AQ_F_1300083_20190213_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY Greif Packaging,LLC-Southeastern Packaging
NC Facility ID 1300083 v
Inspection Report County/FIPS: Cabarrus/025
Date: 02/13/2019
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
NAILS: 322211/Corrugated and Solid Fiber Box Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Josh Petersen Christopher Burrow Josh Petersen NSPS: Subpart Dc
Safety Coordinator General Manager Safety Coordinator
[phone] [phone] [phone]
Compliance Data
Comments:
Inspection Date 02/13/2019 v
Inspector's Name Donna Cook
Inspector's Signature: D Operating Status Operating
r(/ Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: ate- 9 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 Tyne 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
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Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Tracking: X Date submitted for initial review 02/17/2019 _IBEAM WARNING/OB,NOD,NOV,NRE
X IBEAM Document
X IBEAM Inspection, list date inspected f X IBEAM LAT/LONG,Facility Locked
X IBEAM Inspection,list date draft is submitted X IBEAM LAT/LONG,Coordinates checked/ V
X IBEAM Inspection,pollutants/programs checked _IBEAM Complaint
X IBEAM Planning,Next Inspection Date 02/01/2020
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. 1 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.
Safety Issues: Inspector should be cautious of forklift operations inside of this facility
Lat/Long: The facility's coordinates on "Maps of DAQ Regulated Facilities" are not accessible on the
DAQ web site. The latitude and longitude coordinates of this facility in IBEAM are accurate and locked.
Email Contacts: The emails addresses for the authorized, facility, invoice, and technical contacts were
verified by Mr. Josh Petersen, safety coordinator. I changed the email contact for the facility and
technical contacts to Mr. Petersen in IBEAM.
1. The purpose of this site visit was to conduct a routine air quality inspection. Greif Packaging,
LLC- Southeastern Packaging manufactures corrugated sheets. This company has two plants
that are identified as Nos. 1 and 2. Plant No. 1 ceased operations as of May 1,2009. Plant No. 1
resumed operations on May 3,2015,when a new natural gas-fired/No. 2 fuel oil boiler(ID No.
ES-135)became operational to provide steam.to the new corrugator at this facility.
Plant No. 1 operates 24 hours (3 shifts), 5 days per week, and 52 weeks per year. This company
operates a boiler(ID No. ES-135)at Plant No. 1 that is subject to the NSPS requirements of 40
CFR Part 60, Subpart Dc-"Standards of Performance for Small-Industrial-Commercial-
Institutional Steam Generating Units."
Plant No. 2 operates 24 hours (3 shifts), 5 days per week, and 52 weeks per year. This company
operates two boilers(ID Nos. ES-133 and ES-134) at Plant No. 2 that are subject to the NSPS

Greif Packaging,LLC—Southeastern Packaging
February 13, 2019
Page 3
requirements of 40 CFR Part 60, Subpart Dc-"Standards of Performance for Small-Industrial-
Commercial-Institutional Steam Generating Units." Mr. Josh Petersen, safety coordinator, and
Mr. Jason Hogle, maintenance and facilities manager, accompanied us during this inspection.
2. Facility Contact Information:
During the inspection, I verified the facility contact information in IBEAM with Mr. Petersen. I
changed the facility and technical contacts to Mr. Josh Petersen, safety coordinator, in IBEAM.
3. 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.
4. Observations of permitted air emission sources and control devices:
Emission Emission Source Control Control System
Source ID ! Description System ID Description
ES-SS1 corn starch silo (22 tons per CD-BC3 Fcarttr(idge filter(214 square
jIhour maximum process rate) f filter area
dThe corn starch is stored in silo (ID No. ES-SS 1) at Plant 1. The corn starch is mixed with water,
lborax and caustic soda to form an adhesive material in order to bind together the fiber sheets of
(cardboard in the corrugator at Plant No. 1. This company receives one load of corn starch per week
1as indicated by Mr. Petersen.
The pulse jet type cartridge filter(ID No. CD-BC3) captures any particulate matter emissions from
the unloading of cornstarch from the tanker truck into the silo (ID No. ES-SS1)-. Any particulate
matter emissions from the cartridge filter are gravity fed into the silo. The cartridge filter is located
on top of the silo at Plant No. 1. The stack of the cartridge filter is horizontal and uncapped.
iObserved. No tanker truck unloading of corn starch into this silo at Plant No. 1 was occurring at the
time of this inspection. The cartridge filter was not in operation. I observed no visible emissions
from the silo or the cartridge filter at Plant No. 1.
ES-SS2 corn starch silo (22 tons per CD-BC2 cartridge filter(203 square
jhour maximum process rate) feet of filter area)
(The corn starch is stored in silo (ID No. ES-SS2) at Plant 2. The corn starch is mixed with water,
borax and caustic soda to form an adhesive material in order to bind together the fiber sheets of
cardboard in the corrugator at Plant No. 2. This company receives one load of corn starch per week
las indicated by Mr. Peterson.
The pulse jet type cartridge filter(ID No. CD-BC2) captures any particulate matter emissions from
'the unloading of corn starch from the tanker truck into the silo (ID No. ES-SS2). Any particulate
matter emissions from the cartridge filter are gravity fed into the silo. The cartridge filter is located
on top of the silo at Plant No. 2. The stack of the cartridge filter is horizontal and uncapped.
Observed. No tanker truck unloading of corn starch into this silo at Plant No. 2 was occurring at the
,time of the inspection. The cartridge filter was not in operation. I'observed no visible emissions

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Page 4
from the silo or the cartridge filter at Plant No. 2.
ES-B3 (NSPS) natural gas/No. 2 fuel oil-
fired boiler(20.4 million Btu N/A N/A
per hour maximum.heat
input)
The boiler(ID No. ES-B3; company referred to as old boiler ID No. 2) is used to provide steam to
the corrugator at Plant No. 2. Natural gas is the primary fuel of the boiler. No. 2 fuel oil is used as
the backup fuel for the boiler if natural gas is curtailed or an emergency situation occurs at this
facility.
According to the records,the two boilers(ID Nos. ES-B3 and ES-B4) combusted a total of 820, 838
ccf of natural gas in calendar year 2018. No. 2 fuel oil was not combusted in the boiler(ID No. ES-
B3)for curtailment purposes in calendar year 2018. The periodic testing of the boiler(ID No. ES-
B3) is conducted for 30 minutes once a month. The periodic testing is not exceeding 48 hours during
any calendar year.
On the plate of the old boiler ID No. 2 or ES-B3, I observed the following information:
manufacturer, Cleaver Brooks; model number, CBI 200-500-250; serial number, OL-100494; heat
input rate,20,411,600 Btu per hour; manufacturer date, 2000; and oil rating, 145.8 gph) at Plant No.
2. The stack of the boiler is vertical and not capped.
i
Observed. The Cleaver Brooks model boiler#2 or ID No. ES-B3 was in operation on natural gas at
the time of the inspection at Plant No. 2. 1 observed no visible emissions from the exhaust of the
(vertical and uncapped boiler stack.
ES-B4 (NSPS) natural gas/No. 2 fuel oil-
fired boiler(20.4 million Btu N/A N/A
per hour maximum heat
input)
The boiler(ID No. ES-B4; company referred to as new boiler ID No. 1) is used to provide steam to
the corrugator at Plant No. 2. Natural gas is the primary fuel of the boiler. No. 2 fuel oil is used as
the backup fuel for the boiler if natural gas is curtailed or an emergency situation occurs at this
facility.
According to the records,the two boilers (ID Nos. ES-B4 and ES-B3) combusted a total of 820, 838
ccf of natural gas in calendar year 2018. The boiler(ID No. ES-B4)combusted 6,320 gallons of No.
2 fuel oil for 120 hours from January 15 through January 19, 2018 due to curtailment by the supplier,
PSNC, at Plant No. 2. The periodic testing of the boiler(ID No. ES-B4) is conducted for 30 minutes
once a month. The periodic testing is not exceeding 48 hours during any calendar year.
On the plate of the new boiler ID No. 1 or ES-B4,I observed the following information:
manufacturer, Cleaver Brooks; model number, CBLE 200-500-250; serial number, T1305-1-1; heat
input rate,20,412,000 Btu per hour; manufacturer date,2009; and oil rating, 145.8 gph) at Plant No.
2. The stack of the boiler is vertical with a rain cap.
Observed. The Cleaver Brooks model boiler 91 or ES-B4 was not in operation due to an inspection
of this boiler by an outside contractor at Plant No. 2. 1 observed no visible emissions from the
exhaust of the vertical and capped boiler stack.

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February 13,2019
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ES-135 (NSPS) natural gas/No. 2 fuel oil-
fired boiler(21.0 million Btu N/A N/A
per hour maximum heat
input)
The boiler(ID No. ES-135; company referred to as new boiler ID No. 1) is used to provide steam to
the new corrugator at Plant No. 1. Natural gas is the primary fuel of the boiler. No. 2 fuel oil is used
!as the backup fuel for the boiler if natural gas is curtailed or an emergency situation occurs at this
Ifacility.
According to the records,the boiler(ID No. ES-135) combusted 558,788 ccf of natural gas and 0
gallons of No. 2 fuel oil in calendar year 2018. No. 2 fuel oil was not combusted in the boiler for
`'curtailment purposes in calendar year 2018. The periodic testing of the boiler is conducted for 30
minutes once a month. The periodic testing is not exceeding 48 hours during any calendar year.
On the plate of the new boiler ID No. 1 or ES-135, I observed the following information:
manufacturer, Hurst Boiler&Welding Company, Inc.; serial# 82500-250-14; year built 2015; and
17250 steam lbs/hr at Plant No. 1. The stack of the boiler is vertical with a rain cap.
Observed. The Hurst model boiler#1 was in operation on natural gas at the time of the inspection at
Plant No. 1. I observed no visible emissions from the exhaust of the vertical and capped boiler stack.
5. Observations of insignificant air emission sources and control devices listed on the current permit:
Source Exemption Source of Source of Title V
Regulation TAPs? Pollutants?
I-PW-two (2)parts washers ��) 2)�D�(i) No _ Yes
Two parts washers (brand, Selig Industries is the label on each washer)are used to clean various
equipment parts in the maintenance areas at Plant Nos. 1 and 2. One parts washer has a sink/drum
type with a 30 gallon capacity drum underneath it in Plant No. 1. The other parts washer has a sink
with the solvent in the under belly of it at Plant No. 2. There is no drum associated with the parts
washer at Plant No. 2. The two parts washers contained Crystal Clean 142 mineral spirits .
(manufacturer, Heritage-Crystal Clean, LLC; ingredients: distillates-petroleum, hydrotreated light;
located in file of facility). Mr. Jason Hogle, maintenance and facilities manager, estimated the usage
of the two parts washers as five gallons or less per year.
Observed. The two parts washers were not in use at the time of the inspection.
I-Tank2 -No. 2 fuel oil aboveground 2Q .0102
storage tank(12,000 gallon maximum (c)(1)(D)(i) Yes Yes
capacity)
No. 2 fuel oil is the secondary fuel for the two boilers (ID Nos. ES-133 and ES-134)at Plant No. 2.
The No. 2 fuel oil is stored in one horizontal aboveground tank with a capacity of 12,000 gallons.
Observed. The No. 2 fuel oil tank was not in use at the time of the inspection.

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6. Observations of air emission sources and control devices not listed on the current permit:
a. One aboveground vertical tank(10,000 gallon maximum capacity) is used to store the
No. 2 fuel oil for one natural gas-fired/No. 2 fuel oil-fired boiler(ID No. ES-B5) at Plant
No. 1. The No. 2 fuel oil aboveground storage tank(10,000 gallon maximum capacity) is
exempt per 15A NCAC 2Q .0102 (g)(4)..This,tank should be listed in the insignificant/
exempt activities during the next permit revision.
b. This company has one corrugator that is used to corrugate the fiber sheets, bind the fiber
sheets together using glue(corn starch/water/borax/caustic mixture), dry the corrugated
fiber sheets using steam from the two NSPS affected boilers(ID Nos. ES-B3 or#2 and
ES-B4 or#1) at Plant No. 2, and cut excessive trim from the fiber sheets. The corrugator
has no exhaust to the outside atmosphere. During the inspection,the corrugator at Plant
No. 2 was in operation.
At Plant No. 2,the trim from the fiber sheets is picked up from flexible steel pickup lines
on the trim pipe of the corrugator and then transported to an air separator. From the air
separator,the trim is transported to the baler and then baled. Any scrap paper from two
shredders ("hoggers"; referred to as wet end and dry end by this company)and one
pickup vent on the floor are transported via separate fans to the air separator. From the
air separator,the shredded scrap paper is transported to the baler and then baled. The
bales of shredded paper are sent to a paper mill to be recycled.
Any particulate matter emissions from the air separator are transported to the pulse jet
type bagfilter. Underneath the bagfilter,two fifty-five gallon drums are used to collect
any particulate matter.'The bagfilter exhausts inside of the building at Plant No. 2 and
has no pressure relief panels. During the inspection,the air separator,two shredders
("hogs"), one pick up vent on the floor, baler, and pulse jet type bagfilter were in
operation. The photohelic gauge on the bagfilter read 2 inches of water. I observed no
visible emissions from these sources during the inspection.
C. This company has one corrugator that is used to corrugate the fiber sheets, bind the fiber
sheets together using glue(corn starch/water/borax/caustic mixture), dry the corrugated
fiber sheets using steam from the one NSPS affected boiler(ID No. ES-B5) at Plant No.
1, and cut excessive trim from the fiber sheets. The corrugator has no exhaust to the
outside atmosphere. During this inspection,the corrugator at Plant No. 1 was in
operation. I observed no visible emissions from this corrugator at Plant No. 1.
At Plant No. 1,the trim from the fiber sheets is picked up from flexible steel pickup lines
on the trim pipe of the corrugator and the pickup vent on the floor are transported to an
air separator on the roof of this facility. Any scrap paper from two shredders("hoggers";
referred to as wet end and dry end by this company) on the floor are transported via
separate fans to the air separator. From the air separator,the shredded scrap paper is
transported to the baler and then baled. The bales of shredded paper are sent to a paper
mill to be recycled.
Any particulate matter emissions from the air separator are transported to a metal box and
then into the filter system (cloth on the outside of the filter; size unknown). From the
filter system, any dust waste exhausts to a closed-loop cyclone and then through a rotary
valve into a metal box located underneath this cyclone. From the metal box,the dust

Greif Packaging,LLC—Southeastern Packaging
February 13, 2019
Page 7
waste is compressed by a machine into oval brick forms ("pucks"). The oval brick forms
("pucks") are dropped into an open bin and then transported to a landfill. The air from the
cyclone is returned back to the metal box prior to the filter system.
The filter system, closed-loop cyclone, oval brick machine, air separator and baler
exhausts inside of the building at Plant No. 1. During the inspection,the air separator,
two shredders ("hoggers"), baler, filter system, closed-loop cyclone, pickup vent on the
floor and oval brick machine were in operation. I observed no visible emissions from
these sources during the inspection.
d. This company has one electric fire pump located outside of Plant No. 2 in a small
enclosed outbuilding. The electric fire pump was not in operation at the time of the
inspection. The fire pump is not subject to NESHAP Subpart 4Z since it is electrically
powered.
7. Compliance with specific permit conditions and limitations:
a. Condition A. 2. Permit Renewal and Emission Inventory Requirement—The permittee,
at least 90 days prior to the expiration date of this permit, shall request permit renewal by
letter with application form and submit the air pollution emission inventory report with
certification sheet for 2020 calendar year to MRO DAQ.
Observed. I informed Mr. Petersen that the current air permit will expire on September
30, 2021. Compliance with this stipulation is indicated.
b. Condition A. 3. Particulate Control Requirement - As required by 15A NCAC 2D .0503
"Particulates from Fuel Burning Indirect Heat Exchangers," particulate matter emissions
from the fuel burning indirect heat exchangers shall not exceed the allowable emission
rates listed below:
Source Emission Limit
(lbs/million Btu)
natural gas/No. 2 fuel oil-fired boiler(20.4 million Btu per hour 0.41
Imaximum heat input) (ES-133)
inatural gas/No. 2 fuel oil-fired boiler(20.4 million Btu per hour 0.37
(maximum heat input) (ES-134)
Inatural gas/No. 2 fuel oil-fired boiler(21.0 million Btu per hour {-__ 0.37
maximum heat input) (ES-135)
Observed. The particulate matter emissions from the three boilers (ID Nos. ES-133,ES-
B4 and ES-135)while combusting natural gas and No. 2 fuel oil are not exceeding the
allowable emission rates as indicated in the permit review. Compliance with this
stipulation was indicated during the permit application process.
C. Condition A. 4. Particulate Control Requirement - As required by 15A NCAC 2D .0515
"Particulates from Miscellaneous Industrial Processes," particulate matter emissions from
the two corn starch silos (ID Nos. ES-SS1 and ES-SS2) shall not exceed allowable
emission rates.

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Page 8
Observed. The two corn starch silos(ID Nos. ES-SS1 and ES-SS2)are controlled each
by a cartridge filter(ID Nos. CD-BC3 or CD-BC2,respectively). The particulate matter
emissions from the two corn starch silos (ID Nos. ES-SS1 and ES-SS2)are not exceeding
the allowable emissions rates as indicated in the permit review. Compliance with this
stipulation was indicated during the permit application process.
d. Condition A. 5. Sulfur Dioxide Control Requirement-As required by 15A NCAC 2D
.0516 "Sulfur Dioxide Emissions from Combustion Sources,"the sulfur dioxide
emissions from the combustion sources shall not exceed 2.3 pounds per million Btu heat
input.
Observed. Per MRO memo "21) .0516 analysis" dated 04/10/97, compliance is indicated
for No. 1 fuel oil,No. 2 fuel oil, natural gas, butane, propane, and wood fuel. The three
boilers(ID Nos. ES-133,ES-134 and ES-135) are not exceeding the limitation for sulfur
dioxide. Compliance with this stipulation was indicated during the permit application
process.
e. Condition A. 6. Visible Emissions Control Requirement-As required by 15A NCAC 2D
.0521 "Control of Visible Emissions," visible emissions from the emission sources,
manufactured after July 1, 1971, are limited to 20 percent opacity when averaged
over a six-minute period.
Observed. No visible emissions were observed by me at the facility. Compliance with
this stipulation is indicated.
f. Condition A. 7. 15A NCAC 2D .0524 "New Source Performance Standards" -For the
boiler(ID No. ES-133), boiler(ID No. ES-134) and boiler(ID No. ES-135),the permittee
shall comply with all applicable provisions, including the notification,testing,reporting,
recordkeeping, and monitoring requirements contained in Environmental Management
Commission Standard 15A NCAC 2D .0524 "New Source Performance Standards"
(NSPS) as promulgated in 40 CFR 60, Subpart Dc, including Subpart A "General
Provisions".
i. NSPS Reporting Requirements-In addition to any other notification requirements
to the Environmental Protection Agency(EPA), the permittee is required to
NOTIFY the regional supervisor,DAQ, in WRITING, of the following:
A. The date construction(40 CFR 60.7)or reconstruction(40 CFR 60.15)of
an affected source is commenced, postmarked no later than 30 days after
such date. This requirement shall not apply in the case of mass-produced
facilities which are purchased in completed form;
Observed. The new boiler(ID No.ES-135)commenced construction on
April 16, 2015. The new boiler(ID No. ES-135) is considered mass-
produced so the date of construction notification is not required.
Compliance with this stipulation is indicated.
B. The actual date of initial start-up of an affected source, postmarked
within 15 days after such date. If the affected source is permitted to burn

Greif Packaging, LLC—Southeastern Packaging
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Page 9
multiple fuels, then the actual date of start-up, for each fuel, must be
submitted and postmarked within 15 days after such date;
Observed. The new boiler(ID No. ES-135) commenced construction on
April 16, 2015. The actual date of initial start-up for the boiler(ID No.
ES-135) on natural gas was May 3, 2015. The initial start-up notification
for this boiler firing on natural gas was postmarked May 11, 2015 and
received by this office on May 12, 2015. The actual date of initial start-
up of boiler was postmarked within 15 days as required by this condition.
The actual date of initial start-up for the boiler(ID No. ES-135)on No. 2
fuel oil was July 26, 2016 for production purposes. This office received
the initial start-up notification for this boiler firing on No. 2 fuel oil
during an inspection on May 3,2017. A Notice of Deficiency(NOD)
letter dated May 11, 2017 was issued to this company for failure to
submit the start-up notification of this boiler on No. 2 fuel oil
postmarked within the 15 days of start-up as required by NSPS
Subpart Dc and this condition. Compliance with this stipulation is
indicated.
C. The sulfur content of the distillate oil combusted in an affected source
shall not exceed 0.5 percent by weight. Within 30 days after each six-
month period of the calendar year(by January 30 for the previous six-
month period between January and June),the permittee must submit in
writing to the regional supervisor,DAQ,the sulfur content of the
distillate oil combusted in an affected source. If fuel supplier
certification is used to demonstrate compliance, fuel supplier
certification shall include the following information:
1. The name of the oil supplier;
2. A statement from the oil supplier that the oil complies with the
specification under the definition of distillate oil in 40 CFR
60.41(c); and
3. A certified statement signed by the owner or operator of an
affected source that the records of fuel supplier certification
submitted represent all of the fuel combusted during the
reporting period.
Observed. This office received the fuel supplier certification semi-
annual reports on January 23,2019 and July 25, 2018 within the allotted
time frame. The fuel supplier certification submitted by this company
indicated that all the No. 2 fuel oil received from Barefoot Oil Company
of Concord had a maximum sulfur content of 15 ppm or 0.0015 percent
by weight; and then combusted in boilers (ID Nos. ES-133, ES-134 and
ES-135) did not exceed the 0.5 percent by weight of sulfur as specified by
this condition. Compliance with this stipulation is indicated.
ii. NSPS Recordkeeping Requirements -In addition to any other recordkeeping

Greif Packaging,LLC—Southeastern Packaging
February 13, 2019
Page 10
requirements of the EPA,the permittee is required to maintain records as
follows:
A. the amounts of each fuel combusted during each month; and
B. All records required under this section shall be maintained for a period
of two years following the date of such record.
Observed. The records of the natural gas and No. 2 fuel oil combusted in the
three boilers(ID Nos. ES-B3,ES-B4 and ES-B5) are tracked monthly and
annually using an Excel computer spreadsheet by this company. The two boilers
(ID Nos. ES-B3 and ES-B4) at Plant No. 2 combusted a total of 820,838 ccf of
natural gas in calendar year 2018. The boiler(ID No. ES-B4) combusted 6,326
gallons of No. 2 fuel oil from January 15 to January 19,2018 due to the
curtailment. No. 2 fuel oil was not combusted in the boiler(ID No. ES-B3) for
curtailment purposes in calendar year 2018.
The boiler(ID No. ES-B5) at Plant No. 1 combusted 558,788 ccf of natural gas
in calendar year 2018. No. 2 fuel oil was not combusted in the boiler for
curtailment purposes in calendar year 2018. Compliance with this stipulation is
indicated.
iii. NSPS Emissions Limitations -As required by 15A NCAC 2D .0524,the
following permit limits shall not be exceeded:
Affected Source Emission
s) Pollutant Limit
I
t
atural gas/No. 2 fuel oil-fired boiler(20.4 million Btu Sulfur 0.5% by
er hour maximum heat input) (ES-B3) ",content 1weight
Inatural gas/No. 2 fuel oil-fired boiler(20.4 million Btu Sulfur �0.5% by
1per hour maximum heat input)(ES-B4) contentweight
natural gas/No. 2 fuel oil-fired boiler(21.0 million Btu Sulfur 10.5% by
per hour maximum heat input)(ES-B5) content ;,weight
Observed. This company submitted the fuel supplier certification on January 23,
2109 and July 25, 2019 to this office indicating that all the No. 2 fuel oil(ultra
low sulfur diesel-ulsd)received from Barefoot Oil Company of Concord
contained 15 ppm or 0.0015 percent by weight of sulfur and was less than 0.5
percent by weight of sulfur as required by this condition. Compliance with this
stipulation is indicated.
iv. NSPS Performance Testin&-As required by 15A NCAC 2D .0524,the following
performance tests shall be conducted:
Affected Sources) Pollutant_ Test Method
natural gas/No. 2 fuel oil-fired boiler(21.0 million Sulfur fuel supplier
Btu per hour maximum heat input)(ES-B5) �content certification

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Page 11
Observed. The actual date of initial start-up for the boiler(ID No. ES-135)firing
on No. 2 fuel oil occurred on July 26, 2016 for production purposes. This
company is required to submit the fuel supplier certification to MRO DAQ
within 180 days after the initial start-up of this boiler(ID No. ES-135) on No. 2
fuel oil.
This office received the fuel supplier certifications for the No. 2 fuel oil within
the required time frame indicating that the No. 2 fuel oil received from the fuel
oil supplier, Barefoot Oil Company of Concord, contained 15 ppm or 0.0015
percent by weight of sulfur, and then combusted in the boiler(ID Nos. ES-135)
did not exceed the 0.5 percent by weight of sulfur as specified by this condition.
Compliance with this stipulation is indicated.
g. Condition A. 8.Notification Requirement-As required by 15A NCAC 2D .0535,
the permittee of a source of excess emissions that last for more than four hours
and that results from a malfunction, a breakdown of process or control equipment or any
other abnormal conditions, shall notify the Director or his designee of any such
occurrence by 9:00 a.m. Eastern time of the.Division's next business day of becoming
aware of the occurrence.
Observed. Based on records review and the conversation with Mr. Petersen, no excess
emissions have occurred at the facility. Compliance with this stipulation is indicated.
h. Condition A. 9. Fugitive Dust Control Requirement-As required by 15A NCAC 2D
.0540 "Particulates from Fugitive Dust Emission Sources," the permittee shall not cause
or allow fugitive dust emissions to cause or contribute to substantive complaints or
excess visible emissions beyond the property boundary. If substantive complaints or
excessive fugitive dust emissions from the facility are observed beyond the property
boundaries for six minutes in any one hour(using Reference Method 22 in 40 CFR,
Appendix A),the owner or operator may be required to submit a fugitive dust plan as
described in 2D .0540(f).
Observed. MRO DAQ has not received any fugitive dust-emissions complaints
regarding this facility. This company has paved roads at Plant Nos. 1 and 2. There is an
unpaved truck staging area adjacent to Plant No. 2. During the inspection, I observed no
fugitive dust or visible emissions from Plant Nos. 1 and 2. Compliance with this
stipulation is indicated.
i. Condition A. 10. Fabric Filter Requirements including cartridge filters, baghouses, and
other dry filter particulate collection devices-As required by 15A NCAC 2D .0611,the
particulate matter emissions shall be controlled as described in the permitted equipment
list. To comply with the provisions of this permit and ensure that emissions do not
exceed the regulated limits,the permittee shall perform periodic inspections and
maintenance (I&M) as recommended by the manufacturer. In addition,the permittee
shall perform an annual(for each 12 month period following the initial inspection)
internal inspections of the two cartridge filter systems.
A logbook shall be kept on site for the two cartridge filter systems and made available to
Division of Air Quality personnel upon request. The permittee shall record all
inspection, maintenance and monitoring requirements listed above in the logbook. Any

Greif Packaging,LLC—Southeastern Packaging
February 13, 2019
Page 12
variance from the manufacturer's recommendations shall be investigated with corrections
made and date of actions recorded in the logbook.
Observed. Mr. Jason Hogle, maintenance and facilities manager, stated that the
inspection and maintenance activities are being performed quarterly(internal)on
cartridge filter(ID No. CD-BC-3) at Plant No. 1; and monthly(mechanical and internal),
and semi-annual(mechanical)and quarterly(internal)on cartridge filter(ID No. CD-
BC2) at Plant No. 2.
The inspection and maintenance recordkeeping requirements become effective April 10,
2015 for cartridge filter(ID No. CD-BC3) at Plant No. 1. The silo was serviced and
cartridge filter placed in housing by outside contractor by Ringwood on March 3,2015.
The internal inspections of the cartridge filter(ID No. CD-BC3)at Plant No. 1 were on
2/12/19; 11/5/18; 8/8/18; 5/12/18; 2/19/18; 11/15/17; 8/11/17; 5/12/17; and 8/27/16.
The internal inspections of the cartridge filter(ID No. CD-BC2) at Plant No. 2 were on
2/7/19; 10/29/18; 8/12/18; 5/21/18;2/14/18; 6/11/17; 4/21/17; and 12/26/16.
The internal inspections of the two cartridge filters(ID Nos. CD-BC3 and CD-BC2) at
Plant Nos. 1 and 2 are within the 12 month period time frame as indicated by this
condition. This facility is required by General Condition and Limitation B. 2.to keep
records on site for a minimum of two years. The records of the inspection and
maintenance activities for the two cartridge filter(Nos. CD-BC3 and CD-BC2) at Plant
Nos. 1 and 2 are being kept by this company more than two years. Compliance with this
stipulation is indicated.
j. Condition A. 11. Limitation to Avoid 15A NCAC 2Q .0501 -Pursuant to 15A NCAC 2Q
.0315 "Synthetic Minor Facilities,"to avoid the applicability of 15A NCAC 2Q .0501
"Purpose of Section and Requirement for a Permit," as requested by the permittee,
facility-wide emissions shall be less than the following:
i. Operations Restrictions - To ensure emissions do not exceed the limitations,
above,the following restrictions shall apply:
Pollutant Emission Limit
(Tons per consecutive 12-month period)
S02 100
A. The No. 2 fuel oil use shall be less than 2,816,000 gallons per
consecutive 12-month period when burning fuel that is 0.50 percent by
weight sulfur.
B. If multiple fuels are used, emissions should be determined using the sum
of the individual emissions rates.
Observed. The boiler(ID No. ES-134) at Plant No. 2 combusted 6,326 gallons of
No. 2 fuel oil due to curtailment by the natural gas supplier, PSNC Energy,from
January 15 to January 19, 2018. No. 2 fuel oil was not combusted in the boilers
(ID No. ES-133 and ES-13.5) for curtailment purposes in calendar year 2018.

Greif Packaging,LLC—Southeastern Packaging
February 13, 2019
Page 13
The gallons of No. 2 fuel oil combusted by the three boilers (ID Nos. ES-133,ES-
B4 and ES-135)were less than 2,816,000 gallons per consecutive 12-month
period. The sulfur content of the No. 2 fuel oil was reported as 15 ppm or 0.0015
percent by weight of sulfur as certified by the supplier,Barefoot Oil Company of
Concord, on January 23, 2019 and previously on July 25, 2018. Compliance
with this stipulation is indicated.
ii. Recordkeeping Requirements
A. The permittee shall record monthly and total annually the following:
1. No. 2 fuel oil usage, and
2. the facility-wide S02 emissions.
B. Fuel supplier certification shall be kept on-site and made available to
DAQ personnel upon request.
Observed. The natural gas,No. 2 fuel oil and facility-wide sulfur dioxide(S02)
are tracked monthly and annually on an Excel computer spreadsheet by this
company. The fuel supplier certifications are being kept by this company. The
last fuel certification received by this office on January 23, 2019 from supplier,
Barefoot Oil Company of Concord, stated that the sulfur content was 15 ppm or
0.0015 percent by weight. Compliance with this stipulation is indicated.
iii. Reporting Requirements -Within 30 days after each calendar year, regardless of
the actual emissions,the permittee shall submit the following:
A. emissions and/or operational data listed below. The data should include
monthly and 12 month totals for previous 12 month period.
1. The total amount of No. 2 fuel oil combusted, and
2. The facility-wide S02 emissions.
Observed. On January 23, 2019,this office received the annual actual emissions
reports for calendar year 2018 from this company. This company reported that
6,326 gallons of No. 2 fuel oil was combusted in boiler(ID No. ES-134) due to
curtailment purposes in calendar year 2018. The facility-wide S02 emissions
from the combustion of natural gas and No. 2 fuel oil in the boilers were 0.266
tons during calendar year 2018. Compliance with this stipulation is indicated.
k. Condition A. 12. Avoidance Condition for Area Sources Subject to 40 CFR 63 Subpart
JJJJJJ 6J -In accordance with 15A NCAC 2Q .0317,the permittee is avoiding
applicability of 40 CFR 63 Subpart JJJJJJ(6J) "Industrial, Commercial, and Institutional
Boilers Area Sources." The permittee is permitted to operate a natural gas/No. 2 fuel oil-
fired boilers (ID Nos. ES-133,ES-134 and ES-135). Per 40 CFR 63.11195(e),these
sources are exempt from this subpart because they are defined as gas-fired boiler in 40
CFR 63.11237. In order to maintain this exemption,the permittee is allowed to fire
liquid fuel only during periods of gas curtailment, gas supply interruptions, startups, or

Greif Packaging,LLC—Southeastern Packaging
February 13, 2019
Page 14
for periodic testing on liquid fuel (periodic testing not to exceed a combined total of 48
hours during any calendar year).
i. The permittee shall maintain records that document the time periods when liquid
fuel is fired and reasons the liquid fuel is fired.
ii. If the permittee fires liquid fuel for reasons other than gas curtailment, gas supply
interruptions, startups, or for periodic testing on liquid fuel,the Permittee is no
longer exempt from Subpart JJJJJJ(0). As required by 40 CFR 62.11225(g),the
Permittee must provide notice within 30 days of the fuel switch. The notification
must identify:
A. The name of the owner or operator of the affected source,the location of
the source,the boiler(s)that have switched fuels, and the date of the
notice.
B. The date upon which the fuel switch occurred.
C. As required by 40 CFR 63.11210(h),the permittee must demonstrate
compliance within 180 days of the effective date of the fuel switch.
Observed. NCDAQ received the initial notification form from this facility on September
13, 2011, stating that the existing boilers (ID Nos. ES-133 and ES-134; considered existing
if constructed before June 4, 2010) combusts natural gas and only uses No. 2 fuel oil as a
back-up during periods of gas curtailment, gas supply interruptions, startups, and for
periodic testing(not to exceed a combined total of 48 hours during any calendar year).
The boiler(ID No.ES-135) is considered a new area source per NESHAP area boiler
GACT Subpart JJJJJJ(0), since it commenced construction after June 4,2010. During
the permitting process of this boiler(ID No. ES-135),this company chose to avoid
NESHAP Subpart 6J boiler GACT by only burning No .2 fuel oil during times of
curtailment, emergencies and periodic testing. The startup of this boiler firing No. 2 fuel
oil occurred on July 26, 2016.
The boiler(ID No. ES-134)combusted 6,326 gallons of No. 2 fuel oil from January 15 to
January 19, 2018 for 120 hours during to curtailment by the natural gas supplier,PSNC
Energy. The curtailment date recorded by the permittee matches an OFO (operational
flow order)notice issued by the natural gas supplier as shown on their website.
(http://www.I line. williams.com/Transco/index.html). No curtailment of the two boilers
(ID Nos. ES-B3 and ES-135) occurred in calendar year 2018. No curtailment of
natural gas has occurred from January 1, 2019 to present date.
The periodic testing of a boiler is limited to 48 hours during any calendar year. Mr.
Hogle stated that periodic testing of each boiler is conducted for 30 minutes once a
month. The periodic testing of the three boilers ID Nos. ES-133,ES-B4 and ES-135)were
each less than 48 hours in calendar year 2018.
Therefore,the three boilers(ID Nos. ES-133,ES-134 and ES-B5) burning only natural gas
are not subject to the National Emission Standards for Hazardous Air Pollutants
(NESHAP)for Industrial, Commercial, and Institutional Boilers Area Sources(40 CFR

Greif Packaging, LLC—Southeastern Packaging
February 13,2019
Page 15
Part 63, Subpart JJJJJJ or 6J). Compliance with this stipulation is indicated.
1. Condition A. 13. Toxic Air Pollutant Emissions Limitation Requirement-Pursuant to
15A NCAC 2Q .0711 'Emission Rates Requiring a Permit" for each of the below listed
toxic air pollutants (TAPS),the permittee has made a demonstration that facility-wide
actual emissions, where one or more emission release points are obstructed or non-
vertically oriented, do not exceed the Toxic Permit Emission Rates(TPERs) listed in 15A
NCAC 2Q .0711(a). The facility shall be operated and maintained in such a manner that
emissions of any listed TAPs from the facility, including fugitive emissions,will not
exceed TPERs listed in 15A NCAC 2Q .0711(a).
Acute
Chronic i ` Acute
Pollutant Carcinogens Toxicants I Systemic Irritants
(lb/yr) (lb/day) - Toxicants (lb/hr)
(lb/hr)
;Acetaldehyde(75-07-0) �__ j 6.8
Acrolein(107-02-8) �_-..--- '-- - -- 0.02
!Ammonia(as NH3)
1(7664-41-7) 0.68
Arsenic &Compounds
(total mass of elemental
!AS, arsine and all 0.053
;inorganic compounds)
1(ASC (7778394))
Penzene (71-43-2) 8.1
IBenzo(a)pyrene
'(Component of
183329/POMTV & 2.2
'156553/7PAH)(50-32-8)'
IBeryllium Metal
unreacted (Component 0.28
( ) ( P I
ofBEC) (7440-41-7)
.!Cadmium Metal,
!elemental, unreacted 0.37
C(Component of CDC)
1(7440-43-9)
Chromium (VI) Soluble
`Chromate Compounds
((Component of CRC) 0.013
(So1CR6) !
Fluorides (sum of all —^ —
fluoride compounds as 0.34 0.064
mass of ion) (16984-48-
18) _
Formaldehyde(50-00-0) F

Greif Packaging,LLC—Southeastern Packaging
February 13, 2019
Page 16
Hexane,n- (110-54-3) �� ^�� _ 23 �—
�Manganese &compounds 0.63
(MNQ
Mercury, vapor
(Component of HGC) 0.013
(7439-97-6)
Methyl chloroform(71- 250 64
55-6)
Nickel metal(Component 0.13
lof NC) (7440-02-0)
Toluene(108-88-3) .1 98 1 14.4
Xylene(mixed isomers) 57 16.4
(133 0-20-7)
Observed. The TPER limits of 2Q .0711(a)are applicable since the exhaust stacks of the
three boilers are a 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 combusted if the three boilers are
curtailed or periodic testing.
This company is tracking the monthly natural gas and No. 2 fuel oil usage in an Excel
spreadsheet. The facility-wide natural gas usage was 1,379,626 ccf in calendar year
2018. The No. 2 fuel oil usage was 6,326 gallons in calendar year 2018. The DAQ
combustion emissions calculator spreadsheets for natural gas and No. 2 fuel oil were used
to determine if the above listed pollutants were being exceeded. The actual emissions
from the combustion of natural gas and No. 2 fuel oil in the three boilers during calendar
year 2018 indicate that each pollutant is less than the respective TPER limits listed in the
above table. Compliance with this stipulation is indicated.
8. NSPS/NESHAP Review:
a. The three boilers (ID Nos. ES-133,ES-134 and ES-135)burning only natural gas are not
subject to the National Emission Standards for Hazardous Air Pollutants (NESHAP)for
Industrial, Commercial, and Institutional Boilers Area Sources (40 CFR Part 63, Subpart
JJJJJJ or 6J). This company will only burn No. 2 fuel oil in the three boilers (ID Nos.
ES-133,ES-134 and ES-135) during times of gas curtailment, gas supply interruptions,
startups, or for periodic testing(not to exceed combined total of 48 hours per boiler
during any calendar year) (refer to explanation in Condition A. 12).
b. The three boilers (ID Nos. ES-133,ES-134 and ES-B5) are subject to 40 CFR Part 60,
Subpart Dc-"Standards of Performance for Small-Industrial-Commercial-Institutional
Steam Generating Units," since these boilers were constructed after June 9, 1989 with a
maximum heat input capacity greater than 10 million Btu per hour.
C. This company has no emergency or peak shaving engines/generators or gasoline storage
tanks at this facility. The fire pump at Plant No. 2 is not subject to NESHAP Subpart 4Z,
since it is electrically powered.

Greif Packaging,LLC—Southeastern Packaging
February 13, 2019
Page 17
9. Summary of changes needed to the current permit:
a. The No. 2 fuel oil aboveground storage tank (10,000 gallon maximum capacity) should
be listed in the insignificant/exempt activities in permit attachment during the next
revision. The No.2 fuel oil tank is exempt per 15A NCAC 2Q .0102 (g)(4).
b. The electronic yellowsheet for permit changes needed has been completed and placed in
the facility's electronic file.
10. Compliance assistance offered duringthe he inspection: .
None.
11. Section 112(r) applicability:
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.
12. Compliance determination:
Based on my observations, this facility appeared to be in compliance with the applicable air
quality regulations at the time of the inspection.
DLC:lhe
c: MRO File
https://neconnect.sharepoint.com/sites/DAQ-MRO/Counties/CABARRUS/00083/INSPECT_20190213.docx