AQ_F_0100309_20210106_CMPL_CAV-Rpt (4)

NORTH CAROLINA DIVISION OF Winston-Salem Regional Office
AIR QUALITY Lotus Bakeries USA Manufacturing,LLC
NC Facility ID 0100309
Inspection Report County/FIPS:Alamance/001
Date: 01/07/2021
Facility Data Permit Data
Lotus Bakeries USA Manufacturing,LLC Permit n/a
2010 Park Center Drive Issued n/a
Mebane,NC 27302 Expires n/a
Lat: 36d 5.1164m Long: 79d 1.7.7255m Class/Status:Registered
SIC: 2052/Cookies And Crackers Permit Status: Inactive
NAICS: 311821 /Cookie and Cracker Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP
Bart Vanterwyngen Bart Vanterwyngen MACT Part 63: Subpart ZZZZ
Operations Director Operations Director NSPS: Subpart IIII
[phone] [phone]
Compliance Data
Comments:
Inspection Date: 01/06/2021
Inspector's Name: Thomas Gray
Inspector's Signature: Operating Status: Operating
Compliance Code Compliance-inspection
Action Code FCE
Date of Signature: MV;1l MTH On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 * HA
No emissions inventory on record.
*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
Sources of Emissions:
Emission Source Control System E
Description Description
._._.Material Handling Operations' f Dust Control Equipment'
.................................. ............_....................._..................................._...................................................................................................._......................... ..........................................:.........................................................................................................._...._....,..................................._.............................
. .....I
Natural Gas Combustion Sources' N/A
Fuel Oil Combustion Sources
Sanitation and Packaging Operations' N/A
1

..... _wr.. . � W. ww.. ......�.. Emission Source____. __ w.... Control System
Description Description
t Includes Flour,Sugar,Premix and Dough Handling.
2 Includes Ovens,Boilers,Makeup Air Units,Heating and Air Conditioning Units.
!3 Includes Emergency Generator(s).
4 Includes Cleaners/Degreasers,Sanitizers,Printing Inks and Adhesives.
5 Per information provided by the equipment supplier,the control efficiency of the dust control equipment filter media is 99.9%. See Attachment B.
........................_................................
- Introduction:
On January 6, 2021, Mr. Thomas Gray, Environmental Specialist I, of the Winston Salem Regional Office-Division of Air Quality
(WSRO-DAQ),contacted Mr. Bart Vanterwyngen, Operations Director, of Lotus Bakeries USA Manufacturing, LLC, for the purpose
of conducting an announced compliance assurance visit(CAV). This facility has never been visited by the DAQ and began trial batch
operations on August 6,2019. This plant is a cookie manufacturing facility which utilizes dry ingredients(i.e., sugar,flour, cinnamon)
and syrup to produce around 3,000 cookies per minute. The facility produces trademark"biscoff' cookies for the airline industry, as
well as retail grocery markets. Mr. Vanterwyngen stated the facility currently operates 16 hours per day on a five day per week
schedule with occasional cleanings on the weekends. Emission sources at the facility include dry ingredient handling equipment(e.g.,
storage bins, conveyors, hoppers, mixers), natural gas-fired equipment(e.g., rooftop air conditioning units, make-up air units, ovens,
boilers)and a diesel-fired emergency generator. The WSRO-DAQ received a request for registration from the facility on June 5,2019
along with required calculated expected and potential facility-wide emissions. In accordance with 15A NCAC 2Q .0102(e)"any
facility that is not exempted from permitting pursuant to Paragraph (d) of this Rule and whose actual total aggregate emissions of
particulate matter (PM10), sulfur dioxide, nitrogen oxides, volatile organic compounds, carbon monoxide, hazardous air pollutants,
and toxic air pollutants are greater than or equal to five tons per year and less than 25 tons per year may register their facility pursuant
to 15A NCAC 02D .0202 instead of obtaining a permit pursuant to 15A NCAC 02Q .0300." The facility was subsequently issued
registration number 0100309X00 on November 4, 2019. Mr. Vanterwyngen stated the facility is in the planning process to install
several new lines at the facility and will be in contact with the WSRO-DAQ.All contact information as listed in I-BEAM was verified
as correct with Mr. Vanterwyngen,and no changes were necessary at the time of the visit.
Safety:
The following PPE is required while visiting the facility: Safety Glasses, Safety Shoes. It should be noted that shoe booties, hair net,
beard net,and a smock are required as the production area is subject to FDA standards.
Applicable Regulations:
Title 15A NCAC, Subchapter 2D .0202,2D .0503,2D .0515, 2D .0516,2D .0521,2D .0535,2D .0540,2D .0611,2D .1806,40 CFR
60 Subpart IIII, and 40 CFR 63 Subpart ZZZZ. This facility is not required to implement a Section 112(r) risk management plan
(RMP) in accordance with federal regulation 40 CFR 68, because they do not purchase, produce, use or store any of the regulated
chemicals in quantities above their corresponding threshold limits. However, the facility is subject to the General Duty clause
contained in this rule.
Discussion:
The process at the facility is the following: Bulk raw ingredients including flour and sugar are received at the facility via trucks on a
weekly basis.The raw ingredients are then pneumatically blown to one of four of the facility's bulk silos(capacities ranging from 100
to 135 short tons). Mr. Vanterwyngen stated that two of the silos are used for flour only, one for sugar only, and one is a"swing" silo
and can be used for either. It should be noted that the four silos are completely enclosed in a building.Each is equipped with their own
respective cartridge filters to control particulate emissions while venting the silos during the loading process. During the course of the
visit, one of the two flour silos was actively being loaded with no visible emissions, indicating likely compliance with 2D .0521.
Following the bulk silos,raw materials are then gravity fed into their desired pre-mix hoppers. The facility also operates a sugar sifter
and surge hopper and a flour sifter and surge hopper associated only with the"swing"silo. Sugar from the sugar silo is pneumatically
conveyed to the sugar mill collection hopper where it is then introduced to the milled sugar ribbon blender to ensure the appropriate
granulometry for the mix. At this point, smaller amounts of the necessary raw ingredients (salt, baking powder, shortening, etc) are
then introduced into the pre-mix hoppers as well (bag dumping station). Once the desired ratio of raw ingredients is received, the
contents are then fed to the premixer. Contents in the pre-mixer are then sent to one of two premix silos(of which can hold around 7.5
short tons each).Next,the contents are then sent to the premix sifter and surge hopper to make sure the mix is more uniform, before
ultimately being sent to the dough mixer. Each dough batch is approximately 8,000 lbs. Following mixing and resting, the dough is
then baked on one of the facility's two baking lines. Each line contains a natural gas-fired oven with 5 burners, of which all were
2

operating between 140-200 degrees Celsius. During the course of the visit, one line was baking cookies with the Delta Airlines logo,
while the other was baking cookies with the Lotus logo. Following baking, the cookies are then subjected to sorting and packaging.
The vast majority of this process is fully automated and involves sorting, boxing, bagging, and shipment preparation. It should be
noted the facility also operates two small natural gas-fired boilers/hot-water heaters (4.00 MMBtu/hr) used for process water which
were observed in operation with no visible emissions. These boilers provide hot water for the mixer's water jacket, and the industrial
washing machine used to clean the dough bins. The facility also has 19 rooftop air conditioning units, two make-up air units(used for
room air conditioning on the oven lines), and three heating units (used for comfort heating of mechanical room) installed. Lastly, the
facility's 125 kw Kohler emergency diesel-fired generator was observed not in operation. The hour meter reading indicated 90.1
hours, as of the time of the visit.
Applicable Regulations:
2D.0202-Registration of Air Pollution Sources
According to this rule, the Director may require the owner or operator of an air pollution source to register that source by providing
information considered essential in evaluating the source of air pollution such as, but not limited to the quantities and types of
materials used, operating schedules, weight and kinds of air pollutants emitted, process flow diagrams, source location, and facility
contacts. Facilities with an air permit are required to submit emission inventories ninety (90) days prior to the expiration of the
permit. Under the Registration program, registered facilities will not be subject to this emission inventory submittal requirement.
However,the facility will be required to maintain records that would show facility-wide emissions are below the registration threshold
of 25 tons per year. Mr.Vanterwyngen was well aware of these requirements. Compliance with this regulation is anticipated.
2D.0503-"Particulates from Fuel Burning Indirect Heat Exchangers"
This regulation applies and limits particulate emissions to installations in which fuel is burned for the purpose of producing heat or
power by indirect heat transfer and it is applicable to the following Natural Gas combustion sources at the facility:
Nineteen(19)Rooftop Air Conditioning Units(RTU-01 through RTU-19, inclusive)
Two(2)Make-Up Air Units(MAU-02 and MAU-03)
Two(2)Boilers(BL-65125 and BL-65130)
As provided on the registration review(Leo Governale, Env. Engineer,2019),the following equations and calculations below are used to
calculate the allowable emission limit and actual emissions of particulate matter:
E=1.090Q-o.2594
where Q is the maximum heat input in mmBtu/hr and includes
the total sum of all fuel burning heat exchangers at a plant site,
except if the maximum heat input is< 10 mmBtu/hr,then
the allowable emission limit is 0.60 lb PM/mmBtu.
According to information provided on the application for registration, the total maximum heat input of all of the above subject sources is
20.895 mmBtu/hr,and so the allowable emission limit is calculated to be 0.495 lb PM/mmBtu.
Using the AP-42 PM emission factors for Natural Gas Combustion(Table 1.4-2, 7/98),the actual PM emissions are calculated as follows:
PMNatw,al Gas=(7.6 lb PM/106 ft3)x(ft3/1,020 Btu)x 1,000,000 Btu/mmBtu=0.007 lb PM/mmBtu.
0.007 lb PM/mmBtu<0.495 lb PM/mmBtu 4 O.K.
Continued compliance with this condition is anticipated.
2D.0515-Particulates from Miscellaneous Industrial Processes
This rule limits emission rates for particulate matter(PM)from any stack, vent, or outlet,resulting from any industrial process, for which
no other emission control standards are applicable. Each of the PM-generating sources associated with the Material Handling Operations
(15 total sources) has the potential to emit PM, and so they are subject to this regulation, which limits the allowable PM emissions as
derived by the following equations:
3

E=4.10(P)°•" if P<_30 tons/hr,or
E=55.0(P)o-11-40 if P>30 tons/hr
where: P=the process weight rate in tons/hr,and
E=maximum allowable emission rate of PM in lbs/hr
The process weight rates and allowable emissions rates for these sources listed in the following table are based on information provided
on the initial registration review (calculated by Leo Governale, Environmental Engineer, 2019). See table footnotes for additional
information. The following table demonstrates compliance with this regulation. Note that the PM emissions for each source were _
presented in terms of the potential emissions rate and so the actual expected emissions rates shown below were scaled down by a factor of
0.712(6,240 expected actual_8,760 potential hours of operation per year).
Emissions Source M Process Weight Rate Allowable Emissions Rate Actual'Expected Emissions
(P) [tons/hr] (E) [lb PM/hr] Rate [lb PM/hr]
Flour Silo 1
Flour Silo 2
,,,,,,,, ,,,,,,,,,,,,�..,,,.,,.,_�......�.�.�..�..�,..�........�......�...,�...�.�..w...�..�......_._....��.� 24.0,each' 34.5,each 0.037,each2
Sugar Silo �
Swing Silo
Sugar Sifter and Surge Hopper
Flour Sifter and Surge Hopper 19.4,each 0.005,each
�N.�...��.��.. ...�_µw.�..,.,.�..�....._�.,.....,�..N_.,,..,.__��....�.....�.. .�.�..N....� 10.2,each3
Milled Sugar Ribbon Blender
Sugar Mill Collection Hopper
Pre-Mixer
0035'
�� � 4.2,each 10.7,each..............w........�............
._ .........................................................
� ...._...........,............ _.
..._. Pre-Mix Hopper
0.00541
Pre-Mix Silo 1 �.�...�....w�.._.....�.M..�..V..�.........�...�.�..�._ w.....,..._..�..�.w.........wM....�......�......
0.035,each' �
Pre-Mix Silo 2 5.4,each' 12.7,each
Pre-Mix Sifter and Surge Hopper 0.0054
�..�-iDou h Mixer _ 8 4.45 .. _. _. 0.035'
Bag Dumping Station w/Filter ( 5.49 11.2 0.015
........_..............................................................................................................................................................................................................................................................................................................._.................................o
... ...................................................
............:..............................:................................................................................................................ .
I Per information provided with application—see Attachment C:48,000 lb/hr,each(loading rate from trucks)x lb/2,000 ton=24.0 tons/hr,each.
2 0.23 tons PM/yr,each(expected potential emissions)x 2,000 lb/ton x 1 yr/8,760 hr x 0.712=0.037 lb PM/hr.—see Attachment C.
3 Per information provided with application—see Attachment C:340 lb/min,each(unloading rate to plant)x 60 min/hr x lb/2,000 ton=10.2 tons/hr,each.
4 0.03 tons PM/yr,each(expected potential emissions)x 2,000 lb/ton x 1 yr/8,760 hr x 0.712=0.005 lb PM/hr.—see Attachment C.
5 Per information provided with application—see Attachment C: 140 lb/min,each(unloading rate to plant)x 60 min/hr x lb/2,000 ton=4.2 tons/hr,each.
'0.22 tons PM/yr,each(expected potential emissions)x 2,000 lb/ton x 1 yr/8,760 hr x 0.712=0.035 lb PM/hr.—see Attachment C.
'Per information provided with application—see Attachment C: 180 lb/min,each(unloading rate to plant)x 60 min/hr x lb/2,000 ton=5.4 tons/hr,each.
8 Per information provided with application—see Attachment C: 1,022 kg/hr(unloading rate to plant)x 2.204 lb/kg x lb/2,000 ton=1.13 tons/hr.
9 Per information provided with application—see Attachment C: 180 lb/min,each(unloading rate to plant)x 60 min/hr x lb/2,000 ton=5.4 tons/hr,each.
to 0.09 tons PM/yr,each(expected potential emissions)x 2,000 lb/ton x 1 yr/8,760 hr x 0.712=0.015 lb PM/hr.—see Attachment C.
It should be noted that with exception to the Flour, Sugar and Swing Silo,all the above emission sources vent entirely indoors.
2D.0516-Sulfur Dioxide Emissions from Combustion Sources
This regulation applies to all facility-wide sources of combustion that discharge sulfur dioxide (SO2), i.e., the Combustion Sources,
and it states that emissions should not exceed 2.3 lb SO2 per MMBtu input. As stated on the registration review(Leo Governale, Env.
Engineer, 2019) all combustion sources are natural gas-fired and as such are inherently low in SO2 emissions; therefore, it is
reasonable to anticipate that these sources can comply with this regulation.
4

2D.0521—Control of Visible Emissions
The facility is subject to this regulation which limits visible emissions to 40%opacity for sources manufactured as of July 1, 1971 and
to 20% opacity for sources manufactured after July 1, 1971. As this is a new facility, the 20% opacity limit applies to the sources.
During the course of the CAV,no visible emissions were noted,indicating likely compliance with this regulation.
2D.0535—Excess Emissions Reportiniz and Malfunctions
This regulation contains the notification requirements for facilities that have a malfunction, breakdown of process or control
equipment, or any other abnormal conditions that lead to a source of excess emissions lasting longer than four hours in duration. The
facility is required to notify WSRO DAQ by 9:00 the following day of business; provide the name and location of the facility the
excess emissions occurred, the nature and cause of the malfunction or breakdown, the time when the malfunction or breakdown was
first observed, the expected duration, and an estimated rate of emissions. The facility is then required to notify the director when
corrective measures have been completed. During the course of the CAV, Mr. Vanterwyngen stated no know instances of excess
emissions have occurred,nor is the WSRO-DAQ aware of any instances, indicating likely compliance with this regulation.
2D.0540—Particulates from Fugitive Dust Emission Sources
This condition states that the facility shall not cause or allow fugitive dust emissions to cause or contribute to substantive complaints
or excess visible emissions beyond the property boundary. The inspector noted no fugitive dust during the visit. A review of the
IBEAM database indicated no past complaints associated with fugitive dust. Compliance with 2D.0540 is indicated.
2D.0611—Monitorin Emissions from Other Sources:
This regulation applies to the facility's dust control equipment and it requires the Registrant to inspect each control device per the
manufacturer's recommendations, at a minimum annually, and maintain a logbook (either written or electronic) on-site of all
inspections and maintenance performed on the subject equipment. As mentioned in the discussion, the facility's four bulk raw
ingredient silos are each controlled by their own respective cartridge filters. According to records provided by Mr. Vanterwyngen,the
cartridge filters controlling the two flour silos were inspected on February 12,2020, and the cartridge filters controlling the sugar and
swing-silos were inspected on March 8, 2020. According to Mr. Vanterwyngen, the silos received their first shipments of raw
materials in July of 2019.Continued compliance with this condition is anticipated.
2D.1806—Control and Prohibition of Odorous Emissions
This regulation states that the facility shall not operate 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.No objectionable odors were'detected over the course of the compliance assurance visit, and a review
of the IBEAM database indicated no complaints,indicating likely compliance with 2D.1806.
NSPS/NESHAP Applicability:
2D.0524-New Source Performance Standards
The engine associated with the facility's 125 kW Diesel-fired Emergency Generator is subject to 40 CFR 60, Subpart IIII "New
Source Performance Standards for Stationary Compression Ignition Internal Combustion Engines (CI ICE)." This regulation is
applicable to engines that commenced construction after July 11,2005 and were manufactured after April 1,2006 (or July 1,2006 for
fire pumps).The engine associated with the generator is a 2018 197 HP John Deere Engine Model 4045HF285K.
• Owners and operators of 2007 model year and later emergency stationary CI ICE with a displacement of <30 liters per
cylinder that are not fire pump engines must comply with the emission standards for new nonroad CI engines in §60.4202,for
all pollutants, for the same model year and maximum engine power.
• Owners and operator of 2007 model year and later engines must comply with the emission standards by purchasing an engine
certified to the emission standards for the same model year and maximum engine power. The engine must be installed and
configured according to the manufacturer's specifications.
• By October 1, 2010, engines with a displacement <30 liters per cylinder must use diesel fuel that is maximum of 0.0015%
sulfur by weight (15 ppm). The cetane index is limited to a minimum of 40 and the aromatic content is limited to a
maximum of 35 volume percent.
5

• Engines and control devices must be operated and maintained according to the manufacturer's written instructions or
procedures developed by the owner or operator that are approved by the engine manufacturer. In addition, owners and
operators may only change those settings that are permitted by the manufacturer.
• Owners and operators of emergency stationary Cl ICE must install a non-resettable hour meter prior to startup of the engine.
• Operation for maintenance checks and readiness testing is limited to 100 hours per year. Operation in non-emergency
situations is allowed up to 50 hours per year, but those 50 hours are counted towards the 100 hours per year provided for
maintenance and testing.There is no time limit on the use of emergency stationary ICE in emergency situations. -
• Owners and operators of emergency stationary internal combustion engines are not required to submit an initial notification.
Through the non-resettable hour meter,the owner must record the time of operation of the engine and the reason the engine
was in operation during that time. Other recordkeeping requirements, including keeping records of notifications,
maintenance,and engine certification apply if the emergency engine has a displacement>10 liters per cylinder.
The engine was purchased certified to meet the Tier 3 emission requirements as required by the subpart. The engine is part of the EPA
certified engines group JJDXL06.8120. Mr. Vanterwyngen provided documentation indicating the diesel fuel used in the engine was
less than the required 15 ppm sulfur by weight. Documentation provided indicated the engine is serviced quarterly and operated per
manufacturers recommendation.The hour meter reading was 90.1 during the course of the visit.The engine began operation in August
of 2019.Mr. Vanterwyngen was made well aware of the above-mentioned requirements. Continued compliance with this regulation is
anticipated.
2D.1111-Generally Achievable Control Technology
It should be noted, the engine is also subject to 40 CFR 63, Subpart ZZZZ - National Emissions Standards for Hazardous Air
Pollutants for Stationary Reciprocating Internal Combustion Engines (RICE). According to §63.6590 (a)(2)(iii) of this regulation, a
stationary RICE located at an area source of HAP emissions is considered"new" if construction of the stationary RICE commenced
on or after June 12, 2006. As mentioned above,the engine was constructed on 11/01/2018 and is thus considered"new" according to
the subpart. In order to comply with this regulation, the engine must meet the requirements of ZZZZ by meeting the requirements of
j Subpart IIII as discussed above. Continued compliance with this regulation is anticipated.
The facility does not appear to be subject to any other NSPS/NESHAP regulations.
Facility-Wide Emissions:
The table below lists the expected actual and facility-wide emissions as provided with the registration application. Expected potential
uncontrolled PM, PMIo and PM2.5 emissions were calculated by Leo Governale, Env. Engineer, of the WSRO-DAQ, and were
combined with those provided for all other sources. Note that expected actual emissions are based on an anticipated operating
schedule of 6,240 hours per year.
µExpected Actual Emissions Expected Potential Emissions [tons/yr]
Pollutant
[tons/yr] F Controlled FUneontrolled
PMJ47.422+0.57'=47.99
.
..........................PM10 222 3.08 40.3 02+0.573=40.87
PM2s
0.14 0.16
NOx
6.47
CO 6.05 8.37
;
._.......�.,._......
�........
...._.............
................._...........,......,_...._..,._._.......,_,..............._.......,......................,........................................................................,,................_.................,.............................._.....,.......................................,................._...........................�.......................................................,..,...................,.....,.......,........_.......
VOC 2.78 3.86
.....
.................._,...._...._..:.�......_............,,_.....,_„_....,......................,................................ ............................._. Y............._,..,..............................................................,.............,......._.......,...,................,.......,,_...................._....
HAPTotal 0.13 0.18 _
µ TAPTotal ......� .._._...__. _.,_ 0.83 µµ 1.17 m
Total Aggregate Emissions 17.661 N/A
(PM10,S02,NOx,CO,VOC,HAP,TAP)
6

W Expected Actual Emissions Expected Potential Emissions [tons/yr]
Pollutant -- w � . ..., _.._.._...�.... � a.._..
I [tons/yr] Controlled Uncontrolled
.............._.._............_................................._............................................_................................:..............................................___............................
............................................_..........................................
'(2.22+0.14+6.47+6.05+2.78(HAP and TAP not included as they are included in VOC)=17.66 tons/yr. i
a As calculated by this reviewer for Material Handling Sources.See Attachment F.
fo all ces.See Attac
� m
'As provided by Applicant other sources. Gm � mm mm
The facility's aggregate emissions were calculated to be 17.66 tons. As such, the facility qualifies for registration as Registration per
2Q .0102 (e), "actual total aggregate emissions of particulate matter (PM�o), sulfur dioxide (SO2), nitrogen oxides (NOx), volatile
organic compounds(VOC), carbon monoxide(CO), hazardous air pollutants(HAP), and toxic air pollutants(TAP)"shall be "greater
than or equal to five tons per year and less than 25 tons per year."
Registration Status:
No changes in emission sources,facility-wide emissions,or production rates have occurred at this facility that would otherwise affect
the registration status of this facility.
Compliance History:
No Notices of Violation or Deficiency have been issued to this facility in the previous 5 years.
Conclusion:
Based on visual observations and records review over the course of the compliance assurance visit, it appears the facility is operating
in compliance with all applicable air quality rules and regulations.
7