AQ_F_1200204_20190523_CMPL_CAV-Rpt (4)

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NORTH CAROLINA DIVISION OF Asheville Regional Office
AIR QUALITY Jackson Corrugated,LLC
NC Facility ID 1200204
Compliance Assurance Visit Report County/FIPS: Burke/023
Date: 05/23/2019
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: 35d42.1890m Lon g: 8 1 d 47.803 8m Class/Status Registered
SIC: 2679/Converted Paper Products,Nee 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 05/23/2019
Inspector's Name Angela Hopper
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
Al � e Action Code FCE
Date of Signature: ` On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
No emissions inventory on record.
* Hi est 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:
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. The only
update to the contact information needed at this time is to add Mr. Farris' title of Plant Manager.
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 l lam to 7pm. The facility will change
operating hours for the two shifts in the near future and plans to increase staffing. The first shift will
operate 6am to 4pm and the second shift will operate 4pm to 2am.
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(PM,o), 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
Pogntant O'Ei � �
PM* 2.09
PMio** 2.09
SO2 0.04
NOx 7.18
CO 6.03
VOC 0.39
Total 15.73
Compliance Assurance Visit Narrative:
On May 23,2019,I,Angela Hopper, traveled to the facility to conduct an annual routine compliance
assurance visit. I contacted the facility via e-mail on May 3, 2019 to arrange a time for my site visit. I
arrived on site at 9:50 am and was on site for around 40 minutes. I met and toured the facility with Mr.
Lee Farris. This was the facility's first compliance assurance visit.

Emissions Equipment Table
Emissions Sources Control Devices
F7starch loading and storage operations bin vent filtration
Fcorrugated paper edge trimming and bailing cyclonic collection
Emission Sources Observations:
The facility's starch loading, and storage operation and associated bin vent filtration system was observed
in operation with no visible emissions. 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.
The corrugated paper edge trimming and bailing system and associated cyclonic system was also
observed in operation with no visible emissions. During my visit,the line speed for the main paper
machine was 505 feet per minute. According to Mr. Farris,this machine can be operated up to 1,000 feet
per minute.
The facility operates a 16.7 mmBtu 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. Compliance expected.
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. In Compliance.
Particulates from Miscellaneous Industrial Processes: (I 5A 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.I(P)"'for a process rate,P, less than or equal
to 30 tons per hour, or E=55.0(P)011-40 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 expected.
Control of Visible Emissions: (I 5A NCAC 2D .0521)-Visible emissions from the emission sources at
the facility should not be more than 20 percent opacity. No visible emissions were observed during my
visit. In compliance.

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. In Compliance.
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 expected.
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. Compliance is expected.
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 objectional odors were observed in the area of the facility or on
the facility's property during my visit. Compliance is expected.
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. In compliance.
Reporting Requirement: The facility currently has no reporting requirement.
Compliance History
Jackson Corrugated, LLC is a new facility, and this was the first compliance assurance visit.
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: Since this was the first Compliance Assurance Visit, I went over the facility's
requirements, as a Registered Facility,with him. I asked him to contact our office with any questions.
Recommendations: None
Conclusion: During the site visit, Jackson Corrugated,LLC appeared to be operating in compliance with
applicable air quality rules.