December 14, 2007
Grain Elevator PTE Calculation Tool Available for Use
www.agribiz.org A tool to facilitate the calculation of potential to emit (PTE) of regulated air pollutants from
country grain elevators, grain terminal elevators, and country grain terminal elevators is
available for free download at www.iwrc.org .
Inside this issue:
The primary purpose of the tool is to assist grain elevator owners and operators with
Page 1 calculating their PTE particulate matter with a diameter less than or equal to 10 microns,
referred to as PM-10. The tool’s calculations help grain elevator owners determine which
Grain Elevator PTE permitting rules their facility is subject to.
Available for Use The PTE calculation tool was developed by the Iowa Air Emissions Assistance Program (IAEAP)
of the Iowa Waste Reduction Center (IWRC), located at the University of Northern Iowa, in
District Meeting partnership with the Agribusiness Association of Iowa (AAI) and the DNR. For questions
Reminder related to downloading and installing the PTE calculation tool, please contact the IAEAP at
50 Days to Top Screen The PTE calculation tool allows owners and operators to take emissions reduction credit for
Deadline the use of an enclosure on dump pits or load outs that vent to an air pollution control device,
Page 3 such as a cyclone or baghouse.
What's covered under Some facilities have dump pit or load out enclosures that do not vent to an air pollution
the new rule? control device. These are referred to as uncontrolled enclosures. AAI and DNR are still
discussing to what extent, if any, emissions reduction credit should be allowed from these types
of enclosures. It is anticipated that this issue will be resolved within the next couple of weeks.
AAI ALERT Any changes made to the calculation tool as a result of resolution of this issue will be posted at
www.iwrc.org and discussed in a future list serve.
Owners and operators who do not plan to take credit for an uncontrolled enclosure in their
Ends at Midnight on PTE calculations can proceed with using the PTE calculation tool to support the submittal of
12/15/07!!!!! the appropriate registration or application forms. Owners or operators who wish to consider
On September 14, 2007, in claiming credit for an uncontrolled enclosure are advised to wait for the outcome of the
an effort to help farmers discussions between AAI and DNR.
move this year’s record corn
harvest, Governor Chet Workshops to help familiarize grain elevator owners and operators with the proposed
Culver signed a proclamation permitting rules for grain elevators and the PTE calculation tool were started in November
granting a temporary weight
2007. For dates and locations of upcoming workshops please go to www.iowacleanair.com .
limit exemption. This
proclamation increased the
weight allowable for The proposed permitting rules were scheduled to be considered for final adoption at the
shipment of soybeans, corn, December 4, 2007 Environmental Protection Commission (EPC) meeting. At DNR’s and AAI’s
hay, straw and stover to requests, consideration of final adoption was tabled by the Commission due to the on-going
88,000 pounds gross weight discussions about the uncontrolled enclosure credit issue. The proposed grain elevator
without the need for an
permitting rules will be considered by the EPC for final adoption at the January 15, 2008 EPC
This exemption, set to expire
on Wednesday November 15,
was extended. On Thursday,
November 15, Governor District Meeting Reminder
Culver issued a proclamation
extending the exemption for AAI District Meetings are packed with new regulatory and legislative issues! Please come to the
an additional 30 days. The meetings next week: District 6, Dec. 17, 8:00 am, 4 Corners Restaurant, Ainsworth; District 5,
deadline is midnight on Dec. 17, 12:30 pm, Pizza Ranch, Pella; District 2, Dec.18, 8:00 am, Golden Eagle Coop,
December 15th. For the full
Goldfield; District 1, Dec. 18, 1:00 pm, Lake Shore Café, Storm Lake; District 4, Dec. 19,
article and proclamation,
please visit www.agribiz.org.
8:30 am, Happy Chef, Adair. These are “DON’T MISS MEETINGS” this year!
December 14, 2007
50 Days to Top-Screen Deadline - Don’t Wait Till the Last Minute
The Department of Homeland Security (DHS) finally published Appendix A, the List of Regulated
Chemicals, in the Federal Register on November 20, 2007. Appendix A specifies the threshold
www.agribiz.org quantities of chemicals that must be reviewed for compliance with the Chemical Facility Anti-
Terrorism Standards (CFATS). Any facility that possesses (or later comes into possession of) the
listed chemicals in quantities that meet or exceed the screening threshold quantity will have 60
days from the November 20th date to review and complete (if applicable) the CFATS require-
ments. DHS has posted an announcement on its website extending the Top-Screen submission
deadline date to Tuesday, January 22, 2008, due to the weekend and Federal holiday on Mon-
day, January 21, 2008.
How do I comply with CFATS?
Tips on CFATS Compliance - (listed by step)
Step 1 - Review of Appendix A to see if your facility is required to register.
- Calcium Ammonium Nitrate - Facilities with this product should await final interpreta-
tion from DHS whether this product is regulated or not.
- Aluminum Phosphide - Facilities with this product delivered into the facility for final
use are not regulated by DHS if the facility does not ship the product.
- Ammonium Nitrate - We are awaiting final interpretations on questions concerning
transportation packaging and the applicability of the mixture rule.
- Document your review of Appendix A. Maintain the documentation on file.
Step 2 - Register with DHS, if required.
- Reports indicate facilities are receiving their username and password approximately 14
days after registration.
Step 3 - Complete and Submit the Top-Screen
- Best advice continues to be print off a copy of the Top-Screen questions and answer
them on paper before attempting to enter the answers into the computer.
- Sections entitled “Mission Critical” and “Economic Critical” typically do not apply to
small businesses such as farm centers.
- Utilize the longitude/latitude from your most recent Risk Management Plan (RMP) for
consistency. If you do not have a RMP, we recommend you use EPA’s TRI Siting Tool
for use in determining the most accurate longitude/latitude for your facility. Click here
to access the TRI Siting Tool.
- After submitting your Top-Screen, DHS will notify your facility with one of three
1. DHS needs more information in order to determine your level of risk;
2. Your facility is exempt and in compliance with the regulation (Tiered out); or
3. Your tier rating and deadlines for completion of a security vulnerability
assessment (SVA) and Site Security Plan (SSP).
• After the Top-Screen process, your next steps will only be completed when notified
to do so by DHS. Not many companies will need to comply with these regulations
beyond the Top-Screen process. DHS estimates that 6,000 facilities will fall into the
high-risk category as covered facilities.
CFATS gives DHS authority to seek compliance through civil penalties of up to $25,000 per day,
and the ability to shut down non-compliant facilities.
Industry Urges EPA to Proceed with Pesticide Container Rule CropLife America is calling on the
EPA to proceed on a definitive schedule with a rule to require the recycling of empty, disposable
plastic pesticide containers used in agricultural and professional applications in the United States.
December 14, 2007
Employer-paid PPE: What's covered under the new rule?
www.agribiz.org It was a long time coming, but on November 15, 2007, OSHA finally issued its final rule on
employer payment for personal protective equipment (PPE). Under the rule, all required PPE,
Page 3 with a few exceptions, must be provided at no cost to the employee. Employers must
implement the PPE payment requirements no later than May 15, 2008. The rule does not spec-
ify the method that employers must use to pay for PPE. Many employers use allowances or
reimbursement systems, or maintain a stock of PPE and hand it out to their employees. All
these methods are acceptable, as long as the employee receives the PPE at no cost.
Examples under the new rule Employers do NOT have to pay for:
· Non-specialty safety-toe protective footwear (e.g., steel-toe shoes/boots)
· Non-specialty prescription safety eyewear
· Sturdy work shoes
· Lineman's boots
· Ordinary cold weather gear (coats, parkas, cold weather gloves, winter boots)
· Logging boots required under Sec. 1910.266(d)(1)(v)
· Ordinary rain gear
· Back belts
· Long sleeve shirts
· Long pants
Welcome To Our · Dust mask/respirators used under the voluntary use provisions in Sec.1910.134.
Compliance Update Examples under the new rule Employers DO have to pay for:
With all the creative · Foot protection
types in government · Special boots for longshoremen working logs
making new regulations · Rubber boots with steel toes
for our industry it takes a · Shoe covers--toe caps and metatarsal guards
full time staff just to · Non-prescription eye protection
keep up with it. And · Prescription eyewear inserts/lenses for full face respirators
who has time for that? · Prescription eyewear inserts/lenses for welding and diving helmets
AAI, that's who! AAI · Goggles
examines the latest rules · Face shields
· Laser safety goggles
and regulations affecting
· Fire fighting PPE (helmet, gloves, boots, proximity suits, full gear)
your business. As a · Hard hats
member you will receive · Hearing protection
a copy of the · Welding PPE
latest-breaking · Non-specialty gloves: Payment is required if they are PPE, i.e. for protection
regulatory news every from dermatitis or severe cuts/abrasions. Payment is not required if they are only
two weeks. If you for keeping clean or for cold weather (with no safety or health consideration).
would like to receive this · Rubber sleeves
newsletter by e-mail · Aluminized gloves
· Chemical resistant gloves/aprons/clothing
please let the AAI office
· Barrier creams (unless used solely for weather-related protection)
know by e-mailing · Rubber insulating gloves
Jeannine at · Mesh cut proof gloves, mesh, or leather aprons
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