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Title: UPDATE ON THE ASAE PROPOSED STANDARD X-578: COTTON GINS - METHOD OF UTILIZING EMISSION FACTORS IN DETERMINING EMISSION PARAMETERS

Author
item Buser, Michael
item PARNELL JR, CALVIN - TEXAS A&M UNIVERSITY
item SHAW, BRYAN - TEXAS A&M UNIVERSITY
item NORMAN, BILL - NATIONAL COTTON COUNCIL

Submitted to: National Cotton Council Beltwide Cotton Conference
Publication Type: Proceedings
Publication Acceptance Date: 1/9/2001
Publication Date: 6/1/2001
Citation: Buser, M.D., Parnell Jr, C.B., Shaw, B.W., Norman, B. 2001. Update on the ASAE proposed standard x-578: cotton gins - method of utilizing emission factors in determining emission parameters. National Cotton Council Beltwide Cotton Conference. Vol. 2: 1330-1340.

Interpretive Summary: State Air Pollution Regulatory Agencies (SAPRA) establish regulations to control the air pollution associated with cotton gins. The primary regulated pollutant emitted by cotton gins is particulate matter (PM) less than 10 micrometers aerodynamic equivalent diameter (AED), referred to as PM10. In some states, emissions of total suspended particulate matter (TSP) are regulated. The results of a permit engineer's analysis are incorporated into a permit so the facility may operate. The permit approved by the SAPRA permit engineer specifies the allowable emission rate for the facility. Consulting engineers, working with cotton ginners and permit engineers, must develop air pollution abatement systems that comply with SAPRA regulations while minimizing costs. Published technical guidance is not readily available to guide development of regulatory standards or to evaluate specific ginning systems. As a result, numerous reports of unfair regulatory actions due to a lack of understanding of how to properly utilize cotton gin emission factors have surfaced. Thus, a proposed engineering practice standard was developed to define the operations of a cotton gin with engineering data and guidance that can be used by both consulting and permit engineers such that cotton gins are fairly and appropriately regulated. The proposed standard will aid permit and consulting engineers in calculating various air pollution parameters for cotton gins. Further, these procedures could be utilized by consultants when responding to notice of violations, recommending modifications to existing ambient air pollution control systems, or designing and developing new air pollution abatement systems in order to comply with SAPRA regulations.

Technical Abstract: State air pollution regulatory agency (SAPRA) permit engineers, consulting engineers, and other specialists are required to perform in-depth analyses of cotton gin emissions. This analysis may include calculations of emission rates and concentrations of all point sources using emission factors. The primary regulated pollutant emitted by cotton gins is particulate matter (PM) less than 10 micrometers aerodynamic equivalent diameter (AED), referred to as PM10. In some states, emissions of total suspended particulate matter (TSP) are regulated. The results of a permit engineer's analyses are incorporated into a permit so the facility may operate. The permit approved by the SAPRA permit engineer specifies the allowable emission rate for the facility. Consulting engineers, working with cotton ginners and permit engineers, must develop air pollution abatement systems that comply with SAPRA regulations while minimizing cost. A proposed engineering practice standard was developed to define the operations of a cotton gin with engineering data that can be used by both consulting and permit engineers such that cotton gins are fairly and appropriately regulated. This standard provides a basis for involved parties to address the issues from a common platform.