EPA Amends Air Toxics Rules Affecting Prepared Feeds Manufacturing
Posted: 01/26/2012
EPA recently finalized amendments to air toxics standards affecting facilities that manufacture prepared feeds. 

On December 23, 2011, EPA issued “direct final” amendments to the National Emission Standards for Hazardous Air Pollutants (NESHAP) for Area Sources: Prepared Feeds Manufacturing (40 Code of Federal Regulations (CFR) Part 63, Subpart DDDDDDD), sometimes referred to as “7D” or “7D NESHAP.”
The amendments revise the requirements for emissions control for pelleting operations at facilities with a feed throughput of over 50 tons per day. These revisions apply only to existing facilities. Existing, large facilities would still be required to control pelleting operations with a cyclone, but the cyclone would not have to achieve a 95% control efficiency. EPA also clarified the requirement to keep doors closed in some areas of the facility, and clarified the bulk load-out requirements. An existing source (facility) is one that commenced construction before July 27, 2009.
This direct final rule with EPA’s amendments to address the control requirements for pelleting operations becomes effective on February 21, 2012, unless the EPA received adverse comment by January 23, 2012. The notice published in the Federal Register is available at http://www.gpo.gov/fdsys/pkg/FR-2011-12-23/pdf/2011-32835.pdf
EPA had earlier issued a Letter of No Action Assurance (NAA) regarding the control requirements for pelleting operations under the 7D NESHAP. Since the compliance date for this rule was January 5, 2012, EPA issued the NAA to exercise its enforcement discretion to allow existing affected sources to continue to operate without demonstrating compliance with the 95% control efficiency specified in the 7D NESHAP. The NAA is specific to this one requirement and affected sources must comply with all other requirements in the rule. The NAA is available at http://www.iowadnr.gov/Portals/idnr/uploads/air/insidednr/neshap/7d_epa_memo.pdf
The Iowa DNR initially adopted the 7D NESHAP into state air quality rules, but the adoption was rescinded through Executive Order 72. Once EPA’s amendments become effective, the DNR plans to seek input from stakeholders on re-adopting the 7D NESHAP.
At this time, questions concerning applicability or compliance with the 7D NESHAP should be directed to Leslye Werner at EPA Region VII, by email at Werner.leslye@epa.gov or by phone at (913) 551-7858.
For general questions, please contact Diane Brockshus (Email: diane.brockshus@dnr.iowa.gov or phone: (515) 281-4801) or Brian Hutchins (Email: brian.hutchins@dnr.iowa.gov or phone: (515) 281-8448).

This list serve article is intended for consultants, industries, environmental groups, general public, and other entities regulated under the Clean Air Act. It was written by the DNR Air Quality Bureau to share regulatory news, program updates and technical guidance.