AQ_F_1200180_20210311_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Seiren North America,LLC
NC Facility ID 1200180
Inspection Report County/FIPS: Burke/023
Date: 03/29/2021
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: 81d 39.6490m Class/Status Synthetic Minor
SIC: 2221 /Weaving Mills, Synthetics Permit Status Active
NAICS: 31321 /Broadwoven Fabric Mills Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Kevin Heape Koji Kawada Kevin Heape
Maintenance and President Maintenance and
Environmental Manager [phone] Environmental Manager
[phone] [phone]
Compliance Data
Comments:
Inspection Date 03/11/2021
Inspector's Name Michael Koerschner
Inspector's Signature: t Operating Status Operating
4A Compliance Status Compliance-inspection
Action Code FCE
Date of Signature: Inspection Result Compliance
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(in pounds)
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). Go
approximately I 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.
Sa eoy Equipment: Hearing protection, safety glasses.

COVID-19—Due to the ongoing pandemic, this scheduled inspection was an out-of-doors visit only. We walked the
perimeter of the facility and did not enter the facility. We did not go into any roofed or enclosed spaces.
1. Facility Description:
Seiren North America,LLC makes headliner and seat cover fabric for the auto industry. 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. 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 permitted to heat setting at temperatures of up to 190°C(374°F),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 240 employees.
2. Inspection Summary:
On March 11, at—11:00 am,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, (permit-listed
equipment noted in italics).
CD-6 one condenser-type packed bed mist eliminator(20,000 acfm inlet gas flow rate);
installed on:
ES-I one indirectly heated tenter frame(964 pounds of fabric per hour maximum throughput;maximum
oil content of fabric 3.091o); Known by the facility as tenter frame#1
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 condenser uses one pass city water to condense the oils in the airstream off the tenter frames. 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
Temperature after condenser N/A —1190F 120OF 1030F
pressure drop across condenser —3 W'C' >3"W.C. 1" no
reading
pressure drop across re-filter —5"W.C. —4"W.C. 0.2" 0.5"
Not
pressure drop across filters" det rmined —5.2"W.C. 5" 5"
No visible emissions were observed(0%VE). Per Mr. Heape's 3/15/2021 email,only Tenter No.2(ES-2)was in
operation during this inspection.
CD-4 one condenser-type packed bed mist eliminator(20,000 acfm inlet gas flow rate);
installed on:
ES-4 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#8
ES-6 one indirectly heated tenter frame(2,400 pounds of fabric per hour maximum throughput;
maximum oil content of fabric 3.D%); 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 of fabric 3.0%); Known by the facility as tenter frame#5

This condenser/filter is the same size/etc as CD-6. I observed the stack for visible emissions but did not observe any
visible emissions. The following are my observations:
condenser Did not —116 OF 90OF 100°F
temperature record
pressure drop —1" W.C. —1.5"WC 2.5" 2.5"
across condenser
pressure drop —3" W.C. Not reading 2.2" 2.2"
across pre-filter
pressure drop —5"W.C. —5"WC 6.5" 9"
across filters
Per Mr.Heape's 3/15/2021 email,Tenter Frame#5 (ES-7)was operating during this inspection.
CD-5 one venturi scrubber in series with a verticalpacked 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. There were no visible emissions from the scrubber exhaust during the inspection. The scrubber
parameter displays are inside the facility and were not observed during this inspection.
ES-8 one indirectly heated tenter frame(1,200 pounds of fabric per hour maximum throughput;maximum oil
content of fabric 3.0%);
Not observed.
ES-9 one indirectly heated tenter frame with no presetting capacity; Known by the facility as tenter frame#7
(uncontrolled)
Not observed.
3. The following processes that are listed as insignificant activities:
IES-1 -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. In addition there are 2 smaller
IES-2-Six natural gas-fired steam boilers (three rated at 13.2 MMBtu/hr(NSPS affected), two rated at 1.2
MMBtu/hr,and one rated at 8.3 MMBtu/hr maximum heat input)
The boilers were not observed during this inspection. 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;300 HP)and 1 boiler as 8.3 mmBtu/hr(No. 6;200 HP).
According to Mr.Heape,the facility has 5 300-HP boilers and 1 200-11P boiler.They are changing out(buying a
new 200-HP boiler)and will have 4 300-HP boilers and 2 200-HP boilers.The boilers fire natural gas with propane
backup(20,000 gallon propane tank).
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 and the stack was observed with no visible
emissions.

IES-4-One Visco Dry process that utilizes acetic acid and ink
Not observed.
IES-5-One cleaning/soap process that utilizes ethylene glycol and acetic acid
Not observed.
IES-8-One 2000 gallon acetic acid storage tank
Not observed.
IES-11—three electrically-heated embossing operations
Not observed.
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.
I questioned Mr.Heape about stack observations and he indicated that he looks at the stacks daily.
Specific Condition 8— 15A NCAC 2D A 100"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(I&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 I&M 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&Mprogram and each annual inspection should include the
following:
A. inspection of spray nozzles,packing material, chemical feed system (rf so
equipped), and the cleaning/calibration of all associated instrumentation
annually.
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 Permittee 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.
Per my email request,Mr. Heape forwarded me the dates of the last internal inspections of each of these control
devices.According to the 3/15/2021 email,the last internal inspections of the condensers was 12/27/2020(CD-4),
7/2/2020(CD-6) and the last internal inspection of the venturi system was 12/29/2020(CD-5).
5. Recommendations:
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).
Synch up the identification numbers used by the facility when the permit is next opened.
Change the insignificant list to reflect the replacement of a 300-HP boiler with a 200-HP boiler.
Consider re-classifying facility as"small" [I discussed this with Mr.Heape].
6. Conclusion:
During this inspection,the facility appeared to be operating in compliance with Air Permit No. 09231R14.