AQ_F_1300051_20201203_CMPL_InspRpt

NORTH CAROLINA DIVISION OF Mooresville Regional Office
AIR QUALITY S&D Coffee,Inc.
NC Facility ID 1300051
Inspection Report County/FIPS: Cabarrus/025
Date: 12/03/2020
Facility Data Permit Data
S&D Coffee,Inc. Permit 05029/T20
300 Concord Parkway South Issued 5/4/2020
Concord,NC 28027 Expires 3/31/2021
Lat: 35d 23.7312m Long: 80d 36.9372m Class/Status Title V
SIC: 2095/Roasted Coffee Permit Status Active
NAILS: 31192/Coffee and Tea Manufacturing Current Permit Application(s)TV-Renewal
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Zack Bogart Scott Seebold Scott Seebold MACT Part 63: Subpart DDDDD, Subpart ZZZZ
Maintenance Planner and VP of Technical Services VP of Technical Services NSPS: Subpart JJJJ
Scheduler [phone] [phone]
[phone]
Compliance Data
Comments:
Inspection Date 12/03/2020
Inspector's Name Melinda Wolanin
Inspector's Signature:7?'Le64W4 ?(Waa6t J EF Operating Status Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: 12/11/2020 On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2019 12.94 0.0400 7.36 76.77 19.09 12.94 25984.05
2018 12.38 0.0400 6.79 74.75 17.87 12.38 24540.40
2017 12.23 0.0400 6.70 82.33 18.49 12.23 26002.03
*Highest HAP Emitted(in pounds)
Five Year Violation History:
Date Letter Tyne Rule Violated Violation Resolution Date
03/14/2016 NOV Permit Late Title V ACC 03/14/2016
Performed Stack Tests since last FCE:None
Date Test Results Test Method(s) Source(s)Tested

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December 3,2020
Page 2
Type Action: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 12/11/2020 IBEAM WARNING/OB or NOV or NOV/NRE
Tracking: 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
X IBEAM Planning,Next Inspection Date 12/01/2020
Directions: Travel from Mooresville to Concord via Highway 3 South; veer right on Odell School Road;
turn right and make a U-turn to continue east on Poplar Tent Road;turn right on Pitts School Road(first
stop light past Interstate 85); approximately 1 a/lo of a mile off Pitts School Road,turn left onto
Weddington Road; and travel Weddington Road for 4 6/io of a mile. S &D Coffee,Inc. is located on the
left at the corner of Weddington Road and Concord Parkway South(US Highway 29 South). The street
address of this company is 300 Concord Parkway South in Concord.
Safety Equipment: This facility requires and furnishes hairnets for the inspector to wear. A hard hat and
safety glasses are also required. Protective shoes and hearing protection are recommended.
Safety Issues: Be aware of forklift traffic.
Coordinates: Coordinates were checked with no changes needed. The coordinates shown on the
Facilities Regulated by Air Quality map on the air quality website are correct.
Email Contacts: I confirmed that no changes to the contacts was necessary.
COVID Precautions: The facility requires all visitors to undergo a temperature check and to fill out a
health screening form(not a liability waiver). Masks are required. I spoke with Mr. Bogart concerning
COVID protocol before meeting at either S &D Coffee location.
1. The purpose of this site visit was to conduct a routine air quality inspection. I arrived at the
facility around 9:00am on December 3,2020. Before leaving for the inspection,I conducted the
online COVID health screening tool. I completed an on-site inspection which also included
observations made inside the building. This facility processes green coffee beans into roasted
coffee products,including whole and ground beans. This company operates the roasting process
twenty-four hours per day,five to six days a week, and the packaging department sixteen to
twenty hours per day, six days per week, fifty-two weeks per year.Mr.Zack Bogart,Maintenance
Planner and Scheduler,accompanied me during this inspection.According to Mr.Bogart,
production is down due to the response to COVID-19.
2. Facility Contact Information: I confirmed that the contact information is up to date.
3. File Review.
A. Files. The following files were reviewed prior to the inspection: previous inspection
reports; correspondence since the last inspection; quarterly, semiannual, and annual
reports; complaints; stack test results,annual emissions inventories, etc.

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December 3,2020
Page 3
B. Compliance history:
On March 14,2016,the facility was issued an NOV for failure to submit their annual
compliance certification on time.
C. Records Required by Title V. During this inspection, all records required by the Title V
permit were reviewed. The records appear to be in compliance, based on information
submitted.
D. Reporting. All required reports have been submitted since the last inspection and
indicated compliance. Semi-annual reports were received January 27, 2020 and July 27,
2020. Compliance is indicated.
4. Part I - AIR QUALITY TITLE V OPERATION PERMIT. The following permitted emission
sources and/or control devices listed in Section 2 Paragraph 2.1- Emission Source(s) and
Control Devices(s) Specific Limitations and Conditions were observed during this inspection:
A. Coffee bean roasting operations including six (6) roasters and associated cooling and de-stoning
systems
Emission Control
Source Emission Source Description Device Control Device Description
ID No. ID No.
Roaster 1
ES-RI natural gas-fired coffee bean roasting EP-RI-RVC, receiving cyclone(40 inches in diameter)and natural
operation(4.0 million Btu per hour ES-RI-TO gas-fired thermal oxidizer(3.5 million Btu per hour
maximum rated input;4,400 lb/hr maximum rated input)installed in series
maximum process rate)
ES-R1C cooling system(4,400 lbs/hr maximum EP-Rl-C/DC cooling/de-stoning cyclone(21.5 inches in diameter)
process rate)
Roaster 2
ES-R2-New natural gas-fired coffee bean roasting CD-R2-New- Natural gas-fired catalytic oxidizer(3 million Btu per
operation(6.8 million Btu per hour CO hour maximum rated input)
maximum rated input and 4,400 lbs/hr
maximum process rate)
ES-R2C- cooling and de-stoning system(4,400 CD-R2-New- cooling cyclone(63 inches in diameter)and de-stoning
New lbs/hr maximum process rate) CC,CD-R2- cyclone(52 inches in diameter)installed in series
New-DC
Roaster 3
ES-R3 natural gas-fired coffee bean roasting EP-R3-RVC, receiving cyclone(40 inches in diameter)and natural
operation(7.0 million Btu per hour ES-R3-CO gas-fired catalytic oxidizer(2.6 million Btu per hour
maximum rated input and 8,800 lbs/hr maximum rated input)installed in series
maximum process rate)
cooling cyclone(88 inches in diameter)and de-stoning
ES-R3C cooling and de-stoning system(8,800 EP-R3-CC, cyclone(60 inches in diameter)installed in series
lbs/hr maximum process rate) ES-R3-DC

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December 3,2020
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Emission Control
Source Emission Source Description Device Control Device Description
ID No. ID No.
Roaster 4
ES-R4 natural gas-fired specialty coffee bean ES-R4-TO natural gas-fired thermal oxidizer(1.4 million Btu per
roasting operation(0.4 million Btu per hour hour maximum rated input)
maximum heat input;405 pounds per hour
maximum process rate)
Roaster 5
ES-R5 natural gas-fired coffee bean roasting CD-R5-RVC receiving cyclone(88 inches in diameter)and natural
operation(7.0 million Btu per hour CD-R5-CO gas-fired catalytic oxidizer(2.6 million Btu per hour
maximum rated input; 8,800 pounds per maximum rated input)installed in series
hour maximum process rate)
ES-R5C cooling and de-stoning system(8,800 CD-R5-CC cooling cyclone(88 inches in diameter)and de-stoning
lbs/hr maximum process rate) CD-R5-DC cyclone(88 inches in diameter)installed in series
Roaster 6
ES-R6 natural gas-fired coffee bean roasting CD-R6-RVC receiving cyclone(72 inches in diameter)and natural
operation(3.0 million Btu per hour CD-R6-CO gas-fired catalytic oxidizer(4.2 million Btu per hour
maximum heat input,6,850 pounds per maximum heat input)installed in series
hour maximum process rate)
cooling and de-stoning system(6,850 lb/hr CD-R6-CC cooling cyclone(60 inches in diameter and de-stoning
ES-R6C I maximum process rate) I CD-R6-DC I cyclone(36 inches in diameter)installed in series
Observed: The roasters generally operate between 220°F and 450°F. The oxidizers usually run between
800°F to 850°F. There were no visible emissions coming from any of the oxidizers exhausts on the roof. The
roasters have a water quench cycle that emits water vapor from the exhausts,which is visible, at times, from
the stack. The stacks are visible in the baghouse and cycle area behind the building. Roaster 1 (Facility
Reference No. R2000) and Roaster 3 (Facility Reference No. RZ-1) were in operation with no visible
emissions. Roaster 2 (Facility Reference No. J2000), Roaster 5 (Facility Reference No. RZ2), and Roaster 6
(Facility Reference No. R3000-1) were not in operation at the time of the inspection. Roaster 4 (Facility
Reference No. G60) runs small batches and is usually run only every couple of months; it also was not in
operation at the time of the inspection.
Note: Roaster M.No.ES-R2-New(J2000)is not currently operable due to a maintenance accident.
1. 15A NCAC 2D .0515: Particulates from Miscellaneous Industrial Processes
Emissions of particulate matter from this source shall not exceed an allowable emission rate as
calculated by the following equation:
E=4.10 x P 0-61 Where E=allowable emission rate in pounds per hour
P=process weight in tons per hour
The Permittee shall maintain production records,which specify the types of materials and finishes
processed and shall make these records available to a DAQ authorized representative upon
request
Observed: Records are kept in electronic form and were available for review. Compliance is
indicated.

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December 3,2020
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2. 15A NCAC 2D .0516: Sulfur Dioxide Emissions From Combustion Sources
No monitoring/recordkeeping is required for sulfur dioxide emissions from natural gas
combustion for these sources.
Observed: The facility uses natural gas combustion for all roasters. Compliance is indicated.
3. 15A NCAC 2D .0521: Control of Visible Emissions
Visible emissions from the above listed sources shall not be more than 20 percent opacity when
averaged over a six-minute period. To assure compliance, once a month the Permittee shall
observe the emission points of this source for any visible emissions above normal. The results of
the monitoring shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. Submit semiannual reports by January 30
and July 30.
Observed: The facility is making monthly observations on the electronically generated work
order form. The most recent observation occurred on November 24, 2020. There were no
deviations recorded from the previous inspection conducted last December to present. All reports
have been received and indicated compliance.
B. Green bean handling system (ID No. ES-131­11) and associated settling box (ID No. BHI-
SB) and bagfilter(ID No.BHI-BF)
Green bean handling system (ID No. ES-BH2) and associated bagfilters (ID No. CD-B&I
and CD-BF-2)
Observed. Bean handling systems 1 and 2 were not in use at the time of the inspection. The ductwork
appeared to be in good repair. Compliance is indicated.
1. 15A NCAC 2D .0515: Particulates from Miscellaneous Industrial Processes
Particulate matter emissions from the bean handling systems listed above shall be controlled by
bagfilters. To assure compliance,the Permittee shall perform
a. a monthly visual inspection of the system ductwork and material collection unit for leaks; and
b. an annual(for each 12 month period following the initial inspection) internal inspection of
the bagfilter's structural integrity.
The results of inspection and maintenance shall be maintained in a logbook (written or
electronic format) on-site and made available to an authorized representative upon request.
Submit semiannual reports by January 30 and July 30.
Observed: The facility has an electronically generated work order system.Visual observations
and internal inspections are made monthly. The most recent visual inspections of the ductwork
were conducted November 10,2020 for all baghouses. I observed monthly internal inspections
from the last inspection to present. The most recent was dated November 10, 2020. All reports
have been received. Compliance is indicated.

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December 3,2020
Page 6
2. 15A NCAC 2D .0521: Control of Visible Emissions
Visible emissions from the above listed sources shall not be more than 20 percent opacity when
averaged over a six-minute period. To assure compliance, once a month the Permittee shall
observe the emission points of this source for any visible emissions above normal. The results of
the monitoring shall be maintained in a logbook (written or electronic format) on-site and made
available to an authorized representative upon request. The Permittee shall submit a summary
report of the observations postmarked on or before January 30 of each calendar year for the
preceding six-month period between July and December and July 30 of each calendar year for the
preceding six-month period between January and June.
Observed: The facility is making monthly observations on the electronically generated work
order form. The most recent observation occurred on November 24, 2020. All reports have been
received and indicated compliance.
C. Tea leaf mixing and packaging system (ID No. ES-TMP) and associated bagfilter (ID
No. CD-TMP)
Coffee bean grinding and ground coffee conveying/packaging operation (ID No. ES-
CBG/CP) and associated bagfilter(ID No. CD-CBG/CP)
New side green bean handling equipment(ID No.ES-NSGBH) and associated bagfilter
(ID No. CD-NSGBH)
ES-TMP tea leaf mixing and packaging CD-TMP bagfilter(662 square feet of filter
system area)
ES-CBG/CP coffee bean grinding and ground CD- bagfilter(1,180 square feet of filter
coffee conveying/packaging CBG/CP area)
operation
ES-NSGBH New side green bean handling CD-NSGBH bagfilter(1,404 square feet of filter
equipment area)
Observed: These sources were in operation with no visible emissions at the time of the inspection.
1. 15A NCAC 2D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES
a. Emissions of particulate matter from these emission sources(ID Nos.ES-TMP,ES-
CBG/CP, and ES-NSGBH) shall not exceed an allowable emission rate as calculated by the
equation listed in the permit.
Monitoring/Recordkeepin�
b. Particulate matter emissions from these emission sources(ID Nos.ES-TMP,ES-CBG/CP,
and ES-NSGBH) shall be controlled by bagfilters(ID Nos. CD-TMP,CD-CBG/CP, and
CD-NSGBH). To assure compliance,the Permittee shall perform inspections and
maintenance as recommended by the manufacturer. In addition to the manufacturer's
inspection and maintenance recommendations,or if there are no manufacturer's inspection
and maintenance recommendations, as a minimum,the inspection and maintenance
requirement shall include the following:

S&D Coffee,Inc.
December 3,2020
Page 7
i. a monthly visual inspection of the system ductwork and material collection unit for leaks;
and
ii. an annual(for each 12 month period following the initial inspection) internal inspection
of the bagfilter's structural integrity.
c. The results of inspection and maintenance shall be maintained in a logbook(written or
electronic format) on-site and made available to an authorized representative upon request.
The logbook shall record the information outlined in the permit.
Reporting
d. The Permittee shall submit the results of any maintenance performed on the bagfilters within
30 days of a written request by the DAQ.
e. The Permittee shall submit a summary report of monitoring and recordkeeping activities
postmarked on or before January 30 of each calendar year for the preceding six-month period
between July and December and July 30 of each calendar year for the preceding six-month
period between January and June. All instances of deviations from the requirements of this
permit must be clearly identified.
Observed: The facility has an electronically generated work order system.Visual
observations are made weekly and internal inspections are made monthly. The most recent
visual inspections of the ductwork were conducted November 5, 2020 for all baghouses. I
observed monthly internal inspections from the last inspection to present. The most recent
was dated November 5,2020. All reports have been received. Compliance is indicated.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from above listed sources shall not be more than 20 percent opacity when
averaged over a six-minute period. However, six-minute averaging periods may exceed 20
percent not more than once in any hour and not more than four times in any 24-hour period.
In no event shall the six-minute average exceed 87 percent opacity.
Monitoring
b. To assure compliance, once a month the Permittee shall observe the emission points of these
emission sources(ID Nos.ES-TMP,ES-CBG/CP,and ES-NSGBH) for any visible
emissions above normal. The monthly observation must be made for each month of the
calendar year period to ensure compliance with this requirement. The Permittee shall
establish"normal"for these sources within the first 30 days following the effective date of
the emission sources venting to the atmosphere. If visible emissions from this source are
observed to be above normal,the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and
within the monitoring period and record the action taken as provided in the recordkeeping
requirements below, or
ii. demonstrate that the percent opacity from the emission points of the emission source in
accordance with 15A NCAC 2D .2610(Method 9) for 12 minutes is below the limit
given in Section 2.1 C.2. a. of the air permit.

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December 3,2020
Page 8
Recordkeeuing
c. The results of the monitoring shall be maintained in a logbook(written or electronic format)
on-site and made available to an authorized representative upon request. The logbook shall
record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were
observed to be in noncompliance along with any corrective actions taken to reduce
visible emissions; and
iii. the results of any corrective actions performed.
Reporting
d. The Permittee shall submit a summary report of the observations postmarked on or before
January 30 of each calendar year for the preceding six-month period between July and
December and July 30 of each calendar year for the preceding six-month period between
January and June. All instances of deviations from the requirements of this permit must be
clearly identified.
Observed: The facility makes monthly VE observations for ES-CBG/CP, and ES-NSGBH; the
most recent observation occurred on November 24, 2020. See next section for observations of
ES-TMP. All reports have been received and indicated compliance.
3. 15A NCAC 02D .0614: COMPLIANCE ASSURANCE MONITORING
a. For source ES-TMP and associated bagfilter CD-TMP, the Permittee shall comply with 40
CFR Part 64 pursuant to 15A NCAC 02D .0614 to assure that the listed sources comply with
the emission limits of 15A NCAC 02D .0515.
b. To assure compliance, particulate matter and visible emissions from source ES-TMP shall be
controlled by bagfilter CD-TMP as listed in the air permit.
Monitoring/Recordkeeping
c. To assure compliance for sources ES-TMP,the Permittee shall:
i. Conduct daily monitoring of visible emissions from bagfilter (CD-TMP) using EPA
Reference Method 22. This monitoring shall be performed by personnel familiar with
EPA Reference Method 22. If visible emissions are observed from the bagfilter, then an
excursion has occurred;
ii. Perform the monitoring requirements found in Sections 2.1 C.l.c of the air permit for
bagfilter CD-TMP; and
iii. In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable. If bagfilter CD-TMP operates under conditions with a
QIP threshold of ten excursions in a 6-month reporting period from source ES-TMP,then
the Permittee shall develop a Quality Improvement Plan in accordance with 40 CFR§64.

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December 3,2020
Page 9
iv. In the event of an excursion the Permittee shall take appropriate action to correct the
excursion as soon as practicable. If a source or bagfilter listed in Section 2.1 C.1., of the
air permit operates with more than ten excursions in a semiannual reporting period, then
the Permittee shall develop a Quality Improvement Plan (QIP) in accordance with 40
CFR§64.8.
v. The results of monitoring, inspections, maintenance, calibrations and corrections
conducted pursuant to Sections 2.1.C.3.c.i and ii of the air permit shall be maintained in a
logbook (written or electronic format) on-site and made available to an authorized
representative upon request. The logbook shall record the following:
(A)The date and time of each recorded action;
(B) The results of visible emissions monitoring, noting any excursions along with any
corrective actions taken to reduce visible emissions;
(C) The results of any inspections or maintenance performed on the bagfilters; and
(D)Any variance from manufacturer's recommendations, if any, and corrections made.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0614 if this
monitoring and recordkeeping is not conducted.
Reporting
d. The Permittee shall submit a summary report of the monitoring postmarked or delivered on or
before January 30 of each calendar year for the preceding six-month period between July and
December and July 30 of each calendar year for the preceding six-month period between
January and June. All instances of deviations from the requirements of this permit must be
clearly identified. The first report is due by July 30, 2016 covering the period from the
issuance date of this permit to the end of the semiannual period. The report shall also include
the following information,as applicable:
i. Summary information on the number, duration and cause (including unknown cause, if
applicable)of excursions or exceedances,as applicable,and the corrective actions taken;
ii. Summary information on the number, duration and cause (including unknown cause, if
applicable) for monitor downtime incidents (other than downtime associated with zero and
span or other daily calibration checks,if applicable);and
iii. A description of the actions taken to implement a QIP during the reporting period as
specified in 40 CFR 64.8. Upon completion of a QIP, the owner or operator shall include
in the next summary report documentation that the implementation of the plan has been
completed and reduced the likelihood of similar levels of excursions or exceedances
occurring.
Observed: These sources began to vent outdoors in April 2018. The facility has been keeping
daily VE observations with no excursions noted. I observed the daily records through
November 27, 2020. Summary reports were received January 27, 2020 and July 27, 2020
with compliance indicated. Compliance with this condition is indicated.

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December 3,2020
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D. One natural gas-fired 130 kW emergency generator (ID No. ES-EG)
1. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION
SOURCES
a. Emissions of sulfur dioxide from the emergency generator (ID No. ES-EG) shall not exceed
2.3 pounds per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in
fuels, wastes, ores, and other substances shall be included when determining compliance with
this standard.
Testing
b. If emissions testing is required, the testing shall be performed in accordance with General
Condition JJ found in Section 3.
Monitoring/Recordkeeping/Reporting
c. No monitoring, recordkeeping, or reporting is required for sulfur dioxide emissions from
firing natural gas in the emergency engine.
Observed: Compliance was demonstrated during the permit review process.
2. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the emergency generator (ID No. ES-EG) shall not be more than 20
percent opacity each when averaged over a six-minute period. However, six-minute
averaging periods may exceed 20 percent not more than once in any hour and not more than
four times in any 24-hour period. In no event shall the six-minute average exceed 87 percent
opacity.
b. If emissions testing is required, the testing shall be performed in accordance with General
Condition JJ found in Section 3.
Monitoring/Recordkeeping/Reporting
a. No monitoring,recordkeeping, or reporting is required for visible emissions from the firing of
natural gas in the emergency engine.
Observed: The engine was not in operation at the time of the inspection. It is anticipated that the
engine will be in compliance with the visible emission standard when it is operated.
3. 15A NCAC 2D .0524: NEW SOURCE PERFORMANCE STANDARDS
Applicability
a. For this engine,the Permittee shall comply with all applicable provisions, including the
requirements for emission standards,notification,testing,reporting,record keeping, and
monitoring, contained in Environmental Management Commission Standard 15A NCAC 21)
.0524 "New Source Performance Standards(NSPS)" as promulgated in 40 CFR Part 60
Subpart JJJJ—"Standards of Performance for Stationary Spark Ignition Internal Combustion
Engines,"including Subpart A—"General Provisions."

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General Provisions
b. Pursuant to 40 CFR 60 .4246, The Permittee shall comply with the General Provisions of 40
CFR Part 60, Subpart A as presented in Table 3 of 40 CFR Part 60, Subpart JJJJ.
Emission Standards
c. Owners and operators of stationary SI ICE with a maximum engine power greater than or
equal to 75 kW(100 HP),must comply with the emission standards in Table 1 to 40 CFR
Part 60, Subpart JJJJ.
Testing
d. If emissions testing is required,the testing shall be performed in accordance with General
Condition JJ.
Monitoring
e. The engine shall be equipped with a non-resettable hour meter.
Compliance Requirements
f. The Permittee shall comply with the emission standards in Section 2.1.D.3.c of the permit by
purchasing an engine certified to the emission standards in Section 2.1.D.3.c for the
appropriate model year.
g. The Permittee shall operate and maintain the certified stationary ICE and control device(if
included) according to the manufacturer's emission-related written instructions. The Permittee
shall also meet the requirements as specified in 40 CFR Part 1068, subparts A through D, as
they apply. If the engine settings are adjusted according to and consistent with the
manufacturer's instructions,the stationary SI internal combustion engine will not be
considered out of compliance.
h. The Permittee must operate and maintain the stationary SI ICE that achieve the emission
standards as required in Section 2.1.D.3.c of the permit,over the entire life of the engine.
i. The Permittee shall keep the following records:
i. All notifications submitted to comply with 40 CFR 60 and all documentation supporting
any notification.
ii. Maintenance conducted on the engine.
iii. Documentation from the manufacturer that the engine is certified to meet the emission
standards and information as required in 40 CFR parts 90, 1048, 1054, and 1060, as
applicable.
iv. The hours of operation of the engine that is recorded through the non-resettable hour
meter. The Permittee must document how many hours are spent for emergency operation,
including what classified the operation as emergency and how many hours are spent for
non-emergency operation.

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Page 12
Reporting
k. The Permittee shall submit a summary report of monitoring and recordkeeping activities
postmarked on or before January 30 of each calendar year for the preceding six-month period
between July and December and July 30 of each calendar year for the preceding six-month
period between January and June. All instances of noncompliance with the requirements of
this permit shall be clearly identified.
Observed: The generator is operated for 12 minutes each Monday. The hour meter read 118.3
hours when the most recent maintenance occurred on December 9,2020. According to Mr.
Bogart via email on December 11,2020,there was a meter reset on October 29,2020 and S &D
is working with service company to determine why it happened. S &D plans on counting hours
of use from the reading taken on December 9,2020 until the matter is resolved. DAQ will require
confirmation that the hour meter is non-resettable.
I had previously observed the manufacturer's certification.Maintenance is conducted by an
outside contractor every year which includes new oil and filters. Installation was conducted on
January 8,2014. The most recent maintenance was conducted on December 9,2020 (between the
time of the inspection and report finalization);the previous maintenance was conducted
November 18,2019 with the meter showing 143.76 hours. Reports were received January 27,
2020 and July 27,2020 with compliance indicated. Compliance with this condition is indicated.
4. 15A NCAC 2D .1111 MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
Applicability
a. For this source(stationary RICE with a site rating of equal to or less than 500 brake HP located at
a major source of HAP emissions)the Permittee shall comply with all applicable provisions,
including the monitoring,recordkeeping, and reporting contained in Environmental Management
Commission Standard 15A NCAC 02D .I I I I "Maximum Achievable Control Technology"
(MALT) as promulgated in 40 CFR Part 63, Subpart ZZZZ,"National Emission Standards For
Hazardous Air Pollutants For Stationary Reciprocating Internal Combustion Engines"and
Subpart A"General Provisions."
Stationary RICE subiect to Regulations under 40 CFR Part 60
b. Pursuant to 40 CFR 63.6590(c)(6),this source shall meet the requirements of 40 CFR Part 63,
Subpart ZZZZ and Subpart A by meeting the requirements of 40 CFR Part 60 Subpart JJJJ. No
further requirements apply for this engine under 40 CFR Part 63, Subpart ZZZZ and Subpart A.
Observed: According to the permit review,the engine will comply with NESHAP ZZZZ by
complying with NSPS JJJJ. I had previously observed the manufacturer's certification.
Compliance was indicated.
E. One natural gas-fired boiler (ID No. ES-BLR1)
Observed: The boiler is a 2005 Hurst natural gas fired boiler located in the tea packing
building. It was in operation with no visible emissions at the time of the inspection.

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1. 15A NCAC 2D .0503: PARTICULATES FROM FUEL BURNING INDIRECT HEAT
EXCHANGERS
a. Emissions of particulate matter from the combustion of natural gas that are discharged from
this boiler(ID No.ES-BLR1) into the atmosphere shall not exceed 0.60 pounds per million
Btu heat input.
Testing
b. If emissions testing is required,the testing shall be performed in accordance with General
Condition JJ found in Section 3.
Monitoring/Recordkeeping/Reporting
c. No monitoring/recordkeeping/reporting is required for particulate emissions from the firing
of natural gas in this boiler.
Observed: Compliance was demonstrated during the permit review process.
2. 15A NCAC 2D .0516: SULFUR DIOXIDE EMISSIONS FROM COMBUSTION
SOURCES
a. Emissions of sulfur dioxide from the boiler (ID No. ES-BLR1) shall not exceed 2.3 pounds
per million Btu heat input. Sulfur dioxide formed by the combustion of sulfur in fuels,
wastes, ores, and other substances shall be included when determining compliance with this
standard.
Testing
b. If emissions testing is required, the testing shall be performed in accordance with General
Condition JJ found in Section 3.
Monitoring/Recordkeeping/Reporting
c. No monitoring, recordkeeping, or reporting is required for sulfur dioxide emissions from
firing natural gas in this boiler.
Observed: Compliance was demonstrated during the permit review process.
3. 15A NCAC 2D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from the boiler (ID No. ES-BLRI) shall not be more than 20 percent
opacity each when averaged over a six-minute period. However, six-minute averaging
periods may exceed 20 percent not more than once in any hour and not more than four times
in any 24-hour period. In no event shall the six-minute average exceed 87 percent opacity.
Testing
b. If emissions testing is required, the testing shall be performed in accordance with General
Condition JJ found in Section 3.

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Monitoring/Recordkeeping/Reporting
c. No monitoring,recordkeeping, or reporting is required for visible emissions from the firing of
natural gas in this boiler.
Observed: This is a natural gas only boiler. There is a rain cap on the stack. I did not observe
any visible emissions during the inspection. Compliance is indicated.
4. 15A NCAC 2D .1111: -MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY
Applicability
a. For this emission source,the Permittee shall comply with all applicable provisions, including
the notification,testing, and monitoring requirements contained in Environmental
Management Commission Standard 15A NCAC 2D .1111,"Maximum Achievable Control
Technology" as promulgated in 40 CFR Part 63, Subpart DDDDD,"National Emission
Standards for Hazardous Air Pollutants for Major Sources: Industrial, Commercial, and
Institutional Boilers,"including Subpart A"General Provisions."
Definitions and Nomenclature
b. For the purposes of this permit condition,the definitions and nomenclature contained in 40
CFR 63.7575 shall apply.
General Provisions
c. The Permittee shall comply with the General Provisions as applicable pursuant to Table 10 of
40 CFR Part 63, Subpart DDDDD.
Compliance Dates
d. The Permittee shall achieve compliance with the initial tune up requirement and one-time
energy assessment no later than January 31, 2016.
Notification of Compliance Status
e. The Permittee shall submit a Notification of Compliance Status.
f. The notification must be signed by a responsible official and sent before the close of business
on the 60th day following the completion of the initial tune up and one-time energy
assessment(whichever is later).
General Compliance Requirements
g. At all times,the Permittee shall operate and maintain any affected source,including
associated air pollution control equipment and monitoring equipment,in a manner consistent
with safety and good air pollution control practices for minimizing emissions. Determination
of whether such operation and maintenance procedures are being used will be based on
information available to the Administrator that may include,but is not limited to,monitoring
results,review of operation and maintenance procedures,review of operation and
maintenance records, and inspection of the source.

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h. The Permittee shall be in compliance with the work practice standards in this subpart. These
standards apply at all times the affected unit is operating.
Performance Tune-up Requirements
i. The Permittee shall conduct an initial tune-up of the boiler and subsequent tune-ups
annually.
ii. Each annual tune-up shall be conducted no more than 13 months after the previous tune-
up.
iii. The Permittee shall conduct the tune-ups while burning the type of fuel(or fuels in the
case of boilers that routinely burn two types of fuels at the same time)that provided the
majority of the heat input to the boiler over the 12 months prior to the tune-up.
iv. The tune-ups shall be conducted according to the procedures outlined in the permit.
Energy Assessment Requirements
j. The Permittee shall conduct a one-time energy assessment performed by a qualified energy
assessor. The energy assessment must include the items outlined in the permit.
Recordkeeping
k. The Permittee shall keep the following:
i. A copy of each notification and report submitted to comply with this subpart,including
all documentation supporting any Initial Notification or Notification of Compliance
Status,or semiannual compliance report that has been submitted,according to the
requirements in 40 CFR 63.10(b)(2)(xiv).
ii. Maintain on-site and submit, if requested by the Administrator,an annual report
containing the information in paragraphs (A)through(C)below:
(A)The concentrations of carbon monoxide in the effluent stream in parts per million by
volume, and oxygen in volume percent,measured before and after the adjustments of
the source;
(B) A description of any corrective actions taken as a part of the combustion adjustment;
and
(C) The type and amount of fuel used over the 12 months prior to the annual adjustment,
but only if the unit was physically and legally capable of using more than one type of
fuel during that period.Units sharing a fuel meter may estimate the fuel use by each
unit.
iii. maintain records of the calendar date, time, occurrence and duration of each startup and
shutdown.
iv. maintain records of the type(s)and amount(s)of fuels used during each startup and
shutdown.

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1. The Permittee shall:
i. maintain records in a form suitable and readily available for expeditious review;
ii. keep each record for 5 years following the date of each occurrence,measurement,
maintenance, corrective action,report, or record; and
iii. keep each record on site for at least 2 years after the date of each occurrence,
measurement,maintenance,corrective action,report, or record. The Permittee can keep
the records offsite for the remaining 3 years.
Reporting Requirements
m. Pursuant to 40 CFR 63.7550(b),the Permittee shall submit compliance reports to the DAQ on
an annual basis. The Permittee shall submit the compliance report postmarked on or before
January 30 of each calendar year for the preceding 12-month period.
i. The first report shall cover the period beginning on January 31, 2016 and shall be
postmarked on or before January 30,2017.
ii. These reports must also be submitted electronically through the EPA's Central Data
Exchange (CDX)(www.epa.gov/cdx). However,if the reporting form specific to this
subpart is not available in CEDRI at the time that the report is due the report the
Permittee submit the report to the at the appropriate address listed in 40 CFR 63.13.
n. The compliance report must contain the information listed in the permit.
o. If there is a deviation from a work practice standard during the reporting period,the report
must contain the following information:
i. A description of the deviation and which emission limit or operating limit from which the
Permittee deviated; and
ii. Information on the number, duration, and cause of deviations(including unknown cause),
as applicable,and the corrective action taken.
Observed: The facility conducted the initial tune-up January 26, 2016 and completed the
most recent subsequent tune-ups on January 9, 2019 and January 7, 2020. The facility
conducted the energy assessment on January 29,2016;the report was available as requested.
The facility submitted a notification of compliance status on March 10,2016. The annual
compliance report was received on January 27, 2020 with compliance indicated. The facility
failed to submit the report in CEDRI as required. I let Scott Seebold and Zach Bogart know
that they will need to submit to CEDRI as well as to DAQ. Compliance with this condition is
indicated.
F. Chaf handling system(ID Nos.ES-CHS1 and ES-CHS2) and associated bagfilters (ID Nos.
CD-CHSI-BF and CD-CHS2-BF)
Observed: These sources were installed in 2017. These sources were in operation with no
visible emissions at the time of the inspection.

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1. 15A NCAC 02D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES
a. Emissions of particulate matter from these emission sources (ID Nos. ES-CHS1 and ES-
CHS2) shall not exceed an allowable emission rate as calculated by the equation in the
permit.
Testing
b. If emissions testing is required, the testing shall be performed in accordance with General
Condition JJ.
Monitoring/Recordkeeping
c. Particulate matter emissions from these emission sources(ID Nos.ES-CHS1 and ES-CHS2)
shall be controlled by bagfilters (ID Nos. CD-CHSI-BF and CD-CHS2-BF). To assure
compliance, the Permittee shall perform inspections and maintenance as recommended by the
manufacturer. In addition to the manufacturer's inspection and maintenance
recommendations, or if there are no manufacturer's inspection and maintenance
recommendations, as a minimum, the inspection and maintenance requirement shall include
the following:
i. a monthly visual inspection of the system ductwork and material collection unit for leaks;
and
ii. an annual (for each 12 month period following the initial inspection) internal inspection
of the bagfilter's structural integrity.
d. The results of inspection and maintenance shall be maintained in a logbook (written or
electronic format) on-site and made available to an authorized representative upon request.
The logbook shall record the information outlined in the permit.
Reporting
e. The Permittee shall submit the results of any maintenance performed on the bagfilters within
30 days of a written request by the DAQ.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities
postmarked on or before January 30 of each calendar year for the preceding six-month period
between July and December and July 30 of each calendar year for the preceding six-month
period between January and June. All instances of deviations from the requirements of this
permit must be clearly identified.
Observed: The facility has an electronically generated work order system. The most recent
visual inspections of the ductwork were conducted November 23,2020 for both baghouses. I
observed monthly internal inspections from the last inspection to present. The most recent
was dated November 13,2020. All reports have been received. Compliance is indicated.

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2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from above listed sources shall not be more than 20 percent opacity when
averaged over a six-minute period. However, six-minute averaging periods may exceed 20
percent not more than once in any hour and not more than four times in any 24-hour period.
In no event shall the six-minute average exceed 87 percent opacity.
Testing
b. If emissions testing is required,the testing shall be performed in accordance with General
Condition JJ
Monitoring
c. To assure compliance, once a month the Permittee shall observe the emission points of these
emission sources (ID Nos. ES-CHS1 and ES-CHS2) for any visible emissions above
normal. The monthly observation must be made for each month of the calendar year period to
ensure compliance with this requirement. The Permittee shall establish "normal" for these
sources within the first 30 days following the effective date of the emission sources venting to
the atmosphere. If visible emissions from this source are observed to be above normal, the
Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and
within the monitoring period and record the action taken as provided in the recordkeeping
requirements below, or
ii. demonstrate that the percent opacity from the emission points of the emission source in
accordance with 15A NCAC 02D .2610 (Method 9) for 12 minutes is below the limit
given in Section 2.1 C.2. a. of the permit.
Recordkeeping
d. The results of the monitoring shall be maintained in a logbook (written or electronic format)
on-site and made available to an authorized representative upon request. The logbook shall
record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were
observed to be in noncompliance along with any corrective actions taken to reduce
visible emissions; and
iii. the results of any corrective actions performed.
Reporting
e. The Permittee shall submit a summary report of the observations postmarked on or before
January 30 of each calendar year for the preceding six-month period between July and
December and July 30 of each calendar year for the preceding six-month period between
January and June. All instances of deviations from the requirements of this permit must be
clearly identified.

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Observed: The facility is making monthly observations and keeps a log. The most recent
observation occurred on November 23, 2020. All reports have been received and indicated
compliance.
G. Whole Bean Transfer system (ID No. ES-WBTS) and associated bagfilter (ID No. CD-
WBTS)
1. 15A NCAC 02D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES
a. Emissions of particulate matter from these emission sources (ID No. ES-WBTS) shall not
exceed an allowable emission rate as calculated by the equation listed in the permit.
Testing
b. If emissions testing is required, the testing shall be performed in accordance with General
Condition JJ.
Monitoring/Recordkeeping
c. Particulate matter emissions from these emission sources (ID No. ES-WBTS) shall be
controlled by a bagfilter (ID Nos. CD-WBTS). To ensure compliance, the Permittee shall
perform inspections and maintenance as recommended by the manufacturer. In addition to
the manufacturer's inspection and maintenance recommendations, or if there are no
manufacturer's inspection and maintenance recommendations, as a minimum, the inspection
and maintenance requirement shall include the following:
i. a monthly visual inspection of the system ductwork and material collection unit for leaks;
and
ii. an annual (for each 12 month period following the initial inspection) internal inspection
of the bagfilter's structural integrity.
d. The results of inspection and maintenance shall be maintained in a logbook (written or
electronic format) on-site and made available to an authorized representative upon request.
The logbook shall record the information requested in the permit.
Reporting
e. The Permittee shall submit the results of any maintenance performed on the bagfilter within
30 days of a written request by the DAQ.
f. The Permittee shall submit a summary report of monitoring and recordkeeping activities
given in Section 2.1 G.l.c and d of the permit, postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of
each calendar year for the preceding six-month period between January and June. All
instances of deviations from the requirements of this permit must be clearly identified.

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Observed: These sources have been installed but not started up. I visually confirmed that they are
not in operation (lock out/tag out) and confirmed with Mr. Seebold via a phone call follow up to
the inspection on December 7,2020. Compliance will be determined once they are in operation.
2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from above listed sources shall not be more than 20 percent opacity when
averaged over a six-minute period. However, six-minute averaging periods may exceed 20
percent not more than once in any hour and not more than four times in any 24-hour period.
In no event shall the six-minute average exceed 87 percent opacity.
Testing
b. If emissions testing is required,the testing shall be performed in accordance with General
Condition JJ
Monitoring
c. To ensure compliance, once a month the Permittee shall observe the emission points of these
emission sources (ID Nos. ES-CHS1 and ES-CHS2) for any visible emissions above
normal. The monthly observation must be made for each month of the calendar year period to
ensure compliance with this requirement. The Permittee shall establish "normal" for these
sources within the first 30 days following the effective date of the emission sources venting to
the atmosphere. If visible emissions from this source are observed to be above normal, the
Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and
within the monitoring period and record the action taken as provided in the recordkeeping
requirements below, or
ii. demonstrate that the percent opacity from the emission points of the emission source in
accordance with 15A NCAC 02D .2610 (Method 9) for 12 minutes is below the limit
given in Section 2.1 C.2. a. above.
Recordkeeping
d. The results of the monitoring shall be maintained in a logbook (written or electronic format)
on-site and made available to an authorized representative upon request. The logbook shall
record the information required by the permit.
Reporting
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities
given in Section 2.1 G.2.c and d of the permit, postmarked on or before January 30 of each
calendar year for the preceding six-month period between July and December and July 30 of
each calendar year for the preceding six-month period between January and June. All
instances of deviations from the requirements of this permit must be clearly identified.
Observed: These sources have been installed but not started up. I visually confirmed that they are
not in operation (lock out/tag out) and confirmed with Mr. Seebold via a phone call follow up to
the inspection on December 7,2020. Compliance will be determined once they are in operation.

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3. 15A NCAC 02Q .0504: OPTION FOR OBTAINING CONSTRUCTION AND
OPERATION PERMIT
Permitting
a. For completion of the two-step significant modification process pursuant to 15A NCAC 02Q
.0501(b)(2), the Permittee shall file an amended application following the procedures of
Section 15A NCAC 02Q .0500 within one year from the date of beginning operation of these
source(s) (ID Nos.ES-WBTS and CD-WBTS).
Reporting
b. The Permittee shall notify the Regional Office in writing of the date of beginning operation of
this source(ID No.ES-WBTS),postmarked no later than 30 days after such date.
Observed: These sources have been installed but not started up. I visually confirmed that they are
not in operation (lock out/tag out) and confirmed with Mr. Seebold via a phone call follow up to
the inspection on December 7, 2020. Also, according to Mr. Seebold, the company plans on
starting up the equipment during the first quarter of 2021. Compliance will be determined once
they are in operation.
H. Five Coffee Bean Grinders (ID No. ES-5CBG) and associated with Dust Collector (ID No. CD-
5CBG-DC)
Coffee Bean Flavoring Booth(ID No.ES-CBFB)
1. 15A NCAC 02D .0515: PARTICULATES FROM MISCELLANEOUS INDUSTRIAL
PROCESSES
a. Emissions of particulate matter from these emission sources (ID No. ES-WBTS) shall not
exceed an allowable emission rate as calculated by the equation listed in the permit.
Testing
b. If emissions testing is required, the testing shall be performed in accordance with General
Condition JJ.
Monitoring/Recordkeeping
c. Particulate matter emissions from these emission sources (ID No. ES-5CBG) shall be
controlled by a dust collector(ID No. CD-5CBG-DC). To ensure compliance, the Permittee
shall perform inspections and maintenance as recommended by the manufacturer. In addition
to the manufacturer's inspection and maintenance recommendations, or if there are no
manufacturer's inspection and maintenance recommendations, as a minimum, the inspection
and maintenance requirement shall include the following:
i. a monthly visual inspection of the system ductwork and material collection unit for leaks;
and
ii. an annual (for each 12 month period following the initial inspection) internal inspection
of the bagfilter's structural integrity.

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d. The results of inspection and maintenance shall be maintained in a logbook (written or
electronic format) on-site and made available to an authorized representative upon request.
The logbook shall record the information outlined in the permit.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0515 if the ductwork
and dust collector are not inspected and maintained.
e. For the Coffee Bean Flavoring Booth (ID No. ES-CBFB), the Permittee shall maintain
production records such that the process rates "P" in tons per hour, as specified by the
formulas contained in the permit can be derived, and shall make these records available to a
DAQ authorized representative upon request. The Permittee shall be deemed in
noncompliance with 15A NCAC 02D .0515 if the production records are not maintained or
the types of materials and finishes are not monitored.
Reporting
£ No reporting is required for particulate emissions from this source(ID No.ES-CBFB).
g. The Permittee shall submit the results of any maintenance performed on the bagfilter within
30 days of a written request by the DAQ.
h. The Permittee shall submit a summary report of monitoring and recordkeeping activities
given in Section 2.1 H.Lc and d of the current permit postmarked on or before January 30 of
each calendar year for the preceding six-month period between July and December and July
30 of each calendar year for the preceding six-month period between January and June. All
instances of deviations from the requirements of this permit must be clearly identified.
Observed: The coffee bean grinders were brought online in late September 2020. The most
recent monthly visual in section was conducted November 4,2020. The first summary report of
monitoring and recordkeeping activities will be due January 30,2021. The coffee been flavoring
booth is not yet in operation. Compliance is indicated.
2. 15A NCAC 02D .0521: CONTROL OF VISIBLE EMISSIONS
a. Visible emissions from these emission sources (ID Nos. ES-5CBG and ES-CBFB) shall not
be more than 20 percent opacity when averaged over a six-minute period. However, six-
minute averaging periods may exceed 20 percent not more than once in any hour and not
more than four times in any 24-hour period. In no event shall the six-minute average exceed
87 percent opacity.
Testing
b. If emissions testing is required, the testing shall be performed in accordance with General
Condition JJ. If the results of this test are above the limit given in Section 2.1 H.2.a of the
permit,the Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521.
Monitoring
c. To ensure compliance, once a month the Permittee shall observe the emission points of these
emission sources(ID Nos.ES-1CBG through ES-5CBG and ES-CBFB) for any visible
emissions above normal. The monthly observation must be made for each month of the

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calendar year period to ensure compliance with this requirement. The Permittee shall
establish"normal"for these sources in the first 30 days of beginning operation. If visible
emissions from these sources are observed to be above normal,the Permittee shall either:
i. take appropriate action to correct the above-normal emissions as soon as practicable and
within the monitoring period and record the action taken as provided in the recordkeeping
requirements below, or
ii. demonstrate that the percent opacity from the emission points of the emission source in
accordance with 15A NCAC 02D .2610 (Method 9) for 12 minutes is below the limit
given in Section 2.1 H.2.a of the permit.
The Permittee shall be deemed to be in noncompliance with 15A NCAC 02D .0521 if the
required monthly observations are not conducted as required; if the above-normal emissions
are not corrected within the monitoring period or the percent opacity demonstration cannot be
made; or if"normal" is not established for these sources in the first 30 days of beginning
operation.
Recordkeeuing
d. The results of the monitoring shall be maintained in a logbook (written or electronic format)
on-site and made available to an authorized representative upon request. The logbook shall
record the following:
i. the date and time of each recorded action;
ii. the results of each observation and/or test noting those sources with emissions that were
observed to be in noncompliance along with any corrective actions taken to reduce
visible emissions; and
iii. the results of any corrective actions performed.
The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0521 if these records
are not maintained.
Reporting
e. The Permittee shall submit a summary report of the monitoring and recordkeeping activities
given in Section 2.1 H.2.c and d of the current permit postmarked on or before January 30 of
each calendar year for the preceding six-month period between July and December and July
30 of each calendar year for the preceding six-month period between January and June. All
instances of deviations from the requirements of this permit must be clearly identified.
Observed: The facility is making monthly observations and keeps a log for the five coffee bean
grinders and dust collector. The most recent observation occurred on November 23, 2020. I
observed the grinders and dust collector in operation with no visible emissions at the time of the
inspection. The coffee been flavoring booth is not yet in operation All reports have been received
and indicated compliance.

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5. Part I - AIR QUALITY TITLE V OPERATION PERMIT. The following permitted emission
sources and/or control devices listed in Section 2 Paragraph 2.2- Multiple Emission Source(s)
Specific Limitations and Conditions were observed during this inspection:
A. Coffee bean roasters(ID Nos.ES-RI,ES-R2-New,ES-R3,ES-R4,ES-R5,and ES-R6)
STATE-ONLY REQUIREMENT 15A NCAC 2D .1100: Toxic Air Pollutant Emissions
Emission Source Toxic Air Pollutant(s) Emission Limit(s)
ES-Rl Acetic acid 0.28 lb/hr
Acetaldehyde 0.13 lb/hr
Acrolein 0.018 lb/hr
Formaldehyde 0.62 lb/hr
ES-R2-NEW Acetic acid 1.75 lb/hr
Acetaldehyde 1.71 lb/hr
Acrolein 0.02 lb/hr
Formaldehyde 0.868 lb/r
ES-R3 Acetic acid 2.09 lb/hr
Acetaldehyde 2.03 lb/hr
Acrolein 0.024 lb/hr
Formaldehyde 1.04 lb/hr
ES-R4 Acetic acid 0.026 lb/hr
Acetaldehyde 0.012 lb/hr
Acrolein 0.00162 lb/hr
Formaldehyde 0.057 lb/hr
ES-R5 Acetic acid 2.09 lb/hr
Acetaldehyde 2.03 lb/hr
Acrolein 0.02 lb/hr
Formaldehyde 1.04 lb/hr
ES-R6 Acetic acid 1.62 lb/hr
Acetaldehyde 1.58 lb/hr
Acrolein 0.019 lb/hr
Formaldehyde 0.81 lb/hr
Observed: There are no monitoring or reporting requirements, but the facility must maintain
records of operational information demonstrating that the toxic emissions do not exceed the limits
shown above. The facility maintains an electronic database that is used to determine if the toxics
are below the permitted limits. I observed the spreadsheets though November 2020; compliance
was indicated.
B. Coffee bean roasters (ID Nos. ES-Rl, ES-112-New,ES-113,ES-114,ES-R5, and ES-116), green bean
handling systems(ID Nos.ES-BH1 and ES-11112),and Coffee Bean Flavoring Booth(ES-CBFB)
1. 15A NCAC 2Q. 0317: AVOIDANCE CONDITIONS
15A NCAC 2D. 0902: APPLICABILITY [Reasonably Available Control Technology]
a. In order to avoid applicability of this regulation, the above emission sources shall discharge into
the atmosphere less than 100 tons of VOCs per consecutive 12-month period.

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Testing
b. If emissions testing is required, the Permittee shall perform such testing in accordance with
General Condition JJ. If the results of this test are above the limit given in Section 2.2 B.La of
the current permit,the Permittee shall be deemed in noncompliance with 15A NCAC 02Q .0902.
c. Under the provisions of NCGS 143-215.108, the Permittee shall determine the appropriate
emission factor for VOC emissions in units of pounds of VOCs emitted per ton of coffee roasted
by conducting a source test on the roaster (ID No. ES-2-New) in accordance with a testing
protocol approved by the DAQ. Details of the emissions testing and reporting requirements can
be found in General Condition JJ. Testing shall be completed, and the results submitted within
180 days of start up of roaster (ID No. ES-2-New) unless an alternate date is approved by the
DAQ. If the testing is not completed, the Permittee shall be deemed in noncompliance with 15A
NCAC 2D .0902.
Monitoring/Recordkeeping
d. VOC emissions from the six coffee roasters (ID Nos. ES-R1 through ES-R6) shall be controlled
by thermal oxidizers (ID Nos. ES-RI-TO and ES-R4-TO) and catalytic oxidizers (ID Nos. ES-
R2-New-CO,ES-R3-CO, CD-R5-CO, and CD-R6-CO); and Coffee Bean Flavoring Booth JD
No. ES-CBFB) as described in the permitted equipment list. To comply with the provisions of
this permit and ensure that emissions do not exceed the limit in 2.2 B.La of the permit, the
Permittee shall perform periodic inspections and maintenance as recommended by the
manufacturer. As a minimum, the Permittee shall perform an annual internal inspection of each
primary heat exchanger and associated inlet/outlet valves to ensure structural integrity.
e. The Permittee shall calculate the VOC emissions using the emission factors outlined in the
current permit.
£ For the catalytic oxidizer (ID No. CD-R2-New-CO), the Permittee shall maintain the 3-hour
block average catalytic oxidizer firebox temperature equal to or above the three-hour block
average established during the performance test conducted pursuant to Section 2.2 B.l.c. of the
current permit. The Permittee shall record the three-hour block averages in a logbook(written or
electronic format).
g. For Coffee Bean Flavoring Booth(ID No. ES-CBFB),Calculations of VOC emissions per month
shall be made at the end of each month. VOC emissions shall be determined by multiplying the
total amount of each type of VOC-containing material consumed during the month by the VOC
content of the material.
g. The Permittee shall record the calculations and the total amount of VOC emissions monthly in a
logbook(written or electronic format).
h. The Permittee shall be deemed in noncompliance with 15A NCAC 02D .0902 if the monitoring
or recordkeeping in Section 2.2.13.l.d through g of the current permit is not conducted or
maintained or if the VOC emissions exceed the limit in Section 2.2 B.La. of the permit.

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Reporting
i. The Permittee shall submit a semi-annual summary report, acceptable to the Regional Air Quality
Supervisor, of monitoring and recordkeeping activities given in Section 2.2 B.Ld-h of the current
permit postmarked on or before January 30 of each calendar year for the preceding six-month
period between July and December, and July 30 of each calendar year for the preceding six-
month period between January and June. The report shall contain the monthly VOC emissions
for the previous 17 months. The emissions must be calculated for each of the 12-month periods
over the previous 17 months.
Observed: The facility maintains an electronic database that is used to determine the emissions
listed in the permit. The new roaster was put into production on March 15,2018. The facility
completed emissions testing on the new roaster(ID No. ES-R2-New) on July 31,2018. The
results report was postmarked September 12,2018, exactly 180 days from start up. The results
were deemed acceptable by the Stationary Source Compliance Branch(SSCB)on January 22,
2019. The firebox set temperature established by the testing is 8507. The facility keeps records
of the firebox temperature,which indicated compliance with the requirement. The facility is
performing periodic maintenance on the catalytic and thermal oxidizers, including checks of the
primary heat exchanger. See below.
Roaster Facility Label Previous Most recent
ES-R1 R-2000 8/26/2019 6/15/2020
ES-R2-New J2000 12/9/2019 Not operable
ES-R3 RZ-1 10/30/2019 10/29/2020
ES-R4 G60 11/26/2019 3/17/2020
ES-R5 RZ-2 2/24/2019 1/26/2020
ES-R6 R-3000-1 1/19/2019 1/10/2020
The facility keeps a monthly spreadsheet with VOC and TAPS emissions that was updated
through the end of November 2020. The facility VOC and HAPs totals were 60.20 tons and 15.70
tons,respectively. The semi-annual reports were received on January 27,2020 and July 27, 2020.
Compliance was indicated.
C. Coffee bean roasters(ID Nos.ES-RI,ES-R2-New,ES-R3,ES-R4,ES-R5,and ES-R6)
1. 15A NCAC 2Q .0711: TOXIC AIR POLLUTANT EMISSIONS LIMITATION
REQUIREMENT
Pursuant to 15A NCAC 2Q .0711 "Emission Rates Requiring a Permit,"for phenol and hexane
the Permittee has made a demonstration that facility-wide actual emissions do not exceed the
Toxic Permit Emission Rates (TPERs) listed in 15A NCAC 2Q .0711.
Observed: The facility maintains an electronic database that is used to determine the emissions
listed in the permit. I observed the spreadsheets; compliance was indicated.

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December 3,2020
Page 27
D. Facility wide affected sources
1. 15A NCAC 02D .1806: CONTROL AND PROHIBITION OF ODOROUS EMISSIONS
a. The Permittee shall not operate the facility without implementing management practices or
installing and operating odor control equipment sufficient to prevent odorous emissions from the
facility from causing or contributing to objectionable odors beyond the facility's boundary.
Observed: The facility does contribute to odors off property, which I experienced during the
inspection. An official odor evaluation was not conducted at the time of inspection. In addition,
this office has not received any complaints regarding odors. Ccompliance is indicated.
6. Part I - AIR QUALITY TITLE V OPERATION PERMIT. Section 3 - GENERAL
CONDITIONS
a. Permit. Maintain a copy of the permit and application at the facility. Observed. The permit
and application are at the facility.
b. Submissions. Except as otherwise specified, two copies of all documents, reports, test data,
monitoring data are required to be submitted to MRO. Observed. The company is now
submitting two copies.
c. Circumvention. Operate and maintain the facility at all times in a manner that will effect an
overall reduction in air pollution.
d. Excess Emissions. Report excess emissions and permit deviations as required. Observed.
No excess emissions have occurred since the last inspection.
e. Retention of Records. The Permittee shall retain records of all required monitoring data and
supporting information for a period of at least five years from the date of the monitoring
sample,measurement,report, or application. Observed. Records are being maintained.
£ Compliance Certification. By March 1 submit a compliance certification (for the preceding
calendar year). Observed: The report was received on February 27, 2020 with compliance
indicated.
g. Emissions Inventory. Submit an emissions inventory by June 30 of each year. Observed:
Submitted June 25, 2020.
h. Section 112(r). 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.
7. The following insignificant air emission sources and control devices were observed as follows:
Source ID No. Source Description
I-ES-RI-RC, four closed loop roasting cyclones
I-ES-R2-RC,
I-ES-R3-RC, and
I-ES-RS-RC
Observed: hi operation with no issues noted during the inspection.

S&D Coffee,Inc.
December 3,2020
Page 28
IS-SR2 Probat Probatino Tabletop natural gas-fired(0.0185 lb/MMBtu)roaster
associated with research and development operations
Observed: This source is no longer at the main facility and has moved to the West Winds site
(Facility ID No. 1300170)A note was made on the yellow sheet for West Winds.
IS-GCR ground coffee remixing process with associated dust collector(ID No. CD-
GCR)
Observed: There were no visible emissions from the dust collecting system.
IS-GCSS two(2) series of ground coffee storage silos with associated bin vents(ID No.
CD-GCSSBV
Observed: There were no visible emissions from the silos.
IS-CC-1 and two chaff collection cyclones
IS-CC-2
Observed: There were no visible emissions from the dust collecting system outside.
IS-CD-CHS 1-C Chaff handling system No. 1 -cyclone
Observed: There were no visible emissions from the dust collecting system.
IS-CD-CHS2-C Chaff handling system No. 2 -cyclone
Observed: There were no visible emissions from the dust collecting system.
IS-CD-CHS 1-DLC I Chaff handling system No. 1 -divert line cyclone
Observed: There were no visible emissions from the dust collecting system.
IS-CD-CHS2-DLC I Chaff handling system No. 2 -divert line cyclone
Observed: There were no visible emissions from the dust collecting system.
IS-401/402-BF Ground coffee conveying and packaging line with bagfilter
Observed: There were no visible emissions from the dust collecting system.
IS-CHPS Chaff Handling and Pelletizing System
Observed: This source is now in operation,but I did not observe.
IS-SGCHD Spent Grounds Coffee Handling and Drying System
Observed: This source is now in operation,but I did not observe.
IS-DCGPS Dried Coffee Grounds Pelletizing System
Observed: This source is now in operation,but I did not observe.
IS-TLFS Tea Leaf Flavoring Station
Observed: This source is now in operation,but I did not observe.
8. NSPS/NESHAP
The facility is now subject to NESHAP subpart ZZZZ and NSPS subpart JJJJ for the natural gas
fired emergency generator and NESHAP subpart DDDDD for the natural gas fired boiler,
respectively. According to Mr. Bogart, the facility does not have any gasoline storage tanks;
therefore,they are not subject to NESHAP subpart 6C.

S&D Coffee,Inc.
December 3,2020
Page 29
9. Compliance Assistance:
I reminded Mr. Seebold and Mr. Bogart that the annual 5D compliance report needs to be
submitted in CEDRI as well as submitted to the DAQ.
10. Findings. Based on my observations during this inspection, this facility appeared to be in
compliance with the applicable air quality regulations. However, the facility must provide
evidence that the hour meter on the emergency generator is non-resettable.
MJW:lhe
cc: MRO File
https://ncconnect.sharepoint.com/sites/DAQ-MRO/Counties/CABARRUS/00051/INSPECT 20201203.docx