Minimum cost compliance strategies for cotton gins across the US
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abstract
With increasing scrutiny from both SAPRAs and the public, the US cotton ginning industry will be forced to invest in more stringent air pollution control equipment to reduce their Allowable Emission Rate (AER). This increased investment may put an undue financial burden on a cotton gin depending upon the air pollution abatement strategy selected. An airflow model was developed that lists the approximate volume rates of flow from each of ten process system exhausts of a 'standard' gin. The 1996 AP-42 emission factors were modified to correspond to the 'standard' gin with ten exhausts. The airflow model was used in conjunction with the modified 1996 AP-42 emission factors to approximate emission concentrations from each of the exhausts. It was a premise of this research that a cotton ginner could utilize abatement systems selectively to reduce their AER by identifying the exhausts with the highest emission concentrations. After the identification of problematic exhausts, gins can approach the task of reducing their emissions with a minimum cost of compliance. In addition, states utilizing Process Weight Tables (PWT) can also utilize the airflow model to determine AERs and permitted emission factors. Source sampling data obtained from the California Air Resources Board (CARB) were used to demonstrate the utility of the procedures and to compare emission factors calculated using the air model. The procedures and models presented in this paper can assist cotton ginners across the cotton belt to comply with air pollution regulations at the minimum cost.
