|
NATIONAL GRAIN & FEED ORGANIZATIONS URGE EPA TO MODIFY CHROMIUM, MANGANESE PROPOSED CONTROLS
The NGFA and AFIA issued a joint statement on Aug. 26 to the EPA in response to the agency’s proposed rule that would establish a national emission standard requiring most feed manufacturers that use chromium compounds or manganese compounds to comply with specified management practices and use specified equipment controls.
Among other things, within the joint statement the NGFA and AFIA:
- Strongly disagreed with the EPA methodology used to determine estimated baseline emission levels of chromium compounds and manganese compounds of feed manufacturers and the estimated reductions in such emissions from the use of the proposed management practices and equipment controls.
- Urged EPA to establish appropriate definitions for chromium compounds and manganese compounds and a threshold use level of such compounds that a feed manufacturer would need to use before becoming subject to the proposed rule.
- Opposed EPA-proposed housekeeping practices that are not performance-orientated or based upon any reasonable correlation of such practices and ambient air quality.
- Strongly recommended that EPA revise its proposed provision that would require the use of drop socks at feed load-out points to allow for other options that provide a equivalent level of control, such as physical design/lay-out and use of enclosures.
- Strongly opposed EPA’s proposed provisions that would require cyclones used in pelleting operations to have: 1) an efficiency of at least 95 percent in removing particulate matter of less than 10 microns in diameter; and 2) gauges installed to measure the pressure drop across the unit.
The Nebraska Grain and Feed Association (NGF) agree with the NGFA and AFIA in resisting the proposed controls and will inform you of new developments as they may arise.
|
August 19, 2011
Summer Convention
Quarry Oaks, Ashland NE
January 9-11, 2012
Nebraska Ag Classic
Holiday Inn, Kearney, NE
Nebraska Grain and Feed Association
1233 Lincoln Mall, Suite 200
Lincoln. NE 68508
Phone: 402-476-6174
Fax: 402-476-3401
|
