AQ_F_0200037_20210224_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: 02/17/2021
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,Nec 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 Carl Tolbert Mark Hawes NSPS: Subpart RR
Director of Environment Director of North Director of Environment
and Safety American Manufacturing and Safety
[phone] [phone] [phone]
Compliance Data
Comments:
k,AK Inspection Date 02/17/2021
Inspector's Name Denise Hayes
Inspector's Signature: Aube Mxujea Operating Status Operating
Compliance Status Compliance-inspection
Action Code FCE-Offsite
Date of Signature: 02/24/2021 Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2019 0.0100 --- --- 196.96 --- 0.0100 36.15
2018 0.0100 --- --- 195.18 --- 0.0100 36.15
2017 0.0100 --- --- 149.20 --- 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
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation

Shurtape Technologies,LLC—Stony Point
February 17, 2021
Page No. 2
Data Tracking: Date submitted for initial review 02/24/2021 _IBEAM WARNING/OB,NOD,NOV,NRE
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 02/01/2022
Directions: Take I-77 North to 1-40 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.
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 many moving parts in and around the coating units. Also, be aware of
forklift traffic.
Lat/Long: A review of the facility's coordinates on "Maps of DAQ Regulated Facilities" indicates the
facility's latitude and longitude coordinates are accurate. The coordinates are currently not locked in
IBEAM.
COVID-19 Issues: I contacted Mr. Mark Hawes, Director of Environment and Safety, and Jerry Eplin to
discuss the current COVID policies at this facility. Mr. Hawes indicated that visitors are not allowed
onsite. He noted that government employees would be allowed if necessary. Mr. Hawes stated that
masks are required, and that the facility does practice social distancing.
This inspection was performed virtually via Webex and GoPro live streaming due to the current facility's
policies for COVID. Also, there are many areas inside the main production buildings that would not be
sufficient to maintain social distancing. All stacks were observed via GoPro live streaming with no
visible emissions. The records were reviewed via Webex.
Contacts: The authorized, facility, and technical contact emails were verified. There are no changes
needed at the time of this inspection.
1. General Information. The purpose of this inspection was to conduct a full compliance evaluation.
This inspection was performed via Webex and GoPro Live streaming due to COVID-19 restrictions.
The facility is currently not allowing visitors to enter the plant unless they are a vendor or have gone
through specific measures to ensure they have not been affected by the virus. The employees are
required to wear face masks and record their temperatures as they arrive to work.
Shurtape Technologies, LLC (Shurtape) manufactures pressure sensitive tape. No printing is done
on-site. One of the facility's products is a medical tape therefore, the facility has been labeled
"essential" and have continued to operate through the COVID restrictions. The facility has continued
to operate 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. I called into the Webex meeting number with audio and video at 1 pm on February 17, 2021. Mr.
Mark Hawes and Mr. Jerry Eplin from Shurtape also called in for the meeting. Mr. Hawes and Mr.
Eplin were located in their respective offices and called in with audio and video.

Shurtape Technologies,LLC—Stony Point
February 17, 2021
Page No. 3
3. File Review.
A. Contacts. The facility contact list was checked and is current.
B. Files. The following files were reviewed prior to the inspection: current permit, applicability
determinations issued since the most recent permit was issued, and previous inspection
reports. IBeam modules were reviewed to determine if reports were received on time,
emissions inventory was received on time, and any correspondence issued since the last
inspection.
C. Compliance history. There have been no violations or deviations noted in the last five years
by DAQ. The current compliance status is discussed in the following sections.
D. Operating Conditions established by Stack Testing. The facility has not been required to
perform any tests at the time of this inspection.
E. Records Required by Title V. During this inspection, all records required by the Title V
permit were reviewed and appeared to show compliance.
F. NSPS/NESHAP Review
The facility is permitted to operate two tape calenders 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 discussed during this inspection:
A. One tape calender with adhesive release agent application process(ID No. 21)
One film co-extrusion/tape calender with an adhesive release agent application
process(ID No.22)
The tape calender(ID No. 21)was observed not in operation via GoPro Live streaming at
the time of this inspection. The film co-extrusion/tape calender (ID No. 22) was
observed in operation via GoPro Live streaming at the time of this inspection with no

Shurtape Technologies,LLC—Stony Point
February 17, 2021
Page No. 4
visible emissions. For each tape calender, a poly-film is extruded or applied to a cloth
web. A non-VOC (100 percent solid) adhesive is then calendered to the web. After the
adhesive is applied, isopropyl alcohol (IPA) is wicked onto the poly-film 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.
1. Condition 2.1 — A.1. (15A NCAC 2D .0521, "Control of Visible Emissions") - The
tape calenders (ID Nos. 21 and 22) 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 calender(ID No. 22) was observed in operation via GoPro Live
streaming with no visible emissions. The tape calender(ID No. 21)was observed not
in operation via GoPro Live streaming at the time of this inspection. Based on
previous inspections, the tape calender (ID No. 21) can operate with no visible
emissions.
Therefore,the facility appeared to be in compliance with this regulation at the time of
this inspection.
2. Condition 2.1 — A.2. (15A NCAC 2D .0524, "New Source Performance Standards"
as promulgated in 40 CFR 60 Subpart RR) — The calenders are subject to the
requirements of NSPS Subpart RR. The facility has chosen to comply by not causing
the discharge from the tape calenders (ID Nos. 21 and 22) not more than 0.20 kg
VOC/kg of coating solids applied as calculated on a weighted average basis for one
calender 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 monthly 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 via Webex for calendar year
2020. The records appeared to be complete. Mr. Eplin held his device up to the
logbook so I could view the pages. He also turned the pages when I asked for the
next month. The monthly calculated "G" values were observed in the records for
each month with the highest being 0.047. 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 reports were received on July
23, 2021 and January 27, 2021 and appeared to show compliance. The report stated
that no exceedances occurred during the reporting period.
Therefore,the facility appeared to be in compliance with this regulation at the time of
this inspection.

Shurtape Technologies,LLC—Stony Point
February 17, 2021
Page No. 5
3. Condition 2.1 — A.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 consecutive 12-month
period 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 also
required to submit a semi-annual summary report of the monthly VOC emissions.
Observed. The records of monthly VOC emissions were observed via Webex
meeting for calendar year 2020. The records appeared to be complete. The
emissions for each 12-month period were less than the limit of 292.7 tons. The
highest amount observed in the logbook was 188.6 tons per consecutive 12-month
period (January 2020). 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 reports were received on July 23, 2020 and January 27, 2021 and
appeared to show compliance.
Therefore,the facility appeared to be in compliance with this regulation at the time of
this inspection.
5. Part I - AIR QUALITY TITLE V OPERATION PERMIT. Section 3 - GENERAL
CONDITIONS
A. Condition B. - Permit. The facility is required to maintain a copy of the permit and
application at the facility.
Observed. The permit and application were not observed at the time of this inspection.
Based on previous inspections,the facility does maintain these records on site.
B. Condition D. - Submissions. Except as otherwise specified,two copies of all documents,
reports,test data,monitoring data are required to be submitted to MRO.
Observed. The facility typically submits the appropriate number of copies.
C. Condition F. -Circumvention. The facility is required to operate and maintain the facility
at all times in a manner that will affect an overall reduction in air pollution.
Observed. The tape calender (ID No. 22) was observed in operation via GoPro Live
streaming at the time of this inspection with no visible emissions. The facility is
performing the required monitoring to ensure compliance at all times.
D. Condition I.A. and I.B. - Excess Emissions. The facility is required to report excess
emissions and permit deviations.
Observed. The facility indicated that no excess emissions have occurred since the last
inspection.

Shurtape Technologies,LLC—Stony Point
February 17, 2021
Page No. 6
E. Condition K. — Permit Renewal. The facility is required to submit a permit renewal
application at least six months before the date of permit expiration.
Observed. The facility's permit is scheduled to expire on November 30, 2023. The
renewal application will be due during calendar year 2023.
F. Condition O. - 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. The facility is maintaining the required records.
G. Condition P. - Compliance Certification. The facility is required to submit a compliance
certification(for the preceding calendar year)by March 1.
Observed. The most recent compliance certification for calendar year 2019 was received
on February 21, 2020 and appeared to show compliance. The compliance certification
for calendar year 2020 was received on February 22, 2021.
H. Condition X. - Emissions Inventory The facility is required to submit an emissions
inventory by June 30 of each year.
Observed. The most recent emissions inventory was submitted via AERO on June 23,
2020. The signed certification form was postmarked on June 25,2020.
I. Condition CC. -Refrigerant Requirements (Stratospheric Ozone and Climate Protection.
The facility is required to properly dispose of refrigerants.
Observed. The facility maintains a list of the refrigerant containing equipment and uses
only certified technicians to do all refrigerant-related work.
J. Condition DD. - 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.
J. Condition MM. — Fugitive Dust. The facility is required to minimize fugitive dust such
that they do not cause or contribute to substantive complaints or excess visible emissions
beyond the property boundary.
Observed. There were no fugitive dust emissions observed at the time of this inspection.
Based on previous inspections, there is minimal fugitive dust on the plant site. Also,
there have been no complaints received by this office since the last inspection.
6. The following non-permitted air emission sources and control devices were observed as follows:

Shurtape Technologies,LLC—Stony Point
February 17, 2021
Page No. 7
Emission Source ID Emission Source Description Observations
No.
I-31-01 One process solids storage silo and This process was observed not in
conveying system with associated bin operation via GoPro Live
vent cartridge filter(ID No. 1-31-BF- streaming at the time of this
Silo) ins ection.
AI-3I-BLR-1 One natural gas -fired boiler(up to 2.93 This process was observed not in
million Btu per hour maximum heat operation via GoPro Live
input capacity) streaming at the time of this
inspection.
AI-3I-BLR-2 One natural gas -fired boiler(up to 2.76 This process was observed not in
million Btu per hour maximum heat operation via GoPro Live
input capacity) streaming at the time of this
inspection.
I-31-ST-1 One up to 10,000 gallon storage solution Did not observe at the time of
tank this inspection.
1-31-ST-2 One up to 10,000 gallon storage tank Did not observe at the time of
this inspection.
1-31-ST-4 One up to 12,000 gallon storage tank This tank has been removed from
the facility.
1-31-ST-4a One up to 8,000 gallon storage tank Did not observe at the time of
this inspection.
I-31-ST-5 One up to 300 gallon virgin cleaning Did not observe at the time of
solvent tank this inspection.
1-31-ST-6 One up to 500 gallon used cleaning Did not observe at the time of
solvent tank this ins ection.
1-31-LDPE-1 through Four LDPE storage silos(each
1-31-LDPE-4 approximately 6,100 cubic feet volume) Did not observe at the time of
controlled by two bagfilters and this inspection.
associated conveying system
I-PartsCleaner Parts cleaner Did not observe at the time of
this inspection.
I-Corona Corona treater(max 12kW) Did not observe at the time of
this inspection.
I-QA/RD QA and R&D Did not observe at the time of
this inspection.
I-Extruder An extruder Did not observe at the time of
this ins ection.
A. The natural gas-fired boilers (ID Nos. I-31-BLR-1 and 1-31-BLR-2) were observed not in
operation via GoPro Live streaming at the time of this inspection. The boilers were open and
have not been used by this facility in many years. The NCDOL certificate Nos. were
observed to be#33002 for boiler 1 (ID No. 1-31-BLR-1) and#1460 for boiler 2 (ID No. I-31-
BLR-2).
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.

Shurtape Technologies,LLC—Stony Point
February 17, 2021
Page No. 8
8. Summary of changes needed to the current permit:
The insignificant storage tank (ID No. 1-31-ST-4) can be removed from the permit. The
yellowsheet has been updated for this change.
9. Compliance Assistance.
None noted.
10. Findings. Based on my observations during this inspection, this facility appeared to be in
compliance with the applicable air quality regulations.
c: MRO File
DFH:
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/ALEXANDER/00037/INSPECT 20210217.docx