EVALUATION OF COMPLIANCE
STATUS OF GRAIN ELEVATORS
IN THE STATE OF MINNESOTA
k) PEDCo ENVIRONMENTAL
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PEDCo- ENVIRONMENTAL.
SUITE 13 • ATKINSON SQUARE
CINCINNATI. OHIO 45246
513 / 7 V 1 -433O
EVALUATION OF COMPLIANCE
s/
STATUS OF GRAIN ELEVATORS
IN THE STATE OF MINNESOTA
Prepared by
PEDCo-Environmental Specialists, Inc
Suite 13, Atkinson Square
Cincinnati, Ohio 45246
Contract No. 68-02-1321
Task Order No. 8
Prepared for
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region V
Enforcement Division
Chicago, Illinois 60606
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This report was furnished to the Environmental Protection
Agency by PEDCo-Environmental Specialists, Inc., Cincinnati,
Ohio, in fulfillment of Contract No. 68-02-1321, Task Order
No. 8. 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 Environmental Protection Agency.
Mention of company or product names is not to be considered
as an endorsement by the Environmental Protection Agency.
11
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ACKNOWLEDGMENT
This report was prepared for the U.S. Environmental
Protection Agency by PEDCo-Environmental Specialists, Inc.,
Cincinnati, Ohio, under contract to the U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina.
Mr. Donald J. Henz, P.E. was the PEDCo Project Manager.
Mr. Lance Vinson was the Project Officer for the
Environmental Protection Agency.
111
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CONTENTS
1.0 INTRODUCTION
2.0 COMPLIANCE EVALUATION PROCEDURE
2.1 Determination of Compliance Status
2.1.1 Flow Diagram
2.1.2 Preliminary Calculations
2.. 1.3 Air Pollution Control Regulations
2.2 Preparation of Air Enforcement Checklist (AEC)
2.2.1 AEC Part I
2.2.2 AEC Part II - Data to Support Violations
2.2.3 AEC Part III - Desired Abatement Action
APPENDIX A: AIR POLLUTANT EMISSIONS REPORT
APPENDIX B: TYPICAL COMPLIANCE DOCUMENTATION
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1.0 INTRODUCTION
The U. S. Environmental Protection Agency (EPA) designated
39 grain elevators in Minnesota as subjects of a detailed com-
pliance analysis. Work completed by PEDCo under an earlier task
order determined that data in the EPA Regional Office files were
inadequate for conducting an accurate compliance evaluation.
EPA therefore undertook acquisition of the needed information
by issuing to each of the 39 designated grain operations a "114
report questionnaire", which requests information on air pollu-
tant emissions as authorized by Section 114 of the Clean Air Act.
A copy of this questionnaire is included in Appendix A.
Replies to these requests were examined to determine com-
pleteness of the information, and any further required data were
obtained by telephone.
PEDCo then conducted a detailed compliance analysis of
the 39 grain operations by a procedure consisting of three
major steps:
1) Calculating the compliance status of all operations and
processes at the 39 grain-handling plants.
2) Documenting technical determinations' and observations.
by completion of an Air Enforcement Checklist (AEC)
for each source judged to be not in compliance.
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3) Assessing the control improvement required for com-
pliance with regulations and the application of suitable
control technology and equipment, including feasibility
of retrofit, installation schedules, and estimated costs
This report describes in detail PEDCo' s evaluation pro-
cedures and presents in Appendix B an example of the document-
ation that was developed for each plant. •
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2,0 COMPLIANCE EVALUATION PROCEDURE
To ensure a high degree of uniformity in assessment of the
39 grain-handling operations, PEDCo developed a standard compli-
ance evaluation procedure. The documentation format consists of
a cover sheet, a process flow diagram, a completed Air Enforce-
ment Checklist, and supporting calculation sheets. An example
of this documentation package is given in Appendix E. The in-
formation assembled in this format provides a basis for eval-
uation by EPA Enforcement Division personnel; if enforcement
action appears warranted, the documentation serves as technical
background information for attorneys conducting the enforcement
proceedings.
In development of this procedure the principal literature
source was "Emissions Control in the Grain and Feed Industry,
Volume I, Engineering and Cost Study," prepared by Midwest
Research Institute for the Environmental Protection Agency
(Publication No. EPA-450/3-73-003a, December 1973).
2.1 DETERMINATION OF COMPLIANCE STATUS
2.1.1 Flow Diagram
The first step in the evaluation was to prepare a block
flow diagram showing all the processes at a grain elevator
and all the emission points. On these diagrams control
2-1
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devices are shown as follows:
Cyclone
Fabric filter
Gravity settling
chamber
Screen house
All processes are identified by a letter, and all emission
points by a number. An example flow diagram is shown in
Figure 2.1. Sources represented on flow diagrams include the
following:
a) Truck unloading
b) Rail unloading
c) Elevating
d) Grain scale
e) Dryers
f) Cleaners
g) Bin vents
h) Truck loading
i) Rail loading
-j) Flat storage unloading
k) Flat storage loading
2.1.2 Preliminary Calculations
Calculations to determine the compliance status of each
emission point within a facility were done on standard calcula-
tion sheets, as were calculations pertaining to the Air Enforce-
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PROCESS
A/T1A/ HOUSE
f SOURCE
VlDENTIFIERS
OLD HOU^E
Figure 2.1 Actual process flow diagram
drawn by the evaluating engineer.
2-3
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ment Checklist (to be discussed later).
Each emission point is identified by plant number, source
number, and the letters of all processes that emit pollutants
at that source. For example, an uncontrolled process is
assigned simply the letter for that process whereas a baghouse
that controls elevating, grain scale, and bin vents is assigned
the three letters that correspond to those three processes.
The source is also identified by name.
•For each source, the following preliminary information is
required:
a) Air flow
b) Material throughput (per hr) (per yr)
c) Control device types
d) Control device efficiencies
2.1.3 Air Pollution Control Regulations
Three types of sources are regulated by Minnesota's Regu-
lation APC-5 those equipped with a control device, those having
descrete emission pickup points, and those using forced air as part
of the process (e.g. dryers or cleaners). For this evaluation such
sources were considered in compliance with APC-5 if:
a) Source had 99 percent control, or
b) Source was outside the Minneapolis-St. Paul
metropolitan area, was more than one-quarter
mile from a public road or residence, and had
85 percent control, or
c) Neither of the above, but source complied with
APC-5, Table 2 (Source Gas Volume Regulation).
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Determinations of compliance by opacity measurements could
not be made without on-site inspection. The Process Weight
Regulation was not applicable since it requires 99 percent
control even at its lowest level, and APC-5 does not require
a source to control above 99 percent.
Cyclones, filters, and similar equipment used with pneu-
matic conveying systems or product recovery cyclones on hammer
mills were considered as control devices and compliance was
determined by.APC-5.
For sources that were uncontrolled and did not fall under
APC-5 (i.e. did not use forced air as part of the process),
regulation APC-6 was applied. APC-6 states that "No person
shall cause or permit the handling, use, transporting, or storage
of any material in a manner which may allow avoidable amounts of
particulate matter to become airborne." All sources lacking
control devices are emitting pollutants that could be avoided
by adding some type of control equipment; these sources there-
fore fall under APC-6. For this evaluation the source was
considered in violation of APC-6 if it did not use forced air
as part of the process and was uncontrolled.
2.1.3.1 Compliance with APC-5 - If a source was not automati-
cally judged .in compliance with APC-5. according to items (a) or.
(b) above, calculations were made for item (c), and compared with
APC-5, Table 2. The procedure was as follows:
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1) Hourly emissions were calculated in pounds per
hour. This calculation requires values for
emission factors, control efficiency, and maxi-
. mum operating rate. The emission factors used
are shown in Table 2.1. Where the control device
efficiency was not provided by the source or the
efficiency reported was believed too high for
the type of device in use, typical values were
obtained from Table 2.2. In cases, of disparity
between apparently high reported efficiencies
and those estimated from the Table, both values
were recorded on the AEC.
2) Exhaust gas (or air) flow rate was obtained from
the source whenever possible. If the air flow
rate was unknown but fan horsepower of the control
device was known, the air flow rate was estimated
by a method outlined by Clark and Davidson.*
CFM (cubic feet per minute) was calculated by the
formula:
CFM = BHp x 6356 x fan efficiency
Head,in inches of water
where:
BH (Brake Horsepower) = 0.9 x Motor Hp
P
Head = Pressure drop across the control device.
In calculating CFM, a fan efficiency of 0.7 and a
head of 6 inches of water was assumed. If the
source provided neither the air flow rate not fan
horsepower of the control device, typical values
from Table 2.3 were used.
3) From APC-5, Table 2, the allowed emissions in grains/
scf were obtained for the given flow rate through the
control .device. The allowed emissions (grains/scf)
were multiplied by the air flow rate through the
control device and converted to Ib/hr. The allowed
emissions were then compared to actual emissions to
determine whether the source met the regulation.
* Clark and Davidson, Manual for Process Engineering
Calculations, second edition, McGraw-Hill Book Co.,
New York, 1962, page 360.
2-6
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4) If the source did not meet the regulation, the required
control efficiency was calculated by the formula:
Required control allowable emissions
efficiency = (1 - uncontrolled emissions) x 100%
If the calculated required control efficiency was greater than
99 percent, the required control efficiency was entered as 99
percent, since APC-5 (b) (5) states that collection efficiencies
of 99 percent on existing equipment meet the regulation.
The required control efficiency and annual uncontrolled emissions
were then used to calculate allowable emissions in tons per year.
2.1.3.2 Compliance with APC-6 - Uncontrolled sources falling
under regulation APC-6 were automatically considered in violation.
The following calculations were then needed for completion of the
AEC:
1) Annual emissions were calculated by use of the
emission factors in Table 2.1 and the annual
operating rate.
2) Hourly emissions were calculated by use of the
emission factors and the maximum hourly process
operating rate.
3) Typical control device flow rates were obtained
from Table 2.3.
4) Allowable dust loading for the flow rate was
obtained from APC-5, Table 2.
5) Hourly allowable emissions (in pounds per hour)
were calculated by use of the typical control
device flow rate and the allowable dust loading
for that flow rate.
6) Required control efficiency was then calculated
based on allowable dust loading and the actual
uncontrolled dust loading, but not greater than
99 percent controls.
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7) Annual allowable emissions were calculated by
use of the required control efficiency and
annual uncontrolled emissions.
2.2 PREPARATION OF AIR ENFORCEMENT CHECKLIST
An AEC was filled out for each emission source not in
compliance. A cover sheet prepared for each company listed
sources in compliance, sources not in compliance, any non-grain
sources of emissions present (if known), and any additional
comments.. The AEC is formulated in three major parts:
Part I - Summary of pollutant types, laws violated,
and total emissions from each source not
in compliance.
Part II - Data to support violations of each source
not in compliance.
. - Part III - Evaluations of proposed control strategies ,
suggestions for controls that could achieve
compliance, and estimations of control costs.
2.2.1 AEC Part I
The first section of Part I identifies the source, pollu-
tants, and type of operation. Section II calls for a list of
currently enforceable regulations, which in application to
the Minnesota grain operations consist of the following portions
of the State of Minnesota regulations:
1) Excess Dust Loading APC-5(b) (8) Table 2, or
2) Allowing Avoidable Amounts of Particulate Matter
to become Airborne APC-6(a), or
3) Both (1) and (2) .
In the third section of Part I are listed the number of
sources not in compliance, total current emissions from all
2_ Q
O
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sources not in compliance, and total emissions from these
sources after compliance is achieved.
2.2.2 AEC Part II - Data to Support Violations
Part II and Part III of the AEC were completed for every
source that was not in compliance within the cited facility.
Section I of Part II identifies the specific source within the
plant that is noncomplying, and Section II again cites the regu-
lations, violated by the source.
In Section III are listed the calculated annual emissions
without controls and with existing controls. Allowed emissions
are then entered, based on the required control efficiency.
In Section IV any factors that might affect the persuasive
impact of the evidence are identified and explained.
2.2.3 AEC Part III - Desired Abatement Action
The type of control necessary to bring the source into
compliance is shown in Section I,A. Although a cyclone could
provide sufficient control to enable some sources to meet the
regulations, most sources required a fabric filter. Therefore,
the recommended control devices, costs, and compliance schedules
listed in this section reflect the use of fabric filters..
Section I,B calls for a tentative compliance schedule for
bringing the source into compliance. The compliance schedules
prepared for application to these grain-handling plants are given
in Tables 2.4, 2.5, and 2.6. These schedules should be viewed
'only as approximations, since timing is dependent on•availability
of materials and manpower.
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Section I,C provides for description of any proposed
alternative course of action, other than that described in I/A.
Section II of Part III shows the estimated range of installed
costs for controls. For this project the costs were calculated
from the values given in Table 2.3, which are given in cost per
air flow rate through the control device. This table is based
on October 1972 dollars and represents only the normal price
range that would be applicable to perhaps 90 percent of the
various source types. Because of the great variability in
costs, the individual requirements of each facility must be
evaluated carefully and control costs determined accordingly.
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Table 2.1 PARTICULATE EMISSIONS FROM GRAIN HANDLING AND PROCESSING
Emission source
1. Terminal elevators
Shipping or receiving
Rail
Truck
Barge
Transferring, conveying, etc.
Screening and cleaning
Screening only
Drying
2. Country elevators
Shipping or receiving
Rail
Truck
Barge
Transferring, conveying, etc.
(i.e. elevating)
Screening and cleaning
Screening only
Drying
Grain scales
Storage bin vents
Flat storage
Unloading truck to bin
Loading truck from bin
Emissions, Ib/ton.
of grain processed
1.0
1.4
1.2
2.0
5.0
2.0t
5.5
4.0
4.5
5.5
3.5
8.5
4.0h
7.5
2.01
2.0t
2.0h
2.0b
Emissions Control in the Grain and Feed Industry. Volume I -
Engineering and Cost Study. Midwest Research Institute.
Prepared for Environmental Protection Agency, Research Tri-
angle Pixrk, North-Carolina, under Contract No. 68-02-0213,
December 1973. Kansas City, Missouri. Publication No.
b EPA-450/3-73-003a, p. 118.
Engineering judgement based on publication No. EPA-450/3-73-003a.
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Table 2.2 ESTIMATED CONTROL EFFICIENCIES'
(values in percent)
Cyclone
Cyclone
Low velocity
.fabric filters
High velocity
fabric filters
Settling house
Screen house-
85 (other than pneumatic conveying or
product recovery)
99.0 (pneumatic conveying or product recovery)
99 (air-to-cloth ratio = 10-15)
95 (air-to-cloth ratio = 200-500)
50
80
Based on engineering judgement using EPA-450/3-73-003a.
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Table 2.3 TYPICAL CONTROLLED FLOW RATES AND APPROXIMATE
RANGE OF CONTROL COST51
(total installed cost)
Operation
Typical flow rate,
cfm
Installed cost,
$/cfm
1. Grain Handling
Receiving
Truck dump
Boxcar receiving
Hopper car receiving
. Drying
Cleaning
Transfer operations
Scale and garner
Elevating
Loadout
Truck
Rail
Storage bin vents
Flat storage
Unloading to bin
Loading from bin
Grinding
10,000
10,000
10,000
Column Dryer - 100 acfm/bu/hr
Rack Dryer - 70 acfm/bu/hr
Recirculating Dryer (Column) -
30 acfm/bu/hrb
10,000 (each).
2,000
1,500C
5,000
5,000
1,500C
1,500
5,000C
4,000
1.75 - 4.00
1.75 - 4.00
1.75 - 4.00
0.25 - 0.75
2.00 - 3.00
1.50 - 3.00
1.50 - 3.00C
2.00 - 4.50
2.00 - 4.50
1.50 - 3.00C
•1.50 - 3.00°
2.00 - 4.50C
1.50 - 3.00
Emissions Control in .the Grain and Feed Industry.
Volume I - Engineering and Cost Study. Midwest
Research Institute. Prepared for Environmental
Projection Agency, Research Triangle Park, North
Carolina, under Contract No. 68-02-0213, Dec.
1973. Kansas City, Missouri. Publication No.
EPA-450/3-73-003a, p. 325 unless otherwise noted.
b „
From Publication EPA-450/3-73-003a, p. 132. Normal
exhaust temperature 100°F to 110°F.
Based on engineering judgement using EPA-450/3-73-003a.
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Table 2.4 SCHEDULE FOR INSTALLATION OF BAGHOUSE OR SELF-CLEANING
SCREEN FILTER ON. GRAIN HANDLING AND PROCESSING SOURCES
FOR PARTICULATE POLLUTANT CONTROL
Milestones Elapsed time,
. weeks
1 Date of submittal of final control 2
plan to appropriate agency
2 Date of award of control device 9
.contract
3 Date of initiation of on-site 25
construction or installation of
emission control equipment
4 Date by which on-site construction 37
or installation of emission control
equipment is completed
5 Date by which final compliance is 40
achieved
Table 2.5 SCHEDULE OF INSTALLATION OF HIGH-ENERGY CYCLONE
ON GRAIN HANDLING AND PROCESSING SOURCES
FOR PARTICULATE POLLUTANT CONTROL
Milestones Elapsed time,
weeks
1 Date of submittal of final control plan 2
to appropriate agency
2 Date of award of control device contract 9
3 Date of initiation of on-site construe- 25
tion.or installation of emission control
equipment
4 Date by which on-site construction or 35
installation of emission control equip-
ment is completed
5 Date by which final compliance is 38
achieved
. 2-14
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Table 2.6 SCHEDULE FOR INSTALLATION OF LOW ENERGY WET SCRUBBER
. CAPACITY UNDER 150,000 CFM
Milestones • Elapsed time,
.weeks
1
2
3'
Date of submittal of final control plan
1 to appropriate agency
Da-te of award of control device contract
Date of initiation of on-site construe-
4
12
36
tion or installation of emission control
equipment
Date by which on-site construction or 52
installation of emission control equip-
ment is completed
Date by which final compliance is achieved 56
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APPENDIX A
AIR POLLUTANT EMISSIONS REPORT
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AIR POLLUTANT EMISSIONS REPORT
FEED AND GRAIN INDUSTRY
I. PLANT IDENTIFICATION
A. Corporation (parent) Information
Name:
Address:
Chief Executive Officer Name:
Title:
B. Plant Information
Name:
Address (Plant Location):
County:
Person to contact for information regarding this
summary.
Name:
Title:
Telephone Number:
Site: Land area at plant location (in acres). Enclose
a map, engineering drawing or sketch showing
location of principal plant buildings with .
identification names, location of plant property
lines, names and locations of streets nearest to
plant boundaries, location of stacks or other .
discharge points, and distance to any public roadway
or private residence nearest to each plant emission
source. • .
Operation: Provide a block diagram showing the process flow
of major plant processes, identifying the major
operational steps in each process, emission points,
and control units associated with each process
operation. Show the maximum material flow through
each processing unit, the process flow(s) to which
each emission control device is applied, and the
discharge points as identified on the layout drawing.
Normal Plant Operating Schedule
hrs/day; days/wk; wks/yr,
Plant Capacities:
Total Storage Capacity: bushels
Total Grain Processed: . bushels/yr.
for • (year of record)
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FEED AND GRAIN INDUSTRY
II. PROCESS EMISSION SOURCE INFORMATION
- complete one of these forms for each operation which is_ •
exhausted t£ the atmosphere -
A. Description of Operation
1. Type of operation*
Equipment*
a. Type of grains processed
3. Number of identical operations*
4. Operating hours. hrs/day; days/wk; wks/yr.
5. Operating rates:
bushels/hr X Ibs/bushel = Ibs/hr.
B. Emission Information
1. Exhaust Data
a. Means of exhaust .
. Stack: rectangular Q round Q
dimensions '
2
other* area ft
flow ACFM*. temperature °F
height of exhaust discharge above ground ft
Control Equipment (Particulate)
Type* \ Manufacturer and Model
Control Efficiency Design __% Actual* %
Secondary Device (if applicable)
Type* Manufacturer and Model
Control Efficiency: Design . ' % Actual* %
Emission (Particulate)
Rate Ibs/hr. before control system
Ibs/hr. after control system
Concentration grains/SCF after control system
Method of emission determination
Q. Stack Test include report or describe test
Q Other (explain)
Estimate: Show assumptions and calculations below:
Appendix before completing these blanks
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AIR POLLUTANT EMISSION REPORT
FEED AND GRAIN INDUSTRY
APPENDIX: PROCESS EMISSION SOURCE INFORMATION
The explanations below clarify the intent of the questionnaire
items marked with an asterisk (*).
A.I. Type of Operation - indicate the type of operation (for
example, boxcar unloading, grain drying, conveying).
A.2. Equipment - indicate the particular type of equipment
used in the operation (for example, a grain dryer could
be either a rack or column type).
A.3. Number of Identical Operations - indicate the number of
these operations which are identical. (For example, there
might be 10 identical grain storage bins.) Process
information should be for each process. It is not necessary
to complete one form for all the identical operations.
B.I.a. Other - such as a roof vent, window, etc.
Flow - actual cubic feet per minute.
B.2. Type - Cyclone, settling chamber, fabric filter, etc.
Actual - Control efficiency: by stack test or other method.
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APPENDIX B
TYPICAL COMPLIANCE DOCUMENTATION
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Company: XYZ Grain and Seed Company
Sources in compliance - 9-10-J
Sources out of compliance - 9-1-A, 9-2-B, 9-3-C, 9-4-D, 9-5-E,
9-6-F, 9-7-G, 9-8-H, 9-9-1, 9-11-K,
9-12-L, 9-13-M, 9-14-N, 9-15-0.
Non-grain sources - None
Comment's : None
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Seed Co.
Plant 7
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All', LliTOKCEMi.fiT CIIECKLISF
i. Source Idenki f'ioi lion
A. fJani',;:. XYZ Grain and Seed Company
B. Address:
r,. Air Qua lily fonlrol RtMjion: Northwest. Minnesota
i). Pol.In MM (.(.',): Wheat, barley, oats, flax'and sunflower dust.
I. 'lypi' of Operation: grain cleaning and storage; seed production
I . 1 vpf.> n f V i n 1 <:i li on :
A. (.iirr'.'iil: I y on foraMb I (; n'fjul a I: i on
('.i la lion and DCS i (jna lion :
Excess dust loading APC-5 (8) Table. 2
Preventing Particulate from becoming Air-borne APC-6
li. Incromenl v/ilhin ro.
i. lotil (.mis', ions ("'.-ic'li polliil.ini) h-osonl A! Lcr l'.m-:pl ianrt.' _Ach iovrd
Particulate 14 sources 277.2 TPY 8.28 TPY
not in com-
pliance
'Emissions based on U.S. EPA emission factors.
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'APT
IV. Previous1 At tempts at Compliance and Contacts wit'.h Source, if any:
V. Prior Local, SL-ilo, nr Fcdeml Lnforcon'On!: Actions:
V !•. S t a I.e/1 oca I discussion of Proposed Federal L'n forceineut Ac I. ion
A. Name and Lille of highest; official v.'iUi v/hoiu discussed:
I'. ALl.iLude.of person named in A., above low.ird lei;ler,il (ic,'.ion
V'l I.' Not i Hc.HiOIK;
So! i rcc:
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LOG1
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9-1-A
PART 11
DATA' TO SUPPORT VIOLATIONS
I. Source identi Meat ion
A. [lame of romp/my: XYZ Grain and Seed Company
U. Spec i I i-c source within ci'tcd facility:-
Source No. 9-1-A - Truck Dump•
I. KCOU i roiiiPii (.(::,) vkvl.Uod by source:
Preventing Particulate from becoming Air-borne APC-6
I. Evidence supporting violation
A. l.iiiiv, ion Tactors
i. -Ca I cu I a ted eini ssions
a . wi thout controls:
(27,500 TPY) (4.5 Ib/T) (T/2000 Ib) =:61.9. TPY
b. with controls (known/estimated):
Mo controls
APC-6 states particulate emissions must be controlled,
APC-5 (8). Table 2 will apply to the control device.
For a 1.0,000 SCFM fabric filter, 1.27 TPY would be
• allowed.
il.iii!!-1 nl i nd i v i flii.'i I'., '.vlin con toslify to Hi;.1 ;ilfovo in fornio I: ion :
Weal S. Egan (PEDCo)
Donald J: Henz, P'.E. (PEDCo)
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9-1-A
CART 1:
- 2 -
15. Smokereadi IKJS
1. Description of smokerooei iiu) evidence1
2. Names of individuals who can testify Lo I he above in forma Lion:
C. St.ack sam'p'l inn
1. Description nf stack sampling evidence:
L;.' flames of individual:; who can testify l.o Uic a hove information:
L'vidf.'ii'.'i.- in.lii.aMnQ missed i ncremnn t. if a|'|) licalil <••..
V. IdonLily and explain any factors which may al'lei. r the porsiMsive impact.
of the evidence:
Our emission estimates based on U.S. EPA emission factors for
this type of operation. A better estimate of the actual
emissions could be obtained by source testing.
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9-1-A
PART II
S
I. Alia Iciiic'M I •<•)<; t. 'ions which could be Ldkon to richiove coinp I i a rice
A. l.'/i'i s o I co/i l.ro I s ;
A fabric filter control device could bring the
source into compliance.
B. Tcnl.til.ivo compI un.icc schedule
•MILESTONES ' ELAPSED TIME
(Weeks)
1 Date of submittal of. final control 2
plan to appropriate agency
2 Date of award of control device 9
contract
3 Date of initiation of on-site 25
construction or installation
emission control equipment
4 Date by Which on-site construction 37
or installation of emission control
equipment is completed
5 Date by which final compliance is 40
achieved
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9-1-A
C. If the source has proposed an alternative course of act ion'to the
one described in A. above, describe and evaluate the proposed alternative,
(attach copy'of proposal, if available):
I. Estimated cost of r(•.•medial action
Estimated cost of action described in [.A and I.C above1 if knov/n (c|ive
ba'sis for estimate and attach study, if any):
.Installed cost would range .from $17,500 to $40,000 based on a
cost of $1.75 to $4.00/SCFM. •
Reference: Emissions Control in the Grain and Feed Industry,
Volume I _ Engineering and Cost Study. Midwest Research
Institute. Prepared for Environmental Protection Agency,
Reserach Triangle Park, North Carolina, under Contract No.
68-02-0213, December 1973. Kansas City, Missouri.
-------
9-2-B
PART 1 I
DATA TO SUPPORT VIOLATIONS
I. Source Idcnti f ico Lion
A. (Mine of Com|Miiy:. XYZ Grain and Seed Company
B. Spec i I" i <: source w i thin ci tod foci 1 i Ly:
Source No. 9-2-B - Transferring and Elevating
II. R(.H|II i ivmon t(s ) violated by source-:
Preventing Particulate from becoming Air-borne APC-6
III. I'.v i(.h''[ii-f! support iiiij violation
A. Lmissioii factors
I. Calculalod emissions
a. without controls:
(27,500 TPY) (3.5' Ib/T) (T/2000 Ib) = 48.1 TPY
h. v/ith controls (known/es tiina ted):
No controls
A I InwiVfl i.'iui '•',<> ions
•APC-6 states partiuclate emissions must be controlled,
APC-5 (8) Table 2 will apply to the control device.
For a 1500 SCFM fabric filter, 0.48 TPY would be
allowed.
:. il.iin::'. i:>r i ud i v i dud Ir. who can i. e1., lir'y I o I ho .ilmvc1 iu roriu.H. ion :
Neal S. Egan (PEDCo)
Donald J. Henz, P.E. (PEDCo)
-------
'9-2-B
PAKF I !
- 2 -
[i. Smoke readings
1. Description of smokereadincj evidence
2. Homes of individuals who can tost.ify Lo the above information:
C. Stack samp] i n f|
I. Description of stack samplimj evidence;
'.'. ll.iii1!:', ul individual;; who can testify to the ahove i n funiidl. ion:
[J. I'videnci.' ind i c'r'i I. i ny missod ino'C-inen t, if a
V. I i|i:i:i > i ,- cMi'l explain iiny factors which nitiy al'fccl. tlie perf.uasi ve. ini|)ac t
of the (.••/ id'/ncc1:
Our emission estimates based on U.S. EPA emission factors for
this type of operation. A better estimate of the actual
emissions could be obtained by source testing..
-------
9-2-B
PART I
Abatement actions which could bo taken to ar.hii've. compliance
A. Types ol controls:
A fabric filter control device could bring the
source into compliance
B. I'entfilive compliance schedule1
MILESTONES ELAPSED TIME
(Weeks)
1 ' Date of submittal of final control 2
plan to appropriate agency
2 ' Date of award of control device 9
contract
3 Date of initiation of on-site 25
construction or installation of
emission control equipment
4 Date by which on-site construction 37
or installation of emission control
equipment is completed
5 Date by which final compliance is 40
achieved
-------
9-2-B
PART I 1
C. If the source has proposed
-------
9-3-C
PART II
IJATA TO SUPPORT VIOLATIONS
I. Source hk.'Ml.i ficatioM
A. llamO'Of Company: XYZ Grain and Seed Company
B. Specific source v/it.hin cited facility:
Source No,. ' 9-3-C - Scale
M. I'.f.'qu i remon I. (s ) violated by source:
Preventing Particulate from becoming Airborne APC-6
M. F.v i dOiico support i mj violoLion
A. I.'.mi ss inn factors
!. Ca'ku I a tod emissions
a . w i tliou t COM tt'ol S;
(27,500 TPY) (2 Ib/T) (T/2000 Ib) = 27.5 TPY
b. with controls (known/estimated):
No controls
;\ A I lov.T.-d emi ss ions
APC--6 states particulate emissions must be controlled,
APC-5 (8) Table 2 will apply to the control device.
For a .2000 SCFM fabric filter, 0.28 TPY would be allowed
i. iliiiii--1, ul individuals who con testify l.o I he a hove in I onna I. ion :
Neal S. Egan (PEDCo)
Donald J. Henz, P.E. (PEDCo)
-------
APPENDIX B
TYPICAL COMPLIANCE DOCUMENTATION
-------
9-3-C
PART 1 I
li. Smokereadi IHJS
1. Descri|)l.ion of smokeread iiu) evidence
?,. Names of individuals who can testify to Uie above information
C. c>tack Siiinpl iIKJ-
1. Description of stack sampling evidence;
:'. flames of individuals who can testify to Mio-ahovi1 information:
I), tvidoiur indicaI ing missed increment, if ap|)l id-il
IV: Idiiniil'v ,in>l exrilain any factors which may affect the persuasive impact
oI I he ev ii!<'m'.L':
Our emission estimates based on U.S. EPA emission factors for
this type of operation. A'-better estimate of the actual
emissions, could'be obtained by source testing.
-------
9-3-C
PART II
I. Al>() tt^iion I. (•ict'ioiis whi.ch could bo Ukon lo cidiicjvt? compl iance
A. I VI "'"^ o I (.on Lro If,;
A fabric filter control device could bring the
source into compliance.
B. Ti-nUi l;ivc compliance sclicdult:?:
MILESTONES ELAPSED TIME
(Weeks)
1 Date of submittal of final control 2
plan to appropriate agency
2 Date of award of control device 9
contract
3 Date of initiation of on-site 25
construction or installation of
emission control equipment
4 Date by which on-site construction 37
or installation of emission control
equipment is completed
5 Date by which final compliance is 40
achieved
-------
9-3-C
PART I I
If the source has proposed an alternative course of action- to the
one described in A. above, describe and evaluate the proposed 'alternative,
(attach copy of proposal, if available):
Estimated cost of remedial action
Estimated cost of action described in I.A and' f.t above if knov/n ' (gi ve
basis for estimate and attach study, if any):
Installed cost would range from $3,000 to $6,000 based on a
Cost Of $1.50 to $3.00/SCFM.
Reference: Emissions Control in • the Grain and Feed Industry
Volume I - Engineering and Cost Study. Midwest Research
Institute. ' Prepared for Environmental Protection Agency,
Research Triangle Park, North Carolina, under Contract No.
68-02-0213, .December 1973. Kansas City, Missouri.
-------
9-4-D
PART II
DATA TO SUPPORT VIOLATIONS
Source Idc'nti H cat ion
A. (lame 'of f.oiiijjany : XYZ Grain and Seed Company
B . f'|)(!c i f i c '..(inrcc! wi Lhi n ci tod fac i 1 i ty-:
Source No. 9-4-D - Cleaner
!i. Kc-(|ii i remon i. ( i. ) violated by source:
Excess Dust Loading APC-5 (8-) Table 2
.II. Evidence supporting viola lion
A. [mission I'aclors
I . r,(il ciliated emission 5
a . wi Ihoiit. control s:
(8,750 TPY) (8.5 lb/T)' (T/2000 Ib) - 37.2 TPY
I)., wi t.h controls (known/estimated):
(37.2 TPY) (1.0 - 0.50) = 18.6 TPY
All Odi'.'d fjlll i S :i i OllS
3.04 TPY - Based on APC-5 (8) Table 2
v iiani!.-'. of i nd i v i diia I '> v/ho can toslify to. I ho ahnvc in forma lion:
Neal S. Egan (PEDCo)
Donald J. Henz, P.E. (PEDCo)
-------
9-4-D
CART 1 I
- 2 -
l\. Smoke readi IHJS
1. Doscripi. ion of siiioken.'ad'i nij evidence
2. Names of individuals who can testify Lo the above, infonna tion :
C.. Si lick 'odinpl iiuj
I. .Descriptiou of stack sampling evidence:
?. Homes of i rid i v.i duals who can testify to the above information:
0. ividciHo indicating missed increment, if ..ipji!
V. IdenU'lv -uid i/plain diiy factors which may afiecl (.he |)ersuasive impact
of the (.:•'/ idi'iiu:: ' .
Our emission estimates are based on U.S. EPA emission factors
for this type of operation. A better estimate of the actual
emissions could be obtained by source testing.
-------
9-4-D
PART IT
Abcil-.niir'Ml. .iclions which could bo Liken l.n ;ichi<.>vc compliance
A. 'ly|'i;<; "I controls:
The present control device is a settling chamber.
It is doubtful if the efficiency of the settling
chamber could be improved to meet the Minnesota
concentration regulations. A fabric filter control
device could bring the source into.compliance.
I}.' Ten id I. ivo compliance sch(u.lul.e:
MILESTONES ELAPSED TIME
(Weeks)
1 Date of submittal of final control 2
plan to appropriate agency
2 Date of award of control device ' 9
contract
3 Date of initiation of on-site 25
construction or installation of
emission control equipment
4 Date by which on-site construction 37
or .installation of emission control
equipment is completed
5 Date by which final compliance is 40
achieved
-------
9-4-D
C. If the source has proposed an alternative course of action to the
one.described in A. above, describe and evaluate the proposed alternative,
(attach copy of proposal, if available):
II. Estimated cost of re-medial action
Estimated cost of action described in I.A and I.C above if knov/n (
-------
9-5-E
PART II
DATA TO SUPPORT VIOLATIONS
I. Source Identi Heal ion
A. ' Manic; of" Company: XYZ Grain and Seed Company
B. Specific source within cited• faci1ity:
Source No. 9-5-E - Storage Bins
I. Ki.'!|ii i njiiif;nl( s ) violated by source:
.Preventing Particulate from becoming Air-borne APC-6
I. lividencc supporting violation
A. ['mission ('actors
1. Ca1cula ted emissions
i\. wi tliotit control s:
(27,500 TPY) (2 Ib/T) (T/2000 Ib) = 27.5 TPY
I.), with controls (known/estimated)
No controls
?.. All owed em i ss ions
APC-6 states particulate emissions'must be controlled,
APC-5 (8) Table 2 will apply to the control device.
For a 1500 SCFM fabric filter, 0.8 TPY would be allowed
''>. Jl.iiii!:1. (.-I i ud i v i rluii 1'. who con t.csli'ly to Ih" alinvc in forma I. ion :
Neal S. Egan (PEDCo)
Donald J. Henz, P.E. (PEDCo)
-------
9-5-E
I'AKT 1 I
II. Smokeroadinys
I. Doscr i pt ion of smoke rood in li'-;
IV. Identity .nid explain any factors which ii.ay afi'ect the [jersuasive impact
111 .' in' (••'/ i ihMice:
Our emission estimates based on U.S. EPA emission factors for
this type of operation. A better estimate of the actual
emissions could be obtained by source testing.
-------
9-5-E.
PART IT
AlirHoinnnL actions which could he Uken l.o achieve compliance
A. Types of conLrols; .
A fabric filter control device could bring the
source into compliance.
B. Ten Id l.i ve'comp I iance schedule;
MILESTONES. ELAPSED TIME
(Weeks)
1 Date of submittal of final control 2
plan to appropriate agency
2 Date of award of control device 9
contract
3 Date of initiation of on-site 25
construction or installation of
emission control equipment
' 4 Date by which on-site construction 37
or installation or emission control
equipment is completed
5 Date by which final compliance is 40
achieved
-------
9-5-E
I'ART I I I
If the source IMS proposed an alternative course of action to the
one described in A. above., describe and evaluate the proposed alternative,
(attach copy of • proposal , if available):
Estimated cost' of remedial action
F.s t imated cost o'f action described in LA and I.C above if known (.give
basis for estimate and attach study, if any):
Installed cost-would range from $2,250 to $4,500 based on a
cost of $1.50 to $3.00/SCFM.
Reference:. Emissions Control in the Grain and Feed Industry,
Volume I - Engineering and Cost.Study. Midwest Research
Institute. Prepared for Environmental Protection Agency,
Research Triangle Park, North Carolina, under Contract No.
68-02-0213, December 1973. Kansas City, Missouri.
-------
9-6-F
PART I I
DATA TO SUPPORT VIOLATIONS
I. Source Hen l;i f ication
A. Iliinic ol; Company: XYZ Grain and Seed Company
|i. Spoci fi c source v/ithin citocl facility:
Source No. 9-6-F - Rail Loadout
II. RL><|II i reim:ri t.(s ) violatpi'l by source:
Preventing Particulate from becoming Air-borne APC-6
II. Evidence supportiny violation
.A. ['mission ("actors
i. (;,.il f.u I a t'od cnii ssions
a . w i tliou t control S;
(18,300 TPY) (4 Ib/T) (T/2000 Ib) = 36.6 TPY'
h. with controls (kiiown/es tima ted):
No controls
..'. AI lowod oiiii ssions
APC-6 states particulate emissions must be controlled,
APC-5 (8) Table 2 will apply to the control device.
For a 5000 SCFM fabric filter, 0.46 TPY would be allowed
i. iJdin: •, ijt i IK! i v i duii I '> who can testify lo lii;1 iilHiv..1 in I ot'in
-------
9-6-F
['ART I I
- 2 -'
B. Smoke roadinys
I. Descr i pt ion of smokercad iiKj evidence.1
2. llanK.'s of individuals who can tor.l.i fy" l,o tho above in forma Lion
C. Stock Siimpl inrj
1. Description of stack sampl ing evidence;
2. Hani1;1, ol individuals v/ho can testify to I.ho ahove information:
','. I. vi duin.:.' ii'd ica I inrj mtss-ed ino'Oinen !:, if ciiipl ii_ril)li':
V, IdonLil'y ain.l nxiJl'din any factors which may affect the persirar, i ve impact.
of the evidem.e:
Our emission estimates based on U.S. EPA emission factors for
this type of operation. A better estimate of the actual
emissions could be obtained by source testing.
-------
9-6-F
PART II
AlifHon'onI. 'noI;ions which could he Uken to richiove compl iance
A. Types of controls:
A fabric filter control device could bring the
source into compliance.
I'p. TentdMve compliance schedule :
MILESTONES . ELAPSED TIME
(Weeks)
1 Date of submittal of final control 2
plan to appropriate agency
2 Date of award of control device 9
contract .
3 Date of initiation of on-site 25
construction or installation Of
emission control equipment
4 Date by which on-site construction 37
or installation of emission control
equipment is completed
5 ' Date by which final compliance is 40
achieved
-------
9-6-F
I'AR'I I I
If the source has proposed an al terna l:i ve course of action (o the
one described in A. above, describe and evaluate the proposed alternative,
(attach copy of pioposal, if available):
II. Estimated cost of remedial action
Estimated cost of action described in I.A and l.C above if knov/n (
-------
9-7-G
PART 1 I
DATA 'TO SUPPORT VIOLATIONS
I. Source Ident;i Mcation
A. flame of Company: XYZ Grain and Seed Company
R. Spocilic '.onrco within cited Tacility:.
Source No. 9-7-G - Truck Loadout
II. Kequ i rcninnl (':,) viol a tod by source:
Preventing Particulate from becoming Airborne APC-6
II. Evidence; supporting violation
A. Dni '.-,s ion factors
I. Calculated emissions
a . v/i Llifiiil. control s;
(9,200 TPY) (4.5 Ib/T) (T/2000 Ib) = 20.7 TPY
l.i. vntli controls (kn.ov/n/es Lima tc'd):
No controls
';'.. A11 (iwf.-fl eiiii ss ions
APC-6 states particulate emissions must be controlled,
APC-5 (8) Table 2 will apply to the control device.
For a 5000 SCFM fabric filter, 0.23 TPY would be allowed,
iliiii'"', '...-I i iirl i v i
-------
9-7-G
PART JI
- 2 -
B. Smoke-readings
1. Description of smokereadiny evidence
2. Names of individuals who can te.stify to the above information:
C. Stack sampl ing
I. Description of stack sampling evidence:
2. Names of individuals who can testify to the above information:
I!/ Lvidonci.' indicating missed increment, if appl ica
V. Identify and explain any factors which may aflccl the persuasive" impact
of the evidence:
Our emission estimates based on U.S. EPA emission factors for
this type of operation. A better estimate of the actual
emissions could be obtained by source testing.
-------
9-7-G
PART II
Abatement actions which could be Liken In ddiieve compliance
A. • Types of controls:
A fabric filter control device could bring the
source into compliance.
li. Ten iti Live compliance schedule'
MILESTONES ELAPSED TIME
(Weeks)
1 Date of subraittal of final control 2
plan to appropriate agency
2 Date of award of control device 9
contract
3 Date of initiation of on-site 25
construction or installation of
emission control equipment
4 Date by which on-site construction 37
•or installation of emission control
equipment is completed
5 Date by which final compliance is 40
achieved
-------
9-7-G
C. If the source has proposed an-alternative course of action to the
one closeribed in A. above, describe and evaluate the proposed alternative,
(attach copy of proposal, if available):
Estimated cost of remedial action
Estimated cost of action described in i'.A and I.C above if known (give
basis for estimate and attach study, if any):
Installed cost would range from $10,000 to $22,500 based on a
cost.of $2.00 to $4.50/SCFM.
Reference: Emissions Control in the Grain and Feed Industry.
Volume I - Engineering and Cost Study. Midwest Research
Institute. Prepared for Environmental Protection Agency,
Research Triangle Park, North Carolina, under Contract No.
68-02-0213, December 1973. Kansas City, Missouri.
-------
9-8-H
•PART II
DATA TO SUPPORT VIOLATIONS
I. Source I den I. i fi cat ion
A. llanio of Company: XYZ Grain and Seed Company
•[]. .Specific, soured within cited facility:
Source No. 9-8-IT - Truck Dump
I'. K'Miu i rrf'K.'n t( 5 ) violated by source:
Preventing Particulate from becoming Airborne APC-6
II. Ev-idC;nco support.imj violation
.A. [mission factors
1. Ca 1 cu I a tod pnri ss ions
a . wi l;h(iu t control S:
'(5,50.0 TPY) (4.5 Ib/T) (T/2000 Ib) '= 12.4 TPY
I), with control:; (known/estimated):
No controls
APC-6 states particulate emissions must be controlled,
APC-5 (8) Table 2 will apply to the control device.
'For a- 10,000 SCFM fabric filter, 1.17 TPY would be
allowed.
Neal S. Egan (PEDCo)
Donald J. I-Ienz, P.E. (PEDCo)
-------
9-8-H
PART 1 I
- 2 -
I). Smoke read i IHJS
1. noseri|)(, ion of smokereading evidence:
2. Names of individuals who can test.ify t.o I.ho above information;
C. Slack sampl iiK|
1. Description of stack sampling evidence:
?. flames nl individuals who can testify to the ahovo information:
I.', [.'videiici- indiraI inn missed increment, if dppl ica-
iy. |.|"cii!/ -nid explain niiy factors which may affecl the persuasive impact
Our emission estimates based on U.S. EPA emis'sion factors for
this type of operation. A better estimate of the actual
emissions could be obtained by source testing-.
-------
9-8-H
PART II
Abatement action':, which could ho Liken to dchieve compliance.'
A. Types oT controls:
A fabric filter control' device could bring the
source into compliance.
['. I'entrit'.ive compliance schedule •'
MILESTONES ELAPSED TIME
(Weeks-)
1 Date of submittal of final control' 2
plan to appropriate agency
2 Date of award of control device 9
contract
3 Date of initiation of on-site 25
construction or installation of
emission control equipment
4 Date by which on-site construction 37
or installation of emission control
equipment is completed
5 Date by which final compliance is 40
achieved.
-------
9-8-H
PART'ii
C. If the source has proposed an alternative course of action to the
one described in A. above, describe and evaluate the proposed alternati
(attach copy of proposal, if available):
ve,
I. Estimated cost of remedial action
Fslima ted cost of action described in I'.A and
basis for estimate and attach study, if any):-
I.C above i f known (gi ve
Installed cost would range from $17,500 to $40,000 based on a
cost of $1.75 to $4.00/SCFM.
Reference: 'Emissions Control in the Grain and Feed Industry.
Volume I - Engineering and Cost Study. Midwest Research
Institute. Prepared for Environmental Protection Agency,
Research Triangle Park, North Carolina, under Contract No.
68-02-0213, December 1973. Kansas City, Missouri.
-------
9-9-1
PART I
DATA TO SUPPORT VIOLATIONS
Source Identi ficaLion
A. ll,inie of i'nin|,.iny; XYZ Grain and Seed Company
B. Specific source within citod facility:
.Source No. 9-9-1 - Transferring and Elevating
Ri.'qu i remon t( s ) violated by source:
Preventing Particulate.. from becoming Airborne APC-6
Evidence support in
-------
9-9-1
I'A CM' 1
!i. Smokeread i IKJS
1. • Doscri pi. ion of smoke rood ing evidence
2. Names of; individuals who can testify to the -above informaL ion;
C. Stack san'ip I i IHJ
1. Description of stack sampling evidence;
lame", of individuals who can testify to fie above information:
D. LYidenr.c indicating missed increment, if applicable:
! V. liii"ifily .ind f/plain
-------
9-9-1
PART II
Alxitenient actions which could be Uiken to achieve compliance
A. lypes of controls.-
A fabric filter control device could bring the
source into compliance.
15. Tcntdtive compliance schedule :
MILESTONES ELAPSED TIME
(Weeks)
1 Date of submittal of final control 2
plan to appropriate agency
. 2 Date of award of control device 9
contract
3 Date of initiation of on-site 25
construction or installation of
emission control equipment
4 Date by which on-site construction 37
or installation of emission control
equipment is completed
5 Date by which final compliance is 40
achieved
-------
9-9-1
I'AR'I
[f the source has proposed on' alternative course of action to tiie
one described in A. a-bove, describe and evaluate the proposed alternative,
(attach copy of proposal, if available):
Estimated cost of n.-me'dial action
Estimated cost of action described in I.A and
basis for estimate and attach study, if any):
1. C above i f known (rji ve
Installed cost.would range from $2,250 to $4,500 based on a
cost of $1.50 to $3.00/SCFM.
Reference: Emissions Control in the Grain and Feed Industry,
Volume I - Engineering and Cost Study. Midwest Research
Institute. Prepared for Environmental Protection Agency,
Research. Triangle Park, North Carolina, under Contract No.
68-02-0213, December 1973. Kansas City, Missouri.
-------
9-11-K
PART If
DATA TO SUPPORT VIOLATIONS
I. ' Source I den I; i tication
A. flame of Company": XYZ Grain and Seed Company
B. Specific r.ourco within cited facility:
Source No. 9-11-K - Storage Bins
11. Requ i rumen t( !j) violated by source:
Preventing Particulate from becoming Airborne APC-6
II. Evidence support int.] violation
A. I mi ssion l;ac tors
I. C.i I en 1 a ted emi ssions
a . wi tfion t con tro 1 S:'
(5,500 TPY) (2 Ib/T) (T/2000 lb)'= 5.5 TPY
I), with controls (known/estimated):
No controls
Allowi.-d emi sr, ions
APC-6 states particulate emissions must be controlled,
APC-5 (8) Table 2 will apply to the control device.
For a 1500 SCFM fabric filter, 0.64 TPY would be allowed.
ilani!", I'l individuals who can l.e'..lily !» I In; -d>nve information:
Neal S. Egan (PEDCo)
Donald J/Henz, P.E. (PEDCo)
-------
9-11-K
PART 11
[i. Smoke read i IHJS
1. Doscri| it: ion of smokeread iiicj evidence
'/.. Names of 'individuals who can testify Lo I: lie.1 above in Formation:
C. S Lack samp.) i IKI
I. Uescr i |j|: ion of s(:ack sampling evidence:
'.'.. Hairn.", of individuals who can testify l.o I.he a hove infomidt. ion:
i ml i c.ci I. i h'j missed inci'emenl., if ,i|'|il if.,:f. ]••'.•
i V. Men'iiv .'mi I f'Xpl a i n any fact.ors which may affect (.he persuasive impact.
• i! i !'<: •' '.' i ••l''MCii: ' • • ..
Our emission estimates based on U.S. EPA emission factors for
this type of operation. A better estimate of the actual
emissions could be obtained by source testing.
-------
9-11-K
PART III
DESIRED ABATLMLNT ACT ION'
Abatement actions which could be taken to achieve coni|il iance
A. l.ypes of controls:
A fabric filter control device could bring the
source into compliance.
l.i. I'eMUil.ive compliance schedule'
MILESTONES ELAPSED TIME
(Weeks)
1 Da-te of submittal of final control 2
plan to appropriate agency
2 Date of award of control device 9
contract
3 Date of initiation of on-site 25
construction or installation .of
emission control equipment
4 Date by which on-site construction 37
or installation of emission control
equipment is completed
5 Date by which final compliance is 40
achieved
-------
9-11-K
I'AKT I 1 1
C. If (.he source has proposed an alternative course nf action to the
one described in A. above, describe and evaluate the proposed alternative,
(attach copy of proposal, if available):
I. Estimated cost-of remedial action
Estimated cost -of action described in l.A and
ba-sis for estimate and attach study, if any):
I . C above i f known (rj i ve
Installed cost would 'range from $2,250 to $4,500 based on a
cost of $1.50 to $3.00/SCFM.
Reference: Emissions Control in the Grain and Feed Industry
Volume I - Engineering and Cost Study. Midwest Research
Institute. Prepared for Environmental Protection Agency,
Research Traingle Park, North Carolina, under Contract No.
68-02-0213, December .1973. Kansas City, Missouri.
-------
9-12-L
['ART ! I
DATA TO SUPPORT VIOLATIONS
I, Source- Identi Mention
A. (lame of Company: XYZ Grain and Seed Company
B. Spocifu source within cited facility:
Source No. 9-12-L - Rail Loadout
II. Roqu ire'inon t( s ) violated by source:
Preventing Particulate from becoming Airborne APC-6
II. Evidence supporting violation
A. ['miss ion factors
I. •Calculnled emissions
a . w i tliou t control S:
(275 TPY) (4 Ib/T) (T/2000 Ib) =0.55 TPY
b. with controls (known/estimated):
No controls
APC-6 states particulate emissions must be controlled,
APC-5 (8) Table 2 will 'apply to the control device.
For a 5000 SCFM fabric filter, ^0.02 TPY would be allowed,
iliiii!'.:', ij I i ml i v i duo I s who can (.esiify lo Hi:1 .ihovi.1 information:
Neal S. Egan (PEDCo)
Donald J. Henz, P.E. (PEDCo)
-------
9-12-L
PART 1 I
R. Smoke-readi mjs
1. Oescript ion of sinokereadim] evidence
?.. Names of .individuals who can testify Lo the above information:
C. . S lad; sampl i IHJ
I. Inscription of stack sampling evidence;
2 .. llaiHL- '.>.() f ind i v iflnal s who can testify to thr above information:
LVidoin:; indicatiru] missed increment, if ap'pl ical
I'iui'ilv 'iinl i'''|.')ain tiny factors which may .if ted the |,'ersuasive impact
ci 11 • i..- (•„• •/ i v 11 -11 c e:
Our emission estimates based on U. S. EPA emission factors for
this type of operation. A better estimate of the actual
emissions could be obtained by source testing.
-------
9-12-L
PART II-i
DliSIREl) ABAJU-eiT AC I lUIl;
Alid ti'iiien L actions which could 'be Ukejrto achieve compl ianco
'\. Ivi'C"'. ill conl.rol ?;:
A fabric filter control device could bring the
source into compliance.
I'. Tenlcilive compliance1 schoclul e:
MILESTONES . • ELAPSED TIME
(Weeks)
1 . Date of submit-tal of final control 2
plan to appropriate agency
2 Date of award of control device . 9
contract
3 Date of initiation of on-site ' 25
construction or installation of
emission control equipment
4 Date by which on-site construction 37
or installation of emission control
equipment is completed
5 Date by which final compliance is ' 40
achieved
-------
9-12-L
I'AIM I 1.1
C. If the source has proposed an alternative course o'f actio.ri to the
'one described in A. above, describe and evaluate the proposed alternative,
(attach copy of proposal, if available):
Estimated cost of remedial action
Estimated cost of action described, in I.A and I.C above if knov/n (give
basis for estimate and attach study,- if any):
Installed co'st would range from $10,000 to $22,500 based on a
cost of $2.00 to -$4.50/SCFM.
Reference: Emissions Control in the Grain and Feed Industry
.Volume I - Engineering and Cost Study. Midwest Research
Institute. Prepared for Environmental Protection Agency,
Resea::ch Triangle Park, North Carolina, under Contract No.
68-02-0213, December 1973. Kansas City, Missouri.
-------
9-13-M
PART II
DATA TO SUPPORT VIOLATIONS
Source 1 dent i I icat ion
A. Ihme of Company: XYZ Grain and Seed Company.
I',. r.pecilic source within cited Facility:
Source No. 9-13-M - Truck Loadout
II. Refill i reniont(s ) violated by source:
Preventing Particulate from becoming Airborne APC-6
II. livulence support. in: • •
(275 TPY) (4.5 Ib/T) (T/2000 Ib) = 0.62 TPY
b. with controls (known/cs I'.iniri tecl):
No controls
','. AI l()/,'f:d oiii'i ^s ions • .
APC-6 states particulate emissions must be controlled,
APC-5 (8) Table 2 will apply to the control device.
For a 5000 SCFM fabric filter,.0.02 TPY would be allowed
'•). ili'ini!: . ul i IK! i v i rliKi I'., wlui rrin tosln/ to tin: .ibcivi.: in fornid I. ion :
Neal S. Egan' (PEDCo)
Donald J. Henz, P.E. (PEDCo)
-------
9-13-M
I'AKT 1 1
[1. Sinokeroadi nus
1. Description of" smokeread inn, evidence.'
?.. flames ol individuals who can testify to the above information
('.. SIack '.jiini|/l iiif)
I. Description of stack Siiinpliiig evidence;
1. lldiiu.-1-, ol individuals who can testify to (.IIP aliovc i n forma I. ion:
I). !vi Ifjnci' i n.l i en t i ny missed increment, if appl ic.il; li;.-
Id'-niiiy ,-ini| oxploiii any factors which may affect the persuasive impact
u f I IK; (..-',' i dt'iicc:
Our emission estimates based on U.S. EPA emission factors for
this type-of -operation. A better estimate of the actual
emissions could be obtained by source testing.
-------
9-13-M
PART ffl
A|>.i (.omen I ,'icM'ons v/hich could be Uiken to cichiove compl iance
A. 'I v'|"'1; ol conLro I s : .
A fabric filter control device could bring the
source into compliance.
l!. Ten Ui live compliance scliotluli?:
MILESTONES ELAPSED TIME
(Weeks)
1 Date of submittal of final control 2
plan to appropriate agency
2 Date of award of control device 9
contract
3 Date of initiation of on-site 25
construction or installation of
.emission control equipment
4 Date by which on-site construction 37
or installation of emission control
equipment is completed
5 Date by which final compliance, is 40
achieved
-------
9-13-M
I'AIM' I 1 I
C. If the .source has proposed an alternative course of fiction to the
one described in A. above, describe and evaluate the proposed alternative,
(attach copy of proposal, if available): '
11. Estimated cost of remedial action
'Estimated cost of action described in I. A and
basis for estimate and attach study, if any):
I.e. above if known (give
Installed cost would range from $10,000 to $22,500 based on a
cost of $2.00 to $4.50/SCFM.
Reference: Emissions Control in the Grain and Feed Industry.
Volume I - Engineering and Cost Study. Midwest Research
Institute. Prepared for Environmental Protection Agency,
Research Triangle Park, North Carolina, under Contract No.
68-02-0213, December 1973. Kansas City, Missouri.
-------
9-14-N
PART FI
DATA TO SUPPORT VIOLATIONS
I. Source I dun t:i f ica Lion
A. flame of Company: XYZ Grain and Seed Company .
1-5. Specific source within citod facility: .
'Source No. 9-14-N - Flat Storage - Unloading
II'. Rijt|u i remont( s ) viola Led by source:
Preventing Particulate from becoming Airborne APC-6
II. Evidence supportitK) violation
A. ['mission factors
I. CaI ui I a tod omissions
a; w i ihouL' control s;
(3,850 TEY) (2 Ib/T) (T/2000 Ib) - 3.85 TPY
I), with controls (known/os tima tod):
No controls
All uw:;d (.'iiri s:; ions
APC-6 states particulate emissions must be controlled,
APC-5 (8) Table 2 will apply to the control device.
For a 1500 SCFM fabric filter, 0.06 TPY would be
allowed.
'<. ilain1.-'. i.'I' individuals who ran iiritir/ In I h:: ahnvo i n I orma I, ion :
Neal S. Egan (PEDCo)
Donald J. Henz, P.E. (PEDCo)
-------
9-14-N
PART 11
_ 9 _
R. Smokeroadi IKJS
1. Debr.i'i|)(. ion of smokerocidi ny evidence
2. Dames of i nd i vidual s who can testify tiv the above information
C. Stack iampl iiHj
I. Description, of stack sampling evidence:
?. [lames ol iiui i vidua I s who can testify lo Hie above information
0. I. v i dune a' in>l i (.a i. iiKj missed incromen I., if
-------
9-14-N
PART II
Abatement actions which could bo taken to achieve conipl iamce
A. Types of controls;
A fabric filter control device could bring the
source into compliance.
is. Tentative compliance schedule-'
MILESTONES ELAPSED TIME
(Weeks)
1 Date of submittal of final control 2
plan to appropriate agency
2 Date of award of control device 9
contract
3 Date of initiation of on-site 25
construction or installation of
emission control equipment
4 Date by which on-site construction 37
or installation of emission control
equipment is completed
5 Date by which final compliance is 40
achieved
-------
9-14-N
I'ARF III
C. If the source has proposed an alternative course of action to the
one described in A. above, describe and evaluate the proposed alternative,
(attach copy of proposal, if available):
II. Estimated cost of remedial action
Estimated cost of action described in I.A and l.C above if known -(give
basis for estimate and attach study, if any):
Installed cost \vould range from $2,250 to $4,500 based on a
cost of $1.50 to $3.00/SCFM.
Reference: Emissions Control in the Grain and Feed Industry,
Volume I - Engineering and Cos,t Study. Midwest Research
Institute. Prepared for Environmental Protection Agency,
Research Triangle Park, North Carolina, under Contract No.
68-02-0213, December 1973. Kansas City, Missouri.
-------
9-15-0
PART I I
DATA TO SUPPORT VIOLATIONS
Source? 1 den t i f i ca t ion
A. Haine of Company: XYZ Grain and Seed Company
I!. I'pet.ilic source? v/i thin cHf.'d -faci 1 i ty:
Source No. 9-15-0 - Flat Storage - Loading
P.pi|n i remen i.(s ) violated by. source:
Preventing Particulate from becoming Airborne APC-6
Ev i donee;, support iruj violation
A', [.mission ("actors
1. Caleu I a Ied omissions
a . v/i Lliotil.. control s:
. (3,850 TPY) (2 Ib/T) (T/2000 Ib) = 3.85 TPY
h. v/i tli controls (known/cs t iina ted ):
No controls
/'. Allov/"d omissions
APC-6 states particulate emissions must be controlled,
APC-5 (8) Table 2 will apply to the control device.
For a 1500 SCFM fabric filter, 0.20 TPY would be
allowed.
•:.. [Mil!'." nl individuals who can testify to Hie dbovf information:
Neal S. Egan (PEDCo)
Donald J. Henz, P.E. (PEDCo)
-------
9-15-0
I-'AKT
- 2 -
B. SniDkereadi mjs
I. Dcscri i)l. ion of sinokeri.'od-i ncj evidence:
?.. Names of individuals who can testify In lluj above in forma Lion:
C . :> I..H. I: sampl i IK)
I. Ucscr i |)l. ion . of stack sampling
of individuals v/ho can tor.tifv Lu I ho ahovo infoniirjt ion:
iiiilicci i inq missed ino'emen !., if
V. Idontify and explain any factors which may afU'Cl the- persuasive impact
i I '.I'M.1 (:'/ idi'iicc:
Our emission estimates based on U.S. EPA emission factors for
this type of operation.- A better estimate of the actual
emissions could be obtained by source testing.
-------
9-15-0
PART III
IJL:S I R!•:I). ABA] L"MLNT_ AJ;jjj)N'
Al),H(Nnonl, oct, inns v/hich could ho token lo
-------
9-15-0
C. If Lite source;. has proposed an al terna l;i ve course of action to the
•one described in A. above, describe and evaluate the proposed al terna tives
(attach copy of proposal, if avail-able):
I. Estimated cost of remedial action •
Estimated cost.of action described in I.A and I.C above H known (qive
'basis for estimate and attach study, if any):
Installed cost would range from $10,000 to $22',500 based on a
cost of $2.00 to-$4.50/SCFM.
Reference: Emissions Control in the Grain and Feed Industry.
Volume I - Engineering and Cost Study. Midwest Research
Institute. Prepared for Environmental Protection Agency,
Research Triangle Park,.North Carolina, under Contract No.
68-02-0213, December 1973. Kansas City, Missouri.
-------
Minnesota Grain ElevMlcrs
Compliance Status Deterininalion ~
Calculations .V
Z__o,J_Z.
i( )PEDCo- ENVIRONMENTAL
SUITE 13 • ATKINSON SQUARE
CINCINNATI. OHIO .452^6
513/771--4 33O
Company name: XYZ Grain and Seed Company
Dale:
D.
i / --j- C / '
L^Q^J^.A-d.£j&aJlL®J3^
QL^£ ~r jow/_ * /, f)oo
b
r 3&&Q /hr ___________
1 / i f
ngr/ *si '
wn // '<* nee , A PC.
^
_CU]CL T/vnS -for /i Ed '<
^£-JirJ^^ ____
____ _ ___ _____ _ ____________________
Em ^$/ '
>=AL3. TfY
£H7T
re«ure
=1.27
-------
Minnesota Grain Elevators
• Compliance Status Determination
Calculations
ol
- ENVIRONMENTAL
SUITE 13 • ATKINSON SQUARI£
CINCINNATI. OHIO 152.46
513 / 7 7 1 - A 3 3 O
Company name: XYZ Grain and Seed Company
No.
Date:
-
g
' f>
/ roce.s$
* / j
_
J^ — ..._
/Q T/vns -for /}£::£. '-
(l.ooogoo
^~ "
1 1 } ' /'i r^s\
Hourly < (^OO
/~ 'J <<) rt
7r/>-Z%cl /fa
J>J
/ /***
device '.
w
s.^^mm^l7h-
-
-------
Minnesota Grain Elevalors
Compliance Status Determination
Calculations
By:
JEIP1/ IPEDCo - EN.VI RONMENTAL
SUITE 13 • ATKINSON S O U A R E
CINCINNATI. OHIO A 5 2 A 6
513 / 7 7 1 - -4 3 3 O
Company name: XYZ Grain and Seed Company
.No.
'Date: 6/2//74~
9
, 000 , OOO
+
& / /-; ^jo
PC -^
14..^. itfL c.£-.p.r£j/e/L
/ttAjj&JZ '. „.
/ •
C^LLCdJU^.
vr // /E(2 -
,GOO ,000
.4/7/7 ^ :
. Q
^ ^ •*'
7/7
fe
: 2
''('2QOO
^^^
-------
Minnesota Grain Elevators
Compliance Status Determination'
Calculations
illtiet
> 17
By:
Company name; XYZ Grain and Seed Company
PEDCo-ENVIRONMENTAL
SUITE 13 • ATKINSON SQUARE
CI N C I N N AT I, OHIO 452 4 6
513 / 7 71-4330
No:
A-^r
.
^
-rc£ c^&te£/(3J2£.-e- wj£/2_A.fc-
" ............... " ...... ~ ' "' " ....... "T ........
_ _...
-------
Sheet.
of /7
Minnesota Grain Elev.itnrs
Compliance Status Determination
Calculations
jHHu,,-;,;_ JPEDCo- ENVIRONMENTAL
SUITE 13 • ATKINSON SQUARE
CINCINNATI, OHIO 1 5 2 A 6
513/771-4330
Company name; XYZ Grain and Seed Company
.No.
9 —-JZT /
—
o
~ n. :
-f/ow/
, /OOP
I d~ JLJ- /
____ :
&® //ir/yc6c«rJ 1' 2/ /hr
-------
•Minnesota Grain Elevators
Compliance Status Determination
Calculations
By :
bnuel s5 ol _..,/_/
PEDCo - ENVIRONMENTAL.
SUITE 13 • ATKINSON SQUARE
CINCINNATI. OHIO ^ 5 2 » 6
513 /771-133O
Company name: XYZ Grain and Seed Company
No
._£
Date:
? .
9— 4~~ D ..'
/
-------
Minnesota Crain Elevators
Compliance Status Determination
Calculations
By' /1/
blicel_ '/ i
)PEDCo-ENVIRONMENTAL. '. •
SUITE 13 • ATKINSON SQUARE
CINCINNATI. OHIO A 5 2 A 6
513 / 77 1 -A3 3O
Company name: XYZ Grain and Seed Company
No.
^pop'jG.Q J^n ~ror/r7A Tibn '•
3OOP
e 7^r/77fn^ r/'an •
I
4 i I J. *J- JJ- „
M
-^L^LE^L
7 oo e
- - -
I g , ^'^
Annua. •'
oo
. O
• (-
ti
t
: 3000
evce ; ^OOO $
^ooo\<;cf^Y^%o™%)^ = +Jg%
\J
Anno* I: (3 LhT PYX I. — • 9873) =6.
-------
Minnesota Grain Elevators
Compliance Status Determination
Calculations
blieel. £> ol /_
Company,name: XYZ Grain and Seed Company
PEDCo- ENVIRONMENTAL
SUITE 13 • ATKINSON SQUARE
CINCINNATI. OHIO ^152-46
513/771- n 3 3 O
,No.
/£>. ___ 9
~~
raa
e
n&oo r /e Q
-for/na r>$n '•
'< ! , &OQ
~
'/7
-------
( / /
Minnesota Grain Elevator';
Compliance Status Determination
Calculations
By:
jMyxul; JPEDCo- ENVIRONMENTAL
SUITE 13 • ATKINSON SQUARE
CINCINNATI, OHIO A 5 2 4 6
513 / 7 7 1 • -4 3 3 O
Company name: XYZ Grain and Seed Company
,-No.
f—-\ I I s* , I
r\G,porT^
.y:^-^^^^^^
.?m)' ^
-------
Sheet V of
7
Minnesota Grain Elevators
Compliance Status Determination
Calculations
By:
Company name; XYZ Grain and Seed Company
PEDCo-- ENVIRONMENTAL
. SUITE 13 • ATKINSON SQUARE
CINCINNATI. OHIO A- 5 2A 6
513 /7V1-433O
,No.
Date:
Pro-
.Q
too,
__^.
/cn_
:_y2^_ZL2^LL/^^^^ .
£77?/
«^E
TPY
_j2_A£e^
J--Z~-]/i/i^ ] — Osi /—^^
^L-j.?.4-/WSj - 70<^ /o
= i,i7~rpy
-------
Minnesota Grain Elevators
Compliance Status Determination
Calculations
Sheet )O u( / /
By:
Company name: XYZ Grain and Seed Company
PEDCO- ENVIRONMENTAL
.')/ , SUITE 13 • ATKIN'SON SQUARE
.CINCINNATI, OHIO A 5 2 A 6
513 / 7 7 1 - 4 3 3 O
Date:
P
rooe&s,
'< 'L
s
&OO
-r
, /OOP
jOjf2_L '. : :
i2&-£jjl*jQj££j>^J^^^
4 * i JL 4- jj r
?ar //c-U /a Te... /?."?m<3 re, -
' ~
N _ . "^ /^
- 1,27 Ar
LnLr. P.:J2.~r.f Y......
-------
Minnesota Grain Elevators
Compliance Status Determination
Calculations
BY
: Ale., a/. £^&\a f7
u|
BM>»' )PEDCo- ENVIRONMENTAL
SUITE 13 • ATKINSON SQUARE
CINCINNATI, OHIO 452.46
513 / 7 7 1 -^3 3O
Company name: XYZ Grain and Seed Company
No.
Date:
^.^2.^
/
C
~, 12
e>T_
£o.
%>^&OOQ_£_$J®_
-------
i / /
Minnesota Grain Elev.-l.'.rs
Compliance Status Detei iniiialion
Calculations
By:._Z!
Meo JPEDCo- ENVIRONMENTAL
SUITE 13 • ATKINSON S O U A R £
CINCINNATI. OHIO A 5 2 4 6
513/771-4330
Company name: XYZ Grain and Seed Company
No.
Date:
^L_.A/^.-.'. ...... 9 *~ /o - -TV
\/.y tf^od
i y - - XLi- ......
> (jp/v •f/'uooo cwujcf ^Afi^7j7v(7^^/y~ Z&sffl
~ f-J'- - ~\^£.~ - _^__- . _ f f fiil^ .^fc, vj~ I if:
b.^dtl^^//l^(ilji^A
_
(-,%A-£&-jJ^Tpy^ i
121
7
/ on -
..... —
.
?/ 5 -So o r7
-------
Minnesota Grain Elev.i'crs
Coni|)li.ince '.Status Determination
Calculations
By:
1A»\-PL
JpT JPEDCo-EN VI RON MENTAL
SUITE 13 • ATKI N SO N SOU AR E
CINCINNATI, OHIO A 5 2-4 G
513/771-^1330
Company name: XYZ Grain and Seed Company
No..
nQ Tf on '
LjL —.
4££A
\t>,
ll •*.} '
Hourly .i
bLf
^-
n/- // r
0
--!, 21
-------
Minnesota Grain Elevators
Compliance Status Determination
Calculations
By-'
Company name: XYZ Grain and Seed Company
bhcet
Uo jPEDCo- ENVIRONMENTAL
SUITE 13 • ATKINSON SQUARE
CINCINNATI. OHIO -452-46
513/771-4330
.No.
o
f
I /- i i
^2_J=ZZ^_J^^22^_2jL^7_I
/e i/ic-G^'' A/ort
'&—J2&.
r
Jl£J)j£t/Lc£nrj^e.aJu
O, OOP
— -^ -r-
— 27^
£'•»
fr? /55/ d) /
ulsiJ^
I ( 1000
; / x,
- O
e^
OO SC-
>r~
•£000
r
/
-------
Mirnesota Grain Elevitors
Compliance Status Determination
Calculations
By'
Company name: XYZ Grain and Seed Company
blieet ul
Mt. iPEDCo- ENVIRONMENTAL
SUITE 13 • ATKINSON SQUARE
CINCINNATI, OHIO -45246
513 / 7 7 1 -.43 3O
e. A/&. 9
3
/.—^t®.£L
£&£
" ~" "S^^^£^^
^.-^Y^^Si^K^^
'^.^_Z!^_Zfe. £^L.../y^.^_^y_..C,.<5/7.7/^./
J.evtce I 5~0&fi _sc-
f
- j
- f >
^(/.-^rK^ '}^%
...f _ v^/ ^.-p-.*.^- ._-yr..x^- _.^ . .
-------
Minnesota Grain Elevator1:
Coii'pliance Status Determination
Calculations
Sneel ]£> of / /
By:
Company name: XYZ Grain and Seed Company
PEDCo- ENVIRONMENTAL
SUITE 13 • ATKINSON SQUARE
CINCINNATI. OHIO. 45 2 AS
513 77-71-4330
,No.
Date:
9 — /4--A/'- F/«+- S
g JZT/? fo'r/r?.* nfr
2zr_
'O tV PAJ~£ T 6£_^:y.j:>j'C:.f<./_C-6'j3J&.L
e '. 15~£> r>
Allou/'able, _•!
/ e/?6 1/ r e 4 ^/r^
" "•' ^~ '~
= 9 $,
-------
Minnesota Grain Elevator:;
Coniplionce Status Determination
Calculations
By:
Company name: XYZ Grain and Seed Company
- ENVIRONMENTAL
SUITE 13 • ATKINSON SQUARE
CINCIN N ATI. OH IO 45246
513 /771-4330
No..
7
•sj
Pr,
ocess,
-f
bo.
>£„
I/e f~
Ts
, A PC~<£> /y
a
IOu Iz T/vnS -for . /)Ed '-
Q+o, 00$
- 3.
u
/
3 .
pyy(i.
-O.ZQ ~rey
------- |