AQ_F_1300051_20180711_ST_RvwMemo (4)

STATE
ROY COOPER NORTH CAROLINA
Governor Environmental Quality
MICHAEL S.REGAN
Secretary
MICHAEL ABRACZINSKAS Jul 11 2018
Director y �
Sal DiGiovanni
Director of Engineering
S&D Coffee, Inc.
300 Concord Parkway South
Concord,North Carolina 28027
Subject: S&D Coffee, Inc.
Concord, Cabarrus County,North Carolina
Facility ID 1300051,Permit No. 05029T17
VOC Emissions Test Protocol for Coffee Roaster ES-R2-New
By GEL Engineering,LLC
Proposed Test Date: July 12,2018
DAQ Tracking No. 2018-190st
Dear Mr.DiGiovanni:
The North Carolina Division of Air Quality(DAQ)has reviewed the protocol submittal form(PSF)for
the emissions testing of Coffee Roaster ES-R2-New. GEL Engineering has proposed VOC emissions
testing to determine the volatile organic compound(VOC)emission factor for the new coffee bean roaster
as required by the permit. The proposed testing is acceptable as discussed in this letter.
The emissions source to be tested is natural gas-fired coffee bean roaster ES-R2-New controlled by
catalytic oxidizer CD-R2-New-CO. The maximum permitted process rate is 4400 pounds per hour. The
proposed rate for testing is 4200 pounds per hour green coffee beans.
15A NCAC 2Q .0317 Avoidance Conditions applies to avoid the applicability of 15A NCAC 2D .0902
Reasonably Available Control Technology(RACT). Permit Condition 2.2.13.1 specifies the RACT
avoidance requirements for VOC emissions. Condition 2.2.B.La limits the VOC emissions from roasters
ES-RI,ES-R2-New,ES-R3 through ES-R6 and green bean handling systems ES-BH1 and ES-BH2 to"less
than 100 tons of VOCs per consecutive 12-month period." Condition 2.2.B.l.c requires testing to
"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)." Additionally,
2.2.B.l.frequires"For the catalytic oxidizer(ID No.CD-R2-New-CO),the Permittee shall maintain the
3-hour block average catalytic oxidizer firebox temperature equal to or above the three-hour block
average established during the performance test."
GEL Engineering has proposed three 60-minute EPA Method 25A sampling runs at the catalytic oxidizer
stack with EPA Methods 1,2, 3 or 3A, and 4 in support of the VOC emissions sampling. The four
proposed EPA Method 2 volumetric flow runs will be"conducted before and after each VOC run."
,�� A
NORTH CAROLS D_E�� Q
'
Derymnem•f[vkamenw Owl
North Carolina Department of Environmental Quality I Division of Air Quality
217 West Jones Street 11641 Mail Service Center I Raleigh,North Carolina 27699-1641
919.707,8400

Sal DiGiovanni
Tracking No.2018-190st
July 11,2018
Page 2
The PSF states"Green bean throughput on the roaster(lbs)and temperature of the catalytic oxidizer
combustion chamber will be recorded by the facility at least every 15 minutes." The relevant process and
control data shall be included in the final test report.
The proposed test methods and process rate for testing are acceptable. All testing shall be conducted in
strict accordance with the approved methods. Any deviations remain subject to approval by DAQ. If you
have any questions,please contact me at 919-707-8416 or shannon.vogelia ncdenr.:,ov.
Sincerely, l/
X�4 Y
Shannon Vogel
Environmental Engineer
Division of Air Quality,NCDEQ
cc: Central Files, Cabarrus County
Bruce Ingle,Mooresville Regional Office
Kirk Alexander,GEL
IBEAM Documents- 1300051