Project Summaries

11-879  Project Manager: E. M. Barnes


Michael Buser, Oklahoma State University

In 2006, the U.S. Environmental Protection Agency (EPA) lowered the limit on average PM2.5 emissions over a 24-hour period from 65 to 35 micrograms per cubic meter. Some states have set the standard much lower. This comes from a growing concern that the smallest "dust" particles pose the biggest health threat because they are small enough to penetrate deeply into peoples' lungs. PM2.5 refers to particulate matter less than 2.5 microns in diameter - 2.5 microns is about 1/30th of the thickness of a human hair. As states implement required plans to achieve federal standards and begin to regulate industries within their states as part of those plans, they face the major issue of a scarcity or, in some cases, a complete lack of data, on how much PM2.5 the various industries currently emit. Generally speaking, when regulatory agencies have limited data available, they will use estimates that are conservative on the side of protecting public health. For the cotton ginning industry, extremely limited PM2.5 is currently available. To meet current federal deadlines, states are utilizing conservative PM2.5 estimates in their state implementation plans. For example, California is currently calculating cotton gin PM2.5 emission rates as 30% of the total particulate matter emissions. For cotton gins in California, this is a major issue because they will be listed as a significant source of PM2.5 emission within the state and will be required to install additional costly abatement technologies or shut down to meet the new regulations.
This project has been part of a multi-state research team that is working closely with the cotton ginning industry and regulatory agencies across the United States. The research team includes members from: Oklahoma State University, USDA-ARS Cotton Ginning Research Laboratory in Mesilla Park, NM; USDA-ARS Cotton Ginning Research Unit in Stoneville, MS; and the USDA-ARS Cotton Production and Processing Research Unit in Lubbock, TX. The cotton gin advisory group consists of approximately 25 members from all cotton ginning associations in the United States, National Cotton Council, Cotton Incorporated, and Texas A&M University. The air quality advisory group consists of about 50 members from the National U.S. Environmental Protection Agency, EPA Region 4 (Atlanta), EPA Region 9 (San Francisco), Texas Commission on Environmental Quality, North Carolina Department of Natural Resources, Missouri Department of Natural Resources, California Air Resources Board, San Joaquin Unified Air Pollution Control District, USDA-NRCS Air Quality and Climate Change and other USDA-ARS scientists.

This highly collaborative team has conducted stack sampling tests in California, New Mexico, Texas, Missouri, and North Carolina and is on track to submit their research findings in 2012 and 2013 that will close this critical data gap. Preliminary results from the study indicate that cotton gin PM2.5 emission factors are 3 to 6% of total particulate matter emission factors. Although these preliminary results are significantly lower than the conservative California regulatory agency estimates, some cotton gins will be required to implement additional abatement technologies to meet the new regulations, but the costs will be sustainably lower.

If cotton gins are identified as a major PM2.5 emission source, they will most likely be required to install bag houses for all exhausts. The cost for installing this equipment on an average size gin is about $1,350,000 with another $100,000 in annual maintenance costs. If the PM2.5 data gap is not addressed and gins across the country are required to make these changes, it could cost the cotton ginning industry an initial $1.1 billion to make the initial modifications and $85 million per year to maintain the new equipment.

To date, the results from this project have been discussed in 39 plus newspapers and trade magazines. The data generated is being used in several state implementation plans and eventually the permits for the majority of gins in the United States will be updated based on the results of this research. Publication of the results will continue in 2013 and dissemination to federal and state regulatory offices is still in progress.


Project Year: 2012

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