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Prepared Feeds Manufacturing Sources



40 CFR Part 63, Subpart DDDDDDD (NESHAP 7D)

FINAL RULE (eCFR | PDF File)
NESHAP 7D Fact Sheet (PDF File)
NESHAP 7D FAQ (PDF File)
NESHAP 7D Brochure (PDF File)

Initial Notification & Notification of Compliance Form - May 4, 2012 (PDF File)

Brief Summary
New EPA Regulations for
Prepared Feeds Manufacturing Facility
40 CFR Part 63, Subpart DDDDDDD

On December 16, 2009, the Environmental Protection Agency (EPA) finalized emissions limits for toxic air pollutants from prepared feed manufacturing facilities. Toxic air pollutants, or air toxics, are known or suspected to cause cancer, other serious health problems, and environmental damage.

This rule applies to prepared feed manufacturing are sources that produce animal (not including cat and dog) feed products and use chromium and/or manganese compounds. Area sources emit less than 10 tons per year of a single air toxic, or less than 25 tons per year of all combined air toxics.

All facilities that are subject to the rule will be required to apply best management practices in areas of the facility where materials containing chromium and/or manganese are stored, used, or handled. In addition, facilities with an average daily feed production level of more than 50 tons per day will be required to have control equipment to reduce emissions from one specific operation (pelleting / pellet cooling).

Compliance provisions in the rule include requirements for notifications, recordkeeping, and reporting. Within 120 days of the effective date of the final rule, each facility is required to submit an Initial Notification to the EPA, containing basic information about the facility and its operations. A copy of that notification should also be submitted to the Linn County Public Health Air Quality Branch.

For demonstating ongoing compliance, the requirements include daily, monthly, quarterly, and annual inspections and certifications that the management practices are being followed and the control equipment is operating properly.

Costs & Impacts

There are approximately 1,800 facilities in the prepared feeds manufacturing source category nationwide, most of which are small businesses. EPA believes that prepared feeds manufacturing facilities already implement the required best management practices, so there will be no additional costs for these measures. Costs for notifications, recordkeeping, and reporting are estimated to be $1.7 million per year, or about $980 per facility.

EPA estimates that 26 of the facilities with an average daily feed production level of more than 50 tons per day will be required to install control equipment at a nationwide cost of about $2.5 million. Nationwide annual costs are estimated to be just over $3 million per year.

Compliance with this rule will result in estimated emission reductions of around 1,100 tons per year of particulate matter, 100 tons per year of particulate matter less than 2.5 microns in diameter (PM2.5), and around 20 tons per year of chromium and manganese emissions.

EPA is exempting chemical preparation facilities that would be covered by this rule from obtaining Title V operating permits. After a comprehensive evaluation, the EPA found that:

  • The exemption for these facilities would not adversely affect public health, welfare, or the environment because the level of emissions control would be the same if a Title V permit were required;
  • There are implementation and enforcement programs in place that would ensure compliance with the final standards without relying on a Title V permit; and
  • Requiring Title V permits will be unnecessarily burdensome with regard to cost and technical resources on these smaller industrial facilities.

Background

The Clean Air Act requires EPA to identify categories of sources that emit one or more of the listed hazardous air pollutants (air toxics). These categories include both major and area sources.

Major sources of air toxics emit 10 tons per year of a single air toxic or 25 tons per year of all combined air toxics. Examples include chemical plants and steel mills. Area sources release smaller amounts of toxic pollutants into the air—less than 10 tons per year of a single air toxic, or less than 25 tons of all combined air toxics. Examples include neighborhood dry cleaners and gas stations. Though emissions from individual area sources are often relatively small, collectively, their emissions can be of concern‑particularly where large numbers of sources are located in heavily populated areas

The Clean Air Act requires EPA to identify the hazardous air pollutants (air toxics) that pose a health threat in the largest number of urban areas and to regulate sufficient area source categories to ensure that the emissions of these "urban" air toxics are reduced. EPA implements these requirements through the Integrated Urban Air Toxics Strategy. The prepared feeds manufacturing source category in today's rule is included on the area source category list.

For area soruces within each source category, the Clean Air Act allows EPA to develop standards or requirements which provide for the use of generally available control technologies or management practices (GACT), rather than the maximum achievable control technology (MACT) required for major sources.


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