Workshop for
Nonmetallic Mineral Processing
Plants (NMMP) and Affected Asphalt
Plants
Air Resource Management
Southwest District Office
Mara Nasca
Air Program Administrator
Cindy Zhang-Torres
Air Permitting Supervisor
Danielle D. Henry
Air Compliance Supervisor
Cindy Falandysz
Air Enforcement Supervisor
Susan Pelz
Solid Waste Supervisor
Natrevia Gradney, Engineering Specialist
Max Grondahl, Environmental Specialist
Nancy Knight, Engineering Specialist
2
• Nonmetallic Mineral Processing (NMMP)
Plant General Permit (GP) Requirements
• New Requirements in 40 CFR 60, New
Source Performance Standards (NSPS)
Subpart OOO
• Operating a RAP Crusher at Asphalt Plants
• Waste Processing Facility Permit
Requirements
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4

General Conditions in Rule 62-210.310(3), F.A.C.
◦ http://www.dep.state.fl.us/air/rules/fac/62-210.pdf

Specific Conditions
◦
◦
◦
◦
◦
Fuel consumption limits
Controlling unconfined particulate matter
Controlling yard dust
General visible emission requirement
Subpart OOO requirements
 Title 40, Code of Federal Regulations (CFR), Part 60, Subpart OOO;
60.670-676
◦ Initial performance tests
◦ Annual performance tests
◦ Relocation requirements


Conditions for collocation
Non-routine use at non-Title V facilities
5
• Total fuel consumption shall not exceed:
• 23,000 gallons per year of gasoline
• 275,000 gallons per year of diesel
• 1.3 million gallons per year of propane
• 44 million standard cubic feet per year of
natural gas
• Equivalent amount if multiple fuels used.
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 Unconfined
emissions
from
all
relocatable
nonmetallic mineral processing plants, except
those located at mines or quarries and processing
only material from onsite natural deposits, and all
stationary nonmetallic mineral processing plants
that process dry material shall be controlled by
using a water suppression system with spray bars
located wherever unconfined emissions occur at
the feeders, the entrance and exit of the crushers,
the classifier screens, and the conveyor drop
points.
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8
 Unconfined emissions generated by vehicular traffic
or wind shall be controlled by applying water (by
water trucks equipped with spray bars) or effective
dust suppressants on a regular basis to all
stockpiles, roadways and work yards where the
nonmetallic mineral processing plant is located.
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 Visible emissions from any emission point
not subject to Subpart OOO shall be less
than 20% opacity.
10





Types of subject units
Types of excluded units
Particulate matter standards
Test methods and procedures
Reporting and recordkeeping
11
• The following are types of subject units (affected
facilities*)
•
•
•
•
•
Crushers
Grinding mills
Screening operations
Bucket elevators
Belt conveyors
• Bagging operations
• Storage bins
• Enclosed truck or
railcar loading stations
*In the context of Subpart OOO, “affected facilities” refers to facility
components.
12

Types of subject units
◦ Crushing of concrete and asphalt pavement is subject to
Subpart OOO, because both types of materials are generally
composed of nonmetallic minerals listed in 40 CFR
60.671(a) to (r). (EPA Applicability Determination Index,
Control Number: NR42)

Types of excluded units
◦ Underground mining operations.
◦ Some equipment associated with hot mix asphalt plants
and portland cement plants are excluded.
13
•
Types of excluded units
– Fixed sand and gravel plants and crushed stone plants with
capacities of 25 tons per hour or less.
– Capacity means the cumulative rated capacity of all initial
crushers that are part of the plant.
– Portable sand and gravel plants and crushed stone plants*
(e.g. limestone, granite, shell, quartz) with capacities of
150 tons per hour or less.
– Common clay plants and pumice plants with capacities of
10 tons per hour or less.
*RAP crushers fit into this category.
14

EPA Applicability Determination Index further
defines “capacity” as based on manufacturer’s
rating. (Control Number: NR122)
o
Example: “The Barmac crusher and associated conveyors
are subject to Subpart 000 because the Barmac crusher
has a rated capacity greater than 150 tons per hour.
Although Central Rock claims that, because of the size of
the feed material and product, the Barmac crusher can not
process more than 150 tons per hour, Subpart 000 is
based on the actual rated capacity of the affected facility
which is 260 tons per hour for this Barmac crusher
according to the manufacturer.”
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
Types of excluded units
◦ Plants built before, and not modified or reconstructed after,
August 31, 1983.
◦ Modification – any physical change in, or change in the
method of operating of, an existing facility which increases
the amount of any air pollutant or causes any new air
pollutant to be emitted. (40 CFR 60.2)
◦ Reconstruction—40 CFR 60.15(b)
 “Reconstruction” means the replacement of components of an existing
facility to such an extent that:
 (1) The fixed capital cost of the new components exceeds 50 percent
of the fixed capital cost that would be required to construct a
comparable entirely new facility, and
 (2) It is technologically and economically feasible to meet the
applicable standards set forth in this part.
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•
Standards for particulate matter
– On and after the 60th day after achieving the maximum
production rate at which the affected facility will be
operated, but not later than 180 days after initial startup,
no owner or operator subject to the provisions of this
subpart shall cause to be discharged into the atmosphere
from any transfer point on belt conveyors or from any other
affected facility any fugitive emissions which exhibit greater
than 10 percent opacity except as provided below.
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
Definitions
◦ “Transfer Point”
 A point in a conveying operation where the nonmetallic mineral
is transferred to or from a belt conveyor except where the
nonmetallic mineral is being transferred to stockpile. (40 CFR
60.671—Definitions)
◦ “Affected facility”
 Crusher, grinding mill, screening operation, bucket elevator,
belt conveyor, bagging operations, storage bin, enclosed
truck/rail loading station, RAP crusher at asphalt plants.
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19

Standards for particulate matter
◦ Exceptions to 10% opacity limit requirement
 The opacity limit for fugitive emissions from any crusher in
which a capture system is not used is 15%.
 Truck dumping (also includes using a front end loader, track
hoe, etc.) of minerals into any screening operation, feed hopper,
or crusher is exempt from Subpart OOO requirements.
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Truck dumping:
<20% standard, no
testing
Conveyor
transfer
Point
(underbelt
to stacker):
10%
Conveyor to stock pile: <20% standard, no testing
Crusher (in
& out), 15%
standard
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*Note: When submitting a
General Permit registration
or renewal application for a
crusher subject to Subpart
OOO, it may be beneficial
to include a flow chart
describing plant
components and operation.
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
Standards for particulate matter
 Wet screening operations: a screening operation at a
nonmetallic mineral processing plant which removes
unwanted material or which separates marketable fines
from the product by a washing process which is designed
and operated at all times such that the product is saturated
with water.
 Wet mining operations: a mining or dredging operation
designed and operated to extract any nonmetallic mineral
regulated under this subpart from deposits existing at or
below the water table, where the nonmetallic mineral is
saturated with water.
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
Test methods and procedures
 The test methods and procedures in Subpart OOO are being
revised, and the new requirements will be discussed later in
the presentation.
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
Reporting and recordkeeping
◦ The owner or operator shall submit written reports of the
results of all performance tests conducted to demonstrate
compliance with standards.
◦ The owner or operator of any screening operation, bucket
elevator, or belt conveyor that processes saturated material
and is subject to the wet material processing standards and
subsequently processes unsaturated materials shall submit
a report of this change within 30 days following such
change. Likewise if a process is changed from dry material
to wet material, a report must be submitted within 30 days.
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
Reporting and recordkeeping
– Notification of the actual date of initial startup of each
affected facility shall be submitted.
• The notification may be submitted for a combination of affected
facilities in a production line that share the same initial startup
date. The notification shall be postmarked within 15 days after
such date and shall include a description of each affected
facility, equipment manufacturer, and serial number of the
equipment, if available*.
• For portable plants, the startup notification shall include both
the home office and the current location of the portable plant.
*If the equipment manufacturer or serial number are unavailable, this
should be specified in the initial startup notification.
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 For facilities subject to Subpart OOO, initial
performance tests for visible emissions shall be
conducted in accordance with the requirements of
Subpart OOO and Subpart A.
 Within 60 days after achieving the maximum production
rate at which the affected facility will be operated, but not
later than 180 days after initial startup of such facility, the
owner or operator shall conduct performance test(s) and
furnish the Administrator a written report of the results of
such performance test(s).
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

For facilities subject to Subpart OOO, annual
compliance tests must be performed pursuant to
Rule 62-297.310, F.A.C. and in accordance with
the test methods and procedures set forth at
Subpart OOO.
Test results shall be reported in accordance with
the provisions of Rule 62-297.310, F.A.C.
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
Rule 62-297.310, F.A.C.
◦
◦
◦
◦

Operating rate during testing
Observation period
Reporting
Test frequency
Subpart OOO (previously discussed)
29
•
Rule 62-297.310 F.A.C.
– Operating rate during testing
• Testing of emissions shall be conducted with the emissions unit
operating at permitted capacity. If it is impracticable to test at
permitted capacity, an emissions unit may be tested at less than
the maximum permitted capacity; in this case, subsequent
emissions unit operation is limited to 110 percent of the test
rate until a new test is conducted. Once the unit is so limited,
operation at higher capacities is allowed for no more than 15
consecutive days for the purpose of additional compliance
testing to regain the authority to operate at the permitted
capacity.
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•
Rule 62-297.310, F.A.C.
– Observation period
• The required minimum period of observation for a compliance
test shall be sixty (60) minutes for emissions units which emit
or have the potential to emit 100 tons per year or more of
particulate matter, and thirty (30) minutes for emissions units
which have potential emissions less than 100 tons per year of
particulate matter and are not subject to a multiple-valued
opacity standard. The opacity test observation period shall
include the period during which the highest opacity emissions
can reasonably be expected to occur.
−Reporting
 Test reports are required to be submitted to the Department
within 45 days of the test date.
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
Rule 62-297.310, F.A.C.
–
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 1December 31).
‣ DEP guidance memo DARM-OGG-18:
http://www.dep.state.fl.us/air/rules/guidance/ogg18.pdf
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 Relocation requires notification to the Department
by telephone, e-mail, fax, or written
communication at least one business day prior to
moving and transmit by e-mail, fax, post or
courier, a Facility Relocation Notification Form no
later than five business days following relocation.
 Relocation Notification Form located online at:
http://www.dep.state.fl.us/air/rules/forms/relocation.htm
33

A crusher using a general permit may be located
with other facilities that separately registered for,
and are also using, the NMMP plant air general
permit, and with facilities using the concrete batch
plant air general permit, even if under the control
of different persons as long as the following
conditions are met.
 The following types of units and activities may
collocate
◦
◦
◦
◦
Concrete batching plants using air general permits
NMMP plants using air general permits
NMMP plants exempt from permitting
Other emission units and pollutant-emitting activities
exempt from permitting
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
Site-wide fuel usage limitations apply to the
collocation site.
◦ Total fuel consumption limits applied to the collocation
site*:





23,000 gallons per year of gasoline
275,000 gallons per year of diesel
1.3 million gallons per year of propane
44 million standard cubic feet per year of natural gas
An equivalent prorated amount if multiple fuels are used
*Site: One or more contiguous or adjacent properties under control of
the same person (or persons under common control). (Rule 62210.310(5)(e)1., F.A.C.)
35

Recordkeeping requirements
◦ The owners or operators of all collocated concrete batching
plants and NMMP plants shall maintain records to account
for site-wide fuel consumption for each calendar month
and each consecutive twelve months. The owners or
operators shall retain these records, available for
Department inspection, for at least five years.
36

Non-routine use at facilities with air construction
or air operation permits is allowed as long as the
following conditions are met:
◦ The NMMP plant must not be located at a single site for
more than six months in any consecutive 12 months
◦ Records must be kept that indicate how long the NMMP
plant has been at the permitted facility
◦ No NMMP plant using an air general permit shall perform a
routine task at a permitted facility unless the NMMP plant
operation is authorized by the permitted facility’s AC or AO
permit. RAP crushing at an asphalt plant is considered a
routine task.
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38
Proposed Effective Date in State Rules is
October 16, 2009
•NMMP NSPS applies to affected facilities for which
construction, modification, or reconstruction commenced
on or after August 31, 1983.
•These final amendments include revisions for affected
facilities for which construction, modification, or
reconstruction commenced on or after April 22, 2008.
39
Monitoring Requirement
Initial Testing Requirements for Fugitive Emissions
Fugitive Emission Limits
Initial Testing Notification Requirements
Recordkeeping and Report Requirements
40
NAICS Code
Industry
2123
Nonmetallic Mineral Mining and Quarrying
2211
Electric Power Generation, Transmission and
Distribution
3241
Petroleum and Coal Products Manufacturing
3271
Clay Product and Refractory Manufacturing
3273
Cement and Concrete Product Manufacturing
3274
Lime and Gypsum (natural and synthetic) Product
Manufacturing
3279
Other Nonmetallic Mineral Product Manufacturing
(Ground or Treated Mineral and Earth Manufacturing)
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§ 60.674 Monitoring of operations.
(b) If a wet suppression system is used to
control emissions, facility must perform
monthly periodic inspections to check that
water is flowing to discharge spray nozzles
in the wet suppression system.
*Note: Only facilities constructed, modified, or reconstructed
on or after April 22, 2008.
42
§ 60.675 Test methods and procedures.
From
To
(c)(3) When determining compliance with the fugitive
emissions standard, the duration of the Method 9
observations may be reduced from 3 hours (thirty 6minute averages) to 1 hour (ten 6-minute averages) if
no individual readings are > 10 percent and there are
no more than three readings of 10 percent for the 1hour period.
(c)(4) Deleted (crushers w/o capture systems)
(c)(3) When determining compliance with the fugitive
emissions standard, the duration of the Method 9 (40
CFR part 60, Appendix A–4) observations must be 30
minutes (five 6-minute averages).
*Note: For all facilities subject to Subpart OOO.
43
§ 60.675 Test methods and procedures.
(e)(2) A single visible emission observer may conduct
visible emission observations for up to three fugitive,
stack, or vent emission points within a 15-second
interval if the following conditions are met:
(i) No more than three emission points read concurrently
(ii) All three emission points must be w/i a 70 degree viewing
angle in front of the observer such that the proper sun position
can be maintained for all three points.
(iii) If opacity reading for any one of the three points is 
the applicable standard, then the observer must stop taking
readings from the other two points and continue reading
just the single point.
*Note: For all facilities subject to Subpart OOO.
44
TABLE 3 TO SUBPART OOO—FUGITIVE EMISSION LIMITS
For * * *
The owner or operator must
meet the following fugitive
emissions limit for grinding
mills, screening operations,
bucket elevators, transfer
points on belt conveyors,
bagging operations, storage
bins, enclosed truck or railcar
loading stations or from any
other affected facility (as
defined in §§ 60.670 and
60.671) * *
The owner or operator must
meet the following fugitive
emissions limit for crushers at
which a capture system is not
used * * *
The owner or operator must
demonstrate compliance with
these limits by conducting * *
*
Affected facilities (as defined
in §§ 60.670 and 60.671) that
commenced construction,
modification, or
reconstruction after
August 31, 1983 but before
April
22, 2008.
10 percent opacity
15 percent opacity
An initial performance test
according to § 60.11 of this
part and 60.675 of this
subpart.
Affected facilities (as defined
in §§ 60.670 and 60.671)
that commence construction,
modification, or
reconstruction on or after
April 22, 2008.
7 percent opacity
12 percent opacity
An initial performance test
according to § 60.11 of this
part and §60.675 of this
subpart; and
Periodic inspections of water
sprays according to §
60.674(b) and
§ 60.676(b); and
A repeat performance test
according to § 60.11 of this
part and § 60.675 of this
subpart within 5 years from
the previous performance test
for fugitive emissions from
affected facilities without
water sprays. Affected
45
facilities controlled by water
§ 60.675 Test methods and procedures.
From
To
(g) If after 30 days notice for an initial scheduled
performance test, there is a delay in conducting any
rescheduled performance test required in this section,
the owner or operator of an affected facility shall submit
a notice to the Administrator at least 7 days prior to any
rescheduled test.
(g) For performance tests involving only Method 9 (40
CFR part 60 Appendix A–4) testing, the owner or
operator may reduce the 30-day advance notification of
performance test in §60.7(a)(6) and 60.8(d) to a 7-day
advance notification.
*Note: State Rule 62-297.310(7)(a)9,F.A.C.,requires a 15-day
advance notification.
46
§ 60.675 Test methods and procedures.
(i) If the initial performance test date for an
affected facility falls during a seasonal shut
down* of the affected facility, then with
approval from the permitting authority, the
owner or operator may postpone the initial
performance test until no later than 60
calendar days after resuming operation of
the affected facility.
* Seasonal shut down means shut down of an affected
facility for a period of at least 45 consecutive days
due to weather or seasonal market conditions.
47
§ 60.676 Reporting and recordkeeping.
(b)(1)
Record
each
monthly
periodic
inspection required under §60.674(b) or (c),
including dates and any corrective actions
taken, in a logbook (in written or electronic
format). The owner or operator must keep
the logbook onsite and make hard or
electronic copies (whichever is requested) of
the logbook available to the Administrator
upon request.
*Note: Only facilities constructed, modified, or reconstructed on
or after April 22, 2008.
48
§ 60.676 Reporting and recordkeeping.
From
To
(h) The subpart A requirement under § 60.7 (a)(2)
for notification of the anticipated date of initial
startup of an affected facility shall be waived for
owners or operators of affected facilities regulated
under this subpart.
(h) The subpart A requirement under § 60.7 (a)(1)
for notification of the date construction or
reconstruction commenced is waived for affected
facilities under this subpart.
49
§ 60.676 Reporting and recordkeeping.
(k) Notifications and reports required under
this subpart and under subpart A of this part
to demonstrate compliance with this subpart
need only to be sent to the EPA Region or the
State which has been delegated authority
according to § 60.4(b).
50
New Format for Asphalt Plant Permits
•RAP Crushing System Specific Conditions
51
52
Rule 62-701.200, F.A.C. – Definitions
Rule 62-701.300, F.A.C. - Prohibitions
Rule 62-701.220(2)(d), F.A.C.
Industrial by-products – solid waste permit not required
Majority must be sold, used or reused within 1 year
Cannot be hazardous wastes
Must be managed in such a way that Department air or water quality
standards or criteria are NOT violated
Rule 62-701.710, F.A.C.
Waste processing facilities – solid waste permit required
Engineering drawings, site plans, operation plan, calculations, etc.
53
Asphalt road base & concrete
crushing operations
54
Asphalt road base & concrete
crushing operations
55
Asphalt road base & concrete crushing operations
Generally meet definition of industrial by-products
if BMPs are followed

no solid waste permit required
BMPs need to include:
Only clean concrete and asphalt road base material is received
Residues from processing (incidental plastic, wood, metal) must
be containerized and removed at least weekly for offsite disposal
56
Waste processing
facility
Solid waste
permit required
57
Waste processing
facility
Solid waste
permit required
58
Waste processing
facility
Solid waste
permit required
59
60