AQ_F_1200086_20210811_CMPL_InspRpt (4)

QDO0 ) ?U -/SIG
NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Environmental Inks-A Member of the Siegwerk
Group
Inspection Report NC Facility ID 1200086
Date: 08/17/2021 County/FIPS: Burke/023
Facility Data Permit Data
Environmental Inks -A Member of the Siegwerk Group 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: acifi h{ c�ppeared to Ise vPera+iv19 iVI comphavicc.
Inspection Date 08/11/2021
Inspector's Signature: _ - w � Inspector's Name Lisa Whitaker
L
Operating Status Operating
Compliance Status Compliance-inspection
Date of Signature: -AUOUSt 18, 2-02-1 Action Code FCE
Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2012 0.0100 --- 0.1500 7.20 0.1200 0.0100 5.29
2007 --- --- 0.0000 2.90 0.0000 0.0000 ---
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
1. Facility Overview
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.
Safty Equipment: Safety glasses and safety shoes.

Facility Description
Environmental Inks and Coatings 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.The facility
has been at this location since 1985 and employs approximately 60 people. They operate from 6 am to 10 pm,with the bulk of
the production during the hours of 6am to 4 pm,five days per week.
Inspection Narrative
On August 11,2021,I,Lisa Whitaker met with Mr.Lee Kearson,HSE Coordinator,to conduct an annual compliance inspection.
During the inspection,Mr.Kearson provided access and identification of the emission source operations and control devices and
provided electronic access to maintenance records. Everything appeared to be in order and easily accessible.
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),and Mr.
Lee Kearson HSE Coordinator.
Mr.Kearson sent the facility's permit renewal application to the Regional Office by me,which included name change.
The facility has added a new building with production. Mr. Kearson reported(and signs on-site agree)that the new
operation is UV-cured ink production. Mr. Kearson attested that the operation had been reviewed for applicable DAQ
regulations and none were found.
2. Emission Source and Regulatory Review
Source Listing. The facility is permitted to operate the following equipment and controls:
Emission Emission Source Control
Source ID Description System Notes
Observed NOT in operation. This is a
E
ES-1 laboratory pigment blending DC-1 one bagfilter(250 bench-scale pigment blending operation for trial
operations square feet of filter area) and/or test purposes;operation,per Mr.Kearson,
confirmed at about an hour per week.
waterborne ink manufacturing DC-2 one bagfilter(960 Observed in operation with no VE. This line
ES-2 operations square feet of filter area) begins operations about 6:30am and is finishing
Called"""at the facility. daily production by mid-day.
Observed in operation with no VE. Two tanks
dispersion manufacturing DC-6 one bagfilter(2,480 Were in operation at the time of inspection. Per
ES-4 operations Mr.Kearson this amount of usage is normal and
Called"shot"at the facility. square feet of filter area) begins later in the morning to process ES-2
production to the next step.
Permit Conditions
• 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.
• Specific Condition 4: Visible Emissions Control Requirement. Visible emissions from all sources are limited to 20%
opacity.
No visible emissions were observed from the sources in operation. 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.

• Specific Condition 6: Fugitive Dust Control Requirement: 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.
• 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.
Deficiency documented-Mr.Ray Robinson assisted me in reviewing the electronic logbook inspection and
maintenance(I&M)records on the bagfilters. Mr.Robinson reported,at the time of inspection,that magnahelic gauge
readings are used to trigger filter changes. The electronic maintenance system logbook appears to be adequate and up to date.
On August 18,2021,Mr.Kearson provided emailed screenshots of the workorder database including WO history and PM
tasks(image below). When asked for WO history for DC-1,Mr.Kearson replied(excerpt),"As for the Lab Unit there is so
little use(< 1 hour/Quarter)that the unit is not on the PM rotation.". During our opening interview,Mr.Kearson confirmed
that the Lab operated approximately 1 hour each week,however note that Lab Control Device is internally inspected
quarterly;no records were available to demonstrate quarterly internal inspection of the DC-2 or DC-6.Compliance is
indicated.
The recent prior inspections for the bagfilter systems are:
DAQ DAQ Facility Facility date date date date
Device Operations Device Operations name
ID name ID
DC-1 Lab 4 WB Lab 3,6,9,12/2018 3,6,9,12/2019 3,6,9,12/2020 3,6/2021
DC-2 Waterborne 1 WB 11/30/2018 12/3/2019 11/26/2020 8/10/2021
"Production"
DC-6 Dispersion 2 Shot 11/30/2018 12/3/2019 11/26/2020 8/9/2021
l
N�
PM Tasks Equipment Details Parts Open WorkOrders WO History Equipment Log Documents
PM# PMTask Responsible Shift Code Frequency
6 Grease Motor Maintenance 1st Shift Q 2
13 Check Gauges Maintenance 1st Shift EM 1
14 Empty Hopper Maintenance 1st Shift M 1
1s Inspect/Replace Filters Maintenance 1st Shift y 1
24 Check For Leaks Maintenance 1st Shift M 1
• Specific Condition 8: Work Practice Requirements.The regulation documented in this condition has been vacated,however,
while this condition remains in the permit,facilities should continue to exercise the work practices prescribed herein
including proper lidded storage of VOC-containing compounds and waste.
Both lidded and unlidded waste containers were observed,however it could not be established that VOC-containing
waste was in them.
Permit note:this stipulation can be removed from the air permit during the upcoming modification/renewal since the
regulation has been repealed for attainment areas.
• Specific Condition 9 and 11: NC Toxics Requirements.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.
The daily tracking records amounts of ammonium hydroxide additions are used to populate monthly spreadsheets.
According to those spreadsheets,the amounts of ammonium hydroxide additions across 2020 was 0.1 —0.21 and to-date in
2021 has been 0.15 -0.19. The facility does not appear to be at risk of violating this emission limit.Compliance is
indicated.

• Specific Condition 10: Control and Prohibition of Odorous Emissions.The facility must operate to prevent objectionable
odors from creating substantive complaints against the facility.
No odor was detected on or beyond the property boundary.Mr.Kearson stated that no odor complaints had been
received by the facility. No complaints have been received by DAQ-ARO.Compliance is indicated.
Insignificant Sources Listing The facility is known to have had the following source on-site:
Emission Exemption
Source Notes
Source ID Regulation
natural gas-fired boiler(1.83 million F2Q .0102 Removed from service—
I-1B
tu per hour maximum heat input rate)) (2)(B)(i)(I) Fnotreplaced as of this inspection.
3. Compliance History Review: There have been no documented violations since 2008. One unsubstantiated dust
complaint was received on April 30,2018.
4. Stack Test Review: The facility has had no stack test requirements and no tests are pending.
5. Clean air act section 112(r) requirements: Pursuant to 15A NCAC 2D .2100"Risk Management Program," if the
Permittee is required to develop and register a risk management plan pursuant to Section 112(r)of the Federal Clean Air
Act,then the Permittee is required to register this plan with the USEPA in accordance with 40 CFR Part 68.
RMP Not Required—Environmental Inks is subject to the 112(r)program general duty clause, but does not
maintain regulated chemicals onsite above the threshold quantities,which would require a risk management
plan.
6. Compliance Assistance: I hand delivered the facility's Air Quality permit renewal application in addition to their
periodic storm water report(in a separate envelope).I later emailed Mr.Kearson to assist in getting the Emission
Inventory Certification submitted as well.
7. Conclusion:After records review and direct visual observations,this facility appeared to be operating in compliance of
their Air Quality permit.