AQ_F_1800590_20220512_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Substance Incorporated
NC Facility ID 1800590
Inspection Report County/FIPS:Catawba/035
Date: 05/10/2022
Facility Data Permit Data
Substance Incorporated Permit 10649/R00
3000 Frazier Drive Issued 6/19/2020
Claremont,NC 28610 Expires 5/31/2028
Lat: 35d 42.4487m Long: 8ld 9.4048m Class/Status Synthetic Minor
SIC: 2671 /Paper Coated And Laminated Packaging Permit Status Active
NAILS: 326112/Plastics Packaging Film and Sheet(including Laminated) Current Permit Application(s)None
Manufacturing
Program Applicability
Contact Data
SIP
Facility Contact Authorized Contact Technical Contact NSPS: Subpart RR
Gleason Wilson Matthew Cohn Gleason Wilson
Director of Operations President&CEO Director of Operations
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 05/10/2022
Inspector's Name Joe Foutz
Operating Status Operating
Inspector's Signature: JoieQ E Fov-f-z Dim Compliance Status Compliance-inspection
Action Code FCE
Inspection Result Compliance
Date of Signature: 05/12/2022
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
No emissions inventory on record.The emissions inventory is due 03/02/2028.
*Highest HAP Emitted inpounds)
Five Year Violation History:
Date Letter Type Rule Violated Violation Resolution Date
05/11/2021 NOV Part 60-NSPS Subpart RR Pressure Sensitive Tape and 05/26/2021
Label Surface Coating Operations
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

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Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 05/12/2022 IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: X IBEAM Document
X IBEAM Inspection,list date inspected 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 05/01/2023
Directions: The facility is located at 3000 Frazier Drive, Claremont, Catawba County. Take I-77 north
to I-40 West. Take exit 135 for Claremont. At the end of the exit ramp,turn left onto Oxford Street.
Turn right on Main Street. Travel approximately 0.5 miles and turn left onto Penny Road. Travel a short
distance and turn left onto Frazier Drive. The facility will be on your left.
Safety Equipment: This facility requires safety shoes and eye protection.
Safety Issues: None noted.
Coordinates: A review of the facility's coordinates on"Maps of DAQ Regulated Facilities"indicated
the facility's latitude and longitude coordinates were accurate. The coordinate are not locked within
IBEAM.
Email Contacts: IBeam email contacts were reviewed with Gleason Wilson and are accurate.
1. The purpose of this site visit was to conduct a routine air quality inspection. This facility operates an
adhesive line with a 3.52 mmBtu/hr natural gas-fired curing oven.Various organic solvent-based
adhesives are applied with a slot die onto a poly-coated kraft substrate. The adhesive is cured in an
oven, and the exhaust gases from the adhesive application are sent to a 4.79 mmBtu/hr natural gas-
fired Regenerative Thermal Oxidizer(RTO)for VOC and HAP destruction. The facility is currently
operating 12 hours per day, 3 days per week(Tuesday through Thursday), 52 weeks per year. The
facility employs approximately 14 people.
I arrived at the facility at 10:00 am on May 10,2022.Mr. Gleason Wilson accompanied me during
the inspection.
2. Facility Contact Information:
The facility contact information was reviewed and are correct in IBeam.
3. Compliance History File Review:
The facility received an NOV on May 11,2021, for a late stack test report for the RTO.
The facility received an NOD on March 15, 2021,for a late start-up notification report for the RTO.

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4. Observations of Permitted Air Emission Sources and Control Devices:
Emission Emission Source Control Control System
Source ID Description System ID Description
ES-1 (NSPS) adhesive coating application line with CD-1 regenerative thermal oxidizer
a natural gas-fired curing oven (4.79 mmBtu/hr)
(3.52 mmBtu/hr)
Observed. This unit was in operation at the time of the inspection with no issues noted. Adhesive
glue is delivered in barrels. The barrels are then equipped with a pump,which extrudes the glue
through a slot die onto the poly-coated kraft substrate. The substrate is then fed into the curing oven
where the adhesive is cured, and then a vinyl backer is applied. The curing oven has 4 heating zones.
The 1 st zone operates at approximately 140°F and each zone gradually gets hotter with the 4'zone
operating at 240°F. The final product is then cooled,rolled, and cut to customer specifications before
being packaged and shipped. The adhesive coating process and curing oven are in an enclosed area,
which vents to the RTO. The RTO is equipped with a continuous temperature monitoring device and
was in operation with a combustion temperature of 1614'F. Mr.Wilson stated the RTO temperature
set point is 1600°F. Mr.Wilson also stated the RTO is self-sustaining(ie,no natural gas needed)
when the coating line is operating. Natural gas is only needed for the RTO during start-up or when
there is a product change.
Emission Emission Source Control Control System
Source ID Description System ID Description
ES-2 isolvent cleaning process N/A N/A
Observed. This process was not in operation at the time of the inspection. The facility uses solvent
to clean various equipment associated with the adhesive coating application. The amount of solvent
used is tracked and recorded. The facility alternates between cleaning solutions, isopropyl alcohol or
ethyl acetate.
5. Observations of Insignificant Air Emission sources and Control Devices Listed on the Current Permit:
The facility does not have any insignificant air emission sources listed on the permit.
6. Observations of Air Emission Sources and Control Devices not Listed on the Permit:
None
7. Compliance with Specific Permit Conditions and Limitations:
a. Condition A. 2. "Permit Renewal and Emission Inventory Requirement" -At least 90 days prior
to the expiration date of this permit,the Permittee shall request permit renewal by letter with AA
application form and submit air pollution emission inventory report with certification sheet for
2027 calendar year to MRO DAQ.
Observed. The facility's permit was issued June 19,2020 and does not expire until May 31,
2028. Compliance with this stipulation is indicated.

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b. Condition A. 3. 15A NCAC 2D .0515, "Particulates from Miscellaneous Industrial Processes" -
Particulate matter emissions must not exceed the allowable rates.
Observed. Compliance was verified during the permit review process on June 19,2020.
Compliance with this stipulation is indicated.
c. Condition A.4. 15A NCAC 2D .0516, "Sulfur Dioxide Emissions from Combustion Sources"—
Sulfur Dioxide emissions from the combustion sources shall not exceed 2.3 pounds per million
BTU heat input.
Observed. Per MRO memo"21) .0516 analysis"dated 04/10/97, compliance is indicated for No.
1 fuel oil,No. 2 fuel oil,natural gas,butane,propane,and wood fuel. The curing oven and RTO
run exclusively on natural gas. Compliance with this stipulation is indicated.
d. Condition A. 5. 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.
Observed. No visible emissions were observed at the facility at the time of the inspection.
Compliance with this stipulation is indicated.
e. Condition A. 6. 15A NCAC 2D .0524, "New Source Performance Standards Subpart RR"—For
the adhesive coating application line(ID No. ES-1),the permittee shall comply with NSPS
Subpart RR—Standards of Performance for Pressure Sensitive Tape and Label Surface Coating
Operations."
a. Emission Limits-If the amount of VOC input exceeds 45 Mg(50 tons)per 12 month period,
the coating line shall become subject to the emission limits in 40 CFR 60.442(a), and on and
after the date on which the performance test required by 40 CFR 60.8 has been completed,
the Permittee shall:
i. cause the discharge into the atmosphere from an affected facility to not be more than 0.20
kg VOC/kg of coating solids applied as calculated on a weighted average basis for one
calendar month; or
ii. demonstrate for each affected facility a 90 percent overall VOC emission reduction as
calculated over a calendar month; or
iii. demonstrate the percent overall VOC emission reduction specified in 40 CFR 60.443(b)
as calculated over a calendar month.
b. Compliance Requirements—To determine compliance with 40 CFR 60.442,the Permittee
shall calculate a weighted average of the mass of solvent used per mass of coating solids
applied for a one calendar month period according to the following procedures:

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i. Determine the weight fraction of organics and the weight fraction of solids of each
coating applied by using Reference Method 24 or by the coating manufacturer's
formulations data and compute the weighted average by the equation found in 40 CFR
60.443(a)(2).
For each affected facility where the calculated weighted average mass(kg)of VOC per
mass (kg)of coating solids applied each calendar month(G)is less than or equal to 0.20
kg VOC per kg of coating solids applied,the affected facility is in compliance with 40
CFR 60.442(a)(1). If G is greater than 0.20 kg VOC per kg of coating solids applied,
compliance must be documented with 40 CFR 60.442(a)(2).
ii. To determine compliance with 40 CFR 60.442 through the use of a solvent destruction
device, facility is required to do the following:
1. Calculate the required overall VOC emission reduction(Rq)according to the
equation found in 40 CFR 60.443(b). If Rq less than or equal to 90 percent,then the
required overall VOC emission reduction is Rq. If Rq is greater than 90 percent,then
the required overall VOC emission reduction is 90 percent.
2. Determine calendar monthly compliance by comparing the Rq value as specified
above to the overall VOC emission reduction demonstrated in the most recent
performance test that complied with 40 CFR 60.442(a)(2). If the Rq value is less
than or equal to the overall VOC reduction of the most recent performance test,the
affected facility is in compliance with 40 CFR 60.442(a)(2).
3. Continuously record the destruction device combustion temperature during coating
operations for thermal incineration destructions devices. For Permittee shall record
all 3-hour periods(during actual coating operations) during which the average
temperature of the device is more than 28°C(50°F)below the average temperature of
the device during the most recent performance test complying with 40 CFR
60.442(a)(2).
iii. After the initial performance test required for all affected facilities under 40 CFR 60.8,
compliance with VOC emission limitation and percentage reduction requirements under
40 CFR 60.442 is based on the average emission reduction for one calendar month. A
separate compliance check is completed at the end of each calendar month after the initial
performance test, and a new calendar month's average VOC emission reduction is
calculated to show compliance with the standard.
Emissions from startups and shutdowns are to be included when determining if the
standard specified at 40 CFR 60.442(a)(2)is being attained.
c. Monitoring and RecordkegpLng
i. The permittee shall maintain a calendar month record of all coatings applied as well as
calculations to demonstrate compliance with the emission limits in 40 CFR 60.442.

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ii. The Permittee shall install, calibrate,maintain, and operate a monitoring device which
continuously indicates and records the temperature of the regenerative thermal oxidizer's
(ID No. CD-1) exhaust gases. The monitoring device shall have an accuracy of the
greater of±0.75 percent of the temperature being measured expressed in degrees Celsius
or±2.5 'C.
iii. The records of measurements required in 40 CFR 60.443 and 40 CFR 60.445 shall be
maintained in a logbook(written or electronic form) on site and made available to an
authorized representative upon request. The Permittee shall maintain copies of the
records for at least two years following the date of the measurements.
d. Reporting Requirements—In addition to any other notification requirements to the
Environmental Protection Agency(EPA),the Permittee is required to NOTIFY the Regional
Supervisor,DAQ, in WRITING, of the following:
i. The date construction(40 CFR 60.7)or reconstruction(40 CFR 60.15)of an affected
source is commenced,postmarked no later than 30 days after such date. This
requirement shall not apply in the case of mass-produced facilities which are purchased
in completed form; and
ii. The actual date of initial start-up of an affected source,postmarked within 15 days after
such date.
iii. For each calendar year quarter in which the facility is not in compliance with the
applicable emission limits in 40 CFR 60.442,the facility must submit an exceedance
report. If no such exceedances occur during a particular quarter, a report stating this shall
be submitted to the DAQ semi-annually instead.
iv. The Permittee shall also submit semiannual reports for excess emissions as specified in
40 CFR 60.7(c)when the incinerator temperature drops as defined in 40 CFR 60.443(e).
If no such periods occur,the Permittee shall state this in the report. This reporting is not
required for adhering to the compliance option listed in 40 CFR 60.442(a)(1).
e. NSPS Performance Testing-As required by 15A NCAC 2D .0524,the following
performance tests shall be conducted:
Affected Source(s) Pollutant Target Parameter Test Method
I
adhesive coating application line Percent destruction for
with a natural gas-fired curing VOC regenerative thermal Method 25
oven(ID No. ES-1) oxidizer(ID No. CD-1)
Observed: The RTO started operating on October 28, 2020. A performance test was conducted
on April 28,2021 and was approved by the SSCB on July 8,2021. The facility maintains a
spreadsheet of all coatings applied. The spreadsheet is also used to calculate G. The calculation
of G is typically above 0.2. Therefore,the permittee uses the spreadsheet to calculate the
required emission reduction(Rq). The spreadsheet shows an Rq typically below 90%. A

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performance test shows a destruction efficiency of 99% for the RTO. The performance test
indicated an average temperature 1630 OF for the RTO. Therefore,the RTO temperature should
not fall below 1580OF (ie, 50OF below the average RTO temperature during performance test)per
NSPS Subpart RR requirements. The permittee is recording the RTO temperature continuously
and has a set point of 1600°F for the RTO. The RTO was operating at 1614 OF during this
inspection. Mr.Wilson stated the solvents from the adhesive coating application line(ES-1)
provide adequate fuel to the RTO to sustain the temperature and very little or no natural gas is
used during production. Mr. Wilson stated they will shut down the RTO if the coating line is not
operating for 2 days or more. Otherwise,natural gas is used to maintain the RTO temperature
even when the coating line(ES-1)is not operating. The RTO has 2 chambers and the exhaust
from the adhesive coating application line(ES-1) alternates between the chambers every 90
seconds. Semi-annual reports were submitted on July 30,2021 and January 11,2022.
Compliance with this stipulation is indicated.
f. Condition A. 7. 15A NCAC 2D .0535, "Notification Requirement"-The facility shall notify
MRO of any excess emissions that last for more than four hours and that result from a
malfunction,breakdowns or any other abnormal conditions.
Observed. Based on a records review and conversation with Mr. Wilson,no excess emissions
have occurred at the facility. Compliance with this stipulation is indicated.
g. Condition A. 8. 15A NCAC 2D .0540, "Fugitive Dust Control Requirement"-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).
Observed. No dust was observed at the facility or beyond the facility's boundary. MRO has not
received any dust complaints about this facility. Compliance with this stipulation is indicated.
h. Condition A. 9. 15A NCAC 2D .1806, "Control and Prohibition of Odorous Emissions" -The
Permittee shall not operate the facility without implementing management practices or installing
and operating odor control equipment sufficient to prevent odorous emissions from the facility
from causing or contributing to objectionable odors beyond the facility's boundary.
Observed.No odors were detected at the facility or beyond the facility's boundary. No odor
complaints have been received by MRO regarding this facility. Compliance with this stipulation
is indicated.
i. Condition A. 10. 15A NCAC 2Q .0315, "Synthetic Minor Facilities"-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," as requested by the Permittee,facility-wide
emissions shall be less than the following:

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Pollutant Emission Limit
(Tons per consecutive 12-month period)
VOC 100
Individual HAPs 10
Total HAN 25
a. Inspection and Maintenance Requirements -
i. Thermal Oxidizer 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. As a
minimum,the Permittee shall perform an annual(for each 12-month period following the
initial inspection) internal inspection of each primary heat exchanger and associated
inlet/outlet valves to ensure structural integrity.
b. Recordkeeping Requirements
i. A log book(in written or electronic format) shall be kept on site for regenerative thermal
oxidizer(CD-1). The Permittee shall record all inspection,maintenance and monitoring
requirements listed above in the log book.
Observed. The RTO started up on October 28,2020. The facility maintains records of all
maintenance performed on the RTO. Maintenance on the RTO was performed on April 26,2021
and March 25,2022. Compliance with this stipulation is indicated.
j. Condition A. 11. 15A NCAC 2Q .0317, "Avoidance Conditions" -In accordance with 15A
NCAC 2Q .0317,to comply with this permit and avoid the applicability of 15A NCAC 2D .0530
"Prevention of Significant Deterioration," as requested by the Permittee, emissions shall be
limited as follows:
Affected Source(s) Pollutant Emission Limit(Tons Per
Consecutive 12-month Period)
Facility Wide VOC 1 250
Observed. The facility tracks their VOC emissions. The rolling 12-month VOC emissions are
less than 5 tons per year. The requirements of the Synthetic Minor condition will be used to
demonstrate compliance with this condition. Compliance with this stipulation is indicated.
k. Condition A. 12. 15A NCAC 2Q .0711, "Emission Rates Requiring a Permit" -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-vertically 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).

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Carcinogens Chronic Acute Systemic Acute
Pollutant (lb/yr) Toxicants Toxicants Irritants
(lb/day) (lb/hr) (lb/hr)
Ethyl acetate (141-78-6) 1 1 1 36
Observed. The facility keeps a spreadsheet which tracks the toxic emission rates and compares
with the applicable TPER limits. The records were reviewed, and the ethyl acetate emissions were
less than 5 lbs/day. Compliance with this stipulation is indicated.
1. Condition A. 13. 15A NCAC 2Q .0711, "Emission Rates Requiring a Permit" - 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 all emission release points are unobstructed and vertically oriented, do not exceed the
Toxic Permit Emission Rates (TPERs) listed in 15A NCAC 2Q .0711(b). 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(b).
Carcinogens Chronic Acute Systemic Acute
Pollutant (lb/yr) Toxicants Toxicants FI(lb/hr)
rritants
(lb/day) (lb/hr)
Acetaldehyde (75-07-0) 1 28.43
Acrolein(107-02-8) 0.08
Ammonia(as NH3) (7664-41-7) 2.84
Benzene (71-43-2) 11.069
Benzo(a)pyrene (Component of
83329/POMTV & 56553/7PAH) 3.044
(50-32-8) F F
Formaldehyde (50-00-0) 0.16
Hexane, n- (110-54-3) 46.3
Toluene (108-88-3) 197.96 F F 58.97
Observed. The facility keeps a spreadsheet which tracks the toxic emission rates and compares
with the applicable TPER limits. The records were reviewed, and the facility appeared to be in
compliance. Compliance with this stipulation is indicated.
8. NSPS/NESHAP Review:
The facility does not have any fire pumps or generators; therefore,the facility is not subject to
NESHAP 4Z.
The facility does not have any gasoline storage tanks;therefore,the facility is not subject to NESHAP
6C.

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The facility has an adhesive coating line which is subject to NSPS Subpart RR. Initial performance
testing was conducted on April 28,2021. The facility appears to be in compliance with this
stipulation.
9. Summary of Changes Needed to the Current Permit:
As noted in the previous inspection report, Permit Condition A.6.c. should be updated to include
language from 40 CFR 60.445(d), "The owner or operator of an affected facility operating at the
conditions specified in § 60.440(b) shall maintain a 12-month record of the amount of solvent applied
in the coating at the facility." The facility is currently keeping these records, but the permit does not
explicitly state this requirement from 40 CFR 60.445.
10. Compliance Assistance Offered Duringthe h�pection:
None
11. Section 112(r)Applicabili1y:
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.
12. Compliance Determination:
Based on my observations, this facility appeared to be in compliance with the applicable air quality
regulations at the time of the inspection.
JEF:
c: MRO File
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