AQ_F_1200086_20220301_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Siegwerk EIC LLC
NC Facility ID 1200086
Inspection Report County/FIPS: Burke/023
Date: 03/02/2022
Facility Data Permit Data
Siegwerk EIC LLC Permit 05478/R12
1 Quality Products Road Issued 12/6/2013
Morganton,NC 28655 Expires 11/30/2021
Lat: 35d 42.3660m Long: 8 1 d 41.9160m Class/Status Small
SIC: 2893 /Printing Ink Permit Status Active
NAICS: 32591 /Printing Ink Manufacturing Current Permit Application(s) Renewal
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Ray Robinson Scott Bartlett Lee Kearson
Engineering, Facility and Head of Operations Health, Safety&
Maintenance [phone] Environmental Specialist
[phone] [phone]
Compliance Data
Comments:
Inspection Date 03/01/2022
Inspector's Name Mamie Colburn
Inspector's Signature: � W / , Operating Status Operating
��/l/`-' Compliance Status Compliance- inspection
Action Code FCE
Date of Signature: 3 P( Zz Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2020 0.0000 --- --- 3.28 --- 0.0000 ---
2012 0.0100 --- 0.1500 7.20 0.1200 0.0100 5.29
x Highest HAP Emitted inpounds)
Five Year Violation History:None
Date Letter Type Rule Violated Violation Resolution Date
Performed Stack Tests since last FCE: None
Date Test Results Test Method(s) Source(s)Tested

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1. Directions: From Asheville,take I-40 East to exit 103. Turn right onto Highway 64. Go less than
one mile, and then turn left onto Craftsman Drive. The facility is located approximately 200 yards
on the right.
2. Facility Overview
a. Safety: Safety shoes and glasses required. Ammonia smell in mixing areas may be
strong at times. Water present on the floor for wash down.
b. Facility Contacts: Lee Kearson,EHS Specialist will meet with inspector for inspection
and records review. Facility contacts have not changed. If the facility contact is not
available for an inspection, ask for Mr. Ray Robinson,Engineering(cell 828-448-4966),
or Mr. Ronnie Murphy, Maintenance Supervisor(828-391-2315, or 828-448-8028).
c. Facility Overview: Siegwork manufactures water-based inks for use in rotogravure and
flexographic printing. These inks are made by mixing resins and water with organic
pigments;the approximate percentages are 10-15%pigment,40%resin, and 50%water.
Ammonium hydroxide is added to achieve the proper pH. The inks are used for film
work, lamination(water bottles), and other printing projects. Customers include Rock
Tenn,Valdese Packing,the Smythe Corp.,and others.
i. The plant operates from 6 am to 10 pm with the bulk of production from 5:30 am
to 3 pm.
ii. The facility has been at this location since 1985 and employs approximately 60
people.
d. General Observations: Upon arrival no exterior dust,odors, or visible emissions were
seen. The facility was mostly shut down with no mixing ongoing at the time of arrival.
During the inspection a strong residual smell of ammonia was noticeable in the mixing
areas of the facility. Wash down water was seen pooled inside in multiple places.
3. Emission Source Observations
Inspection Narrative: On March 1,2022 I arrived at Siegwerk to complete an annual
compliance inspection. Siegwerk currently has a permit renewal in review at our office. I
spoke with Mr. Kearson about the emissions inventory,which to this point, has not been
resolved due to continued discussion on how to calcluate ammonia emissions. After
discussing this concern in detail in Mr. Kearson's office,we proceeded through the inside
and outside of the plant to view emissions sources. The facility had completed its
product mixing for the day with shipping activity seen along with end of the day cleanup.
Strong odors of ammonia were noted in the two mixing areas. Odors were noticed within
10 feet of the building but not in the parking lot or off-site.
The following permitted sources were observed:
Emission
Emission Source Control
Source Observations Today 3/1/22
Description System
ID
Observed NOT in operation. This is a
DC-1 one bagfilter(250 bench-scale pigment blending operation for
square feet of filter
trial and/or test purposes;operation,per Mr.
ES-1 laboratory pigment blending area) Kearson,confirmed at about an hour per
operations week.
Cartridge Filters
Last bagfilter inspection and maintenance
was logged in June 2021.
I

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Emission Emission Source Control
Source Observations Today 3/1/22
ID Description System
DC-2 one bagfilter(960 Observed NOT in operation. This line
waterborne ink manufacturing square feet of filter begins operations about 6:30am and is
ES-2 operations area) finishing daily production by mid-day.
'
E Called"WB"at the facility.
Cartridge Filters Last bagfilter inspection and maintenance
was logged on 11/30/21.
DC-6 one bagfilter Observed NOT in operation. Dispersion
dispersion manufacturing (2,480 square feet of
manufacturing begins later in the morning to
ES-4 operations filter area) process ES-2 production to the next step.
Called"shot"at the facility.
Last bagfilter inspection and maintenance
Cartridge Filters was logged on 11/30/21.
Insignificant sources:
Emission Exemption
Source Notes
Source ID Regulation
I-1
natural gas-fired boiler(1.83 million 2Q .0102 Removed from service
Btu per hour maximum heat input rate) (c)(2)(B)(i)(I) No replacement boiler
4. Regulator and Permit Condition Review:
a. Specific Condition#3. Particulate Control Requirement. An allowable particulate
emissions rate is calculated based on process weight rate. The last permit renewal
included an emission inventory wherein particulate emissions were evaluated by Harold
Brady, formerly of this office, in 2013. Mr. Kearson stated that no changes had been
made to the facility. Compliance is indicated.
b. Specific Condition 44: Visible emissions control requirement.No visible emissions were
observed during the inspection. Bagfilters were not in operation during the inspection.
Mr. Kearson stated that no visible emission complaints had been received at the facility;
no complaints have been received at DAQ-ARO. Compliance is indicated.
c. Specific Condition#5: Notification Requirements. No abnormal breakdowns of process
or control equipment or any other abnormal conditions have occurred per statement from
Mr. Kearson.No complaints have been received a DAQ-ARO. No notifications were
indicated since prior inspection. Compliance is indicated.
d. Specific Condition#6: Fugitive Dust Control. The facility must operate to prevent dust
from leaving the property and creating substantive complaints. No fugitive dust was
observed on or beyond the property boundary. Mr. Kearson stated that no dust complaints
had been received by the facility. No complaints have been received by DAQ-ARO.
Compliance is indicated.
e. Specific Condition#7: Fabric Filter Requirements. The facility is required to perform, at
a minimum, an annual internal inspection of each bagfilter system, and document them
and any maintenance performed in a logbook. Mr. Ray Robinson opened the electronic
logbook to show recent maintenance on the bagfilters. The electronic maintenance system
logbook appears to be adequate and up to date. DC-1 was last inspected in June 2021.

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DC-2 was last inspected on 11/30/21. DC-6 was last inspected on 11/30/21. Compliance
is indicated.
f. Specific Condition #8: Toxic Air Pollutant Emissions Limitation and Reporting
Requirement: The facility must operate in a manner to not exceed the modeled limit of
20.12 pounds per hour of ammonia emissions and limit any NC TAPs to less than the
TPERs. The facility is required to maintain daily tracking records of usage. Records of
daily ammonium hydroxide use were viewed in facility tracking spreadsheets. Emissions
factor and method to calculate emissions of ammonia were discussed. Compliance is
indicated.
g. Specific Condition #9: Control and prohibition of odor: Odors were not observed off the
property boundary. On-site ammonia odors were noted outside of the mixing room under
a covered dock. There was also a strong ammonia odor within the facility mixing rooms.
No complaints have been received by DAQ- ARO. Compliance is indicated.
B. Records Review: During the inspection, production records that track ammonium hydroxide
were reviewed. Mr. Kearson tracks ammonium hydroxide use in production batches and by time
(daily and monthly reports). Various spreadsheets to calculate the estimated emissions of
ammonia were reviewed. These production records were shared and discussed for the upcoming
permit renewal and emissions inventory process. The permitted emisisons limit is 20.12 lbs/hr
ammonia. The facility does not appear to be violating this emissions limit.
C. Submitted Reports: The facility does not have any annual or semi-annual reporting
requirements.
5. Compliance History Review: There have been no documented violations since 2008. One
unsubstantiated dust complaint was received on April 30, 2018. No new complaints in 2021.
6. Stack Test Review: The facility has had no stack test requirement and no tests are pending.
7. 112r Review: Environmental Inks is subject to the 1 12(r) program general duty clause, but does
not maintain regulated chemicals onsite above the threshold quantities, which would require a risk
management plan.
8. Compliance Assistance: Today's visit included extensive time reviewing the emissions inventory
(EI) and ammonia emissions calculations. Mr. Kearson will follow up with permit engineer,
Michael Koerschner to continue to complete the EI needed for the permit renewal.
9. Recommendation: A new Generac generator was observed outside of the loading dock area. This
generator runs on natural gas and is 17kw, 30 amp. This piece of equipment should be evaluated
during the upcoming permit renewal process for permit applicability. The permit engineer was
notified. The natural gas boiler has been removed from the facility and this change should be
noted on the upcoming permit renewal.
10. Conclusion: Based on record review and visual observations,this facility appeared to be operating
in compliance with applicable rules and regulations at the time of this inspection.