID No. CD-1)OP of 3.5"of H2O. I observed the Condenser/Mist Eliminator(ID No.CD-2)AP of 1.8"of H2O. Mr. Kelly stated that they try to keep the CD-2 OP at under 2.0"of H2O. We then proceeded outside the facility to observe the Condenser/Mist Eliminators(ID No.CD-1 and CD-02). While outside the facility I observed the temperatures and differential pressures of CD-1 which are listed in the table below. FME Inlet Temperature(°F) 154 FME Outlet Temperature(°F) 94 Pre-Filter Differential Pressure(Inches of H20) 0.01 _..._.._....._..._.._........................._....._..........................f.._......... .............: Overall(i.e.,Post-Filter Differential Pressure(Inches of H2O) 4.3 While outside the facility I observed the temperatures and differential pressures of CD-2 which are listed in the table below. FME Inlet Temperature(°F) 242 FME Outlet Temperature(°F) 98 Fire-Filter Differential Pressure(Inches of H2O) 1.7 Overall(i.e.,Post-Filter Differential Pressure(Inches of H2O) 2.4 We 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. 1-03)all operating on NG at 0%opacity. We then proceeded to the roof to observe the emissions from CD-2. I noted what appeared to be VE at—5%opacity from the stack for CD-2 and 0%opacity from the stack for CD-1. This is within permitted limits and a great improvement over recent inspections. Mr.Kelly stated that they had been keeping up their inspection&maintenance(I&M)plans for their Condenser/Mist Eliminator and have noted none of the issues(e.g., collapsed filters and gaps around filters that were in place)found during their internal inspections last year. V. PERMITTED EMISSION SOURCES: Source ID' .�- ' Des�cri ouicc Emission �. tion y Boiler Operations,including: Main-031 Natural gas/No.2 fuel oil-fired boiler (NSPS) (44.398 mmBtu/hr maximum heat input) N/A N/A Operating on NG, 0% VE Textile Operations,including: Textile tenter frame(1,500 lbs of cloth per hour maximum capacity)consisting of the following: a)pad-applied finishing station,and Condenser/Mist Tenter 1 b)therminol(hot oil)heated oven. CD-2 Eliminator Operating and running style H5931,Navy Blue 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 2744 PFP White fabric and appeared to show 5%opacity Textile tenter frame(2,000 lbs of cloth per hour Condenser/Mist Tenter 3 maximum capacity)consisting of the following: CD-1 Eliminator 0 pad-applied finishing station,and b)therminol(hot oil)heated oven Operating and running style 3360,Nat Epoxy fabric and appeared to show 0%opacity 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: Source Santee Exeptipn Riegulatibn Y Title f Source,of , TA1's? Pollutants? I-ES 11 Surface Finishing Operation 2Q .0102(c)(2)(E)(i) Yes Yes Not Observed I-Main-058 Natural gas-fired therminol heater (15 mmBtu/hr maximum heat input) 2 .0102 c 2 B ii Yes Yes (NSPS Subpart Dc) Q ( )( )( )( ) Operating at 10%capacity(Standby) on NG 0% VE I-01 Natural gas/No.2 fuel oil-fired therminol heater 2Q .0102(c)(2)(B)(i)(II) Yes Yes (9.06 mmBtu/hr maximum heat input) Not operating I-03 Natural gas/No.2 fuel oil-fired boiler (22.65 mmBtu/hr maximum heat input) 2Q .0102(c)(2)(B)(i)(II) 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 REQIREMENT —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 COMPLL4NCE: The facility's current permit was renewed on time. The facility's permit expires on 30 April 2022, and the renewal application and EI 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 0.391b/mmBtu. APPEARED IN COMPLL4NCE. 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.INDUSTIRAL PROCESSES—PM emissions shall not exceed emission rates as calculated by the following: E=4.10 * (P)067 for P<=30 tons/hr, or E= 55 * (P)°"-40 for P>30 tons/hr APPEARED IN COMPLL4NCE: The permit review indicates compliance. Control devices are operated and maintained as required, and the facility's emission sources appear to be operated as permitted. 4. 15A NCAC 2D .0516—SULFUR DIOXIDE EMISSIONS FROM COMBUSTION SOURCES— SO2 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 sulfur diesel(ULSD), as verified by fuel certifications. AP-42 SO2 emission factors for natural gas and ULSD are 0.0006 lb/mmBtu, and 0.002 lb/mmBtu respectively. 5. 15A NCAC 2D .0521 —CONTROL OF VISIBLE EMISSIONS—VE<20%opacity. APPEARED IN COMPLL4NCE: Based on the history of this facility I made it a point to drive around the facility before entering the facility to note any VE emissions present. I could not see any in my drive around. During my internal facility inspection, I made it a point to access the facility's roof to observe the facility's Condenser/Mist Eliminator stacks. I noted approximately 5%opacity from the stack for CD-2 and 0%opacity from the stack for CD-1. 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 fuel oil combustion in the last 12 months, and fuel certifications show that the facility only combusts ULSD. Mr. Kelly explained that facility had its natural gas supply curtailed for part of 3 January 2018,from 4 through 6 January 2018 and for part of 16 and 17 January 2018. The facility combusted a total of 16,850 gallons of No. 2 fuel oil during the curtailment period in January 2018. Also, during that time period, the company contracted for a Method 9 reader to conduct a VE observation as required but could not coordinate a boiler tuning contractor in that brief time period. The M9 observer noted(on 3 January 2018) that the facility's sources emitted at 0 to 5%opacity. Based on this result, the facility would not have to have another M9 observation (while oil is being combusted) until after 3 June 2018. Note that the facility purchased 7,619 gallons of No. 2 fuel oil on 15 January 2018 to refill their oil storage tank during the early January curtailment. 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. 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 COMPLIANCE: No fugitive dust concerns were noted during the inspection. All roads are paved, and there have not been any complaints received by the facility or 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"H20, or when water coil AP reaches 3.0"H2O. Weigh oil and particulate collected in the mist eliminator weekly. APPEARED IN COMPLIANCE: 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 awash procedure. I observed a mist eliminator CD-02 (controlling ES-01 and ES-02)AP of 1.82"of H2O. The previous recorded AP reading for CD-2 were 1.82"of H2O recorded at 08:30 AM, on 25 April 2018. I observed a mist eliminator CD-01 (controlling ES-03)AP of 3.5" of H2O. The previous recorded AP reading for CD-2 were 3.4"of H2O recorded at 08:30 AM, on 25 April 2018. Weekly maintenance is performed as required. The last weekly inspection on CD- 01 was on 24 April 2018 and the last weekly inspection on CD-02 was on 29 April 2018. The mist eliminators are inspected semiannually with the most recent internal inspections occurring on 31 March 2018 for CD-1 and for CD-2. 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 none-attainment area 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 COMPLLANCE: No offensive 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 ofNSPS 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. Mr. Kelly showed me the NG usage records that their permit required them to record. In CY 2017, the facility combusted 74,774 Therms (THMs) or 7.48 million cubic feet (MCF) of process natural gas. 13. 15A NCAC 2Q.0315—SYNTHETIC MINOR FACILITIES—Operate within the following limits to maintain SOz 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 COMPLLANCE: Records indicate the facility combusted a total of 16,850 gallons of No. 2 fuel oil during the curtailment period in January 2018. 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 11 January 2018, and indicated compliance. 14. 15A NCAC 2Q .0317—AVOIDANCE CONDITION FOR GACT W—The Permittee shall only fire liquid fuels in Main-031 for periodic testing and during curtailments,gas interruptions, or start- ups. APPEARED IN COMPLLANCE. The facility normally fires boiler(ID No.Main-03) with natural gas. Mr. Kelly explained that facility had its natural gas supply curtailed for part of 3 January 2018, from 4 through 6 January 2018 and for part of 16 and 17 January 2018. The facility combusted a total of 16,850 gallons of No. 2 fuel oil during the curtailment period in January 2018. 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 lb/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. VII. 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. VIII. 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 COMPLLANCE with their air permit at the time of this inspection. PINK SHEET ADDITIONS: • Remove 2D .0958 during permit renewal since it applies only in none-attainment area and Bladen County is in attainment. J do