Grain Journal - July/August 2008 - (Page 106) Temporary or Permanent? PANEL ADDRESSES DISPUTE BETWEEN GRAIN INDUSTRY AND EPA OVER AIR PERMITTING Environmental Open Forum discussion panel from left: Kevin Danner, chairman of a joint GEAPS-NGFA Safety, Health, and Environmental Quality Committee; Marc Fleishaker, NGFA general counsel; Bob Martin, president of LeMar Industries Corp.; and Jess McCluer, NGFA director of regulatory affairs. Photos by Ed Zdrojewski. EDITOR’S NOTE: Much of the information in this article is taken from a panel discussion held during an Environmental Open Forum at the National Grain and Feed Association’s (NGFA) 2008 convention held back in March in Scottsdale, AZ. However, as of press time early in August, the issue of whether or not the U.S. Environmental Protection Agency (EPA) will regard certain temporary storage structures as “permanent grain storage” for purposes of the Clean Air Act remained unresolved. Not every temporary storage structure is under review by the EPA, said Robert Martin, president of LeMar Industries Corp., Des Moines, IA, during an Environmental Open Forum at the 2008 NGFA Convention in Scottsdale, AZ. “In the last three years,” he said, “we’ve built 71 million bushels of traditional rectangular storage, which is filled by a portable auger, and which is not under review by the EPA.” Where grain elevators may be running afoul of the feds is a newer type of round temporary storage characterized by a concrete pad and a center fill tower and conveyor fixed in place in the concrete. LeMar manufactures this 106 GJ J/A type of storage structure. What makes this a critical issue for country grain elevators is the New Source Performance Standards provision of the Clean Air Act that defines elevators that exceed 2.5 million bushels of permanent storage as major sources of PM 10 grain dust particles, that is, particles 10 microns or less. These elevators must obtain Title V air permits from the EPA, a difficult tures as permanent storage, than many of these country elevators will exceed the 2.5-million-bushel limit, in some cases by a wide margin. Center Fill Characteristics One attraction of the center fill configuration, according to Martin, is the savings in labor costs. In a traditional rectangular temporary structure, the grain is aerated through perforated steel or plastic tubing laid out along the ground or pad. Axial fans draw air down through the grain pile and out through the tubing, which not only helps maintain grain quality but also holds the tarp covering in place. Care must be taken in filling this type of pile, however, since it’s very easy to damage the aeration tubes during the process. For most temporary storage managers, going without aeration is not an option. Grain stored outside an upright tank has more exposure to outside elements that cause spoilage, especially if the tarp is blown off during a brisk wind. Managing the tarp is another issue. Covering a pile of grain is a laborintensive procedure that can take a dozen or more workers. Polyethylene tarps, 12 to 14 mils thick, last only one to two years, and if you want to “Since this is not the final EPA action, we can’t sue They appear to have made up their minds on this.” -Jess McCluer, NGFA and expensive process. Elevators across the country have added many millions of bushels worth of temporary storage structures in the past few years in order to handle increasingly large bumper crops and to have enough grain on hand to fill unit trains that can hold up nearly 400,000 bushels each and must be filled in 15 hours or less. If the EPA classifies these struc-
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