Dry Bulk Fertilizer Handling Facilities
January 1997

TNRCC Rule 116.111(3) in Regulation VI requires that Best Available Control Technology
(BACT) be applied to all facilities that must obtain a permit.  BACT determinations are made on
a case-by-case basis. 

What are the minimum controls that need to be considered and may be required to satisfy
BACT requirements for applications with rural, isolated, locations (low nuisance
potential)?

þ    Enclosed conveying and mixing/handling.
þ    Use of "choke feeding" for receiving operations.
þ    Use of fabric filters (or equivalent) on all fan discharges; this include points where there
     is pneumatic receiving or loadout of fertilizer.
þ    Manufacturer's guarantee for outlet grain loading rates on all fabric filters.  Usual outlet
     grain loading rates range from 0.005 gr/dscf to 0.01 gr/dscf.
þ    Loadout spouts equipped with drop socks that extend inside the vehicle being loaded.
þ    Proper maintenance of all abatement devices, duct work, and in-plant roads.
þ    Daily removal of any spillage of raw or finished product and waste material.

What additional controls should be considered and may be required for facilities in tighter
locations with nearby residences, businesses, schools, etc. (high nuisance potential)?

þ    Enclosed receiving and loadout areas.
þ    Application of vegetable or mineral oil during receiving operations.
þ    Use of a dust collection system and bagfilter on areas such as receiving pits, elevator legs,
     and loadout points.
þ    Use of surge bins to minimize dust generated during loadout.
þ    Paved and cleaned or dust suppressant treated parking lot and traffic areas.

In summary, any changes or additions that are thought to be insignificant and appear that no
permit requirements are necessary should be proposed to the TNRCC for review or comments. 
Permit processing time can be greatly reduced by:

  1)  choosing an isolated location; and 
  2)  submitting a well prepared application with a completed PI-1 or PI-1R form.  Refer to
      document entitled "Supplemental Information Sheet for Bulk Fertilizer Handling
      Applications" for more details concerning application information; and 
  3)  proposing controls that meet all BACT and Regulation I requirements.  Proposals for
      anything less should be well justified; and
  4)  sending the original application to the Austin Office, one copy of the application to the
      appropriate regional office, one copy to any appropriate local programs, and keeping
      one copy.

Activities which require public notice should be planned well in advance to allow for a permit
processing time of around 90 days.  Public involvement such as public meetings and/or public
hearings could greatly increase the processing time.