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  • EPA Prepared Feeds Manufacturing National Emission Standard Hazard Air Pollutants

    (Feed NESHAP)Carolina Feed Industry Association

    2010 Fall ConferenceNov. 9, 2010

    David FairfieldDirector of Feed Services

    National Grain and Feed Association

  • Mission and PurposeAbundant and

    Safe Food Supply

    Promotion of Free Markets

    Serving the Industry for More than 114 years!

  • About the NGFA 850 Active Member companies

    Represent all sectors of the U.S. grain and feed industry

    Over 6,000 locations Handle over two-thirds of U.S. grain, oilseeds Over 400 feed manufacturers

    200 Associate Member companies Provide goods and services to the industry

    36 State and Regional Affiliates Strategic Alliance with Pet Food Institute

    (PFI), and North American Export Grain Association (NAEGA)

  • EPA Final Rule Issued Jan. 5, 2010 Governs potential air

    emissions of manganese and chromium from covered feed and feed ingredient manufacturers

    Establishes a variety of standards, monitoring and inspections requirements

  • Applicability Issues 40 CFR 63 Subpart DDDDDDD,

    63.11619 - Am I subject to this subpart?:

    (a) You are subject to this subpart if you own or operate a prepared feeds manufacturing facility that uses a material containing chromium or a material containing manganese and is an area source of emissions of hazardous air pollutants (HAP). [Emphasis added.]

    (a) You are subject to this subpart if you own or operate a prepared feeds manufacturing facility that uses a material containing chromium or a material containing manganese and is an area source of emissions of hazardous air pollutants (HAP). [Emphasis added.]

    (a) You are subject to this subpart if you own or operate a prepared feeds manufacturing facility that uses a material containing chromium or a material containing manganese and is an area source of emissions of hazardous air pollutants (HAP). [Emphasis added.]

    (a) You are subject to this subpart if you own or operate a prepared feeds manufacturing facility that uses a material containing chromium or a material containing manganese and is an area source of emissions of hazardous air pollutants (HAP). [Emphasis added.]

  • Applicability Issues Is my facility an area source of emissions of

    hazardous air pollutants? The prepared feeds manufacturing area source

    category is identified by the North American Industry Classification System (NAICS) code 311119, Other Animal Food Manufacturing

    The [area source] category was identified in the original section 112(k) emissions inventory through the use of the Standard Industrial Classification (SIC) code 2048, Prepared Feeds Manufacturing, except cat and dog feed, the NAICS code that covers this area source category is 311119, which is equivalent to the SIC code used in the original source category definition

  • Applicability Issues Is my facility an area source of emissions of

    hazardous air pollutants?

    [we (EPA)] clarify that prepared feeds manufacturing at farms and animal feed lots is not part of this source category. Facilities primarily engaged in raising or feeding animals are listed under different NAICS codes (e.g., 112210 Hog and Pig Farming, 112112Cattle Feedlots, 112111Beef Cattle Ranching and Farming) and were not part of the sources that formed the basis for the listing of the prepared feed manufacturing area source category.

  • Applicability Issues How are NAICS codes assigned?

    NAICS is the standard used by Federal agencies in classifying business establishments for the purpose of obtaining statistical data related to the U.S. business economy

    Each establishment is assigned a NAICS code based upon its own primary business activity

    An establishment is defined as generally a single physical location where business is conducted or where services or industrial operations are performed

  • Applicability Issues What is an establishments primary

    business activity? Census Bureau: Ideally, the primary

    business activity of an establishment is determined by relative share of production costs and/or capital investment. In practice, other variables, such as revenue, value of shipments, or employment, are used as proxies. The Census Bureau generally uses revenue or value of shipments to determine an establishments primary business activity.

  • Applicability Issues Do I own or operate a prepared feed

    manufacturing facility? EPAs definition: Prepared feed manufacturing

    facility means a facility that is primarily engaged in manufacturing animal feed. A facility is primarily engaged in manufacturing animal feed if the production of animal feed comprises greater than 50 percent of the total production of the facility on an annual basis. Facilities primarily engaged in raising or feeding animals are not considered prepared feeds manufacturing facilities.

  • Applicability Issues Do I use a material containing

    manganese (Mn) or chromium (Cr)? Material containing manganese means a

    material that contains manganese in amounts greater than or equal to 1.0 percent by weight. Common swine trace mineral premix 1.5 to 3

    pound per ton inclusion rate: 2.6 percent Mn

    Material containing chromium means a material that contains chromium in amounts greater than or equal to 0.1 percent by weight

  • Management Practices - Housekeeping(In Regulated Areas)

    Manually remove dust by sweeping or by a vacuum system

    Once per month, remove dust from walls, ledges, and equipment

    Keep doors shut except during entrance and exit

    Store Mn and Cr materials in closed containers

    Management Practices - Mixer Mixer is to be covered at all times except when

    adding materials Mn and Cr materials are to be added to the mixer

    in a manner to minimize emissions

  • Management Practices - Feed Load-Out (For Regulated Materials)

    Each load-out is to have a device to lessen fugitive emissions, such as drop sock or telescopic spout Applies even to enclosed

    load-out systems Device is to be inspected

    monthly to ensure proper operation

  • Pelleting Operations Requirements -Applicable to covered facilities with 50 ton per day

    annual production average for all feeds Cooler cyclone is to provide 95 percent or

    greater particulate matter removal demonstrated by Manufacturers specifications Certification by a

    Professional Engineer or Responsible Person

    EPA-recognized Method 5 Stack Test

    Establish proper operation parameters for cyclone inlet flow or inlet velocity or pressure drop or fan amperage

  • Demonstrating Pellet Cyclone Efficiency Method 5 Stack Test

    Cost is $10,000 to $15,000 for single system Cost is $15,000 to $20,000 for two systems same

    location Includes particle size distribution (PSD)

  • Demonstrating Pellet Cyclone Efficiency

    Method 5 Stack TestInlet Outlet

  • Demonstrating Pellet Cyclone Efficiency Manufacturers Specification

    Most are hesitant to provide blanket statement that equipment meets required efficiency level

    At a minimum, most will want a PSD, along with other some other operating parameters

    Professional Engineers Certification Models are available to determine efficiency Input of cyclone dimensions, PSD, particle

    density, air flow, and air temperature

  • 70

    75

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    95

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    5 10 15 20 30 40 60 70 80

    Perc

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    Typical Cyclone Performance Curves

    "Normal"Efficiency

    "High"Efficiency

    Microns

  • Cyclone Design ParametersTexas A&M University

    Some agencies require 1D3D or 2D2D cyclones

  • Cyclone Monitoring and Recordkeeping Requirements

    Pellet cyclones are to be maintained and operated in accordance with manufacturers specifications. If manufacturers specifications are not available, the facility is to develop and follow standard maintenance and operating procedures that ensure the proper operation of the cyclone.

    Pellet cyclones are to be inspected quarterly for corrosion, erosion or other damage that could result in air leakage.

    The pellet cyclones inlet flow rate, inlet velocity, pressure drop or fan amperage is to be monitored on each day that the pelleting process is operating.

  • You will need access to your cyclones for inspection

    How will you monitor inlet flow rate, inlet velocity, pressure drop or fan amperage?

  • Notification and Compliance Timeframes and Requirements

    Initial Notification: Effected firms were to have notified EPA and their local permitting agency by May 5, 2010

    Compliance Date: Existing facilities: January 5, 2012 New facilities (those that commenced construction or

    reconstruction after July 27, 2009): Upon start-up Notification of Compliance:

    Existing facilities: May 4, 2012 New facilities: Oct. 18, 2010, or within 120 days of

    initial startup, whichever is later

  • Notification and Compliance Timeframes and Requirements

    Annual Compliance Certification: After providing the initial notification of compliance status, every March 1 thereafter, covered facilities are required to prepare annual compliance certification reports for the previous calendar year, and submit the report under certain circumstances

    Recordkeeping: The final rule mand

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