AQ_F_1200204_20220510_CMPL_CAV-Rpt (4)

NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Jackson Paper Manufacturing Co
NC Facility ID 1200204
Compliance Assurance Visit Report County/FIPS: Burke/023
Date: 05/16/2022
Facility Data Permit Data
Jackson Paper Manufacturing Co Permit n/a
1000 Chain Drive, Suite 100 Issued n/a
Morganton,NC 28655 Expires n/a
Lat: 35d 42.1890m Long: 8 1 d 47.8038m Class/Status Registered
SIC: 2679/Converted Paper Products,Nec Permit Status Inactive
NAICS: 322211 /Corrugated and Solid Fiber Box Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Lee Farris Lee Farris Lee Farris
Plant Manager Plant Manager Plant Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 05/10/2022
Inspector's Name Mamie Colburn
Inspector's Signature: Operating Status Operating
Compliance Status Compliance- inspection
Action Code FCE
Date of Signature: ( �2 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
No emissions inventory on record.
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
L-
1. Directions: Take I-40 East to exit 98. Turn left onto Causby Road and cross over I-40
and turn left onto the I-40 westbound ramp and turn right onto Chain Drive. Facility is
located at the end of the road. Follow signs to visitor's parking and entrance.

2,Jackson Corrugated, LLC.
2. Facility Overview:
a. Safety: Safety Shoes, Hearing and Eye Protection. Facility has high noise levels
near grinder and cyclone collection system.
b. Facility Contacts: Mr. Farris, plant manager confirmed there are no changes to the
facility contacts. He is the sole and primary contact. The name of the facility has
not changed.
c. Facility Overview: This facility manufactures corrugated paperboard sheets. The
sheets are then shipped to other facilities for final processing into cardboard
boxes.
i. There are approximately 52 employees at this site, including office staff.
ii. The facility began operations on March 25, 2019, and operates 2 shifts
Monday-Friday.
iii. The first shift currently works from lam to 4pm and the second shift
works from 4pm to 2 am.
iv. Process Description: Starch from the silo is blended with other
components to form an adhesive. The adhesive is added to the surface of
kraft paper and run through the corrugator to laminate layers of kraft paper
to create a board. (The facility has stated that the adhesive contains no
VOC.) After drying, the edges are trimmed with the scrap blown through
a single cyclone collector. PM is separated, and the larger scrap is baled.
A natural gas-fired boiler provides process heat, primarily for the drying
process.
d. General Observations:
i. No dust seen upon arrival from the roof stacks, cyclone.
ii. No offsite odors were observed upon arrival.
iii. Records were generally available and well managed.
iv. The facility was running under normal operations.
3. Emission Source Observations:
a. Compliance Assurance Visit Narrative: On May 10, 2022 I arrived at the
facility to conduct a Compliance Assurance Visit (CAV). I met with Mr. Farris
after observing the cyclone from the parking lot. Mr. Farris and I discussed the
air quality registration with the DAQ. He noted they had no major changes in
production or processes since the last visit in 2021. We traveled to the production
floor and saw the cardboard collection system in action. We walked outside and
viewed the outflow of the cyclone. Visible emissions from the dust collection
cyclone were less than approximately 5%. I viewed the starch cyclone and saw no
air quality concerns within or outside the plant.
b. Emission Sources: The facility is listed as a registered facility. The production
budget for 2022 is 1,064,408,000 sq. ft. This should be tracked over time to see if
production increases trigger permit thresholds.

3,Jackson Corrugated, LLC.
......... ..
Emissions Equipment Table
Emissions Control Devices Seen on site? In Operation?
Sources
starch bin vent filtration Yes, seen in operation—holding starch.
loading and No VE.
storage
operations
......._
corrugated cyclonic collection Yes, seen in operation—cyclone was collecting
paper edge scraps. VE less than 5% from exterior stack.
trimming No leaks seen in ductwork.
and bailing
Facility-Wide Emissions Summary
Pollutant Potential Controlled
Emissions t
PM* 2.09
PMIo** 2.09
S02 0.04
NOx 7.18
CO 6.03
VOC 0.39
Total 15.73
*Production Increased by 30% in 2021. Estimated now to be: 20.45 TPY.
No significant production change in 2022.
Production Budget for 2022 is 1,064,408,000 s . ft.
B. VE Observations: Two main sources of visible emissions exist at this facility: the
starch silo bin vent and the cyclone outflow from the cardboard collection system. Both
of these systems were viewed today. Starch arrives twice per week. No visible emissions
were seen from the starch bin vent silo. This silo was holding starch and has periodic air
pulses which were heard. No starch was seen exiting the vent during these air pulses. No
starch was seen in the surrounding area.
The cyclone was in operation and with materials going through the grinder, scraps being
bailed, and air venting off the top of the cyclone. Visible emissions were less than 5%.
All observed ductwork was free of leaks. No material was seen accumulated around the
outlet of the cyclone.
C. Boiler: In addition to the sources listed above, the facility operates a 16.7 mm BTU
natural gas boiler. The boiler was manufactured in 2015/2016 and is subject to NSPS
Subpart, Dc. The boiler was in operations with no visible emissions.
4. Regulatory and Permit Condition Review
a. The facility had an application review for ownership change in April 2022. Mr.
Farris was designated as Authorized Contact for the facility. The name was also

4,Jackson Corrugated, LLC.
changed to Jackson Paper Manufacturing Company dba Jackson Corrugated,
LLC.
b. The facility must comply with the following EMC Regulations:
i. 15A NCAC 2D .0515, "Particulates from Miscellaneous Industrial
Processes"; The allowable particulate emission rate, "E," in pounds per
hour from any stack, vent, or outlet, resulting from industrial processes
shall not exceed the level calculated with the equation E=4.I(P)0.67 for a
process rate, P, less than or equal to 30 tons per hour, or E=55.0(P)0.11-40
when P is greater than 30 tons per hour. "P" equals the process rate in tons
per hour and includes the weight of all materials introduced into any
specific process that may cause any emission of particulate matter. The
facility appeared to be operating properly during my visit. No excess
emissions were observed. Compliance indicated.
ii. 15A NCAC 2D .0521, "Control of Visible Emissions"; Visible emissions
from the emission sources at the facility should not be more than 20
percent opacity. Visible emissions of 5% or less were observed during my
visit from the particulate control cyclone. Compliance indicated.
iii. 15A NCAC 2D .0540, "Particulates from Fugitive Dust Emission
Sources"; The facility shall not cause or allow fugitive dust emissions to
cause or contribute to substantive complaints or excess visible emissions
beyond the property boundary. No fugitive dust was observed during my
visit to the facility. Compliance indicated.
iv. 15A NCAC 2D .0611, "Monitoring Emissions from Other Sources";
Particulates are controlled via the use of a cyclone. The facility must
inspect the bin vent filtration and cyclonic collection systems per the
manufacturer's recommendations, and at a minimum annually, and
maintain a logbook (either written or electronic) on-site of all inspections
and maintenance performed on this control equipment. Mr. Farris and I
discussed this requirement in detail. These items are not required since
the facility is registered and not permitted. These logbooks were not
viewed but invoices for cleaning were viewed. Cyclones were last cleaned
on March 29, 2022 by Mobile Services. Compliance indicated.
v. 15A NCAC 2D .1806, "Control and Prohibition of Odorous Emissions";
The facility shall take suitable measures to prevent odorous emissions
from the facility operations from contributing to objectionable odors
beyond the property boundary. No objectionable odors were observed in
the area of the facility or on the facility's property during my visit.
Compliance indicated.
c. Records reviewed: The facility does not keep a logbook for maintenance of the
cyclones or starch silo. Invoices were reviewed for bin vent service on April 11,
2022 and cyclone maintenance/service on March 29, 2022.
d. Reports received: No annual or semi-annual reports are required.
5. Compliance History Review: The facility has not had any complaints or violations in
the past 5 years.

5,Jackson Corrugated, LLC.
6. Stack Test Review: No stack tests are required or scheduled.
7. 112r Review: Jackson Corrugated, LLC. 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.
8. Compliance Assistance: None recommended at this time.
9. Recommendations: None at this time.
10. Conclusion/Compliance Statement: Based on a review of records and facility site
visit, at the time of this Compliance Assurance Visit, Jackson Corrugated, LLC. appears
to be in compliance with applicable state and federal air quality regulations.