AQ_F_1300051_20190201_ST_RvwLtr

n a STATE a
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Ploy COOPER M3
Governor i
MICHAEL S.REGAN '
Secretary ? '
MICHAEL ABRACZINSKAS
Director NORTH CAROLINA
Environmental Quality
February 1, 2019
Mr. Scott Seebold,VP of Operations
S&D Coffee, Inc.
300 Concord Parkway South
Concord, NC 28027
Subject: Volatile Organic Compound(VOC) Emissions Testing of the Natural Gas-fired Coffee
Bean Roaster (ID. No. ES-R2-NEW), Performed on July,I and 31, 2018
S&D Coffee, Inc.
Concord, Cabarrus County,North Carolina
Facility ID No. 1300051
Air Permit No. 05029TI8
Tracking No. 2018-190ST
Dear Mr. Seebold:
VOC emissions testing.was performed on the natural gas-fired coffee bean roaster(ID. No. ES-
R2-NEW) at S&D Coffee, Inc., located in Concord, Cabarrus County, North Carolina on July 11 and 31,
2018. The test was performed to establish a VOC emission factor and to determine the three-hour block
average firebox temperature of the catalytic oxidizer(ID.No. CD-R2-New-CO) in accordance with the
requirements of Air Permit No. 05029T17, Specific Conditions and Limitations Nos. 2.2-B.Le. and 2.2-
13.11, respectively.
The Stationary Source Compliance Branch of the North Carolina Division of Air Quality has
completed a review of the referenced test. It was determined that the testing was acceptable to establish
the VOC emission factor for natural gas-fired coffee bean roaster(ID. No. ES-R2-NEW) and the three-
hour block average firebox temperature of the catalytic oxidizer(ID.No. CD-R2-New-CO). Please find
enclosed a copy of the test review memorandum.
If you have any questions with reference to this matter, please do not hesitate to contact me at
[phone].
Sincerely,
Denise Hayes
Environmental Engineer
MJW:
Enclosure
c: MRO File
https:Hncconnect.sharepoint.com/sites/deq/daq_mro/Counties/CABARRUS/00051/STK_LET_20190201.doc
North Carolina Department of Environmental Quality 1 Division of Air Quality
E Mooresville Regional Office 1 610 East Center Avenue,Suite 3011 Mooresville,North Carolina 2811S
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DIVISION OF AIR QUALITY
January 22,2019 JAN 2 15'
MEMORANDUM
To: Bruce Ingle,Mooresville Regional Office
0
From: Shannon Vogel, Stationary Source Compliance Branch
Subject: S&D Coffee,Inc.
Concord,Cabarrus County,North Carolina
Facility ID 1300051,Permit No. 05029T1 7
Volatile Organic Compounds(VOC)Testing of Coffee Roaster No.2(ES-R2-New)
Performed July 11 and 31,2018 by GEL Engineering
Tracking No.2018-190st
GEL Engineering performed EPA Method 25A emissions testing to determine the VOC emissions factor
for the new coffee bean roaster No.2 as required by the permit. The test results are acceptable to
establish the VOC emissions factor in pounds per ton coffee roasted.
The emissions source is natural gas-fired coffee bean roaster ES-R2­New controlled by catalytic oxidizer
CD-R2-New-CO. The maximum permitted process rate is 4400 pounds per hour. The proposed rate was
4200 pounds per hour green coffee,however the report transmittal sheet commented"The maximum
process rate for the new roaster was found to be greater that was originally given by the manufacturer."
The average green coffee rates were 4114 and 5440 lb/hr for the 7/11/18 and 7/31/18 testing,respectively.
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.B.1 specifies the RACT
avoidance requirements for VOC emissions.Condition 2.2.B.La limits VOC emissions from roasters
ES-Rl,ES-R2-New,ES-R3 through ES-R6 and green bean handling systems ES-BHl and ES-BH2 to"less
than 100 tons of VOCs per consecutive 12-month period." Condition 2.2.B.Lc 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)." The permit
specifies using an emissions factor of 2.66 pounds per ton for Coffee Roaster No.2 until the results of this
testing are approved by DAQ. The test results are tabulated below.
Coffee Roaster ES-R2-New VOC Emissions Factor Testing Tracking No.2018:190st
Test Green Test Results Afterburner
Run
Date Coffee,lb/hr VOC,lb/hr VOC,lb/ton green coffee Temperature
1 5012 0.229 0.0912
7/11/18 2 2929 0.481 0.328
3 4400 0.273 0.124
Average 4114 0.328 0.159 886.6°F
1 5198 0.154 0.0592
7/31/18 2 5623 0.254 0.0902
3 5500 0.330 0.120
Average 5440 0.246 0.0905 881.9°F
Additionally,2.2.B.Lf requires"For the catalytic oxidizer(ID No.CD-W-New-CO),the Permittee shall
maintain the 3-hour block average catalytic oxidizer firebox temperature equal to or above the three-hour