Tamping Down Dust

OMAHA (DTN) -- A new coat of paint was barely dry on the 60-year-old Farmers Grain Terminal grain elevator in Greenville, Miss., and Bud Tate was on his way to a facility planning meeting with his manager when he heard EPA had released proposed changes to the standards grain elevators must meet to reduce dust emissions.

Tate said his facility in the Mississippi Delta runs an antiquated dust control system much in need of upgrade -- with or without the proposed rule changes. The company operates nine facilities in Arkansas, Louisiana and Mississippi. Now, the rule posted by EPA at www.regulations.gov July 9, may push Tate's facility and other elevators to make dust-handling improvements. The public comment period on the proposal is set to expire Oct. 7.

"I am working on upgrading dust collection/suppression systems on a 60-year-old elevator, with old Carter-Day and Kice modular systems from 1980 or earlier," he said. "My plan is to capture the dust, mix/blend with mineral oil, and reintroduce in the product flow. So, I'm interested in learning more, as I'm trying to get our elevator to the next level."

One agriculture interest group, the National Grain and Feed Association, said it was just beginning to study the rule in detail. Already, though, NGFA applauded EPA's responsiveness to their concerns about one aspect of the proposal.

Temporary storage facilities will not be counted against elevators when determining if Clean Air Act permits are needed.

Originally, EPA had treated temporary storage structures the same as permanent facilities in determining whether elevators were subject to costly permitting requirements.

"EPA in its proposed rule notes that it is rescinding that interpretation since it is 'now aware that (temporary storage facilities) typically handle the grain less time throughout the year than other types of permanent storage facilities, and may require different treatment,'" NGFA said in a statement.

In recent years, agriculture interest groups made claims that EPA was going to regulate dust from farms and rural roads. EPA officials have stated publicly that the agency was not going to regulate 'farm dust.' As a result of EPA regulations of particulate matter, however, some farmers and ranchers in the Southwest already are required to take steps to reduce dust emissions.

The new standards of performance for grain elevators were lost in the shuffle during the 'farm dust' storm.

POTENTIAL COMPLIANCE COSTS

EPA provided cost estimates on the proposed grain elevator rule for both existing and new facilities that come into operation in the next five years.

The proposal said 88 grain elevators that included 221 "affected facilities" are projected to be subject to the standards in the next five years, "because they will construct, reconstruct or modify an affected facility." EPA put up-front capital costs for all 221 facilities at about $1.1 million. Annual compliance costs were put at $1.2 million, plus yearly recordkeeping and reporting costs estimated at $83,000 for those facilities.

"We determined that the projected compliance costs are reasonable as they are not expected to result in a significant market impact, whether they are passed on to the purchaser or absorbed by firms," EPA said.

OTHER ADDITIONS

The proposed rule also would make a number of amendments to the standards for grain elevators.

It would require 10% "opacity standards" for barge or ship unloading stations that do not use unloading legs, and for column dryers using wire screens. Particulate matter and opacity standards would be made consistent for temporary and permanent storage units.

The rule would require grain elevators to conduct particulate matter tests every five years, test opacity annually, and have weekly visual inspections for affected facilities, as well as visual inspections of fabric filters every six months. Elevators would be required to maintain records of those tests, and would be required to submit electronic copies of performance test reports.

NGFA said in its statement that it would continue to study the rule before issuing public comments to EPA.

"There are a number of significant issues in the EPA proposal that NGFA and its colleagues in other organizations will be evaluating very closely and developing joint comments," the group said. "These issues include a new percentage-based formula proposed by EPA under which about one-third of the capacity of temporary storage space would be included when calculating whether an air permit is required."

The EPA proposal also would add a new section that would apply to grain elevators where construction, modification or reconstruction begins after the July 9 release of the proposal.

The new source performance standards had not been reviewed by EPA since 1984, when temporary storage units were not yet used by elevators.

With the newly proposed standards, any commercial grain elevator constructed after 1978 that has a permanent storage capacity exceeding 2.5 million bushels, NGFA said, will be required to comply with stricter air-permitting and emission standards. It also applies to any facility that has been modified since 1978 to expand its permanent storage capacity to more than 2.5 million bushels.

Tate said his company is in the process of drafting an eight- or 10-year plan for its facilities, so EPA's proposal is timely for the cooperative.

"If EPA shows up, we want to be able to show them where I'm at and where I'm going," he said.

Read the proposed rule here, http://tinyurl.com/…

Todd Neeley can be reached at todd.neeley@dtn.com

Follow Todd on Twitter @toddneeleyDTN

(GH/AG)

Copyright 2014 DTN/The Progressive Farmer. All rights reserved.