AQ_F_0200037_20220310_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Shurtape Technologies,LLC- Stony Point Plant
NC Facility ID 0200037
Inspection Report County/FIPS:Alexander/003
Date: 03/10/2022
Facility Data Permit Data
Shurtape Technologies,LLC-Stony Point Plant Permit 04648/T12
8510 Highway 90 West Issued 12/12/2018
Stony Point,NC 28678 Expires 11/30/2023
Lat: 35d 51.8760m Long: 8ld 3.0096m Class/Status Title V
SIC: 2672/Paper Coated And Laminated,Nee Permit Status Active
NAILS: 322222/Coated and Laminated Paper Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Mark Hawes Stephen Bradley Mark Hawes NSPS: Subpart RR
Director of EHS-C Plant Manager Director of EHS-C
[phone] [phone] [phone]
IL- IL-
Compliance Data
Comments:
Inspection Date 03/10/2022
Inspector's Name Jim Vanwormer
Inspector's Signature: Operating Status Operating
Compliance Status Compliance-inspection
U �UeDix Action Code FCE
Inspection Result Compliance
Date of Signature: 3/11/2022
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2020 0.0100 --- --- 159.69 --- 0.0100 36.20
2019 0.0100 --- --- 196.96 --- 0.0100 36.15
2018 0.0100 --- --- 195.18 --- 0.0100 36.15
*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

Shurtape Technologies,LLC—Stony Point Plant
March 10,2022
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 3/10/2022 _IBEAM WARNING/OB,NOD,NOV,NRE
Tracking: X IBEAM Document
X IBEAM Inspection,list date inspected X 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 03/01/2023
Directions: Take I-77 North to I-40 west to Exit 148. Turn right onto Highway 64 West. Turn right on
Smith Farms Road and then turn left on Highway 90. The facility is on the left in Stony Point. You will
have to use the phone in the vestibule to gain access.
Safety Equipment: Safety shoes, earplugs, and safety glasses are required. The facility also requests that
the inspector have their state ID visible during the inspection.
Safety Issues: Be aware of forklift traffic inside the warehouse,there is a narrow walkway.
Lat/Lonu: A review of the facility's coordinates in IBeam indicates the facility's latitude and longitude
coordinates are accurate. Latitude and longitude coordinates of this facility are locked in IBEAM.
Email Contacts: The authorized, facility, and technical contact emails were verified. Stephen Bradley is
the new authorized contact,IBEAM has been updated.
COVID-19 Information: There were no issues at the facility.
1. General Information. The purpose of this inspection was to conduct a full compliance evaluation.
Shurtape Technologies, LLC (Shurtape) manufactures pressure sensitive tape. No printing is done
on-site. The facility operates 24 hours per day, seven days per week and will operate 50 weeks this
year. The mailing address for this facility is PO Box 1530,Hickory,NC,28603.
2. 1 arrived at the facility at 8:30 A.M. on March 10, 2022. Mr. Jerry Eplin, Environmental Manager,
provided the facility records. Mr. Rodney Speaks, Environmental technician, Mr. Hawes and Mr.
Eplin all accompanied me on the inspection. I changed the authorized contact in IBEAM to reflect
Mr. Bradley. There were no additional changes to the yellow sheet needed for this facility.
3. File Review.
A. Contacts. Mr. Stephen Bradley was added to IBEAM as the authorized contact.
B. Files. The following files were reviewed prior to the inspection: previous inspection reports;
correspondence since the last inspection; quarterly, semiannual, and annual reports;
complaints; stack test results, annual emissions inventories, etc.
C. Compliance history since 2017. No problems have been noted in the last five years by DAQ,
prior to this inspection. The current compliance status is discussed in the following sections.

Shurtape Technologies,LLC—Stony Point Plant
March 10,2022
Page 3
D. Operating Conditions established by Stack Testing.
E. Records Required by Title V. During this inspection, all records required by the Title V
permit were reviewed. The records appear to be in compliance based on information
submitted. The following personnel assisted in the records review:
F. NSPS/NESHAP Review
The facility is permitted to operate two tape calendars that are subject to NSPS Subpart RR,
"Standards of Performance for Pressure Sensitive Tape and Label Surface Coating
Operations".
The facility is not subject to NESHAP at this time. The permit includes a permit shield for
NESHAP Subpart JJJJ, "NESHAP: Paper and Other Web Coating"because the facility is not
a major source for HAP.
The insignificant list of sources includes two natural gas-fired boilers. As such, they are not
subject to NESHAP Subpart JJJJJJ, "NESHAP for Industrial, Commercial, and Institutional
Boilers Area Sources"because they only fire natural gas.
The facility does not have any internal combustion engines that are subject to NESHAP
Subpart ZZZZ, "NESHAP for Stationary Reciprocating Internal Combustion Engines". The
facility has an electric fire pump on-site which has no applicable requirements.
The facility does not have any gasoline tanks that would be subject to NESHAP Subpart
CCCCCC.
4. Part I - AIR QUALITY TITLE V OPERATION PERMIT. The following permitted emission
sources and/or control devices listed in Section 2 Paragraph 2.1- Emission Source(s) and
Control Devices(s) Specific Limitations and Conditions were observed during this inspection:
A. One tape calender with adhesive release agent application process (ID No. 21) and
one film co-extrusion/tape calender with an adhesive release agent application
process(ID No.22)
Observed.Both calender lines were in operation during the inspection. For each tape
calendar,a poly-film is extruded or applied to a cloth web. A non-VOC(100 percent
solid)adhesive is then calendered to the web. Depending on the product,isopropyl
alcohol(IPA) is wicked onto the poly-firm as a release coat. Some poly-film is purchased
that has a non-volatile release coat material already either on the surface or built into the
matrix of the film. The pre-purchased poly-film reduces the usage of isopropyl alcohol
as the facility does not have to apply their own release coat to this material. Line 21 was
applying IPA during the inspection,but Line 22 was not.

Shurtape Technologies,LLC—Stony Point Plant
March 10,2022
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1. 15A NCAC 2D .0521: Control of Visible Emissions - The tape calendars are
subject to the opacity limit of 20% as set by 2D .0521. There are no monitoring,
recordkeeping, or reporting requirements for this condition.
Observed. The tape calendars were observed in operation during the inspection
without visible emissions. Compliance is indicated.
2. 15A NCAC 2D .0524,New Source Performance Standards as promulgated in 40
CFR 60 Subpart RR — The calendars are subject to the requirements of NSPS
Subpart RR. The facility has chosen to comply by not causing the discharge from the
tape calendars (ID Nos. 21 and 22)to be more than 0.20 kg VOC/kg of coating solids
applied as calculated on a weighted average basis for one calendar month ("G"
value). The facility is required to calculate the monthly weighted average of the mass
of solvent used per mass of coatings applied. The facility is required to maintain a
calendar month record of all coatings used and maintain a 12-month record of the
amount of solvent applied in the coating at the facility. The facility is required to
submit quarterly reports of any exceedances that occur. If no exceedances occur, the
facility is required to submit a semi-annual report stating that there were no
exceedances. The facility is required to submit a semi-annual summary report of the
monitoring and recordkeeping activities.
Observed. The records of the monthly weighted average calculations and 12-month
totals of the amount of solvent applied were observed in the facility binders. The
highest monthly calculated"G" value observed in the records over the past year was
0.04. Mr. Eplin indicated that due to the amount of solids used in the process, the
limit of 0.20 kg VOC/kg of coating solids applied is not likely to be exceeded. The
most recent semi-annual report was received on January 20, 2022 and appeared to
show compliance. The report stated that no exceedances occurred during the
reporting period. Compliance is indicated.
3. 15A NCAC 2Q .0317, "Avoidance Conditions" for the avoidance of 15A NCAC
2D .0530, "Prevention of Significant Deterioration — The facility is subject to a
VOC emissions limit of 292.7 tons per year as set by 2Q .0317 (PSD Avoidance).
The facility is required to calculate the VOC emissions each month and record them
in a logbook. The facility is required to submit a semi-annual summary report of the
monthly VOC emissions.
Observed. The records of monthly VOC emissions were observed in binders during
the inspection and appeared to be complete. The highest amount observed in the
logbook in the last 12 months was 188.6 tons per year (January 2021). The monthly
VOC totals include isopropyl alcohol usage from the two tape calenders (ID Nos. 21
and 22), usage of low VOC run material, and cleaning solvent emissions. Flow
meters are used to monitor isopropyl alcohol usage from the two tape calenders. The
facility assumes 100% VOC content for process oil usage even though the actual
VOC content is 0.6%. The most recent semi-annual report was received on January
20,2022 and appeared to show compliance. Compliance is indicated.

Shurtape Technologies,LLC—Stony Point Plant
March 10,2022
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5. Part I - AIR QUALITY TITLE V OPERATION PERMIT. Section 3 - GENERAL
CONDITIONS
A. Permit. Maintain a copy of the permit and application at the facility. Observed. The
permit and application are at the facility.
B. Submissions. Except as otherwise specified, two copies of all documents, reports, test
data, monitoring data are required to be submitted to MRO. Observed. The company
has been submitting two copies.
C. Circumvention. Operate and maintain the facility at all times in a manner that will effect
an overall reduction in air pollution.
D. Excess Emissions. Report excess emissions and permit deviations as required.
Observed. None reported.
E. Retention of Records. The Permittee shall retain records of all required monitoring data
and supporting information for a period of at least five years from the date of the
monitoring sample, measurement, report, or application. Observed. Records are being
maintained.
F. Compliance Certification. By March 1 submit a compliance certification (for the
preceding calendar year). Observed. Submitted on February 17,2022.
G. Emissions Inventory. Submit an emissions inventory by June 30 of each year.
Observed. Submitted on June 21,2021.
H. Refrigerant Requirements (Stratospheric Ozone and Climate Protection). Dispose of
refrigerants properly. Observed. The facility uses an outside contractor and maintains
documentation that all contractors are certified.
I. Section 112(r). 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.
6. The following non-permitted air emission sources and control devices were observed as follows:
A. A. One process solids storage silo and conveying system(ID No. I-31-01)with associated bin
vent cartridge filter (I-31-BF-Silo) was observed in operation during this inspection with no
visible emissions. The storage silo is for filler material. The filler material is clay or calcium
carbonate and can vary depending on price.
B. Two natural gas-fired boilers (ID Nos. I-31-BLR-1 and I-31-BLR-2) were observed during
this inspection. The boilers have been disconnected and haven't been used by the facility in
10 years.
C. Six storage tanks (ID Nos. I-31-ST-1, I-31-ST-2, I-31-ST-4, I-31-ST-4a, I-31-ST-5, and I-31-
ST-6) are listed as insignificant sources. The storage tank (ID No. I-31-ST-4) has been
removed from the facility. The remaining tanks hold IPA, virgin cleaning solvent, and used
cleaning solvent. The tanks were observed during this inspection.

Shurtape Technologies,LLC—Stony Point Plant
March 10,2022
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D. Four LDPE storage silos and associated conveying system (ID Nos. I-31-LDPE-1 through I-
31-LDPE-4) with associated bagfilters were observed during this inspection with no visible
emissions.
E. One parts cleaner (ID No. I-PartsCleaner) was observed during the inspection. The parts
washer uses Crystal Clean, 100% VOC with no HAPs or TAPs. The cleaner was properly
closed and sealed.
F. One Corona treater(ID No. I-Corona)was not observed during this inspection.
G. A QA and R&D lab (ID No. I-QA/RD)was not observed during this inspection.
H. An extruder(ID No. I-Extruder)was not observed during this inspection.
7. Other compliance requirements and issues:
A. The facility operates a bagfilter that exhausts inside the building. The bagfilter captures
emissions from the Banbury mixer, Sigma Mixer, and dry weigh area. The bagfilter has no
emissions since it only controls particulate emissions and vents indoors.
8. Compliance Assistance.
None noted.
9. Changes Needed to the Air Permit
The insignificant storage tank (ID No. 1-31-ST-4) can be removed from the permit. The
yellowsheet was previously updated for this change.
10. Findings. Based on my observations during this inspection, this facility appeared to be in
compliance with the applicable air quality regulations.
JRV:Ims
c: MRO File
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00037/INSPECT_20220310.docx