|
|
|
|
|
NGF URGES MEMBERS TO OPPOSE CHANGES TO NDEQ FUGITIVE DUST MODELING
The Nebraska Department of Environmental Quality (NDEQ) is considering adopting new modeling methods that could require the inclusion of fugitive dust emissions from truck traffic from haul roads which, if implemented, could cost the grain elevator industry dollars and new paperwork requirements. Currently, elevators, ethanol facilities and other effected industries are allowed to use “best management practices” to control fugitive dust or particulate matter (PM) on their haul roads. NDEQ will be accepting written comments on the proposed changes through August 31, 2009. The new internal modeling methods being considered by NDEQ could require additional permit conditions on the PM source adding additional fugitive dust controls or limiting the source of the emissions operations. These PM admission standards would be applicable to both paved and gravel haul roads. NGF is opposed to any change to current fugitive dust modeling standards or any additional controls. The industry group monitoring NDEQ deliberations have pointed out several errors or inconsistencies with the agencies internal modeling that question the accuracy of the modeling or the necessity of new regulations. Changes to the current NDEQ modeling guideline could expand the industries subject to PM emissions. Grain elevators in Nebraska could be hit especially hard because most elevators have no buffer between the emission source and the “ambient air boundary” because the plant sits along a public highway or the elevator may not have a practical way to control access to the property. As the Association prepares comments to the NDEQ, we are also asking members to submit comments opposing the new PM modeling. At the last meeting, NDEQ showed pictures of clouds of dust from a truck on a haul gravel road for illustration purposes. It could be effective if entities like elevators submit pictures showing how clean the haul roads are and how the BMPs are effective in controlling haul road emissions. Some of the ideas are to include pictures of the following:
You can submit comments to NDEQ under the category of non-technical comments. The comments should be submitted to Shelley Kaderly, shelley.kaderly@nebraska.gov. We will keep members apprised as the process moves forward.
|
  
calendar of events
contact us Nebraska Grain and Feed Association
|
|
|
|
