AQ_F_0400009_20170413_CMPL_InspRpt

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NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Hornwood Inc
NC Facility ID 0400009
Inspection Report County/FIPS:Anson/007
Date: 04/25/2017
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 Horne Dale Kelly NSPS: Subpart Dc
Environmental Manager Owner Plant Engineer
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 04/13/2017
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 TONSIYEAR:
TSP S02 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 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. DH2ECTIONS 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: Hornwood,Inc. is a textile company that warps,weaves, dyes yam,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: Yam is spun onto a single spool for processing in the knitting room. Yam may also be draw
warped which draws the diameter of the yam 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 dye water and is
constantly in motion through a 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. The air then
passes over six cold water coils that helps condense the vapor and send it through the mist eliminator.
The mist eliminator houses 18 two-inch fiberglass cylinders that are surrounded by a wire mesh. The
condensed vapor passes through the center of the filter then proceeds out the stack. Jet nozzles are
located at the bottom center of each filter tube and spray wash water into each. The rinse water is
collected at the bottom of the collector unit and sent through a trap to a holding tank for collection and
disposal.
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The facility employs about 360 people and operates 24 hours per day, 6 days per week, 52 weeks per
= year.
i Throughputs:
a I 2 116 8,119,816
2015 � 7 908,000 �i
2014 7,937 000
2013 10,312,041
IV. INSPECTION SUMMARY: On 13 April 2017,I Jeffrey Cole,FRO DAQ,conducted a compliance
inspection of Homwood,Inc. in Lilesville,Anson County. The facility was operating at the time of the
inspection. I met with Benny Burr,Environmental Manager, and Dale Kelly,Plant Manager, and first
verified the FacFinder data. Mr.Burr stated that no changes to the FacFinder were necessary. Mr. Dale
was able to produce all maintenance and inspection records I requested while Mr.Burr was able to
produce the production records for 2016 and the natural gas usage records both monthly and annually for
2016.
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. The facility was issued an NOD after the 5/12/16 inspection for not
conducting Method 9 observations when it performed boiler tuning while combusting fuel oil. Mr.Kelly
informed me that no fuel oil was combusted since the last inspection. Mr.Kelly explained that the
company chose to tune the boiler(on 2/6/17)using natural gas as they had problems scheduling a Method
9 observer(required if combusting fuel oil)during the short tuning time window. Mr. Kelly asked if it
were possible to run the boiler on Fuel oil and perform the M9 observation at a time separate from boiler
tuning. I noted to Mr.Kelly that since this Method 9 observation requirement is listed in their permit .
under the NSPS Subpart Dc stipulation and that the M9 observation can be conducted just before or
during their tune-up after they have switched the boiler over to firing fuel oil.
We then proceeded on inspecting the facility. 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
proceeded to the boiler room where I observed both the Natural gas/No. 2 fuel oil-fired boiler(ID No.
Main-031) and the Natural gas-fired therminol heater(ID No. I-Main-058)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>20%opacity from the stack for CD-2. I did not perform a formal Method 9 observation at the
time of the inspection. I expressed my concern to Mr.Burr and Mr. Kelly and requested that they have a
technician check the CD-2's operating parameters. Mr. Kelly informed me that the temperature of the
emissions entering the unit was—210 IF and the temperature of the emissions exiting the stack the unit
was—100 IF. I told Mr.Kelly that the company needs to have their control device consultant evaluate
CD-2 an conclude if the unit was operating correctly(i.e., as designed)and to contact FRO with the
findings of that inspection.

V. PERMITTED ENIISSION SOURCES:
Ma n-031 Natural gas/No.2 fuel oil-fired boiler
(NSPS) (44.398 mmBtu/hr maximum heat input) N/A N/A
O eratin on NG,0% opacity
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,>20%opacity
(See discussion in the inspection snmrnar
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)
Not Operating
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
Eliminator
b)therminol(hot oil)heated oven Eliminator
Not Operating
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:
I-ES1 l
Surface Finishing Operation 2Q.0102(c)(2)(E)(i) Yes Yes
Operating; 0%opacity
I-Main-058
Natural gas-fired therminol heater
(15 mmBtu/hr maximum heat input) 2Q .0102(c)(2)(B)(ii) Yes Yes K
(NSPS Subpart Dc)
Operating on NG; 0%opacity
I-01
Natural gas/No.2 fuel oil-fired therminol heater 2 0102 c 2 i Yes Yes
(9.06 mmBtu/hr maximum heat input) Q ' O( )�)()(II)
Not Operating
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I-03
Natural gas/No.2 fuel oil-fired boiler 2Q .0102(c)(2)(B)(i)(II) Yes Yes
(22.65 mmBtu/hr maximum heat input)
Not Operating

VI. APPLICABLE AIR QUALITY REGULATIONS:
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A. 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 COMPLIANCE: The facility's permit expires on 30 April 2022, and the
1 application is due no later than 31 January 2022. The facility's current permit was renewed on time.
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B. 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 lb/mmBtu.
APPEARED IN COMPLLANCE. 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.
C. 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)0 67 for P<=30 tons/hr,or
E=55 * (P)° '-40 for P>30 tons/hr
APPEARED INCOMPLIANCE: 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.
D. 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 COMPLIANCE: The facility combusts primarily natural gas, but may combust No.
2 fuel oil if necessary. The facility only accepts ultra-low suer diesel(ULSD), as verified by fuel
certifications. AP-42 S02 emission factors for natural gas and ULSD are 0.0006 lb/mmBtu, and
0.002 lb/mmBtu respectively.
E. 15A NCAC 2D .0521—CONTROL OF VISIBLE EMISSIONS—VE 5 20%opacity.
Concern Expressed: Upon climbing to the roof of the facility to gain the correct Method 9
observation location, I noted what appeared to be VE at>20%opacity from the stack for CD-2. I did
not perform a formal Method 9 observation at the time of the inspection. I expressed my concern to
Mr. Burr and Mr. Kelly and requested that they have a technician check the CD-2's operating
parameters. Mr. Kelly informed me that the temperature of the emissions entering the unit was--210
°F and the temperature of the emissions exiting the stack the unit was--100 'F. I told Mr. Kelly that
the company needs to have their control device consultant evaluate CD-2 an conclude if the unit was
operating correctly(i.e., as designed) and to contact FRO with the findings of that inspection.

F. 15A NCAC 2D .0524-NEW SOURCE PERFORMANCE STANDARDS (Subpart De)-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 COMPLIANCE: 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. The facility's semiannual reports have been received on time, and indicate that the last time
the facility used any measurable amount offuel oil was in 2014 when 6,951 gallons were combusted.
The facility was issued an NOD after the 5112116 inspection for not conducting Method 9
observations when it performed boiler testing while combusting fuel oil. Mr. Kelly indicated that no
fuel oil was combusted since the last inspection and specifically during the most recent annual tune-
up on the boiler. The company chose to tune the boiler using natural gas as they had problems
scheduling a Method 9 observer during the short testing time window.
G. 15A NCAC 2D .0535-NOTIFICATION REQUIREMENT-Notify DAQ in the event of excess
emissions lasting longer than 4 hours.
APPEARED INCOMPLIANCE: Mr. Burr stated that the facility has had no exceedances,
breakdowns, or abnormal conditions requiring notification. -
H. 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.
Burr stated that there had been no dust complaints in the past year.
1. 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 INCOMPLIANCE. The facility monitors pressure drop across the mist eliminators
during each shif, and records the values in a logbook All values in the log book were below the
level which would require a wash procedure. I observed a mist eliminator AP of 1.8"of H2O. The
two previous recorded AP readings for CD-2 were 0.08"of H2O and 0.08"of H2O recorded at 08:30
AMand 10:30 AM, both on 13 April2017. Weekly maintenance is performed as required. The last
weekly inspection on both units was on 7 April 2017. The mist eliminator's coils were changed in a
two-day maintenance operation between 41717 through 419117. The mist eliminators are inspected
semiannually with the most recent internal inspections occurring on 20 January 2017 for CD-2, and
5 April 2017 for CD-1.

J. 15A NCAC 2D .0958—WORK PRACTICES FOR SOURCES OF VOCs—Permittee shall adhere
to work practices as delineated in the permit.
APPEARED IN COMPLLANCE: During this inspection, lids were on tight and all cleaning rags
were properly stored.
K. 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. Burr stated that there had been no odor
complaints in the past year.
L. 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 Da
APPEARED IN COMPLIANCE: I discussed the fact that boiler(ID No. I-Main-058) is subject to
NSPS Subpart De with Mr. Burr. The boiler is only capable offering natural gas, and the facility
keeps appropriate records. Mr. Burr showed me the NG usage records that their permit required
them to record. In CY2016, the facility combusted 96,539 Therms (THMs) or 9,354.6 million cubic
feet(MCF).
M. 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 INCOMPLIANCE: Records indicate no fuel oil consumption in the past 12 months,
which is tracked by taking monthly measurements of the fuel storage'rank levels. Fuel certifications
were available, and show that the facility only receives ULSD. The annual report was received on
time on 05 January 2017, and indicated compliance.
N. 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, and fuel use records indicate that no fuel oil has been fired since the facility was curtailed in
2014. Mr. Burr also noted that no fuel oil was fired during the most recent boiler tune-up conducted
on 6 February 2017 as the company chose to tune the boiler using natural gas due to problems
scheduling a Method 9 observer (required if combusting fuel oil) during the short tuning time
window.

O. 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:
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.
VUL 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,with concern expressed regarding VE at>20%opacity at the CD-2 stack.
- Recommend issuing a Compliance Additional Information letter to the facility noting that they
have a 6-month period to evaluate their Condensers/Mist Eliminators(ID Nos. CD-1 and CD-2)
current controls to determine if they are properly sized,maintained, operated, etc. in order to
resolve what appears to be VE issues.
PINK SHEET ADDITIONS:
Remove 2D .0958 during permit renewal since it applies only in none-attainment area and Anson
County is in attainment.
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