Florida Department of Environmental Protection

1
Florida Department of Environmental Protection
Workshop for Nonmetallic Mineral Processing
Plants (NMMP) and Affected Asphalt Plants

• Air Resource Management
• Southwest District Office

2
Introductions
Mara Nasca Air Program Administrator Cindy
Zhang-Torres Air Permitting Supervisor Danielle
D. Henry Air Compliance Supervisor Cindy
Falandysz Air Enforcement Supervisor Susan Pelz
Solid Waste Supervisor Natrevia Gradney,
Engineering Specialist Max Grondahl,
Environmental Specialist Nancy Knight,
Engineering Specialist
3
Outline

• Nonmetallic Mineral Processing (NMMP)
  Plant General Permit (GP) Requirements
• New Requirements in 40 CFR 60, New Source
  Performance Standards (NSPS) Subpart OOO
• Operating a RAP Crusher at Asphalt Plants
• Waste Processing Facility Permit Requirements

4
Nonmetallic Mineral Processing (NMMP) Plant
General Permit (GP) Requirements
5
NMMP Rule 62-210.310(5)(e) F.A.C.Air General
Permit for Facilities Comprising Nonmetallic
Mineral Processing Plants

• General Conditions in Rule 62-210.310(3), F.A.C.
• http//www.dep.state.fl.us/air/rules/fac/62-210.pd
  f
• Specific Conditions
• Fuel consumption limits
• Controlling unconfined particulate matter
• Controlling yard dust
• General visible emission requirement
• Subpart OOO requirements
• Title 40, Code of Federal Regulations (CFR), Part
  60, Subpart OOO 60.670-676
• Initial performance tests
• Annual performance tests
• Relocation requirements
• Conditions for collocation
• Non-routine use at non-Title V facilities

6
Fuel Consumption Limits

• Total fuel consumption shall not exceed
• 23,000 gallons per year of gasoline
• 275,000 gallons per year of diesel
• 1.3 million gallons per year of propane
• 44 million standard cubic feet per year of
  natural gas
• Equivalent amount if multiple fuels used.

7
Controlling Unconfined Particulate Matter

• Unconfined emissions from all relocatable
  nonmetallic mineral processing plants, except
  those located at mines or quarries and processing
  only material from onsite natural deposits, and
  all stationary nonmetallic mineral processing
  plants that process dry material shall be
  controlled by using a water suppression system
  with spray bars located wherever unconfined
  emissions occur at the feeders, the entrance and
  exit of the crushers, the classifier screens, and
  the conveyor drop points.

8
EPA Regulatory and Inspection Manual for
Nonmetallic Minerals Processing Plants
(305-B-97-008)
9
Controlling Yard Dust

• Unconfined emissions generated by vehicular
  traffic or wind shall be controlled by applying
  water (by water trucks equipped with spray bars)
  or effective dust suppressants on a regular basis
  to all stockpiles, roadways and work yards where
  the nonmetallic mineral processing plant is
  located.

10
General Visible Emissions Requirement

• Visible emissions from any emission point not
  subject to Subpart OOO shall be less than 20
  opacity.

11
Subpart OOO Requirements

• Types of subject units
• Types of excluded units
• Particulate matter standards
• Test methods and procedures
• Reporting and recordkeeping

12
Subpart OOO Requirements

• The following are types of subject units
  (affected facilities)

• Crushers
• Grinding mills
• Screening operations
• Bucket elevators
• Belt conveyors
• Bagging operations
• Storage bins
• Enclosed truck or railcar loading stations

• In the context of Subpart OOO, affected
  facilities refers to facility components.

13
Subpart OOO Requirements

• Types of subject units
• Crushing of concrete and asphalt pavement is
  subject to Subpart OOO, because both types of
  materials are generally composed of nonmetallic
  minerals listed in 40 CFR 60.671(a) to (r). (EPA
  Applicability Determination Index, Control
  Number NR42)
• Types of excluded units
• Underground mining operations.
• Some equipment associated with hot mix asphalt
  plants and portland cement plants are excluded.

14
Subpart OOO Requirements

• Types of excluded units
• Fixed sand and gravel plants and crushed stone
  plants with capacities of 25 tons per hour or
  less.
• Capacity means the cumulative rated capacity of
  all initial crushers that are part of the plant.
• Portable sand and gravel plants and crushed stone
  plants (e.g. limestone, granite, shell, quartz)
  with capacities of 150 tons per hour or less.
• Common clay plants and pumice plants with
  capacities of 10 tons per hour or less.
• RAP crushers fit into this category.

15
Subpart OOO Requirements

• EPA Applicability Determination Index further
  defines capacity as based on manufacturers
  rating. (Control Number NR122)
• Example The Barmac crusher and associated
  conveyors are subject to Subpart 000 because the
  Barmac crusher has a rated capacity greater than
  150 tons per hour. Although Central Rock claims
  that, because of the size of the feed material
  and product, the Barmac crusher can not process
  more than 150 tons per hour, Subpart 000 is based
  on the actual rated capacity of the affected
  facility which is 260 tons per hour for this
  Barmac crusher according to the manufacturer.

16
Subpart OOO Requirements

• Types of excluded units
• Plants built before, and not modified or
  reconstructed after, August 31, 1983.
• Modification any physical change in, or change
  in the method of operating of, an existing
  facility which increases the amount of any air
  pollutant or causes any new air pollutant to be
  emitted. (40 CFR 60.2)
• Reconstruction40 CFR 60.15(b)
• Reconstruction means the replacement of
  components of an existing facility to such an
  extent that
• (1) The fixed capital cost of the new components
  exceeds 50 percent of the fixed capital cost that
  would be required to construct a comparable
  entirely new facility, and
• (2) It is technologically and economically
  feasible to meet the applicable standards set
  forth in this part.

17
Subpart OOO Requirements

• Standards for particulate matter
• On and after the 60th day after achieving the
  maximum production rate at which the affected
  facility will be operated, but not later than 180
  days after initial startup, no owner or operator
  subject to the provisions of this subpart shall
  cause to be discharged into the atmosphere from
  any transfer point on belt conveyors or from any
  other affected facility any fugitive emissions
  which exhibit greater than 10 percent opacity
  except as provided below.

18
Subpart OOO Requirements

• Definitions
• Transfer Point
• A point in a conveying operation where the
  nonmetallic mineral is transferred to or from a
  belt conveyor except where the nonmetallic
  mineral is being transferred to stockpile. (40
  CFR 60.671Definitions)
• Affected facility
• Crusher, grinding mill, screening operation,
  bucket elevator, belt conveyor, bagging
  operations, storage bin, enclosed truck/rail
  loading station, RAP crusher at asphalt plants.

19
EPA Regulatory and Inspection Manual for
Nonmetallic Minerals Processing Plants
(305-B-97-008)
20
Subpart OOO Requirements

• Standards for particulate matter
• Exceptions to 10 opacity limit requirement
• The opacity limit for fugitive emissions from any
  crusher in which a capture system is not used is
  15.
• Truck dumping (also includes using a front end
  loader, track hoe, etc.) of minerals into any
  screening operation, feed hopper, or crusher is
  exempt from Subpart OOO requirements.

21
EPA Regulatory and Inspection Manual for
Nonmetallic Minerals Processing Plants
(305-B-97-008)
Truck dumping lt20 standard, no testing
Conveyor to stock pile lt20 standard, no testing
Conveyor transfer Point (underbelt to stacker)
10
Crusher (in out), 15 standard
22
EPA Regulatory and Inspection Manual for
Nonmetallic Minerals Processing Plants
(305-B-97-008)
Note When submitting a General Permit
registration or renewal application for a crusher
subject to Subpart OOO, it may be beneficial to
include a flow chart describing plant components
and operation.
23
Subpart OOO Requirements

• Standards for particulate matter
• Wet screening operations a screening operation
  at a nonmetallic mineral processing plant which
  removes unwanted material or which separates
  marketable fines from the product by a washing
  process which is designed and operated at all
  times such that the product is saturated with
  water.
• Wet mining operations a mining or dredging
  operation designed and operated to extract any
  nonmetallic mineral regulated under this subpart
  from deposits existing at or below the water
  table, where the nonmetallic mineral is saturated
  with water.

24
Subpart OOO Requirements

• Test methods and procedures
• The test methods and procedures in Subpart OOO
  are being revised, and the new requirements will
  be discussed later in the presentation.

25
Subpart OOO Requirements

• Reporting and recordkeeping
• The owner or operator shall submit written
  reports of the results of all performance tests
  conducted to demonstrate compliance with
  standards.
• The owner or operator of any screening operation,
  bucket elevator, or belt conveyor that processes
  saturated material and is subject to the wet
  material processing standards and subsequently
  processes unsaturated materials shall submit a
  report of this change within 30 days following
  such change. Likewise if a process is changed
  from dry material to wet material, a report must
  be submitted within 30 days.

26
Subpart OOO Requirements

• Reporting and recordkeeping
• Notification of the actual date of initial
  startup of each affected facility shall be
  submitted.
• The notification may be submitted for a
  combination of affected facilities in a
  production line that share the same initial
  startup date. The notification shall be
  postmarked within 15 days after such date and
  shall include a description of each affected
  facility, equipment manufacturer, and serial
  number of the equipment, if available.
• For portable plants, the startup notification
  shall include both the home office and the
  current location of the portable plant.

If the equipment manufacturer or serial number
are unavailable, this should be specified in the
initial startup notification.
27
Initial Performance Tests Rule
62-210.310(5)(e)3.e., F.A.C.

• For facilities subject to Subpart OOO, initial
  performance tests for visible emissions shall be
  conducted in accordance with the requirements of
  Subpart OOO and Subpart A.
• Within 60 days after achieving the maximum
  production rate at which the affected facility
  will be operated, but not later than 180 days
  after initial startup of such facility, the owner
  or operator shall conduct performance test(s) and
  furnish the Administrator a written report of the
  results of such performance test(s).

28
Annual Performance Tests Rule 62-210.310(5)(e)3.e
., F.A.C.

• For facilities subject to Subpart OOO, annual
  compliance tests must be performed pursuant to
  Rule 62-297.310, F.A.C. and in accordance with
  the test methods and procedures set forth at
  Subpart OOO.
• Test results shall be reported in accordance with
  the provisions of Rule 62-297.310, F.A.C.

29
Annual Performance Tests

• Rule 62-297.310, F.A.C.
• Operating rate during testing
• Observation period
• Reporting
• Test frequency
• Subpart OOO (previously discussed)

30
Annual Performance Tests

• Rule 62-297.310 F.A.C.
• Operating rate during testing
• Testing of emissions shall be conducted with the
  emissions unit operating at permitted capacity.
  If it is impracticable to test at permitted
  capacity, an emissions unit may be tested at less
  than the maximum permitted capacity in this
  case, subsequent emissions unit operation is
  limited to 110 percent of the test rate until a
  new test is conducted. Once the unit is so
  limited, operation at higher capacities is
  allowed for no more than 15 consecutive days for
  the purpose of additional compliance testing to
  regain the authority to operate at the permitted
  capacity.

31
Annual Performance Tests

• Rule 62-297.310, F.A.C.
• Observation period
• The required minimum period of observation for a
  compliance test shall be sixty (60) minutes for
  emissions units which emit or have the potential
  to emit 100 tons per year or more of particulate
  matter, and thirty (30) minutes for emissions
  units which have potential emissions less than
  100 tons per year of particulate matter and are
  not subject to a multiple-valued opacity
  standard. The opacity test observation period
  shall include the period during which the highest
  opacity emissions can reasonably be expected to
  occur.
• Reporting
• Test reports are required to be submitted to the
  Department within 45 days of the test date.

32
Annual Performance Tests

• Rule 62-297.310, F.A.C.
• Test Frequency
• Performance tests for visible emissions must be
  conducted annually. (The rule revision effective
  January 10, 2007 requires annual testing.)
• Annually is considered once each calendar year
  (January 1-December 31).
• DEP guidance memo DARM-OGG-18 http//www.dep.stat
  e.fl.us/air/rules/guidance/ogg18.pdf

33
Relocation Requirements

• Relocation requires notification to the
  Department by telephone, e-mail, fax, or written
  communication at least one business day prior to
  moving and transmit by e-mail, fax, post or
  courier, a Facility Relocation Notification Form
  no later than five business days following
  relocation.
• Relocation Notification Form located online at
  http//www.dep.state.fl.us/air/rules/forms/relocat
  ion.htm

34
Conditions for Collocation

• A crusher using a general permit may be located
  with other facilities that separately registered
  for, and are also using, the NMMP plant air
  general permit, and with facilities using the
  concrete batch plant air general permit, even if
  under the control of different persons as long as
  the following conditions are met.

• The following types of units and activities may
  collocate
• Concrete batching plants using air general
  permits
• NMMP plants using air general permits
• NMMP plants exempt from permitting
• Other emission units and pollutant-emitting
  activities exempt from permitting

35
Conditions for Collocation

• Site-wide fuel usage limitations apply to the
  collocation site.
• Total fuel consumption limits applied to the
  collocation site
• 23,000 gallons per year of gasoline
• 275,000 gallons per year of diesel
• 1.3 million gallons per year of propane
• 44 million standard cubic feet per year of
  natural gas
• An equivalent prorated amount if multiple fuels
  are used

• Site One or more contiguous or adjacent
  properties under control of the same person (or
  persons under common control). (Rule
  62-210.310(5)(e)1., F.A.C.)

36
Conditions for Collocation

• Recordkeeping requirements
• The owners or operators of all collocated
  concrete batching plants and NMMP plants shall
  maintain records to account for site-wide fuel
  consumption for each calendar month and each
  consecutive twelve months. The owners or
  operators shall retain these records, available
  for Department inspection, for at least five
  years.

37
Non-routine Operation at Non-Title V Facilities

• Non-routine use at facilities with air
  construction or air operation permits is allowed
  as long as the following conditions are met
• The NMMP plant must not be located at a single
  site for more than six months in any consecutive
  12 months
• Records must be kept that indicate how long the
  NMMP plant has been at the permitted facility
• No NMMP plant using an air general permit shall
  perform a routine task at a permitted facility
  unless the NMMP plant operation is authorized by
  the permitted facilitys AC or AO permit. RAP
  crushing at an asphalt plant is considered a
  routine task.

38
New Requirements in 40 CFR 60, NSPS Subpart OOO
for NMMPs
39
New Requirements in 40 CFR 60, NSPS Subpart OOO
for NMMPs

• Proposed Effective Date in State Rules is
• October 16, 2009
• NMMP NSPS applies to affected facilities for
  which construction, modification, or
  reconstruction commenced on or after August 31,
  1983.
• These final amendments include revisions for
  affected facilities for which construction,
  modification, or reconstruction commenced on or
  after April 22, 2008.

40
New Requirements in 40 CFR 60, NSPS Subpart OOO

• Monitoring Requirement
• Initial Testing Requirements for Fugitive
  Emissions
• Fugitive Emission Limits
• Initial Testing Notification Requirements
• Recordkeeping and Report Requirements

41
Potentially Affected Regulated Entities
42
Monitoring Requirement Addition
 60.674   Monitoring of operations. (b) If a
wet suppression system is used to control
emissions, facility must perform monthly periodic
inspections to check that water is flowing to
discharge spray nozzles in the wet suppression
system.
Note Only facilities constructed, modified, or
reconstructed on or after April 22, 2008.
43
Initial Testing Requirement for Fugitive
Emissions Revision
 60.675   Test methods and procedures. From (c)
(3) When determining compliance with the fugitive
emissions standard, the duration of the Method 9
observations may be reduced from 3 hours (thirty
6- minute averages) to 1 hour (ten 6-minute
averages) if no individual readings are gt 10
percent and there are no more than three
readings of 10 percent for the 1- hour period.
(c)(4) Deleted (crushers w/o capture
systems) To (c)(3) When determining compliance
with the fugitive emissions standard, the
duration of the Method 9 (40 CFR part 60,
Appendix A4) observations must be 30 minutes
(five 6-minute averages).
Note For all facilities subject to Subpart OOO.
44
Initial Testing Requirement for Fugitive
Emissions Addition
 60.675   Test methods and procedures. (e)(2) A
single visible emission observer may conduct
visible emission observations for up to three
fugitive, stack, or vent emission points within a
15-second interval if the following conditions
are met (i) No more than three emission points
read concurrently (ii) All three emission
points must be w/i a 70 degree viewing angle in
front of the observer such that the proper sun
position can be maintained for all three
points. (iii) If opacity reading for any one of
the three points is ? the applicable standard,
then the observer must stop taking readings from
the other two points and continue reading just
the single point.
Note For all facilities subject to Subpart OOO.
45
(No Transcript)
46
Initial Testing Notification Requirement Revision
 60.675   Test methods and procedures. From (g)
If after 30 days notice for an initial scheduled
performance test, there is a delay in conducting
any rescheduled performance test required in
this section, the owner or operator of an
affected facility shall submit a notice to the
Administrator at least 7 days prior to any
rescheduled test. To (g) For performance tests
involving only Method 9 (40 CFR part 60 Appendix
A4) testing, the owner or operator may reduce
the 30-day advance notification of performance
test in 60.7(a)(6) and 60.8(d) to a 7-day
advance notification.
Note State Rule 62-297.310(7)(a)9,F.A.C.,require
s a 15-day advance notification.
47
Initial Testing Notification Requirement Addition
 60.675   Test methods and procedures. (i) If
the initial performance test date for an affected
facility falls during a seasonal shut down of
the affected facility, then with approval from
the permitting authority, the owner or operator
may postpone the initial performance test until
no later than 60 calendar days after resuming
operation of the affected facility.
Seasonal shut down means shut down of an
affected facility for a period of at least 45
consecutive days due to weather or seasonal
market conditions.
48
Recordkeeping and Report Requirement Addition
 60.676   Reporting and recordkeeping. (b)(1)
Record each monthly periodic inspection required
under 60.674(b) or (c), including dates and any
corrective actions taken, in a logbook (in
written or electronic format). The owner or
operator must keep the logbook onsite and make
hard or electronic copies (whichever is
requested) of the logbook available to the
Administrator upon request.
Note Only facilities constructed, modified, or
reconstructed on or after April 22, 2008.
49
Recordkeeping and Report Requirement Revision
 60.676   Reporting and recordkeeping. From (h)
The subpart A requirement under  60.7 (a)(2)
for notification of the anticipated date of
initial startup of an affected facility shall be
waived for owners or operators of affected
facilities regulated under this subpart. To (h)
The subpart A requirement under  60.7 (a)(1)
for notification of the date construction or
reconstruction commenced is waived for affected
facilities under this subpart.
50
Recordkeeping and Report Requirement Addition
 60.676   Reporting and recordkeeping. (k)
Notifications and reports required under this
subpart and under subpart A of this part to
demonstrate compliance with this subpart need
only to be sent to the EPA Region or the State
which has been delegated authority according to
 60.4(b).
51
RAP Crusher at Asphalt Plants

• New Format for Asphalt Plant Permits
• RAP Crushing System Specific Conditions

52
Waste Processing Facility Permit Requirements
53
Solid Waste Management RuleChapter 62-701,
Florida Administrative Code (F.A.C.)

• Rule 62-701.200, F.A.C. Definitions
• Rule 62-701.300, F.A.C. - Prohibitions
• Rule 62-701.220(2)(d), F.A.C.
• Industrial by-products solid waste permit
  not required
• Majority must be sold, used or reused within 1
  year
• Cannot be hazardous wastes
• Must be managed in such a way that Department air
  or water quality standards or criteria are NOT
  violated
• Rule 62-701.710, F.A.C.
• Waste processing facilities solid waste
  permit required
• Engineering drawings, site plans, operation plan,
  calculations, etc.

54
Solid Waste Management RuleChapter 62-701,
Florida Administrative Code (F.A.C.)
Asphalt road base concrete crushing operations
55
Solid Waste Management RuleChapter 62-701,
Florida Administrative Code (F.A.C.)

Asphalt road base concrete crushing operations
56
Solid Waste Management RuleChapter 62-701,
Florida Administrative Code (F.A.C.)

• Asphalt road base concrete crushing operations
• Generally meet definition of industrial
  by-products
• if BMPs are followed ? ? ? no solid waste permit
  required
• BMPs need to include
• Only clean concrete and asphalt road base
  material is received
• Residues from processing (incidental plastic,
  wood, metal) must be containerized and removed at
  least weekly for offsite disposal

57
Solid Waste Management RuleChapter 62-701,
Florida Administrative Code (F.A.C.)

Waste processing facility Solid waste permit
required
58
Solid Waste Management RuleChapter 62-701,
Florida Administrative Code (F.A.C.)

Waste processing facility Solid waste permit
required
59
Solid Waste Management RuleChapter 62-701,
Florida Administrative Code (F.A.C.)

Waste processing facility Solid waste permit
required
60
Any Questions, Comments? DEP Air Contact
Natrevia GradneyNatrevia.Gradney_at_dep.state.fl.us
DEPs websitewww.dep.state.fl.us/airEPAs
Federal Register Websitewww.epa.gov/federalregist
er EPA Regulatory and Inspection Manual for
Nonmetallic Minerals Processing Plants Document
No. 305B97008http//nepis.epa.gov/epa/html/pubs/p
ubtitleother.htm