AQ_F_0400009_20200902_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Fayetteville Regional Office
AIR QUALITY Hornwood Inc
NC Facility ID 0400009
Inspection Report County/FIPS: Anson/007
Date: 09/10/2020
Facility Data Permit Data
Homwood Inc Permit 04888/R14
766 Hailey's Ferry Road Issued 1/23/2114
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)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
NSPS: Subpart Dc
Benny Burr Charles Horne Dale Kelly
Environmental Manager Owner Plant Engineer
[phone] [phone] [phone]
Compliance Data
Comments:
1��, Inspection Date 09/02/2020
r y Inspector's Name Jeffrey Nelson
Inspector's Signature: 2 _ Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: t o l b I 7-0 On-Site Inspection Result Violation
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PMIO * 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(in pounds)
Five Year Violation History:None
Date Letter Tyne Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

I. DIIRECTIONS TO SITE: From FRO,take Hwy 401 S to Wagram,then right on Wire Road past Laurel
Hill.Turn right(west)onto Hwy 74 and travel 27 miles. Turn left onto Hailey's Ferry Rd/ SR 1801 /Pit
Road;the facility is located—1/4 mile away, on the right. Check in at the guard house prior to entry.
H. SAFETY: Standard FRO safety gear. Inspectors should be wary of hot surfaces.
III. FACILITY DESCRIPTION: Homwood,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.

The facility employs about 360 people and operates 24 hours per day, 6 days per week, 52 weeks per
year.
Throughputs:
2019 7,345,321
2018 4,365,985
2017 7,636,000
2016 8,119,816
2015 7,908,000
2014 7,937,000
2013 1Q312,041
IV. INSPECTION SUND4ARY:
On 2 September 2020,I Jeff Nelson of FRO DAQ, conducted a compliance inspection of Hornwood, Inc.
in Lilesville,Anson County. 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
Eliminators and the rear of the facility. 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 only 5% 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 all of the unit's parameters. These parameters were as follows:
Condenser/Mist Eliminator(ES ID No. CD-1)
FME Inlet Temperature(° F) 215
FME Outlet Temperature(° F) 94
Pre-Filter Differential Pressure(Inches of H2O) 0.04
Overall(i.e.,Post-Filter)Differential Pressure (Inches of H2O) 6.9
Condenser/Mist Eliminator(ES ID No. CD-2)
FME Inlet Temperature(°F) 217
FME Outlet Temperature (° F) 118
Pre-Filter Differential Pressure (Inches of H2O) 0.33
Overall(i.e.,Post-Filter)Differential Pressure(Inches of H2O) 7

We then went to Mr. Kelly's old office where the facility keeps their maintenance records. Mr. Kelly was
able to produce all the production records and the natural gas usage records both monthly and annually
for 2019.Mr.Kelly was able to produce the facility's latest air quality permit.
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 789 gallons of fuel oil.Mr.Kelly also stated that the annual tune up
occurred on September 16-17 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.
V. PERMITTED ENIISSION SOURCES:
lame
11 C„s, C11
ratiol(s`y Shja ip '�. ^;.. <Iw
Main-031 Natural gas/No.2 fuel oil-fired boiler
(NSPS) (44.398 mmBtu/hr maximum heat input) N/A N/A
Operating on NG, 0% VE
�I�i," eratious"mdlyitl�n �: ' � s
Textile tenter frame(1,500 lbs of cloth per hour
maximum capacity)consisting of the following:
Tenter 1 a)pad-applied finishing station, and CD-2 Condenser/Mist
b)therminol(hot oil)heated oven. Eliminator
Operating at 0%o aci %
Textile tenter frame(2,000 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 four zone heated oven Eliminator
(7.2 million Btu per hour maximum heat input)
Operating at 0%o acid%
Textile tenter frame(2,000 lbs of cloth per hour
maximum capacity)consisting of the following:
Tenter 3 a)pad-applied finishing station,and CD-1 Condenser/Mist
b)therminol(hot oil)heated oven Eliminator
Operating at 5%opacity.
Textile tenter frame(2,100 lbs of cloth per hour
maximum capacity)consisting of the following:
Tenter 4 a)pad-applied finishing station, and CD 1 Condenser/Mist
b)natural gas-fired six zone heated oven Eliminator
(6 million Btu per hour maximum heat input)
Operating at 5%o achy.

INSIGNIFICANT ACTIVITIES:
I-ES11
Surface Finishing Operation 2Q .0102(c)(2)(E)(i) Yes Yes
Not Observed
I-Main-058
Natural gas-fired therminol heater
(15 nimBtu/hr maximum heat input) 2Q.0102(c)(2)(B)(ii) Yes Yes
(NSPS Subpart Dc)
Operating on NG
0% VE
I-01
Natural gas/No.2 fuel oil-fired therminol heater 2Q .0102(c)(2)(13)(i)(11) Yes Yes
(9.06 mmBtu/hr maximum heat input)
Not operating
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 tow fire status
0% VE
VI. 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 COMPLMNCE: The facility's current permit was renewed on time. The facility's
permit expires on 30 April2022, and the renewal application and El 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 COMPLIANCE: 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 0.00071b/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) 067 for P<= 30 tons/hr, or
E=55 * (P)01'- 40 for P>30 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 suer diesel(ULSD), as verified by feel
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 COMPLL4NCE I noted visible emissions f om Condenser/Mist Eliminator CD-1 at
5%opacity. There was no VE present for CD-2 or from any of the insignificant sources.
6. 15A NCAC 2D .0524—NEW SOURCE PERFORMANCE STANDARDS (Subpart De)—The
facility's boiler(Main-031) is subject. Fuel sulfur content<0.5 wt.% and monthly records of fuel
usage. VE 5 20% opacity. Initial start-up testing, and periodic testing for visible emissions when
switching from natural gas to fuel oil. Semiannual reporting.
APPEARED IN VIOLATION.• The facility maintains the required fuel records, which shows the
facility burned fuel oil during curtailment on 7 August 2019. The fuel certifications show that the
facility only combusts ULSD. Mr. Kelly stated that they performed a tune-up in September 2019 on
both natural gas and No. 2 fuel oil. Mr. Kelly stated that on neither of these dates was a Method 9
V.E. observation conducted The last Method 9 testing that was conducted was 3 January 2018.
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 COMPLLANCE: 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-I and 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 INCOMPLIANCE. 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 awash procedure.
The mist eliminators are also inspected semiannually with the most recent internal inspections
occurring on 9 April 2020 for CD-1 and 2 March 2020 for CD-2. The facility performs weekly
maintenance on both mist eliminators. The last weekly inspection on CD-01 was on 28 August 2020
and the last weekly inspection on CD-02 was on 26 August 2020.
10. 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.
11. 15A NCAC 2D .1806-CONTROL AND PROIIIBITION 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.
12. 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 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 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.

13. 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 COMPLIANCE: Records indicate the facility combusted No. 2 fuel oil during
curtailment on 7 August 2019 and again for a tune up on 16-17 of September 2019. 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
6 January 2020, and indicated compliance.
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 permitted to operate a natural gas/No. 2 fuel oil-fired boiler(ID Nos.
Main-031). Per 40 CFR 63.11195(e),this source is exempt from this Subpart because it is defined as
a gas-fired boiler in 40 CFR 63.11237. In order to maintain this exemption,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).
a. The Permittee shall maintain records that document the time periods when liquid fuel is fired and the
reasons the liquid fuel is fired.
b. If the Permittee fires liquid fuel for reasons other than gas curtailment, gas supply interruptions,
startups, or for periodic testing on liquid fuel,the Permittee is no longer exempt from Subpart JJJJJJ(6J).
As required by 40 CFR 62.11225(g),the Permittee must provide notice within 30 days of the fuel switch.
The notification must identify:
i. The name of the owner or operator of the affected source,the location of the source,the boiler(s)that
have switched fuels, and the date of the notice.
ii. The date upon which the fuel switch occurred.
As required by 40 CFR 63.11210(h),the Permittee must demonstrate compliance within 180 days of the
effective date of the fuel switch.
APPEARED IN COMPLLANCE: The facility normally fires boiler (ID No. Main-031) with natural
gas. Mr. Kelly explained that the boiler fired No. 2 fuel oil when undergoing curtailment on August 7
2019 (which was verified on Transco website) and again during a tune up on September 16-17 2019.
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 .1100
"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 INCOMPLIANCE. 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.
VH. NON-COMPLIANCE HISTORY SINCE 2010:
Date of Non-Compliance Issue Non-Compliance Description
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.
VIII. 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).
IX. CONCLUSION AND RECOMMENDATIONS:
On September 2,2020 Homwood, Inc. appeared to be operating IN VIOLATION for failure to conduct
Method 9 VE Pursuant to 02D .0524,NSPS De. I recommend sending the facility a Notice of Violation
letter for the failure to perform a Method 9 Visible Emission Observation test when burning No.2 fuel oil.
PINK SHEET ADDITIONS:
• None
/j In