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VERMONT AGENCY OF NATURAL RESOURCES Department of Environmental Conservation

Air Quality & Climate Division

TECHNICAL SUPPORT DOCUMENT

FOR

PERMIT TO CONSTRUCT AND OPERATE

#AOP-10-009 DEC PIN# EJ95-0450.04

Permit Date: 9/6/2017

Plumrose USA, Inc. – Swanton, VT

Owner/Operator: Plumrose USA, Inc. 1901 Butterfield Road; Suite 305 Downers Grove, IL 60515

Source: Meat Preparation & Packaging Facility Plumrose USA, Inc. 14 Jonergin Drive Swanton, VT 05488

Prepared By: Steven Snook – Environmental Engineer

Air Quality & Climate Division This Technical Support Document details the Agency of Natural Resources, Department of Environmental Conservation, Air Quality & Climate Division review for the Air Pollution Control Permit to Construct and Operate is intended to provide additional technical information, discussion and clarification in support of the Permit. It is not intended to provide a comprehensive review of the Facility or permit process or duplicate the information contained in the Permit.

Plumrose USA, Inc. AOP-10-009

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1.0 INTRODUCTION Plumrose USA, Inc. (hereinafter “Permittee”) owns and operates the meat processing and packaging facility (also referred to herein as “Facility”) at 14 Jonergin Drive in the town of Swanton, Vermont. For space heat and process heat, the Facility has three boilers, a hot water heater and three make-up air handling units (MAU). Note that in 2012, the Permittee proposed to add MAU-3. At that time, it was determined a permit application was not needed for this piece of equipment and its installation approved via an email dated 7/18/2012. This permit includes emission estimates for MAU-3. This permit also includes emission estimates for the small and large smokers at the Facility.

Table 1-1: Administrative Summary

Administrative Item Result or Date

Date Application Received: 6/7/2010

Date Administratively Complete: 6/8/2010

Date & Location Receipt of Application Noticed: 6/10/2010

Saint Albans Messenger

Date Technically Complete: 7/13/2012

Date Draft Decision: 08/22/2017

Date & Location Draft Decision/Comment Period Noticed:

08/22/2017

VTDEC Environmental Notice Bulletin

Date & Location Public Meeting Noticed: None requested

Date & Location of Public Meeting: None requested

Deadline for Public Comments: 9/1/2017

Date Final Decision: 9/6/2017

Classification of Source Under §5-401: §5-401(6): Fuel burning installations

Classification of Application: Subchapter X

New Source Review Designation of Source: Non-Major Stationary Source

Facility SIC Code(s) & Description(s): 2013 – Sausages and Other Prepared Meat Products

Facility NAICS Code(s) & Description(s): 311612 – Meat Processed from Carcasses


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The allowable emissions for the Facility are summarized below:

Table 1-2: Estimated Air Contaminant Emissions (tons/year)1

PM / PM10 / PM2.5 CO NOx SO2 2 VOC Total HAPs 3 CO2e 4

1.2 7.9 10.8 0.8 <1 <10/25 17,754

1 PM/PM10/PM2.5 - particulate matter, particulate matter of 10 micrometers in size or smaller and particulate matter of

2.5 micrometers in size or smaller, respectively (unless otherwise specified, all PM is assumed to be PM2.5); SO2 - sulfur dioxide; NOx - oxides of nitrogen measured as NO2 equivalent; CO - carbon monoxide; VOCs - volatile organic compounds; HAPs - hazardous air pollutants as defined in §112 of the federal Clean Air Act.

2 Commencing July 1, 2018 the allowed sulfur content of distillate fuel oils will decrease to 0.0015% by weight, further decreasing Facility allowed SO2 emissions from fuel oil combustion unless otherwise already restricted by the permit herein.

3 For purposes of designation of the Facility as a major or minor source of federal hazardous air pollutants (HAPs), the emissions of individual HAPs from the Facility are each <10 tpy and emissions of total HAPs combined are <25 tpy. Actual total combined HAPs from the Facility are estimated at <1 tpy

4 For CO2e ‘at the stack’ – includes emissions from biogenic sources. See section 3.3 for details. This is not a facility limit

2.0 FACILITY DESCRIPTION AND LOCATION

2.1 Facility Locations and Surrounding Area The Permittee owns and operates the meat processing and packaging facility located at 14 Jonergin Drive, Swanton, Vermont. The area surrounding the Facility is primarily industrial and commercial.

2.2 Facility Description

The regulated sources of air contaminant emissions at the Facility are listed in Table 2-1. Refer to Table 2-2 for information on air pollution control equipment used at the facility

TABLE 2-1: Equipment and Stack Information

Description and Model Number

Size or Capacity

Fuel type(s) or process

input

Stack Height (feet above

roof)

Date Installed

Pollution Control

Equipment

Boiler B-1 Bryan Steam, LLC Model# L 64 S 150

FD (S/N 55091)

4.3 MMBtu/hr

Natural Gas with

No.2 oil backup

8 1981 None

Boiler B-2 Bryan Steam, LLC Model# RV450-S-150-FDGO (S/N 92080)

4.5 MMBtu/hr

8 2004 None

Boiler B-3 Johnston Model PFTA200-4 (S/N

105430-0)

8.2 MMBtu/hr

8 2006 None

KEMCO Model GP hot water heater

3.5 MMBtu/hr

Natural Gas 8 2005 None


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TABLE 2-1: Equipment and Stack Information

Description and Model Number

Size or Capacity

Fuel type(s) or process

input

Stack Height (feet above

roof)

Date Installed

Pollution Control

Equipment

Make-up air unit MAU-1 1.98

MMBtu/hr Natural Gas - - None


MMBtu/hr Natural Gas - - None


MMBtu/hr Natural Gas - 2012 None

Small smoker 0.5 lb/hr

wood ‘firing’ rate 2

Electricity and wood

Vents through Oven #1 - None

Larger smoker 1.0 lb/hr

wood ‘firing’ rate 2

Electricity and wood

Vents through Ovens #2 & #3 - None

1 MMBtu/hr – million British Thermal Units per hour 2 wood ‘firing’ rate from application for AOP-12-034.

2.3 Description of Compliance Monitoring Devices This Facility is not equipped with devices to continuously monitor the emission of air contaminants to the ambient air.

2.4 Proposed Modifications to Facility In conjunction with this renewal of the operating permit, the Permittee has not proposed to modify the Facility.

2.5 Identification of Sources with Insignificant or Negligible Emissions Although not required for determining applicability with Subchapter X, quantifiable emissions from “insignificant activities” must be included for the purposes of establishing whether or not a source is subject to other air pollution control requirements, including, but not limited to: reasonably available control technology, major source status, and Title V operating permit applicability.

Table 2-3 lists activities at the Facility which were considered negligible or exempt sources of air contaminant emissions, and therefore were not considered as emission sources as part of the Operating/Construction Permit review.

Table 2-2: Negligible Sources of Contaminant Emissions

Fuel storage tanks: 2,500-gallon Kerosene or No. 2 fuel oil storage tank.


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It should be noted that a process or piece of equipment which is considered a “negligible activity” does not relieve the owner or operator from the responsibility of complying with any applicable requirements associated with said process or equipment.

3.0 QUANTIFICATION OF POLLUTANTS The quantification of emissions from a stationary source is necessary in order to establish the regulatory review process necessary for the operating permit application and to determine applicability with various air pollution control requirements. These determinations are normally based upon allowable emissions. Allowable emission is defined as the emission rate calculated using the maximum rated capacity of the source and, if applicable, either: (a) the applicable emission standard contained in the Regulations, if any, or (b) the emission rate or design, operational or equipment standard specified in any order or agreement issued under the Regulations that is state and federally enforceable. An applicant may impose in its application an emission rate or design, or an operational or equipment limitation which may be incorporated in the Permit to restrict operation to a lower level. Such limitations may include fuel restrictions or production limits.

3.1 Estimating Potential Emission of Criteria Pollutants from the Existing Stationary Source

For the boilers, the Facility has a fuel cap of 200,000 gallons of No. 2 fuel oil and no limit on the amount of natural gas. Table 3-1 summarizes the potential emissions from the No. 2 fuel oil used in the three boilers:

Table 3-1: Oil Fired Boilers - Allowable Emissions Total Fuel input all three Boilers: 200,000gallons/yr No.2 Fuel Oil

Pollutant

Emission Factor Allowable Emissions

(tons per year) Factor Units 2 Source

PM 3.3

lb/1000 gal

AP-42, Fuel Oil Combustion, Tables 1.3-1 and 1.3-2 (5/10)

0.33

CO 5

AP-42, Fuel Oil Combustion, Table 1.3-1 (5/10)

0.5

NOx 20 2.0

SO2 142S 1 0.7

VOC 0.34 AP-42, Fuel Oil Combustion, Table 1.3-3 (5/10) 0.03

HAPs 0.062 AP-42, Fuel Oil Combustion, Tables 1.3-8 to 1.3-10 (5/10)

0.01

1 S represents the weight % of sulfur in the oil. For example, if the fuel is 0.05% sulfur, then S=0.05, and the

emission factor is 7.1 lb/1000 gal 2 lb/1000 gal: pounds of pollutant emitted per 1000 gallons of fuel input to the boiler.

How much time does it take to burn 200,000 gallons in the three boilers? The combined boiler heat output is 17 MMBtu/hr. The heat value for No.2 fuel oil is 0.14 MMBtu/gallon.


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(200,000 gallons) * (0.14 MMBtu/gallon) / (17 MMBtu/hr) = 1,647 hours/hr

There is available capacity for the boilers to burn more fuel (natural gas).

8,760 – 1,647 = 7,113 hours/yr.

How much natural gas can be consumed during the 7,113 hours?

(7,113 hrs) * (17 MMBtu/hr) * (106 Btu/MMBtu) * (CF/1020 Btu) * (MMCF/106 CF) = 118.5 MMCF

The KEMCO hot water heater also burns natural gas and uses the same factors to estimate the emissions. The total potential natural gas from the KEMCO will be added to the boilers.

(3.5 MMBtu/hr) * (106 Btu/MMBtu) * (8,760 hr/yr) * (CF/1020 Btu) * (MMCF/106 CF) = 30.1 MMCF The total potential heat input for the three make-up air units is 3.1 MMBtu/hr.

(3.1 MMBtu/hr) * (106 Btu/MMBtu) * (8,760 hr/yr) * (CF/1020 Btu) * (MMCF/106 CF) = 26.7 MMCF Total potential natural gas usage from the boilers, KEMCO hot water heater and the make-up air units: 118.5 MMCF + 30.1 MMCF + 26.7 MMCF = 175.3

Table 3-2: Natural Gas– Allowable Emissions All Natural Gas Combustion Units

Total Fuel input: 175.3 MMCF natural gas.

Pollutant

Emission Factor Allowable Emissions (tons/year) Factor Units 1 Source

PM 7.6

lb/MMCF

AP-42, Natural Gas Combustion, Table 1.4-2, 7/98 0.67

CO 84 AP-42, Natural Gas Combustion, Table 1.4-1, 7/98

7.36

NOx 100 8.76

SO2 0.6 AP-42, Natural Gas Combustion, Table 1.4-2, 7/98

0.05

VOC 5.5 0.48

HAPs 1.89 AP 42, Natural Gas Combustion, Tables 1.4-3 & 1.4-4 (7/98)

0.17

1 lb/MMCF: pounds of pollutant per million cubic feet of natural gas combusted.


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This facility has two smoker units that are used in conjunction with some of the ovens to add flavor, color and aroma to various meats. The smoke is created by pyrolyzing hardwood chips or sawdust using an electrically heated metal surface in the smoker. The smoke generated by the small smoker is ducted to Oven #1 and the smoke generated by the large smoker is ducted to either Oven #2 or #3. In the application for permit AOP-12-033, the small and large smokers were reported to have a maximum wood usage rate of 0.5 lb/hr and 1.0 lb/hr respectively.

In the AP-42 report ‘9.5.2 Meat Smokehouses,’ the U.S. EPA has developed some limited emission information for both batch and continuous smokehouses. The EPA determined that the emissions are dependent on the quantity of wood used rather than the quantity of meat processed, so the available emission factors have the units of pounds of pollutant emitted per ton of wood processed. The EPA does not specify a moisture content for the wood chips: For the purposed of calculating emissions for this review it is assumed there is no moisture in the wood chips.

Table 3-3: Estimated Emissions from Smokers

Annual maximum wood usage, based on 1.5 lb/hr: 6.57 tons/year.

Pollutant

Emission Factor Potential Emissions (tons/year) Factor (lb/ton) Reference

PM 53 AP-42, Meat Smokehouses Table 9.5.2-1 (9/95) 0.174

VOC 44 AP-42, Meat Smokehouses Table 9.5.2-2 (9/95) 0.145

Table 3-4: Summary of Allowable Air Contaminant Emissions by Source (tons/year)

Source PM / PM10 / PM2.5 CO NOx SO2 VOC Total HAPs

Boilers B-1 through B-3 fuel oil only

0.33 0.50 2.00 0.710 0.034 0.006

All combustion sources - firing Natural Gas

0.67 7.36 8.76 0.053 0.48 0.17

Smokers (large and small) 0.17 - - - 0.145 -

Estimated Facility Emissions 1.17 7.86 10.76 0.76 0.66 0.17

Allowable Facility Emissions 1.2 7.9 10.8 0.8 <1 <10/25


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As summarized in Table 3-5 above:

• The Facility has allowable emissions of all air contaminants in the aggregate of ten (10) or more tons per year: the Facility is therefore subject to Subchapter X of the Regulations and is designated as a Subchapter X Major Source.

• The Facility does not have allowable emissions of any contaminant which would classify the source as a “Major Source” and therefore is not subject to the new source review requirements of §5-502 of the Regulations.

• The Facility does not have allowable emissions of any contaminant which would classify the source as a "Title V Subject Source" and therefore is not subject to the federal operating permit requirements of 40 C.F.R. Part 70 or 71.

3.2 Estimating Actual Emissions of Hazardous Air Contaminants from the Existing Stationary Source

The EPA AP-42 section on Meat Smokehouses notes the following compounds are associated with meat smokehouses: polycyclic aromatic hydrocarbons (PAH), organic acids, acrolein, acetaldehyde and formaldehyde. The primary source of these pollutants is the wood smoke. The EPA has established emission factors for only two of these compounds: formaldehyde and acetic acid. These factors were only for continuous smokehouses and were assigned the lowest emission factor rating of E. In addition, there is no actual information regarding wood usage or HAC emissions from the Facility. At this time, the Agency is concluding that there is not sufficient information available to estimate the mass emission rate of hazardous air contaminants from the batch smokehouse process at this Facility.

The Facility does not have anticipated emissions of identified hazardous air contaminant compounds that exceed their Action Levels.


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3.3 – Estimating Potential Green House Gas Emissions

Facility: Plumrose USA Inc Permit #: AOP-10-009 Date: 7/21/2017

Source Source Quantity

ID Description Combusted Units

200,000 gallons 0 10.0%

175,274,314 scf 0 0.0%

Table 2. Total Company-Wide Stationary Source Fuel Combustion

Quantity

Fuel Type Combusted Units

639,000 gallons

175,274,314 scf

Table 3. Total Company-wide CO2, CH4 and N2O Emissions from Stationary Source Fuel Combustion

CO2 CO2 CH4 CH4 N2O N2O

(kg) (lb) (kg) (lb) (kg) (lb)

Distillate Fuel Oil #2 6,521,941 14,378,401 264.5 583.2 52.9 116.6

Natural Gas 9,553,249 21,061,285 180.2 397.2 18.0 39.7

Total Fossil Fuel Emissions 16,075,190 35,439,686 444.7 980.5 70.9 156.4

Total Non-Fossil Fuel Emissions 0 0 0.0 0.0 0.0 0.0

Total Emissions for all Fuels 16,075,190 35,439,686 444.7 980.5 70.9 156.4

Global Warming Potential CO2 CH4 N2O

1.0 21.0 310.0 metric ton short ton

Total CO2 Emissions - Equivalent (Fossil CO2e + Biogenic CH4 & N2O) 16,106.5 17,754.4

All CO2e emissions at stack (Fossil CO2e + Biogenic CO2e) - for APCD Permit info 16,106.5 17,754.4

Fuel Type

CO2e

Natural Gas

Distillate Fuel Oil #2

Fuel Combusted

Distillate Fuel Oil #2

Natural Gas


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4.0 DISCUSSION OF SELECT APPLICABLE AND NON-APPLICABLE REQUIREMENTS The Agency will assess compliance with these regulations during any inspections of the Facility. The inspections will include confirmation of the proper operation and maintenance of equipment and air pollution control devices, visual observations of emission points, and review of any records required by the Permit.

4.1 Vermont Air Pollution Control Regulations and Statutes

§5-201 and §5-202 - Open Burning Prohibited and Permissible Opening Burning This emission standard, which regulates the open burning of materials, applies to the entire Facility. Open burning of materials is prohibited except in conformance with the requirements of this section

§5-211(2) - Prohibition of Visible Air Contaminants - Installations constructed subsequent to April 30, 1970 This emission standard applies to the entire facility.

§5-221(1) - Prohibition of Potentially Polluting Materials in Fuel; Sulfur Limitation in Fuel This prohibition applies to all stationary fuel burning equipment used on-site. Based on the application submittal, the applicant is expected to comply with this regulation based on the use of natural gas and distillate oil. Natural gas by its official fuel specification definition, comply with this requirement. Based on the application submittal the applicant is expected to comply with this regulation based on the use of distillate fuel oil certified by the supplier to contain no more 0.05% sulfur by weight.

§5-231(3) - Prohibition of Particulate Matter; Combustion Contaminants Based on the application submitted and information available to the Agency, this Facility currently has applicable fuel burning equipment subject to this regulation. The allowable particulate emissions from the subject equipment is shown in Table 4-1.

Table 4-1: Equipment Subject to §5-231(3)

Equipment ID Capacity (MMBtu/hr)

Emission Standard (lbs/MMBtu)

Allowable Emissions (lbs/hr)

B-1 4.3

0.5

2.15

B-2 4.5 2.25

B-3 8.2 4.10

Hot Water Heater 3.5 1.75

§5-241(1) - Prohibition of Nuisance and Odor; Nuisance This requirement applies to the entire Facility and prohibits the discharge of air contaminants that would be a nuisance to the public or the discharge of objectionable odors beyond the property-line of the Facility.

§5-402 – Written Reports When Required This section gives the Agency authority to require the Facility to submit reports summarizing records required to be maintained by the Agency. The Agency will assess


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compliance with this regulation in the future during any inspections of the Facility.

§5-403 – Circumvention This section prohibits the dilution or concealment of an air discharge in order to avoid air pollution control requirements. The Agency will assess compliance with this regulation in the future during any inspections of the Facility.

Subchapter VIII – Registration of Air Contaminant Source. This Subchapter requires the owner or operator of a stationary source register with the Agency if the source produces five (5) tons per year or greater of actual emissions during the preceding calendar year. The owner or operator of a source is required to submit information regarding their operations and pay a fee based upon the quantity of emissions they produce and the fuels that they use at the source.

The Permittee is currently in compliance and has been registering its emissions with the Agency annually on those years when its total emissions exceed 5 tons per year.

4.2 Federal Air Pollution Control Regulations and the Clean Air Act

Section 111 of the Clean Air Act - New Source Performance Standards (NSPS). NSPSs are promulgated under Title 40 of the Code of Federal Regulations ("40 C.F.R.") Part 60. The NSPSs that were reviewed for applicability and the applicable NSPSs are summarized in the following table.

Table 4-2 Applicable Requirements from Section 111 of the Clean Air Act

New Source Performance Standards (NSPSs)

40 CFR Part 60, Subpart Dc - Standards of Performance for Small Industrial-Commercial- Institutional Steam Generating Units. Applies to all boilers 10 MMBTU/hr or greater manufactured after June 9, 1989. Units larger than 30 MMBTU per hour installed after February 27, 2005 are subject to additional particulate matter requirements. The Facility is not subject to this regulation. All of the boilers at the Facility are rated at less than 10 MMBtu/hr.

5.0 CONTROL TECHNOLOGY REVIEW FOR MAJOR SOURCES AND MAJOR

MODIFICATIONS The Facility is not undergoing changes subject to new source review, therefore this section is not applicable. 6.0 AMBIENT AIR QUALITY IMPACT EVALUATION The Facility is not undergoing changes subject to new source review; therefore this section is not applicable.


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7.0 HAZARDOUS AIR CONTAMINANTS The emissions of hazardous air contaminants (“HACs”) are regulated under to §5-261 of the Regulations. The Owner/Operator of a source must quantify its emissions of HACs regulated by this rule. Any Facility whose emission rate of a HAC exceeds its respective Action Level (“AL”) is subject to the rule for the HAC, and the Owner/Operator must then demonstrate that the emissions of the HAC are minimized to the greatest extent practicable by achieving the Hazardous Most Stringent Emission Rate (“HMSER”) for that HAC. If the emission rate of any HAC after achieving HMSER is still estimated to exceed its action level after achieving HMSER, an air quality impact evaluation may be required to further assess the ambient impacts for compliance with the Hazardous Ambient Air Standard (“HAAS”) or Stationary Source Hazardous Air Impact Standard (“SSHAIS”). It should be noted that solid fuel burning equipment (not including incinerators) installed or constructed prior to January 1, 1993, and all fuel burning equipment which combust virgin liquid or gaseous fuel shall not be subject to the requirements of §5-261. As discussed in Section 3.2, emissions from the Facility are not anticipated to exceed the action levels for the HACs included in this evaluation. Therefore, the Facility is not subject to §5-261 of the Regulations at this time. The emission of hazardous air pollutants (“HAPs”) may also be regulated separately under to §112 of the Federal Clean Air Act. This facility has a permit condition limiting the emissions of HAPs to 10 ton/year of any single HAP and 25 tons/year of all HAPS combined, therefore the facility is not subject to the federal HAP standards.

Download - TECHNICAL SUPPORT DOCUMENT FOR PERMIT TO CONSTRUCT … · Plumrose USA, Inc. AOP-10-009 Page 7 of 12 This facility has two smoker units that are used in conjunction with some of the

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