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HomeMy WebLinkAboutAQ_F_0400009_20221123_CMPL_InspRpt_A16 CANNED NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Homwood Inc NC Facility ID 0400009 Inspection Report County/FIPS: Anson/007 Date: 11/23/2022 Facility Data Permit Data Hornwood Inc Permit 04888/R17 766 Hailey's Ferry Road Issued 6/3/2022 Lilesville,NC 28091 Expires 5/31/2030 Lat: 34d 57.2115m Long: 79d 57.6182m Class/Status Small 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 President Plant Engineer (704)848-4121 (704)848-4121 (704)848-4121 Compliance Data Comments: or i Inspection Date 11/08/2022 Inspector's Name Mike Turner Inspector's Signature: dr,~ Operating Status Operating Compliance Status Compliance-inspection G �" Action Code FCE Date of Signature: /� I 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 hest HAP Emitted in pounds) Five Year Violation History: Date Letter Type Rule Violated Violation Resolution Date 10/01/2020 NOV Part 60-NSPS Subpart Dc Small Industrial- 10/05/2020 Commercial-Institutional Steam Generating Units 10/01/2020 NOV 2D .0524 New Source Performance Standards 10/05/2020 04/26/2019 NOV/NRE 2D .0521 Control of Visible Emissions 05/13/2019 04/26/2019 NOV/NRE 2D .0611 Mon itorin Emissions from Other Sources 05/13/2019 Performed Stack Tests since last FCE:None Date Test Results Test Method(s) Source(s)Tested I. DIRECTIONS From FRO,head south on Green St toward Maiden Ln.At the traffic circle,take the 2nd exit onto Gillespie St. Turn right onto W Russell St. Turn left onto Robeson St. Use the left 2 lanes to turn left onto Raeford Rd and continue for 10 miles. Just past Wagram,turn right onto Old Wire Road(NC Hwy 144).Turn right onto Old Wire Road (Hwy 144)and go— 11 '/z miles to Laurel Hill. Turn right onto US 74 West and continue for—25 miles until you enter Anson County,just after crossing the Pee Dee River. Go—5 more miles to Hailey's Ferry Road(crossroads SR 1801),continue approximately 0.5 mile and Homwood is on the right. Check in at the guardhouse. II. SAFETY Standard FRO safety gear.Inspectors should be wary of hot surfaces. III. FACILITY/PROCESS 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 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 Tenter 1,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. 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#3 and#4. CD-4(which is currently still under construction)will control emissions from Tenter 1. In electrostatic precipitator(ID No. CD-3), which controls Tenter 3 and Tenter 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. IV. PERMITTED EMISSION SOURCES Control Control Emission Source ID Emission Source Description System System ID Description Boiler Operations,including: s Natural gas/Ultra-low Sulfur No.2 fuel oil-fired boiler Main-031 (44.398 mmBtu/hr maximum heat input) N/A (NSPS Dc) } Operating w/0%opacity Textile Operations, including: __—-------- Textile __ _.Textile tenter frame(1,500 lbs of cloth per hour maximum Electrostatic capacity)consisting of the following: Precipitator Tenter 1 a) pad-applied finishing station,and CD-4 (2,367 sq.ft. b) therminol(hot oil)heated oven. collection surface Operating with 00//0 opacity area) Textile tenter frame(2,300 lbs of cloth per hour maximum 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) Operating with 0°�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 b) therminol(hot oil)heated oven. Electrostatic Operating with 00/10 opacity, Precipitator Textile tenter frame(2,100 lbs of cloth per hour maximum CD-3 (2,367 sq.ft. capacity)consisting of the following: collection surface a) pad-applied finishing station,and area) Tenter 4 b) natural gas fired six zone oven (6 million Btu per hour maximum heat input) Not operating Natural gas/Ultra-low Sulfur No. 2 fuel oil-fired therminol heater TH-01 (9.06 mmBtu/hr maximum heat input) N/A Not operating Natural gas/Ultra-low Sulfur No.2 fuel oil-fired boiler B-03 (22.65 mmBtu/hr maximum heat input) N/A Not operating 3 INSIGNIFICANT/EXEMPT SOURCES Source Exemption Regulation Source of TAPS? Source of Title V Pollutants? I ES 11 2Q .0102(h)(5) Yes Yes Surface Finishing Operation I-Main-058 = � Natural gas-fired therminol heater (15 mmBtu/hr maximum heat input) 2Q.0102(h)(1)(13) Yes Yes (NSPS Subpart Dc) �I Not operating E The facility switches between Main-031 and Main-058 every two weeks. V. INSPECTION SUMMARY On 8 November 2022, I, Mike Turner,with the Fayetteville Regional Office of DAQ, and Jeff Cole, also with FRO DAQ, conducted a compliance inspection of the Hornwood, Inc. facility. We met with Jay Stewart,the Electrician for the facility. The three of us also spoke to the facility's Technical Contact and Plant Engineer,Mr. Dale Kelley, over a speaker phone. We discussed the following: a) Mr. Stewart verified the FACFINDER information: no changes were needed. b) The facility employs about 360 people and operates 24 hours per day, 6 days per week, 52 weeks per year. c) Throughputs: Year Fabric produced(lb) 2022 (YTD) 4,1 12,000 2021 4,918,000 2020 6,457,521 2019 7,345,321 2018 4,365,985 2017 7,636,000 2016 8 119 816 2015 7,908,000 Mr. Stewart led us on a tour of the facility starting at the control panel for the Condenser/Mist Eliminator. The control panel displayed the following parameters: FME Inlet Temperature(° F) 192 FME Outlet Temperature(° F) 106 Pre-Filter Differential Pressure (Inches of HZO) -1.64 Overall (i.e.,Post-Filter)Differential Pressure(Inches of H20) -1.50 VI. STIPULATION REVIEW 1. 15A NCAC 2D .0202 PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT —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 current permit was renewed on 3 June 2022. The facility's permit expires on 31 May 2030, and the renewal application and EI are due to be submitted no later than 2 March 2030 for the 2028 calendar year. 2. 15A NCAC 2D .0503 PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS—Particulate emissions from the facility's boilers, ID No. Main-031, ID No. TH-01, and B-03, shall not exceed 0.39 lb/mmBtu. APPEARED IN COMPLIANCE— The facility is permitted to combust both natural gas and No. 2 Fuel oil in Main-031, TH-01, and B-03. The facility most recently burned fuel oil in Main-031 during testing on 7 November 2022. This test ran for 19 minutes and was conducted to check the air/fuel ratio on oil. Mr. Stewart stated they checked the fuel level before and after this test and there was no change. He does not know for sure much fuel oil was combusted, but it was negligible. 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.INDUSTRIAL PROCESSES—PM emissions shall not exceed emission rates as calculated by the following: E=4.10 * (P)'-" for P<=30 tons/hr, or E=55 * (P)'-"- 40 for P>3 0 tons/hr APPEARED IN COMPLIANCE—Compliance was determined during the most recent permit review based on operating the source as described in the permit conditions. No changes have been made to operations since that determination. 4. 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 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—Visible emissions from each emission source manufactured after 1 July 1971, shall not exceed 20% opacity when averaged over a six-minute period. APPEARED IN COMPLIANCE— We observed 0%emissions from all sources during this inspection. We observed no indications of previous issues with visible emissions during our inspection. 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 COMPLIANCE— The facility maintains records of fuel use. The fuel certifications show that the facility only combusts ULSD. The facility received an NOV on I November 2020 for failing to conduct Method 9 testing after switching fuels. The most recent Method 9 was conducted on 14 January 2021. The highest 6-minute average for that test was 0%. The most recent semiannual report was received on 18 July 2022 and was compliant. The facility most recently burned fuel oil in Main-031 during testing on 7 November 2022. This test ran for 19 minutes and was conducted to check the air/fuel ratio on oil. Mr. Stewart stated they checked the fuel level before and after this test and there was no change. He does not know for sure much fuel oil was combusted, but it was negligible. On 23 November 2022, I notified Mr. Stewart that a VE test would need to be performed within 45 days of 7 November 2022. Mr. Stewart replied that 17 February 2023 is the first date their vendor is available to do a Method 9 test. On 23 November 2023, FRO Acting Compliance Coordinator, Stephen Allen, contacted Eastern Technical Associates to inquire if they would be available to conduct a Method 9 test at Hornwood before the 45-day j deadline. An ETA representative stated they might be able to get someone out there before 22 December 2022. He also stated he has a list of testing vendors who are certified with their program and would be willing to share it with Mr. Kelly. On 30 November 2022, I emailed Mr. Kelly to inquire if he had secured testing yet. On I December 2022 he replied he has a vendor that can conduct the Method 9 on 19 or 20 December 2022. 7. 15A NCAC 2D .0535 NOTIFICATION REQUIREMENT—Notify DAQ in the event of excess emissions lasting longer than 4 hours. APPEARED IN COMPLIANCE—Mr. Stewart stated the facility has had no excess emissions, breakdowns, or abnormal conditions that would require 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 observed during the inspection. All roads are paved, and there have not been any complaints received by DAQ. Mr. Stewart stated that there had been no dust complaints in the past year. 9. 15A NCAC 2D .0605 RECORDS MAINTENANCE REQUIREMENT—the Permittee shall maintain fuel certification records and confine that the ultra-low sulfur No. 2 fuel oil combusted meets the specification for ASTM D975 Grade No. 2-D S15 fuel oil (maximum 15 ppm [0.0015%] sulfur content,by weight). APPEARED IN COMPLIANCE—The facility maintains records of fuel use. These records show the facility most recently burned fuel oil in Main-031 during testing on 7 November 2022. This test ran for 19 minutes and was conducted to check the air/fuel ratio on oil. Mr. Stewart stated they checked the fuel level before and after this test and there was no change. He does not know for sure much fuel oil was combusted, but it was negligible. The fuel certifications provided with the facility's annual report show the facility only combusts ULSD that meets the specifications ofASTMD975. 10. 15A NCAC 2D .0611 CONDENSER/MIST ELIMINATOR REQUIREMENTS—Annual internal and structural integrity inspections of 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 IN VIOLATION—Internal and structural integrity inspections that meet the criteria for annual internal inspections are performed twice a year, with the most recent being conducted on 31 August 2022. The facility also performs weekly I&M on CD-2. Mr. Stewart stated the pre-filters are changed every week. The facility showed us their log sheets that record inlet temperature, AP, and outlet temperature every two hours while the facility is operating. We reviewed these records from 3 October 2022 to 2 November 2022. The logbook showed there showed there were seven separate entries on 24 October 2022 where the pressure drop across CD-2 was over 8 inches of water. There were also six separate entries on I November 2022 where the pressure drop ranged from 8.02 inches of water to 8.9 inches of water. The records over these time periods did not note that any corrective actions were taken by the facility personnel, including implementing wash procedures to clean the filters inside CD-2. 11. 15A NCAC 2D .0611 ELECTROSTATIC PRECIPITATOR REQUIREMENTS—Shall perform I&M as recommended by the manufacturer,maintain records of I&M,with dates and actions in a logbook, inspections should include checking the power pack, visual inspection for contaminate buildup,visual inspection of the ionizer section contact spring,wires, ground plates and cell plates for contamination, an annual inspection must be completed for each 12-month period. APPEARED IN COMPLIANCE—The electrostatic precipitator(CD-3) is visually inspected weekly. Inspections that meet the criteria for annual inspections are conducted semi-annually, with the most recent conducted on 8 October 2022. The facility maintains detailed records for inspections and maintenance and records were readily available. A second electrostatic precipitator(CD-4), which controls the recently installed tenter 1, started operating three weeks prior to this inspection. There are no I&Mrecords yet for CD-1. 12. 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 objectionable odors were noted during our inspection. Mr. Stewart stated that there had been no odor complaints in the past year, and FRO has not received any odor complaints for this facility. 13. 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, records of fuel usage. 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. The fuel usage records are kept in Mr. Kelly's office and appeared to be up to date. 14. 15A NCAC 2Q .0317 AVOIDANCE CONDITION FOR AREA SOURCES SUBJECT TO 40 CFR 63 Subpart JJJJJJ(6J)—In accordance with 15A NCAC 2Q .0317,the Permittee is avoiding applicability of 40 CFR 63 Subpart JJJJJJ(6J) "Industrial, Commercial, and Institutional Boilers Area Sources."the Permittee is allowed to fire liquid fuel only during periods of gas curtailment, gas supply interruptions, startups, or for periodic testing on liquid fuel (periodic testing not to exceed a combined total of 48 hours during any calendar year)., shall maintain records for when liquid fuel is burned, fuel certifications,must provide notice within 30 days of switching fuels if not for the reasons stated above, and must demonstrate compliance within 180 days of the effective date of the fuel switch. APPEARED IN COMPLIANCE—The facility normally combusts natural gas in the main boiler (ID No. Main-031). Semi-annual reports received on 15 July 2021 and 7 January 2022 state the facility combusted 27 gallons of No. 2 fuel in 2021. A semi-annual report received in FRO on 18 July 2022 state the facility had combusted 0 gallons of No. 2 fuel oil in the first six months of 2022. Records emailed to me by Mr. Kelly on 8 November 2022 show the facility most recently burned fuel oil in Main-031 during testing on 7 November 2022. This test ran for 19 minutes and was conducted to check the air/fuel ratio on oil. The facility's fuel use in Main-031 has only occurred under allowable conditions as set forth in this stipulation. Mr. Kelley stated the facility was not curtailed at all in 2021 and has yet to be curtailed in 2022. 15. 15A NCAC 2Q .0711 EMISSION RATES REQUIRING A PERMIT—The Permittee has made a demonstration that facility-wide actual emissions,where one or more emission release points are obstructed or non-vertically oriented, do not exceed the Toxic Permit Emission Rates(TPERs) listed in 15A NCAC 2Q .0711(a). The facility shall be operated and maintained in such a manner that emissions of any listed TAPS from the facility, including fugitive emissions,will not exceed TPERs listed in 15A NCAC 2Q .07115/20181(a). In accordance with the approved application,the Permittee shall maintain records of operational information demonstrating that the TAP emissions do not exceed the TPERs as listed below: 1-7 Acetic acid(64-19-7) 0.96 Formaldehyde(50-00-0) � � 0.04 APPEARED IN COMPLIANCE—Compliance was determined during the most recent permit review based on operating the source as described in the permit conditions. There have been no changes in chemicals or chemical formulation since that determination. VII. NON-COMPLIANCE HISTORY SINCE 2010 Date of Non- Non-Compliance Description Compliance Issue 10/1/2020 NOV for failing to conduct Method 9 testing within 45 days of switching fuels. 7/29/2020 NOD issued for installing an Unpermitted Air Pollution Control Device. 04/26/2019 NOV/NRE for violations of 2Q .0521 and 2Q .0611. 4/28/2017 CAI issued for expressing concern with V.E. from Mist Eliminators 5/16/2016 NOD issued for failure to perform M9 when burning No. 2 fuel oil,per NSPS Dc requirements. 6/2/2015 CAI to request records unavailable during the 5/26/15 inspection. VIII. 112r APPLICABILITY The facility does not store any of the listed chemicals above the threshold quantities and is not required to maintain a written Risk Management Plan(RMP). IX. CONCLUSION AND RECOMMENDATIONS At the time of inspection on 8 November 2022,Hornwood Inc appeared to be operating IN VIOLATION of permit stipulation 15A NCAC 2D .0611 Condenser/Mist Eliminator Requirement. I recommend a Notice of Violation letter be sent to Hornwood,Inc. for failure to implement wash procedures when the pressure drop across the mist eliminator exceeds 8 inches of water. PINK SHEET NOTE None. /wmt