AQ_F_1300083_20200521_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Greif Packaging,LLC-Southeastern Packaging
NC Facility ID 1300083
Inspection Report County/FIPS: Cabarrus/025
Date: 05/21/2020
Facility Data Permit Data
Greif Packaging,LLC-Southeastern Packaging Permit 06503/RI 1
2200 Mulberry Road Issued 4/8/2015
Concord,NC 28025 Expires 9/30/2021
Lat: 35d 19.9528m Long: 80d 36.8584m Class/Status Synthetic Minor
SIC: 2653/Corrugated And Solid Fiber Box Permit Status Active
NAICS: 322211 /Corrugated and Solid Fiber Box Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Erik Boyle David Casey Jason Hogle NSPS: 'Subpart De
Safety Coordinator General Manager Maintenance Manager
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 05/21/2020
Inspector's Name Donna Cook
Inspector's Signature: `9aura emA Operating Status Operating
Compliance Code Compliance-inspection
Action Code PCE
Date of Signature: 0512712020 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HAP
2012 0.3915 0.0300 5.16 0.2800 4.33 0.3615 185.90
2007 0.2600 0.0100 3.44 0.1900 2.88 0.2600 123.50
*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

Greif Packaging, LLC—Southeastern Packaging
(name changed to CorrChoice Concord)
May 21,2020
Page 2'
Type Action: _Full Compliance X Partial Compliance _Complaint Other:,
Evaluation Evaluation/Reinspection Investigation
Data Tracking: X Date submitted for initial review 5/27/2020 _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
IBEAM Planning,Next Inspection Date
Directions: From Mooresville Regional Office to Concord,travel via Highway 3 South;turn right on
Odell School Road;turn right at the stop light onto Poplar Tent Road due to the no left turn; make a U
turn at the next stop light; Interstate 85 South; exit off Interstate 85 South onto Exit#49-Bruton Smith
Boulevard/Concord Mills Boulevard; turn left onto Bruton Smith Boulevard;turn right on Highway 29
South; 0.2 mile turn left on Morehead Road; turn left on Highway 49 North;2.6 miles turn left at the stop
light onto the access road ramp to Pharr Mill Road;turn left at stop sign onto Pharr Mill Road; 0.2 mile
turn left onto Speedway Drive; and then immediately turn right onto Mulberry Road. Greif Packaging,
LLC-Southeastern Packaging, Plant No. I and plant office is located 0.1 mile on the left at the address of
2200'Mulberry Road located in Concord. Plant No.2 is located across the street from Plant No. 1. The
street address of Plant No.2 is 2215 Mulberry Road located in Harrisburg.
Safety Equipment: This company requires that a hard hat(bump hat), hearing protection, and safety
glasses be worn by the inspector at this facility, No site inspection was made by me during this partial
inspection.
Safety Issues: During the previous full compliance evaluation conducted on February 13,2019,the
safety issues noted by me were forklift operations inside of this facility
Lat/Lone Coordinates: A review of the "Facilities Regulated by Air Quality" on the DAQ web site
indicates the facility's location is accurate and matches the facility's latitude and longitude coordinates
listed in IBEAM. No changes to the latitude and longitude coordinates of this facility are needed in
IBEAM. The latitude and longitude coordinates of this facility are locked in IBEAM.
Facility/Email Contact Information: The facility and email contacts were verified by Mr. Erik Boyle,
safety coordinator, and Mr.Jason Hogle,maintenance manager,with no changes required in IBEAM.
Compliance history file review:
A Notice of Deficiency(NOD) letter dated May 11,2017 was issued to this company for failure to submit
written notification of the actual date of initial start-up of the boiler (ID No. ES-135) on No. 2 fuel oil,
postmarked within 15 days after such date.
Summary of Phone Conversation with Facility Contacts:
The purpose of this phone call was to conduct a partial air quality inspection without visiting the site

Greif Packaging, LLC—Southeastern Packaging
(name changed to CorrChoice Concord)
May 21,2020
Page 3
because of the travel ban imposed by the Governor due to the ongoing corona virus pandemic. This
facility manufactures corrugated sheets. This company has two plants that are identified as Nos. 1 and 2.
I spoke with Mr. Erik Boyle, safety coordinator, and Mr. Jason Hogle, maintenance manager, by
conducting an online meeting using Microsoft Teams. Mr. Hogle stated that both plant Nos: 1 and 2
operates 24 hours(3 shifts), 5 days per week and 52 weeks per year and are not currently impacted by the
corona virus pandemic.
Mr. Hogle provided records to me by email regarding the inspection and maintenance records for the two
cartridge filters (ID Nos. ES-SS 1 and ES-SS2). Mr. Boyle also provided records to me by email
regarding the monthly and annual amounts of natural gas and No.2 fuel oil combusted in the three
boilers; facility-wide SO2 emissions; and the No. 2 fuel oil curtailment and periodic testing logs. Below
is a summary of the discussions I had with Mr. Hogle and Mr. Boyle.
I informed Mr. Hogle and Mr. Boyle that Air Permit No. 06503RI I would expire on September 30,2021.
I reminded Mr. Hogle and Mr. Boyle that the permit renewal must be submitted at least 90 days prior to
the expiration date of this permit. The permit renewal application must also include an emission
inventory for calendar year 2020. I instructed Mr. Hogle and Mr. Boyle to contact Denise Hayes or
Jennifer Womick of MRO DAQ permitting to discuss any questions or concerns regarding the permit
renewal process.
Mr.Hogle informed me that the name of his company had changed to CorrChoice—Concord. However,
no ownership change of this company had occurred. I instructed Mr. Hogle and Mr. Boyle to submit a
permit application form for the name change. I emailed Mr. Hogle and Mr. Boyle the required forms (A
and AA3)to complete and submit electronically by email to Denise Hayes of MRO DAQ permitting or
[e-mail]_v. I also instructed Mr. Hogle and Mr. Boyle to submit by US mail
the original hard copy application forms for the name change to MRO DAQ office.
Mr.Hogle, Mr. Boyle and I discussed the operational status of the following air emission sources:
Permitted:
• Two cartridge filters (ID Nos. CD-BC3 and CD-BC2) installed one each on two corn starch silos (ID
Nos. ES-SS1 and ES-SS2; 22 tons per hour maximum process rate, each) were in use. The stack
exhausts of each cartridge filter are horizontal and uncapped and located on top of each corn starch
silo; and
• Three natural gas/No. 2 fuel oil-fired boilers (ID Nos. ES-B3, ES-B4 and ES-B5; two at 20.4 million
Btu per hour maximum heat input and one at 21.0 million Btu per hour maximum heat input)were in
use. The stack exhaust of boiler (ID No. ES-B3) is vertical and uncapped. The stack exhausts of
each boiler(ID Nos. ES-B4 and ES-B5) are vertical with a rain cap.
Insignificant/Exemnt Activities:
• Two parts washers (ID Nos. I-PW) using a petroleum distillate solvent was in use to clean various
equipment parts in the maintenance areas of plants Nos. 1 and 2; and
• One aboveground No. 2 fuel oil storage tank(ID No. I-Tank2; 12,000 gallon maximum capacity)was
not in use since No. 2 fuel is the secondary fuel for the boilers.

Greif Packaging, LLC—Southeastern Packaging
(name changed to CorrChoice Concord)
May 21, 2020
Page 4
Mr. Hogle and Mr. Boyle stated that that none of the above referenced equipment has been modified or its
associated exhaust stacks changed since the previous inspection conducted on February 13,2019.
The visible emissions from the emissions sources at this facility are limited to 20%opacity when
averaged over a six-minute period as required by 15A NCAC 2D .0521 "Control of Visible Emissions"
and as specified in permit condition A. 6. This office has not received any visible or fugitive dust
emissions complaints regarding this facility. No evaluation of visible or fugitive dust emissions could be
observed by me due to no on-site inspection. There is a notification requirement in permit condition No.
A. 8. for the reporting of any excess emissions by the permittee. I asked Mr. Hogle and Mr. Boyle if any
excess emissions had occurred at this facility since the last inspection on February 13,2019. Mr.Hogle
stated that no excess emissions had occurred at this facility.
The three boilers are subject to 40 CFR Part 60 NSPS Subpart Dc, since the three boilers were
constructed after June 9, 1989 with a maximum heat input capacity greater than 10 million Btu per hour.
The permittee is required to submit in writing to this office the actual date of initial start-up notification of
a boiler firing on either fuels, natural gas or No. 2 fuel oil,within 15 days after such start-up as required
by NSPS Subpart Dc and specific permit condition A. 7. a. The facility is also required by NSPS Subpart
Dc and specified in permit condition A. 7. to maintain monthly records of the amounts of natural gas and
No.2 fuel oil combusted in the three boilers and submit semiannual reports by January 30 and July 30 for
the previous six month periods indicating that the fuel oil used has a sulfur content below 0.5%by
weight.
This office has received the required start-up notifications for the three boilers. The fuel supplier
certification semi-annual reports due on January 30 and July 30 for the previous six-month period were
received by this office on January 30, 2020 and July 30,2019. The fuel oil certifications indicated that all
the No. 2 fuel oil received from the fuel oil supplier, Barefoot Oil Company of Concord, has a maximum
sulfur content of 15 ppm or 0.0015 percent by weight and then combusted in the three boilers did not
exceed the 0.5 percent by weight of sulfur. Mr. Boyle emailed me an Excel spreadsheet that is used to
track the monthly and yearly totals of natural gas,No.2 fuel oil and facility SO2 emissions.
The three boilers have the potential to emit SO2 emissions greater than 100 tons per year. This facility
requested a limit on the amount of fuel oil combusted in the three boilers in order for the SO2 emissions to
remain below 100 tons per year. The No. 2 fuel oil usage is limited in the synthetic minor permit
condition A. 11. to less than 2,816,000 gallons per consecutive 12-month period when burning fuel that is
0.50 percent by weight of sulfur. The permittee is required to keep records of the monthly and total
annually the amount of No.2 fuel oil combusted and the facility-wide sulfur dioxide emissions. The fuel
oil certification for the No.2 fuel oil shall be kept on-site and made available to DAQ personnel upon
request. The permittee is also required to report the total amount of No. 2 fuel oil combusted and the
facility-wide SO2 emissions with 30 days after each calendar year.
On January 30,2020, this office received the annual actual emissions report for calendar year 2019 from
this company. This company reported that 1,408,260 ccf of natural gas and 207 gallons of No.2 fuel oil
were combusted by the three boilers; and the facility-wide SO2 emissions were 0.050 tons in calendar
year 2019. Mr. Boyle emailed me an Excel spreadsheet that is used to track the monthly and yearly totals
of natural gas,No.2 fuel oil and facility-wide SO2 emissions from January 1, 2020 through March 31,
2020. This company reported for this period as follows: 33,706 ccf of natural gas; 136.5 gallons of No. 2
fuel oil and 0.006 tons of SO2 emissions.
This facility elected to avoid NESHAP Subpart 6J boiler GACT by only burning No. 2 fuel oil in the

Greif Packaging, LLC—Southeastern Packaging
(name changed to CorrChoice Concord)
May 21, 2020
Page 5
three permitted boilers during times of curtailment, gas supply interruptions, startups or for periodic
testing on liquid fuel. The records provided by Mr. Boyle indicated that no curtailment of the three
boilers had occurred in calendar year 2019 through March 31,2020. Mr. Hogle stated that the periodic
testing of each boiler is conducted one hour per month. The periodic testing is not exceeding 48 hours for
each individual boiler in a calendar year. Therefore,the three boilers are not subject to NESHAP Subpart
6J.
The particulate emissions from the two corn starch silos (ID Nos. ES-SS1 and ES-SS2) are each being
controlled by the two cartridge filters (ID Nos. CD-BC3 and CD-BC2). This facility is required by the
permit condition A. 10. to perform annual (for each 12 month period following the initial inspection)
internal inspections of the two cartridge filters and also periodic inspections and maintenance (I&M) of
the two cartridge filters as recommended by the manufacturer. This company is required to keep written
or electronic records of all inspections and maintenance activities along with corrections made and date of
actions in the logbook. The filter logbook shall be kept on-site and made available to DAQ personnel
upon request.
Mr. Hogle stated that the internal inspection and maintenance of the two cartridge filters are being
performed quarterly. Mr. Hogle emailed the cartridge filter logbook to me for review. According to the
log book, the annual internal inspections of two cartridge filters are: 2/10/2020; 11/11/2019; 8/26/19;
5/20/19; and previously on 2/12/19 for ID No. CD-BC3 at Plant No. 1 and 2/10/2020; 10/20/19; 7/14/19;
5/7/19; and previously on 2/7/19 for ID No. CD-BC2 at Plant No. 2. The annual internal inspections of
the two cartridge filters were within the 12 month period time frame as indicated by permit condition A.
10. Tis facility is required by general condition B. 2. to keep records on site for a minimum of five years.
The records of the inspection and maintenance activities for the two cartridge filters are being kept by this
company more than two years.
This facility is limited to the following toxic air pollutant emission rates (TPERs) in 15A NCAC 2Q
.0711 "Emission Rates Requiring a Permit" as specified in permit condition A. 13.:
Pollutant Carcinogens Chronic Acute Systemic Acute
(lb/yr) Toxicants Toxicants Irritants
(lb/day) (lb/hr) (lb/hr)
'Acetaldehyde(75-07-0) F-- I 1 6,8
Acrolein (107-02-8) 'F_F_F_ 0.02 _
Ammonia(as NH3) (7664-41-7) F 0,68
Arsenic&Compounds (total mass of ��
elemental AS, arsine and all inorganic 0.053
compounds)(ASC(7778394))
Benzene(71-43-2) 8.1 ��
Benzo(a)pyrene(Component of.
32-8) POMTV &56553/7PAH) (50- 2.2
32-8)
Beryllium Metal(unreacted) 0 28
(Component of BEC) (7440-41-7)
Cadmium Metal,elemental,unreacted 0.37 —�—�

Greif Packaging,LLC—Southeastern Packaging
(name changed to CorrChoice Concord)
May 21, 2020
Page 6
(Component of CDC)(7440-43-9) iF--- F
Chromium (VI) Soluble Chromate
Compounds(Component of CRC) Fo-o'T
(SOICR6) F '
Fluorides(sum of all fluoride
F
compounds as mass of F ion) (16984- FO.34 0.064
,48-8)
Formaldehyde(50-00-0) F F 0.04
Hexane, n-(110-54-3) _ .FF 23 F�F
Manganese&compounds (MNC) ;F _ 0.63 F—�
Mercury, vapor(Component of HGC)
(7439-97-6) F
Methyl chloroform(71-55_6) _ �- 250 64
Nickel metal(Component of NIC) 0.13
(7440-02-0) 77F- - -
Toluene(108-88-3) 98 __F 14.4
Xylene(mixed isomers)(1330-20-7) 57 16.4
The TPER limits of 2Q .0711(a) are applicable since the exhaust stacks of the three boilers area mixture
of vertical and capped and uncapped. This company operates this facility 24 hours per day, 5 days per
week and 52 weeks per year. The primary fuel of the three boilers is natural gas. No.2 fuel oil is
combustcd only if the three boilers are curtailed or for periodic testing.
Mr.Boyle is tracking the monthly natural gas and No. 2 fuel oil usage in an Excel spreadsheet. A review
of the spreadsheet indicated that the facility-wide natural gas usage was 1,408,260 ccf in calendar year
2019 and 33,709 ccf from January 1 through March 31,2020. The No.2 fuel oil usage was 207 gallons'
in calendar year 2019 and 136.5 gallons from January 1 through March 31,2020. The DAQ combustion
emissions calculator spreadsheets for natural gas and No. 2 fuel oil were used to determine if the above
listed pollutants are being exceeded. The actual emissions from the combustion of natural gas and No.
2 fuel oil in the three boilers during calendar year 2019 and January 1 through March 31, 2020 indicate
that each pollutant is less than the respective TPER limits listed in the above referenced table.
I asked Mr. Hogle if there were any emergency or peak shaving generators/engines or gasoline storage
tanks at this facility. Mr. Hogle stated that there were no diesel-fired/natural gas generators/engines or
gasoline storage tanks at this facility. Mr. Hogle stated that there is an electrically powered fire pump at
plant No.2. The fire pump is not subject to NESHAP Subpart 4Z since it is electrically powered.
This company is also not subject to requirements of the Chemical Accident Release Prevention Program,
Section 112(r) of the Clean Air Act. I also discussed this permit conditions B. Nos. 15 and 16 with Mr.
Hogle and Mr. Boyle. I advised them to answer No to 112(r)inquiries on any permit application forms.
Conclusion:
Based on the conversation with Mr.Hogle and Mr. Boyle and the fuel usage and filter inspection and

Greif Packaging, LLC—Southeastern Packaging
(name changed to CorrChoice Concord)
May 21,2020
Page 7,
maintenance records provided by them,this facility appeared to be operating in compliance with the
current air permit. This facility is operating 24 hours per day, five days per week and not currently
impacted by the COVID-19 virus.
The name of this company has changed to CorrChoice Concord. I discussed the submittal of the permit
application forms for name change with Mr.Hogle and Mr. Boyle and emailed them the required forms. I
instructed them to emailed these forms to Denise Hayes of MRO DAQ permitting or at the email account
Daq.reports-applications@,ncdenr.gov and then submit the original hard copy by mail to MRO DAQ.
I also informed Mr. Hogle and Mr. Boyle that the NSPS Subpart De reporting requirement in permit
condition A. 7. a. iii. is due no later than July 30, 2020 and can be submitted electronically at this time by
either emailing me directly or using the email account [e-mail]. Then the
original hard copy report must be submitted by mail with a postmark date no later than July 30, 2020 to
MRO DAQ.
DLC:Ihe
c: MRO File
hups://neconnect.shmpoint.com/sites/DAQ-MRO/Counties/CABARRUS/00083/INSPECT_PCE_20200521.doc