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HomeMy WebLinkAboutAQ_F_0400009_20210803_CMPL_InspRpt NORTH CAROLINA DIVISION OF Fayetteville Regional Office AIR QUALITY Hornwood Inc NC Facility ID 0400009 Inspection Report County/FIPS:Anson/007 Date: 08/13/2021 Facility Data Permit Data Hornwood Inc Permit 04888/R15 766 Hailey's Ferry Road Issued 11/12/2020 Lilesville,NC 28091 Expires 4/30/2022 Lat: 34d 57.2115m Long: 79d 57.6182m Class/Status Synthetic Minor SIC: 2258/Warp Knit Fabric Mills Permit Status Active NAICS: 313312/Textile and Fabric Finishing(except Broadwoven Fabric)Mills Current Permit Application(s)Modification F_ Contact Data - Program Applicability Facility Contact Authorized Contact Technical Contact SIP Benny Burr Charles Horne Dale Kelly NSPS: Subpart Dc Environmental Manager Owner Plant Engineer (704)848-4121 (704)848-4121 (704)848-4121 Compliance Data Comments: Inspection Date 08/03/2021 Inspector's Name Mike Thomas Inspector's Signature: Operating Status Operating Compliance Status Compliance-inspection Action Code FCE Date of Signatu : Inspection Result Compliance /,, r z 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 *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: Date Test Results Test Method(s) Source(s)Tested 01/14/2021 Compliance Method 9 B-03 I. DIRECTIONS TO 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).Tum 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. II. SAFETY: Standard FRO safety gear. Inspectors should be wary of hot surfaces. III. FACILITY DESCRIPTION: Hornwood,Inc. is a textile company that warps,weaves, dyes yarn,heat- sets(tenter frame finishes)and doffs(textures)nylon and polyester knit fabrics. They produce baseball uniforms, automobile seat fabric, cloth for reverse osmosis water purification,gauze liners for tennis shoes,and cowboy shirts to name a few. This process may be divided into several distinct operations as follows: Warping: Yarn is spun onto a single spool for processing in the knitting room. Yarn may also.be draw warped which draws the diameter of the 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 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),the air then passes over four(4)cold water coils and six(6) spray rings that both condense the vapor prior to the mist eliminator. In Condenser/Mist Eliminator(ID No. CD-1),the air passes over six(6)spray rings that help condense the vapor prior to the mist eliminator. There are no cooling coils in CD-1. 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. IV. PERMITTED EMISSION SOURCES: IBM, W i1W0pertior s,including: Main-031 Natural gas/No.2 fuel oil-fired boiler (44.398 mmBtu/hr maximum heat input) N/A N/A (NSPS) Operating on NG with 0%V.E. Text le oral'. includ pg� Textile tenter frame(1,500 lbs of cloth per hour maximum capacity)consisting of the following: Tenter 1 a)pad-applied finishing station,and b)therminol(hot oil)heated oven. Operating with 0%V.E. CD-2 Textile tenter frame(2,000 lbs of cloth per hour Condenser/Mist Eliminator maximum capacity)consisting of the following: Tenter 2 a)pad-applied finishing station,and b)natural gas-fired four zone heated oven (7.2 million Btu per hour maximum heat input) Operating with 0%V.E. 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 Operating with 0%V.E. CD-3 Textile tenter frame(2,100 lbs of cloth per hour Electrostatic Precipitator maximum capacity)consisting of the following: (2,367 sq.ft.collection surface area) Tenter 4 a)pad-applied finishing station,and b)natural gas-fired six zone heated oven (6 million Btu per hour maximum heat input) Operating with 0%V.E. Natural gas/No.2 fuel oil-fired therminol heater TH-01 (9.06 mmBtu/hr maximum heat input) Operating with 0%V.E. - N/A Natural gas/No.2 fuel oil-fired boiler B-03 .(22.65 mmBtu/hr maximum heat input) Not operating INSIGNIFICANT ACTIVITIES: I-ES 11 Surface Finishing Operation 2Q.0102(c)(2)(E)(i) Yes Yes. Not Observed I-Main-058 Natural gas-fired therminol heater . (15 mmBtu/hr maximum heat input) 2Q.0102(c)(2)(B)(ii) Yes Yes (NSPS Subpart De) Operating on NG 0% VE I-01 Natural gas/No.2 fuel oil-fired therminol heater 2Q.0102(c)(2)(B)(i)(II) Yes Yes (9.06 mmBtu/hr maximum heat input) Not o eratin I-03 Natural gas/No.2 fuel oil-fired boiler (22.65 mmBtu/hr maximum heat input) 2Q.0102(c)(2)(B)(i)(II) Yes Yes Operating on NG at low fire status 0% VE The facility employs about 360 people and operates 24 hours per day, 6 days per week, 52 weeks per year. Throughputs: 2020 6,457,521 2019 7,345,321 2018 45365,985 2017 7,636,000 2016 8,119,816 2015 7,908,000 2014 7,937,000 2013 10,312,041 VI. INSPECTION SUMMARY: On 3 August 2021,I Mike Thomas of FRO DAQ, conducted a compliance inspection of Hornwood,Inc. The facility was operating at the time of the inspection. Upon approaching the facility from the front parking area I did not detect any visible emissions from the two Condenser/Mist Eliminator.I met with Mr.Dale Kelly,Plant Engineer, at the front lobby of the facility. I asked Mr. Kelly to verify the contact information from the FacFinder.Mr. Kelly stated that there were no changes necessary.Mr.Kelly led me on a tour of the facility. The logs kept for maintenance of the Condenser/Mist Eliminators were well kept and up to date.Mr.Kelly escorted me to the Condenser/Mist Eliminators outdoors where I observed 0% opacity for CD-2 and 0%opacity for CD-1. Upon reentering the facility,we went to the control panel, on the inside wall near the Condenser/Mist Eliminators,which graphically displays parameters for both units. These parameters were as follows: Condenser/Mist Eliminator(ES ID No. CD-1) FME Inlet Temperature(°F) 232 FME Outlet Temperature(°F) 100 Pre-Filter Differential Pressure(Inches of H2O) -0.22 Overall(i.e.,Post-Filter)Differential Pressure(Inches of H2O) 6.9 - 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 H2O) 1 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 oil.Mr.Kelly also stated that the annual tune up occurred on 15 September 2020 and that fuel oil was fired then as well.I asked if a Method 9 test was conducted either during curtailment or during the tune up.Mr.Kelly explained to me that they had trouble coordinating with the person that usually performs the V.E.testing and as a result Method 9 test was not performed during curtailment or during the tune-up. We 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-058) 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. VII. APPLICABLE AIR QUALITY REGULATIONS: 1. 15A NCAC 2D .0202—PERMIT RENEWAL AND EMISSION INVENTORY REQIREMENT —The Permittee shall submit an application for permit renewal, including an emission inventory for CY 2020,no later than 90-days prior to permit expiration. APPEARED IN COMPLIANCE: The facility's current permit was renewed on time. The facility's permit expires on 30 April 2022, and the renewal application and EI are due to be submitted no later than 31 January 2022 for calendar year 2020. 2. 15A NCAC 2D .0503—PARTICULATES FROM FUEL BURNING INDIRECT HEAT EXCHANGERS—Particulate emissions from the facility's boiler(ID No.Main-031)shall not exceed 0.39 lb/mmBtu. APPEARED IN COMPLLANCE: 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/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<=3 0 tons/hr, or E= 55 * (P)0.11-40 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 S02 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 I observed 0% emissions from all sources during this 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 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. 7. 15A NCAC 2D .0535—NOTIFICATION REQUIREMENT—Notify DAQ in the event of excess emissions lasting longer than 4 hours. APPEARED IN COMPLIANCE: Mr. Kelly stated that the facility has had no excess emissions, breakdowns, or abnormal conditions requiring notification before the inspection. 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 noted during the inspection. All roads are paved, and there have not been any complaints received by DAQ. Mr. Kelly stated that there had been no dust complaints in the past year. 9. 15A NCAC 2D .0611—CONDENSER[MIST ELIMINATOR REQUIREMENTS—Annual internal and structural integrity inspections of CD-1 and CD-2. Change pre-filter weekly. Monitor pressure drop daily and implement wash procedures when mist eliminator AP reaches 7.5-8.0"H20, or when water coil AP reaches 3.0"H2O-Weigh oil and particulate collected in the mist eliminator weekly. APPEARED IN COMPLIANCE: The facility monitors pressure drop across the mist eliminators during each shift, and records the values in a logbook. All values in the logbook were below the level, which would require a wash procedure. The mist eliminators are also inspected semiannually with the most recent internal inspections occurring on 6 April 2021 for CD-1 and 1 March 2021 for CD-2. The facility performs weekly maintenance on both mist eliminators. The last weekly inspection on CD-01 was on 28 July 2021 and the last weekly inspection on CD-02 was on 26 July 2021. 10. 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 and a more in depth inspections semiannually. The last weekly inspection was on 28.Iuly2021. The last semiannual inspection was conducted on 8 July 2021. The facility maintains detailed records for inspections and maintenance. 11. 15A NCAC 2D .0958—WORK PRACTICES FOR SOURCES OF VOCs—Permittee shall adhere to work practices as delineated in the permit. APPEARED IN COMPLIANCE: During this inspection, lids were on tight and all cleaning rags were properly stored. This stipulation will be removed from the permit at next permit opening since it applies only in non-attainment areas and Anson County is in attainment. 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 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 2Q .0102—FEDERAL AND STATE RULES APPLICABLE TO EXEMPTED 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 COMPLL4NCE: 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&Mrecords of the boiler 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. 14. 15A NCAC 2Q .0315—SYNTHETIC MINOR FACILITIES—Operate within the following limits to maintain S02 emissions less than 100 tons annually: 1)Amount of No.2 fuel oil combusted <2,800,000 gallons per consecutive 12-month period; 2) sulfur content of No. 2 fuel less than 0.5%. Annual reporting. APPEARED IN COMPLL4NCE: Records indicate the facility combusted 27 gallons No. 2 fuel oil during the first quarter of 2021. Fuel usage is tracked by taking monthly measurements of the fuel storage tank levels. Fuel certifications were available, and show that the facility only receives ULSD. The annual report was received on time on 11 January 2 02 1, and indicated compliance. 14. 15A NCAC 2Q .0317—AVOIDANCE CONDITION FOR AREA SOURCES SUBJECT TO 40 CFR 63 Subpart JJJJJJ(0) -In accordance with 15A NCAC 2Q .0317,the Permittee is avoiding applicability of 40 CFR 63 Subpart JJJJJJ(0) "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 COMPLL4NCE: 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. 15. 15A NCAC 2Q .0711—EMISSION RATES REQUIRING A PERMIT—Pursuant to 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit," for each of the below listed toxic air pollutants (TAPs),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). a.A permit to emit any of the below listed TAPs shall be required for this facility if actual emissions from all sources will become greater than the corresponding TPERs. b.PRIOR to exceeding any of these listed TPERs,the Permittee shall be responsible for obtaining a permit to emit TAPs and for demonstrating compliance with the requirements of 15A NCAC 2D .l 100 "Control of Toxic Air Pollutants". c.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 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. VIII. NON-COMPLIANCE HISTORY SINCE 2010: Date of Non-Compliance Issue Non-Compliance Description 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. IX. RISK MANAGEMENT (112r): 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(RMP). X. CONCLUSION AND RECOMMENDATIONS: On 2 August 2021,Hornwood,Inc. appeared to be operating IN COMPLIANCE with the conditions of their current air permit. PINK SHEET ADDITIONS: • None /mst