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Grain Elevators
December 1994

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).
-  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 (fabric filter) 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.
-  Manufacture'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 any appropriate fan exhausts.

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) sending one copy of the application to the appropriate regional office, one copy to the Austin
office, one copy to any local programs (if any) 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.