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HomeMy WebLinkAboutAQ_F_0400009_20211117_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Hornwood Inc NC Facility ID 0400009 Inspection Report County/FIPS:Anson/007 Date: 11/19/2021 Facility Data Permit Data Hornwood Inc Permit 04888/R16 766 Hailey's Ferry Road Issued 9/7/2021 Lilesville,NC 28091 Expires 4/30/2022 Lat: 34d 57.2115m Long: 79d 57:6182m Class/Status Small SIC: 2258/warp Knit Fabric Mills Permit Status Active NAILS: 313312/Textile and Fabric Finishing(except Broadwoven Fabric)Mills Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact S 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: Inspection Date 11/17/2021 Inspector's Name Mike Thomas Inspe tor's Si attire° Operating Status Operating Compliance Status Compliance-inspection at o Xignature: Action Code FCE el I Z_1f-Z/ Inspection Result C0111 liance Total Actual emissions in TONS/YEAR: TSP Sot Nox voc coPM10 P 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: 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 Monitoring Emissions from Other Sources 05/13/2019 Performed Stack.Tests since last FCE: None 1. CT SITE,: 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 1/2 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 Hornwood is on the right. Check in at the guardhouse. SAFETY: Standard FIFO safety gear. Inspectors should be wary of hot surfaces. 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. DyeHouse: 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 li inators: The facility was histrically 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. 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. PERMITTED EMISSION SOURCES: . r r i � 3 f,,: yam• .-: ,.,,,-,. ,. ,.,.:. :: t-.. >. Main-031 Natural as/Ultra-low Sulfur No.2 fuel oil-fired boiler g N/A SS (44.398 mmBtu/hr maximum heat input) Natural gas/Ultra-law Sulfur No.2 fuel oil-fired boiler B-03 2.65 mmtu/h i heat input) r maxmum eaN/A (.2 B .. Natural gas/Ultra-low Sulfur No.2 fuel oil-fired TK-01 therminol heater N/A (9.06 mmBtu/hr maximum heat input) 7777-77 77777 :1 Textile tenter frame (1,500 lbs of cloth per hour maximum capacity) Electrostatic Precipitator Tenter 1 consisting of the following: CD-4 (2,367 sq.ft.collection surface a)pad-applied finishing station,and area) b)therminol(hot oil)heated oven. Textile tenter frame it (2,000 lbs of cloth per hour maximum capacity) Tenter 2 consisting of the following: CD-2 Condenser/Mist Eliminator a)pad-applied finishing station,and b)natural gas-fired four zone heated oven s (7.2 million Btu per hour maximum heat input) g _ : 4 'T 5 4:?� � a _ S v ' _v ,r pe A , „Y• ,,.'..:. .,' +, .. .:w s, * x: .:..- :, _ +,,.$.P `d'#.��,'Y��C mR�`: .Lufx'. 's..'v,S� - n5'. vi,.. �'t a v Textile tenter frame 2 000 lbs of cloth per hour maximum capacity) ( , Tenter 3 consisting of the following: a)pad-applied finishing station,and x b)therminol(hot oil)heated oven Electrostatic Precipitator Textile tenter frame CD 3 (2,367 sq.ft.collection surface area) (2,100 lbs of cloth per hour maximum capacity) Tenter 4 consisting of the following: _ a)pad-applied finishing station,and b)natural gas-fired six zone heated oven (6 million Btu per hour maximum heat input) INSIGNIFICANVEXEMPT SOURCES a :• , sM ,...,•.�?v �,s... t::.'r*�t:�,`, r--x' "> �.k z�).�,y�r::�' �� ,A....S�r.. sue'.x'�;'�.r ���'' �' � Fxx✓; .�. .. h. v v. t� u e! G sue. fl ti•s�� iu emu= �•� 3 } r. F r : - t 119 � ra r m: .�$ �.,.. _ c,- 7.. ..,, ,:,..�.vr ,. �..:.. �„..., .. '�' •a, �''�?� �,,. ��.z.��;xs::�,�3 �£z�aS.�s'"4�-.s :,.-.. ,:-; ..p=rs?r.. �va�,u... -�`",. ...,?, ..e�: e.. �•,. �zo:>a >:,4�.v.�.x��r.�z�',.c�.�4..:v„a£,�:. 4, .J „v,.,:a:'�»+'z'��'�,�'��'`,v'..k� ..�zF.,.t',..�hi?ox`._;k���.x,�� .z�'�,a�3' „;v�,�`2.a.:lrt7���;,u:.,.�,�n.,,.: � „•�,.w„„,,.,,,„v,,..,,.�...w.. ,.e..«»»,.,.:,.w.,�w� .,... } I-E S 11 Yes Surface Finishing Operation 2Q .0102(h)(5) Yes i z -...,.. ....,... ....,. .....-�.aa,.>�.,,...;....,a.,..:• .w.,,,.:...�..,.�.�w,vn,.,...,., .,,....,..:„n,.�......,,,,.,,.,.'»..,w..:,.,..v.....w..:,.-,..w...:,.v....•,..,.....w....w,u.,..,..,..:,...,...,,.�..,.,.,:..,....:,�.�..,..�::: .. a z z I-Main-058 0102.2 h 1 B Yes Yes Natural as-fired therminol heater Q O( )O r s (15 mmBtu/hr maximum heat input) (NSPS Subpart Dc h The facility employs about 360 people and operates 24 hours per day, 6 days per week, 52 weeks per year. Throughputs: mgg N .M-- -._0 2020 6,457,521 2019 7,345,321 2018 4,365,985 2017 7,d3600 2016 8,11%816 2015 759085000 2014 75937,000 2013 10,312,041 VI, INSPECTION SUMMARY: On 17 November 2021,I,Mike Thomas with FRO DAQ,conducted a compliance inspection of the Hornwood,Inc.facility. I met with Dale Kelly,Plant Engineer. This was a prearranged inspection to assist with the facility's upcoming permit renewal and emissions inventory. we discussed the following: a) Mr. Kelly verified the FACFINDER information: no changes were needed. b) I went over the user ID and password information for the AERO system with Mr.Kelly and made certain that he was able to lag in successfully. Mr. Kelly showed me the data he had collected for his emissions inventory and stated that he felt like he knew what needed to do to complete their inventory. INSPECTION Mr.Kelly led me on a tour of the facility starting at the control panel for the Condenser/Mist Eliminators, which graphically displays parameters for both units. These parameters were as follows: -Condenser/1V4ist Eliminator(ES ID No. CD-1)Last operated on 3 March 2021. -Condenser/Mist Eliminator(ES ID No. CD-2) FME Inlet Temperature(°F) 215 FME outlet Temperature(°F) 105 Pre-Filter Differential Pressure(Inches of H2O) 0.35 Overall(i.e.,Post-Filter)Differential Pressure(Inches of Hzo) 7 Mr.Kelly provided all the production records and the natural gas usage records both monthly and annually for 2020. 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. Mr. Kelly explained that the facility had been curtailed 7 August 2019 and used fuel oil for only a few hours. On 8 August 2019,the facility resumed burning natural gas. The facility burned approximately 43 8 gallons of fuel.ail.Mr.Kelly also stated that the annual tune up occurred on 13 September 2021 and that fuel oil was fired then as well. U. e then proceeded to the boiler room where I observed the Natural gas/No. 2 fuel oil-fired boiler(ID No. Main-031),the Natural gas-fired therminol heater(ID No.I-Main-05 8)and the Natural gas/No. 2 fuel oil- fired boiler(ID No. I-03)both operating on NG at 0%opacity. The Natural gas/No. 2 fuel oil-fired therminol heater(ID No. I-01)was not operating. VIII. APPLICABLE AIR QUALITY REGULATIONS: . 15A NCAC 2D .0202—PERMIT RENEWAL AND EMISSION 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 L NCE: The facility's current permit was renewed on time. The facility's permit expires on 30 April 2022, and the renewal application and El are due to be submitted no later than 31 January 2 022 for calendar year 2 02 0. 2. '15A NCAC 2 . 5 —PARTICULATES EXCHANGERS—Particulate emissions from the facility's boiler(ID No. Main-031) shall not exceed 0.39 lb/mmBtu. APPEA .N CO1 L NCE: 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/mBtu respectively. 3. 1A 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<—3 0 tons/hr, or E— 55 * (P)'-11-40 for P>3 0 tons/hr APPEAR-APPEAR-ED IN C P NCE: 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. . 15A NCAC 2 . 1 SULFUR DIOXIDE EMISSIONSCOMBUSTION SOURCES— Sot emissions from the facility's combustion sources shall not exceed 2.3 lb/mmBtu. APPEARED IN CO L CE: The facility combusts primarily natural gas, but may combust No. 2 uel oil if necessary. The facility only accepts ultra-low sulfur diesel(ULSD), as verified by fuel f certifications. AP-42 S02 emission4 factors for natural gas and ULSD are 0.0006 lb/mmBtu, and 0.002 lb/mmBtu respectively, 5. 15A NCAC 2 . 52 —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 COMPLL4NCE I observed 0%emissions from all sources during this inspection. . 15A NCAC 2D .0524NEW SOURCE PERFORMANCE S (Subpart Dc) The facility's boiler(Main-03 1)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 C NCE: The facility maintains records of fuel uel 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 current interval for.Method 9 testing is one year based on the results of the last test. 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 16 July 2021 and was compliant. Mr. Kelly stated that he had already made arrangements to conduct a Method 9 the first week of January 2022. 7. 15A NCAC 2 .0535—NOTIFICATION —Notify DAQ in the event of excess emissions lasting longer than 4 hours. APPEARED IN CO PL NCE: Mr. Kelly stated that the facility has had no excess emissions, breakdowns, or abnormal conditions requiring notification before the inspection. . 15A NCAC 2D.0540—PARTICULATES FROM FUGITIVE DUST EMISSIONSOURCES— Fugitive dust emissions shall not cause/contribute to substantive complaints or excessive VE across property boundaries. APPEARED IN C P NC`E: No fugitive dust concerns were noted during the inspection.All roads are paved, and there have not been any complaints received by DAB}. Mr. Kelly stated that there had been no dust complaints in the past year. . 15A NCAC 2D .0605-RECORDS MAINTENANCEREQUIREMENT-the Permittee shall maintain fuel certification records and confnn that the ultra-low sulfur No.2 fuel oil combusted meets the specification.for ASTM D975 Orade No.2-D S 15 fuel oil (maximum 15 ppm [0.00 15%] sulfur content,by weight). APPEARED N C PL NCE. The facility maintains records of fuel uel use. The fuel certifications provided with the facility's annual report, show that the facility only combusts ULSD that meets the specifications of ASTMD975. . 15A NCAC 2 . 611—CONDENSER/MIST ELIMINATORCONDENSER/MIS N S—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"II2O.Weigh oil and particulate collected in the mist eliminator weekly. APPEARED IN CO PL NC.E: T P.Ehe facility monitors pressure drop across the mist eliminator during each shift, and records the values in a logbook. All values in the logbook were below the level, which would require awash procedure. The mist eliminator is also inspected semiannually with the most recent internal inspection occurring on I March 2021 for CD-2. The facility performs weekly maintenance on CD-2. The last weekly inspection on CD-02 was on 12 November 2021. 1. 15A NCAC2D .0611—ELECTROSTATIC PRECIPITATOR REQUIREMENTS—Shall perform I&M as recommended by the manufacturer,maintain records of I& ,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 N C L NCE: The electrostatic precipitator(CD-3) is visually inspected weekly and a more in depth inspections semiannually. The last weekly inspection was on 9 November 2021. The last semiannual inspection was conducted on 8 duly 2021. The facility maintains detailed records for inspections and maintenance. A second electrostatic precipitator(CD-4) has yet to be installed: CD-4 will control emissions from Tenter Frame I once it is installed. 12. 1A NCAC 2 .1 6—CONTROL S EMISSIONS- Permittee shall not cause or contribute to objectionable odors beyond the property boundary. APPEARED IN CO NCEe No objectionable odors were noted as I approached the,facility, nor were there any noticeable odors while inside. Mr. Kelly 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 . 12--FEDERAL AND STATE S APPLICABLE SOURCES—Insignificant boiler,I-Main-058, is subject to the requirements of NSPS Subpart Dc, record keeping for inspection and maintenance and records of fuel usage. APPEARED IN C L NCE: 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 and Mr. Kelly keeps all I&M records of the boilboiler I-Main-058 in his office and they appeared to be up to date. The fuel usage records are also kept in Mr. Kelly's office and appeared to be up to date. 1 . 15A NCAC 2 . 3 7—AVOIDANCE CONDITION FOR AREA SOURCES SUBJECT CFR 63 Subpart J (6 -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 N C I, NCE: The facility normally fires boiler(ID No. Main-031) with natural gas. Mr. Kelly stated that the facility had burned 27 gallons of No. 2 fuel oil during the first quarter of 2021 for testing. The facility combusted 19 gallons offuel oil dining testing conducted on 13 September 2021. 15. 15A NCAC 2Q .0711—EMISSION RATES REQUIR.ING 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 .0711(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: MIBK(methylisobutylketone)(108-10-1) 52 7.6 Toluene(108-88-3) 98 14.4 xylene(mixed isomers)(1330-20-7) 57 16.4 APPEARED IN CO L C.E: 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. } . NON-COMPLIANCE STORY SINCE 2 1 : Date of Non-Compliance Non-Compliance Description Issue l l/l/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, 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 Issued requesting records which were unavailable during the 5/26/15 inspection. X. S MANAGEMENT(1 1 ): 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(R1\4P). CONCLUSION AND REC A : On 16 November 2021,Ilornwood, Inc. appeared to be operating IN COMPLL4NCE with the conditions of their current air permit. PINK S S: No comments. /mst