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