WASHINGTON, July 15, 2014-- The National Grain and Feed Association (NGFA) is giving the EPA a pat on the back for its proposal to change the rule that governs how it deals with temporary grain storage structures.

The EPA, in a July 9 notice in the Federal Register, said it plans to take into account about a third of the capacity of temporary storage space when it calculates when a costly permit is required under the Clean Air Act. In a 2007 letter of interpretation, the agency had basically equated temporary structures with permanent storage facilities.

In its recent proposal, the EPA noted that it is rescinding that interpretation since it is “now aware that (temporary storage facilities) typically handle the grain less time throughout the year than other types of permanent storage facilities, and may require different treatment.”

NGFA, which represents grain elevator operators, feed manufacturers, grain merchants and users of grain products, among others, has been collaborating since 2009 with other grain handling organizations to urge EPA to rescind that interpretation.

“We’re pleased those collaborative efforts and engagement have been successful on this aspect of the issue,” NGFA said in a news release.

EPA is also proposing to add a new section to the rule that would apply to grain elevators built or modified after July 9, when its proposal was published in the Federal Register. This section, including new emissions limits for certain elevators, plus additional testing, monitoring and record-keeping requirements, “will warrant meticulous review by the industry,” NGFA said.

The association said the last time the EPA conducted a comprehensive review of its new source performance standards (NSPS) for grain elevators was in 1984, when temporary storage structures were not in use. Such structures have a concrete/asphalt floor, aeration and a tarp cover, and also a permanent aeration tower and a conveyer system to move the grain to the permanent storage system.

Commercial grain elevators built after 1978 with a permanent storage capacity over 2.5 million bushels are required to comply with stricter air-permitting and emission standards, as does any facility that has been modified since 1978 to expand its permanent storage capacity to more than 2.5 million bushels.

Also subject to the NSPS are grain storage elevators with a permanent storage capacity exceeding 1 million bushels that are located at wheat flour mills, wet or dry corn mills (manufacturing products for human consumption), rice mills or soybean oil extraction plants. Grain-handling facilities located at feed mills, pet food manufacturing plants, cereal manufacturers, breweries and livestock feedlots are not covered by the current NSPS.


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