AQ_F_1200204_20210819_CMPL_CAV-Rpt (4)

Zoo Z o y - CAv
NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Jackson Corrugated,LLC
NC Facility ID 1200204
Compliance Assurance Visit(CAV) Report County/FIPS: Burke/023
Date: 08/23/2021
Facility Data Permit Data
Jackson Corrugated, LLC Permit n/a
1000 Chain Drive,Suite 100 Issued n/a
Morganton,NC 28655 Expires n/a
Lat: 35d 42.1890m Long: 81d 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 Nicki Slusser Lee Farris
Plant Manager President/COO Plant Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 08/19/2021
,,/�
Inspector's Name Mamie Colburn
Inspector's Signature: CCU Operating Status Operating
Compliance Status Compliance- inspection
Action Code FCE
Date of Signature: 10 �Iq h'i Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 " HAP
No emissions inventory on record.
* 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:
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.
Required Safety Equipment:
Safety Shoes, Hearing and Eye Protection

Facility Contacts:
I reviewed the contact information from the IBEAM FacFinder report with Mr.Lee Farris. Mr. Farris let
us know that the company,Jackson Corrugated, LLC was in the process of being bought. The new
President is Carr Tydall. He was changed to the authorized contact. His email is
cj ndallLi� jacksonpaper.net.Mr. Farris was asked to send DAQ a letter in writing explaining the new
owners and possible facility name change.
Facility Description:
This facility manufactures corrugated paperboard sheets. The sheets are then shipped to other facilities
for final processing. There are approximately 52 employees at this site, including office staff. The
facility began operations on March 25,2019 and operates 2 shifts Monday-Friday. The first shift
currently works from lam to 4pm and the second shift works from 4pm to 2 am.
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.
Exempt from Air Permitting_
This office received an application from Jackson Corrugated, LLC, a new facility, on September 4,2018
requesting to become a Registered Facility. This office reviewed the application and on September 21,
2018 Jackson Corrugated,LLC became a Registered Facility. 15A NCAC 2Q .0102(e) states that"Any
facility that is not exempted from permitting pursuant to Paragraph(d)of this Rule and whose actual total
aggregate emissions of particulate matter(PMIo), sulfur dioxide,nitrogen oxides,volatile organic
compounds,carbon monoxide, hazardous air pollutants, and toxic air pollutants are greater than or equal
to five tons per year and less than 25 tons per year may register their facility pursuant to 15A NCAC 02D
.0202 instead of obtaining a permit pursuant to 15A NCAC 02Q .0300." Based on the emissions shown
in the table below,the facility qualifies for Registration in lieu of a Permit. The natural gas boiler located
at the facility is exempt from permitting requirements per 2Q.0102.
Facility-Wide Emissions Summary
Pollutant Potential Controlled
Emissions (t )
PM* 2.09
PMIo** 2.09
SOz 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
Compliance Assurance Visit Narrative:
On August 19,20211, Mamie Colburn,traveled to the facility to conduct an annual routine compliance
assurance visit. I contacted the facility via phone on August 18th to arrange a time for my site visit. I
arrived on site at 10 am and was on site for around an hour and a half. I met and toured the facility with
Mr. Lee Farris. Mr. Farris stated that the company was in the process of having a name an ownership

Emissions Equipment Table
Emissions Sources Control Devices Seen on site? In Operation?
starch loading and bin vent filtration Yes, seen in operation—starch was being loaded.
storage operations No VE.
corrugated paper edge cyclonic collection Yes, seen in operation—cyclone was collecting
trimming and bailing scraps. VE approx. 5% from exterior stack.
.........
Emission Sources Observations:
Bin Vent On Starch Silo:
The facility's starch loading, storage operation, and associated bin vent filtration system was observed in
operation with no visible emissions. At the time of my visit,there was a starch truck loading the silo. The
vent could be heard every few minutes and no VE was seen.
The bin vent is located on a very tall starch silo.There was no starch observed on the ground around the silo.
Access to the top of the starch silo and bin vent is by a very tall straight ladder attached to the side of the
silo. There is no safety cage associated with the ladder. A safety harness to access the ladder would be
required. The bin vent can and should be observed from the ground in the back packing lot. Starch is
received twice a week.
Cyclone Collecting Paper Trimmings:
The corrugated paper edge trimming and bailing system and associated cyclonic system was also observed
in operation with approximately 5% or less visible emissions from the exterior stack.No accumulation of
particulate was noticed around the exterior stack. During my visit,the line speed for the main paper
machine was 407 feet per minute. According to Mr. Farris,this machine can be operated up to 1,000 feet
per minute.
Natural Gas Boiler:
The facility operates a 16.7 mm Btu natural gas only exempt process boiler. The boiler was manufactured
in 2015 or 2016 and is therefore subject to NSPS Subpart,Dc. The boiler was observed in operation with no
visible emissions.
Regulatory Requirements Review:
Record Keeping: (15A NCAC 2D .0202) - The facility is required to maintain records on site to establish
that facility-wide annual air pollutant emissions remain below the 25 ton per year threshold level. The
facility is aware of this requirement and will maintain these records.
During the inspection I viewed the natural gas records for the facility, which they had prepared in advance.
Mr. Lee and I discussed the potential for increased production at the facility in the near future. Since the last
visit there has been no change in the permitted process. Production has increased by 25 to 30%. Continued
increased production could move this facility out of the registered facility class into a regular permitted
facility. Compliance indicated.
Department of Environmental Quality Inspections: (NCGS 143-215.3(a)(2))—The facility shall not refuse
entry or access to any authorized representative of the DEQ 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 registration revocation and assessment of civil penalties. There was no
issue with entry into the facility. Compliance indicated.
Particulates from Miscellaneous Industrial Processes: (15A NCAC 2D .0515) - 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=4.1(P)0-"for a process rate,P, less than or equal to
30 tons per hour, or E=55.0(P)`1-40 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.
Control of Visible Emissions: (15A NCAC 2D .0521) -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.
Excess Emissions Notification Requirements: (15A NCAC 2D .0535) -The facility must report excess
emissions of any regulated pollutant lasting more than four(4)hours, and that result from a malfunction,to
the Division of Air Quality by 9 am of the next working day. Since beginning operation in March 2019,the
facility has not had any excess emissions to report. Compliance indicated.
Fugitive Dust Control Requirement: (15A NCAC 2D .0540)-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.
Control Device Requirements: (15A NCAC 2D .0611)-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. The facility will begin
keeping an Inspection and Maintenance logbook(s)for the bin vent filtration and the cyclonic collection
systems. These logbooks were not viewed but invoices for cleaning were viewed. Cyclones were last
cleaned on June 13, 2021 by Mobile Services. The bin vent was also inspected and cleaned by Mobile
Services on this date. Compliance indicated.
Control and Prohibition of Odorous Emissions: (15A NCAC 2D .1806) -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.
NSPS Fuel Records: The facility is required to keep monthly natural gas consumption records for their
exempt boiler. They are using a detailed bill from their natural gas supplier. I reviewed these records
during my visit and found them to be adequate and up to date. No liquid fuel oil and no other generators on
site. Compliance indicated.
Reporting_Requirement: The facility currently has no reporting requirement.
Compliance History:
Jackson Corrugated, LLC has no compliance issues on record.

Stack Test Review: The facility currently has no stack testing requirements.
112R Review: Jackson Corrugated, LLC does not appear to be subject to 112R.
Compliance Assistance: No compliance assistance requested.
Recommendations: Jackson Corrugated, LLC in the process of being bought by a new entity. The name of
the facility may change. It was recommended that details of this new ownership, including name
change and ownership change are submitted to the DAQ regional supervisor in writing.
Conclusion: During the site visit, Jackson Corrugated, LLC appeared to be operating in compliance with
applicable air quality rules.