AQ_F_1200016_20190305_CMPL_CAV-Rpt (4)

IZouoib - CAV
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: 03/05/2019
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: 8 1 d 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 03/05/2019
Inspector's Name Angela Hopper
Inspector's Signature: r" ) p/�_� Operating Status Operating
Compliance Code Compliance-inspection
(S Action Code FCE
Date of Signature: On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *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.

Safe .
Safety Equipment: Safety Shoes, Hearing and Eye Protection
Safety Issues: There are huge rolls of packaging materials be carried around the facility by lift 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 IBEAM FacFinder report with facility personnel. Mr.
Michael Drugger,the former Production Manager and facility contact,has taken another position within
the company. The new facility contact is the new Production Manager,Mike Stiles. The former
Technical Contact, Scott Reading has also taken another position within the company and Mr. Riley
Lauth is the new Regional EHS Manager and Technical Contact.
Facility Description:
This facility manufactures and prints corrugated paperboard containers. There are approximately 105
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 March 5, 2019,I, Angela Hopper,traveled to the facility to conduct an annual routine compliance
assurance visit. I contacted the facility via telephone on February 18, 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.Mike Stiles. I also did a records review with Mr. Stiles. The facility's last compliance
assurance visit was performed by me,Angela Hopper,on July 19, 2018.
Recent Changes:
Mr. Stiles and I discussed changes at the facility since my last site visit. The previously permitted simple
cyclone(128 inches in diameter)installed on the corrugated box manufacturing waste handling system
has been removed and replaced with anew larger simple cyclone. A small finishing cyclone had also
been added. The finishing cyclone will be 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 hrsignificant/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. Stiles,production at the facility since being exempted from air permitting has increased
only slightly. 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 me a 2019 projected
emission inventory of actual PM emissions of 3.19 tons and VOC emissions of less than 1 ton. These
emissions estimates remain below the air permitting threshold.
Emission Sources:
This facility was previously permitted to operate 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 can be observed from the parking lot. In Compliance.
The recently installed smaller finishing cyclone was not operating at the time of my visit. The equipment
associated with the smaller simple cyclone had not been installed.
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 No2. 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. 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 I
jobs are outsourced
F
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 reviewed during this visit. As noted above,the
facility no longer has the capability to burn No.2 fuel oil. I reviewed the Natural Gas records with Mr.
Stiles and Mr. Lee Oaks, Facility Controller. These records appeared to be adequate and up to date. In
Compliance.
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 burn No2. 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.