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Air Resource Management Southwest District Office March 30, 2010 Workshop for Concrete Batching Plants

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2 Mara Nasca Air Program Administrator Danielle D. Henry Air Compliance Supervisor Cindy Falandysz Air Enforcement Supervisor Joe Panetta Air Program Environmental Specialist III

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3 Concrete Batch Plant (CBP) General Permit (GP) Requirements Air General (AG) Permit under Rule 62-210.310(5) (b), Florida Administrative Code, (F.A.C.) for concrete batching plants Registration Requirements in DEP Form No. 62- 210.920(2)(b), F.A.C. - Effective January 10, 2007 Operating another GP facility at Concrete Batch Plants

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4 ** Additional Rules may be required by Hillsborough, Pinellas and Sarasota Counties

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5 Southwest District has 137 Concrete Batch Plant Facilities that are registered for General Permit

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Rule 62-296.414, F.A.C. Concrete Batching Plants. The following requirements apply to new and existing emissions units producing concrete and concrete products by batching or mixing cement and other materials. This rule also applies to facilities processing cement and other materials for the purposes of producing concrete, and to equipment used to mix cement and soil for onsite soil augmentation or stabilization. 6

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7 What is the Purpose of the Regulation? The Department of Environmental Protection has established an Air General (AG) permit under Rule 62-210.310(5)(b), F.A.C., for concrete batching plants.

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8 The use of an AG permit serves two purposes: Provides notice to the Department that the facility is in operation and Prescribes the requirements under which the facility is allowed to operate (Rule 62-210.310(5)(b), F.A.C.)

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9 Eligible concrete batching plants owners are not required to use the AG permit, but instead may choose to obtain a regular Air Operating (AO) permit. This workshop is intended to assist those who choose to seek entitlement to use the AG permit for their concrete batching plant.

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11 Eligible facilities must not be a major source as defined in Rule 62-210.200, F.A.C. *************************************** Eligible facilities must not emit 10 tons or more per year of any listed hazardous air pollutant (HAP), 25 tons per year of any combination of HAPs, or 100 tons per year or more of any other regulated air pollutant.

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12 A facility using the Concrete Batching Plant AG permit may collocate with other facilities: That have separate concrete batching air general permits With facilities using the Nonmetallic Mineral Processing Plant crushers AG permit, even if under the control of different persons.

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13 The facility must meet the following conditions: The collocation site must not contain any emission units and pollutant-emitting activities other than concrete batching plants and nonmetallic processing plants using the general permit, and nonmetallic mineral processing plants or other emissions units and pollutant-emitting activities exempted from permitting. F.A.C. 62-210.300(3) F.A.C. 62-210.300(3) Pg 40

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14 The total fuel consumption by all emissions units at the collocation site shall not exceed 275,000 gallons of diesel fuel per year or 23,000 gallons per year of gasoline or 44 million standard cubic feet per year of natural gas, or 1.3 million gallons per year of propane, or an equivalent prorated amount if multiple fuels are used.

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15 Under the authority of an air general permit: A relocatable CBP may perform a non-routine task making concrete for a construction project, at a facility with authorization by individual air construction or non-Title V Air Operating Permit, without revision to the facilitys air permit. Any such CBP shall remain at the individually permitted facility for no more than: (6) months from the day it relocates to such facility. The owner or operator of such concrete batching plant shall keep records to indicate how long the plant has been at the permitted facility.

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16 If multiple fuels are used, the equivalent prorated amount of each fuel burned shall not exceed the total amount of such fuel allowed to be burned, multiplied by a fuel percentage. Fuel Percentage = Amount of the fuel burned at the facility Total amount of fuel allowed to be burned by the facility **The sum of the fuel percentages for all fuels burned by the facility shall not exceed 100%.

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17 The duration of the Concrete Batching Plant AG permit is five (5) years. The owner /operator or authorized representative must submit the proper registration form and processing fee of $100.00 at least thirty (30) days prior to the expiration of the facilitys existing AG permit

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18 The owner/operator or authorized representative shall submit a new registration form and fee to the Department prior to a: 1. change of ownership 2. physical change in location 3. any proposed new construction or 4. modification or other equipment changes

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19 Definition of modification or other equipment changes : Involving the installation of new process or air pollution equipment Alteration of existing process or control equipment Installation of control equipment substantially different in terms of capacity, method of operation, material processed, or intended use.

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20 The owner/operator or authorized representative shall notify the Department in writing prior to: any sale, permanent shutdown of the facility change in the name, telephone number of the facility or owner/operator or authorized representative when it is not a change in ownership.

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21 The AG permit is not transferable and does not follow a change in ownership of the facility. The new owner/operator or authorized representative shall submit a new registration form and processing fee of $100 at least thirty (30) days prior to the transfer of ownership of the facility to the new owner.

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22 The AG permit is valid only for the specific activity indicated (i.e. Concrete Batch Plant). Any deviation from the specified activity and the conditions for undertaking that activity shall constitute a violation of the permit. The facility must not emit objectionable odors.

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23 If, for any reason, the owner or operator of any facility or emissions unit operating under an AG permit does not comply with or will be unable to comply with any condition or limitation of the permit, the owner or operator shall immediately provide the Department with: General Conditions [Rule 62-210.310(3), F.A.C.]

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24 1.A description of and cause of noncompliance; and, 2.The period of noncompliance, including dates and times; or, if not corrected, the anticipated time the noncompliance is expected to continue, and steps being taken to reduce, eliminate, and prevent recurrence of the noncompliance. The permittee shall be responsible for any and all damages which may result.

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28 Use of the AG permit does not eliminate or relieve the necessity for the owner/operator or authorized representative to obtain any other federal, state, or local permits that may be required.

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29 THE PERMIT DOES NOT AUTHORIZE: ASBESTOS REMOVAL FROM DEMOLITION OR RENOVATION- [Rule 62-257, F.A.C., or 40 CFR Part 61, Subpart M, National Emission Standard for Asbestos] SWD Asbestos Contacts: http://www.dep.state.fl.us/southwest/contacts/ 813-632-7600 OPEN BURNING [Rules 62-256.300 and 62-256.700, F.A.C.] BYPASSING A CONTROL DEVICE (CIRCUMVENTION)

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31 1. Stack Emissions-Emissions from silos, weigh hoppers (batchers), and other enclosed storage and conveying equipment shall be controlled to the extent necessary to limit visible emissions to 5 percent opacity.

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33 2.Unconfined Emissions-The owner or operator shall take reasonable precautions to control unconfined emissions from hoppers, storage and conveying equip, conveyor drop points, truck loading and unloading, roads, parking areas, stock piles, and yards by doing the following:

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34 a) Management of roads, parking areas, stock piles, and yards, which shall include one or more of the following:

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35 1. Paving and maintenance of roads, parking areas, and yards. 2. Application of water or environmentally safe dust- suppressant chemicals when necessary to control emissions. 3. Removal of particulate matter from roads and other paved areas under control of the owner or operator to mitigate reentrainment, from building or work areas to reduce airborne particulate matter from stock piles. 4. Reduction of stock pile height or installation of wind breaks to mitigate wind entrainment of particulate matter from stock piles.

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37 b) Use of spray bar, chute, or partial enclosure to mitigate emissions at the drop point to the truck.

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39 EPA Method 9,40 CFR 60, Appendix A EPA Method 9, 40 CFR 60, Appendix A

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40 All emissions tests performed pursuant to the requirements of this subsection shall comply with the following requirements. EPA Method 9 a) The reference test method for visible emissions is EPA Method 9, 40 CFR 60 Appendix A Rule 62-297.310 b) Test procedures that shall be followed are specified in Rule 62-297.310, F.A.C. and shall be reported to the Department. ( 15 day prior notice, list EUs/within 45 days submitted)

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41 c) Visible emissions test of silo dust collector exhaust points shall be conducted: while loading the silo at a rate that represents the normal silo loading rate. The minimum loading rate shall be 25 tons per hour unless such a rate is unachievable in practice. If emissions from the weigh hopper (batcher) operation are also controlled by the silo dust collector, the batching operation shall be in operation during batching rate and duration. Each test report shall state the actual silo loading rate during emissions testing and, if applicable, whether or not batching occurred during emissions testing.

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d) If emissions from the weigh hopper (batcher) operation are controlled by a dust collector which is separate from the silo dust collector, visible emissions tests of the weigh hopper (batcher) dust collector exhaust point shall be conducted while batching at a rate that is representative of the normal batching rate and duration. Each test report shall state the actual batching rate during emissions testing. 42

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The owner or operator of any concrete batching plant using the AG permit shall have a performance test conducted for visible emissions for each dust collector exhaust point no later than 30 days after commencing operation and once every calendar year thereafter. 43

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44 Test Frequency Performance tests for visible emissions must be conducted annually. (The rule revision effective January 10, 2007 requires annual testing.) o Annually is considered once each calendar year (January 1-December 31). DEP guidance memo DARM-OGG-18: http://www.dep.state.fl.us/air/rules/guidance/ogg18.pdf http://www.dep.state.fl.us/air/rules/guidance/ogg18.pdf

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46 The owner or operator of equipment used to mix cement and soil for augmentation or stabilization proposing to change location shall notify the appropriate Department of Environmental Protection district office or local air pollution control program by phone, e-mail, fax, or written communication at least one business day prior to changing location and transmit a Facility Relocation Notification Form (DEP Form No. 62-210.900(6)) to the Department no later than five business day following relocation. You may obtain a copy of the form at Facility Relocation Notification http://www.floridadep.org/air/rules/forms/relocation.htm, or by contacting the Small Business Environmental Assistance Program (1-800-722-7457).

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47 Any other relocatable concrete batching plant proposing to change location shall transmit a Facility Relocation Notification Form (DEP Form No. 62-210.900(6), F.A.C.) to the appropriate Department of Environmental Protection district or local air pollution control program office at least five (5) business days prior to relocation. The form and a statewide list of fax numbers are provided at the web link below for your convenience. http://www.floridadep.org/air/rules/forms/relocation.htm

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48 If the facility installs new process or air pollution control equipment, alters existing process or control equipment without replacement, or replaces existing process or control equipment with equipment substantially different than that noted on the most recent registration form, the owner or operator shall submit a new and complete AG permit registration form with the appropriate AG permit processing fee of $100.00 to one of the Tallahassee addresses listed later in the presentation.

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49 Submitting your Registration Form or Need Additional Information? Please send your check for $100.00 made out to FDEP and send the completed registration application to one of the following addresses depending on your choice of delivery methods:

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50 Submitting your Registration Form or Need Additional Information? for OVERNIGHT DELIVERY: (FedEx, UPS, DHL, etc.) FDEP 3800 COMMONWEALTH BLVD, MS-77 TALLAHASSEE, FLORIDA 32399

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51 for regular USPS MAIL DELIVERY: (U.S. Mail) FDEP RECEIPTS POST OFFICE BOX 3070 TALLAHASSEE, FLORIDA 32315-3070

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-DRAFT Guidance Memo- Due to the current economic climate, there seem to be many permitted facilities that have temporarily shut down one or all of their emissions units. The purpose of this guidance is to review what is currently recommended in these situations. 52

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Compliance Testing It is recommended that you not require a shutdown emissions unit to start-up in order to perform a compliance test by its due date, even if other parts of the facility are in operation. Please use care and reasonable judgment in evaluating the situation. For instance, even if there is activity at a concrete block plant but the cement silo itself is too full to accept a load of cement, the facility cannot be reasonably expected to test the filling of the silo for visible emissions until business improves and requires that a load of cement be delivered. 53

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54 If an emissions unit is not timely tested because it was shutdown, or missed any periodic compliance tests required for the period it was shutdown, the emissions unit should be tested as soon as practicable but no later than 60 days after startup. If an emissions unit was timely tested prior to its being shutdown, and did not miss any periodic compliance tests required for the period it was shutdown, it is not required to be tested again within 60 days of startup just because it has started back up. Testing can wait until the next time a compliance test would regularly be due. Example 1. A cement silo is required to have its visible emissions tested once every calendar year but the silo was taken out of operation in October of 2008 without having been tested in 2008. If the cement silo was placed back in operation on April 1, 2009, it should be tested for visible emissions as soon as practicable but no later than May 30, 2009. Example 2. A cement silo is required to have its visible emissions tested once everycalendar year and the silo was taken out of operation in October of 2008 after having its visible emiss- ions tested on October 1, 2008. If the cement silo was placed back in operation on April 1, 2009, it just needs to be tested again by December 31, 2009 because no required test was missed. Example 3. A cement silo is required to have its visible emissions test once every calendar year and the silo was taken out of operation in October of 2008 after having its visible emissions tested on October 1, 2008. If the cement silo was not placed back in operation until April 1, 2010, it should be tested as soon as practicable but no later than May 30, 2010 because it missed the 2009 annual test.

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55 Please remember, the requirements of Rule 62-297.310(7)(b), F.A.C., Special Compliance Tests, apply if the Department has found a good reason, such as questionable maintenance of control equipment. Special Compliance test

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List all equipment in the process Include: The MAKE The MAKE The MODEL The MODEL The Serial # The Capacity 56

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57 Dickson Dibble Air General Permits Program (850) 921-9586 or Stephen McKeough Small Business Environmental Assistance Program 1-800-722-7457

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58 Phone number: 813-632-7600 http://www.dep.state.fl.us/southwest/contacts/

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