AQ_F_0200037_20190403_CMPL_InspRpt

NORTH CAROLINA DIVISION OF AIR QUALITY Mooresville Regional Office
Shurtape Technologies,LLC-Stony Point Plant
Inspection Report NC Facility ID 0200037
Date: 04/03/2019 County/FIPS:Alexander/003
Facility Data Permit Data
Shurtape Technologies, LLC- Stony Point Plant Permit 04648/T12
8510 Highway 90 West Issued 12/12/2018
Stony Point,NC 28678 Expires 11/30/2023
Lat: 35d 51.8760m Long: 8 1 d 3.0096m Class/Status Title V
SIC: 2672/Paper Coated And Laminated,Nec Permit Status Active
NAICS: 322222/Coated and Laminated Paper Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Mark Hawes Carl Tolbert Mark Hawes NSPS: Subpart RR
Director of Environment Director of North Director of Environment
and Safety American Manufacturing and Safety
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 04/03/2019
Inspector's Name Denise Hayes
Inspector's Signature: �, ,t Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: ql l u llq �\� On-Site Inspection Result Compliance
1 1
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2017 0.0100 --- --- 149.20 --- 0.0100 36.15
2016 0.0100 --- --- 106.37 --- 0.0100 ---
2015 0.0100 --- --- 142.40 --- 0.0100 ---
*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
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation

Shurtape Technologies,LLC—Stony Point Plant
April 3, 2019
Page No. 2
Data Tracking: Date submitted for initial review 4/10/2019 _IBEAM WARNING/OB,NOD,NOV,NRE
X IBEAM Document
X IBEAM Inspection, list date inspected X IBEAM LAT/LONG,Facility Locked
X IBEAM Inspection,list date draft is submitted X IBEAM LAT/LONG,Coordinates-checked
X IBEAM Inspection,pollutants/programs checked _IBEAM Complaint
X IBEAM Planning,Next Inspection Date 4/1/2020
Directions: Take I-77 North to I-40 west to Exit 1.48. Turn right onto Highway 64 West. Turn right on
Smith Farms Road and then turn left on Highway 90. The facility is on the left in Stony Point.
Safety Equipment: Safety shoes, earplugs, and safety glasses are required. The facility also requests that
the inspector have their state ID visible during the inspection.
Safety Issues: None noted.
Lat/Low A review of the facility's coordinates in IBeam indicates the facility's latitude and longitude
coordinates are accurate. Latitude and longitude coordinates of this facility are locked in IBEAM.
Contacts: The authorized, facility, and technical contact emails were verified. Mr.Hawes indicated
changes will be coming soon. I recommended he notify our office of the changes when they take place.
1. General Information. The purpose of this site visit was to conduct a full compliance evaluation.
Shurtape Technologies,LLC(Shurtape)manufactures pressure sensitive tape. No printing is done on-
site. The facility operates 24 hours per day, seven days per week, 50 weeks per year. The mailing
address for this facility is PO Box 1530,Hickory,NC, 28603.
2. I arrived at the facility at approximately 9:00 am on April 3, 2019. I met with Mr. Mark Hawes, Mr.
Jerry Eplin, and Mr. Rodney Speaks for this inspection. Ms. Alejandra Cruz, with NCDAQ, also
accompanied me on this inspection.
3. File Review.
A. Contacts. The facility contact list was checked and is current. Mr. Hawes indicated changes
will be forthcoming and will notify our office at that time.
B. Files. The following files were reviewed prior to the inspection: previous inspection reports;
correspondence since the last inspection,semiannual reports,annual emissions inventories,and
annual compliance certification reports.
C. Compliance history.
There have been no violations or deviations noted in the last five years by DAQ. The current
compliance status is discussed in the following sections.
D. Operating Conditions established by Stack Testing. The facility has not been required to
perform any tests at the time of this inspection.

Shurtape Technologies,LLC—Stony Point Plant
April 3,2019
Page No. 3
E. Records Required-by Title V. During this inspection,all records required by the Title V permit
were reviewed and appeared to show compliance.
F. NSPS/NESHAP Review
The facility is permitted to operate two tape calendars that are subject to NSPS Subpart RR,
"Standards of Performance for Pressure Sensitive Tape and Label Surface Coating Operations".
The facility is not subject to NESHAP at this time. The permit includes a permit shield for
NESHAP Subpart JJJJ, "NESHAP: Paper and Other Web Coating" because the facility is not
a major source for HAP.
The insignificant list of sources includes two natural gas-fired boilers. As such, they are not
subject to NESHAP Subpart JJJJJJ, "NESHAP for Industrial, Commercial, and Institutional
Boilers Area Sources"because they only fire natural gas.
The facility does not have any internal combustion engines that are subject to NESHAP Subpart
ZZZZ, "NESHAP for Stationary Reciprocating Internal Combustion Engines". The facility
has an electric fire pump on-site which has no applicable requirements.
The facility does not have any gasoline tanks that would be subject to NESHAP Subpart
CCCCCC.
4. Part I - AIR QUALITY TITLE V OPERATION PERMIT. The following permitted emission
sources and/or control devices listed in Section 2 Paragraph 2.1- Emission Source(s)and Control
Devices(s) Specific Limitations and Conditions were observed during this inspection:
A. 'One tape calender with adhesive release agent application process(ID No.21)and one film
co-extrusion/tape calender with an adhesive release agent application process (ID No. 22)
were observed in operation with no visible emissions at the time of this inspection. For
each tape calender, a poly-film is extruded or applied to a cloth web. A non-VOC(100
percent solid)adhesive is then calendered to the web. After the adhesive is applied,
isopropyl alcohol (IPA) is wicked onto the poly-film as a release coat. Some poly-film is
purchased that has a non-volatile release coat material already either on the surface or built
into the matrix of the film. The pre-purchased poly-film reduces the usage of isopropyl
alcohol as the facility does riot have to apply their own release coat to this material.
1. Condition 2.1 —A.I. (15A NCAC 2D .0521, "Control of Visible Emissions") - The
tape calendars are subject to the opacity limit of 20%as set by 2D .0521. There are no
monitoring, recordkeeping, or reporting requirements for this condition. Observed.
The tape calendars were observed in operation with no visible emissions at the time of
this inspection.
Therefore,the facility appeared to be in compliance with this regulation at the time of
this inspection.

i
Shurtape Technologies,LLC—Stony Point Plant
April 3, 2019
Page No. 4
2. Condition 2 1 —A 2 (15A NCAC 2D .0524 "New Source Performance Standards"as
promulgated in 40 CFR 60 Subpart RR)—The calendars are subject to the requirements
of NSPS Subpart RR. The facility has chosen to comply by not causing the discharge
from the tape calendars(ID Nos. 21 and 22)not more than 0.20 kg VOC/kg of coating
solids applied as calculated on a weighted average basis for one calendar month ("G"
value).. The facility is required to calculate the monthly weighted average of the mass
of solvent used per mass of coatings applied. The facility is required to maintain a
calendar month record of all coatings used and 'maintain a 12-month record of the
amount of solvent applied in the coating at the facility. The facility is required to
submit quarterly reports of any exceedances that occur. If no exceedances occur, the
facility is required to submit a semi-annual teport stating that there were no
exceedances. The facility is required to submit a',semi-annual summary report of the.
monitoring and recordkeeping activities. Observed. The records of the monthly
weighted average calculations and 12-month totals of the amount of solvent applied
were reviewed from March 2018 through March2019 and appeared to be complete.
The highest monthly calculated "G" value observed in the records was 0.049. Mr.
Eplin indicated that due to the amount of solids used in.the process, the limit of 0.20
kg VOC/kg of coating solids applied is not likely to be exceeded. The most recent
semi-annual report was received on January 130, 2019 and appeared to show
compliance. The report stated that no exceedances occurred during the reporting
period.
Therefore,the facility appeared to be in compliance with this regulation at the time of
this inspection. -
3. Condition 2.1 —A.3. (15A NCAC 2Q .0317 "Avoidance Conditions"for the
avoidance of 15A NCAC 2D .0530 "Prevention of Significant Deterioration")—The
facility is subject to a VOC emissions limit of 292.7 tons per year as set by 2Q .0317
(PSD Avoidance). The facility is required to calculate the VOC emissions each
month and record them in a logbook. The facility is required to submit a semi-annual
summary report of the monthly VOC emissions. ;Observed. The records of monthly
VOC emissions were observed and appeared to be complete. The highest amount
observed in the logbook was 214.3 tons per year..The monthly VOC totals include
isopropyl alcohol usage from the two tape calendars (ID Nos. 21 and 22),usage of
low VOC run material, and cleaning solvent emissions. Flow meters are used to
monitor isopropyl alcohol usage,from the two tape calenders. The facility assumes
100%VOC content for process oil usage even though the actual VOC content is
0.6%. The facility has been testing some poly-film with its own release coat,which
would reduce the amount of isopropyl alcohol usage. However,those materials have
not shown to be useful and of good quality. Therefore,the facility has discontinued
the use of the pre-coated materials. The most recent semi-annual report was received
on January 30,2019 and appeared to show compliance.
Therefore,the facility appeared to be in compliance with this regulation at the time of
this inspection.

Shurtape Technologies,LLC—Stony Point Plant
April 3, 2019
Page No. 5
5. Part I-AIR QUALITY TITLE V OPERATION PERMIT. Section 3 -GENERAL CONDITIONS
A. Condition B. - Permit. The facility is required to maintain a copy of the permit and
application at the facility. Observed. The.permit and application were available for
viewing at the time of this inspection.
B. Condition D. - Submissions. Except as otherwise specified,two copies of all documents,
reports, test data, monitoring data are required to be submitted to MRO: Observed. The
facility typically submits the appropriate number of copies.
C. Condition F. -Circumvention. The facility is required to operate and maintain the facility
at all times in a manner that will affect an overall reduction in air pollution. Observed.
The sources were in operation at the time of this inspection with no visible emissions. The
facility is performing the required monitoring to ensure compliance at all times.
D. Condition I.A. and I.B. - Excess Emissions. The facility is required to report excess
emissions and permit deviations. Observed. The facility indicated that no excess
emissions have occurred since the last inspection.
E. Condition K. — Permit Renewal. The facility is required to submit a permit renewal
application at least six months before the date of permit expiration. Observed. The
facility's permit is scheduled to expire on November 30, 2023. The renewal application
will be due during calendar year 2023.
F. Condition O. - Retention of Records. The Permittee shall retain records of all required
monitoring data and supporting information for a period of at least five years from the date
of the monitoring sample,measurement, report, or application. Observed. The facility is
maintaining the required records.
G. Condition P. - Compliance Certification. The facility.is required to submit a compliance
certification (for the preceding calendar year) by March 1. Observed. The most recent
compliance certification for calendar year 2018 was received on February 26, 2019 and
appeared to show compliance.
H. Condition X. - Emissions Inventory. The facility is required to submit an emissions
inventory by June 30 of each year. Observed. The most recent emissions inventory was
submitted via AERO on June 21, 2018. The signed certification form was postmarked on
June 22, 2018.
I. Condition CC. - Refrigerant Requirements (Stratospheric Ozone and Climate Protections .
The facility is required to properly dispose of refrigerants. Observed. The facility
maintains a list of the refrigerant containing equipment and uses only certified technicians
to do all refrigerant-related work.
J. Condition DD. - Section 112(r). This facility does not appear to be subject to the
requirements of the Chemical Accident Release Prevention Program, Section 112(r)of the
Clean Air Act.

Shurtape Technologies,LLC—Stony Point Plant
April 3, 2019
Page No. 6
K. Condition MM. —Fugitive Dust. The facility is required to minimize fugitive dust such
that they do not cause or contribute to substantive complaints or excess visible emissions
beyond the property boundary. Observed. There were no fugitive dust emissions observed
at the time of this inspection. There have been no complaints received by this office since
the last inspection.
6. The following non-permitted air emission sources and control;devices were observed as follows:
A. One process solids storage silo and conveying system(ID No.I-31-01)with associated bin vent
cartridge filter(1-3 1-BF-Silo)was observed in operation with no visible`emissions. The storage
silo is for filler material. The filler material is clay or calcium carbonate and can vary
depending on price.
B. Two natural gas-fired boilers (ID Nos. I-31-BLR-1 and,I-31-BLR-2) were observed not in
operation. The boilers are currently not used by the facility.
C. Six storage tanks (ID Nos. I-31-ST-1, 1-31-ST-2, I-31-ST=4, I-31-ST-4a, I-31-ST-5, and I-31-
ST-6) are listed as insignificant sources. The storage ;tank (ID No. I-31-ST-4) has been
removed from the facility. The remaining tanks hold IPA, virgin cleaning solvent, and used
cleaning solvent. The tanks were observed during this inspection with no problems noted.
D. Four LDPE storage silos and associated conveying system (ID Nos. 1-31-LDPE-I through I-
31-LDPE-4)with associated bagfilters were observed in operation with no visible emissions.
E. One parts cleaner(ID No. I-PartsCleaner) was not observed during the inspection. The parts
washer uses Crystal Clean, 100%VOC with no HAPs or TAPs.
F. One Corona treater(ID No. I-Corona)was not observed during this inspection.
G. A QA and R&D lab (ID No. I-QA/RD)was not observed during this inspection.
H. An extruder(ID No. I-Extruder)was observed during this inspection.
7. Other compliance requirements and issues:
A. The facility operates a bagfilter that exhausts inside the building. The bagfilter captures
emissions from the Banbury mixer, Sigma Mixer, and dry weigh area. The bagfilter has no
emissions since it only controls particulate emissions and!vents indoors.
8. Summary of changes needed to the current permit:
The insignificant storage tank (II) No. I-31-ST-4) can be removed from the permit. The
yellowsheet has been updated for this change.
9. Compliance Assistance.'
None noted.
' J

Shurtape Technologies,LLC—Stony Point Plant
April 3, 2019
Page No.,7
10. Findings. Based on my observations during this inspection, this facility appeared to be in
compliance with the applicable air quality regulations.
c: MRO File
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