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Governor r7i'
MICHAEL S. REGAN
,Secretary
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MICHAELA.ABRACZINSKAS NORTH CAROLINA
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Environmental Quality
1 October 2020
GKWT-IFIED-MAIL
RETURN RECEIPT REQUESTED
Mr. Charles Horne, President
Hornwood Inc.
766 Hailey's Ferry Road
Lilesville, NC 28091
SUBJECT: Notice of Violation:
15A NCAC 02D .0524 New Source Performance Standards
40 CFR 60 Subpart De Standards of Performance for Small Industrial-
Commercial-Institutional Steam Generating Units
Hornwood Inc; Air Permit No. 04888R14
Lilesville,North Carolina, Anson County 06/0400009
Fee Class: Synthetic Minor
Dear Mr. Horne:
On 2 September 2020, Jeff Nelson, with the Division of Air Quality (DAQ) in the
Fayetteville Regional Office (FRO), conducted an air quality compliance inspection of your
facility, Hornwood Inc. in Lilesville, Anson County,NC. During this inspection, Mr. Nelson
met with Mr. Dale Kelly, Plant Engineer. Your facility is permitted to operate a natural gas/No.
2 fuel oil-fired boiler(44.398 mmBtu/hr maximum heat input) (ID No. Main-031)that is subject
to 40 CFR 60 Subpart Dc "New Source Performance Standards for Small Industrial-
Commercial-Institutional Steam Generating Units." In your current air permit, Stipulation A.7.
15A NCAC 02D .0524 "New Source Performance Standards," requires a Method 9 Visible
Emissions (VE) test be performed periodically on boilers burning No. 2 fuel oil.
According to records provided, your facility last performed a Method 9 test, on boiler
Main-031, on 3 January 2018. The results of that test established a semi-annual frequency for
conducting future Method 9 tests when No. 2 fuel oil is burned in boiler Main-031. Therefore,
any fuel oil burned after 3 July 2018 (6 months after the initial test) would trigger a 45-day clock
to conduct a new Method 9 VE test. During the compliance inspection, Mr. Nelson reviewed
facility records and learned that the facility had been curtailed from natural gas and had burned
No. 2 fuel oil on 7 August 2019 and had also burned fuel oil on 16-17 September 2019 during
the annual boiler tune-up. The facility failed to conduct the required Method 9 VE test which
was due no later than 21 September 2019 (based on burning fuel oil on 7 August 2019). Failing
to conduct the required Method 9 VE test constitutes a violation of 15A NCAC 02D .0524
"New Source Performance Standards" and 40 CFR 60 Subpart De "Standards of
Performance for Small Industrial-Commercial-Institutional Steam Generating Units."
North Carolina Department of Environmental Quality I Division of Air Quality
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Fayetteville Regional Office 1 225 Green Street,Suite 7141 Fayetteville,North Carolina 28301
910.433.3300 T 1910.485,7467F

Mr. Charles Horne
1 October 2020
Page 2
Be advised that this is the second time you have failed to conduct the required Method 9
VE test on the subject boiler. On 16 May 2016, this office issued Hornwood Inc. a Notice of
Deficiency for failing to conduct the required Method 9 VE test after burning fuel oil in January
and February 2014. Be aware that continued violations of 15A NCAC 02D .0524,NSPS Subpart
Dc may result in the assessment of civil penalties.
As stated in the subject above, this letter represents a Notice of Violation for the cited
violation. This violation, and any future violation of an air quality regulation, is subject to the
assessme I civil North Carolina-General-Statute-4-43-2-1-57 A.
addition, each day of continuing violation after written notification from the Division of Air
Quality shall be considered a separate offense.
Please provide a written response to this letter as soon as possible, but not later than
15 October 2020. We are concerned with what appears to be a pattern of non-compliance with
respect to the required Method 9 VE testing on the subject boiler. In your response, indicate
what steps you are taking or have taken to return to compliance with the requirements of your air
permit, as well as your plan to ensure future compliance with the cited requirements.
We appreciate your prompt attention to this matter. The DAQ strongly recommends that
you carefully examine your current air permit. If you have any questions regarding your permit
or the cited violation, please contact Jeff Nelson, Environmental Specialist, or Greg Reeves,
Environmental Engineer, at [phone].
Sincerely,
a 0
Heather S. Carter
Regional Supervisor
Division of Air Quality, NC DEQ
HSC/jln
cc: FRO Facility Files
North Carolina Department of Environmental Quality I Division of Air Quality
_ Fayetteville Regional Office 1 225 Green St met,Suite 7141 Fayetteville,Not Carolina 2.8301
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