Gila River Indian Community (GRIC) TIP Development 

Source Specific Emission Limitations & Standards 

Technical Support Document 

Rule AX-Cotton Ginning and Cotton Seed Processing 

1.0 Introduction & Source ~escri~tion'~'~' 

Information for these processes are based on Chapter 9.7 of EPA's Compilation of Air Pollutant 

Emission Factors AP-42, 5th Edition, and information gleaned during site visits. Cotton is a 

natural fiber crop, the fibers (lint) grow from and are attached to the surface of the seeds, which 

are located inside a capsule or boll. When mature, the bolls open, exposing the fiber and seed. 

Raw cotton, called "seed cotton" is then harvested by machine from the fields. The series of 

mechanical processes for cleaning the seed cotton, separating the fibers from the seeds, and 

baling the lint cotton is called ginning. The seeds are then processed to remove the remaining 

lint in order to prepare them for planting the following year. 

Cotton ginning and seed processing are seasonal. Cotton ginning begins with the maturing of the 

cotton crop and ends when the crop is finished. Most of the cotton in the United States is ginned 

between October and December. The bulk of the crop fiom each geographical region is ginned 

in 6 to 8 weeks. Seed processing usually occurs from October to March. During the remainder 

of the year, the gin and seed processing equipment are idle. 

1.1 Cotton Ginning 

Two types of machines are used to harvest cotton in the U.S.: pickers and strippers. Machinepicked cotton normally accounts for 70 to 80 percent of the total cotton harvested, and machinestripped cotton normally accounts for the remaining. Machine picking differs from machine 

stripping mainly in the method by which the seed cotton is removed from the plant. The spindle 

picker machine selectively separates the exposed seed cotton from the open bolls or capsules 

while the mechanical stripper removes the entire capsule with seed cotton plus bract, leaf, and 

stem components in the harvested material. Strippers collect up to six times more leaves, burs, 

sticks, and trash than the spindle picker machines. The higher ratio of trash to cotton resulting 

fiom machine-stripping requires gins to have additional equipment for cleaning and trash 

extraction. 

Typically, modem cotton gins produce 10 to 60 480-lb baleshow and 1,000 to 80,000 

baleslseason. Cotton gins can remove 90 to 99 percent of the trash and all of the seed from the 

lint. A typical cotton ginning facility is divided into five processing areas: unloading system; 

seed cotton drying and cleaning system; overflow system; ginning and lint cleaning system; and 

battery condenser and baling system. A flow diagram is included in Appendix A that shows 

these processing areas. The first three stages are usually referred to as the high pressure side of 

the plant, while the last two (lint cleaning through baling) are called the low pressure side, 

reflecting the pressures used in the air conveying systems. 

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1.2 Seed Processing 

These facilities process the cotton seeds for sale in the agricultural market. Seeds are de-linted, 

refined, chemically treated, color coated, and bagged. Seeds may be de-linted by burning andor 

the use of sulfuric acid. Ammonia is used to neutralize the waste sulfuric acid. A generalized 

process diagram for cotton seed processing (using lint burning and sulfuric acid) is included in 

Appendix A of this document. 

2.0 GRIC Source Profile 

One cotton gin, the Gila River Cotton Gin, currently operates on GRIC land and is owned by the 

Community. Two seed processing facilities are located and operating on GRIC land. They are 

the Stoneville Seed Company and Arizona Processing. 

The Gila River Cotton Gin is located in Pinal County, The majority of the cotton is harvested 

using a machine picker. The remaining cotton left hanging on the plants and the cotton that falls 

to the ground is harvested using a ruud machine, this yields cotton with more trash than that 

which is machine-picked. Two natural gas-fired generators are used for the dryer, and there are 

two stands for cleaning the seed from the seed cotton and a stick cleaner for removing trash, 

which is exhausted to cyclones. Two lint cleaners are used to clean the cotton and they are also 

exhausted to cyclones. The cleaned lint is then fed to the baling system. The trash from the gin 

is collected in overhead bins and then dropped into trailers. The trash is hauled off-site and used 

for either animal bedding or low-grade feed. The seeds are transmitted to a seed cleaning facility 

for further processing. 

Stoneville Seed Company is located adjacent to the Gila River Cotton Gin and operates from 

October to March on a 12-hrlday schedule. A gas-fired flamer is used to burn the lint off the 

seeds. This unit is equipped with a thermal oxidizer to control smoke emissions. Seeds are 

further de-linted using a sulfuric acid bath (10%). Two rotary kilns are used to dry the seeds 

after the acid bath. Ammonia is used to neutralize the sulfuric acid. Refining includes a series of 

shakers, classifiers, and cleaners. The facility is equipped with high efficiency cyclones. After 

refining, the seeds are treated with insecticide and fungicide, color coated, and packaged. Trash 

from the seed refining is conveyed to a cyclone and collection bin. 

Arizona Processing is also a cotton seed processing facility, however it is located in Maricopa 

County. The process is similar to the Stoneville Seed Company, although there is no lint burning 

operation, rather a longer residence time in the acid bath is used to remove the lint. The facility 

is equipped with high efficiency cyclones. 

This regulation will apply to the Gila River Cotton Gin, Stoneville Seed Company, and Arizona 

Processing, and to any future cotton gins or cotton seed processing facilities. This regulation 

will also be applicable to modifications made at the existing facilities, thus applicable 

requirements will need to be reevaluated if a source is modified. 

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3.0 Technical Review - Emission Units, Pollutants, and Control ~echnolo~ies',~,~ 

3.1 Emissions and Controls 

Emissions from cotton ginning and seed processing consist primarily of particulate matter (PM) 

and particulate matter less than 10 micrometers (PMlo) in aerodynamic diameter. According to 

the section on cotton ginning in EPA's AP-42, about 37% of the total PM emissions from cotton 

ginning is PMlo. Also, particulate emissions are generally higher at cotton gins processing 

stripper-harvested cotton and are lower from the first cotton harvest. Before being vented to the 

atmosphere, exhaust from each step is typically routed through a control device. 

Control devices used at cotton gins include cyclones, fine mesh screens, and perforated metal 

drums. Generally, cyclones have been used on high pressure exhausts, while screens and drums 

have been used on low pressure exhausts. Although cyclones can be used on either high or low 

pressure exhausts. Cyclones are also used to control particulate emissions at seed processing 

plants. Also, if lint burning is conducted, the flamer may be equipped with a thermal oxidizer. 

There are two configurations for high efficiency cyclones, 2D-2D and 1D-3D, which refer to the 

ratio of the cylinder length to the cone length @ refers to the diameter). Thus, a 1D-3D cyclone 

would have a cylinder length equal to the diameter and a cone length equal to 3 times the 

diameter. Typically, 1D-3D cyclones have slightly higher collection efficiencies. 

3.2 Emission UnitPollutant Matrix 

Emission units and pollutants associated with cotton ginning and seed processing, as defined in 

this document, are presented in Table 3-1. This matrix is based on available EPA literature on 

source category emissions and emission factors, as well as knowledge from the site visits. 

Table 3 - 1. Emission UnitPollutant Matrix 

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Source Subcategory 

Cotton Ginning 

Seed Processing 

Emission Unit1 Process 

Unloading fan 

Dryers and Cleaners 

Overflow fan 

Lint Cleaners 

Cyclone robber system 

Motelmote trash fan 

Battery condenser 

Master trash fan 

Flamer 

Rotary kiln dryers 

Refining - classifiers, screens 

Seed cleaner 

Seed packaging 

PollutantIParameter 

Opacity, PWM 1 0 

Opacity, PWM10, minimal products of 

combustion 

Opacity, PWM 10 

Opacity, PIWPM10 

Opacity, PWM 10 

Opacity, PWM10 

Opacity, PWM 10 

Opacity, PWM 10 

Opacity, PIWPM 10 

Opacity, PWMIO, minimal products of 

combustion 

Opacity, PWM 10 

Opacity, PWM 10 

Opacity, PWM 10 
4.0 Regulatory Review 

4.1 Tribal ProgramsRules 

A comprehensive review of U.S. tribal air quality programs was performed to define the baseline 

of existing tribal rules and source specific standards. The summary findings of this review are 

contained in a separate report. Where tribal rules and standards were identified that were 

applicable to GRIC source categories or met GRIC regulatory objectives, those provisions and 

requirements are detailed herein. 

No tribal programs or rules were identified that specifically pertain to the cotton gin and cotton 

seed processing source category. 

4.2 Federal Programs and Regulations 

4.2.1 New Source Performance Standards (NSPS) 

There is no NSPS applicable to cotton gins or cotton seed processing. 

4.2.2 National Emission Standards for Hazardous Air Pollutants (NESHAP)/ 

Maximum Achievable Control Technology (MACT) Standards 

There is no NESHAPMACT applicable to cotton gins or cotton seed processing. 

4.2.3 Reasonably Available Control Technology (RACT)Best Available 

Control Technology (BACT)ILowest Achievable Emission Rate (LAER) 

Clearinghouse 

An EPA RACTIBACTILAER Clearinghouse (RBLC) search for entries after 1990 was 

conducted for the following source category: 

70.006: Cotton Ginning 

Table 4-1 presents a summary of RBLC entries relevant to the cotton ginning source category as 

defined in this document. 

4.2.4 Accidental Release Prevention [Sec. 1 12(r)] 

The only potentially subject material expected to be stored or processed at cotton gins and seed 

processing facilities is ammonia. If aqueous ammonia (at concentrations 20% or greater) is 

stored in quantities of 20,000 pounds or more, the facility would be subject to the EPA accidental 

release prevention rule (40 CFR Part 68). 

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Table 4- 1. RBLC Search Results Summary 

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4.2.5 Other 

No other federal air quality regulatory programs or standards were identified as applicable or 

potentially applicable to the cotton gin and cotton seed processing source category. 

4.2.6 Summary of Identified Federal Rules/Programs - Testing, Monitoring, 

Recordkeeping & Reporting Provisions 

No federal air quality regulatory programs or standards were identified, thus there are no federal 

testing, monitoring, recordkeeping, or reporting provisions. 

4.3 State/RegionaVLocal Regulations 

To define State, regional, and local air quality rules applicable to the source categories present or 

expected to potentially site on GRIC land, representative U.S. State air quality rules were 

screened using Internet resources. This screening identified each State air quality rule set with 

source specific regulations matching the matrix of GFUC source categories. The summary State 

rule screening file, STATEMATRIX.xls, is included in Appendix A of this document. From this, 

specific rule provisions applicable to the cotton gin and cotton seed processing source category, 

including emission limitations, standards, monitoring, recordkeeping and reporting, were 

documented to form a baseline of analogous State rules. 

4.3.1 Summary of Identified Rules - Emission Limitations & Standards 

This section presents a summary of existing State air quality rules applicable to the cotton gin 

and cotton seed processing source category as defined in this document. Six Statetlocal program 

standards were identified as relevant and of potential value in developing the GFUC emission 

limits and standards for this source category. The identified State rule provisions, including 

applicability and emission limits/standards are summarized in Table 4-2. 

Table 4-2. Summary State Rule Emission Limits and Standards 

Applicability 

Cotton Gin 

Operation 

Parameter 

Emissions 

Emission LimitJStandard (Units) 

Maximum allowable PM emissions based on 

process weight rates (per hour) are presented 

in a table. Range: 1.6 lbh for 1,000 lbh 

process weight rate to 67.4 lbh for >60,000 

lbh process weight 

Total process weight of all similar units 

employing a similar process type shall be 

used in determining maximum allowable PM 

emissions 

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Emission Limit/Standard (Units) 

Fugitive dust, lint, bolls, cotton seed, or other 

material emitted or lying loose in a yard shall 

be collected and disposed of in an efficient 

manner, or shall be treated in accordance with 

R18-2-604 through 607. 

NOTE: Rules 604-607 include general 

requirements for fugitive dust sources 

including open areas, dry washes, and 

riverbeds; roadways and streets; materials 

handling; and storage piles. Requirements are 

limited to "reasonable precautions" including 

chemical or wet suppression, covering, etc. 

Opacity 540% shall exempt source from mass 

emissions testing 

For process rates 530 tons per hour (tph): 

Maximum allowable PM emissions (lbh) 

(E) = 4.1 OPO.~~ 

For process rates >30 tph: 

Maximum allowable PM emissions (lbh) 

(E) = 55 .oP'.' ' - 40, 

Where: P = Process weight rate (tph) 

Total process weight of all similar units 

employing a similar process type shall be 

used in determining maximum allowable PM 

emissions 

For process rates: 

Maximum allowable PM emissions (lbh) 

(E) = 7 B'.' 

Where: B = Process weight rate (standard 

balesh, where a standard bale is a finished 

bale weighing 500 pounds) 

Pollutant/ 

Parameter 

PM: 

Fugitive 

Dust 

Visible 

Emissions 

PM 

Emissions 

PM 

Emissions 

State Rule 

Arizona 

R18-2-729 

Pinal 

County 

Chapter 5, 

Article 8 

Georgia 

Rule (q) 

Applicability 

Cotton Gins 

Cotton Gins 
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Emission LimiWtandard (Units) 

Opacity GO%, unless not more than one 6- 

minute period in any consecutive 60 minutes, 

not exceeding 3 in any consecutive 24 hours 

and 160%; an alternative opacity limit can be 

developed 

No cotton gin shall be operated as to cause or 

contribute to a violation of the PMlo ambient 

air quality standard (AAQS) or any other 

AAQS in 252: 100-3 

Low pressure exhausts: screens with a mesh 

size of 70 x 70 or finer (U.S. Sieve); 

perforated condenser drums with holes not 

exceeding 0.045 inches in diameter; or 

equipment of equivalent design 

High pressure exhausts: 2D-2D cyclones for 

existing gins, or 1 D-3D cyclone if the capital 

cost to repairlreplace an existing 2D-2D 

cyclone exceeds 50% of the capital wst of a 

new 1 D-3D cyclone); 1D-3D cyclone for 

newlmodified gins or equivalent 

Burr hopvers: For wntrol during dumping, if 

burr hoppers at existing gin are located within 

the corporate city limits of any city or within 

300 fi of 2 or more occupied establishments, 

they must be totally enclosed; total enclosures 

on burr hoppers at new gin sites 

Take reasonable precautions to minimize 

atmospheric pollution from handling, 

transporting, or disposition of any substance 

or material that is likely to be scattered by the 

air or wind, or operate or maintain any gin 

site, open area, right-of-way, storage pile or 

materials, vehicle, or construction, or any 

other enterprise which involves any material 

or substance likely to be scattered by the wind 

or air, that would be classified as air 

pollution; do not allow the discharge of any 

visible fugitive dust emissions beyond the 

property line 

Pollutant/ 

Parameter 

Visible 

Emissions 

PMIO 

Emissions 

PM 

Controls 

Fugitive 

dust 

State Rule 

Oklahoma 

Subchapter 

23 

Applicability 

New, Modified, 

and Existing 

Cotton Gins 
4.3.2 Summary of Identified Rules - Testing, Monitoring, Recordkeeping, & 

Reporting Provisions 

Presented in Table 4-3 is a summary of State rule monitoring, testing, recordkeeping, and 

reporting requirements. 

State Rule 

South 

Carolina §V 

Maricopa 

County Rule 

319 

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Pollutant/ 

Parameter 

PM 

Emissions 

Visible 

Emissions 

Visible 

Emissions 

PM 

Controls 

Applicability 

Cotton Gins 

Ginning 

Operations 

Emission LimitIStandard (Units) 

Maximum allowable PM emissions based on 

production rates are presented in a table. 

Range: 12.3 lbthr for 4 bales (lo) per hour 

production rate (output) to 3 1.2 lbh for 21 6 

bales (1 0) per hour production rate (output); 

a bale is a finished bale weighing 500 pounds 

Opacity 520% 

Opacity <20% 

Each unit fed by seed-cotton unloading, first 

seed-cotton cleaning and master trash systems - 

effective April 7,2001 be controlled by an 

emission control system (ECS) that includes a 

1 D-3D cyclone or equivalent device with at 

least 95% eficiency; the remaining high 

pressure exhaust emission units - no later than 

April 7,2004 be controlled by an ECS that 

includes a 1D-3D cyclone or equivalent device 

with at least 95% efficiency; all low pressure 

exhaust emission units - no later than April 7, 

2004 be controlled by an ECS that includes at 

least a 2D-2D cyclone or equivalent device with 

at least 90% efficiency; trash hopper dumping - 

dump trash into a hopper with an enclosure with 

a minimum of two sides to minimize fugitive 

emissions, the sides of the enclosure shall 

prevent wind dispersion by ensuring that the 

height of the enclosure extends above the 

opening of the dumping device, if an auger is 

used to transport trash the open end of the auger 

or auger sleeve shall be below the top of the 

enclosure 
Table 4-3. Summary of State Rule Monitoring, Testing, Recordkeeping, and Reporting 

Provisions. 

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Recordkeeping1 

Reporting Provisions 

N/A 

Maintain a log of the 

daily process weight, 

hours of operation, and 

air emission control 

equipment replacement/ 

repair costs 

Maintain for 2 years and 

make available for 

inspection by DEQ 

personnel during normal 

business hours 

Rule 

Arizona 

R18-2-729 

Pinal 

County 

Chapter 5, 

Article 8 

Oklahoma 

252: 100- 

23-3 

Applicability 

Test methods 

and 

procedures 

required by 

Section 

Cotton Gin 

Monitoring & Testing Provisions 

Reference methods in the Arizona 

Testing Manual and 40 CFR 60 

Appendix A, shall be used to 

determine compliance as follows: 

Method A-2 for measurement of PM 

Method 1 for sample and velocity 

traverses 

Method 2 for velocity and volumetric 

flow rate 

Method 3 for gas analysis 

Method 9 for visible emissions 

For Method A-2: Sampling time of at 

least 60 minutes. Minimum volume of 

0.53 dscflmin. (Alternate duration 

may be approved by Director if 

necessitated by process) 

Test methods: 

Method 9 in 40 CFR Part 60, 

Appendix A for visible emissions 

Dispersion modeling for PMlo shall be 

performed using an EPA approved 

modeling method 
4.4 Analysis of Source Category Emission Limitations and Standards 

4.4.1 Summary and Analysis of Identified RulesIStandards 

Recordkeeping1 

Reporting Provisions 

For each day of 

operation record the 

total hours when 

ginning operation 

conducted, number of 

bales of cotton 

produced, and total 

weight of all bales 

produced. 

Maintain records of the 

time when an approved 

ECS is used to comply 

with rule, operating 

parameters as in O&M 

Plan, accounting for 

periods when control 

system not operating, 

all maintenance 

performed according to 

the O&M Plan, and 

results daily visual 

inspections and any 

corrective actions 

Rule 

Maricopa 

County 

Rule 319 

In order to evaluate the range of existing tribal, federal, state, and local air quality standards 

relevant to the cotton gin and cotton seed processing source category and make GRIC TIP 

recommendations, the available data set was condensed and organized by emission unit and 

pollutant/parameter. Presented in Table 4-4 is a summary of existing standards applicable to 

cotton gins and cotton seed processing that were used to develop the regulation. Where possible, 

the existing data set has been ranked from most to least stringent. Emission standards not 

correlated to a process or control parameters (e-g., lblhr and ton/yr limits) were not included in 

the evaluation. 

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Applicability 

Cotton Gins 

Monitoring & Testing Provisions 

Provide and maintain an Operation 

and Maintenance Plan for any 

emission control system (ECS), any 

other emission processing equipment, 

and any ECS monitoring devices. 

Install, maintain, and calibrate 

monitoring devices as in O&M Plan. 

Monitoring devices shall measure 

pressures, flow rates, andlor other 

operating conditions necessary to 

determine if the control devices are 

functioning properly. 

Conduct maintenance evaluation of 

control device consisting of an initial 

baseline study and monthly checks 

thereafter. 

Visually check the ECS for leaks, 

holes, and excessive visible emissions 

during each day of operation 
Table 4-4. Summary of Emission Limits and Standards: Cotton Ginning 

4.4.2 Derivation of Proposed GRIC Source Category LimitsIStandards 

The above information was used to develop the proposed regulation for cotton gins and cotton 

seed processing. The only existing regulations for this source category are established by States. 

Emission LimitslStandardslControls 

1 D-3D cyclones 

Low pressure exhausts: 

1. 2D-2D cyclone 

2. Screens with a mesh size of 70 x 70 or finer (U.S. Sieve), 

perforated condenser dnuns with holes not exceeding 0.045 

inches in diameter, or equipment of equivalent design 

High pressure exhausts: 

1. 1 D-3D cyclone or equivalent 

2. 2D-2D cyclones for existing gins, or 1D-3D cyclone if 

the capital cost to repairlreplace an existing 2D-2D cyclone 

exceeds 50% of the capital cost of a new 1 D-3D cyclone); 

ID-3D cyclone for newlmodified gins or equivalent 

Burr hoppers: 

For control during dumping, if burr hoppers at existing 

gin are located within the corporate city limits of any 

city or within 300 ft of 2 or more occupied 

establishments, they must be totally enclosed; total 

enclosures on burr hoppers at new gin sites 

Trash hopper: 

Dump trash into a hopper that shall utilize an enclosure 

with a minimum of two sides in order to minimize 

fugitive emissions. The sides of the enclosure shall 

prevent wind dispersion by ensuring that the height of the 

enclosure extends above the opening of the dumping 

device. If an auger is used to transport the trash into a 

hopper, the open end of the auger or auger sleeve shall be 

below the top of the enclosure. 

1. 520% opacity 

2. 540%, will exempt source fiom mass emissions testing 

Fugitive dust, lint, bolls, cotton seed, or other material 

emitted or lying loose in a yard shall be collected and 

disposed of in an efficient manner 

Emission 

UnitIProcess 

Cotton Seed 

Delinting 

Cotton Ginning 

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Pollutant1 

Parameter 

PMlo 

PM 

controls 

Visible 

emissions 

Fugitive 

Dust 
The State regulations are either process weight-based emission limitations or control technologybased requirements. The process weight-based regulations yield a wide variety of emission rates 

given a certain production rate. For this reason, in developing the source specific category 

regulations for the GRIC TIP, process weight-based emission limitations have been avoided. 

Consequently, the regulations for Oklahoma and Maricopa County were primarily used to 

develop the draft regulation. These two regulations are more recent and based on control 

technology requirements. 

5.0 Proposed Source Category Provisions 

Section VII, Rule C: Cotton Gin and Seed Processing 

Rule C - Avplicability 

This rule applies to all new, existing, and modified cotton gins and cotton seed processing 

operations located or locating on the Gila River Indian Reservation. 

Rule C - Definitions 

Cotton gin means any facility or plant that removes seed, lint, andlor trash from raw cotton 

andlor bales of lint cotton for further processing. 

Cotton seed processing means equipment used to fUrther process cotton seeds for use in the 

agricultural market, including that to collect trash. 

High eficiency cyclone means any cyclone type collector of the 2D-2D or 1D-3D configuration. 

These designations refer to the ratio of cylinder length to cone length, where D is the diameter of 

the cylinder portion. A 2D-2D cyclone would exhibit a cylinder length of 2xD and a cone length 

of 2xD. A 1D-3D cyclone would exhibit cylinder length of IxD and a cone length of 3xD. 

High pressure exhaust means the exhaust cotton handling air systems located at a cotton gin that 

are not defined as "low pressure exhausts." 

Low pressure exhaust means the exhaust air system at a cotton gin that handles air from the 

cotton lint handling system, battery condenser, and mote handling systems. 

Rule C - Emission Limitations and Standards 

Visible Emissions 

Visible emissions from any cotton gin or cotton seed processing shall not exceed 20% 

opacity. 

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Particulate Matter Emission Controls 

Low pressure exhausts. 

Existing sources: Use screens with a mesh size of 70 by 70 or finer (U.S. Sieve) or 

perforated condenser drums with holes not exceeding 0.045 inches in diameter or equipment 

of equivalent design efficiency. 

New or modified sources: Utilize a 2D-2D cyclone collector or equipment of equivalent 

collection efficiency upon commencement of operation. 

High pressure exhausts. 

Existing sources: Use of 2D-2D cyclones. 

New or modified sources: Utilize a 1D-3D cyclone collector or equipment of equivalent 

collection efficiency upon commencement of operation. 

Burrltrash hoppers. 

For emission control during dumping: Utilize an enclosure with a minimum of two sides in 

order to minimize fugitive emissions. The sides of the enclosure shall prevent wind 

dispersion by ensuring that the height of the enclosure extends above the opening of the 

dumping device. If an auger is used to transport the trash into a hopper, the open end of the 

auger or auger sleeve shall be below the top of the enclosure. 

Fugitive Particulate Matter Emissions 

Fugitive dust, lint, bolls, cotton seed, or other material emitted or lying loose in a yard shall 

be collected and disposed of in an efficient manner. 

Operation and Maintenance Plan for Emission Control Systems 

Submit an Operation and Maintenance Plan (O&M Plan) for emission control systems. The 

plan shall be submitted for approval within six months of the effective date of this rule. 

Rule C - Source Testing and Monitoring 

Monitoring devices for pressure, flow rate, or other operating conditions to ensure control 

device is operating properly. 

Conduct baseline evaluation of volumetric flow and conduct monthly checks. 

Visual checks of control system for leaks, holes, and excess visible emissions each day of 

operation. 

Method 9 for visible emissions. 

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Rule C - Recordkeeping and Reporting 

Daily log of hours of operation and process weight (number of bales and weight of bales, or 

weight of seeds processed). 

Replacementlrepair costs for control devices and times when the control system was not 

operating and the action taken. 

Maintenance conducted according to 0 & M Plan. 

Results of daily visual inspections and monthly flow evaluations. 

Keep records 5 years. 

6.0 References 

1 .) U.S. EPA AP-42 Fifth Edition Section 9.7, Cotton Ginning. June 1996. 

2.) U.S. EPA Emission Factor Documentation for AP-42 Section 9.7 Cotton Ginning, Final 

Report. June 1996. 

3.) RTP Environmental Associates GRIC Site Visit and Plant Tour Notes. April 3-4, 2000. 

Included in Appendix A. 

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Appendix A - Site Visit Notes, Process Diagrams, and Other Supporting Materials 

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