Revisions to the South Carolina Air Implementation Plan 110(l) – Page 1

General Amendments to R. 61-62 July 18, 2011 

# Attachment 4

110(l) DemonstrationRevisions to the South Carolina Air Implementation Plan 110(l) – Page 2

General Amendments to R. 61-62 July 18, 2011 

### This Page Intentionally Left BlankRevisions to the South Carolina Air Implementation Plan 110(l) – Page 3

General Amendments to R. 61-62 July 18, 2011 

### Review of Stringency of Proposed Cotton Ginning Reg ulation Pursuant to Section 110(1)

In 1983, the South Carolina Department of Health an d Environmental Control (Department) promulgated a rule to establish specific emission rates for cotton ginnin g operations in the state. For several decades, cot ton ginning operations have been subject to this rule (S.C. Reg ulation 61-62.5, Standard 4, Emissions from Process Industries) which specified that facility’s operations are limi ted to an allowable pound per hour emission rate th at is based upon the total bales of cotton produced. However, the ru le itself does not specify that controls be in plac e at any point in the process or that any monitoring or gin-yard “hou sekeeping” take place.

When Department permit engineers made reviews for t he renewal or construction process, compliance with the process rate curve was based on applying the emissi on factors which are generic to the industry, are n ot source specific, and cannot be tailored to be source speci fic. Then in 1996, the EPA issued revised emission factors for cotton ginning operations. Since the new factors we re higher than the previously used ones, there was no specified means for these sources to show compliance with the process weight rate curve, regardless of how clean they were operating, except through expensive testing.

As a result, the Department has began the process t o develop a revised rule to resolve this dilemma. A s part of the process, regulation of particulate emissions from c otton ginning operations in other states was review ed. Some states use a process weight rate based allowable si milar to the miscellaneous particulate rule that cu rrently applies in South Carolina. Others (North Carolina, for inst ance) have more recently established specific contr ol equipment and work practice based rules.

The proposed rule before you today was developed ba sed on best mangement practices outlined in the USD A’s

“ Cotton Ginners Handbook ,” staff experience with effective emission reducti on techniques, the review of other states regulation of cotton gins, and several discu ssions with the affected industry. The new proposed state rule imposes specific, measurable performance requiremen ts and operating standards. This assures a greater degree of

control of these emissions than that which would re sult from the existing process weight rate curve an d also allows the state to more effectively determine compliance. The proposed revisions will require enforcable con trol of emissions from specific point sources in the ginnin g process rather than establishing an allowable emi ssion rate. This rule establishes requirements to minimize fugi tive emissions from various sources at cotton ginni ng facilities that were not previously covered by any of the afor ementioned particulate rules. In addition to the co ntrol requirements and emissions minimization techniques, this rule incorporates associated requirements for good housekeeping practices in the gin yard, weekly moni toring of control efficiency, recordkeeping, and re porting when necessary. This proposed rule incorporates a c ombination of measures that have previously been implemented at ginning operations as a means of com plying with the current particulate rule, as well a s many measures considered state of the art for this indus try.

This rule also makes use of a state specific stream lined permit process (Regulation 61-62.1, Section I I (I)) that allows for a “registration permit” applicable to an entire industry whose operations are similar. The Department finds the use of registration permits appropriate s ince cotton gins have been acknowledged by the EPA as one of eight specific source categories which fall into th e “minor source” designation as noted in previous N SR guidance

memos 1 . The use of registration permits will greatly redu ce the burden on Department staff and cotton ginnin g facilities in a time where resources are limited.

The Department concludes that this new controls-bas ed regulation will be more stringent than previous rules and will provide for enforceable control of emissions, use of state of the art pollution control devices, and minimization of fugitive emissions that will lead to improved ai r quality in many areas throughout the state.

1 Potential to Emit (PTE) Guidance for Specific Sourc e Categories , published by the EPA on April 14, 1998. This memo randum provides guidance for addressing the minor source s tatus under the Clean Air Act (Act) for lower-emitt ing sources in eight source categories.