|Hughs, Sidney - Hughs Ed|
Submitted to: National Cotton Council Beltwide Cotton Conference
Publication Type: Proceedings
Publication Acceptance Date: 1/9/2001
Publication Date: 6/1/2001
Citation: Interpretive Summary: The above discussion in the paper is an attempt to raise issues and suggest possible means to address the permitting of cotton gins based on sound science. This discussion is probably only going to have application in those states/regions where methods of permitting cotton gins are still being developed. A very brief example of what a possible general operating gpermit might include was given as a starting reference. In addition to th emission factors as published in AP-42 (EPA, 1996), other methods that are used by the various states in their efforts to implement safeguards and compliance verification tools into their permits were also given. The pros and cons of these additional methods have been discussed. It should also be pointed out that the application of these additional methods varies from agency to agency. It is up to the individual state/region and their own regulated ginning industry to determine which of these additional tools, if fany, are most useful for their particular regulatory situation. The goal still remains to make the permitting of cotton gins be based on sound science, more streamlined and more uniform across the U. S. cotton belt, and to remove some of the current uncertainty as to the status of individual cotton gins within the regulatory framework.
Technical Abstract: The 1990 Federal Clean Air Act (CAA) has set forth requirements for Federal operating permits (Title V) for particulate matter (PM). Currently, most cotton belt states/air districts have final approval of their Federal operating permit program as required by the CAA. As a result, the permitting of existing gins is ongoing in many parts of the cotton belt. Cotton gin permitting requirements, as currently being developed, vary widely between states/air districts across the cotton belt. This paper was written as an attempt to address the issue of permitting gins in a more uniform fashion across the cotton belt. Very conservative Federal guidance has recognized that most gins are minor sources of PM. This guidance recognizes that relatively simple sources of PM, such as gins, can probably be permitted in states/air districts by using a general permit to cover the industry. Two methods of permit limit verification, modeling and process weight limits, are generally unsatisfactory when applied to cotton gins. Other methods, such as opacity or specified equipment, poses fewer problems of application when used in a general rule, and are discussed in the paper. The authors are aware that the options discussed may not be feasible for a given state/air district.