Concrete Batch Plant - Florida Department of Environmental Protection

Report
Workshop for
Concrete Batching Plants
Air Resource Management
Southwest District Office
March 30, 2010
Mara Nasca
Air Program Administrator
Danielle D. Henry
Air Compliance Supervisor
Cindy Falandysz
Air Enforcement Supervisor
Joe Panetta
Air Program Environmental Specialist III
2
•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. 62210.920(2)(b), F.A.C. - Effective January 10, 2007
• Operating another GP facility at Concrete Batch
Plants
3
** Additional Rules may be required by Hillsborough, Pinellas and Sarasota Counties
4
Southwest District has
137 Concrete Batch
Plant Facilities that are
registered for General
Permit
5


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
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.
7
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.)
8
•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.
9
10
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.
11
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.
12
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)
Pg 40
13
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.
14
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 facility’s 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.
15
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%.
16

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
facility’s existing AG permit
17

1.
2.
3.
4.
The owner/operator or authorized
representative shall submit a new registration
form and fee to the Department prior to a:
change of ownership
physical change in location
any proposed new construction or
modification or other equipment changes
18
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.
19
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.
20
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.
21
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.
22
General Conditions
[Rule 62-210.310(3), F.A.C.]
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:
23
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.
24
25
26
27
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.
28
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)
29
30
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.
31
32
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:
33
a) Management of roads, parking areas,
stock piles, and yards, which shall include one
or more of the following:
34
1. Paving and maintenance of roads, parking areas, and
yards.
2. Application of water or environmentally safe dustsuppressant 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.
35
36
b) Use of spray bar, chute, or partial enclosure to
mitigate emissions at the drop point to the truck.
37
38
EPA Method 9, 40 CFR 60, Appendix A
39
All emissions tests performed pursuant to the
requirements of this subsection shall comply with
the following requirements.
a)
b)
The reference test method for visible emissions is
EPA Method 9, 40 CFR 60 Appendix A
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 EU’s/within 45 days submitted)
40
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.
41
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

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
–
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
44
45
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).
46
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
47

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.
48

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:
49

Submitting your Registration Form or Need
Additional Information?
for OVERNIGHT DELIVERY: (FedEx, UPS, DHL,
etc.)
FDEP
3800 COMMONWEALTH BLVD, MS-77
TALLAHASSEE, FLORIDA 32399
50
…for regular USPS MAIL DELIVERY: (U.S. Mail)
FDEP
RECEIPTS
POST OFFICE BOX 3070
TALLAHASSEE, FLORIDA 32315-3070
51


-DRAFT Guidance MemoDue 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
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
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 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 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.
54
Special Compliance test

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.
55


List all equipment in the process
Include:
 The MAKE
 The MODEL
 The Serial #
 The Capacity
56
Dickson Dibble
Air General Permits Program (850) 921-9586
or
Stephen McKeough
Small Business Environmental Assistance Program
1-800-722-7457
57
Phone number: 813-632-7600
http://www.dep.state.fl.us/southwest/contacts/
58
59
60

similar documents