Loading...
HomeMy WebLinkAboutAQ_F_0400009_20220603_PRMT_PmtRvw NORTH CAROLINA DIVISION OF Region: Fayetteville Regional Office AIR QUALITY County: Anson Application Review NC Facility ID: 0400009 Inspector's Name: Mike Thomas Issue Date: 06/03/2022 Date of Last Inspection: 11/17/2021 Compliance Code: 3/Compliance- inspection Facility Data Permit Applicability(this application only) Applicant(Facility's Name): Homwood Inc SIP: NSPS: Facility Address: NESHAP: Hornwood Inc PSD: 766 Hailey's Ferry Road PSD Avoidance: Lilesville,NC 28091 NC Toxics: 112(r): SIC: 2258/Warp Knit Fabric Mills Other: NAICS: 313312/Textile and Fabric Finishing(except Broadwoven Fabric)Mills Facility Classification: Before: Small After: Small RENEWAL Fee Classification: Before: Small After: Small Contact Data Application Data Facility Contact Authorized Contact Technical Contact Application Number: 0400009.22A Benny Burr Charles Horne Dale Kelly Date Received: 01/31/2022 Environmental Manager President Plant Engineer Application Type: Renewal (704)848-4121 (704)848-4121 (704)848-4121 Application Schedule: State 766 Hailey's Ferry Road 766 Hailey's Ferry Road 766 Hailey's Ferry Road Existing Permit Data Lilesville,NC Lilesville,NC Lilesville,NC Existing Permit Number: 04888/R16 28091+9759 28091+9759 28091+9759 Existing Permit Issue Date: 09/07/2021 Existing Permit Expiration Date: 04/30/2022 Review Engineer: Jeffrey D.Cole Comments/Recommendations: Issue 04888/R17 Review Engineer's Signature: Date: Permit Issue Date: 06/03/2022 4:;�, C/ Permit Expiration Date: 05/31/2030 3�az 1. Purpose of Application Hornwood Inc is an existing textile manufacturing facility located in Lilesville, Anson County. The facility has requested a permit renewal without modification. This facility is currently classified as Small. The facility has a permit stipulation that limits the facility to only combusting ultra-low sulfur No.2 fuel oil with a maximum sulfur content of 15 ppm by weight(0.0015%),therefore,the facility's potential emissions will not exceed Title V permitting thresholds. The application did not contain any confidential information. There was one facility file"Pink Sheet" item to be addressed in this permit revision(see Section 5). The facility contact for the application is Dale Kelly, Plant Engineer(704-848-4121). Homwood Inc Permit R17 Review Page 2 of 11 2. Facility Description Hornwood, Inc. is a textile company that warps,weaves, and dyes yarn, and 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, cowboy shirts,and other cloth items. 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 it is 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. Finishin,: Cloth is passed through one of four tenter frame dryers which heat set 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 may be napped(which gives it the appearance of fleece), sheared(which cuts off the top of the fleece), or sueded(which sands the fabric). Utilities: Heat for the processes is provided by two natural gas/#2 fuel oil-fired boilers, a natural gas/#2 fuel oil-fired Therminol heater,and a natural gas-fired Therminol heater. Heat for the tenter frame dryers is provided by direct-fired natural gas burners. Mist Eliminators: The facility was historically permitted to operate two condenser/mist eliminators (CD-1 and CD-2). CD-1 is no longer in use and was last operated on 3 March 2021. 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),which currently controls TF-1 and TF-2,the air passes over four(4)cold water coils and six (6)spray rings that both condense the vapor prior to the mist eliminator. Both mist eliminators house sixteen(16)two inch wire mesh cylinders that are each surrounded by a fiberglass 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. Homwood Inc Permit R17 Review Page 3 of 11 I Electrostatic Precipitators: The facility is permitted to operate two electrostatic precipitators(CD-3 and CD-4)both of which are 2,367 square feet of collection surface area. CD-3 controls emissions from Tenter Frames#3 and#4. CD-4 (which is currently still under construction)will control emissions from Tenter Frame#1.In electrostatic precipitator(ID No.CD-3),which controls TF-3 and TF-4, emission gases are passed through transmission plates, particles in the gas stream are ionized and obtain an electrical charge. The charged particles are then collected on the collection plates and removed from the gas stream. 3. Zoning A zoning consistency determination is not required, as this is permit renewal. 4. Application Chronology Date Acdyfity 10/06/21 FRO sent the"Air Permit Renewal Reminder and Emission Inventory Due Notification"letter to the facility. Mike Thomas of FRO DAQ inspected the site and found it to be in apparent compliance. Mr.Thomas offered assistance with preparing the EL Mr. Kelly requested help in logging into AERO. Mr. Thomas went over 11/17/21 the user ID and password information for the AERO system with Mr. Kelly and made certain that he was able to log in successfully. Mr. Kelly told Mr. Thomas that he felt like he knew what needed to do to complete their j inventory and thus declined Mr. Thomas's offer to help enter the emissions data. i FRO received the renewal packet including the"A Form".No fees were k O1/31/22 required. There was no request to keep any information confidential. The application appeared to be complete for processing. PERMIT APPLICATION CLOCK OFF 02/01/22 FRO sent the facility a letter acknowledging receipt of the permit application. i Mike Thomas determined the application was actually incomplete for processing as the emission inventory utilized data from CY 2021 rather 02/11/22 than CY 2020 as required. Mr. Thomas disputed the incorrect operation scenarios and sent the EI back to the Mr.Kelly for corrections. Mr. Cole entered a"Completeness Additional Information"event into IBEAM resetting the permit clock back to when the application was received. Mike Thomas further reviewed the EI data calculations and found that the company's VOC calculations were incomplete and did not reflect the 02/17/22 VOCs from a specific polymer chemical that they utilized. Mr. Thomas contacted Mr.Kelly and suggested that he consult the polymer's manufacturer to determine its VOC content. Hornwood Inc Permit RI Review Page 4 of 11 02/23/22 Mr. Kelly emailed Mr. Thomas and noted that there had been no response from the polymer's manufacturer to their inquiry. 03/03/22 To There were several emails between Mr. Kelly and Mr. Thomas on other 03/16/22 Possible methods to determine the specific polymer's VOC content. Mr. Kelly emailed Mr. Thomas stating that they had contracted a laboratory 1j 03/17/22 i to analyze a sample of the specific polymer to determine its VOC content. i � I 04/07/22 The facility submitted the emissions inventory data via AFRO. 04/08/22 FRO received the emission inventory and certification sheet. ' PERMIT APPLICATION CLOCK ON < i 04/11/22 Stephen Allen approved the emission inventory and forwarded it to the permit engineer. 5. Changes in Equipment,Emissions,and Regulations,and PE Review Requirements Hornwood Inc is requesting a permit renewal without modification. • There are no changes to equipment or regulations. • There was one facility file"Pink Sheet" item to be addressed in this permit revision. The following note stated, "See the R14 permit review for updated information on emission factors for this facility for use in submittal of the next El." The facility appears to have utilized the R14 permit review emission factor logic in their current EI. • No PE Seal is required for a permit renewal without modification. The facility Emission Sources and Controls are as follows: t ._ Emission Control Control Farce Emission Source Description System System ID Description Boiler Operations,including: Main-031 Natural gas/Ultra-low Sulfur No.2 fuel oil-fired boiler N/A (NSPS Dc) (44.398 mmBtu/hr maximum heat input) Textile Operations,including: Homwood Inc Permit R17 Review Page 5 of 11 Emission Control Control Source ID Emission Source Description System System ID Description Textile tenter frame(1,500 lbs of cloth per hour maximum Electrostatic capacity)consisting of the following: Precipitator Tenter 1 a) pad-applied fmishing station,and CD-4 (2,367 sq.ft. b) therminol(hot oil)heated oven. collection surface area) Textile tenter frame(2,300 lbs of cloth per hour maximum F- capacity)consisting of the following: Tenter 2 a) pad-applied finishing station,and CD-2 Condenser/Mist b) natural gas fired six zone oven Eliminator (9 million Btu per hour maximum heat input) Textile tenter frame(2,000 lbs of cloth per hour maximum Tenter 3 capacity)consisting of the following: a) pad-applied finishing station,and b) therminol(hot oil)heated oven. Electrostatic Precipitator -- --------_-- ------ -- CD-3 (2,367 sq.ft. Textile tenter frame(2,100 lbs of cloth per hour maximum collection surface capacity)consisting of the following: area) Tenter 4 a) pad-applied finishing station,and b) natural gas fired six zone oven (6 million Btu per hour maximum heat input) TH-01 Natural gas/Ultra-low Sulfur No.2 fuel oil-fired therminol heater N/A (9.06 mmBtu/hr maximum heat input) B-03 Natural gas/Ultra-low Sulfur No.2 fuel oil-fired boiler N/A (22.65 mmBtu/hr maximum heat input) 1 The insignificant/Exempt Activities at the facility are as follows: S of Source of Source Source Exemption Regulation ounce Title V Pollutants? I-ES I I 02Q.0102(h)(5) Yes Yes Surface Finishing Operation r7 I-Main-058 Natural gas-fired therminol heater 02Q.0102(h)(1)(B) j Yes Yes (15 mmBtu/hr maximum heat input) 1 (NSPS Dc) Homwood Inc Permit R17 Review Page 6of11 6. NSPS,NESHAP,PSD,and Attainment Status, 112(r) • NSPS— ✓ Boiler(ID No. Main-031) is subject to NSPS Subpart Dc because it was constructed in 2001. ✓ Therminol heater(ID No.TH-01) is not subject to NSPS Subpart Dc because it has less than 10 mmBtu/hr maximum heat input and was constructed in 1972. ✓ Boiler(ID No. B-03)is not subject to NSPS Subpart Dc because it was constructed in 1971. ✓ Therminol heater(ID No.I-Main-058)is subject to NSPS Subpart Dc because it was constructed in 2014. • NESHAP—There are no current NESHAP regulations that are applicable to this facility. ✓ The natural gas/Ultra-low Sulfur No. 2 fuel oil-fired boilers(ID Nos. Main-031 and B-03)are not subject to NESHAP Subpart JJJJJJ(6J)because they are considered as gas-fired boilers and avoid the applicability of the rule by combusting liquid fuels only during periods of gas curtailment,gas supply interruption, startups,or periodic testing on liquid fuel(periodic testing not to exceed 48 hours during any calendar year). ✓ The therminol heaters(ID Nos.TH-01 and I-Main-058)are not subject to NESHAP Subpart 6J,as they do not meet the definition of boilers under this rule, since they do not utilize water. • PSD—PSD does not impact this application, as the potential emissions after controls are less than PSD threshold quantities. Anson County has not triggered minor source increment tracking. • 112(r)—The facility does not store any of the subject chemicals in amounts that exceed the threshold quantities. The facility is therefore not required to maintain a written Risk Management Plan(RMP). • Attainment Status—Anson County is in attainment. 7. Facility Emissions Review The Actual Emissions for 2020 are from the latest facility emission inventory submitted via AERO and for this permit review. Potential PMio emissions from the tenter frame dryers were calculated using the emission factor from the Lumberton Dyeing and Finishing facility stack testing in 1980, which indicated an uncontrolled emission factor of 4.18 lb/ton of fabric dried. PM2.5 emission factors were determined based on testing for condensable particulate at the Kordsa facility in January 2014. The condensable PM was considered to be PM25 and was found to be approximately 80%of the PM]o emissions. We have therefore used a factor of PM2.5=0.8 x 4.18=3.3441b/ton of fabric dried. Maximum throughput rate for Tenters 1/2 and Tenters 3/4 are 1.975 tons/hr fabric dried for each pair of tenters(total facility throughput 3.95 tons/hr of fabric dried). Potential before control PM, PMIo and PM2.5 from tenter frame process emissions are 72.31 ton/yr, 72.31 ton/yr and 57.85 ton/yr, Homwood Inc Permit R 17 Review Page 7 of 11 respectively. Note that potential emissions of PM,PMIo and PM2.5 from the tenter frames only are expected to be reduced by 90%for Tenter 2(controlled by a Condenser/Mist Eliminator)and by 95% for Tenter's 1,3 and 4(each controlled by an ESP). Potential combustion emissions for the boilers and tenter frame burners are taken from the DAQ Natural Gas Combustion Emissions Calculator Revision N 1/05/2017 and the DAQ Fuel Oil Combustion Emissions Calculator Revision G 11/5/2012. Potential emissions assume the worst-case emissions using either fuel permitted. Tenter frame process VOC emissions are estimated using material balances from actual 2020 materials usages and VOC content(based on 7,488 hours of operation), ratioed up to 8,760 hours operation. See page 11 of this review for the emission calculations and basis. Facility-wide emissions expected after this modification are as follows: 2020 Emissions Potential Emissions Potential Emissions Pollutant tonslyr More Controls After Controls j tonslyr tons/yr PM 5.91 80.43 12.24* PM10 5.91 74.95 1 6.76* PMz.s �4.79 ____[_ 59.67 4.25* --- SO2 o.a-I 0.91 0.81 NO: 4.26--1 97 �� 97 CO 2.92 68.94 68.94 VOC 2.45--1 7.02 7.02 *Note that these totals include the Tenter potential emissions before control for Tenter's 1,3 and 4 reduced by 95%(ESP equipped)and for Tenter 2 reduced by 90%(Condenser/Mist Eliminator equipped)added to the boiler potential emissions before control as the boilers are uncontrolled. 8. Toxies Review No previous toxics modeling has been performed for this facility. The permit contains a 02Q .0711 toxics permit condition but does not contain a 02D .1100 toxics condition. Note that the toxics condition did not previously apply to the boilers or therminol heaters,and the toxic pollutants from these sources have not been included in the 02Q .0711 permit condition. 9. Facility Compliance History 11/17/21 Mike Thomas conducted the latest facility inspection and found the facility to be in apparent compliance during the inspection. 08/03/21 Mike Thomas conducted a facility inspection and found the facility to be in apparent compliance during the inspection. Hornwood Inc Permit R17 Review Page 8 of 11 10/01/20 NOV issued for failure to conduct a Method 9 VE observation required by NSPS Dc. 09/02/20 Jeffrey Nelson conducted the latest facility inspection and found the facility to be in apparent violation for failure to conduct a Method 9 VE observation under NSPS Dc. 07/29/20 NOD issued for installing an unpermitted air pollution control device per NCGS 143-215.108. 04/15/20 A virtual inspection (partial inspection due to COVID restrictions)was conducted by Jeffrey Nelson. The facility was found to be in apparent compliance during the inspection. 04/26/19 NOV/NRE issued for excess visible emissions and failure to properly maintain a control device. 04/09/19 The facility was inspected by Jeffrey Cole and was found to be in violation of 02D .0521 Visible Emissions during the inspection. 04/13/17 The facility was inspected three(3)times by Jeffrey Cole and was found to be in apparent through compliance during each of these inspections. 04/25/18 05/16/16 NOD issued for failure to perform VE testing under NSPS Dc. 05/12/16 The facility was inspected by Joshua Harris and was found to be in violation of 02D .0524 NSPS Dc during the inspection for failure to perform VE testing during January to February 2014. 06/10/09 The facility was inspected seven(7)times by Robert Hayden and Maureen through Matroni-Rakes and was found to be in apparent compliance during each of these 05/26/15 inspections. 10. Stipulation Review The following regulations are applicable to this facility: Regulation Affected Emission Limit Sources Or Requirement 15 NCAC 02D ( Facility Wide I Permit Renewal&Emissions Inventory Submittal .0202 15 NCAC 02D Main-031 .0503 TH-01 PM<0.39 lb/mmBtu B-03 Tenter 1 15 NCAC 02D Tenter 2 E=4.10 * (P)0-61 for P<30 tons/hr,or .0515 Tenter 3 E=55 *(P)01-40 for P>30 tons/hr fTenter 4 Homwood Inc Permit R17 Review Page 9 of 11 Regulation Affected Emission Limit Sources Or Requirement 15 NCAC 02D Main-031 0516 ( TH-01 2.3 pounds SO2 per million Btu heat input. B-03 15 NCAC 02D F20 percent opacity when averaged .0521 Facility Wide over a six-minute period For Oil-fired boilers>30 mmBtu/hr maximum heat input: 15 NCAC 02D No.2 Oil Sulfur content<0.5%by weight .0524 Main-031 Fuel Usage Records;Semi-annual Reporting NSPS Subpart Dc Initial Method 9 VE source testing if combusting oil Periodic Method 9 VE testing frequency depends on most recent Method 9 observation after starting to combust oil 15 NCAC 02D .0535 Facility Wide Excess Emissions Reporting 15 NCAC 02D Facility Wide Fugitive Dust 0540 Maintain fuel certification records and confirm that the 15 NCAC 02D Main-031 ultra-low sulfur No.2 fuel oil combusted meets the .0605 TH-01 specification for ASTM D975 Grade No.2-D S15 fuel Ad-Hoc B-03 oil(maximum 15 ppm [0.0015%] sulfur content,by weight). Condenser/Mist Eliminator Requirements 15 NCAC 02D CD-2 Periodic I&M per Manufacturer's Recommendations .0611 Annual internal inspection Recordkeeping Electrostatic Precipitator Requirements 15 NCAC 02D CD-3 Periodic I&M per Manufacturer's Recommendations .0611 CD-4 Annual inspection Recordkeeping 15 NCAC 02D Facility Wide Odorous Emissions .1806 1 � 15 NCAC 02Q FI-M ain-058 Applicability of NSPS Subpart Dc .0102 to the exempt therminol heater Avoidance condition for NESHAP Subpart JJJJJJ(6J) 15 NCAC 02Q Main-031 Liquid fuels permitted only during periods of gas .0317 B-03 curtailment,gas supply interruptions,startups,and periodic testing on liquid fuels(not to exceed 48 hours F in any calendar year) 15 NCAC 02Q Facility Wide TPER Limits 0711 11. Conclusion,Comments,and Recommendations I I i Homwood Inc Permit R17 Review Page 10 of 11 • I recommend that air permit 04888R17 be issued to Hornwood Inc. • Modifications to IBEAM: ✓ Adjusted column widths,bolded and shaded throughout to improve appearance. ✓ In the 02D .0524 NSPS Dc condition for boiler ID No.Main-031,changed the emission limitations pollutant from"Particulate"to"Visible Emissions". ✓ In the 02D .0524 NSPS Dc condition for boiler ID No.Main-031,changed the NSPS Performance Testing pollutant from"Particulate"to"Visible Emissions". ✓ Added the Ad-Hoc condition for"Records Maintenance Requirement"under 02D .0605 for the description of Ultra-low Sulfur fuel oil(language excerpted from the Kansas City Sausage Permit R14(Facility ID 8200115). ✓ Changed the title of the 02D .0611 "Condenser Requirements"condition to read "Condenser/Mist Eliminator Requirements". ✓ Modified the wording in the 02Q .0317 Avoidance condition for NESHAP Subpart JJJJJJ (6J)to indicate that two boilers(ID Nos. Main-031 and B-03)are included in this exemption and that the fuel oil is Ultra-low Sulfur No. 2 fuel oil. ✓ Deleted the columns in the 02Q .0711 condition table that listed"Carcinogens",Chronic Toxicants"and"Acute System Toxicants,"as these columns had no entries. Review Engineer Date /7l7 z Permit Coordinator K4L, —C Date 06/03/2022 DAQ Supervisor � _ Date J ?Z /JDC FRO Files I I i Hornwood Inc Permit R17 Review Page 11 of 11 Emissions Calculations: PM and PMio emission factors are taken from testing at the Lumberton Dyeing and Finishing facility in 1980. These factors are: PM=PMio=4.18 lb/ton of fabric dried PM2.5 emission factors are determined based on testing for condensable particulate at the Kordsa facility in January 2014. The condensable PM was considered to be PM2.5 and was found to be approximately 80%of the PMio emissions. We have therefore used a factor of PM2.5=0.8 x 4.18=3.344 lb/ton of fabric dried. Maximum throughput rate for Tenters 1/2 and Tenters 3/4 are 1.975 tons/hr fabric dried for each pair of tenters for a total facility throughput 3.95 tons/hr of fabric dried. Combustion emissions for the boilers and tenter frame burners are taken from the DAQ Natural Gas Combustion Emissions Calculator Revision N 1/05/2017 and the DAQ Fuel Oil Combustion Emissions Calculator Revision G 11/5/2012. Potential emissions assume the worst-case emissions using either fuel permitted. Tenter frame process VOC and HAP/TAP emissions are estimated using material balances from actual 2020 materials usages and VOC/HAP/TAP content(based on 7,488 hours of operation),ratioed up to 8,760 hours operation. CONTROL FACILITY-WIDE FACILITY-WIDE INDIVIDUAL SOURCES EFFICIENCY 2020 POTENTIAL POTENTIAL POTENTIAL ACTUAL EMISSIONS EMISSIONS POLLUTANT EMISSIONS EMISSIONS (for Tenter BEFORE AFTER BEFORE CONTROLS frame tons CONTROLS CONTROLS tons emissions tons/yr tons/yr only) Tenters Tenters 1,2,3,4 I Tester Tenters 1-4 COMBUSTION & MAIN-031 TH-1 Main- B-03 1 &2 3&4 PLUS HAP/TAP 058 PM ONLY PROCESS ONLY ONLY HAP/TAP ONLY PM ------ 4.58* 0.94* 0.03** 2.34* 36.16 36.16 0.22** 90or95 80.43 12.24***** PM,o ------ 1.39* 0.28* 0.03** 0.71* 36.16 36.16 0.22** 90 or 95 74.95 6.76***** PM2.5 ------ 0.35* 0.07* 0.03** 0.18* 28.93 28.93 0.18** 90 or 95 58.67 4.25***** S02 ------ 0.30* 0.06* 0.04** 0.15* ------ ------ 0.26** 0 0.81 0.81 NOx ------ 27.78* 5.67* 6.44** 14.17* ------ I ------ 42.94** 0 97 97 CO ------ 16.01** 3.27** 5.41** 8.17** ------ ------ 36.08** 0 68.94 68.94 VOC 2.15 1.05** 0.21** 0.35** 0.53** ------ ------ 4.88*** 0 7.02 7.02 HAP/TAP 0.16 ------ ------ ------ ------ ------ ------ 0.99**** 0 0.99 0.99 *Worst-case emissions from No.2 Fuel oil combustion,using UItra-Low Sulfur No.2 fuel oil(maximum 15 ppm Sulfur content by weight) "Worst-case emissions from natural gas combustion ***Includes both combustion emissions and process VOC emissions from chemical usage **** Includes only process HAP/TAP emissions from chemical usage *****Note that these totals include the Tenter potential emissions before control for Tenter's 1,3 and 4 reduced by 95%(ESP equipped)and for Tenter 2 reduced by 90%(Condenser/Mist Eliminator equipped)added to the boiler potential emissions before control as the boilers are uncontrolled. I Facility Total CY 2020 Emission Summary Recorded in ED Facility ID #: 0400009 Facility Name: Hornwood Inc Permit#(s): 04888R16 i Green House Gases Pollutants (GHG) Actual Emissions % j Tons/Yr Pollutant CAS Demini- Change mus Not Not N/A Reported Reported CO2 equivalent(sum of individual GHG pollutant emissiot No GHGs times their 1995 IPCC Global Warming Potential (GWP), Reported converted to metric tons) Criteria Pollutants Actual Emissions (Tons/Year) Pollutant CAS CY 2020 CY 2013 Demini- % from ED from Fees mus Change CO CO 2.92 5.32 0.5 -45.1% NOx NOx 4.20 6.35 0.5 1 -33.9% PM(TSP) TSP 5.91 8.97 0.5 -34.1% PM10 PM10 5.91 8.97 0.5 -34.1% PM2.5 PM2.5 4.79 7.25 0.5 -33.9% S02 SO2 0.040000 0.050000 0.5 -20.0% VOC VOC 2.40 10.30 1 0.5 1 -76.7% Hazardous Air Pollutants (HAPs) Actual Emissions and/or Toxic Air Pollutants (TAPS) (Pounds/Year) Pollutant CAS CY 2020 CY 2013 Demini- % from ED from Fees mus Change Arsenic & Compounds (total mass of elemental AS, arsine and Not 0.000000 0.01 N/A all inorganic compounds) Reported Arsenic Compounds -Arsine gas (Component of AS 7784-42-1 Not Not 0.01 N/A Reported Reported Beryllium & compounds (Total mass) Not 0.000000 1.0 N/A Reported Beryllium Unlisted Compounds - Specify Compoun' BEC-Other Not Not 1.0 N/A (Component of BEC) Reported Reported Cadmium & compounds (total mass includes elemental metal) Not 0.000000 0.1 N/A Reported Cadmium oxide (Component of CDC) 1306-19-0 Not Not 0.01 N/A Reported Reported 04/11/2022 Page 1 of 4 Facility Total CY 2020 Emission Summary Recorded in ED Facility ID #: 0400009 Facility Name: Hornwood Inc Permit#(s): 04888R16 Hazardous Air Pollutants (HAPs) Actual Emissions and/or Toxic Air Pollutants (TAPs) (Pounds/Year) Pollutant CAS CY 2020 CY 2013 Demini- % from ED from Fees mus Change Chromium -All/Total(includes Chromium (VI) categories, Not 0.000000 0.1 I N/A metal and others) Reported Chromium(VI)Non-Specific Unlisted Compounds - NSCR6-Other Not Not 0.01 N/A Specify Compound(Component of NSCR6 &CRC) Reported Reported Chromium (VI)Non-Specific Compounds, as Chrom(VI) Not 0.000000 0.01 N/A (Component CRC) Reported Chromium(VI)Non-Specific Unlisted Compounds - NSCR6-Other Not Not 0.01 N/A Specify Compound(Component of NSCR6 &CRC) Reported Reported Glycol ethers (total all individual glycol ethers) Not 15.00 100.0 I N/A Reported Glycol Ethers,Unlisted- Specify Compound GLYET-Other Not 15.00 100.0 N/A (component of GLYET) Reported Lead& compounds Not 0.000000 1.0 I N/A Reported Lead Unlisted Compounds - Specify Compound PBC-Other Not Not 10.0 N/A (Component of PBC) Reported Reported Manganese& compounds Not 0.000000 10.0 N/A Reported Manganese Unlisted Compounds - Specify Compow MNC-Other Not Not 10.0 N/A (Component of MNC) Reported Reported Mercury& Compounds-all total mass includes Hg Vapor Not 0.000000 0.041 N/A Reported Mercury Unlisted Compounds - Specify Compound HGC-Other Not Not 0.001 N/A (Component of HGC) Reported Reported Nickel& Compounds, sum total mass includes elemental Not 0.000000 1,0 N/A Reported Nickel Unlisted Compounds (Component of NIC - NIC-other Not Not 1.0 N/A Specify) Reported Reported Polycyclic Organic Matter(Specific Compounds from OAQPS Not 0.000000 1.0 N/A or Tip Reported Naphthalene (Component of 83329/POMTV) 91-20-3 Not Not 1.0 N/A Reported Reported Acetaldehyde 75-07-0 Not Not 10.0 N/A Reported Reported Acetic acid 64-19-7 90.00 262.00 100.0 04/11/2022 Page 2 of 4 Facility Total CY 2020 Emission Summary Recorded in ED Facility ID#: 0400009 Facility Name: Hornwood Inc Permit#(s): 04888R16 Hazardous Air Pollutants (HAPs) Actual Emissions and/or Toxic Air Pollutants (TAPs) (Pounds/Year) Pollutant CAS CY 2020 CY 2013 Demini- % from ED from Fees mus Change Benzene 71-43-2 Not Not 1.0 N/A Reported Reported Cumene 98-82-8 54.00 Not 100.0 N/A Reported Dioxane, 1,4- 123-91-1 Not Not 0.01 N/A Reported Reported Epichlorohydrin 106-89-8 Not Not 1.0 N/A Reported Reported Ethyl benzene 100-41-4 Not Not 100.0 N/A Reported Reported Ethylene glycol 107-21-1 Not Not 100.0 N/A Reported Reported Ethylene oxide 75-21-8 Not Not 1.0 N/A Reported Reported Fluorides (sum of all fluoride compounds as mass of 16984-48-8 Not Not 10.0 N/A ion) Reported Reported Formaldehyde 50-00-0 13.41 26.61 10.0 F-49.6% Hexane,n- 110-54-3 128.70 194.60 100.0 1 -33.9% Methanol(methyl alcohol) 67-56-1 20.16 18.88 1,000.o 6.8% Methyl chloroform 71-55-6 Not Not 100.0 N/A Reported Reported Polycyclic Organic Matter(Inc PAH, dioxins, etc.N pom Not Not 1.0 N/A &AP 42 historic) Reported Reported Selenium Compounds SEC Not Not 10.0 N/A Reported Reported Toluene 108-88-3 Not Not 100.0 N/A Reported Reported Xylene (mixed isomers) 1330-20-7 108.00 Not 100.0 N/A Reported 04/11/2022 Page 3 of 4 Largest Individual HAP Hexane, n- 128.70 lbs HA P AP Emissions 324.27 lbs Largest Individual CAP PM10 5.91 tons Total CAP Emissions 15.47 tons Total TAP Emissions 340.11 lbs Total Aggregate 15.47 tons Emissions DAQ's Comments Reaardin2 Inventory 2/4/22 Data sent back due to phone call from Dale Kelly informing me that he had used some of the data from the wrong year. 4/11/2022 Reduction in the facility's emissions is due to production being cut down to nearly 1/4th of what it was in 2013. I 04/11/2022 Page 4 of 4