Anrweb.vt.gov
VERMONT AGENCY OF NATURAL RESOURCES
Department of Environmental Conservation
Air Pollution Control Division
TECHNICAL ANALYSIS OF AN AIR CONTAMINANT SOURCE
FOR A PERMIT TO CONSTRUCT AND OPERATE
#AOP-01-024
DEC# BR97-0027
March 25, 2003
Prepared By: Justin Sorenson, Environmental Engineer
Doug Elliott, Environmental Analyst
APPLICANT: Green Mountain Coffee Roasters, Inc.
33 Coffee Lane
Waterbury, Vermont 05676-1529
SOURCE: Coffee Roaster Facility
Green Mountain Coffee Roasters, Inc.
33 Coffee Lane
Waterbury, Vermont 05676
RESPONSIBLE
OFFICIAL: Paul Comey, VP of Facilities
Green Mountain Coffee Roasters, Inc.
APPLICATION
CONTACT: Paul Comey
Green Mountain Coffee Roasters, Inc.
33 Coffee Lane
Waterbury, Vermont 05676-1529
Tel. - (802) 882-2137
Fax - (802) 882-4137
TOWN: Waterbury
COUNTY: Washington
AREA DESIGNATION: Attainment for PM10, SO2, NOx, CO, and Pb and Unclassified for O3
UTM COORDINATES: 678985 mE, 4911575 mN - Zone 18T
(Approximate center of Facility)
I. INTRODUCTION
Green Mountain Coffee Roasters, Inc. (hereinafter "GMCR" and also referred to herein as "Owner/Operator") owns and operates the coffee roasting facility (also referred to herein as "Facility") at 33 Coffee Lane in Waterbury, Vermont. The Facility purchases green coffee beans and roasts them in one of several roasters on site. The roasted beans are then packaged and shipped for sale. The Facility consists of three Probat EN500R 280 pound batch roasters. GMCR has proposed to install two Probat RZ4000 880-pound batch roasters, increase green bean throughput from the current 12 million pounds per year to a maximum of 50 million pounds per year, and install a second propane-fired Waukesha Engine generator. All five (5) of the roasters are to be equipped with catalytic oxidizers for control of air emissions.
A. Administrative Summary
GMCR submitted a combined application for an Air Pollution Control Permit to Construct the proposed changes and Operate the Facility (#AOP-01-024) on June 29, 2001. The application was determined to be administratively complete on July 13, 2001. This Technical Analysis details the Agency of Natural Resources, Department of Environmental Conservation, Air Pollution Control Division's (hereinafter "Agency") review for the combined Air Pollution Control Permit to Construct and Operate the Facility.
Table 1-1: Administrative Summary
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|Facility SIC Code Description(s): |Roasted Coffee |
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|*| | | | | |
| | | | | | |
|PM/PM10 |SO2 |CO |NOx |VOCs |HAPs** |
* PM/PM10 - particulate matter and particulate matter of 10 micrometers in size or smaller, SO2 - sulfur dioxide, NOx - oxides of nitrogen, CO - carbon monoxide, VOCs - volatile organic compounds, Pb - lead, HAPs - hazardous air pollutants as defined in (112 of the federal Clean Air Act.
** Total HAPs are less than 25 tons per year and each individual HAP is less than 10 tons per year.
II. BASIS OF REVIEW
A. Facility Classification
The Facility is classified as a source of air contaminants pursuant to (5-401(17) [Other sources as may be designated by the Air Pollution Control Officer] of the Vermont Air Pollution Control Regulations (hereinafter "Regulations"). In addition, (5-101 of the Regulations defines a stationary source as any structure(s), equipment, installation(s), or operation(s), or combination thereof, which emit or may emit any air contaminant, which is located on one or more contiguous or adjacent properties and which is owned or operated under common control. Based on this definition, all of the equipment, operations, and structures at the Facility are grouped together by the Agency as one stationary air contaminant source for purposes of review under the Regulations.
B. Prior Approvals
GMCR began operations at the Waterbury location in 1985. Numerous odor violations led to an Assurance of Discontinuance issued on January 19, 1990. The AOD required emission controls on the Probat roaster and limited operation of the uncontrolled Sivetz roaster. A temporary permit (#AP-90-054) was issued on October 25, 1990 allowing the second Probat EN500R roaster to be installed with emission controls. The final permit (#AP-90-054a) was issued on January 20, 1993 and restricted annual green throughput to 4 million pounds. On January 25, 1995 permit #AP-90-054b was issued granting approval for a third Probat EN500R roaster and increased annual throughput to 12 million pounds of green beans. The current permit request (#AP-01-024) is to add two Probat RZ4000 roasters and increase maximum annual throughput to 50 million pounds.
Table 2-1: Prior Agency Approvals
| | |
|Date Approval Issued |Description of Approval/Amendment |
| | |
|January 19, 1990 |AOD issued requiring emission controls for odors and VE |
| | |
|October 25, 1990 |#AP-90-054 - Temporary permit allowing second Probat EN500R roaster with controls |
| | |
|January 20, 1993 |#AP-90-054a - Restricted annual green bean throughput to 4 million pounds |
| | |
|January 25, 1995 |#AP-90-054b - Amendment approving third Probat EN500R, annual green bean throughput increase to 12 |
| |million pounds |
C. Proposed Project and Permit Applicability
As noted above, GMCR is classified as a source of air contaminants under Section 5-401 of the Regulations. Pursuant to Title 10 Vermont Statutes Annotated, (hereinafter "V.S.A.") (556, GMCR must apply for and obtain an Air Pollution Control Permit to Construct before commencing the construction, installation, operation or modification of the source. In addition, pursuant to Title 10 Vermont Statutes Annotated, (hereinafter "V.S.A.") (556a and ((,5-1002, 5-1003, and 5-1005 of the Regulations, GMCR is classified as a "Subchapter X Major Source" and is subject to the requirement to obtain an Air Pollution Control Permit to Operate. However, GMCR 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 Title 40 Part 70 or 71 of the Code of Federal Regulations ("CFR").
Consistent with 10 V.S.A. (556(e), the Agency proposes to combine the review for the Permit to Construct and the Permit to Operate and issue a combined Permit to Construct and Operate.
III. FACILITY LOCATION AND DESCRIPTION
A. Facility Location
GMCR owns and operates the coffee roasting facility located at 33 Coffee Lane, Waterbury, Vermont. The area surrounding the Facility is primarily mixed commercial and residential. The Facility is located greater than 100 kilometers from the Lye Brook Wilderness area in Manchester, Vermont and greater than 100 kilometer from the Great Gulf and Dry River Wilderness areas in New Hampshire. The Facility location and layout are depicted in Appendix A of this Technical Analysis.
A. Facility Description
The Facility is a source type listed under the Standard Industrial Classification ("SIC") Code 2095, Roasted Coffee. The regulated sources of air contaminant emissions at the Facility are the five coffee roasters, the roasted coffee bean cooling exhaust, the two propane-fired generators, and the bean transport exhaust system.
GMCR has proposed to modify the Facility by adding two additional coffee roasters, one additional generator, and increasing the annual green bean throughput from 12 million pounds to 50 million pounds. Each new roaster is a Probat RZ4000 880-pound batch roaster rated at 6.75 MMBtu/hr. Each new roaster will be equipped with a Maxon Oven PAC catalytic incinerator for visible emission and odor control. The second generator is a propane-fired Waukesha Enginator F18GLD rated at 249 HP.
The existing three roasters are Probat EN500R 280-pound batch roasters rated at 1.25 MMBtu/hr each. These existing roasters are equipped with Probat NVK-500 1-2E catalytic incinerators. The existing generator is a propane-fired Waukesha VSG11G engine generator rated at 135 HP.
Green beans are delivered to the Facility, weighed for processing, and moved by bucket elevator(Probat EN500R) or pneumatically conveyed(Probat RZ4000) to overhead hoppers. Fans pull air from the hoppers to fabric filters to control particulate from the bean handling. The fabric filters exhaust internally. The preheated roasters are charged with green beans and then the beans undergo several different temperature cycles which correspond to specific roasting profiles. The automated roasting cycles are computer controlled and supervised by Facility personnel. The hot combustion air from the roaster burner roasts the green beans through direct contact. Following the roasting process, the hot exhaust gases pass through a cyclone to remove chaff and then are returned as preheated combustion air for the roaster burner or conveyed through a catalytic incinerator prior to rooftop emission. In order to accommodate the recycling of the roaster exhaust, a portion of the burner exhaust gases are continuously vented through a catalytic incinerator to the ambient air. In the event of a roaster exhaust explosion, an emergency rooftop bursting vent allows the explosion to burst into the atmosphere rather than into the Facility. At the end of a roasting cycle, the water quench activates and sprays the hot roasted beans with a preset volume of water. Steam and odor are generated by the quench process. The roasted beans are then transferred to the cooling trays which cool and clean the beans by pulling air through the beans while mixing them. Some coffee aroma may be emitted by the bean cooling system, but most of the visible emissions and odors are generated from the roasting and water quench cycles. For the EN500R roasters, there is no appreciable chaff generated by the stir flex cooling system and this is vented to the out the outside air uncontrolled. For the RZ4000 roasters, the cooling air exhausts through a cyclone and is then emitted to the atmosphere. All cyclones dump via air-locks to the nitrogen-charged chaff system. The chaff collecting system is closed-looped and nitrogen-charged so as to prevent hot coffee bean chaff from igniting. The cooled beans are then weighed and pneumatically conveyed through destoners. The destoner serves as a air classifier in which the particles that are lighter than the beans pass upward through a cyclone collector while the heavier beans drop out and are conveyed to hoppers. For the EN500R roasters, the destoner air passes through fabric filters and is then vented inside the Facility. For the RZ4000 roasters, the destoner air passes through a cyclone and is then exhausted to the atmosphere. From the hoppers, the beans are packaged as whole beans or sent to a grinder for ground coffee packaging.
C. Insignificant Activities
GMCR operates several propane-fired space heating units rated at less than 3.0 MMBtu/hr. They are considered insignificant activities under Subchapter X of the Regulations.
IV. QUANTIFICATION OF POLLUTANTS
The quantification of emissions from a stationary source is necessary in order to establish the regulatory designation of the Facility and proposed modification, and consequently determine the level of review that is required under the Regulations. The designation of a stationary source is determined by its allowable emissions. Allowable emissions are 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 these Regulations that is state and federally enforceable". This means that allowable emissions must be determined assuming continuous operation of the stationary source (i.e.. 8760 hours per year) at maximum capacity, unless the owner/operator of the source operates under enforceable limits that restrict operation to a lower level. An applicant may impose in its application an emission rate or design, operational or equipment limitation on its operations to be incorporated into the permit to restrict the Facility's allowable emissions. Such limitations may include fuel restrictions such as a limit on sulfur content of the fuel below the regulation maximum allowable, a restriction on annual fuel usage, or a production limit such as a cap on the amount of product to be produced on which the allowable emissions would be calculated.
A. Designation of Existing Stationary Source for the Permit to Construct
The designation of the existing stationary source, prior to any proposed modifications, is determined by its allowable emissions. Any existing facility with allowable emissions equal to or greater than 50 tons per year for any air contaminant, or 5 tons per year for lead, is designated as a major stationary source. Since the existing Facility currently operates under an Air Pollution Control Permit to Construct, the allowable emissions are based on the limitations of the Regulations as well as any limitations of the existing Permit. The regulated sources of air contaminants at the Facility are the Probat coffee roasters(and their associated exhausts). The existing Waukesha VSG11G generator is less than 450 horsepower and is therefore not subject to (5-271 of the Regulations. However, recent information given to the Agency by Waukesha for the VSG11G generator shows that the uncontrolled NOx emission rate is 25 g/bhp-hr. Because of this elevated NOx emission rate, the Agency proposes to limit the annual operation to 2000 hours or require the installation of a catalytic converter. If GMCR elects to install a catalytic converter to reduce this emission rate to the standards found within (5-271 of the Regulations, they may operate the engine without an hourly cap. The propane-fired space heaters and hot water heater are considered insignificant activities under Subchapter X of the Regulations and the emissions are considered negligible. Therefore, emissions from these activities are not quantified. The allowable emissions of particulate matter ("PM/PM10"), sulfur dioxide ("SO2"), oxides of nitrogen ("NOx"), carbon monoxide ("CO"), and volatile organic compounds ("VOCs") from the other regulated sources of air contaminants at the Facility must be calculated.
The existing Facility's allowable emissions from Permit #AP-90-054b are summarized in Table 4-1. The existing Facility's allowable emissions are estimated to be less than major source levels for each air contaminant. Therefore, the existing Facility is designated as a non-major stationary source.
Table 4-1: Summary of Existing Facility Allowable Emissions
| | | | | | |
|Air Contaminant | | | | | |
|Emissions | | | | | |
|(tons/year) | | | | | |
| | | | | | |
|PM/PM10 |SO2 |NOx |CO |VOCs |HAPs |
B. Designation of Facility for the Permit to Construct and Operate
The designation of the Facility for the Permit to Construct and Operate is determined by its allowable emissions following issuance of the permit, taking into account any limitations contained in the permit that restrict the Facility's allowable emissions. Any facility with proposed allowable emissions equal to or greater than 50 tons per year for any air contaminant, or 5 tons per year for lead, is designated as a major stationary source. Based upon its allowable emissions, as summarized in Table 4-2, the future Facility is designated as a non-major stationary source. Any facility that has allowable emissions of all air contaminants in the aggregate of ten (10) or more tons per year or any facility that is subject to a standard, limitation or other requirement under section 111/112 of the federal Clean Air Act (hereinafter "CAA") is subject to the operating permit requirements of Subchapter X of the Regulations. Calculations supporting the derivation of the allowable emissions may be found in Appendix B of this Technical Analysis.
Table 4-2: Summary of Facility Allowable Emissions
| | | | | | |
|Air Contaminant | | | | | |
|Emissions | | | | | |
|(tons/year) | | | | | |
| | | | | | |
|PM/PM10 |SO2 |NOx |CO |VOCs |HAPs |
As summarized in Table 4-2 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 "Title V Subject Source" and therefore is not subject to the federal operating permit requirements of 40 C.F.R. Part 70 or 71.
V. APPLICABLE REQUIREMENTS
Pursuant to (5-501(2) and (5-1006(e)(4) of the Regulations, the Owner/Operator of a stationary air contaminant source applying for a Permit to Construct and/or Operate is required to identify and certify compliance with all applicable state and federal air pollution control requirements before a permit may be issued. These requirements include state and federal regulations, state statutes, the federal Clean Air Act, and the requirements of any construction permit issued under 10 V.S.A. (556 and (5-501 of the Regulations. Applicable federal regulations may include Federal New Source Performance Standards (NSPS) or National Emission Standards for Hazardous Air Pollutants (NESHAP) found in Title 40 of the Code of Federal Regulations Parts 60, 61, and 63. The applicable requirements and the Agency's findings are presented below. Applicability of (5-261 (Control of Hazardous Air Contaminants) is discussed separately under Section VIII below.
The compliance analysis and determination in this technical analysis rely on data and representations provided by the Owner/Operator. Any statements and conclusions regarding the compliance status contained herein are not binding against the State of Vermont in any future legal or administrative proceedings.
A. Vermont Air Pollution Control Regulations and Statutes
(5-211(2) - Prohibition of Visible Air Contaminants - Installations constructed subsequent to April 30, 1970. "No person shall cause, suffer, allow or permit the emission of any visible air contaminant from installations constructed subsequent to April 30, 1970, for more than a period or periods aggregating six (6) minutes in any hour, which has a shade, or density, greater than 20% opacity (No. 1 of the Ringelmann Chart). At no time shall the visible air contaminants have a shade, density, or appearance greater than 60% opacity (No. 3 of the Ringelmann Chart). Compliance with these opacity standards shall be determined in accordance with the proposed Federal Reference Method F-1 contained in the Federal Register Vol.51, No.168, pp. 31076-31081, August 29, 1986 or an alternative method approved in writing by the Agency.
These emission standards apply to all installations at the Facility. The applicant is expected to comply with these emission standards based on proper equipment design, operation and maintenance.
The Agency will assess compliance with these emission standards in the future during any inspections of the Facility. The inspections will include confirmation of the proper operation and maintenance of equipment and the air pollution control devices and visual observations of emission points.
(5-221(1)(a) - Prohibition of Potentially Polluting Materials in Fuel. "No person shall cause or permit the use, purchase, or sale for use in stationary combustion installations within the State of Vermont for heat or power generation, fuels containing more than 2.0% sulfur by weight." Compliance with this standard is based on fuel analyses following the procedures prescribed by the American Society of Testing Materials ("ASTM").
This regulation applies to all of the stationary fuel burning equipment at the Facility. Based on the Facility(s application, the applicant is expected to comply with this regulation based on the use of propane. Natural gas and distillate oil, by their official fuel specification definition, comply with this requirement.
The Agency will assess compliance with this regulation in the future during any inspections of the Facility. The inspections will include confirmation of the use of the proper fuels and review of fuel delivery certifications.
(5-231(1)(b) - Prohibition of Particulate Matter; Industrial Process Emissions. "In cases where process weight is not applicable as determined by the Air Pollution Control Officer, the concentration of particulate matter in the effluent gas stream shall not exceed 0.14 grams per cubic meter (0.06 grains per cubic foot) of undiluted exhaust gas at standard conditions on a dry basis. In the case of wood processing operations, process weight is not applicable, and instead, the concentration standard specified in this subsection shall apply." Compliance with this emission standard shall be determined in accordance with Title 40 Code of Federal Regulations Part 60, Appendix A, Reference Method 5 or an alternative method approved in writing by the Agency.
Based on the application submittal and information available to the Agency, this Facility(s five Probat coffee roasters, the bean cooling exhaust systems, and the RZ4000's bean transport exhaust are currently subject to this regulation. Each Probat EN500R has a maximum capacity to roast 1,680 pounds of green beans per hour(0.84 tons/hour). From the U.S. E.P.A(s AP-42, Compilation of Air Pollutant Emissions, Table 9-13.2, batch roasters equipped with catalytic incinerators emit 0.12 pounds of particulate per ton of green bean throughput. This equates to an allowable emission rate of 0.10 pounds of particulate per hour ((0.84tons/hr)*(0.12lbs/ton)=0.10 lbs/hr).
Each Probat RZ4000 has a maximum capacity to roast 5,280 pounds of green beans per hour(2.64 tons/hour). Based on above analysis, this equates to an allowable emission rate of 0.32 pounds of particulate per hour ((2.64 tons/hr)*(0.12lbs/ton)=0.32 lbs/hr). Each roaster exhausts through its own stack.
From AP-42, Table 9-13.2 the five cooling exhaust stacks will contain 0.028 pounds of particulate per ton of green beans. The Agency estimates that the RZ4000 bean transport/destoner exhaust will contain a similar or less amount of particulate. Using this emission factor for both the cooling and bean transport exhaust, allowable particulate emission rates were calculated. The EN500R cooling exhaust will emit roughly 0.02 pounds of particulate per hour ((0.84tons green/hr)*(0.028 lb. particulate/ton green)) while the RZ4000 cooling and transport exhausts will each emit 0.07 pounds of particulate per hour ((2.64tons green/hr)*(0.028 lb. particulate/ton green)). Without some sort of control device, the emission rate from these exhausts approaches the 0.06 gr/dscf limit of the Regulations. Given the uncertainties of the AP42 emission factors (rating D), the Agency feels the units must be equipped with a cyclone control device at a minimum or else GMCR must provide test data to verify compliance. The RZ4000 units are already proposed to be equipped with cyclones. The EN500R units are all to be removed except one and that remaining one will be moved and fitted with a cylcone by December 31, 2003.
The Agency will assess compliance with this emission standard in the future during any inspections of the Facility. The inspections will include confirmation of the proper operation and maintenance of the required air pollution control devices and visual observations of the stack exhaust.
(5-231(3)(a) - Prohibition of Particulate Matter; Combustion Contaminants. "A person shall not discharge, cause, suffer, allow or permit the emission of particulate matter caused by the combustion of fossil fuel in fuel burning equipment from any stack or chimney in excess of the following emission limits:
(i) 0.5 pounds per hour per million BTU's of heat input in combustion installations where the heat input is 10 million BTU's or less per hour.
(ii) For combustion installations where the heat input is greater than 10 million BTU's per hour, but where the heat input is equal to or less than 250 million BTU's per hour, the applicable limit is determined by using the following formula:
[pic]
where:
EPM - is the particulate matter emission limit, expressed to the nearest hundredth pound per hour per million BTU's; and
HI - is the heat input in millions of BTU's per hour."
Compliance with this emission standard shall be determined in accordance with Title 40 Code of Federal Regulations Part 60, Appendix A, Reference Method 5 or an alternative method approved in writing by the Agency.
Based on the application submittal and information available to the Agency, the Facility(s five Probat coffee roasters and two Waukesha engine generators are subject to (5-231(3)(a)(i) of this Regulation. Each Probat EN500R is rated at 1.25 MMBTU/hr and is therefore limited to 0.5 lbs/hr-MMBTU. Each Probat RZ4000 is rated at 6.75 MMBTU/hr and is limited to 0.5 lbs/hr-MMBTU. Each Waukesha engine is rated well below 10 MMBTU/hr and therefore each engine is limited to 0.5 lbs/hr-MMBTU. The applicant is expected to comply with these emission standards based on AP-42 emission factors and information given to the Agency by Waukesha.
The Agency will assess compliance with this emission standard in the future during any inspections of the Facility. The inspections will include confirmation of the proper operation and maintenance of the fuel burning equipment and air pollution control devices and visual observations of the stack exhaust.
(5-231(4) - Prohibition of Particulate Matter; Fugitive Particulate Matter. "A person shall not cause, suffer, allow, or permit any process operation to operate that is not equipped with a fugitive particulate matter control system. A person shall not cause, suffer, allow, or permit any materials to be handled, transported, or stored; or a building, its appurtenances, or a road to be used, constructed, altered, repaired or demolished without taking reasonable precautions to prevent particulate matter from becoming airborne. Public roads will not be subject to this section unless a public nuisance is created."
Based on the application submittal and information available to the Agency, the Facility currently is considered a source of fugitive particulate matter subject to this regulation. The Facility is required to take reasonable precautions at all times to control and minimize emissions of fugitive particulate matter from the operations at the Facility. This includes but is not limited to the following:
(a) Taking precautions to prevent fugitive particulate matter (ie. coffee bean chaff) during the handling and disposal of the green and roasted coffee bean material collected from the handling, transport, roasting, exhaust, and disposal operations. The Agency may require additional dust control measures on these operations based on Agency inspections of the actual operations.
The Facility is expected to comply with the fugitive emission limitations of this section.
The Agency will assess compliance with these emission limitations in the future during any inspections of the Facility. The inspections will include confirmation of the proper operation of any fugitive particulate matter control measures and visual observations of any emission points.
(5-241(1) and (2) - Prohibition of Nuisance and Odor. "A person shall not discharge, cause, suffer, allow, or permit from any source whatsoever such quantities of air contaminants or other material which will cause injury, detriment, nuisance or annoyance to any considerable number of people or to the public or which endangers the comfort, repose, health or safety of any such persons or the public or which causes or has a natural tendency to cause injury or damage to business or property. A person shall not discharge, cause, suffer, allow, or permit any emissions of objectionable odors beyond the property line of a premises."
Based on the application submittal and information available to the Agency, the Facility is currently in compliance with this regulation. The Facility declares that all coffee roasters will be equipped with catalytic incinerators for the control of odors and visible emissions. In addition, all process air will pass through cyclone collectors prior to exhausting to the atmosphere. The Agency will assess compliance with these emission limitations in the future during any inspections of the Facility.
(5-402 - Written Reports When Requested. (The Air Pollution Control Officer may at any time require written reports from the person operating or responsible for any proposed or existing air contaminant source, which reports shall contain information concerning location, siting, size, and height of contaminant outlets, processes employed, pertinent process and material flow, fuels used, nature and amount and time periods or durations of emissions and such other information as may be relevant to the air pollution potential of the source. These reports shall also include the results of such source testing as may be required under Section 5-404 herein.
(5-403 - Circumvention. "No Person shall build, erect, install or use any article, machine, equipment or other contrivances, the use of which, without resulting in a reduction in the total release of air contaminants to the atmosphere, reduces or conceals an emission which otherwise would constitute a violation of these regulations."
Based on the application submittal and information available to the Agency, the Facility is currently in compliance with this regulation.
Subchapter VIII - Registration of Air Contaminant Source. "Each operator of a source which emits more than five tons of any and all air contaminants per year shall register the source with the Secretary, and shall renew such registration annually."
The applicant is currently in compliance and has been registering its emissions with the Agency annually.
B. Federal Air Pollution Control Regulations and the CAA
Section 112 of the Clean Air Act - National Emission Standards for Hazardous Air Pollutants (NESHAPs). NESHAPs are promulgated under 40 C.F.R. Part 61 and Part 63. No NESHAPs currently apply to the Facility. The Facility HAP emission will be limited to less than 10 tons per year for any one HAP and less than 25 tons per year for all combined HAPs. Total HAP emissions are estimated to be less than 1 ton per year.
VI. CONTROL TECHNOLOGY REVIEW FOR MAJOR SOURCES AND MAJOR MODIFICATIONS
Pursuant to (5-502 of the Regulations each new major source and major modification must apply control technology adequate to achieve the Most Stringent Emission Rate ("MSER") with respect to those air contaminants for which there would be a major or significant emission increase, respectively. The proposed project is designated as a non-major modification of a stationary source and therefore is not subject to MSER review under (5-502 of the Regulations.
VII. AMBIENT AIR QUALITY IMPACT EVALUATION
The Agency's implementation procedures concerning the need for an ambient air quality impact evaluation under (5-501 of the Regulations specifies that such analyses shall be performed when projects result in allowable emissions increase of 10 tpy or more of any air contaminant, excluding VOCs. Air quality impact evaluations are not required by the Agency for individual sources of VOCs. The proposed modification is not estimated to produce greater than 10 tpy of any non-VOC air contaminant. Therefore, an impact evaluation was not necessary to assess compliance with the ambient air quality standards. The Agency has previously established that increases in emissions of less than 10 tpy do not pose a threat to the ambient air quality standards, nor are they expected to significantly deteriorate existing air quality.
VIII. HAZARDOUS AIR CONTAMINANTS
The emissions of hazardous air contaminants ("HACs") are regulated under (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 that 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 AL, 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"). The emission of hazardous air pollutants ("HAPs") may also be regulated separately under (112 of the Federal Clean Air Act. Any applicable HAP regulations are discussed under Section V above.
A. Applicability and Quantification of HAC Emissions
The potential sources of HAC emissions at the Facility are the emissions associated with the handling and roasting of coffee beans decaffeinated with Methylene Chloride ((MC(). MC is a Category I HAC.
MC is a solvent used to decaffeinate green coffee beans. GMCR purchases coffee beans that have already been decaffeinated with MC and they declare that no decaffeination processes occur at the Facility. Roughly ten percent of the Facility(s annual green bean throughput is decaffeinated. GMCR estimates that the residual MC concentration remaining in the beans prior to roasting is 0.1 parts per million. Coffee industry experts() support this claim by stating that most coffee beans decaffeinated with MC arrive at the roasting facility with 0.1 ppm MC concentrations. According to the U.S. Food and Drug Administration, MC concentrations of 10 ppm are acceptable and safe for human consumption.
Prior to roasting, the decaffeinated coffee beans are well below this level and calculations have shown that once the beans are roasted, negligible amounts remain in the bean. All HAC calculations are presented in Appendix B of this Technical Analysis. Most of the MC is incinerated in the roaster and catalytic oxidizer. To err on the conservative side, the Agency has estimated the amount of MC that could potentially emanate from the decaffeinated beans (assuming 0% destruction in the roaster) and compared this value to the corresponding MC Action Level found in the Regulations. As shown below, violations of the Action Level for MC are not anticipated.
| | | |
|% Decaffeinated Coffee |Potential MC Concentration (lb MC/8-hr) |Action Level (lb/8-hr) |
|(50 million lbs. total) | | |
| | | |
|10 |0.0005 |0.16 |
| | | |
|30 |0.0015 |0.16 |
Taking the analysis further, the Agency assumed complete destruction of the MC in the roasting process, its complete conversion into Hydrochloric Acid ((HCl(), and then 100% of the HCl entering the atmosphere. HCl is a Category III HAC. The potential emissions of HCl and a comparison to the HCl Action Level are shown below. Action Level violations are not anticipated.
| | | |
|% Decaffeinated Coffee |Potential HCl Concentration (lb HCl/8-hr) |Action Level (lb/8-hr) |
|(50 million lbs. total) | | |
| | | |
|10 |0.0004 |0.87 |
| | | |
|30 |0.0012 |0.87 |
B. HMSER Selection
If the emission of any HAC from all regulated sources at the Facility is estimated to exceed its AL, then the Facility is subject to the rule and the emissions must be reduced to achieve HMSER for that HAC. HMSER is defined in (5-101 of the Regulations as:
"...a rate of emissions, including a visible emission standard, which the Secretary, on a case-by-case basis, determines is achievable for a stationary source based on the lowest emission rate achieved in practice by such category of source. If a source demonstrates that due to economic impacts and costs, it cannot achieve the lowest emission rate achieved in practice by such category, HMSER shall be the lowest emission rate which the Secretary determines the source is capable of achieving. HMSER may be achieved through the application of pollution control equipment, production processes or techniques, equipment design, work practices, chemical substitution, or innovative pollution control techniques. In no event shall application of HMSER permit a stationary source to emit any contaminants in excess of any federal emission standard or any emission standard in these Regulations."
Action Levels for both MC and HCl are not expected to be violated and, therefore, GMCR is not subject to a HMSER. However, it should be noted that the catalytic incinerators must be functional and operating during all periods of roaster operation.
C.. Air Quality Impact Evaluation
If the emission rate of any HAC after achieving HMSER is still estimated to exceed its AL, the Agency may require an air quality impact evaluation to further assess the ambient impacts for compliance with the Hazardous Ambient Air Standard ("HAAS") or Stationary Source Hazardous Air Impact Standard ("SSHAIS"). In determining whether such an impact evaluation is warranted, the Agency shall take into consideration the following factors:
(a) The degree of toxicity of the air contaminant and the emission rate;
(b) The proximity of the source to residences, population centers and other sensitive human receptors; and
(c) Emission dispersion characteristics at or near the source, taking into account the physical location of the source relative to surrounding buildings and terrain.
As discussed above, Action Level violations are highly unlikely and, as such, an Air Quality Impact Evaluation is not warranted.
IX. REASONABLY AVAILABLE CONTROL TECHNOLOGY
Pursuant to 10 V.S.A. (556a(d), as amended, and (5-1010 of the Regulations the Agency may establish and include within any operating permit issued under this section emission control requirements based on Reasonably Available Control Technology ("RACT"). The Agency has not determined RACT under this authority for this Facility at this time.
X. COMPLIANCE PLAN
A. Description of the Compliance Status for Each Applicable Requirement
See Part V above.
B. Compliance Schedule for Each Applicable Requirement for Which the Source is Not in Compliance
Not applicable to this Facility.
XI. CONCLUSIONS
Based on the foregoing technical analysis, the following conclusions are made:
1. The Agency has determined that the Facility, subject to the recommended permit conditions, will meet all the applicable air pollution control requirements. Furthermore, the proposed project will not significantly deteriorate air quality, nor will it cause or contribute to a violation of an ambient air quality standard.
2. Pursuant to 10 V.S.A. (556 and (5-501 of the Regulations, the proposed modification is designated as a non-major modification and the future Facility is designated as a non-major stationary source.
3. Pursuant to 10 V.S.A. (556a and Subchapter X of the Regulations, the Facility is designated as a Subchapter X Major Source.
4. Draft Permit Conditions (see draft permit)
APPENDICES
Appendix A
A-1: Equipment and Stack Information
Appendix B
Criteria Emission Calculations
Hazardous Air Contaminant Emission Calculations
APPENDIX A
A-1: Equipment and Stack Information
DESCRIPTION AND MODEL NUMBER* |
SIZE OR CAPACITY (MAX. ALLOWED) |
FUEL TYPE(S) OR PROCESS INPUT |
DATE INSTALLED |
POLLUTION CONTROL EQUIPMENT |
FLOW RATE (CFM) |
STACK HEIGHT (FT Above Grade) |
EXIT TEMP. (oF) |
ALLOWABLE EMISSION RATE (lbs/hr) | | | | | | | | | | | | | | |
PM/
PM10 |
SO2 |
NOx |
CO |
VOCs |
HAPs | |
Probat EN500R Roasters(3) |
1.25 MMBTU/hr
(each) |
Propane |
1990, 1993, 1995 |
Fabric Filters/Catalytic Incinerators/Cyclones |
?? |
?? |
900 |
0.10 |
-- |
-- |
1.57 |
0.13 |
-- | |
Propat EN500R Stirflex Cooling System |
-- |
-- |
1990, 1993, 1995 |
Cyclones |
6600 |
?? |
120 |
0.02 |
-- |
-- |
-- |
-- |
-- | |
Probat NVK-500/1-2E Catalytic Incinerator (3) |
-- |
Propane |
1992, 1993, 1995 |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- | |
Probat RZ4000 Roasters (2) |
6.75 MMBTU/hr
(each) |
Propane |
2003 |
Fabric Filters/Catalytic Incinerators/Cyclones |
?? |
?? |
1150 |
0.32 |
-- |
-- |
1.57 |
0.13 |
-- | |
Probat RZ4000 Cooling System |
-- |
-- |
2003 |
Cyclones |
18500 |
?? |
120 |
0.07 |
1.02 |
0.96 |
0.24 |
0.04 |
-- | |
Probat RZ4000 Bean Transport System |
-- |
--
|
2003 |
Cyclones |
10000 |
?? |
80 |
0.07 |
-- |
-- |
-- |
-- |
-- | |
Maxon Oven PAC Catalytic Incinerators (2) |
-- |
Propane |
2003 |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- |
-- | |
Waukesha Enginator
VSG11G |
135 HP |
Propane |
1999 |
|
|
|
|
0.03 |
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