AQ_F_1800092_20150917_PRMT_Permit

- *72
MCDER
North Carolina Department of Environment and Natural Resources
Pat McCrory Donald R.van der Vaart
Governor Secretary
September 17, 2015
Mr. Kurt Wartner
General Manager
WestRock Converting Company-Conover
214 Conover Boulevard
Conover,NC 28613
Subject: Air Permit No. 05061R21
WestRock Converting Company- Conover
Conover, Catawba County,North Carolina
Permit Class: Small
Facility ID# 1800092
Dear Mr. Wartner:
In accordance with your completed application received September 8, 2015, we are
forwarding herewith Permit No. 05061R21 to WestRock Converting Company- Conover, Conover,
Catawba County,North Carolina for the construction and operation of air emissions sources or air
cleaning devices and appurtenances. Please note the records retention requirements are contained in
General Condition 2 of the General Conditions and Limitations.
If any parts,requirements, or limitations contained in this permit are unacceptable to you,
you have the right to request a formal adjudicatory hearing within 30 days following receipt of this
permit, identifying the specific issues to be contested. Such a request will stay the effectiveness of
the entire permit. This hearing request must be in the form of a written petition, conforming to G.S.
150B-23 of the North Carolina General Statutes, and filed with the Office of Administrative
Hearings, 6714 Mail Service Center, Raleigh,NC 27699-6714. The form for requesting a formal
adjudicatory hearing may be obtained upon request from the Office of Administrative Hearings.
Unless a request for a hearing is made pursuant to G.S. 150B-23,this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
15013-22. This request must be submitted in writing to the Director and must identify the specific
provisions or issues for which the modification is sought. Please note that the permit will become
final and binding regardless of a request for informal modification unless a request for a hearing is
also made under G.S. 15013-23.
Mooresville Regonal Office-Division of Air Quality
610 East CenterAvenue,Suite 301,Mooresville,North Carolina 28115
Phone:[phone]/FAX:[phone]
Internet:www.nedenr.gov
An Equal Opportunity\Affirmative Action Employer-Made in part by recycled paper

Kurt Wartner
September 17,2015
Page 2
. Unless exempted by a condition of this permit or the regulations, construction of new
air pollution sources or air cleaning devices, or modifications to the sources or air cleaning
devices described in this permit must be covered under a permit issued by the Division of Air
Quality prior to construction. Failure to do so is a violation of G.S. 143-215.108 and may
subject the Permittee to civil or criminal penalties as described in G.S. 143-215.114A and 143-
215.114B.
This permit shall be effective from September 17, 2015 until November 30, 2016, is
nontransferable to future owners and operators, and shall be subject to the conditions and limitations
as specified therein.
Changes have been made to the permit stipulations. The Permittee is responsible for
carefully reading the entire permit and evaluating the requirements of each permit
stipulation. The Permittee shall comply with all terms, conditions, requirements,limitations
and restrictions set forth in this permit. Noncompliance with any permit condition is grounds
for enforcement action, for permit termination, revocation and reissuance, or modification, or
for denial of a permit renewal application. Should you have any questions concerning this matter,
please contact Jennifer Womick at 704-663-1699.
Sincerely,
Ronald E. Slack, Regional Supervisor
Division of Air Quality,NCDENR
JAW
Enclosures
c: Mooresville Regional Office
G:\AQ\Shared\WPDATA\COUNTIES\CATAWBA\00092\R21—PERMIT.docx

NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENT AND NATURAL RESOURCES
DIVISION OF AIR QUALITY
AIR PERMIT NO. 05061R21
Issue Date: September 17, 2015 Effective Date: September 1.7, 2015
Expiration Date:November 30,2016 Replaces Permit: 0506IR20
To construct and operate air emission source(s) and/or air cleaning device(s), and for the
discharge of-the associated air contaminants.into the atmosphere in accordance with the provisions
of Article 21 B of Chapter 143, General Statutes of North Carolina(NCGS) as amended, and other
applicable Laws,Rules and Regulations,
WestRock Converting Company- Conover
214 Conover Boulevard
Conover, Catawba County,North Carolina
Permit Class: Small
Facility ID# 1800092
(the Permittee) is hereby authorized to construct and operate the air emissions sources and/or air
cleaning devices and appurtenances described below:
Emission Emission Source Control Control System
Source ID Description System ID j Description
ES-1228,ES-1229,ESAL three(3)off-set printing
1162 11presses N/A N/A
3
ES-1262,ES-1263 two(2)windowing machines
I(3,000 pounds per hour
maximum process rate,each) N/A N/A
ES-1266 ;windowing machine(4,000
C pounds per hour maximum N/A N/A
process rate)
E
71267 windowing machine(12,000
pounds per hour maximum N/A 4 N/A
process rate)
ES-1251 1 carton folding and gluing
operation N/A N/A

Permit No. 05061R21
Page 2
Emission Emission Source Control Control System
I Source ID Description System ID Description
Paperboard Cutting Presses and Shredder
. _. .._ .....
F ES-1235 paperboard cutting press CD38,BF42,CD31, ; simple cyclone(ID No. CD38,
(2,980 pounds per hour BF41,BF44 108 inches in diameter)
maximum_ process rate) installed in series with bagfilter
(ID No.BF42, 1005 square feet
of ,filter area)
i
{Alternate Control System
i
;simple cyclone(ID No. CD31, {
168 inches in diameter)
installed in series with bagfilters
j (ID Nos.BF41 and BF44, 1005
{ square feet of filter area,each j
installed in parallel)
paper pounds ti g press CD37,BF44,CD31 ... .. .__
ES-1236 !simple cyclone(ID No. CD37,
our
108 inches in diameter)
maximum_process rate) ; installed in series with bagfilter
! (ID No.BF43, 1005 square feet
i
of filter area)
<Alternate Control System
simple cyclone(ID No. CD31,
168 inches in diameter)
installed in series with bagfilters
(ID Nos.BF41 and BF44, 1005
square feet of filter area,each
installed m parallel)
_..._. .. ...;._. .. _..... . _._ ... _.................j
ES-1237 I paperboard cutting press j CD36,BF40,CD31, simple cyclone(ID No. CD36,
(3,004 pounds per hour BF41,BF44 108 inches in diameter)
maximum process rate) i 'installed in series with bagfilter
(ID No.BF40, 1005 square feet
{ of filter area)
I { ;Alternate Control System
j simple cyclone(ID No. CD31,
168 inches in diameter)
installed in series with bagfilters'
f (ID Nos.BF41 and BF44, 1005
square feet of filter area,each
.. _.. _.. _. installed in parallel)..
ES-1238 paper cutting press(81960 1 CD35,BF39 simple cyclone(ID No.CD35,
pounds per hour maximum 128 inches in diameter)
process rate) installed in series with bagfilter
(ID No.BF39, 1005 square feet
j of filter area)
ES-1239 paperboard cutting press CD31,BF41,BF44 'simple cyclone(ID No.CD31,
(8,960 pounds per hour 168 inches in diameter)
maximum process rate) installed in series with bagfilters
(ID Nos.BF41 and BF44, 1005
square feet of filter area,each
installed in parallel)

Permit No. 05061R21
Page 3
in accordance with the completed application 1800092.15A received September 8, 2015 including
any plans, specifications,previous applications, and other supporting data, all of which are filed
with the Department of Environment and Natural Resources, Division of Air Quality(DAQ) and are
incorporated as part of this permit.
This permit is subject to the following specified conditions.and limitations including any
TESTING, REPORTING, OR MONITORING REQUIREMENTS:
A. SPECIFIC CONDITIONS AND LIMITATIONS
1. Any air emission sources or control devices authorized to construct and operate above must
be operated and maintained in accordance with the provisions contained herein. The
Permittee shall comply with applicable Environmental Management Commission
Regulations, including Title 15A North Carolina Administrative Code (NCAC), Subchapter
2D .0202, 2D .0515, 2D .0521, 2D .0535, 2D .0540, 2D .0611, 2D .0958 and 2Q .0711.
2. PERMIT RENEWAL AND EMISSION INVENTORY REQUIREMENT - The Permittee,
at least 90 days prior to the expiration date of this permit,shall request permit renewal by
letter in accordance with 15A NCAC 2Q .0304(d) and(f). Pursuant to 15A NCAC 2Q
.0203(i),no permit application fee is required for renewal of an existing air permit(without
a modification request). The renewal request(with AA application form) should be
submitted to the Regional Supervisor, DAQ. Also, at least 90 days prior to the expiration
date of this permit,the Permittee shall submit the air pollution emission inventory report "
(with Certification Sheet) in accordance with 15A NCAC 2D .0202,pursuant to N.C.
General Statute 143 215.65. The report shall be submitted to the Regional Supervisor, DAQ
and shall document air pollutants emitted for the 2015 calendar year.
3. PARTICULATE CONTROL REQUIREMENT- As required by 15A NCAC 2D .0515
"Particulates from Miscellaneous Industrial Processes," particulate matter emissions from
paperboard cutting press (ID No. ES-1235),paperboard cutting press (ID No. ES-1236),
paperboard cutting press (ID No. ES-1237),paper cutting press (ID No. ES-1238) and
paperboard cutting press (ID No. ES-1239) shall not exceed allowable emission rates. The
allowable emission rates are, as defined in 15A NCAC 2D .0515,a function of the process
weight rate and shall be determined by the following equation(s), where P is the process
throughput rate in tons per hour(tons/hr) and E is the allowable emission rate in pounds per
hour(lbs/hr).
E=4.10 * (P) 0•67 for P <= 30 tons/hr,or
E=55 * (P) o.ii _ 40 for P>30 tons/hr
4. VISIBLE EMISSIONS CONTROL REQUIREMENT -As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from the emission sources,
manufactured after July 1, 1971, shall not be more than 20 percent opacity when averaged
over a six-minute period, except that six-minute periods averaging not more than 87 percent
opacity may occur not more than once in any hour nor more than four times in any 24-hour
period. However, sources which must comply with 15A NCAC 2D .0524 "New Source
Performance Standards" or .1110 "National Emission Standards for Hazardous Air
Pollutants" must comply with applicable visible emissions requirements contained therein.

Permit No. 05061 R21
Page 4
5. NOTIFICATION REQUIREMENT -As required by 15A NCAC 2D .0535, the Permittee of
a source of excess emissions that last for more than four hours and that results from a
malfunction, a breakdown of process or control equipment or any other abnormal
conditions, shall:
a. Notify the Director or his designee of any such occurrence by 9:00 a.m. Eastern time
of the Division's next business day of becoming aware of the occurrence and
describe:
i. the name and location of the facility,
ii. the nature and cause of the malfunction or breakdown,
iii. the time when the malfunction or breakdown is first observed,
iv. the expected duration, and
V. an estimated rate of emissions.
b. Notify the Director or his designee immediately when the corrective measures have
been accomplished.
This reporting requirement does not allow the operation of the facility in excess of
Environmental Management Commission Regulations.
6. FUGITIVE DUST CONTROL REQUIREMENT -As required by 15A NCAC 2D .0540
"Particulates from Fugitive Dust Emission Sources," the Permittee shall not cause or allow
fugitive dust emissions to cause or contribute to substantive complaints or excess visible
emissions beyond the property boundary. If substantive complaints or excessive fugitive
dust emissions from the facility are observed beyond the property boundaries for six minutes
in any one hour(using Reference Method 22 in 40 CFR,Appendix A),the owner or
operator may be required to submit a fugitive dust plan as described in 2D .0540(f).
"Fugitive dust emissions" means particulate matter that does not pass through a process
stack or vent and that is generated within plant property boundaries from activities such as:
unloading and loading areas,process areas stockpiles, stock pile working, plant parking lots,
and plant roads (including access roads and haul roads).
7. CYCLONE REQUIREMENTS -As required by 15A NCAC 2D .0611,particulate matter
emissions shall be controlled as described in the permitted equipment list.
a. Inspection and Maintenance Requirements - To comply with the provisions of this
permit and ensure that emissions do not exceed the regulatory limits, the Permittee
shall perform an annual (for each 12 month period following the initial inspection)
inspection of the cyclone system. In addition,the Permittee shall perform periodic
inspections and maintenance (I&M) as recommended by the manufacturer.

Permit No. 05061R21
Page 5
b. Recordkeeping_Requirements -The results of all inspections and any variance from
the manufacturer's recommendations or from those given in this permit(when
applicable) shall be investigated with corrections made and dates of actions recorded
in a cyclone logbook. Records of all maintenance activities shall be recorded in the
logbook. The cyclone logbook(in written or electronic format) shall be kept on-site
and made available to DAQ personnel upon request.
8. FABRIC FILTER REQUIREMENTS including cartridge filters,baghouses,and other dry
filter particulate collection devices -As required by 15A NCAC 2D .0611, particulate matter
emissions shall be controlled as described in the permitted equipment list.
a. Inspection and Maintenance Requirements - To comply with the provisions of this
permit and ensure that emissions do not exceed the regulatory limits,the Permittee
shall perform, at a minimum, an annual (for each 12 month period following the
initial inspection) internal inspection of each bagfilter system. In addition,the
Permittee shall perform periodic inspections and maintenance as recommended by
the equipment manufacturer.
b. Recordkeeping_Requirements - The results of all inspections and any variance from
manufacturer's recommendations or from those given in this permit(when
applicable) shall be investigated with corrections made and dates of actions recorded
in a logbook. Records of all maintenance activities shall be recorded in the logbook.
The logbook(in written or electronic format) shall be kept on-site and made
available to DAQ personnel upon request.
9. 15A NCAC 2D .0958: WORK PRACTICES FOR SOURCES OF VOLATILE ORGANIC
COMPOUNDS
a. As required by 15A NCAC 2D .0958(c), for all sources at facilities that use volatile
organic compounds (VOC) as solvents, carriers, material processing media, or
industrial chemical reactants, or in similar uses that mix, blend, or manufacture
volatile organic compounds, or emit volatile organic compounds as a product of
chemical reactions;the Permittee shall adhere to the following required work
practices:
i. The Permittee shall store all VOC-containing material not in use(including
waste material) in containers covered with a tightly fitting lid that is free of
cracks, holes, or other defects.
ii. The Permittee shall clean up spills as soon as possible following proper
safety procedures.
iii. The Permittee shall store wipe rags in closed containers.
iv. The Permittee shall not clean sponges, fabric,wood,paper products, and
other absorbent materials.

Permit No. 0506IR21
Page 6
V. The Permittee shall drain solvents used to clean supply lines and other
coating equipment into closable containers and close containers immediately
after each use.
vi. The Permittee shall clean mixing,blending, and manufacturing vats and
containers by adding cleaning solvent, closing the vat or container before
agitating the cleaning solvent.
vii. The Permittee shall pour spent cleaning solvent into closable containers and
close containers immediately after each use.
b. When cleaning parts with a solvent containing a volatile organic compound,the
Permittee shall:
i. flush parts in the freeboard area,
ii. take precautions to reduce the pooling of solvent on and in the parts,
iii. tilt or rotate parts to drain solvent and allow a minimum of 15 seconds for
drying or until all dripping has stopped, whichever is longer,
iv. not fill cleaning machines above the fill line,
V. not agitate solvent to the point of causing splashing. [15A NCAC 2D
.0958(d)]
10. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT - Pursuant to
15A NCAC 2Q .0711 "Emission Rates Requiring a Permit," for each of the below listed
toxic air pollutants (TAPS),the Permittee has made a demonstration that facility-wide actual
emissions,where one or more emission release points are obstructed or non-verticallX
oriented, do not exceed the Toxic Permit Emission Rates(TPERs) listed in 15A NCAC 2Q
.0711(a). The facility shall be operated and maintained in such a manner that emissions of
any listed TAPS from the facility, including fugitive emissions, will not exceed TPERs listed
in 15A NCAC 2Q .0711(a).
a. A permit to emit any of the below listed TAPS shall be required for this facility if
actual emissions from all sources will become greater than the corresponding
TPERs.
b. PRIOR to exceeding any of these listed TPERs,the Permittee shall be responsible
for obtaining a permit to emit TAPS and for demonstrating compliance with the
requirements of 15A NCAC 2D .1100 "Control of Toxic Air Pollutants".

Permit No. 05061R21
Page 7
c. In accordance with the approved application, the Permittee shall maintain records of
operational information demonstrating that the TAP emissions do not exceed the
TPERs as listed below:
Carcinogens Chronic Acute Systemic E Acute
Pollutant - lb/ r _ _Toxicants Toxicants Irritants
( y ) (lb/day) (lb/hr) (lb/hr)
Acetic acid(64-19-7) 0.96
..........
Ammonia(as NH3) (7664-41 7) 0.68
Styrene (100-42 5). '.�� _. . � 2.7
Xylene (mixed isomers) (1330- 57 16.4
20-7)
B. GENERAL CONDITIONS AND LIMITATIONS
1. In accordance with G.S. 143-215.108(c)(1), TWO COPIES OF ALL DOCUMENTS,
REPORTS,TEST DATA,MONITORING DATA,NOTIFICATIONS,REQUESTS FOR
RENEWAL,AND ANY OTHER INFORMATION REQUIRED BY THIS PERMIT shall
be submitted to the:
Regional Supervisor
North Carolina Division of Air Quality
Mooresville Regional Office
610 East Center Avenue, Suite 301
Mooresville,NC 28115
704-663-1699
For identification purposes, each submittal should include the facility name as listed on the
permit,the facility identification number, and the permit number.
2. RECORDS RETENTION REQUIREMENT - In accordance with 15A NCAC 2D .0605,
any records required by the conditions of this permit shall be kept on site and made available
to DAQ personnel for inspection upon request. These records shall be maintained in a form
suitable and readily available.for expeditious inspection and review. These records must be
kept on site for a minimum of 2 years,unless another time period is otherwise specified.
3. ANNUAL FEE PAYMENT-Pursuant to 15A NCAC 2Q .0203(a),the Permittee shall pay
the annual permit fee within 30 days of being billed by the DAQ. Failure to pay the fee in a
timely manner will cause the DAQ to initiate action to revoke the permit.
4. EQUIPMENT RELOCATION - In accordance with 15A NCAC 2Q .0301, a new air permit
shall be obtained by the Permittee prior to establishing, building, erecting, using, or
operating the emission sources or air cleaning equipment at a site or location not specified in
this permit.

Permit No. 05061 R21
Page 8
5. REPORTING REQUIREMENT - In accordance with 15A NCAC 2Q .0309, any of the
following that would result in previously unpermitted, new, or increased emissions must be
reported to the Regional Supervisor, DAQ:
a. changes in the information submitted in the application regarding facility emissions;
b:---changes that modify equipment or processes of existing permitted-facilities;-or -
c. changes in the quantity or quality of materials processed.
If appropriate, modifications to the permit may then be made by the DAQ to reflect any
necessary changes in the permit conditions. In no case are any new or increased emissions
allowed that will cause a violation of the emission limitations specified herein.
6. In accordance with 15A NCAC 2Q .0309,this permit is subject to revocation or
modification by the DAQ upon a determination that information contained in the application
or presented in the support thereof is incorrect, conditions under which this permit was
granted have changed, or violations of conditions contained in this permit have occurred. In
accordance with G.S. 143-215.108(c)(1),the facility shall be properly operated and
maintained at all times in a manner that will effect an overall reduction in air pollution.
Unless otherwise specified by this permit,no emission source may be operated without the
concurrent operation of its associated air cleaning device(s) and appurtenances.
7. In accordance with G.S. 143-215.108(c)(1),this permit is nontransferable by the Permittee.
Future owners and operators must obtain a new air permit from the DAQ.
8. In accordance with G.S. 143-215.108(c)(1),this issuance of this permit in no way absolves
the Permittee of liability for any potential civil penalties which may be assessed for
violations of State law which have occurred prior to the effective date of this permit.
9. In accordance with G.S. 143-215.108(c)(1),this permit does not relieve the Permittee of the
responsibility of complying with all applicable requirements of any Federal, State, or Local
water quality or land quality control authority.
10. In accordance with 15A NCAC 2D .0605,reports on the operation and maintenance of the
facility shall be submitted by the Permittee to the Regional Supervisor, DAQ at such
intervals and in such form and detail as may be required by the DAQ. Information required
in such reports may include,but is not limited to,process weight rates, firing rates,hours of
operation, and preventive maintenance schedules.
11. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-215.11413, and 143-215.114C, including assessment of
civil and/or criminal penalties.
12. Pursuant to North Carolina General Statute 143-215.3(a)(2), no person shall refuse entry or
access to any authorized representative of the DAQ who requests entry or access for
purposes of inspection, and who presents appropriate credentials,nor shall any person
obstruct, hamper, or interfere with any such representative while in the process of carrying

Permit No. 05061 R21
Page 9
out his official duties. Refusal of entry or access may constitute grounds for permit
revocation and assessment of civil penalties.
13. In accordance with G.S. 143-215.108(c)(1),this permit does not relieve the Permittee of the
responsibility of complying with any applicable Federal, State,or Local requirements
governing the.handling, disposal, or incineration of hazardous, solid, or medical wastes,
including the Resource Conservation and"Recovery Act"(RCRA) administered by the
Division of Waste Management.
14. PERMIT RETENTION REQUIREMENT- In accordance with 15A NCAC 2Q .0110,the
Permittee shall retain a current copy of the air permit at the site. The Permittee must make
available to personnel of the DAQ,upon request,the current copy of the air permit for the
site.
15. 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.
16. PREVENTION OF ACCIDENTAL RELEASES - GENERAL DUTY- Pursuant to Title I
Part A Section 112(r)(1) of the Clean Air Act "Hazardous Air Pollutants - Prevention of
Accidental Releases - Purpose and General Duty, although a risk management plan may not
be required, if the Permittee produces,processes, handles, or stores any amount of a listed
hazardous substance,the Permittee has a general duty to take such steps as are necessary to
prevent the accidental release of such substance and to minimize the consequences of any
release. This condition is federally-enforceable only.
17. GENERAL EMISSIONS TESTING AND REPORTING REQUIREMENTS - If emissions
testing is required by this permit, or the DAQ, or if the Permittee submits emissions testing
to the DAQ in support of a permit application or to demonstrate compliance,the Permittee
shall perform such testing in accordance with 15A NCAC 2D .2600 and:follow all DAQ
procedures including protocol approval,regional notification, report submittal, and test
results approval.
Permit issued this the 17th of September, 2015.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Ronald E. Slack
Regional Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 05061R21