The Iowa DNR invites the public to provide informal input*
on an upcoming rulemaking affecting grain vacuuming activities at small grain elevators.
Purpose of the Proposed Changes
The purpose of this rulemaking is to establish best management practices (BMPs) for grain vacuuming at small grain elevators. The BMPs include practical activities that may be used at elevators to minimize dust and possible air quality impacts resulting from vacuuming grain out of storage structures. The BMPs were developed through a stakeholder workgroup jointly organized by the Iowa Department of Natural Resources (DNR) and Agribusiness Association of Iowa (AAI), and included grain elevator operators and grain vacuum vendors. The proposed BMPs are already being used at some grain elevators.
Need for rule changes
Prior to 2008, most grain facilities used sweep augers to extract the remaining grain from the bottom of storage bins. Beginning in late 2009, the U.S. Occupational Health and Safety Administration (OSHA) sent letters to grain elevators stating operators could not be inside a grain bin while an unguarded sweep auger operated inside the bin. The OSHA letters resulted in more facilities using grain vacuuming to remove the remaining grain from storage bins.
Although grain vacuuming results in more efficient and safer grain bin cleaning, DNR field offices started receiving dust complaints during grain vacuum operation from nearby residences and businesses. As a result of these complaints, the DNR became concerned about particulate pollution and nuisance dust from increased use of grain vacuuming. The DNR subsequently partnered with AAI to convene a stakeholder workgroup to gather information on grain bin vacuuming and to develop solutions that address complaints and ensure compliance with air quality regulations. The proposed BMPs are the result of this collaborative effort.
Summary of Rule Changes
The rule making will amend the current BMPs for “Group 1” grain elevators currently adopted by reference in 567 Iowa Administrative Code (IAC) Chapter 22. Group 1 grain elevators are specifically defined as facilities with potential particulate emissions less than 15 tons per year (567 IAC rule 22.10). Group 1 elevators are typically smaller grain elevators and are often “country grain elevators” that receive fifty percent or more of their grain from nearby farmers during harvest season. A Group 1 elevator may use the BMP document and the streamlined registration process provided in 22.10 rather than applying for an air construction permit.
The BMPs for Group 1 grain elevators are designed to reduce particulate emissions, especially fugitive emissions. The BMPs include both facility-wide and equipment specific practices and apply to both new and existing equipment. The rule making proposal will add management practices specific to grain vacuuming (grain vac) activities to the current BMP document. Grain elevators that are not classified as Group 1 elevators are not covered under the proposed rule changes. Grain elevators classified as Groups 2, 3, or 4, in rule 22.10, as well as other grain elevators not covered under 22.10, must obtain air construction permits. Construction permits include requirements specific to the facility, and may require BMPs similar to those in the BMP document for Group 1 grain elevators.
The Grain Vac Workgroup convened in August 2011. The workgroup consisted of ten participants in addition to representatives from AAI, DNR and the Iowa Department of Agriculture and Land Stewardship. The facility/business participants included representatives from grain elevators and grain vac vendors. The workgroup met two times between August 2011 and June 2012. In addition, the DNR conducted three onsite visits to observe grain vacs in operation.
Information available for review
Information on the proposed rulemaking is available on the DNR’s website at Air Quality Public Input
. Or, click here: http://www.iowadnr.gov/InsideDNR/RegulatoryAir/StakeholderInvolvement/PublicInput.aspx
How to Provide Input
Please provide any informal comments or suggestions to Christine Paulson, Iowa DNR Air Quality Bureau, by Friday, July 19, 2013,*
Fax: (515) 242-5094
Mail or Hand-delivery: DNR Air Quality Bureau, 7900 Hickman Road, Suite 1, Windsor Heights, Iowa, 50324
In particular, the DNR is interested in input from stakeholders on the regulatory costs, including jobs impacts, for grain elevators to undertake the proposed BMPs for grain vacuuming operation. The DNR requests that grain elevator operators and other interested stakeholders specifically review and comment on the DNR’s draft jobs impact statement and fiscal impact statement (available at the website noted above).
For questions, please contact Christine Paulson at the e-mail address noted above or by phone at (515) 242-5154.
*The informal public input period is an opportunity for stakeholders to assist in developing rule proposals. After considering stakeholder input, the DNR will submit the rulemaking proposal to the Governor’s office for clearance. If cleared, the DNR will present the proposed rulemaking for decision to the Environmental Protection Commission (Commission). The public may provide additional comments at the Commission meeting. If the Commission approves the proposal for publication and comment, a Notice of Intended Action will be published in the Iowa Administrative Bulletin. The formal public comment period for the proposed rule changes will be at least 30 days. The DNR will hold a public hearing during the comment period.
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.