feedmill.txt

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Grain Handling/Feedmilling Facilities
January 1997

TNRCC Rule 116.111(3) in Regulation VI requires that Best Available Control Technology
(BACT) be applied to all facilities that must obtain a permit.  BACT determinations are made on
a case-by-case basis. 

What are the minimum controls necessary to meet present BACT requirements for
applications with rural, isolated locations (low nuisance potential)?

    Enclosed conveying.
    Column type dryers with outlet perforations that comply with NSPS Subpart DD (no
     greater than 0.094 inch in diameter).
    Manufacturer's guarantee for NOX emissions for fuel fired equipment with an hourly
     BTU rating greater than 10 million and less than or equal to 40 million.  NOX emission
     factor for fuel fired equipment of this capacity should not exceed 0.10 lb/106 BTU.
    Manufacturer's guarantee for NOX emissions for fuel fired equipment with an hourly
     BTU rating greater than 40 million.  NOX emission factor for fuel fired equipment of
     this capacity should not exceed 0.06 lb/106 BTU.
    Use of scrubbers (or equivalent) when processing feed ingredients that may have the
     potential to produce nuisance odors.  Normally, these are rendering by-products such as
     bone meal, blood meal, fish meal, fish oil, fat oil, liquid fat, etc.  Scrubbers must have
     a minimum retention time of 0.5 seconds through the packing material and 1 second
     through the scrubber, as well as maintain a minimum residual-free chlorine con-
     centration of 10 ppm and a minimum pH of 11 in the scrubber recycle tank.
    Use of fabric filters (or equivalent) on all fan discharges from grinders, hammermills,
     or any other source handling fine or dusty material.
    Manufacturer's guarantee for outlet grain loading rates on all fabric filters.  Usual
     outlet grain loading rates range from 0.005 gr/dscf to 0.01 gr/dscf.
    Well designed, high efficiency cyclones (1D-3D or 2D-2D) on all pellet cooler
     exhausts.
    Loadout spouts equipped with drop socks that extend inside the vehicle being loaded.
    Bin vent filters on all bins which store fine, dusty material.
    Proper maintenance of all abatement devices, duct work, and in-plant roads.
    Daily removal of any spillage of raw or finished product and waste material.
What additional controls should be considered and may be required for facilities in tighter
locations with nearby residences, businesses, schools, etc. (high nuisance potential) ?

    Enclosed receiving and loadout areas.
    Application of vegetable or mineral oil during receiving operations.
    Use of "choke feeding" for receiving operations.
    Use of a dust collection system and bagfilter on areas such as receiving pits, elevator
     legs, and loadout points.
    Use of surge bins to minimize dust generated during loadout.
    Paved and cleaned or dust suppressant treated parking lot and traffic areas.

In summary, any changes or additions that are thought to be insignificant and appear that no
permit requirements are necessary should be proposed to the TNRCC for review or comments. 
Permit processing time can be greatly reduced by:

    1)  choosing an isolated location; and 
    2)  submitting a well prepared application with a completed PI-1 or PI-1R form. Refer to
        document entitled "Supplemental Information Sheet for Grain Elevators/Feedmills" for
        more information on application information; and
    3)  proposing controls that meet all BACT and regulation requirements.  Proposals for
        anything less should be well justified; and
    4)  sending the original application to the Austin Office, one copy of the application to the
        appropriate regional office, one copy to any appropriate local programs, and keeping
        one copy.  

Activities which require public notice should be planned well in advance to allow for a permit
processing time of around 90 days.  Public involvement such as public meetings and/or public
hearings could greatly increase the processing time.