Feed NESHAP

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EPA Prepared Feeds Manufacturing National Emission Standard Hazard Air Pollutants (Feed NESHAP) Carolina Feed Industry Association 2010 Fall Conference Nov. 9, 2010 David Fairfield Director of Feed Services National Grain and Feed Association

Transcript of Feed NESHAP

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EPA Prepared Feeds Manufacturing National Emission Standard Hazard Air Pollutants

(Feed NESHAP)Carolina Feed Industry Association

2010 Fall ConferenceNov. 9, 2010

David FairfieldDirector of Feed Services

National Grain and Feed Association

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Mission and PurposeAbundant and

Safe Food Supply

Promotion of Free Markets

Serving the Industry for More than 114 years!

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About the NGFA 850 Active Member companies

• Represent all sectors of the U.S. grain and feed industry

• Over 6,000 locations• Handle over two-thirds of U.S. grain, oilseeds• Over 400 feed manufacturers

200 Associate Member companies• Provide goods and services to the industry

36 State and Regional Affiliates Strategic Alliance with Pet Food Institute

(PFI), and North American Export Grain Association (NAEGA)

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EPA Final Rule Issued Jan. 5, 2010 Governs potential air

emissions of manganese and chromium from covered feed and feed ingredient manufacturers

Establishes a variety of standards, monitoring and inspections requirements

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Applicability Issues 40 CFR 63 Subpart DDDDDDD, §

63.11619 - Am I subject to this subpart?:

(a) You are subject to this subpart if you own or operate a prepared feeds manufacturing facility that uses a material containing chromium or a material containing manganese and is an area source of emissions of hazardous air pollutants (HAP). [Emphasis added.]

(a) You are subject to this subpart if you own or operate a prepared feeds manufacturing facility that uses a material containing chromium or a material containing manganese and is an area source of emissions of hazardous air pollutants (HAP). [Emphasis added.]

(a) You are subject to this subpart if you own or operate a prepared feeds manufacturing facility that uses a material containing chromium or a material containing manganese and is an area source of emissions of hazardous air pollutants (HAP). [Emphasis added.]

(a) You are subject to this subpart if you own or operate a prepared feeds manufacturing facility that uses a material containing chromium or a material containing manganese and is an area source of emissions of hazardous air pollutants (HAP). [Emphasis added.]

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Applicability Issues Is my facility an area source of emissions of

hazardous air pollutants?• “The prepared feeds manufacturing area source

category is identified by the North American Industry Classification System (NAICS) code 311119, “Other Animal Food Manufacturing””

• “The [area source] category was identified in the original section 112(k) emissions inventory through the use of the Standard Industrial Classification (SIC) code 2048, Prepared Feeds Manufacturing, except cat and dog feed…, the NAICS code that covers this area source category is 311119, which is equivalent to the SIC code used in the original source category definition”

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Applicability Issues Is my facility an area source of emissions of

hazardous air pollutants?

• “ …[we (EPA)] clarify that prepared feeds manufacturing at farms and animal feed lots is not part of this source category. Facilities “primarily engaged” in raising or feeding animals are listed under different NAICS codes (e.g., 112210— Hog and Pig Farming, 112112—Cattle Feedlots, 112111—Beef Cattle Ranching and Farming) and were not part of the sources that formed the basis for the listing of the prepared feed manufacturing area source category.”

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Applicability Issues How are NAICS codes assigned?

• NAICS is the standard used by Federal agencies in classifying business establishments for the purpose of obtaining statistical data related to the U.S. business economy

• Each establishment is assigned a NAICS code based upon its own “primary business” activity

• An establishment is defined as “generally a single physical location where business is conducted or where services or industrial operations are performed”

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Applicability Issues What is an establishment’s “primary

business activity?”• Census Bureau: “Ideally, the primary

business activity of an establishment is determined by relative share of production costs and/or capital investment. In practice, other variables, such as revenue, value of shipments, or employment, are used as proxies. The Census Bureau generally uses revenue or value of shipments to determine an establishment’s primary business activity.”

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Applicability Issues Do I own or operate a “prepared feed

manufacturing facility?”• EPA’s definition: “Prepared feed manufacturing

facility means a facility that is primarily engaged in manufacturing animal feed. A facility is primarily engaged in manufacturing animal feed if the production of animal feed comprises greater than 50 percent of the total production of the facility on an annual basis. Facilities primarily engaged in raising or feeding animals are not considered prepared feeds manufacturing facilities.”

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Applicability Issues Do I use a material containing

manganese (Mn) or chromium (Cr)?• Material containing manganese means a

material that contains manganese in amounts greater than or equal to 1.0 percent by weight. Common swine trace mineral premix – 1.5 to 3

pound per ton inclusion rate: 2.6 percent Mn

• Material containing chromium means a material that contains chromium in amounts greater than or equal to 0.1 percent by weight

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Management Practices - Housekeeping(In Regulated Areas)

Manually remove dust by sweeping or by a vacuum system

Once per month, remove dust from walls, ledges, and equipment

Keep doors shut except during entrance and exit

Store Mn and Cr materials in closed containers

Management Practices - Mixer• Mixer is to be covered at all times except when

adding materials• Mn and Cr materials are to be added to the mixer

in a manner to minimize emissions

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Management Practices - Feed Load-Out (For Regulated Materials)

Each load-out is to have a “device” to lessen fugitive emissions, such as drop sock or telescopic spout• Applies even to enclosed

load-out systems• Device is to be inspected

monthly to ensure proper operation

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Pelleting Operations Requirements -Applicable to covered facilities with 50 ton per day

annual production average for all feeds Cooler cyclone is to provide 95 percent or

greater particulate matter removal demonstrated by• Manufacturer’s specifications• Certification by a

Professional Engineer or Responsible Person

• EPA-recognized Method 5 Stack Test

Establish proper operation parameters for cyclone inlet flow or inlet velocity or pressure drop or fan amperage

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Demonstrating Pellet Cyclone Efficiency Method 5 Stack Test

• Cost is $10,000 to $15,000 for single system• Cost is $15,000 to $20,000 for two systems same

location Includes particle size distribution (PSD)

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Demonstrating Pellet Cyclone Efficiency

Method 5 Stack TestInlet Outlet

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Demonstrating Pellet Cyclone Efficiency Manufacturer’s Specification

• Most are hesitant to provide “blanket” statement that equipment meets required efficiency level

• At a minimum, most will want a PSD, along with other some other operating parameters

Professional Engineer’s Certification• Models are available to determine efficiency• Input of cyclone dimensions, PSD, particle

density, air flow, and air temperature

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5 10 15 20 30 40 60 70 80

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Typical Cyclone Performance Curves

"Normal"Efficiency

"High"Efficiency

Microns

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Cyclone Design ParametersTexas A&M University

Some agencies require 1D3D or 2D2D cyclones

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Cyclone Monitoring and Recordkeeping Requirements

Pellet cyclones are to be maintained and operated in accordance with manufacturer’s specifications. If manufacturer’s specifications are not available, the facility is to develop and follow standard maintenance and operating procedures that ensure the proper operation of the cyclone.

Pellet cyclones are to be inspected quarterly for corrosion, erosion or other damage that could result in air leakage.

The pellet cyclone’s inlet flow rate, inlet velocity, pressure drop or fan amperage is to be monitored on each day that the pelleting process is operating.

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You will need access to your cyclones for inspection…

How will you monitor inlet flow rate, inlet velocity, pressure drop or fan amperage?

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Notification and Compliance Timeframes and Requirements

Initial Notification: Effected firms were to have notified EPA and their local permitting agency by May 5, 2010

Compliance Date:• Existing facilities: January 5, 2012• New facilities (those that commenced construction or

reconstruction after July 27, 2009): Upon start-up Notification of Compliance:

• Existing facilities: May 4, 2012• New facilities: Oct. 18, 2010, or within 120 days of

initial startup, whichever is later

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Notification and Compliance Timeframes and Requirements

Annual Compliance Certification: After providing the initial notification of compliance status, every March 1 thereafter, covered facilities are required to prepare annual compliance certification reports for the previous calendar year, and submit the report under certain circumstances

Recordkeeping: The final rule mandates that required records, notifications and reports be retained for at least five years after they are created

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Compliance Timeline Issues New cyclone delivery can take 12 to

16 weeks• Costs?

Location dependant $25,000 to $75,000

Permit requirements• Permit preparation and approval can

take considerable time

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Take Home Points on NESHAP Carefully review your applicability issues

• Many feed mills use manganese compounds with a Mncontent of greater than or equal to 1.0 percent by weight

• Notify EPA and local permitting agency, if needed

Look at your housekeeping, doors/windows and load-out issues

Evaluate your pelleting cyclones• Are they 95 percent efficient?• How will you inspect them and monitor performance?

Compliance date for existing facilities is January 5, 2012.

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Salmonella in Animal Feed 21 CFR § 500.35 - Animal feeds contaminated

with Salmonella microorganisms• (b) Articles used in food for animals are included within the

definition of food in section 201(f) of the Federal Food, Drug, and Cosmetic Act. Further, Salmonella contamination of such animal feeds having the potentiality for producing infection and disease in animals must be regarded as an adulterant within the meaning of section 402(a) of the act. Therefore, the Food and Drug Administration will regard as adulterated within the meaning of section 402(a) of the act shipments of the following when intended for animal feed and encountered in interstate commerce and found upon examination to be contaminated with Salmonella microorganisms: Bone meal, blood meal, crab meal, feather meal, fish meal, fish solubles, meat scraps, poultry meat meal, tankage, or other similar animal byproducts, or blended mixtures of these.

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Salmonella FDA Compliance Guidance -July 27, 2010

“Direct Human Contact Animal Feed” - animal feed, such as pet food and pet treats, that are intended to be fed to animals in homes, petting zoos, agricultural fairs, and similar venues• If such products contain Salmonella they should be

considered adulterated if they will not subsequently undergo a commercial heat step or other commercial process that will kill the Salmonella (such as rendering, pelleting, extrusion, irradiation, etc.) prior coming into “direct human contact.”

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Salmonella FDA Compliance Guidance -July 27, 2010

“Non-direct human contact animal feed”• Other animal feed and feed ingredients contaminated

with a Salmonella serotype that poses a pathogenic danger to a particular species of animal for which it is intended and will not subsequently undergo a commercial heat step or other commercial process that will kill the salmonella (such as rendering, pelleting, extrusion, irradiation, etc.) prior to feeding should be considered adulterated Poultry feed - Salmonella Pullorum, Salmonella Gallinarum, or

Salmonella Enteritidis Swine feed - Salmonella Choleraesuis Sheep feed - Salmonella Abortusovis Horse feed - Salmonella Abortusequi Dairy and beef feed(s) - Salmonella Newport or Salmonella

Dublin

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Thank you!

David FairfieldDirector of Feed ServicesNational Grain and Feed AssociationEmail: [email protected]: (712) 243‐4035