AQ_F_1200180_20190717_CMPL_InspRpt (4)

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NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Seiren North America, LLC
NC Facility ID 1200180
Inspection Report County/FIPS: Burke/023
Date: 07/19/2019
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 07/17/2019
Inspector's Name Michael Koerschner
Inspector's Signature: Operating Status Operating
/� (� ' Compliance Code Compliance-inspection
/� 'A` "�/ IIIh� Action Code FCE
Date of Signature: On-Site Inspection Result Compliance
I 2U I°►
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). Go
approximately 1 mile andturn right onto Fleming Street(Highway 64). At the intersection of Highway 70 andFleming
Street, turn left onto East Union Street. The facility is on the left at 1500 East Union Street.

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Safety Ec�ui� Hearing protection, safety glasses.
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. 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 July 17,2019 at about 10:20 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,
(permitted equipment noted in italics).
CD-6 one condenser-type packed bed mist eliminator(20,000 acfm inlet gasJlow rate);
installed on:
ES-1 one indirectly heated tenter frame(964 pounds offabric per hour maximum throughput; maximum
oil content offabric 3.0%); Known by the facility as tenter frame#1
ES-2 one indirectly heated tenter frame(964 pounds offabric per hour maximum throughput; maximum
oil content offabric 3.0%);Known by the facility as ternter frame#2
ES-3 one indirectly heated tenter frame(840 pounds offabric per hour maximum throughput; maximum
oil content offabric 3.0%); Known by the facility as tenter frame##3
The above tenter frames were formerly controlled by an afterburner,ID No.CD-1. This unit was replaced with a
condenser and mist eliminator. The condenser/mist eliminator,ID No.CD-6,began operation sometime during
calendar year 2013. 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
Tem erature after condenser —1190F 120OF 1030F 680F
pressure drop across condenser >3"W.C. F, Le no
1.6"
pressure drop across re-filter —4"W.C. 0.2" 1 0.5" 0.95"
pressure drop across filters" 5.2"W.C. 5" 1 5" 1 3"
It was stated during a previous inspection that visible emissions can become an issue if the condenser temperature
reaches 160°F. No visible emissions were observed(0%VE). Mr.Heape stated that the pre-filters are changed
weekly(on the weekends). The pre-filter media is purchased in rolls and is cut to size. The main filters are
composed of mesh cylinders with fiber glass packing inside the cylinders. Mr.Heape stated that the main filters
were replaced"about once every two years."
The tenter frames which are controlled by this condenser/filter unit were observed and observations are recorded in
the table below:

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ES-1/Tenter 1 n/a 8 n/a not operating
ES-2/Tenter 2 180-220 8 —10.9 latex coating
ES-3/Tenter 3 138-151 6 —15.1 final setting
*temperatures have typically been consistent within a few degrees across all zones;ES-1 and ES-2 are
heated with the hot oil boilers, limited use of these tenter frames saves on energy cost by minimizing use of
the hot oil boilers.
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:
I
ES-4 one indirectly heated tenter frame(840 pounds offabric per hour maximum throughput; maximum
oil content offabric 3.0%); Known by the facility as tenter frame#8
ES-6 one indirectly heated tenter frame(2,400 pounds offabric per hour maximum throughput;
maximum oil content offabric 3.0016); Known by the facility as tenter frame#4
ES-7 one indirectly heated tenter frame(2,400 pounds offabric per hour maximum throughput;
maximum oil content offabric 3.0%); 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:
condenser temperature —116OF 90OF 100°F 940F 120OF 80OF 1090F
pressure drop across —1.5"WC 2.5" 2.5" 1.05" 1.1" 1.6" 0.8"
condenser
pressure drop across pre- Not reading 2.2" 2.2" 0.1" 0.8" 1" 0.4"
filter
pressure dropacross filters —5"WC 6.5" 9" 10.5" 7.5" 5" 4" �Y
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 when observed appeared to be minimal; I
did observed visible emissions(less than 10%when we first got to the condenser but they dissipated to 0%opacity.
This unit is the same size,etc as the other condenser unit and the maintenance is the same.
The follo ing operating data was corded foreach tenter frame controlled by CD-4:
h
ES-4 Tenter 8) —150 6 12.3 final setting
ES-6 Tenter 4 123-133 6 12.8 final setting
ES-7 Tenter5 154-163 6 14.4 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:

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ES-5 one natural gas-firedflame 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—28 meters per minute. There were no visible emissions from the scrubber exhaust
during the inspection. The afterburner formerly installed on this unit has been replaced with the scrubber system
consisting of a venturi scrubber,packed tower scrubber,and mist eliminator. This system was installed in October
2012. The following data was recorded:
flow to venturi m 85 96 70 87 ? 100 95
flow to packed tower m 90 90 81 91 ? 70 90
H 9.8 ? 10.23 9.85 ? ? 9.87
venturistatic pressure inches 14" 19 23 2.2
packing static pressure(inches) ? 1.8 ? 0.35
The water flow was recorded via a rotameter type flow measuring device installed on the water supply lines. The
water flow read is read from the top of the float.
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; Known by the facility as tenter frame#7
(uncontrolled)—Observed—not in operation.
n {
ES-9 n/a n/a 3 n/a final setting
3. The following processes that are listed as insignificant activities:
IES-1 -Pressurized/closedfabric 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 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 1 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 572°F
heat input—8.3 mmBtu/hr
year built: 1991

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These heaters are used to supply heated oil to the indirectly heated tenter frames. There was recently a fire at the
base of one of the units(the heat exchanger closer to the boilers)and the facility has had to rent a natural gas-fired
heater while their permanent unit undergoes repairs.Mr.Heape stated that he hoped the repairs would be completed
by the end of August.
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.
j
IES-5 -One cleaning/soap process that utilizes ethylene glycol and acetic acid
i
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 F
the permit the next time the permit is opened.
i
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-I I —three electrically-heated embossing operations
One of the three embossing machines was observed operating at the time of inspection. I did not record process
information.These machines use heat and pressure to make impressions in the web/fabric.
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

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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&Mprogram 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.
a. 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 (I&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 ofspray nozzles,packing material, chemical feed system (fso
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. Recordkeepinjz Requirements-A log book shall be kept on site for each control device and made
available to Division ofAir 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.
Any significant water leakage would show up in the oil water separator tank. Mr. Heape stated that they have had
leaks on the condensers that can easily be isolated.
We reviewed the work orders and maintenance records which indicated the equipment is regularly maintained with
the I&M requirements in compliance with the permit. The last internal inspections of the condensers was 1/2/2019
and the last internal inspection of the venturi system was 12/31/2018.
5. Recommendations:
a. Remove exempt source IFS-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. 09231R14 at the time of the inspection.