EPA-450/2-77-001a
January 1977
STANDARDS SUPPORT
AND ENVIRONMENTAL
IMPACT STATEMENT
VOLUME 1:
PROPOSED STANDARDS
OF PERFORMANCE
FOR GRAIN ELEVATOR
INDUSTRY
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
-------
4^#faujL/
(I V
~tfctct/&MUM&A
s? j / >^L«_ *» £s
{j, cy ex
V
-------
EPA-450/2-77-001a
STANDARDS SUPPORT
AND ENVIRONMENTAL
IMPACT STATEMENT
VOLUME 1:
PROPOSED STANDARDS
OF PERFORMANCE
FOR GRAIN ELEVATOR INDUSTRY
Emission Standards and Engineering Division
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
January 1977
-------
This report has been reviewed by the Emission Standards and Engineering Division, Office of Air
Quality Planning and Standards, Office of Air and Waste Management, Environmental Protection
Agency, and approved for publication. Mention of company or product names does not constitute
endorsement by EPA, Copies are available free of charge to Federal employees, current contractors
and grantees, and non-profit organizations—as supplies permit—from the Library Services Office,
Environmental Protection Agency, Research Triangle Park, North Carolina 27711; or may be
obtained, for a fee, from the National Technical information Service, 5285 Pott Royal Road,
Springfield, Virginia 22161.
11
-------
Draft
Standards Support and
Environmental Impact Statement
Grain Elevators
Type of Actiont Administrative
Prepared by
Don R. Goodwin, Director (Date)
Emission Standards and Engineering Division
Environmental Protection Agency
Research Triangle Park, N. C. 27711
Approved by
Roger Strelow (Date)
Assistant Administrator for Air and Waste Management
Environmental Protection Agency
401 M Street, S.W.
Washington, D. C. 20460
Draft Statement Submitted to Council on Environmental Quality
in
January 1977
(Date)
Additional copies may be obtained or reviewed at:
Public Information Center (PM-21S)
Environmental Protection Agency
Washington, D. C, 20460
111
-------
INTRODUCTION
Standards of performance under section 111 of the Clean Air
Act are proposed following a detailed investigation of i1r pollution
control methods available to the affected industry and the impact
of their costs on the industry. This document summarizles the
information obtained from such a study of the grain elevator
industry. Its ouroose is to explain in detail the background and
basis of the proposed standards and to facilitate analysis of the
proposed standards by interested persons, including those who may
not be familiar with the many technical aspects of the industry.
To obtain additional copies of this document or the Federal Rejjster
notice of proposed standards, write to the Public Information Center
(PM-21S), Environmental Protection Agency, Washington, D. C. 20460
(specify name of document).
AUTHORITY FOR THE STANDARDS
Standards of performance for new stationary sources are
developed under section 111 of the Clean Air Act (42 U.S.C. 18S?c-6|»
as amended in 1970, Section 111 requires the establishment of
standards of oerformance for new stationary sources of air pollution
which ", . .may contribute significantly to air pollution which
causes or contributes to the endangerment of public health or
welfare." The Act requires that standards of performance for such
-------
sources reflect ". . .the degree of emission limitation achievable
through the application of the best system of emission reduction
which (taking into account the cost of achieving such reduction)
the Administrator determines has been adequately demonstrated."
The standards apply only to stationary sources, the construction
or modification of which commences after regulations are proposed
by publication in the Federal Register.
Section 111 prescribes three steps to follow in establishing
standards of performance.
1. The Administrator must identify those categories of
stationary sources for which standards of performance
will ultimately be promulgated by listing them in the
Federa1 Reg i s ter.
2. The regulations applicable to a category so listed must
be proposed by publication in the Federal JtegJster
within 120 days of its listing. This prooosal provides
interested persons an opportunity for comment.
3. Within 90 days after proposal, the Administrator must
promulgate standards with any alterations he deems
appropriate.
Standards of performance, by themselves, do not guarantee
protection of health or welfare; that is, they are not designed
to achieve any specific air guallty levels. Rather, they are
designed to reflect best demonstrated technology (taking into
account costs) for the affected sources. The overriding purpose
v1
-------
of the collective body of standards Is to maintain existing air
quality and to prevent new pollution problems from developing.
Previous legal challenges to standards of performance have
resulted in several court decisions^ of importance in developing
future standards. In those cases, the principal issues were whether
EPA: (1) made reasoned decisions and fully explained the basis
of the standards, (2) made available to interested parties the
information on which the standards were based, and (3) adequately
considered significant comments from interested parties.
Among other things, the court decisions established: (1) that
preparation of an environmental impact statement is not necessary
for standards developed under section 111 of the Clean Air Act
because under this section EPA must consider any counter-productive
environmental effects of a standard in determining what system
of control is "best;" (2) in considering costs it is not necessary
to provide a cost-benefit analysis; (3) EPA is not required to
justify standards that require different levels of control
in different industries unless such different standards may be
unfairly discriminatory; and (4) it is sufficient for EPA to show
that a standard can be achieved rather than that it has been
achieved by existing sources.
Promulgation of standards of performance does not prevent
State or local agencies from adooting more stringent emission
limitations for the same sources. On the contrary, section 116
of the Act (42 U.S.C. 1857-D-l) makes clear that States and
other political subdivisions may enact more restrictive standards.
vii
-------
Furthermore, in heavily polluted areas more stringent standards may
be required under section 110 of the Act (42 U.S.C, 1857c-5) in
order to attain or maintain national Ambient Air Quality Standards
prescribed under section 119 (42 U.S.C, 1857c-4). Finally, section 116
makes clear that a State may not adopt or enforce less stringent
new source oerforaance standards than those adooted by EPA under
section 111.
Although standards of performance are normally structured in
terms of numerical emission limits where feasible, alternative
approaches are sometimes necessary. In cases physical measure-
rent of emissions from a new source may be impractical or exorbitantly
exnensive. For example, emissions of hydrocarbons from storage
vessels for petroleum liquids occur during storage and during tank
filling. The nature of the emissions (hiqh concentrations for short
periods during filling and low concentrations for lonoier periods
during storage) and the configuration of storage tanks make direct
emission measurement highly impractical. Therefore, a more nractical
approach to standards of performance for storage vessels has been
eguipment specifications,
SELECTION OF CATEGORIES OF STATIONARY SOURCES
Section 111 directs the Administrator to publish and from time
to time revise a list of categories of sources for which standards
of performance are to be proposed. A category is to be selected
". . .if [the Administrator] determines it may contribute significantly
to air pollution which causes or contributes to the endangerment
of public health or welfare."
viii
-------
Considerable attention has been qiven to the development of
a methodology for assigning priorities to various source categories.
In brief, the approach that has evolved is as follows: Specific
areas of emphasis are identified by considering the broad strategy
of the Agency for implementing the Clean Air Act. Often, these "areas"
are actually pollutants which are primarily emitted by stationary
sources. Source categories which emit these pollutants are then
evaluated and ranked taking into account such factors as (1) the level
of emission control (if any) already required by State regulations;
(2) estimated levels of control that might result from standards of
performance for the source category; (3) projections of growth and
replacement of existing facilities for the source cateaory; and (4) the
estimated incremental amount of air pollution that could be prevented,
in a preselected future year, by standards of performance for the
source category.
An estimate is then made of the time required to develop
a standard. In some cases, it may not be feasible to develop
a standard immediately for a source category with a high nriority.
This circumstance might occur because a program of research and
development is needed to develop control techniques or because
techniques for sampling and measuring emissions may require refinement.
Selection of a source category for standards development leads
to another major decision: determination of the tyoes of sources
or facilities to which standards will aooly, A source category
often has several facilities that cause air pollution. Emissions
ix
-------
from some of these facilities may be insignificant or very expensive
to control. An investigation of economics may show that, within
the costs that an owner could reasonably afford, air pollution
control is better served by applying standards to the most severe
oollution problems. For this reason (or perhaps because there
may be no adequately demonstrated system to control emissions
from certain facilities), standards often do not apply to all
sources within a category. For similar reasons, the standards
may not apply to all air pollutants emitted by such sources. Con-
sequently, although a source category may be selected to be
covered by standards of performance, not all pollutants or
facilities within that source category may be covered by the standards,
PROCEDURE FOR DEVELOPMENT OF STANDARDS OF PERFORMANCE
Congress mandated that sources regulated under section 111
of the Clean Air Act utilize the best system of air pollution
control (considering cost) that has been adequately demonstrated
at the time of their design and construction. In so doing, Congress
sought to:
1. Maintain existing air quality
2. Prevent new air pollution problems, and
3. Ensure uniform national standards for new facilities.
Standards of performance, therefore, must (1) realistically
reflect best demonstrated control practice; (2) adequately consider
the cost of such control; (3) be applicable to existing sources
that are modified as well as new installations; and (4) meet these
-------
conditions for all variations of operating conditions beinq considered
anywhere in the country.
The objective of a nroqram for develoninq standards of nerformance
1s to identify the best system of emission reduction which "has been
adequately demonstrated {considering costs)," The legislative history
of section 111 and the court decisions referred to earlier make clear
that the Administrator's judgment of what is adequately demonstrated
is not limited to systems that are in actual routine use. Consequently,
the investigation may include a technical assessment of control systems
which have been adequately demonstrated but for which there is
limited operational experience. In most cases, determination of the
"dearee of emission limitation achievable" is based on results of
tests of emissions from existing sources. This has required worldwide
investigation and measurement of emissions from control systems. Other
countries with heavily oooulated, industrialized areas have sometimes
develooed more effective svsterns of control than those in the United States.
Since the best demonstrated systems of emission reduction may not
be In widesnread use, the data base upon which standards are developed
mav be somewhat limited. Test data on existing we11-controlled sources
are an obvious starting point in developing emission limits for new sources,
However, since the control of existing sources generally represents
retrofit techno!ogy or was originally designed to meet an existing State
or local regulation, new sources may be able to meet more stringent
emission standards. Other information, however» is also considered
and judgment is necessarily involved in develooing standards.
xi
-------
A process for the development of a standard has evolved. In general,
it follows the guidelines below,
1. Emissions from existing well-controlled sources are measured.
2. Data on emissions from such sources are assessed with
consideration for such factors as: (a) the representative-
ness of the source tested (feedstock, operation, size, aqet
etc.); (b) the age and maintenance of the control equipment
tested (and possible degradation in the efficiency of control
of similar new equipment even with good maintenance procedures);
(c) the design uncertainties for the type of control equipment
being considered; and (d) the degree of uncertainty that new
sources will be able to achieve similar levels o"-f control,
3. Durinq development of the standards, information from
pilot and prototype installations, guarantees by vendors
of control equipment, contracted (but not yet constructed)
projects, foreign technology, and published literature are
considered, especially for sources where "emerginq" technologv
appears significant.
4, Where possible, standards are developed which permit the
use of more than one control technique or licensed process.
5. Where possible, standards are developed to encourage (or
at least oermit) the use of process modifications or new
processes as a method of control rather than "add-on" systems
of air pollution control.
xii
-------
6. Where possible, standards are developed to permit s.ysteits
capable of controlling more than one pollutant (for examole,
a scrubber can remove both gaseous and oarticulate matter
emissions, whereas an electrostatic orecipitator is soecific
to oarticulate matter),
7, Where appropriate, standards for visible emissions are
develooed in conjunction with concentration/mass emission
standards. The opacity standard is established at a level
which will require proper operation and maintenance of the
emission control system installed to meet the concentration/
mass standard on a day-to-day basis, but not require the
installation of a control system more efficient or expensive
than that required by the concentration/mass standard. In
some cases, however, it is not oossible to develoo concen-
tration/mass standards, such as with sources of fugitive
emissions. In these cases, opacity standards or equipment
standards may be developed to limit emissions.
CONSIDERATION OF COSTS
Section 111 of the Clean Air Act requires that costs be considered
in develooing standards of performance. This requires an assessment •
of the possible economic effects of implementing various levels of
control technology in new plants within a given industry. The first
step in this analysis requires the generation of estimates of installed
caoital costs and annual operating costs for various demonstrated control
xiii
-------
systems, with each control system alternative having a different overall
control capability. The final step in the analvsis is to determine
the economic imnact of the various control alternatives uoon a new Plant
in the industry. The fundamental question to be addressed is whether
or not a new plant would be constructed if a certain level of control
costs will be incurred. Other aspects that are analyzed are the
effects of control costs upon product prices and product suoolies,
and producer profitability.
The economic impact of a proposed standard uoon an industry is
usually addressed both in absolute terms and by comparison with the
control costs that would be incurred as a result of compliance with
typical existing State control regulations. This incremental approach
is taken since a new plant would be required to comply with State
regulations in the absence of a Federal standard of performance. This
approach requires a detailed analysis of the impact upon the industry
resulting from the cost differential that exists between a standard
of performance and the typical State standard.
The costs for control of air oollutants are not the only, control
costs considered. Total environmental costs for control of water
pollutants as well as air pollutants are analyzed wherever possible.
A thorough study of the profitability and pr^ce-setting mechanisms
of the Industry is essential to the analysis so that an accurate
estimate of potential adverse economic impacts can be made. It is
also essential to know the capital requirements placed on plants
xiv
-------
in the absence of Federal standards of oerformanci so that the
additional caoital requirements necessitated by these standards
can be placed in the oroper perspective. Finally, it 1s necessary
to recognize any constraints on capital availability within an
industry as this factor also influences the ability of new plants
to generate the caoital required for installation of the additional
control equipment needed to meet the standards of performance.
CONSIDERATION OF ENVIRONMENTAL
Section 102(2)(c) of the National Environmental Policy Act (NEPA)
of 1969 (PL 91-190) requires Federal agencies to prepare detailed
environmental impact statements on pronosals for legislation and other
major Federal actions significantly affecting the quality of the
human environment. The objective of NEPA is to build into the
decision-making process of Federal agencies a careful consideration
of all environmental aspects of prooosed actions.
As mentioned earlier, in a number of legal challenges to standards
of oerformance for various industries, the Federal Courts of Appeals
have held that environmental impact statements need not he orenared
by the Agency for proposed actions under section 111 of the Clean
Air Act. Essentially, the Federal Courts of Appeals have determined
that "...Section 111 of the Clean Air Act, orooerly construed, requires
the functional equivalent of a NEPA imoact statement" in the sense that
the criteria "...the best system of emission reduction," "...require(s)
the Administrator to take into account counter-oroductive environmental
effects on a proposed standard, as well as economic costs to the industry..."
xv
-------
On this basis, therefore, the Courts "...established) a narrow
1 2
exemption from NEPA for EPA determinations under section 111."'
In addition to these judicial determinations, the Energy Supolv
and Environmental Coordination Act (ESECA) of 1974 (PL 93-319)
specifically exempted proposed actions under the Clean Air Act from
NEPA requirements. According to section 7{c)(l)» "No action taken
under the Clean Air Act shall be deemed a major Federal action
significantly affecting the quality of the human environment within
the meaning of the National Environmental Policy Act of 1969."
The Agency has concluded, however, that the preoaration of
environmental impact statements could have beneficial effects on
certain regulatory actions. Consequently, while not legally required
to do so by section 102(2){c) of NEPA, environmental impact statements
will be prepared for various regulatory actions, including standards
of performance developed under section 111 of the Clean Air Act. This
voluntary preparation of environmental impact statements, however,
in no way legally subjects the Agency to NEPA requirements.
To implement this policy, therefore, a separate section is
included in this document which is devoted solely to an analysis.
of the potential environmental impacts associated with the proposed
standards. Both adverse and beneficial impacts in such areas as air
and water pollution, increased solid waste disposal and increased energy
consumption are identified and discussed.
IMPACT ON EXISTING SOURCES
Standards of performance may affect existing sources in either
of two ways. Section 111 of the Act defines a new source as "any
xvi
-------
stationary source, the construction or modification of which is
commenced after the standards are proposed." Consequently, if
an existing source is modified after proposal of the standards,
with a subsequent increase in air oollution, it is subject to
standards of performance. [Amendments to the general provisions
of Subpart A of 40 CFR Part 60 to clarify the meaning of the term
modification were promulgated on December 16, 1975 (40 FR 58416).]
Second, promulgation of a standard of performance requires
States to establish standards of performance for existing sources
in the same industry under section 111(dj of the Act; unless the
standard for new sources limits emissions of a pollutant for
which air quality criteria have been (or will be) issued under
section 108 or one listed as a hazardous pollutant under section 112.
If a State does not act, EPA must establish such standards. [General
provisions outlining orocedures for control of existing sources under
section 111(d) have been promulgated on Hovember 17, 1975, as Subpart
B of 40 CFR Part 60 (40 FR 53340).]
REVISION OF STANDARDS OF PERFORMANCE
Cdngress was aware that the level of air pollution control
achievable by any industry may improve with technological advances.
Accordingly, section 111 of the Act provides that the Administrator
may revise such standards from time to time. Although standards proposed
and promulgated by EPA under section 111 are designed to require
installation of the "...best system of emission reduction...(taking
into account the cost)..." the standards are reviewed periodically.
xvii
-------
Revisions are proposed and promulgated as necessary to assure
that the standards continue to reflect the best systems of emission
control as they become available in the future. Such revisions are
not retroactive but apply to stationary sources constructed or
modified after proposal of the revised standards.
REFERENCES
1. Portland Cement Association vs. Ruckelshaus, 486 F. 2nd 375
(D.C, Cir. 1973).
2, Essex Chemical Corp. vs. Ruckelshaus, 486 F. 2nd 427 (D.C. Cir. 1973).
xvi i i
-------
TABLE OF CONTENTS
Page
INTRODUCTION v
TABLE OF CONTENTS X1-x
LIST OF FIGURES Xxii
LIST OF TABLES xxj^
CHAPTER 1. SUMMARY 1-1
1.1 PROPOSED STANDARDS ...... 1-1
1.2 ENVIRONMENTAL IMPACT 1-4
1.3 INFLATION IMPACT .......... 1-7
CHAPTER 2. THE GRAIN ELEVATOR INDUSTRY . , 2-1
2.1 GENERAL 2-1
2.2 PROCESSES AND EMISSIONS 2-15
REFERENCES 2-40
CHAPTER 3. SUMMARY OF THE PROCEDURE FOR THE
DEVELOPMENT OF THE PROPOSED STANDARDS ... 3.]
3.1 LITERATURE REVIEW AND INDUSTRIAL CONTACTS ..... 3-1
3.2 PLANT INSPECTIONS ......... 3-1
3.3 SAMPLING AND ANALYTICAL TECHNIQUES ......... 3-2
3.4 EMISSIONS MEASUREMENT PROGRAM . 3-4
REFERENCES 3-6
CHAPTER 4. EMISSION CONTROL TECHNOLOGY . 4_1
4.1 RECEIVING (UNLOADING) ......... 4-4
4.2 HANDLING AND CONVEYING EQUIPMENT ..... 4-12
4.3 DRYING . 4-18
4.4 LOADING ..... ..... 4-22
xix
-------
Page
4.5 ALTERNATIVE SYSTEMS . , 4-30
REFERENCES ....... ..... 4-34
CHAPTER 5. DATA TO SUBSTANTIATE THE
5-1
5.1 PART1CULATE EMISSION DATA - FABRIC FILTERS .... 5-1
5.2 PARTICULATE EMISSION DATA - DRYERS ........ 5-5
5.3 VISIBLE EMISSION/OPACITY DATA ..... 5-5
REFERENCES ....... ..... 5-35
CHAPTER 6. ECONOMIC IMPACT . . 6-1
6.1 CHARACTERIZATION OF THE INDUSTRY, ,•»«-• 6-1
6.2 CONTROL COSTS AND COST EFFECTIVENESS FOR
NEW/RECONSTRUCTED 6-23
6.3 ECONOMIC IMPACT ANALYSIS FOR NEW AND
RECONSTRUCTED SOURCES ....,.., 6-43
REFERENCES ............... 6-74
CHAPTER 7, ENVIRONMENTAL EFFECTS ........ . 7.]
7.1 AIR POLLUTION IMPACTS 7.2
7.2 WATER POLLUTION IMPACT. .... ..... 7.13
7.3 SOLID WASTE IMPACT ................ 7_13
7.4 NOISE AND RADIATION IMPACT ............ 7_i6
7.5 IMPACTS .................. 7_i6
7.6 OTHER ENVIRONMENTAL 7_21
REFERENCES . ...... 7^24
CHAPTER 8. RATIONALE FOR THE PROPOSED STANDARDS ......... 8_-|
8.1 SELECTION OF SOURCE FOR CONTROL Q.-J
8,2 SELECTION OF POLLUTANTS AND AFFECTED FACILITIES . . 8.3
8.3 SELECTION OF BEST SYSTEM OF EMISSION REDUCTION
CONSIDERING COSTS 8-9
xx
-------
Page
8.4 SELECTION OF THE FORMAT AND EMISSION LIMITS
OF THE PROPOSED STANDARDS ........ 8-33
8.5 MODIFICATION AND RECONSTRUCTION CONSIDERATIONS . . . 8-42
8.6 SELECTION OF MONITORING REQUIREMENTS ........ 8-44
8.7 SELECTION OF PERFORMANCE TEST METHODS 8-45
APPENDIX A EVOLUTION OF THE PROPOSED STANDARDS ......... A-l
APPENDIX B ENVIRONMENTAL IMPACT CONSIDERATIONS ......... B-l
APPENDIX C EMISSION SOURCE TEST DATA SUMMARY .......... C-1
REFERENCES FOR APPENDIX C ......... C-24
APPENDIX D METHODOLOGY FOR ESTIMATING THE IMPACT OF
GRAIN ELEVATOR FACILITIES ON AIR QUALITY D-l
XXI
-------
LIST OF FIGURES
Pag6
2-1 Flow of Grain from Farm to Market. 2-4
2-2 Terminal Elevator 2-13
2-3 Truck Receiving , 2-18
2-4 Rail car Receiving. 2-21
2-5 Grain Cleaning ..... . 2-27
2-6 Grain Dryers ..... 2-30
2-7 Truck and Rail car Loading 2-32
2-8 Barge and Ship Loading 2-36
4-1 Truck Unloading Control System 4-5
4-2 Rail car Unloading Control Systems. 4-7
4-3 Boxcar Unloading Control System 4-10
4-4 Barge Receiving Control System 4-11
4-5 Transfer Point Control System, ... 4-14
4-6 Grain Handling and Cleaning Control System . 4-15
4-7 Elevator Leg 4-16
4-8 Rack Dryer with Screen Filter. ... ...... 4-20
4-9 Dryer Emissions Versus Screen Size .... 4-21
4-10 Truck Loading Control System .... ...... 4-23
4-11 Hopper Car Loading Control System. . ; 4-25
4-12 Control System for Boxcar Loading 4-27
4-13 Barge or Ship Loading Control System . 4-29
4-14 State Regulations .Applicable to Grain Elevators 4-31
5-1 Participate Emissions from Processes Controlled by
Fabric Filters . 5-2
5-2 Visible Emission/Opacity Data Summary for Fugitive
Particulate Emission Sources at Gradn Elevators
(Excluding Barge and Ship Unloading Equipment) 5-6
6-1 Control Costs as a Function of Annual Throughput ..... 6-73
xxn
-------
LIST OF TABLES
Page
1-1 Summary of Proposed Standards. .,...,. .1-2
1-2 Matrix of Environmental and Economic Impacts of the
Alternative Systems , , 1-5
2-1 Quantity and Value of Production of Major Grains 2-3
2-2 Number and Capacity of Warehouses Operating Under
Uniform Grain Storage Agreement. ............. 2-6
2-3 Transportation Modes for Receipt and Shipment of
Grain, .......................... 2-10
4-1 Emission Control Devices at Existing Elevators 4-2
5-1 Summary of Visible Emission Data for Truck Unloading
(Facility NJ ................. 5-9
5-2 Summary of Visible Emission Data for Truck Unloading
(Facility A) 5-10
5-3 Summary of Visible Emission Data for Boxcar Unloading
(Facility C) ...... .... 5-11
5-4 Summary of Visible Emission Data for Barge Unloading
(Facility D) 5-13
5-5 Summary of Visible Emission Data for Barge Unloading
(Facility E) ". . . . 5-14
5-6 Summary of Visible Emission Data for Barge Unloading
(Facility E) .....:..... . . 5-15
5-7 Summary-of Visible Emission Data for Grain Handling
(Facility 0} ............... 5-16
5-8 Summary of Visible Emission Data for Truck Loading
(Facility P) "..... 5-18
5-9 Summary of Visible Emission Data for Boxcar Loading
(Facility Q) . . . , 5-19
5-10 Summary of Visible Emission Data for Hopper Car
Loading (Facility R) ....... 5-21
5-11 Summary of Visible Emission Data for Ship Loading
(Facility J) 5-22
5-12 Sunmary of Visible Emission Data for Column Dryer
(Facility S) 5-24
5-13 Summary of Visible Emission Data for Column Dryer
(Facility Tj ..... ........ 5-25
5-14 Summary of Visible Emission Data for Column Dryer
(Facility U) ................. 5-26
5-15 Sunmary of Visible Emission Data for Column Dryer
(Facility V) 5_28
5-16 Sunmary of Visible Emission Data for Rack Dryer
(Facility W) . ............. 5-29
5-17 Summary of Visible Emission Data for Rack.Dryer
(Facility X) ..... . ....... 5.30
5-18 Summary of Visible Emission Data for Column Dryer
(Facility Y) ........ V. ," 5,32
5-19 Summary of Visible Emission Data for Fabric Filter
(Facility A) ..... 5.33
5-20 Summary of Visible Emission Data for Fabric Filter
(Facility B) ................. . 5.34
xxiii
-------
Page
6-1 Concentration of Ownership of Country Elevators, Single
and Multi-Unit Firms - 1967 6-2
6-2 Domestic Consumption, Exports, Production end Carry-In
Stocks of Major U.S. Grains. . 6-6
6-3 Estimated Change in the U.S. Grain Elevator Industry
Structure, 1975-1981 Without New Source Performance
Standards 6-12
6-4 Grain Prices Used in Model Plant Analysis 6-15
6-5 Size Profile of Soybean Mill ing Plants 6-16
6-6 Size Profile of Dry Corn and Wheat Milling Plants. ..... 6-18
6-7 Size Profile of Rice Milling Industry - 1967 6-20
6-8 Summary of Control Technologies on Affected Facilities . . . 6-28
6-9 Model Plant Characteristics for the Grain Elevator
Industry ........... ......... 6-29
6-10 Tabulation of Capital and Annualized Costs for Alternative
Controls for New Grain Elevator Sources 6-31
6-11 Summary of Grain Elevator Annualized Costs for Alternative
Levels of Control Technology/Grain Elevators 6-32
6-12 Summary of Incremental Costs for Alternative Levels of
Control Technology Above State Requirements/Grain
Elevators . 6-33
6-13 Model Plant Characteristics for Grain Processors/Control
Requirements for Grain Handling Facilities . . 6-35
6-14 Tabulation of Capital and Annual!zed Costs for New
Sources/Grain Processors, Commercial Rice Dryers ...... 6-36
6-15 Summary of Grain Processors' and Commercial Rice Dryers'
Costs for Alternative Control Levels 6-38
6-16 Summary of Grain Processors' and Commercial Rice Dryers'
Incremental Costs for Alternative Control Levels Above
State Requirements ......... . . 6-39
6-17 Summary of Cost-Effectiveness for Grain Dryers 6-41
6-18 Grain Storage Elevators - Anticipated Number of New and
Reconstructed Sources (January 1, 1976 to December 30,
1981). 6-46
6-19 Model Grain Distribution Costs (£/Bu.) for Alternative
Controls and Systems . 6-50
6-20 Summary of the Impact of Alternatives Upon Construction of
New Sources 6-53
6-21 Incremental Capital Requirements for Controls at Alternative
Control Levels 6-54
6-22 Model Soybean Processing Plant . 6-57
6-23 Model Wheat Mill 6-59
6-24 Model Wet Corn Mill 6-61
6-25 Model Dry Corn Mill. 6-63
6-26 Model Rice Mill. ...... 6-66
6-27 Model Commercial Rice Dryer. 6-68
xxiv
-------
Page
7-1 Adverse Secondary Environmental Impacts of Individual
Control Techniques Over SIP Requirements. .,.,,.,., 7-3
7-2 Grain Elevator Emissions for Model Elevators with
Alternative Control Systems . 7-5
7-3 Estimated Incremental Annual Particulate Matter Emission
Reduction for Model Plants with Alternative Control
Systems Compared to Emissions Under Typical State
Regulations, System 1 (Ib/yr) . , , 7-8
7-4 Estimated Maximum Ambient Ground Level Particulate
Concentration (yg/m3) »....,... ,7-11
7-5 Solid Waste Disposal with Alternative Control Systems . . , 7-15
7-6 Calculated Energy Requirements to Operate Alternative
Control Systems . 7-17
7-7 Total and Incremental Pollution Control System Energy
Requirements for Model Plants with Alternative Control
Systems . 7-20
7-8 Environmental Impact of No Standard ..... 7-23
8-1 Alternative Controls for Column and Rack. Dryers
(2000 bu/hr Capacity) 8-13
C-l Summary of Particulate Emission Data for Fabric Filter
(Facility A) , C-12
C-2 Summary of Particulate Emission Data for Fabric Filter
(Facility B). , . , » C-13
C-3 Summary of Particulate Emission Data for Fabric Filter
(Facility C). .......... ....... C-14
C-4 Summary of Participate Emission Data for Fabric Filter
(Facility D). . . . C-15
C-5 Summary of Particulate Emission Data for Fabric Filter
(Facility E) ................. C-16
C-6 Summary of Particulate Emission Data for Fabric Filter
(Facility F) C-17
C-7 Summary of Particulate Emission Data for Fabric Filter
(Facility F) C-18
C-8 Summary of Particulate Emission Data for Fabric Filter
(Facility G) C-19
C-9 Summary of Particulate Emission Data for Fabric Filter
(Facility H). . C-20
C-10 Summary of Particulate Emission Data for Fabric Filter
(Facility I) c-21-
C-ll Summary of Particulate Emission Data for Fabric Filter
(Facility J). C-22
C-l2 Summary of Particulate Emission Data for Fabric Filter
(Facility K) C-23
D-l Particulate Emission Sources at Grain Elevator Facilities . D-3
D-2 Emission Rate, Average Emission Height (weighted by .
emission rate)» and Assumed Initial Plume Dimensions for
Each Type of Grain Elevator and level of Emission
Control_ .......................... 0-5
D-3 Estimated Ambient Ground-Level Particulate Concentrations
at Specified Distances Downwind of Grain Elevator
Facilities. ... ............... 0-8
xxv
-------
1. SUMMARY
1.1 PROPOSED STANDARDS
Standards of performance for new and modified grain elevators
are being proposed under authority of section 111 of the Clean
Air Act, Participate matter, the only significant pollutant
emitted, will be controlled from these sources. Preceding
the act of proposal,has been the Administrator's determination
that emissions from grain elevators contribute to the endangerment
of the public health or welfare. In accordance with section 117
of the Clean Air Act, proposal of the standards was preceded
by consultation with appropriate advisory committees, independent
experts, industry representatives, and Federal departments and
agencies.
The proposed standards limit emissions of particulate matter
from eight affected facilities and the air pollution control devices
which are used on these facilities. The,eight affected facilities
are: each truck unloading station, each railroad hopper car and boxcar
unloading station, equipment at each barge and ship unloading station,
all grain handling operations, each grain dryer, each truck loading
station, each railroad hopper car and boxcar loading station, and each
barge and ship loading station. These eight facilities account for
virtually all of the particulate matter emissions from a grain
elevator. A summary of the proposed standards is presented in Table 1-1
There are no stack monitoring requirements in the proposed standards
because the costs involved were judged not fee be reasonable by EPA.
1-1
-------
Table 1-1. Summary of Proposed Standards
Affected Facilities and
Air Pollution Control Devices
Proposed Standards
Truck Unloading Stations
Rail car Unloading Stations
Barge and Ship Unloading Equipment
Handling Operations
Dryers
Truck Loading Stations
Rallctr Loading Stations
Bargt and Ship Loading Stations
A1r Pollution Control Devices
On These Affected Facilities
01 Opacity
No Visible Emissions
.Equipment Specifications
01 Opacity
(Column dryers would be considered 1n com-
pliance with the standard provided the
diameters of all column plate perforations
do not exceed 2.1 mm [ca. 0.084 inch] and
Pack dryers would be In compliance provided
all exhaust gases pass through a 50 or
finer mesh screen filter,)
Opacity
0% Opacity
101 Opacity - General Loading
15% Opacity - "Topping Off" Operations
0.023 g/std. m3 dry basis (0.01 gr/dscf)
and 0% Opacity
1-2
-------
The proposed standards apply to farm elevators, country
elevators, terminal elevators, and commercial rice dryers which
have grain leg capacities greater than 352 m3/h (ca. 10,000 bu/hr)
and to storage elevators at wheat flour mills, wet corn mills,
dry corn mills (human consumption), rice mills, or soybean
extraction plants. The proposed limits are: (1) 0,023 g/std. m3
dry basis and zero percent opacity from air pollution control devices
on any affected facility except grain dryers; (2) zero percent
opacity from any truck unloading station» grain handling
operation, railroad hopper car loading station or railroad
boxcar loading station; (3) no visible emissions from any railroad
hopper car unloading station or railroad boxcar unloading
station; (4) ten percent opacity from any truck loading station;
(5) ten percent opacity* except that the opacity may not exceed
fifteen percent during topp1ng-off operations, from any barge
or ^htP loading station; (6) zero percent opacity from any grain
grain (column dryers would be considered in compliance with the
standard provided the diameters of all column plate perforations
do not exceed 2.1 mm [ca. 0.084 inch] and rack dryers would be in
compliance provided all exhaust gases pass through a 50 or finer
mesh screen filter); (7) operation of a leg which is enclosed from the
top (Including the receiving hopper) to the center line of the
bottom pulley, and ventilation of at least 32.1 actual cubic meters per
cubic meter,of grain handling capacity (ca, 40 ft3/bushel) to a parti-
culate control device on both sides of the leg and the grain receiving
hoDoer, at any barge or ship unloading station.
1-3
-------
1.2 ENVIRONMENTAL IMPACT
A summary of thi beneficial and adverse environmental and
economic impacts associated with the proposed standards and
with the various alternative control systems that were considered
are presented in this section. These impacts are discussed in
detail in Chapter 7, Environmental Effects, and Chapter 6,
Economic Impact. Table 1-2 is a matrix which summarizes these
impacts.
Alternative system number 1 is the baseline system to
which the impacts associated with the other alternative systems
can be compared. Alternative system number 2 is the best
demonstrated control technology, considering costs. Alternative
system number 3 is the best possible control technology. In
some cases, systems £• and 3 are identical. These alternative
systems are described in detail in Chapter 4» Emission Control
Technology.
Large beneficial impacts on air quality will result from
alternative systems 2 and 3 due to the reduction in particulate
matter emissions. There are no impacts on water supply or
treatment for these alternative systems because all of the
air pollution control devices required are dry collector units.
There will be a minimal adverse impact on solid waste collection
and disposal due to the use of more efficient particulate collection
devices. This is, however, considered negligible by EPA. Adverse
energy impacts will be associated with each of the alternative
systems, These impacts are considered small and result primarily
1-4
-------
Table 1-2. Matrix of Environmental and Economic Impacts of the Alternative Systems
\
SYSTEM
NO, 1
SYSTEM
NO. 2
SYSTEM
NO. 3
DELAYED
STANDARD
NO
STANDARD
AIR
IMPACT
0
+4
+4
-3
-4
WATER
IMPACT
0
0
0
0
0
SOLID
WASTE
IMPACT
0
-1
-1 .
•H
+1
ENERGY
IMPACT
0
-2
-2
+2
+2
NOISE AND
RADIATION
IMPACTS
0
-1
-1
+1
+1
ECONOMIC
IMPACT
0
-2
-4
+2
+2 "
INFLATIONARY
IMPACT
0
-1
-1
+1
+1
Key: + Beneficial Impact
- Adverse Impact
0 - No Impact
1 - Negligible Impact
2 - Small Impact
3 - Moderate Impact
4 - Large Impact
-------
from the increased energy requirements of fabric filters over
cyclone control devices. Impacts on noise levels due to
the use of any of the alternative control systems have not
been quantified. The control devices and exhaust fans at
grain elevators are usually located outside of buildings at
either roof or ground level. Although fans are noisy, they
are already required for collection systems now used to meet
existing state regulations. Therefore, any Federal standard
will not introduce new noise problems but may slightly increase
the existing noise levels. There are no known or anticipated
radiation impacts from grain elevator operations. The economic
impacts associated with alternative system 2 have been judged
to be small. Costs were considered in determining the best
demonstrated control technology for this system. Costs were
not considered in determining the best possible control technology
for alternative system 3 and the adverse economic impact is great.
Two additional alternatives have also been considered: the
impact of delayed standards and the impact of no standards.
In both cases the adverse impact on air quality would be moderate
to large, since the new and modified facilities that would
otherwise fall under the proposed standards would be allowed
to emit particulate matter at existing levels. Other impacts
due to these alternatives are negligible positive impacts on
solid waste, and noise, and a small positive impact on economics
and energy consumption.
1-6
-------
1,3 INFLATION IMPACT
The costs associated with the proposed standards for new
and modified facilities at grain elevators have been judged not
to be of such magnitude to require an analysis of the inflationary
impact. . Screening criteria have been developed by EPA to be
used in the impact analysis. These criteria have been outlined
in an Agency publication and include:
(1) National annualized cost of compliance.
(2) Total added production cost in relation to sales price.
(3) Net national energy consumption increase.
(4) Added demands or decreased supplies of selected materials.
Should any of these guideline values listed under these criteria
be exceeded, a full inflationary impact statement is required.
The EPA has determined that this document does not contain
a major proposal requiring preparation of an Inflation Impact
Statement under Executive Order 11821 and OMB Circular A-107.
1-7
-------
2. JM£ QMIOIPW™ 1NQUSJRY
2.1 GENERAL
2.1.1 Background Information
Grain elevators are used to condition and store grain as
it moves from the farm to markets. In general, elevators are
classed as either "country" or "terminal." The U. S. Department
of Agriculture (USDA) distinguishes between country and terminal
elevators on the basis that terminals furnish official weights;
that is, each receipt or shipment is weighed under the super-
vision of a state inspector.
Country elevators generally receive grain or soybeans as they are
harvested in fields within 10 to 20 miles of the elevator. They unload,
weigh, and store the grain and may dry or clean it before shipment
to terminal elevators or processors. Terminal elevators are classi-
fied into two groups, inland (or subterminals) and port terminals.
Inland terminal elevators receive most of their grain from country
elevators and ship to processors, other terminals, and exporters.
One"function of an inland terminal elevator is to store grain in
quantity and upgrade it to meet buyer's specifications. They also
dry and clean grain, as country elevators do, and also blend
different grades of grain.-/
USDA classifies each grain into six grades. No. 1 grade
grains must meet specific minimum test weights (pounds per bushel) and
maximum limits on the percent moisture, "foreign material and other
defects that lower its value.
2-1
-------
Port terminals are defined as those located on major waterways
or in seaports which export agricultural products. The port terminal
provides the same basic functions as an inland terminal, but can
also.load ships and barges.
Plants which process grain also use elevators to receive and
store the grain. These plants process grain into food or food
intermediates for human or animal consumption. All of the same
basic functions performed at country or terminal elevators are
performed at storage elevators owned by processors. Shipment
of grain, however, would be a rarity.
Table 2-1 shows the quantities and values of the principal feed
grains (corn, oats, barley, and sorghum grains); food grains (wheat,
rice, and rye); and soybeans produced on the farm since 1940. The
largest crop is corn with production about three times that of
wheat, the second largest crop. Soybeans (actually an oil seed)
now rank third in production and second in cash value. The
farmer does not sell all of the grain he harvests. Substantial
portions of some crops (especially feed grains) are retained for
use as livestock feed and seed. In 1971, S? percent of the feed
grains (7.3 billion bushels of grain), 94 percent of the food grains,
and 98 percent of the soybeans were sold by farmers to their various
outlets.
*3
Figure 2-1* shows the distribution of wheat, feed grains, and
soybeans as they flow from farm to market. Although this figure is
2-2
-------
TABLE 2-1
QUANTITY AND VALUE OF PRODUCTION OF GRAINS1
r\)
i
Corn
Wheat
Soybeans
Grain sorghums
Oats
Barley
Rice
Rye
Corn
Wheat
Soybeans
Grain sorghums
Oats
Barley
Rice
Rye
QUANTITY OF PRODUCTION
(million bushels)
1940
2
1
,207
815
79
86
,246
311
54
40
1945
2,577
1,108
193
96
1,524
267
68
24
1950
2,764
1,109
299
234
1,369
304
86
21
1955
2,873
935
374
243
1,496
403
124
29
FARM VALUE
1940
1
,519
556
70
41
377
124
44
17
1945
3,652
1,661
402
115
1,016
272
122
32
1950
4,222
2,042
738
245
1,081
358
197
28
(million
1955
3,849
1,859
831
238
890
370
269
31
1960
3,907
1,355
555
620
1,153
429
121
33
1965
4,084
1,316
846
673
927
392
170
33
1970
4,099
1,370
1,124
696
909
410
186
39
1973
5,643
1,711
1,567
937
664
425
189
26
OF PRODUCTION
dollars)
1960
3,929
2,361
1,185
515
693
355
248
30
1965
4,732
1,775
2,151
668
585
395
376
33
1970
5,441
1,826
3,205
798
581
389
433
38
-------
r"
5w, 5F, 3s
/\
SUBTERBINAL
ELEVATOR
f 3?F, 10s
•*H PROCESSOR
¥AL I
:f 5 1 40W, 29F, 48s
4Bw, 28F, 3?s
i
S^
EXPI
38w, 32F, 55s
50w» 25F, 30s
It
w.- perceni WHEAT
F . percent FEED GRAINS
s r percent SOYBEANS
Figure 2-1. .Flow of grain from farm to market.
-------
based on 1963-64 data, it is representative of the current movement
of grains. Based on these data, about 85 percent of the grain sold
by farms is handled by country elevators before shipment to terminal
elevators or grain processors. The other 15 percent bypasses
country elevators. This is possible largely because improved roads,
larger trucks, and more on-farm storage facilities make it economical
to ship directly to more distant terminal elevators and processors.
Country elevators ship 92 percent of their wheat and 87 percent of
their soybeans, but only 56 per cent of the feed grains to terminal
elevators. The balance of the feed grain is shipped directly to
processors.
Table 2-2 contains data from the Agricultural Stabilization and
Conservation Service (ASCS) of the USDA on the number and storage
O
capacities of country and terminal elevators. (ASCS publishes a
monthly list of elevators approved for storage of grain under govern-
ment loans.) These numbers represent most of the elevators and nearly
all of the storage capacity in the nation. The data show that the
number of both country and terminal elevators has decreased each
year since 1969. Information from industry shows that of the 477
terminals registered in 1972, 413 were inland terminals and only
64 were port. In addition to the elevators shown in Table 2-2,
about 600 grain processing plants have elevators
ASCS data show that the average storage capacity of a country
elevator has grown from 363,000 bushels in 1969 to 441,000 bushels
2-5
-------
September 30,
September 30, 1970
September 30, 1971
*? September 30, 1972
01
September 30, 1973
March 31, 1974
Average yearly
^change 1969-74
TABLE 2-2
NUMBER AND CAPACITY OF WAREHOUSES OPERATING UNIFORM GRAIN AGREEMENT3
Country Elevators
Total
Number Capacity..
Average
Capacity
{1,000 bushels)
7,879 2,839,716
7,607 2,922,575
7,380 2,940,125
7,147 3,017,523
6,962 3,044,448
6,847 3,020,963
Terminal Elevators
Total Average
Number CjpjCTty Capacity
(1,000 bushels)
363
384
398
422
437
441
508'
506
489
477
467
465
1 ,854,635
1,880,081
1,835,224
1,814,803
1,810,190
1,803,117
3,651
3,716
3,753
3,805
3,880
3,890
Total
Number Capa c1ty
(1,000 bushel!
8,387 4,714,351
8,113 4,802,656
7,869 4,775,349
7,624 4,832,326
7,429 4,854,638
7,312 4,824,080
-2.76
+1.1
+3.8
-1.76
-0.56
+1.3
-2.7
+0,5
-------
in 1974. Typical storage capacities of country elevators constructed
in the last few years range from 200,000 to 750,000 bushels; however,
many older country tlevators have capacities of only a few thousand
bushels. Terminal elevators have an average storage capacity of
nearly 3,900,000 bushels although, some have capacities in excess
of twelve times that. The capacity of these larger terminals includes
bins added on the original structures and storage in steel tanks or
warehouse-type buildings ("flat storage"). The largest capacity
under one roof is 18,000,000 bushels. The storage capacities of
processing plants range between 500,000 and 3 million bushels.
The current trend of small elevators going out of business will
probably continue. This is not unexpected. Several studies con-
ducted since 1964 reveal an economy-of-scale for larger elevators.
The cost of marketing grain decreases significantly if elevators
are larger than 1,000,000 bushels storage capacity.^" More recently,
there has been a concurrent decrease in demand to store grain and a
greater demand for handling increasingly large quantities of grain
rapidly. These are partially the result of:
1) the recent upsurge in foreign demand for grain;
2) a steady increase in domestic demand;
3) a trend toward more on-farm storage;
4) the reduced amount of grain to be stored as a result of 1, 2,
and 3;
2-7
-------
5} attractive railroad tariffs for multi-car shipments; and
6) increasing use of large hopper cars with capacities up to 80%
1arger than convent!onal cars.
These forces have initiated the construction of elevators with low
storage capacity and high handling capacity which permits multi-
car trains to be quickly loaded. One report indicates over 100
such elevators may be built by 1980. In addition, some existing
elevators will also be modified to gain this ability.
True growth in the grain processing industries is expected to be
slow since'the per capita consumption of grain products is remaining
constant or decreasing. Only soybean processors have significant
incentive to invest in new storage capacity. Soybean production in
the United States has increased over 20 fold, from 70 to 1,567
million bushels, in less than 35 years. Soybeans are an increasingly
important source of protein for man and animals. Soybean oil is
used in foods, cosmetics, paints, and plastics.
Country elevators receive almost 100 percent of their grain by
truck. They ship primarily by truck and rail in near equal quanti-
ties. Inlmd terminals receive grain primarily by truck and rail,
and ship primarily by rail and water. Port terminals receive grain
by rail,, truck, or barge, depending on their location and facilitiis.
They ship almost exclusively by water. A strong trend
2-8
-------
is the increasing use of water transportation by all three types of
elevators. In 1971-72 country elevators shipped 13 percent of their
product by barge, up nearly 100 percent from 1970-71, Receipts by
water at port terminals increased from 25 percent in 1970-71 to 40
percent in 1971-72. The modes of transportation used by country,
inland, and port terminal elevators are summarized in Table 2-3.
The quantity of grain handled in relation to the storage capacity
for the three types of elevators is shown below.
Ratio of grain handled
tostorage capacjty6
1970-71 1971-72
Country elevators 1.8 2.0
Inland terminals 1.2 1.4
Port terminals , 7.7 7.6
The ratio for port terminals is significantly greater than for other
elevators because the primary purpose is not to store grain but to
receive it from inland storage facilities and ship it to overseas
markets. Data on the actual quantities of grain handled by elevators
are not directly available; however, these quantities can be esti-
mated from a number of sources. One method is by extending USDA
Economic Research Service (ERS) data which covers elevators
approved for storage of grain under government loans, to cover all
elevators. This method gives the following estimate:
2-9
-------
TABLE 2-3
TRANSPORTATION FOR RECEIPT AND SHIPMENT OF
Country Elevators
1970-71
1971-72
Inland Terminals
1970-71
1971072
Port Terminals
1970-71
1971-72
Percent
Received by-
Percent
Loadout by-
Truck Rail Water Truck
40
15
10
55
60
50
Rail
25
40
15
17
6
6
55
48
Water
99.8
99.8
0.2
0.2
49
42
45
44
7
13
30
35
94
94
2-10
-------
QUANTITY OF
{tniJ_lion byshejs)
1970-71 1971-72
Country elevator 5,318 5,912
Inland terminal 1,574 1,837
Port terminal 2,717 2,689
A second method, for country elevators only, is to use the volume of
grain sold by farms7 and the corresponding percentage which goes
to country elevators {see Figure 2-1), By this method, 5,190 million
bushels were handled in 1970-71 and 6,288 million in 1971-72. This
method is not applicable to inland and port terminal elevators since
available data on the distribution of grain, shown in Figure 2-1,
are not defined in these terms.
Although elevators are located throughout the United States, the
major concentration is in the grain producing states in the Mid-
Plains, South Plains, and Great Lakes regions.=/ Kansas has the
largest grain storage capacity of any state with 13.2 percent of the
elevators and 15,9 percent of the total domestic capacity, Texas
has only 6,5 percent of the elevators, but 14.0 percent of the total
2/
-'Mid-Plains; Nebraska, Kansas, Colorado, Wyoming, Iowa» and Missouri;
South Plains: Oklahoma, New Mexico, and Texas plus Gulf port facilities;
Great Lakes: Wisconsin, Illinois, Indiana, Ohio, Michigan, and Minnesota,
2-11
-------
capacity. The five states of Kansas, Texas, Illinois, Nebraska, and
Iowa together account for 51.9 percent of the elevators and 57.7 per-
cent of the storage capacity. Country elevators are almost exclusively
located in rural areas and small towns. Of 6,477 country elevators,
87 percent are located in areas with less than 100,000 inhabitants.
Terminal elevators are located in the principal grain-marketing
centers, most of which are in metropolitan areas. However, there is
a recent trend to build terminals in rural areas.
Grain processing facilities for wheat, corn, and rice mills,
soybean processing plants, and wet corn mills are located in both
rural and urban areas. Although most were originally constructed in
rural areas, many have since been surrounded by metropolitan growth.
2.1.2 The Emission Probltm ;
There are four primary functions that take place in an elevator
as shown 1n Figure 2-2: receiving, handling, drying, and shipping.
All of these are materials-handling processes rather than processes
which affect a chemical e&ange in the product. Particulate matter,
which has been designated as a criteria pollutant under section 109
of the Clean Air Act, is the main pollutant, although very small
amounts of combustion products can be emitted from grain dryers
(these usually operate less than three months per year and burn
natural or propane gas). The particulate matter may contain 60-90
2-12
-------
LEG VENTS
INS
AND SHIP
LOADING
ELEVATOR LESS
SCALE AND BINS
WITH VENTS
TRANSFER : {CONVEYOR BELT)
TRIPPER
HQPPERCAR RECEIVING '/ \
AND CAR LOADING / / *
\
RECEIVING \' /
1 ^ '
LEGS a
fcnj
BARGE
Figure 2-2. Terminal elevator.
-------
percent organic material. Three to 20 percent of the inorganic
portion may be free silicon (sand from entrained dirt). Specific
materials in the partieulate matter include particles of grain kernels*
spores of smuts and molds, insect debris, pollen, and dirt from the
field.
The particulate matter can be emitted from almost any point
in the elevator process. Many of the emissions are fugitive.
They become airborne because of ineffectual of nonexistent hooding
or pollutant capture systems.
Suspended particulate material has been monitored with a high.
volume sampler and found to be nearly 240 mlcrograms per cubic meter
in the immediate vicinity of grain handling plants. A size distribution
of these particulates revealed 99.5 percent were less than two microns
and 50 percent were less thin 0,03 micron in diameter. Such, small
particles will readily invade and affect the small air spaces in
the lungs.^ Ambient concentrations of particulate greater than
100 micrograms per cubic meter are known to have adverse health
effects on humans.'0
Insects, molds, and fungi associated with grain handling
may also cause respiratory ailments. The effects of long-term
(decade) exposure to low concentrations of particulate matter
from grain are not known.
2-14
-------
Highly mechanized modern grain elevators without adequate
partfculate matter control equipment can subject workers inside
the elevator to TOO to 400 milligrams of airborne dust per cubic
meter, well above the threshold that causes respiratory problems.
The high incidence of respiratory disease among millers, bakers,
and grain elevator and docfc workers is well known,
2.2 AND
2.2.1 General
The processes at an elevator include receiving (by truck,
railcar and barge), handling and conveying, drying, and loading
(into trucks, rail cars, and aquatic vessels).
Several factors common to each of the processes that can
affect emissions are discussed below. The first is the characteristics
of the particulate matter which varies with the type of grain
handled. A test conducted to determine the magnitude of emissions
from several elevator processes also indicated that emissions from
soybeans are hiqher than for corn, wheat, and mllo. Soybeans
contain more dirt since they grow close to the ground and the
harvester may scrape up earth as it cyts the plant off. Corn
has "beeswings," large flaky particles that readily become
airborne because of their large surface area and low density,
They can be a significant nuisance to nearby residents during
the harvest season. The moisture content of the grain is
another factor. It can vary from 16 to over 20 percent at
2-15
-------
harvest; however, not enough data on moisture content are
available to quantify its effect on emissions. After:the grain
is dried, the moisture content will jiot vary significantly.
The percentage of "foreign material" or "dockage" in grain (the
ratio of the weight of material other than whole grain kernels to
the total weight) can also affect emissions. Most of the foreign
material may be weed seeds, broken kernels, dirt, stones, ana other
heavy particles that do not cause an emission problem. However,
since chaff, straw, and other light materials are also present with
the heavy particles, a high percentage of foreign matter is a rough
indication of high emissions potential. The percent .foreign matter
is often determined for each load of grain received or shipped.
Country elevators, operate primarily during the harvest season
which begins in Jyne for wheat and ends with corn and soybeans in
Novunber. Consequently, their emissions are also "seasonal," In
contrast, terminal elevators may receive and ship grain year round.
In most states, elevators are subject to general process
weight regulations for particulate emissions. .Pennsylvania
has regulations specific to elevators. The application of
these regulations is discussed in Chapter 4. In general,
typical state regulations can usually be met with high
efffcfency cyclones.
Grain dryers are addressed specifically by the state of Maryland.
Their regulations require control of grain dryer emissions with a
2-16
-------
50-mesn screen or its equivalent. The Illinois EPA pro-
posed regulations to the Illinois Pollution Control Board that would
require 50-mesh vacuum-cleaned screens for txhaust gases from rack
dryers and external sheeting with perforations not exceeding .094
inch in diameter for column dryers.
2.2.2 Truck Receiving
Grain is emptied from most trucks (see Figure 2-3} by lifting
the front end with an overhead winch or hydraulic platform to allow
grain to flow from the tailgate. The grain falls from the truck
through a heavy grate and into the receiving hopper. Dust-laden
air can be emitted as air in the hopper is displaced by drain. A conveyer
beneath the hopper moves the grain to storage bins.
The size of the receiving hopper limits the speed at which the
grain can be handled. Small hoppers used at country elevators and
elevators at grain processors where grain is received at a
relatively slow pace minimize air pollution. *By rapidly filling
with grain, they "automatically" decrease the free-fall distance from
the truck bed. When this "choke feed" principle occurs, it may
take five to ten minutes to empty a truck. At subterminal and terminal
elevators where large receiving hoppers and hydraulic hoists are used,
a larger 1000 bushel truck is often emptied in two minutes.
2-17
-------
WICKET
ELEVATOR
LEG
2-3. Truck receiving.
-------
Some trucks have trailers with three or four "hoppers" from which
grain is emptied through a small opening in the bottom of each hopper.
Comparatively little participate matter evolves when hopper trucks
are unloaded since the grain flows slowly.
In climates where it is desirable to protect the receiving
hopper, often a roof and two sides are built so that trucks can
drive through rapidly,
Uncontrolled particulate emissions from truck dumping are
estimated to average 0.6 pound per ton (Ib/ton) of grainJ3 The
amount of particulate matter generated is dependent upon:
1. the type of track (i.e,t hopper or dump);
2. the size of the receiving hopper (i.e., deep or shallow);
3. the speed at which grain is dumped;
4. the type of grain;
5, its moisture content; and
6. the amount of foreign material.
The last three factors were discussed on pages 15 and 16. l*ne others are
discussed above. Tests of truck receiving operations using cyclones
resulted in measured parttculate emissions of 0.05 gr/scfM
2-19
-------
2.2,3 Railcar Receiving
2.3.3,1 Hopper Cars - Hopper cars are typically divided into compart-
ments or hoppers. Each has an opening about two feet square in the
bottom through which the grain is discharged into a receiving
hopper. The receiving hopper is often small so that only one com-
partment at a time can be emptied. This is common at country eleva-
tors and elevators at grain processors where grain 1s received
at a relatively slow pace. As at truck stations, small receiving
hoppers rapidly fill with grain thereby decreasing the free-fall
distance from the hopper car and minimizing air emissions (see
Figure 2-4). At larger facilities the receiving hopper may permit
all three hoppers on the rail car to empty simultaneously, when it is
desirable to protect the receiving hopper from the weather, it 1s often
covered by a shed with large openings at both ends.
Uncontrolled particulate emissions from unloading railcars are
estimated to average 1.3 pounds per ton of grain.13 This estimate is
based on both hopper cars and boxcars. Particulate emissions from hopper
cars are below the average. Particylate emissions from rail cars are
a function of: ^
1. the size of the receiving hopper (i.e., deep or shallow);
2, the amount of protection from winds;
2-20
-------
IN3
ELEVATOR
LEG
2CS
HOPPER
CAR
•w
ii
ft
"1
***
j>
BOX CAR
SBfc-trf
LEG BOOT
Figure 2-4. Rail car receiving
-------
3. the type of grain;
4. Its moisture content; and
5» the amount of entrained foreign material.
2.2.3.2 Boxcars - Conventional boxcars are often used to haul grain.
Before it is loaded, a boxcar must be fitted with a "grain door" which
is installed over the lower part of the sliding door openings in the
side of tne car. The grain door is made of wood or heavy cardboard
and covers about three-fourths the height of the car door opening.
One method of unloading boxcars is to break the grain door.
This results in a surge of paniculate matter as the grain falls
fnto the receiving hopper beside the tracks (see Figure 2-4).
After this initial surge, the remaining grain is scooped out
of the car using power shovels, a front end loader, or some
similar means. A cloud of participate matter may form as each
scoop of grain strikes the receiving hopper. The other common
unloading technique, used mainly by terminal elevators, is a
mechanical car dump. The car is clamped to a movable section of
track which rotates and tilts the car to dump the grain out of
the door into the receiving hopper. This technique is rapid
and results in violent agitation of the air around the flowing
grain. These air currents can entrain particulate matter and
sweep it from the receiving area. As described for hfcpper cars,
a tunnel-like shed over the receiving hopper is sometimes used.
2-22
-------
Uncontrolled participate emissions from unloading railcars
13
are estimated to average 1.3 pounds per ton (lb/T) of grain.
Particulate emissions from boxcars are above this average. The
amount of participate matter generated is dependent upon:
1. the method of unloading the car;
2. the amount of protection from wind;
3. the type of grain;
4. its moisture content; and
5. the amount of entrained foreign material,
2.2.4 Ra.rpft Receiving
Grain is received by barge at inland terminal and port terminal
elevators. The unloading areas are generally open to the weather.
In most cases grain is unloaded with a bucket elevator (leg) that
is lowered into the barge. Their capacities range from 15,000 up
to 75,000 bushels per hour; the average is about 30,000.
Particulate matter can be generated in the barge by the
buckets of the leg and at the transfer point at the top of the
leg where the grain is dumped into a receiving hopper. To
completely clean the barge, it may be necessary to push or pull
the grain to the Teg with power shovels or front end loaders.
This too can generate fugitive particulate emissions.
Uncontrolled particulate emissions from barge unloading
are estimated to average 1.7 pounds per ton of grain. The
particulate emissions from a specific facility are dependent
upon:
2-23
-------
1, the type of grai n;
2. its moisture content; and
3. the amount of entrained foreign material,
2.2.5 Grain Handling and Conveying Equipment
Handling and conveying equipment includes bucket elevators (legs)
used to elevate the grain; conveyors (screw, drag, and belt type)
which move it horizontally; scale and surge bins used to weigh it;
scalpers and cleaners; distributors (turn heads and trippers) which
direct it to one of several places in the elevator*, and the headhouse
and other such structures.
A screw conveyor is a large (about 8" diameter) screw contained
within a trough. The grain which enters one end of the trough is
pushed forward as the screw turns. A drag conveyor consists of
a continuous chain with paddles inside a rectangular enclosure.
The grain is pushed forward by the paddles. The grain kernels
scrape against the sides of the enclosures of screw and drag
conveyors causing particles to break off. These conveyors move the
grain slower (about 50 feet per minute) than belt conveyors. A
belt conveyor is a continuous belt (about 36" wide) that carries
the grain forward at about 300 feet per minute. Friction between
the grain and the belt usually occurs only when it drops onto the
moving belt. Generally, few kernels are broken when using belt
conveyors.
2-24
-------
After the grain has been dumped into the receiving hopper, it is
conveyed to a leg which lifts it to the top of the "headhouse"
where it is discharged to a distribution system (see Figure 2-2).
The grain is usually distributed directly from the headhouse into
storage bins or silos. Wten t&e large silos are filled, participate
matter may be emitted from the silo vents, though these emissions
are rarely visible. These silos are so large they act as their
own settling chamber. Grain stored in one silo for an extended
time may increase in temperature because it is either:
a. too moist and begins to spoil, or
b. diseased or Infested and the disease is growing.
The grain must either be treated to eliminate the cause of the
increasing temperature or it may be "turned" to allow it to cool by
aeration. To "turn" the grain, it is dropped from the bottom of
the silo, conveyed to a leg, lifted to the distributor and dropped to
another empty bin.
To ship grain, it is dropped from the bottom of the silo,
conveyed to a leg, and elevated to the distributor. From there it falls
to grain cleaners or the load-out scales. Grain cleaners are used
in many elevators but especially at terminals where the grain
shipped must meet USDA standards. The portion of grain received,
that is cleaned, by each type of elevator is shown below.
2-25
-------
GRAIN CLEANED16
QUANTITY
PERCENT OF RECEIPTS (mmion bushels/year)
Country 7.8 415
Inland Terminal 22.1 348
Port Terminal 14.6 397
Equipment used to clean grain varies from simply screening it
to a simultaneous screening and winnowing operation. The simple
screening devices remove large sticks, rocks, tools, and other trash,
Participate matter which becomes air&orne as the grain rolls over
the screens will generally settle inside the elevator and not escape
to the atmosphere. However, a small amount of suction is often
applied to reduce trie particulate matter concentration inside the
elevator. This suction system usually discharges through an
air pollution control device to the atmosphere. The more complex
ventilated cleaners pull or blow air through the screens to lift
chaff and other light impurities from the grain (see Figure 2-5),
The light material is collected in a cyclone or fabric filter.
Uncontrolled particulate emissions from screens are estimated
to be 3,2 Ibs per ton of grain. Uncontrolled particulate emissions
from the combination cleaning systems are estimated to be 6.0 Ibs
per ton of grain.
2-26
-------
GRAIN,
SCALPER.
(COARSE SCREEN
DRUM)
ro
PARTICULATE MATTER AND AIR
FOREIGN GRAINS, STONES, LARGE TRASH
GRAIN
FINES AND BROKEN KERNELS
2-5. Grain cleaning
-------
Both country and terminal elevators have scales which are
preceded and followed by surge bins. Conveyors discharge a
continuous stream of grain into the upper surge bin while the
scale weighs batch quantities and discharges them into the lower
surge bin» which also empties continuously. Generally, the griin
drops directly into the shipping vehicle; however, sometimes it
may be necessary to convey the grain to the shipping station.
The air displaced by the entering grain must be vented from
the scale hopper and both surge bins. The surge bins and scale
hopper can be vented to each other to prevent particulate emissions.
Particulate emissions can occur at transfer points as grain
is fed onto or discharged from a conveyor, Examples of transfer
points are the discharge from one conveyor onto another, the
discharge from a lag onto a conveyor, or the discharge from a
storage silo onto a tunnel belt conveyor. If these transfer
points are not hooded, fugitive particulate matter way be emitted
directly to the interior of the elevator or directly into the
atmosphere.
Particulate emissions from handling equipment can be prevented
in many areas through the use of totally enclosed equipment. Another
method which minimizes particulate emissions is to handle grains
at slower rates. This reduces agitation of the air around the
flowing grain and less particulate matter becomes airborne.
Z-2B
-------
Uncontrolled particulate emissions from handling operations
are estimated to be 6.0 pounds per ton (Ib/T) of grain. Again,
the amount of paniculate matter generated is dependent ypon the
same parameters which have been previously discussed; These are:
1. the type of equipment used;
2, the speed of operation;
3, the type of grain;
4. its moisture content;
5, the amount of entrained foreign material; air!
6. thi volume of ventilated air.
2.2.6 Grain Drying
Grain with more than 14 percent moisture must be dried to prevent
its spoiling. Therefore, it must be dried within a few days after
receipt. Corn, soybeans, and milo are the three major grains that
require drying. A typical country elevator might be equipped with a
1000 bushel per hour (bu/hr) dryer while a typical terminal
elevator may have one or several 2000 bu/hr dryers. There are two
basic types of grain dryers, rack and column (see Figure 1-6).
Grain enters the top of both types and flows downward 1n a continuous
stream and out the bottom, Air blown through the grain streams
evaporates the excess moisture. Grain with 16-22 percent moisture
can be reduced to 13 or 14 percent in one or two passes through
the dryers.
2-29
-------
SECTION
I
W
O
COOLER
SECTION
COLUMN DRYER
Figure 2-6. Grain dryers.
-------
Participate matter and chaff can become entrained in the air
and carried from the dryer. The potential quantity of participate
emissions is largely dependent on the type and model of dryer.
In a column dryer the grain flows in a continuous column between
two perforated metal sheets to the bottom. Host of the particulate
matter is trapped within the column of grain and never reaches
the side of the dryer. A rack dryer contains baffles or racks
around which the grain and hot air must flow. This creates
a cascading rotion of the qrain and can cause increased
particulate emissions. The dryer is also more open, since
the air does not pass through metal sheets,
Uncontrolled particulate emissions are estimated to be
as much as 0.5 pound per ton (lb/T) of grain from column
dryers and 4.0 pounds per ton (lb/T) of grain from rack
dryers J7 The amount of participate matter generated is
dependent upon:
1. the type of dryer;
2. the model of dryerj
3. the type of grain dried; and
4. the amount of entrained foreign material.
2.2.7 Truck Loading
Grain 1s usually shipptd by truck from country elevators.
The arain to be loaded out is weighed in the scale hopper
and then dropped into the lower surge bin. It flows directly from
the surge bin down a chute into the truck (see Figure 2-7). Often
the loading area is not enclosed and wind that blows across the end
2-31
-------
GRAIN
i
CO
INJ
RAILCAR LOADING TRUCK LOADING
Figure Z-7. • Truck and railcar loading.
-------
of the loading spout entrains particulate matter from the grain
stream. type of enclosure could greatly reduce the
atmospheric particulate emissions. Participate emissions can
also be reduced by decreasing the free-fall distance between
the end of the loadinq spout and the truck bed. This can
be done with a canvas sock or a telescoping loading spout,
Uncontrolled pafticulate emissions from truck loading have
not been estimated. The amount of particulate matter generated
by truck loading is dependent upon:
1. the amount of protection from the wind;
2, the free-fall distance between the end of the spout and
the truck bed;
3, the type of grain;
4. its moisture content; and
5. the amount of entrained foreign material.
2.2.8 Rail car Loading
2.2,8.1 Hopper Cars - Grain is shipped by hopper cars from country and
inland terminal elevators. They are loaded through either a long
rectangular hatch down the center of the car or two rows of round
hatch openings. The grain to be loaded out is weighed in the scale
hopper and then drops into the lower surge bin. It flows from the
surge bin directly down a loading chute into the rail car (see
Figure 2-7). Particulate matter can be entrained in the air
displaced from the car.
Reducing the free-fall distance between the end of the spout
and the top of the hopper car with canvas socks or telescoping loading
2-33
-------
lowers partieulate emissions because it decreases the
winnowing effect of wind blowing across the end of the loading spout.
Be amount of particulate matter escaping the car can be
by keeping hatch .openings closed if possible. Some type of enclosure
around the loading could also diminish particulate emissions.
Uncontrolled particulate emissions from hopper car loading
1 *%
have been estimated at 0,27 pound per ton 0b/T) of §ra1n.
The amount of particulate matter generated is dependent upon:
1. the amount of protection from the wind;
2. the free-fall distance between the end of the loading spout
and the top of the hopper cari
3. the open area (hatches) through which air can be displaced
from the car;
4. the type of grain;
5, its moisture content; and
6. the amount of entrained foreign material,
2,2,8.2 Boxcars - Before a boxcar can be filled with grain, grain
must be installed over the doorway in the side of the car. The
grain door, constructed of or heivy cardboard, covers about
three-fourths of the height of the door opening. The grain is directed
from the scales down a loading spout and through the opening above
th« grain door (see Figure 2-7). Particulate matter can be entrained
in the air displaced from the car. Some type of enclosure around
the loading area could also diminish particulate emissions.
2-34
-------
Uncontrolled participate emissions from boxcar loading have
been estimated to be 0,27 pound per ton (Ib/T) of grain. The
amount of particulate matter generated is dependent upon:
' 1, the amount of protection from the wind;
2. the type of grain;
3. its moisture content; and
4, the amount of entrained foreign material.
2,2.1 Barge Loading
There are two mechanisms which result in particulate emissions
during the loading of barges. The first is when the grain drops
from the loading spout into the barge (see Figure 2-8). Often,
a free-fall distance of several feet between the end of the spout
and the top of the barge allows wind to entrain particylate
matter fwom the grain stream. This free-fall distance can be
reduced and particulate emissions minimized by using canvas
socks or telescoping loading spouts. The second is re-entrain-
ment as the particulate matter boils up from the hold. Barges
can carry approximately 50,000 bushels of grain. The hold,
is often covered with four large steel hatches. To fill a hold
the entire top must be uncovered by a crane. The newest designs,
however, use a large fiberglass cover with several small hatches
that one man can swing open. The smaller hatch openings minimize
the surface area of the grain that is exposed to the wind. This
is a very important improvement since there appear to be no
barge loading areas that are enclosed and entrapment by the wind
is the major mechanism by which particulate emissions occur.
2-35
-------
i
to
cn
LOADING
GRAIN
HA8DHAT
BUTTERfORTH
/•GRAIN
BULK
TANKER
'TWEEN
figure 2-8. Barges and ship loading.
-------
Uncontrolled particulate emissions from barge loading have
18
been estimated to be 1.2 pounds per ton (Ib/T) of grain. The
amount of particulate matter generated is dependent upon:
1, the open area of the top of the barge;
2. the free-fall distance between the end of the loading spout
and the top of the barge;
3. the type of grain;
4, its moisture content; and
b. the amount of sntrained foreign material.
2.2.fcTship Loading
Grain loaded into ships is conveyed from the scales to the loading
dock where it drops down long spouts into the ship's hold at rates
of about 40,000 bushels per hour.
Fifty to 80-foot loading spouts are not unusual. Particulate
emissions increase with the length of the spout because more
particulate matter is created by abrasion of the kernels
as they bounce down the long loading spout. The velocity
of the falling grain also increases, which causes an increase
in the amount of air entrained in the grain stream. Strong
winds, typical of sea coast areas, also increase particulate
emissions by entraining particulate matter from the free falling
grain stream below the loading spout. Increased loading rates
cause more rapid displacement of particulate-laden air from the
hold and also increase particulate emissions.
2-37
-------
Uncontrolled participate emissions from ship loading
have been estimated to average 1.2 pounds per ton (Ib/T) of
1R
grain. The amount of particulate matter generated is
dependent open:
1. the length of the loading spout;
2. the loading rate;
3. the type of ship;
4. the type of grain;
5. its moisture content; and
6. the amount of foreign material in the grain.
Three types of ships are used to fiaul grain. Each presents
a different source of participate emissions, (see Figure 2-8).
2.2.10,1 Bulk Carrier - The bulk carrier's hold is compartmented
by a series of vertical bulkheads. There are no internal structures
to hamper the loading operation. Hatch openings are large and
permit easy access to all parts of the hold. The loading
operation for this ship can be separated into two stages;
1} general fillinn to within four feet of the top of the hold;
and 2} "topping off" or filling the top four feet of the hold.
Particulate emissions are greatest during "topping off" because
the wind can readily carry the particulate matter away. The
hold cannot be covered at this time because it is necessary
to move the spout around rapidly to spread the grain. Therefore,
it is necessary to minimize the distance between the spout and
the grain surface in order trt reduce participate emissions.
2-38
-------
2.2.10.2 'Tweendecker1 - The hold of the 'tweendecker' is similar
to a bulk carrier except that instead of an unencumbered open space,
the 'tweendecker1 has two horizontal Intermediate decks (see Figure 2-8).
The grain must.be carefully stored under the intermediate decfcs to
assure the hold is completely filled. Otherwise the grain could shift,
'which could cause the ship to list or capsize. To position the grain
under the intermediate deck, a "trimmer" or high-speed conveyor belt
is used to throw the grain from the loading spout. This trimmer
generates a large amount of particulate matter so that loading a
'tweendecker' results in more particulate emissions than a bulk carrier.
2.2.10,3 Tanker - A tanker is designed for transporting liquid in
bulk, but is often used for grain. Access to the holds is gained
through two types of hatches. The primary hatch, the "hardhat," is
three feet in diameter and is used for loading most of the grain.
The "butter-worth" is one foot in diameter. It is used for filling
the small spaces which remain after filling through the hardhats.
Less particulate matter escapes during filling of tankers than other
ships since they are more enclosed.
2-39
-------
REFERENCES
1, "Agricultural Statistics, 1973, "U. S. Department of Agriculture,
Washington, D.C., 1973, pp. 1, 16, 20, 28, 35, 41, and 50.
2, "Emissions Control in the Grain and Feed Industry, Volume I - Engineering
and Cost Study," by Midwest Research Institute for the U, S. Environ-
mental Protection Agency, EPA 45Q/3-73-003a, December 1973, pp. 9-11.
3. Ibid., p. 17, and supplemental data from the U, S. Department of Agri-
culture.
4. "Economic Impact of Anticipated Pollution Abatement Costs for Grain
Storage: Grain'Elevators and Storage Facilities of Soybean Processing,
Wheat Milling, Wit Corn Milling, and Dry Corn Milling Plants," prepared
by Arthur 0. Little, Inc., for the U, S. Environmental Protection Agency,
Contract No. 68-02-1349, Task No. 3, August 1974, p. 30.
5. Ibid.. p. 130.
6. Reference 2, p. 20.
7. Reference 2, p. 6.
8. Reference 2, p. 525.
9. Reference 2, p. 526.
10. Reference 2, p. 523,
2-40
-------
11. "Potential Dust Emissions from a Grain Elevator in Kansas City, Missouri,"
prepared by Midwest Research Institute for the U.S. Environmental Protec-
tion Agency, Contract No. 68-02-0228, Task No. 24» May 1974, p. xiv.
12. "Analysis of Final State Implementation Plans - Rules and Regulations,"
U.S. Environmental Protection Agency, APTD 1334, July 1972, p. 29-31.
13, Reference 11, p. xiii.
14. Reference 2, pp. 122t 123, 125, 127, and 128.
15. Pfaff, Roger 0., "Emission Testing Report" for Plant E» EMB Test No.
74-GRN-7, January 1974.
16. Reference 2, p. 23.
17, "Emission Control in the Grain and Feed Industry, Volume II - Emission
Inventory," by Midwest Research Institute for the U.S. Environmental
Protection Agency, EPA 450/3-73-003b, September 1974, p. 17.
18. Reference 2, p. 118.
2-41
-------
3. SUMMARY OF THE PROCEDURE FOR THE DEVELOPMENT
OF THE PROPOSED STANDARDS^
3,1 LITERATURE REVIEW AND INDUSTRIAL CONTACTS
The program for development of standards of performance for grain
elevators relied largely on results of a previous investigation of air
pollution emissions and control techniques in the grain and feed industry
sponsored by EPA. This earlier study contains the responses of 5*19
elevators throughout the country to a questionnaire on the air pollution
aspects of their business. During the study, discussions were held with
numerous individual grain marketing companies, manufacturers of process
and control equipment, and a trade association (National Grain and Feed
Association). State air pollution control agencies were contacted for
their recommendations on the "best controlled" grain processes in their
areas, Based upon the information from these sources, a number of
elevators were selected for on-site visits. Later* certain of these
were more closely evaluated by actually measuring the emissions from
tnetr control devices.
3,2 PLANT INSPECTIONS
EPA engineers selected and visited forty-five reportedly well-controlled
elevators to evaluate the participate control systems and obtain infor-
mation on the major equipment or operational parameters that affect
emissions. Tht major details noted during the inspections were:
1. design and effectiveness of hoods,
2. type and effectiveness of control devices,
3. visible emissions at the point of paniculate matter
generation and pickup,
4, visible emissions from the control device,
5. maintenance schedule for fa&He filters',
3-1
-------
6, adequate emission test locations,
7. process operation and cycle,
8. process variables that are regularly measured, and
9, types of grains handled and periods of operation.
From these visits, 20 plants were selected for actual measurement
of particulate emissions.
3.3 SAMPLINfi AND ANALYTICAL TECHNIQUES
3,3.1 Elevators
EPA Reference Method i was used to gather the used to
support the proposed particulate standards for emissions from
control devices at grain elevators. The provisions of this method
were originally published in the FederalJe^lster on December 23,
1971 (36 FR 24877). Minor revisions of the method have been
published since then. The method provides detailed sampling
methodology and equipment specifications. The method also provides
specific procedures for the measurement of moisture content and
volume of gas sampled, and permits continuous assurance of isoklnetic
sampling,
Method 5 was not used exactly as prescribed in the FederaJ_ Register.
The electrical heating systems for the probe and filter holder were not
used because the gas streams sampled were of low temperature and
moisture content and grain dust (particulite matter) presents a
oossible explosion hazard. Under these stack conditions, the operation
of Method 5 without probe or filter heaters does not affect the
accuracy of the results. The effect of operating the sampling train
3-2
-------
without heaters is that the in-staek and out-of-stack filtration
methods can be considered equivalent.
Sampling and analytical techniques for participate matter are
discussed in more detail in Chapter 8, section 8.7.
3.3.2 Dryers
Grain dryers typically exhaust directly from the outlet of the
control device to the atmosphere without the use of an exhaust stack.
The cross sectional area of the outlets is generally quite large. The
resulting low velocities and unconfined flow are not amenable to
sampling with conventional techniques. Therefore, during the develop-
ment of the standard of performance, attempts were made to
develop methodology which would allow representative sampling. Since
hooding could cause exhaust pressure buildup and upset the drying
process the procedures which were employed focused upon techniques
for measuring low velocities, and for obtaining representative samples
unaffected by crosswinds. Both a hot wire anemometer, and special
pitot tube technique were used in attempts to accurately measure velocity,
A three-foot section of 12-inch diameter duct was placed perpendicular
to the exhaust outlet to serve as a mini-stack. Sampling was conducted
at the center of the duct section while the duct section was traversed
across the control device outlet.
Based upon the experience gained during two tests employing
these techniques, it was concluded that sampling results of acceptable
*
accuracy could not be obtained. Both the problem of crosswinds, and
the strong vertical component present in the exhaust gas flow which
varies from source to source were identified as primary factors pre-
venting obtainment of representative samples.
3-3
-------
3.4 EMISSIONS MEASUREMENT PROGRAM
3.4.1 Elevators
EPA used Method 5 to perform participate emission tests on 11
installations at grain elevators controlled by fabric filters. The
systems chosen for tests controlled well-defined operations where the
process weight could be determined. The systems collected partlculate
matter generated during truck unloading, boxcar unloading, barge unloading,
conveying and transfer, grain cleaning, railcar loading, and ship
loading.
Each test consisted of three, two-hour test runs, except as noted
in Chapter 5 for facility I. Srain handling operations are intermittent,
therefore, the sample train was stopped and restarted several times
during each test to coincide with the process operation. Process
parameters monitored during each test were:
1. the type of grain handling systems (deep or shallow hopper,
telescoping spout, etc.),
2. the type of grain processed,
3. the weight or volume of grain processed,
4. the percent moisture in the grain,
5. the percent foreign material (chaff, other grains, broken
kernels, stones, etc,} in the grain,and
6. the conveyor belt speed (where appropriate).
* >
Particle size was measured at five of the facilities using a Brinks
impactor. In all but one case, attempts to measure the particle size
of uncontrolled paniculate emissions entering the fabric filters
(inlet tests) were unsuccessful. Large particles plugged the sample
3-4
-------
nozzle preventing further sampling. In tests of outlet
particulate emissions from the fabric filters, not enough
participate could be collected on the impaetion plates to
weiph accurately.
Visible emissions were observed for a minimum of 1 hour
at nine elevators from both the fa&rfc filters and sources of
fugitive particulate emissions.
3.4.2 Dryers
EPA attempted to develop a standard test procedure for
grain dryers and obtain representative particulate emission
samples from two dryers. It was concluded that much more
work would be required to develop a reliable test procedure.
Visible emissions were observed for at least one hour at
four column dryers and for one-half hour at one column dryer.
Two rack dryers were also observed for visible emissions.
3-5
-------
REFERENCES
1. "Emission Control in the Grain and Feed Industry, Volume II -
Emission Inventory," by Mectwest Research Institute for the
United States Environmental Protection Agency, £PA-45Q/3~73-OQ3b,
September 1974, p. 3.
3-6
-------
4. EMISSION CONTROL TECHNOLOGY
A discussion of emission control technology in this industry must
separately consider the equipment used to capture particulate emissions
and that which actually removes pollutants from a gas stream. Grain
elevators use a large variety of equipment to capture particulate
emissions from the many processes; however, they all use similar
equipment or control devices to remove the captured particulate from the
effluent gas stream. Data from a questionnaire survey on the types
o* emission control devices currently in use at 324 country elevators,
196 inland terminal elevators, and 12 port terminal elevators are shown on
Table 4-1.]
Almost every elevator that does control emissions uses either a
cyclone or fabric filter. Cyclones are classified as either high
efficiency or low efficiency. High-efficiency cyclones are characterized
by a narrow inlet opening, long body length relative to body diameter,
and a small outlet diameter. The higher gas velocity in the cyclone
results in a collection efficiency of about 85 to 95 percent. The pressure
drop across a high efficiency cyclone may be 3 to 5 inches of water. This
is the most conuion control device used at elevators. Low-efficiency
cyclones have large inlet openings, large diameter bodies and large out-
let diameters. The slower gas velocity results in collection efficiencies
between t>0 and 85 percent and pressure drops of only 0.5 to 2.0 inches of
water.
Table 4-1 shows that fabric filters are not now used at country
elevators, but are used at terminal elevators and processing plants. Their
4-1
-------
TABLE 4-1
CONTROL DEVICES AT EXISTING ELEVATORS
Facility and
Process
Country
Receiving
Shipping
Cleaning
Trans f er
Legs
Scale and surge bins
Inland Terminal
Receiving
Shipping
Cleaning
Trans f er
Legs
Scales and surge bins
Tri pper
Port Terminal
Receiving
Shipping
Cleaning
Transfer
Legs
Scales and surge bins
Tri pper
Process Storage
Receiving
Cleanings
Transfer
Legs
Scales and surge bins
Tri pper
Percent
Fabric Filter
0
0
0
0
0
0
19
17
10
27
24
8
8
46
0
15
27
41
41
1
42
44
58
50
45
50
Controlled
Cyclone
30
21
60
27
58
26
40
12
33
64
53
17
14
30
26
22
55
22
22
56
16
55
26
30
23
24
by
Other Divice
1
1
13
0
1
1
0
1
0
-
-
-
-
0
0
0
_
_
-
-
2
1
_
«.
_
-
Percent with
No Control
69
78
27
73
41
73
41
70
57
9
23
75
78
24
74
63
18
37
37
43
40
__
16
20
32
26
aPerctnt of controlled plants, only. Data were not sufficient to determine
the percentage of plants without controls,
4-2
-------
most common use is the control of participate emissions from transfer
operations. Fifty-eight percent of the terminal elevators use fabric
filters. These are frequently located in metropolitan areas whert control
requirements are greater.
The typical modern fabric filter at an elevator handles 2000 to
30,000 cubic feet of air per minute, Most are package units that can be
supplied by several manufacturers. The filters operate under negative
pressure with the fan pulling air through the system. Felted, synthetic
fabrics are the most common collection media, The air-to-cloth ratio is
usually between 10:1 and 15:1, The filter bags are cleaned by reversing
the air flow through them. Air flow reversal methods include forcing the
dust cake off the fabric with back pressure; collapsing the cloth thereby
cracking the dust cake; snapping the cake off with a pulse of compressed
air; and blowing it off with a reverse jet which traverses the outside
surface of the cloth.
The methods of capturing participate emissions for each operation
1n the Industry must be considered individually. Three possible alterna-
tive methods of control are considered for each affected facility.
System 1 represents the control typically required by State regulations.
The best possible system EPA could envision represents System 3 control.
System 2 control represents either an intermediate method between
System 1 and 3 control or is equivalent to method 3 control. These
methods consider the total control of particulate matter for each
facility, the capture system and the control device.
4-3
-------
The most important characteristics of the three levels of control
for each operation are discussed below.
4.1 RECEIVING (UNLOADING)
4.1.1 Trucks
In arid regions, truck receiving hoppers are often completely
uncovered, but may be enclosed by a roof or tunnel in other areas of
the nation. The typical capture system consists of a collection hood
at the back of the receiving hopper. It may be mounted either above
or below the grate. Location below the grate is preferable because the
resulting downward draft helps prevent the escape of particulate
matter generated in the hopper. Baffles installed under the grate
can also help prevent the upward flow of particulate-laden air out
of the hopper. Such systems are .typically designed for a face
?
velocity of TOO feet p ?r minute through the grate. To minimize
the adverse effects of wind on collection efficiency, some type
of enclosure around the receiving area is usually required.
After capture, the particulate matter is ventilated to a cyclone
or fabric filter (Figure 4-1). Emission tests on existing facilities
show average particulate emissions of 0.06 pound per ton (Ib/T) of
grain with cyclone control. Those with fabric filter control emit
0.005 Ib/T of grain.3*4
Three levels of control were considered for truck unload'lrjg stations.
System 1 (typical State regulations) requires the use of a receiving
hopper, ventilated to a cyclone. Weather conditions may require the
use of a shed or a roof enclosure. Method 3 (best technology) would
4-4
-------
CONTROL OE¥ICE
ELECTRICAL
ACCORDIAN
DOORS
Figure 4-1. Truck unloading control system
-------
require enclosure of the operation with a four-sided shed having two
ends equipped with quick-closing doors. The receiving hopper would be
ventilated to a fabric filter at a rate of approximately 12,000 cfm and
would contain baffles. The receiving hopper for System 2 would be
equipped identically as in System 3. However, for System 2, a three-
sided shed is required with one end equipped with a quick-closing
door.
Presently, no such operation as described in System 3 is in
operation. The level of the proposed standard, a 0% opacity limit,
has been demonstrated on presently operating System 2 facilities.
4.1.2 Railcars
4.1.2.1 Hopper Cars - Hopper cars are sometimes unloaded using the
choke feed concept to reduce or eliminate particulate emissions. In
this case the receiving hopper is shallow and the grain is allowed
to form a cone between the opening at the bottom of the hopper and the
receiving grate (see Figure 4-2}. There is a momentary cloud of
particulate matter as the receiving hopper fills, but very little
durinn the remainder of the unloading operation as the grain steadily
flows into the hopper.
Particulate emissions from a deep receiving hopper are contained
by ventilating the particulnte matter from below the grate to a cyclone
or fabric filter. The efficiency of particulate pickup can be increased by
installing baffles under the grate to help prevent the upward flow
of particulate-laden air out of the hopper. Such systems are typically
P
designed for a face velocity of 100 feet per minute through the grate.
4-6
-------
-ft.
i
*SI
119
-------
Some type of enclosure around the unloading area can also prevent
wind from decreasing the effectiveness of the particulate matter
capture system. Fast action doors can minimize the resulting
delays in unloading when enclosures are used.
Particulate emissions from cyclone-controlled hopper car
unloading operations are estimated to be 0.1 1B/T of grain received.
When fabric filters are used, parttculate emissions are reduced to
about 0.0002 Ib/T of grain.5
Two levels of control were considered for railroad hopper car
unloading stations. System 1 requires an operation equipped
with a three-sided shed with one end being a quick-closing door. The
receiving hopper is ventilated to a cyclone, except at port terminal
elevators where fabric filters are used. System 3 and System 2 require-
ments are identical in this situation. A totally enclosed shed is
required with quick-closing doors on two ends. The receiving hoppers
are equipped with baffles and are ventilated at a rate of 15,000 to 25,000 cfm
(depending on the size of the facility) to a fabric filter.
The proposed standard of no visible emissions is based on a transfer
of technology from boxcar unloading facilities equipped with the control
technology required by Systems 2 and 3.
4.1.2.2 Boxcars - The boxcar unloading area may be covered by a
roof or have some type of shed enclosure. Since most of the particu-
late matter is generated in the receiving hopper, it is usually
captured by a hood located below the grate and ventilated to a cyclone
or fabric filter (see Figure 4-2). Baffles installed under the grate
help prevent the upward flow of particulate-laden air out of the
receiving hopper.
4-8
-------
The efficiency of partieulate matter pickup can be improved by
stopping wind action with a flexible enclosure around the car
door (Figure 4-3} or by enclosing the receiving area with
type of shed (Figure 4-2). Fast-action doors can minimize the
resulting delays in unloading. Capture systems for these facilities
are typically designed for a face velocity of 100 feet per minute
2
through the grate.
Particulate emissions from boxcar unloading operations with
cyclone control are estimated to be 0,1 Ib/T of grain received.
When fabric filters are used, the partieulate emissions are about
0.0002 Ib/T of grain.5
The two levels of control investigated are identical to those
systems described under hopper car unloading and the proposed standard
of no visible emissions has been demonstrated at facilities equipped
with the control technology required by Systems 2 and 3.
4.1.3 Barges
To minimize particulate emissions from unloading grain from barges,
the bucket elevators (marine legs)* receiving hoppers, and conveyor
belts can be enclosed. Particulate matter is ventilated from the
enclosures to a cyclone or fabric filter (Figure 4-4). Good maintenance
of the enclosures is essential for good capture. Particulate emissions
from barge receiving operations which use cyclones are estimated
to be 0.2 Ib/T of grain received. Fabric filters are able to control
particulate emissions to about 0.0006 Ib/T of grain.
Two levels of control, the requirements of System 1 and Systems
2 and 3, were examined for barge unloading of grain. The requirements
of Systems 2 and 3 are identical for the unloading of barges.
4-9
-------
CONTROL
DEVICE
UNLOADING
DEVICE
ENCLOSURE-
CONVEYOR
*3W//*W/
HOPPER
4-3, Boxcar unloading control system.
4-10
-------
FABRIC
FILTER
MARINE
LEG
k
;
J
^
9—
1
i •—
'r
0_ 1
^ 1
^-™
i
\r
H :
BARGE
Figure 4-4, ]Barge receiving control system.
-------
System 1 requires an enclosed bucket elevator (leg) with venti-
lation to a fabric filter. Systems 2 and 3 require an enclosed
leg from the top (including the receiving hopper) to the center line
of the bottom pulley. Ventilation to a fabric filter shall be
maintained, on both sides of the leg and the grain receiving hopper,
at a rate of at least 32.1 actual cubic meters per cubic meter of grain
handling capacity (ca. 40 ft3/bushel).
Due to the high level of visible emissions obtained, an equipment
standard has been proposed. The specifications previously listed
for Systems 2 and 3 have been demonstrated and EPA has based the proposed
standard on these specifications.
4.2 HANDLING AND CONVEYING EQUIPMENT
4.2.1 Transfer Points
Screw conveyors are enclosed and are operated slowly (less than
100 feet per minute) so that minimal particulate matter is emitted.
Drag conveyors are totally enclosed; however, air may be ventilated
from the enclosure to a cyclone or fabric filter to maintain a slight
negative pressure. Hoods are needed on belt conveyors only at
points where the grain is disturbed (i.e., where it enters or leaves
the belt). Otherwise, a column of air travels with the conveyor
an! does not disturb the particulate matter in the grain. Sometimes, ,
if transfer points are close together, the belt is hooded along its
entire length. The capture velocity of air into the hood should
be 100 feet per minute faster than the speed of the conveyor
belt (500-600 feet per minute) to overcome the laminar layer of air
2
that accompanies the grain away from the hood. Trippers and turn
heads are additional transfer mechanisms. Trippers are usually hooded
4-12
-------
and ventilated to a control device. Turn heads are usually totally
enclosed or hooded.
Air and particulate matter are ventilated from the hoods to
cyclones or fabric filters (see Figures 4-5 and 4-6). Particulate
emissions from cyclones used to control conveyor belts are estimated
to be about 0.1 Ib/T of qrain handled. Particulate emissions from
3
fabric filters have been measured at about 0,0002 Ib/T of grain handled.
4.2.2 Legs
When grain enters the bottom of a "leq" or bucket elevator, a
positive pressure is created at the top. It is necessary to relieve
this pressure by venting the leg, connecting the top and bottom
with a pipe or increasing the size of the housing on the downside
of the leg. Particulate matter can build up in unvented legs
creating explosive conditions; therefore, some insurance companies
require that they be vented to minimize this possibility.
Particulate emissions from leg vents can be controlled by cyclones
or fabric filters (see Figure 4-7). Cyclones are estimated to emit
about 0.1 Ib/T of grain handled. Fabric filters control to about
0,0002 Ib/T of grain handled.
4.2.3 Scales and Garners
A scali hopper or bin and the associated surge bins (garners)
may be vented to a common collector. Both cyclones and fabric filters
are used. It is also possible to vent the bins to etch other such
that air is exhausted to a common control device.
4.2.4 Storage Silos
Normally, particulate emissions from silos are not visible and,
therefore, they are not controlled. In some cases, storage silos have
4-13
-------
UJ
oo
EC
o
>
e
E
o>
A|MI
W
8
c
1
o
%-
CO
o>
&.
c-»
•r™
U_
4-14
-------
,"~r
CLEANER1
FILTER
V
HEADHOUSE
FILTER
V
TUNNEL BELT SYSTEM
4-6. Grain handling and cleaning control System.
-------
ELEVATOR LEG
Figure 4-7. Elevator leg.
-------
been ventilated to a fabric filter. The magnitude of particulate
emissions from storage silo vents has hot been estimated; however, EPA
believes these emissions to be minimal and therefore does not
cover silo vents under the proposed standards.
4.2.5 Scalpers and Cleaners
Participate emissions from screen cleaners and scalpers are
controlled by hooding or enclosing the equipment and ventilating
the participate matter to a cyclone or fabric filter (see Figure 4-6).
The more efficient ventilated cleaners use tight enclosures around
the screens and more suction to lift out light impurities. A recent
development is screen cleaners winch, have air-tight enclosures
and require no ventilation or particulate emissions control device.
Scalpers are usually totally enclosed,
Particulate emissions from screen cleaners without ventilation
which are controlled with cyclones are estimated to be 0.3 Ib/T
of grain handled and those with fabric filters can control particulate
emissions to about 0.003 Ib/T. Particulate emissions from cleaners
with ventilation are estimated to be 0.6 Ib/T with cyclone control
and 0.014 Ib/T with fabric filters.7
4.2.6 Headhouse and Other Such Structures
Fugitive particulate emissions from the headhouse and other
structures which may house additional grain handling operations can
be minimized by properly controlling the operations inside of these
4-17
-------
structures. In addition, the headHouse itself can be ventilated
to an air pollution control device, Particulate emissions from
headhouses and similar structures have not been estimated.
4,2.7 Control Systems for Handling Operations
Two levels of control were considered 1n the standard setting
process for grain handling operations. Typical State regulations,
System 1, require grain handling operations to be ventilated to a
cyclone, except at terminal elevators where ventilation to a fabric
filter is required. System 3 (best technology) and System 2 require-
ments are identical for grain handling. All grain handling operations
require ventilation to fabric filters or total enclosures.
The proposed standard of zero percent opacity has demonstrated
on System I and 3 grain handling operations.
4.3 DRYING
There are two typts of dryers used 1n the Industry, column "and
rack. Uncontrolled column dryers are cleiner than uncontrolled rack
dryers by virtue of their design. Emission tests, which can only be
ysed as a guide in developing the standards due to testing inaccuracies,
performed on column dryers with no control showed pirticulate emissions
of about 0.25 lb/T»8 ind particulate emissions of about 0.18 Ib/T of
9
grain dried from a column dryer equipped with a 58 mesh screen.
Partieulate emissions from a column dryer with O.OS inch diameter
perforations in the column sheeting were measured-at 0,05 Ib/T of
gnin dried.
To* simplest control technicpe used on a rack type dryer is a
screen house. A large enclosure is built around the dryer exhaust
with 24 screen to retain the beeswings. The beeswings settle
to the ground and are periodically removti by hand. More sophisticated
vacuum-cleaning control devices use metal or polyester screens, is shown
4-18
-------
in Figure 4-8, Commonly used screen sizes vary from 35 to 100 mesh.
Vacuum heads automatically sweep the screen to clean it of captured
particles. Partfculate emissions from rack dryers are estimated to
be 1.5 Ib/T of grain dried when a 24 mesh screen is used, about
0.3 Ib/T when a 50 mesh screen is used, and were measured at 0.05
"Ib/T when a vacuum-cleaned 100 mesh screen was ysed.^
Figure 4-9 shows the results of emission tests performed on
rack and column dryers. This graph shows that participate emissions
from a rack dryer equipped with a 50 mesh vacuum-cleaned screen
are approximately equal to particulate emissions from a column dryer
with no screens. It must be noted again that these data can only be
used as a guide due to the testing inaccuracies encountered.
Three levels of control were discussed for column grain dryers
and for rack grain dryers. EPA determined that typical State regulations,
System 1, require no screens (filters) on column dryers and 24-30 mesh
screens (filters) on rack dryers. System 3 control requires a
100 mesh vacuum-cleaned screen (filter) on both column and rack
dryers. System 2 would require no screens (filters) on column dryers
and 50 mesh vacuum-cleaned screens (filters) on rack dryers.
System 2 column dryers have demonstrated that the proposed standard
of 01 opacity 1s achievable. Column dryers with column perforation
plate hole diameters of 0.084 inch or less have also demonstrated com-
pliance with the proposed 01 opacity standard. System 3 is economically
prohibitive for column dryers as explained in Chapter 6. Using 100 mesh
vacuum-cleaned screens (filters) instead of 50 mesh vacuum-cleaned screens
(filters) on rack dryers results in increased operating costs and
only minimal reduction in particulate emissions. Particulate emissions
from column dryers with no screens (filters) are approximately equivalent
4-19
-------
I
SCREEN
FILTER
WITH
VACUUM
CLEANING
SYSTEM
Flguff 4-8. Rack dryer wllh screen fitter.
4-20
-------
O RACK DRYERS
D COLUMN DRYERS
40 60
MESH (U.S, SIEVE SERIES) OF
Figure 4-9. Dryer emissions versus "Screen size.
100
4-21
-------
to participate emissions from rack dryers with 50 mesh screens
(filters). Chapter 8 explains this rationale in more detail.
4.4 LOADING
4,4,1 Trucks
Very few truck loading stations have ventilation type control
systems. Particulate emissions from truck loading can be minimized
by reducing the free-fall distance between the end of the loading
spout and the truck bed. This can be accomplished with a telescoping
spout as .shown in Figure 4-10 or with a canvas sock extension. The
height of a telescoping spout can be quickly adjusted to any level
to maintain it at the surface of the grain. It can also be designed
to move laterally to spread the grain. Very little maintenance would
be required. A canvas sock can serve the same purpose; however, the
hfeight is not as easily varied and the flexible material does not
work well in other than a vertical position. Canvas socks must be
replaced frequently because some grains are very abrasive and quitikly wear
holes through the canvas. A permanent hooding device can also be
installed but must take into account the variety in size and height
of trucks. Capture can be improved if the loading area is enclosed
by some type of shed, Particulate emissions from truck loading
facilities controlled with cyclones are estimated to be 0.03 Ib/T.
Fabric filters can control particulate emissions to about 0.001 Ib/T.
EPA considered three levels of control in developing the proposed
standards for truck loading stations. The requirements of typicil State
standards is System 1. This requires ventilation to a cyclone. Weather
conditions may require a shed or a roof to protect the loading operation.
System 3, considered by EPA to be the best control technique, requires
4-22
-------
ELECTR1CAD
ACCORDIAN
OOORS
Figure 4-10, "truck loading control system.
4-23
-------
ventilation "to a fabric filter and a totally enclosed shed around the
truck loading operation. Two ends can be equipped with quick-closing
doors. System 2 requires ventilation to a fabric filter as in System 3;
however, it requires a shed with only three sides. One end can be
equipped with a quick-closing door.
The proposed standard of 10% opacity has been achieved by a
System 2 truck loading operation. Presently no such operation as
System 3 exists in the field,
4.4.2 Railcars
4.4.2.1 Hopper Cars - Paniculate emissions from hopper car loading
can be similarly minimized by use of a telescoping loading spout or
a canvas sock extension. All hatch doors on the car must be kept
closed except for the one grain fs entering. This allows the car
to act as its own settlinn chamber.
Another technique used is to install a hood at the discharge of
the loading spout. The particulate matter is captured and ventilated
to a control device as shown in Figure 4-11. In this case also* the
hatch doors must be kspt closed. Control can be further improved if
the loading area is enclosed by type of shed. Controlled particulate
emissions from hopper car loading facilities which use cyclones are
estimated to be 0.03 Ib/T. Fabric filters can achieve about 0.001 lb/T.12
There are basically three control technology systems for railroad
hopper car loading. System 1, which reflects typical State regulations,
requires a hooding system ventilated to a cyclone. System 2 requires
the same type of hooding system but with ventilation to a fabric
filter. In addition, a special loading spout and a shed with two
open ends around the operation are required. System 3, the best
4-24
-------
GRAIN
SPOUT
^EXHAUST AIR DUCT
TO FILTER
3-WAY
VALVES^ i •
IK t I
I i
NOTE: 3-WAY VALVE LEADlNfi TO FLEXIBLE LOADING SPOUTS PERMITS
LOADING OF CENTER OR SIDE OPENINGS IN TOP OF HOPPER CARS.
Figure 4-11, Hopper car loading control system.
4-25
-------
possible control technology, requires the sane hooding, ventilation and
loading spout as System 2. However, a totally enclosed shed with quick-
closing doors on two ends is required.
No such operation as System 3 1s presently 1n use, System 2
operations have demonstrated that the proposed opacity limit of
Q% is achievable.
4.4,2.2 Boxcars - Presently, very few boxcar loading stations use
any type of control device. The participate emissions can be captured
by a hood located beside the track as shown in Figure 4-12. An
enclosure should be extendable from the hood to the door of the
car. The particulate matter can then be ventilated to a cyclone or
fabric filter. Control can be improved if the loading area'is enclosed
/
by some type of shed. Controlled particulate emissions from boxcar loading
facilities equipped with cyclones are about 0.03 Ib/T of grain loaded, A
fabric filter would emit less than 0,001 Ib/T.
Railroad boxcar loading operations, as in railroad hopper car loading
operations, have three levels of control which were considered by EPA,
System 1 requires some form of hooding system ventilated to a cyclone.
System 3 requires a totally enclosed shed with quick-closing doors on
two ends and a tightly sealed (side-door) hooding system ventilated to a
fabric filter. System 2 requirements are identical to System 3 requirements
except that a shed with two open ends is required.
EPA is proposing a zero percent opacity standard for railroad boxcar
loading stations based on a transfer of technology from railroad hopper
car loading stations.
4.4.3 Ships and Barges
Particulate emissions from barge loading can be minimized by reducing
the free-fall distance from the end of the spout to the grain surface
4-26
-------
LOADING SPOUT
EXHAUST DUCT
EXHAUST DUCT
APPROX. 12" CLEARANCE
BETWEEN BOXCAR AND HOUSING
Figure 4-12; Control syst*m for boxcar loadinq.
4-27
-------
as discussed 1n the truck loading section. All hold hatches not being
used should be closed. In addition, ventilation from the discharge end
of the spout may be necessary (Figy|»e 4-13), The particulate matter-
ventilated from the end of the spout can be collected in a cyclone
or fabric filter. Particulate emissions from cyclones which control
barge loading are estimated to 6e 0.06 Ib/T. Fabric filters can achieve
about 0.001 Ib/T.
Two approaches are used to control particulate emissions from
ship loading.
a. The entire hold is covered with canvas or plastic
except where the loading spout enters. Particulate
matter may be ventilated from beneath the cover to
a cyclone or fabric filter.
b. A telescoping loading spout is kept extended to the
grain surface, Ventilation is applied at the end of
the spout and the particylats latter is collected tn
a cyclone or fabric filter as shown 1n Figure 4-13.
Two variations of this latter approach were observed by EPA. The end
of the loading spout on one operation was extended into the grain surface
to minimize the generation of particulate emissions. The other operation
used a "dead box" system at the end of the loading spout to slow
the flow of the grain as 1t entered the hold. The end of the spout
was kept a slight distance {six inches to one foot) above the grain
level in the hold.
EHtifer approach can be ducted to a cyclone control device which will
emit about 0.06 Ib/T of grain loaded or a fabric filter which will
emit about 0,001 Ib/T.5 '
4-28
-------
DUST
COLLECTOR
HOSE ADAPTER
f FOR TANKIR
Figure 4-13. Barge or ship loading control system.
4-29
-------
Two levels of control were investigated by EPA for barge and
ship loading stations. System 1 requires a choke-feed loading
spout with ventilation to a cyclone. Systems 2 and 3 require a
similar choke-feed loading spout but with ventilation to a fabric
filter.
The best control system has demonstrated that the proposed
opacity limits of 101 for general loading and 151 for topping-off
are achievable.
4.5 ALTERNATIVE CONTROL SYSTEMS
The individual control techniques for each affected facility
previously described in this chapter were formulated into three
alternative levels of control. Each of these alternative systems
control all of the particulate emission sources from a complete grain
elevator. For purposes of determining the economic and environmental
impacts, EPA developed six model elevators and six model processor
elevators. These model elevators are discussed in Chapters. The three
alternative control systems are summarized in this section. To
determine the true impact of a control system on air pollution, the
reduction in air pollution beyond that which would otherwise be
achieved by state or local regulations must be determined. In most
states, grain elevators are subject to a general process weight
regulation designed to minimize particulate emissions from any source.
Examples of such regulations are illustrated in Figure 4-14. With
these regulations the allowable particulate emissions are a function of tha
amount of material being handled. The stringency of such regulations
is often totally dependent on interpretation by the enforcement agency.
4-30
-------
100
*» . g 10
MJ
UJ
CO
-------
Telephone conversations with members of several state agencies revealed
that difficulty has been experienced in defining the source entities at a
grain elevator to which the regulation is appropriate. Most states appear
to interpret each process within an elevator as a separate emission source
which can emit the maximum allowed by the process weiaht reaulation. The
possible extremes, of course, are to regulate: (a) the entire elevator
as one source or (b) each vent or control system as a separate source.
If the sawe process curve is used regardless of interpretation, it
is obvious that allowable emissions increase with the number of emission
points if each vent system is examined Independently. Typical state
visible emission regulations allow fugitive participate emissions up to
20 percent opacity.
From this information, EPA has concluded that a typical State
standard (designated as System 1) requires the following:
System |
1. High-efficiency cyclones on all affected facilities
(excluding dryers), except railcar unloading at port
terminals, barge and ship loading at inland terminals,
and barge and ship unloading where fabric filter controls
are required,
2. No screens (filters) on column dryers and 20 to 30 mesh
screens on rack dryers,
System 2 represents a more stringent level of control and is the
control system on which EPA has based the proposed standards. System 2
consists of the following:
4-32
-------
1. Fabric filter control on all affected facilities excluding
dryers.
2. No screens (filters) on colymn dryers and 50 or finer
vacuum-cleaned screens on rack dryers,
3. Three-sided shed on truck unloading and truck loading.
4. Shed with two open ends for boxcar and hopper car loading.
5, Totally enclosed shed for rail car unloading,
6, Totally enclosed leg for barge and ship unloading.
System 3 represents the best control technology possible not
considering costs. System 3 1s identical to System 2 except for the
following Items:
System_3
1. 100 vacuum-cleaned screens (filters) on column and rack
dryers. ,
2, Totally enclosed sheds on truck unloading, truck loading,
boxcar loading and hopper car loading operations.
4-33
-------
REFERENCES
1. "Emissions Control in the Grain and Feed Industry, Volume I - Engineering
and Cost Study," by Midwest Research Institute for the U. S. Environ-
mental Protection Agency, EPA 45Q/3-73~QQ3a» December 1973, pp. 365-367.
2. "Environmental Controls for Feed Manufacturing and Grain Handling,"
American Feed Manufacturers Association, Chicago, Illinois, 1971.
3. Logan, Thomas, "Emission Test Report" for Plants A and G» tests were
conducted in March 1972.
4. Ward, Thomas, "Emission Test Report" for Plant B, EMB Test No. 72-CI-33(GRN),
prepared for EPA by Environmental Engineering, Inc., August 1972.
5. Pfaff, Roger 0,» "Emission Test Report" for Plants C and J, EMB Test
No. 74-GRN-8, January 1974.
6. Ward, Thomas, "Emission Test Report" for Plant D, EMB Test No.
73-GRN-2, prepared for EPA by York Research Corp., November 1972.
7. Ward, Thomas, "Emission Test Report" for Plant H, EMB Test No. 73-GRN-5,
the tests were conducted in April 1973.
8. "Emission Control in the Grain and Feed Industry, Volume II - Emission
Inventory," by Midwest Research Institute for the U.S. Environmental
Protection Agency, EPA 450/3-73-OQ3b» September 1974, p. 20.
4-34
-------
9. Gerstle, Richard and DeWees, William, "Emission Test Report" EMB Test
No. 74-GRN-9, prepared for EPA by PEDCo Environmental, the test was
conducted November 1973.
10. "Particulate Emission Tests on Zimmerman Grain Dryer at Elliott,
Illinois," prepared by Industrial Testing Laboratories, Inc., Report
No. 27-11-158E, St. Louis, November 1972,
11. Ward, Thomas, "Emission Test Report," EMB Test No. 73-GRN-4, the test
was conducted in April 1973.
12. Riley, C.E., "Emission Test Report" for Plants I and K, EMB Test No.
74-GRN-6, May 1974.
4-35
-------
5, EMISSION DATA TO SUBSTANTIATE THE PROPOSED STANDARDS
Emission data presented in this section are divided into parti-
cipate emission data from fabric filters, participate emission data
from grain dryers, and visible emission/opacity data. EPA inspected
45 elevators in an attempt to find best demonstrated technology
in the grain elevator industry. Partieulate emissions were measured
from 11 processes controlled with fabric filters at eight of these
elevators, EPA attempted to measure particulate emissions from two
grain drying operations. Visible emission/opacity observations
were taken at eleven elevators from both the fabric filters and
the sources of fugitive emissions. The results of these emission
tests are used to substantiate the proposed standards. Appendix C
describes the tested facilities and provides more detail on the
results of the mass partfculate measurements.
5.1 PARTICULATE EMISSION DATA - FABRIC FILTERS
EPA measured particulate emissions from 11 of the best controlled
processes selected from those at the 45 elevators that were inspected.
The results summarized HI Figure 5-1 cover mass particulate matter
emissions resulting from unloading, handling, cleaning, and loading
operations equipped with fabric filter control. Facilities A and B
are truck unloading stations with ventilation of the receiving
hoppers and with three and two-sided enclosures, respectively.
Facility C is a totally enclosed boxcar unloading station at a
terminal elevator. Facilities D and E are barge unloading
operations {marine legs) at port terminal elevators. Facility F
is a completely hooded tunnel conveyor belt and leg boot system,
and Facility S 1s a receiving conveyor belt and leg boot system,
5-1
-------
3O
O
O
f? 3>
o 2
I1 I
PARTICULAIE EilSSIONS gr/dstl
*s
c
o>
tn
E
m
en
O
O
o
o
o
o
3
CD
D.
cr
•<
so
O"
o
S
C3 I""*
09
3>
33
C1
0
ff>
O
i
O T3
o
=«
CD9_ rrrrrjr rrrr ^
- $
r-*
-------
The fabric filter at Facility H collects particulate matter and chaff
ventilated from the whole wheat cleaning system of a flour mill.
Uncontrolled participate emissions from this cleaning process
are greater than from cleaning processes at elevators; therefore,
the controlled participate emissions should be representative of or
higher than what can be achieved at grain elevators. Facility I is
a corn cleaner with some ventilation. Facility J is a ship loading
station and Facility K 1s a raflcar loading station with a shed
with two open ends. In all cases, the processes are controlled
by fabric filters using felted, synthetic fiber bags, reverse
air cleaning and an air-to-cloth ratio of about 10:1.
Whenever possible, all test runs at each facility were conducted
while only one of the four major grains (corn, wheat, soybeans, milo)
was processed. However, at some facilities a mixture of these grains
was handled through the test period. Facilities A, G, and I handled
only corn; Facility B, only soybeans; and Facilities C, H, and J,
only wheat. Facility F handled milo exclusively during the first
four test runs and wheat during the fifth test. The remaining
facilities {D» E» and K) handled mixtures of two or four grains.
The data do not show any effect on the emissions from the type of
grain processed.
At most of the facilities, three test runs (2 hours each) were
conducted according to EPA's Method 5 except that no heaters were
used on the sampling probe and filter holder. Only one run of
105 minutes was obtained at Facility I because an adequate supply
of corn was not available to maintain longer operation of the corn
5-3
-------
cleaner. Process operation was normal during all the tests except
as reported below.
Very slight visible emissions were evident from the fabric
filter exhaust at Facility E, and several large particles were
caught in the test train. This indicated a leak in the fabric filter
during the test; therefore, data from test E are not considered valid.
The fourth of five test runs at Facility F was conducted when the
last portion of milo was being pulled from a storage bin and was
being "turned" (moved to another bin). Particulate matter concen-
trations in the fabric filter inlet increased from 0.23 grains per
dry standard cubic foot (gr/dscf) in previous test runs to 0.90 gr/dscf.
The .034 gr/scf measured at the fabric filter exhaust during the
fourth test run was over 100 times higher than the other runs. The
material caught in the sample train, unlike particulate matter from
grain that is normally encountered, contained a powdery material.
Apparently, the milo was contaminated; therefore, the results of the
fourth test run were not considered representative of normal
process operation.
No chemical or physical change takes place in the grain or
particulate matter as it proceeds through the elevator. Therefore,
fabric filter particulate emissions from one process should not vary
significantly from another. This assumption is verified by the
test data. The average particulate emissions concentration from
all facilities (excluding Facility E and run 4 at Facility F) is
.003 gr/dscf. i
5-4
-------
5.2 PARTICULATE EMISSION DATA - DRYERS
EPA attempted to measure partieulate emissions from two grain
dryers. The data collected, however, can only be used as a guide
in developing the standard dye to the numerous difficulties encountered
in the measurement technique. The Agency has concluded that methods
for measuring particulate emissions from grain dryers are not
available at this time,
Facility L» a rack dryer controlled with a screen filter with
150 micron openings (100 mesh), was tested by EPA, Corn was being
dried and the process was operating normally. Particulate emissions
of 0,05 Ib/ton were measured from this facility.1
Facility M, a column dryer controlled by a screen filter with
300 micron openings (58 mesh), was also tested by EPA. Corn was being
dried and the process was operating normally. Particulate emissions
of 0.18 Ib/ton of grain dried were measured from this facility.2
5,3 VISIBLE EMISSION/OPACITY DATA
Visible emission/opacity observations were taken at 11 elavators
covering both fabric filters and sources of fugitive emissions.
Appendix C describes the tested facilities 1n more detail.
Figure 5-2 summarizes the visible emission/opacity data for all the
fugitive particulate emission sources at grain elevators, except
barge and ship unloading equipment. This chart givei the average,
standard deviation, range, and positive 95 percent confidence level
of the six-minute opacity averages for each of these affected facilities,
The proposed opacity standards for these sources are based on the
positive 95 percent confidence level,
5-5
-------
Flqure 5-2. VISIBLE EMISSION/OPACITY DATA SUMMARY
FOR FUGITIVE PARTICULATE EMISSION SOURCES
AT GRAIN ELEVATORS (EXCLUDING BARGE
AND SHIP UNLOADING EQUIPMENT)
FACILITY
1. Truck Unloading
2. Rail car Unloading
3. Ira in Handling
4. Truck Loading
5. Rail car Loading
a. Boxcar
Loading
b. Hopper Car
Loading
7. Barge and Ship
Loadi ng
a. Topping off
b. General
, 3. ..Drying.?, a.,. ..Column
b. Rack
S
N
138
20
36
30
6
24
18
49
. ,126
5
IX MINUTE
*(*)
.02
0
0
A.I
3.7
0
5.7
3.4
.04
0
OPACITY
• s(%.)
.09
0
0
2.5
1.1
0
4.8
2.6
.15
0
AVERAGES
RANGE* (%)
NVE-1
ALL NVE
ALL NVE
1-10
3-5
NVE-0
NVE-1 7
NVE-9
NVE-1
NVE-0
+95%
LEVEL*(*1
0 (.2)
0
0
8(8.2)
6(5.5)
0
14(13.6)
8(7.6)
0(.25)
0
PROPOSED VISIBLE
EMISSION/OPACITY
STANDARDS
Q% Opacity
No Visible Emissions
0% Opacity
10% Opacity
01 Opacity
Q% Opacity
15% Opacity
10% Opacity
0% Opacity
01 Opacity
KEY:
N_= Number of 6 minute Averages
X= Average
S= STO Deviation
rtVE= Ho Visible Emissions
*ODaci"ty values have been rounded off to the nearest who la number. The
actual positive 95 percent confidence level is given in parentheses.
5-6
-------
The visible emission/opacity data are also summarized for each
affected facility in this section. Visible emission/opacity data
were gathered using tPA Reference Method 9, originally promulgated
in the FEDERAL REGISTER on December 23, 1971 (36 FR 24877) and revised
on itovember 12, 1974 (39 FR 39872), In obtaining visible emission
data for the fugitive sources of participate matter at grain elevators,
EPA made a distinction between zero percent opacity and no visible
emissions. No visible emissions means an inspector viewing a
source would see no visible emissions without the aid of instruments,
while zero percent opacity indicates visible emissions which are
not of a magnitude to record five percent opacity. Reference
Method.9 specifies that 24 observations be taken at 15-second
intervals and averaged over a six-minuti period. The individual
observations are recorded in 5 percent increments (0» 5, 10, etc.);
however, averaging 24 observations may result in a six-minute
average which is not a whole number. The six-minute average
is to be rounded off to the nearest whole number following the
standard rules of rounding (e.g. 0.49 would be rounded off to
0, 0.50 would be 1, 7.51 would be 8, etc.). This means that an
affected facility subject to a zero percent opacity standard could
have two of 24 observations at 5 percent opacity and the other 22
observations at 0 percent opacity and still be in compliance. The
six-minute average in this case would be 0.42 percent and would be
rounded off to 0 percent, the nearest whole number.
5-7
-------
5.3.1 Truck Unloading Stations
Facility N
Facility N is a truck unloading station located at a port
terminal elevator. The visible emission/opacity data from this
facility are summarized in Table 5-1. A total of 54 six-minute
opacity averages were taken which ranged from no visible emissions
to 1 (0.83) percent opacity. The truck unloading operation was operating
normally during the observation period. A total of 23 trucks of
various designs and sizes unloaded wheat during this period.
Facility A
Facility A is a truck unloading station located at an inland
terminal elevator. The visible emission/opacity data from this
facility are summarized in Table 5-2. A total of 84 six-minute
opacity averages were taken which ranged from no visible emissions
to 0 (0.21) percent opacity. The truck unloading operation was operating
normally during the observation period. A total of 51 trucks of
various designs and sizes unloaded corn and soybeans during this
period.
5,3.2 Rail car Unloading Stations
Facility C
Facility C is a rallcar unloading station at a port terminal
elevator. A total of 20 six-minute opacity averages were taken
of boxcar unloading operations. All observations were no visible
emissions. Table 5-3 summarizes the data obtained at this facility.
A total of nine boxcars were observed during normal unloading operations.
••'heat was being unloaded throughout the observation period.
5-8
-------
Table 5-1
FACILITY N3
Syramry of Visible Emission Data
for Tryck Unloading
Date: September 25, 1975
Type of Facility; Truck Unloading
Type of Discharge*. Fugitive Distance from Observer to
Discharge Point: 40 ft.
Location of Discharge: Shed Door Height of Observation Point: Ground-
20' x, 15' Level
Height of Point of Discharge: O1 to 20' Direction of Observer from
Discharge Point*. East
Description of Background: Sky and Trees
Description of Sky: Hazy to Blue
Wind Direction: North Wind Velocity; 5-10 ml/hr
Color of Plyme: Detached Plume: None
Interference of Steam Plume: None
Duration of Observation: 9/25/75 - 210 minutes
Summary of Data:
Run
1A
IB
1C
No. of 6-Minute
Averagts
20
15
19
No, of Averages Ran§e of
at N-V-E Averages
17 H-V-E to 1 (.83)
13 N-V-E to 0 1,42)
16 N-V-E to 0 (.21)
Average
Opacity (%)
0 (0,0?)
0 (o.03)
0 (0.01)
5-9
-------
Table 5-2
FACILITY A4
Summary of Visible Emission Data
for Truck Unloading
Date: September 29, 1975
Type of Facility: Truck Unloading
Type of Discharge: Fugitive
Location of Discharge: Shed Door
20' x 15'
Height of Point of Discharge: O1 to 20'
Description of Background: Grain Bin
Description of Sky: 251 - 75% cloudy
Distance from Observer to
Discharge Point: 25 ft.
Height of Observation Point: Ground,
Level
Direction of Observer from
Discharge Pointt West
Wind Direction: Southeast
Wind Velocity: 0-10 mi/hr
Color of Plume:
Detached Plume: None
Interference of Steam Plume: None
Duration of Observation: 504 minutes
Summary of Data:
Run
1A
IB
1C
No. of 6-Minute
Averages
»7
24
33
No. of
at
Averages
N-V-E
24
22
28
Range of
Averages
N-V-E to 0
N-V-E to 0
N-V-E to 0
,21
21
:li
Average
Opacity (%)
0
0
0
.008)
.009)
.006)
5-10
-------
Table 5-3
FACILITY C3
Summary of Visible Emission Data
for Boxcar Unloading
Date: September 23, 1975
Type of Facility: Boxcar Unloading
Type of Discharge: Fugitive
Location of Discharqe: Shed Door
20 ' x 15'
Height of Point of Discharge: 0' to 20'
Description of Background: Building
Description of Sky: Overcast
Distance from Observer to
Discharge Point: 20 ft.
Height of Observation Point: SroundU.
Level
Direction of Observer from
Discharge Point: East and West
Wind Direction: South-Southeast
Wind Velocity: 5-10 mi/hr
Color of Plume:
Detached Plume: None
Interference of Steam Plume: None
Duration of Observation: 120 minutes
Summary of Data:
Run
1A
IB
No. of 6 -Minute
Averages
10
10
Range of
Averages
All N-V-E
All N-V-E
5-11
-------
5.3.3 Barge and Ship Unloading Equipment
Facility D
Facility D is a barge unloading operation at a port terminal
elevator. Table 5-4 summarizes the fugitive emission data collected
at Facility D. Visible emissions ranged from 0 to 30 percent opacity.
Wheat and corn were being unloaded and the unloading operations
proceeded normally. These data were taken by an unqualified opacity
reader.
Facl11tyE
Facility E is a barge unloading operation at a port terminal
elevator. Tables 5-5 and 5-6 summarize the fugitive emission
data collected at Facility E. The six-minute opacity averages
ranged from 5 (4.8) to 67 (66.9) percent. Individual opacity readings
ranged from 0 to 100 percent. These data were taken by an unqualified
opacity reader. Normal barge unloading operations were maintained
while soybeans and corn were unloaded.
5.3.4 Grain Handling Operations
Facility 0
Facility 0 is a headhouse and exterior conveyor system (grain
handling operations) located at a port terminal elevator, wheat
was being unloaded, transferred, and cleaned within the headhouse
during the 216 minutes of observations. A total of 36 six-^minute
opacity averages were taken; all were no visible emissions. Normal
operation was maintained during the observation period. Table 5-7
summarizes the fugitive emission data collected at Facility 0.
5-12
-------
Table 5-4
FACILITY D5
Summary of Visible Emission Dita
for Barge Unloading*
Date: October 17, 1§72 and October 18, 1972
Type of facility: Grain Elevator Barge Unloading
Type of Discharge: Fugitive
Distance from Observer to Discharge Point: 40'
Location of Discharge: Marine Leg & Barge Height of Observation Point; 5'
Height of Point of Discharge: is1
Description of Background: N.A.
Direction of Observer from Discharge Point: N.A.
Description of Sky: Clear
Wind Direction:
Mind Velocity:
Color of Plume: Brown
Duration of Observation:
Detached Plume: No
At least four readings were made of fugitive emissions from the
process every^ hour and visible emissions ranged from 0 to 30
percent opacity.
N. A. - Not Available
NOTE: DATA TAKEN BY UNQUALIFIED READER-
*Taken during paniculate emission tests of fabric filter.
5-13
-------
Table 5-5
FACILITY £
6
Surmary of Visible Emission Data
for Barge Unloading*
Date: October 30, 1973
Type of Facility: Grain Elevator - Barge Unloading
Type of Discharge; Fugitive Distance from Observer to Discharge Point: 300'
Location of Discharge: Marine Leg and Barge Height of Observition Point: 10'
Height of Point of Discharge; 0 Direction of Observer from Discharge Point: North
Description of Background: Shipping Dock, Structural Concrete and Shadow$
Description of Sky; Clear
M1nd Direction: West
Color of PI wire: Brown
Duration of Observation: Fourty-elght minutes.
Kind Velocity; N.A.
Detached Plyme: No
SUMMARY OF SIX-MINUTE AVERAGE OPACITIES
Time
Opacity
Set Number
1
2
3
4
5
6
7
8
Start
11:16
11:22
11:28
11:34
11:40
11:46
11:62
11:S8
End
11:21
11:27
11:33
11:39
11:45
11:51
11:57
12:03
Sura
165
115
125
185
270
335
265
395
Average
7 j
§
5
J
11
,6.9)
Hi
5.2)
vL
ll.Z)
in;
17 (16,5)
Filter became plugged and shut off at 12:03
Readings ranged from 0 to 20 percent opacity.
Sketch Showirw How Opacity Varied With Time:
100
*Taken during particulate
emission tests of fabric
filter.
5 20
o 1/2 i
1/2 1
Time, hours
N.A. - Not
NOTE; DATA TAKEN BY UN§!f,UFIP.,RW£R
5-14
-------
Table 5-6
FACILITY E6
Summary of Visible Emission Data
for Barge Unloading*
Date: October 31, 1S73
Type of Facility: Grain Elevator - Barge Unloading
Type of Discharge: Fugitive Distance from Observer to Discharge Point: 300*
Location of Discharge; Marine Leg and Barge Height of Observation Point: 10'
Height of Point of Discharge: 0 Direction of Observer from Discharge Point: North
Description of Background; Shipping Dock, Structural Concrete and Shadows
Description of Sky: Partly Cloudy
Wind Direction: West Wind Velocity: N.A.
Color of Plume: Brown Detached Plume: No
Duration of Observation: Sixty minutes.
SUMMARY OF SIX-MINUTE AVERAGE OPACITIES
Time
Set Number
1
2
3
4
5
6
7
8
9
10
Start
10:29
10:35
10:41
10:47
10: S3
10:59
11:05
11:11
1:31
1:37
End
10:34
10:40
10:46
10:5Z
10:58
11:04
11:10
1:30
1:36
1:42
Opacity
Sum
545
72S
1180
770
9S5
1605
1510
1580
405
500
Average
23 (22.71
30 (30.2
53 (13.3:
32
• 40
67
63
66
if
32,1)
'39.8
66.9
62.9
S5.8
16,9
20.8
Readings ringed from 10 to 100 percent opacity.
Sie Sketch,Showing How Opacity Varied With.Time in Table 5-5.
N.A, - Not Available
NOTE: DATA TAKEN BY UNQUALIFIED READER
*Taken during participate emission tests of fabric filter.
5-15
-------
Table 5-7
FACILITY O3
Summary of Visible Emission Data
for Grain Handling
Date: September 23, 1975
Type of Facility: Grain Handling
Type of Discharge: Fugitive
Location of Discharge: Headhouse ind
Conveyor
Height of Point of Discharge: TOO1
Description of Background: Blue Sky
Description of Sky: Clear
Distance from Observer to
Discharge Point: 300 ft.
Height of Observation Point: Ground
Level
Direction of Observer from
Discharge Point: West
Wind Direction: South
Wind Velocity, 15-25 ffii/hr
Color of Plume:
Detached Plume: None
Interference of Steam Plume: ' None
Duration of Observation: 216 winutes
Summary of Data
Run
1A
IB
No. of 6 -Minute
Averages
18
18
Range of
Averages
All N-V-E
All N-V-E
5-16
-------
5.3.5 Truck loading Stations
Facility P
Facility P is a soybean meal truck loading operation at a
soybean processing plant. As explained in Chapter 4» there
are no well controlled whole grain truck loading facilities
presently in operation. EPA judged that meal is as
dusty as grain and is similar to grain; therefore* transfer
of technology is possible in this situation. The data gathered
at this facility were used to develop the proposed standard,
A total of 30 six-minute opacity averages were taken during normal
loading operations. Nine trucks were loaded with soybean meal
during the observation period, The range of six-minute opacity
averages was 1 (0,8) to 10 (10,4) percent. Table 5-8 summarizes
the fygitlvi emfsiion data obtained it this facility.
5.3.6 Railroad Boxcar Loading Stations
Fad!ity Q
Facility Q 1s a railroad boxcar loading operation at an inland
terminal elevator. This facility- 1s the'best controlled boxcar
loading operation In the field. However, the facility could be
better maintained and a higher ventilation rate could be used.
Table 5-9 summarizes the data obtained at this facility. A total
of § six-minute opacity averages-wera taken during normal loading
0fPNrt1efil-, Foyp hoxiin weft lotted with larley lurin§ the
observation period. The six-minute opacity aVefages
from 3 {2.5} to 5 (5.2) percent. •• The proposed standard 1s based
on a transfer of technology from railroad hopper car loading
as explained in Chapter 8.
5-17
-------
Table 5-8
FACILITY P7
Summary of Visible Emission Data
for Truck Loading
Date: February 3, 1976
Type of Facility: Truck Loading
Type of Discharge: Fugitive
Location of Discharge: Shed Door
20' x 15'
Height of Point of Discharge: 0' to 2
-------
Table 5-9
FACILITY Q7
Summary of Visible Emission Data
for Boxcar Loading
Date; February 4, 1976
Type of Facility: Boxcar Loading
Type of Discharge: Fugitive
Location of Discharge: Shed Door
20' x IS1
Height of Point of Discharge: 0' to 20'
Description of Background: Building
Description of Sky: Clear
Distance from Observer to
Discharge Point: 25 ft.
Height of Observation Point:Ground
Level
Direction of Observer from
Discharge Point: West
Wind Direction: North
Wind Velocity: 0-5 mi/hr
Color of Plume: Tan
Detached Plume: None
Interference of Steam Plume: None
Duration of Observation: 36 minutes
Summary of Data:
Run
1A
18
No. of 6-Hinute
Averages
3
3
Range of
Averages
Average
Opacity (%}
3 (2.9) to 5 (5.2) 4 (3.8)
3 (2.5) to i (4.8) 4 (3.6)
5-19
-------
5.3.7 Railroad Hopper Car Loading Stations
Facility^
Facility R is a railroad hopper car loading station at an inland
terminal elevator. A total of 24 six-minute opacity averages
were taken during normal loading operations of corn into seven hopper
cars. The range of six-minute averages was no visible emissions
to zero percent opacity. Note: There was no wind throughout the
observation period. This was considered abnormal and was taken
into account in developing the proposed standard. Table 5-10
summarizes the fugitive visible emission data from Facility R.
5.3.8 Barge and Ship Loading Stations
Facility J
Facility J is a ship loading station at a port terminal
elevator. A total of 67 six-minute opacity averages were taken
during the loading of wheat into two ships. Of the 67 six-
minute averages, 18 were during the "topping off" operation and
49 were during the general loading operation. Load-out proceeded
normally for the duration of the observation period. Table 5-11
summarizes the fugitive visible emission data gathered at Facility J.
5.3.9 Grain Dryers
Facility S
Facility S is a 2500 bushel/hr cylindrically shaped column
grain dryer located at a country elevator. The perforation plate
diameters were a series of sizes from top to bottom; .078 inch,
.0625 inch and .056 inch. A total of 18 six-minute opacity averages
were taken at this facility. Four of the six-minute averages
5-20
-------
Table 5-10
FACILITY R8
Suimiary of Visible Emission Data
for Hopper Car Loading
Date: February 24, 1976
Type of Facility: Hopper Car Loading
Type of Discharge: Fugitive
Location of Discharge: Shed Door
20 ' x 15'
Height of Point of Discharge: 0' to 2Q-1
Description of Background: Building
Description of Sky: Clear
Distance from Observer to
Discharge Point: 25 ft.
Height of Observation Point: Ground
Level
Direction of Observer from
Discharge Point: East
Wind Direction: Calm
Wind Velocity: 0 mi/hr
Color of Plume:
Detached Plume: None
Interference of Steam Plume: None
Duration of Observation: 144 minutes
Summary of Data:
Run
1A
IB
No. of 6-M1nute
Averages
12
12
No, of Averages
at N-V-E
10
11
Range of
Averages
N-V-E to 0
N-V-E to 0
5-21
-------
Table 5-11
FACILITY J3
Summary of Visible Emission Data
for Ship Loading
Date; September 23 and 24, 1975
Type of Facility: Ship Loading
Type of Discharge: Fupitive
Location of Discharge: Ship Hold
Height of Point of Discharge:
Description of Background: Ship Hold
Description of Sky: Overcast
Distance from Observer to
Discharge Point: 15;ft,
Height of observation Point: Deck
Level
Direction of Observer from
Discharge Point: Southeast to West
Wind Direction: South-Southeast
Wind Velocity: 10-25 mi/hr
Color of Plume:
Detached Plume: N0ne
Interference of Steam Plurae: None
Duration of Observation: 402 minutes
Summary of Data:
No. of 6-Wnute
Ryn Averages
Topplnq-Off
Seneral
1A
IB
2A
2B
9
9
24
25
No. of Averages ' Range of Avenge
at N-V-E Averages Opacity (%)
0
1
8
5
1 (.19) to 13 (12.9)
H-V-E to 17 (17.3)
N-V-E to 8 (7,5)
N-V-E to 9 (8.5)
5,0
6 (6.4)
3 (3.3)
4 (3.5)
5-22
-------
are above the proposed standard; however, these averages were
deemed invalid due to steam Interference. Excluding these four
averages, the range of the 14 six-minute opacity averages is
zero to 0 (0.46) percent opacity. Table 5-1E suwariies the data
obtained at this facility. Normal operation of the dryer
was maintained during the observation period. Corn was being
dried at the actual operating rate of 2200 bushel/hr.
Facility T.
Facility T is a 3500 bushel/hr cylindrically shaped column
grain dryer located at a country elevator. The perforation plate
diameters were of two different sizes. The top .half has diameters
of .0625 inch and the lower half has diameters-of .050 inch.
A total of 40 six-minute opacity averages were taken at Facility T.
The range of averages is no visible emissions to 1 (0.83) percent
opacity. Corn was being dried and normal operation was maintained
during the observation period. Table 5-13 summarizes the visible
emission data collected at this facility.
Facility U
Facility U is a column grain dryer rated at 4000 bushels/hr.
It is rectangular in shape and exhausts through one side of the
(5
structure. The perforation plate diameters are .084 inch and are
uniform over the height of the column. A total of 39 six-minute opacity
averages, all zero percent opacity, were taken at this facility.
Normal operation was.maintained while corn was being dried. Table 5-14
summarizes the visible emission data from this facility.
5-23
-------
Table 5-12
FACILITY S9
Summary of Visible Emission Data
for Column Dryer
Date: October 15, 1975
Type of Facility: Column Dryer-
Type of Discharge: Fugitive
Location of Discharge: Dryer {Cyl iriuer)
Distance from Observer to
Discharge Point: 80 ft.
Height of Observation Point:
Height of Point of Discharge: S' to 40* Direction of Observer from
Discharge Point: East
Description of Background: Sky
Description of Sky: Overcast
Wind Direction: West
Wind Velocity: 5-10 mi/hr
Color of Plume: White
Detached Plume: 20'
Interference of Steam Plume: Yes
Duration of Observation: 108 minutes
Summary of Data:
Run
1A
IB
No. of 6-Hinute
Averages^ _^_
&
8
Range of
Averages
Average
Opacity' (%)
0 to 0
0 to 0
(.42) 0 (0.18
(.46) 0 (0.17
5-24
-------
Table 5-13
FACILITY T9
Summary of Visible Emission Data
for Column Dryer
Date: October 15, 1975
Type of Facility: Column Dryer
Type of Discharge: Fugitive
Location of Discharge: Dryer (Cylinder)
Height of Point of .Discharge:. 4! to TO1
Description of Background: Blue Sky
Distance from Observer to
Discharge Point: 100 ft,
Height of Observation Point: Ground
Level
Direction of Observer from
Discharge Point: Southeast
Description of Sky: Clear
Wind Direction: West
Wind Velocity: 10-15 mi/hr
Color of Plume:
Detached Plume: None
Interference of Steam Plume: None
Duration of Observation: 240 minutes
Summary of Data:
Run
1A
IB
No. of 6-Minute
Averages
20
20
No, of Averages
at N-V-E
5
0
Range of
Averages
N-V-E to 1 (.83)
0 to 1.0
Averaqe
Opacity" (X)
0 CO. 07}
• 0 (0.07)
5-25
-------
Table 5-14
FACILITY U9
Summary of Visible Emission Data
for Column Dryer
Date: October 16, 1975
Type of Facility: Column Dryer
Type of Discharge: Fugitive
Location of Discharge: Dryer (Side)
Height of Pofnt of Discharge: 20' to-60'
Description of Background: Blue Sky
Description of Sky: Clear
Distance from Observer to
Discharge Point: 60 ft.
Height of Observation Point: Rround
Level
Direction of Observer from
Discharge Point: East
Wind Direction: West
Wind Velocity: o-5 mi/hr
Color of Plume:
Detached Plume:
Interference of Steam Plume:
Duration of Observation: 234 minutes
Summary of Data:
Run
1A
IB
No, of 6-Minute
Averages
20
19
Range of
Averages
All 0
All 0
5-26
-------
Facility V
Facility V is a 1000 bushel/hr column grain dryer. It is
similar in design to Facility U and has the same size perforation
diameters. A total of 28 six-minyte opacity averages were taken
at this facility and all wtff zero percent opacity. Corn was beincj
dried during the observation period and normal drying operation
was maintained. Table 5-15 summarizes the visible emission data
from this facility.
Facility H
Facility W is a rack grain dryer located at a country elevator.
No air pollution control devices are used on this grain dryer.
A total of 6 six-minute opacity averages were obtained. The range
of opacity averages is 7 (7,1) to 13 (12,9) percent. Normal operation was
maintained while corn was being dried. Table 5-16 summarizes
the visible emission data collected at this facility.
Facility X
Facility X Is a 2500 bushel/hr rack grain dryer located at a
soybean processing plant. This dryer was equipped with a 50 mesh
vacuum-cleaned screen filter through which all exhaust gases exited.
A total of 5 six-minute opacity averages were obtained. All observa-
tions, a total of 120 taken at 15-second intervals, were no visible
emissions except for one reading of 01 opacity. Normal drying operation
was maintained while soybeans were being dried. Table 5-17 summarizes
the visible emission data from this facility. The wind velocity and
direction were not recorded because the observer was located between
two tall structures. This would negate any effects from wind interference.
5-27
-------
Table 5- 15
FACILITY V9
Summary of Visible Emission Data
for Column Dryer
Date: October 16, 1975
Type of Facility: Column Dryer
Type of Discharge: Fugitive
Location of Discharge: Dryer (Side)
Distance from Observer to
Discharge Point: 75 ft.
Height of Observation Point: 5'
Height of Point of Discharge: 10' to 30' Direction of Observer from
Discharge Point: NE
Description of Background: Building
Description of Sky: Clear
Wind Direction: West
Color of Plume:
Interference of Steam Plume: None
Duration of Observation: 168 minutes
Summary of Data:
Wind Velocity: 0-i mi/hr
Detached Plume:
Run
1A
IB
No. of 6-Minute
Averages
14
14
Range of
Averages
All 0
All 0
5-28
-------
Table 5-16
FACILITY Ws
Summary of Visible Emission Data
for Rack Dryer
Date: October 16, 1975
Type of Facility: Rack Dryer
Type of Discharge: Fugitive
Location of Discharge: Dryer (Side)
Height of Point of Discharge: 10' to §0'
Description of Background: Blue Sky
Description of Sky: Clear
Distance from Observer to
Discharge Point: 20 ft.
Height of Observation Point: Ground
Level
Direction of Observer from
Discharge Point: North
Wind Direction; North
Wind Velocity: 5-12 roi/hr
Color of Plume:
Detached Plume:
Interference of Steam Plume;
Duration of Observation: 48 minutes
Summary of Data
Run
1A
No. of 6-Minute
Averages
Range of
Averages
7 (7.1) to 13 (12,9)
Average
Opacity (I)
10 (10,1)
5_29
-------
Table 5-17
FACILITY X11
Summary of Visible Emission Data
for Rack Dryer
Date: August 25, 1976
Type of Facility: Rack Dryer
Type of Discharge: Fugitive
(50 mesh screen)
Location of Discharge: Dryer (Side)
Height of Point of Discharge: 0' to 10'
Description of Background: Adjacent Building
Wall
Description of Sky: Partly Cloudy
Wind Direction: Not Recorded
Color of Plume: None
Interference of Steam Plume: No
Duration of Observation: 31 minutes
Distance from Observer to
Discharge Point: 20 ft.
Height of Observation Point:
Ground-Level
Direction of Observer from
Discharge Point: North
Wind Velocity: Not Recorded
Detached Plume:
Summary of Data:
Run
1A
No, of 6-Minute
Averages
No. of Averages
at N-V-E
Range of
Averages
N-V-E to 0
5-30
-------
The data recorded in Table 5-18 were taken within 30 minutes of these
data and there was no exterior wind at that tine.
Facility Y
Facility Y is a 2500 bushel/hr column orain dryer located at a
soybean processing plant. It is rectangular in design and has perforation
plate hole diameters of ,08 inch. Soybeans were being dried during
the observation period and normal dryina operation was maintained.
A total of 5 six-minute opacity averages were taken at this facility
and all readings were no visible emissions. Table 5-18 sunmarizes the
visible emission data collected at this facility.
5.3.10 Air Pollution Control Devices
Facility A
Facility A is, a truck unloading station, equipped with fabric
filter control, at an inland terminal elevator. The exhaust from
tht fabric filter was observed during normal unloading operations.
Corn and soybeans were being unloaded. A total of 56 six-minute
opacity averages, all no ¥isible emissions, were taken at this
facility. A summary of the visible emission data from this
facility is found in Table 5-19.
Facility B
Facility B is a tryck unloading station, equipped with fabric
filter control, at a soybean processing plant. Obviously, soybeans
were being unloaded during the observation period of tht fabric
filter exhaust. A total of 21 trucks were unloaded during the
observation period and normal operations were maintained, forty
six-minute opacity averages were taken and all were no visible
emissions. Table 5-20 summarizes the visible emission data taken
at this facility.
5r3]
-------
Table 5-18
FACILITY ¥
11
Summary of Visible Emission
for Column Dryer
Date: Aygyst 25, 1976
Type of facility: Column Dryer
Type of Discharge: Fugitive
Location of Discharge: Dryer (Side)
Height of Point of Discharge: 25' to §0'
Description of Background: Column Dryer
Wall
Description of Sky: Partly Cloudy
Wind Direction: Calm
Color of Plume: None
Interference of Plume: No
Duration of Observation: 31 minutes
Data
Discharge from Observer to
Discharge Point: iO ft.
Height of Observation Point:
Ground-Level
Direction of Observer from
Discharge Point: NE
Wind Velocity: 0 mi/hr
Detached Plume:
Summary of Data:
Run
1A
No, of 6-Minute
Averages
Range of
Averages
All N-V-E
5-32
-------
Table M9
FACILITY A4
Summary of Visible Emission Data
for Fabric Filter
Date: September 29, 1975
Type of Facility: Fabric Filter (Truck Unloading)
Type of Discharge: Stack
Location of Discharge: On Roof
Height of Point of Discharge: 20'
Description of Background: Sky & Green Duct
Description of Sky: Partly Cloudy/Sunny
Wind Direction: South
Color of Plume:
Interference of Steam Plume:
Duration of Observation:
Sunmary of Data
Distance from Observer to
Discharge Point: TOO ft.
Height of Observation Point: Ground
Level
Direction of Observer from
Discharge Point: $E
Wind Velocity: 10-15 mi/hr
Detached Plume: None
minutes
^un
1A
18
No. of 6-Minute
Averages
28
28
Range of
Averages
All N-V-E
All N-V-E
S-33
-------
Table 5-20
FACILITY B10
Summary o'f Visible Emission Data
for Fabric Filter
Date; November 21, 1975
Type of Facility: Fabric Filter (Truck Unloading)
Typt of Discharge: Stack
Location of Discharge: siae or DUI iuuu»
Height of Point of Discharge;
Description of Background: Dark Wall
Description of Sky: Overcast
Distance from Observer to
Discharge Point: 20 ft,
Height of Observation Point: Sround
Level
Direction of Observer from
Discharge Point: East
Wind Direction: North
Wind Velocity: 15*35'ml/hr
Color of Plume:
Detached Flume: None
Interference of Steam Plume:
Duration of Observation:
Summary of Data:
Run
1A
IB
No. of 6 -Minute
Averages
20
20
Range of
Averages
fill N-V-E
All N-V-E
5-34
-------
REFERENCES
1. Ward, Thomas, "Emission Test Report," EHB Test No. 73-GRN-4,
the test was conducted in April 1973.
2. Gerstle, Richard and DeWees, William, "Emission Test Report,"
EMB Test No. 74-GRN-9, prepared for EPA by PEDCo Environmental,
Contract No. 68-02-0237, Task 29, the test was conducted
November 1973.
3. Swanson, Neil R., "Trip Report - Carglll Incorporated;
Continental Grain Company," observations conducted
September 22-25, 1975.
4, Swanson, Neil R., "Trip Report - Carglll, Inc.; Pillsbury Co.,"
observations conducted September 29-30, 1975.
5. Ward, Thomas, "Emission Test Report" for Facility 0, EPA
Test No. 73-GRN-2, prepared for EPA by York Research Corporation,
November 1972.
6. Pfaff, Roger 0., "Emission Test Report" for Facility E,
EPA Test No. 74-GRN-7, January 1974.
7. Roy, Sims L., Jr., "Report of Trip to Obtain Opacity Readings
at Truck Loading Operation in Des Nolnes, Iowa, and Boxcar
Loading Operation 1n Minneapolis, Minnesota, on February 2^4,
1976.
8. Swanson, Neil R., "Trip Report: Carglll, Inc., Denver -
Railroad Hopper Car Loading Operation," observations conducted
February 24, 1976.
9. Swanson, Neil R., "Trip Report - Grain Dryer Facilities in
Illinois," observations conducted October 14-16, 1975.
10. Swanson, Nell R.s "Trip Report - Cargjll Inc., Fayetteville,
N.C.," observations conducted November 21, 1975.
11. Swanson, Neil R., "Trip Report - Cargill Inc., Fayettevl11e,
N.C., grain dryer observations conducted August 25, 1976.
5-35
-------
6. IMPACT
6,1 CHARACTERIZATION OF THE INDUSTRY
6.1.1 .Introduction
The primary functions of the grain elevator industry are to store,
handle, and merchandise grain. In addition to transshipment, the
handling function includes grading, cleaning, blending, and drying,
Grain is harvested only during short periods within the year, but
marketing and consumption is a continuous process. The implication of
this is that some grain elevators engage primarily In grain movement from
the farm to the market', dther elevators engage primarily in storage. The
emphasis of the development of the standards is on the handling and
distribution of grain.
In this section, information is provided on the character of the
firms engaged in the industry, the size and distribution of elevators,
grain prices, the price mechanism, and trends. The industry analysis
in this chapter is divided into two categories: (1) firms who handle
and move grain as their primary business (grain elevators), and (2)
grain processors with handling and storage facilities.
6.1.2 JraJILJleyatgrs
6.1.2,1 Firm .Characteristics
In terms of ownership concentration, the grain elevator industry
is characterized by many single plant firms. This is prevalent especially
imong country elevators (see Table 6-1). Some 64 percent of the elevators
in existence during 1967 were owned by firms with a single, or perhaps
two, elevators. These same elevators were responsible for handling about
71 percent of the grain in terms of sales value. These firms also
6-1
-------
Tible 6-1. CONCENTRATION OF OWNERSHIP OF COLNTRY
Single and Multi-Unit firms - 1967
Firms with
1-2 Elevators
3-5 Elevators
6-25 Elevators
26 Elevators or more
Total
i of firms
4,033
234
118
24
4,409
# of elevators
4,160
59?
751
969
6,477
% of total
elevators
64,2
9.2
11,6
15.0
100.0
Sales value
($1 ,000}
$3,985,180
485,002
525,840
594,686
$5,590,708
% of sales
value
71.3
8,7
9.4
10.6
100.0
I
IS3
Source; U. S. Department of Commerce, U. S. Census of Bysiness, 1967.
-------
traditionally hire relatively few people. Of the grain elevator businesses
included in SIC5053, 35-38 percent had 1-3 employees; 33-34 percent had
4-7 employees; 22-24 percent had 8-19 employees; and 5-6 percent had
20-49 employees.1 These employment statistics and the low concentration
in ownership are indicative of small businesses.
The low concentration of ownership engenders strong competition in
the industry. Most farmers in the primary grain production areas tradition-
ally have been within a short distance from several elevators owned by
different firms. Many elevators were constructed during a time when
farmers used obsolete forms of transportation, which dictated that these
elevators be built at a short distance from the farm. Now, farmers have
larger and more efficient conveyances to move grain to the elevators with
the consequence that competition is stronger among elevators.
Elevator operators are sensitive to cost increases that amount
to only a fraction of a cent per bushel handled. This observation is
an important consideration in the impact analysis of air pollution con-
trols in Section 6.3.
The four basic types of grain elevator operators are: (1) grain exporters,
(2) food processors and feed manufacturers, (3) farm cooperatives, and (4)
independents. Grain exporters who are merchandisers of grain for
retailing in world markets are generally associated with ownership of
inland and port terminals. Their motivation in this regard has been
control of grain procurement and quality. Food processors, unlike exporters,
are not merchandizers. Rather, they require elevators for the purpose of
control of inventory and quality needs for processing. Both exporters
6-3
-------
and food processors have ample capital availability, good management, and
generally little difficulty in passing forward increased costs.
Farmer cooperatives are important in grain marketing in those areas
remote from the consumer markets or port terminals. These cooperatives,
owned by farmer members/shareholders, provide storing, handling, and
merchandising services for the farmers. Cooperatives, not only individu-
ally are becoming larger organizations, but also are increasing their
ownership of country and terminals elevators. In 1963, cooperatives
owned 38 percent of the country elevators and 20 percent of terminals.
By 1980, they are expected to own 60 percent of the country elevators
and 25 percent of the terminals. This growth pattern is occurring at
the expense of the independents, who are very small businesses. The
\
latter generally find difficulty in acquiring capital and .frequently are
reluctant or unable to modernize their facilities.
The significance of the growing importance of farm cooperatives is
the one factor responsible for the anticipated trends in elevator con-
struction. These organizations will be making important decisions in
modernizing elevators to take advantage of changes in transportation modes
and costs, namely multiple-car train discounts. The cooperatives will be
upgrading elevators where unit-train service can be provided, shutting
down elevators where rail service will be discontinued, and trucking
grain to modernized plants.
The impact of this trend will be attrition of small or uneconomical
country elevators clustered in areas where short distances separate them.
6-4
-------
Increased costs, as a result of pollution control on necessary modern-
izations, may force the closure or preclude operation of such elevators,
6.1.2.2 Plant Size and Distribution
The Department of Agriculture lists the number and size of grain
warehouses* which have signed contracts under the Uniform Grain Storage
?
Agreement for permission to store government-owned grain. These data
indicate that some 6700 country warehouses (country elevators) with an
average storage capacity of 447,000 bushels were operative in 1974; and
some 450 terminals, had an average storage capacity of 3,800,000 bushels.
A size distribution of elevators for 12 North Central States3 shows
that 42 percent of country elevators had less than 100,000 bushel storage
capacity; 64 percent less than 200,000 bushel storage; and 84 percent
less than 400,000 bushel storage capacity. Furthermore, 16 percent of
the elevators with greater than 400,000" bushel storage capacity accounted for
54 percent of aggregated storage capacity.
6.1.2.3 Demand for,.U. S_. Grain
The 1950's and the early 1960's were characterized by surplus pro-
duction of grain with large stockpiling of surplus grain stocks. As
shown in Table 6-2» a long-term trend toward balance between supply and
demand has occurred since 1961. This is reflected in the gradual decline
of carry-in stocks. A surge in foreign demand during the 1970's has
been an important factor fn this trend.
A gradual increase in foreign and domestic consumption is expected
through 1981. These data indicate that there will be very little demand
for new storage capacity. This is shown by.the projected 2,312 million
6-5
-------
Table 6-2. DOMESTIC CONSUMPTION, EXPORTS, PRODUCTION,
AND CARRY-IN STOCKS OF MAJOR U.S. GRAINS3
Crop Year
1960-61
1961-62
1962-63
1963-64
1964-65
1965-66
1966-67
1967-68
1968-69
1969-70
1970-71
1971-72
1972-73
1973-74
1974-75
1980-81
Domestic
Consumption
6,392
6,526
6,407
-6,277
6,256
6,902
6,873
6,919
7,301
7,745
7,692
8,094
8,296
8,243L
8,658b
9,555C
Exports Production
- iTllion bushels -
1,357
1,593
1,550
1,837
1,825
2,293
1,935
2,008
1,632
1,936
2,047
2.183
3,354
3,452u
3,005b
3,200°
8,173
7,538
7,505
7,994
7,392
8,440
8,484
9,398
' 9,432
9,639
8,891
10,895
10,531
11,190
9,521
12.755C
Carry- In
Stocks
4,222
4,691
4,144
3,723
3,636
2,975
2,268
2,021
2,609
3,194
3,166
2,341
3,003
1,916
1,363
2,312C
Wheat, corn, soybeans, grain sorghum, oats, barley, rye, rice.
b USDA Estimates.
c Arthur D. Little, Inc. Estimates.
Source: U. S. Department of Agriculture and Arthur D. Little, Inc. Estimates
6-6
-------
bushel estimate for carry-In stocks.4 Production increase from 9,521
million bushels in 1974-75 to some 12,753 million bushels in 1§81 indicates
that the grain handling industry will need to continue handling large
quantities of grain.
The level of on-farm storage capacity directly affects the demand
for commercial elevator storage, On-farm storage capacity is unknown}
however, the Department of Agricultural Statistical Reporting Service
indicates a growing trend of on-farm storage of grain.
6.1.2.4 Prices and,.Price Setting
Srain prices which are the basis for setting cash and future con-
tracts are posted daily for the major commodity markets (Chicago,
Minneapolis, and Kansas City), where the greatest bulk of grain traffic
converges at large terminal facilities. These prices are what exporters
and processors pay to grain merchants in these terminal market cities.
To these prices are added such costs as ocean freight, insurance, addi-
tional storage fees, and handling costs that ire incidental to the
exporters and processors.
The cash (market) price, exclusive of incidental charges, paid by
an exporter or processor at the terminal is then shared with the farmer,
country elevator and terminal operators, and shippers (railroads or
other transportation companies). Each elevator operator subtracts from
the price paid by a terminal or port, his shipping costs of forward
delivery to the terminal or port, his own costs of storing and handling,
and his operating margin before he presents a negotiable price to the
farmer or merchandiser closer to the production area. The farmer either
6-7
-------
accepts this price on any given day or waits a few days or weeks for a
better price. In any event, the farmer competing with many grain producers
of a perishable conmodity must be a price taker.
Although grain prices fluctuate continuously, grain elevators
protect their cost structure and profit margin by offsetting any cash
purchase with a forward sale in the future markets. Cash and future
prices move together in tandem, which enable elevator operators to
handle the risk of fluctuating market prices,
Any elevator operator; of course, is affected by competing elevator
operators, with regard to his own and his competitors costs, and trans-
portation differences. All elevator operators compete in acceptance of
the terminal market price established in the major conmodity.centers.
Any cost increases incidental to an individual elevator are included in
his cost structure and are reflected in a lower negotiation prfce to
the farmer.
The fanner has the choice of accepting, waiting out for a higher
market price, or selling to a competitive elevator. The outcome for this
elevator operator depends on the presence of proximate elevators. If
the farmer does not absorb these cost increases which are reflected in a
lower price for his product, the elevator operator has to absorb these
costs from his profit margin. In summary, this is the price determination
mechanism used in analyzing the impact of incremental control costs incurred
with the establishing of new source performance standards.
In the economic analysis of elevators, grain prices are assumed to
have no influence on establishing profit margins and handling increased
control costs. As mentioned earlier with regard to hedging via futures,
6-8
-------
the market prices of grain are not important 1n determining revenues to
the operation. The elevator operator negotiates a price on a cents-per-
bushel basis, which takes into account a margin for his expenses and some
profits. Although this supposition gives the impression of a constant
operating margin on a cents-per-bushel basis, the elevator operator still
is subject to volume changes in his total operation because of fixed
costs for depreciation, interests, taxes, and so forth.
Another area where grain prices would be important is in the inventory
valuation on balance sheets. Again consistent with the discussion above,
total fixed assets in the discussion on capital availability for pollution
controls excludes the value of grain inventories,
6,1.2.5 Determinants of New Construction
The most important factors of change occurring within the grain
handling industry have come from the transportition industry. Lower rail-
road rates for multi-car units and abandonment of railroad branch lines
are forcing the grain handling industry to shut down inefficient elevators
and modernize existing elevators on viable rail lines.
In order to increase their competitiveness, railroads began to offer
discount rates in 1970 for shipping in units of up to 100 cars. These
unit-trains, so the railroad industry thought, were to capture the
efficiencies of faster turnaround times and to reduce delays in loading,
switching, and unloading cars. Furthermore, the railroad industry encour-
aged the use of jumbo hopper cars rather than the boxcars for the trans-
port of grain. A jumbo hopper can can haul 3500 bushels of grain as
opposed to 2000 bushels for.the typical 40-foot box car.
6-9
-------
The savings In multi-car train rites over single car rates varies
according to the distance between gathering and final unloading points,
the size of train, and usage requirements set forth by the particular
railroad company. On the latter score, some grain shippers would have
to guarantee the use of the train for 5 or more consecutive trips; on
thi other hand, a shipper may request a multi-car train on an occasional
basis.
To this point in time, the availability of multi-car rates has been
mostly in areas serving corn sncl soybean production. However* some
of the major grain exporters believe that similar rates will eventually
be offered by the railroad companies in the wheat production areas.
The impact of the changes in thi transportation system upon thi
grain elevator industry plus the increased demand for grain will produce
significant changes for the grain elevator industry. New distribution
systems will be created. These will include the construction of small
grain gathering inland terminals in the production areas shipping to new
port terminals. These small inland terminals will either be brand new
types of terminals which specialize in high volume grain handling with
minimum storage or modernized country elevators rebuilt with greater leg
capacity and some increased storage.
In addition, distribution systems presently serving existing port
terminals are expected to be overhauled to accommodate transportation
savings and handle greater output. In many remote areas, grain elevators my be
abandoned because of the loss of railroad branch lines, In these areas,
grain will have to be hauled to terminals by large trucks (diesel tractor-
6-10
-------
trailer). As far as new country elevators, few are expected to be
built. However, in some cases some new elevators may have to be built
to replace facilities destroyed by fire, explosion, or sane similar
catastrophe.
Estimates of new and reconstructed elevators have been made which
reflect these trends as just discussed. Table 6-3 shows the estimated
number of elevators in 1974 and 1n 1980. The trends 1n the table
show emphasis on the construction of high throughput elevators, those
having fast loading capability to accommodate multi-car trains. The
critical assumptions underlying these estimates are as follows:
(1) the level of U, S. grain exports will fluctuate moderately
around 3.2 billion bushels per year.
(2) multi-car railroad rate discounts will be offered for all
major grain producing areas in the United States.
(3) some 70 percent of the grain shipped for export will be handled
by high throughput terminals because the greatest transportation
savings appears to be in the long-haul, 100 car unlt:-
trains.
(4) only about 20 percent of the grain shipped for domestic consump-
tion will be handled by high throughput elevators,
(5) by 1980, a significant number of branch rail lines will be
abandoned, thereby interrupting rail service for many country
elevators and resulting in some shut-downs (an attrition rate of
about 3.5 percent for traditional country elevators and 2.5 per-
cent for traditional inland terminals).
6-n
-------
Table 6-3. ESTIMATED CHANGE IN THE U.S. GRAIN ELEVATOR
INDUSTRY STRUCTURE, 1975-1981 WITHOUT
NEW SOURCE PEHFORHUNCE STANDARDS
Type elevator
Traditional country
Upgraded country (25 car)
Upgraded country (50 - 100 car)
High throughput terminals
Traditional inland terminals
Traditional port terminals
Total s
Estimated number of elevators
1974
6480
90
60
45
390
65
7130
1980
4635
305
200
150
335
70
5695
Change
-1845
+215
+140
+105
-26
+5
-1406
6-12
-------
A significant portion of the grain, particularly corn, handled by
elevators 1s dried artificially. Most artificial drying of corn takes
place at the farm or at the first recipient elevator. However, occasionally
some "wet" grain is shipped to terminals where It is dried, particularly
during peak harvest when country elevators may be operating at their
dryer capacity.
The estimates for new dryers are based :on the following assumptions:
(1) most of the growth in dryer capacity has already occurred up to
this point in time.
(2) no new breakthrough in grain drying technology will occur through
1980.
(3) a replacement rate of about 5 percent annually of the current dryer
capacity will be used {based on average life of 20 years).
The estimates of new elevator and dryer construction are shown in
Table 6-11, Section 6,3.2.
6-13
-------
6,1.3 Grain Processors
6.1.3,1 Introduction
In the previous section, the linkage of food processors to ownership
of elevators was briefly touched upon. These processors have grain handling
facilities primarily for receiving and storage of grain intended for their
own mill needs. There are basically five types of food processors of
interest here:
0) wheat mills who produce wheat flour
(2) dry corn mills who produce corn flour
,{3) rice mills who clean and dehull rice and
produce whole grain rice
(4) wet corn mills who produce primarily corn starch
{5} soybean processors who produce soybean as
a major ingredient for animal feed and soybean
oil.
The discussion on grain prices and pricing in Section 6.1.2 would have
some application here. Grain processors generally buy grain on the
basis of world market prices in the manner as exporters. In
terms of managing increased costs for pollution control, these firms would
be expected to attempt to pass forward some or all of these cost increases
to consumers of the products—to the extent allowed by competing processors.
Grain prices assumed for the various model plants in calculating
Q
sales revenues and impact of controls are as stated in Tablt 6-4. These
grain prices are assumed to be the average prices for the 1975-1980
period.
6-14
-------
Table 6-4. GRAIN PRICES USED IN MODEL PLANT ANALYSIS
Grain
Soybeans
Wheat
Corn
Rice
Price, $
5
3
2
4
per taste!
,40
,45
.40
.73
This section explores the Industry characteristics, plant
size, consumer demand for products, and growth potential for each
grain processor type.
6,1.3,2 Soybean Processors
The soybean processing industry is characterized as having a
trend toward fewer plants, yet larger output and employment as a whole.
From 1963 to 1972, the number of plants has declined from 102 to 94, em-
ployment has increased from 6500 to 9000 employees (salaried and waged),
and value added (which does not reflect grain price) has increased from
$152 million to million.9
With regard to size profile, most of the production appears to be
concentrated in plants generating about $30 million in sales revenues.
Table 6-5 shows the size profile of plants in terms of employees and value
of shipments for 1ii7.
6-15
-------
Table §-5 . SIZE PROFILE OF SOYBEAI MILLING PLANTS
Establishment size,
196? employees
1-4
5 _ 9
10 - 19
20 - 49
50 - 99
100 - 249
250 - 499
> 500
TOTAL
Number of
establishments
13
5
6
24
31
16
6
1
102
Approximate number
of employees,
by sector
< 50
< 50
100
900
2200
2200
2700
•N.A. .
8000
Value of shipments,
trillion dollars
3.0
3.2
27.7
346.5
753.1
611.5
403.4
N.A.
2148.3
Source: Census of Manufactures, 1967
uf all the grains discussed in this section, soybeans appears to be
the most likely grain to have well-defined growth. Increasing world
demand for protein sources will require use of soybeans both for production
of animal foods and meat substitutes in food products for human "consump-
tion. Its Increasing importance as a food source will displace some of
the markets for flour (wheat and corn) products.
Strong incentives exist for the soybean industry to invest in
new storage and handling capacity. In recent years, soybeans hive cost at
harvest time about one-third of their peak off-season price. Despite the
opportunities available in the futures markets, there appears ample
6-16
-------
opportunity for materials cost saving by buying and storing large stocks
at harvest time. Industry experts feel that over the next fi¥e years,
two additional large soybean plants will be built annually, with ten
additions per year to existing plants.
6.1.3.3 Flour Mills
Wheat and dry corn mills are lumped together, in this section,
because in many instances the same plants process both grains. The end
product Is basically the sane, floor.
The flour milling industry is characterized as having little
growth, consolidation of production into fewer plants, and attrition of
the smaller plants. Total number of plants have declined from 618 in
1963 to 450 in 1§72. Value added has increased from $373 million
in 1963 to $509 million in 1972 with a virtual standstill from 1967 to 1972.10
Table 6-6 shows the size profile of plants by value of shipments
and employees. Demand for flour products is expected to remain unchanged
over the next few years. There appears to be ample capacity in milling
which will preclude any new construction. Furthermore, little incentive
exists to add storage capacity for the purpose of holding grains for specu-
lative purposes. As a result, no capacity additions are expected through
1981.
6-17
-------
Table 6-6. SIZE PROFILE OF DRY COM AND WHEAT MILLING PLANTS*
Establishment size,
1967 employees
1-4
5-9
10 - 19
20 - 49
50 - 99
*t i»fcft A t f\
iMU "~ X.H7
250 - 499
> 500
TOTAL
Number of
establishments
210
62
56
84
74
t i
•f**
9
2
541
Approximate number
of employees,
bj sector
300
400
800
2700
5300
f "*^V*s
D#UU
4300
N .A.
20,500
1
Value of shipments,
million dollars
18
24.5
48.6
313.2
720.8
rt * *•* r-
any. 3
479.9
N.A.
2454.6
I
a.
includes all flour milling except rice.
Source: Census of Manufactures, 1967
6,1,3.4 Wet Corn Milling
The wet corn milling industry is composed of seventeen very
large plants. These plants are characterized as having large fixed
assets, from $15 million to $115 million. Over the past ten years,
four new plants have come on-stream (two small plants have closed).
Wet corn mills produce corn starch, sugar, corn oil, gluten, animal
feed, and related products, Starch is also made from potatoes and wheat,
as well as corn. However, corn starch is felt to be the major component
of starch production.
6-18
-------
Very little growth is expected for the industry over the next
few years. Ample processing capacity exists for the short-term (up to
five years). Demand for products is expected to increase slowly and steadily.
Furthermore, wet corn millers don't appear to have any problems in
acquiring raw corn. Their production needs only constitute about 10
percent of all American corn production, this would seem to preclude
any need for additional storage at existing plants.
6.1.3.5 Rice Mills and Commercial Rice Dryers
At least 90 percent of the U.S. rice crop is milled in compari-
sion to less than 10 percent of the domestic corn crop and approximately
30 percent of the U.S. wheat crop. The product of rice mills is whole
grain rice.
Rice is harvested "green" or rough and must be dried within
forty-eight hours after harvest. After drying, rice can be stored inde-
finitely, awaiting milling. A good portion of the drying at this
junction is conducted by on-farm dryers and commercial rice dryers.
Rice is grown in three principal regions in the U.S.: (1) Cali-
fornia, (2) Sulf Coast along Texas and West Louisiana, and (3) Mississippi
River valley along Arkansas, Mississippi, and Northeastern Louisiana.
Mill size, configuration, and ownership patterns vary from region to
region. In Louisiana are found the smallest plants, which are family
i
owned, Texas and California have the largest mills. Co-ops own the
plants in California (about SO percent) and Arkansas (about 60 percent).
Elsewhere, private individuals and corporations own the rice mills.
6-19
-------
The number of rice mills has decreased from 74 in 1963 to
56 in 1972.^ The plant closings have been primarily due to
acquisitions and consolidations in Texas and California, Table 6-7
shows the profile of plants by employee size and value of shipments.
The typical rice mill is assumed to process 2.88 mi 11 ion bushels of
rice per year.
Table 6-7. SIZE PROFILE OF RICE MILLING INDUSTRY - 1967
Number of
employees in
establishment
1-4
5-9
10 - 19
20 - 49
50 - 99
100 - 249
250 - 499
TOTAL
Number of
in sector
10
6
6
18
17
7
4
68
Approximate
employees by
sector
25
42
95
630
1240
1000
1300
4200
Value of
$ million
0.8
21,0
10.4
65.7
191,3
121.8
156.4
548.4
Value added
$ thousand
8.0
9,5
36.8
13t6
23.5
24.9
28.5
24.7
Sourcet Census of Manufactures» 1967
6-20
-------
On the other hand, ownership of commercial rice dryers is
spread among many small firms. There were some 219 cownercial rice
dryers in 1973.12 The plant size of these dryers varies from
100,000 bushel capacity to 7 million bushel capacity. Most plants
are less then 500,000 bushel capacity. (The terms capacity and annual
throughput ace used interchangeably in this analysts for dryer
facilities because they are assured to have an annual throughput
to capacity ratio of 1.0.)
In terms of ownership, 160 of the dryers are owned by
independents, or 73 percent of the total; yet, the Independents only
own 59 percent of the storage capacity. Farm cooperatives who own
this remaining portion of the dryers, are roost important in Arkansas.
These dryers are the largest in the industry and the co-operatives
control some two-thirds of the marketing. California is also Important
in terms of co-operative participation in drying. In recent years
new investment in drying and storage capacity In California has only
been initiated by cooperatives or large independent rice mills.
Elsewhere, in particular in Louisiana and Mississippi, the major trend
has been toward on-farm drying and storage.
Integration of drying and storage with milling has been growing
in California. Low returns on drying and storage as a result of low
fees set by the California Public Utilities Commission has discouraged
coraroercial rice dryers. As a result, the mills have invested in
drying and storage to assure access to grain supplies. In the
Mississippi River Delta Region, backward integration from Ho? »ms
to rice dryers has not occurred.
6-21
-------
The growth in demand for rice will most probably come from the
international sector, particularly Asian countries where rice is a
dietary staple. Domestic demand remains relatively unchanged. Recent
history has witnessed shortages of rice and upsurge in prices, prompted
by increased demand in the foriegn sector concurrent with crop failures
in the rest of the world. The outlook for prices is uncertain, but
the world demand will be growing.
One of the few areas tn the world that can expand production
rapidly is the U.S. However, this is constrained to the Mississippi
River Delta Region where both water and land are available to support
increased production. Increased production1 will require additional
drying and storage facilities.
It is difficult to predict who will build new drying and storage.
facilities. As pointed out earlier, these functions can be done on-farm,
commercially, or by the rice mills themselves. The economic analysis
is structured on the basis that either commercial rice dryers or mills
will be prospective new sources.
From the standpoint of the pricing mechanics, any incremental
costs incurred by the mills are assumed to be passed backward to
the commercial rice dryers or farmers. This argument is similar, to
the one used in the marketing of the other grains.
As far as expansion projections, Arthur D. Little estimated that
10 new rice mills would be built over the next five years ending in 1981.
These mills are assumed to require storage facilities. Added drying
capacity to handle the incremental production for these mills is
assumed to be shared with these mills and new commercial rice dryers.
6-22
-------
6.2 CONTROL COSTS AND COST EFFECTIVENESS FOR NEW/RECONSTRUCTED SOURCES
6.2.1 Introduction
The purpose of this section is to present estimates of capital
and amnualized costs for control technology alternatives which may
be used in developing the rationale for recommending new source
performance standards. This section will combine new and reconstructed
facilities for the reason that most of the anticipated growth
will be in the area of expanding and upgrading existing grain
elevator facilities. The grain handling industry in this section
will be divided between the distribution system {grain elevators) and
grain processors. In addition, grain dryers, which are a support
function in the grain distribution system, will be highlighted and
discussed as a separate topic on cost effectiveness.
Most of the discussion on control alternatives and costs will
be emphasized in the grain elevator segment. Following the discus-
sion of control technology alternatives for the individual affected
facilities will be a presentation of control costs for three levels
of control system alternatives on a model plant basis. (The model
plant comprises several unit affected facilities.) In the presenta-
tion of the model plant control systems, costs will be presented
for each affected facility.
The incremental costs of the alternative levels of control
above costs for State requirements will be identified. The incremental
costs are important in determining the economic impact of proposed
performance standards.
Throughout the sect!on^ the terms capital and annualized cost
are used; therefore, a brief definition is in order. The capital
6-23
-------
cost-includes all the cost items necessary to design, purchase, and
install the particular control system. The capital cost includes
the purchased cost of the major control device (fabric filter or high
efficiency cyclone) and auxiliaries such as hoods, fans, and any
instrumentation; the equipment installation cost including foundations,
piping, electrical, wiring, retrofitting (reconstructed sources),
and erection; and the cost of engineering, construction overhead,
and contingencies. All costs are updated to reflect January 1976
dollars.
Trie major source of control costs for this study was the Midwest
1 ^
Research Institute report (MRI)-. Other sources of cost data were
the Arthur D. Little study (ADL),14 vendors15*16'17 (in particular,
for grain dryers), and grain handling operators.18,19
The following assumptions were used to determine annualized
costs. Annual capital charges were calculated on the basis of 100
per cent institutional lending with uniform type payments (capital
recovery factor). Life of equipment was assumed to be 15 years;
rate of interest, 10 per cent. Property taxes and insurance and
administrative costs were calculated on the basis of 4 per cent of
total capital investment. The electrical expenses were determined
from the electrical requirements presented in Chapter 7 for
grain handling. The cost of electricity was assumed as 3 cents per
kilowatt-hour. Maintenance costs for fabric filters were estimated
as $0.13 per cfm; high efficiency cyclones, $0.065 per cfm. Fuel for
grain dryers was assumed to be $2.00 per million BTU. Operating and
maintenance requirements for grain dryer controls were obtained from
the various vendors.
6-24
-------
No credits for product recoYery, reduced fire insurance premiums,
reduced absenteeism of workers, or reduced plant maintenance have been
incorporated in the pollution control costs. Even where the by-products
may have significant market values, the assessment of these credits
is difficult. Therefore, for simplification purposes, accounting for
credits has been omitted in this analysis.
6-25
-------
6,2.2 Grain Elevators
The scope of the grain handling industry under investigation
extends from the small country elevator (on the order of 250,000 bushel
storage) to the port terminal (storage capacity of 5 million bushels).
Most of the anticipated expansion in the industry will be in response
to cost savings techniques within the grain distribution system. To a
lesser degree, some local expansion may occur with a surge in regional grain
production or consolidation of distribution facilities. The type of. expan-
sions that are likely to be considered as reconstructed sources are those that
will upgrade country elevators to accept unit-trains of 25, 50, 75, or 100
cars with emphasis on fast loading in a 24 hour period. This will create
a need on the part of the existing elevator to expand storage and increase
leg capacity. On the other hand, the high throughput terminal, characterized
by minimizing storage and specializing in one grain to serve the export mar-
kets, will be the likely candidate for the new grass roots facilities.
The affected facilities are: truck loading/unloading, railcar loading/
unloading, barge/ship loading, barge/ship unloading, handling (including
conveyors, scales, surge bins, grain cleaning, etc.)» and grain dryers.
The control technology for each affected facility consists of various
degrees of particulate capture (enclosures, hooding) and removal (fabric
filteration vs cyclones). Grain dryers are somewhat different 1n that
screen mesh and column perforation diameters are the critical factors
1n their design and performance. A summary of available control
technologies for each affected facility is presented in Table 6-8 for
6-26
-------
three "levels" delineated as: a) best control technology, b) recommended
control technology, and c) control technology for state requirements.
The categorization of controls in this manner allows for easy association
by the reader with the alternative control levels used later in this analysis
on a model plant basis. As shown in the table, the major difference between
A and B is the shed requirements for railroad car loading and the vacuun-cleaned
screen requirement on column dryers. There are technical reasons why the
totally enclosed sheds might not be reasonable in addition to significant cost
differences. The selection of best control technology on the grain dryers is
a separate issue from the grain loading, unloading, and handling facilities
in B. It will be discussed further in the chapter.
The next step is to characterize the model plants and assimilate these
affected facilities into their configurations. Six model plants that repre-
sent the types of new and reconstructed sources as discussed previously are
presented in Table 6-9 with the important engineering parameters that are
used in determining costs. The parameters for storage capacity, throughput
capacity (leg capacity), annual throughput, and dryer capacity are given.
Ventilation rates (acfm) are presented for control systems to handle the
partfculate emissions for the various affected facilities.
The model plant sizes used in this analysis are sometimes different
from sizes of similar plants in the MRI study. Capital costs were adjusted
by a scale factor of 0.7 (i.e., cost of Control System A = Cost of Control
System B x (Ventilation Rate of A * Ventilation Rate of B) ). Ventilation
6-27
-------
TABLE 6-8. SUMBARY OF CONTROL TECHNOLOGIES ON AFFECTED FACILITIES
Affected Facijjty
Truck Loading/Unloading
Box Car Loading
Hopper Car Loading
Rail car Unloading
Grain Handling
Barge/Ship Loading
Barge/Ship Unloading
Grain Dryers
A. Bes t _Cjon trol iTech no1ogy
Totally enclosed shed with quick closing
doors (2), ventilated hopper, FF,
Totally enclosed shed with quick closing
doors (2), tightly sealed (side-door)
hooding system, FF
Totally enclosed shed with quick closing
door(2), hood, special loading spout, FF
Totally enclosed shed with quick closing
doors (2), ventilated hoppers, FF
Ventilation, FF
A choke-feed spout ventilation, FF
Totally enclosed leg, ventilation, FF
(subject to equipment specifications
on enclosure aspiration)
Vacuum-cleaned screen/any type
B. Recgmiiiended Control Technology
Shed with 1 quick closing doer (other:
opened) ventilated hopper, FF
Shed with open ends
Sane hoodinf, FF as (A)
Shed with open ends
hooding, FF as (A)
Special loading spout
Same as (A)
Same as (A)
Same as (A)
Same as (A)
Vacuum-cleaned screen/rack
No screen/column
C. C.ontroXjrechnolofly, for State. Reguireraervts
Ventilated hopper CY (weather conditions
may require shed or roof cover}
Some form of hooding system, CY
Same hooding as (A), CY
Shed with one end closed CY
(except for FF on Poet Terminal)
Ventilation, CY
(FF on Terminals)
Choke-feed spout, ventilation, CY
(except for FF on Inland terminal)
Enclosed leg, ventilation, FF
Screen/Rack
No screen/column
Reference to Abbreviations: FF - fabric filter
CY - high-efficiency cyclone (efficiency = 90*}
-------
T«Li «-f,
PLANT CWWACHRISTieS FOR TOE SWWM ELIWTOR IHDUSTRf
Description
Capacity
1, Storife - bu.
2. Thrupyt - bu, per yr
3, Lei " bu. P«r hr.
4, Oryer - bw. per hr.
Control System Ventl U-
tton Rstes, ACFM
1. Confclned Receiving/
en Loading
' 2, Truck Receiving
us 3, Railroad Car
Receiving
4. Barge Receiving
5. Handling, Hei§Mng
6, Handling, Tyrnlng,
Barfe Loading
(Inland Terminal ) "
1 . Scale and Garner
8. Railroad Car Loading
i. Drying
10, Cleaning
11. Ship Loading
woo. PLANT i
Traditional Counter
Eleyitor
SOO.OOO
1,000,000
1 x 5000
1,000
10,000
—
—
».
3.0W
_•.
—
—
30,000
—
..
mm. PLAKT t
Upgraded Country
Elevator (2§ cars)
SOO.OOO
1,000,000
1 x 10,000
1,000
16,400
—
—
4,000
«...
--
..
30,000
—
•>-
MODEL PLANT 3
Upgraded Country
lltvator (SO to 100 cars)
500,000
3,500,000
2 x 11,000
2,000
__
12,260
..
__
I x 6,000
--
10, -000
iO.OOO
5,000
,
MODB. PLANT 4
New High
Throughput Terminal
350,000
3,500,000
2 x 15,000
2,000
.*.
12,250
—
__
2x 6,000
•*
_.
"10,000
60,000
5,000
—
PLANT 5
Traditional
Inland Terminal
5,000,000
IS, 000,000
4 x 15.W
2,000
*•**
12,250
1S,0«J
__
__
45,000
2 x 8,000
I x 10,000
60,000
10,000
.,
MODEL RAW 6
Port Terminal
i, 0)0,000
40,000,000
4 x 35,000
2,000
«...
12,250
25,000
15,000
•w
45,000
2 x 10,000
..
60,000
20,000
20,000
-------
rates were assumed to be directly proportional to material throughputs, sub-
ject to physical constraints such as spatial requirements for grain unloading
or loading (boxcar, hopper car, barge, ship, etc.). Operating costs were
adjusted in direct proportion to changes in material throughput or hours of
operation,
A tabulation of the capital and annualized costs for the individual
affected facilities for each model plant for three levels of control is pre-
sented in Table 6-10, It is important to point out here that new sources
affected by new source performance standards will have to compete with new
sources, and existing sources retrofitted prior to 1975, constructed in
compliance with State regulations. Hence, level C serves as the baseline
for comparison of the costs of various control system alternatives.
To show the impact of the pertinent standards upon the grain industry
requires segregating certain service-associated costs. Hence, drying,
cleaning, and handling (unloading, turning, weighing, loading) are separate
functions in so far as the mechanism of sharing the transaction costs for
each function. For example, farmers producing those grains requiring clean-
ing and drying will have to pay for the costs of these services. As an aid
to understanding of the segregation of control costs, a format for the an-
nual i zed costs (aggregate and unit costs) has been prepared and is presented
in Table 6-11.
For comparison with State regulatory requirements on new and reconstructed
sources, Table 6-12has been prepared to show those incremental costs over the
State requirements for the levels of best control technology and recommended
control technology. For the level of best control technology, unit costs
6-30
-------
TAILE 6-10. TABULATION OF CAPITAL AND ANNUALIZED COSTS FOR ALTERNATIVE CONTROLS FOR Niff GRAIN ELEVATOR
: Model Plant
Annual Through Put, Bushels
Retrofit Penalty
A. Best Control Technology
Combined Unloading/Loading
Truck Unloading !
, Railroad Car Unloading
Handling, Weighing
Handling, Turning, Barge Unloading
Scale and Surge Bins
Railroad Car Loading
Cleaning
Ship Loading
iarge Unloading
Drying
Totals
8. Recommend Control Technology
'Combined Unloading/Loading
Truck Unloading
^ Railroad Car Unloading
ca Handling, Weighing
~* Handling, Turning, Barge Loading
Scale and Surge Bins
Railroad Car Loading
Cleaning
! Ship Loading
Barge Unloading
Totals
C, Control Tech, For Stite Ri^yJrsoents
Combined Unloading/Loading
Truck Unloading
Railroad Car Unloading
Handling, Weighing
Handling, turning. Barge Loading
} Scale and Surge Bins
! Railroad Car Loading
Cleaning
., Ship Loading
large Unloading
Totals
12 3416
Traditional Upgraded Upgraded Country New High • Traditional Port
Country Elevator Country Elevator Elevator Through Put Inland Terminal Terminal
(25 cars) (50 to 100 cars) Terminal
1,000,000
m
__lny,t$L Ann.li)
103,400
—
—
17,000
—
—
—
—
--
27,600
148,000
55,600
.0
17,000
—
—
—
_.
, —
—
72,600
32,850
—
—
10,850
•«
—
—
-0
— 0
0.
43,700
19,700
00
-_
3,600
_.
—
..
--
_.
00
5,600
28,900
11,100
—
o.
3,600
0.
—
—
00
00
__
IS, 100
6,700
—
.0.
2,300
.0
00
t»»
0,
__
—
9,000
1,000,000
20*
Igv.(S) AmutlL
146,000
—
.„
25,000
0-
.0
-0
-0
-_
.0
27,600
198,600
88,400
—
—
2S.OOO
—
_.
0.
_.
.«
—
113,400
55,800
-0
—
16,000
—
—
—
—
__
—
71,800
27»600
—
..
5,200
o_
_o
_-
_.
-o
o..
7,000
39,800
17.SOO
0.
—
5,200
—
—
-.
-_
._
—
23,000
11,300
—
—
3,400
—
—
.0
0.
--
_-
14,700
3,500,000
10X
__Iw»tJL Ann,{$}
.-
S3, 000
__
60,800
—
-_
119,400
18,400
o-
00
39,900
291 ,500
—
45,300
—
60,800
0.
—
48,300
18,400
--
—
172,800
o«
24,000
_«
60,800
—
—
20,800
12,400
oo
_.
118,000
_.
11,400
-_
13,400
.0
--
21,800
4,630
--
--
8,700
59,900
--
10,100
—
13,400
._
--
9,640
4,630
._
—
37,770
-•
5,400
—
13,500
—
00
3,500,000
OX
_«
52,300
__
55,300
-_
108,500
16,700
00
00
39,900
272,700
__
41 ,200
0.
55,300
—
._
43,900
li',700
..
—
157,100
_-
21,800
0.
55,300
—
—
4,400] 18,900
2,600i 11,300
__
25,900
00
*-*
107,300
_.
10,600
__
12,500
.-
__
20,000
4,350
--
—
8,700
56,200
__
9,400
0,
12,500
.-
.-
fl.900
4,350
.-
00
35,110
__
5,000
—
12,500
—
.0
4,100
2,400
«-«
—
24,000
15,000,000
01
!«¥.{$) Ann.(S)
48,200
60,500
«.<.
145,300
55,300
14S.OOO
33,400
—
_.
39,900
527,600
—
41 ,200
60,500
0_
145,300
5i,300
80,000
33,400
00
—
415,700
—
21 ,700
26,300
—
145,300
55,300
47,900
22,600
*-
319,100
0_
10,200
13,000
41 ,800
11,500
28,000
7,400
_.
8,700
120,600
—
9,000
13,000
—
41 ,800
11,500
17,000
7,400
-.
.0
99,700
—
4,700
4,800
—
41 ,800
11,500
10,000
4,800
-«.
77,700
40,000,000
OX
In»,{$) Ann.lS)
48,200
95,300
145,300
59,000
66,800
66,300
42,300
39,900
563,100
—
41 ,200
95,300
..
145,300
59,000
_.
66,800
66,300
99,700
516,200
0.
21 ,700
55,300
—
145,300
59,000
_.
51,100
50,600
42,300
425,300
»*»
10,200
21,000
41 ,800
14,800
_.
15,800
15,100
9,500
8,700
136,900
—
9,000-
21 ,000
0.
41,800
14,800
__
15,800
11.100
9,500
127,000
—
4,700
26,000
__
41 ,800
14,800
*"*"*
10,200
10,500
i.500
117,500
-------
TASLE $-11, OF 8RAFN AfWULIZED FOR
ALTERNATIVES LEVB.S OF CONTROL TECHNOLOGY/GRAIN ELEVATORS
A. lest Control Technology
Model
T. Traditional Country
2, Upgraded - 25 car
3, Upgraded - 50/100 car*
4. High Throughput
5. Traditional Inland
6, Port Terminal
Receiving,
Handling, etc.
Total
$ 23,300
32,800
«,§QQ
43,100
1 04.SOO
112,400
Volume
1HH
1MH
3.5MM
3.SMM
law
40MM
t/m
2.33
3.28
1.33
1.23
0.70
0.28
Orylnfl
Total
$5,600
7,000
8,700
8.-7QO
8,? 00
8,700
Volype
SOW
500H
\m
IHM
4MM
WM
*/BU
1.12
1.40
0.87
0.87
O.K
0.87
Cleaning
Total
$ 4,600
4,350
7,400
15,800
Volune
700M
TOOK
3MM
6MM
«/BU
O.S6
0.62
0.25
0.26
B. Recommended Control Technology
Model
1, Traditional Country
2. Upgraded - 25 car
3. Upgraded - 50/100 car
4. High Throughput
S. Traditional Inland
6, Port Terminal
Receiving,
Handling, etc.
Total
$ 15,100
23,000
33,170
30,750
12,300
111,200
Volume
1MM
1MM
3.5W
3.»W
15W
40W
*/8U
1.51
2.30
0.95
0.88
0.62
0.28
Drying
Total
.„
Volume
500M
500M
1MM
1MM
4>W
1MM
tim
—
C\ean1n§
Total
$ 4,600
4,350
7,400
15,800
Volume
700M
700M
3HH
6WI
i/BO
0.66
0.62
0.28
0.2$
C. Control Technology for State Requirements
Model
1. Traditional Country
2. Upgraded - 25 car
3. Upgraded - 50/100 car
4. High Throughput
5, Traditional Inland
6. Port Terrn1n.il
Receiving,
Handling, etc.
Total
$ 9,000
14,700
23,300
21,600
72,900
107,300
Volume
1MM
If*
3.SMM
3,5MM
15MM '
4QMM
*/BU
O.iO
1.47
O.SS
0,62
0.4?- •
0.2?
Oryfflf
Total
~_
--
ffm
' " t.~
--
Volume
50QM
500H
1MH
1HM
4ftf
1MM
t/iU
__
--
.^*»
--
—
Cleaning
Total
-_
$ 2,600
2,400
4»800
10,200-
Volume
,_
700H
nm
3MH
6MM
*/BU
__
0.37
0,34
O.Ii
0.17
NOTE; 1) Volume refers to annual throughput handled, dried, or cleaned in bushels per year.
2) All costs In January 1976 dollars.
-------
er>
i
<*»
TABLE 6-12. SUMMARY OF INCREMENTAL COSTS FOR ALTERNATIVE LEVELS OF
CONTROL TECHNOLOGY STATE REQUIREMENTS/GRAIN
A. Best Control Technology
1,
2.
3.
4.
5.
6.
Model
Traditional
Country
Upgraded- 25 car
Upgraded~5Q/lQQ car
High Throughput
Traditional Inland
Port Terminal
Incranental
Capital ($)
104,300
126,800
173,500
165,400
208,500
137,800
Incremental
Annual 1 zed
Costs ($/yr)
19300
25,100
34,000
32,200
42,900
19,400
Handling and Drying
With Drying
2,55
3.21
1.54
1.48
0,43
0.88
Unit Costs (^/bu)
W/Q Drying
1.43
1.81
0.67
0.61
0.21
0.01
Cleaning
Unit Costs
(*/bu)
0
0
0.29
0.28
0.09
0,09
1.
2.
3.
4.
S.
6.
Model
Traditional
Country
Upgraded-25 ctr
Upgraded~5G/1QO=.ear
High Throughput
Traditional Inland
Port Terminal
Incremental
Capital ($}
28,900
41 ,600
54,800
49,800
96,600
90,900
B, Recowmended
Incremental
Annualized
Costs ($/yr)
6,100
8,300
11,900
11,200
22,000
9,500
Control Technology
Handling Unit Costs
C*/bu)
W/0 Drying
0.61
0,83
0.29
0.26
0,13
0,01
Cleaning Unit
(*/bu)
0
0
0.29
0.28
0.09
0.09
Costs
-------
have been calculated for grain handled without drying and for that portion
of grain handled and dried.
6.2,3 Grai n Processors
The purpose of this section is to present control costs which will serve
as inputs for the economic analysis of the impact of control alternatives upon
the grain processing industry. The basic procedure is to present capital and
annual1zed costs for air pollution control systems for the model plant con-
figurations, 1n much the fashion as in the previous section for grain
elevators. Thust control costs will ba presented for best controls, recommended
controls, and controls for meeting State regulations. The Incremental costs
for best and recommended controls above State requirements will be noted.
The affected facilities include truck and railroad car unloading, handling
(transfer, scales, etc.) and dryers. The scope of the grain processing
fndjBtry under Investigation Includes wheat flour mills, dry corn mills,
Hce mills, wet corn mills, soybean processors, and connerdal rice
dryers. The engineering parameters for estimating the control costs are
presented in Table 6-13* The control technology for the alternative control
levels Is much the same as that applied for the grain elevators. The capital
and annualized control costs for each of the affected facilities is presented
in Table 6*14. The one major difference in costs between grain processors
and elevators appears 1n the truck unloading facility/best technology category.
Costs are presented for an expanded truck shed to accowodate unloading tractor
trailer trucks where 2 quick-closing doors would be considered as best techno-
logy.
6-34
-------
TAill 6-13, PUNT CHARACTERISTICS FOR 6RAIN REQUIREMENTS FOR HANDLINS FACILITIES
Description
Grain Handled, t>y. per year
Elevator Le§ Capacity,
8u. Per Hair
Operating Hours (Receiving)
Hill Capacity
Annual Outpt
i
tn Grain Weight Density
It*, per Bu.
Control System Ventilation
Rates, ftCFM
a) Truck Unloading
b Car Unloading
c Handling and Transfer
d Scale and Surf* Bins
« Dryer
f) Unloadlng/Loadinf
Wheat Mill
2,778,000
5,000
2,500
5,000
CMT/24 hr.
1,250,000
(Off)
60
25^000
2s,oao
10,000
Dry Corn Will
3,348,000
«,000
2,500
5,000
WT/24 hr.
1,250,000
(CUT)
16
12J50
25,000
10^000
m ,000
Rice Mill
2,805,000
5,000
2,500 •.
200
bbl per hr.
800,000
{162 Ib per bbl)
4S
same
as
Bry
Corn
Rice Dryer
767,000
7,000
1500
2,000
iu/hr.
345,000
CUT Processed
45
3,000
fiO.OOO
12.2SO
Sei*ean Processor
11,100,000
20,000
2,500
1,000
Ton/24 hr.
330,000
Ton Processed
SO
same
as
Ory
Corn
Mill
Wet Corn Milling
10,000,000
20,000
2300
30,000
Bu/24 hr.
10,000,000
Bu, Processed
56
same
as
Mieat
«m
-------
TABLE 6-14, TABULATION OF CAPITAL AND ANNUALIZED COSTS FOR NEW SOURCES/GRAIN PROCESSORS, COMMERCIAL RICE DRYERS
All Grain Processors
Truck Unloading
Car Unloading
Handling, Transfer
Scale and Surge Bins
Dryers
TOTALS
Commercial Rice Dryers
Unloading/Loading
Handling, Scale
Dryers
TOTALS
A. Best Control
Technology
Inv. ($) '
62,200^)
75,300
80,200
31.100(2)
248,800
Inv. ($)
69,300
17,000
39,900
126,200
Ann. ($)
13,900
20,700
28,900
8:!°°(2)
71,600
Ann {$)
14,200
3,700
8.700
26,600
B. Recomr ended
Control Tecr oology
Inv. ($)
41,200
75,300
80,200
31,100
227,800
•
Inv. ($)
62,300
17,000
79 f 300
Ann, pj
10,300
20,700
28,900
8,100
68,000
Ann. ($}
13*000
3,700
16,700
C. Control
Technology for
State Requirements
Inv. ($)
21 ,800
36,700
61 ,600
20,300
140,400
Inv, ($)
37 ,800
10,600
48,400
Ann. ($)
5,800
10,400
18,300
5,000
39,500
Ann. ($)
7,800
1,000
8,800
(2)
'Costs include expansion of truck shed to accommodate two quick-closing doors.
For dry corn millers and soybean processors, control capital for dryers is $27,600. Annual1zed costs are
$5,600 per year. In addition, some rice mills may dry rice.
-------
Suiwaries of capital and annualized costs for alternate controls are
presented 1n Table 6-15 for the grain processors and the commercial
rice dryers. Summaries of incremental costs above State standards are
presented in Table 6-16. Srain processors affected by drying operations
have been separated out to highlight the impact of dryer costs for the
best control technology level.
6-37
-------
Table 6-15, Summary of Grain Processors' and Commercial Rice Dryers' Costs for Alternative Control levels
Grain Processor
Capital Costs ($)
Annual 1zed Costs ($/Yr)
Type Grain
Whe*t
Met Corn
Dry Com
03 Soybean
Annual Throughput,
Bu,
2,78 HM
10.00 MM
2.88 m
3.35 MM
11.10 W
Comereial R1ce Dryer
Capital Costs ($}
Annuall zed Costs ($/¥r.)
Unit Costs (
-------
Table 6-16, Summary of Grain Processors' and Commercial R1ce Dryers1 Incremental Costs
for Alternative Control Levels Above State Requirements
Grain Processor
Incremental Capital Costs ($)
Incremental Annual ized Costs ($/yr)
Type Grain
Wheat
Wet Corn
Rice
Dry Corn
Soybean
Annual Throughput,
Bu
2.78 MM
10.00 MM
2,88 MM
3.35 MM
11.10 MN
Commercial Rice Dryer
Incremental Capital Costs ($)
Incremental Annual ized Costs ($/yr)
Incremental Unit Costs, (4/bu)
(Annual Throughput, 0.77 MM
Bu/yr)
A. Best Control Technology
{including Dryers)
136,000
37,700
Unit Costs
U/Bu)
NA
NA
1.31
1.13
0,34
A. Best Control Technology
(including Dryers)
77,800
17,800
2.31
8. Best Control Technology
(w/o Dryers)
108,400
32,180
Unit Costs
WBu)
1.16
0.32
1.12
0,96
0.29
B, Best Control Technology
(w/o Dryers)
37,900
9,100
1.19
C. Recommended Control
Technology
87,400
28,500
Unit Costs
1.03
0.28
0.99
0.85
O.ZS
C, Recommended Control
Technology
30,900
7,900
1.03
-------
6.2.4 Cost Effectiveness for Grain Dryers
The purpose of this section is to present the costs of various
controls on grain dryers against their performance in reducing emissions.
In this section, the capital and annual 1 zed costs for a 2000 bushel/
hour dryer system, including controls, will be presented. Both rack
and column dryers will be reviewed.
The 2000 bu/hr. dryer is assumed to remove 5 percentage points of
moisture and to operate 500 hours annually. This size and operation
represents the typical operation at a country elevator that specializes
in handling corn and soybean grains. It also represents the typical
commercial rice dryer.
The cost data for the dryers and controls are based on vendors
quotations and the Arthur D. Little study, as discussed 1n Section
6.2,1.1. The assumptions used in calculating annualtzed costs were
presented 1n Section 6.2.1.1.
THe only two levels of control analyzed were screens and
Vacuum-cleaned screens. Attempts In establishing a cost-effectiveness
relationship versus screen mesh were unsuccessful. Contact with various
vendors brought-a mixed response as far as cost differences in mesh
size. The most important factor of cost was found to be the vacuum-
cleaning mechanism for removal of collected particulate matter from
the screen enclosure.
A summary of the capital, annualized costs, incremental annualized
costs, and cost-effectiveness are presented in Table 6-17, The data
in the table suggest that the column dryer without a screen is just
as effective as a rack, dryer with the vacuum-cleaned screen, as far as
6-40
-------
Table 6-17. Sumnary of Cost-Effectiveness for Brain Dryers
Dryer
Description
Rack/Screen
Rack/Vacuum
Clean Screer
Column/ no
Screen
Col yum/
Vacuum Clear
Screen
Investment
m
114,300
152,000
105,000
158,400
Annual i zed
Costs ($/yr)
39,430
47 ,fOO
39,300
51,430
Unit Costs
C$/BU)
0.0394
0,0477
Q.0393
0.051
Incremental
Unit Costs
($/BU)
0
0.0083
0
0.011?
Mass Emissions
(Ib/Ton)1
1.10
0.27S
0,25
0.05
Incremental Cost
per Ib Pollutant
Removed ($/lb)
0
0.34
0
1.95
en
Assume 60 Ibs. of grain per bushel.
-------
mass emissions are concerned. The rick dryer with the non-vacuum-cleaned
screen may be just as expensive.as the column dryer with no screen,
both costing about 3.93 cents per bushel; but the rack dryer produces
a significantly greater amount of emissions.
In terms of cost-effectiveness, the requirement of a vacuum-cleaned
screen on the column dryer .will cost $1,95 per incremental pound
of pollutant removed. For the rack dtyer, the requirement of a
vacuum-cleaned screen would cost about $0.34 for each incremental pound
of pollutant removed.
6-42
-------
6.3 ECONOMIC IMPACT ANALYSIS FOR NEW AND RECONSTRUCTED SOURCES
6,3.1 Introduction
In this section, the economic impact of Incremental control costs
is assessed for new and reconstructed sources in the grain distribution system
(grain elevators), grain processors (unloading facilities and grain handling),
and grain drying operations. The incremental control costs developed for the
alternative controls in Section 6,2 will serve as thi inpyt for the analysis
in this section. The economic Impact will be addressed in terms of new
sources to be built for each alternative control level. The conclusion
regarding the impacts at various levels will then be incorporated as a
decision tool in recommending standards in the rationale chapter.
6.3.2 Grain Storage Elevator and Dryers
One important trend in the grain industry is an increased demand for
high throughput elevators. The recent upsurge in foreign demand for U.S. grain,
the slow but steadily increasing domestic demand for grain, the lower level
of grain stocks, the trend toward more on-farra storage, and the attractive
railroad tariff offered by some railroads for multi-car shipments have
combined to produce two major effects: (1) a decrease in the demand for
grain elevators to store grain, and (2) an increase in the demand to handle
and move larger quantities of grain. The above forces have stimulated the
construction of elevators which are located in the country and have
moderate to low storage capacity and the ability to handle grain quickly.
Likewise, these forces have stimulated some elevator operators to modernize
their existing country elevators to load 25, 50, or 100 jumbo hopper cars
quickly.?0
6-43
-------
As a result of this trend most new elevators are being designed with
similar storage capacity but relatively high throughput compared with existing
country elevators. Whereas a conventional country elevator might have a
throughput of 1,000,000 bushels per year with storage capacity of 500,000
bushels, the new high throughput terminal elevator would have the storage
capacity and 3,500,000 bushels per year throughput. Some 105 low storage-high
throughput inland terminal elevators would be constructed in the absence of
standards of performance over a 5 year period terminating in 1981.^ Also an
estimated twelve irmou (traditional} terminals and five port terminals would
??
be constructed in the absence of standards over the same time period.
According to ADI, the typical country elevator with a storage capacity
of 200,000 to 500,000 bushels and an annual throughput ratio of 2-3 is generally
not being constructed at this time. Except for replacement of a country
elevator destroyed by fire or explosion, or for filling an unusual local
need, little economic incentive exists for construction of new country elevators
through 1981. Nevertheless, a projected number of some 40 low storage, low
throughput country elevators may be built, primarily to replace destroyed
facilities, through 1981.23
EPA contact with builders of grain elevators in the midwest found
that some small country elevators may be built.24*25 Qne |>u-nder
indicated that possibly in certain localities without adequate rail
facilities, there might be a need for a new country elevator. In such
areas, the trend is toward construction of more storage, rather than
new elevator construction, and conveyance of grain by tractor-trailer
truck haulage to a terminal elevator.
6-44
-------
A second important trend is modernization of existing country elevators
to load a large number of railroad cars in a relatively short time. Not all
existing country elevators can upgrade their facilities to Toad multi-car
trains; but, those that do have the opportunity would realize a substantial
savings in freight costs. It is important to emphasize that unless the freight
savings are available, there would be ua economic incentive to upgrade the
handling capacity at a country elevator. Expansion in grain production could
be accommodated by addition of storage capacity alone. Nevertheless, an
estimate of 140 modernizations (i.e. upgrading throughput capacity) will occur
by 1981 to utilize 50-100 car trains and 215 modernizations to utilize
25-car (or fewer in number) trains,^ These estimates are for facilities
constructed in the absence of new source performance standards.
Another issue, aside from growth in grain elevators, is the construc-
tion of new grain dryers by grain elevators along the grain distribution
system. These dryers are particularly important to those country elevators
and inland terminals that handle and store corn and soybean grains and to
those port terminals that load grain for export markets. Some 1382 grafn dryers
are expected to be built in the absence of new source performance standards
through 1981.
A summary of the number of new and reconstructed grain storage
elevators and dryers to be built in the absence of new source performance
standards over the 1976-1981 time period 1s presented in Table 6-W.
t •- ...._.
The following atsumptlons are used in analyzing the economic impact
of incremental control costs associated with control levels which are
more stringent thin current Statt regulations. Any new elevator must compete
6-45
-------
TABLE 6-18. .GRAIN ELEVAIQBS_--ANIJ.CIPAIED NUMBER
OF NEW AND RECONSTRUCTED SOURCES IN ABSENCE OF NSPS
(January 1» 1976 to December 30» 1981)
Country Elevators
Country Elevators (Upgraded to
25 car trains)
Country Elevators (Upgraded to
50-100 car trains)
U4*-«fev TUirtrtiirf !htr\i i+» To v*m 1 ri a 1 e
Traditional Inland Terminals
Port Terminals
New, Reconstructed
Grain Elevators
40
21S
140
TOR
12
5
New Grain
Dryers
1115
70
57
K.K
+*•#
65
10
6-46
-------
not only with other elevators in a one-on-one sense but also with rival
transportation and distribution systems composed of country elevators
and terminals. Each new elevator that collects grain from the farmer
and distributes it to an end point, such as a port terminal or processor, is
creating a new collection and transportation system that is competing with
existing similar systems. All existing elevators have incurred control
costs to meet State regulations as of July 1» 1975 and have passed these
costs through their respective distribution systems along to producers and
consumers of grains and possibly absorbed some. It would appear that these
costs are approximately equal to current dollar value of controls for meeting
State regulations on new and reconstructed sources. In other words, retro-
fitting controls to existing sources prior to July 1, 1975 would probably
find that a 20 to 30 percent retrofit penalty to be completely offset by
an inflation rate of the same magnitude for new sources built in 1976 or 1977,
Any new single elevator to be built myst either absorb any incremental costs
that exceed controls for compliance with State regulations or pass them
back to the farmer if it cannot assimilate these costs into its total
distribution (including transportation) system costs. The individual
elevator operator is a small participant in the total world grain market
and cannot be expected to singularly pass his costs forward to the consumer.
In the analysis of the traditional country elevators, the existing
country elevator is assumed to have a total distribution system cost of
48.8 cents per bushel* which includes pollution controls in compliance with
State regulations. In this system, grain moves from the country elevator
through the inland terminal to the port terminal, or processor. In this
system, profit for the country elevator is assumed to be 2.1 cents per
bushel. Incremental control costs associated with best control technology
6-47
-------
with dryinq amount to 2.554 per bushel (see Table 6-12) and 1.43^; per
bushel without drying for a new or rebuilt elevator. The possibility of
passing these incremental costs back to the farmer appears remote
except in those areas where the rebuilt country elevators may be several
miles away from competing elevators. Generally country elevators
are found in clusters. A distance of only some 2-5 miles might separate
elevators within a given clyster whereas distance between clusters may be
20 to 40 miles or more. If one elevator In a cluster is rebuilt and incurs
the additional costs of controls, then this elevator will have a distinct
competitive disadvantage If It- attempts to pass the cost back to the fanner.
The farmer, given this situation, will merely bypass the newly constructed
country elevator and sell his grain to one of the other elevators, who may
havt sufficient storage capacity.
If the competitive situation exists as just discussed for the new or
rebuilt country elevators, the costs of 2.55* per bushel and 1.43* per bushel
(Table 6-12) completely absorbs or nearly absorbs the 2.U expected profit
for the new source. In the judgment of EPA, this is sufficient reason to
believe that the 40 country elevators would not be built if best control
technology were required. Furthermore, best dryer controls for new dryers
built at existing country elevators would be expected to preclude the
construction of approximately 524 dryers.
The recommended controls will require an Incremental cost of 0.6^
per bushel, which would reduce an expected profit of 2.1 cents per bushel
by 29 percent if these costs were absorbed by thi country elevator.
In the judgment of EPA this profit reduction may be sufficient to preclude
the construction of elevators for some 50 percent of the anticipated 40
elevators. It Is difficult to second-guess management viewpoint in this
type of situation; the best perception of the collective opinion of 40
S-48
-------
elevator operators would be that they would be divided equally on this
issue of rebuilding an elevator. Hence, this Is the argument for the
estimate of the Impact of precluding the construction of 20 elevators for the
recommended control level.
For the analysts of the upgraded country elevators and high throughput
terminals., the Importance of the transportation system becomes apparent in
the impact analysis. Table 6-19 shows the estimated total grain distribution
costs for various distribution systems in which grain can proceed from the
point of delivery at the country or inland terminal up to delivery at a
port terminal or grain processor. Pollution control costs have been
assimilated into these cost structures for the alternative control levels,
Systems 2 through 5 involved prospective new sources in competition with
an existing country elevator-existing inland terminal-port system (System 1).
As mentioned earlier, the only incentive for upgrading or building a high
throughput terminal was thi possible reduction of transportation costs.
A review of Table 6-19 finds that System 2 elevator systems, those that
are far removed from the terminal point of consumption, may find a problem
in remaining competitive with existing country elevators. Incremental control
costs for the alternative control levels would increase tht total distribution
costs up to a point (48.8^/bu) beyond which the prospective upgraded elevator
. could no longer compete. For example, a System 2 elevator system would have to
add 2.H for pollution controls (for both upgraded country elevator and
existing inland terminal), which would increase the distribution costs from
42.6-47.2 cents per bushel to 44.7 - 49.3 cents per bushel, with only those
upgrades in the range of 44.7 - 4fi.8 cents remaining viable. Given that the
6-49
-------
TAilE 6-W* WO.
System t
Existing Country
Elevator To
Existing Inland
Terminal To
Port/Processor
OISTRIBUTION COSTS (i/SU.) FOR ALTERNATIVE CONTROLS AND SYSTE«
System 2
Upgraded Country
Elevator (2S Car)
To Existing Marti
Terminal To
Port/Processor
System 3 .System 4
Upgraded Country Upgraded Country
Elevator (2S Car) (Elevator (SQ-1QQ Car)
Directly Directly
To To
Port/Processor Port/Processor
System 5
'New High
Through Put
Inland
Terminal To
Port/Processor
Elevator Operating Costs
•Excl. Pollution Control
alncl. Pollution Control for
State Regulations
Transportation Costs
T mm
o
Total Distribution Costs
°Excl. Pollution Control
"Incl, Pollution Control —
a) State Regulations
e) Recommended Controls
c) Best Controls w/o Orytrs
d) Best Controls w/dryers
'. 15.3
16.9
27,0
; 4,9
47.2
'. 4S.8 '
: NA ,
NA
KA
17. S
19.6
19,0 - 25.0
i,l
42.6 - 47.2
44,7 - 48.8
45. S - 48.8
46.| - 48.8
47.9 - 48.8
11.1
12.6
19,0 - 25.8
3.3
33.4 - 38.4
34.9 - 40.9
35.7 - 41.7
36,7 - 42.7
38.1 - 44.1
4.S
5.S
16.0 - 23.0
1.5
22.0 - 29.0
23.0 - 30.0
23.6 - 30.6
24.0 - 31.0
24.9 - 31 .S
5.4
6.4
Ti.O - E3.0
0.7
22.1 - 2t»l
23.1 - 30.1
23.6 - 30,6
23,9 - 30,9
24,8 - 31.8
-------
44.7 - 48.8 cents 1s a baseline for System 2 elevators in compliance with
State regulations, incremental costs for recommended controls would raise
the distribution costs to 45,5 - 48.8 cents per bushel. If the population
of System 2 elevators were uniformly spread across this cost range, then it
AQ ft «. Af\ £*
can be shown by mathematical calculation, (1 - ^'g _ 44*7 ) x 100^J that
the number of elevators would be diminished by 20 percent. Carrying this
process further, applying oest controls without the dryer vacuum-cleaned
screen requirement would reduce the number of System 2 elevators by 44
percent from the baseline of Stat» regulations. Best controls including
the vacuum-cleaned screen requirement on dryers would reduce the number
of System 2 elevators by 78 percent from the State baseline.
Table 6-20 shows the translation of these percentage reductions into
actual numbers for the System 2 elevators. Some 43 elevators (25 corn/soybean
and IS wheat) are anticipated to be upgraded in the absence of Federal stan-
dards. Of these, 15 will install dryers (13 for corn/soybean and 2 for wheat).
According to the table, the imposition of recommended controls would reduce
the 43 elevators to 35j best controls without dryer'vacuum-cleaned screen, to
24; and best controls with dryer vacuum-cleaned screen, to 9. Intuitively, it
is expected that most elevators that derive their major revenues from
drying (e.g., the 13 corn/soybean cases) would be directly affected by a
stringent dryer standard. In any event, the impact would be a shift of
the drying function from the System 2 to the System 3 elevators. The
cost burden of 1.4 cents per bushel for drying controls in addition to the
normal drying cost of 2.1 cents per bushel could be better handled by the
6-51
-------
competitive elevator system with the distinct transportation advantage.
This is shown in Table 6-20 for System 3 where the number of dryers would
remain unchanged.
With regard to other types of elevators, there does not appear to be
any impact as far as grain handling operations are concerned. For drying
operations, the impact of vacuum-cleaned! screen requirements would preclude the
replacement of some 19 dryers for the upgraded country elevators (50 to 100
car) and high throughput terminals. (See Table 6-20.;) No change is anticipated
In the uumber of dryers at the traditional inland and port terminals.
The preceding analysis has been from the perspective of accommodating
incremental annualized control costs that accrue to various elevators.
It is also important to assess the incremental capital requirements in order
to acquire more information that would support an economic impact analysis
based on annualized costs. Table 6-21 presents the incremental capital
requirements above the State regulation as a baseline for the three
alternative control levels. For example, the upgraded elevator (25 cars)
would require 12 per cent more capital for the proposed controls than for
compliance with the State regulation. Comparing the derived data in
Tables 6-20 and 6-21 » general consistency can be found between the reduc-
tion in sources and incremental capital increases. The one noteworthy exception
appears to be the entire group of upgraded country elevators imposed by the
apparent significant Increases for best controls with and without dryer
vacuum-cleaned screen requirements. These substantial increases in the range of
21 to 37 percent appear sufficiently prohibitive to preclude the upgrading
construction project, yet Table 6-20 shows no impact for upgraded country
elevators that ship directly to port terminal or grain processors. The
6-52
-------
TABLE 6-20. SUMMARY OF THE IMPACT OF ALTERNATIVES
UPON CONSTRUCTION OF NEW SOURCES
i
in
OJ
(Model 1) (Model 2) (Model 2) (Model 3) (Model 4} (Model 5} (Model 6)
Traditional System System System System Traditional
Country 2 3 4 5 Inland Port
Elevators Elevators Elevators Elevators Elevators Terminals Terminals
New Sources/Elevators
a) State Regulations
b) Recommended Controls
c) Best Controls w/o
dryer controls
d) Best Controls w/dryer
control
New Sources/Dryers
a) Without Standard
b) Best Controls
40
20
0
0
1115
625
43
35
24
9
15
0
172
172
172
172
55
55
140
140
140
140
57
48
105
105
105
105
65
55
12
12
12
12
65
65
5
5
5
5
10
10
-------
TABLE 6-21 , INCREMENTAL CAPITAL REQUIREMENTS FOR CONTROLS AT ALTERNATIVE CONTROL LEVELS
Model Plant
New Traditional
Country Elevator
Upgraded (25 car)
Upgraded (50-
100 car)
New High
Throughput
New Traditional
Inland Terminal
New Port Terminal
Total Fixed Assets (Including Controls) 0)
Before
Control
$ 610,000
267,000
506,000
1 ,030,000
6,360,000
15,900,000
State
Regulation
$ 654,000
339,000
624,000
1,137,000
6,679,000
16,325,000
Proposed Control
TFA
$ 683,000
380,000
679,000
1,187,000
6,776,000
16,416,000
% m
Increase*1 ''
4.4
12
9
4.4
1.5
0.6
Best Controls (w/o Dryers)
TFA
$ 730,400
438,000
757,600
1,263,100
6,843,000
16,424,000
IncreaseO)
12
29
21
n
2.5
0.6
Best Controls
(incl . Dryers)
TFA
$ 758,000
465,600
797,500
1,303,000
6,890,000
16,464,000,
Increase* '
16
37
28
15
\
3
0.9
CD
(2)
Fixed assests include storage equipment, receiving and handling apparatus, cleaners, driers, and all other physical assets
such as offices and parking facilities. The value of stored grain is not included in total fixed assets.
% increase for the pertinent level of control relative to state regulation.
tn
-------
explanation for this is that elevator operators would pursue the
opportunity to significantly reduce their transportation and handling costs
if they felt they could by-pass another elevator or terminal in their
shipping to the final market. For the upgraded country elevators that can
ship directly to the terminal, there are substantial savings in the total
distribution costs. These savings are assumed to overrid'e the incremental
capital burdens imposed for controls, with one exception, grain dryers. The
basis for this assumption is that the more serious competition for upgraded
elevators would be existing elevators, not inland or high-throughput terminals,
Country elevators are more numerous and tend to be closer to one another;
terminals are fewer and farther from other terminals.
6-55
-------
6.3.3 Grain Processors
6.3.3.1 Soybean Processing
Increasing worldwide demand for meat and the unreliability of
other high protein animal feed supplies has resulted in a high degree
of growth for the soybean processing industry, The value of shipments
for this industry increased from $1,5 billion in 1963 to $3.4 billion
in 1972, an increase of about 9,5 percent per year. It is expected
that worldwide demand for meat products will continue to grow dramatical-
ly with a correspond I ngly tiranriatic growth In demsnd for soybeans. Over
the next five years, ten additional plants are expected to be built.
Table 6-22 illustrates the financial impact of pollution control
on a model soybean processing plant. This model is representative of
the larger mills to be built in the future. Case 1 represents the
impact of pollution controls for a new source to comply with State
regulations in the absence of new source performance standards. Cases 2
through 4 represent the impact for alternative control levels analyzed
here for new source performance standards.
In comparing Cases 2-4 with Case 1» the percentage of control
capital relative to fixed assets increases from 1,2 percent to the
maximum of 2,4 percent for Case 4. Annualized control costs as a
percentage of profits before taxes increase from 2 percent for State
regulatory compliance to 3.9 percent for Case 4» the worst case.
The price increase for the new source, under the worst case, required to
maintain return on total assets is quite small - 0.15 percent versus
0.07 percent for the State regulation.
6-56
-------
Table 6-22. Model Soybean Processing Plant
Pre-Control Financial Data
Fixed Assets
Total Assets
Sales Revenue
Profit before Taxes
Return on Total Assets (ROI)
$11,660,000
$29,930,OOQm
$66,000»000UJ
$ 2,000,000
6.7X
Control Capital
Annual i zed Control
Costs
Control Capital *
Fixed Assets
Annuali zed Costs *
Profit before Taxes
Price Increase to
Maintain ROI
Case 1
State
Regulation
$140,400
$ 39,500
1.295
2.0%
0.071
Case 2
Recommended
Controls
$227,800
$ 68,000
2.01
3.41
0.131
Case 3
Best Controls
(No Dryers)
$248,800
$ 71,600
2.U
3.61
0.13%
Case 4
Best Controls
(Incl. Dryers)
$276,400
$ 77,200
' 2.4%
3.91
0.15%
' 'Annual Throughput, 11.1 MM Bushels/yr.
Source for financial data: Arthur D. Little (updated to 1976 dollars).
6-57
-------
In view of the results presented 1n Table 6-22• no adverse impact
on industry growth is judged to be caused by adoption of new source
performance standards, A new source's profitability is expected to be
maintained through a price increase of about 0.1 percent beyond current
prices sufficient to maintain ROI for plants in compliance with State
regulations. The additional capital requirements are considered
reasonable.
6,3,3.2 Wheat Mill ins
The domestic wheat milling Industry has not grown over the past
few years. The demand for flour has decreased on a per capita basis
because of the consumer's shift to meat as he has become more affluent.
Therefore, excess milling capacity exists, leaving little incentive for
adding storage or throughput capacity.
Table 6-23 illustrates the financial impact of pollution control
on a model wheat n'lling plant. Case 1 represents the impact of pol-
lution control for a new source to comply with State regulations in
the absence of new source performance standards. Cases 2 and 3
represent the impact of alternative control levels analyzed here for new
source performance standards. Wheat mills normally do not require
grain drying; hence, the absence of a dryer vacuum-cleaned screen require-
ment in this model analysis.
In comparing Case 1 with Cases 2 and 3, incremental control capital
requirements of $86,600 (Case 2) and $108,400 (Case 3} are only
approximately 3 percent (as a percentage of total fixed assets) greater
than for Case 1. Annual!zed control costs of $68,000 and $71,600,
6-58
-------
Table 6-23. Model Wheat Mill
Pre-Control Financial Data
Fixed Assets
Total Assets
Sales Revenue
Profit before Tax
Return on Total Assets (ROI)
$3,480,000
$5»670sOOO
$11,342,000
$ 530,000
9.3%
Control Capital
Annual i zed Control
Costs
Control Capital *
Fixed Assets
Annual i zed Costs *
Profit before Taxes
Price Increase to
Haintain ROI
Case 1
State
Regulation
$140,400
$ 39,500
4. OX
7.5%
Q.46«
Case 2
Recommended
Control s
$227,800
$ 68,000
6.52
12.8%
0.79%
Case 3
Best Controls
(No Dryers}
$248,800
$ 71,600
7.1%
13.5%
0.841
"'Annual Throughput, 2.78 MM Bushels/yr,
Source for financial data: Arthur D. Little (updated to 1976 dollars),
6-59
-------
measured as a percentage of profits before taxes, are approximately
5 percent greater than for Case 1. Price increases required to maintain
a historical ROI of 9.3 percent are approximately 0.8 percent, or 0,4
percent more than prices required to maintain profitability for plants
in compliance with State regulations.
If there were growth in the wheat milling industry, the conclusion
inferred from Table 6-23 is that no adverse impact will result from
adoption of the new source performance standards. The price increase
of 0.4 percent and additional capital requirement of 3 percent are
judged to be reasonable.
6.3.3.3 Wet Corn Milling
Demand for wet corn mill products, primarily corn starch, has
increased at approximately 4-5 percent per year over the last decade.
No change in this growth rate is expected over the next five years.
However, ample wet corn milling capacity exists, which suggests little
need to add to existing capacity over the next five years.
Table 6-24 illustrates the financial impact of pollution control
for a model wet corn milling plant. Case 1 represents the impact of
pollution control for a new source to comply with State regulations in
the absence of new source performance standards. Similar to wheat
milling, the typical wet corn milling plant has no grain drying facility.
Therefore, only two levels of control (Cases 2 and 3) are analyzed
here for new source performance standards.
In comparing Case 1 with Cases 2 and 3» incremental control
capital requirements of $86i600 (Case 2) and $108,400 (Case 3) are
only approximately 0.25 percent (as a percentage of total fixed assets)
6-60
-------
Table 6-24. Model Wet Corn Mill
Pre-Control Financial Data
Fixed Assets
Total Assets
Sales Revenue
Profit before Tax
Return on Total Assets (ROI)
$41,330,000
$54,070,000,,v
$41»594»QOOU)
$ 2,650,000
4.9%
Control Capital
Annualized Control
Costs
Control Capital •*
Fixed Assets
Annual iztd Costs *•
Profit before Taxes
Price Increase to
Maintain ROI
Case 1
State
Regulation
$140,400
$ 39 » 500
0.341
1,5%
o.m
Case 2
Recommended
Control s
$227,800
$ 68,000
0.55%
2.6*
0.191
Case 3
Best Controls
(No Dryers)
$248,800
$ 71,600
0.601
2,7%
0.201
* •'Annual Throughput, 10 MM Bushels/yr.
Source for financial data: Arthur D. Little {updated to 1976 dollars).
6-61
-------
greater than for Case 1. Annualized control costs of $68,000 and
$71,600, measured as a percentage of profits before taxes, are
approximately 1 percent greater than for Case 1. Price increases
required to maintain historical ROI are on the order of 0.1 of 1
percent more than for a new plant in compliance with State regulations.
If there were growth in the wet corn milling industry, the con-
clusion inferred from the data in Table 6-24 is that no adverse impact
will result from the adoption of new source performance standards.
Incremental capital requirements and price increase required to sustain
historic profitability are judged to be negligible.
6.3.3.4 Dry Corn Mi 11 inn .
Dry corn mills produce grits, cornmeal, corn flour, and a base
for breakfast cereals. Production has remained nearly the same for
the last decade; per capita consumption of all flour products has
fallen as people substituted meat for baked goods. The industry has
ample capacity, and per-capita consumption is expected to be level or
slowly decreasing. Therefore, there is no incentive to expand capacity.
Table 6-25 illustrates the financial impact of pollution control
for a model dry corn mill. Case 1 represents the impact of pollution
control for a new source to comply with State regulations in the
absence of new source performance standards. Cases 2 through 4 represent
the impact for alternative control levels analyzed here for new source
performance standards.
6-62
-------
Table 6-25. Model Dry Corn Mill
Pre-Control Financial Data
Fixed Assets
Total Assets
Sales Revenue
Profit before Taxes
Return on Total Assets (ROI)
$3,480,000
$5,67Q,GOQm
$9,793,000U'
$ 530,000
9.3%
Control Capital
Annuali zed Control
Costs
Control Capital *
Fixed Assets
Annual i zed Costs *
Profit before Taxes
Price Increase to
Maintain ROI
Case 1
State
Regulation
$140,400
$ 39,500
4.0%
7.51
0.46%
Case 2
Recommended
Controls
$227,800
$ 68,000
6.5%
12.8*
0.791
Case 3
Best Controls
(No Dryers)
$248,000
$ 71,600
7.135
13.51
0.841
Case 4
Best Controls
(Incl. Dryers)
$276,400
$ 77,200
7,9%
14.6%
1 . 051
' ^Annual Throughput, 3.35 MM Bushels/yr.
Source for financial data: Arthur D. Little (updated to 1976 dollars).
6-63
-------
In comparing Cases 2-4 with 1, the percentage of control capital
relative to fixed assets increases from 4 percent to the maximum of
7.9 percent for Case 4. Annyalized control costs as a percentage of
profits before taxes increase from 7.5 percent for State regulatory
compliance to 14.6 percent for Case 4, the worst case. Price increases
for the new source, under the worst case, required to maintain return
on total assets are small - approximately 1 percent versus approximately
0.5 percent for the State regulation.
If growth were to occur in the dry corn milling industry, the
incremental impact incurred by adoption of new source performance
standards would not present a barrier to this growth, A price increase
of 0,5 percent to pay for the incremental controls for the most
stringent level of controls and to maintain historic profitability appears
to be reasonable for a new source. The same conclusion holds for the
incremental capital requirements.
6.3.3.5 R1ce Milling
The rice milling industry serves as a processor to the rict farming
industry by cleaning and dehulllng rough rice to produce whole grain
milled rice. For the last several years, more than 60 percent of
total domestic milled rice production has been exported. Since
domestic per capita rice consumption has been stable for years and is
expected to remain so in the future, any increases in domestic milled
rice production will occur only as a result of increased International
demand. This international demand will be expected to increase due to
expanding population in countries where rice is a dietary staple. The
United States remains one of the few areas in the world where agricultural
6-64
-------
production can be expanded rapidly. Between 1972 and 1974, Hce prices
jumped from $5 per hundred pounds to $18 per hundred pounds for rough
rice. Such an increase provided an incentive to expand grain production.
However, the stability of these high prices and demand In overseas
markets remain such an uncertainty that projection in future capacity
growth is difficult. The requirements of coordinating marketing
expertise, commodity trading sophistication, and capital investment
planning to manage the risk of selling rice in the international markets
will limit future growth to larger firms.
Table 6-26 illustrates the financial impact of pollution control
on a model rice mill. Case 1 represents the impact of pollution
controls for a new source to comply with State regulations in the absence
of new source performance standards. Cases 2 through 4 represent the
impact for alternative control levels analyzed here for new source per-
formance standards.
In comparing Cases 2 - 4 with Case 1» the percentage of control
capital relative to fixed assets increases from 3.9 percent to the maximum
of 7.6 percent for Case 4. Annualized control costs as a percentage
of profits before taxes increase from 6,2 percent to 12.1 percent for
the worst case. Price increases for the new source, under the worst
case» required to maintain return on total assets are relatively small -
0.59 percent versus 0.3 percent for the State regulation.
In view of the results presented in Table 6-26 » no adverse Impact
on any industry growth is believed to occur with adoption of new
source performance standards. A new source's profitability is expected
to be maintained through a price increase of some 0.3 percent beyond
6-65
-------
Table 6-26. Model Rice Mill
Pre-Control Financial Data
Fixed Assets
Total Assets
Sales Revenue
Profit before Taxes
Return on Total Assets (ROI)
$3,630,000
$7,730,000m
$17,010»OQQIU
$ 636,000
8.2%
Control Capital
Annuali zed Control
Costs
Control Capital *
Fixed Assets
Annuali zed Costs *
Profit before Taxes
Price Increase to
Maintain Wl,
Case 1
State
Regulation
$140,400
$ 39,500
3.92
6.2%
0.30*
Case 2
Recommended
Controls
$227,800
$ 68,000
6.31
10.71
0.51%
Case 3
Best Controls
(No Driers)
$248,000
$ 71,600
6.81
11.3%
0.541
-Case 4
Best Controls
(Incl. Dryers)
$276,400
$ 77,200
7.6*
12.11
0.591
"^Annual Throughput, 2.88 MM Bushels/yr.
Source for financial data: Arthur D. Little (updated to 1976 dollars).
6-66
-------
the price required to maintain RQI for plants in compliance with State
regulations. The additional capital requirements are considered reasonable.
6.3.3.6 Commercial Rice Drying
In 1967, more than 400 establishments solely engaged in drying and
storage functions - no milling involved - were in operation. This
number includes commercial as well as on-farm rice dryers. Approximately
219 of these establishments are commercial rice dryers located in
Arkansas, Mississippi, Texas, Louisiana, and California. Any increase
in rough rice production would require more rice drying facilities.
Due to potential expansion in domestic rice production, as discussed
1n the previous section, growth potential exists for commercial rice
drying.
Table 6-27 illustrates the financial impact of pollution controls
on a model rice dryer. Case 1 represents the requirements for a rice
dryer to comply with "State regulations, in the absence of new source
performance standards. Cases 2 through 4 represent the financial impact
for alternative control levels analyzed for new source performance
standards.
In comparing Cases 2-4 with Case 1, the percentage of control
capital relative to total fixed assets increases from 3.3 percent to
6.0 percent for best controls without dryer vacuum-cleaned screen require-
ments. The screen filter requirement on dryers increases control capital
to 8,7 percent. What is lore important is revealed in the comparison of
the annual!zed costs to profits before taxes, particularly with the
understanding that any new commercial rice dryers are in competition
with rice mills, as well as with existing commercial rice dryers in
compliance with State regulations.
6-67
-------
Table 6-27, Model Commercial Rice Dryer
Pre-Control Financial Data
Fixed Assets
Total Assets
Sales Revenue
Profit before Taxes
Return on Total Assets (ROI)
$1,450,000
$2,100,000m
$ 298,000IU
$ 75,400
3.6%
Control Capital
Annual! zed Control
Costs
Control Capital *
Fixed Assets
Annual! zed Costs *
Profit before Taxes
Price Increase to
Maintain ROI
Case 1
State
Regulation
$48,400
$ 8,800
3.3%
11.7%
3.51
Case 2
Recommended
Controls
$7S,300
$16,700
5.5%
22. 1%
6,61
Case 3
Best Controls
(No Drying)
$86,300
$17,900
6.0%
23. 7%
7.Q%
.Case 4
Best Controls,
(Incl. Dryers)
$126»200
$ 26,600
8.7%
35.31
10.4%
0)
Annual Throughput, 0.77 MM Bushels/yr.
Source for financial data: Midwest Research Institute (updated to 1976
dollars).
6-68
-------
A closer examination of the model in Table 6-27 shows that the
commercial rice dryer with recommended controls would have to Increase
Its price by 1.2 cents per bushel (41.36/bu) relative to hfs com-
petition in compliance with State regulations {4Q,H/bu}, The new
comnercial rice dryer faces a problem both with direct competition
from existing commercial rice dryers and his customers, the rice millers,
who have the available option of purchasing the grain directly from
rice farmers and performing their own drying and storage functions. In
particular, new rice mills, which have to Incur an incremental cost of 1
cent per bushel ($68,000 - $39,500, a difference between Case 1 and
Case 2 shown in Table 6-26) wore than thiir rice milling competitors,
would be more reluctant to take the higher price the new commercial
rice dryer needs to maintain profitability.
For Case 4, the financial impact for the commercial rice dryer
gets worse. Annual1zed control costs as a percentage of profits
before taxei are 35.3 percent versus only 11.7 percent for
the source in compliance with the State regulation. The commercial
rice dryer would find that this cost would definitely be unaffordable.
Even the new rice mill confronted with best control technology and
dryer screen requirement would find his drying costs approximately 1
cent per bushel less expensive than the commercial rice dryer (0,2
cent/bushel for dryer control from Table 6-19 versus 1.13 cents/
bushel for dryer control from Table 6-27).
In view of the data presented in Table 6-20 and the previous
discussion, it is doubtful that Independent commercial rice dryers will be-built
6-69
-------
with the adoption of new source performance standards. These dryers
which would be in direct competition with existing dryers and mills would
find it extremely difficult to maintain historic profitability.
On the other hand, farm co-operatives and rice millers who would
consider the rice drying function as a service function, not a profit
venture, would still find it necessary to build dryers. The Increased
costs for handling and drying would be passed back to the rice farmer.
Possible consequences of this action might be the encouragement of building
larger dryers on the part of the co-operatives, more on-farra dryers (non-
commercial), and more backward integration of mills into drying and
storage.
-------
6.3.4 Size Cut-Off Analysis jElevators)
The purpose of this section is to develop the economic basis for
exemption of a category of grain elevator facilities for which the
recommended controls are inappropriate. In the rationale section.
Chapter 8, the exemption for these facilities will be defined on
the basts of size cut-off defined in terms of leg capacity (bushels per
hour).
The economic analysis of controls in Section 6.3 was conducted on
the basis of annual throughput as the most meaningful parameter for
measurement of the impact of incremental control costs. The size cut-off
then will be determined in this section in terms of annual throughput.
This will then be translated in Chapter 3 into a size cut-off in terms
of leg capacity.
The arguments underlying a size cut-off are two-fold. First, normal
economics of scale on the capital cost of control systems suggest that
such costs are higher on a unit basis for smaller facilities. In this
regard, the smallest model in the economic analysis was the
country elevator with an annual throughput of 1 million bushels.
Second, minimum ventilation requirements are dictated by the physical
dimensions of the unloading pits (for standard sized trucks) and loading
facilities (for standard sized railroad cars). It is doubtful that the
ventilation requirements for elevators can be reduced to any extent
below those specified for the 1 million bushel per year country elevator.
In this analysis then, the total annualized costs for recommended
controls for the 1 million bushel per year country elevator is the
basis for calculating unit costs (| per bushel) for various elevator
6-71
-------
sizes less thin 1 million bushels per year throughput. The only element 1n
these annualized costs that may vary with throughput is energy consumption,
which constitutes a very minor fraction of the costs. Other costs --
capital charges, taxes, insurance, maintenance and labor — are assumed to
be constant. The curve for these costs is shown in Figure 6-1.
The approach taken for a size cut-off exemption is the use of a
conventional breakeven analysis. This technique is used to circumvent
those subjective judgments that would enter into a rate-of-return (ROI)
type of analysis. The judgments would have to be made because - (1) the
variation in pre-control profit margins for small elevators, (2) the
extent to which the costs of State regulations have been passed on, or
absorbed by, existing country elevators, and {3} the minimum ROI accepted
by individual elevator operators - are all unknown. Therefore, the
pre-control profit margin (2.1 i per bushel) in the ADL analysis was
arbitrarily chosen as the breakeven point for a shutdown decision for
country elevators.
Referring to Figure 6-1, a horizontal line representing the 2.1
cent pre-control profit is drawn to intersect the aforementioned control
cost curve. The intersection point, or the breakeven point, for this
analysis occurs at 720,000 bushels per year. As an approximation for the
purpose of regulatory decision, the value of 700,000 bushels per year
throughput should be used.
6-72
-------
US
Ol
o.
•*»>
in
•M
tn
o
"O
01
N
7.5
7.0
6.5
6.0
5.5
5.0
4.5
4.0
3.5
^ 3.0
Figure 6-1. Control Costs as a Function of
Annual Throughput.
=5
C
2.0
1.5
1.0
0.5
0
Profit per,Bushel
(Before Control)
I Size Cutoff: 720,000
I Bushels/Year
0,2 0.4 0,6 0.8
Annual Throughput (Bushels per Bushel)
1.0
6-73
-------
REFERENCES
1. "Economic Impact of Potential Pollution Abatement Costs on the
Grain Elevator Industry and Selected Grain Processing Industries",
prepared by Arthur D. Little, Inc., for the U.S. Environmental
Protection Agency, Contract 68-02-1349, Task No. 3, April 1975,
page 14,
2. Ibid., page 28.
3. Ibid, pg, 34.
4. Ijbid, pg. 47.
5. Ibid., pg 47.
6. Ibid., pg. 52.
7- Ibid., pg. 53.
8. Ibid., pg. 94,
9- Ibid., pg. 245.
10. Ibid., pg. 276.
11. Ibid., pg. 254.
12. U.S. Department of Agriculture, Economic Reserach Service, An In-House
paper.
13. Ibid., pp. 332-347; pp. 399-479.
14. ADL, op. cit., pp. 121-141.
15. Private conmunication: Letter from Leroy Funk of CEA-Carter-Day
Company (Minneapolis) to F. L. Bunyard, OAQPS, EPA, March 17, 1975.
16. Private communication: Letter from F. L. Bunyard, OAQPS, EPA to
Richard Noland, of H. C. Wiedenmann and Son, Inc. (Kansas City),
March 7, 1975.
17. Private communication: Letter from Richard Noland, H. C. Wiedenmann
and Son, Inc., to F. L. Bunyard, OAQPS, EPA, March 13,1975.
18. Trip report by Sims L. Roy, Jr. on Inspection of Cargill Port Terminal
Elevator, Savage, Minnesota, February 4, 1976,
19. Private communication: Telephone call from F. L. Bunyard, OAQPS, EPA,
to Don Enge, Department of Engineering, Cargill, Inc., March 2, 1976.
6-74
-------
20. ADL, op. cit., pp. 55-56.
21. ADL, Revised Summary Report on Impact of New Source Performance
Standards upon New and Modified Grain Elevators, Dryers, and
Cleaners, October 1, 1975,
22. ADL, loc. cit., April 1975, pg. 78.
23. I bid. . pg. 75.
24. Private communication: Telephone conversation, F. L, Bunyard,
QAQPS, EPA, to Phillip Kruzick, Winamac Construction Company,
Winamac, Indiana, March 1976.
25, Private communication: Telephone conversation, F. L. Bunayrd,
OAQPS, EPA to L. J. Allen, Sales Manager* Ruttmann Companies,
Upper Sandusky, Ohio, March 1976.
26 • ADL, loc. cit., October 1, 1975, pp, 224-225.
6-75
-------
7. ENVIRONMENTAL EFFECTS
The purpose of this chapter Is to Identify, quantify and
evaluate the posttive and eegative environmental impacts of the
alternative control systems presented in Chapter 4 for grain
elevators. Three alternative control systems have been evaluated.
System 1 represents control to levels of typical state standards
(no screen [filter] on column dryers, 20-30 mesh screen on rick dryers
and 901 efficient cyclone control). System 2 represents control
levels achieved with 99.9% efficient fabric filter control, no screen
(filter) on column dryers and 50 or finer meshtvacuum-cleaned screen
on rack dryers. System 3 represents control levels achieved wtth 99.9%
efficient fabric filter control, vacuum-cleaned screens (filters) on
column and rack dryers and total enclosure of the operations. These
control systems are described in detail in Chapter 4. The impacts on
total solid waste handling and disposal, nofse and radiatfon, and energy
requirements for the alternative systems are discussed. Both
primary and secondary impacts are considered. Primary impacts are
those directly attributable to each alternative control system.
Secondary impacts are indirect or induced impacts which arise from
the application of these systems. In general, by using one of the
alternative control systems for the affected facilities at grain
elevators, there will be beneficial primary impacts on ambient air
quality and adverse Impacts on solid waste handling and
disposal and energy demand. No impacts on water treatment or supply
are anticipated because dry type collectors are used in both alternative
control systems. Impacts due to an increase in noise as a result
7-1
-------
of the use of one of the alternative control systems are possible,
but have not been quantified. The Agency assumes that any increases
will be negligible when compared to existing levels. No adverse
radiation impacts are anticipated as a result of the proposed standards,
A summary of the anticipated secondary environmental impacts
associated with the alternative control systems is presented in
Table P»l. Impacts on air quality, water supply and treatment,
solid waste disposal and energy consumption are identified. These
impacts will be discussed in more detail later in this chapter.
7.1 AIR POLLUTION IMPACTS
7.1.1 Primary Impacts
The primary impacts that can be attributed to the use of the
alternative control systems can be measured by the reduction in
total mass emissions of particulate matter and fay the reduction
in the maximum predicted ambient air concentration due to these
emissions, Grain elevators controlled to the levels
specified by typical state standards were used as the baseline
to which the impacts due to the proposed standards were compared.
These emission values are summarized 1n Chapter 4 as Control
System No. 1. Emission rates were then determined for facilities
controlled with the alternative control systems.
7.1.1,1 Mass Emissions
The particulate matter mass emission levels were calculated in
terms of pounds of particulate matter emitted per year for various
model plants. The total annual particulate matter emissions for the
7-2
-------
*•!
I
UJ
Table 7-1, SECONDARY aWIR0ffl€NTAL IHPACTS OF INDIVIDUAL CONTROL TECHNIQUES OVER SIP
AFFECTED
FACILITY
TRUCK
LOADING/UNLOADING
RAILCAR
UNLOADING
mo SHIP
UNLOADING
GRAIN
HANOLIN6
6RAIN
DRYIN6
BOXCAR
LOADING
HOPPER CAR
LOADINfi
AND SHIP
LOADING
CONTROL
SYSTEMS
System 3
System 2
System 3 and
System 2 are
fAwtical
r
Systera 3 and
System 2 are
I identical
System 3 and
i System 2 art
identical
System 3 i
System I
System 3
System 2
System 3
System 2
System 3 and
System 2 are
Identical
INCREMENTAL ADVERSE SECONDARY ENVIRONMENTAL IMPACTS
TO
AIR
IMPACT
Increased Emissions
From Power Plant
! Increased Emissions
: From Power Plant
Increased Emissions
From Power Plant
Increased Emissions
Fran Power Plant
Increased Emissions
From Power Plant
Increased Emissions
From Power Plant
None
Increased Emissions
From Power Plant
Increased Emissions
From Power Plant
Increased Emissions
From Power Plant
Increased Emissions
From Power Plant
Increased Emissions
From Power Plant
WATER
IMPACT
None
None
None
Norm
None
Hone
None
None
Nont
None
Hone
Hone
SOLID WASTE
1HPACT
Minimal Handling arw
Disposal Problems
Minimal Handling and
Disposal Problems
<1niffii1 Handling and
Disposal Problems
Minimal Handling and
Disposal Problems
Minima! Handling and
Disposal Problems
Minimi! Handling and
Disposal Problems
None
Minimal Handling and
Disposal Problems
Minimal Handling am
Disposal Problems
Hinlmal Handling and
Disposal Problems
Minimi! Handling and
Disposal Problems
Minimal Handling ant
Disposal Problems
ENERGY
CONSUMPTION
Increased Power
Requirements
Increased Power
Requirements
Increased Power
Requirements
Increased Power
Requirements
Increased Power
Requirements
Increased Power
Requirements
None
Increased Power
Requirements
Increased Power
Requirements
Increased Power
Requirements
Increased Power
. Requirements
Increased Power
Requirements
-------
model plants resulting from the application of the alternative control
systems previously discussed in this chapter and in Chapter 4, Emission
Control Technology, are presented in Table 7-2.
Five types of elevators were used to represent grain
elevators in calculating mass emissions and reductions and ambient
concentrations because the grouped model plants are similar in
emission characteristics. Country elevators and commercial rice
dryers represent model elevators 1 and 2; the high through-put
terminal elevator represents model elevators 3 and 4; the inland termi-
nal elevator represents model 5 elevators; and oort terminal elevators
represent model 6 elevators. Only one type of elevator was used to
represent all of the grain processors (except rice dryers) because
these plants have similar operations and emission characteristics.
Tht model elevators are described in detail 1n Chapter 6,
By combining the potential reductions for each facility, the
total reductions attributable to the alternative control system
and type of grain elevator can be determined. The incremental emission
reduction of the various alternative control systems at model plants
was compared to Alternative Control System 1. The incremental reductions
in total mass emissions achievable are suranarlzed in Table 7-3.
Table 7-3 shows that the emission reduction of Alternative Control
System 2 compared to System 1 ranges from 67 to 941 for the types of
elevators,.:add Control System 3 eonf»ared to Control System 1 results
in an emission reduction ranging from 86 to 96^ for the types of elevators.
7-4
-------
I
Wl
Facility 1
Through-put*
Country
Elevator
1 ,000,000
bu/yr
(Models 1, 2
and R1ce
Dryers )
Table 7-2,
Percent of
Process Through-put
Receiving
Truck
Handling
Turning
{once/yr)
Cleaning
Drying
Shipping
Truck
Rail
Barge
OVERALL
100
100
100
8
25
43
44
13
iRAIN ELEVATOR EMISSIONS FOR MOBIL afWffORS WTH ALTERNATIVE CONTROL SVSTEHS1
Percentage of
Particultte Uncontrolled Elevators
Emission Emissions Currently Using Emissions Mlth
Factors
Ob/T)
.6
3,5
2.0
».
S.O
4.0
0.6
.3
1.2
8.0
1000
(lb/yr)
18
105
60
12
30
7,7
4
5
241,7
Ho
Control
69
45.5
71
17
69
78
f 13
100
Cyclones
31
54.5
29
60
30
22
0
37 percent
Fabric
Filters
0
0
0
0
0
n
V
0
Current Control
(lb/yr) (1971)
13,000
53,550
44,400
3,960
21,600
6,190
3,170
4,680
150,000
System 1
(1b/yr)
1,800
10,500
6,000
1,200
3,850
770
400
500
25,020
System 2
(lb/yr)
18
105
60
12
3,850
7,7
4
5
4.061.7
System 3
(lb/yr)
16
195
14
11
1,280
7
4
5
1,472
collection efficiency
H1qh Through-
put Elevator
3.5 million
by/yr
(Models 3 and 4}
Receiving
Truck
Rail
Handling
Turning
Cleaning
Drying
Shipping
Truck
Rail
Barqe
40
55
5
100
0
22
10
17
48
35
.6
1.3
1.7
3.5
5
4
. ,6
.3
1.2
25.2
75.6
1.1
367,5
115.5
42
10.5
15
44
41
100
45
57
60
70
100
40
0
37
33
29
0
19
0
17
10
11
0
11 ,340
34,067
8,913
180,133
69,300
28,000
7,630
10,780
44,100
2,520
7,560
110
367, 5»
11,510
7,700
1,050
1,500
4,400
25
75.6
1.1
367,5
IIS
7,700
10. i
15
44
23
68
1
331
104
2,567
9.5
13.5
39.6
OVERALL
6.7
696.4
45 percent 394,263
collection efficiency
8,354
3,155
-------
Table 7-2. GRAIN ELEVATOR EMISSIONS FOR MODEL ELEVATORS HITH ALTERNATIVE CONTROL SYSTEMS (continued)
"-I
I
0>
Facility 1
Through-put8
Inland
Terminal
15,000,000
bu/yr
(Model 5)
Process
Receiving
Truck
Rail
Barge
Handling
Turning
Cleaning
Dryl ng
Shipping
Truck
Rail
Barge
OVERALL
Percent of
Through-put
40
55
5
100
0
22
10
17
48
35
Parti cu late
Emission
Factors
Clb/T)
.6
1.3
1.7
3.S
5.0
4.0
.6
.3
1.2
6.7
Uncontrolled
Emissions
1000
Ub/yr)
108
324
4.5
1,575
495
180
45. '
64.8
189
2,985
Percentage of
Elevators
Currently Using
No
Control
41
^ i
100
45
57
60
70
t\*
100
Cycl ones
40
"tw
0
37,
33
29
l-a
i ^
0
45 percent
Fabric
Filters
19
1 •*
0
17
10
11
0
Emissions With
Current Control
(Ib/yr) (1971)
48,600
146,000
38,200
772,000
297,000
120,000
32,700
46,200
189,000
1,689,700
System 1
tlb/yr)
10,800
32,400
450
1,570*
49,500
30,800
4,500
6,480
18,900
155,400
System 2
(Ib/yr)
108
324
4.5
1,570
495
30,800
45
65
189
33,600
System 3
tlb/yr)
97
292
4
1,413
446
10,270
41
59
170
12,792
collection efficiency
Port
Terminal
40,000,000
bu/yr
(Model 6)
Receiving
Truck
Rail
Barge
Handling
Turning
Cleaning
Drying
Shipping
Land
Ship
10
50
40
100
0
14.6
1.0
6
94
.6
1.3
1.7
3.5
5.0
4.0
1.2
1.2
72
780
816
4,200
876
48
86
1,354
24
39
63
38
74
30
32
22
44
26
46
29
15
18
0
19,500
210,000
226,000
1,770,000
571,000
23,000
66,000
1,036,000
7,200
780*
820*
4,200*
87,600
7,700
8,600
135,400
72
780
820
4,200
876
7,700
1,354
65
702
734
3,780
788
2,570
1,218
.OVERALL
6.8
8,232
53 percent 3,920,000
collection efficiency
252,300 15,802 9,857
-------
Table 7-2, GRAIN ELEVATOR EMISSIONS FOR MODEL ELEVATORS WITH ALTERNATIVE CONTROL SYSTEMS (continued)
Percentage of
Facility 1
Through-put*
Process
Storage
3,000,000
bu/yr
(wheat mill.
dry corn
mill, rtce
mill, soy-
Percent of
Process Through-put
Receiving
Truck 50
Ral 1 50
Handling 100
Drying 10
Participate
Emission
Factors
Clb/T)
.6
1.3
3.5 -
4.0
Uncontrolled
Emissions
1000
(Ib/yr)
27
58.5
315
36
Elevators
Currently Using
No Fabric
Control Cyclonts Filters
40 16 42
26 26 48
0 0 50
Emissions With
Current Control System 1
(Ib/yr) (1971) (Ib/yr)
36,000 |
fl ,000 31
19,000 19
,700
,850
»SOO
,230
System 2
(Ib/yr)
27
58.5
31 S
19,230
System 3
(Ib/yr)
24
53
284
6,410
bean processor,
wet corn mm)
OVERALL
4.8
436.5
66 percent
collection efficiency
146.000 59
,280
19,630
6,771
•Typical state standard requires use of a fabric filter control device,
aAverage volume of 33 bushels per ton assumed.
-------
Table 7-3. ESTIMATED ANNUAL PARTICIPATE MATTER EMISSION REDUCTION
FOR PLANTS WITH ALTERNATIVE SYStEMS
TO TYPICAL STATE
1 (Ib/yr)
ALTERNATIVE CONTROL
(I
SYSTEM 2
(I EMISSION REDUCTION)
SYSTEM 3
(1 million by/
yr)
i & 2 i
RICE
20,900
(84)
23,500
(94)
HI6H THROUGH-PUT
ELEVATOR
(3.5 million bu/
3 & 4)
28,400
(77)
33,600
(91)
TERMINAL
ELEVATOR
(15 million bu/
yr)
(MODEL 5)
121,800
(78)
142,600
(92)
PORT TERMINAL
ELEVATOR
(40 million bu/
6)
236,500
(94)
242,400
(96)
ELEVATOR,
PROCESSOR
(3 million bu/
yr)
EXCLUDING RICE
DRYERS
3i»680
(6?)
52,480
(86)
7-8
-------
Taking into account the average number of new, modified, and
reconstructed plants that are expected to be built or modified each year,
the Industry-wide reduction in particulate emissions can be calculated,
The accumulated industry-wide particulate emissions reduction for
various alternative centre! systems through 1980 are presented in
Table 7-8.
7.1.1.2 Ambient Concentrations
For the purpose of evaluating the air pollution impacts
associated with alternative control systems, studies were performed
on model grain elevators. The;;models chosen were of average
design and layout and include, in various combinations, the eieiht
affected facilities controlled by the proposed standards. Meteorolog-
ical modeling was performed for five types of grain elevators; these
types of elevators are described in Section 7.1.1,1,
Maximum ground-level concentrations of particulate rotter were
determined for the emission rates corresponding to each control
2
system and type of grain elevator.
The dispersion estimates were made through application of the
single source (CRSTER) model. The model generates estimated 1 hr,
24 hr and annual ground-level concentrations. The meteorological
data used fn the analysis were chosen to represent the climatology
at grain elevator facilities located where effluent dispersion
would be relatively poor. All meteorological data were from 1964.
For all types of grain elevators except port terminals, the meteorological
data were from National Heather Service Stations in the heart of the
7-9
-------
grain belt. For the port facilities surface meteorological data
from the Great Lakes, Gulf and Pacific Coast locations were
considered and data from Houston, Texas, and Portland, .Oregon
were selected. Particulate matter concentrations were calculated
for 24-hour and annual averages at distances of 0.3 km, 2 km
and 20 km from the center of the elevator. The model assumes that
all emissions are emitted over a horizontal area of approximately
100 x 250 meters.
A detailed description of the meteorological methodology
and the stack heights and emission rates upon which thess calculations
are based is presented in Appendix D.
fhe results of the study that was performed to evaluate maximum
ground-level concentrationsidue to emissions from grain elevators
are presented in Table 7-4. With each type of plant and meteorological
condition, the particulate concentration decreased predictably with
decreases in emission rates and with distances away from the center
of the elevator. It is evident from Table 7^4 that ambient particu-
late concentrations at elevators which use rro control device far
exceed the primary ambient air quality standards, especially at the
shortest downwind distance for which concentrations were estimated
(0.3 km, measured from the center of the facility). Large emission
rates in combination with aerodynamic downwash of the effluents
are responsible for the high ground-level concentrations.
Control to the level of Alternative Control System 1 (typical
itate Standard) reduces the emissions significantly; however, the
maximum 24-hour primary standard of 260 pg/m3 is exceeded at a distance
7-10
-------
Table 7-4. tstiwrco MAXIMJM MVIENT «ouw UYEI W«TJICIJUTE COXCCNTMTIDR
or
ELEVATOR ,
um or COKTKOI
Hsne * Hont
1 « S*$te« I
2»Sy*w« 2 tmssias wm
3 «
RTIXATtD XMIMUN AMBIOT GMUND UYEL
PUTICClATt COHCEfiTRAIIOh (s.9*»3)*
1, tauwtry Elevator
(KxMi T, Z and Wee
Btyeifl
Z, Htg»> Through-nut Elevator
(Jtoitlf 3 and 4}
i. Inland TtratRal Ele*aWr
5}
4, Port final nil Elevator
(MMfe! 6)
9. Stwjff Elevator, Processprs
(Meat Mil. dry corn trill,
rtee «111, soybean p««»««-
S«r, we* corn art 11)
**
**
1
2
3
None
1 *
2
3
MOM
1
2
"3
Hone
, 1
^
3
Now
1
2
1
tS/WC}
It,?
3.3
1.2
.SS
47.6
4. 68
1.31.
i.oz
213.3
i,7
3.1S
1.86
399.i
8.64
3.44
I.JS
35. 8
i,77
lf»
1,1
IWLKMllIK< 111
14 nr*.
Annual
24 hrs.
24 krs.
Jbwual
Z4 Mrs,
Annual
24 hn.
Annual
24 hrs.
24 Nri.
Annual
Annual
24 hr*.
Anna* 7
24 hrs.
Annual
24 hrs.
Annual
6»
24 hrs.
24 Bfs.
Hmvat
24 hrs.
Aniwal
24 hn.
24 hrs,
Awwal
24 hn.
Afnwa1
24 hrs.
Annual
24 hn.
9.3 KB
1008
79
1S0
11
65
S
19
2
»1QOQ
193
250
19
120
9
4
>1000
390
X
140
It
70
6
>1000
348
m
140
it
12
* 120
330
%
•1
S
41
3
Z Ka
100
9
1»
2
C
3
ISO
25
2
IE
S
*1000
94
46
4
17
I
10
cl
>1000
lao
34
4
14
2
9
16
n
4
to
6
2QKD
10
f
I1
S
23
1
2
1
•si
«1
<1
100
$
4
2
:!
140
a
3
i
, 2M nfcro
-------
of 0,3 km from the center of the facility for the Inland terminal elevator,
port terminal tlevator and storage elevator at processors. Control to
the level of Alternative Control System 2 (proposed NSPS) does riot cause
the primary or secondary ambient air quality standard for paniculate
matter to be exceeded at any distance. Control to the level of Alternative
Control System 3 (best control technology not considering cost) will
reduce the maximum ambient particulate concentrations below that
resulting from the use of System 2. The individual control techniques
that comprise the alternative control systems are described in Chapter 4,
Compared to the maximum ambient particulate matter concentration
that results from control to typical state standard levels. Alternative
System Z results in a reduction of the 0,3 km distance 24-hour
average by 52 to 76 percent for the various model plants and
Control System 3 level results In a reduction ranging from 78
to 88 percent. Control Systems 2 and 3 both reduce the maximum
ambient air concentrations significantly.
7.1.2 Secondary A1r Impacts
Secondary Impacts on air quality win arise as a result of
the electrical requirements of certain control techniques that
are used to control grain elevator emissions. Additional emissions
of partlculate matter, NOX and 502 from the coal-fired power plant
supplying the electrical energy can be anticipated. Based on the new source
performance standards for coal-fired power plants, promulgated
in the Federal Register on December 23, 1971 (36 FR 24876}t the
additional emissions can be estimated at 0.1 lb of particulate matter,
7-12
-------
0.7 lb of NOX and 1.2 Ib of S0£ per TO6 Btu produced. The amount
of additional pollutant emissions therefore are small when compared
with the large reductions in participate matter emissions achieved
by implementation of the proposed control systems.
7.2 WATER POLLUTION IMPACT
No liqyid wastes will require treatment or disposal as a
result of the implementation of any of the alternative control
systems because all alternatives involve only dry type partlculate
matter collection devices,
7.3 SOLID WASTE IMPACT
The additional particulate matter collected as a result
of the implementation of the proposed standard is expected to
create minimal adverse solid waste impacts. It is estimated
that currently 68 percent of the particulate matter collected by
emission control devices at elevators is returned to the grain,
30 percent is sold for use in feed manufacturing, and 2 percent
is disposed of as solid waste. The additional particulate matter
collected 6y a rare efficient control device would either he
sold for feed or landfilled.
Elevator operators prefer to return the particulate matter
to the grain to minimize the difference between the amount of grain
purchased and sold (shrink). However, there is an economic limitation
to the amount of particulate matter that can be recycled, since it
degrades the quality of the grain.
7-13
-------
There is good potential for the increased use of participate
matter from grain in feed production, according to the United States
Department of Agriculture and feed manufacturers. Cattle feeds
must contain about 7 percent roughage which can be supplied by hay,
straw, grasses, corn cobs or particulate matter from grain. An
added advantage of using this particulate matter is that it may
contain as much as 18 percent protein. The market for any one
elevator, however, is dependent upon its location relative to
feed manufacturers and other sources of roughage. Transportation
costs are hiqhj therefore, it is not profitable to transport the
particulnte matter very far. The value of the particulate matter
also fluctuates with grain prices.
Approximately 2 percent of the collected particulate matter
2
is expected to be disposed of at sanitary landfills. This amounts
to about .13 pound per ton of grain. When compared to the amount
of particulate matter that must be disposed of at elevators
controlled to meet State regulations, there is a small adverse
solid waste impact with Systems 2 and 3. Compared to an uncontrolled
elevator, however, there is a beneficial impact. This occurs because
some of the large particles emitted from the operations at a completely
uncontrolled elevator will settle inside the building and on the property.
This particulate matter, which amounts to about 10 percent of the
uncontrolled particulate emissions or about 0.7 pound per ton of grain,
must then be cleaned up and disposed of. Table 7-5 shows the weight and
volume of particulate matter that must be disposed of by a typical
7-14
-------
Table 7-5. SOLID WASTE DISPOSAL WITH ALTERNATIVE CONTROL SYSTEMS
Facility and
Through-put
COUNTRY ELEVATOR
1 minion bu/yr
1 , 2 AND RICE
HIGH THROUHG-PUT ELEVATOR
3.5 million bu/yr
(MODELS 3 AND 4}
INLAND TERMINAL
15 million bu/yr
(MODEL 5}
PORT TERMINAL
40 minion bu/yr
(MODEL 6}
PROCESS
3 million bu/yr
(WHEAT MILL, DRY CORN MILL,
RICE MILL, SOYBEAN PROCESSOR,
WET CORN MILL)
Uncontrolled^ System l(c) System 2^
El 6V3tOF ... --T -.,„-, - -i ----- -,
Ib/yr *"""ft3/yr(b) Ib/yr ft3/yr(b) Ib/yr ft3/yr^
24,000 1,200 4S334 217 4,753 238
69,640 3,480 13,190 660 13,760 690
298,500 14,930 56,590 2,830 59,030 2,950
823,200 41,160 159,590 7,980 164,340 8,220
43,650 2,180 7,540 380 8,340 420
a Assumes 10 percent of uncontrolled pprti cul ate emissions settle on property and are disposed
b Assumes a partial! ate matter density of 20 1bs/ft3.
C Accim»«: 9 nerremfr r»f rn*nprte>d nwtprial i<; disnn^pd of.
System 3^°'
b) Ib/yr ft3/yrC
4,805 240
13,860 690
59,440 2,970
164,440 8,220
8,590 430
of.
-------
size elevator. The particulate matter has a bulk density of about
20 pounds per cubic foot.3 Compared to the amount of waste disposed
of at a landfill for an elevator controlled to levels of Alternative
Control System 1, the additional solid waste that must be disposed
of by control to levels of Systems 2 and 3 ranges from 3 to 10 percent
depending on the model plant. The amount of solid waste generated
by Systems 2 and 3 are approximately the same.
7.4 NOISE AND WDIATION IMPACT
The control devices and exhaust fans at grain elevators are
usually located oytside of buildings at either roof or ground level,
Although fans are noisy, they are already required for collection
systems now used to meet existing state regulations. Therefore,
any Federal standard will not introduce new noise problems but
may increase the existing noise levels if larger equipment is
required. This is considered to be negligible.
There are no known or anticipated radiation impacts at grain
elevators.
7.5 ENERSY IMPACTS
Enerny requirements for systems to control air pollution it tjraln
elevators are proportional to the volume of air that must be moved,
the pressure drop of the systems, and the "on-stream time" or
amount of time tach system operates.
Table 7-6 presents an estimate of the energy required to operate
model elevators of a typical size and the energy required to operate
alternative control systems at these elevators. The energy required
to operate a high efficiency cyclone collector 1s estimated to be
of the energy required to operate a fabric filter control
7-16
-------
Table 7-6. WLCULATEB TO ALTfwwrivi CONTROL smew3
Facility
and
Process
Country Elevator
(1 million bu/yr)
Receiving and
Shipping
Handling
Dryer
Aeration
High Through-
put Terminal
(3.5 million
bu/yr)
Inland Terminal
(15 million i»u/
yr)
Receiving
Truck
Rail
Shipping
ioxcar
Hopper Car
Cleaning
Dryer
Scale and Surge
Bins
Handling
Aeration
Operating
Time
(hr/yr)
1,000
2,000
500
1,000
1,000
500
200
300
SCO
2,200
1,000
2,500
1,200
Process
Energy
Required
ta Operate
Elevator
< «W/yr )
12,500
132,000
50,000
62, OOP
"scwy '^CJCJe" .
211,000
896,000
«?,QQO
.
-
.
12.SOQ
408,000
-
1,100,000
750,000
fjSff.KM)
Air Volume
Through Control
Systera (scfln)
12,250
3,000
30,000
-
12,250
15,000
10,000
10,000
10,000
10,000
20,000
45,000
-
Pressure Drop
of System
{Inches H?0|
System 1 System
a 10
e 10
.
.
§.6 IE
S.i 12
f.6 12
9,6 12
i.fi , 12
-
».S 12
20 20
-
2 System 3
..
10
10
.s
-
12
12
11
12
12
.5
. If
20
-
Energy
Required
for Control
System
fKWB/yr)
Systera 1
24,000
8,000
-
-
112,000
24,000
16,000
4, §00
6,400
8,000
-
SO ,000
soo.ooo
_
519,200*
System 2
30,000
10,000
-
-
UPSff
140,000
30,000
20,000
6,000
8,000
10,000
-
60,000
100,000
-
(34,000
Percent Increase
In Enemy Required
Due to Control Systen tf)
System 1 System 1 System 2 System 3
30,000
10,000
2,000
-
4S,flflfl 12.5 11,6 16.4
147,000 12.5 1S.6 16.4
30,000
20,000
S,000
8,000
10,000
2,500
€0,000
100,000
"
SIS, 500 22.1 23 23,1
*Ass«med propcrtlonsl to
throyfh-pyt of country eltvttor.
-------
Table 7-6. CALCULATED ENERGY REQUIREMENTS TO OPERATE ALTERNATIVE CONTROL SYSTEMS (continued)
Facility
and
Process
Port Terminal
Receiving
Truck
Rail
Barge
Rail Loading
Cleaning
Drying
Scale and Surge
Bins
Handling
Shin Loading
Aeration
Process Storage
Receiving
Truck
Rail
Handling
Scale and Surge
Bins
Drying
Operating
Time
(hr/yr)
500
1,000
300
100
350
500
1,500
2,500
1,000
1,200
2,500
2,500
6,000
2.50C*
566
Process
Energy
Required
to Operate
Elevator
KHH/yr
75,000
12,500
47,000
-
17,500
100,000
-
2,750,000
180,000
750,000
3,930,000
??0 000
S*tm\J f WW
3,600,000
.
100,000
A1r Volume
Through Control
System (scfin)
12,250
25,000
15,000
10,000
20,000
60,000
20,000
45,000
20,000
-
12,250
25,000
25,000
10,000
30,000
Pressure Drop
of System
{inches HzQ)
System 1
12
9.6
9.6
9.6
9.6
-
9.6
20
9.6
-
9.6
9,6
16
8
-
System 2
12
12
12
12
12
-
12
20
12
-
12
12
20
10
. -
System 3
12
12
12
12
12
.S
12
20
12
-
12
12
20
10
.ES
Energy
Required
for Control
System
(KWH/yr)
System 1
20, COO
56,000
8, COO
2,400
16, COO
-
64, COO
500,000
48, COO
-
TF?7lQQ
72,000
160,000
560,000
48,000
-
System 2
20,000
70,000
10,000
3,000
20,000
-
80,000
500,000
60,000
-
763,000
90,000
200,000
700,000
60,000
-
Percent Increase
In Energy Required
Due to Control System (X)
System 3 System 1 System 2 System 3
20,000
70,000
10,000
3,000
20,000
3,000
80,000
500,000
60,000
-
766,000 18.2 19-4 .19.5
90,000
200,000
700,000
60,000
2,000
,050,000 i;052,000
21.5
2t-9
VJ
I
CO
-------
3
device because of a lower pressure drop through the cyclone collector.
As can be seen from Table 7-6, the controls required by the typical
state standard require an energy consumption ranging from 12.5 percent
to 22.5 percent of the process energy required without air pollution
controls. The more stringent control required by Systems 2 and 3
increases the power requirements by a maximum of 5.51 over state
requirements.
Table 7-7 presents the total and incremental energy requirements
for model plants with alternative controls. The number of new, modified,
and reconstructed plants that are estimated to be built and modified by
1981 are also presented 1n the table.
As can be expected, fewer new, modified, or reconstructed plants
are expected to be built with the Imposition of more stringent
control systems. For example, a total of 529 facilities are expected
to be built or modified with Alternative Control System 1, 501 with
System 2, and 470 with System 3. To make yearly estimates of energy
consumption, 1t was assumed that these new, modified, and reconstructed
facilities would be built or modified uniformly during the five-year period.
The energy values in Table 7-7 represent the estimated energy that would
have to be delivered to a power plant to generate the appropriate
electrical requirement to operate the control systems. The incremental
energy requirement over typical state standard requirements by 1981 is
estimated to be approximately 17,000 bbl of No. 6 fuel oil for System 2, ,
and about 19,000 bbl of No. 6 fuel oil for System 3. The larger energy
requirement for System 2 over System 1 results from the use of
fabric filters compared to cyclones. The larger energy requirement
of System 3 over System 2 is due to control of grain dryers which
7-19
-------
Table 7-7. TOTAL AND INCREMENTAL POLLUTION CONTROL SYSTEM REQUIREMENTS FOR MODEL PLANTS
WITH ALTERNATIVE CONTROL SYSTEMS*
Year
Control
System
1 «• System 1
2 = System 2
3 • System 3
Country
Elevator
(Models 1 and 2
and Rice Dryers)
No. (109 Btu/yr)
High Through-put
Elevator
(Models 3 and 4)
No. (109 Btu/yr)
Inland Terminal
{Model S)
Ho. (1C9 Btu/yr)
Port Terminal
(Model 6)
No. (109 Btu/yr)
Process Storage
Elevator
(Processors)
No, (109 Btu/yr 5
Total
Energy
(109 Btu/yr)
1976
1977
1978
1979
1980
1
2
3
•1
2
3
1
2
3
1
2
3
1
2
3
51
45
39
51
45
39
51
45
31
51
46
39
51
46
40
16.71
18,43
16.77
16,71
18.43
16.77
16,71
18.43
16.77
16.71
18,84
16,77
16,71
18,84
17.2
49
49
49
49
49
49
4§
49
49
49
49
49
49
49
49
56.20
70.24
73.74
56.20
70.24
73.74
§6.20
70.24
. 73.74
56.20
70.24
73.74
56,20
70.24
73.74
2
2
- 2
2
2
2
2
2
2
3
3
3
3
3
3
12.68
12,98
13.03
12,68
12.98
13,03
12.68
12.91
13.03
IS. 02
19,47
11.55
19.02
19.47
19.55
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
7.30
7.81
7.85
7.30
7.81
7.85
7,30
7.82
7.87
7.32
7.82
7.87
7.34
7.82
7.87
2
2
2
2
2
2
2
2
2
3
3
3
3
3
3
17.20
21.10
21.14
17.20
21.50
21.54
17.20
21.50
21.54
25.80
32.25
32.31
25.80
32.25
32,32
110.09
130.96
132.93
110.09
130,96
132.93
110.09
130.97
132,95
125.05
148.62
150.24
125,07
148.62
150,67
Sub-
Total
1
2
3
255
227
196
83,54
92,98
84,28
245
245
245
280,if
351.18
3i8.7i
12
12
12
76.08
77.90
78.21
5
5
5
36.17
35.06
39.22
12
12
12
103.21
129.01
129.2$
580.39
690.13
$99.72
Incremental energy compared to Control System 1:
(109 Bty/yr) (bbl of 16 oll/yr)
System 2 109.74 17,260
Systems . 119..33 18,770 _ .... .. . „
*A11 energy 1s based on fuel delfvsreB to a power plant to generate the electrical requirement for control systems.
rvj
o
-------
results in slightly higher energy consumption.
7 .6 OTHER ENVIRONMENTAL
7,6,1 Irreversible and Irretrievable Commitment of Resources
The standards of performance will require the Installation
of additional equipment over that now required by State standards.
This will require the additional use of resources such as
steel and building materials. This commitment of resources is
small compared to the national usage of each resource. Some portion
of these resources will ultimately be salvaged and recycled. There
are not expected to be significant amounts of land resources
required to install control equipment. Typical State standards
already require some type of control equipment and most of these
are located on buildings and, if not, require a relatively small
amount of space. Therefore, the commitment of land resources
for siting additional control devices ts expected to be minor.
The proposed standards of performance will require the increased
usage of energy, which is a scarce resource* to operate emission
control devices. This energy will not be retrievable but will
result 1n the control of significant quantities of particulate matter.
7.6.2 Environmental Impact of Delayed Standards
The environmental impact of delaying the standard on grain
elevators will have major adverse environmental effects on emissions
of particulate matter to the atmosphere and minor beneficial impacts
on solid waste disposal and energy usage. There is no new technology
that is being developed for the sources that are proposed to be
regulated which would drastically reduce emissions from the levels
7-21
-------
of best technology considering costs that are currently available.
If the standard were delayed for one year, it would result 1n
emissions of 3 to 3.5 million pounds of participate matter that
would have been collected by Alternative Control Systems 2 or 3,
respectively. Therefore» there appears to be no valid reasons to delay
proposal of the grain elevator standard.
7.6.3 Environmental Impact of No Standard
Based on the potential emissions of particulate matter and
on the growth projections presented in Chapter 8, the adverse
environmental impact of no standard is summarized 1n Table 7-8.
This table shows that 46 to 53 million pounds of partlculate matter
would be emitted in a five-year period if no standard were proposed.
Since there are only minor adverse solid waste impacts, and only
minor energy consumption Impacts associated with each of the alternative
emission control systems which could serve as a basis for the standards,
not setting standards presents little trade-off of potentially
adverse impacts in these areas against the resulting adverse impact
on air quality.
7-22
-------
Table 7-8. ENVIRONMENTAL iwwrr OF NO STANDARD
Country Elevator
(Hodels 1 and 2 ind
Rice. Dryers)
High Through-put
Terminal
(Hodels 3 and 4)
Inland Terminal
(Model 5)
Port Terminal
(Model S)
Grain Processor
(Processors)
Control Cumulative Cumulative Cumulative Cumulative Cumulative Total Emission
System Emissions Emissions Emissions Emissions Emissions Total Cumulative Reduction
1 * System 1 of Participate of Partlculate of Partlculate of Particulate of Partlculate Partlculate Compared to
2 - System 2 Hatter Hitter Matter Hatter Matter Emissions System 1
Ifear 3 - System 3 No, {103 Ib/yr) No. (W Ib/yr) No. (1Q3 Ib/yr) No. <103 Ib/yr) No. (103 Ib/yr) (103 Ib/yr) (10J 1b/yr[_
1976
1977
1978
1979
1980
1
2
3
2
3
1
2
3
1
2
3
1
2
3
51 1,275
45 184.5
39 58.5
102 2,510
90 369
78 117
153 3,825
135 553.5
117 175.5
204 5,100
181 742.1
156 234
255 6,375
227 W0.7
196 294
49 1,803.2
49 411.6
49 1SS.8
98 3,606.4
98 823.2
98 313.6
147 5,409,6
147 1,234,8
147 470.4
196 7,212.8
196 1 ,646.4
196 627,2
245 9,016
245 2,018
245 784
2 310.8
2 67.2
2 21.6
4 621.6
4 134.4
4 51.2
6 • 932.4
6 201,6
6 76,8
9 1, 398.fi
9 302,4
9 111.2
12 . 1,864.8
12 403.2
12 153.6
1 252,3
1 15.8
1 9.9
2 504.6
2 31.6
2 1§,8
3 716.9
3 47.4
3 29.7
4 1,009.2
4 63,2
4 39.6
i 1,261.5
5 79.0
5 4t.l
2 118.6
2 39,2
2 13.6
4 237,2
4 78.4
4 27.2
6 315,8
6 117.6
6 40,8
9 533,6
i 176.4
9 61,2
12 711.4
12 235.2
12 81.6
3,759.9
718.3
264.4
11,279,7
2,154.8
783,2
22,559.4
4,309.8
1,586.4
37,813.6
7,240.3
2,663.6
§7,042.3
10,914.4
4.026.3
3,041,6
3,495,5
9,124,8 '
10,486.5
18,249,6
20,973
30,573.3
35,150
46,095.9
53.016
•M
1
-------
REFERENCES
1. "Emission Control In the Grain and Feed Industry, Volume I -
Engineering and Cost Study," by Midwest Research Institute for
the U.S. Environmental Protection Agency, EPA-45Q/3-73~QQ3a»
December 1973.
2, "Methodology for Estimating the Impact of Grain Elevator Emissions
on A1r Quality," memorandum from Larry Budney, Source-Receptor
Analysis Branch, to Stanley T. Cuffe» Chief, Industrial Studies
Branch, November 1974.
3. Woodard, Kenneth R.» memorandum to James C. Berry, Chief, Standards
Support Criteria Pollutants Section, Industrial Studies Branch,
Subject: Telephone Calls to Determine Solid Waste Disposal and
Energy Requirements at Grain Elevators, January 1975.
7-24
-------
8. RATIONALE FOR THE PROPOSED STANDARDS
8.1 SELECTION OF SOURCE F0ft CONTROL
firain elevators contribute significantly to national emissions
of partfculate matter. It is estimated that the grain elevator
industry emits 606,000 tons of participate matter each year.
Approximately 7900 grain elevators are located
nationwide. Of this amount it is estimated that there are about
6800 country elevators, 500 terminal elevators and 600 storage
elevators at grain processing plants (see Table 2-2).
Although grain elevators are located throughout the United States,
the major concentration is in the grain-producing states 1n the
Mid-Plains, South Plains and Great Lakes regions. Approximately
87 percent of the country elevators are located in areas with less
than 100,000 inhabitants. Terminal elevators are located in the
principal grain-marketing centers, most of which are in metropolitan
areas. There is a trend, however, for terminal elevators to be
built in more rural areas. Grain processing facilities for
wheat, corn, and rice mills; soybean processing plants; and wet
corn mills are located in both rural and urban areas.
Growth in the grain elevator and grain processing industries
is expected to be slow since the per capita consumption of grain
products is remaining constant or decreasing. The total number
of grain elevators is expected to decrease*, however, the total
through-put of j^rain is expected to increase slightly. The trend
is to larger through-put elevators, with low storage capacity and
high handling capacity. Of the processing plants, only soybean
processors have significant incentive to invest in new storage capacity.
8-1
-------
Soybean production in the United States has increased over 20 fold,
from 70,000 to 1,567 million bushels, in less than 35 years. Soybeans
are an increasingly important source of protein for human and animal
consumption; and soybean oil is used in foods, cosmetics, paints
and plastics, in the five-year period Between 1976 and 1181,
approximately 530 grain elevators are expected to be built, modified
or reconstructed. Even though the total growth in the industry
will he slow, the number of new, modified, or reconstructed facilities
will average approximately 100/year, which 1s considered to be
significant.
In a study performed by The Research Corporation of New England
(October 24, 1975), significant sources of participate matter were-,.
identified and ranked in order of total emissions. Four grain
handling operations were shown to be significant sources of particu-
late; processing was ranked fifth, transfer was ranked seventh, cleaning
and screening was ranked tenth, and drying was ranked number thirty-
three. Also, the Conmlttee on Public Works of the U. S. Senate listed
grain elevators as a source for which standards should bt developed.
Particulate natter concentrations due to emissions of particylate
matter from poorly controlled grain elevators have been measured with
a high volume sampler and found to be nearly 240 pg/m^ in the
immediate vicinity of grain handling plants. This is discussed
further in Chapters 2 and 7. Health-related effects on humans have
been documented at ambient concentrations of particulate matter
greater than 100 ug/m3. Under section 109 of the Clean Air Act,
8-2
-------
particulate matter has been designated as a criteria pollutant, and
National Ambient Air Quality Standards have been set for particulate
matter,
EPA has determined that particulate emissions from grain elevators
contribute significantly to air pollution which causes or contributes
to the endangerment of the public health. For this reason* the source
category of grain elevators has been selected for emission control,
8,2 SELECTION OF POLLUTANTS AND AFFECTED FACILITIES
Large quantities of particulate matter, which result from
handling grain, are emitted from grain elevators. This particulate
matter consists of dirt from the field, pieces of grain kernels,
spores of smuts and molds, insect debris, fungi and pollens. The
only combustion process at a grain elevator is the grain dryer
and a very small amount tff NOX and SCU may be emitted from this
process. These pollutants are not considered to be significant
in the amounts emitted from a grain dryer. Particulate matter
is the only significant pollutant at a grain elevator and is the
pollutant that Is proposed to be regulated.
Farm elevators, country elevators, terminal elevators 'and
commercial rice dryers which handle wheat, corn, soybeans, milo,
rice, rye, oats, >or barley and storage elevators at wheat flour
mills, wet corn mills, dry corn mills (human consumption), rice
mills, and soybean oil extraction plants were determined to be the
most significant sources of particulate matter emissions 1n the
grain handling industry, Particulate emissions from these .sources
are proposed to be regulated.
8-3
-------
The grain handling and storage facilities at the specified
grain processing industries were chosen because these industries
handle a large portion of the grains that are processed and are
considered to be significant sources of participate matter.
Animal, pet food and cereal manufacturers; breweries; and
feed lots also process whole grain. These industries were beyond
the scope of the background industry studies. Consequently, no
data are available on these sources and they are not subject to
the proposed standards. In addition, there are relatively few
plants in these peripheral industries.
The proposed standards would apply to affected facilities
that handle wheat, corn, soybeans, mi To, rice, rye, oats, or
barley. These grains were selected to be subject to the standards
because they are the primary grains produced in the United States,
There are several other grains (e.g., millet}, but these crops
are grown and handled in small quantities. Therefore, the
handling of these grains is not considered a significant source
of particulate matter at this time.
Grain elevators are used to handle wheat, corn, soybeans,
milo, rice, rye, oats, and barley. Uncontrolled emissions vary
with the type and mixture of grain handled. It has been shown
that uncontrolled emissions are lowest when wheat is handled.
Particulate emissions are three times higher when handling
soybeans and two tiroes higher when handling milo, as compared
to handlinq wheat. Emissions from corn are about equal to
those from wheat. The processes controlled with fabric filters
8-4
-------
that were tested during this study handled corn, wheat, soy-
beans ,~and ratio. -The test results do not indicate thairthe"""
type of grain affected emissions from the fabric filters. In
EPA's judgment, the same emission levels can be maintained when
handling rice, rye, oats or barley when the best systems of emission
reduction, (considering costs) are used.
The minimum size of farm elevators, country elevators, terminal
elevators and commercial rice dryers to which the proposed standards
apply was based on economics. The fixed costs (capital charges)
for control equipment needed to comply with, the proposed standards
do not change for any country elevator below a through-put of
one million bushels/year. Since most country elevators are in
areas where there is competition with other elevators, there
Is a limit to the cost that can Be passed back to the fanners.
The cost cannot be passed forward to the larger terminal elevators.
Therefore, there is also a limit to the amount that can be either
absorbed by the operator or passed back to the farmer. The maximum
amount estimated that could be absorbed by a country elevator was
$.021 per bushel. Since the control costs are essentially fixed
for elevators smaller than 1 million bu/yr, the control cost per
bushel varies inversely with the amount of grain handled.
An economic analysis showed that the minimum size country
elevator that could afford to install control equipment to meet
the proposed standards was one that handled an annual through-put
of 700,000 bu/yr. All terminal elevators will be above this
minimum through-put level, and most of the farm elevators will be
8-5
-------
below this level. Since there was a possibility that some farm
elevators will be large, it was decided that those large farm
elevators should be controlled.
There are several problems associated with using this type
of cut-off level; (1) It would be difficult to determine the
projected through-put of new or modified elevators, (2) this
through-put level could vary from year to year depending on whether
the crop was good or bad or whether there was more than one crop
harvested per year in a location (e.g. two wheat seasons). The advantage
of determining a cut-off in terms of annual through-put is that
this parameter is most relevant in an economic analysis.
Recognizing the potential problem of determining the applicability,
another alternative cut-off level based on installed equipment was
considered. The storage capacity at an elevator and the leg
capacity were investigated. Both would accomplish the objective
of more definitely determining the applicability of new, modified, or
reconstructed elevators. The leg capacity was selected because it was more
clearly related to the through-put than was storage capacity.
Several firms which construct country elevators were consulted to
determine what leg capacity would be Installed at country elevators
which have a through-put of 700,000 bu/yr. All stated that a leg
capacity of approximately 10,000 bu/hr would be installed at such a
country elevator; therefore, the standards will apply to farm, country,
or terminal elevators that have a leg capacity in excess of 352 m3/h
(ca. 10,000 bu/hr). Since commercial rice dryers have economics similar to
country elevators these are also included under the cut-off level
exemption. The advantage of this cut-off level is that applicability of
8-6
-------
the proposed standards to a new, modified, or reconstructed elevator
could be easily determined. However, due to variations in operation
hours» a disadvantage would be that an elevator that Installs a
10,000 bu/hr leg may handle less than 700,000 bu/yr and therefore
find it uneconomical to install control devices to meet the levels
of the proposed standards.
The proposed standards apply to all sizes of processing plants
that are covered by the standards, except commercial rice
dryers, because the.required control costs are affordable for these
plants.
At farm, country, and terminal elevators and at the grain handling
and storage facilities at processing plants, the only source of par-
ticulate matter emissions is from a combination of the following grain
operations: truck unloading, railroad hopper car and boxcar unloading,
barge and ship unloading, grain handling, grain drying, truck loading,
railroad hopper car and boxcar loading, and barge and ship loading.
All of these sources of particulate matter emissions could be
significant sources of emissions if uncontrolled! therefore, the
proposed standards regulate particulate matter emissions from
each of these sources.
Consideration was given to classifying an entire grain
elevator, including all its various functions, as the affected
facility. If this were done, however, modification or reconstruction
of a substantial portion of an existing grain elevator would make
the entire elevator subject to the proposed standards. Since this
8-7
-------
is not considered reasonable, the operations at grain elevators
were classified into eight affected facilities. The affected
facilities are: each truck unloading station, each railroad boxcar
and hopper car unloading station, equipment at each barge and ship
unloading station, all grain handling operations (which include
conveyors, headhouse and other such structures, legs, scalpers,
cleaners, turn heads, trippers, scales and surge bins), each grain
dryer, each truck loading station, each railroad hopper car and boxcar
loading station, and each barge and ship loading station. There
are several advantages to naming the separate operations as affected
facilities. For example, unloading stations and loading stations
are often physically separated from other parts of the elevator
and often have separate capture systems and air pollution control
devices. Modification or reconstruction of one of these facilities
will make it, but not the whole elevator, subject to the proposed
standards. This is desirable because there can be an increase
in the unloading or loading capacities without affecting other
facilities at the elevator.
Grain handling operations are grouped as one affected
facility since they have similar operating capacities; and common
air pollution control devices frequently serve several pieces
of handling equipment. Modification of one part of the grain
handling system will usually require modification of other
parts in the system; therefore, the whole system would be subject
to the proposed standards.
8-8
-------
8,3 SELECTION OF BEST SYSTEM OF EMISSION REDUCTION CONSIDERING COSTS
The purpose of the proposed standards Is to require that
best demonstrated emission control technology, considering costs,
for particulate matter be installed and operated at new, modified,
and reconstructed grain elevators. The proposed standards would
ensure paniculate containment and pickup at the location of dust
generation, as well as proper operation and maintenance of air
pollution control devices. The individual emission sources to
be controlled include, as discussed in Section 8.2, all sources
of fugitive emissions generated by process equipment and process
exhaust gas streams at grain elevators which are significant.
sources of particulate mattir.
! '
The development of the proposed standards for these emission
j sources at grain elevators relied largely on results of a previous
j investigation of air pollutant emissions and control techniques
I
{ in the grain and feed industry sponsored by EPA, This earlier
i
: study includes the responses from 509 owners or operators of
i elevators throughout tht country to a questionnaire on the air
i
: pollution aspects of their operations. The proposed standards
i " '
i are also based on data concerning emission control systems
i '
j and methods of process operation received through on-s1te observations
of plant operations and control systems, consultation wtth Industry
representatives and manufacturers of control system and devices,
emission tests conducted by EPA and operators of grain elevators,
and meetings with industry associations and the National A1r Pollution
Control Techniques Advisory Committee.
8-9
-------
The selection of the best demonstrated system of emission reduction
(considering costs) for new, modified, and reconstructed grain elevators
is based on evaluating the incremental impacts (compared to State standards)
of alternative control systems on air emissions, energy usage, water
pollution, solid waste pollution, noise pollution and pollution control
costs. The first step is the selection of the most effective methods
for reducing air emissions from each affected facility. These
methods are then compared, considering all environmental impacts
and costs, to determine the best demonstrated emission reduction
method, considering costs, for each affected facility. The best
demonstrated system to control particulate matter from an entire
grain elevator is an assimilation of the best emission reduction
methods for each affected facility, with consideration given to
total costs and economic impact for all the affected facilities.
The costs and environmental impacts for an entire elevator were
considered and EPA found them to be reasonable as discussed in
Chapter 6 of this document.
8.3.1 Grain Dryers
T^ere are two basic types of grain dryers, rack and column.
Grain enters the top of both types, flows downward through the
structure and exits via conveyors at the bottom. Heated air blown
through the grain evaporates the excess moisture. Particulate matter
and chaff can become entrained in the air and carried from the dryer.
The quantity of particulate emissions is largely dependent on the type
(rack or column) of dryer. Uncontrolled column dryers have much
lower emissions than uncontrolled rack dryers by virtue of
their design. In a column dryer the grain flows in a continuous
8-10
-------
packed column between two perforated metal sheets, and most of
the participate matter is trapped within the grain rather than being emitted
through the side of the column and into the atmosphere. A rack
dryer contains baffles or racks around which the grain and hot
air must flow and mix. This creates a cascading motion of grain
flow through the air strewn, resulting in greater entrainment
of grain dust (particulate matter) than in a column dryer.
The current trend 1n the grain elevator Industry is the Installation
of column dryers instead of rack dryers at country elevators, and this
trend is expected to continue. The trend has developed primarily
because typical State standards require that rack dryers be operated
with a 20 to 30 mesh screen for air pollution control, whereas no
air pollution control device is usually required for column dryers.
This gives a significant capital cost advantage to the column dryer.
EPA believes the majority of new, modified, or reconstructed dryers
will be column dryers; however, new rack dryers may be Instilled in
high throygh-put elevators because maintenance costs appear to be
less for rick dryers in these applications.
Emissions from grain dryers are discharged from an exhaust
area that is usually very large. Therefore, it is not technologically
or economically feasible to apply the usual particulate source test
methods designed for measuring stack emissions to this source. Several
attempts to carry out source tests were made by EPA and by operators
of grain elevators. The data collected, however, can only.be
used as a guide in developing a standard due to the numerous
difficulties encountered in the measurement technique, such as
low exit gas velocity, skewed exit velocity, large traverse area,
variability of particulate concentration ind velocity over the
8-11
-------
exit area, and variability in the design of the exhaust areas
on different brands of dryers. The accuracy and precision of the
technique are not sufficient for determining compliance. EPA
has concluded that methods for measuring mass particulate
emissions from grain dryers are not available at this time.
The only practical and feasible method of measuring participate
matter emissions from grain dryers is visible emission determina-
tions.
Table 8-1 illustrates the four options considered by EPA for
controning emissions from column and rack dryers. Two cases for
column dryers were evaluated; column dryers without screen filter
controls with a perforation size range of 0.050 to 0.084 inch
and column dryers with a vacuum-cleaned screen filter. For the
rack dryers, the two cases considered were rack dryers with screens
and rack dryers with vacuum-cleaned screens. For each of these
cases, all the emission data that is available is tabulated along
with the total capital cost, total annual costs, annual incremental
costs, and the impact on installation of new dryers.
The available source test data, which can only be used as a guide
(see Chapter 5) indicate that the most efficient demonstrated method for
controlling particulate emissions from grain dryers, both column and rack
designs, is to cover the exhaust area with a 100 mesh screen (filter)
equipped with a vacuum type cleaning mechanism. (Some plugging
problems have occurred under certain operating conditions when 100 mesh
screen filters are used.) EPA estimates (Case 2, Table 8-1) that approxi-
mately 520 new column dryers would not be installed over a five-year
8-12
-------
00
1
C"»
OJ
W
ft)
z
o
1
2
3
4
Type "of
l Dryer
0
o
c
3
X
X
"23
t»
0
7C
X
X
Type of
Control
O
01
o
3
m
X
r»
-s
fS
n»
,3
X
•<
t/5»J
o r*
*i
fl>3
c"j
^™*
n>
a,
3
fl>
Q.
X
X
TABLE 8-1. Alternative Controls for Column and Rack Dryers
{2000 bu/hr capacity)
Emissions
Visible
Emissions
Visible
TOO Mesh
No Data
58 Mesh
Visible
24-30 Mesh
Visible
TOO Hesh
No Visible
Emissions
50 Mesh
Visible
Opacity
of
Emissions
Perforation
Size Range
O.tJStJ to
0.084 inch
0«
100 Hesh
No Data
58 Mesh
0«c
24-30 Mesh
5-10%A
100 Mesh
Olc
50 Mesh
0%
Mass0
Emissions
(Ib/ton)
,2SB
100 Mesh
.05B
58 Mesh
0,18
24-30 Mesh
T.1B
100 Mesh
.05
50 Mesh
0,5B
CostsE
Capital
Installed
($)
ins tooo
158,400
114,300 ;
152,000
Total
Annual
($/bu)
0.0393
0.051 i
0.0394
0.047?
Incremental
Annual
Control
($/bu)[*3
0
0.0117[30S]
0
O.OQ83[2ir]
Impact on
Installation
of New
Dryers
(No./S yr.)
1 0
i
!
-520
0
0
A. Visual observations were taken sporadically by an unqualified opacity reader.
B, Estimates from Figure 4-9 (use only as a guide).
C. Observation by unqualified opacity reader.
D. All mass data should only be used as a guide, due to inadequacies of measurement method.
E. Costs based on dryer life of 15 years. .. .
-------
period if compliance with the NSPS required the use of a 100 mesh
vacuum-cleaned screen filter. In the absence of NSPS, approximately
1380 new column dryers would be installed. If a coarser screen of
50 mesh were required, the screen plugging problem would be reduced;
however, a vacuum cleaning mechanism would still probably be needed.
Therefore, the adverse economic impact would not be reduced. It is
EPA's judgment that the economic impact of a standard that would
require vacuum-cleaned screens for column dryers (Case 2, Table 8-1)
is not reasonable.
The control costs are reduced if a screen filter rather than a
vacuum-cleaned screen filter were operated on a column dryer. However,
the available data on opacity and the trends indicated by the available
particulate test data (see Chapter 5 of this document) do not clearly
demonstrate that there would be an appreciable difference in emissions
between column dryers equipped with the coarsest screen filters now
used on grain dryers, and those equipped with conventional perforated
plates but no screen filters. Further, some types of column dryers,
because of their configuration, cannot reasonably be equipped with
screen filters. Therefore, the proposed standards were not based on
controlling column dryers with screens (filters).
The remaining emission control alternative is the operation of
a column dryer with no screen (Case 1, Table 8-1). Since the economic
8-14
-------
jmpact of NSPS -canparedjg $tate_standards is. reasonable if no screen
is used, EPA has concluded that this alternative is best
demonstrated technology considering cost for column dryers.
EPA attempted to determine whether smaller perforations in column
dryer plates produce lower emissions. However, no difference in
opacity was observed for the range of hole diameters from 0,050"
to 0.084", There are operational problems with sizes of 0.050"
to 0,0625" because of pluggage. However, many dryers operate with plates
having 0,084" diameter holes with no apparent problems. Consequently,
the column plate perforation size for best demonstrated technology con-
sidering costs 1s concluded to be 2.1 ran (ca, 0.084 inch).
There are no environmental impacts associited with the best
demonstrated technology considering costs for column dryers
compared with the typical State standard, since they are
essentially the same. Both standards allow column dryers to
operate without additional air pollution control equipment.
However, Individual State standards rely mainly on nil since codes
and process weight charts for enforcement. It is questionable
whether process weight charts can be directly applied to dryer
emissions and the enforcement of nuisance codes is subjective.
In order to reduce emissions from rack dryers to a level
comparable to that of best demonstrated technology for column
dryers, it would be necessary to Install a screen ptrticulate
collecting device. The source test data gathered by EPA and by
elevator operators (discussed earlier in this section and 1n
Chapter 5) indicate that emissions from a rack, dryer equipped
with a 50 mesh vacuum-cleaned screen are approximately equivalent
8-15
-------
to the emissions from a column dryer with no screen. Typical
St^te standards now require rack type dryers to use 20 to 30 mesh
screens for pollution control. Requiring a 50 mesh vacuum-cleaned
screen would strengthen the trend toward use of column dryers by
country elevators, but would have no additional economic impact
on the grain: elevator industry.
8.3.2 A1r Pollution Control Devices
EPA separately considered the capture systems at various
grain operations and the air pollution control devices used to
-------- JLI -- --- 4. ---- -J — -«,*.4 _,.T -4,— _.s4.4..K — 47_~« *!»» ___ _.!.„--._ U~C~>»«
rciuuvc MIC u.a(j uur tru par <» i L.U i a LC maestri i i um uic yaa a ui cam
discharge to the atmosphere. The proposed standards would require
air pollution control devices on all of the affected facilities
at a grain elevator, except grain dryers and some types of dust-
tight grain handling operations.
Almost every grain elevator that controls emissions uses either a
cyclone or a fabric filter. Low-energy scrubbing devices are used
occasionally; however, they are generally not as efficient as cyclones
or fabric filters. Cyclones and fabric filters were evaluated by
EPA to determine the best demonstrated control technology, considering
costs, for grain operations.
Cyclones are classified as either high-efficiency or low-efficiency.
The hicjher gas velocity in high-efficiency cyclones, which are the
most common control device presently used at grain elevators, results
in a collection efficiency of about 85 to 95 percent. The pressure drop
across a high efficiency cyclone is approximately 3 to 5 inches of
water. The lower gas velocity in low-efficiency cyclones results in
8-16
-------
collection efficiencies between 60 and 85 percent, and pressure
drops of only 0.5 to 2.0 inches of water.
The typical modern fabric filter at a grain elevator handles
2,000 to 30,000 cubic feet of air per minute, Host are package units
that can be supplied by several manufacturers. The filters usually
operate under negative pressure with the fan pulling air through the
system. Felted, synthetic fabrics are the most common collection media.
The air-to-cloth ratio is usually between 10:1 and 15:1. The filter
bags are cleaned by mechanical shaking or by forcing a jet of air through
them to force the dust cake off the fabric. Fabric filters typically
attain collection efficiencies of better than 99 percent,
EPA measured emissions according to Reference Method 5, except
that the probe was not heated, from eleven grain processes controlled
with fabric filters. The results summarized 1n Chapter 5 of this
document cover grain unloading, handling, and loading operations.
The average concentration of particylate matter emissions from
all facilities, excluding one which had high emissions due to
<%
process irregularities, was 0.00? g/std, nr dry basis. Most of the
individual test results were below 0.023 g/std. m^ dry basis. EPA did
not weasure emissions from cyclones, but estimates that emissions from
grain operations controlled by cyclones average a factor of 10 times
that of fabric filter control devices.
Therefore, EPA has determined, based on the available data, that
the best demonstrated system of emission reduction {considering costs)
for grain operations is a fabric filter.
There are no significant environmental impacts associated with this
control method when compared to cyclone control which is now generally
8-17
-------
required by State standards. Some additional participate matter will
be collected, and power requirements will be somewhat increased.
8.3,3 Truck and Rail car Unloading Stations
The generation of particulate emissions and the methods of
unloading grain from trucks and railears, both boxcars and hopper cars,
are similar. Grain, contained in a railcar or truck bed, is delivered
to the elevator where it is rapidly unloaded by pouring the grain
into a hopper recessed in the ground. Trucks and boxcars are
mechanically elevated arid/or tilted so that the grain is emptied
from the vehicle. Grain from a hopper car and some trucks is released through
outlets at the base of eich individual hopper section. These operations
are described in detail in Chapter 4 of this document. A falling
stream of grain is created in each of these cases which generates
turbulent air flow in the receiving hopper. Particulate matter in
the grain is entrained in the turbulent air currents and flows out of
the .hooper with the displaced air if controls are not applied.
The demonstrated methods for controlling particulate emissions
from truck and railcar unloading operations include a collection hood,
in the receiving hopper, ventilated to an air pollution control device
and a protective enclosure around the facility to reduce the interfering
effect of winds.
Three alternatives were evaluated by EPA concerning protective
enclosures of the unloading station. Generally, enclosures or
sheds are used to protect the grain and workers from inclement
weather. In some locations, however, where the weather is
consistently dry, unloading stations do not have sheds. In
developing the proposed standards, EPA determined that a protective
8-18
-------
enclosure is required to prevent wind from grettly interfering
with the effectiveness of participate capture by the hopper
ventilation system.
The alternative protective enclosures considered weiie
0) a shed with two open ends, (2) a shed with one open end,
and (3) a totally enclosed shed. A shed with two open ends
was determined to be least effective because it allows the wind
to blow directly through and over the receiving hopper, A shed with
one open end and a totally enclosed shed were found to greatly
diminish the effects of wind upon the ventilation system;
The totally enclosed shed has been demonstrated in railcar
(hopper and boxcar) unloading operations, where the two ends
of the shed are equipped with quick-operating doors. However,
all of the truck unloading facilities inspected by EPA were
designed so that the front end of the truck extends out from
under the open end of the shed. Some reduction in participate
emissions could be realized by totally enclosing the truck unloading
operation-, however, no elevators that use this method are known by EPA.
In order to totally enclose the operation» the shed would have
to be gnatly increased in both length and height because the
front tnds of tht trucks are raised considerably to allow the grain
to flow out the rear of the truck. This would increase the cost
of the shed substantially. In addition, truck unloading operations
are located at all small country elevators, whereas railcar unloading
is only found at larger elevators. Greatly increased costs would
be incurred, especially at snail elevators, and minimal reduction
8-19
-------
in emissions would result from the use of a completely enclosed
shed on truck unloading operations. Therefore, EPA has concluded
that the best demonstrated system of emission reduction (considering
costs) for truck unloading stations is a shed with one open end
and for rail car unloading stations is a totally enclosed shed.
When compared to typical State standards, these control methods
will have minimal secondary environmental impacts. More particulate
matter will be collected, -some of which may have to be disposed of,
and the energy requirement will be somewhat greater.
The system for railcar unloading would include a receiving
hopper equipped with baffles and ventilated at a rate of approxi-
mately 15,000 to 25,000 cfm depending on the size of the facility,
The system for truck unloading would include a receiving hopper
equipped with baffles and ventilated at a rate of approximately
12.000 cfm,
8.3.4 Barge and Ship Unloading Enuiwwnt
Barge and ship unloading stations are generally onen to the
weather. Grain is unloaded with a bucket elevator (leg) that is
lowered into trie vessel. Particulate matter is generated in the hold of the
vessel fay the buckets of the leg and at the transfer point at the
top of the leg where the grain Is dumped into a receiving hopper.
To completely clean the barge, it is usually necessary to push
or pull the grain to the leg with power shovels or front end loaders,
which- generates' a large amount of particulate matter emissions.
All of the bucket elevators observed by EPA during the develop-
ment of thi proposed standards had various types of enclosures and
8-20
-------
were ventilated. Ventilation should be applied, to effectively control
particulate matter emissions, on both sides of the bottom portion
of the leg and at the top of the leg where the grain is transferred
to a storage bin, A facility with the leg enclosed frorn the top
(including the receiving hopper) to the center line of the bottom
pulley appeared to perform with the least emissions. This facility
was observed in operation with and without the ventilation system
in operation. Ventilation was applied at the base of the leg
and at the top of the elevator. Significantly higher opacities
were observed during the operation without ventilation than when
the ventilation was 1n use. The ventilation rate used at this
facility, which was 32.1 actual cubic meters per cubic meter of grain
handling capacity (ca, 40 ff3/bu)» was judged to be adequate to
effectively capture the particulate emissions (refer to Chapter 4
of this document).
Therefore, EPA considers the best demonstrated system of
emission reduction (considering costs) for barge and ship unloading
stations to he a leg enclosed from the top (Including the receiving
hopper) to the center line of the bottom pulley with ventilation
to a particulate control device maintained on both sides of the
leg and the grain receiving hopper. The total rate of air ventilation
must be at least,32.1 actual cubic meters per cubic meter of grain
handling capacity (ca. 40 ft3/bu).
8-21
-------
8,3.5 Grain Handling Operations
Grain handling equipment is used to transfer grain from
unloading operations to storage, to clean and weigh the grain,
and to transfer the grain from storage to loading operations.
Conveyors, surge and garner bins, turn heads, cleaners» scalpers,
trippers, legs, scales, tn.e fieadhouse and other such structures
are the individual pieces of equipment included under grain handling
equipment. Most of the individual pieces of equipment are usually
located inside of the headhouse or associated elevator structures.
Emissions from thesf? operations, if not nrnpprly control led; can
be emitted through doors or windows of the headhoyse. For purposes
of the proposed standard, the housing for the conveyor and tripper
mechanism atop the storage silos is considered to be part of
the headhouse. In some cases, however, various grain handling
equipment is located outside of the headhouse. Some conveyor
systems, especially at elevators which load and unload ships
and barges, are always outside of the headhouse.
Emissions from grain handling equipment generally occur at
transfer points in the system and at openings in the partial
enclosures that house some equipment such as cleaners. Emissions
can also be generated over the length of outside conveyors if
they are not properly shielded from winds. At transfer points,
the grain is "dropped" from one piece of equipment to another
and the resulting air turbulence can generate particulate matter emissions,
8-22
-------
Particylate emissions from grain handling equipment can be
minimized through the use of totally enclosed equipment, by
handling the grain at a slower rate, or by using ventilated hooding
systems designed to capture emissions.
EPA has concluded, based on available data and field inspection
of all of the equipment listed under grain handling, that the best
demonstrated system of emission reduction (considering costs) for
grain handling operations are:
1. Cleaners - Two methods are considered to be equally
effective. Screen cleaners can be controlled by
hooding or partially enclosing the cleaner and
ventilating the particulate matter to a particulate
control device. Alternatively, screen cleaners can
be totally enclosed without ventilation,
2. Conveyors - Conveyors can be completely enclosed
and should have a hooding mechanism ventilated
to a particulate control device at any transfer
point along the conveyor.
3. Scales, surge and gamer bins, turn heads, scalpers,
and legs - Scales, surge bins and garner bins can be
vented to a particulate control device. The bins
can be vented to each other so the air can be exhausted
to a single control device. Turn heads and scalpers
can be enclosed and ventilated to a particulate
control device. These operations can ilso be fitted
with total enclosures. Legs can be ventilated
at the top and bottom where grain exits and enters
the bucket elevator.
8-23
-------
4. Trippers and tripper conveyors - Trippers can be
equipped with a hooding system ventilated to a
participate control device. The conveyor associated
with the tripper can be enclosed and can be venti-
lated at all transfer points.
5. Headhouse and other such structures - All other grain
handling operations which are located fnside these
structures can be equipped with the best system uf emission
reduction {considering costs) for that operation.
These techfiollsgies apply equally to the individual grain handling
equipment contained within the headhouse and equipment which is
located outside of the headhouse.
8.3.6 Truck and Rail car Loading Stations
The methods of loading grain into trucks and rail cars (boxcars
and hopper cars) are similar. A stream of grain flows via the
force of gravity through a loading spout into the compartment of
the vehicle. The mechanisms>,ttat generate particulate emissions
are also similar. During these operations, particulate matter in the
grain is entrained in turbulent air currents produced when the stream
of grain impacts the vehicle compartment or grain which has already
been loaded. The particulate matter can then be emitted from the
compartment with the displaced air.
EPA has observed demonstrated methods for controlling particulate
emissions from truck and rail car loading operations that include a
ventilated hooding system and a partial enclosure around the vehicle
and loading spout to reduce the interfering effects of winds.
-------
Truck Loading
During the development of the proposed standards, EPA could not
locate a truck loading operation in the grain Industry that used what
was considered to be the best system of emission reduction (considering cost)
that could be applied. Therefore, other industries such as lime and
flour and grain processing were studied in an attempt to find well
controlled truck loading operations in these industries, EPA located
and observed a soybean meal truck loading operation. This operation 1s
well controlled; however, 1t does not have what fs considered to be the
best system of emission reduction. Loading soybean meal Into trucks
was determined by EPA to be as dusty an operation as loading grain
Into trucks; therefore, a direct transfer of technology to grain
loading operations is possible.
Trucks were loaded with soybean meal inside of a shed with one open
end. The loading spout was equipped with a canvas sleeve, but the soybean
meal had to fall about ten to twelve feet from the end of the sleeve
into the truck bed. Particulate matter was generated from this
process after the meal impacted the truck bed. The shed was
ventilated by a duct at a rate of approximately 6000 cfm. The
ventilation duct was located beside and to the rear of the loading
spout and was not very effective in containing emissions. EPA
believes that a better control system can be designed than the one
observed; however, this is the best system that has been demonstrated
for truck loading operations which are very similar to grain loading
operations. EPA has concluded that the best system of emission
reduction (considering costs) for truck loading operations is a
8-25
-------
sherf with one optn end, equipped with a loading spout with a
canvas sleeve and a hooding system ventilated at a rate of
i
approximately 10,000 to 12,250 cfm. A total enclosure of the
truck loading operation would more effectively eliminate the
Interfering effects of winds. However, no such truck loading
operation was found in the field,
Hopper Carand Boxcar Loading
Participate matter emissions which result from the loading
of grain Into hopper cars is controlled in the grain industry
by a hooding system, ventilated to an air pollution control
device, located at the end of the loading spout. The loading
operation is usually.enclosed in a shed with two open ends.
This control method is the only effective demonstrated partieu-
late control system used for loading grain into hopper cars.
The type of hooding and the ventilation rates are the only
variables. Several hopper car grain loading systems were studied
by EPA by reviewing the manufacturer's designs of the systems
and through communications with grain elevator operators and
plant engineers. EPA gathered data from the operation which
was determined to be the most effective system.
EPA has concluded that the best system of emission reduction
(considering costs) for railroad hopper car loading stations
1s a shed with two open ends, and a hooding system located next
to the loading spout which is ventilated at a rate of about
10,000 cfm.
8-26
-------
The grain industry has essentially only one demonstrated
participate control method for loading boxcars. This technology
is explained in Chapter 4 of this document. The technology consists
of a small building-like structure that is elevated to the level
of the boxcar door. This structure encloses a forked and curved
loadinq spout and the enclosure is ventilated. The entfre operation
is usually enclosed in a shed with two open ends.
EPA took opacity measurements on the best controlled facility
which was found. The operation observed, however, was not considered
to employ the best control technology that could be applied. This facility
could be maintained in better condition and higher ventilation rates
could be used.
Hopper car loading and boxcar loading operations are similar
and best technology requires a shed with two open ends and a hooded
loading spout ventilated to an air pollution control device on both
facilities. The grain flows through a loading spout and is
deposited in a receiving vessel (the rail car) at each facility.
Fugitive particulate matter emissions are also generated in a
similar manner. The stream of grain and induced air flowing into
the railcar disturbs and displaces the air in the railcar. Also,
when the grain impacts against the receiving vessel, turbulence
is created in the surrounding air. Particulate matter can be
entrained 1n the turbulent air currents and flow- out of the
railcar with the displaced air. Possible alternatives could be
to entirely enclose the loading operation or to have a door
on one end; however, no such technology presently exists in the
field.
8-27
-------
EPA has concluded that the best system of emission reduction
(considering costs) for railroad boxcar loading stations is
a shed with two open ends. A loading spout enclosed by a small
building-like structure which extends to within 6 inches of the
side of the boxcar and hinged doors about 8 inches wide, equipped
with rubber flaps, which seal the sides of the enclosure to the
boxcar are part of this best control system. This building-like
structure is ventilated at a rate of about 10,000 cfm.
8.3,1 Barge and Ship Loading Stations _ ,
Grain is loaded Into ships and barges after it is conveyed fr-wii
storage to the loading area. The grain falls dowi long loading spouts
that are inserted into the holds of the vessels. Particulate emissions
occur when the grain drops from the end of the loading spout into
the hold, and when participate matter in the grain already deposited
becomes reentrained in the disturbed air of the hold. The entrained
particulate matter can then exit through the hold opening into the
outside air,
EPA considered t»-o systems for controlling particulate matter
emissions from barge and ship loading. The first consists of a tele-
scoping loading spout that is adjusted to the elevation of the grain
surface as loading proceeds. Ventilation ts applied at the end of
the spout. Tw variations of this system were observed by EPA. The
end of the loading spout on one system was extended Into the grain
surface to minimize the generation of emissions. The other operation
used a "dead box" system at the end of the spout to slow the flow of
8-28
-------
the grain as it entered the hold. The end of the spout was usually
kept a slight distance (six Inches to one foot) above the grain
level in the hold. The second system considered was to cover the
hold with canvas or plastic sheeting except where the loading
spout enters. However, no system of this type was observed in
operation. Participate matter can be ventilated from beneath the
cover to reduce emissions from the hold,
EPA has concluded that the best system of emission reduction
(considering costs) for barge and ship loading operations is a
telescopic loading spout which is adjusted to extend directly Into
the surface of the grain. Approximately 20,000 cfm of ventilation
is applied to the loading spout system, EPA believes, however, that
by covering the entire hold or by using a "dead box" system on the
loading spout, equivalent control can be achieved,
8.3.8 Economic and Environmental Impacts
There will be minimal adverse environmental impacts if the
best system of emission reduction (considering costs) is applied
to each affected facility at grain elevators. As proposed, the
standards would accomplish an overall reduction of more than
9§ percent in uncontrolled particulate emissions from new grain
elevators. This will result in significantly reducing the emissions
of particulate matter to the atmosphere. The existing elevators are
controlled with cyclones while the proposed standards will require the
8-29
-------
use of baghouse control. A typical cyclone is approximately 90 percent
efficient on participate matter from grain elevators while a baghouse
is estimated to be approximately 99 percent efficient.
Estimates for various model grain elevators show that the
proposed standards would reduce partlculate matter emissions to a
level that is 67 to 94 percent less than levels required by typical
State standards. This reduction in emissions results in a significant
reduction of ambient concentrations of partlculate matter in the
vicinity of grain elevators. The maximum 24-hour average concen-
tration at a distance of 0.3 km from the model facilities would be
reduced to a level that is 52 to 76 percent lower than the maximum
concentration that results from control to the levels of typical
State standards. By 1981, the proposed standards would reduce the
total amount of partlculate matter emissions into the atmosphere
by 23,000 tons per year. These estimates indicate that the primary
environmental impact of the proposed standards are beneficial
and also significant. The secondary environmental impacts
of the proposed standard* would be minor. There will be
no impact on water pollution Because only dry collectors would
be used to control particulate emissions. Minimal additional
solid waste handling or disposal problems would be caused by
the standard. Currently, approximately 68 percent of the partlculate
matter collected by emission control devices at elevators is returned
to the grain, 30 percent is sold for use in feed manufacturing and
8-30
-------
2 percent is disposed of as solid waste. The additional participate
matter collected by more efficient control devices will either be
sold for feed or landfilled. Generally* this additional participate
matter will be sold for feed. The market for any one elevator, however,
is dependent upon its location relative to feed manufacturers, EPA
estimates the amount of particulate matter disposed of will remain
at about 2 percent, which woyld amount to about 0.14 pound per ton
of grain. This amounts to only 20 percent of the amount of participate
matter disposed of at an uncontrolled grain elevator. The proposed
standards would have minimal Adverse Impacts on noise and land-use
considerations. A relatively minor amount of partlculate matter,
sulfur dioxide and nitrogen oxides would be discharged into the
atmosphere from power plants supplying the additional electrical
power required for the air pollution control devices needed to achieve the
proposed standards. Overall, there will be a significant positive
effect in reducing the amount of particulate emissions to the
ambient atmosphere.
The Incremental energy required, above the typical State
standard requirements, by the proposed standards to control
all new, modified, or reconstructed grain elevators constructed
by It81 is equivalent to about 17,000 barrels oJF Number 6_fuel oil.
This indicates t&at the proposed standards would &ave a minor
impact on the imbalance between national energy demand and
domestic supply. The energy requirements of the proposed standards
would result from the use of fabric filter control Instead
of the existing cyclone control requirements. The additional
energy that would be reqaired to meet the proposed standards
represents approximately 23 percent of the total process energy
8-31
-------
requirements of new grain elevators. This Is an increase-of
about 5 percent above the energy presently needed to meet typical
State standard requirements for new grain elevators.
Standards of performance for new and modified stationary
sources sometimes result in a more severe economic impact on
smaller firms than larger ones. This occurs primarily because
economies of scale generally favor larger installations and
competitiveness has a greater impact on smaller firms. For
these reasons, EPA has proposed a lower size cut-off, based
on yearly grain through-put of 700,000 bushels. This amount
of grain corresponds to a total leg capacity of 10,000 bushels/
hr and the proposed standards exempt farm, country, terminal
grain elevators and commercial rice dryers that have a total
leg capacity less than 10,000 bu/hr. There is no lower size
cut-off for storage elevators at processing plants, except
commercial rice dryers, because these plants can afford the
necessary controls to meet the proposed standards. Therefore,
the proposed standards would have no adverse impact on small
businesses. The total added production cost in relation to
sales price of the proposed standard is 0.5-perctnt based on
a selling price of $2.40 per bushel for corn. This cost includes
the cost imposed by the standard from the farm to the port
terminal elevator. The maximum cost added at an individual
grain elevator is less than 1 cent per bushel. The costs that
new, modified and reconstructed grain elevators would Incur
to comply with the proposed standards are considered reasonable.
A detailed discussion of the economic considerations evaluated
is presented in Chapter 6 of this document.
8-32
-------
8,4 SELECTION OF THE FORMAT AND EMISSION LIMITS OF THE PROPOSED
STANDARDS
Emission limits and standards for affected facilities at
grain elevators were chosen based on the available data and
information on best systems of emission reduction (considering
costs) discussed in Section 8.3 and Chapter 5. The purpose of
each of the quantitative emission standards is to ensure that
the best system of particulate emission reduction, considering
costs, is applied to each affected facility. In addition, the
standards must be in a form which is enforceable,
Particulate emissions from the affected facilities at a grain
elevator, excluding air pollution control devices, are considered
fugitive emissions. These emissions are discharged from an exhaust area
that is usually very large. Therefore, it is difficult to apply
the usual particulate source test methods designed for measuring
stack emissions to affected facilities at grain elevators. In
addition, numerous difficulties, such -as low exit gas velocity,
skewed exit velocity, variability of particulate concentration
and velocity over the exit area, and the variability in the
design of exhayst areas make source testing Impractical, EPA
has concluded that practical and feasible methods for measuring
the mass of fugitive particulate emissions from affected facilities
at grain elevators are not available at this time. Therefore,
neither mass nor concentration standards have been proposed
for affected facilities at grain elevators. The remaining options
for regulating emissions are visible emission/opacity standards
and equipment standards. For these reasons, the proposed standards
8-33
-------
include visible emission/opacity- standards for six affected
facilities, an opacity standard with the alternative of using
specified equipment for one affected facility, and an equipment
standard for one affected facility. A concentration standard
and an opacity standard are proposed for air pollution control
devices.
The proposed visible emission standards include zero percent,
10 percent, and 15 percent opacity standards and a no visible
emission standard. These various visible emission standards are
necessary because of the different characteristics of the emissions
from the affected facilities. The no visible emission limit means
that an inspector viewing a source would see no visible emissions
without the aid of instruments. This is achievable when an
affected facility is totally enclosed with proper ventilation.
Under this arrangement, no visible emissions escape to the
atmosphere. The emissions from facilities subject to the zero
or greater percent opacity levels would be evaluated according to
EPA Reference Method 9. Reference Method 9 specifies that 24
observations be taken at 15-second intervals and averaged over a
6-minute period. The individual observations are recorded in 5 percent
increments (0, 5, 10, etc.); however, averaging 24 observations may
result in a six-minute average which is not a whole number. The
6-minute average is to be rounded off to the nearest whole number
following the standard rules of rounding (e.g., 0.49 would be rounded
off to 0, 0.50 would be 1, 7.51 would be 8 etc.). This means that
an affected facility subject to a zero percent opacity standard
could have two of 24 observations at 5 percent opacity and the
8-34
-------
other 22 observations at 0 percent opacity and still be in
compliance. The six-minute average in this case would be 0.42
percent and would be rounded off to 0 percent, the nearest
whole number.
GrainPryjrs
The proposed standard for grain dryers limits emissions to zero
percent opacity (six-minute average)» or alternatively column dryers
are in compliance if the column perforation diameters are 2.1 mm
(ca, 0,084 inch) or less and rack dryers are in compliance provided
all exhaust gases pass through a 50 or finer mesh screen filter,
The opacity standard was developed from a total of 130 six-minute
opacity averages taken on five column-type dryers with varying
perforation diameters. Four six-minute averages were rejected
because of the interference of steam in the exhaust. The remainina
126 averages ranged from no visible emissions to one percent opacity,
and the majority were zero percent opacity. Two rack-type dryers were
observed for visible emissions. One was equipped with a 50 mesh
vacuum-cleaned screen (filter) and the other had no screen, A total
of 5 six-mfnute opacity averages, ranging from no visible emissions
to zero percent opacity, were taken at the rack dryer equipped with
the 50 mesh screen. EPA believes that column dryers equipped with
column perforation diameters of 2,1 mm {ca. 0,084 inch) or less
and rack dryers equipped with 50 or finer mesh screens will achieve
the proposed emission limit of zero percent opacity. Therefore,
as an alternative, EPA has proposed the option that a column dryer
may be equipped with column perforations of 2,1 mm (ca. 0.084 inch)
or less and rack dryers may be equipped with 50 or finer mesh screens.
8-35
-------
Ai rPollut 1 on Contrgl_Dey 1 ces
As explained in Section 8.3, EPA concluded that fabric filters
represent the best system of emission reduction (considering costs)
for all of the affected facilities at a grain elevator* except grain
dryers and some types of dust-tight grain handling operations. EPA
measured parti cutate emissions according to Reference Method 5,
except that the p-obe was not heated, from eleven grain processes
controlled with fabric filters.
EPA considered both mass and concentration units for the
proposed standards. The basic difference is that a standard
which restricts the mass rate of emissions would minimize the
total mass emitted, whereas concentration units allow the
rate to increase in direct proportion with the volume of gas
exhausted through the control device. This is an advantage for
concentration units for grain elevators since the concentration
standard does not discourage use of large volumes of ventilation
air. As one might surmize, adequate suction at the collection
hood is necessary for complete capture of the participate matter
generated by the process. Another advantage of concentration
units 1s that the emission test provides all information necessary
for enforcement {determination of mass emissions per volume of
gas discharged through the control device). Mass standards»
however, are usually based on a unit of product o^ raw material
to the process. They require an accurate determination of both
mass emissions and product or raw material weight. The latter
are obtainable only from the operator and are often difficult
8-36
-------
parameters to measure. This is particularly true for grain elevator
operations for the following reasons.
1, The amount of grain handled on conveyor belts, legs,
or cleaners is generally not measured.
2. If more than one process is controlled by a single
collector (i.e., headhouse filter), it way be impossible
to determine the process weight during compliance
testing. When a standard with concentration units is
applicable to each process, compliance for any number
of processes can be determined by only measuring the
concentration from the control device.
The average concentration of participate matter emissions from
all the grain processes tested, excluding one which had high emissions
due to process irregularities, was ,007 gram per standard cubic meter
dry basis. Most of the individual test results were below .023 gram
per standard cubic meter dry basis. Therefore, EPA selected .023
gram per Standard cubic meter dry basis as the emission limit for the
proposed standards. To meet this emission limit, it would be necessary
for grain operations to install and properly operate fabric filter
control systems rather than less effective control systems such as
high efficiency cyclones.
A zero percent opacity standard (based on six-minute averages)
is also proposed for air pollution control devices. EPA observed
two fabric filter systems on grain processes and all of the
individual readings, a total of 56 six-minute averages, were no
visible emissions. EPA believes that the proposed standard of
8-37
-------
zero percent opacity will ensure the proper operation and maintenance
of the air pollution control device.
Truck Unloading
An emission standard of no more than zero percent opacity (six-
minute average) is proposed for truck unloading operations at grain
elevators. A total of 138 six-minute opacity averages have been
gathered by EPA. The range of these six-minute averages is no
visible emissions to 1 (0.83) percent. A total of 120 six-minute
averages were no visible emissions and 17 six-minute averages were
zero percent opacity. Based on the available data, EPA has concluded
that a standard of zero percent opacity can be achieved by the best
technology, considering costs, for twck unloading of grain.
Rail car Unloading ~~
The proposed standard for unloading rail cars, both boxcars
and hopper cars, at grain elevators is no visible emissions. A
total of two hours of visible emission/opacity data was gathered
by EPA on a boxcar unloading operation at a grain elevator. Every
data point, taken at IB-second intervals, was no visible emissions.
Data to substantiate the standard were not collected for hopper
car unloading operations. However, EPA has observed hopper car
unloading operations and believes that unloading of boxcars is
a dustier operation than unloading of hopper cars. Therefore, the
proposed standard applies to both hopper cars and boxcars. Based
on the available data, EPA concluded that no visible emissions
from railcar unloading is achievable.
Barge and Ship Unloading
An equipment standard is proposed for barge and ship unloading
operations at grain elevators. EPA took visible emission/opacity
8-38
-------
observations of a barge unloading operation. The resulting data show
an extremely wide range of opacity, with some six-minute averages
above 65 percent opacity. EPA decided that an opacity standard
could not be set, due to this wide range of six-minute opacity avenges,
that would ensure the use of best demonstrated control technology.
Tnerefore, EPA has proposed a standard which requires the leg to
be enclosed from the top (including tbfe receiving hopper) to the center
line of the bottom pulley with ventilation to a particulate control
device maintained on both sides of the leg and the grain receiving
hopper. The total rate of air ventilated mast be at least 32.1 actual
cubic meters per cubic meter of grain handling capacity (ca» 40 ft3/bu).
Oral n HandTing Operations
The proposed standards would require grain handling operations
to meet a zero percent opacity standard (six-minute average). As
described in Section 8,3, this standard applies to grain handling
equipment located inside of elevator structures (usually neadhouses),
to those located outside of elevator structures and to the elevator
structures themselves. Approximately four hours of visible emission/
opacity data were obtained by EPA on an exterior conveyor and on a
headhouse. These observations were taken concurrently. All of the
data, taken at 15-second Intervals, were no visible emissions.
Separate data were not obtained on every piece of grain equipment
included under grain handling operations. However, the items included
under this affected facility, listed in Section 8.2, were in operation
during the time the headhouse was :being observed. A zero percent opacity
standard has been proposed instead of no visible emissions. Zero
8-39
-------
percent opacity (six-minute average) allows the possibility of slight
emissions from the headhouse. Based on ttiest available data and
information, EPA believes that a zero percent opacity standard is
achievable and will require the use of the best system of emission
reduction (considering costs) for grain handling operations.
Truck loading ' ' "
Truck loading operations at grain elevators will be required
to limit emissions to 10 percent opacity under the proposed standards.
A total of 30 six-minute opacity averages were gathered By EPA
from 9 tryf.k loading operation, The six-minute opacity averages
ranged from one percent to 10 percent. The proposed standard is
based on these data. As explained 1n Section 8.3, EPA believes
that a bitter control system can be designed than the one observed.
However, this operation is the best technology presently available
in the field.
Boxcar and Hopper Car Loading
EPA is proposing a zero percent opacity limit for boxcar loading
and for hopper car loading at grain elevators, EPA believes that a
zero percent opacity limit will require the use of the best control
technologies, considering cost, which are explained in Section 8.3.
A total of 6 six-minute opacity averages were gathered by EPA
on boxcar loading operations. These averages ranged from three
percent to five percent opacity. As explained in Section 8.3, EPA
believes that the boxcar loading operation observed could be main-
tained in better condition toddhave a greater amount of ventilation.
EPA 1s proposing a zero percent opacity standard for boxcar loading
based on a transfer of technology from hopper car loading,
8-40
-------
A hopper car loading operation was observed by EPA personnel
and approximately two and a half hours of visible emission/opacity
data were gathered. Ninety-nine percent of all readings taken, at
15-second intervals, were no visible emissions. There was no
appreciable wind during this observation period. Therefore, EPA
has proposed a zero percent opacity limit to allow for possible
slight particulate emissions during other than ideal conditions.
Barge and Shjj.JL.pa.d1ng
EPA observed ship loading operations at a grain elevator and
gathered approximately six hours of sisible emission/opacity data.
These data were summarized into 67 six-minute averages. EPA further
divided these averages into 18 six-minute averages during the topping
off operation and 49 six-minute averages during normal loading
operations.
Topptng-off fs defined In the regulation as that part of the
barge or ship loading operation which occurs within four feet of
the top of the hold. The six-minute averages taken during topping-
off operations varied greatly and the range was no visible emissions
to 17 percent opacity. Only one six-minute average was above 15 percent
opacity. EPA, therefore, 1s proposing an emission standard of 15
percent opacity during the topping-off period of barge and ship loading
operations. The available data show that this is achievable by the
best demonstrated technology, considering cost.
8-41
-------
The range of the 49 six-minute averages taken during normal
loading operations was no visible emissions to 9 percent opacity.
Based on these data, EPA is proposing an emission standard of
10 percent opacity for normal barge and ship loading operations.
EPA has no data on loading grain Into barges. However, EPA
has observed barge loading operations and considers barge and ship
loading operations to be similar and has concluded that the above
mentioned standards apply to barge loading as well as to ship loading,
8.5 MODIFICATION AND RECONSTRUCTION CONSIDERATIONS
Two actions that would render an existing elevator subject
to the standards of performance for new sources are "modification"
or "reconstruction," All of the pollution sources at grain elevators
have been classified by EPA Into eight affected facilities. This allows
each tffected facility to be modified or reconstructed without
causing the entire grain elevator to be subject to the proposed
standards* If the equipment or operations at an affected facility
are altered 1n a manner which increases air pollution, that
facility may become subject to the standards 1n accordance with
section m(a){45 of the Clean Air Act. Regulations to implement
this provision have been promulgated in 40 CFR SO and amendments to these;
general provisions were promulgated in 40 CFR on December 16, 1975.
Modifications
Modification of an existing facility is any physical change
In, or change in the method of operation of that faciltty which
requires a capital investment and increases the amount of particulate
8-42
-------
emitted to the atmosphere [provided the amount of particulate
emitted to the atmosphere increases as specified in 40 CFR 60.14(b)
or which results in the emission of any air pollutant (to which
a standard applies) into the atmosphere not previously emitted^.
Any change in a facility that results in an increase in the
uncontrolled emission rate (in kilograms per hour) is not considered
a modification if the emission rate to the atmosphere is maintained
at the same level by upgrading the collection system. Also, an
increase in the emission rate to the atmosphere can be permitted
at one affected facility if the operator can demonstrate-te the
Administrator's satisfaction that the total emission rate from
all existing affected facilities at the stationary source has not
increased. Examples of modifications to elevators are increases
in the grain handling capacity of unloading systems, cleaners,
dryers, conveyors, legs, scales, storage capacity, or loading
systems, which result in increased particulate emissions (kg/h)
to the atmosphere. This would occur if a grain elevator were to
upgrade its facilities to take advantage of unit train discount
rates.
The following are not considered modifications:
1. An increase in grain through-put which is accomplished
without making physical eftinges requiring capital
expenditure (i.e., by increasing operating time),
2, Changes to an emission control system, except when the
replacement system is considered less efficient by
the Administrator.
8-43
-------
3. Addition of storage capacity without an increase in
air pollution,
Reconstruction
An "existing facility" would become subject to the standards of
performance for new sources upon reconstruction, irrespective of any
change in emission rate. Reconstruction entails the replacement of
components of an existing facility to such an extent that 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, provided it is technically and economically feasible
to meet the applicable standards.
Examples of reconstruction are:
1. Replacement of a facility destroyed by fire, flood,
tornado, or other catastrophe, and
2., Replacement of a substantial portion of the conveyors,
legs, or other grain handling equipment with equipment
of the same capacity.
8.6, SELECTION OF MONITORING REQUIREMENTS
Continuous opacity monitoring systems are not required on
the control device exhausts because estimated costs of procurement,
installation and start-up are relatively high (usually more than
ten percent) compared to the investment costs of the control systems
for grain elevators. The costs of monitoring were judged not to
be reasonable by EPA, even though enforcement of the standard
would be enhanced by the installation of monitors.
8-44
-------
8-7 SELECTION OF PERFORMANCE TEST
In developing the data base for standards of performance for
new sources and in specifying a reference method for use in compliance
testing, several factors are of primary importance:
(a) The method used for data gathering and the method
subsequently established as the reference method
must be the same, or must have a known relationship
to each other.
' " «
(b) The method should measure pollutant emissions which
are indicative of the performance of theblest systems
of emission reduction.
(c) The method should include methodology conducive to producing
consistent and reliable test results.
For particulate matter emissions from stacks, EPA relies primarily
upon Method 5 which meets these three criteria.
Method 5 was used to obtain the data base for the particulate
emissions concentration standard for new grain elevators; however,
the mithod was not used exactly as prescribed in the Federal Jjejister
(EPA, NSPS, Federal1 Register, 3f(247>' 24882-24895). The electric
heating"systems for the probe and filter holder were not used for
two reasons. First, the gas streams sampled were essentially ambient
streams, of low temperature and moisture content. Consequently,
even without the heaters, no significant amount of water vapor
would condense ahead of the impingers. Second, grain dust {particulate), when
emitted in sufficiently high concentrations, presents an explosion
8-45
-------
hazard; use of the electrical systems presents a possible source
of accidental Ignition.
Tht effect of operating the sampling train without heaters
was that the participate collection took place at stack (ambient)
temperature* rather than at 250°F. Thus, for this type of source,
in-stack and out-of-stack filtration methods (whichever method
1s used, the collection temperature is the same) can be considered
equivalent provided that the in-stack filter does not appreciably
affect velocity measurements and adequate leak check procedures
are followed.
In light of this, two reference methods are being proposed for
compliaace testing for the particulate emissions concentration
standard at new grain elevators: (1) Method 5 with the probe and
filter heaters off, and (2) Method 17, a modification of Method 5,
in which an in-stack filter replaces the glass probe and out~e€fstack
filter. Method 17 employs the type of filter and other sampling
procedures asr.are used in Method 5. Method 17 involves only minor
modification of existing equipment and, by eliminating the need for
a glass-lined probe and a rigid probe-to-fHttr holder connection,
results 1n a simplification of compliance test procedures. Reference
Method 17 has already been proposed in the New Source Performance
Standards for Kraft Pulp_Mills.
Method S is the reference method which EPA has developed
for compliance testing of opacity standards. This method has
already been promulgated.
Grain dryers typically exhaust directly from the outlet of the
control device to the atmosphere without the use of an exhaust stack.
The cross sectional area of the outlets is generally quite large.
8-46
-------
The resulting low velocities and unconflned flow are not amenable to
sampling with conventional techniques. Therefore, during the develop-
ment of the standards of performance, attempts were made to develop
methodology which would allow representative sampling. Since hooding
could cause exhaust pressure buildup and upset the drying process,
the procedures which were employed focused upon techniques for
measuring low velocities, and for obtaining renresentative samples
unaffected by crosswinds. Both a hot wire anemometer, and special
pi tot tube technique were used in attempts to accurately measure
velocity, A three-foot section of 12-inch diameter duct was placed
perpendicular to the exhaust outlet to serve as a mini-stack. Sampling
was conducted at the center of the duct section while the duct section
was traversed across the control device outlet. Based upon the
experience gained during two tests employing these techniques, 1t was
concluded that sampling results of acceptable accuracy could not be
obtained. Both the problem of crosswinds, and the strong vertical
component present in the exhaust gas flow which varies from source to
source were identified as primary factors preventing obtainment of
representative samples.
8-47
-------
APPENDIX A
EVOLUTION OF THE
A-1
-------
APPENDIX A
EVOLUTION OF THE PROPOSED STANDARDS
PO
Date
7/1/71
7/14/71
7/20/71
7/20/71
7/20/71
7/27/71
7/27/71
7/28/71
7/29/71
8/71
Company, Consultant
or Agency
EPA
American Feed Manu-
facturers Associa-
tion
Central Soya
CargHI Inc.
Continental Grain
Co,
Bunge Co.
FAR-MAR-CO
Kansas Grain and
Feed Dealers
Association
Farmland Ibdustries.
Inc.
Dr. A.T. Rossano,
Univ. of Washington
Location
Durham, N.C.
Chicago, 111.
Chicago, 111.
Chicago, 111.
Chicago, 111.
Hutchinson, Kansas
Hutchinson, Kansas
Hutchinson, Kansas
Kansas City, Mo.
Seattle, Wash.
Nature of Action
Initiation of engineering and cost study of the
Grain and Feed Industry, contracted to Midwest
Research Institute.
EPA met with AFMA to discuss the purpose and goals
of the engineering and cost study and solicit mutual
cooperation.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operati ans.
Inspection to locate well controlled grain handling
operati ons.
ERA met with Dr. Rossano to discuss recent air
pollution investigations at a new port terminal
elevator in Seattle.
-------
APPENDIX A (continued)
EVOLUTION OF THE PROPOSED STANDARDS
3*
I
Date
8/71
8/71
8/71
8/71
8/71
9/71
9/71
9/71
9/71
9/71
Company, Consultant
or Agency
Puget Sound Air
Pollution Control
Agency
Marshall-Barr-Pacquer,
Industrial Consulting
Engineers
Mel Jarvis Construction
Co., Inc.
Barton, Inc.
Kice Metal Products
Co,
National Grain and
Feed Association
Hart-Carter Co.
Carglll, Inc.
Aerodyne Develop-
ment Corp.
Aeroglide Corp.
Location
Seattle, Wash,
Seattle, Wash.
Salina, Kansas
Hutchinson, Kansas
Wichita! Kansas
Washington, D.C.
Minneapolis, Minn.
Minneapolis, Minn.
Cleveland, Ohio
Raleigh, N.C.
Nature of Action
EPA met with PSAPCA to discuss emission standards
for grain elevators and emission test data.
EPA-met with representatives of Marshall-Barr-
Pacquer to discuss the design features of new grain
elevators.
EPA met with representatives of Mel Jarvis
Construction Co., Inc. to discuss the design
features of new grain elevators.
EPA met with representatives of Barton, Inc. to
discuss the design features of new grain elevators.
EPA met with representatives of Kice Metal Products
Co. to discuss the design features of new grain
elevators.
EPA met with the Chairman of the Environmental
Quality Committee of NGFA to discuss financial
data required for the economic analysis.
EPA met with representatives of Hart-Carter to
discuss control of grain dryers and other grain
operations,
EPA met with representatives of Cargill to discuss
design of control systems for Cargill elevators.
EPA met with representatives of Aerodyne to discuss
design of control systems for new elevators.
EPA met with representatives of AerotjUde to discuss
grain dryer operation, costs and control techniques.
-------
APPENDIX A (continued)
EVOLUTION OF THE PROPOSED STANDARDS
Date,
9/71
9/16/71
10/12/71
10/21/71
10/71
12/9/71
3/16/72
3/17/72
3/72
4/12/72
4/12/72
4/13/72
Company, Consultant
i orAgency
Illinois Environmental
Protection Agency
CargW, Inc.
Wyandotte Elevator
Pillsbury Co,
Pillsbury Co.
Koppel Terminal
Elevator
The Andersons
Gold Proof Elevator
Carglll, Inc.
Continental Grain
Co.
Mississippi River
Elevator Co,
Bayslde Elevator
Co.
Location
Springfield, 111,
Tuscola, 111,
Kansas City, Kansas
Florence, 111.
Wayne City, 111.
Long Beach, Ca.
Marimee, Ohio
Louisville, Ky.
Tuscola, 111.
Westwego, La.
Myrtle Grove, La,
Reserve, La.
Nature of Action
EPA met with representatives of the Illinois EPA
to discuss emission standards for grain elevators ,
and complaints that have been received on grain
processes. *
Inspection of air pollution control systems at an
Inland terminal elevator.
Inspection of air pollution control systems at an
inland terminal elevator.
Inspection of a river terminal elevator.
Inspection of a country elevator.
Inspection of air pollution control systems at a
port terminal elevator.
Inspection to locate well controlled grain handling
operations.
Inspection of a controlled grain dryer.
Particulate matter emission tests of truck unloading
and grain handling facilities.
Inspection of a controlled barge unloading facility.
Inspection to locate a well controlled port terminal
elevator.
Inspection to locate a well controlled port terminal
elevator.
-------
APPENDIX A (continued)
EVOLUTION OF THE PROPOSED STANDARDS
Date
5/16/72
5/18/72
5/19/72
5/30/72
5/31/72
6/1/72
7/72
8/9,10/72
9/7/72
10/17-19/72
11/28-30/72
12/7/72
Company, Consultant
or Agency
San Francisco Grain
Terminal Co.
Dreyfus Elevator Co,
Cargill, Inc.
Farmers Marketing
Association
Cargill, Inc.
Adolph Cows Co.
Kansas City Terminal
Elevator
Cargill, Inc.
Quaker Oats Co.
Continental Grain
Co.
Cargill, Inc.
Seaboard Allied
Milling Co.
Location
San Francisco, Ca.
Portland, Oregon
Seattle, Wash.
Denver, Colorado
Denver, Colorado
Solden, Colorado
Kansas City, Mo.
Fayetteville, N.C.
Chattanooga, Tenn.
Westwego, La.
Denver, Colorado
Culpepper, Va,
Nature of Action
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operations,
Inspection of grain storage facilities to locate
well controlled grain handling operations.
Inspection to locate well controlled grain handling
operations.
Particulate matter emission testing of truck unloadi
facility.
Inspection of a controlled grain dryer.
Particulate matter emission testing of a barge
unloading facility.
Particulate matter emission testing of a grain dryer
Inspection of a floyr mill to locate well controlled
grain handling and cleaning operations.
-------
Ol
Date
Company, Consultant
Agency
APPENDIX A (continued)
EVOLUTION OF THE PROPOSED STANDARDS
Location
1/10/73
3/12/73
3/15/73
3/15/73
3/15/73
3/15/73
3/15/73
3/15/73
3/15/73
3/15/73
3/28/73
San Francisco, Grain
Terminal
Pillsbury Co.
PHlsbury Co.
Farmers Terminal
Elevator
Ferruzzi and Co.
Continental Grain
Co.
Farmers Elevator Co.
Cargill, Inc.
Continental Grain
Co.
Illinois Grain Co.
Bunge Elevator
San Francisco, Ca.
Wayne City, 111,
Florence, 111.
Beardstown, 111.
Beards town, 111.
Beardstown, 111.
Bluff Springs, 111.
Havana, 111.
Havana, 111.
Havana, 111.
Destrehan, La.
Nature of Action
Particulite matter emission testing of grain
handling operations,
Inspection of a controlled railroad hopper car
loading facility.
Inspection of controlled barge loading facility.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operatlons.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operati ons.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operations.
-------
APPENDIX A (continued)
EVOLUTION OF THE PROPOSED STANDARDS
Date
3/28/73
3/28/73
3/29/73
4/2-5/73
4/23-27/73
6/4/73
7/24,25/73
10/2-6/73
10/16-19/73
10/29-31/73
11/13-16/73
1/24/74
Company, Consultant
or Agency
St. Charles Grain
Elevator
Cargill, Inc.
Mississippi River
Elevator
Quaker Oats Co.
Seaboard Allied
Milling Co.
Cargill, Inc.
Grain and Feed
Industry Advisory
Committee
Cargill, Inc.
Kansas City Terminal
Elevator
Bunge Corp.
Quaker Oats Co,
Bunge Corp.
location.
Destrehan, La.
Baton Rouge, La.
Myrtle Grove, La.
Chattanooga, Tenn.
Culpepper, Va.
Seattle* Wash.
Durham, N.C.
Seattle, Wash.
Kansas City, Mo.
Destrehan, La.
St. Joseph, Mo.
West Memphis, Arkansas
Nature of Action
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operations.
Inspection to locate well controlled grain handling
operations.
Particulate matter emission testing of a grain dryei
Particulate matter emission testing of a grain
cleaning operation.
Inspection to locate well controlled grain handling
operati ons.
EPA met with GFIAC to review the final report pre-
pared by MRI on the grain industry.
Particulate matter emission testing of railroad
boxcar unloading and ship loading facilities.
Particulate matter emission testing of railroad
hopper car loading facilities.
Particulate matter emission testing of barge
unloading equipment.
Particulate matter emission testing of grain'dryer.
Sent 114 letter requesting air pollution control
cost information.
-------
APPENDIX A {continued}
EVOLUTION OF THE
i
CO
Date
1/24/74
2/2S/74
3/74
4/18/74
4/22/74
11/74
12/2/74
12/3/74
1/75
Company, Consultant
or Agency
Quaker Oats Co,
Dept. of the Environ-
ment
National Grain and
Feed Association
Jarvis Construction
Co.
Barton Inc.
EPA
Cargill, Inc.
Bunge Corp,
EPA
Chicago, 111.
Ottawa, Ontario,
Canada
Washington, D.C,
Salina, Kansas
Hutchinson, Kansas
Research Triangle
Park, N.C.
Minneapolis, Minn.
West Memphis, Arkansas
Research Triangle
Park, N.C.
Nature of Action
Sent 114 letter requesting air pollution control
cost Information.
Received letter requesting Information on emission
standards, emission factors and control techniques.
Sent copies of Ern1ss1ons_ Control in the Grain and
FeedIndustry, ^j^'^lH'^ngTK^^ ng and Cos t Study
to be distributed to the industry,
Telephone conversation regarding the number of grain
elevators under construction, their capacity, and the
air pollution control equipment being installed.
Telephone conversation regarding the number of grain
elevators under construction, their capacity, and the
air pollution control equipment being installed.
Memorandum from L. Budney} Source-Receptor Analysis
Branch, to S.T. Cuffe, Chief, Industrial Studies
Branch, "Methodology for Estimating the Impact of
Grain Elevator Emissions on A1r Quality."
Telephone conversation to determine the amount of
grain dust sold, disposed of and returned to the gral
Telephone conversation to determine the value of
grain dust.
Memorandum from K, Woodard to J, Berry, Industrial
Studies Branch, on telephone calls to determine
solid waste disposal and energy requirements at
grain elevators.
-------
Date
Company, Consultant
or Agency
APPENDIX A (continued)
EVOLUTION OF THE PROPOSED STANDARDS
Location
1/21/75
2/19/75
3/2/75
3/7/75
¥" 3/13/75
10
3/13/75
3/17/75
4/24/75
5/15/75
7/28/75
8/27/75
EPA
EPA
Cargill , Inc.
H.C.'WIedenmann
and Son, Inc.
H.C. Wiedenmann
and Son, Inc.
Supreme Rice Mills
CEA-Carter-Day Co.
Corn Refiners
Association
Atroglide Corp.
National Grain and
Feed Association
National Council of
Durham, N.C.
Atlanta, Ga,
Minneapolis, Minn
Kansas City, Mo.
Kansas City, Mo.
Crowley, La,
Minneapolis, Minn
Research Triangle
Park, N.C.
Durham, N.C.
Durham, N.C.
Denver, Colorado
Nature of Action
Farmer Cooperatives
EPA Working Group reviewed the recormended
standards.
Review of the recommended standards by the National
Air Pollution Control Techniques Advisory Committee
(NAPCTAC),
Telephone conversation from F.L. Bunyard, EPA, to
D. Enge, Cargill„ regarding costs.
Letter from F.L. Bunyard, EPA, to R. No!and,
Wledenmann, regarding costs.
Letter from R. No!and, Hiedenmann, to F.L. Bunyard,
EPA, regarding costs.
Inspection of rice mill to compare with grain
handling operation.
Letter from L. Funk, Carter-Day, to F.L. Bunyard,
EPA, regarding costs.
EPA met with CFA to discuss the recommended standan
and control techniques required.
EPA met with representatives of Aeroglide to discus:
the recommended standards for gnin dryers.
EPA met with NGFA to discuss the recommended
standards.
EPA met with NCFC to discuss the recommended
standards.
-------
APPENDIX A (continued)
EVOLUTION OF THE PROPOSED STANDARDS
3*
i
Company, Consultant
Date
9/22-25/75
9/24/75
9/29/75
9/30/75
10/14/75
10/15/75
10/15/75
10/15/75
10/15/75
10/16/75
or Agency
Carglll, Inc.
Continental Grain
Co.
Carglll, Inc.
PHlsbury Co.
Mlnler Co-Op.
Grain Co.
Tremont Co-Op.
Grain Co,
San Jose Co-Op,
Grain Co.
Farmers Grain
and Coal Co,
Illinois Grain
Corp.
Roanoke Farmers
Location
Seattle, Wash.
Tacoma, Wash.
Tuscola* 111.
Wayne City, 111,
Minier, 111.
Tremont, 111.
San Jose, 111.
Mason City, 111.
Havana, 111.
Roanoke, 111,
Nature of Action
Assocation
Inspection of port terminal elevator to take
visible tnrfssIon/opacity observations of ship
loading, truck unloading, boxcar unloading, and
grain handling facilities.
Inspection of ship loading facilities at a port
terminal elevator.
Inspection to take visible emission/opacity obser-
vations of truck unloading facility and the fabric
filter on the facility.
Inspection to take visible emission/opacity obser-
vations of a hopper car loading facility.
Inspection of a column dryer at a country elevator.
Inspection of a column dryer to take visible emission
opacity observations.
Inspection of a column dryer at a country elevator,
Inspection of a column dryer to take visible emission,
opacity observations.
Inspection of a column dryer at a river port terminal
elevator.
Inspection of two column dryers and one rack dryer
to take visible emission/opacity observations.
-------
APPENDIX A (continued)
EVOLUTION OF THE PROPOSED STANDARDS
Date
11/21/75
12/4/75
2/3/76
2/4/76
2/24/76
3/76
3/76
4/5/76
4/5/76
Company, Consultant
or Agency
Cargill, Inc.
Aeroglide Corp,
Swift Edible Oil
Co.
Cargm, Inc;
Carglll, Inc.
Winamae Construction
Co.
Ruttman Compinles
Todd and Sargent
Construction Co.
Jarvis Construction
Co.
location
Fayettevllle, N.C.
Durham, N.C.
Des Molnes, Iowa
Minneapolis, Minn.
Denver, Colorado
Wlnamac, Indiana
Upper Sandusky, Ohio
Ames, Iowa
Salina, Kansas
Nature of Action
Inspection of a processing plant to take visible
emission/opacity observations of a fabric filter
on a truck unloading facility.
EPA met with representatives of Aeroglide to
discuss the recommended standards for grain dryers.
Inspection of soybean processing plant to take
visible emission/opacity observations of a soybean
meal truck loading operation.
Inspection of a terminal elevator to take visible
emission/opacity observations of a boxcar loading
facility.
Inspection of an Inland terminal elevator to take
visible emission/opacity observations of a hopper
car loading facility.
Telephone conversation concerning costs between
F.L. Bunyard, EPA» and P. Kruzick, Winamac Construct
Co.
Telephone conversation concerning costs between
F.L. Bunyard, EPA, and L. Allen, Ruttman Ind,
Telephone conversation concerning lower size cutoff
for standards between N. Swanson, EPA, and Warren
Sargent, Todd and Sargent.
Telephone conversation concerning lower size cutoff
for standards between N. Swanson, EPA, and D. Otis,
Jarvis Construction Co.
-------
APPENDIX A (continued)
EVOLUTION OF THE PROPOSED STANDARDS
5*
Date
4/30/76
6/25/76
7/15/76
8/13/76
8/25/76
9/1/76
10/26/76
11/3/76
11/18/76
Company, Consultant
orAgency
EPA
EPA
EPA
National Grain and
Feed Association
Carpi 11, Inc.
Dept, of Agriculture
Dept. of Agriculture
and Office of Manage-
ment and Budget
EPA
EPA
Location
Durham* N.C.
Washington, D.C.
Washington, D.C,
Durham, N,C.
FayetteviHe, N.C.
Washington, D.C.
Washington, D.C.
Mash1n§ton, D.C.
Washington, D.C.
Nature of Action
EPA Working Group reviewed the recommended standards,
The EPA Steering Committee reviewed the recommended
standards.
The recommended standards package started external
review by Federal agencies and departments.
EPA met with NGFA to discuss their comments on the
recommended standards.
Inspection of soybean processing plant to take
visible emission/opacity observations of a rack
dryer equipped with a 50 mesh screen filter and
a column dryer.
EPA met with the Dept. of Agriculture to discuss
their canwints on the recommended standards.
EPA met with the Dept. of Agriculture and OMB to
discuss eonments on the recommended standards.
The recommended standards package completed external
review by Federal agencies and departments.
The package was forwarded to Washington for final
EPA concurrence.
-------
APPENDIX B
INDEX TO ENVIRONMENTAL IMPACT CONSIDERATIONS
B-1
-------
ihis inaex consists or a reference system, cross-indexed
with the October 21, 1974, FEDERAL REGISTER (39 FR 37419) con-
taining the Agency guidelines concerning the preparation of.
Environmental Impact Statements. This index can be used to
identify sections of the document which contain data and
information germane to any portion of these FEDERAL REGISTER
guidelines.
B-2
-------
INDEXED SYSTEM TO HIGHLIGHT
ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT
Agency Guideline for Preparing Regulatory Action
Environmental Impact Statements (39 FR 37419)
Location Within the Standards Support
and Environmental Impact Statement
1. Background and description of the proposed action.
-Describe the recommended or proposed action and
its purpose.
03
I
ca
-The relationship to other actions and proposals
significantly affected by the proposed action
shall be discussed, including not only other
Agency activities but also those of other
governmental and private organizations.
Alternatives to the proposed action.
-Describe and objectively weigh reasonable
alternatives to the proposed action, to. the
extent such alternatives are permitted by the
law... For use as a reference point to which
other actions can be compared, the analysis
of alternatives should include the alternative
of taking no action, or of postponing action.
In addition, the analysis should include
alternatives having different environmental
impacts, including proposing standards, criteria,
procedures, or actions of varying degress of
stringency. When appropriate, actions with
similar environmental impacts but based on
different technical approaches should be
discussed. This analysis shall evaluate
alternatives in such a manner that reviewers
can judge their relative desirability.
The proposed standards are summarized in Chapter 1,
Section 1.1. The statutory basis for the proposed
standards (Section 111 of the Clean Air Act, as amended)
is discussed in the Introduction. The purpose of the
proposed standards is discussed in Chapter 8, Sections 8.1
and 8.2.
To the knowledge of EPA, there are no other actions or
proposals at this time which will be significantly
affected by this proposed standard.
The alternative control systems, .based upon the best
combinations of control techniques, are presented in
Chapter 4, Section 4.5. A discussion of the alternative
of taking no action and that of postponing the proposed
action is presented in Chapter 7, Sections 7.6.2 and
7.6.3 and in Chapter 1, Section 1,2. The alternative
systems are discussed throughout the document in the
evaluation of the environmental'and economic impacts
associated with the proposed standards.
The selection of the best system of emiss.ion reduction,
considering costs, is presented in Chapter 8, Section 8.3,
The alternative formats of the proposed standards and the
rationale for the selection of the proposed formats are
discussed in Chapter 8, Section 8,4. Also discussed 1n
Section 8.4 are the emission limits for particulate
matter and the rationale for their selection.
-------
INDEXED REFERENCE SYSTEM TO HIGHLIGHT
ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT
Agency Guideline for Preparing Regulatory Action
Environmental Impact Statements (39 FR 37419}
Location Within the Standards Support
and Environmental Impact Statement
-The analysis should be sufficiently detailed to
reveal the Agency's comparative evaluation of
the beneficial and adverse environmental, health
social, and economic effects of the proposed
action and each reasonable alternative.
-Where the authorizing legislation limits the
Agency from taking certain factors into account
in its decision making, the comparative evalua-
tion should discuss all relevant factors, but
clearly identify those factors which the
authorizing legislation requires to be the
basis of the decision making.
-In addition, the reasons why the proposed
action is believed by the Agency to be the
best course of action shall be explained.
A summary of the environmental and economic impacts
associated with the proposed standards is presented
in Chapter 1» Section 1.2.
A detailed discussion of the environmental effects of
each of the alternative control systems can be found
in Chapter 7. This chapter includes discussion of
the beneficial and adverse impacts on air, water, solid
waste, energy, noise, radiation and other environmental
consideration.
A detailed analysis of the costs and economic impacts
associated with the proposed standards can be found in
Chapter 6,
The factors which the authorizing legislation requires
to be the basis of the decision making are discussed
in the Introduction.
The rationale for the selection of particulate matter
emissions from grain elevators for control under the
proposed standards is discussed in Chapter 8, Section 8.1
-------
CROSS INDEXED REFERENCE SYSTEM TO HIGHLIGHT
ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT
Aqeney Guideline for Preparing Regulatory Action
Environmental Impact Statements (39 FR 37419)
Location Within the Standards Support
and Environmental Impact Statement
3, Environmental impact of the proposed action.
A. Primary impact
Primary impacts are those that can be
attributed directly to the action, such as
reduced levels of specific pollutants
brought about by a new standard and the
physical changes that occur in the various
media.with this reduction.
O3
I
tn
B. Secondary impact
Secondary impacts are indirect or induced
impacts. For example, mandatory reduction
of specific pollutants brought about by
a Jn&a standard could result in the adoption
of control technology that exacerbates another
pollution problem and would be a secondary
impact,
Other considerations,
A. Adverse impacts which cannot be avoided
should the proposal be implemented. Describe
the kinds and magnitudes of adverse impacts
which cannot be reduced in severity to an
acceptable level or which can be reduced to
an acceptable level but not eliminated. These
may include air or water pollution, damage
to ecological systems, reduction in economic
activities, threats to health, or undesirable ,
land use patterns. Remedial, protective, and
mitigative measures which will be taken as
part of the proposed action shall be identified.
The primary impacts on mass particulate emissions and
ambient air quality due to the alternative control
systems are discussed in Chapter 7, Section 7.1. Primary
impacts are summarized in Table 1-2, Matrix of Environ-
mental and Economic Impacts of the Alternative Systems,
Chapter 1» Section 1.2.
The secondary environmental impacts attributable to the
alternative control systems are discussed in Chapter 7.
These impacts are summarized in Table 7-1, Adverse
Secondary Environmental Impacts of Individual Control
Techniques Over SIP Requirements, Chapter ?-, Introduction
A summary of the potential adverse environmental and
economic impacts associated with the proposed standards
and the alternatives that were considered are discussed
in Chapter 7 and in Chapter 1» Section 1.2.
-------
CROSS REFERENCE SYSTEM TO HIGHLIGHT
ENVIRONMENTAL IMPACT PORTIONS OF THE DOCUMENT
Agency Guideline for Preparing Regulatory Action
Environmental Impact Statements (39 FR 37419)
Location Within the Standards Support
and Environmental Impact Statement
30
OV
Relationship between local short-term uses
of man's environment and the maintenance
and enhancement of long-term productivity.
Describe the extent to which the proposed
action involves trade-offs between short-
term environmental gains at the expense of
long-term losses, or vice versa and., the extent
to which the proposed action forecloses
future options. Special attention shall be
given to effects which pose long-term risks
to health or safety. In addition, the
timing of the proposed action shall be
explained and justified.
Irreversible and irretrievable commitments
of resources which would be involved in
the proposed action should 1t be implemented.
Describe the extent to which the proposed
Bction curtails the diversity and range of
beneficial uses of the environment. For
example, irreversible damage can result if
a standard is not sufficiently stringent.
The discussion of the use of man's environment is included
in Chapter 7, Section 7.6.1. A discussion of the effects
of particulate matter from grain elevators is included in
Chapter 8, Section 8.1.
Irreversible and irretrievable commitments of resources
are discussed in Chapter 7, Section 7.6.1,
-------
APPENDIX C
TEST DATA
C-l
-------
EMISSION SOURCE TEST DATA SUMMARY
INTRODUCTION
This section presents the summaries of the particulate source
tests cited in Chapter 5. In addition, each facility tested for
mass participate data and for visible emission data is described.
The facilities are identified by the same coding that is used in
Chapter 5. All of the visible emission/opacity data and the
mass particulate source test data from grain dryers are presented in
summarized form in Chapter 5.
EPA Reference Method 5, promulgated in the\ federal Register
on December 23, 1971 (36 FR 24877), was used to gather the data
to support the proposed particulate standards. Method 5 was not
used exactly as prescribed in the Federal Register. The electrical
heating systems for the probe and filter holder were not used
because the gas streams sampled were of low temperature and moisture
content and grain dust (particulate matter) presents a possible
explosion hazard.
DESCRIPTION OF FACILITIES AND SUMMARY OF RESULTS
A. Facility A is a tructe unloading station at an inland
terminal elevator with a shed with one open end and a deep
receiving hopper. It has two lanes, side by side» so that two
trucks can be unloaded at the same time. Both receiving
hoppers are ventilated to a fabric filter. During the particu-
late tests of the fabric filter, corn was the only grain unloaded.
The process was operating normally. A rectangular extension was
C-2
-------
added to the fan exhaust and three participate samples were
col1ected.
Corn and soybeans were being unloaded during the visible
emission/opacity ttsts which were conducted at a later date
than when the particulate tests of the fabric filter ware run.
Both fugitive particulate emissions and emissions from the fabric
filter were observed, A summary of the visible emission data
can fae found in Chapter 5,
B. Facility B is a truck unloading station at a soybean
processing plant with a shed with too open ends. The receiving
hopper is undersized so there is some choke-feed effect. The
receiving hopper is ventilated to a fabric filter located
beside the unloading shed. Only soybeans are unloaded at this
facility. Normal unloading operations were maintained. Three
particulate samples were collected.
Visible emission/opacity observations were made at the
fabric filter exhaust at a later dite than when the particulate
tests were run. A summary of the visible emission data obtained
is included in Chapter 5.
C. Facility C is a railroad boxcar unloading station at
a port terminal elevator. It is a two-laned facility enclosed
by a shed with quick-closing doors it each end. The receiving
hopper is ventilated to a fabric filter. The doors at one
end of the shed remained open during the particulate testing
of the fabric filter. The process was operating normally during
C-3
-------
the testing period and wheat was the only grain unloaded. Three
particulate samples were collected at the inlet and outlet of
the fabric filter.
Fugitive visible emission/opacity observations were con-
ducted at a later date than the participate testing at this facility.
Both doors on the ends of the shed were kept closed, during the
unloading operation, throughout the observation period. Chapter 5
includes a summary of the visible emission data obtained at this
facility.
D. Facility D is barge unloading equipment at a port
terminal elevator. The leg, receiving hopper, and conveyor
belt transfer points are partially enclosed and are ventilated
to a fabric filter. Three particulate samples were collected
at the outlet of the fabric filter. Wheat was unloaded during
the first particulate test and corn was unloaded during the
last two tests. The leg was operating at full capacity throughout
the testing period.
Fugitive visible emission/opacity observations were taken
concurrently with the particulate tests. The opacity reader was
not qualified to read opacity at this time. The visible emission
data obtained at this facility are summarized in Chapter B.
E. Facility E is barge unloading equipment at a port terminal
elevator. The leg and receiving hopper are fully enclosed and the
conveyor transfer points are hooded. These grain handling equipment
C-4
-------
are ventilated to a fabric filter. The leg operated at full
capacity throughout the tests as barges of soybeans and corn
were unloaded. Three particulate samples were collected at the
filter inlet and outlet.
Fugitive visible emission/opacity observations were taken
concurrently with the particulate tests. The opacity reader
was not qualified to read opacity at this time. The observer
was also forced to face into the sun because of the location
of the river. The visible emission data obtained are summarized
1n Chapter 5.
F. Facility F consists of three conveyor belts under the
storage bins at a port terminal elevator. The conveyor belts are
hooded along their entire lengths. The conveyor system is
ventilated to a fabric filter from several points along the hooding
system and from where the grain transfers to the elevator legs.
The process was operating normally with one conveyor belt carrying
grain during the particulate tests. Five particulate samples
were collected at the fabric filter outlet. Milo was handled
during the first four tests and wheat was handled during the
fifth test. The results of the fourth test are exceptionally
high due to the apparent contamination of the milo tested.
G. Facility G is a conveyor belt system transferring grain
from truck receiving hoppers to an elevator leg. The conveyor
system is ventilated to i fabric filter from the points where
the grain drops from the hoppers onto the belt and where the
grain discharges into the leg. The conveyor belt has no hooding
C-5
-------
system. Corn was hand!id during the tests and the process
operated normally. Three particulate samples were collected
at the fabric filter outlet.
H. Facility H is a wheat cleaning system at a flour mill.
Several pieces of cleaning equipment used to separate chaff, dirt,
weed seeds, foreign grains and unsound kernels from the wheat
are ventilated to a fabric filter. The cleaning system operated
at capacity during the particulate emission tests. Three
particulate samples were collected at the fabric filter outlet.
I. Facility I is a com cleaner at an inland terminal
elevator, The cleaner is ventilated to a fabric filter from the
points where the corn enters and leaves the cleaner. Only one
particulite sample could be collected since the cleaner is operated
infrequently. The cleaner was operated at maximum capacity
during the particulate emission test.
J. Facility J is a ship loading station at a port terminal
elevator. Telescoping loading spouts were maintained within
six inches of the grain surface and the ends of the spouts are
ventilated to a fabric filter. The process operated normally
and wheat was being loaded. Three particulate samples were
collected at the fabric filter outlet.
Fugitive visible emission/opacity observations were taken
it a later date than when the particulate emission tests were run.
Two ships were observed while wheat was being loaded. Start-up
loading, general loading and "topping-off" operations were observed.
A summary of the visible emission data from this facility 1s included
in Chapter 5.
C-6
-------
K. Facility K is a railroad boxcar and hopper car loading
station at an inland terminal elevator. The loading area is
enclosed in a shed with two open ends. A stationary hood is
located beside the railroad track and surrounds the loading
spout for boxcars. A long rectangular hood is located above
the center of the'hopper cars to collect particylati matter
from the hopper car loading operation. These hooding systems
are then ventilated to a fabric filter. Three particulate
samples were collected from the fabric filter outlet. Wheat,
corn, milo and soybeans were loaded during the tests. The
loading operation procteded normally,
U Facility L is a rack grain dryer controlled by a
screen filter with 150 micron diameter openings. Corn was
being dried and the process was operating normally. Chapter 5»
Section 5.2 discusses the results of this particulate emission test.
M. Facility M is a column grain dryer controlled by a
screen filter with 300 micron diameter openings. Corn was being
dried and the process was operating normally. Chapter 5, Section 5.2
discusses the results of this particulate emission test.
N. Facility N is a truck unloading station at a port
terminal elevator. The receiving hopper is ventilated to a
fabric filter and is enclosed in a shed with one open end.
The opposite end is equipped with quick-closing doors which are
kept closed during the unloading operation. Unloading of wheat
proceeded normally during the fugitive visible emission/opacity
C-7
-------
observation period. These data are summarized in Chapter 5.
0. Facility 0 is a headhouse and exterior conveyor system
(grain handling operations) located at a port terminal elevator.
Wheat was being unloaded, transferred and cleaned within the
headhouse during the fugitive visible emission/opacity observation
period. The individual peices of handling equipment were generally
controlled by hooding systems ventilated to fabric filters,
The cleaner, however, was an enclosed unit with no ventilation,
A summary of the fugitive visible emission data for this facility
is Included in Chapter 5.
P. Facility P is a soybean meal truck loading station at
a soybean processing plant. The truck loading station included
a shed with one open end. Trucks backed into the shed and were
then loaded with soybean meal through a loading spout equipped
with a canvas sleeve, There was a vertical free-fall distance
of about ten to twelve feet from the spout to the empty truck
bed. The shed was ventilated by an eight-inch duct to a fabric
filter. A summary of the fugitive visible emission data for
i
this facility is included in Chapter 5.
Q. Facility Q is a railroad boxcar loading station at an
inland terminal elevator. The boxcar loading shed has two
open ends and is long enough to accommodate two railcars on each
of the two tracks inside the shed. The boxcar loading system is
on one side of the shed. The loading spout 1s forked and curved
C-8
-------
to distribute the grain Into the front and back of the boxcar.
A small building-like structure encloses the loading spout and
extends to within six inches of the side of the boxcar. The
sides of this enclosure have hinged doors equipped with rubber
flaps to seal the sides to the boxcar. The enclosure is ventilated
to a fabric filter. Barley was being loaded during the fugitive
visible emission observation period. The data collected are
summarized in Chapter 5.
R. Facility R is a railroad hopper car loading station at an
inland terminal elevator. It includes a shed with two open ends and a
special loading spout and hooding system located above the hopper
openings of the railcar. This hooding system can be raised or
lowered and is ventilated to a fabric filter. The shed has
two tracks running through it. The fugitive visible emission
data collected are summarized in Chapter 5.
S. Facility S is a 2500 bushel/hr cylindrically shaped
column grain dryer located at a country elevator. The perforation
plate hole diameters are a series of sizes from top to bottom;
,078 inch, .0625 inch and .016 inch. Normal drying of corn was
maintained during the visible emission observation period. The
visible emission data obtained at this facility are summarized
in Chapter 5.
T. Facility T is a 3500 bushel/hr cylindrically shaped
column grain dryer at a country elevator. The perforation plate
hole diameters are of two different sizes. The top half has hole
C-9
-------
diameters of .0625 inch and the lower half has hole diameters of .050
inch. Corn was being dried and normal operation was maintained during
the observation period, A summary of the visible emission data is
Included in Chapter 5.
U. Facility U is a column grain dryer rated at 4000 bushels/hr
located at a country elevator. It is rectangular in shape and exhausts
through one side of the structure. The perforation plate hole diameters
are .084 inch and are the same size over the height of the columns. This
unit has four grain columns within the structure. Normal operation
was maintained while com was being dried. The visible emission data
from this facility are summarized in Chapter 5,
V. Facility V is a 1000 bushel/hr column grain dryer located at
§ country elevator. It is rectangular in design and has perforation
plate hole diameters of ,084 inch. There are three grain columns in
this dryer. Corn was being dried during the observation period and
normal drying operation was maintained, A summary of the visible
emission data from this dryer is included in Chapter 5.
W, Facility W is a rack grain dryer located at a country elevator.
Corn was being dried during the observation period. Normal operation was
maintained. This dryer was not equipped with any air pollution control
devices. A summary of the visible emission data is included in Chapter 5,
X. Facility X is a 2500 bushel/hr rack grain dryer located at a
soybean processing plant. Soybeans were being dried during the observa-
tion period. Normal operation was maintained. This dryer was equipped
j
with a 50 mesh vacuum-cleaned screen filter. A summary of the visible
emission data is included in Chapter 5.
C-10
-------
Y, Facility Y is a 2500 bushel/hr column grain dryer located at
a soybean processing plant. It is rectangular in design and has perforation
plate hole diameters of .08 inch. Soybeans were being dried during the
observation period and normal drying operation was maintained. A summary
of the visible emission data from this dryer is included in Chapter 5.
C-ll
-------
TABLE C-l
FACILITY
Summary of Partieulate Emission Data for Fabric Filttr
Run Number
Date
Ta«"fr T-tmn - Mi ny+gc
Stack Effluent
Flow rate - ACFM
Flow rate - DSCFM
Temperature - °F
Mater vapor - Vol. %
Particulate Emissions
Probe and filter catch
gr/DSCF
gr/ACF
"Ib/hr
Total catch
gr/DSCF
gr/ACF
Ib/hr
1
3/20/72
90
13,486
13,357
66.1
.1
0.00549
O.OOS35
0.628
0.00552
0.00546
0.628
2
3/21/72
180
13,436
13,331
55,6
.5
0.00187
0.00186
0.213
0.00262
0.00260
0.293
3
3/22/72
180
13,512
13,944
40.0
0.0
0.00146
0.00150
0.167
0.00216
0.00222
0.251
Average
13,478
13»544
53.9
0.2
0.00294
0.00290
0.336
0.00343
0.00343
0.391
C-l 2
-------
TABLE C-2
FACILITY
Sumnary of Particulate Emission Data for Fabric Filter
Run Number
Date
Test Time - Minutes
Stack Effluent
Flow rate - ACFM
Flow rate - DSCFM
Temperature - 6F
Water vapor -Vol.lK "
Particulate Emissions
Probe and filter catch
gr/DSCF
gr/ACF
Ib/hr
Total catch
§r/DSCF
gr/ACF
Ib/hr
1
8/8-9/72
114
11,743
10,926
83.1
2.0
0,0067
0.0062
0.62
0,0093
0.0087
0.86
2
8/9/72
116
10,845
9,959
95.6
1.7
0.0097
0.0089
0.83
0.025
0.023
2.13
3
8/10/72
112
10,117
9,559
71.8
2.1
0.0019
0.0018
0.17
0.0035
0.0033
0.31
Average
114
10,902
10,148
83.5
1.9
0.0061
0.0056
0.54
0.0126
0,0117
1.1
C-13
-------
TABLE C-3
(
FACILITY Cv
Summary of Pirtlculate Emission Data for Fabric Filter
Run Number
Date
last Tinu; - Minutes
Stack Effluent
Row rate - ACFM
Row rite - DSCFM
Temperature - °F
Water vapor - Vol. %
Part fey late Emissions
Probe and filter catch
gr/DSCF
gr/ACF
Ib/hr
Total catch
gr/DSCF
gr/ACF
Ib/hr
1
10/2/73
160
18,927
19,336
60.9
0.9
0.00073
0.00075
0,12
0.00124
0.00127
0.21
2
10/3/73
160
19,222
19,676
60.6
0,9
0.00052
0.00053
0.09
0..00105
0,00108
0.18
3
10/4/73
160
19,462
19,877
59.2
0,9
0.00042
0.00043
0.07
0.00058
0.00059
0,10
Average
160
19,204
19,629
60,2"
0,9
0.00056
0.00057
0.09
0.00096
0.00098
0.16
C-14
-------
TABLE C-4
FACILITY
Sunmary of Particulite Emission Data For Fabric Fflter
Run Number
Date
Test Time - Minutes
10/17/72 10/18/72
148
108
3 Average
10/18/72
108 121
Stack Effluent
Flow rate - ACFM
Flow rate - OSCFM
Temperature - °F
Mater vapor - Vol . %
Parti cul ate Emissions
Probe and filter catch
gr/DSCF
gr/ACF
Ib/hr
Total catch
gr/DSCF
gr/ACF
Ib/hr
21,704
20,200
80.0
2.40
.0,00392
0.003S5
0.687
0.00677
0.00630
1.172
2U416
20,200
75.0
2.29
0.00277
0.00261
0.485
0.00449
0.00423
0.768
20,495
19,800
74.9
2.34
0.00932
0.00880
1.584
0.0125
0,0118
2.12
21,205
20,067
76.5
2.34
0.00534
0.00502
0.92
0.0079
0.0074
1.35
-------
TABLE C-5
FACILITY
Summary of Particatate Emission Data For Fabric Filter
Run Number
Date
Average
10/30/73 10/30/73 10/31/73
on
ton
120
1911
Stack Effluent
Row rate - ACFM
Flow rate - DSCFM
Temperature - "F
Water vapor - Vol. %
Particulate Emissions
Probe and filter catch
gr/DSCF
gr/ACF
Ib/hr
Total catch
gr/DSCF
gr/ACF
Ib/hr
36,196
36,160
68.8
0.8
0.0212
0.0211
6.56
0.0214
0.0214
6.65
39,004
37,752
84.8
0.5
0.0340
0.0329
11.01
0.0344
0.0333
11.15
40,533
38,751
84.6
1.1
0.0219
0.0209
7.27
0.0223
0.0213
7.40
38,578
37,554
79.4
0.8
0.0257
0.0250
8.28 .
0.0261
0.0253
8.40
C-16
-------
TABLE C-6
FACILITY F
(6)
Summary of Particulate Emission Data For Fabric Filter
Run Number
Date
Test Time - Minutes
Stack Effluent
Flow rate - ACFM
Flow rate - DSCFM
Temperature - °F
Water vapor - Vol. %
Particulate Emissions
Probe and filter catch
gr/DSCF
gr/ACF
Ib/hr
Totalcatch
gr/DSCF
gr/ACF
Ib/hr
1/10/73 1/10/73 1/10/73
80
80
80
10,891
11,038
62
0.8
0.000034
0.000034
0.00319
0.00138
0.00138
0.13
10,906
10,998
64
1.0
0.000045
0.000045
T. 00422
0.00152
0.00152
0.14
11,438
11,543
64
0.9
0.000021
0.000021
0,00211
0.000596
0.00060
0.059
C-17
-------
TABLE C-7
FACILITY
Summary of Particulate Emission Data For Fabric Filter
Run Number
Date
4
1/11/73
5
1/11/73
Ol\
on
Average
an
Stack Effluent
Flow rate - ACFM
Flow rate - DSCFM
Temperature - °F
Water vapor - Vol. %
Particulate Emissions
Probe and filter catch
gr/DSCF
gr/ACF
Ib/hr
Total catch
gr/DSCF
gr/ACF
Ib/hr
10,895
11,066
62
0.6
0.0347
0.0352
3.29
0.0349
0.0354
3.31
11,134
11,275
62
0.9
0.000126
0.000128
0.012
0.000783
0.000793
0.075
11,053
11,184
62.8
.8
0.0020
0.0070
0.66
0.0078
0.0080
0.74
C-18
-------
TABLE C-8
FACILITY
Summary of Paniculate Emission Data For Fabric Filter
Run Number
Date
Test Time - Minutes
Stack Effluent
Flow rate - ACFM
Flow rate - DSCFM
Temperature - °F
Water vapor - Vol . %
Particulate Emissions
Probe and filter catch
gr/DSCF
gr/ACF
Ib/hr
Total catch
gr/DSCF
gr/ACF
Ib/hr
1
3/22/72
180
6,489
6,620
45.0
0.0
0.00144
0.00147
0.0794
0.00214
0.00219
0.119
2
3/23/72
180
6,493
6,599
51.8
0.0
0.00108
0.00110
0.0594
0.00169
0.00172
0.0924
3
3/24/72
180
6,369
6,557
40.0
0.0
0.000305
0.000318
0.0133
0.000567
0.000592
0.0266
Average
180
6,450
6,625
45.6
0.0
0.00094
0.00096
0.0507
0.00147
0.00150
0.079
C-19
-------
TABLE C-9
FACILITY
Summary of Participate Emission Data For Fabric Filter
Run Number
Date
TaSt TIlTtS — Minutoc
Stack Effluent
Flow rate - ACFM
Flow rate - DSCFM
Temperature - °F
Water vapor - Vol. %
Parti cul ate Emissions
Probe and filter catch
gr/DSCF
gr/ACF
Ib/hr
Total catch
gr/DSCF
gr/ACF
Ib/hr
1
4/23/73
120
19,978
18,898
81.5
1.6
0.0040
0.0040
0.66
0.0067
0.0066
1.09
2
4/24/73
120
20,709
19,188
93.5
2.1
0.0014
0.0013
0,22
0.0047
0.0045
0.77
3
. 4/24/73
120
19,205
17,878
93.3
1.7
0.0019
0.0018
0.29
0.0051
0.0049
0.78
Average
120
19,964
18,555
89.4
1.8
0.0024
0.0024
0.39
0.0055
0.0053
0.88
C-20
-------
TABLE C-10
FACILITY 1^
Sunmary of Participate Emission Data For Fabric Filter,
Run Number
Date
Test Time - Minutes
Stack Effluent
Flow rate - ACFM
Flow rate - DSCFM
Temperature - °F
Water vapor - Vol. %
1
10/16/73
105
3,857
3,826
59.0
2.3
Particul ate Emi s si ons
Probe and fi1ter catch
gr/DSCF
gr/ACF
Ib/hr
Totalcatch
gr/DSCF
gr/ACF
Ib/hr
0.00277
0.00275
0.09
0.00397
0.00393
0.13
C-21
-------
TABLE C-ll
FACILITY
Summary of Participate Emission Data for Fabric Filter
Run Number
Date
Test Time - Minutes
Stack Effluent
Flow rate - ACFM
Flow rate - DSCFM
Temperature - °F
Water vapor - Vol. %
10/5/72
160
21,956
22,510
54.8 .
0.5
2
10/5/72
IfiO
20,186
20,223
56.5
0.9
3
10/6/72
47
19,662
19,582
58.5
1.1
Average
20,602
20,772
56.6
0.83
Parti cula te Emls s i ons
Probe and filter catch
gr/DSCF
gr/ACF
Ib/hr ;
Total catch
gr/DSCF
gr/ACF
Ib/hr
0,00082 0.00082
0.00084 0.00082
0.16 0.14
0.00100 0.00099
0,00102 0.00099
0.19 0.17
0.00103 0.00089
0.00103 0.00089
0.17 0.16
0.00270 0.00156
0.00269 0.00157
0.45 0.27
C-22
-------
TABLE C-12
FACILITY K^
Summary of Particulate Emission Data For Fabric Filter
Run Number
Date
Test Time - Minutes
Average
10/16/73 10/17/73 10/17/73
160
160
160
160
Stack Effluent
Flow rate - ACFM
Flow rate - DSCFM
Temperature - °F
Water vapor - Vol. %
Parti cul ate Emissions
Probe and filter catch
gr/DSCF
gr/ACF
Ib/hr
Total catch
gr/DSCF
gr/ACF
Ib/hr
6,136
6,099
65.0
0.8
0.00411
0.00408
0.21
0.00558
0.00555
0.29
5,064
4,926
75.0
0.8
0.00824
0.00801
0.35
0.01411
0.01372
0.60
4,982
4,782
80.0
1.0
0.01109
0.01064
0.45
0.01796
0.01723
0.74
5,394
5,269
73.3
0.87
0.00781
0,00758
0.34
0.01255
0.01217
0.54
C-23
-------
REFERENCES
1, Logan, Thomas, "Emission Test Report" for Plants A and S, tests were conducted
in March 1972. EPA Test No. 72-CI-23.
2. Ward, Thomas, "Emission Test Report" for Plant B, EPA Test No. 72-CI-33 (CRN),
prepared for EPA by Environmental Engineering, Incorporated, Contract No.
68-02-0232, Task 14, August 1972.
3. Pfaff, Roger 0., "Emission Test Report" for Plants C and J, EPA Test No.
74-SRN-8, January 1974.
4. Ward, Thomas, "Emission Test Report" for Plant D, EPA Test No, 73-GRN-2,
prepared for EPA by York Research Corporation, November 1972,
5. Pfaff, Roger 0., "Emission Test Report" for Plant E, EPA Test No. 74-6RN-7,
January 1974.
6, Ward, Thomas, "Emission Test Report" for Plant F, EPA Test No. 73-GRN-3,
prepared for EPA by Environmental Engineering Incorporated, Contract No.
68-02-0232, Task 20, January 1973.
7. Ward, Thomas, "Emission Test Report," for Plant H, EPA Test No, 73-GRN-5,
the tests were conducted in April 1973.
/
8, Riley, C. E., "Emission Test Report",for Plants I and K, EMB Test No. 74-GRN-6,
May 1974.
C-24
-------
APPENDIX D
METHODOLOGY FOR ESTIMATING THE IMPACT OF
GRAIN ELEVATOR FACILITIES ON AIR QUALITY
D-1
-------
METHODOLOGY FOR ESTIMATING THE IMPACT
OF GRAIN ELEVATOR FACILITIES ON AIR QUALITY
Particulate emissions from a grain elevator facility are complex.
The emissions are generally distributed over a horizontal area of
approximately 100 x 250 meters. Receiving and shipping operations
(Table D-l) typically are widely distributed over that area, but no
other generalizations can be made about the physical layout of such
sources other than that they are near ground level. The other operations
are not as widely distributed. The handling and cleaning operations
result in emissions at several heights, ranging from near ground
level to about 60 meters above ground level. An estimated average
emission height for each grain elevator, operation, and level of
emission control is listed in Table D-l.
There are essentially no well-defined stacks at such facilities.
Most of the emissions are either fugitive in nature or are emitted
from vents and control devices attached to or near the grain elevator
buildings at various heights. All emissions are near ambient tem-
peratures. The few stacks that do exist appear to be well within the
regions of aerodynamic downwash at such facilities. Thus, effluent
plume rise can be assumed to be negligible.
To estimate the impact of such facilities on air quality, it
was first necessary to choose an appropriate atmospheric dispersion
model and to consolidate the source information contained in the
above discussion and Table D-l into a form suitable for input to the
D-2
-------
Table D-1,
r*rticut*te t»nitn,, .««.vc» «v
firain El enter F«l1ft1e»
-
Type of
"inin Elevator
Country Elevator
(Hodels 1, 2, srol
Wee Drjtrt)
mtjh Through-put
(Nodtls 3 «nd 4)
inland TerwiliT
Elevator
(Hotel 5)
fc '"• "y "•••••y--.»^y»-i"iiiiii- .- llL.«»ii., ,
Port Terminal
Elevator
(Modol 6)
™* ,_ _
btortqe Cievator
Processors (wheat mill,
dry com nil}, He*
Bill, soybean processor,
net corn mill)
Qoeratfon
111 -1--—- — — —
Receiving
Handling
Clewing
Brvlno
Receiving
W*frfllBf
Cleaning
Orylnf •
Shipping
R»ce1»1n§
Handling
Cleaning
Drying
Shipping
Receiving
Handling
t
Cleaning
"r»lrw
SHtffifnfl
Receive
Handling
Drying
Level of Emission
Control
None » None
1 » System 1
2 « Syste* 2
3 » System 3
•*" SoiS "~~
T
3
None
1
2
3
None
1
2
3
Man*
1
2
3
»*e
2
3
None
1
2
S
None
1
2
3
None
1
2
3
None
1
2
3
|g~ • — — —
1
1
3
None
1
1
3
None
1
2
3
Mine
1
2
S
None
1
2
3
Wone
2
3
Nona
1
2
3
None
1
3*
Kant
1
2
1
(tone
1
2
1
None
1
3
None
1
2
3
HPM
T
3
Average
EwHslon
Helfjht
M
•• ""'1 » —
?,*5
7,5
7,5
46
46
46
46
1
23
23
23
5
1
S
S
T5
7."$
7,5
4£
46
46
46
3
23
23
23
S
S
s
8
S
7.5
7.5
7.5
. YJJ
7.5
7.5
7.5
46
•46
48
4S
3
23
23
23
S
5
s
5
5
7.5
7.5
7,5
i . s"
7.5
7^5 .
46
46
46
46
3
23
23
23
8
S
S
5
5
7.5
7.5
i.s
7.5
7,5
7.5
46
16
46
5
5
S
Rate
' "m ' ' •'.
1,7
.17
.17
3.2
.SI
.05
.01
1.0
.1
.01
.01
6.5
.97
,§7
.32
19.6
1.32
,13
.13
7.8
.13
.13
.13
2.2
.22
.02
.02
13.0
1.94
1.94
.$5
5.8
1.07
.09
.09
2.9
.21
.25
140
.6
.& j
fi
3*3 i
1.1
.1
.1
13
1,14
1 94
.61
44
. 2.16
,22
22
ltd
1 (%
t . D
.4
,4
140
.7
.7
6^6
2.2
*2
13
1.94
1.94
130*
2,?
3
. €
.t
21.fi
4.0
,4
.4
7.7
3.8
.38
.38
6.5
.97
.97
.3? .
D-3
-------
model. The dispersion estimates were made through application of
the Single Source (CRSTER) Model. Given a year of hourly meteorological
data, the model estimates maximum 1-hour, 3-hour, 24-hour, and annual
ground-level concentrations. It must be realized that the short-term
values are the maximums for the year in question. During certain years
the maximum values will likely be somewhat higher, due to different
sequences of meteorological conditions.
The formulation of an appropriate set of source input data for .
the model was simplified by the fact that there is no significant
plume rise from the source. Thus, it was only necessary to account for
the fact that the particylate "plume" from such a facility has
a finite initial width and thickness.
In estimating the appropriate "initial plume width," it is
recognized that the actual points of emission due to each operation
are not distributed over the entire 100 x 250 meter area discussed
earlier. However, once the effluents leave their respective sources,
they are probably subjected to considerable turbulent mixing dye to
the presence of large structures and are likely to be dispersed over
much of the above-mentioned area. Therefore, tffluents from all
operations are assumed to be distributed over the entire area.
The initial plume width input to the Single Source Model was based on
that assumption. The smaller of the two facility dimensions (100 meters)
was used for all cases {Table D-2) and for all wind directions. In
D-4
-------
Table D-2. Emission Rate, Average Emisson Height (weighted
by emission rate), and Assumed Initial Plume
Dimensions for Each Type of Grain Elevator and
Level of Emission Control
Type of
Grain
Elevator
Country
Elevator
High
Through-
put
Inland
Terminal
Port
Termi nal
Storage
Elevator
Level of
Emission
Control
None
1
2
3
None
1
2
3
None
1
2
3
None
1
2
3
None
1
2
3
Total
Emission
Rate
(g/sec)
19.7
3.3
1.2
0,55
47.6
4.7
2.3
1.0
213
8.7
3.2
1.9
400
8.6
3.4
2.2
35.8
8.8
1.8
1.1
Average
Emission
Height
(m)
10
13
7.4
9.8
9.5
8.3
7.8
11
32
12
13
20
18
14
15
20
12
23
14
20
Assumed
Initial
Plume
Thickness
M
20
25
15
20
20
15
15
20
64
25
25
40
40
30
30
40
25
40
25
40
Assumed
Initial
Plume
Width
CM)
100
100
100
100
TOO
100
100
100
100
100
100
100
100
TOO
100
100
100
100
100
TOO
D-5
-------
other words, a circular source was assumed in order to ensure reasonably
conservative dispersion estimates downwind of the source. For computa-
tional purposes, the initial cross-wind pollutant distribution is
assumed to be Gaussian,
To estimate the "initial plume thicknesses" for each type of
grain elevator and level of emission control, emission heights listed
in Table D-l were utilized. The heights were weighted by the respective
emission rates, and a weighted average emission height was determined
for each grain elevator and level of emission control (Table 0-2).
The initial plume thicknesses were assumed to be approximately twice
the weighted average emission heights» i.e., the initial vertical
spread of each plume is assured to extend from groynd level to
twice the weighted average emission height. That assumption is
considered valid in'light of the prevalent atmospheric turbulence and
downwash conditions at the facilities under study.
The initial horizontal and vertical pollutant distributions were
assumed to be Gaussian to facilitate the utilization of virtual point
source approximations. Such approximations were necessary because
the Single Source Model only handles "point" sources, whereas the
effluent plumes from the sources in question have finite initial hori-
zontal and vertical dimensions that must be accounted for. Dispersion
coefficients for Pasquill-Gifford stability Class D were used in the
computation of the virtual point source distances.
D-6
-------
The meteorological data used in the analysis were chosen from
locations where effluent dispersion from grain elevator facilities would
result in relatively high concentrations. All meteorological data were
from the year 1964, That is the only year for which data suitable as
input to the model are directly available. For all but the port
facility analyses, meteorological data from seven! National Weather
Service Stations in the heart of the grain belt were examined. Surface
stability-wind data from Omaha, Nebraska were finally chosen because
of the relatively skewed wind rose at that location. The mixing height
data were obtained from the nearest upper air station (Topeka, Kansas)
for which such information is readily available. The high frequency of
wind from a single direction at Omaha should cause estimated maximum
ambient pollutant concentrations at that station to be higher than at
most other grain belt locations. For the port facilities, surface
meteorological data from several Great Lakes, Gulf, and Pacific Coast
locations were considered. Portland, Oregon was finally chosen because
of the relatively skewed wind rose at that location. Upper air data in
this latter case were obtained from Salem, Oregon, which 1s the nearest
station providing such Information,
Table D-3 presents the estimated maximum ambient parttculate concen-
trations at specified distances downwind of the five types of grain
elevator facilities considered in the analysis. Note that a consider-
able degree of emission control would be required for the national
D-7
-------
Table D-3 - Estimated Ambient Ground-Live! Particulate Concentrations at
Specified Distances* Downwind of Grain Elevator Facilities
Type of
Grain
Elevator
Country
Elevator
High
Through-
put
Inland
Terminal
Port
Terminal
Storage
Elevator
Level of
Emission
Control
none
1
2
3
none
1
2
3
none
1
2
3
none
1
2
3
none
1
2
3
Total
Emission
Rate
(g/sec)
19.7
3.3
1.2
0.55
47.6
4.7
2.3
1.0
213
8.7
3.2
1.9
400
8.6
3.4
2.2
35.8
8.8
1.8
1.1
Averaging
Time
Day
Year
Day
Year
Day
Year
Day
Year
Day
Vaav
Day
• Year
Day
Year
Day
Year
Day
Year
Day
Year
Day
Ypar
Day
Year
Day
Year
Day
Year
Day
Year
Day
Year
Day
Year
Day
Year
Day
Year
Day
Year
o
Particulate Concentration {ug/m )
0.3 km
1000
79
150
11
6|
29
2
> 1000
i nn
250
19
120
9
53
4
> 1000
> 300
390
30
140
11
70
6
> 1000
> 300
340
28
140
11
62
6
> 1000
120
330
26
81
6
41
3
2 km
100
9
17
2
1000
94
46
4
17
1
10
< 1
> 1000
180
34
4
14
2
9.
< 1
190
16
47
4
10
< 1
6
< 1
20 km
10
< 1
2
< 1
< 1
< 1
< 1
< 1
23
1
2
< 1
1
< 1
< 1
< 1
100
5
4
< 1
2
< 1
< 1
< 1
140
8
3
< 1
1
< 1
< 1
< 1
17
< 1
4
< 1
< 1
< 1
< 1
< 1
*Distances are as measured from the center of each facility
D-8
-------
ambient air quality standards for particulates to be met in the vicinity
of all the grain elevator facilities studied. If the fugitive emission
and aerodynamic downwash problems at those facilities were eliminated
by venting the emissions into well-designed stacks, the ambient
standards coyld be met with considerably less emission control.
D-9
-------
1
TECHNICAL REPORT DATA >
(Please read Itixmctions on the reverse before completing)
1. REPORT NO.
3, RECIPIENT'S ACCESS(Of*NO.
4. TITLE AND SUBTITLE
Standards Support and Environmental Impact Statement,
Volume 1: Proposed Standards of Performance for the
Grain Elevator Industry
REPORT DATE
January 1977
6. PERFORMING ORGANIZATION CODE
7. AUTHOBSS)
8. PERFORMING ORGANIZATION REPORT NO,
9. PERFORMING ORGANIZATION NAME AND ADDRESS
U.S. Environmental Protection Agency
Office of Air Quality Planning and Standards
Research Triangle Park, N. C. Z7711
1O, PROGRAM iLEMENT NO.
11. CONTRACT/GRANT NO.
12. SPONSORING AGENCY NAME AND ADDRESS
13. TYPE OF REPORT AND PERIOD COVERED
14. SPONSORING AGENCY CODE
is.SUPPLEMENTARY NOTES Volume 1 cKscussEs the proposed standards and the resulting environ
mental and economic effects. Volume 2, to he published when the standards are prom-
ulgated,willcontain a summary of public comments, EPA responses, and a discussion of
i6. ABSTRACTdifferences between the proposed and promulgated standards.
Standards of performance to control particulate matter emissions from new and modified
grain elevators in the U.S. are being proposed under section 111 of the Clean Air Act.
The proposed standards limit emissions of particulate matter from the following
affected facilities and their air pollution control devices: truck loading and
unloading stations, railroad hopper car and boxcar loading and unloading stations,
equipment at barge and ship unloading stations, barge and ship loading stations,
all grain handling operations, and grain dryers. This document contains information
on the grain elevator industry and emission control technology, a discussion of the
selected emission limitations and the supporting data, and the alternatives which
were considered, and analyses of the environmental and economic impacts of the
proposed standards.
17.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
b,IDENTIFIERS/OPEN ENDED TERMS C. COSATI Field/Group
Air pollution control equipment
Air pollution
Grain elevators
Standards of performance
Pollution control
Air pollution control
'Fabric filter
Baghouse
Fugitive emissions
Particulate matter
is. DISTRIBUTION STATEMENT
unlimited. Available from Public Informat
Center (PM-215), Environmental Protection
Agency, Washington, D,C. 20460
19. SECURITY CLASS (ThisReport/
on Unclassified
21. NO. OF PAGES
29. SECURITY CLASS (Thispage)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
-------
ENVIRONMENTAL PROTECTION AGENCY
Technical Publications Branch •"
Office of Administration
Research Trianglt Park, North Carolina 27711
OFFICIAL BUSINESS
AN EQUAL OPPORTUNITY EMPLOYER
POSTAGE AND FEES PAID
ENVIRONMENTAL PROTECTION AGENCY
EPA - 335
SPECIAL FOURTH-CLASS RATE
BOOK
Return this sheet if you do NOT wish to receive this material (_J
or if change of address is needed I I, (Indicate change, including
ZIP code.)
PUBLICATION NO. EPA-45G/2-77-001a
------- |