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United States Department of Agriculture

Agricultural Research Service

Research Project: AIR QUALITY ISSUES RELATED TO AGRICULTURAL OPERATIONS AND PROCESSES Title: Cotton Gin Yard and Road Dust Emissions and the Resulting Effects on Downwind Samplers

Authors
item Hamm, L - TEXAS A&M UNIVERSITY
item Buser, Michael
item Capareda, S - TEXAS A&M UNIVERSITY
item Wanjura, J - TEXAS A&M UNIVERSITY
item Parnell, JR., C - TEXAS A&M UNIVERSITY
item Shaw, B - TEXAS A&M UNIVERSITY

Submitted to: National Cotton Council Beltwide Cotton Conference
Publication Type: Proceedings
Publication Acceptance Date: January 5, 2005
Publication Date: June 20, 2005
Citation: Hamm, L.B., Buser, M.D., Capareda, S.C., Wanjura, J.D., Parnell, Jr., C.B., Shaw, B.W. 2005. Cotton gin yard and road dust emissions and the resulting effects on downwind samplers. In: Proceedings of the Beltwide Cotton Conference, January 4-7, 2005, New Orleans, Louisiana. p. 602-613. 2005 CDROM.

Interpretive Summary: The US Environmental Protection Agency (EPA), under authority granted by the Federal Clean Air Act, delegates the responsibility of regulating and enforcing ambient air quality standards to the states. States are required by EPA to submit state implementation plans (SIP) detailing how a state will implement and enforce regulatory actions to ensure that the National Ambient Air Quality Standards (NAAQS) are achieved. State regulatory agencies use permits to set the allowable emission rates for individual pollutants being emitted from individual facilities so that the facilities' emissions do not negatively impact a region's ambient air quality. State agencies have available tools that can be used to determine whether or not to issue a facility a permit or if a facility is in violation of its existing permit. For example, some states use dispersion modeling or property line sampling. The primary regulated pollutant being emitted from cotton gins is particulate matter (PM) less than 10 microns in diameter. When states use dispersion modeling or property line sampling to determine if a cotton gin is in compliance with its permit, they should acknowledge that there are two sources of PM: 1) the gin's exhaust systems, and 2) fugitive emissions from the gin yard and/or roads located on the facility's property. Fugitive emissions are not generally included in a facility's permit unless the facility is considered a major source. Currently, no cotton gins meet the Title V major source threshold, so a gin's fugitive emissions should not be included in dispersion modeling runs, and property line sampling concentrations should be adjusted to remove the effects of fugitive emissions. This manuscript explores the potential impacts of including fugitive emissions in determining whether or not a gin is in compliance with its permit. The EPA-approved dispersion model, Industrial Source Complex Short Term Version 3, was used in the simulations. Results from the simulations indicated that the average contribution of the uncontrolled gin yard and road emissions could be as high as 35%. Although these simulations are based on EPA AP-42 emission factors and not actual field data, the simulations demonstrate the importance of including only relevant emissions in modeling and knowing the sources that can impact property line sampling concentrations and appropriately accounting for these non-regulated sources of PM.

Technical Abstract: The US Environmental Protection Agency (EPA), under authority granted by the federal Clean Air Act, delegates the responsibility of regulating and enforcing ambient air quality standards to the states. States are required by EPA to submit state implementation plans (SIP) detailing how a state will implement and enforce regulatory actions to ensure that the National Ambient Air Quality Standards (NAAQS) are achieved. State regulatory agencies use permits to set the allowable emission rates for individual pollutants being emitted from individual facilities so that the facilities' emissions do not negatively impact a region's ambient air quality. Some state agencies have used property line sampling or dispersion modeling as tools in determining whether or not to issue a facility a permit or to determine if a facility is in violation of its permit. For cotton ginning facilities, the primary regulated pollutant is particulate matter (PM) less than 10 microns in diameter. When dispersion modeling or property line sampling is used to determine if a cotton gin is in compliance with its allowable emission rate, it is important to recognize that there are two sources of PM: 1) the gin's exhaust systems, and 2) fugitive emissions from the gin yard and/or roads within the facilities' property boundaries. Fugitive emissions are not generally included in a facility's permit unless the facility is considered a major source. Currently, no cotton gins meet the Title V major source threshold, so a gin's fugitive emissions should not be included in dispersion modeling runs and property line sampling concentrations should be adjusted to remove the effects of fugitive emissions. This manuscript explores the potential impacts of including fugitive emissions in determining whether or not a gin is in compliance with its permit. The EPA-approved Gaussian-based model, Industrial Source Complex Short Term Version 3 (ISCST3), was used in the simulations. Results from the simulations indicated that the average contribution of the uncontrolled gin yard and road emissions could be as high as 35%. Although these simulations are based on EPA AP-42 emission factors and not actual field data, the simulations demonstrate the importance of including only relevant emissions in modeling, knowing the sources that can impact property line sampling concentrations, and appropriately accounting for these non-regulated sources of PM.

Last Modified: 10/22/2014
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