AQ_F_1200086_20220311_PRMT_Permit

t,�s.STATE
ROY COOPER �
Governor
ELIZABETH S. BISER
Secretary -
� eMn an+^
tsse paM,n3f'`
MICHAEL A. ABRACZINSKAS NORTH CAROLINA
Director Environmental Quality
March 11, 2022
Mr. Scott Bartlett
Head of Operations
Siegwerk EIC LLC
1 Quality Products Road
Morganton, NC 28655-4759
Subject: Air Permit No. 05478R13
Siegwerk EIC LLC
Morganton, Burke County,North Carolina
Permit Class: Small
Facility ID# 1200086
Dear Mr. Bartlett:
In accordance with your completed application received March 9, 2022, we are forwarding
herewith Permit No. 05478R13 to Siegwerk EIC LLC, Morganton, Burke County, North Carolina for the construction and operation of air emissions sources or air cleaning devices and
appurtenances. Additionally, any emissions activities determined from your air permit application
as meeting the exemption requirements contained in 15A NCAC 2Q .0102 have been listed for
information purposes as an "ATTACHMENT" to the enclosed air permit. 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. 15013-23,this air permit shall be final and
binding.
You may request modification of your air permit through informal means pursuant to G.S.
150B-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.
North Carolina Department of Environmental Quality Division of Air Quality
Asheville Regional Office 1 2090 U.S.Highway 70 Swannanoa,NC 28778
NCR�rH(,'A�ROL. .P-
DeqarMwdolE"Ao-°"tal0`0tyy a� 828 296.4500 T 1 828.299.7043 F

Mr. Scott Bartlett
March 11, 2022
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 March 11, 2022 until February 28, 2030, 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. Specific changes and additions are summarized
below (note: this list may not include all changes and additions):
• The bagfiflter (ID No. DC-2) installed on the waterborne ink manufacturing operations
has been modified to reflect the new filter size;
• 15A NCAC 2D .0958 "Work Practices for Sources of Volatile Organic Compounds"
has been removed because this regulation is no longer applicable;
• The natural gas boiler has been removed from the "Insignificant/Exempt Activities"
list; and
• The natural gas fired emergency generator has been added to the
"Insignificant/Exempt Activities" list.
Should you have any questions concerning this matter, please contact Michael Koerschner at 828-
296-4550.
Sincerely,
Brendan G. Davey, P.E., Regional Supervisor
Division of Air Quality, NC DEQ
BGD:mfk
Enclosures
c: Asheville Regional Office

NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
DEPARTMENT OF ENVIRONMENTAL QUALITY
DIVISION OF AIR QUALITY
AIR PERMIT NO. 054781113
Issue Date: March 11, 2022 Effective Date: March 11, 2022
Expiration Date: February 28,2030 Replaces Permit: 05478R12
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 2 1 B of Chapter 143, General Statutes of North Carolina(NCGS) as amended, and other
applicable Laws, Rules and Regulations,
Siegwerk EIC LLC
1 Quality Products Road
Morganton, Burke County,North Carolina
Permit Class: Small
Facility ID# 1200086
(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 Description
ES-1 laboratory pigment blending operations DC-1 one bagfilter(250 square feet of filter area)
ES-2 lwaterborne ink manufacturing operations I DC-2 lone bagfilter(2100 square feet of filter area)
ES-4 Idispersion manufacturing operations DC-6 lone bagfilter(2,480 square feet of filter area)
in accordance with the completed application 1200086.21A received March 9, 2022 including any
plans, specifications, previous applications, and other supporting data, all of which are filed with the
Department of Environmental Quality, 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

Permit No. 05478R13
Page 2
2D .0202, 2D .0515, 2D .0521, 2D .0535, 2D .0540, 2D .0611, 2D .1100, 2D .1806, 2Q
.0102 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 application Form A) 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 2029 calendar year.
3. PARTICULATE CONTROL REQUIREMENT - As required by 15A NCAC 2D .0515
"Particulates from Miscellaneous Industrial Processes," particulate matter emissions from
laboratory pigment blending operations (ID No. ES-1), waterborne ink manufacturing
operations (ID No. ES-2) and dispersion manufacturing operations (ID No. ES-4) 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-" for P <=30 tons/hr, or
E = 55 * (P) 0��1 -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 air 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 a visible emissions standard in 15A
NCAC 2D .0524 "New Source Performance Standards" or .1110 "National Emission
Standards for Hazardous Air Pollutants" shall meet that standard instead of the 2D .0521
visible emissions standard.
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,

Permit No. 05478R13
Page 3
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 are received 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. FABRIC FILTER REQUIREMENTS includingcartridge artridge 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 particulate collection device 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.
8. TOXIC AIR POLLUTANT EMISSIONS LIMITATION AND REPORTING
REQUIREMENT- Pursuant to 15A NCAC 2D .1100 "Control of Toxic Air Pollutants," and
in accordance with the approved application for an air toxic compliance demonstration, the
permit limits in the table below shall not be exceeded. The Permittee has submitted a toxic
air pollutant dispersion modeling analysis dated for the facility's toxic air pollutant
emissions as listed in the below table. The modeling analysis was reviewed and approved by
the DAQ Air Quality Analysis Branch(AQAB) in 1991. Placement of the emission sources,

Permit No. 05478R13
Page 4
configuration of the emission points, and operation of the sources shall be in accordance
with the submitted dispersion modeling analysis and should reflect any changes from the
original analysis submittal as outlined in the AQAB review memo.
Affected Source(s) Toxic Air Pollutant Emission Limit'.
ink manufacturing ' Ammonia(as NH3) 20.12 lb/hr
operations (7664-41-7)
Recordkeeping Requirements - To ensure compliance with the above limit, the Permittee
shall track ammonia emissions on a daily basis by monitoring ammonium hydroxide usage.
Records of the estimated daily ammonia emissions shall be maintained at the facility, and
shall be made available to Division of Air Quality personnel upon request.
9. CONTROL AND PROHIBITION OF ODOROUS EMISSIONS - As required by 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.
10. Federal and State Rules Applicable to Sources Exempted from Air Permitting_Requirements
- Your facility is subject to the following federal rule:
40 CFR 63 Subpart ZZZZ [RICE MACT]
which is applicable to the natural gas fired emergency generator (Emission Source ID I-
GEN) listed on the "Insignificant/Exempt Activities" list attached to this permit. The
purpose of this permit condition is to inform you of your compliance obligations to these
applicable rules as they are enforceable.
11. TOXIC AIR POLLUTANT EMISSIONS LIMITATION REQUIREMENT - Pursuant to
15A NCAC 2Q .0711 "Emission Rates Requiring a Permit," for each listed toxic air
pollutants (TAPs) except ammonia(NH3), 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).
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. 05478R13
Page 5
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:
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
Asheville Regional Office
2090 U.S. Highway 70
Swannanoa,NC 28778
828-296-4500
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.
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.

Permit No. 05478R13
Page 6
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 effectuate 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. CHANGES NOT REQUIRING PERMIT REVISIONS - Pursuant to 15A NCAC 02Q
.0318, changes to the facility that are not exempt pursuant to 15A NCAC 02Q .0102 may be
allowed without first modifying an applicable air permit if the change(s) meet(s) the
requirements of 15A NCAC 02Q .0318(b)(1)through (b)(5) and the owner or operator
notifies the Director in writing, using forms provided by the Division, seven calendar days
before the change is made. Within 10 business days of receipt of the notice, the Division
shall notify the owner or operator of its determination of whether the change(s) meet(s) the
requirements of 15A NCAC 02Q .0318(b)(1) through(b)(5).
8. 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.
9. 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.
10. 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.
11. 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.
12. A violation of any term or condition of this permit shall subject the Permittee to enforcement
pursuant to G.S. 143-215.114A, 143-215.114B, and 143-215.114C, including assessment of
civil and/or criminal penalties.
13. 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
out his official duties. Refusal of entry or access may constitute grounds for permit
revocation and assessment of civil penalties.

Permit No. 05478RI3
Page 7
14. 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.
15. 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.
16. 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.
17. 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.
18. 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. Additionally, in accordance with 15A NCAC 2D .0605, the Permittee shall
follow the procedures for obtaining any required audit sample and reporting those results.
Permit issued this the I Ith of March, 2022.
NORTH CAROLINA ENVIRONMENTAL MANAGEMENT COMMISSION
Brendan G. Davey, P.E.
Regional Supervisor
By Authority of the Environmental Management Commission
Air Permit No. 05478R13

ATTACHMENT to Permit No. 05478R13, March 11, 2022
Insignificant/Exempt Activities
Source Exemption Source of Source of Title
Regulation TAPs? V Pollutants?
I-GEN -natural gas-fired emergency
generator (17 kW output) —40 CFR 63 2Q .0102 (h)(5) Yes Yes
Subpart ZZZZ [RICE MALT]
1. Because an activity is exempted from being required to have a permit or permit modification
does not mean that the activity is exempted from an applicable requirement or that the owner
or operator of the source is exempted from demonstrating compliance with any applicable
requirement.
2. When applicable, emissions from stationary source activities identified above shall be
included in determining compliance with the permit requirements for toxic air pollutants
under 15A NCAC 2D .1100 "Control of Toxic Air Pollutants" or 2Q .0711 "Emission Rates
Requiring a Permit."
3. Sample permit conditions showing the regulatory requirements for exempt sources subject to
NESHAP,NSPS, and NCAC rules may be found here:
https://deq.nc.gov/aqper itconditions