Florida Department of Environmental Protection Air Resource Management Southwest District Office March 30, 2010 Workshop for Concrete Batching Plants
Transcript
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Air Resource Management Southwest District Office March 30,
2010 Workshop for Concrete Batching Plants
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2 Mara Nasca Air Program Administrator Danielle D. Henry Air
Compliance Supervisor Cindy Falandysz Air Enforcement Supervisor
Joe Panetta Air Program Environmental Specialist III
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3 Concrete Batch Plant (CBP) General Permit (GP) Requirements
Air General (AG) Permit under Rule 62-210.310(5) (b), Florida
Administrative Code, (F.A.C.) for concrete batching plants
Registration Requirements in DEP Form No. 62- 210.920(2)(b), F.A.C.
- Effective January 10, 2007 Operating another GP facility at
Concrete Batch Plants
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4 ** Additional Rules may be required by Hillsborough, Pinellas
and Sarasota Counties
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5 Southwest District has 137 Concrete Batch Plant Facilities
that are registered for General Permit
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Rule 62-296.414, F.A.C. Concrete Batching Plants. The following
requirements apply to new and existing emissions units producing
concrete and concrete products by batching or mixing cement and
other materials. This rule also applies to facilities processing
cement and other materials for the purposes of producing concrete,
and to equipment used to mix cement and soil for onsite soil
augmentation or stabilization. 6
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7 What is the Purpose of the Regulation? The Department of
Environmental Protection has established an Air General (AG) permit
under Rule 62-210.310(5)(b), F.A.C., for concrete batching
plants.
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8 The use of an AG permit serves two purposes: Provides notice
to the Department that the facility is in operation and Prescribes
the requirements under which the facility is allowed to operate
(Rule 62-210.310(5)(b), F.A.C.)
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9 Eligible concrete batching plants owners are not required to
use the AG permit, but instead may choose to obtain a regular Air
Operating (AO) permit. This workshop is intended to assist those
who choose to seek entitlement to use the AG permit for their
concrete batching plant.
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11 Eligible facilities must not be a major source as defined in
Rule 62-210.200, F.A.C. ***************************************
Eligible facilities must not emit 10 tons or more per year of any
listed hazardous air pollutant (HAP), 25 tons per year of any
combination of HAPs, or 100 tons per year or more of any other
regulated air pollutant.
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12 A facility using the Concrete Batching Plant AG permit may
collocate with other facilities: That have separate concrete
batching air general permits With facilities using the Nonmetallic
Mineral Processing Plant crushers AG permit, even if under the
control of different persons.
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13 The facility must meet the following conditions: The
collocation site must not contain any emission units and
pollutant-emitting activities other than concrete batching plants
and nonmetallic processing plants using the general permit, and
nonmetallic mineral processing plants or other emissions units and
pollutant-emitting activities exempted from permitting. F.A.C.
62-210.300(3) F.A.C. 62-210.300(3) Pg 40
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14 The total fuel consumption by all emissions units at the
collocation site shall not exceed 275,000 gallons of diesel fuel
per year or 23,000 gallons per year of gasoline or 44 million
standard cubic feet per year of natural gas, or 1.3 million gallons
per year of propane, or an equivalent prorated amount if multiple
fuels are used.
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15 Under the authority of an air general permit: A relocatable
CBP may perform a non-routine task making concrete for a
construction project, at a facility with authorization by
individual air construction or non-Title V Air Operating Permit,
without revision to the facilitys air permit. Any such CBP shall
remain at the individually permitted facility for no more than: (6)
months from the day it relocates to such facility. The owner or
operator of such concrete batching plant shall keep records to
indicate how long the plant has been at the permitted
facility.
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16 If multiple fuels are used, the equivalent prorated amount
of each fuel burned shall not exceed the total amount of such fuel
allowed to be burned, multiplied by a fuel percentage. Fuel
Percentage = Amount of the fuel burned at the facility Total amount
of fuel allowed to be burned by the facility **The sum of the fuel
percentages for all fuels burned by the facility shall not exceed
100%.
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17 The duration of the Concrete Batching Plant AG permit is
five (5) years. The owner /operator or authorized representative
must submit the proper registration form and processing fee of
$100.00 at least thirty (30) days prior to the expiration of the
facilitys existing AG permit
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18 The owner/operator or authorized representative shall submit
a new registration form and fee to the Department prior to a: 1.
change of ownership 2. physical change in location 3. any proposed
new construction or 4. modification or other equipment changes
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19 Definition of modification or other equipment changes :
Involving the installation of new process or air pollution
equipment Alteration of existing process or control equipment
Installation of control equipment substantially different in terms
of capacity, method of operation, material processed, or intended
use.
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20 The owner/operator or authorized representative shall notify
the Department in writing prior to: any sale, permanent shutdown of
the facility change in the name, telephone number of the facility
or owner/operator or authorized representative when it is not a
change in ownership.
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21 The AG permit is not transferable and does not follow a
change in ownership of the facility. The new owner/operator or
authorized representative shall submit a new registration form and
processing fee of $100 at least thirty (30) days prior to the
transfer of ownership of the facility to the new owner.
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22 The AG permit is valid only for the specific activity
indicated (i.e. Concrete Batch Plant). Any deviation from the
specified activity and the conditions for undertaking that activity
shall constitute a violation of the permit. The facility must not
emit objectionable odors.
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23 If, for any reason, the owner or operator of any facility or
emissions unit operating under an AG permit does not comply with or
will be unable to comply with any condition or limitation of the
permit, the owner or operator shall immediately provide the
Department with: General Conditions [Rule 62-210.310(3),
F.A.C.]
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24 1.A description of and cause of noncompliance; and, 2.The
period of noncompliance, including dates and times; or, if not
corrected, the anticipated time the noncompliance is expected to
continue, and steps being taken to reduce, eliminate, and prevent
recurrence of the noncompliance. The permittee shall be responsible
for any and all damages which may result.
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28 Use of the AG permit does not eliminate or relieve the
necessity for the owner/operator or authorized representative to
obtain any other federal, state, or local permits that may be
required.
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29 THE PERMIT DOES NOT AUTHORIZE: ASBESTOS REMOVAL FROM
DEMOLITION OR RENOVATION- [Rule 62-257, F.A.C., or 40 CFR Part 61,
Subpart M, National Emission Standard for Asbestos] SWD Asbestos
Contacts: http://www.dep.state.fl.us/southwest/contacts/
813-632-7600 OPEN BURNING [Rules 62-256.300 and 62-256.700, F.A.C.]
BYPASSING A CONTROL DEVICE (CIRCUMVENTION)
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31 1. Stack Emissions-Emissions from silos, weigh hoppers
(batchers), and other enclosed storage and conveying equipment
shall be controlled to the extent necessary to limit visible
emissions to 5 percent opacity.
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33 2.Unconfined Emissions-The owner or operator shall take
reasonable precautions to control unconfined emissions from
hoppers, storage and conveying equip, conveyor drop points, truck
loading and unloading, roads, parking areas, stock piles, and yards
by doing the following:
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34 a) Management of roads, parking areas, stock piles, and
yards, which shall include one or more of the following:
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35 1. Paving and maintenance of roads, parking areas, and
yards. 2. Application of water or environmentally safe dust-
suppressant chemicals when necessary to control emissions. 3.
Removal of particulate matter from roads and other paved areas
under control of the owner or operator to mitigate reentrainment,
from building or work areas to reduce airborne particulate matter
from stock piles. 4. Reduction of stock pile height or installation
of wind breaks to mitigate wind entrainment of particulate matter
from stock piles.
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37 b) Use of spray bar, chute, or partial enclosure to mitigate
emissions at the drop point to the truck.
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39 EPA Method 9,40 CFR 60, Appendix A EPA Method 9, 40 CFR 60,
Appendix A
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40 All emissions tests performed pursuant to the requirements
of this subsection shall comply with the following requirements.
EPA Method 9 a) The reference test method for visible emissions is
EPA Method 9, 40 CFR 60 Appendix A Rule 62-297.310 b) Test
procedures that shall be followed are specified in Rule 62-297.310,
F.A.C. and shall be reported to the Department. ( 15 day prior
notice, list EUs/within 45 days submitted)
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41 c) Visible emissions test of silo dust collector exhaust
points shall be conducted: while loading the silo at a rate that
represents the normal silo loading rate. The minimum loading rate
shall be 25 tons per hour unless such a rate is unachievable in
practice. If emissions from the weigh hopper (batcher) operation
are also controlled by the silo dust collector, the batching
operation shall be in operation during batching rate and duration.
Each test report shall state the actual silo loading rate during
emissions testing and, if applicable, whether or not batching
occurred during emissions testing.
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d) If emissions from the weigh hopper (batcher) operation are
controlled by a dust collector which is separate from the silo dust
collector, visible emissions tests of the weigh hopper (batcher)
dust collector exhaust point shall be conducted while batching at a
rate that is representative of the normal batching rate and
duration. Each test report shall state the actual batching rate
during emissions testing. 42
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The owner or operator of any concrete batching plant using the
AG permit shall have a performance test conducted for visible
emissions for each dust collector exhaust point no later than 30
days after commencing operation and once every calendar year
thereafter. 43
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44 Test Frequency Performance tests for visible emissions must
be conducted annually. (The rule revision effective January 10,
2007 requires annual testing.) o Annually is considered once each
calendar year (January 1-December 31). DEP guidance memo
DARM-OGG-18:
http://www.dep.state.fl.us/air/rules/guidance/ogg18.pdf
http://www.dep.state.fl.us/air/rules/guidance/ogg18.pdf
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46 The owner or operator of equipment used to mix cement and
soil for augmentation or stabilization proposing to change location
shall notify the appropriate Department of Environmental Protection
district office or local air pollution control program by phone,
e-mail, fax, or written communication at least one business day
prior to changing location and transmit a Facility Relocation
Notification Form (DEP Form No. 62-210.900(6)) to the Department no
later than five business day following relocation. You may obtain a
copy of the form at Facility Relocation Notification
http://www.floridadep.org/air/rules/forms/relocation.htm, or by
contacting the Small Business Environmental Assistance Program
(1-800-722-7457).
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47 Any other relocatable concrete batching plant proposing to
change location shall transmit a Facility Relocation Notification
Form (DEP Form No. 62-210.900(6), F.A.C.) to the appropriate
Department of Environmental Protection district or local air
pollution control program office at least five (5) business days
prior to relocation. The form and a statewide list of fax numbers
are provided at the web link below for your convenience.
http://www.floridadep.org/air/rules/forms/relocation.htm
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48 If the facility installs new process or air pollution
control equipment, alters existing process or control equipment
without replacement, or replaces existing process or control
equipment with equipment substantially different than that noted on
the most recent registration form, the owner or operator shall
submit a new and complete AG permit registration form with the
appropriate AG permit processing fee of $100.00 to one of the
Tallahassee addresses listed later in the presentation.
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49 Submitting your Registration Form or Need Additional
Information? Please send your check for $100.00 made out to FDEP
and send the completed registration application to one of the
following addresses depending on your choice of delivery
methods:
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50 Submitting your Registration Form or Need Additional
Information? for OVERNIGHT DELIVERY: (FedEx, UPS, DHL, etc.) FDEP
3800 COMMONWEALTH BLVD, MS-77 TALLAHASSEE, FLORIDA 32399
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51 for regular USPS MAIL DELIVERY: (U.S. Mail) FDEP RECEIPTS
POST OFFICE BOX 3070 TALLAHASSEE, FLORIDA 32315-3070
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-DRAFT Guidance Memo- Due to the current economic climate,
there seem to be many permitted facilities that have temporarily
shut down one or all of their emissions units. The purpose of this
guidance is to review what is currently recommended in these
situations. 52
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Compliance Testing It is recommended that you not require a
shutdown emissions unit to start-up in order to perform a
compliance test by its due date, even if other parts of the
facility are in operation. Please use care and reasonable judgment
in evaluating the situation. For instance, even if there is
activity at a concrete block plant but the cement silo itself is
too full to accept a load of cement, the facility cannot be
reasonably expected to test the filling of the silo for visible
emissions until business improves and requires that a load of
cement be delivered. 53
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54 If an emissions unit is not timely tested because it was
shutdown, or missed any periodic compliance tests required for the
period it was shutdown, the emissions unit should be tested as soon
as practicable but no later than 60 days after startup. If an
emissions unit was timely tested prior to its being shutdown, and
did not miss any periodic compliance tests required for the period
it was shutdown, it is not required to be tested again within 60
days of startup just because it has started back up. Testing can
wait until the next time a compliance test would regularly be due.
Example 1. A cement silo is required to have its visible emissions
tested once every calendar year but the silo was taken out of
operation in October of 2008 without having been tested in 2008. If
the cement silo was placed back in operation on April 1, 2009, it
should be tested for visible emissions as soon as practicable but
no later than May 30, 2009. Example 2. A cement silo is required to
have its visible emissions tested once everycalendar year and the
silo was taken out of operation in October of 2008 after having its
visible emiss- ions tested on October 1, 2008. If the cement silo
was placed back in operation on April 1, 2009, it just needs to be
tested again by December 31, 2009 because no required test was
missed. Example 3. A cement silo is required to have its visible
emissions test once every calendar year and the silo was taken out
of operation in October of 2008 after having its visible emissions
tested on October 1, 2008. If the cement silo was not placed back
in operation until April 1, 2010, it should be tested as soon as
practicable but no later than May 30, 2010 because it missed the
2009 annual test.
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55 Please remember, the requirements of Rule 62-297.310(7)(b),
F.A.C., Special Compliance Tests, apply if the Department has found
a good reason, such as questionable maintenance of control
equipment. Special Compliance test
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List all equipment in the process Include: The MAKE The MAKE
The MODEL The MODEL The Serial # The Capacity 56
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57 Dickson Dibble Air General Permits Program (850) 921-9586 or
Stephen McKeough Small Business Environmental Assistance Program
1-800-722-7457