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HomeMy WebLinkAboutAQ_F_1200180_20220510_CMPL_InspRpt (4) NORTH CAROLINA DIVISION OF Asheville Regional Office AIR QUALITY Seiren North America, LLC NC Facility ID 1200180 Inspection Report County/FIPS: Burke/023 Date: 05/16/2022 Facility Data Permit Data Seiren North America, LLC Permit 09231 /R14 1500 E Union Street Issued 4/2/2018 Morganton,NC 28655 Expires 3/31/2026 Lat: 35d 45.1240m Long: 8 1 d 39.6490m Class/Status Synthetic Minor SIC: 2221 /Weaving Mills, Synthetics Permit Status Active NAILS: 31321 /Broadwoven Fabric Mills Current Permit Application(s)None Contact Data Program Applicability Facility Contact Authorized Contact Technical Contact SIP Kevin Heape Koji Kaw Kevin Heape Maintenance and Hajime Yamauchi Maintenance and Environmental Manager President Environmental Manager (828)430-3456 (828)430-3456 (828)430-3456 Compliance Data Comments: Inspection Date 05/10/2022 Inspector's Name Michael Koerschner Inspector's Signature: Operating Status Operating Compliance Status Compliance- inspection Action Code FCE Date of Signature: 2 Inspection Result Compliance Z Total Actual emissions in TONS/YEAR: TSP S02 NOX VOC CO PM10 * HAP 2016 12.36 0.0500 7.73 0.4100 6.48 12.36 926.71 2012 8.23 0.0500 8.30 0.5200 6.96 8.10 6203.00 * 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 Directions: From Asheville, take 1-40 east to exit 105. The exit ramp will circle around. Turn right (north). Co approximately 1 mile and turn right onto Fleming Street(Highway 64). At the intersection of Highway 70 and Fleming Street, turn left onto East Union Street. The facility is on the left at 1500 East Union Street. Safety Equipment: Hearing protection, safety glasses. 5/10/2022 Inspection Report Page 2 1. Facility Description: Seiren North America,LLC makes headliner and seat cover fabric for automobile manufacturers. Polyester and other synthetic yarn is brought into the facility from outside sources and knitted. After knitting,the fabric can be either printed or dyed. Printing is done by a screen printing machine. Dyeing is done in dye becks.After being printed and/or dyed,the material is finished in one of seven tenter frames;the facility is permitted for eight tenter frames. Seven of the tenter frames are in operation and have emissions controlled by condensers/mist eliminators. The facility operates three shifts per day,five days per week and occasionally on Saturdays dying operations and inspection(Q/C)will operate. The facility has approximately 220 employees. 2. Inspection Summary: On May 10,2020 at about 2 p.m. I,Michael Koerschner,met with Mr. Kevin Heape,Maintenance and Environmental Manager, and inspected the facility. See below for an inspection summary for each emission source, (permitted equipment noted in italics). CD-6 one condenser-type packed bed mist eliminator(20,000 acfm inlet gas flow rate); installed on: ES-1 one indirectly heated tenter frame(964 pounds of fabric per hour maximum throughput; maximum oil content of fabric 3.0%); Known by the facility as tenter frame#I ES-2 one indirectly heated tenter frame(964 pounds of fabric per hour maximum throughput; maximum oil content of fabric 3.0%); Known by the facility as ternter frame#2 ES-3 one indirectly heated tenter frame(840 pounds of fabric per hour maximum throughput; maximum oil content of fabric 3.0%); Known by the facility as tenter frame##3 The above tenter frames are controlled by a condenser in series with a mist eliminator. The condenser uses one pass city water for coolant. There is a pre-filter located before the condenser and the main filtration system is after the condenser and consists of an array of nine tube-type filters. The following operating data was observed Reading Reading Reading Reading Reading Parameter 5/10/2022 7/17/2019 2/22/17 3/10/16 3/26/15 Temperature after-condenses- --I 19"F —1 19"F 120"F 1031F 68"F pressure drop across condenser >3"W.C. 1" no 1.6" reading pressure drop across re-filter >3"WC —4"W.C. 0.2" 0.5" 0.95" pressure drop across filters —5.2"W.C. 5" 5" 3" The tenter frames which are controlled by this condenser/filter unit were observed and observations are recorded in the table below: ID No *Temperature Number of Feed rate Inspection (Degrees Celsius Zones meters/m Notes ES-I/Tenter I n/a 8 n/a not operating ES-2/Tenter 2 n/a 8 n/a not operating ES-3/Tenter 3 —150 6 —13.5 final setting Note that there are nappers located near tenter frames ID Nos. ES-1 and ES-2. The nappers do not require permitting. The Visco dry printing process is also near these tenter frames and is an insignificant activity; details on this process are later in this report. CD-4 one condenser-type packed bed mist eliminator(20,000 acfm inlet gas flow rate); installed on: 5/10/2022 Inspection Report Page 3 ES-4 one indirectly heated tenter frame(840 pounds of fabric per hour maximum throughput; maximum oil content offabric 3.001o); Known by the facility as tenter frame#8 ES-6 one indirectly heated tenter frame(2,400 pounds of fabric per hour maximum throughput; maximum oil content of fabric 3.0%); Known by the facility as tenter frame#4 ES-7 one indirectly heated tenter frame(2,400 pounds of fabric per hour maximum throughput; maximum oil content offabric 3.0016); Known by the facility as tenter frame#5 The above tenter frames were formerly controlled by an afterburner, ID No. CD-2, but the afterburner was replaced with a condenser and mist eliminator. The condenser/mist eliminator, ID No. CD-4,began operation in October 2011. The condenser uses one pass city water for coolant. There is a pre-filter located before the condenser and the main filtration system is after the condenser and consists of an array of nine filters. The following operating data was recorded on the condenser: Parameter Reading 5/10/2€122 condenser temperature —750F pressure drop across condenser >3" WC pressure drop across re-filter 10" WC pressure drop mist eliminators 2.5" WC It was stated during a previous inspection that visible emissions can become an issue of the condenser temperature reaches 160°F;the condenser typically operates from 80 to 130°F. There is an oil/water separation tank used to separate the oil and water collected by the condenser. Visible emissions appeared to be minimal; I did not observe any visible emissions from this device. This unit is the same size,etc as the other condenser unit and the maintenance is the same. The follo ing operating data was recorded for each tenter frame controlled by CD-4: ID No. *Temperature Number of Process Speed Inspection De rees Celsius Zones m/minute Notes ES-4(Tenter 8) —150 6 18.7 final setting ES-6 Tenter 4 DOWN 6 DOWN DOWN ES-7 Tenter 5 —150 6 9.4 final setting *temperatures were typically consistent within a few degrees across all zones. CD-5 one venturi scrubber in series with a vertical packed tower and mist eliminator(6,000 acfm inlet gas flow rate) installed on: ES-5 one natural gas fired flame laminator(3.0 mmBtu/hr maximum capacity); The flame laminator is used to bond fabric, foam, and scrim together. The flame laminator was operating during the inspection at a line speed of—27 meters per minute. There were no visible emissions from the scrubber exhaust during the inspection. The following data was recorded: Reading leading Read' Reading Reading Reading Reading Reading Parameter 5/10/2022 7/17/19 9/21/18 2/22/17 3/_10/16 3/26/15 518114 12/6/12 flow to venturi m 95 85 96 70 87 ? 100 95 flow to packed tower 89 90 90 81 91 ? 70 90 (gpm) H 9.8 9.8 ? 10.23 9.85 ? ? 9.87 venturi static pressure 25 14" 19 23 2.2 inches WC packing static I ? 1.8 ? 0.35 pressure(inches WC) 5/10/2022 Inspection Report Page 4 The water flow was recorded via rotameter type flow measuring devices installed on the water supply lines. ES-8 one indirectly heated tenter frame(1,200 pounds offabric per hour maximum throughput; maximum oil content offabric 3.0%); Known by the facility as tenter frame#6(uncontrolled)(idled)—Observed—not in operation. ES-9 one indirectly heated tenter frame with no presetting capacity; This is not on-site. 3. The following processes that are listed as insignificant activities: IES-I -Pressurized/closed fabric dyeing operation (negligible emissions expected) 20 identical closed fabric dyeing vessels were observed in the facility during the inspection. There are 4 banks of 5 dye becks. IES-2-Six natural gas- red steam boilers(three rated at 13.2 MMBtu/hr(NSPS affected), two rated at 1.2 NIMBtu/hr, and one rated at 8.3 MtLIBtu/hr maximum heat input) The boilers were briefly observed during this inspection. The boilers are all about the same size. Note that some of the boilerplates are WRONG in that the minimum firing rate is higher than the maximum firing rate(it appears that the maximum firing rate is off by a decimal place. Each boiler has it's own stack. It appears that the equipment list should reference 5 boilers as 13.2 mmBtu/hr(Nos. 1-5)and l boiler as 8.3 mmBtu/hr(No. 6). IES-3 -Two natural gas-fired hot oil boilers(8.3 MMBtu/hr maximum heat input) These heaters are identical and are vented to a common stack. The following information was recorded from the boilerplate of one of the heat exchangers during a previous inspection: max pressure— 145 psi at 5720F heat input=8.3 mmBtu/hr year built: 1991 These heaters are used to supply heated oil to the indirectly heated tenter frames. IES-4 - One Visco Dry process that utilizes acetic acid and ink This process is located by tenter frame ID No. ES-1;this process performs screen printing on the fabric. Mr. Heape stated that this process rarely operates. During a previous inspection he had stated that the ink is water-based. IES-5 -One cleaning/soap process that utilizes ethylene glycol and acetic acid Mr. Heape stated that this process has been removed and was part of another exempt activity(IES-6- one pre- treatment process)that was removed from the permit with the last permit renewal. We discussed taking IES-5 off the permit the next time the permit is opened. IES-8 -One 2000 gallon acetic acid storage tank This tank was observed during this inspection. A 50%caustic tank is located in front of the acetic acid tank. Each tank has its own enclosure. IES-1 l —three electrically-heated embossing operations Not observed. 5/10/2022 Inspection Report Page 5 4. Review of compliance with permit specific conditions and limitations: Specific Condition 5 -Control of Visible Emissions(15A NCAC 2D .0521): Visible emissions appeared to be well below the applicable 20%opacity limit from the condenser,boiler, and scrubber exhausts. Specific Condition 8— 15A NCAC 2D .1100"Control of Toxic Air Pollutants"and associated stack test: Restrictions- To ensure compliance with the above limits, the following restrictions shall apply: i. emissions from the natural gas-fired flame laminator(ID No. ES-5)shall be controlled by the venturi scrubber and packed tower(ID No. CD-5); ii. the venturi scrubber/packed tower stack(ID No. CD-5) shall be located and operated per information provided by the facility on April 2, 2012. The permit sets forth emission limitations for TDI,hydrogen cyanide, and hydrogen chloride from the flame laminator exhaust in order to comply with the acceptable ambient levels(AALs)for each of these pollutants. The emissions from the flame laminator are controlled by the scrubber as required by the permit. Operations and I&M of the scrubber appear adequate to control the toxic pollutants. Specific Condition 9- LIMITATION TO AVOID 15A NCAC 2Q .0501 - Pursuant to 15A NCAC 2Q .0315 "Synthetic Minor Facilities,"to avoid the applicability of 15A NCAC 2Q .0501 "Purpose of Section and Requirement for a Permit:" Specific Condition 9 of the permit has the following requirements in regard to the condenser/mist eliminators(ID No. CD-4& CD-6)and the scrubber(packed tower)(ID No. CD-5): a. Inspection and Maintenance Requirements- i. Condenser/Mist Eliminator Requirements-Emissions shall be controlled as described in the permitted equipment list. To comply with the provisions of this permit and ensure that emissions do not exceed the regulatory limits, the Permittee shall perform periodic inspections and maintenance (1&M) as recommended by the manufacturer. In addition, the Permittee shall perform an annual(for each 12 month period following the initial inspection) inspection of each condenser system. As a minimum, the 1&A4 program and each annual inspection should include the following: A. inspection and maintenance of the structural integrity of each condenser, including inspection for leakage of coolant and, if the system is under positive gauge pressure, leakage of the contaminated gas stream. To determine leakage of the coolant, the condensate shall be inspected for the presence of coolant. B. inspection and maintenance of the structural integrity of duct work and piping leading to and coming from each condenser. ii. PM-Scrubber(Packed Tower) Requirements-Particulate matter emissions shall be controlled as described in the permitted equipment list. To comply with the provisions of' this permit and ensure that emissions do not exceed the regulatory limits, the Permittee shall perform periodic inspections and maintenance(1&M) as recommended by the manufacturer. In addition, the Permittee shall perform an annual(for each 12 month period following the initial inspection) internal inspection of each scrubber system. As a minimum, the I&M program and each annual inspection should include the following: A. inspection of spray nozzles,packing material, chemical feed system (if so equipped), and the cleaning/calibration of all associated instrumentation annually. 5/10/2022 Inspection Report Page 6 B. two weeks following initial start-up and startup following major maintenance of each scrubber, the Permittee shall shut down the system and inspect for nozzle plugging and settling of the packing. b. Recordkeeping Requirements-A log book shall be kept on site.for each control device and made available to Division of Air Quality personnel upon request. The Perm ittee shall record all inspection, maintenance and monitoring requirements listed above in the log book. Any variance from the manufacturer's recommendations shall be investigated with corrections made and date of actions recorded in the log book. The work on the control devices is tracked with a work order system. The most recent internal inspections are reported in the table below: Control System Description Last Internal Inspection ID CD-4 One condenser-type packed bed mist eliminator 1/17/2022 CD-5 One venturi scrubber in series with a vertical 12/29/2021 packed tower and mist elminiator(6000 acfm as flow rate CD-6 One condenser-type packed bed mist eliminator 1/24/2022 5. Recommendations: a. Remove exempt source IES-5—one cleaning soap process from the Exempt Activities List the next time the permit is opened. This source has been removed from the facility and was associated with another exempt source(ID No. IES-6 pre-treatment process,which was removed with the last permit renewal). b. Adjust the identification numbers of the tenter frames to correspond with the identification numbers used by the facility when the permit is next opened. 6. Conclusion: The facility appeared to be operating in compliance with Air Permit No. 09231 R14 at the time of the inspection.