United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Washington DC 20460
EPA 340/1-90-010
Apri 11991
Stationary Source Compliance Series
xvEPA
Regulatory and
Inspection Manual for
Nonmetallic Mineral
Processing Plants
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Regulatory and Inspection Manual for
Nonmetallic Mineral Processing Plant
by
IT Environmental Programs, Inc.
11499 Chester Road
Cincinnati, Ohio 45246
Contract No. 68-02-4466
Work Assignment No. 91-74
EPA Project Officer: Aaron R. Martin
EPA Work Assignment Manager: Karen A. Randolph
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
Stationary Source Compliance Division
Washington DC 20460
April 1991
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DISCLAIMER
This manual was prepared for the U.S. Environmental Protection Agency by IT
Environmental Programs, Inc., Durham, North Carolina, under Contract No. 68-02-
4466, Work Assignment No. 91-74. The contents of this report are reproduced herein
as received from the contractor. The opinions, findings, and conclusions expressed
are those of the author and not necessarily those of the U.S. Environmental Protection
Agency.
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CONTENTS
Figures x
Tables xiii
Acknowledgment xiv
1. Introduction 1
1.1 Scope and Content 2
1.2 Intended use of the Manual 3
1.3 Industry Overview 4
1.3.1 General 4
1.3.2 General process description 6
2. Process Equipment Emissions and Particulate Matter Controls 12
2.1 Crushers 13
2.1.1 Jaw crushers 14
2.1.2 Gyratory crushers 16
2.1.3 Roll crushers 18
2.1.4 Impact crushers 18
2.1.5 Sources of emissions 20
2.2 Grinding Mills 22
2.2.1 Hammermills 23
2.2.2 Roller mill 24
2.2.3 Rod mill 24
2.2.4 Pebble and ball mills 25
2.2.5 Fluid energy mills 25
2.2.6 Separating and classifying 27
in
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CONTENTS (Continued)
2.3 Emission Controls for Crushers and Grinding Mills 27
2.3.1 Wet dust suppression 28
2.3.2 Dust collection systems 31
2.4 Screening Operations 33
2.4.1 Grizzlies 33
2.4.2 Shaking screens 35
2.4.3 Vibrating screens 35
2.4.4 Revolving screens 37
2.4.5 Emission controls for screening operations 37
2.5 Storage Bins 39
2.5.1 Emission controls for storage bins 39
2.6 Bucket Elevators 41
2.6.1 Emission controls for bucket elevators 44
2.7 Belt Conveyors 44
2.7.1 Emission controls for belt conveyor transfer points 44
2.8 Bagging Operations 48
2.8.1 Emission controls for bagging operations 48
2.9 Enclosed Truck or Railcar Loading Operations 50
2.9.1 Emission controls for enclosed truck or railcar
loading stations 50
IV
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CONTENTS (Continued)
3. Regulatory Requirements and Their Application 52
3.1 Applicability and Designation of Affected Facility - §60.670 52
3.1.1 General applicability and affected
facilities - §60.670(a) 52
3.1.2 Facilities subject to other NSPS - §60.670(b) 53
3.1.3 Facilities exempted by plant type/capacity -
§60.670(c) 54
3.1.4 Exemption by replacement with facilities of equal
or smaller size - §60.670(d) 54
3.1.5 Designation of affected facility by date of
construction, reconstruction, or modification -
§60.670(e) 55
3.2 Definitions - §60.671 56
3.3 Standard for Particulate Matter - §60.672 66
3.3.1 Stack emissions standard - §60.672(a) 66
3.3.2 Fugitive emissions standards - §60.672(b) & (c) 67
3.3.3 Exemption for truck dumping - §60.672(d) 68
3.3.4 Affected facilities enclosed in buildings 68
3.4 Reconstruction - §60.673(a) 69
3.4.1 Fixed capital cost exemptions - §60.673(a) 69
3.4.2 Continuous programs of component replacement -
§60.673 (b) 70
3.5 Monitoring of Operations (Wet Scrubbers) - §60.674 71
3.6 Test Methods and Procedures - §60.675 72
3.6.1 General requirements for performance tests -
§60.675(a) 72
3.6.2 Test methods and procedures for stack emissions -
§60.675(b) 73
v
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CONTENTS (Continued)
3.6.3 Test methods and procedures for fugitive emissions -
§60.675(c) 73
3.6.4 Determining the presence of fugitive emissions from
buildings - §60.675(d) 74
3.6.5 Approved alternatives to the test procedures for
fugitive emissions - §60.675(e) 75
3.6.6 Wet scrubber monitoring compliance - §60.675(f) 76
3.7 Reporting and Recordkeeping - §60.676 76
3.7.1 Reporting requirements for equal or smaller size
replacements - §60.676(a) 76
3.7.2 Special reporting requirements for equal or smaller
size replacements - §60.676(b) 77
3.7.3 Wet scrubber requirements - §60.676(c)(d) & (e) 77
3.7.4 Performance test reporting requirements - §60.676(f) 78
3.7.5 Requirements under delegated enforcement authority -
§60.676(g) 79
4. Compliance Determination (Level II Inspection) 80
4.1 Pre-lnspection Preparation 81
4.1.1 Review of facility background 81
4.1.2 Development of an inspection plan 83
4.1.3 Notification of facility and responsible agency 84
4.1.4 Equipment preparation 86
4.2 Pre-Entry Observations 87
4.2.1 Plant surroundings observation 88
4.2.2 Visible emissions observation 88
4.3 Plant Entry 88
4.3.1 Authority 89
4.3.2 Arrival 89
4.3.3 Credentials 89
VI
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CONTENTS (Continued)
4.3.4 Consent 90
4.3.5 Uncredentialed persons accompanying an inspector 90
4.3.6 Waivers, releases, and sign-in logs 91
4.3.7 Nondisclosure statements 91
4.4 Opening Conference 91
4.5 Inspection Documentation 93
4.5.1 Inspector's field notebook and field notes 94
4.5.2 Visible emission observation form 95
4.5.3 Drawings and maps 98
4.5.4 Copies of records 98
4.5.5 Printed matter 99
4.5.6 Photographs 100
4.6 Verification of Facility Records 101
4.7 Means of Determining Compliance with the Standard for
Particulate Matter 104
4.7.1 Determining compliance with opacity during
the inspection 105
4.7.2 Determining compliance with opacity during the
initial performance test 107
4.8 Field Inspection Procedures for Affected Facilities 108
4.8.1 Crushers 109
4.8.2 Grinding mills 113
4.8.3 Screening operations 115
4.8.4 Storage bins 119
4.8.5 Bucket elevators 119
4.8.6 Belt conveyors 119
4.8.7 Bagging operations 123
4.8.8 Enclosed truck or railcar loading operations 123
VII
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CONTENTS (Continued)
4.9 Field Inspection Procedures for Air Pollution Control
Equipment 127
4.9.1 Operating pulse jet baghouses 127
4.9.2 Operating shaker and reverse air baghouses 128
4.9.3 Nonoperating pulse jet baghouses 129
4.9.4 Nonoperating shaker and reverse air baghouses 131
4.9.5 Spray tower scrubbers 133
4.9.6 Mechannically aided scrubbers 134
4.9.7 Gas-atomized scrubbers 136
4.9.8 Large diameter cyclones 137
4.9.9 Multiple cyclone collectors 139
4.9.10 Wet suppression systems 140
4.10 Post-Inspection Conference 141
4.11 Report Preparation and Tracking 142
4.11.1 Computer data base updates 143
4.11.2 Agency file updates 143
4.11.3 Report preparation 144
Appendices
A. 40 CFR 60, Subpart OOO With February 14, 1989 Revision A-1
B. 40 CFR 60, Subpart A General Provisions (Abbreviated) B-1
C. EPA Method 9 - Visual Determination of Emissions From
Stationary Sources C-1
D. EPA Method 22 - Visual Determination of Fugitive Emissions
From Material Sources and Smoke Emissions From Flares D-1
E. Sample Inspection Forms E-1
F. Sample Inspection Report F-1
VIII
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CONTENTS (Continued)
G. State Agencies to which Authority has been Delegated for
40 CFR 60, Subpart OOO G-1
H. Compilation of EPA Policy Memoranda Concerning 40 CFR 60,
Subpart OOO H-1
IX
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FIGURES
Number Page
1-1 Flowsheet of a typical aggregate crushing plant 7
1-2 General schematic of a nonmetallic mineral processing plant 10
2-1 Double-toggle jaw crusher 15
2-2 Single-toggle jaw crusher 15
2-3 The pivoted spindle gyratory 17
2-4 Cone crusher 17
2-5 Double-roll crusher 19
2-6 Single-roll crusher 19
2-7 Hammermill 21
2-8 Impact crusher 21
2-9 Fluid energy mill 26
2-10 Spray nozzle arrangement above primary crusher throat 29
2-11 Dust suppression application at crusher discharge 30
2-12 Hood configuration used to control a cone crusher 32
2-13 Stationary grizzly 34
2-14 Vibrating screen 36
2-15 Hood configuration for vibrating screen 38
2-16 Baghouse atop a storage bin 40
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FIGURES (Continued)
Number Page
2-17 Cyclones and baghouses serving storage bins 42
2-18 Bucket elevator types 43
2-19 Conveyor belts and transfer point 45
2-20 Hood configuration for conveyor transfer, less than 0.91
meter (3-foot) fall 46
2-21 Hood configuration for a chute-to-belt or conveyor transfer,
greater than 0.91 meter (3-foot) fall 47
2-22 Exhaust configuration at bin or hopper 47
2-23 Bag filling vent system 49
2-24 Combination enclosed truck and railcar loading station 51
4-1 EPA Method 9 Visible Emission Observation Form 96
4-2 EPA Method 22 Field Data Sheet for Outdoor Location 97
4-3 Fugitive emissions from a jaw crusher 110
4-4 Feed inlet of cone crusher with feed skirts 111
4-5 Open feed inlet of cone crusher 112
4-6 Portable jaw crusher 114
4-7 Deck-type screen with fugitive emissions 116
4-8 Screen hood showing open cleanout emitting fugitive dust 117
4-9 Enclosed screen hood showing external fugitive dust buildup 118
4-10 Bucket elevator with fugitive emissions 120
XI
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FIGURES (Continued)
Number Page
4-11 Uncontrolled belt-to-belt transfer point 121
4-12 Belt-to-belt transfer point with capture hood 122
4-13 Nonenclosed truck loading station 124
4-14 Enclosed railcar loading station with fugitive emissions 125
4-15 Enclosed truck loading station with flexible feed tube 126
XII
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TABLES
Number Page
1-1 Major uses of the Nonmetallic Minerals 5
2-1 Relative Crushing Mechanisms 14
4-1 Recommended Inspection and Safety Equipment 87
XIII
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ACKNOWLEDGMENT
This report was prepared for the U.S. Environmental Protection Agency,
Stationary Source Compliance Division, by IT Environmental Programs, Inc. (ITEP),
Durham, North Carolina. The project was directed by Mr. Steven H. Kopp and
managed by Mr. Craig Mann. The principal author is Mr. Craig Mann. ITEP would
like to acknowledge Ms. Karen A. Randolph, the U.S. Environmental Protection
Agency Work Assignment Manager, and Mr. Paul Reinermann for their overall
guidance and direction in preparing this manual.
XIV
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SECTION 1
INTRODUCTION
New Source Performance Standards (NSPS), are promulgated under 40 CFR
Part 60. The general provisions for all NSPS were promulgated in the Federal Register
on December 16, 1975 (40 FR 58416) as Subpart A. Specific standards applicable to
nonmetallic mineral processing plants were initially proposed on August 31, 1983
(48 FR 39566). The NSPS for nonmetallic mineral processing plants was promulgated
as Subpart OOO on August 1, 1985 (50 FR 31337) and revised on February 14, 1989
(54 FR 6680).
The NSPS for nonmetallic mineral processing plants provides 1) rules for
applicability of the standards and designation of affected facilities, 2) standards for
particulate matter emitted from affected facilities, 3) monitoring, reporting, and
recordkeeping requirements, and 4) test methods and procedures for determining
compliance with the emissions standards. The regulatory standards limit particulate
matter emissions from crushers, grinding mills (including air separators, classifiers, and
conveyors), screens, bucket elevators, bagging operations, storage bins, enclosed
truck and railcar loading operations, and transfer points on belt conveyors. Unit
operations not included are drilling, blasting, loading at the mine, hauling, drying,
stockpiling, conveying (other than at transfer points), and windblown dust from
stockpiles, roads and plant yards.
Subpart OOO designates affected facilities as individual pieces of operating
equipment (i.e., screens, storage bins, crushers, etc.) manufactured, modified or
reconstructed after August 31, 1983.
Recordkeeping requirements of the NSPS general provisions as well as those of
Subpart OOO require data to be recorded and notifications issued for individual
operating units.
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The regulatory standards limit both fugitive emissions and stack emissions from
affected facilities. Stack emissions are limited to 0.05 g/dscm (0.02 gr/dscf) and an
opacity of 7 percent, unless a wet scrubbing device is employed to control emissions.
Fugitive emissions are limited to an opacity of 10 percent, except crushers without
capture systems are limited to an opacity of 15 percent.
1.1 Scope and Content
Section 1 describes the content of the manual, its intended use, and gives an
overview of the nonmetallic mineral processing industry including the types of minerals
processed and the general equipment types employed.
Section 2 describes the specific equipment types covered by the standard.
Coverage includes theory of operation, what quantities and types of particulate matter
emissions are expected, and control options most frequently employed in nonmetallic
mineral processing plants. Photographs and/or schematic drawings are reproduced
to facilitate a better understanding of the mechanics behind the operation of these
equipment types and control of their emissions.
Section 3 details the requirements of the regulations including the general
provisions of Subpart A applicable to the nonmetallic mineral processing plants, as
well as the specific requirements of Subpart OOO. Individual sections or paragraphs
of the regulations are cited followed by a clarification. The clarification explains the
intent and application of the preceding citation. Section 3 attempts to clarify the
multitude of questions regarding interpretation of the regulations that have emerged
since the standards were first proposed.
Section 4 describes the steps necessary to conduct a Level II compliance
inspection of a facility subject to the NSPS standards. This section discusses file
review, plant entry procedures and preinspection interviews, safety and inspection
equipment, report writing and tracking of affected facilities, and detailed inspection
techniques for determining compliance with the standards. Photographs and
illustrations are used to acquaint-the reader with typical compliance situations that may
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be encountered. In addition, checklists are included to aid the inspector in compliance
determinations and tracking of affected facilities.
The appendices include the Subpart OOO final rule (51 FR 31337) and revision
(54 FR 6680) incorporated into one document (Appendix A), Sections of Subpart A
that directly affect the requirements contained in Subpart OOO (Appendix B), EPA
Reference Method 9 - Determining the Opacity of Emissions from Stationary Sources
(Appendix C), EPA Reference Method 22 for determining fugitive emissions from
material sources (Appendix D), sample compliance determination and tracking forms
(Appendix E), a typical inspection report for nonmetallic mineral processing plants
(Appendix F), a list of State agencies with delegated authority for the nonmetallic
mineral processing NSPS (Appendix G), and a complilation of EPA policy memoranda
concerning 40 CFR 60, Subpart OOO (Appendix H).
1.2 Intended use of the Manual
The intended audience of this manual is not only EPA, State and local
compliance inspectors but the nonmetallic mineral processing industry as well as other
involved parties. The manual attempts to attain several objectives: 1) present the
latest guidance for applying the regulations and standards to the affected industries, 2)
present field tested techniques for determining compliance of affected facilities, and 3)
answer some of the most frequently asked questions concerning the nonmetallic
mineral processing NSPS.
The manual is written in such a way as to offer guidance on applying the
regulations in the field and for reporting and tracking compliance of affected facilities.
No degree of prescriptiveness, however, can be effective in all situations. In the last
analysis, correct use of these guidelines and procedures must be coupled with a
thorough knowledge of site-specific conditions to ensure correct application of the
regulations.
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1.3 Industry Overview
1.3.1 General
There are many nonmetallic minerals that are individually produced in a wide
range of quantities. For the purpose of the nonmetallic mineral processing NSPS, the
EPA studied 18 minerals based upon Bureau of Mines classifications, which are the
highest mined production segment of the industry involving crushing and grinding
operations, excluding coal, phosphate rock, and asbestos. The 18 nonmetallic
minerals affected by the NSPS are:
Crushed and Broken Stone ° Boron
Sand and Gravel ° Barite
Clay ° Fluorspar
Rock Salt ° Feldspar
Gypsum ° Diatomite
Sodium Compounds ° Perlite
Pumice ° Vermiculite
o
o
o
o
Gilsonite ° Mica
0 Talc and Pyrophyllite ° Kyanite
Geographically, the industry is highly dispersed, with all States reporting
production of at least one of these 18 nonmetallic minerals. The industry is also
extremely diverse in terms of production capacities per facility (from 5 to several
thousand tons per hour) and end product uses.
Crushed stone and gravel are by far the largest segments of the industry.
From 1985 to 1986 figures, there were approximately 4323 processing plants in the
sand and gravel industry and approximately 3557 quarries worked in the crushed
stone industry. Each of the other industries had less than 100 processing plants,
except for the clay industry which had approximately 120 plants.
Table 1-1 lists the major uses of each individual mineral. Generally, the uses of
nonmetallic minerals can be classified as either aggregate for the construction
industry; minerals for the chemical and fertilizer industries; or clay, ceramic, refractory,
and miscellaneous minerals. Minerals generally used for construction are crushed and
broken stone, sand and gravel, gypsum, gilsonite, perlite, pumice, vermiculite, and
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TABLE
Mineral
1-1. MAJOR USES OF THE NONMETALLIC MINERALS
Major uses
Crushed and broken
Sand and gravel
Clay
Rock salt
Gypsum
Sodium compounds
Pumice
Gilsonite
Talc
Boron
Barite
Fluorspar
Feldspar
Diatomite
Perlite
Vermiculite
Mica
Kyanite
stone Construction, lime manufacturing, erosion control
Construction
Bricks, cement, refractory, paper
Highway use, chlorine
Wallboard, plaster, cement, agriculture
Glass, chemicals, paper
Road construction, concrete
Asphalt paving
Ceramics, paint, toilet preparations
Glass, soaps, fertilizer
Drilling mud, chemicals
Hydrofluoric acid, iron and steel, glass
Glass, ceramics
Filtration, filters
Insulation, filter aid, plaster aggregate
Concrete
Paint, joint cement, roofing
Refractories, ceramics
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mica. Minerals generally used in the chemical and fertilizer industries are barite,
fluorspar, boron, rock salt, and sodium compounds. Clay, feldspar, kyanite, talc, and
diatomite can be generally classified as clay, ceramic, refractory, and miscellaneous
minerals.
1.3.2 General Process Description
General industry processing involves extracting from the ground; loading,
unloading, and dumping, conveying, crushing, screening, milling, and classifying.
Some minerals processing also includes washing, drying, calcining, or flotation
operations. The operations performed depend on the ore type and the desired
product.
The mining techniques used for the extraction of nonmetallic minerals vary with
the particular mineral, the nature of the deposit, and the location of the deposit.
Mining is carried out both underground and in open pits. Some minerals require
blasting while others can be removed by excavator, loader, bulldozer, dragline, or
dredging operations alone.
The nonmetallic minerals are normally delivered to the processing plant by truck
and are dumped into a hoppered feeder, usually a vibrating grizzly type, or onto
screens, as illustrated in Figure 1-1. These screens separate or scalp the larger
boulders from the finer rocks that do not require primary crushing, thus minimizing the
load to the primary crusher. Jaw or gyratory crushers are usually used for initial
reduction, although impact crushers are gaining favor for crushing low-abrasion rock,
such as limestones and talc where high reduction ratios are desired. The crusher
product, normally 7.5 to 30 centimeters (3 to 12 inches) in size, and the grizzly
throughs (undersize material) are discharged onto a belt conveyor and normally
transported to either secondary screens and a crusher, or to a surge pile or silo for
temporary storage.
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FINISHING
SCREENS
Figure 1-1. Flowsheet of a typical aggregate crushing plant.
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The secondary screens separate the process flow into generally two fractions
(oversize and throughs) prior to the secondary crusher. The oversize is discharged to
the secondary crusher for further reduction. The undersize, which require no further
reduction at this stage, normally by-pass the secondary crusher. A third fraction, the
throughs, is separated when processing some minerals. Throughs contain unwanted
fines that are usually removed from the crushing process flow and processed as fine
aggregate. For secondary crushing, gyratory or cone crushers are most commonly
used, although impact crushers are used at some installations.
The product from the secondary crushing stage, usually 5.0 centimeters or less
in size, is normally transported to a secondary screen for further sizing. Sized material
from this screen is either discharged directly to a tertiary crushing stage or conveyed
to classifying screens or to a fine-ore bin, which supplies the milling stage. Cone
crushers or hammermills are normally used for tertiary crushing. Rod mills, ball mills,
and hammermills are normally used in the milling stage. The product from the tertiary
crusher or the mill is usually conveyed to a type of classifier such as a dry vibrating
screen system, a wash screen, an air separator, or a wet rake or spiral system (if wet
grinding was employed), which also dewaters the material. The oversize is returned to
the tertiary crusher or mill for further size reduction. At this point, some mineral end
products of the desired grade are conveyed directly to finished product bins, or are
stockpiled in open areas by conveyors or trucks. Other minerals such as talc or barite
may require air classification to obtain the required mesh size, and treatment by
flotation to obtain the necessary chemical purity and color.
Most nonmetallic minerals require additional processing depending on the rock
type and consumer requirements. In certain cases, especially in the crushed stone
and sand and gravel industry, washing may be required to meet particular end product
specifications or demands such as for concrete aggregate. Some minerals, especially
certain lightweight aggregates, are washed and dried, sintered, or treated prior to
primary crushing. Others are dried following secondary crushing or milling. Sand and
8
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gravel, crushed and broken stone, and most lightweight aggregates normally are not
milled and are screened and shipped to the consumer after secondary or tertiary
crushing. Figures 1-1 and 1-2 show simplified diagrams of the typical process steps
required for some nonmetallic mineral processing facilities.
In general, the factors that affect emissions from most mineral processing
operations include: the type of ore processed, the type of equipment and operating
practices employed, the moisture content of the ore, the amount of ore processed,
and a variety of geographical and seasonal factors. These factors, discussed in more
detailed below, apply to both fugitive and stack emission sources associated with
processing plant operations.
The type of ore processed is important. Soft rocks can produce a higher
percentage of fine-grained material than do hard rocks because of their greater
friability and lower resistance to fracture. Thus, it is concluded that the processing of
soft rocks results in a greater potential for uncontrolled emissions than the processing
of hard rock. Minerals arranged in order of increasing hardness are: talc, clay,
gypsum, barite, limestone and dolomite, perlite, feldspar, and quartz. Thus, talc could
be expected to exhibit the highest uncontrolled emissions and quartz the least.
The type of equipment and operating practices employed also affect emissions.
In general, emissions from process equipment such as crushers, screens, grinders,
and conveyors depend on the size distribution of the material, the moisture content,
and the velocity that is mechanically imparted to the material.
The inherent moisture content or wetness of the ore processed can have a
substantial effect on emissions. This is especially evident during mining, initial material
handling, and initial plant process operation such as primary crushing. Surface
wetness causes fine particles to agglomerate or adhere to the faces of larger stones
with a resultant dust suppression effect. However, as new fine particles are created by
crushing and attrition, and as the moisture content is reduced by evaporation, this
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COARSE
ORE
BIN.
GRIZZLY
OR
SCREEN
PRIMARY
CRUSHER
SECONDARY
CRUSHER
SIZE
CLASSIFIER
STOCKPILE
OR BIN
13
STOCKPILE
OR BIN
#4
Figure 1-2. General schematic for nonmetallic minerals processing.
10
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suppressive effect diminishes and may even disappear. Depending on the
geographical and seasonal factors, the primary variables affecting uncontrolled
particulate matter emissions are wind parameters and moisture content of the material.
Wind parameters will vary with geographical location and season and it can certainly
be expected that the level of emissions from sources that are not enclosed (principally
fugitive dust sources) will be greater during periods of high winds than periods of low
winds. The moisture content of the material will also vary with geographical location
and season. It can, therefore, be expected that the level of uncontrolled emissions
from fugitive emission sources will be greater in arid regions of the country than in
temperate ones and greater during the summer months due to a higher evaporation
rate. The effect of equipment type on uncontrolled emissions from all sources will be
more fully discussed in Section 2.
11
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SECTION 2
PROCESS EQUIPMENT EMISSIONS AND
PARTICULATE MATTER CONTROLS
Affected facilities under 40 CFR Part 60, Subpart OOO include only the following
process equipment types: crushers, grinding mills, screening operations, bucket
elevators, belt conveyors, bagging operations, storage bins, and enclosed truck or
railcar loading stations. This section discusses the most common of these equipment
types encountered in the industry, their principles of operation, and the emission
controls most frequently employed. Because of the diversity of processes and
process equipment used in the nonmetallic mineral processing industry, the inspector
requires a fundamental knowledge of the emission sources likely encountered in the
field. Many times an operating plant may appear to be a confusing array of
equipment, sometimes spread over a large area, other times compacted into confined
spaces or enclosed within buildings. The inspector may be required to recognize
subtle differences in equipment and processes to verify that affected facilities are
onsite and are operated within permitted conditions.
When conducting a compliance inspection of a nonmetallic mineral processing
plant, it is usually best to start at the beginning of the process operations and end the
inspection at the finished product loading station(s). This is especially true of the initial
plant visit when the inspector is becoming acquainted with the particular processes
and equipment types employed at the facility. A beginning-to-end approach allows the
inspector to understand the logic of plant processes as well as trace the flow of
materials. For this reason, the types of process equipment defined as affected
facilities under Subpart OOO are presented in this section in the process order most
frequently found in the industry.
12
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2.1 Crushers
Subpart OOO affected facilities begin with the first crushing or grinding
operation at the plant. Plants that do not employ crushing or grinding are, by
definition, not considered nonmetallic mineral processing plants and are thus not
subject to the nonmetallic mineral processing NSPS.
After blasting, ripping, or breaking is completed in the quarry, the initial size
reduction of the raw material is usually accomplished in the primary crusher.
Generally, crushing is size reduction in the coarse range and grinding in the fine
range. Crushing is usually accomplished in machines having crushing or ore contact
surfaces which are mechanically held apart. In grinders, the grinding surfaces will rub
on one another if material is not present.
The mechanical stress applied to rock fragments during crushing may be
accomplished by either compression or impaction. In impaction, the breaking force is
applied very rapidly, while in compression, the rock is slowly squeezed and forced to
fracture. All types of crushers are both compression and impaction to varying
degrees, and in all cases there is some reduction due to rubbing of stone on stone or
on metal surfaces. Generally, compression-type crushers produce less fines and
impart less kinetic energy to particles than do impaction crushers. Table 2-1 ranks
crushers according to their predominant crushing mechanism (from top to bottom,
compression to impaction).
Because the size reduction achievable by one machine is limited, reduction in
stages is frequently required. The various stages include primary, secondary, and
perhaps tertiary crushing. Basically, the crushers used in the nonmetallic minerals
industry are: jaw, gyratory, roll, and impact crushers.
13
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TABLE 2-1. RELATIVE CRUSHING MECHANISMS
Compression
Impaction
Double roll crusher
Jaw crusher
Gyratory crusher
Single roll crusher
Rod mill (low speed)
Ball mill
Rod mill (high speed)
Hammermill (low speed)
Impact breaker
Hammermill (high speed)
2.1.1 Jaw Crushers
Jaw crushers consist of a vertical fixed jaw and a moving inclined jaw that is
operated by a single toggle or a pair of toggles. Rock is crushed by compression as
a result of the opening and closing action of the moveable jaw against the fixed jaw.
Their principal application in the industry is for primary crushing.
The most commonly used jaw crusher is the Blake or double-toggle type. As
illustrated in Figure 2-1, an eccentric shaft drives a Pitman arm that raises and lowers
a pair of toggle plates to open and close the moving jaw which is suspended from a
fixed shaft. In a single-toggle jaw crusher, the moving jaw is itself suspended from an
eccentric shaft and the lower part of the jaw supported by a rolling toggle plate (Figure
2-2). Rotation of the eccentric shaft produces a circular motion at the upper end of
the jaw and an elliptical motion at the lower end. Other types, such as the Dodge and
overhead eccentric are used on a limited scale.
A jaw crusher can be categorized by its feed opening dimensions and may
range from approximately 15x30 centimeters to 213x168 centimeters (6x12 inches to
84x66 inches). The size reduction obtainable may range from 3:1 to 10:1 depending
on the nature of the rock. Capacities are quite variable depending on the unit and its
discharge setting.
14
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MOVEABLE JAW
FIXED JAW
ECCENTRIC
PITMAN ARM
DISCHARGE
Figure 2-1. Double-toggle jaw crusher.
MOVEABLE JAW
FEED
FIXED
JAW
DISCHARGE
TOGGLE
Figure 2-2. Single-toggle jaw crusher.
15
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2.1.2 Gyratory Crushers
Simply, a gyratory crusher may be considered to be a jaw crusher with circular
jaws between which the material flows and is crushed. However, a gyratory crusher
has a much greater capacity than a jaw crusher with an equivalent feed opening.
There are basically three types of gyratory crushers, the pivoted spindle, fixed
spindle, and cone. The fixed and pivoted spindle gyratories are used for primary and
secondary crushing, and cone crushers for secondary and tertiary crushing. The
larger gyratories are grouped according to feed opening and the smaller units by cone
diameters.
The pivoted spindle gyratory (Figure 2-3) has the crushing head mounted on a
shaft that is suspended from above and free to pivot. The bottom of the shaft is
seated in an eccentric sleeve which revolves, thus causing the crusher head to gyrate
in a circular path within a stationary concave circular chamber. The crushing action is
similar to that of a jaw crusher in that the crusher element reciprocates to and from a
fixed crushing plate. Because some part of the crusher head is working at all times,
the discharge from the gyratory is continuous rather than intermittent as in a jaw
crusher. The crusher setting is determined by the wide-side opening at the discharge
end and is adjusted by raising or lowering the crusher head.
Unlike the pivoted spindle gyratory, the fixed spindle gyratory has its crushing
head mounted on an eccentric sleeve fitted over a fixed shaft. This produces a
uniform crushing stroke from the top to the bottom of the crushing chamber.
For fine crushing, the gyratory is equipped with flatter heads and converted to a
cone crusher (Figure 2-4). Commonly, in the lower section a parallel zone exists.
This results in a larger discharge-to-feed area ratio which makes it extremely suitable
for fine crushing at high capacity. Also, unlike regular gyratories, the cone crusher
sizes at the closed side setting and not the open side (wide-side) setting. This
assures that the material discharge will have been crushed at least once at the closed
16
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FEED
FIXED
THROAT
CRUSHING SURFACE
ECCENTRIC
DRIVE
DISCHARGE
Figure 2-3. The pivoted spindle gyratory.
FEED
CRUSHING
SURFACES
DISCHARGE
DRIVE
ECCENTRIC
Figure 2-4. Cone crusher.
17
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side setting. Cone crushers yield an elongated product and a high percentage of fines
due to interparticle crushing. They are the most commonly used crusher in the
industry for secondary and tertiary reduction.
2.1.3 Roll Crushers
These machines are used primarily at intermediate or final reduction stages and
are often used at portable plants. There are essentially two types, the single-roll and
the double-roll. As illustrated in Figure 2-5, the double-roll crusher consists of two
heavy parallel rolls which are turned toward each other at the same speed. Roll
speeds range from 50 to 300 rpm. Usually, one roll is fixed and the other set by
springs. Typically, roll diameters range from 61 to 198 centimeters (24 to 78 inches)
and have narrow face widths, about half the roll diameter. Rock particles are caught
between the rolls and crushed almost totally by compression. Reduction ratios are
limited and range from 3 to 4 to 1. These units produce few fines and no oversize.
They are used especially for reducing hard stone to a final product ranging from 1 /4
inch to 20 mesh.
The working elements of a single-roll crusher include a toothed or knobbed roll
and a curved crushing plate that may be corrugated or smooth. The crushing plate is
generally hinged at the top and its setting is held by a spring at the bottom. A
toothed-roll crusher is depicted in Figure 2-6. The feed caught between the roll and
crushing plate is broken by a combination of compression, impact, and shear. These
units may accept feed sizes up to 51 centimeters (20 inches) and have capacities up
to 454 megagrams per hour (500 tons/h). In contrast with the double-roll, the single-
roll crusher is principally used for reducing soft materials such as limestones.
2.1.4 Impact Crushers
Impact crushers, including hammermills and impactors, use the force of fast
rotating massive impellers or hammers to strike and shatter free falling rock particles.
These units have extremely high reduction ratios and produce a cubical product
18
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FEED
DISCHARGE
ADJUSTABLE
ROLLS
Figure 2-5. Double-roll crusher.
FEED
TOOTH
ROLL
CRUSHING
PLATE
Figure 2-6. Single-roll crusher.
19
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spread over a wide range of particle sizes with a large proportion of fines, thus making
their application in industry segments such as cement manufacturing and agstone
production extremely cost effective by reducing the need for subsequent grinding
machines.
A hammermill consists of a high speed horizontal rotor with several rotor discs
to which sets of swing hammers are attached (Figure 2-7). As rock particles are fed
into the crushing chamber, they are impacted and shattered by the hammers which
attain tangential speeds as high as 76 meters (250 feet) per second. The shattered
rock then collides with a steel breaker plate and is fragmented even further. A
cylindrical grating or screen positioned at the discharge opening restrains oversize
material until it is reduced to a size small enough to pass between the grate bars.
Rotor speeds range from 250 to 1800 rpm and capacities to over 907 megagrams per
hour (1,000 tons/h). Product size is controlled by the rotor speed, the spacing
between the grate bars, and by hammer length.
An impact breaker (Figure 2-8) is similar to a hammermill except that it has no
grate or screen to act as a restraining member. Feed is broken by impact alone.
Adjustable breaker bars are used instead of plates to reflect material back into the
path of the impellers. Primary-reduction units are available that can reduce quarry run
material at over 907 megagrams per hour (1,000 tons/h) capacity to approximately 2.5
centimeters (1 inch). These units are not appropriate for hard abrasive materials, but
are ideal for soft rocks like limestone.
2.1.5 Sources of Emissions
The generation of particulate emissions is inherent in the crushing process.
Emissions are most apparent at crusher feed and discharge points. Emissions are
influenced predominantly by the type of rock processed, the moisture content of the
rock, and the type of crusher used.
The most important element influencing emissions from crushing equipment is
the type of rock and the moisture content of the mineral being crushed. The crushing
20
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FEED
\
BREAKER
PLATE
SWING
HAMMERS
— GRATE BARS
Figure 2-7. Hammermill.
BREAKER
PLATE
BREAKER
BARS
FEED
ROTOR
DISCHARGE
Figure 2-8. Impact crusher.
21
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mechanism employed has a substantial affect on the size reduction that a machine
can achieve; the particle size distribution of the product, especially the proportion of
fines produced; and the amount of mechanically induced energy that is imparted to
fines.
Crushing units using impaction rather than compression produce a larger
proportion of fines as noted above. In addition to generating more fines, impaction
crushers also impart higher velocity to the particles as a result of the fan-like action
produced by the fast rotating hammers. Because of this and the high proportion of
fines produced, impaction crushers generate larger quantities of uncontrolled
particulate emissions per ton of material processed than any other crusher type.
The level of uncontrolled emissions from jaw, gyratory, cone and roll crushers
closely parallels the reduction stage to which they are applied. Emissions increase
progressively from primary to secondary to tertiary crushing. Factors other than the
type of crushing mechanism (compression, impaction) also affect emissions. In all
likelihood, primary jaw crushers produce greater emissions than comparable gyratory
crushers because of the bellows effect of the jaw and because gyratory crushers are
usually choke fed to minimize the open spaces from which dust may be emitted. For
subsequent reduction stages, cone crushers produce more fines as a result of attrition
and consequently generate more dust.
2.2 Grinding Mills
Grinding is a further step in the reduction of material to particle sizes smaller
than those attainable by crushers. Because the material to be treated has already
been reduced to small sizes, and the force to be applied to each particle is
comparatively small, the machines used in grinding are of a different type, and may
operate on a different principle from those used in more coarse crushing. The
Subpart OOO definition of a "grinding mill" does not distinguish between wet and dry
crushing and also includes the air conveying system, air separator, or air classifier
associated with the grinding operation where it is employed.
22
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As with crushers, the most important element influencing emissions from
grinding mills is the reduction mechanism employed, compression, or impaction.
Grinding mills generally use impaction rather than compression. Reduction by
impaction will produce a larger proportion of fines. Particulate emissions are
generated from grinding mills at the grinder's inlet and outlet. Gravity type grinding
mills accept feed from a conveyor and discharge product into a screen or classifier or
onto a conveyor. These transfer points are the source of particulate emissions. The
outlet has the highest emissions potential because of the finer material. Air-swept mills
include an air conveying system and an air separator, a classifier, or both. The air
separator and classifier are generally cyclone collectors. In some systems, the air just
conveys the material to a separator for deposit into a storage bin with the conveying
air escaping via the cyclone vent. In other grinding systems, the air is continuously
recirculated. Maintaining this circulating air system under suction keeps the mill
dustless in operation, and any surplus air drawn into the system due to the suction
created by the fan is released through a vent. In both cases the vent gases will
contain a certain amount of particulate matter.
Many types of grinding mills are manufactured for use by various industries.
The principal types of mills used are: 1) hammer, 2) roller, 3) rod, 4) pebble and ball,
and 5) fluid energy. Each of these types of mills is discussed separately below.
2.2.7 Hammermills
A hammermill consists of a high speed horizontal rotor with several rotor discs
to which sets of swing hammers are attached. As rock particles are fed into the
grinding chamber, they are impacted and shattered by the hammers, which attain
peripheral speeds greater than 76 meters (250 feet) per second. The shattered rock
then collides with a steel breaker plate and is fragmented even further. A cylindrical
grate or screen positioned at the discharge opening restrains oversize material until it
is reduced to a size small enough to pass between the grate bars. Product size is
23
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controlled by the rotor speed, the spacing between the grate bars, and by hammer
length. These mills are used for nonabrasive materials and can accomplish a size
reduction of up to 12:1.
2.2.2 Roller Mill
The roller mill, also known as a Raymond Roller Mill, with its integral whizzer
separator can produce ground material ranging from 20 mesh to 325 mesh or finer.
The material is ground by rollers that travel along the inside of a horizontal stationary
ring. The rollers swing outward by centrifugal force, and trap the material between
them and the ring. The material is swept out of the mill by a stream of air to a whizzer
separator, located directly on top of the mill. Here the oversize is separated and
dropped back for further grinding while the desired fines pass up through the whizzer
blades into the duct leading to the air separator (cyclone).
2.2.3 Rod Mill
The rod mill is generally considered as a granular grinding unit, principally for
handling a maximum feed size of 2 to 4 centimeters (1 to 2 inches), and grinding to a
maximum of 65 mesh. It is normally used in a closed circuit with a sizing device, such
as classifiers or screens, and for wet or dry grinding. It will grind with the minimum of
the finer sizes, such as 100 or 200 mesh, and will handle relatively higher moisture
material without packing.
The mill in its general form consists of a horizontal, slow-speed, rotating,
cylindrical drum. The grinding media consists of a charge of steel rods, slightly
shorter than the mill's inside length and from 5 to 13 centimeters (2 to 5 inches) in
diameter. The rods roll freely inside the drum during its rotation to provide the
grinding action desired.
24
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2.2.4 Pebble and Ball Mills
The simplest form of a ball mill is cylindrical, horizontal, slow-speed rotating
drum containing a mass of balls as grinding media. When other types of grinding
media such as a flint or various ceramic pebbles are used, it is known as a pebble
mill. The ball mill uses steel, flint, porcelain, or cast iron balls.
The diameter of balls or pebbles as the initial charge in a mill is determined by
the size of the feed material and the desired fineness of the product. Usually the
larger diameter ranges are used for preliminary grinding and the smaller for final
grinding. Ball mills reduce the size of the feed mostly by impaction. These grinders •
normally have a speed of 10 to 40 revolutions per minute. If the shell rotates too fast,
centrifugal force keeps the balls against the shell and minimal grinding occurs.
2.2.5 Fluid Energy Mills
When the desired material size is in the range of 1 to 20 microns, an ultrafine
grinder such as the fluid energy mill is required. A typical fluid energy mill is shown in
Figure 2-9. In this type of mill, the particles are suspended and conveyed by a high
velocity gas stream in a circular or elliptical path. Size reduction is caused by
impaction and rubbing against mill walls, and by interparticle attrition. Classification of
the particles takes place at the upper bend of the loop. Internal classification occurs
because the smaller particles are carried through the outlet by the gas stream while
the larger particles are thrown against the outer wall by centrifugal force. Product size
can be varied by changing the gas velocity through the grinder.
Fluid energy mills can normally reduce up to 0.91 megagrams/h (1 ton/h) of
solids from 0.149 mm (100 mesh) to particles averaging 1.2 to 10 microns in diameter.
Typical gas requirements are 0.45 and 1.8 kg (1 to 4 pounds) of steam or 2.7 to 4.1
25
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Figure 2-9. Fluid energy mill.
26
-------
kg (6 to 9 pounds) of air admitted at approximately 6.8 atm (100 psig) per 0.45 kg (1
pound) of product. The grinding chambers are typically about 2.5 to 20 cm (1 to 8
inches) in diameter.
2.2.6 Separating and Classifying
Mechanical air separators of the centrifugal type cover a distinct field and find
wide acceptance for the classification of dry materials in a relatively fine state of
subdivision. In commercial practice the separator may be said to begin where the
impact of vibrating screens leave off, extending from 40 to 60 mesh down.
Briefly stated, the selective action of the centrifugal separator is the result of an
ascending air current generated within the machine by means of a fan, such current
tends to lift the finer particles against the combined effect of centrifugal force and
gravity. In operation, the feed opening allows the material to drop on the lower or
distributing plate where it is spread and thrown off by centrifugal force, the larger and
heavier particles being projected against an inner casing, while the small and lighter
particles are picked up by the ascending air current created by the fan. These fines
are carried over into an outer cone and deposited. Concurrently, the rejected coarse
material drops into the inner cone, passes out through a spout and is recycled back to
the grinding mill.
The air, after dropping the major portion of its burden, is either recirculated
back to the grinding mill or vented. In the case of the recirculated air, a small amount
of extraneous air is entrained in the feed and frequently builds up pressure in the
separator, in which case the excess air may be vented off. Both vent gases are a
source of particulate matter.
2.3 Emission Controls for Crushers and Grinding Mills
Generally, particulate matter emission control for crushers and grinding mills
involve one of two techniques: 1) wet dust suppression, and/or 2) dust collection by
a capture and conveying system to a control device. Wet dust suppression consists
of introducing water or amended water into the material flow, causing the fine
27
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participate matter to be confined and remain with the material flow rather than
becoming airborne. Dust collection involves hooding and enclosing dust-producing
emission points and exhausting emissions to a collection device.
2.3.1 Wet Dust Suppression
Wet dust suppression of dry crushing usually involves water sprays both above
and below the crusher throat. The objective of the water sprays is not to fog the
emission source with a fine mist to capture PM emissions, but rather to prevent
emissions by keeping the material moist during the crushing process. Enough
moisture must be added to progressively wet the ore surfaces as reduction proceeds.
The water spray nozzles above the crusher throat may be positioned close to the
receiving end of the throat or positioned some distance above the throat to assist in
dust suppression from truck or feeder dumping of the ore. Figure 2-10 shows a spray
nozzle arrangement above the throat of a primary jaw crusher. Note that the wide
spray pattern assists in reducing truck dump emissions as well as emissions from the
crusher throat. In determining compliance with the Subpart OOO emission standards
for crushers, however, emissions from truck dumping of material directly or indirectly
into a crusher, grinding mill, screening operation or feed hopper is exempt from the
standards and must be separated from emissions originating directly from the affected
facility.
In addition to water sprays above the crusher throat, spray nozzles are normally
required below the throat where new dry surfaces and dust are generated by the
fracture of the ore. Figure 2-11 shows a typical arrangement for the control of
emissions at the crusher discharge.
When plain or untreated water is used, because of its unusually high surface
tension, the addition of 5 to 8 percent moisture (by weight), or greater, may be
required to adequately suppress dust. In some installations, this may not be optimum
because the excess moisture may cause downstream screen blinding or result in the
coating of mineral surfaces yielding a marginal or nonspecification product.
28
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Figure 2-10. Spray nozzle arrangement above primary crusher throat.
29
-------
SUPPRESSANT
CRUSHER
SPRAY HEADER
\
FILTER
CONTROL
*~ VALVE
RUBBER
SHIELD
BELT
IDLERS
Figure 2-11. Dust suppression application at crusher discharge.
30
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To counteract this effect, small quantities of wetting agents or surfactants may be
added to the water to reduce its surface tension and improve it wetting efficiency.
2.3.2 Dust Collection Systems
Hooding and air volume requirements for the control of crusher and grinder
emissions are quite variable depending upon the size and shape of the emission
source, the hood's position relative to the points of emission, and the velocity, nature,
and quantity of the released particles. The only established criterion is that a minimum
indraft velocity of 61 meters per minute (200 fpm) be maintained through all open
hood areas. To achieve this, capture velocities in excess of 150 meters per minute
(500 fpm) may be necessary to overcome induced air motion, resulting from the
material feed and discharge velocities and the mechanically induced velocity (fan
action) of a particular equipment type. To achieve effective emission control,
ventilation should be applied at both the upper portion, or feed end, of the equipment
and at the discharge point. An exception to this would be at primary jaw or gyratory
crushers because of the necessity to have ready access to get at and dislodge large
rocks that may get stuck in the crusher feed opening. Where access to a device is
required for maintenance, removable hood sections may be used.
In general, the upper portion of the crusher or grinder should be enclosed as
completely as possible. The exhaust rate varies considerably depending on crusher
type. For impact crushers or grinders, exhaust volumes may range from 110 to 230
m3/nnin (4,000 to 8,000 cfm). For compression type crushers, an exhaust rate of 46
m3/min per meter (500 cfm per foot) of discharge opening should be sufficient. The
width of the discharge opening will approximate the width of the receiving conveyor.
For either impact crushers or compression type crushers, pick-up should be applied
downstream of the crusher for a distance of at least 3.5 times the width of the
receiving conveyor. A typical hood configuration used to control particulate emissions
from a cone crusher is depicted in Figure 2-12.
31
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CO
IV)
FEED
BELT
-.
INSPECTION
- DOOR
CONE _.
CRUSHER
CRUSHER
DISCHARGED*
COLLECTION
HOODS
CONTROL
DEVICE
DUST
BIN
EXHAUST
A
FAN
Figure 2-12. Hood configuration used to control a cone crusher.
-------
Grinding or milling circuits which employ air conveying systems operate at
slightly negative pressure to prevent the escape of air containing the ground rock.
Because the system is not airtight, some air is drawn into the system and must be
vented. This vent stream can be controlled by discharging it through a control device.
2.4 Screening Operations
Screening is the process by which a mixture of stones is separated according
to size. In screening, material is dropped onto a mesh surface with openings of
desired size and separated into two fractions, undersize which passes through the
screen opening and oversize which is retained on the screen surface. When material
is passed over and through multiple screening surfaces, it is separated into fractions
of known particle size distribution. Screening surfaces may be constructed of metal
bars, perforated or slotted metal plates, woven wire cloth, or polyurethane materials.
The capacity or size of a screen is primarily determined by the open area of the
screening surface and the physical characteristics of the feed. It is usually expressed
in tons of material per hour per square foot of screen area. Although screening may
be performed wet or dry, dry screening is the more common in crushing circuits.
Screening equipment commonly used in the nonmetallic minerals industry includes
grizzlies, shaking screens, vibrating screens, and revolving screens.
2.4.1 Grizzlies
Grizzlies consist of a set of uniformly spaced bars, rods, or rails. The bars may
be horizontal or inclined and are usually wider in cross section at the top than the
bottom. This prevents the clogging or wedging of stone particles between bars. The
spacing between the bars ranges from 5 to 20 centimeters (2 to 8 inches). Bars are
usually constructed of manganese steel or other highly abrasion-resistant material.
Grizzlies are primarily used to prevent oversize material from entering the
crusher, thus reducing the load. Grizzlies may be stationary (Figure 2-13),
cantilevered (fixed at one end with the discharge end free to vibrate), or mechanically
33
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Figure 2-13. Stationary grizzly.
34
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vibrated. Vibrated grizzlies are simple bar grizzlies mounted on eccentrics. The entire
assembly is moved forward and backward at approximately 100 strokes a minute,
resulting in better flow through and across the grizzly surface.
2.4.2 Shaking Screens
The shaking screen consists of a rectangular frame with perforated plate or wire
cloth screening surfaces, usually suspended by rods or cables and inclined at an
angle of 14 degrees. The screens are mechanically shaken parallel to the plane of
material flow at speeds ranging from 60 to 800 strokes per minute and at amplitudes
ranging from 2 to 23 centimeters (3/4 to 9 inches). Generally, they are used for
screening coarse material, 1.3 centimeters (1/2-inch) or larger.
2.4.3 Vibrating Screens
Where large capacity and high efficiency are desired, the vibrating screen has
practically replaced all other screen types. It is by far the most commonly used
screen type in the nonmetallic minerals industry. A vibrating screen (Figure 2-14)
essentially consists of a inclined flat or slightly convex screening surface which is
rapidly vibrated in a plane normal or nearly normal to the screen surface. The
screening motion is of small amplitude but high frequency, normally in excess of 3,000
cycles per minute. The vibrations may be generated either mechanically by means of
an eccentric shaft, unbalanced fly wheel, cam and tappet assembly, or electrically by
means of an electromagnet.
Mechanically-vibrated units are operated at approximately 1,200 to 1,800 rpm
and at amplitudes of approximately 0.3 to 1.3 centimeters (1/8 to 1/2 inch).
Electrically vibrated screens are available in standard sizes from 30 to 180 centimeters
(12 inches to 6 feet) wide and 0.76 to 6.1 meters (2-1/2 to 20 feet) long. A complete
screening unit may have one or more decks.
35
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Figure 2-14. Vibrating screen.
36
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2.4.4 Revolving Screens
This screen type consists of an inclined cylindrical frame around which is
wrapped a screening surface of wire cloth or perforated plate. Feed material is
delivered at the upper end and, as the screen is rotated, undersized material passes
through the screen openings while the oversized is discharged at the lower end.
Revolving screens are available up to 1.2 meters (4 feet) in diameter and usually run at
15 to 200 rpm.
2.4.5 Emission Controls for Screening Operations
Dust is emitted from screening operations as a result of the agitation of dry
material. The level of uncontrolled emissions depends on the quantity of fine particles
contained in the material, the moisture content of the material and the type of
screening equipment. Generally, dry screening of fines produces higher emissions
than the screening of coarse materials. Also, screens agitated at large amplitudes and
high frequency emit more dust than those operated at small amplitudes and low
frequencies.
As with crushers and grinding mills, particulate matter emission control may be
accomplished by either wet dust suppression when the addition of moisture is not
deleterious to the process, or by dust collection and conveyance to a control device.
A full coverage hood, as depicted in Figure 2-15, is generally used to control
emissions generated at actual screening surfaces. Required exhaust volumes vary
with the surface area of the screen and the amount of open area around the periphery
of the enclosure. A well-designed enclosure should have a space of no more than 5
to 10 centimeters (2 to 4 inches) around the periphery of the screen. A minimum
exhaust rate of 15 m3/min per square meter (50 cfm per square foot) of screen area is
commonly used with no increase for multiple decks.
37
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TO CONTROL
DEVICE
FEED
COMPLETE
ENCLOSURE
SCREEN
THROUGHS
Figure 2-15. Hood configuration for vibrating screen.
38
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As was previously discussed in Section 2.4, screening may be performed either
wet or dry. When the object of wet screening is to remove unwanted material from the
product (e.g., silt, clay, grit, etc.) and not to separate product by size, the operation is
termed washing. Washers are not affected facilities under Subpart OOO (see the
definition of screening operation in Section 3.2).
It should be noted, however, that some washers such as deck-type screens
with spray bars can be modified for dry screening by removing the sprays. If a
washer is modified and used for dry screening, and the washer was manufactured
after August 31, 1983, the modified washer constitutes a screening operation as
defined in §60.671 and therefore becomes an affected facility under Subpart OOO.
2.5 Storage Bins
Storage bins for raw materials, intermediates, and final products may be
charged and unloaded by gravity, mechanically or by pneumatic conveying and
loading systems. Charging and unloading may also occur continuously or
intermittently. Particulate matter emissions may occur during charging as the air head
space in the bin is displaced by product. This air head space is either discharged to
the atmosphere without controls through vents, or is collected and conveyed to a
control device.
2.5.1 Emission Controls for Storage Bins
The amount of uncontrolled particulate matter emissions generated during
storage bin charging is dependent on the material size, charging rate, moisture
content and the charging mechanism employed. Top loading of a storage bin
involving free-falling material is expected to generate the greatest emissions.
The most frequently employed control devices used on storage bins are fabric
dust collectors (baghouse) or air pollution control cyclones. The baghouse may be
positioned atop the storage bin (Figure 2-16) or may be positioned some distance
away. If a cyclone is employed, however, it is positioned above the bin charging port.
39
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Figure 2-16. Baghouse atop a storage bin.
40
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Cyclones with low circumference-to-height ratios are designed as air separators and
are not efficient in reducing fine particulate matter emissions. Figure 2-17 shows two
cyclones, each serving a storage bin and acting as air separators during charging.
Also note that between the cyclones are two baghouses which control emissions from
the exits of each cyclone and also serve as controls on bin venting.
2.6 Bucket Elevators
Bucket elevators are used where substantial elevation is required within a
limited space. They consist of a head and foot assembly which supports and drives
an endless single or double strand chain or belt to which buckets are attached.
Figure 2-18 depicts the three types most commonly used: the high-speed centrifugal-
discharge, the slow speed positive or perfect-discharge, and the continuous-bucket
elevator.
The centrifugal-discharge elevator has a single strand of chain or belt to which
the spaced buckets are attached. As the buckets round the tail pulley, which is
housed within a suitable curved boot, the buckets scoop up their load and elevate it to
the point of discharge. The buckets are so spaced so that at discharge, the material
is thrown out by the centrifugal action of the bucket rounding the head pulley. The
positive-discharge type also uses spaced buckets but differs from the centrifugal type
in that it has a double-strand chain and a different discharge mechanism. An
additional sprocket, set below the head pulley, effectively bends the strands back
under the pulley, which causes the bucket to be totally inverted resulting in a positive
discharge.
The continuous-bucket elevator uses closely spaced buckets attached to a
single or double strand belt or chain. Material is loaded directly into the buckets
during ascent and is discharged gently as a result of using the back of the precluding
bucket as a discharge chute.
41
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Figure 2-17. Cyclones and baghouses serving storage bins.
42
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(b)
(c)
LEGEND
(a) centrifugal discharge
(b) positive discharge
(c) continuous discharge
Figure 2-18. Bucket elevator types.
43
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2.6.1 Emission Controls for Bucket Elevators
Particulate matter emissions generated by bucket elevators are dependent on
the particle size distribution of the material, freefall distance, moisture content, and the
speed of the elevator belt or chain. Emission control is applied at the top of the
elevator at the point of bucket discharge using a dust capture and conveying system
to a control device, usually a baghouse. The angle of the capture system duct
penetration into the elevator enclosure is important to avoid duct pluggage. The
penetration angle should be above or below perpendicular to the elevator. The fan
draft of the capture system should be enough to capture the fines within the
enclosure, but not high enough to capture product.
2.7 Belt Conveyors
Belt conveyors are the most widely used means of transporting, elevating, and
handling materials in the nonmetallic minerals industry. As illustrated in Figure 2-19,
belt conveyors consist of an endless belt that is carried on a series of idlers usually
arranged so that the belt forms a trough. The belt is stretched between a drive or
head pulley and a tail pulley. Although belts may be constructed of other material,
reinforced rubber is the most commonly used. Belt widths may range from 36 to 152
centimeters (14 to 60 inches) with 76 to 91 centimeter (24 to 36 inch) belts the most
common. Normal operating speeds may range from 60 to 120 meters per minute
(200 to 400 feet/minute). Depending on the belt speed, belt width and rock density,
load capacities may be in excess of 1360 megagrams (1,500 tons) per hour.
Subpart OOO only regulates particulate matter emissions from transfer points to
and from affected facility belt conveyors (except transfer points to stockpiles).
2.7.1 Emission Controls for Belt Conveyor Transfer Points
Particulate matter emissions from belt conveyor transfer points are dependent
on the particle size distribution of the material conveyed, moisture content, belt speed,
wind speed, and free-fall distance. Emission control is usually applied by hooding,
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HEAD
PULLEY
IDLER
O
o o u
0
o
TAIL
PULLEY
Figure 2-19. Conveyor belts and transfer point.
capturing, and conveying to a control device or by wet suppression. Fugitive
emissions are possible, however, from the return portion of the belt (bottom) if the
load material is not completely discharged and adheres to the belt surface. Belt
cleaning is usually accomplished immediately below the head pulley by scrapers,
brushes or vibrators.
At belt-to-belt conveyor transfer points, hoods should be designed to enclose
both the head pulley of the upper belt and the tail pulley of the lower belt as
completely as possible. With careful design, the open area should be reduced to
approximately 0.15 square meters per meter (0.5 square feet per foot) of belt width.
Factors affecting the air volume to be exhausted include the conveyor belt speed and
the free-fall distance to which the material is subjected. Recommended exhaust rates
are 33 m3 per min per meter (350 cfm per foot) of belt width for belt speeds less than
61 meters/min (200 fpm) and 150 m3/min (500 cfm) for belt speeds exceeding 61
meters/min (200 fpm). For a belt-to-belt transfer with less than a 0.91 meter (three
foot) fall, the enclosure illustrated in Figure 2-20 is commonly used.
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2" CLEARANCE FOR LOAD
on BELT
or KLT ot>cmuc
CONVEYOR TRANSFER LESS THAM
3* FALL Km MEATEM PALL
FNOVIDE ADDITIONAL KXMAUST AT
LOWE* KLT SEE DETAIL AT fflCMT
Figure 2-20. Hood configuration for conveyor transfer, less than
0.91 meter (3-foot) fall.
For belt-to-belt transfers with a free-fall distance greater than 0.91 meters (three
feet) and for chute-to-belt transfers, an arrangement similar to that depicted in Figure
2-21 is commonly used. The exhaust connection should be made as far downstream
as possible to maximize dust fallout and thus minimize needless dust entrainment. For
material containing a high percentage of fines, additional exhaust air may be required
at the tail pulley of the receiving belt. Recommended air volumes are 20 m3/min (700
cfm) for belts 0.91 meters (three feet) wide and less, and 28 m3/min (1,000 cfm) for
belts wider than 0.91 meters (three feet).
Belt or chute-to-bin transfer points differ from the usual transfer operation in that
there is no open area downstream of the transfer point. Thus, emissions are emitted
only at the loading point. As illustrated in Figure 2-22, the exhaust connection is
normally located at some point remote from the loading point and exhausted at a
minimum rate of 61 m3/rnin per square meter (200 cfm per square foot) of open area.
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FROM CHUTE
OR BELT
,. > TO CONTROL
[ DEVICE
ADDITIONAL tt
EXHAUST
RUBBER
SKIRT
CONVEYOR BELT
Figure 2-21. Hood configuration for a chute-to-belt or conveyor transfer,
greater than 0.91 meter (3-foot) fall.
BELT
LOADING
POINT
BIN
OR
HOPPER
TO CONTROL
DEVICE
Figure 2-22. Exhaust configuration at bin or hopper.
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2.8 Bagging Operations
In the nonmetallic minerals industry the valve type paper bag, either sewn or
pasted together, is widely used for shipping fine materials. The valve bag is "factory
closed," that is, the top and bottom are closed either by sewing or by pasting, and a
single small opening is left on one corner. Materials are discharged into the bag
through the valve. The valve closes automatically due to the internal pressure of the
contents of the bag as soon as it is filled.
The valve type bag is filled by means of a packing machine designed
specifically for this purpose. The material enters the bag through a nozzle inserted in
the valve opening, and the valve closes automatically when the filling is completed.
Bagging operations are a source of particulate emissions. Dust is emitted
during the final stages of filing when dust laden air is forced out of the bag. The
fugitive emissions due to bagging operations are generally localized in the area of the
bagging machine.
2.8.1 Emission Controls for Bagging Operations
Bagging operations are controlled by local exhaust systems and vented to a
baghouse for product recovery. Hood face velocities on the order of 150 meters (500
feet) per minute should be used. An automatic bag filling operation and vent system
is shown in Figure 2-23.
It should be noted that if the baghouse serving the NSPS bagging operation
also serves other process equipment, whether or not they are Subpart OOO affected
facilities, the baghouse emissions will be subject to the Subpart OOO particulate
emission standards unless already covered by other NSPS standards (e.g., Subpart I).
For certain conditions, the Subpart OOO particulate standard may be prorated with
another applicable particulate standard (Section 4.8.2).
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Hood attached to bin
Principal dust source
Bag
Figure 2-23. Bag filling vent system.
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2.9 Enclosed Truck or Railcar Loading Operations
Product materials that are not bagged for shipment may be either bulk loaded
into trucks or railroad cars. The usual method of loading is gravity feeding through
plastic or fabric sleeves. Bulk loading of fine material is a source of particulate
emissions because, as in the bagging operation, dust laden air is forced out of the
truck or railroad car during the loading operation.
Subpart OOO defines an enclosed truck or railcar loading station as "that
portion of a nonmetallic mineral processing plant where nonmetallic minerals are
loaded by an enclosed conveying system into enclosed trucks or railcars." This
means that the conveying system must be enclosed as well as the truck or railcar. An
enclosed conveying system includes the enclosed apparatus that directly discharges
into the truck or railcar. To determine the termination of the enclosed conveying
system, the system should be traced from the transfer point at the truck or railcar
countercurrent to material flow to the first transfer point. Any particulate matter
emissions between these two transfer points are emissions from the enclosed
conveying system.
Finally, the definition of enclosed truck or railcar loading station stipulates that
the truck or railcar be enclosed. Enclosure may be here defined as a hood or cover,
integral or attached to the truck or railcar, through which penetrations are afforded for
loading and displacement of air.
2.9.1 Emission Controls for Enclosed Truck or Railcar Loading Stations
Particulate emissions from enclosed truck and railcar loading of coarse material
can be minimized by eliminating any breaks in the enclosed conveying system.
Shrouds, telescoping feed tubes, and windbreaks can further reduce the fugitive
emissions from this intermittent source. Particulate emissions from loading of fine
material into either trucks or railroad cars can be controlled by an exhaust system
vented to a baghouse. The material is fed through one of the vehicle's openings and
the exhaust connection is normally at another opening. The system should be
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designed with a minimum amount of open area around the periphery of the feed chute
and the exhaust duct. Figure 2-24 shows both an enclosed truck and railcar loading
station. In this example, product material is directly loaded by gravity from storage
bins through enclosed feed tubes. Note that both the truck and railcar are also
separately enclosed systems.
Figure 2-24. Combination enclosed truck and railcar loading station.
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SECTION 3
REGULATORY REQUIREMENTS AND THEIR APPLICATION
Regulatory requirements for the nonmetallic mineral processing NSPS are
contained in 40 CFR Part 60, Subpart OOO as well as in the general provisions of 40
CFR Part 60, Subpart A. This section details these requirements and provides an
explanation of the definitions, rules, and standards contained in Subpart OOO and
those requirements in Subpart A that directly affect the nonmetallic mineral processing
NSPS. In addition, this section provides guidance on the application of the NSPS
requirements.
To facilitate a better understanding of the regulations and their application, the
specific requirements of Subpart OOO are presented in their entirety. Each section of
the subpart is arranged in numerical order and is divided into individual subsections or
paragraphs. Each subsection or paragraph is presented as it appears in the Federal
Register followed by a more detailed explanation of its content as well as notes on its
application. Where applicable, the provisions of Subpart A which directly affect each
subsection or paragraph are included. Finally, cross-sectional references are provided
to better explain each subsection or paragraph in the overall context of the
regulations.
Although this section should be read in its entirety, it may also be used as a
reference when questions arise during actual application of the regulations.
3.1 Applicability and Designation of Affected Facility - §60.670
3.1.1 General Applicability and Affected Facilities - §60.670 (a)
(a) Except as provided in paragraphs, (b) [subject to Subpart F or I], (c) [plants
exempted by capacity] and (d) [replacement of equipment of equal or smaller size] of
this section, the provisions of this subpart are applicable to the following affected
facilities in fixed or portable nonmetallic mineral processing plants; each crusher,
grinding mill, screening operation, bucket elevator, belt conveyor, bagging operation,
storage bin, enclosed truck or railcar loading station.
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Explanation /Application:
Paragraphs (b), (c), and (d) will be more fully explained separately in this
section. Also, each type of affected facility (i.e., crusher, grinding mill, belt conveyor,
etc.) will be covered individually in Section 3.2. The key term is "affected facility." In
determining the appropriate designation of "affected facility" for this NSPS, EPA found
that a narrow designation was most appropriate to minimize emissions by application
of best demonstrated control technology. Under this narrow designation, affected
facilities are individual pieces of operating equipment, not entire plants.
See also:
Appendix B, §60.2 "Affected Facility"
Section 3.1.2,3.1.3, and 3. 1 .4
Section 3.2, §60.671 "Crusher," "Grinding Mill," "Belt
Conveyor,""Screening Operation," "Bucket Elevator," "Bagging
Operation," "Storage Bin," "Enclosed Truck or Railcar Loading
Station," and "Nonmetallic Mineral Processing Plants"
3. 1.2 Facilities Subject to Other NSPS - §60.670 (b)
(b) An affected facility that is subject to the provisions of Subpart F or I or that follows in
the plant process any facility subject to the provisions of Subpart F or I of this part is
not subject to the provisions of this subpart.
Explanation/Application:
Subpart F is the NSPS for portland cement plants while Subpart I is the NSPS
for asphalt concrete plants. At these types of facilities, the nonmetallic mineral
processing NSPS will apply to affected facilities that precede equipment covered by
Subparts F or I. For example, onsite crushing operations at asphalt concrete plants
will be subject to the nonmetallic mineral processing NSPS. Once the crushed stone
is entered as a raw material into the asphalt concrete process, however, equipment for
handling it is covered under Subpart I.
See also:
Appendix H, memorandum from John B. Rasnic to Bernard E.
Turlinski, November 8, 1990.
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3.1.3 Facilities Exempted by Plant Type/Capacity - §60.670 (c)
(c) Facilities at the following plants are not subject to the provisions of this subpart:
(1) Fixed sand and gravel plants and crushed stone plants with capacities, as
defined in §60.671, of 23 megagrams per hour (25 tons per hour) or less
(2) Portable sand and gravel plants and crushed stone plants with capacities, as
defined in §60.671, of 136 megagrams per hour (150 tons per hour) or less
(3) Common clay plants and pumice plants with capacities, as defined in
§60.671, of 9 megagrams per hour (10 tons per hour) or less.
Explanation/Application:
Economic and environmental impacts analysis conducted by EPA indicated that
at these types of facilities operating at these capacities, emissions reductions might be
unreasonably costly for the environmental benefits received.
In order to accurately identify these plant types, the definitions of "fixed plant,"
"portable plant," "capacity," and "initial crusher" must be accurately applied.
See also:
Section 3.2, §60.671 "Fixed Plant," "Portable Plant," "Capacity," and "Initial
Crusher"
3.1.4 Exemption by Replacement with Facilities of Equal or Smaller Size - §60.670 (d)
(d)(1) When an existing facility is replaced by a piece of equipment of equal or smaller
size, as defined in §60.671, having the same function as the existing facility, the new
facility is exempt from the provisions of §§60.672, 60.674 and 60.675 except as provided
in paragraph (d)(3) of this section.
(2) An owner or operator seeking to comply with this paragraph shall comply with the
reporting requirements of §60.676 (a) and (b).
(3) An owner or operator replacing all existing facilities in a production line with new
facilities does not qualify for the exemption described in paragraph (d)(1) of this section
and must comply with the provisions of §§60.672, 60.674, and 60.675.
Explanation/Application:
The key point in paragraph (d)(1) is the term "size." For crushers, grinding
mills, bucket elevators, bagging operations, and enclosed truck or railcar loading
stations, size is defined as the rated capacity in tons per hour. Rated capacity is the
manufacturer's highest rated capacity. To ensure that the replacement equipment is
indeed of equal or smaller size, the manufacturer's highest rated capacities of both the
existing equipment and the replacement equipment should be based on the same
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operating criteria. For example, the size (rated capacity) of an existing crusher may
be based on the crusher efficiency index number (CEIN) method involving variables
such as the test material work index, feed size, product size, open circuit capacities for
each closed side setting, and maximum horsepower. Regardless of rating
methodology, identical or like criteria and methods should be used to rate the capacity
of replacement equipment.
It should be noted that if this exemption is applicable, the owner or operator is
only exempt from §§60.672, 60.674, and 60.675; all other requirements of the Subpart
are applicable.
Paragraph (d)(3) stipulates that if an entire production line is replaced with
equipment of equal or smaller size, the exemptions from the particulate matter
standards (§60.672), wet scrubber monitoring requirements (§60.674), and
performance test (§60.675) do not apply. This also means that if the equipment is
replaced one or more pieces at a time, the entire production line retains the
exemptions until the last piece of equipment is replaced.
§60.671 defines "production line" as all affected facilities which are directly
connected together by a conveying system. Although the definition of "conveying
system" is not limited to feeders, belt conveyors, bucket elevators and pneumatic
systems, movable equipment (i.e., trucks, frontend loaders, etc.) are not to be
included in the definition of "conveying system" as it applies to the definition of
"production line" because movable equipment do not directly connect the affected
facilities.
See also:
Section 3.2, §60.671 "Size" and "Production Line"
3.1.5 Designation of Affected Facility by Date of Construction, Reconstruction, or
Modification - §60.670 (e)
(e) An affected facility under paragraph (a) of this section that commences construction,
reconstruction, or modification after August 31, 1983 is subject to the requirements of
this part.
Explanation/Application:
As defined in §60.2 of Subpart A, "commenced" means that an owner or
operator has undertaken a continuous program of construction (or reconstruction) or
modification or has entered into a contractural obligation to undertake and complete
such a program.
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§60.2 also defines "construction" as fabrication, erection, or installation of an
affected facility. Because of the narrow designation of affected facility under Subpart
OOO, construction means the date of fabrication or manufacture of the affected facility.
For example, a crusher manufactured before August 31, 1983 but erected or installed
after this date would not be designated an affected facility under Subpart OOO.
Finally, §60.2 defines "modification" as any physical change in, or change in the
method of operation of, an existing facility which increases the amount of any air
pollutant (to which a standard applies) from that facility or results in the emission of a
pollutant not previously emitted. EPA does not, however, anticipate that the
modification provisions will be triggered except on rare occassions. Most
modifications to existing facilities will fall within the provisions of §60.14(e) of Subpart A
which, by themselves, are not considered modifications. These provisions include: 1)
routine maintenance, repair and replacement within the IRS annual asset guideline
repair allowance (presently 6.5 percent), 2) An increase in production rate without a
capital expenditure on a facility, 3) an increase in the hours of operation, 4) use of
alternative raw materials if the facility was designed to accommodate them before the
date of the NSPS proposal (August 31, 1983), 5) the addition or use of an air pollution
control device, and 6) relocation or change in ownership. Not meeting the provisions
of §60.14(e) (2), an increase in production rate involving a capital expenditure, is
probably the most likely way a modification would cause an existing facility to become
subject to the NSPS requirements (see the definition of "capital expenditure" in
Appendix B, §60.2).
For a detailed explanation of reconstruction, see Section 3.4.
See also:
0 Appendix B, §60.2 "Commenced," "Construction," "Modification," and
§60.14
Sections 3.7.1, 3.7.2
3.2 Definitions - §60.671
Definitions contained in §60.671 are presented here in alphabetical order as
they appear in the regulations.
Bagging Operation
"Bagging operation" means the mechanical process by which bags are filled with
nonmetallic minerals.
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Explanation/Application:
By definition, only operations which mechanically fill "bags" are designated as
affected facilities. This does not include similar operations that fill boxes, drums, or
other containers.
Belt Conveyor
"Belt conveyor" means a conveying device that transports material from one location to
another by means of an endless belt that is carried on a series of idlers and routed
around a pulley at each end.
Explanation/Application:
Although belt conveyors are listed in §60.670 (a) as affected facilities, only
transfer points to and from belt conveyors manufactured after August 31, 1983 are
subject to the requirements of Subpart OOO (except transfer points to stockpiles).
Bucket Elevator
"Bucket elevator" means a conveying device of nonmetallic minerals consisting of a head
and foot assembly which supports and drives an endless single or double strand chain
or belt to which buckets are attached.
Explanation/Application: None
Building
"Building" means any frame structure with a roof.
Explanation/Application:
There is no requirement that the building be enclosed on any side except the
top (roof). The roof may be any solid structure with the sole purpose of weatherizing
whatever is covered by the roof. The key point is that the roof must be constructed
solely as a weather barrier. For example, a truck loading station beneath a silo
supported by framing members does not constitute a building because the silo was
not constructed solely as a weather barrier for the loading station.
Capacity
"Capacity" means the cumulative rated capacity of all initial crushers that are part of the
plant.
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Explanation/Application:
Capacity is defined here as plant capacity. Therefore, plant capacity is the
cumulative total manufacturer's rated capacity of all the initial crushers that are onsite
whether or not the crushers are in service. See Section 3.1, §60.670(d) for a more
detailed clarification of "rated capacity." Also, see the definition of "initial crusher" in
this section.
Capture System
"Capture system" means the equipment (including enclosures, hoods, ducts, fans,
dampers, etc.) used to capture and transport paniculate matter generated by one or
more process operations to a control device.
Explanation/Application:
None
Control Device
"Control device" means the air pollution control equipment used to reduce paniculate
matter emissions released to the atmosphere from one or more process operations at a
nonmetallic mineral processing unit.
Explanation/Application:
Control devices include, but are not limited to the following: baghouses, wet
scrubbers, cyclones, multiple cyclones, and wet dust suppression systems.
Conveying System
"Conveying system" means a device for transporting materials from one piece of
equipment or location to another location within a plant. Conveying systems include,
but are not limited, to the following: feeders, belt conveyors, bucket elevators,
pneumatic systems, screw conveyors, etc.
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Explanation/Application:
Conveying system is here defined as it relates to the definition of "production
line." In this context, movable equipment (i.e., trucks frontend loaders, etc.) is not
considered part of a conveying system. See the definition of "production line" in this
section. Also see Section 3.1, §60.670(d) (3).
Crusher
"Crusher" means a machine used to crush any nonmetallic minerals, and includes, but is
not limited to, the following types: jaw, gyratory, cone, roll, rod mill, hammermill, and
impactor.
Explanation/Application: See Section 2.1
Enclosed Truck or Railcar Loading Station
"Enclosed truck or railcar loading station" means that portion of a nonmetallic mineral
processing plant where nonmetallic minerals are loaded by an enclosed conveying
system into enclosed trucks or railcars.
Explanation/Application:
Subpart OOO defines an enclosed truck or railcar loading station as "that
portion of a nonmetallic mineral processing plant where nonmetallic minerals are
loaded by an enclosed conveying system into enclosed trucks or railcars." This
means that the conveying system must be enclosed as well as the truck or railcar. An
enclosed conveying system includes the enclosed apparatus that directly discharges
into the truck or railcar. To determine the termination of the enclosed conveying
system, the system should be traced from the transfer point at the truck or railcar
countercurrent to material flow to the first transfer point. Any particulate matter
emissions between these two transfer points are emissions from the enclosed
conveying system.
Finally, the definition of enclosed truck or railcar loading station stipulates that
the truck or railcar be enclosed. Enclosure may be here defined as a hood or cover,
integral or attached to the truck or railcar, through which penetrations are afforded for
loading of material and displacement of air.
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Fixed Plant
"Fixed plant" means any nonmetallic mineral processing plant at which the processing
equipment specified in §60.670(a) is attached by a cable, chain, turnbuckle, bolt or other
means (except electrical connections) to any anchor, slab, or structure including
bedrock.
Explanation/Application:
The definition of a fixed plant relates to the exemptions granted fixed sand and
gravel plants and crushed stone plants with capacities of 23 megagrams per hour (25
tons per hour) or less, and fixed or portable common clay plants and pumice plants
with capacities of 9 megagrams per hour (10 tons per hour) or less. The exception for
electrical connections in the definition includes both power connections and grounding
connections.
Fugitive Emission
"Fugitive emission" means paniculate matter that is not collected by a capture system
and is released to the atmosphere at the point of generation.
Explanation/Application:
Fugitive emissions are those particulate matter emissions not released through
a stack or vent (powered). For the purposes of this definition, a release to the
atmosphere at the point of generation includes release to the atmosphere within a
building as well as a release to the outside atmosphere at the point at which the
particulate matter is first produced.
Grinding Mill
"Grinding mill" means a machine used for the wet or dry fine crushing of any nonmetallic
mineral. Grinding mills include, but are not limited to, the following types: hammer,
roller, rod, pebble and ball, and fluid energy. The grinding mill includes the air
conveying system, air separator, or air classifier, where such systems are used.
Explanation/Application:
As defined, Subpart OOO does not distinguish between wet and dry grinding.
Therefore, wet grinding operations are not exempt from the particulate matter
standards, wet scrubber monitoring requirements, or the performance test
requirements of the regulations. In determining compliance with the standards, all
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emission points in the total grinding system, including the air conveying system, air
separator and/or air classifier, are subject to all the NSPS requirements.
Initial Crusher
"Initial crusher" means any crusher into which nonmetallic minerals can be fed without
prior crushing in the plant.
Explanation/Application:
An initial crusher is the first piece of crushing equipment employed after quarry
reduction (i.e., blasting, cracking, or breaking) is achieved. The location of the initial
crusher(s) may be in the quarry or at the plant. Also, note that this definition is not
conditional as to whether or not a crusher is operating at any given time..." into which
nonmetallic minerals can be fed..." Therefore, if a crusher is onsite, whether or not
operating, its rated capacity must be included in the cumulative total of all initial
crushers for the purpose of establishing plant capacity. See the definitions of
"capacity" and "crusher" in this section. Also see section 3.1, §60.670(c).
Nonmetallic Mineral
"Nonmetallic mineral" means any of the following minerals or any mixture of which the
majority is any of the following minerals.
(a) Crushed and broken stone, including limestone, dolomite, granite, traprock,
sandstone, quartz, quartzite, marl, marble, slate, shale, oil shale, and shell.
(b) Sand and gravel
(c) Clay including kaolin, fireclay, bentonite, fuller's earth, ball clay, and common
clay
(d) Rock salt
(e) Gypsum
(f) Sodium compounds, including sodium carbonate, sodium chloride, and sodium
sulfate
(g) Pumice
(h) Gilsonite
(i) Talc and pyrophyllite
(j) Boron, including borax, kernite, and colemanite
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(k) Barite
(I) Fluorospar
(m) Feldspar
(n) Diatomite
(o) Perlite
(p) Vermlcuiite
(q) Mica
(r) Kyanite, including andalusite, sillimanite, topaz, and dumortierite.
Explanation/Application:
A nonmetallic mineral, by definition, includes any one or any mixture of the
listed minerals which comprises over half of the raw material processed.
Nonmetallic Mineral Processing Plant
"Nonmetallic mineral processing plant" means any combination of equipment that is
used to crush or grind any nonmetallic mineral wherever located, including lime plants,
power plants, steel mills, asphalt concrete plants, portland cement plants, or any other
facility processing nonmetallic minerals except as provided in §60.670(b) and (c).
Explanation/Application:
To be designated as a nonmetallic mineral processing plant, a facility must
employ crushing or grinding processes. Without crushing or grinding processes, the
entire plant is exempt from the NSPS requirements. If, for example, the crusher is
located at the quarry and the quarry is located on the same property as the
processing plant, then the crushing operation would be included and all affected
facilities would be subject to the NSPS requirements.
Portable Plant
"Portable plant" means any nonmetallic mineral processing plant that is mounted on any
chassis or skids and may be moved by the application of a lifting or pulling force. In
addition, there shall be no cable, chain, turnbuckle, bolt or other means (except
electrical connections) by which any piece of equipment is attached or clamped to any
anchor, slab, or structure, including bedrock that must be removed prior to the
application of a lifting or pulling force for the purpose of transporting the unit.
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Explanation/Application:
Although the definition of a portable plant is self-explanatory, the performance
tests required of affected facilities is somewhat different than for fixed plants.
Performance tests for portable plants are required only at the first site and not at
subsequent sites to which the plant is moved with two exceptions. First, if a new
affected facility is added, a new performance test is required. The second exception is
that if a portable plant is moved across State lines, the new State may require a
performance test.
Production Line
"Production line" means all affected facilities (crushers, grinding mills, screening
operations, bucket elevators, belt conveyors, bagging operations, storage bins, and
enclosed truck and railcar loading stations) which are directly connected or are
connected together by a conveying system.
Explanation/Application:
Production line is defined here as it relates to a replacement of an existing
facility with one of equal or smaller size. §60.670(d) (3) provides no exemption from
the particulate matter standards, wet scrubber monitoring provisions, or performance
tests if the owner operator replaces all existing facilities in a production line with new
affected facilities. The definition of production line requires that the affected facilities
be directly connected or connected by a conveying system. Although the definition of
conveying system is not limited to explicit pieces of equipment, movable equipment
(i.e., trucks, frontend loaders, etc.) is not included as part of a conveying system.
Replacement of all facilities in the production line simultaneously or the replacement of
the last facility in the production line will cause all the affected facilities in the
production line to be subject to all the requirements of Subpart OOO.
Screening Operation
"Screening operation" means a device for separating material according to size by
passing undersize material through one or more mesh surfaces (screens) in series, and
retaining oversize material on the mesh surfaces (screens).
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Explanation/Application:
Screens include grizzlies, rotating screens and deck-type screens. Care should
be taken not to confuse a screen with a washer. Washers are designed principally to
remove fines from sized aggregate. As with screens, washers may employ a
separating surface that rotates or a deck-type surface. Wash water may be sprayed
onto the aggregate or slurried with the aggregate across the separating surface. The
key distinction is that washers are designed to remove unwanted or unnecessary
material from the product (e.g., grit, fines, clay, etc.) whereas screens are designed to
separate product by size. Washers are not affected facilities under Subpart OOO
(Section 2.4).
Size
"Size" means the rated capacity in tons per hour of a crusher, grinding mill, bucket
elevator, bagging operation, or enclosed truck or railcar loading station; the total surface
area of the top screen of a screening operation; the width of a conveyor belt; and the
rated capacity in tons of a storage bin.
Explanation/Application:
Size is defined here in relation to the exemptions for replacement of existing
facilities with new facilities of equal or smaller size. Rated capacities are
manufacturer's rated capacities for crushers, grinding mills, bucket elevators, bagging
operations, and enclosed truck or railcar loading stations. For screening operations,
size is determined by the total surface area of the top screen because screen type
and mesh may be changed in most designs. For transfer points on belt conveyors,
size is determined by belt width, while storage bins are sized by rated storage capacity
in tons.
For purposes of applying the equal or smaller size exemption, rated capacity for
crushers, grinding mills, bucket elevators, bagging operations, enclosed truck or
railcar loading stations, and storage bins should be based on equal or like rating
criteria. See Section 3.1, §60.670(d) (1).
Stack Emission
"Stack emission" means the paniculate matter that is released to the atmosphere from a
capture system.
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Explanation/Application:
As defined, stack emissions requires the application of a capture system. The
definition of a capture system, in turn, requires the application of a control device.
Storage Bin
"Storage bin" means a facility for storage (including surge bins) of nonmetallic minerals
prior to further processing or loading.
Explanation/Application: None
Transfer Point
'Transfer point" means a point in a conveying operation where the nonmetallic mineral is
transferred to or from a belt conveyor except where the nonmetallic mineral is being
transferred to a stockpile.
Explanation/Application:
By definition, only transfer points to or from belt conveyors are so defined.
Such transfer points (except those to a stockpile) on belt conveyors manufactured
after August 31, 1983 are subject to the NSPS requirements.
Truck Dumping
"Truck dumping" means the unloading of nonmetallic minerals from movable vehicles
designed to transport nonmetallic minerals from one location to another. Movable
vehicles include but are not limited to: trucks, frontend loaders, skip hoists, and railcars.
Explanation/Application:
Truck dumping is here defined in relation to §60.672(d) which exempts
emissions from truck dumping of nonmetallic minerals into any screening operation,
feed hopper, crusher, or stock pile.
Vent
"Vent" means an opening through which there is mechanically induced air flow for the
purpose of exhausting from a building air carrying paniculate matter emissions from one
or more affected facilities.
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Explanation/Application:
Vent is here defined in relation to §60.672(e) (2) which limits vent emissions to
0.05 g/dscm (0.02 gr/dscf) and 7 percent opacity where vents are used to exhaust
buildings containing one or more affected facilities. Note that this definition requires
that air flow through the vent be mechanically induced. Unpowered vent emissions
are therefore deemed fugitive emissions.
3.3 Standard for Paniculate Matter - §60.672
3.3.1 Stack Emissions Standard - §60.672(a)
(a) On and after the date on which the performance test required to be conducted by
§60.8 is completed, no owner or operator subject to the provisions of this subpart shall
cause to be discharged into the atmosphere from any transfer point on belt conveyors
or from any other affected facility any stack emissions which: 1) Contain paniculate
matter in excess of 0.05 g/dscm, or 2) Exhibit greater than 7 percent opacity, unless the
stack emissions are discharged from an affected facility using a wet scrubbing control
device. Facilities using a wet scrubber must comply with the reporting provisions of
§60.676(c), (d), and (e).
Explanation/Application:
§60.8 (a) of Subpart A requires performance tests to be conducted within 60
days after achieving the maximum production rate at which the facility will be operated,
but no later than 180 days after initial startup of such facility. The maximum
production rate at which the affected facility will be operated is the maximum
achievable capacity based on representative performance of the affected facility.
Because an affected facility has been designated for this NSPS as an individual piece
of operating equipment, the maximum production rate is the maximum process rate at
which the individual piece of equipment is expected to operate considering the
maximum plant capacity. This may or may not be equivalent to the manufacturer's
rated capacity.
§60.2 of Subpart A defines startup as the "setting in operation of an affected
facility for any purpose." Startup, therefore, is the first time the affected facility is
operated for any reason. This includes such operations as short process runs of raw
material for a determination of product quality or specification as well as full production
runs.
The stack particulate matter standard is in the form of a concentration (0.05
g/dscm). Unless a wet scrubbing control device is used, an opacity limit of 7 percent
is also applicable. In lieu of an opacity standard for wet scrubber control devices,
surrogate indicators of compliance were chosen involving monitoring of the scrubber
pressure drop and scrubbing liquid flow rate (Sections 3.5 and 3.7).
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Finally, it should be noted that the regulations specify that the emissions
standards take effect on and after the date on which the performance test(s) is
completed. §60.11 (d) of Subpart A, however, does require that the owner or operator
maintain and operate, at all times, any affected facility and associated control
equipment "in a manner consistent with good air pollution control practice for
minimizing emissions." In addition, any applicable State or local emission standards
remain in force.
See also:
Appendix B, §§60.8 and 60.11 (d)
Sections 3.5 and 3.7
3.3.2 Fugitive Emissions Standards - §60.672 (b) & (c)
(b) On and after the sixtieth day after achieving the maximum production rate at which
the affected facility will be operated, but not later than 180 days after initial startup, no
owner or operator subject to the provisions of this subpart shall cause to be discharged
into the atmosphere from any transfer point on belt conveyors or from any other
affected facility any fugitive emissions which exhibit greater than 10 percent opacity,
except as provided in paragraphs (c), (d), and (e) of this section.
(c) On and after the sixtieth day after achieving the maximum production rate at which
the affected facility will be operated, but no later than 180 days after initial startup, no
owner or operator shall cause to be discharged into the atmosphere from any crusher,
at which a capture system is not used, fugitive emissions which exhibit greater than 15
percent opacity.
Explanation/Application:
All of the provisions of paragraphs 1, 2, and 4 contained in the
"Explanation/Application" of Section 3.3.1 apply to fugitive emissions as well as stack
emissions.
In some situations it may be difficult to distinguish the equipment performing the
initial reduction at the plant as a crusher or a grinding mill. Jaw crushers, gyratory
crushers, and cone crushers are used for coarse reduction only. Roll crushers,
hammermills and impactors may be used as either crushers or grinding mills in that
they may be designed and operated for coarse or fine reduction. Some quarry
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material may be sufficiently small in size that grinding mills may be employed for initial
size reduction in the plant. If a hammermill, impactor, or roll mill are installed as initial
reduction equipment, a determination may be necessary as to whether the equipment
is designated as a crusher or grinding mill for the purposes of applying the 15 percent
opacity standard for crushers without capture systems. As a guide, grinding mills
generally reduce the feed material to a 40 mesh or less.
See also:
Section 2.1 and 2.2
3.3.3 Exemption for Truck Dumping - §60.672 (d)
(d) Truck dumping of nonmetallic minerals into any screening operation, feed hopper, or
crusher is exempt from the requirements of this section.
Explanation/Application:
Care must be taken during opacity compliance determinations to separate
emissions from the affected facility from those of any truck dumping operation. If the
emissions cannot be separated during a Method 9 compliance test, do not interrupt
recording opacity observations, but note which observations occurred during the truck
dumping. When determining average opacity, observations during these events
cannot be used in any 24-observation (6-minute) set.
See also:
Appendix C, Section 2.4 and 2.5
3.3.4 Affected Facilities Enclosed in Buildings - §60.672(e)
(e) If any transfer point on a conveyor belt or any other affected facility is enclosed in a
building, then each enclosed affected facility must comply with the emission limits in
paragraphs (a), (b), and (c) of this section, or the building enclosing the affected facility
or facilities must comply with the following emission limits:
(1) No owner or operator shall cause to be discharged into the atmosphere from any
building enclosing any transfer point on a conveyor belt or any other affected facility any
visible fugitive emissions except emissions from a vent as defined in §60.671.
(2) No owner or operator shall cause to be discharged into the atmosphere from any
vent of any building enclosing any transfer point on a conveyor beii or any other
affected facility emissions which exceed the stack emissions limits in paragraph (a) of
this section.
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Explanation/Application:
Affected facilities enclosed in buildings must comply with either §60.672(a), (b),
or (c), or exhibit no visible emissions from the building as determined by EPA Method
22. If visible emissions from the building are so detected, EPA Method 9 should be
employed inside the building to determine the opacity of the emissions from the
affected facility or facilities.
See also:
Sections 3.6.4 and 4.7.1
3.4 Reconstruction - §60.673
3.4.1 Fixed Capital Cost Exemptions - §60.673 (a)
(a) The cost of replacement of ore-contact surfaces on processing equipment shall not
be considered in calculating either the "fixed capital cost of the new components" or the
"fixed capital cost that would be required to construct a comparable new facility" under
§60.15. Ore-contact surfaces are crushing surfaces, screen meshes, bars, and plates,
conveyor belts, and elevator buckets.
Explanation/Application:
As set forth in §60.15 of Subpart A, reconstruction of an existing facility (e.g.,
screen, bucket elevator, crusher, etc.) means the replacement of components to such
an extent that the fixed capital cost of the new components exceeds 50 percent of the
fixed capital cost to construct a comparable new facility, and it is technologically and
economically feasible to meet the applicable standards. "Fixed capital cost" is also
defined as "the capital needed to provide all the depreciable components."
Under the provisions of Subpart OOO, ore-contact surfaces of both the existing
facility and a comparable new facility are not included in calculating the fixed capital
costs. The ore-contact surfaces cited in §60.673 (a) are the only ore-contact surfaces
to be exempted from calculating the fixed capital costs.
Some confusion may result when replacing components as to whether the
replacements are covered under the routine maintenance, repair, and replacement
provisions of §60.14 (e) (modifications) or under the provisions of §60.15
(reconstruction). If the replacement components are ore-contact surfaces as defined
in §60.673 (a), unlimited monies may be expended for their replacement without
triggering either the modification or reconstruction provisions. If the replacement
components are not ore-contact surfaces, are considered routine replacements, and
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the cost of the replacements do not exceed the IRS annual asset guideline repair
allowance, the modification provisions do not apply. If the replacements are not
considered routine and do not include ore-contact surfaces, the reconstruction
provisions will apply, but only depreciable components would be included in
calculating fixed capital costs.
See also:
Appendix B, §60.2 "Capital expenditure," §§60.14 and 60.15
Section 3.15.
3.4.2 Continuous Programs of Component Replacement - §60.673 (b)
(b) Under §60.15, the "fixed capital cost of the new components" includes the fixed
capital cost of all depreciable components (except components specified in paragraph
(a) of this section) which are or will be replaced pursuant to all continuous programs of
component replacement commenced within any 2-year period following August 31,
1983.
Explanation/Application:
A 2-year period begins each time the owner or operator commences a
reconstruction. "Commenced" is defined in the general provisions (§60.2) as meaning
that an owner or operator has undertaken a continuous program of construction or
modification or that an owner or operator has entered into a contractual obligation to
undertake or complete, within a reasonable time, a continuous program of
construction or modification.
There is not a single 2-year period that begins on any specified date. Rather,
EPA will aggregate any continuous programs of component replacement that begin
within any 2-year period in determining whether "the fixed capital cost of the new
components exceeds 50 percent of the fixed capital cost that would be required to
construct a comparable entirely new facility..." [§60.15(b)(1)] (the "50 percent test.")
For example, suppose that an owner or operator of an existing facility begins program
A of component replacement in month 1, program B in month 40, program C in month
60, and program D in month 80, and that programs B and C, considered together,
meet the 50 percent test in §60.15(b)(1). Since programs B and C commenced within
a 2-year period (20 months apart), the 50 percent test would be satisfied (regardless
of programs A and D, and regardless of when programs B and C are finished).
The affected facility for the purpose of determining the 50 percent reconstructed
threshold is the individual piece of equipment (e.g., crusher, grinding mill, etc.) as
defined in §60.670 and §60.671, not the entire plant. However, replacement of an
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existing affected facility with a new facility of equal or smaller size as described in
§60.670(d) is exempt from compliance with emission limits, but is subject to the
reporting and recordkeeping requirements in §60.676.
See also:
Appendix B, §60.2 "Commenced," "Construction," and "Modification"
Section 3.1.4.
3.5 Monitoring of Operations (Wet Scrubbers) - §60.674
The owner or operator of any affected facility subject to the provisions of this subpart
which uses a wet scrubber to control emissions shall install, calibrate, maintain and
operate the following monitoring devices:
(a) A device for the continuous measurement of the pressure loss of the gas stream
through the scrubber. The monitoring device must be certified by the manufacturer to
be accurate within _+. 250 pascals _+. 1 inch water gauge pressure and must be
calibrated on an annual basis in accordance with manufacturer's instructions.
(b) A device for the continuous measurement of the scrubbing liquid flow rate to the wet
scrubber. The monitoring device must be certified by the manufacturer
to be accurate within _+. 5 percent of design scrubbing liquid flow rate
and must be calibrated on an annual basis in accordance with manufacturer's
instructions.
Explanation/Application:
The principle of operation of a wet scrubbing device involves contacting dust
particles with liquid droplets in some way and then having the wetted and unwetted
particles impinge upon a collecting surface where they can be separated and
removed. The major types of wet scrubbers are wet cyclones, mechanical, spray, self-
induced spray, and venturi scrubbers.
The standards do not include opacity requirements for wet scrubbers. In order
to verify proper operation and maintenance of wet scrubbers, the standards require
the installation, calibration, and recording of the pressure drop across the scrubber
including any type of mist eliminator; and installation, calibration, and recording of the
flow rate of the scrubbing liquid. These surrogate indicators of scrubber performance
can be used to isolate typical performance problems (i.e., throat wear or pluggage,
decreased liquid-to-gas ratio, decreased pressure drop, etc.). See Section 3.7 for
recordkeeping and notification requirements.
"Monitoring device" is defined in §60.2 of Subpart A as "the total equipment,
required under the monitoring of operations sections in applicable subparts, used to
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measure and record (if applicable) process parameters." "Continuous" measurement
of the data is required under §60.674 and recording of the data is required under
§60.676.
See also:
Appendix B, §60.2 "Monitoring device," §§60.7(d) and 60.13(b)
Sections 3.5, 3.6.6, and 3.7.3
3.6 Test Methods and Procedures - §60.675
3.6.1 General Requirements for Performance Tests - §60.675(a)
(a) In conducting the performance tests required in §60.8, the owner or operator shall
use as reference methods and procedures the test methods in Appendix A of this part or
other methods and procedures as specified in this section, except as provided in
§60.8(b). Acceptable alternative methods and procedures are given in paragraph (e) of
this section.
Explanation /Application:
§60.8 of Subpart A provides the general performance test requirements for this
and all other NSPS. These requirements include notification requirements, initial
performance test requirements, test methods and exceptions, requirements for
operating conditions during testing, and sampling facility requirements. §60.8 of
Subpart A also specifies the number of test runs (3), and that compliance is based on
the average of the three test runs unless otherwise specified in the applicable Subpart.
Appendix A of 40 CFR Part 60 contains the reference methods for determining
compliance with all NSPS. Methods applicable to the nonmetallic mineral processing
NSPS include Methods 1 through 5, 9, 17, and 22.
§60.8(b) provides authority for the Administrator (or his representative) to
specify or approve 1) equivalent methods, 2) alternative methods, 3) minor changes in
the methodology of the reference methods, 4) waivers of performance test
requirements, or 5) reduced sampling times or sampling volumes. Approved
alternative procedures for this NSPS are provided in paragraph (e) of this section.
Alternative methods and procedures beyond those given in paragraph (e) may be
specified by the Administrator or submitted by the source and approved by the
Administrator as he deems adequate to determine that the source is in compliance.
See also:
Section 3.7.3
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3.6.2 Tesf Methods and Procedures for Stack Emissions - §60.675(b)
(b) The owner or operator shall determine compliance with the paniculate matter
standards in §60.272(a) as follows: 1) Method 5 or Method 17 shall be used to
determine the paniculate matter concentration. The sample volume shall be at least
1.70 dscm (60 dscf). For Method 5, if the gas stream being sampled is at ambient
temperature, the sampling probe and filter may be operated without heaters. If the gas
stream is above ambient temperature, the sampling probe and filter may be operated at
a temperature high enough, but no higher than 121° C (250° F), to prevent water
condensation on the filter, and 2) Method 9 and the procedures in §60.11 shall be used
to determine opacity.
Explanation/Application:
As explained in the preface of 40 CFR 60, Appendix A, a "Test Methods and
Procedures" section is included within the respective subpart for each NSPS. The
purpose of §60.675(b) is to 1) identify the applicable test method(s), and 2) identify
any special instructions or conditions to be followed such as sampling rates, volumes,
or temperatures. Paragraph (b)(1) above provides these special instructions and
conditions for this NSPS.
Paragraph (b)(2) above specifies Method 9 for determining compliance with the
opacity standards of this subpart. §60.11 (b) of Subpart A requires that initial
compliance be determined using a minimum total time of observation for each affected
facility of 3 hours (30-6 minute averages) unless an alternate method is approved by
the Administrator, or the Administrator waives the associated performance test.
§60.11 (e)(1) of Subpart A requires that an opacity compliance determination be
made concurrently with the performance test (stack test) unless: 1) no performance
test is required, or 2) visibility or other conditions prevent concurrent observations.
Under such conditions, see §60.11(e)(1) for scheduling or rescheduling instructions for
initial opacity determinations. §60.11 also provides other compliance and maintenance
standards for performance tests and compliance determinations.
See also:
Appendix B, §§60.8 and 60.11
Appendix C, Sections 2.1 through 2.5
Sections 3.3, 3.6.1, and 3.7.3
3.6.3 Test Methods and Procedures for Fugitive Emissions - §60.675(c)
(c) In determining compliance with the paniculate matter standards in §60.672(b) and
(c), the owner or operator shall use Method 9 and the procedures in §60.11, with the
following additions:
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1. The minimum distance between the observer and the emission source shall be
4.57 meters (15 ft).
2. The observer shall, when possible, select a position that minimizes interference
from other fugitive emission sources (e.g., road dust). The required observer
position relative to the sun (Method 9, Section 2.1) must be followed.
3. For affected facilities using wet dust suppression for paniculate matter control, a
visible mist is sometimes generated by the spray. The water mist must not be
confused with paniculate matter emissions and is not to be considered a visible
emission. When a water mist of this nature is present, the observation of
emissions is to be made at a point in the plume where the mist is no longer
visible.
Explanation/Application:
Paragraph (c)(1) emphasizes a minimum distance of 15 feet from the emission
source so that opacity observations are not attempted while the observer is in the
plume.
Paragraph (c)(2) emphasizes selecting a position to minimize interferences from
other sources while maintaining the required observer-to-sun angle sector of 140°.
Finally, paragraph (c)(3) emphasizes that water mists from wet suppression
system must not be confused with source emissions. In some situations, a wet
suppression system may be activated intermittently. In such cases, two options are
possible. First, choose a point in the plume beyond which the water mist disappears.
Second, choose the point in the plume of greatest opacity when the wet dust
suppression system is not being operated and begin the Method 9 observations.
When the wet dust suppression system is operated, continue to record opacity at this
point but note all such observations on the data sheet. During data reduction,
eliminate any such observations from any 24-observation (6-minute) set.
See also:
Appendix B, §§60.8 and 60.11
Appendix C, Sections 2.1 through 2.5
Sections 3.3.2, 3.6.1, and 3.6.2
3.6.4 Determining the Presence of Fugitive Emissions From Buildings - §60.675(d)
(d) In determining compliance with §60.672(e), the owner or operator shall use Method
22 to determine fugitive emissions. The performance test shall be conducted while all
affected facilities inside the building are operating. The performance test for each
building shall be at least 75 minutes in duration, with each side of the building and the
roof being observed for at least 15 minutes.
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Explanation/Application:
The 75 minute duration (15 minutes per side and the roof) using Method 22 is
applicable for the initial performance test.
See also:
0 Appendix D, Sections 1 through 6
Section 3.3.4
3.6.5 Approved Alternatives to the Test Procedures for Fugitive Emissions - §60.675(e)
(e) The owner or operator may use the following as alternatives to the reference
methods and procedures specified in this section:
(1) For the method and procedure of paragraph (c) of this section, if emissions from two
or more facilities continuously interfere so that the opacity of fugitive emissions from an
individual affected facility cannot be read, either of the following procedures may be
used:
(i) Use for the combined emission stream the highest fugitive opacity standard
applicable to any of the individual affected facilities contributing to the emissions stream.
(ii) Separate the emissions so that the opacity of emissions from each affected facility
can be read.
Explanation/Application:
The "highest fugitive opacity standard" cited in paragraph (e)(1)(i) must be
Federally enforceable. In addition, any Method 9 opacity observations must use the
point of highest opacity whether from a single or combined plume.
Separation of emissions, as cited in paragraph (e)(1)(ii), may be accomplished
by construction of a physical barrier or by shutting down the interfering facility if the
maximum achievable production rate (capacity) of the affected facility being tested is
not altered or the shutting down of the interfering facility does not cause operational
problems.
See also:
Appendix C, Sections 2.1 through 2.5
Sections 3.6.1, 3.6.3, and 4.7.2
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3.6.6 Wet Scrubber Monitoring Compliance - §60.675(9
(f) To comply with §60.676(d), the owner or operator shall record the measurements as
required in §60.676(c) using the monitoring devices in §60.674(a) and (b) during each
paniculate matter run and shall determine the averages.
Explanation/Application:
To comply with the semi-annual wet scrubber monitoring notification
requirements of the standards (Section 3.7.3), the owner or operator shall record daily
any changes in scrubber pressure drop and scrubbing liquid flow rate. Pressure drop
and liquid flow rate is to be monitored using the equipment described in Section 3.5.
These measurements are to also be recorded during each run of the performance test
[§60.676(c)] and included in the report required by §60.676(f).
See also:
Sections 3.5, 3.7.3, 3.7.4, and 3.7.5
3.7 Reporting and Recordkeeping - §60.676
3.7.1 Reporting Requirements for Equal or Smaller Size Replacements - §60.676(a)
(a) Each owner or operator seeking to comply with §60.670(d) shall submit to the
Administrator the following information about the existing facility being replaced and the
replacement piece of equipment.
(1) For a crusher, grinding mill, bucket elevator, bagging operation, or enclosed truck or
railcar loading station:
(i) The rated capacity in tons per hour of the existing facility being replaced and (ii) The
rated capacity in tons per hour of the replacement equipment.
(2) For a screening operation:
(i) The total surface area of the top screen of the existing screening operation being
replaced and (ii) The total surface area of the top screen of the replacement screening
operation.
(3) For a conveyor belt:
(i) The width of the existing belt being replaced and (ii) The width of the replacement
conveyor belt.
(4) For a storage bin:
(i) The rated capacity in tons of the existing storage bin being replaced and (ii) The
rated capacity in tons of replacement storage bins.
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Explanation/Application:
The information above, plus the information required under paragraph (b) of
§60.676, is to be forwarded to the Administrator when requesting the exemption for
replacement of existing facilities with facilities of equal or smaller size. The information
is to be postmarked 60 days or as soon as practicable before the change is
commenced [§60.7(a)(4)].
See also:
Appendix B, §60.7(a)(4)
Sections 3.1.4 and 3.7.2
3.7.2 Special Reporting Requirements for Equal or Smaller Size Replacements -
§60.676(b)
(b) Each owner or operator seeking to comply with §60.670(d) shall submit the following
data to the Director of the Emission Standards, (MD-13), U.S. Environmental Protection
Agency, Research Triangle Park, North Carolina, 27711.
(1) The information described in §60.676(a).
(2) A description of the control device used to reduce paniculate matter emissions from
the existing facility and a list of all other pieces of equipment controlled by the same
control device; and
(3) The estimated age of the existing facility.
Explanation/Application:
In addition to the reporting requirements in Section 3.7.1, special reporting is
required to the Office of Air Quality Planning and Standards, Emission Standards
Division in Research Triangle Park, North Carolina. This information is to be used for
the purpose of reviewing the standard. As with the time requirements described in
Section 3.7.1, these data are to be postmarked 60 days or as soon as practicable
before the change is commenced.
See also:
Appendix B, §60.7(a)(4)
Sections 3.1.4 and 3.7.1
3.7.3 Wet Scrubber Requirements - §60.676(c)(d) & (e)
(c) During the initial performance test of a wet scrubber, and daily thereafter, the owner
or operator shall record the measurements of both the change in pressure of the gas
stream across the scrubber and the scrubbing liquid flow rate.
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(d) After the initial performance test of a wet scrubber, the owner or operator shall
submit semiannual reports to the Administrator of occurrences when the measurements
of the scrubber pressure loss (or gain) and liquid flow rate differ by more than _+_ 30
percent from the averaged determined during the most recent performance test.
(e) The reports required under paragraph (d) shall be postmarked within 30 days
following the end of the second and fourth calendar quarters.
Explanation/Application:
Changes in pressure drop of the gas stream across the scrubber and the
scrubbing liquid flow rate are to be measured according to the procedures described
in Section 3.5. The section above requires that all "occurrences" of pressure drop and
liquid flow rate that differ by more than _+_ 30 percent from the average during the most
recent performance test be submitted to the Administrator. Because the requirements
described in Section 3.5 call for "continuous" measurements of the scrubber pressure
drop and liquid flow rate, and because paragraph (d) of this section requires reporting
of all occurrences of the specified changes in operating parameters, it would follow
that some type of continuous recording equipment is required to identify these
occurrences on a continuous basis. Because such occurrences may be
instantaneous or represent prolonged events, noncontinuous recording of the data is
not appropriate given the reporting requirements of this Subpart.
Finally, it should be recognized that the intent of the measurement and
reporting requirements of this section is to substitute these parameters as surrogate
indicators of opacity. Therefore, to avoid unnecessary reporting of occurrences due to
instrument noise or other nonrepresentative factors, only occurrences of 6 minutes or
greater (minimum observation time for EPA Method 9) need be reported.
See also:
Appendix B, §60.13(b)
Sections 3.5 and 3.6.6
3.7.4 Performance Test Reporting Requirements - §60.676(1)
(f) The owner or operator of any affected facility shall submit written reports of the
results of all performance tests conducted to demonstrate compliance with the
standards set forth in §60.672, including reports of opacity observations made using
Method 9 to demonstrate compliance with §60.672 (b) and (c) and reports of
observations using Method 22 to demonstrate compliance with §60.672(e).
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Explanation/Application:
The written reports referred to in this paragraph are due within the same time
requirements found in Subpart A, §60.8(a) (i.e., within 60 days after achieving the
maximum production rate at which the facility will be operated, but no later than 180
days after initial startup).
See also:
Appendix B, §§60.8 and 60.11
3.7.5 Requirements Under Delegated Enforcement Authority - §60.676(g)
(g) The requirements of this paragraph remain in force until and unless the Agency, in delegating
enforcement authority to a State under section 111 (c) of the Act, approves reporting
requirements or an alternative means of compliance surveillance adopted by such States. In
that event, affected sources within the State will be relieved of the obligation to comply with
paragraphs (a), (c), (d), (e), and (f) of this section, provided that they comply with requirements
established by the State. Compliance with paragraph (b) of this section will still be required.
Explanation/Application:
Enforcement authority can be delegated to a State, provided the reporting and
recordkeeping requirements of the State are at least as stringent as the reporting and
recordkeeping requirements of this Subpart. Once enforcement authority is approved
by EPA, the owner or operator is relieved of the following reporting and recordkeeping
requirements.
1. Equal or smaller size replacement data (Section 3.7.1)
2. Wet scrubber requirements (Section 3.7.3)
3. Performance test requirements (Section 3.7.4).
Even under delegated authority to the State, however, the special reporting
requirements for replacements of equal or smaller size (Section 3.7.2) remain in force.
See also:
Section 3.7
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SECTION 4
COMPLIANCE DETERMINATION
(LEVEL II INSPECTION)
The purpose of this section is to provide the inspector with a logical and
sequential methodology for determining the compliance status of affected facilities
subject to 40 CFR 60, Subpart OOO. This methodology is consistent with a Level II
compliance inspection as outlined in the Air Compliance Manual. EPA-340/1-85-020,
September 1985, but cannot be employed as a substitute for the initial performance
test requirements described in Subparts A and OOO. A Level II inspection
incorporates the following activities:
0 "Walkthrough" evaluation of emission sources and/or devices
0 Visible emission observations
0 Data collection from and evaluation of process and control device
instrumentation
0 Checks (from outside) of internal conditions of control devices (if shut
down)
0 Routine check of continuous emission monitor (GEM) data
0 Check of source-maintained records
0 Annual determination of continued operation and process throughput of
sources that do not operate control equipment.
General procedures for a Level II inspection include the following sequential
steps:
1. Pre-inspection preparation
2. Pre-entry observations
3. Entry
4. Opening conference with source personnel
5. Source records verification
6. Field inspection procedures
7. Post-inspection conference
8. Reporting and tracking.
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The remainder of this section will cover each of these Level II inspection procedures
as they specifically apply to the nonmetallic mineral processing NSPS.
4.1 Pre-lnspection Preparation
Pre-inspection preparation is always necessary to ensure effective use of the
inspector's time and the facility's time, and to ensure that the inspection is properly
focused on collecting relevant data and information. This preparation involves:
0 Review of facility background
0 Development of an inspection plan
0 Notifications
0 Equipment preparation.
4.1.1 Review of Plant Background
A review of the available background information on the plant to be inspected is
essential to the overall success of the inspection. The review should enable the
inspector to become familiar with the plant's process and emission characteristics;
conduct the inspection in a timely manner; minimize inconvenience to the plant by not
requesting unnecessary data such as that previously provided to the EPA or another
agency; conduct an efficient, but thorough inspection; clarify technical and legal issues
before entry; and prepare a useful inspection report. The following types of
information should be reviewed.
Basic Plant Information
0 Names, titles, and phone numbers of plant representatives
0 Maps showing plant location and geographic relationship to residences,
etc. potentially impacted by emissions
0 Process and production information
0 Flowsheets identifying affected facilities, control devices, monitors, and
other points of interest
0 Safety equipment requirements.
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Pollution Control Equipment and Other Relevant Equipment Data
0 Description and design data for control devices and relevant process
equipment
0 Sources and characterization of emissions
0 Previous inspection checklists (and reports)
0 Baseline performance data and control equipment.
Regulations. Requirements, and Limitations
0 Most recent permits (construction and/or operating) for affected facilities
subject to the NSPS
0 Location and description of all affected facilities subject to the NSPS
standard for particulate matter and the locations of affected facility
emission points (also included in final report)
0 Location and description of all affected facilities subject to the NSPS
recordkeeping/reporting requirements only
° Special exemptions and waivers, if any (e.g., affected facilities previously
waived from initial compliance testing and any waiver conditions)
0 Acceptable plant operating conditions (e.g., maximum permitted
throughput or process weight rates, etc.)
0 Total top screen surface areas of all affected facility screens and belt
widths of all affected facility conveyor belts (for onsite verification)
0 Average scrubber pressure drop and scrubbing liquid flow rate from
most recent compliance test (if applicable)
0 Schedules for replacement of existing facilities with new facilities of equal
or smaller size (if any)
Other applicable emission limits or opacity limits of affected facilities more
restrictive than NSPS limits (i.e., PSD, State regulations, etc.).
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Facility Compliance and Enforcement History
0 Previous inspection reports
0 Complaint history and reports
0 Past conditions of noncompliance
0 Previous enforcement actions
° Pending enforcement actions, compliance schedules and/or variances
0 Continuous monitoring system reports
0 Startup, shutdown and malfunction reports.
4.1.2 Development of an Inspection Plan
Based on the review of the plant background information, the inspector should
develop an inspection plan addressing the following items.
0 Inspection objectives
0 Tasks sequence
0 Procedures
0 Resources
0 Schedule
Although the main objective of the inspection is to determine source compliance
with the NSPS provisions, the plant operating schedule or the sheer number of
sources may not be conducive to covering the entire plant in one inspection. Portions
of the plant or particular production lines may need to be covered separately or during
different inspections. This may be due to intermittent production or scheduling of
maximum operating conditions for different production lines. If necessary, the
inspector should divide the affected facilities to be inspected into manageable groups.
Once the inspector has determined which affected facilities and what plant
records are to be inspected, each individual task necessary to meet the inspection
objectives should be identified and procedures reviewed for accomplishing each task.
All inspection tasks should also be arranged in a logical and chronological
sequence that takes into account the inspection objectives as well as possible
constraints that are anticipated at the plant. The task sequence, however, should
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include the flexibility for change if onsite conditions are not as expected or if plant
operations change during the inspection.
Finally, the resources required to complete the inspection should be reviewed.
Resources include personnel, inspection equipment, and safety equipment required at
the site.
Appendix E provides sample inspection forms that may be used to construct
the task sequence list for an inspection plan.
4.1.3 Notification of Plant and Responsible Agency
EPA Regional Offices and State and local agencies vary in their exact policies
concerning giving a plant advance notification of an inspection. In a recent EPA policy
memo entitled Final Guidance on Use of Unannounced Inspections, however, the
Stationary Source Compliance Division recommends that all Regional inspection
programs incorporate unannounced inspections as part of their overall inspection
approach. The advantages of the unannounced inspection are: 1) the opportunity to
observe the source under normal operating conditions, because the source does not
have time to prepare for the inspection, 2) detection of visible emissions and O&M-
type problems and violations, 3) creation of an increased level of attention by a source
to its compliance status, and 4) projection of a serious attitude toward surveillance by
the Agency.
The potential negative aspects of performing unannounced inspections are 1)
the source may not be operating or key plant personnel may not be available, and 2)
there could be an adverse impact on Agency source relations. However, it has been
demonstrated by the Regional Offices who already use the unannounced inspections
that, in the majority of cases, these drawbacks can be overcome.
When using the unannounced inspection, an alternative to arriving at the source
totally unannounced is to contact the source shortly before the scheduled inspection
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time. This is left to the discretion of the Regional Office and/or the inspector and must
be done so as not to alter the representativeness of the source operation. The
amount of advanced notice given should be noted in the inspection report.
Announced inspections are performed by EPA and its authorized
representatives when some specific purpose is served by providing such notice.
Situations where announced inspections are appropriate are:
0 When specific information is being sought which must be prepared by
the source, or where the source must make significant accommodations
for the inspector to gather the information
0 When the assistance of specific plant personnel is necessary for the
successful performance of the inspections, i.e., the information they
provide cannot be obtained from other on-duty plant personnel or by a
follow-up information request
0 When inspecting government facilities or sources operating under
government contract where entry is restricted due to classified
operations.
When the inspection is announced in advance, a lead time of five working days
is generally appropriate. Notification may be by telephone or letter and it may or may
not include the exact date and time of the inspection. Instances where written
notification (instead of oral) is appropriate are:
0 When requested by the State/local agency or by the source
0 When extensive or specific records are being sought
0 When the inspection is to be performed solely by an EPA or State/local
contractor
0 When inspecting government facilities with classified operations or
otherwise restricted entry
0 Special-purpose inspections, e.g., to establish conditions for a source-
specific SIP revision.
The plant representative notified should have the authority to release data and
samples and to arrange for access to specific processes. In addition, when notifying a
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plant of an inspection, information should be requested in regard to onsite safety
regulations. This will avoid problems concerning safety equipment at the time of the
inspection.
State and/or local agencies should be given a minimum of five working days
advance notice of unannounced or announced inspections to be conducted within
their jurisdiction. In the case of an announced inspection, this notification should
precede that given to the source.
Notification can be written or oral, in any case, a record should be kept. The
notification and record thereof should include the following items:
0 Name and location of subject facility
0 Date and approximate time of the activity
0 Regional Office contact (phone number, etc.)
0 Reason for the inspection
0 Name of the State contact
0 Date and time of notification.
State/EPA Memorandums of Agreements should be consulted for further
information on notification procedures.
4.1.4 Equipment Preparation
Part of the pre-inspection preparation involves obtaining and preparing
inspection and safety equipment. A general list of inspection and safety equipment for
a Level II compliance inspection of nonmetallic mineral processing facilities is included
in Table 4-1. All safety equipment should meet Mine Safety and Health Administration
(MSHA) requirements.
All equipment should be checked before use. The inspector is responsible for
seeing that all equipment necessary to conduct an inspection is brought to the
inspection site.
Safety equipment required for a facility is based on the plant's response to the
inspection announcement or on the safety requirements for that facility previously
recorded in the agency files. Safety requirements must be met, not only for safety
reasons, but to ensure that the inspector is not denied entry to the plant.
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TABLE 4-1. RECOMMENDED INSPECTION AND SAFETY EQUIPMENT
Inspection equipment Safety equipment
Tape measure Respirator with appropriate cartridge(s)
Flashlight Hardhat
Stopwatch Safety glasses or goggles
Duct tape Gloves
Sample bottles Coveralls
Safety shoes
Ear protection
NIOSH/OSHA Pocket Guide to Chemical Hazards
Before or after equipment preparation, the inspector must also consider what
written materials, forms, documents, etc. he/she will require during the inspection.
These should also be gathered and organized before the inspection. These materials
may include any or all from the following list:
Maps
0 Flowcharts
Plant layout
0 Applicable regulations
0 Inspection checklists
0 Field notebook
0 Reference materials
0 Visible emission observation forms (Method 9 and 22 as applicable)
0 Inspection plan or agenda
0 Agency credentials
0 Baseline data
0 Information requested by facility.
4.2 Pre-Entry Observations
Two types of observations, conducted prior to plant entry, have been shown to
be valuable in determination of facility compliance. These are the observation of the
plant surroundings and the visible emission observations.
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4.2.1 Plant Surroundings Observation
Observations of areas surrounding the plant before entry may reveal a variety of
signs of operational practices and pollutant emissions which can aid in the pre-entry
evaluation. These include:
0 Obvious vegetation damage near the plant
Deposits on cars parked close by
0 Conditions around product and waste piles
0 Heavy dusting of standing trees or buildings
0 Proximity of sources to potential receptors.
4.2.2 Visible Emissions Observations
In addition to observing the plant surroundings prior to entry, the inspector may
also perform visible emission observations at that time. Visible emission observations
can be performed on both stack and fugitive sources using both Method 9 and 22 as
long as the provisions of the references methods and the provisions of §§60.11 and
60.675(c) are met.
Although it is likely that not all emission points will be visible from a location
outside the plant property lines, elevated emission points (e.g., stacks, elevated
buildings, silos, bucket elevators, conveyor belt transfer points, etc.) may be easily
read. Extreme care should be taken, however, to ensure that the emission point is
correctly identified at the time of observation. Verification of the emission points that
were observed should be sought during the onsite inspection. Visible emission
observation procedures are detailed in Section 4.7.
4.3 Plant Entry
This section details the accepted procedures under the Clean Air Act (CAA or
the Act) for entry to a facility to conduct onsite inspections. As such, these
procedures are applicable to EPA inspectors and may or may not be applicable or
compatible with State or local procedures. This section does not provide procedures
for obtaining an inspection warrant in the case of refusal of entry which are covered in
detail in other publications.
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4.3.1 Authority
The Clean Air Act authorizes plant entry for the purposes of inspection. In
specific, Section 114 of the Act states:
" the Administrator or his authorized representative, upon presentation
of his credentials shall have a right of entry to, upon or through any
premises of such person or in which any records required to be
maintained are located, and may at reasonable times have access to
and copy any records, inspect any monitoring equipment or methods ,
and sample any emissions which such person is required to sample "
4.3.2 Arrival
Arrival at the facility must be during normal working hours. Entry through the
main gate is recommended unless the inspector has been previously instructed
otherwise. As soon as the inspector arrives on the premises, he should locate a
responsible plant official usually the plant owner, manager, or chief environmental
engineer. In the case of an announced inspection, this person would most probably
be the official to whom notification was made. The inspector should note the name
and title of this plant representative.
4.3.3 Credentials
Upon meeting the appropriate plant official, the inspector should introduce
himself or herself as an EPA inspector and present the official with the proper EPA
credentials and state the reason for requesting entry. The credentials provide the
plant official with the assurance that the inspector is a lawful representative of the
Agency. Each office of the EPA issues its own credentials; most include the
inspector's photograph, signature, his physical description (age, height, weight, color
of hair and eyes), and the authority for the inspection. Credentials must be presented
whether or not identification is requested. After facility officials have examined the
credentials, they may telephone the appropriate EPA Office for verification of the
inspector's identification. Credentials should never leave the sight of the inspector.
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4.3.4 Consent
Consent to inspect the premises must be given by the owner, operator, or his
representative at the time of the inspection. As long as the inspector is allowed to
enter, entry is considered voluntary and consensual, unless the inspector is expressly
told to leave the premises. Express consent is not necessary; absence of an express
denial constitutes consent.
If there is difficulty in gaining consent to enter, inspectors should tactfully probe
the reasons and work with officials to overcome the obstacles. Care should be taken,
however, to avoid threats of any kind, inflammatory discussions, or deepening of
misunderstandings. Whenever the situation is beyond the authority or ability of the
inspector, he or she should contact their supervisor for guidance.
If the inspector is asked to leave the premises after the inspection has begun,
the inspector should 1) tactfully discuss the reason for denial, 2) avoid any situation
that might be construed as threatening or inflammatory, 3) withdraw from the premises
and contact his or her supervisor, 4) note the facility name, address, and the name
and title of the plant official(s) approached and the authority of the person issuing the
denial, and 5) note the date, time, and reason for the denial as well as facility
appearance and any reasonable suspicion why entry was denied. These procedures
also apply if the inspector is denied entry to certain parts of the facility. After
withdrawal from the premises, the inspector should always contact the appropriate
Agency office for further instructions including a determination of whether a warrant
should be obtained to inspect the facility.
4.3.5 Uncredentialed Persons Accompanying an Inspector
The consent of the owner or agent in charge must be obtained for the entry of
persons accompanying an inspector to a site if they do not have specific authorization.
If consent is not given voluntarily, these persons may not enter the premises. If
consent is given, these persons may not view confidential business information unless
officially authorized for access.
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4.3.6 Waivers, Releases, and Sign-In Logs
When the facility provides a blank sign-in sheet, log, or visitor register, it is
acceptable for inspectors to sign it. Under no circumstances should EPA employees
sign any type of "waiver" or "visitor release" that would relieve the facility of
responsibility for injury or which would limit the rights of the Agency to use data
obtained from the facility.
If such a waiver or release is presented, the inspector should politely explain
he/she cannot sign and request a blank sign-in sheet. If an inspector is refused entry
because they do not sign such release, they should leave and immediately report all
pertinent facts to the appropriate supervisory and/or legal staff. All events
surrounding the refused entry should be fully documented. Problems should be
discussed cordially and professionally.
4.3.7 Nondisclosure Statements
Inspectors have, in the past, occasionally been asked to sign nondisclosure
statements or agreements. These agreements vary slightly in content from one to
another, but generally require that confidential information, disclosed to an inspector
during the course of an inspection, be handled thereafter in a specified manner. An
inspector should not sign such agreements since Federal Regulations (40 CFR Part 2,
as amended) on the confidentiality of business information already protect the
business from disclosure of confidential information.
4.4 Opening Conference
Once legal entry has been established, the inspector should proceed with a vital
part of every inspection, the opening conference. The purpose of the opening
conference is to inform the facility official(s) of the purpose of the inspection, the
authorities under which it will be conducted, and the procedures to be followed. The
opening conference also offers the inspector the opportunity to strengthen Agency -
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industry relations through a positive attitude and provide relevant information and other
assistance. The effective execution of the opening conference on the inspector's part
often facilitates the remainder of the inspection.
During the opening conference, the inspector is responsible for covering the
following items:
0 Inspection Objectives - An outline of inspection objectives will inform
facility officials of the purpose and scope of the inspection and may help
avoid misunderstandings.
0 Inspection Agenda - Discussion of the sequence and content of the
inspection including operations and control equipment to be inspected
and their current operating status. This will help eliminate wasted time by
allowing officials time to make any preparations necessary. The types of
measurements to be made and the samples to be collected (if any)
should also be addressed.
0 Facility Information Verification - The inspector should verify or collect the
following information:
Correct name and address of facility
Correct names of plant management and officials
Principal product(s) and production rates
Affected facilities and emission points.
0 List of Records - A list of records (NSPS or permit requirements) to be
inspected will allow officials to gather and make them available to the
inspector.
0 Accompaniment - It is imperative that a facility official accompany the
inspector during the inspection, not only to describe the plant and its
principal operating characteristics, but also to identify confidential data
and for safety and liability considerations.
0 Safety Requirements - The inspector should determine what facility safety
regulations including safety equipment requirements will be involved in
the inspection, and should be prepared to meet these requirements. The
inspector should also inquire about emergency warning signals and
procedures.
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0 Meeting Schedules - A schedule of meetings with key personnel (if
necessary) will allow them to allocate a clear time to spend with the
inspector.
0 Closing Conference - A post-inspection meeting should be scheduled
with the appropriate officials to provide a final opportunity to gather
information, answer questions, and make confidentiality declarations.
0 New Requirements - The inspector should discuss any new rules and
regulations that might affect the facility and answer questions pertaining
to them. If the inspector is aware of proposed rules that might affect the
facility, he or she may wish to encourage facility officials to obtain a copy.
Duplicate Samples and/or Simultaneous Measurements - Facility officials
should be informed of their right to receive a duplicate of any physical
sample collected for laboratory analysis or to conduct simultaneous
measurements such as visible emission observations.
0 Confidentiality Claims - Company officials should be advised of their right
to request confidential treatment of trade secret information.
0 Photographs - If necessary, the inspector should request permission to
take photographs during the inspection.
4.5 Inspection Documentation
The air compliance inspection is generally conducted to achieve one or more of
three main objectives.
1. To provide data and other information for making a compliance
determination.
2. To provide evidentiary support for some type of enforcement action.
3. To gather the data required for other agency functions.
Taking physical samples, reviewing records, and documenting facility operations are
the methods used by the inspector to develop the documentary support required to
accomplish these objectives. The documentation from the inspection establishes the
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actual conditions existing at the time of the inspection so that the evidence of these
conditions may be objectively examined at a later time in the course of an enforcement
proceeding or other compliance related activity.
Documentation is a general term referring to all print and mechanical media
produced, copied, or taken by an inspector to provide evidence of facilities status.
Types of documentation include the field notebook, field notes and checklists, visible
emission observation forms, drawings, flowsheets, maps, lab analyses of samples,
chain of custody records, statements, copies of records, printed matter, and
photographs. Any documentation gathered or produced during the inspection may
eventually become part of an enforcement proceeding. It is the inspector's
responsibility to recognize this possibility and ensure that all documentation can pass
later legal scrutiny.
4.5.1 Inspector's Field Notebook and Field Notes
The core of all documentation relating to an inspection is the inspector's field
notebook or field notes, which provide accurate and inclusive documentation of all field
activities. Even where certain data or other documentation is not actually included in
the notebook or notes, reference should be made in the notebook or notes to the
additional data or documentation such that it is completely identified and it is clear how
it fits into the inspection scheme.
The field notebook and/or notes form the basis for both the inspection report
and the evidence package and should contain only facts and pertinent observations.
Language should be objective, factual, and free of personal feelings or terminology
that might prove inappropriate.
Because the inspector may eventually be called upon to testify in an
enforcement proceeding, or his/her field data may be entered into evidence, it is
imperative that he/she keep detailed records of inspections, investigations, samples
collected, and related inspection functions. The types of information that should be
entered into the field notebook or notes include:
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0 Observations - All conditions, practices, and other observations relevant
to the inspection objectives or that will contribute to valid evidence
should be recorded.
0 Procedures - Inspectors should list or reference all procedures followed
during the inspection such as those for entry, sampling, records
inspection, and document preparation. Such information could help
avoid damage to case proceedings on procedural grounds.
0 Unusual Conditions and Problems - Unusual conditions and problems
should be recorded and described in detail.
0 Documents and Photographs - All documents taken or prepared by the
inspector should be noted and related to specific inspection activities.
(For example, photographs taken should be listed, described, and
related to the subject photographed.)
0 General Information - Names and titles of facility personnel and the
activities they perform should be listed along with other general
information. Pertinent statements made by these people should be
recorded. Information about a facility's recordkeeping procedures may
be useful in later inspections.
4.5.2 Visible Emission Observation Form
Because visible emission (VE) observations are such a frequently used
enforcement tool, a separate form has been developed for recording data from the VE
observation using EPA Method 9 (Figure 4-1). This form has been designed to
include all the supporting documentation necessary, in most cases, for VE observation
data to be accepted as evidence of a violation. Thus, it is recommended that the
inspector use this form for recording opacity observations; an appropriate reference
should be made to the form in the field notebook or notes. In addition, a separate
form is used to record the presence and duration of fugitive emissions from buildings
enclosing NSPS affected facilities. This is the EPA Method 22 Field Data Sheet for
Outdoor Locations (Figure 4-2).
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VISIBLE EMISSION OBSERVATION FORM
No.
COMPANY NAME
STREET ADDRESS
CITY
PHONE (KEY CONTACT)
PROCESS EQUIPMENT
CONTROL EQUIPMENT
DESCRIBE EMISSION POaMT
HEIGHT ABOVE GROUND LEVEL
DISTANCE FROM OBSERVER
Sun End
DESCRIBE EMISSIONS
Sun
EMISSION COLOR
Sun End
POINT IN THE PLUME AT WHICH OPACT
San
DESCRIBE PLUME BACKGROUND
BACKGROUND COLOR
Sun End
WIND SPEED
Sun End
AMBIENT TEMP
Slack SOURCE LAY
with "
Plum*
Sun +
Wind -»-
>
^^
^
SunLoea
ADDITIONAL INFORMATION
STATE Z*>
SOURCE K> NUMBER
OPERATING MODE
OPERATING MODE
HEIGHT. RELATIVE TO OBSERVER
Start End
DIRECTION FROM OBSERVER
Start End
End
f WATER DROPLET PLUME
AlaehadD Oattehad O
fY WAS DETERMINED
End
End
SKY CONDITIONS
Start End
WIND DIRECTION
Start End
WET BULB TEMP RH. p*roM
OUT SKETCH Draw North Arrow
[ EmtoaionPoM
Obaww.Po.a.on
D> ^^^
ion Lin*
OBSEI
N^EC
UIN\
1
2
3
4
t
a
7
6
10
11
12
13
14
IS
17
18
20
21
22
23
24
25
27
26
29
30
OBSEI
OBSEI
ORGA
CONTI
OVATION
0
WER-SK
AVER'S!
NIZATk>
NUEDOI
DATE
IS
IAME(Pf
ilGNATU
1
M VEOF
30
«NT)
RE
ORMNU
START
46
MBER
TME END TIME
COMMENTS
DATE
Figure 4-1. EPA Method 9 Visible Emission Observation Form.
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FUGITIVE OR SMOKE EMISSION INSPECTION
OUTDOOR LOCATION
Company
Location .
Company reprasantativa
ObMivar .
Affiliation
Ottt
Sky Condition*
Precipitation _
Wind diractlon
Wlndspaad
Industry
Procass unit
Skatch procaar unit: indieata obtarvar position ralativa to sourca and tun: Indfeate potamial
•mission points and/or actual amission points.
OBSERVATIONS
Baojn Obsarvation
Clock
time
Obsarvation
pariod
duration.
min:sac
Accumulated
•mission
tima.
min:sac
End observation
Figure 4-2. EPA Method 22 Field Data Sheet for Outdoor Location.
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4.5.3 Drawings and Maps
Schematic drawings, flowsheets, maps, charts, and other graphic records can
be useful as supporting documentation. They can provide graphic clarification of
emission source location relative to the overall facility, relative height and size of
objects, and other information which, in combination with samples, photographs, and
other documentation, can produce an accurate, complete, evidence package.
Drawings and maps should be simple and free of extraneous details. Basic
measurements and compass points should be included, if necessary, to provide a
scale for interpretation.
4.5.4 Copies of Records
A facility's records and files may be stored in a variety of information retrieval
systems, including written or printed materials, computer or electronic systems, or
visual systems such as microfilm and microfiche.
When copies of records are necessary for an inspection report, storage and
retrieval methods must be taken into consideration:
0 Written or printed records can generally be photocopied onsite. Portable
photocopy machines may be available to inspectors through the
Regional Office. When necessary, inspectors are authorized to pay a
facility a "reasonable" price for the use of facility copying equipment. All
copies made for or by the inspector should be initialed and dated for
identification purposes.
0 Computer or electronic records may require the generation of "hard"
copies for inspection purposes. Arrangements should be made during
the opening conference, if possible, for these copies. (Photographs of
computer screens may possibly provide adequate copies of records if
other means are impossible.)
0 Visual systems (microfilm, microfiche) usually have photocopying
capacity built into the viewing machine, which can be used to generate
copies. (Photographs of the viewing screen may provide adequate
copies of records if other means are impossible.)
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Immediate and adequate identification of records reviewed is essential to ensure
the ability to identify records throughout the Agency custody process and to ensure
their admissibility in court. When inspectors are called to testify in court, they must be
able to positively identify each particular document and state its source and the reason
for its collection. Initial, date, number, and record the facility's name on each record,
and reference these items in the field notebook or notes.
0 Initialing/Dating - The inspector should develop a unique system for
initialing and dating records and copies of records so that he/she can
easily verify their validity. This can be done by initialing each document
in a similar position, or by another method, at the time of collection.
Both the original and copy should be initialed. All record identification
notations should be made on the back of the document.
0 Numbering - Each document or set of documents substantiating a
suspected violation or violations should be assigned an identifying
number unique to that document. The number should be recorded on
each document and in the field notebook.
0 Logging - Documents obtained during the inspection should be entered
in the field notebook or notes according to some logical system. The
system should include the following information:
Identifying number
Date
The reason for copying the material
The source of the record
The manner of collection.
4.5.5 Printed Matter
Brochures, literature, labels, and other printed matter may provide important
information regarding a facility's condition and operations. These materials may be
collected as documentation if, in the inspector's judgment, they are relevant. All
printed matter should be identified with the date, inspector's initials, and related
sample numbers. Reference to these materials should be made in the field notebook
or notes.
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4.5.6 Photographs
The documentary value of photographs ranks high as admissible evidence;
clear photos of relevant subjects, taken in proper light and at proper lens settings,
provide an objective record of conditions at the time of inspection. The use of
photographic documentation, however, often elicits a negative reaction from plant
officials, thus, it is recommended that photographic documentation be used only
sparingly and only when necessary to document an inspection finding.
When a situation arises that dictates the use of photographs, the inspector
should obtain the company's permission to take photographs. This is most
conveniently accomplished during the opening conference. The inspector may offer to
provide the official with duplicates of all photographs taken. As with other business
data collected, during and/or at the conclusion of the inspection, the inspector should
ascertain whether any of the photographs taken contain proprietary information and if
the company wishes to designate any as confidential. Photographs taken employing a
Polaroid-type instant camera allow an immediate confidentiality review and the
opportunity for the inspector to readily provide the company with duplicate shots.
Photographs may always be taken form areas of public access (e.g., outside the
fence, from the road, from a parking lot, etc.).
A photographic log should be maintained in the inspector's field notes for all
photographs taken during an inspection, and the entries are to be made at the time
the photograph is taken. These entries are to be numerically identified so that after
the film is developed the prints can be serially numbered corresponding to the log
book descriptions and, if necessary, pertinent information can be easily transferred to
the back of the photograph.
Polaroid-type instant photos should be immediately identified on the back after
shooting with the corresponding photo ID number; photographs that require
developing and printing should be numbered as soon as possible. One
recommendation which will ensure that all prints and negatives can be positively
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identified is that prints and negatives be left uncut and the photographic log be
photographed at the beginning and end of each roll of film. Photographs of a
confidential nature must be developed by an authorized contractor.
4.6 Verification of Facility Records
40 CFR 60, Subpart A and Subpart OOO require that the source maintain a
permanent file of required notifications, reports, measurements, and records for review
by the Administrator or authorized representative. Pursuant to §60.7(d) of Subpart A,
this permanent file is to be retained by the source for at least two years. Integral to
the compliance inspection, these notifications and records must be verified by the
inspector.
A complete records check should be accomplished before the inspector leaves
the plant. However, §60.7(d) does not specify that the owner or operator must locate
this permanent file at the facility to be inspected. If required records are located
elsewhere (main or central corporate office), provisions should be made for the
records to be made available during the inspection. This is best accomplished during
the inspection notification to the facility. If the inspection is unannounced, the
inspector should make definite arrangements with the source during the opening
conference to have the records made available on specified dates.
The following is a list of records required to be kept by the owner or operator of
the source under the provisions of the nonmetallic mineral processing NSPS. Each
item on the list is accompanied by its regulatory citation.
Written Notifications to the Administrator
1. The date of construction or reconstruction of any affected facility -
§60.7(a)(1).
2. The date of anticipated startup of any affected facility - §60.7(a) (2).
3. The date of actual startup of any affected facility - §60.7(a)(3).
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4. Any physical or operational change to an existing facility which may
increase the emissions rate of any air pollutant to which a standard
applies, unless that change is specifically exempted under an applicable
subpart or in §60.14(e).
§60.14(e) exemptions:
0 Routine maintenance, repair and replacement within
the IRS annual asset guideline repair allowance
An increase in production rate of an existing facility
without a capital expense on that facility
0 An increase in the hours of operation
0 Use of an alternative fuel or raw material if the
existing facility was designed to accommodate same
before August 31, 1983
0 The addition or use of any air pollution control device
or system except when such a device or system is
removed or replaced by a system which is less
environmentally beneficial
0 Relocation or change in ownership of an existing
facility.
5. The date that initial performance test opacity observations are anticipated
- §60.7(a)(6).
6. Rescheduled dates for initial performance test opacity observations if
visibility or other conditions prevent opacity observations from being
performed concurrently with the initial performance test - §60.11(e)(1).
7. Proposed "reconstructions" of existing facilities - §60.15(d) (See §60.15(d)
for information required in the notification).
8. 30 day advance notification of any performance test of an affected facility
- §60.8(d).
9. Proposed replacements of existing facilities with facilities of equal or
smaller size - §60.676(a) (See §60.676(a) for information required in the
notification).
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Written Reports to the Administrator
1. Initial performance test results of all affected facilities - §60.8(a).
2. Initial performance test opacity results of all affected facilities -
§60.11 (e)(2).
3. The results of all performance tests of affected facilities to demonstrate
compliance including opacity observation results (Method 9) and/or
Method 22 observation results - §60.676(f).
4. Semiannual reports of occurrences when scrubber pressure drop and
liquid flow rate differ from the average of the last performance test by
±30 percent - §60.676(d).
Records On File
1. Startup, shutdown, and malfunction occurrences and their durations for
all affected facilities; malfunctions of air pollution control equipment
serving affected facilities; and any periods during which continuous
monitoring systems or monitoring devices (i.e., scrubber pressure drop
and liquid flow rate measurement devices) are inoperative - §60.7(b).
2. All measurements of monitoring devices, calibration checks, and all
adjustments and maintenance performed on these devices - §60.7(d).
To include:
0 Daily continuous measurements of scrubber pressure
drop and liquid flow rate - §60.676(c)
0 Scrubber monitoring device annual calibration checks
- §60.674.
It should be remembered that §60.7(d) of Subpart A requires the owner or
operator of the affected facility to maintain these notifications, reports, records, and
measurements for at least two years. Therefore, the inspector should be familiar with
the chronological history of the affected facilities to determine whether the records of
the owner or operator are current and acceptable. Accurate agency files and tracking
of affected facilities, their dates of construction, and dates of performance tests are
vital for a complete and accurate check of source records.
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4.7 Means of Determining Compliance with the Standard for Paniculate
Matter
The standard for paniculate matter for the nonmetallic mineral processing NSPS
is found in §60.672 and includes a mass emission limit of 0.5 g/dscm (0.02 gr/dscf)
for point sources (i.e., stacks and powered vents) and a point source opacity limit of 7
percent, as well as an opacity limit of 10 percent for all fugitive emission sources
except 15 percent for crushers without capture systems (see definition of "capture
system" in Section 3.2). It should be noted that wet suppression is not considered a
capture system. In addition, §60.672(e) limits emissions from affected facilities
enclosed in buildings to 10 or 15 percent opacity as applicable, or limits the building to
no visible emissions.
Determining compliance of each affected facility and/or emission point may
therefore involve visible emission observations using EPA Method 9 or Method 22 as
applicable (Sections 3.6.3 and 3.6.4). In the case of wet scrubbers, a compliance
determination with the monitoring provisions of §60.674 necessarily involves checking
scrubber pressure drop and liquid flow rate data from the continuous monitoring
devices.
Although the only way to determine the compliance status of stacks or powered
vents with the mass emission limit is a stack test, surrogate indicators of compliance
may be used by the inspector to make logical decisions based on engineering
principals as to the likelihood of compliance. Use of surrogate indicators of
compliance is not appropriate for the initial performance test or any other compliance
determination requiring a stack test, but can be used as an indicator of compliance
during inspections. Such surrogate indicators of compliance may include significant
variations in process variables or pollution control equipment variables that are outside
of the range recorded during the most recent compliance test or outside of the range
of good engineering practice (e.g., broken or inoperable baghouse cleaning systems;
bypassed or isolated sections of capture systems; increased process rates of
nonaffected sources co-vented to APC equipment serving NSPS affected facilities,
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etc.). If these surrogate indicators of compliance strongly suggest that the source is
not in compliance with the mass emission limit, a stack test should be required under
the same or similar operating conditions unless it is determined that the operating
conditions constituted a startup, shutdown or malfunction event.
4.7.1 Determining Compliance with Opacity During the Inspection
While §60.11(b) of Subpart A requires a minimum time of observation using EPA
Method 9 of 3 hours (thirty 6-minute averages) to determine compliance with the
NSPS opacity limits for the initial performance test, the inspector is not required to
duplicate these visible emission observation requirements during a compliance
inspection. In the case of affected facilities enclosed in buildings, §60.675(d) of
Subpart OOO similarly requires a minimum observation time using EPA Method 22 of
75 minutes (15 minutes per side and top) during the initial performance test. As with
EPA Method 9, the inspector is not required to duplicate this requirement during a
compliance inspection.
The following are acceptable guidelines that may be used for performing EPA
Method 9 or Method 22 observations during a compliance inspection:
0 Continuous operating/emitting sources - Minimum observation time using
EPA Method 9 should be 18 minutes (three 6-minute observation sets).
When using EPA Method 22 for buildings, minimum observation time
should be 20 minutes (5 minutes per side and top).
0 Intermittent operating/emitting sources - Intermittent sources should be
observed for at least two or three cycles of operation. Observations
should end at the end of the process cycle and noted on the visible
emission observation form. Observations should be continued when the
next cycle begins. A least two 6-minute observation sets should be
recorded.
0 Affected facilities inside buildings - If affected facilities are enclosed in
buildings and the inspector has determined through EPA Method 22 that
fugitive emissions are emitted from the building, the following are
acceptable minor changes to the reference method pursuant to §60.8(b)
for applying EPA Method 9 inside the building:
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1. Assume a position at least 4.57 meters (15 ft) from the source of
emissions.
2. Without available and proper sunlight, use portable directional
lights positioned within the 140° sector to the observer's back.
3. If background color is sufficiently similar to emission color, artificial
backgrounds are permissible to promote color and luminescence
contrast.
0 Unaccessible affected facilities inside buildings - If affected facilities alone,
or existing and affected facilities are enclosed in buildings and the
inspector, after a positive EPA Method 22 reading, cannot gain building
access to perform EPA Method 9 observations, Method 9 observations
may be performed on the entire building. Because the inspector cannot
confirm individual facility opacities from inside the building, the most
restrictive opacity limit is applicable for the entire building (see Appendix
H, memorandum from John S. Seitz to Winston A. Smith, not dated).
0 Wet processes - If, in the opinion of the inspector, the process material
moisture content is sufficiently high to prevent the airborne suspension of
paniculate matter, or if the process material is wetted to the same extent,
or immersed in water, visible emission observations are not necessary
and the affected facility can be considered in compliance with the
standard.
It should be noted that EPA policy is to allow no measurement error allowance
for conducting EPA Method 9. Thus, EPA policy prohibits dropping from
consideration marginal opacity exceedances solely because of possible reader
measurement error (see Appendix H, memorandum from John S. Seitz to Roger O.
Pfaff, March 3, 1989).
The preferred approach for accounting for measurement error is to follow the
procedures for conducting Method 9 observations described in the "Quality Assurance
Handbook for Air Pollution Measurement Systems" (EPA-600/4-77-027b, 1977) and to
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conduct followup investigation whenever opacity exceedances are observed. The
Method 9 guidance materials suggest various ways to augment the visible emission
observation if opacity values are in excess of the standard.
For example, in marginal violation situation, additional sets of readings over
longer time periods or even on different days may be appropriate for ensuring that the
opacity exceedances documented truly reflect noncompliance. Finally, enforcement
officials must exercise their technical judgement carefully in the final determination of
an enforceable violation, which may be based on additional factors such as the plant
operating history and extent and duration of excessive emissions.
4.7.2 Determining Compliance with Opacity During the Initial Performance Test
The observation duration requirements for determining compliance with the
performance test opacity standards of §60.672 are found in §60.11 (b) of Subpart A
(i.e., 3 hours of observations per affected facility or emission point). This requirement
can only be changed pursuant to §60.8(b) which allows the Administrator to 1) specify
or approve, in specific cases, the use of a reference method with minor changes in
methodology, 2) approve the use of an alternative method the results of which he has
determined to be adequate for indicating compliance, 3) approve the use of an
equivalent method, 4) waive the requirement for a performance test because the
owner or operator has demonstrated to the Administrator's satisfaction that the
affected facility is in compliance with the standard, or 5) approve shorter sampling
times and smaller sample volumes when necessitated by process variables or other
factors.
Any and all requests for changes in the performance test requirements pursuant
to §60.8(b) must be submitted to the appropriate EPA Regional Office. Requests
include those from the owner or operator of an affected facility and from States,
whether or not the State has received from EPA delegated authority for 40 CFR 60,
Subparts A or OOO or both.
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4.8 Field Inspection Procedures for Affected Facilities
The field inspection procedures herein include those tasks to be performed in
determining the compliance status of affected facilities with the NSPS standard for
particulate matter (§60.672) and, if applicable, the provisions for monitoring of wet
scrubber operations (§60.674).
As was discussed in Section 2, it is usually best to start the inspection at the
beginning of the facility process operations and end the inspection at the finished
product loading station(s). If, however, from pre-entry observations the inspector has
discovered possible violations at specific plant areas (e.g., excessive stack opacity or
fugitive emissions) it is usually best to begin the field inspection at these areas to
document any violations in a timely manner.
To aid the inspector in keeping track of the number and type of affected
facilities at the source and the opacity and mass emission limits applicable to each
affected facility, a master list containing this information should be carried into the field.
Appendix E contains a sample form that can be used for this purpose. In addition to
affected facilities, existing facilities should be included as potentially affected facilities in
the master list. With this information, the inspector can verify that existing facilities
have not been replaced with new facilities that have not yet been permitted under the
NSPS provisions or modified in such a way as to increase emissions.
In addition to the master list of potentially affected and affected facilities,
Appendix E includes a Field Inspection Sheet that may be used to document
compliance data for individual affected facilities. The Field Inspection Sheet includes
the specific items to be inspected and serves as compliance documentation for
individual affected facilities and emission points.
Finally, Appendix E contains an example Initial Performance Test Field Sheet for
affected facilities. Similar to the Field Inspection Sheet, this form includes space to
illustrate the applicable affected facility or transfer point. The Initial Performance Test
Field Sheet may subsequently be used as a file reference document to be reviewed as
necessary before future inspections.
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The following inspection techniques are specific to individual affected facilities
(e.g., crushers, bagging operations, enclosed truck or railcar loading stations, etc.)
and individual ARC systems (e.g., wet scrubbers, baghouses, wet suppression, etc.).
4.8.1 Crushers
Fugitive emissions from crushers are most apparent at crusher feed and
discharge points. Care must be taken to separate fugitive emission opacity from water
mists generated by wet suppression systems. The inspector should position
himself/herself at least 4.57 meters (15 ft) from the emission source and in
accordance with the provisions of EPA Method 9. Both the crusher inlet and
discharge outlet should be observed. Previously, there has been some confusion as
to whether emissions at the crusher discharge onto a belt conveyor should be
considered crusher emissions or belt conveyor transfer point emissions. For the
purposes of determining compliance with the provisions of Subpart OOO, these
emissions should be considered as crusher emissions. Therefore, if a crusher is an
affected facility and the crusher is not served by a capture system, emissions at both
the inlet and discharge of the crusher are limited to 15 percent opacity. Crusher
discharge emissions onto a belt conveyor that is also an affected facility are not
considered belt conveyor transfer point emissions which are limited to 10 percent
opacity. Figure 4-3 shows excessive fugitive emissions from the discharge of a
primary jaw crusher.
The inspector must exercise caution when observing crusher emissions,
especially at the crusher feed inlet, due to the possibility of ore fragments being
violently ejected from the crusher. Figures 4-4 and 4-5 show the inlets of two
secondary cone crushers with and without skirting, respectively. Note the waterspray
supply hose around the diameter of the crusher casing in Figure 4-4. The inspector
should also maintain a safe distance from any mobile equipment hauling ore to or
from the crusher.
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Figure 4-3. Fugitive emissions from a jaw crusher.
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—,-rrtl
Figure 4-4. Feed inlet of cone crusher with feed skirts.
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Figure 4-5. Open feed inlet of cone crusher.
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In distinguishing whether a crusher (or any other equipment) is portable or fixed
as it applies to the exemption provisions of §60.670(c), the equipment must be
mounted on a movable chassis or skid and must not be attached to any anchor slab,
or structure by any means other than electric cabling. Figure 4-6 shows a portable
primary crusher mounted on a wheeled chassis.
4.8.2 Grinding Mills
As with crushers, fugitive emissions are generated at the grinder's inlet and
outlet with the majority of emissions at the outlet after reduction of raw material (i.e.,
more fines). Because the definition of grinding mill found in §60.671 includes the air
conveying system, air separator, or air classifier, the inspector should also inspect the
entire length of these systems for any fugitive emissions as well as the emission points
for mill sweep air. Both closed-loop and open-circuit systems are common. In the
closed-loop system, dryer flue gases may be added to the mill sweep air and an
equivalent amount of air bled from the system to discharge moisture. In an open-
circuit system, the dryer gases and/or mill sweep air are not recirculated. Typically,
these types of systems use roller or ball type mills.
Normally, when an affected facility is vented to the same ARC equipment and
stack as nonaffected facilities, the emission point is subject to the NSPS standard. In
such cases, performance tests of the affected facility are conducted while the
nonaffected facilities are not operating. When dryer flue gases are vented to the
sweep air of an affected facility grinding mill, however, the dryer usually cannot be shut
down during a performance test. Dryer heat is normally required to prevent the
material being reduced from clogging the grinding mill. For these types of situations it
is acceptable to prorate emissions between the dryer and the grinding mill using the
following equation:
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Figure 4-6. Portable jaw crusher.
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0.5 x
000
P x
where Ep = Prorated emission standard, g/dscm
0.05 = Subpart OOO emission standard, g/dscm
(QSTD)OOO = Volumetric flow rate from Subpart OOO source(s), dscfm
(QSTD)T = (QsioJoop + (QSTD)D = total volumetric flow rate, dscfm
)D = volumetric flow rate from dryer, dscfm
p = Dryer emission standard, g/dscm.
This prorating process requires measurement of both the volumetric flow rate from the
dryer and from the Subpart OOO source (mill). In addition, the test protocol must
include dryer firing rates that are commensurate with representative operating
conditions.
4.8.3 Screening Operations
Affected facility screens may be controlled for fugitive emissions by wet
suppression systems or with hooded capture systems. Figure 4-7 shows a vibrating
deck-type screen releasing excessive fugitive emissions (uncontrolled). Opacity
observations should be made at the point of maximum opacity in the plume.
Hooded screens should be checked for signs of ill-fitting seals or gaps in hood
integrity. Figure 4-8 illustrates a hooded screen with a capture system off-take at the
top of the screen. Note that the cleanout of the evacuation system pipe at the top of
the off-take is open allowing fugitive dust to escape.
If the screen is not operating during the inspection, the inspector should observe
the immediate area of the screen for signs of excess emissions during operation.
Dust buildup is not presumptive evidence of noncompliance since the time for the dust
accumulation is likely to be unknown. However, excessive dust buildup may indicate
that the nonoperating affected facility should be reinspected when operating. Figure 4-
9 shows a considerable dust buildup on the capture system hood and the walls of the
enclosing building around a nonoperating screen.
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Figure 4-7. Deck-type screen with fugitive emissions.
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Figure 4-8. Screen hood showing open cleanout emitting fugitive dust.
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Figure 4-9. Enclosed screen hood showing external fugitive dust buildup.
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4.8.4 Storage Bins
Venting of storage bins during loading or unloading constitutes the emission
potential for these affected facilities. Vents may be controlled or uncontrolled. Typical
ARC equipment involves cyclones, baghouses or wet suppression.
The inspector should observe the vent discharge points during at least one cycle
(loading or unloading). In addition, the inspector should observe the area around the
vent. Accumulations of dust indicate releases of particulate matter. Absence of
opacity does not necessarily equate with no particulate emissions. Large diameter
particles which do not readily scatter light can be emitted in significant mass without
appreciable opacity. Because these large and heavier particles will fallout quickly,
heavy deposits close to the point of emissions may be readily apparent.
4.8.5 Bucket Elevators
Bucket elevators are normally controlled by a capture system at the top of the
elevator at the point of bucket discharge. Fugitive dust is pneumatically conveyed to
an ARC system, usually a baghouse. The inspector should observe the entire length
of the elevator enclosure. If emissions are present, they are usually emitted at the
capture system atop the elevator as in Figure 4-10, or at the access door(s) to the
elevator interior which may be opened to allow for infiltration of makeup air.
4.8.6 Belt Conveyors
Subpart OOO applies only to transfer points to and from affected facility belt
conveyors except transfer points to storage piles. Although wet suppression is the
most frequently used method for emission control, hooding, capture, and conveying to
a control device are also used. Figure 4-11 shows a belt-to-belt transfer point without
controls. If the moisture content of the material being transferred is sufficient to
prevent the material from becoming airborne, visible emission observation can be
waived for determining compliance during the inspection. Belt conveyor transfer
points after process drying are more likely to result in airborne emissions and are
normally controlled with hooded capture systems as illustrated in Figure 4-12.
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Figure 4-10. Bucket elevator with fugitive emissions.
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Figure 4-11. Uncontrolled belt-to-belt transfer point.
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Figure 4-12. Belt-to-belt transfer point with capture hood.
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As with other affected facilities, nonoperating belt conveyors should be examined
at transfer points for evidence of excessive emissions (heavy dusting). Visible
emission observations should be scheduled during operation of the affected facility.
4.8.7 Bagging Operations
Fugitive emissions from bagging operations are generally localized in the area of
the bagging machine(s). Bagging operations are almost always enclosed in buildings
to protect these operations from the weather. In such cases, the inspector may
perform EPA Method 22 observations of the building. If Method 22 observations are
positive for visible emissions, the inspector should perform EPA Method 9
observations of the affected facilities inside of the building. If powered vents are
employed, Method 9 observations of the vent(s) should be made.
4.8.8 Enclosed Truck or Railcar Loading Operations
As with storage bins, truck and railcar loading is an intermittent operation. Visible
emission observations should be made during at least one cycle of operation.
The inspector should completely understand the definition of an enclosed truck or
railcar loading station, which requires that both the conveying system as well as the
truck or railcar be enclosed. Figure 4-13 is an example of a nonenclosed truck
loading station. This type of facility is not covered by the nonmetallic mineral
processing NSPS. Figure 4-14, however, illustrates one type of enclosed station
subject to the NSPS. Note the enclosed feed tube and the three air vents on the
dome of the enclosed railcar. Also note the fugitive emissions from the loading
operation approaching 100 percent opacity immediately above the transfer point.
Figure 4-15 illustrates another type of enclosed truck loading station showing
some visible emissions as the air is displaced from the truck. In this case, loadout
emissions are not controlled because the evacuation system is not connected to the
off-take port at the base of the flexible feed tube (small black square at the top of the
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Figure 4-13. Nonenclosed truck loading station.
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Figure 4-14. Enclosed railcar loading station with fugitive emissions.
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Figure 4-15. Enclosed truck loading station with flexible feed tube.
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4.9 Field Inspection Procedures for Air Pollution Control Equipment
The following are Level II inspection procedures for APC systems typically found
at nonmetallic mineral processing facilities.
4.9.1 Operating Pulse Jet Baghouses
Inspection Steps
0 Method 9 observation of fabric filter discharge
0 Method 9 observation of fugitive emissions from solids handling operation (if
reentrainment is occurring)
0 Method 9 observation of fugitive emissions from process equipment
° Counterflow checks of audible air infiltration into fan, baghouse (solids
discharge valve, access doors, shell), and ductwork; check physical
condition and location of hoods
0 Check static pressure drop across baghouse using onsite gauge; compare
with baseline data
0 Compare compressed air pressures at reservoir with baseline values; check
for audible leaks of compressed air at fittings; check operation of diaphragm
valves, record number of valves that do not appear to be working properly
0 Check inlet gas temperatures using onsite gauge
0 Observe and describe corrosion of fabric filter shell and hoppers
0 Evaluate bag failure records, gas inlet temperature records, pressure drop
data, and other maintenance information.
Evaluation
Visible emissions greater than the standard (7 percent opacity) indicate poor
performance; inspection should include: evaluation of bag problems,
including but not limited to abrasion, chemical attack, high temperature
damage, and improper cleaning; if conditions appear to be severe, a Level
III inspection (primary clean side checks) is recommended
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Fugitive emissions from all process sources should be carefully
documented; reasons for poor capture should be investigated, and include
air infiltration, poor hood condition or location, fan belt slippage (listen for
squeal), fabric blinding, and poor cleaning effectiveness
0 Static pressure drop data and cleaning system performance checks
(compressed air pressures, conditions of diaphragm valves, and frequency
of cleaning) are very important
0 Check of the entire system for air infiltration is very important, because it can
lead to severe problems.
Safety Considerations
0 Level II inspection involves some climbing and close contact with the pulse
jet baghouse; check the integrity of all supports and ladders; climb ladders
properly; avoid contact with hot ducts and roofs; avoid downward point gas
discharge
0 Because the inspector must enter the facility to conduct a Level II inspection,
all facility and agency safety precautions apply.
4.9.2 Operating Shaker and Reverse Air Baghouses
Inspection Steps
° Method 9 observation of fabric filter stack or individual compartment
discharge points
0 Method 9 observation of fugitive emissions from solids handling operation (if
reentrainment is occurring)
Method 9 observation of fugitive emissions from process equipment
0 Counterflow checks of audible air infiltration into fan, baghouse (solids
discharge valve, access doors, shell), and ductwork; check physical
condition and location of hoods
Check static pressure drop across collector using onsite gauges
0 Check static pressure drop across each compartment during cleaning;
values should be zero for shaker collectors
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Confirm that reverse air fan or shaker motor is operating
Check inlet gas temperatures using onsite gauges
Observe and describe corrosion of fabric filter shell and hoppers
Evaluate bag failure records, gas inlet temperature records, pressure drop
data, and other records.
Evaluation
0 Visible emissions >5 percent indicate poor performance; inspections should
include: evaluation of bag problems, including abrasion, chemical attack,
high temperature damage, and excessive cleaning intensities; if conditions
appear severe, a Level III inspection is recommended
0 Fugitive emissions from all process sources should be carefully documented
0 Static pressure drop data and cleaning system performance checks
(compartment static pressure drops during cleaning, operation of reverse air
fan) are very useful for determining if the problem is due to the unit
0 Counterflow inspection of the entire system for air infiltration is very
important because it can gradually lead to severe bag damage, and reduced
capture effectiveness at the process.
Safety Considerations
0 Level II inspection involves some climbing and close contact with the unit;
check the integrity of all supports and ladders; climb ladders properly; avoid
contact with hot ducts and roofs; avoid poorly ventilated areas under
hoppers and between compartments
0 All plant and agency safety procedures for onsite inspections apply.
4.9.3 Nonoperating Pulse Jet Baghouses
Inspection Steps
0 Confirm that unit is out-of-service and will not be brought on line during
period of inspection
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0 Request plant personnel to open one or more access hatches on the clean
side of unit; evaluate quantity and pattern of clean side deposits
0 Check orientation of blow tubes (and extension nipples, if present)
Check for obvious poorly seated bags and gaps in tube sheet welds
0 Request that plant personnel open side access hatches if available
0 Check for bag abrasion against side flanges, internal walkways, and other
bags; check for bowed and bent bag/cage assemblies
0 Check the condition of any deflector plates on the gas inlet
0 Check for obvious erosion of ductwork leading to baghouse
0 Check operation of bag cleaning equipment.
Evaluation
0 Presence of clean side deposits (enough to make a footprint) indicates poor
performance; inspection should include an evaluation of bag failure problems
due to abrasion, excessive cleaning intensities, improper blow tube
alignment, chemical attack, and high temperature damage; potential for
leakage around top of bag and tube sheet should also be checked
0 Potential for bag-to-bag abrasion at bottom and for damage of the fabric
against side flanges and internal walkways can be seen from side access
hatches
0 Deflector serves to protect the bags from abrasive materials
0 Erosion of these plates could contribute to premature failures; eroded
ductwork could lead to reduced pollutant capture at the generation source
and operating temperatures below the acid dewpoint for combustion
sources.
Safety Considerations
0 Hatches located on hoppers should never be opened during an inspection
because there is often dangerous accumulations of hot, free flowing solids
behind the door
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0 Inspector should never stick his or her head into the clean air plenum
because this poorly ventilated area may contain asphyxiants and/or toxic
gases
0 All hatches must be opened carefully to prevent hand injuries.
Special Notes
0 Presence of clean side deposits or other abnormal conditions cannot be
used alone as a basis for a Notice of Violation (NOV)
0 Baghouses should be opened only with consent of plant management
personnel.
4.9.4 Nonoperating Shaker and Reverse Air Baghouses
Inspection Steps
0 Confirm that unit or individual compartment is out-of-service and will not be
brought on line during period of inspection
0 Request that plant personnel open access hatch of compartments isolated;
use the hatch just above the elevation of the tube sheet; evaluate quantity
and pattern of clean side deposits
0 Observe bag tension throughout the portion of the compartment that is
visible from access hatch; check tension of bags that can be reached
without entering compartment
0 Check for leaks around thimble connections or snap ring connections
0 Check for obvious bag abrasion on internal flanges
Check for obvious tube sheet weld failures
0 Note any holes or tears in bags visible from access hatch.
Evaluation
0 Presence of clean side deposits (enough to make a footprint) indicates poor
performance; inspection should include an evaluation of bag failure problems
due to abrasion, excessive cleaning intensities, chemical attack, and high
temperature attack
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Bag tension is critical; in both reverse air and shaker collectors bags must
not sag at bottom; the reverse air bags are kept under 40 to 120 pounds
tension; shaker bags are normally hung with no measurable tension
Spatial pattern of clean side deposits can be used to indicate dust emission
problems; however, once deposits exceed several inches in depth,
diagnostic signs are essentially buried
Gaps in tube sheet welds are usually visible because the high velocity gas
stream passing through gap moves the dust deposits away from that portion
of tube sheet.
Safety Considerations
Hatches located on hoppers should never be opened during inspection
because there is often dangerous accumulations of hot, free flowing solids
behind door
Side access hatches for each compartment should also be opened carefully
because hot clean side deposits ranging from several inches to several feet
in depth may be behind door
Under no circumstances should inspector enter the compartment
Even compartments properly isolated may have high concentrations of toxic
gases, toxic particulate, and asphyxiants; the gas temperature inside can be
quite hot due to radiation and conduction from adjacent compartments still
operating
Respirators should be worn whenever observing conditions through an open
hatch.
Special Notes
Presence of clean side deposits or other abnormal conditions cannot be
used alone as a basis for a NOV
Unit should be opened only with consent of plant management.
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4.9.5 Spray Tower Scrubbers
Inspection Steps
0 Method 9 observation of stack for a period of not less than 6 minutes;
calculate average opacity and describe cycles in the average opacity
0 Method 9 observation of all bypass stacks and vents and any fugitive
emissions from process equipment
0 Presence of rainout close to the stack or mud lips at the discharge point
0 Presence of fan vibration
0 Liquor flow rate and pressure drop indicated by onsite monitors (compare
wih average of last compliance test)
Pump discharge pressure and motor current indicated by onsite gauges
0 Audible pump cavitation
0 Nozzle header pressure indicated by onsite gauge
0 Physical condition of shell and ductwork
0 Recirculation pond layout and pump intake position
0 Physical condition of nozzles observed through access hatch
0 Note means used to dispose of purged liquor.
Evaluation
0 A shift in the average opacity may be due to a decrease in the particle size
distribution of the inlet gas stream; a co-current inspection of the process
operation is often advisable
0 Anything that affects the nozzles will reduce performance; liquor turbidity is
related to the vulnerability to nozzle pluggage and erosion
0 Shell and ductwork corrosion is often caused by operation at pH levels that
are lower than desirable; measure the liquor pH using in-plant instruments, if
available
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0 Performance of a spray tower scrubber is dependent on the liquor flow rate;
any problems that potentially reduce the flow rate should be fully examined.
Safety Considerations
0 Check all ladders and platforms before use; safe climbing and walking
practices are important, especially in cold weather
0 Avoid poorly ventilated areas
0 Avoid hot duct and pipes
0 Terminate inspection if a severely vibrating fan is noted in the vicinity of the
scrubber
0 Under no circumstances should inspector attempt to look inside an
operating wet scrubber
0 Visible emission observations should be made only in secure areas.
Special Notes
0 Observations and data do not provide conclusive evidence of
noncompliance with mass emission standards (requires stack test); these
can be used only as surrogate indicators of compliance.
4.9.6 Mechanically Aided Scrubbers
Inspection Steps
0 Method 9 observation of the stack for a period of not less than 6 minutes;
calculate average opacity
0 Method 9 observation of all bypass stacks and vents and any fugitive
emissions from process equipment
0 Presence of rainout close to the stack or mud lips at the discharge point
0 Presence of fan vibration
0 Pump discharge pressure and motor current indicated by onsite gauges
0 Audible pump cavitation
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Nozzle header pressure indicated by onsite gauge
Physical condition of shell and ductwork
Recirculation pond layout and pump intake position
Note means used to dispose of purged liquor
Static pressure increase across scrubber and liquor flow rate monitored by
onsite gauges (compare with average of last compliance test).
Evaluation
Shift in the average opacity may be due to a decrease in the particle size
distribution of the inlet gas stream; a co-current inspection of the process
operation is often advisable
Liquor turbidity is related to the vulnerability of the fan blades to erosion
damage
Shell and ductwork corrosion is often caused by operation at pH levels
which are lower than desirable; measure liquor pH using in-plant
instruments, if available
Performance of a mechanically aided scrubber is dependent on liquor flow
rate; any problems which potentially reduce the flow rate should be fully
examined; indirect indications of liquor flow rate include pump discharge
pressure, nozzle header pressure, pump motor currents, and audible pump
cavitation.
Safety Considerations
Check all ladders and platforms before use; safe climbing and walking
practices are important at all times
Avoid poorly ventilated areas
Avoid hot ducts and pipes
Terminate inspection if the fan is vibrating severely
under no circumstances should inspector attempt to look inside an
operating wet scrubber
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0 Visible emission observations should be made only in secure areas.
Special Notes
0 Inspection data and observations do not provide conclusive evidence of
violation of mass emission standards (requires stack test); these can be
used only as surrogate indicators of compliance.
4.9.7 Gas-Atomized Scrubbers
Inspection Steps
0 Method 9 observation of stack for a period of not less than 6 minutes;
calculate average opacity
0 Method 9 observation of all bypass stacks and vents and any fugitive
emissions from process equipment
0 Presence of rainout close to the stack or mud lips at the discharge
0 Presence of fan vibration
Static pressure drop across the scrubber and liquor flow rate indicated by
onsite gauges (compare with average of last compliance test)
0 Pump discharge pressure and motor current indicated by onsite gauges
0 Audible pump cavitation
0 Nozzle header pressure indicated by onsite gauge
0 Physical condition of shell and ductwork
0 Recirculation pond layout and pump intake position
0 Physical condition of nozzles observed through access hatch
0 Means used to dispose of purged liquor should be noted.
Evaluation
0 Shift in the average opacity may be due to a decrease in particle size
distribution of the inlet gas stream; a co-current inspection of the process
operation is often advisable
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0 Anything which affects the nozzles will reduce performance; liquor turbidity is
related to the vulnerability to nozzle pluggage and erosion
0 Shell and ductwork corrosion is often caused by operation at pH levels
which are lower than desirable; measure liquor pH using in-plant
instruments, if available
0 Performance of a gas-atomized scrubber is partially dependent on the liquor
flow rate; any problems which potentially reduce the flow rate should be fully
examined
0 Overall performance of a gas-atomized wet scrubber is related to the static
pressure drop except in cases where there is a particle size shift, a change
in the liquor surface tension, or gas-liquor maldistribution problems.
Safety Considerations
0 Check all ladders and platforms before use; safe climbing and walking
practices are important at all times
0 Avoid poorly ventilated areas
0 Avoid hot ducts and pipes
0 Terminate inspection if a severely vibrating fan is noted in the general vicinity
of the scrubber
0 Under no circumstances should inspector attempt to look inside an
operating wet scrubber
0 Visible emission observations should be made only in secure areas.
Special Notes
0 Inspection data and observations do not provide conclusive evidence of
violation of mass emission standards (requires stack test); these can be
used only as surrogate indicators of compliance
4.9.8 Large Diameter Cyclones
Inspection Steps
0 Method 9 observation of stack for a sufficient period to fully characterize
conditions during normal process cycles
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0 Method 9 observation of any fugitive emissions from process equipment,
and material handling operations
0 Presence of accumulated dust in the vicinity of the stack
0 Presence of obvious holes and dents in cyclone shell
0 Air infiltration sites on cyclone shell, cyclone hopper, solids discharge valve,
and inlet ductwork
0 Obvious corrosion of cyclone
° Static pressure drop across the cyclone as indicated by onsite gauge.
Evaluation
0 If the visible emissions have increased more than 5 percent since the
baseline period or if the visible emissions are within 5 percent of the
regulatory limit, a more detailed inspection is recommended
0 Accumulated solids near the stack generally imply high mass emissions
composed of large particles which do not scatter light effectively
0 Fugitive emissions from the process area can be at least partially due to air
infiltration into ductwork or collector; check process area and ductwork
0 Holes and dents in shell can disrupt the gas vortex, causing some
particulate reentrainment and emissions
0 Static pressure provides an indication of the flow rate; removal efficiency
generally increases with the static pressure.
Safety Considerations
0 Positions selected for the Method 9 observations should be secure from
moving vehicles such as cars, trains, and moving machinery
0 Footing must be secure; stockpiles are not acceptable
0 All climbing and walking safety procedures are very important; some
horizontal structures may not be able to withstand the load of accumulated
solids and several people
0 Avoid contact with hot surfaces
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0 Some fugitive leaks from the cyclone body and the cyclone discharge vents
may contain high velocity materials which could cause eye injuries; avoid
potential areas of exposure.
Special Notes
0 Inspection data and observations do not provide conclusive evidence of
violation of mass emission standards (requires stack test); these can be
used only as surrogate indicators of compliance.
4.9.9 Multiple Cyclone Collectors
Inspection Steps
0 Method 9 observation of stack for a sufficient period to fully characterize
conditions during normal process cycles
0 Method 9 observation of any fugitive emissions from process equipment,
and material handling operations
0 Air infiltration sites on collector shell, hopper, solids discharge valve, and
inlet ductwork
0 Static pressure drop across collector as indicated by onsite gauge
0 Inlet gas temperature as indicated by onsite gauge.
Evaluation
0 If the visible emissions have increased more than 5 percent since the
baseline period or if the visible emissions are within 5 percent of the
regulatory limit, a more detailed inspection is recommended
0 Fugitive emissions from the process area can be at least partially due to air
infiltration into ductwork or collector; check process area and ductwork
0 Static pressure provides an indication of the flow rate and the resistance to
gas flow; static pressure should be checked against baseline static pressure
drops for similar process operating rates; if the present value is higher, then
pluggage is possible; if it is lower, erosion of outlet tubes and gasket
problems are likely.
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Safety Considerations
0 Positions selected for the Method 9 observations should be secure from
moving vehicles such as cars, trains, and moving machinery
0 Footing must be secure; stockpiles are not acceptable
0 All climbing and walking safety procedures are very important; some
horizontal structures may not be able to withstand the load of accumulated
solids and several people
0 Avoid contact with hot surfaces
0 Many multicyclone collectors are located in hot areas; avoid heat stress by
limiting the time spent in the area (moderate heat conditions) or by not
entering the area (high heat areas)
Special Notes
° Inspection data and observations do not provide conclusive evidence of
violation of mass emission standards (requires stack test); these can be
used only as surrogate indicators of compliance.
4.9.10 Wet Suppression Systems
Inspection Steps
0 Check the condition of spray nozzles and spray patterns
0 Check nozzle header pressure with baseline data or last compliance test
0 Check timing cycle and actuators for intermittent operation
0 Check for use of wetting agents/surfactants
0 Are wetting agents/surfactants used at manufacturer's specifications or at
similar rates of last compliance test
0 Location of sprays versus file information
0 Check to see if antifreeze is used in winter (if required).
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Evaluation
0 Spray towers and nozzles should be located for maximum dust suppression.
Spray nozzles should emit an adequate spray pattern. Water added to
crusher inlets should be adequate to wet reduced ore size
0 Surfactants and wetting agents should be used at or near manufacturer's
specifications or at rates similar to the last compliance test
0 Manually operated system actuators allow for nonoperation due to human
error
0 High water turbidity may cause increased nozzle pluggage if water is
recycled.
Safety Considerations
0 Level II inspections involve some climbing and proximity to heavy equipment,
puleys, drive belts and moving vehicles; avoid close proximity to equipment
inlets and outlets where reduction fragments may be ejected; do not touch
operating or nonoperating nozzles.
4.10 Post-Inspection Conference
The closing conference with facility officials enables the inspector to "wrap up" the
inspection including answering any questions the company may have, filling in any
gaps in the data collected, and identifying information considered confidential. Thus,
the following elements generally constitute the closing conference.
0 Review of Inspection Data - At this point, the inspector can identify and fill in
any gaps in the information collected and ensure that there is general
agreement on the technical facts.
0 Inspection Follow-up Discussion - The inspector should be willing to answer
inspection related questions from facility officials, but should only state
matters of fact. Under no circumstances should the inspector make
judgments or conclusions concerning the facility's compliance status, legal
effects, or enforcement consequences.
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0 Declaration of Confidential Business Information - Plant officials authorized to
make business confidentiality claims should be given the opportunity to
make a claim of confidentiality by noting such claim on documentary material
provided to EPA. The inspector should note all information claimed
confidential and handle materials accordingly, even if a written declaration is
not made at this time.
0 Preparation of Receipts - The inspector should provide receipts for any
samples or records taken to a responsible plant individual.
Since EPA and State inspectors are often the only direct contact between the
regulatory agency and the regulated industry, the inspector should always be aware of
opportunities to improve industry-agency relations. The closing conference provides
an ideal opportunity to offer various kinds of assistance to facility officials. At this
point, the inspector has first-hand knowledge of questions, problems, and possible
solutions to problems. The inspector should consider:
0 Answering all questions within his ability and authority.
0 Referral of questions and problems to other Agency personnel when
necessary.
0 Discussion of problems and tactful suggestion of possible solutions and
assistance.
0 Tactful probing of problem areas uncovered during the inspection.
0 Offering or suggesting available resources such as technical publications,
special services available to industry, etc.
It is very important that the inspector follow up all referrals and offers to help. A
letter, phone call, or repeat visit will indicate to facility officials a genuine interest on the
part of the agency and aid the agency's industry relations.
4.11 Report Preparation and Tracking
During the inspection, the inspector collects and substantiates inspection data
which may later be used as evidence in an enforcement proceeding. When he/she
returns to the office it is his/her responsibility to see that this data is organized and
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arranged so that other agency personnel may make maximum use of it. Thus, the file
update and inspection report preparation are an important part of the inspection
process. These should both be done as soon as possible after the inspection to
ensure that all events of the inspection are still fresh in the inspector's memory.
He/she must be able to confirm during a later enforcement proceeding that the
information contained in the inspection report is true.
4.11.1 Computer Data Base Updates
Both the EPA and State agencies use several types of "files" for facility information
storage, which include computer data bases. State agencies may use different
variations of an Emissions Inventory System (EIS) while EPA uses data from the
Aerometric Information Retrieval System (AIRS). States with delegation and
enforcement authority for the nonmetallic mineral processing NSPS should enter the
results of compliance inspections of affected facilities into the AIRS Facility Subsystem
as well as into their respective computer data bases.
The inspector should check to see if any required information is missing or has
changed since the last update and then work within the office system to use the data
he/she has collected to update the appropriate data base.
4.11.2 Agency File Updates
The agency files usually contain the hard copies of all information,
correspondence, reports, etc. relevant to a particular facility. Examples of such items
are listed below:
0 General Facility Information
0 Correspondence to Facility
0 Correspondence from Facility
0 Permit Applications
0 Permits
Facility Layout
0 Flowcharts
0 Raw Data from Inspections
0 Inspection Reports
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Source Test Reports
Excess Emission Reports
Case Emission Reports
Agency Notes, etc. on Compliance Actions.
The inspector's data should be used to update the general facility information
including plant contact, correct address, changes in production rates, new flowcharts,
layouts, etc. and of course, the inspector's raw data and inspection report will be
added to the file.
4.11.3 Report Preparation
The inspector's inspection report serves two very important purposes in agency
operations: 1) it provides other agency personnel with easy access to the inspection
information because it has been organized into a comprehensive, usable document;
and 2) it constitutes a major part of the evidence package on the inspection which will
be available for subsequent enforcement proceedings and/or other types of
compliance-related follow-up activities.
Although specific information contained in the inspection report will vary
depending on the requirements of the agency, the basic format includes a narrative
report and documentary support. A typical report format is outlined below.
General Inspection Information
0 Inspection objectives
0 Facility selection scheme
0 Inspection facts (date, time, location, plant official, etc.)
Summary of Findings
0 Factual compliance findings (include problem areas)
0 Compliance status with applicable regulations
0 Administrative problems (as with entry, withdrawal of consent, etc.)
0 Recommended future action (if appropriate)
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Facility Information
0 Process information
0 Raw materials, production rates
0 Control equipment
0 Applicable regulations
0 Enforcement history
Inspection Procedures and Detail of Findings
0 Refer to standard procedures used
0 Describe nonroutine procedures used
0 Reference inspection data attached
0 Note and reference any statements taken
0 Reference photographs, if relevant
0 Reference any drawings, charts, etc. made
0 Reference visible emission observation forms
0 List records reviewed and address inadequacies
Sampling
0 Refer to methods used
0 Reference analytical results attached
Attachments
0 List of all documentary support attached
Documentary support is all evidence referred to in the inspection report. It will
include:
0 Inspector's field notes, forms, checklists
0 Drawings, charts, etc
0 Photographs
0 Analysis results of samples collected
0 Statements taken
° Visible emission observation forms.
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Appendix F contains a typical inspection report for a nonmetallic mineral
processing facility. The inspection and the final inspection report should document
whether the inspection objectives were attained, the compliance status of the affected
facilities, and the need for any follow-on activities required as a result of the inspection.
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APPENDIX A
40 CFR 60, SUBPART 000 WITH
FEBRUARY 14, 1989 REVISION
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Subpart OOO—Standards of
Performance for Nonmetallic Mineral
Processing Plants
[Subpart OOO added by 50 FR 31337.
August 1, 1985]
§60.670 Applicability and designation
of affected facility.
(a) Except as provided in paragraphs
(b), (c) and (d) of this section, the
provisions of this subpart are
applicable to the following affected
facilities in fixed or portable
nonmetallic mineral processing plants:
each crusher, grinding mill, screening
operation, bucket elevator, belt
conveyor, bagging operation, storage
bin, enclosed truck or railcar loading
station.
(b) An affected facility that is subject
to the provisions of Subpart F or I or
that follows in the plant process any
facility subject to the provisions of
Subparts F or I of this part is not
subject to the provisions of this
subpart.
(c) Facilities at the following plants
are not subject to the provisions of this
subpart:
(1) Fixed sand and gravel plants and
crushed stone plants with capacities, as
defined in §60.671, of 23 megagrams
per hour (25 tons per hour) or less;
(2) Portable sand and gravel plants
and crushed stone plants with
capacities, as defined in §60.671, of 136
megagrams per hour (150 tons per hou>)
or less; and
(3) Common clay plants and pumice
plants with capacities, as defined in
§60.671, of 9 megagrams per hour (10
tons per hour) or less.
(d)(l) When an existing facility is
replaced by a piece of equipment of
equal or smaller size, as defined in
§60.671, having the same function as
the existing facility, the new facility is
exempt from the provisions of
§§60.672, 60.674, and 60.675 except as
provided for in paragraph (d)(3) of this
section.
(2) An owner or operator seeking to
comply with this paragraph shall
comply with the reporting
requirements of §60.676(a) and (b).
(3) An owner or operator replacing
a!! existing facilities in 3 production
line with new facilities does not
qualify for the exemption described in
paragraph (d)(l) of this section and
must comply with the provisions of
§§60.672, 60.674 and 60.675.
(e) An affected facility under
paragraph (a) of this section that
commences construction.
reconstruction, or modification after
August 31.1983 is subject to the
requirements of this part.
§60.671 Definitions.
All terms used in this subpart. but not
specifically defined in this section,
shall have the meaning given them in
the Act and in Subpart A of this part.
"Bagging operation" means the
mechanical process by which bags are
filled with nonmetallic minerals.
"Belt conveyor" means a conveying
device that transports material from
one location to another by means of an
endless belt that is carried on a series
of idlers and routed around a pulley at
each end.
"Bucket elevator" means a
conveying device of nonmetallic
minerals consisting of a head and foot
assembly which supports and drives an
endless single or double strand chain
or belt to which buckets are attached.
"Building" means any frame
structure with a roof.
"Capacity" means the cumulative
rated capacity of all initial crushers
that are part of the plant.
"Capture system" means the
equipment (including enclosures,
hoods, ducts, fans, dampers, etc.) used
to capture and transport particulate
matter generated by one or more
process operations to a control device.
"Control device" means the air
pollution control equipment used to
reduce particulate matter emissions
released to the atmosphere from one or
more process operations at a
nonmetallic mineral processing plant.
"Conveying system" means a device
for transporting materials from one
piece of equipment or location to
another location within a plant.
Conveying systems include but are not
limited to the following: Feeders, belt
conveyors, bucket elevators and
pneumatic systems.
"Crusher" means a machine used to
crush any nonmetaiiic minerals, and
includes, but is not limited to, the
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following types: jaw, gyratory, cone,
roll, rod mill, hammermill, and
impactor.
"Enclosed truck or railcar loadir.g
station" means that portion of a
nonmetallic mineral processing plant
were nonmetallic minerals are loaded
by an enclosed conveying system into
enclosed trucks or railcars.
"Fixed plant" means any
nonmetallic mineral processing plant
at which the processing equipment
specified in §60.670(a) is attached by a
cable, chain, turnbucket, bolt or other
means (except electrical connections)
to any anchor, slab, or structure
including bedrock.
"Fugitive emission "means particulate
matter that is not collected by a
capture system and is released to the
atmosphere at the point of generation.
"Grinding mill" means a machine
used for the wet or dry fine crushing
of any nonmetallic mineral. Grinding
mills include, but are not limited to,
the following types: hammer, roller,
rod, pebble and ball, and fluid energy.
The grinding mill includes the air
conveying system, air separator, or air
classifier, where such systems are
used.
"Initial crusher" means any crusher
into which nonmetallic minerals can
be fed without prior crushing in the
plant.
"Nonmetallic mineral" means any of
the following minerals or any mixture
of which the majority is any of the
following minerals:
(a) Crushed and Broken Stone,
including Limestone, Dolomite,
Granite, Traprock, Sandstone, Quartz,
Quartzite, Marl, Marble, Slate, Shale
Oil Shale, and Shell.
(b) Sand and Gravel.
(c) Clay including Kaolin, Fireclay,
Bentonite, Fuller's Earth, Ball Clay,
and Common Clay.
(d) Rock Salt.
(e) Gypsum.
(f) Sodium Compounds, including
Sodium Carbonate, Sodium Chloride,
and Sodium Sulf ate.
(g) Pumice.
(h) Gilsonite.
(i) Talc and Pyrophyllite.
(j) Boron, including Borax, Kernite,
and Colemanite.
(k) Barite.
(1) Fluorospar.
(m) Feldspar.
(n) Diatomite.
(o) Perlite.
(p) Vermiculite.
(q) Mica.
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(r) Kyanite, including Andalusite,
Sillimanite, Topaz, and Dumortierite.
"Nonmetallic mineral processing
plant" means any combination of
equipment that is used to crush or
grind any nonmetallic mineral wherev-
er located, including lime plants,
power plants, steel mills, asphalt con-
crete plants, Portland cement plants,
or any other facility processing non-
metallic minerals except as provided in
f 60.670 (b) and (c).
"Portable plant" means any nonme-
tallic mineral processing plant that is
mounted on any chassis or skids and
may be moved by the application of a
lifting or pulling force. In addition,
there shall be no cable, chain, turn-
buckle, bolt or other means (except
electrical connections) by which any
piece of equipment is attached or
clamped to any anchor, slab, or struc-
ture, including bedrock that must be
removed prior to the application of a
lifting or pulling force for the purpose
of transporting the unit.
"Production line" means all affected
facilities (crushers, grinding mills,
screening operations, bucket elevators,
belt conveyors, bagging operations,
storage bins, and enclosed truck and
railcar loading stations) which are di-
rectly connected or are connected to-
gether by a conveying system.
"Screening operation" means a
device for separating material accord-
ing to size by passing undersize materi-
al through one or more mesh surfaces
(screens) in series, and retaining over-
size material on the mesh surfaces
(screens).
"Size" means the rated capacity in
tons per hour of a crusher, grinding
mill, bucket elevator, bagging oper-
ation, or enclosed truck or railcar load-
ing station; the total surface area of
the top screen of a screening oper-
ation; the width of a conveyor belt;
and the rated capacity in tons of a
storage bin.
"Stack emission" means the particu-
late matter that is released to the at-
mosphere from a capture system.
"Storage bin" means a facility for
storage (including surge bins) or non-
metallic minerals prior to further
processing or loading.
"Transfer point" means a point in a
conveying operation where the nonme-
tallic mineral is transferred to or from
a belt conveyor except where the non-
metallic mineral is being transferred
to a stockpile.
"Truck dumping" means the unload-
ing of nonmetallic minerals from mov-
able vehicles designed to transport
nonmetallic minerals from one loca-
tion to another. Movable vehicles in-
clude but are not limited to: trucks,
front end loaders, skip hoists, and rail-
cars.
"Vent" means an opening through
which there is mechanically induced
air flow for the purpose of exhausting
from a building air carrying particu-
late matter emissions from one or
more affected facilities.
§ 60.672 Standard for participate matter.
(a) On and after the date on which
the performance test required to be
conducted by § 60.8 is completed, no
owner or operator subject to the provi-
sions of this subpart shall cause to be
discharged into the atmosphere from
any transfer point on belt conveyors
or from any other affected facility any
stack emissions which:
(1) Contain particulate matter in
excess of 0.05 g/dscm; or
(2) Exhibit greater than 7 percent
opacity, unless the stack emissions are
discharged from an affected facility
using a wet scrubbing control device.
Facilities using a wet scrubber must
comply with the reporting provisions
of 5 60.676 (c), (d), and (e).
(b) On and after the sixtieth day
after achieving the maximum produc-
tion rate at which the affected facility
will be operated, but not later than
180 days after initial startup, no owner
or operator subject to the provisions
of this subpart shall cause to be dis-
charged into the atmosphere from any
transfer point on belt conveyors or
from any other affected facility any
fugitive emissions which exhibit great-
er than 10 percent opacity, except as
provided in paragraphs (c), (d) and (e)
of this section.
(c) On and after the sixtieth day
after achieving the maximum produc-
tion rate at which the affected facility
will be operated, but not later than
180 days after initial startup, no owner
or operator shall cause to be dis-
charged into the atmosphere from any
crusher, at which a capture system is
not used, fugitive emissions which ex-
hibit greater than 15 percent opacity.
(d) Truck dumping of nonmetallic
minerals into any screening operation,
feed hopper, or crusher is exempt
from the requirements of this section.
(e) If any transfer point on a convey-
or belt or any other affected facility is
enclosed in a building, then each en-
closed affected facility must comply
with the emission limits in paragraphs
(a), (b) and (c) of this section, or the
building enclosing the affected facility
or facilities must comply with the fol-
lowing emission limits:
(1) No owner or operator shall cause
to be discharged into the atmosphere
from any building enclosing any trans-
fer point on a' conveyor belt or any
other affected facility any visible fugi-
tive emissions except emissions from a
vent as defined in § 60.671.
(2) No owner or operator shall cause
to be discharged into the atmosphere
from any vent of any building enclos-
ing any transfer point on a conveyor
belt or any other affected facility
emissions which exceed the stack
emissions limits in paragraph (a) of
this section.
§ 60.673 Reconstruction.
(a) The cost of replacement of ore-
contact surfaces on processing equip-
ment shall not be considered in calcu-
lating either the "fixed capital cost of
the new components" or the "fixed
capital cost that would be required to
construct a comparable new facility"
under $ 60.15. Ore-contact surfaces are
crushing surfaces; screen meshes, bars,
and plates; conveyor belts; and eleva-
tor buckets.
(b) Under § 60.15, the "fixed capital
cost of the new components" includes
the fixed capital cost of all depreciable
components (except components speci-
fied in paragraph (a) of this section)
which are or will be replaced pursuant
tc all continuous programs of compo-
nent replacement commenced within
any 2-year period following August 31,
1983.
§ 60.674 Monitoring of operations.
The owner or operator of any affect-
ed facility subject to the provisions of
this subpart which uses a wet scrubber
to control emissions shall install, cali-
brate, maintain and operate the fol-
lowing monitoring devices:
(a) A device for the continuous
measurement of the pressure loss of
the gas stream through the scrubber.
The monitoring device must be certi-
fied by the manufacturer to be accu-
rate within ±250 pascals ±1 inch
water gauge pressure and must be cali-
brated on an annual basis in accord-
A-4
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ance with manufacturer's Instructions.
(b) A device for the continuous
measurement of the scrubbing liquid
flow rate to the wet scrubber. The
monitoring device must be certified by
the manufacturer to be accurate
within ±5 percent of design scrubbing
liquid flow rate and must be calibrated
on an annual basis in accordance with
manufacturer's instructions.
6 60.675 Test methods and procedures.
[60.675 revised by 54 FR 6662, February
14, 1989]
(a) In conducting the performance
tests required in { 60.8, the owner or
operator shall use as reference methods
and procedures the test methods in
Appendix A of mis part or other
methods and procedures as specified in
this section, except as provided in
5 60.8(b). Acceptable alternative
methods and procedures are given in
paragraph (e) of this section.
(b) The owner or operator shall
determine compliance with the
particulate matter standards in
S 60.272(a) as follows*.
(1) Method 5 or Method 17 shall be
used to determine the particulate matter
concentration. The sample volume shall
be at least 1.70 dscm (60 dscf). For
Method 5, if the gas stream being
sampled is at ambient temperature, the
sampling probe and filter may be
operated without heaters. If the gas
stream is above ambient temperature,
the sampling probe and filter may be
operated at a temperature high enough.
but no higher than 121 *C (250 T). to
prevent water condensation on the filter.
(2) Method 9 and the procedures in
§ 60.11 shall be used to determine
opacity.
(c) In determining compliance with the
particulate matter standards in § 60.672
(b) and (c), the owner or operator shall
use Method 9 and the procedures in
5 60.11. with the following additions:
(1) The minimum distance between
the observer and the emission source
shall be 4.57 meters (15 feet).
(2) The observer shall, when possible.
select a position that minimizes
interference from other fugitive emission
sources (e.g.. road dust). The required
observer position relative to the sun
(Method 9. Section 2.1) must be
followed.
(3) For affected facilities using wet
dust suppression for particulate matter
control, a visible mist is sometimes
generated by the spray. The water mist
must not be confused with particulate
matter emissions and is not to be
considered a visible emission. When a
water mist of this nature is present, the
observation of emissions is to be made
at a point in the plume where the mist is
no longer visible.
(d) In determining compliance with
$ 60.672(e). the owner or operator shall
use Method 22 to determine fugitive
emissions. The performance test shall be
conducted while all affected facilities
inside the building are operating. The
performance test for each building shall
be at least 75 minutes in duration, with
each side of the building and the roof
being observed for at least 15 minutes.
(e) The owner or operator may use the
following as alternatives to the
reference methods and procedures
specified in this section:
(1) For the method and procedure of
paragraph (c) of this section, if
emissions from two or more facilities
continuously interfere so that the
opacity of fugitive emissions from an
individual affected .facility cannot be
read, either of the following procedures
may be used:
(i) Use for the combined emission
stream the highest fugitive opacity
standard applicable to any of the
individual affected facilities contributing
to the emissions stream.
(ii) Separate the emissions so that the
opacity of emissions from each affected
facility can be read.
(f) To comply with § 60.676(d). the
owner or operator shall record the
measurements as required § 60.676(c)
using the monitoring devices in § 60.674
(a) and (b) during each particulate
matter run and shall determine the
averages.
§60.676 Reporting and recordkeeping.
(a) Each owner or operator seeking to
comply with §60.670(d) shall submit to
the Administrator the following informa-
tion about the existing facility being re-
placed and the replacement piece of
equipment.
(1) For a crusher, grinding mill, bucket
elevator, bagging operation, or enclosed
truck or railcar loading station:
(i) The rated capacity in tons per hour
of the existing facility being replaced and
(ii) The rated capacity in tons per hour
of the replacement equipment.
(2) For a screening operation:
(i) The total surface area of the top
screen of the existing screening operation
being replaced and
(ii) The total surface area of the top
screen of the replacement screening
operation.
(3) For a conveyor belt:
(i) The width of the existing belt being
replaced and
(ii) The width of the replacement con-
veyor belt.
(4) For a storage bin:
(i) The rated capacity in tons of the
existing storage bin being replaced and
(ii) The rated capacity in tons of re-
placement storage bins.
(b) Each owner or operator seeking to
comply with §60.670(d) shall submit the
following data to the Director of the Emis-
sion Standards and Engineering Division,
(MD-13), U.S. Environmental Protection
Agency, Research Triangle Park, North
Carolina 27711.
(1) The information described in
§60.676(a).
(2) A description of the control device
used to reduce particulate matter emis-
sions from the existing facility and a list of
all other pieces of equipment controlled by
the same device; and
(3) The estimated age of the existing
facility.
(c) During the initial performance test
of a wet scrubber, and daily thereafter, the
owner or operator shall record the mea-
surements of both the change in pressure
of the gas stream across the scrubber and
the scrubbing liquid flow rate.
(d) After the initial performance test of
a wet scrubber, the owner or operator
shall submit semiannual reports to the
Administrator of occurrences when the
measurements of the scrubber pressure
loss (or gain) and liquid flow rate differ by
more than ± 30 percent from the average
determined during the most recent per-
formance test.
(60.676(d) amended by 54 FR 6662, Feb-
ruary 14, 1989]
(e) The reports required under para-
graph (d) shall be postmarked within 30
days following end of the second and
fourth calendar quarters.
A-5
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(0 The owner or operator of any affect-
ed facility shall submit written reports of
the results of all performance tests con-
ducted to demonstrate compliance with
the standards set forth in §60.672, includ-
ing reports of opacity observations made
using Method 9 to demonstrate compli-
ance with §60.672 (b) and (c) and reports
of observations using Method 22 to dem-
onstrate compliance with §60.672(e).
(g) The requirements of this paragraph
remain in force until and unless the Agen-
cy, in delegating enforcement authority to
a State under Section lll(c) of the Act,
approves reporting requirements or an al-
ternative means of compliance surveil-
lance adopted by such States. In that
event, affected sources within the State
will be relieved of the obligation to comply
with paragraphs (a), (c), (d), (e), and (f)
of this subsection, provided that they com-
ply with requirements established by the
State. Compliance with paragraph (b) of
this section will still be required.
[Approved by the Office of Management
and Budget under control number
2060-0050]
A-6
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APPENDIX B
40 CFR 60, SUBPART A
GENERAL PROVISIONS (ABBREVIATED)
B-1
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Subpart A—General Provisions
§ 60.1 Applicability.
Except as provided in Subparts B
and C, the provisions of this part
apply to the owner or operator of any
stationary source which contains an
affected facility, the construction or
modification of which is commenced
after the date ol publication in this
part of any standard (or, if earlier, the
date of publication of any proposed
standard) applicable to that facility.
§ 60.2 Definitions.
[60.2 amended by 54 FR 6662, February
14. 1989]
The terms used in this part are de-
fined in the Act or in this section as
follows:
"Act" means the Clean Air Act (42
U.S.C. 1857 et seq.. as amended by
Pub. L. 91-604, 84 Stat. 1676).
"Administrator" means the Adminis-
trator of the Environmental Protec-
tion Agency or his authorized repre-
sentative.
"Affected facility" means, with ref-
erence to a stationary source, any ap-
paratus to which a standard is applica-
ble.
"Alternative method" means any
method of sampling and analyzing for
an air pollutant which is not a refer-
ence or equivalent method but which
has been demonstrated to the Admin-
istrator's satisfaction to, in specific
cases, produce results adequate for his
determination of compliance.
"Capital expenditure" means an ex-
penditure for a physical or operational
change to an existing facility which
exceeds the product of the applicable
"annual asset guideline repair allow-
ance percentage" specified in the
latest edition of Internal Revenue
Service (IRS) Publication 534 and the
existing facility's basis, as defined by
section 1012 of the Internal Revenue
Code. However, the total expenditure
for a physical or operational change to
an existing facility must not be re-
duced by any "excluded additions" as
defined in IRS Publication 534, as
would be done for tax purposes.
"Commenced" means; with respect to
the definition of "new source" in section
lll(a)(2) of the Act, that an o^ner or
operator has undertaken a continuous
program of construction or modification
or that an owner or operator has entered
into a contractual obligation to undertake
and complete, within a reasonable time,
a continuous program of construction
or modification.
"Construction" means fabrication,
erection, or installation of an affected
facility.
"Continuous monitoring system
means the total equipment, required
under the emission monitoring sections
in applicable subparts, used to sample
and condition (if applicable), to analyze,
and to provide a permanent record of
emissions or process parameters.
"Equivalent method" means any
method of sampling and analyzing for an
air pollutant which has been demon-
strated to the Administrator's satisfac-
tion to 'have a consistent and quan-
titatively known relationship to the ref-
erence method, under specified condi-
tions.
"Existing facility" means, with ref-
erence to a stationary source, any ap-
paratus of the type for which a standard
is promulgated in this part, and the con-
struction or modification of which was
commenced before the date of proposal
of that standard; or any apparatus which
could be altered in such a way as to~5e of
that type.
"Isokinetic sampling" means sam-
pling in which the linear velocity of the
gas entering the sampling nozzle is equal
to that of the undisturbed gas stream at
the sample point.
"Malfunction" means any sudden and
unavoidable failure of air pollution con-
trol equipment or process equipment
or of a process to operate in a normal or
usual manner. Failures that are caused
entirelv or in cart bv Door maintenance.
careless operation, or any other prevent-
able upset condition or preventable
equipment breakdown shall not be con-
sidered malfunctions.
"Modification" means any physical
change in, or change in the method of
operation of, an existing facility which
increases the amount of any air pollu-
tant (to which a standard applies)
emitted into the atmosphere by that
facility or which results in the emission
of any air pollutant (to which a standard
applies) into the atmosphere not pre-
viously emitted.
"Monitoring device" means the total
equipment, required under the monitor-
ing of operations sections in applicable
subparts, used to measure and record (if
applicable) process parameters.
"Nitrogen oxides" means all oxides of
nitrogen except nitrous oxide, as
measured by test methods set forth in
this part.
"One-hour period" means any .60-
minute period commencing on the hour.
"Opacity" means the degree to which
emissions reduce the transmission of.
light and obscure the view of an object
in the background.
' "Owner or operator" means any per-
son who owns, leases, operates, controls,
or supervises an affected facility or a
stationary source of which an affected
facility is a part.
"Particulate matter"" means any
finely divided solid or liquid material.
,)ther than uncombined water, as
measured by the reference methods
specified under each applicable sub-
part, or an equivalent or alternative
method.
"Proportional sampling" means sam-
pling at a rate that produces a con-
stant ration of sampling rate to stack
gas flow rate.
"Reference method" means any
method of sampling and analyzing for
an air pollutant as specified in the applica-
ble subpart.
"Run" means the net period of time
during which an emission sample is
collected. Unless otherwise specified, a
run may be either intermittent or con-
tinuous within the limits of good engi-
neering practice.
"Shutdown" means the cessation of
operation of an affected facility for
any purpose.
"Six-minute period" means any one
of the 10 equal parts of a one-hour
period.
"Standard" means a standard of per-
formance proposed or promulgated
under this part.
"Standard conditions" means a tem-
perature of 293 K (68°F) and a pres-
B-2
-------
sure of 101.3 kilopascals (29.92 in Hg).
"Startup" means the setting in oper-
ation of an affected facility for any
purpose.
"Volatile Organic Compound" means
any organic compound which participates
in atmospheric photochemical reactions;
or which is measured by a reference meth-
od, an equivalent method, an alternative
method, or which is determined by proce-
dures specified under any subpart.
i 60.3 Unit* and abbreviations.
Used in this part are abbreviations
and symbols of units of measure.
These are defined as follows:
(a) System International (SI) units
of measure:
A—ampere
g—gram
Hz—hertz
J—joule
K-degree Kelvin
kg—kilogram
m—meter
m'—cubic meter
mg—milligram—10'J gram
mm—millimeter—10"' meter
Mg—megagram—10' gram
mol—mole
N—newton
ng—nanogram—10~ • gram
run—nanometer—10" * meter
Pa—pascal
s—second
V—volt
W-watt
n—ohm
MB—microgram—10" * gram
(b) Other units of measure:
3tu—British thermal unit
•C—degree Celsius (centigrade)
cal—calorie
cfm—cubic feet per minute
cu ft—cubic feet
dcf—dry cubic feet
dcm— dry cubic meter
dscf—dry cubic feet at standard conditions
dscm—dry cubic meter at standard condi-
tions
eq—equivalent
•p—degree Fahrenheit
ft—feet
gal—gallon
gr—grain
g-eq—gram equivalent
hr—hour
in—inch
k—1,000
1—liter
1pm—liter per minute
Ib—pound
meq—milliequivalent
min—minute
ml—milliliter
mol. wt.—molecular weight
ppb—parts per billion
ppm—parts per million
psia—pounds per square inch absolute
psig—pounds per square inch gage
•R—degree Rankine
scf—cubic feet at standard conditions
scfh—cubic feet per hour at standard condi-
tions
scm—cubic meter at standard conditions
sec—second
sq ft—square feet
std—at standard conditions
(c) Chemical nomenclature:
CdS—cadmium sulfide
CO—carbon monoxide
CO,—carbon dioxide
HC1—hydrochloric acid
Hg—mercury
H,O—water
H^J—hydrogen sulfide
H^'O.-sulfuric acid
N,—nitrogen
NO—nitric oxide
NOi—nitrogen dioxide
NO.—nitrogen oxides
Oi—oxygen
SO,—sulfur dioxide
SO,—sulfur trioxide
SO.—sulfur oxides
(d) Miscellaneous:
A.S.T.M.—American Society for Testing and
Materials
B-3
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§ 60.5 Determination of construction or
modification.
(a) When requested to do so by an
owner or operator, the Administrator
will make a determination of whether
action taken or intended to be taken
by such owner or operator constitutes
construction (including reconstruc-
tion) or modification or the com-
mencement thereof within the mean-
ing of this part.
(b) The Administrator will respond
to any request for a determination
under paragraph (a) of this section
within 30 days of receipt of such re-
quest.
§ 60.6 Review of plans.
(a) When requested to do so by an
owner or operator, the Administrator
will review plans for construction or
modification for the purpose of pro-
viding technical advice to the owner or
operator.
(bXl) A separate request shall be
submitted for each construction or
modification project.
(2) Each request shall identify the
location of such project, and be accom-
panied by technical information de-
scribing the proposed nature, size,
design, and method of operation of
each affected facility involved in such
project, including information on any
equipment to be used for measure-
ment or control of emissions.
(c) Neither a request for plans
review nor advice furnished by the Ad-
ministrator in response to such re-
quest shall (1) relieve an owner or op-
erator of legal responsibility for com-
pliance with any provision of this part
or of any applicable State or local re-
quirement, or (2) prevent the Adminis--
trator from implementing or enforcing
any provision of this part or taking
any other action authorized by the
Act.
§ 60.7 Notification and record keeping.
(a) Any owner or operator subject to
the provisions of this part shall fur-
nish the Administrator written notifi-
cation as follows:
(PA notification of the date con-
struction (or reconstruction as defined
under § 60.15) of an affected facility is
commenced postmarked no later than
30 days after such date. This require-
ment shall not apply in the case of
mass-produced facilities which are
purchased in completed form.
(2) A notification of the anticipated
date of initial startup of an affected
facility postmarked not more than 60
days nor less than 30 days prior to
such date.
(3) A notification of the actual date
of initial startup of an affected facility
postmarked within 15 days after such
date.
(4) A notification of any physical or
operational change to an existing fa-
cility which may increase the emission
rate of any air pollutant to which a
standard applies, unless that change is
specifically exempted under an appli-
cable subpart or in |60.14(e). This
notice shall be postmarked 60 days or
as soon as practicable before the
change is commenced and shall in-
clude information describing the pre-
c'se nature of the change, present and
proposed emission control systems,
productive capacity of the facility
before and after the change, and the
expected completion date of the
change. The Administrator may re-
quest additional relevant information
subseauent to this notice.
(5) A notification of the date upon
which demonstration of the continu-
ous monitoring system performance
commences in accordance with
§ 60.13(c). Notification shall be post-
marked not less than 30 days prior to
such date.
(6) A notification of the anticipated
date for conducting the opacity obser-
vations required by §60.11(e)(l) of this
part. The notification shall also in-
clude, if appropriate, a request for the
Administrator to provide a visible
emissions reader during a performance
test. The notification shall be post-
marked not less than 30 days prior to
such date.
(60.7(a)(6) added by 50 FR 53113, De-
cember 27, 1985]
(7) A notification that continuous
opacity monitoring system data results
will be used to determine compliance
with the applicable opacity standard
during a performance test required by
I 60.8 in lieu of Method 9 observation
data as allowed by { 60.11(e)(5) of this
part. This notification shall be post-
marked not less than 30 days prior to
the date of the performance test.
[60.7(aK7) added by 52 FR 9781, March 26.
1987]
(b) Any owner or operator subject to
the provisions of this part shall main-
tain records of the occurrence and du-
ration of any startup, shutdown, or
malfunction in the operation of an af-
fected facility; any malfunction of the
air pollution control equipment; or
any periods during which a continuous
monitoring system or monitoring
device is inoperative.
(c) Each owner or operator required
to install a continuous monitoring
system shall submit a written report
of excess emissions (as defined in ap-
plicable subparts) to the Administra-
tor for every calendar quarter. Ali
quarterly reports shall be postmarked
by the 30th day following the end of
each calendar quarter and shall in-
clude the following information:
(1) The magnitude of excess emis-
sions computed in accordance with
§ 60.13(h), any conversion factor(s)
used, and the date and time of com-
mencement and completion of each
time period of excess emissions.
(2) Specific identification of each
period of excess emissions that occurs
during startups, shutdowns, and mal-
functions of the affected facility. The
nature and cause of any malfunction
(if known), the corrective action taken
or preventative measures adopted.
(3) The date and time identifying
each period during which the continu-
ous monitoring system was inoperative
except for zero and span checks and
the nature of the system repairs or ad-
justments.
(4) When no excess emissions have
occurred or the continuous monitoring
system(s) have not been inoperative,
repaired, or adjusted, such informa-
tion shall be stated in the report.
B-4
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(d) Any owner or operator subject to
the provisions of this part shall main-
tain a file of all measurements, includ-
ing continuous monitoring system,
monitoring device, and performance
testing measurements; all continuous
monitoring system performance evalu-
ations; all continuous monitoring
system or monitoring device calibra-
tion checks; adjustments and mainte-
nance performed on these systems or
devices; and all other information re-
quired by this part recorded in a per-
manent form suitable for inspection.
The file shall be retained for at least
two years following the date of such
measurements, maintenance, reports.
and records.
(e) If notification substantially simi-
lar to that in paragraph (a) of this sec-
tion is required by any other State or
local agency, sending the Administra-
tor a copy of that notification will sat-
isfy the requirements of paragraph (a)
of this section.
(f) Individual subparts of this part
may include specific provisions which
clarify or make inapplicable the provi-
sions set forth in this section.
[60.7(0 added by 48 FR 48335, October
18, 1983]
§ 60.8 Performance tests.
(a) Within 60 days after achieving
the maximum production rate at
which the affected facility will be op-
erated, but not later than 180 days
after initial startup of such facility
and at such other times as may be re-
quired by the Administrator under sec-
tion 114 of the Act, the owner or oper-
ator of such facility shall conduct per-
formance test(s) and furnish the Ad-
ministrator a written report of the re-
sults of such performance test(s).
(b) Performance tests shall be con-
ducted and data reduced in accordance
with the test methods and procedures
contained in each applicable subpart
unless the Administrator (1) specifies
or approves, in specific cases, the use
of a reference method with minor
changes in methodology, (2) approves
the use of an equivalent method, (3)
approves the use of an alternative
method the results of which he has
determined to be adequate for indicat-
ing whether a specific source is in
compliance, (4) waives the requirement
for performance tests because the owner
or operator of a source has demonstrated
by other means to the Administrator's
satisfaction that the affected facility is in
compliance with the standard. Nothing in
this paragraph shall be construed to abro-
gate the Administrator's authority to re-
quire testing under section 114 of the Act,
or (5) approves shorter sampling times
and smaller sample volumes when necessi-
tated by process variables or other factors.
[60.8(b) amended by 54 FR 6662, Febru-
ary 14, 1989]
(c) Performance tests shall be con-
ducted under such conditions as the
Administrator shall specify to the
plant operator based on repres°ntative
performance of the affected facility.
The owner or operator shall make
available to the Administrator such
records as may be necessary to deter-
mine the conditions of the perform-
ance tests. Operations during periods
of startup, shutdown, and malfunction
shall not constitute representative
conditions for the purpose of a per-
formance test nor shall emissions in
excess of the level of the applicable
emission limit during periods of start-
up, shutdown, and malfunction be
considered a violation of the applica-
ble emission limit unless otherwise
specified in the applicable standard.
(d) The owner or operator of an af-
fected facility shall provide the Ad-
ministrator at least 30' days prior
notice of any performance test, except
as specified under other subparts, to
afford the Administrator the opportu-
nity to have an observer present.
(e) The owner or operator of an af-
fected facility shall provide, or cause
to be provided, performance testing
facilities as follows:
(1) Sampling ports adequate for test
methods applicable to such facility. This
includes (i) constructing the air pollution
control system such that volumetric flow
rates and pollutant emission rates can be
accurately determined by applicable test
methods and procedures and (ii) providing
a stack or duct free of cyclonic flow during
performance tests, as demonstrated by ap-
plicable test methods and procedures.
[60.8(e)(l) revised by 54 FR 6662, Febru-
ary 14, 1989]
(2) Safe sampling platform(s).
access to sampling
(3) Safe
platform(s).
(4) Utilities for sampling and testing
equipment.
(f) Unless otherwise specified in the
applicable subpart, each performance
test shall consist of three separate
runs using the applicable test method.
Each run shall be conducted for the
time and under the conditions speci-
fied in the applicable standard. For
the purpose of determining compli-
ance with an applicable standard, the
arithmetic means of results of the
three runs shall apply. In the event
that a sample is accidentally lost or
conditions occur in which one of the
three runs must be discontinued be-
cause of forced shutdown, failure of
an irreplaceable portion of the sample
train, extreme meteorological condi-
tions, or other circumstances, beyond
the owner or operator's control, com-
pliance may, upon the Administrator's
approval, be determined using the
arithmetic mean of the results of the
two other runs.
§ 60.9 Availability of information.
The availability to the public of in-
formation provided to, or otherwise
obtained by, the Administrator under
this Part shall be governed by Part 2
of this chapter. (Information submit-
ted voluntarily to the Administrator
for the purposes of §§ 60.5 and 60.6 is
governed by $ 2.201 through § 2.213 of
this chapter and not by § 2.301 of this
chapter.)
§ 60.10 State authority.
The provisions of this part shall not
be construed in any manner to pre-
clude any State or political subdivision
thereof from:
(a) Adopting and enforcing any
emission standard or limitation appli-
cable to an affected facility, provided
that such emission standard or limita-
tion is not less stringent than the
standard applicable to such facility.
(b) Requiring the owner or operator
of an affected facility to obtain per-
mits, licenses, or approvals prior to ini-
tiating construction, modification, or
operation of such facility.
§60.11 Compliance with standards and
maintenance requirements.
(a) Compliance with standards in
this part, other than opacity stand-
ards, shall be determined only by per-
formance tests established by i 60.8,
unless otherwise specified in the appli-
cable standard.
B-5
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(b) Compliance with opacity standards
in this part shall be determined by con-
ducting observations in accordance with
Reference Method 9 in Appendix A of this
part, any alternative method that is ap-
proved by the Administrator, or as pro-
vided in paragraph (e)(5) of this section.
For purposes of determining initial com-
pliance, the minimum total time of ob-
servations shall be 3 hours (30 6-minute
averages) for the performance test or
other set of observations (meaning those
fugitive-type emission sources subject
only to an opacity standard.
(60.11(b) revised by 50 FR 53113, De-
cember 27, 1985; amended by 52 FR
9781, March 26, 1987]
(c) The opacity standards set forth
in this part shall apply at all times
except during periods of startup, shut-
down, malfunction, and as otherwise
provided in the applicable standard.
(d) At all times, including periods of
startup, shutdown, and malfunction,
owners and operators shall, to the
extent practicable, maintain and oper-
ate any affected facility including as-
sociated air pollution control equip-
ment in a manner consistent with
good air pollution control practice for
minimizing emissions. Determination
of whether acceptable operating and
maintenance procedures are being
used will be based on information
available to the Administrator which
may include, but is not limited to,
monitoring results, opacity observa-
tions, review of operating and mainte-
nance procedures, and inspection of
the source.
(60.11(e)(l) and (2) revised, new (3) —
(5) added and former (3) and (4) redesig-
nated as (6) and (7) by 50 FR 53113,
December 27, 1985]
(e)(l) For the purpose of demonstrating
initial compliance, opacity observations
shall be conducted concurrently with the
initial performance test required in §60.8
unless one of the following conditions ap-
ply. If no performance test under §60.8 is
required, then opacity observations shall
be conducted within 60 days after achiev-
ing the maximum production rate at
which the affected facility will be operated
but no later than 180 days after initial
startup of the facility. If visibility or other
conditions prevent the opacity observa-
tions from being conducted concurrently
with the initial performance test required
under §60.8, the source owner or operator
shall reschedule the opacity observations
as soon after the initial performance t?«t
as possible, but not later than jo u.i^
thereafter, and shall advise the Adminis-
trator of the rescheduled date. In these
cases, the 30-day prior notification to the
Administrator required in §60.7(a)(6)
shall be waived. The rescheduled opacity
observations 'shall be conducted (to the
extent possible) under the same operating
conditions that existed during the initial
performance test conducted under §60.8.
The visible emissions observer shall deter-
mine whether visibility or other conditions
prevent the opacity observations from be-
ing made concurrently with the initial per-
formance test in accordance with proce-
dures contained in Reference Method.9 of
Appendix B of this part. Opacity readings
of portions of plumes which contain con-
densed, uncombined water vapor shall not
be used for purposes of determining com-
pliance with opacity standards. The owner
or operator of an affected facility shall
make available, upon request by the Ad-
ministrator, such records as may be neces-
sary to determine the conditions under
which the visual observations were made
and shall provide evidence indicating proof
of current visible observer emission certifi-
cation. Except as provided in-paragraph
(e)(5) of this section, the results of con-
tinuous monitoring by transmissometer
which indicate that the opacity at the time
visual observations were made was not in
excess of the standard are probative but
not conclusive evidence of the actual opac-
ity of an emission, provided that the
source shall meet the burden of proving
that the instrument used meets (at the
time of the alleged violation) Performance
Specification 1 in Appendix B of this part,
has been properly maintained and (at the
time of the alleged violation) that the
resulting data have not been altered in any
way.
(60.11(e)(l) amended by 52 FR 9781,
March 26, 1987]
(2) Except as provided in paragraph
(3)(e) of this section, the owner or opera-
tor of an affected facility to which an
opacity standard in this part applies shall
conduct opacity observations in accord-
ance with paragraph (b) of this section,
shall record the opacity of emissions, and
shall report to the Administrator the opac-
ity results along with the results of the
initial performance test required under
§60.8. The inability of an owner or opera-
tor to secure a visible emissions observer
shall not be considered a reason for not
conducting the opacity observations con-
current with the initial performance test.
(3) The owner or operator of an affect-
ed facility to which an opacity standard in
this part applies may request the Adminis-
trator to determine and to record the opac-
ity of emissions from the affected facility
during the initial performance test and at
such times as may be required. The owner
or operator of the affected facility shall
report the opacity results. Any request to
the Administrator to determine and to
record the opacity of emissions from an
affected facility shall be included in the
notification required in §60.7(a)(6). If for
some reason, the Administrator cannot de-
termine and record the opacity of emis-
sions from the affected facility during the
performance test, then the provisions of
paragraph (e)(l) of this section shall
apply.
(4) An owner or operator of an affected
facility using a continuous opacity monitor
[transmissometer] shall record the moni-
toring data produced during the initial
performance test required by §60.8 and
shall furnish the Administrator a written
report of the monitoring results along with
Method 9 and §60.8 performance test
results.
(60.11(e)(4) corrected by 51 FR 1790,
January 15, 1986]
(5) An owner or operator of an af-
fected facility subject to an opacity
standard may submit, for compliance
purposes, continuous opacity monitor-
ing system (COM3] data results pro-
duced during any performance test re-
quired under §60.8 in lieu of Method 9
observation data. If an owner or opera-
tor elects to submit COM3 data for
compliance with the opacity standard,
he shall notify the Administrator of
that decision, in writing, at least 30
days before any performance test re-
quired under §60.8 is conducted. Once
the owner or operator of an affected
facility has notified the Administrator
to that effect, the COMS data results
will be used to determine opacity com-
pliance during subsequent tests re-
quired under §60.8 until the owner or
operator notifies the Administrator, in
writing, to the contrary. For the pur-
B-6
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pose of determining compliance with
the opacity standard during a perform-
ance test required under §60.8 using
COM3 data, the minimum total time of
COM3 data collection shall be aver-
ages of all 6-minute continuous periods
within the duration of the mass emis-
sion performance test. Results of the
COMS opacity determinations shall be
submitted along with the results of the
performance test required under §60.8.
The owner or operator of an affected
facility using a COMS for compliance
purposes is responsible for demonstrat-
ing that the COMS meets the require-
ments specified in §60.13(c) of this part,
that the COMS has been properly
maintained and operated, and that the
resulting data have not been altered in
any way. If COMS data results are
submitted for compliance with the
opacity standard for a period of time
during which Method 9 data indicates
noncompliance, the Method 9 data will
be used to determine opacity
compliance.
[New 60.11(e)(5) added by 52 FR 9781,
March 26, 1987]
(6) Upon receipt from an owner or
operator of the written reports of the
results of the performance tests re-
quired by §60.8, the opacity observa-
tion results and observer certification
required by §60.11(e)(l], and the
COMS results, if applicable, the Ad-
ministrator will make a finding con-
cerning compliance with opacity and
other applicable standards. If COMS
data results are used to comply with
an opacity standard, only those results
are required to be submitted along
with the performance test results
required by §60.8. If the Administrator
finds that an affected facility is in com-
pliance with all applicable standards
for which performance tests are con-
ducted in accordance with §60.8 of this
part but during the time such perform-
ance tests are being conducted fails to
meet any applicable opacity standard,
he shall notify the owner or operator
and advise him that he may petition
the Administrator within 10 days of re-
ceipt of notification to make appropri-
ate adjustment to the opacity standard
for the affected facility.
[Former 60.11(e)(5) amended and rede-
signated as (6) by 52 FR 9781. March
26, 1987]
(7) The Administrator will grant
such a petition upon a demonstration
by the owner or operator that the af-
fected facility and associated air pollu-
tion control equipment was operated
and .maintained in a manner to mini-
mize the opacity of emissions during
the performance tests; that the per-
formance tests were performed under
the conditions established by the Ad-
ministrator; and that the affected fa-
cility and associated air pollution con-
trol equipment were incapable of
being adjusted or operated to meet the
applicable opacity standard.
[Former 60.11(e)(6) and (7) redesignated
as (7) and (8) by 52 FR 9781, March 26,
1987]
(8) The Administrator will establish
an opacity standard for the affected
facility meeting the above require-
ments at a level at which the source
will be able, as indicated by the per-
formance and opacity tests, to meet
the opacity standard at all times
during which the source is meeting
the mass or concentration emission
standard. The Administrator will pro-
mulgate the new opacity standard in
the FEDERAL REGISTER.
(0 Special provisions set forth under an
applicable subpart of this part shall, super-
sede any conflicting provisions of this
section.
[60.1 l(f) added by 48 FR 48335, October
18, 1983]
§ 60.12 Circumvention.
No owner or operator subject to the
provisions of this part shall build,
erect, install, or use any article, ma-
chine, equipment or process, the use of
which conceals an emission which
would otherwise constitute a violation
of an applicable standard. Such con-
cealment includes, but is not limited
to. the use of gaseous diluents to
achieve compliance with an opacity
standard or with a standard which is
based on the concentration of a pollut-
ant in the gases discharged to the at-
mosphere.
S 60.13 Monitoring requirements.
(a) For the purposes of this section, all
continuous monitoring systems required
under applicable subparts shall be subject
to the provisions of this section upon pro-
mulgation of performance specifications
for continuous monitoring systems under
Appendix B to this part and, if the con-
tinuous monitoring system is used to dem-
onstrate compliance with emission limits
on a continuous basis. Appendix F to this
part, unless otherwise specified in an ap-
plicable subpart or by the Administrator.
Appendix F is applicable December 4,
1987.
[60.13(a] amended by 48 FR 32986, July
20, 1983; revised by 52 FR 21007, June
4, 1987]
(b) All continuous monitoring sys-
tems and monitoring devices shall be
installed and operational prior to con-
ducting performance tests under
§ 60.8. Verification of operational
status shall, as a minimum, include
completion of the manufacturer's writ-
ten requirements or recommendations
for installation, operation, and calibra-
tion of the device.
[60.13(b) revised by 48 FR 23610, May
25, 1983]
(c) If the owner or operator of an af-
fected facility elects to submit contin-
ous opacity monitoring system
(COMS) data for compliance with the
opacity standard as provided under
§ 60.11(e)(5), he shall conduct a per-
formance evaluation of the COMS as
specified in Performance Specification
1, Appendix B, of this part before the
performance test required under § 60.8
is conducted. Otherwise, the owner or
operator of an affected facility shall
conduct a performance evaluation of
the COMS or continuous emission
monitoring system (CEMS) during any
performance test required under $ 60.8
or within 30 days thereafter In accord-
ance with the applicable performance
specification in Appendix B of this
part. The owner or operator of an af-
fected facility shall conduct COMS or
CEMS performance evaluations at
such other times as may be required
by the Administrator under section
114 of the Act.
B-7
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(1) The owner or operator of an af-
fected facility using a COM3 to deter-
mine opacity compliance during any
performance test required under §60.8
and as described in §60.11(e)(5) shall
furnish the Administrator two or, upon
request, more copies of a written re-
port of the results of the COMS per-
formance evaluation described in para-
graph (c) of this section at least 10 days
before the performance test required
under §60.8 is conducted.
(2) Except as provided in paragraph
(c)(l) of this section, the owner or oper-
ator of an affected facility shall furnish
the Administrator within 60 days of
completion two or, upon request, more
copies of a written report of the results
of the performance evaluation.
(60.13(c) revised by 52 FR 9781. March 26,
1987]
(d)(l) Owners and operators of all
continuous emission monitoring sys-
tems installed in accordance with the
provisions of this part shall check the
zero ior low-level value between 0 and
20 PI room of span value) and span (50
to 100 percent of span value) calibra-
tion drifts at least once daily in ac-
cordance with a written procedure.
The zero and span shall, as a mini-
mum, be adjusted whenever the 24-
hour zero drift or 24-hour span drift
exceeds two times the limits of the ap-
plicable performance specifications in
Appendix B. The system must allow
the amount of excess zero and span
drift measured at the 24-hour interval
checks to be recorded and quantified,
whenever specified. For continuous
monitoring systems measuring opacity
of emissions, the optical surfaces ex-
posed to the effluent gases shall be
cleaned prior to performing the zero
and span drift adjustments except
that for systems using automatic zero
adjustments. The optical surfaces
shall be cleaned when the cumulative
automatic zero compensation exceeds
4 percent opacity.
(2) Unless otherwise approved by the
Administrator, the following proce-
dures shall be followed for continuous
monitoring systems measuring opacity
of emissions. Minimum procedures
shall include a method for producing a
simulated zero opacity condition and
an upscale (span) opacity condition
using a certified neutral density filter
or other related technique to produce
a known obscuration of the light
beam. Such procedures shall provide a
system check of the analyzer internal
optical surfaces and all electronic cir-
cuitry including the lamp and photo-
detector assembly.
[60.13(d) revised by 48 FR 23610, May
25, 1983]
(60.l3(e) revised by 48 FR 32986, July
20, 1983]
(e) Except for system breakdowns
repairs, calibration checks, and zero
and span adjustments required under
paragraph (d) of this section, all con-
tinuous monitoring systems shall be in
continuous operation and shall meet
minimum frequency of operation re-
quirements as follows:
(1) All continuous monitoring sys-
tems referenced by paragraph (c) of
this section for measuring opacity of
emissions shall complete a minimum
of one cycle of sampling and analyzing
for each successive 10-second period
and one cycle of data recording for
each successive 6-minute period.
(2) All continuous monitoring sys-
tems referenced by paragraph (c) ol
this section for measuring emissions.
except opacity, shall complete a mini-
mum of one cycle of operation (sam-
pling, analyzing, and data recording)
for each successive 15-minute period.
(f) All continuous monitoring sys-
tems or monitoring devices shall be in-
stalled such that representative mea-
surements of emissions or process pa-
rameters from the affected facility are
obtained. Additional procedures for lo-
cation of continuous monitoring sys-
tems contained in the applicable Per-
formance Specifications of Appendix
B of this part shall be used.
(60.l3(g) and (h) revised by 48 FR
13326, March 30, 1983]
(g) When the effluents from a single
affected facility or two or more affect-
ed facilities subject to the same emis-
sion standards are combined before
being released to the atmosphere, the
owner or operator may install applica-
ble continuous monitoring systems on
each effluent or on the combined ef-
fluent. When the affected facilities are
not subject to the same emission
standards, separate continuous moni-
toring systems shall be installed on
each effluent. When the effluent from
one affected facility is released to the
atomosphere through more than one
point, the owner or operator shall in-
stall an applicable continuous moni-
toring system on each separate efflu-
ent unless the installation of fewer
systems is approved by the Adminis-
trator. When more than one continu-
ous monitoring system is used to meas-
ure the emissions from one affected
facility (e.g., multiple breechings, mul-
tiple outlets), the owner or operator
shall report the results as required
from each continous monitoring
system.
(h) Owners or operators of all con-
tinuous monitoring systems for meas-
urement of opacity shall reduce all
data to 6-minute averages and for con-
tinuous monitoring systems other
than opacity to 1-hour averages for
time periods as defined in § 60.2. Six-
minute opacity averages shall be cal-
culated from 36 or more data points
equally spaced over each 6-minute
period. For continuous monitoring sys-
tems other than opacity, 1-hour aver-
ages shall be computed from four or
more data points equally spaced over
each 1-hour period. Data recorder
during periods of continuous monitor-
ing system breakdowns, repairs, cali-
bration checks, and zero and span ad-
justments shall not be included in the
data averages computed under this
paragraph. An arithmetic or integrat-
ed average of all data may be used.
The data may be recorded in reduced
or nonreduced form (e.g., ppm pollut-
ant and percent O, or ng/J of pollut-
ant). All excess emissions shall be con-
verted into units of the standard using
the applicable conversion procedures
specified in subparts. After conversion
into units of the standard, the data
may be rounded to the same number
of significant digits as used in the ap-
plicable subparts to specify the emis-
sion limit (e.g., rounded to the nearest
1 percent opacity).
(i) After receipt and consideration of
written application, the Administrator
may approve alternatives to any moni-
toring procedures or requirements of
this part including, but not limited to
the following:
(1) Alternative monitoring require-
ments when installation of a continu-
ous monitoring system or monitoring
device specified by this part would not
provide accurate measurements due to
liquid water or other interferences
caused by substances with the effluent
gases.
B-8
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(2) Alternative monitoring require-
ments when the affected facility is in-
frequently operated.
(3) Alternative monitoring require-
ments to accommodate continuous
monitoring systems that require addi-
tional measurements to correct for
stack moisture conditions.
(4) Alternative locations for install-
ing continuous monitoring systems or
monitoring devices when the owner or
operator can demonstrate that instal-
lation at alternate locations will
enable accurate and representative
measurements.
(5) Alternative methods of convert-
ing pollutant concentration measure-
ments to units of the standards.
(6) Alternative procedures for per-
forming daily checks of zero and span
drift that do not involve use of span
gases or test cells.
(7) Alternatives to the A.S.T.M. test
methods or sampling procedures speci-
fied by any subpart.
(8) Alternative continuous monitor-
ing systems that do not meet the
design or performance requirements in
Performance Specification 1, Appen-
dix B, but adequately demonstrate a
definite and consistent relationship
between its measurements and the
measurements of opacity by a system
complying with the requirements in
Performance Specification 1. The Ad-
ministrator may require that such
demonstration be performed for each
affected facility.
(9) Alternative monitoring require-
ments when the effluent from a single
affected facility or the combined efflu-
ent from two or more affected facili-
ties are released to the atmosphere
through more than one point.
[60.130) added by 52 FR 17555, May 11,
1987]
(j) An alternative to the relative ac-
curacy test specified in Performance
Specification 2 of Appendix B may be
requested as follows:
(1) An alternative to the reference
method tests for determining relative
accuracy is available for sources with
emission rates demonstrated to be less
than 50 percent of the applicable
standard. A source owner or operator
may petition the Administrator to
waive the relative accuracy test in sec-
tion 7 of Performance Specification 2
and substitute the procedures in sec-
tion 10 if the results of a performance
test conducted according to the re-
quirements in § 60.8 of this subpart or
other tests performed following the
criteria in I 60.8 demonstrate that the
emission rate of the pollutant of inter-
est in the units of the applicable
standard is less than 50 percent of the
applicable standard. For sources sub-
ject to standards expressed as control
efficiency levels, a source owner or op-
erator may petition the Administrator
to waive the relative accurancy test
and substitute the procedures in sec-
tion 10 of Performance Specification 2
if the control device exhaust emission
rate is less than 50 percent of the level
needed to meet the control efficiency
requirement. The alternative proce-
dures do not apply if the continuous
emission monitoring system is used to
determine compliance continuously
with the applicable standard. The pe-
tition to waive the relative accurancy
test shall include a detailed descrip-
tion of the procedures to be applied.
Included shall be location and proce-
dure for conducting the alternative,
the concentration or response levels of
the alternative RA materials, and the
other equipment checks included in
the alternative procedure. The Admin-
istrator will review the petition for
completeness and applicability. The
determination to grant a waiver will
depend on the intended use of the
CEMS data (e.g., data collection pur-
poses other than NSPS) and may re-
quire specifications more stringent
than in Performance Specification 2
(e.g., the applicable emission limit is
more stringent than NSPS).
(2) The waiver of a CEMS relative
accuracy test will be reviewed and may
be rescinded at such time following
successful completion of the alterna-
tive RA procedure that the CEMS
data indicate the source emissions ap-
proaching the level of the applicable
standard. The criterion for reviewing
the waiver is the collection of CEMS
data showing that emissions have ex-
ceeded 70 percent of the applicable
standard for seven, consecutive, aver-
aging periods as specified by the appli-
cable regulation(s). For sources sub-
ject to standards expressed as control
efficiency levels, the criterion for re-
viewing the waiver is the collection of
CEMS data showing that exhaust
emissons have exceeded 70 percent of
the level needed to meet the control
efficiency requirement for seven, con-
secutive, averaging periods as specified
by the applicable regulation(s) (e.g..
560.45(g) (2) and (3). § 60.73(e), and
§ 60.84(e)L It is the responsibility of
the source operator to maintain
records and determine the level of
emissions relative to the criterion on
the waiver of relative accuracy testing.
If this criterion is exceeded, the owner
or operator must notify the Adminis-
trator within 10 days of such occur-
rence and include a description of the
nature and cause of the increasing
emissions. The Administrator will
review the notification and may re-
scind the waiver and require the
owner or operator to conduct a rela-
tive accuracy test of the CEMS as
specified in section 7 of Performance
Specification 2.
§ 60.14 Modification.
(a) Except as provided under para-
graphs (e) and (f) of this section, any
physical or operational change to an
existing facility which results in an in-
crease in the emission rate to the at-
mosphere of any pollutant to which a
standard applies shall be considered a
modification within the meaning of
section 111 of the Act. Upon modifica-
tion, an existing facility shall bc-come
an affected facility for each pollutant
to which a standard applies and for
which there is an increase in the emis-
sion rate to the atmosphere.
(b) Emission rate shall be expressed
as kg/hr of any pollutant discharged
into the atmosphere for which a
standard is applicable. The Adminis-
trator shall use the following to deter-
mine emission rate:
(1) Emission factors as specified in
the latest issue of "Compilation of Air
Pollutant Emission Factors," EPA
Publication No. AP-42, or other emis-
sion factors determined by the Admin-
istrator to be superior to AP-42 emis-
sion factors, in cases where utilization
of emission factors demonstrate that
the emission level resulting from the
physical or operational change will
either clearly increase or clearly not
increase.
(2) Material balances, continuous
monitor data, or manual emission tests
in cases where utilization of emission
factors as referenced in paragraph (b)
(1) of this section does not demon-
strate to the Administrator's satisfac-
tion whether the emission level result-
ing from the physical or operational
change will either clearly increase or
B-9
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clearly not increase, or where an
owner or operator demonstrates to the
Administrator's satisfaction that there
are reasonable grounds to dispute the
result obtained by the Administrator
utilizing emission factors as referenced
in paragraph (b)(l) of this section.
When the emission rate is based on re-
sults from manual emission tests or
continuous monitoring systems, the
procedures specified in Appendix C of
this part shall be used to determine
whether an increase in emission rate
has occurred. Tests shall be conducted
under such conditions as the Adminis-
trator shall specify to the owner or op-
erator based on representative per-
formance of the facility. At least three
valid test runs must be conducted
before and at least three after the
physical or operational change. All op-
erating parameters which may affect
emissions must be held constant to the
maximum feasible degree for all test
runs.
(5) An estimate of the fixed capital cost
of the replacements and of constructing a
comparable entirely new facility.
(6) The estimated life of the existing
facility after the replacements.
(7) A discussion of any economic or
technical limitations the facility may have
in complying with the applicable stan-
dards of performance after the proposed
replacements.
(e) The Administrator will determine,
within 30 days of the receipt of the notice
required by paragraph (d) of this section
and any additional information he may
reasonably require, whether the proposed
replacement constitutes reconstruction.
(0 The Administrator's determination
under paragraph (e) shall be based on:
(1) The fixed capital cost of the replace-
ments in comparison to the fixed capital
cost that would be requi"ed to
construct a comparable entirely new
facility;
(2) The estimated life of the facility
after the replacements compared to
the life of a comparable entirely new
facility;
(3) The extent to which the compo-
nents being replaced cause or contrib-
ute to the emissions from the facility;
and
(4) Any economic or technical limita-
i.ions on compliance with applicable
standards of performance which are
inherent in the proposed replace-
ments.
(g) Individual subparts of this part
may include specific provisions which
refine and delimit the concept of re-
construction set forth in this section.
B-10
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APPENDIX C
EPA METHOD 9 - VISUAL DETERMINATION
OF EMISSIONS FROM STATIONARY SOURCES
C-1
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40 CFR Ch. I (7-1-88 Edition)
METHOD 9—VISUAL DETERMINATION or THE
OPACITY or EMISSIONS FROM STATIONARY
SOURCES
Many stationary sources discharge visible
emissions into the atmosphere; these emis-
sions are usually in the shape of a plume.
This method involves the determination of
plume opacity by qualified observers. The
method includes procedures for the training
and certification of observers, and proce-
dures to be used in the field for determina-
tion of plume opacity. The appearance of a
plume as viewed by an observer depends
upon a number of variables, some of which
may be controllable and some of which may
not be controllable in the field. Variables
which can be controlled to an extent to
which they no longer exert a significant iiu
fluence upon plume appearance include:
Angle of the observer with respect to the
plume; angle of the observer with respect to
the sun; point of observation of attached
and detached steam plume; and angle of the
observer with respect to a plume emitted
from a rectangular stack with a large length
to width ratio. The method includes specific
criteria applicable to these variables.
Other variables which may not be control-
lable in the field are luminescence and color
contrast between the plume and the back-
ground against which the plume is viewed.
These variables exert an influence upon the
appearance of a plume as viewed by an ob-
server, and can affect the ability of the ob-
server to accurately assign opacity values to
the observed plume. Studies of the theory
of plume opacity and field studies have
demonstrated that a plume is most visible
and presents the greatest apparent opacity
when viewed against a contrasting back-
ground. It follows from this, and is con-
firmed by field trials, that the opacity of a
plume, viewed under conditions where a
contrasting background is present can be as-
signed with the greatest degree of accuracy.
However, the potential for a positive error is
also the greatest when a plume is viewed
under such contrasting conditions. Under
conditions presenting a less contrasting
background, the apparent opacity of a
plume is less and approaches zero as the
color and luminescence contrast decrease
toward zero. As a result, significant negative
bias and negative errors can be made when
a plume is viewed under less contrasting
conditions. A negative bias decreases rather
than increases the possibility that a plant
operator will be cited for a violation of opac-
ity standards due to observer error.
Studies have been undertaken to deter-
mine the magnitude of positive errors which
can be made by qualified observers while
reading plumes under contrasting condi-
tions and using the procedures set forth in
this method. The results of these studies
C-2
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Environmental Protection Agency
(field trials) which involve a total of 769 sets
of 25 readings each are as follows:
(1) For black plumes (133 sets at a smoke
generator). 100 percent of the sets were read
with a positive error' of less than 7.5 per-
cent opacity; 99 percent were read with a
positive error of less than 5 percent opacity.
(2) For white plumes (170 sets at a smoke
generator, 168 sets at a coal-fired power
plant, 298 sets at a sulfurlc acid plant), 99
percent of the sets were read with a positive
error of less than 7.5 percent opacity; 95
percent were read with a positive error of
less than 5 percent opacity.
The positive observational error associat-
ed with an average of twenty-five readings is
therefore established. The accuracy of the
method must be taken into account when
determining possible violations of applicable
opacity standards.
1. Principle and Applicability
1.1 Principle. The opacity of emissions
from stationary sources is determined visu-
ally by a qualified observer.
1.2 Applicability. This method is applica-
ble for the determination of the opacity of
emissions from stationary sources pursuant
to { 60.11(b) and for qualifying observers for
visually determining opacity of emissions.
2. Procedures
The observer qualified in accordance with
paragraph 3 of this method shall use the
following procedures for visually determin-
ing the opacity of emissions:
2.1 Position. The qualified observer shall
stand at a distance sufficient to provide a
clear view of the emissions with the sun ori-
ented in the 140* sector to his back. Consist-
ent with maintaining the above require-
ment, the observer shall, as much as possi-
ble, make his observations from a position
such that his line of vision is approximately
perpendicular to the plume direction, and
when observing opacity of emissions from
rectangular outlets (e.g., roof monitors,
open baghouses, noncircular stacks), ap-
proximately perpendicular to the longer
axis of the outlet. The observer's line of
sight should not include more than one
plume at a time when multiple stacks are in-
volved, and in any case the observer should
make his observations with his line of sight
perpendicular to the longer axis of such a
set of multiple stacks (e.g., stub stacks on
baghouses).
2.2 Field Records. The observer shall
record the name of the plant, emission loca-
tion, type facility, observer's name and af-
filiation, a sketch of the observer's position
relative to the source, and the date on a
* For a set, positive error = average opaci-
ty determined by observers' 25 observa-
tions—average opacity determined from
transmissometer's 25 recordings.
Pt. 60, App. A, Meth. 9
field data sheet (Figure 9-1). The time, esti-
mated distance to the emission location, ap-
proximate wind direction, estimated wind
speed, description of the sky condition
(presence and color of clouds), and plume
background are recorded on a field data
sheet at the time opacity readings are Initi-
ated and completed.
2.3 Observations. Opacity observations
shall be made at the point of greatest opaci-
ty in that portion of the plume where con-
densed water vapor is not present. The ob-
server shall not look continuously at the
plume, but instead shall observe the plume
momentarily at 15-second intervals.
2.3.1 Attached Steam Plumes. When con-
densed water vapor is present within the
plume as it emerges from the emission
outlet, opacity observations shall be made
beyond the point in the plume at which con-
densed water vapor is no longer visible. The
observer shall record the approximate dis-
tance from the emission outlet to the point
in the plume at which the observations are
made.
2.3.2 Detached Steam Plume. When water
vapor in the plume condenses and becomes
visible at a distinct distance from the emis-
sion outlet, the opacity of emissions should
be evaluated at the emission outlet prior to
the condensation of water vapor and the
formation of the steam plume.
2.4 Recording Observations. Opacity ob-
servations shall be recorded to the nearest 5
percent at 15-second intervals on an obser-
vational record sheet. (See Figure 9-2 for an
example.) A minimum of 24 observations
shall be recorded. Each momentary observa-
tion recorded shall be deemed to represent
the average opacity of emissions for a 15-
second period.
2.5 Data Reduction. Opacity shall be de-
termined as an average of 24 consecutive ob-
servations recorded at 15-second intervals.
Divide the observations recorded on the
record sheet into sets of 24 consecutive ob-
servations. A set is composed of any 24 con-
secutive observations. Sets need not be con-
secutive in time and in no case shall two sets
overlap. For each set of 24 observations, cal-
culate the average by summing the opacity
of the 24 observations and dividing this sum
by 24. If an applicable standard specifies an
averaging time requiring more than 24 ob-
servations, calculate the average for all ob-
servations made during the specified time
period. Record the average opacity on a
record sheet. (See Figure 9-1 for an exam-
ple.)
3. Qualifications and Testing
3.1 Certification Requirements. To receive
certification as a qualified observer, a candi-
date must be tested and demonstrate the
ability to assign opacity readings in 5 per-
cent increments to 25 different black
C-3
-------
Pt. 60, App. A, M«th. 9
40 CFR Ch. I (7-1-88 Edition)
plumes and 25 different white plumes, with
an error not to exceed 15 percent opacity on
any one reading and an average error not to
exceed 7.5 percent opacity in each category.
Candidates shall be tested according to the
procedures described in paragraph 3.2.
Smoke generators used pursuant to para-
graph 3.2 shall be equipped with a smoke
meter which meets the requirements of
paragraph 3.3.
The certification shall be valid for a
period of 6 months, at which time the quali-
fication procedure must be repeated by any
observer in order to retain certification.
3.2 Certification Procedure. The certifica-
tion test consists of showing the candidate a
complete run of 50 plumes—25 black plumes
and 25 white plumes—generated by a smoke
generator. Flumes within each set of 25
black and 25 white runs shall be presented
in random order. The candidate assigns an
opacity value to each plume and records his
observation on a suitable form. At the com-
pletion of each run of 50 readings, the score
of the candidate is determined. If a candi-
date fails to qualify, the complete run of 50
readings must be repeated in any retest.
The smoke test may be administered as part
of a smoke school or training program, and
may be preceded by training or familiariza-
tion runs of the smoke generator during
which candidates are shown black and white
plumes of known opacity.
- 3.3 Smoke Generator Specifications. Any
smoke generator used for the purposes of
paragraph 3.2 shall be equipped with a
smoke meter installed to measure opacity
across the diameter of the smoke generator
stack. The smoke meter output shall display
instack opacity based upon a pathlength
equal to the stack exit diameter, on a full 0
to 100 percent chart recorder scale. The
smoke meter optical design and perform-
ance shall meet the specifications shown in
Table 9-1. The smoke meter shall be cali-
brated as prescribed in paragraph 3.3.1 prior
to the conduct of each smoke reading test.
At the completion of each test, the zero and
span drift shall be checked and if the drift
exceeds ±1 percent opacity, the condition
shall be corrected prior to conducting any
subsequent test runs. The smoke meter
shall be demonstrated, at the time of instal-
lation, to meet the specifications listed in
Table 9-1. This demonstration shall be re-
peated following any subsequent repair or
replacement of the photocell or associated
electronic circuitry including the chart re-
corder or output meter, or every 6 months,
whichever occurs first.
TABLE 9-1—SMOKE METER DESIGN AND
PERFORMANCE SPECIFICATIONS
Parameter
a. Light source
b. Spectral response of
photocell.
c. Angle of view
d. Angle of projection—
e. Calibration error
f. Zero and span drift —
g. Response time
Specification
Incandescent lamp operated at
nominal rated voltage.
Photopic (dayNght spectral re-
sponse of the human eye-
reference 4.3).
15* maximum total angle.
15* maximum total angle.
±3% opacity, maximum.
±1% opacity, 30 minutes
5 seconds.
3.3.1 Calibration. The smoke meter is cali-
brated after allowing a minimum of 30 min-
utes warmup by alternately producing simu-
lated opacity of 0 percent and 100 percent.
When stable response at 0 percent or 100
percent is noted, the smoke meter is adjust-
ed to produce an output of 0 percent or 100
percent, as appropriate. This calibration
shall be repeated until stable 0 percent and
100 percent readings are produced without
adjustment. Simulated 0 percent and 100
percent opacity values may be produced by
alternately switching the power to the light
source on and off while the smoke generator
is not producing smoke.
3.3.2 Smoke Meter Evaluation. The smoke
meter design and performance are to be
evaluated as follows:
3.3.2.1 Light Source. Verify from manufac-
turer's data and from voltage measurements
made at the lamp, as installed, that the
lamp is operated within ±5 percent of the
nominal rated voltage.
3.3.2.2 Spectral Response of Photocell.
Verify from manufacturer's data that the
photocell has a photopic response; i.e., the
spectral sensitivity of the cell shall closely
approximate the standard spectral-luminosi-
ty curve for photopic vision which is refer-
enced in (b) of Table 9-1.
C-4
-------
FIQME f-1
KCOUD QP VtSQ*. DETERHINATION OF OPACITY
LOCATION
TEST NUMBER.
DATE
TYPE FACILITY^
CO.ITROL oevice.
HOURS OF OISCRWTIOH.
08SCWCT "
OtStltVER CERTIFICATION MTC.
OBSCTYEH AFFILIATION
POIKT OF CMISS10HS
HEIGHT OF OISCMME FOINT
O
cn
CLOCK TDK
OBSERVE* LOCATION
Distance to Dfsctergt
Direction fro* Discharge
Height of Observation Point
BACKGROUND DESCRIPTION
NEATKER CONDITIONS
Wind Direction
Wind Speed
Anbicnt Temperature
SKY CONDITIONS (clear.
overcast. % clouds, etc.)
PLUME DESCRIPTION
Color
Distance Visible
CTHCR INFOPJIATtON
nititl
Ftnal
SUMMARY OF AVERAGE OPACITY
Set
iMber
TtM
Start-End
Ooacity
SM
Average
Readings ranged fro* to ... I opacity
The source was/was not in conpllance vtth
the time evaluation Mas made.
S
•o
•
«o
-------
Pt. 60, App. A, Moth. 9
40 CFR Ch. I (7-1-88 Edition)
Company...
Location.....
TestNumbi
Date
FIGURE 9-2—OBSERVATION RECORD
Page of •
Observer ..................
Type facility
Point of emissions—
Hr.
Mia
0
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
Seconds
0
15
30
45
Steam plume (check if applicable)
Attached
Detached
Comments
C-6
-------
Environmental Protection Agency
Pt. 60, App. A, Moth. 9
FIGURE 9-2—OBSERVATION RECORD—(CONTINUED)
Page of
Company.
Location..
Test Number..
Date.™
Observer..
Type facility
Point of emissions..
Hr.
Min.
30
31
32
33
34
35
36
37
38
39
40
41
48
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
Seconds
0
15
30
45
Steam plume (check If applicable)
Attached
Detached
ConuviGnts
3.3.2.3 Angle of View. Check construction
geometry to ensure that the total angle of
view of the smoke plume, as seen by the
photocell, does not exceed 15*. The total
angle of view may be calculated from: 0= 2
tan~>d/2L, where 0=total angle of view;
d-the sum of the photocell diameter-t-the
diameter of the limiting aperture; and
C-7
-------
Pt. 60, App. A, Alt. M«th.
L=the distance from the photocell to the
limiting aperture. The limiting aperture is
the point in the path between the photocell
and the smoke plume where the angle of
view is most restricted. In smoke generator
smoke meters this is normally an orifice
plate.
3.3.2.4 Angle of Projection. Check con-
struction geometry to ensure that the total
angle of projection of the lamp on the
smoke plume does not exceed 15*. The total
angle of projection may be calculated from:
0=2 tan~ H1/2L, where 0= total angle of pro-
jection; d= the sum of the length of the
lamp filament + the diameter of the limit-
ing aperture; and L— the distance from the
lamp to the limiting aperture.
3.3.2.5 Calibration Error. Using neutral-
density filters of known opacity, check the
error between the actual response and the
theoretical linear response of the smoke
meter. This check is accomplished by first
calibrating the smoke meter according to
3.3.1 and then inserting a series of three
neutral-density filters of nominal opacity of
20, 50, and 75 percent in the smoke meter
pathlength. Filters calibrated within ±2
percent shall be used. Care should be taken
when inserting the filters to prevent stray
light from affecting the meter. Make a total
of five nonconsecutive readings for each
filter. The maximum error on any one read-
ing shall be 3 percent opacity.
3.3.2.6 Zero and Span Drift. Determine
the zero and span drift by calibrating and
operating the smoke generator in a normal
manner over a 1-hour period. The drift is
measured by checking the zero and span at
the end of this period.
3.3.2.7 Response Time. Determine the re-
sponse time by producing the series of five
simulated 0 percent and 100 percent opacity
values and observing the time required to
reach stable response. Opacity values of 0
percent and 100 percent may be simulated
by alternately switching the power to the
light source off and oh while the smoke gen-
erator is not operating.
4. References.
4.1 Air Pollution Control District Rules
and Regulations, Los Angeles County Air
Pollution Control District, Regulation IV,
Prohibitions, Rule 50.
4.2 Weisburd, Melvin I., Field Operations
and Enforcement Manual for Air, U.S. Envi-
ronmental Protection Agency, Research Tri-
angle Park, NC. APTD-110G. August 1972.
pp. 4.1-4.36.
4.3 Condon, E.U., and Odishaw, H.. Hand-
book of Physics. McGraw-Hill Co., New
York. NY. 1958. Table 3.1. p. 6-52.
C-8
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APPENDIX D
EPA METHOD 22 - VISUAL DETERMINATION OF
FUGITIVE EMISSIONS FROM MATERIAL SOURCES
AND SMOKE EMISSIONS FROM FLARES
D-1
-------
METHOD 22—VISUAL DETERMINATION OF FU-
GITIVE EMISSIONS FROM MATERIAL
SOURCES AND SMOKE EMISSIONS FROM
FLARES
1. Introduction
This method Involves the visual determi-
nation of fugitive emissions, i.e., emissions
not emitted directly from a process stack or
duct. Fugitive emissions include emissions
that (1) escape capture by process equip-
ment exhaust hoods; (2) are emitted during
material transfer; (3) are emitted from
buildings housing material processing or
handling equipment; and (4) are emitted di-
rectly from process equipment. This method
is used also to determine visible smoke emis-
sions from flares used for combustion of
waste process materials.
This method determines the amount of
time that any visible emissions occur during
the observation period, i.e.. the accumulated
emission time. This method does not require
that the opacity of emissions be determined.
Since this procedure requires only the de-
termination of whether a visible emission
occurs and does not require the determina-
tion of opacity levels, observer certification
according to the procedures of Method 9 are
not required. However, it is necessary that
the observer is educated on the general pro-
cedures for determining the presence of visi-
ble emissions. As a m<"<"'""". the observer
must be trained and knowledgeable regard-
ing the effects on the visibility of emissions
caused by background contrast, ambient
lighting, observer position relative to light-
Ing, wind, and the presence of uncombined
water (condensing water vapor). This train-
ing is to be obtained from written materials
found in References 7.1 and 7.2 or from the
lecture portion of the Method 9 certifica-
tion course.
2. Applicability and Principle
2.1 Applicability. This method applies to
the determination of the frequency of fugi-
tive emissions from stationary sources (lo-
cated Indoors or outdoors) when specified as
the test method for determining compliance
with new source performance standards.
This method also is applicable for the de-
termination of the frequency of visible
smoke emissions from flares.
2.2 Principle. Fugitive emissions pro-
duced during material processing, handling,
and transfer operations or smoke emissions
from flares are visually determined by an
observer without the aid of Instruments.
3. Definitions
D-2
-------
Pt. 60, App. A, M«th. 22
40 CFR Ch. I (7-1-88 Edition)
3.1 Emission Frequency. Percentage of
time that emissions are visible during the
observation period.
3.2 Emission Time. Accumulated amount
of time that emissions are visible during the
observation period.
3.3 Fugitive Emissions. Pollutant gener-
ated by an affected facility which is not col-
lected by a capture system and Is released to
the atmosphere.
3.4 Smoke Emissions. Pollutant generat-
ed by combustion in a flare and occurring
Immediately downstream of the flame.
Smoke occurring within the flame, but not
downstream of the flame, is not considered
a smoke emission.
3.5 Observation Period. Accumulated
time period during which observations are
conducted, not to be less than the period
specified in the applicable regulation.
4. Equipment
4.1 Stopwatches. Accumulative type with
unit divisions of at least 0.5 seconds; two re-
quired.
4.2 Light Meter. Light meter capable of
measuring Illuminance in the 50- to 200-lux
range; required for indoor observations
only.
5. Procedure
5.1 Position. Survey the affected facility
or building or structure housing the process
to be observed and determine the locations
of potential emissions. If the affected facili-
ty is located inside a building, determine an
observation location that is consistent with
the requirements of the applicable regula-
tion (Le., outside observation of emissions
escaping the building/structure or inside ob-
servation of emissions directly emitted from
the affected facility process unit). Then
select a position that enables a clear view of
the potential emission pointts) of the affect-
ed facility or of the building or structure
housing the affected facility, as appropriate
for the applicable subpart. A position at
least 15 feet, but not more than 0.25 miles,
from the emission source is recommended.
For outdoor locations, select a position
where the sun is not directly in the observ-
er's eyes.
5.2 Field Records.
5.2.1 Outdoor Location. Record the fol-
lowing Information on the field data sheet
(Figure 22-1): company name. Industry,
process unit, observer's name, observer's af-
filiation, and date. Record also the estimat-
ed wind speed, wind direction, and sky con-
dition. Sketch the process unit being ob-
served and note the observer location rela-
tive to the source and the sun. Indicate the
potential and actual emission points on the
sketch.
5.2.2 Indoor Location. Record the follow-
ing Information on the field data sheet
(Figure 22-2): company name, industry.
process unit, observer's name, observer's af-
filiation, and date. Record as appropriate
the type, location, and intensity of lighting
on the data sheet. Sketch the process unit
being observed and note observer location
relative to the source. Indicate the potential
and actual fugitive emission points on the
sketch.
5.3 Indoor Lighting Requirements. For
Indoor locations, use a light meter to meas-
ure the level of illumination at a location as
close to the emission source(s) as is feasible.
An Illumination of greater than 100 lux (10
foot candles) is considered necessary for
proper application of this method.
5.4 Observations. Record the dock time
when observations begin. Use one stopwatch
to monitor the duration of the observation
period; start this stopwatch when the obser-
vation period begins. If the observation
period is divided into two or more segments
by process shutdowns or observer rest
breaks, stop the stopwatch when a break
begins and restart It without resetting when
the break ends. Stop the stopwatch at the
end of the observation period. The accumu-
lated time indicated by this stopwatch Is the
duration of the observation period. When
the observation period is completed, record
the clock time.
During the observation period, continous-
ly watch the emission source. Upon observ-
ing an emission (condensed water vapor is
not considered an emission), start the
second accumulative stopwatch; stop the
watch when the emission stops. Continue
this procedure for the entire observation
period. The accumulated elapsed time on
this stopwatch is the total time emissions
were visible during the observation period.
i.e.. the emission time.
5.4.1 Observation Period. Choose an ob-
servation period of sufficient length to meet
the requirements for determining compli-
ance with the emission regulation in the ap-
plicable subpart. When the length of the ob-
servation period is specifically stated in the
applicable subpart, it may not be necessary
to observe the source for this entire period
if the emission time required to Indicate
noncompliance (based on the specified ob-
servation period) is observed in a shorter
time period. In other words, if the regula-
tion prohibits emissions for more than 6
minutes In any hour, then observations may
(optional) be stopped after an emission time
of 6 minutes is exceeded. Similarly, when
the regulation is expressed as an emission
frequency and the regulation prohibits
emissions for greater than 10 percent of the
time in any hour, then observations may
(optional) be terminated after 6 minutes of
emissions are observed since 6 minutes Is 10
percent of an hour. In any case, the observa-
tion period shall not be less than 6 minutes
In duration. In some cases, the process oper-
ation may be intermittent or cyclic. In such
D-3
-------
Environmental Protection Agency
cases, it may be convenient for the observa-
tion period to coincide with the length of
the process cycle. x
5.4.2 Observer Rest Breaks. Do not ob-
serve emissions continuously for a period of
more than IS to 20 minutes without taking
a rest break. For sources requiring observa-
tion periods of greater than 20 minutes, the
observer shall take a break of not less than
5 minutes and not more than 10 minutes
after every 15 to 20. minutes of observation.
If continuous observations are desired for
extended time periods, two observers can al-
ternate between making observations and
taking breaks.
5.4.3 Visual Interference. Occasionally,
fugitive emissions from sources other than
the affected facility (e.g., road dust) may
prevent a clear view of the affected facility.
This may particularly be a problem during
periods of high wind. If the view of the po-
tential emission points is obscured to such a
degree that the observer questions the va-
lidity of continuing observations, then the
observations are terminated, and the observ-
er clearly notes this fact on the data form.
5.5 Recording Observations. Record the
accumulated time of the observation period
on the data sheet as the observation period
duration. Record the accumulated time
Pt. 60, App. A, Meth. 22
emissions were observed on the data sheet
as the emission time. Record the clock time
the observation period began and ended, as
well as the clock time any observer breaks
began and ended.
6. Calculations
If the applicable subpart requires that the
emission rate be expressed as an emission
frequency (in percent), determine this value
as follows: Divide the accumulated emission
time (in seconds) by the duration of the ob-
servation period (in seconds) or by any mini-
mum observation period required in the ap-
plicable subpart. if the acutal observation
period is less than the required period and
multiply this quotient by 100.
7. References.
7.1 Missan. Robert and Arnold Stein.
Guidelines for Evaluation of Visible Emis-
sions Certification, Field Procedures, Legal
Aspects, and Background Material. EPA
Publication No. EPA-340/1-75-007. April
1975
7.2 Wohlschlegel. P. and D. E. Wagoner.
Guideline for Development of a Quality As-
surance Program: Volume IX—Visual Deter-
mination of Opacity Emissions From Sta-
tionary Sources. EPA Publication No. EPA-
650/4-74-005-i. November 1975.
D-4
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APPENDIX E
SAMPLE INSPECTION FORMS
E-1
-------
Nonmetallic Mineral Processing Plants
- Plant Information -
Plant ID/permit number:
Plant name and address:
Name of plant contact:
Phone: ( ) ext.
Plant mailing address
(if different from plant address):
Owner/operator name and address
(if different from plant name/address):
Owner/operator phone: ( ) ext.
Nonmetalic minerals processed:
Plant portability: D portable D nonportable
Cummulative rated capacity of all initial crushers: tons/year
Plant exempt by plant type/capacity: D yes D no
Plant emission source type: D Al D A2 D B
(particulate matter) (> 100 t/yr actual) (>100t/yr potential) (<100 t/yr actual & potential)
U.S. EPA plant ID number/s (as applicable):
• National Emissions Data System (NEDS)
Aerometric Information Retrieval System (AIRS)
Attach a detailed flow diagram of the plant showing the locations of all potentially
affected and affected facilities under 40 CFR Pan 60, Subpart OOO.
-------
Plant ID:
Facilities list for crushers, grinding mills, bucket elevators, screening operations, conveyor belts,
bagging operations, storage bins, transfer points, and enclosed truck/rail loading stations.
Master List of
Potentially Affected and Affected Facilites
Sownqrpi
(ernibtr, bBdul
•bntor, ilc.)
D«criplkM/loc«lion
or ID nuinbir
(for tm»ltr pobk, IduUT; both
transfer indi - U, Iron ind la)
IUM*
ttpncHr
DnUof
manufacture
(for transfer points,
(InditHforMcli
trtmltr nd)
SubjMtta
40CFRW
SubpvUForl
(Y«Wo)
40CFR60
Sabpu-IOOO
>rrbk
opMitj
standard
(%op.cllr)
Applkibk
auas
itandard
(g/dscm)
* . tons ner hour for crushers, grinding mills, bucket elevators, bagging operations, and enclosed truck/rail loading stations,
- square meters of top screen surface area for screening operations,
- tons for storage bins.
- meters of belt width for conveyor belts.
** - "Yes" response indicates exemption for replacement of existing facility with facility of equal or smaller size.
-------
Initial Performance Test Field Sheet
Date:
Affected facility:
Source ID number:
Sketch of Affected Facility or Transfer Point;
Description/location:
Source enclosed: pi yes pi no
Source controlled: Q yes pi no
If yes, type of control device:
Scrubber AP inches W.G.
^
Scrubber liquid flow rate GPM
VE method employed: Q Method 9 C
Comments:
Method 22
Compliance status: CH compliance EH noncompliance EH not determined (explain in comments)
Attach appropriate VE Observation Form Signature:
Initial Performance Test Field Sheet
Date:
Affected facility: _
Source ID number:
Sketch of Affected Facility or Transfer Point;
Description/location:
no
Source enclosed: pi yes
Source controlled: p| yes pi no
If yes, type of control device:
Scrubber AP inches W.G.
Scrubber liquid flow rate GPM
VE method employed: EH Method 9 E
Comments:
Method 22
Compliance status: EH compliance EH noncompliance EH not determined (explain in comments)
Attach appropriate VE Observation Form Signature:
-------
Affected facility:
Field Inspection Sheet
Date of inspection:
Source ID number:
Comments:
Description/location:
Source enclosed: pi yes pi no
Source controlled: Q yes pi no
If yes, type of control device:
Scrubber AP inches W.G.
Scrubber liquid flow rate GPM
Baghouse AP
inches W.G.
Bag cleaning: Q operative Q inoperative
VE method employed: CH Method 9 d Method 22 Attach appropriate VE Observation Form
Compliance status: [H comph'ance [H noncompliance Q not determined (explain in comments)
Inspector's signature:
Affected facility:
Field Inspection Sheet
Date of inspection:
Source ID number:
Comments:
Description/location:
Source enclosed: pi yes pi no
Source controlled: r~\ yes pi no
If yes, type of control device:
Scrubber AP inches W.G.
Scrubber liquid flow rate GPM
Baghouse AP
inches W.G.
Bag cleaning: Q operative Q inoperative
VE method employed: Q Method 9 D Method 22 Attach appropriate VE Observation Form
Compliance status: D compliance D noncompliance Q not determined (explain in comments)
Inspector's signature:
-------
APPENDIX F
SAMPLE INSPECTION REPORT
F-1
-------
LEVEL II COMPLIANCE INSPECTION OF
BREAKSTONE LIMESTONE COMPANY
ANYWHERE, USA
Inspection Date: January 5, 1990
Inspector: Joe Brown
Inspection Report Date: January 10, 1990
F-2
-------
INSPECTION PROCEDURES AND CONCLUSIONS
Procedures
On January 5, 1990, an inspection was conducted at Breakstone Limestone Co.
for the purpose of determining compliance of the plant's affected facilities under 40
CFR 60, Subpart OOO. The inspection was unannounced and one of several
inspections of nonmetallic mineral processing facilities in the State.
Entry into the plant was gained without difficulty at 9:00 a.m. Mr. John Smith,
Environmental Manager, acted as the official plant representative and also served as
plant escort for the inspection.
Company records concerning the NSPS affected facilities at this site were
inspected. The following written notifications to the EPA Administrator for each
affected facility were checked and found to meet all regulatory requirements:
0 Date of construction
0 Dates of anticipated and actual startup
0 Date of anticipated initial performance test opacity observations
0 Thirty day advance notice of all compliance tests
Notification for 1) proposed replacements of existing facilities with facilities of equal or
smaller size, 2) proposed reconstructions of existing facilities, and 3) notifications of
modification of existing facilities pursuant to the provisions of §60.14(e) were not
applicable to any existing facility at the plant at the time of inspection.
The following written reports to the EPA Administrator for each affected facility
were checked and found to meet all regulatory requirements:
0 All performance test results and results of all performance test opacity
observations
The following records on file at the plant were checked and found to meet all
regulatory requirements:
F-3
-------
0 Startup, shutdown and malfunction reports
Because no affected facility at this plant is served by a wet scrubber, the
reporting and recordkeeping requirements for wet scrubbers pursuant to Subparts A
and OOO are not applicable.
Because no emission problems were observed outside of the plant boundary
during pre-entry observations, the field inspection began at 10:00 a.m. at the primary
crusher and proceeded through the process flow to the two bagging machines.
During the inspection the plant was operating at a rate of 275 tons/h, which is below
the operating rate recorded for the last compliance test. All existing facilities on the
master list were still operating on site. No modifications to existing facilities were
observed and no new equipment was apparent.
NSPS Sources
Both transfer points from belt conveyor No. 13 were observed. Material
conveyed was of sufficient moisture to prevent visible emissions. Therefore, these
transfer points were in compliance with the NSPS opacity limit.
The Ty-Rock screen No. 20 was observed using EPA Method 9 for 18 minutes,
the highest average 6-minute observation period opacity was 0 percent. The No. 20
screen was in compliance with the NSPS opacity limit.
The building enclosing the No. 25 Raymond mill was observed for 20 minutes
employing EPA Method 22 with no visible emissions observed. The cyclone air
separator serving the No. 25 Raymond mill was observing using EPA Method 9 for 18
minutes. The highest average 6-minute observation period opacity was 0 percent. No
fallout near the discharge of the cyclone was evident. The stack of the baghouse
serving the No. 25 Raymond mill was likewise observed using EPA Method 9 for 18
minutes with a highest average 6-minute observation period opacity of 0 percent. The
pulse-jet baghouse was inspected externally; all diaphragm valves were operating and
air reservoir pressure was comparable to that of the last compliance test. No
evidence of breaches in shell integrity were observed. Pressure drop across the
baghouse was recorded at 4.0 in. W.G. indicating proper operation.
F-4
-------
Product storage bin No. 46 was observed during three unloading cycles. The
stack of the storage bin baghouse was observed for a total of 40 minutes with two
sets of consecutive 6 minute observations recorded during the two unloading cycles.
The highest average 6-minute observation period opacity was 25 percent. During the
two unloading cycles, stack emissions were characterized by cyclic puffs indicating the
possibility of a hole(s) in bags. Pressure drop was recorded across the baghouse at
2.5 in. W.G. which is low for this type of pulse-jet baghouse and 2 in. W.G. below the
average pressure drop recorded during the last compliance test. Air reservoir
pressure was normal and all diaphragm valves appeared to be operable. No
breaches in shell integrity were observed.
Conclusions
The following conclusions are drawn from the inspection:
0 Transfer points on the No. 13 belt conveyor were in compliance with the
NSPS opacity standard
0 The No. 20 Ty-Rock screen was in compliance with the NSPS opacity
standard
0 Emissions from the No. 25 Raymond mill building, cyclone air separator, and
baghouse were in compliance with the NSPS opacity standard
0 Emissions from the baghouse serving the No. 46 storage bin were not in
compliance with the NSPS opacity standard
0 All existing facilities on the master list were on site and showed no
indications of modifications that would increase particulate matter emissions
0 No new equipment that would be subject to the NSPS were observed on the
plant property
All notifications, reports, and records required by the NSPS were available at
the plant upon request and met all NSPS requirements.
F-5
-------
Nonmetallic Mineral Processing Plants
- Plant Information -
Plant ID/permit number: f\ 0
Plant name and address: [Bur A
/v
oy
Name of plant contact:
Phone:
ext.
Plant mailing address
(if different from plant address):
Owner/operator name and address
(if different from plant name/address):
h. ~3 *
Owner/operator phone: ( )
Nonmetalic minerals processed:
ext.
Plant portability: D portable IS nonportable
Cummulative rated capacity of all initial crushers:
Plant exempt by plant type/capacity: D yes
X 10 tons/year
no
Plant emission source type: 12 A 1
(paniculate matter) (> 100 t/yr actual)
D A2 D B
(> 100 t/yr potential) (<100 t/yr actual & potential)
U.S. EPA plant ID number/s (as applicable):
• National Emissions Data System (NEDS)
Aerometric Information Retrieval System (AIRS)
Attach a detailed flow diagram of the plant showing the locations of all potentially
affected and affected facilities under 40 CFR Part 60, Subpart OOO.
-------
-------
Plant ID:
Facilities list for crushers, grinding mills, bucket elevators, screening operations, conveyor belts,
bagging operations, storage bins, transfer points, and enclosed truck/rail loading stations.
Master List of
Potentially Affected and Affected Facilites
(crahtr.biicktt
•Itralor, tic.)
/S**/^*
Sc~,*
*°','r
t;T
£>usAe«-
Y
&£.»
* ~ tons P.GT hour
- square meters
orn>D«mb«r
(Tor truihr potato, ld.»ttlj both
InuihriBdi -U, fraud to)
At*. )3
AS*. 10
AJo.^
*0.+<>
Pown^y
AJo. 01
At*. 62
KM**
c*«clrr
ff.1l
to, S'
100
-7*0
4F/.4T,
120
o.-i<*
DtUof
mmufacluri
(forlmtfarpolak,
|)Tid«u< for rack
PtfFi.
n*r
n*f
/yw
/
nn.
If 70
SobjKtla
4«CFR<0
SubpvtiForl
'c^rab
MO
A/0
A/
/HOblF
AJC)
#0
Emk»loiK
nnUdtofbck
or pow«r»d vtnt
es
^v(s
AJO
V£S
yes
f£~£> 0&
.A/0
w
Control
d«rlc«ljpi
Pfq>pllobl>)
AJ C? V^
A/~
>P/5/J>"A fer- AfCr
bAf/*0 t4f G
0 /Vg'
AU*&
0 109 9/*"f iS*» ^V*
t/» w a 4 /Gi$ Cr/>ft
A/
-------
Affected facility: .
Source ID number:
Field Inspection Sheet
^YO^ Date of inspection:
/Jo.
Comments:
Sn FT"''O-CA/T
Description/location:
f xV>o i's S
(J
Source enclosed: r—i yes
Source controlled: |~] yes
If yes, type of control device:
no
no
Scrubber AP inches W.G.
Scrubber liquid flow rate GPM
Baghouse AP
inches W.G.
Bag cleaning: Q operative Q inoperative
VE method employed: £3 Method 9 C] Method 22 Attach appropriate VE Observation Form
Compliance status: E3 compliance CD noncompliance CD not determined (explain in comments)
r D
Inspector's signature: $^
Field Inspection Sheet
Affected facility: .
Source ID number:
. / 3
Date of inspection:
Comments: /W/> /> r / *1
.;,/*
c> i s rw »- €
Description/location:
!
AT
Source enclosed: pi yes
Source controlled: Q yes
If yes, type of control device:
no
no
Scrubber AP inches W.G.
Scrubber liquid flow rate GPM
Baghouse AP
inches W.G.
Bag cleaning: Q operative Q inoperative
VE method employed: ^ Method 9 D Method 22 Attach appropriate VE Observation Form
Compliance status: S compliance CD noncompliance Q not determined (explain in comments)
Inspector's signature: _
-------
Affected facUity:
»> <> e
Field Inspection Sheet
Date of inspection:
Source ID number:
Comments:
Description/location:
Source enclosed: r—i yes
Source controlled: r-j yes
If yes, type of control device:
no
no
Scrubber AP inches W.G.
Scrubber liquid flow rate GPM
Baghouse AP
inches W.G.
Bag cleaning: Q operative Q inoperative
VE method employed: 0 Method 9 Q Method 22 Affac/z appropriate VE Observation Form
Compliance status: 0 compliance CU noncompliance fZI not determined (explain in comments)
Inspector's signature:
Field Inspection Sheet
^/l-e^ tf,ll Date of inspection:
Source ID number: A/
-------
Field Inspection Sheet
Affected facility: S/g>-/>«>e o/>v Date of inspection:
Source ID number: /v Comments: Hi*f ^i~
Description/location: p^t^^ei'
(g> -/
A S
Source enclosed: rn yes
Source controlled: tt yes
If yes, type of control device:
Cclic
Hno
D no
Scrubber AP inches W.G.
Scrubber liquid flow rate GPM
Baghouse AP 2. »5" inches W.G.
Bag cleaning: ^ operative Q inoperative
VE method employed: H Method 9 Q Method 22 Attach appropriate VE Observation Form
Compliance status: CH compliance IS noncompliance Q] not determined (explain in comments)
Inspector's signature: —
Affected facility:
Field Inspection Sheet
Date of inspection:
Source ID number:
Comments:
Description/location:
Source enclosed: r~i yes rn no
Source controlled: Q yes rn no
If yes, type of control device:
Scrubber AP inches W.G.
Scrubber liquid flow rate GPM
Baghouse AP
inches W.G.
Bag cleaning: Q operative Q] inoperative
VE method employed: [H Method 9 n Method 22 Attach appropriate VE Observation Form
Compliance status: d compliance EH noncompliance D not determined (explain in comments)
Inspector's signature:
-------
APPENDIX G
STATE AGENCIES TO WHICH AUTHORITY HAS
BEEN DELEGATED FOR 40 CFR 60, SUBPART OOO
EPA
Region
State
Address
Maine
Connecticut
Rhode Island
Bureau of Air Quality Control
Department of Environmental Protection
State House
Station 17
Augusta, Maine 04333
(207) 289-2437
Connecticut Department of Environmental Protection
Bureau of Air Management
165 Capital Avenue, Room 144
Hartford, Connecticut 06106
(203) 566-4030
Rhode Island Division of Air and Hazardous Materials
291 Promenade Street
Providence, Rhode Island 02908-5767
(401) 277-2808
New York
Puerto Rico
New York Department of Environmental Conservation
Division of Air Resources
50 Wolf Road
Albany, New York 12223-3250
(518) 457-7230
Puerto Rico Environmental Quality Board
Del Parque Street #204
Corner Pumarada Street
Santurce, Puerto Rico 00910
(809) 725-5140 or (809) 722-0077
G-1
-------
EPA
Region
State
Address
Pennsylvania
Virginia
Bureau of Air Quality Control/Department of
Environmental Control
101 South 2nd Avenue, Box 2357
Harrisburg, Pennsylvania 17105-2357
(717) 787-9702
Bureau of Air Pollution Control
Allegheny County Health Department
301 39th Street
Pittsburgh, Pennsylvania 15201
(412)578-8111
Air Management Services
Philadelphia Department of Public Health
500 South Broad Street
Philadelphia, Pennsylvania 19146
(215) 875-5623
Department of Air Pollution Control
Box 10089
Richmond, Virginia
(804) 786-2378
G-2
-------
EPA
Region
State
Address
IV
Alabama
Florida
Georgia
Mississippi
North Carolina
South Carolina
Alabama Department of Environmental Management
1751 Congressman William L Dickinson Drive
Montgomery, Alabama 36130
(205) 271-7861
Florida State Agency
Department of Environmental Regulation
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
(904) 488-1344
Environmental Protection Division
Department of Natural Resources
Floyd Towers East
205 Butler Street, SE
Atlanta, Georgia 30334
(404) 656-4713
Mississippi Department of Environmental Quality
Bureau of Pollution Control
2380 Highway 80 West
Jackson, Mississippi 39204
(601) 961-5171
Division of Environmental Management
Post Office Box 27687
Raleigh, North Carolina 27611-7687
(919) 733-3340
South Carolina Department of Health and
Environmental Control
Bureau of Air Quality Control
2600 Bull Street
Columbia, South Carolina 29201
(803) 734-4750
G-3
-------
EPA
Region
V
State
Indiana
Illinois
Michigan
Minnesota
Ohio
Wisconsin
Address
Indiana Department of Environmental Management
105 South Meridian Street
Post Office Box 6015
Indianapolis, Indiana 46206
(317) 232-8162
Indianapolis Air Pollution Control Division
2700 South Belmont Avenue
Indianapolis, Indiana 46221
(817) 633-5496
Illinois Environmental Protection Agency
Division of Air Pollution Control
2200 Churchill Road
Post Of ice Box 19276
Springfield, Illinois 62794-9276
(217) 782-7326
Air Quality Division
Michigan Department of Natural Resources
Post Office Box 30028
Lansing, Michigan 48909
(517) 373-7023
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, Minnesota 55155
(612) 296-7301
Ohio Environmental Protection Agency
1800 Water Mark Drive
Columbus, Ohio 43266-0149
(614) 644-2270
Wisconsin Department of Natural Resources
Bureau of Air Management
Post Office Box 7921
Madison, Wisconsin 53707
(608) 266-7718
G-4
-------
EPA
Region
VI
State
Arkansas
Louisiana
New Mexico
Oklahoma
Texas
Address
Arkansas Department of Pollution Control
8001 National Drive
Little Rock, Arkansas 72209
(501) 562-7444
Department of Environmental Quality
Office of Air Quality and Nuclear Energy
625 N. Fourth Street
Baton Rouge, Louisiana 70804
(504) 342-1201
Environmental Improvement Division
Air Quality Bureau
1190 St. Francis Drive
Santa Fe, New Mexico 87503
(505) 827-0070
Albuquerque Environmental Health and Energy
Department
Post Office Box 1293
Albuquerque, New Mexico 87103
(505) 768-2600
Air Quality Service
1000 Northeast 10th Street
Post Office Box 53551
Oklahoma City, Oklahoma 73142
(405) 271-5220
Texas Air Control Board
6330 Highway 290 East
Austin, Texas 78723
(512) 340-5653
G-5
-------
EPA
Region
State
Address
VII
Iowa
Kansas
Nebraska
Iowa Department of Natural Resources
Henry A. Wallace Building
Des Moines, Iowa 50319
(515) 281-5145
Bureau of Air and Waste Management
Forbes Field,
Building 740
Topeka, Kansas 66620
(913) 296-1500
Department of Environmental Control
301 Centennial Mall South
Post Office Box 98922
Lincoln, Nebraska 68509
(402) 471-2189
G-6
-------
EPA
Region
State
Address
VIII
Colorado
Montana
North Dakota
South Dakota
Utah
Wyoming
Colorado Department of Health
Air Pollution Control Division
421OE. 11th Street
Denver, Colorado 80220
(303) 331-8500
Montana State Department of Health and
Environmental Sciences
Air Quality Bureau
Cogswell Building
Helena, Montana 59620
(406) 444-3454
North Dakota State Department of Health
1200 Missouri Avenue
Bismarck, North Dakota 58502-5520
(701) 224-2348
Department of Water and Natural Resources
Division of Air Quality and Solid Waste
Joe Foss Building
Pierre, South Dakota 57501
(605) 773-3153
Utah Department of Health
Division of Environment
Bureau of Air Quality
150288 North 1460 West
Post Office Box 16690
Salt Lake City, Utah 94116
(801) 533-6108
Air Quality Division
Department of Environmental Quality
122 West 25th Street
Cheyenne, Wyoming 82002
(307) 777-7391
G-7
-------
EPA
Region
IX
State
Nevada
Hawaii
Arizona
California
Address
Division of Environmental Protection
201 South Fall Street
Carson City, Nevada 89710
(702) 885-5065
Hawaii Department of Health
Clean Air Branch
500 Ala Moana Boulevard
Honolulu, Hawaii 96813
(808) 543-8200
Office of Air Quality
Department of Environmental Quality
2005 North Central Avenue
Phoenix, Arizona 85004
(602) 257-2308
Bay Area Air Quality Management District
939 Ellis Street
San Francisco, California 94109
(415) 771-6000
Fresno County Air Pollution Control District
1221 Fulton Mall
Fresno, California 73721
(209) 445-3239
Kern County Air Pollution Control District
2700 M Street, Suite 275
Bakersfield, California 93301
(805) 861-3682
Lake County Air Quality Management
883 Lakeport Boulevard
Lakeport, California 95453
(707) 263-7000
District
Mendocino County Air Pollution Control District
Courthouse Square
Ukiah, California 95482
(707) 463-4354
G-8
-------
EPA
Region
State
Address
IX
California (cont.)
Monterey Bay Unified Air Pollution Control District
1164 Monroe Street, Suite 10
Salinas, California 93906
(408)443-1135
North Coast Unified Air Quality Management District
5630 South Broadway
Eureka, California 95501
(707) 443-3093
Sacramento Metropolitan Air Quality Management
District
A Division of Sacramento County Environmental
Management Department
8475 Jackson Road, Suite 215
Sacramento, California 95826
(916) 386-6650
San Diego County Air Pollution Control District
9150 Chesapeake Drive
San Diego, California 92123-1095
(619) 694-3307
San Joaquin County Air Pollution Control District
1601 East Hazelton Avenue
Post Office Box 2009
Stockton, California 95201
(209) 468-3470
Santa Barbara County Air Pollution Control District
5540 Ekwill Street, Suite B
Santa Barbara, California 93111
(805) 681-5325
Siskiyou County Air Pollution Control District
525 South Foothill Drive
Yreka, California 96097
(916) 842-3906
South Coast Air Quality Management
9150 Flair Drive
El Monte, California 91731
(818) 572-6200
Ventura County Air Pollution Control District
800 South Victoria Avenue
Ventura California 93009
(805) 654-2806
G-9
-------
EPA
Region
IX
State
Guam and American
Samoa
Address
No information available
G-10
-------
APPENDIX H
COMPILATION OF EPA POLICY MEMORANDA
CONCERNING 40 CFR 60, SUBPART OOO
H-1
-------
\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
I WASHINGTON, D.C. 20460
NOV 8 1990
OFF ICE OF
AIR AND RADIATION
MEMORANDUM
SUBJECT: Applicability of NSPS Subpart F to Kilns and Clinker
Coolers Using a Common Exhaust Stack
FROM: John B. Rasnic, Acting Director
Stationary Source Compliance Division (EN-341)
Office of Air Quality Planning and Standards
TO: Bernard E. Turlinski, Chief
Air Enforcement Branch
Region III
I have received your memorandum of May I, 1990, requesting a
determination of applicability of Subpart F (Portland Cement
Plants) to a single exhaust' stack used by the kiln and clinker
cooler at a portland cement plant in Virginia. I have also
received your more recent draft letter, addressing the same issue,
to the State of Virginia. I apologize for the delay in our
response to your earlier memorandum.
Your request is for a procedure to determine compliance with
New Source Performance Standards (NSPS) from two NSPS facilities
with different opacity standards, which have a combined exhaust
stream. The facts in your memoranda state that the exhaust stream
from the affected facility with the 10% opacity standard (the
clinker cooler) is introduced into the preheater of the affected
facility with the 20% opacity standard (the kiln). The combined
emissions are then routed to the control device and then released
into the atmosphere.
Section 60.63 of the Subpart requires each owner or operator
to install, calibrate, maintain, and operate (in accordance with
§ 60.13) a Continuous Opacity Monitoring System (COMS) to measure
opacity from any kiln or clinker cooler subject to the Subpart.
Section 60.13(g) of the General Provisions requires two or more
affected facilities which are not subject to the same emission
standard to install an applicable continuous monitoring system on
each separate effluent, unless the installation of fewer systems
is approved by the Administrator.
H-2
Printed on Rfcyded Paper
-------
-2-
Therefore, as indicated in your draft letter to the State, a
COM3 would need to be installed on the ductwork leading from the
clinker cooler to the preheater. That COM3 must show compliance
with the 10% standard. Another COM3 installed on the kiln exhaust
would show compliance with the 20% opacity standard, as your draft
letter stated.
If, however, due to the configuration of the ductwork or for
some other reason approved by the Administrator, installation of
separate COM3 is impossible, the owner or operator may install an
applicable COM3 on the stack to monitor the combined effluent. If
this is done, our concern is that no circumvention of an
applicable opacity standard be permitted as a result of this
configuration. Section 60.12 (Circumvention) of the General
Provisions explicitly prohibits "...the use of gaseous diluents to
achieve compliance with an opacity standard...." To ensure that
the provisions of § 60.12 are complied with, and that compliance
with the standard for clinker coolers is achieved (10% opacity),
this common stack must meet the more stringent opacity requirement
of 10%. Whether the clinker cooler emissions are ducted directly
to the same stack as the kiln, or to the preheater, the 10%
standard still applies.
Furthermore, § 60.13(i)(1-9) allows the Administrator to
consider approval of alternatives to any monitoring procedures or
requirements upon receipt of a written application from the
source. This application may cite factors which interfere with
the accuracy of the monitoring system, may attempt to demonstrate
that the COM3 can be installed at an alternate location and still
provide accurate and representative measurements, or make an
argument for other alternative procedures, methods, or
specifications. Any such alternatives approved by the
Administrator for the COM3 on the clinker cooler must adequately
demonstrate compliance with the 10% standard for clinker coolers.
Turning to a further point you made in your more recent
submittal, you believe that the effluent from the clinker cooler,
after entering the preheater, undergoes a physical and chemical
change, and therefore becomes part of the kiln effluent. You feel
that, because of this transformation, effluent from the clinker
cooler becomes subject to the 20% opacity limit of the kiln, and
not the 10% opacity limit of the cooler. As the above discussion
indicates, we do not agree with that interpretation, given, in
part, the need to ensure compliance with the clinker cooler
standard. Please, note that the source may apply to EPA for an
alternative opacity limit under the provisions of § 60.11(e).
However, as noted above, the source should first explore
alternative monitoring methods which will enable direct monitoring
of the effluent from the clinker cooler prior to its introduction
into the preheater.
H-3
-------
-3-
To ensure consistency, this response has been reviewed by the
Emission Standards Division and the Office of Enforcement. My
staff has also been in touch with your staff to discuss this
request. I am also enclosing a copy of a 1989 letter from
Region IV which illustrates application of the COM3 requirements
in situations similar to this one. Please contact Ken Malmberg of
my staff (FTS 382-2870) if you have any questions about this
memorandum.
Attachment
cc: Roger Pfaff, Region IV
Ed Buckner, Region VII
Shirley Tabler, ISB, ESD (MD-13)
Ron Meyers, ISB, ESD (MD-13)
Justina Fugh, AED
John Rudd, AED
Peter Fontaine, AED
Howard Wright, SSCD
H-4
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
MAR 3- 1933
OFFICE OF
AIR AND RADIATION
MEMORANDUM
SUBJECT: Guidance for Utilization of Method 9 Data in Enforcement
Activities
FROM: John S. Seitz, Directed _ _
Stationary Source Comp^i^ncST Divisiorf
Office of Air Quality Manning and Stands
TO: Roger 0. Pfaff, Chief
Air Compliance Branch
Air, Pesticides and Toxics Management Division
In a July 28 letter to Region IV, North Carolina's Division of
Environmental Management requested resolution of an apparent contradiction
between the preamble for Method 9 that states "the accuracy of the method must
be taken into account when determining possible violations of applicable
opacity standards" and EPA's stated policy of not allowing or accreting an
error allowance when documenting opacity violations. This request was
forwarded to SSCD attached to an October 27, 1988 Region IV memorandum that
provided three alternative options to EPA's present policy on error allowance.
In further discussions between our staffs, we were informed that this request
stems from an enforcement action where a nonmetallic mineral processing plant,
during its performance test, exceeded the opacity standard established by the
NSPS Subpart 000. Further investigation of the elevated levels of opacity
identified problems with the plant's sprayer system, which required corrective
action.
A number of different issues are raised by this case and need to be
addressed one by one. First, the NSPS standards are carefully developed from
a comprehensive program of research, source testing study, and analysis.
Establishing the opacity standard for Subpart 000 sources was typical of this
process. OAQPS conducted a comprehensive study at nonmetallic mineral
processing plants to determine the range of opacity readings during maximum
operation using BDT. The opacity levels at the tested plants were very low
and the resulting Subpart 000 opacity standard adequately takes into account
the observed variation in opacity readings. Thus, even a marginal exceedance
of the standard is a strong indication of a control equipment, operation, or
maintenance problem which may require an enforcement remedy. It should be
noted that opacity standards are separately enforceable requirements and any
exceedance of the standard can be the sole basis for an enforcement action.
H-5
-------
- 2 -
In the, specific case of the North Carolina plant, according to the
information provided to SSCD, it appears the process worked as intended. The
performance test for the Subpart 000 source uncovered an opacity violation
which, on further investigation, showed equipment failure which required
correction, and an appropriate enforcement penalty. Measurement error was not
a relevant issue in this case.
The rationale for EPA's basic policy of no automatic error allowance is
underscored by the North Carolina case. The policy does not attempt to define
exactly how to account for measurement error, but states that adding
measurement error to the standard is not an appropriate method for accounting
for error. Further, arbitrarily eliminating from enforcement consideration
all marginal exceedances relaxes the standard without justification. This
brings into question the original intent of the standard, which is to require
installation of properly designed, well operated control equipment. Clearly,
this should not happen, since it undermines the standard and weakens our
enforcement program.
As for the three alternative policy options proposed in your memorandum,
they can not guarantee the elimination of measurement error. Adopting any of
them amounts to relaxing current opacity standards. Measurement error cannot
be addressed by a blanket policy statement, but instead the opacity observers
must conduct their duties in a systematic and reasonable way.
The preferred approach for accounting for measurement error is to follow
the procedures for conducting Method 9 observations described in the "Quality
Assurance Handbook for Air Pollution Measurement Systems" (EPA-600/4-77-027b,
1977) and to conduct followup investigation whenever opacity exceedances are
observed. The Method 9 guidance materials suggest various ways to augment the
visible emission observation if opacity values are in excess of the standard.
For example, in marginal violation situation, additional sets of readings
over longer time periods or even on different days may be appropriate for
ensuring that the opacity exceedances documented truly reflect noncompliance
rather than measurement error. Finally, enforcement officials must exercise
their technical judgement carefully in the final determination of an
enforceable violation, which may be based on additional factors such as the
plant operating history and extent and duration of excessive emissions.
In summary, there is no conflict between EPA's policy of no direct error
allowance and the requirement to account for error in Method 9 observations.
EPA's policy prohibits dropping frcm consideration marginal opacity
exceedances soley because there may be error. However, EPA does support use
of QA procedures and followup investigation as legitimate methods for
accounting for measurement error. If additional clarification of our policy
is needed, please contact Ken Malmberg at 382-2870.
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\ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
§ WASHINGTON. D.C. 20460
OFFICE OF
AIK AND RADIATION
MEMORANDUM
SUBJECT: Subpart 300 Determination
FROM: John S. Seitz, Director
Stationary Source Compliance Division
Office of Air Quality Planning and Standards
TO: Winston A. Smith, Director
Air, Pesticides and Toxics Management Division
Region IV
This is in response to your October 24, 1988 memorandum on enforcing 4fl
C.F.R. 60.672(e) of the NSPS for nontnetallic minerals. I will address each of
the issues you raised under the action portion of your memorandum, and as Ken
Malmberg of my staff has clarified with Paul Reinnerman.
Safety of our inspectors is of paramount importance when inspecting
sources. If an inspector feels he is compromising his safety by entering a
building like you describe, then he must not enter it. This is a guiding
premise of our entire field inspection program.
Your more substantive concern is with enforcing 60.612(9), because "some
buildings at Subpart 000 facilities preclude entry because of safety
problems." Apparently there is such a facility in Kentucky. All NSPS
standards are designed to require compliance with applicable standards at
startup. Facilities which are subject to NSPS requirements must be built so
they'are testable, or compliance with the standard cannot be determined.
Section 60.8 explicitly requires provision of safe access to sampling
platforms, for example.
Your memorandum states that, since seme VE is being discharged from the
building, entry to th« building must occur to determine which affected
facility is omitting the VE. That is true, but to determine compliance with
the standard, the owner or operator must provide EPA with a means of gathering
the relevant data. The building itself, though providing an indication of a
VE violation, cannot thereby preclude followup to determine the source of
thos« emissions.
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The owner or operator in this case may have to install a vent on each
affected facility for this purpose. As discussed in the Background
Information Document for this Subpart (EPA-450/3-83-001b, April, 1985), the
owner or operator has several options for determining compliance from affected
facilities. Separation of emissions by construction of separate vents for
each affected facility is one of these options and should be considered as a
means for assessing compliance.
If entry to the building cannot occur, then opacity violations from
outside the building will suffice for issuing an NOV. If the building
encloses more than one effected facility, our assumption will be that all such
facilities are in violation. It is up to the source to prove otherwise.
For specific means of reading the opacity of emissions while inside the
building, the alternatives discussed by Jack Farmer in an April 27, 1988
memorandum to Winston Snith on this subject seon sufficient.
Thank you for the opportunity to respond to your questions. I am sorry
for th« lateness of this response. Please call Ken Malmberg of my staff if
you have any questions.
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