cotton.txt

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Cotton Gins 
February 1997

TNRCC Rule 116.111(3) in Regulation VI requires that Best Available Control Technology
(BACT) be applied to all facilities that must obtain a permit.  BACT determinations are made on
a case-by-case basis. 

How will BACT be determined in the permit review?

    The TNRCC recognizes that most cotton gins are small, seasonal businesses, and as of
     May 11, 1993, new guidelines were adopted by the Texas Air Control Board which
     outline procedures for determining BACT.  The location, compliance history, public
     comments, as well as the scope of the project will be considered when determining if gins
     are required to satisfy Baseline BACT or Baseline Plus Additional as outlined below. 
     Baseline BACT is the minimum level of control required for new gins that have an
     isolated location and have a favorable compliance history and have favorable or no
     public comments.  Expansion projects at existing gins in tighter locations  with nearby
     residences, businesses, schools, etc. (high nuisance potential) that are able to show no
     increase in emissions due to the project under review and have community acceptance
     and have a favorable compliance history will also be considered as candidates for
     Baseline BACT.  Any gins that cannot satisfy the above restrictions will be required to
     consider additional controls and justify their proposal in order to satisfy Baseline BACT
     Plus Additional.  For more details on BACT determination, see the attached summary and
     flow chart dated September 11, 1996 (the original finalization date of this document is
     May 6, 1993).  Please contact the NSRP Division at 512-239-1250 for a copy of this
     document.  

What are the minimum controls that need to be considered to satisfy Baseline BACT
requirements?

    Use of small mesh screens on all lint cleaner and battery condenser drums.
    Use of well designed, high efficiency cyclones (1D-3D or 2D-2D) on all other fan
     discharges.
    No open storage of burrs and cotton trash (augered windrows with water sprays may be
     considered on a case-by-case basis).

What additional controls should be considered and may be required for facilities that need
to propose Baseline BACT Plus Additional controls?

    In-line lint filters on all condenser discharges. 
    Large drum filters on all discharges.
    Use of high pressure fans on lint cleaners vented to cyclones.
    Reduced number of fans and air flow rates, together with adequate abatement equipment.
    Totally enclosed burr hopper dump area.
    Paved and cleaned or dust suppressant treated parking lot and traffic areas.
    Covering of all trash trucks prior to leaving the property.
    Use of Roots Blowers for conveying trash.
    Addition of drop-out (plenum) chambers prior to cyclones to improve cyclone
     efficiencies.
    Use of mechanical conveyors in lieu of fans where possible, including the conveying of
     trash to the trash hopper.
    Use of cyclones in series.

In summary, any changes or additions that are thought to be insignificant and appear that no
permit requirements are necessary should be proposed to the TNRCC for review or comments. 
Permit processing time can be greatly reduced by :
  1)  choosing an isolated location; and 
  2)  submitting a well prepared application with a completed PI-1 or PI-1R form.  Refer to
      document entitled "Supplemental Information Sheet for Cotton Gins" for more informa-
      tion on application information; and 
  3)  proposing controls that meet all BACT and Regulation I requirements.  Proposals for
      anything less should be well justified; and
  4)  sending the original application to the Austin Office, one copy of the application to the
      appropriate regional office, one copy to any appropriate local programs, and keeping
      one copy.

Activities which require public notice should be planned well in advance to allow for a permit
processing time of around 90 days.  Public involvement such as public meetings and/or public
hearings could greatly increase the processing time.