Gila River Indian Community (GRIC) 

### TIP Development Source Specific Emission Limitations 

### & Standards Technical Support Document

Rule AX-Cotton Ginningand CottonSeedProcessing
1.0 Introduction & Source~escri~tion'~'~'
Information for these processes are based on Chapter 9.7 of EPA's Compilationof 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 preparethem for planting the followingyear. Cotton ginning and seed processing are seasonal. Cotton ginningbegins with the maturing of the cotton crop and ends when the crop is finished. Most ofthe 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 seedprocessing 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, reflectingthe pressures used in the air conveying systems.

09101 100Draft For internal review only1.2 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. Seedsmay 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 ofthis 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 machinepicker. 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 overheadbins and then dropped into trailers. The trash is hauled off-site and used for either animal bedding or low-grade feed. The seeds 

### are transmittedto 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 refiningis conveyed to a cyclone and collectionbin. Arizona Processing is also a cotton seed processing facility, however it is located in Maricopa County. The process is similarto the Stoneville Seed Company, although there is no lint burning operation, rather a longer residencetime in the acid bath is used to remove the lint. The facility is equippedwith 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 requirementswill need to be reevaluated if a sourceis modified.

09/01/00Draft For internal review only3.0 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 10micrometers (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, exhaustfrom each step is typicallyrouted 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 efficiencycyclones, 2D-2D and 1D-3D, which refer to the ratio of the cylinder lengthto the cone length @refers to the diameter). 

### Thus,a 1D-3Dcyclone would have a cylinder length equal to the diameter and a cone length equal to 3 times the diameter. Typically, 1D-3Dcycloneshave 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 sourcecategory emissionsand emission factors, as well as knowledge from the site visits. Table 3

### -1. Emission UnitPollutant Matrix

09/01/00 Draft For internal review only Source Subcategory Cotton Ginning

Seed Processing EmissionUnit1 Process Unloading fan Dryers and Cleaners
Overflow fan Lint Cleaners Cyclone robber system Motelmotetrash 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 104.0 Regulatory Review
4.1 Tribal ProgramsRules A comprehensive review ofU.S. tribal air qualityprograms 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 requirementsare 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 SourcePerformance Standards (NSPS)
There is no NSPS applicableto 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 applicableto 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. 112(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 quantitiesof 20,000 pounds or more, the facilitywould be subjectto the EPA accidental release prevention rule (40 CFR Part 68).

09101/00Draft For internal review onlyTable 4-1. RBLC Search Results Summary

09101/00 Draft For internal review only4.2.5 Other
No other federal air quality regulatory programs or standards were identified as applicable or potentially applicable to the cotton gin and cotton seedprocessing 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/RegionaVLocalRegulations
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 ofthis 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 Staterules.
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/standardsare summarized in Table 4-2. Table 4-2. Summary StateRule Emission Limits and Standards Applicability
Cotton Gin Operation Parameter
Emissions EmissionLimitJStandard (Units)
Maximum allowablePM emissionsbased on process weight rates (per hour) are presented in a table. Range: 1.6 lbhfor 1,000lbh process weight rate to 67.4 lbh for >60,000 lbh process weight Total process weight of all similar units employinga similar process 

### type shallbe used in determiningmaximum allowablePM emissions

0910 1/00 Draft For internal review only0910 1100Draft For internalreview only 

### 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 storagepiles. 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 530tonsper hour (tph): Maximum allowablePM emissions (lbh) 

### (E) =4.1OPO.~~ For process rates >30 tph: Maximum allowablePM emissions (lbh) (E) =55

### .oP'.' 

# '
-40, Where: P =Process weight rate (tph)
Total process weight of all similarunits employing a similar process type shall be used in determiningmaximum allowablePM 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 500pounds) 

### 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 Gins09/01 I00 Draft For internalreview only Emission LimiWtandard (Units) Opacity GO%, unless not more than one 6- minute period in any consecutive 60 minutes, not exceeding 3 in any consecutive24 hours and 160%;an alternativeopacity limit can be developed No cotton gin shall be operated as to cause or contribute to a violation of the PMloambient 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 holesnot exceeding 0.045 inches in diameter; or equipment ofequivalent design High pressure exhausts: 2D-2D cyclonesfor existing gins, or 1 D-3D cyclone ifthe capital costto repairlreplacean existing2D-2D cyclone exceeds 50% ofthe capital wst of a new 1 D-3D cyclone); 1D-3Dcyclone for newlmodified gins or equivalent Burr hopvers: For wntrol during dumping, if burr hoppers at existing gin are located within the corporatecity limits of any city or within 300 

### fi of2 ormore occupied establishments, they must be totally enclosed;total enclosures on burr hoppers at new gin sites Take reasonable precautionsto minimize atmosphericpollution from handling, transporting, or dispositionof any substance or material that is likely to be scatteredby the air or wind, or operateor maintain any gin site, open area, right-of-way, storage pile or materials, vehicle, or construction,or any other enterprisewhich involves any material or substance likely to be scatteredby the wind or air, that would be classified as air pollution; do not allowthe dischargeof any visible fugitivedust emissionsbeyond the property line Pollutant/ Parameter Visible Emissions

PMIO Emissions

PM Controls

Fugitive dust StateRule
Oklahoma Subchapter 23 Applicability New, Modified, and Existing Cotton Gins4.3.2 Summary of Identified Rules - Testing, Monitoring, Recordkeeping, & Reporting Provisions Presented in Table 4-3 is a summary of State rule monitoring, testing, recordkeeping, and reportingrequirements. 

### StateRule
South Carolina §V

Maricopa County Rule 319

09101 100Draft For internal review only 

### Pollutant/ Parameter PM Emissions

Visible Emissions Visible Emissions PM Controls 

### Applicability
Cotton Gins

Ginning Operations 

### Emission LimitIStandard (Units)
Maximum allowablePM emissionsbased on production rates arepresented in a table. Range: 12.3 lbthrfor 4 bales (lo)per hour production rate (output)to 31.2 lbh for 216 bales (10) per hour production rate (output); a bale is a finished bale weighing 500 pounds Opacity 520% Opacity <20%
Each unit fed by seed-cottonunloading, first seed-cotton cleaning and mastertrash systems - effectiveApril 7,2001 be controlledby 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 controlledby an ECS that includes a 1D-3D cyclone or equivalentdevice with at least 95% efficiency; all lowpressure exhaust emission units -no later than April 7, 2004be controlledby 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 enclosurewith a minimum of two sidesto minimize fugitive emissions, the sides ofthe enclosure shall prevent wind dispersionby ensuring that the height of the enclosure extends above the opening ofthe dumping device, if an auger is used to transport trash the open end ofthe auger or auger sleeve shall be below the top ofthe enclosureTable 4-3. Summary of State Rule Monitoring, Testing, Recordkeeping, and Reporting Provisions.

09/01/00 Draft For internal review only Recordkeeping1 Reporting Provisions N/A

Maintain a log ofthe daily process weight, hours of operation, and air emissioncontrol equipmentreplacement/ repair costs
Maintain for 2 years and make available for inspectionby 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
Referencemethods in the Arizona Testing Manual and 40 CFR 60 Appendix A, shall be used to determine complianceas follows:
Method A-2 formeasurement 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, AppendixA for visible emissions Dispersion modelingfor PMloshallbe performed using an EPA approved modeling method4.4 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 inspectionsand 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.

09101/00 Draft For internal review only Applicability
Cotton Gins Monitoring & Testing Provisions Provide and maintain an Operation and Maintenance Plan for any emission control system (ECS), any other emissionprocessing equipment, and any ECS monitoring devices. Install,maintain, and calibrate monitoring devices as in O&M Plan. Monitoring devices shall measure pressures, flowrates, andlor other operatingconditions necessary to determine ifthe 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 duringeach day of operationTable4-4. Summary ofEmission Limits and Standards: Cotton Ginning

4.4.2 DerivationofProposed GRIC Source CategoryLimitsIStandards 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 establishedby States. Emission LimitslStandardslControls
1 D-3D cyclones
Low pressure exhausts:

1. 2D-2D cyclone 2. Screenswith a mesh size of70 x 70 or finer (U.S. Sieve), perforated condenser dnunswith holes not exceeding0.045 inches in diameter, or equipmentof equivalent design High pressure exhausts:

1. 1 D-3D cycloneor equivalent 2. 2D-2D cyclones for existing gins, or 1D-3Dcyclone if the capital costto repairlreplace an existing 2D-2D cyclone exceeds 50% ofthe 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 limitsof any city or within 300 ft of 2 or more occupied establishments,they must be totally enclosed; total enclosureson burr hoppers at new gin sites
Trashhopper: Dump trash into a hopper that shall utilize an enclosure with a minimum oftwo sides in order to minimize fugitive emissions. The sides ofthe enclosure shall prevent wind dispersionby ensuring that the height ofthe enclosure extends abovethe opening ofthe dumping device. If an auger is used totransport the trash into a hopper, the open end ofthe augeror auger sleeve shallbe 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 disposedofin an efficientmanner Emission UnitIProcess Cotton Seed Delinting Cotton Ginning

09101 I00 Draft For internal review only Pollutant1 Parameter PMlo
PM controls

Visible emissions Fugitive DustThe Stateregulations are eitherprocess weight-based emission limitationsor 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 SectionVII, 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 GilaRiver 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 seedprocessing 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 designationsrefer 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-3Dcyclone would exhibitcylinder length of IxD and a cone length of 3xD. Highpressure exhaust means the exhaust cottonhandling 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 VisibleEmissions
Visible emissions from any cotton gin or cotton seed processing shall not exceed 20% opacity.

09101100Draft For internal review onlyParticulateMatter 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 equivalentdesign efficiency. New or modified sources: Utilize a 2D-2D cyclone collector or equipment of equivalent collectionefficiency upon commencementofoperation. High pressure exhausts. Existing sources: Use of 2D-2D cyclones. New or modified sources: Utilize a 1D-3D cyclone collector or equipment of equivalent collectionefficiency upon commencementofoperation.
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 ofthe enclosure.
FugitiveParticulateMatter 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 efficientmanner.
Operationand 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 ofthe effective date ofthis 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 ofvolumetric 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.

0910 1 I00 

### Draft For internalreview onlyRule C 

### - Recordkeeping and Reporting Daily log of hours of operation and process weight (number of bales and weight of bales, or weight of seedsprocessed). Replacementlrepair costs for control devices and times when the control system was not operating and the actiontaken. Maintenance conducted according to 

### 0 & M Plan. Results ofdaily 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.

09101 100

### Draft For internal review onlyAppendix A - Site VisitNotes, Process Diagrams, 

### and Other SupportingMaterials

09101

### /00Draft For internal reviewonly