AQ_F_1200016_20211201_CMPL_CAV-Rpt (4)

CAY
NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Packaging Corporation of America
NC Facility ID 1200016
Compliance Assurance Visit Report County/FIPS: Burke/023
Date: 12/03/2021
Facility Data Permit Data
Packaging Corporation of America Permit n/a
114 Dixie Boulevard Issued n/a
Morganton,NC 28655 Expires n/a
Lat: 35d 43.7780m Long: 81 d 44.4970m Class/Status Permit Exempt
SIC: 2653 /Corrugated And Solid Fiber Box 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
Mike Stiles Bret Hatfield Riley Lauth NSPS: Subpart Dc
Production Manager General Manager EHS Regional Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 12/01/2021
Inspector's Name Mamie Colburn
Inspector's Signature: ` (-,V" �i✓ Operating Status Operating
Compliance Status Compliance -inspection
Action Code FCE
Date of Signature: 1 4p Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2016 2.45 0.0700 0.8700 0.8200 1.43 0.0800 63.80
2011 2.32 0.0100 0.6500 1.61 1.10 0.1600 2118.70
* Highest HAP Emitted(in pounds)
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:
Exit 1-40 at the Jamestown exit and turn left. Follow Jamestown road to Dixie Blvd and turn left. Facility
is on the right.
Safe .
Safety Equipment: Safety Shoes,Hearing, Safety Vest, and Eye Protection
Safety Issues: There are huge rolls of packaging materials be carried around the facility by lift trucks.
Caution should be used when touring inside the facility. The facility will provide a safety fork lift warning
beeper to be worn during the tour of the production floor. The beeper is equipped with a clip to be worn.
The beeper light will turn red if a fork lift is close by.
Note machines at the facility are very loud when operating.
The larger cyclone is located on the roof and can only be accessed by a combination of stairs and ladders.
Caution should be used if a roof access is necessary.
Facility Contacts:
I reviewed the contact information from the IBEAM FacFinder report with facility personnel. The
Authorized Contact has changed. Bret Hatfield, is the new general manager and authorized contact.
Facility Description:
This facility manufactures and prints corrugated paperboard containers. There are approximately 70
employees at this site. This includes sales and office staff. The facility operates 3 production shifts
Monday-Friday. The third shift is a partially staffed shift. The facility may operate on Saturdays,if needed.
Compliance Assurance Visit Narrative:
On December 1,2021,1,Mamie Colburn,traveled to the facility to conduct an annual routine compliance
assurance visit. I contacted the facility via email in November to arrange a time for my site visit. I arrived
on site at 11 am. I met and inspected the facility with Mr.Mike Stiles, Production Manager. We first
viewed the exterior cyclones and stacks,then we viewed the boiler,then the interior production lines. Last,
I was escorted to the roof to view the simple cyclone. The facility's last compliance assurance visit was
performed by,Angela Hopper, on February 13,2020.
Recent Changes.
In late 2018 and early 2019, some equipment changes were made at the facility. The previously permitted
simple cyclone (128 inches in diameter) installed on the corrugated box manufacturing waste handling
system was removed and replaced with a new larger simple cyclone. A small finishing cyclone was also
added. The finishing cyclone is associated with a new 4 color flexographic printer/folder/cutter/gluer
operation. A folder/gluer machine previously listed on the facility's Air Permit on the Insignificant/Exempt
Activities list has been removed from the site. Two 2-color slotter printers have also been removed from
the site.No new changes have been made since 2019.
Exempt from Air Permitting
This office received a written request from Packaging Corporation of America on April 13,2017 requesting
rescission of Air Permit 05143R10. This office reviewed the exemption request and on May 3,2017,
Packaging Corporation of America,became exempt from air permitting. The facility's emission
inventories for the last 10 years,consistently document facility wide actual emissions less than 5 tons of
PM and VOCs.

Current Production:
According to Mr. Stiles, production is up 8%over the same time last year. After the 2019 site visit,the
previous inspector requested an estimation of air emissions from Mr. Lauth,Technical Contact, since the
facility had both recently added and removed emission sources. Mr. Lauth sent the previous inspector a
2019 projected emission inventory of actual PM emissions of 3.19 tons and VOC emissions of less than 1
ton. VOC emissions are estimated from the total amount pounds of inks used. Those VOC numbers from
form the paint manufacturer and are tracked in their internal EHS system. Those emissions estimates
remain below the air permitting threshold.
If current production was 3.19 tons of PM and permitting is required at 5 tons,then the facility was at
63.6% of their non-permitted capacity. If production went up by 8%then they are now at 71%of
non-permitted capacity for estimated PM. Should production continue to increase, and capacity get closer
to 100%then permitting should be re-evaluated.
Emission Sources:
Emission — Emission Source I Control j Control System
Source ID j Description System ID 11 Description
ES-WHS
corrugated box manufacturing waste CI,-1 one simple cyclone(156
1handling systems s inches in diameter
ES-B-1 one No.2 fuel oiUnatural gas fired boiler
(NSPS, 1(16.8 million Btu per hour heat input rate) N/A N/A
GACT Avoidance)
Emissions Source: ES-WHS and Control System CY-1—Simple Cyclone
This facility operates one new simple cyclone installed on corrugated box manufacturing waste handling
systems. These waste handling systems consist of ductwork(air pick-up and floor sweep lines)to each box
manufacturing and printing unit to collect scrap paper from the trimming, slotting and cutting of the printed
boxes and from a waste-paper grinder(hog)which is hand fed larger pieces of scrap cardboard. All of this
waste material is transferred pneumatically to the cyclone which discharges the collected material into the
"auto bailer"which forms this material into compact mass roughly the size of an extra-large hay bale
(approximately 6'long x 2 1/2' wide x 3' tall and weighs approximately 1200 pounds). This facility
generates approximately 20—25 bails per day.
All of the waste material from the printing lines and floor sweeps consists of fairly large pieces of cardboard
ranging from 1/4 to several inches in diameter(>> 100 microns). Most of the material from the hog also
consists of large particles(>> 100 microns)although the grinding process does generate a small percentage
of particles that are< 100 microns. The facility no longer is required to maintain an Inspection and
Maintenance Logbook on the cyclone. No visible emissions were observed from the cyclone. The Cyclone
is located on the roof and can be observed from the parking lot.
During this inspection I went onto the roof of the facility to view the cyclone while it was in operation.No
visible emissions were seen.No leaks were seen though some fine dust was evident on the general
ductwork. Compliance is indicated.
Emissions Source: Additional Small Cyclone not in original permit
The facility also operates a small finishing cyclone located outside of the building near the visitor's parking
lot. This cyclone was observed in operation,appeared to be free of leaks and had no visible emissions. The

4-color flexographic printer/folder/cutter/gluer associated with the smaller simple cyclone was installed in
April 2019. Compliance is indicated.
Emissions Source: Natural Gas Boiler
Source Emission Limit(lbs/million Btu)
No.2 fuel oil/natural gas fired boiler(ES-B-1) 0.524
The facility was also previously permitted to operate a No.2 fuel oil/natural gas boiler(16.8 million Btu per
hour heat input rate). This boiler can no longer burn No2. fuel oil. The fuel oil tank was removed from the
site and the fuel oil lines were dug up. The facility is now on non-interruptible service. This boiler was
NSPS. The facility was previously operating under a GACT Avoidance Condition for JJJJJJ(6J) and only
burned No. 2 fuel during periods of natural gas curtailments.
The boiler plate was viewed during the inspection. It listed a 2003 manufacture date; max psi of 250; 2027
square feet of space; and a serial number#10272-01.
During the inspection,the boiler was observed in operation with no visible emissions. PSI at the time of
my visit was 170 and the stack temperature was 375 degrees. According to Mr. Stiles,the boiler generally
operates at 170psi. The boiler stack can be observed from the parking lot.
Annual inspection of the boiler was completed on 6/25/2021 by Power House contractor. It had a quarterly
inspection on 9/22/21 and the next inspection is scheduled for December 15, 2021. Compliance is
indicated.
Other Equipment:
The facility also operates flexographic printers,dye cutters,folder/gluer machines(cold glue),a small parts
washer,starch mixing operation and associated 3,300 cubic feet starch storage silo. Note that the starch silo
has not yet been installed. Starch is stored in bags where were viewed. There are no generators on site.
There is a small welding operation on site. During a previous inspection, DAQ personnel were told that
only spot welding is done on site and larger welding jobs are outsourced.During this visit,I confirmed there
were no changes in the glue and inks used at the facility.
Record Keeping and Reporting Requirement
NSPS Fuel Records:
The facility no longer uses or keeps fuel oil on site.No fuel records available or applicable. Compliance is
indicated.
Semi-Annual Reporting Requirement:
Formally, the facility was required to submit a Fuel Oil Certification/Sulfur Content Report on or by
January 30 and July 30 of each year. Since the facility no longer has the capability to burn No2. fuel oil,
this report is no longer required and has been removed from the reporting database. Compliance is
indicated
Compliance History
Packaging Corporation of America has had no documented violations in the last 5 years.
Stack Test Review:
The facility currently has no stack testing requirements.

112R Review:
Packaging Corporation of America is not subject to 112R.
Compliance Assistance:
None
Recommendations:
None
Conclusion:
During the inspection, Packaging Corporation of America appeared to be operating in compliance with
applicable air quality rules.