AQ_F_0400009_20160512_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Hornwood Inc
NC Facility ID 0400009
Inspection Report County/FIPS: Anson/007
Date: 05/19/2016
Facility Data Permit Data
Hornwood Inc Permit 04888/R14
j 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
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 05/12/2016
Inspector's Name Joshua L.Harris
Inspector's Signature: ������� ) Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: os�g`z iG On-Site Inspection Result Deficiency
Total Actual emissions in TONS/YEAR:
TSP SO2 NOX VOC CO PMIO *HAP
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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 pounds)
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
L 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.

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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 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.
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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'et dying. In beam dying,fabric
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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 i
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.
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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.
Throughputs:
2015 7,908,000
2014 7,937,000
2013 10,312,041
IV. INSPECTION SUMMARY: On 12 May 2016,I Joshua Harris,FRO DAQ, conducted a compliance
inspection of Hornwood,Inc. in Lilesville,Anson County. The facility was operating at the time of the
inspection, and as I approached the facility I noted light visible emissions from the CD-1 stack at—10%
opacity. I met with Benny Burr,Environmental Manager, and first verified the FacFinder data. Mr. Burr
stated that Dale Kelly,Plant Engineer, was not available, and that he typically has all of the required
records,however,MT. Burr knew the general locations of the records I was asking for. Mr.Burr escorted
me to the electrical maintenance shop to review the inspection and maintenance records for the facility's
mist eliminators(ID Nos. CD-1 and CD-2). After some difficulty,the required records were produced,
and it appeared that all inspections, maintenance, and monitoring are performed as required.
We then went to the office of Larry Adams,VP of Manufacturing Services,where I reviewed the
facility's fuel use records. Natural gas usage is monitored by the security personnel,who read the meter
at each shift. Fuel oil tank levels are checked monthly,and both Mr. Adams and Mr. Burr stated that the
jl facility has not combusted fuel oil in quite some time. When I asked if the facility's boilers are ever
tuned-up, Mr. Burr stated that they are tuned annually, and that some oil might be combusted at that time,
but not enough to make a noticeable change in tank level. I asked to see the records of the tune-ups to
verify whether fuel oil was combusted in the facility's NSPS Subpart Dc boiler(ID No. Main-031), but
was told that those records were kept by Mr. Kelly,who was unavailable. We then had a discussion
regarding the permit requirement to conduct a Method 9 VE evaluation when a switch is made from
natural gas to fuel oil. Mr. Burr and I then went to the boiler house,where the maintenance technician
indicated that the boilers do combust fuel oil during the tune-ups.No VE evaluations appear to have been
1 made when these fuel switches have occurred.
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Prior to my departure,I went through the permit with Mr. Burr, and explained the testing requirement in
NSPS Dc. I also reiterated the fact that multiple people should to be aware of the locations of required
documentation, and that those records should be accessible at all times.
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V. PERMITTED EMISSION SOURCES:
$oilcr1l 'eratians,ulcTu au m. ........,
Main-03 Natural gas/No.2 fuel oil-fired boiler
M 1
ain-03 (44.398 mmBtu/hr maximum heat input) N/A N/A
Operating on NG;0%opacity
Q erahons lnclpin . NO-
Textile tenter frame(1,500 lbs of cloth per hour
maximum capacity)consisting of the following: Condenser/Mist
Tenter 1 a)pad-applied finishing station,and CD-2 Eliminator
b)therminol(hot oil)heated oven.
Operating; 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 CD-2
b)natural gas-fired four zone heated oven Eliminator
(7.2 million Btu per hour maximum heat input)
Operating; 0%opacity
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,applying "e 0 "coatin ;—10%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 f
(6 million Btu per hour maximum heat input)
Not Operating
VI. APPLICABLE AIR QUALITY REGULATIONS:
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 COMPLL4NCE. The facility's permit expires on 30 April 202Z and the
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.
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APPEARED INCOMPLL4NCE. The facility is permitted to combust both natural gas and No. 2 j
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 0.00071b/mmBtu, and 0.02 lb/mmBtu respectively.
The facility's permit states this limit as 0.039 lb/mmBtu, which is a typo. There is a pink sheet note
to have this corrected at the next permit action.

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)°67 for P<=30 tons/hr, or
E= 55 * (P) 01 t-40 for P>30 tons/hr
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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.
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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 su fur 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<20% opacity.
APPEARED INCOMPLIANCE: Upon arrival, I noted VE at—10%opacity at the stackfor CD-1.
Tenter frame 3, which is controlled by CD-1 was operating at the time, and an epoxy coating was
being applied to the fabric. This operation has historically generated smoke, and previous VE
evaluations have noted VE at—5% I noted 0%opacity for all other sources.
j F. 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 5 20%opacity. Initial start-up testing, and periodic testing for visible emissions when
switching from natural gas to fuel oil. Semiannual reporting.
DEFICIENCYNOTED: 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. Burr and Mr.Adams indicated that some small amount fuel oil is combusted during the annual
tune-ups on the boiler. The facility's semiannual reports have been received on time, and indicate
that the last time the facility used any measurable amount of fuel oil was in 2014 when 6,951 gallons
were combusted. The facility conducted the required initial testing on the boiler in 2002, but has
failed to conduct periodic testing when switching to fuel oil, which has been required by the NSPS
since January 2011. Recommend issuing a Notice of Deficiency for the missed VE evaluations.
G. 15A NCAC 2D .0535—NOTIFICATION REQUIREMENT—Notify DAQ in the event of excess
emissions lasting longer than 4 hours.
APPEARED IN COMPLIANCE: There are no indications of excess emissions which would
require a notification by the facility. I discussed this with Mr. Burr, and he seems to understand the
requirement. No complaints have been received by the facility or by DAQ.
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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 INCOMPLIANCE. 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.
I. 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 shift, and records the values in a logbook All values in the log book were below the
level which would require awash procedure. The facility has recently installed an electronic
monitoring system, and is in the process of configuring the alarms for pressure drop. Weekly
maintenance is performed as required, and the mist eliminators are actually inspected semiannually
with both units being inspected last on 21 January 2016, and 30 July 2015.
J. 15A NCAC 2D .0958—WORK PRACTICES FOR SOURCES OF VOCs—Permittee shall adhere
to work practices as delineated in the permit.
APPEARED IN COMPLIANCE. No concerns were noted during the inspection. There did not
appear to be any unsealed or open containers, or wipe rags left out.
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 COMPLIANCE. No offensive odors were noted as I approached the facility, nor
were there any noticeable odors while inside. No odor complaints have been received by the facility
or by DAQ.
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 Dc.
.APPEARED INCOMPLIANCE: I discussed the fact that this boiler is subject to NSPS Subpart Dc
with Mr. Burr. We referred to the 21).0524 stipulation in the facility's permit for Main-031, and I
showed him which sections are applicable to I-Main-058. The boiler is only capable of firing natural
gas, and the facility keeps appropriate records.
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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.
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APPEARED INCOMPLIANCE: Records indicate no fuel oil consumption in the past 12 months,
which is tracked by taking monthly measurements of the fuel storage tank levels. We discussed the
tune-ups on the facility's boilers, and Mr. Burr stated that some fuel oil is combusted when the tune-
ups are conducted, but it is not a measureable amount. Fuel certifications were available, and show
that the facility only receives ULSD. The annual report was received on time on 08 January 2016,
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 INCOMPLLANCE. The facility only fires natural gas, and fuel use records indicate
that no fuel oil has been fired since the facility was curtailed in 2014. Mr. Burr indicated that some
fuel oil is fired during tune-ups, but not a measurable amount.
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 COMPLIANCE: 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. INSIGNIFICANT ACTIVITIES:
® N rs '1 ti o � r me
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' 41 °n t _
® m��� v 5"Y °tiw '" 8h 5 o I Hx Ix�I"
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I-ES 11 2Q .0102(c)(2)(E)(i) Yes Yes
Surface Finishing Operation
I-Main-058
Natural gas-fired therminol heater 2Q .0102(c)(2)(B)(ii) Yes Yes
{ (15 mmBtu/hr maximum heat input)
SPS Subpart De)
I-01
Natural gas/No.2 fuel oil-fired therminol heater 2Q .0102(c)(2)(B)(i)(11) Yes Yes
(9.06 mmBtu/hr maximum heat input)
I-03
Natural gas/No.2 fuel oil-fired boiler 2Q .0102(c)(2)(B)(i)(I1) Yes Yes
(22.65 mmBtu/hr maximum heat input)

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VHL NON-COMPLIANCE HISTORY SINCE 2010:
06/02/2015 CAI issued requesting records which were unavailable during the 05/26/2015 inspection.
IX. RISK MANAGEMENT (112r): This facility does not use or store any 112(r) subject materials above
threshold limits. Therefore, it is not required to maintain a written Risk Management Plan (RMP).
X. CONCLUSION AND RECOMMENDATIONS:
Hornwood, Inc. appeared to be operating IV COMPLLANCE with their air permit at the time of this
inspection,with noted deficiencies regarding NSPS Subpart De.
- Recommend issuing a Notice of Deficiency with regard to missed VE testing required by NSPS
Subpart Dc after a fuel switch from natural gas to oil in Main-031.
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PINK SHEET ADDITIONS:
Reword I&M requirements of 2D .0611 stipulation which states, "The Permittee shall inspection
and maintenance of the ..."
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