AQ_F_1200016_20200213_CMPL_CAV-Rpt (4)

I ZOOO 16-CAW
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: 02/14/2020
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: 8ld 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 Richard DeAugustinis Riley Lauth NSPS: Subpart Dc
Production Manager General Manager EHS Regional Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 02/13/2020
Inspector's Name Angela Hopper
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: lJ On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PMIO *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(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
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.

Safety:
Safety Equipment: Safety Shoes,Hearing and Eye Protection
Safety Issues: There are huge rolls of packaging materials be carried around the facility by 1fl 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 on your pants pocket 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 MEAM FacFinder report with facility personnel. No
changes need to be made at this time.
Facility Description:
This facility manufactures and prints corrugated paperboard containers. There are approximately 75
employees at this site. This includes sales and office staff. The facility operates 3 shifts Monday-
Friday. The third shift is a partially staffed shift. The facility may operate on Saturdays, if needed.
Compliance Assurance Visit Narrative:
On February 13,2020,I,Angela Hopper,traveled to the facility to conduct an annual routine compliance
assurance visit. I contacted the facility via telephone on February 1.9, 2020 to arrange a time for my site
visit. I arrived on site at 1:45 pm and was on site for around 30 minutes. I met and toured the facility
with Mr. James Dierdorf,Maintenance Manager. Mr. Mike Stiles,Plant Manager and the Facility
Contact was unavailable during my visit. The facility's last compliance assurance visit was performed
by me,Angela Hopper, on March 5, 2019.
Recent Changes:
In late 2018 and early M19, 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.
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. Dierdorf,production at the facility remains the same since the last visit remains about
the same. After the 2019 site visit, I 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 a
2019 projected emission inventory of actual PM emissions of 3.19 tons and VOC emissions of less than 1

i
ton. Those emissions estimates remain below the air permitting threshold. No changes have been made
in the glue and solvents used at the facility.
Emission Sources:
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. In Compliance.
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 with no visible emissions. The 4 color flexographic
printer/folder/cutter/gluer associated with the smaller simple cyclone was installed in April 2019. In
compliance.
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 Not. 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 was observed
in operation with no visible emission. PSI at the time of my visit was 170 and stack temperature was 390
degrees. According to Mr.Dierdorf,the boiler generally operates at 170psi. Boiler stack can be
observed from the parking lot. In Compliance.
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. This equipment was observed in various states of operation with no
visible emissions. 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
Record Keeping and Reporting Requirement
NSPS Fuel Records:
The facility is required to keep the amounts of each fuel combusted during each month and maintain these
records on site for at least years. These records were not reviewed during this visit. As noted above,the
facility no longer has the capability to bum No.2 fuel oil. Compliance is expected.
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 bum Not. fuel oil,
this report is no longer required and has been removed from the reporting database.

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.