AQ_F_1300051_20181113_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: 11/13/2018
Facility Data Permit Data
S&D Coffee,Inc. Permit 05029/T18
300 Concord Parkway South Issued 10/9/2018
Concord,NC 28027 Expires 3/31/2021
Lat: 35d 23.7312m Long: 80d 36.9372m Classification Title V
SIC: 2095/Roasted Coffee Permit Status Active
NAICS: 31192/Coffee and Tea Manufacturing Current Permit Application(s)None
Contact Data Program Applicability
Facility Contact Authorized Contact Technical Contact SIP/Title V
Zack Bogart Scott Seebold Sal DiGiovanni MACT Part 63: Subpart DDDDD, Subpart ZZZZ
Maintenance Planner and VP of Operations Engineering Manager NSPS: Subpart JJJJ
Scheduler [phone] [phone]
[phone]
Compliance Data
Comments:
Inspection Date 11/13/2018
Inspector's Name Melinda Wolanin
Inspector's Signature: Operating Status Operating
Compliance Code Compliance-inspection
"AAA, Action Code FCE
Date of Signature: 2_(� + On-Site Inspection Result Compliance
Total Actual emissions in TONS/YEAR:
TSP S02 NOX VOC CO PM10 *HAP
2017 12.23 0.0400 6.70 82.33 18.49 12.23 26002.03
2016 11.68 0.0400 6.51 77.59 17.49 11.68 24195.75
2015 11.95 0.0600 9.52 78.87 5.66 11.95 24683.75
*Highest HAP Emitted inpounds)
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:
Date Test Results Test Method(s) Source(s)Tested
07/31/2018 Pending

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November 13,2018
Page 2
ETypeAction: X Full Compliance _Partial Compliance _Complaint Other:
Evaluation Evaluation/Reinspection Investigation
Data Date submitted for initial review 11/27/2018 _IBEAM WARNING/OB or NOV or NOWNRE
Tracking: X IBEAM Document
X IBEAM Inspection, list date inspected X IBEAM LAT/LONG,Facility Locked
X IBEAM Inspection,list date draft is submitted IBEAM LAT/LONG,Coordinates checked
X IBEAM Inspection,pollutants/programs checked _IBEAM Complaint
X IBEAM Planning,Next Inspection Date 11/01/2019
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/io of a mile off Pitts School Road,turn left onto
Weddington Road; and travel Weddington Road for 4 Vio 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.Protective shoes
and hearing protection are recommended.
Safety Issues: Be aware of forklift traffic.
Coordinates: Coordinates checked with no changes needed. The coordinates shown on the Facilities Map
were correct.
Email Contacts: I updated the email information for the new facility contact,Mr.Zack Bogart.
1. The purpose of this site visit was to conduct a routine air quality inspection. I arrived at the
facility around 9:00am. 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.
2. Facility Contact Information: Mr. Bogart is the new facility contact; IBEAM was updated.
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.
B. Compliance history:
On March 14,2016,the facility was issued an NOV. for failure to submit their annual
compliance certification on time.
On February 8, 2012,the facility was issued an NOD for failure to submit the semi-
annual report on time.

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Page 3
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 25, 2018 and July 30, 2018.
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-Rl-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-RI-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(8.0 million Btu per hour CO hour maximum rated input)
maximum rated input and 7,400 lbs/hr
maximum process rate)
ES-R2C-
New cooling and de-stoning system(7,400 CD-R2-New- cooling cyclone(63 inches in diameter)and de-stoning
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 8800 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
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 maximum rated input)
hour maximum heat input;405 pounds per
hour maximum process rate

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Emission Control
Source Emission Source Description Device Control Device Description
ID No. ID No.
Roaster 5
ES-R5 natural gas-fired coffee bean roasting CD-RS-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-RS-CC cooling cyclone(88 inches in diameter)and de-stoning
lbs/hr maximum process-rate) CD-RS-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 CD-R6-CC cooling cyclone(60 inches in diameter and de-stoning
ES-R6C lb/hr maximum process rate) CD-R6-DC 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. This is visible, at times, in the baghouse
and cycle area behind the building. Roaster 1 (R2000)was in operation with no visible emissions. Roaster 2
(J2000) was not running at the time of the inspection. Roaster 3 (RZ-1) was in operation with no visible
emissions. Roaster 4 (G60) runs small batches and is usually run only every couple of months; it was not in
operation at the time of the inspection. Roaster 5 (RZ2)was in operation with no visible emissions.Roaster 6
(R3000-1)was in operation with no visible emissions.
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`1 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.
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.

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Page 5
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 3 0.
Observed: The facility is making monthly observations and keeps a log. The most recent
observation occurred on November 4,2018.There were no deviations recorded from last December
to present.All reports have been received and indicated compliance.
4. 15A NCAC 02Q .0504: Option for Obtaining Construction and Operation Permit
Permitting
a. The permittee shall have one year from the date of beginning operation of this source(ID No.
ES-RS-New)to file an amended application following the procedures of Section 15A NCAC
02Q .0500.
Renortin�
b. The Permittee shall notify the Regional Office in writing of the date of beginning operation of
this source; postmarked no later than 30 days after such date.
Observed: This source commenced operating in the beginning of 2018. The application will be
due in early 2019.'Compiiance will be determined at a later date.
B. Green bean handling system (ID No.ES-BHl) and associated settling box(ID No.BHI-SB)
and bagfdter(ID No. BHl-BF)
Green bean handling system (ID No. ES-BH2) and associated bagfilters (ID No. CD-BF-1
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.

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Page 6
Observed: The facility has an electronically generated work order system. Visual observations
are made monthly. The most recent visual inspections of the ductwork were conducted October 4,
2018 for all baghouses. The most recent internal inspection for each system was performed
September 18,2018,previous internal inspections occurred on November 14 and November 6,
2017 for green bean handling systems 1 and 2, respectively. All reports have been received.
Compliance is indicated.
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 and keeps a log. The most recent
observation occurred on October 4,2018.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-NSGBM and associated bagfilter
(ID No. CD-NSGBI)
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)
o eration
�-NSGBA New side green bean handling CD- bagfilter(1,404 square feet of filter
equipment NSGBH 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-NSGBIT) shall not exceed an allowable emission rate as calculated by the
equation listed in the permit.

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Page 7
Monitoring/Recordkeepin�
b. Particulate matter emissions from these emission sources (ID Nos.ES-TMP,ES-CBG/CP,
and ES-NSGBI) shall be controlled by bagfilters (ID Nos. CD-TMP, CD-CBG/CP, and
CD-NSGBI). 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.
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 following:
i. the date and time of each recorded action;
ii. the results of each inspection;
iii. the results of any maintenance performed on the bagfilters; and
iv. any variance from manufacturer's recommendations, if any, and corrections made.
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 checks are
conducted monthly. The most recent visual checks were performed October 5, 2018. The
most recent internal inspection was performed October 22, 2018,the previous internal
inspection was conducted November 16,2017. 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.

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Page 8
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-NSGBIT)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.
Recordkeepin2
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.
Reportins
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 October 5, 2018. 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.

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Page 9
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/Recordkeenin�
r
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.
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

S&D Coffee,Inc.
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Page 10
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. Compliance is indicated.
D. One natural gas-fired 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/Recordkeepini!/Reportin�
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.

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Monitoring/Recordkeeping R'eportin�
c. 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
Applicabilitv
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 2D
.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."
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 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.

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Page 12
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. In order for the engine to be considered an emergency stationary ICE under 40 CFR Part 60,
Subpart JJJJ, any operation other than emergency operation,maintenance and testing,
emergency demand response, and operation in non-emergency situations for 50 hours per
year, as described in paragraphs(i)through(iii) below, is prohibited. If the engine is not
operated according to the requirements in paragraphs(i)through (iii) below,the engine will
not be considered an emergency engine under this subpart and must meet all requirements for
non-emergency engines.
i. There is no time limit on the use of emergency stationary ICE in emergency situations.
ii. The Permittee may operate its emergency stationary ICE for any combination of the
purposes specified in paragraphs (A)through(C) of this condition for a maximum of 100
hours per calendar year. Any operation for non-emergency situations as allowed by
paragraph(iii) of this condition counts as part of the 100 hours per calendar year allowed
by this paragraph(ii).
(A)Emergency stationary ICE may be operated for maintenance checks and readiness
testing, provided that the tests are recommended by federal, state or local
government;the manufacturer,the vendor,the regional transmission organization or
equivalent balancing authority and transmission operator, or the insurance company
associated with the engine.The owner or operator may petition the Administrator for
approval of additional hours to be used for maintenance checks and readiness testing,
but a petition is not required if the owner or operator maintains records indicating
that federal, state, or local standards require maintenance and testing of emergency
ICE beyond 100 hours per calendar year.
(B) Emergency stationary ICE may be operated for emergency demand response for
periods in which the Reliability Coordinator under the North American Electric
Reliability Corporation(NERC)Reliability Standard EOP-002-3, Capacity and
Energy Emergencies (incorporated by reference in 40 CFR 60.17), or other
authorized entity as determined by the Reliability Coordinator, has declared an
Energy Emergency Alert Level 2 as defined in the NERC Reliability Standard EOP-
002-3.
(C) Emergency stationary ICE may be operated for periods where there is a deviation of
voltage or frequency of 5 percent or greater below standard voltage or frequency.
iii Emergency stationary ICE may be operated for up to 50 hours per calendar year in non-
emergency situations. The 50 hours of operation in non-emergency situations are counted
as part of the 100 hours per calendar year for maintenance and testing and emergency
demand response provided in paragraph(2)'of this condition. Except as provided in
paragraph(3)(i)of this condition,the 50 hours per year for non-emergency situations
cannot be used for peak shaving or non-emergency demand response, or to generate
income for a facility to an electric grid or otherwise supply power as part of a financial
arrangement with another entity.

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(A)The 50 hours per year for non-emergency situations can be used to supply power as
part of a financial arrangement with another entity if all of the following conditions
are met:
(1) The engine is dispatched by the local balancing authority or local transmission
and distribution system operator;
(2) The dispatch is intended to mitigate local transmission and/or distribution
limitations so as to avert potential voltage collapse or line overloads that could
lead to the interruption of power supply in a local area or region.
(3) The dispatch follows reliability, emergency operation or similar protocols that
follow specific NERC, regional, state,public utility commission or local
standards or guidelines.
(4) The power is provided only to the facility itself or to support the local
transmission and distribution system.
(5) The owner or operator identifies and records the entity that dispatches the engine
and the specific NERC, regional, state, public utility commission or local
standards or guidelines that are being followed for dispatching the engine. The
local balancing authority or local transmission and distribution system operator
may keep these records on behalf of the engine owner or operator.
Recordkeeping
j. 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.
ReportinE
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.

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Page 14
Observed: The generator is operated for 12 minutes each Monday. The hour meter read 119.67
hours when the most recent maintenance occurred on October 22, 2018. The engine ran 11.26
hours since the previous inspection. 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
October 22,2018;the previous maintenance was conducted November 27, 2017.Reports were
received January 25, 2018 and July 30, 2018 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 .1111 "Maximum Achievable Control Technology"
(MACT)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-BLRI)
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.
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.
TestinE
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/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-BLRI) 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/Re c o r d ke e p i n g/Re p o rti n g
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-BLR1)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.
Monitoring/Record keeping/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.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 21) .1111, "Maximum Achievable Control

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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. The notification shall
contain the following:
i. A description of the affected unit(s) including identification of which subcategories the
unit is in,the design heat input capacity of the unit, and description of the fuel(s)burned.
ii. A signed certification that the Permittee has met all applicable work practice standards.
iii. The following certification(s) of compliance, as applicable:
(A)"This facility complies with the required initial tune-up according to the procedures
40 CFR 63.7540(a)(10)(i)through(vi),"and
(B) "This facility has had an energy assessment performed according to 40 CFR
63.7530(e)."
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 following procedures:
(A)As applicable, inspect the burner, and clean or replace any components of the burner
as necessary(the Permittee may delay the burner inspection until the next scheduled
unit shutdown, not to exceed 36 months from the previous inspection). Units that
produce electricity for sale may delay the burner inspection until the first outage,not
to exceed 36 months from the previous inspection. At units where entry into apiece
of process equipment or into a storage vessel is required to complete the tune-up
inspections, inspections are required.only during planned entries into the storage
vessel or process equipment;
(B) Inspect the flame pattern, as applicable, and adjust the burner as necessary to
optimize the flame pattern. The adjustment should be consistent with the
manufacturer's specifications, if available.
(C) Inspect the system controlling the air-to-fuel ratio, as applicable, and ensure that it is
correctly calibrated and functioning properly(the Permittee may delay the inspection
until the next scheduled unit shutdown, not to exceed 36 months from the previous
inspection). Units that produce electricity for sale may delay the inspection until the
first outage, not to exceed 36 months from the previous inspection.
(D) Optimize total emissions of CO. This optimization should be consistent with the
manufacturer's specifications, if available, and with any nitrogen oxide requirement
to which the unit is subject.
(E) Measure the concentrations in the effluent stream of CO in parts per million, by
volume, and oxygen in volume percent, before and after the adjustments are made
(measurements may be either on a dry or wet basis, as long as it is the same basis
before and after the adjustments are made). Measurements may be taken using a
portable CO analyzer.
(F) If the unit is not operating on the required date for a tune-up, the tune-up must be
conducted within 30 days of startup.

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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 following items:
i. A visual inspection of the boiler system,
ii. An evaluation of operating characteristics of the affected boiler systems, specifications of
energy use systems, operating and maintenance procedures, and unusual operating
constraints,
iii. An inventory of major energy use systems consuming energy from affected boiler(s) and
which are under control of the boiler owner or operator,
iv. A review of available architectural and engineering plans, facility operation and
maintenance procedures and logs, and fuel usage,
v. A review of the facility's energy management practices and provide recommendations for
improvements consistent with the definition of energy management practices, if
identified.
vi. A list of cost-effective energy conservation measures that are within the facility's control.
vii. A list of the energy savings potential of the energy conservation measures identified.
viii.A comprehensive report detailing the ways to improve efficiency,the cost of specific
improvements, benefits, and the time frame for recouping those investments.
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 63.1 0(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.

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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.
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.
Reportine Requirements
in. 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 following information:
i. Company name and address;
ii. Process unit information, emissions limitations, and operating parameter limitations;
iii. Date of report and beginning and ending dates of the reporting period;
iv. The total operating time during the reporting period;
iv. If there are no deviations from the requirements of the work practice requirements in
Section 2.1.EA.i. above, a statement that there were no deviations from the work practice
standards during the reporting period; and
v. Include the date of the most recent tune-up for each unit required to conduct an annual
tune-up according to Section 2.1.EA.i. Include the date of the most recent burner
inspection if it was not done annually and was delayed until the next scheduled or
unscheduled unit shutdown.
o. If there is a deviation from a work practice standard during the reporting period,the report
must contain the following information:

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Page 20
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
subsequent tune-ups on January 11, 2017 and January 26, 2018. 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 29, 2018 with compliance indicated.The facility sumitted the
reports in CEDRI as required (January 29, 2018 and January 27,2017). 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-CHS2-13F)
Observed: These sources are not yet in operation.
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/Recordkeepiny-
c. Particulate matter emissions from these emission sources (ID Nos. ES-CHS1 and ES-CHS2)
shall be controlled by bagfilters (ID Nos. CD-CHS1-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 following:
i. the date and time of each recorded action;

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Page 21
ii. the results of each inspection;
iii. the results of any maintenance performed on the bagfilters; and
iv. any variance from manufacturer's recommendations, if any, and corrections made.
Reaortin�
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: These sources are not yet in operation. Compliance will be determined when the
equipment is operational.
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.

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Recordkeepine
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.
Observed: The chaf handling system was not yet in operation at the time of the inspection.
Compliance will be determined when the equipment is operational.
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

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Page 23
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 following:
i. the date and time of each recorded action;
ii. the results of each inspection;
iii. the results of any maintenance performed on the bagfilters; and
iv. any variance from manufacturer's recommendations, if any, and corrections made.
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.1.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 are being installed but have not yet begun operating. 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:

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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
H. 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 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 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 are being installed but have not yet begun operating. Compliance will be
determined once they are in operation.
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
sources) (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 are being installed but have not yet begun operating. Compliance will be
determined once they are in operation.

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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-Rl,ES-112-New,ES-R3,ES-R4,ES-115,and ES-R6)
1. STATE-ONLY REQUIREMENT 15A NCAC 2D .1100: Toxic Air Pollutant Emissions
Observed: The facility maintains an electronic database that is used to determine if the toxics are
below the permitted limits. I observed the spreadsheets; compliance was indicated.
B. Coffee bean roasters (ID Nos. ES-R1, ES-112-New, ES-113, ES-R4, ES-R5, and ES-R6) and green
bean handling systems(ID Nos.ES-BH1 and ES-BH2)
1. 15A NCAC 2Q. 0317: AVOIDANCE CONDITIONS
15A NCAC 2D. 0900: 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. 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.
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
above,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 startup 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.
d. Calculations and the total amount of VOC emissions shall be recorded monthly in a logbook
(written or electronic format). Submit semiannual reports by January 30 and July 30 of
monitoring and recordkeeping activities.
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 are currently under review by the Stationary Source Compliance Branch
(SSCB). The firebox set temperature established by the testing is 850°F. 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.

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Roaster Facility Label Previous Most recent
ES-RI R-2000 9/9/2017 9/25/2018
ES-R2-New J2000 Start up,3/15/2018 Not yet due
ES-R3 RZ-1 4/22/2017 11/5/2018
ES-R4 G60 3/30/2017 8/31/2018
ES-R5 RZ-2 01/26/2017 3/15/2018
ES-R6 R-3000-1 11/04/2017 3/11/2018
The facility keeps a monthly spreadsheet with VOC and TAPs emissions that was updated
through the end of October 2018.The semi-annual reports were received on January 25, 2018 and
July 30,2018. Compliance was indicated.
C. Coffee bean roasters(ID Nos.ES-RI,ES-R2-New,ES-113,ES-114,ES-115,and ES-116)
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.
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.

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S&D Coffee,Inc.
November 13,2018
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e. 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.
f. Compliance Certification. By March 1 submit a compliance certification (for the preceding
calendar year). Observed: The report was received on February 23, 2018 with compliance
indicated.
g. Emissions Inventory. Submit an emissions inventory by June 30 of each year. Observed:
Submitted June 25, 2018.
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-R5-RC
Observed: In operation with no issues noted during the inspection.
IS-SR2 Probat Probatino Tabletop natural gas-fired (0.0185 lb/MMBtu)roaster
associated with research and development operations
Observed: Not in operation at the time of the inspection.
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-CHSI-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-CHSI-DLC Chaff handling system No. 1 - divert line cyclone

S&D Coffee,Inc.
November 13,2018
Page 28
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 not yet in operation.
IS-SGCHD Spent Grounds Coffee Handling and Drying System
Observed: This source is not yet in operation.
IS-DCGPS Dried Coffee Grounds Pelletizing System
Observed: This source is not yet in operation.
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.
9. Compliance Assistance:
We discussed the need for better organization of maintenance records.
10. Findings. Based on my observations during this inspection, this facility appeared to be in
compliance with the applicable air quality regulations.
MJW:Ihe
cc: MRO File
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