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

General Amendments to R. 61-62 

July 18, 2011 

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Revisions 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 Regulation Pursuant to Section 110(1)

In 1983, the South Carolina Department of Health and Environmental Control (Department) promulgated a rule to 

establish specific emission rates for cotton ginning operations in the state. For several decades, cotton ginning 

operations have been subject to this rule (S.C. Regulation 61-62.5, Standard 4, Emissions from Process Industries)

which specified that facility’s operations are limited to an allowable pound per hour emission rate that is based upon 

the total bales of cotton produced. However, the rule itself does not specify that controls be in place at any point in 

the process or that any monitoring or gin-yard “housekeeping” take place. 

When Department permit engineers made reviews for the renewal or construction process, compliance with the 

process rate curve was based on applying the emission factors which are generic to the industry, are not source 

specific, and cannot be tailored to be source specific. Then in 1996, the EPA issued revised emission factors for 

cotton ginning operations. Since the new factors were 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 to develop a revised rule to resolve this dilemma. As part of the 

process, regulation of particulate emissions from cotton ginning operations in other states was reviewed. Some 

states use a process weight rate based allowable similar to the miscellaneous particulate rule that currently applies 

in South Carolina. Others (North Carolina, for instance) have more recently established specific control equipment 

and work practice based rules. 

The proposed rule before you today was developed based on best mangement practices outlined in the USDA’s 

“Cotton Ginners Handbook,” staff experience with effective emission reduction techniques, the review of other 

states regulation of cotton gins, and several discussions with the affected industry. The new proposed state rule 

imposes specific, measurable performance requirements and operating standards. This assures a greater degree of 

control of these emissions than that which would result from the existing process weight rate curve and also allows 

the state to more effectively determine compliance. The proposed revisions will require enforcable control of 

emissions from specific point sources in the ginning process rather than establishing an allowable emission rate. 

This rule establishes requirements to minimize fugitive emissions from various sources at cotton ginning facilities 

that were not previously covered by any of the aforementioned particulate rules. In addition to the control 

requirements and emissions minimization techniques, this rule incorporates associated requirements for good 

housekeeping practices in the gin yard, weekly monitoring of control efficiency, recordkeeping, and reporting 

when necessary. This proposed rule incorporates a combination of measures that have previously been 

implemented at ginning operations as a means of complying with the current particulate rule, as well as many 

measures considered state of the art for this industry. 

This rule also makes use of a state specific streamlined permit process (Regulation 61-62.1, Section II (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 since cotton gins have been acknowledged by the EPA as one of 

eight specific source categories which fall into the “minor source” designation as noted in previous NSR guidance 

memos1

. The use of registration permits will greatly reduce the burden on Department staff and cotton ginning 

facilities in a time where resources are limited. 

The Department concludes that this new controls-based 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 air quality in many areas throughout the state. 

 

1 Potential to Emit (PTE) Guidance for Specific Source Categories, published by the EPA on April 14, 1998. This memorandum 

provides guidance for addressing the minor source status under the Clean Air Act (Act) for lower-emitting sources in eight source 

categories.