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HomeMy WebLinkAboutAQ_F_0400009_20170808_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Homwood Inc NC Facility ID 0400009 Partial Inspection Report County/FIPS:Anson/007 Date: 08/22/2017 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 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 Home Dale Kelly NSPS: Subpart Dc Environmental Manager Owner Plant Engineer (704)848-4121 (704)848-4121 (704)848-4121 Compliance Data Comments: Inspection Date 08/08/2017 Inspector's Name Jeffrey D. Cole Inspector's Signature: c �C Operating Status Operating Compliance Code Compliance-inspection Action Code PCE Date of Signature: �/a //7 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 *Hi est HAP 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. i 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: MWE 2016 € 8,119,816 2015 7,908,000 2014 7,937,000 2013 10,312,041 IV. INSPECTION SUMMARY: Note: This is only a partial inspection to look at VE from the sources. On 8 August 2017,I Jeffrey Cole,FRO DAQ, conducted a compliance inspection of Hornwood,Inc. in Lilesville,Anson County. This partial inspection was in response to a drive by observation done by Joshua Harris,FRO DAQ. On 29 June 2017,Joshua Harris had observed—37%opacity for the Condenser/Mist Eliminator(ID No. CD-1)and 10-20%from Condenser/Mist Eliminator(ID No. CD-2). I explained to the FRO Compliance Coordinator that the company had informed me that they planned to conduct an internal inspection of CD-I, followed by replacement of all 16 filter housings,during the week of 2 through 8 July 2017. It was decided to wait for a time after that early July I&M effort to inspect the emissions from the facility. The facility was operating at the time of the inspection. Upon approaching the facility, I tried to observe the exhaust form the 2 mist eliminators that were both operating. It is hard to see the stack emissions from the front(east side)of the facility as the stacks are below the roof line at the back(west side)of the facility. There was an overcast and dark sky this day and a valid Method 9 observation was not possible. Observing the front of the facility I saw what appeared to be heated exhaust but 0%opacity from either stack. I went behind the facility and tried to view the stacks from a better angle. From this observation position,I could also see no visible emissions. I then met with Mr. Dale Kelly,Plant Manager to continue conducting my partial inspection. I asked Mr. Kelly what equipment was operating at approximately 9:00 AM that morning when I made my observations. He had a technician examine the data logs and the types of materials are listed in the emission source table. Mr.Kelly explained the inspections and maintenance that had been done on both mist eliminators after my 13 April 2017 compliance inspection. For the Condenser/Mist Eliminator(ID No. CD-1),he stated that the company had had the upper and lower sections of and the chevron separator cleaned on 21 May 2017. Mr.Kelly also described in detail what the 2 through 8 July 2017 I&M effort. He stated that the company replaced all 16 FME filter housings that week. During this replacement,the contractor noted a 1"gap around the diameter of 2 of 16 filters of the circular filters that would have decreased Condenser/Mist Eliminator performance. The unit is designed to capture the oil that is applied to the yarn before the fabric is made. This system was checked and appeared to be operating properly. During the same I&M effort,the contractor added additional spray heads to the existing spray ring for additional cooling. We exited the facility and observed the temperatures and differential pressures of the Condenser/Mist Eliminator(ID No. CD-1) which are listed in the table below. Before this I&M effort the Condenser/Mist Eliminator had a minimum exit temperature of—140°F and now is—100°F. While outside the facility I observed the temperatures and differential pressures of the Condenser/Mist Eliminator(ID No. CD-1)which are listed in the table below. FME Inlet Temperature(°F) ( 195 FME Outlet Temperature(°F) 100 Pre-Filter Differential Pressure(Inches of H2O) 0.8 Overall i.e.,Post-Filter Differential Pressure Inches of HzO 3.2 For the Condenser/Mist Eliminator(ID No. CD-2),he described the I&M work done on the unit after my inspection on 13 April 2017 that noted>20% opacity from CD-2. On 7 May 2017, an internal inspection had shown that one(1)of the sixteen(16)filters had collapsed. The company's contractor cleaned the upper and lower sections of unit and replaced all 16 FME filter housings. On 21 May 2017,they opened the unit to clean the upper and lower sections of unit and the chevron separator,but found an issue. The unit is designed to capture the oil that is applied to the yarn before the fabric is made. The system of waste oil collection at the bottom of the Condenser/Mist Eliminator was filled with heavy oil sludge and the oil drains were mostly clogged. Instead of just scraping out the sludge as in previous annual internal inspections the company decided to have the oil sump and drains steam cleaned. Finally,on 17 June 2017,the company added additional cooling coils and spray heads(for the first time in this unit)for additional cooling. Mr.Kelly also noted that before this I&M effort the Condenser/Mist Eliminator had a minimum exit temperature of—140°F and now is also—100°F. While outside the facility I observed the temperatures and differential pressures of the Condenser/Mist Eliminator(ID No. CD-2)which are listed in the table below. FME Inlet Temperature(°F) 190 FME Outlet Temperature(°F) 110 Pre-Filter Differential Pressure(Inches of HzO) 0.5 Overall(i.e.,Post-Filter Differential Pressure(Inches of H2O) 7.5 While outside the facility Mr.Kelly showed me the waste oil storage tank for the system mentioned above was very nearly full. He stated that since the thorough cleaning of the system in CD-2 and the addition of additional cooling,that the waste oil collection system that had previously collected an estimated 55 gallons of oil per year is now capturing an estimated 1,800 gallons per year. He also stated that the oil is lighter(i.e.,less viscus)and flows better than the oil that was previously collected. We then reentered the facility and we proceeded to Mr.Kelly's office where I asked to see some random pages of their I&M records on CD-2,one page recording parameters before the added cooling and one page recording parameters after the added cooling. Before the added cooling(between 5 through 9 January 2017)the record shows a minimum outlet temperature of 115 °F and a maximum inlet temperature of 142°F(average temperature 129°F). After the added cooling(between 29 through 31 July 2017)the record shows a minimum outlet temperature of 50°F and a maximum inlet temperature of 110°F (average temperature 96 °F). This lower exit temperature aides in the condensation and allow for greater particulate removal to occur. Now that the two condenser/mist eliminators appear to be operating as permitted,I asked Mr.Kelly which parametric data he should monitor to maintain the device's optimum performance. He stated that differential pressure(either a drop or an increase across the device)would be a good sign of plugging or breakthrough of the mesh filters. He also stated that outlet temperature would show if the cooling of the gas was being accomplished. Finally, another good parametric for determining CD-2's performance would be if the amount of waste oil being captured starts dropping which would indicate that the capture system and drains are likely clogged and would be need to be cleaned. He stated that he was adding a semiannual check of the waste oil capture system and drains and an annual steam cleaning of the same. He also stated that he would add a visual check of all filters during each semi-annual inspection to check for filter breakthrough. V. PERMITTED EMISSION SOURCES: }y .oi5!#14Rf n;l fElb -v�;:a i 11.Y.®..® i i. ._...... a ....._._ .......:�_.;w SlI3:.�—:m.a: .� s' .. ...._.- MR, ..._.I � � � ...:.s._ _........ Main-031 Natural gas/No.2 fuel oil-fired boiler (NSPS) (44.398 mmBtu/hr maximum heat input) N/A N/A Not Observed .m.ter:. _ WiI! .-�vF 1..: Textile tenter frame(1,5001bs 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 H53431,black fabric and appeared to show 0%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 1107-1 grey fabric and appeared to show 0%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 3 b)therminol(hot oil)heated oven CD-1 Eliminator Operating and running style 2188L,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: a)pad-applied finishing station,and Condenser/Mist Tenter 4 b)natural gas-fired six zone heated oven CD-1 Eliminator (6 million Btu per hour maximum heat input) Not Operating INSIGNIFICANT ACTIVITIES: ) e I-ES11 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) 2Q.0102(c)(2)(B)(ii) Yes Yes (NSPS Subpart De) Not Observed I-01 Natural gas/No.2 fuel oil-fired therminol heater (9.06 mmBtu/hr maximum heat input) 2Q.0102(c)(2)(B)(i)(II) Yes Yes Not Observed I-03 Natural gas/No.2 fuel oil-fired boiler (22.65 mmBm/hr maximum heat input) 2Q.0102(c)(2)(B)(i)(II) Yes Yes Not Observed VI. APPLICABLE AIR QUALITY REGULATIONS: 1. 15A NCAC 2D.0521—CONTROL OF VISIBLE EMISSIONS—VE<20%opacity. APPEARED INCOMPLMNCE. Both mist eliminator's stacks appear to have emissions that were 0%. opacity. While there was an overcast and dark sky this day and a valid Method 9 observation was not possible, I could not observe any emissions from the stacks from any of the different viewing positions I chose. 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 De 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 COMPLL4NCE with their air permit at the time of this inspection. Recommend sending a letter requesting the company document in detail their scheduled I&M efforts reflecting the added checks and inspections they noted in this inspection. PINK SHEET ADDITIONS:None Jdc