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NGF REQUESTS MEETING ON NDEQ CLEAN AIR ACTIONS EPA Definition of Temporary Storage at Issue The Nebraska Grain and Feed Association (NGF) have requested an informal meeting with the Nebraska Department of Environmental Quality (NDEQ) on their interpretation of proposed New Source Performance Standards (NSPS), Subpart DD of the Clean Air Act. Currently, the NSPS rules requiring stricter air permitting and emission standards apply to any commercial grain elevator built after 1978 with a permanent storage capacity exceeding 2.5 million bushels, or increased their permanent storage capacity beyond the 2.5 million bushels. However, the grain handling industry has since 2006 disputed the Environmental Protection Agency’s (EPA) inclusion of recently constructed temporary storage capacity as permanent storage, affecting potentially dozens of elevators that could now exceed the 2.5 million bushel permanent storage capacity threshold, subjecting them to new costly air permitting requirements under the Clean Air Act. In the letter, NGF pointed out to NDEQ that since 2006, the National Grain and Feed Association (NGFA) has asked EPA to clarify that temporary grain storage be defined consistently with a definition the US Department of Agriculture (USDA) has used for approximately 30 years. Based on an NDEQ recent e-mail to NGF, it appears that the NDEQ is relying on the Nov. 21, 2007 letter from the EPA to the NGFA in which they tentatively conclude that certain types of temporary grain storage – those with an aeration tower – constitute permanent storage based upon Webster’s Dictionary definition of a “bin.” Following the letter, the EPA stated that it planned to resolve the temporary storage matter through a comprehensive review of the NSPS for Grain Elevators. As a result, the NGFA and five other grain-processing organizations have formed a coalition to interact with the EPA during the agency’s NSPS review. The NGFA is co-chairing the effort with the National Oilseed Processors Association (NOPA). The North American Millers Association (NAMA), Corn Refiners Association (CRA), National Council of Farmer Cooperatives (NCFC) and the USA Rice Federation are also participating in the joint effort. Industry and staff representatives from the coalition met with EPA officials in April and May to discuss the NSPS review. During the meetings, the groups discussed EPA’s intentions for gathering information during its NSPS review, including both the Clean Air Act’s required Section 114 questionnaire and industry-supplied data. In requesting the meeting, NGF stated they are concerned that any reclassification of temporary storage to permanent storage is premature given the EPA’s current review and could make facilities incur significant costs to comply with the current grain elevator standard when those requirements will almost certainly change after the NSPS review is finished.
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